Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 1 of 42 RT UNITED STATES DISTRICT COU A SOUTHERN DISTRICT OF FLORID a Case No. 08-80736-Civ-Marr JANE DOE #1 and JANE DOE #2 v. UNITED STATES IONS OF MOTION FOR FINDING OF VIOLAT JANE DOE #1 AND JANE DOE #2'S G ON RIN HEA ACT AND REQUEST FOR A THE CRIME VICTIMS' RIGHTS APPROPRIATE REMEDIES COME NOW Jane Doe #1 and Jane Doe through undersigned counsel, to move #2 (also referred to as "the victims"), for a finding from this Court that the by and victims' rights under ted by the U.S. , 18 U.S.C. § 3771, have been viola the Crime Victims Rights Act (CVRA) ring on the appropriate remedies for Attorney's Office, and to request a hea The victims have proffered a series of e contest. Proceeding on the basis of thes these violations. facts to the Government, which they have failed to 's Office has facts,' it is clear that the U.S. Attorney er with A rights, including their right to conf d CVR repeatedly violated the victims' protecte prosecutors generally about the case tion agreement the and specifically about a non-prosecu l as their right to fair treatment. wel Office signed with the defendant, as See 18 U.S.C. 3771(a)(5) & (8). . Attorney's ple, that in September 2007, the U.S It is now beyond dispute, for exam secution agreement with Jeffrey Office formally signed a non-pro filing a The victims are contemporaneously Epstein that barred his motion to have their facts accepted by the Court. EFTA02752979