Case 9:08-cv-80736-KAM Document 253 Entered on FLSD Docket 05/23/2014 Page 1 of 12 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRa JANE DOE #1 and JANE DOE #2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant INTERVENORS' REPLY To JANE DOES' RESPONSE OPPOSING A PROTECTIVE CONFIDENTIALITY ORDER INTRODUCTION Given that the parties are first focused on litigating the circumstances regarding whether there was a sanctionable violation of the CVRA, the portion of the correspondence authored by Epstein's counsel to the government, foreseeably, is irrelevant to the resolution of this issue for it was only the government, not Epstein, who had obligations under the statute. The theory that Epstein was responsible for the government's construction and implementation of the CVRA is addressed herein. In short, it is neither rational nor true to suggest that the U.S. Attorney and then the Department of Justice — which extensively reviewed the non-prosecution agreement ("NPA") during the months between its September 2007 execution and its June 30, 2008 finalization with Epstein's state plea — were acting, during this time period or during any other, improperly or corruptly or were engaged in a "deliberate conspiracy" in any way by advocating, in this case and on a nationwide basis, the same construction of the CVRA that Epstein's counsel were also advocating. The Plaintiffs' repeated accusation that the Department EFTA02754835