Case 9:08-cv-80736-KAM Document 416 Entered on FLSD Docket 08/11/2017 Page 1 of 65 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08-cv-80736-ICAM JANE DOE 1 AND JANE DOE 2, Petitioners, v. UNITED STATES, Respondent. JANE DOE 1 AND JANE DOE 2'S RESPONSE IN OPPOSITION TO THE GOVERNMENT'S MOTION FOR SUMMARY JUDGMENT Jane Doe 1 and Jane Doe 2 (also referred to as "the victims"), by and through undersigned counsel, pursuant to Fed. R. Civ. P. 56 and Local Rule 56.1, file this response in opposition the Government's Cross-Motion for Summary Judgment (DE 401-2). In support, they state: I. INTRODUCTION As the victims explained in their motion for summary judgment (DE 361), the undisputed facts of this case show that for nine months, the Government and Epstein conspired to conceal a non-prosecution agreement (NPA) from Epstein's victims in order to prevent them from voicing any objection to the agreement. These facts constitute proof of clear violations of the Crime Victims' Rights Act (CVRA), warranting summary judgment on that point and moving the case forward to a consideration of what remedy is available for those violations. 1 EFTA02757823