EFTA00010542.pdf

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Case 9:08-cv-80736-KAM Document 462 Entered on FLSD Docket 06/24/2019 Page 1 of 32 
IN THE UNITED STATES DISTRICT COURT 
FOR THE SOUTHERN DISTRICT OF FLORIDA 
JANE DOE 1 AND JANE DOE 2, 
Civil Action No. 
PETITIONERS, 
V. 
UNITED STATES OF AMERICA, 
RESPONDENT. 
08-80736-CIV-MARRA 
• 
Government's Response to Petitioners' Submission on Proposed Remedies 
The United States of America, by Byung J. Pak, United States Attorney for the 
Northern District of Georgia, and Jill E. Steinberg and Nathan P. Kitchens, 
Special Attorneys for the Southern District of Florida, files this response to 
Petitioners' proposed remedies. 
INTRODUCTION 
The question before this Court is what remedies, if any, should be accorded 
Petitioners under the Crime Victims Rights Act (CVRA) based on this Court's 
finding that the government failed to confer with Petitioners prior to entering 
into a non-prosecution agreement (NPA) with Jeffrey Epstein? Petitioners seek 
1 This Court previously found that Petitioners are crime victims under the 
CVRA; a crime victim's rights under the CVRA attach before the 
government brings formal charges against a defendant; the CVRA's 
"reasonable right to confer" extends to conferring about non-prosecution 
agreements; the CVRA authorizes the rescission of a non-prosecution 
agreement reached in violation of a prosecutor's conferral obligations; and 
the government violated the CVRA by failing to advise the victims that it 
intended to enter into the NPA with Epstein. The government will not 
EFTA00010542


Case 9:08-cv-80736-KAM Document 462 Entered on FLSD Docket 06/24/2019 Page 2 of 32 
what they call "rescission remedies," "apology remedies," "informational 
remedies," "educational remedies," and "miscellaneous remedies" — all of which 
constitute equitable relief, and none of which is authorized by the CVRA. But 
even if the statute did allow equitable relief, Petitioners are not entitled to the 
specific relief they are seeking. 
Nevertheless, the gover…
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