EFTA00013570.pdf

Type: pdf
Source set: data-set-8
Extracted text

Case 9:08-cv-80736-KAM 
Document 19 
Entered on FLSD Docket 08/01/2008 
Page 1 of 16 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-80736-CIV-MARRA/JOHNSON 
JANE DOE #1 AND JANE DOE #2, 
Petitioners, 
v. 
UNITED STATES OF AMERICA, 
Respondent. 
VICTIMS' RESPONSE TO GOVERNMENT'S "NOTICE TO COURT' REGARDING 
ABSENCE OF NEED FOR EVIDENTIARY HEARING" AND MOTION FOR 
PRODUCTION OF NON-PROSECUTION AGREEMENT AND OF REPORT OF 
INTERVIEW 
COME NOW the Petitioners, Jane Doe #1 and Jane Doe #2 (the "victims"), by and 
through their undersigned attorneys to file this Response to the Government's document styled as 
"Notice to Court Regarding Absence of Need for Evidentiary Hearing" as follows: 
INTRODUCTION 
At the conclusion of the oral argument on the victims' petition, victims Jane Doe #1 and 
Jane Doe #2 joined the Government in expressing to the Court a desire to work out a set of 
stipulated facts regarding this case. Towards that end, the Government sent a proposed set of 
stipulated facts to the victims' counsel (Exhibit 1 to this pleading) and, in turn, the victims' sent 
a responsive letter raising concerns about some of the Government's proposed stipulated facts 
and suggesting some additions and modifications (Exhibit 2 to this pleading). The victims also 
requested copies of two relevant documents from the Government: (1) the Non-Prosecution 
1 
EFTA00013570


Case 9:08-cv-80736-KAM 
Document 19 
Entered on FLSD Docket 08/01/2008 
Page 2 of 16 
Agreement with defendant Epstein that is at the center of this litigation and (2) the FBI's report 
of interview concerning a meeting with Jane Doe #1. These requests were also made in several 
telephone conversations with the attorney for the Government. Remarkably, rather than respond 
to the victims' suggestions, the Government has now suddenly reversed course and filed a terse 
document claiming an "absence of a need" for an evidentiary hearing. If anything, however, the 
victims' discussions w…
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