EFTA00027776.pdf

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pdf

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data-set-8

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Case 9:08-cv-80736-KAM Document 452 Entered on FLSD Docket 05/10/2019 Page 1 of 22 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 9:08-ev-80736-ICAM 
JANE DOE 1 AND JANE DOE 2, 
Petitioners, 
v. 
UNITED STATES, 
Respondent. 
JANE DOE 1 AND JANE DOE 2'S POSITION ON THE PROCEDURES TO BE 
FOLLOWED TO DETERMINE A REMEDY FOR THE GOVERNMENT'S 
VIOLATION OF THE CRIME VICTIMS' RIGHTS ACT 
Jane Doe 1 and Jane Doe 2 (also referred to as "the victims"), by and through 
undersigned counsel, now file their position regarding the procedures to be followed to 
determine a remedy for the Government's violation of the Crime Victims' Rights Act (CVRA). 
For the reasons explained below, the Court should direct the Government to begin the process by 
first publicly announcing what remedy (if any) it proposes as appropriate given this Court's 
finding that the rights of Jane Doe 1 and 2 were violated. Thereafter, Jane Doe 1 and 2 will file a 
response, including (if necessary) proposing further remedies. Further cross-briefing could 
follow, assuring all parties (including intervenor Jeffrey Epstein) a chance to place their views 
before the Court. This approach would place the Court in a position to rule expeditiously. While 
the Government opposes having to disclose its proposed remedies first, this approach of 
requiring the Government to initiate remedial action for the violation of the Jane Doe 1 and 2's 
1 
EFTA00027776


Case 9:08-cv-80736-KAM Document 452 Entered on FLSD Docket 05/10/2019 Page 2 of 22 
rights is consistent with the CVRA's language and goals. It is also the best way to bring this 
decade-old litigation to a prompt conclusion. 
RELEVANT BACKGROUND 
As the Court is aware, Jane Doe 1 and 2 filed this action in 2008, alleging a violation of 
their rights. The focus of concern in this case has recently shifted from whether the Government 
violated Jane Doe 1 and 2's CVRA rights to how to remedy that now-proven violation. As the 
Court is aware, …

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