Doe v. United States — CVRA Complaint Challenging NPA

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08-cv-80736-KAM JANE DOE 1 and JANE DOE 2, Petitioners, v. UNITED STATES OF AMERICA, Respondent. PETITION UNDER THE CRIME VICTIMS' RIGHTS ACT Petitioners Jane Doe 1 and Jane Doe 2, by and through undersigned counsel, respectfully petition this Court pursuant to the Crime Victims' Rights Act, 18 U.S.C. § 3771 ("CVRA"), and allege as follows: INTRODUCTION 1. This Petition challenges the United States Government's decision to secretly enter into a Non-Prosecution Agreement ("NPA") with Jeffrey E. Epstein, a serial sexual predator who abused dozens of minor girls in Palm Beach County, Florida, and elsewhere between 1999 and 2007. 2. The Government entered into the NPA without providing any notice to, or conferring with, the victims of Epstein's crimes, in direct violation of the CVRA's mandatory provisions. FACTUAL BACKGROUND 3. Beginning in approximately 1999, Epstein devised and carried out a scheme to sexually abuse minor girls by luring them to his Palm Beach residence under the pretense of paid massage work. 4. In May 2006, the FBI initiated a federal investigation into Epstein's conduct. The investigation identified more than 40 minor victims who had been sexually abused by Epstein. 5. The FBI prepared a 53-page indictment charging Epstein with multiple federal sex offenses that would have resulted in a potential life sentence upon conviction. 6. In September 2007, the Government entered into the NPA with Epstein without notifying any of the identified victims. The terms of the NPA allowed Epstein to plead guilty to two state felony charges of solicitation of prostitution and serve only 18 months in the Palm Beach County Jail. CVRA VIOLATIONS 7. Under the CVRA, crime victims have the right to reasonable, accurate, and timely notice of any public court proceeding or any parole proceeding involving the crime. 18 U.S.C. § 3771(a)(2). 8. Crime victims also have the right to be reasonably heard at any public proceeding in the district court involving sentencing or any parole proceeding. 18 U.S.C. § 3771(a)(4). 9. The Government's deliberate concealment of the NPA from the victims constituted a clear and ongoing violation of the CVRA. PRAYER FOR RELIEF WHEREFORE, Petitioners respectfully request that this Court: (a) declare that the Government violated the CVRA; (b) order the Government to provide notice to all identified victims; and (c) grant such further relief as the Court deems just and proper. Filed: July 7, 2008 Source: U.S. District Court, S.D. Florida — PACER Available at: https://www.courtlistener.com/docket/4355912/doe-v-united-states/