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Correspondence · July 25, 2019

Email from victims' counsel on CVRA remedies briefing in Florida case, July 2019

Date: Thu, 25 Jul 2019 17:01:20 +0000

Attachments: VICTIMS_Reply_to_Epstein_Filed_Pacer.pdf; EPSTEIN_Motionfor Sur Reply.pdf

HIM,

I wanted to make you aware of a recent filing (on Tuesday) by Jane Doe 1 and 2 in the Florida CVRA case. See attached. You may find interesting our argument at pp. 3-6, in which we explain why Judge Marra must craft remedies in the case that relate solely to Florida crimes and Florida victims … because the NPA only covers Florida.

We filed our reply brief on remedies on Tuesday— and that should have brought all briefing on remedies for the CVRA violation to a close. But yesterday Epstein’s lawyer (Marty Weinberg) filed a motion for a sur-reply. See attached. In point (a) on page 2, he argues that he should have an opportunity to file a sur-reply discussing, among other things, the scope of the NPA. On Monday, we will be filing an opposition to Weinberg extending the briefing further. It appears that Judge Marra is poised to rule rapidly on the motion for a sur-reply, as he asked for us to respond quickly.

I wanted to make you aware of these developments. My clients were told back in 2013 that the NPA did not extend to New York or other jurisdictions — and that is the point we are making to Judge Marra.

for Jane Doe 1 and 2

You can access my publications on

CONFIDENTIAL: This electronic message • along with any/all attachments • is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. is admitted to the Utah State Bar, but not the bars of other states. Any views he expresses in this email are his own.

Email from victims' counsel on CVRA remedies briefing in Florida case, July 2019

Emails and letters

DOJ Epstein Files, Data Set 8 · July 25, 2019

Date: Thu, 25 Jul 2019 17:01:20 +0000 Attachments: VICTIMS Reply to Epstein Filed Pacer.pdf; EPSTEIN Motionfor Sur Reply.pdf HIM, I wanted to make you aware of a recent filing (on Tuesday) by Jane Doe 1 and 2 in the Florida CVRA case. See attached. You may find interesting our argument at pp. 3-6, in which we explain why Judge Marra must craft remedies in the case that relate solely to Florida crimes and Florida victims ... because the NPA only covers Florida. We filed our reply brief on remedies on Tuesday— and that should have brought all briefing on remedies for the CVRA violation to a clos…