{
  "document_metadata": {
    "page_number": "271",
    "document_number": "293-1",
    "date": "05/25/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 271 of 349\n\nthe 2005 Guidelines was inconsistent with positions the USAO had taken in correspondence with Epstein's attorneys, in which the government acknowledged that \"it had obligations to notify the victims.\" The court ordered the parties to submit additional briefs regarding the appropriate remedies. Accordingly, the petitioners requested multiple specific remedies, including rescission of the NPA; a written apology to all victims from the government; a meeting with Acosta, Villafaña, and her supervisors; access to government records, including grand jury materials; training for USAO employees; and monetary sanctions and attorneys' fees.387\n\nFollowing Epstein's indictment on federal charges in New York and subsequent death while in custody, on September 16, 2019, the district judge presiding over the CVRA case denied the petitioners' motion for remedies and closed the case, stating that Epstein's death \"rendered the most significant issue that was pending before the Court, namely, whether the Government's violation of Petitioners' rights under the CVRA invalidated the NPA, moot.\"388 The court did not order the government to take corrective measures, but stated that it \"fully expects the Government will honor its representation that it will provide training to its employees about the CVRA and the proper treatment of crime victims.\"389 The court also denied the petitioners' request for attorneys' fees, finding that the government did not act in bad faith, because, \"[a]lthough unsuccessful on the merits of the issue of whether there was a violation of the CVRA, the Government asserted legitimate and legally supportable positions throughout this litigation.\"\n\nOn September 30, 2019, Wild appealed the district court's rejection of the requested remedies, through a Petition for a Writ of Mandamus filed with the U.S. Court of Appeals for the Eleventh Circuit.390 In its responsive brief, the government expressed sympathy for Wild and \"regret[] [for] the manner in which it communicated with her in the past.\"391 Nevertheless, the government argued that, \"as a matter of law, the legal obligations under the CVRA do not attach prior to the government charging a case\" and thus, \"the CVRA was not triggered in SDFL because no criminal charges were brought.\"392 The government conceded, however, that with regard to the New York prosecution in which Epstein had been indicted, \"[p]etitioner and other Epstein\n\n387 Doe, Jane Doe 1 and Jane Doe 2's Submission on Proposed Remedies (May 23, 2019).\n388 Doe, Opinion and Order (Sept. 16, 2019). Among other things, the court rejected the petitioners' contention that it did not address whether the government had violated the victims' CVRA right to be treated with fairness and to receive fair notice of the proceedings, noting that \"[t]hese rights all flow from the right to confer and were encompassed in the Court's ruling finding a violation of the CVRA.\"\n389 The Department's Office of Legal Programs provided a training entitled Crime Victims' Rights in the Federal System to the USAO on January 10, 2020.\n390 See In re Wild, No. 19-13843, Petition for a Writ of Mandamus Pursuant to the Crime Victims' Rights Act, 18 U.S.C. § 3771(d)(3) (Sept. 30, 2019).\n391 Wild, Brief of the United States of America in Response to Petition for Writ of Mandamus Under the Crime Victims Rights Act at 14 (Oct. 31, 2019). As previously noted, at this point, the litigation was being handled by the U.S. Attorney's Office for the Northern District of Georgia.\n392 The government also noted that although the CVRA was amended in 2015 to include a victim's right to be notified in a timely manner of plea bargains and deferred prosecution agreements, \"the amendment did not extend to non-prosecution agreements\" which, unlike plea agreements and deferred prosecution agreements, do not require court involvement.\n\n244\nDOJ-OGR-00004568",
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    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 271 of 349",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "the 2005 Guidelines was inconsistent with positions the USAO had taken in correspondence with Epstein's attorneys, in which the government acknowledged that \"it had obligations to notify the victims.\" The court ordered the parties to submit additional briefs regarding the appropriate remedies. Accordingly, the petitioners requested multiple specific remedies, including rescission of the NPA; a written apology to all victims from the government; a meeting with Acosta, Villafaña, and her supervisors; access to government records, including grand jury materials; training for USAO employees; and monetary sanctions and attorneys' fees.387",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Following Epstein's indictment on federal charges in New York and subsequent death while in custody, on September 16, 2019, the district judge presiding over the CVRA case denied the petitioners' motion for remedies and closed the case, stating that Epstein's death \"rendered the most significant issue that was pending before the Court, namely, whether the Government's violation of Petitioners' rights under the CVRA invalidated the NPA, moot.\"388 The court did not order the government to take corrective measures, but stated that it \"fully expects the Government will honor its representation that it will provide training to its employees about the CVRA and the proper treatment of crime victims.\"389 The court also denied the petitioners' request for attorneys' fees, finding that the government did not act in bad faith, because, \"[a]lthough unsuccessful on the merits of the issue of whether there was a violation of the CVRA, the Government asserted legitimate and legally supportable positions throughout this litigation.\"",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "On September 30, 2019, Wild appealed the district court's rejection of the requested remedies, through a Petition for a Writ of Mandamus filed with the U.S. Court of Appeals for the Eleventh Circuit.390 In its responsive brief, the government expressed sympathy for Wild and \"regret[] [for] the manner in which it communicated with her in the past.\"391 Nevertheless, the government argued that, \"as a matter of law, the legal obligations under the CVRA do not attach prior to the government charging a case\" and thus, \"the CVRA was not triggered in SDFL because no criminal charges were brought.\"392 The government conceded, however, that with regard to the New York prosecution in which Epstein had been indicted, \"[p]etitioner and other Epstein",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "387 Doe, Jane Doe 1 and Jane Doe 2's Submission on Proposed Remedies (May 23, 2019).\n388 Doe, Opinion and Order (Sept. 16, 2019). Among other things, the court rejected the petitioners' contention that it did not address whether the government had violated the victims' CVRA right to be treated with fairness and to receive fair notice of the proceedings, noting that \"[t]hese rights all flow from the right to confer and were encompassed in the Court's ruling finding a violation of the CVRA.\"\n389 The Department's Office of Legal Programs provided a training entitled Crime Victims' Rights in the Federal System to the USAO on January 10, 2020.\n390 See In re Wild, No. 19-13843, Petition for a Writ of Mandamus Pursuant to the Crime Victims' Rights Act, 18 U.S.C. § 3771(d)(3) (Sept. 30, 2019).\n391 Wild, Brief of the United States of America in Response to Petition for Writ of Mandamus Under the Crime Victims Rights Act at 14 (Oct. 31, 2019). As previously noted, at this point, the litigation was being handled by the U.S. Attorney's Office for the Northern District of Georgia.\n392 The government also noted that although the CVRA was amended in 2015 to include a victim's right to be notified in a timely manner of plea bargains and deferred prosecution agreements, \"the amendment did not extend to non-prosecution agreements\" which, unlike plea agreements and deferred prosecution agreements, do not require court involvement.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "244",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004568",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein",
      "Acosta",
      "Villafaña",
      "Wild",
      "Jane Doe 1",
      "Jane Doe 2"
    ],
    "organizations": [
      "USAO",
      "Department's Office of Legal Programs",
      "U.S. Court of Appeals for the Eleventh Circuit",
      "U.S. Attorney's Office for the Northern District of Georgia"
    ],
    "locations": [
      "New York",
      "SDFL",
      "Georgia"
    ],
    "dates": [
      "2005",
      "September 16, 2019",
      "September 30, 2019",
      "May 23, 2019",
      "January 10, 2020",
      "2015",
      "Oct. 31, 2019",
      "05/25/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "293-1",
      "271",
      "349",
      "19-13843",
      "DOJ-OGR-00004568"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the Epstein case, discussing the CVRA and the government's obligations to victims. The text is mostly printed, with some footnotes and citations. There are no visible stamps or handwritten text."
}