{
  "document_metadata": {
    "page_number": "6",
    "document_number": "9:08-cv-01339-KAM Document 209 Filed 07/06/19 Page 6 of 20",
    "date": "07/06/2019",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 9:08-cv-01339-KAM Document 209 Filed 07/06/19 Page 6 of 20 contract.\"); Lomayaktewa v. Hathaway, 520 F.2d 1324, 1325 (9th Cir. 1975) (\"No procedural principle is more deeply imbedded in the common law than that, in an action to set aside a lease or a contract, all parties who may be affected by the determination of the action are indispensable.\"); see also National Licorice Co. v. NLRB, 309 U.S. 350, 362 (1940) (\"It is elementary that it is not within the power of any tribunal to make a binding adjudication of the rights in personam of parties not brought before it by due process of law.\").5 Additionally, a \"favorable ruling\" from this Court will not provide Petitioners with anything for the alleged CVRA violations that is not already available to them. For the due process reasons already discussed above, the United States must legally abide by the terms of the Non-Prosecution Agreement even if this Court should somehow set the agreement aside for Petitioners to consult further with the government attorney handling the case. Moreover, as will be explained in greater detail below, see infra at 8-12, Petitioners already have the present ability to confer with an attorney for the government about a federal criminal case against Epstein - whether or not the Non-Prosecution Agreement is set aside - because the investigation and potential federal prosecution of Epstein for crimes committed against the Petitioners and others remains a legally viable possibility.6 The present proceedings under the CVRA must accordingly be dismissed for lack of standing because Petitioners simply have no injury that is likely to be redressed by a favorable ruling in these proceedings. See, e.g., Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006) (holding that there was no standing where it was speculative that remedy that Plaintiff sought 5 Significantly, it is Epstein's contractual rights under the non-prosecution agreement that Petitioners seek to void through these proceedings. 6 Petitioners' present, as well as past, ability to confer with an attorney for the government also demonstrates that Petitioners fail to satisfy the first two prongs of the standing test: Petitioners have simply not suffered a concrete injury that is fairly traceable to the challenged government conduct. 5 DOJ-OGR-00000310",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 9:08-cv-01339-KAM Document 209 Filed 07/06/19 Page 6 of 20",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "contract.\"); Lomayaktewa v. Hathaway, 520 F.2d 1324, 1325 (9th Cir. 1975) (\"No procedural principle is more deeply imbedded in the common law than that, in an action to set aside a lease or a contract, all parties who may be affected by the determination of the action are indispensable.\"); see also National Licorice Co. v. NLRB, 309 U.S. 350, 362 (1940) (\"It is elementary that it is not within the power of any tribunal to make a binding adjudication of the rights in personam of parties not brought before it by due process of law.\").5",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Additionally, a \"favorable ruling\" from this Court will not provide Petitioners with anything for the alleged CVRA violations that is not already available to them. For the due process reasons already discussed above, the United States must legally abide by the terms of the Non-Prosecution Agreement even if this Court should somehow set the agreement aside for Petitioners to consult further with the government attorney handling the case. Moreover, as will be explained in greater detail below, see infra at 8-12, Petitioners already have the present ability to confer with an attorney for the government about a federal criminal case against Epstein - whether or not the Non-Prosecution Agreement is set aside - because the investigation and potential federal prosecution of Epstein for crimes committed against the Petitioners and others remains a legally viable possibility.6",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The present proceedings under the CVRA must accordingly be dismissed for lack of standing because Petitioners simply have no injury that is likely to be redressed by a favorable ruling in these proceedings. See, e.g., Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006) (holding that there was no standing where it was speculative that remedy that Plaintiff sought",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "5 Significantly, it is Epstein's contractual rights under the non-prosecution agreement that Petitioners seek to void through these proceedings.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "6 Petitioners' present, as well as past, ability to confer with an attorney for the government also demonstrates that Petitioners fail to satisfy the first two prongs of the standing test: Petitioners have simply not suffered a concrete injury that is fairly traceable to the challenged government conduct.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "5",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00000310",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Lomayaktewa",
      "Hathaway",
      "Epstein"
    ],
    "organizations": [
      "NLRB",
      "DOJ"
    ],
    "locations": [],
    "dates": [
      "07/06/2019",
      "1975",
      "1940",
      "2006"
    ],
    "reference_numbers": [
      "9:08-cv-01339-KAM",
      "520 F.2d 1324",
      "309 U.S. 350",
      "470 F.3d 1014",
      "DOJ-OGR-00000310"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a case involving Jeffrey Epstein and alleged CVRA violations. The text is mostly printed, with some footnotes and a header/footer. There are no visible stamps or handwritten text."
}