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Case 1:20-cr-00330-PAE Document672 Filed 06/24/22 Page 3 of 68 LAW OFFICES OF BOBBI C. STERNHEIA\ The CVRA Applies Only to Federal Crimes Based on the text, origin and limited legislative history, the CVRA applies to victims of federal crimes only. 18 U.S.C. § 3771(e). The federal crimes of conviction require the involvement of minors. The Individuals claiming sexual abuse who were not minors may qualify generically as victims of sexual abuse but not as statutory victims of the federal offenses of conviction. The Individuals Are Not "Victims" of the Counts of Conviction Neither the Superseding Indictment nor the Court’s jury instructions support a position that anyone who was not a minor is a "victim" of the counts of conviction. The involvement of a minor is an essential element of the federal offense conduct. Maria Farmer claims she was abused during the time period of the indictment; however, she was not a minor. Sarah Ransome was not a minor when she claims she interacted with Epstein and Ms. Maxwell from approximately October 2006 to April 2007, a full two years after the conduct in this case ended. Teresa Helm also was not a minor and it is unknown when she claims to have had contact with Epstein and Ms. Maxwell. It is unknown whether Juliette Bryant was a minor or when she claims to have had contact with Epstein and Ms. Maxwell. None of these Individuals testified at trial and their credibility remains unexamined. Regarding the charges in this case, they do not qualify as victims under the CVRA. The Individuals Are Not "Victims" Within the Meaning of the CVRA For the Individuals to invoke the rights enumerated under the CVRA, they must first be determined to be "victims" within the meaning of the statute. The CVRA defines a “crime victim” as “a person directly and proximately harmed as a result of the commission of a Federal offense or an offense in the District of Columbia.” 18 U.S.C. 3771(e)(2)(A) (emphasis added). DOJ-OGR-00010594