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Case 1:15-cv-07433-LAP Document 1320-18 Filed 01/03/24 Page 9 of 40 FACTUAL BACKGROUND The CVRA Case The facts relevant to this issue begin in 2008, when attorney Bradley J. Edwards (soon joined by co-counsel Professor Paul Cassell) filed a pro bono action in the Southern District of Florida under the Crime Victims’ Rights Act (CVRA), 18 U.S.C. § 3771. Filed on behalf of Jane Doe | (and later Jane Doe 2) the CVRA action alleged that federal government had failed to protect the rights of Jane Doe | and other similarly situated victims of sex offenses committed by Jeffrey Epstein. See Declaration of Sigrid McCawley (“McCawley Decl.’”) at Exhibit 1, Complaint filed in Jane Doe 1 v. United States, No. 9:08-cv-80736 (S.D. Fla. July 7, 2008). Jane Does | and 2 achieved many victories in the case, including a ruling that the CVRA rights of victims could apply before charges were filed, Does I and 2 v. United States, 817 F.Supp.2d 1337 (S.D. Fla. 2011);' that they had standing to challenge the non-prosecution agreement reached between the Government and Epstein, Jane Does I and 2 v. United States, 950 F.Supp.2d 1262 (S.D. Fla. 2013); and that plea negotiations were not protected from disclosure by any federal rule of evidence, Does v. United States, 749 F.3d 999 (11" Cir. 2014). Congress has also followed the developments in the case closely, recently amending the CVRA to insure that in the future crime victims receive notice of any non-prosecution agreement entered into by the Government. See Pub. L. 114-22, Title L § 113(a), (c)(1), May 29, 2015, 129 Stat. 240, 241 (adding 18 U.S.C. § 3771(a)(9) to give crime victims “[t]he right to be informed in a timely manner of any plea bargain or deferred prosecution agreement). ' See generally Paul G. Cassell, Nathanael J. Mitchell & Bradley J. Edwards, Crime Victims’ Rights During Criminal Investigations? Applying the Crime Victims’ Rights Act before Criminal Charges are Filed, 104 J. CRIM. L. & CRIMINOLOGY 59 (2014).