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Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 44 of 50 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 Epstein’s plea negotiations were not protected from disclosure by any federal rule of evidence, Does v. United States, 749 F.3d 999 (11th 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 I, § 113(a), (c)(1), May 29, 2015, 129 Stat. 240, 241 (adding 18 U.S.C. § 3771(a)(9) to give victims “[t]he right to be informed in a timely manner of any plea bargain or deferred prosecution agreement). With regard to communications by Ms. Giuffre’s attorneys, this request seeks clearly privileged materials, because Ms. Giuffre’s attorneys represent not only Ms. Giuffre (Jane Doe 3) in the CVRA matter, but also Jane Doe 1, Jane Doe 2, and Jane Doe 4. Any communications between the four Jane Does, via Ms. Giuffre’s attorneys, plainly would be subject to attorney- client protection, joint prosecution protection, and work product protection as well. With regard to contact with “witnesses,” the request is vague, unduly burdensome, and overbroad. The CVRA case centers on issues surrounding whether the U.S. Government failed to confer and otherwise protect the rights of victims (including Janes Does 1, 2, 3, and 4) during plea negotiations with Jeffrey Epstein. Accordingly, some of the main “witnesses” in the case are the Government prosecutors who handled the plea negotiations. Several of the same prosecutors who handled the plea negotiations are also involved in defending the CVRA case. The CVRA has been in litigation for nearly eight years, and there have extensive communications with the prosecutors (including communications concerning approximately 10,000 pages of documents that were requested by victims’ counsel and provided to Judge Marra for in camera review). The 38