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Case 1:15-cv-07433-LAP Document 1330-1 Filed 01/05/24 Page 2 of 13 THE FLORIDA CRIME VICTIMS RIGHTS ACT CASE 4. Since July 2008, I have been involved in important and precedent-setting crime victims’ rights litigation in the Southern District of Florida trying to protect the rights of various victims under the Crime Victims’ Rights Act (CVRA), 18 U.S.C. § 3771. Along with Florida co-counsel Bradley J. Edwards, I have been pursuing a federal case pro bono on behalf of two young women who were sexually abused as underage girls by Dershowitz’s close personal friend — Jeffrey Epstein. 5. On July 7, 2008, Mr. Edwards filed an emergency petition to enforce the rights of “Jane Doe No. 1” and “Jane Doe No. 2” under the CVRA, 18 U.S.C. § 3771, alleging that the Government had failed to provide them rights with regard to a plea arrangement it was pursuing with Epstein. DE 1, Jane Doe No. | and Jane Doe No. 2 v. United States, No. 9:08-cv-80736 (S.D. Fla.). As the case developed, it became clear that the U.S. Attorney’s Office for the Southern District of Florida had concealed from Epstein’s victims a non-prosecution agreement (NPA) that they had reached with Epstein. 6. During the litigation, Mr. Edwards and I have won several important victories for our clients, including a ruling that the CVRA can apply to protect crime victims’ rights even before an indictment is filed. See Paul G. Cassell, Nathanael J. Mitchell & Bradley J. Edwards, Crime Victims’ Rights During Criminal Investigations? Apply the Crime Victims’ Rights Act Before Criminal Charges are Filed, 104 J. CRIM. L. & CRIMINOLOGY 58, 67-69 (2014) (describing litigation concerning Epstein). 7. In the course of that case, on October 11, 2011, the victims filed discovery requests with the Government, including requests specifically seeking information about ' In this section of the Declaration, all references to docket entries will be to CVRA case in the Southern District of Florida, No. 9:08-cv-80736. 2