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Case 1:15-cv-07433-LAP Document 1331-4 Filed 01/05/24 Page 10 of 21 case. Several months later, Judge Marra denied Ms. Giuffre’s motion. See April 7, 2015, Order Denying Petitioners’ Motion to Join under Rule 21 and Motion to Amend under Rule 15, Jane Doe No. #1 and #2 v. United States, No. 9:08-cv-80736-KAM, S.D. Fla. at DE 280 and DE 324. This ruling alone eliminates any duty that even arguably could have attached to Ms. Giuffre in 2013 — any contemplated litigation simply never later materialized. But, in any event, any duty that Ms. Giuffre may have had related to the CVRA case would have run to the sole defendant in that case — the U.S. Attorney’s Office. The Office had years earlier (in 2008) identified Ms. Giuffre as a protected “victim” of Jeffrey Epstein’s sex abuse, even mailing to Ms. Giuffre a notice of her rights as a crime victim under the CVRA. See Schultz Dec. at Exhibit 1, Victim Notification Letter. Accordingly, Ms. Giuffre’s status as a “victim” could never have been an issue in the CVRA case. The limited issue in the CVRA case is whether the Government properly discharged its duties to the victims to confer with them and notifying them of the non-prosecution agreement it signed with Jeffrey Epstein. The journal could only have related to issues about Ms. Giuffre’s victimization, and thus even in the unrelated CVRA case, which Ms. Giuffre was not allowed to join, the journal was not relevant. Beyond these problems for Defendant’s argument here, in 2014 the only duty that Ms. Giuffre could have had would have been to the U.S. Attorney’s Office. That Office presumably would have encouraged Ms. Giuffre to undertake whatever steps were needed to facilitate her healing from the terrible crimes Epstein and his co-conspirators inflicted on her. See 18 U.S.C. § 3771(a)(8) (requiring federal government to treat crime victims “with fairness and with respect for the victim’s dignity and privacy’). Defendant’s claim here necessarily requires that Defendant step into the Government’s shoes to establish a breach of duty. Ms. Giuffre has