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10 akat cae As} 14 15 16 17 Ve) 1) 20 21 AA 23 24 25 Case 1:15-cv-07433-LAP Document 1332-2 Filed 01/08/24 Page 13 of 42 12 XGAQGIUc SEALED in Florida that the "ultimate aim of the action in Florida is to invalidate a non-prosecution agreement and allow criminal Promecution. Our position, as we tried to articulate it for over seven years, and this is testimony from Mr. Cassell ina related case that he was a party to and gave a deposition in, and he goes on and says that "The action CVRA, the crime victims action, is ancillary to a contemplated criminal prosecution of Jeffrey Epstein for women who were resisting him in international sex trafficking. So that's the goal of the plaintiff's counsel in this case while representing two other young women in a different case down in Florida. They want to nullify the limited protection Mr. Epstein has. It's protection in Florida, but again, Ms. Giuffre's allegations are that the offenses were committed by both the defendant and Mr. Epstein in four or five other locations, some foreign, some domestic. Mr. Cassell -- even though we strongly believe that Mr. Epstein who went to jail, served time, was on probation and lived up to all his conditions of this non-prosecution agreement, we strongly believe it would be unconstitutional to invalidate it, but the truth is that Judge Marra in the June 19, 2003 opinion, we cited it to your Honor, it's docket entry 189 in that case, and it now has a West citation that I believe is 950 F. Supp.2d, has said that he believes that the SOUTHERN DISTRICT REPORTARS 0 PCy (212) 805-0300