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Courtney Wild

Courtney Wild is an Epstein survivor who, as Jane Doe 1, brought the 2008 Crime Victims' Rights Act challenge to his non-prosecution agreement, which ended when the Supreme Court denied review in 2022.

Courtney Wild is an American survivor of Jeffrey Epstein's abuse who, under the pseudonym Jane Doe 1, filed the July 2008 emergency petition under the Crime Victims' Rights Act that became Doe v. United States. The litigation established in 2019 that federal prosecutors had violated her right to confer by concealing the Epstein non-prosecution agreement, but produced no remedy: the en banc Eleventh Circuit held in 2021 that the statute gave her no way to enforce the right, and the Supreme Court of the United States declined review in February 2022. A proposed amendment to the Act bears her name.1234

The Federal Investigation

According to Edwards, Wild was 14 when Epstein sexually coerced her at his house in Palm Beach. On or about June 7, 2007, FBI agents delivered to her a standard victim notification letter promising the Justice Department's "best efforts" to protect her rights, including "the reasonable right to confer with the attorney for the United States in the case," and stating that "[a]t this time, your case is under investigation." On August 7, 2007 she gave the Federal Bureau of Investigation information about her own abuse and that of Jane Doe 2.15

The U.S. Attorney's Office for the Southern District of Florida signed the non-prosecution agreement on September 24, 2007 without consulting her. In late October 2007 two FBI agents met her and told her that Epstein would plead guilty to state charges and register as a sex offender; she said they did not tell her the agreement had already been signed, and she understood that the federal investigation would continue. On January 10, 2008 the FBI sent her a letter stating that "[t]his case is currently under investigation" and requesting her "continued patience." On January 31, 2008 she met FBI agents and an Assistant U.S. Attorney and gave further details of her abuse; the stipulated record states that the prosecutor "did not disclose to Jane Doe 1 at this meeting that they had already negotiated a NPA with Epstein."1

On June 30, 2008 Epstein pleaded guilty in state court. Wild stated in her declaration that she received no notice that the plea affected her rights and that, had she known the plea was connected to blocking the prosecution of her case, "she would have attended and tried to object to the judge to prevent that plea from going forward."1

The Litigation

Wild had retained Bradley Edwards in June 2008. On July 7, 2008 he filed her emergency petition to enforce her rights, and two days later the government's response made the first reference to the non-prosecution agreement. The case, later joined by the law professor Paul Cassell and the attorney Jay Howell, ran before Judge Kenneth Marra for eleven years. Wild also sued Epstein in state court for damages and received a monetary settlement.16

On February 21, 2019 Marra held that the government had violated her conferral right under the Act. After Epstein's death Marra denied all her requested remedies on September 16, 2019. On September 30, 2019 she petitioned the Eleventh Circuit for mandamus in her own name. At oral argument the government conceded that the office had "made a mistake in causing her to believe that the case was ongoing when in fact the NPA had been signed." A divided panel denied the petition in April 2020; the full court vacated that decision and reheard the case.127

On April 15, 2021 the en banc court denied her petition seven to four. Judge Kevin Newsom wrote for the majority: "We have the profoundest sympathy for Ms. Wild and others like her, who suffered unspeakable horror at Epstein's hands," adding that they had been "left in the dark" and, "so it seems, affirmatively misled" by government attorneys: "Even so, we find ourselves constrained to deny Ms. Wild's petition." The majority held that the Act did not authorize a freestanding suit to enforce victims' rights before charges were filed. The Supreme Court denied her petition for certiorari on February 22, 2022, after the Solicitor General opposed review. Wild wrote after the denial: "The government intentionally misled the victims but found a way to get away with it by working with a child molester to get around the law. And the Judges ruled in their favor. How?"34

The Courtney Wild Crime Victims' Rights Reform Act

In October 2019 Representatives Jackie Speier, Scott Perry, Lois Frankel, and Mo Brooks introduced the Courtney Wild Crime Victims' Rights Reform Act of 2019 (H.R. 4729), which would have made the Act's conferral and notice rights expressly applicable before charges and added remedies for their violation. It was not enacted. Speier reintroduced it in 2022 as H.R. 9444, and Debbie Wasserman Schultz later introduced a successor bill, the Courtney Wild Reinforcing Crime Victims' Rights Act.8

Wild v. Brown

On February 3, 2022 Wild and Haley Robson sued the journalist Julie K. Brown for defamation in Miami-Dade County circuit court over Brown's 2021 book Perversion of Justice: The Jeffrey Epstein Story. Their complaint alleged that the book falsely stated that Wild had been raped by Epstein and had later had intercourse with him, which the complaint said "is false," and that Brown had minimized Wild's role in exposing the agreement, in the creation of the Epstein Victim Compensation Program, and in Epstein's arrest while crediting herself. Robson alleged that after she declined an interview Brown told her she was "making the biggest mistake of your life" and then portrayed her as a member of Epstein's inner circle rather than as a victim. The complaint sought a public apology and damages. Brown told the Florida Bulldog on the day of filing that she had not yet seen the suit and had called her lawyer, and she declined to comment to the Miami Herald. Brown's Miami Herald series "Perversion of Justice" had been cited by the Justice Department as the report that renewed scrutiny of the agreement in 2018.29

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  1. Opinion and Order, Jane Doe 1 and Jane Doe 2 v. United States, No. 9:08-cv-80736-KAM (S.D. Fla. Feb. 21, 2019), ECF No. 435, at 2-3, 12, 16, 19-20, 22 (Marra, J.), quoting ECF No. 407 at paragraphs 6, 13, 70, 93, 97, 126, the Jane Doe 1 declaration (ECF No. 361-26), and ECF No. 415 at paragraph 12. https://storage.courtlistener.com/recap/gov.uscourts.flsd.317867/gov.uscourts.flsd.317867.435.0.pdf ↩
  2. U.S. Department of Justice, Office of Professional Responsibility, "Investigation into the U.S. Attorney's Office for the Southern District of Florida's Resolution of Its 2006-2008 Federal Criminal Investigation of Jeffrey Epstein and Its Interactions with Victims during the Investigation," Executive Summary, November 2020, pp. iii-v. https://www.justice.gov/opr/page/file/1336471/dl ↩
  3. In re Wild, No. 19-13843, 994 F.3d 1244 (11th Cir. Apr. 15, 2021) (en banc), opinion of Newsom, J., at 2-3. https://media.ca11.uscourts.gov/opinions/pub/files/201913843.enb.pdf ↩
  4. Supreme Court of the United States, docket No. 21-351, order of February 22, 2022 denying certiorari. https://www.supremecourt.gov/search.aspx?filename=/docket/docketfiles/html/public/21-351.html ; "Supreme Court Turns Away Jeffrey Epstein Victim's Petition on Dead Predator's Infamous Non-Prosecution Agreement," Law & Crime, February 22, 2022. https://lawandcrime.com/jeffrey-epstein-2/supreme-court-turns-away-jeffrey-epstein-victims-petition-on-dead-predators-infamous-non-prosecution-agreement/ ↩
  5. Bradley J. Edwards with Brittany Henderson, Relentless Pursuit: My Fight for the Victims of Jeffrey Epstein (New York: Simon & Schuster, 2020), publisher's description. https://www.simonandschuster.com/books/Relentless-Pursuit/Bradley-J-Edwards/9781982148140 ↩
  6. Docket, Doe v. United States, No. 9:08-cv-80736-KAM (S.D. Fla.), CourtListener. https://www.courtlistener.com/docket/4502088/doe-v-united-states/ ↩
  7. Opinion and Order, Doe v. United States, No. 9:08-cv-80736-KAM (S.D. Fla. Sept. 16, 2019), ECF No. 478 (Marra, J.). https://www.govinfo.gov/content/pkg/USCOURTS-flsd-9_08-cv-80736/pdf/USCOURTS-flsd-9_08-cv-80736-2.pdf ↩
  8. Office of Rep. Jackie Speier, "Rep Speier Introduces Bipartisan Courtney Wild Crime Victims' Rights Reform Act of 2019," October 2019. https://speier.house.gov/2019/10/rep-speier-introduces-bipartisan-courtney-wild-crime-victims-rights-reform-act-of-2019-to-rectify-injustices-faced-by-epstein-s-victims ; H.R. 4729, 116th Congress. https://www.congress.gov/bill/116th-congress/house-bill/4729/text ; H.R. 9444, 117th Congress. https://www.congress.gov/bill/117th-congress/house-bill/9444 ; Office of Rep. Debbie Wasserman Schultz, "Support the Courtney Wild Reinforcing Crime Victims' Rights Act." https://wassermanschultz.house.gov/uploadedfiles/cvraonepager.pdf ↩
  9. Complaint, Wild and Robson v. Brown (Fla. 11th Jud. Cir., Miami-Dade County, filed Feb. 3, 2022), paragraphs 5-13 and prayer for relief. https://www.courthousenews.com/wp-content/uploads/2022/02/wild-brown-complaint.pdf ; "Two victims of Jeffrey Epstein sue reporter/author Julie Brown for defamation," Florida Bulldog, February 2022. https://www.floridabulldog.org/2022/02/two-victims-jeffrey-epstein-sue-reporter-author-julie-brown-defamation/ ↩

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