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Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Do- .at 01/21/2015 Page 20 of 
20 
NOTIFICATION OF IDENTIFIED VICTIM 
SEPTEMBER 3, 2008 
PAGE 3 OF 3 
directly, he can be reached at +1 305 358-2800. 
If you have already selected other counsel to represent you, or if you do so in the 
future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack 
Goldberger as s th t 
u h 
at Atterbury Gonberger
and Weiss, 
, (561) 
659-8300. 
In addition, there has been litigation between the United States and two other victims 
regarding the disclosure of the entire agreement between the United States and Mr. Epstein. 
Mr. Joscfsberg can provide further guidance on this issue, or if you select another attorney 
to represent you, that attorney can review the Court's order in the matter of In re Jane Does 
I and 2, United States District Court for the Southern District of Florida Court File No. 08-
80736-C1V-MARRA. 
Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of 
Investigation can take pan in or otherwise assist in civil litigation. Thank you for all of your 
assistance during the course of the federal and state investigations and please accept the 
heartfelt regards of myself and Special Agents Kuyrkendall, Slater, and Richards for your 
health and well-being. 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
By: 
cc: 
Robert Joscfsberg, Esq. 
Jack Goldberger, Esq. 
A. Marie Villafaha 
Assistant United States Attorney 
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Case 9:08-cv-80736-KAM ,,ocument 291-2 Entered on FLSD 
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EXHIBIT 2 
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Case 9:08-cv-80736-KAM 
Jcument 291-2 Entered on FLSD U.
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P
ORAS Tam 
C leis Action 
Pe winal Injury 
Wconglul Otell 
Comer cal Lotqatton 
WWW.PATHTOJUSTICE COM 
Farmer, Jaffe, Weissing, 
Edwards, Fistos Et Lehrman, P.L. 
August 20, 2014 
Wifredo A. Ferrer 
United States Attorney 
Southern District of Florida 
RE: 
Jane Does I and 21 United Stales 
Case No. : 
08-80736-Civ-Marra/Johnson 
Dear Mr. Ferrer: 
As you know, we have been in litigation for more than six years on a case under the 
Crime Victims' Rights Act — a case that involves decisions that were all made before you took 
office and that gave Jeffrey Epstein an expansive non-prosecution agreement. Several years ago 
you were nice enough to meet with us and one of our clients to discuss the case, which we 'really I
appreciated. More recently we contacted the line attorneys working on the case to see if we 
could reach some stipulated facts on various issues surrounding the case. 
It is in that spirit of trying to avoid unnecessary battles that we wanted to alert you to a 
motion we are preparing to file to see whether this could be a stipulated motion. Our CVRA 
case is brought on behalf of two sexual assault victims — Jane Doe #1 and Jane Doe #2. We 
would like to add a third victim to the case — Jane Doe #3. Her true name is 
although we would seek to keep her identity confidential during the proceedings. We contacted 
your office about prosecuting the crimes Jeffrey Epstein committed against her a couple years 
ago when we realized that she was not includes in the NPA; however, we were told that despite 
not knowing about this particular victim when the agreement with Epstein was reached, the NPA 
was drafted so broadly as to preclude criminal charges for the crimes committed against her. 
Adding her to the case will not expand the issues in the case. Nor will it result in any new 
discovery or additional delay. 
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Case 9:08-cv-80736-KAM ...ocument 291-2 Entered on FLSD L.,,,ket 01/21/2015 Page 3 of 9 
Wifredo A. Ferrer 
August 20, 2014 
Page 2 
Jane Doc #3 was sexually abused numerous times by Jeffrey Epstein. Shc is keenly 
interested in having our CVRA case fairly resolved. We also note that, under the CVRA, Justice 
Department prosecutors are obligated to use their "best efforts" to help protect crime victims' 
rights. As such, we ask for your stipulation to this amendment. 
A copy of our soon-to-be-filed motion is attached. We wanted to show you what it 
looked like in hopes that you might be able to support it. We would, of course, be glad to 
consider making any changes to the motion that would help gamer your support. 
Thanks in advance for considering this request. 
Very truly yours, 
FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 
Bradley J. Edwards 
BJE::mwk 
Enclosure 
Farmer, Jaffe, Weissing, Edwards, Fistos ft Lehrman, P.L. 
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Case 9:08-cv-80736-KAM .document 291-2 Entered on FLSD L„„ket 01/21/2015 Page 4 of 9 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 08-80736-Civ-Marra/Johnson 
JANE DOE #1 and JANE DOE #2 
1. 
UNITED STATES 
r 
JANE DOE #3'S MOTION TO JOIN CVRA ACTION 
COME NOW Jane Doe #3, by and through undersigned counsel, to move this Court to 
join this action. Because Jane Doe #3's rights have been violated in the same way as the two 
other victims, and because the Crime Victims' Rights Act (CVRA) contains no statute of 
limitations, she should be allowed to join this action. 
As the Court is aware, more than six years ago Jane Doe #1 filed the present action 
against the United States, alleging a violation of her rights under the CVRA, 18 U.S.C. § 3771. 
She alleged that Jeffrey Epstein had sexually abused her and that the United States had entered 
into a secret non-prosecution agreement regarding those crimes in violation of her rights. At the 
first court hearing on the case, the Court allowed Jane Doe #2 to also join the action. Both Jane 
Doe 111 and Jane Doe #2 specifically argued that the government had failed to protect their 
CVRA rights (inter alia) to confer, to reasonable notice, and to be treated with fairness. In 
response. the Government argued that the CVRA rights did not apply to Jane Doe #1 and Jane 
Doe #2 because no federal charges had ever been filed against Jeffrey Epstein. 
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Last June, the Court rejected the United States' position. The Court concluded that the 
CVRA extended rights to Jane Doe til and Jane Doe #2 even though charges were never filed. 
The Court explained that because the NPA barred prosecution of crimes committed against them 
by Epstein, they had "standing" to assert violations of the CVRA rights. DE 189. The Court 
deferred ruling on whether the two victims would be entitled to relief, pending development of a 
fuller evidentiary record. 
Jane Doe #31 was sexually abused by Jeffrey Epstein more than twenty times in and alter 
the summer of 2002. 
Thereafter, in 2007, when the United States entered into its non-
prosecution agreement with Epstein, the United States had identified more than 40 victims by 
name and knew that many more existed. Jane Doe #3 was unknown to the United States, yet the 
United States entered into an agreement with Epstein — the NPA — which purports to preclude 
prosecution against Epstein in the Southern District of Florida, even for serious sexual offenses 
against Jane Doe #3 that are not barred by the Statute of Limitations. Jane Doe #3 was never 
even contacted by the United States, yet the United States contracted away her rights. 
Jane Doe #3 now moves to join the action filed by Jane Doe #1 and Jane Doe #2. She 
believes that her rights were violated in the same fashion as the other victims. 
Adding her to this case will not prejudice the United States. Jane Doe #3 does not seek 
any additional discovery beyond that previously sought by Jane Doe #1 and Jane Doe #2. 
Accordingly. the United States will not be prejudiced or burdened by adding her to this case. 
Indeed, adding her to this case may simplify certain issues, as it appears that the United States 
1 Because she was sexually assaulted as a minor, Jane Doc #3 proceeds in this motion by 
way of a pseudonym. 
2 
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Case 9:08-cv-80736-KAM ,,ocument 291-2 Entered on FLSD D,..Ket 01/21/2015 Page 6 of 9 
made no effort whatsoever to inform her about the non-prosecution agreement and cannot 
possibly argue otherwise, in contrast to certain limited steps that the United States may argue to 
have taken with regard to Jane Doe #1 and Jane Doe #2. 
The CVRA does not contain any statute of limitations for filing an action to enforce 
rights under the statute. Accordingly, her motion should be granted. 
Jane Doe #1 and Jane Doe #2 support the motion. The United States 'insert position 
xxxxxxxxxxxxxxxx I. 
CONCLUSION 
Jane Doe #3 should be allowed to join this action. A proposed order allowing her to join 
is attached to this pleading. 
DATED: August 20, 2014 
Respectfully Submitted, 
/s/ Bradley J. Edwards 
Bradley J. Edwards 
FARMER, JAFFE, WEISSING, 
EDWARDS, FISTOS & LEHRMAN, P.L. 
and 
Paul G. Cassell 
Pro Hac Vice 
S.J. Quinney College of Law at the 
University of Utah 
3 
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Case 9:08-cv-80736-KAM —ocument 291-2 Entered on FLSD D,..Ket 01/21/2015 Page 7 of 9 
MI& 
Attorneys for Jane Doe #3 
CERTIFICATE OF SERVICE 
I certify that the foregoing document was served on August 20, 2014, on the following 
using the Court's CM/ECF system: 
500 S. Australian Ave., Suite 400 
inis
ma
West Palm Beach, FL 33401 
Attorneys for the Government 
Roy Black, Esq. 
Jackie Perczek Es . 
• 
Jay P. Lefkowitz 
Kirkland & Eli 
P 
Martin G. Weinberg. P.C. 
Criminal Defense Counsel for Jeffrey Epstein 
/s/ Bradley J. Edwards 
4 
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Case 9:08-cv-80736-KAM 
Jcument 291-2 Entered on FLSD D.
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Case 9:08-cv-80736-KAM 
)cument 291-2 Entered on FLSD 
'<et 01/21/2015 Page 9 of 9 
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EXHIBIT 3 
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iaui., Tam 
OmsActoon 
Personal Injury 
Wrongful Death 
Comm (((( litigation 
WWW.PATHT0JUSTICE COM 
Farmer, Jaffe, Weissing, 
Edwards, Fistos Et Lehrman, P.L. 
November 19. 2014 
VIA CERTIFIED MAIL 
7009 1680 0000 4959 2808 
Wifredo A. Ferrer 
United States Attorney 
Southern District of Florida 
99 N.G. 4th Street 
Miami. FL 33132 
RE: 
Jane Does I and 2 1 United States 
Case No.: 
08-80736-Civ-Marra/Johnson 
Dear Mr. Ferrer: 
I sent you a letter in August requesting your office's stipulation to our adding Jane Doe 
#3 in this case. Unfortunately. we did not receive a response from your office. We are hopeful 
that your lack of a response was simple oversight. 
In addition to following up on the August letter, we are now requesting your Stipulation 
to the adding of Jane Doe #4 as well. Her true name is 
She was identified by 
your office during the Federal Investigation, and consequently her name appeared on the list of 
victims attached to Mr. Epstein's Non-Prosecution Agreement. 
As we expressed in our personal meetings a couple years ago. we don't understand the 
tactical decision to be adversarial to the victims of known sexual abuse on every point in this 
litigation. Now that many of those issues we discussed have been resolved in our favor, it seems 
to make even more sense to avoid engaging in unnecessary battles that could only serve the 
purpose of delaying the victims' rights to have this case resolved on its merits. 
As I indicated in my August letter requesting your stipulation to the adding of Jane Doe 
#3, adding Jane Doe #4 will also not delay matters, so long as we can stipulate to her being 
added. Without a stipulation, we foresee litigation over this point, which will produce nothing 
but additional delay — and further question about your Office's commitment to full protection of 
victims' rights under the Crime Victims Rights Act. 
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Case 9:08-cv-80736-KAM --Jcument 291-3 Entered on FLSD 
-Ket 01/21/2015 Page 3 of 3 
Wifredo A. Ferrer 
November 19.2014 
Page 2 
Your office is very familiar with 
and her circumstance. She was sexually 
trafficked and abused by Mr. Epstein (and others at the direction of Mr. Epstein) not only in this 
jurisdiction but throughout the United Slates and beyond. Unlike Jane Doe #3. Jane Doe #4 was 
included as a named victim in the NPA. 
There is no statute of limitations in bringing such claims, and I think we would agree that 
the current case is the best vehicle through which to bring these claims, as opposed to forcing us 
to file new actions and starting over on issues and claims inextricably intertwined with the 
current litigation. We don't see a good reason for denying our motion, so we anticipate 
prevailing at the end. But even if you were to object and prevail on the motion to add her to the 
current litigation, the only consequence would be that 
would then file a separate 
CVRA lawsuit, something she is entitled to do because the CVRA contains no time limit. We 
are simply trying avoid all this entirely unnecessary complication. 
We have, throughout this case, consciously avoided filing anything that would 
unnecessarily cast your office in a bad light, and it is again with that in mind that we request your 
stipulation here. We need this stipulation by December 10, 2014 to avoid delaying any other 
aspects of this case. We will not file any pleadings on this subject before that date. 
Lastly. we feel that we are once again at a stage in this litigation where it may make sense 
to meet again face-to-face to attempt to resolve, or at least narrow, some issues in an effort to 
avoid litigating some of the matters that we will be forced to litigate if the parties continue along 
this unreasonably adversarial path. 
Thanks in advance for considering this request. 
Very truly yours, 
FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 
Bradley J. Edwards 
BJE::mwk 
Farmer, Jaffe, Weissing, Edwards, Fistos ft Lehrman, P.L. 
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EXHIBITS 
4 and 5 
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From: 
(USAFLS) 
Sent: Wednesday, December 03, 2014 1:03 PM 
To: Brad Edwards; 
(USAFLS) 
Cc: Paul Cassell 
Subject: RE: DoeiUS 
Brad, 
The US. Attorney has both your letters and Is considering the matter, as well as your request for a meeting. I will try to 
get an answer for you as soon as possible. 
• 
From: Brad Edwards - 
Sent: Wednesday, December 03, 2014 2:12 PM 
To: Redacted (OWLS); 
Redacted 
(USAFLS) 
Cc: Paul Cassell 
Subject: Doe 'US 
When we spoke a few months ago, I told you that we represented 
and were considering 
adding her to this suit. At the time of our call we asked if you would agree to our adding her, and I understood 
that you would have to check with others. Consequently, I sent a couple of letters to Mr. Ferrer that I have 
attached to this email. I was hoping for a response letting me know that the Office would not oppose the 
amendments adding Doe 3 and 4. We also suggested in the letters that perhaps a meeting is in order at this 
point. I know you cannot speak for Mr. Ferrer on that point, which was another reason for addressing the 
letter to him. 
I realize our 11/19 letter asked for a response by the 10th. However, I was hoping you could give me some 
indication whether we will get an answer before the 10th (and perhaps what that answer will be), because if 
there will not be an agreement to adding these Plaintiffs then I want to get the Motion prepared. Let me 
know something as soon as you can. Thanks. 
Sincerely, 
&!(' 
Farmer, Jaffe, Wallis, 
Y
i 
Edwards, Flatos & Lehrman, RL. 
Brad Edwards 
Board Certified Trial Attorney 
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