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criminal"); In re Apr. 1977 Grand Jury Subpoenas, 584 F.2d 1366. 1368 (6th Cir. 1978) ("From 
a simple reading of the statute itself, it seems self-evident that a grand jury investigation of 
possible criminal tax violations should not be characterized as a 'civil action"); United States. 
Wade, 93 F. Supp. 2d 19, 21 (D.D.C. 2000), girds 255 F.3d 833 (D.C. Cir. 2001) (third party 
intervention in criminal proceeding to oppose abatement order was not a "civil action" because 
"as the statute's plain language excludes criminal cases, the Court will not parse criminal cases 
into criminal and 'civil-like' proceedings"); Quinn'. Book Named "Sixty Erode Drawings From 
Julien." 316 F. Supp. 289, 292 (D. Mass. 1970) (where a proceeding to determine whether book 
is obscene is ancillary to a criminal prosecution and serves to aid in the enforcement of criminal 
law, such a proceeding does not come within the term 'civil action"). 
A crime victim's petition to enforce CVRA rights looks nothing like a conventional civil 
action against the Government. A CVRA enforcement proceeding does not grant any monetary 
relief to a victim. The CVRA directly bars a victim from "pursuing a damages action against the 
government for violation of the [CVRA], and there is no implied private right of action under the 
[CVRA]." 3B Wright & 
, Fed. Prac. & Proc. Crim. § 932 (4th ed. 2014); see 18 U.S.C. § 
3771(d)(6) ("Nothing in this chapter shall be construed to authorize a cause of action for 
damages or to create, to enlarge, or to imply any duty or obligation to any victim or other person 
for the breach of which the United States ... could be held liable in damages."); Cunningham. 
U.S Dept of Justice, 961 F. Supp. 2d. 226 (D.D.C. 2013) ("[The] CVRA expressly disallows a 
suit for damages against the federal government or its officials . . . and Mr. Cunningham has 
failed to carry his 'heavy burden' of demonstrating the requisite congressional intent necessary 
to establish an implied private right of action."); 200.000 Towers Investors Restitution Victims'. 
7 
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U.S. ex rel. U.S. Prob. Office New York City Slefff Breach of Crime Victims Act, 2013 WL 
6673612. at *2 (S.D.N.Y. 2013) ("This petition is brought pursuant to the CVRA, which does 
not provide for a private right of action."). Rather, the CVRA provides crime victims certain 
rights that are related to the prosecution of the accused and sentencing of the guilty. These rights 
are not civil, but criminal in nature. See In re McNulty, 597 F.3d 344. 352 n.8 (6th Cir. 2010) 
("The CVRA was not enacted to short circuit civil litigation to those with valid civil remedies 
available."). 
Jane Doe No. 3 and Jane Doe No. 4 are seeking to enforce their rights as crime victims 
under the CVRA — rights that the Government should have provided to them during its criminal 
investigation. They are not seeking monetary damages from the government for the violation of 
their CVRA rights, but rather invalidation of an illegal non-prosecution agreement that bars 
criminal prosecution of Epstein and his potential co-conspirators. The victims' rights are 
ultimately enforceable in, and inseparable from, a criminal proceeding. Their action is simply 
not the type of action covered by .§ 2401(a)'s six-year statute of limitations for "civil actions" 
against the Government. 
The Government complains that the victims' position means that no statute of limitations 
applies to CVRA cases. DE 290 at 506. Not true. The applicable statute of limitations in this 
"ancillary criminal proceeding" is to be found (appropriately enough) in the criminal code — i.e., 
Title 18 — not in the judicial code — Title 28, as the Government's position would have it. Of 
course, the CVRA itself is found in Title 18. And for most crimes, the applicable statute of 
limitations will be the general five-year statute for filing criminal actions, 18 U.S.C. § 3282 — 
shorter than the six-year civil tort statute the Government points to. This case, however, involves 
8 
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Case 9:08-cv-80736-KAM Document 310 Entered on FLSD Docket 02/06/2015 Page 9 of 20 
sexual offenses against children, and the Court should therefore look to the specific statute of 
limitations covering such crimes. See Edwards' ShaIola, 64 F.3d 601, 605 (11th Cir. 1995) 
("[I]t appears contrary to the Supreme Court's directives .. . to apply a statute [of limitations] of 
general applicability when there are other more relevant statutory provisions."). In 18 U.S.C. § 
3283, Congress has decreed that "[fi]o statute of limitations that would otherwise preclude 
prosecution of an offense involving the sexual or physical abuse . . . of a child under the age of 
18 shall preclude such prosecution during the life of the child. or for ten years after the offense, 
whichever is longer."5 This statute of limitations governs the underlying criminal prosecution 
and thus this related CVRA case. Because this limitation period has not expired, Jane Doe No. 3 
and 4's motion to join is timely. Indeed, the Government's position would create an absurd 
result — i.e., that even though the statute of limitations for prosecuting crimes against Jane Doe 
No. 3 and No. 4 has not yet expired, their ability to protect their CVRA rights in the investigative 
process of those crimes has somehow expired! Surely Congress did not intend such a bizarre 
result that would limit the CVRA's effectiveness. 
$ In 1994, this statute allowed prosecution of an offense against a child up until the child 
reached the age of 25. See 18 U.S.C. § 3283 (1994). In 2003, Congress passed the Prosecutorial 
Remedies and Tools Against the Exploitation of Children Today Act (the "PROTECT Act"), 
which further extended the statute of limitations for offenses involving the sexual or physical 
abuse of a child from when the child reaches the age of 25 years to "during the life of the child." 
Pub. L. 108-21, Title II, § 202, 117 Stat. 660 (Apr. 30, 2003). See Joint Explanatory Statement 
of the Committee of Conference, 149 Cong. Rec. 142950-01 (2003) (Conf. Rep.), 2003 WL 
1832092 (while the 25-year age limit "is better than a flat five-year rule, it remains inadequate in 
many cases"). 
Because the crimes against Jane Doc No. 3 were committed while she was a minor 
between around 1999 to 2001 (see DE 291-I at 1-12), the statute of limitations had not yet 
expired as to crimes against her in 2003 and therefore the PROTECT Act's extension of the 
statute of limitations applies in this case. See United Stalest Vickers, 2014 WL 1838255, at *9 
(W.D.N.Y. 2014). 
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Case 9:08-cv-80736-KAM Document 310 Entered on FLSD Docket 02/06/2015 Page 10 of 20 
B. 
Because Jane Doe No. 3 Was 
Accrued, She Has Timely Filed Her Motion. 
' When Her Action First 
Even if 28 U.S.C. § 240I(a) applies to the new victims' claims, Jane Doe No. 3's claim is 
still timely. Congress has writtappion 
into the statute: "The action of any 
person . . . 
at th 
ma be commences within three ears 
a ter tiedisability ceases. 
a 
emp asis a 
). In t is case. Jane oe 
No. 3 was hiding from Jeffrey Epstein and his co-conspirators in 
from the time her 
claim accrued until October 2013, when she returned to the United States. See Ex. 1 at 3 ("I was 
in 
from late 2002 to October 2013. To be clear, I was never in the United States during 
these years, not even for a short trip to visit my mother."). The Court can take judicial notice 
that the distance from West Palm Beach. Florida, to 
and that 
travel between the two points would involve passing over the Pacific Ocean. Therefore, Jane 
Doe 3 was plainly H 
when the events giving rise to her claim occurred, and the 
running of the limitations period, if applicable, did not begin until she returned to Florida about 
16 months ago, in October 2013. Jane Doe 3 has therefore filed her action within the three-year 
time period specified by § 2401(a) for persons returning to this country from 
Confirming the commonsense conclusion that Jane Doe No. 3 was 
Black's Law Dictionary (9th ed. 2009) defines ' 
' as: "(Of a person) 
Being absent from a jurisdiction or nation; out of the country, esp. across the ocean."6
Moreover, Congress first crafted the ' 
 
' language in 1911, when it plainly 
referred to persons living outside the United States. The original tolling provision provided: 
6 Black's Dictionary gives the above-quoted definition for the phrase "beyond seas," but 
10 
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Case 9:08-cv-80736-KAM Document 310 Entered on FLSD Docket 02/06/2015 Page 11 of 20 
Provided, That the claims of married women, first accrued during marriage, of 
persons under the age of twenty-one years. first accrued during minority, and of 
idiots, lunatics, insane persons. and persons 
at the time the claim 
accrued, entitled to the claim, shall not be barred if the suit be brought with three 
years after the disability has ceased... . 
Act of Mar. 3, 1911, ch. 231, § 24, para. 20, 36 Stat. 1093 (emphasis added). The decisive 
question when construing a statute is what did the words mean "at the time of the statute's 
enactment." Taniguchi'. Kan Pac. Saipan, Lids. 132 S. Ct. 1997, 2003 (2012). In 1911, the 
phrase ' 
' clearly embraced persons who were outside the United States, as 
previous court decisions had held. See. e.g., Murray's Lessee'. Baker. 16 U.S. 541, 545 (1818) 
(concluding that "the words 
must be held to the equivalent to 'without the 
limits of the state'). 
In 1948, Congress saw fit to re-codify this provision into Title 28 of the United States 
Code and replaced the statutory references to minors and mentally disabled persons with the 
consolidated term "under a legal disability." See Act of June 25, 1948. Pub. L. No. 80-773, 62 
Stat. 971 (codified as amended at 28 U.S.0 § 2401(a)). But Congress chose to leave the words 
unaltered — with the result that they continue to have the same meaning as 
they had in 1911. See IA SUTHERLAND STATUTORY CONSTRUCTION § 22:33 (7th ed.) 
("Provisions of the original act or section which are repeated in the body of an amendment, 
either in the same or equivalent words, are a continuation of the original law"). 
Congress knows how to write statutes of limitations that do not toll the limitations period 
for persons 
Cf. 18 U.S.C. 2255(b) (containing a tolling provision for crime 
victims "under a legal disability," but not containing a tolling provision any other persons). 
notes that the phrase ' 
' is an equivalent. Id. 
II 
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Case 9:08-cv-80736-KAM Document 310 Entered on FLSD Docket 02/06/2015 Page 12 of 20 
Where Congress has deliberately chosen to toll the running of the limitations period while a 
claimant is 'fl" 
as in 28 U.S.C. 2401(a), a court lacks the power to narrow the 
scope of the plain meaning of that phrase. See CBS Inc.'. PrimeTime 24 Joint Venture, 245 
F.3d 1217. 1228 (11th Cir. 2001) (cautioning against allowing "clearly expressed legislative 
decisions... [to] be subject to the policy predilections of judges."). 
The Government may try to argue that, in its view. this tolling provision is now somehow 
outdated, given the arrival of technology permitting less expensive international telephone calls 
and the like. But the Government's opinion about whether this tolling provision remains sound 
public policy is beside the point. Courts do not exist to "update" statutes in light of the latest 
technological developments. See Myers'. Toolay's d4gnu. Corp., 640 F.3d 1278. 1286 (11th 
Cir. 2011) (courts "are not licensed to practice statutory remodeling"); Wright. Sec 'y for Dept 
of Corrs., 278 F.3d 1245, 1255 (11th Cir.2002) ("Our function is to apply statutes, to carry out 
the expression of the legislative will that is embodied in them, not to 'improve' statutes by 
altering them."); see also Lees 1. City of Riviera Beach, Fla., 166 F.3d 1332, 1351-52 (11th Cir. 
1999) (Edmonson. J., dissenting) ("it is the qualities of the text when it was written — and not our 
response to it as modern readers — that must be our guide. . . . [W]hat we personally might like 
this statute to mean . . . in the light of current circumstances ... has no rightful place in our work 
Whether to modernize a statute is Congress' decision. See City of Greenwood. Miss.'. 
Peacock, 384 U.S. 808, 834 (1966) ("[I]f changes are to be made in the long-settled 
interpretation of the provisions of this century-old . . . statute, it is for Congress and not for this 
Court to make them."). Put simply, while Jane Doe No. 3 was living in 
she was 
12 
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Case 9:08-cv-80736-KAM Document 310 Entered on FLSD Docket 02/06/2015 Page 13 of 20 
— i.e., outside of the borders of the United States — and section 2401(a)'s 
statute of limitations was tolled? 
C. 
Because Jane Doe No. 3 and Jane Doe No. 4 Were Unaware of Their Ability 
to File a CVRA Action Until Recently, They Timely Filed Their Motions. 
In arguing that the statute of limitation has lapsed in this case for Jane Doe No. 3, the 
Government apparently starts the six-year clock running on September 3, 2008, when the U.S. 
Attorney's Office sent a letter to her in M. 
See DE 290 at 3 (citing letter attached as DE 
290-I ).8 But that letter did not clearly communicate that a CVRA cause of action existed. To 
the contrary, the letter was quite misleading about what was happening. The Government told 
Jane Doe No. 3 only that "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." DE 290-I at 3 (emphasis added). 
But the litigation did not involve disclosing the 
agreement; rather the goal was invalidating the agreement. The Government's intentionally 
deceptive description confused Jane Doe No. 3, who states that "[u]nderstanding more about that 
[CVRA] case now. I realize that the letter did not explain that the real purpose of that litigation 
was not to get 'disclosure of the entire agreement' but instead to get criminal charges filed 
against Epstein and to uphold the rights of Epstein's victims. I wish that the Government had 
7 This case does not present any occasion for the Court to consider how § 2401(a)'s 
statute of limitations applies when a person is voluntarily absent from the United States. As Jane 
Doe No. 3 attests in her affidavit, she was involuntarily outside of the United States because she 
was concealing herself from Epstein. See Ex. I at 3 ("my absence from the United States was 
not voluntary — I was hiding from Epstein out of fear of what he would do to me if I returned to 
the United States."). 
The Government also refers briefly to earlier events in the case. See DE 290 at 6-7. But 
clearly those earlier events did disclose to Jane Doe No. 3 the existence of a secret non-
prosecution agreement. She first became aware of the existence of such an agreement through 
the Government's letter on September 3. 2008. 
13 
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Case 9:08-cv-80736-KAM Document 310 Entered on FLSD Docket 02/06/2015 Page 14 of 20 
told me that was what was really going on." Ex. I at 5-6. Given this deception, the Court should 
not conclude — on the basis of mere pleadings — that Jane Doe No. 3's obligation to file began on 
September 3, 2008. Finally, the September letter informed Doe 3 to call an attorney in Miami 
who was assigned her representation by the Government through the NPA. That firm had to 
work within the confines of that Government assignment and direction and therefore could not, 
and did not, inform Jane Doe No. 3 of a right to participate in this CVRA case which was aimed 
at invalidating the very agreement through which this law firm was mandated to operate. 
The Government's position regarding Jane Doe No. 4 is also mystifying. 
The 
Government asserts that she had legal representation "as early as 2012." DE 290 at 9. Of 
course, that date falls well inside the six-year period of limitations, so her claim would not be 
time barred in any event. 
IV. 
THE GOVERNMENT PROVIDES NO PERSUASIVE ARGUMENT AGAINST 
RULE 21 JOINDER. 
For the reasons just explained, neither the CVRA nor 28 U.S.C. § 240I(a) provides any 
barrier to Jane Doe No. 3 and Jane Doe No. 4 joining this case. As a result, the path would seem 
to be clear for the Court to simply grant the current victims' motion for joining the new victims 
under Fed. R. Civ. P. 21. The Government, however. has several other arguments that it throws 
out. None of them is persuasive. 
Perhaps recognizing that Rule 21 broadly allows for the addition of new parties, the 
Government contends that the Rules of Civil Procedure do not even govern this action. 
Proceeding from the premise that this case is an "ancillary criminal proceeding" (DE 290 at 2), 
I4 
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Case 9:08-cv-80736-KAM Document 310 Entered on FLSD Docket 02/06/2015 Page 15 of 20 
the Government points out that the Rules of Criminal Procedure lack a provision for adding new 
parties. Thus, the Government concludes, that no parties can be added here. Id. 
The Government's hyper-technical argument suffers from two clear flaws. First, the 
Court has already ruled that, as to procedural matters in this case, the civil rules govern. See DE 
257 at 3 ("As this Court has previously indicated, see DE 190, the Federal Rules of Civil 
Procedure govern the general course of this proceeding."); see also Local Rule 88.9 (motions in 
criminal cases governed by Local Rule 7.1, which parallels Fed. R. Civ. P. 7). Second and more 
fundamentally, the Government's crabbed interpretation of the CVRA would mean that a new 
victim should never be allowed tojoin a previously-filed CVRA action. This position-  is belied 
not only by the clear intent of Congress to create enforceable rights for crime victims, but also by 
the Government's own action in previously agreeing to Jane Doe No. 2's motion to join the case. 
See DE I5 (tr. July I 1, 2008) at 14 (Court: "[D]o you have any objection to Jane Doe 2 being 
added as a petitioner in this case?" Government counsel: "No, I don't."). Clearly, as the 
Government's own previous agreement demonstrates, some procedural device should allow a 
new victim to be added to a previously-filed CVRA case, as otherwise the court's docket could 
be unnecessarily cluttered with separate actions. 
As a fallback, the Government advances the claim that the rule of civil procedure 
controlling the pending motion is not Rule 21 (regarding joinder of parties), but rather Rule 15 
(regarding amendments to pleadings). See DE 290 at 2. The Government's argument does not 
square with the plain language of the two provisions. While Rule 15 deals with amending 
pleadings, Rule 21 specifically indicates that, upon motion, the Court has power to "add . . a 
party." Of course, since the current motion involves an effort to add new parties, it is 
15 
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Case 9:08-cv-80736-KAM Document 310 Entered on FLSD Docket 02/06/2015 Page 16 of 20 
appropriate for the Court to resolve the issue under Rule 21. As one court has explained, "Any 
conflict or ambiguity which results from a comparison of [Rule 15(a) and Rule 21] ... must be 
resolved in favor of the specific and against the general. Thus, when a proposed amendment to a 
complaint seeks to effect a change in the parties to the action, Rule 21 ... controls and, to that 
extent, limits Rule I5(a)." Intl Broth. of Teamsters'. AFL-CIO, 32 F.R.D. 441, 442 (E.D. 
Mich. 1963). While the Government cites three cases allowing the addition of new parties 
through Rule IS (DE 290 at 102). none of these cases address the issue of whether Rule 15 or 
Rule 21 is the proper vehicle to do so. Most cases that have discussed directly which of the two 
rules applies have concluded that Rule 21 is the appropriate vehicle for adding a party. See, e.g.. 
South Dakota ex rel. S. Dakota R.R. Awh.l. Burlington N. & Santa Fe Ry. Co., 280 F. Supp. 2d 
919, 924 (D.S.D. 2003) ("Pleadings and Motions are dealt with under Part 111 of the Rules [i.e., 
Rules 8 to 16]. Parties are dealt with under Part IV of the Rules [i.e., Rules 17-25]. If a plaintiff 
could simply add a party by amending the complaint, there would be no purpose for Rule 19 . . . 
."); Joseph'. House, 353 F. Supp. 367. 371 (E.D. Va.), ced sub nom. Joseph. Blair, 482 F.2d 
575 (4th Cir. 1973) ("Rule 21 ... provides that parties to an action may be added by order of the 
Court at any stage of the proceedings. This rule precludes the plaintiffs from being able to file 
their amended complaint as of right, which they seek to do. The plaintiffs would ordinarily be 
able to do so under Rule 15(a)."). 
Because the Government has refused to stipulate to Jane Doe No. 3's and Jane Doe No. 
4's entry into the case, the victims are contemporaneously filing with this reply a protective 
motion for amendment under Rule 15 to add the new victims. But the new victims continue to 
rely on Rule 21's plain language as their primary argument to join this case. 
16 
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Case 9:08-cv-80736-KAM Document 310 Entered on FLSD Docket 02/06/2015 Page 17 of 20 
The Court should apply Rule 21 and allow Jane Doe No. 3 and Jane Doe No. 4 to be 
added to this case at this time. It is well-settled that "(u)nder the Rules, the impulse is toward 
entertaining the broadest possible scope of action consistent with fairness to the parties; joinder 
of claims, parties and remedies is strongly encouraged." United Mine Workers of Am.'. Gibbs, 
383 U.S. 715, 724 (1966). As discussed in Part I, above, the Government had not contested the 
reasons that support joining the new victims into this case. Instead, the Government's only 
arguments pertain to the timing of the motion. But Rule 21 itself makes clear that new parties 
can be added "at any time." Fed. R. Civ. P. 21. And the cases clearly demonstrate the joinder is 
appropriate, even at very late stages of a proceeding, if justice will be served. See. e.g.. Data 
General Corp. 
Grumman Sys. Support Corp., 825 F. Supp. 340, 344 (D. Mass. 1993) (where 
common question of fact existed about plaintiff student suing under the Civil Rights and two 
other students who were not parties to the suit, it was appropriate for the court to join the two 
other students at the conclusion of the trial when a portion of the relief request was granted). 
Of course, this case is not at a late stage, but is still in a discovery phase. 
The Government's arguments about undue delay and prejudice arc meritless, as the 
victims discuss in their concurrently-filed motion for amendment under Rule 15.9 But for 
purposes of this Rule 21 motion, one point is decisive. If the Court does not allow the new 
victims to join this CVRA enforcement action, then they intend to file their own, separate 
enforcement actions. Because there is no statute of limitations for doing so. the separate actions 
would be proper. But the separate actions would produce entirely duplicative litigation over the 
9 The victims specifically adopt and incorporate by reference here the arguments against 
undue delay and prejudice that they make in their Rule IS pleading. 
17 
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Case 9:08-cv-80736-KAM Document 310 Entered on FLSD Docket 02/06/2015 Page 18 of 20 
same set of facts. This reality should be the decisive factor in favor of allowing joinder here. 
See Hawkins'. Fulton C'nty., 95 F.R.D. 88. 91 (N.D. Ga. 1982) (allowing new parties to be 
added under Rule 21 because denying motion "would only result in the filing of a second. 
possibly duplicative suit. This Court is duty bound to prevent that sort of duplication of effort 
which is a waste of judicial resources."). Indeed, allowing joinder will clearly reduce litigation 
burdens — on both the Court and the Government. The motion seeks to have the new victims 
added into this action, conditioned on the requirement that they not re-litigate any issues 
previously litigated. Of course. if Jane Doe No. 3 and Jane Doe No. 4 were to file new lawsuits, 
they would not be subject to any such restriction. 
Allowing joinder in this action is clearly consistent with the Crime Victims' Rights Act. 
The CVRA — the most specific directive to this Court — commands that the Court "shall ensure 
that the crime victim is afforded the rights described [in the CVRA]." 18 U.S.C. § 3771(b)(1) 
(emphasis added). Congress intended that "the courts of this country . . . will be responsible for 
enforcing" victims' rights provided in the CVRA. 150 CONG. REC. 22953 (Oct. 9, 2004) 
(statement of Sen. Kyl). The best way the Court can "ensure" that Jane Doe No. 3 and Jane Doe 
No. 4's rights are afforded is by allowing them to join this enforcement action. The Court should 
accordingly allow them to join. 
CONCLUSION 
Jane Doe No. 3 and Jane Doe No. 4 should be allowed to join Jane Doe No. I and Jane 
Doe No. 2 in this action, pursuant to Rule 21 of the Federal Rules of Civil Procedure. The 
joinder should be conditioned on the requirement that Jane Doe No. 3 and Jane Doe No. 4 not re-
litigate any issues previously litigated by Jane Doe No. 1 and Jane Doe No. 2. 
18 
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.ease 9:08-cv-80736-KAM Document 310 Entered on FLSD Docket 02/06/2015 Page 19 of 20 
DATED: February 6. 2015 
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 
Attorneys, or the victims 
This daytime business address is provided for identification and correspondence 
purposes only and is not intended to imply institutional endorsement by the University of Utah 
19 
EFTA00188660

Case 9:08-cv-80736-KAM Document 310 Entered on FLSD Docket 02/06/2015 Page 20 of 20' 
CERTIFICATE OF SERVICE 
I certify that the foregoing document was served on February 6, 2015, on the following 
using the Court's CM/ECF system: 
500 S. Australian Ave., Suite 400 
West Palm Beach, FL 33401 
(561) 820-8711 
Fax: 561 820-8777 
Attorneys for the Government 
Thomas Scott 
ar
COLE. SCOTT & KISSANE, P.A. 
-and-
Kendall Coffey 
Gabriel Groisman 
Benjamin H. Brodsk 
n
om
COFFEY BURLINGTON. P.L. 
Attorneys for Alan Dershowit: 
/s/ Bradley J. Edwards 
20 
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EXHIBIT 1 
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Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 2 of 28 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 08-80736-CIV-MARRA 
JANE DOE #1 and JANE DOE #2, 
Petitioners, 
vs. 
UNITED STATES OF AMERICA, 
Respondent. 
DECLARATION OF JANE DOE 3 
I. 
The Court is familiar with me from my previous declaration in this case. I am currently 
31 years old and want to become a part of the case to enforce my rights and possibly allow 
criminal prosecution of Jeffrey Epstein and others who abused underage girls. 
2. 
I have seen a Government filing saying that I waited too long before trying to become a 
part of this case. I don't think that the Government's position tells the full story about me. In 
fact, 1 believe the Government is hiding some of the things that it knows about me and about 
other powerful people involved in this case. 1 am filing this declaration so that the Court will 
have more facts to make the decision about whether to let me come into the case. 
3. 
In its latest filing, the Government seems to be questioning why I was afraid and did not 
come forward to speak more quickly. To understand my reasons, it is important that I share at 
least some additional information about why I was so fearful after my abuse by Epstein and 
others. 
4. 
The Court can best understand my situation by looking at my previous declaration and 
then understanding why I was afraid of Epstein, how I eventually escaped from him, and how I 
was forced to hide from him and others. 
5. 
I first met Epstein when I was 15 years old. I have told the Court about some of my 
sexual and physical abuse in my earlier declaration. 
6. 
As a result of that abuse and my considerable interactions with Epstein and his friends, I 
knew that Epstein was connected to some of the most powerful people in the world, including a 
member of the British Royal family, a former President of the United States, and other very 
powerful lawyers, politicians and businessmen. I was afraid of what would happen if I tried to 
escape from Epstein or report him to law enforcement. 
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Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 3 of 28 
7. 
1 also knew what Epstein and Maxwell had been doing the years that I was with them. In 
addition to constantly finding underage girls to satisfy their personal sexual desires, Epstein and 
Maxwell also got girls for Epstein's powerful friends and acquaintances. Epstein specifically 
told me that the reason for him doing this was so that they would "owe him," they would "be in 
his pocket," and he would "have something on them." Epstein used to brag a lot to me about the 
important people that owed him favors. 
8. 
Epstein said that he knew people that were very powerfid and who were politically 
involved, and that consequently he was someone you didn't want to mess with. I also knew this 
to be true from my personal observations with him. 
9. 
Epstein also apparently paid to get protection from authorities. For example, Epstein told 
me that he paid a substantial "donation" to the Palm Beach police every year to "keep their 
mouths shut" about his activities. I do not know if his claim is true, but it certainly added to my 
fear. 
10. 
Epstein arranged for many politically powerful, older men to have sex with underage 
girls — including me. Because these were crimes — and because some of these men were married 
— this gave Epstein the ability to blackmail these men and obtain political and other favors. I 
believe that Epstein's connections and his ability to blackmail these other powerful people could 
have helped Epstein seek a plea bargain from the authorities that kept him out of prison. T also 
believe that these connections most likely have prevented him from being arrested in the other 
locations where he has committed similar offenses. 
II. 
I also knew that Epstein maintained videos in some rooms where I had sex with other 
powerful people, and I believe that those videos could be used as further blackmail. 
12. 
I have listed a few of the powerful people that Epstein forced me to have sex with in my 
earlier declaration. There were others, though, who I continue to refrain from naming publicly 
out of fear for physical repercussions. 
13. 
Part of my fear comes from physical abuse that I suffered when Epstein forced me to 
have sex with other people. Without going into the details of the sexual activities I was forced to 
endure, there were times when I was physically abused to the point that I remember fearfully 
thinking that I didn't know whether I was going to survive. 
14. 
Jeffrey Epstein knew about this physical and sexual abuse because I would detail it for 
him as part of my debriefing. Epstein didn't care. Epstein said things like, "You get that 
sometimes." I told him how much I hated having to be with some people, but Epstein still sent 
me back. I had no choice. 
15. 
I give the Court this information so that it can better understand why I was so afraid of 
Epstein and what he could do to me. I could provide more details to the Court, if the Court needs 
more details on this issue. I also wanted to provide this information to the Court because I have 
been accused of being a "serial prostitute." I don't think that is a fair way to describe my 
situation, given that I was so young and so many powerful people were forcibly abusing rm. 
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16. 
Epstein let me know one of his good friends was former President Bill Clinton. While I 
did not have sex with former President Clinton, Epstein clearly had access to this extremely 
powerful man. Epstein also made me sexually service other very powerful people, which made 
me more fearful and feeling like I had nobody to report to without putting myself in more 
danger. I don't think it is fair for the Government to talk about why I didn't try to join this case 
sooner without talking about (hese kinds of facts - facts that I believe it has been able to confirm. 
17. 
After years of abuse and being lent out, 1 began to look for a way to escape. I had been 
first forced into all this because I wanted to be a massage therapist. Epstein had taken me into 
his clutches through promises and talk. But once he had me under his control, I felt trapped. 
18. 
I kept asking Epstein for my promised training and education. Epstein finally got me a 
plane ticket to Thailand to go to Chaing Mai to learn Thai massage. This sounded like my 
chance to escape. In September 2002, I packed my bags for good. I knew this would be my only 
opportunity to break away from Epstein. 
19. 
On September 27, 2002, I flew from JFK in New York to Chaing Mai, Thailand. I 
arrived around September 29 for my training, But Epstein was going to get something out of this 
as well. I was supposed to interview a girl to bring back to the United States for Epstein. 
20. 
Exhibit 1 is a list of room charges in Thailand, with the charges going to Epstein's 
account This exhibit shows Epstein's telephone numbers and is evidence that he paid for my 
hotel in Thailand. 
21. 
Exhibit 2 is a set of documents showing my itinerary and flight plans for me going to 
Thailand, paid for by Epstein. 
22. 
I did the massage training in Chiang Mai. I met a truly great and special guy and told him 
honestly what I was being forced to do. He told me I should get out of it. I told him that the 
people I was working for were very powerful and that I could not disobey them without risking 
my life. He told me he would protect me, and I had confidence in him. I saw my opportunity to 
escape and to be with someone wILL
 luriloved me and would protect me. To make a long story 
short, I married him and flew to 
23. 
I called Epstein and told him I was not coming back. He asked why? I said "I've fallen 
in love." And Epstein basically just said "good luck and have a good life." I could tell he was 
not happy. I was very afraid of what he was going to do to me. I thought Epstein or one of his 
powerful friends might send someone to have me killed. 
24. 
I stayed in 
from that point on, withisninisband and away from the life I had 
been forced to live as Epstein's sex slave. I was in 
from late 2002 to October 2013. To 
be clear, I was never in the United States during these years, not even for a short trip to visit my 
mother. And my absence from the United States was not voluntary — I was hiding from Epstein 
out of fear of what he would do to me if I returned to the United States. 
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25. 
In around 2007, after not hearing from anyone for years, out of
 blue I was contacted 
by someone who identified himself with a plain sounding name and claimed he was with the 
FBI. It seemed very odd for someone doing an official criminal investigation to just call up on 
the phone like that. I hadn't heard Epstein's name for years. I didn't know who this person was 
and what it was really about. I wasn't sure what was going on. 
26. 
This man said he was looking into Jeffrey Epstein. The man asked if I had been involved 
with Epstein. My first instinct was to say nothing; because I wasn't sure he was really with the 
FBI or any authorities. I did answer a few basic questions, telling him that I knew Jeffrey 
Epstein and met him at a young age. The whole conversation didn't feel like it was right. This 
man never offered to come and meet with me in person. He instead asked me right off the bat 
about Epstein's sexual practices. I thought it would be strange for a real law enforcement officer 
to behave that way. I became increasingly uncomfortable and suspicious about who was actually 
calling me. 
27. 
The way the conversation was going made me doubt whether I was really talking to an 
FBI agent. It did not seem very official. I became very uncomfortable, so I told him nothing 
more about Epstein. The conversation probably didn't even last three minutes. The conversation 
immediately triggered all of the fears of Epstein and his powerful friends that had caused me to 
escape the first time. If the call accomplished anything, it only put me back in fear and told me 
that I could be found quite easily and had nobody official protecting me. 
28. 
I suspected that the man who called me was working for Epstein or one of Epstein's 
powerful friends. If the man who called me was really an FBI agent and was interested in what I 
knew about Epstein, I thought he would have made some effort to see me personally. I believed 
that if this was really an agent who was investigating Epstein, then he knew who I was and how I 
fit into Epstein's sexual crimes in many different places. Such an agent would send someone to 
meet me in person (who could provide potential protection from Epstein). He never did. 
29. 
Getting a call from this supposed FBI Agent made me very scared. I had left that old life 
behind me and started a new life in a new country in hopes that the powerful people whose 
illegal activities I knew all about would never find me. And now I had been tracked down by 
someone and was frightened. 
30. 
Shortly after this purported FBI call, I was contacted by someone who was clearly 
working for Epstein. This person discussed an investigation into Epstein, and said that some of 
the girls were saying Epstein had sexual contact with them. After they made those allegations, 
they were being discredited as drug addicts and prostitutes. But, on the other hand, if I were to 
keep quiet, I would "be looked after." The fact that this call calm in right after the FBI call 
reinforced my concern that the man I had talked to earlier was not really working for the FBI, but 
was really working for Epstein. I didn't think that the FBI and Epstein would both be working 
together and would both get my phone number at almost exactly the same tint. I played along 
and told this person that I had gotten a call from the "FBI" but that I didn't tell them anything. 
The person was pleased with that. 
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31. 
A short time later, one of Epstein lawyers (not Alan Dershowitz) called me, and then got 
Epstein on the line at the same time. Epstein and his lawyer basically asked again if I was going 
to say anything. The clear implication was that I should not say anything, The way they were 
approaching me, I was afraid of what would happen if I didn't keep quiet. My thought was that if 
I didn't say the right things, I might get hurt. 
32. 
I promised Epstein and his lawyer that I would keep quiet. They seemed happy with that 
and that seemed to me the way to most likely keep me and my family safe. And I did what 
Epstein and his lawyer told me — I kept quiet. 
33. 
I now understand that Epstein reached a non-prosecution agreement with the federal 
government in 2007 and pled guilty to two state crimes in June 2008. No one told me anything 
about those events until much later. In fact, nobody called or came to see me to explain what a 
non-prosecution agreement was, what crimes Epstein could have been charged with, why he was 
not being charged with the crimes he committed, or anything whatsoever about the case. I was 
never offered a chance to meaningfully confer with the prosecutor for the Government, and I was 
never notified of any hearing that could affect me or my rights as a crime victim to ever bring 
charges. 
34. 
On September 3, 2008, the FBI sent a victim notification letter to me. This was the first 
written communication I had received from the FBI. The letter was attached as Exhibit 1 to my 
earlier statement. This kind of written communication, on official FBI stationary, is the way that 
I thought the FBI really communicated with people that they wanted to talk to. The fact that I got 
this official letter from them made me wonder even more whether that the call I had received 
earlier was really from the FBI. The letter that I got did not mention that anyone from the FBI 
had ever called me before. 
35. 
The letter started off with the sentence: "By virtue of this letter, the United States 
Attorney's Office for the Southern District of Florida provides you with the following notice 
because you are an identified victim of a federal offense." That sentence (among others) made it 
seem like this was the first time the FBI was officially contacting me. That was tlx: first time I 
was told about my rights as a crime victim. 
36. 
I did not know what was happening about any criminal prosecution of Epstein at this 
tint. I wanted him prosecuted. And given his constant illegal sexual behavior, I thought it was 
obvious that he should be prosecuted. But after reading the letter, I was confused. The letter did 
not explain what was actually happening or what role, if any, that I could play. In fact, the letter 
thanked me for my assistance during the investigations, yet it wasn't clear what that was 
referring to. 
37. 
Also, the letter did not directly say that Epstein's crimes against me were not going to be 
prosecuted. It just said that "the United States has agreed to defer federal prosecution in favor of 
this state plea and sentence . . .." I did not know what that meant. The letter did not inform me 
how it applied to me. The letter also said that there was "litigation between the United States 
and two other victims regarding the disclosure of the entire agreement between the United States 
and Mr. Epstein." Understanding more about that case now, I realize that the letter did not 
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