EPSTEIN
page 10 / 524 . OCR, unverified
discuss the statements in detail. We also discuss some of the discovery and the cooperating witnesses. What is the
Government position about filing that motion under seal?
Also,
affidavit hasn't been signed because the only regular access to a notary are members of his legal team and we
don't want to witness his signature. We will have him sign it through whatever the process is at MCC or in open court at
our next appearance.
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Garden City, NY 11530
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please notify us immediately by telephone or email and immediately delete this message and all its attachments
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From•
To:
C
"
Subject: Re: bail
Date: Mon, 01 Mar 2021 19:07:51 +0000
Thank you.
Sent from my iPhone
On Mar 1, 2021, at 1:10 PM,
H
wrote:
We wanted to let you know that Ghislaine Maxwell has submitted a third motion for bail. We currently anticipate that
this motion will be resolved on the papers, but we will let you know if a hearing is scheduled.
Best,
Assistant tnUnited States Attorney
Southern District of New York
One Saint Andrew's Plaza
EFTA00021552
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EXHIBIT D
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Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 1 of 14
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 08-80736-Civ-Marra/Johnson
JANE DOE #1 and JANE DOE #2
v.
UNITED STATES
JANE DOE #3 AND JANE DOE #4's CORRECTED MOTION PURSUANT TO RULE 21
FOR JOINDER IN ACTION
COME NOW Jane Doc #3 and Jane Doc #4 (also referred to as "the new victims"), by and
through undersigned counsel, to file this motion pursuant to Federal Rule of Civil Procedure 21
to join this action, on the condition that they not re-litigate any issues already litigated by Jane
Doc #1 and Jane Doe #2 (also referred to as "the current victims"). The new victims have
suffered the same violations of their rights under the Crime Victims' Rights Act (CVRA) as the
current victims. Accordingly, they desire to join in this action to vindicate their rights as well.
Because the new victims will not re-litigate any issues previously litigated by the current victims
(and because they are represented by the same legal counsel as the current victims), the
Government will not be prejudiced if the Court grants the motion. The Court may "at any time"
add new parties to the action, Fed. R. Civ. P. 21. Accordingly, the Court should grant the
motion.'
FACTUAL BACKGROUND
As minor victims of sexual offenses, Jane Doe #3 and Jane Doe #4 desire to proceed by
way of pseudonym for the same reasons that Jane Doe #1 and Jane Doe #2 proceeded in this
fashion. Counsel for the new victims have made their true identities known to the Government.
004288
CONFIDENTIAL
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Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 2 of 14
As the Court is aware, more than six years ago, Jane Doe #1 filed the present action
against the Government, alleging a violation of her rights under the CVRA, 18 U.S.C. § 3771.
DE I. She alleged that Jeffrey Epstein had sexually abused her and that the United States had
entered into a secret non-prosecution agreement (NPA) 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 #1 and Jane Doc #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.
The Court has firmly rejected the United States' position. In a detailed ruling, the Court
concluded that the CVRA extended rights to Jane Doc #1 and Jane Doc #2 even though federal
charges were never filed.
DE 189.
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. Id. The Court deferred ruling on whether the two victims would
be entitled to relief, pending development of a fuller evidentiary record. id.