WVVW.PATHTOJUSTICECOM Oro Tam Class Attie., Personal Injury Wrongful Death Commercial Liogation Farmer, Jaffe, Weissing, Edwards, Fistos Et Lehrman, P.L. January 29, 2015 Wilfredo A. Ferrer United States Attorney Southern District of Florida 99 N.E. 4th Street Miami, FL 33132 RE: Jane Does I and 2 v. United States Case No. 9:08-cv-80736-KAM Dear Mr. Ferrer: As you know, we have corresponded with you in the past on the Crime Victims' Rights Act case captioned above. And you met with Jane Doe No. 1 several years ago, promising (as we understood it) to do what could be done to help protect crime victims' rights in this case. It is in that spirit that we are writing to request your assistance on three motions that we are planning to make shortly in this case. We hope that you will be able to agree to all three requests. We will be filing these motions on Friday, February 6, 2015. Accordingly, the favor of a reply by Wednesday, February 4, 2015, is requested. I. Motion to Amend the Victims' Petition to Conform to Evidence. The first motion will be a motion to amend the victims' petition in this case to conform to the evidence that has developed. As you may recall, Jane Doe No. 1 filed her petition for enforcement of her rights under the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, on July 7, 2008. See Exhibit 1. At that time, Jane Doe No. 1 and the other victs were unaware of the existence of a non-prosecution agreement (NPA). After that day, the victims gradually became aware of the existence of the NPA, as reflected in Jane Doe's reply in support of her petition. See Exhibit 2. And in proceedings held over the next few months, Judge Marra ordered that the NPA be made available to the victims. Unable to reach a stipulation with your office, in 425 North Andrews Avenue • Suite 2 • Fort Lauderdale, Florida 33301 954.524.2820 office 954.524.2822 fax EFTA00210758