Case 9:08-cv-80736-KAM Document 344 Entered on FLSD Docket 12/17/2015 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08.80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 I UNITED STATES JANE DOE NO. 1 AND JANE DOE NO. 2'S MOTION FOR DEPOSITIONS OF GOVERNMENT WITNESSES COME NOW Jane Doe No. I and Jane Doe No. 2 (the "victims"), by and through undersigned counsel, to file this motion for court permission to take the depositions of six important Government witnesses in this action. The witnesses have significant information relevant to the case and the victims should be allowed to depose them. For example, two the witnesses are FBI agents who the Government claims properly informed the victims about Jeffrey Epstein's non-prosecution agreement. Three of the witnesses are Assistant U.S. Attorney's (AUSA's) who were heavily involved in discussions with defense counsel about victim notifications as well as organizing telephone calls and other contacts with victims that the Government maintains adequately informed the victims about the Epstein case. The sixth witness is the U.S. Attorney would made all final decisions on victim notifications and Epstein's non-prosecution agreement (NPA). These witnesses are also apparently going to form the basis for the Government's summary judgment motion regarding the victims' alleged "complicity" in Epstein's crimes. Documentary evidence does not reveal what EFTA00211035