UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08.80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES CONFIDENTIAL MEMORANDUM ON BEHALF OF JANE DOE NO. 1 AND JANE DOE NO. 2 REGARDING MEDIATION COME NOW Jane Doe No. 1 and Jane Doe No. 2 (the "victims"), by and through undersigned counsel, to provide this confidential memorandum, intended to be reviewed solely by mediator U.S. Magistrate Judge Dave Lee Brannon and his supporting staff. The victims believe that they have an extremely strong case for establishing that the Government violated their rights under the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771. They have recently filed a sixty-page summary judgment motion (DE 361), supported by more than one hundred exhibits, primarily incontestable emails between the Government and Jeffrey Epstein's defense counsel. These emails establish incontrovertibly that the Government did not confer with the victims when it reached a deal with politically-connected billionaire Jeffrey Epstein that allowed him to escape any federal prosecution through a non-prosecution agreement (NPA). The victims believe that their summary judgment motion has a high likelihood of success. Nonetheless, in the interest of facilitating a possible resolution, they are willing to see what the Government might be willing to agree to as part of a resolution. 1 EFTA00211249