U 7,4 THE UNIVERSITY OF UTAH December 2, Am PAUL G. CASSELL S.J. QUINNEY COLLEGE OF LAW Wilfredo A. Ferrer U.S. Attorney for the Southern District of Florida U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 Re: Jeffrey Epstein's Sexual Assault Victims in Jane Does 1 & 2 v. United States Dear Mr. Ferrer: My co-counsel, Brad Edwards, and I are writing with a simple request: That your Office continue to view Jane Does 1— 33 as "victims" of Jeffrey Epstein's sexual assaults against them. Since 2007, this has been the position of your Office. Indeed, in 2007-08, your Office extracted hundreds of thousands of dollars in payments from Epstein based on representations that these girls were "victims" of his crimes. Recently, however, attorneys in your Office have suggested that these girls might have somehow been "complicit" in their own sexual abuse and therefore not "victims" of Epstein's crimes under the Crime Victims' Rights Act, 18 U.S.C. § 3771. This suggestion is the worst form of victim blaming, which will inevitably cause additional emotional distress to these victims — and a position that finds no support in law. We hope that you will reject this suggestion and adhere to your Office's long-standing position. If for any reason you disagree, we hope that you will extend us the same courtesy that your Office extended to Jeffrey Epstein's counsel and permit us to seek review of your decision through appropriate review in the Justice Department, including review by the Deputy Attorney General. Some background may be useful regarding this request. As you know, from about 1998 to about 2005, Jeffrey Epstein sexually abused dozens of minor girls, including Jane Does 1- 33. Working closely with the FBI, your Office helped to investigate these crimes. In September 2007, your Office entered into a non-prosecution agreement (NPA) with Epstein, in which the Office agreed to provide to Epstein a list of persons "whom it has identified as