UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marrallohnson JANE DOES #1 and #2 Petitioners, v. UNITED STATES Respondent. RESPONDENT'S MOTION FOR SUMMARY JUDGMENT Respondent, United States of America, by and through its undersigned counsel, files its Motion for Summary Judgment, pursuant to Rule 56, Federal Rules of Civil Procedure, and states: I. STATEMENT OF UNCONTROVERTED FACTS 1. On or about September 24, 2007, Jeffrey Epstein entered into a Non-Prosecution Agreement with R. Alexander Acosta, United States Attorney, Southern District of Florida. 2. On or about October 29, 2007, an Addendum to the Non-Prosecution Agreement was executed by Jeffrey Epstein, and Assistant United States Attorne 3. On June 30, 2008, Jeffrey Epstein entered pleas of guilty to various charges in the Circuit Court, Fifteenth Judicial Circuit, in and for Palm Beach County, Florida. Epstein was sentenced the same date, and is currently imprisoned in Palm Beach County, Florida. 4. Jeffrey Epstein has not had any federal criminal charges filed against him in the United States District Court, Southern District of Florida, for the period January 1, 2001, to the present. II. THERE HAS NEVER BEEN ANY "CASE" OR "COURT PROCEEDING" IN THE UNITED STATES DISTRICT COURT, SOUTHERN DISTRICT OF FLORIDA, AGAINST JEFFREY EPSTEIN A. Victim's Claims a On July 7, 2008, Jane Doe filed her Emergency Victim's Petition for Enforcement of Crime Victim's Rights Act, 18 U.S.C. Section 3771 (D.E. 1). Jane Doe alleged that, while she was a minor child, she was the victim of federal crimes committed by Jeffrey Epstein. She alleged that she believed Epstein was the subject of a federal criminal investigation being conducted by the United States Government in the Southern District of Florida. Jane Doe acknowledge that Epstein had recently been prosecuted and pleaded guilty, on June 30, 2008, in the Circuit Court for Palm Beach County, "to various similar st