UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 AND JANE DOE 2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant MOTION OF JEFFREY EPSTEIN FOR PROSPECTIVE LIMITED INTERVENTION AT THE REMEDY STAGE OF THESE PROCEEDINGS Jeffrey Epstein hereby moves, pursuant to Fed. R. Crim. P. 24(a)(2) and 24(b)(1)(B), that he be permitted to intervene in these proceedings when and if they reach the stage at which the Court will consider what remedy to order if it finds that the government violated the plaintiffs' rights under the CVRA. Mr. Epstein does not seek to intervene generally in the case, as the duties and obligations imposed by the CVRA apply solely to the government; the statutory requirements do not run to Mr. Epstein; he had no obligations to the plaintiff under the CVRA. The dispute regarding whether the government violated the plaintiffs' rights under the CVRA is one between the plaintiffs and the government. However, if the case reaches the remedy issue, which this Court has said is contingent upon whether the plaintiffs' "evidentiary proofs will entitle them to [rescission] relief," "a question properly reserved for determination upon a fully developed evidentiary record," Order Denying Government's Motion to Dismiss for Lack of Subject Matter Jurisdiction (Doc. 189) at 11-12, Mr. Epstein has a clear and compelling interest in opposing any remedy that would entail rescission of his non-prosecution agreement with the EFTA00583795