UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE I AND JANE DOE 2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant INTERVENOR JEFFREY EPSTEIN'S MEMORANDUM IN SUPPORT OF HIS ATTENDANCE AT OR PARTICIPATION IN SETTLEMENT CONFERENCE Intervenor Jeffrey Epstein has requested that he be permitted to attend, through counsel, the settlement conference to be convened in this matter. The right to participate in the settlement conference flows inexorably from Judge Marra's granting of Mr. Epstein's motion to intervene as of right at the remedy stage of these proceedings to advocate for why the remedy in this case—to the extent that the plaintiffs can establish their entitlement to any—should not extend to the rescission of his nonprosecution agreement and from his grant of permissive intervention on the issue of release of information falling within the grand jury secrecy protections of Rule 6(e). Although certain constitutional and contractual arguments for maintaining the inviolability of Mr. Epstein's nonprosecution agreement, if plaintiffs still intend to pursue this remedy, are common to both the government and to Mr. Epstein, other compelling reasons why the nonprosecution agreement should not be invalidated are personal to Mr. Epstein and properly presented by him, through counsel, at any settlement conference to be held in this matter. EFTA00589566