Case 9:08-cv-80119-KAM Document 560-3 Entered on FLSD Docket 06/10/2010 Page 1 of 4 AFFIDAVIT OF LAMES 1. I am an attorney in good standing-with the Florida Bar ancladmitted-to. pradtice Southern District of Florida. I am a partner in the law firm of =Jaffe Weissing li=iFistos and Lehrman. 2. I am the lead attorney currently representing "Jane Doe" in the case of Jane Doe v. Jeffrey Epstein, case number 08-80893 in federal Court In the Southern District of Florida. I am the lead attorney representing Sane- Doi; Whole civil cciinPlaint Ifiefiei that - tintein sexually molested her numerous occasions when she was a minor. Defendant Epstein has entered into a "non-prosecution agreement" (NPA) with the 3. federal government for sex crimes against minors. Under that agreement, the federal government has agreed not to file criminal charges against Epstein for sex crimes committed against approximately thirty girls, including Jane.Doe. In exchange, Epstein agreed to plead guilty to state law criminal charges involving solicitation of prostitution and procuring a minor for prostitution. The victim of the criminal . charges to which he.has pled was not Jane Doe. 4. Under the NPA, Epstein has agreed not to contest civil liability of any of his approximately thirty .victims — provided that the victim agrees to limit themselves to the damages provided by 18 U.S.C. § 2255 (currently set at $150,000). Jane Doe has not agreed to limit herself to pursuing only $150,000 in damages. Therefore, the terms of the NPA purport to prevent Jane Doe from using the NPA to prove liability. 5. Epstein has filed an answer to Jane Doe's complaint, in which he has invoked his Fifth Amendment right to silence with respect to the allegations that he molested her as a child. Epstein has further argued that this Fifth Amendment Invocation is the functional equivalent of, and must be treated as, a specific denial of the allegations. 6. Defendant Epstein's deposition has been taken on several occasions