Case 9:08-cv-80736-KAM Document 81 Entered on FLSD Docket 05/16/2011 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marraa JANE DOE #1 and JANE DOE #2 v. UNITED STATES / JANE DOE #1 AND JANE DOE #2'S RESPONSE TO MOTION TO INTERVENE OF BRUCE REINHART COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to oppose the motion of attorney Bruce E. Reinhart to permissively intervene in this case under Fed. R. Civ. P. 24(b)(1)(b) (DE #79). The motion to intervene should be denied. Reinhart appears to be merely the cat's paw of a possible real party in interest — Jeffrey Epstein. It is of no concern to Reinhart whether or not this Court rules that the Government violated Jane Doe #1 and Jane Doe #2's rights under the Crime Victims' Rights Act. Thus Reinhart has not established that he has some kind of "common question of law or fact" sufficient to support his permissive intervention into this case. Accordingly, as with the similar motion for Epstein's defense attorneys, his motion to intervene in this Crime Victims' Rights Act case is without merit and should be denied. Alternatively, if the Court elects to permit Reinhart to permissively intervene, legal counsel for Jane Doe #1 and Jane Doe #2 should be allowed to, first, depose Reinhart about his involvement in the Epstein criminal investigation and, second, respond to his baseless motion for Rule 11 sanctions. 1 EFTA02753363