Case 9:08-cv-80736-KAM Document 96 Entered on FLSD Docket 09/16/2011 Page 1 of 21 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S RESPONSE TO MOTION FOR "LIMITED" INTERVENTION OF JEFFREY EPSTEIN 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 convicted sex offender Jeffrey Epstein for "limited" intervention in this case under Fed. R. Civ. P. 24(a) and Fed. R. Civ. P. 24(b) (DE 93). The motion for "limited" intervention should be denied for three separate and independent reasons. First, Epstein's motion is not timely. The victims very specifically advised Epstein more than one year ago that they would be filing U.S. Attorney correspondence in this case in an effort to invalid his non-prosecution-agreement. Yet Epstein did not move to intervene until after the Court held a hearing on this very subject. Not only has Epstein delayed his motion to intervene, but the circumstances of the case make it quite clear that his delay was a deliberate tactical maneuver designed to prejudice the victims. Accordingly, the Court should not allow, and thereby reward, this late intervention, and should instead deny his motion as untimely. Second, Epstein has improperly moved for "limited" intervention in this case — by which he apparently means intervention to allow him to raise objections to the victims' motion to use EFTA02753488