291-03.pdf

EXHIBIT 3 Case 9:08-cv-80736-KAM Document 291-3 Entered on FLSD Docket 01/21/2015 Page 1 of 3 Case 9:08-cv-80736-KAM Document 291-3 Entered on FLSD Docket 01/21/2015 Page 2 of 3 Farmer, Jaffe, Weissing, Edwards, Fistos Et Lehrman, P.L. Commercial Lltiga1lon WWW.PATHTOJUSTICE.COM VIA CERTIFIED MAIL 7009 1680 0000 4959 2808 Wifredo A. Ferrer United States Attorney Southern District of Florida 99 N.E. 4th Street Miami FL 33132 November 19, 2014 RE: Jane Does 1 and 2 v. United States Case No. : 08-80736-Civ-Marra/Johnson Dear Mr. Fener: I sent you a letter in August requesting your office's stipulation to our adding Jane Doe #3 in this case. Unfortunately, we did not receive a response from your office. We are hopeful that your lack of a response was simple oversight. In addition to following up on the August letter we are now requesting your Stipulation to the adding of Jane Doe #4 as well. Her true name is She was identified by your office during the Federal Investigation, and consequently her name appeared on the list of victims attached to Mr. Epstein's Non-Prosecution Agreement. As we expressed in our personal meetings a couple years ago we don't understand the tactical decision to be adversarial to the victims of known sexual abuse on every point in this litigation. Now that many of those issues we discussed have been resolved in our favor it seems to make even more sense to avoid engaging in unnecessary battles that could only serve the purpose of delaying the victims rights to have this case resolved on its merits. As I indicated in my August letter requesting your stipulation to the adding of Jane Doe #3 adcling Jane Doe #4 will also not delay matters so long as we can stipulate to her being added. Without a stipulation we foresee litigation over this point, which will produce nothing but additional delay - and further question about your Office's commitment to full protection of victims' rights under the Crime Victims Rights Act. 425 Nort h Andrews Avenue • Suite 2 • Fort Lauderdale, Florida 33301 954.524.2820 office 954.524.2822 fax Case 9:08-cv-80736-KAM Document 291-3 Entered on FLSD Docket 01/21/2015 Page 3 of 3 Wifredo A. Fen-er November 19 2014 Page 2 Your office is very familiar with and her circumstance. She was sexually trafficked and abused by Mr. Epstein (and others at the direction of Mr. Epstein) not only in this jurisdiction but tlu·oughout the United States and beyond. Unlike Jane Doe #3, Jane Doe #4 was included as a named victim in the PA. There is no statute of limitations in bringing such claims, and I think we would agree that the current case is the best vehicle tlu·ough which to bring these claims, as opposed to forcing us to file new actions and starting over on issues and claims inextricably intertwined with the current litigation. We don' t see a good reason for denying our motion, so we anticipate prevailing at the end. But even if you were to object and prevail on the motion to add her to the current litigation, the only consequence would be that would then file a separate CVRA lawsuit, something she is entitled to do because the CVRA contains no time limit. We are simply trying avoid all this entirely uru1ecessary complication. We have tlu·oughout this case consciously avoided filing anything that would u1mecessarily cast your office in a bad light, and it is again with that in mind that we request your stipulation here. We need this stipulation by December 10, 2014 to avoid delaying any other aspects of this case. We will not file any pleadings on this subject before that date. Lastly we feel that we are once again at a stage in this litigation where it may make sense to meet again face-to-face to attempt to resolve, or at least naITow some issues in an effort to avoid litigating some of the matters that we will be forced to litigate if the parties continue along this umeasonably adversarial path. Thanks in advance for considering thjs request. Very truly yours, FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN P.L. ~-s~ Bradley J. Edwards - BJE::rnwk Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue • Suite 2 • Fort Lauderdale, Florida 33301 954.524.2820 office 954.524.2822 f ax