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On October 20, 2010, this Court (Marra, J.), entered an order (Doc. #222) remanding to 
the magistrate judge to give Epstein an opportunity to file a reply brief. 
On November 1, 2010, Epstein filed a reply to the response to his motion for protective 
order. Doc. #223. 
On January 5, 2011, this Court (Johnson, J.) entered an order (Doe. #226) resolving 
Epstein's objection. The Order began by stating: "To the extent Epstein's Counsel ask the Court 
to find the subject correspondence privileged and on that basis prohibiting Plaintiffs' Counsel 
from disclosing it in either of the two proceedings, said request is denied." Id. at 3. The Order, 
however, indicated that Jane Does' counsel should file the correspondence under seal with "the 
appropriate institution" so that the institution could "make the determination of admissibility as it 
relates to their respective cases." Id. at 3.1
DISCUSSION 
I. 
JANE DOE #1 AND JANE DOE #2 SHOULD BE PERMITTED TO USE TILE 
CORRESPONDENCE, AS IT IS HIGHLY RELEVANT TO THEIR CASE. 
Under the Magistrate Judge's Order, Jane Doe #1 and Jane Doe #2 are directed to submit 
the correspondence to "the appropriate institute" for a "determination of admissibility." The 
victims have done that, filing only a redacted version of their pleading in the public court file, 
At one point, the Magistrate Judge appeared to think that the "appropriate institution" 
for the CVRA was the Justice Department, as the Magistrate Judge thought that Jane Doe was 
proceeding by way of an "internal Justice Department Complaint procedure." Of course, Jane 
Doe is not proceeding here by way of the internal Justice Department procedure, but rather the 
statutorily authorized procedure for filing a motion in the district court. See 18 U.S.C. § 
3771(d)(3). 
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submitting an unredacted version to the Court. The victims have also submitted all of the 
correspondence to the Court under seal as well. 
The only remaining issue for the Court under the Magistrate Judge's Order is a 
"determination of admissibility as it relates" to the CVRA case. The correspondence is plainly 
admissible, as it is bigWy_relevara to _thityictints1 argument—that--the—Justiee—Departmenuns 
intentionally concealed the existence  of  tlle...nonzprqsecution agreement from them. 
The 
correspondence specifically shows that the U.S. Attorney's Office reached a firm non-
prosecution agreement with Epstein in September 2007, but subsequently deliberately decided to 
conceal the existence of that agreement from the victims. The correspondence further shows that 
the U.S. Attorney's Office was aware of its statutory obligation to inform the victims of the non-
prosecution agreement. Indeed, some of the correspondence involves specific discussion of the 
CVRA and victim notices. 
All relevant evidence is admissible. See Fed. R. Evict. 402. Relevant evidence is 
"broadly defined," United States v. Glasser, 773 F.2d 1553, 1560 (11i° Cir. 1985), as evidence 
that has "any tendency to make the existence of any fact that is of consequence to the 
determination of the action more probably or less probable than it would be without the 
evidence." Fed. R. Evid. 401. Much of the correspondence bears directly on points that the U.S. 
Attorney's Office has already discussed in its pleadings. The Government's Response to the 
Victim's Petition, for example, contains an extensive discussion of the background of the 
investigation, the plea negotiations, and the U.S. Attorney's Office's understanding of its 
obligations under the CVRA. See Government's Resp. to Victim's Emergency Petition for 
Enforcement of Crime Victims Rights Act at 3-6 (dos. #13) (citing Declaration of Asst. U.S. 
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Attorney Marie Villafafia). 
These same subjects were also discussed at length at the Court's 
July 11, 2008, hearing on the matter. See, e.g., Tr. July 11, 2008, at 3-4, 18-19, 22-29. The 
correspondence provides far more detailed information on this subject than was previously 
available to the victims. More important, the correspondence also shows a concerted effort by 
the U.S. Attorney's Office and Epstein to conceal the non-prosecution agreement from the 
victims. 
The victims should therefore be allowed to use the correspondence, as it sheds important 
light on the events surrounding the non-prosecution agreement, which are central to the victims' 
arguments that the U.S. Attorney's Office violated their rights. 
II. 
THE VICTIMS' PLEADINGS SHOULD BE UNSEALED. 
The victims' pleadings should also be unsealed. The victims have, of course, filed only a 
redacted version of their pleading in the court public file, thereby ensuring full compliance with 
the Court's order that they give Epstein a chance to object. But there is no underlying reason for 
sealing of these documents. The Court has already ruled that the correspondence is not 
privileged. Accordingly, no good reason exists for keeping the pleadings confidential, and 
accordingly they should be made part of the Court's public file. 
In addition, no sealing order could be justified in this case. The Eleventh Circuit has 
instructed that the district courts must make substantial findings before sealing records in cases 
before it. For instance, in United States v. Ochaa-Masque, 428 F.3d 1015 (11th Cir. 2005), it 
reversed an order from this Court that had sealed pleadings in a criminal case, emphasizing the 
importance of the public's historic First Amendment right of access to the courts. To justify 
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sealing, "a court must articulate the overriding interest along with findings specific enough that a 
reviewing court can determine whether the closure order was properly entered." Id at 1030. 
Here there is no overriding interest in keeping the pleadings secret. To the contrary, there 
is an overriding interest in having these matters exposed to public light. There is considerable 
public interest in the question of how a serial pedophile could arrange such a lenient plea 
agreement with the U.S. Attorney's Office. There has long been suspicion that Jeffrey_KEstein
was receiving favorable treatment in the criminal investigation because of his wealth and power. 
See, e.g., Abby Goodnough, Questions of Preferential Treatment Are Raised in Florida Sex 
Case, N.Y. TIMES, Sept. 3, 2006, at 19 (noting questions that the public had been left "to wonder 
whether the system tilted in favor of a wealthy, well-connected alleged perpetrator and against 
very young girls who are alleged victims of sex crimes"). Indeed, the interest in the matter is 
strong enough that the widely-viewed television program Law and Order: Special Victim Unit 
devoted an episode to it last month, suggesting in its plot that federal government had intervened 
improperly to prevent effective prosecution. See Law & Order Commemorates Jeffrey Epstein's 
Taste for Teen Hookers, hup://gawkencom/#!5751094/law—order-commemorates-jeffity-
epsteins-taste-for-teen-hookers. Also, there is strong current media interest in the case. "British 
tabloids have gone berserk the past two weeks with the growing scandal over the friendship that 
Prince Andrew, 51, fourth in line for the throne, has maintained with the multimillionaire, a 
registered sex offender [Jeffrey Epstein]." Jose Lambiet, Prince's Friendship with Pedophile 
Causes Furor Across the Pond, PALM BEACH POST, Mar. 9, 2011, at 2B. There are also current 
reports that the FBI is reopening its investigation into the matter. See Sharon Churcher, FBI Will 
Reopen Case Against Prince's Friend, SUNDAY MAIL (UK), Mar. 6, 2011. 
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Of course, the Court is not being asked in this pleading to decide the wisdom of the non-
prosecution agreement entered into by the U.S. Attorney's Office. The public can make up its 
own mind on that subject — but only if it is allowed to review the facts surrounding the 
negotiation of the agreement and the treatment of crime victims during the negotiation process. 
The Court should accordingly unseal the victims' pleading. 
M. 
EPSTEIN HAS NO "STANDING" TO RAISE ANY OBJECTIONS WITHOUT 
INTERVENING IN THE CVERA CASE. 
As a courtesy to Epstein, we have provided copies of all these pleadings to defendant 
Epstein. It should be noted, however, that while Epstein is well aware of this CVRA action, he 
has chosen not to intervene. Cf Fed. R. Civ. P. 24 (providing procedures for intervention). 
Without intervening in the case, he cannot raise any objections to use of the correspondence in 
this case — or to any relief that the Court might grant to the victims. 
The victims have no objection to Epstein intervening in this case — at this time. If, 
however, Epstein delays intervention until after a reasonable period of time, the victims will 
argue that his motion to intervene is untimely. The victims will argue that any attempted 
intervention by Epstein after the date on which the Government must respond to the victims' 
motion for a finding of violation of the CVRA is untimely, as that is when the victims must 
begin drafting reply pleadings. See United States' Jefferson County, 720 F.2d 1511, 1516 (1Ith
Cir. 1983) (listing factors to be considered in determining whether motion to intervene is timely). 
CERTIFICATE OF CONFERENCE 
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The Government has no objection to the motion to unseal. On August 26, 2010, Epstein 
was given notice of the victims' intent to use these materials in this case. He has yet to intervene 
in this case, let alone interpose any objection in this case. 
CONCLUSION 
For all the foregoing reasons, the Court should allow Jane Doe #1 and Jane Doe #2 to use 
the U.S. Attorney's correspondence in this CVRA action. The Court should therefore unseal the 
victims redacted pleading, entering the full pleading — and the attached correspondence — as 
publicly accessible records. 
DATED: March 21, 2011 
Respectfully Submitted, 
s/ Bradley J. Edwards 
Bradley J. Edwards 
FARMER, JAFFE, WEISSING, 
EDWARDS, FISTOS & LEHRMAN, P.L. 
and 
Paul G. Cassell 
Pro Hac Vice 
S.J. Quinney College of Law at the 
University of Utah 
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CERTIFICATE OF SERVICE 
The foregoing document was served on March 21, 2011, on the following using the Court's 
CM/ECF system: 
Assistant U.S. Attorney 
Attorney for the Government 
Joseph L. Ackerman, Jr. 
Fowler White Burnett PA 
Criminal Defense Counsel for Jeffrey Epstein 
(courtesy copy of pleading via U.S. mail) 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 08-80736-Civ-Marra/Johnson 
JANE DOES #1 AND #2, 
Petitioners, 
v. 
UNITED STATES OF AMERICA, 
Respondent. 
UNITED STATES' RESPONSE TO PETITIONERS' MOTION 
TO USE CORRESPONDENCE TO PROVE VIOLATIONS OF THE 
CRIME VICTIMS' RIGHTS ACT AND TO HAVE THEIR 
UNREDACTED PLEADINGS UNSEALED !DEMI 
The United States of America, by and through the undersigned, hereby files this Response 
in partial opposition to Petitioners' Motion to Use Correspondence to Prove Violations of the Crime 
Victims' Rights Act and to Have Their Unredacted Pleadings Unsealed (DE51). As explained in the 
United States' Response to Petitioners' Motion for Finding of Violations of the Crime Victims 
Rights Act (DE48), and Petitioners' Motion to Have Their Facts Accepted (DE49), it is the position 
of the United States that this case presents a straightforward legal issue and no additional facts or 
evidence are necessary for the resolution of the matter. The United States also was not a party to the 
action wherein Petitioners were ordered to obtain court approval prior to using the correspondence 
as evidence.' Accordingly, the United States takes no position as to that portion of Petitioners' 
'The Government does note, however, that Petitioners have filed the Non-Prosecution 
Agreement ("NPA") in the public portion of the Court file. (DE48, Ex. E.) That document is the 
subject of a Protective Order in the instant suit. (See DE26.) Petitioners have previously moved to 
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Motion, although it notes that merely attaching the correspondence to a motion without 
authenticating it does not make it admissible evidence. 
With regard to Petitioners' Motion to Unseal, when Petitioners' originally conferred with the 
government, the undersigned stated that there was no objection to the motion to unseal. However, 
a copy of what Petitioners intended to file was not provided. Also, upon undertaking some research 
in preparation for a response to DE49, it was determined that the Government could not, in 
accordance with our legal obligations, agree to unsealing the documents referenced herein. 
Accordingly, for the reasons set forth herein, the United States opposes, in part, Petitioners' Motion 
to Unseal. Instead, the United States has filed herewith, under seal, a redacted version of DE48 and 
the relevant portions of Exhibit A, and asks the Court to unseal only redacted versions, if the Court 
decides to grant Petitioners' Motion to Unseal. 
CERTAIN PORTIONS OF PETITIONERS' PLEADINGS RUN AFOUL OF FED. R. 
CRIM. P. 6(e) AND/OR CONSTITUTIONAL MANDATES. 
Several of the "facts" that Petitioners include in their Statement of Undisputed Facts allege 
that Jeffrey Epstein ("Epstein") and others have committed crimes for which they were never 
charged or convicted. Others refer to matters that were occurring before the grand jury. The 
documents contained in Exhibit A to their pleading contain similar materials. The Federal Rules of 
Criminal Procedure and constitutional mandates dictate that these should be kept sealed. 
A. 
Federal Rule of Criminal Procedure 6(e) 
Rule 6(e) states that "an attorney for the government" "must not disclose a matter occurring 
unseal the NPA in this action, (see DE28,) which the Court has denied. (DE36.) Although the 
Government acknowledges that the NPA is a matter of public record in other courts, it is not a public 
record here. As discussed below, its disclosure, which includes names of uncharged persons, 
implicates Due Process. 
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Case 9:08-cv-60736-KAM Document 60 Entered on FLSD Docket 04/07/2011 Page 3 of 10 
before the grand jury." Fed. IL Crim. P. 6(e)(2)(B). Furthermore, court hearings and court records 
and orders must be sealed "to the extent and as long as necessary to prevent the unauthorized 
disclosure of a matter occurring before a grand jury." Fed. R. Crim. P. 6(eX5) & (6). 
Courts have construed "a matter occurring before the grand jury" to include "events which 
have already occurred before the grand jury, such as a witness's testimony, [and] matters which will 
occur, such as statements which reveal the identity of persons who will be called to testify or which 
report when the grand jury will return an indictment." In re Grand Jury Investigation, 610 F.2d 
202, 216-17 (5th Cir. 1980). 
While Petitioners were merely asking the Government to agree with their assertions of " fact" 
based upon materials Petitioners had received from counsel for Epstein, rather than asking the 
Government to make affirmative disclosures of grand jury material, "Rule 6(e) does not create a type 
'It is worth noting that, within the same case, a court can take differing positions on this. 
Compare: 
With: 
['Me disclosure of information obtained from a source independent of the grand jury 
proceedings, such as a prior government investigation, does not violate Rule 6(e). 
A discussion of actions taken by government attorneys or officials, e.g., a 
recommendation by the Justice Department attorneys to department officials that an 
indictment be sought against an individual does not reveal any information about 
matters occurring before the grand jury. Nor does a statement of opinion as to an 
individual's potential criminal liability violate the dictates of Rule 6(e). 
Disclosures which expressly identify when an indictment would be presented to the 
grand jury, the nature of the crimes which would be charged, and the number of 
persons who would be charged run afoul of the secrecy requirements codified in Rule 
6(e). 
In re Grand fray Investigation, 610 F.2d at 217, 218. In light of these conflicting directives, the 
government must err, if at all, on the side of treating all information related to grand jury proceedings 
as "matters occurring before the grand jury." 
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of secrecy which is waived once public disclosure occurs." In re Motions ofDow Jones & Co., Inc., 
142 F.3d 496, 505 (D.C. Cir. 1998) (quoting In re North, 16 F.3d 1234, 1245 (D.C. Cir. 1994)). 
"[E]ven if material concerning the grand jury investigation had been disclosed to the public, the 
Government attorney .. . had a duty to maintain grand jury secrecy. This attorney could neither 
confirm nor deny the information presented by the 'external party.'" Senate of the Commonwealth 
of Puerto Rico v. United States Dept of Justice, 1992 WL 119127 at '3 (D.D.C. May 13, 1992) 
(citing Bony v. United States, 740 F. Supp. 888, 891 (D.D.C. 1990) ("Rule 6(e) does not create a 
type of secrecy which is waived once public disclosure occurs. The Government is obligated to 
stand silent regardless of what is reported, accurate or not, by the press."). 
The reasons for Rule 6(e) are multiple: 
In addition to preventing adverse pretrial publicity about a person who may be 
indicted and subsequently tried, secrecy protects the reputation of a person under 
investigation who is not indicted. The secrecy requirement also encourages reluctant 
witnesses to testify without fear of reprisals from those against whom testimony is 
given, prevents tampering with grand jury witnesses in an effort to alter their trial 
testimony, and permits the grand jury to deliberate free from the influence of 
publicity. Finally, secrecy prevents disclosures to persons who may be interested in 
the investigation if the facts are known or might attempt to escape if they have reason 
to believe certain indictments will issue. 
United States v. Eisenberg, 711 F.2d 959, 961 (11th Cir. 1983) (citing United States v. Procter & 
Gamble Co., 356 U.S. 677, 681 n.6 (1958)). 
Several of the "facts" contained in Petitioners' submission contain allegations related to 
matters occurring before the grand jury. Pursuant to Fed. R. Crim. P. 6(e), the Government cannot 
confirm or deny the accuracy of those allegations. Likewise, portions of Exhibit A to Docket Entry 
48 refer to matters occurring before the Grand Jury. Notwithstanding Petitioners' citations to the 
First Amendment and the interest of the press and the public in this case, the First Amendment right 
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Case 9:08-cv-80736-KAM Document 60 
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of access is not absolute and sealing is appropriate in connection with grand jury proceedings. As 
explained by Judge Jordan in United States v. Steinger, 626 F. Supp. 24i 1231 (S.D. Fl. 2009): 
"The proper functioning of our grand jury system depends upon the secrecy of grand 
jury proceedings," Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 218 
(1979), and this expectation of privacy is generally codified in Rule 6(e) of the 
Federal Rules of Criminal Procedure 
There is a second reason why sealing is currently appropriate. As noted above, the 
Public Integrity Section has determined that six former or present public officials had 
no knowledge of, or involvement in, the alleged wrongdoing, and its probe continues 
against others who have yet to be indicted or cleared. The sealed documents and 
transcripts refer to many of those individuals by name. Disclosure of those names, 
and the matters being investigated, could have devastating consequences for those 
persons who have been cleared of any misconduct, as well as for those still under 
investigation. As William Shakespeare put it centuries ago, "the purest treasure 
mortal times afford is spotless reputation; that away, men are but guilded loam, or 
painted clay." W. Shakespeare, RICHARD II, ACT 1, SCENE 1, lines 177-78 (1597). 
And if it is true that "at every word a reputation dies," A. Pope, THE RAPE OF THE 
Lock, CANTO III, line 16 (1712), then public access to the sealed documents and 
transcripts here could easily kill many reputations. This overriding interest is, I 
believe, of a higher value under [Ness-Enterprise Co. v. Superior Court, 464 U.S. 
501 (1984)] so as to warrant sealing, and provides good cause under the common-law 
access balancing test to preclude disclosure. 
Swinger, 626 F. Supp. 2d at 1235-36 (brackets in original omitted). See also In re Petition of 
American Historical Ass 'n, 62 F. Supp. 2d 1100, 1103 (S.D.N.Y. 1999) ("A cornerstone of the grand 
jury secrecy tide is the protection of the reputations and well-being of individuals who are subjects 
of grand jury proceedings, but are never indicted . . [T]he rule of secrecy seeks to protect . . 
unindicted individuals from the anxiety, embarrassment, and public castigation that may result from 
disclosure.") (cited in Steinger). 
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B. 
Due Process 
As noted above, one of the reasons behind 6(e) is to protect the reputations of persons who 
are under investigation but not indicted. This is a corollary to what the Court of Appeals found to 
be a due process protection afforded by the Fifth Amendment of the United States Constitution — 
namely, "that the liberty and property concepts of the Fifth Amendment protect an individual from 
being publicly and officially accused of having committed a serious crime, particularly where the 
accusations gain wide notoriety." See In re Smith, 656 F.2d 1101, 1106 (5th Cir. 1981) (citation 
omitted).' In Smith, the petitioner filed a motion seeking to have his name stricken from the factual 
proffers of two criminal defendants. Smith had not been criminally charged or convicted. The Court 
of Appeals agreed with Smith, castigating the Government: 
no legitimate governmental interest is served by an official public smear of an 
individual when that individual has not been provided a forum in which to vindicate 
his rights... . 
[W]e completely fail to perceive how the interests of criminal justice were advanced 
at the time of the plea hearings by such an attack on the Petitioner's character. The 
presumption of innocence, to which every criminal defendant is entitled, was 
forgotten by the Assistant United States Attorney in drafting and reading aloud in 
open court the factual resumes which implicated the Petitioner in criminal conduct 
without affording him a forum for vindication. 
Id. at 1106, 1107. The Court of Appeals ordered the District Court Clerk's Office to "completely 
and permanently obliterate and strike from the records of the pleas of guilty . . . any and all 
identifying reference to or name of Mr. Smith, the Petitioner, so that such references may not be used 
as a public record to impugn the reputation of Petitioner." Id. at 1107. The Court further ordered 
that all of the pleadings in the case be scaled. Id. 
'This opinion of the Fifth Circuit was made binding precedent in the Eleventh Circuit 
pursuant to Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981) (en bane). 
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Courts have interpreted Smith to apply not only to references to unindicted co-conspirators 
in indictments and factual proffers, but also to motion papers. See, e.g., United States v. Anderson, 
55 F. Supp. 24 1163, 1168 (D. Kan. 1999) ("After carefully reviewing the government's moving 
papers on the conflict of interest issue, the court can find no reason why the government might have 
'forgotten' the presumption of innocence in such a public pleading . .") (citing Smith, 656 F.2d at 
1107); United States v. Holy Land Foundation, 624 F.3d 685 (5th Cir. 2010) (Fifth Amendment 
rights of organization were violated when its name was listed among 246 unindicted coconspirators 
in pre-trial brief). 
Petitioners' "Statement of Undisputed Material Facts," and Exhibit A to DE48 contain 
allegations related to uncharged crimes against not only Epstein but several other individuals.' In 
keeping with the First Amendment's limited right of access, the United States does not oppose the 
motion to unseal in flit rather, pursuant to Smith and its progeny, the relevant allegations should be 
redacted. See, e.g., Smith, 656 F.2d at 1107 (ordering Clerk's Office to "completely and permanently 
obliterate and strike from the records ... any and all identifying reference to or name of Mr. Smith" 
and sealing all other related records); United States v. Anderson, 55 F. Supp. 24 1163, 1170 (D. Kan. 
1999) (ordering Clerk's Office to "completely and permanently strike" all references to petitioners); 
Steinger, 626 F. Supp. 2d at 1237 (concluding that documents must be kept hilly sealed because 
"redactions would be so heavy as to make the released versions incomprehensible and 
unintelligible"). 
Filed herewith, under seal in accordance with Rule 6(e), is a proposed redacted copy of DE48 
and the relevant pages of Exhibit A. With respect to DE48 itself, the Government has only redacted 
°The NPA also contains such references. 
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language that in some way suggests that the Government (including the FBI) is the source of the 
allegation. However, the Government reiterates, as it has stated in its opposition to "Petitioners' 
Motion to Have Their Statement of Undisputed Material Facts Accepted" that it denies all of the 
allegations contained in Petitioners' Statement that aver violations of law by Epstein or others that 
have not resulted in a conviction, including but not limited to paragraphs 1, 2, 4, 5, 10, 11, 17, 37, 
52, and 53. With respect to Exhibit A, out of 359 pages, the United States only seeks to redact 40 
full pages, and seeks to redact individual words or sentences on an additional 20 pages. 
The United States further respectfully requests that the Court allow it to redact the personal 
telephone number and email address of its personnel, that appears on eighteen pages in Exhibit A 
to DE48. The information serves no evidentiary purpose. 
The United States has conferred with counsel for Petitioners on these matters. Petitioners 
have no objection to the redaction of the personal telephone number and email address of 
government personnel and to the redaction of individual statutory references in Exhibit A. 
Petitioners object to redactions of DE48 and to further redactions ofErthibit A. For ease of reference 
by the Court, the redactions that arc agreed to are marked in blue; those that are in dispute are 
marked in red. Redactions that appear in plain black are pre-existing (i.e., they are redactions done 
either by Petitioners or by Epstein's counsel). 
CONCLUSION 
For the foregoing reasons, the United States respectfully requests that the Court deny, in part, 
Petitioners' Motion to Unseal its Motion for Finding of Violations of Crime Victim's Rights Act and 
Request for Hearing on Appropriate Remedies [DE481 and Exhibit A thereto and, instead, that the 
Court unseal only a redacted version of those pleadings, that is, the redacted documents filed 
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herewith. 
Respectfully submitted, 
WIFREDO A. FERRER 
UNITED STATES ATTORNEY 
By: 
Assistant U.S. Attorney 
Fla. Bar No. 0936693 
Attorney for Respondent 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on April 7, 2011, I electronically filed the foregoing document 
with the Clerk of the Court using CM/ECF. 
Assistant U.S. Attorney 
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Paul G. Cassell 
S.J. Quinney College of Law at the 
University of Utah 
SERVICE LIST 
Jane Does I and 2 v. United States, 
Case No. 08-80736-CIV-MARRA/JOHNSON 
United States District Court, Southern District of Florida 
Lehrman, P.L. 
Attorneys for Jane Doe # 1 and Jane Doe # 2 
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