EFTA01099175

Dershowitz from being physically present for the deposition; and (4) requires the deposition to 
be taken at the offices of her counsel, BSF. None of Jane Doe No. 3's proposed modifications 
are warranted under Florida law. 
First, the proposed "limitations" on Jane Doe No. 3's questioning would unreasonably 
narrow the scope of the deposition. Jane Doe No. 3 requests that she not be asked any questions 
"about [her] experiences as a sexually trafficked minor"; "about individuals that she was 
sexually trafficked to"; "about any rapes that occurred when she was a minor child"; or "about 
anything related to her sexual activity either as a minor or thereafter." Motion to Quash, at 12. 
As set forth above, these issues are directly relevant to the issues in dispute in this litigation — 
namely, whether Dershowitz made the purportedly defamatory statements while knowing that 
the Joinder Motion was "well-founded." Moreover, Jane Doe No. 3 has provided first-hand, 
public accounts regarding these very topics on several different occasions, including in an on-
the-record interview that was published by a widely read British tabloid and in which she 
included details that not even a tabloid would publish them. The obvious inference is that Jane 
Doe No. 3 received payment for her "exclusive interview" to the tabloids, and in all events she 
voluntarily spoke to the media about the same experiences as to which Dershowitz seeks 
discovery. She can hardly claim "embarrassment" as a reason not to give important evidence 
within her knowledge in light of her previous volunteered and detailed public accounts of her 
time as a "sex slave." These voluntary disclosures necessarily constitute, as a matter of law, a 
waiver of any assertion of privacy. See Berkeley, 699 So. 2d at 791. 
Second, Jane Doe No. 3 has not provided any support for her speculative assertions that 
Dershowitz's attorneys are likely to use harassing or derogatory language in a deposition, and the 
suggestion that they would do so insulting. The topics at issue (which Jane Doe No. 3 herself put 
21 
EFTA01099195

at issue) must be fully explored, but counsel for Dershowitz will of course treat the witness with 
courtesy and respect and will conduct the deposition in a manner that fully comports with the 
Florida Rules of Civil Procedure, as well as the Florida Rules of Professional Conduct. 
Moreover, it was she, through her lawyers, who made the most insulting and derogatory 
allegations against Dershowitz, which he has the right to challenge. 
As explained below, Dershowitz is concerned about the conduct of the deposition from 
the other side, namely whether Jane Doe No. 3's counsel will improperly instruct the witness not 
to answer or otherwise coach the witness. To avoid any problems, Dershowitz requests that the 
Court appoint a Special Magistrate to preside over the deposition pursuant to Rule 1.490(b) of 
the Florida Rules of Civil Procedure and handle any disputes that may arise during the course of 
the deposition.3
Third, the Court may not, as a matter of law, preclude Dershowitz from being physically 
present at the deposition of Jane Doe No. 3. "It is a venerated principle that a party has a right to 
be present at an oral deposition." Ferrigno v. Yoder, 495 So. 2d 886, 888 (Fla. 2d DCA 1986) 
(citing Cacace v. Associated Technicians, Inc., 144 So. 2d 82 (Fla. 3d DCA 1962) and further 
explaining that, although a court may properly exclude a party in some circumstances, that 
measure should be "ordered rarely indeed" because a party's right to be present at each stage of a 
lawsuit is "virtually sacrosanct" (internal quotation marks omitted)). Jane Doe No. 3's purported 
fear of being in close physical proximity to Dershowitz because he is an "incredibly powerful 
individual," Motion to Quash, at 5, is not the sort of "rare" circumstance that warrants an order 
precluding Dershowitz from attending the deposition in person. 
3 The appointment of a Special Magistrate requires the consent of the parties. Accordingly, 
Dershowitz has asked counsel for Jane Doe No. 3 and counsel for Plaintiffs to consent to this 
request. That request is pending. 
22 
EFTA01099196

Dershowitz is 76 years old. He has been a professor (now emeritus) at Harvard Law 
School for decades and is a highly regarded attorney, who is bound to act and will act in 
accordance with professional standards, as he always has. Jane Doe No. 3 will be accompanied 
by counsel, as will Dershowitz. The notion that Jane Doe No. 3 is afraid to be in the same room 
with Dershowitz is a preposterous litigation tactic, and Dershowitz intends to challenge the 
truthfulness of that assertion if Jane Doe No. 3 makes it under oath. 
Moreover, the whole premise for Jane Doe No. 3's request (and many of the other 
limitations on discovery sought in the Motion to Quash) is that her allegations against 
Dershowitz are true. The Court cannot and must not accept that premise, which Dershowitz 
contests in the strongest possible terms. This is especially true in light of the fact that none of 
Jane Doe No. 3's allegations have ever been investigated or corroborated by any law 
enforcement or objective investigators, and at least some of her allegations — especially those 
involving former President Clinton and Vice President Gore — are preposterous on their face. 
Fourth, the Court should deny Jane Doe No. 3's request to conduct the deposition at the 
offices of her counsel, BSF. Because Jane Doe No. 3's lawyers refused to accept service of a 
subpoena and put Dershowitz to the trouble and expense of obtaining a commission and serving 
Jane Doe No. 3 in Colorado, Dershowitz could have insisted on taking the deposition in 
Colorado. Instead, the parties have agreed that Dershowitz will take the deposition of Jane Doe 
No. 3 in Florida. There is no reason that the deposition should not be taken at the office of the 
attorneys who noticed the deposition as is customary, absent agreement on some other mutually 
acceptable site in the Fort Lauderdale area. 
23 
EFTA01099197

REOUEST FOR APPOINTMENT OF SPECIAL MAGISTRATE 
As set forth above, Dershowitz respectfully requests that the Court appoint a Special 
Magistrate to preside over the deposition of Jane Doe No. 3. Rule 1.490(b) provides that "[t]he 
court may appoint members of The Florida Bar as special magistrates for any particular service 
required by the court, and they shall be governed by all the provisions of law and rules relating to 
magistrates except they shall not be required to make oath or give bond unless specifically 
required by the order appointing them." As noted previously, Dershowitz has asked counsel for 
Jane Doe No. 3 and counsel for Plaintiffs to consent to the appointment of a Special Magistrate. 
That request is pending. 
CONCLUSION 
The Court should deny the Motion to Quash because (1) the documents and testimony 
that Dershowitz seeks are relevant to this litigation; and (2) Dershowitz's need for this 
information clearly outweighs Jane Doe No. 3's privacy interests, which she has waived in any 
event given her voluntary statements to the press and the public about the very same issues. The 
Court also should deny Jane Doe No. 3's request for a protective order because the proposed 
modifications to the subpoena are not reasonable. The Court should also enter a reference 
pursuant to Rule 1.490 that appoints a Special Magistrate to preside over the deposition of Jane 
Doe No. 3. 
24 
EFTA01099198

Dated: May 15, 2015 
Respectfully Submitted, 
s/ Thomas E. Scott 
Thomas E. Scott 
Florida Bar No. 149100 
Thomas.scott@csklegal.com 
Steven R. Safra 
Florida Bar No. 057028 
Steven.safra@csklegal.com 
COLE, SCOTT & KISSANE, P.A. 
Dadeland Centre II, 14th Floor 
9150 South Dadeland Boulevard 
Miami, Florida 33156 
Richard A. Simpson 
(admitted pro hac vice) 
rsimpson@wileyrein.com 
Mary E. Borja 
(admitted pro hac vice) 
mborja@wileyrein.com 
Ashley E. Eiler 
(admitted pro hac vice) 
aeiler@wileyrein.com 
WILEY REIN LLP 
1776 K Street NW 
Counsel for Alan M. Dershowitz 
EFTA01099199

CERTIFICATE OF SERVICE 
WE HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-
mail on May 15, 2015 to: Jack Scarola, Esquire, Searcy Denny et al jsx@searcylaw.com and 
mep@searcylaw.com, counsel for Plaintiffs, and to Sigrid McCawley, Esquire, Boies Schiller & 
Flexner, counsel for Jane Doe No. 3, at smccawley@bsfllp.com. 
COLE, SCOTT & KISSANE, P.A. 
Attorneys for Defendant 
9150 S. Dadeland Blvd. 
Suite 1400 
Miami, Florida 33156 
thornas.scott@csklegal.com 
steven.safra @cskle al.com 
By: 
s/ Thomas E. Scott 
THOMAS E. SCOTT 
FBN: 149100 
STEVEN R. SAFRA 
FBN: 057028 
26 
EFTA01099200

EXHIBIT A 
EFTA01099201

Case 9:08-cv-80736-KAM Document 324 Entered on FLSD Docket 04/07/2015 Page 1 of 10 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.:08-CV-80736-ICAM 
JANE DOE 1 and JANE DOE 2, 
Petitioners, 
vs. 
UNITED STATES OF AMERICA, 
Respondent. 
ORDER DENYING PETITIONERS' MOTION TO JOIN UNDER RULE 21 AND 
MOTION TO AMEND UNDER RULE 15 
This cause is before the Court on Jane Doe 3 and Jane Doe 4's Corrected Motion 
Pursuant to Rule 21 for Joinder in Action ("Rule 21 Motion") (DE 280), and Jane Doe 1 and Jane 
Doe 2's Protective Motion Pursuant to Rule 15 to Amend Their Pleadings to Conform to 
Existing Evidence and to Add Jane Doe 3 and Jane Doe 4 as Petitioners ("Rule 15 Motion") (DE 
311). Both motions are ripe for review. For the following reasons, the Court concludes that they 
should be denied. 
I. Background 
This is an action by two unnamed petitioners, Jane Doe I and Jane Doe 2, seeking to 
prosecute a claim under the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771. (DE I). 
Generally, they allege that the respondent Government violated their rights under the CVRA by 
failing to consult with them before negotiating a non-prosecution agreement with Jeffrey Epstein, 
who subjected them to various sexual crimes while they were minors. (Id.). Petitioners initiated 
this action in July 2008. 
I([LO. 
EFTA01099202

Case 9:08-cv-80736-KAM Document 324 Entered on FLSD Docket 04/07/2015 Page 2 of 10 
On December 30, 2014, two other unnamed victims, Jane Doe 3 and Jane Doe 4, moved 
to join as petitioners in this action pursuant to Federal Rule of Civil Procedure 21. (DE 280). 
Petitioners (Jane Doe 1 and Jane Doe 2) support the Rule 21 Motion. (LI. at 11). Jane Doe 3 and 
Jane Doe 4 argue that they "have suffered the same violations of their rights under the [CVRAJ 
as the" Petitioners, and they "desire to join in this action to vindicate their rights as well." ( 
at 
I). The Government vehemently opposes joinder under Rule 21. (DE 290). The Government 
argues that Rule 15 is the proper procedural device for adding parties to an action, not Rule 21. 
(a. at 1). 
"[O]ut of an abundance of caution," Petitioners filed a motion to amend their petition 
under Rule 15, conforming the petition to the evidence and adding Jane Doe 3 and Jane Doe 4 as 
petitioners. (DE 311 at 2). The Government opposes the Rule 15 Motion as well. (DE 314). 
Among other things, the Government argues that amending the petition to include Jane Doe 3 
and Jane Doe 4 should be denied because of their undue delay in seeking to join the proceedings, 
and the undue prejudice that amendment will cause. (Id.). 
After considering the parties' submissions and the proposed amended petition, the Court 
finds that justice does not require amendment in this instance and exercises its discretion to deny 
the amendment. 
II. Discussion 
"The decision whether to grant leave to amend a complaint is within the sole discretion of 
the district court." Laurie v. Ala. Ct. Crim. Apps., 256 F.3d 1266, 1274 (11th Cir. 2001). "The 
court should freely give leave when justice so requires." Fed. R. Civ. P. 15(a)(2). Justice does 
not require amendment in several instances, "includ[ing] undue delay, bad faith, dilatory motive 
2 
EFTA01099203

Case 9:08-cv-80736-KAM Document 324 Entered on FLSD Docket 04/07/2015 Page 3 of 10 
on the part of the movant, . . . undue prejudice to the opposing party by virtue of allowance of the 
amendment, [and] futility of amendment?" Laurie, 256 F.3d at 1274 (quoting Foman v. Davis, 
371 U.S. 178, 182 (1962)). In addition to considering the effect of amendment on the parties, the 
court must consider 'The importance of the amendment on the proper determination of the merits 
of a dispute." 6 Wright & Miller, Fed. Prac. & Fed. P. § 1488, p. 814 (3d ed. 2010). Justice does 
not require amendment where the addition of parties with duplicative claims will not materially 
advance the resolution of the litigation on the merits. See Herring v. Delta Air Lines. Inc., 894 
F.2d 1020, 1024 (9th Cir. 1989). 
A. 
Rule 21 Motion 
Jane Doe 3 and Jane Doe 4's first attempt to join in this proceeding was brought under 
Rule 21. (DE 280). "If parties seek to add a party under Rule 21, courts generally use the 
standard of Rule 15, governing amendments to pleadings, to determine whether to allow the 
addition." 12 Wright & Miller, Fed. Prac. & Fed. P., p. 432 (3d ed. 2013); see also Galustian v. 
Peter, 591 F.3d 724, 729-30 (4th Cir. 2010) (collecting cases and noting that Rule 15(a) applies 
to amendments seeking to add parties); Frank v. U.S. West. Inc., 3 F.3d 1357, 1365 (10th Cir. 
1993) ("A motion to add a party is governed by Fed. R. Civ. P. 15(a) ...."). 
Rule 21, "Misjoinder and Non joinder of Parties," provides the court with a tool for 
correcting the "misjoinder" of parties that would otherwise result in dismissal. Fed. R. Civ. P. 
21. Insofar as Rule 21 "relates to the addition of parties, it is intended to permit the bringing in 
of a person, who through inadvertence, mistake or for some other reason, had not been made a 
party and whose presence as a party is later found necessary or desirable." United States v. Com. 
Bank of N. Am., 31 F.R.D. 133, 135 (S.D.N.Y. 1962) (internal quotation marks omitted). 
3 
EFTA01099204

Case 9:08-cv-80736-KAM Document 324 Entered on FLSD Docket 04/07/2015 Page 4 of 10 
In their Rule 21 Motion, Jane Doe 3 and Jane Doe 4 do not claim that they were omitted 
from this proceeding due to any "inadvertence" or "mistake" by Petitioners; rather, they seek to 
join this proceeding as parties that could have been permissively joined in the original petition 
under Rule 20 ("Permissive Joinder of Parties"). As courts generally use the standards of Rule 
15 to evaluate such circumstances, the Court will consider the joinder issue as presented in the 
Rule 15 Motion.' The Court will consider the arguments presented in the Rule 21 Motion as if 
they are set forth in the Rule 15 Motion as well. Because the arguments are presented in the Rule 
15 Motion (and because the Court is denying the Rule 15 Motion on its merits, as discussed 
below), the Rule 21 Motion will be denied. 
The Court also concludes that portions of the Rule 21 Motion and related 
filings should be stricken from the record. Pending for this Court's consideration is a Motion 
for Limited Intervention filed by Alan M. Dershowitz, who seeks to intervene to "strike the 
outrageous and impertinent allegations made against him and [to] request[] a show cause order to 
the attorneys that have made them." (DE 282 at 1). The Court has considered Mr. Dershowitz's 
arguments, but it finds that his intervention is unnecessary as Federal Rule of Civil Procedure 
12(0 empowers the Court "on its own" to "strike from a pleading an insufficient defense or any 
redundant, immaterial, impertinent, or scandalous matter." Fed. R. Civ. P. 12(f). 
Petitioners' Rule 21 Motion consists of relatively little argumentation regarding why the 
Court should permit them to join in this action: they argue that (1) they were sexually abused by 
The Court notes that, regardless of which motion it considers, the same standard 
governs the addition of parties under Rule 21 and Rule 15. See Goston v. Potter, No. 08-cv-478 
FJS ATB, 2010 WL 4774238, at *5 (N.D.N.Y. 2010) (citing Bridgeport Music, Inc. v. Universal 
Music Grp., Inc., 248 F.R.D. 408, 412 (S.D.N.Y. 2008)). 
4 
EFTA01099205

Case 9:08-cv-80736-KAM Document 324 Entered on FLSD Docket 04/07/2015 Page 5 of 10 
Jeffrey Epstein, and (2) the Government violated their CVRA rights by concealing the non-
prosecution agreement with them. (DE 280 at 3; see a at 7-8). However, the bulk of the Rule 
21 Motion consists of copious factual details that Jane Doe 3 and Jane Doe 4 "would prove" "[i]f 
allowed to join this action." (a. at 3, 7). Specifically, Jane Doe 3 proffers that she could prove 
the circumstances under which a non-party introduced her to Mr. Epstein, and how Mr. Epstein 
sexually trafficked her to several high-profile non-party individuals, "including numerous 
prominent American politicians, powerful business executives, foreign presidents, a well-known 
Prime Minister, and other world leaders." ( 
at 3-6). She names several individuals, and she 
offers details about the type of sex acts performed and where they took place. 
id. at 5).1
At this juncture in the proceedings, these lurid details are unnecessary to the 
determination of whether Jane Doe 3 and Jane Doe 4 should be permitted to join Petitioners' 
claim that the Government violated their rights under the CVRA. The factual details regarding 
with whom and where the Jane Does engaged in sexual activities are immaterial and impertinent 
to this central claim (i.e., that they were known victims of Mr. Epstein and the Government owed 
them CVRA duties), especially considering that these details involve non-parties who are not 
related to the respondent Government. These unnecessary details shall be stricken. 
The original Rule 21 Motion (DE 279) shall be stricken in its entirety, as it is wholly 
superseded by the "corrected" version of the Rule 21 Motion (DE 280). From the corrected Rule 
21 Motion, the Court shall strike all factual details regarding Jane Doe 3 between the following 
sentences: "The Government then concealed from Jane Doe #3 the existence of its NPA from 
2 Jane Doe 4's proffer is limited to sexual acts between Mr. Epstein and herself. (See DE 
280 at 7-8). 
5 
EFTA01099206

Case 9:08-cv-80736-KAM Document 324 Entered on FLSD Docket 04/07/2015 Page 6 of 10 
Jane Doe #3, in violation of her rights under the CVRA" L  at 3); and "The Government was 
well aware of Jane Doe #3 when it was negotiating the NPA, as it listed her as a victim in the 
attachment to the NPA" (E:l. at 6). As none of Jane Doe 4's factual details relate to non-parties, 
the Court finds it unnecessary to strike the portion of the Rule 21 Motion related to her 
circumstances. Regarding the Declaration in support of Petitioners' response to Mr. 
Dershowitz's motion to intervene (DE 291-1), the Court shall strike paragraphs 4, 5, 7, 11, 13, 
15, 19 through 53, and 59, as they contain impertinent details regarding non-parties. Regarding 
the Declaration of Jane Doe 3 in support of the Rule 21 Motion (DE 310-1), the Court shall strike 
paragraphs 7 through 12, 16, 39, and 49, as they contain impertinent details regarding non-
parties. Jane Doe 3 is free to reassert these factual details through proper evidentiary proof, 
should Petitioners demonstrate a good faith basis for believing that such details are pertinent to a 
matter presented for the Court's consideration. 
As mentioned, Mr. Dershowitz moves to intervene "for the limited purposes of moving to 
strike the outrageous and impertinent allegations made against him and requesting a show cause 
order to the attorneys that have made them." (DE 282 at 1). As the Court has taken it upon itself 
to strike the impertinent factual details from the Rule 21 Motion and related filings, the Court 
concludes that Mr. Derschowitz's intervention in this case is unnecessary. Accordingly, his 
motion to intervene will be denied as moot.' Regarding whether a show cause order should 
This also moots Mr. Dershowitz's Motion for Leave to File Supplemental Reply in 
Support of Motion for Limited Intervention. (DE 317). Denying Mr. Dershowitz's motion to 
intervene also renders moot Petitioners' motion (DE 292) to file a sealed document supporting its 
response to Mr. Dershowitz's motion. It will accordingly be denied as moot, and DE 293 (the 
sealed response) will be stricken from the record. 
6 
EFTA01099207

Case 9:08-cv-80736-KAM Document 324 Entered on FLSD Docket 04/07/2015 Page 7 of 10 
issue, the Court finds that its action of striking the lurid details from Petitioners' submissions is 
sanction enough. However, the Court cautions that all counsel are subject to Rule 11's mandate 
that all submissions be presented for a proper purpose and factual contentions have evidentiary 
support, Fed. R. Civ. P. 11(b)(1) and (3), and that the Court may, on its own, strike from any 
pleading "any redundant, immaterial, impertinent, or scandalous matter," Fed. R. Civ. P. 12(f). 
B. 
Rule 15 Motion 
Between their two motions (the Rule 21 Motion and Rule 15 Motion), Jane Doe 3 and 
Jane Doe 4 assert that "they desire to join in this action to vindicate their rights [under the 
CVRA] as well." (DE 280 at 1). Although Petitioners already seek the invalidation of Mr. 
Epstein's non-prosecution agreement on behalf of all "other similarly-situated victims" (DE 189 
at 1; DE 311 at 2, 12, 15, 18-19), Jane Doe 3 and Jane Doe 4 argue that they should be fellow 
travelers in this pursuit, lest they "be forced to file a separate suit raising their claims" resulting 
in "duplicative litigation" (DE 280 at 11). The Court finds that justice does not require adding 
new parties this late in the proceedings who will raise claims that are admittedly "duplicative" of 
the claims already presented by Petitioners. 
The Does' submissions demonstrate that it is entirely unnecessary for Jane Doe 3 and 
Jane Doe 4 to proceed as parties in this action, rather than as fact witnesses available to offer 
relevant, admissible, and non-cumulative testimony. (See, e.g., DE 280 at 2 (Jane Doe 3 and 
Jane Doe 4 "are in many respects similarly situated to the current victims"), 9 ("The new victims 
will establish at trial that the Government violated their CVRA rights in the same way as it 
violated the rights of the other victims."), 10 (Jane Doe 3 and Jane Doe 4 "will simply join in 
motions that the current victims were going to file in any event."), 11 (litigating Jane Doe 3 and 
7 
EFTA01099208

Case 9:08-cv-80736-KAM Document 324 Entered on FLSD Docket 04/07/2015 Page 8 of 10 
Jane Doe 4's claims would be "duplicative"); DE 298 at 1 n.1 ("As promised ... Jane Doe No. 3 
and Jane Doe No. 4 do not seek to expand the number of pleadings filed in this case. If allowed 
to join this action, they would simply support the pleadings already being filed by Jane Doe No. 1 
and Jane Doe No. 2."); DE 311 at 5 n.3 ("[A]ll four victims (represented by the same legal 
counsel) intend to coordinate efforts and avoid duplicative pleadings."), 15 (Jane Doe 3 and Jane 
Doe 4 "challenge the same secret agreement 
i.e., the NPA that the Government executed with 
Epstein and then concealed from the victims. This is made clear by the proposed amendment 
itself, in which all four victims simply allege the same general facts.")). As the Does argue at 
length in their Rule 15 Motion, Jane Doe 1's original petition "specifically allege[s] that the 
Government was violating not only her rights but the rights of other similarly-situated victims." 
(DE 311 at 2). The Court fails to see why the addition of "other similarly-situated victims" is 
now necessary to "vindicate their rights as well." (DE 280 at 1). 
Of course, Jane Doe 3 and Jane Doe 4 can participate in this litigated effort to vindicate 
the rights of similarly situated victims there is no requirement that the evidentiary proof 
submitted in this case come only from the named parties. Petitioners point out as much, noting 
that, regardless of whether this Court grants the Rule 15 Motion, "they will call Jane Doe No. 3 
as a witness at any trial." (DE 311 at 17 n.7). The necessary "participation" of Jane Doe 3 and 
Jane Doe 4 in this case can be satisfied by offering their properly supported and relevant, 
admissible, and non-cumulative 
testimony as needed, whether through testimony at trial 
see DE 280 at 9) or affidavits submitted to support the relevancy of discovery requests° see 
The non-party Jane Does clearly understand how to submit affidavits. (See DEs 291-1, 
310-1). 
8 
EFTA01099209

Case 9:08-cv-80736-KAM Document 324 Entered on FLSD Docket 04/07/2015 Page 9 of 10 
id. at 10). Petitioners do not contend that Jane Doe 3 and Jane Doe 4's "participation in this 
case" can only be achieved by listing them as parties. 
As it stands under the original petition, the merits of this case will be decided based on a 
determination of whether the Government violated the rights of Jane Doe 1, Jane Doe 2, and all 
"other similarly situated victims" under the CVRA. Jane Doe 3 and Jane Doe 4 may offer 
relevant, admissible, and non-cumulative evidence that advances that determination, but their 
participation as listed parties is not necessary in that regard. See Herring, 894 F.2d at 1024 
(District court did not abuse its discretion by denying amendment where "addition of more 
plaintiffs . . . would not have affected the issues underlying the grant of summary judgment."); cf. 
Arthur v. Stern, 2008 WL 2620116, at *7 (S.D. Tex. 2008) (Under Rule 15, "courts have held 
that leave to amend to assert a claim already at issue in [another lawsuit] should not be granted if 
the same parties are involved, the same substantive claim is raised, and the same relief is 
sought.").5 And, as to Jane Doe 4 at least, adding her as a party raises unnecessary questions 
about whether she is a proper party to this action.6
Petitioners also admit that amending the petition to conform to the evidence by 
including references to the non-prosecution agreement itself is "unnecessary" as the "existing 
petition is broad enough to cover the developing evidence in this case." (DE 311). The Court 
s The Court expresses no opinion at this time whether any of the attestations made by 
Jane Doe 3 and Jane Doe 4 in support of their motion will be relevant, admissible, and non-
cumulative.
6 The Government contends that Jane Doe 4 is not a true "victim" in this case because 
she was not known at the time the Government negotiated the non-prosecution agreement, and 
accordingly she was not entitled to notification rights under the CVRA. (See DE 290 at 10). 
Any "duplicative" litigation filed by Jane Doe 4 would necessarily raise the issue of whether she 
has standing under the CVRA under these circumstances. 
9 
EFTA01099210

Case 9:08-cv-80736-KAM Document 324 Entered on FLSD Docket 04/07/2015 Page 10 of 10 
agrees, and it concludes that justice does not require amending the petition this late in the 
proceedings. 
III. Conclusion 
Accordingly, it is hereby ORDERED AND ADJUDGED as follows: the Rule 21 Motion 
(DE 280) is DENIED; the Rule 15 Motion (DE 311) is DENIED; Intervenor Dershowitz's 
Motion for Limited Intervention (DE 282) and Motion for Leave to File Supplemental Reply in 
Support of Motion for Limited Intervention (DE 317) are DENIED AS MOOT; Petitioners' 
Motion to Seal (DE 292) is DENIED AS MOOT; the following materials are hereby 
STRICKEN from the record: 
• 
DE 279, in its entirety. 
• 
DE 280, all sentences between the following sentences: 
"The Government then concealed from Jane Doe #3 the 
existence of its NPA from Jane Doe #3, in violation of her 
rights under the CVRA" (DE 280 at 3); and "The 
Government was well aware of Jane Doe #3 when it was 
negotiating the NPA, as it listed her as a victim in the 
attachment to the NPA" (DE 280 at 6). 
• 
DE 291-1, paragraphs 4, 5, 7, 11, 13, 15, 19 through 53, 
and 59. 
• 
DE 310-1, paragraphs 7 through 12, 16, 39, and 49. 
• 
DE 293, in its entirety. 
DONE AND ORDERED in chambers at West Palm Beach, Palm Beach County, 
Florida, this 61° day of April, 2015. 
KENNETH A. MARRA 
United States District Judge 
10 
EFTA01099211

EXHIBIT B 
EFTA01099212

912/2015 
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KAITLANSARSRALL 14 YEARS OLD 0 Ban 
BEACH. Ft MISSING SINCE 5/3 PLEASECONTAC 
HIRATIFIER IF YOU HAVE ANY IDEA WHERESHE 
MAY BE 
561.904-1799 
Jordan Garnett 
FACEBOOK FAMILIMI I realty need everyone's help, A lankly friend of ours has 
gone mssing.She was iASI seenbeard from on May 3rd, Her name is Ka 'land 
Marsh.. 
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HT
Human Trafficking Coalition Of The Palm Beaches 
El= 
shared a photo. 
9 hrs • 
Another missing chili.. West Palm Beach. 
Comrrents 
19,.'a ta. ChWIOCIe• now 
ar4 on:soy:N.1 
please 
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troryine rase  Yap fr, fray inn, 
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1.1, w Intact maw urger 
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ems tswe 
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skate Cal int WM/ 
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xarrg log vs sae Won 
Nikki Carter 
URGENT Ok b we repost Foolishness all the tme._someeoeys baby is missing. 
Let's join together and bring him home. He went missing last night at about 91... 
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Human Trafficking Coalition Of Tho Palm Beaches 
shared TOLE- Florida Department of Law Enforcement's 
photo. 
9 ha • 
https thyme facebook ccadpages'Hisnan-Trafficking-Coalition-Of-ThePalm-Beachestit5953982139669 
2/12 
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