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Jane Doe #3's and Jane Doe #4's participation is also directly relevant to the discovery 
disputes currently pending in this case. The Government has raised various relevancy objections 
to the documents that Jane Doe #1 and Jane Doe #2 are attempting to obtain. The current 
victims have responded by explaining how these documents are relevant, including explaining 
how these documents might bear on the way in which Epstein used his powerful political and 
social connections to secure a favorable plea deal, as well as provide proof of the Government's 
motive to deliberately fail to investigate certain aspects of the victims' claims in an effort to 
maintain the secrecy of the facts and resolve the case without the victims' knowledge. See, e.g., 
DE 266 at 6-10. Jane Doe #3 and Jane Doe #4's participation will help prove the relevancy of 
these requests, as well as the need for those requests. 
One clear example is Request for Production No. 8, which seeks documents regarding 
Epstein's lobbying efforts to persuade the Government to give him a more favorable plea 
arrangement and/or non-prosecution agreement, including efforts on his behalf by Prince 
Andrew and former Harvard Law Professor Alan Dershowitz. Jane Doe #1 and Jane Doe #2 
have alleged these materials are needed to prove their allegations that, after Epstein signed the 
non-prosecution agreement, his performance was delayed while he used his significant social and 
political connections to lobby the Justice Department to obtain a more favorable plea deal. See, 
e.g., DE 225 at 7-8 (discussing DE 48 at 16-18). Jane Doe #3 has directly person knowledge of 
Epstein's connection with some of these powerful people and thus how Epstein might have used 
them to secure favorable treatment. 
Adding two new victims to this case will not delay any of the proceedings. They will 
simply join in motions that the current victims were going to file in any event. For example, the 
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new victims will simply join in a single summary judgment motion that the current victims 
anticipate filing after discovery has been completed. 
Nor will adding the new victims prejudice the United States. As the court is aware, this 
Court is still in its initial discovery stage. The Court is currently considering whether to reject 
the Government's assertion of privilege over documents regarding the case. See DE 265 
(victims' reassertion of objections to the Government privilege claims). The new victims do not 
seek any additional discovery beyond that previously sought by the current victims.' 
Accordingly, the United States will not be prejudiced or burdened by adding them to this case. 
The CVRA does not contain any statute of limitations for filing an action to enforce 
rights under the statute. Accordingly, were the Court to deny this motion, the result might be 
that the new victims would then be forced to file a separate suit raising their claims, which would 
then possibly proceed on a separate litigation track. Rather than require duplicative litigation, 
the Court should simply grant their motion to join. 
Jane Doe #1 and Jane Doe #2 support the joinder motion. Counsel for the victims have 
discussed this motion with the Government at length in an effort to avoid any need to file a 
substantive pleading on the issue. Counsel for the victims asked the Government during the 
summer for its position on joinder. 
The Government, however, took the matter under 
advisement for months. 
Ultimately, after several inquiries from victims counsel, the 
Government indicated without explanation that it opposes this motion. Counsel for the victims 
has requested a meeting with the Government on this issue, which will hopefully occur in 
2 Jane Doe #3 and Jane Doe #4 have asked the Government to provide them with the 
record of their statements that they provided to the FBI. These FBI 302's should be only a few 
pages long. 
II 
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January. In the meantime, however, counsel for the victims believe that it is no longer 
appropriate to delay filing this motion and accordingly file it at this time. 
Because the 
Government is apparently opposing this motion, Jane Doe #3 and Jane Doe #4 have described 
the circumstances surrounding their claims so that the Court has appropriate information to rule 
on the motion. 
CONCLUSION 
Jane Doe #3 and Jane Doe 04 should be allowed to join this action, pursuant to Rule 2! 
of the Federal Rules of Civil Procedure. Their joinder should be conditioned on the requirement 
that they not re-litigate any issues previously litigated by Jane Doe #1 and Jane Doe #2. 
A 
proposed order to that effect is attached to this pleading. 
DATED: December 30, 2014 
Respectfully Submitted, 
/s/ Bradley J. Edwardk 
Bradley J. Edwards 
FARMER, JAFFE, WEISSING, 
EDWARDS FISTOS & LE RMA , P.L. 
And 
Paul G. Cassell 
Pro Hoc Vice 
S.J. Quinney College of Law at the 
12 
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Case 9:08-cv-80736-KAM Document 279 Entered on FLSD Docket 12/30/2014 Page 13 of 13 
Attorneys for Jane Doe HI and Jane Doe 11,2 
CERTIFICATE OF SERVICE 
I certify that the foregoing document was served on December 30, 2014, on the following 
using the Court's CM/ECF system: 
Mlm 
500 S. Australian Ave., Suite 400 
West Palm Beach, FL 33401 
Attorneys for the Government 
/s/ Bradley J. Edwards 
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Case 9:08-cv-80736-KAM Document 279-1 Entered on FLSD Docket 12/30/2014 Page 1 of 1 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 08-80736-Civ-Marra/Johnson 
JANE DOE #1 and JANE DOE #2 
I 
UNITED STATES 
ORDER GRANTING JANE DOE #3 AND JANE DOE #4's MOTION PURSUANT TO 
RULE 21 FOR JOINDER IN ACTION 
This matter is before the Court on JANE DOE #3 AND JANE DOE #4 MOTION 
PURSUANT TO RULE 21 FOR JOINDER IN ACTION. Having carefully considered the 
same and finding good cause show, it is 
ORDERED AND ADJUDGED that Jane Doe #3 and Jane Doe #4 are allowed to join this 
action, pursuant to Rule 21 of the Federal Rules of Civil Procedure. They are ordered not to re-
litigate any issues previously litigated by Jane Doe #1 and Jane Doe #2 in this action. 
DONE AND ORDERED in Chambers at West Palm Beach, Florida, this 
day of 
,201 
KENNETH A. MARRA 
UNITED STATES DISTRICT JUDGE 
cc: 
All counsel 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 08-80736-C1V-MARRA/JOHNSON 
JANE DOE #1 AND JANE DOE #2, 
Plaintiffs. 
vs. 
UNITED STATES OF AMERICA, 
Defendant. 
MOTION FOR LIMITED INTERVENTION BY ALAN M. DERSHOWITZ 
Alan M. Dershowitz (herein, "Prof. Dershowitz"), a nonparty to this litigation, is the 
victim of scurrilous allegations made in Jane Doe #3 and Jane Doe #4's Motion Pursuant to Rule 
21 for Joinder in the Action (the "Joinder Motion"), filed as of record at DE 279. Having no 
remedy in this proceeding for the harm to his reputational interest, Prof. Dershowitz hereby seeks 
to intervene in this action, both as of right under Fed. R. Civ. P. 24(a) and permissively under 
Fed. R. Civ. P. 24(6), 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. 
With respect to the legal framework for intervention, Prof. Dershowitz agrees with the 
general principles stated by this Court in its earlier Order on intervention dated September 26, 
2011 (DE 99), including the broad discretion afforded district courts concerning intervention. 
However, as is summarized in the paragraphs that follow, this motion for intervention stands 
upon dramatically different circumstances than the prior motion, which was denied. 
The 
proposed Plaintiffs' and their counsel's defamatory falsehoods about Prof. Dershowitz are of an 
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entirely different order of magnitude. and they have spread around the world. 
What makes them doubly troubling is their irrelevancy: although categorically false, the 
allegations against Prof Dershowitz have absolutely nothing to do with whether the United 
States government violated its duty to confer with the Plaintiffs prior to entering into the non-
prosecution agreement with Jeffrey Epstein, and, if so, what remedies might apply. Because 
those are the issues to be adjudicated by the Court in the underlying lawsuit, it is apparent that 
the broadside against Prof. Dershowitz was ginned up for reasons having nothing to do with the 
merits of this case. Prof Dershowitz must be given the opportunity to defend himself through 
intervention in this action. 
The Joinder Motion is nothing more than a vehicle to impugn the reputation of 
Prof. Dershowitz, filed with the certain result of stirring up media interest. 
The Joinder Motion purports to seek to add two new plaintiffs as parties to this litigation, 
but does not even attach a proposed amended complaint in violation of the local rules. See S.D. 
Ha. L.R. 15.1 (requiring a party who moves to amend a pleading to attach the original of the 
amendment to the motion). Instead, the paper simply proffers various salacious allegations as 
quotable tabloid fodder. Specifically naming Prof. Dershowitz, and identifying him as Mr. 
Epstein's counsel, Plaintiffs' counsel allege that Jane Doe #3 was "required" to have sexual 
relations with Prof. Dershowitz "on numerous occasions while she was a minor," and, in 
addition, that Prof. Dershowitz was "an eyewitness to the sexual abuse of many other minors." 
(DE 279 at 4.) 
The Motion goes on to state that Prof. Dershowitz was involved in the 
negotiation of the non-prosecution agreement for Jeffrey Epstein which "provided protection for 
[Prof. Dershowitz] against criminal prosecution in Florida for sexually abusing Jane Doe #3." 
(Id.) 
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To the great detriment of Prof. Dcrshowitz, and as Plaintiffs' counsel surely anticipated, 
the contemptible allegations against Prof. Dershowitz and others have created a media firestorm. 
Over the weekend of January 3 and 4, 2015, major media outlets—including the Miami Herald, 
the Washington Post, the Wall Street Journal, the New York Times, and the Jerusalem Post—
picked up the story and highlighted the most libelous allegations against Prof. Dcrshowitz. 
Yet, as stated above, the allegations against Prof. Dershowitz are completely irrelevant to 
this case. The issue to be determined on the Plaintiffs' Petition is whether, in violation of the 
Crime Victims' Rights Act, the United States Attorney's Office breached its obligations to meet 
and confer with the Plaintiffs—including proposed plaintiff Jane Doe # 3, who has made the 
accusations against Prof. Dershowitz—prior to entering into a non-prosecution agreement with 
Jeffrey Epstein on September 24, 2007. 
That issue turns on the government's knowledge of 
Jane Doe # 3's allegation at the time of the agreement, including, for example, whether she was 
designated as a witness by the government. What has been levelled against Prof. Dershowitz 
simply has nothing to do with any relevant issues in this case. In short, there was no legitimate 
purpose for including these extremely harmful allegations in the Joinder Motion. 
II. 
The allegations made against Prof. Dershowitz are outrageously false. 
Besides being wholly irrelevant, the allegations made in the Joinder Motion with respect 
to Prof. Dershowitz are categorically false. See Declaration of Alan Dershowitz, attached hereto 
as Exhibit A. 
In fact, they are absolutely outrageous. Prof. Dershowitz is married and has three children 
and two grandchildren. He is the Felix Frankfurter Professor of Law, Emeritus, at Harvard Law 
School. Prof. Dershowitz, a graduate of Brooklyn College and Yale Law School, joined the 
Harvard Law School faculty at age 25 after clerking for Judge David Banton and Justice Arthur 
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Case 9:08-cv-80736-KAM Document 282 Entered on FLSD Docket 01/05/2015 Page 4 of 10 
Goldberg. Prof. Dershowitz is, among other things, a civil liberties attorney. During his long and 
distinguished career, he has published more than one thousand articles in newspapers. journals 
and magazines on a variety of topics. He has published fiction and non-fiction works and law 
review articles about criminal and constitutional law. He has received awards from many 
institutions and organizations for his work, including the Anti-Defamation League. In his private 
legal practice he represents individuals and corporations, and even provides counsel to various 
world leaders. Prof. Dershowitz's reputation, which is sterling, is at the core of his remarkable 
career. 
Ill. 
Prof. Dershowitz should be allowed to intervene under these circumstances. 
It is to protect his reputation for which Prof. Dershowitz seeks to intervene in this action. 
He is entitled to do so under these circumstances, both as of right and with the permission of the 
Court. 
Intervention as of right is governed by Federal Rule of Civil Procedure 24(a)(2). Rule 
24(a)(2) requires the Court to allow anyone to intervene who claims an interest relating to the 
property or transaction that is the subject of the action, and is so situated that disposing of the 
action may as a practical matter impair or impede the movant's ability to protect its interest, 
unless existing parties adequately represent that interest. Among the interests that satisfy these 
criteria are injury to reputation. Sackniani. Liggett Grp., Inc., 167 F.R.D. 6, 20-21 (E.D.N.Y. 
1996) (citing Penthouse Intl. W.I. Playboy Enterprises, Inc.. 663 F.2d 371, 373, 392 (2d Cir. 
1981)). The burden of demonstrating an interest relating to the subject of the action that cannot 
be adequately represented by others is minimal. Georgia'. U.S. Army Corps of Engineers, 302 
F.3d 1242, 1255 (11th Cir. 2002). 
Clearly, Plaintiffs' and Plaintiffs' counsel's accusations of sex with minors and 
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Case 9:08-cv-80736-KAM Document 282 Entered on FLSD Docket 01/05/2015 Page 5 of 10 
conspiracy to violate the law arc injurious to Prof. Dershowitz's reputation—indeed, they 
constitute libel per se--such that he has an interest relating to the subject matter of this action. It 
is far from certain, however, that the defendant in this action, United States of America, has the 
same interest as Prof. Dershowitz in disproving the preposterous allegations that have been made 
against him. For example, in defending the suit that Plaintiffs have brought, the United States of 
America will not necessarily need to defend against or seek to disprove the allegations that Prof. 
Dershowitz had sex with minors in concert with Mr. Epstein. Only Prof. Dershowitz is situated 
to protect his reputational interest here. 
This Court's recently-published and fully-considered reasoning in Krauser I. Evolution 
Holdings, Inc., 975 F.Supp. 2d 1247 (S.D. Fla. 2013) (finding inventor had standing to challenge 
a patent application which denied his contribution, based on inventor's reputational interest) 
supports this notion: "The common law recognized that a man's reputation was possibly his 
most valuable asset, that vindicating that reputation in the face of one who sought to defame it 
was of paramount importance, and that such vindication need not unnecessarily punish the 
defamer because a judgment in favor of the plaintiff that simply established the falsity of the 
defamation—and nothing more—was vindication enough." ld. at 1260. That is essentially what 
Prof. Dershowitz seeks here. 
Furthermore, permissive intervention under Rule 24(b) is also appropriate. See Walker. 
Jim Dandy Co., 747 F.2d 1360, 1365 (11th Cir. 1984). 
IV. 
These facts are distinguishable from those presented by the earlier intervenor 
motion filed by Bruce Reinhart. 
Prof. Dershowitz acknowledges that this Court earlier denied a motion to intervene by 
former Assistant United States Attorney Bruce E. Reinhart in 2011. (See DE 99 at 12-13.) Back 
5 
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