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LETTER TO 
Consider CC to Hon Kenneth Marra 
US Attorney Wilfredo Ferrer 
Re Jane Doe #1 and Jane Doe #2 v United States Case No 08-80736-Civ-
Marra 
Dear.. 
and MEM 
Late on December 30, 2014, the petitioners lawyers Bradley J Edwards 
and Paul Cassell filed a Motion Pursuant to Rule 21 for Joinder in Action, 
Dkt 279, which was later replaced by a similar corrected pleading Dkt 280. 
The Motion was ostensibly to add parties to a lawsuit that has been pending 
for over 6 years. As to the request as to Jane Doe #3, it comes more than 5 
years after she was aware of the NPA having relied upon its provisions to 
sue Jeffrey Epstein as Jane Doe 102, and at least 3 years 8 months after she 
was provably in communication with Mr. Edwards and providing him 
statements about Mr. Epstein. As the case is between the Government and 
the Petitioners with Mr. Epstein as only a limited Intervenor and as the 
allegations raised as to me by the Motion are not material to the resolution of 
whether the CVRA was or was not violated and what an appropriate remedy 
would be, and because the allegations are defamatory, incontrovertibly 
untrue, uncorroborated, gratuitously included and malicious, I request that 
you move to strike them from the record of these proceedings. 
First, I never had any sexual contact with Jane Doe #3 as alleged, not in 
West Palm Beach, not in New Mexico, not in the US Virgin Islands, not on a 
private airplane, not anywhere. I do not recall ever being in her presence 
and can certainly attest under oath that I never had sexual contact of any 
kind with her. I have never had a massage from any under age female at any 
Epstein residence, I have never had a massage on a private airplane, I have 
only been to his New Mexico residence on one occasion, with my daughter 
and wife who were with me at all times, I have only been to his US Virgin 
Islands residence with my wife who was with me at all times, and the 
entirety of the allegations are demonstrably untrue. I say "demonstrably" 
because no flight manifest would put me on a plane with Jane Doe #3, and 
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no witness would ever say I was in her presence in a private setting 
anywhere anytime. 
Second, the lawyers who filed this pleading conducted no investigation 
into whether the allegations were true. They apparently just accepted Jane 
Doe #3s word without more. They then included details clearly irrelevant to 
the Motion. They apparently did so to create a nexus to the NPA they are 
challenging — claiming that I "helped negotiate an agreement with a 
provision that provided protection for himself against criminal prosecution 
in Florida for sexually abusing Jane Doe #3", Motion at 4. Ms Villafana 
negotiated the agreement with two other attorneys for Mr. Epstein — Jay 
Leflcowitz and Martin Weinberg. I did not participate in any such 
negotiation. I did not help draft the agreement. I certainly did not 
apprehend any risk to myself or that I would be protected by any provision 
incorporated into the agreement that named four associates of Mr. Epstein 
but not me (nor Ms Maxwell). To suggest that I had a personal motive for 
seeking "broad immunity" for third parties is reckless, untrue, and, if it was 
said outside of court, defamatory. Again, I only learned of the accusation on 
December 30, 7 years 3 months after the execution of the NPA. The 
accusation is untrue therefore it is not one I ever imagined could or would be 
brought when the NPA was negotiated. Finally, the Government as well as 
Mr. Leflcowitz and Mr. Weinberg all know that although I attended meetings 
with Ms Villafana and others at the United States Attorney's Office both 
before and after the September 2007 Agreement, that I was not a participant 
in its drafting nor in its negotiation. 
Third, as stated, whether Jane Doe #3 is allowed to join the litigation is 
not a decision that relies upon the detailed allegations she is now making as 
to me or any other third party. We have no established procedural pathway 
to contest the allegations given that they are wholly immaterial to the legal 
issues in dispute in the underlying litigation. Her lawyers, by vouching for 
the truth of the allegations in the media, have made themselves principals in 
a defamation case I am preparing along with a bar complaint. Lawyers must 
investigate the truth of allegations, particularly when they know that 
intervention is unlikely to be allowed given how irrelevant the issues raised 
are to the case itself but how maliciously damaging they are to the person 
whose reputation is being attacked. I therefore ask you to ask Judge Marra 
to strike these irrelevancies from the public record. I further request that you 
verify that the allegation that I negotiated the NPA to protect myself is 
untrue. 
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