LETTER TO

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 EFTA00589710 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. EFTA00589711 EFTA00589712