Case 9:08-cv-80736-KAM Document 321 Entered on FLSD Docket 04/03/2015 Page 1 of 3

Case 9:08-cv-80736-KAM Document 321 Entered on FLSD Docket 04/03/2015 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 9:08-cv-80736-ICAM JANE DOE #1 and JANE DOE #2. Petitioners, vs. UNITED STATES OF AMERICA, Respondent. VICTIMS' SUPPLEMENTAL AUTHORITY IN SUPPORT OF RESPONSE TO MOTION FOR LI\IITED INTERVENTION BY ALAN M. DERSHOWITZ COME NOW petitioners Jane Doe No. I and Jane Doe 2, as well as movants Jane Doe No. 3 and Jane Doe No. 4 ("the victims"), to provide supplemental authority in support of their Response to Motion Limited Intervention by Alan M. Dershowitz (DE 291). In their response, the victims argued that a "sinister pattern" existed of persons refusing to provide information about Jeffrey Epstein's sex trafficking. DE 291 at 15. One of the persons identified as improperly refusing to provide information was Jean Luc Brunel. Id. at 16. Within the last several weeks, victims' counsel have learned that Brunel has filed a complaint in the Circuit Court for Dade County against Epstein. See Brunel v. Epstein, No. 14- 21348-CA-01 (11th Jud. Cir. Jan. 26, 2015) (Ex. I) (available at 2015 WL 129782). In the complaint, Brunel admits that he evaded deposition requests by undersigned counsel on behalf of several of Epstein's victims. Brunel further alleges that this evasion was due to Epstein's instructions. Brunel's complaint alleges that he was told by "Epstein to leave the Palm Beach EFTA00607078 Case 9:08-cv-80736-KAM Document 321 Entered on FLSD Docket 04/03/2015 Page 2 of 3 area in anticipation of a deposition of Plaintiff Brune[I] in a [civil') case against Epstein. On the direct advice of Epstein, Plaintiff Brune[I] went to Europe and Asia for a period of time. This was done for the sole purpose of delaying Plaintiff Brunens deposition." Complaint at ¶ 33. These admissions by Brunel that he evaded a deposition in the civil cases against Epstein further supports the arguments made by the victims that a sinister pattern of concealment exists. The Court should consider this fact, along with the other evidence, as a further reason supporting denial of the pending motion to intervene. DATED: April 3. 2015 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephon Facsimile E-mail: and Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, UT 84112 Telephone Facsimi E-mail: Attorneys for Jane Doe #1 and Jane Doe #2 Brunel's complaint says that the deposition was for a "criminal case." But this is obviously in error, since (as the Court is aware) the potential criminal case against Epstein concluded with the non-prosecution agreement in 2008. • This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah 2 EFTA00607079 Case 9:08-cv-80736-KAM Document 321 Entered on FLSD Docket 04/03/2015 Page 3 of 3 CERTIFICATE OF SERVICE I certify that the foregoing document was served on April 3, 2015, on the following using the Court's CM/ECF system: Dexter Lee A. Marie Villafafia 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 ax: E-mail: E-mail: Attorneys for the Government Thomas Scott COLE, SCOTT & KISSANE, P.A. Dadeland Centre II 9150 South Dadeland Boulevard, Suite 1400 Miami, Florida 33156 Telephone Facsimile: -and- Kendall Coffey Gabriel Groisman Benjamin H. Brodsky COFFEY BURLINGTON, P.L. 2601 South Bayshore Drive, PH 1 Miami, Florida 33133 Telephone Facsimile: Attorneys for Alan Dershowitz /s/ Bradley J. Edwards 3 EFTA00607080