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EFTA00210758 | EFTA00210760 Wilfredo A. Ferrer January 29, 2015 Page 3 CVRA enforcement action is an "ancillary criminal proceeding[]," DE 290 at 2, presumably not covered by a statute of limitations applicable to a "civil action commences against the United States." 28 U.S.C. § 2401(a). Even more surprising to us was your Office's failure to discuss the second sentence in § 2401(a), which provides that the six-year rule is not applicable to "any person . . . beyond the seas at the time the claim accrues . . ." Your Office sent FBI agents to Australia to interview Jane Doe No. 3 in 2011, and clearly was aware that she was "beyond the seas" — and thus, under the plain language of the statute, not obligated to file within six years. We don't see any good faith basis for your Office maintaining that the six-year provision applies in light of its knowledge that she hiding from Epstein in Australia. But to avoid further unnecessary litigation about such subjects, we hope that you will agree to a Rule 15 amendment to simply add Jane Doe No. 3 and Jane Doe No. 4 into the case. A Rule 15 amendment obviates statute of limitations concerns, because it "relates back to the date of the original pleading" by "assert[ing] a claim . . . that arose out of the conduct, transaction, or occurrence set out — or attempted to be set out — in the original pleading." Fed. R. Civ. P. 15(c)(1XB). Jane Doe No. 1's initial petition plainly mentioned other victims. The initial petition alleged that, "[u]pon information and believe, [Jeffrey Epstein] is engaged in plea negotiations with the Office of the United States Attorney for the Southern District of Florida concerning federal crimes which he is alleged to have committed against minor children, including [Jane Doe No. 1]." DE 1 at 1-2. Jane Doe No. l's petition went on to allege that the Government was violating not only her rights but the rights of other similarly-situated victims: "On information and belief, rough the same crimes were committed [by Epstein] against several other youngfemales. These victims, too, are in danger oflosing their right to confer under the CVRA." DE 1 at 7 n.2 (emphasis added). After a Government response admitting that he had reached a secret plea deal, Jane Doe No. I filed a reply in support of her petition, which again very directly mentioned other victims. The reply stated: "This deferred prosecution agreement was reached without conferral with [Jane Doe No. 1] — or, indeed, with the many other young victims of [Epstein's] crimes." DE 9 at 1 (emphasis added). The reply went on to explain that the agreement "remarkably allowed the defendant — a billionaire with extraordinary political connections — to escape all federal prosecutions for dozens of serious federal sex of enses against minors." Id. at 1-2. The reply continued to explain relief sought, specifically that "[t]he Court should therefore declare the proposed non-prosecution agreement an illegal one, since it was reached in violation of the CVRA, and order the Government to confer with Petitioner and the other victims in this matter before reaching any disposition in this case." Id. at 2 (emphasis added). The petition asked the Court to "hold that [Jane Doe No. 1] and the other victims in this case had the right to confer with the Government before it reached its non-prosecution agreement." Id. at 8 (emphasis added); see also id (the Government kept Jane Doe No. 1 "and the many other victims of [Epstein's] federal sex offenses . . . in the dark about the fact that the Government was planning to reach a deal . . . ."); id at 10 (the Government did not use "its `best efforts' to protect the rights of [Jane Doe No. 1] (and the other victims) in this case when it failed to confer with her Farmer, Jaffe, Weissing, Edwards, Fistos ft Lehrman, P.L. 425 North Andrews Avenue • Suite 2 • Fort Lauderdale, Florida 33301 954.524.2820 office 954.524.2822 fax EFTA00210760
April 24, 2026 at 9:58 AM