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Jane Doe # 3 And Jane Doe # 4 And The Motion Pursuant To A Rule 21 Joinder In Action (8/27/26) · The Vault: The Epstein Files

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  Speaker 1: What's up everyone, and welcome back to the Epstein Chronicles.
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  Speaker 1: In this episode, we're going to keep it moving and
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  Speaker 1: we're going to continue looking at some unsealed documents, and
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  Speaker 1: this time we're taking a look at Jane Do number
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  Speaker 1: three and Jane Do number four's motion pursuing the Rule
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  Speaker 1: twenty one for Joinder in action case number zero eight
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  Speaker 1: DASH eight zero seven three six Dash SIV Dash Mara Johnson,
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  Speaker 1: Jaine DO number one and Jane Do number two versus
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  Speaker 1: the United States, Come Now, Jane Do number three and
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  Speaker 1: Jane Do number four, also referred to as the new victims,
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  Speaker 1: buy and through Undersigned Council to file this motion pursuing
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  Speaker 1: the Federal Rule of Civil Procedure twenty one to join
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  Speaker 1: this action on the condition that they not relitigate any
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  Speaker 1: issues already litigated by Jane Do number one and Jane
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  Speaker 1: Do number two, also referred to as the current victim.
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  Speaker 1: The new victims have suffered the same violations of their
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  Speaker 1: rights under the Crime Victim's Rights Act as the current victims. Accordingly,
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  Speaker 1: they desire to join in this action to vindicate their
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  Speaker 1: rights as well. Because the new victims will not re
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  Speaker 1: litigate any issues previously litigated by the current victims, and
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  Speaker 1: because they are represented by the same legal council as
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  Speaker 1: the current victims, the government will not be prejudiced. If
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  Speaker 1: the Court grants this motion, the Court may at any
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  Speaker 1: time add new parties to the action fed R Dot
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  Speaker 1: siv p Dot twenty one. Accordingly, the Court should grant
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  Speaker 1: the motion the factual background as the Court is aware.
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  Speaker 1: More than six years ago, Jane No. Number one filed
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  Speaker 1: the present action against the government, alleging a violation of
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  Speaker 1: her rights under the CVRA Statue eighteen US Code three
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  Speaker 1: seventy seven to one. She alleged that Jeffrey Epstein had
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  Speaker 1: sexually abused her and that the United States had entered
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  Speaker 1: into a secret non prosecution agreement regarding those crimes and
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  Speaker 1: violation of a rights. At the first court hearing on
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  Speaker 1: this case, the Court allowed Jane Doe number two to
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  Speaker 1: also join the action. Both Jane Doe number one and
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  Speaker 1: Jane Doe number two specifically argued that the government had
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  Speaker 1: failed to protect their CRVA rights inter alia, to confer
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  Speaker 1: to a reasonable notice and to be treated with fairness.
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  Speaker 1: In response to the government argued that the CVRA rights
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  Speaker 1: did not apply to Jane Doe number one and Jane
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  Speaker 1: Do number two because no federal charges had ever been
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  Speaker 1: filed against Jeffrey Epstein. The Court has firmly rejected the
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  Speaker 1: United States position. In a detailed ruling, the Court concluded
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  Speaker 1: that the CVRA extended rights to Jane Doe number one
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  Speaker 1: and Jane Doe number two even though federal charges were
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  Speaker 1: not filed. The Court explained that because the NPA barred
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  Speaker 1: prosecution of crimes committed against them by Epstein, they had
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  Speaker 1: standing to assert violations of the CVRA rights. The Court
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  Speaker 1: deferred ruling on whether the two victims would be entitled
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  Speaker 1: to relief pending development of a fuller evidentiary record. Two
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  Speaker 1: other victims, who are in many respects similarly situated to
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  Speaker 1: the current victims, now wish to join this action. The
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  Speaker 1: new victims joining at this stage will not cause any delay,
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  Speaker 1: and their joinder in this case is the most expeditious
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  Speaker 1: manner in which to pursue their rights, because the background
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  Speaker 1: regarding their abuse is relevant to the Court's assessment of
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  Speaker 1: whether to allow them to join. Their circumstances are accounted
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  Speaker 1: here briefly. Jaine Do number three circumstances as with Jane
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  Speaker 1: Do Number one and Jane Do number two. Jane Do
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  Speaker 1: number three was repeatedly sexually abused by Epstein. The government
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  Speaker 1: then concealed from Jane Do number three the existence of
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  Speaker 1: its NPA from Jane Do number three, in violation of
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  Speaker 1: her rights under the CVRA. If allowed to join this action,
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  Speaker 1: Jane Do number three would prove the following. In nineteen
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  Speaker 1: ninety nine, Jane Doe number three was approached by Gallaine Maxwell,
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  Speaker 1: one of the main women whom Epstein used to procure
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  Speaker 1: underage girls for sexual activities and a primary co conspirator
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  Speaker 1: in his sexual abuse and sex trafficking scheme. In fact,
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  Speaker 1: it became known to the government that Maxwell herself regularly
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  Speaker 1: participated in Epstein's sexual exploitation of miners, including Jane Doe
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  Speaker 1: number three. Maxwell persuaded Jane Doe number three, who was
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  Speaker 1: fifteen years old, to come to Epstein's mansion, in a
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  Speaker 1: fashion very similar to the manner in which Epstein and
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  Speaker 1: his other co conspirators coerced dozens of other children, including
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  Speaker 1: Jane Do number one and Jane Doe number two. When
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  Speaker 1: Jane Doe number three began giving Epstein a massage, Epstein
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  Speaker 1: and Maxwell turned it into a sexual encounter, as they
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  Speaker 1: had done with many other victims. Epstein then became enamored
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  Speaker 1: with Jane Doe number three, and, with the assistance of Maxwell,
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  Speaker 1: converted her into what is commonly referred to as a
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  Speaker 1: sex slave. Epstein Jane Doe number three as his sex
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  Speaker 1: slave from about nineteen ninety nine through two thousand and two,
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  Speaker 1: when she managed to escape to a foreign country and
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  Speaker 1: hide out from Epstein and his co conspirators. For years,
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  Speaker 1: from nineteen ninety nine through two thousand and two, Epstein
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  Speaker 1: frequently sexually abused Jane Doe number three, not only in
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  Speaker 1: West Palm Beach, but also in New York, New Mexico,
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  Speaker 1: the US Virgin Islands, in international airspace, on Epstein's private plane,
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  Speaker 1: and elsewhere. Epstein also sexually trafficked the then minor Jane Doe,
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  Speaker 1: making her available for sex to politically connected and financially
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  Speaker 1: powerful people. Epstein's purposes in lending Jane Doe, along with
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  Speaker 1: other young girls to such powerful people were to ingratiate
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  Speaker 1: himself with them for business, personal, political and financial gain,
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  Speaker 1: as well as to obtain potential blackmail information. One such
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  Speaker 1: powerful individual that Epstein forced then minor Jaine Doe number
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  Speaker 1: three to have sexual relations with was former Harvard law
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  Speaker 1: professor Alan Dershowitz, a close friend of Epstein's and well
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  Speaker 1: known criminal defense attorney. Epstein required Jane Doe number three
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  Speaker 1: to have sexual relations with Dershowitz on numerous occasions while
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  Speaker 1: she was a miner, not only in Florida, but also
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  Speaker 1: on private planes in New York, New Mexico, and other
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  Speaker 1: US virgin islands. In addition to being a participant in
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  Speaker 1: the abuse of Jane Doe number three and other miners,
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  Speaker 1: Dershowitz was an eyewitness to the sexual abuse of many
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  Speaker 1: other miners by Epstein and several of Epstein's co conspirators.
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  Speaker 1: Now we know that Dershowitz and Virginia dropped their dueling lawsuits,
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  Speaker 1: and Virginia said that she could have been mistaken when
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  Speaker 1: she says it was Dershowitz. However, I have a funny
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  Speaker 1: feeling there's a little bit more there than we're aware of.
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  Speaker 1: Can I prove that I cannot? Back to the document.
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  Speaker 1: Dershowitz would later play a significant role in negotiating the
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  Speaker 1: NPA on Epstein's behalf. Indeed, Dershowitz helped negotiate an agreement
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  Speaker 1: that provided immunity from federal prosecution in the Southern District
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  Speaker 1: of Florida not only to Epstein, but also any potential
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  Speaker 1: co conspirators of Epstein. NPA at five. Thus, Dershowitz held
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  Speaker 1: negotiate an agreement with a provision that provided protection for
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  Speaker 1: himself against criminal prosecution in Florida for sexually abusing Jane
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  Speaker 1: Doe number three. Because this broad immunity would have been
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  Speaker 1: controversial if disclosed, Dershowitz, along with other members of Epstein's
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  Speaker 1: defense team and the government, tried to keep the immunity
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  Speaker 1: provision secret from all of Epstein's victims and the general public,
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  Speaker 1: even though such secrecy violated the Crime Victim's Rights Act.
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  Speaker 1: Claim Maxwell was another person in Epstein's inner circle and
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  Speaker 1: a co conspirator in Epstein's sexual abuse. She was someone
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  Speaker 1: who frequently also appreciated the immunity granted by the NPA
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  Speaker 1: for the crimes she committed in Florida. In addition to
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  Speaker 1: participating in the sexual abuse of Jane Doe number three
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  Speaker 1: and others, Maxwell all So took numerous sexually explicit pictures
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  Speaker 1: of underage girls involved in sexual activities, including Jane Doe
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  Speaker 1: number three. She shared these photographs, which constituted child pornography
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  Speaker 1: under applicable federal laws with Epstein. The government is apparently
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  Speaker 1: aware of and in certain instances possesses some of these
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  Speaker 1: photographs full stop. How come we haven't seen any sort
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  Speaker 1: of information about photographs? And if anybody's in these photographs
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  Speaker 1: that the government allegedly has, those people need to go
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  Speaker 1: to prison. Perhaps even more important to her role in
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  Speaker 1: Epstein's sexual abuse ring, Maxwell had direct connections to other
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  Speaker 1: powerful individuals with whom she could connect Epstein. For instance,
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  Speaker 1: one such powerful individual Epstein forced Jane Doe number three
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  Speaker 1: to have sexual relations with was a member of the
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  Speaker 1: British royal family, Prince Andrew aka the Joe Exotic of
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  Speaker 1: the Windsor family. Jane Doe number three was forced to
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  Speaker 1: have sexual relations with this Prince when she was a
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  Speaker 1: miner in three separate geographical locations in London, at Glenn
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  Speaker 1: Maxwell's apartment in New York, and on Epstein's private island
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  Speaker 1: in the US Virgin Islands. In an orgy with numerous
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  Speaker 1: other underage girls, Epstein instructed Jane Doe number three that
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  Speaker 1: she was to give the Prince whatever he demanded and
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  Speaker 1: required Jane Doe number three to report back to him
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  Speaker 1: on the details of the sexual abuse. Maxwell facilitated Prince
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  Speaker 1: Andrews acts of sexual abuse by acting as a madam
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  Speaker 1: for Epstein, thereby assisting in intentionally trafficking Jane Doe number
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  Speaker 1: three and numerous other young girls for sexual purposes. Another
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  Speaker 1: person in Epstein's inner circle of friends who becomes apparent
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  Speaker 1: with almost no investigative effort is Jean Luke Brunel. Epstein
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  Speaker 1: sexually trafficked Jane Doe number three to Jean Luke Brunel
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  Speaker 1: many times. Brunell was another Epstein close friend and a
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  Speaker 1: regular traveling companion who had many contacts with young girls
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  Speaker 1: throughout the world. Brunell has been a model scout for
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  Speaker 1: various modeling agencies for many years and apparently was able
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  Speaker 1: to get us passports for young girls to work as models.
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  Speaker 1: He would bring the young girls, ranging from ages as
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  Speaker 1: young as twelve, to the United States for sexual purposes
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  Speaker 1: and farm them out to his friends, especially Ebstein. Brunell
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  Speaker 1: would offer the girls modeling jobs. Many of the girls
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  Speaker 1: came from poor countries or impoverished backgrounds, and he lured
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  Speaker 1: them in with the promise of making good money. Epstein
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  Speaker 1: forced Jane Doe number three to observe him. Brunell and
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  Speaker 1: Maxwell engage in illegal sexual acts with dozens underage girls.
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  Speaker 1: Epstein also forced Jane Doe number three to have sex
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  Speaker 1: with Brunell on numerous occasions at places including Epstein's mansion
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  Speaker 1: in West Palm Beach, Little Saint James Island in the
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  Speaker 1: US Virgin Islands, many including Orgies that were comprised of
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  Speaker 1: other underage girls, New York City, New Mexico, Paris, the
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  Speaker 1: South of France, and California. Epstein also trafficked Jane Doe
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  Speaker 1: number three for sexual purposes to many other powerful men,
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  Speaker 1: including numerous prominent American politicians, powerful business executives, foreign presidents,
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  Speaker 1: a well known prime minister, and other world leaders. Epstein
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  Speaker 1: required Jane Doe number three to describe the events that
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  Speaker 1: she had with these men so that he could potentially
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  Speaker 1: blackmail them. The government was well aware of Jane Doe
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  Speaker 1: number three when it was negotiating the NPA, as it
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  Speaker 1: listed her as a victim in the attachment to the NPA. Moreover,
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  Speaker 1: even a rudimentary investigation of Jane Doe number three's relationship
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  Speaker 1: with Epstein would reveal the fact that she had been
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  Speaker 1: trafficked throughout the United States and internationally for sexual purposes. Nonetheless,
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  Speaker 1: the government secretly negotiated a non prosecution agreement with Epstein,
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  Speaker 1: precluding any federal prosecution in the Southern District of Florida
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  Speaker 1: of Epstein and his co conspirators. As with Jane Doe
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  Speaker 1: number one, in Jaine Do number two, the government concealed
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  Speaker 1: the non prosecution agreement from Jane Doe number three, all
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  Speaker 1: in violation of her rights under the CVRA, to avoid
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  Speaker 1: Jane DO number three from raising powerful objections to the
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  Speaker 1: NPA that would have shed tremendous public light on Epstein
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  Speaker 1: and other powerful individuals, and that likely would have prevented
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  Speaker 1: it from being concluded in the secretive manner in which
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  Speaker 1: it was CHAINO number four and her circumstances. If permitted
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  Speaker 1: to join this action, Jaane DO number four would allege
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  Speaker 1: and could prove at trial that she has VRA claims
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  Speaker 1: similar to those advanced by Jane DO number one and
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  Speaker 1: Jaine DO number two, based on the following. As with
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  Speaker 1: the other Jane Does, Jane Do number four was repeatedly
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  Speaker 1: sexually abused by Epstein in or around the summer of
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  Speaker 1: two thousand and two, Jane Do number four, an economically
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  Speaker 1: poor and vulnerable sixteen year old child, was told by
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  Speaker 1: another one of Epstein's underage minor sex abuse victims that
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  Speaker 1: she could make three hundred dollars cast by giving an
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  Speaker 1: old man a massage on Palm Beach. An acquaintance of
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  Speaker 1: Jane Doe number four, also a minor sexual abuse victim
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  Speaker 1: of Epstein, telephoned Epstein and scheduled Jane Doe number four
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  Speaker 1: to go to Epstein's house to give him a massage.
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  Speaker 1: During that call, Epstein himself got on the phone a
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  Speaker 1: means of interstate communication with Jane Doe number four, asking
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  Speaker 1: her personally to come to his mansion in pom Beach.
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  Speaker 1: Jane Do number four then went to Epstein's mansion and
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  Speaker 1: was escorted upstairs to Epstein's large bathroom by one of
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  Speaker 1: Epstein's assistants. Shortly thereafter, Jeffrey Epstein emerged and laid face
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  Speaker 1: down on the table and told Jane Doe number four
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  Speaker 1: to start massage in them. Epstein asked Jane Doe number
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  Speaker 1: three her age, and she told him that she had
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  Speaker 1: recently turned sixteen. Epstein subsequently committed a legal sexual acts
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  Speaker 1: against Jane Do number four. On many occasions, Epstein used
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  Speaker 1: the means of interstate communication ie a cell phone to
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  Speaker 1: arrange for these sexual contacts. Epstein also frequently traveled in
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  Speaker 1: interstate commerce ie on his personal jet for purposes of
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  Speaker 1: illegally sexually abusing Jane Do number four. That would be
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  Speaker 1: a Man Act violation. That's why the man Act is
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  Speaker 1: on the books. Funny, Epstein never got hit with that, huh.
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  Speaker 1: In the meantime, however, a council for the victims believe
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  Speaker 1: that it is no longer appropriate to delay filing this
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  Speaker 1: motion and accordingly file it at this time because the
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  Speaker 1: government is apparently opposing this motion. Jane Do number three
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  Speaker 1: and Jane Do number four have described the circumstances surrounding
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  Speaker 1: their claims so that the court has appropriate information to
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  Speaker 1: rule on the motion. The conclusion Jane Do number three
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  Speaker 1: and Jane Do number four should be allowed to join
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  Speaker 1: this action pursuant to Rule twenty one of the Federal
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  Speaker 1: Rules of Civil Procedure. Their joinder should be conditioned on
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  Speaker 1: the requirement that they not relitigate any issues previously litigated
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  Speaker 1: by Jane Do number one and n Jane No. Number two.
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  Speaker 1: A proposed order to that effect is attached to this pleading.
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  Speaker 1: This document was dated December thirtieth, twenty fourteen, and it
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  Speaker 1: was signed by Bradley Edwards. All of the information that
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  Speaker 1: goes with this episode can be found in the description
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  Speaker 1: box