{
  "document_metadata": {
    "page_number": "9",
    "document_number": "208-2",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 208-2 Filed 04/16/21 Page 9 of 15\nCase 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 8 of 14\n\nThe acts Epstein committed against Jane Doe #4, constituted numerous federal sex offenses, some of which do not carry a statute of limitations and thus are not time-barred. See 18 U.S.C. § 3283. And these offenses were the kinds of offenses that the Federal Bureau of Investigation (FBI) and U.S. Attorney's Office for the Southern District of Florida were pursuing in 2007. So far as Jane Doe #4 is aware, the U.S. Attorney's Office made no serious effort to locate her. Instead, after identifying approximately forty separate underage sexually abused victims, and apparently preparing a 53-page federal indictment and with full awareness of the existence of many victims like Jane Doe #4 - unidentified and not interviewed - it entered into a non-prosecution agreement barring prosecution of Epstein's federal crimes against these victims. This is contrary to the Government's normal approach in prosecuting federal sex offenses. It also violated Jane Doe #4's rights under the CVRA, including the fact that she had a \"reasonable\" right to confer with the U.S. Attorney's Office before they entered into an agreement with a sex offender barring prosecution of him for the crimes he committed against her. 18 U.S.C. § 3771(a)(5).\n\nMOTION FOR JOINDER\nJane Doe #3 and Jane Doe #4 now both move to join this action filed by Jane Doe #1 and Jane Doe #2, pursuant to Rule 21 of the Federal Rules of Civil Procedure. Rule 21 provides that \"[o]n motion or on its own, the court may at any time, on just terms, add . . . a party.\" Rule 21 \"grants the court broad discretion to permit a change in the parties at any stage of a litigation.\" Ford v. Air Line Pilots Ass'n Int'l, 268 F. Supp. 2d 271, 295 (E.D.N.Y. 2003) (internal quotation omitted). The new victims should be allowed to join the current victims in this action under Rule 21.\n8\nGIUFFRE 004295 CONFIDENTIAL\nDOJ-OGR-00003744",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 208-2 Filed 04/16/21 Page 9 of 15",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 8 of 14",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The acts Epstein committed against Jane Doe #4, constituted numerous federal sex offenses, some of which do not carry a statute of limitations and thus are not time-barred. See 18 U.S.C. § 3283. And these offenses were the kinds of offenses that the Federal Bureau of Investigation (FBI) and U.S. Attorney's Office for the Southern District of Florida were pursuing in 2007. So far as Jane Doe #4 is aware, the U.S. Attorney's Office made no serious effort to locate her. Instead, after identifying approximately forty separate underage sexually abused victims, and apparently preparing a 53-page federal indictment and with full awareness of the existence of many victims like Jane Doe #4 - unidentified and not interviewed - it entered into a non-prosecution agreement barring prosecution of Epstein's federal crimes against these victims. This is contrary to the Government's normal approach in prosecuting federal sex offenses. It also violated Jane Doe #4's rights under the CVRA, including the fact that she had a \"reasonable\" right to confer with the U.S. Attorney's Office before they entered into an agreement with a sex offender barring prosecution of him for the crimes he committed against her. 18 U.S.C. § 3771(a)(5).",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "MOTION FOR JOINDER",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Jane Doe #3 and Jane Doe #4 now both move to join this action filed by Jane Doe #1 and Jane Doe #2, pursuant to Rule 21 of the Federal Rules of Civil Procedure. Rule 21 provides that \"[o]n motion or on its own, the court may at any time, on just terms, add . . . a party.\" Rule 21 \"grants the court broad discretion to permit a change in the parties at any stage of a litigation.\" Ford v. Air Line Pilots Ass'n Int'l, 268 F. Supp. 2d 271, 295 (E.D.N.Y. 2003) (internal quotation omitted). The new victims should be allowed to join the current victims in this action under Rule 21.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "8",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "GIUFFRE 004295 CONFIDENTIAL",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003744",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein",
      "Jane Doe #1",
      "Jane Doe #2",
      "Jane Doe #3",
      "Jane Doe #4"
    ],
    "organizations": [
      "Federal Bureau of Investigation (FBI)",
      "U.S. Attorney's Office",
      "Air Line Pilots Ass'n Int'l"
    ],
    "locations": [
      "Florida",
      "E.D.N.Y."
    ],
    "dates": [
      "04/16/21",
      "01/02/2015",
      "2007",
      "2003"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 208-2",
      "Case 9:08-cv-80736-KAM",
      "Document 280",
      "18 U.S.C. § 3283",
      "18 U.S.C. § 3771(a)(5)",
      "Rule 21",
      "GIUFFRE 004295",
      "DOJ-OGR-00003744"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the Epstein case, discussing the victims' rights and a motion for joinder. The document is marked as 'CONFIDENTIAL'."
}