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CascGASE-4:2950609890-PAR umbecument 2084 on FilethO4¥Le4b4/oPage 8 Of dde 7 of 10
issue, the Court finds that its action of striking the lurid details from Petitioners’ submissions is
sanction enough. However, the Court cautions that all counsel are subject to Rule 11’s mandate
that all submissions be presented for a proper purpose and factual contentions have evidentiary
support, Fed. R. Civ. P. 11(b)(1) and (3), and that the Court may, on its own, strike from any
pleading “any redundant, immaterial, impertinent, or scandalous matter,” Fed. R. Civ. P. 12(f).
B. Rule 15 Motion
Between their two motions (the Rule 21 Motion and Rule 15 Motion), Jane Doe 3 and
Jane Doe 4 assert that “they desire to join in this action to vindicate their rights [under the
CVRA|] as well.” (DE 280 at 1). Although Petitioners already seek the invalidation of Mr.
Epstein’s non-prosecution agreement on behalf of all “other similarly-situated victims” (DE 189
at 1; DE 311 at 2, 12, 15, 18-19), Jane Doe 3 and Jane Doe 4 argue that they should be fellow
travelers in this pursuit, lest they “be forced to file a separate suit raising their claims” resulting
in “duplicative litigation” (DE 280 at 11). The Court finds that justice does not require adding
new parties this late in the proceedings who will raise claims that are admittedly “duplicative” of
the claims already presented by Petitioners.
The Does’ submissions demonstrate that it is entirely unnecessary for Jane Doe 3 and
Jane Doe 4 to proceed as parties in this action, rather than as fact witnesses available to offer
relevant, admissible, and non-cumulative testimony. (See, e.g., DE 280 at 2 (Jane Doe 3 and
Jane Doe 4 “are in many respects similarly situated to the current victims”), 9 (“The new victims
will establish at trial that the Government violated their CVRA rights in the same way as it
violated the rights of the other victims.”), 10 (Jane Doe 3 and Jane Doe 4 “will simply join in
motions that the current victims were going to file in any event.”), 11 (litigating Jane Doe 3 and
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Document Details
| Filename | DOJ-OGR-00003732.jpg |
| File Size | 558.0 KB |
| OCR Confidence | 93.9% |
| Has Readable Text | Yes |
| Text Length | 2,087 characters |
| Indexed | 2026-02-03 16:40:12.061278 |