Case 9:08-cv-80736-KAM Document 127 Entered on FLSD Docket 12/05/2011 Page 1 of 25

Case 9:08-cv-80736-KAM Document 127 Entered on FLSD Docket 12/05/2011 Page 1 of 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 1. UNITED STATES JANE DOE #1 AND JANE DOE #2'S RESPONSE TO GOVERNMENT'S SEALED MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to respond to the Government's Sealed Motion to Dismiss for Lack of Subject Matter Jurisdiction. The Court should deny the motion. Because the Government has filed a motion to dismiss alleging that the victims' pleadings are facially deficient, the Court must assume the truth of the victims' allegations - specifically that the Government and Epstein deliberately conspired to enter into a secret non- prosecution agreement in violation of the victims' rights under the Crime Victims' Rights Act (CVRA). Given such allegations (and,