MEMY-1805 marker2 court-doe-v-us (salt 4090): 1811/1811

marker2/court-doe-v-us/EFTA02752688/EFTA02752688.md

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+UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF 08-80736-Civ-MAR RA
+
+IN RE: JANE DOE,
+
+Petitioner.
+
+STEVEN M. LARIMORE CLERK U.S. INST. CT. S. O. OF FLA. • MIAMI
+
+## enc y VICTIM'S PETITION FOR ENFORCEMENT OF CRIME VICTIM'S RIGHTS ACT, 18 U.S.0 . SECTION <sup>3771</sup>
+
+COMES NOW the Petitioner, JANE DOE (hereinafter "Petitioner"), by and through her undersigned attorneys, pursuant to the Crime Victim's Rights Act, 18 U.S.C. Section <sup>3771</sup> (`'CVRA"), and files this Petition for Enforcement in the above styled action as follows:
+
+1. Petitioner, an adult, as a minor child was a victim of federal crimes committed by JEFFREY EPSTEIN (hereinafter "Defendant"). These crimes included sex trafficking of children by fraud, in violation of 18 U.S.C. § 1591, use of a means of interstate commerce to entice a minor to commit prostitution, in violation of 18 U.S.C. § 2422, as well as wire fraud, in violation of 18 U.S.C. § 1343. The Defendant committed these crimes within the jurisdiction of the Southern District of Florida in Palm Beach County, Florida.
+
+2. Upon information and belief, the Defendant is the subject of a federal criminal investigation conducted by the United States of America in the Southern District of Florida. The Defendant has recently been prosecuted and pleaded guilty, on June 30, 2008, in the Circuit Court for Palm Beach County to various similar state offenses including solicitation of minors for prostitution.
+
+3. Upon information and belief, the Defendant 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 the Petitioner. Such negotiations may likely result in a disposition of the charges in the next several days.
+
+4. Under the CVRA, before any charges are filed against the Defendant, the Petitioner has the rights (among others) to notice of her rights under the CVRA, to confer with the prosecutors, and to be treated with fairness. As soon as charges are filed, the Petitioner has the rights (among others) to timely notice of court proceedings, the right not to be excluded from such proceedings, the right to be heard at such public proceedings regarding conditions of release, any plea, and any sentence, the right to confer with the attorney for the government. the right lo restitution, and the right to be treated with fairness and with respect for her dignity and privacy.
+
+5. The Petitioner has been denied her rights in that she has received no consultation with the attorney for the government regarding the possible disposition of the charges, no notice of any public court proceedings, no information regarding her right to restitution, and no notice of rights under the CVRA, as required under law.
+
+6. The Petitioner is in jeopardy of losing her rights, as described above, if the government is able to negotiate a plea or agreement with the Defendant without her participation and knowledge.
+
+WHEREFORE, for the reasons outlined above, the Petitioner respectfully requests this Court to grant her Petition, and to order the United States Attorney to comply with the provisions of the CVRA prior to and including any plea or other agreement with the Defendant and any attendant proceedings.
+
+### MEMORANDUM
+
+### I. THE CRIME VICTIMS' RIGHTS ACT MAKES CRIME VICTIMS INDEPENDENT PARTICIPANTS THROUGHOUT THE CRIMINAL JUSTICE PROCESS.
+
+In October 2004, Congress passed and the President signed into law the Crime Victims' Rights Act, Pub. L. No. 108-405, 118 Stat. 2251 (codified at 18 U.S.C. § 3771). Because this appears to be the first case involving the Act to come before this Court, a bit of background may be in order.
+
+### A. The CVRA Gives Crime Victims Rights to Participate in the Criminal Justice Process.
+
+Congress passed the CVRA "to give crime victims enforceable rights to participate in federal criminal proceedings." Opinion at 14. Congress was concerned that in the federal system crime victims were "treated as non-participants in acritical event in their lives. They were kept in the dark by prosecutors too busy to care enough ... and by a court system that simply did not have <sup>a</sup>place for them." 150 CONG. REC. S4262 (Apr. 22, 2004) (statement of Sen. Feinstein). To remedy this problem, Congress gave victims "the simple right to know what is going on, to participate in the process where the information that victims and their families can provide may be material and relevant ... ." Id.
+
+The CVRA gives victims of federal crimes aseries of rights, including the right to notice of court proceedings, to be heard at plea and sentencing hearings, and to reasonably "confer with the attorney for the Government in the case." 18 U.S.C. § 3771(a). Victims also have a"right of access to the terms of <sup>a</sup>plea agreement ... ." In re Interested Party I, 530 F.Supp. 2d 136, <sup>2008</sup>WL 134233 at •7 (D.D.C. 2008). The CVRA also assures victims broadly that they will "be treated with fairness." 18 U.S.C. § 3771(aX8).
+
+Of course, these rights would be of little use to most crime victims unless they were told about them. To ensure that victims are notified of their rights, the CVRA directs employees of the Justice Department "and other departments and agencies of the United States engaged in the detection, investigation, or prosecution of crime" to use their "best efforts to see that crime victims are notified of... the rights described (in the CVRA]." 18 U.S.C. § 3771(c)(1) (emphasis added).1
+
+# B. The CVRA Gives Victims Rights During the Investigation of a Crime.
+
+The CVRA gives victims rights during the investigation of a crime. The Fifth Circuit recently reached this conclusion, holding:
+
+> The district court acknowledged that "[t]here are clearly rights under the CVRA that apply before any prosecution is underway." BP Prods., 2008 WL 501321 at •11,2008 U.S. Dist. LEXIS 12893, at •36. Logically, this includes the CVRA's establishment of victims' "reasonable right to confer with the attorney for the Government." 18 U.S.C. & 3771(a)(5). At least in the posture of this case (and we do not speculate on the applicability to other situations), the government should have fashioned a reasonable way to inform the victims of the likelihood of criminal charges and to ascertain the victims' views on the possible details of aplea bargain.
+
+In re 527 F.3d 391,394 (51h Cir. 2008).
+
+The position that CVRA rights apply before charges have been filed is consistent with the Justice Department regulations under the CVRA, which explain that government officials "must advise a victim [about their rights under the CVRA) ... at the earliest opportunity at which it may be done without interfering with an investigation." A.G. GUIDELINES FOR VICTIM AND WITNESS
+
+<sup>I</sup>Further supporting this requirement is another statute, 42 U.S.C. § I 0607(cX3). which directs government officials tc provide victims with "the earliest possible notice of," among other things, "the filing of charges against <sup>a</sup>suspected offender."
+
+ASSISTANCE 23 (May 2005). And the plain language of the CVRA undergirds this conclusion, as it applies not simply to prosecutors but to government agencies "engaged in the detection [and] investigation ... of crime ... ." 18 U.S.C. § 3771(c)(1). Indeed, if there were any doubt, the plain language of the CVRA extends victims' right to situations "in which no prosecution is underway." 18 U.S.C. § 3771(d)(3).
+
+# H. PETITIONER IS A "VICTIM PROTECTED BY THE CVRA.
+
+Under the CVRA the crime victim is defined as "a person directly and proximately harmed as a result of the commission of a Federal offense ... ." 18 U.S.C. Section 3771(e). In particular, Defendant called Petitioner when she was a minor over atelephone (a means of interstate communication) requesting that she perform <sup>a</sup>massage in exchange for payment. As Defendant well knew, that request was fraudulent, as he not only intended to receive a massage, but also intended to have her perform sexual acts in exchange for a cash payment to Petitioner. Only when Petitioner arrived at a Defendant's mansion as directed by Defendant, did Defendant reveal his true purpose of obtaining sexual favors in exchange for payment. This conduct violated 18 U.S.C. § 2422, which forbids using <sup>a</sup>means of interstate commerce to knowingly "induce" or "entice" a minor "to engage in prostitution." In addition, this conduct was both a use of "fraud" to obtain a commercial sex act, in violation of 18 U.S.0 § 1591, and use of wire communications to perpetrate a "scheme and artifice to defraud," in violation of 18 U.S.C. § 1343.
+
+It appears obvious that Petitioner was "directly and proximately" harmed by these crimes, thereby making her a victim under the CVRA. It should be emphasized that the CVRA "was designed to be a `broad and encompassing' statutory victims' bill of rights." United States v.
+
+Degenhardt, 405 F.Supp.2d 1341, 1342 (D. Utah 2005) (quoting 150 Cong. Rec. S4261 (daily ed. Apr. 22, 2004) (statement of Sen. Feinstein)). Congress intended the CVRA to dramatically rework the federal criminal justice system. In the course of construing the CVRA generously, the Ninth Circuit observed: "The criminal justice system has long functioned on the assumption that crime victims should behave like good Victorian children -- seen but not heard. The Crime Victims' Rights Act sought to change this by making victims independent participants in the criminal justice process." Kenna v. U.S. Dist. Court for C.D. Cal., 435 F.3d 1011, 1013 (9th Cir. 2006). Accordingly, because the CVRA is remedial legislation, courts should interpret it "liberally to facilitate and accomplish its purposes and intent." Elliott Industries Ltd. Partnership v. BP America Production Co., 407 F.3d 1091, 1118 (10th Cir. 2005) (noting remedial legislation should be "interpreted liberally to facilitate and accomplish its purposes and intent"). The CVRA itself suggests this conclusion by requiring that courts must treat crime victims with "fairness." United States v. Patkar, 2008 WL 233062 at \*3 (D. Haw. 2008) (citing United States v. Turner, 367 F.Supp.2d 319, 335 (E.D.N.Y. 2005)).
+
+Not only must the CVRA as a whole be interpreted liberally, but its definition of "crime victim" requires <sup>a</sup>generous construction. After reciting the direct-and-proximate-harm language at issue here, one of the Act's two co-sponsors -- Senator Kyl -- explained that "(t)his is an intentionally broad definition because all victims of crime deserve to have their rights protected ." 150 Cong. Rec. S10912 (Oct. 9, 2004) (emphasis added). The description of the victim definition as "intentionally broad" was in the course of floor colloquy with the other primary sponsor of the CVRA and therefore deserves significant weight. See Kenna, 435 F.3d at 1015-16 (discussing significance of CVRA sponsors= floor statements).
+
+The definition of "crime victims" must thus be construed broadly in favor of Petitioner. She obviously qualifies as a"victim" under the CVRA.
+
+### III. PETITIONER IS ENTITLED TO NOTICE OF HER RIGHTS, AN OPPORTUNITY TO CONFER WITH THE PROSECUTORS AND TO BE TREATED WITH FAIRNESS.
+
+Because Petitioner is a "victim" under the CVRA, she has certain protected rights under the Act. Most important, the Act promises that she will have an opportunity to "confer with the attorney for the Government in the case." To date, Petitioner has not been given that right. This raises that very real possibility that the Government may negotiate and conclude <sup>a</sup>plea agreement with the Defendant without giving Petitioner her protected rights.2
+
+Petitioner is entitled to have this conference with prosecutors before any final plea agreement is reached. The Fifth Circuit reached exactly this conclusion in <sup>a</sup>very recent case. In In rel., 527 F.3d 391 (5th Cir. 2008), the Government negotiated <sup>a</sup>plea agreement with the well-heeled corporate defendant without conferring with the victims. When the Government's failure was challenged in the Fifth Circuit, the Fifth Circuit concluded that the Government had indeed violated the CVRA. The Fifth Circuit observed: "In passing the [CVRA), Congress made the policy decision-which we are bound to enforce-that the victims have aright to inform the plea negotiation process by conferring with prosecutors before <sup>a</sup>plea agreement is reached." Id. at 394.
+
+This Court is obligated to protect the rights of Petitioner. The CVRA directs that "[i)n any court proceeding involving an offense against acrime victim, the court shall ensure that the
+
+<sup>2</sup>On information and belief, roughly the same crimes were committed against several other young females. These victims, too, are in danger of losing their right to confer under the CVRA.
+
+crime victim is afforded the rights described in [the CVRA].” 18 U.S.C. § 3771(b)(1). The CVRA also confers on crime victims the right to “assert the rights described in [the CVRA].” 18 U.S.C. § 3771(d)(1). Therefore, this Court has its own independent obligation to intercede and ensure that the Government respects the rights of Petitioner under the CVRA.
+
+### CONCLUSION
+
+The Petitioner requests the intervention of this Court to ensure that her rights are respected and accorded, as promised in the Crime Victims’ Rights Act.
+
+DATED this 7th day of July, 2008.
+
+Respectfully Submitted,
+
+THE LAW OFFICE OF BRAD [REDACTED] &  
+ASSOCIATES, LLC
+
+![]()Brad [REDACTED], Esquire  
+Attorney for Petitioner  
+Florida Bar #542075  
+2028 [REDACTED] Street  
+Suite 202  
+Hollywood, Florida 33020  
+Telephone: 954-414-8033  
+Facsimile: 954-924-1530
+
+**CERTIFICATE OF SERVICE**
+
+I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been provided by United States mail and via facsimile to: ANN [REDACTED] C. VILLAFANA, AUSA, United States Attorney's Office, 500 South Australian Avenue, Suite 400, West Palm Beach, Florida 33401, this 7th day of July, 2008.
+
+![]()Brad [REDACTED], Esquire  
+Attorney for Petitioner  
+Florida Bar No. 542075
+
+JJS 44 (Rev. 2 08)
+
+CIVIL COVER SHEET
+
+ELECTRONIC D.C.  
+**JULY 7, 2008**  
+STEVEN M. LARIMORE  
+CLERK U.S. DIST. CT.  
+S.D. OF FLA. - MIAMI
+
+The JS 44 civ 1 cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk the civil cocket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.) **NOTICE: Attorneys MUST Indicate All Re-filed**
+
+| <b>I. (a) PLAINTIFFS</b><br><i>In re: Jane Doe</i>                                                                                                                                                                                                                                                              |  | <b>DEFENDANTS</b><br><i>United States of</i>                                    |  |
+|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|---------------------------------------------------------------------------------|--|
+| <b>(b) County of Residence of First Listed Plaintiff</b><br><i>Palm Bch.</i><br>(EXCEPT IN U.S. PLAINTIFF CASES)                                                                                                                                                                                                |  | County of Residence of First Listed Defendant<br>(IN U.S. PLAINTIFF CASES ONLY) |  |
+| <b>(c) Attorney's (Firm Name, Address, and Telephone Number)</b><br><i>Law office of Brad Edwards &amp; Associates<br/>2028 Harrison Street<br/>Suite 202<br/>Hollywood, FL 33020</i>                                                                                                                           |  | NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT LAND INVOLVED.  |  |
+| (1) Check County Where Action Arose: <input type="checkbox"/> MIAMI-DADE <input type="checkbox"/> MONROE <input type="checkbox"/> BROWARD <input checked="" type="checkbox"/> PALM BEACH <input type="checkbox"/> ST. LUCIE <input type="checkbox"/> INDIAN RIVER <input type="checkbox"/> OKEECHOBEE HIGHLANDS |  |                                                                                 |  |
+
+**II. BASIS OF JURISDICTION** (Place an "X" in One Box Only)
+
+ 1 U.S. Government Plaintiff  3 Federal Question (U.S. Government Not a Party)
+
+ 2 U.S. Government Exercise Diversity (Indicate Citizenship of Parties in Item III)
+
+*O8CV80736 MARRA/JOHNSON*
+
+**III. CITIZENSHIP OF PRINCIPAL PARTIES** (Place an "X" in One Box for Plaintiff and One Box for Defendant)
+
+|                                         | PTF                      | DEF                      | PTF | DEF |
+|-----------------------------------------|--------------------------|--------------------------|-----|-----|
+| Citizen of This State                   | <input type="checkbox"/> | <input type="checkbox"/> | 1   | 1   |
+| Citizen of Another State                | <input type="checkbox"/> | <input type="checkbox"/> | 2   | 2   |
+| Citizen or Subject of a Foreign Country | <input type="checkbox"/> | <input type="checkbox"/> | 3   | 3   |
+
+| CONTRACT                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | TORTS                                                                                                                                                                                                                                                                                                                                                                                                                                        |                                                                                                                                                                                                                                                                                                                                                                                                                | FORFEITURE/PENALTY                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | BANKRUPTCY  |  | OTHER STATUTES |  |
+|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------|--|----------------|--|
+| <input type="checkbox"/> 110 Insurance<br><input type="checkbox"/> 120 Marine<br><input type="checkbox"/> 130 Act<br><input type="checkbox"/> 140 Negotiable Instrument<br><input type="checkbox"/> 150 Recovery of Overpayment & Enforcement of Judgment<br><input type="checkbox"/> 151 Medicare Act<br><input type="checkbox"/> 152 Recovery of Defaulted Student Loans (Exc. Victorians)<br><input type="checkbox"/> 153 Recovery of Overpayment of Veteran's Benefits<br><input type="checkbox"/> 160 Stockholders' Suits<br><input type="checkbox"/> 190 Other Contract<br><input type="checkbox"/> 195 Contrac Product Liability<br><input type="checkbox"/> 196 Franchise | <input type="checkbox"/> 310 A rplane<br><input type="checkbox"/> 315 A rplane Product Liability<br><input type="checkbox"/> 320 Assault, Libel & Slander<br><input type="checkbox"/> 330 Federal Employers' Liability<br><input type="checkbox"/> 340 Marine<br><input type="checkbox"/> 345 Marine Product Liability<br><input type="checkbox"/> 350 Motor Vehicle<br><input type="checkbox"/> 355 Motor Vehicle Product Liability<br><input type="checkbox"/> 360 Other Personal Injury | <input type="checkbox"/> 362 Personal Injury - Med. Malpractice<br><input type="checkbox"/> 365 Personal Injury - Product Liability<br><input type="checkbox"/> 368 Asbestos Personal Injury Product Liability<br><input type="checkbox"/> 370 Other Fraud<br><input type="checkbox"/> 371 Truth in Lending<br><input type="checkbox"/> 380 Other Personal Property Damage<br><input type="checkbox"/> 385 Property Damage Product Liability | <input type="checkbox"/> 610 Agriculture<br><input type="checkbox"/> 620 Other Food & Drug<br><input type="checkbox"/> 625 Drug Related Seizure of Property 21 USC 881<br><input type="checkbox"/> 630 Liquor Laws<br><input type="checkbox"/> 640 R.R. & Truck<br><input type="checkbox"/> 650 Airline Regs.<br><input type="checkbox"/> 660 Occupational Safety/Health<br><input type="checkbox"/> 690 Other | <input type="checkbox"/> 422 Appeal 2k USC 158<br><input type="checkbox"/> 423 Withdrawal 2k USC 157<br><input type="checkbox"/> 820 Copyrights<br><input type="checkbox"/> 830 Patent<br><input type="checkbox"/> 840 Trademark<br><input type="checkbox"/> 861 HIA (1395ff)<br><input type="checkbox"/> 862 Black Lung (923)<br><input type="checkbox"/> 863 DIWC DIWW (405(g))<br><input type="checkbox"/> 864 SSID Title XVI<br><input type="checkbox"/> 865 RSI (405(g))<br><input type="checkbox"/> 870 Taxes (U.S. Plaintiff or Defendant)<br><input type="checkbox"/> 871 IRS Third Party 26 USC 7609 | <input type="checkbox"/> 400 Stare Reapportionment<br><input type="checkbox"/> 410 Antitrust<br><input type="checkbox"/> 430 Barks and Banking<br><input type="checkbox"/> 450 Commerce<br><input type="checkbox"/> 460 Deportation<br><input type="checkbox"/> 470 Racketeer Influenced and Corrupt Organizations<br><input type="checkbox"/> 480 Consumer Credit<br><input type="checkbox"/> 490 Cable Sat TV<br><input type="checkbox"/> 810 Selective Service<br><input type="checkbox"/> 850 Securities Commodities Exchange<br><input type="checkbox"/> 875 Customer Challenge 12 USC 3410<br><input type="checkbox"/> 890 Other Statutory Actions<br><input type="checkbox"/> 891 Agricultural Acts<br><input type="checkbox"/> 892 Economic Stabilization Act<br><input type="checkbox"/> 893 Environmental Matters<br><input type="checkbox"/> 894 Energy Allocation Act<br><input type="checkbox"/> 895 Freedom of Information Act<br><input type="checkbox"/> 900 Appeal of Fee Determination Under Equal Access to Justice<br><input type="checkbox"/> 950 Constitutionality of State Statutes |             |  |                |  |
+| REAL PROPERTY                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | CIVIL RIGHTS                                                                                                                                                                                                                                                                                                                                                                                                                                 |                                                                                                                                                                                                                                                                                                                                                                                                                | PRISONER PETITIONS                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | IMMIGRATION |  |                |  |
+| <input type="checkbox"/> 210 Land Condemnation<br><input type="checkbox"/> 220 Foreclosure<br><input type="checkbox"/> 230 Rent Lease & Ejectment<br><input type="checkbox"/> 240 Torts to Land<br><input type="checkbox"/> 245 Tor Product Liability<br><input type="checkbox"/> 290 All Other Real Property                                                                                                                                                                                                                                                                                                                                                                     | <input type="checkbox"/> 441 Voting<br><input type="checkbox"/> 442 Employment<br><input type="checkbox"/> 443 Housing Accommodations<br><input type="checkbox"/> 444 Welfare<br><input type="checkbox"/> 445 Amer. w Disabilities Employment<br><input type="checkbox"/> 446 Amer. w Disabilities Other                                                                                                                                                                                   | <input type="checkbox"/> 510 Motions to Vacate Sentence<br><input type="checkbox"/> 530 General<br><input type="checkbox"/> 535 Death Penalty<br><input type="checkbox"/> 540 Mandamus & Other<br><input type="checkbox"/> 550 Civil Rights<br><input type="checkbox"/> 555 Prison Condition                                                                                                                                                 | <input type="checkbox"/> 470 Naturalization Application<br><input type="checkbox"/> 463 Habeas Corpus-Alien Detainee<br><input type="checkbox"/> 465 Other Immigration Actions                                                                                                                                                                                                                                 |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |             |  |                |  |
+
+**V. ORIGIN** (Place an "X" in One Box Only)
+
+ 1 Original Proceeding  2 Removed from State Court  3 Re-filed-(see VI below)  4 Reinstated or Reopened  5 Transferred from another district (specify)  6 Multidistrict Litigation  7 Appeal to District Judge from Magistrate Judgment
+
+**VI. RELATED/RE-FILED CASE(S).** (See instructions second page)
+
+a) Re-filed Case  YES  NO b) Related Cases  YES  NO
+
+JUDGE DOCKET NUMBER
+
+**VII. CAUSE OF ACTION**
+
+Cite the U.S. Civil Statute under which you are filing and Write a Brief Statement of Cause (Do not cite jurisdictional statutes unless diversity): *Crime Victim's Rights Act 18 USC § 3771 potition on behalf of victim of sex offenses to be accorded her rights under the CVRA*
+
+LENGTH OF TRIAL via 1 days estimated (for both sides to try entire case)
+
+**VIII. REQUESTED IN COMPLAINT:**  CHECK IF THIS IS A CLASS ACTION UNDER F.R.C.P. 23 **DEMAND \$** CHECK YES only if demanded in complaint: **JURY DEMAND:**  Yes  No
+
+**ABOVE INFORMATION IS TRUE & CORRECT TO THE BEST OF MY KNOWLEDGE**
+
+SIGNATURE OF ATTORNEY OF RECORD *SERR* DATE *7-7-08*
+
+FOR OFFICE USE ONLY  
+AMOUNT *350.00* RECEIPT # *124403* IFP

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marker2/court-doe-v-us/EFTA02752698/EFTA02752698.md

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+![](_page_0_Picture_166.jpeg)
+
+UNITED STATES DISTRICT COURT  
+SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.
+
+08-80736-Civ-MARRA/[REDACTED]
+
+In re:  
+Jane Doe  
+v.
+
+Plaintiff
+
+United States  
+of America
+
+Defendant
+
+CERTIFICATION OF EMERGENCY
+
+I hereby certify that, as a member of the Bar of this Court, I have carefully examined this matter and it is a true emergency.
+
+I further certify that the necessity for this emergency hearing has not been caused by a lack of due diligence on my part, but has been brought about only by the circumstances of this case. The issues presented by this matter have not been submitted to the Judge assigned to this case or any other Judge or Magistrate Judge of the Southern District of Florida prior hereto.
+
+I further certify that I have made a bona fide effort to resolve this matter without the necessity of emergency action.
+
+Dated this 7 day of July, 2008.
+
+Signature: [Signature]
+
+Print Name: Brad
+
+Florida Bar Number: 542 075
+
+Telephone Number: 954-414-8033
+
+\*\*\*\*\*
+
+I hereby certify that the Judge assigned to this case is unavailable for this emergency (a copy of his/her notification to the Clerk is on file). In accordance with Local Rule 3.7, the Honorable
+
+\_\_\_\_\_ was randomly drawn from the Emergency Wheel.
+
+Dated: \_\_\_\_\_
+
+**STEVEN M. LARIMORE**  
+Court Administrator • Clerk of Court
+
+By: \_\_\_\_\_  
+Deputy Clerk

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marker2/court-doe-v-us/EFTA02752699/EFTA02752699.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+NO. 08-80736-CIV-MARRA
+
+IN RE: JANE DOE,
+
+Petitioner
+
+## ORDER
+
+THIS CAUSE comes before the Court on Plaintiff's Emergency Petition for Enforcement of Crime Victim's Rights Act (DE 1), filed July 7, 2008. It is hereby ORDERED that the United States' Attorney shall file a response to this petition by 5:00 P.M. on Wednesday, July 9, 2008.
+
+DONE AND ORDERED in at West Palm Beach, Palm Beach County,
+
+Florida, this 7h day of July, 2008.
+
+KENNETH A. MARRA United States District Judge
+
+Copies furnished to: R. Alexander Acosta, United States' Attorney all counsel of record

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marker2/court-doe-v-us/EFTA02752700/EFTA02752700.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO. 08-80736-CIV-MARRAi
+
+IN RE: JANE DOE,
+
+Petitioner.
+
+/
+
+## NOTICE OF ENTRY OF APPEARANCE FOR RESPONDENT UNITED STATES OF AMERICA
+
+Assistant United States Attorney Dexter A. Lee enters his appearance on behalf of the respondent, United States of America. The undersigned respectfully requests that notices, orders, and other documents be sent to the undersigned at:
+
+> United States Attorney's Office 99 N.E. 4th Street, Suite 300 Miami, Florida 33132 (305) 961-9320 Fax: (305) 530-7139 E-mail: dexterlee@usdoj.gov
+
+> > Respectfully submitted,
+
+R. ALEXANDER ACOSTA UNITED STATES ATTORNEY
+
+By: s/ Dexter A. Lee DEXTER A. LEE Assistant U.S. Attorney Fla. Bar No. 0936693 99 N.E. 0 Street Miami, Florida 33132 (305) 961-9320 Fax: (305) 530-7139 E-mail: dexterleeausdoj.gov
+
+Attorney for Respondent
+
+## CERTIFICATE OF SERVICE
+
+I HEREBY CERTIFY that on July 9, 2008, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF.
+
+s/ Dexter A. Lee
+
+DEXTER A. LEE
+
+Assistant U.S. Attorney
+
+## SERVICE LIST
+
+In Re Jane Doe
+
+Case No. 08-80736-CIV-MARRA
+
+United States District Court, Southern District of Florida
+
+Brad IM, Esq.
+
+The Law Office of Brad & Associates, LLC
+
+2028 Street, Suite 202
+
+Hollywood, Florida 33020
+
+(954) 414-8033
+
+Fax: (954) 924-1530
+
+Attorney for Jane Doe

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marker2/court-doe-v-us/EFTA02752702/EFTA02752702.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO. 08-80736-CIV-MARRa
+
+IN RE: JANE DOE,
+
+Petitioner.
+
+## ORDER
+
+TAKE NOTICE that the above-styled cause has been set for ahearing on Petitioner's Emergency Petition for Enforcement of Crime Victim's Rights Act on Friday, July 11, 2008 at 10:15 A.M. before United States District Judge Kenneth A. Marra, 701 Clematis Street, Courtroom 4, West Palm Beach, Florida.
+
+DONE and ORDERED in at West Palm Beach, Palm Beach County, Florida this /6 day of July, 2008.
+
+KENNETH A. MARRA United States District Judge copies to:
+
+all counsel of record

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marker2/court-doe-v-us/EFTA02752703/EFTA02752703.md

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+# UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80736-CIV-MARRS
+
+IN 1E: JANE DOE,
+
+Petitioner.
+
+FILED by— \_ D.C. JUL 11 2038 STEVEN M. LAWN )RE CLERK U.S. DIST. CT. S.D. OF FLA. • LN
+
+# VICTIM'S REPLY TO GOVERNMENT'S RESPONSE TO EMERGENCY PETITION FOR ENFORCEMENT OF CRIME VICTIM'S RIGHTS ACT, 18 U.S.C. § <sup>3771</sup> AND OBJECTION TO GOVERNMENT'S MOTION FOR SEALING OF PLEADINGS
+
+COMES NOW the Petitioner, JANE DOE, by and through her undersigned attorney, pu-suant to the Crime Victim's Rights Act, 18 U.S.C. Section 3771 ("CVRA"), and files this Reply to the Government's Response to her Emergency Petition for Enforcement and Objection to the Sealing of the Pleadings in this matter as follows:
+
+### INTRODUCTION
+
+Four days ago (July <sup>7</sup> ih), Petitioner filed in this Court a motion seeking enforcement of (among other rights) her right to "confer" with the prosecution before a plea arrangement is reached disposing of the criminal charges involving her — <sup>a</sup>right promised to her in the Crime Victims' Rights Act (CVRA). See 18 U.S.C. § 3771(d)(5) (victims of crime have the "reasonable right to confer with the attorney for the Government in the case"). Two days later (July 91h), the Government sent her a notice that, in light of defendant, Jeffrey Epstein's entry of guilty pleas to %arious state charges and 18-month jail sentence, the Government had agreed to defer all federal prosecution — including any federal prosecution for the federal crimes committed against ler. This deferred prosecution agreement was reached without conferral with Petitioner — or, indeed, with the many other young victims of the defendant's crimes. And the agreement remarkably al owed the defendant — a billionaire with extraordinary political connections -- to escape all federal prosecution for dozens of serious federal sex offenses against minors.
+
+On July 91h, the Government also filed with this Court a response to the Petitioner's petition for enforcement of her CVRA rights. In its response, the Government argues that it (lid not need to confer with Petitioner because there was no formal "court proceeding" pending at the time the Government negotiated this non-prosecution agreement. This position ignores the plain la iguage of the CVRA - which extends the right to confer to any "case," not any "court proceeding" — and flies in the face of the Fifth Circuit's recent decision that is squarely on point — In re M, 527 F.3d 391 (5ih Cir. 2008). Perhaps in recognition of the weakness of its position, the Government goes on to argue that it used its "best efforts" to comply the CVRA. But the Government never conferred with Petitioner about the agreement - so the Government's efforts fall well short of affording Petitioner her right to confer. Finally, the Government claims that it disclosed some of its activities to Petitioner in this case (identified as "C.W." in the Government's papers). But neither Petitioner nor undersigned counsel were ever notified of the proposed nonprosecution agreement. To the contrary, undersigned counsel was advised that a federal indictment was in the works. For all these reasons, the Government's response lacks merit. The Court should therefore declare the proposed non-prosecution agreement an illegal one. sine( 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.
+
+The Government also apparently proposes to keep its activities in this case secret, by filing documents under seal. It bears emphasizing that none of the pleadings in this matter discloses, either directly or indirectly, the identity of a minor victim. In light of this fact, the Government
+
+bears a heavy burden in deviating from the ordinary rules, a burden it has not carried. There is no sound basis for keeping the pleadings in this matter sealed. Moreover, the matter is one of exceptional public interest — involving what appears to Petitioner to be a "sweetheart" nonprosecution agreement for multiple sex crimes against children committed by a well connected billionaire. Accordingly, the papers in this case should be lodged in the Court's public file
+
+# I. THE GOVERNMENT HAS VIOLATED PETITIONER'S RIGHT TO "CONFER" BEFORE REACHING THE NON-PROSECUTION AGREEMENT.
+
+The Crime Victims' Rights Act promises Petitioner that she will have "[title reasonable right to confer with the attorney for the Government in the case." 18 U.S.C. § 3771(d)(5) (emphasis added). To justify its failure to confer here, the Government's lead argument in its response is that there was no "court proceeding" in this case that triggered Petitioner's right to confer. Gov't Response at 1-2. The Government's position flouts the plain language of the CVRA. The CVRA guarantees to Petitioner the right to confer with prosecutors "in the case not in a "court proceeding." Indeed, the fact that (as the Government notes) the drafters of the CVRA used the term "court proceeding" elsewhere in the statute makes it obvious that they intended to give victims a right to confer that extended beyond simple court proceedings -- that is, the right to confer about "the case."
+
+Obviously there was "a case" going on in this matter for some time. Indeed, the Government sent notice to Petitioner more than a year ago that "your case is under investigation." See Letter from A. Villafafia to C.W. at 2 (June 7, 2007) (attached to Govemmem's Response) (emphasis added). The notice went on to tell Petitioner that "as a victim and/or witness of a federal offense, you have a number of rights." Id. at 1. Of course, she would not have had those rights if she was not covered by the CVRA. Interestingly, the letter also advised
+
+Petitioner that "if you believe that the rights set forth above [e.g., the right to confer and other CVRA rights] are being violated, you have the right to petition the Court for relief" Id. at I.
+
+If there were any doubt that the drafters of the CVRA intended for its rights to extend to pre-indictment situations, they disappear in light of the CVRA's instruction that a crime victim sv to seeks to assert rights in pre-indictment situations should proceed in the court where the crime was committed: "The rights described in subsection (a) [of the CVRA] shall be asserted in the district in which a defendant is being prosecuted for the crime or, if no prosecution is urdentuy, in the district court in the district in which the crime occurred." 18 U.S.C. § 3771(d)(3) (emphasis added). Petitioner noted the importance of this language in her opening Petition, see Emergency Victim's 5, but the Government chose not to discuss it in its reply.
+
+In a case remarkably similar to this one, the Fifth Circuit has recently held that victims have a right to confer with federal prosecutors even before any charges are filed. In In re M, 527 F.3d 391, 394 (51h Cir. 2008), a wealthy corporate defendant reached a generous plea &al w th the Government — a deal that the Government concluded and filed for approval with the district court without conferring with the victims. When challenged on a mandamus petition by the victims, the Fifth Circuit held:
+
+> The district court acknowledged that "[t]here are clearly rights under the CVRA that apply before any prosecution is underway." BP Prods., 2008 WL 501321 at \*11, 2008 U.S. Dist. LEXIS 12893, at \*36. Logically, this includes the CVRA's establishment of victims' "reasonable right to confer with the attorney for the Government." 18 U.S.C. § 3771(a)(5). At least in the posture of this case (and we do not speculate on the applicability to other situations), the government should have fashioned a reasonable way to inform the victims of the likelihood of criminal charges and to ascertain the victims' views on the possible details of a plea bargain.
+
+la. at 394.
+
+As we understand the Government's response, it asks this Court to decline to follow the Fifth Circuit's holding and create a split of authority on this important issue. See Gov't Response at 2-3. Notably, the Government does not cite any cases supporting its position. Instead, the Government would have this Court deviate from the Fifth Circuit's well-reasoned opinion because the Circuit's "discussion of the scope of the right to confer was unnecessary because the co art ultimately declined to issue mandamus relief" Gov't Response at 2 (citing 527 F.3d at 395). This is simply untrue. The Fifth Circuit faced a petition for mandamus relief from the victims in that case, asking that a proposed "binding" plea agreement negotiated under Fed. R. Crim. P. I I (c)( I )(C) (i.e., a plea agreement obligating the judge to impose a specific sentence) be rejected. The victims asked for that relief because of the Government's failure to confer with tFem before the charges and accompanying plea agreement were filed. The Fifth Circuit held teat the victims' rights had been violated in the passages quoted above. It then went on to remand .he rratter to the district court for further consideration of the effect of the violations of the victims' rights:
+
+We arc confident, however, that the conscientious district court will fully consider the victims' objections and concerns in deciding whether the plea agreement should be accepted.
+
+The decision whether to grant mandamus is largely prudential. We conclude that the better course is to deny relief, confident that the district court will take heed that the victims have not been accorded their full rights under the CVRA and will carefully consider their objections and briefs as this matter proceeds.
+
+527 F.3d at 396. Obviously, the Fifth Circuit could not have instructed the District Court to "take hxd" of the violations of victims' rights unless it has specifically held, as a matter of law, that t w victims' rights had been violated.
+
+The Government's next effort to deflect the force of the Fifth Circuit's decision is that the
+
+Circuit did not directly quote three words found in the CVRA's right to confer — the words "in the case." See Gov't Response at 2. But the Fifth Circuit had received briefs totaling close to 100 pages in that case and was obviously well aware of the statute at hand. Indeed, in the very paragraph the Government claims is troublesome, the Fifth Circuit cited to the district coin opinion under review, which had quoted all the words in the statute. See United States v. BP Products, 2008 WL 501321 at "7 (noting victims right to confer "in the case"), cited in In re M, 527 F.3d at 394.
+
+The Government finally notes that the Fifth Circuit properly stated that its ruling about the Government violating the right to confer applied "in the posture of this case." 527 F.3d at 394. Bit the posture of this case — at least in its relevant aspects -- is virtually identical to the posture there. The Fifth Circuit held that the Government had an obligation to confer with the victims before charges mere filed and before a final plea arrangement ms reached. Without giving I he victims a chance to confer before hand, the plea agreement might be fatally flawed because it did not consider the concerns of the victims. Thus, the Fifth Circuit emphasized the need to confer with victims before any disposition was finally decided: "The victims do have reason to believe that their impact on the eventual sentence is substantially less where, as here, their input is received after the parties have reached a tentative deal. As we have explained, that is why ,ve conclude that these victims should have been heard at an earlier stage." Id. at 395. The posture in this case is exactly the same - the Government should have conferred before the parties "reached a tentative deal." The fact that the deal reached here is slightly different than the deal reached in the case (a non-prosecution agreement versus a plea agreement) is truly a distinction without a difference. If anything, the facts here cry out for conferral even more than in
+
+that case. At least the defendant there agreed to plead guilty to a federal felony. Here, the we.ilthy defendant has escaped all federal punishment — a plea deal that Petitioner would have strenuously objected to . . . if the Government had given her the chance.
+
+The Fifth Circuit's decision in= has been cited in one very recent District Court decision, which provides further support for Petitioner's position here. In United States v. Rubin, 2008 WI. 2358591 (E.D.N.Y. 2008), the victims argued for extremely broad rights under the C'VRA. After citing, the District Court agreed that the rights were expansive and could apply before indictment, but subject to the outer limit that the Government be at lean "contemplating" charges:
+
+Quite understandably, movants perceive their victimization as having begun long before the government got around to filing the superseding indictment. They also believe their rights under the CVRA ripened at the moment of actual victimization, or at least at the point when they first contacted the government. Movants rely on a decision from the Southern District of Texas for the notion that CVRA rights apply prior to any prosecution. In United States v. BP Products North America, Inc., the district court reasoned that because § 3771(d)(3) provided for the assertion of CVRA rights "in the district court in which a defendant is being prosecuted for the crime or, if no prosecution is underway, in the district court in the district in which the crime occurred," the CVRA clearly provided for "rights ... that apply before any prosecution is underway." (United States v. BP Products North America, Inc., Criminal No. H-07-434, 2008 WL 501321 at \*1 .Tex. Feb.21, 2008) (emphasis in original), mandamus denied in part, In re , No. 08-20125, 2008 WL 1960245 (5ih Cir. May 7, 2008). But, assuming that it was within the contemplation and intendment of the CVRA to guarantee certain victim's rights prior to formal commencement of a criminal proceeding, the universe of such rights clearly has its logical limits. For example, the realm of cases in which the CVRA might apply despite no prosecution being "underway," cannot be read to include the victims of uncharged crimes that the government has not even contemplated. It is impossible to expect the government, much less a court, to notify crime victims of their rights if the government has not verified to at least an elementary degree that a crime has actually taken place, given that a corresponding investigation is at a nascent or theoretical stage.
+
+Id. at •6. Here, of course, the criminal investigation went far beyond the "nascent or theoretical
+
+stage" — to a point where the Government determined that crimes had been committed and that the defendant should plead guilty to either a state or federal offense.
+
+For all these reasons, the Court should follow the Fifth Circuit and hold that Petitioner and the other victims in this case had the right to confer with the Government before it reached ils non-prosecution agreement.
+
+# II. THE GOVERNMENT HAS NOT USED ITS "BEST EFFORTS" TO COMPLY WITH THE CRIME VICTIM'S RIGHTS ACT.
+
+The Government next argues that it has somehow used its "best efforts" to comply with the CVR A in this case. Gov't Response at 3. The bulk of the Government's arguments concern varous notices that it sent to victims. Buried in the middle of these arguments is the Government's stark concession that proves Petitioner's claim: "[T] he specific terms of the negotiation here not disclosed prior to a final agreement being reached because the Government believed doing so aould jeopardize and prejudice the prosecution in the event an agreement could not be made." Gov't Response at 6 (emphasis added). In other words, Petitioner — and the many other victims of the defendant's federal sex offenses — was deliberately kept in the dark about the fact that the Government was planning to reach a deal that would permit the defendant to escape all federal punishment in favor of an 18-month county jail sentence. This bald decision to conceal from the victims what was happening violated the basic premise of the Crime Victim's Rights Act: that victims deserve to know what is happening in their cases. Congress was concerned that in the federal system crime victims were "treated as non-participants in a critical event in their lives. They were kept in the dark by prosecutors too busy to care enough ... and by a court system that simply did not have a place for them." 150 CoNG. REC. S4262 (Apr. 22. 2004) (statement of Sen. Feinstein). To remedy this problem, Congress gave victims "the simple
+
+right to know what is going on, to participate in the process where the information that victivis an•d their families can provide may be material and relevant ... ." Id.
+
+The CVRA required the Government to confer with Petitioner and consider her views about the proposed arrangement in this case. Indeed, the Government's own regulations requit prosecutors to "consider victims' views about prospective plea negotiations." U.S.DEP'T OF JUSTICE OFFICE FOR VICTIMS OF CRIME, ATTORNEY GENERAL GUIDELINES FOR VICTIMS AND WITNESS ASSISTANCE 30 (2005). Congress obviously intended for victims to have ameaningful role in the criminal justice process.
+
+The Fifth Circuit recently confronted — and rejected — a very similar claim from the Government that it did not need to meaningfully confer with crime victims. There, tte Government's purported justification for failing to confer was the risk of pre-trial publicity to the defendant. The Fifth Circuit summarily dismissed that argument, holding: "Congress made the policy decision -- which we are bound to enforce -- that the victims have aright to inform the plea negotiation process by conferring with prosecutors before aplea agreement is reached." Id. at 395. In this case, too, this Court is "bound to enforce" Congress' decision that prosecutors confer with victims before reaching a plea agreement.
+
+The Government is not entitled to pick and choose which particular cases it will giv.: victims the right to confer. In support of its remarkable position, the Government cites <sup>a</sup> pro vision in the CVRA that provides that "[n]othing in this chapter shall be construed to impair the prosecutorial discretion of the Attorney General or any officer under his direction." 18 U.S.C. § 3'17/ (d 1(6). But the Government made the same argument in the case — and lost. The Fifth Circuit reversed the District Court decision that enforcing the right to confer might impair
+
+prosecutorial discretion with the following statement: "[Giving the right to confer to victims] is not an infringement, as the district court believed, on the government's independent prosecutor al discretion. . . . instead, it is only a requirement that the government confer in some reesonahle wry with the victims before ultimately exercising its broad discretion." 574
+
+Moreover, the Government's asserted justification for failing to confer is transparently flimsy. It asserts that, if the victims had been told that the plea agreement gave them advantages in civil litigation against the defendant, then that would have "provid[ed) Epstein the means )f impeaching the victim witnesses . . ." Gov't Response at 5. But obviously the victims were already subject to impeachment on that ground — even if no plea agreement was ever reached. The defense attorneys presumably would have asked all of the victims at any criminal trial about the possibility that they could pursue civil litigation against the defendant if he was convicted. The plea agreement did not change the obvious fact that a criminal conviction — whether by plea agreement or by jury trial — would facilitate civil claims by the victims of the defendant's crimes.
+
+In light of all this, this Court should reach the obvious conclusion: The Government did not use its "best efforts" to protect the rights of Petitioner (and the other victims) in this case when it failed to confer with her about the non-prosecution agreement.
+
+#### III. THE GOVERNMENT DID NOT CONFER WITH PETITIONER.
+
+The Government finally makes a factual argument about the state of negotiations in this case. The brief discussion (see Gov'ts Response at 7-8) is somewhat vague. One short passa€,e in the response, however, seems to assert that Petitioner was given some sort of notice about tie plea agreement about nine months ago. Gov't Response at 7 ("In October 2007, C.W. was not represented by counsel. . . . She was given telephonic notice of the agreement, as were three other
+
+victims.").
+
+If the Government is asserting that Petitioner was told that a non-prosecution agreement had been reached with the defendant as early as October 2007, Petitioner strongly disputes this alleged "fact." To the contrary, undersibmed counsel was told by federal prosecutors within the last 60 days that a federal "indictment" was under consideration.
+
+Petitioner does not believe that the Government is truly asserting that she was told about a non-prosecution agreement because, elsewhere in its brief, the Government makes the opposi:e assertion: "[TJhe specific terms of the negotiation ntre not disclosed prior to a final agreement being reached because the Government believed doing so nvuld jeopardize and prejudice tie prosecution in the event an agreement could not he made." Gov't Response at 6 (emphasis added).
+
+Because of the confusion about what the Government is truly asserting, Petitioner requests an opportunity to address the facts directly with the Court at the hearing. If necessary, Petitioner also requests leave of Court after the hearing to provide whatever supplemental infiwmation (by way of affidavit or otherwise) that would be needed to prove that she was never told that the Government was considering a federal non-prosecution agreement with the defendant, much less given a chance to confer with the Government on this extraordinarily lenient disposition.
+
+#### IV. THE COURT SHOULD ENTER AN ORDER DIRECTING THE GOVERNMENT TO CONFER WITH THE PETITIONER BEFORE ANY NON-PROSECUTION AGREEMENT BECOMES FINALIZED.
+
+Far all these reasons, it is obvious that Petitioner's right to confer was violated in this case. The question then arises as to the appropriate remedy. The obvious remedy is to declare the non-prosecution agreement illegal and direct that the Government proceed to negotiate <sup>a</sup>new agreement — in a process that respects Petitioner's (and the other victims') rights.
+
+The non-prosecution agreement here violates federal law. As described by tie Government (the victims have not been even given the courtesy of a copy of the agreement), tie agreement prevents federal prosecution of the defendant for numerous sex offenses. Yet tne agreement was reached without giving Petitioner her right to confer - a violation of 18 U.S.C. § 3771(a)(5).
+
+When other plea arrangements have been negotiated in violation of federal law, they have been stricken by the courts. For example, United States v. UM 98 F.3d 944 (7th Cir. 199E), held that where a sentence on a new crime could not run concurrently with aprobation revocation the defendant was then serving — contrary to the assumption of the parties to the plea agreement the defendant was not entitled to specific performance of the plea agreement. The Court explained that the case was one "in which the bargain is vitiated by illegality . . ." Here, of course, exactly the same is true: the non-prosecution agreement is vitiated by illegally — namely, the fact that it was negotiated in violation of the victims' rights. Other cases reach similar conclusions. See. e.g.. United States v. a 70 F.3d 563 (101h Cir. 1995) (prosecutor agreed to recommend probation, but it now appears that would be an illegal sentence in this case, and thus the only adequate remedy is to allow defendant to withdraw the plea); Craig v. People, <sup>986</sup> P.2d 951 (Colo. 1999) (because "neither the prosecutor nor the trial court have authority to modify or waive the mandatory parole period," such "is not apermissible subject of plea negotiations," and thus, even if "the trial court erroneously approves of such an illegal bargain" such plea is "invalid" and thus will not be specifically enforced). Nor can the defendant claim
+
+some right to specific performance of an illegal non-prosecution agreement. See State v. 582 N.W.2d 879 (Minn. 1998) (plea agreement for 81 months sentence, but court added 10-year conditional release term because, under facts of case, a sentence without such release term was "plainly illegal," and thus the remedy of specific performance not available); State v. Wall, 348 N.C. 671, 502 S.E.2d 585 (1998) (plea agreement was for sentence to be concurrent with one not yet completed, but state statute mandates consecutive sentence on facts of this case; "defendant is not entitled to specific performance in this case because such action would violate the laws of this stale"); I:x parte Rich, 194 S.W.3d 508 (Tex. Crim App. 2006); (where "the plea bargain seemed fair on its face when executed, it has become unenforceable due to circumstances beyond the cortrol of [the parties], namely the fact that one of the enhancement paragraphs WES mischaracterized in the indictment, resulting in an illegal sentence far outside the statutory range." proper remedy is plea withdrawal, as "there is no way of knowing whether the State would have offiatd a plea bargain within the proper range of punishment that he deemed acceptable"); State v. Afarzone. 212 W.Va. 368, 572 S.E.2d 891 (2002) (where plea agreement was that defendant would plead guilty to 2 felony counts of felon in possession of firearm and prosecutor would dismiss the remaining 6 counts re other offenses with prejudice, and all parties erroneously believed these 2 crimes were felonies, lower court "correctly resolved this unfortunate predicament by holding that a plea agreement which cannot be fulfilled based upon legal impossibility must be vacated in its entirety, and the parties must be placed, as nearly as possible, in the positions they occupied prior to the entry of the plea agreement").
+
+This Court is obligated to take steps to protect Petitioner's rights. Under the CVRA, "[i]ii any court proceeding involving an offense against a crime victim, the court shall ensure that the
+
+crime victim is afforded the rights described in [the CVRA]." 18 U.S.C. § 3771(b)(0. The CVRA also confers on crime victims the right to "assert the rights described in [the CVRA]." <sup>18</sup> U.S.C. § 377I(d)( I ). Obviously there is now a court proceeding before this Court in which Pctitioner is asserting rights under the CVRA. This Court must therefore protect her rights Dy declaring the non-prosecution agreement invalid.
+
+#### V. THE PUBLIC IS ENTITLED TO SEE THE GOVERNMENT'S EXPLANATIONS FOR ITS EXTRAORDINARILY LENIENT NON-PROSECUTION AGREEMENT.
+
+The Government has also filed its pleadings in this matter under seal. There is no sound re2son for concealing from the public the Government's explanations in this matter. Accordingly, the Government's pleadings should be unsealed.
+
+The Government offers two explanations for sealing its pleadings. First, the Government claims that the pleading would reveal correspondence with minors. Gov't Motion at 1. But the Government has redacted the names of the minors involved (including Petitioner's name), so there is no good basis for sealing. (Counsel does respectfully request that the Government doublecheck its redactions to make sure that no name has been overlooked.) Indeed, the very statute that the Government cites (18 U.S.C. § 3509(d)(2)) envisions that minors' names will be redacted and then the remaining pleadings made available to the public. See 18 U.S.C. § 3509(d)(2) ("The person who makes a filing [involving a minor] shall submit to the clerk of the court . . . the paper with the portions of it that disclose the name of or other information concerning a child redacted, to be placed in the public record') (emphasis added).
+
+Second, the Government asserts that its pleading should be kept under seal "to maintain the confidentiality of the agreement reached with an interested party." Gov't Motion at 2. Petitioner believes exactly the opposite is true - confidentiality will undermine public confidence in the federal criminal justice system.
+
+This case involves a non-prosecution agreement with apolitically-connected billionaire that has drawn considerable public attention. See. e.g., Palm Beach Post.Com, Banker Epstein Pleads in Prostitution Case, Gets 18 Months (June 30, 2008) ("He lives in a Palm Beach waterfront mansion and has kept company with the likes of President Bill Clinton, Prince Andrew and Donald Trump, but investment banker Jeffrey Epstein will call the Palm Beach County jail ho ne for the next 18 months"). The public is entitled to know all of the circumstances surrounding this federal (non) prosecution. The public may well wonder — as Petitioner does in N.; case — why a defendant who committed multiple sex crimes over an extended period of time against numerous minor victims is receiving only an 18-month jail sentence and a "free pass" fro <sup>n</sup> the federal government. if the Government had conferred with Petitioner, she would have explained why this proposed disposition did not begin to reflect "the seriousness of the offense" 18 U.S.('. §3553(a)(2XA).
+
+The Eleventh Circuit has instructed that the district courts must make substantial findings betare scaling records in cases before it. For instance, in United States v. Ochoa-Vasque, <sup>428</sup> F.3d 1015 (111h Cir. 2005), it reversed an order from this Court that had sealed pleadings in <sup>a</sup> criminal case, emphasizing the importance of the public's historic First Amendment right of access to the courts. To justify sealing, "a court must articulate the overriding interest along with findings specific enough that a reviewing court can determine whether the closure order was properly entered." Id. at 1030. The Government has not discussed the controlling court authority on sealing orders, much less attempted to prove that there is an "overriding interest"
+
+justifying sealing. For this reason, the Government's attempts to keep secret what has been done in this case should be rejected and its motion for sealing of its response denied.
+
+**CONCLUSION**
+
+The Petitioner requests the intervention of this Court to ensure that her rights are respected and accorded, as promised in the Crime Victims' Rights Act. The Court should enter an order finding the non-prosecution agreement in this case was negotiated in violation of the CVRA and therefore is illegal and invalid. The Court should also deny the Government's motion to seal its pleadings in this case.
+
+DATED this 11th day of July, 2008.
+
+Respectfully Submitted,
+
+THE LAW OFFICE OF BRAD [REDACTED] &  
+ASSOCIATES, LLC
+
+![]()Brad [REDACTED] Esquire  
+Attorney for Petitioner  
+Florida Bar #542075  
+2028 [REDACTED] Street  
+Suite 202  
+Hollywood, Florida 33020  
+Telephone: 954-414-8033  
+Facsimile: 954-924-1530
+
+**CERTIFICATE OF SERVICE**
+
+I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been provided by hand delivery in open court to the Attorney appearing on behalf of the United States Attorney's Office, this 11th day of July, 2008.
+
+![]()Brad [REDACTED] Esquire  
+Attorney for Petitioner  
+Florida Bar No. 542075

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marker2/court-doe-v-us/EFTA02752720/EFTA02752720.md

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+**U.S. District Court  
+Southern District of Florida (West Palm Beach)  
+CIVIL DOCKET FOR CASE #: 9:08-cv-80736-KAM  
+*Internal Use Only***
+
+Doe v. United States of America  
+Assigned to: Judge Kenneth A. Marra  
+Cause: no cause specified
+
+Date Filed: 07/07/2008  
+Jury Demand: None  
+Nature of Suit: 440 Civil Rights: Other  
+Jurisdiction: U.S. Government Defendant
+
+**Petitioner**
+
+**Jane Doe**
+
+represented by [REDACTED] **James [REDACTED]**  
+2028 [REDACTED] Street  
+Suite 202  
+Hollywood, FL 33020  
+954-414-8033  
+Fax: 924-1530  
+Email: BE@kubickidraper.com  
+*LEAD ATTORNEY*  
+*ATTORNEY TO BE NOTICED*
+
+V.
+
+**Respondent**
+
+**United States of America**
+
+represented by **Ann [REDACTED] C. Villafana**  
+United States Attorney's Office  
+500 South Australian Avenue  
+Suite 400  
+West Palm Beach, FL 33401  
+561-820-8711  
+Fax: 820-8777  
+Email: [REDACTED]  
+*LEAD ATTORNEY*  
+*ATTORNEY TO BE NOTICED*
+
+**Dexter Lee**  
+United States Attorney's Office  
+99 NE 4 Street  
+Miami, FL 33132  
+305-961-9320  
+Fax: 530-7139  
+Email: dexter.lee@usdoj.gov  
+*LEAD ATTORNEY*  
+*ATTORNEY TO BE NOTICED*
+
+| Date Filed | #        | Docket Text                                                                                                                                                                                             |
+|------------|----------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| 07/07/2008 | <u>1</u> | EMERGENCY PETITION for Victim's Enforcement of Crime Victim's Rights Act 18 USC 3771 against United States of America Filing fee \$ 350. Receipt#: 724403, filed by Jane Doe.(rb) (Entered: 07/07/2008) |
+| 07/07/2008 | <u>2</u> | CERTIFICATE OF EMERGENCY by Jane Doe re <u>1</u> Complaint (rb) (Entered: 07/07/2008)                                                                                                                   |
+| 07/07/2008 | <u>3</u> | ORDER requiring U.S. Attorney to respond to <u>1</u> Complaint filed by Jane Doe by 5:00 p.m. on 7/9/08. Signed by Judge Kenneth A. Marra on 7/7/08. (ir) (Entered: 07/07/2008)                         |
+| 07/09/2008 | <u>4</u> | NOTICE of Attorney Appearance by Dexter Lee on behalf of United States of America (Lee, Dexter) (Entered: 07/09/2008)                                                                                   |
+
+| 07/09/2008  | 6  | Sealed Document. (rb) (Entered: 07/10/2008)                                 |
+|-------------|----|-----------------------------------------------------------------------------|
+| 07/09/2008  | 7  | Sealed Document. (rb) (Entered: 07/10/2008)                                 |
+| 07/09/2008  | 8  | Sealed Document. (rb) (Entered: 07/10/2008)                                 |
+| 07/10/2008  |    | 5 ORDER SETTING HEARING: Petitioner's Emergency Petition for Enforcement    |
+| 07/I 1/2008 | 2  | REPLY to Response (under seal) rd. Complaint/Emergency Petition, and        |
+| 07/I 1/2008 | 10 | Minute Entry for proceedings held before Judge Kenneth A. Marra:            |
+| 07/11/2008  |    | li. ORDER Denying Motion to Seal re 7 Sealed Document, 6 Sealed Document, 8 |

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marker2/court-doe-v-us/EFTA02752722/EFTA02752722.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+NO. 08-80736-CIV-MARRall
+
+IN RE: JANE DOE,
+
+Petitioner.
+
+## ORDER DENYING MOTION TO SEAL
+
+THIS CAUSE comes before the Court on the United States of America's Motion to Seal its Response to Victim's Emergency Petition for Enforcement of Crime Victim Rights Act, filed July 9, 2008. The Court has carefully considered the motion and is otherwise fully advised in the premises. For the reasons explained at the hearing held on July 11, 2008, it is hereby
+
+ORDERED AND ADJUDGED that the Motion to Seal is DENIED. The Clerk shall make available for public viewing all documents placed under seal on July 9, 2008.
+
+DONE AND ORDERED ink at West Palm Beach, Palm Beach County, Tt• Florida, this/ day of July, 2008.
+
+KENNETH A. MARRA United States District Judge
+
+Copies furnished to: all counsel of record

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marker2/court-doe-v-us/EFTA02752723/EFTA02752723.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO. 08-80736-CIV-MARRa.
+
+IN RE: JANE DOE,
+
+Petitioner.
+
+| FILED by <u>DCS</u> D.C.                                             |
+|----------------------------------------------------------------------|
+| JUL 09 2008                                                          |
+| STEVEN M. LAIRMORE<br>CLERK U.S. D. ST. CT.<br>S.D. OF FLA. - W.P.B. |
+
+## UNITED STATES' MOTION TO FILE RESPONSE TO VICTIM'S EMERGENCY PETITION FOR ENFORCEMENT OF VICTIM RIGHTS ACT AND DECLARATION OF A. VILLAFAICIA UNDER SEAL.
+
+The United States of America, by and through its undersigned counsel, files its Motion to File Response to Victim's Emergency Petition for Enforcement of Victim Rights Act and Declaration of A. Villaftula Under Seal, pursuant to S.D. Fla. L.R. 5.4 and 18 U.S.C. § 3509(dX2), and states:
+
+On July 7, 2008, petitioner filed her Emergency Victim's Petition for Enforcement of Crime Victim Rights Act, 18 U.S.C. § 3771. Petitioner did not disclose her name, and alleges that she was a minor child when she was the victim of federal crimes committed by Jeffrey Epstein. Petition, 9 I.
+
+On July 7, 2008, the Court directed the Government to file a response to the Petition by July 9, 2008, at 5:00 p.m.
+
+The Government has prepared its Response, which is attached as Exhibit A, and :he Declaration of Assistant United States Attorney A. Villafafla, as well as correspondence with several individuals who were minors when the relevant events occurred. Additionally, the Government's Response also refers to actions taken by the United States Attorney's Office with an interested party which was done in confidence. The Government believes that its Response should
+
+ro
+
+be filed under seal, in order to protect the minor victims' privacy, as well as to maintain the confidentiality of the agreement reached with an interested party.
+
+The Government requests that its Response and the Declaration be sealed until the termination of the instant litigation, or five years from the date of filing, whichever occurs first. Upon the expiration of the time period for sealing, the Government requests the documents be returned to the United States Attorney's Office.
+
+WHEREFORE, the government respectfully requests that its Response to Victim's Emergency Petition for Enforcement of Crime Victim Rights Act, 18 U.S.C. § 3771, and the Declaration of A. [REDACTED] Villafaña be filed under seal.
+
+Respectfully submitted,
+
+R. ALEXANDER ACOSTA  
+UNITED STATES ATTORNEY
+
+By:
+
+![]()DEXTER A. LEE  
+Assistant U.S. Attorney  
+Fla. Bar No. 0936693  
+99 N.E. 4<sup>th</sup> Street  
+Miami, Florida 33132  
+(305) 961-9320  
+Fax: (305) 530-7139  
+E-mail: [dexter.lee@usdoj.gov](mailto:dexter.lee@usdoj.gov)
+
+Attorney for Respondent
+
+## CERTIFICATE OF SERVICE
+
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via facsimile transmission and U.S. Mail, this /17/! day of July, 2008, to: Brad Esq., The Law Offices of Brad & Associates, LLC, (954) 924-1530, 2028 Street, Suite 202, Hollywood, Florida 33020.
+
+Assistant U.S. Attorney

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marker2/court-doe-v-us/EFTA02752726/EFTA02752726.md

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+#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO. 08-80736-CIV-MARRAi
+
+IN RE: JANE DOE,
+
+Petitioner.
+
+I
+
+### GOVERNMENT'S RESPONSE TO VICTIM'S EMERGENCY PETITION FOR ENFORCEMENT OF CRIME VICTIM RIGHTS ACT, 18 U.S.C. § 3771
+
+FILED Dy D.C. JUL 0 9 2008 STEVER M. tARIMORE CLEAN U.S. Inn Cr S.O. OF R.A. - W.RB.
+
+The United States of America, by and through its undersigned counsel, files its Response to Victim's Emergency Petition for Enforcement of Victim Rights Act, 18 U.S.C. § 3771, and states:
+
+# I. THERE IS NO "COURT PROCEEDING" UNDER 18 U.S.C. § 3771(b1
+
+Petitioner complains that she has been denied her rights under the Crime Victims Rights Act, 18 U.S.C. § 3771. In the emergency petition filed by the victim, she alleges the Government has denied her rights since she has received no consultation with the attorney for the government regarding possible disposition of the charges (18 U.S.C. § 377I(a)(5)); no notice of any public court proceedings (18 U.S.C. § 3771(aX2)); no information regarding her right to restitution (18 U.S.C. § 377140(6)); and no notice of rights under the Crime Victim Rights Act (CVRA). Emergency Petition, ¶ 5.
+
+The instant case is unique in several respects. First, in 2006, Jeffrey Epstein was charged with felony solicitation of prostitution in the Circuit Court of the Fifteenth Judicial Circuit, Palm Beach County, Florida. This charge was based upon the offenses alleged in paragraph I of the petition. Second, while Epstein has been under federal investigation, he has not been charged in
+
+14B
+
+the Southern District of Florida.
+
+Title 18, U.S.C., Section 3771(bX1) provides in pertinent part that, "riln any court proceeding involving an offense against a crime victim, the court shall ensure that the crime victim is afforded the rights described in subsection (a)." There is no "court proceeding" in the instant case since Epstein has not been charged with violation of any federal statute. No federal grand jury indictment has been returned, nor has any criminal information been filed. There can thus be no failure of a right to notice of a public court proceeding or the right to restitution.
+
+In her memorandum, petitioner relics upon In Re M, 527 F.3d 391 (5th Cir. 2008), where the Fifth Circuit held that the CVRA required the government to "confer in some reasonable way with the victims before ultimately exercising its broad discretion." a at 395. In M, the government sought and obtained an ex parte order permitting it to negotiate a plea agreement with BP Products North America, without first consulting with the victims, individuals injured and survivors of those killed in a refinery explosion. A plea agreement was ultimately negotiated and the victims objected. The appellate court found that the CVRA granted a right to confer. However, the court declined to grant mandamus relief for prudential reasons, finding that the district court had the benefit of the views of the victims who chose to participate at the hearing held on whether the plea agreement should be accepted. Id. at 396.
+
+is legally distinguishable in several respects. For one thing, the court's discussion of the scope of the right to confer was unnecessary because the court ultimately declined to issue mandamus relief. M, 527 F.3d at 395. Also, in offering its view that this right applies precharge, it is noteworthy that the court, in purporting to quote the statute, omitted the last three words of section 3771(aX5)("in the case"), words that arguably point in the opposite direction by
+
+suggesting that the right applies post-charge. Further, the court went to great lengths to emphasize that its holding was limited to the particular circumstances presented in that case (i.e., the simultaneous filing of a plea agreement and formal charges), which of course, is not the case here. No federal charges have been filed in the instant case, and this case, unlike , involves an agreement to defer federal prosecution in favor of prosecution by the State of Florida and not a guilty plea. Its at 394. Finally, the court expressly declined to "speculate on the fright to confer's) applicability to other situations." Id. Nothing in § 3771(aX5) supports the petitioner's claim that she had a right to be consulted before the Government could enter into a nonprosecution agreement which defers federal prosecution in exchange for state court resolution of criminal liability, and a significant concession on an element of a claim for compensation under 18 U.S.C. § 2255.
+
+## II. THE GOVERNMENT HAS USED ITS BEST EFFORTS TO COMPLY WITH 18 U.S.C.& 3771(al
+
+The Epstein case was investigated initially by the Palm Beach Police Department in 2006. Exhibit A, Declaration of Assistant United States Attorney A. Villafana, ¶ 2. Subsequently, the Palm Beach Police Department sought the assistance of the Federal Bureau of Investigation (FBI). Id. Throughout the investigation, when a victim was identified, victim notification letters were provided to the victim by both the FBI Victim-Witness Specialist and AUSA Villafafa. WA 3. Petitioner's counsel. Brad , Esq., currently represents C.W., T.M., and S.R. The U.S. Attorney's Office victim notification letter to C.W. was provided by the FBI. and the letter to T.M. was hand-delivered by AUSA Villafaiia to her when she was interviewed in April 2007. FBI victim notification letters were mailed to C.W. and T.M. on
+
+January 10, 2008, and to S.R. on May 30, 2008. Villafafla Decl., 1 3.
+
+Throughout the investigation, AUSA Villafafia and the FBI's Victim-Witness Specialist had contact with C.W. Villafafia Decl., 1 4. Earlier in the investigation, T.M. was represented by James Eisenberg, Esq. Consequently, all contact with T.M. was made through Mr. Eisenberg.
+
+In mid-2007, Epstein's attorneys approached the U.S. Attorney's Office in an effort to resolve the federal investigation. al 5. At that time, Mr. Epstein had been charged by the State of Florida with solicitation of prostitution, in violation of Florida Statutes § 796.07. Mr. Epstein's attorneys sought a global resolution of this matter. The United States subsequently agreed to defer federal prosecution in favor of prosecution by the State of Florida, so long as certain basic preconditions were met. One of the key objectives for the Government was to preserve a federal remedy for the young girls whom Epstein had sexually exploited. Thus, one condition of that agreement, notice of which was provided to the victims on July 9, 2008, is the following:
+
+> "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less."
+
+The Attorney General Guidelines for Victim and Witness Assistance (May 2005), Article
+
+IV, Services to Victims and Witnesses, provides the following guidance for proposed plea agreements:
+
+- (3) Proposed Plea Agreements. Responsible officials should make reasonable efforts to notify identified victims of, and consider victims' views about, prospective plea negotiations. In determining what is reasonable, the responsible official should consider factors relevant to the wisdom and practicality of giving notice and considering views in the context of the particular case, including, but not limited to, the following factors:
+- (a) The impact on public safety and risks to personal safety.
+- (b) The number of victims.
+- (c) Whether time is of the essence in negotiating or entering a proposed plea.
+- (d) Whether the proposed plea involves confidential information or conditions.
+- (e) Whether there is another need for confidentiality.
+- (f) Whether the victim is a possible witness in the case and the effect that relaying any information may have on the defendant's right to a fair trial.
+
+Throughout negotiations, Epstein's attorneys claimed that one reason victims came forward and pressed their claims was their desire for money. They argued that victims might have an inducement to fabricate or enhance their testimony, in order to maximize their opportunities to obtain financial recompense. Villafana Dccl., 9 8. The Government was extremely concerned that disclosure of the proposed terms would compromise the investigation by providing Epstein the means of impeaching the victim witnesses, should the parties fail to reach an agreement. In light of the fact (i) that the United States agreed to defer prosecution to a previously filed state criminal case; (ii) that as a result sentencing would take place in state court before a state judge; (iii) that if the state resolution failed to meet minimum standards such that a federal prosecution was warranted, the victims would be witnesses and thus potential
+
+impeachment issues were of concern; and (iv) the United States was already making efforts to secure for victims the right to proceed federally under 18 U.S.C. § 2255 even if prosecution took place in state court, the Government determined that its actions in proceeding with this agreement best balanced the dual position of the Jane Does as both victims and potential v.itnesses in a criminal proceeding.
+
+On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA Villafafia received a copy of the proposed state plea agreement, and learned that Epstein's state plea hearing was scheduled for Monday, June 30, 2008, at 8:30 a.m. Villafafia Decl., ¶ 10. AUSA Villafafia and the Palm Beach Police Department attempted to provide notification to victims in the short time that they had. a Although all known victims were not notified, AUSA Villafafia did call attorney to provide notice to his clients regarding the hearing. AUSA Villafafia did this, even though she had no obligation to provide notice of a state court hearing. Mr. advised that he could not attend but that someone would be present at the hearing. ld.
+
+The Government has complied with 18 U.S.C. § 3771(cX1) by using its best efforts to "see that crime victims are notified of, and accorded, the rights described in subsection (a)." Specifically, petitioner was afforded the reasonable right to confer with the attorney for the Government under 18 U.S.C. § 3771(aX5). Disclosure of the specific terms of the negotiation were not disclosed prior to a final agreement being reached because the Government believed doing so would jeopardize and prejudice the prosecution in the event an agreement could not be made. Further, although 18 U.S.C. § 3771(a)(2) does not apply to state court proceedings, the government nonetheless notified petitioner's counsel on Junc 27, 2008, of the plea hearing in state court on June 30, 2008.
+
+Section 3771(d)(6) provides, in relevant part, that "[n]othing in this chapter shall be construed to impair the prosecutorial discretion of the Attorney General or any officer under his direction." The Government exercised its judgment and discretion in determining that there was a need for confidentiality in the negotiations with Epstein. The significant benefit of obtaining Epstein's concession that victims suing him under 18 U.S.C. § 2255(a) were "victims" of the enumerated offenses, despite the fact he has not been convicted in federal court, was of sufficient importance to justify confidentiality of the negotiations.
+
+## III. THE GOVERNMENT'S DISCUSSIONS WITII T.M., C.W," AND S.R.
+
+Attorney Brad has advised the Government that he represents T.M., C.W., and S.R. Victim letters were provided to all three individuals. The letters to C.W. and T.M. were forwarded on January 10, 2008. Villafaila Decl., 1 3. On May 28, 2008, S.R.'s status as a victim was confirmed when she was interviewed by federal agents. a The FBI Victim Witness specialist sent her a letter on May 30, 2008. EL
+
+When the agreement was signed in September 2007, T.M. was openly hostile to a prosecution of Epstein, and S.R. had refused to speak with federal investigators. Id., ¶ 7. While individual victims were not consulted regarding the agreement, none of Mr. clients had expressed a desire to be consulted prior to the resolution of the federal investigation. Id.
+
+In October 2007, C.W. was not represented by counsel. al 8. She was given telephonic notice of the agreement, as were three other victims. Id. These four individuals were also given notice of an expected change of plea, in state court, in October 2007.
+
+In mid-June 2008, Mr. contacted AUSA Villafana to advise that he represented C.W. and S.R., and requested a meeting. 11,1 9. AUSA Villafaila asked Mr. to send
+
+to her any information that he wished her to consider. Nothing was provided. Id. AUSA Villafela also told Mr. he could contact the State Attorney's Office, if he wished. To her knowledge, Mr. did not make the contact.
+
+The Government has acted reasonably in keeping T.M. C.W., and S.R. informed. Petitioner's rights under the CVRA have not been violated. •I herefore, her emergency petition should be denied.
+
+Respectfully submitted,
+
+R. ALEXANDER ACOSTA UNITED ST ) T S ATTORNEY
+
+By: A DEXTER A. LEE Assistant U.S. Attorney Fla. Bar No. 0936693 99 N.E. 4" Street Miami, Florida 33132 (305) 961-9320 Fax: (305) 530-7139 E-mail: dexter.leeOusdoj.gov Attorney for Respondent 6P
+
+## CERTIFICATE OF SERVICE
+
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via facsimile transmission and U.S. Mail, this? day of July, 2008, to: Brad Esq., The Law Offices of Brad & Associates, LLC, (954) 924-1530, 2028 Street, Suite 202, Hollywood, Florida 33020.
+
+> DEXTE' A. LEE Assistant U.S. Attorney

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marker2/court-doe-v-us/EFTA02752734/EFTA02752734.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+Case No. 08-80736-Civ-Marra
+
+IN RE: JANE DOE,
+
+Petitioner.
+
+I
+
+| FILED by                                                            | <u>7/3</u> | D.C. |
+|---------------------------------------------------------------------|------------|------|
+| JUL 09 2008                                                         |            |      |
+| STEVEN M. LARIMORE<br>CLERK U.S. DIST. CT.<br>S.D. OF FLA. - W.P.B. |            |      |
+
+## DECLARATION OF A. VILLAFARA IN SUPPORT OF UNITED STATES' RESPONSE TO VICTIM'S EMERGENCY PETITION FOR ENFORCEMENT OF CRIME VICTIM RIGHTS ACT. 18 U.S.C. § 3771
+
+I. I, A. Villafafta, do hereby declare that I am a member in good standing of the Bar of the State of Florida. I graduated from the University of California at Berkeley School of Law (Boalt .1 in 1993. After serving as a judicial clerk to the Hon. David F. Levi in Sacramento, California, I was admitted to practice in California in 1995. I also am admitted to practice in all courts of the states of Minnesota and Florida, the Eighth, Eleventh, and Federal Circuit Courts of Appeals, and the U.S. District Courts for the Southern District of Florida, the District of Minnesota, and the Northern District of California. My bar admission status in California and Minnesota is currently inactive. I am currently employed as an Assistant United States Attorney in the Southern District of Florida and was so employed during all of the events described herein.
+
+2. I am the Assistant United States Attorney assigned to the investigation of Jeffrey Epstein. The case was investigated by the Federal Bureau of Investigation ("FBI"). The federal investigation was initiated in 2006 at the request of the Palm Beach Police Department ("PBPD") into allegations that Jeffrey Epstein and his personal assistants had used facilities of interstate commerce to induce young girls between the ages of thirteen and seventeen to engage in prostitution, amongst other offenses.
+
+3. Throughout the investigation, when a victim was identified, victim notification letters were provided to her both from your Affiant and from the FBI's Victim-Witness Specialist. Attached hereto are copies of the letters provided to three clients, T.M., C.W., and S.R.' Your Affiant's letter to C.W. was provided by the FBI. (Ex. I ). Your Affiant's letter to T.M. was hand-delivered by myself to T.M. at the time that she was interviewed (Ex. 2).2 Both C.W. and T.M. also received letters from the FBI's Victim-Witness Specialist, which were sent on January 10, 2008 (Exs. 3 & 4). S.R. was identified via the FBI's investigation in 2007, but she initially refused to speak with investigators. S.R.'s status as a victim of a federal offense was confirmed when she was interviewed by
+
+<sup>&#</sup>x27;Attorney filed his Motion on behalf of "Jane Doe," without identifying which of his clients is the purported victim. Accordingly, I will address facts related to C.W., T.M., and S.R. All three of those clients were victims of Jeffrey Epstein's while they were minors beginning when they were fifteen years old.
+
+<sup>&#</sup>x27;Please note that the dates on the U.S. Attorney&#x27;s Office letters to C.W. and T.M. are not the dates that the letters were actually delivered. Letters to all known victims were prepared early in the investigation and delivered as each victim was contacted.</p><p block-type='Text'>federal agents on May 28, 2008. The FBI&#x27;s Victim-Witness Specialist sent a letter to S.R. on May 30, 2008 (Ex. 5).</p><p block-type='Text'>4. Throughout the investigation, the FBI agents, the FBI&#x27;s Victim-Witness Specialist, and your A ffiant had contact with C.W. and S.R. Attorney other client, T.M., was represented by counsel and, accordingly, all contact with T.M. was made through that attorney. That attorney was James Eisenberg, and his fees were paid by Jeffrey Epstein, the target of the investigation.&#x27;</p><p block-type='Text'>5. In the summer of 2007, Mr. Epstein and the U.S. Attorney&#x27;s Office for the Southern District of Florida (&quot;the Office&quot;) entered into negotiations to resolve the investigation. At that time, Mr. Epstein had been charged by the State of Florida with solicitation of prostitution, in violation of Florida Statutes § 796.07. Mr. Epstein&#x27;s attorneys sought a global resolution of the matter. The United States subsequently agreed to defer federal prosecution in favor of prosecution by the State of Florida, so long as certain basic preconditions were met. One of the key objectives for the Government was to preserve a federal remedy for the young girls whom Epstein had sexually exploited. Thus, one condition of that agreement, notice of which was provided to the victims on July 9, 2008, is the following:</p><p block-type='Text'>&quot;Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein</p><p><sup>&#</sup>x27;The undersigned does not know when Mr. began representing T.M. or whether T.M. ever formally terminated Mr. Eisenberg&#x27;s representation.</p><p block-type='Text'>had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein&#x27;s attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.&quot;</p><p block-type='Text'>6. An agreement was reached in September 2007. The Agreement contained an express confidentiality provision.</p><p block-type='Text'>7. Although individual victims were not consulted regarding the agreement, several had expressed concerns regarding the exposure of their identities at trial and they desired a prompt resolution of the matter. At the time the agreement was signed in September 2007.. T.M. was openly hostile to the prosecution of Epstein. The FBI attempted to interview S.R. in October 2007, at which time she refused to provide any information regarding Jeffrey Epstein. None of Attorney clients had expressed a desire to be consulted prior to the resolution of the federal investigation.</p><p block-type='Text'>8. As explained above, one of the terms of the agreement deferring prosecution to the State of Florida was securing a federal remedy for the victims. In October 2007, shortly after the agreement was signed, four victims were contacted and these provisions were discussed. One of those victims was C.W. who at the time was not represented, and she was given notice of the agreement. Notice was also provided of an expected change of plea in October 2007. When Epstein&#x27;s attorneys learned that some of the victims had been</p><p block-type='Text'>notified, they complained that the victims were receiving an incentive to overstate their involvement with Mr. Epstein in order to increase their damages claims. While your Affiant knew that the victims&#x27; statements had been taken and corroborated with independent evidence well before they were informed of the potential for damages, the agents and I concluded that informing additional victims could compromise the witnesses&#x27; credibility at trial if Epstein reneged on the agreement.</p><p block-type='Text'>9. After C.W. had been notified of the terms of the agreement, but before Epstein performed his obligations, C.W. contacted the FBI because Epstein&#x27;s counsel was attempting to take her deposition and private investigators were harassing her. Your Affiant secured pro bono counsel to represent C.W. and several other identified victims. Pro bono counsel was able to assist C.W. in avoiding the improper deposition. hat pro bono counsel did not express to your Affiant that C.W. was dissatisfied with the resolution of the matter.</p><p block-type='Text'>10. In mid-June 2008, Attorney contacted your Affiant to inform me that he represented C.W. and S.R. and asked to meet to provide me with information regarding Epstein. 1 invited Attorney to send to me any information that he wanted me to consider. Nothing was provided. I also advised Attorney that he should consider contacting the State Attorney&#x27;s Office, if he so wished. I understand that no contact with that office was made. Attorney had alluded to T.M., so I advised him that, to my knowledge, T.M. was still represented by Attorney James Eisenberg.</p><p block-type='Text'>11. On Friday, June 27, 2008, at approximate 4:15 p.m., your Affiant received a copy of the proposed state plea agreement and learned that the plea was scheduled for 8:30 a.m., Monday, June 30, 2008. Your Affiant and the Palm Beach Police Department attempted to provide notification to victims in the short time that Epstein&#x27;s counsel had given us. Although all known victims were not notified, your Affiant specifically called attorney to provide notice to his clients regarding the hearing. Your Affiant believes that it was during this conversation that Attorney notified me that he represented T.M., and I assumed that he would pass on the notice to her, as well. Attorney informed your Affiant that he could not attend but that someone would be present at the hearing. Your Affiant attended the hearing, but none of Attorney clients was present.</p><p block-type='Text'>12. On today&#x27;s date, your Affiant provided the attached victim notifications to C.W. and S.R. via their attorney, (Exs. 6 &amp; 7). A notification was not provided to T.M. because the U.S. Attorney&#x27;s modification limited Epstein&#x27;s liability to victims whom the United States was prepared to name in an indictment. In light of T.M.&#x27;s prior statements to law enforcement, your Affiant could not in good faith include T.M. as a victim in an indictment and, accordingly, could not include her in the list provided to Epstein&#x27;s counsel.</p><p block-type='Text'>13. Furthermore, with respect to the Certification ofEmetgency, Attorney did not ever contact me prior to the filing of that Certification to demand the relief that he requests in his Emergency Petition. On the afternoon of July 7, 2008, after your Affiant had</p><p block-type='Text'>already received the Certification of Emergency and Emergency Petition, I received a letter from Attorney that had been sent, via Certified Mail, on July 3, 2008. While that letter urges the Attorney General and the United States Attorney to consider &quot;vigorous enforcement&quot; of federal laws with respect to Jeffrey Epstein, it contains no demand for the relief requested in the Emergency Petition.</p><p block-type='Text'>14. 1 declare under penalty of perjury, pursuant to 28 U.S.C. § 1746 that the foregoing is true and correct to the best of my knowledge and belief.</p><p block-type='Text'>Executed this day of July, 2008.</p><p block-type='Text'>A. ane i afafta, sq.</p><p><img src='\_page\_7\_Picture\_1.jpeg'></p><p><img src='\_page\_7\_Picture\_4.jpeg'></p><p block-type='Text'>United States Attorney Southern District of Florida</p><p block-type='Text'>300 South Australian Ave . Suite 400 West Palm Beach. Ft. 33401 (361)820-VI! Facsimile. (361) 820-8777</p><p block-type='Text'>June 7, 2007</p><h1>DELIVERY BY HAND</h1><p block-type='Text'>Miss odlellwa</p><p block-type='Text'>Re: Crime Victims&#x27; and Witnesses&#x27; Rights</p><p block-type='Text'>Dear Miss Warn</p><p block-type='Text'>Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense, you have a number of rights. Those rights arc:</p><p block-type='ListGroup'><ul><li block-type='ListItem'>(I) The right to be reasonably protected from the accused.</li><li block-type='ListItem'>(2) The right to reasonable, accurate, and timely notice of any public court proceeding involving the crime or of any release or escape of the accused.</li><li block-type='ListItem'>(3) The right not to be excluded from any public court proceeding, unless the court determines that your testimony may be materially altered if you are present for other portions of a proceeding.</li><li block-type='ListItem'>(4) The right to be reasonably heard at any public proceeding in the district court involving release, plea, or sentencing.</li><li block-type='ListItem'>(5) The reasonable right to confer with the attorney for the United States in the case.</li><li block-type='ListItem'>(6) The right to full and timely restitution as provided in law.</li><li block-type='ListItem'>(7) The right to proceedings free from unreasonable delay.</li><li block-type='ListItem'>(8) The right to be treated with fairness and with respect for the victim&#x27;s dignity and privacy.</li></ul></p><p block-type='Text'>Members of tie U.S. Department of Justice and other federal investigative agencies, including the Federal Bureau of Investigation, must use their best efforts to make sure that these rights are protected. If you have any concerns in this regard, please feel free to contact me at 561 209-1047, or Special Agent Nesbitt Kuyrkendall from•the Federal Bureau of Investigation at 561 822-5946. You also- can contact the Justice Department&#x27;s Office for Victims of Crime in Washington, D.C. at 202.307-5983. That Office has a website at www.ovc.gov.</p><p block-type='Text'>.&quot; You can seek the advice of an attorney with respect to the nghtg listed above and, if you believe that the rights set forth above are being violated, you have the right to petition the Court for relief</p><p block-type='Text'>MISS a \lab JuriE 7.2007 PAGE 2</p><p block-type='Text'>In addition to these rights, you are entitled to counseling and medical services, and protection from intimidation and harassment. If the Court determines that you are a victim, you also may be entitled to restitution from the perpetrator. A list of counseling and medical service providers can be provided to you, if you so desire. If you or your family is subjected to any intimidation or harassment, please contact Special Agent Kuyrkendall or myself immediately. It is possible that someone working on behalf of the targets of the investigation may contact you. Such contact does not violaisabe law:- However, if you are contacted, you have the choice of speaking to that person or refusing tondo do: If you refuse and feel that you are being threatened or harassed, then please &#x27;contact Special Agent Kuyrkendall or myself.</p><p block-type='Text'>You also are entitled to notification of upcoming case events. At this time, your case is under investigation! If anyone is charged in connection with the investigation, you will be notified.</p><p block-type='Text'>Sincerely,</p><p block-type='Text'>R. Alexander Acosta United States Attorney</p><p block-type='Text'>By</p><p block-type='Text'>cc: Special Agent Nesbitt Kuyrkendall, F.B.I.</p><p block-type='Text'>A. Villafafia Assistant United States Attorney</p><p block-type='Text'>f f</p><p><img src='\_page\_9\_Picture\_1.jpeg'></p><p block-type='Text'>United States Attorney Southern District of Florida</p><p block-type='Text'>SOO South Australian Aye., Suite 400 West Palm Beach. Ft. 33401 MD 820-8711 Facsimile: (\$61) 820.8777</p><p block-type='Text'>August II, 2006</p><h4>DELIVF,RY BY HAND</h4><p block-type='Text'>Miss TallliPla</p><p block-type='Text'>• Re: Crime Victims&#x27; and Witnesses&#x27; Rights</p><p block-type='Text'>Dear Miss Me</p><p><img src='\_page\_9\_Picture\_4.jpeg'></p><p block-type='Text'>Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense. you have a number of rights. Those rights are:</p><p block-type='ListGroup'><ul><li block-type='ListItem'>(4)</li><li block-type='ListItem'>(5)</li><li block-type='ListItem'>(6)</li><li block-type='ListItem'>(7)</li><li block-type='ListItem'>(8) The right to be reasonably protected from the accused. The right to reasonable, accurate, and timely notice of any public court proceeding involving the crime or of any release or escape of the accused. The right not to be excluded from any public court proceeding, unless the court determ&#x27;nes that your testimony may be materially altered i f you are present for other portions of a proceeding. The right to be reasonably heard at any public proceeding in the district court involving release, plea, or sentencing. The reasonable right to confer with the attorney for the United States in the case. The right to full and timely restitution as provided in law. The right to proceedings free from unreasonable delay. The right to be treated with fairness and with respect for the victim&#x27;s dignity and privacy. f</li></ul></p><p block-type='Text'></p><p block-type='Text'>Members of the U.S. Departrfient of Justice and other federal investigative agencies, including the Federal Bureau of Investigation, must use their best efforts to make sure that these rights are protected. If you have any concerns in this regard, please feel free to contact me at 561 209-1047, or Special Agent Nesbitt Kuyrkendall from the Federal Bureau of Investigation at 561 822-5946. You also can contact the Justice Department&#x27;s Office for Victims of Crime in Washington, D.C. at 202-307-5983. That Office has a websitc at www.ovc.gov.</p><p block-type='Text'>You can seek the advice of an attorney with respect to the rights, listed above and, if you believe that the rights set forth above are being violated, you have the right to petition the Court for relief.</p><p block-type='Text'>Miss &#x27;I&#x27; At KiUS1 II, 2006 PAGE 2</p><p block-type='Text'>mos</p><p block-type='Text'>In addition to these rights, you are entitled to counseling and medical services, and lit from intimidation and harassment. If the Court determines that you are a victim, you ..1. . entitled to restitution from the perpetrator. A list of counseling and medical service pio . be provided to you, if you so desire. If you or your family is subjected to any into • harassment, please contact Special Agent Kuyrkendall or myself immediately. It is p. • someone working on behalf of the targets of the investigation may contact you. Such coy. not violate the law. However, if you are contacted, you have the choice of speaking to ,ii or refusing to do so. If you refuse and feel that you are being threatened or harassed, d,1 . Contact Special Agent Kuyrkendall or myself.</p><p block-type='Text'>You also are entitled to notification of upcoming case events. At this time, your L. .• investigation. If anyone is charged in connection with the investigation, you will be &#x27;hi,</p><p block-type='Text'>By:</p><p block-type='Text'>cc: Special Agent Nesbitt Kuyrkendall, F.B.I.</p><p block-type='Text'>Sincerely,</p><p block-type='Text'>R. Alexander Acosta United States Attorney</p><p block-type='Text'>A. Villafarla Assistant United States Attorney</p><p block-type='Text'>tc</p><p><img src='\_page\_11\_Picture\_1.jpeg'></p><p block-type='Text'>U.S. Department of Justice Federal Bureau of Investigation FBI - West Palm Beach Suite 500 505 South Fleeter Drive West Palm Beach, FL 33401 Phone: (581) 633-7517 Fax: (561) 833-7970</p><p block-type='Text'>January 10, 2008</p><p block-type='Text'>MS&#x27;</p><p block-type='Text'>Re: Case Number:</p><p block-type='Text'>Dearr</p><p block-type='Text'>This case is currently under Investigation. This can be a lengthy process and we request your continued patience while we conduct a thorough investigation.</p><p block-type='Text'>As a alma victim, you have the following rights under 18 United States Code § 3771: (1) The right to be reasonably protected from the accused: (2) The right to reasonable, accurate, and timely notice of any public court proceeding, or any parole proceeding, involving the crime or of any release or escape or the accused; (3) The right not to be excluded from any such public court proceeding: unless the court. after receiving clew and convincing evidence, determines that testimony by the victim would be materially altered If the victim heard other testimony et that proceeding; (4) The right to be reasonably heard at any public proceeding in the district court Involving release, pea, sentencing, or any parole proceeding: (5) The reasonable right to confer with the attorney for the Government In the case; (6) The right to full and timely restftuticn as provided In law; (7) The right to proceedings free from unreasonable delay; (8) The right to be treated with fairness and with respect for the victim&#x27;s dignity and privacy.</p><p block-type='Text'>We wRI make our best efforts to ensure you are accorded the rights described. Most of these rights pertain to events occurring after the arrest or indictment of an Individual for the crime. and It will become the responsibility of the prosecuting United States Attorney&#x27;s Office to ensure you are accorded those rights. You may also seek the advice of a private attorney with respect to these rights.</p><p block-type='Text'>The Victim Notification System (VNS) is designed to provide you with direct information regarding the case as 4 proceeds through the criminal justice system. You may obtain current information about this matter on the Internet at WWW.Notlty.USOO.I.GOV or from the VNS Call Center at 1-865-D0J-4YOU (1-866-385- 4968) (TDD/TTY: 1.866-228.4619) (International: 1.502-213-2767). In addition, you may use the Call Center or Internet to uodate your contact information and/or change your decision about participation ki the notification program. If you update your information to include a current email address, VNS will send information to that address. You will need the following Victim Identification Number (VIM) &#x27;1941737&#x27; and Personal Identification Number (PIN) &#x27;5502&#x27; anytime you contact the Call Center and the first time you log on to VNS on the Internet. In addition, the first time you access the VNS Internet site, you will be prompted to enter your last name (or business name) as currently contained in VNS. The name you should enter Is a</p><p><img src='\_page\_11\_Picture\_11.jpeg'></p><p block-type='Text'>%sr If you have additional questions which Inv°Ne this matter, please contact the office listed above. When you call, please provide the file number located at the top of this letter. Please remember, your participabon in the notification part of this program is voluntary. In order to continue to receive notifications, it is your responsibility to keep your contact information current</p><p block-type='Text'>Sincerely.</p><p block-type='Text'></p><p block-type='Text'>Tveller VIcOm Specialist</p><p><img src='\_page\_13\_Picture\_1.jpeg'></p><p block-type='Text'>U.S. Department of Justice Federal Bureau of Investigation FBI - West Palm Beach Suite 500 505 South Fleeter Drive West Palm Beach, FL 33401 Phone: (581) 833.7517 Fax: (581) 533-7970</p><p block-type='Text'>January 10.2008</p><p block-type='Text'>James Eisenberg One Clearlake Center Ste 704 Australian South West Palm Beach. FL 33401</p><p block-type='Text'>Re.</p><p block-type='Text'>Dear James ELsenbom:</p><p block-type='Text'>You have requested to receive notifications for lake</p><p block-type='Text'>This case is currently under Investigation. This can be a lengthy process and we request your continued patience while we conduct a thorough investigation.</p><p block-type='Text'>Asa crime victim, you have the following tights under 18 United States Code § 3771: (1) The right to be reasonably protected from the accused: (2) The right to reasonable, accurate, and timely notice of any public court proceeding, or any parole proceeding, Involving the time or of any release or escape of the accused; (3) The right not to be excluded from any such public court proceeding. unless the court, after receiving clear and convincing evidence, determines that testimony by the victim would be materially altered if the victim heard other testimony at that proceeding; (4) The right to be reasonably heard at any public proceeding in the district court involving release, plea, sentencing, or any parole proceeding; (5) The reasonable right to confer with the attorney for the Government in the case; (6) The right to lull and timely restitution as provided in law; (7) The right to proceedings free from unreasonable delay: (8) The right to be treated with fairness and with respect for the victim&#x27;s dignity and privacy.</p><p block-type='Text'>We will make our best efforts to ensure you are accorded the rights described. Most of these nghts pertain to events occurring after the arrest or Indictment of an individual for the crime, and it will become the responsibiiity of the prosecuting United States Attorney&#x27;s Office to ensure you are accorded those rights. You may also seek the advice of a private attorney with respect to these rights.</p><p block-type='Text'>The Victim Notification System (VNS) is designed to provide you with direct Information regarding the case as it proceeds though the criminal justice system. You may obtain current information about this matter on the Internet at WWW.Nottfy.USDOJ.GOV or from the VNS Call Center at 1.886-DOJ-4YOU (1.866-365- 4968) (TDD/ITY, 1.866.228-4619) (International: 1.502.213-2767). In addition, you may use the Cal Center or Internet to update your contact infonnetton and/or change your decision about participation in the notification program. If you update your Information to include a current email address. VNS will send information to that address. You wil need the following Victim Identification Number (VIN) &#x27;1941741&#x27; and Personal Identification Number (PIN) &#x27;7760&#x27; anytime you contact the Call Center and the first time you log on to VNS on the Internet. In addition, the first time you access the VNS Internet site, you will be prompted to enter your lest name (or business name) as currently Contained in SINS. The name you should enter is Eisenberg.</p><p><img src='\_page\_13\_Picture\_12.jpeg'></p><p block-type='Text'>If you have additional questions which Involve this matter, please contact the office listed above. When you cat please pro&#x27;Me the file number located at the top of this letter. Please remember, your participation in the notification part of this program is voluntary. In order to continue to receive notifications, it is your responsibility to keep your contact information current.</p><p block-type='Text'>Sincerely.</p><p block-type='Text'></p><p block-type='Text'>Twiler Victim &#x27;ietist</p><p><img src='\_page\_15\_Picture\_17.jpeg'></p><p><b>U.S. Department of Justice</b><br/>Federal Bureau of Investigation<br/>FBI - West Palm Beach<br/>Suite 500<br/>505 South Flagler Drive<br/>West Palm Beach, FL 33401<br/>Phone: (561) 833-7517<br/>Fax: (561) 833-7970</p><p><img src='\_page\_15\_Picture\_19.jpeg'></p><p>May 30, 2008</p><p>SECRET [REDACTED]<br/>[REDACTED]</p><p>Re: [REDACTED]</p><p>Dear SECRET [REDACTED]</p><p>Your name was referred to the FBI's Victim Assistance Program as being a possible victim of a federal crime. We appreciate your assistance and cooperation while we are investigating this case. We would like to make you aware of the victim services that may be available to you and to answer any questions you may have regarding the criminal justice process throughout the investigation. Our program is part of the FBI's effort to ensure the victims are treated with respect and are provided information about their rights under federal law. These rights include notification of the status of the case. The enclosed brochures provide information about the FBI's Victim Assistance Program, resources and instructions for accessing the Victim Notification System (VNS). VNS is designed to provide you with information regarding the status of your case.</p><p>This case is currently under investigation. This can be a lengthy process and we request your continued patience while we conduct a thorough investigation.</p><p>As a crime victim, you have the following rights under 18 United States Code § 3771: (1) The right to be reasonably protected from the accused; (2) The right to reasonable, accurate, and timely notice of any public court proceeding, or any parole proceeding, involving the crime or of any release or escape of the accused; (3) The right not to be excluded from any such public court proceeding, unless the court, after receiving clear and convincing evidence, determines that testimony by the victim would be materially altered if the victim heard other testimony at that proceeding; (4) The right to be reasonably heard at any public proceeding in the district court involving release, plea, sentencing, or any parole proceeding; (5) The reasonable right to confer with the attorney for the Government in the case; (6) The right to full and timely restitution as provided in law; (7) The right to proceedings free from unreasonable delay; (8) The right to be treated with fairness and with respect for the victim's dignity and privacy.</p><p>We will make our best efforts to ensure you are accorded the rights described. Most of these rights pertain to events occurring after the arrest or indictment of an individual for the crime, and it will become the responsibility of the prosecuting United States Attorney's Office to ensure you are accorded those rights. You may also seek the advice of a private attorney with respect to these rights.</p><p>The Victim Notification System (VNS) is designed to provide you with direct information regarding the case as it proceeds through the criminal justice system. You may obtain current information about this matter on the Internet at WWW.Notify.USDOJ.GOV or from the VNS Call Center at 1-866-DOJ-4YOU (1-866-365-4968) (TDD/TTY: 1-866-228-4619) (International: 1-502-213-2767). In addition, you may use the Call Center or Internet to update your contact information and/or change your decision about participation in the notification program. If you update your information to include a current email address, VNS will send information to that address. You will need the following Victim Identification Number (VIN) '2074381' and Personal Identification Number (PIN) '1816' anytime you contact the Call Center and the first time you log on to VNS on the Internet. In addition, the first time you access the VNS Internet site, you will be prompted to enter your last name (or business name) as currently contained in VNS. The name you should enter is [REDACTED]</p><p>[REDACTED]</p><p>[REDACTED]</p><p>If you have additional questions which involve this matter, please contact the office listed above. When you call, please provide the file number located at the top of this letter. Please remember, your participation in the notification part of this program is voluntary. In order to continue to receive notifications, it is your responsibility to keep your contact information current.</p><p>Sincerely,</p><img/><img/><p><img src='\_page\_17\_Picture\_1.jpeg'></p><p block-type='Text'>U.S. Department of Justice</p><p block-type='Text'>United States Attorney Southern District of Florida</p><table border="1">
+<tr>
+<td colspan="2">ADMIRAL</td>
+</tr>
+<tr>
+<td colspan="2"><b>GOVERNMENT<br/>EXHIBIT</b></td>
+</tr>
+<tr>
+<td colspan="2">
+ CASE<br/>
+<u>NO. 08-80736-CV-MARRA</u>
+</td>
+</tr>
+<tr>
+<td colspan="2">
+ EXHIBIT<br/>
+<u>NO. 6</u>
+</td>
+</tr>
+</table><p block-type='Text'>SOO South Australian Ave.. Suite 400 West Palm Beach. FL 3340! (560 8204711 Facsimile: (561)820-8777</p><p block-type='Text'>July 9, 2008</p><h2>VIA F SIMILE</h2><p block-type='Text'>Brad , Esq. The Law Offices of Brad &amp; Associates, LLC 2028 Street, Suite 202 Ifollywood, Florida 33020.</p><blockquote><p block-type='Text'>Re: Jeffrey Epstein/C - %S NOTIFICATION OF IDENTIFIED VICTIM</p></blockquote><p block-type='Text'>Dear Mr. In</p><p block-type='Text'>By virtue of this letter, the United States Attorney&#x27;s Office for the Southern District of Florida asks that you provide the following notice to your client, Cala vis.</p><p block-type='Text'>On June 30, 2008, Jeffrey Epstein (hereinafter referred to as &quot;Epstein) entered a plea of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve months&#x27; imprisonment to be followed by an additional six months&#x27; imprisonment, followed by twelve months of Community Control 1, with conditions of community confinement imposed by the Court.</p><p block-type='Text'>In light of the entry of the guilty plea and sentence, the United States has agreed to defer federal prosecution in favor of this state plea and sentence, subject to certain conditions.</p><p block-type='Text'>One such condition to which Epstein has agreed is the following:</p><p block-type='Text'>&quot;Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein</p><p block-type='Text'>BRAD ESQ.</p><p block-type='Text'>NOTIFICATION OF IDENTIFIED VICTIM a Van</p><p block-type='Text'>Jur 9, 2008</p><p block-type='Text'>PAGE 2 OF 2</p><p block-type='Text'>had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein&#x27;s attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.&quot;</p><p block-type='Text'>Through this letter, th is Office hereby provides Notice that your client, Cline. is an individual whom the United States was prepared to name as a victim of an enumerated offense.</p><p block-type='Text'>• d.</p><p block-type='Text'>Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.</p><p block-type='Text'>Please understand that neither the U.S. Attorney&#x27;s Office nor the Federal Bureau of Investigation can take part in or otherwise assist in civil litigation; however, it<sup>l</sup> you do file <sup>a</sup> claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an enumerated offense, please provide notice of that denial to the undersigned.</p><p block-type='Text'>Please thank your client for all of her assistance during the course of this examination and express the heartfelt regards of myself and Special Agents Kuyrkendall and Richards for the health and well-being of Ms. <sup>a</sup></p><blockquote><p block-type='Text'>R. ALEXANDER ACOSTA UNITED STATES ATTORNEY</p></blockquote><p block-type='Text'>By:</p><p block-type='Text'>A. V1LLAFAFIA ASSISTANT U.S. ATTORNEY</p><p block-type='Text'>cc: Jack Goldberger, Esq.</p><p><img src='\_page\_19\_Picture\_1.jpeg'></p><p block-type='Text'>U.S. Department of Justice</p><p block-type='Text'>United States Attorney Southern District of Florida</p><table border="1">
+<tr>
+<td colspan="2">ADMIRA-C</td>
+</tr>
+<tr>
+<td colspan="2"><b>GOVERNMENT<br/>EXHIBIT</b></td>
+</tr>
+<tr>
+<td colspan="2">
+ CASE<br/>
+ NO. 08-80736-CV-MARRA
+ </td>
+</tr>
+<tr>
+<td colspan="2">
+ EXHIBIT<br/>
+ NO. 7
+ </td>
+</tr>
+</table><p block-type='Text'>500 South Australian Ave.. Suite 400 West Palm Beach. FL 33401 (561)820-8711 Facsimile: (56!) 820-8777</p><p block-type='Text'>July 9, 2008</p><h1>VI FACSIMILE</h1><p block-type='Text'>Brad , Esq. The Law Offices of Brad &amp; Associates, LLC 2028e Street, Suite 202 Hollywood, Florida 33020.</p><blockquote><p block-type='Text'>Re: Jeffrey Epstein/e it NOTIFICATION OF IDENTIFIED VICTIM</p></blockquote><p block-type='Text'>Dear Mr. e:</p><p block-type='Text'>By virtue of this letter, the United States Attorney&#x27;s Office for the Southern District of Florida asks that you provide the following notice to your client, a le</p><p block-type='Text'>On June 30, 2008, Jeffrey Epstein (hereinafter referred to as &quot;Epstein) entered a plea of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve months&#x27; imprisonment to be followed by an additional six months&#x27; imprisonment, followed by twelve months of Community Control I, with conditions of community confinement imposed by the Court.</p><p block-type='Text'>In light of the entry of the guilty plea and sentence, the United States has agreed to defer federal prosecution in favor of this state plea and sentence, subject to certain conditions.</p><p block-type='Text'>One such condition to which Epstein has agreed is the following:</p><p block-type='Text'>&quot;Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein</p><p block-type='Text'>BRAD .ESQ•</p><p block-type='Text'>NOTIFICATION OF IDENTIFIED VICTIM Sane</p><p block-type='Text'>JULY 9, 2008</p><p block-type='Text'>PAGE 2 OE 2</p><p block-type='Text'>had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein&#x27;s attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.&quot;</p><p block-type='Text'>Through this letter, this Office hereby provides Notice that your client, S P is an individual whom the United States was prepared to name as a victim of an enumerated offense. •</p><p block-type='Text'>Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.</p><p block-type='Text'>Please understand that neither the U.S. Attorney&#x27;s Office nor the Federal Bureau of Investigation can take part in or otherwise assist in civil litigation; however, if you do file a claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an enumerated offense, please provide notice of that denial to the undersigned.</p><p block-type='Text'>Please thank your client for all of her assistance during the course of this examination and express the heartfelt regards of myself and Special Agents Kuyrkendall and Richards for the health and well-being of Ms. lap</p><blockquote><p block-type='Text'>R. ALEXANDER ACOSTA UNITED STATES ATTORNEY</p></blockquote><p block-type='Text'>By:</p><p block-type='Text'>cc: Jack Goldberger, Esq.</p><p block-type='Text'>A. VILLAFARA ASSISTANT U.S. ATTORNEY</p>
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marker2/court-doe-v-us/EFTA02752755/EFTA02752755.md

@@ -0,0 +1,485 @@
+THE UNITED STATES DISTRICT COWAW SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO. 08-80736-CIV-MARRA
+
+IN RE: JANE DOE, Plaintiff, vs.
+
+UNITED STATES OF AMERICA, Defendant.
+
+FILED by D,C.
+
+JUL 17 axw STEVEN M. LARIMORE CLERK LI S DIST CT S. D. of FLA. - MIAMI
+
+ORIGINAL
+
+Federal Courthouse West Palm Beach, Florida July 11, 2008 10:15 a.m.
+
+The above entitled matter came on for Emergency Petitioner for Enforcement of Crime Victim Rights before the Honorable Kenneth A. Marra, pursuant to Notice, taken before Victoria Aiello, Court Reporter, pages 1-32.
+
+For the Plaintiff: , Esquire
+
+For the Defendant: Dexter Lee, AUSA Maria Villafana, AUSA RECD by CI
+
+STEVEN M. LARIMCRE CLERK U. S. CfST. CT S. D. of FLA. - mum
+
+JUL I
+
+J P
+
+41; :or
+
+(Call to Order of the Court).
+
+2 THE COURT: Good morning. Please be seated.
+
+3 This is the case of In Re: Jane Doe, Case 4 Number 08-80736-Civ-Marra. May I have counsel state 5 their appearances, please?
+
+6 MR. LEE: Good morning, Your Honor. May it 7 please the Court, for the United States of America, 0 we have Maria Villafana, Assistant United States 9 Attorney and Dexter Lee, Assistant United States lo Attorney. And we have seated in the front row FBI 11 Special Agent Becker Kendall and Jason Richards. 12 Thank you, Your Honor.
+
+13 MR. : Good morning, Your Honor. Brad 14 on behalf of the petitioners. Petitioners 15 are also in the courtroom today. This petition is 16 styled on her behalf.
+
+17 THE COURT: Good morning. All right. We're 18 here on the petitioner's motion to enforce her 19 rights as a victim under 18 USC 3771. I have 20 received the petition, the government's response and 21 the victim's reply, which was filed, I guess, this 22 morning. So, You want to proceed, counsel?.
+
+23 MR. : Yes, Your Honor. You prefer me 24 at the podium?
+
+25 THE COURT: It is easier for us to hear you.
+
+MU r
+
+1 MR. : Your Honor, as a factual background, Mr. Epstein is a billionaire that sexually abused and molested dozens and dozens of girls between the ages of 13 and 17 years old. And 5 through cooperating victims, that evidence can be 6 proven. Because of his deviant appetite for young girls, combined with his extraordinary wealth and power, he may just be the most dangerous sexual predator in U.S. history. This petitioner is one of 10 the victims and she is in attendance today. Another one of Mr. Epstein's victims is also in attendance today. She would be able to provide evidence that she provided-- that Mr. Epstein paid her to provide him over 50 girls for the purposes of him to sexually abuse. Therefore, the undercurrents of the 16 petition are clear. The plea bargain that was worked out for Mr. Epstein in light of the offenses that he committed is clearly unfair to the point that if anybody looks at the information, it is 20 unconscionable.
+
+THE COURT: Well, I mean, is that for me? That's not my role. That's the prosecutor's role to apply, would it not? I can't force them to bring criminal charges. What do I have to do with that.
+
+MR. : Okay.
+
+41 1
+
+4 fr
+
+1 THE COURT: That may be your opinion, that 2 may be your client's opinion, but I presume that the 3 government is aware that that's your client's 4 opinion. How does that change anything?
+
+5 MR. That's my problem. I'm not 6 sure that the government is aware that is 7 petitioner's opinion and that's why we're here 8 today, just to enforce the victim's rights under 18 9 USC 3771, Crime Victims Rights Act, and all we are 10 asking is to order that the plea agreement that has 11 been negotiated in this case--
+
+12 THE COURT: How do you know there is a plea 13 agreement? The plea agreement is with the State of 14 Florida, wasn't it?
+
+15 MR. : There was a state charge with 16 one victim that I'm aware of. And the plea 17 agreement as to that one victim was 18 months in the 18 county jail. But along with that, the Palm Beach 19 County Sheriff investigating this case was getting 20 no action out of the local authorities and sent this 21 to the FBI.
+
+22 THE COURT: It was actually the Palm Beach-- 23 Town of Palm Beach Police, not the Sheriff's Office.
+
+24 MR. : I'm sorry, Judge. And that's 25 why the FBI got involved because Michael Feeter
+
+VI l
+
+1 2 3 wrote a scathing letter to the State Attorney about Mr. Epstein receiving preferencial treatment by local authorities.
+
+4 5 6 7 8 9 10 11 12 13 Before the FBI took the case, they went behind the victim's back, and this is our motion, without the victim's input and allowing her the right to meaningfully confer with the government, which is a right that she can assert at this time. They worked out a plea deal where if Mr. Epstein would plead to this other charge regarding another victim in the state court case, they would agree to not prosecute him for all of the federal charges of what they were aware of in federal court..
+
+14 15 THE COURT: So that's already apparently taken place, correct?
+
+16 17 18 19 MR. : I don't know if it has taken place. I'm not sure exactly what stage it is in. know it is supposed to be attached at some point in time to a state court plea.
+
+20 21 THE COURT: Hasn't he already plead guilty, though?
+
+22 23 24 25 MR. : If he did plead guilty, it is my understanding and belief that the agreement with the federal government and with the U.S. Attorney's Office wasn't signed on that day. So it is still my 1 belief, I could be wrong, but that that agreement 2 hasn't been completed as of this time.
+
+3 THE COURT: So let's assume it hasn't been 4 completed.
+
+5 MR. : Okay. Then petitioner would 6 like the right to confer with--
+
+7 THE COURT: You can go in the conference 8 room. We've got the FBI agents, you've got the assigned prosecuting attorney. You have got a conference room. You've got your client. Go and talk. Confer. And then it is up government to decide what to do, correct?
+
+13 MR. : In a way, Your Honor, that's 14 very similar to what happened in In Re: and PB 15 case where there is a plea agreement negotiated and 16 then the victim gets the right to confer.
+
+17 THE COURT: It'S already negotiated. What 18 am I supposed to do?
+
+19 MR. : Order that the agreement that 20 was negotiated is invalid and it is illegal as it 21 did not pertain to the rights of the victim.
+
+THE COURT: I can order you into the conference room. Then the government can do what it chooses. It can agree to prosecute or it can agree to going forward with the agreement it had already
+
+reached and after consulting your client and in 2 taking into consideration your client's views, 3 decide to go forward anyway. I can't make them 4 prosecute him. I can't-- All I can do is, at best, say confer with the victim, consider the victim's 6 input before you make a decision or reconsider the 7 decision you already made in view of the victim's 8 input, if it is possible for you to do that. So if 9 I invalidate the agreement, what's the best you can 10 get? The right to confer?
+
+11 MR. : Exactly. That is all we can.
+
+12 THE COURT: So why can't you go into the 13 conference room now, take as much time as you feel 14 you need and confer?
+
+15 MR. : Judge, at this time I'd like to 16 move ore tenus to add the victim that's in the 17 courtroom to this conference with the U.S. 18 Attorney's Office.
+
+19 THE COURT: So is that Jane Doe 2 for 20 purposes of this?
+
+23. MR. : Exactly, Your Honor.
+
+22 THE COURT: All right. Let me hear from the 23 government then.
+
+24 MR. LEE:. Good morning, Your Honor. May it 25 please the Court.
+
+9 lie
+
+1 2 3 4 5 6 7 8 9 10 11 12 13 Let me update the Court on the status of various matters. The agreement to defer prosecution to the State of Florida was signed and completed by December of 2007. Mr. Epstein's attorneys saught a higher review within the Department of Justice and it took a number of months for that to come to fruition. When it came to fruition, he ended up pleading guilty on June 30, 2008 to two charges in state court, and he was sentenced to a term of incarceration of 18 months, with another 12 months of community control after the completion of his sentence, and he is currently incarcerated as we speak.
+
+14 15 16 17 18 19 20 21 22 23 24 we have two arguments, Your Honor. First, insofar as the right that they claim under 3771(a)(5), their right to confer in the case, we respectfully submit that there was no case in federal court and, indeed, none was contemplated if the plea agreement was to be successfully completed, since it contemplated the State of Florida sentence on the criminal charges. So as long as certain conditions were met and certain federal interests were vindicated, the federal government was satisfied that this was an appropriate disposition.
+
+25 Insofar as the best effort, Your Honor, we
+
+1 have cited the Attorney General's guidelines. The 2 guidelines do say that you should normally advise 3 victims of plea negotiations and the terms of the 4 plea, but they recognize that there are times when 5 they may not be appropriate or could cause some harm 6 or prejudice, and they set out six factors which are 7 to be considered, non-exhaustive factors.
+
+8 We have advised, in the declaration of AUSA 9 Villafana that when the subject of having Mr. 10 Epstein concede that he would be convicted of an 11 enumerated offense for purposes of a cause of action 12 under 18 USC 2255, there was a rather strenuous 13 objection from Mr. Epstein's counsel that the 14 federal government was inducing some effort to 15 either fabricate claims, enhance claims or embellish 16 claims and if this agreement ultimately could not be 17 consumated, then we'd have a federal prosecution on 18 our hands, and we did not want to be in a positin of 19 creating additional impeachment material.
+
+I can't say that the stand by Mr. 21 that the arguments of inducement in a subsequent civil action can be made by any criminal victim, 23 that is true. It is another thing for that inducement to have come before the prosecution arguing about the credibility and veracity of the
+
+I:),
+
+1 2 3 4 individual. That was a considerably strong point, in essence, in not discussing those terms with the victims as might ordinarily be done if those considerations did not exist.
+
+5 6 So, first, Your Honor, we believe that 3771(a)(5) does not apply.
+
+7 8 9 10 11 THE COURT: Well, what about the language in the statute that suggests that a victim can bring a claim or seek enforcement of his or her rights under the statute before a case is filed? What does that refer to?
+
+12 13 venue provision essentially telling an individual if 14 15 16 17 18 19 20 21 MR. LEE: Your Honor, we believe that's a there is no exigent case, there is no case of United States versus So And So, then you seek to enforce your rights, then you can go in and do so in the did court where the offense occurred. This is not saying, necessarily, that rights exist, but if you believe they exist, here is the place where you're going to have to lodge it, and the Court will have to decide.
+
+22 23 24 25 Now, there are certain of the eight rights accorded in 3771(a) that could come up before any charge is filed. For instance, let's say somebody believes that the perpetrator of the crime is going
+
+to try to harm them or threatened them or 2 intimidated them into not testifying or cooperating 3 with the government and, of course, no indictment 4 has been returned. If an individual went to the 5 government and believed that the individual had not 6 acted appropriately, they can go to the district 7 court and say I need to have my rights under 8 3771(a)(1) enforced because those people are 9 threatening me, and the government hasn't done 10 enough. That would be a situation.
+
+11 But we're talking really here about (a)(5), 12 which is the right to consult in the case and we 13 respectfully submit that there is not case until a 14 charge has been filed.
+
+15 THE COURT: So, what about the circuit case 16 that was actually pending case had to do with a plea 17 agreement in a pending case?
+
+18 MR. LEE: Yes. The distinction between the 19 case and the instant case, Your Honor, is 20 this. In , they had negotiated with BP 21 Petroleum for a plea and it was always contemplated 22 that there was going to be a federal prosecution. 23 The distinction in this case was that there was 24 already a pending state prosecution and the 25 objective for both sides was to keep it in state
+
+court and the federal government's objective was to 2 ensure that there were sufficient safeguards in the 3 state court proceedings and concessions made by Mr. 4 Epstein so that federal interests, particularly a 5 cause of action for damages for the victims of the 6 sexual exploitation could be preserved. So that's 7 the key distinction because there was no federal 8 case, there was no federal criminal charge 9 contemplate so long as the agreement could be 10 reached.
+
+11 THE COURT: All right. So they want me to 12 invalidate your non-prosecution agreement.
+
+13 MR. LEE: Your Honor, we respectfully submit 14 that 3771 does not grant authority of this Court to 15 do so. In the case, for instance, Your Honor, 16 there was a plea agreement that was entered into and 17 district court, of course, entertained a plea 18 agreement and exercised its judicial discretion in 19 terms of whether to accept it or not. The victims 20 were encouraged to go to district court and say, you 21 know, we didn't hear about this. We should have, 22 and we object to it for the following reasons. The 23 district court take that into account. There is no 24 plea agreement before this Court. There will be no 25 plea proceedings in this court. That was all done
+
+r
+
+1 2 in state court several weeks ago. So that's another basis for distinguishing
+
+3 4 THE COURT: All right. So is there any point in conferring with these victims?
+
+5 6 7 8 MR. LEE: Your Honor, I will always confer, sit down with Jane Doe 1 and 2, with the two agents and Ms. Villafana. We'll be happy to sit down with them.
+
+9 10 11 12 13 14 THE COURT: But it wouldn't make any difference in terms of the outcome. Would maybe give them the benefit of your explanation of why you did what you did and why you came to the conclusion you did, but it is not going to change your decision in any way.
+
+15 16 17 MR. LEE: If it is going to change, it would have to be done at a level higher than mine, Your Honor.
+
+18 19 20 21 22 23 THE COURT: What was-- I didn't understand your statement earlier that Mr. Epstein wanted some kind of review of higher authority within the Department in terms of whether or not the federal government was going to insist on preserving any civil claims.
+
+24 25 MR. LEE: Your Honor, of the agreement was consumated by the parties in December of 2007. Mr. 1
+
+1 Epstein's attorneys wanted a further review of the 2 agreement higher up within the Department of Justice 3 and they exercised their ability to do that.
+
+4 THE COURT: Meaning? Again, I'm trying to 5 understand. He wasn't happy with the agreement that 6 he had signed?
+
+7 MR. LEE: Basically, yes And was trying to 8 maintain that the agreement should be set aside or 9 more favorable terms.
+
+10 THE COURT: Now, in terms of -- You don't 11 dispute that Jane Doe 1 and 2-- First of all, do you 12 have an objection to Jane Doe 2 being added as a 13 petitioner in this case?
+
+14 MR. LEE: No, I don't.
+
+15 THE COURT: I'll grant that request.
+
+16 You don't dispute that they're victims 17 within the meaning of the Act.
+
+18 MR. LEE: It depends to which -- There is one 19 Jane Doe-- Well, there is one individual who is one 20 of Mr. clients who we do not believe to 21 been a victim. If these are SN and CW, then we have 22 no objection and I can discuss-- If I may have a 23 moment, Your Honor.
+
+24 Your Honor, thank you. I have been 25 corrected. We have no objection.
+
+1 THE COURT: Okay.
+
+2 MR. LEE: We agree they're victims.
+
+3 THE COURT: Now, what is your oosition, 4 then, regarding the right of a victim of a crime 5 that is potentially subject to federal prosecution 6 to be, to have input with the prosecutor, your 7 office, before a resolution or decision not to 8 prosecute is made? Do you say that there is no 9 right to confer under those circumstances because 10 there is no "case pending" so any decision not to 11 prosecute, there is no right to confer but that 12 right to confer only is triggered once there is an 13 indictment or an information filed?
+
+14 MR. LEE: That is correct, Your Honor. The 15 Attorney General guidelines which were published in 16 May of 2005 provide that the rights in 3771(a)(1 17 through 8) accrue when a charge is filed in federal 18 court. Now, that my change after the 19 decision. It is under consideration. But that's 20 the government's position.
+
+21 THE COURT: All right. And so -- Are you 22 saying all of the rights--
+
+23 MR. LEE: Your Honor, some of the rights 24 clearly will only pertain after a charge has been 25 filed. The one that pertains to notice of public 4
+
+1 hearing, public proceedings, though, can't apply 2 until there are public proceedings to be had.
+
+3 Of course, these guidelines are a floor and 4 not a ceiling. They're to be applied with common 5 sense. If somebody-- If charges of assault were 6 being investigated and somebody would come in and 7 say the perpetrator whom you're investigating is 8 getting ready to indict has been threatening me, 9 following me, and I need help because he or she is lo going to do something bad to me and try to take care 11 of me before I can testify in the grand jury, this 12 person would not be turned away because a charge 13 hasn't been filed yet. Those guidelines would be 14 applied with common sense.
+
+15 But specifically insofar as a (a)(5), which 16 is the right to consult with the attorney for the 17 government in the case, that would not accrue until 18 there is a days. And, in our view, a case doesn't 19 come into being until charges are filed.
+
+20 THE COURT: And are there any reported 21 decisions that you are aware of where any court has 22 found a right to confer before charges are filed?
+
+23 MR. LEE: I'm not aware of any, Your Honor.
+
+24 THE COURT: All right. Thank you.
+
+25 MR. LEE: Thank you, Your Honor.
+
+••I
+
+1 THE COURT: Counsel?
+
+2 N.R. : I would just like to address 3 that decision. They're asking you that you 4 just simply ignore it because the decision clearly 5 was a decision made because as it is a direct result 6 of a plea deal being worked out prior to the victims 7 being able to speak.
+
+THE COURT: But there was a pending case, 9 though, correct?
+
+io MR. : As I understand the decision--
+
+11 THE COURT: As I understand the plea deal, it 12 was negotiated prior to charges being filed. Then 13 there was a filed case and then the court had the 14 ability to accept the plea or not. And at that 15 point, you would have the ability to entertain or 16 assert an objection because you weren't consulted 17 about the plea.
+
+18 So there was a proceeding or case in which 19 you can assert a right to confer. How do you do 20 that before a case is filed? How do you enforce the 21 government or force the government to consult about 22 not filing a case? Every case they have to consult 23 with the victim before they decide not to prosecute?
+
+24 MR. : No, there are limitations. I 25 think in my reply I refer to the case of U.S. V.
+
+1 Rubin where they discussed that very scenario 2 stating there at least has to be criminal charges 3 contemplate by the government before these rights 4 kick in. The rights under (d)(3) and (a)(5), the 5 right to confer and the case clearly states 6 clearly rights under the CBRA apply before 7 prosecution is under way. Logically, this includes 8 the CBRA establishments of a victim's reasonable 9 right to confer with the attorney for the 10 government. And, that's read in the plain reading 11 of the statutes as well.
+
+12 This first case in interpreting it, I think 13 it's pretty clear the distinction they're making 14 between BP and this case. Is it a distinction 15 withoug a real difference in that the court is 16 saying you have this right before the case is filed 17 which is exactly what we are saying. And the result 18 in that case was they filed the case, later let him 19 plea out to some sweet deal. And in this case, what 20 we have is they avoid that by deciding not to file. 21 Either way, you deprive the victim of their right 22 before making that decision.
+
+23 And the main problem that the court had in 24 , as it states, the victims do have rights when 25 there is an impact and the eventual sent is
+
+1 substantially less. Whereas here, their input is 2 received after the parties have reached a tentative 3 deal. Well, the government just stated the deal was 4 reached back in October of 2007. However, attached 5 to their response is a letter to my client 6 petitioner, dated January 10, 2008, after the time 7 then counsel just put on the record that the deal 8 9 10 11 12 13 14 15 16 was already finalized and it starts, the opening paragraph talks about whether they wanted the victims to have the right to confer. It says, this case is currently under investigation. This is January 2008. This case has been a lengthy process and we request your continued patience while we conduct a thorough investigation. Sounds like the exact opposite of, we want you to come in and confer and let us know what you really feel about this.
+
+17 18 19 20 21 22 23 24 That is our biggest problem with what has happened here, is that she just wasn't given a voice and if somebody would have heard her, we believe there would have been a different outcome. To go back into a room right now and talk, after there has already been a plea negotiated without Your Honor ordering that in this case the plea deal needs to be vacated, it is illegal and give her her rights.
+
+25 THE COURT: Well, would you agree or not
+
+.1 L.
+
+1 that Mr. Epstein plead guilty to the state charges probably at least, in part, in reliance upon the fact that he had an agreement with the federal government they weren't going to prosecute? Would you concede that or would would present evidence to 6 that effect?
+
+7 MR. : Of course we would. Yes, of 8 course. Sure.
+
+9 THE COURT: So you agree that Mr. Epstein is 10 now sitting in the Palm Beach County Jail a 11 convicted felon serving 18 months of imprisonment, 12 at least in material part, because he relied upon 13 the government's non-prosecution agreement?
+
+14 MR. : YeS. I agree that he is sitting there because he is guilty and maybe he took the plea rather than going to trial and being found guilty later in part because of this non-prosecution agreement that was worked out behind the other 19 victims' backs. I would agree with that.
+
+THE COURT: So he accepted the State's deal in part because he knew he had an agreement from the federal government that they weren't going to prosecute.
+
+24 25 true. MR. : I presume. I speculate that is V
+
+1 THE COURT: So you want me now, then, to set 2 aside the government's agreement with him because 3 there was no conferring, yet he has already accepted 4 a plea agreement and is sitting in custody, in part, 5 in reliance on that agreement. I mean, I can undo 6 the agreement in your theory, but how do I-- Mr. 7 Epstein, in a sense, would then be adversely 8 affected by my actions when he acted in reliance 9 upon the agreement. How does that work?
+
+10 MR. : Certainly, we're only asking 11 you to vacate the agreement. I understand and your 12 point is well taken. And I believe that at that 13 point in time his rights may kick in and say, wait, 14 I was relying on this other deal so I wouldn't be 15 prosecuted for these hundreds of other girls that I 16 molested; that I plead guilty over here to the one 17 girl that I will admit to molesting. So maybe I can 18 get to withdraw my plea. But the last thing he wants 19 to do because if he ends up going to trial, I'll be 20 in prison for the rest of his life like any other 21 person who ever did this crime would be. He could 22 have that argument, I guess, but still wouldn't 23 really work well for him.
+
+24 THE COURT: All right. So you still think I 25 should set aside the agreement, require the
+
+1 government to confer?
+
+2 MR. : Work out a plea negotiation
+
+3 commensorate with the crimes that he committed and
+
+4 that are favorable after they confer with the
+
+5 victims. And it is within their discretion. Of
+
+6 course, they can decide on their own that, hey, I
+
+think that the agreement was fair after they have
+
+8 talked with the victims. That could happen. I
+
+9 don't know if a reasonable person that would do
+
+10 that, but it could happen.
+
+11 THE COURT: Apparently, you are not
+
+12 suggesting that that these person are not
+
+13 reasonable.
+
+14 MR. : I'm suggesting they haven't
+
+15 conferred with the victims and that if they took
+
+16 into consideration what these two in the courtroom
+
+17 have to say, I don't think that we'd be in this same
+
+i8 position right now.
+
+19 THE COURT: They have never spoken to your
+
+2C client about what happened to them?
+
+21 MR. : They have spoken to them about
+
+22 what happened. Maybe not about what the girls
+
+23 wanted to happen as a result of this case, which is
+
+24 part of conferring to decide that these girls wanted
+
+25 money on their own, which is basically what this--
+
+Jr
+
+this non-prosecution agreement entails that has 2 language that he'll agree to liability in a civil 3 case. That's not what these girls-- They want 4 justice. They want him in prison now more than 5 ever. The reason they stated they kept this 6 agreement from the girls and they basically conceded we didn't tell the girls about this agreement, well, 8 the reason is because they would have objected and 9 they wouldn't have been able to sign off on this and io the victims would have had a voice, and we'd still 11 been going through litigation. The exact problem 12 they tried to prevent, at least in their terms which 13 was the impeachment of these girls at a later trial, 14 is still available to anybody once the civil suits 15 are filed anyway.
+
+16 They have three arguments. One, we didn't 17 have to talk to them. Two, we did talk to them sort 18 of. And if you don't buy that, the reason we didn't 19 talk to them, we were trying to prevent them from 20 being impeached later. None of them trump the 21 victims' rights to confer prior to plea 22 negotiations. That's why, Your Honor, we would ask 23 this Court to enter an order vacating that previous 24 plea agreement as illegal, ask them to confer with 25 the victims once again or for the first time and
+
+1 work out a negotiated plea to that accord.
+
+THE COURT: well, all you can ask them to do is confer. I can't ask them to do anything beyond that. I mean, it is up to them to negotiate.
+
+5 MR. : I wouldn't quarrel with that.
+
+THE COURT: Now, having learned today, I guess, that the agreement was signed when, in October?
+
+9 MR. : October 2007, I heard.
+
+THE COURT: About eight or nine months ago, 11 is there any need to rush to a decision in this matter? The decision has already been made. You filed this, I think, on the presumption that the agreement was about to take place and you wanted to be able to confer beforehand and you weren't sure what was going on.
+
+MR. : Precisely, Your Honor. And I'm 18 holding the letters that are exhibits that they were writing to my client during the year of 2008 telling her how lengthy of a process this was going to be 21 and be patient. So, right, I was completely in the 22 dark about when this agreement was signed.
+
+THE COURT: In view of the fact that this agreement has already been consumated, and you want me to set it aside, as opposed to something that's
+
+1 about to occur, would you agree that-- and I have done this very quickly because of the petition and your allegation that something was about to happen. I'm not blaming you.
+
+MR. : I was mistaken.
+
+6 THE COURT: I'm not blaming you for doing 7 that. In view of what you know now, is there any 8 9 need to treat this as an emergency that has to be decided by tomorrow?
+
+10 11 MR. : I can't think of any reason in light of what we just heard.
+
+12 13 14 15 16 17 18 19 THE COURT: Mr. Lee, do you have anything else you wanted to add? Does either side think I need to take evidence about anything? If I do, since this is not an emergency anymore, I can probably find a more convenient time to do that. I don't have the time today to take evidence. But if you do believe that I should take evidence on this issue.
+
+20 21 22 23 24 MR. : It may be best if I conferred with the U.S. Attorney's Office on that and we can make a decision whether it is necessary or whether Your Honor deemed it was necessary for you to make a decision.
+
+25 THE COURT: I want to know what your
+
+1 respective positions are because it may be something in terms of having a complete record, and this is going to be an issue that's it going to go to the Eleventh Circuit, may be better to have a complete record as to what your position is and the 6 government's is as to what actions were taken. And I don't know if I have enough information, based on Ms. Villafana's affidavit or I need additional information. And because it is not an emergency, I don't have to do something quickly, we can play it be ear and make this into a more complete record for 12 the court of appeals.
+
+MR. : If there is a time where it is necessary to take evidence, Your Honor is correct in 15 stating that it is not an emergency and it doesn't 16 need to happen today. And, I will confer with the government on this and if evidence needs to be 18 taken, it be taken at a later date. It doesn't seem like there will be any prejudice to any party.
+
+THE COURT: Mr. Lee, do you have any 21 thoughts? You want to consult with Mr.
+
+MR. LEE: There may be a couple of factual matters that I need to chat with petitioner's counsel on. If we can reach agreement on those as 25 to what was communicated to CW and what time, if
+
+1 they don't dispute that, then we don't think it will 2 be necessary to have an evidentiary hearing. But if 3 we can agree, fine or maybe we can't. We'll talk 4 about it.
+
+S THE COURT: All right. So why don't you let 6 me know if you think an evidentiary hearing is 7 necessary. If there are additional stipulations you 8 want to enter into or supplement what has already 9 been presented, you can do that.
+
+10 Now, the other issue I want to take up, 11 though, is the government filed its response to the 12 petition under seal. And so I want to know why. 13 What is in there that at this point needs to be 14 under seal? Is there anything in there that's 15 confidential, privileged, anything that's different 16 from what you hve said here in open court that 17 requires that to be sealed?
+
+18 MR. LEE: Well, Your Honor, on our motion to 19 seal was based on two reasons. One that dealt with 20 individuals or minors at the time that the offense 21 occurred. So we were attempting to protect the 22 privacy of those individuals. And also it dealt 23 with negotiations with Mr. Epstein which were in the 24 nature of plea negotiations, which we treat as 25 confidential. Normally, they're not aired out in
+
+1 open court. So those were our two reasons.
+
+2 3 4 THE COURT: All right. But I guess the letters you attached only related to Mr. client.
+
+5 MR. LEE: Three of them, yes, Your Honor.
+
+6 8 THE COURT: Are you prepared, Mr. to waive any issues regarding the release of those documents that relate to your clients?
+
+9 10 11 MR. : Judge, I think it would be appropriate to redact the names of the clients as they have done.
+
+12 13 THE COURT: I don't think the names are in there.
+
+14 15 16 17 MR. : I think they're redacted. They're blacked out. I have no problem with releasing those documents. I'm not sure that's part of the deal. But if it is--
+
+18 MR. LEE: It is.
+
+19 MR. : Okay. I'll waive.
+
+20 21 22 THE COURT: You really don't have any objection to those letters that were sent to them being released to the public?
+
+23 MR. : Of course not, Judge.
+
+24 25 THE COURT: Then what is there about the plea agreement or the negotiations that is in the 1 response that we really haven't already kind of--
+
+2 MR. LEE: Your Honor, there was a
+
+3 confidentiality agreement in the deferral of
+
+4 prosecution to the State of Florida. So we were
+
+5 trying to maintain the confidentiality of the
+
+6 negotiations that occurred since we had discussions
+
+7 during those negotiations as one of the reasons why
+
+8 we decided not to tell all of the individuals what
+
+9 was going on.
+
+10 THE COURT: But is that still necessary,
+
+11 that confidentiality or is that kind of moot at this
+
+12 point?
+
+13 MR. LEE: Well, we would like it sealed.
+
+14 Admittedly, what happened today in open court has
+
+15 probably weakened our argument. I don't dispute
+
+16 that.
+
+17 THE COURT: In your opinion, anything in
+
+18 particular, any paragraph in the response or in Ms.
+
+19 Villafana's affidavit that you think is particularly
+
+20 troublesome that should remain under seal?
+
+21 MR. LEE: May I have a moment, Your Honor?
+
+22 THE COURT: Yes.
+
+23 MR. LEE: Thank you. Your Honor, one aspect
+
+24 of this in the notification letters that were
+
+25 dispatched to individuals which were attached to Ms. 1 2 3 4 5 Villafana's declaration, there is a citation to a clause in the agreement that was reached regarding the damages remedy under 18 USC 2255 that was subject to the constitutionality agreement, we believe that should still remain confidential.
+
+6 7 8 THE COURT: But hasn't the fact that this provision was part of the agreement again been aired? Is there any secret to it anymore?
+
+9 10 11 12 MR. LEE: The actual text of it has not been aired. The existence of it has been heard but the actual text has not and we believe it should still remain confidential.
+
+13 14 THE COURT: Okay. Any other argument on that issue?
+
+15 MR. LEE: No, Your Honor. Thank you.
+
+16 17 THE COURT: Ms. Villafana wants to speak to you.
+
+18 19 20 21 22 23 MR. LEE: Your Honor, one item that I'd like to bring to the Court's attention. We had advised Mr. Epstein and his attorneys that if we were to dislose some of the agreement, we would give them advance notice and ability to lodge an objection. We would like an opportunity to do that.
+
+24 25 THE COURT: All right. But you're not disclosing. It would be by my order that it would 1 be disclosed.
+
+2 3 4 MR. LEE: Yes, Your Honor. And we just would like to register that we believe it should remain confidential.
+
+5 THE COURT: All right.
+
+6 7 MR. : Your Honor, I don't see any authority for keeping that under seal.
+
+8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: I agree. The fact that there is this preserved right on behalf of the victims to pursue a civil action is already a matter of public record; the exact text of the clause-- I don't see that disclosing the text of the clause when the fact that the clause exists is already a matter of public record. It is not harmful in any way to Mr. Epstein or the government and the letters to the victim that the victim can disclose those letters, they're not under any confidentiality obligation or restriction and they're free to disclose it themselves if they choose to. So I don't see that there is any real public necessity to keep the response sealed in view of what we discussed already on the record and the victim's ability to disclose those provisions of their own choosing, if they wish. So, in view of the public policy that matters filed in court proceedings should be open to the public and sealing 1 should only occur in circumstances that justife the 2 need to restrict public access, I'm going to deny 3 the motion to seal the response and allow that to be 4 viewed.
+
+All right. So i'll let both of you confer about whether there is a need for any additional evidence to be presented. Let me know one way or the other. If there is, we'll schedule a hearing. If there isn't and you want to submit some additional stipulated information, do that, and then I'll take care of this in due course.
+
+12 MR. : Thank you, Your Honor.
+
+13 THE COURT: All right.
+
+14 MR. LEE: Thank you, Your Honor.
+
+15 MS. VILLAFANA: Thank you, Your Honor.
+
+16 THE COURT: You're welcome.
+
+17 (Proceedings concluded.)
+
+18
+
+19
+
+20 I hereby certify that the foregoing is true 21 and correct to the best of my ability.
+
+22
+
+23
+
+24 4.#6 lea eitt
+
+25 Victoria Aiello, Court Reporter

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marker2/court-doe-v-us/EFTA02752787/EFTA02752787.md

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+![](_page_0_Picture_12.jpeg)
+
+UNITED STATES DISTRICT COURT  
+SOUTHERN DISTRICT OF FLORIDA
+
+Case No.: 08-80736-Civ-MARRA/[REDACTED]
+
+In re: Jane Doe, *et al.*
+
+Petitioners.
+
+![](_page_0_Picture_17.jpeg)
+
+**MOTION FOR LIMITED APPEARANCE, CONSENT TO  
+DESIGNATION AND REQUEST TO ELECTRONICALLY RECEIVE  
+NOTICES OF ELECTRONIC FILING**
+
+In accordance with Local Rules 4.B of the Special Rules Governing the Admission and Practice of Attorneys of the United States District Court for the Southern District of Florida, the undersigned respectfully moves for the admission of Paul G. Cassell, Esquire, for purposes of limited appearance as co-counsel on behalf of Jane Does #1 and #2, herein, in the above-styled case only, and pursuant to Rule 2B, Southern District of Florida, CM/ECF Administrative Procedures, to permit Paul G. Cassell to receive electronic filings in this case, and in support thereof states as follows:
+
+1. While Paul G. Cassell Esquire, is not admitted to practice in the Southern District of Florida, he is a member in good standing of the Utah State Bar and the bar of the U.S. District Court for the District of Utah.
+
+2. Movant, Brad [REDACTED], Esquire, of the law firm of The Law Offices of Brad [REDACTED] & Associates, is a member in good standing of the The Florida Bar and the United States District Court for the Southern District of Florida, maintains an office in this State for the practice of law, and will shortly be filing the appropriate application to be authorized to file through the Court's electronic filing system. Movant consents to be designated as a member of the Bar of this Court with whom the Court and opposing counsel may readily communicate regarding the conduct of the case,
+
+upon whom filings shall be served, who shall be required to electronically file all documents and things that may be filed electronically, and who shall be responsible for filing documents in compliance with the CM/ECF Administrative Procedures. See Section 2B of the CM/ECF Administrative Procedures.
+
+3. In accordance with the local rules of this Court, Paul G. Cassell, Esquire, has made payment (enclosed) of this Court's \$75 admission fee. A certification in accordance with Rule 4B is attached hereto.
+
+4. Paul G. Cassell, Esquire, by and through designated counsel and pursuant to Section 2B, Southern District of Florida, CM/ECF Administrative Procedures, hereby requests the Court to provide Notice of Electronic Filings to Paul G. Cassell, Esquire, at email address: [cassellp@law.utah.edu](mailto:cassellp@law.utah.edu).
+
+WHEREFORE, Brad [REDACTED], Esquire, moves this Court to enter an Order permitting Paul G. Cassell to appear before this Court on behalf of Jane Doe, for all purposes relating to the proceedings in the above-styled matter and directing the Clerk to provide notice of electronic filings to Paul G. Cassell.
+
+Date: July 24, 2008.
+
+Respectfully submitted,
+
+![]()Brad [REDACTED], Esquire  
+Florida Bar #542075  
+be@bradedwardslaw.com  
+2028 [REDACTED] Street  
+Suite 202  
+Hollywood, Florida 33020  
+Telephone: 954-414-8033  
+Facsimile: 954-924-1530  
+Attorney for Jane Doe #1 & #2
+
+# CERTIFICATE OF SERVICE
+
+I HEREBY CERTIFY that a true and correct copy of the foregoing Motion for Limited Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic Filings was served by mail, on July 24, 2008 , on all counsel or parties of record on the service list.
+
+Brad, Esquire
+
+Case No.: 08-80736
+
+# SERVICE LIST
+
+Ann C. Villafana Assistant U.S. Attorney United States Attorney's Office 500 South Australian Avenue Suite 400 West Palm Beach, FL 33401
+
+Dexter Lee Assistant U.S. Attorney United States Attorney's Office 99 N.E. 4th Street Miami, Florida 33132
+
+### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+Case No.: 08-80736
+
+In re: Jane Doe, et al.
+
+Petitioners.
+
+## CERTIFICATION OF PAUL G. CASSEL, ESQ.
+
+Paul G. Cassell, Esquire, pursuant to Rule 4B of the Special Rules Governing the Admission and Practice of Attorneys, hereby certifies that (1)1 have studied the Local Rules of the United States District Court for the Southern District of Florida; and (2) I am a member in good standing of the Utah Bar and the bar for the U.S. District Court for the District of Utah.
+
+Paul G. Cassell, -squire
+
+CERTIFICATE OF SERVICE
+
+I HEREBY CERTIFY that a true and correct copy of the foregoing Motion for Limited Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic Filings was served by mail, on July 24, 2008, on all counsel or parties of record on the service list.
+
+![]()Brad [REDACTED], Esquire  
+Florida Bar #542075  
+be@bradedwardslaw.com  
+2028 [REDACTED] Street  
+Suite 202  
+Hollywood, Florida 33020  
+Telephone: 954-414-8033  
+Facsimile: 954-924-1530  
+Attorney for Jane Doe #1 & #2
+
+Case No.: 08-80736
+
+# SERVICE LIST
+
+Ann RIC. Villafana Assistant U.S. Attorney United States Attorney's Office 500 South Australian Avenue Suite 400 West Palm Beach, FL 33401
+
+Dexter Lee Assistant U.S. Attorney United States Attorneys Office 99 N.E. 4th Street Miami, Florida 33132

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marker2/court-doe-v-us/EFTA02752794/EFTA02752794.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+Case No. 08-80736-Civ-Marra
+
+JANE DOES #1 and #2
+
+Petitioners,
+
+v.
+
+UNITED STATES
+
+Respondent.
+
+/
+
+## GOVERNMENT'S NOTICE TO COURT REGARDING ABSENCE OF NEED FOR EVIDENTIARY HEARING
+
+Respondent United States, by and through its undersigned counsel, files its Notice to Court Regarding Absence of Need for Evidentiary Hearing, and states:
+
+- I. At the conclusion of the hearing held on July 11, 2008, the Court asked the parties whether an evidentiary hearing would be necessary. The Government suggested that the parties confer, and determine whether such a hearing should be held.
+- 2. After consideration, the Government believes that an evidentiary hearing is not necessary. The precise issue before the Court is whether the Government was obligated, under 18 U.S.C. § 377/ (a)(5), to confer with petitioners prior to entering into an agreement with Jeffrey Epstein, which permitted the pending State of Florida prosecution to go forward, so long as Epstein agreed to certain conditions.
+- 3. The Government believes there are two relevant facts which will permit the Court to resolve the legal issue: (I) there are no criminal charges in the United States District Court, Southern District of Florida, filed against Jeffrey Epstein; and (2) Epstein entered pleas of guilty
+
+in Florida State Court on June 30, 2008, was sentenced, and is now imprisoned in Palm Beach County. The Government believes the absence of any charges in the Southern District of Florida can be judicially noticed pursuant to Fed.R.Evid. 201(b), because such information is either generally known within the territorial jurisdiction of the trial court, or, is capable of accurate and ready determination by resort to sources whose accuracy cannot reasonably be questioned. Cash Inn of Dade, Inc. v. Metropolitan Dade County 938 F.2d 1239, 1243 (11th Cir. 1991)("A district court may take judicial notice of public records within its files relating to the particular case before it or related cases."Xcitation omitted). Under the same rationale, the absence of such files can also be judicially noticed. Epstein's convictions in State court can be established by public record documents, which the Government will file with this Court.
+
+Respectfully submitted,
+
+R. ALEXANDER ACOSTA UNITED STATES ATTORNEY
+
+By: s/ Dexter A. Lee DEXTER A. LEE Assistant U.S. Attorney Fla. Bar No. 0936693 99 N.E. 4th Street Miami, Florida 33132 (305) 961-9320 Fax: (305) 530-7139 E-mail: dexter.leeOusdoi.gov
+
+Attorney for Respondent
+
+## CERTIFICATE OF SERVICE
+
+I HEREBY CERTIFY that on July 29, 2008, I electronically filed the foregoing document with the Clerk of the Court using CMJECF.
+
+s/ Dexter A. Lee
+
+DEXTER A. LEE
+
+Assistant U.S. Attorney
+
+## SERVICE LIST
+
+Jane Does 1 and 2 v. United States,
+
+Case No. 08-80736-CIV-MARRAi
+
+United States District Court, Southern District of Florida
+
+Brad , Esq.,
+
+The Law Offices of Brad & Associates, LLC
+
+2028 Street, Suite 202
+
+Hollywood, Florida 33020
+
+(954) 414-8033
+
+Fax: (954) 924-1530

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marker2/court-doe-v-us/EFTA02752797/EFTA02752797.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+Case No. 08-80736-Civ-Marra
+
+JANE DOES #1 and #2
+
+v.
+
+UNITED STATES
+
+## STIPULATION
+
+The parties to this action, petitioners Jane Doe #1, Jane Doe #2, and the respondent United States of America, by and through their undersigned counsel, do hereby stipulate and agree that the following facts are true and correct and that no further evidentiary hearing is required with respect to the pending "Victim's Emergency Petition for Enforcement of Crime Victim Right Act, 18 U.S.C. § 3771.
+
+1. In 2006, at the request of the Palm Beach Police Department, the Federal Bureau of Investigation ("FBI") opened an investigation into allegations that Jeffrey Epstein ("Epstein") and his personal assistants had used facilities of interstate commerce to induce young girls between the ages of thirteen and seventeen to engage in prostitution, amongst other offenses. The case was presented to the United States Attorney's Office for the Southern District of Florida, which accepted the case for investigation.
+
+2. At the time that the investigation was opened, the Palm Beach County State Attorney's Office had presented evidence to a state grand jury, which had returned an indictment charging solicitation of prostitution. That charge made no reference to the ages of the registration. minor victims and, upon conviction, would not require sex offender
+
+3. Jane Doe #1 is a woman with initials C.W., and Jane Doe #2 is a woman with initials T.M. Both were victims of Epstein's while they were minors beginning when they were fifteen years old. Both Jane Does were identified through the Palm Beach Police Department's investigation of Epstein.
+
+4. Attached as Exhibits 1, 2, 3, and 4 to the Declaration of A. Villafa►3a **are true and correct copies of victim notification letters sent to Jane Does 1 and 2 from the United States Attorney's Office and the FBI.** 
+
+**5. Throughout the investigation, the FBI agents and the Assistant U.S. Attorney had several meetings with Jane Doe #1. During those meetings, Jane Doe #1 never expressed a desire to be consulted prior to the resolution of the investigation. Jane Doe #2 was represented by counsel and, accordingly, all contact was made through that attorney. That attorney never expressed that Jane Doe #2 wanted to be consulted prior to the resolution of the investigation.** 
+
+**6. In September 2007, Epstein and the U.S. Attorney's Office reached an agreement whereby the United States would defer federal prosecution in favor of**  prosecution by the State of Florida, so long as certain basic preconditions were met. Those included a conviction on a state sex offense that reflected that the victims were minors at the time the crimes occurred and that would require sex offender registration. Another key objective for the United States Attorney's Office was to preserve a federal remedy for the young girls whom Epstein had sexually exploited. The Agreement contained an express confidentiality provision. The Agreement was subsequently modified in October and December 2007.
+
+7. Although individual victims were not consulted regarding the agreement, several had expressed concerns regarding the exposure of their identities at trial and they desired a prompt resolution of the matter. At the time the agreement and the modifications were signed in September, October, and December 2007, Jane Doe #2 was openly hostile to the prosecution of Epstein.
+
+8. In October 2007, shortly after the initial agreement was signed, Jane Doe #1 was contacted to be advised regarding the resolution of the investigation. On October 26, 2007, Special Agents E. Nesbitt Kuyrkendall and Jason Richards met in person with Jane Doe #1. The Special Agents explained that the investigation had been resolved, that Epstein would plead guilty to state charges, he would be required to register as a sex offender for life, and he had made certain concessions related to the payment of damages to the victims, including Jane Doe #1. During this meeting, Jane Doe #1 did not raise any objections to the resolution of the matter.
+
+9. Jane Doe # l's perception of the explanation provided by the Special Agents was that only the State part of the Epstein investigation had been resolved, and that the federal investigation would continue, possibly leading to a federal prosecution.
+
+10. When Epstein's attorneys learned that some of the victims had been notified, they complained that the victims were receiving an incentive to overstate their involvement with Epstein in order to increase their damages claims. Following the signing of the Agreement and the modifications thereto, Epstein's performance was delayed while he sought higher level review within the Department of Justice. Throughout that period, the FBI and the U.S. Attorney's Office maintained contact with the victims, to be prepared if Epstein were to renege on the agreement.
+
+11. After Jane Doe #1 had been notified of the terms of the agreement, but before Epstein performed his obligations, Jane Doe #1 contacted the FBI because Epstein's counsel was attempting to take her deposition and private investigators were harassing her. Assistant U.S. Attorney A. Villafaiia secured pro bono counsel to represent Jane Doe #1 and several other identified victims in connection with the criminal investigation. Pro bono counsel was able to assist Jane Doe #1 in avoiding the improper deposition.
+
+12. In mid-June 2008, Attorney contacted AUSA Villafafla to inform her that he represented Jane Doe #1 and, later, Jane Doe #2. Attorney asked to meet to provide information regarding Epstein. Attorney was asked to send any information that he wanted considered, but did not send anything.
+
+13. On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA Villafafia received a copy of Epstein's proposed state plea agreement and learned that the plea was scheduled for 8:30 a.m., Monday, June 30, 2008. AUSA Villafafia and the Palm Beach Police Department attempted to provide notification to victims in the short time that Epstein's counsel had provided. Attorney was called to provide notice to his clients regarding the hearing.
+
+14. On July 9, 2008, AUSA Villafafia sent a victim notification to Jane Doe #1 via her attorney, which is attached as Exhibit 6 to the Villafafia Declaration. That notification contains a written explanation of the full terms of the agreement between Epstein and the U.S. Attorney's Office. A notification was not provided to Jane Doe #2 because the agreement limited Epstein's liability to victims whom the United States was prepared to name in an indictment.
+
+SO STIPULATED AND AGREED.
+
+Dated:
+
+ESQ. Attorney for Petitioners Jane Does #1 &
+
+2
+
+R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated:
+
+LEE
+
+By:
+
+ASSISTANT U.S. ATTORNEY DEXTER
+
+Attorney for Respondent United States

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marker2/court-doe-v-us/EFTA02752803/EFTA02752803.md

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+![](_page_0_Picture_14.jpeg)
+
+AND ASSOCIATES
+
+July 17, 2008
+
+Ann [REDACTED] C. Villafaña, AUSA  
+United States Attorney's Office  
+500 South Australian Avenue  
+West Palm Beach, Florida 33401
+
+Re: Proposed Stipulated Facts for In Re Jane Doe
+
+Dear Ms. Villafaña:
+
+Thank you for your recent proposed stipulation of facts in this case. I believe that we have considerable common ground. At the same time, however, it appears to me that a few areas of potential disagreement are arising. In view of that, and to avoid any misunderstandings, I thought it might be useful to send a short letter outlining several requests and issues for resolution before I send you back my proposed stipulated facts.
+
+1. I am working with two other attorneys on this case – Jay Howell in Jacksonville, Florida, and Professor Paul Cassell in Salt Lake City, Utah. Because they were not in court for the hearing last Friday, they will need to review a transcript of the hearing before our legal team can agree to any stipulated facts. I have requested a transcript, but the preparation of it will apparently take several weeks. Do you have any way of expediting the preparation of the transcript by requesting it yourself? Also, as you know, my clients are indigent. As part of the Government's responsibility to use its "best efforts to see that crime victims are . . . accorded[] the rights" in the CVRA, 18 U.S.C. § 3771(c)(1), I was wondering whether the Government would be willing to pay for the transcript.
+
+2. Your proposed stipulation indicates that in September 2007 the U.S. Attorney's Office reached an agreement with Epstein to resolve the case, which was then modified in October and December of that year. While this seems plausible, to stipulate to the facts, I would obviously need to see copies of those three agreements. Moreover, because the circumstances surrounding the initial agreement and its later modification are now the subject of litigation, my client is entitled to see them. See 18 U.S.C. § 3771(a)(8) (victim's right to "be treated with fairness"). In addition, your proposed stipulation states that: "On July 9, 2008, AUSA Villafaña sent a victim notification to Jane Doe #1 via her attorney, [REDACTED] [REDACTED], which is attached as Exhibit 6 to the Villafaña Declaration. That notification contains a written explanation of the *full terms* of the agreement between Epstein and the U.S. Attorney's Office." I am puzzled by this proposed stipulation, as your July 9 letter explicitly noted that it was covering only some of the provisions in the agreement. Perhaps the fact that I have not yet received the agreement is all just an oversight on your part, and you had intended to give me the "full terms" of the plea agreement that was ultimately reached. In any event, the simplest way to proceed at this point is for the plea agreement – and the earlier versions -- to be provided to me so that I can review
+
+OFFICE: 954-414-8033/305-935-2011  
+FAX: 954-924-1530/305-935-4227  
+BE@BRADEDWARDSLAW.COM
+
+Annie C. Villafafta, AUSA United States Attorney's Office Page 2
+
+them with my clients. Of course, no possible harm to the Government can come from the release of the documents, as this criminal matter is now concluded — at least from the Government's perspective.
+
+3. I am wondering about your position on the confidentiality provision in the agreement. As I understand things from your proposed stipulation, in September 2007 you "reached" an agreement with Epstein's attorneys that "contained an express confidentiality provision." Are you taking the position that this "express" provision barred disclosure of the substance of the agreement to my clients? And, if so, would you stipulate that the FBI agents and your office complied with the provision up through June 30 when, I assume, the confidential provision expired as Epstein entered his guilty plea in open court?
+
+## 4. Your proposed stipulation indicates:
+
+On October 26, 2007, Special Agents E. Nesbitt Kuyrkendall and Jason Richards met in person with Jane Doe #1. The Special Agents explained that the investigation had been resolved, that Epstein would plead guilty to state charges, he would be required to register as a sex offender for life, and he had made certain concessions related to the payment of damages to the victims, including Jane Doe #1. During this meeting, Jane Doe #1 did not raise any objections to the resolution of the matter.
+
+From the drafting of this proposed stipulation, it appears that you may be working from a Report of Interview with my client (i.e., an FBI 302). My client has a differing recollection of some aspects of that meeting. Of course, she did not take notes of the meeting. Therefore, I ask that you provide me (the relevant parts of) any report of this meeting as well as reports of any other meetings relevant to the matters at hand.
+
+I believe that my client is entitled to a copy of (the relevant parts of) the reports of interviews with her. Of course, a criminal defendant would be entitled to such documents. See Fed. R. Crim. P. 16(a)(1)(A) & (B). As an innocent victim in this matter, my client should be treated with at least the same consideration. See 18 U.S.C. § 3771(a)(8) (victim's right to "be treated with fairness").
+
+5. I am hoping that the Special Agents' and my client's recollections about one point of the October 26th meeting coincides: that she was never told that the agreement blocked all federal prosecution for the crimes at hand. Is a stipulation on that point agreeable?
+
+OFFICE: 954-414-8033/305-935-2011 FAX: 954-924-1530/305-935-4227 BEORRADEDWARDSLAW.0OM
+
+AnnIM C. Villafafta, AUSA United States Attorney's Office Page 3
+
+6. You mention your assistance in securing pro bono counsel for Jane Doe #1 to help prevent harassment. I trust that you would be willing to stipulate that you did not mention the federal non-prosecution agreement to this counsel and that you did not mention that a plea agreement had already been reached. Professor Cassell has spoken to Meg Garvin, Esq., at the National Crime Victims' Law Institute, and that is her recollection of the events.
+
+7. I think that your proposed stipulation regarding my contact with the office is somewhat abbreviated. I wonder what you would think about the following:
+
+In mid-June 2008, Mr.MI contacted AUSA Villa form her that he represented Jane Doe #1 and, later, Jane Doe #2. Mr. asked to meet to provide information about the federal crimes committed by Epstein, hoping to secure jigaiticant federal indictment against Epstein. AUSA Villafafta and Mr. discussed the possibility of harges being filed. At the end of the call, AUSA Villafafla asked Mr. to send any information that he wanted considered by the U.S. Attorney's Office in determining whether to file federal charges. of the confidentiality provision that existed in the plea agreement, Mr.," was not informed that, in September 2007, the U.S. Office had reached an agreement not to file federal charges. Mr. was also not informed that any resolution of the criminal matter was imminent.
+
+On July 3, 2008, Mr. sent to AUSA a a letter, a true and correct copy of which is attached. In the letter, Mr. EM indicated his desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients: "We urge the Attorney General and our United States Attorney to consider the fundamental import of the vigorous enforcement of our Federal laws. We urge you to move forward with the traditional indictments and criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take the steps necessarilect our children from this very dangerous sexual predator." When Mr. wrote this letter, he was still unaware that a non-prosecution agreement had been reached with Epstein. Mr. first learned of this fact on or after July 9, 2008, when the Government filed its responsive pleading to Jane Doe's emergency petition. That pleading was the first u 'c ention of the non-prosecution agreement and the first disclosure to Mr. and his clients. 6 .1
+
+8. I trust that you will agree that the Government had probable cause to file a multiple count federal indictment against Epstein, including an indictment charging crimes
+
+OFFICE: 954-414-8033/305-935-2011 FAX: 954-924-1530/305-935-4227 BEOBRADEDWARDSLAW.COM
+
+Ann [REDACTED], C. Villafaña, AUSA  
+United States Attorney's Office  
+Page 4
+
+against Jane Doe #1 and Jane Doe #2. In asking for this stipulation, I realize that you have taken the position that you would not have filed an indictment involving Jane Doe #2, presumably because you thought that you could not carry the Government's burden of proof beyond a reasonable doubt. At the same time, though, I trust you will concede that the evidence in that case was strong enough to pass the probable cause standard.
+
+9. Finally, in light of the fact that you have been sending letters to Jane Doe #2, which was obviously done because you believed her to be a "victim" in this case, and since she has been added in this matter as a victim, we would like some assurances that she will be protected, as the other victims have been, in your agreement with Mr. Epstein.
+
+Thank you very much for considering these issues and concerns. I look forward to working with you to reach a stipulation that covers as much common ground as possible in this case. If you think that further discussions might be helpful, I would like to try and set up a conference call with you and my co-counsel to discuss these issues further.
+
+Sincerely,
+
+![]()BE/sg  
+Enclosure
+
+cc: Dexter Lee, AUSA  
+United States Attorney's Office  
+99 N.E. 4th Street  
+Miami, Florida 33132
+
+![](_page_4_Picture_2.jpeg)
+
+July 3, 2008
+
+Ann C. Villafana, AUSA United States Attorney's Office 500 South Australian Avenue West Palm Beach, Florida 33401
+
+Dear Ms. Villafana:
+
+VIA CERTIFIED MAIL RETURN RECEIPT REQUESTED 7007 2680 0002 5519 8503
+
+As you are aware, we represent several of the young girls that were victimized and abused by Jeffrey Epstein. While we are aware of his recent guilty plea and conviction in his State Court case, the sentence imposed in that case is grossly inadequate for asexual predator of this magnitude. The information and evidence that has come to our attention in this matter leads to <sup>a</sup>grave concern that justice will not be served in this cause if Mr. Epstein is not aggressively prosecuted and appropriately punished. Based on our investigation and knowledge of this case, it is apparent that he has sexually abused more than 100 underage girls, and the evidence against him is overwhelmingly strong.
+
+As former Assistant State Attorneys with seven years' prosecution experience, we believe that the evidence against Mr. Epstein is both credible and deep and that he may be the most dangerous sexual predator of children that our country has ever seen. The evidence suggests that for at least 4 years he was sexually abusing as many as three to manipulate four girls a day. It is inevitable that if he is not confined to prison, he will continue to and sexually abuse children and destroy more lives. He is asexual addict that focused all of his free time on sexually abusing children, and he uses his extraordinary wealth and power to lure in poor, underprivileged little girls and then also uses his wealth to shield himself from prosecution and liability. We are very concerned for the health and welfare of the girls he has already victimized, and concerned that if justice is not properly served now and he is not imprisoned for <sup>a</sup>very long time, he will get a free pass to sexually abuse children in the future. Future abuse and victimization is obvious to anyone who really reviews the evidence in this case, and future sexual abuse of minors is inevitable unless he is prosecuted, tried and appropriately sentenced. Money and power should not allow <sup>a</sup>man to make his own laws, and he has clearly received preferential treatment at every step up to this point. If he were a man of average wealth or the abused girls were from middle or upper class families, then this man would spend the rest of his life in prison. In acountry of true, blind justice, those distinctions are irrelevant, and we really hope he does not prove the point that <sup>a</sup>man can commit heinous crimes against children and buy his way out of it.
+
+If the Department of Justice's recent commitment to the protection of our children from child molesters is to be more than rhetoric, then this is the time and the case where the Department must step forward. We urge the Attorney General and our United States
+
+OFFICE, 954-414-8033/305-935-2011 PAX, 954-924-1530/305-935 - 4227 BE•BRADEDWARDSLAW.COM
+
+Ann [REDACTED] C. Villafana, AUSA  
+United States Attorney's Office  
+Page Two
+
+Attorney to consider the fundamental import of the vigorous enforcement of our Federal laws. We urge you to move forward with the traditional indictments and criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take the steps necessary to protect our children from this very dangerous sexual perpetrator. We will help you to do this in any way possible to ensure that true Justice is served in this case.
+
+Sincerely,
+
+![]()Brad [REDACTED] Esquire  
+Jay Howell, Esquire
+
+---
+
+OFFICE: 954-414-8033/305-935-2011  
+FAX: 954-924-1530/305-935-4227  
+BE@BRADEDWARDSLAW.COM
+
+| <b>SENDER: COMPLETE THIS SECTION</b><br><input type="checkbox"/> Complete Items 1, 2, and 3. Also complete Item 4 if Restricted Delivery is desired.<br><input type="checkbox"/> Print your name and address on the reverse so that we can return the card to you.<br><input type="checkbox"/> Attach this card to the back of the mailpiece, or on the front if space permits.                                                                   |  |
+|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|
+| 1. Article Addressed to:<br><div style="border: 1px solid black; padding: 10px; text-align: center;">                 Ann [REDACTED] C. Villafana, AUSA<br/>                 United States Attorney's Office<br/>                 500 South Australian Avenue<br/>                 West Palm Beach, Florida 33401             </div>                                                                                                              |  |
+| <b>COMPLETE THIS SECTION ON DELIVERY</b><br>A. Signature <span style="float: right;"><input type="checkbox"/> Agent</span><br><input checked="" type="checkbox"/> Addressee<br>B. Received by (Printed Name) <span style="float: right;"><input type="checkbox"/> C. Date of Delivery</span><br><div style="border: 1px solid black; padding: 5px; text-align: center;">                 CELWESS <span style="float: right;">7/7/08</span> </div> |  |
+| D. Is delivery address different from item 1? <input type="checkbox"/> Yes <input type="checkbox"/> No<br>If YES, enter delivery address below: <input type="checkbox"/> No                                                                                                                                                                                                                                                                       |  |
+| 3. Service Type<br><input checked="" type="checkbox"/> Certified Mail <input type="checkbox"/> Express Mail<br><input type="checkbox"/> Registered <input type="checkbox"/> Return Receipt for Merchandise<br><input type="checkbox"/> Insured Mail <input type="checkbox"/> C.O.D.                                                                                                                                                               |  |
+| 4. Restricted Delivery? (Extra Fee) <input type="checkbox"/> Yes                                                                                                                                                                                                                                                                                                                                                                                  |  |
+| 2. Article Number (Transfer from service label) <span style="border: 1px solid black; padding: 5px;">7007 2640 0002 5519 8503</span><br>PS Form 3811, February 2004 <span style="float: right;">Domestic Return Receipt <span style="float: right;">102595-02-M-1540</span></span>                                                                                                                                                                |  |
+
+ 7007 2620 0002 5519 8503  
+ 7007 2640 0002 5519 8503  
+ 7007 2620 0002 5519 8503
+ 
+
+| <b>U.S. Postal Service</b><br><b>CERTIFIED MAIL RECEIPT</b><br><i>(Domestic Mail Only; No Insurance Coverage Provided)</i>                                  |                  |
+|-------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------|
+| For delivery information visit our website at <a href="http://www.usps.com">www.usps.com</a>                                                                |                  |
+| <b>OFFICIAL USE</b>                                                                                                                                         |                  |
+| Postage \$<br>Certified Fee<br>Return Receipt Fee<br>(Endorsement Required)<br>Restricted Delivery Fee<br>(Endorsement Required)<br>Total Postage & Fees \$ | Postmark<br>Here |
+| Sent To<br>Street Apt. No.<br>or PO Box No.<br>City, State, ZIP 4                                                                                           |                  |
+| PS Form 3800, August 2006 <span style="float: right;">See Reverse for Instructions</span>                                                                   |                  |

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marker2/court-doe-v-us/EFTA02752810/EFTA02752810.md

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+![](_page_0_Picture_2.jpeg)
+
+AND ASSOCIATES
+
+July 3, 2008
+
+Anna C. Villafana, AUSA United States Attorney's Office 500 South Australian Avenue West Palm Beach, Florida 33401
+
+Dear Ms. Villafana:
+
+VIA CERTIFIED MAIL RETURN RECEIPT REQUESTED 7007 2680 0002 5519 8503
+
+As you are aware, we represent several of the young girls that were victimized and abused by Jeffrey Epstein. While we are aware of his recent guilty plea and conviction in his State Court case, the sentence imposed in that case is grossly inadequate for asexual predator of this magnitude. The information and evidence that has come to our attention in this matter leads to <sup>a</sup>grave concern that justice will not be served in this cause if Mr. Epstein is not aggressively prosecuted and appropriately punished. Based on our investigation and knowledge of this case, it is apparent that he has sexually abused more than 100 underage girls, and the evidence against him is overwhelmingly strong.
+
+As former Assistant State Attorneys with seven years' prosecution experience, we believe that the evidence against Mr. Epstein is both credible and deep and that he may be the most dangerous sexual predator of children that our country has ever seen. The evidence suggests that for at least 4 years he was sexually abusing as many as three to four manipulate <sup>g</sup>irls a day. It is inevitable that if he is not confined to prison, he will continue to and sexually abuse children and destroy more lives. He is asexual addict that focused all of his free time on sexually abusing children, and he uses his extraordinary wealth and power to lure in poor, underprivileged little girls and then also uses his wealth to shield himself from prosecution and liability. We are very concerned for the health and welfare of the girls he has already victimized, and concerned that if justice is not properly served now and he is not imprisoned for <sup>a</sup>very long time, he will get a free pass to sexually abuse children in the future. Future abuse and victimization is obvious to anyone who really reviews the evidence in this case, and future sexual abuse of minors is inevitable unless he is prosecuted, tried and appropriately sentenced. Money and power should not allow <sup>a</sup>man to make his own laws, and he has clearly received preferential treatment at every step up to this point. If he were a man of average wealth or the abused girls were from middle or upper class families, then this man would spend the rest of his life in prison. In acountry of true, blind justice, those distinctions are irrelevant, and we really hope he does not prove the point that <sup>a</sup>man can commit heinous crimes against children and buy his way out of it.
+
+If the Department of Justice's recent commitment to the protection of our children from child molesters is to be more than rhetoric, then this is the time and the case where the Department must step forward. We urge the Attorney General and our United States
+
+OFFICE, 954-414-8033/305-935-2011 FAX: 954-924-1530/305-935-4227 BEORRADEDWARDSLAW.00M
+
+Ann [REDACTED] C. Villafana, AUSA  
+United States Attorney's Office  
+Page Two
+
+Attorney to consider the fundamental import of the vigorous enforcement of our Federal laws. We urge you to move forward with the traditional indictments and criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take the steps necessary to protect our children from this very dangerous sexual perpetrator. We will help you to do this in any way possible to ensure that true Justice is served in this case.
+
+Sincerely,
+
+![]()Brad [REDACTED], Esquire  
+Jay Howell, Esquire
+
+---
+
+OFFICE: 954-414-8033/305-935-2011  
+FAX: 954-924-1530/305-935-4227  
+BE@BRADEDWARDSLAW.COM