MEMY-1805 harvest: vision-joined (part 65)

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vision-joined/ds9-unparsed-06/bb86f207192ddbd439b9940c03f9381b62ecdde75bb6b446a630f181f780103b.md

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+From:
+To:
+Subject: Activity in Case 9:08-cv-80119-KAM Doe |. Epstein Appeal of Magistrate Judge Decision to
+District Court
+Date: Thu, 18 Mar 2010 23:15:43 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered by Mermelstein, Stuart on 3/18/2010 at 7:15 PM EDT and filed on
+3/18/2010
+Case Name:
+Case Number:
+Filer:
+Doe | Epstein
+9:08-cv-80119-KAM
+Jane Doe
+Document Number: 493
+Docket Text:
+APPEAL OF MAGISTRATE JUDGE DECISION to District Court by Jane Doe re [480] Order on
+Motion to Compel (Mermelstein, Stuart)
+9:08-cv-80119-KAM Notice has been electronically mailed to:
+Adam D. Horowitz
+Bradley James Edwards
+Isidro Manuel Garcia
+Jack Alan Goldberger
+Jack Patrick Hill
+Jeffrey Mare Herman
+Katherine Warthen Ezell
+EFTA00207130
+
+Michael James Pike
+Paul G. Cassell
+Richard Horace Willits
+Robert C. Josefsberg
+Robert Deweese Critton, Jr
+Stuart S. Mermelstein
+9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+The following documents) are associated with this transaction:
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=3/18/2010] [FileNumber=7376775-0
+] [2d42472d27f2b9758b5378dec54ddb647a009a1512f893858ea5162f42e0aa0f35a
+9bbd22d09bбc283ab9ea096e15cf1885813fe8d2720fb63d3aedfd9d90826]]
+EFTA00207131

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vision-joined/ds9-unparsed-06/bbca051c0e5dbf55b257bc8361a11a76bd2c5b0eb25373a0e1977171604c64ad.md

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+To: Paul Cassell <cassellp@law.utah.edu>, Brad Edwards <bedwards@pathtojustice.com>
+Subject: Replies and Responses Due on January 6, 2012
+Date: Fri, 06 Jan 2012 00:23:38 +0000
+Importance: Normal
+Paul and Brad,
+appy New Year. I need to ask if you have an objection to the government seeking a second enlargement of time, up t
+uesday, January 24, 2012, to file replies to the victims' two responses to the government's motion to dismiss and motio
+to stay discovery, and responses to the victims' protective motion to compel and protective motion for remedies.
+] is preparing for an evidentiary hearing in a 28 U.S.C. 2255 motion, which is scheduled for January 24, 2012. 1 am
+scheduled to go to trial in a tort case sometime during the two week trial period commencing January 17, 2012. I have
+spent most of the preceding two weeks getting ready for the trial. My colleague Ed Sanchez, with sporadic assistance
+from
+and I, will be preparing the responses and replies.
+Please let me know if you have any objections. Thanks.
+EFTA00204920

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vision-joined/ds9-unparsed-06/bbdab5fa8579617ac2960b55c3f403fc752a793803d805b912d167175e3392d0.md

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+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOES #1 and #2
+UNITED STATES
+JANE DOE #1 AND JANE DOE #2'S STATUS REPORT AND RESPONSE TO
+COURT'S ORDER TO SHOW LACK OF PROSEUCTION
+Jane Doe #1 and Jane Doe #2 (*the victims"), through counsel, file the response to
+Court's order to file a status report and show cause regarding prosecution of the case (doc. #40).
+BACKGROUND
+As the Court is aware, it entered an order administratively closing this case on September
+9, 2010 (doc. #38). That order recited that fact that Jane Doe #1 and Jane Doe #2 had recently
+settled their civil cases with Jeffrey Epstein as the basis for closure. On September 13, 2010, the
+victims promptly filed a notice that, while they had settled their case with Jeffrey Epstein, they
+had reached no settlement with the U.S. Attorney's Office and intended to make filings in this
+case shortly (doc. #39). The victims requested administrative reopening of the case and, if the
+Court deemed it advisable, a prompt scheduling conference with the U.S. Attorney's Office
+regarding the case. The victims also advised that they had only recently received important
+correspondence between the U.S. Attorney's Office and the Epstein proving that there had been
+an orchestrated decision to deny them their rights.
+On October 8, 2010, the Court entered an order directing the victims to file a status report
+and show cause why the case should not be dismissed for want of prosecution.
+1
+EFTA00206717
+
+STATUS REPORT
+As the Court is aware from the victims' filing on September 13, 2010 (doc. #39, the
+victims have now received important evidence that allows them to file a comprehensive motion
+explaining the factual background underlying the denials of their rights under the Crime Victims
+Rights Act and the legal reasons for concluding that their rights under the Act have been
+violated. The victims prepared a full motion to that effect - accompanied by a detailed factual
+and legal memorandum. They planned to file the motion and memorandum simultaneously with
+this pleading. The motion looks something like a summary judgment motion, although the exact
+procedures for CVRA cases are unclear.
+In an effort to narrow and resolve disputes in this case, the victims then provided an
+advance copy of their factual and legal pleadings to the U.S. Attorney's Office, along with a
+request that the U.S. Attorney's Office stipulate to as many facts as possible. The U.S.
+Attorney's Office then asked the victims to delay filing their pleading for a period up to and
+including two weeks from today to permit further discussions about the facts and about possible
+settlement of the disputes. The U.S. Attorney's Office represented that, from their perspective, if
+the victims were to file their pleadings today it would make it more difficult to reach a resolution
+of the case.
+In view of this request from the U.S. Attorney's Office, the victims have accordingly
+agreed to delay filing their comprehensive motion for a period of two weeks. In exchange, the
+U.S. Attorney's Office has agreed to stipulate that it has not been prejudiced by the passage of
+time involved in resolving this case and that it will not be prejudiced by an additional two weeks
+before the victims file their motion.
+2
+EFTA00206718
+
+The victims wish to make clear that they stand ready to file their comprehensive motion
+for a finding of violations of their rights in two weeks, on November 10, 2010. They are also
+prepared to make that filing in whatever form the Court might direct as the most appropriate to
+resolve this case quickly.
+It should be noted that the victims' motion will ask for an evidentiary hearing if the facts
+are disputed by the U.S. Attorney's Office. Before filing the motion, the victims had also sent a
+copy of the facts to the U.S. Attorney's Office in an effort to obtain their agreement to them and
+to expedite the case. (As the Court is aware from the victims" earlier filing, the victims
+attempted to negotiate a stipulated set of facts with the U.S. Attorney's Office, only to be
+rebuffed by the U.S. Attorney's Office. See doc. #17 (U.S. Attorney giving "notice" that only
+two facts are relevant to this case and declining to provide information on other facts in the
+case); doc. #19 (victims response); doc. #22 (U.S. Attorney's reply).) The parties jointly advise
+the Court that they believe that two weeks of discussions may narrow the issues on which the
+victims would request an evidentiary hearing. The U.S. Attorney's Office, at this time, opposes
+any evidentiary hearing.
+If no resolution of the case is achieved in the next two weeks, the victims would propose
+the following schedule for bringing this case to a conclusion:
+November 10, 2010 - Victims file comprehensive motion.
+November 24, 2010 -- U.S. Attorney's Office files response to the victims' motion.
+December 3, 2010 - Victims' file Reply to Response.
+Evidentiary Hearing (if facts contested) - early December, at a time convenient to the Court.
+January 1, 2011 - Court issues ruling on whether victims' rights were violated.
+If the Court enters a finding that the victims' rights were violated, then ....
+January 14, 2011 - Victims brief on the appropriate remedy for a violation;
+January 28, 2011 - U.S. Attorney's Office (and any other interested person) files response to
+victims' remedy brief.
+February 4, 2011 - Victims reply on remedy issues.
+Hearing if necessary - mid-February, at a time convenient to the Court.
+3
+EFTA00206719
+
+This proposed schedule would allow Jane Doe #1 and Jane Doe #2 to have their case
+fully resolved on the merits within the next few months. The victims would have no objection to
+the Court accelerating the schedule. The U.S. Attorney's Office agrees that this schedule is
+appropriate to resolve the victims' motion, although it may have additional motions and
+arguments it wishes to file as well.
+THE CASE SHOULD NOT BE DISMISSED FOR LACK OF PROSECUTION
+Jane Doe #1 and Jane Doe #2 should not have their case dismissed for lack of prosecution
+for the simple reason that they have not failed to prosecute it. To the contrary, as recounted more
+fully in the statement of facts contained in their contemporaneously filed motion for a finding of
+violation of their rights, they have been attempting to secure information that would help prove
+their case.
+The victims hereby expressly incorporate that statement of facts, and supporting
+evidence (particularly the Declaration from Bradley J. Edwards, Esq..) as part of this pleading.
+Although the victims rely on all of the information contained in the statement of facts, in
+the interest of a brief summary the victims would note that they have been diligently attempting
+to secure correspondence between Epstein and the U.S. Attorney's Office regarding the non-
+prosecution agreement reached in this case. After the U.S. Attorney's Office declined to provide
+the information, the victims sought to secure that information as part of their civil lawsuits
+against Epstein. This was because of a reasonable legal judgment that the victims' counsel that it
+was in their best interest to pursue the civil lawsuit against Epstein had a faster pace. Because of
+protracted litigation from Epstein's battery of lawyers, the vietims did not secure any of the
+correspondence they sought until June 30, 2010. Even then, they secured only part of that
+correspondence - litigation to secure the rest of that correspondence continues to this day. See
+4
+EFTA00206720
+
+Declaration of Bradley J. Edwards, Esq., Attachment to Jane Doe #1 and Jane Doe #2's Motion
+for Finding of Violations of the Crime Victims' Rights Act.
+The victims have also never been asked by the U.S. Attorney's Office to accelerate the
+resolution of this case.
+During the last year, the victims' counsel have been in contact with the
+U.S. Attorney's Office on numerous matters related to Jeffrey Epstein. At no time did the U.S.
+Attorney's Office ask the victims to begin moving more quickly to resolve this case. As noted
+above, the U.S. Attorney's Office agrees it has not been prejudiced by the passage of time that
+has taken place in the case so far.
+The victims would also note that the Court has never advised them of a deadline for
+moving forward with their CVRA case. The victims also knew that the Court was aware of the
+intense and protracted litigation what was proceeding with Epstein in the various civil cases
+against him. It seemed reasonable to the victim to resolve those cases first and then turn to the
+CVRA case - and the victims assumed that the Court was also proceeding on this approach, as
+the victims never received any inquiry from the Court about their CVRA case until the
+September 2010 order "administratively" closing the case. Within 5 days of receiving that
+communication from the Court, the victims promptly advised the Court of their intent to continue
+moving forward with the case and suggesting a scheduling conference if the Court deemed it
+advisable.
+The victims have now proposed a specific schedule that will bring this matter to a final
+conclusion in the next few months. There is no reason to dismiss the case precipitously now on
+the eve of a final resolution.
+The Eleventh Circuit has repeatedly noted that dismissal with prejudice is an "extreme
+sanction" and "is plainly improper unless and until the district court finds a clear record of delay
+5
+EFTA00206721
+
+or willful conduct and that lesser sanctions are inadequate to correct such conduct." Betty K
+Agencies, Ltd. |. M/ MONADA, 432 F.3d 1333, 1338-39 (11th Cir.2005). In this case, there is
+no clear record of delay or willful conduct. To the contrary, there is a pattern of the vietims
+diligently attempting to secure evidence (i.e., the correspondence) vital to their case in the face of
+determined opposition from both the United States and a billionaire sex offender represented by
+a battery of attorneys. The Eleventh Circuit has held that simple negligence in meeting a court-
+imposed deadline is not sufficient to warrant dismissal. See McKelvey I AT & T Techs., Inc., 789
+F.2d 1518, 1520 (11th Cir.1986) (per curiam). Here, there is not even negligence, as the victims
+have not failed to meet any deadline that the Court has set and today stand ready to bring the
+case to an expeditious conclusion on the schedule they propose. On September 13, 2010, the
+victims also suggested to the Court that a scheduling conference would be one way to proceed in
+this case - a suggestion that they continue to offer to the Court.
+CONCLUSION
+The Court should establish the schedule proposed by the victims and bring this case to a
+conclusion on the merits as the victims propose.
+DATED: October 27, 2010
+Respectfully Submitted,
+s/ Bradley J. Edwards
+Bradley J. Edwards
+P.L.
+6
+EFTA00206722
+
+Paul G. Cassell
+Pro Hac Vice
+Attorneys for Jane Doe #1 and Jane Doe #2
+7
+EFTA00206723
+
+CERTIFICATE OF SERVICE
+Epstein through current counsel.
+8
+EFTA00206724

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+From:
+(USAFLS)" <
+To:
+(USAFLS)" {
+Ce:'
+(USAFLS)" <
+Subject: RE: government position?
+Date: Fri, 03 Feb 2012 01:02:06 +0000
+Importance: Normal
+Yes. I will respond to Cassell. Have a good trip.
+From:
+(USAFLS)
+Sent: Thursday, February 02, 2012 7:55 PM
+To:
+(USAFLS
+Cc:
+1. (USAFLS)
+Subject: FW: government position?
+I don't know why he keeps sending these to me or leaving you off the emails. Can you respond? I will be
+traveling and at the Bar's Professional Ethics Committee meeting in Orlando tomorrow.
+Thanks,
+From: Paul Cassell [mailto:
+Sent: Thursday, February 02, 2012 7:43 PM
+To:
+Cc:
+(USAFLS); Brad Edwards
+(USAFLS)
+Subject: RE: government position?
+Hey
+Sorry to rush you, but following up on our email from a couple of days ago, Brad and I are hoping to file tomorrow
+(1) Our motion for order directing government to file redacted, unsealed pleadings in the public court file (all three of
+your sealed pleadings); and
+(2) A motion for the court to deny the motion to dismiss without requiring additional pleadings from us or, at a
+minimum, ti grant leave to file a sur-reply (we propose that our brief be of the same length as yours and due 4 weeks
+after the court rules on our motion (1) above).
+I know there may be a "clearance" process there on this case, but hoping you can give us a position by, say, noon Friday?
+Thanks in advance for your help.
+Paul Cassell
+Co-counsel for Jane Doe #1 and Jane Doe #2
+EFTA00204877
+
+Paul G. Cassell
+Ronald N. Boyce Presidential Professor of Criminal Law
+S.J. Quinney College of Law at the University of Utah
+Voice:
+Fax:
+Email:
+http://www.law.utah.edu/profiles/default.asp?PersonID=57&name=Cassell,Paul
+CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only
+for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended
+recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error,
+please immediately notify the sender by reply electronic mail and delete the original message. Thank you.
+From:
+I. (USAFLS) [mailto:
+Sent: Friday, January 27, 2012 5:14 PM
+To: Paul Cassell; Brad Edwards
+Cc:
+(USAFLS)
+Subject: Reply re Motion to Dismiss
+Hi Paul and Brad - I apologize, I didn't get
+email because I have been in trial prep. Here is the reply
+without the attachments. Brad should have received the complete documents today in the mail. The attachments
+are the complaints and amended complaints from the E. W. and L.M. state court litigation.
+I have encrypted the file because of the 6(e) material. I will send the password to Brad separately. Paul - if you
+want to give me a number where I can send you a text, I can text to you or leave you a voicemail with the
+password.
+Assistant U.S. Attorney
+Fax
+EFTA00204878

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vision-joined/ds9-unparsed-06/bc1697d115569a1dd79602db6981b801e97879c5b927bbef5601a4bfa9ca3e9b.md

@@ -0,0 +1,536 @@
+STATEMENT OF FACTS
+Jane Doe #1 and Jane Doe #2 offer the following statement of facts, which they are
+prepared to establish at any evidentiary hearing that the Court might schedule.
+1. Between about 2003 and 2006, defendant Jeffrey Epstein (a billionaire with significant
+political connections) sexually abused more than 40 minor girls at his mansion in West Palm
+Beach, Florida, and elsewhere.
+2. 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, among 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. See Declaration of Bradley J. Edwards, Esq. at 1
+(hereinafter "Edwards Declaration"). The Palm Beach County State Attorney's Office was
+investigating the case. Edwards Declaration at 1.
+3. The FBI determined that both Jane Doe #1 and Jane Doe #2 were victims of sexual assaults
+by Epstein while they were minors beginning when they were approximately thirteen years of
+age and approximately XXXXx years of age. Both Jane Does were initially identified through the
+Palm Beach Police Department's investigation of Epstein. Edwards Declaration at 1.
+4. On about June 7, 2007, FBI agents hand-delivered to Jane Doe #1 a standard CVRA victim
+notification letter.
+See Doc. #14 (attachment 1 to decoration al A Alone
+The
+notification promises that the Justice Department would makes its "best efforts" to protect Jane
+Doe #1's rights, including "[t]he reasonable right to confer with the attorney for the United
+States in the case" and "to be reasonably heard at any public proceeding in the district court
+EFTA00206695
+
+involving ... plea ...." The notification further explained that "[alt this time, your case is
+under investigation." That notification meant that the FBI had identified Jane Doe #1 as a victim
+of a federal offense and therefore as someone protected by the CVRA
+5. On about August 11, 2007, Jane Doe #2 received a standard CVRA victim notification letter.
+See Doc. #14 (attachment 2 to declaration of A. Marie
+The notification promises that
+the Justice Department would makes its "best efforts" to protect Jane Doe #1's rights, including
+"[t]he reasonable right to confer with the attorney for the United States in the case" and "to be
+reasonably heard at any public proceeding in the district court involving •.• plea ...." The
+notification further explained that "[a]t this time, your case is under investigation." That
+notification meant that the FBI had identified Jane Doe #2 as a victim of a federal offense and
+therefore as someone protected by the CVRA.
+6. Early in the investigation, the FBI agents and the Assistant U.S. Attorney had several
+meetings with Jane Doe #1. Jane Doe #2 was represented by counsel and, accordingly, all
+contact was made through that attorney. Edwards Declaration at 1.
+7. In May 2007, the U.S. Attorney's Office had a 82-page prosecution memorandum outlining
+numerous federal sexual offenses committed by Epstein, and had prepared a 53-page indictment
+for numerous federal offenses. U.S. Attorney's Correspondence at 4.
+In and around September 2007, plea discussions took place between Jeffrey Epstein,
+represented by numerous attorneys (including lead criminal defense counsel Jay Lefkowitz) and
+the U.S. Attorney's office for the Southern District of Florida, represented primarily by Assistant
+U.S. Attorney A. Marie
+The plea discussions generally began from the premise that
+Epstein would plead guilty at least one federal felony offense surrounding his sexual assaults of
+more than 40 minor girls. From there, the numerous defense attorneys progressively and
+EFTA00206696
+
+relentlessly negotiated more favorable plea terms so that Epstein would ultimately plead to only
+two misdemeanor offenses and would serve only jail time. Many of the negotiations are
+reflected in e-mails between Lefkowitz and
+Copies of the correspondence are attached as
+Exhibit 2 to the Edwards Declaration accompanying this filing (hereinafter cited as "U.S. Attorney's
+Correspondence" and referenced by Bates number stamp).' Because Epstein has moved to keep these
+documents under seal, they are at this time filed under seal with the Court.
+9.
+In September 2007, in connection with plea discussions about a possible federal assault
+charges against Epstein, Assistant U.S. Attorney (AUSA) A. Marie
+proposed that
+Epstein plead to an assault charge involving a telephone call made by Epstein while he was on
+his private jet. During the telephone call, Epstein warned his personal assistant, Lesley Groff,
+against turning over documents and electronic evidence responsive to a subpoena issued by a
+federal grand jury in the Southern District of Florida investigating Epstein's sex offenses. U.S.
+Attorney's Correspondence at 49, 58.
+10. The correspondence also shows that AUSA
+was interested in finding a place to
+conclude a plea bargain that would effectively keep the victims from learning what was
+happening through the press.
+She wrote in an e-mail to defense counsel: "On an avoid the
+press' note, I believe that Mr. Epstein's airplane was in Miami on the day of the Ms. Groff
+telephone call. If he was in Mimi-Dade County at the time, then I can file the charge in the
+District Court in Miami, which will hopefully cut the press coverage significantly." U.S.
+Attorney's Correspondence at 29. Ms.
+was aware that most of the victims of Epstein,
+• Through diligent efforts, counsel for Jane Doe #1 and Jane Doe #2 received copies of half of the e-mail
+correspondence (the half reflecting
+communications to defense counsel) on about June 30,
+2010.
+EFTA00206697
+
+including Jane Doe #1 and Jane Doe #2, resided in the West Palm Beach area rather than the
+Miami area.
+11. On about September 24, 2007, Assistant U.S. Attorney A. Marie
+sent an e-mail to
+Jay Lefkowitz, criminal defense counsel for Epstein, regarding the agreement. The e-mail stated
+that the Government and Epstein's counsel would negotiate between themselves about what
+information would be disclosed to the victims about the agreement:
+Thank you, Jay.
+I have forwarded your message only to Alex [Acosta], Andy,
+and Roland. I don't anticipate it going any further than that. When I receive the
+originals, I will sign and return one copy to you. The other will be placed in the
+case file, which will be kept confidential since it also contains identifying
+information about the girls.
+When we reach an agreement about the attorney representative for the girls, we
+can discuss what I can tell him and the girls about the agreement. I know that
+Andy promised Chief Reiter an update when a resolution was achieved. ...
+Rolando is calling, but Rolando knows not to tell Chief Reiter about the money
+issue, just about what crimes Mr. Epstein is pleading guilty to and the amount of
+time that has been agreed to. Rolando also is telling Chief Reiter not to disclose
+the outcome to anyone.
+U.S. Attorney's Correspondence at 153 (emphases added).
+12. On about September 25, 2007, AUSA
+send an e-mail to Lefkowitz stating: "And
+can we have a conference call to discuss what I may disclose to .... the girls regarding the
+agreement." U.S. Attorney's Correspondence at 156.
+13. On about September 26, 2007, AUSA.
+sent an e-mail to Lefkowitz in which she
+stated: "Hi Jay - Can you give me a call at 561 209-[xxxx] this morning? I am meeting with the
+agents and want to give them their marching orders regarding what they can tell the girls." U.S.
+Attorney's Correspondence at xxxxx. The reasonable inference is that the "marching orders"
+agreed to between the Government and Epstein's defense counsel was that no mention would be
+EFTA00206698
+
+made of the non-prosecution agreement between the U.S. Attorney's Office and Epstein, as no
+subsequent mention was made to the victims of the non-prosecution agreement.
+14.
+On about September 27, 2007, Assistant U.S. Attorney A. Marie
+revealed to an
+attorney (Bert Ocariz), who was under discussion to be a representative of victims of Epstein's
+sexual abuse, that a non-prosecution agreement was in the process of being reached with Epstein.
+The e-mail stated: "Bert's firm has raised a number of good questions about how they are going
+to get paid." U.S. Attorney's Correspondence at 161. The e-mail went on to state: "I told Bert
+that as part of our agreement we (the federal government) are not going to indict Mr. Epstein, but
+him an idea of the charged that we had planned to bring as related to 18 USC 2255." Id. The e-
+mail also asked permission from Epstein's counsel to send to Ocariz a copy of parts of the plea
+agreement: "With respect to question 2 [a question from Ocariz regarding "[w]hen will it be
+possible to see the plea agreement so that we understand exactly what Epstein concedes to in the
+civil case?], do I have your permission to send Bert just that section of the plea agreement that
+applies to the damages claims (I would recommend sending paragraphs 7 through 10, or at least
+7 and 8)?" Id.
+15. In a letter later sent by Jay Lefkowitz to the U.S. Attorney for the Southern District of
+Florida, Lefkowitz stated that ASUA
+had "assiduously" hidden from him the fact that
+Bert Ocariz was a friend of
+• boyfriend. U.S. Attorney's Correspondence at 267.
+Lefkowitz also stated that
+had misleadingly used the term "friend" rather than the more
+accurate term "boyfriend" to describe the connection. Id. at 268 Lefkowitz further stated the
+boyfriend had a business relationship with Ocariz and that the boyfriend would have
+financially benefitted from the presumably lucrative referral of sexual assault cases against
+Epstein to Ocariz. On December 13, 2007,
+wrote a letter to Lefkowitz to deny these
+EFTA00206699
+
+accusations. In the letter,
+stated: "... I am surprised by your allegations regarding my
+role because I thought that we had worked very well together in resolving this dispute. I also am
+surprised because I feel that I bent over backwards to keep in mind the effect that the agreement
+would have on Mr. Epstein and to make sure that you (and he) understood the repercussions of
+the agreement." Id.
+16.
+On about September 24, 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. Epstein and the U.S. Attorney's Office accordingly entered into a "Non-
+Prosecution Agreement" (NPA) reflecting their agreement. Most significantly, the NPA gave
+Epstein a promise that he would not be prosecuted for a series of federal felony offenses
+involving his sexual abuse of more than 30 minor girls. The NPA instead allowed Epstein to
+plead guilty to two state felony offenses for solicitation of prostitution and procurement of
+minors for prostitution. The NPA also set up a procedure whereby a victim of Epstein's sexual
+abuse could obtain an attorney to proceed with a civil claim against Epstein, provided that the
+victim agreed to proceed exclusively under 18 U.S.C. § 2255 (i.e., provided that the victim
+agreed to seek no more than $150,000 in damages against Epstein). See Affidavit of Bradley J.
+Edwards, Attachment xxxxxx (copy of the non-prosecution agreement). The agreement was
+signed by Epstein and his legal counsel, as well as the U.S. Attorney's Office, on about
+September 24, 2007.
+17. A provision in the non-prosecution agreement made the agreement secret. In particular, the
+agreement stated: "The parties anticipate that this agreement will not be made part of any public
+record.
+If the United States receives a Freedom of Information Act request or any compulsory
+process commanding the disclosure of the agreement, it will provide notice to Epstein before
+EFTA00206700
+
+making the disclosure." See Edwards Declaration, Exhibit xxx (copy of the non-prosecution
+agreement), at &13.
+By entering into such a confidentiality agreement, the U.S. Attorney's
+Office put itself in a position notifying the crime victims (including Jane Doe #1 and Jane Doe
+#2) of the non-prosecution agreement would violate terms of the agreement - specifically the
+confidentiality provision. Accordingly, from September 24, 2007 through at least June 2008 - a
+period of more than nine months -- the U.S Attorney's Office did not notify any of the victims of
+the existence of the non-prosecution agreement.
+18. A reasonable inference from the evidence is that the U.S. Attorney's Office wanted the non-
+prosecution agreement kept from public view because of the intense public criticism that would
+have resulted from allowing a billionaire who had sexually abused more than 40 minor girls to
+escape from federal prosecution with only a county court jail sentence and because of the
+possibility that the victims could have objected to the agreement in court and prevented its
+consummation.
+19. The Non-Prosecution Agreement that had been entered into between the U.S. Attorney's
+Office and Epstein was subsequently modified by an October 2007 Addendum and a December
+19, 2007, letter from the U.S. Attorney to Attorney Lilly Ann Sanchez. See Supplemental
+Declaration of A. Marie
+doc. #35, at 1; U.S. Attorney's Correspondence at 234-37.
+The U.S. Attorney's Office did not notify any of the victims of the existence of these
+modifications of the agreement through at least June 2008 - a period of more than six months.
+On about August 14, 2008, Epstein's defense counsel told the U.S. Attorney's Office that they
+did not consider the December 19, 2007, letter to be operative. Id.
+20.
+In October 2007, shortly after the initial plea agreement was signed, Jane Doe #1 was
+contacted to be advised regarding the resolution of the investigation. On October 26, 2007,
+EFTA00206701
+
+.. met in person with Jane Doe #1. The
+Special Agents explained 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, the Special Agents did
+not explain that an agreement had already been signed that precluded any prosecution of Epstein
+for federal charges.
+The agents could not have revealed this part of the non-prosecution
+agreement without violating the terms of the non-prosecution agreement. Whether the agents
+themselves had been informed of the existence of the non-prosecution agreement by the U.S.
+Attorney's Office is not certain. Because the plea agreement had already been reached with
+Epstein, the agents made no attempt to secure Jane Doe #1's view on the proposed resolution of
+the case. Edwards Declaration at xxxxxx.
+21.
+Jane Doe #1'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. Edwards Declaration at xxxxxx.
+22.
+On about November 27, 2007, Assistant U.S. Attorney L SC
+sent an e-mail to Jay
+Lefkowitz, defense counsel for Epstein. The e-mail stated:
+The United States has a statutory obligation (Justice for All Act of 2004) to notify
+Lomorrow will make one full week since you were formally notified of the
+election. I must insist that the vetting process come to an end. Therefore, unles
+by COB tomorrow, I will simultaneously send you a draft of the letter. I intend to
+notify the victims by letter after COB Thursday, November 29th.
+U.S. Attorney's Correspondence at 255.
+EFTA00206702
+
+23. On about November 29, 2007, Assistant U.S. Attorney A. Marie
+sent a draft of a
+crime victim notification letter to Jay Lefkowitz, defense counsel for Jeffrey Epstein. The
+notification letter explained: "I am writing to inform you that the federal investigation of Jeffrey
+Epstein has been completed, and Mr. Epstein and the U.S. Attorney's Office have reached an
+agreement containing the following terms ...." The letter then went on to explain that Epstein
+would plead guilty to two state offenses and receive an 18 month sentence. The letter did not
+explain that, as part of the agreement with Epstein, the Justice Department was agreeing not to
+prosecute Epstein for any of the numerous federal offenses that had been committed. U.S.
+Attorney's Correspondence at 256-59.
+24. Apparently because of concerns from Epstein's attorneys, the U.S. Attorney's Office never
+sent the proposed victim notification letter discussed in the previous paragraph to the victims.
+Instead, a misleading letter stating that the case was "currently under investigation" (described
+below) was sent in January 2008. At no time before reaching non-prosecution agreement did the
+Justice Department contact any victims, including Jane Doe #1, about their views on the non-
+prosecution.
+25. On about December 6, 2007, Jeffrey H. L
+, First Assistant U.S. Attorney sent a letter to
+Jay Lefkowitz, noting the U.S. Attorney's Office's legal obligations to keep victims informed of
+the status of plea negotiations with Epstein. The letter stated:
+Finally, let me address your objections to the draft Vietim Notification Letter.
+You write that you don't understand the basis for the Office's belief that it is
+appropriate to notify the victims. Pursuant to the "Justice for All Act of 2004,
+[another name from the CVRA] crime victims are entitled to: "The right to
+inasrine, crue an he mily not to be excluded rom any sech eding court
+EFTA00206703
+
+crime victims are notified of, and accorded, the rights described in subection (a)."
+18 U.S.C. § 3771(c)(1)....
+Our Non-Prosecution Agreement resolves the federal investigation by allowing
+Mr. Epstein to plead to a state offense. The victims identified through the federal
+investigation should be appropriately informed, and our Non-Prosecution
+Agreement does not require the U.S. Attorney's Office to forego its legal
+obligation.
+U.S. Attorney's Correspondence at 191-92.
+26. Despite this recognition of its obligation to keep victims "appropriately informed" about the
+non-prosecution agreement, the U.S. Attorney's Office did not follow through and inform the
+victims of the non-prosecution agreement. To the contrary, as discussed below, it continued to
+tell the victims that the case was "under investigation." Edwards Declaration at xxxxxxx.
+27. On December 13, 2007, A. Marie
+sent a letter to Jay Lefkowitz, defense
+counsel for Epstein, rebutting charges that had apparently been made against her by the Epstein
+defense. The letter stated that a federal indictment against Epstein "was postponed for more than
+five months to allow you and Mr. Epstein's other attorneys to make presentations to the Office to
+convince the Office not to prosecute." The letter also recounted that "You and I spent hours
+negotiating the terms [of the non-prosecution agreement], including when to use 'a' versus "the'
+and other minutiae. When you and I could not reach agreement, you repeatedly went over my
+head, involving Messrs. Lourie, Menchel,
+, and Acosta in the negotiations at various
+times." U.S. Attorney's Correspondence at 269.
+28. The December 13, 2007, letter also reveals that the Justice Department stopped making
+victim notifications because of objections from Epstein's criminal defense counsel: "Three
+victims were notified shortly after the signing of the Non-Prosecution Agreement of the general
+terms of the Agreement. You raised objections to any victim notification, and no further
+notifications were done." U.S. Attorney's Correspondence at 270 (emphasis added).
+EFTA00206704
+
+29.
+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.
+See U.S. Attorney's Correspondence passim.
+30.
+On January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI
+advising them that "[t]his case is currently under investigation. This can be a lengthy process
+and we request you continued patience while we conduct a thorough investigation." See Doc.
+#14 (attachments 3 and 4 to declaration of A. Marie l
+) (emphasis added). The statement
+in the notification letter was false. The case was not currently "under investigation." To the
+contrary, the case had been resolved by the non-prosecution agreement entered into by Epstein
+and the U.S. Attorney's Office discussed previously. Moreover, the FBI did not notify Jane Doe
+#1 or Jane Doe #2 that a plea agreement had been reached previously, and that part of the
+agreement was a non-prosecution agreement with the U.S. Attorney's Office for the Southern
+District of Florida. Edwards Declaration at xxxx.
+31.
+In early 2008, Jane Doe #1 and Jane Doe #2 came to believe that criminal prosecution
+of Epstein was extremely important. The also desired to be consulted by the FBI and/or other
+representatives of the federal government about the prosecution of Epstein. In light of the letters
+that they had received around January 10, they believed that a criminal investigation of Epstein
+was on-going and that they would be contacted before the federal government reached any final
+resolution of that investigation. Edwards Declaration at xxxx.
+32.
+On about February 25, 2008, Assistant U.S. Attorney Jay
+sent an e-mail to Jay
+Lefkowitz, Epstein's criminal defense counsel, explaining that the Justice Department's Child
+Exploitation Obscenity Section (CEOS) had agreed to review Epstein's objections to the
+proposed plea agreement that had been reached with the U.S. Attorney's Office for the Southern
+EFTA00206705
+
+District of Florida. The letter indicated that, should CEOS reject Epstein's objections to the
+agreement, then "Mr. Epstein shall have one week to abide by the terms and conditions of the
+September 24, 2007 Agreement as amended by letter from United States Attorney Acosta to Jay
+Lefkowitz." U.S. Attorneys Correspondence at 290-91.
+33.
+In about April 2008, 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. Marie
+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. AUSA
+secured pro bono
+counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in
+Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms.
+Garvin was not advised that a non-prosecution agreement had been reached in this matter.
+34.
+In mid-June 2008, Mr. Edwards contacted AUSA
+to inform her that he
+represented Jane Doe #1 and, later, Jane Doe #2. Mr. Edwards asked to meet to provide
+information about the federal crimes committed by Epstein, hoping to secure a significant federal
+indictment against Epstein. AUSA
+and Mr. Edwards discussed the possibility of
+federal charges being filed. At the end of the call, AUSA
+asked Mr. Edwards was
+asked to send any information that he wanted considered by the U.S. Attorney's Office in
+determining whether to file federal charges.
+Because of the confidentiality provision that existed
+in the plea agreement, Mr. Edwards was not informed that previously, in September 2007, the
+U.S. Attorney's Office had reached an agreement not to file federal charges.
+Mr. Edwards was
+also not informed that any resolution of the criminal matter was imminent. Edwards Declaration
+at xxxxxx.
+EFTA00206706
+
+35.
+On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA
+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
+and the Palm Beach Police Department attempted to
+provide notification to victims in the short time that Epstein's counsel had provided. Attorney
+Edwards was called to provide notice to his clients regarding the hearing. AUSA |
+did
+not tell Attorney Edwards that the guilty pleas in state court would bring an end to the possibility
+of federal prosecution pursuant to the plea agreement. Edwards Declaration at xxxxxx.
+36.
+On June 30, 2008, AUSA
+sent an e-mail to Jack Goldberger, criminal defense
+counsel for Epstein, that stated: "Jack: The FBI has received several calls regarding the Non-
+Prosecution Agreement. I do not know whether the title of the document was disclosed when the
+Agreement was filed under seal, but the FBI and our office are declining comment if asked."
+U.S. Attorney's Correspondence at 321.
+37.
+On July 3, 2008, Mr. Edwards sent to AUSA
+a letter. See Affidavit of Bradley
+J. Edwards, Esq., at xxxxxx (attachment 2). In the letter, Mr. Edwards indicated his client's
+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 necessary to protect our
+children from this very dangerous sexual predator." When Mr. Edwards wrote this letter, he was
+still unaware that a non-prosecution agreement had been reached with Epstein - a fact that
+continued to be concealed from him (and the victims) by the U.S. Attorney's Office. Mr.
+Edwards first saw a reference to the NPA on or after July 9, 2008, when the Government filed its
+EFTA00206707
+
+responsive pleading to Jane Doe's emergency petition. That pleading was the first public
+mention of the non-prosecution agreement and the first disclosure to Mr. Edwards (and thus to
+Jane Doe #1 and Jane Doe #2) of the possible existence of a non-prosecution agreement.
+Edwards Declaration at xxxx.
+38.
+On July 9, 2008, AUSA
+sent a victim notification to Jane Doe #1 via her
+attorney, Bradley Edwards, which is attached as Exhibit 6 to the
+Declaration. That
+notification contains a written explanation of some of the terms of the agreement between
+Epstein and the U.S. Attorney's Office. A full copy of the terms was not provided. 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. As a result, Jane Doe #2
+never received a notification a letter about the agreement. The notification did not mention the
+non-prosecution agreement with the U.S. Attorney's Office. Edwards Declaration at xxxx.
+39. On July 9, 2008, AUSA
+filed a sworn declaration with the Court in connection
+with the case (doc. #14). The declaration purported to recount limit parts of the non-prosecution
+agreement and stated that "these provisions were discussed" with several victims, including Jane
+Doe #1. Id. at 4.
+40.
+On July 11, 2008, the Court held a hearing on Jane Doe #1 and Jane Doe #2's Emergency
+Petition for Enforcement of Rights. During the hearing, the Government conceded that Jane Doe
+#1 and Jane Doe #2 were "victims" within the meaning of the Crime Victim's Rights Act. Tr. at
+14-15.
+41. During the July 11 hearing, the Court and the parties discussed the fact that the petition
+should not be treated as an "emergency" petition because there was not any particular rush to
+ruling on it. Tr. at 24-25.
+The Court further discussed a need to "hav[e] a complete record, and
+EFTA00206708
+
+this is going to be an issue that's ... going to go to the Eleventh Circuit, [s] it] may be better to
+have acomplete record as to what your position is and the 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 b[y] ear and make this into a more complete record for the
+court of appeals." Tr. at 25-26. (
+Counsel for Jane Doe #1 and Jane Doe #2 explained: " ...
+Your Honor is correct in stating that it is not an emergency and it doesn't need to happen today.
+And, I will confer with the government on this and if evidence needs to be taken, it [can] be
+taken at a later date. It doesn't seem like there will be any prejudice to any party [from delay]."
+Tr. at 26. The hearing concluded: "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." Tr. at 32. The Court then adjourned, taking
+the victims' petition under advisement.
+42. The U.S. Attorney's Office and the victims then attempted to reach a stipulated set of facts
+underlying the case. The U.S. Attorney's Office set a proposed set of facts, and the victims sent
+a counter-proposal. Rather than respond to the victims' proposal, however, the U.S. Attorney's
+Office suddenly reversed course. (Doc. #19 at 2). On July 29, 2008, it filed a Notice to Court
+Regarding Absence of Need for Evidentiary Hearing (doc. #17). The Government took the
+position that, because no federal criminal charges had been filed in the Southern District of
+Florida, no additional evidence was required to decide the petition before the Court.
+43. On August 1, 2008, Jane Doe #land Jane Doe #2 filed (doc. #19) a response to the
+Government's "Notice."
+In the response, Jane Doe #1 and Jane Doe #2 gave a proposed
+EFTA00206709
+
+statement of facts surrounding the case. The proposed statement of fact was based on the
+information available to the victims at that time. The proposed statement of facts highlighted the
+fact that the Government had signed a non-prosecution agreement containing an express
+confidentiality provision, which prevented the Government from disclosing the agreement to
+them and other victims. Id. at 5. The response also noted that the Court had taken the victims'
+petition under advisement. The response further noted that the Government had not attempted to
+work with the victims to draft a full set of undisputed facts and had refused the victims' efforts to
+obtain documents relevant to the case. Id. at 9. The victims response also requested that the
+Court direct the Government to confer with the victims regarding the undisputed facts of the
+case, produce the non-prosecution agreement at issue in the case, and produce an FBI Report of
+Interview with Jane Doe #1. The response also requested that the Court enter judgment for the
+victims' on their petition finding a violation of rights and schedule a hearing on the appropriate
+remedy. Id. at 14.
+44.On August 14, 2008, the Court held a hearing on the case. No schedule for further
+proceedings was established at that hearing.
+45. On October 9, 2008, Bradley J. Edwards, counsel for Jane Doe #1 and Jane Doe #2, sent a
+letter to counsel for the U.S. Attorney's Office in this case advising that two possibly false
+statements had been made to the Court in the July 9th sworn declaration of AUSA |
+See
+Oct. 9, 2008, Letter from Bradley J. Edwards to Marie
+at 1, Attachment xxxx to
+Edwards Declaration. First, while Ms.
+had described a term as being part of the plea
+agreement with Epstein, that term later became defunct, at least in the view of Epstein's
+attorneys (and apparently acceded to by the U.S. Attorney's Office). Second, Ms.
+had
+EFTA00206710
+
+said that "four victims [including C.W. - i.e., Jane Doe #1] were contacted and these provisions
+were discussed," it was not clear what provisions had in fact been discussed.
+46. On December 22, 2008, AUSA Marie l
+filed a supplemental affidavit, "correcting"
+the statement made in her July 8, 2008, declaration about the terms of the plea agreement (doc.
+#35). The supplemental affidavit stated that "part 3" of the agreement with defendant Epstein
+was, in the view Epstein' legal counsel no longer operative. The supplemental affidavit,
+however, did not clarify what terms of the agreement had been discussed.
+47. On April 9, 2009, counsel for Jane Doe #1 and Jane Doe #2 sent to the Court in this case
+(via the PACER system) a notice of a change of law firm affiliation. Doc. #37.
+48. In approximately May 2009, counsel for Jane Doe #1 and Jane Doe #2 propounded
+discovery requests in both state and federal civil cases against Epstein, seeking to obtain
+correspondence between Epstein and prosecutors regarding his plea agreement - information that
+the U.S. Attorney's Office was unwilling to provide to Jane Doe #1 and Jane Doe #2. Epstein
+refused to produce that information, and extended litigation to obtain the materials followed.
+Edwards Declaration at xxxxx.
+49. Because of this extended litigation, Jane Doe #1 and Jane Doe #2 did not have access to
+important correspondence demonstrating a violation of their rights until June 30, 2010. On that
+day, counsel for Epstein sent to Bradley J. Edwards, Esq., legal counsel for Jane Doe #1 and Jane
+Doe #2, approximately 358 pages of e-mail correspondence between his legal counsel and the
+U.S. Attorney's Office for the Southern District of Florida regarding the plea agreement that had
+been negotiated between them. See Attachment 1 to Edwards Aff. These e-mail disclosed for
+the first time the steps that had been taken by the U.S. Attorney's Office to avoid having the
+victims in the case learn about the non-prosecution agreement that had been reached between
+EFTA00206711
+
+Epstein and the Government.
+Litigation continues to this day to obtain the correspondence
+regarding
+the state prosecution and regarding
+what Epstein's attorneys said in the
+correspondence with the prosecutors. Edwards Declaration at xxxxxx.
+50. In mid-July 2010, Jane Doe #1 and Jane Doe #2 settled their civil lawsuits against Mr.
+Epstein. Notice of this fact was promptly provided to the Court. Edwards Declaration at xxx.
+51. On September 8, 2010, the Court entered an order stating that "[a]n examination fo the
+docket reveals that no activity has taken place in this case since April of 2009. In light of the
+underlying settlements between the victims and Mr. Epstein, it is hereby ordered and adjudged
+that this case is closed." Doc. #38.
+52. Promptly on the heels of this administrative order, on September 13, 2010, Jane Doe #1 and
+Jane Doe #2 filed a notice that they "intend to make subsequent filing in the case shortly. They
+accordingly request administrative reopening of the case and, if the Court deems it advisable, a
+scheduling conference with the U.S. Attorney's Office regarding the case." Doc. #39 at 1. They
+further advised the Court that their settlements with Jeffrey Epstein in no way affected "their
+determination to move forward with the above-captioned CVRA action against a different entity
+- the U.S. Attorney's Office for the Southern District of Florida." Id. at 2. The pleading further
+advised that "Tilf the Court wishes to proceed to an expeditious conclusion to this Case, Jane Doe
+#1 and Jane Doe #2 have no objection to the Court setting up an expedited schedule for
+proceeding on the case." Id. The pleading further advised that the reason the victims had not
+filed for summary judgment in the case was that they had been attempting to secure
+correspondence between the U.S. Attorney's Office and Epstein to corroborate their argument
+that the Office had violated their rights. They noted that they had just secured half of that
+EFTA00206712
+
+correspondence two months earlier.
+Id. at 2. The victim asked that, "if the Court deems it
+advisable, that a scheduling conference be set for this case."
+53. At all times material to this statement of facts, it would have been practical and feasible for
+federal government to inform Jane Doe #1 and Jane Doe #2 of the details of the proposed non-
+prosecution agreement with Epstein, including in particular the fact that the agreement barred
+any federal criminal prosecution. Edwards Declaration at xxxx.
+EFTA00206713

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vision-joined/ds9-unparsed-06/bc38f00047c403b6193697bdf66bdf1662ca13cac15693f75cfa2196478cade4.md

@@ -0,0 +1,62 @@
+From:
+To:
+Subject: Activity in Case 9:08-cv-80119-KAM Doe v. Epstein Motion to Compel
+Date: Wed, 10 Mar 2010 22:41:42 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer: PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. Distriet Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered by Edwards, Bradley on 3/10/2010 at 5:41 PM EST and filed on
+3/10/2010
+Case Name:
+Case Number:
+Filer:
+Document Number: 486
+Doe v. Epstein
+9:08-CV-80119-KAM
+Jane Doe
+Docket Text:
+Plaintiff's MOTION to Compel Production of FBI Records by Jane Doe. Responses due by
+3/29/2010 (Attachments: # (1) Text of Proposed Order)(Edwards, Bradley)
+9:08-cv-80119-KAM Notice has been electronically mailed to:
+Adam D. Horowitz
+Bradley James Edwards
+Isidro Manuel Garcia
+Jack Alan Goldberger
+Jack Patrick Hill
+Jeffrey Mare Herman
+Katherine Warthen Ezell
+EFTA00207115
+
+Michael James Pike
+Paul G. Cassell
+Richard Horace Willits
+Robert C. Josefsberg
+Robert Deweese Critton, Jr
+Stuart S. Mermelstein
+9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-
+Martin G. Weinberg
+20 Park Plaza
+Boston, MA 02116
+The following documents) are associated with this transaction:
+Document description:Main Document
+Original filename:/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=3/10/2010] [FileNumber=7345602-0
+][192fd039e889cb83796с85ca21a3f3fa10717efbef019c2ceb1580e6948ca70d6bd
+1bf789307d20360053a7090726ee58c44c4faae5eбa9e52609f877d7f3ebf]]
+Document description:Text of Proposed Order
+Original filename:n/a
+Electronic document Stamp:
+[STAMP dcecfStamp_ID=1105629215 [Date=3/10/2010] [FileNumber=7345602-1
+][3f87c4e5ceb71b58796d7aabfd8196с63641c075d0901722f8d93730fe046748bd0
+5f7c74837323b0af480393ac143c4811002c02c55d66e3e2d75c2368f72ec]]
+EFTA00207116

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vision-joined/ds9-unparsed-06/bc4cc0704cc0315f13d48cb1e6fd8f9f258ef6b105f34dc17cdd2bf7b3710109.md

@@ -0,0 +1,11 @@
+FEDERAL SENTENCING GUIDELINES CALCULATION
+(Using November 1, 2004 Guidelines Manual)
+Each count of §§ 1591, 2422(b) and 2423(b):
+Base Offense Level under 2G1.3: 24
+Offense involved sexual contact: +2
+26
+Counts do not group, so add 5 levels for more than 5 units, pursuant to 3D1.4
+Apply Repeat and Dangerous Sex Offender against Minors enhancement at 4B1.5
+Assuming Criminal History Category I, advisory guideline range is 188 - 235 months with lifetime supervised
+release.
+EFTA00204857

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vision-joined/ds9-unparsed-06/bc551b68637dee458f23ba6ce9fd58fb50555d881c1d8d29cd11b2a558a65f67.md

@@ -0,0 +1,196 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOE #1 and JANE DOE #2,
+Plaintiffs
+UNITED STATES,
+Defendants
+JANE DOE #1 AND JANE DOE #2'S SUPPLEMENTAL REQUEST
+FOR PRODUCTION TO THE GOVERNMENT REGARDING NEW INFORMATION
+CONCERNING INVESTIGATION OF HANDLING OF EPSTEIN NON-
+PROSECUTION AGREEMENT
+COME NOW Jane Doe #1 and Jane Doe #2 ("the victims), by and through undersigned
+counsel, and request the defendant United States (hereinafter "the Government") to produce the
+original or best copy of the items listed herein below for inspection and/or copying, pursuant to
+the Court's Order (DE 99) directing discovery in this case, the Court's Order denying the
+Government's motion to dismiss and lifting stay of discovery (DE 189), and the Court's
+Omnibus Order (DE 190):
+BACKGROUND
+As the Government will recall, the victims have repeatedly asked the Government to
+stipulate to undisputed facts in this case. The Government has declined. Accordingly, the
+victims filed their Motion for Finding of Violations of the Crime Victims" Rights Act and
+Request for a Hearing on Appropriate Remedies (DE 48) (the victims" "summary judgment
+motion") along with a Motion to Have Their Facts Accepted Because of the Government's
+Failure to Contest Any of the Facts (DE 49).
+EFTA00205316
+
+On September 26, 2011, the Court denied the victims' motion to have their facts accepted
+(DE 99 at 11). At the same time, however, the Court has ordered discovery to develop the
+factual record concerning the summary judgment motion (DE 99 at 11). The Court reserved
+ruling on the victims' motion for an order directing the Government not to suppress relevant
+evidence (DE 99 at 11).
+On September 28, 2011, the victims requested that the Government voluntarily provide
+documents concerning this case. The Government declined to provide even a single document.
+On October 3, 2011, the victims sent requests for production of documents relevant to
+this case.
+On November 8, 2011, the same day that the production of this discovery was due, rather
+than produce a single item of discovery or stipulate to a single fact, the Government filed a
+motion to dismiss the victims' case. The Government also filed an accompanying motion for a
+stay in this case.
+On November 8, 2011, the Government filed an ex parte, sealed motion to stay further
+discovery in this case. (DE 121). On November 9, 2011, the Court granted an ex parte, sealed
+order to stay. (DE 123).
+On December 5, 2011, the victims filed a response to Government's motion to stay. The
+victims strenuously objected to the Government's approach, alleging specifically that "delay
+appears to be the Government's motivation for filing the motion to dismiss." DE 129 at 2. The
+victims went on to recount the fact that the Government had waited three years to file a motion to
+dismiss, concluding that "as a practical matter, the Government's motion has had the desired
+effect of delay: While its motion remains pending, the victims have been effectively denied any
+ability to obtain discovery from the Government." DE 129 at 2-3. The victims also filed a
+EFTA00205317
+
+protection motion to compel (DE 130) asking that the Court direct the Government to produce
+the requested materials.
+On January 24, 2012, the Government filed a reply in support of its motion to stay. DE
+140. In that reply, the Government represented that it would voluntarily be providing
+information to the victims:
+"IT]he United States has agreed to provide some information to [the
+victims] even during the pendency of the stay and is undertaking a search for that
+information." DE 140 at 4. Contrary to that representation, however, over the next seventeen
+months, the Government did not provide any information to the victims.
+A year after the Government's motion to dismiss, on December 6, 2012, the victims filed
+a Motion for a Prompt Ruling Denying the Government's Motion for a Stay (DE 179). The
+motion explained that it had been more than a year since the Government had filed its motion for
+a stay and that the Government's refusal to produce any information continues to effective block
+the victims from learning what happened during the Government's plea negotiations with the
+man who sexually abused them. The Government filed a response in opposition to that motion
+(DE 182).
+On February 25, 2013, counsel for the victims sent a request to the Government that, in
+view of that fact that its requested stay had never been granted, it should begin fulfilling its
+court-ordered discovery obligations:
+The victims believe that in view of fact that it has been more than fifteen
+months since the Government filed its motion for a stay of discovery and yet the
+Court has not granted that motion, the Court's discovery order is in effect and
+controlling. Accordingly, the victims respectfully request that by March 8, 2013,
+the Government produce all of the materials which is covered by the victims'
+liscovery requests. If the Government has not produced those materials b
+March 8, 2013, the victims may be forced to seek the intervention of the Court t
+order the Government to follow its obligations.
+If you would like to discuss this further, please feel free to set up a time
+where we can talk to you over the phone about all this. We are happy to work
+EFTA00205318
+
+with you to try and minimize any unnecessary burden from your discovery
+obligations.
+E-mail from Paul G. Cassell & Bradley J. Edwards to Dexter Lee, et al., Counsel for the
+Government (February 25, 2013).
+The Government ignored the e-mail and did not respond in any way.
+Accordingly, in view of the Government recalcitrance and refusal to even discuss its
+discovery obligations, on March 14, 2013, the victims filed a motion to compel production of
+discovery materials. The Government did not respond to this motion.
+On June 1, 2013, the Court denied the Government's motion to dismiss. DE 189. That
+denial also lifted stay of discovery proceedings. DE 189 at 14 ("The stay of discovery pending
+ruling on the Government's motion to dismiss entered on November 8, 2011 [DE# 123] is also
+lifted."). The Court also entered an Omnibus Order (DE 190) that, among other things, granted
+the victim motion to compel (DE 130).
+SUPPLEMENTAL DISCOVERY REQUEST
+The victims now request one specific item of supplemental discovery relating to information
+that, in large measure, has come into existence since they filed the first request for production of
+documents on October 3, 2011:
+Jane Doe #1 and Jane Doe #2 have asked the Government to investigate their allegations that
+the U.S. Attorney's Office for the Southern District of Florida entered into a non-prosecution
+agreement with Jeffrey Epstein for sexual offenses committed against them and other victims
+based on considerations apart from the merits of the criminal case and also that violations of
+criminal law, rules of ethics, Justice Department policies (including policies on crime
+victims' rights), and the Crime Victims Rights Act occurred during the negotiations leading
+up to and surrounding the entry of the non-prosecution agreement. Please provide any
+information that the Government has developed concerning or relating to those allegations
+and the handling of the negotiations and consummation of the non-prosecution agreement,
+including any information developed by the Justice Department's Office of Professional
+Responsibility (OPR), the Federal Bureau of Investigation or other federal investigative
+entity, and any grand jury investigating these (or releated) allegations, including any grand
+jury meeting in the Southern District of Florida, the Middle District of Florida, the District of
+EFTA00205319
+
+New Jersey, and/or the District of Columbia. For this one discovery request only, please
+include all relevant grand jury transcripts and evidence collected by the grand jury.
+DEFINITIONS
+For the purpose of construing the foregoing discovery requests, the following terms are
+defined:
+The term "documents" means and includes, without limitation, all writings of any kind,
+including the originals and all non-identical copies or drafts, whether different from the original
+by reason of any notation made on such copy or draft or otherwise including, without limitation,
+correspondence, memoranda, notes, diaries, statistics, letters, e-mails, electronic computer files,
+telegrams, minutes, contracts, reports, studies, checks, statements, receipts, returns, summaries
+pamphlets, books, prospectuses, interoffice communications, offers, notations of any sort of
+conversation, telephone calls, meetings or other communications, bulletins, printed matter,
+computer print-outs, teletypes, facsimiles, invoices, work sheets and all dratts, alterations,
+modifications, changes, and amendments of any of the foregoing, graphic or aural writs, records
+or representations of any kind including, without limitation, photographs, charts, graphs,
+microfiche, microfilm, videotape, recordings, motion pictures; and electronic, mechanical or
+electric records or representations of any kind including, without limitation, tapes, cassettes and
+dise recordings, and writings and printed material of every kind.
+The term "correspondence" means any tangible object that conveys information or
+memorializes information that was conveyed in tangible or oral form including, but not limited
+to, writings, letters, memoranda, reports, notes, e-mails, telephone logs, telephone billing
+information, telephone recordings, and interoffice communications.
+The term "Epstein's victims" means any person that the Government identified as a
+possible victim of a sex offense committed by Jeffrey Epstein, including Jane Doe #1, Jane Doe
+#2, all victims identified in attachment to the non-prosecution agreement entered into by Epstein,
+and another person that the Government investigated as a possible victim of Epstein's sex
+offenses.
+The term "Government" means the federal government, including all employees of and
+components of the United States Department of Justice (such as, the Office of the Attorney
+General, the Office of the Deputy Attorney General, the Criminal Divisions, the Office of
+Professional Responsibility, the Child Exploitation and Obscenity Section, the U.S. Attorney's
+Offices for the Southern District and Middle District of Florida, and the Federal Bureau of
+Investigation) and other federal government agencies with law enforcement responsibilities
+related to the Epstein case (such as the Internal Revenue Service). This request for production
+seeks all documents, correspondence, and other information held by all of these entities,
+including all employees of and components of the Justice Department that worked on or were in
+any way involved the Epstein investigation and/or that possess information relevant to the
+victims' claims.
+The term "including" means containing within the request, but not limiting the request.
+EFTA00205320
+
+The term "witness statement" means any document or other recording in any form
+(including oral form) reflecting, recording, or otherwise memorializing a statement made or
+information conveyed by a potential witness, including for example FBI 302's.
+The term
+includes information collected by any law enforcement, prosecuting or government agency,
+including all federal, state, and local law enforcement agencies located in Washington, D.C., or
+PRIVILEGE LOG
+If you believe that any document, correspondence, or other information requested in this
+request is subject to a privilege and if you intend to assert that privilege, please provide a
+consistent with Local Rule 26.1(g), including a description a document that is
+consistent with Local Rule 26.1(g)(3)(B). Your privilege log should include the type of
+document, general subject matter of the document, date of the document, and author and
+addressee of the document or correspondence.
+REDUCING UNDUE BURDEN
+If you believe that complying with any of the foregoing requests would be unduly
+burdensomur please contact victims counsel - Bradley J. Edwards - to discuss ways to reduce
+DATED: June 24, 2013
+Respectfully Submitted,
+s/ Bradley J. Edwards
+Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+EDWARDS, FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+Telephone (954) 524-2820
+Florida BaD No: 54-2752
+E-mail: brad@pathtojustice.com
+and
+Paul G. Cassell
+Pro Hac Vice
+J. Quinney College of Law at th
+niversity of Uta
+332 S. 1400 E.
+EFTA00205321
+
+Salt Lake City, UT 84112
+Telephone: 801-585-5202
+Facsimile: 801-585-6833
+E-Mail: cassellp@law.utah.edu
+Attorneys for Jane Doe #1 and Jane Doe #2
+EFTA00205322

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+From:
+To:
+Subject: Activity in Case 9:08-cv-80232-KAM Doe No. 3 L. Epstein Order on Motion to Compel
+Date: Fri, 05 Feb 2010 14:59:30 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. Distriet Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered on 2/5/2010 at 9:59 AM EST and filed on 2/5/2010
+Case Name:
+Doe No. 3|. Epstein
+Case Number:
+9:08-cv-80232-KAM
+Filer:
+Document Number: 139
+Docket Text:
+ORDER Denying as Moot [51] Motion to Compel Answers To Interrogatories and Production of
+Documents. Signed by Magistrate Judge Linnea R. Johnson on 2/5/2010. (sa)
+9:08-cv-80232-KAM Notice has been electronically mailed to:
+Adam D. Horowitz
+Jack Alan Goldberger
+Jeffrey Mare Herman
+Michael James Pike
+Robert Deweese Critton, Jr
+Stuart S. Mermelstein
+9:08-cv-80232-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-
+EFTA00207084
+
+The following document(s) are associated with this transaction:
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=2/5/2010] [FileNumber=7230164-0]
+[6b75b07770e0eb45b8dda9091979920103e66df8824c9a096433c189b9e468401cbc
+8c2ae3a36e65c047b0347a8291b94f5a805913ede7fdf638dela228ce5e4]]
+EFTA00207085

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vision-joined/ds9-unparsed-06/bca1b334e538aa135b4f805d8f342bb805aec5f6262d4826711967d679cf6ea0.md

@@ -0,0 +1,63 @@
+From: "emecfautosender@flsd.uscourts.gov" <cmecfautosender@flsd.uscourts.gov>
+To: "flsd_cmecf_notice@flsd.uscourts.gov" <flsd_cmecf_notice@flsd.uscourts.gov>
+Subject: Activity in Case 9:08-cv-80119-KAM Doe |. Epstein Order on Motion for Leave to File Excess
+Pages
+Date: Mon, 05 Apr 2010 18:16:09 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered on 4/5/2010 at 2:16 PM EDT and filed on 4/5/2010
+Case Name:
+Doe | Epstein
+Case Number:
+9:08-CV-80119-KAM
+Filer:
+Document Number: 515
+Docket Text:
+ORDER granting [514] Motion for Leave to File Excess Pages. Signed by Judge Kenneth A.
+Marra on 4/5/2010. (ir)
+9:08-cv-80119-KAM Notice has been electronically mailed to:
+Adam D. Horowitz
+ahorowitz@sexabuseattorney.com
+Bradley James Edwards
+brad@pathtojustice.com. beth@pathtojustice.com
+Isidro Manuel Garcia
+isidrogarcia@bellsouth.net
+Jack Alan Goldberger
+jagesq@bellsouth.net, nalanis@agwpa.com
+Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, kmc@searcylaw.com, s.slater@searcylaw.com,
+sas@searcylaw.com, vat@searcylaw.com
+-
+Jeffrey Mare Herman jherman@hermanlaw.com
+Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com
+EFTA00207209
+
+Michael James Pike MPike@bclclaw.com, bobbie@bclelaw.com, jcadwell@bclelaw.com
+Paul G. Cassell cassellp@law.utah.edu
+Richard Horace Willits lawyerwillits@aol.com, reelrhw@hotmail.com
+Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton@podhurst.com,
+mestradal@podhurst.com
+Robert Deweese Critton, Jr rcrit@belclaw.com, bobbie@belclaw.com
+Stuart S. Mermelstein ssm@sexabuseattorney.com, jarbour@sexabuseattorney.com,
+Irivera@sexabuseattorney.com
+9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+Martin G. Weinberg
+20 Park Plaza
+Boston, MA 02116
+The following documents) are associated with this transaction:
+Document description:Main Document
+Original filename:/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=4/5/2010] [FileNumber=7434643-0]
+[94bad243 ff5938b2a329430274128602cadea516d6f3d72102afc716a5c200b6c
+341075e730ddcabddd5dae6815005b428eaa9686c9c049baa40c630792a2]]
+EFTA00207210

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@@ -0,0 +1,31 @@
+From: Jackie Perczek <
+To:
+•. (USAFLS)":
+Subject: Epstein/Doe I. USAO
+Date: Thu, 29 Sep 2011 15:08:15 +0000
+Importance: Normal
+nline.
+mares: ATT0000
+Hi
+I would like to ask Judge Marra until October 14 to file replies re: Epstein's motion to intervene. I ran this by
+Paul Cassell who has no objection. Can I file the motion as unopposed and tell the Judge that the govt does not
+biect either?
+Thanks,
+Jackie
+Jackie Perczek, Esq.
+BLACK
+SREBNICK
+KORNSPAN
+STUMPF
+201 South Biscayne Boulevard
+Suite 1300
+Miami, Florida 33131
+Fax:
+www.royblack.com
+**************************************************************
+The information in this email transmission is privileged and confidential. If you are not the intended recipient, nor
+the employee or agent responsible
+for delivering it to the intended recipient, you are hereby notified that any dissemination or copying of this
+transmission (including any attachments) is strictly prohibited. If you have received this email in error, please
+notify the sender by email reply. Thank you.
+EFTA00205864

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vision-joined/ds9-unparsed-06/bd74a3ea4d426149dc8c1ef50f0b50532564814488a44d9e8b028931f129f786.md

@@ -0,0 +1,68 @@
+From: "emecfautosender@flsd.uscourts.gov" <cmecfautosender@flsd.uscourts.gov>
+To: "flsd_cmecf_notice@flsd.uscourts.gov" <flsd_cmecf_notice@flsd.uscourts.gov>
+Subject: Activity in Case 9:08-cv-80119-KAM Doe |. Epstein Motion for Leave to File Excess Pages
+Date: Fri, 26 Mar 2010 18:32:01 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer: PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered by Pike, Michael on 3/26/2010 at 2:32 PM EDT and filed on 3/26/2010
+Case Name:
+Case Number:
+Filer:
+Document Number: 501
+Doe | Epstein
+9:08-cv-80119-KAM
+Jeffrey Epstein
+Docket Text:
+Defendant's MOTION for Leave to File Excess Pages in Reply to Plaintiff's Response in
+Opposition to Defendant's Motion for Rule 4 Review and Appeal by Jeffrey Epstein.
+(Attachments: # (1) Exhibit Order)(Pike, Michael)
+9:08-Cv-80119-KAM Notice has been electronically mailed to:
+Adam D. Horowitz
+ahorowitz@sexabuseattorney.com
+Bradley James Edwards
+brad@pathtojustice.com, beth@pathtojustice.com
+Isidro Manuel Garcia
+isidrogarcia @bellsouth.net
+Jack Alan Goldberger
+jagesq@bellsouth.net, nalanis@agwpa.com
+Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, kmc@searcylaw.com, s.slater@searcylaw.com,
+sas@searcylaw.com, vat@searcylaw.com
+Jeffrey Mare Herman jherman@hermanlaw.com
+Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com
+EFTA00207107
+
+Michael James Pike MPike@bclclaw.com, bobbie@bclelaw.com, jcadwell@bclelaw.com
+Paul G. Cassell cassellp@law.utah.edu
+Richard Horace Willits lawyerwillits@aol.com, reelrhw@hotmail.com
+Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton@podhurst.com,
+mestradal@podhurst.com
+Robert Deweese Critton, Jr rcrit@belclaw.com, bobbie@belclaw.com
+Stuart S. Mermelstein ssm@sexabuseattorney.com, jarbour@sexabuseattorney.com,
+Irivera@sexabuseattorney.com
+9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+Martin G. Weinberg
+20 Park Plaza
+Boston, MA 02116
+The following documents) are associated with this transaction:
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=3/26/2010] [FileNumber=7405326-0
+][557fcaf41989e5264f04ad6911cc01eбd596d43c5343ba3fc8c9c5681e65f450b61
+98b632c09243f86ffcf9d4855bla860b1994ced6539ab0a3094fbebef9da6]]
+Document description:Exhibit Order
+Original filename:n/a
+Electronic document Stamp:
+[STAMP dcecfStamp_ID=1105629215 [Date=3/26/2010] [FileNumber=7405326-1
+аса8af258е747c947а982е786fЗad22cf94a1384ddb2b5b827c4466111db0]]
+EFTA00207108

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vision-joined/ds9-unparsed-06/bdefd53a846521f872508adabf9f22f3a78e4db1e6b0d7477163f0a2baf3bb7e.md

@@ -0,0 +1,474 @@
+Statements
+EFTA00201132
+
+BEAR
+STEARNS
+OFFICE SERVICING YOUR ACOUNT
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE ZICHERMAN, IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+Important Message
+In an effort to deliver statements to you more efficiently.
+Bear Steams has enhanced the distribution of
+statements to household accounts. Beginning in June,
+all statements with the same Address and Social
+Security number / Taxpayer identification number will
+be mailed in a single envelope. For further details,
+please contact your account executive.
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD April 28, 2001
+THROUGH
+May 25, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 27, 2001
+JEFFREY EPSTEIN
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6809
+Premise or Third Party Repurchase Agreements
+with Bear, Stearns& Co. Inc. outstanding as of date of statement
+PURCHASE/
+START DATE
+03/27/01
+REPURCHASE/
+END DATE
+OPEN
+PLACHASE PRICE!
+PRINCIPAL
+1.050.087.12
+PRICING
+RATE
+3.770000
+REPOI ACCRUED
+INTEREST*
+16,850.16
+NET AMOUNT
+1,066,937.28
+05/23/01
+OPEN
+TS72L REPURCHASE AGREEMEN12-495 201-80
+*he at one protons do not appear in any other section of the staleman.
+3.770000
+73.021.98
+12.568.223.78
+$13,635,161.06
+STOP
+****** End of Statement******
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or writo to Cient Sorvices at Bear, Stoams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859
+SP The surren s four or ratanal purposes red die Set revere date for portant iformation.
+05/26/01;12:59 001
+EFTA00201133
+
+2 of 2
+LEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+05/26/01:12:59 001
+V478
+EFTA00201134
+
+BEAR
+STEARNS
+OFFICE SERVICING YOUR ACOUNT
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD March 31, 2001
+THROUGH
+April 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 30, 2001
+JEFFREY EPSTEIN
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6809
+Premise or Third Party Repurchase Agreements
+with Bear, Stearns& Co. Inc. outstanding as of date of statement
+PURCHASE/
+START DATE
+03/27/01
+REPURCHASE/
+END DATE
+OPEN
+PLACHASE PRICE/
+PRINCIPAL
+1.050.087.12
+PRICING
+RATE
+4.370000
+REPO/ ACCRUED
+INTEREST*
+13,413.16
+NET AMOUNT
+1,063,500.28
+04/12/01
+OPEN
+13.245.201.80
+TOTAL REPURCHASE AGREEMENTS
+*he at one protons do not appear in amy other section of the staleman.
+4.370000
+30,143.87
+13.275.345.67
+$14,338,845.95
+STOP
+*** End of Statement*****
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859
+SIP The suremen s foul ratanal purger red de Set revere die for portant iformation.
+04/28/01:19:29 001
+V471
+EFTA00201135
+
+2 of 2
+LEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+04/28/01:19:29 001
+V471
+EFTA00201136
+
+BEAR
+STEARNS
+OFFICE SERVICING YOUR ACOUNT
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+CLEARED THRESH SONARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD February 24, 2001
+THROUGH
+March 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 23, 2001
+ACCOUNT EXECUTIVE ZICHERMAN, IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+Important Message
+Decimal Trading is Here for Nasdaq!
+Decimal Trading is the shift from fractional pricing
+(e.g.21 1/2) to decimal pricing (e.g.$21.50 yor
+equities and options. Nasdaq securities have been
+phased in during March and the remaining securities
+are scheduled to be trading in decimals in April.
+For details, visit our website at www.bearstearns.
+com.
+JEFFREY EPSTEIN
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6809
+Premise or Third Party Repurchase Agreements
+with Bear, Stearns & Co. Inc. outstanding as of date of statement
+PUACHASEr
+START DATE
+03/27/01
+REPURCHASE/
+END DATE
+OPEN
+PUACHASE PRICE!
+PRINCIPAL
+1.050.087.12
+PRICING
+RATE
+5.250000
+REPOI ACCRUED
+INTEREST*
+9,547.97
+NET AMOUNT
+1,059,635.09
+03/27/01
+OPEN
+1371 REPURCHASE AGREEMEN 14.615.81650
+*he at one protons do not appear in any other section of the staleman.
+5.250000
+108,850.07
+14.724,666.57
+$15,784,301.66
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Sorvices at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen s four ratanal purger red de Set revere dae for portant iformation.
+03/31/01:19:27 001
+V466
+EFTA00201137
+
+BEAR
+STEARNS
+2 org
+OFFICE SERVICING YOUR ACCOUNT
+ear, Stears & Co. In
+45 Park Avenue
+New York, New York 10167
+Your messages
+Bear, Stearns Securities Corp, Net Capital and
+Net Capital Requirements:
+At November 30, 2000 and January 26, 2001, the
+Company's net capital of $2,620,960,000 and
+$2,202,436,000, all respectively.
+A complete copy of the Bear, Stearns Securities
+Corp, Statement of Financial Condition is available
+on the web site www.bearstearns.com, Alternatively,
+to request a free printed copy please call -
+toll free 1-866-299-9331,
+STOP
+****** End of Statement******
+027
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD February 24, 2001
+THROUGH
+March 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 23, 2001
+03/31/01:19:27 001
+V466
+EFTA00201138
+
+3 of 3
+LEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+03/31/01:19:27 001
+V466
+EFTA00201139
+
+BEAR
+STEARNS
+OFFICE SERVICING YOUR ACOUNT
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Your Messages ............
+.....
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD January 27, 2001
+THROUGH
+February 23, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 26, 2001
+2
+JEFFREY EPSTEIN
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6809
+Premise or Third Party Repurchase Agreements
+with Bear, Stearns & Co. Inc. outstanding as of date of statement
+PURCHASEY
+START DATE
+02/22/01
+REPURCHASE/
+END DATE
+OPEN
+PUACHASE PRICE!
+PRINCIPAL
+5.036,584.88
+PRICING
+RATE
+5.350000
+REPOI ACCRUED
+INTEREST*
+3,003.76
+NET AMOUNT
+5,039,588.64
+02/02/01
+OPEN
+11.615.816.50
+TOTAL REPURCHASE AGREEMENTS
+*he at one protons do not appear in amy other section of the staleman.
+5.350000
+47,383.64
+11.663.200.14
+$16,702,788.78
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen s four or ratanal furycer rear die Set revere date for portant formation.
+02/24/01:22:22 001
+EFTA00201140
+
+BEAR
+STEARNS
+2 org
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stears & Co. Inc
+45 Park Avenue
+New York, New York 10167
+Your messages
+The interest, if any, charged to your account
+during December 2000 was computed on the net
+STOP
+****** End of Statement******
+027
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD January 27, 2001
+THROUGH
+February 23, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 26, 2001
+02/24/01:22:22 001
+EFTA00201141
+
+3 of 3
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+LEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+027
+02/24/01:22:22 001
+EFTA00201142
+
+BEAR
+STEARNS
+OFFICE SERVICING YOUR ACOUNT
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD December 30, 2000
+THROUGH
+January 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 29, 2000
+ACCOUNT EXECUTIVE ZICHERMAN, IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+Important Message
+Decimal Trading is Coming!
+Decimal Trading is the shift from fractional pricing
+(e.g.,21 1/2) to decimal pricing (e.g.,$21.50)for
+equities and options.
+All trading on NYSE, AMEX, and regional exchanges
+will be in decimals effective as of 1/29/01.
+For details, visit our website at www.bearstearns.com.
+JEFFREY EPSTEIN
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6809
+Premise or Third Party Repurchase Agreements
+with Bear, Stearns& Co. Inc. outstanding as of date of statement
+PURCHASEY
+REPURCHASE/
+PURCHASE PRICE!
+START DATE
+END DATE
+PRINCIPAL
+01/19/01
+OPEN
+4,000,000.00
+o1201
+OPEN
+1.615.816.50
+TOTAL REPURCHASE AGREEMENTS
+The of sierent do do not appear in any other section of this statemane.
+PRICING
+RATE
+5.950000
+5.950000
+REPOI ACCRUED
+INTEREST*
+2283280
+NET AMOUNT
+14,022,823.89
+.......
+,620,309.3
+$15,643,133.26
+STOP
+****** End of Statement******
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or writa to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+This statement should he retained for your records. See reveree cide for imortart intormat
+01/27/01:15:33 001
+EFTA00201143
+
+2 of 2
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+LEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+027
+01/27/01:15:33 001
+EFTA00201144

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vision-joined/ds9-unparsed-06/bea6489f0fe42de869ae84b4de99be0a9e80f6870ff459638b8c7a60e9fd451f.md

@@ -0,0 +1,778 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOES #1 and #2
+V.
+UNITED STATES
+JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF
+THE CRIME VICTIMS' RIGHTS ACT, REQUEST FOR AN EVIDENTIARY
+HEARING IF FACTS ARE CONTESTED, AND REQUEST FOR HEARING ON
+APPROPRIATE REMEDIES
+COMES NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and
+through undersigned counsel, to move for a finding from this Court that their rights as crime
+victims under the Crime Victims Rights Act (CVRA) have been repeatedly violated by the U.S.
+Attorney's Office, to request an evidentiary hearing to establish those violations if the U.S.
+Attorney's Office contests the underlying facts, and to request a brief schedule and a hearing on
+the appropriate remedies for these violations.
+As recounted in more detail below, the victims have recently-obtained correspondence
+between the U.S. Attorney's Office and defendant Jeffrey Epstein. Based on this correspondence
+and other evidence, it is now clear that the U.S. Attorney's Office has repeatedly violated the
+protected rights of the victims under the CVRA, including their right to confer with prosecutors
+generally about the case and specifically about a non-prosecution agreement it signed with the
+defendant. It is now beyond dispute that in September 2007, the U.S. Attorney's Office reached
+a non-prosecution agreement with Jeffrey Epstein that barred his prosecution for numerous
+1
+EFTA00206835
+
+federal sex offense he committed against the victims (as well as against many other minor girls).
+Rather than confer with the victims about this non-prosecution agreement, however, the U.S.
+Attorney's Office agreed to a
+"confidentiality" provision in the agreement barring the
+agreement's disclosure to anyone - including the victims. For the next nine months, the U.S.
+Attorney's Office assiduously concealed from the victims the existence of this signed non-
+prosecution agreement.
+For example, the U.S. Attorney's Office stopped sending victim
+notifications about the case when defendant Epstein objected. Indeed, the Office went so far as
+to send (in January 2008) a false victim notification letter to the victims informing them that the
+"case is currently under investigation," when in fact the U.S. Attorney's Office had already
+resolved the case three months earlier by signing the non-prosecution agreement. Again on May
+30, 2008, the U.S. Attorney's Office sent yet another victim notification letter to a recognized
+victim informing her that the "case is currently under investigation" and that it "can be a lengthy
+process and we request your continued patience while we conduct a thorough investigation."
+Then in June 2008, on the eve of consummating Epstein's state guilty plea that was part non-
+prosecution agreement, the U.S. Attorney's Office asked legal counsel for Jane Doe #1 and Jane
+Doe #2 to send a letter in writing expressing the victims' views on a possible plea bargain - not
+disclosing to the victims' legal counsel that this was a pointless exercise because the non-
+prosecution agreement had already been signed some nine months earlier.
+All of these actions and many more like them constitute clear violations of Jane Doe #1
+and Jane Doe #2's rights under the Crime Victims Rights Act. The Court should accordingly
+find that the U.S. Attorney's Office has violated the Act and set a briefing schedule and hearing
+on the proper remedy for those violations.
+2
+EFTA00206836
+
+STATEMENT OF FACTS
+Jane Doe #1 and Jane Doe #2 offer the following statement of facts, which they are
+prepared to establish at any evidentiary hearing that the Court might schedule.
+1. Between about 2001 and 2006, defendant Jeffrey Epstein (a billionaire with significant
+political connections) sexually abused more than 40 minor girls at his mansion in West Palm
+Beach, Florida, and elsewhere. Among the girls he sexually abused were Jane Doe #1 and Jane
+Doe #2. Because Epstein used a means of interstate commerce and knowingly traveled in
+interstate commerce to engage to abuse Jane Doe #1 and Jane Doe #2 (and the other victims), he
+committed violations of federal law, specifically repeated violations of 18 U.S.C. § 2422.
+2. 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, among 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. The Palm Beach County State Attorney's Office was
+also investigating the case. See Declaration of Bradley J. Edwards, Esq. at & & 1-2 (hereinafter
+"Edwards Declaration").
+3. The FBI determined that both Jane Doe #1 and Jane Doe #2 were victims of sexual assaults
+by Epstein while they were minors beginning when they were approximately fourteen years of
+age and approximately thirteen years of age respectively. Edwards Declaration at & 2.
+4. On about June 7, 2007, FBI agents hand-delivered to Jane Doe #1 a standard CVRA victim
+notification letter. See Edwards Declaration, Exhibit "A." The notification promises that the
+EFTA00206837
+
+Justice Department would makes its "best efforts" to protect Jane Doe #1's rights, including
+"[t]he reasonable right to confer with the attorney for the United States in the case" and "to be
+reasonably heard at any public proceeding in the district court involving ... plea...." The
+notification further explained that "[a]t this time, your case is under investigation." That
+notification meant that the FBI had identified Jane Doe #1 as a victim of a federal offense and as
+someone protected by the CVRA.
+5. On about August 11, 2007, Jane Doe #2 received a standard CVRA vietim notification letter.
+See Edwards Declaration, Exhibit "B." The notification promised that the Justice Department
+would makes its "best efforts" to protect Jane Doe #2's rights, including "[t]he reasonable right
+to confer with the attorney for the United States in the case" and "to be reasonably heard at any
+public proceeding in the district court involving ... plea...." The notification further explained
+that "[alt this time, your case is under investigation." That notification meant that the FBI had
+identified Jane Doe #2 as a victim of a federal offense and as someone protected by the CVRA.
+6. Early in the investigation, the FBI agents and the Assistant U.S. Attorney had several
+meetings with Jane Doe #1. Jane Doe #2 was represented by counsel that was paid for by the
+criminal target Epstein and, accordingly, all contact was made through that attorney. Edwards
+Declaration at & 5.
+7. In and around September 2007, plea discussions took place between Jeffrey Epstein,
+represented by numerous attorneys (including lead criminal defense counsel Jay Lefkowitz), and
+the U.S. Attorney's office for the Southern District of Florida, represented primarily by Assistant
+U.S. Attorney
+The plea discussions generally began from the premise that
+Epstein would plead guilty at least one federal felony offense surrounding his sexual assaults of
+4
+EFTA00206838
+
+more than 40 minor girls. From there, the numerous defense attorneys progressively negotiated
+more favorable plea terms so that Epstein would ultimately plead to only two state court felony
+offenses and would serve only county jail time. Many of the negotiations are reflected in e-mails
+between Lefkowitz and
+Copies of the correspondence are attached as Exhibit J to the
+Edwards Declaration accompanying this filing (hereinafter cited as "U.S. Attorney's Correspondence"
+and referenced by Bates number stamp). Because Epstein has moved to keep these documents
+from the public, they are at this time filed under seal with the Court.
+8. At the time of plea discussions, the U.S. Attorney's Office had an 82-page prosecution
+memorandum outlining numerous federal sexual offenses committed by Epstein, and had
+prepared a 53-page indictment for numerous federal offenses. U.S. Attorney's Correspondence
+at 4.
+9.
+In September 2007, Assistant U.S. Attorney (AUSA)
+in an effort to
+avoid prosecuting Epstein for his numerous sexual offenses against children, proposed to
+Epstein's attorneys that rather than plea to any charges relating to him molesting children,
+Epstein should instead plead to a single assault charge involving a telephone call made by
+Epstein while he was on his private jet. During the telephone call, Epstein warned his personal
+assistant, Lesley Groff, against turning over documents and electronic evidence responsive to a
+subpoena issued by a federal grand jury in the Southern District of Florida investigating
+Epstein's sex offenses. U.S. Attorney's Correspondence at 49, 58.
+• Through diligent efforts, counsel for Jane Doe #1 and Jane Doe #2 received copies of half of the e-mail
+correspondence (the half reflecting Villafaña's communications to defense counsel) on about June 30,
+2010. See Edwards Declaration at & &20-22.
+5
+EFTA00206839
+
+10.
+The correspondence also shows that AUSA
+was interested in finding a place to
+conclude a plea bargain that would effectively keep the victims from learning what was
+happening through the press.
+She wrote in an e-mail to defense counsel: "On an 'avoid the
+press' note, I believe that Mr. Epstein's airplane was in Miami on the day of the Ms. Groff
+telephone call. If he was in Mimi-Dade County at the time, then I can file the charge in the
+District Court in Miami, which will hopefully cut the press coverage significantly." U.S.
+Attorney's Correspondence at 29. Ms. Villafaña was aware that most of the victims of Epstein,
+including Jane Doe #1 and Jane Doe #2, resided outside the Miami area.
+11.
+On about September 24, 2007, Assistant U.S. Attorney
+sent an e-mail
+to Jay Lefkowitz, criminal defense counsel for Epstein, regarding the agreement. The e-mail
+stated that the Government and Epstein's counsel would negotiate between themselves about
+what information would be disclosed to the victims about the agreement:
+Thank you, Jay. I have forwarded your message only to Alex [Acosta],
+and
+I don't anticipate it going any further than that. When I receive the
+originals, I will sign and return one copy to you. The other will be placed in the
+case file, which will be kept confidential since it also contains identifying
+information about the girls.
+When we reach an agreement about the attorney representative for the girls, we
+can discuss what I can tell him and the girls about the agreement. I know that
+I promised Chief Reiter an update when a resolution was achieved. ...
+Rolando is calling, but
+time that has been agreed to.
+the outcome to anyone.
+U.S. Attorney's Correspondence at 153 (emphases added).
+6
+EFTA00206840
+
+12. On about September 25, 2007, AUSA
+sent an e-mail to Lefkowitz stating: "And
+can we have a conference call to discuss what I may disclose to ... the girls regarding the
+agreement." U.S. Attorney's Correspondence at 156.
+13. On about September 26, 2007, AUSA.
+sent an e-mail to Lefkowitz in which she
+stated: "Hi Jay - Can you give me a call al
+[xxxx] this morning? I am meeting with the
+agents and want to give them their marching orders regarding what they can tell the girls." U.S.
+Attorney's Correspondence at 359.
+The reasonable inference is that the "marching orders"
+agreed to between the Government and Epstein's defense counsel was that no mention would be
+made of the non-prosecution agreement between the U.S. Attorney's Office and Epstein, as no
+subsequent mention was made to the victims of the non-prosecution agreement.
+14.
+On about September 27, 2007, Assistant U.S. Attorney
+revealed to an
+attorney (Bert Ocariz), who was under discussion to be a representative of victims of Epstein's
+sexual abuse in civil litigation, that the government was in the process of reaching a non-
+prosecution agreement with Epstein.
+An e-mail confirming these disclosures stated: "Bert's
+firm has raised a number of good questions about how they are going to get paid." U.S.
+Attorney's Correspondence at 161. The e-mail went on to state: "I told Bert that as part of our
+agreement we (the federal government) are not going to indict Mr. Epstein, but give him an idea
+of the charges that we had planned to bring as related to 18 USC 2255." Id. The e-mail also
+asked permission from Epstein's counsel to send to Ocariz a copy of parts of the plea agreement:
+"With respect to question 2 [a question from Ocariz regarding "[w]hen will it be possible to see
+the plea agreement so that we understand exactly what Epstein concedes to in the civil case?], do
+7
+EFTA00206841
+
+I have your permission to send Bert just that section of the plea agreement that applies to the
+damages claims (I would recommend sending paragraphs 7 through 10, or at least 7 and 8)?" Id.
+15. On about September 25, 2007, ASUA
+sent a letter to Jay Jefkowitz in which she
+suggested that the victims should be represented by someone who was not an experienced
+personal injury attorney:
+"They [the other lawyers under consideration] are all very good
+personal injury lawyers, but I have concerns about whether there would be an inherent tension
+becaue they may feel that they might make more money ... if they proceed outside the terms of
+the pela agreement. (Sorry - I just have a bias against plaintiffs" attorneys.)" U.S. Attorney's
+Correspondence at 157. Villafaña continued to push Ocariz as the best choice, in part because it
+would reduce publicity: "One nice thing about Bert [Ocariz] is that he is in Miami where teher
+has been almost no coverage of the case." Id.
+16. In a letter later sent by Jay Lefkowitz to the U.S. Attorney for the Southern District of
+Florida, Lefkowitz stated that ASUA
+had "assiduously" hidden from him the fact that
+Bert Ocariz was a friend of
+I's boyfriend. U.S. Attorney's Correspondence at 267.
+Lefkowitz also stated that
+had misleadingly used the term "friend" rather than the more
+accurate term "boyfriend" to describe who had recommended Ocariz. Id. at 268. Lefkowitz
+further stated the
+I's boyfriend had a business relationship with Ocariz and that the
+boyfriend would have financially benefitted from the presumably lucrative referral of sexual
+assault cases against Epstein to Ocariz. On December 13, 2007,
+wrote a letter to
+Lefkowitz to deny these accusations. In the letter,
+stated: "... I am surprised by your
+allegations regarding my role because I thought that we had worked very well together in
+resolving this dispute. I also am surprised because I feel that I bent over backwards to keep in
+8
+EFTA00206842
+
+mind the effect that the agreement would have on Mr. Epstein and to make sure that you (and he)
+understood the repercussions of the agreement." Id.
+17.
+On about September 24, 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. Epstein and the U.S. Attorney's Office accordingly entered into a "Non-
+Prosecution Agreement" (NPA) reflecting their agreement. Most significantly, the NPA gave
+Epstein a promise that he would not be prosecuted for a series of federal felony offenses
+involving his sexual abuse of more than 30 minor girls. The NPA instead allowed Epstein to
+plead guilty to two state felony offenses for solicitation of prostitution and procurement of
+minors for prostitution. The NPA also set up a procedure whereby a victim of Epstein's sexual
+abuse could obtain an attorney representative to proceed with a civil claim against Epstein,
+provided that the victim agreed to proceed exclusively under 18 U.S.C. § 2255 (i.e., provided
+that the victim agreed to seek no more than $150,000 in damages against Epstein - an amount
+that Epstein argued later was limited to $50,000). See Edwards Declaration, Exhibit "C" (copy
+of the non-prosecution agreement). The agreement was signed by Epstein and his legal counsel,
+as well as the U.S. Attorney's Office, on about September 24, 2007.
+18. A provision in the non-prosecution agreement made the agreement secret. In particular,
+the agreement stated: "The parties anticipate that this agreement will not be made part of any
+public record.
+If the United States receives a Freedom of Information Act request or any
+compulsory process commanding the disclosure of the agreement, it will provide notice to
+Epstein before making the disclosure." By entering into such a confidentiality agreement, the
+U.S. Attorney's Office put itself in a position that notifying the crime victims (including Jane
+9
+EFTA00206843
+
+Doe #1 and Jane Doe #2) of the non-prosecution agreement would violate terms of the
+agreement - specifically the confidentiality provision. Accordingly, from September 24, 2007
+through at least June 2008 - a period of more than nine months -- the U.S Attorney's Office did
+not notify any of the victims of the existence of the non-prosecution agreement.
+19.
+A reasonable inference from the evidence is that the U.S. Attorney's Office wanted the
+non-prosecution agreement kept from public view because of the intense public criticism that
+would have resulted from allowing a politically-connected billionaire who had sexually abused
+more than 40 minor girls to escape from federal prosecution with only a county court jail
+sentence and because of the possibility that the victims could have objected to the agreement in
+court and prevented its consummation.
+20. The Non-Prosecution Agreement that had been entered into between the U.S. Attorney's
+Office and Epstein was subsequently modified by an October 2007 Addendum and a December
+19, 2007, letter from the U.S. Attorney to Attorney Lilly Ann Sanchez.
+See Supplemental
+Declaration of
+doc. #35, at 1; U.S. Attorney's Correspondence at 234-37.
+The U.S. Attorney's Office did not notify any of the victims of the existence of these
+modifications of the agreement through at least June 2008 - a period of more than six months.
+On about August 14, 2008, Epstein's defense counsel told the U.S. Attorney's Office that they
+did not consider the December 19, 2007, letter to be operative. Id.
+21.
+In October 2007, shortly after the initial plea agreement was signed, Jane Doe #1 was
+contacted to be advised regarding the resolution of the investigation. On October 26, 2007,
+Special Agents
+Jand
+met in person with Jane Doe #1. The
+Special Agents explained that Epstein would plead guilty to state charges, he would be required
+10
+EFTA00206844
+
+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, the Special Agents did
+not explain that an agreement had already been signed that precluded any prosecution of Epstein
+for federal charges. The agents could not have revealed this part of the non-prosecution
+agreement without violating the terms of the non-prosecution agreement. Whether the agents
+themselves had been informed of the existence of the non-prosecution agreement by the U.S.
+Attorney's Office is not certain. Because the plea agreement had already been reached with
+Epstein, the agents made no attempt to secure Jane Doe #1's view on the proposed resolution of
+the case. Edwards Declaration at & 7.
+22.
+Jane Doe #1'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. Edwards Declaration at & 8.
+23.
+On about November 27, 2007, Assistant U.S. Attorney
+sent an e-mail to Jay
+Lefkowitz, defense counsel for Epstein. The e-mail stated that the U.S. Attorney's Office had an
+obligation to notify the victims about the plea agreement:
+The United States has a statutory obligation (Justice for All Act of 2004) to notify
+the victims of the anticipated upcoming events and their rights associated with the
+agreement entered into by the United States and Mr. Epstein in a timely fashion.
+Tomorrow will make one full week since you were formally notified of the
+selection. I must insist that the vetting process come to an end. Therefore, unless
+you provide me with a good faith objection to Judge Davis's selection [as special
+master for selecting legal counsel for victim pursuing claims against Epstein] by
+COB tomorrow, November 28, 2007, I will authorize the notification of the
+victims. Should you give me the go-head on Podhurst and Josephsberg selectior
+by COB tomorrow, I will simultaneously send you a draft of the letter. I intend to
+notify the victims by letter after COB Thursday, November 29th.
+U.S. Attorney's Correspondence at 255 (emphasis rearranged).
+11
+EFTA00206845
+
+24. On about November 29, 2007, Assistant U.S. Attorney
+sent a draft of a
+crime victim notification letter to Jay Lefkowitz, defense counsel for Jeffrey Epstein. The
+notification letter explained: "I am writing to inform you that the federal investigation of Jeffrey
+Epstein has been completed, and Mr. Epstein and the U.S. Attorney's Office have reached an
+agreement containing the following terms ...." The letter then went on to explain that Epstein
+would plead guilty to two state offenses and receive an 18 month sentence. The letter did not
+explain that, as part of the agreement with Epstein, the Justice Department had previously agreed
+not to prosecute Epstein for any of the numerous federal offenses that had been committed. U.S.
+Attorney's Correspondence at 256-59.
+25. Apparently because of concerns from Epstein's attorneys, the U.S. Attorney's Office never
+sent the proposed victim notification letter discussed in the previous paragraph to the victims.
+Instead, a misleading letter stating that the case was "currently under investigation" (described
+below) was sent in January 2008 and May 2008. At no time before reaching non-prosecution
+agreement did the Justice Department contact any victims, including for example Jane Doe #1,
+about their views on the non-prosecution.
+26. On about December 6, 2007,
+First Assistant U.S. Attorney sent a letter to
+Jay Lefkowitz, noting the U.S. Attorney's Office's legal obligations to keep victims informed of
+the status of plea negotiations with Epstein. The letter stated:
+Finally, let me address your objections to the draft Victim Notification Letter.
+You write that you don't understand the basis for the Office's belief that it is
+appropriate to notify the victims. Pursuant to the "Justice for All Act of 2004,"
+[another name from the CVRA] crime victims are entitled to: "The right to
+instringe, acrime and the mily not to be excluded from any such eding court
+12
+EFTA00206846
+
+proceeding ....
+• 18 U.S.C. § 3771(a)(2) & (3). Section 3771 also commands
+that 'employees of the Department of Justice ... engaged in the detection,
+investigation, or prosecution of crime shall make their best efforts to see that
+crime victims are notified of, and accorded, the rights described in subection (a).'
+18 U.S.C. § 3771(c)(1)....
+Our Non-Prosecution Agreement resolves the federal investigation by allowing
+Vr. Epstein to plead to a state offense. The victims identified through the federa
+nvestigation should be appropriately informed, and our Non-Prosecution
+Agreement does not require the U.S. Attorney's Office to forego its legal
+obligation.
+U.S. Attorney's Correspondence at 191-92 (emphasis added).
+27. Despite this recognition of its obligation to keep victims "appropriately informed" about the
+non-prosecution agreement, the U.S. Attorney's Office did not follow through and inform the
+victims of the non-prosecution agreement. To the contrary, as discussed below, it continued to
+tell the victims that the case was "under investigation." Edwards Declaration at & 4 and & 12.
+28.
+On December 13, 2007,
+sent a letter to Jay Lefkowitz, defense
+counsel for Epstein, rebutting charges that had apparently been made against her by the Epstein
+defense. The letter stated that a federal indictment against Epstein "was postponed for more than
+five months to allow you and Mr. Epstein's other attorneys to make presentations to the Office to
+convince the Office not to prosecute." The letter also recounted that "You and I spent hours
+negotiating the terms [of the non-prosecution agreement], including when to use 'a' versus 'the'
+and other minutiae. When you and I could not reach agreement, you repeatedly went over my
+head, involving Messrs.
+, and Acosta in the negotiations at various
+times." U.S. Attorney's Correspondence at 269.
+29. The December 13, 2007, letter also reveals that the Justice Department stopped making
+victim notifications because of objections from Epstein's criminal defense counsel: "Three
+13
+EFTA00206847
+
+victims were notified shortly after the signing of the Non-Prosecution Agreement of the general
+terms of the Agreement.
+You raised objections to any victim notification, and no further
+notifications were done." U.S. Attorney's Correspondence at 270 (emphasis added).
+30.
+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.
+See U.S. Attorney's Correspondence passim.
+31.
+On January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI
+advising them that "It]his case is currently under investigation. This can be a lengthy process
+and we request you continued patience while we conduct a thorough investigation." See Doc.
+#14 (attachments 3 and 4 to declaration of l
+(emphasis added). The statement
+in the notification letter was false. The case was not currently "under investigation." To the
+contrary, the case had been resolved by the non-prosecution agreement entered into by Epstein
+and the U.S. Attorney's Office discussed previously. Moreover, the FBI did not notify Jane Doe
+#1 or Jane Doe #2 that a plea agreement had been reached previously, and that part of the
+agreement was a non-prosecution agreement with the U.S. Attorney's Office for the Southern
+District of Florida. Edwards Declaration at & 9.
+32.
+In early 2008, Jane Doe #1 and Jane Doe #2 came to believe that criminal prosecution
+of Epstein was extremely important. They also desired to be consulted by the FBI and/or other
+representatives of the federal government about the prosecution of Epstein. In light of the letters
+that they had received around January 10, they believed that a criminal investigation of Epstein
+was on-going and that they would be contacted before the federal government reached any final
+resolution of that investigation. Edwards Declaration at &10.
+14
+EFTA00206848
+
+33.
+On about February 25, 2008, Assistant U.S. Attorney
+sent an e-mail to Jay
+Lefkowitz, Epstein's criminal defense counsel, explaining that the Justice Department's Child
+Exploitation Obscenity Section (CEOS) had agreed to review Epstein's objections to the
+proposed plea agreement that had been reached with the U.S. Attorney's Office for the Southern
+District of Florida. The letter indicated that, should CEOS reject Epstein's objections to the
+agreement, then "Mr. Epstein shall have one week to abide by the terms and conditions of the
+September 24, 2007 Agreement as amended by letter from United States Attorney Acosta to Jay
+Lefkowitz." U.S. Attorneys Correspondence at 290-91.
+34. In about April 2008, 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
+secured pro bono counsel to represent Jane Doe #1. Pro bono
+counsel was able to assist Jane Doe #1 in avoiding the improper deposition. AUSA
+secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims'
+Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During
+the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached.
+35.
+On May 30, 2008, another of Mr. Edwards's clients who was recognized as an Epstein
+victim by the U.S. Attorney's Office, received a letter from the FBI advising her that "[t]his case
+is currently under investigation. This can be a lengthy process and we request your continued
+patience while we conduct a thorough investigation." The statement in the notification letter was
+false.
+The case was not currently "under investigation." To the contrary, the case had been
+resolved by the non-prosecution agreement entered into by Epstein and the U.S. Attorney's
+Office discussed previously. Edwards Declaration at & 12.
+15
+EFTA00206849
+
+36.
+In mid-June 2008, Mr. Edwards contacted AUSA
+to inform her that he
+represented Jane Doe #1 and, later, Jane Doe #2. Mr. Edwards asked to meet to provide
+information about the federal crimes committed by Epstein, hoping to secure a significant federal
+indictment against Epstein. AUSA
+and Mr. Edwards discussed the possibility of
+federal charges being filed. At the end of the call, AUSA
+asked Mr. Edwards to send
+any information that he wanted considered by the U.S. Attorney's Office in determining whether
+to file federal charges.
+Because of the confidentiality provision that existed in the plea
+agreement, Mr. Edwards was not informed that previously, in September 2007, the U.S.
+Attorney's Office had reached an agreement not to file federal charges. Mr. Edwards was also
+not informed that resolution of the criminal matter was imminent. Edwards Declaration at & 13.
+37.
+On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA
+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
+and the Palm Beach Police Department attempted to
+provide notification to victims in the short time that Epstein's counsel had provided. Attorney
+Edwards was called to provide notice to his clients regarding the hearing. AUSAI
+did
+not tell Attorney Edwards that the guilty pleas in state court would bring an end to the possibility
+of federal prosecution pursuant to the plea agreement. Edwards Declaration at & 14.
+38.
+On June 30, 2008, AUSA
+sent an e-mail to Jack Goldberger, criminal defense
+counsel for Epstein, that stated: "Jack: The FBI has received several calls regarding the Non-
+Prosecution Agreement. I do not know whether the title of the document was disclosed when the
+Agreement was filed under seal, but the FBI and our office are declining comment if asked."
+U.S. Attorney's Correspondence at 321.
+16
+EFTA00206850
+
+39.
+On July 3, 2008, Mr. Edwards sent to AUSA
+a letter. See Affidavit of Bradley
+J. Edwards, Esq., at 15 (attachment 2). In the letter, Mr. Edwards indicated his client's 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 necessary to protect our
+children from this very dangerous sexual predator." When Mr. Edwards wrote this letter, he was
+still unaware that a non-prosecution agreement had been reached with Epstein - a fact that
+continued to be concealed from him (and the victims) by the U.S. Attorney's Office. Mr.
+Edwards first saw a reference to the NPA on or after July 9, 2008, when the Government filed its
+responsive pleading
+; to Jane Doe's emergency petition. That pleading was the first public
+mention of the non-prosecution agreement and the first disclosure to Mr. Edwards (and thus to
+Jane Doe #1 and Jane Doe #2) of the possible existence of a non-prosecution agreement.
+Edwards Declaration at & 15.
+40.
+On July 9, 2008, AUSA
+sent a victim notification to Jane Doe #1 via her
+attorney, Bradley Edwards. Edwards Declaration, Exhibit "H." That notification contains a
+written explanation of some of the terms of the agreement between Epstein and the U.S.
+Attorney's Office. A full copy of the terms was not provided. 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. As a result, Jane Doe #2 never received a
+17
+EFTA00206851
+
+notification a letter about the agreement. The notification did not mention the non-prosecution
+agreement with the U.S. Attorney's Office. Edwards Declaration at & 16.
+41. On July 9, 2008, AUSA
+filed a sworn declaration with the Court in connection
+with the case (doc. #14). The declaration purported to recount limit parts of the non-prosecution
+agreement and stated that "these provisions were discussed" with several victims, including Jane
+Doe #1. Id. at 4.
+42.
+On July 11, 2008, the Court held a hearing on Jane Doe #1 and Jane Doe #2's Emergency
+Petition for Enforcement of Rights. During the hearing, the Government conceded that Jane Doe
+#1 and Jane Doe #2 were "vietims" within the meaning of the Crime Victim's Rights Act. Tr. at
+14-15.
+43. During the July 11 hearing, the Court and the parties discussed the fact that the petition
+should not be treated as an "emergency" petition because there was not any particular rush to
+ruling on it. Tr. at 24-25. The Court further discussed a need to "hav[e] a complete record, and
+this is going to be an issue that's ... going to go to the Eleventh Circuit, [s] it] may be better to
+have a complete record as to what your position is and the government's is as to what actions
+were taken. And I don't know if I have enough information, based on
+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 b[y] ear and make this into a more complete record for the
+court of appeals."
+Tr. at 25-26.
+Counsel for Jane Doe #1 and Jane Doe #2 explained: " ...
+Your Honor is correct in stating that it is not an emergency and it doesn't need to happen today.
+And, I will confer with the government on this and if evidence needs to be taken, it [can] be
+taken at a later date. It doesn't seem like there will be any prejudice to any party [from delay]."
+18
+EFTA00206852
+
+Tr. at 26. The hearing concluded: "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." Tr. at 32. The Court then adjourned, taking
+the victims" petition under advisement.
+44. The U.S. Attorney's Office and the victims then attempted to reach a stipulated set of facts
+underlying the case. The U.S. Attorney's Office set a proposed set of facts, and the victims sent
+a counter-proposal. Rather than respond to the victims" counter-proposal, however, the U.S.
+Attorney's Office suddenly reversed course. (Doc. #19 at 2). On July 29, 2008, it filed a Notice
+to Court Regarding Absence of Need for Evidentiary Hearing (doc. #17). The Government took
+the position that, because no federal criminal charges had been filed in the Southern District of
+Florida, no additional evidence was required to decide the petition before the Court.
+45. On August 1, 2008, Jane Doe #land Jane Doe #2 filed (doc. #19) a response to the
+Government's "Notice." In the response, Jane Doe #1 and Jane Doe #2 gave a proposed
+statement of facts surrounding the case. The proposed statement of fact was based on the
+information available to the victims at that time. The proposed statement of facts highlighted the
+fact that the Government had signed a non-prosecution agreement containing an express
+confidentiality provision, which prevented the Government from disclosing the agreement to
+them and other victims. Id. at 5. The response also noted that the Court had taken the victims'
+petition under advisement. The response further noted that the Government had not attempted to
+work with the victims to draft a full set of undisputed facts and had refused the victims' efforts to
+obtain documents relevant to the case. Id. at 9. The victims response also requested that the
+19
+EFTA00206853
+
+Court direct the Government to confer with the victims regarding the undisputed facts of the
+case, produce the non-prosecution agreement at issue in the case, and produce an FBI Report of
+Interview with Jane Doe #1. The response also requested that the Court enter judgment for the
+victims' finding a violation of rights and schedule a hearing on the appropriate remedy. Id. at 14.
+46. On August 14, 2008, the Court held a hearing on the case. During that hearing, the U.S.
+Attorney's Office conceded "we do feel bound by the confidentiality provision such that we
+could not voluntarily disclose this non-prosecution agreement without court order compelling us
+to do so." Tr. at 8. The Office went on to further concede that it could not justify depriving the
+victims of the opportunity to see the agreement. Id. at 14. The hearing concluded without any
+schedule or deadlines being put in place.
+47. On October 9, 2008, Bradley J. Edwards, counsel for Jane Doe #1 and Jane Doe #2, sent a
+letter to counsel for the U.S. Attorney's Office in this case advising that two possibly false
+statements had been made to the Court in the July 9t sworn declaration of AUSAL
+See
+Oct. 9, 2008, Letter from Bradley J. Edwards to Marie Villafaña at 1, Edwards Declaration,
+Attachment "I." First, while Ms.
+had described a term as being part of the plea
+agreement with Epstein, that term later became defunct, at least in the view of Epstein's
+attorneys (and apparently acceded to by the U.S. Attorney's Office). Second, Ms.
+had
+said that "four victims [including Jane Doe #1] were contacted and these provisions were
+discussed," it was not clear what provisions had in fact been discussed.
+filed a supplemental affidavit, "correcting"
+48. On December 22, 2008, AUSA Marie l
+the statement made in her July 8, 2008, declaration about the terms of the plea agreement (doc.
+#35).
+The supplemental affidavit stated that "part 3" of the agreement with defendant Epstein
+20
+EFTA00206854
+
+was, in the view Epstein' legal counsel, no longer operative. The supplemental affidavit,
+however, did not clarify what terms of the agreement had been discussed.
+49. On April 9, 2009, counsel for Jane Doe #1 and Jane Doe #2 sent to the Court in this case
+(via the PACER system) a notice of a change of law firm affiliation. Doc. #37.
+50. In approximately May 2009, counsel for Jane Doe #1 and Jane Doe #2 propounded
+discovery requests in both state and federal civil cases against Epstein, seeking to obtain
+correspondence between Epstein and prosecutors regarding his plea agreement - information that
+the U.S. Attorney's Office was unwilling to provide to Jane Doe #1 and Jane Doe #2. Epstein
+refused to produce that information, and extended litigation to obtain the materials followed.
+Edwards Declaration at & 20.
+51. Because of this extended litigation, Jane Doe #1 and Jane Doe #2 did not have access to
+important correspondence demonstrating a violation of their rights until June 30, 2010. On that
+day, counsel for Epstein sent to Bradley J. Edwards, Esq., legal counsel for Jane Doe #1 and Jane
+Doe #2, approximately 358 pages of e-mail correspondence between his legal counsel and the
+U.S. Attorney's Office for the Southern District of Florida regarding the plea agreement that had
+been negotiated between them.
+See Edwards Declaration, Attachment "J." These e-mails
+disclosed for the first time the extreme and unusual steps that had been taken by the U.S.
+Attorney's Office to avoid prosecuting Epstein and to avoid having the victims in the case learn
+about the non-prosecution agreement that had been reached between Epstein and the
+Government.
+Litigation continues to this day to obtain the correspondence regarding the state
+prosecution and regarding what Epstein's attorneys said in the correspondence with the
+prosecutors. Edwards Declaration at & 22
+21
+EFTA00206855
+
+52. In mid-July 2010, Jane Doe #1 and Jane Doe #2 settled their civil lawsuits against Mr.
+Epstein. Notice of this fact was promptly provided to the Court. Edwards Declaration at xxx.
+53. On September 8, 2010, the Court entered an order stating that "[a]n examination of the
+docket reveals that no activity has taken place in this case since April of 2009. In light of the
+underlying settlements between the victims and Mr. Epstein, it is hereby ordered and adjudged
+that this case is closed." Doc. #38.
+54. Promptly on the heels of this administrative order, on September 13, 2010, Jane Doe #1 and
+Jane Doe #2 filed a notice that they "intend to make subsequent filing in the case shortly. They
+accordingly request administrative reopening of the case and, if the Court deems it advisable, a
+scheduling conference with the U.S. Attorney's Office regarding the case." Doc. #39 at 1. They
+further advised the Court that their settlements with Jeffrey Epstein in no way affected "their
+determination to move forward with the above-captioned CVRA action against a different entity
+- the U.S. Attorney's Office for the Southern District of Florida." Id. at 2. The pleading further
+advised that "Tilf the Court wishes to proceed to an expeditious conclusion to this Case, Jane Doe
+#1 and Jane Doe #2 have no objection to the Court setting up an expedited schedule for
+proceeding on the case." Id. The pleading further advised that the reason the victims had not
+filed for summary judgment in the case was that they had been attempting to secure
+correspondence between the U.S. Attorney's Office and Epstein to corroborate their argument
+that the Office had violated their rights. They noted that they had just secured half of that
+correspondence two months earlier.
+Id. at 2. The victim asked that, "if the Court deems it
+advisable, that a scheduling conference be set for this case."
+22
+EFTA00206856
+
+55. At all times material to this statement of facts, it would have been practical and feasible for
+federal government to inform Jane Doe #1 and Jane Doe #2 of the details of the proposed non-
+prosecution agreement with Epstein, including in particular the fact that the agreement barred
+any federal criminal prosecution. Edwards Declaration at & 26.
+LEGAL MEMORANDUM
+The victims have previously briefed the issues of why they are entitled to entry of an
+order by this Court finding that the U.S. Attorney's Office violated their rights under the CVRA.
+See Doc. #1; Doc #9 at 3-11; Doc. #19 at 3-9, 14. The victims specifically incorporate those
+pleadings by reference here. In short, as explained in the victims' earlier pleadings, the Office
+violated the victims' right to confer before reaching the non-prosecution agreement and also
+failed to use its best efforts to comply with the CVRA.
+In light of the new evidence that the victims have uncovered, it now palpably obvious
+that not only has the U.S. Attorney's Office violated their rights, but that the violations were part
+of an orchestrated, deliberate attempt to keep the victims in the dark about the non-prosecution
+agreement so that they could not raise any timely objection to it. The facts recounted
+demonstrate the following chain of events. The U.S. Attorney's Office first reached a non-
+prosecution agreement with Epstein, in which it agreed not to prosecute him for numerous
+crimes (including, for example, sex offenses committed by Epstein against Jane Doe #1). As
+part of that agreement, the U.S. Attorney's Office agreed to a "confidentiality" provision that
+forbade publicly disclosing the existence of the agreement. As a result, the U.S. Attorney's
+Office and FBI agents acting under its direction kept the existence of the non-prosecution
+agreement secret from the victims and the public. The reasonable inference from the evidence is
+23
+EFTA00206857
+
+that the U.S. Attorney's Office wanted to keep the agreement a secret to avoid intense criticism
+that would have surely ensued had the victims and the public learned that a billionaire sex
+offender with political connections had arranged to avoid federal prosecution for numerous
+felony sex offenses against minor girls.
+As part of this pattern of deception, the U.S. Attorney's Office discussed victim
+notification with the defendant sex offender and, after he raised objections, stopped making
+notification. Then later in January 2008, the U.S. Attorney's Office arranged for letters to be
+sent to the victims - including Jane Doe #1 and Jane Doe #2 - that falsely stated that to each that
+your "case is currently under investigation." This was untrue, as the U.S. Attorney's Office had
+already resolved the federal case by signing a non-prosecution agreement with Epstein. Indeed,
+the pattern of deception continued even after Jane Doe #1 and Jane Doe #2 were represented by
+legal counsel. In May 2008, the Office sent a similar letter stating "your case is currently
+investigation" to another victim (represented by Bradley J. Edwards). As late as the middle of
+June 2008 - more than eight months after the non-prosecution agreement had been signed -- the
+Assistant U.S. Attorney handling the case told the attorney representing Jane Doe #1 and Jane
+Doe #2 (Edwards) to send information that he wanted the Office to consider in determining
+whether to file federal charges. The Office concealed from him the fact that the determination
+had already been made and a non-prosecution agreement had been signed long ago. The Office
+also concealed from him the fact that guilty pleas in state court were imminent. The Office
+provided notice about the fact of the non-prosecution agreement only after Epstein had entered
+his guilty pleas in state court - in other words, only after the time for the victims to be able to
+24
+EFTA00206858
+
+object to the non-prosecution agreement during the plea process had come and gone. Even at
+that time, the Office did not disclose the provisions in the agreement.
+This behavior does not satisfy the Office's obligations under the CVRA to use its "best
+efforts" to insure that vietims receive protection of their rights. 18 U.S.C. § 3771(c)(1). In
+particular, it makes clear that the victims were not afforded their right "to confer with the
+attorney for the Government in the case." 18 U.S.C. § 3771(a)(5). Whatever else may be said
+about the deception, it also starkly violates the victims' right "to be treated with fairness and with
+respect for the victim's dignity ...." 18 U.S.C. § 3771(a)(8). The pattern also denied the
+victims of timely notice of court proceedings, 18 U.S.C. § 3771(a)(3), including in particular the
+state court guilty plea
+The Court should find that these violations of the victims* rights were not accidental but
+deliberate. The U.S. Attorney's Office was well aware its resolution of the federal cases
+triggered an obligation under the CVRA to notify the victims of what was happening to their
+cases. Indeed, the First Assistant in the Office wrote to Epstein's defense counsel that pursuant
+to the CVRA
+crime victims are entitled to: "The right to reasonable, accurate, and timely notice
+etay ubim any proceeding cout poing the crime a sc Bignate
+(3). Section 3771 also commands that "employees of the Department of Justice..
+. engaged in the detection, investigation, or prosecution of crime shall make their
+best efforts to see that crime victims are notified of, and accorded, the rights
+described in subsection (a)." 18 U.S.C. § 3771(c)(I).... Our Non-Prosecution
+Agreement resolves the federal investigation by allowing Mr. Epstein to plead to
+a state offense. The victims identified through the federal investigation should be
+appropriately informed, and our Non-Prosecution Agreement does not require the
+U.S. Attorney's Office to forego its legal obligation.
+25
+EFTA00206859
+
+U.S. Attorney's Correspondence at 191-92. Despite recognizing in private correspondence with
+defense counsel that victims of Epstein's sexual assault should be "appropriately informed"
+about the Non-Prosecution agreement in a "timely" fashion, the U.S. Attorney's Office
+ultimately did nothing to inform them of the agreement until after the agreement had been
+consummated in court.
+In short, Jane Doe #1 and Jane Doe #2 - and the many other victims of the defendant's
+federal sex offenses - were deliberately kept in the dark about the fact that the U.S. Attorney's
+Office was planning to reach a deal that would permit the defendant to escape all federal
+punishment. This bald decision to conceal from the vietims what was happening violated the
+core 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 victims and their families can provide may be material and relevant ...
+" Id. If ever a case cried out for a court finding that prosecutors have violated the rights of
+crime victims, it is this one. The victims respectfully ask for a finding that the U.S. Attorney's
+Office has violated their rights under the Crime Victims' Rights Act.
+CERTIFICATE OF CONFERENCE
+Counsel for Jane Doe #1 and Jane Doe #2 are engaged in on-going discussions with
+counsel for the U.S. Attorney's Office to resolve the matters raised in this pleading. The U.S.
+26
+EFTA00206860
+
+Attorney's Office has agreed to stipulate to all facts presented by Jane Doe #1 and Jane Doe #2
+that are correct. At this time, however, the parties have not been able to reach any further
+agreements.
+CONCLUSION
+For all these reasons, the Court should find the U.S. Attorney's Office violated Jane Doe
+#1 and Jane Doe #2's rights under the Crime Victims Rights Act and then schedule an
+appropriate hearing on the remedy for these violations. The scope of the remedy that is
+appropriate may depend in part of the scope of the violations that the Court finds. For this
+reason, it makes sense to bifurcate the process and determine, first, the extent of the violations
+and then, second, the remedy appropriate for those violations. If the Court would prefer to see
+more immediate briefing on remedy issues, the victims stand prepared to provide that briefing at
+the Court's direction.
+DATED: October 27, 2010
+Respectfully Submitted,
+s/ Bradley J. Edwards
+Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+EDWARDS, FISTOS & LEHRMAN, P.L.
+Fort Lauderdale, Florida 33301
+and
+27
+EFTA00206861
+
+Paul G. Cassell
+Pro Hac Vice
+Salt Lake City, UT 84112
+Attorneys for Jane Doe #1 and Jane Doe #2
+28
+EFTA00206862
+
+CERTIFICATE OF SERVICE
+Also serve Epstein through current lawyer.
+29
+EFTA00206863

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vision-joined/ds9-unparsed-06/bec23e1123949610574ed902e0bb25f4005365277bc021114c4c96476190e57c.md

@@ -0,0 +1,65 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+West Palm Beach, FL 33401
+July 19, 2007
+DELIVERY BY HAND
+Ms.
+Re: Grand Jury Investigation Confidential
+Dear Ms.
+This letter is an invitation for you to testify before a federal Grand Jury, and is supplied in order to
+rovide helpful background information about the Grand Jury.
+federal crimes which may have been committed in this District.
+As a Grand Jury witness you will be asked to testify and answer questions under oath, and to
+produce records and documents. Only the members of the Grand Jury, attorneys for the United States
+and a stenographer are permitted in the Grand Jury room while you testify.
+The U.S. Department of Justice encourages prosecutors to notify an individual in appropriate
+cases that he or she is a target of a grand jury investigation. Accordingly, you are hereby notified that you
+are a target of a federal grand jury investigation in the Southern District of Florida concerning suspected
+violations of federal law, including but not limited to, possible violations of Title 18, United States Code,
+Sections 2, 371, 1512, 1591, 1952, 1956, 1960, 2421, 2422, and 2423.
+You are advised that the destruction or alteration of any document required to be produced before
+the grand jury constitutes serious violation of federal law, including but not limited to Obstruction of
+Justice.
+A "target" is a person as to whom the prosecutors or the Grand Jury have substantial evidence
+linking him or her to the commission of a crime and who, in the judgment of the prosecutors, is a putative
+defendant.
+This letter constitutes an invitation to you to testify on your own behalf before the grand jury
+about matters under investigation. Of course, you are not required to appear before the grand jury. The
+decision whether to do so is a voluntary matter which is entirely up to you. The grand jury, if in fact it
+learns of this opportunity afforded to you, will be instructed not to draw any adverse inference from your
+failure to appear should you decide not to accept this invitation. You must further understand that should
+you decide to testify, your testimony could be used against you if any criminal charges should be filed
+against you.
+Should you decide to appear before the grand jury, you will have the same rights and obligations
+as any non-immunized grand jury witness. Specifically,
+You may refuse to answer any question if a truthful answer to the question would tend to
+incriminate you.
+You have the right to stop answering questions at any time.
+Anything you say may be used against you at the grand jury or in a subsequent legal
+proceeding.
+The grand jury will permit you a reasonable opportunity to step outside the grand jury
+room to consult with your attorney, if you so desire, at any point during the testimony you
+give.
+Please be further advised that the giving of false testimony before the grand jury will subject you
+to a prosecution for perjury in addition to the violations set forth above.
+As a target of a grand jury investigation who has been asked to appear before the grand
+jury, you may wish to retain the services of an attorney. If you cannot afford the services of
+independent counsel, the Court may be able to appoint counsel to represent you. If you would like
+the United States to ask the Court to appoint an attorney to represent you, please contact the
+EFTA00204831
+
+undersigned at 1
+The United States is investigating other individuals, and you may be
+nterested in cooperating with the United States against those other targets. If you hire an attorney
+r if the Court appoints one to represent you, that counsel can contact me to discuss that possibiliti
+Please advise me whether you wish to testify before the grand jury by close of business Friday,
+August 10, 2007. IfI do not receive notification from you or your counsel by this date, I will assume that
+you do not wish to testify before the grand jury.
+Sincerely,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+Assistant United States Attorney
+bec:.
+EFTA00204832

vision-joined/ds9-unparsed-06/bf3a2f6300dc5c808e49f20f79e41a371ba34020fed8efc75e4a58303906fd4e.json

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vision-joined/ds9-unparsed-06/bf3a2f6300dc5c808e49f20f79e41a371ba34020fed8efc75e4a58303906fd4e.md

@@ -0,0 +1,37 @@
+Subject: FLORIDA OFFENDER ALERT MESSAGE
+Date: Sat, 10 Jul 2010 19:12:08 + 0000
+Importanc
+Normal
+e:
+•Florida Offender Alert System
+07/10/2010
+You have subscribed with the Florida Offender Alert System to receive e-mail notifications
+when a registered Florida sexual offender or predator reports an address within the
+following subscribed address of interest:
+Radius: one mile
+Subscribed Address: 358 El Brillo Way, Palm Beach, FL 33480
+This e-mail is to inform you that the following updated address information was reported to
+the Florida Sexual Offender Registry and falls within the specified radius:
+Offender Name:
+JEFFREY E EPSTEIN
+DOB:
+01/20/1953
+Reported Offender Address: 358
+EL BRILLO WAY, PALM BEACH, FL
+View
+Offender
+Elyer
+To change your subscription information, go to FloridaOffenderAlert.com and select
+"Tracking Addresses."
+It is unlawful to misuse public records information regarding a sexual offender or predator
+as defined by Florida Statute Section 775.21(10)(c).
+Opt-Out of Notifications
+Assistance with Technical Issues
+Safety Tips and Victim Information
+Frequently Asked Questions
+Thank you,
+The Florida Offender Alert System
+The Florida Offender Alert System is being provided in partnership between the Florida Sheriffs Association, Florida Police Chiefs
+Association and Florida Department of Law Enforcement.
+Please do not respond to this e-mail. This is an unmonitored e-mail location.
+EFTA00206554

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vision-joined/ds9-unparsed-06/bf6a133ae20682ba540d5345f3300c182d3454ea097486ffe67b6d84d7a86afc.md

@@ -0,0 +1,89 @@
+Case 9:08-cv-80736-KAM Document 48-4
+Entered on FLSD Docket 03/21/2011 Page 1 of 3
+JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF THE
+CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE
+REMEDIES
+CASE NO:
+08-80736-Ciy-]
+EXHIBIT D
+EFTA00205237
+
+07/09/2008
+15:14
+FAX 5618059846
+Gase 9:08-cv-80736-KAM
+USAO WPB CONFRM
+4024
+Document 48-4 Entered on FLSD Docket 03/21/2011. Page 20f2
+U.S. Department of Justice
+United States Altorney
+Souihern District of Florida
+500 South Australian /ve., Suite 400
+Wert Polm Beach FL 33401
+Facsimile.
+August 11, 2006
+DELIVERY BY HAND
+Miss
+Re:
+Crime Victims' and Witnesses' Rights
+Dear Miss
+Pursuant to the Justice for All Act of 2004, as a victim and/or wilness of a federal offense,
+you have a number of rights. Those rights are:
+(1)
+(2)
+The right to be reasonably protected from the accused
+The right to reasonable, accurate, and timely notice of any public court proceeding
+(3)
+involving the crime or of any release or escape of the accused.
+The night 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.
+(4)
+The right to be reasonably heard at any public proceeding in the district court
+involving release, plea, or sentencing
+(5)
+(б)
+(7)
+(8)
+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's dignity and
+privacy.
+Members of the 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 !
+, or Special Agent
+From the Federal Bureau of Investigation at
+You also can contact the Justice Department's Office for Victims of Crime in
+Washington, D.C. at 1
+That Office has a website at www.ovc.gov.
+You can seek the advice of an attomey with respect to the rights listed above and, if you
+believe that the rights set forth above are being violated, you have the right lo petition the Court for
+relief.
+EFTA00205238
+
+07/09/2008 15:14 FAX 5618059846
+USAO WPB CONFR
+2025
+Gase 9:08-cv-80736-KAM Document 48-4 Entered on FLSD Docket 03/21/2011 Page 3 of 3
+MISS TEA
+AUGUST 11, 2006
+PAGE 2
+In addition to these rights, you are entitled to counseling and medical services, and pr ›:
+from intimidation and harassment. If the Court determines that you are a victim, you alin i;
+entitled to restitution from the perpetrator. A list of counseling and medical service prox ri
+be provided to you, if you so desire. If you or your family is subjected to any intim..!.t
+harassment, please contact Special Agent
+or myself immediately. It is posser i
+someone working on behalf of the targets of the investigation may contact you. Such cont
+not violate the law. However, if you are contacted, you have the choice of speaking to tid ;
+or refusing to do so. If you refuse and feel that you are being threatened or harassed, Ir:
+contact
+or myself.
+You also are entitled to notification of upcoming case events. At this time, your ca:. •
+nvestigation. If anyone is charged in connection with the investigation, you will be noti
+Sincerely.
+R. Alexander Acosta
+United States Attorney
+EFTA00205239

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vision-joined/ds9-unparsed-06/bf7872d1d86c92281c97ea04283af96ac5933cd90e661d1483f0408daa966f81.md

@@ -0,0 +1,110 @@
+bedwards@pathtojustice.com/
+Subject: RE: Voluntary Production of Materials?
+Date: Mon, 09 Jan 2012 20:31:11 +0000
+Importance: Normal
+As mentioned last week, Brad and I wanted to chat with you about where we are on discovery in this case. I spoke with
+Brad, and while our recollection of what you promised you were going to do may be slightly different than ours, we
+believe there was at least a general agreement to the spirit of the voluntary production - that is, you were going to
+cooperate to the extent that you are able.
+As we explained on our phone call, we requested the things that we would like produced. While you may believe those
+requests to be overly broad and may assert that legal objection in your responses, you indicated that you would be willing
+to produce certain documents that may not be all the documents in your possession responsive to the request but that
+would amount to some documents or materials that we do not yet have. Without making us go through the unnecessary
+exercise of narrowing our requests, it would be most helpful if you would just shoot us over whatever documents or
+materials that you are willing to share with us voluntarily. We will agree that whatever production you make does not
+constitute a waiver of any legal objection you may have to any discovery request.
+So, are you willing to produce anything to us is, I guess, the bottom line. Thanks for any voluntary help you can extend.
+Paul Cassell
+Co-Counsel for Jane Doe #1 and Jane Doe #2
+Paul G. Cassell
+Ronald N. Boyce Presidential Professor of Criminal Law
+CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only
+for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended
+recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error,
+please immediately notify the sender by reply electronic mail and delete the original message. Thank you.
+Sent: Saturday, January 07, 2012 8:08 AM
+To: Paul Cassell
+Subject: Re: Replies and Responses Due on January 6, 2012
+EFTA00205139
+
+Thanks. Hope everyone has a great weekend.
+Ed
+From: Paul Cassell [mailto:cassellp@law.utah.edu]
+Sent: Friday, January 06, 2012 07:00 PM
+. Brad Edwards <bedwards@pathtojustice.com>
+Subject: RE: Replies and Responses Due on January 6, 2012
+1.
+Thanks for the clarification on the 90 day rule.
+2. Brad and I need to confer about the discovery issues, but that is not a basis for our withholding consent for an
+extension. So you may indicate that we consent to the extension. Brad and I have a different recollection about
+discovery issues than you do. But let's chat about that next week.
+Sorry to hear y'all are working at 7 PM on Friday night. Paul
+Paul G. Cassell
+CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only
+for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended
+recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error,
+please immediately notify the sender by reply electronic mail and delete the original message. Thank you.
+Sent: Friday, January 06, 2012 4:07 PM
+ToR Paul Cassell
+Brad Edwards
+Subject: RE: Replies and Responses Due on January 6, 2012
+Hi, Paul.
+As always, we appreciate your efforts to be accommodating. With respect to the conditions that you have placed on your
+agreement to the requested extension:
+(1) No 90-day notice is called for by Local Rule 7.1(b)(4) for the motions/responses/replies connected to the
+requested extension because none is a "motion or other matter which has been pending and fully briefed" and
+none is a "motion or other matter as to which the Court has conducted a hearing." In any event, after the recent
+amendments to the Local Rules, the 90-day notices are only "serve[d] on all parties and any affected non-
+parties." Court filing of the 90-day notices is no longer contemplated by the Local Rules.
+(2) As to our discussion in early December, we have a different recollection. At that time, notwithstanding our
+motion to stay discovery, we expressed a willingness to work with you and Brad to attempt to identify items that
+EFTA00205140
+
+might be producible by the government pursuant to a narrowed and specific request for production that seeks
+relevant items and where the production by the government would not be burdensome or otherwise
+objectionable. We remain willing to work toward such a goal, but have been waiting to hear from you or Brad to
+begin the process of identifying the items that would be the subject of such a narrowed request. In fact,
+called Brad several weeks ago to discuss the requests for admissions, but they were unable to connect at that
+time.
+If the government's position on these two points causes you to withhold your agreement to our requested extension, we
+would be happy to inform the Court that you oppose our motion for extension of time. If we do not hear from you by
+7:00 pm Miami time that you agree to the requested extension notwithstanding the government's position on these two
+points, we will report to the Court that you object to the extension. Please be sure to send any reply concerning your
+position to Dexter, as he will be filing the motion for extension this evening.
+Thanks, and have a nice weekend.
+From: Paul Cassell [mailto: cassellp@law.utah.edu]
+Sent: Friday, January 06, 2012 10:41 AM
+subjeccaRe, Repies and Responses Due on January 6, zuIz
+As you know, we're happy to try and be accommodating. We would be glad to consent to additional time, but
+would ask in exchange for two things:
+1. The various delays mean that several motions have now been (or will shortly be) pending for more than 90
+days, triggering a 90 day report obligation under the local rules. We would trust you would be willing to file
+2. When we finished our telephone call with you some weeks back, Brad and I understood that we would be
+receiving (a) some initial discovery in the case and (b) a list of additional discovery that we could expect if
+your motion to dismiss is denied. But we have yet to receive anything at all regarding discovery. We would
+trust that you will carry through on what we understood you had agreed to in the telephone call.
+Again, we are happy to help - but would ask you to help us on these two points. Thanks!
+Paul Cassell
+Co-counsel for Jane Doe #1 and Jane Doe #2
+Paul G. Cassell
+EFTA00205141
+
+ge is
+intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it
+to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have
+received this message in error, please immediately notify the sender by reply electronic mail and delete the original
+Sent: Thursday, January 05, 2012 5:24 PM
+To: Paul Cassell; Brad Edwards
+Subject: Replies and Responses Due on January 6, 2012
+Paul and Brad,
+Happy New Year. I need to ask if you have an objection to the government seeking a second enlargement of
+time, up to Tuesday, January 24, 2012, to file replies to the victims' two responses to the government's motion to
+dismiss and motion to stay discovery, and responses to the victims' protective motion to compel and protective
+motion for remedies.
+* is preparing for an evidentiary hearing in a 28 U.S.C. 2255 motion, which is scheduled for January 24,
+2012. I am scheduled to go to trial in a tort case sometime during the two week trial period commencing January
+17, 2012. I have spent most of the preceding two weeks getting ready for the trial. My colleague Ed Sanchez,
+with sporadic assistance from
+and I, will be preparing the responses and replies.
+Please let me know if you have any objections. Thanks.
+EFTA00205142

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vision-joined/ds9-unparsed-06/bfa30ee673c0cff62ff097cf4c42f9e3b7d885f2c9c6812bfbc11add82803815.md

@@ -0,0 +1,18 @@
+From: "Schultz, Anne (USAFLS)" <ASchultz@usa.doj.gov>
+To: "Villafana, Ann Marie C. (USAFLS)" <AVillafana@usa.doj.gov>
+Subject: RE: Jane Does | US
+Date: Thu, 20 Jun 2013 15:14:07 +0000
+Importance: Normal
+BTW, I don't think I have Roy Black's email, but I'll go back and double check my emails in case I overlooked it.
+-----Original Message-----
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Thursday, June 20, 2013 10:17 AM
+To: Lee, Dexter (USAFLS); Schultz, Anne (USAFLS); Sanchez, Eduardo (USAFLS); Yera, E.J. (USAFLS)
+Subject: Jane Does | US
+Hi everyone: I know you received Roy Black's email. He also left me a voicemail. When are you available to
+discuss? I am in debriefings but can step out as needed. Thank you.
+PS: should we ask Mike Rotker to attend to discuss appellate issues?
+A. Marie Villafaña
+Assistant US Attorney
+Sent from my iPhone
+EFTA00205281

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vision-joined/ds9-unparsed-06/c0472e72b7aec61813e138ee3340acdb4f63d4324a068de3ca22544c42b4f876.md

@@ -0,0 +1,14 @@
+From:
+To:
+Cc:
+Subject: Jane Does v. U.S. - Draft Motion to Stay Discovery
+Date: Sat, 05 Nov 2011 19:37:35 +0000
+Importance: Normal
+Attachments: jane_does_Motion_stayDisc.wpd
+and
+Attached please find my draft motion to stay discovery. In the factual background section, I review many of the requests,
+in an attempt to demonstrate how petitioners are overreaching into irrelevant areas. I don't believe the stay motion
+needs to be filed under seal, unless expressing the view that a case still exists, in which petitioners can consult with the
+attorney for the government, is not a matter to be disclosed in a public filing.
+I reviewed your motion to dismiss and it is excellent. I have no suggestions or revisions.
+EFTA00204931

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@@ -0,0 +1,369 @@
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 1 of 14
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA/JOHNSON
+JANE DOES #1 AND #2,
+Plaintiffs,
+VS.
+UNITED STATES,
+Defendant.
+ORDER
+THIS CAUSE is before the Court upon Plaintiffs' Motion for Finding of Violations of the
+Crime Victims' Rights Act (DEs 48, 52), Plaintiffs' Motion to Have Their Facts Accepted
+Because of the Government's Failure to Contest Any of the Facts (DE 49), Plaintiffs' Motion for
+Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence (DE 50), and
+Motion to Intervene or in the Alternative for a Sua Sponte Rule 11 Order
+(DE 79).' All motions are fully briefed and ripe for review, and the Court has heard oral
+arguments on all motions.
+The Court has carefully considered the briefing and the parties?
+arguments and is otherwise fully advised in the premises.
+' The Court is awaiting supplemental briefing on the Motion to Intervene of Roy Black,
+Martin Weinberg, and Jay Lefkowitz (DE 56) and will rule on that motion after it is fully briefed.
+Also, because the proposed interveners seek intervention to request a protective order against
+disclosure of certain correspondences at issue in Plaintiffs' Motion to Use Correspondence to
+Prove Violations of the Crime Victims' Rights Act and to Have Their Unredacted Pleadings
+Unsealed (DE 51), the Court will defer ruling on the latter motion until the intervention motion is
+ripe for review.
+EFTA00205830
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 2 of 14
+Background'
+Plaintiffs Jane Doe #1 and Jane Doe #2 are alleged victims of federal sex crimes
+committed by Jeffrey Epstein in Palm Beach County. Between 2001 and 2007, Epstein sexually
+abused multiple underage girls at his Palm Beach mansion, including Plaintiffs. In 2006, the
+Federal Bureau of Investigation ("FBI") opened an investigation into allegations that Epstein was
+inducing underage girls to engage in sexual acts. The case was eventually presented to the
+United States Attorney's Office for the Southern District of Florida, which accepted it for
+investigation. The Palm Beach County State Attorney's Office was also investigating similar
+allegations against Epstein. Plaintiffs allege that the FBI and U.S. Attorney's Office's
+investigation developed a strong case for a federal prosecution against Epstein based on
+"overwhelming" evidence.
+In June 2007, the FBI delivered to Jane Doe #1 a standard victim-notification letter,
+which explained that the case against Epstein was "under investigation" and notified Jane Doe #1
+of her rights under the Crime Victims' Rights Act ("CVRA"). In August 2007, Jane Doe #2
+received a similar notification letter.
+In September 2007, Epstein and the U.S. Attorney's Office began plea discussions. The
+negotiations led to an agreement under which Epstein would plead guilty to two state felony
+offenses for solicitation of prostitution and procurement of minors for prostitution and the U.S.
+= This background discussion is based on the allegations in Plaintiffs' Petition for
+Enforcement of Crime Victims' Rights Act (DE 1) and the Statement of Material Facts in
+Plaintiffs' Motion for Finding of Violation of the Crime Victims' Rights Act (DEs 48, 52).
+These allegations are not yet supported by evidence and the Court relies on them here solely to
+provide the context for the threshold legal issues addressed in this order. As discussed below,
+further factual development is necessary to resolve the additional issues raised in Plaintiffs'
+motions.
+2
+EFTA00205831
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 3 of 14
+Attorney's Office would agree not to prosecute Epstein for federal offenses. On September 24,
+2007, Epstein and the U.S. Attorney's Office executed a Non-Prosecution Agreement ("NPA")
+under these terms.
+Plaintiffs contend that the U.S. Attorney's Office did not confer with them regarding the
+plea discussions and, in fact, intentionally kept secret the negotiations and the NPA. From
+September 24, 2007, the day on which the NPA was executed, through June 2008, the U.S.
+Attorney's Office did not notify either Plaintiff of the existence of the NPA.
+During this period, Plaintiffs communicated multiple times with the FBI and U.S.
+Attorney's Office, but neither Plaintiff was informed of the NPA. On January 10, 2008, the FBI
+sent letters to Plaintiffs advising them that "It]his case is currently under investigation," but
+failing to disclose the existence of the NPA. On January 32, 2008, Jane Doe #1 met with FBI
+agents and attorneys from the U.S. Attorney's Office to discuss her abuse by Epstein. The
+government did not disclose the existence of the NPA. In mid-June 2008, Plaintiffs' counsel
+contacted the Assistant United States Attorney ("AUSA") handling their case to discuss the
+status of the investigation. The AUSA did not disclose the existence of the NPA. On June 27,
+2008, the U.S. Attorney's Office notified Plaintiffs' counsel that Epstein was scheduled to plead
+guilty in state court on June 30, 2008. The U.S. Attorney's Office did not disclose the existence
+of the NPA nor the relationship between Epstein's state plea and the U.S. Attorney's Office's
+agreement to forgo federal charges. On July 3, 2008, Plaintiffs' counsel sent a letter to the U.S.
+Attorney's Office stating Jane Doe #1's desire that it bring federal charges against Epstein.
+3
+EFTA00205832
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 4 of 14
+On July 7, 2008, Jane Doe #1 filed a petition in this Court to enforce her rights under the
+CVRA. Jane Doe #1 alleged that she believed plea discussions were under way between Epstein
+and the U.S. Attorney's Office, and that the government, by failing to notify her of this
+development, had violated her rights under the CVRA. The United States responded to the
+petition on July 9, 2008, arguing that (1) a federal indictment had never been returned against
+Epstein and therefore the CVRA did not attach, and (2) nevertheless, the U.S. Attorney's Office
+had used its best efforts to comply with the CVRA. The government's response also disclosed
+that the U.S. Attorney's Office had entered into the NPA with Epstein.
+On July 11, 2008, this Court held a hearing on Jane Doe #1's petition, at which Jane Doe
+#2 was added as a plaintiff. At the hearing, Plaintiffs explained that their petition did not present
+an emergency and that therefore an immediate resolution was not necessary. On August 14,
+2008, the Court held a status conference and ordered the United States to turn over the NPA to
+all identified victims, including Plaintiffs, and further ordered the parties to work out the terms of
+a protective order governing the NA's disclosure.
+This action was relatively inactive for the next year and one-half while Plaintiffs litigated
+civil actions against Epstein. After those cases settled, Plaintiffs attempted to resolve their
+CVRA dispute with the U.S. Attorney's Office. On March 18, 2011, after the parties" settlement
+efforts failed, Plaintiffs filed a series of motions, which the Court now addresses in turn, along
+with
+Motion to Intervene.
+3 Jane Doe #2 joined this action after Jane Doe #1 filed the initial Petition for
+Enforcement of Crime Victims' Rights Act.
+4
+EFTA00205833
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 5 of 14
+Motion for Finding of Violations of the Crime Victims' Rights Act
+The CVRA was designed to protect victims' rights and ensure them involvement in the
+criminal-justice process. United States I. Moussaoui, 483 F.3d 220, 234 (4" Cir. 2007); Kenna I
+U.S. Dist. Court, 435 F.3d 1011, 1016 (9" Cir. 2006) ("The [CVRA] was enacted to make crime
+victims full participants in the criminal justice system."). The statute enumerates the following
+eight rights:
+(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.
+18 U.S.C. § 3771(a).
+If a prosecution is underway, the CVRA grants victims standing to vindicate their rights
+in the ongoing criminal action. 18 U.S.C. § 3771(d)(3). If, however, a prosecution is not
+underway, the victims may initiate a new action under the CVRA in the district court of the
+5
+EFTA00205834
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 6 of 14
+district where the crime occurred.* Id. The statute also tasks the district courts and the
+prosecutors with the responsibility of protecting these rights. See 18 U.S.C. § 3771(b)(1) ("IT]he
+court shall ensure that the crime victim is afforded the rights described in subsection (a)."); §
+3771(c)(1) ("Officers and employees of the Department of Justice ... shall make their best
+efforts to see that crime victims are notified of, and accorded, the rights described in subsection
+(a).").
+Here, Plaintiffs first argue that as a matter of law the CVRA's protections attach before a
+formal charge is filed against the criminal defendant. Accordingly, Plaintiffs contend that the
+CVRA applied here and that the U.S. Attorney's Office violated their CVRA rights; namely,
+their rights to confer, to be treated with fairness, and to accurate and timely notice of court
+proceedings. Based on these violations, Plaintiffs request that this Court set a briefing schedule
+and hearing on the appropriate remedy, which according to Plaintiffs is to invalidate the non-
+prosecution agreement.
+The United States argues that as a matter of law the CVRA does not apply before formal
+charges are filed, i.e., before an indictment or similar charging document, and therefore does not
+apply here because formal charges were never filed against Epstein. The United States further
+argues that even if the CVRA applied here, the U.S. Attorney's Office complied with its
+requirements.
+The Court first addresses the threshold issue whether the CVRA attaches before the
+government brings formal charges against the defendant The Court holds that it does because the
+"Here, because no criminal case was pending, Plaintiffs filed their petition as a new
+matter in this judicial district, which the Clerk of Court docketed as a civil action.
+6
+EFTA00205835
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 7 of 14
+statutory language clearly contemplates pre-charge proceedings. For instance, subsections (a)(2)
+and (a)(3) provide rights that attach to "any public court proceeding ... involving the crime."
+Similarly, subsection (b) requires courts to ensure CVRA rights in "any court proceeding
+involving an offense against a crime victim." Court proceedings involving the crime are not
+limited to post-complaint or post-indictment proceedings, but can also include initial appearances
+and bond hearings, both of which can take place before a formal charge. By way of example,
+under Rule 5(a)(1)(A) of the Federal Rules of Criminal Procedure, upon arrest the defendant
+must be taken before a magistrate judge "without unnecessary delay" for an initial appearance. If
+the arrest takes place on a weekday, "without unnecessary delay" will typically require that the
+initial appearance occur the following morning, which will often be within twenty-four hours of
+arrest. See United States I. Mendoza, 473 F.2d 697, 702 (5" Cir. 1973) (holding that the
+government satisfied Rule 5's "without unnecessary delay" requirement by bringing the
+defendant before the magistrate judge on the first weekday morning following the arrest). By
+contrast, Rule 5(b) requires that where the defendant is arrested without a warrant, the
+government must file the complaint "promptly." The Supreme Court has interpreted "promptly"
+under Rule 5(b) as generally requiring that the complaint be filed within forty-eight hours of
+arrest. Cnty. Of Riverside I. McLaughlin, 500 U.S. 44, 56-57 (1991). It is therefore possible that
+where the defendant is arrested on a weekday without a warrant, the initial appearance—which
+may also involve the detention or bond hearing under Rule 5(d)(3)-will take place before the
+government files the criminal complaint.
+Subsection (c)(1) requires that "Officers and employees of the Department of Justice and
+other departments and agencies of the United States engaged in the detection, investigation, or
+7
+EFTA00205836
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 8 of 14
+prosecution of crime shall make their best efforts to see that crime victims are notified of, and
+accorded, the rights in subsection (a)." (Emphasis added). Subsection (c)(1)'s requirement that
+officials engaged in "detection [or] investigation" afford victims the rights enumerated in
+subsection (a) surely contemplates pre-charge application of the CVRA.
+Subsection (d)(3) explains that the CVRA's enumerated rights "shall be asserted 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." (Emphasis added). If
+the CVRA's rights may be enforced before a prosecution is underway, then, to avoid a strained
+reading of the statute, those rights must attach before a complaint or indictment formally charges
+the defendant with the crime.
+This interpretation is consistent with other federal decisions that have addressed the scope
+of the CVRA. For instance, in In re Dean, 527 F.3d 391 (5" Cir. 2008), the court held that
+subsection (a)(5)'s "right to confer" applied before any prosecution is underway. Id. at 394.
+Specifically, the court explained:
+The district court acknowledged that "there are clearly rights under the CVRA that
+apply before any prosecution is underway." Logically, this includes the CVRA's
+establishment of victims" "reasonable right to confer with the attorney for the
+Government." At least in the posture of this case (and we do not speculate on th
+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.
+Id. at 394 (internal citation and quotation marks omitted). Federal district courts have reached
+similar conclusions. See, e.g., United States . Rubin, 558 F. Supp. 2d 411, 417 n.5 (E.D.N.Y.
+2008) (discussing victims' "ability to seek pre-prosecution relief" under the CVRA); United
+States I. Okun, No. 08-132, 2009 WL 790042, at *2 (E.D. Va. Mar. 24, 2009) ("IT]he Fifth
+EFTA00205837
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 9 of 14
+Circuit has noted that victims acquire rights under the CVRA even before prosecution. This
+view is supported by the statutory language, which gives the victims rights before the accepting
+of plea agreements and, therefore, before adjudication of guilt."); United States I. BP Prods N.
+Am. Inc., No. 07-434, 2008 WL 501321, at *11 (S.D. Tex. Feb. 21, 2008) ("There are clearly
+rights under the CVRA that apply before any prosecution is underway."), mandamus denied in
+part, In re Dean 527 F.3d 391 (5"' Cir. 2008).
+The United States argues that because the CVRA accords rights related to "any court
+proceeding," 18 U.S.C. §§ 3771(b)(1), (d)(3), and "in the case," § 3771(b)(5), the CVRA applies
+only after formal charges are filed. The Court finds this argument unavailing. First, as discussed
+above, "court proceedings" can occur before formal charges are filed. Similarly, subsection
+(a)(5)'s reference to the right to confer with "the attorney for the Government in the case," is not
+limited to post-charge proceedings, as the United States is represented by attorneys in each
+criminal case at, for example, initial appearances and bond hearings. Last, the government's
+interpretation ignores the additional language throughout the statute that clearly contemplates
+pre-charge protections, such as subsection (c)(1)'s mandate that U.S. agencies involved at the
+"detection" and "investigation" stage use their best efforts to accord victims their enumerated
+rights under the CVRA and subsection (d)(3)'s provision that victims may vindicate their CVRA
+s For this reason, the Court respectfully disagrees with the interpretation adopted in In re
+Petersen, No. 10-298, 2010 WL 5108692 (N.D. Ind. Dec. 8, 2010), upon which the United States
+relies. See id. at *2 (holding that a "victim's "right to be treated with fairness and with respect
+for [his or her] dignity and privacy' may apply before any prosecution is underway and isn't
+necessarily tied to a 'court proceeding' or 'case,' but concluding that "the right "to confer with
+the attorney for the Government in the case' ... arise[s] only after charges have been brought
+against a defendant and a case has been opened"). But see In re Dean, 527 F.3d at 394 (holding
+that under subsection (a)(5), "the government should have fashioned a reasonable way to inform
+the victims of the likelihood of criminal charges").
+9
+EFTA00205838
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 10 of 14
+rights even if "no prosecution is underway." See United States I. DBB, Inc., 180 F.3d 1277,
+1281 (11" Cir. 1999) ("[W]e read the statute to give full effect to each of its provisions. We do
+not look at one word or term in isolation, but instead we look to the entire statutory context.")
+(citation omitted).
+The Court also rejects the United States' argument that pre-charge CVRA rights could
+impair prosecutorial discretion and decision-making. Any encroachment into the prosecutors'
+discretion is expressly limited by the CVRA itself, which provides: "Nothing 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. § 3771(d)(6). As the court explained in Rubin, "there is absolutely no
+suggestion in the statutory language that victims have a right independent of the government to
+prosecute a crime, set strategy, or object to or appeal pretrial or in limine orders .... In short, the
+CVRA, for the most part, gives victims a voice, not a veto." 558 F. Supp. at 418; see also BP
+Prods N. Am., 2008 WL 501321, at *15 ("Even under an expansive approach, the reasonable
+right to confer on a proposed plea agreement and the government's obligation to provide notice
+of that right is subject to the limit that the CVRA not impair prosecutorial discretion."). Thus, to
+the extent that the victims' pre-charge CVRA rights impinge upon prosecutorial discretion, under
+the plain language of the statute those rights must yield.
+Having determined that as a matter of law the CVRA can apply before formal charges are
+filed, the Court must address whether the particular rights asserted here attached and, if so,
+whether the U.S. Attorney's Office violated those rights. However, the Court lacks a factual
+record to support such findings and must therefore defer ruling on these two issues pending the
+limited discovery discussed below.
+10
+EFTA00205839
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 11 of 14
+11.
+Motion to Have Their Facts Accepted Because of the Government's Failure to
+Contest Any of the Facts
+For the reasons stated on the record at the August 12, 2011 hearing on this motion, the
+Court will deny Plaintiffs' request to have their facts accepted as true.
+Ill.
+Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant
+Evidence
+Plaintiffs request an order from the Court "directing the U.S. Attorney's Office not to
+suppress material evidence relevant to this case." (DE 50 at 1). Specifically, Plaintiffs seek all
+information and material known to the government that may be favorable to the victims
+regarding possible violations of their rights under the CVRA. The United States opposes the
+motion, arguing that neither the CVRA nor the Federal Rules of Civil Procedure impose a duty
+upon the U.S. Attorney's Office to provide evidence to Plaintiffs here.
+At the August 12, 2011 hearing on this motion, the United States agreed that this Court,
+under its inherent authority to manage this case, could impose discovery obligations on each
+party. Because the Court finds that some factual development is necessary to resolve the
+remaining issues in this case, it will permit Plaintiffs the opportunity to conduct limited
+discovery in the form of document requests and requests for admissions from the U.S. Attorney's
+Office. Either party may request additional discovery if necessary.
+Because the Court will allow this limited factual development, it is unnecessary to decide
+here whether the CVRA or the Federal Rules of Civil Procedure provide discovery rights in this
+context. The Court therefore reserves ruling on Plaintiffs' motion.
+EFTA00205840
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 12 of 14
+IV.
+Motion to Intervene or in the Alternative for a Sua Sponte Rule
+11 Order
+Bruce E. Reihart seeks leave to intervene as a party-in-interest under Rule 24(b) of the
+Federal Rules of Civil Procedure. Reinhart seeks to intervene to file a motion for sanctions
+based on allegedly "unfounded factual and legal accusations made about Movant in Plaintiffs"
+Motion for Finding of Violations of the Crime Victims' Rights Act." (DE 79 at 1). In that
+motion, Plaintiffs alleged that Reinhart, a former Assistant U.S. Attorney, "joined Epstein's
+payroll shortly after important decisions were made limiting Epstein's criminal liability" and
+improperly represented Epstein victims in follow-on civil suits. (DE 48 at 22). Plaintiffs
+contend that such conduct "give[s], at least, the improper appearance that Reinhart may have
+attempted to curry [favor] with Epstein and then reap his reward through favorable employment."
+(DE 48 at 23). Reinhart takes great offense to these accusation-
+-which he contends are false,
+irrelevant to the CVRA claims, and gratuitous and seeks intervention to rebut these allegations
+and move for sanctions.
+Under Rule 24(b) of the Federal Rules of Civil Procedure, "the court may permit anyone
+to intervene who ... has a claim or defense that shares with the main action a common question
+of law or fact." It is "wholly discretionary with the court whether to allow intervention under
+Rule 24(b) and even though there is a common question of law or fact, or the requirements of
+Rule 24(b) are otherwise satisfied, the court may refuse to allow intervention." In re Bayshore
+Ford Trucks Sales, Inc., 471 F.3d 1233, 1246 (11"" 2006). The Court will deny
+request to intervene.
+12
+EFTA00205841
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 13 of 14
+First, the Court finds that |
+• claim does not share a common question of law or
+fact with the CVRA action. Reinhart claims that two paragraphs of Plaintiffs' forty-page motion
+make groundless and bad-faith accusations against his integrity and character. However, the
+veracity of Plaintiffs' two paragraphs —i.e., whether Reinhurt used his position at the U.S.
+Attorney's Office to ingratiate himself with Epstein and advance his career in private
+practice-involves no common questions with the Plaintiffs' claims that the U.S. Attorney's
+Office violated their CVRA rights through the process in which it entered into the NPA with
+Epstein. Indeed, I
+motion argues that the allegations against him are "irrelevant" and
+that Plaintiffs "do[] not make any effort to connect these allegations to the relief [they] seek[]."
+(DE 79 at 2).
+Second, even if these accusations shared common questions with Plaintiffs' CVRA
+claims, the Court would exercise its discretion and deny intervention. The Court cannot permit
+anyone slighted by allegations in court pleadings to intervene and conduct mini-trials to vindicate
+their reputation. Absent some other concrete interest in these proceedings, the Court does not
+believe that the allegations here are sufficiently harmful to justify permissive intervention.
+Reinhart has publicly aired his opposition to and denial of Plaintiffs' contentions, both on this
+docket and in open court, and the Court finds that further proceedings on this issue are
+unwarranted. For the same reason, the Court declines to conduct a sua sponte Rule 11 inquiry.
+Conclusion
+For the foregoing reasons, it is hereby ORDERED AND ADJUDGED that Plaintiffs'
+Motion for Finding of Violations of the Crime Victims' Rights Act (DEs 48, 52) is GRANTED
+IN PART. The Court concludes that the CVRA can apply before formal charges are filed. The
+13
+EFTA00205842
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 14 of 14
+Court defers ruling on the merits of Plaintiffs' CVRA claims until the parties complete the
+discovery ordered herein.
+It is further ORDERED AND ADJUDGED that Plaintiffs' Motion to Have Their Facts
+Accepted (DE 49) is DENIED.
+The Court reserves ruling Plaintiffs' Motion for Order Directing the U.S. Attorney's
+Office Not to Withhold Relevant Evidence (DE 50) pending the discovery ordered herein.
+It is further ORDERED AND ADJUDGED that
+Motion to Intervene
+or in the Alternative for a Sua Sponte Rule 11 Order (DE 79) is DENIED.
+DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County, Florida
+this 26" day of September, 2011.
+KENNETH A. MARRA
+United States District Judge
+14
+EFTA00205843

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+From:
+To:
+(Other)
+Date: Tue, 24 Apr 2012 19:38:12 +0000
+Importance: Normal
+Subject: Activity in Case 9:08-cv-80736-KAM Doe |. United States of America Response/Reply
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered on 4/24/2012 at 3:38 PM EDT and filed on 4/23/2012
+Case Name:
+Case Number:
+Filer:
+Doe | United States of America
+9:08-CV-80736-KAM
+Roy Black
+Jeffrey Epstein
+Jay Lefkowitz
+Martin G. Weinberg
+Document Number: 170(No document attached)
+Docket Text:
+REPLY to [164] Supplemental Briefing by Roy Black, Jeffrey Epstein, Jay Lefkowitz, Martin G.
+Weinberg. (Is)(See Image at DE #[169])
+9:08-cv-80736-KAM Notice has been electronically mailed to:
+Bradley James Edwards
+Bruce Reinhart
+Jacqueline Perczek
+Jay L. Howell
+Jay P. Lefkowitz
+EFTA00205534
+
+Martin G. Weinberg
+Paul G. Cassell
+Roy Eric Black
+9:08-cv-80736-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-
+1:
+EFTA00205535

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+Subject: RE: Memo regarding Conflict in Epstein Investigation
+Date: Tue, 26 Jul 2011 21:07:23 +0000
+Importance: Normal
+Thanks. Could you send it in WP? Thanks again.
+subject: Memo regarding Conflict in Epstein Investigation
+Hi Ben - Here is the Memo you requested during our conference call. Please let me know if you want it in Word
+Perfect so you can cut and paste it into a letter to DC.
+Thank you. Sorry for the delay.
+« File: Epstein Conflict Memo.pdf >>
+EFTA00205968

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+ATTACHMENT 1
+USER LITIGATION HOLD NOTICE AND CERTIFICATION FORM
+PRIVACY ACT PROTECTED
+1. NOTICE
+Please be advised that, by and through this Notice, we, the United States Attorney's Office for the Southern District of
+Florida ("USAO"), have instituted a "Litigation Hold" in connection with the claims set forth in Jane Does #1 and #2 l
+United States, Case No.: 08-80736-CIV-MARRA/Johnson regarding alleged violation of the petitioners' rights
+under the Crime Victim's Rights Act ("CVRA").
+To institute this Litigation Hold, we are implementing preservation procedures regarding any and all records, data, or other
+information, whether they exist in paper form or as electronically stored information ("ES/"), within the USAO's possession,
+custody or control relating to the Complaint/Claims (collectively, "Information"). The USAO's obligation to preserve this
+Information pertains not only to paper copies, or "hard copies" (whether in draft or final, partial or complete, versions), but
+also to ESI in its originally-created, or "native" format, as it exists on any computer system (whether it be on the USAO's
+system or your personal computer), as well as removable or portable electronic storage media. Specific examples of
+Information subject to this Litigation Hold include, but are not limited to, e-mails and other electronic communications,
+word processing documents, records, spreadsheets, databases, calendars, telephone logs, internet usage files, network
+access information, and information on other kinds of media, including PDAs (such as Palm Pilots, BlackBerries, and cell
+phones), thumb drives, CDs, as well as digital voicemail and text messages.
+Because the USAO must take reasonable steps to preserve such Information in whatever form it has been created and
+maintained, the USAO's Lit Hold Coordinator and Systems Manager must coordinate with all those who may have such
+Information. We therefore require your assistance to both identify and preserve any and all Information relating to the
+Complaint/Claims, whether or not the Information is ultimately discoverable. Furthermore, we must confirm that you
+understand and accept your preservation obligations under this Litigation Hold.
+Accordingly, you are required to take the two following steps: (1) Identify to us all such Information and where it resides (in
+Section Il below); and (2) Certify having received notice of this Litigation Hold and understanding and accepting your
+preservation obligations under this Litigation Hold (in Section III below). [NOTE: While seeking to identify all such
+Information, please refrain to the maximum extent possible from opening emails/files you believe to be relevant.]
+IDENTIFY ALL INFORMATION SUBJECT TO THE LITIGATION HOLD
+Please identify all locations where the Information described above may exist: CHECK ALL THAT APPLY
+Hard Copy Documents:
+X Printed Emails
+X Case Files/Logs
+USAO System - Microsoft Outlook:
+Xl Email Messages
+Calendar Items
+A Tasks
+• Notes
+X Public Folders-
+A Contacts
+X PST Files ("Archive") C Office Communicator
+(continued on next page)
+• Calendars/Appointment Books
+USAO System - EVoll:
+• Telephone Data
+X Other
+Attachment 1, USAP 3-13.300.003
+Page |1
+EFTA00206891
+
+ATTACHMENT 1
+(continued from previous page)
+USAO System - Network Data (i.e., documents/files and folders residing on network drives):
+Personal (N, H & M) Drive Document/Files/Folders Shared Files/Folders LUONs/Alcatraz/USA-5
+• Inter- and Intra-net • Other
+USAO System - Mobile PIN/SMS:
+* Blackberry/Other
+USAO System - Classified/Special Data:
+• Document/Files/Folders/Other
+Non-Network Data (i.e., documents/files and folders residing on local hord drives and thumb drives:
+XLocal (C & D) Drives Portable Media/Thumb Drives [ Deleted items (Recycle Bin)
+Personal Non-Network Data (located or residing somewhere other than the USAO System):
+• Document/Files/Folders • Internet Email Messages • Portable Media/Thumb Drives
+• PDAs/Other
+III. CERTIFICATION
+By this Notice and Certification, I acknowledge that I have received, understand, and accept my obligations to preserve any
+and all Information (as defined above) I may have now, as well as all such Information I may subsequently receive, create or
+modify. I further understand and accept that my continuing Litigation Hold obligations require that I preserve all such
+Information in "native" format and, conversely, that I not delete or destroy any such Information until I receive formal
+written notice that this Litigation Hold is discontinued. To fulfill these continuing obligations, I will undertake the necessary
+steps to preserve this Information, be it "hard copy" and/or ESI, in coordination with the USAO's Lit Hold Coordinator and
+Systems Manager.
+Please be advised that failure to preserve and retain this Information may result in sanctions and/or implicate professional
+conduct rules. Consequently, if you are unsure whether certain information should be preserved, err on the side of caution
+and preserve the information until you have spoken to the USAO's Lit Hold Coordinator about it. If you have any questions
+about whether to preserve certain ESI, or its native formatting, please contact the USAO's Lit Hold Coordinator or Systems
+Manager.
+Please sign below to acknowledge you have read this Notice and Certification and understand and accept your preservation
+obligations, then return the executed copy to the USAO's Lit Hold Coordinator. Thank you.
+INFORMATION CONTAINED IN THIS FORM MAY CONSTITUTE PRIVATE, CONFIDENTIAL AND/OR SENSITIVE, AS
+WELL AS PERHAPS ALSO PRIVILEGED AND/OR OTHERWISE PROTECTED, INFORMATION
+Attachment 1, USAP 3-13.300.003
+Page |2
+EFTA00206892

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+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+January 22, 2010
+VIA ELECTRONIC MAIL
+Spencer T. Kuvin, Esq.
+Leopold~Kuvin, P.A.
+2925 PGA Boulevard
+Suite 200
+Palm Beach Gardens, FL 33410
+Re: Jeffrey Epstein/B.B.
+Dear Mr. Kuvin:
+Thank you for your letter regarding the deposition of Mr. Reiter. I have not received or
+reviewed a copy of Mr. Reiter's deposition, so I do not know the substance of his testimony.
+In response to your questions, no computer was seized from Mr. Epstein's home, and the
+FBI did not return any computer equipment to Mr. Epstein, or any lawyer or investigator
+working for Mr. Epstein. While Chief of Police, Mr. Reiter was provided with a copy of the list
+of identified victims that was provided to Mr. Epstein via his attorneys. A cover sheet provided
+that the document should be treated as confidential, pursuant to Title 18, United States Code,
+Section 3509(d) and Florida Law. Mr. Reiter was not instructed to destroy the letter by the U.S.
+Attorney's Office, although he may have decided to do so of his own accord.
+Regarding your proposed subpoenas, a federal official's testimony cannot be authorized
+without first complying with their employing agency's Touhy regulations. See United States el
+rel. Touhy |. Ragen, 340 U.S. 462, 468 (1951); 5 U.S.C. § 301. The regulations related to the
+Federal Bureau of Investigation can be found at 28 C.F.R. §$ 16.21, et seq. Requests for
+documents are normally handled through FOIA requests. Agency counsel for the FBI handles
+those types of requests.
+Sincerely,
+Jeffrey H. Sloman
+United States Attorney
+By:
+A. Marie Villataña
+Assistant U.S. Attorney
+EFTA00207023