# EXHIBIT A ## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/ IN RE: JANE DOE, Petitioner. / FILED by S D.C. JUL 0 9 2008 ## DECLARATION OF A. VILLAFARA IN SUPPORT OF UNITED STATES' RESPONSE TO VICTIM'S EMERGENCY PETITION FOR ENFORCEMENT OF CRIME VICTIM RIGHTS ACT. 18 U.S.C. § 3771 STEVEN M. LARIMORE CtERK U.S. DIET. CT. S.D. OF FLA. • Witt 1. I, A. Villafafia, do hereby declare that I am amember in good standing of the Bar of the State of Florida. I graduated from the University of California at Berkeley School of Law (Boalt s in 1993. After serving as ajudicial clerk to the Hon. David F. Levi in Sacramento, California, I was admitted to practice in California in 1995. I also am admitted to practice in all courts of the states of Minnesota and Florida, the Eighth, Eleventh, and Federal Circuit Courts of Appeals, and the U.S. District Courts for the Southern District of Florida, the District of Minnesota, and the Northern District of California. My bar admission status in California and Minnesota is currently inactive. I am currently employed as an Assistant United States Attorney in the Southern District of Florida and was so employed during all of the events described herein. 2. I am the Assistant United States Attorney assigned to the investigation of Jeffrey Epstein. The case was investigated by the Federal Bureau of Investigation ("FBI"). The federal investigation was initiated in 2006 at the request of the Palm Beach Police Department ("PBPD") into allegations that Jeffrey Epstein and his personal assistants had used facilities of interstate commerce to induce young girls between the ages of thirteen and seventeen to engage in prostitution, amongst other offenses. 3. Throughout the investigation, when a victim was identified, victim notification letters were provided to her both from your Affiant and from the FBI's Victim-Witness Specialist. Attached hereto are copies of the letters provided to three clients, T.M., C.W., and S.R.' Your Affiant's letter to C.W. was provided by the FBI. (Ex. ). Your Affiant's letter to T.M. was hand-delivered by myself to T.M. at the time that she was interviewed (Ex. 2).2 Both C.W. and T.M. also received letters from the FBI's Victim-Witness Specialist, which were sent on January 10, 2008 (Exs. 3 & 4). S.R. was identified via the FBI's investigation in 2007, but she initially refused to speak with investigators. S.R.'s status as a victim of a federal offense was confirmed when she was interviewed by 'Attorney filed his Motion on behalf of "Jane Doe," without identifying which of \_ his clients is the purported victim. Accordingly, l will address facts related to C.W., T.M., and S.R. All three of those clients were victims of Jeffrey Epstein's while they were minors beginning when they were fifteen years old. ?Please note that the dates on the U.S. Attorney's Office letters to C.W. and T.M. are not the dates that the letters were actually delivered. Letters to all known victims were prepared early in the investigation and delivered as each victim was contacted. federal agents on May 28, 2008. The FBI's Victim-Witness Specialist sent a letter to S.R. on May 30, 2008 (Ex. 5). 4. Throughout the investigation, the FBI agents, the FBI's Victim-Witness Specialist, and your A Mant had contact with C.W. and S.R. Attorney other client, T.M., was represented by counsel and, accordingly, all contact with T.M. was made through that attorney. That attorney was James Eisenberg, and his fees were paid by Jeffrey Epstein, the target of the investigation.' 5. In the summer of 2007, Mr. Epstein and the U.S. Attorney's Office for the Southern District of Florida ("the Office") entered into negotiations to resolve the investigation. At that time, Mr. Epstein had been charged by the State of Florida with solicitation of prostitution, in violation of Florida Statutes § 796.07. Mr. Epstein's attorneys sought a global resolution of the matter. The United States subsequently agreed to defer federal prosecution in favor of prosecution by the State of Florida, so long as certain basic preconditions were met. One of the key objectives for the Government was to preserve a federal remedy for the young girls whom Epstein had sexually exploited. Thus, one condition of that agreement, notice of which was provided to the victims on July 9, 2008, is the following: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein 3The undersigned does not know when Mr. began representing T.M. or whether T.M. ever formally terminated Mr. Eisenberg's representation. had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein'S attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 6. An agreement was reached in September 2007. The Agreement contained an express confidentiality provision. 7. Although individual victims were not consulted regarding the agreement, several had expressed concerns regarding the exposure of their identities at trial and they desired a prompt resolution of the matter. At the time the agreement was signed in September 2007, T.M. was openly hostile to the prosecution of Epstein. The FBI attempted to interview S.R. in October 2007, at which time she refused to provide any information regarding Jeffrey Epstein. None of Attorney clients had expressed a desire to be consulted prior to the resolution of the federal investigation. 8. As explained above, one of the terms of the agreement deferring prosecution to the State of Florida was securing a federal remedy for the victims. In October 2007, shortly after the agreement was signed, four victims were contacted and these provisions were discussed. One of those victims was C. W.-With at the time was not represented, and she was given notice of the agreement. Notice was also provided of an expected change of plea in October 2007. When Epstein's attorneys learned that some of the victims had been notified, they complained that the victims were receiving an incentive to overstate their involvement with Mr. Epstein in order to increase their damages claims. Mile your A ffiant knew that the victims' statements had been taken and corroborated with independent evidence well before they were informed of the potential for damages, the agents and I concluded that informing additional victims could compromise the witnesses' credibility at trial if Epstein reneged on the agreement. 9. After C.W. had been notified of the terms of the agreement, but before Epstein • performed his obligations, C.W. contacted the FBI because Epstein's counsel was attempting to take her deposition and private investigators were harassing her. Your Affiant secured pro bono counsel to represent C.W. and several other identified victims. Pro bono counsel was able to assist C.W. in avoiding the improper deposition. That pro bono counsel did not express to your Affiant that C.W. was dissatisfied with the resolution of the matter. 10. In mid-June 2008, Attorney contacted your Affiant to inform me that he represented C.W. and S.R. and asked to meet to provide me with information regarding Epstein. I invited Attorney to send to me any information that he wanted me to consider. Nothing was provided. I also advised Attorney that he should consider contacting the State Attorney's Office, if he so wished. I understand that no contact with that office was made. Attorney had illUded to T.M., scirliclVikd him that, to my knowledge, T.M. was still represented by Attorney James Eisenberg. • 1 I. On Friday, June 27, 2008, at approximate 4:15 p.m., your Affiant received a copy of the proposed state plea agreement and learned that the plea was scheduled for 8:30 a.m., Monday, lune 30, 2008. Your Affiant and the Palm Beach Police Department attempted to provide notification to victims in the short time that Epstein's counsel had given us. Although all known victims were not notified, your Affiant specifically called attorney to provide notice to his clients regarding the hearing. Your Affiant believes that it was during this conversation that Attorney notified me that he represented T.M., and I assumed that he would pass on the notice to her, as well. Attorney informed your Affiant that he could not attend but that someone would be present at the hearing. Your Affiant attended the hearing, but none of Attorney I= clients was present. 12. On today's date, your Affiant provided the attached victim notifications to C.W. and S.R. via their attorney, (Exs. 6 & 7). A notification was not provided to T.M. because the U.S. Attorney's modification limited Epstein's liability to victims whom the United States was prepared to name in an indictment. In light of T.M.'s prior statements to law enforcement, your Affiant could not in good faith include T.M. as a victim in an indictment and, accordingly, could not include her in the list provided to Epstein's counsel. 13. Furthermore, with respeet tdtheCertifiCaticiri of Ethergency, Attorney did not ever contact me prior to the filing of that Certification to demand the relief that he requests in his Emergency Petition. On the afternoon °flu1y 7, 2008, after your Affiant had already received the Certification of Emergency and Emergency Petition, I received a letter from Attorney [REDACTED] that had been sent, via Certified Mail, on July 3, 2008. While that letter urges the Attorney General and the United States Attorney to consider "vigorous enforcement" of federal laws with respect to Jeffrey Epstein, it contains no demand for the relief requested in the Emergency Petition. 14. I declare under penalty of perjury, pursuant to 28 U.S.C. § 1746 that the foregoing is true and correct to the best of my knowledge and belief. Executed this 9th day of July, 2008. ![]()![](_page_8_Picture_2.jpeg) ### U.S. Department of Justice United States Attorney Southern District of Florida ![](_page_8_Picture_5.jpeg) 500Sough Australian Ave , Suite 400 ;Vest Pahn Bench, FL. 33401 (.561)820-8711 Facsimile: (561) 820-8777 June 7, 2007 #### DELIVERY BY HAND Miss Clalleal Re: Crime Victims' and Witnesses' Rights Dear Miss Win Pursuant to the Justice for All Act of2004, as a victim and/or witness of a federal offense, you have a number of rights. Those rights arc: - (I) - (2) - (3) - (4) - (5) - (6) - (7) - (8) The right to be reasonably protected from the accused. The right to reasonable, accurate, and timely notice of any public court proceeding involving the crime or of any release or escape of the accused. The right not to be excluded from any public court proceeding, unless the court determines that your testimony may be materially altered if you are present for other portions of a proceeding. The right to be reasonably heard at any public proceeding in the district court involving release, plea, or sentencing. The reasonable right to confer with the attorney for the United States in the case. The right to full and timely restitution as provided in law. The right to proceedings free from unreasonable delay. The right to be treated with fairness and with respect for the victim's dignity and privacy. CI; Members of me 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 arc protected. If you have any concerns in this regard, please feel free to contact me at 561 209-1047, or Special Agent Nesbitt Kayrkendall frotwthe Federal Bureau of Investigation at 561 822-5946. You also• can contact thrliiifi& Uepartnient's °Moe (Or NietibiS "cif Cr-tine in Washington, D.C. at 202-307-5983. That Office has a website at www.ovc.gov. You con seek the advice of an attorney with respect to the righl's listed above and, if you believe that the rights ::et forth above are being violated, you have the right to petition the Court for relief. Miss OWED a JUNE 7, 2007 P4of 2 Inaddition to these rights, you are entitled to counseling and medical services, and protection from intimidation and harassment. if the Court determines that you arc avictim, you also may be entitled to restitution from the perpetrator. A list of counseling and medical service providers can be provided to you, if you so desire. If you or your family is subjected to any intimidation or harassment, please contact Special Agent Kuyrkendall or myself immediately. It is possihle that someone working on behalf of the targets of the investigation may contact you. Such contact does not violaleithe la t" However, if you are contacted, you have the choice of speaking to that person or refusing to'clo to. If you refuse and feel that you are being threatened or harassed, then please • contact Special Agent Kuyrkendall or myself. You also are entitled to notification of upcoming ease events. At this time, yourcase is under investigation) I (anyone is charged in connection with the investigation, you will be notified. Sincerely, R. Alexander Acosta United States Attorney By: 4.elsectoruc,\_ A. VillafaAa Assistant United States Attorney cc: Special Agent Nesbitt Kuyrkendall, F.B.I. ![](_page_10_Picture_2.jpeg) United Slates Attorney • Southern District of Florida ![](_page_10_Picture_5.jpeg) 500 South Australian 4 pm. Suite 400 West Polm Couch. Ft 37401 (561)8204711 Facsimile: (561) 820-8777 August I I, 2006 #### DELIVERY BY HAND Miss Tea Re: Crime Victims' and WitnessesiRigIns Dear Miss Mgaa Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense, you have a number of rights. Those rights are: - (I ) The right to be reasonably protected from the accused. - (2) The right to reasonable, accurate, and timely notice of any public court proceeding involving the crime or of any release or escape of the accused. - (3) The right not to be excluded from any public court pmcecding, 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) The retsonable right to confer with the attorney for the United States 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. ( 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 561 209.1047, or Special Agent Nesbitt Kuyrkendall from the Federal Bureau of Investigation at 561 822-5946.-- au also can-contact-the Justice .Depariment's Office ,for -Vietims. of Crime in Washington, D.C. at 202-307.5983. That Office has a websitc at www.ovc.gov. You can seek the advice of an attorney with respect to the rightelisted above and, if you believe that the rights set forth above are being violated, you have the right to petition the Court for relief MISS Tea AUGUST I I, 2006 PAGE 2 In addition to these rights, you are entitled to counseling and medical services, and I., .• from intimidation and harassment. If the Court determines that you are avictim, you entitled to restitution from the perpetrator. A list of counseling and medical service pm. be provided to you, if you so desire. If you or your family is subjected to any inter • harassment, please contact Special Agent Kuyrkendall or myself immediately. It is p. someone working on behalf of the targets of the investigation may contact you. Such ci".• not violate the law. However, if you are contacted, you have the choice of speaking to or refusing to do so. If you refuse and feel that you are being threatened or harassed, IN. Contact Special Agent Kuyrkendall or myself. You also are entitled to notification of upcoming case events. At this time, your L.1. investigation. If anyone is charged in connection with the investigation, you will be no. Sincerely, R. Alexander Acosta United States Attorney By: A. Villafana Assistant United States Attorney cc: Special Agent Nesbit( Kuyrkendall, F.B.I. ![](_page_12_Picture_1.jpeg) U.S. Department of Justice Federal Bureau of investigation FBI - WOE Palm Beach Suite 500 505 South Flagler Drive West Palm Beach. FL 33401 Phone: (581) 833-7517 Fax (561) 833-7970 January 10, 2008 Re: Case Number: Dear CIMINIVel This Case Is currently under Investigation. This can be a lengthy process end we request your continued patience while we conduct a thorough Investigation. As a alma victim, you have the following rights under 18 United States Code § 3771: (1) The right to be reasonably protected from the accused; (2) The right to reasonable, accurate, and timely notice of any pulsars court proceeding, or any parole proceeding, Involving the acme or of any release or escape of the accused; (3) The right not to be excluded from any such public court proceeding, unless thecourt, after receiving clear and oonvindng evidence. determines that testimony by the victim would be materially altered If the victim heard other testimony et that proceeding; (4) The light 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 fug and timely restitution as provided In law; (7) The right to proceedings free from unreasonable delay; (5) The right to be treated with fairness and with respect for the victim's dignity and privacy. We will make our best efforts to ensure you VW accorded the rights described. Most of these rights pertain to events occurring after the arrest or indictment of an Individual for the time, and it will become the responsibility of the prosecuting Untied States Attorney's Office to ensure you are accorded those rights. You may also seek the advice of a private attorney with respect to these rights. The Victim NottficaUon System (VNS) is designed to provide you with direct information regarding the case es it proceeds through the criminal Justice system. You may obtain current Information about this matter on the internal el WWW.NotIfy.USD0J.GOV or from the VN5 Call Canter at 1-865-00J-4YOU (1465-365- 4968) (TDDITTY: 1-886-228-4819) (International: 1.502.213-2767). In addition, you may use the Call Center or Internet to update your contact information and/or change your decision about participation in the • notification program. If you update your Information to include a current email address, VNS will send information to that address. You wig need the following Victim Identification Number (VIN) '1941737' and ' Personal Ideratficatbn Number (PIN) '5502' anytime you contact the Call Center and the first time you log on to VNS on the Internal In addition, the float time you access the VNS Internet site, you will be prompted to enter your last name (or business name) 85 currently contained in VNS. The name you should enter Is Was ![](_page_12_Picture_11.jpeg) If you have additional questions which involve this matter, please contact the office listed above. When you cal. please provide the Oki number located at the top of this letter. Please remember, your participation in the notification part of this program is voluntary. In order to continue to receive notifications. it is your responsibility to keep your contact information current Sincerely. OIAA 2.1/n ;VA) Twlier Victim Specialist ![](_page_14_Picture_1.jpeg) U.S. Department of Justice Federal Bureau of Investigation FBI - Weal Palm Beach Suite 500 505 South Rapier Drive West Palm Beach, FL 33401 Phone: (561) 833.7517 Fax: (581)633-7970 January 10, 2006 James Eisenberg One Cleariake Center Ste 704 Australian South Weal Palm Beach, FL 33401 Re: Dear James Eisenberg: You have requested to receive notifications for Tallhkle This case is currentiy under Investigation. This can be a lengthy process and we request your continued patience while we conduct a thorough Investigation. Asa crime victim, you have the following rights under 18 United States Codes 3771: (1) The right to be reasonably protected from the.accused; (2) The right to reasonable, accurate, and timely notice of any public court proceeding, or any parole proceeding, Involving the crone or of any release or escape of the accused; (3) The right not to be excluded from any ouch 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 horn unreasonable delay: (8) The right to be treated with fairness and with respect for the victim's dignity and privacy. We will make our best efforts to ensure you are accorded the rights deathbed. Most of these rights pertain to events occurring after the arrest or Indictment of an individual for the crime, and It will become the responsibility of the prosecuting United States Attorney's Office to ensure you are accorded those rights. You may oleo seek the advice of aprivate attorney with respect to these rights. The Vern Noble:190n System (VNS) is designed to provide you with direct Information regarding the case as It proceeds through the criminal justice system. You may obtain current Information about this matter on the Internet at WWW.Notly.USDOJ.GOV or from the VNS Call Center al 1.666-00J-4YOU (1-866-385- 4968) (TDD/TTY; 1-666-228-4619) (International 1-502-213-2767). In addition, you may use the Cal Center or Internet to update your contact inforrnabon and/or change your decision about participation in the notification program, If you update your information to include aourrent email address. VNS will send information to that address. You wil need the following Victim Identification Number WIN) '1941741' and Personal Identification Number (PIN) 7760' anytime you contact the Call Center and the first time you log on to -VNS onthaintemetrin addition, the first time you access theliNSintemet site, you will-be prompted:10 enter your lest name (or business name) as currently contained in VNS. The name you should enter is Eisenberg. ![](_page_14_Picture_12.jpeg) If you have additional questions which involve this matter, please contact the office listed above. When You call, please provide the file number located at the top of this letter. Please remember, your participation in the notification part of this program Is voluntary. In order to continue to receive notifications. It is your responsibility to keep your contact Information current. Sincerely. 1; Lei. :11:1`) T Victim pa alist ![](_page_16_Picture_742.jpeg) U.S. Department of Justice Federal Bureau of Investigation FBI - West Palm Beach Suite 500 505 South Flagler Drive West Palm Beach, FL 33401 Phone: (561) 833-7517 Fax: (561) 833-7970 ![](_page_16_Picture_744.jpeg) May 30, 2008 SECRET [REDACTED] Re: [REDACTED] Dear SA [REDACTED] Your name was referred to the FBI's Victim Assistance Program as being a possible victim of a federal crime. We appreciate your assistance and cooperation while we are investigating this case. We would like to make you aware of the victim services that may be available to you and to answer any questions you may have regarding the criminal justice process throughout the investigation. Our program is part of the FBI's effort to ensure the victims are treated with respect and are provided information about their rights under federal law. These rights include notification of the status of the case. The enclosed brochures provide information about the FBI's Victim Assistance Program, resources and instructions for accessing the Victim Notification System (VNS). VNS is designed to provide you with information regarding the status of your case. This case is currently under investigation. This can be a lengthy process and we request your continued patience while we conduct a thorough investigation. As a crime victim, you have the following rights under 18 United States Code § 3771: (1) The right to be reasonably protected from the accused; (2) The right to reasonable, accurate, and timely notice of any public court proceeding, or any parole proceeding, involving the crime or of any release or escape of the accused; (3) The right not to be excluded from any such public court proceeding, unless the court, after receiving clear and convincing evidence, determines that testimony by the victim would be materially altered if the victim heard other testimony at that proceeding; (4) The right to be reasonably heard at any public proceeding in the district court involving release, plea, sentencing, or any parole proceeding; (5) The reasonable right to confer with the attorney for the Government in the case; (6) The right to full and timely restitution as provided in law; (7) The right to proceedings free from unreasonable delay; (8) The right to be treated with fairness and with respect for the victim's dignity and privacy. We will make our best efforts to ensure you are accorded the rights described. Most of these rights pertain to events occurring after the arrest or indictment of an individual for the crime, and it will become the responsibility of the prosecuting United States Attorney's Office to ensure you are accorded those rights. You may also seek the advice of a private attorney with respect to these rights. The Victim Notification System (VNS) is designed to provide you with direct information regarding the case as it proceeds through the criminal justice system. You may obtain current information about this matter on the Internet at WWW.Notify.USDOJ.GOV or from the VNS Call Center at 1-866-DOJ-4YOU (1-866-365-4968) (TDD/TTY: 1-866-228-4619) (International: 1-502-213-2767). In addition, you may use the Call Center or Internet to update your contact information and/or change your decision about participation in the notification program. If you update your information to include a current email address, VNS will send information to that address. You will need the following Victim Identification Number (VIN) '2074381' and Personal Identification Number (PIN) '1815' anytime you contact the Call Center and the first time you log on to VNS on the Internet. In addition, the first time you access the VNS Internet site, you will be prompted to enter your last name (or business name) as currently contained in VNS. The name you should enter is [REDACTED] [REDACTED] [REDACTED] • If you have additional questions which Involve this matter, please canted the office listed above. When you call, plane provide the nle number located at the lop of this letter. Please remember, your participation in the notification part of this program le voluntary. In order to continue to receive nollficaliOrtS, It is your responsibility to keep your contact information current. Sincerely, Cr . TMle Victimigalist ![](_page_18_Picture_1.jpeg) U.S. Department of Justice • United States Attorney Southern District of Florida | ADMINISTRATION | | |-----------------------------------------------------------------------|--| | GOVERNMENT
EXHIBIT | | | CASE
NO. 08-80736-CV-MARRA
EXHIBIT
NO. 6 | | 500 South Australian Ave.. Suite 400 West Palm Beach. FL 33401 (560 820-87O Facsimile: (561) 820-8777 July 9, 2008 ## VIA FACSIMILE Brad l=1 Esq. The Law Offices of Brad 1=1& Associates, LLC 2028 Street, Suite 202 Hollywood, Florida 33020. > Re: leffi:eyEgaletnplIMIRIP I/ Vai: NOTIFICATION OF IDENTIFIED VICTIM Dear Mr. a By virtue of this letter, the United States Attorney's Office for the Southern District of Florida asks that you provide the following notice to your client, QM.% WIM. On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-009454AJOCXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be followed by an additional six months' imprisonment, followed by twelve months of Community Control 1, with conditions of community confinement imposed by the Court. In light of the entry of the guilty plea and sentence, the United States has agreed to defeiriedelarpfbilaiitilirril-FfaVOT Of this state- plea" and sentence; subject to certain conditions. One such condition to which Epstein has agreed is the following: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United StatesCode, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein BRAD [REDACTED] ESQ. NOTIFICATION OF IDENTIFIED VICTIM C [REDACTED] W [REDACTED] JULY 9, 2008 PAGE 2 OF 2 had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." Through this letter, this Office hereby provides Notice that your client, C [REDACTED] W [REDACTED] is an individual whom the United States was prepared to name as a victim of an enumerated offense. Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300. Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist in civil litigation; however, if you do file a claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an enumerated offense, please provide notice of that denial to the undersigned. Please thank your client for all of her assistance during the course of this examination and express the heartfelt regards of myself and Special Agents Kuyrkendall and Richards for the health and well-being of Ms. W [REDACTED] R. ALEXANDER ACOSTA UNITED STATES ATTORNEY ![]()cc: Jack Goldberger, Esq. ![](_page_20_Picture_1.jpeg) RS. Department of Justice United States Attorney Southern District of Florida ![A small rectangular label with a black border. It contains the text 'ADMINISTRATIVE COMMUNICATIONS SECTION' at the top, 'GOVERNMENT EXHIBIT' in the center, and 'CASE NO. 08-80736-CV-MARRA' at the bottom. A small '7' is written in the bottom right corner.]()500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (56/) 820-8711 Facsimile: (561)820-8777 July 9, 2008 VIA FACSIMILE BnItargq. The Law Offices of Brad Associates, LLC 2028a Street, Suite 202 . Hollywood, Florida 33020. Re: Jeffrey Epstein/1MR RIM NOTIFICATION OF IDENTIFIED VICTIM Dear Mr. By virtue of this letter, the United States Attorney's Office for the Southern District of Florida asks that you provide the following notice to your client, allia ROMP On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be followed by an additional six months' imprisonment, followed by twelve months of Community Control I, with conditions of community confinement imposed by the Court. In light of the entry of the guilty plea and sentence, the United States has agreed to .defer\_federal\_prosecution\_in\_famor\_oLthis..state plea and sentence; subject to certain conditions. One such condition to which Epstein has agreed is the following: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein Bitm=5, ESQ. NOTIFICATION OF IDENIVIED VICTIM S JULY 9, 2008 PAGE 2 OF 2 had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." Through this letter, this Office hereby provides Notice that your client, a . P is an individual whom the United States was prepared to name as a victim of an enumerated offense. Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300. Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist in civil litigation; however, if you do file a claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an enumerated offense, please provide notice of that denial to the undersigned. Please thank your client for all of her assistance during the course of this examination and express the heartfelt regards of myself and Special Agents Kuyrkendall and Richards for the health and well-being of Ms. lap > R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: cc: Jack Goldberger, Esq. A. VILLAFARA ASSISTANT U.S. ATTORNEY