EFTA00184224

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July 9, 2008 
A. 
C. S 
Esq. 
Assistant United States Attorney 
United States Attorney's Office 
500 South Australian Avenue 
4th Floor. Suite 400 
SENT VIA E-MAIL 8c FACSIMILE 
Re: 
Jeffrey E. Epstein 
Dear Ms. Villafana: 
5,r‘Tas 
40. sir 
'JOSEPH R.ATTERBURY 
rt JACK A. GOLDBERGER 
JASON S.WEISS 
"Board Certified Criminal Trial Attorney 
T Member of Now Jersey di Florida Bart 
Thank you for your letter to me dated July 8, 2008 and the draft document dated, e-mailed and faxed 
to me at my office on June 30, 2008, styled "Notification of Identified Victims." I would like to 
address a few related issues. 
First, please note that we have several requests concerning any such notification. Specifically, we 
request that: 
(a) Any notification be sent to any individual by mail (or served upon their attorney, 
to the extent known), and we respectfully object to any service by hand, a method of 
service which carries the concomitant risk of conversations regarding the notification 
that potentially would place the federal authorities in a position of being advocates 
for civil litigation; 
(b) My notification be effectuated by a separate mailing to each individual without 
the inclusion of any language that appeared on the second page of your June 30, 2008 
memorandum; i.e. rather than including in each notification a large section listing 
"identified individuate with redactions other than the name of the recipient (which 
we contend would be a clear and impermissible signal to any individual that the 
notification is a broad notification to numerous other alleged victims). Rather, a 
simple one page notification directed only to the recipient, and limited to the 
information currently on the first page of your draft memorandum would suffice. 
One Clearlake Centre, Suite 1400 
250 Australian Avenue South West Palm Beach, FL. 33401 
p 
wvvw.agwpacom 
08-80736-CV-MARRA 
RFP WPB 00052 
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Case 9:08-cv-80736-KAM Document 362-43 Entered on FLSD Docket 02/10/2016 Page 3 of 3 
(c) You eliminate from any notification any language that is currently contained in 
the "acknowledgment" section of the June 30, 2008 memorandum; and 
(d) You supplement the notification with the Government's previously made 
representation that it is not vouching for the veracity of any claim by any identified 
individual. See Letter from J. Sloman to E. 
(10/25/07). 
Second, please note also that we do not understand your request that Mr. Epstein and his attorneys 
execute the rider / acknowledgment contained within your June 30 hand-delivered draft. 
Speeifically,we do not believe that the Non-Prosecution Agreement requires Mr. Epstein's execution 
of any such additional stipulation. Because we want to ensure that Mr. Epstein continues to strictly 
comply with the letter of the parties' agreement, we respectfully ask that you explain why you 
believe that the Non-Prosecution Agreement requires execution of your stipulation. 
Our understanding of the Non-Prosecution Agreement is that it does not require Mr. Epstein to 
"acknowledge" anything not already contained within the four corners of the written ageement. The 
agreement certainly contains no written term obligating that he "waive any evidentiary challenge to 
the introduction of a copy" of any "Notification of Identified Victims" in "any judicial proceeding 
between any identified individual" and Mr. Epstein, as your memorandum currently requests. 
Further, please note that your June 30 stipulation, as drafted, is not limited to Section 2255 
proceedings. Rather, yourJune 30 draft requires Mr. Epstein to waive evidentiary challenges in "any 
judicial proceeding" - - which clearly exceeds the bounds of the parties' written agreement. 
Third, I would respectfully request that you provide me with the names of the "pro bono lawyers" 
who, you indicated to me at our June 30 meeting at my office, were intending to represent certain 
persons identified on your June 30 draft notification, as well as any knowledge that the Government 
has as to how they were selected, and what communications the Government has had with them to 
date. 
Finally, please know that it is Mr. Epstein's firm intent to fulfill strictly each term and condition of 
his Non-Prosecution Agreement with the Government. Nothing hi this letter should be construed, 
however, as waiving any defense that may be available to Mr. Epstein under the parties' written 
agreement. 
I look forward to your response. Until then, I remain, 
V 
trul yours, 
Ja 
A. Goldberger 
cc: 
Jeffrey Epstein 
08-80736-CV-MARRA 
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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 
Facshnile: 
July 9, 2008 
VIA FACSIMILE 
Jack A. Goldberger, Esq. 
Atterbury, Goldberger & Weiss, P.A. 
One Clcarlake Centre, Suite 1400 
250 Australian Ave S. 
West Palm Beach, FL 33401-5015 
Re: 
Jeffrey Epstein 
Dear Mr. Goldberger: 
Thank you for your letter of today's date regarding the proposed Victim Notification. 
Let me address some of the items in your letter. 
We have no objection to doing individual mailings. The Notification was drafted in 
that way in order to minimize the number of documents that Mr. Epstein would sign. Now 
that you have raised an objection to signing the Acknowledgment, each notification will list 
only the victim who is being notified. 
In light of Mr. Epstein's refusal to sign the Acknowledgment, the Acknowledgment 
portion has been deleted and the notification has been slightly modified in order to provide 
more complete information and it has been formatted as a letter rather than a more formal 
"Notification" document. 
We will not be including any statement that the U.S. Attorney's Office is not vouching 
for the veracity of any claim. As you know, the U.S. Attorney's modification of the 2255 
portion of the Agreement now limits our victim list to those persons whom the United States 
08-80736-CV-MARRA 
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JACK GOLDBERGER, ESQ. 
JULY 9, 2008 
PAGE 2 
was prepared to include in an indictment. This means that, pursuant to Justice Department 
policy, these are individuals for whom the United States believes it has proof beyond a 
reasonable doubt that each of them was a victim of an enumerated offense. There will be no 
statement one way or the other regarding the validity of any claim. 
You have asked for an explanation of why I believe the Acknowledgment portion is 
required by the lens of the Agreement. Under a strict reading of the Agreement, it is not 
required, other than to Acknowledge that the United States has performed its obligation of 
providing Mr. Epstein with a list of identified victims following his guilty plea and 
sentencing. The purpose of the Acknowledgment was to create one single document 
incorporating the parties' agreement on the single topic of the right to proceed under 18 
U.S.C. § 2255. This would avoid litigation regarding the victims' rights to have access to 
the original Non-Prosecution Agreement. Without such an express Acknowledgment by Mr. 
Epstein that the Notice contains the substance of that Agreement, I believe that the victims 
will have a justification to petition for the entire agreement, which is contrary to the 
confidentiality clause that the parties have signed. If you believe that particular words are 
objectionable, I am happy to consider a modification. 
As I mentioned to you last week, I will provide you with the names of the attorneys 
currently representing the victims when we have compiled all of that in fonnation. Some of 
the victims are represented by attorneys from the South Carolina Victim Assistance Network 
and the Maryland Crime Victims Resource Center, both of which were recommended by a 
victims' rights organization that receives grants from the Justice Department. 
If you have any suggestions for a modification of the Acknowledgment, please let me 
know. 
Sincerely, 
United States Attorney 
cc: 
Karen Atkinson, AUSA 
By: 
Assistant United States Attorney 
08-80736-CV-MARRA 
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U.S. Department of Justice 
FILE COPY 
United Stales A►torney 
Southern District of Florida 
500 South Australian Ave., Suite 400 
IVest Palm Beach, FL 33401 
July 9, 2008 
NOTIFICATION OF IDENTIFIED VICTIM 
NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED 
STATES CODE, SECTION 3509(d) AND FLORIDA LAW, 
THE ATTACHED DOCUMENT IS TO BE TREATED AS 
CONFIDENTIAL AND SHALL NOT BE DISCLOSED 
EXCEPT IN CONNECTION 
WITH 
A 
LEGAL 
PROCEEDING. 
08-80736-CIV-MARRA 
000777 
EFTA00185070

of Florida asks that you provide the following notice to your client, 
Case 9:08-c -80736-KAM Document 362-45 Entered on FLSD Docket 02/10/2016 Page 3 of 4 
U.S. Department of Justice 
"•• 
United States Attorney 
Southern District of Florida 
F P' 
500 South Australian Ave., Suite 400 
West Palm Beach, FL 3340! 
Facsimile: 
July 9, 2008 
VIA FACSIMILE 
Brad Edwards, Esq. 
The Law Offices of Brad Edwards & Associates, LLC 
2028 Harrison Street, Suite 202 
Hollywood, Florida 33020. 
Re: 
Jeffrey Epstein/ 
NOTIFICATION OF 
IDENTIFIED VI
A 
Dear Mr. Edwards: 
By virtue of this letter, the United States Attorney's Office for the Southern District 
II
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 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 
defer federal prosecution in favor 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 States Code, Section 2255, will have the same 
rights to proceed under Section 2255 as she would have had, if Mr. Epstein 
08-80736-CI V-MARRA 
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Case 9:08-cv-80736-KAM Document 362-45 Entered on FLSD Docket 02/10/2016 Page 4 of 4 
BRAD EDWARDS, ESQ. 
NOTIFICATION OF IDENTIFIED VICTIM 
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, 
_J 
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 3340!, 
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 
and 
for 
the health and well-being of Ms. 
cc: 
Jack Goldberger, Esq. 
UNITED STATES ATTORNEY 
By: 
A 
ASSISTANT U.S. ATTORNEY 
08-80736-C1V-MARRA 
000779 
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U.S. Department of Justice 
United Stales Attorney 
Southern District of Florida 
500 South Australian Ave., Suite 400 
West Palm Beach, FL 3340! 
July 9, 2008 
NOTIFICATION OF IDENTIFIED VICTIM 
NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED 
STATES CODE, SECTION 3509(d) AND FLORIDA LAW, 
THE ATTACHED DOCUMENT IS TO BE TREATED AS 
CONFIDENTIAL AND SHALL NOT BE DISCLOSED 
EXCEPT 
IN 
CONNECTION 
WITH 
A 
LEG AL 
PROCEEDING. 
08-80736-CIV-MARRA 
000774 
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Case 9:08-
:0736-KAM Document 362-46 Entered on FLSD Docket 02/10/2016 Page 3 of 4 
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 South Australian Ave., Suite 4UU 
West Palm Beach. FL 33401 
July 9, 2008 
VIA FACSIMILE 
Brad Edwards, Esq. 
The Law Offices of Brad Edwards & Associates, LLC 
2028 Harrison Street, Suite 202 
Hollywood, Florida 33020. 
Re: 
Jeffrey Epsteins eurr aNOTIFICATION OF 
IDENTIFIED VI 
Dear Mr. Edwards: 
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, 
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 I 5th Judicial Circuit in 
and for Palm Beach County (Case Nos. 2006-cl-009454AXXXMI3 and 2008-cf-
009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to he 
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 
defer federal prosecution in favor 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 States Code, Section 2255, will have the same 
rights to proceed under Section 2255 as she would have had. if Mr. Epstein 
08-80736-CIV-MARRA 
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BRAD EDWARDS, ESQ. 
NOTIFICATION OF IDENI IVIED VICTIM 
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, El_- 
IM 
is an individual whom the United States was prepared to name as a victim of an 
ted offense. 
Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack 
Goldberger, asks that you contact him at Atterbury Goldber er and Weiss, 250 Australian 
Avenue South, Suite 1400, West Palm Beach, FL 33401, 
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 other assistance during the course of this examination 
and express the heartfelt regards of m self and Special Agents 
and 
for 
the health and well-being of Ms.• 
cc: 
Jack Goldberger, list'. 
By: 
UNITED STATES ATTORNEY 
A. 
ASSISTANT U.S. ATTORNEY 
08-80736-CIV-MARRA 
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U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
Ant Yitlajiina 
Wa
rr
i
Facsimile 
FACSIMILE COVER SHEET 
TO: 
Jack Alan Goldberger 
DATE: 
July 10.2008 
FAX NO. 
PHONE NO.
# OF PAGES:  
2
RE: 
Jeffrey Epstein 
FROM: 
A.
PHONE NO. 
VILLAFA1CIA, Assistant U.S. Attorney 
COMMENTS: 
08-80736-CV-MARRA 
RFP WPB 000535 
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JOSEPH R.ATTERBURY 
11 JACK A. GOLDBERGER 
JASON S.WEISS 
ROAN CeetIlled CrenbulTrIal Attorney 
Member of New Jersey a Florida Bus 
July 10, 2008 
A. up C. pm Esq. 
Assistant Un e u es Attorney 
500 S. Australian Avenue 
- 
 & FACSIMILE 
Re: 
Jeffrey E. Epstein 
Dear Ms. 
Thank you for your letter of yesterday. Kindly allow me a few follow-up points. 
First, we respectfully request a reasonable opportunity to review and comment on a draft 
of the modified notification letter you Intend to mail before you send it. 
Second, we respectfully ask that you provide us with the identity of the victims' rights 
organization described in your letter; the name and contact information of the person at 
that organization with whom the Government has been communicating; copies of any 
communications with that organization and the pro-bono lawyers/groups who were 
recommended by that organization; and a description of any non-written communications 
that the Government has had with that organization and the pro-bono lawyers/groups. 
Third, while we appreciate your offer to disclose the names of the lawyers currently 
representing the individuals when you have finished compiling all of that Information, we 
would be very grateful if you would provide any contact information you do have, on a 
rolling basis. 
Fourth, would it be possible for you to advise us of the full name of the minor to whom you 
have referred by initials, as well as the identities of the three Individuals whom the 
Government notified about the deferred-prosecution agreement shortly after its signing (as 
One Clearlake Centre, Suite 1400 
250 Australian Avenue South West Palm Beach. FL 33401 
p ei300 
f 
www.agwpa.com 
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indicated In your letter of December 13, 2007)7 
Fifth, please recall that Mr. Illwrote 
to Judge 
on October 25, 2007 that "The 
United States takes no position as o the validity of any such claim under this statute." To 
avoid any appearance that the United States is endorsing or encouraging litigation by the 
identified individuals, we believe that such a statement should be included in any 
notification letter. 
I look fonyard to receiving your Input on these Issues. Until then, I remain, 
Jack A. Goldberger 
JAG/na 
co; 
Jeffrey E. Epstein 
08-80736-CV-MARRA 
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(USAFLS) 
From: 
Jock Goldberger figoldberger@agwpa.comi 
Sent: 
-Irid 
il 1 1_701111 1 le, pm 
To: 
(USAFLS) 
Subject 
otice of thsclosure 
Please call me in regard to this 
lack goldberger 
From:  
 (USAFLS) 
Sent: riday, July 11, 2008 12:01 PM 
To: Jack Goldberger 
Cc: Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) 
Subject: Nonce of Disclosure 
Dear Mr. Goldberger: 
Today, Dexter Lee and I appeared before Judge Marra in connection with a suit filed by wand 
asserting that their rights as victims were breached by our failure to consult with them belbrc entering into the 
Non-Prosecution Agreement. In response to their petition. I filed a Declaration under seal that included the 
victim notification letters provided to their attorney, Brad Edwards. Al today's hearing, and over our objection, 
Judge Marra denied our motion to seal and unsealed the declaration. Accordingly. one piece or the Non-
Prosecution Agreement. specifically the paragraph that is quoted in the victim notification letters, has been 
disclosed. 
Assistant U.S. Attorney 
590 
08-80736-CV-MARRA 
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