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THE INVESTIGATION OF EPSTEIN'S CRIMES 
4. In 2005, the Town of Palm Beach Police Department received a complaint from the 
parents of a 14-year-old girl about her sexual abuse by Jeffrey Epstein. The PBPD then capably 
conducted a thorough investigation and ultimately identified approximately 20 girls between the 
ages of 14 and 17 who were sexually abused by Epstein." 
5. In 2006, at the request of the PBPD, the FBI opened a federal investigation into 
allegations that Epstein and his personal assistants had used facilities of interstate commerce to 
induce girls between the ages of 14 and 17 to engage in illegal sexual activities. 
6. The FBI ultimately determined that both Jane Doe 1 and Jane Doe 2 were victims of 
sexual abuse by Epstein while they were minors. Jane Doe 1, for example, provided detailed 
information about her abuse—and the abuse of Jane Doe 2—to the FBI on August 7, 2007.19
7. On about August II, 2006, Jane Doe 2 received a standard CVRA victim notification 
letter. The notification promised that the Justice Department would make its "best efforts" to 
protect Jane Doe 2's rights, including "[t]he reasonable right to confer with the attorney for the 
Government 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." 20 That notification meant that Jane Doe 2 had been identified as a victim 
of a federal offense and as someone protected by the CVRA. 
1s Exhibit 34; see also RFP WPB 001940.001941 (Exhibit 40) (later description of investigation by the U.S. 
Attorney's Office). 
19 Exhibit 26; Exhibit 27; Exhibit 32. 
10 August II, 2006 Victim Notification Letter to Jane Doe 2 (Exhibit 41). 
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8. More generally, the FBI established that Epstein used paid employees to repeatedly 
find and bring minor girls to him. Epstein worked in concert with others to obtain minor girls 
not only for his own sexual gratification, but also for the sexual gratification of others?' 
EPSTEIN'S FEDERAL PLEA NEGOTIATIONS 
9. From January 5, 2007 through September 2007, plea discussions took place between 
the U.S. Attorney's Office for the Southern District of Florida and Jeffrey Epstein, who was 
represented by numerous attorneys??
10. On February I, 2007, the Epstein defense team sent a 24-page letter to the Office 
going over what they intended to present during a meeting at the Office the same day. The letter 
falsely stated: "Epstein did not know or believe any women were under 18 years of age." It also 
contained other deceptive factual and legal arguments about Epstein's culpability.23
1. By March 15, 2007, the Office was sending letters to victims informing them of their 
rights pursuant to the CVRA.24
12. By May 2007, the Office had drafted an 82-page prosecution memorandum and 53-
page indictment outlining numerous federal sexual offenses committed by Epstein 25
13. On about June 7, 2007, FBI agents hand delivered to Jane Doe I a standard CVRA 
victim notification letter. The notification promised that the Justice Department would make its 
"best efforts" to protect Jane Doe I'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 
21 See note 14, supra. 
22 RFP WPB 001744 (Exhibit 42). 
23 RFP WPB 000730.000754 (Exhibit 43) (asserting Epstein thought the girls were 18 or older). 
24 Exhibit I. 
22 US_Atty_Cor. 00004 (Exhibit 44); Exhibit 6. 
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in the district court involving [a]...plea." The notification further stated that, "[a]t this time, your 
case is under investigation."26
14. The notification described in the previous paragraph meant that Jane Doe 1 had been 
identified as a victim of a federal offense and as someone protected by the CVRA. Jane Doe I 
relied on these representations and believed that the Government would protect these rights and 
keep her informed about the progress of her case 29
15. On July 6, 2007, Epstein's lawyers sent a 23-page letter lodging numerous, technical 
legal arguments to persuade the Office that no federal crimes had been committed by Epstein, 
and that consequently there were no federal crime victims. The letter also falsely claimed that 
"Mr. Epstein never targeted minors," and urged the Government against a federal prosecution on 
the basis that Epstein was an upstanding citizen who had made tremendous philanthropic and 
personal contributions that warranted a declination to prosecutes 
16. On August 2, 2007, another attorney for Epstein sent a similar letter expressing the 
same sentiments.29
17. However, by August 3, 2007, the Government had disproven or rejected Epstein's 
various arguments against federal charges, as AUSA 
sent a letter to Epstein's 
counsel stating, tie would reiterate that the agreement to Section 2255 liability applies to all of 
the minor girls identified during the federal investigation, not just the 12 that form the basis of an 
26 June 7, 2007 Victim Notification Letter to Jane Doe I (Exhibit 45). 
17 Exhibit 26. 
2$ MIA_CEOS_00077-00099 (Exhibit 46); RFP MIA 000189 (Exhibit 47). 
29 RFP MIA 000053.000055 (Exhibit 48). 
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initial planned charging instrument."30 This was a clear indication from the federal prosecutors 
that all of the minor girls identified through the investigation were classified as victims with 
federal rights pursuant to the CVFtA. 
18. By September 10, 2007, multiple drafts of the NPA had been exchanged between 
Epstein's counsel and the U.S. Attorney's Office; however, no one from the Office and no 
Government representative had notified a single victim about the existence of the plea 
negotiations, much less conferred with them about their views on those negotiations 3t 
19. On September 12, 2007, while attempting to create alternative charges against Epstein, 
the U.S. Attorney's Office expressed concern about 'e effect of taking the position that Mr. 
Epstein's house is in the special maritime and territorial jurisdiction of the United States" 
because the Government had "no evidence of any assaults occurring either on Mr. Epstein's 
plane or offshore from his residence."32
20. On September 13, 2007, the line prosecutor emailed Epstein's counsel indicating that 
in an effort to come up with a solution to the September 12 concern, she had been "spending 
some quality time with Title 18 looking for misdemeanors." The line prosecutor further 
indicated, "I know that someone mentioned there being activity on an airplane, I just want to 
make sure that there is factual basis for the plea that the agents can confirm." Epstein's counsel 
responded, lailready thinking about the same statutes."33
70 RFP WPB 001479-001480 (Exhibit 49); Exhibit 48 (earlier correspondence attached for reference). 
31 RFP MIA 000058-000063 (Exhibit 50). 
32 Exhibit 12; RFP MM 000072-000073 (Exhibit 51). 
" Exhibit 11 (emphasis added). 
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21. On September 14, 2007, after having spoken on the telephone about the subject matter 
of the September 13 emails, Epstein's counsel and the line prosecutor exchanged emails 
including a proposed plea agreement for Epstein to plea to assaulting one of his co-
conspirators?' 
22. On September 15, 2007, the line prosecutor sent an email to the Epstein defense team 
raising concerns about a resolution that would not involve one of Epstein's minor victims and 
stating: 
I have gotten some negative reaction to the assault charge with [a co-conspirator] 
as the victim, since she is considered one of the main perpetrators of the offenses 
that we planned to charge in the indictment. Can you talk to Mr. Epstein about a 
young woman named [Jane Doe]? We have hearsay evidence that she traveled on 
Mr. Epstein's airplane when she was under 18, in around the 2000 or 2001 time 
frame." 
23. On September 16, 2007, the line prosecutor corresponded with Epstein's counsel 
about having Epstein plead to obstruction of justice for pressuring one of his co-conspirators to 
prevent her from turning over evidence or complying with a previously-served grand jury 
subpoena.36
24. In the same correspondence, the Office discussed with defense counsel how they could 
contrive to establish jurisdiction away from the location where the crimes actually occurred—
and away from where the victims actually lived—so as to avoid the public finding out about 
anything: "On an `avoid the press' note, I believe that Mr. Epstein's airplane was in Miami on 
the day of the [co-conspirator] telephone call. If he was in Miami-Dade County at the time, then 
34 Exhibit 13. 
33 Exhibit 15; RFP WPB 000066-000074 (Exhibit 52). 
36 RFP WPB 000124.000I26 (Exhibit 53). 
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I cart file the charge in the District Court in Miami, which will hopefully cut the press coverage 
significantly." They also discussed having Epstein plea to a second charge of assaulting a 
different co-conspirator." 
25. On September 16, 2007, the line prosecutor wrote to Epstein's counsel indicating that 
the Office did not like the factual basis for the proposed charges as the Office was "not 
investigating Mr. Epstein abusing his girlfriend."38
26. The correspondence further discussed a possible plea disposition that would make it 
hard for a judge to see what was happening: 
Andy [i.e., AUSA Andrew Laurie] recommended that some of the timing issues 
be addressed only in the state agreement, so that it isn't obvious to the judge that 
we are trying to create federal jurisdiction for prison purposes. 
I will include our standard language regarding resolving all criminal liability and I 
will mention 'co-conspirators,' but I would prefer not to highlight for the judge all 
of the other crimes and all of the other persons that we could charge. Also, we do 
not have the power to bind Immigration . . . there is no plan to try to proceed on 
any immigration charges against either Ms. [co-conspirator] or Ms. [co-
conspirator]." 
27. In the same email, the line prosecutor wrote to defense counsel about a meeting 
outside the U.S. Attorney's Office: "Maybe we can set a time to meet. If you want to meet 'off 
campus' somewhere, that is fine.s10
28. On about September 16, 2007, Epstein's counsel provided a proposed NPA to the 
Government that extended immunity from federal prosecution not only for Epstein, but also to 
77 US_Atty_Cor. at 29 (Exhibit 54); RD urn 000122 (Exhibit 55); RFP WPB 000125.000126 (Exhibit 56); RFP 
MIA 000281 (Exhibit 57). 
37 Exhibit 7. 
39 i d.
10 Exhibit 7; US_Atty_Cor. 00196 (Exhibit 58) (indicating that at least one additional meeting was held off campus 
between the Government and counsel for Epstein). 
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certain co-conspirators: "Epstein's fulfilling the terms and conditions of the Agreement also 
precludes the initiation of any and all criminal charges which might otherwise in the future be 
brought against 
Lesley Groff, and 
or any 
employee of N.E.S. for any criminal charge that arises out of the ongoing federal investigation as 
described above."41
29. On September 17, 2007, the line prosecutor wrote to defense counsel Jay Lefkowitz: 
"Please send [a document] to my home e-mail address — [redacted] and give me a call on my cell 
[redacted] so I can be ready for some discussions tomorrow."°Z In discovery in this case, the 
U.S. Attorney's Office has not produced any emails sent to or from any home e-mail addresses 
of its prosecutors. 
30. On September 17, 2007, defense counsel Jay Lefkowitz responded: "[D]o you have 
another obstruction proffer I can review that you have drafted? Also, if we go that route, would 
you intend to make the deferred prosecution agreement public?"4J 
31. On September 18, 2007, the Office responded: "A non-prosecution agreement would 
not be made public or filed with the Court, but it would remain part of our case file. It probably 
would be subject to a FOIA request, but it is not something that we would distribute without 
compulsory process.'" 
32. On September 20, 2007, the U.S. Attorney's Office wrote: "On the issue about 18 
USC 2255 [a civil restitution provision], we seem to be miles apart. Your most recent version 
41 Exhibit 16. 
42 RFP WPB 001709 (Exhibit 59). 
43 Exhibit 17. 
44 Exhibit 10. 
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not only had me binding the girls to a trust fund administered by the state court, but also 
promising that they will give up their 2255 rights.... In the context of a non-prosecution 
agreement, the office may be more willing to be specific about not pursuing charges against 
others.i15
33. On September 21, 2007, state prosecutor 
wrote the line prosecutor 
about the proposed deal and added: "Glad we could get this worked out for reasons I won't put in 
writing. After this is resolved I would love to buy you a cup at Starbucks and have a 
conversation:" 6 Such statement is further evidence of the fact that Epstein's counsel, the U.S. 
Attorney's Office, and the State of Florida were conferring daily in an effort to resolve the case 
in a way that would compensate the victims through restitution, yet no one made any effort to 
notify the victims of the true status of the case. 
34. On September 21, 2007, the line prosecutor emailed Epstein's counsel stating, "I think 
that the attached addresses the concerns about having an unlimited number of claimed victims, 
without me trying to bind girls whom I do not represent.i47 Despite knowledge that such 
agreement would be binding on the victims, the Office never attempted to notify or confer with 
the victims about the existence of the NPA. 
35. On September 23, 2007, the U.S. Attorney's Office sent an email to Lefkowitz stating: 
"It is factually accurate that the list we are going to give you are persons we have identified as 
victims. If we did not think they were victims, they would have no right to bring suit."48
45 RFP AIM 000173 (Exhibit 60). 
46 Exhibit 21. 
47 US_Atty_Cor 0081-0087 (Exhibit 61) (emphasis added). 
a Exhibit 4. 
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36. On September 24, 2007, the line prosecutor sent an e-mail to a prospective 
representative for the Epstein victims named Humberto "Bert" Ocariz, entitled "Conflict Check" 
confirming the girls' status as victims, stating: "Please keep this confidential because these are 
minor victims. This is a preliminary list." 49 Later on September 24, 2007, the line prosecutor 
sent an email to Lefkowitz stating, "I have compiled a list of 34 confirmed minors."50
37. As correspondence continued on September 24, 2007, and the NPA was being 
executed, Lefkowitz sent an email to line prosecutor 
stating: 'M 
— Please do 
whatever you can to keep this [i.e., the NPA] from becoming public.sS1
SIGNING THE SECRET NON-PROSECUTION AGREEMENT 
38. On September 24, 2007, Epstein and the U.S. Attorney's Office formally reached an 
agreement whereby the United States would defer federal prosecution in favor of prosecution by 
the State of Florida. Epstein and the Office accordingly entered into a NPA reflecting such 
agreement. Most significantly, the NPA gave Epstein a promise that he would not be prosecuted 
in the Southern District of Florida for a series of federal felony offenses involving his sexual 
abuse of more than 30 known minor girls and countless other unknown minors. The NPA 
instead allowed Epstein to plead guilty to state felony offenses for solicitation of prostitution and 
procurement of minors for prostitution.52
39. The NPA also set up a procedure whereby a victim of Epstein's sexual abuse could 
obtain an attorney to proceed with a civil settlement with Epstein, provided that the victim 
49 Exhibit 2. 
S0 Exhibit 4. 
st Exhibit 57. 
32 Executed Non-Prosecution Agreement (Exhibit 62). 
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agreed to limit damages sought from Epstein.53 Such provision was devised by Epstein's 
counsel and the Office without the knowledge or consent of the victims, and without any 
opportunity for them to reasonably confer on the provision. 
40. Among other provisions, the NPA expanded immunity to any "potential co-
conspirator" of Epstein's: "In consideration of Epstein's agreement to plead guilty and to provide 
compensation in the manner described above, if Epstein successfully fulfills all of the terms and 
conditions of this agreement, the United States also agrees that it will not institute any criminal 
charges against any potential co-conspirators of Epstein, including but not limited to 
Lesley Groff, or 
"54 
41. The NPA also provided that it was confidential: "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 that disclosure."55
LACK OF VICTIM NOTIFICATION BEFORE THE NPA WAS SIGNED 
42. From the time the FBI began investigating Epstein until September 24, 2007—when 
the NPA was concluded—the U.S. Attorney's Office never conferred with the victims about a 
NPA.56
43. From the time the FBI began investigating Epstein until September 24, 2007—when 
the NPA was concluded—the U.S. Attorney's Office never even told the victims that such an 
$3 Exhibit 62. 
Mats. 
55 
a See Tr. of July 11, 2008 Hearing (Exhibit 63) at 9-12; [DE 141 at 4 (Exhibit 64). 
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agreement was under consideration.57
FAILURE TO NOTIFY OTHER SIMILARLY-SITUATED VICTIMS 
ABOUT THE NPA 
44. Many, if not all, other similarly-situated victims received standard CVRA victim 
notification letters substantively identical to those sent to Jane Doe I and Jane Doe 2 and the 
Government reasonably expected them to rely on those representations.°
45. The U.S. Attorney's Office did not consult or confer with any of the victims about the 
NPA before it was signed." 
46. The U.S. Attorney's Office did not tell any of the victims about the NPA before it was 
signed.°
47. Because none of the victims knew about the NPA or any other possible resolution of 
the case, they could not have conferred with prosecutors about the NPA before it was signed.° 
48. Epstein's counsel was aware that the Office was deliberately keeping the NPA secret 
from the victims and, indeed, had sought assurances to that effect.62
NEGOTIATIONS ABOUT CONCEALING THE NPA FROM THE VICTIMS 
49. After the NPA was signed, Epstein's counsel and the Office began negotiations about 
whether the victims would be told about the NPA.63
" See Exhibit 63 at 9-12; Exhibit 64 at 4; [DE 225-1] at 51 (Exhibit 65). 
" Id. 
" Id. 
60 Id 
61 Exhibit 26; Exhibit 27. 
62 Exhibit 63 at 9; US_ Atty_Cor. 0153 (Exhibit 66) (emphases added); RFP MIA 000489-000491 (Exhibit 67). 
44 Exhibit 66 (emphases added). 
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50. It was a deviation from the Government's standard practice to negotiate with defense 
counsel about the extent of crime victim notifications." 
51. To pressure the Office to agree to positions they wanted, Epstein's counsel began "a 
year-long assault on the prosecution and the prosecutors." This assault was more aggressive than 
any U.S. Attorney Alex Acosta, or any of his prosecutors, had ever seen in their extensive 
experience e5 
52. On about September 24, 2007, the U.S. Attorney's Office sent an e-mail to Leflcowitz, 
stating that the Government and Epstein's counsel would negotiate privately about what 
information would be disclosed to the victims about the agreement: 
Thank you, Jay. I have forwarded your message only to [United States Attorney] 
Alex [Acosta], Andy, and Roland. 1 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.66
53. On September 25, 2007, the line prosecutor 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."67
64 Exhibit 65 at 50. 
" 001795-001797 (Exhibit 68); see, e.g., Exhibit 24. 
b6 Exhibit 66 (emphases added). 
US_Atty_Cor. at 156 (Exhibit 69). 
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54. On September 25, 2007, the line prosecutor sent an email to Lefkowitz, (I) expressing 
what she called "bias" against plaintiffs' attorneys, (2) trying to set up an arrangement whereby 
Epstein's victims would not be represented by various private attorneys, and (3) arguing instead 
for an attorney in Miami who could help keep things concealed: "They [Ted Babbitt, Stuart 
Grossman, Chris Searcy, Jake Lytal] are all very good personal injury lawyers, but I have 
concerns about whether there would be an inherent tension because they may feel that THEY 
might make more money (and get a lot more press coverage) if they proceed outside the Terms 
of the plea agreement. (Sorry — I just have a bias against plaintiffs' attorneys.) One nice thing 
about Bert is that he is in Miami where there has been almost no coverage of this case."68
55. On September 26, 2007, the line prosecutor sent an e-mail to Lefkowitz in which she 
stated: "Hi Jay — Can you give me a call at ■-Ixxx-xxxx] this morning? I am meeting with the 
agents and want to give them their marching orders regarding what they can tell the girls.s69
56. On September 27, 2007, the attorney appointed by the Office to represent the 
victims—without the knowledge of the victims—emailed the Office asking questions about the 
assignment, including whether he could see a copy the indictment or plea agreement "so that we 
understand exactly what Epstein concedes to in the civil case.i70
57. On September 27, 2007, upon inquiry from the Office, Lefkowitz responded by stating 
that the attorney representative "certainly [] should not get a copy of any indictment.s71
68 RFP WPB 000384 (Exhibit 70). 
69 Exhibit 26; US_Atly_Cor. at 359 (Exhibit 71). 
J° 000574-000575 (Exhibit 72). 
RFP WPB 001687 (Exhibit 73). 
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58. On September 27, 2007, the line prosecutor informed Epstein's counsel of concerns 
raised by the attorney representative for the girls selected by the Government and paid for by 
Epstein. Specifically, "[t]he concern is, if all 40 girls decide they want to sue, they don't want to 
be in a situation where Mr. Epstein says this is getting too expensive, we won't pay anymore 
attorneys' fees. "72
59. On September 27, 2007, the line prosecutor sent an email to state prosecutors 
and 
: "Can you let me know when Mr. Epstein is going to enter his 
guilty plea and what judge that will be in front of? I know the agents and I would really like to 
be there, `incognito."' The fact that they intended to be at the plea proceeding "incognito" is 
evidence that they did not intend to notify the victims of the proceeding.73
60. On October 3, 2007, the U.S. Attorney's Office sent a proposed letter that would have 
gone to a special master for selecting an attorney representative for the victims under NPA's 
compensation procedure. The letter described the facts of the Epstein case as follows: "Mr. 
Epstein, through his assistants, would recruit underage females to travel to his home in Palm 
Beach to engage in lewd conduct in exchange for money. Based upon the investigation, the 
United States has identified 40 young women who can be characterized as victims pursuant to 18 
U.S.C. § 2255. Some of those women went to Mr. Epstein's home only once, some went there 
as many as 100 times or more. Some of the women's conduct was limited to performing a 
72 Exhibit 23. 
RFP WPB 002046 (Exhibit 74). 
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topless or nude massage while Mr. Epstein masturbated himself. For other women, the conduct 
escalated to full sexual intercourse."' 
61. On October 10, 2007, Lefkowitz sent a letter to U.S. Attorney Acosta stating, in 
pertinent part: "Neither federal agents nor anyone from your Office should contact the identified 
individuals to inform them of the resolution of the case, including appointment of the attorney 
representative and the settlement process. Not only would that violate the confidentiality of the 
agreement, but Mr. Epstein also will have no control over what is communicated to the identified 
individuals at this most critical stage. We believe it is essential that we participate in crafting 
mutually acceptable communication to the identified individuals." The letter further proposed 
that the attorney representative for the victims be instructed that "[Otte details regarding the 
United States's investigation of this matter and its resolution with Mr. Epstein is confidential. 
You may not make public statements regarding this matter."" 
62. On October 18, 2007, the U.S. Attorney met with Lefkowitz in person for breakfast. 
Meanwhile, the victims had still not been notified of the NPA.76
63. On October 23, 2007, Lefkowitz sent a letter to U.S. Attorney Acosta, which stated: "I 
also want to thank you for the commitment you made to me during our October 12 meeting in 
which you . . . assured me that your Office would not . . . contact any of the identified 
individuals, potential witnesses, or potential civil claimants and their respective counsel in this 
matten 
RIP WPB 000411-000412 (Exhibit 75). 
RFP MIA 000015.000016 (Exhibit 76). 
76 RFP WPB 002020402021 (Exhibit 77). 
77 Exhibit 67 (emphasis added). 
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64. On October 24, 2007, AUSA 
sent a letter to Jay Lefkowitz, proposing an 
Addendum to the NPA clarifying the procedures for the third-party representative for the victims 
under the NPA's compensation procedures.78
65. On October 25, 2007, AUSA 
sent a letter to Ret. Judge Davis about 
selecting an attorney to represent the victims under the NPA's compensation procedure.79
LACK OF VICTIM NOTIFICATION AFTER THE NPA WAS SIGNED 
66. After the NPA was signed, the Office regarded the agreement as having "an express 
confidentiality provision.s80
67. By entering into the confidentiality provision, the Office put itself in a position that 
conferring with the crime victims—including Jane Doe I, Jane Doe 2, and other similarly-
situated victims—about the co-conspirator immunity provision and the NPA's non-prosecution 
provisions would have violated the confidentiality provision of the agreement.81
68. The confidentiality provision was a contractual prohibition, binding on the U.S. 
Attorney's Office, against disclosing the terms of the NPA 82
69. Epstein was well aware of this failure to notify the victims and, indeed, arranged for 
this failure to notify the victims?" 
70. On about October 26 or 27, 2007, after the initial plea agreement was signed, FBI 
agents contacted Jane Doe I. Special Agents E. 
US_Atty_Cor. 00220-00226 (Exhibit 78). 
" 000551-000554 (Exhibit 79). 
" Exhibit 64 at 4. 
61 Exhibit 62. 
82 Id 
" Id.; Exhibit 63 at 4-6, 18-19, 22-23, 28-29; Exhibit 64 at 4-5; Exhibit 69. 
24 
and 
met in 
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person with Jane Doe I. During this litigation, the Special Agents have said that they explained 
that Epstein would plead guilty to state charges involving another victim, he would be required 
to register as a sex offender for life, and he had made certain concessions related to the payment 
of damages? 
71. 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 for crimes committed 
against Jane Doe I or the many other victims cooperating with the federal investigation.BS 
72. The Special Agents also did not explain that an agreement had already been signed 
that precluded any prosecution of Epstein's co-conspirators, including Marcinkova who had 
personally sexually abused Jane Doe I at the direction of Epstein. Because the plea arrangement 
had already been reached with Epstein, the agents made no attempt to secure Jane Doe I 's view 
on the proposed resolution of the case or to confer with her about it.86
73. Jane Doe I did not get the opportunity to meet or confer with the attorney for the 
Government in the case about any potential federal deal that related to her or the crimes Epstein 
committed against her.87
74. The agents could not have revealed the immunity features of the NPA without 
violating its terms, which required that the Government "provide notice to Epstein before making 
... disclosure" of the NPA.88
84 Exhibit 26. 
" Exhibit 62; Exhibit 26; Exhibit 63 at 4.6, 18.19, 22-23. 
u Id. 
87 Id.
u Id. 
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75. Jane Doe l's understanding of the Special Agent's explanation was that only the state 
portion of the Epstein investigation was being resolved, and that the federal investigation in 
which she was participating would continue. This understanding is consistent with the future 
communication she received." 
76. In addition to Jane Doe 1, FBI agents talked to only two other victims out of the 34 
identified victims about the "general terms" of the NPA, including the provision providing a 
federal civil remedy to the victims." 
77. After these meetings with three victims, Epstein's defense team complained. At that 
point, the U.S. Attorney's Office decided not to make any notifications about the NM to any 
victim 91
78. Other than the three victims mentioned above, the United States did not inform any of 
the victims of anything about the status of the case or any plea discussions with Epstein, 
including even the existence of the NPA.92
79. On about November 27, 2007, AUSA 
sent an e-mail to Leflcowitz, (with a 
cc to U.S. Attorney Acosta) stating that the Office had a statutory obligation to notify the victims 
about Epstein's plea to state charges that was part of the NPA: 
The United States has a statutory obligation (Justice for All Act of 2004) to notes 
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 
89 Exhibit 26; Exhibit 63 at 4-6, 18-19, 22-23, 28-29; [DE 58] (Exhibit 80) at I I. 
" RFP MM 000408 (Exhibit 81); Exhibit 64 at 4. 
91 Exhibit 64 at 5. 
92 Exhibit 62; Exhibit 65 at 57; Exhibit 64 at 4-5. 
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master for selecting legal counsel for victims 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 [victim representative] 
. selection 
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 20.93
80. On November 28, 2007, the Government sent an email to Lefkowitz attaching a letter 
dated November 29, 2007 (the apparent date upon which it was intended to be mailed) and 
explained that "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 proposed letter then spelled out a number of the provisions 
in the NM, including that because Epstein's plea to state charges was "part of the resolution of 
the federal investigation," the victims were "entitled to be present and to make a statement under 
oath at the state sentencing.s44
81. On November 28, 2007, Lefkowitz sent an email to U.S. Attorney Acosta (with a copy 
to AUSA Sloman) objecting to victim notifications: 
We do, however, strongly and emphatically object to your sending a letter to the 
alleged victims. Finally, we disagree with your view that you are required to 
notify the alleged victims pursuant to the Justice for All Act of 2004.... 
Furthermore, if a letter is to be sent to these individuals, we believe we should 
have a right to review and make objections to that submission prior to it being 
sent to any alleged victims.... fljt it should happen only after Mr. Epstein has 
entered his plea." 
82. The Government complied with such direction and failed to inform the victims of the 
NPA until after Epstein entered his plea. On November 29, 2007, Lefkowitz sent a letter to U.S. 
Attorney Acosta objecting to the proposed victim notification letter, stating that it is 
93 US_Atty_Cor. at 00255-00262 (Exhibit 82) (emphasis rearranged). 
" RFP WPB 000429 (Exhibit 83); RFP MIA 000011-000014 (Exhibit 84). 
" Exhibit 26 (emphasis added). 
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inappropriate for any letter to be sent to the victims before Epstein entered his plea or had been 
sentenced. Lefkowitz also told the Government that the victims should not be invited to the state 
sentencing, that they should not be encouraged to contact law enforcement officials, and that 
encouraging the attorney representative to do anything other than get paid by Epstein to settle the 
cases was to encourage an ethical conflict.96
83. On about November 30, 2007, U.S. Attorney Acosta sent a letter to one of Epstein's 
defense attorneys, Ken Starr, stating: "I am directing our prosecutors not to issue victim 
notification letters until this Friday at 5 p.m., to provide you with time to review these options 
with your client." The letter also explained that the line prosecutor had informed Acosta "that 
the victims were not told of the availability of Section 2255 relief during the investigation phase 
of this matter" despite the fact that the tittle of law . . . now requires this District to consider 
the victims' rights under this statute in negotiating this Agreement."97
84. Because of concerns from Epstein's attorneys, the U.S. Attorney's Office never sent 
the proposed victim notification letters discussed in previous paragraphs to the victims or 
anything discussing any of the NPA provisions.98
85. On December 5, 2007, Starr sent a letter to U.S. Attorney Acosta (with copy to AUSA 
Sloman) asking about issuance of victim notification letters and stating: "While we believe that it 
is wholly inappropriate for your Office to send this letter under any circumstances, it is certainly 
inappropriate to issue this letter without affording us the right to review it."99
96 REP MIA 000007-000010 (Exhibit 85). 
" RFP MIA 000501-507 (Exhibit 86). 
" Exhibit 26; RFP MIA 000025.000037 (Exhibit 87). 
99 Exhibit 76. 
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