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Page 2 
ATTORNEY FOR EPSTEIN VICTIMS: 'I HAVE NEVER SEEN A STRANGER CASE' Palm Beach Daily News 
September 20, 2009 Sunday 
North Palm Beach criminal defense attorney Barry Maxwell said he is not surprised that federal charges weren't 
filed. 
"My experience has been that the federal government does not intervene in sex-assault cases, except if we're deal-
ing with a serial rapist or it crosses jurisdictional lines," Maxwell said. "It's either not a big enough case or not atrocious 
enough for them." 
Epstein, 56, served 13 months of his 18-month sentence at the Palm Beach County Stockade and received liberal 
work-release privileges while in jail. He was able to go to his West Palm Beach office six days a week for up to 16 
hours a day. 
He is now serving one year of probation at his Palm Beach mansion and is registered as a lifelong sex offender. 
Epstein 'flatly abided' by deal, says defense 
Epstein's attorney Jack Goldberger released the following statement: "This document relates to allegations that 
were made many years ago. It was by its provisions and agreement of the parties to remain confidential in part to protect 
the identities of collateral third parties. 
"Mr. Epstein has fully abided by all of its terms and conditions. He is looking forward to putting this difficult peri-
od of his life behind him. He is continuing his longstanding history of science philanthropy both here In South Florida 
and nationwide." 
Goldberger had blocked the unsealing by filing court papers asking that the documents stay scaled "to prevent a se-
rious imminent threat to the fair, impartial and orderly administration of justice; to protect a compelling government 
interest; to avoid substantial injury to innocent third parties; and to avoid substantial injury to a party by disclosure of 
matters protected by a common law and privacy right, not generally inherent in these specific type of proceedings, 
sought to be closed." 
Circuit Judge Jeffrey Colbath ordered the agreement to be unsealed in June, but Epstein's attorneys appealed the 
ruling to the Fourth District Court of Appeals, which affirmed Colbath's ruling. Colbath had ruled that the federal 
agreement — sealed in state court — was improperly sealed. 
'I felt it was my fault' 
More than a dozen lawsuits against the billionaire money manager have been filed in federal and state court, all 
with similar allegations: that a minor girl was taken to Epstein's mansion on El Brillo Way and led upstairs to a spa 
room by one of Epstein's assistants, where he would ask the girl to perform massages and/or various sex acts, for which 
he would pay her. 
One victim, who is known as Jane Doe #5 in a federal court lawsuit against Epstein, said she didn't find out about 
the deal until after it was finalized. She was IS at the time one of her schoolmates told her she could make $200 by giv-
ing a massage to a man in Palm Beach. 
She says she was "nervous and scared and wanted to leave" once she got to Epstein's spa mom. 
"I thought, 'I can't call my dad or my mom because I'm stuck in this situation and didn't know what to do," she said. 
"I really didn't know what this man was capable of. For a long time, l felt like it was my fault and that's exactly what he 
wanted me to feel." 
Epstein has curfew 
While he is serving the 12 months of house arrest at his Palm Beach home, Epstein must observe a 10 p.m. to 6 
a.m. curfew, have no unsupervised contact with anyone younger than 18 and not view, own or possess pornographic or 
sexual materials. 
The indictment followed an ll-month investigation by Palm Beach police, who said Epstein paid five underage 
girls for massages and sometimes sex at his El Brillo Way home. Then-State Attorney Barry Krischer declined to pros-
ecute Epstein on multiple charges involving unlawful sex acts with minors. Instead, he brought the case to a grand jury, 
which charged Epstein on the lesser charge of soliciting prostitution. 
Then-Palm Beach Police Chief Michael Reiter wrote Krischer a letter asking him to remise himself from the case. 
When that didn't happen, Reiter requested an FBI investigation to determine if any federal laws were broken. 
EFTA00191344

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ATTORNEY FOR EPSTEIN VICTIMS: 'I HAVE NEVER SEEN A STRANGER CASE' Palm Beach Daily News 
September 20, 2009 Sunday 
'Out of the ordinary' 
West Palm Beach criminal defense attorney Gregg Lerman said several aspects of the Epstein case are unusual. 
"I don't understand why it would be a federal case in this circumstance, and why was there anything in writing at all 
and why did they seal the agreement? Lerman said. 'Why did it go to the grand jury instead of through the state filing 
lewd assault charges? That's unusual. And it's very unusual that they structure a plea to get county time rather than 
prison time. That's definitely out of the ordinary. Nobody goes to county jail as a state criminal punishment." 
— mdargan 
(i)pbdailynews.com 
GRAPHIC: Caption: Epstein Deal does not allow prosecution of co- conspirators. 
LOAD-DATE: September 1, 2010 
EFTA00191345

Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 17 of 
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Local News West Palm Beath. Palm Beach County, Martin at SI. Ludt Counties I The Palm Beach Post 
I 
NEWS 
Source 
rim .INDUillONFLTRELOIL• 
CLEANS OUT UP TO 40% OF 
SLUDGE IN THE WE OIL CHANGE? 
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Local 
News 
Li, Creak, Palm Beaches and Trrasure Coen 
Palm Beach sex offender's secret plea deal: 
Possible co-conspirators not charged, presses 
victims to settle civil suits 
BY SUSAN SPENCER.WENDEL 
Pam 80•01 Post Shoff Meer 
Friday. Seplamber 10.2009 
WEST PALM BEACH — fiflonaire Mender sex offender Jeffrey Epstaln's secret non-proseaNch weaned ha 
'Ouch with Wein prosecutor, was Waxed Friday. Offering the not pubic look et the deal Epstein's high-powered 
legal canal brokered on hie behalf 
Soo:ding the agreement, ha Federal GUMMI of Investigation and the U S Altoinefs Ottica invehlgaled Epstein 
IOr verhus Went afros India/00 PrOsalutton some pun shed. by • Wilma" 01 10 yen uP to la In Olen 
But redenil prosaanon backed down and *greed lc mad goy fry subpoenas. II Epstein ganged guilty to 
pnatlagarnrshend felonies h mate court which heutUrnately de Ile reashed an 154nanth Oa sentence of which 
he served 13 
A lama tenni prosecutor of 15 yeert Mad Johnson al Stuart said the depanty In the odorant sentences was 
arse/ 
The USW Saws Moneys Oda dee *dyed not lo charge any ol Eolith's possible co-compmica • Sarah 
Kellen, Actlans Rom Lesley Groff end Nada Misrartove 
The agreement was negotiated In pert by New York howywegm ezignInal deem. Quemoy Geoid Larogn 
on Its Aril draft h SePtentRar 21301.ilIerfulmd wt Epstein Par en &TOSS • LOOPS by the U.S AranYri• OfAce 
and approved by Epheln -to represent some of the slams In civil wits they had reed newt Spank, Thal 
attorney le promised Miami Weyer Doti Josafsbeg 
Former prom:dor Johnson sag ho has nrner nen a provision Ma that belay 
But en edclondon to the adeentent signed the b owing month stud EISetataYs dry te pay SaatabaTilaS and Me 
victims WS not scup( a soltament end head Wwed litigator 
The agreement. alined by Aselstent U S Stoney Mena Vlits'ens. don not washy sale whether any Nano 
were contained or consulted beton. he del was made. 
Attorney Brad Edwards of Fort Logordale. who repined. Inge of he young women. believes eel none of pa 
between 30 end 40 woman klionthed Cs vxtrns In the federal hveetggon were laid of the del Ed ride said No 
clients were nil fepeiving Wen a the mall months aletwerds saying Me U.9 Attorneys Office enuring thorn 
Epstein would be prosecuted 
'Never Ontiulting he victims a probably the most milogrous aspect of • • E delude 
SWIM *am SI 
inane *Oh money on buy Ms way out of anydikg Ira outrageous end embarrneing Ce United State* 
Morays Othrte and the State Attorneys Onto' 
Epstein now feces many chllevamits fled by Me *Omen. who ere rePrellenial by • vs/101Y Altorrera In "SS. the 
fads sailed are the @erne that famish had a pied ecuon for teenage gale. dahlia? poor. 'anorak, an., end 
lung them to Ns hone via other young women The teens descnbs esteno.ne a atalrcasa fried with nude 
Phologradis of young don end to the spa roan where Epstein woud appear in a sawn laWal 
Fame. Chat Judge 811 WOW. wed manedu one of Me victima. end The Pain Bead) Poet sagN the 
unsealing of the evened Berger refers ail as a 'swell/wan 0aai • 
'Why wee li so Imported 'or he godmmont to make ads deal?' Berger asked ttelalcaay 'We have not yet had 
honest explanalfon by any public panda/ as to why II was made 
and wily On VICIWY9 were IOW dews/ to river • 
fanner leder* prosecutor Ryon McCabe described the agreement in 'very uncirlhodoe Such agreements. he said. 
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EFTA00191346

Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 18 of 
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Local Newt West Palm Beach, Palm Beach County, Marlin di Si. Lucie Counties I The Palm Beach Post 
416/t3 138 PM 
Ma vary, nry ram Ih novae men or Mead of the prtiardOre that wet let up hero' uld McCabe who ha. no 
invetvemoM in my Epstein Illlsollon and is now o securities itgaton Niamey 
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pro "emotion.' 
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worked tor Epstein Including Henri Fenno' Nun Danneertz end Kenneth Sim of anion Impeadenont lefts 
Lelcove le • pest penident c4 the Nebel& AseedatIon of Criminal Dolton Lawyers 
Egitesys local deems exemity. Jack GeldbergOI. Issued a «element Friday saying he had fought tie rebase or 
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dubbed NM. artor they retained a carplakil ken a relative 01 a 14.yeareed girt etc hed Slyer* Epstein a naked 
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Page I 
LexisNexis 
7 of II DOCUMENTS 
Copyright 2009 ProQuest Information and Learning 
All Rights Reserved 
ProQuest SupaText 
Copyright 2009 Palm Beach Post 
Palm Beach Daily News 
June 25, 2009 Thursday 
Final Edition 
SECTION: A SECTION; Pg. A.I 
LENGTH: 557 words 
HEADLINE: JUDGE TO RULE ON SEALED PLEA-DEAL PAPERS TODAY 
BYLINE: MICHELE DARGAN, MICHELE DARGAN, Daily News Staff Writer 
BODY: 
A circuit judge will decide today whether the public will be privy to the federal government's non-prosecution deal 
with Jeffrey Epstein, which was sealed when the convicted sex offender pleaded guilty in June 2008 to two felony 
counts. 
Epstein, of Palm Beach, will be released from the Palm Beach County Stockade July 22, after serving less than 13 
months of his 18- month sentence for procuring a minor for prostitution and solicitation of prostitution. 
Teri Barbera, spokeswoman for the Palm Beach County Sheriffs Office, confirmed his release date Tuesday. 
Epstein's projected release date had been Sept. 24, but gain lime — which includes his participation in a 
work-release program — moves the date up to July 22, Barbera said. 
Epstein, 56, has been in the work-release program since Oct. 10, in which he is allowed out of the stockade six days 
a week, from 10 a.m. to 10 p.m., to go to his West Palm Beach office, the Florida Science Foundation, monitored by an 
ankle bracelet and accompanied by a deputy. 
As part of Epstein's state plea agreement, the U.S. Attorney's Office agreed not to prosecute Epstein on federal 
charges as long as he fulfills all requirements of his sentence and probation. The federal non-prosecution agreement has 
been under seal in state court. 
Epstein's attorney Jack Goldberger filed court papers asking that the documents stay sealed for the following rea-
sons: "to prevent a serious imminent threat to the fair, impartial and orderly administration of justice; to protect a com-
pelling government interest; to avoid substantial injury to innocent third parties and to avoid substantial injury to a party 
by disclosure of matters protected by a common law and privacy right, not generally inherent in these specific type of 
proceedings, sought to be closed." 
Fort Lauderdale-based attorney Brad Edwards represents three Epstein victims and has asked Circuit Judge Jeffrey 
Colbath to unseal the federal agreement to the public. An attorney for The Palm Beach Post also has asked that the rec-
ords be unsealed. 
Edwards and his clients have seen the agreement after a federal judge ruled that they are allowed to see it. But that 
ruling bars Edwards and anyone else who sees the document from disclosing the terms to anyone else. 
Edwards said he wants to use that document "in the deposition of various material witnesses" relative to his cases. 
EFTA00191348

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Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 20 of 
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Page 2 
JUDGE TO RULE ON SEALED PLEA•DEAL PAPERS TODAY Palm Beach Daily News June 25, 2009 Thursday 
Radaronline.com has reported that Epstein has "secretly been helping the reds unravel a Ponzi scheme" related to 
the June 2008 indictment of two former managers of Bear Stearns Mortgage Investment Fund. 
Epstein's rep, Howard Rubenstein, confirmed last year that Epstein is "Major Investor No. 1" in the indictment, 
which says he lost about 557 million. 
Goldberger could not be reached for comment. 
The Manhattan money manager has been incarcerated since June 30, when he pleaded guilty to the two felony 
counts. As part of the plea agreement, Epstein must serve one year of house arrest after his release and register as a life-
long sex offender. 
In addition to the criminal case, there are more than a dozen civil lawsuits — both state and federal — pending 
against Epstein. All contain similar allegations: Epstein, through his employees and assistants, brought minor girls to his 
Palm Beach home on El Brill° Way for erotic massages and sometimes sex. 
— mdargan®pbdailynews.com 
GRAPHIC: Caption: Epstein To be released from jail July 22. 
LOAD-DATE: September I, 2010 
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Page I 
LexisNexis" 
9 of 13 DOCUMENTS 
Copyright 2009 Sun-Sentinel Company 
All Rights Reserved 
Sun-Sentinel (Fort Lauderdale, Florida) 
June IS, 2009 Monday 
Palm Beach Edition 
SECTION: LOCAL; Pg. 3B 
LENGTH: 348 words 
HEADLINE: HEARING SET TO CONSIDER SECRECY OF PLEA BARGAIN 
BYLINE: Susan Spencer-Wendell The Palm Beach Post 
BODY: 
A Palm Beach Circuit Court judge will not immediately unseal a deal that wealthy Palm Beach money manager 
Jeffrey Epstein made with federal prosecutors to avoid charges. 
Circuit Judge Jeff Colbath acknowledged, though, at a hearing last week that Epstein's deal was not sealed in ac-
cordance with state and local court rules. 
"I don't see where any of the procedures were ever followed to begin with," Colbath said. 
Colbath also set a full hearing on the matter for lune 25. 
Attorneys for young women now suing Epstein, together with The Palm Beach Post, are asking Colbath to unseal 
the deal that Epstein made with federal prosecutors. 
"It's a secret agreement, a secret sweetheart agreement," said former Circuit Judge Bill Berger, who represents 
some of the women. "Everybody was in on this deal except the victims and the public. The public should be outraged it 
has gone as far as it has." 
Brad Edwards, a second attorney representing the women, has seen the sealed deal after a federal judge allowed 
him and his clients to view it, but would not discuss its contents. 
Edwards would say only that the women were "outraged' that it had been negotiated behind their backs. 
A reporter asked Edwards whether he thought Epstein received special treatment by federal prosecutors. 
"Are you kidding? It's transparent. Certainly, no one else gets treated like that," Edwards said. 
Epstein, 56, a reported money manager of billionaires, is serving an I8-month sentence in the Palm Beach County 
Stockade after pleading guilty almost a year ago in state court to felony solicitation of prostitution and procuring teen-
agers for prostitution. Epstein is allowed out, though, each day horn 7 a.m. to I I p.m., a Sheriffs Office spokesman 
said. 
Displeased with the way the State Attorney's Office handled the case, Palm Beach police forwarded information to 
the FBI. 
INFORMATIONAL BOX: 
Young women have sued 
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HEARING SET TO CONSIDER SECRECY OF PLEA BARGAIN Sun-Sentinel (Fort Lauderdale, Florida) June 15, 
2009 Monday 
Money manager Jeffrey Epstein made a deal and is serving an 18-month sentence in jail. Attorneys for young 
women suing Epstein are asking a judge to unseal the deal that Epstein made with federal prosecutors. 
NOTES: < Informational box at end of text. (TOPIC) Prostitution solicitation case 
LOAD-DATE: June I5, 2009 
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COMPOSITE EXHIBIT 3 
EFTA00191352

caVelikarlergticRAM dirt:WM/61'1-1491 feLgtWfbtficiffrqiaVed6€001$6gibt#014••• pkie of 43 
tbe Ottobingtost 
Eleventh Circuit rules that discovery 
can move forward on my Crime 
Victims' Rights Act case 
By Paul Cassell Updated: April 21 at 9:41 am 
On Friday the llth Circuit ruled that discovery can move forward in an important 
Crime Victims' Rights Act case that my co-counsel, Brad Edwards, and I are 
pursuing. The narrow issue before the court was whether prosecutors and defense 
attorneys could assert some sort of "privilege" to prevent crime victims from 
reviewing the correspondence that lead to a plea bargain. More broadly, the ruling 
means that the victims will have a chance to return to the district court and seek to 
invalidate a plea agreement that (we alleged) was consummated in violation of their 
rights. I hope that the case will ultimately set an important precedent that federal 
prosecutors can't keep victims in the dark about the plea deals that they reach. 
Here are the important facts, taken from the Ilth Circuit's opinion: The case arose in 
2006, the FBI began investigating allegations that wealthy investor Jeffrey Epstein 
had sexually abused dozens and dozens of minor girls. The U.S. Attorney's Office for 
the Southern District of Florida accepted Epstein's case for prosecution, and the FBI 
issued victim notification letters to my two clients, minors Jane Doe No. I and Jane 
Doe No. 2, in June and August 2007. Extensive plea negotiations ensued between the 
prosecutors and Epstein. On Sept. 24, 2007, the prosecutors entered into a non-
prosecution agreement with Epstein in which they agreed not to file any federal 
charges against Epstein in exchange for his guilty plea to minor Florida offenses (e.g., 
solicitation of prostitution). Not only did the prosecutors neglect to confer with the 
victims before they entered into the agreement with Epstein, they also concealed its 
existence for at least nine months. For example, the prosecutors sent post-agreement 
letters to the victims reporting that the "case is currently under investigation" and 
explaining that "[t]his can be a lengthy process and we request your continued 
patience while we conduct a thorough investigation." 
On June 27, 2008, the prosecutors informed my co-counsel Brad Edwards, that 
Epstein planned to plead guilty to the Florida charges three days later. But the 
prosecutors failed to disclose that Epstein's pleas to those state charges arose from his 
federal non-prosecution agreement and that the pleas would bar a federal prosecution. 
As a result, the victims did not attend the state court proceedings. 
On July 7, 2008, Edwards and 1 filed a petition alleging that Jane Doe No. I was a 
victim of federal sex crimes committed by Epstein and that the United States had 
wrongfully excluded her from plea negotiations. We also alleged that the federal 
prosecutors had violated her rights under the Crime Victims' Rights Act (CVRA) 
http://www.washingtonpost.cominewsholokh-conspiracy!wp/2014/04/2 Veleventh-circuit-r... 
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EFTA00191353

caWvot-Prsttodco,thet dbtatiyecinums kretvbanompc§egitiokiettgaivokc4..- plkits2 of /3 
specifically her rights to confer with the government, to be treated with fairness, to 
receive timely notice of relevant court proceedings, and to receive information about 
restitution. The United States responded by claiming that it used its "best efforts" to 
comply with the rights afforded to victims under the CVRA, but that the act did not 
apply to pre-indictment negotiations with potential federal defendants. 
After Jane Doe No. 2 joined the initial petition, the district court (Marra, J.) found 
that both women qualified as "crime victims" under the CVRA. The district court 
later rejected the government's argument that the act only applies after the filing of a 
federal criminal indictment. (I've written a law review article about the issue of how 
early crime victims' rights attach in the criminal process, which can be downloaded 
here.) 
Among other relief, we sought rescission of the non-prosecution agreement as a 
remedy for the violation of the victims' rights. To make the case for such a remedy, 
we moved for discovery of the correspondence between the U.S. and Epstein's 
attorneys during the plea negotiations. Epstein's attorneys intervened, arguing that 
Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a 
privilege for plea negotiations, barring release of the correspondence. They also 
argued that the court should find that the materials were protected under the work 
product doctrine or, alternatively, should be protected under a new "common-law 
privilege for plea negotiations." 
The district court first ruled that rescission of the plea agreement was a possible 
remedy under the act. The court then ruled that we were entitled to review the 
correspondence, rejecting all of Epstein's arguments. 
On Friday, the 11th Circuit affirmed the district court's ruling that we could review 
the plea correspondence. At pp. 18-22 of its published opinion, the court concluded 
that there was no basis for restricting access to such correspondence when crime 
victims have a legitimate need to review it. The court rejected, for example, the work 
product argument because plea discussions are not confidential: 
Disclosure of work-product materials to an adversary waives the work-product 
privilege. See, e.g., In re Chrysler Motors Corp. Overnight Evaluation Program 
Ling., 860 F.2d 844, 846 (8th Cir. 1988); In re Doe, 662 F.2d 1073, 1081-82 (4th Cir. 
1981). Even if it shared the common goal of reaching a quick settlement, the United 
States was undoubtedly adverse to Epstein during its investigation of him for federal 
offenses, and the intervenors' disclosure of their work product waived any claim of 
privilege. . . . 
The court also declined to recognize a new privilege for plea bargaining, finding the 
relationship between prosecutors and defense attorneys did not need special 
protection: 
As a last-ditch effort, the intervenors contend that "lijf more is needed in addition to 
the plain language of Rule 410 to preclude disclosure of the correspondence to 
plaintiffs, it can be found in the conjunction of Rule 410, the work-product privilege, 
and the Sixth Amendment right to the effective assistance of counsel in the plea 
bargaining process," but this novel argument fails too. As explained above, Rule 410 
http://www.washingtonpost.com/news/volokh-conspiracy/wp/2014/04/21/eleventh-circuit-r... 
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EFTA00191354

caRcniglarSektitisikAt dbEefrFibfrinAtil fietarkobwr€§evoNSicOotAtasolci...pg§siq efh 
does not create a privilege and the intervenors waived any work-product privilege. 
The intervenors concede too that the right to counsel under the SiVI Amendment had 
not yet attached when the correspondence was exchanged. Lumlek. City of Dade 
City, Fla., 327 F.3d 1186,1195 (11th Cir. 2003) ("[T]he Sixth Amendment right to 
counsel ordinarily does not arise until there is a formal commitment by the 
government to prosecute," such as a "formal charge, preliminary hearing, indictment, 
information, or arraignment."). The "conjunctive" power of three false claims of 
privilege does not rescue the correspondence from disclosure. ... 
The Supreme Court has identified several considerations relevant to whether a court 
should recognize an evidentiary privilege—the needs of the public, whether the 
privilege is rooted in the imperative for confidence and trust, the evident' ry benefit 
of the denial of the privilege, and any consensus among the states, Jaffee' Redmond, 
518 U.S. I, 10-15 (1996)—but none of these considerations weighs in favor of 
recognizing a new privilege to prevent discovery of the plea negotiations. Although 
plea negotiations are vital to the functioning of the criminal justice system, a 
prosecutor and target of a criminal investigation do not enjoy a relationship of 
confidence and trust when they negotiate. Their adversarial relationship, unlike the 
confidential relationship of a doctor and patient or attorney and client, warrants no 
privilege beyond the terms of Rule 410. See Jaffee, 518 U.S. at 10. But the victims 
would enjoy an evidential)/ benefit from the disclosure of plea negotiations to prove 
whether the United States violated their rights under the Act. 
Moving forward, this case raises the important issue of what kinds of remedies are 
available for violations of the Crime Victims' Rights Act. Our complaint alleges that, 
prodded by Epstein, the federal prosecutors deliberately concealed the sweetheart 
plea deal they had reached with him to avoid public criticism of the deal. I am 
hopeful that in future district court proceedings, we will be able to prove that clear 
violation of the CVRA and then obtain the remedy of invalidating the illegally-
negotiated plea deal. 
The Washington Post Company 
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Posted: 12 00 a.m. Monday. April 21. 2014 
Appeals court rules against sex offender 
Attorneys for underage victims seek to overturn 'sweetheart plea.' 
Related 
By Michele Dargan 
Daily News Staff Writer 
Underage victims of billionaire sex offender Jeffrey Epstein are entitled to correspondence between federal prosecutors and 
Epstein's attorneys related to his sweetheart plea deal, a federal appeals court ruled Friday. 
This is one more step in the fight by victims' attorneys Brad Edwards and Paul Cassel1 10 overturn the secret deal. which 
saved Epstein from facing serious federal charges and serving significant prison lime. 
If Epstein had been found guilty on federal charges, statutory penalties ranged from 10 years to life in prison.
Instead, the sealed pact was pail and parcel of Epstein's acceptance of a slate plea deal Epstein pleaded guilty to 
soliciting a minor for prostitution and soliciting prostitution. He received an 18-month sentence in a vacant wing of the Palm 
Beach County Stockade, and was let out on work release six days a week for up to 16 hours a day. 
Edwards and Cassell represent Jane Doe No. 1 and Jane Doe No. 2, who say the U.S. Attorneys Office violated the Crime 
Victims' Rights Act by signing the federal non-prosecution agreement In 2007 without notifying the victims. Their case is 
pending in U.S. District Court in West Palm Beach. 
The 24-page published opinion says U S. District Judge Kenneth Marra did not err in his June 2013 ruling, when he ordered 
the correspondence turned over to the victims. 
"Sweetheart plea' 
'We're now going to get a complete picture of the negotiations that led to this sweetheart plea arrangement,' said Cassell. a 
former federal judge 'We think It will show the part of the discussion to keep the victims in the dark about what was 
happening. If that's what the correspondence shows, we'll use that as part of our argument for throwing out the plea: 
Cassell said he anticipates that 500 pages of correspondence should be released early this week 
The opinion by the three-judge panel ruled against Epstein's arguments that the correspondence was protected by an 
attorney's work-product privilege. The court says privilege was waived when attorneys voluntarily sent the correspondence 
to federal prosecutors during negotiations. 
"Disclosure of work-product materials to an adversary waives the work-product privilege: the ruling says. 
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The ruling also dismissed Epstein's claims that a federal rule of evidence protects his plea correspondence. That rule 
applies only to defendants who withdraw a guilty plea. Because he pleaded guilty. that doesn't apply, the ruling says. 
'While respectful of the panel's decision, given issues of overriding importance to the criminal justice system regarding the 
need for continued confidentiality for communications between defense lawyers and prosecutors, we will be petitioning the 
court of appeals for further review: said Boston based atlomey Martin Weinberg, who represents Epstein. 
The U.S. Attorney's Office failed to notify victims prior to striking a non-prosecution agreement with Epstein on Sept. 24. 
2007. and didn't tell them of the agreement's existence for al least nine months, the ruling says. 
On June 27, 2008, the U.S. Attorney's Office told the victims that Epstein planned to plead guilty to stale charges three 
days later. But federal prosecutors failed to disclose that his pleas to the stale charges arose from his federal non-
prosecution agreement and would bar federal charges. 
Jane Does No. 1 and No. 2. who were, respectively. 12 and 13 at the time they were victimized,received confidential 
monetary settlements in civil cases. 
They are among more than two dozen underage girls who filed lawsuits or settled claims against Epstein. All alleged they 
were lured to his Palm Beach mansion to give him sexually charged massages andlor sex In exchange for money. 
'A well-connected billionaire got away with molesting many girls,' Edwards said. "These girls should al least know how and 
why he was able to get away with these crimes. This ruling will allow us access to the documents that will provide insight 
into how that happened. I suspect that the answers revealed by these documents will ultimately allow us to invalidate that 
agreement and permit prosecution of Mr. Epstein." 
More News 
We Recommend 
From Around the Web 
• Appeals-court decision in Epstein case rights a 
terrible wrong (Palm Beach Daily News) 
• Memorial service set for former 'Daily News' 
reporter (Palm Beach Daily News) 
• Ernest S. Johnston Jr. (Palm Beach Daily News) 
• Choosing plants? There's always something new 
(Palm Beach Daily News) 
• Slate restripes Royal Palm intersections (Palm 
Beach Daily News) 
• Eunice "Penny Jacobs (Palm Beach Daily 
News) 
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• Posted by THEPALMBEACHER1 at 3:02 pm Apr 21. 2014 
• Report Abuse 
Its inconceivable to see articles like this!' USUALLY, one gels charged with statutory rape, child molestation, etc.. and its 
Guaranteed that they will do prison lime. Now, If your a "BILLIONAIRE". you can BUY yourself freedom, and throw money 
to the victims and say adiostlft Its OBVIOUS, payments. kickbacks. DONATIONS, financial promises are all part of this 
deal. Where is the JUSTICE SYSTEM? Where is the Stale Attorney. The JUDGES? People go to jail for petty thefts, illegal 
drugs, assault. battery, domestic violence, but this case is PROOF that the LEGAL system can be BOUGHT for the right 
price!!' Its OBVIOUS this individual has a severe mental problem, a sexual predator, who would ship young girls like human 
trafficking back and forth via his private jets . Its no different than "THE BACKPAGE" girls being exploited by their pimps 
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being housed in cheap motels along federal hwy for GUY LIKE THIS to get their sexual perversions satisfied!! Read tho 
entire case and see That young gills flowed thru Palm Beach South Ocean Blvd and South County Rd to his El Brillo 
"MANSION OF PERVERSION' with this guy as its Master!! For people to think "Palm Beach" has the "Elite", the "Upper 
Crust" of society, it also is home to some of the worst thieves, sexual predators, financial criminals the world has ever 
known!! Mr Epstein has Billions of Dollars, and can afford the Best Criminal Attorneys, yet Can't or WON'T get Professional 
Mental Help with hi9 sexual desires and fascination with young girls And the Court systems goes along with him!!! 
Unbelievable.. 
• Posted by Adios al 3:12 pm. Apr 22, 2014 
• Report Abuse 
I agree with the post by the palm bleacher. This guy is a pery and needs to sit out of society. Vvhen listening to his 
depositions. he pretended to be insulted by the questions being asked of him and his lawyer shut it down quickly VVhat 
remains to be seen is if the soon lo be released files will bear the fruit we all hope it does My worry is that the tracks will be 
covered and he will not get his due 
His opinion of himself allows hum to think he did nothing wrong and these BABIES he molested were not of his place in 
society and were simply objects to be thrown away. Mat would he think if someone did that to his BABIES if he has any? I 
can bet that the full force of his money would work against whomever played with his kids. ...bloody gross! 
2 Comment(s) 
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sun-sentinel.com/news/palm-beach/fl-jeffrey-epstein-federal-court-of-appeals-
20140421,0,6594687.story 
Sun Sentinel 
Victims win right to see negotiations that led to 'lenient' plea 
agreement for billionaire sex offender 
Latest in legal saga involving Jeffrey Epstein, 61, financier convicted of procuring 
minor for prostitution 
By Brett Clarkson, Sun Sentinel 
7:43 PM EDT, April 21, 2014 
Did a Palm Beach billionaire being investigated for having sex with young girls use his 
wealth to negotiate a lenient and secret agreement that saw him avoid federal 
prosecution? 
Attorneys for two victims, known only as Jane Doe I and 2, may soon get an answer thanks to an 
appeals court ruling against financier and sex offender Jeffrey Epstein, 61. 
The ruling, issued Friday, orders federal authorities to disclose the correspondence that took place 
between Epstein's attorneys and federal prosecutors when they were negotiating a 2007 agreement, 
which allowed him to escape federal prosecution if he pleaded guilty to state charges that carried a 
lesser penalty. 
"We're trying to figure out if Epstein used his political connections and great wealth to secure this 
kind of arrangement, that was unheard of, frankly, if you look at these charges," said Paul Cassell, an 
attorney for the women. 
Epstein is a native New Yorker who according to media reports built a huge fortune as a money 
manager and owns several properties including a primary residence in Manhattan, a Palm Beach 
mansion and his own island in the Caribbean. At one point he counted among his friends former 
President Bill Clinton, Donald Trump and other high-powered figures. 
The appeal court decision described the background of Epstein's case, stating that in 2006, the Federal 
Bureau of Investigation "began investigating allegations that Jeffrey Epstein had sexually abused 
several minor girls." 
In September 2007, federal prosecutors struck the non-prosecution deal with Epstein, but didn't tell 
the victims, court filings say. 
"Not only did the United States neglect to confer with the victims before it entered into the agreement 
with Epstein, it also failed to notify them of its existence for at least nine months," Circuit Judge 
William H. Pryor wrote in the appeals court decision. 
ad vertiseinenl 
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In June 2008, Epstein pleaded guilty to a state charge of procuring a person under the age of 18 for 
prostitution and was sentenced to 18 months in prison. He spent 13 months behind bars, and is 
registered as a sex offender in Florida. 
The situation also resulted in civil suits being filed against Epstein, who according to media reports 
settled claims from about two dozen young women who alleged he paid them for sexual massages at 
his Palm Beach mansion, some as young as 14, according to media reports. 
To the attorneys who represent the Jane Does 1 and 2, the sentence was much lighter than the years, 
or possibly decades, that Epstein could've spent behind bars had he been prosecuted in the federal 
system. 
They're hoping that the correspondence, ordered released by the Eleventh Circuit Court of Appeals, 
will shed light on what they say is an unusually lenient deal. 
"I can say that I've been teaching criminal law for more than two decades and I have never seen a plea 
agreement as lenient as this one, for hands-on sex offenders," said Cassell, who is based in Salt Lake 
City. 
But one of Epstein's attorney's, Martin Weinberg, based in Boston, disputed those characterizations. 
Weinberg said Monday that the plea agreement was "reached in good faith" and that "it's not a fair 
conclusion" to describe the agreement as either improper or tainted by Epstein's wealth. 
"It's Mr. Cassell's hope that this correspondence may support that theory, but the reality is that the 
U.S. Attorney's Office made a responsible judgment in how to implement the law," Weinberg said. 
Weinberg said he was concerned about the potential impact the ruling would have on the ability of 
criminal defense attorneys and prosecutors to communicate confidentially. 
He also said he and Epstein co-counsel, Miami criminal defense attorney Roy Black, will ask the 
Atlanta-based appeals court to review the decision. 
As for the Jane Does, who are now over 18, it's just the latest development in a long legal saga, 
another one of their attorneys said. 
"They're pretty numb at this point to favorable news because they've heard this before and nothing's 
happened," said Fort Lauderdale attorney Brad Edwards. 
Edwards and Cassel said their goal is to have Epstein's plea agreement deemed to be in violation of 
federal victims' rights legislation and invalidated. Edwards said Epstein should face a new 
prosecution. 
Edwards also said he was first told by the U.S. Attorney's Office that he would receive the 
correspondence documents on Monday, but was then told that they weren't ready yet. Cassell said the 
documents number 500 pages. 
In an email, Annette Castillo, spokeswoman for the U.S. Attorney's Office, Southern District of 
Florida, said the office couldn't comment. 
bsclarksonetribune.cont, 561-243-6609 or Twitter @BrettClarkson 
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Appellate ruling could force feds to reconsider sex charges against Palm 
Beacher Epstein 
Posted. 9., • rn Monday. April 21, 2014 
BY DAPHNE DURET - PALM BEACH POST STAFF WRITER 
A federal appellate court has moved two young victims of billionaire sex offender Jeffrey Epstein a step closer 
to wiping out a plea deal that prosecutors made behind their backs. 
The 11th Circuit Court of Appeals ruled Friday that the underage victims were entitled to see all 
correspondence between federal prosecutors and Epstein's lawyers regarding a secret 2007 plea deal that 
kept Epstein from federal charges in exchange for an I8-month work-release sentence in state prison. 
The plea negotiations took place as Epstein litigated a series of now settled civil claims surrounding 
allegations that he had sex in his Palm Beach mansion with dozens of underage girls. 
The two victims who are seeking the documents are not identified in court documents. They were 12 and 13 at 
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the time of their liaisons with Epstein, who pleaded guil to two prostitution solicitation charges. The girls 
reached an out-of-court settlement with him. 
In ruling that the correspondence should be public, the appellate court authorized the release of more than 
500 pages of documents. The victims' lawyers would use the documents to prove that, by keeping the 
agreement secret, prosecutors violated a federal act aimed at protecting victims' rights. 
A win in that battle could invalidate Epstein's agreement with federal prosecutors, allowing them to 
reconsider criminal charges, but this time with input from the victims. 
Epstein's lawyers argued that the correspondence constituted confidential plea negotiations and therefore 
should not be shared with the victims' lawyers. 
"Although plea negotiations are vital to the functioning of the criminal justice system, a prosecutor and target 
of a criminal investigation do not enjoy a relationship of confidence and trust when they negotiate," the 
appellate justices wrote, calling the prosecutor-defense attorney relationship adversarial. 
They upheld a 2013 ruling by U.S. District Court Judge Kenneth Marra. He ordered the release of all the plea 
documents, but only federal prosecutors complied. 
The victims' attorneys, Brad Edwards and Paul Cassell, have called the ruling a victory for the rights of victims 
to be heard, even in cases like Epstein's, where federal prosecutors ultimately never filed charges. The victims 
were unaware of the plea agreement until three days before Epstein pleaded to the state charges in June 2008. 
A federal deal had been in place for nine months by then. 
Had prosecutors filed charges and negotiated a plea with Epstein in federal court, they would be barred from 
seeking any additional punishment against him. But because his plea agreement to a sex solicitation charge 
came in state court, federal prosecutors theoretically could charge him again. 
Still, Epstein's lawyers could argue that the only reason he agreed to the state sentence was because he 
believed it would free him of the federal charges for good. Edwards said Epstein's attorneys have made parts 
of those arguments in pre-trial hearings, and he expects them to appeal Friday's ruling. Epstein's Boston-
based attorney, Martin Weinberg. told the Palm Beach Daily News he would appeal. 
"While respectful of the panel's decision, given issues of overriding importance to the criminal justice system 
regarding the need for continued confidentiality for communications between defense lawyers and 
prosecutors, we will be petitioning the court of appeals for further review," Weinberg told the paper. 
Invalidating Epstein's plea would force federal prosecutors to meet with the alleged victims to hear their 
comments on whether to pursue charges against Epstein. They still could decline. 
"You can't force the federal government to prosecute anyone," Edwards said. "But we're hoping that if maybe 
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