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FBI VOL00009

EFTA00230786

1131 sivua
Sivut 381–400 / 1131
Sivu 381 / 1131
06-26-'09 13:39 FROMM & LOCICERO 
T-059 F001/005 F-889 
THOMAS LOCICERO
BRALOW 
400 N. 
DriveeSuite 1100•Tam a FL 33602 
(Phone) 
(Fax) 
Toll Free: 866.395-7100 
L  
facsimile transmittal 
To: 
Marilyn, Judicial Assistant to Judge 
FAX 
561-355-1616 
Colbath 
R. Alexander Acosta, Esq., USAO 
Barbara Burns, Esq., ASAO 
Jack Alan Goldberger, Esq. 
Bradley J. Edwards, Esq. 
William J. Berger, Esq. 
Robert D. Critton, Esq. 
Spencer T. Kuvin, Esq. 
From: 
Deanna K. Shullman, Esq. 
Re: 
State v. J. Epstein 
Date: 
06/04/2009 
Pages: 
5 
urgent K 
For review D 
Please see attached proposed Order. 
Please comment D 
Please reply ta 
Please recycle 0 
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LoCicem B Bralow PL and is confidential or 
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confidential 
EFTA00231166
Sivu 382 / 1131
06-26-'09 13:39 FROM 
& LOCICERO 
T-059 P002/005 F-889 
Tamp
400 N 
Dr., SW. 1100, Tampa, FL 33602 
THOMAS I ()CICERO 
P.O. 
x 
Tampa 
ph, 
fax 
1-2602 
toll 
Ft. Lauderdale 
BRALOW 
101 N.E. INS Ave,, SW. 1500 
oFht..ISSIL 
101111fee 
New York City 
220 E 42nd St.. 10th Flom 
New York. NY 10017 
ee 
tax 
WAN/ slo1eveirm rem 
Dee 
Direct 
Deanna.shu„manottoiawfirm.com
Reply To Tampa 
June 26, 2009 
VIA FASCIMILE 
The Honorable Jeffrey Colbath 
Fifteenth Judicial Circuit-Palm Beach 
Palm Beach County Courthouse 
Main Judicial Complex 
205 N. Dixie Highway, Room 11F 
West Palm Beach, FL 33401 
Re: 
State of Florida v. Jeffrey Epstein 
Dear Judge Colbath: 
This law firm represents the Palm Beach Post in the above matter. I have prepared a 
proposed Order, which I believe accurately reflects your ruling at the hearing on June 26, 2009 
on Defendant Jeffrey Epstein's Motion to Stay Disclosure of the Non-Prosecution Agreement 
and Addendum Pending Review. 
By copy of this letter, I am providing all counsel of record a copy of the proposed Order. 
If the attached Order meets with Your Honor's approval, please enter the same. If you would 
like to have an electronic copy of this proposed order, please have your Judicial Assistant call 
my office to make arrangements for us to send you the order via email. 
Sincerely, 
 
THOMAS, LOCICERO & BRALOW PL 
,atlena.0-0 
K 
Deanna K. Shullman 
EFTA00231167
Sivu 383 / 1131
06-26-'09 13:40 FROM-THOMAS & L0CICER0 
T-059 P003/005 F-889 
Hon. J. Colbath 
06/26/09 
Page 2 of 2 
DKS/kb 
Enclosures 
cc: 
U.S. Attorney's Office (via facsimile) 
State Attorney's Office (via facsimile) 
Jack Alan Goldberger, Esq. (via facsimile) 
Bradley J. Edwards, Esq. (via facsimile) 
Deanna K. Shullman, Esq. (via facsimile) 
Spencer T. Kuvin, Esq. (via facsimile) 
EFTA00231168
Sivu 384 / 1131
06-26-'09 13:41 FROM-THOMAS & L0CICER0 
T-059 P004/005 F-889 
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CRIMINAL DIVISION 
STATE OF FLORIDA 
vs. 
JEFFREY EPSTEIN 
Case Nos.: 2006-CF9454-AXX & 
2008-9381CF-AXX 
ORDER 
This matter came before the Court on Defendant Jeffrey Epstein's Motion to Stay 
Disclosure of the Non-Prosecution Agreement and Addendum Pending Review and upon further 
consideration of this Court's June 26, 2009 Order unsealing certain records in this case. A 
hearing was conducted on these matters on June 26, 2009. 
On June 26, 2009, this Court entered an order unsealing the non-prosecution agreement 
and an addendum on file in this case. Having inspected the documents, this Court finds that they 
do not name any victims and do not contain any material subject to confidentiality pursuant to 
Federal Rule of Criminal Procedure 6. Thus, the Court declines to make any redactions to the 
records before releasing them to the public. 
The Court further finds that Defendant has not demonstrated that a stay pending appeal is 
warranted. Defendant has not shown any irreparable harm or likelihood of success on the merits 
on appeal. These documents were not properly closed in the first instance, no present basis for 
closure exists, and good cause supports disclosure given the public interest in these proceedings 
and the lack of compelling interest in closure. 
Accordingly, it is ordered and adjudged as follows: 
1. 
Effective at noon on July 2, 2009, the non-prosecution agreement (docketed July 
2, 2008) and addendum (docketed August 25, 2008) are unsealed; 
EFTA00231169
Sivu 385 / 1131
06-26-'09 13:42 FROM-THOMAS & L0CICER0 
T-059 P005/005 F-889 
2. 
Defendant's Motion for Stay pending appellate review is DENIED; 
3. 
The Clerk of Court is directed to release the documents to the public at noon on 
Thursday, July 2, 2009. 
Done and ordered this 
day of June, 2009 in Palm Beach County, West Palm 
Beach, Florida. 
Hon. Jeffrey Colbath 
CIRCUIT JUDGE 
cc: 
U.S. Attorney's Office 
State Attorney's Office 
Jack Alan Goldberger, Esq. 
Bradley 1. Edwards, Esq. 
Deanna K. Shullman, Esq. 
Spencer T. Kuvin, Esq. 
2 
EFTA00231170
Sivu 386 / 1131
KnEusixn-WALsit, 
COMPIANI & VARGAS, P.A. 
SUITE 5O3. FLAGLER CENTER 
501 SOUTH FLAGLER DRIVE 
WEST PALM BEACH, FLORIDA 33401-5913 
JANE KREUSLER-WALSH 
BARBARA J. COMPIANI 
REBECCA MERCIER VARGAS 
BOARD CERTIFIED APPELLATE LAWYERS 
By Hand Delivery 
Honorable Jeffrey Colbath 
Palm Beach County Courthouse 
Fifteenth Judicial Circuit 
205 North Dixie Highway, Room 11F 
West Palm Beach, FL 33401 
June 30, 2009 
Re: 
Epstein v. State of Florida 
15th Circuit Court Case No. 2008CF009381A 
Dear Judge Colbath: 
'ELEPHONE 
FACSIMILE 
Enclosed is a copy of Epstein's Emergency Petition for Writ of Certiorari, 
Emergency Motion to Review Denial of Stay, Motion to Use One Appendix and 
Motion to Seal, as filed with the Fourth District Court of Appeal. Due to the 
volume of the appendix, we have only enclosed the table of contents. Please let us 
know if you wish to receive a copy of the appendix. Thank you. 
JKW/bl 
Enclosure 
 seleno. 
Robert D. Critton 
Very truly yours, 
p
1CREUSLER-WALSH 
Jack A. Goldber er 
Judith Stevenson Arco 
William J. Berger 
Deanna K. Shullman 
Spencer T. Kuvin 
EFTA00231171
Sivu 387 / 1131
IN THE DISTRICT COURT OF 
APPEAL OF THE STATE OF 
FLORIDA, FOURTH DISTRICT 
JEFFREY EPSTEIN, 
CASE NO. 
PALM BEACH COUNTY 
Petitioner, 
L.T. CASE NO. 2008 CF 009381A 
v. 
STATE OF FLORIDA, 
Respondent. 
APPENDIX TO 
EMERGENCY PETITION FOR WRIT OF CERTIORARI AND 
EMERGENCY MOTION TO REVIEW DENIAL OF STAY 
ROBERT D. CRITTON 
BURMAN, CRITTON, LUTTIER & COLEMAN 
515 North Flagler Drive, 
West Palm Beach, FL 33401 
and 
JACK A. GOLDBERGER 
ATTERBURY, GOLDBERGER & WEISS, P.A. 
250 Australian Avenue South, Suite 1400 
West Palm Beach, FL 33401 
and 
JANE ICREUSLER-WALSH and 
BARBARA J. COMPIANI of 
KREUSTRB-WAT 
COMPIANI & VARGAS, P.A. 
501 South Flagler Drive, Suite 503 
West Palm Beach, FL 33401-5913 
Counsel for Petitioner 
EFTA00231172
Sivu 388 / 1131
e 
EFTA00231173
Sivu 389 / 1131
Document 
Tab 
Proceedings in Southern District Court 
Victim's (Doe) Petition for Enforcement of Crime Victim's 
Right Act, 18 U.S.C. Section 3771 
Judge Marra's Order to Compel Production and Protective 
Order (8/21/08) 
Victims' (Doe #1 and Doe #2) Motion to Unseal Non-
Prosecution Agreement (9/25/08) 
A-1 
A-2 
A-3 
Respondent's (U.S. Attorney's Office) Opposition to Victims' 
Motion to Unseal Non-Prosecution Agreement (10/8/08) 
A-4 
Victims' (Doe #1 and Doe #2) Reply to Respondent's 
A-5 
Opposition to Victims' Motion to Unseal Non-Prosecution 
Agreement (10/16/08) 
Judge Marra's Order Denying Petitioners' (Doe #1 and Doe #2). 
Motion to Unseal Non-Prosecution Agreement (2/12/08 [sic should 
be 2/12/09]) 
Proceedings in 15th Judicial Circuit 
Transcript of Epstein's Plea Conference (6/30/08) 
Epstein's Plea (6/30/08) 
Agreed Order Sealing Document in Court File (7/2/08) 
NonParty M.'s Motion to Vacate Order Sealing Records 
And Unseal Records (5/12/09) 
A-6 
A-7 
A-8 
A-9 
A-l0 
Palm Beach Post's Motion to Intervene and Petition for 
A-11 
Access (6/1/09) 
Applicant, ■.'s Motion to Intervene and Supporting 
A-12 
Memorandum of Law (6/11/09) 
EFTA00231174
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Document 
Tab 
Epstein's Motion to Make Court Records Confidential (6/11/09) 
A-13 
Epstein's Motion to Stay Disclosure of the Non-Prosecution 
A-14 
Agreement and Addendum Pending Review (6/25/09) 
Intervener's [..] Response to Motion to Stay and Supporting 
Memorandum of Law (6/26/09) 
A-15 
Order of Judge Jeffrey J. Colbath granting motions to unseal (6/25/09) 
A-16 
Order of Judge Jeffrey J. Colbath denying motion to stay (6/26/09) 
A-17 
Transcript on non-parties' motions to unseal and Epstein's 
motion for confidentiality (6/25/09) 
A-18 
Transcript on Epstein's motion to stay (6/26/09) 
A-19 
EFTA00231175
Sivu 391 / 1131
LEGAL 
RECYCLED PAPER 
TO REORDER CALL 954446-9399 
EFTA00231176
Sivu 392 / 1131
Case 9:08-cv-80736-KAM 
Document 1 
Entered on FLSD Docket 07/07/2008 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
08-80736-Civ-MARRA/JOHNSON 
CASE NO.: 
IN RE: JANE DOE, 
Petitioner. 
FI 
cilio 
ELaT 
JULY 7, 2008 
STEVEN IA. LARIUORE 
CLERK M.S. GIST. CS. 
5.0. Or ILA. • MIAMI 
s,., ers end y VICTIM'S PETITION FOR ENFORCEMENT OF 
CRIME VICTIM'S RIGHTS ACT. 18 U.S.0 . SECTION 3771 
COMES NOW the Petitioner, JANE DOE (hereinafter "Petitioner"), by and through her 
undersigned attorneys, pursuant to the Crime Victim's Rights Act, 18 U.S.C. Section 3771 
(''CVR_A"), and files this Petition for Enforcement in the above styled action as follows: 
I. 
Petitioner, an adult, as a minor child was a victim of federal crimes committed by 
JEFFREY EPSTEIN (hereinafter "Defendant"). 
These crimes included sex trafficking of 
children by fraud, in violation of 18 U.S.C. § 1591, use of a means of interstate commerce to 
entice a minor to commit prostitution, in violation of 18 U.S.C. § 2422, as well as wire fraud, in 
violation of 18 U.S.C. § 1343. The Defendant committed these crimes within the jurisdiction of 
the Southern District of Florida in Palm Beach County, Florida. 
2. 
Upon information and belief, the Defendant is the subject of a federal criminal 
investigation conducted by the United States of America in the Southern District of Florida. The 
Defendant has recently been prosecuted and pleaded guilty, on June 30, 2008, in the Circuit 
Court for Palm Beach County to various similar slate offenses including solicitation of minors 
for prostitution. 
3. 
Upon information  and beliefs the Defendant is engaged in plea negotiations-with 
the Office of the United States Attorney for the Southern District of Florida concerning federal 
0110 
EFTA00231177
Sivu 393 / 1131
Case 9:08-cv-80736-KAM 
Document 1 
Entered on FLSD Docket 07/07/2008 
Page 2 of 10 
crimes which he is alleged to have committed against minor children, including the Petitioner. 
Such negotiations may likely result in a disposition of the charges in the next several days. 
4. 
Under the CVRA, before any charges are filed against the Defendant, the 
Petitioner has the rights (among others) to notice of her rights under the CVRA, to confer with 
the prosecutors, and to be treated with fairness. As soon as charges are filed, the Petitioner has 
the rights (among others) to timely notice of court proceedings, the right not to be excluded from 
such proceedings, the right to be heard at such public proceedings regarding conditions of 
release, any plea, and any sentence, the right to confer with the attorney for the government, the 
right to restitution, and the right to be treated with fairness and with respect for her dignity and 
privacy. 
5. 
The Petitioner has been denied her rights in that she has received no consultation 
with the attorney for the government regarding the possible disposition of the charges, no notice 
of any public court proceedings, no information regarding her right to restitution, and no notice 
of rights under the CVRA, as required under law. 
6. 
The Petitioner is in jeopardy of losing her rights, as described above, if the 
government is able to negotiate a plea or agreement with the Defendant without her participation 
and knowledge. 
WHEREFORE, for the reasons outlined above, the Petitioner respectfully requests this 
Court to grant her Petition, and to order the United States Attorney to comply with the provisions 
of the CVRA prior to and including any plea or other agreement with the Defendant and any 
attendant proceedings. 
2 
2.110 
EFTA00231178
Sivu 394 / 1131
Case 9:08-cv-80736-KAM 
Document 1 
Entered on FLSD Docket 07107/2008 
Page 3 of 10 
MEMORANDUM 
I. 
THE CRIME VICTIMS' RIGHTS ACT MAKES CRIME VICTIMS 
INDEPENDENT 
PARTICIPANTS 
THROUGHOUT 
THE 
CRIMINAL JUSTICE PROCESS. 
In October 2004, Congress passed and the President signed into law the Crime Victims' 
Rights Act, Pub. L. No. 108-405, 118 Stat. 2251 (codified at 18 U.S.C. § 3771). Because this 
appears to be the first case involving the Act to come before this Court, a bit of background may 
be in order. 
A. 
The CVRA Gives Crime Victims Rights to Participate in the Criminal Justice 
Process. 
Congress passed the CVRA "to give crime victims enforceable rights to participate in 
federal criminal proceedings." Opinion at 14. Congress was concerned that in the federal system 
crime victims were "treated as non-participants in a critical event in their lives. They were kept 
in the dark by prosecutors too busy to care enough ... and by a court system that simply did not 
have a place for them." 150 CONG. REC. S4262 (Apr. 22, 2004) (statement of Sen. Feinstein). 
To remedy this problem, Congress gave victims "the simple right to know what is going on, to 
participate in the process where the information that victims and their families can provide may 
be material and relevant ... ." Id. 
The CVRA gives victims of federal crimes a series of rights, including the right to notice 
of court proceedings, to be heard at plea and sentencing hearings, and to reasonably "confer with 
the attorney for the Government in the case." 18 U.S.C. § 3771(a). Victims also have a "right 
of access to the terms of a plea agreement ... ." In re Interested Parry 1, 530 F.Supp. 2d 136, 
2008 WL 134233 at •7 (D.D.C. 2008). The CVRA also assures victims broadly that they will 
"be treated with fairness." 18 U.S.C. § 377I(a)(8). 
3 
1010 
EFTA00231179
Sivu 395 / 1131
Case 9:08-cv-80736-KAM 
Document 1 
Entered on FLSD Docket 07/07/2008 
Page 4 of 10 
*a/ 
Of course, these rights would be of little use to most crime victims unless they were told 
about them. To ensure that victims are notified of their rights, the CVRA directs employees of 
the Justice Department "and other departments and agencies of the United States engaged in the 
detection, investigation, or prosecution of crime" to use their "best efforts to see that crime 
victims are notified of 
the rights described (in the CVRA]." 18 U.S.C. § 3771(c)(1) (emphasis 
added).1 
B. 
The CVRA Gives Victims Rights During the Investigation of a Crime. 
The CVRA gives victims rights during the investigation of a crime. The Fifth Circuit 
recently reached this conclusion, holding: 
The district court acknowledged that "(t]here are clearly rights 
under the CVRA that apply before any prosecution is underway." 
BP Prods., 2008 WL 501321 at '11, 200811.S. Dist. LEXIS 12893, 
at *36. Logically, this includes the CVRA's establishment of 
victims' "reasonable right to confer with the attorney for the 
Government." 18 U.S.C. & 3771(a)(5). At least in the posture of 
this case (and we do not speculate on the applicability to other 
situations), the government should have fashioned a reasonable 
way to inform the victims of the likelihood of criminal charges and 
to ascertain the victims' views on the possible details of a plea 
bargain. 
ha re Dean, 527 F.3d 391, 394 (5th Cir. 2008). 
The position that CVRA rights apply before charges have been filed is consistent with the 
Justice Department regulations under the CVRA, which explain that government officials "must 
advise a victim (about their rights under the CVRA) ... at the earliest opportunity at which it may 
be done without interfering with an investigation." A.G. GUIDELINES FOR VICTIM AND WrThrESS 
I Further supporting this requirement is another statute, 42 U.S.C. § I0607(c)(3), which directs government officials 
to provide victims with "the earliest possible notice of," among other things, "the filing of charges against a 
suspected offender." 
4 
loll@ 
EFTA00231180
Sivu 396 / 1131
Case 9:08-cv-80736-KAM 
Document 1 
Entered on FLSD Docket 07/07/2008 
Page 5 of 10 
yostr 
Nvor 
ASSISTANCE 23 (May 2005). And the plain language of the CVRA undergirds this conclusion, as 
it applies not simply to prosecutors but to government agencies "engaged in the detection [and) 
investigation ... of crime ... ." 18 U.S.C. § 3771(c)(1). Indeed, if there were any doubt, the plain 
language of the CVRA extends victims' right to situations "in which no prosecution is 
underway." 18 U.S.C. § 3771(dX3). 
H. 
PETITIONER IS A "VICTIM PROTECTED BY THE CVRA. 
Under the CVRA the crime victim is defined as "a person directly and proximately 
harmed as a result of the commission of a Federal offense ... ." 18 U.S.C. Section 3771(e). In 
particular, Defendant called Petitioner when she was a minor over a telephone (a means of 
interstate communication) requesting that she perform a massage in exchange for payment. As 
Defendant well knew, that request was fraudulent, as he not only intended to receive a massage, 
but also intended to have her perform sexual acts in exchange for a cash payment to Petitioner. 
Only when Petitioner arrived at a Defendant's mansion as directed by Defendant, did Defendant 
reveal his true purpose of obtaining sexual favors in exchange for payment This conduct 
violated 18 U.S.C. § 2422, which forbids using a means of interstate commerce to knowingly 
"induce" or "entice" a minor "to engage in prostitution." In addition, this conduct was both a use 
of "fraud" to obtain a commercial sex act, in violation of 18 U.S.0 § 1591, and use of wire 
communications to perpetrate a "scheme and artifice to defraud," in violation of 18 U.S.C. § 
1343. 
It appears obvious that Petitioner was "directly and proximately" harmed by these crimes, 
thereby making her a victim under the CVRA. It should be emphasized that_the CVRA "was 
designed to be a 'broad and encompassing' statutory victims' bill of rights." United States' 
5 
lot 00 
EFTA00231181
Sivu 397 / 1131
Case 9:08-cv-80736-KAM 
Document 1 
Entered on FLSD Docket 07/07/2008 
Page 6 of 10 
v 
Degenhardt, 405 F.Supp.2d 1341, 1342 (D. Utah 2005) (quoting 150 Cong. Rec. S4261 (daily 
ed. Apr. 22, 2004) (statement of Sen. Feinstein)). Congress intended the CVRA to dramatically 
rework the federal criminal justice system. In the course of construing the CVRA generously, the 
Ninth Circuit observed: "The criminal justice system has long flinctioned on the assumption that 
crime victims should behave like good Victorian children — seen but not heard. The Crime 
Victims' Rights Act sought to change this by making victims independent participants in the 
criminal justice process." Kenna v. U.S. Dist. Court for C.D. Cat, 435 F.3d 1011, 1013 (9th Cir. 
2006). Accordingly, because the CVRA is remedial legislation, courts should interpret it 
"liberally to facilitate and accomplish its purposes and intent." 
Elliott Industries Ltd. 
Partnership v. BP America Production Co., 407 F.3d 1091, 1118 (10th Cir. 2005) (noting 
remedial legislation should be "interpreted liberally to facilitate and accomplish its purposes and 
intent"). The CVRA itself suggests this conclusion by requiring that courts must treat crime 
victims with "fairness." United States v. Patkar, 2008 WL 233062 at •3 (D. Haw. 2008) (citing 
United States v. Turner, 367 F.Supp.2d 319, 335 (ED.N.Y. 2005)). 
Not only must the CVRA as a whole be interpreted liberally, but its definition of "crime 
victim" requires a generous construction. After reciting the direct-and-proximate-harm language 
at issue here, one of the Act's two co-sponsors -- Senator Kyl -- explained that "Mills is an 
intentionally broad definition because all victims of crime deserve to have their rights protected 
." 150 Cong. Rec. S10912 (Oct. 9, 2004) (emphasis added). The description of the victim 
definition as "intentionally broad" was in the course of floor colloquy with the other primary 
sponsor of the CVRA and therefore deserves significant weight. See Kenna, 435 F.3d at 1015T6 
(discussing significance of CVRA sponsors.. floor statements). 
6 
EFTA00231182
Sivu 398 / 1131
Case 9:08-cv-80736-KAM 
Document 1 
Entered on FLSD Docket 07/07/2008 
Page 7 of 10 
4.•• 
The definition of "crime victims" must thus be construed broadly in favor of Petitioner. 
She obviously qualifies as a "victim" under the CVRA. 
III. 
PETITIONER IS ENTITLED TO NOTICE OF HER RIGHTS, AN 
OPPORTUNITY TO CONFER WITH THE PROSECUTORS AND 
TO BE TREATED WITH FAIRNESS. 
Because Petitioner is a "victim" under the CVRA, she has certain protected rights under 
the Act. Most important, the Act promises that she will have an opportunity to "confer with the 
attorney for the Government in the case." To date, Petitioner has not been given that right. This 
raises that very real possibility that the Government may negotiate and conclude a plea agreement 
with the Defendant without giving Petitioner her protected rights.2 
Petitioner is entitled to have this conference with prosecutors before any final plea 
agreement is reached. The Fifth Circuit reached exactly this conclusion in a very recent case. In 
In re Dean, 527 F.3d 391 (5th Cir. 2008), the Government negotiated a plea agreement with the 
well-heeled corporate defendant without conferring with the victims. When the Government's 
failure was challenged in the Fifth Circuit, the Fifth Circuit concluded that the Government had 
indeed violated the CVRA. The Fifth Circuit observed: "in passing the [CVRAJ, Congress 
made the policy decision-which we are bound to enforce-that the victims have a right to inform 
the plea negotiation process by conferring with prosecutors before a plea agreement is reached." 
Id. at 394. 
This Court is obligated to protect the lights of Petitioner. The CVRA directs that "[i]n 
any court proceeding involving an offense against a crime victim, the court shall ensure that the 
2 On information and belief, roughly the same crimes werc committed against several other young females. These 
victims, too, arc in danger of losing their right to confer under the CVRA. 
7 
7 of 10 
EFTA00231183
Sivu 399 / 1131
Case 9:08-cv-80736-KAM 
Document 1 
Entered on FLSD Docket 07/07/2008 
Page 8 of 10 
crime victim is afforded the rights described in [the CVRA)." 18 U.S.C. § 3771(bX1). The 
CVRA also confers on crime victims the right to "assert the rights described in [the CVRA]." 18 
U.S.C. § 3771(d)(I). Therefore, this Court has its own independent obligation to intercede and 
ensure that the Government respects the rights of Petitioner under the CVRA. 
CONCLUSION 
The Petitioner requests the intervention of this Court to ensure that her rights are 
respected and accorded, as promised in the Crime Victims' Rights Act. 
DATED this 7th day oil& 2008. 
Respectfully Submitted, 
THE LAW OFFICE OF BRAD EDWARDS & 
ASSOCIATES, LLC 
Brad Edwards, Esquire 
Attorney for Petitioner 
Florida Bar #542075 
2028 Harrison Street 
Suite 202 
Hollywood, Florida 33020 
Telephone: 
Facsimile: 
8 
emu, 
EFTA00231184
Sivu 400 / 1131
Case 9:08-cv-80736-KAM 
Document 1 
Entered on FLSD Docket 07/07/2008 
Page 9 of 10 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been 
provided by United States mail and via facsimile to: 
United States Attorney's Office, 500 South Australian Avenue, 
Florida 33401, this ah day of July, 2008. 
c410 
, AUSA, 
West Palm Beach, 
Brad Edwards, Esquire 
Attorney for Petitioner 
Florida Bar No. 542075 
9 
EFTA00231185
Sivut 381–400 / 1131