EFTA00231917

Case 9:08-cv-80736-KAM 
Document 28 
Entered on FLSD Docket 09/25/2008 
Page 7 of 8 
G. Cassell 
Attorney for Petitioners 
Pro Hac Vice 
332 S. 1400 E. 
Salt Lake City, UT 84112 
Telephone: 
Facsimile: 
E-Mail: 
Jay C. Howell, Esquire 
Attorney for Petitioners 
Pro Hac Vice 
644 Cesery Boulevard 
Suite 250 
Jacksonville, Florida 32211 
Telephone: 
Facsimile: 
E-Mail: 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on September 25, 2008, I electronically filed the foregoing 
document with the Clerk of the Court using CM/ECF. 
SERVICE LIST 
Jane Doe I and Jane Doe 2 
Case No.: 08-80736-CV-MARRA/JOHNSON 
United States District Court, Southern District of Florida 
sststant U.S. Attorney 
99 N.E. 4th Street 
Miami, Florida 33132 
Telephone: 
Facsimile: 
EFTA00232317

Case 9:08-cv-80736-KAM 
Document 28 
Entered on FLSD Docket 09/25/2008 
Page 8 of 8 
AUSA 
United States Attorney's Office 
500 South Australian Avenue 
Suite 400 
West Palm Beach, Florida 33401 
s/ Brad Edwards 
Brad Edwards, Esquire 
Attorney for Petitioner 
Florida Bar No. 
I HEREBY FURTHER CERTIFY that on September 25, 2008, a true and correct copy of 
the above and foregoing document is being provided by United States mail to: 
Jack Alan Goldberger, Esquire 
Atterburty, Goldberger & Weiss, P.A. 
250 Australian Avenue South 
Suite 1400 
Milorida 
33401 
Michael R. Tein, Esquire 
Lewis Tein, P.L. 
3059 Grand Avenue 
Suite 340 
Coconut Grove Florida 33133 
Robert D. Critton, Jr., Esquire 
Michael J. Pike, Esquire 
Burman, Critton, Luttier & Coleman, LLP 
515 North Flagler Drive 
Suite 400 
West Palm Beac Florida 33401 
s/ Brad Edwards 
Brad Edwards, Esquire 
Attorney for Petitioner 
Florida Bar No. 
8 
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Case 9:08-cv-80736-KAM 
Document 28-2 
Entered on FLSD Docket 09/25/2008 
Page 1 of 1 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-80736-CIV-MARRA/JOHNSON 
JANE DOE #1 AND JANE DOE #2, 
Petitioners, 
v. 
UNITED STATES OF AMERICA, 
Respondent. 
ORDER TO UNSEAL NON-PROSECUTION AGREEMENT 
THIS CAUSE comes before the Court on the Petitioners' Motion to Unseal Non-
Prosecution Agreement between the United States Attorneys Office for the Southern District of 
Florida and Jeffity Epstein. After consideration of the Motion and the record, it is 
ORDERED AND ADJUDGED that the Petitioners' Motion is GRANTED and the Non-
Prosecution Agreement between the United States Attorneys Office for the Southern District of 
Florida and Jeffrey Epstein is hereby ordered to be unsealed. 
DONE AND ORDERED in Chambers, in West Palm Beach, Palm Beach County, 
Florida, this 
day of 
, 2008. 
KENNETH A. MARRA 
UNITED STATES DISTRICT COURT 
Copies furnished to: all counsel of record 
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EFTA00232320

Case 9:08-cv-80736-KAM 
Document 29 
Entered on FLSD Docket 10/08/2008 
Page 1 of 7 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 08-80736-Civ-Marra/Johnson 
JANE DOES #1 and #2 
Petitioners, 
v. 
UNITED STATES OF AMERICA, 
Respondent. 
RESPONDENT'S OPPOSITION TO VICTIMS' MOTION 
TO UNSEAL NON-PROSECUTION AGREEMENT 
Respondent, by and through its undersigned counsel, files its Opposition to 
Victims' Motion to Unseal Non-Prosecution Agreement, and states: 
L 
THE MOTION TO UNSEAL SHOULD BE DENIED 
BECAUSE THE NON-PROSECUTION AGREEMENT HAS 
NEVER BEEN FILED UNDER SEAL IN THIS COURT. 
Petitioners have filed their motion to unseal the non-prosecution agreement, 
claiming that no good cause exists for sealing it. As an initial matter, the motion should 
be denied because the non-prosecution agreement entered into between the United States 
Attorney's Office and Jeffrey Epstein was never filed in the instant case by the United 
States, either wider seal or otherwise, On August 14, 2008, this Court ?mid a telephonic 
hearing to discuss petitioners' request for a copy of the non-prosecution agreement. The 
United States advised the Court that the Agreement had a confidentiality provision, 
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Case 9:08-cv-80736-KAM 
Document 29 
Entered on FLSD Docket 10/08/2008 
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which the United States was obligated to honor. The United States requested that, if the 
Agreement was to be produced to petitioners, it should be done pursuant to a protective 
order, to ensure that further dissemination of the Agreement would not occur. At that 
time, petitioners had no objection to such a procedure. 
On August 21, 2008, this Court entered its Order to Compel Production and 
Protective Order (DE 26). Subpart (b) of the Order provides that, "Petitioners and their 
attorneys shall not disclose the Agreement or its terms to any third party absent further 
court order, following notice to and an opportunity for Epstein's counsel to be heard." 
(DE 26 at 1.) Presumably, petitioners' motion to unseal is an effort to modify the terms 
of the Protective Order, to enable them to disclose the Agreement to third parties. 
Since the Agreement has not been filed under seal with this Court, the legal 
authority cited by petitioners regarding sealing of documents, United States v. Ochoa-
Vasaue, 428 F.3d 1015 (11th Cir. 2005), is inapposite. The parties who negotiated the 
Agreement, the United States Attorney's Office and Jeffrey Epstein, determined that the 
Agreement should remain confidential. They were free to do so, and violated no law in 
making such an agreement. Since the Agreement has become relevant to the instant 
lawsuit, petitioners have been given access to it, upon the condition that it not be 
disclosed further.' Petitioners have no legal right to disclose the Agreement to third 
parties, or standing to challenge the confidentiality provision. 
Lit is unclear whether the Petitioners themselves (as opposed to their attorneys) have 
actually reviewed the Non-Prosecution Agreement. The Court's Order to Compel Production 
required petitioners' counsel to review and agree to the Protective Order and to do the same with 
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In order to have standing, petitioners must show: (1) an injury in fact, meaning an 
injury that is concrete and particularized, and actual or imminent; (2) a causal connection 
between the injury and the causal conduct; and (3) a likelihood that the injury will be 
redressed by a favorable decision. Granite State Outdoor Advertising, Inc. v. City of 
Clearwater, Fla., 351 F.3d 1112, 1116 (11th Cir. 2003). Petitioners already have obtained 
access to the agreement, so they cannot claim a denial of access as an injury in fact. 
Their motion to unseal refers to their stated desire to confer with other victims of Epstein 
and their attorneys "to determine whether they were likewise provided with inaccurate 
information about the nature of the plea agreement." (DE 28 at 5.) 
This asserted reason for needing to unseal the Agreement is baseless given that the 
Protective Order, at the Court's direction, specifically provides for a very simple 
procedure to allow other victims and their lawyers to see the Agreement. ( 
DE 26 at 
1-2, subpart (d).) All that is required is for any victims and/or their attorneys to review 
and agree to the terms of the Protective Order, and to provide the signed acknowledgment 
of that agreement to the United States. 
Petitioners' claim that they wish to discuss with others the "possible legal 
responses" to the Government, including the National Alliance of Victims' Rights 
Attorneys, also provides no basis for vacatur of the Protective Order. Petitioners contend 
that the "sealing order would apparently block these forms of consultation . . ." (DE 28 at 
their clients. Copies of those signed acknowledgements to abide by the Protective Order were 
then to be provided "promptly" to the United States. To date, only Attorney Brad Edwards has 
provided a signed acknowledgement. 
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5.) First, there is no sealing order. Second, the Protective Order does not prevent 
petitioners from consulting with anyone; it only prevents them from disclosing the 
Agreement. Petitioners fail to mention why it is necessary for the National Alliance of 
Victims' Rights Attorneys to have the Agreement in hand, in order to meaningfully 
consult with them. 
Petitioners also assert that they would like to be able to reference the Agreement 
"in a parallel civil suit that is pending before this Court." (DE 28 at 5.) Given that the 
suit names Jeffrey Epstein as a defendant and is pending before the same district judge, it 
seems that litigation regarding the production and use of the Agreement should occur in 
that case, where the true party in interest, Jeffrey Epstein, is present and represented by 
counsel, rather than in a suit that was originally filed in July as an "Emergency Petition" 
under the various victims' rights laws. 
H. 
THE GOVERNMENT ACCURATELY DESCRIBED THE 
PROVISIONS OF THE AGREEMENT, • 
THE TIME THE 
RESPONSES WERE FILED WITH THE COURT. 
Petitioners castigate the Government for inaccurately describing the non-
prosecution agreement. (DE 28 at 2-5.) They contend a particular provision cited by the 
Government does not appear in the copy of the Agreement produced to them. 
During the telephonic hearing on August 14, 2008, Government counsel advised 
the Court and petitioners' counsel that there was an ongoing dispute between the 
—Government-and Epstein alai neys-overwhat constituted the Agreement. Government 
counsel advised that, in its opinion, the Agreement had three parts. The first part was 
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executed in September 2007, the second part, an addendum, was executed in October 
2007, and the third part was a December 2007 letter from the United States Attorney to 
Epstein's attorneys, suggesting a further modification of the Agreement. The 
Government advised the Court that it believed that all three parts comprised the 
Agreement, while it appeared that Epstein's attorneys were contending the Agreement 
was comprised only of parts one and two. 
At the commencement of the instant litigation, in July 2008, the Government 
believed the Agreement was comprised of all three parts mentioned above. This belief 
was expressed in victim notification letters, including one sent to Jane Doe # 1 ,2 the 
Government's July 9, 2008 response to the Emergency Petition for Enforcement of 
Victims Rights Act, as well as the Declaration of A. 
Villafaila, Assistant U.S. 
Attorney, which accompanied the Government's response. This belief continued until 
August 2008, when the Government advised Epstein's attorneys that the victims had 
2The victim notification letter was provided to Epstein's attorneys prior to being sent, 
who approved the language of which the petitioners now complain. Thus, petitioners' repeated 
assertions that the Government made these errors intentionally and/or negligently are meatless. 
(See. e.g., DE 28 at 4-5 ("The Government apparently feels free to disclose to the victims one 
provision in the non-prosecution agreement that it believes it is to its advantage to disclose, but 
not others. The Government should not be permitted to pick and choose, particularly where it 
has inaccurately described the provision that it has chosen to disclose.") The Government seeks 
no "advantage" in this suit brought by the two victims. Furthermore, the petitioners' original 
emergency petition focused on their concern about the amount of jail time that Epstein would 
serve. The provision that they complain of now has no relation to jail time. Furthermore, 
petitioners aver that the October 2007 disclosure to Jane Doe #1 contained inaccurate 
information, but that disclosure was made before the December 2007 letter and, therefore, did 
not include anything related to the U.S. Attorney's now-defunct proposed amendment to the 
Agreement. 
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Document 29 
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Page 6 of 7 
demanded disclosure of the Agreement to them, and discussions ensued about what 
constituted the Agreement. Epstein's attorneys then told the Government that Epstein 
believed the Agreement consisted only of the first and second parts. These were the parts 
disclosed to petitioners pursuant to the Protective Order in compliance with the Court's 
order to compel production. The fact that an erroneous disclosure was inadvertently 
made to one petitioner after Epstein had already entered his guilty plea, was sentenced, 
and surrendered to begin serving his sentence does not create an injury where one did not 
exist before. 
CONCLUSION 
For the foregoing reasons, the United States respectfully requests that the Court 
deny Petitioners' Motion to Unseal the Non-Prosecution Agreement. 
Respectfully submitted, 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
By: 
s/ 
A 
A. 
Assistant U.S. Attorne 
Fla. Bar No 
99 N.E. 4th Street 
Miami. Florida 33132 
6 
Fax: 
E-mail: 
j usdoj.gov 
Attorney for Respondent 
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Case 9:08-cv-80736-KAM 
Document 30 
Entered on FLSD Docket 10/16/2008 
Page 1 of 6 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-80736-CIV-MARRA/JORNSON 
JANE DOE #1 AND JANE DOE #2, 
Petitioners, 
v. 
UNITED STATES OF AMERICA, 
Respondent. 
VICTIMS' REPLY TO RESPONDENT'S OPPOSITION TO 
VICTIMS' MOTION TO UNSEAL IWN-PROSECUTION AGREEMENT 
COME NOW the Petitioners, Jane Doe #1 and Jane Doe #2 ("the victims'), by and 
through undersigned counsel, and reply to the Government's Opposition to Victims' Motion to 
Unseal Non-Prosecution Agreement. 
The victims have moved for a lifting of the protective order barring them from publicly 
disclosing or discussing the terms of the non-prosecution agreement between Jeffrey Epstein and 
the United States Government. Jeffrey Epstein has made no response to this motion. The 
Government, however, contends that the victims' motion should be denied because the victims 
cannot show any injury from the protective order. The Government's position is wrong for three 
reasons. First, the Government bears the burden of showing some good cause for a protective 
order. It has utterly failed to even offer any such cause — much less show that it is good cause. 
Second, the Government — with the apparent contrivance of Jeffrey Epstein's attorneys — has 
 
made inacrurare represenrationv nhout the nature of the non-prosecution agreementirrits-notices 
to the victims and in its filing before the Court. To set the record straight, therefore, the victims 
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Case 9:08-cv-80736-KAM 
Document 30 
Entered on FLSD Docket 10/16/2008 
Page 2 of 6 
should be allowed to publicly discuss the agreement. Finally, the victims are burdened by 
provisions in the protective order. For all these reasons, the protective order should be lifted. 
I. 
No Good Cause Has been Shown for Sestina the Aereemeet 
In their motion to unseal the agreement, the victims argued that there was no good reason 
for the protective order requiring them not to fluffier disseminate the agreement. Curiously, the 
Government's response does not offer any substantive reason for the agreement to remain under 
seal or under a protective order.' Instead, the Government contends that victims have "no legal 
right to disclose the Agreement to third parties, or standing to challenge the confidentiality 
provision." Gov't Response at 2. But this argument has things backwards. It is not the victims' 
task to show some reason for not entering a protective order, rather, it is the Government's task 
to show some affirmative reason for entering the order in the first place. See Fed. R. Civ. P. 
26(c) (allowing for entry of a protective order upon motion for a party "for good cause shown"); 
see also In re Alexander Grant & Co. Litigation, 820 F.2d 352, 356 (11th Cir. 1987) ("good 
cause" for a protective order "generally signifies a sound basis or legitimate need to take judicial 
action"). Having been given the opportunity to explain why the document has to remain 
confidential, the Government chose not to do so. And Jeffrey Epstein was served with the 
victims' motion, but chose not to respond. Presumably this was because Jeffrey Epstein had no 
real interest at stake in the confidentiality of the agreement. Therefore, the protective order 
should be lifted because it lacks any articulated justification — much less any justification that 
constitutes good cause. 
' The Government prefers to view the Issues in this case es involving not the sealing of a document but rather the 
entry of a protective order preventing the disclosure of a document. To simplify the dispute in this case, we will 
proceed on the Government's view of the situation. 
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Document 30 
Entered on FLSD Docket 10/16/2008 
Page 3 of 6 
2. 
The Government. With the Apparent Aid of Epstein, Has Provided Inaccurate 
Information to the Victims (and to the Court). 
The victims also asked that the protective order be lifted to help clarify the record in this 
case. The Government has made public representations in its pleadings in this case about the 
civil remedy provision in the non-prosecution agreement. It also specifically sent notices to Jane 
Doe #1 and other victims of Jeffrey Epstein's crimes describing this provision in the agreement. 
Those representations were inaccurate — as the Government now seemingly admits. See Gov't 
Response at 6 (referring to "erroneous disclosure" that was "inadvertently made" to Jane Doe 
#1). Indeed, the Government now takes the position that the responsibility for those inaccurate 
representations to the victim — as well as to the Court — lies with Jeffrey Epstein's attorneys'. 
See Gov't Response at 5 ("the [inaccurate] victim notification letter was provided to Epstein's 
attorneys prior to being sent, who approved the language of' which the petitioners now 
complain."). 
The apparent approval by Jeffrey Epstein's attorneys of inaccurate information being sent 
to crime victims (and possibly their approval of inaccurate information being provided, as a 
result, to the Court) raises very significant issues under the Crime Victim's Rights Act. The 
victims have, therefore, sent a letter to the U.S. Attorney's Office requesting clarification of 
exactly how Jeffrey Epstein's attorneys participated in misleading the victims. See Attachment 1 
(Oct. 9, 2008, Letter from Brad Edwards, Esq. to AUSA 
D. Indeed, it appears that the 
Government may have provided an inaccurate description of another feature of the non-
prosecution agreement to the victims. See Attachment 2 (Oct. 15, 2008 Letter from Brad 
Edwards, Esq. to AUSA 
(noting-Government's representation-to victims of a right to 
recover at least $150,000 in damages from Jeffrey Epstein while Jeffrey Epstein's lawyers take 
the position that the agreement allows automatic recovery of only $50,000). In light of all these 
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apparent misrepresentations about precisely what the non-prosecution agreement entails, the 
victims should not be bound by a protective order barring their public disclosure of the 
agreement. 
3. 
The Protective Order Unfairlv Burdens the Victims. 
In their motion, the victims also explained how the protective order burdened their efforts 
to confer with other victims' tights attorneys regarding how best to proceed in light of the non-
prosecution agreement. The Government does not seriously contest the victims' representations 
about the burdens imposed by the protective order. Instead, it takes the truly remarkable position 
that "the Protective Order does not prevent [the victims) from consulting with anyone; it only 
prevents them from disclosing the Agreement." Gov't Response at 4. But the whole point of the 
victims' motion was that the protective order places burdens on the victims in consulting with 
other attorneys about the agreement. Obviously, it is of no help to the victims to be able to 
consult with other attorneys on that issue if the agreement itself cannot be disclosed. 
CONCLUSION 
The provision in the protective order barring the victims and their attorneys from publicly 
disclosing the non-prosecution agreement should be lifted. 
DATED this ligi day of October 2008. 
Respectfully Submitted, 
THE LAW OFFICE OF BRAD EDWARDS & 
ASSOCIATES, LLC 
By: 
s/ Brad Edwards 
Brad Edwards, Esquire 
Attorney for Petitioners 
Florida Bar 
2028 Harrison Street - Suite 202 
Hollywood, 
Telephone: 
E-Mail: 
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Document 30 
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Page 5 of 6 
Paul G. Cassell 
Attorney for Petitioners 
Pro Hac Vice 
332 S. 1400 E. 
Salt Lake City 
4 
Telephone: 
Facsimile: 
E-Mail: 
Jay C. Howell, Esquire 
Attorney for Petitioners 
Pro Hac Vice 
644 Cesery Boulevard - Suite 250 
Jacksonville, F 
Telephone: 
Facsimile: 
E-Mail: 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on October 16. 2008, I electronically filed the foregoing 
document with the Clerk of the Court using CMJECF. 
SERVICE LIST 
Jane Doe 1 and Jane Doe 2 
Case No.: 08-80736-CIV-MARRA/JOHNSON 
United States District Court, Southern District of Florida 
Assistant U.S. Attorney 
99 N.E. 4th Street 
Miami, Flori 
Telephone: 
Facsimile: 
AUSA 
United States Attorney's Office 
500 South Australian Avenue 
Suite 400 
West Palm Beach, Florida 33401 
s/ Brad Edwards 
Brad Edwards, Esquire 
Attorney for Petitioner 
Florida Bar No. 
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Case 9:08-cv-80736-KAM 
Document 30 
Entered on FLSD Docket 10/16/2008 
Page 6 of 6 
I HEREBY FURTHER CERTIFY that on October 16. 2008, a true and correct copy of 
the above and foregoing document is being provided by United States mall to: 
Jack Alan Goldberger, Esquire 
Atterburty, Goldberger & Weiss, PA. 
250 Australian Avenue South 
Suite 1400 
h Florida 33401 
Michael FL Tein, Esquire 
Lewis Tein, P.L. 
3059 Grand Avenue 
Suite 340 
nda 33133 
Robert D. Critton, Jr., Esquire 
Michael J. Pike, Esquire 
Burman, Critton, Luttier & Coleman, LLP 
515 North Flagler Drive 
Suite 400 
West Pa m B a h Florida 33401 
s/ Brad Edwards 
Brad Edwards, Esquire 
Attorney for Petitioner 
Florida Bar No. 
. 
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Case 9:08-cv-80736-KAM 
Document 36 
Entered on FLSD DocKet 02/12/2009 
Page 1 of 2 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
NO. 08-80736-CIV-MARRA/JOHNSON 
JANE DOES #1 AND #2, 
Petitioners, 
v. 
UNITED STATES OF AMERICA, 
Respondent. 
ORDER 
THIS CAUSE comes before the Court on the Petitioners' Motion to Unseal Non-Prosecution 
Agreement (DE 28), filed September 25, 2008. Respondent filed its response (DE 29), on October 
8, 2008, and Petitioners filed their reply (DE 30) on October 16, 2008. The Court has carefully 
considered the motion and the record and is otherwise fully advised in the premises. 
Petitioners motion seeks the Court to enter an order unsealing the Non-prosecution 
Agreement, including any modifications and addenda thereto (collectively referred to as the 
"Agreement"), between the United States Attorney's Office for the Southern District of Florida 
("USAO") and Jeffrey Epstein ("Epstein"). At a hearing held on August 14, 2008, the Court ordered 
the USAO to produce the Agreement to counsel for the Petitioners and to any other victims 
identified by the USAO and their counsel, pursuant to the terms of the Court's Order. (See DE 26, 
August 21, 2008). Petitioners argue that the Agreement "should now be unsealed." 
 
First, as Respondent points-cut -the Agrcc,4„gut Vectb 
-filed-in this case, under seal or 
otherwise. Petitioners also assert that the Agreement should be "unsealed" because the victims 
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and/or their attorneys believe the Government has mischaracterized some of its provisions. If and 
when such alleged mischaracterizations become relovtuit to an issue to be decided by the Court, the 
parties will be given the opportunity to advance their positions and the Court will resolve the issue. 
If disclosure of the Agreement will be required for the Court to resolve the issue, appropriate 
disclosure will be ordered. 
Furthermore, to the extent Petitioners are seeking modification of the restrictions placed 
upon their use of the Agreement by the Court's August 21,2008 order, Petitioners have not met their 
burden to justify a modification. Petitioners' mere desire to discuss the Agreement with third parties 
is insufficient, in and of itself, to warrant the granting of such relief. If and when Petitioners have 
a specific tangible need to be relieved of the restrictions, they should file an appropriate motion. If 
a specific tangible need arises in a civil case Petitioners or other alleged victims are pursuing against 
Epstein, relief should be sought in that case, with notice to the United States, the other party to the 
Agreement. Accordingly, it is 
ORDERED AND ADJUDGED that Petitioners' Motion to Unseal Non-Prosecution 
Agreement (DE 28) is DENIED. 
DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida, 
this 12* day of February, 2008. 
KENNETH A. MARRA 
UNITED STATES DISTRICT JUDGE 
Copies furnished to: 
all counsel of record 
2 
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