EFTA01081657

Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 35 of 42 
direction4) kept the existence of the non-prosecution agreement secret from the victims and the 
public. The reasonable inference from the evidence is that the U.S. Attorney's Office wanted to 
keep the agreement a secret to avoid intense criticism that would have surely ensued had the 
victims and the public learned that a billionaire sex offender with political connections had 
arranged to avoid federal prosecution for numerous felony sex offenses against minor girls. 
As part of this pattern of deception, the U.S. Attorney's Office discussed victim 
notification with the defendant sex offender and, after he raised objections, stopped making 
notifications. Then later in January 2008, the U.S. Attorney's Office arranged for letters to be 
sent to the victims — including Jane Doe #1 and Jane Doe #2 — that falsely stated that to each that 
your "case is currently under investigation." This was untrue, as the U.S. Attorney's Office had 
already resolved the federal case by signing a non-prosecution agreement with Epstein. Indeed, 
the pattern of deception continued even after Jane Doe NI and Jane Doe #2 were represented by 
legal counsel. In May 2008, the Office sent a similar letter stating "your case is currently 
investigation" to another victim (represented by attorney Bradley .1. Edwards). As late as the 
middle of June 2008 — more than eight months after the non-prosecution agreement had been 
signed -- the Assistant U.S. Attorney handling the case told Edwards to send Information that he 
wanted the Office to consider in determining whether to file federal charges. The Office 
concealed from him that it had already made the determination not to file federal charges and 
that the Office had in fact signed a non-prosecution agreement long ago. The Office also 
concealed from him the fact that guilty pleas in state court were imminent. The Office disclosed 
4 It is unknown whether the U.S. Attorney's Office even made the FBI aware of the NPA 
in a timely fashion. 
35 
EFTA01081697

Case 9:08-cv-80736-KAM Document 48 
Entered on FLSD Docket 03/21/2011 Page 36 of 42 
the non-prosecution agreement only after Epstein had entered his guilty pleas in state court — in 
other words, only after the time for the victims to be able to object to the non-prosecution 
agreement during the plea process had come and gone. Even at that time, the Office did not 
disclose the provisions in the agreement. In short, the victims never learned about the non-
prosecution agreement barring federal prosecution of their cases because of a deliberate 
decisions by the U.S. Attorney's Office, not mere "negligence or inaction." McCorlde, 321 F.3d 
at 1297. Accordingly, the Government is stopped from arguing that the Crime Victims' Rights 
Act does not apply to this case. 
IL 
THE COURT SHOULD FIND THAT THE VICTIMS' RIGHTS HAVE BEEN 
VIOLATED AND THEN SET UP A BRIEFING SCHEDULE AND HEARING ON 
TILE APPROPRIATE REMEDY. 
This U.S. Attorney's Office's behavior in this case does not satisfy the Office's 
obligations under the CVRA to use its "best efforts" to insure that victims receive protection of 
their rights. 18 U.S.C. § 3771(c)(1). In particular, the undeniable chain of events makes clear 
that the victims were not afforded their right "to confer with the attorney for the Government in 
the case." 18 U.S.C. § 3771(a)(5). Whatever else may be said about the deception, it also 
starkly violates the victims' right "to be treated with fairness and with respect for the victim's 
dignity . ..." 18 U.S.C. § 3771(a)(8). The pattern also denied the victims of timely notice of 
court proceedings, 18 U.S.C. § 3771(a)(3), including in particular the state court guilty plea. 
As we understand the position of the Government, it does not truly contest that — if the 
CVRA applied — it managed to discharge its various obligations under the Act. Instead, the 
Government relies solely on a technical argument to reach the conclusion that it discharged its 
obligations — namely, the argument that the CVRA does not apply until a formal indictment is 
36 
EFTA01081698

Case 9:08-cv-80736-KAM Document 48 
Entered on FLSD Docket 03/21/2011 Page 37 of 42 
filed. As just explained, however, that technical argument must be rejected as inconsistent with 
the CVRA's plain language and interpretation by other courts. Accordingly, this Court should 
find that the Government has violated its CVRA obligations. 
Once the Court finds such a violation, the next issue becomes what remedy should apply. 
Since the earliest days of our nation, it has been settled law that "where there is a legal right, 
there is also a legal remedy . . . .. 
Morbury.v. Madison, 5 U.S. 137, 163 (1803) (internal 
quotation omitted). Moreover, "[1)1 the right is created by a federal statute, the federal courts 
have the power to fashion an appropriate remedy." Intracoastal Transp., Inc. v. Decatur County. 
Georgia 482 F.2d 361, 371 (5th Cir. 1973). As we understand the Government's position in this 
case, however, they believe that this Court is powerless to do anything to correct the palpable 
violation of victims' rights documented in this case. 
Jane Doe #1 and Jane Doc #2 respectfully request that the Court set up a briefing 
schedule and a hearing on this important issue. The victims believe that they can establish that 
the appropriate remedy for the clear violations of their rights is to invalidate the Non-Prosecution 
Agreement. While the victims request an opportunity to provide more extensive briefing on this 
subject, they provide a few citations in support of their position here. 
When other plea arrangements have been negotiated in violation of federal law, they have 
been stricken by the courts. For example, United States v. Walker, 98 F.3d 944 (7th Cir. 1996), 
held that where a sentence on a new crime could not run concurrently with a probation 
revocation the defendant was then serving — contrary to the assumption of the parties to the plea 
agreement — the defendant was not entitled to specific performance of the plea agreement. The 
Court explained that the case was one "in which the bargain is vitiated by illegality ...." Id. at 
37 
EFTA01081699

Case 9:08-cv-80736-KAM Document 48 
Entered on FLSD Docket 03/21/2011 Page 38 of 42 
947. Here, of course, exactly the same is true: the non-prosecution agreement is vitiated by 
illegality — namely, the fact that it was negotiated in violation of the victims' rights. Other cases 
reach similar conclusions. See, e.g., United States v. Cooper, 70 F.3d 563, 567 (10th Cir. 1995) 
(prosecutor agreed to recommend probation, but it later appeared that would be an illegal 
sentence in this case, and thus only adequate remedy is to allow defendant to withdraw plea); 
Craig v. People, 986 P.2d 951, 959-60 (Colo. 1999) (because "neither the prosecutor nor the trial 
court have authority to modify or waive the mandatory parole period," such "is not a permissible 
subject of plea negotiations," and thus, even if "the trial court erroneously approves of such an 
illegal bargain" such plea is "invalid" and thus will not be specifically enforced). Nor can the 
defendant claim some right to specific performance of an illegal non-prosecution agreement. See 
State v. Garcia, 582 N.W.2d 879, 881-82 (Minn. 1998) (plea agreement for 81 months sentence, 
but court added 10-year conditional release term because, under facts of case, sentence without 
such release term "plainly illegal," and thus remedy of specific performance not available); State 
v. Wall, 348 N.C. 671, 502 S.E.2d 585, 588 (1998) (plea agreement was for sentence to be 
concurrent with one not yet completed, but state statute mandates consecutive sentence on facts 
of this case; "defendant is not entitled to specific performance in this case because such action 
would violate the laws of this state"); Ex parte Rich, 194 S.W.3d 508, 515 (Tex. Crim. App. 
2006); (where "the plea bargain seemed fair on its face when executed, it has become 
unenforceable due to circumstances beyond the control of [the parties], namely the fact that one 
of the enhancement paragraphs was mischaracterized in the indictment, resulting in an illegal 
sentence far outside the statutory range," proper remedy is plea withdrawal, as "there is no way 
of knowing whether the State would have offered a plea bargain within the proper range of 
38 
EFTA01081700

Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 39 of 42 
punishment that he deemed acceptable"); State v. Mazzone, 212 W.Va. 368, 572 S.E.2d 891, 897 
(2002) (where plea agreement was that defendant would plead guilty to 2 felony counts of felon 
in possession of firearm and prosecutor would dismiss remaining 6 counts re other offenses with 
prejudice, and all parties erroneously believed these 2 crimes were felonies, lower court 
"correctly resolved this unfortunate predicament by holding that a plea agreement which cannot 
be fulfilled based upon legal impossibility must be vacated in its entirety, and the parties must be 
placed, as nearly as possible, in the positions they occupied prior to the entry of the plea 
agreement"). 
The Non-Prosecution Agreement that the Government entered into in this case was 
simply illegal. The Government did not protect the congressionally-mandated rights of victims 
before it entered into this Agreement. Perhaps it is for this reason that the Agreement is so 
shockingly lenient — blocking prosecution for dozens and dozens of federal felony sex offenses 
against several dozen minor girls. But regardless of the leniency, the only issue for the Court is 
whether the Agreement was lawful. It was not, and so the Court invalidate it.s The victims 
respectfully ask for a full briefing schedule and a hearing on this important issue. 
5 Defendant Jeffrey Epstein was notified about this case long ago, and was notified on 
August 26, 2010, that the victims would be filing correspondence in support of their motions. 
Ile has not chosen to intervene in this action, and so he should not be heard to complain about 
remedy the Court might impose. 
In any event, there arc no double jeopardy barriers to invalidating the plea. As explained 
in a leading criminal procedure treatise: 
The review of defendant's sentence is also provided in federal cases upon 
application of a victim. The Crime Victim's Rights Act allows a victim to seek to 
reopen a sentence through a writ of mandamus, if the victim has asserted and been 
denied the right to be heard at sentencing. Like the prosecution's statutory right 
to appeal, the victim's statutory remedy should pose no double jeopardy 
39 
EFTA01081701

Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 40 of 42 
CERTIFICATE OF CONFERENCE 
As recounted above, counsel for Jane Doe #1 and Jane Doe #2 have approached the U.S. 
Attorney's Office for more than two and a half years in an effort to reach stipulated facts. The 
U.S. Attorney's Office ultimately terminated those efforts on March 15, 2011, taking the position 
that the facts of the case are irrelevant and that, on any set of facts, it did not violate the CVRA. 
CONCLUSION 
For all the foregoing reasons, the Court should find the U.S. Attorney's Office violated 
Jane Doe #1 and Jane Doe #2's rights under the Crime Victims Rights Act and then schedule an 
appropriate hearing on the remedy for these violations. The scope of the remedy that is 
appropriate may depend in pad of the scope of the violations that the Court finds. For this 
reason, it makes sense for the Court to bifurcate the process and determine, first, the extent of the 
violations and then, second, the remedy appropriate for those violations. If the Court would 
prefer to see more immediate briefing on remedy issues, the victims stand prepared to provide 
that briefing at the Court's direction. 
difficulties if as the piFrancesco] Court explained 
the defendant is 'charged 
with knowledge of the statute and its . . . provisions, and has no expectation of 
finality in his sentence until the [review by writ) is concluded . . .." 
LAFAVE ET AL., CRIMINAL Procedure § 26.7(b) (Nov. 2010) (quoting United States v. 
DiFrancesco, 449 U.S. 117, 146 (1980)). 
40 
EFTA01081702

Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 41 of 42 
RATED: March 21, 2011 
Respectfully Submitted, 
p/ Bradley J. Edwards 
Bradley J. Edwards 
FARMER, JAFFE, WEISSING, 
EDWARDS, FISTOS & LEHRMAN, P.L. 
425 North Andrews Avenue, Suite 2 
Fort Lauderdale, Florida 33301 
Telephon 
Facsimile 
Florida Bar No.: 542075 
E-mail: brad®pathtojustice.com 
and 
Paul G. Cassell 
Pro Hoc Vice 
S.J. Quinney College of Law at the 
University of Utah 
332 S. 1400 E. 
"ANL 
Salt Lake C.
Telephone: 
Facsimi • 
E-Mail: 
Attorneys for Jane Doe #1 and Jane Doe #2 
41 
EFTA01081703

Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 42 of 42 
CERTIFICATE OF SERVICE 
The foregoing document was served on March 21, 2011, on the following using the Court's 
CM/ECF system: 
A. Marie ViBefogs 
Assistant U.S. Attorney 
500 S. Australian Ave., Suite 400 
West Palm Beach, FL 33401 
Fax: 
E-mail: 
Attorney for the Government 
Joseph L. Ackerman, Jr. 
Joseph Ackerman, Jr. 
Fowler White Burnett PA 
777 S. Flagler Drive, West Tower, Suite 901 
West Palm Beach, FL 33401 
Criminal Defense Counsel for Jeffrey Epstein 
(courtesy copy of pleading via U.S. mail) 
42 
EFTA01081704

Case 9:08-cv-80736-KAM Document 48-1 Entered on FLSD Docket 03/21/2011 Page 1 of 1 
JANE DOE kl AND JANE DOE N2'S MOTION FOR FINDING OF VIOLATIONS OF THE 
CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE 
REMEDIES 
CASE NO: 08-80736-Clv-Marra/Johnsou 
EXHIBIT A 
Filed Under Seal 
EFTA01081705

Case 9:08-cv-80736-KAM Document 48-2 Entered on FLSD Docket 03/21/2011 Page 1 of 6 
JANE DOE NI AND JANE DOE N2'S MOTION FOR FINDING OF VIOLATIONS OF THE 
CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE 
REMEDIES 
CASE NO: 08-80736-Clv-Marra/Johnson 
EXHIBIT B 
EFTA01081706

Case 9:08-cv-80736-KAM Document 48-2 Entered on FLSD Docket 03/21/2011 Page 2 of 6 
F0-302 (Rev. 1044* 
- - 
FEDERAL BUREAU OF INVESTIGATION 
Date of transcription 
08/14 /2007 
C 
was interviewed in West Palm Beach, 
Florida, re a ing "Feral  investigation involving the sexual 
exploitation of minors. After being advised of the identity of,the 
interviewing agents and the nature of the interview, V - 
provided 
the following information: 
In 2003 or 2004 W 
was introduced to JEFFREY EPSTEIN 
for the purpose of providing
 with personal massages. A 
was 
approached at a party by a female she believed was named 
ISE. 
She described the female as havin 
r 
hair and taller. The 
female was later identified as 
. eallp 
told 
Weil/ and Well's friend, MS 
MSS, 
that they could make money by 
providing massages to EPSTEIN. 91.0.1•11. told We that she could 
provide the massages with her clothes on or off. We_, who was 
fifteen years old, believed that she was close to turning sixteen 
when she first met EPSTEIN. However, during wilts first contact 
with EPSTEIN, she told him that she had just turned eighteen. 
and WO traveled to EPSTEIN's residence in Palm 
Beach by taxi. 
was regnant at the time. Once at the 
residence, 
took W 
pstairs. EPSTEIN entered the room 
wearin only. 
Once EPSTEIN had removed the robe, both 
and WOOMIprovided EPSTEIN with a massage. Both 
and WIMMOhad removed their clothing and remained only in their 
underwear. EPSTEIN asked ato 
leave. Once alone with Wei 
EPSTEIN began to masturbate. WOMMrwas uncomfortable. 
After 
EPSTEIN climaxed the massage was over. We believed that fles 
had mentioned EPSTEIN might masturbate during the massage but she 
was still very surprised when he masturbated. EPSTEIN paid WES 
$200.00. EPSTEIN did not touchleduring that massage. WIMP 
departed EPSTEIN's residence with two men that worked for EPSTEIN. 
They drove WEEMWto a Shell Gas Station located near Okeechobee 
Boulevard and the Florida Turnpike. 
Prior to departing the residence, Wileprovided her 
telephone number to one of EPSTEIN's assistants, a 
(PHONETIC). 
Willigsdescribed her as a very pretty Hispanic female in 
her early twenties, with lon 
I'S, 
and approximately 5'5" to 
5'6" tall. vallostated that 
, another iii
TEIN's 
assistants, or EPSTEIN would usually contact her. 
would
telephone and ask if she was available or if she had any other 
Investigation on 
08/07/2007 
M West Palm Beach, Florida 
31E-MM-108062 
SA E. Nesbitt Kuyrkenall 
in 
SA Jason R. Richards 
Datedkmed 08/07/2007 
This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your ataxy: 
if and at contenu we not to be destrIbuted outside your agency. 
EFTA01081707

Case 9:08-cv-80736-KAM Document 48-2 Entered on FLSD Docket 03/21/2011 Page 3 of 6 
, 
1:13302* (Rev. 10445) 
31E-MN-108062 
CominutionORD-Mad 
UMEINMIK 
,On  08/07/2007  Jar  
2 
girls she could bring: When EPSTEIN telephoned, he usually asked 
for wato 
come over. According to WS 
EPSTEIN's house 
telephone number began with the di its 655. She would call 
sometimes and leave a message. W 
stated that when they 
telephoned her they would inform her of when they would be coming 
back to town and if she might have anyone new. WIMMOdid not 
believe that EPSTEIN ever really liked her. 
WIMMOtraveled to the EPSTEIN's residence during 2003 and 
2004 over twenty five times. WAMObelieved that she provided 
EPSTEIN with approximately 10-15 massages. EPSTEIN initially 
started out touching WNW 
breasts but gradually the massages 
became more sexual. EPSTEIN would instruct Sion 
how and what to 
do during the massages. He would request Mato 
rub his chest and 
nipples. WOMMistated that on approximately two occasions, EPSTEIN 
asked that WOMMOremove her underwear and provide the massage nude. 
h 
complied. womerstated that EPSTEIN would make her feel that 
she had the option to do what she wanted. 
During one massage, WM stated that she had been.giving 
EPSTEIN a massage for approximately 30-40 minutes when instead of 
EPSTEIN turning over to masturbate, EPSTEIN brought another female 
into the massage area. 
S' 
described the female as a beautiful 
blonde girl, a "Cameron Diaz" type, 19 years of age, bright blue 
eyes, and speaking with an accent. EPSTEIN had WIMMOstraddle the 
female on the massage table. EPSTEIN wanted willito touch the 
females breast. According to we, EPSTEIN "pleasured" the female 
while Wflwas straddled on top of the female. W 
stated she 
could hear what she believed to be a vibrator. W 
said for 
EPSTEIN it was all about pleasuring the female. After the female 
climaxed, EPSTEIN patted W
on the shoulder and she removed 
herself from the table. The female got up from the table and went 
into the spa/sauna. EPSTEIN commented to Wallothat in a few 
minutes the female would realize what had just happened to her. 
wSreceived $200.00. 
meadvised the interviewing agents that EPSTEIN had 
used a back massager on her vagina. EPSTEIN asked her first if he 
could use the massager on her. Wiestated that she had held her 
breath when EPSTEIN used the back massager on her. wiestated 
that at no time during any of the massages had EPSTEIN caused her 
to climax. 
During another massage, % 
believed by this time she 
was seventeen, EPSTEIN placed his hand on WINED vagina, touching 
EFTA01081708

Case 9:08-cv-80736-KAM Document 48-2 
Entered on FLSD Docket 03/21/2011 Page 4 of 6 
17O.302a (lter. 10-6-95) 
31E-MM-108062 
Continuation of FD-302 of 
.On  08/07/2007  "lc  
3 
clitoris. wSwas uncomfortable and told him to stop. 
EPSTEIN complied. WOMMOstated that the incident freaked her out. 
WIIMPstated that EPSTEIN was upset because she was upset. WOOS 
never return to the residence. WOMMOstated that she did not deal 
with EPSTEIN anymore after that incident. 
EPSTEIN gave both 1. 
and MUMMOMPeach a book entitled 
"Massage for Dummies". They received the books on the same visit. 
EPSTEIN also commented how strong Willis hands were when it came to 
her providing his massages. 
On another occasion, WOOPmentioned to EPSTEIN that she 
was looking at a car, a Toyota Corolla. EPSTEIN provided t 
with 
$600.00 - $700.00. Illestated that EPSTEIN gave her the money 
after the incident with the other female. 
According to wall EPSTEIN would ask her to bring him 
other girls. rime who started dancing at strip clubs when she was 
16, brought girls from the club as well as from other sources. 
WILD stated she brought girls from fifteen years of age to twenty-
five years of age. Allipstated that EPSTEIN would get frustrated 
with,her if she did not have new females for him. On one instance, 
EPSTEIN hung up on her because she could not provide him with 
anyone new. V
 stated that EPSTEIN's preference was short, 
little, white girls. la stated that EPSTEIN was upset when one 
of the other girls brought a black girl. WOMOstated that EPSTEIN 
did not want black girls or girls with tatoos. 
* 
stated that one of the girls she stayed with on 
occasion, 5, 
also started providing EPSTEIN with 
massages. A telephone number for Naas 
L.
 
W 
said that her family resides in 
, Florida, possibly 
INNIIIIIMP sabialso stayed with 
during this same 
time period. However, IMMO never went to EPSTEIN's house or 
provided him with massages. 
has a Yacht Club address. 
Another girl that Wallehad taken to EPSTEIN's residence 
was ISMEMNOLast Name Unknown(LNU). According to PL 
a 
EPSTEIN 
liked LOMMIMOLNU a lot. S
 said that she was never a favorite of 
EPSTEIN. EPSTEIN offered Wie$300.00 to brinJEISLNU. 
Lea 
LNU was a couple years younger than a 
W 
believed that she 
was either 16 or 17 when she first went to EPSTEIN's residence. 
WOMMOsaid that Lae 
LNU went 2-3 times but that she did not want 
any part of it after that. Wile believes she could identify a 
LNU if she saw her photograph. we also stated that Limmtum at 
EFTA01081709

Case 9:08-cv-80736-KAM Document 48-2 
Entered on FLSD Docket 03/21/2011 Page 5 of 6 
. F13-302a (Rev. 10-645) 
31E—MM-108062 
Continustiom of FD-302 of 
a
 a 
,O. O91O712OO7 
 .Par 
4 
one time attended 
HIGH SCHOOL. 
WONSDalso 
believed that they had met through a group of friends while 
attending 
- a dropout prevention school. 
WIMMOmentioned another girl by the name of CUMIS 
fillps 
EPSTEIN distinguished the two "
 by referring to 
MIMIMMOPas 
ISIMMOhworked at an ice cream 
shop. WIMMIstated that she did not like MM. 
and that ISMOMMOr 
was a storyteller and a bad liar. Walestated that laillilenever 
really wanted to go to EPSTEIN's residence but she went anyway. 
WOOM.said that she had not taken a good look at EPSTEIN's 
penis. WOMOWexplained that it seemed like he would always try and 
hide his penis. W` stated that EPSTEIN never asked her for sex. 
WOMMWstarted dancing when she was sixteen at 
The owner, MIS 
let her dance. WIMphas also 
worked at Saolocated 
in Boynton 
Beach, Florida. 
W- used illegal drugs during the years she provided 
EPSTEIN with massages. Welesaid that EPSTEcIN tried to provide her 
with advice regarding controlled substances. 
S 
_stated that she met with EPSTEIN's attorneys, 'Wm 
IMMINIMPand a unidentified female(UF), at the ALE HOUSE RESTAURANT. 
Wilipmet with them after she contacted 
, who confirmed that 
the were reall workin• for EPSTEIN. P
itated that 
also 
W 
oun out t at 
an t e I 
are employed by 
 
 
They asked a lot of questions. They 
specifically asked about LOMMNO, and a GlIMILNU. 4MMOreiterated 
her dislike for LEEN 
WIMMOalso informed the interviewing agents that she had 
spoken to 7. 
she believed before the fourth of July. M 
told WiliMpthat she had met with investigators and that they had 
videoed her. 
numbers: 
WimmOconfirmed her association to the following telephone 
Old cellular number - (561) 
Possibly an old cellular number - (561) 
telephone number - (561)eam 
EFTA01081710

Case 9:08-cv-80736-KAM Document 48-2 Entered on FLSD Docket 03/21/2011 Page 6 of 6 
FD•30L (Rev. 10-6-95) 
31E-MM-108062 
Continuoboo of FD-302 of 
C=V
 
Oa  08/07/2007  ,Fat  
5 
t, 
cP 
EFTA01081711

Case 9:08-cv-80736-KAM Document 48-3 Entered on FLSD Docket 03/21/2011 Page 1 of 3 
JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF THE 
CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE 
REMEDIES 
CASE NO: 08-80736-Civ-Marrahlohnson 
EXHIBIT C 
EFTA01081712

07/09/2008 15:13 FAX 5618059846 
USAO WPB CONFRM 
Case 9:08-cv-80736-KAM ,ument 48-3 
Entered on FLSD Dirt 
03/21/ 
U.S. Department of Justice 
Untied States Attorney 
Southern District of Florida 
al 022 
300 South Australian Ave., Suite 4OO 
We t P 
ch. FL 33401 
Facsimile: 
June 7, 2007 
Pit-EVERY BY HAND 
Miss Sit 
Re: 
Crime Victims' and Witnesses' Rights 
Dear Miss AS 
Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense, 
you have a number of rights. Those rights are: 
(I) 
The right to be reasonably protected from the accused. 
(2) 
The right to reasonable, accurate, and timely notice of any public court proceeding 
involving the crime or of any release or escape of the accused: 
(3) 
The right not to be excluded from any public court proceeding, unless the court 
determines that your testimony may be materially altered if you arc present for othei 
portions of a proceeding. 
(4) 
The right to be reasonably heard at any public proceeding in the district court 
involving release, plea, or sentencing. 
(5) 
The reasonable right to confer with the attorney for the United States in the case. 
(6) 
The right to full and timely restitution as provided in law. 
(7) 
The right to proceedings free from unreasonable delay. 
(8) 
The right to be treated with fairness and with respect for the victim's dignity and 
privacy. 
Members of the U.S. Department of Justice and other federal investigative agencies, 
including the Federal Bureau of Lnvestigation, must use their best efforts to make sure that 
n is are protected. If you have any concerns in this regard, please feel free to contact me at 
, or Special Agent Nesbitt Kuyrkendall frorn•the Federal Bureau of Investigation at 
. You als • 
n 
the Justice Department's Office for Victims of Crime in 
Washington, D.C. at
. That Office has a website at www.ovc.gov. 
You can seek the advice of an attorney with respect to the rights listed above and, if you 
believe that the tights set forth above are being violated, you have the right to petition the Court for 
relief. 
EFTA01081713

07/09/2008 15:14 FAX 5618059846 
USAO WPB CONFRI 
14023 
Case 9:08-cv-80736-KAM ,ument 48-3 
Entered on FLSD Dirt 
03/21/2011 Page 3 of 3 
Miss cruet 
JUNE 2.2002 
PAGE 2 
In addition to these rights, you are entitled to counseling and medical services, and protection 
from intimidation and harassment. If the Court determines that you are a victim, you also may be 
entitled to restitution from the perpetrator. A list of counseling and medical service providers can 
be provided to you, if you so desire. If you or your family is subjected to any intimidation or 
harassment, please contact Special Agent Kuyrkendalt or myself immediately. It is possible that 
someone working on behalf of the targets of the investigation may contact you. Such contact does 
not viola/debt Imw. However, if you are contacted, you have the choice of speaking to that person 
or refusing to"do go. If you refuse and feel that you are being threatened or harassed, then please 
contact Special Agent Kuyrkendall or myself. 
You also are entitled to notification of upcoming case events. At this time, your case is under 
investigation! If anyone is charged in connection with the investigation, you will be notified. 
Sincerely, 
By: 
cc: 
Special Agent Nesbitt ICurkendall, F.A.I. 
R. Alexander Acosta 
United States Attorney 
•freelea"-
4O-
A. Marie Villafaila 
Assistant United States Attorney 
f 
EFTA01081714

Case 9:08-cv-80736-KAM Document 48-4 Entered on FLSD Docket 03/21/2011 Page 1 of 3 
JANE DOE NI AND JANE DOE n'S MOTION FOR FINDING OF VIOLATIONS OF THE 
CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE 
REMEDIES 
CASE NO: 08-130736-Clv-MarrafJohnson 
EXHIBIT D 
EFTA01081715

a 024 
07/09/2008 15:14 FAX 5618059846 
USAO WPB CONFRM 
Case 9:08-cv-80736-KAM ,ument 48-4 
Entered on FLSD Dir t 03/21/ 
U.S. Department of Justice 
United Stoles Attorney 
Southern District of Florida 
500 South Aitstrolian Ave., Suite 400 
Wen Palm each. FL 3340/ 
Facsimile: 
August I I, 2006 
DEVVERY BY HAN') 
Miss Tea 
Re: 
Cnme Victims' and Witnesses' Rights 
Dear Miss Mills 
Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense, 
you have a number of rights. Those rights are: 
(I) 
The right to be reasonably protected from the accused. 
(2) 
The right to reasonable, accurate, and timely notice of any public court proceeding 
involving the crime or of any release or escape of the accused. 
(3) 
The right not to be excluded from any public court proceeding, unless the court 
determines that your testimony may bomaterially altered if you arc present for other 
portions of 0 proceeding. 
(4) 
The right to be reasonably heard at any public proceeding in the district court 
involving release, plea, or sentencing. 
(5) 
The reasonable right to confer with the attorney forte United States in the case. 
(6) 
The right to full and timely restitution as provided in law. 
(7) 
The right to proceedings lice from unreasonable delay. 
(8) 
The right to be treated with fairness and with respect for the victim's dignity and 
privacy. 
C.( 
Members of the U.S. Department of Justice and other federal investigative agencies, 
including the Federal Bureau of Investigation, must use their best efforts to make sure that t 
n is are protected. If you have any concerns in this regard, please feel free to contact me at 
, or Special Agent Nesbitt Kuyrkendall from the Federal Bureau of Investigation at 
• You also can contact the Justice Department's Office for Victims of Crime in 
Washington, D.C. at 
That Office has a wcbsite at www.ovc.gov. 
You can seek the advice of an attorney with respect to the rights listed above and, if you 
believe that the rights set forth above are being violated, you have the right to petition the Court for 
relief. 
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