EFTA01099834

Rule 26(a)(1) Disclosures in Jane Doe #1 and Jane Doe #2 vs. United States. No. 09-80736 
r
.r.• 
II ' . i 
S/A Witness #152 
Ivan Robles 
Lebet Johnson 
All people on inmate visito . • 
u• 
! 
tli ii . ...: ; 
J. e. Pan . 
Stc han 
.sslyn - 
L nne DeRothchild 
Ro ler Shank 
i 
Dejongh 
u ttola 
Kent Anderson 
, 
lo Anderson 
Dianne Porteaux 
Whitne Ta or 
Redd Vonhool 
r
ZW.T1717. 
, S/A Witness #105 
William "Bill" Rile 
• • 
Martin Nowak 
Howard Rubenstein 
: . 
Bill Clinton 
Prince Andrew 
William Hammon 
Robert Roxbur: 
6 
EFTA01099874

Rule 26(a)(1) Disclosures in Jane Doe #1 and Jane Doe #2 vs. United States, No. 09-80736 
David Rogers, 
rrison, 
Alan Dershowit7. 
a i Reach Police, 
Amanda Grant 
7 
EFTA01099875

Rule 26(a)(I) Disclosures in Jane Doe #1 and Jane Doe #2 vs. United States. No. 09-80736 
Ir
f3MCMSIRIttau 
oe, 
USAO, 500 South Australian Ave., WPB, FL 
33401 
•  
order°, 
PALM BEACH VICTIM SERVICES, =I 
I 
Steven Huffenber: 
Michael Stroll 
' Tonargula, 
Dou las Shoettle, 
Records Custodian, Palm Beach Police Department 
Records Custodian, FBI 
Documents and Tangible Things that Will Be Used to Establish Claims 
and Defenses 
Correspondence between the U.S. Attorney's Office and Jeffrey Epstein's 
Defense Counsel 
Non-Prosecution Agreement (various copies) 
Messages taken from message pads found at Defendant's home 
Documents related to Jeffrey Epstein produced by Alfredo Rodriguez 
Jeffrey Epstein flight logs 
Jeffre E stein phone records 
phone records 
Jail Visitation Logs 
Jeffrey Epstein's probation file 
All probable cause affidavits related to criminal investigation of Jeffrey 
Epstein 
8 
EFTA01099876

Rule 26(a)(1) Disclosures in Jane Doe #1 and Jane Doe #2 vs. United States. No. 09-80736 
All evidence, information and documents taken or possessed by FBI related 
to criminal investigation of Jeffrey Epstein 
Plaintiffs and other victims' statements to the FBI related to criminal 
investigation of Jeffrey Epstein 
Video of Search Warrant of Jeffrey Epstein's home being executed 
Application for Search Warrant of Jeffrey Epstein's home 
All records of homes, properties, bank accounts and any and all records 
related to Jeffrey Epstein's assets 
Jeffrey Epstein's passport (or copy) 
Jeffrey Epstein's driver's license (or copy) 
List of corporations owned by Jeffrey Epstein 
All documents evidencing relationship between Jeffrey Epstein and Jean Luc 
Brunel 
All documents evidencing relationship between Jeffrey Epstein and MC2 or 
any modeling agencies 
Affidavit and Application for Search Warrant on Jeffrey Epstein's home 
Tape recording or transcript of recording of conversation between Jeffrey 
Epstein and George Rush 
Notepads found in Jeffrey Epstein's home and/or during trash pulls outside 
of his home during criminal investigation 
The Palm Beach State Attorney's Criminal file against Jeffrey Epstein 
All documents related to Jeffrey Epstein's 6/30/08 conviction 
Jeffrey Epstein's criminal plea colloquy 
Public records from the Department of Corrections related to Jeffrey Epstein 
Records from the Florida Department of Law Enforcement related to Jeffrey 
Epstein 
All statements made by Jeffrey Epstein 
List of properties and vehicles in Larry Visoski's name 
All of Jeffrey Epstein's Responses to Requests for Production, Requests for 
Admission, Answers to Interrogatories in this matter, and cases 08-80119, 
08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 
09-80591, 09-80656, 09-80802, 09-81092 
All discovery related responses of Jeffrey Epstein in this matter and cases 08-
80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-
80469, 09-80591, 09-80656, 09-80802, 09-81092 
Jeffrey Epstein's Answers and Affirmative Defenses in all civil cases against 
him 
All Complaints in which Jeffrey Epstein was a plaintiff or defendant 
Jeffrey Epstein's Deposition testimony and discovery responses in this case 
and cases 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 
08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 
Jeffrey Epstein's Deposition testimony and discovery responses in State 
9 
EFTA01099877

Rule 26(0(1) Disclosures in Jane Doe #1 and Jane Doe #2 vs. United States, No. 09-80736 
Court cases LM v. Jeffrey Epstein, Case No. 502008CA02805IXXXXMB 
AB and E.W. v. Jeffrey Epstein, Case No. 502008CP003626)OOOCMB 
Jeffrey Epstein Deposition Testimony and discovery responses in State Court 
case 
Jeffrey 
Epstein 
v. 
Scott 
Rothstein, 
et 
al. 
Case 
No. 
502009CA040800)COCKMBAG 
Probable Cause Affidavits . epared against Jeffrey Epstein and 
Audio ta.e of 
Photographs, videos and books taken in the search warrant of Jeffrey 
Epstein's home 
Documents related to or evidencing Jeffrey Epstein's donations to law 
enforcement 
Victim Notification Letter from US Attorney's Office to Plaintiff 
Palm Beach Police Department Incident Report dated 4/20/06 
All reports and documentation generated by Palm Beach Police Department 
related to Jeffrey Epstein 
All Witness Statements generated by Palm Beach Police Department relating 
to Jeffrey Epstein 
Passenger Manifests of Jeffrey Epstein's aircraft and private plane flight logs 
Passenger lists for flights taken by Jeffrey Epstein 
Letter from Jeffrey Epstein to Alberto Pinto regarding house island project 
Jeffrey Epstein's bank statements 
Jeffrey Epstein's tax returns 
2 emails involving communications of Jeffrey Epstein, Jeff Fuller, 
Pappas Suat, Jean Luc Brunel and Amanda Grant 
DVD of plea and colloquy taken on 6-30-08 
Transcript of plea and colloquy taken on 6-30-08 
Massage Table 
Lotions taken from Jeffrey Epstein's home during search warrant 
Computers taken from Jeffrey Epstein's home during search warrant 
Vibrators, dildos and other sex toys taken from Jeffrey Epstein's home during 
search warrant 
No Contact Orders entered against Jeffrey Epstein 
Criminal Score Sheet regarding Jeffrey Epstein 
Documents evidencing Jeffrey Epstein's Community Control and Probation 
Jeffrey Epstein's Sex Offender Registration 
Jeffrey Epstein's Booking photograph 
CAD calls to 358 EL BRILLO WAY, PALM BEACH FL 33480 
List of Jeffrey Epstein's House contacts 
Documents related to Jeffre E•stein's investments 
Letter from Chief 
to 
10 
EFTA01099878

Rule 26(a)(1) Disclosures in Jane Doe #1 and Jane Doe #2 vs. United States, No. 09-80736 
List of planes owned by Jeffrey Epstein 
Letter from Guy Fronstin to Assistant State Attorney dated 1-11-06 
Letter from Guy Fronstin to Assistant State Attorney dated 1-13-06 
Letter from Guy Fronstin to Assistant State Attorney dated 2-17-06 
Letter from Guy Fronstin to Assistant State Attorney dated 4-6-06 
Letter from Guy Fronstin to Assistant State Attorney dated 4-10-06 
Letter from Goldberger dated 6-22-06 
All subpoenas issued to State Grand Jury 
Documents related to the rental of a vehicle for-
Documents related toproperty searches of Jeffrey Epstein's properties 
Arrest Warrant of 
Police report regarding 
picking up money dated 11-28-04 
Alan Dershowitz Letter dated 4-19-06 and Statute 90.410 
Guy Fronstin letter dated 4-17-06 
Jeffrey Epstein Account Information 
Jeffrey Epstein Criminal Closeout Sheet 
Jeffrey Epstein Polygraph Test and Results 
JEGE, Inc. Passenger Manifest 
Hyperion Air Passenger Manifest 
Fli: information for 
Passenger List Palm Beach flights 2005 
Jeffrey Epstein notepad notes 
Pleadings of Jane Doe 1 and 2 v. US case 
Jeffrey Epstein 51° Amendment Speech 
Reiter letter to 
dated 5-1-06 
Jail recei .ts of Je ffrey Epstein 
Police Report dated 11-28-04 
Victim Notification letter dated 7-9-08 
Police report of Juan Alessi theft at Jeffrey Epstein's home 
All items listed on the Palm Beach Police Property Report Lists 
All items taken in the execution of the search warrant of Jeffrey Epstein's 
home: 358 EL BRILLO WAY, PALM BEACH FL 33480 
All copies of convictions related to Jeffrey Epstein 
Jeffrey Epstein criminal records 
All documents produced b Palm Beach Police Department prior to the 
deposition of Detectiv. 
We believe that the Government has copies or, or immediate access to, all of these materials. As 
you know, we received the great bulk of these items from the Government. If you require 
assistance in locating any of them, please let us know. 
11 
EFTA01099879

Rule 26(a)(1) Disclosures in Jane Doe #1 and Jane Doe #2 vs. United States, No. 09-80736 
We look forward to receive your similar disclosures as soon as possible, so that we may 
incorporate them in our pleadings that we will be filing in this case in reply to your response to 
our pending motions. 
Sincerely, 
A dBradley J. Edwards 
Fe ORPaul G. j
Co-Counsel for Jane Doe #1 and Jane Doe #2 
The views expressed in this letter are solely those of its authors. 
12 
EFTA01099880

SJ. QUINNEY 
COLLEGE OF LAW 
THE UNIVERSITY OF UTAH 
March 1, 2011 
Wifredo A. Ferrer 
United States Attorney 
Southern District of Florida 
PAUL G. CASSELL 
Ronald N. Boyce Presidential Professor of Criminal Law 
Re: 
Jane Doe #1 and Jane Doe #2 vs. United States, No. 09-80736 
Dear Mr. Ferrer: 
We are writing to you personally on behalf of lane Doe #1 and Jane Doe #2 in one last 
effort to try and narrow our range of difference in the pending Crime Victims Rights Act case 
regarding Jeffrey Epstein. We make two requests: First, we are requesting that you agree to . 
our proposal for narrowing the range of disputes between your Office and the victims, Jane Doe 
#1 and Jane Doe #2. Second, if you are unable to agree to our proposal, we request that you 
agree not to withhold information in your Office's possession that would support their claims 
under the Crime Victims Rights Act (CVRA). 
By way of background, as you know, we have been attempting to work with your Office 
for more than two-and-a-half years to reach a stipulated set for facts in this CVRA case that 
would avoid the need for any public battle between your Office and the victims . Indeed, we 
reached out to you for a personal meeting to try to avoid a fight, and you were kind enough to 
meet with Jane Doe #1 and her undersigned attorneys. During that meeting, we expressed our 
intention to go the extra mile to try and avoid any fight with your Office and to see if there was 
a way to fight only Jeffrey Epstein the sex offender, rather than the prosecutors who work for 
you. 
Today we had a telephone conference call with two of your attorneys, 
and 
in which they told us that we would not be receiving any cooperation rom 
your 
ice on our CVRA case and that, in short, we would have to "see you in court." We were 
also told that your Office was taking the position that it could, and would, withhold from the 
victims information in your Office's possession that would support their claims under the CVRA. 
After receiving approval from 
and. 
we wanted to write to you personally in one 
last effort to see if we can narrow our differences on these two issues and avoid a disappointing 
battle. 
Narrowing the Issues in Dispute 
During today's conference call, it appeared that there was some confusion from Dexter 
and Marie as to precisely what the victims were proposing. Our proposal is simply this: that 
EFTA01099881

your Office and Jane Doe #1 and Jane Doe #2 would stipulate to a set of facts to provide 
context for the Court while we litigate the legal issue in dispute, that is whether the CVRA 
applies even though no federal charges were ultimately filed. If your Office prevails on that 
issue, the victims would obviously have no claim under the CVRA. The victims would then 
pursue their appellate rights in the Eleventh Circuit. If, however, the victims prevail on that 
issue, then your Office would take "no position" on the remedy sought by the victims for the 
violation of their rights afforded them under the Act. Your Office would essentially stand aside 
and agree not to take any position on the victims' request to set aside the NPA as a remedy for 
that violation of the victims' rights. 
We understood from our meeting with you in December that
 wanted to do what 
you could to help the victims in this case. Yet as we understood 
and 
today, they 
were taking the position that we would receive no cooperation of any sort from your Office. 
And we further understood from them that your Office was now going to take the position that 
even if the victims' congressionally-mandated rights were violated, there is simply no remedy 
for those violations and thus the victims should have no recourse for the violations. 
On behalf of our clients, we want to once again reach out and make sure that your 
Office wants to move to an adversarial litigation posture on these issues. We simply don't 
understand why your Office is now going to take a litigating position hostile to ours on issues 
beyond the legal question of when CVRA rights attached in this case. We appreciate that the 
Department has institutional concerns about the timing of CVRA rights. But we don't 
understand why your Office is now going to fight against the victims in their efforts seeking to 
overturn a NPA that by any measure is unfair. This is not simply our view —the unfairness of 
the NPA has now attracted comment literally throughout the world, Including serving as the 
basis for an unfavorable portrayal in a recent Law and Order: Special Victim Episode and a 
feature story yesterday in the London-based Sunday Moil. We are not asking your Office to join 
us in our efforts to throw out this unjust agreement. But can't your Office simply stand on the 
sidelines and let us make our case against Epstein. Fighting a politically well-connected 
billionaire is difficult enough, without having the weight of the U.S. Attorney's Office for the 
Southern District of Florida thrown against us too. We respectfully make one last request for 
you to move forward with our proposal for narrowing differences between us. 
Withholding Favorable Evidence 
If you feel that your Office must fight us in court on every possible issue, then we are 
respectfully writing to request that we resolve one issue outside of court: Whether your Office 
can withhold from the victims evidence in its ossesslon that is favorable to their CVRA case. 
During our conference call with 
and 
, we pointed out that if we were criminal 
defense attorneys representing criminals, your Office would promptly turn over to us all 
information in its possession that was helpful to these criminals under the Brady and Giglio 
decisions. We asked your Office to 
to th vi ims the same assistance that it would 
provide to criminals — i.e., we asked 
and 
to voluntarily provide to us information 
2 
EFTA01099882

in your Office's possession that was helpful the victims' CVRA case. We were informed that 
your Office will be taking the position in Court that it can and will withhold from the victims 
such information, apparently on the theory that victims lack due process or other "discovery" 
rights under the CVRA. 
We believe that the position that your Office can suppress relevant evidence is legally 
unfounded for four reasons and, in any event, is unsound policy at odds with promises that the 
Attorney General has made to crime victims and to the public. With regard to the legal 
problems in this position, first, the CVRA promises victims of crime that they will be "treated 
with fairness." 18 U.S.C. § 3771(a)(8). The clear intent of Congress in passing this provision was 
to provide a substantive "due process" right to crime victims. As one of the CVRA's co-sponsors 
(Senator Kyl) explained, "The broad rights articulated in this section are meant to be rights 
themselves and are not intended to just be aspirational. One of these rights is the right to be 
treated with fairness. Of course, fairness includes the notion of due process. Too often victims 
of crime experience a secondary victimization at the hands of the criminal justice system. This 
provision is intended to direct Government agencies and employees, whether they are in 
executive or judiciary branches, to treat victims of crime with the respect they deserve." 150 
CONG. M. 54269 (Apr. 22, 2004) (emphasis added). 
Because the CVRA extends a "due process" right to crime victims like Jane Doe #1 and 
Jane Doe #2, victims have a right to fair access to evidence to prove their case. The very 
foundation of the Brady obligation is due process: "[T]he suppression by the prosecution of 
evidence favorable to an accused . .. violates due process where the evidence is material either 
to guilt or to punishment." Brady v. Maryland, 373 U.S. 83, 87 (1963). It would similarly 
violate due process for the prosecution to suppress evidence favorable to a crime victim where 
the evidence is material either to proving a CVRA violation or to the remedy for a violation. 
Second, entirely apart from whether the victims have a right to obtain such information, 
your Office has an affirmative obligation to disclose it to victims. The CVRA directly commands 
that "[o]fficers and employees of the Department of Justice and other departments and 
agencies of the United States engaged in the detection, investigation, or prosecution of crime 
shall make their best efforts to see that crime victims are notified of, and accorded, the rights 
described in [the CVRA)." 18 U.S.C. § 3771(c)(1) (emphasis added).' It is simply impossible for 
As you can see from this language, the CVRA applies not only to the U.S. Attorney's Office for the 
Southern District of Florida but also to the relevant office of the FBI. We are "cc'ing" a copy of this letter 
to the FBI so that they can be informed of our view that they should provide assistance to the victims in 
this matter as well, rather than join your Office in any effort to withhold evidence. We understand that 
your Office represents the FBI on these issues, and are happy to continue our discussions with you 
regarding the FBI obligations in this area. At the appropriate time, however, if we are unable to reach 
agreement, we would like to have this discussion with a representative of the FBI to see whether they 
are in accord with your position. It is our understanding that the appropriate person would be the 
"special agent-In-charge of the division having primary responsibility for conducting the investigation." 
ATTORNEY GENERAL GUIDELINES FOR VICTIM AND WITNESS ASSISTANCE 11 (May 2005). 
3 
EFTA01099883

your Office to make its "best efforts" to accord victims their rights while simultaneously 
withholding evidence that would help them obtain those rights in court. 
Third, the attorneys in your Office have duties of candor to the Court that would not 
permit it to present evidence or testimony that is known to be false. Fla. Bar Rule 4-3.3(a)(4). 
Allowing the victims access to evidence favorable to their claim will insure compliance with this 
rule. Similarly, in an ex parte proceeding, a lawyer must inform the court of all material facts 
known to the lawyer that will enable the court to make an informed decision "whether or not 
the facts are adverse." Fla. Bar. Rule 4-3.3(d). If your Office is correct that we are not entitled 
to access to favorable evidence, then the proceedings involving that evidence are essentially ex 
parte — requiring your Office to make disclosure to the Court. Surely the more appropriate way 
to proceed is to simply disclose those materials in the first instance to the victims. 
Fourth and finally, your Office has previously taken the position that the CVRA petition 
filed by the victims is covered by the civil rules. If so, then the victims can serve discovery 
requests as in any other civil cases. The victims can likewise take depositions of witnesses who 
possess relevant evidence to their claims. Indeed, under Fed. R. Civ. P. 26(a)(1)(A), your Office 
would be required to automatically produce such information. 
For all these reasons, it is our considered opinion that your Office does not have a 
legally well-founded position to withhold evidence from the victims in this case. Even if the 
Office did have such a position, however, we are mystified as to why your Office would want to 
assert such a position. Attorney General Holder has recently publicly discussed the 
Department's obligations regarding production of exculpatory information to criminals, 
explaining "We're not here to win cases, but to do justice." Attorney Genera! Holder Discusses 
Efforts to Improve Prosecutor Training, WALL ST. J., Apr. 30, 2010. With all respect, we submit 
that your Office should seek to do justice not merely for criminals, but also for the victims of 
those criminals. We therefore respectfully request that you simply provide this information to 
us as a matter of justice, avoiding the need for us to litigate this question. To avoid burdening 
your Office, we would be happy to provide a specific list of the information that we believe is 
material to the victims' CVRA case — a limited amount of information that could be swiftly 
located by your Office. 
Conclusion 
We frankly believe we have been very patient on this case and have gone to the extra 
mile to avoid an unnecessary fight with your Office. But our clients are asking us what the 
status of their case is, and we have an obligation to proceed diligently. Our first choice is to 
work something out with you. But if your Office is for some reason unwilling or unable to do 
that, we believe we have an overwhelming case of clear cut CVRA violations — a case that we 
will present to the Court. 
4 
EFTA01099884

As we told 
and 
even though your Office has refused to provide any 
accommodations to us, we will continue to discuss with them our proposed statement of facts, 
with the aim of removing information that they believe is damaging to your Office and that we 
can leave out as unessential to our case. We hope that you will favorably consider our requests 
in this letter and try to find an approach that will minimize our need to become embroiled in a 
court dispute between crime victims and the prosecutors who aim to protect them. If we are 
unable to do so, our intention is to file our "summary judgment" pleadings (which we provided 
in their entirety to your Office as a courtesy six months ago) on March 18, 2011. 
Sincerely, 
Bradley J. dwards 
Paul 
Cassell 
Co-Counsel for Jane Doe #1 and Jane Doe #2 
Cc: 
Special Agent in Charge 
Miami FBI Field Office 
The views expressed in this letter are solely those of its authors. 
5 
EFTA01099885

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
WIFREDO A. FERRER 
UNITED STATES ATTORNEY 
Paul G. Cassell 
Professor of Law 
Quinney College of Law 
University of Utah 
RE: 
Letter of March 1, 2011 
Jane Does 1 and 2 v. United States 
Dear Mr. Cassell: 
99 N.F.. 4 Street 
Wong FL 33132 
March 15, 2011 
As you have recognized in your letter of March 1, 2011, the Department of Justice has a 
variety of institutional concerns regarding the interpretations of the Crime Victims' Rights Act 
(CVRA) that you are advocating on behalf of your clients. While we have no desire to be involved 
in any litigation with your clients or to be in any position adverse to them, the positions that you are 
advocating on behalf of your clients have far-reaching implications that were never intended by the 
CVRA and that extend beyond the above-referenced matter and the interests of both your clients and 
Jeffrey Epstein. In fact, requiring victim consultation and involvement before everyday prosecutorial 
decisions can be made not to pursue federal investigations, not to file federal criminal charges on 
specific allegations, or to divert a matter/allegations to state and local authorities would bring federal 
prosecutorial functions to a virtual halt and would exhaust prosecutorial resources in all sorts of 
cases all across the country. The pre-charge victim consultation and involvement that you advocate 
are simply unworkable. Moreover, your positions are contrary to the Department of Justice's 
interpretation of the CVRA and are unsupported by the pertinent statutory provisions. 
Nonetheless, as this Office has repeatedly attempted to make clear, we remain willing to 
cooperate with you, your clients, and other victims of Mr. Epstein's offenses. We have provided 
such cooperation in the past, and we will continue to do so. As you must surely understand, and as 
I mentioned to you and your client when we met this past December, the government simply cannot 
take legal positions in a spirit of cooperation that are contrary to law or that would hamper the 
government's prosecutorial ability to serve its citizenry, even if such positions would help 
accommodate certain individual crime victims in a particular matter. 
Because, as a matter of law, the CVRA is inapplicable to this matter in which no federal 
criminal charges were ever filed, your requests for the government's agreement on a set of proposed 
EFTA01099886

Letter to Paul G. Cassell 
Jane Does / and 2 v. United States 
March 15, 2011 
Page 2 of 2 
stipulated facts is unnecessary and premature. That is, because whether the rights in 18 U.S.C. 
§ 3771(a) attach prior to the filing of a charge in a federal court is a matter of statutory interpretation, 
resolution of that question is not dependent upon the existence of any certain set of facts, other than 
whether a charging document was ever filed against Jeffrey Epstein in the United States District 
Court for the Southern District of Florida. And while this Office remains willing to cooperate, 
cooperation does not mean agreeing to facts that are not relevant to the resolution of the legal dispute 
at issue, or failing to defend a prerogative that has been entrusted, as a matter of law, solely to the 
Executive Branch. 
With respect to your requests concerning information in the government's possession, we are 
fully aware of our legal and ethical obligations, have complied with those obligations, and will 
continue to do so in the future. But, contrary to your contentions, the law does not grant either you 
or your clients any right to discovery or unfettered access to information in the possession of the 
government, whether under the CVRA, the due process clause, or any other authority. Nonetheless, 
we remain willing to cooperate with you and your clients with any proper request for information, 
just as we would with any other person making such a request. 
Your request that the government not defend the government's non-prosecution agreement 
with Mr. Epstein is also something to which we simply cannot accede. Although that non-
prosecution agreement preceded my tenure as United States Attorney, this Office is legally bound 
to abide by that agreement and cannot legally or constitutionally engage in any action, direct or 
indirect, that seeks to undermine or circumvent that agreement and its terms, regardless of those 
contentions set forth in your March I, 2011 letter that the non-prosecution agreement was unwise 
or unjust. 
I recognize that the government's position in this matter is not what you and your clients 
would have desired. Be assured that this is not because the government and the members of this 
Office do not sympathize with the victims of Mr. Epstein's offenses or understand their concerns. 
Nonetheless, as I have tried to explain in a brief, summary fashion, deep-seated prosecutorial 
concerns and constitutional obligations that we are obliged to satisfy must guide the government's 
actions in these matters. 
If you have any questions concerning any of the legiletails regard, 
overnment's 
position on these matters, please contact AUSAs 
and Anne 
, who 
continue handling this matter on behalf of the United States and who have my complete confidence. 
111 1
11111.
WIF 
O A. FERRER 
UNITED STATES ATTORNEY 
EFTA01099887

LAW OFFICE 
a -kat/elite alitea • 
AND ASSOCIATES 
October 9, 2008 
AUSA 
United States Attorney's Office 
Re: 
Jane Doe # and Jane Doe #2 v. United States of America 
Case No.: 
08-80736-CIV-MARRADOHNSON 
Dear Mr. E: 
I am writing to call to your attention two potentially false statements that the Government 
made, albeit inadvertently, in a sworn declaration submitted to the Court in connection with the 
above-captioned case. I request that your office file a corrected declaration and accompanying 
explanation. 
The first statement is found at page 3 to 4 of the July 9 th, 2008 declaration of 
. There a provision in a plea agreement with Mr. Jeffrey Epstein is recounted. As we 
understand the Government's current position in this case, it is that this provision is not in fact 
part of the plea agreement in this case. If our understanding is correct, then Ms. Villafaita has 
filed a false affidavit with the court, albeit inadvertently. We respectfully request that she file a 
new affidavit that corrects this false information, along with all other information relevant to 
understanding how the false information came to be provided to the court — and to the victims in 
this case. This correction should, in my view, include more details about how Epstein and his 
attorneys approved a submission of false information to the victims as you stated on Page 5, n.2 
in your October 8, 2008 filing "Respondent's Opposition to Victims' Motion to Unseal Non-
Prosecution Agreement" — presumably knowing that litigation surrounding the victims' rights 
issues was on-going and that such false information might be ultimately presented to the court. 
Such information is highly relevant to what remedy the victims might ultimately choose to seek 
for violations of their rights in this case. 
The second statement may or may not be false, but may need some clarification. At page 
4 of Ms. 
declaration, she states that "[i]n October 2007, shortly after the agreement was 
signed, four victims [including C.W.] were contacted and these provisions were discussed' 
(emphasis added). Similarly at page 5, the declaration states: "After C.W. had been notified of 
the terms of the agreement ....." (emphasis added). I write to inquire whether, in view of the fact 
that the provision noted above is not in fact (according to the Government's current view) part of 
the_ plea agreement, whether this was the provision that the gevemmentLipaccuratelyldiscussed 
with the victims. Put another way, I am wondering whether the Government will now stipulate 
that it, at most, discussed with the victims a provision in the plea agreement that never was 
actually part of the plea agreement. 
EFTA01099888

AUSA 
United States Attorney's Office 
October 9, 2008 
Page Two 
I continue to be interested in working out a joint stipulation of proposed facts in this case 
with the Government. If you would like to proceed in that direction, please give me a call. If, 
however, the Government is not willing to work out a joint stipulation of facts, then I need to 
have the record be as clear as possible, and at a minimum would request that the Government 
correct the inaccurate information it has provided to the court and clarify precisely how such 
inaccurate information came to be made a part of the record and the extent to which Mr. Epstein, 
through his attorneys, was culpable. 
Sincerely, 
BE/sg 
Brad Edwards 
2028 HARRISON STRERT,SUITE 202, HOLLYWOOD, FLORIDA 33020 
EFTA01099889

Er 
COLLEG.E Cif- LAW 
THE UNIVERSITY OF UTAH 
Wifredo A. Ferrer 
United States Attorney 
Southern District of Florida 
PAUL C. CASSELL 
Ronald N. Royce Presidential Professor of Criminal Law 
September 29, 2011 
Re: 
Follow-up on leffrey Epstein 
Dear Mr. Ferrer: 
As you know, Brad Edwards and I represent Jane Doe #1 and Jane Doe #2 in their 
efforts to protect their rights under the Crime Victims' Rights Act. You were nice enough to 
meet with Jane Doe #1 in December 2010 on that case, and we appreciate that At the 
conclusion of that meeting, I also provided you with a letter presenting my grave concerns 
about possible improper influences being brought to bear on your Office during its 
negotiation of the Jeffrey Epstein non-prosecution agreement (For your convenience, I 
attach a copy of that letter.) It was my understanding that you deemed my allegations 
serious enough to forward my letter to the Office of Professional Responsibility (OPR) for 
further investigation, and it was my impression that OPR was going to look into the 
allegations raised in my letter. 
I must say that I was surprised to receive a letter five months later from OPR 
indicating that my concerns were not being investigated. On May 6, 2011, OPR stated that 
it was their policy "to refrain from investigating issues or allegations that were, are being, 
or could have been addressed in the court of litigation, unless a court has made a specific 
finding of misconduct by a DOJ attorney ... or there are present other circumstances." OPR 
stated that my allegations fell into the category of allegations that were being litigated 
because Jane Doe #1 and Jane Doe #2 were raising these issues in their CVRA case. 
Accordingly, OPR indicated it was not going to review the allegations that I presented. 
I am writing now to request the opportunity to meet with you further and to pass 
along additional information in support of my concerns. I wanted to follow up with you to 
make sure that someone was looking into my allegations about improper influences 
affecting your Office's decision to accord Jeffrey Epstein an extraordinarily lenient plea. It 
may well be that OPR has some policy precluding an investigation. But will your Office then 
investigate these issues? 
I am also writing to alert you to additional information that continues to lead me to 
believe that something was rotten with the way this case was handled. 
1 
www.law.utah.edu • Main Office (801) 581-6833 • Facsimile (801) 581-6897 
332 South 1400 East, Room 101 • Salt Lake City. Utah 84132-0730 
EFTA01099890

As you may know, 
was a senior prosecutor and supervisor in your 
Office when the non-prosecution agreement with Jeffrey Epstein was approved. It is our 
impression that he was directly involved in supervising the Epstein investigation as the 
former Chief of the Criminal Division of your Office. It has been our understanding for 
quite some time that he frequently corresponded with Epstein's attorneys, especially Lily 
Ann Sanchez, during the plea discussions, and it is our understanding that he left your 
Office around the time the non-prosecution agreement was signed. 
Our private investigator has recently learned that 
left your office to work at 
a New York law firm representing white collar criminals. He also learned that -
quite expensive apartment in New York City is located in close proximity to real estate 
properties (specifically condos) owned by Jeffrey Epstein. The location of Menchel's 
apartment, his role during the Epstein negotiations and his departure immediately after 
the NPA was signed, leads us to believe that 
and Epstein may have had a business 
or other relationship either during or after 
time in the Office. If that is the case, 
then we would appreciate you providing the information that you have in that regard 
voluntarily, as opposed to us having to conduct formal discovery to get it. 
As you also know, Judge Marra has recently ordered discovery to proceed in this 
case. We obviously would like for that process to go as smoothly as possible and want to 
avoid becoming involved in true adversary litigation with your Office. On behalf of our 
clients, we just want to get to the bottom of this, and we feel safe in assuming that you do 
too at this point. 
For all these reasons, I am writing to request another chance to meet with you about 
our concerns and about making the discovery process go smoothly. Thank you in advance 
for considering this request. I would be happy to provide any other additional information 
that would be useful to you. 
Sincere) 
Pau G. asse 
cc: 
Assistant U.S. Attorney 
cc: 
Assistant U.S. Attorney 
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1. A 11' 
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AND ASSOCIATES 
July 17, 2008 
MME
, AUSA 
United States Attorney's Office 
500 South Australian Avenue 
West Palm Beach, Florida 33401 
Re: 
Proposed Stipulated Facts for In Re Jane Doe 
Dear Ms. 
Thank you for your recent proposed stipulation of facts in this case. I believe that we 
have considerable common ground. At the same time, however, it appears to me that a few areas 
of potential disagreement are arising. In view of that, and to avoid any misunderstandings, I 
thought it might be useful to send a short letter outlining several requests and issues for 
resolution before I send you back my proposed stipulated facts. 
1. 
I am working with two other attorneys on this case — Jay Howell in Jacksonville, 
Florida, and Professor Paul Cassell in Salt Lake City, Utah. Because they were not in court for 
the hearing last Friday, they will need to review a transcript of the hearing before our legal team 
can agree to any stipulated facts. I have requested a transcript, but the preparation of it will 
apparently take several weeks. Do you have any way of expediting the preparation of the 
transcript by requesting it yourself? Also, as you know, my clients are indigent. As part of the 
Government's responsibility to use its "best efforts to see that crime victims are . . . accorded[] 
the rights" in the CVRA, 18 U.S.C. § 3771(cX1), I was wondering whether the Government 
would'be willing to pay for the transcript. 
2. 
Your proposed stipulation indicates that in September 2007 the U.S. Attorney's 
Office reached an agreement with Epstein to resolve the case, which was then modified in 
October and December of that year. While this seems plausible, to stipulate to the facts, I would 
obviously need to see copies of those three agreements. Moreover, because the circumstances 
surrounding the initial agreement and its later modification are now the subject of litigation, my 
client is entitled to see them. See 18 U.S.C. § 3771(a)(8) (victim's right to "be treated with 
fairness"). In addition, your proposed stipulation states that: "On July 9, 2008, AUSA 
sent a victim notification to Jane Doe 41 via her attorney, Bradley Edwards, which is attached as 
Exhibit 6 to the Villafafia Declaration. That notification contains a written explanation of the full 
terms of the agreement between Epstein and the U.S. Attorney's Office." I am puzzled by this 
proposed stipulation, as your July 9 letter explicitly noted that it was covering only some of the 
provisions in the agreement. Perhaps the fact that I have not yet received the agreement is all 
just an oversight on your part, and you had intended to give me the "full terms" of the plea 
agreement that was ultimately reached. In any event, the simplest way to proceed at this point is 
for the plea agreement — and the earlier versions -- to be provided to me so that I can review 
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them with my clients. Of course, no possible harm to the Government can come from the release 
of the documents, as this criminal matter is now concluded — at least from the Government's 
perspective. 
3. 
I am wondering about your position on the confidentiality provision in the 
agreement. As I understand things from your proposed stipulation, in September 2007 you 
"reached" an agreement with Epstein's attorneys that "contained an express confidentiality 
provision." Are you taking the position that this "express" provision barred disclosure of the 
substance of the agreement to my clients? And, if so, would you stipulate that the FBI agents 
and your office complied with the provision up through June 30 when, I assume, the confidential 
provision expired as Epstein entered his guilty plea in open court? 
4. 
Your proposed stipulation indicates: 
On October 26, 2007, Special Agents 
and 
met in person with Jane Doe #1. 
The Special Agents explained t t 
e 
investigation had been resolved, that Epstein would plead guilty to state charges, 
he would be required to register as a sex offender for life, and he had made certain 
concessions related to the payment of damages to the victims, including Jane Doe 
#1. 
During this meeting, Jane Doe #1 did not raise any objections to the 
resolution of the matter. 
From the drafting of this proposed stipulation, it appears that you may be working from a Report 
of Interview with my client (i.e., an FBI 302). My client has a differing recollection of some 
aspects of that meeting. Of course, she did not take notes of the meeting. Therefore, I ask that 
you provide me (the relevant parts of) any report of this meeting as well as reports of any other 
meetings relevant to the matters at hand. 
I believe that my client is entitled to a copy of (the relevant parts of) the reports of 
interviews with her. Of course, a criminal defendant would be entitled to such documents. See 
Fed. R. Crim. P. 16(a)(1)(A) & (B). As an innocent victim in this matter, my client should be 
treated with at least the same consideration. See 18 U.S.C. § 3771(a)(8) (victim's right to "be 
treated with fairness"). 
5. 
I am hoping that the Special Agents' and my client's recollections about one point 
of the October 26th meeting coincides: that she was never told that the agreement blocked all 
federal prosecution for the crimes at hand. Is a stipulation on that point agreeable? 
2028 HARRISON STRRET,SUITE 202, HOLLYWOOD, FLORIDA 33020 
EFTA01099893