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Agreement with defendant Epstein that is at the center of this litigation and (2) the FBI's report 
of interview concerning a meeting with Jane Doe #1. These requests were also made in several 
telephone conversations with the attorney for the Government. Remarkably, rather than respond 
to the victims' suggestions, the Government has now suddenly reversed course and filed a terse 
document claiming an "absence of a need" for an evidentiary hearing. If anything, however, the 
victims' discussions with the Government have made clear that the Court should not enter 
judgment for the Government but rather should enter immediate judgment for the victims that the 
Government violated their rights under the CVRA. The Court should then schedule a hearing to 
determine the proper remedy for the violation of the victims' rights. 
In particular, the Government now apparently admits that the Non-Prosecution 
Agreement it struck with Epstein in September 2007 contained an "express confidentiality 
provision." See Exhibit 1 to this pleading, Government's Proposed Stipulated Facts, at page 3, 
paragraph 6. Assuming that the Government honored its agreement with the defendant (a fact 
that the victims have proposed to stipulate to), the Government could not have "conferred" with 
the victims about the proposed arrangement over the next nine months because doing so would 
have violated its confidentiality obligations with the defendant. As a result, the Government 
plainly has not afforded the victims' their right to "confer" about the proposed arrangement under 
the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771(a)(5). In addition, the Government 
effectively misled the victims that it had reached a Non-Prosecution Agreement with Epstein, 
plainly violating the victims' rights to be treated with "fairness" under the CVRA, 18 U.S.C. 
§3771(a)(8). The Court should therefore find that the victims' rights have been violated. 
The Court should also order the Government to produce the Non-Prosecution Agreement 
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to the victims. The victims are entitled to know what disposition has been made in their case. 
Moreover, that Agreement purportedly contains provisions pertaining to the civil liability of 
Epstein for crimes he has committed against Jane Doe #1 and Jane Doe #2. Epstein obviously 
knows what those provisions are. The victims are entitled to see those provisions and the 
surrounding document as well. 
The Court should also order the Government to produce a report of interview with Jane 
Doe #1 from about October 26, 2007, during which the Government apparently claims that it 
discussed the plea arrangement with the victims. 
Finally, after these documents are produced to the victims and the Court enters judgment 
that the victims' rights have been violated, the Court should schedule a hearing to determine the 
appropriate remedy for the violations of the victims' rights. 
THE VICTIMS' PROFFERED FACTS 
The Government's latest submission takes the position that "after consideration" it is now 
unnecessary to hold an evidentiary hearing. The Government apparently believes that the Court 
could rule in its favor based on just two submitted undisputed facts. In taking this position, the 
Government apparently believes that there are no set of facts that could sustain judgment for the 
victims. To the contrary, however, the available facts require judgment for the victims that their 
rights under the CVRA have been violated. 
Having attempted to confer with the Government about the facts in this case, counsel for 
the victims respectfully submit the following — and more complete -- set of facts that, on 
information and belief, they could establish if given the opportunity to do so: 
In 2006, at the request of the Palm Beach Police Department, the Federal Bureau of 
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Investigation opened an investigation into allegations that Jeffrey Epstein had used facilities of 
interstate commerce to induce young girls between the ages of thirteen and seventeen to engage 
in prostitution (among other offenses). The case was presented to the United States Attorney's 
Office for the Southern District of Florida, which accepted the case for investigation. Jane Doe 
#1 and Jane Doe #2 were victims of sex crimes committed by Epstein while they were minors. 
The U.S. Attorney's Office's investigation soon revealed that Epstein had committed 
federal sex crimes against Jane Doe ill and Jane Doe #2. This made Jane Doe #1 and Jane Doe 
#2 "victims" protected by the Crime Victim's Rights Act, 18 U.S.C. § 3771. Accordingly, the 
U.S. Attorney's Office arranged to have victim notification letters sent to Jane Doe #1 and Jane 
Doe #2. For example, on about June 7, 2007, Assistant U.S. Attorney A. Marie Villafafia sent a 
letter to Jane Doe #1 that began: "Pursuant to the [CVRA], as a victim and/or witness of a federal 
offense, you have a number of rights." The letter then listed the various rights of victims under 
the CVRA. The U.S. Attorney's Office would not have sent such a letter to Jane Doe #1 if it did 
not believe that she was a victim and was protected by the CVRA. 
By mid-2007, the U.S. Attorney's Office had ample information to file an indictment 
against Epstein charging multiple federal sex offenses. It elected not to file an indictment but 
instead to engage in pre-indictment plea discussions with Epstein. 
In September 2007, Epstein and the U.S. Attorney's Office reached an agreement 
blocking any federal prosecution of the federal offenses he had committed. 
This Non-
Prosecution Agreement barred federal charges for Epstein's sex offenses in favor of prosecution 
by Florida, so long as several preconditions were met. Those included a conviction on a state 
sex offense that reflected that the victims were minors at the time the crimes occurred and that 
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would require sex offender registration. 
While the Agreement barred federal criminal 
prosecution, it envisioned that the victims would pursue a civil rights action against Epstein for 
his sexual offenses against them. Most important for present purposes, the Agreement contained 
an express confidentiality provision, which prevented the Government from disclosing the terms 
of the Agreement to the victims or others before it was consummated. The Agreement was 
subsequently modified in October and December 2007. The Agreement has several addenda that 
are relevant to the Agreement. (To date, although requested to do so, the Government has 
refused to provide to the victims the final Non-Prosecution Agreement or any of its earlier 
versions.) Through his attorneys, Epstein was aware of the confidentiality provision and of the 
fact that it would block the Government from conferring with the victims about the plea 
arrangement. 
On about October 26, 2007, FBI Special Agents E. Nesbitt Kuyrkendall and Jason 
Richards met in person with Jane Doe #1 at a restaurant. The Special Agents explained that there 
had been discussions with Epstein about a possible resolution of the charges against him. 
Consistent with the express confidentiality provision in the Non-Prosecution Agreement, the 
Special Agents did not disclose that the arrangement would bar any federal prosecution of 
Epstein. Nor did the Agents disclose that the Non-Prosecution Agreement had been finalized. 
Jane Doc #1's reasonable perception of the meeting was that only the State part of the Epstein 
investigation had been resolved, and that the federal investigation would continue, possibly 
leading to a federal prosecution. (While the Government has a report of interview regarding this 
meeting with the victim that could confirm the victims' understanding of the facts, the 
Government has refused Jane Doe #1's request to see the report.) 
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Following the signing of the Non-Prosecution Agreement and the modifications thereto 
by the U.S. Attorney's Office for the Southern District of Florida, Epstein received an unusual 
benefit that the Government does not ordinarily provide to other criminal defendants: his 
performance was delayed while he was given an opportunity to seek higher level review within 
the Department of Justice in Washington, D.C. 
On around January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI 
advising them that "[t]his case is currently under investigation. This can be a lengthy process 
and we request you continued patience while we conduct a thorough investigation." The FBI 
sent these letters, under the direction of the U.S. Attorney's Office, because it believed that the 
CVRA applied to Jane Doe #1 and Jane Doe #2. The FBI did not notify Jane Doe #1 or Jane 
Doe #2 that the Non-Prosecution Agreement had been concluded four months earlier. Jane Doe 
#1 and Jane Doe #2 reasonably understood that a federal criminal investigation of Epstein was 
on-going and that federal criminal charges were possibility. At the time, Jane Doe #1 and Jane 
Doe #2 believed that criminal prosecution of Epstein was extremely important. They also 
desired to be consulted by the FBI and/or other representatives of the federal government about 
the prosecution of Epstein. In light of the letters that they had received around January 10 
(among other things), they reasonably believed that they would be contacted before the federal 
government reached any final resolution of that investigation. 
In the spring 2008, Jane Doe #1 contacted the FBI because Epstein's counsel was 
attempting to take her deposition and private investigators were harassing her. Assistant U.S. 
Attorney A. Marie Villafafia secured pro bono counsel to represent Jane Doe #1 and several other 
identified victims in connection with the criminal investigation. Pro bono counsel was able to 
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assist Jane Doe #1 in avoiding the improper deposition. AUSA Villafafla secured pro bono 
counsel by contacting Meg Garvin, Esq. of the National Crime Victims' Law Institute in 
Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. 
Garvin was not advised about the Non-Prosecution Agreement. 
In mid-June 2008, Mr. Edwards contacted Assistant U.S. Attorney Villafafia to inform her 
that he represented Jane Doe #1 and, later, Jane Doe #2. Mr. Edwards asked to meet to provide 
information about the federal crimes committed by Epstein, hoping to secure a significant federal 
indictment against Epstein. AUSA Villafafia and Mr. Edwards discussed the possibility of federal 
charges being filed. At the end of the call, AUSA Villafafia asked Mr. Edwards to send any 
information that he wanted considered by the U.S. Attorney's Office in determining whether to 
file federal charges. Because of the confidentiality provision in the Non-Prosecution Agreement, 
Mr. Edwards was not informed of the Agreement's existence. 
Mr. Edwards was also not 
informed that any resolution of the criminal matter was imminent. 
On July 3, 2008, Mr. Edwards sent to AUSA Villafafia a letter, a true and correct copy of 
which is attached as Exhibit 3. In the letter, Mr. Edwards indicated his desire that federal 
charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients: "We 
urge the Attorney General and our United States Attorney to consider the fundamental import of 
the vigorous enforcement of our Federal laws. We urge you to move forward with the traditional 
indictments and criminal prosecution commensurate with the crimes Mr. Epstein has committed, 
and we further urge you to take the steps necessary to protect our children from this very 
dangerous sexual predator." When Mr. Edwards wrote this letter, he still had not been made 
aware that a Non-Prosecution Agreement had been reached with Epstein. 
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On about July 3, 2008, Jane Doe #1 and Jane Doe #2 learned, through telephones 
conversations had between Mr. Edwards and AUSA Villafafia, that the U.S. Attorney's Office 
and Epstein might be in the process of finalizing some sort of plea arrangement. Accordingly, 
they filed an emergency motion seeking to protect their rights under the CVRA, including in 
particular their right to confer about the proposed plea arrangement. 
Mr. Edwards — and thus his clients -- first learned of the Non-Prosecution Agreement on 
or after July 9, 2008, when the Government filed its responsive pleading to Jane Doe's 
emergency petition. That pleading was the first public mention of the non-prosecution agreement 
and the first disclosure to Mr. Edwards and his clients. Epstein, through his attorneys, knew that 
the victims had not been informed about the plea arrangement. 
On July 9, 2008, AUSA Villafafia sent a victim notification to Jane Doe #1 via her 
attorney, Mr. Edwards, which is attached as Exhibit 6 to the Villafafia Declaration. That 
notification contains a written explanation of some of the terms of the Non-Prosecution 
Agreement between Epstein and the U.S. Attorney's Office. A full copy of the terms was not 
provided. This was the first time that Jane Doe #1 was told that the arrangement blocked any 
possibility of federal criminal charges being filed against Epstein. A notification was not 
provided to Jane Doe #2 because the agreement limited Epstein's liability to victims whom the 
United States was prepared to name in an indictment. 
On July I I, 2008, the Court held a hearing on the victims' emergency motion. During the 
hearing, the Government discussed in open court various provisions of the Non-Prosecution 
Agreement. At the conclusion of the hearing, victims' counsel and the Government agreed to 
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confer in an effort to determine the undisputed facts of the fact. The Court took the motion under 
advisement. 
On July 16, 2008, the Government sent to Mr. Edwards a proposed set of undisputed 
facts, which is attached to this pleading as Exhibit 1. 
On July 17, 2008, Mr. Edwards sent a response to the Government, which is attached to 
this pleading as Exhibit 2. The response made various suggestions to the proposed undisputed 
facts. The response also requested a copy of the Non-Prosecution Agreement and the Report of 
Interview with Jane Doe #1. 
On July 29, 2008, rather than attempt to work with victims' counsel to draft a set of 
undisputed facts, the Government filed its "Notice to Court Regarding Absence of Need for 
Evidentiary Hearing." 
At all times material to this statement of facts, it would have been easily practical and 
feasible for the Federal Government to inform Jane Doe # I and Jane Doe #2 of the details of any 
proposed plea agreement with Epstein, including in particular the details of the Non-Prosecution 
Agreement. The reason that AUSA Villafafla and the FBI agents acting with her did not provide 
this information to Jane Doe #1 and Jane Doe #2 was because of the express confidentiality 
provision that had been entered into by the Federal Government and Epstein. This provision 
was requested by Epstein. The Government was under no obligation to enter into such an 
arrangement and would have been statutorily forbidden from entering into such an arrangement 
by the CVRA's requirement that it "confer" with the victims about any disposition of their cases. 
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THE GOVERNMENT SHOULD BE DIRECTED TO CONFER WITH THE VICTIMS 
REGARDING THE UNDISPUTED FACTS OF THE CASE 
The Government should be directed to confer with the victims about the facts in this case, 
rather than allowed to obscure the facts with its proposed "notice" that an evidentiary hearing is 
unnecessary. The reason that the Government abruptly terminated discussions about the facts 
with the victims seem obvious: The facts, if revealed, would plainly demonstrate that the victims 
did not receive their right under the CVRA to confer with the Government and to be treated 
fairly. The victims will not repeat all of their arguments from their earlier pleadings but would 
simply highlight for the Court the point that this case already reeks of favored treatment for a 
billionaire sex offender who has substantial influence. Regardless of how the Court proceeds, it 
should at least do so on the basis of fully developed factual record so that the victims and the 
public can be assured that justice has been done. 
If anything, the facts in this case now call for immediate judgment in favor of the victims. 
Based on the Government's proposed stipulated facts (Exhibit 1 to this pleading), it is now 
obvious that the Government could not have fulfilled its statutory obligations to confer with the 
victims. As now admitted by the Government, in September 2007, it had entered into a Non-
Prosecution Agreement with Epstein containing what it describes as "an express confidentiality 
provision." While the Government has refused to disclose the text of this provision (or, indeed, 
the Non-Prosecution Agreement itself), it is apparent that the Government could not have 
conferred with the victims about the Agreement while abiding by the confidentiality provision. 
Likewise it is now apparent that the Government has not fulfilled its statutory obligation 
to treat the victims with fairness. The Government reached the Non-Prosecution Agreement with 
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Epstein in September 2007, yet affirmatively concealed that Agreement from the victims through 
a series of misleading statements and representations over the next nine months. For example, 
on around January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI advising 
them that "lijhis case is currently under investigation. This can be a lengthy process and we 
request your continued patience while we conduct a thorough investigation." As the Government 
well knew, however, a Non-Prosecution Agreement had already been reached with Epstein at that 
time — a fact not disclosed in the letter. 
The victims therefore request judgment in their favor that their rights under the CVRA 
have been violated. 
In the alternative, the victims request that the Court direct that the 
Government confer in good faith with the victims to attempt to reach a set of stipulated facts that 
might form the basis for a final ruling in this case. As part of this conference, the victims request 
that the Government indicate which (if any) of the proposed facts set forth above it disputes. 
THE GOVERNMENT SHOULD BE REQUIRED TO PRQDUCE 
THE NON-PROSECUTION AGREEMENT 
Remarkably, the Government has yet to disclose to the victims the very Non-Prosecution 
Agreement that lies at the heart of this case. This failure becomes even more curious when 
assessed against the Government's proposed stipulation of facts, which included the proposed 
fact that the victims had been told about the "full terms" of the Agreement. The proposed 
stipulated facts that the Government sent to the victims included this proposed stipulation: 
On July 9, 2008, AUSA Villafafla sent a victim notification to Jane Doe #1 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. 
Contrary to its own proposed stipulation, the Government has never disclosed to the victims the 
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"full terms" of its Non-Prosecution Agreement with Epstein. To protect the victims' right to be 
treated with fairness, 18 U.S.C. § 3771(a)(8), it should be required to do so now. 
Congress' main concern in passing the CVRA was that crime victims were "treated as 
non-participants in a critical event in their lives. They were kept in the dark by prosecutors too 
busy to care enough ... and by a court system that simply did not have a place for them." 150 
CONG. REc. S4262 (Apr. 22, 2004) (statement of Sen. Feinstein). To remedy this problem, 
Congress gave victims "the simple right to know what is going on, to participate in the process 
where the information that victims and their families can provide may be material and relevant ... 
." Id. To date, Jane Doe #1 and Jane Doe #2 do not know what has happened to their case, 
because they have not been told how it has been resolved. Of course, no possible harm to the 
Government can come from the release of the Agreement, as this criminal matter is now 
concluded — at least from the Government's perspective. 
Production of the Non-Prosecution Agreement is also warranted because it has provisions 
in it that are designed to benefit Jane Doe #1 and Jane Doe #2. As described by the Government, 
the Agreement contains provisions in it that preclude Epstein from contesting civil liability for 
the sex offenses committed against a number of the victims, including Jane Doe ill. Obviously, 
Jane Doe #1 cannot take advantage of this provision if her attorneys are not able to review it. 
Jane Doe #1 and Jane Doe #2 intend to file civil suits against Epstein within the next few days. 
Epstein knows what is in the Non-Prosecution Agreement that may be helpful to him. Jane Doe 
#1 and Jane Doe #2 are entitled to see the Agreement for items that may be helpful to them. 
Finally, Epstein is apparently taking advantage of provisions in the Non-Prosecution 
Agreement to stall civil suits against him. For example, in Jane Doe'. Epstein et al., No. 08-
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80804-MARRA/JOHNSON (S.D. Fla. 2008), on July 25, 2008, Epstein filed a motion for a stay. 
That motion claims that the civil action is "a counterpart to a pending federal criminal action." 
The basis for that claim, so far as Jane Doe #1 and Jane Doe #2 can tell, is the federal Non-
Prosecution Agreement. Epstein should not be permitted to use provisions in the Agreement to 
his advantage in private litigation without disclosing those provisions to the parties he is 
opposing. Indeed, as a simple matter of fairness to the victims, see 18 U.S.C. § 3771(a)(5) 
(victims right to "fairness"), the provisions should be disclosed. 
In sum, the Court should direct the Government to reveal to the victims what it has done 
to resolve the case by ordering production of the full Non-Prosecution Agreement and any 
accompanying addenda to the agreement. 
THE GOVERNMENT SHOULD BE REQUIRED TO PRODUCE THE REPORT OF 
INTERVIEW WITH JANE DOE # I 
The Government apparently has a report of interview indicating that two named FBI 
agents met with Jane Doe #1 on about October 26, 2007. The Government, however, has 
declined to produce it. 
The Government should be directed to produce this information to Jane Doe #1. Of 
course, a criminal defendant would be entitled to such a report. See Fed. R. Crim. P. 16(a)(1)(A) 
& (B). As an innocent victim in this matter, Jane Doe #1 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"). Jane 
Doe #1 requested this report in her letter regarding the proposed stipulated facts (see Exhibit 2 to 
this filing), a request that the Government has simply ignored. 
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AFTER ENTERING JUDGMENT FOR THE VICTIMS' ON THE VIOLATION OF THEIR 
RIGHTS, THE COURT SHOULD SCHEDULE A HEARING ON THE APPROPRIATE 
REMEDY 
For the reasons just explained, the Court should enter judgment for Jane Doe #1 and Jane 
Doe #2 on the violations of their rights under the CVRA and order the Government to produce 
the Non-Prosecution Agreement and the report of interview with Jane Doe #1. After doing that, 
the question then arises as to what is the proper remedy for the violations of victims' rights. 
To be clear, at this time, the victims seek two things: (1) a judicial declaration that the 
Government violated their rights under the CVRA and an apology from the Government; and (2) 
a hearing to discuss the appropriate remedy under the circumstances. At the same time, the 
victims are not asking to have any provision in the Non-Prosecution Agreement establishing 
liability in a civil suit to be vacated or declared invalid. 
Because the possible connection 
between these two things raises complex legal issues, the victims respectfully request that the 
Court order a hearing at which the appropriate remedy can be discussed. The victims also need 
to review the full text of the Non-Prosecution Agreement and any accompanying addenda to 
make an appropriate determination about the remedy that they wish to pursue. 
CONCLUSION 
The Court should find that the Government violated Jane Doe #1 and Jane Doe #2's 
rights under the CVRA to confer and to be treated with fairness during the negotiation and 
consummation of the Non-Prosecution Agreement. In the alternative, the Court should direct the 
Government to confer with the victims regarding what facts are undisputed in this matter and, 
should material facts actually be disputed, hold an evidentiary hearing regarding those facts. So 
that the victims can discuss these matters with the Government, the Court should order the 
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Government to provide to the victims the full Non-Prosecution Agreement (and accompanying 
addenda) that is central to this litigation as well as a report of interview with Jane Doe #1 from 
about October 26, 2007. The Court should then hold a hearing on the proper remedy for the 
violations of the victims' rights. 
DATED this I st day of August, 2008. 
Respectfully Submitted, 
THE LAW OFFICE OF BRAD EDWARDS & 
ASSOCIATES, LLC 
By: 
s/ Brad Edwards 
Brad Edwards, Esquire 
Attorney for Petitioners 
Florida Bar No. 542075 
2028 
Street 
Suite 202 
Hollywood, Florida 33020 
Telephone: 
954-414.8033 
Facsimile: 
954-924-1530 
E-Mail: 
beQbradedwardslaw.com 
Paul G. Cassell 
Attorney for Petitioners 
Pro Hac Vice 
332 S. 1400 E. 
Salt Lake City, UT 84112 
Telephone: 
801-585-5202 
Facsimile: 
801-585-6833 
E-Mail: 
casselln@law.utah.edu 
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CERTIFICATE OF SERVICE 
! HEREBY CERTIFY that on August 1, 2008, I electronically filed the foregoing 
document with the Clerk of the Court using CM/ECF. 
s/ Brad Edwards 
Brad Edwards, Esquire 
Attorney for Petitioner 
Florida Bar No. 542075 
SERVICE LIST 
Jane Doe 1 and Jane Doe 2 
Case No.: 08-80736-CIV-MARRA/JOHNSON 
United States District Court, Southern District of Florida 
Dexter A. Lee, 
Assistant U.S. Attorney 
99 N.E. 4th Street 
Miami, Florida 33132 
Telephone: 
305-961-9320 
Facsimile: 
305-530-7139 
16 
EFTA00190612

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.gov> 
Sent: 
Tuesday, August 05, 2008 6:35 PM 
To: 
Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen 
(USAFLS) 
Subject: 
FW: Jeffrey Epstein Agreement 
Attachments: 
Epstein Agrmt001.pdf 
Hi everyone — I still haven't heard from Roy, but in the meantime, I have been looking for correspondence that 
could be described as an assent to the modification in the December letter. 
First, as set forth below, prior to the change of plea, we informed Epstein's counsel that we took the position 
that we already have a binding agreement and that nothing further was required. (This was a June 24 e-mail) 
Dear Roy and Jack: 
I am just writing to re-state that it is the Government's position that we have a signed, binding agreement and 
that there is no need for further modification. 
Please keep us informed of the date and time of the change of plea and sentencing. 
Thank you. 
We took the same position in the e-mails that Jeff and I sent to Jay Lefkowitz notifying him of Epstein's need to 
promptly perform their obligations following the various DOJ decisions. This was the language we used: 
Dear Mr. Lefkowitz: 
I understand that the Deputy Attorney General has completed his review of the Epstein matter and has 
determined that federal prosecution of Mr. Epstein's case is appropriate. 
Accordingly, Mr. Epstein has until the close of business on Monday, June 30, 2008, to comply with the terms 
and conditions of the agreement between the United States and Mr. Epstein (as modified by the U.S. Attorney's 
December 19th letter to Ms. Sanchez), including entry of a guilty plea, sentencing, and surrendering to begin his 
sentence of imprisonment. 
If you have any questions, please feel free to contact me at the number shown below. 
(This was sent on June 23n° to Jay and June 24th to Roy.) Following this correspondence, Epstein entered his 
guilty plea. 
On June 30th, a couple of hours after the change of plea, the agents and I went to Jack Goldberger's office and 
met with Jack and Mike Tein. We provided them with the proposed Notification of Identified Victims. On the 
first page of that notice, we wrote the following: 
In light of the entry of the guilty plea and sentence, the United States has agreed to defer 
federal prosecution in favor of this state plea and sentence, subject to certain conditions. 
22 
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One such condition to which Epstein has agreed is the following: 
"Any person, who while a minor, was a victim of a violation of an offense enumerated 
in Title 18, United States Code, Section 2255, will have the same rights to proceed 
under Section 2255 as she would have had, if Mr. Epstein had been tried federally and 
convicted of an enumerated offense. For purposes of implementing this paragraph, 
the United States shall provide Mr. Epstein's attorneys with a list of individuals whom 
it was prepared to name in an Indictment as victims of an enumerated offense by Mr. 
Epstein. Any judicial authority interpreting this provision, including any authority 
determining which evidentiary burdens if any a plaintiff must meet, shall consider that 
it is the intent of the parties to place these identified victims in the same position as 
they would have been had Mr. Epstein been convicted at trial. No more; no less." 
On July 9, 2008, Jack Goldberger wrote me a letter with some objections to the Proposed 
Notification. Although he had several requests for changes, he stated: "Rather, a simple one page notification 
directed only to the recipient, and limited to the information currently on the first page ofyour draft 
memorandum would suffice." 
This, to me, is a written assent that the quoted language is, in fact, one of the conditions to which Epstein has 
agreed. So, I think that we do have a written, binding agreement comprised of the three documents that, as far 
as I know, were filed with the state court with Jack Goldberger's approval. (I am waiting to hear back from the 
ASA.) 
Here again is what I provided to the State Attorney's Office, for your records. 
«Epstein Agrmt001.pdf» 
I am concerned that we were adamant before Epstein's plea that we had a complete agreement and nothing 
more was necessary and now taking the position that we do not have an operative document (or set of 
documents). 
Alex, does the Black and Goldberger correspondence described above allay your concerns? Or would you still 
like me to raise this issue with Roy whenever he gets back to me? 
Thank you, sorry for the lengthy e-mail. 
A. Marie Villafalfa 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
From: Villafana, Ann Marie C. (USAFLS) 
23 
EFTA00190614

Sent: Tuesday, June 24, 2008 4:05 PM 
To: 'Roy BLACK'; 'Jack Goldberger' 
Cc: Atkinson, Karen (USAFLS) 
Subject: Jeffrey Epstein Agreement 
Dear Roy and Jack: 
I am just writing to re-state that it is the Government's position that we have a signed, binding agreement and 
that there is no need for further modification. 
Please keep us informed of the date and time of the change of plea and sentencing. 
Thank you. 
A. Marie Villafafia 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
24 
EFTA00190615

IN RE: 
INVESTIGATION OF 
JEFFREY EPSTEIN 
NON-PROSECUTION AGREEMENT 
IT APPEARING that the City of Palm Beach Police Department and the State 
Attorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, 
the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey 
Epstein (hereinafter "Epstein"); 
IT APPEARING that the State Attorney's Office has charged Epstein by indictment 
with solicitation of prostitution, in violation of Florida Statutes Section 796.07; 
IT APPEARING that the United States Attorney's Office and the Federal Bureau of 
Investigation have conducted their own investigation into Epstein's background and any 
offenses that may have been committed by Epstein against the United States from in or 
around 2001 through in or around September 2007, including: 
(1) 
knowingly and willfully conspiring with others known and unknown to 
commit an offense against the United States, that is, to use a facility or means 
of interstate or foreign commerce to knowingly persuade, induce, or entice 
minor females to engage in prostitution, in violation of Title 18, United States 
Code, Section 2422(b); all in violation of Title 18, United States Code, Section 
371; 
(2) 
knowingly and willfully conspiring with others known and unknown to travel 
in interstate commerce for the purpose of engaging in illicit sexual conduct, as 
defined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18, 
United States Code, Section 2423(b); all in violation of Title 18, United States 
Code, Section 2423(e); 
(3) 
using a facility or means of interstate or foreign commerce to knowingly 
persuade, induce, or entice minor females to engage in prostitution; in 
violation of Title 18, United States Code, Sections 2422(b) and 2; 
(4) 
traveling in interstate commerce for the purpose of engaging in illicit sexual 
conduct, as defined in 18 U.S.C. § 2423(f), with minor females; in violation 
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of Title 18, United States Code, Section 2423(b); and 
(5) 
knowingly, in and affecting interstate and foreign commerce, recruiting, 
enticing, and obtaining by any means a person, knowing that the person had 
not attained the age of 18 years and would be caused to engage in a 
commercial sex act as defined in 18 U.S.C. § 1591(cX1); in violation of Title 
18, United States Code, Sections 1591(a)(1) and 2; and 
IT APPEARING that Epstein seeks to resolve globally his state and federal criminal 
liability and Epstein understands and acknowledges that, in exchange for the benefits 
provided by this agreement, he agrees to comply with its terms, including undertaking certain 
actions with the State Attorney's Office; 
IT APPEARING, after an investigation of the offenses and Epstein's background by 
both State and Federal law enforcement agencies, and after due consultation with the State 
Attorney's Office, that the interests of the United States, the State of Florida, and the 
Defendant will be served by the following procedure; 
THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for 
the Southern District of Florida, prosecution in this District for these offenses shall be 
deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the 
following conditions and the requirements of this Agreement set forth below. 
If the United States Attorney should determine, based on reliable evidence, that, 
during the period of the Agreement, Epstein willfully violated any of the conditions of this 
Agreement, then the United States Attorney may, within ninety (90) days following the 
expiration of the term of home confinement discussed below, provide Epstein with timely 
notice specifying the condition(s) of the Agreement that he has violated, and shall initiate its 
prosecution on any offense within sixty (60) days' of giving notice of the violation. Any 
notice provided to Epstein pursuant to this paragraph shall be provided within 60 days of the 
United States learning of facts which may provide a basis for a determination of a breach of 
the Agreement. 
After timely fulfilling all the terms and conditions of the Agreement, no prosecution 
for the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have 
been the subject of the joint investigation by the Federal Bureau of Investigation and the 
United States Attorney's Office, nor any offenses that arose from the Federal Grand Jury 
investigation will be instituted in this District, and the charges against Epstein if any, will be 
dismissed. 
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