This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →
FBI VOL00009
EFTA00233329
549 pages
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Case 9:08-cv-80811-KAM Document 33 Entered on FLSD Docket 01/07/2009 Page 19 of 41 discovery in this civil case, until the final conclusion of the Federal Criminal Action. Conclusion Because this lawsuit arises from the same allegations as the Federal Criminal Action, this Court should stay this lawsuit until that action is no longer pending, Respectfully submitted, LEWIS TEIN, P.L. By: A. LEWIS EW ATTERBURY, GOLDBERGER & WEISS, P.A. By: Jack A. Goldberger Attorneys for Defendant Jeffrey Epstein 19 Lewis 'reins 3059 &oho AvEreue. SunE 340. COCONUT GAM. Flown 33133 EFTA00233849
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Case 9:08-cv-80811-KAM Document 33 Entered on FLSD Docket 01/07/2009 Page 20 of 41 EXHIBIT A EFTA00233850
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Case 9:08-cv-80811-KAM Document 33 Entered on FLSD Docket 01/07/2009 Page 21 of 41 Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008 Page 1 of 21 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson IN RE: JANE DOE, Petitioner. FILED by Mt, D.C. JUL 0 9 2008 TAM.Dist I.O. Of FLA -WO& DECLARATION OF A. IN SUPPORT OF UNITED STATES' RESW LQy , I Lcnmsziuict jriQimMT!ni fficEAIM QF CRIME VICTIM RIGHTS ACT, 18 U.S.C. § 3771 hereby declare that I am a member in good standing of the liar of the State of Florida. I graduated from the University of California at Berkeley School of Law (Boalt Hall) in 1993. After serving as a judicial clerk to the Hon. David F. Levi in Sacramento, California, I was admitted to practice in California in 1995. I also am admitted to practice in all courts of the states of Minnesota and Florida, the Eighth, Eleventh, and Federal Circuit Courts of Appeals, and the U.S. District Courts for the Southern District of Florida, the District of Minnesota, and the Northern District of California. My bar admission status in California and Minnesota is currently inactive. I am currently employed as an Assistant United. States Attorney in the Southern District of Florida and was so employed during all of the events described herein. 9/0 EFTA00233851
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Case 9:08-cv-80811-KAM
Document 33
Entered on FLSD Docket 01/07/2009
Page 22 of 41
Case 9:08-cv-80736-KAM
Document 14
Entered on FLSD Docket 07/15/2008
Page 2 of 21
2.
1 am the Assistant United States Attorney assigned to the investigation of
Jeffrey Epstein. lie case was investigated by the Federal Bureau of Investigation ("FBI").
The federal investigation was initiated in 2006 at the request of the Palm Beach Police
Department ("PBPD") into allegations that Jeffrey Epstein and his personal assistants had
used facilities of interstate commerce to induce young girls between the ages of thirteen and
seventeen to engage in prostitution, amongst other offenses.
3.
Throughout the investigation, when a victim was identified, victim notification
letters were provided to her both from your Affiant and from the FBI's Victim-Witness
Specialist. Attached hereto are copies of the letters provided to Bradley Edwards' three
clients, T.M., C.W., and S.R.' Your Affiant's letter to C.W. was provided by the FBI. (Ex.
1). Your Affiant's letter to T.M. was hand-delivered by myself to T.M. at the time that she
was interviewed (Ex. 2).2 Both C.W. and T.M. also received letters from the FBI's Victim-
Witness Specialist, which were sent on January 10, 2008 (Exs. 3 & 4). S.R. was identified
via the FBI's investigation in 2007, but she initially refused to speak with investigators.
S.R.'s status as a victim of a federal offense was confirmed when she was interviewed by
'Attorney Edwards filed his Motion on behalf of "Jane Doe," without identifying which of
his clients is the purported victim. Accordingly, I will address facts related to C.W., T.M., and S.R.
All three of those clients were victims of Jeffrey Epstein's while they were minors beginning when
they were fifteen years old.
'Please note that the dates on the U.S. Attorney's Office letters to C.W. and T.M. are not the
dates that the letters were actually delivered. Letters to all known victims were prepared early in the
investigation and delivered as each victim was contacted.
-2-
EFTA00233852
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Case 9:08-cv-80811-KAM
Document 33
Entered on FLSD Docket 01/07/2009
Page 23 of 41
Case 9:08-cv-80736-KAM
Document 14
Entered on FLSD Docket 07/15/2008
Page 3 of 21
federal agents on May 28, 2008. The FBI's Victim-Witness Specialist sent a letter to S.R.
on May 30, 2008 (Ex. 5).
4.
Throughout the investigation, the FBI agents, the FBI's Victim-Witness
Specialist, and your A Mani had contact with C.W. and S.R. Attorney Edwards' other client,
T.M., was represented by counsel and, accordingly, all contact with T.M. was made through
that attorney. That attorney was James Eisenberg, and his fees were paid by Jeffrey Epstein,
the target of the investigation.'
5.
In the summer of 2007, Mr. Epstein and the U.S. Attorney's Office for the
Southern District of Florida ("the Office") entered into negotiations to resolve the
investigation. At that time, Mr. Epstein had been charged by the State of Florida with
solicitation of prostitution, in violation of Florida Statutes § 796.07. Mr. Epstein's attorneys
sought a global resolution of the matter. The United States subsequently agreed to defer
federal prosecution in favor of prosecution by the State of Florida, so long as certain basic
preconditions were met. One of the key objectives for the Government was to preserve a
federal remedy for the young girls whom Epstein had sexually exploited. Thus, one
condition of that agreement, notice of which was provided to the victims on July 9, 2008, 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
'The undersigned does not know when Mr. Edwards began representing T.M. or whether
T.M. ever formally terminated Mr. Eisenberg's representation.
-3-
EFTA00233853
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Case 9:08-cv-80811-KAM Document 33 Entered on FLSD Docket 01/07/2009 Page 24 of 41 Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008 Page 4 of 21 %leo \sor 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." 6. An agreement was reached in September 2007. The Agreement contained an express confidentiality provision. 7. Although individual victims were not consulted regarding the agreement, several had expressed concerns regarding the exposure of their identities at trial and they desired a prompt resolution of the matter. At the time the agreement was signed in September 2007, T.M. was openly hostile to the prosecution of Epstein. The FBI attempted to interview S.R. in October 2007, at which time she refused to provide any information regarding Jeffrey Epstein. None of Attorney Edwards' clients had expressed a desire to be consulted prior to the resolution of the federal investigation. 8. As explained above, one of the terms of the agreement deferring prosecution to the State of Florida was securing a federal remedy for the victims. In October 2007, shortly after the agreement was signed, four victims were contacted and these provisions were discussed. One of those victims was C.W. who at the time was not represented, and she was given notice of the agreement. Notice was also provided of an expected change of pica in October 2007. When Epstein's attorneys learned that some of the victims had been EFTA00233854
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Case 9:08-cv-80811-KAM Document 33 Entered on FLSD Docket 01/07/2009 Page 25 of 41 Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008 Page 5 of 21 \Of notified, they complained that the victims were receiving an incentive to overstate their involvement with Mr. Epstein in order to increase their damages claims. While your Affiant knew that the victims' statements had been taken and corroborated with independent evidence well before they were informed of the potential for damages, the agents and I concluded that informing additional victims could compromise the witnesses' credibility at trial if Epstein reneged on the agreement. 9. After C.W. had been notified of the terms of the agreement, but before Epstein performed his obligations, C.W. contacted the FBI because Epstein's counsel was attempting to take her deposition and private investigators were harassing her. Your Affiant secured pro bono counsel to represent C.W. and several other identified victims. Pro bono counsel was able to assist C.W. in avoiding the improper deposition. That pro bono counsel did not express to your Affiant that C.W. was dissatisfied with the resolution of the matter. 10. In mid-June 2008, Attorney Edwards contacted your Affiant to inform me that he represented C.W. and S.R. and asked to meet to provide me with information regarding Epstein. I invited Attorney Edwards to send to me any information that he wanted me to consider. Nothing was provided. I also advised Attorney Edwards that he should consider contacting the State Attorney's Office, if he so wished. I understand that no contact with that office was made. Attorney Edwards had alluded to T.M., so I advised him that, to my knowledge, T.M. was still represented by Attorney James Eisenberg. -5- EFTA00233855
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Case 9:08-cv-80811-KAM Document 33 Entered on FLSD Docket 01/07/2009 Page 26 of 41 Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008 Page 6 of 21 ••••• 1*.mor II. On Friday, June 27, 2008, at approximate 4:15 p.m., your Affiant received a copy of the proposed state plea agreement and learned that the plea was scheduled for 8:30 u.m., Monday, June 30, 2008. Your Affiant and the Palm Beach Police Department attempted to provide notification to victims in the short time that Epstein's counsel had given us. Although all known victims were not notified, your Affiant specifically called attorney Edwards to provide notice to his clients regarding the hearing. Your Affiant believes that it was during this conversation that Attorney Edwards notified me that he represented T.M., and I assumed that he would pass on the notice to her, as well. Attorney Edwards informed your Affiant that he could not attend but that someone would be present at the hearing. Your Affiant attended the hearing, but none of Attorney Edwards' clients was present. 12. On today's date, your Affiant provided the attached victim notifications to C.W. and S.R. via their attorney, Bradley Edwards (Exs. 6 & 7). A notification was not provided to T.M. because the U.S. Attorney's modification limited Epstein's liability to victims whom the United States was prepared to name in an indictment. In light of T.M.'s prior statements to law enforcement, your Affiant could not in good faith include T.M. as a victim in an indictment and, accordingly, could not include her in the list provided to Epstein's counsel. 13. Furthermore, with respect to the Certification of Emergency, Attorney Edwards did not ever contact me prior to the filing of that Certification to demand the relief that he requests in his Emergency Petition. On the afternoon of July 7, 2008, after your Affiant had -6- EFTA00233856
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Case 9:08-cv-80811-KAM Document 33 Entered on FLSD Docket 01/07/2009 Page 27 of 41 Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008 Page 7 of 21 already received the Certification of Emergency and Emergency Petition, I received a letter from Attorney Edwards that had been sent, via Certified Mail, on July 3, 2008. While that letter urges the Attorney General and the United States Attorney to consider "vigorous enforcement" of federal laws with respect to Jeffrey Epstein, it contains no demand for the relief requested in the Emergency Petition. 14. I declare under penalty of perjury, pursuant to 28 U.S.C. § 1746 that the foregoing is true and correct to the best of my knowledge and belief. Executed this day of July, 2008. -7- EFTA00233857
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Case 9:08-cv-80811-KAM Document 33 Entered on FLSD Docket 01/07/2009 Page 28 of 41 Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/20 U.S. Department of Justice United States Attorney Southern District of Florida $00 South Ausiraloan Ave. &MO 400 Wen Palm Beach. FL 33401 (561)810.8711 Facsimile- MO 820877? June 7, 2007 DELIVERY BY HAND Miss 0.111111 Re: Crime Victims' and Witnesses' Rights Dear Miss 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 nghts arc: (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 are present for other portions of a proceeding. (4) The nglit 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. I Members of tie U.S. Department of Justice and other federal investigative agencies, including the Federal Bureau of Investigation, must use their best effons to make sure that I Tweeted. If you VP anv concerns in this regard, please feel free to contact me at or Special Agen "tom-the Federal Bureau of Investigation at You als -can contact 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 rigl;ex listed above and, if you believe that the lights set forth above are being violated, you have the right to petition the Court for relief. EFTA00233858
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Case 9:08-cv-80811-KAM Document 33 Entered on FLSD Docket 01/07/2009 Page 29 of 41 Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008 Page 9 of 21 ••••• •••••' miss JuNE 7, 2007 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 arc a victim, you also may be entitled to restitution lion 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 Agin or myself immediately. It is possible that someone working on behalf of the targetslo ielkation may contact you. Such contact does not viola:guise law.- However, if you are contacted, you have the choice of speaking to that person or refusing teclo so.' If you refuse and feel that you are being threatened or harassed, then please contact Special Agent r myself You also are entitled to notification of upcoming case events. At this time, your case is under invesuganon, If anyone is charged in connection with the investigation, you will be notified. Sincerely, R Alexander Acosta United States Attorney By: Assistant United States Attorney cc: Special Agent .B.I. EFTA00233859
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Case 9:08-cv-80811-KAM Document 33 Entered on FLSD Docket 01/07/2009 Page 30 of 41 Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/200 U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australum Ave.. Suite 400 West Palm Beach. FL 33401 O6O820-8711 Facsimile (361)820-8777 August I I, 2006 DELIVERY BY HAND Miss Tea Re: Crime Victims' and Witnesses' Righl Dear Miss I Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense, you have a number of nghts. Those rights are: (1) 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 pmcecding, unless the court determ'nes that your testimony may be materially altered if you are present for other 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 re;.sonabte 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. f Members of the U.S. Department of Justice and other firieral investigative agencies, including the Federal Bureau of Investigation, must use their best efforts to make sure that these rights are protected. If you have any concerns in this regard, please feel free to contact me al or Special AgentSm 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 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 rights iet forth above are being violated, you have the right to petition the Court for relief EFTA00233860
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Case 9:08-cv-80811-KAM Document 33 Entered on FLSD Docket 01/07/2009 Page 31. of 41 Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008 Page 11 of 21 misa At ICUS r 11, 2006 PAGE 2 In addition to these rights, you are entitled to counseling and medical services, and t., from intimidation and harassment. If the Court determines that you are a victim, you ..I. entitled to restitution from the perpetrator. A list of counseling and medical service pit, . be provided to you, if you so desire. If y or ur family is subjected to any intw harassment, please contact Special Agent or myself immediately. It is somconc working on behalf of the targets of the investigation may contact you. Such c'. • not violate the law. However, if you are contacted, you have the choice of speaking in ii . or refusing to do so. If you refuse and feel that you are being threatened or harassed, it.: Contact Special Agent or myself. You also arc entitled to notification of upcoming case events. At this time, you • investigation. If anyone is charged in connection with the investigation, you will he ii.i• Sincerely, R. Alexander Acosta United States Attorney cc; Special Agent By Assistant United States Attorney F.B.I. EFTA00233861
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Case 9:08-cv-80811-KAM Document 33 Entered on FLSD Docket 01/07/2009 Page 32 of 41 Case 9;08-py-89.7§§-KAM Document 14 Entered on FLSD Docket oulazonas. Paget,12,,of 21 U.S. Department of Justice Federal Bureau of Investigation FBI - West Palm Beath Suite 500 505 South Fleeter Drive West Palm Beech, FL 33401 Phone: (561) 633-7517 Fax: (561) 033-7970 January /0, 2006 ay case Number.. De- olts Case is currently under Investigation. This can be a lengthy process and we request your continued patience while we conduct a thorough Investigation. As a aims victim. you have the following rights under 18 United States Code § 3771: (1) The right to be masons* protected from the accused; (2) The right to reasonable, accurate, end timely notice of any pubno coin proceeding, or any parole proceeding, involving me dime or of any release or escape or the accused; (3) The right not to be excluded from any suds public court proceeding, thins the court, after receiving dear and convincing evidence, determines that testimony by the victim would be mate:May altered ri the viCtim heard other testimony et that proceeding; (4) The right to be reasonably heard al any public proceeding In the district court involving release, plea, sentencing, or any parole proceeding: (5) The reasonable tight to confer with the attorney (or the Government In the case; (6) The right to Na and timely restitution as provided in law; (7) The right to proceedings free horn urreasoneble delay; (8) The right lobe treated with fairness and with reaped for the victim's dignity and privacy. We wet make our best efforts to ensure you an accorded the rights described. Moat of these rights pertain to events occurring after the arrest or indictment of en individual for the crime, and it wit become the responsibility of the prosecuting United States Attorney's Office to ensure you ere accorded those rights. You may also seek the advice of a private attorney with respect to these rights. The Victim Notification System (VHS) is designed to provide you with eked information regarding the rose es it proceeds through the criminal Justice system. You may obtain current Information about this matter on the Internet el WWW.Nodfy.USPOJ.GOV or from tie VN6 Call Center at14366-D0J-4YOU (1-865-385- 40358) (TDOTITY: 1-668-228-4819) (International: 1.502.213-2767). In addition, you may use the Cell Center or Internet to µodete your contact information and/or change your decision about participation in the notification program. If you update your information to Include a current email aileron. VNIsilliaficl information to that seeress. You MI niagjia following lnclim Identification Number (VIN) 'and Personal Identification Number (PIN) anytime you contact the Call Center and the first time you log on to VNS on the intermit. In addition, the first time you access the VNS Internet site, you ittlI be prompted to enter your last name (or business name) es currently contained in VNS. The name you Should enter is a EFTA00233862
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Case 9:08-cv-80811-KAM Document 33 Entered on FLSD Docket 01/07/2009 Page 33 of 41 Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07P15/20t)8""Pagre Ilbt 21 If you have additional I:volition& Mitch Involve this matter, please contact the office listed ebove. When you cal, please provide the Ille number totaled at the top of this letter. Please remember, your partidpation in the notification pan of this program is voluntary. In order to continue to receNe notifications, it Is your responsibility to keep your contact Information current 5.ncerely. EFTA00233863
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Case 9:08-cv-80811-KAM Document 33 Entered on FLSD Docket 01/07/2009 Page 34 of 41 Case 9:0&cv-80736-KAM Document 14 Entered on FLSD Docket 07041/45/Q.008,,, Page ottlrot 21 ••••••1 ••••0 U.S. Department of Justice Federal Bureau of investigation FBI - West Palm Beech Suite 600 505 South Filmier Drive west Palm Beach, FL 33401 Phone: (581) 833-7517 Fax: (581) 633-7970 January 10. 2008 James Llsenberg One Cleanake Center Ste 704 Australian South West Palm Beach. FL 33401 Re. Dear James Eisenberg: You have requested to receive notifications for T.MMUS This case is umenay under InvestIgation. This can be a lengthy process and we request your continued patience while we conduct a thorough investgatIon. Asa crime victim, you have the following rights under 16 United States Coda § 3771: (1) The right to be reasonably protected fmm the accused: (2) The right to reasonable, accurate, and timely notice of any public court proceeding, or any parole proceeding, InvoNing the crime or of any release or escape of the accused; (3) The right not to be excluded from any such public court proceeding. unless the court. after receiving dear and convincing evidence, dotemilnes that testimony by the victim would be materially altered If the victim heard other testimony at that proceeding; (4) The right to be reasonably heard at any public proceeding In the district court involving release, plea, sentencing, or any parole proceeding; (5) The reasonable right to confer with the attorney for the Government in the case; (6) The right to full and timely restitution as provided In law; (7) The right to proCetdIngS free from unreasonable delay: (8) The right to be treated with fairness and with rasped for the victim's dignity and privacy. We will make our best efforts to ensure you are accorded the rights descnbed. Most of these nghts pertain to events occuning after the arrest or Indictment of an Individual for the crime, and It will become the responsibility of the prosecuting United States Attorney's Office to ensure you we accorded those rights. You may also seek the advice of a private attorney with respect to these rights. The Victim NottficatiOn System (VNS) is designed to provide you with direct Information regarding the case as It proceeds through the criminal Justice system. You may obtain current IMormatbn about this matter on the Internet at WWW,Nottfy.USDO.J.DOV or from the VNS Call Cantor at 1-866-D0J-4YOU (1-886-365- 4966) (1 DD/TTY: 1.868.228.4619) (International: 1.602.213.2767). In addition, you may use the Cell Center or Internet to yodels your contact inforrneeon erxlior change your deolaton about participation in the nouficebon program. If you update your Information to Include a current emel address. VHS will send information to that address. You will need the following Victim Identification Number (VIN) end Personal Identification Number (RINIM anytime you contact the Cali Center end thefirst e you log onto VNS on the Internet. In addition. the first time you access the VNS Internet site you will be prompted lo enter your lest name (or business name) as currently contained in VNS. The name you should enter is Eisenberg. EFTA00233864
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Case 9:08-cv-80811-KAM Document 33 Entered on FLSD Docket 01/07/2009 Page 35 of 41 Case 9:08-0180736-KAM Document 14 Entered on FLSD Docket 07#46/2S08,D4Page clzatf 21 It you have adenine, Clue!Mona whICti Involve this matter, please contact the office Muted above. Whon you call, please provide the nie number totaled at the top of this letter. Please remember, your parOcipabon in the roPlateattorl part of this PrOPritM IS voluntary. In order to continue to receive notelcallons. his your reSpOnsIbIllty to keep your contact Information current. Sincerehi, Victim Specialist EFTA00233865
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Case 9:08-cv-80811-KAM Document 33 Entered on FLSD Docket 01/07/2009 Page 36 of 41 Case 9:06:cv-80736-KAM Document 14 Entered on FLSD Docket 0-7M5120 µay 30. 2008 Re: Des U.S. Department of Justice Federal Bureau of Investigation FBI • West Palm Beach Suite 600 505 South Fleeter Drive West Palm Beach, FL 33401 Phone: (661) 833-7517 Fag: (561) B33-7970 Your name was referred to the Fars Victim Assistance Program as being a possible victim of a federal crime. We appreciate your assistance and cooperation while we ere Investigating this case. We would like to make you aware of the victim services that may be available to you and to answer any questions you may have regarding the criminal justice process througneut the Investigation. Our program is part of the FBI's effort to ensure the victims are treated with respect and are provided information about their rights under federal law. These rights Include notification of the status of the case. The enclosed brochures provide Information about the Fars Victim Assistance Program, resources and instructions for accessing the Victim Notification System (YNS). VNS Is designed to provide you with information regarding the status of your case. This case Is currently under Investigation. This can be a lengthy process and we request your continued patience while we conduct a thorough investigation. As a came victim, you hove the following rights under 18 United Stales Code § 3771: (1) The right to be reasonably protected from the accused; 12) The right to reasonable, accurate, end timely notice of any public court proceeding, or any parole proceeding, involving the crime or of any relies° or escape of the accused; (3) The right not to be excluded from any such 'iliac court proceeding, unless the court, after receiving dear and convincing evidence, determines that testimony by the victim would be materialty altered It the victim heard other testimony at that proceeding: (4) TM right to be reasonably heard at any public proceeding in the district court Involving release, plea, sentencing, or any parole proceeding; (5) The reasonable right to center with the attorney for the Government in the case; (6) The right to full and timely restitution as provided 11 law; (7) The right to proceedings free from unreasonable delay; VII The right to be heated with fairness and with respect for the victim's dignity and privacy. We Will make our best efforts to ensure you ere accorded the rights described. Most of these rights pertain to events occurring after the arrest or indictment of an Individual for the crime. and it will become the responsibility of the prosecuting United States Attorneys Office to ensure you are accorded those rights. You may also seek the advice of e private attorney with respect to these rights. The Victim Notification System (VHS) Is designed to provide you with direct information regarding the case as it proceeds through the criminal justice system. You may obtain current information about this matter on the Internet at WWVI'.NotilY.USDOJ GOV or horn the VNS Cell Center at 1.866-DOJJYQU (1-886-365- 4968) (TDDrITY71-866-228-4619) (International: 1-602.213.2767). In addition, you may use the Call Center or Internet to update your contact Information androt change your decision about participation in the notification program. if you update your Information to inducte a current email address. VNS will send information to that address. You will need the following Victim Identification Number (VIN) '2074381' and Personal Identiffcallon Plumber (PIN) '1816' anytime you contact the Cali Center and the first lime you log or. to VMS on the Internet In addition, the first time you access the VNS Internet sae, you will be prompted to enter your last name (or business name) as currently contained In VNS. The name you should enter is Rea EFTA00233866
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Case 9:08-cv-80811-KAM Document 33 Entered on FLSD Docket 01/07/2009 Page 37 of 41 Caseft08-ev-89.736-KAM Document 14 Entered on FLSD Docket 07-46/24306, -.• Page cii7tal 21 11 you have additional questions which Involve this matter, please contain' the office Sated above. When you cell, please provide the tile number bested at the top of this letter. Please remember, your participation tne notification part of this program Is voluntary. In order to continue to receive nottliCallOns, ti is your responsibility to keep your cannot Information current. • Sincerely, victor bpeciasst TOTAL A.07 EFTA00233867
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Case 9:08-cv-80811-KAM Document 33 Entered on FLSD Docket 01/07/2009 Page 38 of 41 Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008 Pa 'e 18 of 21 v U.S. Department of Justice United States Attorney Southern District of Florida 4301/MMENT EXHIBIT Nt8I 110716CV•KNIRA EXHIBIT NO. 6 500 South Australian Ave.. Suite 400 West Palm Beach. FL 33401 (561)8204711 Facsimile: (561)8204777 July 9, 2008 VIA FACSIMILE Brad Edwards, Esq. The Law Offices of Brad Edwards & Associates, [.LC Re: Jeffrey 4..stein/QIN...la NOTIFICATION OF IDENTIFIED VICTIM Dear Mr. Edwards: By virtue of this letter, the United States Attorney's Office for the Southern District of Florida asks that you provide the following notice to your client, On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-009454A)OCXMB and 2008-cf- 009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be followed by an additional six months' imprisonment, followed by twelve months of Community Control 1, with conditions of community confinement imposed by the Court. 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. 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 I8, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein EFTA00233868