EFTA01081657

07/09/2008 16:15 FAY 5618059846 
USAO WPB CONFRM 
[bon 
Case 9:08-cv-80736-KAM •ument 
48-7 
Entered on FLSD Dile
32,1R5gg) Ppg2 2,pf 3 
Department of Justice 
Federateureau of inve-sligation 
FBI - West Palm Beach 
Suite 500 
505 South Flagler Drive 
West Pe 
tech FL 33401 
Piro
• 
Fax: 
January 10, 2008 
James Eisenberg 
One Cie snake Center Ste 704 Australian South 
West Pain, Beach, FL 33401 
Re: 
Dear James Eisenberg: 
You have requested to receive notifications for Tinge 
This case is contently under Investigation. This can bee lengthy process and we request your 
continued patience wNla we conduct a thorough Investigation. 
As a crime victim, you have the following rights under 18 United Stater, Code 5 3771: (1) The right to 
be reasonably protected from the accused: (2) The right to reasonable, accurele, and timely notice of any 
public court proceeding, or any prude proceeding, Involving 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 convkicIng evidence, determines that teelnony by the *dm wduld be materially altered if 
the victim heard other testimony at that proceeding: (4) The right to
 reasonably heard at any public 
proceeding in the district court involving release, plea, sentencing, or any parole proceeding; (5) The 
reasonable right to confer wet the etterney for the Government in the case; (6) The right to full and timely 
reslitudon as provided in law: (7) The rIgM to proceedings free from unreasonable delay-. (8) The right to be 
treated with farness and with respect for the victim's dignity and PriYacY. 
We vd6 make our beat efforts to ensure you are accorded the tights described. Most of these rights 
pertain to events oocuning after the arrest or Indictment of an Individual Mr the cnme, and k Mil become the 
responsibility of the prosecuting United States Attorneys Office to ensure you are accorded those rights. You 
may also flak the edvioe of a privets attorney with respect to these rights. 
The victim Notification System (VNS) is designed to provide you with direct Information regarding the 
case ash proceeds through the criminal Justice system. You may obtain current infermadon about this matter 
on the Internet at WWW.Notify.U6DOLGOV or from the VNS Call Canter at 1-866-D0,1-4YOU (1.866-365-
4968) (TDD/TTY: 1486-228-4819) (Inbemallonat 1502.213.2767). In addition, you may use the Cal 
Center or IMemetto update yaw contact information and/or change your dedslOn about particJpation in the 
notification program.. If you update your information to Include a current small Oddress, VNS vAn send 
information to that address. You will need the following Victim Identification Number (VIN) '194174r and 
Personal IdentlfleatIOn Number (PIN) 7760' anytime you contact the Can Center and the first time you tog on to 
VNS on the Internet. In addlton, the find tbrie you access the VNS Internet site, you will be prompted to enter 
your lest name (or business name) as Wreath, contained in VNS. The name you should enter Is Eisenberg. 
EFTA01081737

07/09/2008 15:15 FAX 5618059848 
USAO WPM CONFRM 
1 029 
Case 9:0?-cv: 80736-KAM 
ument 48-7 
Entered on FLSD Deets93/21/2011 Page 3 of 3 
too om. 
r -rmene 
If you have additional qoatIons with Involve thrs maw, please conlact the office kited above. When 
you ca. pan provide Vii Fie number boated at the top of it letter. Please remember, your partldpation 
In the notification part of Oda program is voluntary. In order to (*Minus to recant narrations, it is your 
reeponsiblItty to keep your contact It/motion current. 
• 
Sincerely. 
ej.)i to •-aen;-(73 
Twiter Smith 
Victim Specialist 
EFTA01081738

Case 9:08-cv-80736•KAM Document 48-8 Entered on FLSD Docket 03/21/2011 Page 1 of 3 
JANE DOE NI AND JANE DOE N2'S MOTION FOR FINDING OF VIOLATIONS OF THE 
CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE 
REMEDIES 
CASE NO: 0840736-Chr-Marra/Johnson 
EXHIBIT H 
EFTA01081739

Case 9:08-cv-80736-KAM Document 48-8 Entered on FLSD Docket 03/21/2011 Page 2 of 3 
FD-302 (Ray. )04-95) 
- 1 -
FEDERAL BUREAU OF INVESTIGATION 
Date of nenserinnsm 
0210812009
On Thursday, January 31, 2008, AMMOMPKOMPnet with 
Assistant United States Attorney MARIE VILLAFANA, UNITED STATES 
ATTORNEY'S OFFICE (USAO) and Attorney MYESHA K. BRADEN, UNITED 
STATES DEPARTMENT OP JUSTICE(D0J), CRIMINAL DIVISION. Also present 
at the meeting were Special Agents E. NESBITT KUYRKENDALL and JASON 
R. RICHARDS, FEDERAL BUREAU OF INVESTIGATION. The meeting was 
arranged pursuant to a federal investigation regarding the sexual 
exploitation of minors. During the course of the meeting, 
provided the following additional or clarifying information not 
previously documented in earlier FD-302s: 
JEFFREY EPSTEIN and his assistants, 
and 
_(identified 
as 
and 
would 
contact Wen to set u a pointments for EPS 
N's massages. 
According to ww, 
would call and say that EPSTEIN was on 
a flight and inquire about scheduling work for mem 
Life was not going well for Williduring the time she was 
providing EPSTEIN with massages. WOOMpwas buying and taking drugs, 
i.e. Xanax, Lorcets, and Percosets. Waft said that she stayed on 
pills. we explained that she wanted to feel numb. 4010 stopped 
attending school at age fifteen. Her parents were addicted to 
crack and cocaine. Prior to her parent's drug use, We was in the 
band, a cheerleader, and a straight "A" student. We played the 
trumpet for the school band. When her parent's drug habits got 
bad, things went downhill, they lost everything. 
WIND became a dancer the day before her sixteenth 
birthday at ellelleitle 
She worked there for six months, 
up 'until the employer found out she was underage. Later, MS 
worked for 
which she did for 6 months. Willi stopped 
seeing EPSTEIN during that time. 
all stated that she brought up to twenty, twenty-five, 
or thirty different girls. wOMMIsaid all of the girls but maybe 
ten of them were underage. Some of the females WOOMbrought for 
EPSTEIN were dancers. 
I
 said that EPSTEIN did not care for all 
of the girls she brought to him. WOMB explained that EPSTEIN did 
not care for some of the dancers, the older females, and the 
females with tattoos. 
hinstigiWorion 
 01/31/2008 
 m  West Palm Beach, Florida 
nice 31E-MM-108062 
SA E. Nesbitt Kuyrkendall 
by 
SA Jason R. Richards 
Disc chatted 01/31/2008
This document contains neither recommendations nor conclusions of the FBI. It Is the ptoperry of the FB) and is loaned w your agency: 
it and its contents arc not to be distributed outside your agency. 
EFTA01081740

Case 9:08-cv-80736-KAM Document 48-8 Entered on FLSD Docket 03/21/2011 Page 3 of 3 
FE).3022 (Rev. )0+95) 
•
 
31E-MM-108062 
Continuation of fl>302 
a
 al
.on  01/31/2008  .Fate  2 
L 
said that during the massages EPSTEIN would push 
further and further regarding the sexual activity. According to 
WAIN EPSTEIN never asked, "is this okay," he would just see how 
far one would let him go. 
NOPrecalled seeing sculptures of naked women and lots 
of pictures of kids in the library. 
• 
WIWI stated that everybody thought Epstein was a 
neurologist. 
WIllialso stated that 
•
.
 
.
 
V 
1/4
rit 
.1 at-
4 
EFTA01081741

Case 9:08-cv-80736-KAM Document 48-9 Entered on FLSD Docket 03/21/2011 Page 1 of 3 
JANE DOE #1 AND JANE DOE N2'S MOTION FOR FINDING OF VIOLATIONS OF THE 
CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE 
REMEDIES 
CASE NO: 08-80736-Ov-Marra/Johnson 
EXHIBIT I 
EFTA01081742

la 030 
07/09/2008 15:15 FAX 5618059846 
115A0 WPB CONFIRM 
Case 9:08-cv-80736-KAM eument 48-9 Entered on FLSD Dirt 03/21 
U.S. Department of Justice 
Federal Bureau of Investigation 
FBI - West Palm Beach 
Suite 500 
505 South Fleeter Drive 
West P 
33401 
Pho 
• 
Fax 
May 30, 2005 
Re: 
Deer
Irs
• 
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 are 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 throughout the investigation. Our program is part of the Fars 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 
(VNS). VNS Is designed to provide you vAlt information regarding the status of your case. 
This case Is currently under Investigation. This can bee lengthy process and we request your 
continued patience white we conduct a thorough investigation. 
As a crime victim, you have the following rights under 18 United Slates Coda § 3771: (1) The right to 
be reasonably protected from the accused; (2) The right to reasonable, accurate, and timely notice of any 
public court proceeding, or any parole proceeding, involving 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, attar 
receiving clear and convincing evidence, determines that testimony by the victim would be maternity 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 etbrney for the Government In the case; (5) The right to full and timely 
restitution is provided In law; (7) The right to proceedings free from unreasonable delay, (s) The right to be 
treated :44th fairness and with respect for the victim's dignity and privacy. 
We will make our best efforts to ensure you ens accorded the rights described. Most of these rights 
pertain to events occurring after the arrest or Indictment of an hdividual for the crime, and h wfil become the 
responsibility of ihe prosecuting United States Attorney's Office to ensure you are accorded those rights. You 
may also seek the advice ate private attorney with respect to these rights. 
The Victim Notlficagon 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 Information abo 
' 
.er 
PePi
e Internet at 
' 
DOJ.GOV or be 
Center at 1-856-DOJ-4YOU (1 
) (TDOrTIY: 1 
) (International: 1 
. In addition, you may use the Call 
e
or Internet to update your contact information and/or change your decision about participation in the 
notification program. if you update your information to Include a anent email address, VNS win send 
Information to that address. You will need the following Victim Identification Number (VIM) 2074361' and 
Personal Identification Number (PIN) '1816' anytime you contact the Call Center and the first time you log on to 
VNS on the Internet. In addition, the first time you access the VNS Internet site, you will be prompted to enter 
your test name (or business name) as currently contained in VNS. The name you should enter Is Rips 
EFTA01081743

07/09/2008 15: 15 FAX 5618059846 
USACI YIPS CONFRM 
Qom 
Case 9:08-cv-80736-KAM ,ument 48-9 
Entered on FLSD Dilet 03/21/2011 Page 3 of 3 
. _
OJV 07J1 
r:tir•oi 
0 
46.-..-.. 
If you have additional questions attach invoNe this matter, please contact the office toted above. When 
you call. please provide the file number located at the lop of this letter. Please remember, your participation 
In the nottnaation pert of this program le voluntary. In order to continue to receive notifications, lt is your 
responsibility to keep your contact information current. 
Sincerity, 
0 
. 
 
 (CA. 
Tit." 
Tallier Smith 
Victim SpeciaSst 
TOTAL P,e7 
EFTA01081744

Case 9:08-cv-80736-KAM Document 48-10 Entered on FLSD Docket 03/21/2011 Page 1 of 4 
JANE DOE NI AND JANE DOE N2'S MOTION FOR FINDING OF VIOLATIONS OF THE 
CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE 
REMEDIES 
CASE NO: 08-80736-Ov-Marra/Johnson 
EXHIBIT J 
EFTA01081745

Case 9:08-cv-80736-KAM Document 48-10 
Entered on FLSD Docket 03/21/2011 Page 2 of 4 
• AND ASSOCIATES 
July 3, 2008 
Ann Marie C. Villafana, AUSA 
United States Attomey's Office 
500 South Australian Avenue 
West Palm Beach, Florida 33401 
Dear Ms. Villafana: 
VIA CERTIFIED MAIL 
RETURN RECEIPT REQUESTED 
7007 2680 0002 5519 8503 
As you are aware, we represent several of the young girls that were victimized 
and abused by Jeffrey Epstein. While we are aware of his recent guilty plea and 
conviction in his State Court case, the sentence imposed in that case is grossly inadequate 
for a sexual predator of this magnitude. The information and evidence that has come to 
our attention in this matter leads to a grave concern that justice will not be served in this 
cause if Mr. Epstein is not aggressively prosecuted and appropriately punished. Based on 
our investigation and knowledge of this case, it is apparent that he has sexually abused 
more than 100 underage girls, and the evidence'against him is overwhelmingly strong. 
As former AsSistant State Attorneys with seven years' prosecution experience, we 
believe that the evidence against Mr. Epstein is both credible and deep and that he may 
be the most dangerous sexual predator of children that our country has ever seen. The 
evidence suggests that for at least 4 years he was sexually abusing as many as three to 
four girls a day. It is inevitable that if he is not confined to prison, he will continue to 
manipulate and sexually abuse children and destroy more lives. He is a sexual addict that 
focused all of his free time on sexually abusing children, and he uses his extraordinary 
wealth and power to lure in poor, underprivileged little girls and then law uses his wealth 
to shield himself from prosecution and liability. We are very concerned for the health 
and welfare of the girls he has already victimized, and concerned that if justice is not 
properly served now and he is not imprisoned for a very long time, he will get a free pass 
to sexually abuse children in the future. Future abuse' and victimization is obvious to 
anyone who really reviews the evidence in this case, and future sexual abuse of minors is 
inevitable unless be is prosecuted, tried and appropriately sentenced. Money and power 
should not allow a man to make his own laws, and he has clearly received preferential 
treatment at every step up to this point. If he were a man of average wealth or the abused 
girls were from middle or upper class families, then this man would spend the rest of his 
life in prison. In a country of true, blind justice, those distinctions are irrelevant, and we 
really hope he does not prove the point that a man can commit heinous crimes against 
children and buy his way out of it. 
If the Department of Justice's recent commitment to the protection of our children 
from child molesters is to be more than rhetoric, then this is the time and the case where 
the Department must step forward. We urge the Attorney General and our United States 
2028 HARRISON STRZET,SUITE 202, HOLLYWOOD, FLORIDA 33020 
OFFICIZI 
EFTA01081746

Case 9:08-cv-80736-KAM Document 48-10 Entered on FLSD Docket 03/21/2011 Page 3 of 4 
Ann Marie C. Villafana, AUSA 
United States Attorney's Office 
Page Two 
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 perpetrator. We will help you to do this in any way possible to ensure that true 
Justice is served in this case. 
Sincerely, 
Brad Edwards, Esquire 
Jay Howell, Esquire 
2028 HARRISON STRERT,SUITS 202, HOLLYWOOD, FLORIDA 53020 
OFFIORt 
FAX, 
EFTA01081747

Case 9:08-cv-80736-KAM Document 48-10 
Entered on FLSD Docket 03/21/2011 Page 4 of 4 
SENDER: COMP! ETE THIS SECTION' 
: 
•. 
. 
Camp Sete Items 1,2, and S. Also complete 
iterni4 If Restricted Delivery Is desired. 
■ Print your name and address on the reverse 
so that we cantoture the card to you. 
• Attach this card to the back of the Maliplece. 
• 
or oil the front If space permits. 
t. Arad, Addressed to: 
. _ 
. 
•
 
Ann Mail. C. Means, AUSA 
United States Attorney's Office 
500 South Australian Avenue• 
Waist Paint Beach, Florida 33401 ; 
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• 
EFTA01081748

Case 9:08-cv-80736-KAM Document 48-11 Entered on FLSD Docket 03/21/2011 Page 1 of 3 
JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF THE 
CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE 
REMEDIES 
CASE NO: 08-80736-Clv-Marra/Johnson 
EXHIBIT K 
EFTA01081749

07/09/2008 15:15 FAX 5818059846 
USA() ITYB 
032 
Gpse 9:08-cv-80736-KAM ilument 48-11 Entered on FLSD Stet 03/21/2011 Page 2 of 3 
U.S. Department of Justice 
• 
United States Attorney 
Southern District of Florida 
500 South Australian Ave.. Suite 400 
West Palm Beach. FL 35401 
Facsimile.
July 9, 2008 
VIA FACSIMILE 
Brad Edwards, Esq. 
The Law Offices of Brad Edwards & Associates, LLC 
2028 Harrison Street, Suite 202 
Hollywood, Florida 33020. 
Re: 
Jeffrey Epstein/U. - Was 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, a 
VIE 
On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein)• entered a plea 
of guilty to violation* of Florida Statutes Sections 796.07 (felony solicitation of prostitution) 
and 796.03 (procurement of Mint= tit engage in prostitutiOn); in the I Sthludicial Circuit in 
and for Faint. Beach County (Case Nos. 2006-cf-Q09454tAJOO{W and 200g-cf-
009381AX-30ga) and was leoten 044 to a term of twelve lotclatte itoPti§onotent to be 
followed by an additi0nal sit 
imprisotuneat. fightuted by Sae Maths of 
Community Control I, with conditions of community conflitetnent 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 feilowing: 
"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 
EFTA01081750

07/09/2008 15:16 FAX 5618059846 
USAO WPB CONFRM 
0033 
Case 9:08-cv-80736-KAM •ument 48-11 
Entered on FLSD Garet 03/21/2011 Page 3 of 3 
BRAD EDWARDS, ESQ. 
NOTIFICATION OF IDENTIFIED VICTIM CMS 
Me 
JULY 9, 2008 
PAGE 2 OF 2 
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." 
Through this letter, this Office hereby provides Notice that your client, arta 
is an individual whom the United States was prepared to name as a victim of an enumerated 
offense. 
• 
ti
Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack 
Goldberger, asks that you contact hitn at Atteibury Goldberger and Weiss, 250 Australian 
Avenue South; Suite 1400, West Palm Beach, FL 33401, 
Please understand that neither the 1.1:5. AttOntey'S Office nay the Federal Butes" of 
Investigation can take part in or otherwise.assist in civil litigation; however, if yen do Mt a 
claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim elan 
enumerated offense, please provide notice of thet denial to the undersigned. 
Nast thank your client for all ether assistance during the course of this examination 
al144141, 44110141$1401€11 prprlt ofts*itanftdWeciat Agents Kuyskendalt andRieltankfrie 
beS4000 wolirbeing off
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
BY: 
cc: 
Jack Goldberger, Esq. 
A. MARIE VILLAFARA 
ASSISTANT U.S. ATTORNEY 
EFTA01081751

Case 9:08-cv-80736-KAM Document 49 
Entered on FLSD Docket 03/21/2011 Page 1 of 10 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 08-80736-Civ-Marra/Johnson 
JANE DOE #1 and JANE DOE #2 
v. 
UNITED STATES 
JANE DOE #1 AND JANE DOE #2'S MOTION TO HAVE THEIR FACTS ACCEPTED 
BECAUSE OF THE GOVERNMENT'S FAILURE TO CONTEST ANY OF THE FACTS 
COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and 
through undersigned counsel, to move this Court to accept all of their facts in their Motion for 
Finding of Violations of the Crime Victims' Rights Act. The victims have been attempting to 
negotiate with the Government for more than 30 months on a stipulated set of facts. Despite 
repeated opportunities to advise the victims of what facts they are contesting, the Government in 
the last few days has flatly declared that it will not discuss the facts in this case. This is violation 
of the Court's direction to the parties as well as the local rule on the subject. Accordingly, the 
Government should be deemed to have failed to contest the victims' facts and the Court should 
proceed to resolve this case on the basis of the victims' proffered facts. 
FACTUAL BACKGROUND 
The victims have been attempting to reach an agreement on the facts surrounding this 
case since filing their petition on June 7, 2008. In that petition, the victims' recited the facts as 
The petition was initially filed on behalf of Jane Doe #1. Jane Doe #2 was quickly 
added into the case. For simplicity, we will refer to the pleadings as having been filed by "the 
EFTA01081752

Case 9:08-cv-80736-KAM Document 49 Entered on FLSD Docket 03/21/2011 Page 2 of 10 
they understood them at the time — i.e., the victim asserted "upon information and belief' that 
they understood that Epstein was involved in on-going plea negotiations with the U.S. Attorney's 
Office for the Southern District of Florida. Victims' Petition (doe. #1) at 1. On July 9, 2008, the 
Government responded with a sealed response (quickly unsealed by the Court), that stated that 
an agreement had already been reached with Epstein. Government's Response to Victims' 
Emergency Petition (doe. #13). Two days later, the victims replied, explaining that they were 
just learning these facts from the Government's pleading. 
See, e.g., Victims' Reply to 
Government's Response (doc. #9) at 8. 
The Court quickly scheduled a hearing on the victims' petition, held on July 11, 2008. 
The Court discussed a need to "hav[e] a complete record, and this is going to be an issue that's 
... going to go to the Eleventh Circuit, [so it] may be better to have a complete record as to what 
your position is and the government's is as to what actions were taken." Tr. at 25-26. Counsel 
for the victims explained: " . 
I will confer with the government on this and if evidence needs 
to be taken, it [can] be taken at a later date." Tr. at 26. The Court concluded the hearing with the 
following instructions: "So I'll let both of you confer about whether there is a need for any 
additional evidence to be presented. Let me know one way or the other. If there is, we'll 
schedule a hearing. If there isn't and you want to submit some additional stipulated information, 
do that, and then I'll take care of this in due course." Tr. at 32. 
The victims and the U.S. Attorney's Office then attempted to reach a stipulated set of 
facts underlying the case. The U.S. Attorney's Office offered a very abbreviated set of proposed 
facts, and the victims responded with a detailed set of proposed facts. Rather than respond to the 
victims." 
2 
EFTA01081753

Case 9:08-cv-80736-KAM Document 49 Entered on FLSD Docket 03/21/2011 Page 3 of 10 
victims' specific facts, however, the U.S. Attorney's Office suddenly reversed course. On July 
29, 2008, it filed a Notice to Court Regarding Absence of Need for Evidentiary Hearing (doc. 
#17). 
The U.S. Attorney's Office took the following position: "After consideration, the 
Government believes that an evidentiary hearing is not necessary" (doe. #17 at 1). The Office 
asserted that the Court need only take judicial notice of the fact that no indictment had been filed 
against Epstein to resolve the case. 
On August I, 2008, the victims filed a response to the Government's "Notice" (doc. #19), 
giving a proposed statement of facts surrounding the case. The proposed statement of facts 
highlighted the fact that the Government had signed a non-prosecution agreement containing an 
express confidentiality provision, which prevented the Government from disclosing the 
agreement to them and other victims. Id. at 5. The victims response also requested that the 
Court direct the Government to confer with the victims regarding the undisputed facts of the 
case, produce the non-prosecution agreement and other information about the case. Id. at 14. 
On August 14, 2008, the Court held a hearing on the case regarding the confidentiality of 
the non-prosecution agreement. The Court ultimately ordered production of the agreement to the 
victims. 
After the U.S. Attorney's Office made the non-prosecution agreement available to the 
victims, the victims reviewed it and pursued further discussions with the U.S. Attomey's Office. 
Ultimately, however, the U.S. Attorney's Office declined to reach a stipulated set of facts with 
the victims and declined to provide further information about the case. 
With negotiations at an impasse, the victims attempted to learn the facts of the case in 
other ways. In approximately May 2009, counsel for the victims propounded discovery requests 
3 
EFTA01081754

Case 9:08-cv-80736-KAM Document 49 Entered on FLSD Docket 03/21/2011 Page 4 of 10 
in both state and federal civil cases against Epstein, seeking to obtain correspondence between 
Epstein and prosecutors regarding his plea agreement — infonnation that the U.S. Attorney's 
Office was unwilling to provide to the victims. Epstein refused to produce that information, and 
(as the Court is aware) extended litigation to obtain the materials followed. The Court rejected 
all of Epstein's objections to producing the materials. 
On June 30, 2010, counsel for Epstein sent to counsel for the victims approximately 358 
pages of e-mail correspondence between criminal defense counsel and the U.S. Attorney's Office 
regarding the plea agreement that had been negotiated between them. See Jane Doe 41 and Jane 
Doe #2's Motion for Finding of Violations of the Crime Victims' Rights Act and Request for a 
Hearing on Appropriate Remedies, Attachment "A." These e-mails fully disclosed for the first 
time the extreme steps that had been taken by the U.S. Attorney's Office to avoid prosecuting 
Epstein and to avoid having the victims in the case learn about the non-prosecution agreement 
that had been reached between Epstein and the Government. 
In mid-July 2010, Jane Doe #1 and Jane Doe #2 settled their civil lawsuits against 
Epstein. 
Then, armed with the new information, they turned to moving forward in the CVRA 
case. 
On September 13, 2010, the victims informed the Court that they were preparing new 
filings in the case. 
On October 12, 2010, the Court entered an order directing the victims to provide a status 
report on the case by October 27, 2010. That same day, counsel for the victims again contacted 
the U.S. Attorney's Office about the possibility of reaching a stipulated set of facts in the case. 
That same day, the U.S. Attorney's Office responded: "We don't have any problem with 
agreeing that a factual assertion is correct if we agree that is what occurred" (doc. #41 at 2). 
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Case 9:08-cv-80736-KAM Document 49 
Entered on FLSD Docket 03/21/2011 Page 5 of 10 
On October 23, 2010, the victims e-mailed to the U.S. Attorney's Office a detailed proposed 
statement of facts, with many of the facts now documented by the correspondence between the U.S. 
Attorney's Office and Epstein's counsel. The victims requested that the U.S. Attorney's Office 
identify which facts it would agree to. In a letter to the U.S. Attorney's Office, the victims stated: 
If you believe that any of the facts they propose are incorrect, Jane Doe #1 and Jane 
Doe #2 would reiterate their long-standing request that you work with us to arrive at a 
mutually-agreed statement of facts. As you know, in the summer of 2008 Jane Doe 
#1 and Jane Doe #2 were working with you on a stipulation of facts when you 
reversed course and took that position that no recitation of the facts was necessary 
(see doe. #19 at 2). . . . I hope that your e-mail means that you will at least look at our 
facts and propose any modifications that you deem appropriate. Having that evidence 
quickly available to the Court could well help move this case to a conclusion. 
That same day, the U.S. Attorney's Office agreed to forward the proposed statement of facts to the 
appropriate Assistant U.S. Attorney for review (doe. #41 at 2-3). 
On October 26, 2010, rather than stipulate to undisputed facts, the U.S. Attorney's Office 
contacted the victims' attorneys and asked them to delay the filing of their motion for a two-week 
period of time so that negotiations could be held between the Office and the victims in an attempt to 
narrow the range of disputes in the case and to hopefully reach a settlement resolution without the 
need for further litigation. Negotiations between the victims and the U.S. Attorney's Office then 
followed over the next two days. However, at 6:11 p.m. on October 27, 2010 — the date on which the 
victims' pleading was due — the U.S. Attorney's Office informed the victims that it did not believe 
that it had time to review the victims' proposed statement of facts and advise which were accurate 
and which were inaccurate. The Office further advised the victims that it believed that the victims did 
not have a right to confer with their Office under the CVRA in this case because in its view the case 
is "civil" litigation rather than the "criminal" litigation (doc. #41 at 3). 2
2 In seeming contradiction to this position, on March 17, 2011, the U.S. Attorney's Office 
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