EFTA00081226.pdf

Case 9:08-cv-80736-KAM Document 341-2 Entered on FLSD Docket 11/23/2015 Page 1 of 20 Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 1 of 20 EXHIBIT 'I EFTA00081226 Case 9:08-cv-80736-KAM Document 341-2 Entered on FLSD Docket 11/23/2015 Page 2 of 20 Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 2 of 20 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. DECLARATION OF 1. My name is and I was born in August, 1983. 2. I am currently 31 years old. 3. I grew up in Palm Beach, Florida. When I was little, I loved animals and wanted to be a veterinarian. But my life took a very different turn when adults began to be interested in having sex with me. EFTA00081227 Case 9:08-cv-80736-KAM Document 341-2 Entered on FLSD Docket 11/23/2015 Page 3 of 20 Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 3 of 20 6. I came back for several days following and did the same sorts of sexual things for Epstein. 8. So I started "working" exclusively for Epstein. He took me to Ncw York on his big, private jet. We went to his mansion in Ncw York City. I was shown to my room, a very luxurious room. The mansion was huge. I got scared because it was so big. Epstein brought me to a room with a massage parlor. To me, it looked like an S&M parlor. Epstein made me engage in sexual activities with him there. 9. You can see how young I looked in the photograph below. 1 EFTA00081228 Case 9:08-cv-80736-KAM Document 341-2 Entered on FLSD Docket 11/23/2015 Page 4 of 20 Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 4 of 20 10. Epstein took me on a ferry boat on one of the trips to New York City and there he took the picture above. I was approximately IS or 16 years old at the time. 12. I was trained to be "everything a man wanted me to be." It wasn't just sexual training - they wanted me to be able to cater to all the needs of the men they were going to send me to. They said that they loved that I was very compliant and knew how to keep my mouth shut. 14. From very early on I was fearful of Epstein. Epstein told me he was a billionaire. I told my mother that I was working for this rich guy, and she said "go, go far away." Epstein had promised me a lot, and 1 knew if I left I would be in big trouble. I also knew that I was a witness to a lot of illegal and very bad behavior by Epstein and his friends. If I left Epstein, he knew all kinds of powerful people. He could have had me killed or abducted, and I always knew he was capable of that if I did not obey him. He let me know that he knew many people in high places. Speaking about himself, he said "I can get away" with things. I was very scared, particularly since I was a teenager. 3 EFTA00081229 Case 9:08-cv-80736-KAM Document 341-2 Entered on FLSD Docket 11/23/2015 Page 5 of 20 Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 5 of 20 16. To illustrate my connection to these places, I include four photographs taken of me in New Mexico (shown below). The first one is a museum in Santa Fe, New Mexico. We had gone sightseeing for the day. Epstein took this picture of me. I was approximately 17 at the time, judging from the looks of it. At the end of the day we returned to Epstein's Zorro Ranch. The second picture is me on one of Epstein's horses on the ranch in New Mexico. The following two are from wintertime in New Mexico. 4 EFTA00081230 Case 9:08-cv-80736-KAM Document 341-2 Entered on FLSD Docket 11/23/2015 Page 6 of 20 Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 6 of 20 IL. 17. When I was with him, Epstein had sex with underage girls on a daily basis. His interest in this kind of sex was obvious to the people around him. The activities were so obvious 5 EFTA00081231 Case 9:08-cv-80736-KAM Document 341-2 Entered on FLSD Docket 11/23/2015 Page 7 of 20 Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 7 of 20 and bold that anyone spending any significant time at one of Epstein's residences would have clearly been aware of what was going on. 18. Epstein's code word for sexual encounters was that it was a "massage". At times the interaction between Epstein and the girls would start in a massage room setting, it was always a sexual encounter and never just a massage. 6 EFTA00081232 Case 9:08-cv-80736-KAM Document 341-2 Entered on FLSD Docket 11/23/2015 Page 8 of 20 Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 8 of 20 7 EFTA00081233 Case 9:08-cv-80736-KAM Document 341-2 Entered on FLSD Docket 11/23/2015 Page 9 of 20 Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 9 of 20 8 EFTA00081234 Case 9:08-cv-80736-KAM Document 341-2 Entered on FLSD Docket 11/23/2015 Page 10 of 20 Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 10 of 20 9 EFTA00081235 Case 9:08-cv-80736-KAM Document 341-2 Entered on FLSD Docket 11/23/2015 Page 11 of 20 Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 11 of 20 10 EFTA00081236 Case 9:08-cv-80736-KAM Document 341-2 Entered on FLSD Docket 11/23/2015 Page 12 of 20 Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 12 of 20 II EFTA00081237 Case 9:08-cv-80736-KAM Document 341-2 Entered on FLSD Docket 11/23/2015 Page 13 of Case 9:08-cv-80736-KAM Document 291-1 &red on FLSD Docket 01/21/2015 Page 13 of 20 54. I now understand that Epstein reached a non-prosecution agreement with the federal government in 2007 and pled guilty to two state crimes in June 2008. I now know that I was identified by the federal government as one of Epstcin's and his co-conspirator's sexually abused victims. However, no one told me about those events until after they happened. 55. On September 3, 2008, the FBI sent a victim notification letter to me. This was the first written communication I had received from the FBI. The letter is attached as Exhibit I. The letter describes an agreement in which compensation would be made victims of Epstein's 12 EFTA00081238 Case 9:08-cv-80736-KAM Document 341-2 Entered on FLSD Docket 11/23/2015 Page 14 of 20 Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 14 of 20 sexual abuse. The letter also said that the federal government was going to "defer federal prosecution." No one had told me about deferring federal prosecution before this. 56. In 2011, two FBI agents, called me in Australia and then came to meet me. They met me at the U.S. Consulate in Sidney. They seemed to be very professional and hard working. I thought to myself, "Wow, these people will do the right thing against the bad guys and protect me." 57. The agents wcrc mainly focused on Epstein but while there I provided them some information about others who wcrc involved in illegal acts as well. I was aware that a false statement to these law enforcement officers was a crime and I told the truth — giving them the information that I could recall about the individuals they inquired about. 58. Epstein also trafficked me for sexual purposes to many other powerful men, including politicians and powerful business executives. Epstein required me to describe the sexual events that I had with these men presumably so that he could potentially blackmail them. I am still very fearful of these men today. 60. In this affidavit, I have tried to focus on how I was trafficked for sexual purposes. I have not described all of the details of the sexual activities Epstein forced me to have. Also, I have not described all of the details of the other events discussed here. If a judge wants me to 13 EFTA00081239 Case 9 08-cv-80736-KAM Document 341-2 Entered on FLSD Docket 11/23/2015 Page 15 of 20 Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 15 of 20 present my information in more detail, including more specific descriptions of the sexual activities with the men Epstein sent me to, I could do so. 61. I have directed my attorneys, Bradley Edwards and Paul G. Cassell, to pursue all reasonable and legitimate means to have criminal charges brought against these powerful people for the crimes they have committed against me and other girls. They are representing me in this case pro bono. 62. Since I filed my motion in this case. my credibility has been attacked. I am telling the truth and will not let these attacks prevent me from exposing the truth of how I was trafficked for sex to many powerful people. These powerful people seem to think that they don't have to follow the same rules as everyone else. That is wrong. I hope that by coming forward, I can help expose the problem of sex trafficking and prevent the same sort of abuse and degradation that happened to me from happening to other girls. 63. I declare under penalty of perjury that the foregoing is true and correct. Executed this fsday oflanuary, 2015. (Location of signature left undisclosed for security reasons) 14 EFTA00081240 Case 9:08-cv-80736-KAM Document 341-2 Entered on FLSD Docket 11/23/2015 Page 16 of 20 Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 16 of 20 EXHIBIT 1 EFTA00081241 Case 9:08-cv-80736-KAM Document 341-2 Entered on FLSD Docket 11/23/2015 Page 17 of 20 Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 17 of 20 US. Department otjustice United SiotesAttorney Southern District of Florida 300 South Australian Ave.. Suite 400 Wert Palm Brach, FL 33401 (560 820-8711 Facsimile: (561)8204777 September 3, 2008 NOTIFICATION OF IDENTIFIED VICTIM NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED STATES CODE, SECTION 3509(d) AND FLORIDA LAW, THE ATTACHED DOCUMENT IS TO BE TREATED AS CONFIDENTIAL AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTION WITH A LEGAL PROCEEDING. EFTA00081242 Case 9:08-cv-80736-KAM Document 341-2 Entered on FLSD Docket 11/23/2015 Page 18 of 20 Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 18 of 20 U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 Wart Pam Beach, FL 33401 (S61) 8304711 Facsimile. (561)820-8777 September 3, 2008 VIA COURIER Re: Jeffrey Epstein/ NOTIFICATION OF IDENTIFIED VICTIM Dear By virtue of this letter, the United States Attorney's Office for the Southern District of Florida provides you with the following notice because you are an identified victim of a federal offense. 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-009454AXXXMB and 2008-cf- 00938 IAXXXIAB) 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 I, 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, including the following: 1. An independent Special Master was assigned the task of selecting an attorney representative to represent the victims, including you, in connection with civil actions between the victims and Mr. Epstein. The EFTA00081243 Case 9:08-cv-80736-KAM Document 341-2 Entered on FLSD Docket 11/23/2015 Page 19 of 20 Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 19 of 20 NOTIFICATION Or IDENTIFIED V 'Glib, SEPTEMBER 3,2008 PAGE 2 Ora Special Master selected Robert Josefsberg, Esq. of the firm Podhurst Orseck, PA., a highly-respected and experienced attorney. You are not obligated to use Mr. Josefsberg as your civil attorney, but, as explained in greater detail below, Mr. Josefsberg's services will be provided at no cost to you because Mr. Epstein is obligated to pay the costs and fees of the attorney-representative. Also, Mr. Epstein and his attorneys can only contact you via Mr. Josefsberg, assuming that you would like Mr. Josefsberg to serve as your attorney. 2. If you elect to file suit against Mr. Epstein pursuant to Title 18, United States Code, Section 2255, Mr. Epstein will not contest the jurisdiction of the United States District Court for the Southern District of Florida over his person and/or the subject matter, and Mr. Epstein waives his right to contest liability and also waives his right to contest damages up to an amount as agreed to between you and Mr. Epstein, so long as you elect to proceed exclusively under I8 U.S.C. § 2255, and you waive any other claim for damages, whether pursuant to state, federal, or common law. Notwithstanding this waiver, Epstein's agreement with the United States, his waivers and failure to contest liability and such damages in any suit are not to be construed as an admission of any criminal or civil liability. 3. As stated above, Mr. Epstein has agreed to pay the fees of the attorney representative selected by the independent third party. This provision, however, shall not obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus, if after consideration of potential settlements, you and Mr. Josefsberg elect to file a contested lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other contested remedy, the obligation to pay the costs of the attorney representative, as opposed to any statutory or other obligations to pay reasonable attorneys fees and costs such as those contained in Section 2255, shall cease. Please contact either myself at or Justice Department Victim-Witness Specialist Twi ler Smith at with a good telephone number andior e-mail address, so that we may provide Mr. Josefsberg with a timely means of communicating with you. If you would like to contact Mr. Josefsberg EFTA00081244 Case 9:08-cv-80736-KAM Document 341-2 Entered on FLSD Docket 11/23/2015 Page 20 of 20 Case 9:08-cv-80736-KAM Document 291-1 Entered on FLSD Docket 01/21/2015 Page 20 of 20 NOTIFICATION OF IDENTIFIED VICTIM SEPTEMBER 3, 2008 PACE 3 OF 3 directly, he can be reached at +1 305 358.2800. If you have already selected other counsel to represent you, or if you do so in the future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300. In addition, there has been litigation between the United States and two other victims regarding the disclosure of the entire agreement between the United States and Mr. Epstein. Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney to represent you, that attorney can review the Court's order in the matter of In re Jane Does 1 and 2, United States District Court for the Southern District of Florida Court File No. 08- 80736-CIV-MARRA. Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist in civil litigation. Thank you for all of your assistance during the course of the federal and state investigations and please accept the heartfelt regards of myself and Special Agents Kuyrkendall, Slater, and Richards for your health and well-being. Sincerely, R. Alexander Acosta United States Attorney By: cc: Robert losefsberg, Esq. Jack Goldberger, Esq. A. Marie Villafafia Assistant United States Attorney EFTA00081245