EFTA00175910.pdf

pw-d— cp—triw (3-4-C Yirn Neit cabby, wpot C125/Dt EFTA00175910 NOTIFICATION Pursuant to the Agreement between the United States Attorney's Office for the Southern District of Florida (hereinafter referred to as "the Office") and Jeffrey Epstein (hereinafter referred to as "Epstein"), the Office hereby provides Notice to the individuals listed below (hereinafter referred to as "identified individuals") that each of them is a person who, while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, committed by Epstein, and whom the Office was prepared to name as a victim in an Indictment charging Epstein with an enumerated offense. The Office further provides Notice to the identified individuals that, pursuant to the Agreement between the Office and Epstein, a copy of this document may be introduced in a judicial proceeding between any such identified individual and Epstein, and that any judicial authority interpreting this Notification, including any authority determining what evidentiary burdens, if any, a plaintiff must meet, shall consider that it is the intent of Epstein and the Office to place the identified individuals in the same position as they would have been had Epstein been convicted of those federal offenses. Identified Individuals Jane Doe #1 Jane Doe #12 Jane Doe #23 Jane Doe #2 Jane Doe #13 Jane Doe #24 Jane Doe #3 Jane Doe #14 Jane Doe #25 Jane Doe #4 Jane Doe #15 Jane Doe #26 Jane Doe #5 Jane Doe #16 Jane Doe #27 Jane Doe #6 Jane Doe #17 Jane Doe #28 Jane Doe #7 Jane Doe #18 Jane Doe #29 Jane Doe #8 Jane Doe #19 Jane Doe #30 Jane Doe #9 Jane Doe #20 Jane Doe #10 Jane Doe #21 Jane Doe #11 Jane Doe #22 EFTA00175911 R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: By: ASSISTANT UNITED STATES ATTORNEY ACKNOWLEDGEMENT I have received this Notification from my attorney, Roy Black, Esquire, have read it and discussed it with my attorney, and I hereby acknowledge that it accurately sets forth my understanding and agreement with the Office of the United States Attorney for the Southern District of Florida. I understand that an exact copy of this Notification will be provided to each identified individual, except that the names of all other identified individuals will be redacted, and I hereby waive any evidentiary challenges to the introduction of a copy of this document—even in redacted form—in any judicial proceeding between any identified individual and myself. Dated: Jeffrey Epstein Witnessed by: Roy Black, Esquire EFTA00175912 e partment of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 150 I 8111_07 1)820-8777 RNACtC) i8 IVA Qi jSrA" t pf FIFIED VICTIMS On June 3 (9 (2-61°44 :ed to as "Epstein) entered a plea of guilty to '•2S f 96.07 (felony solicitation of prostitution) and 5 in prostitution), in the 15th Judicial Circuit in ,,J umy kt-use NOS. 2006-cf-009495AXXXMB and 2008- ) and was sentenced to a term of eighteen months' imprisonment to be followed by years of probation. In light of the entry of the guilty plea and sentence, and pursuant to the terms of the deferred prosecution agreement between Epstein and the United States Attorney's Office for the Southern District of Florida (hereinafter referred to as "the Office"), the Office hereby provides notice to Epstein that the following is a list of individuals whom the Office was prepared to name as victims in an Indictment charging Epstein with violations of federal statutes enumerated in Title 18, United States Code, Section 2255 (hereinafter referred to as "identified individuals"). The terms of the deferred prosecution agreement provide that the identified individuals shall have the same right to seek damages pursuant to Title 18, United States Code, Section 2255, as they would have had if Mr. Epstein had been tried and convicted of those enumerated offenses in a federal court. Section 2255 provides, in relevant part: Any person who, while a minor, was a victim of a violation of section . . . 2422, or 2423 of this title and who suffers personal injury as a result of such violation, regardless of whether the injury occurred while such person EFTA00175913 NOTIFICATION OF IDENTIFIED VICTIMS JULY 2008 PAGE 2 OF 3 was a minor, may sue in any appropriate United States District Court and shall recover the actual damages such person sustains and the cost of the suit, including a reasonable attorney's fee. Any person as described in the preceding sentence shall be deemed to have sustained damages of no less than $150,000 in value. Thus, pursuant to the deferred prosecution Agreement between the Office and Epstein, the Office hereby provides Notice to the identified individuals that each of them is a person who, while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, committed by Epstein. The Office further provides Notice to the identified individuals that, pursuant to the Agreement between the Office and Epstein, a copy of this document may be introduced in a judicial proceeding between any such identified individual and Epstein, and that any judicial authority interpreting this Notification, including any authority determining what evidentiary burdens, if any, a plaintiff must meet, shall consider that it is the intent of Epstein and the Office to place the identified individuals in the same position as they would have been had Epstein been convicted of those federal offenses. Identified Individuals Jane Doe #1 Jane Doe #2 Jane Doe #3 Jane Doe #4 Jane Doe #5 Jane Doe #6 Jane Doe #7 Jane Doe #8 Jane Doe #9 Jane Doe #10 Dated: Jane Doe #11 Jane Doe #I2 Jane Doe #13 Jane Doe #14 Jane Doe #15 Jane Doe #16 Jane Doe #17 Jane Doe #18 Jane Doe #19 Jane Doe #20 By: Jane Doe #21 Jane Doe #22 Jane Doe #23 Jane Doe #24 Jane Doe #25 Jane Doe #26 Jane Doe #27 Jane Doe #28 Jane Doe #29 Jane Doe #30 R. ALEXANDER ACOSTA UNITED STATES ATTORNEY ASSISTANT U.S. ATTORNEY ACKNOWLEDGEMENT I have received this Notification from my attorney, Roy Black, Esquire, have read EFTA00175914 NOTIFICATION OF IDENTIFIED VICTIMS JULY,_, 2008 PAGE 3 OF 3 it and discussed it with my attorney, and I hereby acknowledge that it accurately sets forth my understanding and agreement with the Office of the United States Attorney for the Southern District of Florida. I understand that an exact copy of this Notification will be provided to each identified individual, except that the names of all other identified individuals will be redacted, and I hereby waive any evidentiary challenges to the introduction of a copy of this document—even in redacted form—in any judicial proceeding between any identified individual and myself. Dated: Jeffrey Epstein Witnessed by: Roy Black, Esquire EFTA00175915 partmcnt of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach FL 33401 (561)820-8711 Facsimile: (561) 820-8777 July __, 2008 NOTIFICATION OF IDENTIFIED VICTIMS 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 - *ins. 2006-cf-009495AXXXMB and 2008- ) and was sentenced to a t y~ risonment to be followed by years of probation. 44 tes has agreed to Oik subject to certain -r :9 One such condition to which Eps' 1.10 g: 0 In light of the entry of the guilty pie defer federal prosecution in favor of th conditions. "Any person, who while a min( IP n of an offense enumerated in Title 18, Unite zi 'S. 'CI , will have the same rights to proceed under d J have had, if Mr. Epstein had been tried federally ,... ,umerated offense. For purposes of implementing this paragwv., Anted States shall provide Mr. Epstein's attorneys with a list of indiviullals 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 EFTA00175916 NOTIFICATION OF IDENTIFIED VICTIMS JULY 2008 PAGE 2 OF 3 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 the individuals identified below are individuals whom the United Stats was prepared to name as a victim of an enumerated offense. Identified Individuals Jane Doe #1 Jane Doe #2 Jane Doe #3 Jane Doe #4 Jane Doe #5 Jane Doe #6 Jane Doe #7 Jane Doe #8 Jane Doe #9 Jane Doe #10 Jane Doe #11 Jane Doe #12 Jane Doe #13 Jane Doe #14 Jane Doe #15 Jane Doe #16 Jane Doe #17 Jane Doe #18 Jane Doe #19 Jane Doe #20 Dated: By: Jane Doe #21 Jane Doe #22 Jane Doe #23 Jane Doe #24 Jane Doe #25 Jane Doe #26 Jane Doe #27 Jane Doe #28 Jane Doe #29 Jane Doe #30 R. ALEXANDER ACOSTA UNITED STATES ATTORNEY ASSISTANT U.S. ATTORNEY ACKNOWLEDGEMENT I have received this Notification from my attorney, Roy Black, Esquire, have read it and discussed it with my attorney, and I hereby acknowledge that it accurately sets forth my understanding and agreement with the Office of the United States Attorney for the Southern District of Florida. I understand that an exact copy of this Notification will be provided to each identified individual, except that the names of all other identified individuals will be redacted, and I hereby waive any evidentiary challenges to the EFTA00175917 NOTIFICATION OF IDENTIFIED VICTIMS JULY 2008 PAGE 3 OF 3 introduction of a copy of this document—even in redacted form—in any judicial proceeding between any identified individual and myself Dated: Jeffrey Epstein Witnessed by: Roy Black, Esquire EFTA00175918