EFTA00221654.pdf

Case 9:08-dv-80119-KAM Document 31-2 Entered on FLSD Docket 07/29/2008 Page 1 of 22: EXHIBIT A EFTA00221654 Case 9:08-cv-80119-KAM Document 31-2 Entered on FLSD Docket 07/29/2008 Page 2 of 22 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 D.C. JUL 0 9 2008 STEVEN M. LAMONT CLERK U.S. DIST CT S.D. Of Ft*. - DECLARATION OF IN SUPPORT OF UNITED STATES' RESPONSE TO VICTIM'S EMERGENCY PETITION FOR ENFORCEMENT OF CRIME VICTIM RIGHTS ACT, 18 U.S.C. $ 3771 1. I, ado hereby declare that I am a member in good standing of the Bar 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. EFTA00221655 Case 9:08-cv-80119-KAM Document 31-2 Entered on FLSD Docket 07/29/2008 Page 3 of 22 Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008 Page 2 of 21 • 2. I am the Assistant United States Attorney assigned to the investigation of Jeffrey Epstein. The 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 identi fled, 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. Accordingli,l-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- EFTA00221656 Case 9:08-cv-80119-KAM Document 31-2 Entered on FLSD Docket 07/29/2008 Page 4 of 22 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 FEJ'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 Affiant had contact with C.W. and S.R. Attorney Edwards' other client, 'f.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- EFTA00221657 Case 9:08-cv-80119-KAM Document 31-2 Entered on FLSD Docket 07/29/2008 Page 5 of 22 Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008 Page 4 of 21 had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein't 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 discitssed. One of those victims was C: W: who at the tithe was not represented, and the was given notice of the agreement. Notice was also provided of an expected change of plea in October 2007. When Epstein's attorneys learned that some of the victims had been -4- EFTA00221658 Case 9:08-cv-80119-KAM Document 31-2 Entered on FLSD Docket 07/29/2008 Page 6 of 22 Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008 Page•5 of 21 •—• 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 deposit ion 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. 1 understand that no contact with that office was made. Attorney EdWards had alluded lci-T.M-.; SO fatNiged him that, to my knowledge, T.M. was still represented by Attorney James Eisenberg. EFTA00221659 Case 9:08-cv-80119-KAM Document 31-2 Entered on FLSD Docket 07/29/2008 Page 7 of 22 Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008 Page 6 of 71 11. 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 a.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. Attomey 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, witlitespeetWthetertifidatiOri ofEinergency, Attorney 13dWards 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- EFTA00221660 Case 9:08-cv-80119•KAM Document 31-2 Entered on FLSD Docket 07/29/2008 Page 8 of 22 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, 1 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. 1 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 CIO day of July, 2008. -7- EFTA00221661 Case 9:08-cv-80119-KAM Document 31-2 Entered on FLSD Docket 07/29/2008 Pate 9 of 22 Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/20 U.S. Department of Justice United Stoles Attorney Southern District of Florida June 7, 2007 DKIVERY BY HAND Miss Cla Re: Crime Victims' and Witnesses' Rights Dear Miss We Pursuanr to the Justice for All Act of 2004, as a victim and/or witness or a federal offense, you have a number of rights. Those rights 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 right 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. if Members of tie U.S. Department of Justice and other federal 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 at 561 209-1047, or Special Agent Nesbitt Kityrkendall fronrlhe Federal Bureau of Investigation at 561 822-5946. You also• can contact thntistice fle-Pitifirenri. Office for Vietiing of Criihe in - Washington, D.C. at 202.307-5983. That Office has a website at www.ove.gov. You can seek lie advice of an attorney with respect to the right's listed above and, if you believe that the rights set forth above are being violated, you have the right to petitiOn the Court for relief. EFTA00221662 Case 9:08-cv-80119-KAM Document 31-2 Entered on FLSD Docket 07/29/2008 Page 10 of 22 Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008 Page 9 0121 MISS SAM JUNE 7, 20O PAGE 2 In addition to these rights, you are entitled in 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 from 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 ipapoinepa or myself immediately. II is possible that someone working on behalf of the targets of the investigation may contact you. Such contact does not viola/tithe law:, However, if you are contacted, you have the choice of speaking to that person or refusing tondo c),' If you refuse and feel that you are being threatened or harassed, then please contact SI or myself You also are entitled to notification of upcoming MC events. At this time, your case is under investigation! If anyone is charged in connection with the investigation, you will be notified. Sincerely, R. Alexander Acosta United States Attorney • ./1 .1 4h /7 cc: By: ff .01 EFTA00221663 Case 9:08-cv-80119-KAM Document 31-2 Entered on FLSD Docket 07/29/2008 P 1 of 22 Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/200 'Nes U.S. Department ofJuslice United States Attorney • Southern District of Florida August I I, 2006 DCLWERY BY HAND Miss Tea 5 Re: Crime Victims' and Witnesses' Rights Dear Miss Malls 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 rights are: (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 deterrnE 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 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. Members of the U.S. Department of Justice and other federal 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 at 561 209-1047, or Special Agent Nesbitt Kuyrkendall from the Federal Bureau of Investigation at 561 8224946, --You also -can-contact. the Justice Dep;rtment's -Office :for Wictims._of-Criras Washington, D.C. at 202.307-5983. 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 set forth above are being violated, you have the right to petition the Court for relief. EFTA00221664 Case 9:08-cv-80119-KAM Document 31-2 Entered on FLSD Docket 07/29/2008 Pau 12 of 22 Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008 Page 11 of 21 Miss Ss AUGUST 11. 2006 PAGE 2 In addition to these rights, you are entitled to counseling and medical services, and bi .• from intimidation and harassment. if the Court determines that you area victim, you entitled to restitution from the perpetrator. A list of counseling and medical service pro . • be provided to• you, if you so desire. If you or your family is subjected to any inlet • harassment, please contact SMIMMINIMISIr myself immediately. It is p. • someone working on behalf of the targets of the investigation may contact you. Such c.a.' not violate the law. However, if you are contacted, you have the choice of speaking to th or refusing to do so. If you refuse and feel that you are being threatened or harassed, Il - Contact You also are entitled to notification of upcoming caseevents. At this time, your .- investigation. if anyone is charged in connection with the investigation, you will be it. Sincerely, R. Alexander Acosta United States Attorney cc: By: EFTA00221665 Case 9:08-cv-80119-KAM Document 31-2 Entered on FLSD Docket _01/29/2008 Paae 13 of 22 Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07,Clbg_VQ6,. Page.la,orZ1 January 10, 2008 Re: Case Numberde Dear Thts case is currently under Investigation. This can be a lengthy process end we request your continued patience while we conduct a thorough investigation. As a crime victim, you have the following rights under 18 United States Code § 3771: (1) The right to be reasonably protected from the accused: (2) The right to reasonable, atone's, and Ornery notice of any public court proceeding, or any parole proceeding, Involving the crime or of any release or escape of the accused: (3) TM right not to be excluded from any such public court proceeding, unless the court, after receiving clear and convincing evidence. determines that testimony by the victim would be materially altered If the victim heard other testimony et that proceeding; (4) The right to be reasonably heard at any public proceeding In the district court invoMng release, plea, sentencing, or any parole proceeding; (5) The reasonable right to confer wall the attorney for the Government in the case; (6) The right to full end timely restitution as provided In law; (7) The right to proceedings free from unreasonable delay; (B) The right to be treated with fairness end with respect for the vIctIm's dignity and privacy. We will make our best efforts to ensure you are accorded the rights described. Most of these rights pertain to events occurring after the arrest or Ind1ctnent of an Individual for the crime. and It wiH become the responsibility of the prosecuting Untied states Attorney's Office to ensure you are accorded those rights. You may also seek the advice of attorney with respect to these rights. The Victim Notification System (VNS) is designed to provide you with direct information regarding the case as a proceeds through the criminal Justice system. You may obtain current Information about this matter on the Internet et WWW.Notly.USDO.I.GOV or from the VNS Call Center at 1-865-D0J-4YOU (1-886.365- 4968) (TDD/TTY: 1-866-2284619) (International; 1.502-2132767). In addidon, you may use the Call Center or Internet to update your contact information end/or change your decision about participation in the notification program. If you update your Information to induct& a current email address. VNS will send information to that address. You Al need the following Victim Identification Number (VIN) '1941737' and' Personal IdentMoation Number (PIN) '5502' 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 last name (or business name) as currently contained in VNS. The name you should enter Is Vieh it 4p ; . et EFTA00221666 Case 9:08-cv-80119-KAM Document 31-2 Entered on FLSD Docket 07/22/2004 Fagg 14 of 22 Case 9:08-tv-80736-KAM Document 14 Entered on FLSD Docket 07-P15/20108 "Page I" orz1 If you have additional Questions which Involve this matter, please contact the office fisted above. When you cat, please provide the file number located it the top of this letter. Please remember. your participation in the notification part of this program is voluntary. In order to, continue to receNe notifications, it Is your reaponsttolltly to keep your contact Information current. Sincerely, 10. EFTA00221667 Case 9:08-cv-80119-KAM Document 31-2 Entered on FLSD DoketD7/29/2008 _P 15 of 22 Case 9:08:cv-80736-KAM Document 14 Entered on FLSD Docket 01"5PL9VUtdopi Page Ifileaw r0T21 January 10, 2008 One Cleartake Center Ste 704 AUstrellan South West Palm Beach, FL 33401 Re: SIMINIESI II Dear You have requested to receive notification* for Taber 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 crime victim, you have the following rights under 18 United States Code § 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 10 be excluded from any such public court proceeding, unless the court, after • receiving clear and convincing evidence, determine* that testimony by the Arlin would be materially altered If the victim heard other testimony at 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 right to confer with the attorney for the Government in the case; (8) The right to full and timely restitution ae 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. We will make our best efforts to ensure you are 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 Attorney's Office to ensure you are accorded those rights. You may eh* seek the advice of a private attorney with respect to these rights. The Victim Nollficati0n System (VNS) is designed to provide you with direct information regarding the case as It proceeds through the criminaljustice system. You may obtain current information about this matter on the Internet at WWW.Notify.USDOLGOV or from the VNS Cat Center at 1.886-D0J-4YOU (1-865.365- 4968) (TDD/TTY: 1-856-228-4619) (International: 1.502.213-2767). In addition, you may uae the Cell Center 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.current email address, VNS will send information to that address. You will need the following Victim Identification Number WIN) '1941741' and Personal Identification Number (PIN) '7750' anytime you contact the Call Center end the first lime you log on to ----VNS-onthelntemek-In addition the:firet time you access theArNS interne( site, you werbe promptedlo enter your last name (or business name) as currently contained in VNS. The name you should enter Is Eisenberg. EFTA00221668 Case 9:08-cv-80119-KAM Document 31-2 Entered on FLSD Doct 9a912/908 A 16 of 22 Case 9:08-ov-8073-6-KAM Document 14 Entered on FLSD Docket 0714b/2 :2 I age t 1- py 1 If you have addlUonel questions which Involve this matter, please contact the office listed above. When you cot. please provide the file number located at the top of this letter. Please remember, your partcipabon in the notlication part of this program is voluntary. In order to continue to receive notritaations, fl is your responsIbllity to keep your contact Information current. Sincerely, EFTA00221669 Case 9:08-cv-80119-KAM Document 31-2 Entered on FLSD Docket 07/29/2 Case 9:0:0v-80736-KAM . Document 14 Entered on FLSD Docket 0-71/ 51-20 Nee May 30, 2008 Re: Dew a Your name was referred to the FBI's 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 throughout 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 nights under federal law. These rights Include notification of the status of the case. The enclosed brochures provide information about the FBI's Victim Assistance Program, resources and instructions for accessing the Victim Notification System (VNS). VNS is designed to provide you with information regarding the status of your case. This case Is currently under investigation. This can bee lengthy process and we request your continued patience while we conduct a thorough investigation. As a crime victim, you have Itie following rights under 18 United States Code § 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 pubfic court proceeding, unless the court, atter • receiving clear and convincing evidence, determines 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 proceedings free from unreasonable delay; (8) The right to be treated with fairness end with respect for the Adler; dignity and privacy. We wit make our beat 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 whl 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 rasped to these rights. The Victim Notification System (VNS) Is designed to provide you with direct information regarding the case sett proceeds-through•the criminaljustice-systemr—You-may obtain-current information about:this matter on the Internet al WWW.Notity.USI30..t.GOV or from the VNS Cell Center at 1.866-D0J-4Y01/ (1-866-355- 4968) (TOWTTY: 1.866.228-4619) (International: 1-502.213.2767). In addition, you may use the Call Center 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 current email address, VNS will send information to that address. You will need the following Victim Identification Number WIN) '2074381' end Personal IdentMcation Number (PIN) '1816' anytime you contact the Call Center end the first time you log or. to VNS on the Internet In addalon, the first lime you access the VNS Internet site, you will be prompted to enter your last name (or business name) as currently contained in VNS. The name you should enter is RUA i EFTA00221670 Case 9:08-cv-80119-KAM Document 31-2 Entered on FLSD Docket 07/29/2008 Page 18 of 22 Caseipt08-ev-80736-KAM Document 14 Entered on FLSD Docket 07146/243087,, Page 01/7taf21 VV Sap" %NO If you have addlUonal questions which Involve tills matter, please contact the office listed above. When you call, please provide the Me number located at the top of this letter. Please remember, your participation in the notification part of this program is voluntary. In order to continue to receive notification, Pt is your responsibility to keep your contact Information current. Sincerely, Cr ••••••••••=rd 70TAL P.07 EFTA00221671 Case 9:08-cv-80119-KAM Document 31-2 Entered on FLSD Docket 017/29/2.908 pa ae 19 of 22 Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/20l98 Page 18 or21 U.S. Department of Justice United States Attorney Southern District of Florida 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: JeffrStgjaa il Vai NOTIFICATION OF IDENTIFIED VICTIM Dear Mr. Edwards: 408111.0 GOVERNMENT EXHIBIT coag Nopgaionc-cv-mmtan EXHIBIT NO, 6 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, QS wit 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- 009381 AXXXMB) 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 —cfefeFfedEril—ploTediTti0-d-iii- fiVor 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 18, United States•Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein EFTA00221672 Case 9:08-cv-80119-KAM Document 31-2 EnterecLoolLSD Docket 07129/29%e M.20 of 22 Case 9:08-cv-80736-KAM Document 14 Entered on t-La.t uocaet ofzuuo BRAD EDWARDS, ESQ. NOTIFICATION OF IDEUTIFIED VICTIM a vellk JUI.Y 9, 2008 PAGE 2 or 2 had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United Stales 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, CiatipWal is an individual whom the United States was prepared to name as a victim of an enumerated offense. t • to t Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300. 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; however, if you do file a claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an enumerated offense, please provide notice of that denial to the undersigned. Please thank your client for all of her assistance during the course of this examination and express the heartfelt regards of myself and for the health and well-being of Ms.:Vtila R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: A cc: Jack Goldberger, Esq. EFTA00221673 Case 9:08-cv-80119-KAM Document 31-2 Entered cm FtSI 989kgM9/2g08 6%9521 of 22 Case 9:08-cv-80736-KAM Document 14 Entered on L D oc e l / age 2 U.S. Department ofilustice United Suites Attorney Southern District of Florida GOVERNMENT EXHIBIT CASE µO.08-8073CCV-MARRA 901IBIT NO. 7 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/SUM RS 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, SWIM ROMP 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- 00938I AXXXMB) 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 .deferfederal_prosccution_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 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein EFTA00221674 Case 9:08-cv-80119-KAM Document 31-2 Entered on_aS8D Nickel J97/29/2008 Pacie122 of 22 Case 9:08-cv-80736-KAM Document 14 Entered on Entered uocitet izuutt rage 21 orz BRAD EDWAltDS, ESQ. NOTIFICATION OF IDENTIFIED VICTIM See JULY 9, 2008 PACE 2 OP 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, a P is an individual whom the United States was prepared to name as a victim of an enumerated offense. Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300. 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; however, if you do file a claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an enumerated offense, please provide notice of that denial to the undersigned. Please thank your client for all of her assistance during the course of this examination . . . . and express the heartfelt regards of myself and the health and well-being of Ms. alp R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: cc: Jack Goldberger, Esq. EFTA00221675