EFTA00222351.pdf

Case 9:08-dv-80119-KAM Document 31-2 Entered on FLSD Docket 07/29/2008 Page 1 of 22: EXHIBIT A EFTA00222351 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 IN RE: JANE DOE, Petitioner. DECLARATION OF i.. IN SUPPORT OF UNITED STATES' RESPONSE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson FILED by D.C. JUL 0 9 2008 STEVEN M. LAMMORE CLERK U.S. DIST. CT. S.D. OF fu.. W.RD. TO VICTIM'S EMERGENCY PETITION FOR ENFORCEMENT OF CRIME VICTIM RIGHTS ACT, 18 U.S.C. § 3771 1. I, do 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. EFTA00222352 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- EFTA00222353 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- EFTA00222354 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- EFTA00222355 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. EFTA00222356 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- EFTA00222357 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 \es, already received the Certification of Emergency and Emergency Petition, I received a letter from Attorney Edwards that had been sent, via Certified Mail, on July 3, 2008. While that letter urges the Attorney General and the United States Attorney to consider "vigorous enforcement" of federal laws with respect to Jeffrey Epstein, it contains no demand for the .relief requested in the Emergency Petition. 14. 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 em day of July, 2008. -7- EFTA00222358 Case 9:08-cv-80119-KAM Document 31-2 Entered on FLSD Docket 07/29/2008 Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/20 DELIVERY BYIJAND Miss COM Alla U.S. Department of Justice United Stoles Attorney Southern District of Florida June 7, 2007 Re: Crime Victims' and Witnesses' Rights Dear Miss WS Pursuant 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 o f 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 Ml 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 proiecied. If you have any concerns in this regard, please feel free to contact me at LA,/ IL., ' ' " from the Federal Bureau of Investigation at .= You also can contact thF Justice aepliinreiirt °Moe for VietthiS of Crithe it Washington, D.C. at 202.307-5983. That Office has a website at wvAv.ovc.gov. You can seek the 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. EFTA00222359 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 of '21 s-F ...to • MISS SAM JUNE 7,2007 PAGE 2 In addition to these rights, you are entitled to counseling and medical services, and protection from intimidation and harassment. If the Court determines that you arc a victim, you also may be entitled to restitution 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 or myself immediately. 11 is possible that someone working on behalf of the targets of the investigation may contact you. Such contact does not viola ithe law& However, if you are contacted, you have the choice of speaking to that person or refusing Rho to.' tf you refuse and feel that you are being threatened or harassed, then please contact r myself. You alsoareentitled to notification of upcoming case 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 cc: f f I t• EFTA00222360 Case 9:08-cv-80119-KAM Document 31-2 Entered on FLSD Docket 07/29/2008 Pa. e -11 of 22 Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/200,5 Nes U.S. Department of Justice United Stares Attorney • Southern District of Florida 4 !•• lir August I I, 2006 DELAYER Y BY HAND Miss Tea 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. f 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 arc protected. I r you have any concerns in this regard; please feel free to contact me at pm the Federal Bureau of Investigation at MINIM You also can-contact. the Justice Department's -Office :for Wieiims.Of--Critne in 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. EFTA00222361 Case 9:08-cv-80119-KAM Document 31-2 Entered on FLSD Docket 07/29/2008 Pape 12 of 22 Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008 Page 11 or21 miss es AUGUST I I, 2006 PAGE 2 In addition to these rights, you are entitled to counseling and medical services, and i., .• 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 pi,. • be provided to you, if you so desire. If you or your family is subjected to any limit • harassment, please contact[IPMMIIIIIIIMIIar myself immediately. It is p. • someone working on behalf of the targets of the investigation may contact you. Such ow' not violate the law. However, if you are contacted, you have the choice of speaking in tit or refusing to do so. It' you refuse and feel that you are being threatened or harassed, illy Contact Rosispos or myself. You also are entitled to notification of upcoming case events. At this time, your L. investigation. if anyone is charged in connection with the investigation, you will be nil' Sincerely, , R. Alexander Acosta United States Attorney By: cc. :' f EFTA00222362 Case 9:08-cv-80119-KAM Document 31-2 Entered on FLSD Dostset_01/29/2008 Pau 13 of 22 Case 9:08: cy-8074-KAM ,Document 14 Entered on FLSD Docket 0661,o6Z.UUM, ragerAaez1 U.S. Department of Justice Federal Bureau of Investigation F81 - West Palm Beath Suite 500 January 10, 2008 Re: Case Number:de Dear clavell TNe 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, atone's, 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, 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 distrid court InvONIng release, plea, sentencing, or any parole proceeding: (5) The reasonable light to confer with 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 wtil 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 Untied states Attorney's Office to ensure you are accorded those rights. You may also seek the advice of a private attorney with respect to these rights. The Victim Notification 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 about this matter on the Internet at wWW.Noly.US00..I.GOV or from the VMS Call Center at 1-866-DOJ-4Y0U (1-866-365. 4958) (TDD/TTY: 1-866-22B-461g) (International: 1.502-2132767). In addition, 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 will need the following Victim Identification Number (VIN) 1941737' ethd. Personal Identifloatlon Number (PIN) '5502' anytime you contact the Call Center and the first time you tog on to VNS on the Internet. in add Won, the first time you access the VNS Internet sae, you will be prompted to enter your last name (or business name) as currently contained in VNS. The name you should enter Is VS • EFTA00222363 Case 9:08-cv-80119-KAM Document 31-2 Entered on FLSD Docket 07/22/200§. facie 14 of 22 Case 9:08-tv-80736-KAM DOCument 14 Entered on FLSD Docket 07115/2008 "Page `1, 17r21 \-0 Newry If you have additional Questions which Involve this matter, please contact the office fisted above. When you cal, please provide the file number located it the top of this letter. Please remember. your participation in the notincation pall of this program is voluntary. In order to, continue to receive notificationS, it is your responsibility to keep your contact Information current. Sincerely: EFTA00222364 Case 9:08-cv-80119-KAM Document 31-2 Entered on FLSD Docket 1029/29108 . Paae 15 of 22 Case 9:08:cv-80.736-KAM Document 14 Entered on FLSD Docket 0744c5PL9-WVDI Page attgeor21 ' %mon U.S. Department of Justice Federal Bureau of Investigation FBI - West Palm Beach January 10, 2008 n_ _ _ Ste 704 Mittman South Weal Palm Beach, FL 33401 Re: Wan Dear You have requested to receive notifications for as 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 aims victim, you have the following rights under 18 United States Code § 37711 (1) The right to be reasonably protected from the, accused: (2) The right to reasonable, aCcursie, 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, after • receiving clear and convincing evidence, determines that testimony by the Actin would be materially altered If tie 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 (or the Government in the ease; (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 aka seek the advice of a private attorney with respect to these rights. The Victim Notification System (VNS) is designed to provide you wtth direct information regarding the case as It proceeds through the criminal justice system. You may obtain current IrdormatIon about this matter on the Internet at WWW.Notify.USDOJ.GOV or from the VNS Call Center at 1.886-OOJ-4YOU (1-886.386- 4968) (TDD/TTY; 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 wilt send information to that address. You will need the following Victim Identification Number (VIN) '1941741' and Personal Identification Number (PIN) 7760' anytime you contact the Call Center and the first time you log on to —VNS-orytheintemeirin addlbOn, thefirat time you access theWNS internal she, you wIll.be prOrnptedito enter your last name (or business name) as currently contained In VNS. The name you should enter is Eisenberg. EFTA00222365 Case 9:08-cv-80119-KAM Document 31-2 Entered on FLSD Docket Q7/29/2908 Panei 6 of 22 Case 9:08-ov-89736-KAM Document 14 Entered on FLSD Docket 07/4b/QM6-nlFage tb' t isvrzi If you have additional questions whIChinvOlve this matter, please Canted the office listed above. When you call, please provide the file number located et the top of this letter. Please remember, your participation in the notification part of this program Is voluntary. In order to continue to receive notifications, It is your responsibility to keep your contact Information current. sincerely. • EFTA00222366 Case 9:08-cv-80119-KAM Document 31-2 Entered on FLSD Docket 07/29/ Case 9:0:0v-80736-KAM Document 14 Entered on FLSD Docket 071/51-20 Nee U.B. Department of Justice Federal Bureau of investigation FBI - West Palm Beach May 30, 2008 Re: Deer - Your name was referred to the FBI's Victim Assistance Program as being a possible vIcUm 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 FBI's effort to ensure the victims are treated with respect and are provided information about their rights under federal law. These rights Include notification of the status of the case. The enclosed brochures provide information about the 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 cunenly 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 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 pale 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 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 vicUrrte dignity and privacy. We wit make our best efforts to ensure you ere accorded the rights described. Most of these rights pertain to events occurring after the arrest or indictment of an Individual for the crime, and it will become the responsibility of the prosecuting United States Attorney's Office to ensure you are accorded those rights. You may also seek the advice of a private attorney with respect to these rights. The Victim Notification System (VNS) Is designed to provide you with direct information regarding the case asit proceeds through criminal•justice-system-You-may obtain-current information about:this matter on the Internet al ININW.Notity.USDO../.GOV or from the VNS Cell Center at 1.866-DOJ-4YOU (1-866-355- 4965) (TOOrTTY: 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' and Personal Identification Number (PIN) '1816' anytime you contact the Call Center end the first IlMe you log or. to VNS on the Internet In addition, 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 EFTA00222367 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 07445/243087,, Page W7taf21 VV 41•2•1 %ENO II you have additional questions which involve fills matter, please contact the office listed above. When you cell, please provide the file 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 notifications, 11 is your responsibility to keep your contact information current. Sincerely, TOTAL P.07 EFTA00222368 Case 9:08-cv-80119-KAM Document 31-2 Entered on FLSD Docket 017/29/2008 pa ae 19 of 22 Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/20I08 Page 18 or-21 U.S. Department of Justice `AI United States Attorney Southern District of Florida 40810.0 GOVERNMENT EXHIBIT CASE NO.0x-130:16-CV-MARRA EXHIBIT NO, 6 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: Jefhathsni±Allae l/ Vai 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, Cak 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 --d-eferIedEfirpi-WediitiatrilifriVarof An 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 StatesCode, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein EFTA00222369 Case 9:08-cv-80119-KAM Document 31-2 EnterecLoolLSD Dackat 07/29/2008 Pacia?0 of 22 Case 9:08-cv-80736-KAM Document 14 Entered on t-Li) uocKet utri o/duuo Kage lv z BEAD EDWARDS, ESQ. NOTIFICATION OF IDEWTIFIED 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 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, CurneWal 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 or the health and well-being of Ms. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: cc: Jack Goldberger, Esq. EFTA00222370 Case 9:08-cv-80119-KAM Document 31-2 Entered cm Fb9 989%936p/29,08 6'95,21 of 22 Case 9:08-cv-80736-KAM Document 14 Entered on L D oc e / age 2 U.S. Department ofilustice United Slates Attorney Southern District of Florida GOVERNMENT EXHIBIT CASE µO.08-8073C.-CV-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/SUMP F 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, sum Res 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- 009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be followed by an additional six months' imprisonment, followed by twelve months of Community Control 1, with conditions of community confinement imposed by the Court. In light of the entry of the guilty plea and sentence, the United States has agreed to .deferfederal_prosecution_in_favor_of .this..state plea and sentence, subject to certain conditions. One such condition to which Epstein has agreed is the following: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein EFTA00222371 Case 9:08-cv-80119-KAM Document 31-2 Entered on_aSDI Docket .07/29/2008 Paae122 of 22 Case 9:08-cv-80736-KAM Document 14 Entered on Entered uocket utrio/zuuo rage 21 orz BRAD EDWAltDS, ESQ. NOTIFICATION OF IDENTIFIED VICTIM Sant JULY 9, 2008 PAOC 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, Srl 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. lap By: cc: Jack Goldberger, Esq. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY for EFTA00222372