Court Records
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EXHIBIT A
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IN RE: JANE DOE,
Petitioner.
DECLARATION OF A. VILLAFARA
IN SUPPORT OF UNITED STATES' RESPONSE
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 08-80736-Civ-Marra/ FILED by D.C.
JUL 0 9 2008
STEVEN AL LARIMORE CLERK U.S. DIST. CT. S.D. Dr FLA. . w.RS:
TO VICTIM'S EMERGENCY PETITION FOR ENFORCEMENT
OF CRIME VICTIM RIGHTS ACT, 18 U.S.C. § 3771
1. I, A. Villafafia, 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 fl 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.
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2. 1 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 identified, 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 Ma 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 filed his Motion on behalf of "Jane Doe," without identifying which of _
his clients is the purported victim. Accordingly, 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-
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Nee ••••de
federal agents on May 28, 2008. The FBI'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 A fliant had contact with C. W. and S.R. Attorney other client,
T.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
3The undersigned does not know when Mr. began representing T.M. or whether
T.M. ever formally terminated Mr. Eisenberg's representation.
-3-
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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 AttorneyMI' 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 discussed. One of those victims was C. W.- who at the time was not represented, and she
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
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notified, they complained that the victims were receiving an incentive to overstate their
involvement with Mr. Epstein in order to increase their damages claims. Mile 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 deposition 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 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 to send to me any information that he wanted me to
consider. Nothing was provided. I also advised Attorney that he should consider
contacting the State Attorney's Office, if he so wished. I understand that no contact with that
office was made. Attorney EdWards had.alluded to T.M,, atirlicNiSed him that, to my
knowledge, T.M. was still represented by Attorney James Eisenberg.
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•.•••
• 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 toprovide 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
to provide notice to his clients regarding the hearing. Your Affiant believes that
it was during this conversation that Attorney notified me that he represented T.M.,
and I assumed that he would pass on the notice to her, as well. Attorney 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 I= clients was present.
12. On today's date, your Affiant provided the attached victim notifications to
C.W. and S.R. via their attorney, (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, with respeet tii-theCertifieaticiri of Emergency, Attorney
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 °flu1y 7, 2008, after your Affiant had
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already received the Certification of Emergency and Emergency Petition, I received a letter
from Attorney 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. I 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 CM day of July, 2008.
-7-
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N.-de
U.S. Department of Justice
United States Attorney
Southern District of Florida
300 South Australian Ave , Sully 400
;Vest Pahn Bench, FL 3340)
([Phone Redacted]
Facsimile: (36))820-8777
June 7, 2007
DELIVERY BY HA
Miss ail vidli
Re: Crime Victims' and Witnesses' Rights
Dear Miss Wei
Pursuant to the Justice for All Act of2004, as a victim and/or witness of 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 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. I (
Members of me 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. If you have any concerns in this regard, please feel free to contact me at 561
209-1047, or Special Agent Nesbitt Kuyrkendall frorwthe Federal Bureau of Investigation at 561
822-5946. You also• can contact thrlilifiae Uepartnient's Offiee (Or NietibiS "cif Crithe iii
Washington, D.C. at [Phone Redacted]. Thal Office has a website at www.ovc.gov.
You con seek the advice of an attorney with respect to the righlk listed above and, if you
believe that the tights ::et forth above are being violated, you have the right to petition the Court for
relief.
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•
Miss ONO, a
JUNE 7, 2007
PAGE 2
Inaddition to theserights, 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 Special Agent Kuyrkendall or myself immediately. It is possihle that
someone working on behalf of the targets of the investigation may contact you. Such contact does
not violnelithe law:" However, if you are contacted, you have the choice of speaking to that person
or refusing tedo to. If you refuse and feel that you are being threatened or harassed, then please
• contact Special Agent Kuyrkendall or myself.
You alsoare entitled to notification of upcoming case events. At this time, yourcase is under
investigation) I (anyone is charged in connection with the investigation, you will be notified.
Sincerely,
R. Alexander Acosta
United States Attorney
By:
cc: Special Agent Nesbitt Kuyrkendall, F.B.I.
4.elgeaoruc,_ A. VillafaAa
Assistant United States Attorney
rr
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U.S. Department of Justice
United Slates Attorney
• Southern District of Florida
500 South Australian rivr..Suite 400
Welt Palm °cock f6 33401
([Phone Redacted]
Facsimile: ([Phone Redacted]
August 11, 2006
DELIVERY BY HAND
Miss Tea
Re: Crime Victims' and WitnessesiRighis
Dear Miss Mea
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 pmceeding, 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 retsonable 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
822-3946.---You also can-contact-the Justice .Department.s Office ,fur IZI.171S..0.f -Clime -in
Washington, D.C. at [Phone Redacted]. That Office has a websitc at www.ove.gov.
You can seek the advice of an attorney with respect to the rightslisted above and, if you
believe that the rights set forth above are being violated, you have the right to petition the Court for
relief
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Miss Salt
AUGUST 1 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 are a victim, you
entitled to restitution from the perpetrator. A list of counseling and medical service pit,.
be provided to you, if you so desire. If you or your family is subjected to any Mini •
harassment, please contact Special Agent Kuyrkendall or myself immediately. It is p
someone working on behalf of the targets of the investigation may contact you. Such ctn..
not violate the law. However, if you are contacted, you have the choice of speaking to it):
or refusing to do so. If you refuse and feel that you are being threatened or harassed, IN.
Contact Special Agent Kuyrkendall 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 he it'.'
Sincerely,
R. Alexander Acosta
United States Attorney
By:
A. Villafana
Assistant United States Attorney
cc: Special Agent Nesbitt Kuyrkendall, F.B.I.
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\so •—•
U.S. Department of Justice
Federal Bureau of Investigation
FBI - West Palm Beath
Suite 500
505 South Ehnen Drive
West Palm Beech, Fl. 33401
Phone: ([Phone Redacted]
Fax ([Phone Redacted]
January 10, 2008
Re: Case Number:
Deer
TMs 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 came 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 lo reasonable, accurate, and timely notice of any -
publics court proceeding, or any parole proceeding, 'meeting 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 tiat 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 end timely
restitution es 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 wit 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 t win 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 lo 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.Notty.US00,J.GOV or from the VNS Call Canter at 1-865-00J-4YOU (1-866-365-
4968) (TDD/TTY: [Phone Redacted]) (International: [Phone Redacted]). In addition, you may use the Can
Center or Internet to update your contact information indica change your decision about participation in the
notificedon program. If you update your Information to Include a current email address, VNS will send
information to that address. You wig need the following Victim Identification Number (VIN) '1941737' and'
Personal Identification Number (PIN) '5502' anytime you contact the Ceti Center and the first time you log on to
VNS on the Internal In addition, the first time you access the VNS Internet site, you will be prompted to enter
your last name (or business name) es currently contained in VNS. The name you should enter Is a
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%we
If you have additional questions which involve this matter, please contact the office listed above. When
you cal 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 notifications, it is your
responsibility to keep your contact Information current
Sincerely,
Twiler=
%/cern Specialist
EFTA02741630
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U.S. Department of Justice
Federal Bureau of Investigation
FBI - Weal Palm Beach
Sults 500
505 South Finder Drive
West Palm Beach, FL 33401
Phone: ([Phone Redacted]
Fax: ([Phone Redacted]
January 10, 2006
James Eisenberg
One Cleariake Center Ste 704 Australian South
West Palm Beach, FL 33401
Re: la b
Dear James Eisenberg:
You have requested to receNe notifications for Make
This case is °Jaunt?), 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 Stales Codes 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 thins or of any release or escape of the
accused; (3) The right not to be excluded from any auch 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 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) Tne right to proceedings free horn unreasonable delay: (A) Tne 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 deathbed. Most of these rights
pertain to events occurring after the arrest or Indictment of an individual for the crime, and It will become the
responsiblity or the prosecuting United States Attorney's Office to ensure you are accorded those rights. You
may Bk9O seek the advice of a private attorney with respect to these rights.
The Victim NotlfiCati0n 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.NotIty.USD0J.GOu or from the VNS Call Center al 1.8811-00J.4YOU (1-866-385-
4968) (TOD/TTY: [Phone Redacted]) (International: [Phone Redacted]). In addition. you may use the Cal
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 aourrent email address. VNS will send
information to that address. You MI need the following Victim Identification Number WIN) '1941741' and
Personal Identification Number (PIN) 7760' anytime you contact the Call Center and the first time you log on to
-VNSontheintemel:-In addition. Uro first time you access theiMainternal site, you wilthe prompted:to enter
your last name (or business name) as currently contained in VNS. The name you should enter is Eisenberg.
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If you have additional questions which Involve this matter, please contact the once listed above. When
You call, 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. It is your
responsibility to keep your contact Information current.
Sincerely,
cfr ; Ir.. _an,:tk,
Twiler
Victim fielist
EFTA02741632
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U.S. Department of Justice
Federal Bureau of investigation
FBI • West Palm Beach
Suite 500
505 South Flagler Drive
West Palm Beach, FL 33401
Phone: ([Phone Redacted]
Fax: ([Phone Redacted]
May 30. 2008
Re: IIIIIISOMP011e
Dear a
Your name was referred to the FBI's Victim Assistance Program es 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 lo answer any questions you mey 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 cunently 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 tie accused; (2) The right to reasonable, accurate, and timely notice of any
public court proceeding, or any parole proceeding, involving the crime or of any release or escape of the
accused; (3) The right not to be excluded from any such public court proceeding, unless the court, alter
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 es provided h law; (7) The right to proceedings free from unreasonable delay; (el The right to be
treated with fairness and with respect for the vicbm's dignity and privacy.
We ',soil 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, end 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 (VMS) Is designed to provide you with direct information regarding the
case evil proceedsthroughtecriminaljualicasystemr -You mayobtaln.current informedon about:this matter
on the Internet at WWW.Notify.USDOJ.GOV or from the VMS Cell Center at 1-806-DOJ-4YOU (1-866-365-
4968) (TDOTITY: [Phone Redacted]) (International: [Phone Redacted]). 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 (VIN) 2074381' and
Personal Identification Number (PIN) '1816' anytime you Contact the Call Center end the first time 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 VMS. The name you should enter is lift
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Casetit08-ev-80-736-KAM Document 14 Entered on FLSD Docket 07145/2808, n Page elf7taf 21
• If you have additional questions which Involve this matter, please contact the office listed above. When
you call, please provide the me number located at the lop of this letter. Please remember, your participation
in the notification part of this program le voluntary. In order to continue to receive notifications, It is your
responsibility to keep your contact information current.
Sincerely,
c.
LtA.
Twle
victimrec gist
TOM P.0?
EFTA02741634
Case 9:08-cv-80381-KAM Document 35-1 Entered on FLSD Docket 07/29/2008 Page 19 of 22
Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008 Page 18 of 21
U.S. Department of Justice •
United States Attorney
Southern District of Florida
MSC
GOVERNMENT
EXHIBIT
CASE
NOSH-80736-CV-MARRA
EXHIBIT NO. 6
500 South Australian Ave.. Suite 400
West Palm Beailt FL 33401
([Phone Redacted]
Facsimile: ([Phone Redacted]
July 9, 2008
VIA FACSIMILE
Brad l= Esq.
The Law Offices of Brad 1M& Associates, LLC
2028 Street, Suite 202
Hollywood, Florida 33020.
Re: Jeffrey Epstein/aVai NOTIFICATION OF
IDENTIFIED VICTIM
Dear Mr. a
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, QM.% WIM.
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
defeiriedefirproildiitiiiffil -FfsiVOTtif 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
EFTA02741635
Case 9:08-cv-80381-KAM Document 35-1 Entered on FLSD Docket 07/29/2008 Pane 2_0 of 22
Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008 Page 19-ot 21
BRADS ESQ.
NOTIFICATION OF IDENTIFIED VICTIM C' Vie
Joi.r 9, 2008
PAGE 2 or 2
had been tried federally and convicted o f 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 oldie 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, CamirWal
is an individual whom the United States was prepared to name as a victim of an enumerated
offense. • :is
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, ([Phone Redacted].
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 Special Agents K uyrkendal I and Richards for
the health and well-being of
R. ALEXANDER ACOSTA
UNITED STATES ATTORNEY
V1LLAFANA
ASSISTANT U.S. ATTORNEY
cc: Jack Goldberger, Esq.
EFTA02741636
Case 9:08-cv-80381-KAM Document 35-1 Entered on FLSD Docket 07/29/2008 Pane 21 of 22
Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008 Page 20 of 21
•-•
U.S. Department of Justice
United States Attorney
Southern District of Florida
dame
GOVERNMENT
EXHIBIT
CASE
No.08-8073(-CV.MARRA
EXHIBIT
NO. 7
500 South Australian Ave., Suite 400
West Palm Beach, FL 33401
([Phone Redacted]
Facsimile: ([Phone Redacted]
July 9, 2008
VIA FACSIMILE
BnItargq.
The Law Offices of Brad... Associates, LLC
2028a Street, Suite 202 .
Hollywood, Florida 33020.
Re: Jeffrey Epstein/s a NOTIFICATION OF
IDENTIFIED VICTIM
Dear Mr.
By virtue of this letter, the United States Attorney's Office for the Southern District
of Florida asks that you provide the following notice to your client, a WIMP
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
.defer_federal_prosecution_in_favor_ofithis..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
EFTA02741637
Case 9:08-cv-80381-KAM Document 35-1 Entered on FLSD Docket 07/29/2008 Page 22 of 22
Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008 Page 21 of 21
BRAME. , ESQ.
NOTIFICATION OF IDENTIFIED VICTIM Sea
JULY 9, 2008
PAGE 2 of 2
had been tried federally and convicted of an enumerated offense. For purposes
of implementing this paragraph, the United States shall provide Mr. Epstein's
attorneys with a list of individuals whom it was prepared to name in an
Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
authority interpreting this provision, including any authority determining
which evidentiary burdens if any a plaintiff must meet, shall consider that it is
the intent of the parties to place these identified victims in the same position
as they would have been had Mr. Epstein been convicted at trial. No more; no
less."
Through this letter, this Office hereby provides Notice that your client, 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, ([Phone Redacted].
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 Special Agents Kuyrkendall and Richards for
the health and well-being of Ms. Fallip
R. ALEXANDER ACOSTA
UNITED STATES ATTORNEY
By:
cc: Jack Goldberger, Esq.
A. VILLAFA9A
ASSISTANT U.S. ATTORNEY
EFTA02741638