EFTA00191264

Connected People (39)

Referenced in Findings (1)

Extracted Text

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 08-80736-Civ-Marra/Johnson
JANE DOES #1 and #2
I.
UNITED STATES
JOINT STATEMENT OF UNDISPUTED FACTS
The parties hereby stipulate and agree that the following facts are not in dispute and may
be accepted as true:
1. Between about 2001 and 2006, defendant Jeffrey Epstein (a—billienaire—with—signifteant
politieal-eenneetiens)-sexually-abusedinere-than-40 enticed into prostitution minor girls at his
mansion in West Palm Beach, Florida, and elsewhere. Among the girls he sexually            sed so
enticed were Jane Doe #1 and Jane Doe #2. Because Epstein, through others, used a means of
interstate commerce and knowingly traveled in interstate commerce to engage in this conduct,
te-abuse-Jane-Dee-#4-en43ane-Dee-#2-(and-the-ether-vietims), he committed violations of federal
law, specifically repeated violations of 18 U.S.C. § 2422.
2. In 2006, at the request of the Palm Beach Police Department, the Federal Bureau of
Investigation ("FBI") opened an investigation into allegations that Jeffrey Epstein ("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, among other offenses. The
case was presented to the United States Attorney's Office for the Southern District of Florida,
which accepted the case for investigation. The Palm Beach County State Attorney's Office was
EFTA00191264
also investigating the-ease Epstein. See Declaration of Bradley J. Edwards, Esq. at ¶¶ 1-2
(hereinafter "Edwards Declaration").
The FBI determined that both Jane Doe 111 and Jane Doe 112 were ictims of aexual 025auh6
by-Epstein-while-they-were-flinierS-iteginning-when-thest-wete-apprenimately-faufteen-years-ef
age-and-apprenintately-thifteen-years-efage-respeetivelyrEdwards-1)eelaratien-at-11-2,
4. On about June 7, 2007, FBI agents hand-delivered to Jane Doe #1 a standard-G-V-RA-victim
notification letter. See Edwards Declaration, Exhibit "A." The notification promises that the
Justice Department would makes its "best efforts" to protect Jane Doe #1's rights, including
"[tjhe reasonable right to confer with the attorney for the United States in the case" and "to be
reasonably heard at any public proceeding in the district court involving . . . plea . . . ." The
notification further explained that "[a]t this time, your case is under investigation." That
notification meant that the FBI had identified Jane Doe #1 as a potential victim of a federal
offense. and-as-senteene-preteeted-by-the-GVRA:
5. On about August 11, 2007, Jane Doe #2 received a standard CVRA victim notification letter.
See Edwards Declaration, Exhibit "B." The notification promised that the Justice Department
would makes its "best efforts" to protect Jane Doe #2's rights, including "[t]he reasonable right
to confer with the attorney for the United States in the case" and "to be reasonably heard at any
public proceeding in the district court involving . . . plea ...." The notification further explained
that "[a]t this time, your case is under investigation." That notification meant that the FBI had
identified Jane Doe #2 as a potential victim of a federal offense. aftd-as-semeene-proteeted-by
the CVRA.
6. Early-in During the investigation, the FBI agents and the Assistant U.S. Attorney had-several
meetinga met with Jane Doe #1. Jane Doe #2 was represented by counsel that was paid for by
EFTA00191265
the criminal target Epstein and, accordingly, all contact was made through that attorney. Jane
Doe #2 was openly hostile to the investigation, and told investigators that she was not a
victim of any offense, that Epstein was an "awesome man," and that she would consider
marrying Epstein. Jane Doe #2 actively avoided law enforcement's attempts to secure her
cooperation with the investigation and contacted other potential witnesses and victims to
advise them against cooperating with the authorities. Edwards Declaration at ¶ 5.
7.   In and around September 2007, plea discussions took place between Jeffrey Epstein,
represented by numerous attorneys (including lead criminal defense counsel Jay Leflcowitz), and
the U.S. Attorney's office for the Southern District of Florida.,] reptesentect-pciffier-ily-by
Assistent-U7SrAttemey-ArMaFie--WHefefier-ae-plea-diseussiens-genecally-begen-from-Ihe
premise-that-Bpstein-weekl-plead-guilty-et-least-ene-federal-felefty-effense-suFfeunding-his-sexual
tissaults-ef-mere-than-40-miner-girls. Frem-ther-er the-numereus-elefense-attecneys-pfegressively
uegetiated—rnere—favemble—prea—lems—se—thet—gpsteiii—weuld—tiltimetely—plead These plea
negotiations eventually resulted in Epstein pleading guilty to enly two state court felony
offenses with a recommendation of 18 months' imprisonment. end-would-serve-only-emu:4y
Meny-ef-the-negetietiens-Eife-refleetefl-in-e-mails-between-Leflte                       lat
Gepies Parts of the correspondence are attached as Exhibit J to the Edwa

[... truncated, 298,646 characters total]