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54. On September 25, 2007, the line prosecutor sent an email to Lefkowitz, (I) expressing 
what .called "bias" against plaintiffs' attorneys, (2) trying to set up an arrangement whereby 
Epstein's victims would not be represented by various private attorneys, and (3) arguing instead 
for an attorney in Miami who could help keep things concealed: "They 
I are all very good personal injury lawyers, but I have 
concerns about whether there would be an inherent tension because they may feel that THEY 
might make more money (and get a lot more press coverage) if they proceed outside the Terms 
of the plea agreement. (Sorry — I just have a bias against plaintiffs' attorneys.) One nice thing 
about Bert is that he is in Miami where there has been almost no coverage of this case."68
55. On September 26, 2007, the line prosecutor sent an e-mail to Lefkowitz in which ■ 
stated: "[Ii Jay — Can you give me a call atIM[xxx-xxxx] this morning? I am meeting with the 
agents and want to give them their marching orders regarding what they can tell the girls."69
56. On September 27, 2007, the attorney appointed by the Office to represent the 
victims—without the knowledge of the victims—emailed the Office asking questions about the 
assignment, including whether he could see a copy the indictment or plea agreement "so that we 
understand exactly what Epstein concedes to in the civil case.s70
57. On September 27, 2007, upon inquiry from the Office, Lefkowitz responded by stating 
that the attorney representative "certainly [] should not get a copy of any indictment."71
68 REP WPB 000384 (Exhibit 70). 
69 Exhibit 26; US_Aity_Cor. at 359 (Exhibit 71). 
7° 000574-000575 (Exhibit 72). 
71 RFP WPB 001687 (Exhibit 73). 
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58. On September 27, 2007, the line prosecutor informed Epstein's counsel of concerns 
raised by the attorney representative for the girls selected by the Government and paid for by 
Epstein. Specifically, "Mlle concern is, if all 40 girls decide they want to sue, they don't want to 
be in a situation where Mr. Epstein says this is getting too expensive, we won't pay anymore 
attorneys' fees."72
59. On September 27, 2007, the line prosecutor sent an email to state prosecutors 
and 
"Can you let me know when Mr. Epstein is going to enter his 
guilty plea and what judge that will be in front of? I know the agents and I would really like to 
be there, `incognito.'" The fact that they intended to be at the plea proceeding "incognito" is 
evidence that they did not intend to notify the victims of the proceeding.73
60. On October 3, 2007, the U.S. Attorney's Office sent a proposed letter that would have 
gone to a special master for selecting an attorney representative for the victims under NPA's 
compensation procedure. The letter described the facts of the Epstein case as follows: "Mr. 
Epstein, through his assistants, would recruit underage females to travel to his home in Palm 
Beach to engage in lewd conduct in exchange for money. Based upon the investigation, the 
United States has identified 40 young women who can be characterized as victims pursuant to 18 
U.S.C. § 2255. Some of those women went to Mr. Epstein's home only once, some went there 
as many as 100 times or more. Some of the women's conduct was limited to performing a 
72 Exhibit 23. 
73 REP WPB 002046 (Exhibit 74). 
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topless or nude massage while Mr. Epstein masturbated himself. For other women, the conduct 
escalated to full sexual intercourse.s74
61. On October 10, 2007, Lefkowitz sent a letter to U.S. Attorney =, 
stating, in 
pertinent part: "Neither federal agents nor anyone from your Office should contact the identified 
individuals to inform them of the resolution of the case, including appointment of the attorney 
representative and the settlement process. Not only would that violate the confidentiality of the 
agreement, but Mr. Epstein also will have no control over what is communicated to the identified 
individuals at this most critical stage. We believe it is essential that we participate in crafting 
mutually acceptable communication to the identified individuals." The letter further proposed 
that the attorney representative for the victims be instructed that "[t]he details regarding the 
United States's investigation of this matter and its resolution with Mr. Epstein is confidential. 
You may not make public statements regarding this matter."75
62. On October 18, 2007, the U.S. Attorney met with Lefkowitz in person for breakfast. 
Meanwhile, the victims had still not been notified of the NPA.76
63. On October 23, 2007, Lefkowitz sent a letter to U.S. Attorney 
, which stated: "I 
also want to thank you for the commitment you made to me during our October 12 meeting in 
which you . . . assured me that your Office would not . . . contact any of the identified 
individuals, potential witnesses, or potential civil claimants and their respective counsel in this 
matter?" 
74 RFP WPB 000411-000412 (Exhibit 75). 
77 REP MIA 000015.000016 (Exhibit 76). 
76 REP WPB 002020-002021 (Exhibit 77). 
J7 Exhibit 67 (emphasis added). 
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64. On October 24, 2007, AUSA anent 
a letter to Jay Lefkowitz, proposing an 
Addendum to the NPA clarifying the procedures for the third-party representative for the victims 
under the NPA's compensation procedures." 
65. On October 25, 2007, AUSA 
sent a letter to Ret. Judge 1. 
about 
selecting an attorney to represent the victims under the NPA's compensation procedure.79
LACK OF VICTIM NOTIFICATION AFTER THE NPA WAS SIGNED 
66. After the NPA was signed, the Office regarded the agreement as having "an express 
confidentiality provision.s80
67. By entering into the confidentiality provision, the Office put itself in a position that 
conferring with the crime victims—including Jane Doe 1, Jane Doe 2, and other similarly-
situated victims—about the co-conspirator immunity provision and the NPA's non-prosecution 
provisions would have violated the confidentiality provision of the agreement.8I
68. The confidentiality provision was a contractual prohibition, binding on the U.S. 
Attorney's Office, against disclosing the terms of the NPA.82
69. Epstein was well aware of this failure to notify the victims and, indeed, arranged for 
this failure to notify the victims.83
70. On about October 26 or 27, 2007, after the initial plea agreement was signed, FBI 
agents contacted Jane Doe 1. Special Agents E. 
16 US_Atty_Cor. 00220-00226 (Exhibit 78). 
" 
000551-000554 (Exhibit 79). 
i 0 Exhibit 64 at 4. 
E1 Exhibit 62. 
t2 
67 Id.; Exhibit 63 at 4-6, 18-19, 22-23, 28-29; Exhibit 64 at 4-5; Exhibit 69. 
24 
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person with Jane Doe 1. During this litigation, the Special Agents have said that they explained 
that Epstein would plead guilty to state charges involving another victim, he would be required 
to register as a sex offender for life, and he had made certain concessions related to the payment 
of damages.84
71. During this meeting, the Special Agents did not explain that an agreement had already 
been signed that precluded any prosecution of Epstein for federal charges for crimes committed 
against Jane Doe 1 or the many other victims cooperating with the federal investigation.85
72. The Special Agents also did not explain that an agreement had already been signed 
that precluded any prosecution of Epstein's co-conspirators, including 
who had 
personally sexually abused Jane Doe 1 at the direction of Epstein. Because the plea arrangement 
had already been reached with Epstein, the agents made no attempt to secure Jane Doe l's view 
on the proposed resolution of the case or to confer with her about it.86
73. Jane Doe 1 did not get the opportunity to meet or confer with the attorney for the 
Government in the case about any potential federal deal that related to her or the crimes Epstein 
committed against her.87
74. The agents could not have revealed the immunity features of the NPA without 
violating its terms, which required that the Government "provide notice to Epstein before making 
... disclosure" of the NPA." 
" Exhibit 26. 
" Exhibit 62; Exhibit 26; Exhibit 63 at 4-6, 18-19, 22-23. 
36 Id 
87 Id.
88 Id 
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75. Jane Doe 1's understanding of the Special Agent's explanation was that only the state 
portion of the Epstein investigation was being resolved, and that the federal investigation in 
which she was participating would continue. This understanding is consistent with the future 
communication she received.B9
76. In addition to Jane Doe 1, FBI agents talked to only two other victims out of the 34 
identified victims about the "general terms" of the NPA, including the provision providing a 
federal civil remedy to the victims.90
77. After these meetings with three victims, Epstein's defense team complained. At that 
point, the U.S. Attorney's Office decided not to make any notifications about the NPA to any 
victim 91
78. Other than the three victims mentioned above, the United States did not inform any of 
the victims of anything about the status of the case or any plea discussions with Epstein, 
including even the existence of the NPA.92
79. On about November 27, 2007, AUSA 
sent an e-mail to Leflcowitz, (with a 
cc to U.S. Attorney—) stating that the Office had a statutory obligation to notify the victims 
about Epstein's plea to state charges that was part of the NPA: 
The United States has a statutory obligation (Justice for All Act of 2004) to notify 
the victims of the anticipated upcoming events and their rights associated with the 
agreement entered into by the United States and Mr. Epstein in a timely fashion. 
Tomorrow will make one full week since you were formally notified of the 
selection. I must insist that the vetting process come sir 
Therefore, unless 
you provide me with a good faith objection to Judge 
selection [as special 
n Exhibit 26; Exhibit 63 at 4-6, 18-19, 22-23, 28-29; [DE 58] (Exhibit 80) at 11. 
9° RFP MIA 000408 (Exhibit 81); Exhibit 64 at 4. 
9' Exhibit 64 at 5. 
n Exhibit 62; Exhibit 65 at 57; Exhibit 64 at 4-5. 
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master for selecting legal counsel for victims pursuing claims against Epstein] by 
COB tomorrow, November 28, 2007, I will authorize the notification of the 
victims. Should you give me the go-head on [victim representative] . . . selection 
by COB tomorrow, I will simultaneously send you a draft of the letter. I intend to 
notify the victims by letter after COB Thursday, November 29th." 
80. On November 28, 2007, the Government sent an email to Lefkowitz attaching a letter 
dated November 29, 2007 (the apparent date upon which it was intended to be mailed) and 
explained that "I am writing to inform you that the federal investigation of Jeffrey Epstein has 
been completed, and Mr. Epstein and the U.S. Attorney's Office have reached an agreement 
containing the following terms." The proposed letter then spelled out a number of the provisions 
in the NPA, including that because Epstein's plea to state charges was "part of the resolution of 
the federal investigation," the victims were "entitled to be present and to make a statement under 
oath at the state sentencing."94
81. On November 28, 2007, Lefkowitz sent an email to U.S. Attorney 
(with a copy 
to AUSA =) 
objecting to victim notifications: 
We do, however, strongly and emphatically object to your sending a letter to the 
alleged victims. Finally, we disagree with your view that you are required to 
notify the alleged victims pursuant to the Justice for All Act of 2004.... 
Furthermore, if a letter is to be sent to these individuals, we believe we should 
have a right to review and make objections to that submission prior to it being 
sent to any alleged victims.... [fit it should happen only after Mr. Epstein has 
entered his plea." 
82. The Government complied with such direction and failed to inform the victims of the 
NPA until after Epstein entered his plea. On November 29, 2007, Lefkowitz sent a letter to U.S. 
Attorney 
objecting to the proposed victim notification letter, stating that it is 
" US_Atty_Cor. at 00255-00262 (Exhibit 82) (emphasis rearranged). 
" RFP WPB 000429 (Exhibit 83); RFT MIA 000011-000014 (Exhibit 84). 
" Exhibit 26 (emphasis added). 
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inappropriate for any letter to be sent to the victims before Epstein entered his plea or had been 
sentenced. Lefkowitz also told the Government that the victims should not be invited to the state 
sentencing, that they should not be encouraged to contact law enforcement officials, and that 
encouraging the attorney representative to do anything other than get paid by Epstein to settle the 
cases was to encourage an ethical conflict." 
83. On about November 30, 2007, U.S. Attorney 
sent a letter to one of Epstein's 
defense attorneys, Ken Starr, stating: "I am directing our prosecutors not to issue victim 
notification letters until this Friday at 5 p.m., to provide you with time to review these options 
with your client." The letter also explained that the line prosecutor had informed 
"that 
the victims were not told of the availability of Section 2255 relief during the investigation phase 
of this matter" despite the fact that the "Mule of law . . . now requires this District to consider 
the victims' rights under this statute in negotiating this Agreement.s97
84. Because of concerns from Epstein's attorneys, the U.S. Attorney's Office never sent 
the proposed victim notification letters discussed in previous paragraphs to the victims or 
anything discussing any of the NPA provisions.98
85. On December 5, 2007, Starr sent a letter to U.S. Attorney 
(with copy to AUSA 
asking about issuance of victim notification letters and stating: "While we believe that it 
is wholly inappropriate for your Office to send this letter under any circumstances, it is certainly 
inappropriate to issue this letter without affording us the right to review it."99
96 RIP MIA 000007-000010 (Exhibit 85). 
"RFP MR 000501-507 (Exhibit 86). 
"Exhibit 26; RFP MIA 000025-000037 (Exhibit 87). 
" Exhibit 76. 
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86. On about December 6, 2007, 
sent a letter to Lefkowitz again recognizing the 
rights of the victims, and also recognizing that the victims had not yet been afforded any rights, 
despite the fact that the NPA was signed months earlier. The letter stated: 
[E]ach of the listed individuals are persons whom the Office identified as victims. 
[T]he Office is prepared to indict Mr. Epstein based upon Mr. Epstein's 
`interactions' with these individuals. This conclusion is based upon a thorough 
and proper investigation - one in which none of the victims was informed of any 
right to receive damages of any amount prior to the investigation of her claim. 
RN Office can say, without hesitation, that the evidence demonstrates that each 
person on the list was a victim of Mr. Epstein's criminal behavior. 
Finally, let me address your objections to the draft Victim Notification Letter. 
You write that you don't understand the basis for the Office's belief that it is 
appropriate to notify the victims. Pursuant to the `Justice for All Act of 2004,' 
crime victims are entitled to: `The right to reasonable, accurate, and timely notice 
of any public court proceeding ... involving the crime' and the `right not to be 
excluded from any such public court proceeding....' 18 U.S.C. § 3771(a)(2) & 
(3). Section 3771 also commands that `employees of the Department of Justice .. 
. engaged in the detection, investigation, or prosecution of crime shall make their 
best efforts to see that crime victims are notified of, and accorded, the rights 
described in subsection (a).' 18 U.S.C. § 3771(c)(1).... 
With respect to notification of the other information that we propose to disclose, 
the statute requires that we provide a victim with the earliest possible notice of: 
the status of the investigation, the filing of charges against a suspected offender, 
and the acceptance of a plea. 42 U.S.C. 10607(c)(3). Just as in 18 U.S.C. 3771, 
these sections are not limited to proceedings in a federal district court. Our Non-
Prosecution Agreement resolves the federal investigation by allowing Mr. Epstein 
to plead to a state offense. The victims identified through the federal investigation 
should be appropriately informed, and our Non-Prosecution Agreement does not 
require the U.S. Attorney's Office to forego its legal obligations. 
[T]he Office believes that it has proof beyond a reasonable doubt that each listed 
individual was a victim of Mr. Epstein's criminal conduct while the victim was a 
minor. The law requires us to treat all victims "with fairness and with respect for 
the victim's dignity and privacy." 18 U.S.C. 3771(a)(8).10° 
100 US_Atty_Cor. 190-193 (Exhibit 88) (emphasis added). 
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The letter included a footnote stating: "Unlike the State's investigation, the federal investigation 
shows criminal conduct by Mr. Epstein at least as early as 2001, so all of the victims were 
minors at the time of the offense.s101
87. On December 7, 2007, defense attorney Lilly Ann Sanchez sent a letter to AUSA 
requesting "that the Office hold off on sending any victim notification letters." The 
Government complied.102
88. While discussing with defense counsel changes in the October 2007 Addendum and in 
a December 19, 2007 letter from the U.S. Attorney to Attorney Lilly Ann Sanchez, the U.S. 
Attorney's Office did not confer with any of the victims about these modifications to the NPA. 
89. On December 13, 2007, the line prosecutor sent a letter to Lefkowitz confirming that 
the Government had earlier stopped making victim notifications because of objections from 
Epstein's criminal defense counsel: "You raised objections to any victim notification, and no 
further notifications were done."103 The December 13, 2007 letter reveals it would have been 
possible to confer with victims about the NPA. The U.S. Attorney's Office was able to confer 
constantly with Epstein's counsel about the parameters of the NPA, but intentionally declined to 
confer with Epstein's victims about the Agreement.104
90. On December 19, 2007, U.S. Attorney 
sent a letter to Lilly Atm Sanchez 
stating, "I understand that the defense objects to the victims being given notice of time and place 
of Mr. Epstein's state court sentencing hearing. We intend to provide victims with notice of the 
101 RFP WPB 000620 (Exhibit 89). 
1°2 RFP WPB 001557 (Exhibit 90). 
103 Exhibit 24; Exhibit 69; RFP MIA 00469 (Exhibit 91). 
104 Id.
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federal resolution, as required by law. We will defer to the discretion of the State Attorney 
regarding whether he wishes to provide victims with notices of the state proceedings.105
91. In about early January 2008, as the result of pressure from Epstein's attorneys, 
agreed with Epstein's attorneys "that there were significant irregularities with the deferred 
prosecution agreement" and "called a time-out." 
At that time, 
asked the Child 
Exploitation and Obscenity Section of the Justice Department's Criminal Division, located in 
Washington, D.C., to look at the case.106
CONCEALING THE NPA WHILE EPSTEIN SOUGHT REVIEW 
92. Following the entry of the "time out," any requirement that Epstein carry out his 
obligations under the NPA was delayed while he sought higher level review within the Justice 
Department. During this review, the victims were not told about the existence of the NPA.107
93. On January 10, 2008, Jane Doc 1 and Jane Doe 2 received victim notification letters 
from the FBI advising them that "[t]his case is currently under investigation. This can be a 
lengthy process and we request your continued patience while we conduct a thorough 
investigation."I°8
94. The January 10, 2008, notification letter did not disclose that the federal cases in the 
Southern District of Florida involving Jane Doe 1 and Jane Doe 2 were the subject of the NPA 
in 
US Atty_Cor. 00272-00273 (Exhibit 92); RFP MIA 000038-000040 (Exhibit 93); RFP MIA 00041-00047 
(Exhibit 94); RFP MIA 000048-000052 (Faikap5). 
106 Exhibit 91 (email from Lefkowitz to a, 
dated February 29, 2008, and noting that it had been nearly two 
months since the "time out" agreement). 
107 Exhibit 26; Exhibit 27; RFP WPB 001616-001623 (Exhibit 96); Exhibit 63 at 4-5, 18-19, 22-29. 
108 January 10, 2008 Victim Notification Letter to Jane Doe I (Exhibit 97) (emphasis added); January 10, 2008 
Victim Notification Letter to Janc Doc 2 (Exhibit 98). 
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entered into by Epstein and the U.S. Attorney's Office discussed previously, or that there had 
been any potentially binding resolution.109
95. On about January 10, 2008, other victims similarly-situated to Jane Doe 1 and Jane 
Doe 2 received letters identical in substance to those described in the immediately preceding 
paragraphs."° 
96. In early 2008, Jane Doe 1 and Jane Doe 2 believed that criminal prosecution of 
Epstein was extremely important. They also desired to be consulted by the FBI or other 
representatives of the Federal Government about the prosecution of Epstein. In light of the 
letters that they had received around January 10, 2008, they reasonably believed, as was 
obviously intended by the letters, that a federal criminal investigation of Epstein was on-going—
including investigation into Epstein's crimes against them. 'They also reasonably believed that 
they would be contacted by and have an opportunity to confer with federal prosecutors before the 
Federal Government reached any final resolution of that investigation.' 
97. On January 31, 2008, Jane Doc 1 met with FBI Agents and AUSA's from the U.S. 
Attorney's Office. She provided additional details of Epstein's sexual abuse of her. The 
AUSA's did not disclose to Jane Doe I at this meeting that they had already negotiated a NPA 
with Epstein.112
98. On March 19, 2008, the line prosecutor sent a lengthy email to a prospective pro bono 
attorney for one of Epstein's victims who had been subpoenaed to appear at a deposition. The 
109 Id 
11° Exhibit 63 at 4-5, 18-19, 22-29. 
III Exhibit 63 at 4-6, 18-19, 22-23, 28-29; Exhibit 26; Exhibit 27. 
112 Exhibit 33. 
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email listed the attorneys representing Epstein, the targets of the investigation, and recounted in 
detail the investigation that had been conducted to that point. The email did not reveal the fact 
that Epstein had signed the NPA in September 2007."3
99. On May 30, 2008, Jane Doe 5 (another client of the undersigned), who was recognized 
as an Epstein victim by the U.S. Attorney's Office, received a letter from the FBI advising her 
that "[t]his case is currently under investigation. This can be a lengthy process and we request 
your continued patience while we conduct a thorough investigation."11° The statement in the 
notification letter was misleading. The letter did not disclose the NPA already entered into by 
Epstein and the Office, and instead implied that the Office was still investigating Epstein and had 
not decided how to proceed with the case, neither of which was accurate.115
100. The May 30, 2008, victim letter to Jane Doe 5 also acknowledged the victims' rights 
under the CVRA at the same time as the Office was not disclosing the NPA's existence to Jane 
Doe 5 and the other victims.116
101. In mid-June 2008, Mr. Edwards contacted the line AUSA handling the case to inform 
her that he represented Jane Doe 1 and, later, Jane Doe 2. Mr. Edwards asked to meet to provide 
information about the federal crimes committed by Epstein against these victims, hoping to 
secure a significant federal indictment against Epstein, consistent with his clients' desires. The 
line prosecutor and Mr. Edwards discussed the possibility of federal charges being filed in the 
" 3 Exhibit 40. 
" 4 Exhibit 29. 
I" td. 
116 Exhibit 28; Exhibit 62. 
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future. Mr. Edwards was lead to believe federal charges could still be filed, with no mention 
whatsoever of the existence of the NPA or any other possible resolution to the case.'" 
102. At the end of the call, the line prosecutor asked Mr. Edwards to send any information 
that he wanted considered by the Office in determining whether to file federal charges. Because 
of the confidentiality provision that existed in the plea agreement, the line prosecutor did not 
inform Mr. Edwards that months earlier, in September 2007, the Office had reached an 
agreement not to file federal charges. The line prosecutor also did not inform Mr. Edwards that 
resolution of the criminal matter was imminent.118
103. On June 19, 2008, Mr. Edwards sent an email to the line prosecutor requesting to 
meet in person to confer with the Government regarding the status of his clients' case.' 19 
104. Because the line prosecutor did not tell Mr. Edwards about the NPA, Mr. Edwards 
was not able to confer with the prosecutor about the NPA on behalf of his clients. Mr. Edwards, 
however, made it perfectly clear that his clients wanted to confer with the prosecutor before any 
resolution was reached. Epstein was aware of this continued concealment of the NPA from the 
victims and, indeed, sought this concealment.12°
105. On June 23, 2008, the line prosecutor sent an email to Lefkowitz stating that the 
Deputy Attorney General had completed his review of the Epstein matter and "determined that 
federal prosecution of Mr. Epstein's case [wa]s appropriate. Accordingly, Mr. Epstein ha[d] until 
117 Exhibit 63 at 4-6, 18-19, 22-23, 28-29; Exhibit Mat 5-6. 
1S Id.; US_Atty_Cor. 0321 (Exhibit 99). 
19 REP WPB 001894 (Exhibit 100). 
12e Exhibit 63 at 4-6, 18-19, 22-23, 28-29; Exhibit M at 5-6; Exhibit 99. 
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the close of business on Monday, June 30, 2008, to comply with the terms and conditions of the 
agreement between the United States and Mr. Epstein."12I 
EPSTEIN'S ENTRY OF HIS GUILTY PLEA 
106. On and before June 30, 2008, the Government and Epstein's attorneys corresponded 
extensively (often multiple times on any given day) regarding Epstein's entry of his guilty plea. 
Throughout the course of these communications, the Government and Epstein operated on the 
agreement that the victims would not be told about the NPA, much less about the fact that 
Epstein's plea was a triggering event for the federal case being resolved.ln 
107. On about June 27, 2008, the U.S. Attorney's Office called Mr. Edwards to provide 
notice to his clients regarding the impending Monday morning hearing. The notice, however, 
was only that Epstein was pleading guilty to state solicitation of prostitution charges involving 
other victims—not Mr. Edwards' clients nor any of the federally-identified victims. The U.S. 
Attorney's Office did not tell Mr. Edwards that the guilty pleas in state court would bring an end 
to the possibility of federal prosecution pursuant to the plea agreement.123
108. In fact, the U.S. Attorney's Office did not disclose to Edwards the fact that the guilty 
pleas in state court had any bearing on the cases of Jane Doe 1 and Jane Doe 2. As a result, Jane 
Doe 1 and Jane Doe 2 did not attend the plea hearing.124
121 Exhibit 40. 
13t Exhibit 26; Exhibit 27; Exhibit 62; Exhibit 63 at 4.6, 18-19, 22-23; Exhibit 99; REP WPB 000512-000513 
(Exhibit 101). 
123 Exhibit 62; Exhibit 63 at 4-6, 18-19, 22-23; Exhibit 99; Exhibit 101. 
124 Exhibit 26; Exhibit 27; Exhibit 62; Exhibit 63 at 4-6, 18-19, 22-23; Exhibit 99; Exhibit 101; Declaration of Brad 
Edwards (Exhibit 102). 
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109. Had they known that the plea agreement in state court made it impossible to prosecute 
Epstein federally for his crimes against them, they would have objected to this resolution and 
would have certainly attended the hearing.I25
110. On or before June 30, 2008, the Office prepared a draft victim notification to be sent 
to the victims—a letter that it intended to show to both Epstein and Jack Goldberger, as reflected 
by a place for the initials of both Epstein and Goldberger on the document. The notification was 
designed to inform the victims of the provisions of deferral of federal prosecution in favor of 
state charges. The notification letter began by describing Epstein's guilty plea in the past tense: 
"On June 30, 2008, Jeffrey Epstein ... entered a plea of guilty to violations of Florida statutes 
forbidding the solicitation of minors to engage in prostitution and felony solicitation of 
prostitution." Later, a substantively identical letter was prepared for Epstein's and Guy Lewis' 
review. 126 
III. On June 30, 2008, the Office sent an e-mail to Goldberger reflecting continuing 
efforts to keep the NPA secret: "Jack: The FBI has received several calls regarding the Non-
Prosecution Agreement. I do not know whether the title of the document was disclosed when the 
Agreement was filed under seal, but the FBI and our office arc declining comment if asked."'" 
112. On June 30, 2008, Epstein plead guilty to state law solicitation of prostitution charges. 
Because the Federal Government failed to notify the victims about the NPA or its arrangements 
with Epstein, neither Jane Doe 1, Jane Doe 2, Jane Doe 5, nor any of the identified victims in the 
123 Exhibit 26; Exhibit 27; Exhibit 63 at 4-6, 18-19, 22-23; Exhibit 99; Exhibit 101; Exhibit 102. 
In US. Atty_Cor. 00323 (Exhibit 103); RIP WPB 000515-000520 (Exhibit 104). 
in  Exhibit 99. 
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federal case were aware of the ramifications of the state proceeding (either in person or through 
counsel).128
113. Immediately following the June 30, 2008 hearing, the line prosecutor told one of the 
victims' attorneys that Epstein had "plead guilty today in state court."129
114. On June 30, 2008, based on what she had been told by the Government, Jane Doe 1 
thought that the Office was still investigating and pursuing her case. She did not receive notice 
that Epstein's state guilty plea affected her rights in any way. If she had been told that the state 
plea had some connection to blocking the prosecution of her case, she would have attended and 
tried to object to the judge to prevent that plea from going forward.13°
115. On June 30, 2008, based on what she and her attorneys had been told by the 
Government, Jane Doe 2 thought that the Government was still investigating her case. If she had 
been told that the state plea had some connection to blocking the prosecution of her case, she 
would have tried to confer with the prosecutors about it and tried to get charges filed. She 
wanted to be treated fairly in the processin 
116. From September 24, 2007, the date that the NPA was signed, through at least the state 
court plea on June 30, 2008—a period of more than nine months—the Office did not notify any 
of Epstein's victims about the existence of the NPA.I32
4-6, 18-19, 22-23; Exhibit 64 at 6; 000001-000002 (Exhibit 105). 
128
129
Exhibit 26; Exhibit 27; Exhibit 63 at 
REP WPB 001861 (Exhibit 106). 
1" Exhibit 26; Exhibit 63 at 4-6, 18-19, 22-23. 
13' Exhibit 27; Exhibit 63 at 4-6, 18-19, 22-23; Exhibit 105. 
O2 Exhibit 62; Exhibit 63 at 4-6, 18-19, 22-23, 28-29; Exhibit 64 at 4; US_Atty_Cor. 00267-00271 (Exhibit 107). 
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117. On July 1, 2008, the day following Epstein's plea, the line prosecutor cmailed the 
Assistant State Attorney a copy of the NPA for "filing with the Court under seal" demonstrating 
that the agreement continued to be withheld from the victims.'33
118. On July 3, 2008, as specifically directed by the U.S. Attorney's Office, Mr. Edwards 
sent a letter to the Office communicating the wishes of Jane Doe 1, Jane Doe 2, and Jane Doe 5 
that federal charges be filed against Epstein: "We urge the Attorney General and our United 
States Attorney to consider the fundamental import of the vigorous enforcement of our Federal 
laws. We urge you to move forward with the traditional indictments and criminal prosecution 
commensurate with the crimes Mr. Epstein has committed, and we further urge you to take the 
steps necessary to protect our children from this very dangerous sexual predator."134
119. When Mr. Edwards wrote his July 3, 2008 letter, he was still unaware that a NPA had 
been reached with Epstein and that there was any federal resolution of the case—facts that the 
Office continued to conceal, at the request of Epstein, not only from Edwards but also as his 
clients and other victims.' 
120. On July 7, 2008, the line prosecutor again conferred with Epstein's counsel seeking 
permission to begin distributing the notification letters to the victims, acknowledging her failure 
to include one victim who was still a minor in 2008.136
121. Mr. Edwards first saw a reference to the NPA on or after July 9, 2008, when the 
Government filed its responsive pleading to Jane Doe's emergency petition. That pleading was 
173 RFP WPB 001857 (Exhibit 108). 
16 Exhibit 105. 
" 3 Exhibit 63 at 4-6, 18-19, 22-23, 28-29; Exhibit 99; RFP WPB 001855 (Exhibit 109); [DE 48] (Exhibit 110) at 
18-19. 
O6 RFP WPB 001854 (Exhibit 111). 
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the first public mention of the NPA and the first disclosure to Mr. Edwards—and thus to Jane 
Doe 1, Jane Doe 2, and Jane Doe 5—of the possible existence of a NPA.I37
122. Mr. Edwards detrimentally relied on the misleading representations made by the 
Office that the case was still under investigation when he was writing his July 3, 2008 letter. He 
would not have wasted his time undertaking a pointless exercise had he known that the U.S. 
Attorney's Office had previously negotiated a NPA, and he would have informed his clients 
about the agreement.138
A MOTIVE TO CONCEAL THE NPA FROM THE VICTIMS 
123. The U.S. Attorney's Office—pushed by Epstein—wanted the NPA kept from public 
view because of the strong objection it would have faced from victims of Epstein's abuse, and 
because of the public criticism that would have resulted from allowing a politically-connected 
billionaire who had sexually abused more than 30 minor girls to escape from federal prosecution 
with only a county court jail sentence.139
124. When deciding whether to notify the victims before Epstein entered his guilty plea, 
the Office was aware that a state court judge would have to review the plea and determine 
whether it was in the public interest, and accordingly chose not to "highlight" certain potentially 
objectionable features.14°
'" Exhibit 62; Exhibit 63 at 4-6, 18-19, 22-23, 28-29; Exhibit 99; Exhibit 110 at 18-19. 
In See Exhibit 28; Exhibit 102; Exhibit 105. 
l" Exhibit 26; Exhibit 27; Exhibit 62; Exhibit 63 at 4-6, 18-19, 22.23; Exhibit 99; Exhibit 101; Exhibit 102; Exhibit 
57 (urging Government to try and keep agreement from becoming public); Exhibit 7 (explaining Government's 
desire not to "highlight" possible charges or defendants being immunized). 
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125. Concealing the NPA from the victims prevented them from using their right to confer 
with the Government about why the NPA was not desirable or appearing at Epstein's plea and 
sentencing hearing to raise their concerns with the Court."' 
THE VICTIMS' UNSUCCESSFUL ATTEMPTS TO ENFORCE THEIR RIGHTS 
126. On July 7, 2008, Jane Doe 1 filed an emergency petition for enforcement of her rights 
under the CVRA. At the time, Jane Doe 1 was not aware of the NPA, so she sought a court order 
directing the Government to confer with her before reaching any such agreement. Epstein 
quickly became aware of this petition.142
127. On July 8, 2008, the line prosecutor sent a letter to Epstein's counsel stating that 
victims would be informed about the civil compensation provision of the NPA the next day: 
In accordance with the terms of the Non-Prosecution Agreement, on June 30, 
2008, the United States Attorney's Office provided you with a list of thirty-one 
individuals "whom it was prepared to name in an Indictment as victims of an 
enumerated offense by Mr. Epstein." . . . In deference to your vacation, we 
allowed you a week to provide us with any objections or requested modifications 
of the list and/or the Notification language. Yesterday, I contacted you via 
telephone and e-mail, but received no response. Accordingly, the United States 
hereby notifies you that it will distribute the victim notifications tomorrow, July 9, 
2008, to each of the thirty-two identified victims, either directly or via their 
counsel. w3 
128. On July 9, 2008, Jack Goldberger sent a letter to the line prosecutor raising concerns 
about the notifications, and suggesting modifications to the notification letter. Epstein's counsel 
also objected to the victim notification letters containing certain information about the NPA.I44
I" 18 U.S.C. § 3771; Exhibit 26; see also Exhibit 62. 
Ni [DE 1] (Exhibit 112) at 1-2. 
13 Exhibit 101. 
" 4 RFP WPB 000524-000525 (Exhibit 113). 
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