EFTA00184224

A' udgloggtv1454:417'.4"41-49b62-2611i61,46g181:Ir40Q1Pocket 02/10/2016 PaglglYeetts
Honorable Mark HUI) 
May 19, ZOOS 
Page 7 
Government's confidential "list or victims." Most of these lawsuits seek S50 
million in money darnages.4
a 
Assistant U.S. Attorney David Weinstein spoke about the case in great detail to 
Landon Thomas, a reporter with the Mew York Times, and revealed confidential 
information about the Government's allegations against Mr. Epstein. The Assistant 
U.S. Attorney also revealed the substance of confidential plea negotiations. 
When counsel for Mr. Epstein complained about die media leaks, first A.tsistaii; 
Stamen responded by asserting that "Mr. Thomas was given, pursuant to his 
request, non-case specific information concerning specific federal statutes " Based 
on Mr. Thomas' contemporaneous notes, that assertion appears to be false. For 
example, Mr. Weinstein told Mr. Thomas that federal authorities believed that 
Mr. Epstein had hired girls over the telephone and traveled in interstate commerce 
for the purpose of engaging in underage sex. He recounted to Mi. Thomas the 
USAO's theory of prosecution against Mr. Epstein. replete with an analysis of the 
key statutes being considered. 
Fun:hermore, after Mr. Epstein's defense ream 
complained about the leak to the USAO, Mr. Weinstein, in Mr Thomas' own 
description, then admonished him for talking to the defense, and getting hint in 
trouble. Mr. Weinstein further told him not to believe the "spin" of Mr. F.psteints 
"high-priced attorneys," and then, according to Mr. Thomas. Mr. Weinstein 
forcefully "reminded" Mr. Thomas • that all prior conversations were merct) 
hypothetical. 
We are constrained to conclude that the actions of federal officials in this case strike at 
the heart of one of the vitally important, enduring values in this country: the honest enforcement 
of federal law, free of political considerations and free of the taint of personal financial 
motivations on the part of federal prosecutors thin, at a minimum, raise the appearance of serious 
impropriety. 
We were told by U.S. Attorney 
that as parr of the review he requested, the 
Department had the authority, and his consent, to make any determination it deemed appropriate 
regarding this matter, including a decision to decline federal prosecution. Yet, C •OS's only 
conclusion, based on its limited review of the investigation, is that U.S. Attorney 
would 
not abuse his discretion by proceeding against Mr. Epstein. Thus, the decision of whether 
A) recently as two months ago. Mr. Slornan Was still listed publicly us r. pun of his former law firm. While we 
assume this was an on:night, Mr. Stoinan's identifirAilon As pan of the firm plus the appearance of 
Impropriety. 
08-80736-CV-MARRA 
RIP WPB 001622 
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Honorable Mark Hip 
May 19, 2008 
Page 8 
prosecution is fair and appropriate has been placed, once again, in U.S. Attorney 
hands. 
in light of the foregoing, we respectfully ask that you review this matter and discontinue 
all federal involvement so that the State can appropriately bring this matter to tlosure. We 
would greatly appreciate the opportunity to inect with you to discuss these important issues. 
Such a meeting would provide the Department with an opportunity to review the paramount 
issues of federalism and. the appearance al" selectivity that are generated by the unprecedented 
attempts to broaden the ambit of federal stattitc.s to places that they have never before reached. 
We sincerely appreciate your attention to this matter. 
Respectfully submitted, 
) 
Kenneth W. Starr 
Kirkland & Ellis la 
Joe D. Whitley 
Alston & Bird fa 
0840736-CV-MARRA 
RFP WPB 001623 
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( 
( 
EXHIBIT 
97 
EFTA00184946

Case 9:9"-cv116T3e:IZANA AllrMent 362-27 Entered on FLSD iiiIT,L02/10221.6 po
t2 of 3 
U.S. Department of Justice 
Federal Bureau of Investigation 
FBI - Weed Palm Beach 
Suite 500 
505 South Flagler Drive 
West Palm Beach. Ft. 33401 
January 10, 2008 
Re: Case Number:' 
Dear 
This case la currently under Investigation. This can bee lengthy process end we request your 
continued patience while wo conduct a thorough Investigation. 
As a crime victim. you have the following tights under 18 United States Code § 3711: (1) The right to 
be reasonably protected from the accused; (2) The right to reasonable, accurate, and timely notice of any 
publics court proceeding, or any parole proceeding, invoiving 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 dear and convincing evidence, determines that testsnony by the victim would be maternally altered if 
the victim heard other testimony at that proceeding; (4) The right to be reasonably heard at any pupils 
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; (0) The right to full and timely 
restitution as provided In law: (7) The right to proceedings free from unreasonable delay; (a) The right to bo 
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 at these rights 
portatn to events occurring after the arrest or indicunem of an Individual for the alma, and it will become the 
responsibbity of the proeocuting Untied States Attorney's Orrice to ensure you are accorded those rights. You 
may also seek the advice of a private attorney with roepect to these rights. 
The Victim Notification System (VNS) is destined to provide you with direct informeffon regarding the 
case as It proceeds Through the criminal Justice system. You may obtain current Information about this metier 
on the Internet et VYWW.Notify,USDOJ.0OV or from The VNS Call Center at 1-866-D0J-4Y0U (1-868-385-
4968) (TD0MY: 1.866-2284616) (International: 1-502-213-2767). In addition, you may use the Can 
Center or Internet to update your contact irdormation end/or change your decision about parkipation In Ole 
notification program. If you update your Information to Include a currenterrnell address, VNS will Send 
infotnieton to that address. You will need the following Viodm Identification Number (VIN)' 
Personal Identification Number (PIN) 
anytime you contact the Cell Center and the erst time you log PI to 
VNS on the Internet. In addition, the first time you access the VNS Internet site, you wilt be prompted to enter 
your last name (or business name) as currently contained in VNS. The name you should enter is 
EFTA00184947

---
Calse 9:-O8-cv-80736-KAM lirment 362-27 Entered on FLSD liket02/1912016 Preggaof 3 
It you have additional questions which involve this matter, please contact the Oka listed above. When 
you cell, please provide the Ole number located at the top of this letter. Please remember, your pardcipellon 
in the notification part of this pogrom is voluntary. In circlet to continue to meths notifications. it Is your 
responsibility to keep your contact information current. 
Sincerely,. 
ciao; bia, 
TwIler Smith 
Victim Specialist 
EFTA00184948

Case 9:08-cv-80736-KAM Document 362-28 Entered on FLSD Docket 02/10/2016 Page 1 of 3 
EXHIBIT 
98 
EFTA00184949

app 9:011-cv-p0136-KAM Ellument 362-28 Entered on FLSD 
kgov,toggle ri.Rciptg of 3 
January ig. 2008 
U.S. Department of Justice 
Federal.Bureau of Investigation 
FBI - West Palm Beach 
Suite 500 
505 South Flagler Drive 
West Palm Beach. FL 33401 
James Eisenberg 
Ono Cleadako Center Ste 704 Australian South 
West Palm Beach. Ft. 33401 
Re: 
Dear James Eisenberg: 
You have requested to receive notifications for 
This case is currently under Investigation. This can be a lengthy process and we request your 
continued patience while we conduct a thorough investigation. 
Asa crime victim, you have the following rights under 18 United States Coda § 3771: (1) The right to 
be reasonably protected from the accused; (2) The right to reasonable, accurate, and timely notice of any 
public 0:m41race/ding, or any parole proceeding, Involving the alma or of any release or escape of the 
accused; (3) The right not to be excluded from any ouch public court proceeding. unless the court, after
receiving clear and convincing evidence, determines that testimony by the victim wduld be materially altered If 
the victim heard other testimony at that proctiedincr, (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 cunfer with the attorney for the Government in the case; (6) The right to full and timely 
restitution os provided in law; (7) The right to proceedings free from unreasonabledelay: (a) The right to be 
treated with fairness and with respect for the victim's dignity and privacy. 
We MU make our best efforts to ensure you are accorded tie 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 
responelbeity of the prosecuting tinned Slates Attorneys Office to ensure you are accorded those rights. You 
may also seek the odvlue of is pdveta attorney with respect to these rights. 
The Victim Motlficatlon 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.Notify.I1800J-GOV or from the VNS Call Center at 1-866-D0J-4YOU (1.866.365-
4958) (TDD/TTY: 1-050-228-4619) (lritemational: 1-502-213-2767). In addition, you may use One CaN 
Center or Internet to update your contact infomuslion end/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 
' and 
Personal identification Number 
anytime, you contact the Call Center and the first time you log on to 
VNS on the Internet. In addition, the first lima you access the VNS Internet site, you will be prompted to enter 
your lest name (or business name) es currently contained in VNS. The name you should enter is Eisenberg. 
EFTA00184950

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ment 362-28 Entered on FLSD *ket 02/10/2016 Page 3 of 3 
DOI ODU 0,31 
M.U3/0e 
“ 
; 
If you MVO additional questions which Involve this matter, please contact the office dated above. When 
you can. please provide the flue number located at the top of this letter. Please remember, your participabon 
in the notification part of this program is voluntary. In order to continue to receive noldicattons, rt is your 
reeponsIblitty lo keep your contact Information current. 
Sincerely. 
cg i i iR,, -3,:rftP 
Twikg Smith 
Victim Specialist 
EFTA00184951

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Jack Goldberger 
From: 
Sent: 
To: 
Subject: 
On Jun 30, 2008, at 5:16 PM, " 
wrote: 
. \("USAFLS1)" . 
facie 
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 are declining comment if asked. 
A. 
Yillafaila 
Assistant U.S. Attorney 
1 
US_Atty_Cor_00321 
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.(USAFLS) 
From: 
Brad Edwards ([email protected]) 
Sent: 
ThillwARV  
ie 9908 11:34 AM 
To: 
 
p (USAFLS) 
Subject: 
Jeff Epstein 
I have information and concerns that I would like to share. While I understand that you are limited in what you can 
discuss, I would like to meet with you and discuss my plans. This would be beneficial to you and me. Let me know If you 
are interested in meeting and talking. My schedule is free next Monday, Tuesday, and Wednesday, July 23.25. If any of 
those days are open for you. then I will go to you and can meet you at any time convenient for you. I am scheduling to 
meet with my client again next week in your area anyway, so it would be no problem for me to meet you on the same 
day. I look forward to hearing back from you. 
Sincerely, 
Brad Edwards. Esquire 
Law Office of Brad Edwards & Associates 
2028 Harrison Street 
Suite 202 
Hollywood, Florida 33020 
Telephone: 
954-414-8033 (Broward) 
305-935-2011 (Miami-Dade) 
Facsimile: 
954-924-1530(Broward) 
305/935-4227 (Miami-Dade) 
e-mail: 
[email protected] 
PRIVILEGED AND CONFIDENTIAL: The intbrmation contained in this e-mail message is intended for the 
use of the individual or entity to which it is 
addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure 
under applicable laws. If the reader of this 
message is not the intended recipient, or the employee or agent responsible for delivery to the intended 
recipient, you are hereby notified that any use, printing, 
reproduction, disclosure or dissemination of this communication may be subject to legal restriction or sanction. 
909 
08-80736-CV-MARRA 
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Case 9:08-cv-80736-KAM Document 362-31 Entered on FLSD Docket 02/10/2016 Page 2 of 3 
U.S. Department ofJustice 
United States Attorney 
Southern District of Florida 
500 South Australian Ave., Suite 400 
West Palm Beach, Ft 3340/ 
Facsimile.• 
July 8, 2008 
VIA FACSIMILE AND ELECTRONIC MAIL 
Jack A. Goldberger, Esq. 
Atterbury, Goldberger & Weiss, P.A. 
One Clearlake Centre, Suite 1400 
25b Australian Ave S. 
West Palm Beach, FL 33401-5015 
Re: 
Jeffrey Epstein 
Dear Mr. Goldberger: 
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." Yesterday, I provided you with the identification of another victim whom I had 
erroneously left off of that list. At the time the list was provided, Special Agent 
and I impressed upon you the need to finalize this last piece of the agreement as quickly as 
possible so that we could fulfill our victim notification obligations. In deference to your 
vacation, we allowed you a week to provide us with any objections or requested 
modifications to 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. A carbon copy of each notification will be provided to you, and 
the notification will list you as the contact person for any civil litigation, if the victim decides 
08-80736-CV-MARRA 
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JACK POLDEERGER, ESQ. 
Jui.v 8,2008 
PAGE 2 
to pursue damages. If the United States learns that a civil suit has been filed against Mr. 
Epstein and he has denied that one of these victims is entitled to proceed under 18 U.S.C. 
§ 2255, that will be considered a breach of the Non-Prosecution Agreement and the United 
States will proceed accordingly. 
Sincerely, 
United States Attorney 
cc: 
Karen Atkinson, AUSA 
By: 
Assistant United States Attorney 
08-80736-CV-MARRA 
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EXHIBIT 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 08-80736-Civ-Marra/Johnson 
JANE DOE No. I and JANE DOE No. 2 
v. 
UNITED STATES 
AFFIDAVIT OF BRADLEY J. EDWARDS, ESQ. REGARDING NEED FOR 
PRODUCTION OF DOCUMENTS 
1. I, Bradley J. Edwards, Esq., do hereby declare that I am a member in good standing of the Bar 
of the State of Florida. Along with co-counsel, I represent Jane Doe No. 1 and Jane Doe No. 2 
(as referred to as "the victims") in the above-listed action to enforce their rights under the Crime 
Victims Rights Act (CVRA). I also represented them (and several other victims) in civil suits 
against Jeffrey Epstein for sexually abusing them. I am also familiar with the criminal justice 
system, having served as state prosecutor in the Broward County State Attorney's Office. 
2. This affidavit covers factual issues regarding the Government's assertions of privilege to 
more than 13,000 pages of documents it has produced for in camera inspection in this case. This 
affidavit provides factual information demonstrating that the Government's assertions of 
privilege are not well founded. It farther demonstrates that the victims have a compelling and 
substantial need for the information requested and have no other way of obtaining the 
information. 
Background Regarding Unsuccessful Efforts to Reach Stipulated Facts with the 
Government 
3. On July 7, 2008, I filed a petition to enforce the CVRA rights of Jane Doe No. 1 and Jane Doe 
No. 2 with regard to sex offenses committed against them by Jeffrey Epstein while they were 
minors. The course of the proceedings since then is well-known to the Court. For purposes of 
this affidavit regarding privileges, it is enough to briefly recount the efforts of the victims to 
reach a stipulated set of facts with the Government — efforts that the Government has blocked. 
4. The Court first held a hearing on victims' petition on July 11, 2008. The Court discussed a 
need to "hav[e] a complete record, and this is going to be an issue that's ... going to go to the 
Eleventh Circuit, [so it] may be better to have a complete record as to what your position is and 
the government's is as to what actions were taken." Tr. at 25-26. The Court concluded the 
hearing with the following instructions: "So I'll let both of you confer about whether there is a 
need for any additional evidence to be presented." Tr. at 32. 
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5. The victims and the U.S. Attorney's Office then attempted to reach a stipulated set of facts 
underlying the case. The U.S. Attorney's Office offered a very abbreviated set of proposed facts, 
and the victims responded with a detailed set of proposed facts. Rather than respond to the 
victims' specific facts, however, the U.S. Attorney's Office suddenly reversed course. On July 
29, 2008, it filed a Notice to Court Regarding Absence of Need for Evidentiary Hearing (DE 17). 
The U.S. Attorney's Office took the following position: "After consideration, the Government 
believes that an evidentiary hearing is not necessary" (DE 17 at 1). The Office asserted that the 
Court need only take judicial notice of the fact that no indictment had been filed against Epstein 
to resolve the case. 
6. On August 1, 2008, the victims filed a response to the Government's "Notice," giving a 
proposed statement of facts surrounding the case. DE 19 at 5. The victims' response also 
requested that the Court direct the Government to confer with the victims regarding the 
undisputed facts of the case, and produce the non-prosecution agreement and other information 
about the case. Id at 14. On August 14, 2008, the Court held a hearing on the case regarding 
the confidentiality of the non-prosecution agreement. The Court ultimately ordered production 
of the agreement to the victims. 
7. After the U.S. Attorney's Office made the non-prosecution agreement available to the 
victims, the victims reviewed it and pursued further discussions with the U.S. Attorney's Office. 
Ultimately, however, the U.S. Attorney's Office declined to reach a stipulated set of facts with 
the victims and declined to provide further information about the case. 
8. With negotiations at an impasse, the victims attempted to learn the facts of the case in other 
ways. In approximately May 2009, counsel for the victims propounded discovery requests in 
both state and federal civil cases against Epstein, seeking to obtain correspondence between 
Epstein and prosecutors regarding his plea agreement — information that the U.S. Attorney's 
Office was unwilling to provide to the victims and information that was highly relevant both to 
the victims' civil suit and their CVRA enforcement action. Epstein refused to produce that 
information, and (as the Court is aware) extended litigation to obtain the materials followed. The 
Court rejected all of Epstein's objections to producing the materials. 
9. On June 30, 2010, counsel for Epstein sent to counsel for the victims approximately 358 
pages of e-mail correspondence between criminal defense counsel and the U.S. Attorney's Office 
regarding the plea agreement that had been negotiated between them. See DE48-Attachment 
1/Exhibit A. These e-mails began to disclose for the fast time the extreme steps that had been 
taken by the U.S. Attorney's Office to avoid prosecuting Epstein and to avoid having the victims 
in the case learn about the non-prosecution agreement that had been reached between Epstein 
and the Government. 
While the Court ordered that all of the correspondence be turned over to 
the victims, Epstein chose to disobey that order and instead only produced the correspondence 
authored by the Government and redacted all correspondence authored by him or his attorneys. 
10. In mid-July 2010, Jane Doe No. 1 and Jane Doe No. 2 settled their civil lawsuits against 
Epstein. 
Then, armed with the new information, they turned to moving forward in the CVRA 
case. On September 13, 2010, the victims informed the Court that they were preparing new 
filings in the case. 
11. On October 12, 2010, the Court entered an order directing the victims to provide a status 
report on the case by October 27, 2010. That same day, counsel for the victims again contacted 
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the U.S. Attorney's Office about the possibility of reaching a stipulated set of facts in the case. 
That same day, the U.S. Attorney's Office responded: "We don't have any problem with 
agreeing that a factual assertion is correct if we agree that is what occurred" (DE 41 at 2). 
12. On October 23, 2010, the victims e-mailed to the U.S. Attorney's Office a detailed proposed 
statement of facts, with many of the facts now documented by the correspondence between the 
U.S. Attorney's Office and Epstein's counsel. The victims requested that the U.S. Attorney's 
Office identify which facts it would agree to. In a letter to the U.S. Attorney's Office, the victims 
stated: 
If you believe that any of the facts they propose are incorrect, Jane Doe No. 1 and 
Jane Doe No. 2 would reiterate their long-standing request that you work with us 
to arrive at a mutually-agreed statement of facts. As you know, in the summer of 
2008 Jane Doe No. 1 and Jane Doe No. 2 were working with you on a stipulation 
of facts when you reversed course and took that position that no recitation of the 
facts was necessary (see doe. No. 19 at 2). . . . I hope that your e-mail means that 
you will at least look at our facts and propose any modifications that you deem 
appropriate. Having that evidence quickly available to the Court could well help 
move this case to a conclusion. 
That same day, the U.S. Attorney's Office agreed to forward the proposed statement of facts to 
the appropriate Assistant U.S. Attorney for review (DE 41 at 2-3). 
13. On October 26, 2010, rather than stipulate to undisputed facts, the U.S. Attorney's Office 
contacted the victims' attorneys and asked them to delay the filing of their motion for a two-
week period of time so that negotiations could be held between the Office and the victims in an 
attempt to narrow the range of disputes in the case and to hopefully reach a settlement resolution 
without the need for further litigation. Negotiations between the victims and the U.S. Attorney's 
Office then followed over the next two days. However, at 6:11 p.m. on October 27, 2010 — the 
date on which the victims' pleading was due — the U.S. Attorney's Office informed the victims 
that it did not believe that it had time to review the victims' proposed statement of facts and 
advise which were accurate and which were inaccurate. The Office further advised the victims 
that it believed that the victims did not have a right to confer with their Office under the CVRA 
in this case because in its view the case is "civil" litigation rather than "criminal" litigation (doe. 
No. 41 at 3).
14. As a result, purely as an accommodation to the U.S. Attorney's Office, on October 27, 2010, 
the victims filed a report with the Court in which they agreed to delay filing their motion and 
accompanying facts for up to two-weeks to see if negotiations can resolve (or narrow) the 
disputes with the U.S. Attorney's Office (DE 41 at 4). Discussions with the U.S. Attorney's 
Office dragged on, including a personal meeting between Jane Doe No. 1 and the U.S. Attorney 
in December 2010. 
I In seeming contradiction to this position, on March 17, 2011, the U.S. Attorney's Office 
informed the victims that it would not be making any initial disclosures to the victims as required 
for civil cases by Fed. R. Civ. P. 26(a)(1). The U.S. Attorney's Office did not explain why they 
believe that this rule of civil procedure is inapplicable if they think this case is properly viewed 
as a "civil" case. 
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25 
• at dif4 
15. After further discussions failed to produce any agreement or other visible progress, the 
victims informed the U.S. Attorney's Office that they would file their "summary judgment" 
motion with the Court on March 18, 2011 and requested further cooperation from the Office on 
the facts. 
16. Ultimately, after months of discussion, the U.S, Attorney's Office informed counsel for the 
victims that — contrary to promises made earlier to stipulate to undisputed facts — no such 
stipulation would be forthcoming. Instead, on March 15, 2011, the U.S. Attorney for the 
Southern District of Florida, Wifredo A. 
, sent a letter to the victims declining to reach any 
agreement on the facts: 
Because, as a matter of law, the CVRA is inapplicable to this matter in which no 
federal criminal charges were ever filed, your requests for the government's 
agreement on a set of proposed stipulated facts is unnecessary and premature. 
That is, because whether the rights in 18 U.S.C. § 3771(a) attach prior to the filing 
of a charge in a federal court is a matter of statutory interpretation, resolution of 
that question is not dependent upon the existence of any certain set of facts, other 
than whether a charging document was ever filed against Jeffrey Epstein in the 
United States District Court for the Southern District of Florida. And while this 
Office remains willing to cooperate, cooperation does not mean agreeing to facts 
that are not relevant to the resolution of the legal dispute at issue . . . . 
Letter from Wifredo A. 
to Paul G. Cassell (March 15, 2011). 
17. Accordingly, unable to work with the Government to reach a resolution of the facts, on 
March 21, 2011, the victims filed a Motion for Summary Judgment, alleging 53 undisputed facts 
along with some evidentiary support for each of the facts. DE 48. The victims also filed a 
motion to have their facts accepted because of the Government's failure to contest their facts. 
DE 49. The victims also filed a motion to have the Court direct the Government to not withhold 
relevant evidence. DE 50. 
18. Following a hearing on the motions, on September 26, 2011, the Court rejected the 
Government's argument that the CVRA was inapplicable in this case because the Government 
had never filed charges against Epstein. DE 99. The Court, however, rejected the victims' 
argument that it should accept their facts because of the Government's failure to contest the 
facts. DE 99 at 11. Instead, the Court directed that discovery could proceed in the form of 
requests for admission and document production requests. Id at 11. The Court reserved ruling 
on the victims' motion that the Government should be directed not to withhold evidence. 
19. In light of the Court's order, on October 3, 2011, the victims filed requests for production 
with the Government. The requests included 25 specific requests, each of which linked very 
directly to the facts that the victims were attempting to prove in this case. 
20. On November 7, 2011, the day when the Government's responses were due, rather than 
produce even a single page of discovery, the Government filed a motion to dismiss the victims' 
petitions. DE 119. On that same day, the Government filed a motion to stay discovery. DE 121. 
The victims filed a response, arguing that the Government's motion was a stall tactic. DE 129. 
The victims also filed a motion to compel production of all of their discovery requests. DE 130. 
The Government filed a reply, arguing that it was not stalling. Indeed, the Government told the 
Court that "the United States has agreed to provide some information to [the victims] even 
4 
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