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(USAFLS) 
From: 
Sent: 
To: 
Cc: 
Subject: 
(USAFLS) 
p 
er 17. 2008 12:00 PM 
inson, Karen (USAFLS) 
Your inquiry regarding the Epstein case 
Garcia. Rolando (USAFLS): 
. Jeff 
Ili Barry - the Non-Prosecution Agreement contains a confidentiality provision that requires us to inform Mr. 
Epstein's counsel before making any disclosure - even a compulsory disclosure. I am cc'ing you on a letter to 
Jay Lellowitz. Roy Black. and Jack Goldberger informing them of the request and asking them, as parties to the 
criminal case, to contact you regarding a possible suit by the Shiny Sheet. 
On another note, I also will be informing them that I believe that they still have not filed the complete 
agreement with the Court. as requited by the Judge at the hearing. 
Thank you very much for reaching out to us when you received this request, and if you need any help from us. 
please let us know. 
Assistant U.S. Attorney 
32 
08-80736-CV-1v1ARRA 
RFP WPB-001773 
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(USAFLS) 
From: 
. (USAFLS) 
Sent: 
HMiFiner 
18, 2008 2:52 PM 
To: 
KATHERINE W. EZELL 
Subject: 
RE: Emalling: C11066 
Hi Kathy -- As far as I know, Judge Marra has not ever seen the agreement or 
these notification letters. The agreement was filed under seal in the state 
court, but it was filed after the fact, so I don't know if the sentencing judge 
ever reviewed it. 
The letters were reviewed by my office and Jay Lefkowitz and Roy Black before 
they went out. 
I am going to send my letter out by e-mail today, but I am just waiting to hear 
back from the higher-ups in Miami. 
A. 
Villafaha 
Assistant U.S. Attorne 
 
Original Message 
From: KATHERINE W. EZELL [mailto:[email protected]) 
Sent: Thursday, Se tember 18, 2008 1:56 PM 
To: 
. (USAFLS) 
Subject: Emailing: CI1066 
«CI1066.WPD» 
Here's the draft. One question I had here. Was this arrangement in any way 
"blessed" by Judge Marra? Can I mention the Court, as I did a couple of times, 
or should I take this out. By the way, I re-read the rules that would apply to 
emails, letters or calls from us-- and they will be awful to have to comply with. 
36 
08-80736-CV-MARRA 
REP WPB-001763 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 08-80736-CIV-KAM 
JANE DOE, 
) 
) 
PETITIONER, 
) 
) 
UNITED STATES OF AMERICA, 
) 
) 
RESPONDENT. 
) 
) 
 
) 
West Palm Beach, Florida 
November 23, 2015 
TRANSCRIPT OF STATUS CONFERENCE PROCEEDINGS 
BEFORE THE HONORABLE KENNETH A. MARRA 
UNITED STATES DISTRICT JUDGE 
Appearances: 
FOR THE PETITIONER 
FOR THE RESPONDENT 
Reporter 
Bradley J. Edwards, ESQ., 
Brittany Henderson, ESQ., AND 
Paul G. Cassell, ESQ. 
Farmer Jaffe Weissing, et al. 
425 North Andrews Avenue, Suite 2 
Fort Lauderdale, FL 33301 
Dexter Lee, AUSA, AND 
Ed Sanchez, AUSA 
United States Attorney's Office 
99 Northeast 4th Street 
Miami, FL 33132 
Stephen W. Franklin, RMR, CRR, CPE 
Official Court Reporter 
701 Clematis Street 
E-mail: [email protected] 
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(Call to the order of the Court.) 
THE COURT: Good afternoon, please be seated. 
MR. SANCHEZ: Good afternoon, Your Honor. 
MR. LEE: Good afternoon, Your Honor. 
THE COURT: We are here in the case of Doe versus 
United States, Case Number 08-80736-CIV-MARRA. 
May I have counsel state their appearances. 
MR. EDWARDS: Brad Edwards and Britney Henderson, as 
well as Paul Cassell on the telephone on behalf of the 
Petitioners. 
THE COURT: Good afternoon. 
MR. LEE: Good afternoon, Your Honor. May it please 
the Court. For the Respondents, Ed Sanchez and Dexter Lee, 
Assistant U.S. Attorneys. Good afternoon, Your Honor. 
THE COURT: Thank you for being available on 
relatively short notice. I just thought we should get 
together and discuss where this case is going and how the 
parties thought we should proceed. 
So Mr. Edwards why don't you tell me. 
MR. EDWARDS: Sure. I don't mind taking the lead on 
that. 
This is our plan, and I can tell you that Paul 
Cassell and I are being very careful in the way that we 
present what is going to be a 60-page summary judgment motion. 
We have set internally a deadline of filing, an artificial 
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deadline for ourselves, of December 15th. If Your Honor is 
okay with that, then that seems like it's going to fall in 
line. When I say we're being careful, we're being careful in 
how we're going to prepare and file the exhibits and what gets 
filed to make sure that we strictly comply with your prior 
orders in that regard. 
That summary judgment, if granted, would take us, 
then, to the remedy stage, which I think is the next phase 
that would obviously be contested by parties in addition to 
the Government. If denied, then I would foresee requesting 
from Your Honor the ability to take several depositions, 
engage in some limited but additional discovery, and before 
requesting a jury trial, and I think that at least between my 
co-counsel and I, we envision getting this case resolved, if 
possible, by mid summer 2016. At least maybe that's overly 
optimistic, but that's my hope. 
THE COURT: All right. Eight years later. 
All right. So a 60-page summary judgment motion is 
going to take, I would think, the Government more than the 
normal 10 days to respond to that, especially if it's going to 
come on December 15th, and with the holidays. 
MR. EDWARDS: And we're obviously going to work with 
them in that regard. 
THE COURT: All right. So you just threw out a 
procedural issue that just stuck out as a jury trial. You 
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wanted to have a jury trial. I was wondering what would be 
the basis for a jury trial in this case? And not that we need 
to resolve that issue today, but is there any -- where do you 
see a right to a jury trial in this case? I guess we can deal 
with that down the road. 
MR. EDWARDS: I think that's probably best. 
THE COURT: Okay. All right. Mr. Lee, what do you 
foresee as how we should go forward with this case? 
MR. LEE: Your Honor, we believe there's an issue 
about whether or not Jane Does 1 and 2 may have been complicit 
in the offenses, if you will. Specifically that they, 
themselves, procured additional young women for Mr. Epstein 
and were paid commissions or referral fees for it. 
We're looking at a case that came out from the 
Eleventh Circuit, In Re Wellcare Health Plans, Incorporated, 
754 F.3d 1234, June of 2014. We believe that issue is 
relevant because they found, the Court of Appeals, that if 
someone was complicit in the actual offense, that they are not 
entitled to be a victim and can invoke no victim rights under 
the Victim Rights Act. 
So what we would propose to do is within the next 
week or so, to propound some very short requests for 
admissions and interrogatories directed to that specific 
issue. When the Petitioners file their 60-page summary 
judgment motion, we would anticipate, assuming we can get a 
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short extension of time to respond, we would file our own 
response and potentially a cross motion for summary judgment, 
Your Honor. 
THE COURT: All right. Mr. Edwards, did you want to 
say something? 
MR. EDWARDS: Yes. 
Well, today is the first day that I've heard that 
the Government may attempt to argue that the victims were 
complicit in this and thus are disqualified, and I think that 
Your Honor has recognized all along that we represent not only 
Jane Doe 1 and 2, but all other similarly situated victims. 
There were numerous identified by the Government, some of 
which, in fact, many of which, because of the way that the 
crime and scheme was laid out from top to bottom, many of 
which were also recruiters. And so this additional, I will 
say, issue is going to likely lead to additional other issues, 
including what other victims can now be included; are there 
going to be additional Jane Does that may actually need to be 
joined by name, because they don't fall under the category of 
Jane Doe 1 and 2, to the extent that there's this latest 
argument gets any traction. 
Like I said, today's the first day I've heard this, 
and so I have not read this case that's being cited, and I'm 
frankly surprised that now the victims who have been 
categorized as victims are now being considered something less 
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than that. But -- so that may change the timetable, I guess. 
THE COURT: All right. Well, I guess we're not in a 
position to resolve that issue today. 
MR. EDWARDS: We are not. 
THE COURT: Okay. So Mr. Edwards, you mentioned if 
I deny your summary judgment motion, then you wanted to do 
some limited additional discovery in the nature of what? What 
are you foreseeing, again, looking down the road, if we get to 
that point. 
MR. EDWARDS: So, for instance, if Your Honor were 
to determine that there was a genuine issue of material fact 
on the issue of did Jane Doe number 2 -- just taking her for 
example -- was she able to meaningfully confer with the 
Government? I would like to -- and the Government says, well, 
this is what we considered meaningfully conferring. It's she 
talked to X agent over here about something else. I would 
like to take the deposition of that agent, if that's something 
that they're going to rely upon. Or even the prosecutor, 
since it's actually the obligation is to give the victims the 
right to meaningfully confer with the prosecutor in the case. 
I'd just like to take the prosecutor's deposition to figure 
out what did you talk to her about, what did you not, so that 
we could hammer out whether that's meaningfully conferring 
under the statute. 
THE COURT: So, again, if we get to the point where 
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a motion for summary judgment is denied, that's the extent of 
the additional discovery that you feel you would need to take, 
just the issue of what conferring the Government did with the 
victims in this case? 
MR. EDWARDS: Yes, sir. That's all I can anticipate 
the right now. 
THE COURT: Okay. 
MR. EDWARDS: With this -- with the latest that I 
just heard, who knows. 
THE COURT: Okay. From your standpoint. 
MR. EDWARDS: Yes. 
THE COURT: Mr. Lee, other than this limited 
discovery you just mentioned dealing with whether the Jane 
Does 1 and 2 were complicit in the underlying criminal conduct 
that Mr. Epstein was involved with, do you foresee any other 
additional discovery that you might need to take? 
MR. LEE: No, Your Honor. 
If I may comment briefly. 
Your Honor, typically a CVRA action is part of a 
criminal proceeding in the normal course. Of course, there's 
really nothing normal about this case, but we all know that. 
But we don't believe that it is necessary or necessarily 
appropriate to ingraft the civil discovery rights onto this 
dispute. If there is a factual dispute that the Court finds 
would preclude a summary judgment motion, then the next step 
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is to go into an evidentiary hearing, much as would be held if 
there was a criminal case attached to this. 
So we would object to any further discovery. 
THE COURT: All right. But you just told me you 
wanted to take some discovery. 
MR. LEE: Your Honor, you have already allowed them 
to do discovery, which is fine, and we have produced it. We 
want to exercise the same pre-summary judgment. But insofar 
as what goes on after summary judgment, in the event that it's 
denied, then it would go into -- straight into an evidentiary 
hearing. 
THE COURT: All right. So, again, you don't --
other than this limited discovery that you just mentioned, you 
don't foresee or think it would be appropriate to have any 
additional discovery beyond that? 
MR. LEE: That's correct, Your Honor. 
THE COURT: Okay. 
MR. CASSELL: Your Honor, this is Paul Cassell. If 
I could just mention -- Brad mentioned the limited discovery 
we would need. There is also one matter that Mr. Edwards may 
want to discuss with you at sidebar that could potentially 
surface at some point. 
THE COURT: All right. I guess Mr. Edwards knows 
what you're talking about. 
MR. EDWARDS: Sure, sure. 
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So we do have outstanding discovery requests that 
have been objected to by the Government. We have circulated a 
motion to compel to the Government, as well as to let's call 
them outside third parties. And there has been some 
discussion as to how we may be able to resolve it without the 
need of filing a motion to compel and putting anything back 
into a court record. 
So we're trying to work that out amongst ourselves 
first. And if we can't, I guess we'd ask Your Honor if you 
could -- if you would indulge such an issue being filed under 
seal, even though it may be not technically appropriate to 
file under seal, and see it in camera so that it doesn't 
become kind of a sideshow. 
THE COURT: All right. Well, again, that's 
something that may be necessary and might be worked out among 
the parties; is that correct? 
MR. EDWARDS: Hopefully. 
THE COURT: Is that what you were referring to, 
Mr. Cassell? 
MR. CASSELL: Yes. 
THE COURT: Okay. Well, I don't think I need to 
learn anything more specific at this point. If it become 
necessary, we'll deal with it. 
So is there anything else we should talk about 
today? 
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MR. EDWARDS: No, except that, like I said, the time 
table we were planning to file this summary judgment motion 
was -- let's say it's already in draft form -- December 15th. 
If there is going to be additional discovery that's going to 
be allowed, propounded from the Government to our victims, I 
would just ask that we have kind of a discovery cutoff so that 
we could see the discovery, respond to the discovery and then 
file our summary judgment motion. Because it may help to 
frame what the issues are in those motions. That seams --
THE COURT: Well, again, there's no deadline by 
which you're supposed to file anything at this point. That's 
one of the reasons why I had the hearing, to see if we should 
set some deadlines and a scheduling order going forward so 
that, you know, we don't -- it doesn't linger. 
I would suggest maybe that the parties get together 
and see if you can come to an agreement on putting together a 
schedule for whatever needs to be done before summary 
judgment, and assuming if the summary judgment's denied, when 
can an evidentiary hearing be held. 
I guess we should talk about this issue of a jury 
trial that was just raised. And, again, I haven't researched 
it. I don't know precisely what the rules are for something 
like this, but my inclination would be this is not a jury 
issue. This is something for me to decide whether it was 
if it was in the criminal -- brought up in the criminal 
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context, I would think that the Judge would decide it. There 
wouldn't be any right to a jury trial. I don't know why, 
since this was filed as a separate civil proceeding, that that 
would change. But, again, I'm not prepared to make a ruling 
on that. I'm not saying that that's the ultimate outcome. 
I'm just giving you my initial impression. 
And I'm just wondering if -- you know, if we're 
going -- if it's not going to be jury, then we can schedule 
something I think relatively quickly. I don't know how much 
is going to be needed beyond what's already undisputed in 
terms of factually what happened. I don't know what -- how 
much evidence would need to be taken at an evidentiary 
hearing. 
Mr. Edwards, what do you think about if there was 
going to be an evidentiary hearing, jury or nonjury, I mean, 
how much time do you think it would take? 
MR. EDWARDS: Well, it depends on, to me, what the 
Government's defenses are and whether -- and whether it's 
really going to come down into the nuance of what the 
Government did or did not say to victim A, and what they did 
or did not say to victim number 8, or number 9, or number 10. 
If it comes down -- if it really gets that specific, and it 
ultimately is going to require a determination that, yes, 
victim 2, 6 and 7's rights were violated in this regard, or 
I don't think that it should, but it sounds like it could. 
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And we have been contacted by other victims who do wish to 
testify and present evidence, and Your Honor said that's okay. 
So I think that all that kind of plays in. 
I would think that if it's not going to be a jury 
trial -- so absent picking juries and those things -- then a 
couple days, two, three days we could probably get it done, I 
would think no matter how many victims testify, just because 
it's very narrow, the scope, I would think, of the 
examination. 
THE COURT: That's what I would think, too, it would 
be very narrow. 
So Mr. Lee? 
MR. LEE: Yes, Your Honor. 
And in so far as the jury trial, we believe there is 
no entitlement to a jury trial. It's based upon the Seventh 
Amendment. And this goes a little way back the last time I 
briefed this issue. It's basically whether, at the time of 
the founding of the Republic and common law, whether or not 
somebody was entitled to a jury trial at that time. This 
cause of action and this statute did not exist at that time, 
so therefore we submit that there is no right to a jury trial. 
THE COURT: All right. Well, again, we don't need 
to decide that today. I was just -- since it was mentioned, I 
thought I would just raise that as an issue we're going to 
have to resolve at some point. 
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MR. LEE: Yes, sir. 
THE COURT: So maybe that's something that should be 
briefed before we set a date for resolution one way or the 
other. 
MR. EDWARDS: I think also that we would work with 
opposing counsel, send them what we have in terms of why we 
think it should be, and perhaps we could agree on that. 
THE COURT: All right. So can I ask both sides to 
maybe get together and see if you can come up with some type 
of a proposed schedule going forward on whatever needs to be 
done, and if you can't agree on things you can tell me your 
respective positions, and then I can possibly set a 
an 
order going forward. 
MR. EDWARDS: Absolutely. 
Thank you, Your Honor. 
MR. LEE: Yes, Your Honor, of course. 
THE COURT: All right. Anything else we should or 
need to discuss today? 
MR. LEE: Nothing for the Respondents. Thank you, 
Your Honor. 
MR. EDWARDS: And nothing from the Petitioners. 
Thank you, Your Honor. 
THE COURT: Mr. Cassell, anything else? 
MR. CASSELL: No, Mr. Edwards capably conveyed our 
positions. 
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THE COURT: All right. Thank you, again, for being 
available on short notice, and we'll wait to hear back from 
both sides. 
How much time do you think you need to put something 
together? A couple weeks? 
MR. EDWARDS: I would say we could -- yeah, two or 
three weeks I think we'll put it together and we'll submit it. 
MR. LEE: We agree. 
THE COURT: Thank you. Take care. 
(Proceedings concluded.) 
* * * * * 
CERTIFICATE 
I, Stephen W. Franklin, Registered Merit Reporter, and 
Certified Realtime Reporter, certify that the foregoing is a 
correct transcript from the record of proceedings in the 
above-entitled matter. 
Dated this 7th day of DECEMBER, 2015. 
/s/Stephen W. Franklin 
Stephen W. Franklin, RMR, CRR 
EFTA00185202

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MR. CASSELL: [3] 
8/17 9/1913/23 
MR. EDWARDS: [18] 
MR. LEE: [11] 
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-i[1] 1/5 
/s/Stephen [1] 14/19 
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Brad [2) 2/8 8/19 
Bradley [1] 1/15 
briefed [2) 12/1713/3 
briefly [1] 7/18 
Britney [1] 2/8 
ritta 
brou 
teretk 
11 1/15ut
1] 10/25 
C 
came [1] 4/14 
camera [1] 9/12 
can't [2] 9/913/11 
capably [1] 13/24 
care [1] 14/9 
careful [3] 2/23 3/3 3/3 
case 114] 
Cassell [6] 
categorized [1) 5/25 
category [1] 5/19 
cause [1] 12/20 
CERTIFICATE [1] 
14/12 
Certified [1] 14/14 
certify [1] 14/14 
change [2] 6/1 11/4 
Circuit [1] 4/15 
circulated [1] 9/2 
cited [1] 5/23 
CIV [2] 1/22/6 
civil [2] 7/23 11/3 
Clematis [1] 1/22 
co [1] 3/14 
co-counsel [1) 3/14 
comes [1] 11/22 
comment [1) 7/18 
commissions [1] 4/13 
common [1] 12/18 
compel [2] 9/39/6 
complicit [4] 4/10 4/18 
5/9 7/14 
comply [1] 3/5 
concluded (1] 14/10 
conduct [1] 7/14 
confer [2] 6/13 6/20 
CONFERENCE [I] 
1/10 
conferring [3] 6/15 6/23 
7/3 
considered [2] 5/25 6/15 
contacted [1] 12/1 
contested [I] 3/9 
context [1) 11/1 
conveyed [1) 13/24 
correct [3] 8/169/16 
14/15 
counsel [3] 2/7 3/1413/6 
couple [2] 12/614/5 
course [3] 7/20 7/20 
13/16 
court [7] 
CPE [1] 1/21 
crime [1] 5/14 
criminal [5] 
cross [1] 5/2 
CRR [2] 1/2114/20 
cutoff [1] 10/6 
CVRA [1] 7/19 
D 
date [1] 13/3 
Dated [1] 14/17 
days [3] 3t20 12/6 12/6 
deadline [3] 2/25 3/1 
n
o
s
e
deadlines [1] 10/13 
deal [2] 4/4 9/23 
dealing [1] 7/13 
December [4] 3/13/21 
10/314/17 
December 15th [3] 3/1 
3/21 10/3 
decide [3] 10/2411/1 
12/23 
defenses [1] 11/18 
denied [4] 3/10 7/1 8/10 
10/18 
deny [1] 6/6 
depends [1] 11/17 
deposition [2] 6/17 6/21 
depositions [1] 3/11 
deterntination [1] 11/23 
determine [1] 6/11 
Dexter [2] 1/182/13 
directed [1] 4/23 
discovery [17] 
discuss [3] 2/17 8/21 
13/18 
discussion [1) 9/5 
dispute [2] 7/24 7/24 
disqualified [1] 5/9 
DISTRICT [3] 1/11/1 
1/12 
DOE [5] 
Does [3] 4/10 5/18 7/14 
doesn't [2] 9/12 10/14 
don't [14] 
done [3] 10/1712/6 
13/11 
down [4] 4/5 6/811/19 
11/22 
draft [1] 10/3 
E 
E-mail [1] 1/23 
Ed [2] 1/19 2/13 
Edwards [9] 
Eight [1] 3/17 
Eleventh [1) 4/15 
else [4] 6/16 9/2413/17 
13/23 
engage [1] 3/12 
entitled [3] 4/1912/19 
14/16 
entitlement [1] 12/15 
envision [1] 3/14 
Epstein [2] 4/12 7/15 
especially [I) 3/20 
ESQ [3] 1/15 1/15 1/16 
et [1] 1/16 
even [2] 6/189/11 
event [1] 8/9 
evidence [2] 11/1212/2 
evidentiary [5] 
examination [1] 12/9 
example [1] 6/13 
except [1] 10/1 
exercise [1] 8/8 
exhibits [1] 3/4 
exist [1] 12/20 
extension [1] 5/1 
extent [2] 5/207/1 
F 
F.3d [1] 4/16 
fact [2] 5/13 6/11 
factual [1] 7/24 
factually [11 11/11 
fall [2] 3/25/19 
far [1] 12/14 
Farmer [1] 1/16 
feel [1] 7/2 
fees [1] 4/13 
figure [1] 6/21 
file [7] 
filed [3] 3/5 9/1011/3 
thing [2] 2/25 9/6 
finds [1] 7/24 
fine [1] 8/1 
first [3] 5/15/22 9/9 
F142) 1/171/20 
FLORIDA [3] 1/1 1/7 
1/23 
foregoing [1] 14/14 
foresee [4] 3/10 4/8 7/15 
8/14 
foreseeing [1] 6/8 
form [1] 10/3 
Fort [1] 1/17 
forward [4] 4/810/13 
13/10 13/13 
found [1] 4/17 
founding [1] 12/18 
frame [1] 10/9 
Franklin [4] 1/21 14/13 
14/19 14/20 
frankly [1] 5/24 
further [1] 8/3 
G 
genuine [1] 6/11 
gets [3) 3/4 5/21 11/22 
getting [1] 3/14 
give [1] 6/19 
giving [1] 11/6 
goes [2] 8/912/16 
ODE (23] 
Good [6] 
Government [11] 
Government's [1] 11/18 
granted [1] 3/7 
guess [6] 
H 
hammer [1] 6/23 
happened [I] 11/11 
haven't [1] 10/21 
Health [1] 4/15 
hear [1] 14/2 
heard [3] 5/751227/9 
hearing [6] 
held (2] 8/1 10/19 
help [1] 10/8 
Henderson [2] 1/15 2/8 
here [2] 2/5 6/16 
holidays [1) 3/21 
Honor [22] 
HONORABLE [1] 1/11 
hope [1] 3/16 
Hopefully [1] 9/17 
EFTA00185203