EFTA00206173

Associated Newspapers Ltd. Registered Office: 
• 
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this e-mail may not reflect the views and opinions of Associated Newspapers Limited or any of its subsidiary companies. 
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abuse of these facilit! 
ies. 
Associated Newspapers Ltd. Registered Office: 
From: 
(USAFLS) 
Sent: 
Friday, March 04, 2011 3:52 PM 
To: 
(USAFLS) 
Subject: 
Re: Jeffrey Epstein 
Let me call you before you respond 
Fro 
ill 
Message ----
(USAFLS) 
March 04, 2011 03:47 PM 
. (USAFLS) 
Su: 
(USAFL 
Subject: FW: Jeffrey Epstein 
Here is his inquiry =— he wants me to confirm whether FBI is interested in this info. I will not. 
 
Original 
a----
From: 
[mailto: 
Sent: Fricl
arch 04, 2011 3:16 PM 
To: =,=I 
(USAFLISI S 
Subject: Jeffrey Epstein 
Dear 
I work for the Mail on Sunday newspaper in London. En land. The Mail on 
Sunday last week published an interview with 
about her 
time working for Jeffrey Epstein. We plan to publish more revelations this 
week. 
I have been led to believe that the FBI is interested in pursuing the 
allegations published in the Mail on Sunday - and that Epstein may have 
committed offences not covered by the non prosecution agreement. 
Can you give me any guidance as to whether my information is correct? 
You may contact me by email or on 
Regards, 
EFTA00206293

Nick Pryer 
Assistant Features Editor 
Mail on Sunday 
This e-mail and any attached files are intended for the named addressee 
only. It contains information which may be confidential and legally 
privileged and also protected by copyright. Unless you are the named 
addressee (or authorised to receive for the addressee) you may not copy or 
use it, or disclose it to anyone else. If you received it in error please 
notify the sender immediately and then delete it from your system. Please 
be advised that the views and opinions expressed in this e-mail may not 
reflect the views and opinions of Associated Newspapers Limited or any of 
its subsidiary companies. We make every effort to keep our network free 
from viruses. However, you do need to check this e-mail and any attachments 
to it for viruses as we can take no responsibility for any computer virus 
which may be transferred by way of this e-mail. Use of this or any other 
e-mail facility signifies consent to any interception we might lawfully 
carry out to prevent abuse of these facilities. 
Associated News a ers Ltd. Registered Office: 
This e-mail and any attached files are intended for the named addressee only. It contains information, which may be 
confidential and legally privileged and also protected by copyright. Unless you are the named addressee (or authorised to 
receive for the addressee) you may not copy or use it, or disclose it to anyone else. If you received it in error please notify 
the sender immediately and then delete it from your system. Please be advised that the views and opinions expressed in 
this e-mail may not reflect the views and opinions of Associated Newspapers Limited or any of its subsidiary companies. 
We make every effort to keep our network free from viruses. However, you do need to check this e-mail and any 
attachments to it for viruses as we can take no responsibility for any computer virus which may be transferred by way of 
this e-mail. Use of this or any other e-mail facility signifies consent to any interception we might lawfully carry out to prevent 
abuse of these facilitl 
ies. 
Associated Newspapers Ltd. Registered Office: 
From: 
(USAFI-S) 
Sent: 
Wednesday, March 09, 20114:33 PM 
To: 
(USAFLS); 
(USAFLS); 
(USAFLS); 
(USAFLS); 
(USAFLS) 
Cc: 
. (FBI) 
Subject: 
Highly Confidential -- Preliminary Investigation of Additional Crimes of Jeffrey Epstein and 
Others 
Importance: 
High 
As all of you know, there has been much in the press lately about revelations by 
regarding her 
relationship with Jeffrey Epstein and his introduction of her to a number of highly placed world and business 
leaders. Ms. 
was one of the victims identified in our initial investigation of Jeffrey Epstein, although at 
the time we were only able to speak to her briefly on the telephone, and the agency and the office were unwilling 
to spend the funds to fly a group to Australia to interview her without an assurance that she would provide 
complete information. 
Through speaking with the press, Ms. 
made contact with Brad Edwards and his investigator, 
Fisten, who in turn, reached out to me, and I to Special Agent 
regarding these new allegations. (They 
EFTA00206294

are not allegations that we had heard from Ms. 
during the initial investigation.) Special Agent 
and I spoke briefly with Ms. 
on Monday to arrange with her to do a formal interview, with FBI LegAt 
and Australian National Police involvement, at the American embassy in Sydney. We are trying to set up that 
interview for Monday or Tuesday. 
Today, Special Agent 
and I met with Brad Edwards, 
Fisten, and one of Brad Edwards' law 
partners, Steve Jaffe, regarding Ms. 
' allegations and other potential crimes uncovered during the course 
of Edwards' and Fisten's lengthy investigation of Epstein during their prosecution of several civil suits against 
him. I mean to provide you all with a lengthy legal memo discussing the potential charges against Epstein and 
the effect of the Non-Prosecution Agreement on any prosecution, but the things we learned today were of such 
significance, that I did not want to wait any longer. 
Fisten provided us with the following information regarding 
Ms. 
has reported 
that she was flown all over the United States and Europe to have sex with a number of prominent men and one 
woman. All of the trips were on Epstein's private plane and after each encounter she was paid by Epstein. Ms. 
also reports that the encounters were videotaped by Epstein and, at the end of each encounter, Epstein 
would "debrief" Ms. 
and take notes. These allegations are consistent with information received during 
our investi ation that Epstein made his millions by "getting dirt" on important people and blackmailing them. 
Ms. 
also reported that Epstein gave her Xanax to keep her emotionally malleable. 
The important
 who were listed are: Governor Bill Richardson; Prince Andrew; Alan Dershowitz (oral sex 
when Ms. 
was 16); Senator George Mitchell; (former) Israeli Prime Minister Ehud Barak; Les Wexner 
(CEO of The Limited GroupNictorias Secret); Ghislaine Maxwell. Glenn Dubin (founder of Highbridge 
Capital); and a Nobel Prize winning scientist from Harvard. Ms. 
has allegedly seen some of the videos 
and she may have pictures or other documentation, but we will need to get that from her. She also said that there 
were a lot of other
 that she was forced to have sex with, but she would need to see pictures to identify 
them. Ms. 
also reported that President Bill Clinton came to Epstein's house several times and received 
"erotic massages," although not from her, and at least one of these happened while he was still president. Some 
of these encounters occurred in Palm Beach, some in New Mexico, some in the U.S. Virgin Islands, and some in 
Europe (all at Epstein's residences or on his plane). [Please note that the newspapers say "there is no allegation 
that there was any sexual contact with Prince Andrew" due to the libel laws in England that don't allow the un-
corroborated statements to be published, but she did report having sex with all of the above-listed men to the 
reporter, according to Fister.] 
Ms. 
identified at least two other girls who were prostituted by Epstein to this high-profile men. 
In addition to these crimes, Brad Edwards and 
Fisten provided a lot of information regarding their own 
investigation of Epstein that relate to obstruction of justice, including: Epstein's perjury during a deposition in 
one of the civil cases that led the court reporter to approach Edwards and say "that is the clearest case of perjury 
I have ever seen and I will be happy to testify about it for you;" evidence of Epstein and his  probation officer 
falsifying records showing that Epstein was at home while Epstein was in South Beach or outside the state; and 
Epstein sending a lawyer to see a victim who had been subpoenaed and telling her that the government was 
going to take away her baby if she cooperated. 
And, last but certainly not least, there was a long discussion of Epstein's involvement with a modeling agency 
based in New York and Miami that was used as a front to bring in underage girls to service Epstein and his 
friends. There are a number of potential targets related to these allegations but, in short, the agency would 
submit fraudulent visa applications saying that the girls were here to model, but they were really brought in to 
prostitute — a classic human trafficking case. Epstein's partner has previously been discredited in connection 
with a former modeling agency he owned where he used promises of modeling contracts to sexually abuse 
young girls. 
Edwards and Fister also have been in contact with a "source" who Epstein has contacted to discuss developing a 
new "system" to obtain large amounts of girls. They are going to provide Wende's card to this "source" to see if 
EFTA00206295

he is willing to cooperate. 
As mentioned, I will write up a formal memo with analysis and a proposed course of conduct. 
Assistant U.S. Attorney 
Fax 
From: 
(USAFLS) 'c
> 
Sent: 
Monday, February 28, 2011 1:35 PM 
To: 
. (USAFLS) 
Subject: 
RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
Sure - who is 
by the way? 
From: 
(USAFLS) 
Sent: Monda , Februa 
28, 2011 1:29 PM 
To: 
(USAFLS); 
(USAFLS) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
Maybe after we finish with DOJ, the four of us (you two and 
and I) can stay on and discuss a bit 
further? After my discussion with the person at Appellate and some case law research, I have some 
ideas. 
Assistant U.S. Attorney 
Fax 
EFTA00206296

From: 
(USAFLS) 
Sent: Monda , February 28, 2011 1:25 PM 
To: 
(USAFLS); 
(USAFLS) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.FIa.) 
Absolutely. I agree with you. Thanks. 
From: 
(USAFLS) 
Sent: Monda , Februa 
28, 2011 1:24 PM 
To: 
(USAFLS); 
(USAFLS) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.FIa.) 
I really don't think we can do what Cassell asks, to stand by and do nothing. 
Can I represent that as 
our office's position? 
From: 
(USAFLS) 
Sent: Monda , February 28, 2011 1:21 PM 
To: 
(USAFLS); 
(USAFLS) 
Subject: FW: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
I'm going to call in but really only to listen. Thanks. 
From: 
(USAEO) 
Sent: Monda , February 28, 2011 1:12 PM 
To: 
(USAEO); 
. (SMO); 
(USAFLS
Cc: 
(USAFLS); 
. (USAFLS) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.FIa.) 
. (USAFLS); 
The call in number for 1:30 is 
, pass code 
EFTA00206297

From: 
(USAEO) 
Sent: Monda February 28, 2011 12:29 PM 
To: 
. (SMO); 
. (USAFLS); 
Cc: 
(USAFLS); 
. (USAFLS) 
Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
Let's say 1:30. We will get a call in #. Thanks. 
From: 
Sent: Monda 
To: 
(SMO) 
Februa 
28, 2011 12:27 PM 
. (USAFLS); 
(USAEO); 
Cc: 
(USAFLS); 
(USAFLS) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
Me too. 
From: 
(USAFLS) 
Sent: Monda , February 28, 2011 12:25 PM 
To: 
(USAEO); 
(USAEO); -
(USAFLS
Cc: 
(USAFLS); 
. (USAFLS) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
Either of those times works for me. Thank you. 
Assistant U.S. Attorney 
Fax 
From: 
(USAEO) 
Sent: Monday, February 28, 2011 12:25 PM 
(USAEO); 
(USAEO); 
. (SMO); 
EFTA00206298

. (USAFLS); 
(USAEO); 
. (SMO); 
Cc: 
(USAFLS); 
. (USAFLS) 
Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
I apologize, but we didn't schedule since we hadn't heard regarding everyone's availability. Does 1:00 
or 1:30 work? 
From: 
(USAFLS) 
Sent: Monda Februa 
28, 2011 11:54 AM 
To:
USAEO); 
(USAFLS); 
SMO); MilaUSAFLS) 
Cc: 
. (USAFLS); 
(USAEO) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
Are we speaking at noon? What is the call-in number? 
Thank you. 
Assistant U.S. Attorney 
Fax 
(USAEO) 
February 28, 2011 9:08 AM 
SMO); 
USAFLS 
. (USAFLS); 
(USAFLS); 
(USAEO) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
. (USAFLS); 
If you mean can I get a conference call line, yes, I can. 
EFTA00206299

(SMO) 
February 28, 2011 9:07 AM 
USAEO); 
USAFLS 
. (USAFLS); 
(USAFLS); 
. (USAFLS); 
(USAEO) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
: Can you set up a call? I have a 10:00 meeting (30 minutes), and an as yet unscheduled 
obligation to assist in briefing the AG for his testimony on the Hill tomorrow. Sometime between noon 
and 1 is likely to be best for me. 
(USAEO) 
February 28, 2011 8:43 AM 
SMO); 
USAFLS 
. (USAFLS); 
(USAFLS); 
(USAEO) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
I agree, as well. I am available anytime between noon and 3:00 today. 
From: 
(SMO) 
Sent: Saturda February 26, 2011 4:19 PM 
To: 
(USAFLS); 
Cc: 
. (USAFLS); 
(USAFLS); 
Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
USAEO 
I agree completely. Let's try and talk Monday, with 
on the phone if possible. 
From: 
Sent: Saturda 
To: 
Cc: 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
(USAFLS) 
February 26, 2011 04:08 PM 
SMO); 
. (USAFLS); 
USAEO 
. (USAFLS); 
. (USAFLS) 
(USAFLS); 
. (USAFLS) 
Mr. 
I'm looking for the appropriate officials in the Department with programmatic responsibility for the 
CVRA, so that we may obtain guidance on our litigating position. 
What Cassell wants the 
government to do is abdicate its role in defending its actions. If the DOJ's position is that no rights 
attach until a charging instrument is filed, then we should vigorously defend that position. Our office is 
EFTA00206300

most reluctant to do what Cassell asks, since negotiating the non-prosecution agreement was clearly 
within the prerogatives granted to the Executive Branch. 
Whether the bargain struck with Epstein 
was wise or not should not be the issue. 
I will be in the office all day Monday. Thanks for your assistance. 
From: 
(SMO) 
Sent: Saturda February 26, 2011 3:40 PM 
To: 
(USAFLS); 
Cc: 
. (USAFLS); 
(USAFLS) 
Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
USAEO 
Thanks. Perhaps we should try and find a time to talk on Monday. This scenario raises a 
variety of policy issues that extend well beyond the question of "when do the rights attach." Frankly, I 
don't think the court should even reach that question given the posture of the case as you describe it. 
From: 
(USAFLS) 
Sent: Saturda February 26, 2011 02:23 PM 
To: 
SMO); 
USAEO 
Cc: 
. (USAFLS); 
(USAFLS) 
Subject: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
Ms. 
and Mr. 
Our office is currently litigating a Crime Victims Rights Act (CVRA) lawsuit filed by Jane Does 1 and 2, 
who were victims of sexual abuse by Jeffrey Epstein, a multi-millionaire investor living in Palm Beach, 
Florida. 
Jane Does 1 and 2 v. United States Case No. 08-80736-CIV-MARRA (S.D.Fla.). We are 
seeking your advice and guidance on a proposal from the victims' attorneys, that the government take 
no position on whether the CVRA granted rights to the victims, when the U.S. Attorney's Office 
negotiated a non-prosecution agreement with Epstein. 
In 2006, the Palm Beach Police Department began investigating allegations that Jeffrey Epstein was 
enticing underage girls into prostitution. 
Epstein was alleged to have paid underage girls to provide 
him with massages, while the young girls were unclothed. 
The case was referred to the FBI and 
U.S. Attorney's Office, and the FBI began its own investigation. 
Epstein hired a number of highly-
paid attorneys, including Alan Dershowitz and Kenneth Starr, to attempt to stave off criminal charges. 
Ultimately, in 2007, Epstein was charged in state court with soliciting minors for prostitution. 
In 
September 2007, the U.S. Attorney's Office entered into a Non-Prosecution Agreement with Epstein, in 
which he agreed to plead guilty to the state criminal charge, and serve a sentence of 18 months. 
EFTA00206301

Epstein also agreed that, in any civil action under 18 U.S.C. 2255 by the underage victims, he would 
not raise the lack of a federal sex offense as a defense. 
In July 2008, Epstein plead guilty, and 
was sentenced to serve six months at the Palm Beach County Detention Facility, followed by 12 
months in home detention. 
In July 2008, after the Non-Prosecution Agreement had been executed, two victims, 
and • 
filed 
an action under the CVRA, 18 U.S.C. 3771. 
They claimed that the government was obligated, under 
18 U.S.C. 3771(a)(5), to speak with the victims prior to the execution of the Non-Prosecution 
Agreement. 
An emergency hearing was held on July 11, 2008, before U.S. District Judge Kenneth 
Marra. 
Since Epstein had entered his state court plea and been sentenced already, the court found 
there was no emergency. He directed the parties to meet and determine if there were any factual 
disputes and whether an evidentiary hearing would be necessary. 
Attorney Brad Edwards initially represented the victims. 
Soon, he was joined by Paul Cassell, a 
University of Utah law professor, and former federal judge who served in the District of Utah from 
2002-2007. Cassell is a victims' rights advocate who has appeared in many cases throughout the 
United States. 
The victims' rights suit was inactive for the next two years, with Edwards and Cassell 
using the civil suit as a means to attempt to gain access to information helpful in their civil actions for 
damages against Epstein. 
They were able to obtain a copy of the Non-Prosecution Agreement 
through the civil litigation. 
In August 2010, the district court, noting that the last civil suit had been settled, entered an order 
closing the case. 
Edwards and Cassell immediately filed documents with the court, advising that the 
case should not be closed or dismissed, and they wanted to pursue final action by the court. 
Since 
September 2010, AUSA 
and I have been dealing with Cassell and Edwards on how to 
resolve the case. 
They claim the victims had a right to be consulted prior to the execution of the 
Non-Prosecution Agreement, and that we violated the CVRA by not consulting them. 
The remedy 
they seek is a set aside by the court of the Non-Prosecution Agreement, and a prosecution of Epstein. 
On December 10, 2010, United States Attorney Wifredo A. M, 
, and I, met with Cassell, Edwards, and M, one of the victims. 
We discussed the 
posture of the case, and 
told us her views of what occurred and her desire to see Epstein receive 
justice for what he did. Cassell presented U.S. Attorney 
a four-page letter, requesting an 
investigation of the Jeffrey Epstein prosecution. He claims there may have been improper influence 
exercising by Epstein, noting that Epstein is a "politically-connected billionaire." 
Cassell cites to an 
alleged ti off to E stein that a search warrant on his residence was to be executed; that a former 
AUSA, 
, left the West Palm Beach office and soon began appearing on behalf of 
individuals aligned with Epstein; and an unprecedented level of secrecy between the FBI and the U.S. 
Attorney's Office, where the FBI was purportedly kept in the dark about the impending Non-
Prosecution Agreement. 
He also claims that the victims were deceived regarding the existence of 
the Non-Prosecution Agreement. 
Cassell's request for an investigation was referred to DOJ OPR on December 16, 2010. 
has requested various documents from our office, presumably to determine whether an 
investigation should be opened. 
Cassell and Edwards had planned to file a motion for summary 
judgment on December 17, 2010. Due to concerns that the U.S. Attorney's Office might have to be 
recused, due to the allegations of misconduct, Cassell agreed to defer filing their motion. 
We have 
since been advised by EOUSA General Counsel's Office that there is no need for our office to recuse 
itself, since we are only litigating the legal issue of whether rights under the CVRA attached. 
After the new year began, Cassell inquired about the status of the OPR complaint and the recusal 
issue. 
EFTA00206302

On Thursday, February 10, 2011, Deputy Chief 
AUSA 
and I spoke 
with Cassell and Edwards regarding the status of the case. I told them Cassell's letter request for an 
investigation of the Non-Prosecution Agreement had been referred to OPR, and OPR had requested 
various documents from our office. 
I also told them the EOUSA General Counsel's office advised 
that our office could go ahead and represent the United States in the CVRA lawsuit. I suggested that 
the parties were ready to move forward with filing documents with the court so it could resolve this 
case. 
I asked whether it might be useful to engage in mediation in an attempt to resolve the case. 
Cassell 
told us they wanted the Non-Prosecution Agreement to be set aside. 
I told him that was not likely to 
happen. Cassell then suggested that the United States Government should step aside and allow 
them to "go after" Epstein to get the agreement set aside. 
I asked him how he expected that would 
be done, since the only parties to the Non-Prosecution Agreement were Epstein and the 
Government. 
Cassell said they would file their summary judgment motion, and the government 
would take no position on their motion. Presumably, Epstein would either intervene, or be brought in 
as a necessary party, and defend the Non-Prosecution Agreement. 
I told them this would have to be 
approved by the U.S. Attorney and Main Justice. 
I have serious misgivings about not defending the Executive Branch's prerogative to engage in a Non-
Prosecution Agreement, free from supervision or oversight by the judiciary. 
If we stand by the 
sidelines, Cassell will be arguing the Government was obligated to consult with the victims, and 
because we failed to do so, the agreement is a nullity. 
Whatever we may think of the Agreement, it 
was the prerogative of the U.S. Attorney's Office to enter into it with Epstein, and we should be willing 
to defend what we did. The DOJ's position is that the rights in the CVRA do not attach until there is a 
federal court proceeding. 
Since Epstein was never charged in federal court, we were not obligated 
to consult with the victims before entering into the Non-Prosecution Agreement. 
We wanted to seek your views on Cassell's suggestion before we responded to him. We are currently 
scheduled to have a conference call with Cassell and Edwards on Tuesday, March 1. I can be 
reached at 
. Thanks. 
• 
From: 
(USAFLS) 
Sent: 
Monday, February 28, 2011 1:29 PM 
To: 
(USAFLS); 
(USAFLS) 
Subject: 
RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.FIa.) 
Maybe after we finish with DOJ, the four of us (you two and 
and I) can stay on and discuss a bit 
further? After my discussion with the person at Appellate and some case law research, I have some 
ideas. 
Assistant U.S. Attorney 
EFTA00206303

Fax 
From: 
(USAFLS) 
Sent: Monda , February 28, 2011 1:25 PM 
To: 
(USAFLS); 
(USAFLS) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.FIa.) 
Absolutely. I agree with you. Thanks. 
From: 
(USAFLS) 
Sent: Monda , Februa 
28, 2011 1:24 PM 
To: 
(USAFLS); 
(USAFLS) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.FIa.) 
I really don't think we can do what Cassell asks, to stand by and do nothing. 
Can I represent that as 
our office's position? 
From: 
(USAFLS) 
Sent: Monda , February 28, 2011 1:21 PM 
To: 
(USAFLS); 
(USAFLS) 
Subject: FW: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
I'm going to call in but really only to listen. Thanks. 
From: 
(USAEO) 
Sent: Monda , February 28, 2011 1:12 PM 
To: 
(USAEO); 
. (SMO); 
(USAFLS
Cc: 
(USAFLS); 
. (USAFLS) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.FIa.) 
. (USAFLS); 
EFTA00206304

The call in number for 1:30 is 
, pass code 
From: 
(USAEO) 
Sent: Monda , February 28, 2011 12:29 PM 
To: 
. (SMO); 
. (USAFLS); 
(USAEO); 
Cc: 
(USAFLS); 
. (USAFLS) 
Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
Let's say 1:30. We will get a call in #. Thanks. 
From: 
Sent: Monda 
To: 
(SMO) 
Februa 
28, 2011 12:27 PM 
. (USAFLS); 
(USAEO); 
Cc: 
(USAFLS); 
(USAFLS) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
Me too. 
From: 
(USAFLS) 
Sent: Monda . February 28. 2011 12:25 PM 
To: 
(USAEO); 
(USAEO); 
Cc: 
(USAFLS); -.
(USAFLS) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
Either of those times works for me. Thank you. 
Assistant U.S. Attorney 
(USAEO); 
. (SMO); 
EFTA00206305

Fax 
From: 
(USAEO) 
Sent: Monda Februa 
28, 2011 12:25 PM 
To: 
. (USAFLS); 
(USAEO); 
Cc: 
(USAFLS); 
. (USAFLS) 
Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
. (SMO); 
I apologize, but we didn't schedule since we hadn't heard regarding everyone's availability. Does 1:00 
or 1:30 work? 
From: 
. (USAFLS) 
Sent: Monda Februar 28, 2011 11:54 AM 
To:
USAEO); 
(USAFLS); 
SMO); MilaUSAFLS) 
Cc: 
. (USAFLS); 
(USAEO) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
Are we speaking at noon? What is the call-in number? 
Thank you. 
Assistant U.S. Attorney 
Fax 
(USAEO) 
February 28, 2011 9:08 AM 
SMO); 
USAFLS 
. (USAFLS); 
(USAFLS);U 
(USAEO) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
. (USAFLS); 
EFTA00206306

If you mean can I get a conference call line, yes, I can. 
(SMO) 
February 28, 2011 9:07 AM 
USAEO); 
USAFLS 
. (USAFLS); 
(USAFLS); 
(USAEO) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
. (USAFLS); 
: Can you set up a call? I have a 10:00 meeting (30 minutes), and an as yet unscheduled 
obligation to assist in briefing the AG for his testimony on the Hill tomorrow. Sometime between noon 
and 1 is likely to be best for me. 
(USAEO) 
February 28, 2011 8:43 AM 
SMO); 
USAFLS 
. (USAFLS); 
(USAFLS); 
(USAEO) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
I agree, as well. I am available anytime between noon and 3:00 today. 
From: 
(SMO) 
Sent: Saturda February 26, 2011 4:19 PM 
To: 
USAFLS ; 
Cc: 
. (USAFLS); 
(USAFLS); 
Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
USAEO 
I agree completely. Let's try and talk Monday, with 
on the phone if possible. 
. (USAFLS); 
. (USAFLS) 
From: 
(USAFLS) 
Sent: Saturda February 26, 2011 04:08 PM 
To: 
SMO); 
USAEO 
Cc: 
. (USAFLS); 
(USAFLS); 
. (USAFLS) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
Mr. 
EFTA00206307

I'm looking for the appropriate officials in the Department with programmatic responsibility for the 
CVRA, so that we may obtain guidance on our litigating position. 
What Cassell wants the 
government to do is abdicate its role in defending its actions. If the DOJ's position is that no rights 
attach until a charging instrument is filed, then we should vigorously defend that position. Our office is 
most reluctant to do what Cassell asks, since negotiating the non-prosecution agreement was clearly 
within the prerogatives granted to the Executive Branch. 
Whether the bargain struck with Epstein 
was wise or not should not be the issue. 
I will be in the office all day Monday. Thanks for your assistance. 
From: 
Sent: Saturda 
To: 
Cc: 
. (USAFLS); 
(USAFLS) 
Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
(SMO) 
February 26, 2011 3:40 PM 
USAFLS); 
USAEO 
Thanks. Perhaps we should try and find a time to talk on Monday. This scenario raises a 
variety of policy issues that extend well beyond the question of "when do the rights attach." Frankly, I 
don't think the court should even reach that question given the posture of the case as you describe it. 
From: 
Sent: Saturda 
To: 
Cc: 
Subject: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
(USAFLS) 
February 26, 2011 02:23 PM 
SMO); 
. (USAFLS); 
USAEO 
(USAFLS) 
Ms. 
and Mr. 
Our office is currently litigating a Crime Victims Rights Act (CVRA) lawsuit filed by Jane Does 1 and 2, 
who were victims of sexual abuse by Jeffrey Epstein, a multi-millionaire investor living in Palm Beach, 
Florida. 
Jane Does 1 and 2 v. United States Case No. 08-80736-CIV-MARRA (S.D.Fla.). We are 
seeking your advice and guidance on a proposal from the victims' attorneys, that the government take 
no position on whether the CVRA granted rights to the victims, when the U.S. Attorney's Office 
negotiated a non-prosecution agreement with Epstein. 
In 2006, the Palm Beach Police Department began investigating allegations that Jeffrey Epstein was 
enticing underage girls into prostitution. 
Epstein was alleged to have paid underage girls to provide 
him with massages, while the young girls were unclothed. 
The case was referred to the FBI and 
EFTA00206308

U.S. Attorney's Office, and the FBI began its own investigation. 
Epstein hired a number of highly-
paid attorneys, including Alan Dershowitz and Kenneth Starr, to attempt to stave off criminal charges. 
Ultimately, in 2007, Epstein was charged in state court with soliciting minors for prostitution. 
In 
September 2007, the U.S. Attorney's Office entered into a Non-Prosecution Agreement with Epstein, in 
which he agreed to plead guilty to the state criminal charge, and serve a sentence of 18 months. 
Epstein also agreed that, in any civil action under 18 U.S.C. 2255 by the underage victims, he would 
not raise the lack of a federal sex offense as a defense. 
In July 2008, Epstein plead guilty, and 
was sentenced to serve six months at the Palm Beach County Detention Facility, followed by 12 
months in home detention. 
In July 2008, after the Non-Prosecution Agreement had been executed, two victims, 
and • 
filed 
an action under the CVRA, 18 U.S.C. 3771. 
They claimed that the government was obligated, under 
18 U.S.C. 3771(a)(5), to speak with the victims prior to the execution of the Non-Prosecution 
Agreement. 
An emergency hearing was held on July 11, 2008, before U.S. District Judge Kenneth 
Marra. 
Since Epstein had entered his state court plea and been sentenced already, the court found 
there was no emergency. He directed the parties to meet and determine if there were any factual 
disputes and whether an evidentiary hearing would be necessary. 
Attorney Brad Edwards initially represented the victims. 
Soon, he was joined by Paul Cassell, a 
University of Utah law professor, and former federal judge who served in the District of Utah from 
2002-2007. Cassell is a victims' rights advocate who has appeared in many cases throughout the 
United States. 
The victims' rights suit was inactive for the next two years, with Edwards and Cassell 
using the civil suit as a means to attempt to gain access to information helpful in their civil actions for 
damages against Epstein. 
They were able to obtain a copy of the Non-Prosecution Agreement 
through the civil litigation. 
In August 2010, the district court, noting that the last civil suit had been settled, entered an order 
closing the case. 
Edwards and Cassell immediately filed documents with the court, advising that the 
case should not be closed or dismissed, and they wanted to pursue final action by the court. 
Since 
September 2010, AUSA 
and I have been dealing with Cassell and Edwards on how to 
resolve the case. 
They claim the victims had a right to be consulted prior to the execution of the 
Non-Prosecution Agreement, and that we violated the CVRA by not consulting them. 
The remedy 
they seek is a set aside by the court of the Non-Prosecution Agreement, and a prosecution of Epstein. 
On December 10, 2010, United States Attorney Wifredo A. M, 
, and I, met with Cassell, Edwards, and M, one of the victims. 
We discussed the 
posture of the case, and 
told us her views of what occurred and her desire to see Epstein receive 
justice for what he did. Cassell presented U.S. Attorney 
a four-page letter, requesting an 
investigation of the Jeffrey Epstein prosecution. He claims there may have been improper influence 
exercising by Epstein, noting that Epstein is a "politically-connected billionaire." 
Cassell cites to an 
alleged ti off to E stein that a search warrant on his residence was to be executed; that a former 
AUSA, 
, left the West Palm Beach office and soon began appearing on behalf of 
individuals aligned with Epstein; and an unprecedented level of secrecy between the FBI and the U.S. 
Attorney's Office, where the FBI was purportedly kept in the dark about the impending Non-
Prosecution Agreement. 
He also claims that the victims were deceived regarding the existence of 
the Non-Prosecution Agreement. 
Cassell's request for an investigation was referred to DOJ OPR on December 16, 2010. 
has requested various documents from our office, presumably to determine whether an 
investigation should be opened. 
Cassell and Edwards had planned to file a motion for summary 
judgment on December 17, 2010. Due to concerns that the U.S. Attorney's Office might have to be 
recused, due to the allegations of misconduct, Cassell agreed to defer filing their motion. 
We have 
EFTA00206309

since been advised by EOUSA General Counsel's Office that there is no need for our office to recuse 
itself, since we are only litigating the legal issue of whether rights under the CVRA attached. 
After the new year began, Cassell inquired about the status of the OPR complaint and the recusal 
issue. 
On Thursday, February 10, 2011, Deputy Chief 
AUSA 
and I spoke 
with Cassell and Edwards regarding the status of the case. I told them Cassell's letter request for an 
investigation of the Non-Prosecution Agreement had been referred to OPR, and OPR had requested 
various documents from our office. 
I also told them the EOUSA General Counsel's office advised 
that our office could go ahead and represent the United States in the CVRA lawsuit. I suggested that 
the parties were ready to move forward with filing documents with the court so it could resolve this 
case. 
I asked whether it might be useful to engage in mediation in an attempt to resolve the case. 
Cassell 
told us they wanted the Non-Prosecution Agreement to be set aside. 
I told him that was not likely to 
happen. Cassell then suggested that the United States Government should step aside and allow 
them to "go after" Epstein to get the agreement set aside. 
I asked him how he expected that would 
be done, since the only parties to the Non-Prosecution Agreement were Epstein and the 
Government. 
Cassell said they would file their summary judgment motion, and the government 
would take no position on their motion. Presumably, Epstein would either intervene, or be brought in 
as a necessary party, and defend the Non-Prosecution Agreement. 
I told them this would have to be 
approved by the U.S. Attorney and Main Justice. 
I have serious misgivings about not defending the Executive Branch's prerogative to engage in a Non-
Prosecution Agreement, free from supervision or oversight by the judiciary. 
If we stand by the 
sidelines, Cassell will be arguing the Government was obligated to consult with the victims, and 
because we failed to do so, the agreement is a nullity. 
Whatever we may think of the Agreement, it 
was the prerogative of the U.S. Attorney's Office to enter into it with Epstein, and we should be willing 
to defend what we did. The DOJ's position is that the rights in the CVRA do not attach until there is a 
federal court proceeding. 
Since Epstein was never charged in federal court, we were not obligated 
to consult with the victims before entering into the Non-Prosecution Agreement. 
We wanted to seek your views on Cassell's suggestion before we responded to him. We are currently 
scheduled to have a conference call with Cassell and Edwards on Tuesday, March 1. I can be 
reached at 
. Thanks. 
• 
From: 
(USAFLS) 'c
> 
Sent: 
Monday, February 28, 2011 1:55 PM 
To: 
. (USAFLS); 
(USAFLS) 
Subject: 
RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
Probably a conference call is just as easy. 
From: 
(USAFLS) 
Sent: Monda , Februa 
28, 2011 1:54 PM 
To: 
(USAFLS); 
(USAFLS) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
EFTA00206310

Should we call the number again? Or should I just do a conf call? 
Assistant U.S. Attorney 
Fax 
From: 
(USAFLS) 
Sent: Monda , Februa 
28, 2011 1:35 PM 
To: 
. (USAFLS) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
Sure - who is 
by the way? 
From: 
(USAFLS) 
Sent: Monda , Februa 
28, 2011 1:29 PM 
To: 
(USAFLS); 
(USAFLS) 
Subject: RE: Jane Does 1 and 21 United States - CVRA Lawsuit (S.D.Fla.) 
Maybe after we finish with DOJ, the four of us (you two and 
and I) can stay on and discuss a bit 
further? After my discussion with the person at Appellate and some case law research, I have some 
ideas. 
Assistant U.S. Attorney 
EFTA00206311

Fax 
From: 
(USAFLS) 
Sent: Monda , February 28, 2011 1:25 PM 
To: 
(USAFLS); 
(USAFLS) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.FIa.) 
Absolutely. I agree with you. Thanks. 
From: 
(USAFLS) 
Sent: Monda , Februa 
28, 2011 1:24 PM 
To: 
(USAFLS); 
(USAFLS) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.FIa.) 
I really don't think we can do what Cassell asks, to stand by and do nothing. 
Can I represent that as 
our office's position? 
From: 
(USAFLS) 
Sent: Monda , February 28, 2011 1:21 PM 
To: 
(USAFLS); 
(USAFLS) 
Subject: FW: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
I'm going to call in but really only to listen. Thanks. 
From: 
(USAEO) 
Sent: Monda , February 28, 2011 1:12 PM 
To: 
(USAEO); 
. (SMO); 
(USAFLS
Cc: 
(USAFLS); 
. (USAFLS) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.FIa.) 
. (USAFLS); 
EFTA00206312