EFTA01099834

07/09/2008 15:15 FAX 
USAO 5VPB CONFitif 
U1029 
• 
• 
DOI OD° ODOI 
r.OD/Or 
if you have additional questions which Involve this matter, please contact the office listed above. When 
you call. please provide the fife number bated at the top of this letter. Please remember, your participation 
in the notification part of this program is voluntary. In order to continue to receive notifications. ft is your 
responsibility lo keep your contact Information currant. 
Sincerely, 
Victim Specialist 
EFTA01099854

07/09/2008 15:15 FAX 
USA° ITPB CONFRM 
2)030 
May 30, 2008 
Uer 
• 
U.S. DepartmeM of Justice 
Federal Bureau of Investigation 
FBI • West Palm Beach 
Suite 500 
505 South Fleeter Drive 
West Palm Beech, FL 33401 
Your name was referred to the Fars Victim Assistance Program as being a possible victim of a federal 
crime. We appreciate your assistance and cooperation while we are Investigating this case. We would like to 
make you aware of the victim services that may be available fo you and to answer any questions you may have 
regarding the criminal justice process throughout the investigation. Our program its part of the FBI's effort to 
ensure the victims are treated with respect and are provided information about their rights under federal law. 
These rights Include nofification of the status of the case. The enclosed. brochures provide Information about 
the FBI's Victim Assistance Program, resources and instructions for accessing the Victim Notification System 
(VNS). VNS Is designed to provide you with information regarding the status of your case. 
This case Is currently under Investigation. This can be a lengthy process and we request your 
continued patience while we conduct a thorough investigation. 
As a crime victim, you have the following rights under 18 United States Code § 3771: (1) The right to 
be reasonably protected from the accused: (2) The right to reasdnable, accurate, and (finely notice of any 
public court proceeding, or any parole proceeding, involving the crime or of any release or escape of the 
accused: (3) The right not to be excluded from any such public =Hi proceeding, unless the court, after 
receiving clear and convincing evidence, determines that testimony by the victim would be materially altered it 
the victim heard other testimony at that proceeding; (4) The right to be reasonably heard et any public 
proceeding in the district court Involving release, plea. sentencing, or any parole proceoging; (5) The 
reasonable right to confer with the attorney for the Government in the case; (6) The right to full and timely 
restitution es provided in law; (7) The right to proceedings free from unreasonable delay; (8) The right to be 
treated with faness end with respect for the victim's dignity and privacy. 
We will make our best efforts to ensure you are accorded the rights described. Most of these rights 
pertain to events occuning after the arrest or indicbnent of an individual for the crime. and it will become the 
responsibility of the prosecuting United States Atbmey's Office to ensure you are accorded those rights. You 
may also seek the advice of a private attorney with respect to these rights. 
The Victim Notification System (VNS) Is designed to provide you with direct information regarding the 
case as ii proceeds through the criminal justice system. You may obtain current information about this 
r 
on the Internet at VVWW.No 
nter 
In add' n, y um y use e 
en et or n erne 
up eta your contact information and/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 
following Victim Identification Number 
' end 
nytime you contact the Can Center an 
e 
t t me you log on to 
. 
. 
n. 
I's 
e you access the VNS Internet site, you will be prom 
d 
er 
your Last name (or Dueness nome) as currently contained in VNS. The name you should enter I 
-se 
EFTA01099855

07/09/2008 15:15 
FAS.. 
IISAO WPB CONERV 
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• 
moo• nav ooa♦ 
r.nrior 
II you have additional questions which Involve this matter, please contact the office Ested above. When 
you call, please provide the flee number located at the top of this letter. Please rernember, your participation 
in the notification part of this program Is voluntary. In order to continue to receive notifications. It is your 
responsibility to keep your contact information current. 
Sincerely, 
Victim Specialist 
TOfl. P.07 
EFTA01099856

It 032 
Mil 
 
07/09/2008 15:15 FAX 
USA0 WPB CORERS
U.S. Department of Justice 
• 
• 
United States Attorney 
Southern District of Florida 
500 South Australian Ave.. Suite 400 
West Palm 
VIA FACSIMILE 
Brad Edwards, Esq. 
The Law Offices of Brad Edwards & Associates, LLC 
July 9, 2008 
Re: 
aTIO 
OF 
MENT/rEED VICTIM 
Dear Mr. Edwards: 
By victue of this letter, the United States Anomeyts Office for the Southern District 
of Florida asks that yea provide the following notice to your client, 
On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea 
of guilty to violations afFleriela Statutes Sections 796.07 (felony solicitation of prostitution) 
and 796.03 (procurement of alifiQrS to engage in Prnsti10 04 ift the 15-th Judicial Circuit in 
and for Rahn:' literlich • Ootinty Tose Dios, 20Q6-c 0044444XXXIsa and 2002-cf-
0093a IA,TX40)00divat *eaten* tri a ten of tIbigi+iiiiiati$' 4Sp4ositaeat to be 
foltavved by wit *W1114031 sPtinOttlits' irn t8otiiatt4t, fOstwect by itiEebt Months of 
Community Control 1, with conditions of community contitalnent irriposed by the Court. 
In light of the entry of the guilty plea and sentence, the United. States has agreed to 
defer federal prosecution in €avor of this state plea and sentence, subject to certain 
conditions. • 
One such condition to which Epstein has agreed is the following: 
"Any person; who while a minor, was a victim ot a violation of an offense 
enumerated in Title 18, United States Code, Seetion 2215, Vein have the. same 
rights to proceed under Section 2255 as she would have had; if Mr. Epstein 
EFTA01099857

07/09/2008 15:16 FAX 
USAO WPB CONFRM 
QtO33 
• 
BRAD EDWARDS, ESQ. 
NOTIFICATION OF IDENTIFIED VIC 
JULY 9, 2008 
PAGE 2 OF 2 
had been tried federally and convicted of an enumerated offense. For purposes 
of implementing this paragraph, the United States shall provide Mr. Epstein's 
attorneys with a list of individuals whom it was prepared to name in an 
Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial 
authority interpreting this provision, including any authority determining 
which evidentiary burdens if any a plaintiff must meet, shall consider that his 
the intent of the parties to place these identified victims in the same.position 
as they would have been had Mr. Epstein been convicted at trial. No more; no 
less." 
Through this letter, this Office hereby provides Notice that your clien 
is an individual whom the United States was prepared to name as a victim of an enumerated 
offense. 
i 
-. • Ai 
%souk! Your client decide to ilk a •claim against Jeffrey Epstein, his attorney, Jack 
Goldberger, asks that you contact him at Atterbury Goldbert er and Weiss 
Please understand that neither the U:S: Attorney's Office nor the Federal Bureau of 
Itrutatigitliou can take part in or othenvise assitt in civil litigation; However, if yonder 5Ie a 
claim under 18 U.S.C. § 2255 and Mi. Speck) denies that your client is a victim Of an 
enumerated offense, please provide notice of that denial to the undersigned. 
Please thankyour client for glebes assistance 
laidtegtratati4thatirtiglt Kyr* *010€0. 
.410,4# rald virelitbeing SIMON 
cc: 
Jack Goldberger, Esq. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
EFTA01099858

USAO WPB CONFAB 
a 034 
07/09/2008 15:16 FA 
b t 
U.S. Department of Justice 
• 
United States Attorney 
Southern District of Florida 
500 South Australian Ave.. Suite 400 
•
 
July 9, 2008 
VIA FACSIMILE 
Brad Edwards, Esq. 
The Law Offices of Brad Edwards & Associates, LLC 
Re: 
IDENTIFIER virotyk 
Dear Mr. Edwards:.
By Virtue of this Lena, thegnited.III*AMtorney's Office for e o 
Tic! 
of Florida nits thitynn provide the iilhaWingdittiee to your elieht 
On June 30, 2008, Jeffrey Epstein (hereinafter referred toss "Epstein) entged aplea 
of guilty to violations of Florida Statutes Sections 796.07 (klony solicitation of prostitution) 
and 796.03:(procuranent of minerstatinsage in Presthittiort);lin the 15tit Judicial Grafi! in 
and for Pratt Beath County k(44re Has. 2006-cf-0094,4AXXXIca and 2000ref-
ogottiax9emn) aod.was septeMorto-A.Ospt twel*vostigT impoioroitig. to lie 
4044tied, by ilkvig0404Fig 314'W 
traill**tra,k :Oteimi* 
*tht .***IL et 
Connhunity:C'ont€ol 
With contddenti 
confinement imposed* thi§ourt. 
In light of the entry of the guilty plea and sentence, the United States ties agreed to 
defer federal prosecution in favor of this state. plea and sentence, subject to certain 
.conditions. 
One such condition to whichtpstehtItanagreed is the lot/owing; 
"Any person, who while a Minor, was a-victim of a violation_ cif an offense 
enumerated in Title 18, United-410er Code,* Section 2255, will have thee same 
rights to proceed under Section 2255 as she would haye had, if Mr. Epstein 
EFTA01099859

07/09/2008 15:16 FAX 5618059846 
USAO WPB CONFRM 
Q035 
• 
• 
BRAD EDWARD$, ESQ. 
NOTIFICATION OF IDENTIFIED VICTIM 
JULY 9, 2008 
PAGE 2 OF 2 
had been tried federally and convicted of an enumerated offense. For purposes 
of implementing this paragraph, the United States shall provide Mr. Epstein's 
attorneys with a list of individuals whom it was prepared to name in an 
Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial 
authority interpreting this provision, including any authority determining 
which evidentiary burdens if any aplaintiff must meet, shall consider that it is 
the intent of the parties to place these identified victims in the same position 
as they would have been had Mr. Epstein been convicted at trial. No more; no 
loss." 
Through this letter, this Office hereby provides Notice that your client, 
is an individual whom the United States was prepared to name as a victim of an 
enumerated offense. 
Should your eftent decide in frig a claim against Jeffrey Epstein, his attorney, lack 
Goldberger; ash& that you contact idyl at Aiterbury Goldberger and Weiss, 
Mate underatand that neither the U.S. Attorney's Offite not the Federal Bureau of 
hvvcstigattiort can take port in or otherwise assist in civil litigation; however, if you do file a 
claim under it U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an 
enumerated offense, please provide notice of that denial to the undersigned. 
Please thank y.pus client ler *of her assistance durin the course of this examination 
.antitiMmatistttehaatatirtre.tardstOf, 
Aid 
far 
gut 104, 
Stt*ittt 
B 
cc: 
Jack Goldberger, Esq. 
It ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
ASSISTANT U.S. ATTORNEY 
EFTA01099860

March 20, 2011 
To whom it may concern: 
I served as U.S. Attorney for the Southern District of Florida from 2005 through 2009. Over the 
past weeks, I have read much regarding Mr. Jeffrey Epstein. Some appears true, some appears 
distorted. I thought it appropriate to provide some background, with two caveats. (0 under 
Justice Department guidelines, I cannot discuss privileged internal communications among 
Department attorneys and (ii) I no longer have access to the original documents, and as the 
matter is now nearly 4 years old, the precision of memory is reduced 
The Epstein matter was originally presented to the Palm Beach County State Attorney. Palm 
Beach Police alleged that Epstein unlawfully hued underage high-school females to provide him 
sexually lewd and erotic massages. Police sought felony charges that would have resulted in a 
term of imprisonment. According to press reports, however, in 2006 the State Attorney, in part 
due to concerns regarding the quality of the evidence, agreed to charge Epstein only with one 
count of aggravated assault with no intent to conunit a felony. That charge would have resulted 
in r.o jail time, no requirement to register as a sexual offender and no restiaMon for the underage 
victims. 
Local police were dissatisfied with the State Attorney's conclusions, and requested a federa: 
investigation Federal authorities received the State's evidence and engaged in addibonal 
investigation. Prosecutors weighed the quality of the evidence and the likelihood for success at 
trial. With a federal case, there were two additional considerations. First, a federal criminal 
prosecution requires that the crime be more than local; it must have an interstate nexus. Second, 
as the matter was initially charged by the state, the federal responsibility is, to some extent, to 
back-stop state authorities to ensure that there is no miscarriage of justice, and not to also 
prosecute federally that which has already been charged at the state level. 
After considering the quality of the evidence and the additional considerations, prosecutors 
concluded that the state charge was insufficient. In early summer 2007, the prosecutors and 
agents in this case met with Mr. Epstein's attorney, Roy Black. Mr. Black is perhaps best known 
for his successful defense of William Kennedy Smith. The prosecutors presented Epstein a 
choice: plead to more serious state felony charges (that would result m 2 years' imprisonment, 
registration as a sexual offender, and restitution for the victims) or else prepare for a federal 
felony trial. 
What followed was a year-long assault on the prosecution and the prosecutors. I use the word 
assault intentionally, as the defense in this case was more aggressive than any which I, or the 
prosecutors in my office, bad previously encountered. Mx. Epstein hired an army of legal 
superstars: Harvard Professor Alan Dershowitz, former Judge and then Pepperdine Law Dean 
Kenneth Starr, former Deputy Assistant to the President and then Kirkland & Ellis Partner Jay 
Letkowitz, and several others, including prosecutors who had formally worked in the U.S. 
EFTA01099861

Attorney's Office and in the Child Exploitation and Obscenity Section of the Justice Department. 
Defense attorneys next requested a meeting with me to challenge the prosecution and the terms 
previously presented by the prosecutors in their meeting with Mr. Black. The prosecution team 
and i met with defense counsel in Fall 2007, and I reaffirmed the office's position: two years, 
registration and restitution, or trial. 
Over the next several months, the defense team presented argument after argument claiming that 
felony criminal proceedings against Epstein were unsupponed by the evidence and lacked a basis 
in law, and that the office's insistence on jail-time was motivated by a zeal to overcharge a man 
merely because he is wealthy. They bolstered their arguments with legal opinions from well-
known legal experts. One member of the defense team warned me that the office's excess zeal in 
Coming a good man to serve time in jail might be the subject of a book if we continued to 
proceed with this matter. My office systematically considered and rejected each argument, and 
when we did, my office's decisions were appealed to Washington. As to the warning, I ignored 
it. 
The defense strategy was not limited to legal issues. Defense counsel investigated individual 
prosecutors and their families, looking for personal peccadilloes that may provide a basis for 
disqualification. Disqualifying a prosecutor is an effective (though rarely used) strategy, as 
eliminating the individuals most familiar with the facts and thus most qualified to take a case to 
trial banns likelihood for success. Defense counsel tried to disqualify at least two prosecutors. I 
carefully reviewed, and then rejected, these arguments. 
Despite this army of attorneys, the office held arm to the terms first presented to Mr. Black in 
the original meeting. On June 30, 2008, after yet another last =mite appeal to Washington D.C. 
was rejected, Epstein pled guilty in state court. He was to serve 18 months imprisonment, 
register as a sexual offender for life and provide restitution to the victims. 
Some may feel that the prosecution should have been tougher. Evidence that has come to light 
since 2007 may encourage that view. Many victims have since spoken out, tiling detailed 
statements in civil eases seeking damages. Physical evidence has since been discovered. Had 
these additional statements and evidence been known, the outcome may bave been different But 
they were not known to us at the time. 
A prosecution decision must be based on admissible facts known at the time. In cases of this 
type, those are unusually difficult because victims are frightened and often decline to testify or if 
they do speak, they give contradictory statements. Our judgment in this case, based on the 
evidence blown at the time, was that it was better to have a billionaire serve time in jail, register 
as a sex offender and pay his victims restitution than risk a trial with a reduced likelihood of 
success. I supported that judgment then, and based on the state of the law as it then stood and the 
evidence known at that time, I would support that judgment again. 
Epstein's treatment, while in state custody, likewise may encourage the view that the office 
should have been tougher. Epstein appears to have received highly unusual treatment while in 
jail. Although the terms of confinement in a state prison arc a matter appropriately left to the 
EFTA01099862

State of Florida, and not federal authorities, without doubt, the treatment that he received while 
in state custody undermined the purpose of a jail sentence 
Some may also believe that the prosecution should have been tougher in retaliation for the 
defense's tactics. The defense, arguably, often failed to negotiate in good faith. They would 
obtain concessions as pan of a negotiation and agree to proceed, only to change their minds, and 
appeal the office's position to Washington. The investigations into the family lives of individual 
prosecutors were, in my opinion, uncalled for, as were the accusations of bias and / or 
misconduct against individual prosecutors. At times, some prosecutors felt that we should just 
go to trial, and at times i felt that frustration myself. What was right in the first meeting, 
however, remained right inespective of deft. nse tactics. Individuals have a constitutional right to 
a defense. The aggressive exercise of that right should not be punished, nor should a defense 
counsel's exercise of their right to appeal a U.S. Attorney to Washington, D.C. Prosecutors must 
be careful not to allow frustration and anger with defense counsel to influence their judgment. 
After the plea, I recall receiving several phone calls. One was from the FBI Special Agent-in-
Charge. He called to offer congratulations He had been at many of the meetings regarding this 
case. He was aware of the tactics of the defense, and he called to praise our prosecutors for 
holding firm against the tikes of Messrs. Black, Dershowitz, Lefkowitz and Stan. It was a proud 
moment. I also received calls or communications from Messrs. Dershowitz, Lefkowitz and 
Starr. I had known all three individuals previously, from my time in law school and at Kirkland 
& Ellis in the mid 90s. They all sought to make peace. i agreed to talk and meet with each of 
them after Epstein pled guilty, as I think it important that prosecutors battle defense attorneys in 
a case and then move on. I have tried, yet i confess that has been difficult to do (tally in this case. 
The bottom line is this: Mr. Jeffrey Epstein, a billionaire, served time in jail and is now a 
registered sex offender. He has been required to pay his victims restitution, though restitution 
clearly cannot compensate for the crime. And we know much more today about his crimes 
because the victims have come forward to speak out. Some may disagree with the prosecutorial 
judgments made in this case, but those individuals arc not the ones who at the time reviewed the 
evidence available for trial and assessed the likelihood of success. 
Respectfully, 
R. Alexander Acosta 
Former U.S. Attorney 
Sothern District of Florida 
EFTA01099863

EFTA01099864

U
, THE UNIVERSITY OF UTAH 
S.J. QUINNEY 
COLLEGE OF LAW 
-Wifredo A. Ferrer 
United States Attorney 
Southern District of Florida 
PAUL G. CASSELL 
Ronald N. Boyce Presidential Professor of Criminal Law 
Tele hone: 
December 10, 2010 
Re: 
Request for Investigation of Jeffrey Epstein Prosecution 
Dear Mr. Ferrer: 
I am writing as someone with extensive experience in the federal criminal justice system 
— as a former Associate Deputy Attorney General, Assistant United States Attorney, federal 
judge, and currently criminal law professor —to alert you to what seems to be the most 
suspicious criminal case I have ever encountered. I ask that you investigate whether there were 
improper influences and actions during your office's criminal investigation of Jeffrey Epstein, 
particularly regarding the decision to enter into a binding non-prosecution agreement blocking 
his prosecution for numerous federal sex offenses he committed over many years against more 
than thirty minor girls. 
As I am sure you are well aware, in 2006 your office opened a criminal investigation with 
the FBI into allegations that for years Jeffrey Epstein sexual abused dozens of minor girls in his 
West Palm Beach mansion. The FBI soon developed compelling evidence that Epstein had in 
fact committed numerous federal sex offenses with more than 30 minor girls. And yet, your 
office ultimately entered into a plea arrangement which allowed Epstein escape with a non-
prosecution agreement that ensured he would have no federal criminal liability and would 
spend no more than 18 months in state jail. For sexual offenses of this magnitude — in a case 
with more than 30 witnesses providing interlocking testimony, all made automatically 
admissible by virtue of Fed. R. Evid. 414 —this is an extraordinary outcome. 
Why did your office enter into this highly unusual non-prosecution arrangement with 
Epstein? Suspicion begins with the point that Epstein is a politically-connected billionaire. But 
that wouldn't be troubling without considerable other evidence that something went terribly 
wrong with the prosecution for other, improper reasons. Consider the following highly unusual 
facts: 
First, it appears that Epstein was tipped off before the execution of a search warrant at 
his home. We know that lead state police officers --and 
Police Chief a 
al
l- complained that the house was "sanitized" by the time they arrived to serve a search 
warrant for child pornography. This sanitation was evident by the various computer wires 
hanging with no computers attached. Housekeeper Janusz Banasiak later testified In a civil 
EFTA01099865

deposition that Epstein's assistant, end 
another man (unknown) were 
instructed to remove, and did in fact remove, multiple computers from Epstein's home shortly 
before the search warrant was served. The fact that there could well have been a tip off is 
apparently suspected by federal authorities. 
Second, there is evidence that one of the senior prosecutors in your office joined 
Epstein's payroll shortly after important decisions were made limiting Epstein's criminal liability 
— and im ro erl re resented people close to Epstein. During the federal investigation of 
Epstein, 
vas a senior Assistant U.S. Attorney in your office. As we understand 
things, he was a direct supervisor of the line prosecutor handling the case and thus was well 
aware of details of the Epstein investigation and plea negotiations. We further believe that he 
was consulted on issues related to the prosecution of Epstein and Epstein's co-conspirators, 
including specifically issues related to whether Epstein employees and pilots should be 
prosecuted for their involvement in Epstein's sexual offense. We further believe that he 
personally and substantially participated in making such decisions about the course of the 
criminal investigation. 
Within months after the non-prosecution agreement was signed by your offic'
left your office and immediately went into private practice as a white collar criminal defense 
attorney. His office coincidentally happened to be not only in the same building (and on same 
floor) as Epstein's lead criminal defense counsel, Jack Goldberger, but it was actually located 
right next door to the Florida Science Foundation -- an Epstein-owned and -run company where 
Epstein spent his "work release." 
While working in this office adjacent to Epstein's 
undertook the representation 
of numerous Epstein employees and pilots during the civil cases filed against Epstein by the 
victims — cases that involved the exact same crimes and exact same evidence being reviewed by 
the U.S. Attorney's office when he was employed there. Specifically, he represented 
(Epstein's number one co-conspirator who was actually named as such in the N PA , is 
), his pilots Larry Morrison, Larry Visoski, David Rogers, William 
Hammond and Robert Roxburgh. (Hammond and Roxburgh were not deposed but the others 
were.) Our understanding is that his representation of these individuals was paid for, directly 
or indirectly, by Epstein. 
was well aware of what evidence your office and federal investigator had 
collected against Epstein and about the minor girls who were his victims. As a consequence, he 
knew what evidence the attorneys for the victims were using. He also knew what each of those 
witnesses had said, if anything, to federal and state investigators during the criminal 
investigation. 
We have been unable to place our fingers on the federal regulations governing such later 
representation. We do know, however, that such actions appear to be in direct contravention 
of the Florida ethical rules regarding attorneys who leave government employment. For 
2 
EFTA01099866

example, Florida R. Prof. Conduct 4-1.11(a) provides "la] lawyer shall not represent a private 
client in connection with a matter in which the lawyer participated personally and substantially 
as a public officer or employee unless the appropriate government agency consents after 
consultation." Similarly, Florida R. Prof. Conduct 4-1.11(b) provides that "(al lawyer having 
information that the lawyer knows is confidential government information about a person 
acquired when the lawyer was a public officer or employee may not represent a private client 
whose interests are adverse to that person in a matter in which the information could be used 
to the material disadvantage of that person." Both these rules appear to have been violated. 
But entirely apart from the details of ethical rules, the fact that one of your prosecutors was 
involved in making important decisions about the scope of criminal liability for Epstein and his 
associates and then — after criminal liability was significantly limited— representing numerous 
people at Epstein's behalf raises serious questions. At the very least, there is the strong 
appearance that 
may have attempted to curry favor with Epstein and then reap his 
reward through favors le employment. At the very worst, there may have been advance 
discussions — we simply don't know at this point. 
Third, Epstein appears to have deliberately kept from victims in the case correspondence 
with your office and the Justice Department that might have shed light on improper influences. 
Along with other capable attorneys, I was involved in representing one of Epstein's victims 
a 
who filed a federal civil case against Epstein. Suspecting that Epstein may have 
improperly influenced your office, we immediately served discovery requests on Epstein for all 
the correspondence with your office regarding the plea negotiations. Eleven months of hard 
litigation ensued, in which Epstein made every conceivable argument against production. 
Finally, late in June of this year, his appeals exhausted, Epstein produced the correspondence to 
us. However, in violation of the court order, he redacted the correspondence so that he 
provided only emails and other statements from your office — not his emails and statements to 
your office. More significantly, even though he was under court order to produce all 
correspondence between his attorneys and your office, Epstein secretly withheld 
• correspondence by several of his most hi h-powered attorneys — namely Ken Starr and Lilly Ann 
Sanchez. Epstein settled the case withElwithin days after this limited production, and we did 
not realize the absence of what must have been critical discussions between your office and 
Starr and Snachez (among others). Epstein's refusal to allow us to see that information raises 
the suspicion in our minds that there must have been unusual pressures being brought to bear 
during the plea discussions that would have been revealed had Epstein complied with his 
production obligations. 
Fourth, there appears to have been an unprecedented level of secrecy between your 
office and the Federal Bureau of Investigation during this case. The FBI was responsible, along 
with state and local police agencies, for building the case against Epstein. They appear to have 
developed an overwhelming criminal against him. And yet, when your office signed the non-
prosecution agreement with him, it is not clear to us that the FBI was consulted about this 
decision. Indeed, we have suspicions that the FBI was not informed of this decision until, 
perhaps, months later. 
3 
EFTA01099867

Supporting this suspicion is our on-going litigation regarding the treatment of the victims 
in this case. As you know from our draft pleadings that we have discussed with your office, we 
believe there is compelling evidence that the victims and their attorneys were deceived about 
the existence of a non-prosecution agreement for months in order to avoid what certainly 
would have been a firestorm of controversy about such lenient treatment of a repeat sex 
offender. Our impression from the evidence we have been able to obtain so far is that the FBI 
was similarly kept in the dark — not consulted about or even told about the NPA. While a 
certain amount of tension has always existed between federal prosecuting and investigating 
agencies, not even informing the FBI about the Epstein NPA seems highly unusual. 
All of these strange facts — as well as the facts that we are alleging in our crime victims' 
litigation — lead us to think that there was something rotten with the way this case was 
handled. Epstein could have faced years and years in prison for numerous federal sex offenses. 
And yet he managed to contrive to walk away with no federal time at all (and only minimal 
state time). We respectfully ask you to investigate through appropriate and independent 
channels the handling of the Epstein (non)prosecution. 
Thank you in advance for considering this request. I would be happy to provide any 
other additional information that would be useful to you. 
4 
EFTA01099868

Qui Tam 
Class Action 
Personal Injury 
Wrongful Death 
Commercial Litigation 
PATHTOJUSTICE.00M 
Farmer, Jaffe, Weissing, 
Edwards, Fistos Et Lehrman, P.L. 
March 22, 2011 
Assistant United States 
Southern District of Florida 
Re: 
Rule 26(a)(I) Disclosures in Jane Doe #1 and Jane Doe #2 vs. United States. No. 
09-80736 
Dear 
As you know, in the past you have asserted that the federal rules regarding civil cases 
cover Jane Doe #1 and Jane Doe #2's petition for relief under the Crime Victims' Rights Act. 
If you are correct that the civil rules apply, then both sides of the case are obligated to make 
voluntary initial disclosures under Rule 26(a)(1). We are writing to make our initial disclosures 
and ask you to promptly do the same. 
INDIVIDUALS LIKELY TO HAVE DISCOVERABLE 
INFORMATION 
B
e Epstein, 
Prosecutors in the U.S. Attorne s Office who have handled the 
Epstein case, including 
■ 
and Alex Acosta. 
EFTA01099869

Rule 26(a)(1) Disclosures in Jane Doe #1 and Jane Doe #2 vs. United States—No. 09-80736 
FBI agents who have handled this case. 
All attorneys and investigators involved in the Office of 
Professional Responsibility investigation related to this case. 
L. Dennison Reed Ps .D., 
p 
Larry Visoski, 
: 
• . . C/' •
 
Ti"' 
Y WILL 
• s 
I 
Alfredo Rodriguez, 
C/O Federal Public defender or Bureau of Prisons 
R.
t 
Palm Beach Police 
 
eac 
'once, 
r
a
'am
Records Custodian of Palm Beach Police, 
• 
. PODHURST 
OXISISIAll A, 
I 
I 
do Adam Horowitz, Mermelstein & 
iiiilin, 
Antonio I i ueroa 
do Robert Josefsberg, Esq., PODHURST 
FLAGLER STREET, STE 800, MIAMI, 
ORSECK, PA, 25 W 
FL 33131 
do Spencer Kuvin, LEOPOLD KUVIN, PA, 
200, PBG FL 33410 
2925 PGA BLVD STE 
do Jack Scarol. SEARCY DENNEY, ET 
2 
EFTA01099870

Rule 26(0(11 Disclosures in Jane Doe #1 and Jane Doe #2 vs. United States. No. 09-80736 
Carol 
Morton Case 
I
 
Courtne Lan:le 
Jane Doe #1 (C.W.), do Bradley Edwards, Es ., FARMER, 
JAFFE, WEISSING, ET AL., 
eor: a 
do Adam Horowitz, Mermelstein & Horowitz, 
P.A. 
I 
. 
• SI 
rt 
Joscfsber
' 
I 
' ST • ' SECK, • A,
t 
t 
1 .mill4-).
. 44 -4iNtalka, . PODHURST 
ORSECK, PA, 
do Robert Josefsberg, E .., PODHURST 
ORSECK PA, 
I 
I 
• 
• • 
J.sefs.
I 
.
6 0 
• 
• 
do Adam Horowit Mermelstein & Horowi 
o •o rt oses 
g, 
• ., 
DHURST 
ORSECK, PA, 25 W FLAGLER STREET, STE 800, MIAMI, 
FL 33131 
, do Robert Josefsberg, Esq., PODHURST 
• •f. 
A, 25 W FLAGLER STREET, STE 800, MIAMI, 
FL 33131 
do Adam Horowitz, Mermelstein & Horowitz, 
P. • . 1 
05 Thsca e Boulevard, Suite 2218 Miami, FL 33160 
do Robert Josefsberg, Esq., PODHURST 
K, PA, 25 W FLAGLER STREET, STE 800, MIAMI, 
FL 33131 
do Robert Josefsberg, Esq., PODHURST 
") :Li al 
A, 
3 
EFTA01099871

Rule 26(4(1) Disclosures in Jane Doe #1 and Jane Doe #2 vs. United States. No. 09-8073 
do Robert Josefsbe , E . PODHURST 
ORSECK, PA, 
, c/o Bradley Edwards 
FARME 
JAFFE 
WEISSING , ET AL 
Jane Doe #2 (T.M.), do Bradley Edwards, FARMER, JAFFE, 
WEISSING, ET AL., 
do Adam Horowitz, Mennelstein & Horowitz, 
P.A., 
do Adam Horowitz, Mermelstein & 
• 
9 
do Robert Josefsberg, 
. , PODHURST 
ORSECK PA, 
c/o Adam Horowitz, Mermelstein & Horowi 
P.A., 
do Isidro M. Garcia, Garcia Law Finn, P.A. 
Mark Epstein 
Ghislaine Maxwell, do Brett Jaffe Cohen & Gresser, LLP, 
Justin Vanove 
Alfredo Rodriguez, 
C/O Federal Public defender or Bureau of Prisons 
Leslie Wexner, 
Jean Luc Brunel 
Jennie Saunders 
4 
EFTA01099872

Rule 26(a)(1) Disclosures in Jane Doe #1 and Jane Doe #2 vs. United States, No. 09-80736 
David C Deerfield David Seth Kokin), 
H:
I
Beller 
Janusz Banasiak, 
Beata Banasiak, 
Juan Alessi 
Lawrence Krauss 
Mortimer Zuckerman 
I
Vadwon Cotrin 
Patrick former housekee . - r 
I
 
former housekee ier 
I 
S/A Witness #160 
I 
S/A Witness #152 
I
 
I
 
unknown South Africa 
Ronald Baron 
Glenn Dubin, 
S/A Witness /1149 
I
 
Sand Ber:er 
Officer 
Palm Beach Police, 
Officer 
Palm Beach Police, 
5 
EFTA01099873