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the non-prosecution agreement only after Epstein had entered his guilty pleas in state court — in 
other words, only after the time for the victims to be able to object to the non-prosecution 
agreement during the plea process had come and gone. Even at that time, the Office did not 
disclose the provisions in the agreement. In short, the victims never learned about the non-
prosecution agreement barring federal prosecution of their cases because of a deliberate 
decisions by the U.S. Attorney's Office, not mere "negligence or inaction." McCorkle, 321 F.3d 
at 1297. Accordingly, the Government is stopped from arguing that the Crime Victims' RightS 
Act does not apply to this case. 
II. 
THE COURT SHOULD FIND THAT THE VICTIMS' RIGHTS HAVE BEEN 
VIOLATED AND THEN SET UP A BRIEFING SCHEDULE AND HEARING ON 
THE APPROPRIATE REMEDY. 
This U.S. Attorney's Office's behavior in this case does not satisfy the Office's 
obligations under the CVRA to use its "best efforts" to insure that victims receive protection of 
their rights. 18 U.S.C. § 3771(c)(1). In particular, the undeniable chain of events makes clear 
that the victims were not afforded their right "to confer with the attorney for the Government in 
the case." 18 U.S.C. § 3771(a)(5). Whatever else may be said about the deception, it also 
starkly violates the victims' right "to be treated with fairness and with respect for the victim's 
dignity . . ." 18 U.S.C. § 3771(a)(8). The pattern also denied the victims of timely notice of 
court proceedings, 18 U.S.C. § 3771(a)(3), including in particular the state court guilty plea. 
As we understand the position of the Government, it does not truly contest that — if the 
CVRA applied — it managed to discharge its various obligations under the Act. Instead, the 
Government relics solely on a technical argument to reach the conclusion that it discharged its 
obligations — namely, the argument that the CVRA does not apply until a formal indictment is 
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filed. As just explained, however, that technical argument must be rejected as inconsistent with 
the CVRA's plain language and interpretation by other courts. Accordingly, this Court should 
find that the Government has violated its CVRA obligations. 
Once the Court finds such a violation, the next issue becomes what remedy should apply. 
Since the earliest days of our nation, it has been settled law that "where there is a legal right, 
there is also a legal remedy . . . .." Marbury.v. Madison, 5 U.S. 137, 163 (1803) (internal 
quotation omitted). Moreover, "[i]f the right is created by a federal statute, the federal courts 
have the power to fashion an appropriate remedy." Intracoastal Transp., Inc.' Decatur County, 
Georgia 482 F.2d 361, 371 (5th Cir. 1973). As we understand the Government's position in this 
case, however, they believe that this Court is powerless to do anything to correct the palpable 
violation of victims' rights documented in this case. 
Jane Doe #1 and Jane Doe #2 respectfully request that the Court set up a briefing 
schedule and a hearing on this important issue. The victims believe that they can establish that 
the appropriate remedy for the clear violations of their rights is to invalidate the Non-Prosecution 
Agreement. While the victims request an opportunity to provide more extensive briefing on this 
subject, they provide a few citations in support of their position here. 
When other plea arrangements have been negotiated in violation of federal law, they have 
been stricken by the courts. For example, United Stalest Walker, 98 F.3d 944 (7th Cir. 1996), 
held that where a sentence on a new crime could not run concurrently with a probation 
revocation the defendant was then serving — contrary to the assumption of the parties to the plea 
agreement — the defendant was not entitled to specific performance of the plea agreement. The 
Court explained that the case was one "in which the bargain is vitiated by illegality . ..." Id. at 
37 
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947. Here, of course, exactly the same is true: the non-prosecution agreement is vitiated by 
illegality — namely, the fact that it was negotiated in violation of the victims' rights. Other cases 
reach similar conclusions. See, e.g., United Statest Cooper, 70 F.3d 563, 567 (101h Cir. 1995) 
(prosecutor agreed to recommend probation, but it later appeared that would be an illegal 
sentence in this case, and thus only adequate remedy is to allow defendant to withdraw plea); 
Craig.). People, 986 P.2d 951, 959-60 (Colo. 1999) (because "neither the prosecutor nor the trial 
court have authority to modify or waive the mandatory parole period," such "is not a permissible 
subject of plea negotiations," and thus, even if "the trial court erroneously approves of such an 
illegal bargain" such plea is "invalid" and thus will not be specifically enforced). Nor can the 
defendant claim some right to specific performance of an illegal non-prosecution agreement. See 
State.). Garcia, 582 N.W.2d 879, 881-82 (Minn. 1998) (plea agreement for 81 months sentence, 
but court added 10-year conditional release term because, under facts of case, sentence without 
such release term "plainly illegal," and thus remedy of specific performance not available); State 
•. Wall, 348 N.C. 671, 502 S.E.2d 585, 588 (1998) (plea agreement was for sentence to be 
concurrent with one not yet completed, but state statute mandates consecutive sentence on facts 
of this case; "defendant is not entitled to specific performance in this case because such action 
would violate the laws of this state"); Ex parte Rich, 194 S.W.3d 508, 515 (Tex. Crim. App. 
2006); (where "the plea bargain seemed fair on its face when executed, it has become 
unenforceable due to circumstances beyond the control of [the parties], namely the fact that one 
of the enhancement paragraphs was mischaracterized in the indictment, resulting in an illegal 
sentence far outside the statutory range," proper remedy is plea withdrawal, as "there is no way 
of knowing whether the State would have offered a plea bargain within the proper range of 
38 
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punishment that he deemed acceptable"); Stalet Mammal W.Va. 368, 572 S.E.2d 891, 897 
(2002) (where plea agreement was that defendant would plead guilty to 2 felony counts of felon 
in possession of firearm and prosecutor would dismiss remaining 6 counts re other offenses with 
prejudice, and all parties erroneously believed these 2 crimes were felonies, lower court 
"correctly resolved this unfortunate predicament by holding that a plea agreement which cannot 
be fulfilled based upon legal impossibility must be vacated in its entirety, and the parties must be 
placed, as nearly as possible, in the positions they occupied prior to the entry of the plea 
agreement"). 
The Non-Prosecution Agreement that the Government entered into in this case was 
simply illegal. The Government did not protect the congressionally-mandated rights of victims 
before it entered into this Agreement. Perhaps it is for this reason that the Agreement is so 
shockingly lenient — blocking prosecution for dozens and dozens of federal felony sex offenses 
against several dozen minor girls. But regardless of the leniency, the only issue for the Court is 
whether the Agreement was lawful. It was not, and so the Court invalidate it.5 The victims 
respectfully ask for a full briefing schedule and a hearing on this important issue. 
Defendant Jeffrey Epstein was notified about this case long ago, and was notified on 
August 26, 2010, that the victims would be filing correspondence in support of their motions. 
He has not chosen to intervene in this action, and so he should not be heard to complain about 
remedy the Court might impose. 
In any event, there are no double jeopardy barriers to invalidating the plea. As explained 
in a leading criminal procedure treatise: 
The review of defendant's sentence is also provided in federal cases upon 
application of a victim. The Crime Victim's Rights Act allows a victim to seek to 
reopen a sentence through a writ of mandamus, if the victim has asserted and been 
denied the right to be heard at sentencing. Like the prosecution's statutory right 
to appeal, the victim's statutory remedy should pose no double jeopardy 
39 
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. Case Stee-cw-60735-1011a Caanummantt 3162-4BntEmak nal Ei1911 SID daet s ZrY2f0420118a0atfroll42 
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CERTIFICATE OF CONFERENCE 
As recounted above, counsel for Jane Doe #1 and Jane Doe #2 have approached the U.S. 
Attorney's Office for more than two and a half years in an effort to reach stipulated facts, The 
U.S. Attorney's Office ultimately terminated those efforts on March 15, 2011, taking the position 
that the facts of the case are irrelevant and that, on any set of facts, it did not violate the CVRA. 
CONCLUSION 
For all the foregoing reasons, the Court should find the U.S. Attorney's Office violated 
Jane Doe #1 and Jane Doe #2's rights under the Crime Victims Rights Act and then schedule an 
appropriate hearing on the remedy for these violations. The scope of the remedy that is 
appropriate may depend in part of the scope of the violations that the Court finds. For this 
reason, it makes sense for the Court to bifurcate the process and determine, first, the extent of the 
violations and then, second, the remedy appropriate for those violations. If the Court would 
prefer to see more immediate briefing on remedy issues, the victims stand prepared to provide 
that briefing at the Court's direction. 
difficulties if as the [DiFrancesco] Court explained . . . the defendant is 'charged 
with knowledge of the statute and its . . . provisions, and has no expectation of 
finality in his sentence until the [review by writ] is concluded .. ..'" 
LAFAVE ET AL., CRIMINAL Procedure § 26.7(b) (Nov. 2010) (quoting United Slates I. 
DiFrancesco, 449 U.S. 117, 146 (1980)). 
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DATED: March 21.2011 
Respectfully Submitted, 
s/ Bradley J. Edwards 
Bradley J. Edwards 
FARMER, JAFFE, WEISS1NG, 
EDWARDS, FISTOS & LEHRMAN, P.L. 
425 North Andrews Avenue, Suite 2 
Fort Lauderdale, Florida 33301 
Telephone (954) 524-2820 
Facsimile (954) 524-2822 
Florida Bar No.: 542075 
E-mail: [email protected] 
and 
Paul G. Cassell 
Pro Hac Vice 
S.J. Quinney College of Law at the 
University of Utah 
332 S. 1400 E. 
Salt Lake City, UT 84112 
Telephone: 801-585-5202 
Facsimile: 801-585-6833 
E-Mail: cassellnalaw.utah,edu 
Attorneys for Jane Doe #1 and Jane Doe #2 
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CERTIFICATE OF SERVICE 
The foregoing document was served on March 21, 2011, on the following using the Court's 
CMIECF system: 
Assistant U.S. Attorne 
Fax: 
E-mail: ann.marie.c.villafanaQusdoi.aov 
Attorney for the Government 
Joseph L. Ackerman, Jr. 
Joseph Ackerman, Jr. 
Fowler White Burnett PA 
777 S. Flagler Drive, West Tower, Suite 901 
West Palm Beach, FL 33401 
Criminal Defense Counsel for Jeffrey Epstein 
(courtesy copy of pleading via U.S. mail) 
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From: 
Sent: 
To: 
Cc: 
Subject: 
Importance: 
Dear Jack: 
.(USAFLS) 
(USAFLS) 
Nliz•- idW. July Of, 2008 10:53 AM 
rger 
E N. (FBI); 
e rey psein 
High 
Jason R (FBI); Atkinson, Karen (USAFLS) 
Special Agent 
reminded me that I failed to include one of our identified victims. She is still a 
minor, and her initials are 
Please let me know when you are available, and I will provide you with the revised list. I would like to receive 
the signed notification by tomorrow so that I can begin distributing them to the victims. 
Thank you. 
A. Marie Villafafla 
Assisi ant 
696 
08-80736-CV-MARRA 
RFP WPB-001854 
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FILED by  DJ  D.C. 
nacmotaie 
JULY 7, 2008 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
08-80736-Civ-MARRA/JOHNSON 
CASE NO.: 
IN RE: JANE DOE, 
Petitioner. 
STEVEN M. LARIMORE 
CLERK U.S. DIST. CT. 
S•O. OF FLA. • MIAMI 
s.? cry enc y VICTIM'S PETITION FOR ENFORCEMENT OF 
CRIME VICTIM'S RIGHTS ACT, 18 U.S.C. SECTION 3771 
COMES NOW the Petitioner, JANE DOE (hereinafter "Petitioner"), by and through her 
undersigned attorneys, pursuant to the Crime Victim's Rights Act, 18 U.S.C. Section 3771 
("CVRA"), and files this Petition for Enforcement in the above styled action as follows: 
1. 
Petitioner, an adult, as a minor child was a victim of federal crimes committed by 
JEFFREY EPSTEIN (hereinafter "Defendant"). 
These crimes included sex trafficking of 
children by fraud, in violation of 18 U.S.C. § 1591, use of a means of interstate commerce to 
entice a minor to commit prostitution, in violation of 18 U.S.C. § 2422, as well as wire fraud, in 
violation of 18 U.S.C. § 1343. The Defendant committed these crimes within the jurisdiction of 
the Southern District of Florida in Palm Beach County, Florida. 
2. 
Upon information and belief, the Defendant is the subject of a federal criminal 
investigation conducted by the United States of America in the Southern District of Florida. The 
Defendant has recently been prosecuted and pleaded guilty, on June 30, 2008, in the Circuit 
Court for Palm Beach County to various similar state offenses including solicitation of minors 
for prostitution. 
3. 
Upon information and belief, the Defendant is engaged in plea negotiations with 
the Office of the United States Attorney for the Southern District of Florida concerning federal 
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crimes which he is alleged to have committed against minor children, including the Petitioner. 
Such negotiations may likely result in a disposition of the charges in the next several days. 
4. 
Under the CVRA, before any charges are filed against the Defendant, the 
Petitioner has the rights (among others) to notice of her rights under the CVRA, to confer with 
the prosecutors, and to be treated with fairness. As soon as charges are filed, the Petitioner has 
the rights (among others) to timely notice of court proceedings, the right not to be excluded from 
such proceedings, the right to be heard at such public proceedings regarding conditions of 
release, any plea, and any sentence, the right to confer with the attorney for the government, the 
right to restitution, and the right to be treated with fairness and with respect for her dignity and 
privacy. 
5. 
The Petitioner has been denied her rights in that she has received no consultation 
with the attorney for the government regarding the possible disposition of the charges, no notice 
of any public court proceedings, no information regarding her right to restitution, and no notice 
of rights under the CVRA, as required under law. 
6. 
The Petitioner is in jeopardy of losing her rights, as described above, if the 
government is able to negotiate a plea or agreement with the Defendant without her participation 
and knowledge. 
WHEREFORE, for the reasons outlined above, the Petitioner respectfully requests this 
Court to grant her Petition, and to order the United States Attorney to comply with the provisions 
of the CVRA prior to and including any plea or other agreement with the Defendant and any 
attendant proceedings. 
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MEMORANDUM 
I. 
THE CRIME VICTIMS' RIGHTS ACT MAKES CRIME VICTIMS 
INDEPENDENT 
PARTICIPANTS 
THROUGHOUT 
THE 
CRIMINAL JUSTICE PROCESS. 
In October 2004, Congress passed and the President signed into law the Crime Victims' 
Rights Act, Pub. L. No. 108-405, 118 Stat. 2251 (codified at 18 U.S.C. § 3771). Because this 
appears to be the first case involving the Act to come before this Court, a bit of background may 
be in order. 
A. 
The CVRA Gives Crime Victims Rights to Participate in the Criminal Justice 
Process. 
Congress passed the CVRA "to give crime victims enforceable rights to participate in 
federal criminal proceedings." Opinion at 14. Congress was concerned that in the federal system 
crime victims were "treated as non-participants in a critical event in their lives. They were kept 
in the dark by prosecutors too busy to care enough ... and by a court system that simply did not 
have a place for them." 150 CoNG. REC. S4262 (Apr. 22, 2004) (statement of Sen. Feinstein). 
To remedy this problem, Congress gave victims "the simple right to know what is going on, to 
participate in the process where the information that victims and their families can provide may 
be material and relevant ... ." Id. 
The CVRA gives victims of federal crimes a series of rights, including the right to notice 
of court proceedings, to be heard at plea and sentencing hearings, and to reasonably "confer with 
the attorney for the Government in the case." 18 U.S.C. § 3771(a). Victims also have a "right 
of access to the terms of a plea agreement ... ." In re Interested Party 1, 530 F.Supp. 2d 136, 
2008 WL 134233 at *7 (D.D.C. 2008). The CVRA also assures victims broadly that they will 
"be treated with fairness." 18 U.S.C. § 377I(a)(8). 
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Of course, these rights would be of little use to most crime victims unless they were told 
about them. To ensure that victims are notified of their rights, the CVRA directs employees of 
the Justice Department "and other departments and agencies of the United States engaged in the 
detection, investigation, or prosecution of crime" to use their "best efforts to see that crime 
victims are notified of ... the rights described [in the CVRA]." 18 U.S.C. § 3771(c)(1) (emphasis 
added).1 
B. 
The CVRA Gives Victims Rights During the Investigation of a Crime. 
The CVRA gives victims rights during the investigation of a crime. The Fifth Circuit 
recently reached this conclusion, holding: 
The district court acknowledged that "[t]here are clearly rights 
under the CVRA that apply before any prosecution is underway." 
BP Prods., 2008 WL 501321 at *11. 2008 U.S. Dist. LEXIS 12893, 
at *36. Logically, this includes the CVRA's establishment of 
victims' "reasonable right to confer with the attorney for the 
Government." 18 U.S.C. ti 3771(a)(5). At least in the posture of 
this case (and we do not speculate on the applicability to other 
situations), the government should have fashioned a reasonable 
way to inform the victims of the likelihood of criminal charges and 
to ascertain the victims' views on the possible details of a plea 
bargain. 
In re Dean, 527 F.3d 391, 394 (5th Cir. 2008). 
The position that CVRA rights apply before charges have been filed is consistent with the 
Justice Department regulations under the CVRA, which explain that government officials "must 
advise a victim [about their rights under the CVRA] ... at the earliest opportunity at which it may 
be done without interfering with an investigation." A.G. GUIDELINES FOR VICTIM AND WITNESS 
I Further supporting this requirement is another statute, 42 U.S.C. § I0607(cX3), which directs government officials 
to provide victims with "the earliest possible notice of," among other things, "the filing of charges against a 
suspected offender." 
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ASSISTANCE 23 (May 2005). And the plain language of the CVRA undergirds this conclusion, as 
it applies not simply to prosecutors but to government agencies "engaged in the detection [and] 
investigation ... of crime ... ." 18 U.S.C. § 3771(c)(1). Indeed, if there were any doubt, the plain 
language of the CVRA extends victims' right to situations "in which no prosecution is 
underway." 18 U.S.C. § 3771(d)(3). 
II. 
PETITIONER IS A "VICTIM PROTECTED BY THE CVRA. 
Under the CVRA the crime victim is defined as "a person directly and proximately 
harmed as a result of the commission of a Federal offense ... ." 18 U.S.C. Section 3771(e). 
In 
particular, Defendant called Petitioner when she was a minor over a telephone (a means of 
interstate communication) requesting that she perform a massage in exchange for payment. As 
Defendant well knew, that request was fraudulent, as he not only intended to receive a massage, 
but also intended to have her perform sexual acts in exchange for a cash payment to Petitioner. 
Only when Petitioner arrived at a Defendant's mansion as directed by Defendant, did Defendant 
reveal his true purpose of obtaining sexual favors in exchange for payment. This conduct 
violated 18 U.S.C. § 2422, which forbids using a means of interstate commerce to knowingly 
"induce" or "entice" a minor "to engage in prostitution." In addition, this conduct was both a use 
of "fraud" to obtain a commercial sex act, in violation of 18 U.S.0 § 1591, and use of wire 
communications to perpetrate a "scheme and artifice to defraud," in violation of 18 U.S.C. § 
1343. 
It appears obvious that Petitioner was "directly and proximately" harmed by these crimes, 
thereby making her a victim under the CVRA. It should be emphasized that the CVRA "was 
designed to be a `broad and encompassing' statutory victims' bill of rights." United States' 
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Degenhardt, 405 F.Supp.2d 1341, 1342 (D. Utah 2005) (quoting 150 Cong. Rec. S426I (daily 
ed. Apr. 22, 2004) (statement of Sen. Feinstein)). Congress intended the CVRA to dramatically 
rework the federal criminal justice system. In the course of construing the CVRA generously, the 
Ninth Circuit observed: "The criminal justice system has long functioned on the assumption that 
crime victims should behave like good Victorian children -- seen but not heard. The Crime 
Victims' Rights Act sought to change this by making victims independent participants in the 
criminal justice process." Kenna' U.S. Dist. Court for C.D. Cal., 435 F.3d 1011, 1013 (9th Cir. 
2006). 
Accordingly, because the CVRA is remedial legislation, courts should interpret it 
"liberally to facilitate and accomplish its purposes and intent." 
Elliott Industries Ltd. 
Partnership'. BP America Production Co., 407 F.3d 1091, 1118 (10th Cir. 2005) (noting 
remedial legislation should be "interpreted liberally to facilitate and accomplish its purposes and 
intent"). The CVRA itself suggests this conclusion by requiring that courts must treat crime 
victims with "fairness." United States' Patkar, 2008 WL 233062 at *3 (D. Haw. 2008) (citing 
United States' Turner, 367 F.Supp.2d 319, 335 (E.D.N.Y. 2005)). 
Not only must the CVRA as a whole be interpreted liberally, but its definition of "crime 
victim" requires a generous construction. After reciting the direct-and-proximate-harm language 
at issue here, one of the Act's two co-sponsors -- Senator Kyl -- explained that "[t]his is an 
intentionally broad definition because all victims of crime deserve to have their rights protected 
." 150 Cong. Rec. S10912 (Oct. 9, 2004) (emphasis added). The description of the victim 
definition as "intentionally broad" was in the course of floor colloquy with the other primary 
sponsor of the CVRA and therefore deserves significant weight. See Kenna, 435 F.3d at 1015-16 
(discussing significance of CVRA sponsors= floor statements). 
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The definition of "crime victims" must thus be construed broadly in favor of Petitioner. 
She obviously qualifies as a "victim" under the CVRA. 
III. 
PETITIONER IS ENTITLED TO NOTICE OF HER RIGHTS, AN 
OPPORTUNITY TO CONFER WITH THE PROSECUTORS AND 
TO BE TREATED WITH FAIRNESS. 
Because Petitioner is a "victim" under the CVRA, she has certain protected rights under 
the Act. Most important, the Act promises that she will have an opportunity to "confer with the 
attorney for the Government in the case." To date, Petitioner has not been given that right. This 
raises that very real possibility that the Government may negotiate and conclude a plea agreement 
with the Defendant without giving Petitioner her protected rights.2 
Petitioner is entitled to have this conference with prosecutors before any final plea 
agreement is reached. The Fifth Circuit reached exactly this conclusion in a very recent case. In 
In re Dean, 527 F.3d 391 (5th Cir. 2008), the Government negotiated a plea agreement with the 
well-heeled corporate defendant without conferring with the victims. When the Government's 
failure was challenged in the Fifth Circuit, the Fifth Circuit concluded that the Government had 
indeed violated the CVRA. The Fifth Circuit observed: "In passing the [CVRA], Congress 
made the policy decision-which we are bound to enforce-that the victims have a right to inform 
the plea negotiation process by conferring with prosecutors before a plea agreement is reached." 
Id. at 394. 
This Court is obligated to protect the rights of Petitioner. The CVRA directs that "[i]n 
any court proceeding involving an offense against a crime victim, the court shall ensure that the 
2 On information and belief, roughly the same crimes were committed against several other young females. These 
victims, too, are in danger of losing their right to confer under the CVRA. 
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crime victim is afforded the rights described in [the CVRA]." 18 U.S.C. § 3771(b)(1). The 
CVRA also confers on crime victims the right to "assert the rights described in [the CVRA]." 18 
U.S.C. § 3771(d)(1). Therefore, this Court has its own independent obligation to intercede and 
ensure that the Government respects the rights of Petitioner under the CVRA. 
CONCLUSION 
The Petitioner requests the intervention of this Court to ensure that her rights are 
respected and accorded, as promised in the Crime Victims' Rights Act. 
DATED this 7th day of July, 2008. 
Respectfully Submitted, 
THE LAW OFFICE OF BRAD EDWARDS & 
ASSOCIATES, LLC 
Brad Edwards, Esquire 
Attorney for Petitioner 
Florida Bar #542075 
2028 Harrison Street 
Suite 202 
Hollywood, Florida 33020 
Telephone: 
954-414-8033 
Facsimile: 
954-924-1530 
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CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been 
provided by United States mail and via facsimile to: ANN 
C. 
United States Attorney's Office, 
this 7th day of July, 2008. 
, AUSA, 
Brad Edwards, Esquire 
Attorney for Petitioner 
Florida Bar No. 542075 
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