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17 
Following the signing of the Non-Prosecution Agreement and the modifications thereto 
by the U.S. Attorney's Office for the Southern District of Florida, Epstein received an unusual 
benefit that the Government does not ordinarily provide to other criminal defendants: his 
performance was delayed white he was given an opportunity to seek higher level review within 
the Department of Justice in Washington, D.C. 
On around January 10, 2008, Jane Doc #1 and Jane Doe #2 received letters from the FBI 
advising them that "[t]his case is currently under investigation. This can be a lengthy process 
and we request you continued patience while we conduct a thorough investigation." The FBI 
sent these letters, under the direction of the U.S. Attorney's Office, because it believed that the 
CVRA applied to Jane Doe #1 and Jane Doe #2. The FBI did not notify Jane Doe #1 or Jane 
Doe #2 that the Non-Prosecution Agreement had been concluded four months earlier. Jane Doe 
#1 and Jane Doe #2 reasonably understood that a federal criminal investigation of Epstein was 
on-going and that federal criminal charges were possibility. At the time, Jane Doe #1 and Jane 
Doe #2 believed that criminal prosecution of Epstein was extremely important. They also 
desired to be consulted by the FBI and/or other representatives of the federal government about 
the prosecution of Epstein. In light of the letters that they had received around January 10 
(among other things), they reasonably believed that they would be contacted before the federal 
government reached any final resolution of that investigation. 
In the spring 2008, Jane Doe #1 contacted the FBI because Epstein's counsel was 
attempting to take her deposition and private investigators were harassing her. Assistant U.S. 
Attorney 
secured pro bono counsel to represent Jane Doe il l and several other 
identified victims in connection with the criminal investigation. Pro bono counsel was able to 
6 
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17 
assist Jane Doe #1 in avoiding the improper deposition. AUSA Villafafla secured pro bono 
counsel by contacting Meg Garvin, Esq. of the National Crime Victims' Law Institute in 
Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. 
Garvin was not advised about the Non-Prosecution Agreement. 
In mid-June 2008, Mr. Edwards contacted Assistant U.S. Attorney Villafafla to inform her 
that he represented Jane Doe #1 and, later, Jane Doe #2. Mr. Edwards asked to meet to provide 
information about the federal crimes committed by Epstein, hoping to secure a significant federal 
indictment against Epstein. AUSA Villafafla and Mr. Edwards discussed the possibility of federal 
charges being filed. At the end of the call, AUSA Villafafla asked Mr. Edwards to send any 
information that he wanted considered by the U.S. Attorney's Office in determining whether to 
file federal charges. Because of the confidentiality provision in the Non-Prosecution Agreement, 
Mr. Edwards was not informed of the Agreement's existence. Mr. Edwards was also not 
informed that any resolution of the criminal matter was imminent. 
On July 3, 2008, Mr. Edwards sent to AUSA Villafafia a letter, a true and correct copy of 
which is attached as Exhibit 3. In the letter, Mr. Edwards indicated his desire that federal 
charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients: "We 
urge the Attorney General and our United States Attorney to consider the fundamental import of 
the vigorous enforcement of our Federal laws. We urge you to move forward with the traditional 
indictments and criminal prosecution commensurate with the crimes Mr. Epstein has committed, 
and we further urge you to take the steps necessary to protect our children from this very 
dangerous sexual predator." When Mr. Edwards wrote this letter, he still had not been made 
aware that a Non-Prosecution Agreement had been reached with Epstein. 
7 
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17 
On about July 3, 2008, Jane Doe #1 and Jane Doe #2 learned, through telephones 
conversations had between Mr. Edwards and AUSA Villafafia, that the U.S. Attorney's Office 
and Epstein might be in the process of finalizing some sort of plea arrangement. Accordingly, 
they filed an emergency motion seeking to protect their rights under the CVRA, including in 
particular their right to confer about the proposed plea arrangement. 
Mr. Edwards — and thus his clients -- first learned of the Non-Prosecution Agreement on 
or after July 9, 2008, when the Government filed its responsive pleading to Jane Doe's 
emergency petition. That pleading was the first public mention of the non-prosecution agreement 
and the first disclosure to Mr. Edwards and his clients. Epstein, through his attorneys, knew that 
the victims had not been informed about the plea arrangement. 
On July 9, 2008, AUSA 
sent a victim notification to Jane Doe #1 via her 
attorney, Mr. Edwards, which is attached as Exhibit 6 to the 
Declaration. That 
notification contains a written explanation of some of the terms of the Non-Prosecution 
Agreement between Epstein and the U.S. Attorney's Office. A full copy of the terms was not 
provided. This was the first time that Jane Doe #1 was told that the arrangement blocked any 
possibility of federal criminal charges being filed against Epstein. A notification was not 
provided to Jane Doe #2 because the agreement limited Epstein's liability to victims whom the 
United States was prepared to name in an indictment. 
On July 11, 2008, the Court held a hearing on the victims' emergency motion. During the 
hearing, the Government discussed in open court various provisions of the Non-Prosecution 
Agreement. At the conclusion of the hearing, victims' counsel and the Government agreed to 
8 
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17 
confer in an effort to determine the undisputed facts of the fact. The Court took the motion under 
advisement. 
On July 16, 2008, the Government sent to Mr. Edwards a proposed set of undisputed 
facts, which is attached to this pleading as Exhibit 1. 
On July 17, 2008, Mr. Edwards sent a response to the Government, which is attached to 
this pleading as Exhibit 2. The response made various suggestions to the proposed undisputed 
facts. The response also requested a copy of the Non-Prosecution Agreement and the Report of 
Interview with Jane Doe #1. 
On July 29, 2008, rather than attempt to work with victims' counsel to draft a set of 
undisputed facts, the Government filed its "Notice to Court Regarding Absence of Need for 
Evidentiary Hearing." 
At all times material to this statement of facts, it would have been easily practical and 
feasible for the Federal Government to inform Jane Doe #1 and Jane Doe #2 of the details of any 
proposed plea agreement with Epstein, including in particular the details of the Non-Prosecution 
Agreement. The reason that AUSA Villafafla and the FBI agents acting with her did not provide 
this information to Jane Doe #1 and Jane Doe #2 was because of the express confidentiality 
provision that had been entered into by the Federal Government and Epstein. This provision 
was requested by Epstein. The Government was under no obligation to enter into such an 
arrangement and would have been statutorily forbidden from entering into such an arrangement 
by the CVRA's requirement that it "confer" with the victims about any disposition of their cases. 
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17 
THE GOVERNMENT SHOULD BE DIRECTED TO CONFER WITH THE VICTIMS 
REGARDING THE UNDISPUTED FACTS OF THE CASE 
The Government should be directed to confer with the victims about the facts in this case, 
rather than allowed to obscure the facts with its proposed "notice" that an evidentiary hearing is 
unnecessary. The reason that the Government abruptly terminated discussions about the facts 
with the victims seem obvious: The facts, if revealed, would plainly demonstrate that the victims 
did not receive their right under the CVRA to confer with the Government and to be treated 
fairly. The victims will not repeat all of their arguments from their earlier pleadings but would 
simply highlight for the Court the point that this case already reeks of favored treatment for a 
billionaire sex offender who has substantial influence. Regardless of how the Court proceeds, it 
should at least do so on the basis of fully developed factual record so that the victims and the 
public can be assured that justice has been done. 
If anything, the facts in this case now call for immediate judgment in favor of the victims. 
Based on the Government's proposed stipulated facts (Exhibit 1 to this pleading), it is now 
obvious that the Government could not have fulfilled its statutory obligations to confer with the 
victims. As now admitted by the Government, in September 2007, it had entered into a Non-
Prosecution Agreement with Epstein containing what it describes as "an express confidentiality 
provision." While the Government has refused to disclose the text of this provision (or, indeed, 
the Non-Prosecution Agreement itself), it is apparent that the Government could not have 
conferred with the victims about the Agreement while abiding by the confidentiality provision. 
Likewise it is now apparent that the Government has not fulfilled its statutory obligation 
to treat the victims with fairness. The Government reached the Non-Prosecution Agreement with 
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17 
Epstein in September 2007, yet affirmatively concealed that Agreement from the victims through 
a series of misleading statements and representations over the next nine months. For example, 
on around January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI advising 
them that "[Obis case is currently under investigation. This can be a lengthy process and we 
request your continued patience while we conduct a thorough investigation." As the Government 
well knew, however, a Non-Prosecution Agreement had already been reached with Epstein at that 
time — a fact not disclosed in the letter. 
The victims therefore request judgment in their favor that their rights under the CVRA 
have been violated. 
In the alternative, the victims request that the Court direct that the 
Government confer in good faith with the victims to attempt to reach a set of stipulated facts that 
might form the basis for a final ruling in this case. As part of this conference, the victims request 
that the Government indicate which (if any) of the proposed facts set forth above it disputes. 
THE GOVERNMENT SHOULD BE REQUIRED TO PRODUCE 
THE NON-PROSECUTION AGREEMENT 
Remarkably, the Government has yet to disclose to the victims the very Non-Prosecution 
Agreement that lies at the heart of this case. This failure becomes even more curious when 
assessed against the Government's proposed stipulation of facts, which included the proposed 
fact that the victims had been told about the "full terms" of the Agreement. The proposed 
stipulated facts that the Government sent to the victims included this proposed stipulation: 
On July 9, 2008, AUSA Villafafta sent a victim notification to Jane Doe #1 via her 
attorney, Bradley Edwards, which is attached as Exhibit 6 to the Villafafla 
Declaration. That notification contains a written explanation of the full terms of 
the agreement between Epstein and the U.S. Attorney's Office. 
Contrary to its own proposed stipulation, the Government has never disclosed to the victims the 
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17 
"full terms" of its Non-Prosecution Agreement with Epstein. To protect the victims' right to be 
treated with fairness, 18 U.S.C. § 3771(a)(8), it should be required to do so now. 
Congress' main concern in passing the CVRA was that 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 
Coma. 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. To date, Jane Doe #1 and Jane Doe #2 do not know what has happened to their case, 
because they have not been told how it has been resolved. Of course, no possible harm to the 
Government can come from the release of the Agreement, as this criminal matter is now 
concluded — at least from the Government's perspective. 
Production of the Non-Prosecution Agreement is also warranted because it has provisions 
in it that are designed to benefit Jane Doe #1 and Jane Doe #2. As described by the Government, 
the Agreement contains provisions in it that preclude Epstein from contesting civil liability for 
the sex offenses committed against a number of the victims, including Jane Doe #1. Obviously, 
Jane Doe #1 cannot take advantage of this provision if her attorneys are not able to review it. 
Jane Doe #1 and Jane Doe #2 intend to file civil suits against Epstein within the next few days. 
Epstein knows what is in the Non-Prosecution Agreement that may be helpful to him. Jane Doe 
#1 and Jane Doe #2 are entitled to see the Agreement for items that may be helpful to them. 
Finally, Epstein is apparently taking advantage of provisions in the Non-Prosecution 
Agreement to stall civil suits against him. For example, in Jane Doe 1. Epstein et al, No. 08-
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80804-MARRA/JOHNSON (S.D. Fla. 2008), on July 25, 2008, Epstein filed a motion for a stay. 
That motion claims that the civil action is "a counterpart to a pending federal criminal action." 
The basis for that claim, so far as Jane Doe #1 and Jane Doe #2 can tell, is the federal Non-
Prosecution Agreement. Epstein should not be permitted to use provisions in the Agreement to 
his advantage in private litigation without disclosing those provisions to the parties he is 
opposing. Indeed, as a simple matter of fairness to the victims, see 18 U.S.C. § 3771(a)(5) 
(victims right to "fairness"), the provisions should be disclosed. 
In sum, the Court should direct the Government to reveal to the victims what it has done 
to resolve the case by ordering production of the full Non-Prosecution Agreement and any 
accompanying addenda to the agreement. 
THE GOVERNMENT SHOULD BE REQUIRED TO PRODUCE THE REPORT OF 
INTERVIEW WITH JANE DOE #1 
The Government apparently has a report of interview indicating that two named FBI 
agents met with Jane Doe #1 on about October 26, 2007. The Government, however, has 
declined to produce it. 
The Government should be directed to produce this information to Jane Doe #1. Of 
course, a criminal defendant would be entitled to such a report. See Fed. R. Crim. P. 16(a)(1)(A) 
& (B). As an innocent victim in this matter, Jane Doe #1 should be treated with at least the same 
consideration. See 18 U.S.C. § 3771(aX8) (victim's right to "be treated with fairness"). Jane 
Doe #1 requested this report in her letter regarding the proposed stipulated facts (see Exhibit 2 to 
this filing), a request that the Government has simply ignored. 
13 
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AFTER ENTERING JUDGMENT FOR THE VICTIMS' ON THE VIOLATION OF THEIR 
RIGHTS, THE COURT SHOULD SCHEDULE A HEARING ON THE APPROPRIATE 
REMEDY 
For the reasons just explained, the Court should enter judgment for Jane Doe #1 and Jane 
Doe #2 on the violations of their rights under the CVRA and order the Government to produce 
the Non-Prosecution Agreement and the report of interview with Jane Doe #1. After doing that, 
the question then arises as to what is the proper remedy for the violations of victims' rights. 
To be clear, at this time, the victims seek two things: (1) a judicial declaration that the 
Government violated their rights under the CVRA and an apology from the Government; and (2) 
a hearing to discuss the appropriate remedy under the circumstances. At the same time, the 
victims are not asking to have any provision in the Non-Prosecution Agreement establishing 
liability in a civil suit to be vacated or declared invalid. 
Because the possible connection 
between these two things raises complex legal issues, the victims respectfully request that the 
Court order a hearing at which the appropriate remedy can be discussed. The victims also need 
to review the full text of the Non-Prosecution Agreement and any accompanying addenda to 
make an appropriate determination about the remedy that they wish to pursue. 
CONCLUSION 
The Court should find that the Government violated Jane Doe #1 and Jane Doe #2's 
rights under the CVRA to confer and to be treated with fairness during the negotiation and 
consummation of the Non-Prosecution Agreement. In the alternative, the Court should direct the 
Government to confer with the victims regarding what facts are undisputed in this matter and, 
should material facts actually be disputed, hold an evidentiary hearing regarding those facts. So 
that the victims can discuss these matters with the Government, the Court should order the 
14 
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17 
Government to provide to the victims the full Non-Prosecution Agreement (and accompanying 
addenda) that is central to this litigation as well as a report of interview with Jane Doe #1 from 
about October 26, 2007. The Court should then hold a hearing on the proper remedy for the 
violations of the victims' rights. 
DATED this 1st day of August, 2008. 
Respectfully Submitted, 
THE LAW OFFICE OF BRAD EDWARDS & 
ASSOCIATES, LLC 
By: 
s/ Brad Edwards 
Brad Edwards, Esquire 
Attorney for Petitioners 
Florida Bar No. 542075 
2028 Harrison Street 
Suite 202 
Hollywood, Florida 33020 
Telephone: 
954-414-8033 
Facsimile: 
954-924-1530 
E-Mail: 
[email protected] 
Paul G. Cassell 
Attorney for Petitioners 
Pro Hac Vice 
332 S. 1400 E. 
Salt Lake City, UT 84112 
Telephone: 
801-585-5202 
Facsimile: 
801-585-6833 
E-Mail: 
[email protected] 
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17 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on August 1, 2008, I electronically filed the foregoing 
document with the Clerk of the Court using CM/ECF. 
s/ Brad Edwards 
Brad Edwards, Esquire 
Attorney for Petitioner 
Florida Bar No. 542075 
SERVICE LIST 
Jane Doe 1 and Jane Doe 2 
Case No.: 08-80736-C1V-MARRA/JOHNSON 
United States District Court, Southern District of Florida 
Dexter A. Lee, 
Assistant U.S. Attorney 
99 N.E. 4th Street 
Miami, Florida 33132 
Telephone: 
305-961-9320 
Facsimile: 
305-530-7139 
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. (USAFLS) 
From: 
. (USAFLS) 
Sent: 
ill i
gi..
ust
, 2008 3.58 PM 
To: 
Roy BLACK 
Cc: 
Atkinson, Karen (USAFLS), Lee, Dexter (USAFLS) 
Subject: 
Notification of Possible Compelled Disclosure of the Non-Prosecution Agreement 
Dear Roy: 
In accordance with paragraph 13 of the Non-Prosecution Agreement, I am providing notice of possible 
compulsory process commanding the disclosure Mite Agreement. As I'm sure you know. two of Mr. Epstein's 
victims have filed suit against the United States alleging that the government violated their rights as victims by 
not consulting them prior to entering into the Non-Prosecution Agreement. 
As part of their response to one of the government's 111Mgs, the victims asked the Court to order the production 
of the Non-Prosecution Agreement. The deadline for the government to respond is August I 5th and we intend 
to oppose the motion based upon the confidentiality provision. I have attached a copy of the victims' pleading 
for your review. 
In connection with this. we want to make certain that we are making consistent representations to the judiciary 
regarding the contents of the Agreement. I know that Jack Goldberger filed the Agreement under seal in the 
state court in accordance with the state judge's order. Can you provide us with a copy of what Jack filed, so 
that, if we arc ordered by the federal court to disclose the agreement, it is exactly the same as what has been 
tiled in the state court? 
Thank you again for your assistance. 
DE19_080801_Vi 
Alms' Resp to N.. 
.1. 
Villrfrda 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach. FL 33401 
Tracking: 
296 
08-80736-CV-MARRA 
RIP WPB-001825 
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EXHIBIT 
124 
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20 
. (USAFLS) 
From: 
Sent: 
To: 
Cc: 
Subject: 
. (USAFLS) 
8 525 PM 
nson. wren (USAFLS) 
RE messages 
[hank 
I think we arc going m have to produce a cup) of the agreement in a sub pending in the 
federal court. and I want to make sure that we are using the same document in hoth courthouses. 
Thank you again, and have a good weekend. 
A. Ahirie 
Assistant I I,S. Attorney 
500 S. Australian Ave. Suite 400 
West Palm Beach. r I. 33401 
From: 
Belohlavek 
Sett 
008 5:13 PM 
To: 
(USAFLS) 
Subject: messages 
Have gotten your messages but have been swamped and am just getting out of court. I will gel with you on Monday 
Have a good weekend. 
Tracking: 
itS9 
08-80736-CV-MARRA 
PPP WPB-001820 
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20 
(USAFLS) 
From: 
(USAFLS) 
Sent: 
urs ay, ugus 
, 008 4:36 PM 
To: 
Roy BLACK 
Subject: 
RE: Notification of Possible Compelled Disclosure of theNon-Prosecution Agreement 
Thank you, Roy. Your help is greatly appreciated. 
A. 
Villafaha 
Assistant U.S. Attorney 
 
Original Message 
From: Roy BLACK [mailto:[email protected]] 
Sent: Thursda , August 07, 2008 4:34 PM 
To: 
. (USAFLS) 
Subject: Re: Notification of Possible Compelled Disclosure of theNon-Prosecution 
Agreement 
I am working on this and will get back to you. 
 
Original Message 
From: 
(USAFLS)" 
To: Roy BLACK <[email protected]> 
Cc: Dexter (USAFLS) 
Cc: Karen (USAFLS) At 
Sent: 8/7/2008 3:57:52 PM 
Subject: Notification of Possible Compelled Disclosure of the Non-Prosecution 
Agreement 
Dear Roy: 
In accordance with paragraph 13 of the Non-Prosecution Agreement, I am providing 
notice of possible compulsory process commanding the disclosure of the Agreement. 
As I'm sure you know, two of Mr. Epstein's victims have filed suit against the 
United States alleging that the government violated their rights as victims by 
not consulting them prior to entering into the Non-Prosecution Agreement. 
As part of their response to one of the government's filings, the victims asked 
the Court to order the production of the Non-Prosecution Agreement. The deadline 
for the government to respond is August 15th and we intend to oppose the motion 
based upon the confidentiality provision. I have attached a copy of the victims' 
pleading for your review. 
In connection with this, we want to make certain that we are making consistent 
representations to the judiciary regarding the contents of the Agreement. I know 
291 
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20 
that Jack Goldberger filed the Agreement under seal in the state court in 
accordance with the state judge's order. Can you provide us with a copy of what 
Jack filed, so that, if we are ordered by the federal court to disclose the 
agreement, it is exactly the same as what has been filed in the state court? 
Thank you again for your assistance. 
Regards, 
«DE19_080801Victims' Resp to Notice.pdf» 
A. 
Assistant U.S. Attorney 
Tracking: 
292 
08-80736-CV-MARRA 
RFP WPB-001822 
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20 
(USAFLS) 
From: 
Roy BLACK (RBIACK©royblack.comi 
Sent: 
008 4:34 PM 
To: 
. (USAFLS) 
Subject:
Possible Compelled Disclosure of theNon-Prosecution Agreement 
I am working on this and will get back to you. 
 
Original Message 
From: 
To: Roy BLACK <[email protected]> 
Cc: Dexter (USAFLS) Lee 
Cc: Karen (USAFLS) Atkinson 
Sent: 8/7/2008 3:57:52 PM 
Subject: Notification of Possible Compelled Disclosure of the Non-Prosecution 
Agreement 
Dear Roy: 
In accordance with paragraph 13 of the Non-Prosecution Agreement, I am providing 
notice of possible compulsory process commanding the disclosure of the Agreement. 
As I'm sure you know, two of Mr. Epstein's victims have filed suit against the 
United States alleging that the government violated their rights as victims by 
not consulting them prior to entering into the Non-Prosecution Agreement. 
As part of their response to one of the government's filings, the victims asked 
the Court to order the production of the Non-Prosecution Agreement. The deadline 
for the government to respond is August 15th and we intend to oppose the motion 
based upon the confidentiality provision. I have attached a copy of the victims' 
pleading for your review. 
In connection with this, we want to make certain that we are making consistent 
representations to the judiciary regarding the contents of the Agreement. I know 
that Jack Goldberger filed the Agreement under seal in the state court in 
accordance with the state judge's order. Can you provide us with a copy of what 
Jack filed, so that, if we are ordered by the federal court to disclose the 
agreement, it is exactly the same as what has been filed in the state court? 
Thank you again for your assistance. 
Regards, 
«DE19_080801_Victims' Resp to Notice.pdf» 
A. 
Assistant U.S. Attorne 
291 
08-80736-CV-MARRA 
RFP WPB-001823 
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Villafana, Anne 
C. (USAFLS) 
From: 
. (USAFLS) 
Sent: 
.1.. 
Mi
tgust F2008 a 58 PM 
To: 
Roy BLACK 
Cc: 
Atkinson, Karen (USAFLS); Lee. Dexter (USAFLS) 
Subject: 
Notification of Possible Compelled Disclosure of the Non•Prosecut ion Agreement 
Dear Roy: 
In accordance with paragraph 13 of the Non-Prosecution Agreement, lam providing notice of possible 
compulsory process commanding the disclosure of the Agreement. As I'm sure you know. two of Mr. Epstein's 
victims have filed suit against the United States alleging that the government violated their rights as victims by 
not consulting them prior to entering into the Non-Prosecution Agreement. 
As part of their response to one of the government's filings. the victims asked the Court to order the production 
of the Non-Prosecution Agreement. The deadline for the government to respond is August ISs and we intend 
to oppose the motion based upon the confidentiality provision. I have attached a copy of the victims' pleading 
for your review. 
In connection with this, we want to make certain that we are making consistent representations to the judiciary 
regarding the contents of the Agreement. I know that Jack Goldberger tiled the Agreement under seal in the 
state court in accordance with the state judge's order. Can you provide us with a copy of what Jack filed, so 
that, if we are ordered by the federal court to disclose the agreement. it is exactly the mine as what has been 
filed in the state court? 
Thank you again for your assistance. 
Regards. 
Marie 
DE19_08080 l_VI 
Resp to N.. 
.4. 
Villafatla 
Tracking: 
296 
08-80736-CV-M.ARRA. 
RFP WPB-001825 
EFTA00185123