EFTA00185206

Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 17 of 
18 
Bates Range 
Descri tion 
Privilege(s) Asserted 
P-014838 
thru 
P-014843 
4/4/2008-4/7/2008 emails between 
Work Product 
6(e) 
Deliberative Process 
and 
regarding status of CEOS review 
of Epstein matter 
P-014844 
thru 
P-014851 
4/10/2008-4/18/2008 emails between 
6(e) 
Work Product 
Deliberative Process 
Investigative Privilege 
and 
about continued 
delay in presenting case to grand jury due to failure to receive decision 
from
a
DC, status of grand jury presentation and on
 muesli tion 
P-014852 
thru 
P-014864 
4/11/20084/23/2008 emails between 
and 
Work Product 
Deliberative Process 
Privacy Act 
regarding self-reporting to OPR false allegations of ethics 
violations 
P-014865 
4/29/2008 email from 
I 
to 
, 
Work Product 
6(e) 
Deliberative Process 
Investi alive Privilege 
on 
re grand jury presentation 
P-014866 
thru 
P-014883 
4/21/2008-5/1/2008 emails between 
and 
about continued delay in presenting case to grand jury due to failure to 
receive decision from DC, status of grand jury presentation and ongoing 
investigation, staffing of case for purposes of trial, and meeting to 
prepare for 9 . • d • 
resentation 
6(e) 
Work Product 
Deliberative Process 
Investigative Privilege 
P-014884 
thru 
PM 14886 
5/2/2008 emails between 
6(e) 
Work Product 
Attorney-Client Privilege 
Investigative Privilege 
Deliberative Process 
and 
regarding 
developments in Epstein investigation and impact on grand jury 
presentation 
P-014887 
thru 
P-014894 
4/29/2008-5/2/2008 emails between 
and 
6(e) 
Work Product 
Deliberative Process 
Investigative Privilege 
regarding contact by Epstein counsel and victims and draft letter to 
counsel for Epstein 
Page 17 of 18 
EFTA00185446

Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 18 of 
18 
Bates Ran e 
Description 
Privil 
s Asserted 
P-014895 
thru 
P-014900 
5/7/2008-5/9/2008 emails between 
Work Product 
6(e) 
Deliberative Process 
Attorney-Client Privilege 
Investigative Privilege 
, and 
regarding awaiting 
approval from DC and status of ongoing investigation 
P-014901 
thru 
P-014906 
5115/2008-5/16/2008 emails between 
and 
Work Product 
Deliberative Process 
regarding receiving final approval from DC 
P-014907 
thru 
P414911 
5/19/2008-5/22/2008 emails between 
6(e) 
Work Product 
Deliberative Process 
Investigative Privilege 
and 
regarding preparation for grand jury 
presentation; communication with S/A Kuyrkendall regarding plea 
negotiations; and status of on oin investigation 
P414912 
thru 
P-014919 
5/23/2008-5/27/2008 emails between 
Work Product 
6(e) 
Deliberative Process 
Investigative Privilege 
(FBI), and Jason 
Richards (FBI) re status of investigation, indictment review, grand jury 
preparation, and E . stein's attem •t to revisit plea negotiations 
P-014920 
thru 
P-014923 
8/15/2008 email from 
to Alex Acosta, 
Work Product 
Deliberative Process 
and 
containing draft 
response to 8/15/2008 email from Jay Lefkowitz regarding 
implementation of the NPA. (Redacted version produced to opposing 
counsel) 
Page 18 of 18 
EFTA00185447

Case 9:08-cv-80736-KAM Document 338 Entered on FLSD Docket 08/03/2015 Page 1 of 2 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 08-80736-Civ-Marra/Matthewman 
JANE DOE #1 AND JANE DOE #2, 
Petitioners, 
I 
UNITED STATES OF AMERICA, 
Respondent. 
UNITED STATES' NOTICE OF FILING THIRD SUPPLEMENTAL PRIVILEGE LOG 
Pursuant to the Court's June 18, 2013 Omnibus Order (DE 190), the Respondent, United 
States of America, by and through the undersigned Assistant United States Attorney, hereby gives 
notice of its filing of its Third Supplemental Privilege Log. The index has been marked with 
Bates Numbers P-014924 thru P-015267. 
The documents referenced in the Third Supplemental Privilege Log will be delivered 
tomorrow to the Chambers of U.S. District Judge Kenneth A. Marra for ex parte in camera review, 
pursuant to the Court's Omnibus Order. 
Respectfully submitted, 
UNITED STATES ATTORNEY 
By: 
Assistant United States Attorney 
Florida Bar No. 0018255 
500 South Australian Ave, Suite 400 
West Palm Beach. FL 33401 
Telephone: 
Facsimile: 
1 
EFTA00185448

Case 9:08-cv-80736-KAM Document 338 Entered on FLSD Docket 08/03/2015 Page 2 of 2 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on August 3, 2015, I electronically filed the foregoing 
document with the Clerk of the Court using CM/ECF. According to the Court's website, 
counsel for all parties are able to receive notice via the CM/ECF system. 
Assistant United States Attorney 
SERVICE LIST 
Jane Does 1 and 2'. United States, 
Case No. 08-80736-CIV-MARRA/MATTHEWMAN 
United States District Court, Southern District of Florida 
Brad Edwards, Esq., 
Farmer Jaffe Weissing Edwards Fistos Lehrman 
425 N Andrews Ave Ste 2 
Fort Lauderdale, FL 33301-3268 
brad®pathtojustice.com 
954-524-2820 
Fax: 954-524-2822 
Paul G. Cassell 
S.J. Quinney College of Law at the 
University of Utah 
332 S. 1400 E. 
Salt Lake City, Utah 84112 
(801) 585-5202 
Fax: (801) 585-6833 
E-mail: casselp®law.utah.edu 
Attorneys for Jane Doe # 1 and Jane Doe # 2 
2 
EFTA00185449

Case 9:08-cv-80736-KAM Document 338-1 Entered on FLSD Docket 08/03/2015 Page 1 of 7 
JANE DOE'. UNITED STATES 
COURT FILE NO. 08-80736-CV-MARRA 
THIRD SUPPLEMENTAL PRIVILEGE LOG - BOX #5 
Bates Range 
Deseir.ion 
Privilege(s) Asserted 
P-014924 
5/27/2008 emails between IM. 
and 
regarding 
Work Product 
Deliberative Process
report of new state.  lea deal for J. Epstein 
P-014925 
thru 
P-014927 
5/27/2008 emails between 
and .-- 
Work Product 
Deliberative Process 
Investigative Privilege 
6e 
regarding potential renewed plea negotiations for J. Epstein 
and plans to review and revise updated indictment package 
P-014928 
5/23/2008-5/27/2008 emails between 
, 
Attorney-Client Privilege 
Investigative Privilege 
6(e) 
Privacy Act/TVPA/CVRA 
and 
regarding plans to meet to prepare for indictment 
presentation, service of grand jury subpoenas, interviews of additional 
witnesses, and plea negotiation issue 
P-014929 
thru 
P-014933 
5/27/2008-5/28/2008 emails between 
E. 
Attorney-Client Privilege 
Investigative Privilege 
6(e) 
Privacy Act/TVPA/CVRA 
and 
regarding request for legal analysis of 
statute of limitations issues under state and federal law 
P-014934 
thru 
P-014935 
5/27/2008-5/28/2008 emails between 
all 
Work Product 
Deliberative Process 
= 
and 
regarding report of new state plea 
deal for J. Epstein 
P-014936 
thru 
P-014940 
5/29/2008-5/30/2008 emails between 
= 
E. 
and 
regarding 
planned grand jury presentation, status of investigation, possible grant 
of immunity to victim/witness for grand jury testimony 
Work Product 
Attorney-Client Privilege 
6(e) 
Investigative Privilege 
Deliberative Process 
Privacy Act/IVPA/CVRA 
Page 1 of 7 
EFTA00185450

Case 9:08-cv-80736-KAM Document 338-1 Entered on FLSD Docket 08/03/2015 Page 2 of 7 
Bates Range 
Description 
Privilege(s) Asserted 
P-014941 
thru 
P-014954 
6/2/2008 draft letter to Deputy Attorney General 
regarding 
Work Product 
6(e) 
Deliberative Process 
Investigative Privilege 
reasons to approve continued prosecution of J. Epstein 
(NB: The Court has already determined that final version of this letter 
is protected by Work Product/Deliberative Process/Attorney-Client 
Privileges) 
P-014955 
thru 
P-014971 
6/3/2008 draft letter to Deputy Attorney General 
regarding 
Work Product 
6(e) 
Deliberative Process 
Investigative Privilege 
reasons to approve continued prosecution of J. Epstein 
(NB: The Court has already determined that final version of this letter 
is protected by Work Product/Deliberative Process/Attorney-Client 
Pria 
P-014972 
thru 
P-014975 
6/6/2008 emails between 
. 
li
 
and E. 
Attorney-Client Privilege 
Investigative Privilege 
6(e) 
Privacy Act/TVPA/CVRA 
regarding victim/witness subpoenaed to the grand jury and need for 
additional grand jury subpoenas 
P-014976 
6/18/2008 emails between 
A. Acosta, 
Work Product 
Deliberative Process 
M 
and 
regarding telephone conference 
with R. Black about allowing J. Epstein to accept state plea to 60 days' 
imprisonment. 
P-014977 
thru 
P-014978 
6/19/2008 email forwardin: 6/19/2008 email from 
to E. 
and 
(NB: Asserting privilege only for 
email. Attorney 
Edwards presumably has cop of his email to 
Attorney-Client Privilege 
Investigative Privilege 
P-014979 
thru 
P-014980 
6/23/2008 emails between 
. 
and 
(USAO staff) regarding scheduling of grand jury time for indictment 
presentation and witness testimony 
(Information regardin unrelated 
d ' 
case redacted
Work Product 
Investigative Privilege 
6(e) 
P-014981 
6/23/2008 emails between 
. 
E. 
, 
Attorney-Client Privilege 
Work Product 
6(e) 
Investigative Privilege 
Deliberative Process 
Privacy Act/TVPA/CVRA 
and 
regarding grand jury subpoena to 
victim/witness, revisions to indictment, planned grand jury presentation, 
and plans to supersede indictment 
Page 2 of 7 
EFTA00185451

Case 9:08-cv-80736-KAM Document 338-1 Entered on FLSD Docket 08/03/2015 Page 3 of 7 
Bates Range 
Resell 
Privilege(s) Asserted
P-014982 
thru 
P-014990 
.) 
Work Product 
Deliberative Process 
6/25/2008 emails between 
. 
, 
and A. Acosta regarding draft of notification of victim list for 
J. Epstein counsel with attached drafts 
(NB: Final list, with victim names redacted, has been produced to 
counsel for Petitioners
P-014991 
thru 
P-015004 
6/23/2008-6/26/2008 emails between-. 
and counsel for 
6(e) 
Investigative privilege 
Privacy Act/TVPA/CVRA 
grand jury witness/victim regarding immunity and travel for grand jury 
ap ear
e,
P-015005 
thru 
P-015006 
6/28/2008 emails between 
. 
A. Acosta, and 
Work Product 
Deliberative Process 
Attorney-Client Privilege 
regarding correspondence with J. Goldberger and proposed 
chang
agreement 
P-015007 
7/3/2008 emails between_and 
A. Acosta 
Work Product 
Deliberative Process 
regarding telephone cod. 
nd regarding meeting with 
Sheriff's Office about work release program 
P-015008 
thru 
P-015024 
7/8/2008 emails between 
A 
Attorney Advisory, Victim 
Witness Staff, EOUSA), and 
regarding filing of 
Petitioners' suit, with attached Draft of 
Declaration and initial 
Petition (DE1) 
(NB: Privilege is not being asserted for second attachment (DEI). 
Attachment was prepared by petitioners and is not being produced 
because it is within their custodiiii,control.) 
Work Product 
Deliberative Process 
P-015025 
thru 
P-015028 
7/8/2008 email from 
. 
to 
A. Acosta, and 
Work Product 
Deliberative Process 
regarding victim notification letter provided to counsel for J. 
Epstein on 11/28/2007 with attachment 
(NB: The 11/28/2007 email to J. Leflcowitz with attachment will be 
produced to petitioners' counsel contemporaneously with the filing of 
this lo 
P-015029 
thru 
P-015034 
7/7/2008-7/8/2008 emails between 
and 
regarding 
Work Product 
Deliberative Process 
Attorney-Client Privilege 
background of J. Epstein investigation, negotiations, and victim 
notifications, and forwarding earlier emails related to Lee questions 
Page 3 of 7 
EFTA00185452

Case 9:08-cv-80736-KAM Document 338-1 Entered on FLSD Docket 08/03/2015 Page 4 of 7 
Bates Ran e 
Description 
Privile e s Asserted 
P-015035 
thru 
P-015062 
7/8/2008-7/9/2008 emails between 
, 
A. Acosta, 
, 
, and 
regarding response to Jane Doe suit, procedure for filing, and internal 
office policies 
Work Product 
Deliberative Process 
P-015063 
thru 
P-015069 
7/11/2008-7/14/2008 emails between 
• nr 
A. Acosta, 
and 
re outcome of hearing in 
Jane Doe I. U.S. suit and contact from counsel for J. E stein 
Attorney-Client Privilege 
Work Product 
Deliberative Process 
P-015070 
thru 
P-015071 
7/14/2008-7/15/2008 emails between 
E. 
Attorney-Client Privilege 
and T. Smith regarding FBI victim 
notifications and guidance regarding language to use and information to 
rovide 
P-015072 
thru 
P-015074 
7/17/2008 email from 
to A. Acosta, 
. 
Work Product 
Deliberative Process 
and 
with attached draft of letter to M. Tein 
regarding misrepresentations in filings on behalf of J. Epstein in civil 
suits 
P-015075 
thru 
P-015081 
7/18/2008-7/21/2008 emails between 
U 
E. 
, 
and 
regarding 
preparation of victim notification letters, victim contact list, filigg.of 
victim notification letter in a civil proceeding, and contact by . 
with one victim o uun that sentence im sed was insufficient 
Attorney-Client Privilege 
Work Product 
Investigative Privilege 
P4115082 
thru 
P-015084 
7/21/2008 emails between 
I 
, 
Work Product 
Attorney-Client Privilege 
Deliberative Process 
6(e) 
E. 
and 
regarding ongoing 
victim notification process and Epstein filings in state court litigation 
related to federal grand * 
investigation 
P-015085 
thru 
P-015090 
7/22/2008 emails between 
A. AS 
, 
E. 
, and 
regarding 
7/21/2008 letter from M. Tein announcing plan to stay the civil suits 
against J. Epstein and notification that B. Reinhart is counsel of record 
for S. 
in civil suits 
(NB: Tein letter is being produced to petitioners' counsel concurrently 
with production of this privilege log) 
Work Product 
Attorney-Client Privilege 
Deliberative Process 
Page 4 of 7 
EFTA00185453

Case 9:08-cv-80736-KAM Document 338-1 Entered on FLSD Docket 08/03/2015 Page 5 of 7 
Bates Range 
Desii 
Privilege(s) Asserted 
P-015091 
thru 
.ion 
7/22/2008 emails between 
. 
r 
and E. 
Attorney-Client Privilege 
6(e) 
regarding ongoing victim notification process 
P-015092 
Investigative Privilege 
Privacy Act/TVPA/CVRA 
P-015093 
7/22/2008 emails between 
, E. 
Attorney-Client Privilege 
thru 
, 
and 
regarding correspondence 
M
inn 
Work Product 
P-015097 
J. Epstein counsel with attached draft response 
6(e) 
: A final version of the letter has been .roduced.) 
Deliberative Process
P-015098 
. 
7/23/2008 ernails between 
and 
regarding 
Work Product 
correspondence with counsel for J. Epstein and notice of breach 
Deliberative Process 
6(e) 
P-015099 
7/25/2008 emails between 
and 
regarding 
6(e) 
extension of grand jury to allow for continued presentation of J. Epstein 
Work Product 
case 
Deliberative Process 
P-015100 
8/2/2008 email from 
to A. Acosta, 
and 
Work Product 
thru 
P-015116 
Mg 
summarizing status of Jane Doe 
United States 
litigation and requesting views on making certain disclosures to counsel 
for petitioners with attached pleading filed by petitioners (DE19) 
6(e) 
Deliberative Process 
(NB: Privilege is not being asserted for attachment. Attachment was 
prepared by petitioners and is not being produced because it is within 
theirsiSoyd and control.) 
P-015117 
8/5/2008 email from 
. IM 
to A. Acosta, 
. 
Work Product 
thru 
and 
regarding analysis of JeffiSstem agreement, with 
Deliberative Process 
P-015135 
attached 6/24/2008 email from 
. I
II to R. Black and J. 
Goldberger and attached Epstein agreement. 
(NB: Privilege is not being asserted for the two attachments. The 
6/24/2008 email will be produced to petitioners' counsel 
contemporaneously with the filing of this log, and the Agreement has 
previously been produced to petitioners pursuant to an earlier Court 
order.) 
Page 5 of 7 
EFTA00185454

Case 9:08-cv-80736-KAM Document 338-1 Entered on PLSD Docket 08/03/2015 Page 6 of 7 
Bates Range 
Description 
Privilege(s) Asserted 
P-015136 
thru 
P-015172 
8/13/2008-8/15/2008 emails between A. Acosta, 
Work Product 
Deliberative Process 
Attorney-Client Privilege 
and 
. 
regarding scope of Epstein 
agreement and correspondence and telephone conference with J. 
Lefkowitz 
(NB: Emails to and from J. Lefkowitz and R. Black have been 
produced to Petitioners' counsel) 
P-015173 
thru 
P-015186 
8/25/2008 emails between 
A 
A. Acosta, 
Work Product 
Deliberative Process 
Attorney-Client Privilege 
= 
and 
regarding letter received from J. 
Lefkowitz 
(NB: Lefkowitz letter has been produced to Petitioners' counsel 
P-015187 
thru 
P-015194 
O8-8/26/2008 emails between 
. 
A. Acosta, 
Work Product
Deliberative Process 
S 
and 
re draft response to J. Lefkowitz 
and draft amended victim notification letter 
(NB: Final version of letter to Lefkotiz and Black has been produced to 
Petitioners' counsels
P-015195 
thru 
P-015198 
9/2/2008 emails between 
. 
 
, and
Work Product 
Deliberative Process 
Attorney-Client Privilege 
regarding revised victim notification 
P-015199 
thru 
P-015206 
9/17/2008 emails between 
. 
A. Acosta, 
Work Product 
Deliberative Process 
Attorney-Client Privilege 
I= 
, and 
regarding efforts by Palm 
Beach Daily News to unseal NonProsecution Agreement that had been 
filed in state court 
(NB: Emails from Counsel for Daily News and from State Attorney's 
Office have been 'roduced to Petitioners' counsel 
P-015207 
thru 
P415213 
9/17/2008 email from 
I 
to A. Acosta, 
Work Product 
Deliberative Process 
Privacy Act/TVPA/CVRA 
= 
and 
regarding attached letters from J. 
Herman alleging that victim notifications violated Bar ethics rules 
(NB: Redacted versions of the letters have been produced to Petitioners' 
counsel) 
P-015214 
thru 
P-015226 
9/29/2008 correspondence to Florida Bar Ethics Counsel regarding 
victim notification letters and allegation of ethics violation for 
distribution of letters with attached proposed victim notification letters 
Work Product 
Relevance 
Florida Bar Privacy Rules 
Page 6 of 7 
EFTA00185455

Case 9:08-cv-80736-KAM Document 338-1 Entered on FLSD Docket 08/03/2015 Page 7 of 7 
Bates Range 
Description 
Privilege(s) Asserted 
P-015227 
thru 
P-015233 
10/18/2008-10/20/2008 emails between 
A. A 
Work Product 
Deliberative Process 
and.. 
regarding correspondence with 
discussing changes to understanding of portions of Non-Prosecution 
agreement and victim notifications 
P-015234 
thru 
P-015238 
11/4/2008 correspondence from Florida Bar Ethics Counsel regarding 
Florida Ethics Rules involved in distributing victim notification letters. 
Work Product 
Relevance 
Florida Bar Privacy Rules 
P-015239 
thru 
P-015263 
11/26/2008 emails between 
and 
Work Product 
Deliberative Process 
regarding email from R Black about work release 
(NB: Email from R. Black has been roduced to Petitioners' cou e 
P-015264 
thru 
P-015267 
12/4/2008 emails between E. 
and 
Attorney-Client Privilege 
Work Product 
Investigative Privilege 
Privacy Act/TVPAJCVRA 
regarding attempts to send victim notification letters overseas via Legal 
Attaches and unrelated Epstein financial issue 
Page 7 of 7 
EFTA00185456

L 
EFTA00185457

Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 1 of 57 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 9:08-cv-80736-KAM 
JANE DOE 1 AND JANE DOE 2, 
Petitioners, 
UNITED STATES, 
Respondent. 
JANE DOE 1 AND JANE DOE 2'S CONSOLIDATED STATEMENT OF UNDISPUTED 
MATERIAL FACTS AND MOTION FOR PARTIAL SUMMARY JUDGMENT WITH 
INCORPORATED MEMORANDUM OF LAW 
Jane Doe 1 and Jane Doe 2 (also referred to as "the victims"), by and through 
undersigned counsel, pursuant to Fed. R. Civ. P. 56 and Local Rule 56.1, move for summary 
judgment on the issue of the United States Government's violation of their rights under the 
Crime Victims' Rights Act (CVRA), where no genuine issue of material fact exists.' In support, 
they state: 
INTRODUCTION 
In 2004, Congress enacted the CVRA because it found that in case after case "victims, 
and their families, were ignored, cast aside, and 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 place for them." 150 CONG. REC. 7296 (2004) (statement of 
The Court previously granted the victims leave to file a 60-page motion for partial summary judgment. DE 327. 
EFTA00185458

Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 2 of 57 
Sen. Feinstein). In passing the CVRA, Congress mandated a series of rights for crime victims. 
Sadly, several years later, when the Government began handling this case, it did precisely what 
Congress thought it had forbidden. The Government deliberately kept crime victims "in the 
dark" so that it could enter into a plea arrangement designed to prevent the victims from raising 
any objection. In doing so, the Government refused to afford victims the rights they had been 
promised by Congress—particularly "the right to reasonable, accurate, and timely notice of any 
public court proceeding," "the reasonable right to confer with the attorney for the Government in 
the case," and "the right to be treated with fairness and with respect for the victim's dignity and 
privacy."2
The undisputed evidence begins in 2005, when the Palm Beach Police Department 
("PBPD") had identified numerous girls as victims of Jeffrey Epstein's sexual crimes. In 2006, 
the PBPD turned the case over to federal authorities for further investigation. As early as March 
15, 2007 and throughout the rest of the investigation, the United States Attorney's Office for the 
Southern District of Florida ("the Office") specifically identified several dozen girls whom it 
classified as "victims" under the CVRA. Once that identification was made, the Government 
was obligated to afford these victims certain rights under the CVRA—a fact of which the 
Government itself was well aware? Indeed, the Government provided notification to the girls 
that they were classified as "victims" under the CVRA. 
But what the Government did not tell the victims lies at the heart of the case. It is 
undisputed that the Government did not tell the victims that, by May 2007, the Office had 
2 18 U.S.C. § 3771(aX2), (4)-(5), (8); RFP MIA 000001-000006 (Exhibit 1). 
3 000966-000967 (Exhibit 2); 000589-000591 (Exhibit 3); US_Atty_Cor 00135 (Exhibit 4); RFP MIA 000222 
(Exhibit 5). 
2 
EFTA00185459

Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 3 of 57 
prepared an 82-page prosecution memorandum and a 53-page indictment against Epstein and his 
co-conspirators! At that time, rather than confer with the victims about how to proceed, the 
Government began conferring about this issue exclusively with Epstein's counsel. Epstein's 
counsel contended that, despite abundant connection to interstate commerce, Epstein's sex 
trafficking was purely of local concern. By August 2007, federal prosecutors had disproven or 
rejected these defense arguments and notified the defense that all of the identified victims 
retained federal rights. 
For example, during August 2007, Jane Doe I, and other similarly situated victims, 
provided details to federal agents of the abuse that they endured at the hands of Epstein and his 
co-conspirators. In September 2007, without conferring with any of the victims, the Government 
and Epstein shifted gears and began working together to concoct a criminal charge for Epstein to 
plea to other than his sexual abuse of minors. As alternative charges, they discussed charging 
Epstein with: (I) various misdemeanors, (2) assaulting his co-conspirators and girlfriend, (3) 
using private investigators to chase and harass victims' families, (4) obstructions of grand jury 
subpoenas, or (5) his obstruction of the federal investigation when he instructed another co-
conspirator to lie to federal agents.5 Ultimately, however, none of those would work. Assistant 
U.S. Attorney ("AUSA") 
(the "line prosecutor") informed Epstein's counsel that 
she was getting pushback for creating a charge using one of the main co-conspirators as the 
RFP WPB 000286 (Exhibit 6). 
5 US_Atty_Cor 00030-00032 (Exhibit 7); RFP MIA 000129 (Exhibit 8); RFP MIA 000133 (Exhibit 9); RFP MIA 
000095 (Exhibit 10); RFP MIA 000075-000076 (Exhibit 11); RFP WPB 000220 (Exhibit 12); RFP MIA 000077-
000087 (Exhibit 13); RFP MIA 000088 (Exhibit 14); RFP WPB 000235.000244 (Exhibit 15); RFP WPB 000107-
000112 (Exhibit 16); RFP WPB 002188 (Exhibit 17); RFP WPB 000266-000277 (Exhibit 18); RFP MIA 000113 
(Exhibit 19); RFP MIA 000151-000160 (Exhibit 20); RFP MIA 000098-000105 (Exhibit 21). 
3 
EFTA00185460

Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 4 of 57 
victim .° Consequently, the Government and Epstein searched for another crime for Epstein to 
plead to, which could accompany a federal non-prosecution agreement (NPA). Incredibly, the 
offense to which Epstein and the Government ultimately agreed, labeled the minor victims 
"prostitutes." 
The undisputed evidence clearly shows that by September 21, 2007, the line prosecutor 
had informed Palm Beach State Attorney 
that a federal resolution had been 
reached by way of a NPA, yet the victims remained uninformed? On September 24, 2007, the 
NPA was signed, preventing prosecution of all federal crimes committed by Epstein and his co-
conspirators against the victims. After the signing of the NPA, the Government and Epstein's 
attorneys worked together to choose a lawyer to be paid by Epstein to represent Epstein's victims 
for the purpose of settling civil restitution claims. This too was all being done without the 
victims having any knowledge whatsoever. The correspondence between the Government and a 
candidate for that representative position as well as between the Government and Epstein's 
counsel reflects that the Government still had not yet disclosed the NPA to the victims, and was 
following the guidance of Epstein's counsel in making decisions with respect to the timing and 
substance of any communication to the victims.8
For the next nine months, from the time the NPA was signed through the date of 
Epstein's state court plea in June of 2008, the Office—doing Epstein's bidding—assiduously 
concealed the NPA's existence from the victims. While this indulgent deal was incredible in its 
own right, even more extraordinary was how the victims were treated during the process. Rather 
6 Exhibit 15. 
RFP WPB 002125 (Exhibit 22). 
3 See e.g., USAttyCor 00166 (Exhibit 23). 
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than confer with the victims about the fact that resolution by NPA was ever being considered—
or even tell them that it was already a signed deal—the Office and Epstein inserted a 
"confidentiality" provision into the agreement barring its disclosure to anyone, including the 
victims. There is no dispute that the Government did not inform the victims of the NPA or of the 
possibility of any such type of resolution. Consequently, there is no dispute that the Government 
did not afford the victims any rights before the signing of the NPA. 
In October 2007, after the NPA was signed, federal agents spoke with three of the more 
than 30 identified victims, including Jane Doe 19 The Government does not dispute that this 
contact only occurred after the signing of the NPA. Even more important, it is not disputed that 
this contact was: 1) made by the Federal Bureau of Investigation ("FBI") and not a "prosecutor 
for the Government," 2) that the FBI did not inform the victims of the NPA and certainly did not 
confer with the victims about the details of the NPA, and 3) that this contact only occurred with 
three of the more than 30 victims. Lastly, while the content of that conversation is contested, any 
stretched argument that the conversation satisfied CVRA requirements for Jane Doe 1 are belied 
by the timing of the conversation as well as the uncontested documentary evidence of the 
communications with the victims (including with Jane Doe 1) that followed that conversation. 
Subsequent to the FBI's contact with three of Epstein's victims, the Government 
informed Epstein's attorneys that victim notification letters needed to be sent to all the victims 
pursuant to the CVRA. Rather than comply with this acknowledged requirement, Epstein's 
counsel convinced the Government that (contrary to standard Government practice) Epstein 
9 RIP MIA 000464-000468 (Exhibit 24). 
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should be permitted to provide input into any message being delivered, and ultimately that the 
victims should not be told anything "until after Epstein pleas."10
In January 2008, FBI agents again met with Jane Doe I and gathered additional details 
about Epstein's abuse as well as the direct sexual abuse by one of his co-conspirators, 
who participated in the abuse of other victims as well. The Government then sent 
a victim notification letter to Jane Doe 1 informing her of her rights under the CVRA, that "this 
will be a long investigation," and to "be patient."" Jane Doe I was sent a similar letter on June 
7, 2008.12 Other victims were also sent these letters communicating that the Epstein case was an 
on-going active criminal investigation—not that the Government had already immunized Epstein 
for all federal crimes committed against each of the victims, through a NPA. These misleading 
letters were sent almost up until the date of Epstein's state court plea in late June 2008.13
On June 30, 2008, Epstein pled guilty to state court charges. It is uncontested that the 
victims were not reasonably and accurately informed about that hearing—specifically, they were 
never told the hearing was part of a process that would extinguish any possibility of Epstein 
being prosecuted for the crimes he had committed against them in Florida. Even after the plea, 
the Government once again conferred with Epstein's attorneys to decide what to tell the victims. 
As the Court is aware, this CVRA action was filed in July 2008 at a time when the 
victims mistakenly believed that the federal case remained open, and wanted to ensure that their 
rights under the CVRA were afforded before any possible federal disposition. At the emergency 
RFP WPB 001978-001979 (Exhibit 25). 
H Declaration of Jane Doe I (Exhibit 26); Declaration of Jane Doe 2 (Exhibit 27). 
12 000978-000989 (Exhibit 28). 
o [DE 48) Exhibit I (Exhibit 29). 
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hearing on the Petition for Enforcement of Crime Victims' Rights Act, Jane Doe I and Jane Doe 
2 were in the courtroom to learn for the first time that the federal case had been resolved. 
The undisputed facts show that for nine months, the Government and Epstein conspired 
to conceal the NPA from the victims to prevent them from voicing any objection, and to avoid 
the firestorm of controversy that would have arisen if it had become known that the Government 
was immunizing a politically-connected billionaire and all of his co-conspirators from 
prosecution of hundreds of federal sex crimes against minor girls. Such facts demonstrate clear 
violations of the CVRA's requirements that the Government afford victims the reasonable right 
to confer, the right to be treated with fairness, and the right to reasonable and accurate notice 
about court hearings. No genuine issue of material fact or law can exist on these points. The 
Court should accordingly grant summary judgment for the victims on the issue of the CVRA 
violations and then, in subsequent proceedings, turn to the issue of the proper remedy for those 
violations. 
STATEMENT OF UNDISPUTED MATERIAL FACTS 
Pursuant to Local Rule 56.1, the victims submit this statement of undisputed material 
facts in support of their motion for partial summary judgment:14
I' In an effort to streamline their case and bring it to a more rapid resolution, in this summary judgment motion the 
victims present only some of the evidence that they are prepared to produce at any evidentiary hearing in this matter. 
For instance, the victims have concentrated on the emails and other documents establishing violations of their rights, 
largely avoiding issues of the Government's "motive" for the violations and other related issues. Because of the 
possibility that the Court may not grant summary judgment on this narrower approach, the victims are continuing to 
pursue discovery with regard to motive and several other important issues that would come into play at a broader 
evidentiary hearing. See, e.g., [DE 344] (victims' motion for deposition of government witnesses). The victims 
reserve the right to supplement this motion if additional discovery is received through these discovery efforts and to 
present these broader issues at any evidentiary hearing or remedy phase of these proceedings. 
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EPSTEIN'S CRIMES 
I. Between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor 
girls, including Jane Doe I and Jane Doe 2, at his mansion in Palm Beach, Florida, located in the 
Southern District of Florida, and elsewhere in the United States and overseas.15
2. Because Epstein and his co-conspirators knowingly traveled in interstate and 
international commerce to sexually abuse Jane Doe 1, Jane Doe 2, and other similarly situated 
victims, they committed violations of not only Florida law (see, e,g., Fla. Stat. §§ 794.05, 796.04, 
796.045, 39.201 & 777.04), but also federal law, including repeated violations of 18 U.S.C. §§ 
1591, 2421, 2422, 2423, & 371).16
EPSTEIN'S VICTIMS 
3. In addition to personally abusing his victims, Epstein also directed other persons to 
sexually abuse the girls. For example, 
sexually abused Jane Doe 1 and other 
victims at the direction of Epstein.I7
IS See, e.g., Exhibit 26; Exhibit 27; Jane Doe 102 
Epstein Complaint (Exhibit 30); Response to Request for 
Admission #1 (Exhibit 31) (admitting federal investigation); FBI 302 of Interview with Jane Doe 1 on August 14, 
2007 (Exhibit 32); FBI 302 of Interview with Jane Doe 1 on January 31, 2008 (Exhibit 33); Palm Beach Police 
Report (Exhibit 34) (discussing investigation of numerous Epstein victims); Exhibit 6 (nagt 82-page prosecution 
memo and 52-page prepared indictment); [DE 304] Declaration of FBI Special Agent NM (Exhibit 35) (notin
that the FBI identified many potential victims of sexual abuse by Epstein); The People of the State of New York I. 
Jeffrey Epstein (Exhibit 36); RFP WPB 000550.000554 (Exhibit 37) (listing 31 victims the that U.S. Attorney's 
Office was prepared to name as a victim of an enumerated federal offense); Sora Hearing Transcript (Exhibit 38); 
RFP MIA 000361-000365 (Exhibit 39) (Chief of Child Exploitation Section of the Justice Department concluding 
after review of the facts that U.S. Attorney's would not abuse its discretion in prosecuting; noting "multiple 
mutually-corroborating witnesses," the Epstein case "consistent in principle with other federal prosecutions 
nationwide"). 
16 See note 14, supra. 
" See Exhibit 32; Exhibit 33; Exhibit 34. 
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