EFTA00206173

From: 
(SMO) 
Sent: Saturda February 26, 2011 4:19 PM 
To: 
(USAFLS); 
Cc: 
. (USAFLS); 
(USAFLS); 
Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
USAEO 
I agree completely. Let's try and talk Monday, with 
on the phone if possible. 
From: 
Sent: Saturda 
To: 
Cc: 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
(USAFLS) 
February 26, 2011 04:08 PM 
SMO); 
. (USAFLS); 
USAEO 
. (USAFLS) 
(USAFLS); 
. (USAFLS) 
Mr. 
I'm looking for the appropriate officials in the Department with programmatic responsibility for the 
CVRA, so that we may obtain guidance on our litigating position. 
What Cassell wants the 
government to do is abdicate its role in defending its actions. If the DOJ's position is that no rights 
attach until a charging instrument is filed, then we should vigorously defend that position. Our office is 
most reluctant to do what Cassell asks, since negotiating the non-prosecution agreement was clearly 
within the prerogatives granted to the Executive Branch. 
Whether the bargain struck with Epstein 
was wise or not should not be the issue. 
I will be in the office all day Monday. Thanks for your assistance. 
From: 
(SMO) 
Sent: Saturda February 26, 2011 3:40 PM 
To: 
(USAFLS); 
Cc: 
. (USAFLS); 
(USAFLS) 
Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
USAEO 
Thanks. Perhaps we should try and find a time to talk on Monday. This scenario raises a 
variety of policy issues that extend well beyond the question of "when do the rights attach." Frankly, I 
don't think the court should even reach that question given the posture of the case as you describe it. 
EFTA00206253

From: 
Sent: Saturda 
To: 
Cc: 
Subject: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
(USAFLS) 
February 26, 2011 02:23 PM 
SMO); 
. (USAFLS); 
USAEO 
(USAFLS) 
Ms. 
and Mr. 
Our office is currently litigating a Crime Victims Rights Act (CVRA) lawsuit filed by Jane Does 1 and 2, 
who were victims of sexual abuse by Jeffrey Epstein, a multi-millionaire investor living in Palm Beach, 
Florida. 
Jane Does 1 and 2 v. United States Case No. 08-80736-CIV-MARRA (S.D.Fla.). We are 
seeking your advice and guidance on a proposal from the victims' attorneys, that the government take 
no position on whether the CVRA granted rights to the victims, when the U.S. Attorney's Office 
negotiated a non-prosecution agreement with Epstein. 
In 2006, the Palm Beach Police Department began investigating allegations that Jeffrey Epstein was 
enticing underage girls into prostitution. 
Epstein was alleged to have paid underage girls to provide 
him with massages, while the young girls were unclothed. 
The case was referred to the FBI and 
U.S. Attorney's Office, and the FBI began its own investigation. 
Epstein hired a number of highly-
paid attorneys, including Alan Dershowitz and Kenneth Starr, to attempt to stave off criminal charges. 
Ultimately, in 2007, Epstein was charged in state court with soliciting minors for prostitution. 
In 
September 2007, the U.S. Attorney's Office entered into a Non-Prosecution Agreement with Epstein, in 
which he agreed to plead guilty to the state criminal charge, and serve a sentence of 18 months. 
Epstein also agreed that, in any civil action under 18 U.S.C. 2255 by the underage victims, he would 
not raise the lack of a federal sex offense as a defense. 
In July 2008, Epstein plead guilty, and 
was sentenced to serve six months at the Palm Beach County Detention Facility, followed by 12 
months in home detention. 
In July 2008, after the Non-Prosecution Agreement had been executed, two victims, 
and • 
filed 
an action under the CVRA, 18 U.S.C. 3771. 
They claimed that the government was obligated, under 
18 U.S.C. 3771(a)(5), to speak with the victims prior to the execution of the Non-Prosecution 
Agreement. 
An emergency hearing was held on July 11, 2008, before U.S. District Judge Kenneth 
Marra. 
Since Epstein had entered his state court plea and been sentenced already, the court found 
there was no emergency. He directed the parties to meet and determine if there were any factual 
disputes and whether an evidentiary hearing would be necessary. 
Attorney Brad Edwards initially represented the victims. 
Soon, he was joined by Paul Cassell, a 
University of Utah law professor, and former federal judge who served in the District of Utah from 
2002-2007. Cassell is a victims' rights advocate who has appeared in many cases throughout the 
United States. 
The victims' rights suit was inactive for the next two years, with Edwards and Cassell 
using the civil suit as a means to attempt to gain access to information helpful in their civil actions for 
damages against Epstein. 
They were able to obtain a copy of the Non-Prosecution Agreement 
through the civil litigation. 
In August 2010, the district court, noting that the last civil suit had been settled, entered an order 
closing the case. 
Edwards and Cassell immediately filed documents with the court, advising that the 
case should not be closed or dismissed, and they wanted to pursue final action by the court. 
Since 
September 2010, AUSA 
and I have been dealing with Cassell and Edwards on how to 
resolve the case. 
They claim the victims had a right to be consulted prior to the execution of the 
Non-Prosecution Agreement, and that we violated the CVRA by not consulting them. 
The remedy 
they seek is a set aside by the court of the Non-Prosecution Agreement, and a prosecution of Epstein. 
EFTA00206254

On December 10, 2010, United States Attorney Wifredo A. M, 
, and I, met with Cassell, Edwards, and M, one of the victims. 
We discussed the 
posture of the case, and 
told us her views of what occurred and her desire to see Epstein receive 
justice for what he did. Cassell presented U.S. Attorney 
a four-page letter, requesting an 
investigation of the Jeffrey Epstein prosecution. He claims there may have been improper influence 
exercising by Epstein, noting that Epstein is a "politically-connected billionaire." 
Cassell cites to an 
alleged ti off to E stein that a search warrant on his residence was to be executed; that a former 
AUSA, 
, left the West Palm Beach office and soon began appearing on behalf of 
individuals aligned with Epstein; and an unprecedented level of secrecy between the FBI and the U.S. 
Attorney's Office, where the FBI was purportedly kept in the dark about the impending Non-
Prosecution Agreement. 
He also claims that the victims were deceived regarding the existence of 
the Non-Prosecution Agreement. 
Cassell's request for an investigation was referred to DOJ OPR on December 16, 2010. 
has requested various documents from our office, presumably to determine whether an 
investigation should be opened. 
Cassell and Edwards had planned to file a motion for summary 
judgment on December 17, 2010. Due to concerns that the U.S. Attorney's Office might have to be 
recused, due to the allegations of misconduct, Cassell agreed to defer filing their motion. 
We have 
since been advised by EOUSA General Counsel's Office that there is no need for our office to recuse 
itself, since we are only litigating the legal issue of whether rights under the CVRA attached. 
After the new year began, Cassell inquired about the status of the OPR complaint and the recusal 
issue. 
On Thursday, February 10, 2011, Deputy Chief 
AUSA 
and I spoke 
with Cassell and Edwards regarding the status of the case. I told them Cassell's letter request for an 
investigation of the Non-Prosecution Agreement had been referred to OPR, and OPR had requested 
various documents from our office. 
I also told them the EOUSA General Counsel's office advised 
that our office could go ahead and represent the United States in the CVRA lawsuit. I suggested that 
the parties were ready to move forward with filing documents with the court so it could resolve this 
case. 
I asked whether it might be useful to engage in mediation in an attempt to resolve the case. 
Cassell 
told us they wanted the Non-Prosecution Agreement to be set aside. 
I told him that was not likely to 
happen. Cassell then suggested that the United States Government should step aside and allow 
them to "go after" Epstein to get the agreement set aside. 
I asked him how he expected that would 
be done, since the only parties to the Non-Prosecution Agreement were Epstein and the 
Government. 
Cassell said they would file their summary judgment motion, and the government 
would take no position on their motion. Presumably, Epstein would either intervene, or be brought in 
as a necessary party, and defend the Non-Prosecution Agreement. 
I told them this would have to be 
approved by the U.S. Attorney and Main Justice. 
I have serious misgivings about not defending the Executive Branch's prerogative to engage in a Non-
Prosecution Agreement, free from supervision or oversight by the judiciary. 
If we stand by the 
sidelines, Cassell will be arguing the Government was obligated to consult with the victims, and 
because we failed to do so, the agreement is a nullity. 
Whatever we may think of the Agreement, it 
was the prerogative of the U.S. Attorney's Office to enter into it with Epstein, and we should be willing 
to defend what we did. The DOJ's position is that the rights in the CVRA do not attach until there is a 
federal court proceeding. 
Since Epstein was never charged in federal court, we were not obligated 
to consult with the victims before entering into the Non-Prosecution Agreement. 
We wanted to seek your views on Cassell's suggestion before we responded to him. We are currently 
scheduled to have a conference call with Cassell and Edwards on Tuesday, March 1. I can be 
EFTA00206255

reached at 
. Thanks. 
• 
From: 
Sent: 
To: 
Cc: 
Subject: 
(SMO) < 
Saturday, February 26, 2011 3:40 PM 
(USAFLS); 
(USAFLS); 
(USAFLS) 
Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
(USAEO) 
Thanks. Perhaps we should try and find a time to talk on Monday. This scenario raises a 
variety of policy issues that extend well beyond the question of "when do the rights attach." Frankly, I 
don't think the court should even reach that question given the posture of the case as you describe it. 
From: 
Sent: Saturda 
To: 
Cc: 
Subject: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
(USAFLS) 
February 26, 2011 02:23 PM 
SMO); 
. (USAFLS); 
USAEO 
(USAFLS) 
Ms. 
and Mr. =, 
Our office is currently litigating a Crime Victims Rights Act (CVRA) lawsuit filed by Jane Does 1 and 2, who were 
victims of sexual abuse by Jeffrey Epstein, a multi-millionaire investor living in Palm Beach, Florida. Jane Does 
1 and 2 v. United States Case No. 08-80736-CIV-MARRA (S.D.Fla.). We are seeking your advice and guidance 
on a proposal from the victims' attorneys, that the government take no position on whether the CVRA granted 
rights to the victims, when the U.S. Attorney's Office negotiated a non-prosecution agreement with Epstein. 
In 2006, the Palm Beach Police Department began investigating allegations that Jeffrey Epstein was enticing 
underage girls into prostitution. 
Epstein was alleged to have paid underage girls to provide him with 
massages, while the young girls were unclothed. 
The case was referred to the FBI and U.S. Attorney's Office, 
and the FBI began its own investigation. 
Epstein hired a number of highly-paid attorneys, including Alan 
Dershowitz and Kenneth Starr, to attempt to stave off criminal charges. 
Ultimately, in 2007, Epstein was charged in state court with soliciting minors for prostitution. 
In September 
2007, the U.S. Attorney's Office entered into a Non-Prosecution Agreement with Epstein, in which he agreed to 
plead guilty to the state criminal charge, and serve a sentence of 18 months. Epstein also agreed that, in any 
civil action under 18 U.S.C. 2255 by the underage victims, he would not raise the lack of a federal sex offense as 
a defense. 
In July 2008, Epstein plead guilty, and was sentenced to serve six months at the Palm Beach 
County Detention Facility, followed by 12 months in home detention. 
In July 2008, after the Non-Prosecution Agreement had been executed, two victims, Nand 
filed an action 
under the CVRA, 18 U.S.C. 3771. 
They claimed that the government was obligated, under 18 U.S.C. 3771(a) 
(5), to speak with the victims prior to the execution of the Non-Prosecution Agreement. 
An emergency 
hearing was held on July 11, 2008, before U.S. District Judge Kenneth Marra. 
Since Epstein had entered his 
EFTA00206256

state court plea and been sentenced already, the court found there was no emergency. He directed the 
parties to meet and determine if there were any factual disputes and whether an evidentiary hearing would be 
necessary. 
Attorney Brad Edwards initially represented the victims. Soon, he was joined by Paul Cassell, a University of 
Utah law professor, and former federal judge who served in the District of Utah from 2002-2007. Cassell is a 
victims' rights advocate who has appeared in many cases throughout the United States. 
The victims' rights 
suit was inactive for the next two years, with Edwards and Cassell using the civil suit as a means to attempt to 
gain access to information helpful in their civil actions for damages against Epstein. 
They were able to obtain 
a copy of the Non-Prosecution Agreement through the civil litigation. 
In August 2010, the district court, noting that the last civil suit had been settled, entered an order closing the 
case. 
Edwards and Cassell immediately filed documents with the court, advising that the case should not be 
closed or dismissed, and they wanted to pursue final action by the court. 
Since September 2010, AUSA 
and I have been dealing with Cassell and Edwards on how to resolve the case. 
They claim the victims 
had a right to be consulted prior to the execution of the Non-Prosecution Agreement, and that we violated the 
CVRA by not consulting them. The remedy they seek is a set aside by the court of the Non-Prosecution 
Agreement, and a prosecution of Epstein. 
On December 10, 2010, United States Attorney Wifredo A. 
and I, met with Cassell, Edwards, and S 
one of the victims. 
We discussed the posture of the 
case, and 
told us her views of what occurred and her desire to see Epstein receive justice for what he did. 
Cassell presented U.S. Attorney 
a four-page letter, requesting an investigation of the Jeffrey Epstein 
prosecution. He claims there may have been improper influence exercising by Epstein, noting that Epstein is a 
"politically-connected billionaire." 
Cassell cites to an alleged tip off to Epstein that a search warrant on his 
residence was to be executed; that a former AUSA, 
left the West Palm Beach office and soon 
began appearing on behalf of individuals aligned with Epstein; and an unprecedented level of secrecy between 
the FBI and the U.S. Attorney's Office, where the FBI was purportedly kept in the dark about the impending 
Non-Prosecution Agreement. He also claims that the victims were deceived regarding the existence of the 
Non-Prosecution Agreement. 
Cassell's request for an investigation was referred to DOJ OPR on December 16, 2010. 
has 
requested various documents from our office, presumably to determine whether an investigation should be 
opened. 
Cassell and Edwards had planned to file a motion for summary judgment on December 17, 2010. 
Due to concerns that the U.S. Attorney's Office might have to be recused, due to the allegations of misconduct, 
Cassell agreed to defer filing their motion. 
We have since been advised by EOUSA General Counsel's Office 
that there is no need for our office to recuse itself, since we are only litigating the legal issue of whether rights 
under the CVRA attached. 
After the new year began, Cassell inquired about the status of the OPR complaint and the recusal issue. 
On Thursday, February 10, 2011, Deputy Chief 
AUSA 
and I spoke with Cassell 
and Edwards regarding the status of the case. I told them Cassell's letter request for an investigation of the 
Non-Prosecution Agreement had been referred to OPR, and OPR had requested various documents from our 
office. 
I also told them the EOUSA General Counsel's office advised that our office could go ahead and 
represent the United States in the CVRA lawsuit. I suggested that the parties were ready to move forward with 
filing documents with the court so it could resolve this case. 
EFTA00206257

I asked whether it might be useful to engage in mediation in an attempt to resolve the case. Cassell told us 
they wanted the Non-Prosecution Agreement to be set aside. I told him that was not likely to happen. 
Cassell then suggested that the United States Government should step aside and allow them to "go after" 
Epstein to get the agreement set aside. 
I asked him how he expected that would be done, since the only 
parties to the Non-Prosecution Agreement were Epstein and the Government. 
Cassell said they would file 
their summary judgment motion, and the government would take no position on their motion. Presumably, 
Epstein would either intervene, or be brought in as a necessary party, and defend the Non-Prosecution 
Agreement. I told them this would have to be approved by the U.S. Attorney and Main Justice. 
I have serious misgivings about not defending the Executive Branch's prerogative to engage in a Non-
Prosecution Agreement, free from supervision or oversight by the judiciary. If we stand by the sidelines, 
Cassell will be arguing the Government was obligated to consult with the victims, and because we failed to do 
so, the agreement is a nullity. Whatever we may think of the Agreement, it was the prerogative of the U.S. 
Attorney's Office to enter into it with Epstein, and we should be willing to defend what we did. The DOJ's 
position is that the rights in the CVRA do not attach until there is a federal court proceeding. 
Since Epstein 
was never charged in federal court, we were not obligated to consult with the victims before entering into the 
Non-Prosecution Agreement. 
We wanted to seek your views on Cassell's suggestion before we responded to him. We are currently 
scheduled to have a conference call with Cassell and Edwards on Tuesday, March 1. I can be reached at 
. Thanks. 
From: 
(USAFLS) < 
Sent: 
Saturday, February 26, 2011 4:08 PM 
To: 
. (OLP) (JMD); 
(USAEO) 
Cc: 
(USAFLS); 
(USAFLS); 
(USAFLS) 
Subject: 
RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.FIa.) 
Mr. 
I'm looking for the appropriate officials in the Department with programmatic responsibility for the 
CVRA, so that we may obtain guidance on our litigating position. 
What Cassell wants the 
government to do is abdicate its role in defending its actions. If the DOJ's position is that no rights 
attach until a charging instrument is filed, then we should vigorously defend that position. Our office is 
most reluctant to do what Cassell asks, since negotiating the non-prosecution agreement was clearly 
within the prerogatives granted to the Executive Branch. 
Whether the bargain struck with Epstein 
was wise or not should not be the issue. 
I will be in the office all day Monday. Thanks for your assistance. 
EFTA00206258

From: 
Sent: Saturda 
To: 
Cc: 
. (USAFLS); 
(USAFLS) 
Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
(SMO) 
February 26, 2011 3:40 PM 
USAFLS); 
USAEO 
Thanks. Perhaps we should try and find a time to talk on Monday. This scenario raises a 
variety of policy issues that extend well beyond the question of "when do the rights attach." Frankly, I 
don't think the court should even reach that question given the posture of the case as you describe it. 
From: 
Sent: Saturda 
To: 
Cc: 
Subject: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
(USAFLS) 
February 26, 2011 02:23 PM 
SMO); 
. (USAFLS); 
USAEO 
(USAFLS) 
Ms. 
and Mr. 
Our office is currently litigating a Crime Victims Rights Act (CVRA) lawsuit filed by Jane Does 1 and 2, 
who were victims of sexual abuse by Jeffrey Epstein, a multi-millionaire investor living in Palm Beach, 
Florida. 
Jane Does 1 and 2 v. United States Case No. 08-80736-CIV-MARRA (S.D.Fla.). We are 
seeking your advice and guidance on a proposal from the victims' attorneys, that the government take 
no position on whether the CVRA granted rights to the victims, when the U.S. Attorney's Office 
negotiated a non-prosecution agreement with Epstein. 
In 2006, the Palm Beach Police Department began investigating allegations that Jeffrey Epstein was 
enticing underage girls into prostitution. 
Epstein was alleged to have paid underage girls to provide 
him with massages, while the young girls were unclothed. 
The case was referred to the FBI and 
U.S. Attorney's Office, and the FBI began its own investigation. 
Epstein hired a number of highly-
paid attorneys, including Alan Dershowitz and Kenneth Starr, to attempt to stave off criminal charges. 
Ultimately, in 2007, Epstein was charged in state court with soliciting minors for prostitution. 
In 
September 2007, the U.S. Attorney's Office entered into a Non-Prosecution Agreement with Epstein, in 
which he agreed to plead guilty to the state criminal charge, and serve a sentence of 18 months. 
Epstein also agreed that, in any civil action under 18 U.S.C. 2255 by the underage victims, he would 
not raise the lack of a federal sex offense as a defense. 
In July 2008, Epstein plead guilty, and 
was sentenced to serve six months at the Palm Beach County Detention Facility, followed by 12 
months in home detention. 
In July 2008, after the Non-Prosecution Agreement had been executed, two victims, 
and • 
filed 
an action under the CVRA, 18 U.S.C. 3771. 
They claimed that the government was obligated, under 
18 U.S.C. 3771(a)(5), to speak with the victims prior to the execution of the Non-Prosecution 
Agreement. 
An emergency hearing was held on July 11, 2008, before U.S. District Judge Kenneth 
Marra. 
Since Epstein had entered his state court plea and been sentenced already, the court found 
EFTA00206259

there was no emergency. He directed the parties to meet and determine if there were any factual 
disputes and whether an evidentiary hearing would be necessary. 
Attorney Brad Edwards initially represented the victims. 
Soon, he was joined by Paul Cassell, a 
University of Utah law professor, and former federal judge who served in the District of Utah from 
2002-2007. Cassell is a victims' rights advocate who has appeared in many cases throughout the 
United States. 
The victims' rights suit was inactive for the next two years, with Edwards and Cassell 
using the civil suit as a means to attempt to gain access to information helpful in their civil actions for 
damages against Epstein. 
They were able to obtain a copy of the Non-Prosecution Agreement 
through the civil litigation. 
In August 2010, the district court, noting that the last civil suit had been settled, entered an order 
closing the case. 
Edwards and Cassell immediately filed documents with the court, advising that the 
case should not be closed or dismissed, and they wanted to pursue final action by the court. 
Since 
September 2010, AUSA 
and I have been dealing with Cassell and Edwards on how to 
resolve the case. 
They claim the victims had a right to be consulted prior to the execution of the 
Non-Prosecution Agreement, and that we violated the CVRA by not consulting them. 
The remedy 
they seek is a set aside by the court of the Non-Prosecution Agreement, and a prosecution of Epstein. 
On December 10, 2010, United States Attorney Wifredo A. M, 
, and I, met with Cassell, Edwards, and M, one of the victims. 
We discussed the 
posture of the case, and 
told us her views of what occurred and her desire to see Epstein receive 
justice for what he did. Cassell presented U.S. Attorney 
a four-page letter, requesting an 
investigation of the Jeffrey Epstein prosecution. He claims there may have been improper influence 
exercising by Epstein, noting that Epstein is a "politically-connected billionaire." 
Cassell cites to an 
alleged ti off to E stein that a search warrant on his residence was to be executed; that a former 
AUSA, 
, left the West Palm Beach office and soon began appearing on behalf of 
individuals aligned with Epstein; and an unprecedented level of secrecy between the FBI and the U.S. 
Attorney's Office, where the FBI was purportedly kept in the dark about the impending Non-
Prosecution Agreement. 
He also claims that the victims were deceived regarding the existence of 
the Non-Prosecution Agreement. 
Cassell's request for an investigation was referred to DOJ OPR on December 16, 2010. 
has requested various documents from our office, presumably to determine whether an 
investigation should be opened. 
Cassell and Edwards had planned to file a motion for summary 
judgment on December 17, 2010. Due to concerns that the U.S. Attorney's Office might have to be 
recused, due to the allegations of misconduct, Cassell agreed to defer filing their motion. 
We have 
since been advised by EOUSA General Counsel's Office that there is no need for our office to recuse 
itself, since we are only litigating the legal issue of whether rights under the CVRA attached. 
After the new year began, Cassell inquired about the status of the OPR complaint and the recusal 
issue. 
On Thursday, February 10, 2011, Deputy Chief 
AUSA 
and I spoke 
with Cassell and Edwards regarding the status of the case. I told them Cassell's letter request for an 
investigation of the Non-Prosecution Agreement had been referred to OPR, and OPR had requested 
various documents from our office. 
I also told them the EOUSA General Counsel's office advised 
that our office could go ahead and represent the United States in the CVRA lawsuit. I suggested that 
the parties were ready to move forward with filing documents with the court so it could resolve this 
case. 
I asked whether it might be useful to engage in mediation in an attempt to resolve the case. 
Cassell 
told us they wanted the Non-Prosecution Agreement to be set aside. 
I told him that was not likely to 
happen. Cassell then suggested that the United States Government should step aside and allow 
EFTA00206260

them to "go after" Epstein to get the agreement set aside. 
I asked him how he expected that would 
be done, since the only parties to the Non-Prosecution Agreement were Epstein and the 
Government. 
Cassell said they would file their summary judgment motion, and the government 
would take no position on their motion. Presumably, Epstein would either intervene, or be brought in 
as a necessary party, and defend the Non-Prosecution Agreement. 
I told them this would have to be 
approved by the U.S. Attorney and Main Justice. 
I have serious misgivings about not defending the Executive Branch's prerogative to engage in a Non-
Prosecution Agreement, free from supervision or oversight by the judiciary. 
If we stand by the 
sidelines, Cassell will be arguing the Government was obligated to consult with the victims, and 
because we failed to do so, the agreement is a nullity. 
Whatever we may think of the Agreement, it 
was the prerogative of the U.S. Attorney's Office to enter into it with Epstein, and we should be willing 
to defend what we did. The DOJ's position is that the rights in the CVRA do not attach until there is a 
federal court proceeding. 
Since Epstein was never charged in federal court, we were not obligated 
to consult with the victims before entering into the Non-Prosecution Agreement. 
We wanted to seek your views on Cassell's suggestion before we responded to him. We are currently 
scheduled to have a conference call with Cassell and Edwards on Tuesday, March 1. I can be 
reached at 
. Thanks. 
• 
-
-
-
-
-
-
-
-
From: 
(FBI) 
Sent: 
Monday, February 28, 2011 11:27 AM 
To: 
(USAFLS) 
Subject: 
Fw: Customs POC 
From: 
To: 
Sent: Mon Feb 28 11:16:59 2011 
Subject: Fw: Customs POC 
I talked to 
on Fri, they sent Subpoenas to the pilots. Not through FAA 
From: 
(USAFLS) < 
To: 
Cc: 
Sent: Thu Feb 24 13:03:22 2011 
Subject: RE: Customs POC 
Hi Luz — I have reached out to 
Can you talk with 
about how we got the 
flight plans/flight manifests for Epstein's planes in that case? I think that was done through the FAA. 
EFTA00206261

Thank you. 
Assistant U.S. Attorney 
Fax 
From: 
(FBI) 
Sent: Wednesday, February 23, 2011 4:19 PM 
To: 
 
 
 . (USAFLS) 
Subject: Customs POC 
The Point of Contact we have in our Miami office is: 
Investigative Operations Analyst 
FBI 
Palm Beach County RA 
EFTA00206262

(USAFLS) 
February 22, 2011 4:54 PM 
(USAFLS); 
(USAFLS) 
Subject: Sledgehammer Meeting Reminder 
Hi everyone — Just a quick reminder that we have our Master Meeting tomorrow at 2:00. 
The meeting will be in the 4ft" Floor Conference Room at the U.S. Attorney's Office, 
See you all there! 
Thank you. 
Assistant U.S. Attorney 
Fax 
From: 
(SMO) < 
Sent: 
Monday, February 28, 2011 9:07 AM 
To: 
(USAEO); 
(USAFLS) 
Cc: 
(USAFLS); 
(USAFLS); 
(USAFLS); 
(USAEO) 
Subject: 
RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.FIa.) 
EFTA00206263

: Can you set up a call? I have a 10:00 meeting (30 minutes), and an as yet unscheduled 
obligation to assist in briefing the AG for his testimony on the Hill tomorrow. Sometime between noon 
and 1 is likely to be best for me. 
(USAEO) 
February 28, 2011 8:43 AM 
SMO); 
USAFLS 
. (USAFLS); 
(USAFLS); 
(USAEO) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
I agree, as well. I am available anytime between noon and 3:00 today. 
From: 
(SMO) 
Sent: Saturda February 26, 2011 4:19 PM 
To: 
(USAFLS); 
Cc: 
. (USAFLS); 
(USAFLS); 
Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
USAEO 
I agree completely. Let's try and talk Monday, with 
on the phone if possible. 
From: 
(USAFLS) 
Sent: Saturda February 26, 2011 04:08 PM 
To: 
SMO); 
USAEO 
Cc: 
. (USAFLS); 
(USAFLS); 
Subject: RE: Jane Does 1 and 2I. United States - CVRA Lawsuit (S.D.Fla.) 
Mr. 
. (USAFLS); 
. (USAFLS) 
. (USAFLS) 
I'm looking for the appropriate officials in the Department with programmatic responsibility for the 
CVRA, so that we may obtain guidance on our litigating position. 
What Cassell wants the 
government to do is abdicate its role in defending its actions. If the DOJ's position is that no rights 
attach until a charging instrument is filed, then we should vigorously defend that position. Our office is 
most reluctant to do what Cassell asks, since negotiating the non-prosecution agreement was clearly 
within the prerogatives granted to the Executive Branch. 
Whether the bargain struck with Epstein 
was wise or not should not be the issue. 
I will be in the office all day Monday. Thanks for your assistance. 
EFTA00206264

From: 
Sent: Saturda 
To: 
Cc: 
. (USAFLS); 
(USAFLS) 
Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
(SMO) 
February 26, 2011 3:40 PM 
USAFLS ; 
USAEO 
Thanks. Perhaps we should try and find a time to talk on Monday. This scenario raises a 
variety of policy issues that extend well beyond the question of "when do the rights attach." Frankly, I 
don't think the court should even reach that question given the posture of the case as you describe it. 
From: 
Sent: Saturda 
To: 
Cc: 
Subject: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
(USAFLS) 
February 26, 2011 02:23 PM 
SMO); 
. (USAFLS); 
USAEO 
(USAFLS) 
Ms. 
and Mr. 
Our office is currently litigating a Crime Victims Rights Act (CVRA) lawsuit filed by Jane Does 1 and 2, 
who were victims of sexual abuse by Jeffrey Epstein, a multi-millionaire investor living in Palm Beach, 
Florida. 
Jane Does 1 and 2 v. United States Case No. 08-80736-CIV-MARRA (S.D.Fla.). We are 
seeking your advice and guidance on a proposal from the victims' attorneys, that the government take 
no position on whether the CVRA granted rights to the victims, when the U.S. Attorney's Office 
negotiated a non-prosecution agreement with Epstein. 
In 2006, the Palm Beach Police Department began investigating allegations that Jeffrey Epstein was 
enticing underage girls into prostitution. 
Epstein was alleged to have paid underage girls to provide 
him with massages, while the young girls were unclothed. 
The case was referred to the FBI and 
U.S. Attorney's Office, and the FBI began its own investigation. 
Epstein hired a number of highly-
paid attorneys, including Alan Dershowitz and Kenneth Starr, to attempt to stave off criminal charges. 
Ultimately, in 2007, Epstein was charged in state court with soliciting minors for prostitution. 
In 
September 2007, the U.S. Attorney's Office entered into a Non-Prosecution Agreement with Epstein, in 
which he agreed to plead guilty to the state criminal charge, and serve a sentence of 18 months. 
Epstein also agreed that, in any civil action under 18 U.S.C. 2255 by the underage victims, he would 
not raise the lack of a federal sex offense as a defense. 
In July 2008, Epstein plead guilty, and 
was sentenced to serve six months at the Palm Beach County Detention Facility, followed by 12 
months in home detention. 
In July 2008, after the Non-Prosecution Agreement had been executed, two victims, 
and • 
filed 
an action under the CVRA, 18 U.S.C. 3771. 
They claimed that the government was obligated, under 
18 U.S.C. 3771(a)(5), to speak with the victims prior to the execution of the Non-Prosecution 
Agreement. 
An emergency hearing was held on July 11, 2008, before U.S. District Judge Kenneth 
EFTA00206265

Marra. 
Since Epstein had entered his state court plea and been sentenced already, the court found 
there was no emergency. He directed the parties to meet and determine if there were any factual 
disputes and whether an evidentiary hearing would be necessary. 
Attorney Brad Edwards initially represented the victims. 
Soon, he was joined by Paul Cassell, a 
University of Utah law professor, and former federal judge who served in the District of Utah from 
2002-2007. Cassell is a victims' rights advocate who has appeared in many cases throughout the 
United States. 
The victims' rights suit was inactive for the next two years, with Edwards and Cassell 
using the civil suit as a means to attempt to gain access to information helpful in their civil actions for 
damages against Epstein. 
They were able to obtain a copy of the Non-Prosecution Agreement 
through the civil litigation. 
In August 2010, the district court, noting that the last civil suit had been settled, entered an order 
closing the case. 
Edwards and Cassell immediately filed documents with the court, advising that the 
case should not be closed or dismissed, and they wanted to pursue final action by the court. 
Since 
September 2010, AUSA 
and I have been dealing with Cassell and Edwards on how to 
resolve the case. 
They claim the victims had a right to be consulted prior to the execution of the 
Non-Prosecution Agreement, and that we violated the CVRA by not consulting them. 
The remedy 
they seek is a set aside by the court of the Non-Prosecution Agreement, and a prosecution of Epstein. 
On December 10, 2010, United States Attorney Wifredo A. M, 
, and I, met with Cassell, Edwards, and M, one of the victims. 
We discussed the 
posture of the case, and 
told us her views of what occurred and her desire to see Epstein receive 
justice for what he did. Cassell presented U.S. Attorney 
a four-page letter, requesting an 
investigation of the Jeffrey Epstein prosecution. He claims there may have been improper influence 
exercising by Epstein, noting that Epstein is a "politically-connected billionaire." 
Cassell cites to an 
alleged ti off to E stein that a search warrant on his residence was to be executed; that a former 
AUSA, 
, left the West Palm Beach office and soon began appearing on behalf of 
individuals aligned with Epstein; and an unprecedented level of secrecy between the FBI and the U.S. 
Attorney's Office, where the FBI was purportedly kept in the dark about the impending Non-
Prosecution Agreement. 
He also claims that the victims were deceived regarding the existence of 
the Non-Prosecution Agreement. 
Cassell's request for an investigation was referred to DOJ OPR on December 16, 2010. 
has requested various documents from our office, presumably to determine whether an 
investigation should be opened. 
Cassell and Edwards had planned to file a motion for summary 
judgment on December 17, 2010. Due to concerns that the U.S. Attorney's Office might have to be 
recused, due to the allegations of misconduct, Cassell agreed to defer filing their motion. 
We have 
since been advised by EOUSA General Counsel's Office that there is no need for our office to recuse 
itself, since we are only litigating the legal issue of whether rights under the CVRA attached. 
After the new year began, Cassell inquired about the status of the OPR complaint and the recusal 
issue. 
On Thursday, February 10, 2011, Deputy Chief 
AUSA 
and I spoke 
with Cassell and Edwards regarding the status of the case. I told them Cassell's letter request for an 
investigation of the Non-Prosecution Agreement had been referred to OPR, and OPR had requested 
various documents from our office. 
I also told them the EOUSA General Counsel's office advised 
that our office could go ahead and represent the United States in the CVRA lawsuit. I suggested that 
the parties were ready to move forward with filing documents with the court so it could resolve this 
case. 
I asked whether it might be useful to engage in mediation in an attempt to resolve the case. 
Cassell 
told us they wanted the Non-Prosecution Agreement to be set aside. 
I told him that was not likely to 
EFTA00206266

happen. Cassell then suggested that the United States Government should step aside and allow 
them to "go after" Epstein to get the agreement set aside. 
I asked him how he expected that would 
be done, since the only parties to the Non-Prosecution Agreement were Epstein and the 
Government. 
Cassell said they would file their summary judgment motion, and the government 
would take no position on their motion. Presumably, Epstein would either intervene, or be brought in 
as a necessary party, and defend the Non-Prosecution Agreement. 
I told them this would have to be 
approved by the U.S. Attorney and Main Justice. 
I have serious misgivings about not defending the Executive Branch's prerogative to engage in a Non-
Prosecution Agreement, free from supervision or oversight by the judiciary. 
If we stand by the 
sidelines, Cassell will be arguing the Government was obligated to consult with the victims, and 
because we failed to do so, the agreement is a nullity. 
Whatever we may think of the Agreement, it 
was the prerogative of the U.S. Attorney's Office to enter into it with Epstein, and we should be willing 
to defend what we did. The DOJ's position is that the rights in the CVRA do not attach until there is a 
federal court proceeding. 
Since Epstein was never charged in federal court, we were not obligated 
to consult with the victims before entering into the Non-Prosecution Agreement. 
We wanted to seek your views on Cassell's suggestion before we responded to him. We are currently 
scheduled to have a conference call with Cassell and Edwards on Tuesday, March 1. I can be 
reached at 
. Thanks. 
• 
From: 
(USAEO) < 
Sent: 
Monday, February 28, 2011 9:08 AM 
To: 
. (OLP) (JMD); 
(USAFLS) 
Cc: 
(USAFLS); 
(USAFLS); 
(USAEO) 
Subject: 
RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
If you mean can I get a conference call line, yes, I can. 
(USAFLS); 
(SMO) 
Februa 
28, 2011 9:07 AM 
USAEO); 
USAFLS 
. (USAFLS); 
(USAFLS); 
(USAEO) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
. (USAFLS); 
: Can you set up a call? I have a 10:00 meeting (30 minutes), and an as yet unscheduled 
obligation to assist in briefing the AG for his testimony on the Hill tomorrow. Sometime between noon 
and 1 is likely to be best for me. 
From: 
(USAEO) 
Sent: Monda February 28, 2011 8:43 AM 
To: 
. (SMO); 
(USAFLS) 
EFTA00206267

Cc: 
(USAFLS); 
(USAFLS); 
(USAEO) 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
I agree, as well. I am available anytime between noon and 3:00 today. 
From: 
(SMO) 
Sent: Saturda February 26, 2011 4:19 PM 
To: 
(USAFLS); 
Cc: 
. (USAFLS); 
(USAFLS); 
Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
USAEO 
I agree completely. Let's try and talk Monday, with 
on the phone if possible. 
From: 
Sent: Saturda 
To: 
Cc: 
Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
(USAFLS) 
February 26, 2011 04:08 PM 
SMO); 
. (USAFLS); 
USAEO 
. (USAFLS); 
. (USAFLS) 
(USAFLS); 
. (USAFLS) 
Mr. 
I'm looking for the appropriate officials in the Department with programmatic responsibility for the 
CVRA, so that we may obtain guidance on our litigating position. 
What Cassell wants the 
government to do is abdicate its role in defending its actions. If the DOJ's position is that no rights 
attach until a charging instrument is filed, then we should vigorously defend that position. Our office is 
most reluctant to do what Cassell asks, since negotiating the non-prosecution agreement was clearly 
within the prerogatives granted to the Executive Branch. 
Whether the bargain struck with Epstein 
was wise or not should not be the issue. 
I will be in the office all day Monday. Thanks for your assistance. 
From: 
(SMO) 
Sent: Saturda , February 26, 2011 3:40 PM 
To: 
(USAFLS); 
(USAEO) 
EFTA00206268

Cc: 
(USAFLS); 
(USAFLS) 
Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
Thanks. Perhaps we should try and find a time to talk on Monday. This scenario raises a 
variety of policy issues that extend well beyond the question of "when do the rights attach." Frankly, I 
don't think the court should even reach that question given the posture of the case as you describe it. 
From: 
(USAFLS) 
Sent: Saturda February 26, 2011 02:23 PM 
To: 
SMO); 
USAEO 
Cc: 
. (USAFLS); 
(USAFLS) 
Subject: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) 
Ms. 
and Mr. 
Our office is currently litigating a Crime Victims Rights Act (CVRA) lawsuit filed by Jane Does 1 and 2, 
who were victims of sexual abuse by Jeffrey Epstein, a multi-millionaire investor living in Palm Beach, 
Florida. 
Jane Does 1 and 2 v. United States Case No. 08-80736-CIV-MARRA (S.D.Fla.). We are 
seeking your advice and guidance on a proposal from the victims' attorneys, that the government take 
no position on whether the CVRA granted rights to the victims, when the U.S. Attorney's Office 
negotiated a non-prosecution agreement with Epstein. 
In 2006, the Palm Beach Police Department began investigating allegations that Jeffrey Epstein was 
enticing underage girls into prostitution. 
Epstein was alleged to have paid underage girls to provide 
him with massages, while the young girls were unclothed. 
The case was referred to the FBI and 
U.S. Attorney's Office, and the FBI began its own investigation. 
Epstein hired a number of highly-
paid attorneys, including Alan Dershowitz and Kenneth Starr, to attempt to stave off criminal charges. 
Ultimately, in 2007, Epstein was charged in state court with soliciting minors for prostitution. 
In 
September 2007, the U.S. Attorney's Office entered into a Non-Prosecution Agreement with Epstein, in 
which he agreed to plead guilty to the state criminal charge, and serve a sentence of 18 months. 
Epstein also agreed that, in any civil action under 18 U.S.C. 2255 by the underage victims, he would 
not raise the lack of a federal sex offense as a defense. 
In July 2008, Epstein plead guilty, and 
was sentenced to serve six months at the Palm Beach County Detention Facility, followed by 12 
months in home detention. 
In July 2008, after the Non-Prosecution Agreement had been executed, two victims, 
and • 
filed 
an action under the CVRA, 18 U.S.C. 3771. 
They claimed that the government was obligated, under 
18 U.S.C. 3771(a)(5), to speak with the victims prior to the execution of the Non-Prosecution 
Agreement. 
An emergency hearing was held on July 11, 2008, before U.S. District Judge Kenneth 
Marra. 
Since Epstein had entered his state court plea and been sentenced already, the court found 
there was no emergency. He directed the parties to meet and determine if there were any factual 
disputes and whether an evidentiary hearing would be necessary. 
Attorney Brad Edwards initially represented the victims. 
Soon, he was joined by Paul Cassell, a 
University of Utah law professor, and former federal judge who served in the District of Utah from 
2002-2007. Cassell is a victims' rights advocate who has appeared in many cases throughout the 
United States. 
The victims' rights suit was inactive for the next two years, with Edwards and Cassell 
EFTA00206269

using the civil suit as a means to attempt to gain access to information helpful in their civil actions for 
damages against Epstein. 
They were able to obtain a copy of the Non-Prosecution Agreement 
through the civil litigation. 
In August 2010, the district court, noting that the last civil suit had been settled, entered an order 
closing the case. 
Edwards and Cassell immediately filed documents with the court, advising that the 
case should not be closed or dismissed, and they wanted to pursue final action by the court. 
Since 
September 2010, AUSA 
and I have been dealing with Cassell and Edwards on how to 
resolve the case. 
They claim the victims had a right to be consulted prior to the execution of the 
Non-Prosecution Agreement, and that we violated the CVRA by not consulting them. 
The remedy 
they seek is a set aside by the court of the Non-Prosecution Agreement, and a prosecution of Epstein. 
On December 10, 2010, United States Attorney Wifredo A. M, 
, and I, met with Cassell, Edwards, and M, one of the victims. 
We discussed the 
posture of the case, and 
told us her views of what occurred and her desire to see Epstein receive 
justice for what he did. Cassell presented U.S. Attorney 
a four-page letter, requesting an 
investigation of the Jeffrey Epstein prosecution. He claims there may have been improper influence 
exercising by Epstein, noting that Epstein is a "politically-connected billionaire." 
Cassell cites to an 
alleged ti off to E stein that a search warrant on his residence was to be executed; that a former 
AUSA, 
, left the West Palm Beach office and soon began appearing on behalf of 
individuals aligned with Epstein; and an unprecedented level of secrecy between the FBI and the U.S. 
Attorney's Office, where the FBI was purportedly kept in the dark about the impending Non-
Prosecution Agreement. 
He also claims that the victims were deceived regarding the existence of 
the Non-Prosecution Agreement. 
Cassell's request for an investigation was referred to DOJ OPR on December 16, 2010. 
has requested various documents from our office, presumably to determine whether an 
investigation should be opened. 
Cassell and Edwards had planned to file a motion for summary 
judgment on December 17, 2010. Due to concerns that the U.S. Attorney's Office might have to be 
recused, due to the allegations of misconduct, Cassell agreed to defer filing their motion. 
We have 
since been advised by EOUSA General Counsel's Office that there is no need for our office to recuse 
itself, since we are only litigating the legal issue of whether rights under the CVRA attached. 
After the new year began, Cassell inquired about the status of the OPR complaint and the recusal 
issue. 
On Thursday, February 10, 2011, Deputy Chief 
AUSA 
and I spoke 
with Cassell and Edwards regarding the status of the case. I told them Cassell's letter request for an 
investigation of the Non-Prosecution Agreement had been referred to OPR, and OPR had requested 
various documents from our office. 
I also told them the EOUSA General Counsel's office advised 
that our office could go ahead and represent the United States in the CVRA lawsuit. I suggested that 
the parties were ready to move forward with filing documents with the court so it could resolve this 
case. 
I asked whether it might be useful to engage in mediation in an attempt to resolve the case. 
Cassell 
told us they wanted the Non-Prosecution Agreement to be set aside. 
I told him that was not likely to 
happen. Cassell then suggested that the United States Government should step aside and allow 
them to "go after" Epstein to get the agreement set aside. 
I asked him how he expected that would 
be done, since the only parties to the Non-Prosecution Agreement were Epstein and the 
Government. 
Cassell said they would file their summary judgment motion, and the government 
would take no position on their motion. Presumably, Epstein would either intervene, or be brought in 
as a necessary party, and defend the Non-Prosecution Agreement. 
I told them this would have to be 
approved by the U.S. Attorney and Main Justice. 
EFTA00206270

I have serious misgivings about not defending the Executive Branch's prerogative to engage in a Non-
Prosecution Agreement, free from supervision or oversight by the judiciary. 
If we stand by the 
sidelines, Cassell will be arguing the Government was obligated to consult with the victims, and 
because we failed to do so, the agreement is a nullity. 
Whatever we may think of the Agreement, it 
was the prerogative of the U.S. Attorney's Office to enter into it with Epstein, and we should be willing 
to defend what we did. The DOJ's position is that the rights in the CVRA do not attach until there is a 
federal court proceeding. 
Since Epstein was never charged in federal court, we were not obligated 
to consult with the victims before entering into the Non-Prosecution Agreement. 
We wanted to seek your views on Cassell's suggestion before we responded to him. We are currently 
scheduled to have a conference call with Cassell and Edwards on Tuesday, March 1. I can be 
reached at 
. Thanks. 
• 
From: 
(USAFLS) < 
Sent: 
Monday, March 07, 2011 5:28 PM 
To: 
. (USAFLS) 
Subject: 
FW: Jeffrey Epstein 
> 
See below. Is this your case? Obviously we will make no comment. 
From: 
(SMO) 
Sent: Monday March 07, 2011 5:25 PM 
To: 
.(USAFLS) 
Subject: FW: Jeffrey Epstein 
I believe 
is out. See below. 
From: 
(SMO) 
Sent: Monc
March 07, 2011 5:18 PM 
To: 
, 
(USAFLS) 
Subject: Jeffrey Epstein 
, Is your office handling this matter? A WSJ reporter is trying to get more information. 
The Justice Department is investigating Jeffrey Epstein for child trafficking, The Daily Beast 
has learned—and has widened the scope of its probe to include a famous modeling agency. 
EFTA00206271

Hedge-fund manager Jeffrey Epstein completed his sentence for soliciting prostitution with a minor last 
week. But it appears his problems may not be over. Now The Daily Beast has learned that: 
• Federal investigators continue to investigate Epstein's activities, to see whether there is 
evidence of child trafficking—a far more serious charge than the two in his non-prosecution 
agreement, the arrangement between Epstein and the Department of Justice allowing him to 
plead guilty to lower-level state crimes. Trafficking can carry a 20-year sentence. 
• The FBI is also investigating Epstein's friend Jean Luc Brunel, whose MC2 modeling agency 
appears to have been a source of girls from overseas who ended up on Epstein's private jets. 
Under the concept of double jeopardy, Epstein can no longer be prosecuted for any of the charges 
covered by his non-prosecution agreement, in which he agreed to serve a short term of incarceration, 
fund the civil suits of named victims, and register as a sex offender. The victims who accepted cash 
settlements in these civil suits agreed not to testify against him or speak publicly about the case. 
However, new evidence developed by the Department of Justice on other offenses not covered by the 
agreement, including allegations by additional victims who come forward, could lead to new charges. 
There is no statute of limitations in the federal sex-trafficking law, which was also enacted by the state 
of Florida in 2002. Because his predatory habits stretch back many years and involved dozens of 
young-looking girls, there may well be more evidence to uncover. (Several young women who claim to 
be Epstein victims have recently contacted a Ft. Lauderdale lawyer, but to date no new civil complaints 
have been filed.) 
These new developments come one week after the publication of two articles in The Daily Beast about 
Epstein's pattern of sexual contact with underage girls, which Palm Beach police began investigating 
in 2005 and the U.S. Attorney's office then settled in a 2007 plea deal. The first article quoted a 
deposition by then-Palm Beach Chief of Police Michael Reiter, in which he stated that Epstein, a 
billionaire with many powerful friends, had received special treatment in both his plea deal and the 
terms of his incarceration. Although federal investigators at one point produced a draft 53-page 
indictment against Epstein, he was eventually allowed to plead guilty to only two relatively minor state 
charges and receive a short term of incarceration: 13 months in the county jail, during which he went 
to the office every day, and one year of community control, during which he traveled frequently to New 
York and his private island in the Virgin Islands. 
The Daily Beast has now discovered another instance in which Epstein apparently received special 
consideration: As a convicted sex offender, he is required by law to undergo an impartial psychological 
evaluation prior to sentencing and to receive psychiatric treatment during and after incarceration. This 
is because child molesters tend to be repeat offenders with high rates of recidivism. According to a 
source in law enforcement, however, Epstein was allowed to submit a report by his private 
psychologist, Dr. Stephen Alexander of Palm Beach, Florida, whose phone has since been 
disconnected with no forwarding information. 
The Daily Beast's second article provided details about Epstein's systematic abuse of underage girls 
at his Palm Beach mansion, where members of his staff allegedly recruited and paid a parade of 
teenagers, most of them 16 or younger, to perform daily massages that devolved into masturbation, 
groping, and sometimes full-blown sexual contact. It also revealed a monetary relationship between 
Epstein and Jean Luc Brunel, a frequent visitor to whom he gave $1 million around the same time that 
Brunel was starting his MC2 modeling agency. Some of the young girls MC2 recruited from overseas 
-often from Eastern Europe and South America—are known to have been passengers on Epstein's 
private jets. 
The U.S. Attorney General's Office in Florida says that it is against policy to confirm or deny the 
existence of an investigation. Jeffrey Epstein's lawyer, Jack Goldberger, says he has no knowledge of 
an ongoing probe, and he told The Daily Beast, "Jeffrey Epstein has fully complied with all state and 
EFTA00206272