EFTA01080086

Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 35 of 42 
direction4) kept the existence of the non-prosecution agreement secret from the victims and the 
public. The reasonable inference from the evidence is that the U.S. Attorney's Office wanted to 
keep the agreement a secret to avoid intense criticism that would have surely ensued had the 
victims and the public learned that a billionaire sex offender with political connections had 
arranged to avoid federal prosecution for numerous felony sex offenses against minor girls. 
As part of this pattern of deception, the U.S. Attorney's Office discussed victim 
notification with the defendant sex offender and, after he raised objections, stopped making 
notifications. Then later in January 2008, the U.S. Attorney's Office arranged for letters to be 
sent to the victims — including Jane Doe #1 and Jane Doe #2 — that falsely stated that to each that 
your "case is currently under investigation." This was untrue, as the U.S. Attorney's Office had 
already resolved the federal case by signing a non-prosecution agreement with Epstein. Indeed, 
the pattern of deception continued even after Jane Doe NI and Jane Doe #2 were represented by 
legal counsel. In May 2008, the Office sent a similar letter stating "your case is currently 
investigation" to another victim (represented by attorney Bradley .1. Edwards). As late as the 
middle of June 2008 — more than eight months after the non-prosecution agreement had been 
signed -- the Assistant U.S. Attorney handling the case told Edwards to send Information that he 
wanted the Office to consider in determining whether to file federal charges. The Office 
concealed from him that it had already made the determination not to file federal charges and 
that the Office had in fact signed a non-prosecution agreement long ago. The Office also 
concealed from him the fact that guilty pleas in state court were imminent. The Office disclosed 
4 It is unknown whether the U.S. Attorney's Office even made the FBI aware of the NPA 
in a timely fashion. 
35 
EFTA01080126

Case 9:08-cv-80736-KAM Document 48 
Entered on FLSD Docket 03/21/2011 Page 36 of 42 
the non-prosecution agreement only after Epstein had entered his guilty pleas in state court — in 
other words, only after the time for the victims to be able to object to the non-prosecution 
agreement during the plea process had come and gone. Even at that time, the Office did not 
disclose the provisions in the agreement. In short, the victims never learned about the non-
prosecution agreement barring federal prosecution of their cases because of a deliberate 
decisions by the U.S. Attorney's Office, not mere "negligence or inaction." McCorlde, 321 F.3d 
at 1297. Accordingly, the Government is stopped from arguing that the Crime Victims' Rights 
Act does not apply to this case. 
IL 
THE COURT SHOULD FIND THAT THE VICTIMS' RIGHTS HAVE BEEN 
VIOLATED AND THEN SET UP A BRIEFING SCHEDULE AND HEARING ON 
TILE APPROPRIATE REMEDY. 
This U.S. Attorney's Office's behavior in this case does not satisfy the Office's 
obligations under the CVRA to use its "best efforts" to insure that victims receive protection of 
their rights. 18 U.S.C. § 3771(c)(1). In particular, the undeniable chain of events makes clear 
that the victims were not afforded their right "to confer with the attorney for the Government in 
the case." 18 U.S.C. § 3771(a)(5). Whatever else may be said about the deception, it also 
starkly violates the victims' right "to be treated with fairness and with respect for the victim's 
dignity . ..." 18 U.S.C. § 3771(a)(8). The pattern also denied the victims of timely notice of 
court proceedings, 18 U.S.C. § 3771(a)(3), including in particular the state court guilty plea. 
As we understand the position of the Government, it does not truly contest that — if the 
CVRA applied — it managed to discharge its various obligations under the Act. Instead, the 
Government relies solely on a technical argument to reach the conclusion that it discharged its 
obligations — namely, the argument that the CVRA does not apply until a formal indictment is 
36 
EFTA01080127

Case 9:08-cv-80736-KAM Document 48 
Entered on FLSD Docket 03/21/2011 Page 37 of 42 
filed. As just explained, however, that technical argument must be rejected as inconsistent with 
the CVRA's plain language and interpretation by other courts. Accordingly, this Court should 
find that the Government has violated its CVRA obligations. 
Once the Court finds such a violation, the next issue becomes what remedy should apply. 
Since the earliest days of our nation, it has been settled law that "where there is a legal right, 
there is also a legal remedy . . . .. 
Morbury.v. Madison, 5 U.S. 137, 163 (1803) (internal 
quotation omitted). Moreover, "[1)1 the right is created by a federal statute, the federal courts 
have the power to fashion an appropriate remedy." Intracoastal Transp., Inc. v. Decatur County. 
Georgia 482 F.2d 361, 371 (5th Cir. 1973). As we understand the Government's position in this 
case, however, they believe that this Court is powerless to do anything to correct the palpable 
violation of victims' rights documented in this case. 
Jane Doe #1 and Jane Doc #2 respectfully request that the Court set up a briefing 
schedule and a hearing on this important issue. The victims believe that they can establish that 
the appropriate remedy for the clear violations of their rights is to invalidate the Non-Prosecution 
Agreement. While the victims request an opportunity to provide more extensive briefing on this 
subject, they provide a few citations in support of their position here. 
When other plea arrangements have been negotiated in violation of federal law, they have 
been stricken by the courts. For example, United States v. Walker, 98 F.3d 944 (7th Cir. 1996), 
held that where a sentence on a new crime could not run concurrently with a probation 
revocation the defendant was then serving — contrary to the assumption of the parties to the plea 
agreement — the defendant was not entitled to specific performance of the plea agreement. The 
Court explained that the case was one "in which the bargain is vitiated by illegality ...." Id. at 
37 
EFTA01080128

Case 9:08-cv-80736-KAM Document 48 
Entered on FLSD Docket 03/21/2011 Page 38 of 42 
947. Here, of course, exactly the same is true: the non-prosecution agreement is vitiated by 
illegality — namely, the fact that it was negotiated in violation of the victims' rights. Other cases 
reach similar conclusions. See, e.g., United States v. Cooper, 70 F.3d 563, 567 (10th Cir. 1995) 
(prosecutor agreed to recommend probation, but it later appeared that would be an illegal 
sentence in this case, and thus only adequate remedy is to allow defendant to withdraw plea); 
Craig v. People, 986 P.2d 951, 959-60 (Colo. 1999) (because "neither the prosecutor nor the trial 
court have authority to modify or waive the mandatory parole period," such "is not a permissible 
subject of plea negotiations," and thus, even if "the trial court erroneously approves of such an 
illegal bargain" such plea is "invalid" and thus will not be specifically enforced). Nor can the 
defendant claim some right to specific performance of an illegal non-prosecution agreement. See 
State v. Garcia, 582 N.W.2d 879, 881-82 (Minn. 1998) (plea agreement for 81 months sentence, 
but court added 10-year conditional release term because, under facts of case, sentence without 
such release term "plainly illegal," and thus remedy of specific performance not available); State 
v. Wall, 348 N.C. 671, 502 S.E.2d 585, 588 (1998) (plea agreement was for sentence to be 
concurrent with one not yet completed, but state statute mandates consecutive sentence on facts 
of this case; "defendant is not entitled to specific performance in this case because such action 
would violate the laws of this state"); Ex parte Rich, 194 S.W.3d 508, 515 (Tex. Crim. App. 
2006); (where "the plea bargain seemed fair on its face when executed, it has become 
unenforceable due to circumstances beyond the control of [the parties], namely the fact that one 
of the enhancement paragraphs was mischaracterized in the indictment, resulting in an illegal 
sentence far outside the statutory range," proper remedy is plea withdrawal, as "there is no way 
of knowing whether the State would have offered a plea bargain within the proper range of 
38 
EFTA01080129

Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 39 of 42 
punishment that he deemed acceptable"); State v. Mazzone, 212 W.Va. 368, 572 S.E.2d 891, 897 
(2002) (where plea agreement was that defendant would plead guilty to 2 felony counts of felon 
in possession of firearm and prosecutor would dismiss remaining 6 counts re other offenses with 
prejudice, and all parties erroneously believed these 2 crimes were felonies, lower court 
"correctly resolved this unfortunate predicament by holding that a plea agreement which cannot 
be fulfilled based upon legal impossibility must be vacated in its entirety, and the parties must be 
placed, as nearly as possible, in the positions they occupied prior to the entry of the plea 
agreement"). 
The Non-Prosecution Agreement that the Government entered into in this case was 
simply illegal. The Government did not protect the congressionally-mandated rights of victims 
before it entered into this Agreement. Perhaps it is for this reason that the Agreement is so 
shockingly lenient — blocking prosecution for dozens and dozens of federal felony sex offenses 
against several dozen minor girls. But regardless of the leniency, the only issue for the Court is 
whether the Agreement was lawful. It was not, and so the Court invalidate it.s The victims 
respectfully ask for a full briefing schedule and a hearing on this important issue. 
5 Defendant Jeffrey Epstein was notified about this case long ago, and was notified on 
August 26, 2010, that the victims would be filing correspondence in support of their motions. 
Ile has not chosen to intervene in this action, and so he should not be heard to complain about 
remedy the Court might impose. 
In any event, there arc no double jeopardy barriers to invalidating the plea. As explained 
in a leading criminal procedure treatise: 
The review of defendant's sentence is also provided in federal cases upon 
application of a victim. The Crime Victim's Rights Act allows a victim to seek to 
reopen a sentence through a writ of mandamus, if the victim has asserted and been 
denied the right to be heard at sentencing. Like the prosecution's statutory right 
to appeal, the victim's statutory remedy should pose no double jeopardy 
39 
EFTA01080130

Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 40 of 42 
CERTIFICATE OF CONFERENCE 
As recounted above, counsel for Jane Doe #1 and Jane Doe #2 have approached the U.S. 
Attorney's Office for more than two and a half years in an effort to reach stipulated facts. The 
U.S. Attorney's Office ultimately terminated those efforts on March 15, 2011, taking the position 
that the facts of the case are irrelevant and that, on any set of facts, it did not violate the CVRA. 
CONCLUSION 
For all the foregoing reasons, the Court should find the U.S. Attorney's Office violated 
Jane Doe #1 and Jane Doe #2's rights under the Crime Victims Rights Act and then schedule an 
appropriate hearing on the remedy for these violations. The scope of the remedy that is 
appropriate may depend in pad of the scope of the violations that the Court finds. For this 
reason, it makes sense for the Court to bifurcate the process and determine, first, the extent of the 
violations and then, second, the remedy appropriate for those violations. If the Court would 
prefer to see more immediate briefing on remedy issues, the victims stand prepared to provide 
that briefing at the Court's direction. 
difficulties if as the piFrancesco] Court explained 
the defendant is 'charged 
with knowledge of the statute and its . . . provisions, and has no expectation of 
finality in his sentence until the [review by writ) is concluded . . .." 
LAFAVE ET AL., CRIMINAL Procedure § 26.7(b) (Nov. 2010) (quoting United States v. 
DiFrancesco, 449 U.S. 117, 146 (1980)). 
40 
EFTA01080131

Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 41 of 42 
RATED: March 21, 2011 
Respectfully Submitted, 
p/ Bradley J. Edwards 
Bradley J. Edwards 
FARMER, JAFFE, WEISSING, 
EDWARDS, FISTOS & LEHRMAN, P.L. 
425 North Andrews Avenue, Suite 2 
Fort Lauderdale, Florida 33301 
on 
la
Florid 
• 
E-mai 
and 
Paul G. Cassell 
Pro Hoc Vice 
S.J. Quinney College of Law at the 
University of Utah 
332 S. 1400 E. 
Salt Lake 
Telephone 
Facsim 
E-Mail 
Attorneys for Jane Doe #1 and Jane Doe #2 
41 
EFTA01080132

Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 42 of 42 
CERTIFICATE OF SERVICE 
The foregoing document was served on March 21, 2011, on the following using the Court's 
CM/ECF system: 
A. Marie ViBefalls 
Assistant U.S. Attorney 
500 S. Australian Ave., Suite 400 
West Palm Beach, FL 33401 
Fax: 
E-mail: 
Attorney or tie mvernment 
Joseph L. Ackerman, Jr. 
Joseph Ackerman, Jr. 
Fowler White Burnett PA 
777 S. Flagler Drive, West Tower, Suite 901 
West Palm Beach, FL 33401 
Criminal Defense Counsel for Jeffrey Epstein 
(courtesy copy of pleading via U.S. mail) 
42 
EFTA01080133

Case 9:08-cv-80736-KAM Document 48-1 Entered on FLSD Docket 03/21/2011 Page 1 of 1 
JANE DOE kl AND JANE DOE N2'S MOTION FOR FINDING OF VIOLATIONS OF THE 
CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE 
REMEDIES 
CASE NO: 08-80736-Clv-Marra/Johnsou 
EXHIBIT A 
Filed Under Seal 
EFTA01080134

Case 9:08-cv-80736-KAM Document 48-2 Entered on FLSD Docket 03/21/2011 Page 1 of 6 
JANE DOE NI AND JANE DOE N2'S MOTION FOR FINDING OF VIOLATIONS OF THE 
CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE 
REMEDIES 
CASE NO: 08-80736-Clv-Marra/Johnson 
EXHIBIT B 
EFTA01080135

Case 9:08-cv-80736-KAM Document 48-2 Entered on FLSD Docket 03/21/2011 Page 2 of 6 
F0-302 (Rev. 1044* 
- - 
FEDERAL BUREAU OF INVESTIGATION 
Date of transcription 
pe,114 /2007 
as interviewed in West Palm Beach, 
Florida, re 
ng a 
eral investigation involving the sexual 
exploitation of minors. After being advised of the identity of,the 
interviewing agents and the nature of the interview, 
provided 
the following information: 
In 2003 or 2004 
as introduced to JEFFREY EPSTEIN 
for the purpose of providinghim with personal massages. il
was 
r
approached at a party by a female she believed was named 
SE. 
She described the female as havin 
ro . hair and taller. The 
female was later identified as 
. Sip 
told 
and 
friend, 
that the rnnld make money by 
providing massages to EPSTEIN. 
told 
hat she could 
provide the massages with her clothes on or o 
who was 
fifteen years old, believed that she was clo 
rning sixteen 
when she first met EPSTEIN. However, during 
first contact 
with EPSTEIN, she told him that she had just turned eighteen. 
traveled to EPSTEIN's residence in Palm 
Beach by taxi. 
Was •regnant 
at the time. Once at the 
residence, 
too 
pstairs. EPSTEIN entered the room 
wearin only a ro e. Once EPS EIN had removed the robe, both 
andll'Illprovided EPSTEIN with a massage. Both AIMINIMOM 
and 
had removed their clothing and remained only in their 
underwear. EPSTEIN asked 
to leave. Once alone with 
EPSTEIN began to masturbate. 
was uncomfortable. 
After 
EPSTEIN climaxed the massage was over. 
elieved that INIMINIes 
had mentioned EPSTEIN might masturbate during the massage but she 
was still very surprised when h 
urbated. EPSTEIN pain 
$200.00. EPSTEIN did not touch 
during that massage. 
departed EPSTEIN's residence wi,. 
men that worked for EPSTEIN. 
They drove 
to a Shell Gas Station located near Okeechobee 
Boulevard and the Florida Turnpike. 
Prior to departing the residence,eprovided her 
telephone number to one of EPSTEIN's assistants, a 
(PHONETIC). 
described her as a very pretty Hispanic female in 
her early t
iis, with lon brown hair and approximately 5'5" to 
5'6" tall. 
stated that 
another
EIN's 
assistants, or EPSTEIN would usua y con act her. 
would 
telephone and ask if she was available or if she ha any other 
Investigation on 
08/07/2007 
M West Palm Beach, Florida 
Filed 31E-MM-108062 
SA E. Nesbitt Kuyrkenall 
by 
SA Jason R. Richards 
Datedkmed 
08/07/2007 
This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your ataxy: 
if and at contenu we not to be destrIbuted outside your agency. 
EFTA01080136

Case 9:08-cv-80736-KAM Document 48-2 Entered on FLSD Docket 03/21/2011 Page 3 of 6 
, 
1:13302.• (Rov. 10-645) 
31E-MN-108062 
Continuation of PD-302 of 
,On  08/07/2007  Joy  
2 
Y 
 
4. 
girlgghs could bring: When EPSTEIN telephoned; he usually asked 
for 
to come over. According to 
EPSTEIN's house 
telephone number began with the 
She would call 
sometimes and leave a message. 
tated that when they 
telephoned her they would info 
f when tliii
ld be coming 
back to town and if she might have anyone new. 
did not 
believe that EPSTEIN ever really liked her. 
traveled to the EPSTEIN's residence during 2003 and 
2004 over twenty five times.nelieved 
that she provided 
EPSTEIN with approximate) 10-15 massages. EPSTEIN initially 
IP* 
started out touching 
reasts but gradually the massages 
became more sexual. 
would instruct Illelon how and what to 
do during the massages. He would requestillIto rub his chest and 
nipples. 
tated that on approximately two occasions, EPSTEIN 
asked that 
move her underwear and provide the massage nude. 
iiiil
omplied. 
stated that EPSTEIN would make her feel that 
td the opt 
do what she wanted.
During one massage, 
tated that she had been.giviqg 
EPSTEIN a massage for approxim 
30-40 minutes when instead of 
EPSTEIN turning over to 
turbate, EPSTEIN brought another female 
into the massage area. 
escribed the female as a beautiful 
Mir 
blonde girl, a "Cameron D az" type, 19 years ofisbright blue 
an
eyes, and speaking with 
accent. EPSTEIN had 
straddle the 
female on the massage table. EPSTEIN wanted 
to touch the 
femaliiiiiiast. According to 
EPSTEIN "pleasured" the female 
while
was straddled on top of the female: 
tated she 
could hear what she believed to be a vibrator. 
aid for 
EPSTEIN it was all about leasuring the female. A ter the female 
climaxed, EPSTEIN patted 
n the shoulder and she removed 
herself from the table.
e emale got u from the table and went 
into the spa/sauna. EPSTEIN commented t 
hat in a few 
Ails
the female would realize what had just happened to her. 
c
eeived $200.00. 
advised the interviewing agents that EPSTEIN had 
used a back massager on her vag 
EPSTEIN asked her first if he 
could use the massager on her. 
stated that sh 
eld her 
breath when EPSTEIN used the bac ma sager on her. 
tated 
that at no time during any of the massages had EPSTEIN caused her 
to climax. 
During another massage,IIIIII6 
y this time she 
was seventeen, EPSTEIN placed his hand on 
agina, touching 
EFTA01080137

Case 9:08-cv-80736-KAM Document 48-2 Entered on FLSD Docket 03/21/2011 Page 4 of 6 
FD•302a (Ito. 10-6-95) 
31E-MM-108062 
Continuation of FD-)02 of 
.On  08107/20Q7  Pige  
3 
clitoris. leas 
uncomfortable and told him to stop. 
EPSTEIN complied. 
stated that the incident freaked h 
stated that EPSTEIN was upset because she was upset. 
never return to the residence. IIIIIIhtated that she did not deal 
with EPSTEIN anymore after that incident. 
EPSTEIN gave both 
and 
each a book entitled 
"Massage for Dummies". They received the books on the same visit. 
EPSTEIN also commented how strong 
hands were when it came to 
her providing his massages. 
On another occasion, EMentioned to EPSTEIN li
the 
was looking at a ca 
yota Corolla. EPSTEIN provided 
with 
$600.00 - $700.00. 
tated that EPSTEIN gave her the money 
after the incident wi 
e other female. 
Acciallito 
EPSTEIN would ask her to bring him 
other girls. 
who started dancing at strip clubs when she was 
ought girls from the club as well as from other sources. 
tated she broxiiiiiirls from fifteen years of age to twenty-
five years of age. 
-tated that EPSTEIN would get frustrated 
with,her if she did not have new females for him. On one instance, 
EPSTEIN hun 
her because she could not provide him with 
anyone new.
stated that EPSTEIN's preference was short, 
little, white girls. IIIIIMItated that EPSTEIN was upset when one 
of the other girls brought a black girl. 
stated that EPSTEIN 
did not want black girls or girls with to oos. 
occasion, 
massages. A 
said that h 
time period. 
provided him 
tated that one of the girls she stayed with on 
, also started providing EPSTEIN with 
telephone number for Wilielawas ale 
w 
ily resides in 
, Florida, possibly 
also stayed with 
during this same 
However,
 never went to EPSTEIN's house or 
with massages. 
has a Yacht Club address. 
Another girl thatMaiad taken to EPSTEIN's residence 
was 
t Name U 
LNU). According to 
EPSTEIN 
liked 
a lot. 
a favorite of 
EPSTEIN. EPS EIN offered 
$300.00 to brio 
U. 
LNU was a couple years younger than 
elieved than.. 
was either 16 
7 when she first went to EPSTEIN's residence. 
said 
that 
any part of it a 
went 2-3 times but that she did not 
believes she could identify 
lso stated thatMIELNU at 
er 
at. 
LNU if she saw her photograph. 
aid that she was ever 
EFTA01080138

Case 9:08-cv-80736-KAM Document 48-2 Entered on FLSD Docket 03/21/2011 Page 5 of 6 
. F13-302a (Rev. 10-645) 
31E-MM-108062 
Continustiom of FD-302 of 
,on 09/07/2007  .Par 
4 
one time attended 
HIGH SCHOOL. 
also 
believed that they had met through a group of friends while 
attending 
- a dropout prevention school. 
Ilillimentioned another girl by the name of 
ligipm EPSTEIN distinguished 
ali 
by referring to 
shop. 
was a story eller and a bad liar. IIIIIIIstate t at 
never 
really wanted to go to EPSTEIN's residence but she went anyway. 
aid that she had not taken a good look at EPSTEIN's 
penis. 
explained that it seemed like he would always try and 
hide his penis. IIIIIIptated that EPSTEIN never asked her for sex. 
IIIIIrtarted dancing when she was sixteen 
The owner, IS 
let her dance. 
as also 
worked at fiawspao located 
in 
Florida. 
stated that she did not like 
used ill 
l drugs during the years she provided 
EPSTEIN wil!ssages. 
said that EPSTEIN tried to provide her 
with advice regarding con 
led substances. 
IIIIIILtated that she met with 
:IN's attorne s, agpm 
lir
and a unidentified female(UF), 
met with them after she contacted 
who con rme• 
a 
ey were 
workin for EPSTEIN. 
aced thatIIIIIIIIalso 
ked of 
nd stated that s e was living in 
found out that ellimpand the OF are employed by 
specifically as 
They asked a lot of 
estio 
They 
nd a 
U. 
eiterated 
her dislike for 
114.1 
so informed the interviewing agents that 
had 
spok 
she believed before the fourth of July. 
told 
a s.e had met with investigators and that they ha 
videos 
er. 
numbers: Illillionfirmed her association to the following telephone 
Old cellular number - 
Possibly an old cellular number - 
mllIll''s telephone number - 
EFTA01080139

Case 9:08-cv-80736-KAM Document 48-2 Entered on FLSD Docket 03/21/2011 Page 6 of 6 
FD402a (Rev. 10-6-95) 
31E-MM-108062 
Continuoboo of FD-302 of 
Is 
t, 
' 
e. 
.0u  08/07/2007  ,Plisc  
5 
ca• 
EFTA01080140

Case 9:08-cv-80736-KAM Document 48-3 Entered on FLSD Docket 03/21/2011 Page 1 of 3 
JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF THE 
CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE 
REMEDIES 
CASE NO: 08-80736-Civ-Marrahlohnson 
EXHIBIT C 
EFTA01080141

07/09/2008 15:13 FAX 5618059846 
USAO WPB CONFRM 
Case 9:08-cv-80736-KAM ,ument 48-3 
Entered on FLSD Dirt 
03/21/ 
U.S. Department of Justice 
Untied States Attorney 
Southern District of Florida 
il022 
300 South Australian Ave., Suite 4OO 
Was Palm Beach, FL 33401 
(361)820-8111 
Facsimile- (360 820-8777 
June 7, 2007 
IMLIVERY BY BAND 
Mis 
Re: 
Crime Victims' and Witnesses' Rights 
Dear Mi'
Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense, 
you have a number of rights. Those rights are: 
(I) 
The right to be reasonably protected from the accused. 
(2) 
The right to reasonable, accurate, and timely notice of any public court proceeding 
involving the crime or of any release or escape of the accused: 
(3) 
The right not to be excluded from any public court proceeding, unless the court 
determines that your testimony may be materially altered if you arc present for othei 
portions of a proceeding. 
(4) 
The right to be reasonably heard at any public proceeding in the district court 
involving release, plea, or sentencing. 
(5) 
The reasonable right to confer with the attorney for the United States in the case. 
(6) 
The right to full and timely restitution as provided in law. 
(7) 
The right to proceedings free from unreasonable delay. 
(8) 
The right to be treated with fairness and with respect for the victim's dignity and 
privacy. 
Members of the U.S. Department of Justice and other federal investigative agencies, 
including the Federal Bureau of Investigation, must use their best efforts to make sure that 
n is are protected. If you have any concerns in this regard, please feel free to contact me at 
, or Special Agent Nesbitt Kuyrkendall from•the Federal Bureau of Investigation at 
. You also• can contact the Justice Department's Office for Victims of Crime in 
Washington, D.C. at 202-307-5983. That Office has a website at www.ovc.gov. 
You can seek the advice of an attorney with respect to the riglI:es listed above and, if you 
believe that the tights set forth above are being violated, you have the right to petition the Court for 
relief. 
EFTA01080142

07/09/2008 15:14 FAX 5618059846 
IMO WPB CONFRI 
it 023 
Case 9:08-cv-80736-KAM ,ument 48-3 
Entered on FLSD Dirt 
03/21/2011 Page 3 of 3 
wfis 
JUNFRI 
PAGE 2 
In addition to these rights, you are entitled to counseling and medical services, and protection 
from intimidation and harassment. If the Court determines that you are a victim, you also may be 
entitled to restitution from the perpetrator. A list of counseling and medical service providers can 
be provided to you, if you so desire. If you or your family is subjected to any intimidation or 
harassment, please contact Special Agent Kuyrkendalt or myself immediately. It is possible that 
someone working on behalf of the targets of the investigation may contact you. Such contact does 
not viola/debt Imw. However, if you are contacted, you have the choice of speaking to that person 
or refusing to"do go. If you refuse and feel that you are being threatened or harassed, then please 
contact Special Agent Kuyrkendall or myself. 
You also are entitled to notification of upcoming case events. At this time, your case is under 
investigation! If anyone is charged in connection with the investigation, you will be notified. 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
By: 
cc: 
Special Agent Nesbitt ICurkendall, F.A.I. 
A. Marie Villafaila 
Assistant United States Attorney 
f 
EFTA01080143

Case 9:08-cv-80736-KAM Document 48-4 Entered on FLSD Docket 03/21/2011 Page 1 of 3 
JANE DOE NI AND JANE DOE n'S MOTION FOR FINDING OF VIOLATIONS OF THE 
CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE 
REMEDIES 
CASE NO: 08-130736-Clv-MarrafJohnson 
EXHIBIT D 
EFTA01080144

a 
024 
07/09/2008 15:14 FAX 5618059846 
USAO WPB CONFRM 
Case 9:08-cv-80736-KAM ,ument 48-4 
Entered on FLSD Dir t 03/21/ 
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
SOO Sonia Australian Ave., Suite 400 
West Palm Beach. FL 23401 
(561)820-87H 
Facsimile: (S61) 820-8777 
August I1, 2006 
Lig. 
IA. 
Mis. 
Re: 
Crime Victims' and Witnesses' Rights 
Dear Miss 
Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense, 
you have a number of rights. Those rights are: 
(I) 
The right to be reasonably protected from the accused. 
(2) 
The right to reasonable, accurate, and timely notice of any public court proceeding 
involving the crime or of any release or escape of the accused. 
(3) 
The right not to be excluded from any public court proceeding, unless the court 
determines that your testimony may bomaterially altered if you arc present for other 
portions of a proceeding. 
(4) 
The right to be reasonably heard at any public proceeding in the district court 
involving release, plea, or sentencing. 
(5) 
The reasonable right to confer with the attorney forte United States in the case. 
(6) 
The right to full and timely restitution as provided in law. 
(7) 
The right to proceedings lice from unreasonable delay. 
(8) 
The right to be treated with fairness and with respect for the victim's dignity and 
privacy. 
C.( 
Members of the U.S. Department of Justice and other federal investigative agencies, 
including the Federal Bureau of Investigation, must use their best efforts to make sure that t 
n is are protected. If you have any concerns in this regard, please feel free to contact me at 
, or Special Agent Nesbitt Kuyrkcndall from the Federal Bureau of Investigation at 
• You also can contact the Justice Depaitment's Office for Victims of Crime in 
Washington, D.C. at 202-307-5983. That Office has a websitc at www.ovc.gov. 
You can seek the advice of an attorney with respect to the rightly listed above and, if you 
believe that the rights set forth above are being violated, you have the right to petition the Court for 
relief. 
EFTA01080145