EFTA01099834

AUSA 
United States Attorney's Office 
Page 3 
6. 
You mention your assistance in securing pro bono counsel for Jane Doe #1 to help 
prevent harassment. I trust that you would be willing to stipulate that you did not mention the 
federal non-prosecution agreement to this counsel and that you did not mention that a plea 
agreement had already been reached. Professor Cassell has spoken to Meg Garvin, Esq., at the 
National Crime Victims' Law Institute, and that is her recollection of the events. 
7. 
I think that your proposed stipulation regarding my contact with the office is 
somewhat abbreviated. I wonder what you would think about the following: 
In mid-June 2008, Mr. Edwards contacted AUSA 
to inform her 
that he represented Jane Doe #1 and, later, Jane Doe #2. Mr. Edwards asked to 
meet to provide information about the federal crimes committed by Epstein, 
secure a significant federal indictment against Epstein. 
AUSA 
and Mr. Edwards discussed itfi lsibility of federal charges being 
filed. At the end of the call, AUSA 
asked Mr. Edwards to send any 
information that he wanted considered by the U.S. Attorney's Office in 
determining whether to file federal charges. 
Because of the confidentiality 
provision that existed in the plea agreement, Mr. Edwards was not informed that, 
in September 2007, the U.S. Attorney's Office had reached an agreement not to 
file federal charges. Mr. Edwards was also not informed that any resolution of the 
criminal matter was imminent. 
On July 3, 2008, Mr. Edwards sent to AUSA 
a letter, a true and 
correct copy of which is attached. In the letter, Mr. Edwards indicated his desire 
that federal charges be filed against defendant Epstein. In particular, he wrote on 
behalf of his clients: "We urge the Attorney General and our United States 
Attorney to consider the fundamental import of the vigorous enforcement of our 
Federal laws. We urge you to move forward with the traditional indictments and 
criminal prosecution commensurate with the crimes Mr. Epstein has committed, 
and we further urge you to take the steps necessary to protect our children from 
this very dangerous sexual predator." When Mr. Edwards wrote this letter, he 
was still unaware that a non-prosecution agreement had been reached with 
Epstein. Mr. Edwards first learned of this fact on or after July 9, 2008, when the 
Government filed its responsive pleading to Jane Doe's emergency petition. That 
pleading was the first public mention of the non-prosecution agreement and the 
first disclosure to Mr. Edwards and his clients. 
8. 
I trust that you will agree that the Government had probable cause to file a 
multiple count federal indictment against Epstein, including an indictment charging crimes 
2028 HARRISON STRERT,SUITE 202, 
HOLLYWOOD, FLORIDA 33020 
EFTA01099894

AUSA 
United States Attorney's Office 
Page 4 
against Jane Doe #1 and Jane Doe #2. In asking for this stipulation, I realize that you have taken 
the position that you would not have filed an indictment involving Jane Doe #2, presumably 
because you thought that you could not carry the Government's burden of proof beyond a 
reasonable doubt. At the same time, though, I trust you will concede that the evidence in that 
case was strong enough to pass the probable cause standard. 
9. 
Finally, in light of the fact that you have been sending letters to Jane Doe #2, 
which was obviously done because you believed her to be a "victim" in this case, and since she 
has been added in this matter as a victim, we would like some assurances that she will be 
protected, as the other victims have been, in your agreement with Mr. Epstein. 
Thank you very much for considering these issues and concerns. I look forward to 
working with you to reach a stipulation that covers as much common ground as possible in this 
case. If you think that further discussions might be helpful, I would like to try and set up a 
conference call with you and my co-counsel to discuss these issues further. 
BE/sg 
Enclosure 
cc: 
Brad Edwards 
AUSA 
United States Attorney's Office 
99 N.E. 4th Street 
Miami, Florida 33132 
EFTA01099895

-•LAW 
OFFICE -
AND ASSOCIATES 
July 3, 2008 
AUSA 
mte 
tates ttorney's Office 
500 South Australian Avenue 
West Palm Beach, Florida 33401 
Dear Ms. 
VIA CERTIFIED MAIL 
RETURN RECEIPT REQUESTED 
7007 2680 0002 5519 8503 
As you are aware, we represent several of the young girls that were victimized 
and abused by Jeffrey Epstein. While we are aware of his recent guilty plea and 
conviction in his State Court case, the sentence imposed in that case is grossly inadequate 
for a sexual predator of this magnitude. The information and evidence that has come to 
our attention in this matter leads to a grave concern that justice will not be served in this 
cause if Mr. Epstein is not aggressively prosecuted and appropriately punished. Based on 
our investigation and knowledge of this case, it is apparent that he has sexually abused 
more than 100 underage girls, and the evidence against him is overwhelmingly strong. 
As former Assistant State Attorneys with seven years' prosecution experience, we 
believe that the evidence against Mr. Epstein is both credible and deep and that he may 
be the most dangerous sexual predator of children that our country has ever seen. The 
evidence suggests that for at least 4 years he was sexually abusing as many as three to 
four girls a day. It is inevitable that if he is not confined to prison, he will continue to 
manipulate and sexually abuse children and destroy more lives. He is a sexual addict that 
fococed all of his free time on sexually abusing children, and he uses his extraordinary 
wealth and power to lure in poor, underprivileged little girls and then also uses his wealth 
to shield himself from prosecution and liability. We are very concerned for the health 
and welfare of the girls he has already victimized, and concerned that if justice is not 
properly served now and he is not imprisoned for a very long time, he will get a free pass 
to sexually abuse children in the future. Future abuse and victimization is obvious to 
anyone who really reviews the evidence in this case, and future sexual abuse of minors is 
inevitable unless he is prosecuted, tried and appropriately sentenced. Money and power 
should not allow a man to make his own laws, and he has clearly received preferential 
treatment at every step up to this point. If he were a man of average wealth or the abused 
girls were from middle or upper class families, then this man would spend the rest of his 
life in prison. In a country of true, blind justice, those distinctions are irrelevant, and we 
really hope he does not prove the point that a man can commit heinous crimes against 
children and buy his way out of it. 
If the Department of Justice's recent commitment to the protection of our children 
from child molesters is to be more than rhetoric, then this is the time and the case where 
the Department must step forward. We urge the Attorney General and our United States 
EFTA01099896

AUSA 
United States Attorney's Office 
Page Two 
Attorney to consider the fundamental import of the vigorous enforcement of our Federal 
laws. We urge you to move forward with the traditional indictments and criminal 
prosecution commensurate with the crimes Mr. Epstein has committed, and we further 
urge you to take the steps necessary to protect our children from this very dangerous 
sexual perpetrator. We will help you to do this in any way possible to ensure that true 
Justice is served in this case. 
Sincere! 
Brad Edwards, Esquire 
Jay Howell, Esquire 
EFTA01099897

• Complete items 1,2, and 3. Also complete 
ltent4 if Restricted Delivery Is desired. 
•. • Print your name and address on the reverse 
so that me can-return the card to you. 
• Attach this card to the back of the inailplece, 
or on the front if space permits. 
1. Article Addressed to: 
United States Attorney's Office 
500 South Australian Avenue 
tlAiist Palm Beach, Florida 33401 
•-••••
• ' `0  Agent 
•e-,0O Addressee 
D. Is delivery address d/fferent from Item 
Yee 
If YES, enter detrvery address below: 
0 No 
3. r
ice Type 
Certified Ma 
CI Egress Mae 
0 Registered 
0 Return Remelt for Merchanclie 
CI Insured Mall 
:0 C.O.D. 
Argele Nurnber ' 
- • - -• 
• - -- • - 
- - • 
..
r.-
alreurfeiiemeenrengelo 
007 2650 0002 5519' 8503. 
..... _ _ 
` PS Form 3811. February 2004 
Domes& Ream Receipt 
102595.02.11.4840 
m 
• 
CI 
Im 
Eel 
10„ 
I ri 
U,
I N
O 
O 
• co 
-o 
O 
N 
U.S. Postal Service. 
CERTIFIED MAIL. RECEIPT 
'(Domestic Mall Only; No Insurance Coverage Provided) 
OFFICIAL USE 
Pcstage 
Certified Fee 
Return ReCeldi Fee 
(Endorsement Required) 
Restricted Delivery Fee 
(Endorsement Required) 
Iced Peefttgo & Fees 
PS Form 3000 AUDIS 2006 
- WA 
rime.)7fitire: 
or PO Box No. 
Posenerk 
Hero 
EFTA01099898

-LAW OFFICE 
e)/ 
• 
(Sea 
C elittentio 
AND ASSOCIATES. --
October 15, 2008 
AUSA 
United States Attorney's Office 
99 N.E. 4th Street 
Miami, Florida 33132 
Re: 
Jane Doe # and Jane Doe #2 v. United States of America 
Case No.: 
08-80736-CIV-MARRA/JOHNSON 
Dear Mr.. 
I am writing to inquire about whether Mr. Epstein has violated his Non-Prosecution 
Agreement with the Government. 
As you know, the Government has repeatedly described the Non-Prosecution Agreement 
as guaranteeing to the victims of Epstein's sexual abuse at least $150,000 in civil damages. The 
Government has made these representations in reliance on a current provision in the U.S. Code — 
18 U.S.C. § 2255(a) — which provides for an automatic amount of damages of at least $150,000. 
At the time that the Non-Prosecution Agreement was drafted and signed, that was the law that 
was in effect. 
In Epstein's latest filing in federal court, however, he takes the position that the pre-2006 
Amendments version of the law applies. See Defendant Epstein's Motion to Dismiss, for More 
Definite Statement and To Strike Directed to Plaintiff Jane Doe's Complaint at 9, Jane Doe v. 
Jeffrey Epstein, No. 08-CIV-80893-Marra/Johnson (discussing § 2255 and stating that the 
"applicable version of the statute" is "pre-2006 Amendments"). The 2006 Amendments altered 
§ 2255(a), by increasing the presumed minimum damages from $50,000 to $150,000. See Pub. 
L. 109-248, Title VII, § 707(b), (c), July 27, 2006, 120 Stat. 650. 
In light of Epstein's latest filing, I write to ask several questions: 
(1) Would you stipulate that you told me several times that Epstein had agreed to pay at 
least $150,000 to the identified victims of his abuse? 
(2) Did Epstein in fact agree to pay damages to the identified victims of his abuse at least 
$150,000? 
(3) Did the Government tell victims, either directly or through counsel, that Epstein had 
agreed to pay his victims at least $150,000? 
EFTA01099899

AUSA 
United States Attorney's Office 
October 15, 2008 
Page Two 
(4) Is Epstein in compliance with his Non-Prosecution Agreement with the Government 
when he is now taking the legal position, through his attorneys, that he only has to 
pay the victims $50,000 damages under § 2255? 
Thank you for any clarification you can provide on these questions. 
BE/sg 
Brad Edwards 
cc: 
,AUSA 
United States Attorney's Office 
500 South Australian Avenue 
West Palm Beach, Florida 33401 
EFTA01099900