EFTA00220771.pdf

U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 Facsimile: July 10, VIA FACSIMILE AND U.S. MAIL Jeffrey Herman, Esq. Herman & Mermelstein, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, Florida 33160 Re: Jeffrey Epstei NOTIFICATION OF IDENTIFIED VICTIM Dear Mr. Herman: By virtue of this letter, the United States Attorney's Office for the Southern District of Florida asks that you provide the following notice to your client, Angelique Garcia. On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be followed by an additional six months' imprisonment, followed by twelve months of Community Control 1, with conditions of community confinement imposed by the Court. In light of the entry of the guilty plea and sentence, the United States has agreed to defer federal prosecution in favor of this state plea and sentence, subject to certain conditions. One such condition to which Epstein has agreed is the following: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." Through this letter, this Office hereby provides Notice that your client, Angelique Garcia (née Cavallaro), is an individual whom the United States was prepared to name as a victim of an enumerated offense. Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401. Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist in civil litigation; however, if you do file a claim EFTA00220771 under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an enumerated offense, please provide written documentation of that denial to the undersigned. Please thank your client for all of her assistance during the course of this investigation and express the heartfelt regards of myself and Special Agents Kuyrkendall and Richards for the health and well-being of Ms. Garcia. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: A. MARIE VILLAFARA ASSISTANT U.S. ATTORNEY cc: Jack Goldberger, Esq. EFTA00220772