📄 Extracted Text (315 words)
U.S. Department of Justice
United States Attorney
Southern District of Florida
500 S Australian Ave, Ste 400
West Palm Beach, FL 33401
(561) 820-8711
Facsimile: (561) 820-8777
June 12, 2009
DELIVERY BY HAND
Jack A. Goldberger, Esq.
Atterbury, Goldberger & Weiss, P.A.
One Clearlake Centre, Suite 1400
250 Australian Ave S.
West Palm Beach, FL 33401-5015
Re: Jeffrey Epstein
Dear Mr. Goldberger:
Pursuant to the terms of the Non-Prosecution Agreement, the United States Attorney's
Office for the Southern District of Florida hereby provides you with notice that the United
States Attorney has determined, based on reliable evidence, that Jeffrey Epstein has willfully
violated one of the conditions of the Non-Prosecution Agreement. Specifically, on May 26,
2009, Jeffrey Epstein, through his counsel, filed a "Motion to Dismiss the First Amended
Complaint or, in the Alternative, for a More Definite Statement," in the matter of Jane Doe
No. 101 v. Jeffrey Epstein, Court File No. 09-CV-80591-ICAM. "Jane Doe,No. 101" was on
the list provided to Mr. Epstein's attorneys of individuals whom the United States had
identified as victims, as defined in 18 U.S.C. § 2255, and "Jane Doe No. 101" has elected to
proceed exclusively under 18 U.S.C. § 2255. By filing the Motion to Dismiss, Mr. Epstein
is contesting liability and, therefore, has violated Term 8 of the Non-Prosecution Agreement.
Based upon Mr. Epstein's breach of that term, the U.S. Attorney's Office will pursue
its remedies. The U.S. Attorney's Office also is continuing its review of Mr. Epstein's
filings in the civil suits to determine whether additional breaches have occurred. If any are
EFTA00617214
JACK GOLDBERGER,ESQ.
JUNE 12, 2009
PAGE 2 OF 2
identified, they will be communicated to you in accordance with the terms of the Non-
Prosecution Agreement.
Sincerely,
Jeffrey H. Sloman
Acting United States Attorney
By:
A. Marie Villafaiia
Assistant United States Attorney
cc: Karen Atkinson, Chief, Northern Division
Roy Black, Esq.
EFTA00617215
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