EFTA00233329.pdf

:%W OFFICE • Olier,leittea/di • A N I) ASSOCIATES July 3, 2008 VIA CERTIFIED MAIL United States Attorney's Office RETURN RECEIPT REQUESTED 7007 2680 0002 5519 8503 Dear 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 focused 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 BEOBRADEDWARDSLAW.COM EFTA00233329 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. Sincerely, Brad Edwards, Esquire Jay Howell, Esquire 2028 HARRISON STREET,SUITE 202, HOLLYWOOD, FLORIDA 33020 OFFICE: 954-414-8033/305-935-2011 FAX: 954-924-1530/305-935-4227 BEOBRADEDWARDSLAW.COM EFTA00233330  LAW OFFICE • Ofikeaceigh • AND ASSOCIATES October 15, 2008 United States Attorney's Office 99 N.E. 4th Street Miami, Florida 33132 Re: Jane Doe # and Jane Doe #2'. 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 Moir Definite Statement and To Strike Directed to Plaintiff Jane Doe's Complaint at 9, Jane Doe 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? BEG B RAD EDWARDS LAW.COM EFTA00233331 EFTA00233332  Sent: Thl trreInt• hints 10 00(10 A -AA Du To: Cc: vu, Hahn 1v. t 1 LO) Subject: Epstein Case Dear I just wanted to let you know that Karen and I spoke with Roy Black yesterday regarding the Epstein case Roy asked whether there was a way to resolve the federal and state litigation simultaneously and mentioned your desire to wrap up the case before you retired. We informed him that the Office's position is that if Epstein promptly abides by the terms of the signed non-prosecution agreement entered into by the Office and Mr. Epstein, we will end our investigation. If Mr. Epstein chooses to go forward with a different plea in the State, that is his prerogative, but we will consider it a breach of the federal non-prosecution agreement and will proceed accordingly. The federal non-prosecution agreement signed by Mr. Epstein and his counsel requires Mr. Epstein to plead guilty to the current state indictment and also to an information charging a state offense that requires sex offender registration, specifically the charge of procuring minors to engage in prostitution, at least 18 months imprisonment, and an agreement that the victims can pursue damages claims as though Mr. Epstein had been convicted of the federal offenses. Our agreement does not address probationary periods following the term of incarceration. Those are statutorily set on the federal side, so we have left that issue to the defense to negotiate with you. If you have any questions, please let me know. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 ( 1 ) LA-pka.:k. O fctrAroo Tracking: EFTA00233333 Recipient Road Road: 6/19/2008 4:48 PM Read. 6/19/2008 4:47 PM 2 EFTA00233334  PEAL OF THE STATE OF FLORIDA IN THE DISTRICT COURT OF AP BEACH, FL 33401 ACH LAKES BLVD., WEST PALM FOURTH DISTRICT, 1525 PALM BE September 2, 2009 CASE NO.: 4D09-2554 L.T. No. : 20098CF009381A JEFFREY EPSTEIN 1. STATE OF FLORIDA, ET AL. Appellee I Respondent(s). Appellant / Petitioner(s), BY ORDER OF THE COURT: filed July 13, 2009, to file portion of ORDERED that appellee E.W.'s motion ed to be moot; further, response under seal is hereby determin ion filed July 14, 2009, to file one reply ORDERED that appellant's agreed mot - ing peti ton for writ of cert iora ri and for the time to run from service of the last support filed response is hereby granted; further, August 5, 2009, to supplement the ORDERED that appellee B.B.'s motion filed record is hereby granted; further, DER ED that app elle e E.W .'s mot ion filed July 27, 2009, for attorney's fees and OR costs is hereby denied; further, filed July 23, 2009, for attorneys' fees and ORDERED that appellee B.B.'s motion costs is hereby denied; further, Newspapers, Inc. d/b/a The Palm Beach ORDERED that appellee Palm Beach rneys' fees and costs is hereby denied. Post's motion filed July 21, 2009, for atto r. g is a true copy of the original court orde I HEREBY CERTIFY that the foregoin Served: Jane Kreusler•Walsh Jack A. Goldberger Barbara J. Compiani Diana Martin Robert D. Critton, Jr. Deanna K. Shullman U.S. Attorney'S Office Spencer T. Kuvin Witham J. Berger Rebecca Mercier Vargas State Attomey.P.B. Bradley J. Edwards James B. Lake R. Alexander Acosta Michael J. Pike Jeffrey H. Sloman Hon. Jeffrey J. Colbath Ic EFTA00233335  APPEAL OF THE STATE OF FLORIDA DISTRICT COURT OF URTH DISTRICT FO July Term 2009 N, JEFFREY EPSTEI Appellant, 1. d IDA, E.W. B.B. an STATE OF FLOR /a THE PA LM BEACH POST, R S, IN C ., d /b SPAPE PALM BEACH NEW Appellees. No. 4D09-2554 09j (September 2, 20 PER CURIAM. peal and ion for writ of ce rtiorari as a full ap We trea t petitioner's petit affirm. LEVINE, JJ., concur. HAZOURI, DAMOORGIAN and t, Palm rt fo r th e Fi fte en th Judicial Circui . Appeal from the C ircuit Cou th , Ju dg e; L.T. Case Nos ba Jeffrey J. Col Beach County; B & 50 2008CF009381AX XMB. 4A X X M 502006CF00945 sh, ra J. C om pi an i of Kreusler-Wal alsh and Barba Burman, Critton, Littler & Jane Kreusler-W er t D . C ri tto n of , P.A., s, P.A., Rob oldberger 8s Weiss Compiani 8s Varga r of A tte rb ur y, G A. Goldberge Coleman, and Jack for appellant. West Palm Beach, icero & K . Sh ul lm an of Thomas, LoC and Deanna spapers, Inc., James B. Lake da le , fo r ap pe lle e Palm Beach New Lauder Bralow, PL, Fort B each Post. d/b/a The Palm uderdale, for ot hs te in R os en fe ldt Adler, Fort La r of R William J. Berge appellee E.W. , P.A., Palm en ce r T. K uv in of Leopold-Kuvin and Sp Diana L. Martin fo r appellee B.B. Beach Gardens, EFTA00233336  earing. of timely filed motion for reh Not final until disposition 2 EFTA00233337  A - Swaramearas •freA FUL N BELITTENMUU_ER, Clerk Fourth District Court of Appeal EFTA00233338  THE PALM BEACH POST • FRIDAY, SEPTEMBER 4.2009 Appeals court backs unsealing of Epstein's '07 deal with feds By SUSAN SPENCER-WENDEL ey manager of billionaires have fought vigorously Palm Brack Post Staff Miler WEST PALM BEACH — against the agreement's An appeals court has release. They have 15 affirmed a lower court days to request a rehear- ruling unsealing the con- ing with the 4th District fidential deal Jeffrey Ep- Court of Appeal. Epstein stein struck with federal Absent that, it will be- Attorneys prosecutors to avoid being come public. for the charged by them. Epstein's local criminal Palm Beach The 4th District Court defense attorney Jack money of Appeal this week up- Goldberger did not return manager held Circuit Judge Jeffrey a call seeking comment. have 15 Colbath's earlier decision Epstein's own attorneys, days to seek to unseal the agreement. in federal filings, have a rehearing. Attorneys for the mon- See EPSTEIN, 66 ► Civil litigation intensifies, deposition ends abruptly ► EPSTEIN from 1B An attorney's questioning referred to his confiden- tial deferred prosecution of Epstein becomes personal. agreement with the US. Attorney's Office, struck in September 2007, as "un- precedented" and "highly Donald 'frump and Prince who represents an alleged unusual." Andrew. "International victim identified only as Attorneys for The Palm Moneyman of Mystery," "B.B.", Kuvin questioned Beach Past as well as al- declared a 2002 New York Epstein about the shape leged victims of Epstein's magazine profile of Ep- of his genitalia and the sexual advances sought to stein. deposition abruptly ended, have the deal unsealed in He pleaded guilty in according to a transcript. state court. 2008 to procuring teens Kuvin has since made Colbath found that the for prostitution and was a motion in court to be proper.sealing procedures sentenced to 18 months able to inspect Epstein's had not been followed by in jail, but allowed out ex- genitalia. an earlier judge. tensively for work release. Kuvin said Thursday he "There is nothing more Epstein was released in seeks to corroborate a de- fundamentally important late July, after serving '13 scription one woman gave than for the public and months of the sentence. Palm Beach police. press to observe how the He now faces civil Because Epstein is in- government is doing its lawsuits filed by young voking his right to remain job," Post attorney Deanna women allegedly lured to silent in depositions, this Shullman has said. "There his Palm Beach home and is the only way to do it, is great public interest paid to perform massages Kuvin said. in how everybody in this and other acts. 'We want to corroborate case is doing their job." That civil litigation is. what those girls saw,' According to various intensifying. Kuvin said. media accounts, Epstein This week, while Ep- moved in circles that in- stein was being deposed O susan_spencer wendel@ cluded President Clinton, by attorney Spencer Kuvin, pbpost.com 4 EFTA00233339  NTH URT OF THE FIFTEE IN THE CIRCUIT CO AND FOR PALM BEACH IN JUDICIAL CIRCUIT, COUNTY, FLORI DA 009381A CASE NO. 2008CF STATE OF FLORIDA vs. , JEFFREY EPSTEIN Defendant. AGREED ORDER rties, Jack he ar d up on th e agreement of the pa to be This cause came on the State of d -r e p re s e n ti ng g Jeffrey Epstein an Goldberger representin the plea vis ed th at th e pa rti es have reviewed both t being fully ad Florida, and the Cour ve nf er en ce in th e De fendants case and ha co transcript of the plea agreement and the ndition of an da to ry pu bl ic se rvice" as a special co quirement of "m confirmed that the re l ac in g th e De fe nd an t on Community Contro ked off on the Order Pl community control chec e special y, it is he re by or de re d and adjudged that th ror. Accordingl was due to a clerical er ted. itio n of "m an da to ry public service" is dele cond mmunity th at th e O rd er Pl ac ing the Defendant on Co advised The Court being further orida for work or fe nd an t's tra ve l ou tside the State of Fl ess the De Control did not addr d and e to cla rif y th at om iss ion, it is hereby ordere d the parties desir business purposes an a for business th or ize d to tra ve l ou tside the State of Florid fendant is au adjudged that the De before m un ity co nt ro l of fic er. At least 48 hours allowed by his com and work purposes if ant shall first e of Fl or id a fo r wo rk purposes the Defend ide the Stat the need to travel outs ns or nt ro l of fic er an d th en follow any instructio of his community co obtain the permission EFTA00233340  ol officer. requirements imposed on him by his community contr h County, Florida on this DONE AND ORDERED in West Palm Beach, Palm Beac day of September, 2009. JEFFREY COLBATH Circuit Court Judge Copies: Jack A. Goldberger, Esquire ASA Department of Corrections EFTA00233341  H TH E CI RC UI T CO URT OF THE FIFTEENT IN H AND FOR PALM BEAC JUDICIAL CIRCUIT, IN COUNTY, FLORIDA "W" CRIMINAL DIVISION 00938IAXXMB CASE NO. 502008CF B 502006CF009454AXXM STATE OF FLORIDA, vs. JEFFREY EPSTEIN, Defendant G DOCU MENTS UNDER SEAL ORDER RELEASIN urt of urt as a result of the Fourth District Co THIS MATTER came before the Co it is an ce of th e tri al co urt's order, wherefore affirm Appeal's per curiam to as AD JU DG ED th at th e documents referred ORDERED AND July 2, 2008, en t" file d un de r seal in the court file on n Agreem A. "Non-Prosecutio io n Ag re em en t" fil ed under seal in the court the Non-Prosecut B. "The Addendum to 08, filed on August 25, 20 shall be released. of ement nor the Adde ndum contain the names The Court notes that neither the Agre this leased contemporaneously with ve ni le vic tim s. Th ese documents will be re any alleged ju order. is ach County, Florida th t Palm Beach, Palm Be DONE AND ORDERED in Wes 09 . day of September, 20 JEFFREY COLBATH Circuit urt Judge Copies furnished: - Southern District S. Attorney's Office R. Alexander Acosta, U. Su ite 40 0 Avenue, 500 South Australian lm Be ath , FL 33401 West Pa EFTA00233342 Page Two 0094S4AXXMB 9381AXXMB/502006CF Case No. S02008CF00 nts Under Seal Order Releasing Docume e ., State Attorney's Offic William J. Berger, Esq. q. Bradley J. Edwards, Es se n( eld t Adler Rothstein Ro q. Robert O. Critton, Es Critton, tu rn er & Coleman q. Jack A. Goldberger, Es oldber er & Weiss, P.A. q. Spencer T. Kuvin, Es Id-Kuvin, P.A. -sq. Deanna K. Shullman, EFTA00233343  P. 006/0'd 10:06 A111-30-Z008(408) I • IN RE: INVESTIGATION OF JEFFREY EPSTEIN N AGEEE8tENT NOIN:PROSECIPTIO te e Department and the Sta G tha t the Ci ty of Palm Beach Polic Co un ty (he rei na fte r, IT APPEARIN Ci rcu it in an d for Patrn Belch the 15th Ju dic ial uct of Je y ffr Attorney's Office for ve co nd uc ted an inv estigation into the cond Office") ha the "State Attorney's Epstein (herei na fte r "E pstein"); Epstein by indictmem t the St ate At tor ne y's Office has charged ITAPPEARING tha 7; rida Statutes Section 796.0 lic ita tio n of pr os tit ution, in violation of Flo with so Bureau of d St att z At tor ne y's Office and the Federal IT APPEARING that the Un ite round and any n inv est iga tion into Epstein's teckg ucted the ir ow d States from in or Investigation have cond co mm itt ed by Ep stein against the Unite have been offenses thut may ar ou nd September 2007, including: thr ou gh in or around 2001 to known and unknown i ly an d wi llf ull y conspiring with others e a fac ilit y or me an s (1) knowing the Un ite d St ates, that is, to us commit an offense ag ain st uce, or en e tic gn co mm erc e to knowingly persuade, ind ited States of interstate or forei violation of Title 18, Un gage in prostitution, in States Code, Section minor females to en in violation of Title18,United 24 22 (b ); all Code, Section 371; known to travel co ns pir ing wi th others known and un as ly and wilfu lly illicit sexual conduct, (2) knowing e commerce for the purpose of engaging in Ti tle 18 , in interstat s, in violation of § 24 23 (f) , with minor female , ite d Sta tes defined in 18 in violation of Title 18 Ur , Section 2423(b); all United States Code (e); Code, Section 2423 knowingly s of int ers tat e or foreign commerce to a facility or me an tution; in (3) using en tic e mi no r fem ales to engage in prosti persuade, induce, or ited States Code, Sections 2422(b) and 2; R, Un violation of Title I gaging in illicit sexual co mm erc e for the purpose of en (4) traveling in int ers tat e ales; in violation ed in 18 § 2423(1), with minor fem conduct, as de fin Page 1 of 7 EFTA00233344  P. 007/0I4 I Or 06 1061 30-2008(014) ; and tes Code, Section 2423(b) of Title 18, United Sta erce, retaining. in an d aff ec tin g int erstate and foreign comm the person bad (5) lemwi ngly, n, knowing that g by any means a perso a enticing, and obtainin years and wo uld be caused to engage in ed the ag e of 16 ; in vio lat ion of Ti tle not attain . §1591(c)(1) as defined in 18 U.S.C commercial sex act 91 (a) (1) and 2; and , Sections 15 IS, United States Code and federal criminal in see ks to res olve globally his state rr APPEARING tha t Ep ste ange for the benefits an d ac kn owledges that, in exch liability and Epstein un do-M in ds ing undertakingcertain nt, he ag ree s lo co mply with its terms, includ me provided by this agree wi th the St ate Attorney's Office; actions by d Epstein's background G, af ter an inv est igation of the offenses an ati on wi th the Sta te IT APPEARIN er due consult de ral law en for ce me nt agencies, raid aft ate of Flo rid a, an d the both Stare rind Fe United States, the St t the interests of the Attorney's Office, tha pro ce du re; ed by the following Defendant will be serv States Attorney for y of R. Alexander Acosta, United THEREFORE, on th e au tho rit r these offenses shall be Fl or ida , pro sec ution in this District fo abides by the the Southern District of by the Sta te of Flo rida, provided that Epstein ecution *below. deferred in favor of pros e requirements of this Agreement set forth nd itio ns an d th following co iable evidence, that, sh ou ld determine, based on rel If the United St ate s At tor ne y y of the conditions of this Ag ree me nt, Ep stein wi Wilily violated an 0) days following the during the period of the (9 ney may, within in'nety ree me nt, the n the United States Attor cu sse d be low , pro vid e Epstein with timely Ag nfi ne me nt dis of home co d shall initiate its expiration of the term the Ag ree me nt that he has violated, an ndition (s) of the violation. Any notice specifying the co six ty (6 0) days' of giving notice of prosecution on any of fense wi thi n ed within 60 days of the t to thi s pa ragraph shall be provid notice provided to Ep stein pu rsu an termination of a brtach of of fac ts wh ich ma y provide a basis for a de United States learning the Agreement. prosecution ms an d co nd itio ns of the Agreement, no After timely fulfilling all the ter enses that have 2 of thi s Ag reement, nor any other off on pages 1 an d igation and the for the offenses set out tio n by the Federal Bureau of Invest been the subject of the join t inv est iga m the Perim-al Grand Jwy r an y offenses that arose fro be United Stares Attorney's Of fic e, no ainst Epstein if any, will titute d in thi s Di str ict, and the charges ag investigation will be ins dismissed. Page 2 of 7 EFTA00233345  P. 008/Olt 10:06 JO-30-2008(MON) nt: Terms of the Agreeme indicanent as sh all ple ad gu ilt y (not nolo contendere) to the it in and for 1. Epstein Judicial Circu ainst him in the 15th currently pending ag -0 09 495AX/03M) charging Co un ty (Case No. 2006-cl Palm Be nc h , in violation of FL Salt § of so licitation of 'restitution on e (1 ) co un t ilty to an Information filed Epstein shall plead gu 796.07. In addition, fic e ch arg ing Epstein with an off ense that At tor ne y's Of itation of by the State a se x offender, that is, the solicesSection to reg ist er as requires him floads Statut stitution, in violation of minors to engage in pro 796.03; that the Court impose a ste in sh all ma ke a binding recommendation 2. Ep follows: