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Case 9:08-cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 1 of 16
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-80736-CIV-MARRA/JOHNSON
JANE DOE #1 AND JANE DOE #2,
Petitioners,
v.
UNITED STATES OF AMERICA,
Respondent.
VICTIMS' RESPONSE TO GOVERNMENT'S "NOTICE TO COURT' REGARDING
ABSENCE OF NEED FOR EVIDENTIARY HEARING" AND MOTION FOR
PRODUCTION OF NON-PROSECUTION AGREEMENT AND OF REPORT OF
INTERVIEW
COME NOW the Petitioners, Jane Doe #1 and Jane Doe #2 (the "victims"), by and
through their undersigned attorneys to file this Response to the Government's document styled as
"Notice to Court Regarding Absence of Need for Evidentiary Hearing" as follows:
INTRODUCTION
At the conclusion of the oral argument on the victims' petition, victims Jane Doe #1 and
Jane Doe #2 joined the Government in expressing to the Court a desire to work out a set of
stipulated facts regarding this case. Towards that end, the Government sent a proposed set of
stipulated facts to the victims' counsel (Exhibit 1 to this pleading) and, in turn, the victims' sent
a responsive letter raising concerns about some of the Government's proposed stipulated facts
and suggesting some additions and modifications (Exhibit 2 to this pleading). The victims also
requested copies of two relevant documents from the Government: (1) the Non-Prosecution
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Agreement with defendant Epstein that is at the center of this litigation and (2) the FBI's report
of interview concerning a meeting with Jane Doe #1. These requests were also made in several
telephone conversations with the attorney for the Government. Remarkably, rather than respond
to the victims' suggestions, the Government has now suddenly reversed course and filed a terse
document claiming an "absence of a need" for an evidentiary hearing. If anything, however, the
victims' discussions with the Government have made clear that the Court should not enter
judgment for the Government but rather should enter immediate judgment for the victims that the
Government violated their rights under the CVRA. The Court should then schedule a hearing to
determine the proper remedy for the violation of the victims' rights.
In particular, the Government now apparently admits that the Non-Prosecution
Agreement it struck with Epstein in September 2007 contained an "express confidentiality
provision." See Exhibit 1 to this pleading, Government's Proposed Stipulated Facts, at page 3,
paragraph 6. Assuming that the Government honored its agreement with the defendant (a fact
that the victims have proposed to stipulate to), the Government could not have "conferred" with
the victims about the proposed arrangement over the next nine months because doing so would
have violated its confidentiality obligations with the defendant. As a result, the Government
plainly has not afforded the victims' their right to "confer" about the proposed arrangement under
the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771(a)(5). In addition, the Government
effectively misled the victims that it had reached a Non-Prosecution Agreement with Epstein,
plainly violating the victims' rights to be treated with "fairness" under the CVRA, 18 U.S.C.
§3771(aX8). The Court should therefore find that the victims' rights have been violated.
The Court should also order the Government to produce the Non-Prosecution Agreement
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to the victims. The victims are entitled to know what disposition has been made in their case.
Moreover, that Agreement purportedly contains provisions pertaining to the civil liability of
Epstein for crimes he has committed against Jane Doe #1 and Jane Doe #2. Epstein obviously
knows what those provisions are. The victims are entitled to see those provisions and the
surrounding document as well.
The Court should also order the Government to produce a report of interview with Jane
Doe #1 from about October 26, 2007, during which the Government apparently claims that it
discussed the plea arrangement with the victims.
Finally, after these documents are produced to the victims and the Court enters judgment
that the victims' rights have been violated, the Court should schedule a hearing to determine the
appropriate remedy for the violations of the victims' rights.
THE VICTIMS' PROFFERED FACTS
The Government's latest submission takes the position that "after consideration" it is now
unnecessary to hold an evidentiary hearing. The Government apparently believes that the Court
could rule in its favor based on just two submitted undisputed facts. In taking this position, the
Government apparently believes that there are no set of facts that could sustain judgment for the
victims. To the contrary, however, the available facts require judgment for the victims that their
rights under the CVRA have been violated.
Having attempted to confer with the Government about the facts in this case, counsel for
the victims respectfully submit the following — and more complete -- set of facts that, on
information and belief, they could establish if given the opportunity to do so:
In 2006, at the request of the Palm Beach Police Department, the Federal Bureau of
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Investigation opened an investigation into allegations that Jeffrey Epstein had used facilities of
interstate commerce to induce young girls between the ages of thirteen and seventeen to engage
in prostitution (among other offenses). The case was presented to the United States Attorney's
Office for the Southern District of Florida, which accepted the case for investigation. Jane Doe
#1 and Jane Doe #2 were victims of sex crimes committed by Epstein while they were minors.
The U.S. Attorney's Office's investigation soon revealed that Epstein had committed
federal sex crimes against Jane Doe #1 and Jane Doe #2. This made Jane Doe #1 and Jane Doe
#2 "victims" protected by the Crime Victim's Rights Act, 18 U.S.C. § 3771. Accordingly, the
U.S. Attorney's Office arranged to have victim notification letters sent to Jane Doe #1 and Jane
Doe #2. For example, on about June 7, 2007, Assistant U.S. Attorney A. Marie Villafafia sent a
letter to Jane Doe #1 that began: "Pursuant to the [CVRA), as a victim and/or witness of a federal
offense, you have a number of rights." The letter then listed the various rights of victims under
the CVRA. The U.S. Attorney's Office would not have sent such a letter to Jane Doe #1 if it did
not believe that she was a victim and was protected by the CVRA.
By mid-2007, the U.S. Attorney's Office had ample information to file an indictment
against Epstein charging multiple federal sex offenses. It elected not to file an indictment but
instead to engage in pre-indictment plea discussions with Epstein.
In September 2007, Epstein and the U.S. Attorney's Office reached an agreement
blocking any federal prosecution of the federal offenses he had committed. This Non Prosecution Agreement barred federal charges for Epstein's sex offenses in favor of prosecution
by Florida, so long as several preconditions were met. Those included a conviction on a state
sex offense that reflected that the victims were minors at the time the crimes occurred and that
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would require sex offender registration. While the Agreement barred federal criminal
prosecution, it envisioned that the victims would pursue a civil rights action against Epstein for
his sexual offenses against them. Most important for present purposes, the Agreement contained
an express confidentiality provision, which prevented the Government from disclosing the terms
of the Agreement to the victims or others before it was consummated. The Agreement was
subsequently modified in October and December 2007. The Agreement has several addenda that
are relevant to the Agreement. (To date, although requested to do so, the Government has
refused to provide to the victims the final Non-Prosecution Agreement or any of its earlier
versions.) Through his attorneys, Epstein was aware of the confidentiality provision and of the
fact that it would block the Government from conferring with the victims about the plea
arrangement.
On about October 26, 2007, FBI Special Agents E. Nesbitt Kuyrkendall and Jason
Richards met in person with Jane Doe #1 at a restaurant. The Special Agents explained that there
had been discussions with Epstein about a possible resolution of the charges against him.
Consistent with the express confidentiality provision in the Non-Prosecution Agreement, the
Special Agents did not disclose that the arrangement would bar any federal prosecution of
Epstein. Nor did the Agents disclose that the Non-Prosecution Agreement had been finalized.
Jane Doe #1's reasonable perception of the meeting was that only the State part of the Epstein
investigation had been resolved, and that the federal investigation would continue, possibly
leading to a federal prosecution. (While the Government has a report of interview regarding this
meeting with the victim that could confirm the victims' understanding of the facts, the
Government has refused Jane Doe #1's request to see the report.)
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Following the signing of the Non-Prosecution Agreement and the modifications thereto
by the U.S. Attorney's Office for the Southern District of Florida, Epstein received an unusual
benefit that the Government does not ordinarily provide to other criminal defendants: his
performance was delayed while he was given an opportunity to seek higher level review within
the Department of Justice in Washington, D.C.
On around January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI
advising them that "[t]his case is currently under investigation. This can be a lengthy process
and we request you continued patience while we conduct a thorough investigation." The FBI
sent these letters, under the direction of the U.S. Attorney's Office, because it believed that the
CVRA applied to Jane Doe #1 and Jane Doe #2. The FBI did not notify Jane Doe #1 or Jane
Doe #2 that the Non-Prosecution Agreement had been concluded four months earlier. Jane Doe
#1 and Jane Doe #2 reasonably understood that a federal criminal investigation of Epstein was
on-going and that federal criminal charges were possibility. At the time, Jane Doe #1 and Jane
Doe #2 believed that criminal prosecution of Epstein was extremely important. They also
desired to be consulted by the FBI and/or other representatives of the federal government about
the prosecution of Epstein. In light of the letters that they had received around January 10
(among other things), they reasonably believed that they would be contacted before the federal
government reached any final resolution of that investigation.
In the spring 2008, Jane Doe #1 contacted the FBI because Epstein's counsel was
attempting to take her deposition and private investigators were harassing her. Assistant U.S.
Attorney A. Marie Villafafla secured pro bono counsel to represent Jane Doe #1 and several other
identified victims in connection with the criminal investigation. Pro bono counsel was able to
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assist Jane Doe #1 in avoiding the improper deposition. AUSA Villafana secured pro bono
counsel by contacting Meg Garvin, Esq. of the National Crime Victims' Law Institute in
Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms.
Garvin was not advised about the Non-Prosecution Agreement.
In mid-June 2008, Mr. Edwards contacted Assistant U.S. Attorney Villafafia 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, hoping to secure a significant federal
indictment against Epstein. AUSA Villafafia and Mr. Edwards discussed the possibility of federal
charges being filed. At the end of the call, AUSA Villafafia 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 in the Non-Prosecution Agreement,
Mr. Edwards was not informed of the Agreement's existence. Mr. Edwards was also not
informed that any resolution of the criminal matter was imminent.
On July 3, 2008, Mr. Edwards sent to AUSA Villafafia a letter, a true and correct copy of
which is attached as Exhibit 3. 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 still had not been made
aware that a Non-Prosecution Agreement had been reached with Epstein.
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On about July 3, 2008, Jane Doe #1 and Jane Doe #2 learned, through telephones
conversations had between Mr. Edwards and AUSA Villafaila, that the U.S. Attorney's Office
and Epstein might be in the process of finalizing some sort of plea arrangement. Accordingly,
they filed an emergency motion seeking to protect their rights under the CVRA, including in
particular their right to confer about the proposed plea arrangement.
Mr. Edwards — and thus his clients -- first learned of the Non-Prosecution Agreement 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. Epstein, through his attorneys, knew that
the victims had not been informed about the plea arrangement.
On July 9, 2008, AUSA Villafafia sent a victim notification to Jane Doe #1 via her
attorney, Mr. Edwards, which is attached as Exhibit 6 to the Villafafia Declaration. That
notification contains a written explanation of some of the terms of the Non-Prosecution
Agreement between Epstein and the U.S. Attorney's Office. A full copy of the terms was not
provided. This was the first time that Jane Doe #1 was told that the arrangement blocked any
possibility of federal criminal charges being filed against Epstein. A notification was not
provided to Jane Doe #2 because the agreement limited Epstein's liability to victims whom the
United States was prepared to name in an indictment.
On July 11, 2008, the Court held a hearing on the victims' emergency motion. During the
hearing, the Government discussed in open court various provisions of the Non-Prosecution
Agreement. At the conclusion of the hearing, victims' counsel and the Government agreed to
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confer in an effort to determine the undisputed facts of the fact. The Court took the motion under
advisement.
On July 16, 2008, the Government sent to Mr. Edwards a proposed set of undisputed
facts, which is attached to this pleading as Exhibit 1.
On July 17, 2008, Mr. Edwards sent a response to the Government, which is attached to
this pleading as Exhibit 2. The response made various suggestions to the proposed undisputed
facts. The response also requested a copy of the Non-Prosecution Agreement and the Report of
Interview with Jane Doe #I.
On July 29, 2008, rather than attempt to work with victims' counsel to draft a set of
undisputed facts, the Government filed its "Notice to Court Regarding Absence of Need for
Evidentiary Hearing."
At all times material to this statement of facts, it would have been easily practical and
feasible for the Federal Government to inform Jane Doe #1 and Jane Doe #2 of the details of any
proposed plea agreement with Epstein, including in particular the details of the Non-Prosecution
Agreement. The reason that AUSA Villafafia and the FBI agents acting with her did not provide
this information to Jane Doe #1 and Jane Doe #2 was because of the express confidentiality
provision that had been entered into by the Federal Government and Epstein. This provision
was requested by Epstein. The Government was under no obligation to enter into such an
arrangement and would have been statutorily forbidden from entering into such an arrangement
by the CVRA's requirement that it "confer" with the victims about any disposition of their cases.
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THE GOVERNMENT SHOULD BE DIRECTED TO CONFER WITH THE VICTIMS
REGARDING THE UNDISPUTED FACTS OF THE CASE
The Government should be directed to confer with the victims about the facts in this case,
rather than allowed to obscure the facts with its proposed "notice" that an evidentiary hearing is
unnecessary. The reason that the Government abruptly terminated discussions about the facts
with the victims seem obvious: The facts, if revealed, would plainly demonstrate that the victims
did not receive their right under the CVRA to confer with the Government and to be treated
fairly. The victims will not repeat all of their arguments from their earlier pleadings but would
simply highlight for the Court the point that this case already reeks of favored treatment for a
billionaire sex offender who has substantial influence. Regardless of how the Court proceeds, it
should at least do so on the basis of fully developed factual record so that the victims and the
public can be assured that justice has been done.
If anything, the facts in this case now call for immediate judgment in favor of the victims.
Based on the Government's proposed stipulated facts (Exhibit 1 to this pleading), it is now
obvious that the Government could not have fulfilled its statutory obligations to confer with the
victims. As now admitted by the Government, in September 2007, it had entered into a Non Prosecution Agreement with Epstein containing what it describes as "an express confidentiality
provision." While the Government has refused to disclose the text of this provision (or, indeed,
the Non-Prosecution Agreement itself), it is apparent that the Government could not have
conferred with the victims about the Agreement while abiding by the confidentiality provision.
Likewise it is now apparent that the Government has not fulfilled its statutory obligation
to treat the victims with fairness. The Government reached the Non-Prosecution Agreement with
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Epstein in September 2007, yet affirmatively concealed that Agreement from the victims through
a series of misleading statements and representations over the next nine months. For example,
on around January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI advising
them that "[t]his case is currently under investigation. This can be a lengthy process and we
request your continued patience while we conduct a thorough investigation." As the Government
well knew, however, a Non-Prosecution Agreement had already been reached with Epstein at that
time — a fact not disclosed in the letter.
The victims therefore request judgment in their favor that their rights under the CVRA
have been violated. In the alternative, the victims request that the Court direct that the
Government confer in good faith with the victims to attempt to reach a set of stipulated facts that
might form the basis for a final ruling in this case. As part of this conference, the victims request
that the Government indicate which (if any) of the proposed facts set forth above it disputes.
THE GOVERNMENT SHOULD BE REQUIRED TO PRODUCE
THE NON-PROSECUTION AGREEMENT
Remarkably, the Government has yet to disclose to the victims the very Non-Prosecution
Agreement that lies at the heart of this case. This failure becomes even more curious when
assessed against the Government's proposed stipulation of facts, which included the proposed
fact that the victims had been told about the "full terms" of the Agreement. The proposed
stipulated facts that the Government sent to the victims included this proposed stipulation:
On July 9, 2008, AUSA Villafafia sent a victim notification to Jane Doe #1 via her
attorney, Bradley Edwards, which is attached as Exhibit 6 to the Villafafia
Declaration. That notification contains a written explanation of the full terms of
the agreement between Epstein and the U.S. Attorney's Office.
Contrary to its own proposed stipulation, the Government has never disclosed to the victims the
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"full terms" of its Non-Prosecution Agreement with Epstein. To protect the victims' right to be
treated with fairness, 18 U.S.C. § 3771(a)(8), it should be required to do so now.
Congress' main concern in passing the CVRA was that crime victims were "treated as
non-participants in a critical event in their lives. They were kept in the dark by prosecutors too
busy to care enough ... and by a court system that simply did not have a place for them." 150
CONG. REC. 54262 (Apr. 22, 2004) (statement of Sen. Feinstein). To remedy this problem,
Congress gave victims "the simple right to know what is going on, to participate in the process
where the information that victims and their families can provide may be material and relevant ...
." Id. To date, Jane Doe #1 and Jane Doe #2 do not know what has happened to their case,
because they have not been told how it has been resolved. Of course, no possible harm to the
Government can come from the release of the Agreement, as this criminal matter is now
concluded — at least from the Government's perspective.
Production of the Non-Prosecution Agreement is also warranted because it has provisions
in it that are designed to benefit Jane Doe #1 and Jane Doe #2. As described by the Government,
the Agreement contains provisions in it that preclude Epstein from contesting civil liability for
the sex offenses committed against a number of the victims, including Jane Doe # I. Obviously,
Jane Doe #1 cannot take advantage of this provision if her attorneys are not able to review it.
Jane Doe #1 and Jane Doe #2 intend to file civil suits against Epstein within the next few days.
Epstein knows what is in the Non-Prosecution Agreement that may be helpful to him. Jane Doe
# I and Jane Doe #2 are entitled to see the Agreement for items that may be helpful to them.
Finally, Epstein is apparently taking advantage of provisions in the Non-Prosecution
Agreement to stall civil suits against him. For example, in Jane Doe v. Epstein et at, No. 08-
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80804-MARRA/JOHNSON (S.D. Fla. 2008), on July 25, 2008, Epstein filed a motion for a stay.
That motion claims that the civil action is "a counterpart to a pending federal criminal action."
The basis for that claim, so far as Jane Doe #1 and Jane Doe #2 can tell, is the federal Non Prosecution Agreement. Epstein should not be permitted to use provisions in the Agreement to
his advantage in private litigation without disclosing those provisions to the parties he is
opposing. Indeed, as a simple matter of fairness to the victims, see 18 U.S.C. § 3771(a)(5)
(victims right to "fairness"), the provisions should be disclosed.
In sum, the Court should direct the Government to reveal to the victims what it has done
to resolve the case by ordering production of the full Non-Prosecution Agreement and any
accompanying addenda to the agreement.
THE GOVERNMENT SHOULD BE REQUIRED TO PRODUCE THE REPORT OF
INTERVIEW WITH JANE DOE #1
The Government apparently has a report of interview indicating that two named FBI
agents met with Jane Doe #1 on about October 26, 2007. The Government, however, has
declined to produce it.
The Government should be directed to produce this information to Jane Doe #1. Of
course, a criminal defendant would be entitled to such a report. See Fed. R. Crim. P. 16(a)(1)(A)
& (B). As an innocent victim in this matter, Jane Doe #1 should be treated with at least the same
consideration. See 18 U.S.C. § 3771(a)(8) (victim's right to "be treated with fairness"). Jane
Doe #1 requested this report in her letter regarding the proposed stipulated facts (see Exhibit 2 to
this filing), a request that the Government has simply ignored.
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AFTER ENTERING JUDGMENT FOR THE VICTIMS' ON THE VIOLATION OF THEIR
RIGHTS, THE COURT SHOULD SCHEDULE A HEARING ON THE APPROPRIATE
REMEDY
For the reasons just explained, the Court should enter judgment for Jane Doe #1 and Jane
Doe #2 on the violations of their rights under the CVRA and order the Government to produce
the Non-Prosecution Agreement and the report of interview with Jane Doe #1. After doing that,
the question then arises as to what is the proper remedy for the violations of victims' rights.
To be clear, at this time, the victims seek two things: (1) a judicial declaration that the
Government violated their rights under the CVRA and an apology from the Government; and (2)
a hearing to discuss the appropriate remedy under the circumstances. At the same time, the
victims are not asking to have any provision in the Non-Prosecution Agreement establishing
liability in a civil suit to be vacated or declared invalid. Because the possible connection
between these two things raises complex legal issues, the victims respectfully request that the
Court order a hearing at which the appropriate remedy can be discussed. The victims also need
to review the full text of the Non-Prosecution Agreement and any accompanying addenda to
make an appropriate determination about the remedy that they wish to pursue.
CONCLUSION
The Court should find that the Government violated Jane Doe #1 and Jane Doe #2's
rights under the CVRA to confer and to be treated with fairness during the negotiation and
consummation of the Non-Prosecution Agreement. In the alternative, the Court should direct the
Government to confer with the victims regarding what facts are undisputed in this matter and,
should material facts actually be disputed, hold an evidentiary hearing regarding those facts. So
that the victims can discuss these matters with the Government, the Court should order the
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Government to provide to the victims the full Non-Prosecution Agreement (and accompanying
addenda) that is central to this litigation as well as a report of interview with Jane Doe #1 from
about October 26, 2007. The Court should then hold a hearing on the proper remedy for the
violations of the victims' rights.
DATED this 1st day of August, 2008.
Respectfully Submitted,
THE LAW OFFICE OF BRAD EDWARDS &
ASSOCIATES, LLC
By: s/ Brad Edwards
Brad Edwards, Esquire
Attorney for Petitioners
Florida Bar No. 542075
2028 Harrison Street
Suite 202
Hollywood, Florida 33020
Telephone: 954-414-8033
Facsimile: 954-924-1530
E-Mail: be@bradedwardslaw.com
Paul G. Cassell
Attorney for Petitioners
Pro Hac Vice
332 S. 1400 E.
Salt Lake City, UT 84112
Telephone: 801-585-5202
Facsimile: 801-585-6833
E-Mail: cassello@law.utah.edu
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on August 1, 2008, I electronically filed the foregoing
document with the Clerk of the Court using CM/ECF.
s/ Brad Edwards
Brad Edwards, Esquire
Attorney for Petitioner
Florida Bar No. 542075
SERVICE LIST
Jane Doe 1 and Jane Doe 2
Case No.: 08-80736-CIV-MARRA/JOHNSON
United States District Court, Southern District of Florida
Dexter A. Lee,
Assistant U.S. Attorney
99 N.E. 4th Street
Miami, Florida 33132
Telephone: 305-961-9320
Facsimile: 305-530-7139
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