EFTA00027666.pdf
2.22 MB
Extraction Summary
7
People
6
Organizations
5
Locations
8
Events
8
Relationships
6
Quotes
Document Information
Type:
Court document (opinion and order)
File Size:
2.22 MB
Summary
This document is an Opinion and Order from a U.S. District Court case related to Jeffrey Epstein. It details the history of Epstein's sexual abuse of minor girls, including Petitioners Jane Doe 1 and Jane Doe 2, from 1999 to 2007 in Palm Beach, Florida, and internationally. The document outlines the investigation by the PBPD and FBI, and the subsequent discussions and negotiations between the U.S. Attorney's Office and Epstein's legal team from 2006 to 2007, including efforts to secure a plea agreement and manage press coverage.
People (7)
| Name | Role | Context |
|---|---|---|
| Jane Doe 1 | Petitioner |
Victim of sexual abuse by Jeffrey Epstein, provided information to the FBI, received CVRA notification letter.
|
| Jane Doe 2 | Petitioner |
Victim of sexual abuse by Jeffrey Epstein, initially unwilling to provide information to FBI, received CVRA notificat...
|
| Jeffrey Epstein | Abuser/Defendant |
Sexually abused more than 30 minor girls, including Petitioners, traveled in interstate and international commerce fo...
|
| Assistant United States Attorney | Line Prosecutor |
Testified about CVRA letters, exchanged emails with Epstein's counsel, had concerns about resolution, proposed plea a...
|
| Mr. Epstein's counsel | Defense Attorney |
Engaged in discussions with the U.S. Attorney's Office, sent letters, exchanged drafts of NPA, exchanged emails with ...
|
| Parents of a 14 year old girl | Complainants |
Filed a complaint with PBPD in 2005 about their daughter's sexual abuse by Epstein.
|
| [Jane Doe] | Co-conspirator/Victim |
Young woman mentioned in line prosecutor's email, traveled on Epstein's airplane when under 18, potential victim or c...
|
Organizations (6)
| Name | Type | Context |
|---|---|---|
| UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA |
Where the case 08-80736-CIV-MARRA is filed.
|
|
| UNITED STATES |
Party in the case.
|
|
| Town of Palm Beach Police Department (PBPD) |
Received the initial complaint in 2005, requested FBI assistance.
|
|
| Federal Bureau of Investigation (FBI) |
Opened an investigation in 2006, determined Jane Doe 1 and Jane Doe 2 were victims, received information from Jane Do...
|
|
| U.S. Attorney's Office for the Southern District of Florida (the Office) |
Engaged in discussions with Epstein's attorneys, drafted prosecution memorandum and indictment, sent CVRA letters, ex...
|
|
| Justice Department |
Mentioned in CVRA notification letter regarding protection of rights.
|
Timeline (8 events)
1999-2007
Jeffrey Epstein sexually abused more than 30 minor girls, including Petitioners Jane Doe 1 and Jane Doe 2, at his mansion in Palm Beach, Florida, and elsewhere in the United States and overseas.
Palm Beach, Florida; United States; overseas
2005
Town of Palm Beach Police Department (PBPD) received a complaint from parents of a 14-year-old girl about her sexual abuse by Jeffrey Epstein.
Palm Beach, Florida
2006
Federal Bureau of Investigation (FBI) opened an investigation into allegations that Epstein and his personal assistants used interstate commerce facilities to induce girls (14-17) into illegal sexual activities, at the request of the PBPD.
August 3, 2007
Government rejected Epstein's various arguments against federal charges.
U.S. Government
Jeffrey Epstein
August 7, 2007
Jane Doe 1 provided information about her abuse and Jane Doe 2's abuse to the FBI.
February 1, 2007
Epstein's defense team sent a 24-page letter to the U.S. Attorney's Office, outlining their intended presentation for a meeting the same day.
Jeffrey Epstein's defense team
U.S. Attorney's Office
January 2007 - September 2007
Discussions took place between the U.S. Attorney's Office for the Southern District of Florida and Jeffrey Epstein's attorneys.
U.S. Attorney's Office
Jeffrey Epstein's attorneys
May 2007
U.S. Attorney's Office drafted an 82-page prosecution memorandum and a 53-page indictment outlining numerous federal sexual offenses committed by Epstein.
U.S. Attorney's Office
Jeffrey Epstein
Locations (5)
| Location | Context |
|---|---|
|
Location of Epstein's mansion where sexual abuse occurred, location where PBPD received complaint.
|
|
|
Location where sexual abuse occurred, interstate commerce violations.
|
|
|
Location where sexual abuse occurred, international commerce violations.
|
|
|
Mentioned as a potential location to file charges to cut press coverage.
|
|
|
Location in Miami-Dade County where charges could be filed.
|
Relationships (8)
Sexually abused Jane Doe 1.
Sexually abused Jane Doe 2. Paid for Jane Doe 2's counsel.
Sexually abused more than 30 minor girls, used paid employees to find them, worked in concert with others.
Worked in concert with others to obtain minors, pressured co-conspirators, proposed plea for assaulting a co-conspirator.
Jeffrey Epstein's counsel
→
legal opponents/negotiators
→
U.S. Attorney's Office
Engaged in discussions, exchanged letters, negotiated plea agreements.
Exchanged emails, discussed plea agreements, corresponded on legal strategy.
Both petitioners in the case, both victims of Epstein, both received CVRA letters.
Hearsay evidence that she traveled on Mr. Epstein's airplane when she was under 18.
Key Quotes (6)
"From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls, including Petitioners Jane Doe 1 and Jane Doe 2 (hereinafter, “Petitioners”), at his mansion in Palm Beach, Florida, and elsewhere in the United States and overseas."Source
EFTA00027666.pdf
Quote #1
"By March 15, 2007, the Office was sending letters to victims informing them of their rights pursuant to the Crime Victims' Rights Act ("CVRA")."Source
EFTA00027666.pdf
Quote #2
"I have gotten some negative reaction to the assault charge with [a co-conspirator] as the victim, since she is considered one of the main perpetrators of the offenses that we planned to charge in the indictment. Can you talk to Mr. Epstein about a young woman named [Jane Doe]? We have hearsay evidence that she traveled on Mr. Epstein's airplane when she was under 18, in around the 2000 or 2001 time frame."Source
EFTA00027666.pdf
Quote #3
"On an ‘avoid the press’ note, I believe that Mr. Epstein's airplane was in Miami on the day of the [co-conspirator] telephone call. If he was in Miami-Dade County at the time, then I can file the charge in the District Court in Miami, which will hopefully cut the press coverage significantly."Source
EFTA00027666.pdf
Quote #4
"the Office did not like the factual basis for the proposed charges as the Office was “not investigating Mr. Epstein [for] abusing his girlfriend.”"Source
EFTA00027666.pdf
Quote #5
"[REDACTED TEXT] (i.e., AUSA [REDACTED TEXT]) recommended that some of the timing issues be addressed only in the state agreement, so that it isn't obvious to the judge that we are trying to create federal jurisdiction for prison purposes."Source
EFTA00027666.pdf
Quote #6
Full Extracted Text
Complete text extracted from the document (9,686 characters)
Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 1 of 33
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08-80736-CIV-MARRA
JANE DOE 1 AND JANE DOE 2,
Petitioners,
vs.
UNITED STATES,
Respondent.
OPINION AND ORDER
This cause is before the Court upon Jane Doe 1 and Jane Doe 2's Motion for Partial
Summary Judgment (DE 361); the United States's Cross-Motion for Summary Judgment (DE
408); Jane Doe 1 and Jane Doe 2's Motion to Compel Answers (DE 348) and Jane Doe 1 and
Jane Doe 2's Motion for Finding Waiver of Work Product and Similar Protections by
Government and for Production of Documents (DE 414). The Motions are fully briefed and ripe
for review. The Court has carefully considered the Motions and is otherwise fully advised in the
premises.
Summary Judgment (DE 361); the United States's Cross-Motion for Summary Judgment (DE
408); Jane Doe 1 and Jane Doe 2's Motion to Compel Answers (DE 348) and Jane Doe 1 and
Jane Doe 2's Motion for Finding Waiver of Work Product and Similar Protections by
Government and for Production of Documents (DE 414). The Motions are fully briefed and ripe
for review. The Court has carefully considered the Motions and is otherwise fully advised in the
premises.
I. Background
The facts, as culled from affidavits, exhibits, depositions, answers to interrogatories and
reasonably inferred for the purpose of these motions, are as follows:
reasonably inferred for the purpose of these motions, are as follows:
From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor
girls, including Petitioners Jane Doe 1 and Jane Doe 2 (hereinafter, “Petitioners”), at his mansion
in Palm Beach, Florida, and elsewhere in the United States and overseas. (Government Resp. to
Petitioner's Statement of Undisputed Material Facts (hereinafter, “DE 407 at ¶ 1.) Because
EFTA00027666
Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33
Epstein and his co-conspirators knowingly traveled in interstate and international commerce to
sexually abuse Jane Doe 1, Jane Doe 2 and others, they committed violations of not only Florida
law, but also federal law. (DE 407 at ¶ 2.) In addition to his own sexual abuse of the victims,
Epstein directed other persons to abuse the girls sexually. (DE 407 at ¶ 3.) Epstein used paid
employees to find and bring minor girls to him. Epstein worked in concert with others to obtain
minors not only for his own sexual gratification, but also for the sexual gratification of others.
(DE 407 at ¶ 8.)
sexually abuse Jane Doe 1, Jane Doe 2 and others, they committed violations of not only Florida
law, but also federal law. (DE 407 at ¶ 2.) In addition to his own sexual abuse of the victims,
Epstein directed other persons to abuse the girls sexually. (DE 407 at ¶ 3.) Epstein used paid
employees to find and bring minor girls to him. Epstein worked in concert with others to obtain
minors not only for his own sexual gratification, but also for the sexual gratification of others.
(DE 407 at ¶ 8.)
In 2005, the Town of Palm Beach Police Department (“PBPD”) received a complaint
from the parents of a 14 year old girl about her sexual abuse by Jeffery Epstein. The PBPD
ultimately identified approximately 20 girls between the ages of 14 and 17 who were sexually
abused by Epstein. (DE 407 at ¶ 4.) In 2006, at the request of the PBPD, the Federal Bureau of
Investigation (“FBI”) opened an investigation into allegations that Epstein and his personal
assistants used the facilities of interstate commerce to induce girls between the ages of 14 and 17
to engage in illegal sexual activities. (DE 407 at ¶ 5.) The FBI ultimately determined that both
Jane Doe 1 and Jane Doe 2 were victims of sexual abuse by Epstein while they were minors. Jane
Doe 1 provided information about her abuse and Jane Doe 2's abuse to the FBI on August 7,
2007. (DE 407 at ¶ 6.)
from the parents of a 14 year old girl about her sexual abuse by Jeffery Epstein. The PBPD
ultimately identified approximately 20 girls between the ages of 14 and 17 who were sexually
abused by Epstein. (DE 407 at ¶ 4.) In 2006, at the request of the PBPD, the Federal Bureau of
Investigation (“FBI”) opened an investigation into allegations that Epstein and his personal
assistants used the facilities of interstate commerce to induce girls between the ages of 14 and 17
to engage in illegal sexual activities. (DE 407 at ¶ 5.) The FBI ultimately determined that both
Jane Doe 1 and Jane Doe 2 were victims of sexual abuse by Epstein while they were minors. Jane
Doe 1 provided information about her abuse and Jane Doe 2's abuse to the FBI on August 7,
2007. (DE 407 at ¶ 6.)
From January of 2007 through September of 2007, discussions took place between the
U.S. Attorney's Office for the Southern District of Florida (“the Office”) and Jeffrey Epstein's
attorneys. (DE 407 at ¶ 9.) On February 1, 2007, Epstein's defense team sent a 24-page letter to
the Office going over what they intended to present during a meeting at the Office the same day.
(DE 407 at ¶ 10.)
U.S. Attorney's Office for the Southern District of Florida (“the Office”) and Jeffrey Epstein's
attorneys. (DE 407 at ¶ 9.) On February 1, 2007, Epstein's defense team sent a 24-page letter to
the Office going over what they intended to present during a meeting at the Office the same day.
(DE 407 at ¶ 10.)
2
EFTA00027667
Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 3 of 33
By March 15, 2007, the Office was sending letters to victims informing them of their
rights pursuant to the Crime Victims' Rights Act ("CVRA"). (DE 407 at ¶ 11.) By May of 2007,
the Office had drafted an 82-page prosecution memorandum and a 53-page indictment outlining
numerous federal sexual offenses committed by Epstein. (DE 407 at ¶ 12.) On or about June 7,
2007, FBI agents had delivered to Jane Doe 1 a standard CVRA victim notification letter. The
notification letter promised that the Justice Department would make its “best efforts” to protect
Jane Doe 1's rights, including “the reasonable right to confer with the attorney for the United
States in the case” and “to be reasonably heard at any public proceeding in the district court
involving [a] ... plea.” The notification further stated that, “[a]t this time, your case is under
investigation.” (DE 407 at ¶ 13.) Jane Doe 1 relied on those representations and believed that the
Government would protect those rights and keep her informed about the progress of her case.
(DE 407 at ¶ 14.)
numerous federal sexual offenses committed by Epstein. (DE 407 at ¶ 12.) On or about June 7,
2007, FBI agents had delivered to Jane Doe 1 a standard CVRA victim notification letter. The
notification letter promised that the Justice Department would make its “best efforts” to protect
Jane Doe 1's rights, including “the reasonable right to confer with the attorney for the United
States in the case” and “to be reasonably heard at any public proceeding in the district court
involving [a] ... plea.” The notification further stated that, “[a]t this time, your case is under
investigation.” (DE 407 at ¶ 13.) Jane Doe 1 relied on those representations and believed that the
Government would protect those rights and keep her informed about the progress of her case.
(DE 407 at ¶ 14.)
On July 6, 2007, Epstein's lawyers sent a 23-page letter lodging numerous arguments to
persuade the Office that no federal crimes had been committed by him. (DE 407 at ¶ 15.) By
August 3, 2007, the Government had rejected Epstein's various arguments against federal
persuade the Office that no federal crimes had been committed by him. (DE 407 at ¶ 15.) By
August 3, 2007, the Government had rejected Epstein's various arguments against federal
1 On or about August 11, 2006, Jane Doe 2 received the same CVRA letter. (DE 407 at ¶
5-7.)
5-7.)
Initially, Jane Doe 2 was unwilling to provide any information to the FBI or the Office,
unless she was assured her statements would not be used against her. She also described Epstein
as “an awesome man” and stated that she hoped “nothing happens to” him. (DE 415 at ¶¶ 14-
15.) This was during the time period where Jane Doe 2 had obtained counsel paid for by Epstein.
(Jane Doe 2 Decl. ¶¶ 5-7.)
unless she was assured her statements would not be used against her. She also described Epstein
as “an awesome man” and stated that she hoped “nothing happens to” him. (DE 415 at ¶¶ 14-
15.) This was during the time period where Jane Doe 2 had obtained counsel paid for by Epstein.
(Jane Doe 2 Decl. ¶¶ 5-7.)
Assistant United States Attorney (“AUSA”) [REDACTED TEXT] ("line prosecutor"
[REDACTED TEXT] ) testified that both Jane Doe 1 and Jane Doe 2 received letters describing their rights
under the CVRA. Although Jane Doe 1 and 2 were given [REDACTED TEXT] and the FBI agent's
name and phone number, neither contacted either of them. ( [REDACTED TEXT] Decl. ¶ 5, DE 403-19.)
[REDACTED TEXT] ) testified that both Jane Doe 1 and Jane Doe 2 received letters describing their rights
under the CVRA. Although Jane Doe 1 and 2 were given [REDACTED TEXT] and the FBI agent's
name and phone number, neither contacted either of them. ( [REDACTED TEXT] Decl. ¶ 5, DE 403-19.)
3
EFTA00027668
Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 4 of 33
charges and sent a letter to Epstein's counsel stating, “[w]e would reiterate that the agreement to
Section 2255 [a civil restitution provision] liability applies to all of the minor girls identified
during the federal investigation, not just the 12 that form the basis of an initial planned charging
instrument.” (DE 407 at ¶ 17.) On September 10, 2007, multiple drafts of a non-prosecution
agreement (“NPA”) had been exchanged between Epstein's counsel and the Office. (DE 407 at ¶
18.)
Section 2255 [a civil restitution provision] liability applies to all of the minor girls identified
during the federal investigation, not just the 12 that form the basis of an initial planned charging
instrument.” (DE 407 at ¶ 17.) On September 10, 2007, multiple drafts of a non-prosecution
agreement (“NPA”) had been exchanged between Epstein's counsel and the Office. (DE 407 at ¶
18.)
On September 12, 2007, while attempting to create alternative charges against Epstein,
the Office expressed concern about “the effect of taking the position that Mr. Epstein's house is
in the special maritime and territorial jurisdiction of the United States” because the Government
had “no evidence of any assaults occurring either on Mr. Epstein's plane or offshore from his
residence.” (DE 407 at ¶ 19.) On September 13, 2007, the line prosecutor emailed Epstein's
counsel indicating an effort to come up with a solution to the aforementioned concern and she
stated that she had been “spending some quality time with Title 18 looking for misdemeanors.”
The line prosecutor further indicated, “I know that someone mentioned there being activity on an
airplane. I just want to make sure that there is a factual basis for the plea that the agents can
confirm.” Epstein's counsel responded, “[a]lready thinking about the same statutes.” (DE 407 at
¶ 20.)
the Office expressed concern about “the effect of taking the position that Mr. Epstein's house is
in the special maritime and territorial jurisdiction of the United States” because the Government
had “no evidence of any assaults occurring either on Mr. Epstein's plane or offshore from his
residence.” (DE 407 at ¶ 19.) On September 13, 2007, the line prosecutor emailed Epstein's
counsel indicating an effort to come up with a solution to the aforementioned concern and she
stated that she had been “spending some quality time with Title 18 looking for misdemeanors.”
The line prosecutor further indicated, “I know that someone mentioned there being activity on an
airplane. I just want to make sure that there is a factual basis for the plea that the agents can
confirm.” Epstein's counsel responded, “[a]lready thinking about the same statutes.” (DE 407 at
¶ 20.)
On September 14, 2007, after having spoken on the telephone about the subject matter
of the September 13 emails, Epstein's counsel and the line prosecutor exchanged emails
including a proposed plea agreement for Epstein to plead guilty to assaulting one of his
coconspirators. (DE 407 at ¶ 21.) On September 15, 2007, the line prosecutor sent an email to
the Epstein defense team raising concerns about a resolution that would not involve one of
of the September 13 emails, Epstein's counsel and the line prosecutor exchanged emails
including a proposed plea agreement for Epstein to plead guilty to assaulting one of his
coconspirators. (DE 407 at ¶ 21.) On September 15, 2007, the line prosecutor sent an email to
the Epstein defense team raising concerns about a resolution that would not involve one of
4
EFTA00027669
Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 5 of 33
Epstein's minor victims and stating:
I have gotten some negative reaction to the assault charge with [a
co-conspirator] as the victim, since she is considered one of the main
perpetrators of the offenses that we planned to charge in the
indictment. Can you talk to Mr. Epstein about a young woman named
[Jane Doe]? We have hearsay evidence that she traveled on Mr.
Epstein's airplane when she was under 18, in around the 2000 or
2001 time frame.
co-conspirator] as the victim, since she is considered one of the main
perpetrators of the offenses that we planned to charge in the
indictment. Can you talk to Mr. Epstein about a young woman named
[Jane Doe]? We have hearsay evidence that she traveled on Mr.
Epstein's airplane when she was under 18, in around the 2000 or
2001 time frame.
(DE 407 at ¶ 22.)
On September 16, 2007, the line prosecutor corresponded with Epstein's counsel
about having Epstein plead guilty to obstruction of justice for pressuring one of his co-conspirators
not to turn over evidence or complying with a previously-served grand jury subpoena. (DE 407 at
¶ 23.) The Office also stated, “On an ‘avoid the press’ note, I believe that Mr. Epstein's airplane was
not to turn over evidence or complying with a previously-served grand jury subpoena. (DE 407 at
¶ 23.) The Office also stated, “On an ‘avoid the press’ note, I believe that Mr. Epstein's airplane was
in Miami on the day of the [co-conspirator] telephone call. If he was in Miami-Dade County at the
time, then I can file the charge in the District Court in Miami, which will hopefully cut the press
time, then I can file the charge in the District Court in Miami, which will hopefully cut the press
coverage significantly.” They also discussed having Epstein plead guilty to a second charge of
assaulting a different co-conspirator. (DE 407 at ¶ 24.)
On September 16, 2007, the line prosecutor wrote to Epstein's counsel indicating that
the Office did not like the factual basis for the proposed charges as the Office was “not
investigating Mr. Epstein [for] abusing his girlfriend.” (DE 407 at ¶ 25.) The correspondence
further stated:
investigating Mr. Epstein [for] abusing his girlfriend.” (DE 407 at ¶ 25.) The correspondence
further stated:
[REDACTED TEXT] (i.e., AUSA [REDACTED TEXT]) recommended that some of the timing issues be
addressed only in the state agreement, so that it isn't obvious to the judge that we are
trying to create federal jurisdiction for prison purposes.
addressed only in the state agreement, so that it isn't obvious to the judge that we are
trying to create federal jurisdiction for prison purposes.
I will include our standard language regarding resolving all criminal liability and I
will mention ‘co-conspirators,' but I would prefer not to highlight for the judge all
of the other crimes and all of the other persons that we could charge. Also, we do not
will mention ‘co-conspirators,' but I would prefer not to highlight for the judge all
of the other crimes and all of the other persons that we could charge. Also, we do not
5
EFTA00027670
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document