EFTA00013878.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: [REDACTED]
July __, 2008
NOTIFICATION OF IDENTIFIED VICTIMS
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-009495AXXXMB and 2008-_______) and
was sentenced to a term of eighteen months' imprisonment to be followed by ___ years of
probation.
In light of the entry of the guilty plea and sentence, and pursuant to the terms of the
deferred prosecution agreement between Epstein and the United States Attorney's Office for the
Southern District of Florida (hereinafter referred to as "the Office"), the Office hereby provides
notice to Epstein that the following is a list of individuals whom the Office was prepared to name
as victims in an Indictment charging Epstein with violations of federal statutes enumerated in
Title 18, United States Code, Section 2255 (hereinafter referred to as "identified individuals").
The terms of the deferred prosecution agreement provide that the identified individuals
shall have the same right to seek damages pursuant to Title 18, United States Code, Section 2255,
as they would have had if Mr. Epstein had been tried and convicted of those enumerated offenses
in a federal court. Section 2255 provides, in relevant part:
Any person who, while a minor, was a victim of a violation of section . . . 2422, or
2423 of this title and who suffers personal injury as a result of such violation,
regardless of whether the injury occurred while such person was a minor, may sue
in any appropriate United States District Court and shall recover the actual
damages such person sustains and the cost of the suit, including a reasonable
attorney's fee. Any person as described in the preceding sentence shall be deemed
to have sustained damages of no less than $150,000 in value.
Thus, pursuant to the deferred prosecution Agreement between the Office and Epstein, the
Office hereby provides Notice to the identified individuals that each of them is a person who,
while a minor, was a victim of a violation of an offense enumerated in Title 18, United States
Code, Section 2255, committed by Epstein. The Office further provides Notice to the identified
individuals that, pursuant to the Agreement between the Office and Epstein, a copy of this
document may be introduced in a judicial proceeding between any such identified individual and
Epstein, and that any judicial authority interpreting this Notification, including any authority
determining what evidentiary burdens, if any, a plaintiff must meet, shall consider that it is the
intent of Epstein and the Office to place the identified individuals in the same position as they
would have been had Epstein been convicted of those federal offenses.
Identified Individuals
Jane Doe #1
Jane Doe #2
Jane Doe #3
Jane Doe #4
Jane Doe #5
Jane Doe #6
EFTA00013878

Jane Doe #7
Jane Doe #8
Jane Doe #9
Jane Doe #10
Jane Doe #11
Jane Doe #12
Jane Doe #13
Jane Doe #14
Jane Doe #15
Jane Doe #16
Jane Doe #17
Jane Doe #18
Jane Doe #19
Jane Doe #20
Jane Doe #21
Jane Doe #22
Jane Doe #23
Jane Doe #24
Jane Doe #25
Jane Doe #26
Jane Doe #27
Jane Doe #28
Jane Doe #29
Jane Doe #30
R. ALEXANDER ACOSTA
UNITED STATES ATTORNEY
Dated: ________________ By: [REDACTED SIGNATURE]
ACKNOWLEDGEMENT
I have received this Notification from my attorney, Roy Black, Esquire, have read it and
discussed it with my attorney, and I hereby acknowledge that it accurately sets forth my
understanding and agreement with the Office of the United States Attorney for the Southern
District of Florida. I understand that an exact copy of this Notification will be provided to each
identified individual, except that the names of all other identified individuals will be redacted,
and I hereby waive any evidentiary challenges to the introduction of a copy of this document—
even in redacted form—in any judicial proceeding between any identified individual and myself.
Dated: ________________
Jeffrey Epstein
Witnessed by: ________________________________
Roy Black, Esquire
EFTA00013879