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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 I, 2007, Epstein's defense team sent a 24-page letter to the Office going over what they intended to presen
ial Facts (hereinafter, "DE 407" at 9 1.) Because EFTA00081333 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 commit
re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls
ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori
individuals, potential witnesses, or potential civil claimants and their respective counsel in this matter." (DE 407 at ¶ 63.) On October 24, 2007, AUSA Jeff Sloman sent a letter to Jay Lefkowitz, proposing an addendum to the NPA clarifying the procedures for the third-party representative for the victims under
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 I, 2007, Epstein's defense team sent a 24-page letter to the Office going over what they intended to presen
ial Facts (hereinafter, "DE 407" at 9 1.) Because EFTA00794122 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 commit
re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls
ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori
individuals, potential witnesses, or potential civil claimants and their respective counsel in this matter." (DE 407 at ¶ 63.) On October 24, 2007, AUSA Jeff Sloman sent a letter to Jay Lefkowitz, proposing an addendum to the NPA clarifying the procedures for the third-party representative for the victims under
and privacy."' The undisputed evidence begins in 2005, when the Palm Beach Police Department ("PBPD") had identified numerous girls as victims of Jeffrey Epstein's sexual crimes. In 2006, the PBPD turned the case over to federal authorities for further investigation. As early as March 15, 2007 and throughout t
cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 3 of 57 prepared an 82-page prosecution memorandum and a 53-page indictment against Epstein and his co-conspirators.4 At that time, rather than confer with the victims about how to proceed, the Government began conferring about this issue
BPD") had identified numerous girls as victims of Jeffrey Epstein's sexual crimes. In 2006, the PBPD turne
e victims. The letter also falsely claimed that "Mr. Epstein never targeted minors," and urged the Government
7 (emphasis added). 23 EFTA00804350 Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 24 of 57 64. On October 24, 2007, AUSA Jeff Sloman sent a letter to Jay Leflcowitz, proposing an Addendum to the NPA clarifying the procedures for the third-party representative for the victims unde
and privacy."' The undisputed evidence begins in 2005, when the Palm Beach Police Department ("PBPD") had identified numerous girls as victims of Jeffrey Epstein's sexual crimes. In 2006, the PBPD turned the case over to federal authorities for further investigation. As early as March 15, 2007 and throughout t
cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 3 of 57 prepared an 82-page prosecution memorandum and a 53-page indictment against Epstein and his co-conspirators.4 At that time, rather than confer with the victims about how to proceed, the Government began conferring about this issue
BPD") had identified numerous girls as victims of Jeffrey Epstein's sexual crimes. In 2006, the PBPD turne
e victims. The letter also falsely claimed that "Mr. Epstein never targeted minors," and urged the Government
7 (emphasis added). 23 EFTA00591627 Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 24 of 57 64. On October 24, 2007, AUSA Jeff Sloman sent a letter to Jay Leflcowitz, proposing an Addendum to the NPA clarifying the procedures for the third-party representative for the victims unde
- captioned case. Recently, however, it appears that the Government may attempting to argue that they were somehow "accused" of the crimes involving Epstein. The Government may also take a similar position with regard to other young women who may wish to participate in this case. Accordingly, Jane Doe 1
ane Doe 30. EE. Jane Doe 31. FF. Jane Doe 32. GG. Jane Doe 33. 3. On the date on which each of the following persons was first sexually abused by Jeffrey Epstein in the Southern District of Florida, they were not "[a] person accused of the crime," 18 U.S.C. § 3771(d)(1), of their sexual abuse: A. Jane Doe 1.
18 U.S.C. § 3771(d)(1), committed by or involving Jeffrey Epstein in the Southern District of Florida: A.
e Doe 27. BB. Jane Doe 28. CC. Jane Doe 29. DD. Jane Doe 30. EE. Jane Doe 31. FF. Jane Doe 32. GG. Jane Doe 33. 4. On about November 27, 2007, AUSA Jeff Sloman sent a communication to counsel for Jeffrey Epstein that stated, in part, "Therefore, unless you provide me with a good faith objection to Judge Da
Entities connected to both Jeffrey Epstein and AUSA Jeff Sloman

Lesley Groff
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Eric Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJack Goldberger
PERSON
Martha Stewart
PERSON
Barry Diller
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Kenneth Marra
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATION
Paul Cassell
PERSONFBI
ORGANIZATION
A. Marie Villafana
PERSON
Jay Lefkowitz
PERSON
Palm Beach
LOCATIONRoy Black
PERSON