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the victims explained in their motion for summary judgment (DE 361), the undisputed facts of this case show that for nine months, the Government and Epstein conspired to conceal a non-prosecution agreement (NPA) from Epstein's victims in order to prevent them from voicing any objection to the agreement.
ed Jane Doe 1 and Jane Doe 2 (and several other victims) in civil suits against Jeffrey Epstein for injuries my clients suffered as a consequence of Jeffrey Epstein's sexual abuse of them. 2. I have previously filed an affidavit in this matter (see DE 225-1). This affidavit repeats some of the information contai
Undisputed Fact 1 ("Between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls,
she, herself] procured additional young women for Mr. Epstein and [was] paid commissions or referral fees for
otification Letter. You write that you don't understand the basis for the Office's belief that it is appropriate to notify the victims. Pursuant to the `Justice for All Act of 2004,' crime victims are entitled to: `The right to reasonable, accurate, and timely notice of any public court proceeding ... involving the cri
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
otification Letter. You write that you don't understand the basis for the Office's belief that it is appropriate to notify the victims. Pursuant to the `Justice for All Act of 2004,' crime victims are entitled to: 'The right to reasonable, accurate, and timely notice of any public court proceeding ... involving the cri
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
otification Letter. You write that you don't understand the basis for the Office's belief that it is appropriate to notify the victims. Pursuant to the `Justice for All Act of 2004,' crime victims are entitled to: 'The right to reasonable, accurate, and timely notice of any public court proceeding ... involving the cri
Entities connected to both Jeffrey Epstein and the `Justice for All Act

Lesley Groff
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Eric Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJack Goldberger
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
Ken Starr
PERSON