Epstein Secrets

will be instituted in this District, and the charges against Epstein if any, will be dismissed. Page 2 of 7 EFTA00234577 Terms of the Agreement I. Epstein shall plead guilty (not nob contendere) to the Indictment as currently pending against him in the 15th Judicial Circuit in and for Palm Beach Count

/3 0/0 • Dated: Dated: Dated: By: P e tritts TAM 2€ A. MARIE a ASSIST U.S. ATTORNEY JEFFREY EPSITaN GERALD IJIFCOURT, ESQ. COUNSEL TO JEFFREYEPSTEIN LILLYANNSANCH87, ES ATTORNEY FOR JEFFREY EPSTEIN EFTA00234642 Exhibit 17 EFTA00234643 10/25/07 THU 13:16 FAX 305 530 8440 EXECUTIVE OFFICE

fendant Date of Plea Defendant EFTA00234616 PLEA Ilk THE CIRCUITCOURT THE FOLLOWING IS TO REFLECT ALL TERMS OF THE NEGOTIATED SETTLEMENT Name: Jeffrey E Epstein Plea: Gusty Dfle No. Charge Count Lester Degree C6CF039454AMB Felony Solicitation of Prostitution 1 No 3 FEL OSCF0D9361AMB Pr curing Person

ed during that conversation and during the hearing with Judge Marra, the U.S. Attorney's Office is not a party to any of the civil suits against Mr. Epstein pending in the U.S. District Court or any state court and takes no position regarding those lawsuits. The U.S. Attorney's Office is not advising or

ECT ALL TERMS OF THE NEGOTIATED SETTLEMENT Name: Jeffrey E Epstein Plea: Gusty Dfle No. Charge Count Les

is not a party to any of the civil suits against Mr. Epstein pending in the U.S. District Court or any state

tter that contained the language from "Part 3" of the Agreement. Based upon that communication, your Affiant sent the victim notification letter to Jane Doe NI and attached it to your Affiant's July 9,2008 Declaration. 6. Although copies of all of the victim notification letters, including the one addres

will be instituted in this District, and the charges against Epstein if any, will be dismissed. Page 2 of 7 EFTA00213055 Terms of the Agreement I. Epstein shall plead guilty (not nob contendere) to the Indictment as currently pending against him in the 15th Judicial Circuit in and for Palm Beach Count

S ATTORNEY Dated: /D /3010 '7. • Dated: Dated: Bed: t ts /91W4 BY: 4 ASSIST U.S. ATTORNEY JEFFREY EPSITaN GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREYEPSTEIN LILLYANNSANCH87, ES ATTORNEY FOR JEFFREY EPSTEIN EFTA00213120 Exhibit 17 EFTA00213121 10/25/07 THU 13:16 FAX 305 530 8440 EXECUTIVE OFFICE

fendant Date of Plea Defendant EFTA00213094 PLEA Ilk THE CIRCUITCOURT THE FOLLOWING IS TO REFLECT ALL TERMS OF THE NEGOTIATED SETTLEMENT Name: Jeffrey E Epstein Plea: Gusty Dfle No. Charge Count Lester Degree C6CF039454AMB Felony Solicitation of Prostitution 1 No 3 FEL OSCF0D9361AMB Pr curing Person

FREY EPSIEN RALD LEFCO RT ESQ. COUNSEL TO JEFF Y EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EP

ECT ALL TERMS OF THE NEGOTIATED SETTLEMENT Name: Jeffrey E Epstein Plea: Gusty Dfle No. Charge Count Les

is not a party to any of the civil suits against Mr. Epstein pending in the U.S. District Court or any state

tter that contained the language from "Part 3" of the Agreement. Based upon that communication, your Affiant sent the victim notification letter to Jane Doe NI and attached it to your Affiant's July 9,2008 Declaration. 6. Although copies of all of the victim notification letters, including the one addres

) & (8). It is now beyond dispute, for example, that in September 2007, the U.S. Attorney's Office formally signed a non-prosecution agreement with Jeffrey Epstein that barred his The victims are contemporaneously filing a motion to have their facts accepted by the Court. EFTA00078993 Case 9:08-cv-80736-KAM

ein agreed to a "confidentiality" provision in the agreement barring its disclosure to anyone — including the victims. For the next nine months, as Epstein was well aware, the U.S. Attorney's Office assiduously concealed from the victims the existence of this signed non-prosecution agreement. Indeed, th

t's desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients

formally signed a non-prosecution agreement with Jeffrey Epstein that barred his The victims are contempo

criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take t

that the plea agreement made it impossible to prosecute Epstein federally for his crimes against them, they would have objected to this resolution. Jane Doe NI and Jane Doe #2 thus detrimentally relied on the inaccurate representations of the U.S. Attorney's Office that their cases were still under investi

) & (8). It is now beyond dispute, for example, that in September 2007, the U.S. Attorney's Office formally signed a non-prosecution agreement with Jeffrey Epstein that barred his The victims are contemporaneously filing a motion to have their facts accepted by the Court. EFTA00208374 Case 9:08-cv-80736-KM/

ein agreed to a "confidentiality" provision in the agreement barring its disclosure to anyone — including the victims. For the next nine months, as Epstein was well aware, the U.S. Attorney's Office assiduously concealed from the victims the existence of this signed non-prosecution agreement. Indeed, th

t's desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients

formally signed a non-prosecution agreement with Jeffrey Epstein that barred his The victims are contempo

criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take t

at 234-37; Tr. July 11, 2008, 18-19, 22-23, 28- 29? 21. In October 2007, shortly after the initial plea agreement was signed, FBI agents contacted Jane Doe NI. On October 26, 2007, Special Agents and met in person with Jane Doe #1. The Special Agents explained that Epstein would 3 On about August 14, 200

t's desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients

ls the victims of federal sex crimes committed by Jeffrey Epstein ...." As you know, in 2008 your Office d

criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take t

confer with the attorney for the Government in the case"). Two days later (July 91h), the Government sent her a notice that, in light of defendant, Jeffrey Epstein's entry of guilty pleas to various state charges and 18-month jail sentence, the Government had agreed to defer all federal prosecution — including a

y Epstein ...." As you know, in 2008 your Office did not object to adding Jane Doe No. 2 into this litigation, recognizing that she was a victim of Epstein's crimes and had interests at stake in the case. We continue to be perplexed that you are not extending the same consideration to Jane Doe No. 3 an

t the Government to produce all evidence that it possesses supporting these facts, for reasons the victims explain in their contemporaneously-filed Jane Doe NI and Jane Doe #2's Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence. 3 EFTA00210792 Case 9:08-cv-80736-KAM

ring on Appropriate Remedies (unredacted), and a complete set of exhibits, including the e-mails in Exhibit A. The e-mails in Exhibit A are between Epstein's defense attorney and AUSA Villafalta. They were produced in civil litigation between Epstein and some of his victims. Epstein's attorneys redacted

e 15th Judicial Circuit in and for Palm Beach County (tereinaRer, the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey Epstein (hereinafter "Epstein"); IT APPEARING that the State Attorney's Of fice has charged Epstein by indictment with solicitation of prostitution, in vio

t's desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients

formally signed a non-prosecution agreement with Jeffrey Epstein that barred his I The victims are contem

criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take t

ary 2008 and May 2008. At no time before reaching the non-prosecution agreement did the Justice Department notify any victims, including for example Jane Doe NI, about the non-prosecution agreement. The victims were therefore prevented from exercising their CVRA right to confer with prosecutors about the ca

osecution Agreement, an October 2007 Addendum and a letter dated December 19, 2007 from the U.S. Attorney to Attorney Lilly Ann Sanchez , Counsel to Jeffrey Epstein (DE 35 at ¶3).' I I assume those involved in the above-referenced litigation, have copies of the relevant court filings, but if you desire any of t

he Victim's Petition further alleges that in violation of the CVRA, Jane Doe #1 was not consulted with respect to the USAO-SDFLA's negotiations with Epstein (DE 1 at ¶¶3-6). The "Jane Doe NI and Jane Doe # 2 Status Report and Response to Court's Order to Show Lack of Prosecution" (DE 41) argues that "th

States, Case No.: 08-80736-C1V- MARRA/Johnson AND Jeffrey Epstein As a follow-up to your recent meeting co

on of It• indicates that "in the summer of 2007, Mr. Epstein and the [USAO-SDFLA] entered into negotiations t

leges that in violation of the CVRA, Jane Doe #1 was not consulted with respect to the USAO-SDFLA's negotiations with Epstein (DE 1 at ¶¶3-6). The "Jane Doe NI and Jane Doe # 2 Status Report and Response to Court's Order to Show Lack of Prosecution" (DE 41) argues that "there [was] an orchestrated decision

osecution Agreement, an October 2007 Addendum and a letter dated December 19, 2007 from the U.S. Attorney to Attorney Lilly Ann Sanchez , Counsel to Jeffrey Epstein (DE 35 at ¶3).' I I assume those involved in the above-referenced litigation, have copies of the relevant court filings, but if you desire any of t

he Victim's Petition further alleges that in violation of the CVRA, Jane Doe #1 was not consulted with respect to the USAO-SDFLA's negotiations with Epstein (DE 1 at ¶¶3-6). The "Jane Doe NI and Jane Doe # 2 Status Report and Response to Court's Order to Show Lack of Prosecution" (DE 41) argues that "th

States, Case No.: 08-80736-C1V- MARRA/Johnson AND Jeffrey Epstein As a follow-up to your recent meeting co

Villafafia indicates that "in the summer of 2007, Mr. Epstein and the [USAO-SDFLA] entered into negotiations t

leges that in violation of the CVRA, Jane Doe #1 was not consulted with respect to the USAO-SDFLA's negotiations with Epstein (DE 1 at ¶¶3-6). The "Jane Doe NI and Jane Doe # 2 Status Report and Response to Court's Order to Show Lack of Prosecution" (DE 41) argues that "there [was] an orchestrated decision

case, the victims had (for example) no CVRA right to confer with prosecutors about a secret non-prosecution agreement barring federal prosecution of Epstein for crimes committed against the victims. This position contravenes the CVRA's plain language. The CVRA covers agencies involved in the "detection"

REC. S4260, 54269 (statement of Sen. Feinstein) (discussing § 377 l(d)(1) and explaining "[tjhis provision " The Government also attempts to raise Jeffrey Epstcin's "rights to Due Process." Gov't Resp. at 46. The victims are mystified as to why the Government would want to assert the rights of the criminal who

n- prosecution agreement (NPA) it negotiated with Jeffrey Epstein — an agreement that blocked federal pros

EFING SCHEDULE AND HEARING ON THE APPROPRIATE REMEDIES. For all the reasons just explained, the Court should find that the Government has violated Jane Doe NI and Janc Doe #2's rights under the CVRA. At the tail end of its brief, however, the Government briefly raises a flurry of desperate arguments to avo