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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2 I. UNITED STATES JOINT STATEMENT OF UNDISPUTED FACTS The parties hereby stipulate and agree that the following facts are not in dispute and may be accepted as true
ensued between the United States and Epstein. Despite the investigation revealing that Epstein had molested more than 40 minor girls, in Late 2007, the United Stales entered into a non- prosecution agreement (NPA) with Epstein - esseNiatly egree:ng to immunize Epstein for al of the Federal Sex crimes he committed
copy of the terms was not provided. A notification was not provided to Jane Doe #2 because the agreement limited Epstein's liability to victims whom the United States was prepared to name in an indictment. As a result, Jane Doe #2 never received a notification a letter about the agreement. The-rietifieation4id-net
on the [NPA] when seeking civil relief against Epstein . . . and affirmatively advanced the terms of the [NPA] as a basis for relief from Epstein." United States' Reply in Support of its Motion to Dismiss for Lack of Subject Matter Jurisdiction, Doc. 205-6 at 12-13. After reaping the benefits of the NPA, the
her cooperation with the investigation and contacted other potential witnesses and victims to advise them against cooperating with the authorities. Edwards Declaration at ¶ 5. 7. In and around September 2007, plea discussions took place between Jeffrey Epstein, represented by numerous attorneys (including lead cr
Justice Department would makes its "best efforts" to protect Jane Doe #1's rights, including "[t]he 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 EFTA00206695 involving . . . plea . . . ." The notificatio
ion of Bradley J. Edwards, Esq. at 1 (hereinafter "Edwards Declaration"). The Palm Beach County State Attorney's Office was investigating the case. Edwards Declaration at 1. 3. The FBI determined that both Jane Doe #1 and Jane Doe #2 were victims of sexual assaults by Epstein while they were minors beginning when
copy of the terms was not provided. A notification was not provided to Jane Doe #2 because the agreement limited Epstein's liability to victims whom the United States was prepared to name in an indictment. As a result, Jane Doe #2 never received a 17 EFTA00206780 notification a letter about the agreement. The n
n agreement. Edwards Declaration at & 15. 40. On July 9, 2008, AUSA sent a victim notification to Jane Doe #1 via her attorney, Bradley Edwards. Edwards Declaration, Exhibit "H." That notification contains a written explanation of some of the terms of the agreement between Epstein and the U.S. Attorney's Office
Justice Department would makes its "best efforts" to protect Jane Doe #1's rights, including "[t]he 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 EFTA00206732 involving . . . plea . . . ." The notificatio
ion of Bradley J. Edwards, Esq. at 1 (hereinafter "Edwards Declaration"). The Palm Beach County State Attorney's Office was investigating the case. Edwards Declaration at 1. 3. The FBI determined that both Jane Doe #1 and Jane Doe #2 were victims of sexual assaults by Epstein while they were minors beginning when
copy of the terms was not provided. A notification was not provided to Jane Doe #2 because the agreement limited Epstein's liability to victims whom the United States was prepared to name in an indictment. As a result, Jane Doe #2 never received a 17 EFTA00206851 notification a letter about the agreement. The n
n agreement. Edwards Declaration at & 15. 40. On July 9, 2008, AUSA sent a victim notification to Jane Doe #1 via her attorney, Bradley Edwards. Edwards Declaration, Exhibit "H." That notification contains a written explanation of some of the terms of the agreement between Epstein and the U.S. Attorney's Office
copy of the terms was not provided. A notification was not provided to Jane Doe #2 because the agreement limited Epstein's liability to victims whom the United States was prepared to name in an indictment. As a result, Jane Doe #2 never received a notification a letter about the agreement. The-noticieatien-did-not
n—agreement7 Edwards Declaration at & 15. 40. On July 9, 2008, AUSA sent a victim notification to Jane Doe #1 via her attorney, Bradley Edwards. Edwards Declaration, Exhibit "H." That notification contains a written explanation of some of the terms of the agreement between Epstein and the U.S. Attorney's Office
Entities connected to both United States and Edwards Declaration

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
Alexander Acosta
PERSONJane Doe
PERSONFBI
ORGANIZATION
Kenneth Marra
PERSON
Bradley Edwards
PERSON
Scarlett Johansson
PERSONJack Goldberger
PERSONMaria Farmer
PERSON
Lesley Groff
PERSON
Jay Lefkowitz
PERSON
Paul Cassell
PERSON
A. Marie Villafana
PERSON
Palm Beach Police Department
ORGANIZATION
West Palm Beach
LOCATION
Harvey Weinstein
PERSON
Jeffrey Sloman
PERSON