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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
l at-564-209--Enentl-this-mentifte-1-am-nweting-widt-the-agents-and-want-to-give-them4heir marching orders regarding what they can tell the girls." U.S. Attorneys Correspondence at 359. The reasonable inference is that the "marching orders" agreed to between the Government and Epsteinls-tiefense-eounsel-was-that-ne-mention-
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
to abide by the terms and conditions of the September 24, 2007 Agreement as amended by letter from United States Attorney Acosta to Jay Lefkowitz." U.S. Attorneys Correspondence at 290-91. 33. In about April 2008, Jane Doe #1 contacted the FBI because Epstein's counsel was attempting to take her deposition and private inve
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
to abide by the terms and conditions of the September 24, 2007 Agreement as amended by letter from United States Attorney Acosta to Jay Lefkowitz." U.S. Attorneys Correspondence at 290-91. 34. In about April 2008, Jane Doe #1 contacted the FBI because Epstein's counsel was attempting to take her deposition and private inve
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
to abide by the terms and conditions of the September 24, 2007 Agreement as amended by letter from United States Attorney Acosta to Jay Lefkowitz." U.S. Attorneys Correspondence at 290-91. 33. In about April 2008, Jane Doe #1 contacted the FBI because Epstein's counsel was attempting to take her deposition and private inve
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
to abide by the terms and conditions of the September 24, 2007 Agreement as amended by letter from United States Attorney Acosta to Jay Lefkowitz." U.S. Attorneys Correspondence at 290-91. 34. In about April 2008, Jane Doe #1 contacted the FBI because Epstein's counsel was attempting to take her deposition and private inve
Justice Department would makes its "best efforts" to protect Jane Doe #2's rights, including "Nike 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 involving . . . plea . . . ." The notification further expla
have one week to abide by the terms and conditions of the September 24, 2007 Agreement as amended by letter from United States Attorney Lefkowitz." U.S. Attorneys Correspondence at 290-91. 17 to Jay EFTA00207896 39. On May 30, 2008, another of Mr. Edwards's clients who was recognized as an Epstein victim by the U.S. Att
e Justice Department would makes its "best efforts" to protect Jane Doe #2's rights, including "Rpm 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 involving . . . plea . . . ." The notification further expla
to abide by the terms and conditions of the September 24, 2007 Agreement as amended by letter from United States Attorney Acosta to Jay Lefkowitz." U.S. Attorneys Correspondence at 290-91. 17 EFTA00235767 39. On May 30, 2008, another of Mr. Edwards's clients who was recognized as an Epstein victim by the U.S. Attorney's
Entities connected to both United States and U.S. Attorneys Correspondence

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