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ictim of a violation of lenumemtod $04)(1011x of Title l8) and who suffers personal injury as a m utt of such violation ...may sue In any oppropioto United Stales 011trint Court and shall recover the actual damages such person sustains and the cost of the suit, includingii reasonable attorney's fee." toot U
litigant. to contest allegations made against him seem to contradict the principles of justice and fairness that fire embedded in the tenets of the United Slates Attorney's Office. I also assert that on both a principled and practical level. the mere involvement of your Office in the matter with respect to
NETT MIAMI • F00 LAUDERDALE • WraT PALM UfA01 • 5T. PETER5OLMO 3067800201 December 7, 2007 Jeffrey Sloman First Assisiam United States Attorney United Stales Attorney's Office Southern District of Florida Re: Jeffrey Epstein Dear Jeff: 1-(466 P.002/004 F-016 Callnac) 5810 FIALA FouNi0arni nowt 130
d victims. This letter is meant to assist you in performing your duties by providing you with background information regarding the agreement between the United States and Jeffrey Epstein and the duties that the attorney representative will have to perform. The Federal Bureau of Investigation and the U.S. Attorney
e Petitioners have not been attempting to negotiate with the government for more than 30 months. As set forth in the Procedural I Iistory Section of the United States' Opposition to Jane Doe #1 and Jane Doe #2's Motion for Finding of Violations of the Crime Victim Rights Act ("CVRA"), at the last hearing on the Pet
13. who was appointed by the parties to select the attorney representative. informe r. Pp s counsel that he received a telephone call from Mr. Oeariz directly requesting that Judge appoint him as the attorney s entative in this matter. Although it is unclear how Mr. cariz even knows that Judge
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
-of the pela agreement. (Sorry 1-jual-have-a-bies-against-ptaintiffsz-atterneysel.687 Attorney's Correspondence at 157. Villafana continued to push Oeariz as the best choice, in EFTA00191269 beeause4t-weukl-redttee-publiei ne-niee4hing-about-Beft-feeafi*is-that-he4s-in-Miatni where-teheF-has-beea-al
this procedure because. as I mentIona I think It to probably in their best WOWS. In terms of plea agreement language. let me suggest the following: Thu United Slates agrees to make a minion seeking the appointment of a Guardian ad titan to mpresent the identified victims, Following the appointment of such Guardia
mber I I, 2007 Page 4 The final agreement was very similar to what was proposed by Ms. Villotbna in her initial draft agreement on July 31. 2007: The United Stoles shall provide l3poein's anomey's with u list of individuals whom ii fins identified as victims, as defined in IR U.S.C. § 2255. alter Epstein has si
hich point they were eliminated by your Office: IT APPEARING, idler an invizligation of the offenses and Epstcin's background, thin the interest or the United Stales pursuant to the Petite policy will be served by the Following procedure ... Epstein understands that the United Stales Attorney has no authority to
IJSAO conceded that it was inappropriate for its attorneys to select the attorney representative, Ms. Villafana continued to impro rly lobby for Mr. Oeariz's appointment. On October 19, 2007, retired Judge Edward B. who was appointed by the parties to select the attorney representative. informed Mr. E
to undcdakc discussion with the Slate Attomey's Office Ia custom caswpiiiiitim with these procedures. which compliance will be necessary to satisfy the United States' intero.t, pursuant to the Petite policy. We reiterate that this case was at heart a local mutter that was being billy addressed by the state crimi
ugh such misconduct was, as we contend it is, inextricably intertwined with the credibility of the accusations being made against Mr. Epstein by the United States Attorney's Office in Miami (''USAO"). Moreover. CEOS did not assess the terms of the Deferred Prosecution Agreement now in effect, nor did CEOS revi
n. Even after your Office conceded that it was inappmpriate for its attorneys to select the attorney representative. Ms. continued to lobby for Mr. Oeariz's appointment. ()n October 19. 2007, retired Judge %%3 Davis. who was appointed by the panics to select the attorney representative. informed Mr.
S L LP Jay P I otternWs, P C. loP 11Wr r ly blk Orland can VIA FACSIMILE (303) SM1-4444 Honorable R. Alexander Acosta united States Attorney United Slates Attorney's ()filet Southern District of Florida 99 NE itlh Street Miami. Fla 33132 Dear Alex: nap MIn IARD 'Armen-. Cinarmap Conte, 153 Emit
to undertake discussion with the Slate Attorney's 011ie,: to ensure compliance with these procedures. which compliance will he necessary to satisfy the United Status' interest. pursuant In the Poise policy. We reiterate that this ease was at heart a local matter that was being fully addressed by the state crimin
o sett e civil claims. First. she inappropriately attempted to nominate !lambert "Hen" Oeariz for attorney representative. despite the fact that Mr. Oeariz has a longstanding relationship with friend and law school classmate of from counsel. We also learned from Mr. Ocariz turns out to he a very good
Entities connected to both United States and Oeariz

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATIONLeon Black
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Alexander Acosta
PERSONJane Doe
PERSONFBI
ORGANIZATION
Kenneth Marra
PERSON
Bradley Edwards
PERSON
Bill Clinton
PERSON
Scarlett Johansson
PERSONJack Goldberger
PERSON
Joe Biden
PERSON
Jay Lefkowitz
PERSON
Paul Cassell
PERSON
A. Marie Villafana
PERSON
the United States District Court
ORGANIZATION