8
Shared Docs
8
Same-Page
8 / 8
Mentions
nce of a September 2007 Non-Prosecution 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 filin
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
nce of a September 2007 Non-Prosecution 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 filin
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
torney's Office and Epstein was subsequently modified by an October 2007 Addendum and a December 19, 2007, letter from the U.S. Attorney to Attorney Lilly Ann Sanchez. The U.S. Attorney's Office did not confer with any of the victims about these modifications of the agreement (or even notify them of the existence
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
torney's Office and Epstein was subsequently modified by an October 2007 Addendum and a December 19, 2007, letter from the U.S. Attorney to Attorney Lilly Ann Sanchez. The U.S. Attorney's Office did not confer with any of the victims about these modifications of the agreement (or even notify them of the existence
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
torney's Office and Epstein was subsequently modified by an October 2007 Addendum and a December 19, 2007, letter from the U.S. Attorney to Attorney Lilly Ann Sanchez. The U.S. Attorney's Office did not confer with any of the victims about these modifications of the agreement (or even notify them of the existence
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
torney's Office and Epstein was subsequently modified by an October 2007 Addendum and a December 19, 2007, letter from the U.S. Attorney to Attorney Lilly Ann Sanchez. The US. Attorney's Office did not confer with any of the victims about these modifiCations of the agreement (or even notify them of the existence
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
secution Agreement ("Part I"); (2) an October 2007 Addendum ("Part 2"); and (3)a letter dated December 19, 2007, from the U.S. Attorney to Attorney Lilly Ann Sanchez, counsel to Jeffrey Epstein ("Part 3"). EFTA00234649 Case 9:08-cv-80736-KAM Document 35 Entered on FLSD Docket 12/22/2008 Page 2 of 4 4. On J
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
secution Agreement ("Part I"); (2) an October 2007 Addendum ("Part 2"); and (3)a letter dated December 19, 2007, from the U.S. Attorney to Attorney Lilly Ann Sanchez, counsel to Jeffrey Epstein ("Part 3"). EFTA00213127 Case 9:08-cv-80736-KAM Document 35 Entered on FLSD Docket 12/22/2008 Page 2 of 4 4. On J
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
Entities connected to both Lilly Ann Sanchez and Jane Doe NI

Jeffrey Epstein
PERSONJoseph L. Ackerman
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
United States
LOCATION
Alexander Acosta
PERSON
Jay Lefkowitz
PERSON
Lesley Groff
PERSONthe Southern District
LOCATION
George W. Bush
PERSONJane Doe
PERSONLeon Black
PERSON
Department of Justice
ORGANIZATION
Ken Starr
PERSONFBI
ORGANIZATION
Alan Dershowitz
PERSON
A. Marie Villafana
PERSON
Marc Rich
PERSONAnn Sanchez
PERSON