EFTA00177211¶
Case 9:08-cv-80, Jδ-KAM¶
Document 30 Entereon FLSD Docket 10/16/2018¶
LAW OFFICE¶
Page 1 of 2¶
AND ASSOCIATES¶
October 15, 2008¶
Dexter Lee, AUSA¶
United States Attorney’s Office¶
99 N.E. 4th Street¶
Miami, Florida 33132¶
Re: Jane Doe # and Jane Doe #2 United States of America¶
Case No.: 08-80736-CIV-MARRA/JOHNSON¶
Dear Mr. Lee:¶
I am writing to inquire about whether Mr. Epstein has violated his Non-Prosecution Agreement with the Government.¶
As you know, the Government has repeatedly described the Non-Prosecution Agreement as guaranteeing to the victims of Epstein’s sexual abuse at least $150,000 in civil damages. The Government has made these representations in reliance on a current provision in the U.S. Code – 18 U.S.C. § 2255(a) – which provides for an automatic amount of damages of at least $150,000. At the time that the Non-Prosecution Agreement was drafted and signed, that was the law that was in effect.¶
In Epstein’s latest filing in federal court, however, he takes the position that the pre-2006 Amendments version of the law applies. See Defendant Epstein’s Motion to Dismiss, for More Definite Statement and To Strike Directed to Plaintiff Jane Doe’s Complaint at 9, Jane Doe Jeffrey Epstein, No. 08-CIV-80893-Marra/Johnson (discussing § 2255 and stating that the “applicable version of the statute” is “pre-2006 Amendments”). The 2006 Amendments altered § 2255(a), by increasing the presumed minimum damages from $50,000 to $150,000. See Pub. L. 109-248, Title VII, § 707(b), (c), July 27, 2006, 120 Stat. 650.¶
In light of Epstein’s latest filing, I write to ask several questions:¶
(1) Would you stipulate that you told me several times that Epstein had agreed to pay at least $150,000 to the identified victims of his abuse?¶
(2) Did Epstein in fact agree to pay damages to the identified victims of his abuse at least $150,000?¶
(3) Did the Government tell victims, either directly or through counsel, that Epstein had agreed to pay his victims at least $150,000?¶
2028 HARRISON STREET, SUITE 202, HOLLYWOOD, FLORIDA 33020¶
OFFICE: 954-414-8033/305-935-2011 FAX: 954-924-1530/305-935-4227 BE@BRADEDWARDSLAW.COM¶
EFTA00177212¶
Case 9:08-cv-8U. J6-KAM¶
Document 36¶
Entere on FLSD Docket 10/16/2018¶
Page 2 of 2¶
Dexter Lee, AUSA¶
United States Attorney’s Office¶
October 15, 2008¶
Page Two¶
(4) Is Epstein in compliance with his Non-Prosecution Agreement with the Government when he is now taking the legal position, through his attorneys, that he only has to pay the victims $50,000 damages under § 2255?¶
Thank you for any clarification you can provide on these questions.¶
Sincerely,¶
BE/sg¶
Brad Edwards¶
cc: Ann Marie C. Villafaña, AUSA United States Attorney’s Office 500 South Australian Avenue West Palm Beach, Florida 33401¶
2028 HARRISON STREET, SUITE 202, HOLLYWOOD, FLORIDA 33020¶
OFFICE: 954-414-8033/305-935-2011 FAX: 954-924-1530/305-935-4227 BE@BRADEDWARDSLAW.COM¶
EFTA00177213¶
29¶