U.S. Department of Justice¶
United States Attorney Southern District of Florida¶
FILE COPY¶
500 South Australian Ave., Suite 400¶
West Palm Beach, FL 33401¶
(561) 820-8711¶
Facsimile: (561) 820-8777¶
July 10, 2008¶
NOTIFICATION OF IDENTIFIED VICTIMS¶
NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED STATES CODE, SECTION 3509(d) AND FLORIDA LAW, THE ATTACHED DOCUMENT IS TO BE TREATED AS CONFIDENTIAL AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTION WITH A LEGAL PROCEEDING.¶
EFTA00189893¶
U.S. Department of Justice¶
United States Attorney¶
Southern District of Florida¶
500 South Australian Ave., Suite 400¶
West Palm Beach, FL 33401¶
(561) 820-8711¶
Facsimile: (561) 820-8777¶
July 10, 2008¶
VIA CERTIFIED MAIL¶
Jack A. Goldberger, Esq.¶
Atterbury, Goldberger & Weiss, P.A.¶
One Clearlake Centre, Suite 1400¶
250 Australian Ave S.¶
West Palm Beach, FL 33401-5015¶
Re: Jeffrey Epstein¶
Dear Mr. Goldberger:¶
FINAL NOTIFICATION OF IDENTIFIED VICTIMS¶
On June 30, 2008, Jeffrey Epstein (hereinafter referred to as “Epstein) entered a plea of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-009454AXXMB and 2008-cf-009381AXXMB) and was sentenced to a term of twelve months’ imprisonment to be followed by an additional six months’ imprisonment, followed by twelve months of Community Control 1, with conditions of community confinement imposed by the Court.¶
In light of the entry of the guilty plea and sentence, the United States has agreed to defer federal prosecution in favor of this state plea and sentence, subject to certain conditions.¶
One such condition to which Epstein has agreed is the following:¶
“Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes¶
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JACK GOLDBERGER, ESQ. JULY 10, 2008 PAGE 2 OF 2¶
of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.”¶
Through this letter, this Office hereby provides Notice that the individuals identified below are individuals whom the United States was prepared to name as victims of an enumerated offense.¶
Identified Individuals¶
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- JOSEPH R. ATTERBURY
† JACK A. GOLDBERGER¶
JASON S. WEISS¶
- Board Certified Criminal Trial Attorney
† Member of New Jersey & Florida Bars¶
July 10, 2008¶
Assistant United States Attorney¶
500 S. Australian Avenue¶
4th Floor, Suite 400¶
West Palm Beach, Florida 33401¶
SENT VIA E-MAIL & FACSIMILE¶
(561) 820-8777¶
Re: Jeffrey E. Epstein¶
Dear¶
Thank you for your letter of yesterday. Kindly allow me a few follow-up points.¶
First, we respectfully request a reasonable opportunity to review and comment on a draft of the modified notification letter you intend to mail before you send it.¶
Second, we respectfully ask that you provide us with the identity of the victims’ rights organization described in your letter; the name and contact information of the person at that organization with whom the Government has been communicating; copies of any communications with that organization and the pro-bono lawyers/groups who were recommended by that organization; and a description of any non-written communications that the Government has had with that organization and the pro-bono lawyers/groups.¶
Third, while we appreciate your offer to disclose the names of the lawyers currently representing the individuals when you have finished compiling all of that information, we would be very grateful if you would provide any contact information you do have, on a rolling basis.¶
Fourth, would it be possible for you to advise us of the full name of the minor to whom you have referred by initials, as well as the identities of the three individuals whom the Government notified about the deferred-prosecution agreement shortly after its signing (as¶
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indicated in your letter of December 13, 2007)?¶
Fifth, please recall that Mr. Sloman wrote to Judge Davis on October 25, 2007 that “The United States takes no position as to the validity of any such claim under this statute.” To avoid any appearance that the United States is endorsing or encouraging litigation by the identified individuals, we believe that such a statement should be included in any notification letter.¶
I look forward to receiving your input on these issues. Until then, I remain,¶
Jack A. Goldberger¶
JAG/na¶
cc: Jeffrey E. Epstein¶
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