EFTA00193211¶
West Palm Beach, FL 33401¶
Phone 561 209-1047¶
Fax 561 820-8777¶
From: Villafana, Ann Marie C. (USAFLS)¶
Sent: Thursday, September 18, 2008 7:21 PM¶
To: eto@flabar.org¶
Cc: Atkinson, Karen (USAFLS); Lee, Dexter (USAFLS)¶
Subject: Request for Written Staff Opinion¶
Dear Sir or Madam: Please see the attached correspondence. Thank you for your assistance.¶
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<<Final Victim Notification — Sample.pdf>>¶
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A. Marie Villafaña¶
Assistant U.S. Attorney¶
500 S. Australian Ave, Suite 400¶
West Palm Beach, FL 33401¶
Phone 561 209-1047¶
Fax 561 820-8777(See attached file: Florida Bar Ltr re Ethics Opinion.pdf)(See attached file: Final Victim Notification — Sample.pdf)(See attached file: Final Victim Notification Represented Sample.pdf)¶
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EFTA00193212¶
partment 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 ___, 2008¶
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-009495AXXXMB and 2008-¶
___) and was sentenced to a term of eighteen months’ imprisonment to be followed by ___ years of probation.¶
In light of the entry of the guilty plea and sentence, and pursuant to the terms of the deferred prosecution agreement between Epstein and the United States Attorney’s Office for the Southern District of Florida (hereinafter referred to as “the Office”), the Office hereby provides notice to Epstein that the following is a list of individuals whom the Office was prepared to name as victims in an Indictment charging Epstein with violations of federal statutes enumerated in Title 18, United States Code, Section 2255 (hereinafter referred to as “identified individuals”).¶
The terms of the deferred prosecution agreement provide that the identified individuals shall have the same right to seek damages pursuant to Title 18, United States Code, Section 2255, as they would have had if Mr. Epstein had been tried and convicted of those enumerated offenses in a federal court. Section 2255 provides, in relevant part:¶
Any person who, while a minor, was a victim of a violation of section … 2422, or 2423 of this title and who suffers personal injury as a result of such violation, regardless of whether the injury occurred while such person¶
EFTA00193213¶
NOTIFICATION OF IDENTIFIED VICTIMS JULY ___, 2008 PAGE 2 OF 3¶
was a minor, may sue in any appropriate United States District Court and shall recover the actual damages such person sustains and the cost of the suit, including a reasonable attorney’s fee. Any person as described in the preceding sentence shall be deemed to have sustained damages of no less than $150,000 in value.¶
Thus, pursuant to the deferred prosecution Agreement between the Office and Epstein, the Office hereby provides Notice to the identified individuals that each of them is a person who, while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, committed by Epstein. The Office further provides Notice to the identified individuals that, pursuant to the Agreement between the Office and Epstein, a copy of this document may be introduced in a judicial proceeding between any such identified individual and Epstein, and that any judicial authority interpreting this Notification, including any authority determining what evidentiary burdens, if any, a plaintiff must meet, shall consider that it is the intent of Epstein and the Office to place the identified individuals in the same position as they would have been had Epstein been convicted of those federal offenses.¶
Identified Individuals¶
| Jane Doe #1 | Jane Doe #11 | Jane Doe #21 |
| Jane Doe #2 | Jane Doe #12 | Jane Doe #22 |
| Jane Doe #3 | Jane Doe #13 | Jane Doe #23 |
| Jane Doe #4 | Jane Doe #14 | Jane Doe #24 |
| Jane Doe #5 | Jane Doe #15 | Jane Doe #25 |
| Jane Doe #6 | Jane Doe #16 | Jane Doe #26 |
| Jane Doe #7 | Jane Doe #17 | Jane Doe #27 |
| Jane Doe #8 | Jane Doe #18 | Jane Doe #28 |
| Jane Doe #9 | Jane Doe #19 | Jane Doe #29 |
| Jane Doe #10 | Jane Doe #20 | Jane Doe #30 |
R. ALEXANDER ACOSTA¶
UNITED STATES ATTORNEY¶
Dated: ___¶
By:¶
A. MARIE VILLAFAÑA¶
ASSISTANT U.S. ATTORNEY¶
ACKNOWLEDGEMENT¶
I have received this Notification from my attorney, Roy Black, Esquire, have read¶
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NOTIFICATION OF IDENTIFIED VICTIMS JULY ___, 2008 PAGE 3 OF 3¶
it and discussed it with my attorney, and I hereby acknowledge that it accurately sets forth my understanding and agreement with the Office of the United States Attorney for the Southern District of Florida. I understand that an exact copy of this Notification will be provided to each identified individual, except that the names of all other identified individuals will be redacted, and I hereby waive any evidentiary challenges to the introduction of a copy of this document—even in redacted form—in any judicial proceeding between any identified individual and myself.¶
Dated: ___¶
Jeffrey Epstein¶
Witnessed by:¶
Roy Black, Esquire¶