Text extracted via OCR from the original document. May contain errors from the scanning process.
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EXHIBIT 1
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CASE NO. 08-80736-CIV-MARRA
JANE DOE #1 and JANE DOE #2,
Petitioners,
vs.
Respondent.
DECLARATION OF
1.
My name is
and 1 was born in
2.
I am currently
3.
I grew up in Palm Beach, Florida. When I was little, I loved animals and wanted
to be a veterinarian. But my life took a very different turn when adults began to be interested in
having sex with me.
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6.
I came back for several days following and did the same sorts of sexual things for
Epstein.
8.
So I started "working" exclusively for Epstein. He took me to New York on his
big, private jet. We went to his mansion in Ncw York City. I was shown to my room, a very
luxurious room. The mansion was huge. I got scared because it was so big. Epstein brought me
to a room with a massage parlor. To me, it looked like an S&M parlor. Epstein made me engage
in sexual activities with him there.
9.
You can see how young I looked in the photograph below.
2
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10.
Epstein took me on a ferry boat on one of the trips to New York City and there he
took the picture above. I was approximately IS or 16 years old at the time.
12.
I was trained to be "everything a man wanted me to be."
It wasn't just sexual
training - they wanted me to be able to cater to all the needs of the men they were going to send
me to. They said that they loved that I was very compliant and knew how to keep my mouth
shut.
14.
From very early on I was fearful of Epstein. Epstein told me he was a billionaire.
I told my mother that I was working for this rich guy, and she said "go, go far away." Epstein
had promised me a lot, and I knew if I left I would be in big trouble. I also knew that I was a
witness to a lot of illegal and very bad behavior by Epstein and his friends. If I left Epstein, he
knew all kinds of powerful people. He could have had me killed or abducted, and I always knew
he was capable of that if I did not obey him. He let me know that he knew many people in high
places. Speaking about himself, he said "I can get away" with things.
I was very scared,
particularly since I was a teenager.
3
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16.
To illustrate my connection to these places, I include four photographs taken of
me in New Mexico (shown below). The first one is a museum in Santa Fe, New Mexico. We
had gone sightseeing for the day. Epstein took this picture of me. I was approximately 17 at the
time, judging from the looks of it. At the end of the day we returned to Epstein's Zorro Ranch.
The second picture is me on one of Epstein's horses on the ranch in New Mexico. The following
two are from wintertime in New Mexico.
4
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17.
When I was with him, Epstein had sex with underage girls on a daily basis. His
interest in this kind of sex was obvious to the people around him. The activities were so obvious
5
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and bold that anyone spending any significant time at one of Epstein's residences would have
clearly been aware of what was going on.
18.
Epstcin's code word for sexual encounters was that it was a "massage". At times
the interaction between Epstein and the girls would start in a massage room setting, it was
always a sexual encounter and never just a massage.
6
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II
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54.
I now understand that Epstein reached a non-prosecution agreement with the
federal government in 2007 and pled guilty to two state crimes in June 2008. I now know that I
was identified by the federal government as one of Epstein's and his co-conspirator's sexually
abused victims. However, no one told me about those events until after they happened.
55.
On September 3, 2008, the FBI sent a victim notification letter to me. This was
the first written communication I had received from the FBI. The letter is attached as Exhibit I.
The letter describes an agreement in which compensation would be made victims of Epstein's
12
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sexual abuse. The letter also said that the federal government was going to "defer federal
prosecution." No one had told me about deferring federal prosecution before this.
56.
In 2011, two FBI agents, called me in Australia and then came to meet me. They
met me at the U.S. Consulate in Sidney. They seemed to be very professional and hard working.
I thought to myself, "Wow, these people will do the right thing against the bad guys and protect
me."
57.
The agents wcrc mainly focused on Epstein but while there 1 provided them some
information about others who wcrc involved in illegal acts as well. I was aware that a false
statement to these law enforcement officers was a crime and I told the truth — giving them the
information that I could recall about the individuals they inquired about.
58.
Epstein also trafficked me for sexual purposes to many other powerful men,
including politicians and powerful business executives. Epstein required me to describe the
sexual events that I had with these men presumably so that he could potentially blackmail them.
I am still very fearful of these men today.
60.
In this affidavit, I have tried to focus on how I was trafficked for sexual purposes.
I have not described all of the details of the sexual activities Epstein forced me to have. Also, I
have not described all of the details of the other events discussed here. If a judge wants me to
13
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present my information in more detail, including more specific descriptions of the sexual
activities with the men Epstein sent me to, I could do so.
61.
I have directed my attorneys, Bradley). Edwards and Paul G. Cassell, to pursue
all reasonable and legitimate means to have criminal charges brought against these powerful
people for the crimes they have committed against me and other girls. They are representing me
in this case pro bono.
62.
Since I filed my motion in this case. my credibility has been attacked. I am telling
the truth and will not let these attacks prevent me from exposing the truth of how I was trafficked
for sex to many powerful people. These powerful people seem to think that they don't have to
follow the same rules as everyone else. That is wrong. I hope that by coming forward, I can
help expose the problem of sex trafficking and prevent the same sort of abuse and degradation
that happened to me from happening to other girls.
63.
I declare under penalty of perjury that the foregoing is true and correct.
Executed this 14-1 fsday of January. 2015.
(Location of signature left undisclosed for security reasons)
14
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EXHIBIT 1
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US. Department ofjustice
7
United Slates Attorney
Southern District of Florida
300 South Australian Ave.. Suite 400
West Palm Beach FL 3340/
(560 B30-871I
Facsimile: (560 820-8777
September 3, 2008
NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
EXCEPT IN
CONNECTION
WITH
A
LEGAL
PROCEEDING.
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U.S. Department of Justice
United States Attorney
Southern District of Florida
500 South Australian Ave., Suite 400
West Palm Beach, FL 33401
(561) 8204711
Facsimile. (561)8204771
September 3, 2008
VIA COURIER
Re:
Jeffrey Epstein/
NOTIFICATION OF
Dear
By virtue of this letter, the United States Attorney's Office for the Southern District
of Florida provides you with the following notice because you are an identified victim of a
federal offense.
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 ofprostitution)
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-009454AXXXMB and 2008-cf-
00938 1 AYJOCIAB) 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 I, 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, including the following:
1.
An independent Special Master was assigned the task of selecting an
attorney representative to represent the victims, including you, in
connection with civil actions between the victims and Mr. Epstein. The
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SEPTEMBER 3, 2009
PAGE 2 Ora
Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
Orseck, P.A., a highly-respected and experienced attorney. You are not
obligated to use Mr. Josefsberg as your civil attorney, but, as explained
in greater detail below, Mr. Josefsbag's services will be provided at no
cost to you because Mr. Epstein is obligated to pay the costs and fees
of the attorney-representative. Also, Mr. Epstein and his attorneys can
only contact you via Mr. Josefsberg, assuming that you would like Mr.
Josefsberg to serve as your attorney.
2.
If you elect to file suit against Mr. Epstein pursuant to Title 18, United
States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
of the United States District Court for the Southern District of Florida
over his person and/or the subject matter, and Mr. Epstein waives his
right to contest liability and also waives his right to contest damages up
to an amount as agreed to between you and Mr. Epstein, so long as you
elect to proceed exclusively under I8 U.S.C. § 2255, and you waive any
other claim for damages, whether pursuant to state, federal, or common
law. Notwithstanding this waiver, Epstein's agi cement with the United
States, his waivers and failure to contest liability and such damages in
any suit are not to be construed as an admission of any criminal or civil
liability.
3.
As stated above, Mr. Epstein has agreed to pay the fees of the attorney
representative selected by the independent third party. This provision,
however, shall not obligate Epstein to pay the fees and costs of
contested litigation filed against him. Thus, if after consideration of
potential settlements, you and Mr. Josefsberg elect to file a contested
lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
contested remedy, the obligation to pay the costs of the attorney
representative, as opposed to any statutory or other obligations to pay
reasonable attorneys fees and costs such as those contained in Section
2255, shall cease.
Please contact either myself at
or Justice
Department Victim-Witness Specialist Twi ler Smith at
with a good
telephone number andior e-mail address, so that we may provide Mr. Josefsberg with a
timely means of communicating with you. It' you would like to contact Mr. Josefsberg
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SEPTEMBER 3.2008
PAGE 3 OF 3
directly, he can be reached at +1 305 358.2800.
If you have already selected other counsel to represent you, or if you do so in the
future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
659-8300.
In addition, there has been litigation between the United States and two other victims
regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
to represent you, that attomey can review the Court's order in the matter of In re Jane Does
1 and 2, United States District Court for the Southern District of Florida Court File No. 08-
80736-CIV-MARRA.
Please understapd that neither the U.S. Attorney's Office nor the Federal Bureau of
Investigation can take part in or otherwise assist in civil litigation. Thank you for all of your
assistance during the course of the federal and state investigations and please accept the
heartfelt regards of myself and Special Agents Kuyrkendall, Slater, and Richards for your
health and well-being.
Sincerely,
R. Alexander Acosta
United States Attorney
By:
cc:
Robert Josefsberg, Esq.
Jack Goldberger, Esq.
A. Marie Villafaha
Assistant United States Attorney
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