EFTA00177701Set 9
2008-07-1790p16,925w
Government's responsibility to use its "best efforts to see that crime victims are . . . accorded[]
the rights" in the CVRA, 18 U.S.C. § 3771(cX1), I was wondering whether the Government ... litigation, my
client is entitled to see them. See 18 U.S.C. § 3771(aX8) (victim's right to "be treated with
fairness"). In addition, your proposed stipulation states that: "On July ... sent a victim notification to Jane Doe #1 via her attorney, Bradley Edwards. which is attached as
Exhibit 6 to the Declaration. That notification contains a written explanation of thefull
https://www.justice.gov/epstein/files/DataSet%209/EFTA00177701.pdf
EFTA00267745Set 9
31p14,652w
POLICE TARGETING BY THE USE OF TECHNOLOGY - 1993 - 2021
ILLEGAL SURVEILLANCE PRIVACY OF VICTIMS OWN HOME
ORGANISED CRIME - SYNDICATE - CORRUPTION
OVERVIEW OF EVENTS ;
MOTIVE ;
Multiple Intellectual Property Theft occurring ... Privacy of victims own home over a 27 year period, first
recorded event in 1993 and continuing until last recorded event in 2021.
Multiple Intellectual Property Theft occurring following Hand ... party, including family
members, not installed on a computer, hand written in Privacy of victims own home 1993 - 2021.
Government and Police Illegal Surveillance, and including shared surveillance with organised
https://www.justice.gov/epstein/files/DataSet%209/EFTA00267745.pdf
EFTA00267683Set 9
31p14,629w
POLICE TARGETING BY THE USE OF TECHNOLOGY - 1993 - 2021
ILLEGAL SURVEILLANCE PRIVACY OF VICTIMS OWN HOME
ORGANISED CRIME - SYNDICATE - CORRUPTION
OVERVIEW OF EVENTS ;
MOTIVE ;
Multiple Intellectual Property Theft occurring ... Privacy of victims own home over a 27 year period, first
recorded event in 1993 and continuing until last recorded event in 2021.
Multiple Intellectual Property Theft occurring following Hand ... party, including family
members, not installed on a computer, hand written in Privacy of victims own home 1993 - 2021.
Government and Police Illegal Surveillance, and including shared surveillance with organised
https://www.justice.gov/epstein/files/DataSet%209/EFTA00267683.pdf
EFTA00078040Set 9
2021-03-2924p5,122w
minor girls by, among
other things, helping Epstein to recruit, groom, and ultimately
abuse victims known to MAXWELL and Epstein to be under the age
of 18. The victims were ... were
groomed and abused by MAXWELL and Epstein, both of whom knew
that certain victims were in fact under the age of 18.
2. As a part and in furtherance ... their scheme to
abuse minor victims, GHISLAINE MAXWELL, the defendant, and
Jeffrey Epstein enticed and caused minor victims to travel to
EFTA00078040
Case 1:20-cr-00330-AJN Document
https://www.justice.gov/epstein/files/DataSet%209/EFTA00078040.pdf
EFTA00078835Set 9
2011-04-0854p17,640w
JANE DOE #2'S
MOTION FOR FINDING OF VIOLATIONS OF THE CRIME VICTIM RIGHTS
ACT AND REQUEST FOR A HEARING ON APPROPRIATE REMEDIES
Respondent, United States of America ... appellate review, and provides that a
victim may not move to disturb a defendant's plea or sentence unless, among
other things, "the victim petitions the court of appeals ... victim's motion in the district court. 18
U.S.C. §§ 37771(d)(3), 3771(d)(5). We are mindful that the federal restitution
statutes are intended to protect victims, not defendants
https://www.justice.gov/epstein/files/DataSet%209/EFTA00078835.pdf
EFTA00083566Set 9
2019-02-2133p11,288w
addition to his own sexual abuse of the victims,
Epstein directed other persons to abuse the girls sexually. (DE 407 at ¶ 3.) Epstein used paid
employees to find and bring ... ultimately determined that both
Jane Doe 1 and Jane Doe 2 were victims of sexual abuse by Epstein while they were minors. Jane
Doe 1 provided information about her abuse ... Page 3 of 33
By March 15, 2007, the Office was sending letters to victims informing them of their
rights pursuant to the Crime Victims' Rights Act ("CVRA
https://www.justice.gov/epstein/files/DataSet%209/EFTA00083566.pdf
EFTA00098414Set 9
2019-02-2133p11,272w
addition to his own sexual abuse of the victims,
Epstein directed other persons to abuse the girls sexually. (DE 407 at ¶ 3.) Epstein used paid
employees to find and bring ... ultimately determined that both
Jane Doe 1 and Jane Doe 2 were victims of sexual abuse by Epstein while they were minors. Jane
Doe 1 provided information about her abuse ... Page 3 of 33
By March 15, 2007, the Office was sending letters to victims informing them of their
rights pursuant to the Crime Victims' Rights Act ("CVRA
https://www.justice.gov/epstein/files/DataSet%209/EFTA00098414.pdf
EFTA00081333Set 9
2019-02-2133p11,299w
addition to his own sexual abuse of the victims,
Epstein directed other persons to abuse the girls sexually. (DE 407 at ¶ 3.) Epstein used paid
employees to find and bring ... ultimately determined that both
Jane Doe 1 and Jane Doe 2 were victims of sexual abuse by Epstein while they were minors. Jane
Doe 1 provided information about her abuse ... Page 3 of 33
By March 15, 2007, the Office was sending letters to victims informing them of their
rights pursuant to the Crime Victims' Rights Act ("CVRA
https://www.justice.gov/epstein/files/DataSet%209/EFTA00081333.pdf
EFTA00164618Set 9
2019-07-0228p5,679w
reference.
B. Probable Cause Justifying Search of the Subject Premises
The Indictment and Victim-1
7. As set forth in Exhibit A, from at least in or about ... including at least in or about 2005, EPSTEIN sexually abused numerous
minor victims at the Subject Premises. In particular, and as alleged in the Indictment, when a
victim arrived ... Premises
with a massage table, where she would perform a massage on EPSTEIN. The victims, who were
as young as 14 years of age, were told by EPSTEIN or other
https://www.justice.gov/epstein/files/DataSet%209/EFTA00164618.pdf
EFTA01081533Set 9
2015-04-1122p6,321w
PRODUCTION
COME NOW Jane Doe No. 1 and Jane Doe No. 2 (the "victims"), by and through
undersigned counsel, to file this motion to compel the Government to provide answers ... requests for production involving Alan Dershowitz.
Some background: On April 11, 2015, the victims sent a Second Request for Admissions
and a Second Request for Production to the Government, seeking ... submit to the Court, via this motion to compel, the issue of whether
the victims' discovery requests are "reasonably calculated to lead to discovery of admissible
evidence
https://www.justice.gov/epstein/files/DataSet%209/EFTA01081533.pdf
EFTA01626027Set 10
2020-07-0818p3,380w
minor girls by, among
other things, helping Epstein to recruit, groom, and ultimately
abuse victims known to MAXWELL and Epstein to be under the age
of 18. The victims were ... were
groomed and abused by MAXWELL and Epstein, both of whom knew
that certain victims were in fact under the age of 18.
2. As a part and in furtherance ... their scheme to
abuse minor victims, GHISLAINE MAXWELL, the defendant, and
Jeffrey Epstein enticed and caused minor victims to travel to
EFTA01626027
Case 1:20-cr-00330-AJN Document
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01626027.pdf
EFTA00008874Set 6
18p3,208w
minor girls by, among
other things, helping Epstein to recruit, groom, and ultimately
abuse victims known to MAXWELL and Epstein to be under the age
of 18. The victims were ... were
groomed and abused by MAXWELL and Epstein, both of whom knew
that certain victims were in fact under the age of 18.
2. As a part and in furtherance ... their scheme to
abuse minor victims, GHISLAINE MAXWELL, the defendant, and
Jeffrey Epstein enticed and caused minor victims to travel to
GM_GLSDN Y_00000346
EFTA00008874
Epstein's residences
https://www.justice.gov/epstein/files/DataSet%206/EFTA00008874.pdf
EFTA00077180Set 9
2020-07-0818p3,380w
minor girls by, among
other things, helping Epstein to recruit, groom, and ultimately
abuse victims known to MAXWELL and Epstein to be under the age
of 18. The victims were ... were
groomed and abused by MAXWELL and Epstein, both of whom knew
that certain victims were in fact under the age of 18.
2. As a part and in furtherance ... their scheme to
abuse minor victims, GHISLAINE MAXWELL, the defendant, and
Jeffrey Epstein enticed and caused minor victims to travel to
EFTA00077180
Case 1:20-cr-00330-AJN Document
https://www.justice.gov/epstein/files/DataSet%209/EFTA00077180.pdf
EFTA00091565Set 9
2020-07-0818p3,380w
minor girls by, among
other things, helping Epstein to recruit, groom, and ultimately
abuse victims known to MAXWELL and Epstein to be under the age
of 18. The victims were ... were
groomed and abused by MAXWELL and Epstein, both of whom knew
that certain victims were in fact under the age of 18.
2. As a part and in furtherance ... their scheme to
abuse minor victims, GHISLAINE MAXWELL, the defendant, and
Jeffrey Epstein enticed and caused minor victims to travel to
EFTA00091565
Case 1:20-cr-00330-AJN Document
https://www.justice.gov/epstein/files/DataSet%209/EFTA00091565.pdf
EFTA00097783Set 9
2020-07-0818p3,380w
minor girls by, among
other things, helping Epstein to recruit, groom, and ultimately
abuse victims known to MAXWELL and Epstein to be under the age
of 18. The victims were ... were
groomed and abused by MAXWELL and Epstein, both of whom knew
that certain victims were in fact under the age of 18.
2. As a part and in furtherance ... their scheme to
abuse minor victims, GHISLAINE MAXWELL, the defendant, and
Jeffrey Epstein enticed and caused minor victims to travel to
EFTA00097783
Case 1:20-cr-00330-AJN Document
https://www.justice.gov/epstein/files/DataSet%209/EFTA00097783.pdf
EFTA00208359Set 9
2011-03-2115p4,101w
COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and
through undersigned counsel, to move for an order from this Court directing ... civil cases, requiring the Government to make appropriate
production of such evidence to the victims.
BACKGROUND
In discussions with the U.S. Attorney's Office about this case, counsel for Jane ... Jane Doe #2 inquired about whether the Office would voluntarily provide to the victims
information in its possession that was material and favorable to the victims' case. Victims'
counsel pointed
https://www.justice.gov/epstein/files/DataSet%209/EFTA00208359.pdf