EFTA01109331Set 9
2009-07-2752p14,953w
therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and,
as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to
this Section ... right by a jury.
COUNT 66
Cause of Action Pursuant to 18 U.S.C. 6 2255
Page 101 of 234
101 of 234
EFTA01109331
Case 9:09-cv-81092-JIC Document ... other crimes, specifically including, but not limited to,
those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e).
L.M. is therefore a victim
https://www.justice.gov/epstein/files/DataSet%209/EFTA01109331.pdf
EFTA01109231Set 9
2009-07-2450p14,349w
jurisdiction of this action and the claims set forth herein
pursuant to 18 U.S.C. § 2255. L.M. seeks damages in excess of 1 million dollars.
7. This Court has venue ... this action pursuant to 28 U.S.C. § 1391(b), as a
substantial part of the events giving rise to the claims occurred in this District.
STATEMENT OF FACTS
8. Upon information ... other crimes, specifically including, but not
limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(b), and § 2423(e).
17. The crimes committed against L.M. by Epstein were
https://www.justice.gov/epstein/files/DataSet%209/EFTA01109231.pdf
EFTA00212996Set 9
2009-04-2019p6,697w
jurisdiction of this action and the claims set forth herein pursuant
to 18 U.S.C. § 2255.
7. This Court has venue of this action pursuant to 28 U.S.C ... other crimes, specifically including, but not limited to, those crimes
designated in 18 U.S.C. § 2422(b), § 2423(b), § 2423(c), § 2251, § 2252, § 2252A(a)(1), §
2252A ... liability unto Plaintiff, Jane Doe. Plaintiff hereby exclusively seeks civil remedies
pursuant to 18 U.S.C. § 2255.
COUNT ONE
(Cause of Action for Coercion and Enticement of Minor to Enaaae
https://www.justice.gov/epstein/files/DataSet%209/EFTA00212996.pdf
EFTA00189787Set 9
2009-06-0914p4,999w
victims identified in the federal investigation file
suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the U.S.
District Court for the Southern District of Florida ... referred to in paragraph (7),2 supra, elects to file suit
pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the
United States District Court ... Epstein, so long as the
identified individual elects to proceed exclusively under 18 U.S.C. § 2255,
and agrees to waive any other claim for damages, whether pursuant to state,
federal
https://www.justice.gov/epstein/files/DataSet%209/EFTA00189787.pdf
EFTA00208970Set 9
2007-09-2776p17,680w
identified 40 young women who can be characterized as victims pursuant to 18
U.S.C. § 2255. Some of those women went to Mr. Epstein's home only once, some went
there ... Florida for any victim who chose to sue him for
damages pursuant to 18 U.S.C. § 2255. Mr. Epstein agreed to provide an attorney for victims
who elected to proceed exclusively ... individuals referred to in paragraph (7), supra, elects to file suit
pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the
United States District Court
https://www.justice.gov/epstein/files/DataSet%209/EFTA00208970.pdf
EFTA00213453Set 9
2007-09-2379p13,346w
commerce for the purpose of engaging in illicit sexual conduct, as
defined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18,
United States Code, Section ... commerce for the purpose of engaging in illicit sexual
conduct, as defined in 18 U.S.C. § 2423(f), with minor females; in violation
Page 1 of 6
EFTA00213458
of Title ... would be caused to engage in a
commercial sex act as defined in 18 U.S.C. § 1591(cX1); in violation of Title
18, United States Code, Sections
https://www.justice.gov/epstein/files/DataSet%209/EFTA00213453.pdf
EFTA01125545Set 9
2009-03-1515p7,691w
commission of a Federal
offense or an offense in the District of Columbia," 18 U.S.C. § 3771(e), may assert
statutory rights in federal criminal proceedings "involving an offense against ... crime
victim." 18 U.S.C. § 3771(b)(I).
No rights in criminal proceedings against persons who were not charged with any
offense, were not charged (if before trial or plea ... Accused
Victims have a "right to be reasonably protected from the accused." 18 U.S.C. §
3771(a)(1). Because there must be an "accused," a "complaint, information or indictment
of conduct
https://www.justice.gov/epstein/files/DataSet%209/EFTA01125545.pdf
EFTA01718506Set 10
2007-12-17100p26,890w
alleged victims pursuant to the Justice for All Act of 2004. First, 18 U.S.C.
§ 2255, the relevant statute under the Agreement for the settlement of civil remedies, does not
have ... list of individuals "whom it has identified as victims, as defined in 18 U.S.C. § 2255."
Indeed, you have told us that at least one identified individual is currently 24 years ... Fifth, your letter mischaracterizes the nature of Mr. Epstein's liability under the 18
U.S.C. § 2255 provisions of the Agreement. Your letter states that every individual who receives
the letter
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01718506.pdf
EFTA01696704Set 10
2005-05-08100p34,772w
punished as contempt.
Issued under authority ofPublic Law No. 106-544, § 5(a)
(IS U.S.C. 0486)
ORIGINAL
3oStl- MM - C 41 3775-
444 Signature:
Name, Title: SSA
Issued this ... EFTA01696705
CERTIFICATE OF SUBPOENA
(Pun. Public Law No. 544, 106th Congress, 2million)
(18 U.S.C. §3486)
I hereby certify that I served the subpoena on the reverse hereof in the following ... contempt.
Issued under authority of Public Law No. 106-544. § 5(a).
(18 U.S.C. §3486)
ATTESTED COPY
Signature:
Name, Title: SSA
Issuedthis 22 dayof December 2006
EFTA01696707
.vr
• Public
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01696704.pdf
EFTA00799825Set 9
2017-06-0632p10,748w
contend the Government violated their rights under the Crime Victims' Rights
Act ("CVRA"), 18 U.S.C. § 3771, by: (I) failing to confer with them (D.E. 361 at 48-51; (2)
failing ... criminal prosecution. In accordance with her request, the
Government obtained immunity under 18 U.S.C. § 6001 in order to obtain information from Jane ... nearly 7 years after this matter was
filed, Congress added a new subsection, 18 U.S.C. § 3771(a)(9), which gave victims "[t]he right
to be informed in a timely
https://www.justice.gov/epstein/files/DataSet%209/EFTA00799825.pdf
EFTA00811809Set 9
2018-08-2251p13,267w
JURISDICTION AND VENUE
7. This Court has jurisdiction over this case pursuant to 28 U.S.C. §1331. In addition,
the sum or value of the claims in this case, exclusive ... Therefore,
this Court has jurisdiction over the remaining causes of action pursuant to 28 U.S.C. §1332(d).
8. At all relevant times, the claims arose in this District. Defendants conducted ... Venue in the Southern District of New York
is therefore proper pursuant to 28 U.S.C. §1391(a).
PARTIES
9. Plaintiff Marvin Gerber ("Gerber") is a resident of Wantagh, New York
https://www.justice.gov/epstein/files/DataSet%209/EFTA00811809.pdf
EFTA00207984Set 9
2011-05-0229p9,189w
CVRA covers agencies
involved in the "detection" and "investigation" of federal crimes, 18 U.S.C. § 3771(c)(1), and
allows victims to file for protection of CVRA rights even when ... prosecution is underway," 18
U.S.C. § 3771(d)(3). Moreover, a number of courts have ruled that the CVRA extends victims
rights even before an indictment is filed. This Court should ... crime victims are notified of, and accorded, the rights described in [the CVRA]." 18
U.S.C. § 3771(c)(1) (emphasis added). The victims have cited this provision prominently and
repeatedly
https://www.justice.gov/epstein/files/DataSet%209/EFTA00207984.pdf
EFTA00213534Set 9
2007-09-23108p11,165w
potential
settlements, the attorney representative elects to file a contested
lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other
contested remedy, the paragraph 7 obligation ... potential
settlements, an attorney representative elects to file
a contested lawsuit pursuant to 18 U.S.C. s 2255 or
elects to pursue any other contested remedy, the
paragraph 7 obligation ... potential settlements, an attorney representative elects to file a contested
lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested remedy, the
paragraph 7 obligation
https://www.justice.gov/epstein/files/DataSet%209/EFTA00213534.pdf
EFTA00029004Set 8
2019-07-0810p4,995w
defendant with one count of sex trafficking of minors,
in violation of 18 U.S.C. § 1591, and one count of conspiracy to commit sex trafficking of minors,
in violation ... U.S.C. § 371.
As charged by the grand jury, the facts underlying the charges in the Indictment arise from
a years-long scheme to sexually abuse underage girls. In particular, beginning ... Page 4
ARGUMENT
I. Applicable Law
Under the Bail Reform Act, 18 U.S.C. §§ 3141 et seq., federal courts are empowered to
order a defendant's detention pending trial upon
https://www.justice.gov/epstein/files/DataSet%208/EFTA00029004.pdf
EFTA00010542Set 8
2019-06-2432p8,663w
supervisors, and this discretion is expressly preserved in the CVRA. See
18 U.S.C. § 3771(d)(6).
Although the CVRA may not have required it, here, the government engaged
with ... proximately harmed as a result of the "commission of a Federal offense." 18
U.S.C. § 3771(e)(2)(A). Thus, without identifying exactly which federal offense
was committed by filing formal ... harmed. Moreover, the crime victims rights are tied to
a court proceeding, see 18 U.S.C. § 3771(b)(1), which indicates that formal charges
are required prior to the attachment
https://www.justice.gov/epstein/files/DataSet%208/EFTA00010542.pdf
EFTA00194687Set 9
2008-09-02135p42,589w
when the work
performed is aimed at pursuing "a contested lawsuit pursuant to 18 U.S.C. § 2255" or "any other
contested remedy." Simply put, the Agreement and Addendum only require ... civil claims against him $50,000.00, which is the statutory amount provided
by 18 U.S.C. § 2255, at the time of the alleged violations. Each individual would receive this
amount, without ... truly yours,
J P. LefIowitz
2 S50,000 represents tile statutory minimum under 18 U.S.C. § 2255, constitutionally questionably statute r
reasons we will not address here, at the time
https://www.justice.gov/epstein/files/DataSet%209/EFTA00194687.pdf
EFTA00229830Set 9
2007-03-1512p7,605w
charged (early 2004 through mid-2005), it is noted.
A. Coercion and Enticement: 18 U.S.C. § 2422
Whoever, using the mail or any facility or means of interstate . . . commerce, . . .
knowingly persuades ... imprisoned
not less than 5 years and not more than 30 years.
18 U.S.C. § 2422(b). The Eleventh Circuit Pattern Jury Instructions list the elements of this offense as:
First ... fined under
this title or imprisoned not more than 30 years, or both.
18 U.S.C. § 2423(b).
1. Proof of intent to travel
The defendant will most likely assert that
https://www.justice.gov/epstein/files/DataSet%209/EFTA00229830.pdf
EFTA00210039Set 9
2008-06-1914p7,715w
USAO has indicated
its intent to prosecute Mr. Epstein for purported violations of 18 U.S.C. §§ 2422, 2423, and
1591. However, as set forth in detail in prior submissions, the facts ... There was no use of drugs or
alcohol. There was no child pornography.
18 U.S.C. § 1591 is clearly designed to combat organized rings of individuals who engage in
the business ... letter also
makes clear that our pivotal legal challenge to the use of 18 U.S.C. § 2422(b) had already "been
previously raised and thorou y considered and rejected by ... CEOS
https://www.justice.gov/epstein/files/DataSet%209/EFTA00210039.pdf