EFTA00261688Set 9
70p27,499w
Died of breast cancer ()Any
Maq Winters dated targeted victims at ePbefore marriage to Chapman and targeted
victims fathers marriage tcynIfila ear _ ccmsaTe..o prig-nes
stoft ... Betrayal : Relationsh ip - Patter 'A) KONICI.:- CONINECren
~llag Winters datin• history with )Targeted victims father
result of fathers with targeted victims=,
, targeted victims I betray between
and Mag Winters ... seeking a relationship with while dating Mag
Winters.
---,..> Targeted victims scribed Maq Winters as "a very nice girl".
Targeted victims explai ng the betrayal of the
relationship, her stealing
https://www.justice.gov/epstein/files/DataSet%209/EFTA00261688.pdf
EFTA00267556Set 9
31p14,651w
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/EFTA00267556.pdf
EFTA00267516Set 9
31p14,658w
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/EFTA00267516.pdf
EFTA00208374Set 9
2011-03-2142p12,054w
REQUEST FOR A
THE CRIME VICTIMS' RIGHTS
APPROPRIATE REMEDIES
), by and
Doe #2 (also referred to as "the victims"
COME NOW Jane Doe #1 and Jane
victims' rights under ... move
ted by the U.S.
, 18 U.S.C. § 3771, have been viola
the Crime Victims Rights Act (CVRA)
these violations.
ring on the appropriate remedies for
Attorney's Office ... request a hea
failed to
facts to the Government, which they have
The victims have proffered a series of
's Office has
e facts,' it is clear that
https://www.justice.gov/epstein/files/DataSet%209/EFTA00208374.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
EFTA00794122Set 9
2019-02-2133p11,320w
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/EFTA00794122.pdf
EFTA00304742Set 9
2011-12-0525p7,975w
COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and
through undersigned counsel, to respond to the Government's Sealed Motion to Dismiss ... motion.
Because the Government has filed a motion to dismiss alleging that the victims'
pleadings are facially deficient, the Court must assume the truth of the victims' allegations —
specifically that ... deliberately conspired to enter into a secret non-
prosecution agreement in violation of the victims' rights under the Crime Victims' Rights Act
(CVRA). Given such allegations (and, indeed, even without
https://www.justice.gov/epstein/files/DataSet%209/EFTA00304742.pdf
EFTA01653604Set 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
EFTA01653604
Case 1:20-cr-00330-AJN Document
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01653604.pdf
EFTA00018663Set 8
2020-07-0133p7,092w
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
EFTA00018677
Epstein's residences in different states, which MAXWELL
https://www.justice.gov/epstein/files/DataSet%208/EFTA00018663.pdf
EFTA00013570Set 8
2008-08-0116p4,576w
JANE DOE #1 AND JANE DOE #2,
Petitioners,
v.
UNITED STATES OF AMERICA,
Respondent.
VICTIMS' RESPONSE TO GOVERNMENT'S "NOTICE TO COURT' REGARDING
ABSENCE OF NEED FOR EVIDENTIARY HEARING ... INTERVIEW
COME NOW the Petitioners, Jane Doe #1 and Jane Doe #2 (the "victims"), by and
through their undersigned attorneys to file this Response to the Government's document styled ... Evidentiary Hearing" as follows:
INTRODUCTION
At the conclusion of the oral argument on the victims' petition, victims Jane Doe #1 and
Jane Doe #2 joined the Government in expressing
https://www.justice.gov/epstein/files/DataSet%208/EFTA00013570.pdf
EFTA01265886Set 10
14p2,693w
Residence") to engage in sex acts with
him, after which he would give the victims hundreds of dollars
in cash. Moreover, and in order to maintain and increase his
supply ... victims, EPSTEIN also paid certain of his victims to
recruit additional girls to be similarly abused by EPSTEIN. In
SDNY_GM_00005887
CONFIDENTIAL
EFIA_00119950
EFTA01265886
this way, EPSTEIN created ... vast network of underage victims for
him to sexually exploit in locations including New York and
Palm Beach.
3. The victims described herein were as young as 14
years
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01265886.pdf
EFTA00027776Set 8
2019-05-1033p9,666w
FOLLOWED TO DETERMINE A REMEDY FOR THE GOVERNMENT'S
VIOLATION OF THE CRIME VICTIMS' RIGHTS ACT
Jane Doe 1 and Jane Doe 2 (also referred to as "the victims ... followed to
determine a remedy for the Government's violation of the Crime Victims' Rights Act (CVRA).
For the reasons explained below, the Court should direct the Government to begin ... Department of Justice . . . shall make their best
efforts to see that crime victims are notified of, and accorded, the rights described in [the
CVRA]." Ex. 1. at 3 (citing
https://www.justice.gov/epstein/files/DataSet%208/EFTA00027776.pdf
EFTA00068050Set 9
2019-07-1228p13,916w
also faces substantial evidence of his guilt, founded on the corroborated
testimony of numerous victims, and this case presents the very real possibility that he will go to
prison ... perpetrated, including through the minimization of his conduct and
casual disparagement of victims in his arguments.
Against this backdrop of significant—and rapidly-expanding—evidence, serious charges,
and the prospect ... Page 2
law, seeks to diminish and demean the harm caused to the many victims of the defendant's
appalling sexual abuse, and utterly fails to meet its burden
https://www.justice.gov/epstein/files/DataSet%209/EFTA00068050.pdf