The Timeline below examines decades-long failures by federal law enforcement and oversight agencies—including the Department of Justice, the FBI, and the Department of the Treasury—in the handling of Jeffrey Epstein’s crimes: child sexual abuse and the sex trafficking of minors, as well as the sexual abuse of young adult women. These failures span Democratic and Republican administrations, and transcend party. They have taken place in the context of extreme wealth and influence which, together with gendered power dynamics and socioeconomic vulnerability, have shaped government inaction. Public officials—through neglect, minimization, or deliberate manipulation—blunted scrutiny, weakened victim protections, and enabled continued exploitation and abuse. While much of this “tale of national disgrace,” as the Eleventh Circuit en banc court put it, centers on powerful men, Ghislaine Maxwell’s role shows that direct complicity also crossed gender lines.
Accounts of the survivors of these crimes were frequently discounted or disbelieved, and their fundamental interests were often sidelined. But their actions and perseverance finally brought some justice.
This timeline focuses on public records, especially court filings and government documents. The aim is light, not heat—clear facts over indignation—to show, with as much precision as possible, how systems entrusted with protection failed children and young women, and what those failures reveal about power, class, gender, and justice.
Here’s what’s known from the public record.
Table of Contents
2. Virginia Giuffre said Epstein/Maxwell effectively said, “We own the police”
3. May 2006: FBI opens an investigation into Jeffrey Epstein (“Operation Leap Year”)
6. 2005–2007: Federal failures to identify and investigate Ghislaine Maxwell
7. The terms of the Non-Prosecution Agreement (NPA): Prelude to the “deal of a lifetime”
8. NPA negotiated in secret—then buried: prosecutors hid NPA talks from victims
10. Prosecutors sought to hide the Florida state court plea hearing from the victims
11. Kept off the judge’s radar: NPA terms and timing withheld from the Florida state court
13. The plea agreement: the “deal of a lifetime”
18. Deficiencies in the 2020 OPR report
19. Blocking DOJ Inspector General from investigating failures
20. Executive Branch handling of the Epstein file and Maxwell imprisonment in 2025
21. Congressional handling of the Epstein file and Maxwell imprisonment in 2025
1. Maria Farmer reported Epstein’s abuse to the FBI twice on or around late August 1996, but the Bureau did not open an investigation until May 23, 2006—almost a decade later
After contacting the NYPD’s Sixth Precinct on Aug. 29, Maria Farmer was advised to reach out to the FBI; NYPD provided her with the FBI’s phone number. She contacted the FBI twice, and on at least one occasion the FBI agent allegedly hung up on her. Neither call was followed up.
(a) Farmer v. United States, 1:25-cv-01709, (D.D.C.) Complaint (May 29, 2025)
“On August 29, 1996, she reported Epstein and Maxwell to law enforcement. … The NYPD explained that they could only address the local fire threats [made by Epstein] and that she needed to report her additional allegations to the FBI. They gave her the FBI’s telephone contact information[.] … Following the NYPD’s instructions … Maria promptly contacted the FBI, making at least two calls to two different offices. … Without notice or explanation, while Maria was in mid-sentence, the FBI abruptly hung up on her. … The FBI made no effort to meet with Maria or otherwise follow up.” ¶¶ 112–22 (emphasis added).
(b) NYPD Police Report Complaint #1996-0067241 (08/29/96) (Exhibit 1)
(c) Maria Farmer entry in her personal journal (1997) (Maria Farmer Complaint (May 2025), ¶ 125)
(d) FBI’s Nov. 14, 2006 interview notes record Farmer’s statement that, in 1996, NYPD’s Sixth Precinct told her to contact the FBI (p. 35).
According to Maria Farmer’s attorney and her civil complaint, FBI agents arrived unannounced at her North Carolina home on November 11, 2006, stated they were aware of her 1996 FBI complaint about Epstein, and told her they had tracked her down because of that earlier report.
(a) Maria Farmer Complaint (May 2025), ¶¶ 176-77
(b) Maria Farmer attorney Jennifer Freeman letter to FBI Director Wray, DOJ IG Horowitz, and AG Garland calling for a full investigation into the FBI’s handling of the Epstein case (May 2, 2023), pp. 5-6.
2. Virginia Giuffre said Epstein/Maxwell effectively said, “We own the police”
“Jeffrey and Ghislaine’s way of keeping us under his thumb, under his rule, under their control, were invisible chains. And it was that constant: ‘We own the police. You can’t run. You can’t tell anybody. We’ll never be held accountable for this.’” (NBC News video interview (2019) part 2, at 05:14 – 05:36)
3. May 2006: FBI opens an investigation into Jeffrey Epstein (“Operation Leap Year”)
May 23, 2006 — Federal investigation formally opened. Following initial discussions between FBI and AUSA Ann Marie Villafaña in early 2006, and a May meeting with the lead Palm Beach PD detective, Villafaña prepared the paperwork to open a USAO case file. The investigation, codenamed “Operation Leap Year,” was formally initiated that day with supervisory approval.
Source: Office of Professional Responsibility, Investigation into the U.S. Attorney’s Office for the Southern District of Florida’s Resolution of Its 2006–2008 Federal Criminal Investigation of Jeffrey Epstein and Its Interactions with Victims during the Investigation, November 2020, pp. 16-18.
4. DOJ/FBI mischaracterization and victim-blaming: Treating children as ‘prostitutes’ and failing to understand child sexual abuse
(a) Maria Farmer Complaint (May 2025), ¶ 12:
“In addition, in violation of various federal laws, federal law enforcement denigrated victims, calling them ‘child prostitutes,’ and failed to provide notices of criminal processes or offer them victim services or protection.”
(b) In re Courtney Wild, No. 19-13843 (11th Cir. argued Dec. 3, 2020) (oral argument, at 35:38 – 35:47).
During the Eleventh Circuit oral argument on Dec. 3, 2020, a judge asked whether the government had affirmatively acknowledged that Courtney Wild was not a prostitute and invited Assistant U.S. Attorney Jill Steinberg to apologize for any contrary suggestion in the non-prosecution agreement. Steinberg agreed that “she’s not [a] prostitute” and that “minors cannot consent to sex,” noting “that’s the department policy” and “that’s the law,” but she did not offer the apology the judge requested.
(c) Julie K. Brown, Perversion of Justice: The Jeffrey Epstein Story (New York: HarperCollins, 2021), p. 76:
“Lawyers representing the victims said that federal prosecutors didn’t seem to understand how to build a sensitive case involving someone who had power and money. ‘The prosecutors didn’t need two dozen girls to testify; all they needed was one or two,’ said lawyer Spencer Kuvin.
Kuvin said the FBI only interviewed one of his clients, and there were two other victims who would have helped their case.
‘What these girls were really looking for was for the criminal justice system to do what it was supposed to do,’ Kuvin said. ‘Every one of my clients wanted Epstein to go to jail.’ Some of the victims were even intimidated by the FBI agents and prosecutors, who at times seemed to treat the girls as if they had done something wrong. Prosecutors did little to help ease victims’ anxieties, pointing out that testifying against Epstein would be difficult on them and their families, who would likely be pulled into the spotlight in the event of such a high-profile prosecution. Ultimately, most of the victims were never formally interviewed by the FBI or federal prosecutors. And some of those who were interviewed were too uncomfortable to share all the details of Epstein’s abuse.
‘We knew the whole story had not been told,’ said Adam Horowitz, another one of the civil attorneys representing victims. ‘We knew there were many more victims and girls who had not yet contacted a lawyer.’
‘It was clear that prosecutors were uninformed about how to deal with victims of sex crimes,’ said Marci Hamilton, a law professor at the University of Pennsylvania and an expert on crimes against children. ‘They clearly had no awareness about sex trafficking, how it starts and how it flourishes. Epstein was not engaging in individual sex abuse; he was creating an entire system.’ The FBI agents tailored their questions so narrowly that it seemed as if they didn’t want to know how deep the crimes were, and who was involved.
‘The FBI agents told them, “We just want the facts. We don’t want hearsay and opinions,” Kuvin said.
Jessica Arbour, a young lawyer who was hired by victims’ lawyer Jeffrey Herman to help with the case, said she spent most of her time fielding calls from the victims at all hours of the day and night. At the time, she was around the same age as the victims, and tried to act as a bridge between them and the legal system.
The girls were very distrustful of the FBI, she said, because they showed up without any warning, knocking on their doors and questioning them in front of their parents and spouses. In some cases, the girls couldn’t even tell whether the agents were working for the government or whether they had been sent by Epstein.”
(d) Julie K. Brown, Perversion of Justice: The Jeffrey Epstein Story (New York: HarperCollins, 2021), p. 38:
“I found that the prosecutors in the case didn’t seem to understand the psychology behind childhood sexual abuse. Because some of the girls had returned and others had even fallen in love with Epstein, the state and federal prosecutors, for the most part, had dismissed them as willing partners, or even prostitutes.
What society wants is a victim who is a sweet, adorable, innocent angel that God sent from heaven—and an offender who is this evil horrible sexual predator, a “dirty old man in a wrinkled raincoat,” that’s what we prefer, but that’s not reality,’ [Kenneth] Lanning [a former FBI agent with two decades in the Behavioral Science Unit specializing in child sexual abuse] said. The Epstein case, he explained, was complicated by the fact that the girls, the victims, didn’t fit into the comfortable mold that the criminal justice system prefers. ‘The prosecutors who were looking at the case were saying “that’s not what she said, she changed her story” and the children, they look like adults. But they are mentally and emotionally immature, so it is normal for them to give differing accounts of the trauma they experienced. In fact, it would have been abnormal for them to tell the same story with the same exact details every single time. The child’s brain doesn’t work that way unless they are coached.”
(e) “Everyone Heard About Jeffrey Epstein’s Enablers. Few Listened to His Victims”, Fresh Air, NPR radio broadcast (July 20, 2021) (interview with Julie K. Brown).
Julie K. Brown: “You know, a number of the victims told me that. They said that they – when I was questioned not by the Palm Beach police – they weren’t in this category – but by prosecutors and the FBI agents, they said that – they said, look, I almost felt like I had done something wrong. And they were very scared because … the FBI was making them feel like they perhaps had broken the law. … And at the time that this case happened … there was still law on the books in Florida … that child prostitution was illegal … not on the part of … the pimps but the girls that were involved and the boys … What they were doing was illegal. So part of the thing that the prosecutors used to excuse the fact that they weren’t going after the case was they would tell the girls, look. You understand that what you did was illegal. And in a way, they sabotaged their own case because they made the victims feel like they could get in trouble. They didn’t want to cooperate as much as they would”
(f) Julie K. Brown, “How a Future Trump Cabinet Member Gave a Serial Sex Abuser the Deal of a Lifetime”, Miami Herald (Nov. 28, 2018).
“Despite substantial physical evidence and multiple witnesses backing up the girls’ stories, the secret deal allowed Epstein to enter guilty pleas to two felony prostitution charges. Epstein admitted to committing only one offense against one underage girl, who was labeled a prostitute, even though she was 14, which is well under the age of consent — 18 in Florida.
‘She was taken advantage of twice — first by Epstein, and then by the criminal justice system that labeled a 14-year-old girl as a prostitute,’’ said Spencer Kuvin, the lawyer who represented the girl.
‘It’s just outrageous how they minimized his crimes and devalued his victims by calling them prostitutes,’ said Yasmin Vafa, a human rights attorney and executive director of Rights4Girls, which is working to end the sexual exploitation of girls and young women.
‘There is no such thing as a child prostitute. Under federal law, it’s called child sex trafficking — whether Epstein pimped them out to others or not. It’s still a commercial sex act — and he could have been jailed for the rest of his life under federal law,’ she said.”
(g) Barry Levine, The Spider: Inside the Criminal Web of Jeffrey Epstein and Ghislaine Maxwell (Crown: 2020), p. 163:
“The FBI’s behavior was not above reproach either. One victim, Dainya Nida, was introduced to Epstein in June 2003 when she was a sixteen-year-old student at John I. Leonard High School, ten miles from Epstein’s Palm Beach mansion. Nida would later comment that neither FBI agents nor federal prosecutors seemed interested in her plight. The agents would come to where she was working to question her, making it appear as if she was the one who had done something wrong.” (citing Jane Musgrave, “Jeffrey Epstein Victim Goes Public: I Want to Know Why,” Palm Beach Post, January 31, 2020)
5. In 2007, the US Attorney for the Southern District of Florida stops the investigation of Epstein before its completion
(a) Justice Department’s Office of Professional Responsibility (OPR) 2020 report faulted the US Attorney Alex Acosta for having “resolved the federal investigation before significant investigative steps were completed.” p. x, 284.
“The federal government was uniquely positioned to fully investigate the conduct of an individual who engaged in repeated criminal conduct in Florida but who also traveled extensively and had residences outside of Florida. Even if the Petite policy had applied, OPR has little doubt that the USAO could have obtained authorization from the Department to proceed with a prosecution under the circumstances of this case.” p. 171
“OPR concludes that Acosta’s decision to resolve the federal investigation through the NPA constitutes poor judgment. … [T[he NPA was a flawed mechanism for satisfying the federal interest that caused the government to open its investigation of Epstein. … he resolved the federal investigation before significant investigative steps were completed.” pp. x, 284 (emphasis added).
(b) The OPR report states that the failure to complete the investigation meant investigators “did not know the full scope of Epstein’s conduct … or whether the additional victims might implicate other offenders”:
“Yet, Acosta made the decision to resolve the case through a state-based resolution and extended that proposal to Epstein’s defense attorneys before the investigation was completed. As the investigation progressed, the FBI continued to locate additional victims, and many had not been interviewed by the FBI by the time of the initial offer. In other words, at the time of Acosta’s decision, the USAO did not know the full scope of Epstein’s conduct; whether, given Epstein’s other domestic and foreign residences, his criminal conduct had occurred in other locations; or whether the additional victims might implicate other offenders. In addition, Villafaña planned to approach the female assistants to attempt to obtain cooperation, but that step had not been taken.” p. 175 (emphasis added).
“Although the FBI interviewed numerous employees of Epstein and Villafaña identified three of his female assistants as potential co-conspirators, at the time that the USAO extended the terms of its offer, there had been no significant effort to obtain these individuals’ cooperation against Epstein.” (p. 175 n.252)
(c) The OPR report (pp. 175-79) includes a detailed analysis of the DOJ’s responsibility in failing to obtain Epstein’s computers and hard drives before stopping the investigation and entering the non-prosection agreement.
“There was good reason to believe the computers contained relevant — and potentially critical — information; and it was clear Epstein did not want the contents of his computers disclosed. Nothing in the available record reveals that the USAO benefitted from abandoning pursuit of this evidence when they did, or that there was any significant consideration of the costs and benefits of forgoing the litigation to obtain production of the computers. Instead, the USAO agreed to postpone and ultimately to abandon its efforts to obtain evidence that could have significantly changed Acosta’s decision to resolve the federal investigation with a state guilty plea or led to additional significant federal charges. By agreeing to postpone the litigation, the USAO gave away leverage that might have caused the defense to come to an agreement much earlier and on terms more favorable to the government. The USAO ultimately agreed to a term in the NPA that permanently ended the government’s ability to obtain possible evidence of significant crimes and did so with apparently little serious consideration of the potential cost.” p. 178 (emphasis added).
6. 2005–2007: Federal failures to identify and investigate Ghislaine Maxwell
By 1996—and certainly by 2006—law enforcement had notice of Ghislaine Maxwell’s connection to Epstein and her potential involvement in exploitation and abuse. The FBI was told directly about Maxwell’s role in 1996 and again in 2006; and Palm Beach authorities (PBPD/State Attorney) documented her central involvement in their 2005 files, including contemporaneous interviews.
(a) Maria Farmer Complaint (May 2025), ¶¶ 112-19, 180, 185.
In 1996, Maria Farmer reported to NYPD (Complaint #1996-0067241) and then the FBI that both Jeffrey Epstein and Ghislaine Maxwell had sexually abused her and others. She described an ongoing child-exploitation scheme (including explicit images kept in a safe), putting law enforcement on clear notice of Maxwell’s role. In 2006, during an FBI home visit in North Carolina, she again identified Maxwell’s direct role—stating (at ¶ 180) that “Maxwell would frequently ‘go get girls’ for Epstein’s sexual desires.”
(b) Sworn Statement of Juan P. Alessi (Epstein’s house manager of Palm Beach mansion), Nov. 21, 2005 (Palm Beach Police Department)
Alessi referenced Maxwell several times including saying she was always with Epstein. He confirmed that Maxwell was Epstein’s “girlfriend” and that during his 11 years as house manager it was Maxwell that he would communicate with regarding Epstein and Maxwell visiting the Palm Beach mansion and making any arrangements (p. 6). He stated that “most of the time it was Ms. Maxwell that traveled with him all the time” (p. 8). Alessi described her as Epstein’s “boss, girlfriend” and said she was the house staff’s “immediate superior” (pp. 8–9). He observed Ms. Maxwell going upstairs in the direction of the bedroom quarters (pp. 10–11). He further explained that the “standard” procedure when cleaning up sex toys often left on Epstein’s sink was to store them “in a basket inside Ms. Maxwell’s closet” (pp. 12–13).
(c) Det. Joseph Recarey’s 2006 PBPD notes tie Maxwell directly to recruitment/coordination through interviews with women who provided massages and/or reported sexual abuse:
One of the victims, Johanna Sjoberg said “Ghislaine Maxwell…approached her…[saying] they needed some girls to work at the house,” and that she “would be notified by Maxwell” when Epstein came to Palm Beach.
Another victim, Christina Venero said she met “Ghislaine Maxwell and Jeffrey Epstein” through a friend; she “only provided massages and that was it” and “never was approached for anything else;” while she massaged Epstein’s “guests and assistants,” it is unclear whether Maxwell received a massage, though “Maxwell and Epstein have commented negatively about her tattoos previously when she has provided massages”—which suggests Maxwell was at least present in the room during some of those massage sessions.
(d) PBPD and Palm Beach County State Attorney’s Office (SAO) files (here, pp. 60, 66-70; here, pp. 93-95) includes Colonial Bank/“DDA Statement” bank records naming “JEFFREY E EPSTEIN OR GHISLAINE MAXWELL” and a “GHISLAINE MAXWELL OR ALFREDO RODRIGUEZ — HOUSEHOLD ACCOUNT,” showing late-2004/early-2005 activity: $10,000 incoming wires and repeated teller-cashed checks ($1,000–$5,000) annotated “Petty Cash” and “To J.E.” These records place Maxwell as a co-holder on a household account used for cash withdrawals and payments tied to Epstein—documentary evidence PBPD/SAO had by early 2005.
(e) OPR Report: DOJ acknowledged Maxwell but excluded her as a co-conspirator
“Villafaña acknowledged that investigators were aware of Epstein’s longtime relationship with a close female friend who was a well-known socialite, but, according to Villafaña, in 2007, they ‘didn’t have any specific evidence against her.’ Accordingly, Villafaña believed that the only ‘co-conspirators’ of Epstein who would benefit from the provision were the four female assistants identified by name.” p. 167.
“The FBI had interviewed one victim who implicated the female friend in Epstein’s conduct, but the conduct involving the then minor did not occur in Florida.” p. 167 n.239.
The FBI failed to question victims about Ghislaine Maxwell in 2007, and DOJ now admits it was not aware of her involvement at the time of the NPA.
(a) The Department of Justice has stated that “the government was not even aware of [Maxwell’s] role in Epstein’s scheme at that time” of the Non-Prosecution Agreement. The Government made this statement most recently in the U.S. Solicitor General’s written submission to the U.S. Supreme Court on July 14, 2025:
“But there is no evidence that the parties to the NPA intended for the coconspirators clause to benefit petitioner. […] The government was not even aware of petitioner’s role in Epstein’s scheme at that time.” p. 15.
(b) Carolyn Andriano, one of the victims, testified that in her 2007 FBI interview, she was never asked about Maxwell (pp. 1553-54; pp. 127-8 of Exhibit):
“Q. In 2007, were you interviewed by the FBI about Jeffrey Epstein?
A. Yes.
Q. During that interview, did you tell the FBI that you noticed an older lady with short black hair and an accent at Epstein’s residence the first time you went there with
Virginia?
A. Yes.
Q. Who was that?
A. Maxwell.
Q. During your interview with the FBI in 2007, did you mention the other details of your interactions with Maxwell?
A. No.
Q. Why not?
A. I wasn’t asked about Maxwell.”
As early as 2000, major outlets publicly flagged Epstein’s close relationship with Ghislaine Maxwell—some of which featured in the Palm Beach investigators’ case files. These accounts flagged a close Epstein-Maxwell partnership and social circles of very young women, and hinted at her facilitation role years before the 2005–2007 investigations.
(a) New York Post (Page Six) (December 2000) reported that Epstein “likes the company of attractive young women” and that Maxwell was “on some kind of retainer,” adding she’d been “very good about introducing him to some of her pals.” (See PBPD/PB County State Attorney’s 2005 file clipping, p. 49).
(b) The Evening Standard (January 2001) detailed Maxwell’s and Prince Andrew’s close relationship and her role as his “fixer” including introducing him to Epstein and the three of them taking five breaks together over the past 12 months.
(c) New York Magazine (October 2002) reported that Epstein had “for more than ten years…been linked to…Ghislaine Maxwell,” noting gossip-column speculation about “the true nature of his relationship” with her and quoting a society journalist who called them “soul mates” who “serve each other’s purposes.” (See PBPD/PB County State Attorney’s 2005 file clipping, p. 49).
(d) Vanity Fair (March 2003) portrayed Maxwell as Epstein’s “most public companion of the last decade” and “best friend,” describing her summoning young women to Epstein’s townhouse and hosting parties (incl. one with Prince Andrew) filled with young Russian models—scenes some guests found “horrified.” (See PBPD/PB County State Attorney’s 2005 file clipping, p. 31).
7. The terms of the Non-Prosecution Agreement (NPA): Prelude to the “deal of a lifetime”
(a) The NPA included the following elements highly favorable to Epstein:
- Government to give Epstein’s attorney a victim list after sentencing (Term 7, p. 4)
“The United States shall provide Epstein’s attorneys with a list of individuals whom it has identified as victims, as defined in 18 U.S.C. § 2255, after Epstein has signed this agreement and been sentenced.”
- Keep the NPA out of public record; FOIA notice to Epstein (Term 13, p. 5)
“The parties anticipate that this agreement will not be made part of any public record. If the United States receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before making that disclosure.”
- Epstein to approve and pay for attorney for victims (Term 7, p. 4; Term 7C, Addendum to Term 7)
“Upon the execution of this agreement, the United States, in consultation with and subject to the good faith approval of Epstein’s counsel, shall select an attorney representative for these persons [the victims], who shall be paid for by Epstein. Epstein’s counsel may contact the identified individuals [the victims] through that representative.”
“Epstein has agreed to pay the fees of the attorney representative[.] … This provision … shall not obligate Epstein to pay the fees and costs of contested litigation … if … an attorney representative elects to file a contested lawsuit … 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 § 2255, shall cease.”
- Victims must proceed exclusively under § 2255 (Civil remedy for personal injuries; waiving other damages) to trigger Epstein’s capped no-contest on jurisdiction, liability, and damages; non-admission preserved (Term 8, p. 4)
“If any of the individuals [the victims] referred to in paragraph (7) … elects to file suit pursuant to 18 U.S.C. § 2255 (Civil remedy for personal injuries), Epstein will not contest the jurisdiction of the United States District Court for the Southern District of Florida… and waives his right to contest liability and also waives his right to contest damages up to an amount as agreed … so long as the identified individual elects to proceed exclusively under § 2255, and agrees to waive any other claim for damages … Notwithstanding this waiver … [these] waivers … are not to be construed as an admission of any criminal or civil liability.”
- Co-conspirator immunity (named and unnamed individuals) (post-terms paragraph, p. 5)
“[I]f Epstein successfully fulfills all of the terms and conditions of this agreement, the United States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova.”
- Suspend the federal grand-jury investigation; hold subpoenas in abeyance (post-terms paragraph, p. 5)
“[U]pon execution of this agreement and a plea agreement with the State Attorney’s Office, the federal Grand Jury investigation will be suspended, and all pending federal Grand Jury subpoenas will be held in abeyance unless and until the defendant violates any term of this agreement. … Upon the successful completion of the terms of this agreement, all outstanding grand jury subpoenas shall be deemed withdrawn.”
(b) The Eleventh Circuit Court of Appeals en banc decision, addressing the NPA’s victim-handling provisions described these terms as:
“An odd set-up—and one that, it seems to us, was likely calculated to quickly and quietly resolve as many victim suits as possible.” (In re Courtney Wild, 994 F.3d 1244 (11th Cir. en banc 2021), p. 5 n.1. (emphasis added).
(c) OPR report:
“[Acosta] agreed to several unusual and problematic terms in the NPA without the consideration required under the circumstances.” p. x (emphasis added).
“This broad provision promising not to prosecute ‘any potential co-conspirators’ is troubling and … OPR did not find evidence showing that the subjects gave careful consideration to the potential scope of the provision or whether it was warranted given that the investigation had been curtailed and the USAO lacked complete information regarding possible co-conspirators.” p. 168 (emphasis added).
“[T]he USAO did not have a sufficient investigative basis from which it could conclude with any reasonable certitude that there were no other individuals who should be held accountable along with Epstein or that evidence might not be developed implicating others. Prosecutors rarely promise not to prosecute unidentified third parties. The rush to reach a resolution should not have led the USAO to agree to such a significant provision without a full consideration of the potential consequences and justification for the provision.” pp. 185-86.
8. NPA negotiated in secret—then buried: prosecutors hid NPA talks from victims
(a) The Eleventh Circuit Court of Appeals en banc decision, in 2021, described months of secrecy and defense-coordinated negotiations designed to keep victims uninformed and the finalized NPA concealed. (In re Courtney Wild, 994 F.3d 1244 (11th Cir. 2021) (en banc)).
“Worse, it appears that prosecutors worked hand-in-hand with Epstein’s lawyers—or at the very least acceded to their requests—to keep the NPA’s existence and terms hidden from victims.” (majority opinion by Judge Newsom, p. 5) (emphasis added).
“[A]t approximately the same time that the sides concluded the NPA, they began negotiating about what prosecutors could (and couldn’t) tell victims about the agreement. Seemingly in deference to Epstein’s lawyers’ repeated requests, the government held off—for nearly an entire year—on notifying Epstein’s victims of the NPA’s existence.” (majority opinion by Judge Newsom, pp. 5-6) (emphasis added).
“[T]he government’s efforts appear to have graduated from passive nondisclosure to (or at least close to) active misrepresentation.” (majority opinion by Judge Newsom, p. 6) (emphasis added).
“If secrecy was the goal, it seems to have been achieved—there is no indication that any of Epstein’s victims were informed about the NPA or his state charges until after he pleaded guilty.” (majority opinion by Judge Newsom, p. 6) (emphasis added).
“But it wasn’t until July 2008—during the course of this litigation—that petitioner learned of the NPA’s existence, and until August 2008 that she finally obtained a copy of the agreement.” (majority opinion by Judge Newsom, pp. 6-7)
“U.S. Attorney’s Office secretly engaged in discussions with Epstein’s defense team regarding the forthcoming federal criminal charges. (dissenting opinion by Judge Branch, p. 101) (emphasis added).
“As the Agreement was being signed, Epstein’s attorney Jay Lefkowitz e-mailed AUSA Villafaña, requesting: ‘Marie – Please do whatever you can to keep this [Agreement] from becoming public.’ (emphasis added by judge). AUSA Villafaña assured Lefkowitz that the Agreement would be kept confidential.” (dissenting opinion by Judge Branch, p. 103 n.6)
“Instead, for nine months after the September 2007 execution of the Agreement, the U.S. Attorney’s Office continued to negotiate with Epstein’s defense team about the extent of crime victim notifications—a course of action which the U.S. Attorney’s Office now admits is a deviation from the government’s standard practice.” (dissenting opinion by Judge Branch, pp. 103-04) (emphasis added).
(b) The Eleventh Circuit’s prior panel opinion mirrored—word for word—many of the en banc criticisms and also offered further observations. (In re Courtney Wild, 955 F.3d 1196, 1220 (11th Cir. 2020), reh’g en banc granted, opinion vacated, 967 F.3d 1285 (11th Cir. 2020))
“[A]s already explained, the undisputed facts show … federal prosecutors in the Southern District of Florida negotiated ‘a secret non-prosecution agreement” with Epstein, and that ‘[f]rom the time that the FBI began investigating Epstein through the consummation of the secret NPA, the Government never conferred with Epstein’s victims about the NPA [or] even told them that such an agreement was under consideration.’” (majority opinion by Judge Newsom, p. 15) (emphasis added).
“Shockingly though, the [U.S. Attorney’s] Office then (1) conducted many days of extensive plea negotiations with Epstein’s attorneys and secretly entered into a Non-Prosecution Agreement (‘NPA’), granting Epstein federal immunity in return for his plea to two state prostitution-solicitation charges, (2) never conferred one minute with the victims about the NPA or told the victims that such an agreement was under consideration, (3) worked closely with Epstein’s lawyers to keep the NPA’s existence and terms hidden from the victims, … and (5) never informed the victims about the NPA until after Epstein pled guilty in State Court and the secret sweetheart deal was done.” (dissenting opinion by Judge Hull, pp. 60-1) (emphasis added).
“Pre-charge, the [U.S. Attorney’s] Office spent days conferring and negotiating with Epstein’s defense team, but had not a minute for the victims.” (dissenting opinion by Judge Hull, p. 64) (emphasis added).
“[T]he [U.S. Attorney’s] Office cleverly entered into a sweetheart plea deal with Epstein.” (dissenting opinion by Judge Hull, p. 62)
“[T]he parties made great efforts to keep that secret from the victims and the public, too.” (dissenting opinion by Judge Hull, p. 71) (emphasis added).
“[T]he [U.S. Attorney’s] Office misrepresented to the victims that ‘this case’ was still under investigation, advised them ‘to be patient,’ and never disclosed the government’s NPA with Epstein.” (dissenting opinion by Judge Hull, p. 74)
“[T]he Office admitted that it was a deviation from the government’s standard practices to negotiate with defense counsel about the extent of crime victim notifications.” (dissenting opinion by Judge Hull, p. 75) (emphasis added).
(c) OPR Report:
“[T]he lack of consultation was part of a series of government interactions with victims … reflected poorly on the Department as a whole, and is contradictory to the Department’s mission to minimize the frustration and confusion that victims of a crime endure.” pp. x-xi, (emphasis added).
9. Prosecutors misled victims about the investigation’s status—assuring them that the Epstein case was “currently under investigation” despite agreeing to the NPA
(a) In re Courtney Wild, 994 F.3d 1244 (11th Cir. 2021) (en banc):
“[O]nly to be left in the dark—and, so it seems, affirmatively misled—by government attorneys.” (majority opinion by Judge Newsom, p. 2) (emphasis added).
“And to be clear, the government’s efforts appear to have graduated from passive nondisclosure to (or at least close to) active misrepresentation. In January 2008, for example, approximately four months after finalizing and executing the NPA, the government sent a letter to Ms. Wild stating that Epstein’s case was ‘currently under investigation,’ explaining that ‘[t]his can be a lengthy process,’ and ‘request[ing her] continued patience while [it] conduct[ed] a thorough investigation.’ The government sent a similar letter to another victim in May 2008, some eight months after inking the NPA.” (majority opinion by Judge Newsom, p. 6) (emphasis added) (italics in original)
“[A]dding insult to an already grievous injury, government prosecutors (by their own admission) affirmatively misled Ms. Wild— and dozens of others like her—regarding the status of their criminal investigation. Shameful all the way around. The whole thing makes me sick.” (majority opinion by Judge Newsom, p. 68) (emphasis added).
“[T]he U.S. Attorney’s Office affirmatively misled victims for months concerning the Agreement and the resolution of the federal case. For example, … on January 31, 2008, Wild met with AUSA Villafaña, FBI agents, and another federal prosecutor, provided additional details of Epstein’s sexual abuse of her, and expressed her hope that Epstein would be prosecuted. During that meeting, however, the federal prosecutors and FBI agents still did not disclose the Agreement to Wild. Then, in mid-June of 2008, Bradley Edwards, the attorney for Wild and several of Epstein’s other victims, discussed with AUSA Villafaña the possibility of federal charges being filed against Epstein in the future. AUSA Villafaña failed to mention the Agreement or its terms.” (dissenting opinion by Judge Branch, pp. 104-05) (emphasis added).
“Given the OPR Report, it is hardly surprising the victims continue to pursue this civil suit to discover and unravel the mystery of why the prosecutors … signed such a sweetheart plea … in secret and then for nearly a year took great efforts to hide the Agreement by affirmative misrepresentations to the victims and their counsel too.” (dissenting opinion by Judge Hull, p. 182 n.10) (emphasis added).
“[T]his case is about how the U.S. prosecutors fell short on Epstein’s evil crimes. Mysteries remain about how Epstein escaped federal prosecution and why, for nearly a year, the government made affirmative misrepresentations to the Florida victims of his serious sex crimes and to the victims’ counsel.” (dissenting opinion by Judge Hull, p. 184) (emphasis added).
(b) OPR Report, p. xi:
The letters sent by an FBI agent to victims after the NPA had been signed “risked misleading the victims and contributed to victim frustration and confusion by failing to provide important information about the status of the investigation. The letters also demonstrated a lack of coordination between the federal agencies responsible for communicating with Epstein’s victims and showed a lack of attention to and oversight regarding communication with victims.” (emphasis added).
10. Prosecutors sought to hide the Florida state court plea hearing from the victims
OPR Report:
“Acosta exercised poor judgment when he failed to make certain that the state intended to and would notify victims identified through the federal investigation about the state plea hearing. His decision left victims uninformed about an important proceeding that resolved the federal investigation, an investigation about which the USAO had communicated with victims for months. It also ultimately created the misimpression that the Department intentionally sought to silence the victims. Acosta failed to ensure that victims were made aware of a court proceeding that was related to their own cases, and thus he failed to ensure that victims were treated with forthrightness and dignity.” p. xi, 285 (emphasis added).
“[T]he failure to reevaluate the strategy prior to interviews of victims and discussions with victims’ attorneys occurring in 2008 led to interactions that contributed to victims’ feelings that the government was intentionally concealing information from them. … After examining the full scope and context of the government’s interactions with victims, OPR concludes that the government’s lack of transparency and its inconsistent messages led to victims feeling confused and ill-treated by the government; gave victims and the public the misimpression that the government had colluded with Epstein’s counsel to keep the NPA secret from the victims; and undercut public confidence in the legitimacy of the resulting agreement. The overall result of the subjects’ anomalous handling of this case understandably left many victims feeling ignored and frustrated and resulted in extensive public criticism. … In sum, OPR concludes that the victims were not treated with the forthrightness and sensitivity expected by the Department.” p. xi, 286 (emphasis added).
11. Kept off the judge’s radar: NPA terms and timing withheld from the Florida state court
In re: Courtney Wild, No. 19-13843 (11th Cir.) (Apr. 14, 2020): 955 F.3d 1196
“AUSA Villafana responded: ‘A non-prosecution agreement would not be made public or filed with the Court, but it would remain part of our case file.’” (dissenting opinion by Judge Hull, p. 71) (emphasis added).
“In an e-mail to Lefkowitz, dated September 16, 2007, AUSA Villafana suggested strategies to conceal portions of the plea deal from the courts, stating that a prosecutor had ‘recommended that some of the timing issues be addressed only in the state agreement, so that it isn’t obvious to the judge that we are trying to create federal jurisdiction for prison purposes.’ AUSA Villafana added: ‘I will include our standard language regarding resolving all criminal liability and I will mention “co-conspirators,” but I would prefer not to highlight for the judge all of the other crimes and all of the other persons that we could charge.’” (dissenting opinion by Judge Hull, p. 71 n. 4) (emphasis added).
“To this date, the U.S. Attorney’s Office has presented no evidence that it or anyone else told the State Court, either before or during Epstein’s state hearing, about the secret consideration Epstein had negotiated with the federal government—federal immunity for him and all co-conspirators—if the State Court accepted his state plea.” (dissenting opinion by Judge Hull, p. 76) (emphasis added).
12. Before litigation, prosecutors represented to victims and defense that CVRA protections would ensure victim communications; after litigation started, they reversed that stance
(a) In re Courtney Wild, 994 F.3d 1244 (11th Cir. 2021) (en banc). p. 4; pp. 100–01 (communicating CVRA protections to victims); p. 104 (prosecutor–defense communications).
(b) In re Courtney Wild, 955 F.3d 1196 (11th Cir. 2020), vacated on reh’g en banc, 967 F.3d 1285 (11th Cir. 2020). p. 68 (communicating CVRA protections to victims); pp. 77–78 (prosecutor–defense communications); see also pp. 65, 81–82.
13. The plea agreement: the “deal of a lifetime”
Despite extensive evidence supporting federal sex-trafficking charges, DOJ leaders instead negotiated what became known as the “deal of a lifetime.”
By May 2007, the lead federal prosecutor Ann Marie Villafaña prepared a 82-page prosecution memo and 60-count draft indictment alleging that Epstein committed numerous federal sex crimes. Her boss, the US Attorney for SDFL, Alex Acosta, instead overruled her proposed charges and personally approved an agreement reducing Epstein’s exposure to just two state crimes for soliciting prostitution and a recommendation of 18 months in county jail.
“Marie broke her back trying to do the right thing, but someone was always telling her to back off. We never really knew who it was, we just thought it was very odd,” a prosecutor told the reporter Julie K. Brown.
Epstein served less than 13 months in a minimum-security Palm Beach County facility, which included a work release program that allowed him to spend 12 hours a day purportedly working at a Foundation he had recently incorporated. “Villafaña learned, just days after Epstein was sentenced, that he was going on work release—and strenuously objected,” according to Brown’s book.
The Palm Beach Sheriff’s Office instructed deputies assigned to watch Epstein during his work release that “Inmate Epstein is responsible for his own transportation.” “Almost every day, Epstein’s security guard and valet, Igor, picked him up at the jail each morning in a black SUV,” according to Brown’s book. Epstein reportedly made “at least sixty-nine visits in six months to doctors, sometimes for two appointments in one day. He would also travel as often as three times a week to a chiropractor in Lake Worth, records show.” An internal email of the sheriff’s department referred to Epstein as a “client.” “The officers assigned to Epstein’s work release detail were directed to dress in suits and ties, not in uniform,” according to Brown’s book. Local news obtained internal Palm Beach County Sheriff’s Office emails showing that “sheriff’s officials … made the work-release even more lenient, approving Epstein leaving his office each day in July 2009 and going back to his mansion.”
Victims have alleged Epstein engaged in sexual conduct with them while he was on work release including at his mansion and at his Foundation. Attorney Brad Edwards also alleged that Epstein propositioned women between the ages of 18 and 20 at the Foundation office while he was on work release.
[In November 2018, the Miami Herald published a major exposé by Julie K. Brown. The series detailed the “deal of a lifetime,” and included interviews with many of the victims. At the time, Acosta was Secretary of Labor. He was compelled to resign in disgrace.]
14. Epstein flew domestically, internationally, and to the Virgin Islands despite being a registered sexual offender
Federal law enforcement apparently failed to monitor, verify, and act on Epstein’s travel obligations—allowing a registered sex offender with a private jet to move freely, including internationally, despite concrete leads and readily available tools to scrutinize or curtail his movements.
As a registered sex offender (Florida – see also here; later classified in January 2011 as Level-3 in New York), he was required under the Sex Offender Registration and Notification Act 2011 rules and International Megan’s Law (IML) (2016) to give authorities 21 days’ advance notice of any foreign travel.
Despite this, as detailed below, supervision and enforcement remained reactive: SDNY did not refer him to the U.S. Marshals Service (USMS) IML unit for suspected non-reporting until Jan. 8, 2019, and the USMS profile explicitly records “International Lookout Placed[:] No.”
By March 2019, his USVI Sex Offender Registry notice listed only “France,” while flight and FAA data showed additional flights to Vienna and Monaco, prompting a §2250(b) non-reporting probe. By his July 2019 pretrial detention litigation, the Government admitted that in the prior 18 months Epstein had taken more than 20 international flights by private jet (Epstein’s own attorney confirmed that he “traveled extensively,” including outside the United States, between November 2018 and July 2019); and he was arrested on July 6, 2019 after landing at Teterboro Airport in New Jersey from Paris.Taken together, authorities knew—or should have known—that a registered offender was repeatedly crossing borders, but they did not proactively verify or enforce his reporting obligations.
These lapses occurred despite the FBI and the U.S. Attorney’s Office for the Southern District of Florida investigating Epstein in 2006–07 for trafficking offenses, including interstate and potential international transportation of minors. (Prosecutors explored Mann Act/§ 2423 theories and reviewed flight logs, though the OPR Report (see e.g., p. 17) later stated that they lacked proof of cross-border transport at that time.)
(a) Pre-investigation travel: Reactive rather than preventative oversight. SDNY began its Epstein investigation in November 2018, and did not refer him to the USMS International Megan’s Law unit until Jan. 8, 2019 for suspected failures to report foreign travel. No lookout or other preventive measures appear in the case file. He continued flying internationally until his July 6, 2019 arrest on arrival from Paris.
“Jeffrey EPSTEIN was referred to the USMS IML Unit by the US Attorney’s Office for the Southern District of New York as … [someone who] travels frequently Internationally and may have not reported all his International travel as required by International Megan’s Law.
….
Investigation reveals EPSTEIN travels Internationally quite frequently using private planes and may have failed to report all his International travel. Based upon this information, a MS04 investigation has been initiated to determine if EPSTEIN is in Violation of Title 18 Section 2250(b) regarding his failure to report International travel.” (p. 66)
(b) During investigation travel: a March 2019 non-disclosure wasn’t acted on promptly. Epstein’s undisclosed international travel in March 2019 was not acted upon for nearly 12 weeks. His USVI Sex Offender Registry notified the USMS that Epstein had traveled internationally only to France from March 19 through March 29, 2019, but flight and FAA data showed he also traveled to additional countries (Austria and Monaco) during that same period in late March 2019. The USMS did not appear to initiate an investigation until June 13. Investigators took their first documented step toward MLATs over a month later, on July 17, when the USMS Senior Investigator raised submitting MLAT requests to France, Monaco, Austria, and Morocco with an Assistant US Attorney, who said he would subsequently do so. Investigators submitted a search warrant to SDNY for Epstein’s international phone records on July 22; and they received FAA flight details on August 5.
“On 3/19/2019 the USMS received notification from the US Virgin Islands Sex Offender Registry that EPSTEIN was traveling to France from 3/19/2019 through 03/29/2019 via his private jet (N212JE). No other countries are listed on the notification form. According to a public website that tracks flight activity EPSTEIN traveled on March 22, 2019 to Vienna, Austria and on March 27, 2019 to Monaco. These countries are not listed on the notification form. Based on the above information, an MS04 investigation has been initiated to determine if EPSTEIN is in violation of 18 USC 2250 (b) regarding his failure to report international travel.” (p. 62)
“ – On July 17, 2019 SI [USMS Senior Inspector] ████ spoke with the AUSA ████ in regards to submitting an MLAT request to the countries of France, Monaco, Austria, and Morocco. AUSA ████ stated he would submit the requests.
– On or about July 19, 2019 SI ████ and ████ spoke with Customs and Border Protection (CBP) in regards to obtaining flight logs and records for EPSTEINs private plane. CBP stated these could be obtained through the pilots themselves or maybe the FAA.
– On July 22, 2019 SI ████ submitted a search warrant to AUSA ████ for EPSTEINs phone number that he listed he can be reached on during international travel. SI ████ is hoping to gain historical information that may provide insight to countries EPSTEIN visited while on international travel.
– On August 5, 2019 SI ████ received information from the FAA in regards to flight plan histories. This information reveals numerous more Countries of international travel by EPSTEINs jet. It will be investigated further.
The investigation continues.” (p. 63)
15. Failure to further investigate Epstein/Maxwell before November 2018 despite revelations in several court cases
The DOJ and FBI failed to investigate after 2007 despite explosive revelations of a wider criminal conspiracy, including the role of Ghislaine Maxwell, in news reports and several civil lawsuits filed in the Southern District of New York and the Southern District of Florida.
(a) Maria Farmer, Notice of Claim Under the Federal Tort Claims Act to FBI (2023):
“Federal Law Enforcement’s Failures for More than Another Decade
The FBI did virtually nothing to stop the Epstein sex trafficking conspiracy for more than another decade and took further substantive action only:• after Claimant (and other survivors, including Sarah Ransome) complaint to federal law enforcement and actively engaged with non-FBI law enforcement;
• after lengthy prosecution of federal civil litigation alleging the NPA violated the Crime Victims Rights Act guarantees, leading to a judicial determination that the government’s failure to notify victims of the settlement and the NPA itself violated the ACT – e.g., Doe v. United States, 359 F. Supp. 3d 1201 (S.D. Fla. 2019)
• after numerous journalists reported the story; and
• after numerous other private lawsuits and other efforts brought this conspiracy to light and still do so – e.g., Doe v. Epstein, (2009) (579 F. Supp. 3d) (S.D.N.Y. 2012); Giuffre v. Maxwell, Case No. 1-15-cv-07433-LAP (S.D.N.Y. complaint filed 2015); and Jane Doe 1 v. Deutsche Bank et al., 22-cv-10018 (S.D.N.Y. 2022).”
(b) Victims brought several lawsuits, including by reputable law firms, that involved detailed allegations of the wider sex trafficking conspiracy and specifically identified Ghislaine Maxwell as a key part of the alleged criminal conspiracy.
Barry Levine, The Spider: Inside the Criminal Web of Jeffrey Epstein and Ghislaine Maxwell (Crown: 2020), p. 290:
“At the time [in 2019], one of the great mysteries in the Epstein saga was why Maxwell had never been charged with any crimes. From the time of her arrival in New York until Epstein’s incarceration in Florida in 2008, Ghislaine Maxwell had been by many accounts an active participant—or even a proactive lieutenant—in the financier’s international child sex trafficking ring. She had been implicated by dozens of victims as an accomplice to abuse and even a perpetrator of it in suits filed against her.”
A sample of those civil lawsuits is below. Several of the lawsuits led to large amounts of discovery, depositions and other court filings, which provided further information about Maxwell’s alleged conduct for the public at large and federal criminal investigators in particular.
2009:
Doe No. 101 v. Epstein, 9:09-cv-80591, (S.D. Fla.): Amended complaint (May 1, 2009) (Maxwell named as Epstein co-conspirator)
- Civil action under 18 U.S.C. § 2255, alleging violations of: § 2422(b) (coercion/enticement of minor to engage in prostitution or sexual activity), § 2423(b) (travel with intent to engage in illicit sexual conduct), § 2251 (sexual exploitation of children), § 2252(a)(1) (transport of visual depiction of minor engaging in sexually explicit conduct), § 2252A(a)(1) (transport of child pornography), § 2252A(g) (engaging in a child exploitation enterprise). The suit alleges that at age 17, in the spring of 2003, plaintiff was recruited by one of Epstein’s agents and abused at Epstein’s Palm Beach mansion, where assistants arranged transport/scheduling and paid $200 per “massage.” Beyond extensive sexual abuse, the complaint described Epstein’s attempt to have her procure other minors, hidden cameras and nude photos of minors in the mansion (alleging that lewd images of plaintiff may have been taken and transported interstate), and identified Ghislaine Maxwell—not a defendant—as Epstein’s “socialite friend/partner” who conspired with others to further the scheme and help Epstein evade police detection.
Doe No. 102 v. Epstein, 9:09-cv-80656, (S.D. Fla.): Complaint (May 4, 2009) (Maxwell named as Epstein co-conspirator)
- Civil action under 18 U.S.C. § 2255, alleging violations of: § 2422(b) (coercion/enticement of minor to engage in prostitution or sexual activity), § 2423(a) (transportation of minor with intent to engage in criminal sexual activity), §§ 2423(b) and 2421 (travel with intent to engage in illicit sexual conduct, § 2422(a) (coercion and enticement to engage in prostitution or sexual or activity), § 2251 (sexual exploitation of children), § 2252(a)(1) (transport of visual depictions of minor engaging in sexually explicit conduct), § 2252A(a)(1) (transport of child pornography), and § 2252A(g) (engaging in a child exploitation enterprise). The suit alleges that Epstein sexually abused and trafficked Virginia Giuffre beginning at age 15, after she was recruited by Ghislaine Maxwell at Mar-a-Lago in 1998; alleges repeated abuse across Palm Beach, New York, New Mexico, Los Angeles, Europe, the Caribbean, and Africa, with Maxwell facilitating grooming, transport, and direct sexual assaults, including instructing plaintiff to undress and “assaulting, battering, exploiting, and abusing Plaintiff.”
2010:
M.J. v. Epstein and Sarah Kellen, 9:10-cv-81111, (S.D. Fla.) in SDFL: Complaint (September 17, 2010) and statement (Maxwell named as part of an alleged civil RICO conspiracy with Epstein and Kellen)
- Claims include battery and intentional infliction of emotional distress against Epstein; conspiracy to commit tortious assault/battery against Kellen; twenty counts under 18 U.S.C. § 2255 premised on alleged violations of § 2422(b) (knowingly conspiring with others to entice Kellen and other minor females to engage in prostitution), § 2423(b) (travel with intent to engage in illicit sexual conduct), conspiracy under § 2423(e) (alleged incidents occurred every month between Aug. 2002–Mar. 2004); plus Florida Civil RICO under Fla. Stat. §§ 772.103(3)-(4). Plaintiff alleges that at age 16 she was escorted by Sarah Kellen into Epstein’s Palm Beach mansion, where Espstein abused her at least 20 times between the summer of 2002 and spring of 2004, and pressured her to recruit other minors; the enterprise used code words “work”/“massage,” targeted underprivileged minors, and engaged in witness intimidation/obstruction and post-2008 asset-hiding to thwart victims’ recovery; the RICO Statement identifies Ghislaine Maxwell, Jean-Luc Brunel, and Nadia Marcinkova (along with Kellen) as enterprise participants—Maxwell allegedly recruited minors, helped provide a “modeling” cover, and participated in sexual abuse.
2011:
Jane Doe 1 and Jane Doe 2 v. United States, 9:08-cv-80736, (S.D. Fla.): Motion (Maxwell named as co-conspirator in motion for finding violations Crime Victims Rights Act with non-prosecution agreement; subsequent motion in 2015 listed Maxwell as one of three people allegedly benefited by non-prosecution agreement)
- Motions brought under the Crime Victims’ Rights Act, 18 U.S.C. § 3771, seeking enforcement of victims’ rights to confer with prosecutors and be treated with fairness during pre-indictment negotiations; alleges that, while negotiating the 2007 NPA, the FBI and USAO-SDFL recognized an active “case” against Epstein but entered into a secret agreement deferring federal charges, concealed its terms from victims for months, and issued incomplete and misleading notices; discovery filings further allege that an AUSA, at the defense’s request, added a co-conspirator immunity clause to the NPA despite acknowledging this was atypical, took steps to prevent the NPA from becoming public, and failed to inform victims that it would block federal prosecutions; Maxwell was described as part of the larger enterprise in which Epstein acted “in concert … with others” to procure minors and a beneficiary of the non-prosecution immunity clause.
2014:
Jane Doe 1 and Jane Doe 2 v. United States, 9:08-cv-80736, (S.D. Fla.): Motion (Maxwell named as a “primary co-conspirator” of Epstein)
- Motion by Jane Does 3 & 4 (December 30, 2014) to join the 2011 suit (above) alleged that Maxwell recruited Jane Doe #3 at age 15, participated in abuse, and took sexually explicit photos shared with Epstein; that Doe #3 was trafficked domestically and internationally to Prince Andrew and Jean-Luc Brunel (using a “modeling” cover and obtaining passports), and that the government knew of Doe #3 (listed in 2007 NPA); cites the court’s earlier ruling that CVRA rights apply pre-indictment and frames joinder as relevant to the court’s evaluation of an alleged prosecutor–Epstein conspiracy to secure the NPA; Maxwell is described as “one of the main women whom Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator in his sexual abuse and sex trafficking scheme.” Maxwell and her agent’s responses to the press about these allegations in January 2015 led Giuffre to file a defamation suit against Maxwell in September 2015.
2017:
Jane Doe 43 v. Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen, Lesley Groff, Natalya Malyshev, 1:17-cv-00616, (S.D.N.Y.): Amended complaint (Maxwell named as co-conspirator)
- Trafficking Victims Protection Act suit under 18 U.S.C. § 1595—predicates alleged violations include § 1591 (sex trafficking of children), § 1592 (unlawful conduct with respect to Plaintiff’s passport and associated immigration documents), § 1593A (knowingly benefitting from participating in the alleged Epstein sex trafficking venture enterprise), § 1594(a) (for attempting to violate § 1591), and § 1594(b) and(c) (for conspiring to violate §§ 1591 and 1592, respectively) ). Plaintiff alleges that around Oct. 2006–May 2007, she (a South African living in New York) was recruited through fraudulent promises of career help and transported for commercial sex acts in New York and the U.S. Virgin Islands; Maxwell is described as the enterprise’s senior operator—designing the recruitment system, training/overseeing recruiters, controlling scheduling (the “rotation”), instructing techniques, and, with Epstein and Kellen, holding plaintiff’s passport to coerce compliance; Groff managed logistics/scheduling/travel and maintained communications to keep victims compliant; Malyshev acted as a recruiter who brought plaintiff in; the conduct used Epstein’s properties (in NY and the U.S. Virgin Islands) and aircraft. The complaint alleges a hierarchical venture supplying girls to Epstein and others, leveraging wealth, threats, and fraud, and notes the operation shifted from Palm Beach to New York/U.S. Virgin Islands around the 2007 NPA.
16. Failure to further investigate/indict Epstein post-2007 NPA and before 2018-19, despite tips to the FBI and Treasury Department, including from JPMorgan
Despite years of JPMorgan alerts—six Treasury filings (2002–2016), approximately 150 Cash Transaction Reports (73 before Epstein’s July 2006 arrest), and reports to federal law enforcement—no federal agency (FBI or any U.S. Attorney’s Office) contacted the bank or indicated any investigation.
(a) In Janes Does 1-6, Laura Newman, and Sandra Ward v. FBI (Sept. 2025), the plaintiffs allege: “The FBI failed to comply with FBI protocols and missed reports of bank involvement and government elites as co-conspirators,” citing to statements made by JPMorgan Chase in litigation (para. 66).
“66. The FBI received notices and tips of suspicious banking activity linking the accounts to funding sex trafficking. The FBI was notified that JP Morgan Chase handled more than $1.1 million in payments from Epstein to girls or women, many with Eastern European surnames. Again, nothing was done by the FBI to investigate and present evidence for prosecution until 2019.”
(b) In the U.S. Virgin Island’s suit against JPMorgan, bank counsel told the court that JPMorgan made six filings with the Treasury Department (2002, 2003, 2008, 2013, 2015, 2016); further said that the bank had also reported Epstein-related “financial activity to federal law enforcement”; and between 2002 and 2013 JPMC filed approximately 150 Cash Transaction Reports on Epstein (73 before his July 2006 arrest), and law enforcement never contacted the bank in response.
“There are six filings made with the treasury department during the course of the relationship between JPMorgan and Jeffrey Epstein that predate that final post-death filing.” (p. 31)
“There were failings [sic] made with the Treasury Department, and there was no response or action taken by the federal government in response to filings made in 2002, 2003, 2008, 2013, 2015 and 2016.” (pp. 33-4)
“JPMC states that it reported … financial activity to federal law enforcement in the form of Cash Transaction Reports (‘CTRs’).” (p. 27)
“Between 2002 and 2013, JPMC filed approximately 150 CTRs related to Epstein and his accounts in which JPMC identified its relationship with Epstein, flagged his large cash withdrawals[.] […] Seventy-three of these CTRs were filed before Epstein was arrested in July 2006. […] Law enforcement never contacted JPMC in response to any CTR.” (p. 8)
(c) In a sworn deposition in the U.S. Virgin Island’s suit against JPMorgan, then managing director for the bank’s Financial Intelligence Unit, Phillip DeLuca, said at some point around 2009-2011, he called Special Agent Tim Moyer, DeLuca’s regular contact at the FBI, to “exchange information” about Epstein. Moyer told DeLuca that he would call DeLuca back later to discuss Epstein, but did not do so. DeLuca interpreted this to mean the FBI “weren’t interested.”
“Question: Given your consistent dealings with law enforcement, how did you interpret the fact that the FBI never got back to you about Epstein?
De Luca: That they weren’t interested.”
17. Federal law enforcement failed to investigate after 2007; trafficking persisted through at least 2017, and evidence seized in July 2019 indicates continued criminal conduct including child sexual abuse material (CSAM)
(a) The Government of U.S. Virgin Islands Second Amended Complaint (and here) against the Jeffrey Epstein Estate and two Executors of the Estate (background info: news report):
“61. Another victim was flown by Epstein and his associates to New York or Palm Beach and then to the Virgin Islands dozens of times from 2004, when she was age 20, to 2017. She was repeatedly abused by Epstein and also was pressed to have sex with Epstein’s business colleagues.”
“213. Another victim was brought by Defendants dozens of times between 2004 and 2017 to Little St. James, where she too observed a succession of young women and female children who likewise were transported to the island and were required to have sexual relations with Epstein and his guests.”
(b) Kaitlyn Doe’s complaint alleges sexual assaults from 2007-2014, including when Epstein was on work-release during his Florida sentence.
(c) Janes Does 1-6, Laura Newman, and Sandra Ward v. FBI (Complaint) (Sept. 2025):
“Court papers filed in Epstein’s much-delayed child sex trafficking case in 2019 had evidence of CDs containing child pornography with handwritten labels including “Young [Name] + [Name],” “Misc nudes 1” and “Girl pics nude.” The massage table, where many of the victims were abused and raped by Epstein and his friends, was still in his Upper East side mansion in 2019 when raided.” (para. 12)
18. Deficiencies in the 2020 OPR report
The DOJ’s OPR report drew sharp criticism as a “whitewash”: the Department initially released only an executive summary to the public (the full report later surfaced via the Washington Post), and it recast what many viewed to be clear professional misconduct as mere “poor judgment.” Critics of the report included the lead prosecutor in the Southern District of Florida. In court, victims’ counsel also argued that DOJ had withheld key documents and failed to retrieve critical records — despite acknowledged victim-notification failures and the premature closure of the federal probe.
The report downplayed a “data gap” in Alex Acosta’s email inbox that lasted between May 2007 to April 2008—a crucial period, spanning from the time when Acosta’s Office prepared a draft indictment against Epstein to shortly before Epstein pleaded guilty in state court, during which Epstein’s lawyers aggressively lobbied federal prosecutors to end the federal case. As former judge Paul Cassell, one of the victims’ attorneys, said, “The gap seems to have surgically struck on exactly the time period when most of the big decisions were being made. I was stunned because you would think if there was ever a case where the Justice Department would have been very careful to make sure they had complete records and things weren’t missing, this would be the one.” But mention of Acosta’s missing emails were only in a brief section in an appendix on “methodology” in the report.
Victims rebuked the OPR report as a “slap in the face” and said they were giving up hope of ever achieving real accountability.
(a) Criticisms of OPR by Southern District of Florida lead prosecutor Marie Villafaña, who drafted the federal indictment against Epstein in 2007
The lead prosecutor in the US Attorney’s Office, Marie Villafaña, made a public statement after the OPR’s report was released sharply criticizing “implicit institutional biases that prevented me and the FBI agents who worked diligently on this case from holding Mr. Epstein accountable for his crimes” and the failure of OPR to consider those factors:
“I am pleased that OPR finally has completed its investigation but am disappointed that it has not released the full report so the victims and the public can have a fuller accounting of the depth of interference that led to the patently unjust outcome in the Epstein case.”
“That injustice, I believe, was the result of deep, implicit institutional biases that prevented me and the FBI agents who worked diligently on this case from holding Mr. Epstein accountable for his crimes. By not considering those implicit biases based on gender and socioeconomic status, OPR lost an opportunity to make recommendations for institutional changes that could prevent results like this one from occurring in the future.” (emphasis added)
(b) From victims’ lawyers and survivors
- Jena-Lisa Jones (victim): “It felt very much like another slap in the face.” “I’m still very, very mad at this whole situation.” “I was hoping to have a little bit more peace when I came out of this, a little bit more answers on to what had happened, what was going on. And if anything, it left me more angry.” She further said, “I honestly don’t think that anybody will take responsibility in any sense, in any shape or form in the way that they actually should as adults.”
- Dainya Nida (victim): “Any time I am involved in any of this I never have any expectations anymore because I know I am never going to get the answer why.”
- Paul Cassell (a former federal judge and lawyer representing victims): “I think, frankly, what we got was an effort to paper over what happened.” “I think they’re trying to put the most favorable light on what’s clearly misconduct on the part of their attorneys.” He also said the report was “a coverup,” blasted OPR for not interviewing Epstein’s defense attorneys, and flagged a “technical glitch” that left a year-long gap in Alex Acosta’s incoming emails during key decision months.“How can you possibly claim you’ve done a thorough investigation without exploring these issues?” “The report lets Acosta take the fall for everybody,” Cassell said, adding, “That’s very convenient since he’s left the Justice Department.”
- Brad Edwards (lawyer representing victims) criticized the report for “backing into the conclusions they wanted.” “They decided before it started, how are we going to reach the conclusion that there was no wrongdoing or that the victims’ rights weren’t violated.” “And let’s figure out a way to maneuver around the actual facts and reach those conclusions.” He also said, “They just say he used poor judgment, and that’s their way of basically letting everyone off the hook while offering some sort of an olive branch to the victims that we acknowledge weren’t treated perfectly.” “But nobody really did anything wrong. It’s really offensive. It’s hurtful.”
- Adam Horowitz (lawyer representing victims): “The mountain of mistakes was not just poor judgment. It was reckless.”
(c) Congressional reaction
- Sen. Ben Sasse (R-NE), Chairman of the Senate Judiciary Oversight Subcommittee: “Letting a well-connected billionaire get away with child rape and international sex trafficking isn’t ‘poor judgment’ — it is a disgusting failure. Americans ought to be enraged.” “Epstein should be rotting behind bars today, but the Justice Department failed Epstein’s victims at every turn.” “The DOJ’s crooked deal with Epstein effectively shut down investigations into his child sex trafficking ring and protected his co-conspirators in other states. Justice has not been served.” “The full report needs to be released to the public. OPR might have finished its report, but we have an obligation to make sure this never happens again.”
- Sen. Tim Kaine (D-VA.): ““How is letting a child sex trafficker walk free anything but gross professional misconduct? How is keeping the plea deal secret from the survivors not a clear violation of the Crime Victims’ Rights Act? The light-handedness of OPR’s report is just the latest in a long series of failures by the Justice Department to deliver justice for these young women and girls.”
(d) Judicial reaction
- In re Courtney Wild, 994 F.3d 1244 (11th Cir. en banc 2021) (Judge Frank Hull, dissenting) p. 182, n10: “The DOJ’s failure to discipline its own prosecutors heightens the importance of the CVRA’s private right of action. … Given the OPR Report, it is hardly surprising the victims continue to pursue this civil suit to discover and unravel the mystery of why the prosecutors not only signed such a sweetheart plea deal for the billionaire Epstein in the first place but did so in secret and then for nearly a year took great efforts to hide the Agreement by affirmative misrepresentations to the victims and their counsel too.
19. Blocking DOJ Inspector General from investigating failures
(a) The Deputy Attorney General denied the Department’s Office of Inspector General’s requests to review the NPA, according to statements by the Inspector General provided to Congress in May 2021:
“The IG Access Act is needed precisely because the Department has consistently denied the OIG’s requests to investigate serious allegations of professional misconduct by lawyers, including the circumstances under which Jeffrey Epstein received a non-prosecution agreement from the Southern District of Florida. The NAAUSA letter also asserts that because current law allows the OIG to investigate attorney professional misconduct with the approval of the Deputy Attorney General, there is no need for the IG Access Act. Although NAAUSA is correct that existing Department regulations allow the OIG to request authority from the Deputy Attorney General to conduct a professional misconduct investigation, the reality is that in every instance where the OIG has made a request pursuant to the regulation, the then Deputy Attorney General has denied the OIG’s request, including the Epstein case. Moreover, requiring the OIG to request permission from Department leadership to handle a matter, and empowering the Deputy Attorney General to “block” OIG oversight of a serious misconduct allegation, undermines IG independence and is inconsistent with the Inspector General Act.” p. 4 (emphasis added).
(b) Inspector General told Congress again in October 2021:
“Although existing Department regulations allow the OIG to request authority from the Deputy Attorney General to conduct a professional misconduct investigation, the reality is that in every instance where the OIG has made a request pursuant to the regulation, the then Deputy Attorney General has denied the OIG’s request. That includes, most recently, the OIG’s request to investigate the circumstances under which Jeffrey Epstein received a non-prosecution agreement from the Southern District of Florida.” p. 3.
20. Executive Branch handling of the Epstein file and Maxwell imprisonment in 2025
The Justice Department engaged in the following conduct in 2025:
(a) After senior officials promised to provide the public with transparency in releasing information in the Epstein file, an unsigned memo by DOJ and FBI stated on July 7, 2025:
“One of our highest priorities is combatting child exploitation and bringing justice to victims. Perpetuating unfounded theories about Epstein serves neither of those ends. To that end, while we have labored to provide the public with maximum information regarding Epstein and ensured examination of any evidence in the government’s possession, it is the determination of the Department of Justice and the Federal Bureau of Investigation that no further disclosure would be appropriate or warranted.” (emphasis added).
Note-1: Attorney General Pam Bondi reportedly ordered the FBI to engage in an extraordinary review of all the files and to “flag” any records in which President Trump was mentioned, a process that took place from March 14 to late March (see Sen. Durbin letter to AG Bondi). In May, Attorney General Bondi and Deputy Attorney General Todd Blanche reportedly informed the president that his name appears multiple times in the files.
Note-2: The longtime Section Chief of the FBI’s Record/Information Dissemination Section was reportedly forced out after clashing with senior DOJ/FBI officials over the process for handling the files.
(b) The DOJ and FBI July 7 memo also stated (implausibly): “We did not uncover evidence that could predicate an investigation against uncharged third parties.”
Annie Farmer’s attorneys wrote to federal courts:
“[T]he Government’s recent suggestion that no further criminal investigations are forthcoming is a cowardly abdication of its duties to protect and serve. It is obviously impossible for two people to conduct a decades-long sex-trafficking enterprise involving thousands of victims without other individuals who participated in and facilitated these unspeakable atrocities.” p. 1.
(c) The DOJ did not communicate with victims before requesting the release of grand jury materials in the Epstein and Maxwell cases, an omission revealed after the judges in those cases asked whether DOJ had done so.
Victims’ attorneys Edwards and Cassel told Judge Berman:
“Given our history fighting for the enforcement of the CVRA on behalf of Jeffrey Epstein’s many victims, we were quite surprised to learn that the government sought the unsealing of grand jury materials before this Court without first conferring with the victims or their counsel, a step required by the CVRA and reinforced by Doe v. United States, 08-80736 (S.D. Fla.). … This omission reinforces the perception that the victims are, at best, an afterthought to the current administration.” p. 2.
(d) Judge Engelmeyer strongly criticized the government for its request to unseal the grand jury transcripts. The court emphasized repeatedly that the transcripts would provide no information that was not already a part of the public record. He remarked, “A member of the public, appreciating that the Maxwell grand jury materials do not contribute anything to public knowledge, might conclude that the Government’s motion for their unsealing was aimed not at ‘transparency’ but at diversion—aimed not at full disclosure but at the illusion of such” (emphasis added). And he suggested the government’s false claims that the grand jury transcripts contained critical information may have misled the victims. “Had the Government’s motion made clear that these records are redundant of the evidence at Maxwell’s public trial, the victims’ responses to the motion to unseal might well have been different,” the judge wrote.
(e) The DOJ did not communicate with victims before moving Ghislaine Maxwell to a lower-security prison.
Victims’ attorneys Edwards and Cassel told Judge Engelmeyer:
“Maxwell’s recent move to a lower-security prison has further eroded the victims’ confidence that their safety and dignity are priorities. The transfer was made without prior notice to the victims, without opportunity to object, and without explanation-actions they see as extraordinarily insensitive and suggestive of ulterior purposes.”
(f) The government has provided no explanation for transferring Maxwell to a minimum-security federal prison camp in Bryan, Texas. A letter by House Judiciary Committee Democrats demanded information from DOJ and the Bureau of Prisons relating to the transfer and Deputy AG Blanche’s interview with Maxwell, stating: “These actions raise substantial concerns that the Administration may now be attempting to tamper with a crucial witness, conceal President Trump’s relationship with convicted sex offenders, and coax Ms. Maxwell into providing false or misleading testimony in order to protect the President. The transfer also appears to violate both DOJ and Bureau of Prisons (BOP) policies.” The letter further noted that the lower security facility, with “greater freedom for inmates,” was, “prior to this extraordinary transfer, categorically off-limits to sex offenders.” The letter also stated, “Even if a waiver were to be granted, standard BOP policy would allow for a waiver only after multiple levels of review that would ordinarily take months to complete. Even if approved for a redesignation, which typically requires new facts or evidence, an inmate would then have to join a months-long waitlist for an opening at a camp.”
(g) The President has made publicly statements that raise concerns he would pardon or commute Maxwell. As attorneys Edwards and Cassel told a federal court, “The risk of a pardon or commutation exacerbates safety concerns in derogation of§ 3771(a)(l), and threatens severe psychological harm, including triggering trauma responses.”
21. Congressional handling of the Epstein file and Maxwell imprisonment in 2025
(a) In July, Speaker of the House Mike Johnson (R-LA) took the rare step of recessing the House early for the summer, in order to avoid holding votes related to releasing the Epstein files. Speaker Johnson said he wanted to give the Trump Administration “space” to disclose information related to Epstein on its own, without Congressional action; to date, the White House (and DOJ) has revealed no new information since the House recessed. The discharge petition, which would force a House vote on whether DOJ must release information contained in the Epstein files, is “set to trigger a vote within days of the House’s return in September.”
(b) Speaker Johnson criticized the bipartisan discharge petition. Speaker Johnson called it “reckless” and said: “I agree with President Trump, with the Department of Justice, with the FBI that you need all credible evidence and information out there,” Johnson said. “That word ‘credible’ is important. And why? Because you have to protect innocent people’s names and reputations whose names might be, as you noted at the outset of the program, intertwined into all these files.”
(c) On August 11, the House Oversight Committee issued eleven subpoenas related to Jeffrey Epstein and Ghislaine Maxwell. The Committee, chaired by Rep. James Comer (R-KY), issued deposition subpoenas for former Attorneys General and FBI Directors; and a document subpoena to DOJ for information related to Epstein. The first subpoena is due Monday, August 18. However, it failed to subpoena some of the most relevant and important individuals involved in the federal investigation of Epstein and Maxwell, including: Alex Acosta, the former U.S. Attorney for the Southern District of Florida during the office’s Epstein investigation between 2006-07;Marie Villafaña, the lead prosecutor in the SDFL office handling the Epstein investigation; Geoffrey Berman, the former U.S. Attorney for the Southern District of New York when Epstein was indicted in 2019; and Audrey Strauss, the deputy U.S. Attorney in SDNY under Berman and Acting U.S. Attorney when Ghislaine Maxwell was charged.
(d) On July 29, Senate Democrats sent a letter to Attorney General Bondi demanding “the full and complete Epstein files” no later than August 15, pursuant to 5 U.S.C §2954, which requires “[a]n executive agency, on request of … any five members” of the Committee on Governmental Affairs of the Senate, to “submit any information requested of it relating to any matter within the jurisdiction of the committee.” DOJ ignored this request, and on August 15, Senate Minority Leader Chuck Schumer (D-NY) accused the Trump Administration of “breaking the law” and threatened to sue.
