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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA,

v. 

JEFFREY EPSTEIN,

x

19 CR 490 (RMB)

Defendant.

x

New York, N.Y.
August 27, 2019
10:30 a.m.

Before:

HON. RICHARD M. BERMAN,

District Judge

## APPEARANCES

GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York

BY: 

Assistant United States Attorneys

MARTIN G. WEINBERG, PC
Attorney for Defendant
BY: MARTIN G. WEINBERG

STEPTOE & JOHNSON, LLP
Attorneys for Defendant

BY: REID WEINGARTEN
MICHAEL MILLER

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(Case called)

THE COURT: Good morning, everybody. Please be

seated.

So just some housekeeping. We have a podium here for both attorneys and others who may be speaking, and so we would like you, attorneys and others who are speaking, to come up to the podium. This room is a little cavernous. We thought the podium over there would be more comfortable.

For starters, and for this you don't have to go up to the podium, if you could just indicate your names. This table in front to my left, your right, are defense counsel, and that table to my right, your left, are government attorneys.

If we could just ask the attorneys to introduce themselves.

MS. : Good morning, your Honor. and for the government. Joining us at counsel table are Special Agent of the FBI and Detective Paul Byrne of the NYPD.

MR. WEINGARTEN: Good morning, your Honor. Reid Weingarten. MR. WEINBERG: Martin Weinberg. Good morning, your Honor. THE COURT: Good morning. MR. MILLER: Good morning, your Honor. Michael Miller from Steptoe & Johnson on behalf of the

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defendant.

THE COURT: Great. Again, good morning to all of you. This hearing that we're having today considers the government's motion to dismiss the indictment in this case.

I must add that it also serves as the opportunity for me to thank all of you, the attorneys and the victims who are here today, among others, for your very hard work and dedication in this case.

We also have here today the U.S. Attorney for the Southern District of New York, Geoffrey Berman, who has also been very helpful and indispensable in this matter.

The news on August 10, 2019, that Jeffrey Epstein had been found dead in his cell at the Metropolitan Correctional Center, at the MCC, was certainly shocking. Most of you, and myself for that matter, were anticipating that the next steps in this case would be defense motion practice, including a motion to dismiss, followed by a trial on the merits before a jury, if the motions were not successful, and through which the accusers and the accused would come face to face, allowing everyone to get their day in court. Mr. Epstein's death obviously means that a trial in which he is a defendant cannot take place. It is a rather stunning turn of events.

The government's motion to dismiss the indictment 25 because of Jeffrey Epstein's death on August 10, 2019, is

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relatively straightforward. In my view, a public hearing clearly is nevertheless the preferred vehicle for its resolution.

Incidentally, while I'm on this subject, I got some 5 help today from the New York Law Journal from two professors who write that a hearing is -- let me tell you exactly what they said. They say, in part, that this is an odd moment for transparency in a criminal case. I think that is an odd sentence to hear about, transparency in a criminal case.

They go on to say that normally, if a prosecutor seeks to dismiss an indictment for such an obviously worthy reason, the court would simply grant the request. As to that statement, I respectfully say it is incorrect as a matter of law.

They go on to say the judge would not schedule a hearing and he definitely would not allow the victims to speak. If he did hold a hearing, whatever informational interests the victims may have would be served by affording them a chance to attend the hearing, not by giving them a speaking role.

I read it. It was incredulous. I'm still incredulous. I don't quite understand at all. There is a suggestion in the article that the reason they are making these suggestions has to do with minimization of drama in this case. In the Jeffrey Epstein case, there has not been much a minimization of drama, and what little drama might happen

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today, I don't think it would be very significant.

On a somewhat more serious note, don't quote me on this, but it is my understanding that one of the authors of that article is himself counsel in one of the Epstein-related cases. I was surprised to learn that very recently. I'm certain it is true. I was also surprised that that aspect was not disclosed in the Law Journal.

But in any event, I think you know where I'm heading. I respectfully disagree with the Law Journal piece. I was saying that the government's motion is relatively straightforward, and in my view, a public hearing is clearly, nevertheless, the preferred vehicle for its resolution. I'm still convinced of that.

A few may differ on this, but public hearings are exactly what judges do. Hearings promote transparency and they provide the court with insights and information which the court may not otherwise be aware of.

The victims have been included in the proceeding today both because of their relevant experiences and because they should always be involved before rather than after the fact.

Indictment 19 CR 490 charges Jeffrey Epstein with sex trafficking and with conspiracy to commit sex trafficking. The U.S. Attorney, on August 19, 2019, requested that the court 24 approve the government's proposed order of nolle prosequi. I think that's a rough justice. That means nolle prosequi,

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discontinuance by the prosecutor of all or of a part of the case that he or she has commenced.

The government in its motion concludes that Epstein's death abates these proceedings. In accordance with Federal Rule of Criminal Procedure 57(b), I determined to hold a public hearing and I notified the victims that they would be given the opportunity to be heard before any final action on the motion. That is the purpose also of today's proceeding. I would do that every time.

Also, recognized that Epstein, Mr. Epstein died before any judgment of conviction against him had been obtained, and that the government's proposed order appears, in form and substance, to be appropriate.

Federal Rule of Criminal Procedure 48(a) codifies the nolle prosequi process. It is entitled dismissal, and it states in relevant part that the government may, with leave of the court, dismiss an indictment, information, or complaint, and that leave of the court proviso, you should know, was added as an amendment to the original draft of Rule 48, which had originally provided for automatic dismissal upon the motion of the government.

This proviso, in my judgment, is clearly directed toward an independent judicial assessment of the public interest in dismissing the indictment. Thus, even whereas, in this case, the standard of court review is deferential, the

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court must still make its own independent determination. A conclusory statement from the government that dismissal is appropriate does not satisfy the court's obligations.

It is also, in my view, required that the court consider the views of the victims in the case at the hearing and before deciding whether to grant the motion. This is being done here both as a matter of law and as a measure of respect that we have for the victims' difficult decisions to come forward in this matter.

In a case called United States v. Heaton, H-e-a-t-o-n-, the government filed a Rule 48 motion for leave to dismiss a charge against a defendant who allegedly committed a sexual offense against a young victim. Although I should point out, very importantly, that that defendant was still alive, which distinguishes it from our case.

Nevertheless, I think it is irrelevant because in evaluating the Rule 48 motion, then district Judge Paul G. Cassell -- who is now a law professor at the University of Utah and is regarded to be a noted expert in victims' rights -- concluded that under the Crime Victims' Rights Act, victims have broad rights that extend to a court's decision whether to grant a government motion to dismiss under Rule 48.

I completely share that viewpoint in these circumstances, even though the facts of our case, as I said, are somewhat different from those in Heaton. I believe it is

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the court's responsibility, and manifestly within its purview, to ensure that the victims in this case are treated fairly and with dignity.

The fundamental substantive principle which applies in 5 considering the government's motion is termed the rule of abatement. This principle originated in the English common law. It was adopted by most U.S. federal courts, but more recently, it has faced some appropriate criticism. The rule of abatement is best explained in the Second Circuit case of U.S. v. Wright.

In that Wright case, two defendants had pled guilty to embezzlement and tax evasion. Both defendants appealed, but one of the defendants died while his appeal was pending in the Second Circuit. The Court of Appeals rule that under the rule of abatement, the judgment of conviction against the deceased defendant was required to be vacated and the indictment was to be dismissed. The Wright court held that when a convicted defendant dies while his direct appeal as of right is pending, his death abates not only the appeal, but also proceedings had during the course of the prosecution.

The Second Circuit incidentally has also held that when a criminal conviction abates upon the death of a defendant, any restitution ordered as a result of that conviction must also abate, and it is also ruled the same with respect to associated forfeiture orders.

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This latter application of the rule of abatement 2 regarding forfeiture has not been universally accepted among federal courts, but it certainly is the law in this circuit. Some of you may be interested to know that some United States courts, state courts, have criticized the rule of abatement, particularly in the face of growing recognition of victims' rights in the criminal justice system, including the Crime Victims' Rights Act.

It has been written and contended in the Brooklyn Law Review -- I can give you the cite later -- that when courts abate criminal convictions, they reimpose a burden on victims that legislatures intended to alleviate through these victim rights statutes. The state Supreme Court has even concluded that the expansion and codification of victims' rights provides the changed conditions needed for overruling the rule of abatement. It has also been stated that Alaska's statute and its constitution now require the criminal justice system to accommodate the rights of crime victims. Further, that the abatement of criminal convictions has important implications for these rights.

But coming back to our case, which is what you are concerned about and I am as well, it is appropriate to conclude 23 that if the rule of abatement applies to a convicted defendant as in the Wright case, it should also apply a fortiori in the Epstein case, which was still in the pretrial phase when

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Mr. Epstein died, when there had been no conviction.

So that's just some background I wanted to share with you. At this point in time, I would like to turn to the government prosecutors to hear from them in support of their Rule 48 application to dismiss the Epstein indictment.

MS. : Thank you, your Honor. Would you like me to address the court from the

podium?

THE COURT: If you wouldn't mind. MS. : Thank you, your Honor.

I believe your Honor has accurately summarized the state of the law, as set forth in our papers, in light of the clear Second Circuit law, that upon the death of a defendant before a final entry of a judgment of conviction, all proceedings must be abated.

In light of that clear law, the government is legally obligated to seek dismissal of the pending indictment against Jeffrey Epstein, and we respectfully submit, likewise, that the entry of the proposed order is similarly required by law.

A few notes to make about that, though, your Honor. To be very clear, dismissal of this indictment as to Jeffrey Epstein in no way prohibits or inhibits the government's ongoing investigation into other potential coconspirators, nor does it prevent the bringing of a new case in the future or the prosecution of new defendants.

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It also does nothing to prevent the government from continuing to explore the possibility of seeking civil forfeiture of any assets that were used to facilitate the crimes charged in this indictment. Indeed, as has been stated 5 publicly, investigations into those matters have been ongoing, remain ongoing, and will continue following dismissal of the indictment here.

I would also like to note that, as the government has previously mentioned, this dismissal in no way lessens the government's resolve to stand up for the victims in this case, both those who have come forward and those who have yet to do so. We agree with your Honor's sentiment that those victims should be respected, and we appreciate your Honor's recognition of that.

One housekeeping matter that I did want to reference for your Honor. The protective order in this case requires destruction or return of any and all discovery material upon conclusion of the case. We have been in communication with defense counsel, who have confirmed that they have returned all physical copies that they have of discovery that the government has produced to date, and they are in the process of deleting any copies that they may have made. So the parties are in compliance with the protective order.

Finally, I just wanted to say a word about the victims in this case, and particularly those who are here in court

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today. I'll note that in light of the court's order indicating that the victims and their counsel would be permitted to be heard in court here today, the government has endeavored to provide notice to all known victims of today's proceeding. We did so either directly where a victim was not represented by counsel or through counsel where a victim is represented by an attorney.

The government does not know exactly how many victims or their attorneys are here today and we do not know how many of them or their counsel would like to speak. To the extent any individuals do wish to speak, we do not know the substance of what they would like to say. We have left that entirely up to the individual decisions of the victims and their attorneys.

I will note, though, that throughout this case, the government has endeavored and done our utmost to fulfill our obligations under the Crimes Victims' Rights Act. We have done so by trying to keep as many victims as we are aware of up to date about the ongoing case and about any developments in the case.

We will continue to provide services and offer services to any of the victims in this case, even after the indictment is dismissed. Both the U.S. Attorney's office and the FBI have been in touch with all known victims or have attempted to be in touch with all known victims, either again 25 directly where victims are not represented by counsel or

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through counsel where they have attorneys. We have expressed to them that services are available for those who wish to take advantage of them.

Unless the court has any questions for me, the government will otherwise rest on its papers.

THE COURT: I just have one question.

The protective order, is that self-executing or do 1 need to do something?

MS. : It is self-executing, your Honor. THE COURT: Thanks very much, Ms. MS. : Thank you, your Honor. THE COURT: Yes.

I'll turn to counsel for the defense at this time. Mr. Weingarten, I'm happy to hear from you.

MR. WEINGARTEN: Thank you.

Your Honor, I think it is an understatement of the year to say the world looks and feels differently today than it did the last time I was before you. For us, the elephant in the room is what happened to our client. I would like to tell you how we see the world and where we are on that subject.

We start with the Attorney General's statements, public statements, that there were very serious improprieties in the jail. We obviously read the press. We see that the warden has been taken out. We see that the guards on duty at the time have been put on leave. We understand guards are

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refusing to cooperate with the investigation. We have heard allegations that people at the time who had responsibility for protecting our client falsified information. We understand that there were orders out there that Jeffrey Epstein was never to be left alone and that the orders were ignored by many of the employees of the prison.

In a word, yikes. In addition, obviously we followed the medical examiner's report, or we haven't followed the report, we haven't seen it, but heard conclusions, initially not enough evidence to come to a conclusion, wanted to see more. We assumed she was talking about the videotapes, but then came to the conclusion that it was suicide.

We report to the court that

THE COURT: Suicide by hanging --

MR. WEINGARTEN: Yes.

THE COURT: -- was her conclusion?

MR. WEINGARTEN: Yes.

And we report to the court that we had a doctor there at the time, and we also have been in receipt of a tremendous amount of medical and scientific evidence volunteered to us opining that the injuries suffered, as reported, were far more consistent with assault than with suicide, and we are happy to supply the court with all the information that we have.

Now, in addition, as the court noted, we were underway with our pretrial motions, and as the court obviously

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understands, the NPA and the role of the NPA was going to be critically important. And I would simply like to report that we went pretty far along.

We interviewed all of the relevant lawyers on the defense side who participated in the NPA, and we were satisfied that we had a very strong argument that every one of those lawyers believed with an objective basis that the deal was global. That is, at the time --

THE COURT: I'm sorry, that?

MR. WEINGARTEN: The deal of the NPA was global. That is, more specifically, at the time, the Florida prosecutors and agents knew of conduct in New York, and that no competent defense counsel negotiating in good faith with the prosecutors would have ever agreed to a deal back then that allowed New York prosecutors to indict for precisely the same conduct in the future, which, of course, is what happened.

In addition, we have come up with very powerful evidence, we believe, that Florida prosecutors, who participated in the deal, steered the victims and the alleged victims to New York on more than one occasion because they did not want to suffer the sleights of attacks against them. So we have advanced the ball on this very subject and we are prepared to completely report to the court as to where we are and what we've done.

Another point. We obviously had contact with our

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client at or around the time of his death, and obviously the attorney-client privilege survives death and we are not going to forfeit the privilege, but we will report to the court, with as much specificity as the court may want, that at or around the time of his death, we did not see a despairing, despondent suicidal person. Details to follow, if the court wishes.

The 800-pound gorilla, for us, of course, are the video surveillance tapes. Obviously we assume there is a tape that leads directly to the door where Jeffrey Epstein was housed. If that tape reports for 12 hours before his death that no one went in and out of that room, then the suggestion that there was something other than a suicide seems preposterous.

But there is no such evidence that has surfaced to date. Just the opposite. We have heard, and we actually read in the press, that the tapes were either corrupted or not functioning. Talk about a yikes. If, in fact, the system was broken for six months before Jeffrey Epstein was housed, I mean, that would be stunning incompetence. If it was allowed to continue to be inoperative when Jeffrey Epstein was housed, it would be incompetence times ten. But what if the tapes only broke down or were inoperative or were corrupted on the day he was killed or the day he died? Then we're in a completely different situation.

So where does this lead? I think where it leads,

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Judge, is there are incredibly important questions that remain open. The public interest in this matter is obvious from this courtroom. There are conspiracy theories galore. We are all for finding the truth. We believe this court has an indispensable role to play.

Whether or not this indictment is dismissed, I think this court has the inherent authority to find out what happened on its watch. Obviously, when the court detained Jeffrey Epstein, the court did not anticipate that weeks later he would be dead in his cell. I think given the inherent authority of the court, the court should make inquiry.

This could come in many forms. Obviously the court made inquiry as to what happened in the first incident. When there was an allegation of an attempted suicide, the court made inquiry. The court obviously was interested.

I recall your language. You talked about that being one of the several open questions indicating an interest on the court for the others as well. Obviously, the ultimate question is what happened to the client.

THE COURT: You're talking about the July 23, 2019 incident?

MR. WEINGARTEN: Yes.

The court obviously could hold hearings. The court 24 could assign a lawyer to help the court. I think this is an area where there is intense public interest. We have complete

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confidence in the prosecutors in the Southern District and the FBI to do a competent investigation. But these are allegations against serious components of the United States Department of Justice. Sometimes the appearance of justice is just as important as justice itself.

I think the court supervising, or at least keeping an interest in this proceeding, is incredibly important for the public to have confidence in the ultimate findings, and certainly for us to have confidence in the ultimate findings.

One more issue, Judge. The conditions of the jail, in a word, they were dreadful. Not just for Jeffrey Epstein, but for many of the prisoners over there. This is a prison within the shadows of this courthouse. The situation is rife with vermin. The abuse and the conditions in that prison, in a word, are a disgrace and everybody knows it.

A person with authority told us, someone with knowledge, that the prisoners in Guantanamo -- and he spoke with personal knowledge -- are treated better than the prisoners right across the way. The feds certainly know how run a disciplined, clean prison. I've been in 20 of them. They know how to do it just fine. And the question is, why in the world does it not happen down the road? I think that is a perfectly legitimate subject for the court to make inquiry.

to

In a word, we want the court to help us find out what happened. The court has a role to play. It is the institution

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that most people have confidence in in these very troubled times.

So whether or not you dismiss the indictment, to us, is beside the point. We want you to stay on the case, we want you to conduct an investigation, and we want to know what happened here.

Thank you, your Honor.

THE COURT: Just so it is clear, so your view on the motion directly on its merits of the nolle prosequi order and application by the U.S. Attorney, do you have a view on that?

MR. WEINGARTEN: I think if the court felt that the case had to stay alive for the court to continue, we would oppose it. I think --

THE COURT: I'm sorry, if what?

MR. WEINGARTEN: If the issue, if you took the position for you to conduct the investigation or lead the investigation or participate in the investigation, then we want, the role we want you to play, if the indictment has to be alive, we would oppose the motion.

I don't think you need to do that. I think you can dismiss the indictment.

THE COURT: So you're suggesting that you support the government's motion, just viewed in the context of -- MR. WEINGARTEN: Yes, of course. THE COURT: Great.

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MR. WEINBERG: Judge, if I can just supplement? THE COURT: Absolutely.

MR. WEINBERG: Thank you, sir.

Thank you, as an out-of-town lawyer for the privilege to appear in front of you, your Honor.

THE COURT: It's my pleasure.

MR. WEINBERG: First, as to the conditions, we think your Honor trusted the government, the Bureau of Prisons, to keep our client safe and keep him in civilized conditions. The government will again ask, as to other defendants, that they be detained at the MCC, some subset of them will end up in the SHU unit.

It is a horrific. I've called it medieval. There's vermin on the floor. There is wet from the plumbing. There is no sunlight. There is limited exercise. It is simply conditions that no pretrial detainee -- and I would go farther as a criminal defense lawyer -- no United States defendant should be subjected to.

Certain judges have taken views of the conditions. We would urge your Honor, the government talks about and we talk about transparency, to see what kind of conditions there exist within 50 or 100 yards of one of the great United States district courts.

Second, in terms, we have a profound problem with the conclusions of the medical examiner. There are for three

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reasons, your Honor.

One is the timing of Mr. Epstein's demise. It was on August 10. On August 12, a bail pending appeal motion was being filed in the Second Circuit. On August 12 or 13, the United States Attorneys were going to respond to our request for the preservation and production of documents that would have facilitated and furthered our efforts to demonstrate communications between the Southern District of Florida, the Northern District of Georgia, which was standing in the shoes of the Southern District of Florida main justice and the Southern District.

In other words, we were beginning the process discharging our responsibilities. There had been no new evidence that Mr. Epstein had committed any offense against a minor after 2005. The subject matter of the New York prosecution was squarely within the heartland of the Florida NPA. We had a significant motion to dismiss. This was not a futile, you know, defeatist attitude.

Third, we had all the discovery motions that your Honor had scheduled. So the timing for a pretrial detainee to commit suicide on August 10, when his bail pending appeal motion is being filed on August 12, strikes us as implausible.

Second, we had an independent doctor who was present at the autopsy which occurred on August 11. On August 11, the city medical examiner's findings were inconclusive. We are

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told by a very experienced forensic pathologist that the broken bones in Mr. Epstein's neck, in his larynx, are more consistent 3 with external pressure, with strangulation, with homicide, if you will, than with suicide. It doesn't exclude suicide, but the pure medical forensic evidence creates profound issues about what happened to him.

Also the time of death. Our medical examiner's opinion is it occurred at least 45 minutes and probably hours before 6:30 a.m. on August 10, when he was first found, if you will, according to the reports. Yet he was moved, something that is not ordinary in these circumstances.

I would also --

THE COURT: Excuse me. He was moved?

MR. WEINBERG: Instead of having the cell in the condition it was found, if he had been dead for 45 minutes or two hours or four hours, there were efforts to move him and, therefore, make it more difficult to reconstruct whether or not he died of suicide or some other cause.

I spoke to Stacey Richmond, who is a responsible member of this court who represents the family of Mr. Epstein. She spoke to the medical examiner on the Friday after Mr. Epstein's death and asked why, if the conclusion was made late in the afternoon on Friday that week. She specifically asked about what extrinsic nonmedical evidence caused the medical examiner to go from uncertain to suicide, and she was

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told that the medical examiner had seen nine minutes of one video which was on a stairwell between floors at the MCC. She was told that the principal video that would have showed the whole hall was corrupted. It was in DC with the FBI to see if they can reconstruct it.

And I asked the same questions that my co-counsel did, you know, was the dysfunction of the critical pivotal video, in the most secure prison east of Florence, out in Colorado known to the MCC before August 10, or was this corruption occurring on August 10, which would again cause us to be skeptical of the servitude of the medical examiner's conclusions that this was suicide rather than some other cause.

So with my co-counsel, we ask your Honor, it is not a question of trust or not trust. They ask you to detain people and you trust the Bureau of Prisons. And it is within your inherit authority, your Honor, to find out what happened to our client.

We are angry about the conditions he was held in. And we're also angry, quite frankly, your Honor, that the only 20 source of information that we get as to what happened to him is through the media rather than through the United States Attorney's office. We've made requests informal. We have made Touhy requests. We've been told there is a pending investigation.

But we trust your Honor and the judiciary, and with

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all due respect, we believe there is an inherent and central role, a pivotal role in your Honor to find out what happened to a defendant in a case before the court, whether or not the court grants the nolle pros today or whether it holds it pending an investigation into Mr. Epstein's death.

We're not here without significant doubts regarding the conclusion of suicide. We are not here to say what happened. We don't know what happened. But we deeply want to know what happened to our client.

Thank you, sir.

THE COURT: And you, as Mr. Weingarten, have the same view of the nolle prosequi motion?

MR. WEINBERG: Yes, your Honor.

THE COURT: OK.

points?

MS. : Your Honor, may I respond to some of those

THE COURT: Sure.

MS. : Thank you, your Honor.

Just briefly. With the exception of the noting that 20 the defense does not have an objection to the government's motion, virtually everything else that defense counsel just argued, respectfully is completely irrelevant to the purposes of today's proceeding and to the motion that is pending before your Honor.

As an initial matter, the question

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THE COURT: Well, it may be. Well, I don't know. Yo. say irrelevant.

It is a public hearing, and I think it is fair game for defense counsel to raise its concerns.

MS. : Certainly, your Honor. But it is irrelevant to whether or not the motion should be granted. THE COURT: Right. I get that.

MS. : I would also note that the question of Mr. Epstein's death is the subject of an ongoing and active investigation, as has been publicly noted, by a separate team of Assistant United States Attorneys from the Southern District of New York, separate from the team who is handling this prosecution, as well as a separate team of FBI agents.

There is an ongoing and active grand jury investigation into the circumstances surrounding Mr. Epstein's death. It is the function of a grand jury and of the Federal Bureau of Investigation to investigate crimes in the federal court system. It is not the purview, respectfully, of the court to conduct an investigation into uncharged matters.

So respectfully, we disagree with defense counsel's suggestion that the court has some authority to conduct an independent investigation. To the extent any other defendants who are detained in the MCC have concerns about the conditions or believe that the conditions are relevant to a future or current bail determination, it is for those defendants and

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their counsel to raise those arguments and for the judges hearing those arguments to evaluate those claims. It is not relevant to today's proceedings.

Thank you, your Honor.

THE COURT: In those other cases, Ms. , judges do have authority to investigate, but don't here? MS. : Not to investigate, your Honor, but to hear arguments about the conditions of confinement in the MCC as they may relate to any bail determination. I believe that was the argument that was made.

The bigger picture here, your Honor, is that the focus of today's proceeding, as we understand it, is to allow the victims who have gathered here today to be heard and to comment upon the case and to comment upon the motion that is pending, and to bring this case to a close.

THE COURT: Got it.

MR. WEINGARTEN: May I?

THE COURT: Sure.

MR. WEINGARTEN: We obviously saw this as, perhaps, 20 the last opportunity to be before you, and we wanted to take advantage of the opportunity to say our peace and thank you for allowing us.

There is precedent here. Ted Stevens, the Senator from Alaska case in Washington, DC, Judge Emmet Sullivan ordered an independent investigation by a private lawyer when

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he was deeply troubled by the alleged Brady violations. I represented the prosecutors in that case, so I'm very, very familiar with it.

It is analogous. It is a situation where there was tremendous controversy over what happened in the case and whether or not the prosecutors went off the reservation. Judge Sullivan -- and there were three or four independent -- not independent, DOJ inquiries into the very same matter. But Judge Sullivan wanted his own opportunity to make a judgment with his own independent investigation.

THE COURT: OK.

MR. WEINBERG: If I could just add one precedent, your Honor.

The Chief judge in the District of Massachusetts or the Chief Judge at the time, Judge Wolf, in a case called U.S. v. Fleming, when the conditions at Walpole, which is a state prison where federal prisoners were being held -- we don't have a federal MCC in Boston went to the prison, stayed in the prison to determine whether or not the complaints about the conditions were authentic.

I think your Honor has the inherent authority to go to the ninth floor and see how the MCC houses pretrial detainees. Thank you.

THE COURT: Are you saying that whether or not the motion is granted that is pending before us?

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MR. WEINBERG: Yes, your Honor.

I think, like when appeals are taken, bail issues remain before the district court. Jurisdiction is not completely divested. Your Honor issued a pretrial detention order and your Honor has the power, the inherent authority, they are not going to refuse to allow you to go look at the ninth floor. They are going to count on you to make decisions in the future.

I just trust that the executive branch is not going to prevent the judicial branch from looking into the death of Jeffrey Epstein or the conditions in the SHU unit at the MCC, sir.

THE COURT: Great. Thank you. MS. : May I, your Honor? Just very briefly, your Honor. I would note that upon the dismissal of the indictment, which I believe the parties agree is appropriate in this case, there would be no case. There would be no jurisdiction for the court to conduct any sort of inquiry, even if the court had such authority.

THE COURT: Right.

OK. I think we've heard enough.

It is at this point in the hearing that I would like to call upon victims' counsel, plural, for any remarks they may have and they may wish to make. Also, to introduce their clients, those of them who wish to be heard.

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It would be helpful if, in doing that, if counsel - Mr. Edwards and I see and I see Mr. Boise as well -- I know they are counsel to several, at least several of the victims. It would be helpful if whoever is speaking, both Mr. Edwards and Mr. Boise, would indicate to the court whether or not they have discussed the pending motion with their clients, that is to say and the rule of abatement, etc., etc. with them prior to today's hearing.

Are we going to hear from Mr. Edwards first, is that right?

MR. EDWARDS: Thank you, your Honor.

THE COURT: You bet.

It would be helpful, Mr. Edwards, if you would state and spell your name for the court reporter.

If you are going to introduce someone else, which I trust that you are, if you could state and spell their name as well.

MR. EDWARDS: Yes, your Honor.

May it please the court. Brad Edwards, B-r-a-d

E-d-w-a-r-d-s, with the law firm of Edwards Pottinger.

I have in the courtroom today 15 victims that I represent and have represented over the years. There are at least 20 more who didn't make this hearing today for a multitude of reasons, some out of fear of public exposure, others because the way in which this case ended will never

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1 bring full justice, and they decided it was best for them not to talk today.

Some of my clients are going to address the court that are here today. Others are not. Some are going to use their names, and have in the past, and others wish to remain anonymous. And I have instructed each of them to inform the court reporter that they will be proceeding as Jane Doe so that the court reporter can take them down.

THE COURT: For those who wish to remain anonymous? MR. EDWARDS: Exactly, your Honor.

THE COURT: And that is satisfactory, as far as I am concerned.

MR. EDWARDS: Before we do that, I would like to address a couple of the things that have occurred this morning.

First of all, whether relevant or not, I personally, and on behalf of my clients, do appreciate the presentation that Mr. Weingarten made and Mr. Marty Weinberg made.

I have tremendous respect for Mr. Weinberg. I've worked with him through this and related cases for years, and I understand the reason why they made the presentation that they made.

There is two things of interest to our clients in that respect. One is, because of the tragic ending, that none of my 24 clients wanted, nor did I, nor did anyone else, if there is some civil rights violation and there is some civil remedy for

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Mr. Epstein that goes to the estate, certainly the victims are interested in that as they might help to repair the damage done.

Second, Mr. Epstein's untimely death, the timing is curious to us. But more so, it makes it absolutely impossible for the victims to ever get the day in court that they wanted in court and to get full justice. That now can never happen. I know that Mr. Epstein's attorneys say he wanted it, and they know, we did too. And there are a lot of people here today that are very sad by the way that this ended for both Mr. Epstein and the fact that full justice was robbed from them, once again.

The second issue I wanted to address was the Law Review or the Law Journal article that your Honor referenced, which is troubling because the opinion seems to say that transparency is not appropriate in the criminal system and is not appropriate at this point in time.

That's tough to swallow, especially in this case, given the long history of this case. Personally, it is tough to swallow, and on behalf of my clients, I can say that is very concerning. Transparency is the only way that the justice system works. We know this because there was a similar investigation of Mr. Epstein many years ago, from 2005 to 2008.

My personal involvement in this case was because a young female came into my office named and she

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came to me not asking to file a lawsuit against Jeffrey Epstein, but simply asking for the government to talk to her. She was cooperating in an FBI investigation and wanted the government to speak with her, and I thought that was going to be an easy task.

It was only a few months later that we learned that this investigation that was represented to my client in written form, that it would be a long investigation, and to be patient. Basically, to hang tight. It was resolved by way of a secret deal that never allowed any of the more than 30 victims who had been identified of Mr. Epstein's abuse in Florida to ever participate in a single hearing. There was a hearing. They were never notified.

I then went on to represent many of them in civil cases and also in extensive pro bono work. And I can tell your Honor that while Jeffrey Epstein's abuse of them hurt them and harmed them for many years, the feelings they had was aggravated exponentially by the facts that they had no rights in the criminal justice system, by the fact that they were treated as if they didn't matter. They were not allowed their rights under the Crime Victims' Rights Act to meaningfully confer with prosecutors, to be treated with fairness, to be treated with dignity. That is what this is supposed to be about, and to have notice of hearings.

So I do want to thank your Honor, and especially the

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prosecutors who have worked this investigation and this case, 2 which is very different in experience for all of my clients and the other Epstein victims in this case, because they were allowed to be a part of the process. While some of them elected not to be here today, that opportunity should always be allowed for them.

In 2008, we filed that case under the Crime Victims' Rights Act because our clients' rights were violated, and as your Honor knows, a federal judge has ruled in our clients' favor that their rights were violated. So this hearing today means a lot to them. The fact that they may never get their chance to speak in court, they may never get complete closure, and all of us have to wonder, if their rights had been afforded them the first time, would any of us be here right now. Or wouldn't it more likely be the case that everyone, including Jeffrey Epstein, would have turned out better for it?

Today, I have not only represented, but met and become very close with many of these victims. Many of these survivors. They are very strong people. They are people who 20 have persevered through a lot of adversity. It's been a roller coaster of emotions that has led us to where we are today. And while they have all been cast over the years because of the secrecy of the first investigation, in the shadow as victims, you can't put them all in one bucket and say one size fits all. They are each individual people who were harmed differently and

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distinctly through not only the abuse, but the system.

And on behalf of all of them, I would like to thank your Honor for the fairness with which they've been treated, and the United States Attorney's office for the way in which you have handled this investigation, and especially how you have treated the victims in this case.

Like I said, I have many who want to speak. Some that can't. This is a very difficult day for them. But we appreciate the opportunity and the invitation.

The first client that I have that is going to address your Honor is the one who walked into my office in 2008 asking just to be heard,

THE COURT: Hold on one second. Did you all want to be seated?

You don't need to be standing. Whatever is more comfortable until you're ready to give some comments. It's up to you.

, if you could spell your name for the court reporters, please.

last

name

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My name is and I'm a victim

of Jeffrey Epstein. Jeffrey Epstein sexually abused me for years, robbing me of my innocence and mental health. Jeffrey Epstein has done nothing but manipulate our justice system, where he has never been held accountable for his actions, even to this day.

Jeffrey Epstein robbed myself and all the other victims of our day in court to confront him one by one, and for that he is a coward.

I want to thank the U.S. Attorney's for seeking justice that has been long over due, and most importantly, given us, the victims, our day in court to speak our peace and find some sort of closure. I feel very angry and sad that justice has never been served in this case. Thank you.

THE COURT: Thanks very much.

MR. EDWARDS: I believe my next client who is going to speak is probably going to speak as Jane Doe.

JANE DOE NO. 1: Yes, Jane Doe.

THE COURT: We'll say Jane Doe No. 1, just for the record.

JANE DOE NO. 1: Okay. Thank you for allowing us to speak today. I've shifted what I want to say in hearing what's already been said, and just about the question of Jeffrey's death. I don't know what the relevance is to this 25 hearing, but I do know that it is profoundly relevant to my

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life, as a victim. I don't like that word, but I still feel like I am learning the ways that he's impacted me as a complex situation, but he was also a major part of my life. As destructive as that relationship was and as much of a villain as we have created him to be -- based on facts we've created him to be a villain -- he's a complex villain and actually all of that is irrelevant. Anybody deserves -- an investigation is the right thing to do. Like, we do need to know how he died.

It felt like a whole new trauma all over again, and I don't know why, you know, because I I'm trying to defend myself against him at this point in my life, but it still does not feel good. It didn't feel good to wake up that morning and find out that he had allegedly committed suicide. Okay. But I also wanted to say to the press, I'm reading -- I read my story in the paper. I read so many other girls' stories that are so similar to my own, and everything that's been focused on is not the most important part of it.

There was -- the problem with focusing on these, the facts of the situation, that were out of the ordinary and like because he was such a grand person, and it was just a unique situation. I know that that's the more interesting side of the story, but I don't want to be used as entertainment. And the 23 problem, the fundamental problem of the whole situation is the element of exploitation and coercion, and these are things that so many girls can relate to.

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And even though this Jeffrey Epstein brought it to a grand scale, on some level, a lot of girls could relate to the trauma that we are talking about, and even though this whole situation sucks, I would like to think that it may be possibly a catalyst for change because, obviously, as we're seeing with the "Me Too" movement, change needs to happen and it's -- what I'm seeing in the papers is not a common story, but it's so much more common than you realize. That's all. Thank you.

THE COURT: Thank you very much.

MR. EDWARDS: I believe that the next client is going to also be a Jane Doe; so I think for the purposes of the record it will be Jane Doe 2.

THE COURT: Yes.

JANE DOE NO. 2: Good morning, your Honor.

THE COURT: Good morning. How are you?

JANE DOE NO. 2: Doing okay. I hadn't prepared any words to speak today, but there is something that was on my mind this morning when I got here. It's been on my mind in reading through the press and through the people that I've spoken to about it, friends, family. It's something that's bothered me because I think it has a lot of blame in it, as well, a little bit of what my friend, who was up here, was speaking about.

I think that a lot of people asked why we spent so much time, why we stayed. It's an experience that's really

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hard to explain to people who haven't gone through it. I think there's a writer, Thomas Nagel, who wrote an essay called "What is it like to be a bat?" And I think that he touches on it pretty strongly and if you haven't experienced something, it's very hard to fully understand why someone makes the decisions they do and what the circumstances were.

I don't want to speak for all of the victims. I think each of us has a different story and different circumstances for why we stayed in it, but for me, I think he was really strategic in how he approached each of us. Things happened slowly over time. We didn't -- it almost was like, putting it like that analogy of a frog being in a pan of water and slowly turning the flame up. You didn't realize it was happening, and it just -- I don't think anyone can fully understand the experience, but I just -- the blame feels very strong.

There's a lot of support as well, but i just want people to try and understand that we aren't bad people. We weren't trying to -- it wasn't a situation where we were trying to extort money from someone. A lot of us were in very vulnerable situations and in extreme poverty, circumstances where we didn't have anyone on our side, to speak on our behalf, and that's really scary.

You start to blame yourself because, at first, you 24 don't tell anyone what's happening, and it becomes your deep, dark secret that you tried to keep from everyone. And I didn't

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even know I was a victim until I spoke with my lawyers. I had no idea. I had so much self-hatred and doubt and just guilt for everything. I still do. I still don't feel like I deserve to say I'm a victim, and I think that's a big problem with our society right now, that people are still blaming victims, and I think that does need to change.

I hope that today people understand that each of us has a story, has a past, has a family and just give us a chance to you know, that's basically all I just wanted to say.

THE COURT: Thank you so much.

JANE DOE NO. 2: Thank you so much.

THE COURT: Okay.

MR. EDWARDS: Okay. I think that the next person who is going to speak is also going to be speaking as Jane Doe; so for the purpose of the record, Jane Doe No. 3.

JANE DOE NO. 3: Thank you for allowing us to speak today. I came to New York City 15 years ago to pursue modeling from a small town. I signed on with an agency and was excited to pursue my passion and my dream. Several months later, I met a female who told me about Mr. Epstein. She portrayed him as an amazing man who genuinely cared for people and that he was going to be able to help me in a modeling career.

I was excited to meet him, after hearing her talk about him. He sounded like an amazing person. An introduction was made at his New York home, and it is there that I was

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sexually assaulted. I left his home, after he threw me, basically put money on the table, and I was ashamed. I was embarrassed. This was not the way I was brought up, and I couldn't believe this had happened to me.

I left and my world kind of spiraled after that. I stopped going on modeling castings. I gained weight. I became depressed. I stopped going out with my friends, and only five months after I had been in New York City to pursue my dream, left. I left the modeling industry, and I left New York City, and I totally switched my career paths.

I buried this deep within me, and all of the new occurrences that have come up in the media is what brought it back up for me. And I feel sickened and saddened that it took so many years, and God knows how many victims, for this to finally come out, but I'm thankful it did. And I'm just angry that he's not alive anymore to have to pay the price for his actions. So I thank you for your time.

THE COURT: You're very welcome.

MR. EDWARDS: Your Honor, Jane Doe No. 4, I believe, is going to speak now.

JANE DOE NO. 4: Good morning, your Honor. THE COURT: Good morning.

JANE DOE NO. 4: I just have something very short to say. I met Jeffrey Epstein at a very vulnerable place in my life, and whatever the outcome is with everything, I just

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wanted to express that we, the victims, we will always carry irreparable damage and pain throughout our lives after this. It's something that's never going to go away.

You know, whoever we marry in our life, whatever future we have in our life, it's always going to be something that's always there for us. And I'm very nervous right now. And Jeffrey Epstein, he took away the chance I had at having the future I had envisioned for myself as a young girl, and I think many of us here today will never fully heal from that pain and the heartache that we'll continue carrying with us.

So I just wanted to say that. It's something that it's irreparable. I can't even really use a better word to describe that. So thank you for hearing us today.

THE COURT: You're very welcome.

MR. EDWARDS: Your Honor, Jane Doe No. 5 would like to speak.

JANE DOE NO. 5: This is a letter that I wrote%;B so it's going to be: Dear Jeffrey, I think you are a mentally disturbed human being. You used your power to make me believe 20 at a young age that I could have my dreams of being a model. You paid for your freedom. You violated my rights. You should have to pay for them, just as anyone else. You got a plea deal that no one else would have been able to get. You used your money to get out of paying the price for your actions.

Also, as a victim, I never got to see what the

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agreement was or why the special treatment got approved. think you should have been in jail for several years in population and live like everyone else that is mentally disturbed like you. You paid for yourself to get special treatment while you were in jail. I don't even think you spent a day in a jail as a normal human being.

You had investigators come to my house and also went to my friend's house to question them. I will never be able to over -- I will never be able to get over the overwhelming emotions and embarrassment I experienced from that trauma. I needed therapy several times a week and had high stress and anxiety levels.

You paid your way to make the public think that the girls had nothing in life going on for them. You wanted to try and blame that we were lower class and that was the problem with the girls. I was from a middle class family and did well in school. I lived the American girl dream -- or the American girl life. I went on family vacations around the world, grew up in a good city, and my parents are still married to this day. Basically, everything you said that we didn't have in our life, I did.

It all came down to I was told I was making $200 in an hour. Being young, that was a lot of money, and I didn't know any better. Sadly, you were the one with an illness that you should have to go and see a doctor and also have a mentor group

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for the sickness you have. I will continue with writing my book about that secret life, with all the newspaper articles of the case, my high school agenda book of official dates. I'm basing that proof that I deposited cash after leaving Jeffrey's. I still have all of the information, articles that I collected over the years.

You mentally and physically traumatized me. I went to therapy, and it was the best thing I did for myself. If anyone only learns one thing from this case, I hope is that money should not let you buy your way free. A crime is a crime and a victim is a victim. Thank you.

THE COURT: Thank you. Thank you very much. MR. EDWARDS: Your Honor, my next client is

I met Jeffrey Epstein through my first massage teacher, a man who took me in as his apprentice to teach me a practice I wanted to learn while in desperate search to find a cure for a debilitating neurological disorder that have, which manifests into violent vomiting attacks, largely triggered by stress. It's called Cyclic Vomiting Syndrome.

I was recruited by Ghislaine Maxwell. Upon my first meeting of her, I wouldn't know I had been recruited until many years later, when I would read it in a headline. Ghislaine and 24 Jeffrey took me in. They sent me to school. They gave me a job. They flew me around the world, introduced me to a world I

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had only dreamt of and made me feel as though I had become a part of their family, another thing I was desperately searching for.

But on my third or fourth time meeting them, they brought me to Jeffrey's island for the first time, and on the first night there, came tapping on my door late at night to inform me Jeffrey was ready for another massage. My instincts told me this didn't feel right, but I got up and followed her to a villa I hadn't yet seen. Jeffrey and Ghislaine's villa.

I began my massage, trying not to let him smell my fear and obvious discomfort, but before I knew what was happening, he grabbed onto my wrist and tugged me towards the

I spent two weeks vomiting, almost to death, in a Los Angeles hospital after that first encounter. Jeffrey's abuse would continue for the next three years, and I allowed it

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to continue because I had been taken advantage of my entire life and had been conditioned to just accept it.

It took me a long time to come forward, too long maybe, and all it took to bring -- and all that it took to bring this man to justice has been robbed by his death. Every day, every week I've spent in the hospital since, I've suffered and he has won. Every job offer that's been offered to me and then retracted because of my connection to this case, I have suffered and he has won. Every public humiliation I have endured, I have suffered and he has won. Every relationship that I've had to end because of the abuse that I have endured by the hands of this man, I have suffered and he has won.

Every woman sitting in this room today, and all of the women who have yet come forward and who have not yet to come forward and whose lives have been affected by Jeffrey Epstein's sick abuse of young girls, we have all suffered, and he is still winning in death.

I refuse to let this man win in death. I couldn't fight back when Jeffrey Epstein sexually abused me because I hadn't yet found my voice. Well, I have found my voice now, and while Jeffrey may no longer be here to hear it, I will not stop fighting, and I will not be silenced anymore. I needed him to hear the pain he's caused, what I've gone through because of him. I wrote a 350-page book of all the pain that I have endured at the hands of this man that I really needed him

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to hear. His death has robbed me of that justice. Please don't rob us of justice again. Thank you. THE COURT: Thank you.

MR. EDWARDS: Your Honor, I think I have one more client that is going to speak today, THE COURT: Would you spell that?

Good morning, your Honor.

THE COURT: Good morning.

My name is spelled

Thank you, your Honor, for giving us the opportunity to be heard this morning.

THE COURT: Sure.

When I was introduced to Jeffrey Epstein, I was young and full of hope and the foolishness of teenager. I was idealistic, and I saw the good in people. Jeffrey Epstein manipulated me, coerced me and sexually abused me.

Something I think is very important to communicate is that loss of innocence, trust and joy is not recoverable. The abuse, spanning several years, was devaluing beyond measure and affected my ability to form and maintain healthy relationships, both in my work and my personal life. He could not begin to 24 fathom what he took from us, and I say "us" because I am every girl he did this to, and they're all me. And today we stand

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together, those that are present and those that aren't.

I was a victim, and it has taken me many, many years to stand here and say, yes, it was me. I was a victim, but 1 will not remain a victim and be silent for one more day. Although I think it's tragic when anybody dies before their time, I'm extremely relieved that Jeffrey Epstein will not be in a position to hurt anymore children or anymore women, and I'm glad to be part of a group of women who are now bonded forever in the trauma that we endured at the hands of this man. Thank you.

THE COURT: Thank you. MR. EDWARDS: Your Honor, we had one client who was not able to be here but sent a message through a letter. Her name is last name, And Brittany Henderson, of my office, is going to read her letter as instructed.

THE COURT: Sure.

MS. HENDERSON: Thank you, your Honor.

THE COURT: Yup.

MS. HENDERSON: What happened to me occurred many years ago when I was in high school, but it still effects my life. I was told then that Jeffrey Epstein was going to be held accountable, but he was not. In fact, the government worked out a secret deal and didn't tell me about it. The case ended without me knowing what was going on, without him being

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held responsible, without any explanation and without a chance for my voice to be heard. I was treated like I did not matter.

Many years later, he was arrested again. These investigators and attorneys representing the United States have been completely different. I am still mad, concerned and confused about how he committed suicide and escaped responsibility again, but I know it is not the fault of the judge or the government attorneys.

I was allowed to be a part of the process this time. My attorney was able to tell me what was going on at every stage because they kept him informed. Thank you for inviting me. It means more to me than you can ever know. I was not able to be here this time, but I know that I was allowed to be and I had the chance to attend this hearing, which is helping me in my healing process. The fact that I mattered this time and the other victims mattered is what counts. For that, I am grateful.

THE COURT: Thank you.

MR. EDWARDS: Your Honor, finally, in 2008 when I filed the case under the Crime Victims Rights Act, it wasn't me alone. I did it with Paul Cassell and Jay Howell.

Paul Cassell is here today, and I think your Honor even cited to a piece of -- an opinion of his from when he was on the bench, and he has some remarks to make.

Once again, your Honor, I really do believe that this

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is a model for how victims should be treated in a criminal process, and we really do appreciate it. Thank you.

THE COURT: Thank you.

MR. CASSELL: I'll be very brief because I know there are others that want to speak here. I'm Paul Cassell, C-a-s-s-e-1-1, previously served as a federal judge at the District of Utah, currently a law professor, where I teach crime victims rights at the University of Utah, College of Law.

I just wanted to take one minute to address some suggestion that there would be no need for a hearing this morning. I think, having heard already from these powerful victims and recognizing how important giving those statements will be in the trajectory of their lives, makes clear that your Honor has followed exactly the right path. Legally, there is one precedent, which is U.S. v. Heaton, a case that you cited that I wrote about a decade ago, and as explained in that opinion, victims have important interests in the criminal justice system that can only be recognized if they're given their day in court.

With all due respect to other law professors that have recently written an article, I think transparency is one of the overriding objectives in our criminal justice system, and the one substantive action that I would urge your Honor to take today is to publish your remarks as a published opinion. The Heaton case is, to my knowledge, the only reported decision on

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this particular issue, even though it's more than a decade old and, yet, we can see today that these problems recur in many other cases. Your remarks today, I think, should be published so that they can serve as a guide for other judges around the country.

I would encourage you to add into your remarks a reference to the Crime Victims Rights Act. The Crime Victims Right Act promises victims the right to be treated with fairness, dignity and respect, and the process that we see unfolding this morning is a clear example of how victims can be treated with fairness, dignity and respect.

So I know that your Honor is wondering what is the appropriate action here. Unfortunately, it seems like there are no other legal options, but there was a legal option for you to decide to exercise, which was to allow these victims to come forward. And if there's been one positive thing that has come out of the tragedies, the abuse, the other events of this case, it's been your decision to allow these victims to be heard this morning, and I encourage you to publish your decision and to encourage other judges to follow what is clearly a model for crime victims rights and is clearly an example that should be followed in other cases down the road.

THE COURT: Thank you very much. I appreciate your being here. I had no idea that you would be here when I wrote the remarks, but it was clear from the literature that you are

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the leading expert formerly of the District Court of Utah, I believe, and it's a pleasure to have you here today.

MR. CASSELL: Thank you, your Honor.

THE COURT: Thanks.

Mr. Boies?

MR. BOIES: Thank you, your Honor. David Boies of Boies Schiller Flexner. We have with us today five of the victims that we represent. There are a number of additional victims who either were unable to attend or are still unwilling to come forward publicly. This has been an enormously traumatic aspect of their lives, something that, as you've already heard and will hear more today, is something that they can never entirely escape from.

I want to, as prior counsel have, commend both the Court and counsel for the Department of Justice for the consideration and respect and attention that they have paid to the victims. We believe that that is not only right, as a matter of human dignity, but we think that is exactly what the law requires and intends.

I will be more blunt than the Court has been, or Professor Cassell has been about Professor Green's article. That is an article that cites no authority, and I believe there is no authority for his proposition. I entirely respect his right to advocate on behalf of his client Alan Dershowitz, who has retained him in connection with litigation that we've

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brought against Mr. Dershowitz, but I would have expected that the Law Journal or Professor Green himself would have disclosed that connection, which I think is a conflict.

But regardless of the appropriateness of his disclosure, or lack of disclosure, I think that his article opposing allowing the victims to have a voice in this 7 proceeding is inconsistent not only with the policy that underlies the Crime Victim Rights Act and the very statute that Mr. Epstein is being prosecuted under, but it ignores the actual language of those statutes, and many other statutes, in which Congress has made clear that the purpose of the criminal law is no longer simply to punish the individual defendant, but it is to find some way of trying to mitigate the damage that has been done to the victims through restitution and economic mitigation, but also through the ability to confront and to have the court system and the justice system and the prosecutors treat these victims as they are victims, as they are human beings, and they are entitled to the respect that our society needs to give every human being. So I think that this is not only commendable, but I think it is what the law requires.

In response to the question the Court asked, I have discussed this hearing with my clients. I have told them that, 24 under the applicable law, the government has no alternative but to move to dismiss this case, and I believe under the

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applicable law in this circuit, the Court has no alternative but to grant that motion.

I think the current law is outdated, as the Court suggested in some of its remarks. I think there will come a time when either an Appellate court or the Congress will make clear that, just as it's possible to continue civil cases against someone after they have deceased, it is possible, at least for purposes of things like restitution, to continue criminal cases, but we are not there now. And, fortunately, in this case, there are other ways and perhaps even more efficient ways to vindicate the interests of the victims here.

We greatly appreciate the remarks of the representative of the Department of Justice today, and we, too, on behalf of the victims, are not going to stop when we walk out of this courtroom. We are going to continue to seek vindication against Mr. Epstein's estate and, in some senses, perhaps even more important, against the people who worked with him and enabled him.

As you have already heard, and will hear more, Mr. Epstein did not act alone. He could not have done what he did, on the scope and the scale of what he did, for as many years as he did it without the activities and support and the co-conspirator activity of a number of other key individuals, and those individuals also need to bear their share of responsibility, and those people need to have a reckoning as

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My partner Sig McCawley, who's been working with me for more than five years on this case, is going to, with the Court's permission, introduce five of our clients who will speak briefly to your Court. Thank you very much.

THE COURT: Thank you very much, Mr. Boies. Pleasure to have you here.

MS. McCAWLEY: Thank you, your Honor, the first victim that would like to speak today is

THE COURT: Can we have the spelling of your name? MS. McCAWLEY: Sure. Sigrid, S-i-g-r-i-d, and the last name is M-c-C-a-w-1-e-y, and I'm a partner at Boies Schiller Flexner.

THE COURT: Thank you.

Good morning.

THE COURT: Good morning.

Thank you, prosecutors and Judge, and the Court. My name is I note today I do feel respected and listened to; so I appreciate that, and I have to say that I commend the boldness of the New York prosecutors for pursuing a man that has, you know -- and others, that have clearly taken a lot from a lot of people.

17 years ago I knew him only as "Jeffrey." I was 25 recruited and brought from California to New York, and that

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experience for the last 17 years has been a dark corner in my story, in my life, in my life story and that has been definitely made worse by my own self-shame and that -- and anger for normalizing all of the red flags. I feel like we are conditioned to do that, and that's something that needs to change.

So I'm here today, you know, I'm coming forward because it is time to bring light to that darkness, and it's time to replace that darkness with light. And I am a survivor of this, and I do aim to progress further from being a survivor, you know. I feel I've worked hard, quite hard, to get to where I'm at now, and I'm definitely at a place in my life where I will no longer cover up. I'll no longer cover up what needs to be brought to light.

Jeffrey is no longer here, and the women that helped him are, Ghislaine Maxwell. My experience is with Ghislaine Maxwell and and they definitely need to be held accountable for helping him, helping themselves, helping one another carry on this huge, almost like a system. So they need to be held accountable, all of them, and I would like to see that, certainly on behalf of myself and for everyone here. Thank you.

THE COURT: Thanks so much. MS. McCAWLEY: Our next client, who is going to speak this morning, is

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Good morning, your Honor. Good morning. How are you? Okay. Thank you. My name is

THE COURT:

I am a victim of Jeffrey Epstein and Ghislaine Maxwell in the dark and cruel and criminal acts they committed against me and hundreds of other girls and young women for years and years and years, unstopped.

Thank you for allowing me to address the Court and speak the truth. I commend the prosecutors from the Southern District of New York for the ongoing investigation and its pursuit of justice for us victims. It has given me hope, and I will not let go of that hope.

When I was recruited by Ghislaine Maxwell at Mar-a-Lago, just before I was 17, I thought I was given a big break, and I'd be able to reset my life and become an actual real massage therapist. My hopes were quickly dashed, and my dreams were stolen. Jeffrey Epstein is no longer alive, but this is not about how he died. This is about how he lived.

He will not have his day in court, but the reckoning of accountability has begun, supported by the voices of these brave and beautiful women in this courtroom today. The reckoning must not end. It must continue. He did not act alone and we, the victims, know that. We trust the government

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is listening and that the others will be brought to justice. Thank you, your Honor.

THE COURT: Thank you very much.

MS. McCAWLEY: The next client of ours that will be speaking this morning is

Thank you, your Honor. My name is I'm a victim of Jeffrey Epstein and Ghislaine Maxwell's international sex trafficking ring.

I would like to thank the Court for the dignity and the respect you are showing me here today, as well as the other victims. I would also like to acknowledge and extend my gratitude to the prosecutors from the Southern District of New York for pursuing justice on behalf of the victims. Please, please finish what you have started. I struggled to find the words to adequately say how important your work is to us.

For a very long time Jeffrey Epstein gamed the system at every level, and when he realized he couldn't do that any longer, he showed the world what a depraved and cowardly human being he is by taking his own life. But we, the victims, are still here, prepared to tell the truth, and we all know he did not act alone. We are survivors, and the pursuit of justice should not abate. Thank you, your Honor.

THE COURT: You're very welcome.

MS. McCAWLEY: Our next client who is going to be

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speaking this morning is

Good morning, your Honor.

THE COURT: Good morning.

I had the opportunity to speak at Jeffrey Epstein's bail hearing, and I really appreciate that you heard me and listened to me that day. I am so sorry that others will not have the opportunity to stand before him the way that I did. But I'm here today to speak on behalf of my sister, who could not be here.

Jeffrey Epstein, Ghislaine Maxwell not only assaulted her, but as we're hearing from so many of these brave women here today, they stole her dreams and her livelihood. She risked her safety in 1996, so many years ago, to report them, to no avail, and it is heartbreaking to her and to me that all this destruction has been wrought since that time.

We were deeply disappointed and disturbed by Epstein's death and the fact that that was allowed to happen while he was in the government's custody, and I'm encouraged to hear that there will be a full investigation as to how that was allowed to happen.

But it is extremely important, as others are saying, that he did not act alone and that the other people that were a 24 part of what he did are held accountable and that that investigation continues.

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I believe that we have a real problem in this country with perpetrators of sexual abuse and sexual assault being held accountable. There are so many roadblocks to victims being heard, to cases being investigated thoroughly, and then to those cases being prosecuted. And so I think this is a really important signal to send a message to victims out there that people will take you seriously, people will follow through, and that even those in power, as we have unfortunately seen, that has not been often are able to escape that, that even those in power will be held accountable. Thank you.

THE COURT: Thanks so much.

MS. McCAWLEY: Our next client, who's going to address the Court is She says it much more beautifully than I do; so I'll let her say it.

My first name is spelled,

; last name is

My name is and I am a victim of

Jeffrey Epstein and the sophisticated sex trafficking operation he ran, where he allegedly was to be a financier.

I was 20 and previously modeled and was living in the West Village. I met a young woman named through a mutual friend. We were friends for a few months. She was an amazing artist and liked to party. One day she called me and asked if I was interested in meeting a friend of hers. She told me he wanted to meet me and really liked blonds, and I thought he was

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our age and liked to do the same things we did at that age; so I agreed.

On a sunny, crisp day, we took the train together to

the Upper East Side. She then began to talk a little bit about

him on our way to his house. I was at his house. I was

sexually assaulted by both and Jeffrey Epstein in his [ ]
mansion. It left me feeling both disgusted and betrayed.

As we walked home to the subway afterwards, she continued to tell me about the man who had just abused me with her participation. She seemed exhilarated from the horrific experience. I was shocked and in a daze. This is a few things that she had told me. She told me he went to Cooper Union. He was a mathematical genius. That he had favorite girls that he would take to Chanel for 15-minute, all-you-can-buy shopping trips. She told me his right-hand person had connection to the arts and the fashion world, and she could help me.

This is not my complete story. I'll stop here. I'm in a good, stable place in my life, and I had decided to come forward to be a voice to the victims who may not be able to tell their story, or at least not yet. I feel like I am a survivor.

Thank you, Judge Berman, for inviting victims to speak today before you. We hope the government is listening very closely to the words we are saying.

THE COURT: Thank you very much.

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MR. BOIES: Your Honor, just very briefly. THE COURT: Sure.

MR. BOIES: I would like to express to the Court how proud I am of all of these women who have come forward. It's taken an enormous amount of strength and courage for them to do so. Thank you.

THE COURT: Thanks, Mr. Boies. Hold on one second. (Pause)

MS. LERNER: Thank you, your Honor. My name is Kimberly Lerner, of Lerner and Lerner, and your Honor, with your permission, I would like my client, , to stand next to me.

THE COURT: Sure.

MS. LERNER: Would that be okay?

THE COURT: Absolutely.

MS. LERNER: Your Honor, I would like to begin by saying that I am in awe of all of these beautiful women. I just want to let you know, on behalf of and myself, we admire you, we respect you, and we applaud you, and you are brave survivors. And s heart is with all of you, and we thank you so much for coming forward.

when she went public, she thought she was one of the only ones, and to see all of these faces is, I know, amazing for her.

Jeffrey Epstein was a predator, a pedophile and a sick

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individual. However, he was also a thief. He stolen, childhood dreams, her innocence and her self-confidence. She was 14 years old. What he could not buy, he forcibly took. Why? Because he surrounded himself with a network of powerful people who not only looked the other way, but also actively facilitated and participated in his sexual abuse of children.

Jeffrey Epstein thought he was above the law, and essentially he was until now. The system let and the other victims down, but it does not have to end here. We ask the U.S. Attorney's Office and the FBI to bring all of Epstein's enablers and co-conspirators to justice.

It has taken 18 years to find her voice, and again, Jeffrey Epstein has tried to silence her. While she will never have her chance to face him in court, he no longer has any power over her. Today, this brave survivor will be heard.

Thank you for allowing me to be able to have my chance in court today, to be able to tell you what this horrific man did to my life. You can't even imagine how much it affected my childhood, all the way through my adult life. He robbed me of my dreams. He robbed me of my chance to pursue a career I always adored. He stole my chance at really feeling love because I was so scared to trust anyone for so many years that I had such severe anxiety. I didn't want to leave my house let alone my bed.

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The fact that he felt entitled to take away my innocence, the fact that he felt that he could do whatever he wanted, regardless of the laws, hurts me so very much. It took me years to tell anyone what Epstein did to me because I was so ashamed and embarrassed at what people would say or think of me until I found out there were other victims, girls just like me. I knew I could no longer keep my silence no matter how ruthless and powerful Epstein was, and still is even after his death.

The fact I will never have a chance to face my predator in court eats away at my soul. Even in death, Epstein is trying to hurt me. I had hoped to at last get an apology, but this evil man had no remorse or caring for what he did to anyone. I felt let down by the people who were supposed to watch him in prison. They let this man kill himself and kill the chance of justice for so many others in the process, taking away our ability to speak.

Out of all the damages and side effects that Epstein caused by his heartless and selfish acts, it's very hard to put my feelings and emotions into words, trying to let his horrendous actions go and attempting to forgive him, has been so difficult for me. Yet, as hard as it's been to come so publicly forward, I refuse to let Epstein take me as a victim anymore.

I am a survivor. The many that stand before me here today that have shared the horrific experiences with this

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deplorable human being, because even though this weak, evil coward tried to steal all of our childhoods, tried to steal all of our innocence and tried to steal all of our means of justice, he will never steal our inner strength, and he will never, ever, ever steal our voice. Thank you so much.

THE COURT: You're welcome.

MS. GIBBS: Good morning, your Honor. Teri Gibbs, T-e-r-i, G-i-b-b-s. For the record, I am a California attorney. I'm not admitted to the New York State bar. I am here to make a statement on behalf of New York attorney, Lisa Bloom. I work for her firm, The Bloom Firm.

Lisa Bloom represents four of Jeffrey Epstein's victims, Jane Doe 6, for the record, Jane Doe 7 and Jane Doe 8. I am so proud of all of you victims who are here today and are able to voice yourselves today. I will not and cannot comment on the criminal case, or Ms. Bloom's communications with her clients.

Ms. Bloom would like to share three of her client's statements for the record. Here are the statements. Statement of Jane Doe 6.

To the Honorable Richard M. Berman. Jeffrey Epstein stole my innocence. He gave me a life sentence of guilt and shame. I do not consider myself a victim. I see myself a survivor. The abuse that I endured cannot continue. Let's stop this before it happens to other young women. Jane Doe.

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Statement of Jane Doe 7. To the Honorable Richard M. Berman. I used to be relatively carefree, inquisitive, hopeful and excited about life, but my life changed because of Jeffrey Epstein. My perspective on life became very dark when I was unknowingly recruited by one of his agents. Jeffrey Epstein ruined me. His recruiter ruined me. The far-reaching consequences of that day ruined my family's lives.

I've chosen to remain anonymous in order to protect my 9 family from unwanted media attention.

I was just trying to figure out my path in life when I encountered Jeffrey Epstein in his New York City mansion. I cannot even begin to summarize the many detriments this experience of sexual assault has had on my life. Immediately following the incident, I was unable to function and be around other people. My parents had to rescue me and bring me home, where I became a recluse for years.

I was changed forever and buried my assault deep down, where the darkness couldn't hurt me anymore, but of course, it has always been here, lingering and affecting me unconsciously. At the time, I was mired in shame, guilt and humiliation. I had somehow tricked myself into thinking that I had allowed the assault to happen, that I did it to myself, that I don't deserve to be alive or to be loved. I believed that I was a disgusting, shameful person who does not deserve to ever be happy. These are the thoughts I've lived with on a daily

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basis.

Furthermore, because I couldn't tell anyone, out of fear of judgment, blame or retaliation, keeping this secret completely hindered my ability to uncover why these issues existed for me, which could have led to a path of healing over the years.

It is time for those of power to do the right thing. It is time for compassion toward our fellow human beings to reign over money, power and greed. We need to protect our most vulnerable to allow them a chance at a normal life, and nothing should come in the way of that. I believe that for future generations, including my own children, this case will set a precedent that victims must no longer suffer in silence on our own or be shamed for coming forward to seek protection.

This case should demonstrate to those who want to harm others that there will be a reckoning, and they will pay dearly for the harm they inflict on innocent people. Judge Berman, : thank you for from the bottom of my heart for this forum and opportunity.

To all of those survivors who came before me, I commend your bravery. There is no way I could have done this without you.

Thank you to the public following this story, for your 24 outrage and desire for answers, which will hopefully move this case forward so that victims can stop having to relive their

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experiences every day and move on to begin to heal.

God bless the victims, their families, the investigators and public servants working so diligently to find those answers and to right all these wrongs. Jane Doe 7.

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THE COURT: Thanks very much.

MS. GIBBS: One more. Statement of Jane Doe 8.

In the past few weeks, i have had to reflect on my interaction with Jeffrey Epstein and realized that, though I have yet to put it all behind me, I am still a victim. I say this because I have to come to terms with it in an effort to truly get past the abuse I suffered at the hands of Epstein.

Pursuing criminal penalties against him and having an opportunity to address the egregious crimes he committed against me and other young woman would have helped my recovery process. This all came to an abrupt halt when he took his own life. This point of disclosure is lost.

I cannot say that I am pleased he committed suicide, but I am at peace knowing he will not be able to hurt anyone else. However, a sad truth remains. I, along with other people, will never have an answer as to why. I will never have an apology for the wrongdoing. And most importantly, Epstein will not be justly sentenced for his crimes. Now I sit in my home questioning the well-being of those girls like myself. In choosing death, Epstein denied everyone justice.

Any efforts made to protect Epstein's name and legacy send a message to the victims that he wins and that he is untouchable. I understand his case may be dismissed or closed, but this makes me feel as though I, and anyone else who fell pry to his hands, simply do not matter.

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I ask that you very seriously consider the final decision, because it will undoubtedly affect all other facets of this case, including any future charges brought against the recruiters or third parties to his crimes. I do not want the narrative to be, Those poor girls. I want to send a message to anyone who would consider engaging in similar acts to think twice beforehand. I want some sort of closure for those of us who relive those horrible moments where we were assaulted, abused, and taken advantage of by Epstein.

You have the opportunity to help us seek that closure. I appreciate your time and consideration and ask for your continued support in dealing with this case to illustrate that we, Epstein's victims, do matter.

Sincerely, Jane Doe 8.

On behalf of Lisa Bloom and The Bloom Firm, thank you, your Honor.

THE COURT: Thank you, Ms. Gibbs. Did we have any other victim's counsel or victims? Ms. Allred.

MS. ALLRED: Good morning, your Honor. THE COURT: Good morning. How are you? MS. ALLRED: Fine. Thank you. Allred, Maroko & Goldberg by Gloria Allred, G-1-o-r-i-a A-1-1-r-e-d.

Your Honor, thank you so much for this opportunity to

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afford the victims their voice, because many of them have never spoken before. They never spoke in Florida. They never spoke anywhere. They never told their mother. They never told their father. They never told their family members. This is an opportunity for them to be heard. We thank you for that.

Your Honor, for 43 years my firm has been the leading women's rights private law firm in the United States. We have helped thousands of victims. And I, as an officer of the court, and as a believer in the system, have tried to encourage the victims to have confidence in the system that should provide them access to justice that should help them to assert and vindicate their rights in a court of law. It has been increasingly difficult in this case for me to say to my clients that they should have confidence in the system of justice given what has occurred in this case, People v. Jeffrey Epstein.

Having said that, I am encouraged by the fact that this court, essentially, in an unprecedented situation where the defendant is deceased, is still affording these victims an opportunity to be heard. So we thank you for that. It is some encouragement.

Your Honor, you also asked do our clients wish to be heard in reference to some of the issues that have been raised this morning, including what should happen into this case. Your Honor, there has been a suggestion that the court should investigate the circumstances of the death of Mr. Epstein. I'm

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not going to repeat the arguments made by counsel, but I would say that if there is jurisdiction, and I know that is a legal issue which has been previously argued, that certainly it would increase the confidence of my clients. Not just my clients, but victims all over, and some are, by the way, located in other parts of the world, to have the court oversee the investigation.

We are encouraged by the sensitivity of the attorneys for the United States Attorney's office for the Southern District of New York and the investigation that is going on with the separate team. However, and, of course, the defense is also conducting its own investigation. But I do think the greatest confidence would be if the court in some way would be able to oversee an investigation because the court is a neutral party. And although the court certainly has a stake in finding out what happened to defendants who are in the custody of the federal system and who should be there to face the prosecutors and the charges against them, but now are not because clearly the system has failed.

And the United States Attorney has admitted that, and even before he admitted that, everybody knows the system failed. Failed the victims, failed the court, failed everyone.

In any event, your Honor, having seen so many thousands of victims of gender violence, sex harassment, sexual assault, I've dealt with child sex trafficking, child

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molesters, I mean, this is a unique case because there are so many victims and so many failures of the system. At this point, what we would really ask for is not just words, but words have been helpful, but deeds, and that is very important.

In addition, I would like to say, throughout this case is the running theme of the betrayal of trust. Betrayal of trust by Jeffrey Epstein. Betrayal of trust by the system. And betrayal of trust to the victims who had a right to justice. And the Crime Victims' Act should not just be words, it should have meaning and it should be enforced.

In essence, we are asking, although you may need to, of course, grant this motion to dismiss, I think because the court has shown sensitivity to victims and victims' needs, if there is a way to at least keep the record open so that victims who have not been able to be physically present in the courtroom today and who have not been able to submit to the court any letters, victim impact, and who have not been able to secure attorneys or speak to attorneys yet -- so, for example, I'll still hearing from victims who I have not been able to meet with yet because they just recently are now contacting me -- so if they could submit, at least for the record, their victim impact statements, that, I think, would be a very important assistance to them. So that would be, at least they would know that what they are sharing is on the record.

So, in summary, I would say that they are looking

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forward to the very serious investigation by the United States Attorney of who may have conspired in this case, and that is very hopeful, and we're hoping that everyone who may have a role to this criminal prosecution will submit that evidence.

This is about power. This is about many victims having lived in fear -- fear of the rich, the powerful, the famous, fear that the system will not afford them justice. So fear of not coming forward. And fear, of course, is a weapon that the rich, powerful, famous, and sexual predators used to silence the victims. But that is gone for a lot of victims because they refuse to suffer in silence.

Finally, it does take courage to speak truth to power. We thank this honorable court for giving these victims a voice. We thank them, even after the death of the defendant, for showing respect for the victims, allowing them dignity, allowing them a voice. We do want truth, we do want justice, we do want accountability, and we do want those conspirators to face the justice system.

Your Honor, right now we have two of our clients who would like to address the court.

THE COURT: Sure.

MS. ALLRED: Then I have a couple of statements on victims who do not wish to address the court.

As they come up, we'll give them the opportunity to say either their name or Jane Doe.

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By the way, thank you, your Honor, for allowing some of these victims to be called Jane Doe. What number the court affords to them, we'll accept whatever that is.

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Thank you.

THE COURT: We're up to nine.

MS. ALLRED: Thank you.

Hello. My name is

That _5

I was going to start this statement by saying that 1 was a victim of Jeffrey Epstein. But that's not the case. I'm still a victim of Jeffrey Epstein. I'm still a victim because the fear of not being heard stopped me from telling my story for so many years. This lingering fear almost stopped me from attending this monumental movement of strength and power.

I'm still a victim because I am fearful for my daughters and everyone's daughters. I'm fearful for their future in this world, where there are predators in power, a world where people can avoid justice if their pockets run deep enough.

I'm still a victim because the 17-year-old was manipulated into thinking she had found someone who cared, someone who wanted to help. Jeffrey knew I had nowhere to go. He knew I was vulnerable, and he took advantage of that poor 24 girl, who will never be the same.

I cannot eat at the thought that Jeffrey Epstein -- _

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cannot eat at the thought of Jeffrey Epstein not serving the time he needed to realize the pain and suffering he caused so many vulnerable young girls. He thought he was untouchable, and honestly, so did I. I thought he was the most powerful person I would ever meet.

But the end is here and here I stand becoming more powerful than he will ever be. Thank you.

THE COURT: Thank you.

JANE DOE: Jane Doe.

Um, in 2004, when I was 15 years old, I flew on Jeffrey Epstein's plane to Zorro Ranch, where I was sexual molested by him for many hours. What I remember most vividly was him explaining to me how beneficial the experience was for me and how much he was helping me to grow. Yikes.

I remember feeling so small and powerless, especially after he positioned me by laying me on his floor so that I was confronted by all the framed photographs on his dresser of him smiling with wealthy celebrities and politicians.

After he finished with me, he told me to describe in detail how good my first sexual experience felt. That was the first of many lies I was forced to carry for him, the weight of which proliferated my trauma. I felt powerless not merely because one man wanted to strip me of my innocence, but because I was the victim of a system that just enfranchises human beings, making them vulnerable to pedophilic exploitation.

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As unjust as what happened to me was, I believe that experience to be a symptom of insidious and pathological violence that extreme wealth yields, a violence which ultimately stays hidden through channels of extreme power that serve it.

I first identified with this feeling the night after I was molested by Epstein, when another girl and I took out two of his ATVs and raised them across the mesa. I crashed mine and expressed my concern to the other girl of getting in trouble, which she replied to me, Don't worry, no one gets in trouble for anything here.

Even as a child, I understood, in a sad and precocious way, what I hoped we have the ability of changing now. Even though Epstein is dead, there is still justice to be brought for the crimes we felt powerless against concealing for him and the system that supported him for all these years.

Thank you.

THE COURT: You're very welcome.

MS. ALLRED: Thank you.

Your Honor, may it please the court. I would like to read a statement for Jane Doe, my client, who is present in court, but requested that I read it.

We only have one opportunity at childhood. One opportunity to develop. One opportunity to find direction for our lives. Jeffrey Epstein robbed and denied me at each

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opportunity he had.

I came from a small Texas town, not far from the New Mexico border. My mother died when I was 11, after suffering from cancer for many years. My father was devastated, as were my siblings and I. My father was saddled with debt. My only hope for college was to get a scholarship.

When I was 15, I was a blossoming freshman in high school and was trying to carry on my mother's dream. She wanted me to master the violin. After school, I would often go to a mall in a nearby city. A lady approached me and saw I had a violin case with me and asked if I was any good. We talked about the violin, my family, and why I had clothes that looked like hand-me-downs.

The lady told me she works for a very rich man who had a home close by and that he would pay to hear me play. I was told that if I could get away, she could arrange for transportation to and from his place and have me back before anyone knew I was gone. After some hesitation, I agreed. This decision was the beginning of the end of my childhood.

The man who only identified himself as J or Jeff had asked if I would give him a massage, and over four visits, eventually progressed The money he gave me further placed my young soul into a perverse sense of hell.

I was so utterly disgusted with myself and what he did

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to me that I stopped going to see him. I had documented the events with a Texas rape crisis center about the man I know now as Jeffrey Epstein.

Epstein targeted and took advantage of me, a young girl, whose mother had recently died a horrific death and whose family structure had deteriorated. His actions placed me, a young girl, into a downward spiral to the point where I purchased a gun and drove myself to an isolated place to end my suffering.

A voice that could only have been from my mother told me, quote, I am not the victim, I am the victor, and I dare not pull the trigger." I returned the gun days later.

Epstein is a coward. He lived his life leaching off the souls of inspiring, young girls due to the fact that he could never know how it feels inspired to live. Like a leach, once Epstein had his fill, he would unlatch and seek out another victim.

The only sense of justice I had hoped to see was Epstein being sentenced. However, Epstein died as he lived, taking the easy way out without any responsibility.

Your Honor, the next statement is also a statement of a Jane Doe. May it please the court.

I was a 16-year-old virgin when Jeffrey Epstein first raped me. I was naive and gullable. He was a pillar of finance and a giant in the world that I was an insignificant

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part of. I was so impressed that this great man would even talk to me and impart any of his wisdom on me. I gladly jumped at the chance to meet him again, when he told me how impressed he was with my personal story and maturity for my age.

When I was in his presence, he made an effort to call celebrities and influential people on speakerphone, like Academy Award-winning actresses and super models, who always answered his calls. Sadly, I was impressed.

He was friends with former and future heads of states and every other fixture in the New York social scene and beyond. He knew important people in my own world that I looked up to and revered, but he spoke about them like they were sweet distractions far beneath his stature. He could easily reach down from his position and influence the people directly involved with my daily life and future prosperity. I was the perfect victim.

My whole life was extremely turbulent. But one of my mother's greatest wishes was that all her children would graduate from respectable universities. He promised me that he would write me a letter of recommendation for Harvard if I got the grades and scores needed for admission. His word was worth a lot, he assured me, as he was in the midst of funding and leading Harvard's studies on the human brain, and the president was his friend.

The fact that all of you already know these next

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details, which I'll share, should ignite fire instead of induce the complacency they did in the past, when heard repeatedly over the years, but yes, an innocent massage turned sexual almost immediately.

"Here, come. Come help me with a kink in my shoulder while we finish our discussion." and a couple of hundred dollars, disgust and dirty secret, more praise and imparted wisdom from a godlike figure, a deliberate diabolical depression of grooming and submission for his pleasure and release. Even if I resisted, I was no match for him. I felt powerless, ashamed, and embarrassed. I wanted to vomit remembering these moments.

What I learned in those depraved sessions, staring up at the dome ceiling in his private massage room, tore a violent hole through any normal sexual awakening. I'm haunted forever, having learned everything there is to know about sex through a vile criminal. Every time a new molestation would bring a new lesson, the progressive and constant unwinding. I was nothing more than a teenage prostitute. I was his slave.

I had never even kissed a boy before I met him, and never throughout the horrific abuse did Jeffrey Epstein kiss me even once.

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I got a few hundred dollars, as usual, as he led me out of his mansion with assurances that I was on the right path guided by him. I lied to myself and tried to believe him. I became a hollow shell. If I missed an appointment, he threatened me and let me know who was in charge. "Do you know how important my time is? I'll bury you. I owe this -- I won't say the word -- F'ing town." He would hang up.

I would stand there frozen in the street, terrified that his assistant would call to reschedule. I made sure to stay in line and not disobey him. I was in complete denial. Being paid after every scheduled meeting felt routine and disgusting. He was the master of the universe and the world bent to his will.

He would eventually brag to his assistants about my ability to please him sexually right in front of me, leaving me feeling grotesque and worthless. Everything in my outside life was falling apart. I distanced myself from friends and grew further away from my family. I felt less human after each ordeal. My psyche broke down completely and wouldn't let me continue.

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One day I walked out of his residence and passed a girl similar to myself. When I turned around, she was entering Jeffrey's residence. He no longer even tried to schedule his appointments with other girls in secrecy from me. Maybe he never did. I was too stupid to see.

My world shattered. I had been so naive. I had an epiphany in a calvary of desperation. I realized I was just one of many young girls he had in rotation come to perform for him for money. I went into a deep depression and never lifted completely. I wanted to inflict pain on myself. I was humiliated, angry, and suicidal. I locked myself away from everything. I cut myself off forever from the world I had known.

I endured the daily agony of knowing my life would never be the same. I could never go back to New York City and the wonderful life I had taken for granted before I met this demon named Jeffrey Epstein.

This creature had manipulated and outwitted the whole system, including some of the most intelligent scientists, political people, prosecutors, and power players. How easy was it to manipulate a 16-year-old virgin who never had a boyfriend and came from a background of hardship with no parental guidance or support.

I went to therapy and was given antidepressants for severe anxiety and depression. My only solace, years later,

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was my desire to succeed on my own terms. I emersed myself into my studies and was accepted to every college I applied to, graduating from a top university. To this day, there is still an ache in my being that I did not apply to Harvard in fear of his influence there.

They say you never forget your first. I'm in a never-ending nightmare trying to do just that. I'm forever suffering because everything reminds me of that horror. This new wave of worldwide publicity only worsens my despair.

It was only many years later that I was finally intimate with a man again, and those moments were marred by my actions as a child with Jeffrey Epstein. Even now is impossible to separate his treachery from any care of a good man.

For one brief moment there was elation when he was recently arrested. I would finally get my chance to see him again face to face and show him what I had become, that I had succeeded on my own, that I was worth something in spite of his abuse, and that I had surmounted the monumental obstacles he laid before me throughout my entire life since falling prey to him.

I had hoped humanity would prevail, but it seems to me that he outsmarted everyone so far, and his ghost is still laughing at us. I appeal to all of those just and true that his evil legacy and his death not stand in the way of

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resolution and justice for all of his underaged victims. Thank you, your Honor.

And then just one last one, and this is much shorter. Statement of Jane Doe, also my client.

I was a model in another country when I came to the United States. I was told by a booker that I needed to meet with a man named Jeffrey Epstein, who was the owner of Victoria's Secret. The booker told me that Mr. Epstein could help me get into Victoria Secret's world.

It was my childhood dream to be a Victoria's Secret model. So I went one day in the afternoon and I met Mr. Epstein in his office in his mansion in New York. A woman introduced herself and suggested to me that I should be extremely nice to Mr. Epstein, because if he liked me, he would probably have photographers shooting photos of me right away.

The told me to go upstairs and directed me to Jeffrey Epstein's office. Mr. Epstein had a white robe on and we chatted very briefly. I had my portfolio of photos, but he didn't even look at it. Suddenly, he took his robe off and got close to me. I got up to leave, but the door was locked.

I didn't know what was going on. It was my first official meeting to be cast in the United States. I was a 23 young girl and confused. He got very close to me, and I had a skirt on.

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At that point, I ran to the door again and figured out how to get out of there. A girl outside asked me where I was going and she said to be careful. She said that Mr. 'kpstein knew a lot of powerful people, including Bill Clinton, and that if I didn't do what Mr. Epstein wanted, I would not be able to have any job in the industry.

I was so scared. I couldn't wait to get out of there, and I left. I took the train home. I had spent all of my savings getting Victoria's Secret lingerie to prepare for what I thought would be my audition. But instead, it seemed like a casting call for prostitution. I felt like I was in hell.

Thank you, your Honor.

Thank you.

THE COURT: Thank you, Ms. Allred.

Was there anybody else, any victim's counsel or any of the other victims who have not been heard and wish to be heard?

Well, OK then. All I have to say, really, is thank you, all of you, for your participation in today's remarkable hearing. I think everybody has benefited greatly from your input, and especially from the testimony of victims here today and who have had the courage to come forward.

We have also benefited throughout these proceedings, 24 however brief altogether, from the attorneys' legal advocacy and their written and oral submissions. I'm grateful to them

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as well, both for the government and the defense and those representing the victims.

Finally, we're also grateful to the press for their very diligent coverage of seemingly every detail of this case.

That concludes our work for today and we stand adjourned.

Thanks. 

(Adjourned)

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