Epstein Data Wiki

Victims in the Epstein record

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tagstopic, victims, court-records, compensation, redactions

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Designation used by federal prosecutorsThe collective term “the Minor Victims”, and separate numbered witness designations, in the Southern District of New York prosecution of Ghislaine Maxwell12
Designation used in the civil suitsNumbered Jane Doe pseudonyms, including Jane Doe 1 in the Southern District of New York3 and separately numbered Jane Doe plaintiffs in the Southern District of Florida4
Compensation programmeEpstein Victims’ Compensation Program; protocol dated May 29, 2020, approved by the Probate Court of the U.S. Virgin Islands on June 3, 2020; claims filing period June 25, 2020 to March 25, 202156
Programme administratorJordana H. Feldman, with Kenneth R. Feinberg and Camille S. Biros as co-designers7
Total number of victimsNot stated. The programme’s own closing statement counts claims and claimants, not victims: approximately 225 claims submitted, approximately 150 claimants found eligible8

Courts, federal prosecutors and the Epstein Victims’ Compensation Program each built their own machinery for identifying, counting and protecting the people the record treats as Epstein’s victims, and the three did not use the same categories or the same numbering. This page reports that machinery from the documents that create it: the pseudonyms and designations, and the statements the record makes about how many people are involved, including the compensation programme’s own count of claims and claimants.

It is a page about the record. It identifies no complainant, and it does not reproduce any account of what was done to anyone. The proceedings themselves are covered at Jane Doe #1 and Jane Doe #2 v. United States, the Palm Beach Police Department investigation and the 2008 non-prosecution agreement; the grounds on which the released files were redacted are covered at Document Redaction Integrity.

How the record designates them

The civil suits brought in the Southern District of Florida proceeded under numbered pseudonyms. The court’s opinion of February 12, 2009 on a motion to dismiss is captioned Jane Doe No. 5 v. Jeffrey Epstein and refers to the plaintiff throughout as “Plaintiff Jane Doe No. 5”.4 The action brought in the same district under the Crime Victims’ Rights Act is captioned Jane Doe #1 and Jane Doe #2 v. United States of America, No. 08-80736-Civ-Marra.9

The numbering was not applied uniformly. In the expert report served in the Virgin Islands’ action against JPMorgan Chase, the expert records in two footnotes that a woman who spoke at a hearing “was not given a Jane Doe number by the court”, and that “[b]ased on my accounting in the transcript, she would be Jane Doe No. 10”; a second footnote says the same of another woman and numbers her 11.10 Those two numbers are the expert’s own, not the court’s.

Federal prosecutors in the Southern District of New York used a separate scheme. In a letter motion of November 18, 2021 in United States v. Ghislaine Maxwell, the Government wrote that “[f]or sake of simplicity, the Government uses the term ‘Minor Victims’ to include Witness-3”, and added: “The Government acknowledges the Court’s order that Witness-3 should not be referenced at trial as a victim.”1 The court had ruled that this witness was not to be referred to at trial as a victim; the Government’s letter records that order and, for its own purposes, groups that witness under the collective term anyway.

What the record says about how many

No document cited on this page states a total. Four statements bear on the question, and each is scoped to its own author.

A pseudonymous plaintiff’s first amended class-action complaint against JPMorgan Chase Bank, N.A. alleges that “Epstein victimized hundreds of young women and girls with the assistance of a wide network of co-conspirators, including JP Morgan.”3 That is an allegation in a private plaintiff’s pleading, not a government’s complaint and not a finding by any court. Epstein had been dead more than three years when the complaint was filed; no response from him to this allegation is recorded, and none could be.

The expert retained by the Virgin Islands in that action, Bridgette Carr, wrote in a footnote to her opinion on the recruitment of economically vulnerable girls and young women: “Many of the documents I reviewed were redacted so I am unable to say how many victims met this criterion; however, I am unaware of any victim who described herself as economically stable.”10 Her stated position is that the redactions in the material she was given prevented a count.

The FBI New York Field Office issued an intelligence note on April 6, 2022 assessing the recruitment techniques of wealthy and influential individuals involved in sex trafficking, an assessment that covers more than one such individual and is not confined to Epstein. It states that the assessment is made “with medium confidence” and is “based on information from five victims with direct access, one victim’s court testimony, two individuals with direct access, and open source reporting”.11 That is a statement of the basis for one assessment spanning multiple subjects, and not a count of Epstein’s victims.

The press release announcing the opening of the compensation programme records that its protocol was designed “with input from attorneys representing over 70 victims, the Attorney General of the Virgin Islands, the Epstein Estate and other interested parties”.7 That figure describes the clients of the lawyers consulted on the design, and the release does not offer it as a total.

The compensation programme: who counted

The Epstein Victims’ Compensation Program was proposed to the Probate Court of the U.S. Virgin Islands on November 14, 2019, a draft protocol was presented to that court on February 4, 2020, the final protocol was approved on June 3, 2020, and claims could be filed from June 25, 2020 until March 25, 2021.6 The programme was designed by Kenneth R. Feinberg, Camille S. Biros and Jordana H. Feldman, and administered by Feldman.7 The programme’s own closing statement, issued August 9, 2021, records that approximately 225 claims were submitted, that approximately 150 claimants were found eligible, that 92 percent of eligible claimants accepted the compensation offered them, and that the Program paid over $121 million of the nearly $125 million awarded.8 Those are counts of claims and of claimants found eligible under the protocol’s own criteria; no document cited on this page states how many people the record treats as Epstein’s victims, and a count of claimants is not a count of victims.

The protocol’s eligibility criteria and evidentiary standard, what a claimant gave up in exchange for an award, the absence of any cap on compensation, and the programme’s confidentiality arrangements and the litigation over them are set out at Victim Compensation Program.

Footnotes

  1. Letter motion of the U.S. Attorney’s Office for the Southern District of New York to quash the defendant’s Rule 17(c)(3) subpoena to the administrator of the Epstein Victims’ Compensation Program, November 18, 2021, United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN), EFTA00010118, p. 1 and footnote 1. ↩ ↩2

  2. Letter of the U.S. Attorney’s Office for the Southern District of New York to counsel for the defendant, October 28, 2020, United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN), EFTA00030569, pp. 1 and 6. ↩

  3. Jane Doe 1, individually and on behalf of all others similarly situated v. JP Morgan Chase Bank, N.A., No. 22-cv-10019-JSR (S.D.N.Y.), First Amended Individual and Class Action Complaint, Document 36, filed January 13, 2023, EFTA00162121, p. 8, paragraph 25. ↩ ↩2

  4. Jane Doe No. 5 v. Jeffrey Epstein, No. 08-80381-CIV-MARRA (S.D. Fla.), Opinion and Order on Motion to Dismiss and Motion for More Definite Statement, entered February 12, 2009, EFTA02741750, p. 1 (caption and opening). No other page of this document is cited here. ↩ ↩2

  5. Independent Epstein Victims’ Compensation Program, Protocol, May 29, 2020, EFTA00010045, p. 8 (protocol folio 1). ↩

  6. Same press release, EFTA00032569, p. 2. ↩ ↩2

  7. Press release, “Renowned Claims Resolution Experts Announce Commencement of the Epstein Victims’ Compensation Program”, embargoed to June 25, 2020, EFTA00032569, p. 1. ↩ ↩2 ↩3

  8. Press release, “Independent Epstein Victims’ Compensation Program Announces Conclusion of Claims Process — Approximately $125 Million Awarded to Eligible Claimants”, August 9, 2021, EFTA00078666, p. 1. ↩ ↩2

  9. Jane Doe #1 and Jane Doe #2 v. United States of America, No. 08-80736-Civ-Marra/Matthewman (S.D. Fla.), United States’ Response to Petitioners’ Second Request for Admissions to the Government, entered January 14, 2016 [Document 354-2], EFTA01626136, p. 1 (caption). ↩

  10. Expert report of Bridgette Carr, June 16, 2023, filed as Exhibit 9 to Document 237-9 in Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 1:22-cv-10904-JSR (S.D.N.Y.), EFTA02810334, p. 21 (report folio 18), footnotes 77, 80 and 82. Nothing else in this report is cited here. ↩ ↩2

  11. FBI New York Field Office intelligence note, “Wealthy, Influential Individuals Involved in Sex Trafficking Likely Rely Primarily on Referrals and Career Enhancement Promises to Entice Victims”, 06 April 2022, EFTA00172536, p. 1. No other page of this document is cited here. ↩

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