ATTORNEYS AT LAW January 7, 2021 VIA EMAIL Laura Birger Chief of the Criminal Division United States Attorney's Office Southern District of New York I St. Andrew's Plaza New York, New York 10007 Re: Dear Laura: In anticipation of our call tomorrow, we thought it would be useful to set out our thoughts about our client, Since 2019, has engaged in plea negotiations with your Office. Throughout this time period, prior counsel and we have stressed that we believe that any osecution of is wrong. The events for which you are considering prosecuting years ago. The sex trafficking was run by and for the benefit of Mr. Epstein. sexual) or financial) benefit from Mr. E stein's sexual abuse of women. There is no question that making appointments and phone calls were at Epstein and Maxwell's direction. occurred did not Your Office has acknowledged that none of the victims ever told their age, but you argue she should have known their age from circumstantial evidence. Thus, you allege that she turned a blind eye to Mr. Epstein's wrongdoing — the same that can be said about every other person in Mr. Epstein's orbit, including the numerous people who worked in his houses, arranged his travel, etc. For these reasons and others, we have told your Office that we believe that it is unjust to single out for prosecution. We understand from you that many of the victims are angry at her because they recall her scheduling some of their appointments and walking some of them to the massage room, whereupon Mr. Epstein molested them. The victims were young at the time that this occurred, and they were traumatized by Mr. Epstein's abusive conduct. We 1 EFTA_00054804 EFTA01250743