{"efta_number": "EFTA00207048", "page_count": 11, "url": "https://epstein-data.com/EFTA00207048", "pdf_url": "https://epstein-data.com/pdf/EFTA00207048.pdf", "pages": [{"efta_number": "EFTA00207048", "page_number": 0, "text_content": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA \nCASE NO. \nUNITED STATES OF AMERICA \nvs. \nALFREDO RODRIGUEZ, \nDefendant. \n \n/ \nPLEA AGREEMENT \nThe United States of America and Alfredo Rodriguez (hereinafter referred to as the \n\"defendant\") enter into the following agreement: \n1. \nThe Charge to Which the Defendant Is Pleading Guilty: The defendant agrees \nto plead guilty to the sole count of the Information, which charges that, from at least as early \nas January 18, 2007, through on or about November 3, 2009, in Palm Beach County, in the \nSouthern District of Florida, and elsewhere, the defendant did corruptly conceal a record, \ndocument, or other object, with the intent to impair the object's availability for use in an \nofficial proceeding, that is proceedings before a federal grand jury, and otherwise corruptly \nobstructed and impeded said official proceeding; in violation of Title 18, United States Code, \nSection 1512(c). \n2. \nThe Elements of the Offense of Conviction: The elements of the offense of \nobstruction of justice, in violation of Title 18, United States Code, Section 1512(c), are as \nPage 1 of 11 \nEFTA00207048\n", "char_count": 1151}, {"efta_number": "EFTA00207048", "page_number": 1, "text_content": "follows: \nFirst, that the defendant concealed a record, document, or other object with the \nintent to impair the object's availability for use in an official proceeding, or otherwise \nobstructed or impeded that proceeding; \nSecond, that the defendant did so \"corruptly,\" that is, wrongfully and with \nimproper purpose; and \n\"Third, that the defendant's conduct had a relationship in time, causation or \nlogic with the official proceeding, that is, that the endeavor had the natural and \nprobable effect of interfering with the due administration of justice. \n3. \nStatutory Penalties: The defendant understands and acknowledges that, as to \nthe charge contained in the Information, the Court may impose a maximum sentence of \ntwenty (20) years' imprisonment to be followed by a term of supervised release of up to three \n(3) years, and may impose a fine of up to $250,000. The defendant also understands that, in \naddition to any term of imprisonment and supervised release and/or any fine that is imposed, \nthe Court may order him to pay restitution to any victim of his offense, as required by law. \nThe defendant understands and acknowledges that a violation of the terms of his supervised \nrelease can result in additional criminal penalties. \n4. \nSpecial Assessment: The defendant further understands and acknowledges that, \nin addition to the sentence imposed under paragraph 3 of this Agreement, a special \nassessment in the amount of $100 will be imposed. The defendant agrees that any special \nassessment imposed shall be paid at the time of sentencing. \nPage 2 of 11 \nEFTA00207049\n", "char_count": 1590}, {"efta_number": "EFTA00207048", "page_number": 2, "text_content": "5. \nApplicability of Sentencing Guidelines: The defendant is aware that the \nsentence will be imposed by the Court after considering the Federal Sentencing Guidelines \nand Policy Statements (hereinafter \"Sentencing Guidelines\"). The defendant acknowledges \nand understands that the Court will compute an advisory sentence under the Sentencing \nGuidelines and that the applicable guidelines will be determined by the Court relying in part \non the results of a Pre-Sentence Investigation by the Court's Probation Office, which \ninvestigation will commence after the entry of the defendant's guilty plea. The defendant is \nalso aware that, under certain circumstances, the Court may depart from the advisory \nsentencing guideline range that it has computed, and may raise or lower that advisory \nsentence under the Sentencing Guidelines. The defendant further understands that the Court \nis required to consider the advisory guideline range determined under the sentencing \nguidelines, but is not bound to impose that sentence; the Court is permitted to tailor the \nultimate sentence in light of other statutory concerns, and such sentence may be either more \nsevere or less severe than the Sentencing Guidelines' advisory sentence. Knowing these \nfacts, the defendant understands and acknowledges that the Court has the authority to impose \nany sentence within and up to the statutory maximum authorized by law for the offense \nidentified in paragraph 1 and that the defendant cannot withdraw his guilty plea solely as a \nresult of the sentence imposed. \n6. \nRights Waived by Pleading Guilty: The defendant understands that by pleading \nguilty, he knowingly and voluntarily waives the following rights: \na. \nthe right to plead not guilty and to persist in a plea of not guilty; \nPage 3 of 11 \nEFTA00207050\n", "char_count": 1804}, {"efta_number": "EFTA00207048", "page_number": 3, "text_content": "the right to a speedy and public trial before a jury of his peers; \nthe right to the effective assistance of counsel at trial, including, if the \ndefendant could not afford an attorney, the right to have the Court appoint an attorney \nfor the defendant; \nd. \nthe right at trial to be presumed innocent until guilt has been proven \nbeyond a reasonable doubt by the United States; \ne. \nthe right at trial to confront and cross-examine witnesses against the \ndefendant; \nf. \nthe right to compel or subpoena the testimony of witnesses and other \nevidence to present at trial; \ng. \nthe right at trial to testify or to remain silent, and the right that such \nsilence could not be used against the defendant; \nh. \nthe right to challenge the sufficiency of the Information; and \ni. \nthe right to appeal any pretrial rulings or a finding of guilt. \n7. \nGovernment's Right to Disclose Information to the Court: The Office of the \nUnited States Attorney for the Southern District of Florida (hereinafter \"Office\") reserves the \nright to inform the Court and the Probation Office of all facts pertinent to the sentencing \nprocess, including all relevant information concerning the offenses committed, whether \ncharged or not, as well as concerning the defendant and the defendant's background. Subject \nonly to the express terms of any agreed-upon sentencing recommendations contained in this \nAgreement, this Office further reserves the right to make any recommendation as to the \nPage 4 of 11 \nEFTA00207051\n", "char_count": 1497}, {"efta_number": "EFTA00207048", "page_number": 4, "text_content": "quality and quantity of punishment. \n8. \nAcceptance of Responsibility: The United States and the defendant agree that. \nalthough not binding on the Probation Office or the Court, they will jointly recommend that \nthe Court should reduce by two levels the sentencing guideline level applicable to the \ndefendant's offense, pursuant to Section 3E1.1 of the Sentencing Guidelines, based upon the \ndefendant's recognition and affirmative acceptance of personal responsibility. If at the time \nof sentencing the defendant's offense level is determined to be 16 or greater, and the \ndefendant complies with the requirements of Section 3E1.1, the government will make a \nmotion requesting an additional one-level decrease pursuant to Section 3E1.1(b) of the \nSentencing Guidelines, stating that the defendant has assisted authorities in the investigation \nor prosecution of his own misconduct by timely notifying authorities of his intention to enter \na plea of guilty, thereby permitting the government to avoid preparing for trial and permitting \nthe government and the Court to allocate their resources efficiently. \n9. \nLimitation on Joint Sentencing Recommendations: The defendant understands \nand agrees that the United States will not be required to make the motion and sentencing \nrecommendation set forth in paragraph (8) if the defendant: (a) fails or refuses to make a full, \naccurate and complete disclosure to the Probation Office of the circumstances surrounding \nthe relevant offense conduct; (b) is found to have misrepresented facts to the government \nprior to entering this plea agreement; (c) commits any misconduct after entering into this plea \nagreement, including but not limited to committing a state or federal offense, violating any \nterm of release, or making false statements or misrepresentations to any governmental entity \nPage 5 of 11 \nEFTA00207052\n", "char_count": 1874}, {"efta_number": "EFTA00207048", "page_number": 5, "text_content": "or official; or (d) fails to abide by the terms of the side agreement between the defendant and \nthis Office. \n10. \nFactual Proffer: The defendant, his counsel, and the United States further agree \nthat, had this case proceeded to trial, the United States would have introduced the following \nevidence, which is sufficient to support a plea of guilty and proves beyond a reasonable doubt \nthat the defendant is guilty of the charge contained in the Information. \na. \nThe defendant was formerly employed as a property manager by Jeffrey \nEpstein (\"Epstein\"), and lived and worked at Epstein's residence in Palm Beach, Florida, in \nthe Southern District of Florida, in 2004 and 2005. \nb. \nIn 2006, the defendant was interviewed by members of the Town of \nPalm Beach Police Department regarding allegations of illicit sexual conduct between Epstein \nand several minor females. On January 18, 2007, Special Agents of the Federal Bureau of \nInvestigation also interviewed the defendant in connection with a federal grand jury \ninvestigation of Epstein's criminal activity. The defendant was asked by law enforcement \nto produce any information or evidence in his possession related to Epstein's criminal \nactivity. The defendant also was provided with contact information for FBI Special Agents \nand was asked to contact them if he remembered or discovered any further information. \nc. \nIn July and August 2009, the defendant was subpoenaed to appear for \ndeposition in connection with several civil lawsuits filed against Epstein by minor female \nvictims of his criminal conduct. The subpoenas called for the defendant to appear and \nproduce documents related to Epstein. The defendant appeared for deposition but did not \nPage 6 of 11 \nEFTA00207053\n", "char_count": 1746}, {"efta_number": "EFTA00207048", "page_number": 6, "text_content": "produce any documents. \nd. \nBeginning in August 2009, after the conclusion of the second deposition, \nthe defendant contacted a cooperating witness (CW) and informed the CW that he had \nadditional information that he had not previously disclosed to any law enforcement agency \nor any of the civil attorneys, including lists of \"hundreds\" of additional victims and their \ntelephone numbers. The defendant agreed to turn this information over to the CW in \nexchange for $50,000. The CW tried to convince the defendant to turn over the material \nvoluntarily, but the defendant refused. The CW then approached law enforcement. During \na consensually monitored telephone call on October 28, 2009, the CW told the defendant that \nhe would be contacted by an associate of the CW regarding the purchase of the material. The \n\"associate\" was, in fact, an undercover Special Agent of the Federal Bureau of Investigation \n(\"UCE\"). \ne. \nOn October 29, 2009, the UCE contacted the defendant via telephone. \nThe defendant again explained that he would only turn over the information in exchange for \nmonetary compensation. During the conversation, the defendant admitted that he knew that \nthe information was relevant to the FBI's criminal investigation and was called for by the \ninvestigation. The defendant explained that he had not turned over the information to the FBI \nbecause: (1) it was his \"property\" and he should be compensated for it; and (2) he was afraid \nthat Epstein would make him \"disappear\" or otherwise harm him, and the information was \nhis \"insurance policy.\" \n1. \nOn November 3, 2009, the defendant met with the UCE at a \nPage 7 of 11 \nEFTA00207054\n", "char_count": 1660}, {"efta_number": "EFTA00207048", "page_number": 7, "text_content": "predetermined location. During the meeting, the defendant produced a small bound book and \nseveral sheets of legal pad paper containing hand-written notes. The defendant discussed in \ndetail the information contained within the book, which he admitted removing from Epstein's \nhome without Epstein's permission, and identified important information to the UCE. In \naddition, the defendant admitted that he had previously lied to the FBI during the course of \nthe federal criminal investigation of Epstein. The defendant asked the UCE about the \n$50,000.00, took possession of the money, and began counting it. The defendant was then \ndetained for Obstruction of Official Proceedings, in violation of Title 18, United States Code, \nSection 1512(c), and questioned. After Miranda warnings were administered by agents, the \ndefendant waived his rights and signed a written waiver of those rights. The defendant \nadmitted that he had the documents and book in his possession and had never turned them \nover to local law enforcement or the FBI. In addition, the defendant advised he had \nwitnessed naked girls whom he believed were minors at the pool area of Epstein's home, \nknew that his former employer was engaging in sexual contact with underage girls, and had \nviewed pornographic images of underage girls on computers in Epstein's home. \ng. \nThe items that the defendant attempted to sell to the UCE were reviewed \nby an FBI Special Agent involved in the federal grand jury investigation of Epstein. As the \ndefendant had described, the items contained information material to the Epstein \ninvestigation, including names of material witnesses and additional victims. The items also \nwould have corroborated testimony of victims already identified. Had the items been \nproduced in response to the inquiries of the state or federal authorities, or if the defendant had \nPage 8 of 11 \nEFTA00207055\n", "char_count": 1897}, {"efta_number": "EFTA00207048", "page_number": 8, "text_content": "contacted the federal authorities at any time after his initial interview to produce these items, \nthe materials would have been presented to the federal grand jury. \n11. \nNo Promises or Representations Regarding Ultimate Sentence: The defendant \nis aware that the sentence has not yet been determined by the Court. The defendant also is \naware that any estimate of the probable sentencing range or sentence that the defendant may \nreceive, whether that estimate comes from the defendant's attorney, the government, or the \nprobation office, is a prediction, not a promise, and is not binding on the government, the \nprobation office, or the Court. The defendant understands further that any recommendation \nthat the government makes to the Court as to sentencing, whether pursuant to this agreement \nor otherwise, is not binding on the Court and the Court may disregard the recommendation \nin its entirety. The defendant acknowledges that no one has promised or guaranteed what \nsentence the Court will impose. The defendant understands and acknowledges, as previously \nacknowledged in paragraph 5 above, that the defendant may not withdraw his plea based \nupon (a) the Court's decision not to accept a sentencing recommendation made by the \ndefendant and/or the government, or (b) the fact that he received an incorrect estimate of the \nsentence that he would receive, whether that estimate came from his attorney. the United \nStates, and/or the Probation Office. \n12. \nVoluntariness of Plea: The defendant agrees that he has entered into this Plea \nAgreement freely and voluntarily, and that no threats or promises, other than the promises \ncontained in this written Plea Agreement, were made to induce the defendant to enter his plea \nof guilty. \nPage 9 of 11 \nEFTA00207056\n", "char_count": 1778}, {"efta_number": "EFTA00207048", "page_number": 9, "text_content": "13. \nConsent to Forfeiture/Disposal/Destruction of Items: The defendant agrees to \nforfeit all interests in any items seized during the course of this investigation, whether the \ndefendant currently owns, has previously owned, or over which the defendant currently, or \nhas in the past, exercised control, directly or indirectly. Defendant agrees to hold the United \nStates, its agents, and employees harmless from any claims whatsoever in connection with \nthe forfeiture, seizure, or destruction of property covered by this agreement. The defendant \nagrees that this property may be destroyed or disposed of in accordance with the policies and \nprocedures of the custodial agency. The defendant further agrees to waive all constitutional \nand statutory challenges in any manner (including direct appeal, habeas corpus, or any other \nmeans) to any destruction or disposal of property carried out in accordance with this Plea \nAgreement on any grounds, including that the forfeiture constitutes an excessive fine or \npunishment. Defendant acknowledges that all property covered by this agreement is subject \nto forfeiture as property involved in illegal conduct giving rise to forfeiture. \n14. \nAppeal Waiver: The defendant is aware that Title 18, United States Code, \nSection 3742 affords the defendant the right to appeal the sentence imposed in this case. \nAcknowledging this, in exchange for the undertakings made by the United States in this plea \nagreement, the defendant hereby waives all rights conferred by Section 3742 to appeal any \nsentence imposed, including any restitution order, or to appeal the manner in which the \nsentence was imposed, unless the sentence exceeds the maximum permitted by statute or is \nthe result of an upward departure and/or a variance from the guideline range that the court \nestablishes at sentencing. The defendant further understands that nothing in this agreement \nPage 10 of 11 \nEFTA00207057\n", "char_count": 1936}, {"efta_number": "EFTA00207048", "page_number": 10, "text_content": "shall affect the government's right and/or duty to appeal as set forth in Title 18, United States \nCode, Section 3742(b). However, if the United States appeals the defendant's sentence \npursuant to Section 3742(b), the defendant shall be released from the above waiver of \nappellate rights. By signing this agreement, the defendant acknowledges that he has \ndiscussed the appeal waiver set forth in this agreement with his attorney. The defendant \nfurther agrees, together with the United States, to request that the district court enter a \nspecific finding that the defendant's waiver of his right to appeal the sentence to be imposed \nin this case was knowing and voluntary. \n15. \nEntire Agreement: This is the entire agreement and understanding between the \nUnited States and the defendant. There are no other agreements, promises, representations, \nor understandings unless contained in a side letter from the United States Attorney's Office \nexecuted by all panics and counsel prior to the change of plea. \nJEFFREY H. SLOMAN \nUNITED STATES ATTORNEY \nDate: \nBy: \nASSISTANT UNITED STATES ATTORNEY \nDate:  \n \nBy: \n \nDate: \nBy: \nALFREDO RODRIGUEZ, DEFENDANT \nDAVE LEE BRANNON, ESQ. \nATTORNEY FOR DEFENDANT \nPage 11 of 11 \nEFTA00207058\n", "char_count": 1236}]}