{"efta_number": "EFTA00235326", "page_count": 360, "url": "https://epstein-data.com/EFTA00235326", "pdf_url": "https://epstein-data.com/pdf/EFTA00235326.pdf", "pages": [{"efta_number": "EFTA00235326", "page_number": 0, "text_content": "JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF THE \nCRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE \nREMEDIES \nCASE NO: 0840736-Civ-Marra/Johnson \nEXHIBIT A \nFiled Under Seal \nEFTA00235326\n", "char_count": 227}, {"efta_number": "EFTA00235326", "page_number": 1, "text_content": "C)\n09/12/2007 03:44 PM \nTo < \ncc \"alikUSAFLS1r \nbcc \nSubject Jeffrey Epstein \nJay —lavas nice seeing you again. -.Nand I tallced with Alex \nand \nWe are all satisfied in principle with the agreement, but \nthe Office is uncomfortable with the recommended federal charge. \nSpecifically, we are concerned about the effect of taking the \nposition that Mr. Epstein's house is in the special maritime and \nterritorial jurisdiction of the United States, and we have no \nevidence of any assaults occurring either on Mr. Epstein's plane or \noffshore from his residence. \nWe are hoping that you can find an alternative federal statute that \ncan be used. I also will wait to hear from Jack Goldberger to \ndiscuss logistics. \nThank you. \nI-\nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \nUS_Atty_Cor_001 \nEFTA00235327\n", "char_count": 810}, {"efta_number": "EFTA00235326", "page_number": 2, "text_content": "usdo \nEgov, \n09/13/2007 07:27 PM \nTo \"Jay Lelkowile \ncc \nbcc \nSubject RE: \nHi Jay -- Yes, I am. I have been spending some \nquality time with Title 18 looking for misdemeanors. \nDo you want to take a look at 18 USC 403, 18 USC \n1512(d), and 47 EEC 223(a)(1)(B) and we can talk about \nthem tomorrow? I know that someone mentioned there \nbeing activity on an airplane, I just want to make \nsure that there is factual basis for the plea that the \nagents can confirm. \nI'm not sure exactly where I will be tomorrow morning, \nso is it alright if I call you? \nHave a good evening. \n33401 \n \nOriginal Message \nFrom: Jay Lefkowitz fmailto: \nSentil\nrl\nll13,\n. \n2007 7:21 PM \nTo: \n(USAFLS)\nSubject: \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmaster@kirkland.com, \nand \nUS_Atty_Cor_002 \nEFTA00235328\n", "char_count": 1269}, {"efta_number": "EFTA00235326", "page_number": 3, "text_content": "0 \ndestroy this communication and all copies thereof, \nincluding all attachments. \n* • fa * • \nUS_Atty_Cor_003 \nEFTA00235329\n", "char_count": 125}, {"efta_number": "EFTA00235326", "page_number": 4, "text_content": "09119/2007 12:14 PM \nTo \ncc \nbee \nSubject RE: Meeting \n\"Jay Lelkovatt \nJudge Johnson has duty next week. \nJay — !hate to have to be firm about this, but we need to wrap this up by \nMonday. I will not miss my indictment date when this has dragged on \nfor several weeks already and then, if things fall apart, be left in a less \nadvantageous position than before the negotiations. I have had an \n82-page pros memo and 53-page indictment sitting on the shelf since \nMay to engage in these negotiations. There has to be an ending date, \nand that date is Monday. \nVillqfcrifa \nMS \nAttorney \nSent: 09/19/2007 11:51 AM AST \nTo: Jay Letkowitz \nSubject: Meeting \nSAFLS\\)\" \nis available Monday morning. Our most flexible West Palm \nBeach magistrate is on duty on Monday, so, assuming we have \nsigned documents by 1:30 or so, we should be able to get Mr. \nEpstein arraigned on Monday. I doubt that we will be able to get \neverything finished up here, get down to Miami, and try to find a \nMiami mag by close of business on Monday. \nUS_Atty_Cor_004 \nEFTA00235330\n", "char_count": 1051}, {"efta_number": "EFTA00235326", "page_number": 5, "text_content": "Q9/14t2007 09:55 \nAM \nTo \n\"Jay Le&ovate \ncc \nbce \nSubOct Pile documents \nHi Jay — I'm not sure which of those e-mail addresses is correct \nHere are drafts of the plea agreement and information. They have \nnot yet been blessed by Miami, but they have approved of prior \nsimilar drafts, so these should be close to what is needed. My \nYou also can get \nhome e-mail is \nme over the weekend on my cell phone at \n<<infomuttion charging 1512 and 113.pdf>> \n<<OLY Plea Agreement v4 1512 and 113 violations.pdf>> \nRegards, \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \nInformation charging 1512 and 113.pdt \nOLY Plea Agreement v4 1512 and 113 vlolatlons.pdf \nUS_Atty_Cor_005 \nEFTA00235331\n", "char_count": 688}, {"efta_number": "EFTA00235326", "page_number": 6, "text_content": "D \nUNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA \nCASE NO. \n18 U.S.C. § 1512(dX2) \n18 U.S.C. § 113(aX5) \nUNITED STATES OF AMERICA \nvs. \nJEFFREY EPSTEIN, \nDefendant. \nR \nThe United States Attorney charges that: \nCOUNT I \nIn or around October 2005, in Palm Beach County, in the Southern District of Florida, and \nelsewhere, the defendant, \nF \nJEFFREY EPSTEIN, \ndid intentionally harass another person, that is, Jane Doe #I, in an attempt to delay, prevent, and \ndissuade Jane Doe #1 from reporting to a law enforcement officrer of the United States the \n]g l\ncommission of a federal offense; in violation of Title 18, United Slat \node, Sections 1512(O2) \nand 2. \nCOUNT 2 \nIn or around \n2005, in the special territorial jurisdiction of the United States, that \nis, in an aircraft owned by a United States citizen while in flight over the high seas, and elsewhere, \nUS_Atty_Cor_006 \nEFTA00235332\n", "char_count": 905}, {"efta_number": "EFTA00235326", "page_number": 7, "text_content": "the defendant, \nJEFFREY EPSTEIN, \ndid kno \nly commit a simple assault on a person who was over the age of 16 years, that is, M.; \nin violat • \nTitle IS, United States Code, Section 113(aX5). \nR. ALEXANDER AC\nUNITED STATES ATTORNEY \nVILLAFARA \nASSISTANT UNITED STATES ATT \n2 \nF \nT \nUS_Atty_Cor_007 \nEFTA00235333\n", "char_count": 311}, {"efta_number": "EFTA00235326", "page_number": 8, "text_content": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA \nUNITDATES OF AMERICA \nvs. \nJEFFREY EPSTEIN, \nDefendant. \nCase 1'0'0.  \nR, \nPLEA AGREEMENT \nThe United States Attorney for the Southern District of Florida (\"the United States\"), \nand Jeffrey Epstein (hereinafter referred to as thitfendant\") enter into the following \nagreement \n1. \nThe defendant agrees to plead guilty to the Information which charges the \ndefendant as follows: Count 1 charges that the defendant intentionally harassed another person, \nthat is, Jane Doe #1, in an attempt to delay, prevent, and dissuade J \nill from reporting to a \nlaw enforcement officer of the United States the commission of a federal offense; in violation of \nTitle 18, United States Code, Sections 1512(d)(2) and 2; and Count 2 charges that the defendant, \nwhile in an airplane over the high seas, did knowingly commit a simple assault on a person who was \nT\nover the age of 16 years, that is, M.; in violation of Title 18, United States Code, Secti \nI I 3(aX5). \n2. \nThe defendant is aware that the sentence will be imposed by the Court after \nconsidering the Federal Sentencing Guidelines and Policy Statements (hereinafter \nPage 1 of 7 \nUS_Atty_Cor_008 \nEFTA00235334\n", "char_count": 1220}, {"efta_number": "EFTA00235326", "page_number": 9, "text_content": "\"Sentencing Guidelines\"). The defendant acknowledges and understands that the Court will \ncompute an advisory sentence under the Sentencing Guidelines and that the applicable \nguideli \nill be determined by the Court relying in part on the results of a Pre-Sentence \nInvesti \nby the Court's probation office, which investigation will commence after the \nguilty plea has been entered. The defendant is also aware that, under certain circumstances, \nthe Court may depart from the advisory sentencing guideline range that it has computed, and \nmay raise or lower that advisory soft under the Sentencing Guidelines. The defendant \nis further aware and understands that the Court is required to consider the advisory guideline \nrange determined under the Sentencing Guidelines, but is not bound to impose that sentence; \nthe Court is permitted to tailor the ultimate sentence in light of other statutory concerns, and \nsuch sentence may be either more seven or less \nre than the Sentencing Guidelines' \nadvisory sentence. Knowing these facts, the defendant understands and acknowledges that \nthe Court has the authority to impose any sentence within and up to the statutory maximum \nauthorized by law for the offenses identified in paragraph 1 and \nthe defendant may not \nwithdraw the plea solely as a result of the sentence imposed. \n3. \nThe defendant further understands and acknowledges that, as to Count 1 of the \nInformation, the Court may impose a statutory maximwn term of imprisonment of up to one \n(I) year, to be followed by a term of supervised release of up to a maximum off (I) year. \nIn addition to terms of imprisonment and supervised release, the Court may impose a fine of \nup to $100,000. The defendant further understands and acknowledges that, as to Count 2 of \nthe Information, the Court may impose a statutory maximum term of imprisonment of up to \nPage 2 of 7 \nUS_Atty_Cor_009 \nEFTA00235335\n", "char_count": 1908}, {"efta_number": "EFTA00235326", "page_number": 10, "text_content": "six (6) months, to be followed by a term of supervised release of up to a maximum of one (1) \nyear. In addition to terms of imprisonment and supervised release, the Court may impose a \nfine of \n$100,000. \nThe defendant further understands and acknowledges that, in addition to any \nsentence imposed under paragraph 3 of this Agreement, a special assessment in the amount \nof $50 will be imposed on the defendant, which must be paid at or before the time of \nsentencing. \nR \n5. \nThe defendant understands that the Court will order that he must pay full \nrestitution to all victims of the offense to which he is pleading guilty. The defendant \nunderstands that the amount of restitution owed to each victim will be determined at or \nbefore sentencing. \nA \n6. \nThe parties agree to jointly recommend that the defendant receive a sentence \nof eighteen (18) months' imprisonment, to be followed by two (2) years of supervised \nrelease; and a fine of $200,000. \n7. \nThe defendant agreesthat,ifanyoftheviictimsidentiAbdinthefederal investigation \nfile suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the jurisdiction of the U.S. \nDistrict Court for the Southern District of Florida over his person and/or the subject matter, and the \nnoT\ne\ndefendant will not contest that the identified victims are persons who, while mi \n, \nvictims \nof violations of Title 18, United States Code, Sections(s) 2422 and/or 2423. The \nhod States \nagrees to provide the defendant's attorneys with a list of the identified victims, which will not \nexceed forty, after the defendant has signed this agreement and has been sentenced. The United \nPage 3 of 7 \nUS_Atty_Cor_001 \nEFTA00235336\n", "char_count": 1677}, {"efta_number": "EFTA00235326", "page_number": 11, "text_content": "States further agrees to make a motion with the United States District Court for the Southern District \nof Florida for the appointment of a guardian ad litem for the identified victims and the defendant's \ncounsel \ncontact the identified victims through that guardian. \nThe defendant agrees to plead guilty (not nolo contendere) to an Information filed \nby the Palm Beach County State Attorney's Office charging an offense for which the defendant must \nregister as a sex offender, that is, solicitation of minors to engage in prostitution, in violation of Fl. \nStat. 796.03. The defendant agrees tha \nd the Palm Beach County State Attorney's Office will \nmake a joint, binding recommended \nthe Court impose a sentence of at least thirty (30) \nmonths, to be divided as follows: \n(a) \nthe defendant shall begin by serving at least twenty (20) months in prison, \nwithout any opportunity for wit olding adjudication or sentencing, and \nwithout probation or oammu • \nc t \nof in lieu of imprisonment; and \n(b) \nfollowing the term of imprisonment, the defendant shall serve ten (10) \nmonths of community control/home confinement with electronic monitoring. \n9. \nThe defendant agrees to waive all challenges to the s\ntation filed by the State \nAttorney's Office and to waive the right to appeal his conviction anJ\nH\nentence in the state court. \n10. \nThe defendant agrees that he will provide to the U.S. Attorney's Office copies of all \nproposed agreements with the Palm Beach County State Attorney's Office prior to entering into \nthose agreements. \n11. \nThe United States reserves the right to inform the Court and \nprobation \noffice of all facts pertinent to the sentencing process, including all relevant information \nconcerning the offenses committed, whether charged or not, as well as concerning the \nPage 4 of 7 \nUS_Atty_Cor_0011 \nEFTA00235337\n", "char_count": 1844}, {"efta_number": "EFTA00235326", "page_number": 12, "text_content": "defendant and the defendant's background, and to respond to any questions from the Court \nand the Probation Office and to any misstatements of fact or law. Subject only to the express \nterms \nagreed-upon sentencing recommendations contained in this Agreement, this \nOffice \nreserves the right to make any recommendation as to the quality and quantity \nof punishment. \n12. \nThe defendant is aware that the sentence has not yet been determined by the \nCourt. The defendant also is a \nany estimate of the probable sentencing range or \nsentence that the defendant may receive, whether that estimate comes from the defendant's \nattorney, the government, or the probation office, is a prediction, not a promise, and is not \nbinding on the government, the probation office or the Court. The defendant understands \nfurther that any recommendation that the govern \nr rnakes to the Court as to sentencing, \nwhether pursuant to this agreement or otherwise, is not binding on the Court and the Court \nmay disregard the recommendation in its entirety. The defendant understands and \nacknowledges, as previously acknowledged in paragraph 2 abov \nthe defendant may not \nwithdraw his plea based upon the Court's decision no \naccept a sentencing \nrecommendation made by the defendant, the government, or a recommendation made jointly \nby both the defendant and the government. \n13. \nWAIVER OF RIGHT TO APPEAL AND COLLATERALLY \nACK \nTHE SENTENCE. The defendant is aware that Title 18, United States Code, Section 3742 \naffords the defendant the right to appeal the sentence imposed in this case. Acknowledging \nthis, in exchange for the undertakings made by the United States in this plea agreement, the \nPage 5 of 7 \nUS_Atty_Cor_0012 \nEFTA00235338\n", "char_count": 1731}, {"efta_number": "EFTA00235326", "page_number": 13, "text_content": "defendant hereby waives all rights conferred by Section 3742 to appeal any sentence \nimposed, including any restitution order, or to appeal the manner in which the sentence was \nimpos \ness the sentence exceeds the maximum permitted by statute or is the result of \neiwk) \nan upw \nparture or upward variance from the guideline range that the Court establishes \nat sentencing. The defendant further voluntarily and expressly waives, to the maximum \nextent permitted by federal law, the right to collaterally attack his sentence in any post-\nconviction proceeding, including a \non on any ground brought under 28 U.S.C. § 2254, \n28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18 U.S.C. § 3771. The defendant further understands \nthat nothing in this agreement shall affect the government's right and/or duty to appeal as set \nforth in Title 18, United States Code, Section 3742(b). However, if the United States appeals \nthe defendant's sentence pursuant to Section 374 \nthe defendant shall be released from \nthe above waiver of appellate rights. By signing this agreement, the defendant acknowledges \nthat he has discussed the appeal waiver set forth in this agreement with his attorney. \n14. \nIf the defendant fails in any way to fulfill each on \nand \n• obligations under this \n1.,34., \nPlea Agreement, the United States,\n only the United States, \nelect to be released from \nits commitments under this Plea Agreement. If the United States elects to void the Plea \nAgreement because of a breach by the defendant, then the United States agrees not to use the \ndefendant's guilty plea against him. However, the United States mayprosecute'i \nefendant \nfor any and all Federal crimes that he has committed related to this case and may seek any \nsentence for such crimes up to and including the statutory maximums. The defendant \nexpressly waives any statute of limitations defense and any constitutional or statutory speedy \nPage 6 of 7 \nUS_Atty_Cor_001 3 \nEFTA00235339\n", "char_count": 1954}, {"efta_number": "EFTA00235326", "page_number": 14, "text_content": "or \n• \n1.9CAS \n09114/2007 09:57 AM \nTo \"Joy Letkowite \ncc \nbcc \nSubject RE: Follow up \nSorry, Jay. I just got this and have to run off to \nthe hospital. I will revise and re-email you tomorrow \nor late tonight. \nanti!!!!ll'orne \nWest Pa \nBe \n \nOriginal Message \nFrom: Jay Lefkowitz \nSent: Fricia \nSeptember 19, \nTo: \n. (USAFLS) \nSubject: Follow up \n******* *************** **** ***** * ****** * ** ***** ******* \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nUS_Atty_Cor_0014 \nEFTA00235340\n", "char_count": 827}, {"efta_number": "EFTA00235326", "page_number": 15, "text_content": "and may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmaster@kirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \nUS_Atty_Cor_001 5 \nEFTA00235341\n", "char_count": 279}, {"efta_number": "EFTA00235326", "page_number": 16, "text_content": "a Vie .cony \n09/15/2007 03:16 \nPM \nA  rx \nA• alr • \nTo \ncc \nbcc \nSubject JE negotiations \nHi Jay — Sorry to trouble you over the weekend. Here are the \nrevised documents with the 403 charge. I have otten some \nnegative reaction to the assault charge with \nas the \nvictim, since she is considered one of the mate perpetrators of the \noffenses that we planned to charge in the indictment. Can you talk \nto Mr. Epstein about a young woman name \nWe have \nhearsay evidence that she traveled on Mr. Epstein's airplane when \nshe was under 18, in around the 2000 or 2001 time frame. That \nfalls outside the statute of limitations, but perhaps we could \nconstruct a 371 conspiracy around that? \nLet me know what you think. \nThank you. \n•c•c< OM sot EOM on c rgIng±t(fl_id 113.pffLs_\nva\nlieen \narchived by user 'CommonStore/IT/Kirkland-Ellis' on '11/26/2007 \n01:07:11r >>> \n«.< Attachment 'OLY Plea Agreement v5 403 and 113 violations.odf \nhas been archived by userSommonStore/117Kbkland-Ellie on \n'11/26/2007 01:07:57'. >>> \nUS_Atty_Cor_001 6 \nEFTA00235342\n", "char_count": 1048}, {"efta_number": "EFTA00235326", "page_number": 17, "text_content": "sr \nD \nUNITED STATES OF \nvs. \nJEFFREY EPSTEIN, \nDefendant. \nUNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA \nCASE NO. \n18 U.S.C. § 403 \n18 U.S.C. § 113(a)(5) \nA \nINFORMATION \nThe United States Attorney charges that: \nCOUNT \nIn or around August 2006, in Palm Beach CoF, in the Southern District of Florida, and \nelsewhere, the defendant, \nJEFFREY EPSTEIN, \nb \ndid knowingly and intentionally violate the privacy protection accot  y 18 U.S.C. § 3509 to a \nchild victim, that is, Jane Doe #1; in violation of Title 18, United Sta \node, Sections 403 and 2. \nCOUNT 2 \nIn or around \n2005, in the special territorial jurisdiction of the United States, that \nis, in an aircraft owned by a United States citizen while in flight over the high seas, and elsewhere, \nthe defendant, \nJEFFREY EPSTEIN, \nUS_Atty_Cor_001 7 \nEFTA00235343\n", "char_count": 832}, {"efta_number": "EFTA00235326", "page_number": 18, "text_content": "did imowingly commit a simple assault on a person who was over the age of 16 years, that is, U; \nin violation of Title 18, United States Code, Section 113(a)(5). \nD \nIt. ALEXANDER ACOSTA \nUNITED STATES AT. \nASSISTANT UNI' \nATES ATTORNEY \nA \n2 \nF \nT \nUS_Atty_Cor_001 8 \nEFTA00235344\n", "char_count": 282}, {"efta_number": "EFTA00235326", "page_number": 19, "text_content": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA \nD \nCase No. \nUNITED STATES OF AMERICA \nvs. \nJEFFREY EPSTEIb \nDefend \nPLEA AGREEMENT \nThe United States Attorney fo \ne Southern District of Florida (\"the United States\"), \nand Jeffrey Epstein (hereinafter re \nd to as the \"defendant\") enter into the following \nagreement \n1. \nThe defendant agrees to plead guilty to the Information which charges the \ndefendant as follows: Count 1 charges that theFfendant knowingly and intentionally \nviolated the privacy protection accorded to child victims by 18 U.S.C. § 3509; in violation \nof Title 18, United States Code, Sections 403 and 2; and Count 2 charges that the defendant, \nwhile in an airplane over the high seas, did knowingly commit l\n on a person \nwho was over the age of 16 years, that is, \nin violation of Title 18, United States Code, \nSection 113(aX5). \n2. \nThe defendant is aware that the sentence will be imposed by the Court after \nconsidering the Federal Sentencing Guidelines and Policy Statements (hereinafter \nPage 1 of 7 \nUS_Atty_Cor_0019 \nEFTA00235345\n", "char_count": 1075}, {"efta_number": "EFTA00235326", "page_number": 20, "text_content": "\"Sentencing Guidelines\"). The defendant acknowledges and understands that the Court will \ncompute an advisory sentence under the Sentencing Guidelines and that the applicable \nguidelityll be determined by the Court relying in part on the results of a Pre-Sentence \nInvestigation by the Court's probation office, which investigation will commence after the \nguilty plea has been entered. The defendant is also aware that, under certain circumstances, \nthe Court may depart \nthe advisory sentencing guideline range that it has computed, and \nmay raise or lower \nisory sentence under the Sentencing Guidelines. The defendant \nis further aware and understands that the Court is required to consider the advisory guideline \nrange determined under the Sentencing Guidelines, but is not bound to impose that sentence; \nir\nthe Court is permitted to tailor the uisentence in light of other statutory concerns, and \nsuch sentence may be either more severe or less severe than the Sentencing Guidelines' \nadvisory sentence. Knowing these facts, the defendant understands and acknowledges that \nthe Court has the authority to impose any senten \nin and up to the statutory maximum \nauthorized by law for the offenses identified in paragraph 1 and that the defendant may not \nwithdraw the plea solely as a result of the sentence imposed. \n3. \nThe defendant further understands and acknowled \nthe \nes that, as to Count 1 of the \nt \nInformation,\n Court may impose a statutory maximum term of nprisonment of up to one \n(1) year, to be followed by a term of supervised release of up to a maximum of one (1) year. \nIn addition to terms of imprisonment and supervised release, the Court may impose a fine of \nup to $100,000. The defendant further understands and acknowledges that, as to Count 2 of \nthe Information, the Court may impose a statutory maximum term of imprisonment of up to \nPage 2 of 7 \nUS_Atty_Cor_0020 \nEFTA00235346\n", "char_count": 1913}, {"efta_number": "EFTA00235326", "page_number": 21, "text_content": "six (6) months, to be followed by a term of supervised release of up to a maximum of one (1) \nyear. In addition to terms of imprisonment and supervised release, the Court may impose a \nfine of D$100,000. \n4. \nThe defendant further understands and acknowledges that, In addition to any \nsentence imposed under paragraph 3 of this Agreement, a special assessment in the amount \nof $50 will be impog \non the defendant, which must be paid at or before the time of \nsentencing. \n5. \nThe defendant understands that the Court will order that he must pay full \nrestitution to all victims of the offense to which he is pleading guilty. The defendant \nunderstands that the amount of resAon owed to each victim will be determined at or \nbefore sentencing. \n6. \nThe parties agree to jointly recommend that the defendant receive a sentence \nof eighteen (18) months' imprisonment, to be T red by two (2) years of supervised \nrelease; and a fine of $200,000. \n7. \nThe defendant agrees that, if any of the victims identified in the federal \ninvestigation file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the \njurisdiction of the U.S. District Court for the Southern District \nFlorida over his person \nand/or the subject matter, and the defendant will not contest that the identified victims are \npersons who, while minors, were victims of violations of Title 18, United States Code, \nSections(s) 2422 and/or 2423. The United States agrees to provide the defendant's attorneys \nwith a list of the identified victims, which will not exceed forty, after the defendant has \nPage 3 of 7 \nUS_Atty_Cor_0021 \nEFTA00235347\n", "char_count": 1620}, {"efta_number": "EFTA00235326", "page_number": 22, "text_content": "signed this agreement and has been sentenced. The United States further agrees to make a \nmotion with the United States District Court for the Southern District of Florida for the \nappoin \nof a guardian ad I item for the identified victims and the defendant's counsel may \ncontact the identified victims through that guardian. \n8. \nThe defendant agrees to plead guilty (not nolo contendere) to an Information \nfiled by the Palm Be k\nCounty State Attorney's Office charging an offense for which the \ns\ndefendant must regi \na sex offender, that is, solicitation of minors to engage in \nprostitution, in violation of Fl. Stat. 796.03. The defendant agrees that he and the Palm \nBeach County State Attorney's Office will make a joint, binding recommendation that the \nCourt impose a sentence of at least \n(30) months, to be divided as follows: \n(a) \nthe defendant shall begin by serving at least twenty (20) months in \nprison, without any opportunity for withholding adjudication or \n(b) \nsentencing, and without • \non or community control in lieu of \nimprisonment; and \nfollowing the term of imprisonment, the defendant shall serve ten (10) \nmonths of community control/home confinement with electronic \nmonitoring. \n9. \nThe defendant agrees to waive all challenges to the Information filed by the \nState Attorney's Office and to waive the right to appeal his conviction and sentence in the \nstate court. \n10. \nThe defendant agrees that he will provide to the U.S. Attorney's Office copies \nPage 4 of 7 \nUS_Atty_Cor_0022 \nEFTA00235348\n", "char_count": 1532}, {"efta_number": "EFTA00235326", "page_number": 23, "text_content": "of all proposed agreements with the Palm Beach County State Attorney's Office prior to \nentering into those agreements. \nip\nThe United States reserves the right to inform the Court and the probation \noffice of all facts pertinent to the sentencing process, including all relevant information \nconcerning the offenses committed, whether charged or not, as well as concerning the \nk\ni\ndefendant and the de \ndant's background, and to respond to any questions from the Court \nand the Probation Of \nd to any misstatements of fact or law. Subject only to the express \nterms of any agreed-upon sentencing recommendations contained in this Agreement, this \nOffice further reserves the right to make any recommendation as to the quality and quantity \nof punishment. \nA \n12. \nThe defendant is aware that the sentence has not yet been determined by the \nCourt. The defendant also is aware that any estimate of the probable sentencing range or \nsentence that the defendant may receive, whether estimate comes from the defendant's \nattorney, the government, or the probation office, is a prediction, not a promise, and is not \nbinding on the government, the probation office or the Court. The defendant understands \nfurther that any recommendation that the government makes to the Court as to sentencing, \nT\nwhether pursuant to this agreement or otherwise, is not binding \nthe Court and the Court \nmay disregard the recommendation in its entirety. The defendant understands and \nacknowledges, as previously acknowledged in paragraph 2 above, that the defendant may not \nwithdraw his plea based upon the Court's decision not to accept a sentencing \nrecommendation made by the defendant, the government, or a recon-unendation made jointly \nPage 5 of 7 \nUS_Atty_Cor_0023 \nEFTA00235349\n", "char_count": 1769}, {"efta_number": "EFTA00235326", "page_number": 24, "text_content": "by both the defendant and the government. \n13. \nWAIVER OF RIGHT TO APPEAL AND COLLATERALLY ATTACK \nTHE SIDENCE. The defendant is aware that Title 18, United States Code, Section 3742 \naffords the defendant the right to appeal the sentence imposed in this case. Acknowledging \nthis, in exchange for the undertakings made by the United States in this plea agreement, the \ndefendant hereby w • \nall rights conferred by Section 3742 to appeal any sentence \nimposed, including a\nCtitution order, or to appeal the manner in which the sentence was \nimposed, unless the sentence exceeds the maximum permitted by statute or is the result of \nan upward departure or upward variance from the guideline range that the Court establishes \nat sentencing. The defendant ftuthAaluntarily and expressly waives, to the maximum \nextent permitted by federal law, the right to collaterally attack his sentence in any post-\nconviction proceeding, including a motion on any ground brought under 28 U.S.C. § 2254, \n28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18 U.S.C. \n1. The defendant further understands \nthat nothing in this agreement shall affect the governments right and/or duty to appeal as set \nforth in Title 18, United States Code, Section 3742(b). However, if the United States appeals \nthe defendant's sentence pursuant to Section 3742(b), the defendant shall be released from \nthe above waiver of appellate rights. By signing this agreement, \nefendant acknowledges \nthat he has discussed the appeal waiver set forth in this agreement with his attorney. \n14. \nIf the defendant fails in any way to fulfill each one of his obligations under this \nPlea Agreement, the United States, and only the United States, may elect to be released from \nits commitments under this Plea Agreement. If the United States elects to void the Plea \nPage 6 of 7 \nUS_Atty_Cor_0024 \nEFTA00235350\n", "char_count": 1855}, {"efta_number": "EFTA00235326", "page_number": 25, "text_content": "Agreement because of a breach by the defendant, then the United States agrees not to use the \ndefendant's guilty plea against hint However, the United States may prosecute the defendant \nfor any\n Federal crimes that he has committed related to this case and may seek any \nsentence for such crimes up to and including the statutory maximums. The defendant \nexpressly waives any statute of limitations defense and any constitutional or statutory speedy \ntrial defense to such \nosecution, except to the extent that such a defense exists as of the \ndate he signs this P1eA Bement. Finally, the defendant understands that his violation of \nthe terms of this Plea Agreement would not entitle him to withdraw his guilty plea. \n15. \nThis is the entire agreement and understanding between the United States and \nthe defendant. There are no other a \nents, promises, representations, or understandings. \nDate:  \n \nBy:  \nEL ALTNDER ACOSTA \nUNII \nSTATES ATTORNEY \nDate:  \n \nBy:  \nJEFFREY EPSTEINFr\nDEFENDANT \nDate:  \n \nBy:  \nJAY LEFKOWITZ, ESQ. \nATTORNEY FOR DEFENDANT \nPage 7 of 7 \nUS_Atty_Cor_0025 \nEFTA00235351\n", "char_count": 1101}, {"efta_number": "EFTA00235326", "page_number": 26, "text_content": "om> \n09/16/2007 08:49 AM \nlitgaiatakte \nTo \"Jay Lefkowitz\" \ncc \nbcc \nSubject Re: JE negotiations \nHi Jay — Sorry -- I didn't get your message until this morning. I \nwill call you at 9:15. If that doesn't work, let me know a better \ntime, otherwise I will just plan to speak to you at 9:15. Thanks. \nUS_Atty_Cor_0026 \nEFTA00235352\n", "char_count": 330}, {"efta_number": "EFTA00235326", "page_number": 27, "text_content": "om> \n09/16/2007 09:07 AM \nTo *Jay Lofkowitz\" < \ncc \nbcc \nSubject Re: JE negotiations \nSounds fine. Thanks. Can you e-mail me the number where you \nwant me to call you? \nUS_Atty_Cor_0027 \nEFTA00235353\n", "char_count": 200}, {"efta_number": "EFTA00235326", "page_number": 28, "text_content": "cm> \n09/16/2007 10:35AM \nTo \"Jay LeNewer \ncc \nbcc \nSubject Re: JE negotiations \n'PA \n-4441\n1!\"fgerniVig \n3\"fek?-iatal\n \nSiAl\ncUtg0 \nHi Jay — I will wait to hear from you before I change the \ndocuments back to the 1512, but can you tell me when you call \nback whether you had any issues with the language of the plea \nagreement or the information that I sent earlier? Thanks. \nUS_Atty_Cor_0028 \nEFTA00235354\n", "char_count": 407}, {"efta_number": "EFTA00235326", "page_number": 29, "text_content": "aegmel.com. \n09116/200711:41 \nAM \nTo •Jay Lolkowitf \ncc \nbce \nSubiect Re: a negotiations \nHi Jay — I looked up some 11th Circuit cases on simple assault and \nfound some good language. I also learned that, every moment that \none is aboard an enclosed civil airplane, they are in the \"special \naircraft jurisdiction of the United States,\" so the assault charge is \nreally a violation of 49 USC 46506, which doesn't change the \npenalties. \nI have drafted up a factual proffer that I would use at the change of \nplea based upon our brief conversation and the agents' interaction \nwith Ms. \nhome. The agents and I would need to speak \nwith Ms. \nand Ms. Groff briefly to confum that these \nfacts are true. Feel free to make suggestions. \nOn an \"avoid the press\" note, I believe that Mr. Epstein's airplane \nwas in Miami on the day of the Ms. Groff telephone call. If he was \nin Miami-Dade County at the time, then I can file the charge in the \nDistrict Court in Miami, which will hopefully cut the press \ncoverage significantly. Do you want to check that out? \nI will talk to you later. Thanks. \n<cc< Attachment 'Epstein Plea Proffer.doe hes been archived by user \ntonunonStoreill7Kiridand-Ellie on '11/28/2007 01:0817'. >>> \nUS_Atty_Cor_0029 \nEFTA00235355\n", "char_count": 1251}, {"efta_number": "EFTA00235326", "page_number": 30, "text_content": "om> \n09/16/2007 03:54 PM \nTo \"Jay Lefkowitzs\ncc \nboc \nSubject Re: \nHi Jay — This can wait until after the show but my voice is going \nso I thought I would type it up. I talked to \nand he still doesn't \nlike the factual baths. In his opinion, the plea should only address \nthe crimes that we were addressing, and we were not investigating \nMr. Epstein abusing his girlfriend. \nSo, these are the only options that he recommended: \n1. We go back to the original agreement where Mr. Epstein pleads \nonly to state charges and serves his time in the state, except that we \ncan agree to only 18 months imprisonment. \n2. Mr. Epstein pleads guilty to the state charges and also pleads to \neither two obstruction counts or to one count of violating 47 USC \n223(aX1)(3), with a joint non-binding recommendation of 18 \nmonths, so that Mr. Epstein can serve his time federally. \n3. (My suggestion only, not \nI go back to the U.S. \nAttorney and ask him to agree to an ABA-plea to a 371 count \n(conspiracy to violate 2422(b)) with a binding 20-month \nrecommendation so that Mr. Epstein can serve all of his time in a \nfederal facility. \nOr 4. Mr. Epstein pleads to one obstruction count, and serves part \nof his time federally and part state. \nOn your other proposed changes, some are fine and some are \nproblematic. \nRe your paragraph 2: As to timing, it is my understanding that Mr. \nEpstein needs to be sentenced in the state after he is sentenced in \nthe federal case, but not that he needs to 21 d guilty and be \nsentenced after serving his federal time. I. \nrecommended that \nsome of the timing issues be addressed only in the state agreement, \nso that it isn't obvious to the judge that we are trying to create \nfederal jurisdiction for prison purposes. My understanding is that \nMr. Epstein should sign a state plea agreement, plead guilty to the \nUS_Atty_Cor_0030 \nEFTA00235356\n", "char_count": 1872}, {"efta_number": "EFTA00235326", "page_number": 31, "text_content": "a \nfederal offenses, plead guilty to the state offenses, be sentenced on \nthe federal offenses, and then be sentenced on the state offenses, \nand then start serving the federal sentence. \nRe your paragraph 3: As to the reservation of Mr. Epstein's right to \nwithdraw his state plea or to appeal his state plea or sentence, that \nis fine, but we need the caveat that, if he were to do so, the United \nStates could proceed on our charges. \nRe your paragraph 6: With respect to the waiver of the right to \nappeal the federal sentence, given the way we have drafted the \ninformation, it is possible that getting to the 18 month sentence \nwill require an upward departure. The'version of the agreement \nthat you were working from is a federal non-prosecution \nagreement, the ones I have sent you recently are plea agreements \nthat get filed with the court. Please see if the appeal waiver \nlanguage in those versions is alright. \nRe your paragraph 7: As I mentioned, we will not waive the \npresentence investigation. I know that this will delay Mr. Epstein's \nsentencing by 70 days, but that will allow him to get all of his \naffairs in order. As to bail, it will be set at the time of arraignment, \nand we can work out a joint recommendation regarding the amount \nand its limitations. I have no objection to making a joint \nrecommendation that Mr. Epstein remain out on bond pending his \nsentencing, but Pm not sure that it belongs in a plea agreement, \nespecially since I can't bind the court on that issue. However, I can \nassure you, and we can put it on the record during the plea \ncollooquy, that I will join in your recommendation that he remain \nout on bond pending sentencing. The same goes for the prison \ncamp issue. As I mentioned, I have opposed a designation only \nonce in a very particular case. I can assure you, and we can put it \non the record at the plea colloquy that I will not oppose your \nrecommendation for Mr. Epstein's designation. \nRe your paragraph 8: As I mentioned over the t\n... [truncated, 2638 chars — for the full page use /api/corpus/document/EFTA00235326/31 or ?id=EFTA00235326&page=31]", "char_count": 2638}, {"efta_number": "EFTA00235326", "page_number": 32, "text_content": "and I will facilitate as much as I can getting the girls' approval of \nthis procedure because, as I mentioned, I think it is probably in \ntheir best interests. In teams of plea agreement language, let me \nsuggest the following: \nThe United States agrees to make a motion seeking the \nappointment of a Guardian ad Litem to represent the identified \nvictims. Following the appointment of such Guardian, the parties \nagree to work together in good faith to develop a Trust Agreement, \nsubject to the Court's approval, that would provide for any \ndamages owed to the identified victims pursuant to 18 U.S.C. \nSection 2255 Then include the last two sentences of your \nparagraph 8. \nRe the two paragraphs following your paragraph 8: I will include \nour standard language regarding resolving all criminal liability and \nI will mention \"co-conspirators,\" but I would prefer not to highlight \nfor the judge all of the other crimes and all of the other persons that \nwe could charge. Also, we do not have the power to bind \nImmigration and we make it a policy not to try to, however, I can \ntell you that, as far as I know, there is no plan to try to proceed on \n• \nan immi ation charges against either Ms. El or Ms. \nAlso, on the grand jury subpoenas, I can prepare letters \nwithdrawing them as of the signing of the plea agreement, but I \nwould prefer to take out that language. In my eyes, once we have a \nplea agreement, the grand jury's investigation has ended and there \ncan be no more use of the grand jury's subpoena power. \nI had hoped that we were far closer to resolving this than it appears \nthat we are. Can I suggest that tomorrow we either meet live or via \nteleconference, either with your client or having him within a quick \nphone call, to hash out these items? I was hoping to work only a \nhalf day tomorrow to save my voice for Tuesday's hearing and \ngrand jury, if necessary, but maybe we can set a time to meet. If \nyou want to meet \"off campus\" somewhere, that is fine. I will \nmake sure\n... [truncated, 2302 chars — for the full page use /api/corpus/document/EFTA00235326/32 or ?id=EFTA00235326&page=32]", "char_count": 2302}, {"efta_number": "EFTA00235326", "page_number": 33, "text_content": "1.90v> \n09/17/2007 09:43 AM \nTo \n' \ny Letkowite \ncc \"Gerald Letco \nXUSAFIS‘r < \nbee \nXUSAFLSWI \nSubject Heating before Judge Marra has been tai \nRoy and Jay — I received a call from Jenny, who is standing in as \nJudge Marra's CRD. She spoke with the judge and he agreed to \ntake the matter off the calendar. I told Jenny that if we are able to \nreach a plea agreement, we will withdraw the subpoena and Mr. \nBlack will withdraw his motion to quash. \nPlease call if you have questions. \nWM \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \nUS_Atty_Cor_0033 \nEFTA00235359\n", "char_count": 573}, {"efta_number": "EFTA00235326", "page_number": 34, "text_content": "09/17/2007 11:45 \nAM \nTo \"Jay LetkowIte \ncc \nbcc \nSubject Non-Prceecutton Agreements \nHi Jay — To avoid you having to reinvent the wheel, here is a copy \nof the last version of the non-prosecution agreement in Word and \nWordPerfect. \n<<070911 Epstein Non-Prosecution Agreemeatwpd» <<070911 Epstein \nNon-Prosecution Agreement.doc>> \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \n070911 Epstein Non-Prosecution Agreementwpd \n3 070911 Epstein Non-Prosecution Agreernentdoc \nUS_Atty_Cor_0034 \nEFTA00235360\n", "char_count": 508}, {"efta_number": "EFTA00235326", "page_number": 35, "text_content": "IN RE: \nINVESTIGATION OF \nJEFFREY EPSTEIN \nNON-PROSECUTION AGREEMENT \nIT APPEARING that the City of Palm Beach Police Department and the State Attorney's \nOffice for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, the \"State \nAttorney's Office\") have conducted an investigation into the conduct of Jeffrey Epstein \n(hereinafter \"Epstein\"); \nIT APPEARING that the State Attorney's Office has charged Epstein with three counts of \nsolicitation of prostitution, in violation of Florida Statutes Section 796.07; \nIT APPEARING that the United States Attorney's Office and the Federal Bureau of \nInvestigation have conducted their own investigation of the offenses and Epstein's background; \nIT APPEARING that Jeffrey Epstein (hereinafter \"Epstein\") has committed offenses \nagainst the United States from in or around 2001 through in or around October 2005, including: \n(1) \nknowingly and willftilly conspiring with others known and unknown to commit an \noffense against the United States, that is, to use a facility or means of interstate or \nforeign commerce to knowingly persuade, induce, or entice minor females to \nengage in prostitution, in violation of Title 18, United States Code, Section \n2422(b); all in violation of Title 18, United States Code, Section 371; \n(2) \nknowingly and willfully conspiring with others known and unknown to travel in \ninterstate commerce for the purpose of engaging in illicit sexual conduct, as \ndefined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18, \nUnited States Code, Section 2423(b); all in violation of Title 18, United States \nCode, Section 2423(e); \n(3) \nusing a facility or means of interstate or foreign commerce to knowingly persuade, \ninduce, or entice minor females to engage in prostitution; in violation of Title 18, \nUnited States Code, Sections 2422(b) and 2; \n(4) \ntraveling in interstate commerce for the purpose of engaging in illicit sexual \nconduct, as defined in 18 \n§ 2423(f), with minor females; in\n... [truncated, 2200 chars — for the full page use /api/corpus/document/EFTA00235326/35 or ?id=EFTA00235326&page=35]", "char_count": 2200}, {"efta_number": "EFTA00235326", "page_number": 36, "text_content": "and obtaining by any means a person, knowing that the person had not attained the \nage of 18 years and would be caused to engage in a commercial sex act as defined \nin 18 U.S.C. § 1591(cX1); in violation of Title 18, United States Code, Sections \n1591(aX1) and 2; and \nIT APPEARING that Epstein has accepted responsibility for his behavior by his signature \non this Agreement and \nIT APPEARING, after an investigation of the offenses and Epstein's background, that the \ninterest of the United States pursuant to the Petite policy will be served by the following \nprocedure; \nTHEREFORE, on the authority of R. Alexander Acosta, United States Attorney for the \nSouthern District of Florida, prosecution in this District for these offenses shall be deferred in \nfavor of prosecution by the State of Florida, provided that Epstein abides by the following \nconditions and the requirements of this Agreement set forth below. \nShould Epstein violate any of the conditions of this Agreement, the United States \nAttorney may at any time initiate prosecution against Epstein for any offense. In this case, the \nUnited States Attorney will furnish Epstein with notice specifying the condition(s) of the \nAgreement that he has violated. \nAfter timely fulfilling all the terms and conditions of the Agreement, no prosecution for \nthe offenses set out on pages 1 and 2 of this Agreement will be instituted in this District, and the \ncharges against Epstein if any, will be dismissed. \nTerms of the Agreement: \n1. \nEpstein shall plead guilty (not nolo contendere) to an Information filed by \nthe State Attorney's Office charging violations of the following Florida \nStatutes: \n(a) \nlewd and lascivious battery on a child, in violation of FL Stat. \n800.04(4); \n(b) \nsolicitation of minors to engage in prostitution, in violation of Fl. \nStat. 796.03; and \n(c) \nengaging in sexual activity with minors at least sixteen years of \nage, in violation of Fl. Stat. 794.05. \n2. \nEpstein and the State Attorney's Office shal\n... [truncated, 2163 chars — for the full page use /api/corpus/document/EFTA00235326/36 or ?id=EFTA00235326&page=36]", "char_count": 2163}, {"efta_number": "EFTA00235326", "page_number": 37, "text_content": "(a) \nEpstein shall begin by serving at least twenty (20) months in \nprison, without any opportunity for withholding adjudication or \nsentencing, and without probation or community control in lieu of \nimprisonment; and \n(b) \nfollowing the term of imprisonment, Epstein shall serve ten (10) \nmonths of community control. \n3. \nEpstein shall waive all challenges to the Information filed by the State \nAttorney's Office and shall waive the right to appeal his conviction and \nsentence. \n4. \nEpstein shall provide to the U.S. Attorney's Office copies of all proposed \nagreements with the State Attorney's Office prior to entering into those \nagreements. \n5. \nEpstein agrees that, if any of the victims identified in the federal \ninvestigation file suit pursuant to 18 U.S.C. § 2255, Epstein will not \ncontest the jurisdiction of the U.S. District Court for the Southern District \nof Florida over his person and/or the subject matter, and Epstein will not \ncontest that the identified victims are persons who, while minors, were \nvictims of violations of Title 18, United States Code, Sections(s) 2422 \nand/or 2423. \n6. \nThe United States shall provide Epstein's attorneys with a list of the \nidentified victims, which will not exceed forty, alter Epstein has signed \nthis agreement and has been sentenced. The United States shall make a \nmotion with the United States District Court for the Southern District of \nFlorida for the appointment of a guardian ad litem for the identified \nvictims and Epstein's counsel may contact the identified victims through \nthat counsel. \n7. \nEpstein shall enter his guilty plea and be sentenced not later than \nSeptember 28, 2007, and shall begin service of his sentence not later than \nOctober 15, 2007. \n8. \nWith credit for gain time, Epstein shall serve at least 17 months in a state \ncorrectional institution. \nEpstein understands that the United States Attorney has no authority to require the State \nAttorney's Office to abide by any terms of this agreement. Epste\n... [truncated, 2264 chars — for the full page use /api/corpus/document/EFTA00235326/37 or ?id=EFTA00235326&page=37]", "char_count": 2264}, {"efta_number": "EFTA00235326", "page_number": 38, "text_content": "pursuant to the Petite policy. \nBy signing this agreement, Epstein asserts and certifies that each of these terms is \nmaterial to this agreement and is supported by independent consideration and that a breach of any \none of these conditions allows the United States to elect to terminate the agreement and to \ninvestigate and prosecute Epstein for any and all federal offenses. \nBy signing this agreement, Epstein asserts and certifies that he is aware of the fact that the \nSixth Amendment to the Constitution of the United States provides that in all criminal \nprosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further is \naware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court may \ndismiss an indictment, information, or complaint for unnecessary delay in presenting a charge to \nthe Grand Jury, filing an information, or in bringing a defendant to trial. Epstein hereby requests \nthat the United States Attorney for the Southern District of Florida defer such prosecution. \nEpstein agrees and consents that any delay from the date of this Agreement to the date of \ninitiation of prosecution, as provided for in the terms expressed herein, shall be deemed to be a \nnecessary delay at his own request, and he hereby waives any defense to such prosecution on the \nground that such delay operated to deny him rights under Rule 48(b) of the Federal Rules of \nCriminal Procedure and the Sixth Amendment to the Constitution of the United States to a \nspeedy trial or to bar the prosecution by reason of the running of the statute of limitations for a \nperiod of months equal to the period between the signing of this agreement and the breach of this \nagreement. Epstein further asserts and certifies that he understands that the Fifth Amendment \nand Rule 7(a) of the Federal Rules of Criminal Procedure provide that all felonies must be \ncharged in an indictment presented to a grand jury. Epstein hereby agrees and consents that, if \n... [truncated, 2579 chars — for the full page use /api/corpus/document/EFTA00235326/38 or ?id=EFTA00235326&page=38]", "char_count": 2579}, {"efta_number": "EFTA00235326", "page_number": 39, "text_content": "Tn\n.@usdo \n1410v* \n09/17,2007 01:11 PM \nTo c \n> \ncc \nl(USAFLST \nbcc \nSubject My whereabouts \nHi Jay — lam headed home. If a document is readytakcLeviewed \nlater today, can ou send a copy to me and also to \n(who is \nin, in f \nnd to my home e-mail address —\nand give me a call on my cell'. \n, so I can be ready for some discussions tomorrow. If \nanything else comes up, please don't hesitate to call. \nThanks, \nUS_Atty_Cor_0039 \nEFTA00235365\n", "char_count": 440}, {"efta_number": "EFTA00235326", "page_number": 40, "text_content": "\"=\\\nSAMS‘ '\n®usdoj.gov> \n09/18/2007 09:14 AM \nTo \"Jay Lefkowite \nCC \nSub RE: Draft Agreements? \nject \nHi Jay - I know that the U.S. Attorney will not go below 18 \nmonths of prison/jail time (and I would strongly oppose the \nsuggestion). \nAssistant U.S. Attome\nWest Palm Beach, FL 3340 \nUS_Atty_Cor_0040 \nEFTA00235366\n", "char_count": 317}, {"efta_number": "EFTA00235326", "page_number": 41, "text_content": "I believe there are only two types of agreements that would apply \nto this case: (1) a plea agreement to a federal charge or charges; \nand (2) a non-prosecution agreement (which is really a deferred \nprosecution agreement because the defendant agrees that if he \nviolates the agreement, the U.S. can prosecute him). \nA plea agreement is part of the court file. It is not accessible \non-line via PACER, but someone can go to the Clerk's Office to \nobtain a copy. \nA non-prosecution agreement would not be made public or filed \nwith the Court, but it would remain part of our case file. It \nprobably would be subject to a FOIA request, but it is not \nsomething that we would distribute without compulsory process. \nOn the obstruction charges, many of the facts I included in that first \nproffer were hypothesized based upon our discussions and the \nagents' observations of Ms. Groff We will need to interview her \nto confirm the accuracy of those facts. On a second count, we \ncould rely on the incident where Mr. Epstein's private investigators \nfolloweclia father, forcing him off the road. Or, if there is \nsomething more recent related to any grand jury subpoenas, we \ncould consider that. \nHope that helps. \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \n*****************••**** \n******** * ********* * ************ \n**•** \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only for \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International LLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly prohibited \nUS_Atty_Cor_0041 \nEFTA00235367\n", "char_count": 1743}, {"efta_number": "EFTA00235326", "page_number": 42, "text_content": "and may be unlawful. If you have received this \ncommunication in error, please notify us immediately by \nreturn e-mail or by e-mail to postmaster@ldrldand.com, and \ndestroy this communication and all copies thereof \nincluding all attachments. \n************** ***** *tit \n******** \n********* \n* ************ \n070918 12.22 pm Plea Agreement 1512 counts.wpd \nor \nYd. \nI \nUS_Atty_Cor_0042 \nEFTA00235368\n", "char_count": 399}, {"efta_number": "EFTA00235326", "page_number": 43, "text_content": ";11 1:= \n1.00v> \n09/18/2007 09:14 AM \nFeta/11OW \nTo \"Jay Lefkowitz\" \ncc \nbcc \nSubject RE: Draft Agreements? \n',iikohte \nt're \nHi Jay —1 know that the U.S. Attorney will not go below 18 \nmonths of prisonnail time (and I would strongly oppose the \nsuggestion). \ntI-\nAssistant U.S. Attorn\nWest Palm Beac t \n33 01 \n09(18/2007 08:44 AM \nTo-Jay Letkowitz\" \n(MMIIMEM \nco \nSubMcDrsft Agreements? \nHi Jay - I was hoping there would be things for me to read this \nmorning, but I will try to remain patient. \nI believe there are only two types of agreements that would apply \nto this case: (1) a plea agreement to a federal charge or charges; \nUS_Atty_Cor_0043 \nEFTA00235369\n", "char_count": 664}, {"efta_number": "EFTA00235326", "page_number": 44, "text_content": "WOW' \n09/18/2007 01:23 PM \nTo \"Jay Lefkowftz\" MEMO= \ncc \nbce \nSubject RE Drag Agreements? \nHi Jay — I think that you are referring to USSG 1B1.9, which \ndoesn't apply to Class A misdemeanors. If you have some other \nbasis, please let me know. \nCould you share the attached draft with your colleagues. It is in \nkeeping with what.. communicated to me was the operative \n\"deal.\" The U.S. Attorney hasn't had a chance to review all of the \nlanguage, but agrees with it in principle. The only thing we haven' \nt been able to discuss is the highlighted language regarding the \nstate sentence. I believe that takes care of your client's concern \nabout having to serve \"duplicate\" time in the state, and our concern \nabout getting the state guilty plea wrapped up at the beginning \nrather than years down the road. \nn\nwill both be available at 2:00. You can reach us at \nifil One of my suggestions is going to be (again) that \nwe all sit down together in the same room, including.. and/or \nso we can hash out the still existing issues and get a signed \ndocument \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \nUS_Atty_Cor_0044 \nEFTA00235370\n", "char_count": 1139}, {"efta_number": "EFTA00235326", "page_number": 45, "text_content": "a \nSAFLS\\)\" \nSent: 09/18/2007 12:43 PM AST \nTo: Jay Le&owitz \nSubject: RE: Draft Agreements? \nHi Jay - It looks like I will be here all afternoon, but earlier is \nbetter than later. There are a number of issues with your version, \nbut one that you can look at before our call is the calculation of the \nguidelines on the 1512(d) counts. The cross-reference to 2X3.1 \napplies, which then takes us to 2G1.3. Giving Mr. Epstein the \nbenefit of the doubt (that they would treat this as though there were \nonly one victim), he would have a base offense level of 24, plus 2 \nfor a commercial sex act, totaling 26. Returning to 23O.1, we \nwould subtract 6 levels and subtract another 3 levels for acceptance \nfor a total offense level of 17. With criminal history category of I, \nthat results in 24 to 30 months, which is in Zone D. \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \nUS_Atty_Cor_0045 \nEFTA00235371\n", "char_count": 910}, {"efta_number": "EFTA00235326", "page_number": 46, "text_content": "as \n! I\n09/18/2007 02:53 \nPM \nTo Jay Lelkowite \ncc \nbcc \nSubject Factual proffer \nHi Jay — I didn't want us to get sidetracked during the conference \ncall. I want to make sure that \ne a fai \nbasis for \n\"harassment.\" Forcibly flying \nand \nsomewhere else is \na different 1512 offense with a 10 year cap. This is the factual \nproffer that I drafted up earlier this afternoon, to give you an idea \nof what it would look like. \nWhen I include a factual proffer in a plea agreement, I usually use \nprefatory language like: The parties agree that, had this case \nproceeded to trial, the United States would have proven \nthe following facts beyond a reasonable doubt, and that \nthe following facts are true and correct and are sufficient \nto support a plea of guilty . \n<<Epstein Plea Proffer.doc>> \nI-\nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \nSSSAMOSABILEDIWIPAI\n0-EgatEslgeEtragnamblvesLby user\n' \ni\nregmmal \nIsa6/2 \n07 •11:55'.>» \nU S_Atty_Co r_O 046 \nEFTA00235372\n", "char_count": 971}, {"efta_number": "EFTA00235326", "page_number": 47, "text_content": "UNITED STATES vs. JEFFREY EPSTEIN \nPLEA PROFFER \nOn August 21, 2007, FBI Special Agents \nand a \nINE. \ntraveled to the home of Lesley Groff to serve her with a federal grand jury \nsubpoena in connection with an investigation pending in the Southern District of Florida. \nMs. Groff works as the personal assistant of the defendant. Ms. Groff began speaking \nwith the agents and then excused herself to go upstairs to check on her sleeping child. \nWhile upstairs, Ms. Groff telephoned the defendant Jeffrey Epstein, and informed him \nthat the FBI agents were at her home. Mr. Epstein instructed Ms. Groff not to speak with \nthe agents and reprimanded her for allowing them into her home. Mr. Epstein applied \npressure to keep Ms. Groff from complying with the grand jury subpoena that the agents \nhad served upon her. In particular, Mr. Epstein warned Ms. Groff against turning over \ndocuments and electronic evidence responsive to the subpoena and pressured her to delay \nher appearance before the federal grand jury in the Southern District of Florida. \nThis conversation occurred when Mr. Epstein was aboard his privately owned \ncivilian aircraft in Miami in the Southern District of Florida. His pilot had filed a flight \nplan showing that the parties were about to return to Teterboro, New Jersey. After the \nconversation with Ms. Groff, Mr. Epstein became concerned that the FBI would by to \nserve his traveling companion, \n, with a similar grand jury subpoena. In \nfact, the agents were preparing to serve Ms. \nwith a target letter when the \nflight landed in Teterboro. Mr. Epstein then re-directed his airplane, making the pilot file \na new flight plan to travel to the U.S. Virgin Islands instead of the New York City area, \nthereby keeping the Special Agents from serving the target letter on--. \nUS_Atty_Cor_0047 \nEFTA00235373\n", "char_count": 1835}, {"efta_number": "EFTA00235326", "page_number": 48, "text_content": "During the course of that flight, the defendant verbally harassed Ms. a, \nharassing and pressuring her not to cooperate with the grand jury's investigation, thereby \nhindering and dissuading her from reporting the commission of a violation of federal law \nto a law enforcement officer, namely, Special Agents of the FBI. \nUS_Atty_Cor_0048 \nEFTA00235374\n", "char_count": 353}, {"efta_number": "EFTA00235326", "page_number": 49, "text_content": "(3,\nUNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA \nCase No. \nUNITED STATES OF AMERICA \nvs. \nJEFFREY EPSTEIN, \nDefendant. \nPLEA AGREEMENT \n• \nThe United States Attorney for the Southern District of Florida (\"the United \nStates\"), and Jeffrey Epstein (hereinafter referred to as the \"defendant\") enter into the \nfollowing agreement: \nI. \nThe defendant agrees to plead guilty to a two-count Information which \ncharges the defendant as follows. Count I charges that the defendant intentionally \nharassed another person, that is, ■., in an attempt to delay, prevent, and dissuade ■. \nfrom attending or testifying in an official proceeding, that is a Federal Grand Jury \nappearance in the Southern District of Florida, in violation of Title 18, United States \nCode, Sections 1512(d)(2) and 2; and Count 2 charges that the defendant intentionally \nharassed another person, that is, \n., in an attempt to delay, prevent, and dissuade.. \nfrom reporting to a law enforcement officer of the United States the commission of a \nfederal offense; in violation of Title 18, United States Code, Sections 1512(dX2) and 2. \n2. \nThe defendant agrees and understands that the above charges involve his \nconduct, and the conduct of others, between in and around early 2001 through in and \nUS_Atty_Cor_0049 \nEFTA00235375\n", "char_count": 1310}, {"efta_number": "EFTA00235326", "page_number": 50, "text_content": "a \naround September 2007 involving a conspiracy to solicit minors to engage in prostitution \nand to travel in interstate commerce to engage in illicit sexual conduct. _This agreement \nresolves the federal criminal liability of the defendant and any co-conspirators in the \nSouthern District of Florida growing out of any criminal conduct by those persons known \nto the United States Attorney's Office for the Southern District of Florida as of the date of \nthis plea agreement, including but not limited to the above-described scheme. \n3. \nThe United States agrees that, upon entry of the defendant's guilty plea, its \nGrand Jury investigation will be suspended, and all pending Grand Jury subpoenas will be \nheld in abeyance unless and until the defendant violates any term of this agreement, as \nexplained in paragraph 19, infra. The defendant likewise agrees to withdraw his pending \nmotion to intervene and to quash certain grand jury subpoenas. The defendant further \nagrees that the current custodian of certain computer equipment shall maintain that \nevidence inviolate until all of the terms of this agreement have been satisfied. \n4. \nThe defendant is aware that the sentence will be imposed by the Court after \nconsidering the Federal Sentencing Guidelines and Policy Statements (hereinafter \n\"Sentencing Guidelines\"). The defendant acknowledges and understands that the Court \nwill compute an advisory sentence under the Sentencing Guidelines and that the \napplicable guidelines will be determined by the Court relying in part on the results of a \nPre-Sentence Investigation by the Court's probation office, which investigation will \ncommence after the guilty plea has been entered. The defendant is also aware that, under \ncertain circumstances, the Court may depart from the advisory sentencing guideline range \nthat it has computed, and may raise or lower that advisory sentence under the Sentencing \nGuidelines. The defendant is further aware and understands that the Court is required\n... [truncated, 2311 chars — for the full page use /api/corpus/document/EFTA00235326/50 or ?id=EFTA00235326&page=50]", "char_count": 2311}, {"efta_number": "EFTA00235326", "page_number": 51, "text_content": "o r \nsevere than the Sentencing Guidelines' advisory sentence. Knowing these facts, the \ndefendant understands and acknowledges that the Court has the authority to impose any \nsentence within and up to the statutory maximum authorized by law for the offenses \nidentified in paragraph 1 and that the defendant may not withdraw the plea solely as a \nresult of the sentence imposed. \n5. \nThe defendant further understands and acknowledges that, as to each of \nCounts 1 and 2 of the Information, the Court may impose a statutory maximum term of \nimprisonment of up to one (1) year, to be followed by a term of supervised release of up \nto a maximum of one (1) year. In addition to terms of imprisonment and supervised \nrelease, the Court may impose a fine of up to $100,000 as to each count. \n6. \nThe defendant further understands and acknowledges that, in addition to \nany sentence imposed under paragraph 3 of this Agreement, a special assessment in the \namount of $50 will be imposed on the defendant, which must be paid at or before the time \nof sentencing. \n7. \nThe defendant understands that the Court will order that he must pay full \nrestitution to all victims of the offense to which he is pleading guilty. The defendant \nunderstands that the amount of restitution owed to each victim will be determined at or \nbefore sentencing. \n8. \nThe parties agree to jointly recommend that the defendant receive a \nsentence of eighteen (18) months' imprisonment, to be followed by two (2) years of \nsupervised release; and a fine of $200,000. \nThe parties' further agree to jointly \nrecommend that the Court impose one year of home confinement as a special condition of \nsupervised release. \n9. \nThe defendant agrees that, if any of the victims identified in the federal \ninvestigation file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the \njurisdiction of the U.S. District Court for the Southern District of Florida over his person \n3 \nUS_Atty_Cor_0051 \nEFTA00235377\n", "char_count": 1984}, {"efta_number": "EFTA00235326", "page_number": 52, "text_content": "and/or the subject matter, and the defendant will not contest that the identified victims are \npersons who, while minors, were victims of violations of Title 18, United States Code, \nSections(s) 2422 and/or 2423. The United States agrees to provide the defendant's \nattorneys with a list of the identified victims, which will not exceed forty, after the \ndefendant has signed this agreement and has been sentenced. The United States further \nagrees to make a motion with the United States District Court for the Southern District of \nFlorida for the appointment of a guardian ad litem for the identified victims and the \ndefendant's counsel may contact the identified victims through that guardian. \n10. \nThe defendant further understands and acknowledges that he must \nundertake certain actions with the State Attorney's Office for the 15th Judicial Circuit in \nand for Palm Beach County (hereinafter, \"State Attorney's Office\") in order to satisfy the \nUnited States' federal interest in the investigation and prosecution of his offenses, in \n0\n --\n/ \naccordance with the Justice Department's Petite policy. \nEpstein understands and \nacknowledges that the United States Attorney has no authority to require the State \nAttorney's Office to abide by any terms of this Agreement. Epstein understands that it is \nhis obligation to undertake discussion with the State Attorney's Office to ensure \ncompliance with these procedures. \n11. \nIn addition to entering a guilty plea in the instant case, the defendant agrees \nto plead guilty to an Information filed by the Palm Beach County State Attorney's Office \ncharging an offense for which the defendant must register as a sex offender, that is, \nsolicitation of minors to engage in prostitution, in violation of Fl. Stat. 796.03. The \ndefendant must enter this guilty plea before he is sentenced on the federal offenses. \n12. \nThe defendant agrees that he and the Palm Beach County State Attorney's \nOffice will make a joint, binding recommendation that \n... [truncated, 2243 chars — for the full page use /api/corpus/document/EFTA00235326/52 or ?id=EFTA00235326&page=52]", "char_count": 2243}, {"efta_number": "EFTA00235326", "page_number": 53, "text_content": "federal prison. Those sentences may run concurrently with the federal sentence imposed \npursuant to this agreement. [NB: The other option is: The defendant and the Palm \nBeach County State Attorney's Office shall make a joint, binding recommendation \nthat the Court impose a sentence of at least sixty (60) months' probation, which will \ninclude at least twelve (12) months of community control/home confinement to be \nserved upon the defendant's release from federal prison.] \n13. \nThe defendant agrees to waive all challenges to the Information filed by the \nState Attorney's Office and to waive the right to appeal his conviction and sentence in the \nstate court. \n14. \nThe defendant agrees to provide to the U.S. Attorney's Office copies of all \nproposed agreements with the Palm Beach County State Attorney's Office prior to \nentering into those agreements. \n15. \nThe defendant agrees that the timely completion of these actions is material \nto this agreement and is supported by independent consideration and that a breach of any \none of these conditions allows the United States to elect to terminate the agreement and to \ninvestigate and prosecute Epstein for any and all federal offenses. \n16. \nThe United States reserves the right to inform the Court and the probation \noffice of all facts pertinent to the sentencing process, including all relevant information \nconcerning the offenses committed, whether charged or not, as well as concerning the \ndefendant and the defendant's background, and to respond to any questions from the \nCourt and the Probation Office and to any misstatements of fact or law. Subject only to \nthe 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 \nquality and quantity of punishment. \n17. \nThe defendant is aware that the sentence has not yet been determined by the \nCourt. The defendant also is aware that any estimate of the probable sentencin\n... [truncated, 2046 chars — for the full page use /api/corpus/document/EFTA00235326/53 or ?id=EFTA00235326&page=53]", "char_count": 2046}, {"efta_number": "EFTA00235326", "page_number": 54, "text_content": "sentence that the defendant may receive, whether that estimate comes from the \ndefendant's attorney, the government, or the probation office, is a prediction, not a \npromise, and is not binding on the government, the probation office or the Court. The \ndefendant understands further that any recommendation that the government makes to the \nCourt as to sentencing, whether pursuant to this agreement or otherwise, is not binding on \nthe Court and the Court may disregard the recommendation in its entirety. The defendant \nunderstands and acknowledges, as previously acknowledged in paragraph 4 above, that \nthe defendant may not withdraw his plea based upon the Court's decision not to ar_rept a \nsentencing recommendation made by the defendant, the government, or a \nrecommendation made jointly by both the defendant and the government. \n18. \nWAIVER OF RIGHT TO APPEAL AND COLLATERALLY \nATTACK THE SENTENCE. 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 \nplea agreement, the defendant hereby waives all rights conferred by Section 3742 to \nappeal any sentence imposed, including any restitution order, or to appeal the manner in \nwhich the sentence was imposed, unless the sentence exceeds the maximum permitted by \nstatute. The defendant further voluntarily and expressly waives, to the maximum extent \npermitted by federal law, the right to collaterally attack his sentence in any \npost-conviction proceeding, including a motion on any ground brought under 28 U.S.C. § \n2254, 28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18 U.S.C. § 3771. The defendant further \nunderstands that nothing in this agreement shall affect the government's right and/or duty \nto appeal as set forth in Tide 18, United States Code, Section 3742(b). However, if the \nUnited States appeals the defendant's sentence pursuant to Section 37\n... [truncated, 2231 chars — for the full page use /api/corpus/document/EFTA00235326/54 or ?id=EFTA00235326&page=54]", "char_count": 2231}, {"efta_number": "EFTA00235326", "page_number": 55, "text_content": "agreement with his attorney. \n19. \nIf the defendant fails in any way to fulfill each one of his obligations under \nthis Plea Agreement, the United States, and only the United States, may elect to be \nreleased from its commitments under this Plea Agreement. If the United States elects to \nvoid the Plea Agreement because of a breach by the defendant, then the United States \nagrees not to use the defendant's guilty plea against him. However, the United States \nmay prosecute the defendant for any and all Federal crimes that he has committed related \nto this case and may seek any sentence for such crimes up to and including the statutory \nmaximums. The defendant expressly waives any statute of limitations defense and any \nconstitutional or statutory speedy trial defense to such a prosecution, except to the extent \nthat such a defense exists as of the date he signs this Plea Agreement. Finally, the \ndefendant understands that his violation of the terms of this Plea Agreement wou►d not \nentitle him to withdraw his guilty plea. \n20. \nThis is the entire agreement and understanding between the United States \nand the defendant. \nThere are no other agreements, promises, representations, or \nunderstandings. \nDate:  \n \nBy:  \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nDate:  \n \nBy:  \nJEFFREY EPSTEIN, DEFENDANT \nDate:  \n \nBy:  \n7 \nUS_Atty_Cor_0055 \nEFTA00235381\n", "char_count": 1370}, {"efta_number": "EFTA00235326", "page_number": 56, "text_content": "3 \nM=US60 \n1.90n \n0911912007 10:39 AM \nTo 'Jay Lefkcwitz' \ncc \nboc \nSubject RE: Draft Agreements? \nHi Jay — Can you send me an update on where we arc? I assume that \neveryone will be off on Friday, 30 \nwe need to have a final agreement by \ntomorrow so I can set up an arraignment on Monday. twill need to get \nthe Information approved, file it with the Court, get a judge assigned, \nand get us on the calendar for an initial appearance and arraignment. \nThank you. \nMy a/c isn't workin so I am sitting in a different office. You can get \nme at \nor on my cell at \n. Also, if you want \nme to look at BOP regs regarding the camp issue, please let me know. \nArlistant U.S. Attorney \nUS_Atty_Cor_0056 \nEFTA00235382\n", "char_count": 710}, {"efta_number": "EFTA00235326", "page_number": 57, "text_content": "11:1= \n1.0on \n09/19/2007 11:21 AM \nTo \"Jay Lefkowite \ncc \nbce \nSubject RE: Draft Agreements? \n- I don't know the factual basis for the alleged harassment of \nIii\nbecause we have no independent evidence of that. So, \nthe agents need to talk to them and then I can draft up a proposed factual \nproffer. I have sent an e-mail to \nand \nto determine their \navailability. Thanks. \nAssistant U.S. Attorney \nUS_Atty_Cor_0057 \nEFTA00235383\n", "char_count": 431}, {"efta_number": "EFTA00235326", "page_number": 58, "text_content": "bow \n09/19/200711:48 AM \nTo \"Jay Lefkowite \ncc \nbee \nSubject RE: Draft Agreements? \nAlright, that is pretty much what I had written yesterday. Here is my \nsuggestion: \nOn \n7, FBI Special Agents \nand \ntraveled to the home of Lesley Groff to serve \nher with a federal grand jury subpoena in connection with an \ninvestigation pending in the Southern District of Florida. Ms. \nGroff works as the personal assistant of the defendant. Ms. Groff \nbegan speaking with the agents and then excused herself to go \nupstairs to check on her sleeping child. While upstairs, Ms. Groff \ntelephoned the defendant, Jeffrey Epstein, and informed him that \nthe FBI agents were at her home. \nThis conversation occurred when Mr. Epstein was aboard \nhis privately owned civilian aircraft in Miami in the Southern \nDistrict of Florida. His pilot had filed a flight plan towing that \nthe parties were about to return to Teterboro, New Jersey. After \nthe conversation with Ms. Groff, Mr. Epstein became concerned \nwould try to serve his traveling companions, \ngram,\nand \nwith similar \nd ' \nsubpoenas. \nthe agents were preparing to serve Ms. \nand Ms. \nwith target letters when the flight landed in Tete \nro. Mr. \nEpstein then re-directed his airplane, making the pilot file a new \nflight plan to travel to the U.S. Virgin Islands instead of the New \nYork City area, thereby kee in the Specialieits from serving \nthe target letters on Ms. \nand Ms. \n. \nDuring t} a cowseoof that flight\nefendant verbally harassed \nboth Ms. \nand Ms. \nharassing and pressuring \nthem not to cooperate with the grand jury's investigation, thereby \nhindering and dissuading them from reporting the commission of a \nviolation of federal law to law enforcement officers, namely, \nSpecial Agents of the FBI. \nMO\nAttorney \nUS_Atty_Cor_0058 \nEFTA00235384\n", "char_count": 1799}, {"efta_number": "EFTA00235326", "page_number": 59, "text_content": "Messa \nFrom: \n.1(USAFLS1)\" \ndoj.govj \nSent: 09/19/2007 11:18 AM AST \nTo: Jay Lefkowitz \nSubject: RE: Draft Agreements? \nI\n- I chlaloaow the factual basis for the alleged harassment of \nIM and= because we have no independent evidence of that. So, \nthe agents need to talk to them a\nn I ciliate up a proposed factual \nproffer. I have sent an e-mail to= \nand ME to determine their \navailability. Thanks. \n1011. \nAttorney \nUS_Atty_Cor_0059 \nEFTA00235385\n", "char_count": 450}, {"efta_number": "EFTA00235326", "page_number": 60, "text_content": "***** \n*St ****•************ ***************** ******* \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only for \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International LLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly prohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately by \nreturn e-mail or by e-mail to postmaster@leuldand.com, and \ndestroy this communication and all copies thereof, \nincluding all attachments. \n******************************•*********************** \n**•** \nUS_Atty_Cor_0060 \nEFTA00235386\n", "char_count": 775}, {"efta_number": "EFTA00235326", "page_number": 61, "text_content": "Ste. \nIIMISMIl@usdo \n1.9ov> \n09119/2007 01:29 PM \nTo \"Jay Letkowitz\" \ncc \nboa \nSubject Meeting on Monday \nHi Jay — We can start as early as you like on Monday. \nwill \njoin us at 10:00. We can meet here in our offices so I can make \nany necessary changes and get us over to the courthouse. \nEMS \nAssistant U.S. Attorney \nUS_Atty_Cor_0061 \nEFTA00235387\n", "char_count": 351}, {"efta_number": "EFTA00235326", "page_number": 62, "text_content": "r @usdoLgo \n09720O007 03:52 \nPM \n*.. \nTo \"Jay Letkowile < \ncc \n< \nusdo. \nKaren N(USAFL.Slr \nbcc \nSubject Final version of Plea Agreement — EPSTEIN \nHi Jay - I have attached the plea agreement as approved by the \nU.S. Attorney and the proposed information. If your client is going \nto accept the agreement, please let me know by noon tomorrow, so \nthat I can file the Information, get a judicial assignment, and \narrange an arraignment and change of plea for Monday. We also \nwill need to set a time for the agents to interview Ms. =and \nMs. =1.to \nfinalize a factual proffer. \nFollowing the plea, Mr. Epstein will have at least 70 days before \nsentencing plus the time to self-surrender in order to get his affairs \nin order, including entering his guilty pleas to the state charges. \nmentioned that your client is considering returning to our \noriginal offer of just a state plea. If that is the case, the \nnon-prosecution agreement that was provided to you last week will \ncontrol. Again, we will need to receive a signed version by \ntomorrow if that is Mr. Epstein's decision. \nYou can reach me on my cell phone at \nThank you. \n<<070920 3.45 pm Plea Agreement 1512 camts.wpd>> \n<<070919 Information charging I 512.wpd>> \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \n«< Attachment '070020 3.45 tam Plea Agreement 1512 countsmadt \nUS_Atty_Cor_0062 \nEFTA00235388\n", "char_count": 1370}, {"efta_number": "EFTA00235326", "page_number": 63, "text_content": "has been archived by user 'Commonatoreallkirkland-Ellis' on \n'11/2612007 01:16:02'. >>> \n«< Attachment'070flUigsrma0on charging 1512.wod' has been \narchived by user 'CommonStoratirfigridand-Eills' on '11/26/2002. \n41:16:03',>» \nUS_Atty_Cor_0063 \nEFTA00235389\n", "char_count": 259}, {"efta_number": "EFTA00235326", "page_number": 64, "text_content": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA \nCase No. \nUNITED STATES OF AMERICA \nvs. \nJEFFREY EPSTEIN, \nDefendant. \nI\nPLEA AGREEMENT \nThe United States Attorney for the Southern District of Florida (\"the United \nStates\"), and Jeffrey Epstein (hereinafter referred to as the \"defendant\") enter into the \nfollowing agreement: \n1. \nThe defendant agrees to plead guilty to a two-count Information which \ncharges that the defendant intentionally harassed two other persons, that is, \nand \nIn, in an attempt to delay, prevent, and dissuade those persons from reporting to a law \nenforcement officer of the United States the commission of a federal offense; in violation \nof Title 18, United States Code, Sections 1512(dX2) and 2. \n2. \nThe defendant agrees and understands that the above charges involve his \nconduct, and the criminal conduct of others, between in and around early 2001 through in \nand around September 2007. This agreement resolves the federal criminal liability of the \ndefendant and any co-conspirators in the Southern District of Florida growing out of any \ncriminal conduct by those persons known to the United States Attorney's Office for the \nSouthern District of Florida as of the date of this plea agreement. \n1 \nUS_Atty_Cor_0064 \nEFTA00235390\n", "char_count": 1278}, {"efta_number": "EFTA00235326", "page_number": 65, "text_content": "3. \nThe United States agrees that, upon entry of the defendant's guilty plea, its \nGrand Jury investigation will be suspended, and all pending litigation between the parties \nwill be held in abeyance unless and until the defendant violates any term of this \nagreement, as explained in paragraph 18, infra. Both parties agree to maintain their \nevidence inviolate until all of the terms of this agreement have been satisfied. \n4. \nThe defendant is aware that the sentence will be imposed by the Court after \nconsidering the Federal Sentencing Guidelines and Policy Statements (hereinafter \n\"Sentencing Guidelines\"). The defendant acknowledges and understands that the Court \nwill compute an advisory sentence under the Sentencing Guidelines and that the \napplicable guidelines will be determined by the Court relying in part on the results of a \nPre-Sentence Investigation by the Court's probation office, which investigation will \ncommence after the guilty plea has been entered. The defendant is also aware that, under \ncertain circumstances, the Court may depart from the advisory sentencing guideline range \nthat it has computed, and may raise or lower that advisory sentence under the Sentencing \nGuidelines. The defendant is further aware and understands that the Court is required to \nconsider the advisory guideline range determined under the Sentencing Guidelines, but is \nnot bound to impose that sentence; the Court is permitted to tailor the ultimate sentence in \nlight of other statutory concerns, and such sentence may be either more severe or less \nsevere than the Sentencing Guidelines' advisory sentence. Knowing these facts, the \ndefendant understands and acknowledges that the Court has the authority to impose any \nsentence within and up to the statutory maximum authorized by law for the offenses \nidentified in paragraph 1 and that the defendant may not withdraw the plea solely as a \nresult of the sentence imposed. \n5. \nThe defendant further understands and acknowledges that, \n... [truncated, 2224 chars — for the full page use /api/corpus/document/EFTA00235326/65 or ?id=EFTA00235326&page=65]", "char_count": 2224}, {"efta_number": "EFTA00235326", "page_number": 66, "text_content": "to a maximum of one (1) year. In addition to terms of imprisonment and supervised \nrelease, the Court may impose a fine of up to $100,000 as to each count. \n6. \nThe defendant further understands and acknowledges that, in addition to \nany sentence imposed under paragraph 4 of this Agreement, a special assessment in the \namount of $50 will be imposed on the defendant, which must be paid at or before the time \nof sentencing. \n7. \nThe defendant understands that the Court will order that he must pay full \nrestitution to all victims of the offenseS to which he is pleading guilty. The defendant \nunderstands that the amount of restitution owed to each victim will be determined at or \nbefore sentencing. \n8. \nThe parties agree to jointly recommend that the defendant receive a \nsentence of eighteen (18) months' imprisonment, to be followed by one (1) year of \nsupervised release, and a fine of $200,000. \nThe parties' further agree to jointly \nrecommend that the Court impose one year of home confinement as a special condition of \nsupervised release. \n9. \nThe defendant agrees that, if any of the victims identified in the federal \ninvestigation file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the \njurisdiction of the U.S. District Court for the Southern District of Florida over his person \nand/or the subject matter, and the defendant will not contest that the identified victims are \npersons who, while minors, were victims of violations of Title 18, United States Code, \nSections(s) 2422 and/or 2423. The United States agrees to provide the defendant's \nattorneys with a list of the identified victims, which will not exceed forty, after the \ndefendant has signed this agreement and has been sentenced. The United States further \nagrees to make a motion with the United States District Court for the Southern District of \nFlorida for the appointment of a guardian ad litem for the identified victims and the \ndefendant's counsel may contact the identified victims throug\n... [truncated, 2052 chars — for the full page use /api/corpus/document/EFTA00235326/66 or ?id=EFTA00235326&page=66]", "char_count": 2052}, {"efta_number": "EFTA00235326", "page_number": 67, "text_content": "I0. \nThe United States has reached this agreement with the defendant in \nresponse to the defendant's request to globally resolve his state and federal criminal \nliability. To do so, the defendant further understands and acknowledges that he must \nundertake certain actions with the State Attorney's Office for the 15th Judicial Circuit in \nand for Palm Beach County (hereinafter, \"State Attorney's Office\"). \n11. \nIn addition to entering a guilty plea in the instant case, the defendant agrees \nthat, prior to his sentencing on the federal charges, he will plead guilty to an Information \nfiled by the State Attorney's Office charging an offense for which the defendant must \nregister as a sex offender, that is, solicitation of minors to engage in prostitution, in \nviolation of Fl. Stat. 796.03. The defendant agrees that he will waive all challenges to the \nInformation filed by the State Attorney's Office and waive the right to appeal his \nconviction and sentence in the state court. \n12. \nThe defendant agrees that he will make a binding recommendation that the \n15th Judicial Circuit Court impose a sentence of at least eighteen (18) months' \nimprisonment to be followed by at least twelve (12) months of community controVhome \nconfinement to be served upon the defendant's release from federal prison. \nThe \ndefendant further represents that he has had discussions with the State Attorney's Office, \nwhich has agreed to likewise make this recommendation. The sentences imposed by the \n15th Judicial Circuit Court may tun concurrently with the federal sentence imposed \npursuant to this agreement. \n13. \nThe defendant agrees to provide to the U.S. Attorney's Office copies of all \nproposed agreements with the State Attorney's Office prior to entering into those \nagreements. \n14. \nThe defendant agrees that the timely completion of these actions is material \nto this agreement and is supported by independent consideration and that a breach of any \none of these conditions allows the United S\n... [truncated, 2084 chars — for the full page use /api/corpus/document/EFTA00235326/67 or ?id=EFTA00235326&page=67]", "char_count": 2084}, {"efta_number": "EFTA00235326", "page_number": 68, "text_content": "investigate and prosecute the defendant for any and all federal offenses. \n15. \nThe United States reserves the right to inform the Court and the probation \noffice of all facts pertinent to the sentencing process, including all relevant information \nconcerning the offenses committed, whether charged or not, as well as concerning the \ndefendant and the defendant's background, and to respond to any questions from the \nCourt and the Probation Office and to any misstatements of fact or law. Subject only to \nthe 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 \nquality and quantity of punishment. \n16. \nThe defendant is aware that the sentence has not yet been determined by the \nCourt. The defendant also is aware that any estimate of the probable sentencing range or \nsentence that the defendant may receive, whether that estimate comes from the \ndefendant's attorney, the government, or the probation office, is a prediction, not a \npromise, and is not binding on the government, the probation office or the Court. The \ndefendant understands further that any recommendation that the government makes to the \nCourt as to sentencing, whether pursuant to this agreement or otherwise, is not binding on \nthe Court and the Court may disregard the recommendation in its entirety. The defendant \nunderstands and acknowledges, as previously acknowledged in paragraph 4 above, that \nthe defendant may not withdraw his plea based upon the Court's decision not to accept a \nsentencing recommendation made by the defendant, the government, or a \nrecommendation made jointly by both the defendant and the government. \n17. \nWAIVER OF RIGHT TO APPEAL AND COLLATERALLY \nATTACK THE SENTENCE. 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 m\n... [truncated, 2068 chars — for the full page use /api/corpus/document/EFTA00235326/68 or ?id=EFTA00235326&page=68]", "char_count": 2068}, {"efta_number": "EFTA00235326", "page_number": 69, "text_content": "plea agreement, the defendant hereby waives all rights conferred by Section 3742 to \nappeal any sentence imposed, including any restitution order, or to appeal the manner in \nwhich the sentence was imposed, unless the sentence exceeds the maximum permitted by \nstatute. The defendant further voluntarily and expressly waives, to the maximum extent \npermitted by federal law, the right to collaterally attack his sentence in any \npost-conviction proceeding, including a motion on any ground brought under 28 U.S.C. § \n2254, 28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18 U.S.C. § 3771. The defendant further \nunderstands that nothing in this agreement shall affect the government's right and/or duty \nto appeal as set forth in Title 18, United States Code, Section 3742(b). However, if the \nUnited States appeals the defendant's sentence pursuant to Section 3742(b), the defendant \nshall be released from the above waiver of appellate rights. By signing this agreement, \nthe defendant acknowledges that he has discussed the appeal waiver set forth in this \nagreement with his attorney. \n18. \nIf the defendant fails in any way to fulfill each one of his obligations under \nthis Plea Agreement, the United States, and only the United States, may elect to be \nreleased from its commitments under this Plea Agreement. If the United States elects to \nvoid the Plea Agreement because of a breach by the defendant, then the United States \nagrees not to use the defendant's guilty plea against him. However, the United States \nmay prosecute the defendant for any and all Federal crimes that he has committed related \nto this case and may seek any sentence for such crimes up to and including the statutory \nmaximums. The defendant expressly waives any statute of limitations defense and any \nconstitutional or statutory speedy trial defense to such a prosecution, except to the extent \nthat such a defense exists as of the date he signs this Plea Agreement. Finally, the \ndefendant understands that his violation o\n... [truncated, 2202 chars — for the full page use /api/corpus/document/EFTA00235326/69 or ?id=EFTA00235326&page=69]", "char_count": 2202}, {"efta_number": "EFTA00235326", "page_number": 70, "text_content": "and the defendant. \nThere are no other agreements, promises, representations, or \nunderstandings. \nDate:  \n \nBy: \nDate:  \n \nBy:  \nDate:  \n \nBy: \nDate:  \n \nBy: \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nASSISTANT UNITED STATES ATTORNEY \nJEFFREY EPSTEIN, DEFENDANT \nROY BLACK, ESQ. \nATTORNEY FOR DEFENDANT \nGERALD LEFCOURT, ESQ. \nCOUNSEL TO DEFENDANT \n7 \nUS_Atty_Cor_0070 \nEFTA00235396\n", "char_count": 387}, {"efta_number": "EFTA00235326", "page_number": 71, "text_content": "09/20/2007 03:58 PM \nTo 'Jay Leflcowite \nco \nbco \nSubject Epstein plea agreement \nJay — there was one spacing problem with the last version. Here is \nthe final. We have added Roy Black's name to a signature line so \nthat a Florida attorney signs it and we don't have to worry about \nPro Hac Vice motions. if you would prefer Jack Goldberger's \nname, please let me know. \n<<070920 3.45 pm Plea Agreement 1512 counts:wpd» \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \n«< Attachment '070112Q1,454/flleakmantent 1512soamsaipv\nhalbeariarsh\nityneamtntInfilore/IT/Kirkland-Ellis' on \n'11/26/2007 01:16:07, >» \nUS_Atty_Cor_0071 \nEFTA00235397\n", "char_count": 641}, {"efta_number": "EFTA00235326", "page_number": 72, "text_content": "1.9ov' \n09/20/2007 05:35 PM \nTo \"Jay Lefkowite \ncc \nbcc \nSubject RE: Final version of Plea Agreement — El \nTry me on my cell. I will keep it with me. \n. Thanks. \nsis \nL 33401 \nnagusdol.gov> \n05/20/2007 03.82 PM \nTo \ncc \n\\(USAFLST \n\\(USAFLSV \n\\(USAFLST \nSubjecflnal version of Ptea Agreement — EPSTEIN \nUS_Atty_Cor_0072 \nEFTA00235398\n", "char_count": 333}, {"efta_number": "EFTA00235326", "page_number": 73, "text_content": "Hi Jay — I have attached the plea agreement as approved by the \nU.S. Attorney and the proposed information. If your client is going \nto accept the agreement, please let me know by noon tomorrow, so \nthat I can file the Information, get a judicial assignment, and \narrange an arraignment and change of plea for Mondaya also \nwill need to set a time for the agents to interview Ms. EM and \nMs. \nto finalize a factual proffer. \nFollowing the plea, Mr. Epstein will have at least 70 days before \nsentencing plus the time to self-surrender in order to get his affairs \nin order, including entering his guilty pleas to the state charges. \nmentioned that your client is considering returning to our \noriginal offer of just a state plea. If that is the case, the \nnon-prosecution agreement that was provided to you last week will \ncontrol. Again, we will need to receive a signed version by \ntomorrow if that is Mr. Epstein's decision. \n0 \nJ \nYou can reach me on my cell phone at \n«070920 3.46 pm Plea Agreement 1512 counts.wpd» \n«070919 Information charging 1512.wpd>> \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \nThank you. \nUS_Atty_Cor_0073 \nEFTA00235399\n", "char_count": 1158}, {"efta_number": "EFTA00235326", "page_number": 74, "text_content": "MISNSW \nWow' \n09/20/2007 06:43 PM \nTo 'Jay LefkowIte \ncc \nbcc \nSubject RE: Ptee Agreement — EPSTEIN \nJay -- The 18 and 12 has already been agreed to by our office, so \nthat is not a problem. \nOn the issue about IS USC 2255, we seem to be miles apart. Your \nmost recent version not only had me binding the girls to a trust \nfund administered by the state court, but also promising that they \nwill give up their 2255 rights. \nI reviewed the e-mail that I sent you on Sunday with the comments \non some of your other changes. In the context of a non-prosecution \nagreement, the office may be more willing to be specific about not \npursuing charges against others. However, as I stated on Sunday, \nthe Office cannot and will not bind Immigration. \nAlso, your timetable will need to move up significantly. Ass \nsaid in our meeting last week, his office can put together a plea \nagreement, information, and get you all before the judge on a \nchange of plea within a day. \nI am headed out now, but you can get me on my cell or call me \ntomorrow in the office. Thank you. \nNM IMO \n33401 \nSir \nUS_Atty_Cor_0074 \nEFTA00235400\n", "char_count": 1115}, {"efta_number": "EFTA00235326", "page_number": 75, "text_content": "11111111111 \n***** \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmasterOkirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \nUS_Atty_Cor_0075 \nEFTA00235401\n", "char_count": 681}, {"efta_number": "EFTA00235326", "page_number": 76, "text_content": "EFTA00235402\n", "char_count": 13}, {"efta_number": "EFTA00235326", "page_number": 77, "text_content": "that is not a problem. \nOn the issue about 18 USC 2255, we seem to be miles apart. Your \nmost recent version not only had me binding the girls to a trust \nfund administered by the state court, but also promising that they \nwill give up their 2255 rights. \nI reviewed the e-mail that I sent you on Sunday with the comments \non some of your other changes. In the context of a non-prosecution \nagreement, the office may be more willing to be specific about not \npursuing charges against others. However, as I stated on Sunday, \nthe Office cannot and will not bind Immigration. \nAlso, your timetable will need to move up significantly. As \nsaid in our meeting last week, his office can put together a pia \nagreement, information, and get you all before the judge on a \nchange of plea within a day. \nI am headed out now, but you can get me on my cell or call me \ntomorrow in the office. Thank you. \nAssistant U.S. At\nam\ni\nlen \nWest Palm Beach FL 33401 \nMir \nAMC \n1.11111111M \nThanks — Jay \nUS_Atty_Cor_0077 \nEFTA00235403\n", "char_count": 1016}, {"efta_number": "EFTA00235326", "page_number": 78, "text_content": "** ******************* *** ******* ***************** ****** \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmasterekirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \n**** \n****** \n********** \n***** *********** ****************** \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only for \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International LLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly prohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately by \nreturn e-mail or by e-mail to postmaster@kirkland.com, and \ndestroy this communication and all copies thereof, \nincluding all attachments. \n****************************************************** \nUS_Atty_Cor_0078 \nEFTA00235404\n", "char_count": 1467}, {"efta_number": "EFTA00235326", "page_number": 79, "text_content": "09/21/2007 11:49 AM \nTo \ncc \nDoc \nSubject Re: Cal today \nI am happy to talk. \nMy caveat is that in the middle of negotiations, u try \nto avoidundermining my staff by allowing \n\"interlocutorty\" appeals so to speak so I'd want \non the call \nI'll have her set something up. \nAlex \nSent from my SlackBerry Wireless Handheld \ninal Me \n----\nUS_Atty_Cor_0079 \nEFTA00235405\n", "char_count": 366}, {"efta_number": "EFTA00235326", "page_number": 80, "text_content": "11.11111111111IIMMIIIP \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland 6 Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmaster@kirkland.com. \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \nUS_Atty_Cor_0080 \nEFTA00235406\n", "char_count": 685}, {"efta_number": "EFTA00235326", "page_number": 81, "text_content": "Ousdoj.govs-\n09/21/2007 02:12 PM \nTo %ley Legtowite Malian \ncc \nbcc \nSubject Revised Non-Prosecution Agreement \n‘%. \n1 Sink \nI tilit \nHi Jay — Here is my attempt at combining our thoughts. I need to \ntalk to the office about the immigration language before I put it in \nhere. I know that we have not and don't plan to ask immigration to \ndo that, but let me see if they are okay with including it in writing. \nI spent about an hour with a former corporate counsel from a \nhospital who now works here to go over the 2255 language. I think \nthat the attached addresses the concern about having an unlimited \nnumber of claimed victims, without me trying to bind girls whom I \ndo not represent. This language hasn't been approved by the office \nyet, so consider it a draft. \nThese are all the same document, just in different formats. \n<<070921 Epstein Non-Prosecution Agreementwpd>> <<070921 Epstein \nNon-Prosecution Agreementdoc>> <-4070921 Epstein Non-Proseadlon \nAgreementpd*> \nThanks. If you have any immediate thoughts before you leave, \nplease let me know. \nMIMI ME \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \n«< Attachment '070921 Epstein Non-Prosecution Aareement.wpd' has \nbeen archived by user 'CommonStorefIT/Kirkland-Ellis' on '11/26/2007 \n01:17:28'. >>> \n«< Attachment '070921_EPetein Non-Prosecution Aoreementdod has \nteen archived by useriornimatritORKI\nE1102902112(M2.\n01:17:28'. >>> \nUS_Atty_Cor_0081 \nEFTA00235407\n", "char_count": 1438}, {"efta_number": "EFTA00235326", "page_number": 82, "text_content": "011 \n>>> \n<<< Attachment '070921 Epstein Non-Prosecution Aoreementocif hes \nbeen archived by user 'CommonStore/IT/Knkland-Ellis' on '11/2(W2007 \n01:17:29% >» \nUS_Atty_Cor_0082 \nEFTA00235408\n", "char_count": 190}, {"efta_number": "EFTA00235326", "page_number": 83, "text_content": "IN RE: \nINVESTIGATION OF \nJEFFREY EPSTEIN \n/ \nNON-PROSECUTION AGREEMENT \nIT APPEARING that the City of Palm Beach Police Department and the State Attorney's \nOffice for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, the \"State \nAttorney's Office\") have conducted an investigation into the conduct of Jeffrey Epstein \n(hereinafter \"Epstein\"); \nIT APPEARING that the State Attorney's Office has charged Epstein with three counts of \nsolicitation of prostitution, in violation of Florida Statutes Section 796.07; \nIT APPEARING that the United States Attorney's Office and the Federal Bureau of \nInvestigation have conducted their own investigation of the offenses and Epstein's background; \nIT APPEARING that Jeffrey Epstein (hereinafter \"Epstein\") has committed offenses \nagainst the United States from in or around 2001 through in or around October 2005, including: \n(1) \nknowingly and willfully conspiring with others known and unknown to commit an \noffense against the United States, that is, to use a facility or means of interstate or \nforeign commerce to knowingly persuade, induce, or entice minor females to \nengage in prostitution, in violation of Tide 18, United States Code, Section \n2422(b); all in violation of Title 18, United States Code, Section 371; \n(2) \nknowingly and willfully conspiring with others known and unknown to travel in \ninterstate commerce for the purpose of engaging in illicit sexual conduct, as \ndefined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18, \nUnited States Code, Section 2423(b); all in violation of Title 18, United States \nCode, Section 2423(e); \n(3) \nusing a facility or means of interstate or foreign commerce to knowingly persuade, \ninduce, or entice minor females to engage in prostitution; in violation of Title 18, \nUnited States Code, Sections 2422(b) and 2; \n(4) \ntraveling in interstate commerce for the purpose of engaging in illicit sexual \nconduct, as defined in 18 U.S.C. § 2423(f), with minor fema\n... [truncated, 2207 chars — for the full page use /api/corpus/document/EFTA00235326/83 or ?id=EFTA00235326&page=83]", "char_count": 2207}, {"efta_number": "EFTA00235326", "page_number": 84, "text_content": "and obtaining by any means a person, knowing that the person had not attained the \nage of 18 years and would be caused to engage in a commercial sex act as defined \nin 18 U.S.C. § 1591(cXl); in violation of Title 18, United States Code, Sections \n1591(a)(1) and 2; and \nIT APPEARING that Epstein has accepted responsibility for his behavior by his signature \non this Agreement; and \nIT APPEARING, after an investigation of the offenses and Epstein's background, that the \ninterest of the United States pursuant to the Petite policy will be served by the following \nprocedure; \nTHEREFORE, on the authority of R. Alexander Acosta, United States Attorney for the \nSouthern District of Florida, prosecution in this District for these offenses shall be deferred in \nfavor of prosecution by the State of Florida, provided that Epstein abides by the following \nconditions and the requirements of this Agreement set forth below. \nIf the United States Attorney should determine that Epstein has violated any of the \nconditions of this Agreement, then the United States Attorney may at any time initiate \nprosecution against Epstein for any offense. In this case, the United States Attorney will furnish \nEpstein with notice specifying the condition(s) of the Agreement that he has violated. \nAfter timely fulfilling all the terms and conditions of the Agreement, no prosecution for \nthe offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have been the \nsubject of the joint investigation by the Federal Bureau of Investigation and the United States \nAttorney's Office will be instituted in this District, and the charges against Epstein if any, will be \ndismissed. \nTerms of the Agreement: \n1. \nEpstein shall plead guilty (not nolo contendere) to an Information filed by \nthe State Attorney's Office charging Epstein with an offense that requires \nhim to register as a sex offender, that is, the solicitation of minors to \nengage in prostitution, in violation of Florida Statutes\n... [truncated, 2471 chars — for the full page use /api/corpus/document/EFTA00235326/84 or ?id=EFTA00235326&page=84]", "char_count": 2471}, {"efta_number": "EFTA00235326", "page_number": 85, "text_content": "(b) \nfollowing the term of imprisonment, Epstein shall serve twelve \n(12) months of community control. \n3. \nEpstein shall waive all challenges to the Information filed by the State \nAttorney's Office and shall waive the right to appeal his conviction and \nsentence. \n4. \nEpstein shall provide to the U.S. Attorney's Office copies of all proposed \nagreements with the State Attorney's Office prior to entering into those \nagreements. \n5. \nThe United States shall provide Epstein's attorneys with a list of \nindividuals whom it has identified as victims, as defined in 18 U.S.C. § \n2255, after Epstein has signed this agreement and been sentenced. Upon \nthe execution of this agreement, the United States will file a motion with \nthe United States District Court for the Southern District of Florida for the \nappointment of a guardian ad litem for these persons. Epstein's counsel \nmay contact the identified individuals through that guardian. \n6. \nIf any of the individuals referred to in paragraph (5), supra, elect to file \nsuit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction \nof the United States District Court for the Southern District of Florida over \nhis person and/or the subject matter, and Epstein waives his right to \ncontest liability and also waives his right to contest damages up to an \namount as agreed to between the identified victim and Epstein. Epstein's \nsignature on this agreement is not to be construed as an admission of civil \nor criminal liability as to any person whose name does not appear on the \nlist provided by the United States. As to those individuals whose names \nappear on the list provided by the United States, Epstein's signature on \nthis agreement likewise is not to be construed as an admission of any civil \nliability other than that contained in 18 U.S.C. § 2255. \n7. \nEpstein shall enter his guilty plea and be sentenced not later than October \n19, 2007, and shall self-report to begin serving his sentence not later than \nDecember\n... [truncated, 2553 chars — for the full page use /api/corpus/document/EFTA00235326/85 or ?id=EFTA00235326&page=85]", "char_count": 2553}, {"efta_number": "EFTA00235326", "page_number": 86, "text_content": "In consideration of Epstein's agreement to plead guilty and to provide compensation to \nvictims, if Epstein successfully fulfills all of the terms and conditions of this agreement, the \nUnited States also agrees that it will not institute an criminal charges again any potential co-\nco \n• for of Epstein, including \nMI, Lesley Groff, or \nFurther, upon execution of this agreement and a plea agreement with the State \nAttorney's Office, the federal Grand Jury investigation will be suspended, and all pending \nfederal Grand Jury subpoenas will be held in abeyance unless and until the defendant \nviolates any term of this agreement. The defendant likewise agrees to withdraw his \npending motion to intervene and to quash certain grand jury subpoenas. Both parties \nagree to maintain their evidence, including certain computer equipment, inviolate until all \nof the terms of this agreement have been satisfied. \nBy signing this agreement, Epstein asserts and certifies that each of these terms is \nmaterial to this agreement and is supported by independent consideration and that a breach of any \none of these conditions allows the United States to elect to terminate the agreement and to \ninvestigate and prosecute Epstein and any other individual or entity for any and all federal \noffenses. \nBy signing this agreement, Epstein asserts and certifies that he is aware of the fact that the \nSixth Amendment to the Constitution of the United States provides that in all criminal \nprosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further is \naware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court may \ndismiss an indictment, information, or complaint for unnecessary delay in presenting a charge to \nthe Grand Jury, filing an information, or in bringing a defendant to trial. Epstein hereby requests \nthat the United States Attorney for the Southern District of Florida defer such prosecution. \nEpstein agrees and consents that any de\n... [truncated, 3146 chars — for the full page use /api/corpus/document/EFTA00235326/86 or ?id=EFTA00235326&page=86]", "char_count": 3146}, {"efta_number": "EFTA00235326", "page_number": 87, "text_content": "By signing this agreement, Epstein asserts and certifies that the above has been read and \nexplained to him. \nEpstein hereby states that he understands the conditions of this Non-\nProsecution Agreement and agrees to comply with them. \nDated: \nJEFFREY EPSTEIN \nDated: \nGERALD LEFCOURT, ESQ. \nCOUNSEL TO JEFFREY EPSTEIN \nDated: \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \n0 \nPage 5 of 5 \nUS_Atty_Cor_0087 \nEFTA00235413\n", "char_count": 419}, {"efta_number": "EFTA00235326", "page_number": 88, "text_content": "OW21/2007 Ce:42 PM \ntgov> \n09/21/2007 02:45 PM \nYes. I'm here for a while. Thanks. \nVillajaha \n61.110.to\n.e \nWest Palm Beach FL 33401 \nTo 'Jay Letkowite \ncc \nbcc \nSubject RE: Reminder \nMir \nTo'Jay Lefkowltf \n<JLefltowilzakirkiand.com> \nSubjecReminder \nHi Ja — Just a reminder. My home e-mail address is \nThanks. \nVillafaha \nAssistant U.S. Attorney \nUS_Atty_Cor_0088 \nEFTA00235414\n", "char_count": 380}, {"efta_number": "EFTA00235326", "page_number": 89, "text_content": "West Palm Beach, FL 33401 \nUS_Atty_Cor_0089 \nEFTA00235415\n", "char_count": 58}, {"efta_number": "EFTA00235326", "page_number": 90, "text_content": "\"N/lilefane, \n3/111efentpuedo \n1.9 \n09/21/2007 02:54 PM \nTo \"Jay Letkowite < \ncc \nbcc \nSubject RE: Reminder \nHi Jay — I thought there was 5 years' probation with 18 months in \njail followed by 12 months' home confinement. I only see 12 \nmonths incarceration, 12 months community control, with 6 of \nthose months in jail, which would result in only 6 months' home \nconfinement. Am I missing something? Thanks. \nAssistant U.S. Atis\nm\no \nWest Palm Beac FL 33401 \nwitasSIMISSIIMIS \nsols \nems \nUSAFLs \n09/21/2007 02:42 PM \nTo\"Jay Letkowite \n<J1elkowlizipirkland ccen> \nCO \nSubJecRemlnder \nHi Ja • — Just a reminder. My home e-mail address is \nThanks. \nUS_Atty_Cor_0090 \nEFTA00235416\n", "char_count": 678}, {"efta_number": "EFTA00235326", "page_number": 91, "text_content": "4.1.. Villafaffa \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \nUS_Atty_Cor_0091 \nEFTA00235417\n", "char_count": 101}, {"efta_number": "EFTA00235326", "page_number": 92, "text_content": "Merle C. \nWow' \n09/21/2007 02:55 PM \nTo \"Jay Leikoseite <JLetkovalzepdrkland.coo \ncc \nbcc \nSubject Integration Question \nHi Jay — I talked ton' \nabout the immigration language you \nwanted to include. He said absolutely not, we don't include that in \nany of our agreements. \nNMI \nVillafarta \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \nUS_Atty_Cor_0092 \nEFTA00235418\n", "char_count": 374}, {"efta_number": "EFTA00235326", "page_number": 93, "text_content": "'Acosta, Alex XUSAFLST \ncAlexAcoMeOusdotgov,\n09232007 1223 PM \ncc \n<Andrew.Loune2@usck \nSAFLSI\" \nbcc \nSubject Re: Jaffrey Epstein - confidential \nApologies - a. Call on our side. \nJay - marie will get back to you. \nSent from my BlackBerry Wireless Handheld \n \nOriginal Message \nFrom: Acosta, Alex (USAFLS) <AAcosta@usa.doj.gov> \nTo: 'JLefkowitzfikirkland.come \nCC: \n<Andrew.Lourie2@usdoj.gov>: \n. (USAFLS) \na ana usa. o .gov> \nSent: Sun Sep 23 12:22:46 2007 \nSubject: Re: Jeffrey Epstein - confidential \nCan we do a conf call? \nSent from my BlackBerry Wireless Handheld \n \nOriginal Message \nev> \nUS_Atty_Cor_0093 \nEFTA00235419\n", "char_count": 627}, {"efta_number": "EFTA00235326", "page_number": 94, "text_content": "0 \nUS_Atty_Cor_0094 \nEFTA00235420\n", "char_count": 34}, {"efta_number": "EFTA00235326", "page_number": 95, "text_content": "3 \n(3 \nUS_Atty_Cor_0095 \nEFTA00235421\n", "char_count": 38}, {"efta_number": "EFTA00235326", "page_number": 96, "text_content": "• \n1 \n• \nt \nUS_Atty_Cor_0096 \nEFTA00235422\n", "char_count": 43}, {"efta_number": "EFTA00235326", "page_number": 97, "text_content": "OnW \n09/23/2007 04:04 PM \nTo \"Jay Lefkowite \ncc \"AM Shah\" <est \nC. (usAns)\" \nu \nbcc \nSubject Re: Draft Agreement \nHere is the most recent version. I noticed that the font size kept \nchanging throughout, so I put it all in Times New Roman 13pt. I \nam attaching in Word Perfect, Word, and PDF. \n-- Original Message — \nIPSIMINIM \n \nina4101.111P0, 0\".W.40.!?yejlt4,14 \n- \n• \n' \n• \n- \n. \nallaggris\n111111101. 11. 11111. 1\"\nMilleal \nUS_Atty_Cor_0097 \nEFTA00235423\n", "char_count": 458}, {"efta_number": "EFTA00235326", "page_number": 98, "text_content": "E \nrd Street j New York, NY 10022 \nDirect 1212-446-6460 Fax I \nasheth@lirkland.corn \n*Admission Pending in New York \n[attachment \"20070923 Draft of Epstein Non-Prosecution \nAgreement (without Term 1) (Redlined).doc\" deleted by \nJay Leflcowitz/New York/Kirkland-Ellis] \nMt* \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only for \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International LLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly prohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us Immediately by \nreturn e-mail or by e-mail to postmasta@kinclancLca and \ndestroy this communication'and all copies thereof, \nincluding all attachments. \n***** \ncorn \nment 070. .1c costa Non-Prosecution Agreementdocs has \nbeen archived by user 'CommonStore/IT/Kiridand-Ellis' on '11/26/2007 \n01;19:45% >>> \n«C Attachment '070923 Epstein Non-Prosecution Anreementmdf has \nbeen archived by user 'CommonStore/IT/Kirkland-Ellis' on '11/26/2007 \n01:19:45'. ,» \n.jtshatachrdenaf spdleinlitu -Prosecution\ncc \nt\nb;nflmarQomma\nn MOWN\" \n91:19:46'. >>> \nUS_Atty_Cor_0098 \nEFTA00235424\n", "char_count": 1316}, {"efta_number": "EFTA00235326", "page_number": 99, "text_content": "IN RE: \nINVESTIGATION OF \nJEFFREY EPSTEIN \nNON-PROSECUTION AGREEMENT \nIT APPEARING that the City of Palm Beach Police Department and the State \nAttorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, \nthe \"State Attorney's Office\") have conducted an investigation into the conduct of Jeffrey \nEpstein (hereinafter \"Epstein\"); \nIT APPEARING that the State Attorney's Office has charged Epstein by \nindictment with solicitation of prostitution, in violation of Florida Statutes Section \n796.07; \nIT APPEARING that the United States Attorney's Office and the Federal Bureau \nof Investigation have conducted their own investigation into Epstein's background and \nany offenses committed by Epstein against the United States from in or around 2001 \nthrough in or around October 2005, including: \n(I) \n(2) \n(3) \nknowingly and willfully conspiring with others known and unknown to \ncommit an offense against the United States, that is, to use a facility or \nmeans of interstate or foreign commerce to knowingly persuade, induce, or \nentice minor females to engage in prostitution, in violation of Title 18, \nUnited States Code, Section 2422(b); all in violation of Title 18; United \nStates Code, Section 371; • \nknowingly and willfully conspiring with others known and unknown to \ntravel in interstate commerce for the purpose of engaging in illicit sexual \nconduct, as defined in 18 U.S.C. § 2423(f), with minor females, in violation \nof Title 18, United States Code, Section 2423(b); all in violation of Title 18, \nUnited States Code, Section 2423(e); \nusing a facility or means of interstate or foreign commerce to knowingly \npersuade, induce, or entice minor females to engage in prostitution; in \nviolation of Title 18, United States Code, Sections 2422(b) and 2; \n(4) \ntraveling in interstate commerce for the purpose of engaging in illicit sexual \nPage 1 of 6 \nUS_Atty_Cor_0099 \nEFTA00235425\n", "char_count": 1926}, {"efta_number": "EFTA00235326", "page_number": 100, "text_content": "conduct, as defined in 18 U.S.C. § 2423(f), with minor females; in violation \nof Title 18, United States Code, Section 2423(b); and \n(5) \nknowingly, in and affecting interstate and foreign commerce, recruiting, \nenticing, and obtaining by any means a person, knowing that the person had \nnot attained the age of 18 years and would be caused to engage in a \ncommercial sex act as defined in 18 U.S.C. § 1591(cX1); in violation of \nTitle 18, United States Code, Sections 1591(aX1) and 2; and \nIT APPEARING, after an investigation of the offenses and Epstein's background, \nthat the interest of the United States pursuant to the Petite policy will be served by the \nfollowing procedure; \nTHEREFORE, on the authority of R. Alexander Acosta, United States Attorney \nfor the Southern District of Florida, prosecution in this District for these offenses shall be \ndeferred in favor of prosecution by the State of Florida, provided that Epstein abides by \nthe following conditions and the requirements of this Agreement set forth below. \nIf the United States Attorney should determine, based on information he deems \nreliable, that Epstein has violated any of the conditions of this Agreement, then the United \nStates Attorney may at any time initiate prosecution against Epstein for any offense. In \nthis case, the United States Attorney will furnish Epstein with timely notice specifying the \ncondition(s) of the Agreement that he has violated, and shall initiate its prosecution within \nsixty (60) days' of giving notice of the violation. \nAfter timely fulfilling all the terms and conditions of the Agreement, no \nprosecution for the offenses set out on pages 1 and 2 of this Agreement, nor any other \noffenses that have been the subject of the joint investigation by the Federal Bureau of \nInvestigation and the United States Attorney's Office, nor any offenses that were the \nsubject of the Federal Grand Jury investigation will be instituted in this District, and the \ncharges against Epstein if any, \n... [truncated, 2471 chars — for the full page use /api/corpus/document/EFTA00235326/100 or ?id=EFTA00235326&page=100]", "char_count": 2471}, {"efta_number": "EFTA00235326", "page_number": 101, "text_content": "recommendation that the Court impose a thirty (30) month sentence \nto be divided as follows: \n(a) \n(b) \nEpstein shall begin by serving eighteen (18) months in county \njail for all charges, without any opportunity for withholding \nadjudication or sentencing, and without probation or \ncommunity control in lieu of imprisonment; and \nfollowing the term of imprisonment, Epstein shall serve \ntwelve (12) months of community control. \n3. \nThe terms contained in paragraph 2, supra, do not foreclose Epstein \nand the State Attorney's Office from agreeing to recommend any \nadditional term(s) of probation and/or incarceration. \n4. \nEpstein shall waive all challenges to the Information filed by the \nState Attorney's Office and shall waive the right to appeal his \nconviction and sentence. \n5. \nEpstein shall provide to the U.S. Attorney's Office copies of all \nproposed agreements with the State Attorney's Office prior to \nentering into those agreements. \n6. \nThe United States shall provide Epstein's attorneys with a list of \nindividuals whom it has identified as victims, as defined in 18 U.S.C. \n§ 2255, after Epstein has signed this agreement and been sentenced. \nUpon the execution of this agreement, the United States will file a \nmotion with the United States District Court for the Southern District \nof Florida for the appointment of a guardian ad !item for these \npersons. Epstein's counsel may contact the identified individuals \nthrough that guardian. \n7. \nIf any of the individuals referred to in paragraph (6), supra, elects to \nfile suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the \njurisdiction of the United States District Court for the Southern \nDistrict of Florida over his person and/or the subject matter, and \nEpstein waives his right to contest liability and also waives his right \nto contest damages up to an amount as agreed to between the \nidentified victim and Epstein. Notwithstanding this waiver, as to \nthose individuals whose names appear on the list prov\n... [truncated, 2126 chars — for the full page use /api/corpus/document/EFTA00235326/101 or ?id=EFTA00235326&page=101]", "char_count": 2126}, {"efta_number": "EFTA00235326", "page_number": 102, "text_content": "construed as an admission of any criminal or civil liability other than \nthat contained in 18 U.S.C. § 2255. \n8. \nEpstein's signature on this agreement also is not to be construed as \nan admission of civil or criminal liability or a waiver of any \njurisdictional or other defense as to any person whose name does not \nappear on the list provided by the United States. \n9. \nEpstein shall enter his guilty plea and be sentenced not later than \nOctober 19, 2007, and shall self-report to begin serving his sentence \nnot later than December 10, 2007. \n10. \nEpstein agrees that he will not be afforded any benefits with respect \nto gain time, other than the rights, opportunities, and benefits as any \nother inmate, including but not limited to, eligibility for gain time \ncredit based on standard rules and regulations that apply in the State \nof Florida. At the United States' request, Epstein agrees to provide \nan account of the gain time he earned during his period of \nincarceration. \nEpstein understands that the United States Attorney has no authority to require the \nState Attorney's Office to abide by any terms of this agreement. Epstein understands that \nit is his obligation to undertake discussion with the State Attorney's Office to ensure \ncompliance with these procedures, which compliance will be necessary to satisfy the \nUnited States' interest, pursuant to the Petite policy. \nIn consideration of Epstein's agreement to plead guilty and to provide \ncompensation in the manner described above, if Epstein successfully fulfills all of the \nterms and conditions of this agreement, the United States also agrees that it will not \ninstitute any criminal char esitsin any potential co-conspirator of E tein including but \ng\nnot limited to \nLesley Groff, or \n. Further, \nupon execution of this agreement and a plea agreement with the State Attorney's Office, \nthe federal Grand Jury investigation will be suspended, and all pending federal Grand \nJury subpoenas will be held in abeyance unle\n... [truncated, 2688 chars — for the full page use /api/corpus/document/EFTA00235326/102 or ?id=EFTA00235326&page=102]", "char_count": 2688}, {"efta_number": "EFTA00235326", "page_number": 103, "text_content": "breach of any one of these conditions allows the United States to elect to terminate the \nagreement and to investigate and prosecute Epstein and any other individual or entity for \nany and all federal offenses. \nBy signing this agreement, Epstein asserts and certifies that he is aware of the fact \nthat the Sixth Amendment to the Constitution of the United States provides that in all \ncriminal prosecutions the accused shall enjoy the right to a speedy and public trial. \nEpstein further is aware that Rule 48(b) of the Federal Rules of Criminal Procedure \nprovides that the Court may dismiss an indictment, information, or complaint for \nunnecessary delay in presenting a charge to the Grand Jury, filing an information, or in \nbringing a defendant to trial. Epstein hereby requests that the United States Attorney for \nthe Southern District of Florida defer such prosecution. Epstein agrees and consents that \nany delay from the date of this Agreement to the date of initiation of prosecution, as \nprovided for in the terms expressed herein, shall be deemed to be a necessary delay at his \nown request, and he hereby waives any defense to such prosecution on the ground that \nsuch delay operated to deny him rights under Rule 48(b) of the Federal Rules of Criminal \nProcedure and the Sixth Amendment to the Constitution of the United States to a speedy \ntrial or to bar the prosecution by reason of the running of the statute of limitations for a \nperiod of months equal to the period between the signing of this agreement and the breach \nof this agreement as to those offenses that were the subject of the grand jury's \ninvestigation. Epstein further asserts and certifies that he understands that the Fifth \nAmendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all \nfelonies must be charged in an indictment presented to a grand jury. Epstein hereby \nagrees and consents that, if a prosecution against him is instituted for any offense that was \nthe subject of the gr\n... [truncated, 2233 chars — for the full page use /api/corpus/document/EFTA00235326/103 or ?id=EFTA00235326&page=103]", "char_count": 2233}, {"efta_number": "EFTA00235326", "page_number": 104, "text_content": "By signing this agreement, Epstein asserts and certifies that the above has been \nread and explained to him. Epstein hereby states that he understands the conditions of \nthis Non-Prosecution Agreement and agrees to comply with them. \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nDated: \nDated: \nDated: \nDated: \nBy:morimm----\nASSISTANT U.S. ATTORNEY \nJEFFREY EPSTEIN \nGERALD LEFCOURT, ESQ. \nCOUNSEL TO JEFFREY EPSTEIN \nJACK GOLDBERGER, ESQ. \nATTORNEY FOR JEFFREY EPSTEIN \nPage 6 of 6 \nUS_Atty_Cor_001 04 \nEFTA00235430\n", "char_count": 517}, {"efta_number": "EFTA00235326", "page_number": 105, "text_content": "Jay - \n'Acosta, Alex \nTo \n%(USAFLEAr \n<AlexAcosta& \nMUSAFIST \nedol.gov> \ncc \n09/23/2007 04:33 \nbcc \nPM \nSubject Re: \nI do not mean to be difficult, but our negotiations \nmust take place with the AUSAs assigned to the case. \nand III have discussed this matter at length \nwith me an several others in the office several \ntimes, inclduing today. They have discretion to \nproceed as they believe just and appropriate. \nI will be out of pocket much of monday on travel. I \nknow that you and others will be here and want to make \nIiii \nsure \nt my absence do not cause any delays. \nand \nhave authority to proceed as they, in \ne\nonal opinion, consider best. \nAlex. \nSent from my BlackBerry Wireless Handheld \n \nOriginal Message \nFrom: Jay Lefkowitz \n> \nTo: Acosta, Alex (USA \n< cos a usa. o .gov> \nSent: Sun Sep 23 14:11:57 2007 \n11.111111111111111111111111e \nUS_Atty_Cor_001 05 \nEFTA00235431\n", "char_count": 885}, {"efta_number": "EFTA00235326", "page_number": 106, "text_content": "The information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmaster@kirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \nUS_Atty_Cor_001 06 \nEFTA00235432\n", "char_count": 663}, {"efta_number": "EFTA00235326", "page_number": 107, "text_content": "J.govs• \n09/23/2007 06:52 PM \nTo cJLetkowitz@kitkland.eom> \ncc \nboc \nSubject Revised agreemeM \nHi Jay- Can you look at this? Especially paragraph 7. I think this \ncovers the exclusive remedy concern you had. \n<<070923 Epstein Non-Prosecution Agreement finni.pcii%* \nAVachment '07092a Epstein Non-Prosecution Agreement tinal.odr \nhas been archived by user 'CommonStore/IT/KIddend-Ellis' on \n11/28/2007 01;19:68i, »> \nUS_Atty_Cor_001 07 \nEFTA00235433\n", "char_count": 449}, {"efta_number": "EFTA00235326", "page_number": 108, "text_content": "IN RE: \nINVESTIGATION OF \nJEFFREY EPSTEIN \nNON-PROSECUTION AGREEMENT \nIT APPEARING that the City of Palm Beach Police Department and the State \nAttorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, \nthe \"State Attorney's Office\") have conducted an investigation into the conduct of Jeffrey \nEpstein (hereinafter \"Epstein\"); \nIT APPEARING that the State Attorney's Office has charged Epstein by indictment \nwith solicitation of prostitution, in violation of Florida Statutes Section 796.07; \nIT APPEARING that the United States Attorney's Office and the Federal Bureau of \nInvestigation have conducted their own investigation into Epstein's background and any \noffenses that may have been committed by Epstein against the United States from in or \naround 2001 through in or around September 2007, including: \n(1) \nknowingly and willfully conspiring with others known and unknown to \ncommit an offense against the United States, that is, to use a facility or means \nof interstate or foreign commerce to knowingly persuade, induce, or entice \nminor females to engage in prostitution, in violation of Title 18, United States \nCode, Section 2422(b); all in violation of Title 18, United States Code, Section \n371; \n(2) \nknowingly and willfully conspiring with others known and unknown to travel \nin interstate commerce for the purpose of engaging in illicit sexual conduct, as \ndefined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18, \nUnited States Code, Section 2423(b); all in violation of Title 18, United States \nCode, Section 2423(e); \n(3) \nusing a facility or means of interstate or foreign commerce to knowingly \npersuade, induce, or entice minor females to engage in prostitution; in \nviolation of Title 18, United States Code, Sections 2422(6) and 2; \n(4) \ntraveling in interstate commerce for the purpose of engaging in illicit sexual \nconduct, as defined in 18 U.S.C. § 2423(f), with minor females; in violation \nPage 1 of 6 \nUS_Atty_C\n... [truncated, 2023 chars — for the full page use /api/corpus/document/EFTA00235326/108 or ?id=EFTA00235326&page=108]", "char_count": 2023}, {"efta_number": "EFTA00235326", "page_number": 109, "text_content": "of Title 18, United States Code, Section 2423(b); and \n(5) \nknowingly, in and affecting interstate and foreign commerce, recruiting, \nenticing, and obtaining by any means a person, knowing that. the person had \nnot attained the age of 18 years and would be caused to engage in a \ncommercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title \n18, United States Code, Sections 1591(a)(1) and 2; and \nIT APPEARING, after an investigation of the offenses and Epstein' s background, that \nthe interest of the United States pursuant to the Petite policy will be served by the following \nprocedure; \nTHEREFORE, on the authority of R.. Alexander Acosta, United States Attorney for \nthe Southern District of Florida, prosecution in this District for these offenses shall be \ndeferred in favor of prosecution by the State of Florida, provided that Epstein abides by the \nfollowing conditions and the requirements of this Agreement set forth below. \na \nIMP \nIf the United States Attorney \nshould \ndetermine, based \non \nreliable \nevidence, that Epstein has willfully violated any of the conditions of this Agreement, then \nthe United States Attorney may at any time initiate prosecution against Epstein for any \noffense. In this case, the United States Attorney will furnish Epstein with timely notice \nspecifying the condition(s) of the Agreement that he has violated, and shall initiate its \nprosecution within sixty (60) days' of giving notice of the violation. \nAfter timely fulfilling all the terms and conditions of the Agreement, no prosecution \nfor the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have \nbeen the subject of the joint investigation by the Federal Bureau of Investigation and the \nUnited States Attorney's Office, nor any offenses that were the subject of the Federal Grand \nJury investigation will be instituted in this District, and the charges against Epstein if any, \nwill be dismissed. \nTerms of the Agreement: \n1. \nEpstein shall \n... [truncated, 2477 chars — for the full page use /api/corpus/document/EFTA00235326/109 or ?id=EFTA00235326&page=109]", "char_count": 2477}, {"efta_number": "EFTA00235326", "page_number": 110, "text_content": "be divided as follows: \n(a) \nEpstein shall begin by serving eighteen (18) months in county \njail for all charges, without any opportunity for withholding \nadjudication or sentencing, and without probation or community \ncontrol in lieu of imprisonment; and \n(b) \nfollowing the term of imprisonment, Epstein shall serve twelve \n(12) months of community control. \n3. \nThe terms contained in paragraphs 1 and 2, supra, do not foreclose \nEpstein and the State Attorney's Office from agreeing to plead to any \nadditional charge(s) or from recommending any additional term(s) of \nprobation and/or incarceration. \n4. \nEpstein shall waive all challenges to the Information filed by the State \nAttorney's Office and shall waive the right to appeal his conviction and \nsentence. \n0 \n5. \nEpstein shall provide to the U.S. Attorney's Office copies of all \nproposed agreements with the State Attorney's Office prior to entering \ninto those agreements. \n6. \nThe United States shall provide Epstein's attorneys with a list of \nindividuals whom it has identified as victims, as defined in 18 U.S.C. \n§ 2255, after Epstein has signed this agreement and been sentenced. \nUpon the execution of this agreement, the United States will file a \nmotion with the United States District Court for the Southern District \nof Florida for the appointment of a guardian ad litem for these persons. \nEpstein's counsel may contact the identified individuals through that \nguardian. \n7. \nIf any of the individuals referred to in paragraph (6), supra, elects to \nfile suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the \njurisdiction of the United States District Court for the Southern District \nof Florida over his person and/or the subject matter, and Epstein waives \nhis right to contest liability and also waives his right to contest damages \nup to an amount as agreed to between the identified victim and Epstein, \nso long as the identified victim elects to proceed exclusively under \n18 U.S.C. § 2255, and agrees to w\n... [truncated, 2150 chars — for the full page use /api/corpus/document/EFTA00235326/110 or ?id=EFTA00235326&page=110]", "char_count": 2150}, {"efta_number": "EFTA00235326", "page_number": 111, "text_content": "this waiver, as to those individuals whose names appear on the list \nprovided by the United States, Epstein's signature on this agreement is \nnot to be construed as an admission of any criminal or civil liability \nother than that contained in 18 U.S.C. § 2255. \n8. \nEpstein's signature on this agreement also is not to be construed as an \nadmission of civil or criminal liability or a waiver of any jurisdictional \nor other defense as to any person whose name does not appear on the \nlist provided by the United States. \n9. \nEpstein shall enter his guilty plea and be sentenced not later than \nOctober 26, 2007, and shall self-report to begin serving his sentence not \nlater than January 4, 2008. \n10. \nEpstein agrees that he will not be afforded any benefits with respect to \ngain time, other than the tights, opportunities, and benefits as any other \ninmate, including but not limited to, eligibility for gain time credit \nbased on standard rules and regulations that apply in the State of \nFlorida. At the United States' request, Epstein agrees to provide an \naccount of the gain time he earned during his period of incarceration. \nEpstein understands that the United States Attorney has no authority to require the \nState Attorney's Office to abide by any terms of this agreement. Epstein understands that \nit is his obligation to undertake discussion with the State Attorney's Office to ensure \ncompliance with these procedures, which compliance will be necessary to satisfy the United \nStates' interest, pursuant to the Petite policy. \nIn consideration of Epstein's agreement to plead guilty and to provide compensation \nin the manner described above, i f Epstein successfully fulfills all of the terms and conditions \nof this agreement, the United States also agrees that it will not institute any criminal char es \nco-conspiratorifisein including but not limited to \nLesley Groff, or \nNM. \nFurther, upon execution o this \nagreement and a plea agreement with the State Attorney's Office, the f\n... [truncated, 2643 chars — for the full page use /api/corpus/document/EFTA00235326/111 or ?id=EFTA00235326&page=111]", "char_count": 2643}, {"efta_number": "EFTA00235326", "page_number": 112, "text_content": "By signing this agreement, Epstein asserts and certifies that each of these terms is \nmaterial to this agreement and is supported by independent consideration and that a breach \nof any one of these conditions allows the United States to elect to terminate the agreement \nand to investigate and prosecute Epstein and any other individual or entity for any and all \nfederal offenses. \na \nBy signing this agreement, Epstein asserts and certifies that he is aware of the fact that \nthe Sixth Amendment to the Constitution of the United States provides that in all criminal \nprosecutions the =owl shall enjoy the right to a speedy and public trial. Epstein further \nis aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court \nmay dismiss an indictment, information, or complaint for unnecessary delay in presenting \na charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein \nhereby requests that the United States Attorney for the Southern District of Florida defer such \nprosecution. Epstein agrees and consents that any delay from the date of this Agreement to \nthe date of initiation of prosecution, as provided for in the terms expressed herein, shall be \ndeemed to be a necessary delay at his own request, and he hereby waives any defense to such \nprosecution on the ground that such delay operated to deny him rights under Rule 48(b) of \nthe Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the \nUnited States to a speedy trial or to bar the prosecution by reason of the running of the statute \nof limitations for a period of months equal to the period between the signing of this \nagreement and the breach of this agreement as to those offenses that were the subject of the \ngrand jury's investigation. Epstein further asserts and certifies that he understands that the \nFifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all \nfelonies must be charged in an \n... [truncated, 2396 chars — for the full page use /api/corpus/document/EFTA00235326/112 or ?id=EFTA00235326&page=112]", "char_count": 2396}, {"efta_number": "EFTA00235326", "page_number": 113, "text_content": "a \nBy signing this agreement, Epstein asserts and certifies that the above has been read \nand explained to him. Epstein hereby states that he understands the conditions of this Non-\nProsecution Agreement and agrees to comply with them. \nR. ALEXANDER. ACOSTA \nUNITED STATES ATTORNEY \nDated: \n \nBy: \nASSISTANT U.S. ATTORNEY \nDated: \nDated: \nDated: \nJEFFREY EPSTEIN \nGERALD LEFCOURT, ESQ. \nCOUNSEL TO JEFFREY EPSTEIN \nJACK GOLDBERGER, ESQ. \nATTORNEY FOR JEFFREY EPSTEIN \nPage 6 of 6 \nUS_Atty_Cor_00113 \nEFTA00235439\n", "char_count": 513}, {"efta_number": "EFTA00235326", "page_number": 114, "text_content": "09/23/2007 08:04 PM \nTo \"Jay Loiko?.itz\" < \ncc\nbcc \nSubject RE: Revised agreement \nYes. Where would you like me to call you? \nXUSAnStr \nii\novl \nSent 09/2312607 \nPM AST \nTo: Jay Lefkowitz \nSubject: Revised agreement \nHi Jay — Can you look at this? Especially paragraph 7. I \nthink this covers the exclusive remedy concern you had. \n«070923 Epstein Non-Prosecution Agreement final.pdP'> \n*•**************************************************** \n***** \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only for \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International LLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly prohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately by \nreturn e-mail or by e-mail to postmaster®kirkland.com, and \ndestroy this communication and all copies thereof, \nincluding all attachments. \nUS_Atty_Co r_0011 4 \nEFTA00235440\n", "char_count": 1108}, {"efta_number": "EFTA00235326", "page_number": 115, "text_content": "War,\n0923/2007 08:04 PM \nTo \"Jay Lefkowitz\" siLarkovateaktriciand.ca \ncc \nboc \nSubject RE: Revised agreement \n1 is definitely under 18 still, and I think there Is a second minor. \nThe appointment of the guardian ad Rem is to provide you with a \nmechanism to make contact with the girls and to give them the \nassistance of an independent attorney who represents them (as \nopposed to me, who represents the government). If you are \nwilling to provide the girls with independent counsel, at Mr. \nEpstein's expense (and I get to pick the attorney), that is alright \nwith me. \n111111\n-11\nSent 09/23/2007 06:52 PM AST \nTo: Jay Lefkowitz \nSubject: Revised agreement \nHi Jay - Can you look at this? Especially paragraph 7. I \nthink this covers the exclusive remedy concern you had. \n«070923 Epstein Non-Prosecution Agreement tinal.pdf» \n****************************************************** \n*it** \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only for \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International LLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly prohibited \nand may be =lawful. If you have received this \nUS_Atty_Cor_00115 \nEFTA00235441\n", "char_count": 1351}, {"efta_number": "EFTA00235326", "page_number": 116, "text_content": "communication in error, please notify us immediately by \nreturn e-mail or by e-mail to postmaster@ltirkland.corn, and \ndestroy this communication and all copies thereof, \nincluding all attachments. \n****************************************** \n****** t***•• \nUS_Atty_Cor_00116 \nEFTA00235442\n", "char_count": 290}, {"efta_number": "EFTA00235326", "page_number": 117, "text_content": "Wawa \n09/23/2007 08:37 PM \nTo 'Jay LeOcolMte cl.efkewitz@fdrldand.coe \ncc \nbcc \nSubject RE: \nA trustee means there is a trust that has been \napproved by a court and \nthat the court has appointed a trustee. That doesn't \napply here. I \ncannot bind the girls to a trust. If a guardian is \nappointed, the girls \nelect to use him as their attorney and they all agree \nthat a trust is in \ntheir beat interests, that is their decision, not \nmine. I would not be \nmaking the motion for appointment of the guardian \nunder 17(c) anyway. \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland a Ellis LLP or Kirkland i Ellis International \nLLP. \nUS_Atty_Cor_00117 \nEFTA00235443\n", "char_count": 836}, {"efta_number": "EFTA00235326", "page_number": 118, "text_content": "Unauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmaster@kitkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \nUS_Atty_Cor_00118 \nEFTA00235444\n", "char_count": 387}, {"efta_number": "EFTA00235326", "page_number": 119, "text_content": "\"Villafanan \n09,23/2007 08:58 PM \nTo 'Jay Letkowite <Jletkowitzekirkland.com> \ncc \nbcc \nSubject Epstein agreement \nHi Jay— Here are the revisions that I agree with and those I don't. \nWe have been over paragraph 6 an infinite number of times. It is \nfactually accurate that the list we are going to give you are persons \nwe have identified as victims. If we did not think they were \nvictims, they would have no right to bring suit, regardless of \nwhether your client is willing to waive liability or not. I have not \nbalked about giving your client yet another month to self-surrender, \nso please let us just put this to rest. I changed the amount of time \nfor the US to notify you of breach to take into account the fact that \nthis agreement will not be completed within 30 months of \nexecution (because of the lengthy delay before self-surrender) and \nto give us a 6 month windowin case we discover a violation after \nMr. Epstein is released. \nIdo not care if you want to call the appointed person a\" \nrepresentative\" instead of a guardian, so long as he/she is: (1) a \nlawyer, (2) independent; (3) selected by our Office or a federal \njudge; and (4) paid for by your client or by the federal court. \nI have sent this to Alex for his review. I have asked him to call me \neither late tonight or early tomorrow morning. When I get his \ncomments, I will get back to you, probably tomorrow. \nThank you. \n<<070923 Epstein Non-Prosecution Agreement final v2.pdf>> \nssialiachinganuagauslisatennunith \nlane has been archived by user 'CommonStoie/IT/Kirkland-Ells' on \n'11/26/2007 01:20:2g, >» \nUS_Atty_Cor_00119 \nEFTA00235445\n", "char_count": 1620}, {"efta_number": "EFTA00235326", "page_number": 120, "text_content": "IN RE: \nINVESTIGATION OF \nJEFFREY EPSTEIN \nNON-PROSECUTION AGREEMENT \nIT APPEARING that the City of Palm Beach Police Department and the State \nAttorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, \nthe \"State Attorney's Office\") have conducted an investigation into the conduct of Jeffrey \nEpstein (hereinafter \"Epstein\"); \nIT APPEARING that the State Attorney's Office has charged Epstein by indictment \nwith solicitation of prostitution, in violation of Florida Statutes Section 796.07; \nIT APPEARING that the United States Attorney's Office and the Federal Bureau of \ninvestigation have conducted their own investigation into Epstein's background and any \noffenses that may have been committed by Epstein against the United States from in or \naround 2001 through in or around September 2007, including: \n(1) \nknowingly and willfully conspiring with others known and unknown to \ncommit an offense against the United States, that is, to use a facility or means \nof interstate or foreign commerce to knowingly persuade, induce, or entice \nminor females to engage in prostitution, in violation of Title 18, United States \nCode, Section 2422(b); all in violation of Title 18, United States Code, Section \n371; \n(2) \nknowingly and willfully conspiring with others known and unknown to travel \nin interstate commerce for the purpose of engaging in illicit sexual conduct, as \ndefined in 18 U.S.C. § 2423(0, with minor females, in violation of Title 18, \nUnited States Code, Section 2423(b); all in violation of Title 18, United States \nCode, Section 2423(e); \n(3) \nusing a facility or means of interstate or foreign commerce to knowingly \npersuade, induce, or entice minor females to engage in prostitution; in \nviolation of Title 18, United States Code, Sections 2422(b) and 2; \n(4) \ntraveling in interstate commerce for the purpose of engaging in illicit sexual \nconduct, as defined in 18 U.S.C. § 2423(f), with minor females; in violation \nPage 1 of 6 \nUS_Atty_Co\n... [truncated, 2023 chars — for the full page use /api/corpus/document/EFTA00235326/120 or ?id=EFTA00235326&page=120]", "char_count": 2023}, {"efta_number": "EFTA00235326", "page_number": 121, "text_content": "of Title 18, United States Code, Section 2423(b); and \n(5) \nknowingly, in and affecting interstate and foreign commerce, recruiting, \nenticing, and obtaining by any means a person, knowing that the person had \nnot attained the age of 18 years and would be caused to engage in a \ncommercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title \n18, United States Code, Sections 1591(aX1) and 2; and \nIT APPEARING, after an investigation of the offenses and Epstein's background, that \nthe interest of the United States pursuant to the Petite policy will be served by the following \nprocedure; \nTHEREFORE, on the authority of IL Alexander Acosta, United States Attorney for \nthe Southern District of Florida, prosecution in this District for these offenses shall be \ndeferred in favor of prosecution by the State of Florida, provided that Epstein abides by the \nfollowing conditions and the requirements of this Agreement set forth below. \nIf the United States Attorney should determine, based on reliable evidence, that \nEpstein has willfully violated any of the conditions of this Agreement, then the United States \nAttorney may, within forty (40) months of the execution of this Agreement, provide Epstein \nwith timely notice specifying the condition(s) of the Agreement that he has violated, and \nshall initiate its prosecution on any offense within sixty (60) days' of giving notice of the \nviolation. \nAfter timely fulfilling all the terms and conditions of the Agreement, no prosecution \nfor the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have \nbeen the subject of the joint investigation by the Federal Bureau of Investigation and the \nUnited States Attorney's Office, nor any offenses that were the subject of the Federal Grand \nJury investigation will be instituted in this District, and the charges against Epstein if any, \nwill be dismissed. \nTerms of the Agreement \n1. \nEpstein shall plead guilty (not nob contendere) to an Information \n... [truncated, 2424 chars — for the full page use /api/corpus/document/EFTA00235326/121 or ?id=EFTA00235326&page=121]", "char_count": 2424}, {"efta_number": "EFTA00235326", "page_number": 122, "text_content": "be divided as follows: \n(a) \nEpstein shall begin by serving eighteen (18) months in county \njail for all charges, without any opportunity for withholding \nadjudication or sentencing, and without probation or community \ncontrol in lieu of imprisonment; and \n(b) \nfollowing the term of imprisonment, Epstein shall serve twelve \n(12) months of community control. \n3. \nThe terms contained in paragraphs 1 and 2, supra, do not foreclose \nEpstein and the State Attorney's Office from agreeing to recommend \nany additional charge(s) or any additional term(s) of probation and/or \nincarceration. \n4. \nEpstein shall waive all challenges to the Information filed by the State \nAttorney's Office and shall waive the right to appeal his conviction and \nsentence. \n5. \nEpstein shall provide to the U.S. Attorney's Office copies of all \nproposed agreements with the State Attorney's Office prior to entering \ninto those agreements. \n6. \nThe United States shall provide Epstein's attorneys with a list of \nindividuals whom it has identified as victims, as defined in 18 U.S.C. \n§ 2255, after Epstein has signed this agreement and been sentenced. \nUpon the execution of this agreement, the United States will file a \nmotion with the United States District Court for the Southern District \nof Florida for the appointment of a guardian ad litem for these persons. \nEpstein's counsel may contact the identified individuals through that \nguardian. \n7. \nIf any of the individuals referred to in paragraph (6), supra, elects to \nfile suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the \njurisdiction of the United States District Court for the Southern District \nof Florida over his person and/or the subject matter, and Epstein waives \nhis right to contest liability and also waives his right to contest damages \nup to an amount as agreed to between the identified victim and Epstein, \nso long as the identified victim elects to proceed exclusively under 18 \nU.S.C. § 2255, and agrees to waive any other claim\n... [truncated, 2129 chars — for the full page use /api/corpus/document/EFTA00235326/122 or ?id=EFTA00235326&page=122]", "char_count": 2129}, {"efta_number": "EFTA00235326", "page_number": 123, "text_content": "this waiver, as to those individuals whose names appear on the list \nprovided by the United States, Epstein's signature on this agreement is \nnot to be construed as an admission of any criminal or civil liability \nother than that contained in 18 U.S.C. § 2255. \n8. \nEpstein's signature on this agreement also is not to be construed as an \nadmission of civil or criminal liability or a waiver of any jurisdictional \nor other defense as to any person whose name does not appear on the \nlist provided by the United States. \n9. \nEpstein shall enter his guilty plea and be sentenced not later than \nOctober 26,2007, and shall self-report to begin serving his sentence not \nlater than January 4, 2008. \n10. \nEpstein agrees that he will not be afforded any benefits with respect to \ngain time, other than the rights, opportunities, and benefits as any other \ninmate, including but not limited to, eligibility for gain time credit \nbased on standard rules and regulations that apply in the State of \nFlorida. At the United States' request, Epstein agrees to provide an \naccounting of the gain time he earned during his period of \nincarceration. \n11. \nThe parties anticipate that this agreement will not be made part of any \npublic record. If the United States receives a Freedom of Information \nAct request or any compulsory process commanding the disclosure of \nthe agreement, it will provide notice to Epstein before making that \ndisclosure. \nEpstein understands that the United States Attorney has no authority to require the \nState Attorney's Office to abide by any terms of this agreement. Epstein understands that \nit is his obligation to undertake discussion with the State Attorney's Office to ensure \ncompliance with these procedures, which compliance will be necessary to satisfy the United \nStates' interest, pursuant to the Petite policy. \nIn consideration of Epstein's agreement to plead guilty and to provide compensation \nin the manner described above, if Epstein successfully fulfills all of \n... [truncated, 2442 chars — for the full page use /api/corpus/document/EFTA00235326/123 or ?id=EFTA00235326&page=123]", "char_count": 2442}, {"efta_number": "EFTA00235326", "page_number": 124, "text_content": "in abeyance unless and until the defendant violates any term of this agreement. The \ndefendant likewise agrees to withdraw his pending motion to intervene and to quash certain \ngrand jury subpoenas. Both parties agree to maintain their evidence, including certain \ncomputer equipment, inviolate until all of the terms of this agreement have been satisfied. \nUpon the successful completion of the terms of this agreement, all outstanding grand jury \nsubpoenas shall be deemed withdrawn. \nBy signing this agreement, Epstein asserts and certifies that each of these terms is \nmaterial to this agreement and is supported by independent consideration and that a breach \nof any one of these conditions allows the United States to elect to terminate the agreement \nand to investigate and prosecute Epstein and any other individual or entity for any and all \nfederal offenses. \nBy signing this agreement, Epstein asserts and certifies that he is aware of the fact that \nthe Sixth Amendment to the Constitution of the United States provides that in all criminal \nprosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further \nis aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court \nmay dismiss an indictment, information, or complaint for trateceqsary delay in presenting \na charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein \nhereby requests that the United States Attorney for the Southern District of Fl orida defer such \nprosecution. Epstein agrees and consents that any delay from the date of this Agreement to \nthe date of initiation of prosecution, as provided for in the terms expressed herein, shall be \ndeemed to be a necessary delay at his own request, and he hereby waives any defense to such \nprosecution on the ground that such delay operated to deny him rights under Rule 48(b) of \nthe Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the \nUnited St\n... [truncated, 2892 chars — for the full page use /api/corpus/document/EFTA00235326/124 or ?id=EFTA00235326&page=124]", "char_count": 2892}, {"efta_number": "EFTA00235326", "page_number": 125, "text_content": "By signing this agreement, Epstein asserts and certifies that the above has been read \nand explained to him. Epstein hereby states that he understands the conditions of this Non-\nProsecution Agreement and agrees to comply with them. \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nDated: \nDated: \nDated: \nDated: \nBy Nommor----\nASSISTANT U.S. ATTORNEY \nJEFFREY EPSTEIN \nGERALD LEFCOURT, ESQ. \nCOUNSEL TO JEFFREY EPSTEIN \nLILLYIII SANCHEZ, ESQ. \nATTORNEY FOR JEt4•REY EPSTEIN \nPage 6 of 6 \nUS_Atty_Cor_001 25 \nEFTA00235451\n", "char_count": 519}, {"efta_number": "EFTA00235326", "page_number": 126, "text_content": "Zil=rusdo \nj.gov> \n09/24/2007 09:36 AM \nTo \"Jay Lefkowite <JLefkowilz@kbidend.coi \ncc \nbcc \nSubject RE: Epstein \n11:30 is fine. I am waiting for final edits from \nAlex. Can you send me all of the state agreements? \nMy fax number is below or you can e-mail. Thanks. \nVillafafia \nAssista \n0.S. A tor e \n1m Beac , \n \nOriginal Messa e \nThe information contained in this communication is \nconfidential, may be attorney-client' \nprivileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmasterOkirkland.com, \nUS_Atty_Cor_00126 \nEFTA00235452\n", "char_count": 911}, {"efta_number": "EFTA00235326", "page_number": 127, "text_content": "and \ndestroy this communication and all copies thereof, \nincluding all attachments. \na \nUS_Atty_Cor_001 27 \nEFTA00235453\n", "char_count": 121}, {"efta_number": "EFTA00235326", "page_number": 128, "text_content": "09/24/2007 10:13 AM \nTo \"Jay Lefkowitt <J1entowitz@kirkland.com> \ncc \nbcc \nSubject Epstein agreement as reviewed by the U.S. Atter \nHi Jay - Here is the agreement with Alex's edits. Thank you. \n<<070924 Epstein Non-Prosecution Agreement w Acosta edits v2.pdf>> \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \n«< Attachment '070924 Epstein Non-Prosecution Agreement w Acosta \nedits %/Zoe has been archived by use&\n'CommonStore4T/tarkland-Ellis' onillaWal0.7  01:21:11% >» \nUS_Atty_Cor_001 28 \nEFTA00235454\n", "char_count": 510}, {"efta_number": "EFTA00235326", "page_number": 129, "text_content": "IN RE: \nINVESTIGATION OF \nJEFFREY EPSTEIN \nNON-PROSECUTION AGREEMENT \nIT APPEARING that the City of Palm Beach Police Department and the State \nAttorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, \nthe \"State Attorney's Office\") have conducted an investigation into the conduct of Jeffrey \nEpstein (hereinafter \"Epstein\"); \nIT APPEARING that the State Attorney's Office has charged Epstein by indictment \nwith solicitation of prostitution, in violation of Florida Statutes Section 796.07; \nIT APPEARING that the United States Attorney's Office and the Federal Bureau of \nInvestigation have conducted their own investigation into Epstein's background and any \noffenses that may have been committed by Epstein against the United States from in or \naround 2001 through in or around September 2007, including: \n(1) \nknowingly and willfully conspiring with others known and unknown to \ncommit an offense against the United States, that is, to use a facility or means \nof interstate or foreign commerce to knowingly persuade, induce, or entice \nminor females to engage in prostitution, in violation of Title 18, United States \nCode, Section 2422(b); all in violation of Title 18, United States Code, Section \n371; \n(2) \nknowingly and willfully conspiring with others known and unknown to travel \nin interstate commerce for the purpose of engaging in illicit sexual conduct, as \ndefined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18, \nUnited States Code, Section 2423(b); all in violation of Title 18, United States \nCode, Section 2423(e); \n(3) \nusing a facility or means of interstate or foreign commerce to knowingly \npersuade, induce, or entice minor females to engage in prostitution; in \nviolation of Title 18, United States Code, Sections 2422(b) and 2; \n(4) \ntraveling in interstate commerce for the purpose of engaging in illicit sexual \nconduct, as defined in 18 U.S.C. § 2423(f), with minor females; in violation \nPage 1 of 6 \nUS_Atty_C\n... [truncated, 2024 chars — for the full page use /api/corpus/document/EFTA00235326/129 or ?id=EFTA00235326&page=129]", "char_count": 2024}, {"efta_number": "EFTA00235326", "page_number": 130, "text_content": "of Title 18, United States Code, Section 2423(b); and \n(5) \nknowingly, in and affecting interstate and foreign commerce, recruiting, \nenticing, and obtaining by any means a person, knowing that the person had \nnot attained the age of 18 years and would be caused to engage in a \ncommercial sex act as defined in 18 U.S.C. § 1591(cX1); in violation of Title \n18, United States Code, Sections 1591(a)(1) and 2; and \nIT APPEARING that Epstein seeks to resolve globally his state and federal criminal \nliability and Epstein understands and acknowledges that, in order to do so, he must undertake \ncertain actions with the State Attorney's Office; \nIT APPEARING, after an investigation of the offenses and Epstein's background by \nboth State and Federal law enforcement agencies, and after due consultation with the State \nAttorney's Office, that the interests of the United States, the State of Florida, and the \nDefendant will be served by the following procedure; \nTHEREFORE, on the authority of R. Alexander Acosta, United States Attorney for \nthe Southern District of Florida, prosecution in this District for these offenses shall be \ndeferred in favor of prosecution by the State of Florida, provided that Epstein abides by the \nfollowing conditions and the requirements of this Agreement set forth below. \nIf the United States Attorney should determine, based on reliable evidence, that, \nduring the period of the Agreement, Epstein willfully violated any of the conditions of this \nAgreement, then the United States Attorney may, within ninety (90) days following the \nexpiration of the term of home confinement discussed below, provide Epstein with timely \nnotice specifying the condition(s) of the Agreement that he has violated, and shall initiate its \nprosecution on any offense within sixty (60) days' of giving notice of the violation. \nAfter timely fulfilling all the terms and conditions of the Agreement, no prosecution \nfor the offenses set out on pages 1 and 2 of this Agreement, nor an\n... [truncated, 2623 chars — for the full page use /api/corpus/document/EFTA00235326/130 or ?id=EFTA00235326&page=130]", "char_count": 2623}, {"efta_number": "EFTA00235326", "page_number": 131, "text_content": "minors to engage in prostitution, in violation of Florida Statutes Section \n796.03; \n2. \nEpstein shall make a binding recommendation that the Court impose a \nthirty (30) month sentence to be divided as follows: \n(a) \nEpstein shall be sentenced to eighteen (18) months in county jail \nfor all charges, without any opportunity for withholding \nadjudication or sentencing, and without probation or community \ncontrol in lieu of imprisonment; and \n(b) \nfollowing the term of imprisonment, Epstein shall serve twelve \n(12) months of community control. \n3. \nThe terms contained in paragraphs 1 and 2, supra, do not foreclose \nEpstein and the State Attorney's Office from agreeing to recommend \nany additional charge(s) or any additional term(s) of probation and/or \nincarceration, and do not foreclose a Judge of the 15th Judicial Circuit \nfrom imposing a sentence in excess of the terms set forth above. \n4. \nEpstein shall waive all challenges to the Information filed by the State \nAttorney's Office and shall waive the right to appeal his conviction and \nsentence. \n5. \nEpstein shall provide to the U.S. Attorney's Office copies of all \nproposed agreements with the State Attorney's Office prior to entering \ninto those agreements. \n6. \nThe United States shall provide Epstein's attorneys with a list of \nindividuals whom it has identified as victims, as defined in 18 U.S.C. \n§ 2255, after Epstein has signed this agreement and been sentenced. \nUpon the execution of this agreement, the United States will file a \nmotion with the United States District Court for the Southern District \nof Florida for the appointment of a guardian ad litem for these persons. \nEpstein's counsel may contact the identified individuals through that \nguardian. \n7. \nIf any of the individuals referred to in paragraph (6), supra, elects to \nfile suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the \njurisdiction of the United States District Court for the Southern District \nof Florida over his person and/or th\n... [truncated, 2084 chars — for the full page use /api/corpus/document/EFTA00235326/131 or ?id=EFTA00235326&page=131]", "char_count": 2084}, {"efta_number": "EFTA00235326", "page_number": 132, "text_content": "his right to contest liability and also waives his right to contest damages \nup to an amount as agreed to between the identified victim and Epstein, \nso long as the identified victim elects to proceed exclusively under 18 \nU.S.C. § 2255, and agrees to waive any other claim for damages, \nwhether pursuant to state, federal, or common law. Notwithstanding \nthis waiver, as to those individuals whose names appear on the list \nprovided by the United States, Epstein's signature on this agreement is \nnot to be construed as an admission of any criminal or civil liability \nother than that contained in 18 U.S.C. § 2255. \n8. \nEpstein's signature on this agreement also is not to be construed as an \nadmission of civil or criminal liability or a waiver of any jurisdictional \nor other defense as to any person whose name does not appear on the \nlist provided by the United States. \n9. \nEpstein shall use his best efforts to enter his guilty plea and be \nsentenced not later than October 26, 2007. The United States has no \nobjection to Epstein self-reporting to begin serving his sentence not \nlater than January 4, 2008. \n10. \nEpstein agrees that he will not be afforded any benefits with respect to \ngain time, other than the rights, opportunities, and benefits as any other \ninmate, including but not limited to, eligibility for gain time credit \nbased on standard rules and regulations that apply in the State of \nFlorida. At the United States' request, Epstein agrees to provide an \naccounting of the gain time he earned during his period of \nincarceration. \n11. \nThe parties anticipate that this agreement will not be made part of any \npublic record. If the United States receives a Freedom of Information \nAct request or any compulsory process commanding the disclosure of \nthe agreement, it will provide notice to Epstein before making that \ndisclosure. \nEpstein understands that the United States Attorney has no authority to require the \nState Attorney's Office to abide by any terms of this agr\n... [truncated, 2554 chars — for the full page use /api/corpus/document/EFTA00235326/132 or ?id=EFTA00235326&page=132]", "char_count": 2554}, {"efta_number": "EFTA00235326", "page_number": 133, "text_content": "do so will be a breach of the agreement \nIn consideration of Epstein's agreement to plead guilty and to provide compensation \nin the manner described above, if Epstein successfully fulfills all of the terms and conditions \nof this agreement, the United States also agrees that it will not institute any \n• ' \nis \ntential co-conspiratoggkpstein, including but not limited to \nLesley Groff, or \nMarcinkova. Further, upon execution of this \nagreement and a plea agreement with the State Attorney's Office, the federal Grand Jury \ninvestigation will be suspended, and all pending federal Grand Jury subpoenas will be held \nin abeyance unless and until the defendant violates any term of this agreement The \ndefendant likewise agrees to withdraw his pending motion to intervene and to quash certain \ngrand jury subpoenas. Both parties agree to maintain their evidence, including certain \ncomputer equipment, inviolate until all of the terms of this agreement have been satisfied. \nUpon the successfhl completion of the terms of this agreement, all outstanding grand jury \nsubpoenas shall be deemed withdrawn. \n0 \nBy signing this agreement, Epstein asserts and certifies that each of these terms is \nmaterial to this agreement and is supported by independent consideration and that a breach \nof any one of these conditions allows the United States to elect to terminate the agreement \nand to investigate and prosecute Epstein and any other individual or entity for any and all \nfederal offenses. \nBy signing this agreement, Epstein asserts and certifies that he is aware of the fact that \nthe Sixth Amendment to the Constitution of the United States provides that in all criminal \nprosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further \nis aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court \nmay dismiss an indictment, information, or complaint for unnecessary delay in presenting \na charge to the Grand Jury, filing an informatio\n... [truncated, 3306 chars — for the full page use /api/corpus/document/EFTA00235326/133 or ?id=EFTA00235326&page=133]", "char_count": 3306}, {"efta_number": "EFTA00235326", "page_number": 134, "text_content": "subject of the grand jury's investigation, it may be by way of an Information signed and filed \nby the United States Attorney, and hereby waives his right to be indicted by a grand jury. \nBy signing this agreement, Epstein asserts and certifies that the above has been read \nand explained to him. Epstein hereby states that he understands the conditions of this Non-\nProsecution Agreement and agrees to comply with them. \nR ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nDated: \nDated: \nDated: \nDated: \nBy:\nASSISTANT U.S. ATTORNEY \nJEFFREY EPSTEIN \nGERALD LEFCOURT, ESQ. \nCOUNSEL TO JEFFREY EPSTEIN \nLILLY'. SANCHEZ, ESQ. \nATTORNEY FOR JEFFREY EPSTEIN \nPage 6 of 6 \nUS_Atty_Cor_001 34 \nEFTA00235460\n", "char_count": 694}, {"efta_number": "EFTA00235326", "page_number": 135, "text_content": "To *Jay Letitowite \nco ill\n'Weinberg' <osorrtgeorkinetattnet>, \nwSAR-ScArnallirniliGarcia. \nbcc \nSubject RE: Epstein agreement as reviewed by the U.S. Adorns, \nHi Jay — Sorry for the delay. The U.S. Attorney had a last-minute \nconcern, that I think I fixed (it is in the first \"It Appearing\" clause \nfollowing the list of statutes potentially violated). \nAfter you get the green light, let's discuss the potential \nrepresentative. The person I am thinking of has run a preliminary \nconflicts check and it looks alright. \nAlso, to address Mr. Epstein's concern regarding the list of names, \nI wanted to tell you that I have compiled a list of 34 confirmed \nminors. There are six others, whose names we already have, who \nneed to be interviewed by the FBI to confirm whether they were 17 \nor 18 at the time of their activity with Mr. Epstein. Once those \ninterviews are completed, I can finalize the list of identified \nvictims, which I will put in a formal document that I will maintain \nuntil the time of Mr. Epstein's sentencing. \nAssuming that this agreement is fine, please execute at least three \ncopies, and send one to me by fax and the rest by FedEx. I will \nexecute and send the copies back. \nThank you. \nWE \nUS_Atty_Cor_001 35 \nEFTA00235461\n", "char_count": 1250}, {"efta_number": "EFTA00235326", "page_number": 136, "text_content": "Assistant U.S. Attorney \nWest Palm Beach, FL 33401 \nCSIO\nAMS\" \n®usdoj.gov> \n09/24/2007 10:13 AM \nTo \"Jay Letkowitz\" \n<Thefkowitzgdrkland.cont> \ncc \nSub Epstein agreement as reviewed \nject by the U.S. Attorney \nHi Jay — Here is the agreement with Alex's edits. Thank you. \nUS_Atty_Cor_001 36 \nEFTA00235462\n", "char_count": 305}, {"efta_number": "EFTA00235326", "page_number": 137, "text_content": "<<070924 Epstein Non-Prosecution Agreement w Acosta edits \nv2.pdf>> \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \nW\n824 Final Epstein Non-Prosecution Aoreementpdr \nhes been archived by user 'CommonStore/IT/Kirldend-Elnet on.. \n'11,26/2007 01:22;05% >>> \nUS_Atty_Cor_001 37 \nEFTA00235463\n", "char_count": 294}, {"efta_number": "EFTA00235326", "page_number": 138, "text_content": "IN RE: \nINVESTIGATION OF \nJEFFREY EPSTEIN \nNON-PROSECUTION AGREEMENT \nIT APPEARING that the City of Palm Beach Police Department and the State \nAttorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, \nthe \"State Attorney's Office\") have conducted an investigation into the conduct of Jeffrey \nEpstein (hereinafter \"Epstein\"); \nIT APPEARING that the State Attorney's Office has charged Epstein by indictment \nwith solicitation of prostitution, in violation of Florida Statutes Section 796.07; \nIT APPEARING that the United States Attorney's Office and the Federal Bureau of \nInvestigation have conducted their own investigation into Epstein's background and any \noffenses that may have been committed by Epstein against the United States from in or \naround 2001 through in or around September 2007, including: \n(1) \nknowingly and willfully conspiring with others known and unknown to \ncommit an offense against the United States, that is, to use a facility or means \nof interstate or foreign commerce to knowingly persuade, induce, or entice \nminor females to engage in prostitution, in violation of Title 18, United States \nCode, Section 2422(b); all in violation of Title 18, United States Code, Section \n371; \n(2) \nknowingly and willfully conspiring with others known and unknown to travel \nin interstate commerce for the purpose of engaging in illicit sexual conduct, as \ndefined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18, \nUnited States Code, Section 2423(b); all in violation of Title 18, United States \nCode, Section 2423(e); \n(3) \nusing a facility or means of interstate or foreign commerce to knowingly \npersuade, induce, or entice minor females to engage in prostitution; in \nviolation of Title 18, United States Code, Sections 2422(b) and 2; \n(4) \ntraveling in interstate commerce for the purpose of engaging in illicit sexual \nconduct, as defined in 18 U.S.C. § 2423(i), with minor females; in violation \nPage 1 of 7 \nUS_Atty_C\n... [truncated, 2024 chars — for the full page use /api/corpus/document/EFTA00235326/138 or ?id=EFTA00235326&page=138]", "char_count": 2024}, {"efta_number": "EFTA00235326", "page_number": 139, "text_content": "of Title 18, United States Code, Section 2423(b); and \n(5) \nknowingly, in and affect►ng interstate and foreign commerce, recruiting, \nenticing, and obtaining by any means a person, knowing that the person had \nnot attained the age of 18 years and would be caused to engage in a \ncommercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title \n18, United States Code, Sections 1591(a)(1) and 2; and \nIT APPEARING that Epstein seeks to resolve globally his state and federal criminal \nliability and Epstein understands and acknowledges that, in exchange for the benefits \nprovided by this agreement, he agrees to comply with its terms, including undertaking certain \nactions with the State Attorney's Office; \nIT APPEARING, after an investigation of the offenses and Epstein's background by \nboth State and Federal law enforcement agencies, and after due consultation with the State \nAttorney's Office, that the interests of the United States, the State of Florida, and the \nDefendant will be served by the following procedure; \nTHEREFORE, on the authority of R. Alexander Acosta, United States Attorney for \nthe Southern District of Florida, prosecution in this District for these offenses shall be \ndeferred in favor of prosecution by the State of Florida, provided that Epstein abides by the \nfollowing conditions and the requirements of this Agreement set forth below. \nIf the United States Attorney should determine, based on reliable evidence, that, \nduring the period of the Agreement, Epstein willfully violated any of the conditions of this \nAgreement, then the United States Attorney may, within ninety (90) days following the \nexpiration of the term of home confinement discussed below, provide Epstein with timely \nnotice specifying the condition(s) of the Agreement that he has violated, and shall initiate its \nprosecution on any offense within sixty (60) days' of giving notice of the violation. Any \nnotice provided to Epstein pursuant to this paragraph shall be provide\n... [truncated, 2657 chars — for the full page use /api/corpus/document/EFTA00235326/139 or ?id=EFTA00235326&page=139]", "char_count": 2657}, {"efta_number": "EFTA00235326", "page_number": 140, "text_content": "Terms of the Agreement: \n1. \nEpstein shall plead guilty (not nob contendere) to the Indictment as \ncurrently pending against him in the 15th Judicial Circuit in and for \nPalm Beach County (Case No. 2006-cf-009495AXXXMS) charging \none (1) count of solicitation of prostitution, in violation of Fl. Stat. § \n796.07. In addition, Epstein shall plead guilty to an Information filed \nby the State Attorney's Office charging Epstein with an offense that \nrequires him to register as a sex offender, that is, the solicitation of \nminors to engage in prostitution, in violation of Florida Statutes Section \n796.03; \n2. \nEpstein shall make a binding recommendation that the Court impose a \nthirty (30) month sentence to be divided as follows: \n(a) \nEpstein shall be sentenced to consecutive terms of twelve (12) \nmonths and six (6) months in county jail for all charges, without \nany opportunity for withholding adjudication or sentencing, and \nwithout probation or community control in lieu of \nimprisonment; and \n(b) \nEpstein shall be sentenced to a term of twelve (12) months of \ncommunity control consecutive to his two terms in county jail \nas described in Term 2(a), supra. \n3. \nThis agreement is contingent upon a Judge of the 15th Judicial Circuit \naccepting and executing the sentence agreed upon between the State \nAttorney's Office and Epstein, the details of which are set forth in this \nagreement. \n4. \nThe terms contained in paragraphs 1 and 2, supra, do not foreclose \nEpstein and the State Attorney's Office from agreeing to recommend \nany additional charge(s) or any additional term(s) of probation and/or \nincarceration. \n5. \nEpstein shall waive all challenges to the Information filed by the State \nAttorney's Office and shall waive the right to appeal his conviction and \nsentence. \n6. \nEpstein shall provide to the U.S. Attorney's Office copies of all \nproposed agreements with the State Attorney's Office prior to entering \nPage 3 of 7 \nUS_Atty_Cor_00140 \nEFTA00235466\n", "char_count": 1982}, {"efta_number": "EFTA00235326", "page_number": 141, "text_content": "into those agreements. \n7. \nThe United States shall provide Epstein's attorneys with a list of \nindividuals whom it has identified as victims, as defined in 18 U.S.C. \n§ 2255, after Epstein has signed this agreement and been sentenced. \nUpon the execution of this agreement, the United States, in consultation \nwith and subject to the good faith approval of Epstein's counsel, shall \nselect an attorney representative for these persons, who shall be paid for \nby Epstein. Epstein's counsel may contact the identified individuals \nthrough that representative. \n8. \nIf any of the individuals referred to in paragraph (7), supra, elects to \nfile suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the \njurisdiction of the United States District Court for the Southern District \nof Florida over his person and/or the subject matter, and Epstein waives \nhis right to contest liability and also waives his right to contest damages \nup to an amount as agreed to between the identified individual and \nEpstein, so long as the identified individual elects to proceed \nexclusively under 18 U.S.C. § 2255, and agrees to waive any other \nclaim for damages, whether pursuant to state, federal, or common law. \nNotwithstanding this waiver, as to those individuals whose names \nappear on the list provided by the United States, Epstein's signature on \nthis agreement, his waivers and failures to contest liability and such \ndamages in any suit are not to be construed as an admission of any \ncriminal or civil liability. \n9. \nEpstein's signature on this agreement also is not to be construed as an \nadmission of civil or criminal liability or a waiver of any jurisdictional \nor other defense as to any person whose name does not appear on the \nlist provided by the United States. \n10. \nExcept as set forth in paragraph (8), supra, neither Epstein's signature \non this agreement, nor its terms, nor any resulting waivers or \nsettlements by Epstein are to be construed as admissions or evidence of \ncivil or \n... [truncated, 2428 chars — for the full page use /api/corpus/document/EFTA00235326/141 or ?id=EFTA00235326&page=141]", "char_count": 2428}, {"efta_number": "EFTA00235326", "page_number": 142, "text_content": "later than January 4, 2008. \n12. \nEpstein agrees that he will not be afforded any benefits with respect to \ngain time, other than the rights, opportunities, and benefits as any other \ninmate, including but not limited to, eligibility for gain time credit \nbased on standard rules and regulations that apply in the State of \nFlorida. At the United States' request, Epstein agrees to provide an \naccounting of the gain time he earned during his period of \nincarceration. \n13. \nThe parties anticipate that this agreement will not be made part of any \npublic record. If the United States receives a Freedom of Information \nAct request or any compulsory process commanding the disclosure of \nthe agreement, it will provide notice to Epstein before making that \ndisclosure. \n- \nEpstein understands that the United States Attorney has no authority to require the \nState Attorney's Office to abide by any terms of this agreement Epstein understands that \nit is his obligation to undertake discussions with the State Attorney's Office and to use his \nbest efforts to ensure compliance with these procedures, which compliance will be necessary \nto satisfy the United States' interest. Epstein also understands that it is his obligation to use \nhis best efforts to convince the Judge of the 15th Judicial Circuit to accept Epstein's binding \nrecommendation regarding the sentence to be imposed, and understands that the failure to \ndo so will be a breach of the agreement. \nIn consideration of Epstein's agreement to plead guilty and to provide compensation \nin the manner described above, if Epstein successfully fulfills all of the terms and conditions \nof this agreement, the United States also agrees that it will not institute any cri ' \ntential co-conspirat \n• \n• \nding but not limited to \n, Lesley Groff; or \nFurther, upon execution of this \nagreement and a plea agreement with the State Attorney's Office, the federal Grand Jury \ninvestigation will be suspended, and all pending federal Grand Jury subpo\n... [truncated, 2747 chars — for the full page use /api/corpus/document/EFTA00235326/142 or ?id=EFTA00235326&page=142]", "char_count": 2747}, {"efta_number": "EFTA00235326", "page_number": 143, "text_content": "material to this agreement and is supported by independent consideration and that a breach \nof any one of these conditions allows the United States to elect to terminate the agreement \nand to investigate and prosecute Epstein and any other individual or entity for any and all \nfederal offenses. \nBy signing this agreement, Epstein asserts and certifies that he is aware of the fact that \nthe Sixth Amendment to the Constitution of the United States provides that in all criminal \nprosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further \nis aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court \nmay dismiss an indictment, information, or complaint for unnecessary delay in presenting \na charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein \nhereby requests that the United States Attorney for the Southern District ofFlorida defer such \nprosecution. Epstein agrees and consents that any delay from the date of this Agreement to \nthe date of initiation of prosecution, as provided for in the terms expressed herein, shall be \ndeemed to be a necessary delay at his own request, and he hereby waives any defense to such \nprosecution on the ground that such delay operated to deny him rights under Rule 48(b) of \nthe Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the \nUnited States to a speedy trial or to bar the prosecution by reason of the running of the statute \nof limitations for a period of months equal to the period between the signing of this \nagreement and the breach of this agreement as to those offenses that were the subject of the \ngrand jury's investigation. Epstein further asserts and certifies that he understands that the \nFifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all \nfelonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees \nand consents that, if a pr\n... [truncated, 2333 chars — for the full page use /api/corpus/document/EFTA00235326/143 or ?id=EFTA00235326&page=143]", "char_count": 2333}, {"efta_number": "EFTA00235326", "page_number": 144, "text_content": "By signing this agreement, Epstein asserts and certifies that the above has been read \nand explained to him. Epstein hereby states that he understands the conditions of this Non-\nProsecution Agreement and agrees to comply with them. \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nDated: \n \nBy: \nASSISTANT U.S. ATTORNEY \nDated: \nDated: \nDated: \nJEFFREY EPSTEIN \nGERALD LEFCOURT, ESQ. \nCOUNSEL TO JEFFREY EPSTEIN \nLILLY IIKSANCHEZ, ESQ. \nATTORNEY FOR JEFFREY EPSTEIN \nPage 7 of 7 \nUS_Atty_Cor_00144 \nEFTA00235470\n", "char_count": 510}, {"efta_number": "EFTA00235326", "page_number": 145, "text_content": "09/24/2007 02:16 \nPM \nTo \"Jay Lefkowite \ncc \nbcc \nSubject The final final \n<<070924 Final Epstein Non-Prosecution Agrees ent.pcle>> \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \nM070924 Final Epstein Non•Prosecution Agreement.pcif \nUS_Atty_Cor_00145 \nEFTA00235471\n", "char_count": 271}, {"efta_number": "EFTA00235326", "page_number": 146, "text_content": "IN RE: \nINVESTIGATION OF \nJEFFREY EPSTEIN \n1101LEROSECOMAGILEEMENI \nIT APPEARING that the City of Palm Beach Police Department and the State \nAttorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, \nthe \"State Attorney's Office\") have conducted an investigation into the conduct of Jeffrey \nEpstein (hereinafter \"Epstein\"); \nIT APPEARING that the State Attorney's Office has charged Epstein by indictment \nwith solicitation of prostitution, in violation of Florida Statutes Section 796.07; \nIT APPEARING that the United States Attorney's Office and the Federal Bureau of \nInvestigation have conducted their own investigation into Epstein's background and any \noffenses that may have been committed by Epstein against the United States from in or \naround 2001 through in or around September 2007, including: \n(1) \nknowingly and willfully conspiring with others known and unknown to \ncommit an offense against the United States, that is, to use a facility or means \nof interstate or foreign commerce to knowingly persuade, induce, or entice \nminor females to engage in prostitution, in violation of Title 18, United States \nCode, Section 2422(b); all in violation of Title 18, United States Code, Section \n371; \n(2) \nknowingly and willfully conspiring with others known and unknown to travel \nin interstate commerce for the purpose of engaging in illicit sexual conduct, as \ndefined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18, \nUnited States Code, Section 2423(b); all in violation of Title 18, United States \nCode, Section 2423(e); \n(3) \nusing a facility or means of interstate or foreign commerce to knowingly \npersuade, induce, or entice minor females to engage in prostitution; in \nviolation of Title 18, United States Code, Sections 2422(b) and 2; \n(4) \ntraveling in interstate commerce for the purpose of engaging in illicit sexual \nconduct, as defined in 18 U.S.C. § 2423O1 with minor females; in violation \nPage 1 of 7 \nUS_Atty_Cor_0\n... [truncated, 2019 chars — for the full page use /api/corpus/document/EFTA00235326/146 or ?id=EFTA00235326&page=146]", "char_count": 2019}, {"efta_number": "EFTA00235326", "page_number": 147, "text_content": "of Title 18, United States Code, Section 2423(b); and \n(5) \nknowingly, in and affecting interstate and foreign commerce, recruiting, \nenticing, and obtaining by any means a person, knowing that the person had \nnot attained the age of 18 years and would be caused to engage in a \ncommercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title \n18, United States Code, Sections 1591(a)(1) and 2; and \nIT APPEARING that Epstein seeks to resolve globally his state and federal criminal \nliability and Fpstein understands and acknowledges that, in exchange for the benefits \nprovided by this agreement, he agrees to comply with its terms, including undertaking certain \nactions with the State Attorney's Office; \nIT APPEARING, after an investigation of the offenses and Epstein's background by \nboth State and Federal law enforcement agencies, and after due consultation with the State \nAttorney's Office, that the interests of the United States, the State of Florida, and the \nDefendant will be served by the following procedure; \nTHEREFORE, on the authority of R. Alexander Acosta, United States Attorney for \nthe Southern District of Florida, prosecution in this District for these offenses shall be \ndeferred in favor of prosecution by the State of Florida, provided that Epstein abides by the \nfollowing conditions and the requirements of this Agreement set forth below. \nIf the United States Attorney should determine, based on reliable evidence, that, \nduring the period of the Agreement, Epstein willfully violated any of the conditions of this \nAgreement, then the United States Attorney may, within ninety (90) days following the \nexpiration of the term of home confinement discussed below, provide Epstein with timely \nnotice specifying the condition(s) of the Agreement that he has violated, and shall initiate its \nprosecution on any offense within sixty (60) days' of giving notice of the violation. Any \nnotice provided to Epstein pursuant to this paragraph shall be provide\n... [truncated, 2656 chars — for the full page use /api/corpus/document/EFTA00235326/147 or ?id=EFTA00235326&page=147]", "char_count": 2656}, {"efta_number": "EFTA00235326", "page_number": 148, "text_content": "Terms of the Agreement \n1. \nEpstein shall plead guilty (not nolo contendere) to the Indictment as \ncurrently pending against him in the 15th Judicial Circuit in and for \nPalm Beach County (Case No. 2006-cf-009495AXXXMB) charging \none (1) count of solicitation of prostitution, in violation of Fl. Stat. § \n796.07. In addition, Epstein shall plead guilty to an Information filed \nby the State Attorney's Office charging Epstein with an offense that \nrequires him to register as a sex offender, that is, the solicitation of \nminors to engage in prostitution, in violation of Florida Statutes Section \n796.03; \n2. \nEpstein shall make a binding recommendation that the Court impose a \nthirty (30) month sentence to be divided as follows: \na\n(a) \nEpstein shall be sentenced to consecutive teens of twelve (12) \nmonths and six (6) months in county jail for all charges, without \nany opportunity for withholding adjudication or sentencing, and \nwithout probation or community control in lieu of \nimprisonment; and \n(b) \nEpstein shall be sentenced to a term of twelve (12) months of \ncommunity control consecutive to his two terms in county jail \nas described in Term 2(a), supra. \n3. \nThis agreement is contingent upon a Judge of the 15th Judicial Circuit \naccepting and executing the sentence agreed upon between the State \nAttorney's Office and Epstein, the details of which are set forth in this \nagreement. \n4. \nThe terms contained in paragraphs 1 and 2, supra, do not foreclose \nEpstein and the State Attorney's Office from agreeing to recommend \nany additional charge(s) or any additional term(s) of probation and/or \nincarceration. \n5. \nEpstein shall waive all challenges to the Information filed by the State \nAttorney's Office and shall waive the right to appeal his conviction and \nsentence, except a sentence that exceeds what is set forth in paragraph \n(2), supra. \n6. \nEpstein shall provide to the U.S. Attorney's Office copies of all \nPage 3 of 7 \nUS_Atty_Cor_00148 \nEFTA00235474\n", "char_count": 1987}, {"efta_number": "EFTA00235326", "page_number": 149, "text_content": "proposed agreements with the State Attorney's Office prior to entering \ninto those agreements. \n7. \nThe United States shall provide Epstein's attorneys with a list of \nindividuals whom it has identified as victims, as defined in 18 U.S.C. \n§ 2255, after Epstein has signed this agreement and been sentenced. \nUpon the execution of this agreement, the United States, in consultation \nwith and subject to the good faith approval of Epstein's counsel, shall \nselect an attorney representative for these persons, who shall be paid for \nby Epstein. Epstein's counsel may contact the identified individuals \nthrough that representative. \n8. \nIf any of the individuals referred to in paragraph (7), supra, elects to \nfile suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the \njurisdiction of the United States District Court for the Southern District \nofFlorida over his person and/or the subject matter, and Epstein waives \nhis right to contest liability and also waives his right to contest damages \nup to an amount as agreed to between the identified individual and \nEpstein, so long as the identified individual elects to proceed \nexclusively under 18 U.S.C. § 2255, and agrees to waive any other \nclaim for damages, whether pursuant to state, federal, or common law. \nNotwithstanding this waiver, as to those individuals whose names \nappear on the list provided by the United States, Epstein's signature on \nthis agreement, his waivers and failures to contest liability and such \ndamages in any suit are not to be construed as an admission of any \ncriminal or civil liability. \n9. \nEpstein's signature on this agreement also is not to be construed as an \nadmission of civil or criminal liability or a waiver of any jurisdictional \nor other defense as to any person whose name does not appear on the \nlist provided by the United States. \n10. \nExcept as to those individuals who elect to proceed exclusively under \n18 U.S.C. § 2255, as set forth in paragraph (8), supra, neither Epstein's \nsig\n... [truncated, 2437 chars — for the full page use /api/corpus/document/EFTA00235326/149 or ?id=EFTA00235326&page=149]", "char_count": 2437}, {"efta_number": "EFTA00235326", "page_number": 150, "text_content": "sentenced not later than October 26, 2007. The United States has no \nobjection to Epstein self-reporting to begin serving his sentence not \nlater than January 4, 2008. \n12. \nEpstein agrees that he will not be afforded any benefits with respect to \ngain time, other than the rights, opportunities, and benefits as any other \ninmate, including but not limited to, eligibility for gain time credit \nbased on standard rules and regulations that apply in the State of \nFlorida. At the United States' request, Epstein agrees to provide an \naccounting of the gain time he earned during his period of \nincarceration. \n13. \nThe parties anticipate that this agreement will not be made part of any \npublic record. If the United States receives a Freedom of Information \nAct request or any compulsory process commanding the disclosure of \nthe agreement, it will provide notice to Epstein before making that \ndisclosure. \nEpstein understands that the United States Attorney has no authority to require the \nState Attorney's Office to abide by any terms of this agreement. Epstein understands that \nit is his obligation to undertake discussions with the State Attorney's Office and to use his \nbest efforts to ensure compliance with these procedures, which compliance will be necessary \nto satisfy the United States' Interest. Epstein also understands that it is his obligation to use \nhis best efforts to convince the Judge of the 15th Judicial Circuit to accept Epstein's binding \nrecommendation regarding the sentence to be imposed, and understands that the failure to \ndo so will be a breach of the agreement. \nIn consideration of Epstein's agreement to plead guilty and to provide compensation \nin the manner described above, if Epstein successfully fulfills all of the terms and conditions \nof this agreement, the United States also agrees that it will not institute any criminal charges \nirsaiitential \nco-conspirators of E ate' including but not limited to \nLesley Groff or \nFurther, upon execution o \ns \na\n... [truncated, 2821 chars — for the full page use /api/corpus/document/EFTA00235326/150 or ?id=EFTA00235326&page=150]", "char_count": 2821}, {"efta_number": "EFTA00235326", "page_number": 151, "text_content": "By signing this agreement, Epstein asserts and certifies that each of these terms is \nmaterial to this agreement and is supported by independent consideration and that a breach \nof any one of these conditions allows the United States to elect to terminate the agreement \nand to investigate and prosecute Epstein and any other individual or entity for any and all \nfederal offenses. \nBy signing this agreement, Epstein asserts and certifies that he is aware of the fact that \nthe Sixth Amendment to the Constitution of the United States provides that in all criminal \nprosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further \nis aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court \nmay dismiss an indictment, information, or complaint for unnecessary delay in presenting \na charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein \nhereby requests that the United States Attorney for the Southern District ofFlorida defer such \nprosecution. Epstein agrees and consents that any delay from the date of this Agreement to \nthe date of initiation of prosecution, as provided for in the terms expressed herein, shall be \ndeemed to be a necessary delay at his own request, and he hereby waives any defense to such \nprosecution on the ground that such delay operated to deny him rights under Rule 48(b) of \nthe Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the \nUnited States to a speedy trial or to bar the prosecution by reason of the running of the statute \nof limitations for a period of months equal to the period between the signing of this \nagreement and the breach of this agreement as to those offenses that were the subject of the \ngrand jury's investigation. Epstein further asserts and certifies that he understands that the \nFifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all \nfelonies must be charged in an i\n... [truncated, 2420 chars — for the full page use /api/corpus/document/EFTA00235326/151 or ?id=EFTA00235326&page=151]", "char_count": 2420}, {"efta_number": "EFTA00235326", "page_number": 152, "text_content": "By signing this agreement, Epstein asserts and certifies that the above has been read \nand explained to him. Epstein hereby states that he understands the conditions of this Non-\nProsecution Agreement and agrees to comply with them. \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nDated: \n \nBy: \nDated: \nDated: \nDated: \nVILLAFARA \nASSISTANT U.S. ATTORNEY \nJEFFREY EPSTEIN \nGERALD LEFCOURT, ESQ. \nCOUNSEL TO JEFFREY EPSTEIN \nLILLY. SANCHEZ, ESQ. \nATTO \nFOR ibil.REY EPSTEIN \nPage 7 of 7 \nUS_Atty_Cor_001 52 \nEFTA00235478\n", "char_count": 518}, {"efta_number": "EFTA00235326", "page_number": 153, "text_content": "CI= \nJ.gov). \n09O4/2007 04:34 PM \nSubject RE: Do you have a signed copy? \nTo \ncc \nbcc \n'Jay Lefkovdtz\" < \nnk you, \n. I have forwarded your message only to Alex, \nand \nI don't anticipate it going any further than \ntt at. When rece e the originals, I will sign and return one copy \nto you. The other will be placed in the case file, which will be kept \nconfidential since it also contains identifying Information about the \ngirls. \nWhen we reach an agreement about the attorney representative \nfor the girls, we can discuss what I can tell him and the girls about \nthe agreement. I know that \npromised Chief Reiter an update \nwhen a resolution was achiev . (Something I wouldn't have \npro i \nin light of what happened last year.) \nis calling, \nbut \nknows not to tell Chief Reiter abou \ne money issue, \njust a \nw t crimes Mr. Epstein is plead' \nuilty to and the \namount of time that has been agreed to. \nalso is telling \nChief Reiter not to disclose the outcome to anyone. \nMir \ntie \n.1.11111.161,FISi \n• \n09/242007 04:04 PM \nTo\"Jay Leficovnte \n4.ilefkowitzgkirkland.com> \ncc \nSubjectDo you nave a signed copy? \nHi Jay - Sony to be a bother, but do you have a copy that at least \ncontains Mr. Epstein's signature? I need to pass it along to the \npowers that be. Thanks. \nUS_Atty_Cor_001 53 \nEFTA00235479\n", "char_count": 1301}, {"efta_number": "EFTA00235326", "page_number": 154, "text_content": "(73 \na \nNMatene, \nTo \"Jay Letkowat citeflcowaz@kirkland.cot \ncc \nbcc \n08/25/2007 08:36 PM \nSubject Other attorneys \nHi Jay — These four people were recommended. I have not \ncontacted them to find out what their rates are. All are very active \nin the plaintiffs' bar in the West Palm area. Ted Babbitt would be \nmy first choice of these four but I think be is conflicted out because \none of his partners is married to an AUSA here. Stuart Grossman \nis probably my second choice. \nTed Babbitt — httpfiwww,babbitt-iohnson.comilhabbittihttul\nStuart Grossman —\nhtto;//www.arossmanandroth.com/sgrossrnan.htm \nChris Searcy — \nhttrd/www.searcvlaw.com/CHRISTIANDSEARCY/tabid/935/def \nault.aspx \nLake Lytal, Jr. \nhttp://wwwivtalreiter.comfmclex.olip?page id=37 \nTalk to Jack Goldberger about this group. They are all very good \npersonal injury lawyers, but I have concerns about whether there \nwould be an inherent tension because they may feel that THEY \nmight make more money (and get a lot more press coverage) if \nthey proceed outside the terms of the plea agreement (Sorry — I \njust have a bias against plaintiffs' attorneys.) One nice thing about • \nBert is that he is in Miami where there has been almost no \ncoverage of this case. \nJust so you know, I have never met Bert, but a good friend in our \nappellate section and one of the district judges in Miami are good \nfriends with him and recommended him. \nCan you let me know tomorrow? lam going to be out for a while \nstarting on Friday, and I would like to get this underway before I \nleave. \nThank you. \nUS_Atty_Cor_001 54 \nEFTA00235480\n", "char_count": 1588}, {"efta_number": "EFTA00235326", "page_number": 155, "text_content": "Assistant U.S. Attorney \nWest Palm Beach, FL 33401 \nUS_Atty_Cor_001 55 \nEFTA00235481\n", "char_count": 85}, {"efta_number": "EFTA00235326", "page_number": 156, "text_content": "MIWong. \nTo \"Jay LotkovAte \ncc \nbce \nSubOM Conference call \nWW' \n09/25/200712:11 PM \nHi Jay — Have you approved Mr. Ocariz as the girls' \nrepresentative? And can we have a conference call to discuss what \nI may disclose to him and to the girls regarding the agreement? \nThank you. \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \nf.\" \nUS_Atty_Cor_001 56 \nEFTA00235482\n", "char_count": 372}, {"efta_number": "EFTA00235326", "page_number": 157, "text_content": "Stuart Grossman —\nhttp://www.grossmanandroth.com/sgrossman.hgu\nChris Searcy —\nhttve//www.searcvlaw.com/CHRJSTIANASEARCY/tabld/935/def \naultasnx \nLake Lytal, Jr. — http://www.lvtakeiter.com/indeLphffinage idr=37 \nTalk to Jack Goldberger about this group. They are all very good \npersonal injury lawyers, but I have concerns about whether there \nwould be an inherent tension because they may feel that THEY \nmight make more money (and get a lot more press coverage) if \nthey proceed outside the terms of the plea agreement- (Sorry — I \njust have a bias against plaintiffs' attorneys.) One nice thing about \nBert is that he is in Miami where there has been almost no \ncoverage of this case. \nJust so you know, I have never met Bert, but a good friend in our \nappellate section and one of the district judges in Miami are good \nfriends with him and recommended him. \nCan you let me know tomorrow? I am going to be out for a while \nstarting on Friday, and I would like to get this underway before I \nleave. \nThank you. \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \nUS_Atty_Cor_001 57 \nEFTA00235483\n", "char_count": 1100}, {"efta_number": "EFTA00235326", "page_number": 158, "text_content": "W—\n1U:a \n4\nlieISMS \n09/26/200711O3 Ml \nTo \"Jay Lefitowitc\" cilmikowitzakirkland.col \ncc \nbcc \nSubject One more thing \nWIWI/ \nHi Jay — Did you send me the original signed agreement? 1 would \nlike to sign that copy and return copies to you. Thank you. \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \nUS_Atty_Cor_001 58 \nEFTA00235484\n", "char_count": 336}, {"efta_number": "EFTA00235326", "page_number": 159, "text_content": "Made C. \nundo \nWort \n09/26/2007 11:49 AM \nTo \"Jey Leftist' <JLetkowitzekinstend.ca \ncc \nbcc \nSubject RE: One more thing \nHi Jay — Meaning no disrespect to these distinguished gentlemen, one of \nmy criteria is that, if negotiations with you don't work out, they have the \nstamina to take you all to trial, so 1 politely decline your suggestion. \ns \nt U. . Attorney \nas \n• \na\nSAELST \nSent: 09/26/2007 11:03 AM AST \nTo: Jay Lelkowitz \nSubject: One more thing \nHi Jay — Did you send me the original signed agreement? I would \nlike to sign that copy and return copies to you. Thank you. \nI \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \nUS_Atty_Cor_001 59 \nEFTA00235485\n", "char_count": 671}, {"efta_number": "EFTA00235326", "page_number": 160, "text_content": "******************************** \n**•**•**•**•*********• \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only for \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International LLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly prohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately by \nreturn e-mail or by e-mail to postmaster®Icirkland.com, and \ndestroy this communication and all copies thereof, \nincluding all attachments. \nis ***** ******************** \n************ \n***** ****••• \n****• \nUS_Atty_Cor_001 60 \nEFTA00235486\n", "char_count": 784}, {"efta_number": "EFTA00235326", "page_number": 161, "text_content": "fwafoneiSI. \nWow' \n09/27/2007 10:52 AM \nTo *Jay Lethowite <JLefkowitzarldrldand.coi \ncc \nbcc \nSubject Conference CaN with Bert Ocartz \nhiCti\n. fit:\n74M • \nFll Jay — Bert's firm has raised a number of good questions about \nhow they are going to get paid and setting up a procedure that \navoids any conflict of interest with their clients. Are you around \ntoday to do a conference call? Let me know what times work for \nyou because Bert wants to get their conflicts counsel on the call \nwith us. \nThese are some of the questions he sent to me. I told Bert that as \npart of our agreement we (the federal government) are not going to \nindict Mr. Epstein, but gave him an idea of the charges that we had \nplanned to bring as related to 18 USC 2255. With respect to \nquestion 2, do I have your permission to send Bert just that section \nof the plea agreement that applies to the damages claims (I would \nrecommend sending paragraphs 7 through 10, or at least 7 and 8)? \nCan you talk with your client about items 3 and 4? I envisioned \nShook Hardy sending regular bills to you, with any privileged \ninformation redacted, and being paid like every other client pays \nthe bills. \n1. Can we get a copy of the Indictment (or can you tea me the nature of \nthe crimes against the girls)? \n2. When will it be possible to see the plea agreement so that we \nunderstand exactly what Epstein concedes to in the civil case? \n3. Is there any cap or other limitation on attorney's fees that the \ndefendant will pay in the civil case? \n4. What is the contemplated procedure for, and timing of, the payment of \nattorney's fees and costs? \nVillafarla \nUS_Atty_Cor_001 61 \nEFTA00235487\n", "char_count": 1661}, {"efta_number": "EFTA00235326", "page_number": 162, "text_content": "West Palm Beach, FL 33401 \nAssistant L'.S. Attorney \nUS_Atty_Cor_00162 \nEFTA00235488\n", "char_count": 85}, {"efta_number": "EFTA00235326", "page_number": 163, "text_content": "r \n`Villafene,Mall \nTo \"Jay Lefkovtt\" \ncc \n1410n \nbcc \n0927/200711:08 AM \nSubject RE Conference Call with Bert Ocartz \nThanks, Jay. Can we make it 4:15 or later? I have a 3:30 that \nmight run more than a half hour. And let me know about sending \nBert the agreement language. That might aid our discussions \nbecause the firm will have a better idea of what the litigation will \nentail. \nAssi\ntl\nis\nilis\nma\nstan\ntto \nWest Palm Beac FL 33401 \nMr' \nes\" \nOri \nI Me \n— \nFrom: \nSAFLS)\" \nSent: 09/27/2007 10: 1 \nA \nTo: Jay Lefkowitz \nSubject: Conference Call with Bert Ocariz \nHi Jay — Bert's firm has raised a number of good questions about \nhow they are going to get paid and setting up a procedure that \navoids any conflict of interest with their clients. Are you around \ntoday to do a conference call? Let me know what times work for \nyou because Bert wants to get their conflicts counsel on the call \nwith us. \nThese are some of the questions he sent to me. I told Bert that as \nUS_Atty_Cor_001 63 \nEFTA00235489\n", "char_count": 1009}, {"efta_number": "EFTA00235326", "page_number": 164, "text_content": "part of our agreement we (the federal government) are not going to \nindict Mr. Epstein, but gave him an idea of the charges that we had \nplanned to bring as related to 18 USC 2255. With respect to \nquestion 2, do I have your permission to send Bert just that section \nof the plea agreement that applies to the damages claims (I would \nrecommend sending paragraphs 7 through 10, or at least 7 and 8)? \nCan you talk with your client about items 3 and 4? I envisioned \nShook Hardy sending regular bills to you, with any privileged \ninformation redacted, and being paid like every other client pays \nthe bills. \n1. Can we get a copy of the indictment (or can you tell me the nature of \nthe crimes against the girls)? \n2. When will it be possible to see the plea agreement so that we \nunderstand exactly what Epstein concedes to in the chin case? \n3. Is there any cap or other limitation on attorney's fees that the \ndefendant will pay in the civil case? \n4. What is the contemplated procedure for, and timing of, the paynient of \nattorney's fees and costs? \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only for \nthe use of the addressee. It is the property of \nUS_Atty_Cor_001 64 \nEFTA00235490\n", "char_count": 1351}, {"efta_number": "EFTA00235326", "page_number": 165, "text_content": "Kirkland & Ellis LLP or Kirkland & Ellis International LLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly prohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately by \nreturn e-mail or by e-mail to postmaster@lchidand.com, and \ndestroy this communication and all copies thereof, \nincluding all attachments. \n*SS** \n7-\nUS_Atty_Cor_001 65 \nEFTA00235491\n", "char_count": 456}, {"efta_number": "EFTA00235326", "page_number": 166, "text_content": "Vdlefanallallit \ns\nis\nsmin\n)40Y,\n09/27/2007 0.3:06 PM \nTo 'Jay Lefkowite \ncc \nbcc \nSubject RE: Conference Cal with Bert °Gertz \nHi Jay - I already told Bert that there is no indictment and, as I \nmentioned, he doesn't really need to/want to see the entire plea \nagreement, just the relevant paragraphs so that he understands what \nthe scope of his representation will be. I think they would be \nhappy knowing that their hourly rate will be paid when it is billed. \nThe concern is, if all 40 girls decide they want to sue, they don't \nwant to be in a situation where Mr. Epstein says this is getting too \nexpensive, we won't pay any more attorneys' fees. \nTwo suggestions, that I haven't run past Bert, are: \n1. \nMr. Epstein signs a standard fee agreement, where \none of his attorneys or accountants who is not working on \nthe damages litigation receives a monthly bill with \nattorney's fees charged at an hourly rate and costs billed \nmonthly. The bills will have any privileged information \nredacted. If there is a dispute about a bill that cannot be \nresolved, it will be submitted to a mediator for resolution. \n2. \nIf that is too open-ended for Mr. Epstein, do the \nhourly/monthly billing until Bert has had a chance to confer \nwith all of the girls to determine how many want him to \nrepresent them. Once it is known how many girls will be \nrepresented by Bert, and maybe who those girls are, there \ncan be a more educated discussion about estimated fees and \ncosts. \nJust some food for thought. I will be out of the office tomorrow, \nbut I will be reachable by cell phone. I will make sure Bert is \navailable and confirm the time with you. \n33401 \nUS_Atty_Cor_001 66 \nEFTA00235492\n", "char_count": 1687}, {"efta_number": "EFTA00235326", "page_number": 167, "text_content": "1111.111C \n11111.111.11111101S\n1\n11111r \ndissamsese \nNimun aise \n. (USAFLS)\" \nsdoj. gov] \nSent 09/27/2007 10:51 AM AST \nTo: Jay LetkowItz \nSubject: Conference Call with Bert Ocariz \nHi Jay — Bert's firm has raised a number of good questions about \nhow they are going to get paid and setting up a procedure that \navoids any conflict of interest with their clients. Are you around \ntoday to do a conference call? Let me know what times work for \nyou because Bert wants to get their conflicts counsel on the call \nwith us. \nUS_Atty_Cor_001 67 \nEFTA00235493\n", "char_count": 554}, {"efta_number": "EFTA00235326", "page_number": 168, "text_content": "r-\nThese are some of the questions he sent to me. I told Bert that as \npart of our agreement we (the federal government) are not going to \nindict Mr. Epstein, but gave him an idea of the charges that we had \nplanned to bring as related to 18 USC 2255. With respect to \nquestion 2, do I have your permission to send Bert just that section \nof the plea agreement that applies to the damages claims (I would \nrecommend sending paragraphs 7 through 10, or at least 7 and 8)? \nCan you talk with your client about Items 3 and 47 I envisioned \nShook Hardy sending regular bills to you, with any privileged \ninformation redacted, and being paid like every other client pays \nthe bills. \n1. Can we get a copy of the Indictment (or can you ten me the nature of \nthe crimes against the girls)? \n2. When will It be possible to see the plea agreement so that we \nunderstand exactly what Epstein concedes to in the civil case? \n3. Is there any cap or other limitation on attorney's fees that the \ndefendant will pay In the civil case? \n4. What Is the contemplated procedure for, and timing of, the payment of \nattorney's fees and costs? \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \n*********************** \n****** **********************•• \n• \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nUS_Atty_Cor_001 68 \nEFTA00235494\n", "char_count": 1376}, {"efta_number": "EFTA00235326", "page_number": 169, "text_content": "constitute inside information, and is intended only for \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International LLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly prohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately by \nreturn e-mail or by e-mail to postmastengldrldand.com, and \ndestroy this communication and all copies thereof, \nincluding all attachments. \n....• \na \nUS_Atty_Cor_00 1 69 \nEFTA00235495\n", "char_count": 563}, {"efta_number": "EFTA00235326", "page_number": 170, "text_content": "1•90v> \nOB/27/2007 05:11 PM \nTo \"Jay Lefkowitz° <JLetkowb.@kirldand.coi \ncc \nbcc \n&Med Can you give me a car \nHi Jay — Can you give me a quick ring. Thanks. \nVlllajalla \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \nUS_Atty_Cor_001 70 \nEFTA00235496\n", "char_count": 255}, {"efta_number": "EFTA00235326", "page_number": 171, "text_content": "To \"Jay Lefka.vite < \ncc \nbec \nSubject Re: \nHi Jay \n'haven't been able to access my e-mail until now. I am \nfree until 10:00, then at 1:00, then at 5:00. Would any of those \nwork for you? \n-- Original Message \n--- Original Message ---\n°es \n=me \nlaimmarom \nwas \nUS_Atty_Cor_001 71 \nEFTA00235497\n", "char_count": 294}, {"efta_number": "EFTA00235326", "page_number": 172, "text_content": "The information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only for \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International LLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly prohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately by \nreturn e-mail or by e-mail to postmaster@kirkland.com, and \ndestroy this communication and all copies thereof, \nincluding all attachments. \n• *****•*******************************•************* \n***fig** \nUS_Atty_Cor_001 72 \nEFTA00235498\n", "char_count": 723}, {"efta_number": "EFTA00235326", "page_number": 173, "text_content": "lAMMentelll \nMarla C. \nu \n.gov> \n1O/O3/2OO7 O3:15 \nPM \nHi Jay -- This afternoon is fine. Here is the memo \nthat I put together. Just let me know whore I should \ncall you at 4:0O. Thanks. \nMOM \nAssistant U.S. Attorney \nTo \"JayLefkowitt<Aefkowkrakirkland.com> \ncc \nbct \nSubject RE: \n \nOriginal Message \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn.e-mail or.by e-mail to postmaster@kirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \n«< Attachment locial Master Proposal.wne has been archived by \nu”r 'CommonStore/1171(Irkland-Ellis' on '12/04/2007 00:49:45'. >>> \nUS_Atty_Cor_001 73 \nEFTA00235499\n", "char_count": 1095}, {"efta_number": "EFTA00235326", "page_number": 174, "text_content": "PROPOSAL FOR PROCEEDING ONCE ATTORNEY \nLS SELECTED \n1. \nProvide selected attorney with: \na. \na copy of the relevant portion of the Non-Prosecution Agreement \nb. \nthe names and contact information for the identified victims; and \nc. \na retainer agreement. \ni. \nThe retainer agreement will provide for the monthly billing of \nfees at an hourly rate and monthly expenses. \na \nii. \nThe billing statements will be sent to and paid by an attorney \nor accountant not involved in the damages litigation, and will not be \nmade available to any person or fum involved in the damages \nlitigation. \niii. \nBilling statements will have privileged and work product information \nredacted. \niv. \nDisputes regarding fees will be referred to a Special Master (perhaps \nthe Special Master who selected the attorney). \n2. \nThe agents and I will contact The girls individually to inform them of the \nresolution of the case, including the selection of an attorney to represent them, if \nthey so choose. I will provide them with the name and telephone number of the \nattorney and also let them know that the attorney will be contacting them. \n3. \nThe selected attorney will contact each victim and review with her the facts \nof her case and the options that she has, namely: \na. \nselecting another attorney and handling everything through that \nattorney; \nb. \nattempting to reach an agreement with Mr. Epstein for an amount of \ndamages pursuant to 18 U.S.C. § 2255; \nc. \nfiling suit seeking other state and/or federal damages or restitution; \nand \nUS_Atty_Cor_001 74 \nEFTA00235500\n", "char_count": 1557}, {"efta_number": "EFTA00235326", "page_number": 175, "text_content": "PROPOSAL FOR SELECTION OF ATTORNEY \nTO REPRESENT VICTIMS \n1. \nSelect a Special Master. \n2. \nProvide the Special Master with: \na. \na joint list containing the names of five attorneys; \nb. \na joint statement of relevant facts regarding the case; \nc. \neach party's list of criteria; \nd. \na copy of the relevant portion of the Non-Prosecution Agreement \n(discussing the role of the attorney for the victims); and \ne. \na proposed retainer agreement. \n3. \nEach attorney on the list can provide the Special Master with information \nregarding his/her experience, firm size, etc. \n4. \nThe Special Master can interview any or all of the attorneys as the Special \nMaster deems appropriate. \n5. \nThe Special Master will provide us with the top three choices (in order). \nThe first attorney will be contacted and a conflicts check will be run. If there is a \nconflict in representation, the second attorney will be contacted, etc. \nUS_Atty_Cor_001 75 \nEFTA00235501\n", "char_count": 952}, {"efta_number": "EFTA00235326", "page_number": 176, "text_content": "d. \nnot seeking any money damages from Mr. Epstein. \n4. \nIf the specific victim selects option (3Xb), the selected attorney will contact \ncounsel for Mr. Epstein to negotiate a settlement amount and the terms of that \nsettlement. \n5. \nIf the specific victim selects option (3)(b) and the parties are unable to reach \nan agreement regarding a settlement amount, then the victim can: \na. \nask the selected attorney to file suit in the U.S. District Court for the \nSouthern District of Florida, pursuant to 18 U.S.C. § 2255; or \nb. \nfile suit in state or federal court pursuing damages under any state or \nfederal remedy. \n6. \nIf the specific victim selects option (5Xa), the representation of the victim \nby the selected attorney will continue using the same monthly billing and payment \nsystem contained in the retainer agreement \n7. \nIf the specified victim selects option (5)(b), Mr. Epstein will have no further \nobligation to pay the attorney, except as ordered by the Court hearing the suit. \nUS_Atty_Cor_001 76 \nEFTA00235502\n", "char_count": 1030}, {"efta_number": "EFTA00235326", "page_number": 177, "text_content": "10/03/2007 03:38 PM \nTo \"Jay Lelkowke <Jlefkowezerdedend.cm \ncc \nbcc \nSubject RE: \nThat is fine. I'm sorry I didn't get your e-mail \nsooner. Since I am out of the office, the best way to \nreach me is on my cell, or you can send an e-mail \n(which becomes a text message) to \n56160123018cingularme.com \nTomorrow I am available early in the morning (7:00 to \n7:45), or at 8:30, or at 5:00, or after 6:45. \nThanks. \n-----Or' \nal Messa e \nWIM\nP\n \nOri final Message  \nFrom: \" \n. (USAFLS)• \n( \nSent: \n: \nTo: Jay Lefkowitz \nSubject: RE: \nHi Jay -- This afternoon is fine. Here is the memo \nthat I put together. Just let me know where I should \ncall you at 4:00. Thanks. \nRilitIPPWorney \nUS_Atty_Cor_001 77 \nEFTA00235503\n", "char_count": 712}, {"efta_number": "EFTA00235326", "page_number": 178, "text_content": "- \n- \n- \n- \n-Ori inal Message \n****** \n***** *********** \n**** ******** \n** ******** \n********** \n***** \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland I. Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmaster@kirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \n* * * \n* \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland 4 Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmaster@kirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \n* * * * * \nUS_Atty_Cor_001 78 \nEFTA00235504\n", "char_count": 1420}, {"efta_number": "EFTA00235326", "page_number": 179, "text_content": "To 'Jay LeOcowtte <JLelkovAteOldridend.coo \n(USAFLS \" \ncc \nbcc \n10/03/2007 07:31 PM \nSubject RE: Proposed Letter to Special Master \nHi Jay -- That was simply a draft for discussion \npurposes. I am hoping that we will send such a letter \njointly, once we have finalized the process and pick a \nmaster. Thanks. \nre a\ninIMI\nA\nS)\nFL \" \n10/03/2007 04:24 PM \nTo \n\"Jay Lefkowitz• \ncc \nSubject \nProposed Letter to Special Master \nHi Jay - To move things along, I also have enclosed \nthe proposed text of a letter to the Special Master. \n«PROPOSED Letter to Special Master.pdf» \nVillafana \nAssistant U.S. Attorney \nUS_Atty_Cor_001 79 \nEFTA00235505\n", "char_count": 639}, {"efta_number": "EFTA00235326", "page_number": 180, "text_content": "o r \nMI= \nJr \n10/05/2007 07:48 AM \nTo \"JayLalkovAtt<JL•fltovitsOkirktand.cot \ncc \nbcc \nSubject RE: Proposed Letter to Special Master \nGood morning, Jay. We need to resolve the attorney \nissue today. It has been weeks since execution of the \ncontract, and there is no need for further delay. \nAs far as the five attorney names that we will be \nproviding, I propose Bert Ocariz, Katherine Ezell at \nPodhurst Orseck, Stuart Grossman, Ed Rogers, and \nWalter Cobath. \nIf you would like to use the same Special Master to \nresolve fees disputes as well as to handle the \nselection of the attorney, I would recommend that we \nuse retired 11th circuit Judge Joseph Hatchett instead \nof Judge Davis because of Judge Davis's health \nproblems. (No one has contacted Judge Hatchett yet, \nbut one of the District Judges in Miami mentioned him \nas a good choice.) \nI am available for a conference call between 9:00 and \n10:00, and between 3:15 and 6:00. Please call me on \nmy cell \n) and let me know which of those \ntimes works best for you. \nThank you. \n1111.111\n-\nal\nat\nli)\" \n10/03/2007 04:24 PM \nTo \n\"Jay Lefkowitz' cal=EIMMI> \nUS_Atty_Cor_001 80 \nEFTA00235506\n", "char_count": 1149}, {"efta_number": "EFTA00235326", "page_number": 181, "text_content": "cc \nSubject \nProposed Letter to Special Master \nHi Jay - To move things along, I also have enclosed \nthe proposed text of a letter to the Special Master. \n<<PROPOSED Letter to Special Master.pdf>> \nAssistant U.S. Attorney \nFax 561 820-8777 \nUS_Atty_Cor_001 81 \nEFTA00235507\n", "char_count": 274}, {"efta_number": "EFTA00235326", "page_number": 182, "text_content": "Pao \nJr \n10/092001 04:47 PM \nTo \"Jay Lefkowitz\" <JLefkowitz@kirkland.cou \ncc \nbcc \nSubject RE: Proposed Letter to Special Master \nJay -- I will call In at 5:30. \nS \n. USAFLS)\"\n10/05/2007 07:48 AM \nTo \n\"Jay Lefkowitz\" caMEMEI=ME> \ncc \nSubject \nRE: Proposed Letter to Special Master \nUS_Atty_Cor_001 82 \nEFTA00235508\n", "char_count": 315}, {"efta_number": "EFTA00235326", "page_number": 183, "text_content": "Good morning, Jay. We need to resolve the attorney \nissue today. It has been weeks since execution of the \ncontract, and there is no need for further delay. \nAs far as the five attorney names that we will be \nproviding, I propose Bert Ocariz, Katherine Ezell at \nPodhurst Orseck, Stuart Grossman, Ed Rogers, and \nWalter Cobath. \nIf you would like to use the same Special Master to \nresolve fees, disputes as well as to handle the \nselection of the attorney, I would recommend that we \nuse retired 11th Circuit Judge Joseph Hatchett instead \nof Judge Davis because of Judge Davis's health \nproblems. (No one has contacted Judge Hatchett yet, \nbut one of the District Judges in Miami mentioned him \nas a good choice.) \nI am available for a conference call between 9:00 and \n10:00, and between 3:15 and 6:00. Please call me on \nmy cell (FIEFFIR \nand let me know which of those \ntimes wor s es \nor you. \nThank you. \n!MCC \n11111111111\n\"\" \n. (USAFLS)\" \n10/03/2007 04:24 PM \nTo \n\"Jay Lefkowitz\" \ncc \nSubject \nProposed Letter to Special Master \nUS_Atty_Cor_001 83 \nEFTA00235509\n", "char_count": 1070}, {"efta_number": "EFTA00235326", "page_number": 184, "text_content": "Hi Jay - To move things along, I also have enclosed \nthe proposed text of a letter to the Special Master. \n<<PROPOSED Letter to Special Master.pdf» \nVillafafta \nAssistant U.S. Attorney \nUSAFLS)\" \n10/03/2007 04:24 PM \nTo \n\"Jay Lefkowitz\" \ncc \nSubject \nProposed Letter to Special Master \nHi Jay - To move things along, I also have enclosed \nthe proposed text of a letter to the Special Master. \n<<PROPOSED Letter to Special Master.pdf>> \nAssistant U.S. Attorney \n10/03/2007 03:18 PM \nTo \n•Jay Lefkowitz\" \ncc \nSubject \nMemo in PDF format \nUS_Atty_Cor_001 84 \nEFTA00235510\n", "char_count": 569}, {"efta_number": "EFTA00235326", "page_number": 185, "text_content": "Hi Jay - In case you can't open the other version, \nhere it is in pdf. \nc<Special Master Proposal.pdf>> \nIIIIIIIIIVillafafla \nAssistant U.S. Attorney \nUS_Atty_Cor_001 85 \nEFTA00235511\n", "char_count": 184}, {"efta_number": "EFTA00235326", "page_number": 186, "text_content": "To \"Jay LefkowItz\" \ncc \nbcc \n10/05/2007 05:42 PM \nSubject RE: Proposed Letter to Special Master \nJay — I will call you at 5:30. \nAssistant U.S. Attorney \n10/05/2007 07:48 AM \nTom-lay Laowite \ncc\nSubJectRE: Proposed Letter to Special \nMaster \nUS_Atty_Cor_001 86 \nEFTA00235512\n", "char_count": 275}, {"efta_number": "EFTA00235326", "page_number": 187, "text_content": "Good morning, Jay. We need to resolve the attorney \nissue today. It has been weeks since execution of the \ncontract, and there is no need for further delay. \nAs far as the five attorney names that we will be \nproviding, I propose Bert Ocariz, Katherine Ezell at \nPodhurst Orseck, Stuart Grossman, Ed Rogers, and \nWalter Cobath. \n• \nIf you would like to use the same Special Master to \nresolve fees disputes as well as to handle the \nselection of the attorney, I would recommend that we \nuse retired 11th Circuit Judge Joseph Hatchett instead \nof Judge Davis because of Judge Davis's health \nproblems. (No one has contacted Judge Hatchett yet, \nbut one of the District Judges in Miami mentioned him \nas a good choice.) \nI am available for a conference call between 9:00 and \n10:00, \nan•\n• 5 and 6:00. Please call me on \nmy cell ( \nand let me know which of those \ntimes works best for you. \nThank you. \n11111111111111C-\nwitMlisiffr \n:rnmanisime. \n10/03/2007 04:24 PH \nTo \n\"Jay Lefkowitz\" \ncc \nSubject \nProposed Letter to special master \n<S1\n111=MMIL \nUS_Atty_Cor_001 87 \nEFTA00235513\n", "char_count": 1082}, {"efta_number": "EFTA00235326", "page_number": 188, "text_content": "10/03/2007 0424 PM \nHi Jay - To move things along, I also have enclosed \nthe proposed text of a letter \nto the Special Master. \n«PROPOSED Letter to Special Master.pdf» \nVillafaAa \nAssistant \nU.S. Attorney \nTo'Jay Lolkowkr\" \ncc \nSubjectProposed Letter to Special \nMester \nHi Jay — To move things along, I also have enclosed the proposed \ntext of a letter to the Special Master. \n«PROPOSED Letter to Special Master.pdfr> \nAssistant U.S. Attorney \n10/03/2007 03:18 PM \nTo\"Jay LeStoeh' \naJLeMovAtz(0kirklarnicom> \ncc\nSubjecMemo In PDF format \nUS_Atty_Cor_001 88 \nEFTA00235514\n", "char_count": 572}, {"efta_number": "EFTA00235326", "page_number": 189, "text_content": "Hi Jay — In case you can't open the other version, here it is in pH. \n<‹special Master Proposal. pdf» \nAssistant U.S. Attorney \nMEI \nUS_Atty_Cor_001 89 \nEFTA00235515\n", "char_count": 166}, {"efta_number": "EFTA00235326", "page_number": 190, "text_content": "12/26/07 ITV 15:2\n.2 FAX 305 530 3140 \nEXECUTIVE 0PPICE \nQ.S. Department of Justice \nUnited Mates Attoreey \nSouthern Leiria of Florida \n2)002 \nP..1W2Y_BY \"SW\" \nTI \nJay?. Leficowitt, Esq. \nKirkland & Ellis IL? \nCltigroup Center \n153 EaSt 53rd Street \nNew York, New York 10022-4675 \nRer. \nefCrgy_ER,Itgin \nDear Jay: \n99N.& f aron \nMurat FL 331124111 \n(305) 961-9ZI9 \nPactrmac \n.13045444 \nDecember 6, 2007 \nI write in response to your recent e-mails and Jonas regarding victim notification and other \nissues. Our Office is trying to perform our contractual obligations under the Agreement, whichwe \nfeel are being frustrated by defense counsel's °bleeder& The Office also is concerned about Mc \nEpstains5 amp:v(O117MM \nMore than three weeks ago we spoke about the failtue to set a timely plea and sentencing \ndate. At that time, you assured me that to scheduling delay was caused by the uneven \nJudge McSodey.S2 promised that a date would be set promptly. On Novturtne 15 \nGaeta met with \nICrisher on another matter, and was told by Mx. Krisher that he had Jost \nspoken with Jack Goldberger, and that Mr. Epctebt's plea and sentencing were set to occur on \nDecember 14, 2007. Since that time, we have bled to confirm the date and time of the hearing in \norder to include drat infornution in the victim noti ?tendon letters. You continue to refer to the plea \nand sentencing as though it Wilikril.lanaary;14r.X.risheisofficebas not confirmed any date; and \nMr. Goldberger recently told\n Atlanta* that 'there is no date.\" \nI must reiterate that a delayed guilty plea and sentencing — now mote than two months \nbeyond the original deadline — is unacceptable to the Office. As you will recall. the aka end \nsentencing hearing originallywas to occur in early Octoba 2007, but was delayed until Octobee26th \nto allow Mr. Goldberger to attend. R was delayed again until November to allow you to attend. \nRather than using your best efforts to insure that the plea and sentencing occur in November, we \nrecardyl\n... [truncated, 2319 chars — for the full page use /api/corpus/document/EFTA00235326/190 or ?id=EFTA00235326&page=190]", "char_count": 2319}, {"efta_number": "EFTA00235326", "page_number": 191, "text_content": "12/05/00 TEU 15:23 PAX 305 330 3140 \nJAY P. lancoVirra, Esq. \nDemand, 2007 \n?AM/ 2 ore \nRXECUrINE MICR \nQ003 \nany past or fittare delay. Mr. Epstein currently has lbw Florida Bar members on his defense team, \nso attorney scheduling is not an adequate basis for delay. \nThree weeks ago talso asked you to provide our Office with the terms of the Plea Agreement \nwith the State Attorneys Office. It is now tome than two Months sines the signing of the Non. \nPreset:anion Agre.ement cod wo baveyet to see anyfomol agreement, or oven a list of essential terms \nof such an agreement. \nMat, let me address your allegation that attorneys In ow office and agents of the FBI have \n' leaked infermation to the mesa In an effort to alba possible civil litigation with Mr. Epstein. This \nis online. There has been no contact between any member of the press and any employee of our \noffice or the FBI since you incorrectly imensed investigators of tolling \"Vanity Rae about Mr. \nStarr's entploynoatt by Mr. Epstein several months ago. We intend to continue to telltale from \ncommenting or providing information to the press. We would ask that your client and all of his \nrepresentatives do the same. \nI also .mot to address your Interpretation of several statements that were included in-\ncorrespondence —at yourinsistence— as proof that the designated victimshave invalid therm, Let \nme make clear that cach of the listed individuals are persons whom the Office identified as victims \nas defined in Section 2255, that is, as persons \"who, while a minor, was a violins of a *laden of \nsection ... 2422 or 2423 of this title\" In other words, the Office is prepared lo indict Mr. Epstein \nbased upon Mr. lipstein't \"interactions\" with those individuals,' This conclusion is based upon a \nthomogh and proper investigation —one in which 7100Q of the victims was informal of anyright to \nreceive damages of any amount prior to the Investigation other clalm. The Office agrees that it is \nnot a party to, and will not t\n... [truncated, 3370 chars — for the full page use /api/corpus/document/EFTA00235326/191 or ?id=EFTA00235326&page=191]", "char_count": 3370}, {"efta_number": "EFTA00235326", "page_number": 192, "text_content": "C,\na \n12/06/07 110 15:23 FAX 305 530 8540 \nEXECUTIVE 0PMCE \nJAY P. LerKoVettl, EsQ. \nDEMMER 6.2007 \n?A053 O►e \nnot to be excluded from any such public court proceeding \n.\" 18 U.S.C. § 3771(sX2) & (3). \nSection 3771 also commands that \"employees of the Deparbnent of Justice . \nengaged in the \ndetection, investigation, orprosocution of etimothall make their best carts to see that crime victims \nare notified of, and accorded, the rights described in subsection (a).\" 18 U.S.C. § 3771(cXI). \nAdditionally, pursumat to the Victims' Rights and Restitution Act of 1940, our Mee Is \nobligated to \"Inform a victim of any restitution or other relief to which the victim may be entitled \nunder this or any other law and [the) manner in which such relief maybe obtained.\" 42 U.S.C. § \n10607(O(1)(R). With nespect to notification of the other information that we propose to disclose, \nthe statute requires Out we provide a victim with the earliest posabie notice of the status of the \ninvestigation; the fling of charges against a suspected offender; and the acceptant). oral:lee. 42 \nU.S.C. § 10607(c)(3). Just as in 18 U.S.C. § 3771, theta sections are not limited to proceedings in \na federal distriet *curt. Our Non-Prosecution Agreement resolves the federal investigation by \nallowing Mr. Epstein to plead to a state offense. The victims identified through the. federal \ninvestigation should be appropriately informed, and our Non-Prosecution Agreement does not \nrequire the U.S. Attorney's Office to forego its legal obligations. \nWith respect to 'our assertion that we are seeking to \"federalize\" the state plea, our office \nh simply informing the victims or their rights It does not comorrut them to appear at the hewing \nor to the a victim impact statement In het, the letter recommends the sanding of my statement to \nthe State Attorney's Office so that ASA Beloblavek an determine Which, if any, statements are \nappropriate to file with the Court. \nNon you assert that ow letter miacharacterizeis M\n... [truncated, 3353 chars — for the full page use /api/corpus/document/EFTA00235326/192 or ?id=EFTA00235326&page=192]", "char_count": 3353}, {"efta_number": "EFTA00235326", "page_number": 193, "text_content": "12/06/07 TEU 15:23 FAX 306 530 6440 \nEXECUTIVE OFFICE \nSAY P. LEPKOWI72, ESQ. \nMCDADE& 6.2007 \nNOE 4 co 4 \nLastly, you object to personal cotrunanication between the victims and federal attorneys or \nagents. We have no objection to sending the letters through the mai? but we will not remove the \nlanguage about contacting AUSA Villafaiht or Special Agent \nwith questions or \nconcerns. Again, federal lane requires that victims have the \"reasonable right to confer with the \nattorney for the Gammon= in this case.\" 18 U.S.C. § 3771(1)(5). The three tame who were \nnotified prior to your objection had questions directed to Mr. Epstein's putdahment, not the civil \nlitigation. Those questions we appropriately directed to law enforcement. If questions arise related \nto the civil litigation, AUSA Villathila and Special Agent icuyrkenclall will recommend that the \nvictims direct those questions to Mr. Josefsberg. \nI havi snacked a revised letter incorporating the changes on which wo can agree. Please \nprovideany hurter comments by the oleos ofbuslness on Friday. lit addition, please provide us with \n&definitive statement, sigood by your diem, of Hs intention to slide by each and every taro of the \nAgreement by close of business on Friday, December 7,21)Y1, By that time, you must also provide \nus with the agreements) with the State Attorneys Oplee rmd a date and time certain lbw the plea and \nsentencing, which must occur no later than December 14, 2007. That mutt be closure in this \nmatter. \nshwa*, \nit. Alexander Acosta \nncy \nBy: \n'lefBcyB Mom= \nFirst Assistant United States Attorney \nEnclosure \ncc: \nR. Alexander Acosta, U.S. Attorney \nAUSA \nVrneiktha \n'This is contingent, however, on being able to provide adequate notice of the change of \nplea and sentencing. The sooner that yvu schedule that hearing with Judge MeScrley, the sooner \nwe coo dispatch these letters. If you delay Bucher, we will have to rely on telephone or personal \nnotification. \nUS_Atty_Cor_001 93 \nEFTA00235519\n", "char_count": 1999}, {"efta_number": "EFTA00235326", "page_number": 194, "text_content": "v\nissias\nQc•gov> \n10/07/2007 07:42 PM \nTo \"Jay Lelkowite <JLotkowitzddrkland.corn> \ncc \nbcc \nSubject Call Tomorrow \nJay — The office is closed tomorrow for Columbus Day. Can we \nreschedule for Tuesday at 10:00? Thank you. \nII I I I I I I I I I MI \nAssistant U.S. Attorney \nUS_Atty_Cor_001 94 \nEFTA00235520\n", "char_count": 306}, {"efta_number": "EFTA00235326", "page_number": 195, "text_content": "\"AcooDLAMx \n(USAPISr \nealexAcos1aOusd \nci•0com \n10/11/2007 12:20 \nPM \nTo clelkowkz©Mrklend.com> \ncc \nboa \nSubject Re: \nI'm speaking to the PS bar at noon, but promised to \nattend their morning session from 9 to 10 30. \n7, 7 30 or even 8 am if that is better should give us \nplenty of time. \nThe convention center is 5 moan \naway. So I'm not leaving the hotel until 8 45. \nPick whatever is most convenient for you. \nAlex \nSent from my BlackBerry Wireless Handheld \n \nOriginal Message \nFrom: Jay Lefkowitz \nTo: Acosta, Alex (USAFLS < costa usa. o .gov> \nSent: Thu Oct 11 11:34:56 2007 \n111111111111111111mai \n****** *** ***** ******** ***************** \n* ***** ********* \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \n• \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmaster@kirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \nUS_Atty_Cor_001 95 \nEFTA00235521\n", "char_count": 1337}, {"efta_number": "EFTA00235326", "page_number": 196, "text_content": "_ \n'Acosta. Alex \n(USAFLSr \n<AlexAcostaawsd \n01-90v1' \n10/111200702:31 \nPM \nro sca \ncc \nbec \nSubject Fw: WPB Marriott 1001 Okeechobee Blvd. West Pah \nBeach, FL 33401 \nJay - see you at 7. Address is below. Alex. \nSent from my BlackBerry Wireless Handheld \n \nOriginal Message \nFrom: Castillo, Annette (0S.AFLS) \nCkpastillollusa.doj.gov> \nTo: Acosta, Alex (USAFLS) <AAcosta@usa.doj.gov> \nSent: Thu Oct 11 12:49:09 2007 \nSubject: WPB Marriott 1001 Okeechobee Blvd. West Palm \nBeach, FL 33401 \nUS_Atty_Cor_001 96 \nEFTA00235522\n", "char_count": 522}, {"efta_number": "EFTA00235326", "page_number": 197, "text_content": "(Cu \naStman. \nTo \"Jay LeficoeAtz\" \ncc \n.90V> \ntax \n10/1=007 \nSubJed RE: Addendum \n1 .28 PM \nTry 954-805-2013 \nFrom: Jay Leflcovalz [mallto:3LefkowittAbtand.com] \nSent Friday October 12, 2007 12:09 PM \nTo: Sloman, \n(USAFtS) \nSubject: Re: Addendum \n-- Original Mesats, --- \nFrom: \"Sloman, \n(USAFLS)\" \nSloman@usdoj.govj \nSent: 10/12/2007 09:48 AM AST \nTo: Jay Leflcowitz \nCc: \"Aco \nAlex \nSAFLS)\" <Alex.Acosts@usdoj.gov>; \n\"Villafana. \nSAFLS \" \nSubject RE: Addendum \nJay, \nI just got off the phone with Alex. Here is the revised paragraph I . \nThanks, II \n1. \nThe United States has the right to assign to an independent \nthird-party the responsibility for consulting with and, subject to the \ngood faith approval of Epstein's counsel, selecting the attorney \nrepresentative for the victims. If the United States elects to assign \nthis responsibility to an independent third-party, the United States \nretains the right to request that the independent third-party consult \nwith the United States after the preliminary selection but prior to \nthe final designation of the attorney representative. \nFrom: Jay LefkowItz (nailto:3LefkowttzOkirkland.com) \nSent: Thursday, October 11, 2007 3:12 PM \nUS_Atty_Cor_001 97 \nEFTA00235523\n", "char_count": 1220}, {"efta_number": "EFTA00235326", "page_number": 198, "text_content": "To: Stmana (USARS) \nSubject Re: Addendum \n1 \nOriginal Molar — \nFrom: \"Slornan,W(USAPIM\" PeftSloman@lusdoj.gov] \nSent 10/11/2007 12:17 PM AST \nTo: Jay Le&owitz \nCc \"Acosta, Alex (USAFLS)* <Alex.Acosta6usdoj.gov> \nSubject: Addendum \nJay, \nPursuant to our conversation. Thanks, \nIN RE: \nINVESTIGATION OF \nJEFFREY EPSTEIN \nUS_Atty_Cor_001 98 \nEFTA00235524\n", "char_count": 352}, {"efta_number": "EFTA00235326", "page_number": 199, "text_content": "ADDENDUM TO THE NON-PROSECUTION \nAGREEMENT \nIT APPEARING that the parties seek to clarify certain provisions \nof page 4, paragraph 7 of the Non-Prosecution Agreement \n(hereinafter \"paragraph 7\"), that agreement is modified as follows: \n1. \nThe United States has the right to assign to an independent \nthird-party, the responsibility for consulting with and, subject to the \ngood faith approval of Epstein's counsel, selecting the attorney \nrepresentative for the victims. If the United States elects to assign \nthis responsibility to an independent third-party, the United States \nretains the right to request that the independent third-party also \nconsult with the United States. \n2. \nPursuant to paragraph 7, Epstein has agreed to pay the fees of \nthe attorney representative. This provision, however, shall not \nobligate Epstein to pay the fees and costs of contested litigation \nfiled against him. Thus, if after consideration of potential \nsettlements, the attorney representative elects to file a contested \nlawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other \ncontested remedy, the paragraph 7 obligation to pay the costs of the \nattorney representative, as opposed to any statutory or other \nobligations to pay reasonable attorneys fees and costs such as those \ncontained in s 2255 to bear the costs of the attorney representative, \nshall cease. \nBy signing this Addendum, Epstein asserts and \ncertifies that the above has been read and explained to \nhim. Epstein hereby states that he understands the \nclarifications to the Non-Prosecution Agreement and \nagrees to comply with them. \nIL ALEXANDER \nACOSTA \nUNITED STATES \nUS_Atty_Cor_001 99 \nEFTA00235525\n", "char_count": 1678}, {"efta_number": "EFTA00235326", "page_number": 200, "text_content": "ATTORNEY \nDated: \nBy: \nATTORNEY \nDated: \nASSISTANT U.S. \nDated: \nJEFFREY EPSTEIN \nESQ. \nEPSTEIN \nDated: \nGERALD LEFCOURT, \nCOUNSEL TO JEFFREY \nESQ. \nLILLY \nSAI•ICHEZ, \nJEFFREY EPSTEIN \nATTORNEY FOR \nUS_Atty_Cor_00200 \nEFTA00235526\n", "char_count": 231}, {"efta_number": "EFTA00235326", "page_number": 201, "text_content": "The information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only for \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International LLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly prohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately by \nreturn e-mail or by e-mail to postmaster@kirkland.com, and \ndestroy this communication and all copies thereof; \nincluding all attachments. \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only for \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International LLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly prohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately by \nreturn e-mail or by e-mail to postmaster®kirldand.com, and \ndestroy this communication and all copies thereof, \nincluding all attachments. \n*******************•***** \n***** *M.*** \n******* ******** \nUS_Atty_Cor_00201 \nEFTA00235527\n", "char_count": 1341}, {"efta_number": "EFTA00235326", "page_number": 202, "text_content": "\"Sloni\nCa\nt•\n10(181200712:39 PM \n4:30 is fine. We'll call you. \nTo •Jay Left °wile \ncc \nboa \nSubject RE: \n \nOriginal Message \nFrom: Jay Lefkowitz (mailto: \nSent: Tuesday, October 16, 2. 1.1 \nTo: Sloman, \n(USAFLS) \nSubject: \n***** \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmaster@kirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \nUS_Atty_Cor_00202 \nEFTA00235528\n", "char_count": 893}, {"efta_number": "EFTA00235326", "page_number": 203, "text_content": "cis \nc400,40 \n10116/2007 04:00 PM \nTo •Jay Lefkowltf e../LetkowilziakIrktand.cos \ncc \nbcc \nSubject RE: Confidential - for settlement purpose' \nJay, \nThe below is exactly the same as yours, except for \ndeletion of \"Other than the joint written submission, \nneither the United States nor Epstein's counsel shall \ncommunicate with the independent third party nor shall \nthe United States communicate with the attorney \nrepresentative selected by him\" in your 1(a). \n1. The United States has the right to assign to an \nindependent third-party the responsibility for \nconsulting with and, subject to the good faith \napproval of Epstein's counsel, selecting the attorney \nrepresentative for the individuals identified under \nthe Agreement. If the United States elects to assign \nthis responsibility to an independent third-party, \nboth the United States and Epstein retain the right to \nmake good faith objections to the attorney \nrepresentative suggested by the independent \nthird-party prior to the final designation of the \nattorney representative. \n2. The parties will jointly prepare a short written \nsubmission to the independent third-party regarding \nthe role of the attorney representative and regarding \nEpstein's Agreement to pay such attorney \nrepresentative his or her regular customary hourly \nrate for representing such victims subject to the \nprovisions of paragraph 3, infra. \n3. Pursuant to additional paragraph 1, Epstein has \nagreed to pay the fees of the attorney representative \nselected by the independent third party. This \nprovision, however, shall not obligate Epstein to pay \nthe fees and costs of contested litigation filed \nagainst him. Thus, if after consideration of potential \nsettlements, an attorney representative elects to file \na contested lawsuit pursuant to 18 U.S.C. s 2255 or \nelects to pursue any other contested remedy, the \nparagraph 7 obligation of the Agreement to pay the \ncosts of the attorney representative, as opposed to \nany statutory or other obligation\n... [truncated, 2196 chars — for the full page use /api/corpus/document/EFTA00235326/203 or ?id=EFTA00235326&page=203]", "char_count": 2196}, {"efta_number": "EFTA00235326", "page_number": 204, "text_content": "From: Jay Lefkowitz [mailtoMIEMEle \nSent: Mondays..2ptober 15, 2007 10:53 AM \nTo: Sloman, \n(USAFLS) \nSubject: Confidential - for settlement purposes only \nUS_Atty_Cor_00204 \nEFTA00235530\n", "char_count": 187}, {"efta_number": "EFTA00235326", "page_number": 205, "text_content": "1 \nUS_Atty_Cor_00205 \nEFTA00235531\n", "char_count": 35}, {"efta_number": "EFTA00235326", "page_number": 206, "text_content": "\"Sloman \nov,\n10/17/2007 01:58 PM \nTo \"Jay Lefkowitz\" \ncc \nbcc \nSubject RE: \n<<071015 Special Master I.etter2.wpd>> Jay, \nHere's our proposed letter to the special master. \n \nOriginal Message \nFrom: Jay Lefkowitz (mailto \nSent: Tuesdaillictober 16, 2007 9:26 AM \nTo: Sloman, \n(USAFLS) \nSubject: \nS\nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Bllis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmaster@kirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \n0\n71015 Special /Metre Letter2.wpd \n• \nUS_Atty_Cor_00206 \nEFTA00235532\n", "char_count": 998}, {"efta_number": "EFTA00235326", "page_number": 207, "text_content": "S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave., Suite 400 \nWest Pabst Beach, P7 33401 \n(561) 820-8711 \nFaestertle: (561) 820-8777 \nOctober \n2007 \nPit \nDELIVERY BY FACSIMILE \nThe Hon. Edvvard B. Davis (Ret.) \nAkemmn Senterfitt \nOne Southeast Third Avenue, 25th Floor \nMiami, Florida 33131 \nRe: \nService as a Special Master \nDear Judge Davis: \nThank you for agreeing to save as a Special Master and for assisting the United \nStates Attorney's Office in the selection of an attorney representative to represent a group \nof identified victims. This letter is meant to assist you in performing your duties by \nproviding you with background information regarding the agreement between the United \nStates and Jeffrey Epstein and the duties that the attorney representative will have to \nperform. \nThe Federal Bureau of Investigation and the U.S. Attorney's Office conducted an \ninvestigation of Mr. Epstein. As a result of that investigation, the U.S. Attorney's Office \nand Mr. Epstein entered into a Non-Prosecution Agreement and an Addendum that \ncontains, inter cilia, the following terms: \n7(a)The United States has the right to assign to an independent third-party the responsibility \nfor consulting with and, subject to the good faith approval of Epstein's counsel, selecting the \nattorney representative for the individuals identified under the Agreement. If the United \nStates elects to assign this responsibility to an independent third-party, both the United States \nand Epstein retain the right to make good faith objections to the attorney representative \nUS_Atty_Cor_00207 \nEFTA00235533\n", "char_count": 1653}, {"efta_number": "EFTA00235326", "page_number": 208, "text_content": "The Hon. Edward B. Davis (Ret.) \nOctober ___ 2007 \nPage 2 of 4 \nsuggested by the independent third•party prior to the final designation of the attorney \nrepresentative. \n7(b)The parties will jointly prepare a short written submission to the independent third-party \nregarding the role of the attorney representative and regarding Epstein's Agreement to pay \nsuch attorney representative his or her regular customary hourly rate for representing such \nvictims subject to the provisions of paragraph 7(c), infra. \n7(c). Pursuant to additional paragraph 7(a), Epstein has agreed to pay the fees of the attorney \nrepresentative selected by the independent third party. This provision, however, shall not \nobligate Epstein to pay the fees and costs of contested litigation filed against him. Thus, If \nafter consideration of potential settlements, an attorney representative elects to file a contested \nlawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested remedy, the \nparagraph 7 obligation of the Agreement to pay the costs of the attorney representative, as \nopposed to any statutory or other obligations to pay reasonable attorneys fees and costs such \nas those contained ins 2255 to bear the costs of the attorney representative, shall cease. \n8.If any of the individuals referred to [in the paragraphs above] elects to file \nsuit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction \nof the United States District Court for the Southern District of Florida over \nhis person and/or the subject matter, and Epstein waives his right to contest \nliability and also waives his right to contest damages up to an amount \nagreed to between Epstein and the identified individual, so long as the \nidentified individual elects to proceed exclusively under 18 U.S.C. § 2255, \nand agrees to waive any other claim for damages, whether pursuant to state, \nfederal, or common law. Notwithstanding this waiver, with respect to those \nindividuals whose names appear on the l\n... [truncated, 2985 chars — for the full page use /api/corpus/document/EFTA00235326/208 or ?id=EFTA00235326&page=208]", "char_count": 2985}, {"efta_number": "EFTA00235326", "page_number": 209, "text_content": "The Hon. Edward B. Davis (Ret) \nOctober _ 2007 \nPage 3 of 4 \nThe most recent version of the statute referenced above, 18 U.S.C. § 2255, \nprovides that: \nMy person who, while a minor, was a victim of a violation of section . . . \n2422 or 2423 of this title and who suffers personal injury as a result of such \nviolation, regardless of whether the injury occurred while such person was a \nminor, may sue in any appropriate United States District Court and shall \nrecover the actual damages such person sustains and the cost of the suit, \nincluding a reasonable attorney's fee. Any person as described in the \npreceding sentence shall be deemed to have sustained damages of no less \nthan S150,000 in value. \nSection 2422 prohibits the use of a facility of interstate commerce to induce minors \nto engage in sexual activity and prostitution, and section 2423 prohibits interstate travel \nfor the purpose of engaging in sexual activity or prostitution with minors. The United \nStates has identified \nvictims as defmed by this statute. \nDue to the circumstances of the case and the number and caliber of the attorneys \nwho represent Mr. Epstein, in selecting the victims' attorney representative, the United \nStates suggests that you consider the following criteria: \n1. \nExperience doing both plaintiffs' and defense litigation. \n2. \nExperience with state and federal statutory and common law tort claims. \n3. \nThe ability to communicate effectively with young women (the victims' \ncurrent ages are between 16 and 24). \n4. \nEmployment with a firm large enough to handle the possibility of at least a \ndozen trials at the same time. \n5. \nExperience litigating against large law firms and high profile attorneys. \n6. \nSensitivity to the nature of the suit and the victims' interest in maintaining \ntheir privacy. \n7. \nExperience litigating in federal court in the Southern District of Florida. \nUS_Atty_Cor_00209 \nEFTA00235535\n", "char_count": 1920}, {"efta_number": "EFTA00235326", "page_number": 210, "text_content": "The Hon. Edward B. Davis (Ret.) \nOctober \n2007 \nPage 4 of 4 \n8. \nThe resources to hire experts and others, while working on a contingency \nfee basis, in order to prepare for trial, if a settlement cannot be reached. \n9. \nThe ability to negotiate effectively. \nPursuant to this letter, the United States assigns to you the responsibility for \nconsulting with and selecting the attorney representative for the individuals. The United \nStates and Epstein retain the right to make good faith objections to the attorney \nrepresentative you select prior to the final designation of the attorney representative. In \nthat regard, after you have reached a decision regarding the attorney x‘incaentative, please \nprovide me with his or her name and contact information. \nIf I can provide you with any further information, please do not hesitate to contact \nme. Thank you again for your assistance with this matter. \nSincerely, \nR. Alexander Acosta \nUnited States Attorney \nBy: \nJeffrey Sloman \nFirst Assistant United States Attorney \ncc: \nAUSA \nUS_Atty_Cor_00210 \nEFTA00235536\n", "char_count": 1067}, {"efta_number": "EFTA00235326", "page_number": 211, "text_content": "0 \n'Acosta. Alex \n(USAFLS)' \n<AdexAcostagou \nsdoj.govv \n10118/2007 1229 \nPM\nve\n.43340: evi \nTo \"JayLeflamAdm<JLekowitz@lthkMndcoma \ncc \"Woman, ■ (USAFLS)' \nbcc \nSubjed RE:Fdikmmup \nla\n-- Can you see any issues with this? If not, \nse confirm with \nJay. \n-----Original Message \nFrom: Jay Lefkowitz (mailto:pripaMMI \nSent: Thursday, October 18, \nTo: Acosta, Alex (USAFLS) \nSubject: Follow up \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmasterOkirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \nUS_Atty_Cor_00211 \nEFTA00235537\n", "char_count": 1052}, {"efta_number": "EFTA00235326", "page_number": 212, "text_content": "Jay, \n\"Sloman, \nus .gov> \n10/18/2007 \nSubject RE:Folkwyup \n05:43 PM \n \n'neSt\ntratSit\ntp s0 \nTo -JaylefltovAte \ncc 'Acosta, Alex (USAFLS)\" <AlexAcosta@usd0j.gov4: \nboo \nPlease confirm that this will not affect when Epstein \nbegins serving his sentence. If it does, I have to \nreconsider postponement of the guilty plea date. \nThanks, \n \nOriginal Message \nFrom: Jay Lefkowitz (mailto:FIRRI\n) \nSent: Thursda \nOctober 18, \nTo: Sloman, \n(USAFLS) \nCc: Acosta, \nex (USAFLS) \nSubject: Re: Follow up \n \n Original Message  \nFrom: \"Sloman, \n(USAFLS)\"\nSent: 10/18/200 \n:39 PM AST \nTo: Jay Lefkowitz \nCc: \"Acosta, Alex (USAFLS)\" <Alex.Acostaeusdoj.gov> \nSubject: RE: Follow up \nThe change of plea will take place on November 20. \nAgreed. \n \nOriginal Message \nFrom: Jay Lefkowitz (mailto:1111.1\n) \nSent: Thursday, October 18, \nTo: Acosta, Alex (USAFLS) \nCc: Sloman, III' (USAFLS) \nSubject: Re: Follow up \n \n Original Message  \nFrom: \"Acosta, Alex (USAFLS)\" (Alex.Acosta8usdoj.gov) \nSent: 10/18/2007 12:15 PM AST \nTo: Jay Lefkowitz \nCc: \"Sloman, \n(USAFLS)\" < \nUS_Atty_Cor_0021 2 \nEFTA00235538\n", "char_count": 1078}, {"efta_number": "EFTA00235326", "page_number": 213, "text_content": "Subject: RE: Follow up \nCan you see any issues with this? If not, \nplease confirm with \nJay. \n-----Original Message \nFrom: Jay Lefkowitz (mailto: \nSent: Thursday, October 18, 2007 10:12 AM \nTo: Acosta, Alex (USAFI08) \nSubject: Follow up \n**tee \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the add \n. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmaster@kirkland.00a, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nUS_Atty_Cor_0021 3 \nEFTA00235539\n", "char_count": 1063}, {"efta_number": "EFTA00235326", "page_number": 214, "text_content": "for \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmaster@kirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmasterfkirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \nUS_Atty_Cor_00214 \nEFTA00235540\n", "char_count": 1133}, {"efta_number": "EFTA00235326", "page_number": 215, "text_content": "Jay, \nThe Judge Davis issue is a non-starter. We've beaten \nthat horse to death. Regarding your contention that \n\"the attorney representative be told clearly that Mr. \nEpstein has agreed to pay the lawyer's hourly rate \nonly for the time he or she spends working to \neffectuate settlements for the identified women,\" Alex \nand I agree that paragraph 7C is sufficient, \nRegarding the other points, we have made the following \nconcessions: \n1. \nRegarding the language concerning a \nlawyer whose firm is sizeable enough to litigate \nmultiple trials simultaneously, I have removed \nparagraph 4 on page 3 of the letter. \n2. \nRegarding the 15Ok statutory limit \nlanguage, I have included a footnote which should \nsatisfy your concern. \n3. \nRegarding language there may be \ndiscovery to test the claims of alleged \"victims\", \nplease see new paragraph 4 on page 3 which now states \nas criteria that the firm should have \"Experience \nlitigating against large law firms and high profile \nattorneys who may test the veracity of the victims' \nclaims.\" \nI have attached the Addendum and the revised letter to \nJudge Davis. Jay, this needs to be concluded. Alex and \nI believe that this is as far as we can go. Therefore, \nplease advise me whether we have a deal no later than \nCOB tomorrow, Tuesday, October 23, 2007. Thanks, \n \nOriginal Message \nFrom: Jay Lefkowitz (mailto:11\n) \nSent: Friday October 19, 20 \n: \nTo: Sloman, \n(USAFLS) \nSubject: Re: \nO \nUS_Atty_Cor_0021 5 \nEFTA00235541\n", "char_count": 1473}, {"efta_number": "EFTA00235326", "page_number": 216, "text_content": "(z) \n \n Original Message  \nFrom: \"Sloman, \n(USAFLS)\" \nSent: 10/17/200761:58 PM AST \nTo: Jay Lefkowitz \nSubject: RE: \n«071015 Special Master Letter2.wpd>> Jay, \nHere's our proposed letter to the special master. \n \nOriginal Message \nFrom: Jay Lefkowitz (mailto: \nSent: Tuesdayk pctober 16, 211.11 \nTo: Sloman, \n(USAFLS) \nSubject: \n♦•+fr \nThe information contained in this communication is \nUS_Atty_Cor_0021 6 \nEFTA00235542\n", "char_count": 421}, {"efta_number": "EFTA00235326", "page_number": 217, "text_content": "confidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmasterekirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmaster@kirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \n* • • • • \nUS_Atty_Cor_0021 7 \nEFTA00235543\n", "char_count": 1252}, {"efta_number": "EFTA00235326", "page_number": 218, "text_content": "a \n<\noma; tursr \n'S  Jeff.Slorn \noj.gov• \n10/22/2007 05:23 PM \nTo cLefkowitz@lOrldand.00m> \ncc \nboc \nSubl•c1 Re: Epstein \nI have not spoken to him but it was our intention to \nassign the decision to select a lawyer to Judge Davis \nnot for him to represent the girls. We do not want to \nselect the lawyer who represents the girls. I don't \nknow who said he'd do it but it wasn't us. \nSent from my BlackBerry Wireless Handheld \n \n Original Messagamm\n.\nFrom: Jay Le\nittz < \nTo: Sloman, \n(USAFLS) \nCc: Acosta, Alex (USAFLS); \n(USAFLS) \nSent: Mon Oct 22 17:10:00 2007 \nSubject: Re: Epstein \n< \n\"Sloman, a \n(USAFLS)\" \n10/22/2007 04:40 PM \nTo \n\"Jay Lefkowitz\" < \ncc \n\"Acosta, Ale \n\" \n<Alex.Acost \n(USAFLS). < \nSubject \nEpstein \nUS_Atty_Cor_0021 8 \nEFTA00235544\n", "char_count": 754}, {"efta_number": "EFTA00235326", "page_number": 219, "text_content": "Or\n'\n \n,\n \n.1 \n10/23/2007 05:36 PM \nTo \"Jay Lelkowitz\" <JLefkovitz@kIrklend.cot \ncc \"Acosta, Alex (USAFLS)\" <Alex.Acoein@ \nbcc \nSubject RE: Epstein \no\nt \nditt. \n. \nJay, \nCan't speak tonight. Won't send It out tonight. I'll check with Alex In \nthe morning and will call you then. \nS \nFrom: Jay Leficowitr [mallto:3Leflowit@kirkland.com] \nSent Tuesdays pctober 23, 2007 5:34 PM \nTo: Sloman, \n(USARS) \nCa Acosta, Alex (USARS) \nSubject Epstein \nIIIIIIIIII \n********** ******* ***** ******************** *********** * \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the add \n It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmasterekirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \n* • * * * \nUS_Atty_Cor_00219 \nEFTA00235545\n", "char_count": 1182}, {"efta_number": "EFTA00235326", "page_number": 220, "text_content": "alat\nipUSAPLS)\" \nusdoj.gov> \n10/24/2007 03:45 PM \nTo \ncc \n'Jay Lefkowtte \n\"Ae \n(USAPIS)' eAlex.AcostaeusdoLgov> \nbcc \nSubject Epstein Addendum and Letter to Judge \n<<Addenclum.vmd>> <<011015 Special Muter Letter4.wpd>> \nJay, \nPursuant to our conversation, here is the revised letter and a new \naddendum. Theonly changeto the addendumisthat I renumbered the \nnew paragraphs from A,B, and C to 7A, 7B, and 7C.Once you \napprove,I will contact Judge Davis and send him the letter. Please \nexecute the addeadum,PDFthe executedoriginalto me as soon as \npossible and Fed Ex the original to me thereafter. \n«< Attachment 'Addendum.wed' has been archived by user \ntommonStore/IT/kiricland-Eills' on '12/25/2007 00:26:41'. >n \n«< Attachment '071015 Special Master Letter4.wod' has been \narchived by user 'CorninonStore/f17KIddand-Ellis' on '12/25/2007 \n00:28:42', >>> \nUS_Atty_Cor_00220 \nEFTA00235546\n", "char_count": 891}, {"efta_number": "EFTA00235326", "page_number": 221, "text_content": "IN RE: \nINVESTIGATION OF \nJEFFREY EPSTEIN \nADDENDUM TO THE NON-PROSECUTION AGREEMENT \nIT APPEARING that the parties seek to clarify certain provisions of page 4, \nparagraph 7 of the Non-Prosecution Agreement (hereinafter \"paragraph 7\"), that \nagreement is modified as follows: \n7A. \nThe United States has the right to assign to an independent third-party the \nresponsibility for consulting with and, subject to the good faith approval of \nEpstein's counsel, selecting the attorney representative for the individuals \nidentified under the Agreement. \nIf the United States elects to assign this \nresponsibility to an independent third-party, both the United States and Epstein \nretain the right to make good faith objections to the attorney representative \nsuggested by the independent third-party prior to the final designation of the \nattorney representative. \n7B. \nThe parties will jointly prepare a short written submission to the independent \nthird-party regarding the role of the attorney representative and regarding Epstein's \nAgreement to pay such attorney representative his or her regular customary hourly \nrate for representing such victims subject to the provisions of paragraph C, infra. \n7C. \nPursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the \nattorney representative selected by the independent third party. This provision, \nhowever, shall not obligate Epstein to pay the fees and costs of contested litigation \nfiled against him. Thus, if after consideration of potential settlements, an attorney \nrepresentative elects to file a contested lawsuit pursuant to 18 U.S.C. s 2255 or \nelects to pursue any other contested remedy, the paragraph 7 obligation of the \nAgreement to pay the costs of the attorney representative, as opposed to any \nstatutory or other obligations to pay reasonable attorneys fees and costs such as \nthose contained in s 2255 to bear the costs of the attorney representative, shall \ncease. \nBy signing this Addendum, Epstein asserts a\n... [truncated, 2166 chars — for the full page use /api/corpus/document/EFTA00235326/221 or ?id=EFTA00235326&page=221]", "char_count": 2166}, {"efta_number": "EFTA00235326", "page_number": 222, "text_content": "Non-Prosecution Agreement and agrees to comply with them. \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \n0 \nDated: \nDated: \nDated: \nDated: \nBy:\nASSISTANT U.S. ATTORNEY \nJEFFREY EPSTEIN \nGERALD LEFCOURT, ESQ. \nCOUNSEL TO JEFFREY EPSTEIN \nLILLY \nSANCHEZ, ESQ. \nATTORNEY FOR JEFFREY EPSTEIN \nUS_Atty_Cor_00222 \nEFTA00235548\n", "char_count": 320}, {"efta_number": "EFTA00235326", "page_number": 223, "text_content": "S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n99 NE es Street \nMims; FL 33132-2111 \n(305) 961-9299 \nFacsimile (305) 5304444 \nOctober \n2007 \n2 \nDELIVERY BY FACSIMILE \nThe Hon. Edward B. Davis (Ret.) \nAlterman Senterfitt \nOne Southeast Third Avenue, 25th Floor \nMiami, Florida 33131 \nRe: \nService as a Special Master \nDear Judge Davis: \nThank you for agreeing to serve as a Special Master and for assisting the United \nStates Attorney's Office in the selection of an attorney representative to represent a group \nof identified victims. This letter is meant to assist you in performing your duties by \nproviding you with background information regarding the agreement between the United \nStates and Jeffrey Epstein and the duties that the attorney representative will have to \nperform. \nThe Federal Bureau of Investigation and the U.S. Attorney's Office conducted an \ninvestigation of Mr. Epstein. As a result of that investigation, the U.S. Attorney's Office \nand Mr. Epstein entered into a Non-Prosecution Agreement and an Addendum that \ncontains, inter alki, the following terms: \n7A. The United States has the right to assign to an independent third-party \nthe responsibility for consulting with and, subject to the good faith approval \nof Epstein's counsel, selecting the attorney representative for the individuals \nidentified under the Agreement. If the United States elects to assign this \nUS_Atty_Cor_00223 \nEFTA00235549\n", "char_count": 1461}, {"efta_number": "EFTA00235326", "page_number": 224, "text_content": "The Hon. Edward B. Davis (Ret.) \nOctober \n2007 \nPage 2 of 4 \nresponsibility to an independent third-party, both the United States and \nEpstein retain the right to make good faith objections to the attorney \nrepresentative suggested by the independent third-party prior to the final \ndesignation of the attorney representative. \n7B. The parties will jointly prepare a short written submission to the \nindependent third-party regarding the role of the attorney representative and \nregarding Epstein's Agreement to pay such attorney representative his or \nher regular customary hourly rate for representing such victims subject to \nthe provisions of paragraph 7C, infra. \n7C. Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees \nof the attorney representative selected by the independent third party. This \nprovision, however, shall not obligate Epstein to pay the fees and costs of \ncontested litigation filed against him. Thus, if after consideration of \npotential settlements, an attorney representative elects to file a contested \nlawsuit pursuant to 18 U.S.C. § 2255 or elects to pursue any other contested \nremedy, the paragraph 7 obligation of the Agreement to pay the costs of the \nattorney representative, as opposed to any statutory or other obligations to \npay reasonable attorneys fees and costs such as those contained in § 2255 to \nbear the costs of the attorney representative, shall cease. \n8If any of the individuals referred to [in the paragraphs above] elects to file \nsuit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction \nof the United States District Court for the Southern District of Florida over \nhis person and/or the subject matter, and Epstein waives his right to contest \nliability and also waives his right to contest damages up to an amount \nagreed to between Epstein and the identified individual, so long as the \nidentified individual elects to proceed exclusively under 18 U.S.C. § 2255, \nand agrees to waive any other claim f\n... [truncated, 2667 chars — for the full page use /api/corpus/document/EFTA00235326/224 or ?id=EFTA00235326&page=224]", "char_count": 2667}, {"efta_number": "EFTA00235326", "page_number": 225, "text_content": "The Hon. Edward B. Davis (Ret) \nOctober \n2007 \nPage 3 of 4 \n10.Except as to those individuals who elect to proceed exclusively under 18 \nU.S.C. § 2255, as set forth in [the above paragraphs], neither Epstein's \nsignature on this agreement, nor its terms, nor any resulting waivers or \nsettlements by Epstein are to be construed as admissions or evidence of \ncivil or criminal liability or a waiver of any jurisdictional or other defense \nas to any person, whether or not her name appears on the list provided by \nthe United States. \nThe most recent version of the statute referenced above, 18 U.S.C. § 2255, \nprovides that: \nAny person who, while a minor, was a victim of a violation of section . . . \n2422 or 2423 of this title and who suffers personal injury as a result of such \nviolation, regardless of whether the injury occurred while such person was a \nminor, may sue in any appropriate United States District Court and shall \nrecover the actual damages such person sustains and the cost of the suit, \nincluding a reasonable attorney's fee. Any person as described in the \npreceding sentence shall be deemed to have sustained damages of no less \nthan $150,000 in value.' \nSection 2422 prohibits the use of a facility of interstate commerce to induce minors \nto engage hi sexual activity and prostitution, and section 2423 prohibits interstate travel \nfor the purpose of engaging in sexual activity or prostitution with minors. The United \nStates has identified 34 victims as defined by this statute. \nPursuant to this letter, the United States assigns to you the responsibility for \nconsulting with and selecting the attorney representative for the individuals. The United \nStates and Epstein retain the right to make good faith objections to the attorney \nrepresentative you select prior to the final designation of the attorney representative. In \nthat regard, after you have reached a decision regarding the attorney representative, please \nprovide me with his or her name and contact infor\n... [truncated, 2199 chars — for the full page use /api/corpus/document/EFTA00235326/225 or ?id=EFTA00235326&page=225]", "char_count": 2199}, {"efta_number": "EFTA00235326", "page_number": 226, "text_content": "The Hon. Edward B. Davis (Ret) \nOctober _ 2007 \nPage 4 of 4 \nIf I can provide you with any further information, please do not hesitate to contact \nme. Thank you again for your assistance with this matter. \nSincerely, \nIt, Alexander Acosta \nUnited States Attorney \nBy: \nJeffrey Sloman \nFirst Assistant United States Attorney \ncc: \nAUSA \nUS_Atty_Cor_00226 \nEFTA00235552\n", "char_count": 368}, {"efta_number": "EFTA00235326", "page_number": 227, "text_content": "oklon \n10,24/2007 04:25 PM \n3059619299 \nTo MMIIIMB.,\ncc\nbcc \nSubject Re: \nSent from my BlackBerry Wireless Handheld \n \n Original Message  \nFrom: Jay \nitz <JLefkowitzekirkland.com> \nTo: Sloman\n (OWLS) \nSent: Wed Oct 24 16:23:05 2007 \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmaster@kirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all Attachments. \n******* *****&& ******* & ********* \n****** \n***** ***** \nUS_Atty_Cor_00227 \nEFTA00235553\n", "char_count": 953}, {"efta_number": "EFTA00235326", "page_number": 228, "text_content": "\"\nS\nl\no\nm\n \na\n \nn\n,\n \n■ \n1\n1\n1\n1\n.\n0\n'\nOMWY. \n10/24/2007 05:30 \nPM \nTo \"Jay Leflcowite < \ncc \nUSAFLST \nadoj.govo, \"Acosta. Alex \n(USAFLS)\" <Alex_Acoste©usdoLgov> \nbcc \nSubject Epstein - Letter to Judge Davis \nJay, \nHere is the latest and hopefully final version of the letter to Judge \nDavis. \nS \n<<071015 Special Master Letter5.µpd>> \n«e Attachment '071015 Special Master LetW/5,werr IPS beam_ \narchived by user 'CommonStore/IT/Ktridend-Ellist en '12/25/2007 \nQ0:27:04'. >» \nUS_Atty_Cor_00228 \nEFTA00235554\n", "char_count": 508}, {"efta_number": "EFTA00235326", "page_number": 229, "text_content": "S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave., Suite 400 \nWest Palm Beach. FL 33401 \n(561) 8204711 \nFacsimile: (561) 820-8777 \nOctober \n2007 \nDELIVERY BY FACSIMILE \nThe Hon. Edward B. Davis (Ret.) \nAkerman Senterfitt \nOne Southeast Third Avenue, 25th Floor \nMiami, Florida 33131 \nRe: \nService as a Special Master \nDear Judge Davis: \nThank you for agreeing to serve as a Special Master and for assisting the United \nStates Attorney's Office in the selection of an attorney representative to represent a group \nof identified victims. This letter is meant to assist you in performing your duties by \nproviding you with background information regarding the agreement between the United \nStates and Jeffrey Epstein and the duties that the attorney representative will have to \nperform. \nThe Federal Bureau of Investigation and the U.S. Attorney's Office conducted an \ninvestigation of Mr. Epstein. As a result of that investigation, the U.S. Attorney's Office \nand Mr. Epstein entered into a Non-Prosecution Agreement and an Addendum that \ncontains, inter alio, the following terms: \n7A. The United States has the right to assign to an independent third-party \nthe responsibility for consulting with and, subject to the good faith approval \nof Epstein's counsel, selecting the attorney representative for the individuals \nidentified under the Agreement. If the United States elects to assign this \nUS_Atty_Cor_00229 \nEFTA00235555\n", "char_count": 1485}, {"efta_number": "EFTA00235326", "page_number": 230, "text_content": "The Hon. Edward B. Davis (Res.) \nOctober \n2007 \nPage 2 of 4 \nresponsibility to an independent third-party, both the United States and \nEpstein retain the right to make good faith objections to the attorney \nrepresentative suggested by the independent third-party prior to the final \ndesignation of the attorney representative. \n7B. The parties will jointly prepare a short written submission to the \nindependent third-party regarding the role of the attorney representative and \nregarding Epstein's Agreement to pay such attorney representative his or \nher regular customary hourly rate for representing such victims subject to \nthe provisions of paragraph 7C, infra. \n7C. Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees \nof the attorney representative selected by the independent third party. This \nprovision, however, shall not obligate Epstein to pay the fees and costs of \ncontested litigation filed against him. Thus, if after consideration of \npotential settlements, an attorney representative elects to file a contested \nlawsuit pursuant to 18 U.S.C. § 2255 or elects to pursue any other contested \nremedy, the paragraph 7 obligation of the Agreement to pay the costs of the \nattorney representative, as opposed to any statutory or other obligations to \npay reasonable attorneys fees and costs such as those contained in § 2255 to \nbear the costs of the attorney representative, shall cease. \n8.1f any of the individuals referred to [in the paragraphs above] elects to file \nsuit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction \nof the United States District Court for the Southern District of Florida over \nhis person and/or the subject matter, and Epstein waives his right to contest \nliability and also waives his right to contest damages up to an amount \nagreed to between Epstein and the identified individual, so long as the \nidentified individual elects to proceed exclusively under 18 U.S.C. § 2255, \nand agrees to waive any other claim \n... [truncated, 2668 chars — for the full page use /api/corpus/document/EFTA00235326/230 or ?id=EFTA00235326&page=230]", "char_count": 2668}, {"efta_number": "EFTA00235326", "page_number": 231, "text_content": "The Hot Edward B. Davis (Ret.) \nOctober_ 2007 \nPage 3 of 4 \n10.Except as to those individuals who elect to proceed exclusively under 18 \nU.S.C. § 2255, as set forth in [the above paragraphs], neither Epstein's \nsignature on this agreement, nor its terms, nor any resulting waivers or \nsettlements by Epstein are to be construed as admissions or evidence of \ncivil or criminal liability or a waiver of any jurisdictional or other defense \nas to any person, whether or not her name appears on the list provided by \nthe United States. \nThe most recent version of the statute referenced above, 18 U.S.C. § 2255, \nprovides that: \nAny person who, while a minor, was a victim of a violation of section . .\n2422 or 2423 of this title and who suffers personal injury as a result of such \nviolation, regardless of whether the injury occurred while such person was a \nminor, may sue in any appropriate United States District Court and shall \nrecover the actual damages such person sustains and the cost of the suit, \nincluding a reasonable attorney's fee. Any person as described in the \npreceding sentence shall be deemed to have sustained damages of no less \nthan $150,000 in value.' \nSection 2422 prohibits the use of a facility of interstate commerce to induce minors \nto engage in sexual activity and prostitution, and section 2423 prohibits interstate travel \nfor the purpose of engaging in sexual activity or prostitution with minors. The United \nStates has identified 34 victims as defined by this statute. The United States takes no \nposition as to the validity of any such claim under this statute. \nDue to the circumstances of the case and the number and caliber of the attorneys \nwho represent Mr. Epstein, in selecting the victims' attorney representative, the United \nStates suggests that you consider the following criteria: \n1. \nExperience doing both plaintiffs' and defense litigation. \n2. \nExperience with state and federal statutory and common law tort claims. \n3. \nThe ability to communicate\n... [truncated, 2224 chars — for the full page use /api/corpus/document/EFTA00235326/231 or ?id=EFTA00235326&page=231]", "char_count": 2224}, {"efta_number": "EFTA00235326", "page_number": 232, "text_content": "The lion. Edward B. Davis (Ret) \nOctober _ 2007 \nPage 4 of 4 \n4. \nExperience litigating against large law firms and high profile attorneys who \nmay test the veracity of the victims' claims. \n5. \nSensitivity to the nature of the suit and the victims' interest in maintaining \ntheir privacy. \n6. \nExperience litigating in federal court in the Southern District of Florida. \n7. \nThe resources to hire experts and others, while working on a contingency \nfee basis, in order to prepare for trial, if a settlement cannot be reached (defense \ncounsel has reserved the right to challenge such litigation). \n8. \nThe ability to negotiate effectively. \nPursuant to this letter, the United States assigns to you the responsibility for \nconsulting with and selecting the attorney representative for the individuals. The United \nStates and Epstein retain the right to make good faith objections to the attorney \nrepresentative you select prior to the final designation of the attorney representative. In \nthat regard, after you have reached a decision regarding the attorney representative, please \nprovide me with his or her name and contact information. \nIf I can provide you with any further information, please do not hesitate to contact \nme and/or the U.S. Attorne \nefkowitz, Esq. on behalf of Epstein. Mr. \nLefkowitz can be reached at \n- Kirkland & Ellis LLP, Citigroup Center, \n153 East 53'd Street, New York, New York 10022-4611. Thank you again for your \nassistance with this matter. \nSincerely, \nR. Alexander Acosta \nUnited States Attorney \nBy: \nJeffrey Sloman \nFirst Assistant United States Attorney \ncc: \nAUSA \nUS_Atty_Cor_00232 \nEFTA00235558\n", "char_count": 1641}, {"efta_number": "EFTA00235326", "page_number": 233, "text_content": "\"Slornanli \no \nON \n10/30/2007 02:42 PM \nTo -Jay Lefkowite 411=MIS \ncc \"Acosta, Alex (USAFLS)\" cAlex.AcostalgAin403-0 \nbcc \nSubject Epstein \n \nain:nras \nTitimaphW \nJay, \nHere is an executed version of the addendumPleaseFed Ex the \noriginal signature pages to me. Thanks, \nS \n<<epstein addendum 10 3 0.pdf>> \n«< Ma &gent 'eostein addendum 10 30.pdf has been archived by_ \nuser VommonStore/IT/KIrkland-Ellis' on '12/31/2007 23:47:35'. >>> \nUS_Atty_Cor_00233 \nEFTA00235559\n", "char_count": 469}, {"efta_number": "EFTA00235326", "page_number": 234, "text_content": "Di RE: \nINVESTIGATION OF \nJEFFREY EPSTEIN \nADDENDUM TO TIM NON-PROSECIMbN AGREEMENE \nIT APPEARING that the parties seek to clarify certain provisions of page 4, paragraph 7 \nof the Non-Prosecution Agreement (hereinafter \"paragraph T'), that agreement is modified as \nfollows: \n7A. \nThe United States has the right to assign to an independent third-party the responsibility \nfor consulting with and, subject to the good faith approval of Epstein's counsel, selecting \nthe attorney representative for the individuals identified under the Agreement. If the \nUnited States elects to assign this responsibility to an Independent third-party, both the \nUnited States and Epstein retain the right to make good faith objections to the attorney \nrepresentative suggested by the independent third-party prior to the final designation of \nthe attorney representative. \nThe parties will jointly prepare a short written submission to the independent third-party \nregarding the role of the attorney representative and regarding Epstein's Agreement to \npay such attorney representative his or her regular customary hourly rate for representing \nsuch victims subject to the provisions of paragraph C, infra. \n7C. \nPursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the attorney \nrepresentative selected by the independent third party. This provision, however, shall not \nobligate Epstein to pay the fees and costs of contested litigation filed against him. Thus, \nif after consideration of potential settlements, an attorney representative elects to file a \ncontested lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested \nremedy, the paragraph 7 obligation of the Agreement to pay the costs of the attorney \nrepresentative, as opposed to any statutory or other obligations to pay reasonable \nattorneys fees and costs such as those contained in a 2255 to bear the costs of the attorney \nrepresentative, shall cease. \nUS_Atty_Cor_00234 \nEFTA00235560\n", "char_count": 1980}, {"efta_number": "EFTA00235326", "page_number": 235, "text_content": "By signing this Adcknduzn, Epstein asserts and certifies that the above has been read and \nexplained to Mit. Epstein hereby, states that he understands the clarifications to the Non-\nProsecutiorrAgettIndnt and agrees to comply with than. \nR. ALEXANDE.R. ACOSTA \nUNITED STATES ATTORNEY \nDated:  /0/3 OA 7 \nDated: \nDated: \nDated: \nBy: \nVILLAYANA \nASSISTANT U.S. ATTORNEY \n' eafak4a4A--\nGERALD LEFCOURT, ESQ. - \nCOUNSEL TO YEFFREY EPSTEDI \nLILLY.' SANCHEZ, ESQ. \nATTORNEY POR JEFFREY EPSTEIN \nUS_Atty_Cor_00235 \nEFTA00235561\n", "char_count": 522}, {"efta_number": "EFTA00235326", "page_number": 236, "text_content": "By signing this Addendum, Epstein asserts and certifies that the above has been read and \nexplained to hlm. Epstein hereby states that he understands the clarifications to the Noc-\nProsecution Agreement and agrees to comply with them. \nDated:  /0 ASO \nDated: \nDated: \nDated: \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nBy: \nV . \ntindi \nFA t) EA \nA A. MARIE VILLAFASIA \nASSISTANT U.S. ATTORNEY \nL1LLYIIIISANCREZ, ESQ. \nATTORNEY FOR JEFFREY EPSTEIN \nUS_Atty_Cor_00236 \nEFTA00235562\n", "char_count": 482}, {"efta_number": "EFTA00235326", "page_number": 237, "text_content": "By signing this Addendum, Epstein asserts and cenithes that the above has been read and \nexplained to him. Epstein hereby WM that he understands the clarificadons to the Non-\nProsecution Agreement end agrees to comply with than. \nR. ALEXANDER ACOSTA \nUNTIED STATES ATTORNEY \nDam  ii/3 Wo 1 \n• \nDated: \nDined: \nWed: ithlgaia\n.\nBr --tIt2-74 1-604.-- mum \n,6 a&LAFAPIA \nASSISTANT U.S. ATTORNEY \nJEFFREY EPSTEIN \nGERALD LEFCOURT, ESQ. \nCOUNSEL TO JEFFREY EPSTEIN \nATTORNEY FOR JEFFREY EPSTEIN \nUS_Atty_Cor_00237 \nEFTA00235563\n", "char_count": 522}, {"efta_number": "EFTA00235326", "page_number": 238, "text_content": "\"Slomen, \ns \n.gova \n10/30/2007 05:38 \nPM \nJay, \nTo \"Jay Lefkowite <JLefkowitz@kirldand.com> \ncc \nboa \nSubject RE: Epstein \nI called Judge Davis before I sent him the agreed upon letter. He \nindicated his willingness to serve as the \"decider? I will call him \ntomorrow to see whether anything has changed and when we can \nanticipate a decision. Regarding the subpoena question, let me \nthink about that overnight. Thanks, \nS \nFrom: Jay Lefkowltz [mallto:JLefkowitz@kirkland.com) \nSent: Tuesdaypctober 30, 2007 4:54 PM \nTo: Sidman, gi (USAFLS) \nCc Acosta, Alex (USAFIS) \nSubject Re: Epstein \n— Original Mess, — \nFrom: \"Slants, M(USAFLS)\" dinSlocanigandoj.gov) \nSent: 10/30/2007 02:42 PM MT \nTo: Jay Lefkowitz \nCc \"Acosta, Alex (USAFT-Sr <Alex.Acosta®usdoj.gov> \nSubject: Epstein \nJay, \nHere is an executed version of the addendum. Please Fed \nUS_Atty_Cor_00238 \nEFTA00235564\n", "char_count": 873}, {"efta_number": "EFTA00235326", "page_number": 239, "text_content": "Ex the original signature pages to me. Thanks, \na \n«epsteln addendum 10 30.pdP> \n***Ma** \n***** ***** ***** * ***** *•*** *********** ***WS \n*•**• \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only for \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International LLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly prohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately by \nreturn e-mail or by e-mail to postmastengkirkland.com, and \ndestroy this communication and all copies thereof, \nincluding all attachments. \n••**•** ****************** ***ass* ***** ***********•***** \n***** \nUS_Atty_Cor_00239 \nEFTA00235565\n", "char_count": 872}, {"efta_number": "EFTA00235326", "page_number": 240, "text_content": "\"Simon, \n.goto \n10/31/2007 04:33 \nPM \nTo \"Jay Lefkowite <JLefluswitz@kIrkland.com> \ncc \nbcc \nSubject Epstein \nJay, \nYour understanding from Jack Goldberger conforms to my \nunderstanding that Mr. Epstein's plea and sentence will take place \non the same day. I understand that the plea and sentence will occur \non or before the January 4th date. \nU \na \nUS_Atty_Cor_00240 \nEFTA00235566\n", "char_count": 383}, {"efta_number": "EFTA00235326", "page_number": 241, "text_content": "moot/o03 \n1//05/07 VON 10:05 PAX 30$ 550 0440 \nBMW: vte. ()SPICE \n[(Nn \na \na \nU.S. Department of Justice \nUnited Stotts /Mornay \nSouthern District lined* \npELIvERYTAY_FACSB417,li \nJay P. Lcfkowitz, Esq. \nKirkland Jr Ellis T.LP \nCitigroup Center \n153 East 53rd Street \nNew York, New York 10022-4675 \nRe: \nJeffrey Epstein \nDear Jay: \n99 NS. r stmt \nant, FL 15132,1111 \n(305) 941-9299 \nreadmits: O051 5304444 \nNovember 5.2007 \nSeveral things have come to my attention that seem contrary to your client intending to abide \nby his obligations under the Non-Prosecution Agreement. As you know, that agreement requires Our \nOffice to inform you of potential breaches to give you and your client the opportunity to respond \nbefore an indictment is filed. At this tune, I do not believe that the agreement has been breached: \nhowever, I have sufficient concerns that need to Sc addressed. \nPint, I understand that private, investigators worIcingfbr Mr. Epstein have contacted victims \nto ask them whether anydetectives or FBI agents have discussed afinancial sottlemont with them. \nOn one occasion, the yin vans investigators told the parent of a victim that she should get an attorney \nfor her daughter and she should do so right away. These actions are troublesome because the per \nagents legally aro required to advise the victims of the resolution of the matter, which includes \ninforming them that, as part of the resolution, that Mr. Epstein has weed to pay damages in some \ncircumstances. Furthermore, Mr. Epstein well knows that we are in the process of selecting an \nattorney to represent the victims and, but for the inordinate amount of time spent negotiating the \nAddendum, that attorney would already have been selected. Paragraph 7 of the Non•Prosecution \nAgreement explicitly provides that contact with the victims shall. be through that counsel. \nAccordingly, please confirm that there will be no further efforts to contact any victims until Judge \nDavis selects the attorney representative an\n... [truncated, 2392 chars — for the full page use /api/corpus/document/EFTA00235326/241 or ?id=EFTA00235326&page=241]", "char_count": 2392}, {"efta_number": "EFTA00235326", "page_number": 242, "text_content": "illasiotr \nMON l0:00 FAX 30$ 530 6440 \nEXECTrIvE 'REECE: \ngå 003/003 \nlä 003 \nJAY?. l.natcouniz. \nNoverama 5, 2007 \nPane 2 Os 2 \nEpstein had to begin his term of incarceration not later than Sanuary 4, 2008. T have teamed that the \nNovember hearing has been removed from the calendar and the next case disposition conference hats \nnot been set until January 7.2008. This delay is unacceptable, and, pursuant to your obligations, the \nOffice requests that you confer with the Spite Attorney's Office to try to find a date In November \nwhen the judge is available to conduct a simultaneous plea and sentencing. if you cannot find such \na date, please provide documentation of your efforts to abide by the mans of tbc Non-Prosecution \nAgreement. \nThird, there hove been several press reports that Mr. Epstein no longer intends to enter a \ngull ty plea. Normallylvmuld not pay any attention to such reports, but your recent correspondence \nattempting to restrict our Office from communicating with the State Attorney's Office and the \n;illusion to the imposition of sentences that clearly fall outside the terms of the Non-Prosecution \nAgroemeot raises concern. Please confirm that Mr. Epstein intends to abide by his agreement to \nplead guilty lo the specified charges and to make a binding recommendation that the Court impose \na sentence of 18 months of ountintious confinement In the county jail. \nFinally, the Non-Prosecution Agreementrequires that you provide the Office with cbpieg of \nall propose d agreements with the State Attorney's Olllee before Mr. Epstein signs any such \nagreements. To date, no such agreements have been received. Please provide me with copies of any \nand all agreements with the State Attorney's Office for outroview. The Office also would like to \nhave someone present at the change ofplen and sentencing to monitorMr. Epstein's compliancewith \nthe turns of the Non-Prosecution Agreement, so please keep me informed of the date, time, and \nlocation of the hearing. \nPica\n... [truncated, 2413 chars — for the full page use /api/corpus/document/EFTA00235326/242 or ?id=EFTA00235326&page=242]", "char_count": 2413}, {"efta_number": "EFTA00235326", "page_number": 243, "text_content": ",An\", , nna \n06/16/2008 11:16 F81. \n05/16/08 \nFRI 11:08 F.« \nUNITED STATES DEPARTME.\n(-3 \nCriminal Divisio \nChild Exploitation and Obsc \n1400 New York Avenue, NW \nSuite 600 \nWashington, DC 20530-0001 \n• 20005 \nTO: \nR. Alexander ACO9ta • Esq. \nJay LefIccuitz, Eski. \nOPETCE NUMBER: \nFAX NUMBER: \n305/530-7087 \nE1/445-4900 \nFROM: \nAlexandra Ge)h.r.\nLe4-rci fa, \nbc)-3 \nDAT/3/11ME: \nMay 16, 2008 \nOFFICE NUMBER: (202) 514-5780 \nNUMBER OF PAGES, EXCLUDING THIS SHEET: 5\nSPECIAL INSTRUCTIONS: \nUS_Atty_Cor_00243 \nEFTA00235569\n", "char_count": 521}, {"efta_number": "EFTA00235326", "page_number": 244, "text_content": "1/40002/000 \n21/08/D7 YON 10:05 FAX )05 53u e4A0 \nEX.ECil! V E (WV \n[d002 \n• \n• \nU.S. Oepartinent of Justice \nUnited Stares Attorney \nSouthern District oily/pride \nDELIVERY tlYIACSIMITZ \nJay P. Lefkowitz, Esq. \nKirkland & Ellis 'UP \nCitigroup Center \n153 East 33rd Street \nNew York, New York 10022-4675 \nRe: \nJeffrey Epstein \nDear fey: \n99 ME. *strew \nMist! PL 33132411f \n005)96,4299 \nPuctimile: (305) .5304444 \nNovember 5.2007 \nSeveral things have come to my attention that scent contraty to your• client intending to abide \nby his obligations under the Non-Prosecution Agreement. AS you know, that agreement requires our \nOffice to lotto= you of potential breaches to give you and your client the opportunity to respond \nbefore an indictment is filed. At this t➢me, I do not believe that the agreement has been breached; \nhowever, I have sufficient concerns that need to be addressed. \nFiat, I understand that private investimuors working for Mr. Epstein have contacted victims \nto ask them whether any detectives or FBI agents have discussed a financial settlement with them. \nOn one occasion, the private investigators told the parent of a victim that she should get an attorney \nFor her daughter and she should do so tight away. These actions etc troublesome because the FBI \nagents legally are required to advise the victims of the resolution of the matter, which includes \nInforming them that, as part of the resolution, that Mr. Epstein has agreed to pay damages in some \ncircumstances. Furthermore, Mr. Epstein well {mows that we are in the proems of selectiog an \nattorney to represent the victims and, but for the Inordinate amount o£ time spent negotiating the \nAddendum, that attorney would already have been selected. Paragraph 7 of the Nun-Prosecution \nAgreement explicitly provides that contact with the victims shall, be through that counsel. \nAccordingly, please confirm that there will be no further efforts to contact any victims until Judge \nDavis selects the attorney representa\n... [truncated, 2402 chars — for the full page use /api/corpus/document/EFTA00235326/244 or ?id=EFTA00235326&page=244]", "char_count": 2402}, {"efta_number": "EFTA00235326", "page_number": 245, "text_content": "11/08,07 MON 10100 PAX 304 330 6440 \nEN:eon:Ice OFFICE \na 003/003 \n0003 \nJAY P. I.Evitowra., Esq. \nNovi:maga S, 2007 \nPACs 2 of 2 \nEpstein had to begin his term of incarceration not later than January:, 2008. I have loaned that the \nNovember hearing has been removed from the calendar and the next case disposition conference; has \nnot been sot until January 7, 2008. This delay is unacceptable, and, pursuant to your obligadons, the \nOffice requests that you confer with the State Attorney's Office to try to find a date In November \nwhen the judge is available toconduct a simultaneous plea and sentencingc. If you cannot find such \na date. please provide documentation of your efforts to abide by the tams of tbc Non-Prosecution \nAgreement. \nThird, thew have been severe' press reports that Mr. Epstein no longer intends to enter a \nguiltyplea. Normally I would nut pay any attention to such reports, but your recent correspondence \nattempting to restrict our Office from communicating with the State Attorney's Office and the \nallusion to the imposition of sentences that clearly fall outside the terms of the Non-Proseetttion \nAgreement raises concern. Please confirm that Mr. Epstein intends to abide by his agreement to \nplead guilty to the specified charges and to make a binding recommendation that the Court impose \na sentence of 18 months of continuous confinement in the county jail. \nI finally, thelcon-ProsocationAgreementrequires that you providnthe Office with copies of \nall proposed agreements with the State Attorney's Office before Mr. Epstein signs any such \nagreements. To date, no such agreements have been received. Please provide inn with copies of any \nand all agrcemords with the State Attorney's Office for our review. Tho Office also would like to \nhave someone present at the change ofplea and sentencingto monitorMr. Epstein's compliance with \nthe wane of the Non-Prosecution Agreement, so please keep me informed of the date, time, and \nlocation of the hearing. \nPleas\n... [truncated, 2425 chars — for the full page use /api/corpus/document/EFTA00235326/245 or ?id=EFTA00235326&page=245]", "char_count": 2425}, {"efta_number": "EFTA00235326", "page_number": 246, "text_content": "Fine \n11/15/2007 01:51 PM \n(305)961-9299 \n-----Original Message \nFrom: Jay Lefkowitz \nSent: Thursdaya_November 15, 20 \nTo: Sloman, \n(USAFLS) \nSubject: \nTo \"Jay Le&mite \ncc \nbee \nSubject RE: \n:47 pm \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland G Ellis LLP or Kirkland G Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmaster@kirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \nUS_Atty_Cor_00246 \nEFTA00235572\n", "char_count": 861}, {"efta_number": "EFTA00235326", "page_number": 247, "text_content": "\"AS Mu \n°MARLS)\" \ncaexAcostaO \nustIoLgov> \n11/19/2007 \n02:25 PM \nTo tteflmwite@kkMamicom> \ncc \nboc \nSubled Re: niportal \nJay -- the 2pm is outside the office. Won't be back \nuntil about 3. How anout then? \nSent from my SlackSerry Wireless Handheld \n \n Original Message  \nFrom: Jay Lef kowitz \nTo: Acosta, Alex (OSAFLS) \nSent: Mon Nov 19 11:59:25 2007 \nSubject: Re: important \n\"Acosta, Alex (USAFLS)\" cAlex.Acostaeusdoj.gov> \n11/19/2007 10:46 AM \nTo \nCC \nSubject \nJay - \nRe: important \nI'm around mid afternoon tuesday (have a very early \ndinner) and early wed (have an appt outside the office \nfrom 11 30 to 2). \nUS_Atty_Cor_00247 \nEFTA00235573\n", "char_count": 645}, {"efta_number": "EFTA00235326", "page_number": 248, "text_content": "Should I bring \n(if there's business to talk, he \nis handling epsEtirri)7 \nAlex. \nSent from my BlackBerry Wireless Handheld \n \n Original Message  \nFrom: Jay Lefkowitz \nTo: Acosta, Alex (US \nSent: Mon Nov 19 09:31:12 2007 \nSubject: important \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland 6 Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmaster@kirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nUS_Atty_Cor_00248 \nEFTA00235574\n", "char_count": 1287}, {"efta_number": "EFTA00235326", "page_number": 249, "text_content": "and may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmasterekirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \nUS_Atty_Cor_00249 \nEFTA00235575\n", "char_count": 279}, {"efta_number": "EFTA00235326", "page_number": 250, "text_content": "rucsAp\nostacsAtrax \nTo < \ncc\n40mukmaW§URW*0 \nova \nbcc \n11/20/2007 03:58 PM \nSubject Re: \nYes. See you then. \nSent from my Blacktlerry Wireless Handheld \n \n Original Message  \nFrom: Jay Lefkowitz < \nTo: Acosta, Alex (USAFLS) \nSent: Tue Nov 20 15:39:34 2007 \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmaster@kirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \n* * * r. \nU S_A t t y_C o \nr_O 0 2 5 \n0 \nEFTA00235576\n", "char_count": 941}, {"efta_number": "EFTA00235326", "page_number": 251, "text_content": "Watt Alex \n(USAFLSr \n<AlexAcostaeusdoi.g \now. \n1121200711:44 AM \nTo \"Jay Lefkowite <JLelkowitz@kitklend.corn> \ncc \nbcc \nSubject RE: \nI'm on my way to a mtg outside the office. Unlikely \nto be before 3pm. \nThat said, III/ is around if you want to talk with him \nre the 2255. \n-----Original Message \nFrom: Jay Letkowitz \nSent: Wednesday, November 21, 2007 11:38 AM \nTo: Acosta, Alex (USAFLS) \nSubject: \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmaster@kirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \nUS_Atty_Cor_00251 \nEFTA00235577\n", "char_count": 1063}, {"efta_number": "EFTA00235326", "page_number": 252, "text_content": "11/21/2007 02A8 PM \nSure \nTo ciLefltowitz@lcirldand.com> \nee \nbee \nSubject Re•. \nSent from my BlackSerry Wireless Handheld \n \n Original Message  \nFrom: Jay Lefkowitz \nTo: Sloman, \n(USA \nSent: Wed Nov 2 14:47:24 2007 \nA****** ******** #4.14.***Atke*www****** \n************** \n**** \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmaster@kirkland.com, \nand \ndestroy this Communication and all copies thereof, \nincluding all attachments. \nUS_Atty_Cor_00252 \nEFTA00235578\n", "char_count": 943}, {"efta_number": "EFTA00235326", "page_number": 253, "text_content": "Sure \nJay LelltowIWNew \nYork/Kiddand-Etas \n11/26/2007 1214 PM \n\"Sloman. ■ (USAFLS)\" IMMINIME> \n\"Stoma:, \nusdol.gov> \n11/21/2007 \n02:48 PM \nTo \"Sloman.Ill (USAR_Sr \ncc \nbcc \nSubject Re:2 \nTo <Jlefkowii7gpkirklanicom> \ncc \nSubject Re: \nSent from my BlackBerry Wireless Handheld \n \n Original Message  \nFrom: Jay Lefkowitz \nTo: Sloman, \n(USAFLS) \nSent: Wed Nov 21 14:47:24 2007 \n• • * * • \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland 6 Ellis LLP or Kirkland 4 Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nUS_Atty_Cor_00253 \nEFTA00235579\n", "char_count": 801}, {"efta_number": "EFTA00235326", "page_number": 254, "text_content": "and may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmasterekirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \nUS_Atty_Cor_00254 \nEFTA00235580\n", "char_count": 279}, {"efta_number": "EFTA00235326", "page_number": 255, "text_content": "ams \n11/27/2O07 01:55 PM \n7 1.\nTo 'Jay LelkowItz\",<Jtelkowitz©Itirlikuld.col \ncc \"Acosta. Alex (USAFLS)\" <AlexAcostae \nbce \nSubplot Epstein \n7.111:1,71MTPT..Wirw \nNliSlageivzto-4;aii'5W \n\"\n\"'A\nJay, \nPlease accept my apologies for not getting back to you sooner but I \nwas a little under the weather yesterday. I hope that you enjoyed \nyour Thanksgiving. \nRegarding the issue of due diligence concerning Judge Davis' \nselection, I'd like to make a few observations. First, Guy Lewis has \nknown for some time that Judge Davis was making reasonable \nefforts to sect= Aaron Podhurst and Bob Josephsberg for this \nassignment In fact, when I told you of Judge Davis's selection \nduring our meeting last Wednesday, November 21\", you and \nProfessor Dershowitz seemed very comfortable, and certainly not \nsurprised, with the selection. Podhurst and Josephsberg are no \nstrangers tuarly the entire Epstein defense team including Guy \nLewis, Lill.. Sanchez, Roy Black, and, apparently, Professor \nDershowitz who said he knew Mr. Josephsberg from law school. \nSecond, Podhurst and Josephsberg have long-standing stellar \nreputations for their legal acumen and ethics. It's hard for me to \nimagine how much more vetting needs to be done. \nThe United States has a statutory obligation (Justice for All Act of \n2004) to notify the victims of the anticipated upcoming events and \ntheir rights associated with the agreement entered into by the \nUnited States and Mr. Epstein in a timely fashion. Tomorrow will \nmake one full week since you were formally notified of the \nselection. I must insist that the vetting process come to an end. \nTherefore, unless you provide me with a good faith objection to \nJudge Davis's selection by COB tomorrow, November 28, 2007,1 \nwill authorize the notification of the victims. Should you give me \nthe go-ahead on Podhurst and Josephsberg selection by COB \ntomorrow, I will simultaneously send you a draft of the letter. I \nintend to notify the victims by letter after COB Thursday,\n... [truncated, 2060 chars — for the full page use /api/corpus/document/EFTA00235326/255 or ?id=EFTA00235326&page=255]", "char_count": 2060}, {"efta_number": "EFTA00235326", "page_number": 256, "text_content": "O1113410MPM \n11/28/2007 04:46 PM \nNW\":\n1-•••  • \nTo 'Jay LefkowItz\" < \ncc \"Slornan, il(USAFLS)* AMMO! \n\"Acosta, Alex (LISAPLS)- <Alex.Acosta@usdoj.9 \nbcc \nSubject Epstein: Victim Notification Leifer \nIf+ '904°Safi\nDear Jay: \ntasked that I forward the victim notification letter to you. It is \nattached. \nThank you. \n<<Victim Notification Ltr pdf, •> \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \n«.< Attarcliffig\ne archived\n'CornmonStoretIVKIrkiend-Ellis' on '0 /30/2008 00;30:02'. >>> \nUS_Atty_Cor_00256 \nEFTA00235582\n", "char_count": 526}, {"efta_number": "EFTA00235326", "page_number": 257, "text_content": "fZ \nk \nU.S. Department of Justice \nDELIVERY BY HAND \nMiss \nUnited States Attorney \nSouthern District of Florida \n500 South Australtan 4w., Sulk 400 \nWan Palm Bath, FL 33401 \n(561)820-8711 \nfl ab: fie: (561) 820-8777 \nNovember 29, 2007 \nRe: \nCrimeittetHins' Rights— Notification of Resolution of Epstein InveS.tigatt \nDear Miss\nSeveral months ago, I provided you with a letter notifying you of your rights as a victim \npursuant to the Justice for All Act «2004 and other federal legislation, including: \n(I) \nThe right to be reasonably protected from the accused. \n(2) \nThe right to reasonable, accurate, and timely notice of any public court proceeding \ninvolving the crime or of any release or escape of the accused. \n(3) \nThe right not to be excluded from any public court proceeding, unless the court \ndetermines that your testimony may be materially altered ifyou arepresent for other \nportions of a proceeding. \n(4) \nThe right to be reasonably heard at any public proceeding in the district court \ninvolving release, plea, or sentencing. \n(5) \nThe reasonable right to confer with the attorney for the United States in the cam. \n(6) \nThe right to fill and timely restitution as provided in law. \n(7) \nThe right to proceedings free from unreasonable delay. \n(8) \nThe right to be treated with fhimen and with respect for the victim's dignity and \nprivacy. \nI am writing to inform you that the federal investigation of Jeffrey Epstein has been \ncompleted, and Mr. Epstein and the U.S. Attorney's Office have reached an agreement containing \nthe following terms. \nFirst, Mr. Epstein agrees that he Will plead guilty totwo state offenses, including the offense \nof soliciting minors to engage in prostitution, whichwill require him lo register as a sexual predator \nfor the remainder of his life. \nUS_Atty_Cor_00257 \nEFTA00235583\n", "char_count": 1829}, {"efta_number": "EFTA00235326", "page_number": 258, "text_content": "Mess \nNOVa4RER 29,2007 \nPAGE 2 \nSecond, Mr. Epstein has agreed to Make a binding recommendation of 18 months' \nimprisonment to the state court Judge who sentences bim. Mr. Epstein will serve that sentence of \nimprisonment at the PalmBeach County Jail. \nThird, Mr. Epstein has agreed that he will not contest jurisdiction or liability if you elect to \nseek damages from him because the United States has identified you as a minor victim of certain \nfederal offenses, including travel in interstate commerce to engage in prostitution with minors read \nthe use of facilities of interstate commerce to induce minors to engage in prostitution. To assist you \nin making such a claim, the U.S. Attorney's Office has asked an independent Special Master to \nselect attorneys to represent you. Those attorneys axe Aaron Podhurst and Robert (\"Bob\") \nJosefsberg with the law finis of Podhurst Orseck, PA. They can be reached at (305) 358-2800. I \nanticipate that someone from their law firm will be contacting yon shortly. I must also advise you \nfig  you are not obligated to use these attorneys. In Act you have the absolute right to select vela \npwn attorney. so you can decide not to speak with Masts. Podhurst/ Yosoftheig at all. or you tin \nspeak with them and decide at any time to use a different attorney If you do decide to seek damages \nGom Mr.Epstein and you decide to use Messrs. Podburstllosefsberg as your attorneya, Mr. Epstein \nwill be responsible for paying attorney's fees incurred during the time spent trying to negotiate a \nsettlement. If you are unable to reach a settlement with Mr. Epstein, you and Mr. Josefitberg can \ndiscuss bow best to proceed. \nAs I mentioned above, as part of the resolution of the federal investigation, Mr. Epstein has \nagreed to plead guilty to state charges. Mr. Epstein's change of plea and sentencing will occur on \nDecember 14,2007, at \na.m., beforeJudgeSraira IC McSorley, inConrtmom 11F at the Palm \nBeach County Courthouse, 205 North Dixie Highway, West \n... [truncated, 3093 chars — for the full page use /api/corpus/document/EFTA00235326/258 or ?id=EFTA00235326&page=258]", "char_count": 3093}, {"efta_number": "EFTA00235326", "page_number": 259, "text_content": "Miss \nNOvEMBER29.2007 \nPam 3 \n4. \nYour e-mail address \n5. \nA notation of whether you would lace to participate in the \"VINE system,\" which \nprovides automated notification calls any time an inmate is moved. (To use this \norient, Your calls must go to you directly, not through a switchboard.) \nThank you for all of your help during the course of the investlgatiobiliou hav \nquestions or concerns, please do not hesitate to contact me or Special Agent \nat (561) 8224946. \nSincerely, \nR. Alexander Acosta \nUnited States Attorney \nBr \nAssistant United States Attorney \ncc: \nSpecial Agent \nKnyrIcendall, \nMs. Clearetha Wright, Victim-Witnoss Coordhtator, U.S. Attorney's Office \nUS_Atty_Cor_00259 \nEFTA00235585\n", "char_count": 707}, {"efta_number": "EFTA00235326", "page_number": 260, "text_content": "US. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South AustralianAve., Suite 400 \nWest Palm Beach. FL 33401 \n(561)8204711 \nFacsimile: (561) 8204777 \nNovember 29, 2007 \nDELIVERY BY HAND \nMiss \nRe: \nDear Miss \nSeveral months ago, I provided you with a letter notifying you of your rights as a victim \npursuant to the Justice for All Act of 2004 and other federal legislation, including: \n(1) \nThe right to be reasonably protected from the accused. \n(2) \nThe right to reasonable, accurate, and timely notice of any public court proceeding \ninvolving the crime or of any release or escape of the accused. \n(3) \nThe right not to be excluded from any public court proceeding, unless the court \ndetermines that your testimony may be materially altered if you are present for other \nportions of a proceeding. \n(4) \nThe right to be reasonably heard at any public proceeding in the district court \ninvolving release, plea, or sentencing. \n(5) \nThe reasonable right to confer with the attorney for the United States in the case. \n(6) \nThe right to full and timely restitution as provided in law. \n(7) \nThe right to proceedings free from unreasonable delay. \n(8) \nThe right to be treated with fairness and with respect for the victim's dignity and \nprivacy. \nI ant writing to inform you that the federal investigation of Jeffrey Epstein has been \ncompleted, and Mr. Epstein and the U.S. Attorney's Office have reached an agreement containing \nthe following terms. \nFirst, Mr. Epstein agrees that he will plead guilty to two state offenses, including the offense \nof soliciting minors to engage in prostitution, which will require him to register as a sexual predator \nfor the remainder of his life. \nUS_Atty_Cor_00260 \nEFTA00235586\n", "char_count": 1756}, {"efta_number": "EFTA00235326", "page_number": 261, "text_content": "MISS \nNOVEMBER 29,2007 \nPAGE 2 \nSecond, Mr. Epstein has agreed to make a binding recommendation of 18 months' \nimprisonment to the state court judge who sentences him. Mr. Epstein will serve that sentence of \nimprisonment at the Palm Beach County Jail. \nThird, Mr. Epstein has agreed that he will not contest jurisdiction or liability if you elect to \nseek damages from him because the United States has identified you as a minor victim of certain \nfederal offenses, including travel in interstate commerce to engage in prostitution with minors and \nthe use of facilities of interstate commerce to induce minors to engage in prostitution. To assist you \nin making such a claim, the U.S. Attorney's Office has asked an independent Special Master to \nselect attorneys to represent you. Those attorneys are Aaron Podhurst and Robert (\"Bob\") \nJosefsberg with the law firm of Podhurst Orseck, P.A. They can be reached at (305) 358-2800. I \nanticipate that someone from their law firm will be contacting you shortly. J must also advise vott \nthat you are not oblieated to use these anonnevs. Infect. you have the absolute richt to select your \nown attorney. so you can decide notto speak with Mssrs. Podhurst/ Josefsbersr at all. or you cap \nspeak with them and decide at any time to use a different attorney, If you do decide to seek damages \nfrom Mr. Epstein and you decide to use Messrs. Podhurst / Josefsberg as your attorneys, Mr. Epstein \nwill be responsible for paying attorney's fees incurred during the time spent trying to negotiate a \nsettlement. If you are unable to reach a settlement with Mr. Epstein, you and Mr. Josefsberg can \ndiscuss how best to proceed. \nAs I mentioned above, as part of the resolution of the federal investigation, Mr. Epstein has \nagreed to plead guilty to state charges. Mr. Epstein's change of plea and sentencing will occur on \nDecember 14, 2007, at \na.m., before Judge Sandra K. McSorley, in Courtroom 1 I F at the Palm \nBeach County Courthouse, 205 North Dixie Hi\n... [truncated, 3104 chars — for the full page use /api/corpus/document/EFTA00235326/261 or ?id=EFTA00235326&page=261]", "char_count": 3104}, {"efta_number": "EFTA00235326", "page_number": 262, "text_content": "MISS \nNOVESS3ER 29, 2007 \nPAGB 3 \n4. \nYour e-mail addresi \n5. \nA notation of whether you would like to participate in the \"VINE system,\" which \nprovides automated notification calls any time an inmate is moved. (To use this \nsystem, your calls must go to you directly, not through a switchboard.) \nThank you for all of your help during the course of the investigatioilou have an \nquestions or concerns, please do not hesitate to contact me or Special Agent \nat (561) 822-5946. \nSincerely, \nR. Alexander Acosta \nUnited States Attorney \nBy: \nsistant nit \ntotes Attorney \ncc: \nSpecial Agent \nF.B.I. \nMs. Clearetha n t, al\nistitess Coordinator, U.S. Attorney's Office \nUS_Atty_Cor_00262 \nEFTA00235588\n", "char_count": 697}, {"efta_number": "EFTA00235326", "page_number": 263, "text_content": "YI \natIltdoj.gov,\n11/29/2007 06:30 PM \nTo 'Jay Lofkowltz• <JLefkowitz@kirkland.com> \ncc \nbcc \nSubject RE: Epstein: Victim Notification Letter \nHI Jay — The only attachment is my letter, did I miss something? \nThanks. \narsimmillellmas \nas\nI/2%1.1y Lett \n\" 4.1Lefkowftzaltirkland.cram, \nsr \n.goo, •Acosta, Nex (USAFL8)-\n11728/2007 04:48 PM \n<Alexaoostagusdolgov> \nSuEpstein: Victim Natific44ion Letter \nact \nct \nDear Jay: \nmasked that T forward the victim notification letter to you. It is \nattached. \nThank you. \n<Wictim Notification Lttpdt>> \nAssistant U.S. Attorney \nUS_Atty_Cor_00263 \nEFTA00235589\n", "char_count": 600}, {"efta_number": "EFTA00235326", "page_number": 264, "text_content": "West Palm Beach, FL 33401 \nThe information contained in this commun., ioation is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use ofm the addressee. It is the property of \nKirkland 6 Ellis LLP or Kirkla- nd 6 Ellis \nInternational LLP. \nUnauthorized use, disclosure or copying- of this \ncommunication or any part thereof is strictly \nprohibited \nand may be, unlawful. If you have received this \ncommunication in - error, please notify us immediately \nby \nreturn e-mail or by e-mail to = \npostmasterOkirkland.com, and \ndestroy this communication and all copiece s thereof, \nincluding all attachments. \n**** ***** * ********* ******.o. \na \nUS_Atty_Cor_00264 \nEFTA00235590\n", "char_count": 741}, {"efta_number": "EFTA00235326", "page_number": 265, "text_content": "To \"Jay Lefirowitz\" <JLeiltowttzeptdridand.coi \ncc \n1.110v> \nbcc \n12/10/2007 04:43 PM \nSubject Meeting on Friday with Ken Start \nHi Jay - Will you be attending the meeting on Friday? \nThank you. \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \nUS_Atty_Cor_00265 \nEFTA00235591\n", "char_count": 280}, {"efta_number": "EFTA00235326", "page_number": 266, "text_content": "'Merle C. \n1.90n \n12/13/200710:03 AM \nTo < \ncc \" \n(USAFLS)\" <KerenAtkis \nen, \nLS)' < \n\"Acosta. A ex (USAFLS)\" <1.c.gos a \nbcc \nSubOct Correspondence \nDear Jay: Please review the enclosed. I look forward to seeing \nyou tomorrow. \n«071213 a \nLtr to Lefkowitz finaipdf'> \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \n071213 Viafana Ltr to Lefkabitz rmat pdf \nUS_Atty_Cor_00266 \nEFTA00235592\n", "char_count": 395}, {"efta_number": "EFTA00235326", "page_number": 267, "text_content": "a\nU.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \nDELIVERY BY ELECTRONIC MAIL \nJay P. Lefkowitz, Esq. • \nKirkland & Ellis LLP \nCitigroup Center \n153 East 53rd Street \nNew York, New York 10022-4675 \nRe: \nJeffrey Epstein \nDear Jay: \n500 S. Australian Ave, Ste 400 \nWest Palm Beach FL 33401 \n(561) 8204711 \nFacsimile: (561) 820-8777 \nDecember 13, 2007 \nI am writing not to respond to your asserted \"policy concerns\" regarding Mr. Epstein's Non-\nProsecution Agreement, which will be addressed by the United States Attorney, but the time has \ncome for me to respond to the ever-increasing attacks on my role in the investigation and \nnegotiations. \nIt is an understatement to say that I am surprised by your allegations regarding my role \nbecause I thought that we had worked very well together in resolving this dispute. I also am \nsurprised because I feel that I bent over backwards to keep in mind the effect that the agreement \nwould have on Mr. Epstein and to make sure that you (and he) understood the repercussions of the \nagreement. For example, I brought to your attention that one potential plea could result in no gain \ntime for your client; I corrected one of your calculations of the Sentencing Guidelines that would \nhave resulted in Mr. Epstein spending far more time in prison than you projected; I contacted the \nBureau of Prisons to see whether Mr. Epstein would be eligible for the prison camp that you desired; \nand I told you my suspicions about the source of the press \"leak\" and suggested ways to avoid the \npress. Importantly, I continued to work with you in a professional manner even after] learned that \nyou had been proceeding in bad faith for several weeks — thinking that I had incorrectly concluded \nthat solicitation of minors to engage in prostitution was a registrable offense and that you would \n\"fool\" our Office into letting Mr. Epstein plead to a non-registrable offense. Even now, when it is \nclear that neither you nor your client \n... [truncated, 2341 chars — for the full page use /api/corpus/document/EFTA00235326/267 or ?id=EFTA00235326&page=267]", "char_count": 2341}, {"efta_number": "EFTA00235326", "page_number": 268, "text_content": "JAY P. LEFKOWITZ, ESQ. \nDECEMBER 13,2007 \nPAGE 2 OF 5 \nI informed you that I selected Mr. Ocariz because he was a friend and classmate of two people \nwhom I respected, and that I had never met or spoken with Mr. Ocariz prior to contacting him about \nthis case. All of those facts are true. I still have never met Mr. Ocariz, and, at the time that he and \nI spoke about this case, he did not know about my relationship with his friend. You suggest that I \nshould have explicitly informed you that one of the referrals came from my \"boyfriend\" rather than \nsimply a \"friend,\" which is the term I used, but it is not my nature to discuss my personal \nrelationships with opposing counsel. Your attacks on me and on the victims establish why I wanted \nto find someone whom I could trust with safeguarding the victims' best interests in the face of \nintense pressure from an unlimited number of highly skilled and well paid attorneys. Mr. Ocariz \nwas that person. \nOne of your letters suggests a business relationship between Mr. Ocariz and my boyfriend. \nThis is patently untrue and neither my boyfriend nor I would have received any financial benefit \nfrom Mr. Ocariz's appointment. Furthermore, after Mr. Ocariz teamed more about Mr. Epstein's \nactions (as described below), he expressed a willingness to handle the case pro bono, with no \nfinancial benefit even to himself. Furthermore, you were given several other options to choose from, \nincluding the Podhurst firm, which was later selected by Judge Davis. You rejected those other \noptions. \nYou also allege that I improperly. disclosed information about the case to Mr. Ocariz. \nprovided Mr. Ocariz with a bare bones summary of the agreement's terms related to his appointment \nto help him decide whether the case was something he and his firm would be willing to undertake. \nI did not provide Mr. Ocariz with facts related to the investigation because they were confidential \nand instead recommended that he \"Google\" Mr. Epstein's name for backg\n... [truncated, 3625 chars — for the full page use /api/corpus/document/EFTA00235326/268 or ?id=EFTA00235326&page=268]", "char_count": 3625}, {"efta_number": "EFTA00235326", "page_number": 269, "text_content": "JAY P. LEFKOWITZ, ESQ. \nDECEMBER 13,2007 \nPAGE 3 OF 5 \nalready been submitted to the Office on several occasions and you suggest that I have kept that \ninformation from those who reviewed the proposed indictment package. Contrary to your \nsuggestion, those submissions were attached to and incorporated in the proposed indictment \npackage, so your suggestion that I tried to hide something from the reviewers is false. I also take \nissue with the duplicity of stating that we must accept as true those parts of the Recarey reports and \nwitness statements that you like and we must accept as false those parts that you do not like. You \nand your co-counsel also impressed upon me from the beginning the need to undertake an \nindependent investigation. It seems inappropriate now to complain because our independent \ninvestigation uncovered facts that are unfavorable to your client. \nYou complain that I \"forced\" your client and the State Attorney's Office to proceed on \ncharges that they do not believe in, yet you do not want our Office to inform the State Attorney's \nOffice of facts that support the additional charge nor do you want any of the victims of that charge \nto contact Ms.Belohlavek or the Court. Ms. B elohlavek's opinion may change if she knows the full \nscope of your client's actions: You and I spent several weeks trying to identify and put together a \nplea to federal charges that your client was willing to accept. Yet your letter now accuses me of \n\"manufacturing\" charges of obstruction of justice, making obscene phone calls, and violating child \nprivacy laws. When Mr. Lourie told you that those charges would \"embarrass the Office,\" he meant \nthat the Office was unwilling to bend the facts to satisfy Mr. Epstein's desired prison sentence — a \nstatement with which I agree. \nI hope that you understand how your accusations that I imposed \"ultimatums\" and \"forced\" \nyou and your client to agree to unconscionable contract terms cannot square with the true facts of \nthis ca\n... [truncated, 3772 chars — for the full page use /api/corpus/document/EFTA00235326/269 or ?id=EFTA00235326&page=269]", "char_count": 3772}, {"efta_number": "EFTA00235326", "page_number": 270, "text_content": "JAY P. LEFKOWTIZ, ESQ. \nDECEIvEBER 13, 2007 \nPAGE 4 OF 5 \nissue if it were raised during negotiations. As I stated, it was not, leading me to believe that it was \nnot a matter of concern to the defense. Since the signing of the Non-Prosecution Agreement, the \nagents and I have vetted the list of victims more than once. In one instance, we decided to remove \na name because, although the minor victim was touched inappropriately by Mr. Epstein, we decided \nthat the link to a payment was insufficient to call it \"prostitution.\" I have always remained open to \na challenge to the list, so your suggestion that Mr. Epstein was forced to write a blank check is \nsimply unfounded. \nYour last set of allegations relates to the investigation of the matter. For instance, you claim \nthat some of the victims were informed of their right to collect damages prior to a thorough \ninvestigation of their allegations against Mr. Epstein. This also is false. None of the victims was \ninformed of the right to sue under Section 2255 prior to the investigation of the claims. Three \nvictims were notified shortly after the signing of the Non-Prosecution Agreement of the general \nterms of that Agreement. You raised objections to any victim notification, and no further \nnotifications were done. Throughout this process you have seen that I have prepared this case as \nthough it would proceed to trial. Notifying the witnesses of the possibility of damages claims prior \nto concluding the matter by plea or trial would only undermine my case. If my reassurances are \ninsufficient, the fact that not a single victim has threatened to sue Mr. Epstein should assure you of \nthe integrity of the investigation.' \n'There are numerous other unfounded allegations in your letter about document demands, \nthe money laundering investigation, contactingpotential witnesses, speaking with the press, and the \nlike. For the most part, these allegations have been raised and disproven earlier and need not be \nreaddressed. Howe\n... [truncated, 3621 chars — for the full page use /api/corpus/document/EFTA00235326/270 or ?id=EFTA00235326&page=270]", "char_count": 3621}, {"efta_number": "EFTA00235326", "page_number": 271, "text_content": "JAY P. LEFROWITZ, ESQ. \nDECEMBER 13, 2007 \nPAGE 5 ot, 5 \nWith respect tcall \nI contacted her attorney — who was paid for by Mr. Epstein and \nwas directed by counsel for Mr. Epstein to demand immunity — and asked only whether he gill \nrepresented...md if he wanted me to send the victim notification letter to him. He asked \nwhat the letter would say and I told him that the letter would be forthcoming in about a week and \nthat I could not provide him with the terms. With respect wastatus \nas a victim, you \nagain want us to accept as true onl fac that are beneficial to your client and to reject as false \nanything detrimental to him.\nrnade a number of statements that are contradicted by \ndocumentary evidence and a review of her recorded statement shows her lack of credibility with \nrespect to a number of statements. Based upon all of the evidence collecte \nis classified \nas a victim as defined by statute. Of course, that does not mean tha \nconsiders herself \na victim or that she would seek damages from Mr. Epstein. I believe \na number of the identified \nvictims will not seek damages, but that does not negate their legal status as victims. \nI hope that you now understand that your accusations against myself and the agents are \nunfounded. In the future, I recommend that you address your accusations to me so that I can correct \nany misunderstandings before you make false allegations to others in the Department. I hope that \nwe can move forward with a professional resolution of this matter, whether that be by your client's \nadherence to the contract that he signed, or by virtue of a trial. \nSincerely, \nR. Alexander Acosta \nUnited States Attorney \nBy: \ni \na \nAssistant United States Attorney \ncc: \nIt. Alexander Acosta, U.S. Attorney \nJeffrey Sloman, First Assistant U.S. Attorney \nYou also accuse me of \"broaden[ing] the scope of the investigation without any foundation \nfor doing so by adding charges of money laundering and violations of a money transmitting business \nto the in\n... [truncated, 2212 chars — for the full page use /api/corpus/document/EFTA00235326/271 or ?id=EFTA00235326&page=271]", "char_count": 2212}, {"efta_number": "EFTA00235326", "page_number": 272, "text_content": "12/10,07 veo 17:03 FAXJ05 330 6440 \nSXECUTIVB OFFICE \nU.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \nA AuxUWER ACOSTA \nOVIT0DST4TE3firrOreigi,\nDMZ& Y By FACSII4X-4 \nLillynni Sanchez \nFowler White BMW, PA \n1395 Brickell Ave, 14° Float \nMiami, FL 33 I 31 \nRe: \nJeff \nrein \nDear Ms. Sanchez: \nAlt tit 4 Sinn \n,Matt Ft. 33132 \n005)961.9100 - Totophm \n003)3304FM - florsPago \nDecember 19, 2007 \nI write to follow up on the December 14th meeting between defense counsel and the Epstein \nprosecutors, as well as our First Assistant, the Miami FM Special Agent in Charge and myself.' f \nwrite to you because 1am not certain who among the defense team is the appropriate recipient of this \nletter. 1 address issues raised by several members of the defense team, and would thus ask that you \nplease provide a copy of this letter to all appropriate defense team numbers. \nFirst, I would like to address the Section 2255 issue .2 As I stated in my December 4* letter, \nmy understanding is that the lgon-Prosecution Agreement entered into between this Office and Mr. \nEpsteinresponds to Mr. Epstein's &skew reach a global resolution of his state and federal criminal \nliability. tinder this Agreement, tbis District has agreed to defer prosecution forentanerauxlsections \n3 over the past two weeks, we have received several hundred pages of assonants and tabiblis from defense counsel. \nThis is not the forum to respond to the several hats raised. attd our silence should not te interpret as agseelneoli I \nwould, however. like to address one Issue. Your December lit\" letter mutts that as a result of defense emend \nobjections to at appointment mecca, the USA° proposed an addendum to the Agreartern to provide tin dm use of \nimkpendcm third patty selector. M I tomil this matter, before I had any knowledge of defense counsel \nobjections, I rue spa* proposed the AddenduM to Mr. Lelkowitz at an October manias in Palm Beach. I did this \nin an anempt to avoid what I foresaw wo\n... [truncated, 2550 chars — for the full page use /api/corpus/document/EFTA00235326/272 or ?id=EFTA00235326&page=272]", "char_count": 2550}, {"efta_number": "EFTA00235326", "page_number": 273, "text_content": "12/19/07 in 17:03 FAX 305 530 8440 \netuctrrIva CIVICS \nof Title IS in favor of prosecution by the State of Florida, provided that the Mr. Epstein satisfies \nthree general federal interests: (1) that Mr. Epstein plead guilty to a \"registerable\" state offense; (2) \nthat this state plea include a binding recommendation Ma sufficient term of imprisonment; and (3) \nthat the Agreement not harm the interests of his victims. \nWith this in mind, I have considered defense counsel arguments regarding the Section 2255 \nportions of the Agreement, As l previously observed, our intent has been to place tine victims in the \nsame position as they would have been had Mr. Epsteinbeen Convicted at trial. No more; no less. \nFrom our meeting, it appears that the defense agrees that this was the Intent, During the course of \nnegotiations that intent was reduced to writing in Paragraphs 7 and 8, which as i wrote previously, \nappear for from simple to understand. I would thus propose that we solve our disagreements over \ninterpretations by saying precisely what we mean, in a simple titration, I would replace Paragraphs 7 \nand 8 with the following language: \n\"Any person, who while a minor, was a victim of a violation of an offense enumerated in \nTitle 18, United Slates Code, Section 2255, will have the same rights to proceed under \nSection 2255 as she would have bad, if Mr. Epstein been tried federally and convicted of an \ntuntrnerated offense. For purposes of implementing this paragraph, the United Stain shall \nprovide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an \n'Indictment as victims of au enumerated offense by Mr. Epstein. Any judicial authority \ninterpreting this provision, includingany authority detennining which evidentiary burdens if \nany a plaintiff must meet, shell consider that it is the intent of the parties to place these \nidentified victims in the same position as they would have been had Mr, Epstein been \nconvicted at trial. No mom; no\n... [truncated, 3522 chars — for the full page use /api/corpus/document/EFTA00235326/273 or ?id=EFTA00235326&page=273]", "char_count": 3522}, {"efta_number": "EFTA00235326", "page_number": 274, "text_content": "12/10/07 TED 17:04 FAX 305 530 8440 \nEXECUTIVE OFFICE \nFinally, I would like to address a more general point. Our Agreement was first signed on \nSeptember 201,2007. Pursuant to paragraph 11,1*. Epstein was to use illsbestefforts to enter his \nguilty plea and be sentenced no later than October 26,2007. As outlined in correspondence between \nour prosecutors and defense counsel, this deadline came and went. Our prosecutors reiterated in \ndefense counsel several times their concerns regarding delays, and in fact, asked me several vaxlcs \nago to declare the Agreement in breach because of those delays I resisted that invitation. I share \nthis fact because it is background to my frustration with what appears to be an 1 la hour appeal. \nweeks before the now scheduled January 4th plea date. \nThis said, the issues raised are important and must be fully vetted irrespective of timeliness \nconcerns. We hope to preserve the January 4a data I understand that defense counsel shares our \ndesire not to move that appearance and will work with our office to expedite this process over the \nnext several days. With this in mind, and in the event that defense counsel may wish to seek review \nof our determinations in Washington D.C., I spoke this past Monday with the Assistant Attorney \nGeneral Fisher, to Inform her of a possible appeal, to ask her to grant the potential request for review, \nand to In fret review this case In an copedited manner to attempt to preserve the January ea pleadate. \nI want to again reiterate that it is not the intention of this Office ever to force the hand of a \ndefendant to enter into an agreementagainst his wishes. Your client has the right to proceed to trial, \nand he should do so If he believes that he did not commit the elements of the charged offense. \nI will respond to the pending issues shortly. In the interim, I would ask that you \ncommunicate your position with respect to the sections 2255 and 3371 issues as quickly as possible. \nSincerely, \nR. ALEXAND\n... [truncated, 2181 chars — for the full page use /api/corpus/document/EFTA00235326/274 or ?id=EFTA00235326&page=274]", "char_count": 2181}, {"efta_number": "EFTA00235326", "page_number": 275, "text_content": "\"Acosta. Alex \n(USAFLS)' \nTo <JLelkowitz@kirkland.com> \n<AJexAcosta©u \nsdoj.gov,  \nbcc \n12/20/2007 02:19 \nSubject Re: Important \nPM \nIf you do prefer to talk, 10 to noon, or 2 to 3 would \nwork. \nSent from my BlackBerry Wireless Handheld \n \n Original Message  \nFrom: Acosta, Alex (USAFLS) \nTo: 'JLefkowitz@kirkland.com' \nSloman, \n(USAFLS) \nSir irel\nt \n2007 \nSubject: Re: Important \nSure. Not a problem. We can also talk by phone if \nthat's easier. \nSent from my BlackBerry Wireless Handheld \n \n Original Messag  \nFrom: Jay Lefkowitz \nTo: Acosta, Alex (USAFLS \nSent: Thu Dec 20 13:37:33 2007 \nSubject: Important \n******* \n***** \n** ************** \n*********** \n***** \n* ********* \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addr \n. It is the property of \nKirkland G Ellis LLP or Kirkland 6 Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \nUS_Atty_Cor_00275 \nEFTA00235601\n", "char_count": 1139}, {"efta_number": "EFTA00235326", "page_number": 276, "text_content": "communication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmastergkirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \nUS_Atty_Cor_00276 \nEFTA00235602\n", "char_count": 231}, {"efta_number": "EFTA00235326", "page_number": 277, "text_content": "\"Acmes, Alec \n(USAPLSr \n<Alexacostegu \nsdal.pova• \n12(27/2007 01:32 \nPM \nTo <JLefkowttz©kkItland.coo> \ncc \nbcc \nSubject Re: \nNot a probelm. We can talk later in the week or \nweekend if its easier. \nSent from my BlackBerry Wireless Handheld \n \n Original Message  \nFrom: Jay Lefkowitz 11.\n> \nTo: Acosta, Alex (US \nCc: Sloman, \n(USAFLS); \n(USAFLS) \nSent: Thu Dec 27 12:21:50 2007 \nSubject: Re: \n \n Original Message  \nFrom: \"Acosta, Alex (USAFLS)\" LAlex.Acostaeusdoj.gov) \nSent: 12/27/2007 11:37 AM EST \nTo: Jay Lefkowi z \nCc: \"Sloman, \n(USAFI.S) • \nUSAFLS)\" \nSubject: RE: \nJay -- I just reviewed the letter. I agree that we \nshould talk. Can \nyou give me some times that work on your end, and \nwe'll try to set \nsomething up? \n \nOriginal Message \nFrom: Jay Lefkowitz [mailto:6.11.\n] \nSent: Wednesday, December 2 , \n: \nP \nTo: Acosta, Alex (USAFLS) \nSubject: \nUS_Atty_Cor_00277 \nEFTA00235603\n", "char_count": 887}, {"efta_number": "EFTA00235326", "page_number": 278, "text_content": "***** \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland 6, Ellis LLP or Kirkland 6 Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmaster@kirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \n* \n******** * \n***** ************** ******** * ****** ********** \n***** \n***a* \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland 6 Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmaster@kirkland.com, \nend \ndestroy this communication and all copies thereof, \nincluding all attachments. \nUS_Atty_Cor_00278 \nEFTA00235604\n", "char_count": 1380}, {"efta_number": "EFTA00235326", "page_number": 279, "text_content": "\"Acoste,Alex \nTo cksfluwdiz MddandoznWYSbmaN \nUSAFLSr \n(USAFLS) \n,nAMOants, \n<AlmAcostattu \n*&44100  \ncc \n12/28/2007 02:18 \nPM \nboo \nSubject Re: \nJay - I don't know what will happen at this point. \nMay be best to wait until after we speak monday \nmorning. Alex \nSent from my BlackBerry Wireless Handheld \n \n Original Message  \nFrom: Jay Lefkowitz \nTo: Acosta, Alex (USA \nSent: Fri Dec 28 13:52:31 2007 \nSubject: Re: \n \n Original Message  \nFrom: \"Acosta, Alex (USAFLS)\" (Alex.Acostailusdoj.gov) \nSent: 12/28/2007 01:35 PM EST \nTo: Jay Lefkowitz \nSubject: Re: \nJay _ \nI want to respect your sabbath. Let's just talk \nmonday morning. Would 11 am work? \nSent from my BlackBerry Wireless Handheld \n \n Original Message  \nFrom: Jay Lefkowitz \nTo: Acosta, Alex (USA \nSent: Fri Dec 28 12:51:13 2007 \nUS_Atty_Cor_00279 \nEFTA00235605\n", "char_count": 823}, {"efta_number": "EFTA00235326", "page_number": 280, "text_content": "The information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e—mail to postmaster@kirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \n* * * * * \n******** * ****** ******* ***** ** *********** ************** \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmasterBkirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \nUS_Atty_Cor_00280 \nEFTA00235606\n", "char_count": 1366}, {"efta_number": "EFTA00235326", "page_number": 281, "text_content": "\"Acosta, Alex \n(USAFter \n<Alec.Acosta@usd \not.gov,\n12!31/200711:05 \nAM \nwill do. 3 min. \nTo \"Jay Le&ovate anillIM> \ncc \nbcc \nSubject RE: \n \nOriginal Message \nFrom: Jay Lefkowitz (mailto\n) \nSent: Monday, December 31, 2007 11:02 AM \nTo: Acosta, Alex (USAFL$) \nSubject: \n********** *it ************ *******41.* ***** *ilk** ***** \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmasterOkirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \nUS_Atty_Cor_00281 \nEFTA00235607\n", "char_count": 990}, {"efta_number": "EFTA00235326", "page_number": 282, "text_content": "Jay LeficovAtz/New \nYorkiKtrkland•Eilis \n01/022008 03:44 PM \nTo \"Acosta, Alex (USAFLS)\" cAlexAcosta@ruscioj.g \ncc \"Acosta, Alex (USAFLS)\" eatex.Acosta@eadoi.g \n\"Castillo, Annette (USAFLS)* cAnnette.Castillog \n\"Sloman. MUSAFLS)\" \nbcc \nSubject RE:® \n\"Acosta, Alex (USAFLS)* <AlexAcosta@usdoj.gov> \n\"Acosta, Alex \n(USAFLS)' \n<Alex:Acosta@ \nusdoj.gov> \n01/02/2008 \n03:36 PM \nTo -Acosta, Alex (USAFLS)• <Alex.Acosta(pusdoj.gov>, \nLatkowite <JLelkovoltzgkireland.com> \ncc 'Castillo, Annette (USAFLS • <Annette.Castelo@usdol.g-\n\"Sioman, eusAF, \ngoy> \nSubject RE: \nActually, the morning is bad. How about 3pm or 4pm? \nFrom: Acosta, Alex (USAFLS) \nSent Wednesday, January 02, 2008 3:33 PM \nTo: Jay Lefkowitz \nCc: Castillo, Annette (USAFLS); Sloman, ■(USAFLS) \nSubjects RE: \n11 am? \nFrom: Jay Lefkowitz \nSent: Wednesday, January \n, \nTo: Acosta, Alex (USARS) \nSubject \nWPM \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the add \n. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nUS_Atty_Cor_00282 \nEFTA00235608\n", "char_count": 1262}, {"efta_number": "EFTA00235326", "page_number": 283, "text_content": "Unauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmaster@kirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \n44********** ****** **** ********* **ie..*** *********** ***** \n9 - \nUS_Atty_Cor_00283 \nEFTA00235609\n", "char_count": 456}, {"efta_number": "EFTA00235326", "page_number": 284, "text_content": "•Acosta, Alex (USAFLSr \n<A)sx.Acostoausdoi.gow \n01/07/2008 11:28AM \nNot a problem. \n \nOriginal Message \nFrom: Jay Lefkowitz \nSent: Monday, January 07, 20 \nTo: Acosta, Alex (USAFLS) \nSubject: \nTo \"Jay Lefkowite <AefkowItz@kirkland.cot \ncc \"Castillo. Annette (USAFLS)\" eAnnette.C4 \nbet \nSubject RE: \n***** \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland fi Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmastergkirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \nUS_Atty_Cor_00284 \nEFTA00235610\n", "char_count": 968}, {"efta_number": "EFTA00235326", "page_number": 285, "text_content": "5eumsm,Ales(USAFLE)\" \n<Alex.Acosta@usdoj.gon \n01/07/2008 11:28 AM \nTo 'Jay Lefty:mite \ncc \"CaMillo,Aplione(USAFLS)\"cAnne8e.C1 \nbcc \nSubject RE: \nNot a problem. \n-----Original Message \nFrom: Jay Lefkowitz Imailto:JLefkowitzOkirkland.com) \nSent: Monday, January 07, 2005 11:21 AM \nTo: Acosta, Alex (USSFLS) \nSubject: \na \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this\ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmasterikirkland.cem, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \nUS_Atty_Cor_00285 \nEFTA00235611\n", "char_count": 980}, {"efta_number": "EFTA00235326", "page_number": 286, "text_content": "\"Acosta, Alex (USAFLS)* \n<Alex.Acosta@usdol.goy> \n01/07/2008 03:41 PM \nTo \"Jay Lefkowitz\" <JLelkowitz@idrkland.coi \ncc \"Castillo, Annette (USAFLS)\" <Annette.CI \n\"Kristin Andersen\" ckandersen@kirkland. \nbee \nSubject RE: \nAnnettga,,gan you pis provide to Jay the conf. table speaker phone \nft., for =and I. \nFrom: Jay Lefkown [mallto:JLefkowitz@klrldand.com) \nSent: Wednesday, January 02, 2008 3:44 PM \nTo: Acosta, Alex (USAFLS) \nCc: Acosta, Alex (USAFLS); Castillo, An \ne (USAFLS); Sloman, \n(USAFLS); Kristin Andersen \nSubject: RE: \nS \n\"Acosta, Alex (USAFLS)\" \n<Alex Ac ontaausdo) goy \n01/02/2008 03:36 PM \nTtrAcosta. Alex (USAFLS)\" eatex.Acosta@usdoj.gov, , \"Jay \nLeatorette 4IMINMMit \nceCtisthlo. Amalie (USAFLS)\" eannotte.CasliN \nectojew., \n\"Stamm nuSAFtSr \nSublocRE \nActually, the morning is bad. How about 3pm or 4pm? \nFrom: Acosta, Alex (USAFLS) \nSent Wednesday, January 02, 2008 3:33 PM \nTo: Jay Lefkowitz \nCc Castillo, Annette (USAFLS); Stoman, \n(USAFLS) \nSubject RE: \n11 am? \nFrom: Jay LefkOwiU [manta \nSent Wednesday, January 02, 2008 2:46 PM \nTo: Acosta, Alex (USAFLS) \nSubject \nUS_Atty_Cor_00286 \nEFTA00235612\n", "char_count": 1121}, {"efta_number": "EFTA00235326", "page_number": 287, "text_content": "a \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of thi addr \n. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmasterekirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmasterekirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \nUS_Atty_Cor_00287 \nEFTA00235613\n", "char_count": 1292}, {"efta_number": "EFTA00235326", "page_number": 288, "text_content": "'Acosta, Alex (USAFLS)\" \n*Alox.Aconausdolgoo \n01/30/2008 06:33 PM \nTo <JLefkowitz©Icirkland.corn> \ncc \nbcc \nSubject Re: \nJay -\nThanks for the email. I sent it along to the trial \nteam. \nI'm also looking forward to when this is over, so we \ncan talk about non-work matters. \nHope all is well with you and the family. \nAlex. \nSent from my BlackBerry Wireless Handheld \n \n Original Messals\n,\nFrom: Jay Lefkowitz \nTo: Acosta, Alex (USAFLS) \nSent: Wed Jan 30 13:07:11 2000 \n• \n**IV** *********** \n***** *Ike** ********** t* ********* \n******* \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nUS_Atty_Cor_00288 \nEFTA00235614\n", "char_count": 735}, {"efta_number": "EFTA00235326", "page_number": 289, "text_content": "the use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International \nLLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately \nby \nreturn e-mail or by e-mail to postmesterekirkland.com, \nand \ndestroy this communication and all copies thereof, \nincluding all attachments. \nUS_Atty_Cor_00289 \nEFTA00235615\n", "char_count": 498}, {"efta_number": "EFTA00235326", "page_number": 290, "text_content": "Jay, \nau\nSAFLS)\" \nsdol.govs. \n02/2512008 07:43 PM \nTo \ncc \"Oosterbaan, Andrew' <Andrew.Oosterts \nbcc \nSubject Epstein \nThe Section Chief of Dears Child Exploitation \nObscenity Section (CEOS) notified me today that he will \nreview the matter involving your client Jeffrey Epstein. \nThe Section Chief has indicated that he is ready to \nproceed immediately, and I understand you are in the \nprocess of providing him this week with a summary of \nissues to be reviewed, and expect to meet with him next \nweek. \nThe Section Chief also indicated that you would be \ncalling this Office regarding the upcoming March 3, \n2008 court date in the Fifteenth Judicial Circuit, in and \nfor Palm Beach County. As you know, the Agreement \nentered into by your client originally provided that the \nUnited States Attorney's Office for the Southern District \nof Florida (this Office) would defer prosecution if your \nclient pled guilty to enumerated state charges by October \n26, 2007. Since then, that date has been postponed for a \nnumber of reasons. At this juncture, it would not be \nreasonable to keep the current March 3s date as a \ndeadline for compliance with the Agreement. That said, \nthis Office is very concerned about additional delays. \nDespite this concern, I want to assure you that if counsel \nfor Mr. Epstein meets with CEOS next week (the week \nof March 3), this Office will extend the time for \ncompliance with the Agreement to provide CEOS time to \nengage in a thorough review. \nIt goes without saying that in the event that CEOS \ndecides that a federal prosecution should not be \nundertaken against Mr. Epstein, this Office will close its \nUS_Atty_Cor_00290 \nEFTA00235616\n", "char_count": 1673}, {"efta_number": "EFTA00235326", "page_number": 291, "text_content": "investigation. However, should CEOS disagree with Mr. \nEpstein's position, Mr. Epstein shall have one week to \nabide by the terms and conditions of the September 24, \n2007 Agreement as amended by letter from United States \nAttorney Acosta to Jay Leflcowitz. \nJeffrey H. Sloman \nFirst Assistant U.S. Attorney \nSouthern District of Florida \nUS_Atty_Cor_00291 \nEFTA00235617\n", "char_count": 371}, {"efta_number": "EFTA00235326", "page_number": 292, "text_content": "<IaUSAPLS\nr\nusdej.govm \n02/27/2008 09:45 PM \nTo <JLeflcowitzakirkland.com> \nCC Vesta/bean, Andrew\" <Andrew.Oostertm \nbcc \nSubject Fe: Epstein \nSent from my BlackBerry Wireless Handheld \n \n Original Message  \nFrom: Jeffrey Sloman <jalomanebellsouth.net> \nTo: Sloman, pp \n(USAF1S) \nSent: Wed Fe \n21:37:02 2008 \nSubject: Epstein \nJay, \nYou have renewed your request for certain information \nwhich this Office does not generally make available in \nsimilar pre-indictment situations. After carefully \nconsidering your request, I have decided, in my \ncapacity as the First Assistant V.S. Attorney, not to \nmake an exception here. \nRegarding the Landon Thomas matter, Mr. Thomas was \ngiven, pursuant to his request, non-case specific \ninformation concerning specific federal statutes. \nRegarding the offer to extend the current deadline of \nMarch 3, 2008 contained in my February 25th email. \nThat offer was based on counsel for Mr. Epstein \nmeeting with CEOS the week of March 3rd. You indicate \nthat you are unavailable. It is hard to imagine that \nsome or all of the other attorneys representing Mr. \nEpstein cannot serve this function. After all, Mr. \nEpstein is also represented by Dean Kenneth Starr, \nMartin Weinberg, Roy Black, Gerald Lefcourt, Harvard \nProfessor Alan Dershowitz, Lily III Sanchez, and Guy \nLewis. \nThat being said, the Southern District of Florida will \nonly renew the offer to extend the current deadline if \nyou and the CEOS Section Chief mutually agree on a \ntimetable by close of business on Friday, February 29, \n2008 to meet and complete presentations no later than \nMarch 19, 2008. Given that CEOS is ready to proceed \nUS_Atty_Cor_00292 \nEFTA00235618\n", "char_count": 1677}, {"efta_number": "EFTA00235326", "page_number": 293, "text_content": "immediately, this seems like more than ample time. As \nI indicated.in my previous email, if CEOS subsequently \ndecides that a federal prosecution should not be \nundertaken against Mr. Epstein, this Office will close \nits investigation. However, should CEOS disagree with \nMr. Epstein's position, Mr. Epstein shall have one \nweek to abide by the terms and conditions of the \nSeptember 24, 2007 Agreement as amended by letter from \nUnited States Attorney Acosta. \nJeffrey H. Sloman \nFirst Asst. US Attorney \nSouthern District of Florida \nUS_Atty_Cor_00293 \nEFTA00235619\n", "char_count": 568}, {"efta_number": "EFTA00235326", "page_number": 294, "text_content": "Jay, \nS\nAFLSr \n01.90v,\n02/29t2008 07:17 PM \nTo eaelkowitz@kkkland.com> \ncc \nbcc \nSubject Epstein \nI know you emailed the U.S. Attorney but I feel \ncompelled to respond. \nIn my Monday, February 25th email, I tried to express my \nconcern, on behalf of the SDFL, about additional delays \nconcerning this matter and the desire to expedite review \nwithout interfering or restricting the process. When you \nreplied on Wednesday , February 27th, it seemed to me \nthat nothing had much changed. Your email stated \" \nbecause I am currently scheduled to be on trial all next \nweek in Delaware, I don't think we will actually be able \nto begin meeting with Drew until the following week, at \nthe earliest.\" I felt that no effort was being made towards \nscheduling, and that, at the very least, one of Mr. Epstein \n's other lawyers could have attempted to schedule a \nmeeting with CEOS. To put it another way, it appeared to \nme that this matter was going to drag unnecessarily. \nObviously you sensed my frustration in my responding \nemail which, in turn, generated your email to the USA. \nLate this afternoon, I was informed that you have \nscheduled a meeting with CEOS for March 12th. \nObviously, I am heartened to hear of this development. \nPlease be assured that it is not, and never has been, this \nOffice's intent to interfere with or restrict the review \nprocess for either Mr. Epstein or CEOS. I leave it to you \nand CEOS to figure out how best to proceed and will \nawait the results of that process. \nUS_Atty_Cor_00294 \nEFTA00235620\n", "char_count": 1530}, {"efta_number": "EFTA00235326", "page_number": 295, "text_content": "(7) \nS loman, FAUSA \nUS_Atty_Cor_00295 \nEFTA00235621\n", "char_count": 53}, {"efta_number": "EFTA00235326", "page_number": 296, "text_content": "Subject: Epstein \nJay, \nI know you emailed the U.S. Attorney but I feel \ncompelled to respond. \nIn my Monday, February 25th email, I tried to express \nmy concern, on behalf of the SDFL, about additional \ndelays concerning this matter and the desire to \nexpedite review without interfering or restricting the \nprocess. When you replied on Wednesday , \nFebruary 27th, it seemed to me that nothing had \nmuch changed. Your email stated \"because I am \ncurrently scheduled to be on trial all next week in \nDelaware, I don't think we will actually be able to \nbegin meeting with Drew until the following week, at \nthe earliest.\" I felt that no effort was being made \ntowards scheduling, and that, at the very least, one \nof Mr. Epstein's other lawyers could have attempted \nto schedule a meeting with CEOS. To put it another \nway, it appeared to me that this matter was going to \ndrag unnecessarily. Obviously you sensed my \nfrustration in my responding email which, in turn, \ngenerated your email to the USA. \nLate this afternoon, I was informed that you have \nscheduled a meeting with CEOS for March 12th. \nObviously, I am heartened to hear of this \ndevelopment. Please be assured that it is not, and \nnever has been, this Office's intent to interfere with \nor restrict the review process for either Mr. Epstein \nor CEOS. I leave it to you and CEOS to figure out \nhow best to proceed and will await the results of that \nprocess. \n■ \nSloman, FAUSA \nUS_Atty_Cor_00296 \nEFTA00235622\n", "char_count": 1475}, {"efta_number": "EFTA00235326", "page_number": 297, "text_content": "C)\nThe information contained in this commun.. ication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only \nfor \nthe use of,. the add \n. It is the property of \nKirkland & Ellis LLP or Kirkla.. nd & Ellis \nInternational LLP. \nUnauthorized use, disclosure or copying- of this \ncommunication or any part thereof is strictly \nprohibited \nand may be unlawful. If you have received this \ncommunication in — error, please notify us immediately \nby \nreturn e-mail or by e-mail to \npostmasterekirkland.com, and \ndestroy this communication and all coping. s thereof, \nincluding all attachments. \nUS_Atty_Cor_00297 \nEFTA00235623\n", "char_count": 675}, {"efta_number": "EFTA00235326", "page_number": 298, "text_content": "Jay, \n03/05/2008 09:09 AM \nTo \"Jay Lefkowite <JLefkowitz@kirkland.cot \ncc \nbcc \nSubject RE: Epstein \nI have again carefully considered your request and have decided \nnot to make an exception here. \nSloman, FAUSA \nFrom: Jay Lefkowitz [malkot.ltatkowIt@kaldend.com] \nSent TuesduMarch 04, 20O8 4:35 PM \nTo: Sloman, \n(USARS) \nSubject Re: Epsbain \n-- Original \nOriginal Masse - \nFrom: \"Slomaa. \n(USAFLS)\" \nSent: 02/29/2008 07:17 PM EST \nTo: Jay Lefkowitz \nUS_Atty_Cor_00298 \nEFTA00235624\n", "char_count": 483}, {"efta_number": "EFTA00235326", "page_number": 299, "text_content": "05/16/2008 11:18 FAS \n05/18/08 PEI 11:08 PAX \nUNITED STATES DEPARTME \nCriminal Divisio \nChild Exploitation and Obsc \n1400 New York Avenue, NW \nSuite 600 \nWashington, DC 20530-0001 \n• 20005 \n• \nTO: \nAlexander Aoosta, Esq. \nTay parkawftz, Esq. \n. OFFICE NUMBER: \nLc-4-w \nbo \nFAX NUMBER: \n305/530-7087 \nFROM: \nAlexandra Gelber \nDATEMME:: \nMay 16, 2008 \nOFFICE NUMBER: (202) 514-5780 \nNUMBER OF PAGES, FXCLUDINO THIS SHEET: 5\nSPECIAL INSTRUCTIONS: \nUS_Atty_Cor_00299 \nEFTA00235625\n", "char_count": 477}, {"efta_number": "EFTA00235326", "page_number": 300, "text_content": "05/16/2008 11:16 FAX \n' 05/16/08 FRI 11:08 FAX \nU.S. Department of Justice \nCriminal Division \nAndrew G. Oostettaan, Chief \nQ002/006 \nJ002 \nadd \nefftlelearion end Ott \nX•6110“ \nJay Lefkowitz, Esq. \nKirkland & Ellis LISP \nCitigroup Center \n153 E. 5314 St \nNew York, NY 10022-4611 \nRe: \nInvestigation ()Peery Epstein \nDear Mr. Lefkowitz: \n1400 New York Amu% NW \nSane 600 \nWalkinstax. DC 20130 \n(2o2) )11-57$0 FAX.• (202)1/44793 \nMay 15, 2008 \nPursuant to your request and the request of U.S. Attorney R. Alexander Acosta, we have \nindependently evaluated certain issues raised in the investigation offefftey Epstein to determine \nwhether a decision to prosecute Mr. Epstein for federal criminal violations would contradict \ncriminal enforcement policy interests. As part of our evaluation, we have reviewed letters \nwritten on behalf of Mr. Epstein on Febniary 1, 2007, June 25, 2007, July 6, 2007, March 28, \n2008, April 8, 2008, April 28, 2008, and May 14, 2008, with their attachments. We have also \nreviewed memos prepared by the U.S. Attorney's Office. As you will recall, we met with you \nand other representatives of Mr. Epstein to further discuss your views on the propriety of a \nfederal prosecution. We have discussed the factual and legal issues you raise with the Criminal \nDivision's Appellate Section, and we consulted with the Office of Enforcement Operations \nconcerning the petite policy. \nWe are examining the narrow question as to whether there is a legitimate basis tbr the \nU.S. Attorney's Office to proceed with a federal prosecution of Mr. Epstein. Ultimately, the \nprosecutorial decision making authority within a U.S. Attorney's Office lies with the U.S. \nAttorney. Therefore, to borrow a phrase from the case law, the question we sought to answer \nwas whether U.S. Attorney Acosta would abuse his discretion if he authorized prosecution in this \ncase. \nAs you know, our review of this case is limited, both factually and legally. We have not.\nlooked at the entire universe of \n... [truncated, 2331 chars — for the full page use /api/corpus/document/EFTA00235326/300 or ?id=EFTA00235326&page=300]", "char_count": 2331}, {"efta_number": "EFTA00235326", "page_number": 301, "text_content": "05/18/2008 11:16 FAX \n05/16/08 PRI 11:08 FAX \nQ003/006 \n11003 \nAs was made clear at the outset, we did not review the facts, circumstances, or terms \nincluded in the plea offer, nor any allegations that individuals involved in the investigation \nengaged in misconduct. Despite that agreement, we note that your letters of April 8, April 28, \nand May 14 focus in large part on accusations of investigative or prosecutorial misconduct. Not \nonly do allegations of prosecutorial misconduct fall outside the boundary of our agreed review, \nthey also fall outside the authority of the Criminal Division in the first instance. Simply, the \nCriminal Division does not investigate or resolve allegations of professional misconduct by \nfederal prosecutors. For these reasons, we do not respond to the portion of those letters that \ndiscuss alleged misconduct. \nBased on our review of all of these materials, and after careful consideration of the issues, \nwe conclude that U.S. Attorney Acosta could properly use his discretion to authorize prosecution \nin this case. We will briefly address each of the issues that you have raised. \nKnowledge ofage. Federal child exploitation statutes differ as to whether there must be \nproof that the defendant was aware that the children were under the age of 18. However, even \nfor those statutes where knowledge of age is an element of the offense, it is possible to satisfy \nthat element with proof that the defendant was deliberately ignorant of facts which would suggest \nthat the person was a minor. For that reason, the fact that some of the individuals allegedly lied \nto Mr. Epstein about their age is not dispositive of the issue. While there may be an open factual \nissue as to Mr. Epstein's knowledge, we cannot say that it would be impossible to prove \nknowledge of age for any such charges which require it. Therefore, Mr. Acosta could rightfully \nconclude that this factual issue is best resolved by a jury. \nTravel for the purpose. In the materials you pr\n... [truncated, 3671 chars — for the full page use /api/corpus/document/EFTA00235326/301 or ?id=EFTA00235326&page=301]", "char_count": 3671}, {"efta_number": "EFTA00235326", "page_number": 302, "text_content": "06/16/2006 11:16 FAX \n05/16706 FRI 11:09 FAX \nR)004/006 \nso novel as to implicate the so-called \"clear statement rule,\" the Er Past Facto clause, or the Due \nProcess clause. As with the other legal issues, Mr. Acosta may elect to proceed with the case. \nAbsence of coercion. With respect to 18 U.S.C. § 1591, the alleged absence of the use of \nforce, fraud, or coercion is of no moment. The statute does not require the use of force, fraud, \nand coercion against minors. Because of their ago, a degree of coercion is presumed. In your \nmaterials, you note that the statute requires that the minors must be \"caused\" to engage in a \ncommercial sex act, further arguing that the word \"cause\" suggests that a certain amount of \nundue influence was used. We reject that interpretation, as it would read back into the offense an \nelement•-coercion—that Congress has expressly excluded. We have successfully prosecuted \ndefendants for the commercial sexual exploitation of minors, even when the minors testified that \nnot only did they voluntarily engage in the commercial sex acts, it was their idea to do so. As \nsuch, Mr. Acosta could properly decide to pursue charges under Section 1591 even if there is no \nevidence of coercion. \nMore broadly, a defendant's criminal liability does not hinge on his victim identifying as \nhaving suffered at his hands. Therefore, a prosecution could proceed, should Mr. Acosta decide \nto do so, even though some of the young women allegedly have said that they do not view \nthemselves as victims. \nWitness credibility. As all prosecutors know, there arc no perfect witnesses. Particularly \nin cases involving exploited children, as ono member of your defense team, Ms. Thacker, surely \nknows from her work at CEOS, it is not uncommon for victim-witnesses to give conflicting \nstatements. The prosecutors are in the best position to assess the witness's credibility. Often, the \nprosecutor may decide that the best approach is to present the witness, let defense counsel\n... [truncated, 3448 chars — for the full page use /api/corpus/document/EFTA00235326/302 or ?id=EFTA00235326&page=302]", "char_count": 3448}, {"efta_number": "EFTA00235326", "page_number": 303, "text_content": "fib 005/006 \n06/16/2008 11:17 FAX \n06/16/08 FRI 11:09 FAX \nthe case on the merits after jeopardy has attached.\" USAM 9-2.031(C). Our understanding is \nthat the state case is still pending. As such, the procedural posture of the state case does not \nimplicate the petite policy. \nWe recognize that the petite policy could be triggered if the state case concluded after a \nfederal indictment was issued but prior to the commencement of any federal trial. Id. However, \nthe policy \"does not apply ... where (he (state) prosecution involved only a minor part of the \ncontemplated federal charges.\" USAM 9-2.031(B). Based on our understanding of the possible \nfederal charges and existing state charges, we do not think the petite policy would be an issue \nshould federal proceedings take place. \nFederalism and Prosecutorial Discretion. All of the above issues essentially ask whether \na federal prosecution can proceed. We understand, however, that you also ask whether a federal \nprosecution should proceed, even in the event that an of the elements of a federal offense could \nbe proven. On this issue, you raised two arguments: that the conduct at issue here is traditionally \na state concern because the activity is entirely local, and that the typical prosecution under federal \nchild exploitation statutes have different facts than the ones implicated here. You have \nessentially asked us to look into whether a prosecution would so violate federal prosecutorial \npolicy that a United States Attorney's Office should not pursue a prosecution, We do not think \nthat is the case here for the following reasons. \nSimply, the commercial sexual exploitation of children is a federal concern, even when \nthe conduct is local, and regardless of whether the defendant provided the child (the \"pimp\") or \npaid for the child (the \"john\"). In your materials, you refer to a letter sent by the Department of \nJustice to Congress in which the Department expresses concern over the expansion of federal \nlaws to\n... [truncated, 3499 chars — for the full page use /api/corpus/document/EFTA00235326/303 or ?id=EFTA00235326&page=303]", "char_count": 3499}, {"efta_number": "EFTA00235326", "page_number": 304, "text_content": "--• --• \n----- --\n05/16/0$ Fit 11:10 PAX \nWiluvW vy.• \n(hoes \nfacts, we conclude that federal prosecution in this case would not be improper or inappropriate. \nWhile you raise many compelling arguments, we do not see anything that rays co us categorically \nthat a federal case should not be brought. Mr. Acosta would not be abusing hie prosecutorial \ndiscretion should he authorize fodaal prosecution of Mr. \nShwa* \nco: \nAM) Alice S. Fisher \nDAAG Sigal P. Mandelker \nU.S. Attorney R. Alexander Acosta \na \nS \nOOSterballt \nUS_Atty_Cor_00304 \nEFTA00235630\n", "char_count": 553}, {"efta_number": "EFTA00235326", "page_number": 305, "text_content": "05/16/2008 11:18 FAX \n05/18/08 \nFRE 11:08 FAX \nU.S. Department of Justice \nCriminal Division \nAndrew 0. Oosterbaan, Chief \ncb002/008 \nQ002 \nChild ka,ploliarlun and Obnvnity Ration \nJay Lefkowitz, Esq. \nKirkland & Ellis LLP \nCitigroup Center \n153 E. 53i8 St. \nNew York, NY 10022-4611 \nRe: \nInvestigation of Jeffery Epstein \nDear Mr. Lefkowitz: \n1400 AM York Ammo, NW \nSW. 600 \nfrottlagton. DC 28130 \n(302) 5/4.5740 PAX: (202) 1/4-179) \nMay 15, 2008 \nPursuant to your request and the request of U.S. Attorney R. Alexander Acosta, we have \nindependently evaluated certain issues raised in the investigation of Jeffrey Epstein to determine \nwhether a decision to prosecute Mr. Epstein for federal criminal violations would contradict \ncriminal enforcement policy interests. As part of our evaluation, we have reviewed letters \nwritten on behalf of Mr. Epstein on February 1, 2007, June 25, 2007, July 6, 2007, March 28, \n2008, April 8, 2008, April 28, 2008, and May 14, 2008, with their attachments. We have also \nreviewed memos prepared by the U.S. Attorney's Office. As you will recall, we met with you \nand other representatives of Mr. Epstein to further discuss your views on the propriety of a \nfederal prosecution. We have discussed the factual and legal issues you raise with the Criminal \nDivision's Appellate Section, and we consulted with the Office of Enforcement Operations \nconcerning the petite policy. \nWe are examining the narrow question as to whether there is a legitimate basis for the \nU.S. Attorney's Office to proceed with a federal prosecution of Mr. Epstein. Ultimately, the \nprosecutorial decision making authority within a U.S. Attorney's Office lies with the U.S. \nAttorney. Therefore, to borrow a phrase from the case law, the question we sought to answer \nwas whether U.S. Attorney Acosta would abuse his discretion if he authorized prosecution in this \ncase. \nAs you know, our review of this case is limited, both factually and legally. We have not \nlooked at the entire uni\n... [truncated, 2343 chars — for the full page use /api/corpus/document/EFTA00235326/305 or ?id=EFTA00235326&page=305]", "char_count": 2343}, {"efta_number": "EFTA00235326", "page_number": 306, "text_content": "06/16/2008 11:16 FAX \n05/16/08 \nPRI 11:08 FAX \n133003/006 \nQ) 003 \nAs was made clear at the outset, we did not review the facts, circumstances, or terms \nincluded in tho plea offer, nor any allegations that individuals involved in the investigation \nengaged in misconduct. Despite that agreement, we note that your letters of April 8, April 28, \nand May 14 focus in large part on accusations of investigative or prosecutorial misconduct. Not \nonly do allegations of prosecutorial misconduct fall outside the boundary of our agreed review, \nthey also fall outside the authority of the Criminal Division in the first instance. Simply, the \nCriminal Division does not investigate or resolve allegations of professional misconduct by \nfederal prosecutors. For these reasons, we do not respond to the portion of thoso letters that \ndiscuss alleged misconduct. \nBased on our review of all of these materials, and after careful consideration of the issues, \nwe conclude that U.S. Attorney Acosta could properly use his discretion to authorize prosecution \nin this case. We will briefly address each of the issues that you have raised. \nKnowledge of age. Federal child exploitation statutes differ us to whether there must be \nproof that the defendant was aware that the children were under the age of 18. However, even \nfor those statutes where knowledge of age is an element of the offense, it is possible to satisfy \nthat element with proof that the defendant was deliberately ignorant of facts which would suggest \nthat the person was a minor, For that reason, the fact that some of the individuals allegedly lied \nto Mr. Epstein about their age is not dispositivc of the issue. While there may be an open factual \nissue as to Mr. Epstein's knowledge, we cannot say that it would be impossible to prove \nknowledge of age for any such charges which require it. Therefore, Mr. Acosta could rightfitlly \nconclude that this factual issue is best resolved by a jury. \nTravel for the purpose. In the materials \n... [truncated, 3679 chars — for the full page use /api/corpus/document/EFTA00235326/306 or ?id=EFTA00235326&page=306]", "char_count": 3679}, {"efta_number": "EFTA00235326", "page_number": 307, "text_content": "05/16/2008 11:16 RAI \n05/16/08 PRI 11:09 FAS \nQ004/006 \nso novel as to implicate the so-called \"clear statement rule,\" the Lx Post Facto clause, or the Due \nProcess clause. As with the other legal issues, Mr. Acosta may elect to proceed with the case. \nAbsence of coercion. With respect to 18 U.S.C. § 1591, the alleged absence of the use of \nforce, fraud, or coercion is of no moment. The statute does not require the use of force, fraud, \nand coercion against minors. Because of their age, a degree of coercion is presumed. In your \nmaterials, you note that the statute requires that the minors must be \"caused\" to engage in a \ncommercial sex act, further arguing that the word \"cause\" suggests that a certain amount of \nundue influence was used. We reject that interpretation, as it would read back into the offense an \nelement-coercion—that Congress has expressly excluded. We have successfully prosecuted \ndefendants for the commercial sexual exploitation of minors, even when the minors testified that \nnot only did they voluntarily engage in the commercial sex acts, it was their idea to do so. As \nsuch, Mr. Acosta could properly decide to pursue charges under Section 1591 even if there is no \nevidence of coercion. \nMore broadly, a defendant's criminal liability does not hinge on his victim identifying as \nhaving suffered at his hands. Therefore, a prosecution could proceed, should Mr. Acosta decide \nto do so, even though some of the young women allegedly have said that they do not view \nthemselves as victims. \nWitness  credibility. As all prosecutors know, there are no perfect witnesses. Particularly \nin cases involving exploited children, as one member of your defense learn, Ms. Thacker, surely \nknows front her work at CEOS, it is not uncommon for victim-witnesses to give conflicting \nstatements. The prosecutors are in the best position to assess the witness's credibility. Often, the \nprosecutor may decide that the best approach is to present the witness, let defense counse\n... [truncated, 3456 chars — for the full page use /api/corpus/document/EFTA00235326/307 or ?id=EFTA00235326&page=307]", "char_count": 3456}, {"efta_number": "EFTA00235326", "page_number": 308, "text_content": "®005/006 \n• \n06/16/2008 11:17 FAS \n05/16/08 FRI 11:09 FAX \nthe case on the merits after jeopardy has attached.\" USAM 9-2.03I(C). Our understanding is \nthat the state case is still pending. As such, the procedural posture of the state case does not \nimplicate the petite policy. \nWe recognize that the petite policy could be triggered if the state case concluded after a \nfederal indictment was issued but prior to the commencement of any federal trial. Id. However, \nthe policy \"does not apply ... where the (state) prosecution involved only a minor part of the \ncontemplated federal charges.\" US AM 9-2.031(B). Based on our understanding of the possible \nfederal charges and existing state charges, we do not think the petite policy would be an issue \nshould federal proceedings take place. \nFederalism and Prosecutorial Discretion. All of the above issues essentially ask whether \na federal prosecution can proceed. We understand, however, that you also ask whether a federal \nprosecution should proceed, even in the event that all of the elements of a federal offense could \nbe proven. On this issue, you raised two arguments: that the conduct at issue here is traditionally \na state concern because the activity is entirely local, and that the typical prosecution under federal \nchild exploitation statutes have different facts than the ones implicated here. You have \nessentially asked us to look into whether a prosecution would so violate federal prosecutorial \npolicy that a United States Attorney's Office should not pursue a prosecution. We do not think \nthat is the case here for the following reasons. \nSimply, the commercial sexual exploitation of children is a federal concern, even when \nthe conduct is local, and regardless of whether the defendant provided the child (the \"pimp\") or \npaid for the child (the \"john\"). in your materials, you refer to a letter sent by the Department of \nJustice to Congress in which the Department expresses concern over the expansion of federal \nlaws \n... [truncated, 3505 chars — for the full page use /api/corpus/document/EFTA00235326/308 or ?id=EFTA00235326&page=308]", "char_count": 3505}, {"efta_number": "EFTA00235326", "page_number": 309, "text_content": "05.0.0/01: \nFRI 11:10 FAX \natoms \nfacts, we conclude that federal prosecution in this ease would not bo improper or inappropriate. \nWhile you raise many compelling arguments, we do not see anything that says to us categorically \nthat a federal cue should Dot be brought. Mr. Acosta would not be abusing his prosecutorial \ndiscretion should he authorize federal prosecution of Mr. gpotei \nS \nco: \nAAG Alice S. Either \nDRAG Sigel P. Mandencer \nU S. Attorney R. Alexander Acosta \n5 \n. Oosterbaan \nUS_Atty_Cor_00309 \nEFTA00235635\n", "char_count": 526}, {"efta_number": "EFTA00235326", "page_number": 310, "text_content": "Jack Goldberger \n4 \nFrom: \nSent: \nTo: \nSubject: \nRead carefully the GJ suspension portion of the non pros agreement. It says upon signing the non pros agreement and A \nPLEA AGREEMENT with SAO all pending Si subpoenas will be held in abeyance. Doesn't that imply that when we sign \nplea agreement with state this week the new Si subpoenas that are out now go into abeyance status also \nFrom: \n(USAFIS) [mallto \nSent: ue\n1.11Jun.lit \n4:16 PM \nTo: Roy BLACK. Jack Goldberger \nCc: \n(USAFLS) \nSub \n: Je ey pstein Agreement \nDear Roy and Jack: \nI am just writing to re-state that it is the Government's position that we have a signed, binding agreement and \nthat there is no need for further modification. \nPlease keep us informed of the date and time of the change of plea and sentencing. \nThank you. \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \nUS_Atty_Cor_00310 \nEFTA00235636\n", "char_count": 881}, {"efta_number": "EFTA00235326", "page_number": 311, "text_content": "JUN. 27.2F28 \n3:33PM \nIF.rYio WPB FL \nNO.324- \nP.2 - \nU.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Auttrallem Ave.. Sua. 400 \nwesrPaint Beach. FL 33401 \nan) 820-8711 \nFaestridle: (561)820-8777 \nJune 27, 2008 \nVIA FACSTMIT \nJack A. Goldberger, Esq. \nAtterbuty, Goldberger & Weiss, P.A. \nOne Clearlake Centre, Suite 1400 \n250 Australian Ave S. \nWest Palm Beach, FL 33401-5015 \nRoy Black, Esq. \nBlack Srebniok Komspan & Stumpf P.A. \n201 S. Biscayne Blvd, Suite 1300 \nMiami, FL 33131 \nRe: \nkfty_apstem \nDear Messrs. Goldberger and Black: \nI write to follow up on my e-mail correspondence ofjune24 and June 26, and my message \nthis morning. As of 3:15 p.m., Friday, June 27, 2008, the Office still has not received a copy oh \nproposed plea agreement between Mr. Epstein and the State Attorney's Office, nor has the Office \nreceived notice of a date and time for a change of plea. \nAs you know, the Non-Prosecution Agreement between Mr. Epstein and the Office called \nfor Mr. Epstein to plead, be sentenced, and begin serving his sentence not later than January 4, \n2008—almost six months ago. The Office has continued that deadline to allow Mr. Epstein to raise \nvarious issues with the Department of Justice, but repeatedly advised that, once those appeals were \ncompleted, Mr. Epstein would need to perform the terms of the agreement within a short window \nthereaftet. Now that those appeals have been exhausted, we promptly Informed counsel for Mr. \nEpstein tbstt he must enter his plea, be sentenced, and begin serving his sentence by 5:00 on Monday, \nJune 30, 2008. \nThis week I have seat two e-mails and left a message -with Mr. Black's rcceponist asking \nfor the date end time of the change of plea and fox a copy of the proposed pica agreement between \nMr. Epstein and the State Attorney's Office in accordance with the terms of the Non-Prosecution \nAgreement. I have received no response to any of those requests. \nUS_Atty_Cor_00311 \nEFTA00235637\n", "char_count": 1998}, {"efta_number": "EFTA00235326", "page_number": 312, "text_content": "JIM. 27.2028 \n3139PM \nLEM WPB FL \nJACK O0LDBBR0ER, ESQ. \nRoY Blanc ESQ. \nJUNE 27, 2008 \nNos 2 oP 2 \nNO.324 \nP.3 -\"- \" \nI have received correspondence from counsel for a witness asking to cancel or continue the \nwitness's appearance because he “understand[s] that there has been a recent development with \nrespect to Mr. Epstein in that he intends to plead guilty in Florida state court on Monday pursuant \nto a deferred prosecution agreement with your office that has already been executed\" and that he has \n\"learned from Mr. Epstein's attomoy that the plea is scheduled to take plaoo on Monday morning.\" \nI also understand that there is an entry on Judge McSorley1 s docket that a hearing la scheduled for \n8:30 a.m. on Monday. \nBoth parties have agreed that it is a material term of the Non-Prosecution Agreement that the \nUnited States shall have the right to review the terms of any agreements between Epstein and the \nState Attorney's Office prior to entering into those agreements. If, indeed, the change of plea is set \nfor 8:30 Monday morning, the agreement with the State Attorney's Office must be provided to the \nOffice by 4:30 today to allow adequate time to review and comment. ?allure to provide this \nopportunity shall be deemed a breach of the Agreement. \nAccordingly, I spin ask that you provide me with a copy of the Plea Agreement with the \nState Attorney's Office and notification of the date and time of the change of plea. \nThank you. \nBY: \ncc: \nKaren Atkinson, AUSA \nSincerely, \nA. Marie Villafafut \nAssistant United States Attorney \nUS_Atty_Cor_0031 2 \nEFTA00235638\n", "char_count": 1590}, {"efta_number": "EFTA00235326", "page_number": 313, "text_content": ":UN.27.2003 c:3 21 \nUSAO WPS 7L \nNO.213 \n'‘'.2 \nU.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Maattlien Ave, Stilts 400 \nWest Pan Beath FL 33401 \n(561) 8204711 \n• \nFacsimile: (361) 820.8777 \nJune 27, 2008 \nVIA FACSIMILE AND ELECTRONIC M411. \nJack A. Goldberger, Esq. \nAtterbury, Goldberger & Weiss, P.A. \nOne Clearlake Centre, Suite 1400 \n250 Australian Ave 5: \nWest Palm Beach, FL 334014015 \nRoy Black, Esq. \nBlack Srebnick Kornspan & Stumpf P.A. \n201 S. Biscayne Blvd, Suite 1300 \nMiami, FL 33131 \nRe: \nJeffrey Epstein \nDear Messrs. Goldberger and Black: \nThank you for providing me with the proposed plea agreementbetween Mr. Epstein and the \nState Attorney's Office. The U.S. Attorney's Office hereby provides Notice that the proposed \nsentencing provision does Re comply with the terms of the Non-Prosecution Agreement. \nThe second sentencing paragraph of the proposed plea agreement reads: \nOn 08CF00938 AME,the Defendant is sentenced to 18 months Commonly Control \n1 (one). As 4 special condition of this Cougnunitv Control the Defendant must \nserve the first 6 months in the Palm Beach County Detention Facility . , . \n'rho Non-Prosecution Agreement specifloally provides: \n'Epstein shall be sentenced to consecutive tonne of twelve (12) months and Mx (6) \nmonths In county la91 for all charges, . .. without probation or community control la \nBegslimprisonment \nThus, the proposed plea agreement with the State Attorney's Office does not comply with the terms \nof the Non-Prosecution Agreement. To comply with the Agreement, Mr. Epstein must make a \nbinding recommendation of eighteen months kuensonmeJS, which means confinementtwenty-four \nUS_Atty_Cor_0031 3 \nEFTA00235639\n", "char_count": 1729}, {"efta_number": "EFTA00235326", "page_number": 314, "text_content": "SUN. 27. 2008 \n5: 55PM \nW \nWPB FL \nNU. de.4 \nr'.4 \nJACK GOtaBPROEft, ESQ. \nROY ILA= pa/ \nJUNG 27, 2008 \nPAos208 2 \nhours a day at the County Jail, and the judp must accept that recommendation. Community control \nmust follow that term of incarceration. \nSecondly, we have not been provided with a copy of the Information filed In ease number \n08CF009381AMB. I want to confinn that Mt Epstein is being charged with the substantive offense \nof procuring minors to engage in prostitution, not Sterared procurement. Accordingly, please \nprovide me with a copy ofiho Information at your earliest opportunity. I will be available via email \nthroughout the weekend or you may reach me on my cell phone at 561 6014301. \nThank you, \ncc: \nKaren Atkinson, AUSA \nSincerely, \nR. Alexander Moats \nUnited States Attorney \nBY: \nataw-tliestkr4.-\n.111Villafalia \nAssistant United States Attorney \nUS_Atty_Cor_00314 \nEFTA00235640\n", "char_count": 910}, {"efta_number": "EFTA00235326", "page_number": 315, "text_content": "Jack Goldberger \nFrom: \nSent: \nTo: \nCc: \nSubject: \nsee \nFrom: \n(USAFLS) \nSent: Fri 6/27/2008 5:45 PM \nTo: \nRoy BLACK \nCc: \n(USAFLS) \nSubject: Notice of Non-Compliance \nDear Messrs. Goldberger and Black: \nPlease see the attached Notification Letter. \n«080627 Goldberger Black notification itr.pdf>> \nVillafaRa \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \nUS_Atty_Cor_0031 5 \nEFTA00235641\n", "char_count": 395}, {"efta_number": "EFTA00235326", "page_number": 316, "text_content": "Jack Goldberger \nFrom: \nSent: \nTo: \nSubject: \nnot a p/ob!em. \nMow \nFrom:_,. \n(USAFLS) [malt\nSent: Sat 6/28/2008 11:31 AM \nTo: Jac \ner \nCc: \n(USAFLS); \nSu \n. Re: Notice of Non-Compliance \nDear Jack: \nI have conferred with a state court practitioner who stated that that is nothing that prohibits you from agreeing to a consecutive six-\nmonth sentence of incarceration followed by one year of community control as specified in the non-prosecution agreement. \nIf you elect to proceed with the plea agreement as currently drafted, we ask that you insert the word \"imprisoned\" following the words \n\"six months\" in the second sentencing paragraph. \nPlease confirm that this change is acceptable. Thank you. \n-- Original Message --\nFrom: IMIE, \n(USAFLS) \nSent: Fri 6/27/2008 5:45 PM \nTo: Jack \n, Roy BLACK \nCc: \n(USAF1S) \nSubject: Notice of Non-Compliance \nDear Messrs. Goldberger and Black: \nPlease see the attached Notification Letter. \n<<080627 Goldberger Black notification Itr.pdf>> \nUS_Atty_Cor_0031 6 \nEFTA00235642\n", "char_count": 1015}, {"efta_number": "EFTA00235326", "page_number": 317, "text_content": "MIS \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \n• \n2 \nUS_Atty_Cor_0031 7 \nEFTA00235643\n", "char_count": 96}, {"efta_number": "EFTA00235326", "page_number": 318, "text_content": "Jack Goldberger \n(UAFLS) \nSent: \nrily\n'..nel l.08 \n11S:31 AM \nTo: \nCc: \n(USARS); Rfilack©RoyEllackoorn \nSubject \na o ce \non-Compliance \nDear Jack: \nI have conferred with a state court practitioner who stated that there is nothing that \nprohibits you from agreeing to a consecutive six-month sentence of incarceration followed by \none year of community control as specified in the non-prosecution agreement. \nIf you elect to proceed with the plea agreement as currently drafted, we ask that you insert \nthe word \"imprisoned\" following the words \"six months' in the second sentencing paragraph. \nPlease confirm that this change is acceptable. Thank you. \n3\n,,-, \nFrom: \n(USAFLS) \nSent: !WOOS 5:45 \nHA \nTo: Jack Goldber er; Roy BLACK \nCc: \n(USAFLS) \nSubject: Notice of Non-Compliance \nDear Messrs. Goldberger and Black: \nPlease see the attached Notification Letter. \n«080627 Goldberger Black notification ltr.pdf» \nAssistant U.S. Attorney \nUS_Atty_Cor_00318 \nEFTA00235644\n", "char_count": 969}, {"efta_number": "EFTA00235326", "page_number": 319, "text_content": "PLEA IN THE CIRCUIT COURT \nTHE FOLLOWING IS TO REFLECT ALL TERMS OF THE NEGOTIATED SETTLEMENT • \nName: Jeffrey E. Epstein \nPlea: Guilty \nCase No. \nCharge \nCount Lesser \nDecree \n06CF009454AMB \nFelony Solicitation of Prostitution \n1 \nNo \n3 FEL \n08CF009381AMB \nProcuring Person Under 18 for Prosthution 1 \nNo \n2 FEL \nPSI: Waived:Not Required X \nRequired/Requested \nADJUDICATION: \nAdjudicate (x I \nSENTENCE: \nOn 06CF000454AMB, the Defendant is sentenced to 12 months in the Palm Beach Cotinty \nDetention Facility, with credit for I (one) day time served. \nOn 08CF009381AMS, the Defendant is sentenced to 18 months Community Control 1 (one). As \na special condition of this Community Control, the Defendant must serve the lista \nmonths hi the Palm Beach County Detention Facility, with credit for 1 (one) day time \nserved. This sentence Is to be served consecutive to the 12 month sentence in \n08CF009454AMB. The conditions of community control are attached hereto and \nincorporated herein. \nOTHER COMMENTS OR CONDITIONS,: \nCourt Cost& $47400 \nCost of Prosecution: $50.00 \nDrug Trust Fund: $50.00 \nMe special condition of his community control, the Defendant Isle have no unsupervised \ncontact with minors, and the supervising adult must be approved by the Department of \nCorrections. \nThe Defendant is designated as a Swami Offender pursuant to Florida Statute 943.0435 and \nmust abide by el the corresporang requirements of the statute, a copy of which Is attached \nhereto and incorporated herein. \nThe Defendant must provide a DNA sample In court at the time of this plea. \nAssistant State Attorney \nAttorney for the Defendant \nDate of Plea \nDefendant \nUS_Atty_Cor_00319 \nEFTA00235645\n", "char_count": 1683}, {"efta_number": "EFTA00235326", "page_number": 320, "text_content": "G \nPLEA IN TM CIRCUIT COURT \nTHE FOLLOVONG IS TO REFLECT ALL TERMS OF THE NEGOTIATED SETTLEMENT \nName: Jeffrey E. Eythteln \nPlea: Gully \nciteeit\nCalla \nQmitloinipr \nOtenta \nD0CFN0NS4AMB \nFelony sotioltation of Prostitution \ni \nNo \n3 FEL \nDaCF31333IAMEI \nProcuring Person Under 13 tar Prostthaton 1 \nNo \n2 FEL \nMr: Ytialysthefot Required \n, \nRequirecIffiequeVed \nap,41_U9CAIELM: \nMthaste tx \n'SENTENCE: \nOn 06CseethMatv13,. the CeiandarrlIsserrisneeci to 12 months in the Palm Be ass County \nDetention Faray, with crea for (one) day dme serest \nOn 08CF00SINHAMB, the Delandent la sentenced to 6 rntm hdhr rho Palm Roach County \nDetention Feat, %eel verities i (one) day' he served. This 6 Month sentence \nto t\nserved cansawiHe to the 12 month sentence in O3CF0094644ME3. Following this 6 \nmonth swamp's, the Defendant va3 be yawed on 12 months Ccranitrolty Control I (one). \nThe =Widens ci community =hot are attached hereto ondtriornptheted herein. \nOTHER COMMA-ES OR cared DOHS: \n32,\nAs a veva] concert of his community control, tho pet antis to have no unsuporetcd \ncontnot with inMors, and the super/help adult must te mowed by the Department of \nCorXcifons. \nThe Defendant to deggiabed as a Sexual °Mender Frost:ant to fqoilott Statute MAIM and \nMust akin by all the corresponding mquimrncnls of the stntulat, a copy of rinth et ettaithed \nhereto and incorporated herein. \nThe Verandard must provide a DNAsant* in court at the time of \nrp iill. GI; \nlathe Defanclant \nlen43r4t\n4 \nUS_Atty_Cor_00320 \nEFTA00235646\n", "char_count": 1516}, {"efta_number": "EFTA00235326", "page_number": 321, "text_content": "Jack Goldberger \nFrom: \nSent: \nTo: \nSubject: \nOn Jun 30, 2008, at 5:16 PM, la \nMal \nXUSAFLS1)\" \nwrote: \nJack: \nThe FBI has received several calls regarding the Non-Prosecution Agreement. I do not know \nwhether the title of the document was disclosed when the Agreement was filed under seal, but \nthe FBI and our office are declining comment if asked. \nAssistant U.S. Attorney \n• \nWest Palm Beach, FL 33401 \n1 \nUS_Atty_Cor_00321 \nEFTA00235647\n", "char_count": 442}, {"efta_number": "EFTA00235326", "page_number": 322, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave.. Suite 400 \nWest Palm Heath. FL 33401 \n(561)820-8711 \nFacsimile: (561) 8204777 \nJune 30, 2008 \nNOTIFICATION OF IDENTIFIED VICTIMS \nNOTICE: IN ACCORDANCE WITH TITLE 18, UNITED \nSTATES CODE, SECTION 3509(d) AND FLORIDA LAW, \nTHE ATTACHED DOCUMENT IS TO BE TREATED AS \nCONFIDENTIAL AND SHALL NOT BE DISCLOSED \nEXCEPT \nIN \nCONNECTION \nWITH \nA LEGAL \nPROCEEDING. \nUS_Atty_Cor_00322 \nEFTA00235648\n", "char_count": 499}, {"efta_number": "EFTA00235326", "page_number": 323, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave., Suite 400 \nWest Palm Beach, FL 3340! \n(56!) 8204711 \nFacsimile: (560 820.8777 . \nJune 30, 2008 \nNOTIFICATION OF IDENTIFIED VICTIMS \nOn June 30, 2008, Jeffrey Epstein (hereinafter referred to as \"Epstein) entered a plea \nof guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) \nand 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in \nand for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-\n009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be \nfollowed by eighteen months' of Community Control 1, the first six months of which must \nbe served imprisoned at the Palm Beach County Detention Facility. \nIn light of the entry of the guilty plea and sentence, the United States has agreed to \ndefer federal prosecution in favor of this state plea and sentence, subject to certain \nconditions. \nOne such condition to which Epstein has agreed is the following: \n\"Any person, who while a minor, was a victim of a violation of an offense \nenumerated in Title 18, United States Code, Section 2255, will have the same \nrights to proceed under Section 2255 as she would have had, if Mr. Epstein \nhad been tried federally and convicted of an enumerated offense. For purposes \nof implementing this paragraph, the United States shall provide Mr. Epstein's \nattorneys with a list of individuals whom it was prepared to name in an \nIndictment as victims of an enumerated offense by Mr. Epstein. Any judicial \nauthority interpreting this provision, including any authority determining \nwhich evidentiary burdens if any a plaintiff must meet, shall consider that it is \nthe intent of the parties to place these identified victims in the same position \nas they would have been had Mr. Epstein been convicted at trial. No more; no \nless.\" \nInitials of Jeffrey Epstein  \n \nInitials of Jack Go\n... [truncated, 2042 chars — for the full page use /api/corpus/document/EFTA00235326/323 or ?id=EFTA00235326&page=323]", "char_count": 2042}, {"efta_number": "EFTA00235326", "page_number": 324, "text_content": "NOTIFICATION OF IDENTIFIED VICTIMS \nJUNE 30, 2008 \nPAGE 2 OF 3 \nThrough this letter, this Office hereby provides Notice that the individuals identified \nbelow are individuals whom the United States was prepared to name as a victim of an \nenumerated offense. \nIdentified Individuals \nDated: \n \nBy: ot \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nVILLAFARA \nASSISTANT U.S. ATTORNEY \nACKNOWLEDGMENT \n1 have received this Notification from my attorney, Jack Goldberger, Esquire, have \nread it and discussed it with my attorney, and I hereby acknowledge that it accurately sets \nforth my understanding and agreement with the Office of the United States Attorney for the \nSouthern District of Florida regarding the notification and rights of identified victims. I \nInitials of Jeffrey Epstein  \n Initials of Jack Goldberger \nUS_Atty_Cor_00324 \nEFTA00235650\n", "char_count": 852}, {"efta_number": "EFTA00235326", "page_number": 325, "text_content": "NOTIFICATION OF IDENTIFIED VICTIMS \nJUNE 30.2008 \nPAGE 3 OF 3 \nunderstand that an exact copy of this Notification will be provided to each identified \nindividual, except that the names of all other identified individuals will be redacted, and I \nhereby waive any evidentiary challenges to the introduction of a copy of this document-even \nlin redacted form—inI iany judiciat proceeding bettien any identified individualid myself. \ni \nt \nI \n4 \ni \n4i \n4 \niDated:  \ni \n \ni \ni \n4 \n4 \n• \ntt \nI \nJekey Epsteinl.\nt \ni \ni \n1 \nI \n4 \n1 \n4 \ni \nti \nI \ni \nWitt \n \n t\nessed by: \n \nr_____ \ni \ni \nI \ni Jack Goldberge Esquire \nI \n0 \n4 \nIII \nI \nI \nUS_Atty_Cor_00325 \nEFTA00235651\n", "char_count": 662}, {"efta_number": "EFTA00235326", "page_number": 326, "text_content": "laprqs.410..u-B skistegt• . \nir \n• cm1400isozoti: .c-\nbreerothyoffilfri; trc'n\"01014. \n'Grafi \nto \nkits \n\".2k1 OSP \nN \n \n •0 \n• \n• ,A) \n- 40;g644.11.01$ 4;ii: \nPardo 011?5:' \n \n•/' \ntuk1/4 lub*L,Wat Pul ' \ntho tivuthipi*at cookpit\n' • \n• i tspozit \nmyoti,vontORovisetior“. \njra= \nticAum \nI \ntrig \nkm. ft ./NA kir.. \nRat .10a-Mf-M • \n• .• \n• \nUS_Atty_Cor_00326 \nEFTA00235652\n", "char_count": 374}, {"efta_number": "EFTA00235326", "page_number": 327, "text_content": "ti 4 f•—• \n1;•'; \n• ' \nL \n, \n*:. \nage 2\nink \n‘,. \n. \n:ProI / \n•: O \nSex Off7 Drag ON Fr \nO.C. I C.C. 0: -14..L...t.9'  14:as titiofs:. ,T7r.„4.„ \nOotttleo. vat \n. \n•• • ' \n• \n• \n. \n• \nGI Probation tdmsfernadth:. .4 ** \n• \n• \n•\n ...\n. \n• \n. \n \n' \n. \n' \n • \n. \nEIPEOMIt. \n0 gornPlete,Otiginally \n.0 (lurks/in \nQS Deft: to \n,Q. Deg. \nfl  Oak to \n0 Restitution \nCONCOIT'CMS: 1 \n• • \n. \n. \n• \n. \n.. \n. \n. \nOrSq34,00nrillioni ... \n-- • . ..• . \n• \n. . \n. . . \n .• \n•\n• • \np.m.,\n;\n with the-billowing (*.copilot'''. \n..• • \n. \n• \n• - '• • \n•\n, , . • \n• \n. \n.  .\n. \nfelted to•Prob., Dept. Immediately, tan release. i ' \n• \n. \n. \n.. . \nrisk ip have in care, custody; or confratany.tthlawful•Of1 \nI. etsial, sub**, \n et: . \n. \n. • \n&Vies, 'Object \nimmad)atetY n \nProb. Officer If alace of residence-to \nchanges. • - .„: \n• \n.z 4 •:,:* \nfled \n . \nCIV ed \n\" • \n\"rgiii\n-afplYTO \nV, \n[MS Of \n. \n- - . , 4- \n• .- \n--- •:-4.-^,\" \n4.-..v., \n:tki4Sitii* \n0 No tonSumption/Possession \nO attend \n\"ta .0ettiellio \n•.. vornpitit criNtil. \n'Teiffirnlick40414°)e \nof Alcbhol \n• \n.- \n• .AAandier NAMeetings \n• •• \n• • \nel qtal/ l '\n \nual'Eval. within / by: \n., :Art # \n•\n' \n64 pitere:•-:,•r DetWavat \n• \n.ay.:-:•1\n...\nOr Drugs or Intoxicante without a Prescription... \" '‘ ;al' .; : • • \nper. Week: .  .\n. \n• \n' \n• : ' \n• •.Ziiziel \nAsap. pfiaguy iitrpospie the sale cif alcobot..,t: • .. `'.2.: pi \nfr,squerst any.olace 9Thfieusyreas \n'CI :Complete. :.._• the of °anima:14y \ntri:rice to he-done at the rate of ...._..:..242 Lira pet ilWril4o.(1Thapj \n••0 \n \n• • \n' q,l2g. /la' \n• \n• \n• • \n• : • - - '• \" ''••%1\n.244tbrfilitItestglisittlatets4Ditigtler \n.. \n_ \nQ. apza.iiiiteuccep.sfuny.compoteakichciaiiiiis:sessitoNethiiiinpot r.636.014. : • .... .„... ... .' : \n.p N.&•06?iteg t No -viotifit Contact/. Igo.. keel orintlInsct.contact w/Viptim(s), •etherslistet•iiv.• , - \n• \n• \nII,5 Conte \n0 \nCa- RoldatiOuetody, \n0 •Eater•Shd Successfully \nCl Sofia Weepon \nwardfinor Child-ten wigAltil \n'girt \n• ' ' e't \nwearer on aware o\n... 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[truncated, 2537 chars — for the full page use /api/corpus/document/EFTA00235326/328 or ?id=EFTA00235326&page=328]", "char_count": 2537}, {"efta_number": "EFTA00235326", "page_number": 329, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Alvan Suits 400 \nI9at Palo Bradt Florida 334014233 \nMay 14, 2007 \nVIA HAND DELIVERY \nJack A. Goldberger, Esq. \nAtterbury, Goldberger & Weiss, P.A. \nOne Clearlake Centre, Suite 1400 \n250 Australian Avenue South \nWest Palm Beach, FL 33401-5015 \nDear Mr. Goldberger: \nThank you for your letter of May 19, 2007, and the documents attached thereto. I have enclosed \nanother copy of the grand jury subpoenas that were provided to Bruce Lyons, former counsel for Hyperion \nand JEGE,. on April 25, 2007. The time for responding has passed, so please provide the requested \ndocuments as soon as possible. Please also have the Custodians of Records of the Corporati \nthe Business Records Certifications and Inventory Forms and return everything to Special Agent\nat the Federal Bureau of Investigation, 505 South Flagler Drive, Suite 500, West Palm Beach, FL 33401-\n5933. \nThank you for your assistance with this matter. \nEnclosures \ncc: Special Agent \nFBI \nSincerely, \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nBy: A. MARIE VILLAFAIAA \nAssistant United States Attorney \nUBBD5j \nUS_Atty_Cor_00329 \nEFTA00235655\n", "char_count": 1206}, {"efta_number": "EFTA00235326", "page_number": 330, "text_content": "th \nUnited States District Court \nSOUTHERN DISTRICT OF FLORIDA \nen \nTO: Custodian of Records \nHyperion Air, Inc. \nSUBPOENA TO TESTIFY \nBEFORE GRAND JURY \nFOJ 07-103(WPB)-Tues./No. OLY-46 \nSUBPOENA FOR: \nE\nPERSON \nEl DOCUMENTS OR OBJECT(S1 \nYOU ARE HEREBY COMMANDED to appear and testifybefore the Grand Jury oftheUnited StatesDistriet \nCourt at the place, date and time specified below. \nPLACE: \n• \nUnited States District Courthouse \n701 Clematis Sweet \nWest Palm Beath, Florida 33401.\nROOM: \nGrand Jury Room \nDATE AND TIME: \nMay 8, 2007 \n1:00 pm* \nYOU ARE ALSO COMMANDED to bring with you the following document(s) or obit:Logs): \nAll income tax returns, balance sheets, regulatory filings, minutes of board of directors meetings, and \ndocuments required by or Bled with the Internal Revenue Service and/or the State of Delaware \nreferring or relating to the period of 111/2003 to 12/31/2005. \nFor the period 1/1/2003 to the present, the names of all employees, copies of all W-2s for all employees, \nand the names of all corporate directors, board members, and shareholders. \n?least coordinate your compliance with this subpoena and confirm the date and (yne aid location of \nyour appearance with Special Agent \nKuyrkendall, FedeTal Bureau of Investigation, Telephone: \n(561) 822-5946. \nThis subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting \nonbehalf of the court. \nglY)DBPVIY CLERK \nDATE: \nApril 24, 2007 \nThis subpoena is issued upon application \nof the \nStates of America \nAddress and Phone Number of Assistant U.S. Attorney \nAssistant U.S. Attorney \na urn re\naate, \n Suite 400 \nWestPalmBeach, FL 33401.6235 \nTel: (561) 820-8711 x3047 \nFax: (561) 802-1787 \n'If noi applkable, amr 'owe.\" \nla In asil be Hit et A0110 \nFORM 0RD•217 \nJAN46 \nUS_Atty_Cor_00330 \nEFTA00235656\n", "char_count": 1832}, {"efta_number": "EFTA00235326", "page_number": 331, "text_content": "S \nU.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \nMet Australian Art, Silts 400 \nWitt Patin Ira FL LI4014231 \n($61)820-8111 \nAPPEARANCE NOTICE \nThe attached subpoena requires the production of the records specified to a Federal \nGrand Jury/Trial in the Southern District of Florida. \n• \nA new provision of the Federal Rules of Evidence provides that routine business \nrecords may be admitted at trial through the declaration of a custodian, if they are provided \nsufficiently in advance of trial to allow an opportunity for any challenges to their \nauthenticity. Therefore, you may be able to avoid appearing personally at the grand \nJury/trIal at the time and place specified by completely filling Out the attached Certification \nand Inventory and immediately returning it with the records to Special Agent \nKuyrkendall, FBI at the following address: \nFederal Bureau of Investigation \n505 South Flagler Drive, Ste. 500 \nWest Palm Beach, Florida 33401.5923 \nEARLY VOLUNTARY TURNOVER' • \nPlease note that we are requesting an early voluntary turnover of the materials \nsubpoenaed, The early voluntary turnover date Is prior to Mav 8. 2007. \nBY: \nSincerely, \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nAS \nITED STATES ATTORNEY \nUS_Atty_Cor_00331 \n06607 \nEFTA00235657\n", "char_count": 1302}, {"efta_number": "EFTA00235326", "page_number": 332, "text_content": "R. \nCERTIFICATION OF BUSINESS RECORDS \nI, the undersigned, \n, declare that I am: \nemployed by/associated with \n in the \nposition of  \n• \n and by reason of my \nposition am authorized and qualified to make this declaration. \nIn my employment with the above-named banklcompany I am familiar with the \nbusiness records it maintains. The above-named bank/company maintains records of its \nbusiness whIcih are: \n1. madd at or near the time of the occurrence of the matters set forth therein, by, \nor from Information transmitted by, reperson with knowledge of those matters; \n2. kept In the course of regularly conducted business activity; and \n3. made by the regularly conducted activity as a regular practice. \nAmong the records so maintained are the attached records Itemized In Appendix A, \nInventory of Documents. \nI declare under penalty of perjury that the foregoing Is true and correct. \nDate of execution: \nPlace of execution: \nSignature: \n08608; \nUS_Atty_Cor_00332 \nEFTA00235658\n", "char_count": 983}, {"efta_number": "EFTA00235326", "page_number": 333, "text_content": "APPENDIX A \nDOCUMENT INVENTORY \nThe documents submitted are as follows: \nSignature of Records Custodian: \n06609 \nUS_Atty_Cor_00333 \nEFTA00235659\n", "char_count": 145}, {"efta_number": "EFTA00235326", "page_number": 334, "text_content": "United States District Court \nSOUTHERN .DISTRICT OF FLORIDA \nTO: Custodian of Records \nJEOE, Inc. \nSUBPOENA TO TESTIFY \nBEFORE GRAND JURY \nFes O7-103(WPB)-Tues /No. OLY-47 \nSUBPOENA FOR: \nE\nPERSON \n••••••••\n•• \nX DOCUMENTS OR OrldECI[S] \nYOUARE HEREBY COMMANDED to appear and testifybefore the Grand Jury of theOnited States District \n. Court at the place, date and time specified below. \nPLACE: \nUnited States District Courthouse \n701 Clematis Street \nWest Palm Beach, Florida 33401 \nROOM: \nGrand Jury Room \nDATE AND TIME: \nMay 8, 2007 \n1:00 pm* \nYOU Ala ALSO COMMANDED to bring with you the following documents) or object(s): \nAll income tax returns, balance sheets, regulatory filings, minutes of board of directors meetings, and \ndocuments required by or filed with the Internal Revenue Service and/or the State of Delaware \nreferring or relating to the period of 1/1/2003 to 12/31/2005. \nFor the period 1/1/2003 to the present, the names of all employees, copies of all W-2s for all employees, \nand the names of all corporate directors, board members, and shareholders. \n*Please coordinate your compliance \nd confirm the date and time , and location of \nyour appearance with Special Agent \nFederal Bureau of Investigation, Telephone: \n(561) 822-5946. \nThis subpoena shall remain in effect until you arc granted leave to depart by the court or by an officer acting \nCo behalf of the court. \nCLERK \nISN0DIFUTY CUM \nDATE: \nApril 24, 2007 \nThis subpoena is issued upon application \nof the United Stites of \nmiirs\nand Phore'Numbet of Assistant US. Attorney \nVillataiia, Assistant U.S. Attorney \nS00 So. Australian Avenue, Suite 400 \nWest Palm Beech, FL 33401-6235 \nTel: (561)820-8711 x3047 \nFax (561) 802-1787 \nIf not spplleable, <ma nese \nTakesedhllge•CA0110 \nFORM ORD•227 \nJAMS6 \nUS_Atty_Cor_00334 \nOBE \nEFTA00235660\n", "char_count": 1819}, {"efta_number": "EFTA00235326", "page_number": 335, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \nSOD& Amitniltaw Ave, Sulfa 400 \nWere Pala Duct \n3$801401 \n(561)820-8711 \nAPPEARANCE NOTICE \nThe attached subpoena requires the production of the records specified to a Federal \nGrand Jury/Trial in the Southern District of Florida. \nA new provision of the Federal Rules of Science provides that routine business \nrecords may be admitted at trial through the declaration of a custodian, if they are provided \nsufficiently In advance of trial to allow an opportunity for any challenges to their \nauthenticity. Therefore, you may be able to avoid appearing personally at the grand \nJury/trlal at the time and place specified by completely filling out the attached Carlo. \nand immediately returning it with the records to Special Agent \nFBI at the following address: \nFederal Bureau of Investigation \n505 South Flagler Drive, Ste. 500 \nWest Palm Beach, Florida 33401.5923 \nEARLYMOLUNTARY TURNOVER \nPlease note that we are requesting an early voluntary turnover of the materials \nsubpoenaed. The early voluntary turnover date is prior to May S. 2007. \nSinderely, \nBY: \nFL ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nASSISTANT UNITED STATES ATTORNEY \nUS_Atty_Cor_00335 \nEFTA00235661\n", "char_count": 1256}, {"efta_number": "EFTA00235326", "page_number": 336, "text_content": "CERTIFICATION OF BUSINESS RECORDS \nI, the undersigned, \n, declare that I am: \nemployed by/associated with \nIn the \nposition of \nand by reason of my \nposition am authorized and qualified to make this declaration. \nIn my employment with the above-named bank/company I am familiar with the \nbusiness records it maintains. The above-named bank/company maintains records of its \nbusiness which are: \n1. made at or near the time of the occurrence of the matters set forth therein, by, \nor from Information transmitted by, a person with knowledge of those matters; \n2. kept In the course of regularly conducted business activity; and \n3. made by the regularly conducted activity as a regular practice. \nAmong the records so maintained are the attached records itemized in Appendix A, \nInventory of Documents. \nI declare under penalty of perjury that the foregoing is true and correct. \nDate of execution: \nPlace of execution: \nSignature: \n0B612 \nUS_Atty_Cor_00336 \nEFTA00235662\n", "char_count": 971}, {"efta_number": "EFTA00235326", "page_number": 337, "text_content": "' \nI ' \nAPPENDIX A \nDOCUMENT INVENTORY \nThe documents submitted are as follows: \nSignature of Records Custodian: \nOB613\nUS_Atty_Cor_00337 \nEFTA00235663\n", "char_count": 152}, {"efta_number": "EFTA00235326", "page_number": 338, "text_content": "UD/lb/ZUU( LO:DI LAX 0010V4A/01 \n•J••••.•••• \n• • \n.• ••• \n• ••• \nU.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Ataraltan Ava,Sutte 400 \nWest Palm Beach, FL 33401 \nO61)820-87)1 \nFacardis: (561) 820-8777 \nMay 15, 2007 \nVIA mcsua \nJack A. Goldberger, Esq. \nAttcrbury, Goldberger & Weiss, P A. \nOno Clearlakc Centre, Suite 1400 \n250 Australian Ave S. \nWest Palm Beach, FL 33401-5015 \nRe: \nSubpoenas SIEGE. Inc. and Hyperion Air, Inc. \nDear Mr. Goldberger: \nIt was a pleasure speaking with you today. As we discussed, the deadlines for complying \nwith the subpoenas to MOE, Inc. and Hyperion Air, Inc. have been extended to May 29, 2007. If \nthere arc any categories for which no documents exist, please ask the Custodian. of Records to \nprovide a certificate of nonexistence of records. \nAlso, following our conversation I mceived a voicemail from Lilly IIISanchez addressing \nthe subpoenas. Since you have provided a written statement that you represent SEGE and Hyperion, \nI will assume that you alone save as their counsel unless you toll mo otherwise. With that in mind, \npursuant to Rule 6(e), I do not intend to discuss matters related to these subpoenas with other \nattorneys, \n. \nThank you again for your assistance. \nCC: \nBy: \nSincerely, \nR. Alexander Acosta \nAssistant United States Attorney \nUS_Atty_Cor_ 00338 \nEFTA00235664\n", "char_count": 1379}, {"efta_number": "EFTA00235326", "page_number": 339, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n300 JoinhAurrraltwbowsue. Slaw 400 \nWest Palm Beach, Plorlda S3401-6235 \ntel: O61) 810.8711 \nPar (501) 8104777 \n• \nJune, 2007 \nJack Alan Goldberger, Esq. \nAttcrbury Goldberger et al\n250 South Australian Ave. \nSuite 1400 \nWest Palm Beach, FL 334015-5015 \nRe: Subpoenas to 513GE, Inc, and Hyperion Air, Inc. \nDear Mr. Goldberger: \nThank you for your response to the subpoenas issued to TEGE, TAO. and Hyperion Air, Inc. \nIn the responses from each company, thcM are no lists of the corporate directors, board \nmembers, and shareholders (with the exception of the WOE IRS Form 2553 and Hyperion Sham \nCertificate). Please ask the Custodian of Records to provide a list of all corporate directors, board \nmembers, and shareholders from January 1, 2003 to the present. Please also ask the Custodian of \nRecords to confirm that them are no records of any board of directors meetings that occurred \nbetween January 1, 2003 and December 31, 2005. \nThank you again for your assistance. \nSincerely, \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nBy IIIMIVILLAFARA \nAssistant nited States Attorney \nUS_Atty_Cor_00339 \nEFTA00235665\n", "char_count": 1201}, {"efta_number": "EFTA00235326", "page_number": 340, "text_content": "Jack Goldberger \nFrom: \nSent: \nTo: \nSubject: \nsi\naliaggsaa \nRead carefully the Si suspension portion of the non pros agreement. It says upon signing the non pros agreement and A \nPLEA AGREEMENT with SAO all pending GJ subpoenas will be held In abeyance. Doesn't that imply that when we sign \nplea agreement with state this week the new al subpoenas that are out now go into abeyance status also \nFrom: VIllafana, EIMIS \n(USAFLS) \nSent: Tuesday, June 24, 2008 4:16 PM \nTo: \n• \nGoldberger \nCc■\n(USAFLS) \nSubj \n:Jeffrey Epstein Agreement \nDear Roy and Jack: \nI am just writing to re-state that it is the Government's position that we have a signed, binding agreement and \nthat there is no need for further modification. \nPlease keep us informed of the date and time of the change of plea and sentencing. \nThank you. \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \nUS_Atty_Cor_00340 \nEFTA00235666\n", "char_count": 898}, {"efta_number": "EFTA00235326", "page_number": 341, "text_content": "LN. v..≥ane \n3:35PM \n()SRO wPB ft \n• \n•••••••••• \nU.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Aw.. Suite 400 \nWens Patin Reach FL 33401 \n($61) 8204711 \nFacsimile: (561)820-8777 \nJuno 27, 2008 \nVLIt Map= \nJack A. Goldberger, Esq. \nAtterbury, Goldberger & Weiss, P.A. \nOne Clearlake Centre, Suite 1400 \n250 Australian Ave S. \nWest Palm Beach, FL 33401-5015 \nRoy Black, Esq, \nBlack Srebniok Kornepan & Stumpf PA. \n201 S. Biscayne Blvd, Suite 1300 \nMiami, FL 33131 \nRe: \nItiftethildeb \nDear Mean. Goldberger and Black: \nI write to follow up on my e-mail correspondence of June 24 and June 26, and my message \nthis morning. As of 3:15 p.m., Friday, June 27, 2008, the Office still has not received a copy of a \nproposed plea agreement between Mr. Epstein and the State Attorney's Office; nor has the Office \nreceived notice of a date and time for a change of plea. \nAs you know, the Non-Prosecution Agreement between Mr. Epstein and the Office called \nfor Mr. Epstein to plead, be sentenced, and begin serving his sentence not lea than January 4, \n2008—almost six months ago. The Office has continued that deadline to allow Mr, Epstein to raise \nvarious issues with the Department ofJustioe. but repeatedly advised that, once those appeals were \ncompleted, Mr. Epstein would need to perform the tents of the agreement within a short window \nthereafter. Now that those appeals have been exhausted, we promptly brimmed counsel for Mr. \nEpstein tbat he must enter his plea, be sentenced, and begin serving his sentence by 5:00 on Monthly, \nlime 30, 2008, \nThis week I have sent two e-mails and left a message with Mr. Black's receptionist asking \nfor the date and time of the change of plea and for a copy of the proposed plea agreement between \nMr. Epstein and the State Attorney's Office in accordance with the terms of the Non-Prosecution \nAgreement I have received no response to any of those requests. \nUS_Atty_Cor_00341 \nEFTA00235667\n", "char_count": 1991}, {"efta_number": "EFTA00235326", "page_number": 342, "text_content": "JUN.27.2026 \n3:39M1 \nISO UPS FL \nJACK GOLDBERGER, ESQ. \nROY SLAM SEQ. \nAin 27, 2008 \nPAGE 2 op 2 \nNO.324 \nP.3 \nI have received correspondence from counsel for a witness asking to cancel or continue the \nwitness's appearance because he \"under:tangs] that then, has been a recent development with \nrespect to Mr. Bpstein in that he intends to plead guilty in Florida state court on Monday pursuant \nto a deferred prosecution agreement with your office that has already been executed\" and that he has \n\"learned from Mr. Epstein's attorney that the plea is scheduled to take place on Monday morning.\" \nI also understand that there is an entry on Judge McSorley's docket that a hearing is scheduled for \n8:30 a.m. on Monday. \nBoth parties have agreed that it is a material term of the Won-Prosecution Agreement that the \nUnited States shall have the right to review the terms of any agreements between Epstein and the \nState Attorney's Office prior to entering into those agreements. If, indeed, the change of plea is set \nfor 8:30 Monday morning, the agreement with the State Attorney's Office must be provided to the \nOffice by 4:30 today to allow adequate time to review and comment Failure to provide this \nopportunity shall be deemed a breach of the Agreement. \nAccordingly,' again ask that you provide me with a copy of the Plea Agreement with the \nState Attorney's Office and notification of the date and time of the change of plea. \nThank you. \nBy: \ncc: \nKaren Atkinson, Ali SA \nSincerely, \nIt Alexander Acosta \nun}ty,gtajea Attggrey \nA. Marie Villafana \nAssistant United States Attorney \nUS_Atty_Cor_00342 \nEFTA00235668\n", "char_count": 1624}, {"efta_number": "EFTA00235326", "page_number": 343, "text_content": "JUN.27.200B \nSISSPM \nUSA° WPB FL \nNO.329 \nP.2 \nDepartment of Justice \nUnited Staus Attorney \nSouthern District of Florida \n500 South Augrallan Avt, Suits 400 \nWart Paler back FL 33401 \n(561) 820-8711 \n' \nloadmilt (161)820-8777 \nJuno 27, 2008 \nVIkFACStMJLE AND EI BOTRONIC MA tt \n. Jack A. Goldberger, Esq. \nAtterbttry, Goldberger & Weiss, P.A. \nOne aearlake Centre, Suite 1400 \n250 Australian Ave S. \nWest Palm Beach, FL 33401-5015 \nRoy Black, Esq. \nBlack Srebniok Komspan & Stumpf P.A. \n201 S. Biscayne Blvd, Suite 1300 \nMiami, Pl. 33131 \nJaHey Epstein\nDear Messrs. Goldberger and Black: \nThank you for providing me with the proposed plea agreement between Mr. Epstein and the \nState Attorney's Office. The US. Attorney's Office hereby provides Notice that the proposed \nsentencing provision does ekt comply with the terms of the Non-Prosecutioa Agreement. \nThe second sentencing paragraph of the proposed plea agreement reeds: \nOn 08CF00938IAMB, the Defendant issentenced to 18 months commun fry Central \nI (met As 4 special condition of this Community Control the Defendant must \nserve the first 6 months In the Palm Beach County Detention Facility \n. \nThe Non-Prosecution Agreement specifically provides: \n'Epstein shall be sentenced to consecutive terms of twelve (12) months and eh (6) \nmonths In county Mil for oil charge*, . without orobation or communitysorthol iB \nIISLAfittlttlitnEM4111. \nThus, the proposed plea agreement with the State Attorney's Office does not comply with the terms \nof the Non-Proseeution Agreement To comply with the Agreement, Mr. Epstein must make a \nbinding recommendation of eighteen months imprisonment, which means confinement twenty-four \nUS_Atty_Cor_00343 \nEFTA00235669\n", "char_count": 1712}, {"efta_number": "EFTA00235326", "page_number": 344, "text_content": "RM. 27. 22)08 \n: 55Pri \nuSiO0 WPB FL \nNU. de:i \nJACK GOLDBERGSR, ESQ, \nROY BLACK, ESQ. \nJUNE 27, 2008 \nPAos2 Of 2 \nhews a day at the County Jail, and thejudge must acceptthatrecommendation. Community control \nmust follow that term of Incarceration. \nSecondly, wo have not been provided with a oopy of the Information filed In case number \nOSCF009381AME. I want to confirm that Mr. Epstein is being charged withthe substantive offense \nof procuring minors to engage in prostitution, not attempted procurement. Accordingly, please \nprovide mc with a copy of the Information at your earliest opportuni \nwi I be available via e-mail \nthroughout the weekend or you may reach me on my coil phone at \nThank you. \nBy: \ncc: \nKaron Atkinson. AURA \nSincerely, \nIL Alexander Acosta \nUnited States Attorney \naktr-Aatiiig#O-.\ngi\nVillafafia \ntant United States Attorney \nUS_Atty_Cor_00344 \nEFTA00235670\n", "char_count": 888}, {"efta_number": "EFTA00235326", "page_number": 345, "text_content": "Jack Goldberger \n• \nFrom: \nSent: \nTo: \nCc: \nSubject: \nFrom: \n. (USAFLS) \nSent: Fri 6/27/2008 5:45 PM \nTo: Jac \nI e \nr; Roy BLACK \nCc: \n(USAFLS) \nSubject Notice of Non-Compliance \nDear Messrs. Goldberger and Black: \nPlease see the attached Notification Letter. \n«080627 Goldberger Black notification Itr.pctf» \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401 \nUS_Atty_Cor_00345 \nEFTA00235671\n", "char_count": 394}, {"efta_number": "EFTA00235326", "page_number": 346, "text_content": "Jack Goldberger \nFrom: \nSent: \nTo: \nSubject: \nnot a problem. \nFrom: M, \nIIIM. \n(USAFLS) [\nTilustrko).gov) \nSent: Sat 6/28/20G8 11:31 AM \nIlia\nTo: \nc \n- I \nr \nCc:\n REftack@RoyElladtcom \nSub ct: Re: Notice of Non-Compliance \nDear Jack: \nI have conferred with a state court practitioner who stated that there is nothing that prohibits you from agreeing to a consecutive six-\nmonth sentence of incarceration followed by one year of community control as specified in the non-prosecution agreement. \nIf you elect to proceed with the plea agreement as currently drafted, we ask that you insert the word \"imprisoned\" following the words \n\"six months\" in the second sentencing paragraph. \nPlease confirm that this change is acceptable. Thank you. \n--- Original Message --\nair \nFrom. M. \n(USAFLS) \nSent: Fri 627/2008 5:45 PM \nTo; ac G Id r ; Roy BLACK \nCc: \n(USAFLS) \nSubject: Notice of Non-Compliance \nDear Messrs. Goldberger and Black: \nPlease see the attached Notification Letter. \n<<080627 Goldberger Black notification ltr.pdfx.> \nIt \nustoitoyl \nUS_Atty_Cor_00346 \nEFTA00235672\n", "char_count": 1073}, {"efta_number": "EFTA00235326", "page_number": 347, "text_content": "Mile \nVillefaan \nAssistant U.S. Attorney \nWest Palm Beach, FL 33401•\nMIME \n2 \nUS_Atty_Cor_00347 \nEFTA00235673\n", "char_count": 110}, {"efta_number": "EFTA00235326", "page_number": 348, "text_content": "C)\nJack Goldberger \nFrom: \nSent \nTo: \nSubject: \nOn Jun 30, 2008, at 5:16 PM, ' \nwrote: \nJack: \n\\aismtsvi \nThe FBI has received several calls regarding the Non-Prosecution Agreement. I do not know \nwhether the title of the document was disclosed when the Agreement was filed under seal, but \nthe FBI and our office are declining comment if asked. \nAssistant U.S. Attorney \n• \nWest Palm Beach, FL 33401 \n1 \nUS_Atty_Cor_00348 \nEFTA00235674\n", "char_count": 437}, {"efta_number": "EFTA00235326", "page_number": 349, "text_content": "1/4\nU.S. Department ofJustice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave., Suite 400 \nWest Palm Beath, FL 33401 \n(561)810-8711 \nFacsimile: (561) 820-8777\nJune 30, 2008 \nNOTIFICATION OF IDENTIFIED VICTIMS \nNOTICE: IN ACCORDANCE WITH TITLE 18, UNITED \nSTATES CODE, SECTION 3509(d) AND FLORIDA LAW, \nTHE ATTACHED DOCUMENT IS TO BE TREATED AS \nCONFIDENTIAL AND SHALL NOT BE DISCLOSED \nEXCEPT \nIN CONNECTION WITH \nA \nLEGAL \nPROCEEDING. \nUS_Atty_Cor_00349 \nEFTA00235675\n", "char_count": 501}, {"efta_number": "EFTA00235326", "page_number": 350, "text_content": "z \nU.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 Sous* Australian AS*, Sa41. 400 \nWest Pah back Plod& 334014131 \nMay 14, 2007 \nVIA HAND DELIVERY \nJack A. Goldberger, Esq. \nAtterbury, Goldberger &.Weiss, P.A. \nOne Clearlake Centre, Suite 1400 \n250 Australian Avenue South \nWest Palm Beach, FL 33401-5015 \nDear Mr. Goldberger: \nThank you for your letter of May 19, 2007, and the documents attached thento. I have enclosed \nanother copy of the grand jury subpoenas that were provided to Bruce Lyons, former counsel for Hyperion \nand JEGE,. on April 25, 2007. The time for responding has passed, so please provide the requested \ndocuments as soon as possible. Please also have the Custodians of Records of the Corporations com lete \nthe Business Records Certifications and InventoryForma andretum everything to Special Agent \nat the Federal Bureau of Investigation, 505 South Flagler Drive, Suite 500, West Palm Beach, FL 33401-\n%53. \nThank you for your assistance with this matter. \nSincerely, \n• \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nBy. \nEnclosures \ncc: Special Agent \nFBI \nAssistant 'United States Attorney \nUS_Atty_Cor_00350 \nOBBD5i \nEFTA00235676\n", "char_count": 1196}, {"efta_number": "EFTA00235326", "page_number": 351, "text_content": "United States District Court \nSOW-MIRY DISTRICT OF FLORIDA \nTO: Custodian of Records \nSUBPOENA TO TESTIFY \nHyperion Air, Inc. \nBEFORE GRAND JURY \nFQJ 07-103(WPB)-Tues./No. OLY-46 \nSUBPOENA FOR: \nE\nPERSON ri DOCUMENTS OR OBJECT( Si \nYOIY ARE HEREBY COMMANDED to appear andtestifybefore the Grand Jury of the United StatesDistrict \nCourt at the place, date and time specified below. \nPLACE: \nUnited States District Courthouse \n701 Clematis Street \nWest Beim Beach, Florida 33401 \nROOM: \nGrand Jury Room \nDATE AND TIME: \nMay 8, 2007 \n1:00 pm* \nYOU ARE ALSO COMMANDED to bring with you the following document(&) or object(s): \nAll Income tax returns, balance sheets, regulatory filings, minutes of board of directors meetings, and \ndocuments required by or filed with the Internal Revenue Service and/or the State of Delaware \nreferringor relating to the period of 1/112003 to 12/31/2005. \nFor the period 111/2003 to the present, the names of all employees, copies of all W-2s for all employees, \nand the names of all corporate directors, board members, and shareholders. \n*Pleas/ coordinate your compliance \nd confirm the date and time , and location of \nyour appearance with Special Agent \n, Federal Bureau of Investigation, Telephone: \n(561) 822.5946. \n• \nThis subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting \non behalf of the court. \nPi DEPUTY CLERK \nDATE \nApril 24, 2007 \nIts subpoena is issued upon application \nof the \nStates of a1/41110fial\nor\nMilasianeNnmber\nuo.sfAsAsistantyU.S. Attorney \n500 So. Australian Avenue, Suits 400 \nWest Palm Bead, Ft 334014235 \nTel: (561) 5204711 x3047 \nPam (561) 802-1787 \nnine spestate error \nTokiediiiief AM* \nFORM ORD-22/ \n104.$6 \nOBBOG • \nUS_Atty_Cor_ 00351 \nEFTA00235677\n", "char_count": 1771}, {"efta_number": "EFTA00235326", "page_number": 352, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \nta\nn\nibillsigg\ningt \n061)8208711 \nAPPEARANCE NOTICE \nThe attached subpoena requires the production of the records specified to a Federal \nGrand Jury/Trial In the Southern District of Florida. \nA new provision of the Federal Rules of Evidence provides that routine business \nrecords may be admitted at Mai through the declaration of a custodian, if they are provided \nsufficiently in advance of trial to allow an opportunity for any challenges to their \nauthenticity. Therefore, you may be able to avoid appearing personally at the grand \njuryltdal at the time and place specified by completely filling out the attached Certification \nand immediately returning It with the records to Special Agent \nFBI at the following address: \nFederal Bureau of Investigation \n506 South Flagler Drive, Ste. 500 \nWest Palm Beach, Florida 33401-5923 \nEARLY VOLUNTARY TURNOVER,.\nPlease note that we are requesting an early voluntary turnover of the materials \nsubpoenaed. The early voluntary turnover date Is prior to May 8. 2007. \nBY: \nSincerely, \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nTATES ATTORNEY \n06607! \nUS_Atty_Cor_00352 \nEFTA00235678\n", "char_count": 1214}, {"efta_number": "EFTA00235326", "page_number": 353, "text_content": "N.\nK. \nCERTIFICATION OF BUSINESS RECORDS \nI, the undersigned, \n, declare that I am: \nemployed by/associated with \n in the \nposition of \nand by reason of my \nposition am authorized and qualified to make this declaration. \nIn my employment with the above-named bank/company I am familiar with the \nbusiness records it maintains. The above-named bank/company maintains records of its \nbusiness which are: \n1. made at or near the time of the occurrence of the matters set forth therein, by, \nor from Information transmitted by. a person with knowledge of those matters; \n2. kept in the course of regularly conducted business activity; and \n3. made by the regularly conducted activity as a regular practice. \nAmong the records so maintained are the attached records itemized in Appendix A, \nInventory of Documents. \nI declare under penalty of perjury that the foregoing is true and correct. \nDate of execution:  \n• Place of execution: \nSignature: \nUS_Atty_Cor_00353 \nEFTA00235679\n", "char_count": 975}, {"efta_number": "EFTA00235326", "page_number": 354, "text_content": "APPENDIX A \nDOCUMENT INVENTORY \nThe documents submitted are as follows: \nSignature of Records Custodian: \nOBB09; \nUS_Atty_Cor_00354 \nEFTA00235680\n", "char_count": 146}, {"efta_number": "EFTA00235326", "page_number": 355, "text_content": "mmr•m•\nz. \nUnited States District Court \nSOUTHERN DISTRICT OF FLORIDA \n(;) \nTO: Custodian of Records \nJEGE, Inc. \nSUBPOENA TO TESTIFY \nBEFORE GRAND JURY \nFel 07-103(WPB)-Tues./No. OLY-47 \nSUBPOENA FOR: \nO \nPERSON E DOCUMENTS OR OBJECT[S] \nYOUARE HEREBY COMMANDED to appear andtestifybefore theGrand Jury of theUnited States District \nCourt at the place, date and time specified below. \nFLACK: \nUnited States District Courthouse \n701 Clematis Street \nWest Palm Beach, Florida 33401 \nROOM \n• \nGrand Jury Roan \nDATE AND TIME: \nMay 8, 2007 \n1:00 pm* \nYOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s): \nAll income tax return, balance sheets, regulatory filings, minutes of board of directors meetings, and \ndocuments required by or filed with the Internal Revenue Service and/or the State of Delaware \nreferring or rotating to the period of 1/1/2003 to 12/31/2005. \nFor the period 1/1/2003 to the present, the names of all employees, copies of all W-2s for all employees, \nand the names of all corporate directors, board members, and shareholders. \n*Please coordinate your compliance wit \nc ulymena and confirm the date and time, and location of \nyour appearance with Special Agent\n(561) 8224946. \nFederal Bureau of Investigation, Telephone: \nThis subpoena shall ranain in effect until you are granted leave to depart by the taint or by an °Mom acting \non behalf of the court. \n• \n(BY)DEPLITYCIIPX \nThis subpoena is issued upon application \nof the United States of Anarloa \nOa_ \nNe \nand Three Nambet of Assistant 118. Attorney \nAnn \nC. Metal% Agenda U.S. Attorney \n500 or. \nWisp Avenae, State 400 \nWed Palm Brach, PI. 33401-6235 \nTd: (561) 820-8711 x3047 \nFar (561) 802-1717 \ntemlamM*le,mt\"nme \nTolawnillnionOM \nRAMORD427 \nMX16 \nOEM \nUS_Atty_Cor_00355 \nEFTA00235681\n", "char_count": 1792}, {"efta_number": "EFTA00235326", "page_number": 356, "text_content": "• • \nl• \nU.S. Department of Justice \nih Tiled States Attorney \nSouthern District of Florida \nSOO S Australia Ave,. State 400 \nWan Pals Bead FL 334014235 \nO41)8204M \nAPPEARANCE NOTICE \nThe attached subpoena requires the production of the records specified to a Federal \nGrand Juryarial in the Southern District of Florida. \nA new provision of the Federal Rules of Evidence provides that routine business \nrecords may be admitted at trial through thadeclaration of a custodian, if they are provided \nsufficiently In advance of trial to allow an opportunity for any challenges to their \nauthenticity. Therefore, you may be able to avoid appearing personally at the grand \njury/trial at the time and place specified by completely filling out the attached Ce \n111.\nand immediately returning it with the records to Special Agent\n, FBI at the following address: \nFederal Bureau of Investigation \n505 South Nagler Drive, Ste. 500 \nWest Palm Beach, Florida 33401-5923 \n&Nilo, VOLUNTARY TURNOVER \nPlease note that we are requesting an early voluntary turnover of the materials \nsubpoenaed. The early voluntary turnover date is prior to May 8. 2007. \nBY.\nSincerely. \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nUS_Atty_Cor_00356 \n06611 \nEFTA00235682\n", "char_count": 1240}, {"efta_number": "EFTA00235326", "page_number": 357, "text_content": "• \n•t \nCERTIFICATION OF BUSINESS RECORDS \nI, the undersigned, \n, declare that I am: \nemployed bylassoclated with \nIn the \nposition of \nand by reason of my \nposition am authorized and quailed to make this declaration. \nIn my employment with the above-named bank/company I am familiar with the \nbusiness records it maintains. The above-named bank/company maintains records of its \nbusiness which are: \n1. made at or near the time of the occurrence of the matters set forth therein, by, \nor from information transmitted by, a person with knowledge of those matters; \n2. kept in the course of regularly conducted business activity; and \n3. made by the regularly conducted activity as a regular practice. \nAmong the records so maintained are the attached records itemized in Appendix A, \nInventory of Documents. \nI declare under penalty of perjury that the foregoing is true and correct \nDate of execution: \nPlace of execution: \nSignature: \nOGGI2 \nUS_Atty_Cor_00357 \nEFTA00235683\n", "char_count": 975}, {"efta_number": "EFTA00235326", "page_number": 358, "text_content": "• \n1/4\n•••••=0 \naleS \nAPPENDIX A \nDOCUMENT INVENTORY \nThe documents submitted are as follows: \nSignature of Records Custodian: \n06613 \nUS_Atty_Cor_00358 \nEFTA00235684\n", "char_count": 167}, {"efta_number": "EFTA00235326", "page_number": 359, "text_content": "\"VI!latrine, Ann \nMarie C. \nWSAFIS \\)\" \nelantatedol.go \nv> \n09/26/2007 11:01 \nAM \nTo \ncc \nbcc \nSubject RE: Other attorneys \n\"Jay Lefkowrte CLeficowitz@kirktand.corn> \nHi Jay — Can you give me a call at 561209-1021 this morning? I \nam meeting with the agents and want to give them their marching \norders regarding what they can tell the girls. \nAlso, please remove Babbitt and Searcy from the list There is too \ngreat a chance of an appearance of impropriety with Babbitt and I \nreceived a bad report about Searcy last night. \nThank you. \nA. Marie Villafana \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \nUS_Atty_Cor_ 00359 \nEFTA00235685\n", "char_count": 715}]}