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Evaluation Only. Created with Aspose.Words. Copyright 2003-2010 Aspose Pty Ltd. 
People I Epstein 
2011 NY Slip Op 08293 
Decided on November 17, 2011 
Appellate Division, First Department 
Published by New York State Law Reporting Bureau pursuant to 
Judiciary Law § 431. 
This opinion is uncorrected and subject to revision before publication 
in the Official Reports. 
Decided on November 17, 2011 
Manarelli, J.P., Sweeny, Moskowitz, = 
Abdus-Salaam, JJ. 
6081 30129/10 
(*Wile People of the State of New York, Respondent, 
I
 
Jeffrey E. Epstein, Defendant-Appellant. 
Kirkland & Ellis LLP, New York (Jay P. Lefkowitz of 
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counsel), for appellant. 
Cyrus R. Vance, Jr., District Attorney, New York (Deborah L. 
Morse of counsel), for respondent. 
Order, Supreme Court, New York County (Ruth Pickholz, J.), entered on or about 
January 18, 2011, which adjudicated defendant a level three sex offender pursuant to the 
Sex Offender Registration Act (Correction Law art 6-C), unanimously affirmed, without 
costs. 
Clear and convincing evidence, including reliable hearsay (see People' Mingo, 12 NY3d 
563, 571 [2009]) supported the assessment of points for risk factors sufficient for a level 
three sex offender adjudication (Correction Law § 168-n[3]). In the circumstances of this 
case, the court properly relied on highly reliable proof of criminal conduct for which 
defendant was neither indicted nor convicted. 
The sex offender adjudication arises out of defendant's sex offenses in Florida. The 
evidence before the SORA hearing court established that defendant committed multiple 
offenses against a series of underage girls. The girls were brought to defendant's home to 
provide "massages" that led to very serious sex crimes. 
These facts were established by reliable hearsay, including the probable cause affidavit 
prepared by Florida law enforcement authorities after their investigation, and the Board 
of Examiners of Sex Offenders' case summary (see Mingo, 12 NY3d at 572-573, 577). 
The probable cause affidavit was extremely detailed. It set forth the sworn, tape-recorded 
statements of the victims. The victims' detailed accounts of defendant's crimes 
corroborated each other, and were also corroborated by other evidence, including 
declarations against penal interest made by defendants accomplice. 
In 2006, the Florida prosecutor obtained an indictment charging defendant with 
solicitation of prostitution. In 2008, the Florida prosecutor filed an information, this time 
charging procuring a person under 18 for prostitution. A few days after the information, 
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defendant pleaded guilty to both accusatory instruments. Both instruments involved the 
same victim, who was only one of defendant's many victims. 
The Board and the hearing court are not limited to the underlying crime in determining an 
offender's risk level (see People' Johnson. 77 AD3d 548, 549-550 [2010], lv denied 16 
NY3d 705 [2011]). "[T]he fact that an offender was not indicted for an offense may be 
strong evidence that the offense did not occur" (Sex Offender Registration Act: Risk 
Assessment Guidelines and Commentary, General Principles 117, at 5 [2006]). However, 
here the strong evidence that the [k2]offenses against the other victims did occur 
outweighs any inferences to be drawn from the manner in which this case was prosecuted 
in Florida. 
The reasons for the actions taken by the Florida authorities remain unclear on this record. 
The record before us is insufficient to establish that those authorities reasonably believed 
the charges involving the other victims were unprovable. The record permits competing 
inferences. In any event, the hearing court was entitled to rely on the reliably proven facts 
themselves, and was not necessarily bound by any exercises of prosecutorial discretion. 
We reject defendant's argument that the People should be estopped from taking a 
different position on appeal from the position they took before the hearing court. At the 
hearing, the People mistakenly conceded that the conduct for which defendant was not 
indicted should not be considered, and that defendant should be adjudicated a level one 
offender. These were legal arguments that the court rejected, and it is the court's 
determination that we review on this appeal. Furthermore, when the court announced that 
it was rejecting the People's position and would consider the offenses against additional 
victims, defendant did not request any opportunity to challenge the reliability of the 
additional charges. Accordingly, defendant was not deprived of a fair opportunity to 
litigate the issue (see e.g. People' Strong, 276 AD2d 271 [2000], lv denied 96 NY2d 807 
[2001]). 
Defendant's remaining claims are improperly raised for the first time on appeal (see 
People' Windham, 10 NY3d 801 [2008]), and are unavailing in any event. 
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THIS CONSTITUTES THE DECISION AND ORDER 
OF THE SUPREME COURT, APPELLATE DIVISION, FIRST DEPARTMENT. 
ENTERED: NOVEMBER 17, 2011 
CLERK 
MACROBUTTON DoFicldClick [Return to Decision List] 
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U.S. Department of Justice 
Criminal Division 
Andrew G. Oosterbaan, Chief 
Child Exploitation ad (Amery Section 
Jay Lefkowitz, Esq. 
Kirkland & Ellis LLP 
Citigroup Center 
153 E. 53n0 St. 
New York, NY 10022-4611 
Re: 
Investigation of-Jeffery Epstein 
Dear Mr. Lefkowitz: 
1400 New York Avenue. NW 
Suite 600 
Washimron, DC 10330 
May 15, 2008 
Pursuant to your request and the request of U.S. Attorney 
, we have 
independently evaluated certain issues raised in the investigation of Jeffrey Epstein to determine 
whether a decision to prosecute Mr. Epstein for federal criminal violations would contradict 
criminal enforcement policy interests. As part of our evaluation, we have reviewed letters 
written on behalf of Mr. Epstein on Febniary 1, 2007, June 25, 2007, July 6, 2007, March 28, 
2008, April 8, 2008, April 28, 2008, and May 14, 2008, with their attachments. We have also 
reviewed memos prepared by the U.S. Attorney's Office. As you will recall, we met with you 
and other representatives of Mr. Epstein to further discuss your views on the propriety of a 
federal prosecution. We have discussed the factual and legal issues you raise with the Criminal 
Division's Appellate Section, and we consulted with the Office of Enforcement Operations 
concerning the petite policy. 
We are examining the narrow question as to whether there is a legitimate basis for the 
U.S. Attorney's Office to proceed with a federal prosecution of Mr. Epstein. Ultimately, the 
prosecutorial decision making authority within a U.S. Attorney's Office lies with the U.S. 
Attorney. Therefore, to borrow
 from the case law, the question we sought to answer 
was whether U.S. Attorney 
would abuse his discretion if he authorized prosecution in this 
case. 
As you know, our review of this case is limited, both factually and legally. We have not 
looked at the entire universe of facts in this case. It is not the role of the Criminal Division to re-
conduct a complete factual inquiry from scratch. Furthermore, we did not analyze any issues 
concerning prosecution under federal statutes that do not pertain to child exploitation, such as the 
money laundering statutes. 
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As was made clear at the outset, we did not review the facts, circumstances, or terms 
included in the plea offer, nor any allegations that individuals involved in the investigation 
engaged in misconduct. Despite that agreement, we note that your letters of April 8, April 28, 
and May 14 focus in large part on accusations of investigative or prosecutorial misconduct. Not 
only do allegations of prosecutorial misconduct fall outside the boundary of our agreed review, 
they also fall outside the authority of the Criminal Division in the first instance. Simply, the 
Criminal Division does not investigate or resolve allegations of professional misconduct by 
federal prosecutors. For these reasons, we do not respond to the portion of those letters that 
discuss alleged misconduct. 
Based on our review of all of these materials, and.after careful consideration of the issues, 
we conclude that U.S. Attorney 
could properly use his discretion to authorize prosecution 
in this case. We will briefly address each of the issues that you have raised. 
Knowledge of age. Federal child exploitation statutes differ as to whether there must be 
proof that the defendant was aware that the children were under the age of 18. However, even 
for those statutes where knowledge of age is an element of the offense, it is possible to satisfy 
that element with proof that the defendant was deliberately ignorant of facts which would suggest 
that the person was a minor. For that reason, the fact that some of the individuals allegedly lied 
to Mr. Epstein about their age is not dispositivc of the issue. While there may be an open factual 
issue as to Mr. Epstein's knowledge, we cannot say that it would be impossible to prove 
knowledge of age for any such charges which require it. Therefore, Mr. 
could rightfully 
conclude that this factual issue is best resolved by a jury. 
Travel for the purpose. In the materials you prepared, you suggest that Mr. Epstein 
should not be charged with violating 18 U.S.C. § 2423(b) because his dominant purpose in going 
to Florida was not to engage in illegal sexual activity, but rather to return to one of his residences. 
While we fully understand your argument, we also find that the U.S. Attorney's office has a good 
faith basis fully to develop the facts on this issue and brief the law to permit a court to decide 
whether the law properly reaches such conduct. Mr. 
would not be abusing his discretion 
if he decided to pursue such a course of action. 
Intent to engage in the conduct at the time of travel. Based on our review of the facts of 
this case, we respectfully disagree that there is no evidence concerning Mr. Epstein's intent when 
he traveled, and when that intent was formed. Should Mr. 
elect to let the case proceed so 
that a jury can resolve this factual issue, he would be within his discretion to do so. 
• 
Use of a facility or means of interstate or foreign commerce. Much of the materials you 
have prepared and much of the meeting we had focused on 18 U.S.C. § 2422(b), specifically your 
contention that Mr. Epstein did not use the phone to coerce anyone to engage in illegal sexual 
activity. We understand the issue you raise concerning the statutory interpretation. As before, 
however, we cannot agree that there is no evidence that would support a charge under Section 
2422(b), nor can we agree that there is no argument in support of the application of that statute to 
this case. Finally, our assessment is that the application of that statute to these facts would not be 
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so novel as to implicate the so-called "dear statement rule," the Ex Post Facto clause, or the Due 
Process clause. As with the other legal issues, Mr. =may 
elect to proceed with the case. 
Absence of coercion. With respect to 18 U.S.C. § 1591, the alleged absence of the use of 
force, fraud, or coercion is of no moment. The statute does not require the use of force, fraud, 
and coercion against minors. Because of their age, a degree of coercion is presumed. In your 
materials, you note that the statute requires that the minors must be "caused" to engage in a 
commercial sex act, further arguing that the word "cause" suggests that a certain amount of 
undue influence was used. We reject that interpretation, as it would read back into the offense an 
element—coercion—that Congress has expressly excluded. We have successfully prosecuted 
defendants for the commercial sexual exploitation of minors, even when the minors testified that 
not only did the voluntarily engage in the commercial sex acts, it was their idea to do so. As 
such, Mr. 
could properly decide to pursue charges under Section 1591 even if there is no 
evidence of coercion. 
More broadly, a defendant's criminal liability does not hinge on his victim identifying as 
having suffered at his hands. Therefore, a prosecution could proceed, should Mr. =decide 
to do so, even though some of the young women allegedly have said that they do not view 
themselves as victims. 
Witness credibility. As all prosecutors know, there are no perfect witnesses. Particularly 
in cases involving exploited children, as one member of your defense team, Ms. Thacker, surely 
knows from her work at CEOS, it is not uncommon for victim-witnesses to give conflicting 
statements. The prosecutors are in the best position to assess the witness's credibility. Often, the 
prosecutor may decide that the best approach is to present the witness, let defense counsel 
ex lore the credibility problems on cross-examination, and let the jury resolve the issue. Mr. 
would be within his authority to select that approach, especially when here there are 
multiple, mutually-corroborating witnesses. 
Contradictions and omissions in the search warrant application. We have carefully 
reviewed the factual issues you raise concerning the search warrant application. For a search 
warrant to be suppressed, however, the factual errors must be material, and the officers must not 
have proceeded in good faith. Despite the numerous factual errors you describe, the U.S. 
Attorney's Office could still plausibly argue that the mistakes—whether inadvertent or 
intentional—were not material to the determination that probable cause existed for a search, and 
that the search was in good faith in any event. As such, Mr. 
could properly elect to 
defend the search warrant in court rather than forego prosecution. 
Petite Policy: After reviewing the petite policy and consulting with the Office of 
Enforcement Operations ("CEO"), we conclude that the petite policy does not prohibit federal 
prosecution in this case. According to the U.S. Attorney's Manual, the petite policy "applies 
whenever there has been a prior state or federal prosecution resulting in an acquittal, a 
conviction, including one resulting from a plea agreement, or a dismissal or other termination of 
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• 
• 
• 
the case on the merits after jeopardy has attached." USAM 9-2.03I(C). Our understanding is 
that the state case is still pending. As such, the procedural posture of the state case does not 
implicate the petite policy. 
We recognize that the petite policy could be triggered if the state case concluded after a 
federal indictment was issued but prior to the commencement of any federal trial. Id. However, 
the policy "does not apply ... where the [state] prosecution involved only a minor part of the 
contemplated federal charges." USAM 9-2.031(B). Based on our understanding of the possible 
federal charges and existing state charges, we do not think the petite policy would be an issue 
should federal proceedings take place. 
Federalism and Prosecutorial Discretion. All of the above issues essentially ask whether 
a federal prosecution can proceed. We understand, however, that you also ask whether a federal 
prosecution should proceed, even in the event that all of the elements of a federal offense could 
be proven. On this issue, you raised two arguments: that the conduct at issue here is traditionally 
a state concern because the activity is entirely local, and that the typical prosecution under federal 
child exploitation statutes have different facts than the ones implicated here. You have 
essentially asked us to look into whether a prosecution would so violate federal prosecutorial 
policy that a United States Attorney's Office should not pursue a prosecution. We do not think 
that is the case here for the following reasons. 
Simply, the commercial sexual exploitation of children is a federal concern, even when 
the conduct is local, and regardless of whether the defendant provided the child (the "pimp") or 
paid for the child (the "john"). In your materials, you refer to a letter sent by the Department of 
Justice to Congress in which the Department expresses concern over the expansion of federal 
laws to reach almost all instances of prostitution. In that portion of the letter, the Department 
was expressly referring to a proposed federal law that reach adult prostitution where no force, 
fraud, or coercion was used. Indeed, the point being made in that letter is that the Department's 
efforts are properly focused on the commercial sexual exploitation of children and the 
exploitation of adults through the use of force, fraud, or coercion. As such, there is no 
inconsistency between the position taken in that letter and the federal prosecution of wholly local 
instances of the commercial sexual exploitation of children. 
If Congress wanted to limit the reach of federal statutes only to those who profit from the 
commercial sexual exploitation of children, or only to those who actually traffic children across 
state lines, it could have done so. It did not. Finally, that a prosecution of Mr. Epstein might not 
look precisely like the cases that came before it is not dispositive. We can say with confidence 
that this case is consistent in principle with other federal prosecutions nationwide. As such, Mr. 
can soundly exercise his authority to decide to pursue a prosecution even though it might 
involve a novel application of a federal statute. 
Conclusion. After carefully considering all the factual and legal issues raised, as well as 
the arguments concerning the general propriety of a federal case against Mr. Epstein on these 
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w 
facts, we conclude that federal prosecution in this case would not be improper or inappropriate. 
While you raise many compelling arguments, we do not see anything that says to us categorically 
that a federal case should not be brought. Mr. 
would not be abusing his prosecutorial 
discretion should he authorize federal prosecution of Mr. E 
cc: 
AAG Alice S. Fisher 
DAAG Sigal P. Mandelker 
U.S. Attorney 
Si 
5 
Oosterbaan 
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(USAFLS) 
From: 
(USAFLS) 
Sent: 
ednesday. March 19. 2008 6:18 PM 
To: 
Cc: 
. E N., Twiter Smith 
Subjaet: 
epresen a ion of vieurns in Florida 
CONFIDENTIAL 
I li Jason and Pauline - My info is showin below. I lw Justice I h:partment V ictim Advocate assigned to 11w case 
is 'hviler Smith. She is located at the FBI office here in West Palm Beach. Ilte numbcr there is 
is the case agent assigned to the case. She can answer any questions !hat you have. fler 
direct diat is 
I will be out of the office tomorrow. so if you necd anything you can sive 
a 
call. 
By this e-mail, I will ask Twi ler and 
to put together a letter to the victims infoaning them of the 
availability of pro bont) legal representation with your name and telephone nutuber. I understand dun >mi and 
your colleagues in Maryland are still working out logistics. so we will svait to send out until we know what 
name and contact infomlation should be ineluded. 
the one urgent case is that of victi 
She has been subpocnaed to appear for a deposition on 
Monday in West reim I3each. I have given 
the contact information for Pauline Mandel. and I know 
Olm Vanessa was going to cal) her today. (I just snoke with Pauline and she has everything under controll. 
For conllicis purposes. here are the relevant namn and finns: 
The targets' narres are Jeffrey Epstein. 
the attomeys involved in the case so far are: Guy Fronstin (West Palm Beach). Jack Goldberger of Atterbury 
Goldberger and Weiss (West Palm Beach). Ros Black or Black Srebnlck Kornspan & Stumpf (Miami). Guy 
Lewis and Michael Tein of Lewis & lein (Miami), Ken Star and Jay Lelkowitz of Kirkland & Ellis (New York 
and L.A.), Alan Dershowitz from Harvard. Gerald lefeoun (New York). Bruce Lyons (Et Lauderdale). Lilly 
Ann Sanchez of Fowler White & Bunten (Miami), Jim hisenberg (West Palm I3each). Michael Dalko of 
Bogenschutz & Dunku (Fon Lauderdale). Roben Targ of Diaz Reus RollT& Targ (Miami). Nathun Dershowitz 
of Dershowitz. Elger & Adelson (New York). Dennis Block of Cadwalader. Wiekershain & Taft LIP (New 
York). William Richey (Miami ond Palm City, FL). and Stephanie Thacker (West Virginia). 
If a Orm name isn't listed, then they are sole praclitioners. 
Here isa brief summary of the case: 
the investigation initially was undertaken by the City of Palm Beach Police Department in response id 
a complaint reccived from the parents of a I4-year-old girl,. from Ro al Palm Beach. When. 
and another girl hegan fighting at school because the other
 alet:used. of being a prostitute. one of 
the school principals intervened. Bie principal searched := 
purse and found $300 cash. The 
principal asked p 
where the money came from. 
initially claimed that she carned the money 
working at "Cluk-Fil-A." which no one helieved. 
then claimed that she made the money selt ing 
I 
drugs: no une believed that either. E !fnatt> admitted that she hud been paid $300 to givs a massage 
to a man on Palm Beach istand. 
parents approached the Palm Beach Police Department 
("PBPD") about pressing charges. 
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PBPD began investigating the  recipient of the massage. Jeffrey Epstein. and two of his assistants. 
 
PBPD identified 27 girls who went to Epstein's house to perform 
"massage services" (not including one licensed massage therapist). The girls' ages ranged from 14 
years' old to 23 years' old. Some girls saw Epstein only once and some saw him dozens of times. 'Ile 
"massage services" performed also varied. Some girls were fully clothed while they massaged Epstein: 
some wore only their underwear; and some were fully nude. During all of these massages. Epstein 
masturbated himselfand he would touch the girl performing the massage. usually fondling their breasts 
and touching their vaginas - either over their clothing or on their bare skin. Epstein often used a 
vibrator to masturbate the girls and digitally penetrated a number of them. For the girls who saw him 
more often. Epstein graduated to oral sex and vaginal sex. Epstein sometimes brought his 
assistant/girlfriend. 
into the sexual activity. One of the girls described 
as Epstein's "sex slave". 
On October 18, 2005, PBPD obtained a search warrant with the assistance of the Palm Beach County 
State Attorney's Office (-PBSAO"). By this time, PBSAO had already been contacted by Epstein's 
cadre of lawyers. When P1313O arrived at Epstein's home Iwo days later (10/20/05) to execute the 
search warrant, they found several items conspicuously missing. For example. computer monitors and 
keyboards were found, but the CPUs were gone. Similarly, surveillance cameras were found, but they 
were disconnected and the videotapes were gone. Nonetheless. the search did recover some evidence 
of value. including message pads showing messages from many girls over a two year span. The 
messages show girls returning phone calls to confirm appointments to -work." Messages were taken 
by 
The search also recovered numerous 
photos of Epstein sitting w ith naked girls whose ages are undetermined. Iwo other assistants. 
have also been implicated. 
Photographs taken inside the home show that the girls' descriptions of the layout of the home and 
master bedroom/bathroom area are accurate. PBPD also found massage tables and oils, the high school 
transcript of one of the girls, and sex toys. 
The investigation showed that girls from local high schools would be contacted by one of Epstein's 
assistants to make an appointment to - work." Up to three appointments each day would be made. the 
girls would travel to Epstein's home in Palm Beach where they would meet Epstein's chef and 
Epstein's assistant usually 
in the kitchen. The assistant would escort the girls upstairs to the 
master bedroom/bathroom urea and set up the massage table and massage oils. The girl sometimes was 
instructed to remove her clothing. 'file assistant would leave and Epstein would enter the room 
wearing a robe. Ile would remove the robe and lie lace down and nude on the massage table. Epstein 
would then instruct the girl on what to do and would ask her to remove her clothing. Atter some time. 
Epstein would turn over, so that he was lying lace up. Epstein would masturbate himself and fondle 
the girl performing the massage. When Epstein climaxed, the massage was over, and the girl was 
instructed to get dressed and to go downstairs to the kitchen while Epstein showered. Epstein's 
assistant would be in the kitchen and the girl would be paid- usually $200—and if it was a "new" girl. 
the assistant would ask for the girl's phone number to contact her in the future. Girls were encouraged 
to find other girls to bring with them. If it girl brought another girl to perform a -massage." each girl 
would receive 3200. 
More detailed facts appear in the state's probable cause affidavit, which can be found online at 
w.thesmokineautheorn 
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U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
August t 1, 2006 
DELIVERY BY HAND 
Miss 
Re: 
Crime Victims' and Witnesses' Right 
Dear Miss 
500 South Australian Are.. Suite 400 
West Palm Beach. FL 31401 
Pursuant to the Justice for All Act of 2004, as a victim anti/or witness o f a federal offense, 
you have a number of rights. Those rights arc: 
(4) 
( 5) 
(6) 
(7) 
(8) 
The right to be reasonably protected from the accused. 
The right to. reasonable, accurate, and timely notice of any public court proceeding 
involving the crime or of any release or escape of the accused. 
The right not to be excluded from any public court proceeding, unless the court 
determines that your testimony may be materially altered if you are present for other 
portions of a proceeding. 
The right to be reasonably heard at any public proceeding in the district court 
involving release, plea, or sentencing. 
The reasonable right to confer with the attorney for the United States in the case. 
The right to full and timely restitution as provided' in law. 
The right to proceedings free from unreasonable delay. 
The right to be treated with fairness and with respect for the victim's dignity and 
privacy. 
(.( 
Members of the U.S. DepartMent of Justice and other federal investigative agencies, 
including the Federal Bureau of Investigation, must use their best effort to make sure that these 
rights are protected. If you have any concerns in this regard, please feel free to contact me at, 
or Special Agent 
from the Federal Bureau of Investigation at 
You also can contact the Justice Department's Office for Victims of Crime in 
Washington, D.C. at 
That Office has a websitc at www.ovc.gov. 
You can seek the advice of an attorney with respect to the rights listed above and, if you 
believe that the rights set forth above are being violated, you have the right to petition the Court for 
relief. 
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MISS-
AUGUST 11.2006 
PAGE 2 
In addition to these rights, you are entitled to counseling and medical services, and or .; 
from intimidation and harassment. If the Court determines that you are a victim, you al.:,
entitled to restitution from the perpetrator. A list of counseling and medical service pro, uk 
be provided to you, if you so desire. If 
family is subjected to any Ultimo, 
• 
harassment, please contact Special Agent 
or ntyself immediately. It is 
; - 
someone working on bchal f of the targets of the investigation may contact you. Such cunt :•.' 
not violate the law. However, if you are contacted, you have the choice of speaking to dim 
or refusing to do so. If ou refuse and feel that you are being threatened or harassed, tiny. r: 
Contact Special Agent 
or myself. 
You also are entitled to notification of upcoming case events. At this lime, your ca••• 
investigation. If anyone is charged in connection with the investigation, you will he nni.: 
Sincerely, 
United States Attorney 
By: 
cc: 
Special Agent 
F.B.I. 
A. 
Assistant United States Attorney 
f 
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(USAFLS) 
From: 
Lilly Ann Sanchez (LAS@FOWLER-WHITE.COMJ 
Sent:
Friday .lanuary M 7007 4:05 PM 
To: 
(USAFLS) 
Cc: 
Gerald Letcourl 
Subject: 
Jeffrey Epstein 
Illt 
hope you had a great holiday season. Gerald Lefcourt and I would like to speak with you early next week on the Epstein 
matter. if you provide me with some convenient dates and times for us to call you, I will coordinate with Gerry and 
confirm same. 
regards 
Lilly Ann Sanchez, Esq, 
FOWLER WHITE BURNETT P.A. 
Espirito Santo Plaza, 14th Floor 
1395 Brickell Avenue 
Miami, Florida 33131.3302 
Telephone: (305) 789-9200 
Direct Dial: (305) 789-9279 
Facsimile: (305) 789.9201 
Isanchez(Ofowler-white.00m 
**TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance 
with requirements imposed by the IRS, we inform you that any tax 
advice contained in this communication (including attachments) was 
not intended or written to be used, and cannot be used, for the 
purpose of (i) avoiding penalties under the Internal Revenue Code 
or (ii) promoting, marketing or recommending to another party any 
transaction or matter addressed herein. If you would like such advice, 
please contact us.*** 
***Attention: The information contained in this E-mail message 
is attorney privileged and confidential information intended only 
for the use of the individual(s) named above. If the reader of this 
message is not the intended recipient, you are hereby notified that any 
dissemination, distribution or copy of this communication is strictly 
prohibited. If you have received this communication in error, please 
contact the sender by reply E-mail and destroy all copies of the original 
message. Thank you. 
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EFTA00184602

Case 9:08-cv-80736-KAM Document 361-43 Entered on FLSD Docket 02/10/2016 Page 1 of 
26 
EXHIBIT 
43 
EFTA00184603