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15 
By signing this agreement, Epstein asserts and certifies that the above has been read 
and explained to him. Epstein hereby states that he understands the conditions of this Non-
Prosecution Agreement and agrees to comply with thorn. 
1.1
1/11.1.114EY 
Dated: 
 
By: 
Dated: 
Dated:  7/9-410 
Dated: 
A. 
VILLAFARA 
ASSISTANT U.S. ATTORNEY 
JEFFREY EPSTEIN 
Page 7 of 7 
LILLY ANN SANCHEZ, ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
RAL 
EEC° 
ESQ. 
OUNSEL TO JEFFR Y EPSTEIN 
EFTA00184724

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• 
15 
By signing this agreement, Epstein mats and certifies that the above has been read 
and explained to hint Epstein hereby states that he understands the conditions of this Non-
Prosecution Agreement and agrees to comply with On 
UNITED STATES ATTORNEY 
Dated: 
Br 
A-
ASSLSTANT U.S. ATTORNEY 
Dated: 
JEFFREY EPSTEIN 
Dated: 
Dated:
09--
GERALD LEFCOURT, ESQ. 
COUNSEL TO JEFFREY EPSTEIN 
ESQ. 
ATTORNEY FOR JEFFREY BPSTETN 
Page 7 of 7 
EFTA00184725

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15 
IN RE: 
INVESTIGATION OF 
JEFFREY EPSTEIN 
ADDENDUM TOTEM NON-PROSECUTION AGREEMENT 
IT APPEARING that the parties seek to clarify certain provisions of page 4, paragraph 7 
of the Non-Prosecution Agreement (hereinafter "paragraph 7"), that agreement Is modified as 
follows: 
7A. 
The (Jolted States has the right to assign to an independent third-party the responsibility 
for consulting with and, subject to the good faith approval of Epstein's counsel, selecting 
the attorney representative for the individuals identified under the Agreement. If the 
United States elects to assign this responsibility to an independent third-party, both the 
United States and Epstein retain the right to make good faith objections to the attorney 
representative suggested by the independent third-party prior to the final designation of 
the attorney representative. 
7D. 
The parties will jointly prepare a short written submission to the Independent third-party 
regarding the role of the attorney representative and regarding Epsteln's Agreement to 
pay such attorney representative his or her regular customary hourly rate for representing 
such victims subject to the provisions of paragraph C, infra. 
7C. 
Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the attorney 
representative selected by the independent third party. This provision, however, shall not 
obligate Epstein to pay the foes and costs of contested litigation filed against him. Thus, 
if after consideration of potential settlements, an attorney representative elects to file a 
contested lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested 
remedy, the paragraph 7 obligation of the Agreement to pay the costs of the attorney 
representative, as opposed to any statutory or other obligations to pay reasonable 
attorneys fees and costs such as those contained in s 2255 to bear the costs of the attorney 
representative, shall cease. 
r 
EFTA00184726

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15 
By signing this Addendum, Epstein asserts and certifies that the above has been read and 
explained to him. Epstein heretry, slates that he understands the clarifications to the Non-
PMSeanthe Agreement and agrees to comply with them. 
R. ALEXANDER...IL 
UNITED STATES ATTORNEY 
Dated: 
Dated. / Ph WI-
Dated: 
Dated: 
By: 
AIM 
VILLAPANA 
ASSISTANT U.S. ATTORNEY 
GERALD LEFCOURT, ESQ. 
COUNSEL TO JEFFREY EPSTEIN 
LILLY ANN SANCIIEZ, ESQ. 
ATTORNEY MR JEFFREY EPSTEIN 
EFTA00184727

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15 
By signing this Addendum, Epstein asserts and certifies that the above has been read and 
explained to him. Epstein hereby states that he understands the clarifications to the Non-
Prosecution Agreement and agrees to comply with them. 
TED STATES A I ItaNLY 
Dated: 
By: 
Dated; 
Dated:ICA? / 07 
Dated: 
A. tipm);ILI.AFARA 
AS 
U.S. ATTORNEY 
JEFFREY EPSTEIN 
RALD LEFCO 
ESQ. 
COUNSEL TO JEFF 
Y EPSTEIN 
LILLY ANN SANCHEZ. ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
EFTA00184728

Case 9:08-cv-80736-KAM Document 361-62 Entered on FLSD Docket 02/10/2016 Page 14 of 
15 
By signing thle Addendum, Epstein mesas and certifies that the above has boon read and 
explained to him. Epstein hereby states that he understands the clarifications to the Nona 
Prosecution Agreement and agrees to comply with than. 
UNITED STATES ATTORNEY 
Dated: 
 
By: 
Dated: 
Dated: 
Dated: ii(Y_Slin -•
A. MIFYILLAFAIIA 
ASSISTANT U.S. ATTORNEY 
JEFFREY EPSTEIN 
GERALD LEFCOURT, ESQ. 
COUNSEL TO JEFFREY EPSTEIN 
LILLY A 
MOM, ES 
ATTORNEY FOR JEFFREY EPSTEIN 
EFTA00184729

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Dec-OT-OT 
01:66pe 
From-fowler -White 06rnett 
Aar.* tem 
3061/00201 
T-286 
P.003/024 
F-O71 
Joey& Epstein do hereby roar= 
the NaProsteraisui Agrcana it and Addendum w 
sem dared October 30, 2007, 
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EXHIBIT 
63 
EFTA00184731

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Page 1 
THE UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 08-80736-CIV-MARRA 
IN RE: JANE DOE, 
Plaintiff, 
vs. 
UNITED STATES OF AMERICA, 
Defendant. 
Federal Courthouse 
West Palm Beach, Florida 
July 11, 2008 
10:15 a.m. 
The above entitled matter came on for 
Emergency Petitioner for Enforcement of Crime Victim 
Rights before the Honorable Kenneth A. Marra, 
pursuant to Notice, taken before Victoria Aiello, 
Court Reporter, pages 1-32. 
For the Plaintiff: Bradley Edwards, Esquire 
For the Defendant: Dexter Lee, AUSA 
, AUSA 
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1 
(Call to Order of the Court). 
2 
THE COURT: Good morning. Please be seated. 
3 
This is the case of In Re: Jane Doe, Case 
4 
Number 08-80736-Civ-Marra. May I have counsel state 
5 
their appearances, please? 
6 
MR. LEE: Good morning, Your Honor. May it 
7 
please the Court, for the United States of America, 
8 
we have 
, Assistant United States 
9 
Attorney and Dexter Lee, Assistant United States 
10 
Attorney. And we have seated in the front row FBI 
11 
Special Agent Becker Kendall and Jason 
12 
Thank you, Your Honor. 
13 
MR. EDWARDS: Good morning, Your Honor. Brad 
14 
Edwards on behalf of the petitioners. Petitioners 
15 
16 
17 
18 
19 
20 
21 
the victim's reply, which was filed, I guess, this 
22 
morning. So, You want to proceed, counsel?. 
23 
MR. EDWARDS: Yes, Your Honor. You prefer me 
24 
at the podium? 
25 
THE COURT: It is easier for us to hear you. 
are also in the courtroom today. This petition is 
styled on her behalf. 
THE COURT: Good morning. All right. We're 
here on the petitioner's motion to enforce her 
rights as a victim under 18 USC 3771. I have 
received the petition, the government's response and 
I 
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Page 3 
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MR. EDWARDS: Your Honor, as a factual 
2 
background, Mr. Epstein is a billionaire that 
3 
sexually abused and molested dozens and dozens of 
4 
girls between the ages of 13 and 17 years old. And 
5 
through cooperating victims, that evidence can be 
6 
proven. Because of his deviant appetite for young 
7 
girls, combined with his extraordinary wealth and 
8 
power, he may just be the most dangerous sexual 
9 
predator in U.S. history. This petitioner is one of 
10 
the victims and she is in attendance today. Another 
11 
one of Mr. Epstein's victims is also in attendance 
12 
today. She would be able to provide evidence that 
13 
she provided-- that Mr. Epstein paid her to provide 
14 
him over 50 girls for the purposes of him to 
15 
sexually abuse. Therefore, the undercurrents of the 
16 
petition are clear. The plea bargain that was 
17 
worked out for Mr. Epstein in light of the offenses 
18 
that he committed is clearly unfair to the point 
19 
that if anybody looks at the information, it is 
20 
unconscionable. 
21 
THE COURT: Well, I mean, is that for me? 
22 
That's not my role. That's the prosecutor's role to 
23 
apply, would it not? I can't force them to bring 
24 
criminal charges. What do I have to do with that. 
25 
MR. EDWARDS: Okay. 
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1 
THE COURT: That may be your opinion, that 
2 
may be your client's opinion, but I presume that the 
3 
government is aware that that's your client's 
4 
opinion. How does that change anything? 
5 
MR. EDWARDS: That's my problem. I'm not 
6 
sure that the government is aware that is 
7 
petitioner's opinion and that's why we're here 
8 
today, just to enforce the victim's rights under 18 
9 
USC 3771, Crime Victims Rights Act, and all we are 
10 
asking is to order that the plea agreement that has 
11 
been negotiated in this case--
12 
THE COURT: How do you know there is a plea 
13 
agreement? The plea agreement is with the State of 
14 
Florida, wasn't it? 
15 
MR. EDWARDS: There was a state charge with 
16 
one victim that I'm aware of. And the plea 
17 
agreement as to that one victim was 18 months in the 
18 
county jail. But along with that, the Palm Beach 
19 
County Sheriff investigating this case was getting 
20 
no action out of the local authorities and sent this 
21 
to the FBI. 
22 
THE COURT: It was actually the Palm Beach--
23 
Town of Palm Beach Police, not the Sheriff's Office. 
24 
MR. EDWARDS: I'm sorry, Judge. And that's 
25 
why the FBI got involved because Michael Feeter 
I 
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1 
wrote a scathing letter to the State Attorney about 
2 
Mr. Epstein receiving preferencial treatment by 
3 
local authorities. 
4 
Before the FBI took the case, they went 
5 
behind the victim's back, and this is our motion, 
6 
without the victim's input and allowing her the 
7 
right to meaningfully confer with the government, 
8 
which is a right that she can assert at this time. 
9 
They worked out a plea deal where if Mr. Epstein 
10 
would plead to this other charge regarding another 
11 
victim in the state court case, they would agree to 
12 
not prosecute him for all of the federal charges of 
13 
what they were aware of in federal court.. 
14 
THE COURT: So that's already apparently 
15 
taken place, correct? 
16 
MR. EDWARDS: I don't know if it has taken 
17 
place. I'm not sure exactly what stage it is in. I 
18 
know it is supposed to be attached at some point in 
19 
time to a state court plea. 
20 
THE COURT: Hasn't he already plead guilty, 
21 
though? 
22 
MR. EDWARDS: If he did plead guilty, it is 
23 
my understanding and belief that the agreement with 
24 
the federal government and with the U.S. Attorney's 
25 
Office wasn't signed on that day. So it is still my 
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Page 6 
1 
belief, I could be wrong, but that that agreement 
2 
hasn't been completed as of this time. 
3 
THE COURT: So let's assume it hasn't been 
4 
completed. 
5 
MR. EDWARDS: Okay. Then petitioner would 
6 
like the right to confer with--
7 
THE COURT: You can go in the conference 
8 
room. We've got the FBI agents, you've got the 
9 
assigned prosecuting attorney. You have got a 
10 
conference room. You've got your client. Go and 
11 
talk. Confer. And then it is up government to 
12 
decide what to do, correct? 
13 
MR. EDWARDS: In a way, Your Honor, that's 
14 
very similar to what happened in In Re: Dean and PB 
15 
case where there is a plea agreement negotiated and 
16 
then the victim gets the right to confer. 
17 
THE COURT: It's already negotiated. What 
18 
am I supposed to do? 
19 
MR. EDWARDS: Order that the agreement that 
20 
was negotiated is invalid and it is illegal as it 
21 
did not pertain to the rights of the victim. 
22 
THE COURT: I can order you into the 
23 
conference room. Then the government can do what it 
24 
chooses. It can agree to prosecute or it can agree 
25 
to going forward with the agreement it had already 
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1 
reached and after consulting your client and in 
2 
taking into consideration your client's views, 
3 
decide to go forward anyway. I can't make them 
4 
prosecute him. I can't-- All I can do is, at best, 
5 
say confer with the victim, consider the victim's 
6 
input before you make a decision or reconsider the 
7 
decision you already made in view of the victim's 
8 
input, if it is possible for you to do that. So if 
9 
I invalidate the agreement, what's the best you can 
10 
get? The right to confer? 
11 
MR. EDWARDS: Exactly. That is all we can. 
12 
THE COURT: So why can't you go into the 
13 
conference room now, take as much time as you feel 
14 
you need and confer? 
15 
MR. EDWARDS: Judge, at this time I'd like to 
16 
move ore tenus to add the victim that's in the 
17 
courtroom to this conference with the U.S. 
18 
Attorney's Office. 
19 
THE COURT: So is that Jane Doe 2 for 
20 
purposes of this? 
21 
MR. EDWARDS: Exactly, Your Honor. 
22 
THE COURT: All right. Let me hear from the 
23 
government then. 
24 
MR. LEE:. Good morning, Your Honor. May it 
25 
please the Court. 
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1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Let me update the Court on the status of 
various matters. The agreement to defer prosecution 
to the State of Florida was signed and completed by 
December of 2007. Mr. Epstein's attorneys saught a 
higher review within the Department of Justice and 
it took a number of months for that to come to 
fruition. When it came to fruition, he ended up 
pleading guilty on June 30, 2008 to two charges in 
state court, and he was sentenced to a term of 
incarceration of 18 months, with another 12 months 
of community control after the completion of his 
sentence, and he is currently incarcerated as we 
speak. 
We have two arguments, Your Honor. First, 
insofar as the right that they claim under 
3771(a)(5), their right to confer in the case, we 
respectfully submit that there was no case in 
federal court and, indeed, none was contemplated if 
the plea agreement was to be successfully completed, 
since it contemplated the State 
on the criminal charges. So as 
conditions were met and certain 
of Florida sentence 
long as certain 
federal interests 
were vindicated, the federal government was 
satisfied that this was an appropriate disposition. 
Insofar as the best effort, Your Honor, we 
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1 
have cited the Attorney General's guidelines. The 
2 
guidelines do say that you should normally advise 
3 
victims of plea negotiations and the terms of the 
4 
plea, but they recognize that there are times when 
5 
they may not be appropriate or could cause some harm 
6 
or prejudice, and they set out six factors which are 
7 
to be considered, non-exhaustive factors. 
8 
We have advised, in the declaration of AUSA 
9 
that when the subject of having Mr. 
10 
Epstein concede that he would be convicted of an 
11 
enumerated offense for purposes of a cause of action 
12 
under 18 USC 2255, there was a rather strenuous 
13 
objection from Mr. Epstein's counsel that the 
14 
federal government was inducing some effort to 
15 
either fabricate claims, enhance claims or embellish 
16 
claims and if this agreement ultimately could not be 
17 
consumated, then we'd have a federal prosecution on 
18 
our hands, and we did not want to be in a positin of 
19 
creating additional impeachment material. 
20 
I can't say that the stand by Mr. Edwards 
21 
that the arguments of inducement in a subsequent 
22 
civil action can be made by any criminal victim, 
23 
that is true. It is another thing for that 
24 
inducement to have come before the prosecution 
25 
arguing about the credibility and veracity of the 
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1 
individual. That was a considerably strong point, in 
2 
essence, in not discussing those terms with the 
3 
victims as might ordinarily be done if those 
4 
considerations did not exist. 
S 
So, first, Your Honor, we believe that 
6 
3771(a)(5) does not apply. 
7 
THE COURT: Well, what about the language in 
8 
the statute that suggests that a victim can bring a 
9 
claim or seek enforcement of his or her rights under 
10 
the statute before a case is filed? What does that 
11 
refer to? 
12 
MR. LEE: Your Honor, we believe that's a 
13 
venue provision essentially telling an individual if 
14 
there is no exigent case, there is no case of United 
15 
States versus So And So, then you seek to enforce 
16 
your rights, then you can go in and do so in the did 
17 
18 
19 
20 
21 
22 
23 
24 
25 
court where the offense occurred. This is not 
saying, necessarily, that rights exist, but if you 
believe they exist, here is the place where you're 
going to have to lodge it, and the Court will have 
to decide. 
Now, there are certain of the eight rights 
accorded in 3771(a) that could come up before any 
charge is filed. For instance, let's say somebody 
believes that the perpetrator of the crime is going 
I 
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1 
to try to harm them or threatened them or 
2 
intimidated them into not testifying or cooperating 
3 
with the government and, of course, no indictment 
4 
has been returned. If an individual went to the 
5 
government and believed that the individual had not 
6 
acted appropriately, they can go to the district 
7 
court and say I need to have my rights under 
8 
3771(a)(1) enforced because those people are 
9 
threatening me, and the government hasn't done 
10 
enough. That would be a situation. 
11 
But we're talking really here about (a)(5), 
12 
13 
14 
15 
16 
17 
18 
19 
Dean case and the instant case, Your Honor, is 
20 
this. In Dean, they had negotiated with BP 
21 
Petroleum for a plea and it was always contemplated 
22 
that there was going to be a federal prosecution. 
23 
The distinction in this case was that there was 
24 
already a pending state prosecution and the 
25 
objective for both sides was to keep it in state 
which is the right to consult in the case and we 
respectfully submit that there is not case until a 
charge has been filed. 
THE COURT: So, what about the circuit case 
that was actually pending case had to do with a plea 
agreement in a pending case? 
MR. LEE: Yes. The distinction between the 
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court and the federal government's objective was to 
2 
ensure that there were sufficient safeguards in the 
3 
state court proceedings and concessions made by Mr. 
4 
Epstein so that federal interests, particularly a 
5 
cause of action for damages for the victims of the 
6 
sexual exploitation could be preserved. So that's 
7 
the key distinction because there was no federal 
8 
case, there was no federal criminal charge 
9 
contemplate so long as the agreement could be 
10 
reached. 
11 
THE COURT: All right. So they want me to 
12 
invalidate your non-prosecution agreement. 
13 
MR. LEE: Your Honor, we respectfully submit 
14 
that 3771 does not grant authority of this Court to 
15 
do so. In the Dean case, for instance, Your Honor, 
16 
there was a plea agreement that was entered into and 
17 
18 
19 
20 
21 
22 
23 
district court take that into account. There is no 
24 
plea agreement before this Court. There will be no 
25 
plea proceedings in this court. That was all done 
district court, of course, entertained a plea 
agreement and exercised its judicial discretion in 
terms of whether to accept it or not. The victims 
were encouraged to go to district court and say, you 
know, we didn't hear about this. We should have, 
and we object to it for the following reasons. The 
1 
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