EFTA00184224

Case 9:08-cv-80736-KAM Document 362-12 Entered on FLSD Docket 02/10/2016 Page 4 of 9 
,w, 
U.S. Department ofTustleer 
United States Attorney 
Southern Dtstrkt ofFlorida 
iz 
500 South Aselmilan Ave, SW. 400 
ffat helm Beach, Pt, 33401 
November 29, 2007 
DELIVERY AY HAND 
Miss 
Re: 
crime VictimeL.Righ
eitisation
Dear Miss
Several months ago, I provided you with a letter notifying you of your rights as a victim 
pursuant to the Justice for All Act of 2004 and other federal legislation, including: 
(1) 
The right to be reasonably protected from the accused. 
(2) 
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. 
(3) 
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. 
(4) 
The right to be reasonably heard at any public proceeding in the district court 
involving release, plea, or sentencing. 
(5) 
The reasonable right to confer with Ihe attorney for die United States in the ease. 
(6) 
The right to Rill and timely restitution as provided in law. 
(7) 
The right to proceedings free from unreasonable delay. 
• 
(8) 
The right to be treated with fairness and with respect for the victim's dignity and 
privacy. 
i am writing to inform you that the federal investigation of Jeffrey Epstein has been 
completed, and Mr. Epstein and the U.S. Attorney's Office have reached an agreement containing 
the following terms. 
First, Mr. Epstein agrees that he ivill plead guilty to two state offenses, including the offense 
ofsoliciting minors to engage in prostitution, which will require him to register as a sexual predator 
for the remainder of his life. 
US_Atty_Cor_00257 
EFTA00184864

Case 9:08-cv-80736-KAM Document 362-12 Entered on FLSD Docket 02/10/2016 Page 5 of 9 
Mths 
Nova/•tem 29,2007 
PAGE 2 
Second, Mr. Epstein has agreed to make a binding recommendation of 18 months' 
imprisonment to the state court judge who sentences him, Mr. Epstein will servo that sentence of 
imprisonment at the Pakeneach County Jail. 
Third, Mr. Epstein has agreed that he will not contest jurisdiction or liability if you elect to 
seek damages from him because the United States has Identified you as a minor victim of certain 
federal offenses, including travel in interstate commove to engage in prostitution with minors and 
the use of facilities of interstate commerce to induce minors to engage in prostitution. To assist you 
in maldng such a claim, the U.S. Attorney's Office has asked in independent Special Master to 
select attorneys to represent you. Those attorneys am Aaron Podhurst and Robert ("Bob") 
Josefsberg with the law firm of Podhurst Ossetic, P.A. They can he reached at (305) 358-2800. 1 
anticipate that someone from their law firm will be contacting you shortly. I must also advise/Non 
That you are not obligated to use these attorneys. In fact. you have the absolute right to select your 
own attorney. so you can decide not to speak with Mssrs. Podhurst/ Josefsherg at all. or you comp 
speak with them and decide at a 
o to use a different attorney If you do decide to seek damages 
from Mr. Epstein and you decide to use Messxs.Podburst/Josefsberg as your attorneys, Mr. Epstein 
will be responsible for paying attorney's fees incurred during the time spent trying to negotiate a 
settlement. If you are unable to reach a settlement with Mr. Epstein, you and Mr. Josefsberg can 
discuss how best to proceed. 
As I mentioned above, as part of the resolution of the federal investigation, Mr. Epstein has 
agreed to plead guilty to state charges. Mr. Epstein's change of plea and sentencing will occur on 
December 14,2007, at 
a.m. beforeIudge Sandra K. MoSorley, inCourtroom I1P at the Palm 
Beach County Courthouse, 205 North Dixie Highway, West Palm Beach, Florida. Pursuant to 
Florida Statutes Sections 960.001(1)(k) and 921.143(1), you are entitled to be present and to make 
a statement under oath. If you choose, you can submit a written statement under oath, which will 
be filed by the State Attorney's Office on your behalf. If you elect to prepare a written statement, 
it should address the fbllowing: 
the acts of the case and the extent of any bum, including social, psychological, or 
physical harm, financial losses, 1093 of earnings directly or indirectly resulting from 
the crime for which the defendant is being sentenced, and any matter relevant to an 
appropriate disposition and sentence. FL Stat. 921.143(2). 
Yon also are entitled to notification wham Mr. Epstein is released from imprisonment at the 
end of his prison term and/or if ho is allowed to participate in a work release program. To receive 
such notification, please provide the State Attorney's Office with the following information: 
I. 
Your manta 
2. 
Your address 
3. 
Your home, work, and/or cell phone numbers 
US_Atty_Cor_00258 
EFTA00184865

Case 9:08-cv-80736-KAM Document 362-12 Entered on FLSD Docket 02/10/2016 Page 6 of 9 
MISS 
NOVEMBER 29,2007 
1"non 3 
4. 
Your e-mail address 
5. 
A notation of whether you would like to participate in tho "VINE system," which 
provides automated notification calls any time an inmate is moved. (To use this 
system, your calls must go to you directly, not through a switchboard.) 
Thank you for all of your help during the course of the investigation. If you have any 
questions or concerns, please do not hesitate to contact me or Special Agent 
Knyrkendall 
at 
Sincerely, 
United States Attorney 
By: 
A. 
Villefoga 
Assistant United States Attorney 
cc: 
Special Agent Nesbitt ICuyrkendall, F.D.I. 
Ms. Clearetha Wright, Victim-Witness Coordinator, U.S. Attorney's Office 
US_Atty_Cor_00259 
EFTA00184866

Case 9:08-cv-80736-KAM Document 362-12 Entered on FLSD Docket 02/10/2016 Page 7 of 9 
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 South Australian Ave, Suite 400 
West Palm Beach, FL 3340! 
November 29, 2007 
DELIVERY BY HAND 
Miss 
Re: 
Crime Victims' Rights — Notification of Resolution of Epstein _Investigation 
Dear Miss 
. 
Several months ago, 1 provided you with a letter notifying you of your rights as a victim 
pursuant to the Justice for All Act of 2004 and other federal legislation, including: 
(1) 
The right to be reasonably protected from the accused. 
(2) 
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. 
(3) 
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. 
(4) 
The right to be reasonably heard at any public proceeding in the district court 
involving release, plea, or sentencing. 
(5) 
The reasonable right to confer with the attorney for the United States in the case. 
(6) 
The right to full and timely restitution as provided in law. 
(7) 
The right to proceedings free from unreasonable delay. 
(8) 
The right to be treated with fairness and with respect for the victim's dignity and 
privacy. 
I am writing to inform you that the federal investigation of Jeffrey Epstein has been 
completed, and Mr. Epstein and the U.S. Attorney's Office have reached an agreement containing 
the following terms. 
First, Mr. Epstein agrees that he will plead guilty to two state offenses, including the offense 
of soliciting minors to engage in prostitution, which will require him to register as a sexual predator 
for the remainder of his life. 
US_Atty_Cor_00260 
EFTA00184867

Case 9:08-cv-80736-KAM Document 362-12 Entered on FLSD Docket 02/10/2016 Page 8 of 9 
MISS 
NOVEMBER 29,2007 
PAGE 2 
Second, Mr. Epstein has agreed to make a binding recommendation of 18 months' 
imprisonment to the state court judge who sentences him. Mr. Epstein will serve that sentence of 
imprisonment at the Palm Beach County Jail. 
Third, Mr. Epstein has agreed that he will not contest jurisdiction or liability if you elect to 
seek damages from him because the United States has identified you as a minor victim of certain 
federal offenses, including travel in interstate commerce to engage in prostitution with minors and 
the use of facilities of interstate commerce to induce minors to engage in prostitution. To assist you 
in making such a claim, the U.S. Attorney's Office has asked an independent Special Master to 
select attorneys to represent you. Those attorneys are Aaron Podhurst and Robert ("Bob') 
Josefsberg with the law firm of Podhurst Orseck, P.A. They can be reached at (305) 358-2800. I 
anticipate that someone from their law firm will be contacting you shortly. I must also advise you 
that you are not obligated to use iese attome . In fact, you have the absolute 
h 
seleetypl
own attorney, so you can decide not to speak with MSS/S. Podhurst/ Josefsberg at all, or you can 
speakwith them and decide at any time to use a different attorney, If you do decide to seek damages 
from Mr. Epstein and you decide to use Messrs. Podhurst/Josefsberg as your attorneys, Mr. Epstein 
will be responsible for paying attorney's fees incurred during the time spent trying to negotiate a 
settlement. If you are unable to reach a settlement with Mr. Epstein, you and Mr. Josefsberg can 
discuss how best to proceed. 
As I mentioned above, as part of the resolution of the federal investigation, Mr. Epstein has 
agreed to plead guilty to state charges. Mr. Epstein's change of plea and sentencing will occur on 
December 14, 2007, at 
 a.m., before Judge Sandra K. McSorley, in Courtroom 11F at the Palm 
Beach County Courthouse, 205 North Dixie Highway, West Palm Beach, Florida. Pursuant to 
Florida Statutes Sections 960.001(1)(k) and 921.143(1), you are entitled to be present and to make 
a statement under oath. If you choose, you can submit a written statement under oath, winch will 
be filed by the State Attorney's Office on your behalf. If you elect to prepare a written statement, 
it should address the following: 
the facts of the case and the extent of any harm, including social, psychological, or 
physical harm, financial losses, loss of earnings directly or indirectly resulting from 
the crime for which the defendant is being sentenced, and any matter relevant to an 
appropriate disposition and sentence. Fl. Stat 921.143(2). 
You also are entitled to notification when Mr. Epstein is released from imprisonment at the 
end of his prison term and/or if he is allowed to participate in a work release program. To receive 
such notification, please provide the State Attorney's Office with the following information: 
1. 
Your name 
2. 
Your address 
3. 
Your home, work, and/or cell phone numbers 
US Atty_Cor_00261 
EFTA00184868

Case 9:08-cv-80736-KAM Document 362-12 Entered on FLSD Docket 02/10/2016 Page 9 of 9 
MISS 
NOVEMBER 29,2007 
PAGE 3 
4. 
Your e-mail address 
5. 
A notation of whether you would like to participate in the "VINE system," which 
provides automated notification calls any time an inmate is moved. (To use this 
system, your calls must go to you directly, not through a switchboard.) 
Thank you for all of your help during the course of the investigatlakkou have any 
questions or concerns, please do not hesitate to contact me or Special Agen 
Kuyrkendall 
Sincerely, 
R. Alexandea 
United States Attorney 
By: 
A. 
Assistant United States Attorney 
cc: 
Special Agent.. Kuyrkendall, F.B.I. 
Ms. Clearetha Wright, Victim-Witness Coordinator, U.S. Attorney's Office 
US_Atty_Cor_00262 
EFTA00184869

Case 9:08-cv-80736-KAM Document 362-13 Entered on FLSD Docket 02/10/2016 Page 1 of 2 
EXHIBIT 
83 
EFTA00184870

Case 9:08-cv-80736-KAM Document 362-13 Entered on FLSD Docket 02/10/2016 Page 2 of 2 
11/29/2007 0630 PM 
To "Jay Lefltowitt i4JLefkowitztQldrklend.com> 
cc 
bcc 
Subject RE: Epstein: Victim Notification Lotter 
Hi Jay — The only attachment is my letter, did I miss something? 
Thanks. 
Bee 
< nn. ar o. . 
an 
uedo).gova 
11/2812007 04:48 PM 
ToeJay leflovott <JLefitowitz@kirltland.eom> 
&Stamen. JO WSSFLST 
. 
SuEpstain: Victim Notification Letter 
b;e 
ct 
Dear Jay: 
Jeff asked that I forward the victim notification letter to you. It is 
attached. 
Thank you. 
«Victim NotlfloatIon Ltr.pdf» 
A. 
Villafaila 
Assistant U.S. Attorney 
08-80736-CV-MARRA 
RFP WPB 01)0429 
EFTA00184871

Case 9:08-cv-80736-KAM Document 362-14 Entered on FLSD Docket 02/10/2016 Page 1 of 5 
EXHIBIT 
84 
EFTA00184872

Case 9:08-cv-80736-KAM Document 362-14 Entered on FLSD Docket 02/10/2016 Page 2 of 5 
• 
• 
U.S. Department of Justice 
United States Attorney 
Southern District of -Florida 
500 South Australian Ave.. Suite 400 
West Palm Beach, FL 33401 
Facsimile.• 
November 29, 2007 
DELIVERY BY UNITED STATES MAIL 
Miss 
Re: 
Crime Victims' Rights — Notification of Resolution of Epstein Investigation 
Dear Miss 
Several months ago, I provided you with a letter notifying you of your rights as a victim 
pursuant to the Justice for All Act of 2004 and other federal legislation, including: 
(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. 
I am writing to inform you that the federal investigation of Jeffrey Epstein has been 
completed, and that Mr. Epstein and the U.S. Attorney's Office have reached an agreement 
containing the following terms. 
First, Mr. Epstein agrees that he will plead guilty to two state offenses, including the offense 
of soliciting minors to engage in prostitution, which will require him to register as a sexual offender 
for the remainder of his life. 
RFP MIA 000011 
EFTA00184873

Case 9:08-cv-80736-KAM Document 362-14 Entered on FLSD Docket 02/10/2016 Page 3 of 5 
4 
a 
MISS 
NOVEMBER 29,2007 
PAGE 2 
Second, Mr. Epstein has agreed to make a binding recommendation of 18 months' 
imprisonment to the state court judge who sentences him. Mr. Epstein will serve that sentence of 
imprisonment at the Palm Beach County Jail. 
Third, Mr. Epstein has agreed that he will compensate you for damages you have suffered, 
under the following circumstances. That portion of the agreement that relates to those claims reads 
as follows: 
7. 
The United States shall provide Epstein's attorneys with a list of 
individuals whom it has identified as victims, as defined in 18 U.S.C. 
§ 2255, after Epstein has signed this agreement and been sentenced. 
Upon the execution of this agreement, the United States, in consultation 
with and subject to the good faith approval of Epstein's counsel, shall 
select an attorney representative for these persons, who shall be paid for 
by Epstein. Epstein's counsel may contact the identified individuals 
through that representative. 
8. 
If any of the individuals referred to in paragraph (7), supra, elects to 
file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the 
jurisdiction of the United States District Court for the Southern District 
of Florida over his person and/or the subject matter, and Epstein waives 
his right to contest liability and also waives his right to contest damages 
up to an amount as agreed to between the identified individual and 
Epstein, so long as the identified individual elects to proceed 
exclusively under 18 U.S.C. § 2255, and agrees to waive any other 
claim for damages, whether pursuant to state, federal, or common law. 
Notwithstanding this waiver, as to those individuals whose names 
appear on the list provided by the United States, Epstein's signature on 
this agreement, his waivers and failures to contest liability and such 
damages in any suit are not to be construed as an admission of any 
criminal or civil liability. 
9. 
Epstein's signature on this agreement also is not to be construed as an 
admission of civil or criminal liability or a waiver of any jurisdictional 
or other defense as to any person whose name does not appear on the 
list provided by the United States. 
10. 
Except as to those individuals who elect to proceed exclusively under 
18 U.S.C. § 2255, as set forth in paragraph (8), supra, neither Epstein's 
RFP MIA 000012 
EFTA00184874

• 
Case 9:08-cv-80736-KAM Document 362-14 Entered on FLSD Docket 02/10/2016 Page 4 of 5 
• 
MISS 
NOVEMBER 29, 2007 
PAGE 3 
signature on this agreement, nor its terms, nor any resulting waivers or 
settlements by Epstein are to be construed as admissions or evidence of 
civil or criminal liability or a waiver of any jurisdictional or other 
defense as to any person, whether or not her name appears on the list 
provided by the United States. 
Pursuant to the terms of the agreement and an addendum, to assist you in making such a 
claim, the U.S. Attorney's Office has asked an independent Special Master to select attorneys to 
represent you. Those attorneys are Aaron Podhurst and Robert ("Bob") Josefsberg with the law firm 
of Podhurst Orseck, P.A. They can be reached at (305) 358-2800. I anticipate that someone from 
their law firm will be contacting you shortly. J must also advise you that you arc not obligated to 
use these attorneys. In fact, you have the absolute right to select your own attorney, so you can 
decide not to sneak with Messrs. Podhurst/Josefsberg at all, or you can speak with them and decide 
at any time to use a different attorney. If you do decide to seek damages from Mr. Epstein and you 
decide to use Messrs. Podhurst/Josefsberg as your attorneys, Mr. Epstein will be responsible for 
paying attorney's fees incurred during the time spent trying to negotiate a settlement. If you are 
unable to reach a settlement with Mr. Epstein, you and Mr. Josefsberg can discuss how best to 
proceed. 
As I mentioned above, as part of the resolution of the federal investigation, Mr. Epstein has 
agreed to plead guilty to state charges. Mr. Epstein's change of plea and sentencing will occur on 
December 14, 2007, at 
a.m., before Judge Sandra K. McSorley, in Courtroom 1 IF at the Palm 
Beach County Courthouse, 205 North Dixie Highway, West Palm Beach, Florida. Pursuant to 
Florida Statutes Sections 960.001(1)(k) and 921.143(1), you arc entitled to be present and to make 
a statement under oath. If you choose, you can submit a written statement under oath, which may 
be filed by the State Attorney's Office on your behalf. If you elect to prepare a written statement, 
it should address the following: 
the facts of the case and the extent of any harm, including social, psychological, or 
physical harm, financial losses, loss of earnings directly or indirectly resulting from 
the crime for which the defendant is being sentenced, and any matter relevant to an 
appropriate disposition and sentence. Fl. Stat. 921.143(2). 
You also are entitled to notification when Mr. Epstein is released from imprisonment at the 
end of his prison term and/or if he is allowed to participate in a work release program. To receive 
such notification, please provide the State Attorney's Office with the following information: 
1. 
Your name 
2. 
Your address 
3. 
Your home, work, and/or cell phone numbers 
4. 
Your e-mail address 
5. 
A notation of whether you would like to participate in the "VINE system," which 
RFP MIA 000013 
EFTA00184875

Case 9:08-cv-80736-KAM Document 362-14 Entered on FLSD Docket 02/10/2016 Page 5 of 5 
J) 
MISS 
NOVEMBER 29, 2007 
PAGE 4 
provides automated notification calls any time an inmate is moved. (To use this 
system, your calls must go to you directly, not through a switchboard.) 
Thank you for all of your help during the course of the investigatiosiou have an 
questions or concerns, please do not hesitate to contact me or Special Agent 
at 
By: 
Sincerely, 
United States Attorney 
Assistant United States Attorney 
cc: 
Special Agent 
F.B.I. 
Ms. Clearetha Wright, Victim-Witness Coordinator, U.S. Attorney's Office 
RFP MIA 000014 
EFTA00184876

Case 9:08-cv-80736-KAM Document 362-15 Entered on FLSD Docket 02/10/2016 Page 1 of 5 
EXHIBIT 
85 
EFTA00184877

Case 9:08-cv-80736-KAM Document 362-15 Entered on FLSD Docket 02/10/2016 Page 2 of 5 
KIRKLAND & ELLIS LLP 
Jay P. Lefkowitc, P.C. 
To all Miler Directly: 
r 
.com 
VIA E-MAIL 
1 
United States Attorney's Office 
Southern District of Florida 
Dear 
AND AITIIJATED PARDO/SHIPS 
Gahm* Center 
Now Yor ., 1.1M4.11 
oninv.kirldand.com 
November 29,2007 
Re: Jeffrey Epstein 
Facsimile: 
I am responding to the draft letter 
sent to me last night, which purports to be a 
letter that you would sign and send to eachIl e individuals whom you have not even identified 
to us, and'about whom the government has made clear it "takes no position" as to the validity of 
potential claims that these individuals may have against Mr. Epstein. I cannot reconcile your 
commitment to "take no position" regarding these potential claims with your intention to sign 
such a letter, which will surely fmd its way almost immediately into the press, refers to these 
individuals as "minor victims," refers to Mr. Epstein as a "sexual predator," misstates the terms 
of our federal non-prosecution agreement (the "Agreement"), and invites federal witnesses to 
attend Mr. Epstein's state sentencing in order to give victim impact statements, although they are 
in most respects not state victims at all. 
More fundamentally, we don't understand the basis for your Office's belief that it is 
appropriate for any letter to be sent to these individuals at this stage — before Mr. Epstein has 
either entered a plea or been sentenced. We respectfully disagree with your view that you are 
required to notify the alleged victims pursuant to the Justice for All Act of 2004. First, 18 U.S.C. 
§ 2255, the relevant statute under the Agreement for the settlement of civil remedies, does not 
have any connection to the Justice for All Act. The Justice for All Act refers to restitution, and 
§ 2255 is a civil remedy, not a restitution statute. 
We also believe that the draft letter could not diverge more dramatically from your 
statement last week that your Office would not intervene in the state process from this point 
forward, and that you would merely monitor it. Indeed, the letter as currently drafted invites 
federal witnesses to become participants in a state proceeding, thus federalizing the state plea 
and sentencing in the same manner as would the appearance and statements of a member of your 
Office or the FBI. 
Chicago 
Hong Kong 
London 
Los Angeles 
Munich 
San Francisco 
Washington. D.C. 
RFP MIA 000007 
EFTA00184878

Case 9:08-cv-80736-KAM Document 362-15 Entered on FLSD Docket 02/10/2016 Page 3 of 5 
. , 
• 
KIRKLAND & ELLIS LLP 
November 29, 2007 
Page 2 
With that said, I respectfully identify below the specific objections we have with the 
proposed letter. 
First, it states that "Mr. Epstein has agreed that he will not contest jurisdiction or liability 
if [the alleged victims] elect to seek damages from him ..." This language implies that Mr. 
Epstein has agreed to concede jurisdiction and has waived liability whether or not each 
individual identified by the government as a "victim" of federal crimes ultimately settles her 
claim pursuant to the Agreement. The letter as drafted invites the witnesses to whom it is sent to 
believe that they can litigate their claims without Mr. Epstein being able to contest jurisdiction or 
liability — a construction of the Agreement that is in direct conflict with its terms. The 
Agreement we entered makes clear that Mr. Epstein's waiver of jurisdiction and liability is 
limited to those instances where the identified individual settles with him pursuant to Sections 7 
through 8 of the Agreement and Addendum. As you are well aware, Mr. Epstein has no 
obligation or intention to concede jurisdiction or liability in any claim for damages — by an 
enumerated "victim" or anyone else — where that party fails to settle her claims pursuant to the 
terms of the Agreement. 
Second, there is no basis to refer to Mr. Epstein as a "sexual predator." Pursuant to the 
terms of the Agreement, Mr. Epstein will be required to register as a "sexual offender," not a 
"sexual predator." Those are very different categories under Florida law. Mr. Epstein has 
agreed to enter a plea of guilty to two counts of violation of Florida Statutes §§ 796.03 and 
796.07. Under Florida law, those charges do not classify him as a sexual predator. See Florida 
Statute § 775.21(4Xa). Rather, he is only a sexual offender as defined by Florida Statute 
§ 943.0435(1Xa). To identify Mr. Epstein as a sexual predator, in this letter or elsewhere,is 
inaccurate and would irreparably harm him. 
Third, we find no basis in law that provides the identified individuals with either a right 
to appear at Mr. Epstein's plea and sentence, or to submit a written statement to be filed by the 
State Attorney. According to Florida Statutes §§ 960.001(k) and 921.143(1), the sentencing 
court permits only "the victim of the crime for which the defendant is being sentenced ... to 
[a]ppcar before the sentencing court for the purpose of making a statement under oath for the 
record; and [s]ubmit a written statement under oath to the office of the state attorney, which 
statement shall be filed with the sentencing court." Florida Statute § 960.001(k) citing 
§ 921.143(1) (emphasis added). Here, Mr. Epstein is pleading guilty to, and being sentenced for, 
state offenses, not the federal offenses under which the government has recognized these 
identified individuals as "victims." The state charges for which Mr. Epstein will be sentenced 
are not coextensive with the federal investigation. Under Florida law, only those persons 
identified as victims of the state offenses may make a statement at the hearing or submit a 
written statement. 
RFP MIA 000008 
EFTA00184879

Case 9:08-cv-80736-KAM Document 362-15 Entered on FLSD Docket 02/10/2016 Page 4 of 5 
KIRKLAND & ELLIS LLP 
November 29, 2007 
Page 3 
With respect, encouraging these individuals to participate in the state sentencing will 
have the effect of creating a media frenzy that will surely impact the sentence Mr. Epstein 
receives — precisely what your Office promised to avoid. Such an intrusion into state affairs, 
when the identified individuals are not even victims of the crime for which Mr. Epstein is being 
sentenced is highly inappropriate. The federal investigation of Mr. Epstein has been concluded, 
and witnesses or civil claimants identified as purported victims of federal offenses have no place 
in the state proceeding. We also think it will likely promote spurious civil litigation against Mr. 
Epstein, a result that would be highly irresponsible to encourage. 
Fourth, we take serious issue with the assertion in the letter that the government has 
identified each recipient of the letter as a "minor victim." The term "minor victim" is notably 
absent from the Agreement. Section 7 of the Agreement states only that the government will 
provide a list of individuals "whom it has identified as victims, as defined in 18 U.S.C. § 2255." 
Indeed, you have told us that at least one identified individual is currently 24 years old, and thus 
would appear not to have been a minor at the time of the alleged conduct (and therefore is 
presumably not eligible to settle her claims under the Agreement). To confer on these women 
the imprimatur of a government "finding" is both incendiary and unwarranted. 
Fifth, your letter mischaracterizes the nature of Mr. Epstein's liability under the 18 
U.S.C. § 2255 provisions of the Agreement. Your letter states that every individual who receives 
the letter is a victim of "certain offenses, including travel in interstate commerce to engage in 
prostitution with minors and the use of facilities of interstate commerce to induce minors to 
engage in prostitution." This construction implies that these individuals are all victims of both 
offenses (travel in interstate commerce to engage in prostitution with minors and the use of 
facilities of interstate commerce to induce minors to engage in prostitution.) Clearly that is not 
the case. Consequently, the language should be revised to reflect that the identified individuals 
may be victims of certain offenses, but not necessarily both offenses. Additionally, fo
e 
of fairness and candor, we believe the same language contained in your letter to Judgelliak
stating that "fflhe United States takes no position as to the validity of any such claim under this 
statute," should be included in any proposed letter. 
Sixth, your letter states that Mr. Podhurst and Mr. Josefsberg may "represent" the 
identified individuals. Since we have not yet had the opportunity to speak with Mr. Podhurst or 
Mr. Josefsberg (though we hope to do so this week), we do not know that they will even agree to 
serve in this capacity. Since I believe the role you are casting for these attorneys creates a 
significant ethical problem, specifically the conflict between counseling the clients to settle for 
the statutory amount and rewarding the attorneys for litigating rather than settling their claims, I 
would not assume that they, or any ethical attorney, would agree to accept this assignment as you 
define it. Whether that will mean that other attorneys will have to be sought, or you will realize 
that the role is untenable as described, either result will require modification of the letter. 
RFP MIA 000009 
EFTA00184880

Case 9:08-cv-80736-KAM Document 362-15 Entered on PLSD Docket 02/10/2016 Page 5 of 5 
KIRKLAND & ELLIS LLP 
November 29, 2007 
Page 4 
Seventh, the identified individuals should not contact lawyers in your Office or agents of 
the FBI. To encourage these individuals to contact federal law enforcement officials is entirely 
inconsistent with your promise that there will be no further federal involvement in this case. 
Moreover, such contact can only invite the possibility for impermissible or partial 
communications. Recently, you asked the defense not to contact potential witnesses in this 
matter in part because the Agreement contemplated the selection of an attorney representative. 
For the same reason there should be no continuing invitation for the witnesses to remain in 
contact with either your Office or the FBI. Any questions these individuals may have regarding 
their rights under the Agreement should be answered by Judge =or 
the attorney 
representative. 
Eighth, this letter should be mailed rather than delivered by hand. We see no reason for 
hand delivery, and mailing will ensure that there are no impermissible or partial communications 
made to the identified individuals upon delivery of the letter. If your Office insists on hand 
delivery of any such letter, however, it should only be made by a third party service, not by law 
enforcement agents. 
Finally, as you know, Judge Stan has requested a meeting with Assistant Attorney 
General Fisher to address what we believe is the unprecedented nature of the § 2255 component 
of the Agreement. We are hopeful that this meeting will take place as early as next week. 
Accordingly, we respectfully request that we postpone our discussion of sending a letter to the 
alleged victims until after that meeting. We strongly believe that rushing to send any letter out 
this week is not the wisest manner in which to proceed. Given that Mr. Epstein will not even 
enter his plea for another few weeks, time is clearly not of the essence regarding any notification 
to the identified individuals. 
Sincerely, 
2;
. Ldko tz 
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• 
• 
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
UNITE1,11,WEY 
DELIVERY BY FACSIMILE 
Kenneth W. Starr, Esq 
Kirkland & Ellis LLP 
777 South Figueroa Street 
Los Angeles, CA 90017 
Re: 
Jeffrey Epstein 
Dear Mr. Start: 
99 N.E I Sates 
Mast FL 33132 
OW 961-9100 - Tekpitone 
(303) 530-6414 - Facsimile 
I write in response to your November 28th letter, in which you raise concerns regarding the 
Non-Prosecution Agreement between this Office and your client, Mr. Epstein. I take these concerns 
seriously. As your letter focused on the Section 2255 portion of the Agreement, my response will 
focus primarily on that issue as well. 1 do wish to make some more general observations, however. 
Section 2255 provides that "[a)ny person who, while a minor, was a victim of a violation of 
[enumerated sections of Title 18) and who suffers personal injury as a result of such violation .. . 
may sue in any appropriate United States District Court and shall recover the actual damages such 
person sustains and the cost of the suit, including a reasonable attorney's fee." Thus, had this Office 
proceeded to trial, and had Mr. Epstein been convicted, the victims of his actions would have been 
able to seek to relief under this Section. 
The Non-Prosecution Agreement entered into between this Office and Mr. Epstein responds 
to Mr. Epstein's desire to reach a global resolution of his state and federal criminal liability. Under 
this Agreement, this District has agreed to defer prosecution for enumerated sections of Title 18 in 
favor of prosecution by the State of Florida, provided that the Mr. Epstein satisfies three general 
federal interests: (1) that Mr. Epstein plead guilty to a "registerable" offense; (2) that this plea 
include a binding recommendation for a sufficient term of imprisonment; and (3) that the Agreement 
not harm the interests of his victims. This third point deserves elaboration. The intent is to place 
the victims in the same position as they would have been had Mr. Epstein been convicted at trial. 
No more; no less. 
With this in mind, I turn to the language of the Agreement. Paragraph 8 of the Agreement 
provides: 
If any of the individuals referred to in paragraph (7), supra, elects to file suit pursuant 
to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the United Slaws 
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