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identified individual and Epstein, so long as the identified individual elects to proceed exclusively 
under IS 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. 
a 
Paragraph 8 addresses how Mr. Epstein's waivers are triggered pursuant to a settlement 
with each identified individual. Paragraph 8 is clear that Mr. Epstein will only waive § 2255 
liability "so long as" each identified individual proceeds exclusively under § 2255 and agrees to 
waive damages other than "an amount as agreed to between the identified individual and 
Epstein." The Agreement's silence with respect to what happens if the parties cannot settle on a 
damages amount indicates that the parties intended for the scope of the attorney representative's 
representation to be limited to settling claims with Mr. Epstein, not representing these identified 
individuals in § 2255 lawsuits. 
Ms. 
however, insists that the attorney representative's duties include pursuing a 
lawsuit under § 2255 on behalf of each identified individual in the event that settlement talks are 
unsuccessful. This interpretation is incorrect because Ms. 
ignores Paragraph 8, which 
limits the scope of the attorney representative's representation. 
The longstanding intention of the parties is also consistent with our interpretation of the 
Agreement based on prior iterations of the Agreement, which only refer to appointing a trustee or 
a guardian ad litem to protect the interests of the identified individuals. Thus, legal representation 
in a lawsuit was never contemplated under the Agreement. Also, Mr. Epstein's agreement to pay 
the attorney representative's fees reaffirms that the parties never intended for the attorney 
representative to bring lawsuits. § 2255 includes a provision for attorrnes, but only if there 
is a monetary recovery. If the Agreement contemplates, as Ms. OM 
suggests, that the 
attorney representative could file suit on behalf of each identified individual, Mr. Epstein would 
never have agreed to pay attorneys fees for those that being suit and lose. It is clear that Mr. 
Epstein agreed to pay the attorney representative's fees because he assumed that each identified 
individual represented by the attorney representative would recover something by settling on their 
respective damages claim. 
Ms. 
interpretation of the Agreement would also trigger profound ethical 
problems due to the conflicts of interests that would arise. For instance, if Mr. Epstein agrees to 
pay for the attorney representative's fees and monthly expenses in any potentially litigated matter, 
then the attorney representative would effectively be incentivized to reject settlement under § 
2255 in an effort to draw out the lawsuits and incur more fees. If the lawyer were allowed to 
represent the identified individuals in a lawsuit, the best interests of each identified individual 
might not be served, because the attorney representative will always be more interested in 
pursuing lawsuits in lieu of settling claims against Mr. Epstein efficiently and fairly. This conflict 
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could compromise the attorney representative's duty of loyalty. See ABA Annotated Model 
Rules of Professional Conduct, Rule 1.8(0 CA lawyer shall not accept compensation for 
representing a client from one other than the client unless... there is no interference with the 
lawyer's independence of professional judgment or with the client-lawyer relationship"). And Mr. 
Epstein would essentially be paying the attorney representative to sue himself. Such a result is 
inappropriate and unconscionable. 
The attorney representative will face other conflicts as well. As a general matter, multiple 
representation of a group of individuals that elects to settle on damages as well as one or more 
individuals who reject settlement carries with it the heightened potential for irreparable conflicts. 
For example, the ethics rules preclude an attorney from simultaneously representing parties that 
are likely to end up in conflict. See ABA Annotated Model Rules of Professional Conduct, Rule 
1.7 ("A lawyer shall not represent a client if...there is a significant risk that the representation of 
one or more clients will be materially limited by the lawyer's responsibilities to another client, a 
former client or a third person or by a personal interest of the lawyer."). Here, I can imagine a 
case where one of the identified individuals is called as a witness by Mr. Epstein to dispute an 
allegation by another identified individual who is a party to the case. The attorney representative 
would have to cross examine the witness, who is also his client. In another scenario, the attorney 
representative may receive privileged information from one identified individual, which precludes 
him from using that information with respect to another identified individual. In each scenario, 
the attorney representative will be simultaneously representing parties that may be in conflict, in 
violation of Rule 1.7. 
For these reasons, we believe that Ms. 
interpretation of the Agreement in 
connection with the attorney representative's role in the settlement process must be rejected. 
Second Issue: Waiver of Liability. Ms. 
incorrectly alleges that Mr. Epstein 
has waived liability even when claims are not settled. Pursuant to the Agreement, if the identified 
individuals choose not to settle with Mr. Epstein, he will not waive liability for those individuals 
whose claims are not settled by the attorney representative. Paragraph 8 is clear that Mr. Epstein 
will only waive § 2255 liability so long as each identified individual proceeds exclusively under § 
2255 and agrees to waive damages other than "an amount as agreed to between the identified 
individual and Epstein." (Paragraph 8, Agreement) Consequently, those identified individuals 
who choose not to settle with Mr. Epstein are not covered by the terms of the Agreement and will 
have to prove, among other things, that they are victims under the enumerated statutes. 
Third Issue: Communication to Identified Individuals. Ms. 
proposes that 
either she or federal agents will speak with the identified individuals regarding the settlement 
process. 
We do not think it is the government's place to be co-counsel to the identified 
individuals, nor should the FBI be their personal investigators. Neither federal agents nor anyone 
from your Office should contact the identified individuals to inform them of the resolution of the 
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case, including appointment of the attorney representative and the settlement process. Not only 
would that violate the confidentiality of the Agreement, but Mr. Epstein also will have no control 
over what is communicated to the identified individuals at this most critical stage. We believe it 
is essential that we participate in crafting a mutually acceptable communication to the identified 
individuals. We further believe that communications between your Office or your case agents 
and the identified individuals might well violate Rule 6(c)(2)(B) of the Federal Rules of Criminal 
Procedure. The powers of the federal grand jury should not, even in appearance, be utilized to 
advance the interests of a party to a civil lawsuit. 
We propose that the following joint communication be made to Judge M, 
who will act 
as the attorney representative and communicate accordingly with the identified individuals: 
As counsel for the United States of America and Jeffrey Epstein, we jointly write 
to you to provide information relevant to your services as the attorney 
representative to represent certain identified individuals who may have a civil 
claim against Mr. Epstein. 
The United States has conducted an investigation of Mr. Epstein regarding his 
solicitation of females, some of whom the government alleges were underage, to 
engage in prostitution in his Palm Beach County home. 
Based on this 
investigation, the United States has identified certain individuals who may be 
eligible to seek a civil remedy against Mr. Epstein pursuant to 18 U.S.C. § 2255. 
The United States and Mr. Epstein have agreed to a resolution of this investigation. 
As part of the resolution of this matter, the parties have agreed to a settlement 
process for these identified individuals. The parties agree that you will contact 
each identified individual and explain the nature of the resolution of this matter, 
including the settlement process, in accordance with a joint communication drafted 
by the United States and Mr. Epstein. The parties further agree that you will 
interview each identified individual to confirm that they have a viable claim 
against Mr. Epstein pursuant to 18 U.S.C. § 2255. 
Pursuant to the resolution of this matter, you will represent only those identified 
individuals who elect to settle their claims with Mr. Epstein, and your duties will 
be limited to negotiating a settlement on the identified individuals' behalf and 
dispersing the settlement proceeds. Mr. Epstein has agreed that he will not contest 
jurisdiction in the Southern District of Florida, and he will not contest liability 
pursuant to 18 U.S.C. § 2255 for those identified individuals who elect to settle all 
potential claims against him regarding this matter. Mr. Epstein has also agreed to 
pay reasonable attorney's fees and expenses that you incur as a result of settlement 
negotiations and settlement administration of this matter. 
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• 
• 
• 
October 10, 2007 
Page 6 
To settle these claims, the parties agree that you will negotiate a total settlement 
amount with Mr. Epstein for each identified individual who elects to settle. After 
the United States formally declines to initiate any prosecution against Mr. Epstein 
related to this matter and each identified individual you represent executes a 
waiver of all rights to pursue any litigation regarding this matter, you may then 
distribute the proceeds from the total settlement amount to the identified 
individuals in the manner you see fit. 
For those identified individuals who elect not to settle their claims, Mr. Epstein 
will not waive his right to contest jurisdiction, liability or damages. Furthermore, 
Mr. Epstein will not pay for their attorney's fees or expenses, and you may not 
represent these individuals in any capacity. Each of these individuals will be 
responsible for finding, hiring and paying for her own attorney. 
The details regarding the United State's investigation of this matter and its 
resolution with Mr. Epstein is confidential. You may not make public statements 
regarding this matter. If you have any questions regarding this matter, including 
the settlement process, you must contact Mr. Epstein's counsel and request a joint 
clarification from said counsel and the United States. You should not contact the 
United States directly. The parties will make every effort to answer your questions 
via a joint communication. 
M, as you know, when Mr. Epstein signed the Agreement, he did so in order to reach 
finality with your Office and with the express representation that the federal investigation against 
him would cease. To that end, I would like your assurance that after you and I agree to the issues 
raised in this letter, that it will be the end of the United States' involvement barring a willful 
breech of the Agreement. Specifically, the government or any of its agents will not make any 
further communications to the identified individuals and will not make any ex parte 
communications with Judge 
I look forward to resolving these open issues with you during our 4:30 call today. 
Sincerely, 
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U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 South Australian Ave., Suite 400 
West Pahn Beach, FL 33401 
Facslm e: 
March 15, 2007 
DELIVERY BY HAND 
Miss 
Re: 
Crime Victims' and Witnesses' Rights 
Dear Miss  Ile 
Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense, 
you have a number of rights. Those rights are: 
(I) 
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 MI 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. 
Members of the U.S. Department of Justice and other federal investigative agencies, 
including the Federal Bureau of Investigation, must use their best efforts to make sure that t 
rights are  protected. If you have an concerns in this regard, please feel free to contact me at 
or Special Agent 
from the Federal Bureau of Investigation at 
You also an con act the Justice Department's Office for Victims of Crime in 
Washington, D.C. at 
. That Office has a website 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 arc being violated, you have the right to petition the Court for 
relief. 
i ! i 
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Miss 
MARCEi.15,2007 
PAGE 2 
In addition to these rights, you are entitled to counseling and medical services, and protection 
from intimidation and harassment. If the Court determines that you are a victim, you also may be 
entitled to restitution from the perpetrator. A list of counseling and medical service providers can 
be provided to you, if you so desire. If 
family is subjected to any intimidation or 
harassment, please contact Special Agent 
or myself immediately. It is possible that 
someone working on behalf of the targets of the investigation may contact you. Such contact does 
not violate the law. However, if you are contacted, you have the choice of speaking to that person 
or refusing to do so. I 
re se 
d feel that you are being threatened or harassed, then please 
contact Special Agent 
myself.. 
 
You-also-are-entitled-to-nofifieatiotrof upcoming-case-events:—At-this-timeiyourease is 
under investigation. If anyone is charged in connection with the investigation, you will be notified. 
Sincerely, 
Unit 
States Attorney 
By: 
cc: 
Special Agent=-, 
C.B.I. 
Assistant United States Attorney 
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USAFLS) 
From: 
(USAFLS) 
Sent: 
onday, September 24, 2007 10:56 AM 
To: 
'Ocariz, Humberto H. (SHB)' 
Subject: 
RE: Conflict Check 
Bert, 
Please keep this confidential because these arc minor victims. This is a preliminary list: 
t
C
1 
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Assistant II.S. Attorney 
From: Ocariz, Humberto H. (SHB) [mailto:
Sent: Monday, September 24, 2007 10:27 AM 
To: 1 
(USAFLS) 
Subject: RE: Conflict Check 
Thanks. I am also going to need the list of the 40 girls who will he my clients. Can you send those as well? 
Thanks, 
Bert Ocariz 
From: 1 
(USAFLS)  
Sent: Monday, September 24, 2007 10:25 AM 
To: Ocariz, Humberto H. (SHB) 
Subject: Conflict Check 
Hi Bert - Here is the list of names for a conflict check 
Jeffrey Epstein 
Mucinska 
J. Epstein Virgin Islands Foundation, Inc. 
J.Epstein & Company, Inc. 
Epstein Interests 
Financial Trust company, Inc. 
NES, LLC 
New York Strategy Group, Inc. 
JEGE, Inc. 
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Flyperion Air, Inc. 
Jeffrey Epstein would be the defendant in any lawsuit, but the other individuals are persons involved in the 
triminal activity. All of the corporations are essentially alter-egos of Epstein. 
Thank you so much. 
Assistant U.S. Attorney 
Mail Gate made the following annotations on Mon Sep 24 2007 09:27:21 
CONFIDENTIALITY NOTICE: This c-mail message including attachments, i f any, is intended for the person 
or entity to which it is addressed and may contain confidential and/or privileged material. Any unauthorized 
review, use, disclosure or distribution is prohibited. If you arc not the intended recipient, please contact the 
sender by reply e-mail and destroy all copies of the original message. Thank you. 
3 
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J 
09124/2007 
01:27 PM 
To "Jay Lefitowitt tteficorigpldrklencl.com,
cc 'Mai* Weinberg" eoMutgwetworldnet.ett.net>. 
bcc 
Subject RE: Epstein agreement as reviewed by the U.S. Attorney 
Hi Jay - Sony for the delay. The US. Attorney had a last-minute 
concern, that I think I fixed (it is in the first "It Appearing" clause 
following the list of statutes potentially violated). 
A.fter you get the green light, let's discuss the potential 
representative. The person I am thinking of has run a preliminary 
conflicts check and it looks alright. 
Also, to address Mr. Epstein's concern regarding the list of names, 
I wanted to tell you that 1 have compiled a list of 34 confirmed 
minors. There are six others, whose names we already have, who 
need to be interviewed by the FBI to confirm whether they were 17 
or 18 at the time of their activity with Mr. Epstein. Once those 
interviews are completed, I can finalize the list of identified 
victims, which I will put in a formal document that I will maintain 
until the time of Mr. Epstein's sentencing. 
Assuming that this agreement is fine, please execute at least three 
copies, and send one to me by fax and the rest by FedEx. I will 
execute and send the copies back. 
Thank you. 
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(USAFLS) 
From: 
. (USAFLS) 
nt: 
unday, SepteWiW2 , 2007 8:58 PM 
Jay Lefkowitz 
dubject: 
Epstein agreement 
Hi Jay — Here are the revisions that I agree with and those I don't. We have been over paragraph 6 an infinite number of 
times. It is factually accurate that the list we are going to give you are persons we have Identified as victims. If we did 
not think they were victims, they would have no right to bring suit, regardless of whether your client is willing to waive 
liability or not. I have not balked about giving your client yet another month to self-surrender, so please let us just put 
this to rest. I changed the amount of time for the US to notify you of breach to take into account the fact that this 
agreement will not be completed within 30 months of execution (because of the lengthy delay before self-surrender) 
and to give us a 6 month window in case we discover a violation after Mr. Epstein is released. 
I do not care if you want to call the appointed person a "representative" instead of a guardian, so long as he/she is: (1) a 
lawyer; (2) independent; (3) selected by our Office or a federal judge; and (4) paid for by your client or by the federal 
court. 
I have sent this to. 
for his review. I have asked him to call me either late tonight or early tomorrow morning. When 
I get his comments, I will get back to you, probably tomorrow. 
Thank you. 
70923 Epstein 
-Prosecution.. 
1 
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09119/200712:14 PM 
To 'Jay Lot kowite <JLetkowIlz@kirkland.cot 
co 
bee 
Subject RE: Meeting 
Judge Johnson has duty next week. 
Jay —I hate to have to be firm about this, but we need to wrap this up by 
Monday. I will not miss my indictment date when this has dragged on 
for several weeks already and then, if things fall apart, be left in a less 
advantageous position than before the negotiations. I have had an 
82-page pros memo and 53-page indictment siding on the shelf since 
May to engage in these negotiations. There has to be an ending date, 
and that date is Monday. 
Assistant U.S. Attorney 
ris 
1=111FININIONS. 
Orip*nal Mosspso ---
Prong 1 
\(USAFLS\)' 
Sent: U9/19/2UU/ 
I AM Ab I 
To: Jay Lefkowlm. 
Subject: Meeting 
Barry is available Monday morning. Our most flexible West Palm 
Beach magistrate is on duty on Monday, so, assuming we have 
signed documents by 1:30 or so, we should be able to get Mr. 
Epstein arraigned on Monday. I doubt that we will be able to get 
everything finished up here, get down to Miami, and try to find a 
Miami mag by close of business on Monday. 
08-80736-CV-MARRA 
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I 
09/16/2007 03:54 PM 
To "Jay Leficowite <JLefkowitzfikickland.cot 
cc 
bee 
Subject Re: 
Hi Jay — This can wait until after the show• but y voice is going 
so I thought I would type it up. I talked to 
and he still doesn't 
like the factual basis. In his opinion, the plea should only address 
the crimes that we were addressing, and we were not investigating 
Mr. Epstein abusing his girlfriend. 
So, these are the only options that he recommended: 
1. We go back to the original agreement where Mr. Epstein pleads 
only to state charges and serves his time in the state, except that we 
can agree to only 18 months imprisonment. 
2. Mr. Epstein pleads guilty to the state charges and also pleads to 
either two obstruction counts or to one count of violating 47 USC 
223(a)(1)(Et), with a joint non-binding recommendation of 18 
months, so that Mr. Epstein can serve his time federally. 
3. (My suggestion only, not IN): 
I go back to the U.S. 
Attorney and ask hirp to agree to an ABA-plea to a 371 count 
(conspiracy to violate 2422(b)) with a binding 20-month 
recommendation so that Mr. Epstein can serve all of his time in a 
federal facility. 
Or 4. Mr. Epstein pleads to one obstruction count, and serves part 
of his time federally and part state, 
On your other proposed changes, some aro fine and some are 
problematic. 
Re your paragraph 2: As to timing, it is my understanding that Mr. 
Epstein needs to be sentenced in the state after he is sentenced in 
the federal case, but not that he needs to l
id guilty and be 
sentenced after serving his federal time. 
recommended that 
some of the timing issues be addressed only in the state agreement, 
so that it isn't obvious to the Judge that we are trying to create 
federal jurisdiction for prison purposes. My understanding is that 
Mr. Epstein should sign a state plea agreement, plead guilty to the 
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federal offenses, plead guilty to the state offenses, be sentenced on 
the federal offenses, and then be sentenced on the state offenses, 
and then start serving the federal sentence. 
Re your paragraph 3: As to the reservation of Mr. Epstein's right to 
withdraw his state plea or to appeal his state plea or sentence, that 
is fine, but we need the caveat that, if he were to do so, the United 
States could proceed on our charges. 
Re your paragraph 6: With respect to the waiver of the right to 
appeal the federal sentence, given the way we have drafted the 
information, it is possible that getting to the 18 month sentence 
will require an upward departure. The version of the agreement 
that you were working from is a federal non-prosecution 
agreement, the ones I have sent you recently are plea agreements 
that get filed with the court. Please see if the appeal waiver 
language in those versions is alright, 
Re your paragraph 7: As I mentioned, we will not waive the 
presentence investigation. I know that this will delay Mr. Epstein's 
sentencing by 70 days, but that will allow him to get all of his 
affairs in order. As to bail, it will be set at the time of arraignment, 
and we can work out a joint recommendation regarding the amount 
and its limitations. I have no objection to making a joint 
recommendation that Mr. Epstein remain out on bond pending his 
sentencing, but Fm not sure that it belongs in a plea agreement, 
especially since I can't bind the court on that issue. However, I can 
assure you, and we can put it on the record during the plea 
collooquy, that I will join in your recommendation that he remain 
out on bond pending sentencing. The same goes for the prison 
camp issue. As I mentioned, I have opposed a designation only 
once in a very particular case. I can assure you, and we can put it 
on the record at the plea colloquy that I will not oppose your 
recommendation for Mr. Epstein's designation. 
Re your paragraph 8: As I mentioned over the telephone, I cannot 
bind the girls to the Trust Agreement, and I don't think it is 
appropriate that a state court would administer a trust that seeks to 
pay for federal civil claims. We both want to avoid unscrupulous 
attorneys and/or litigants from coming forward, and I know that 
your client wants to keep these matters outside of public court 
filings, but I just don't have the power to do what you ask Here is 
my recommendation. During the period between Mr. Epstein's 
plea and sentencing, I make a motion for appointment of the 
Guardian Ad Litem. The three of us sit down and discuss things, 
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