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., .. 
UNITED STATES vs. JEFFREY EPSTEIN 
PLEA PROFFER 
On August _, 2007, Mr. Epstein learned that his Special Agents would attempt to serve 
subpoenas on his personal assistants, 
While traveling to the 
New York City area, Mr. Epstein re-directed his airplane to the U.S. Virgin Islands in order to 
harass to delay Special Agents from serving target letters on his assistants, 
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From: 
Sent: 
To: 
Cc: 
Subject: 
Attachments: 
(USAFLS) 
(USAFLS) 
ber 21c 2007 2:15 PM 
eating with pstem's attorneys 
070921 Epstein Non•Prosecution Agreement pdl 
Iii Harry and 
- I his is the draft I just sent to Jay there arc id ill some outstanding issues. hut I thought 
that )(to might want to .1.1: what the most recent hulks like. 
l'i/hdatia 
Assistant U.S. Attorney 
500 S. Australian Asc. Suite 400 
West Palm Beach. EL 33.4111 
From: 
[malitolikrische@salS.state.O.us] 
Sen 
I, 2007 1:18 PM 
To: 
(USAFLS) 
Cc: 
Subject: RE: Meeting with Epsteln's attorneys 
I just spoke to Jack and related our conversation. You can expect a call from him shortly.
I understand the deft. gets 3 days a month gain time plus 3 additional days a month if he works. So I think that would 
work out to 15 months actual lime served. He would then be on the bracelet. house arrest, for one year Jack indicated 
that he double checked with the stockade and the registration offense won't act as a bar to Epstein doing his time at the 
stockade, so they intend to register concurrent with the plea of guilty 
Glad we could gel this worked out for reasons I won't put in writing After this is resolved I would love to buy you a cup at 
Starbucks and have a conversation 
From• 
(USAFLS)I 
Son • 
21, 2007 1:10 PM 
To: 
Sub 
: RE: Meeting with Epstein's attorneys 
I Ii Barry. [hanks tin• your time this morning. We called Jay and told him that we (you and our office) had 
decided what would work best and that you would contact Jack to finalize the slate agreement. I um trying to 
finish the federal agreement. In addition to the sentence imposed. I want to put in a pro% i dim that he As ill 
:moot 6. 1w in jail at le:Nat:en:tin number of dal. , to make sure hedoesn't try I
 
...: .0 -ium int c'' someone with the 
I lorida prison :luau wines to let him out e:u•l' 
so do 
know hock much "gain lime" s‘otild rpmein earn? 
du you call it "gain time' or -goo•d 'hoc- 
%twit:thing else? 
Thank you. 
Assistant LS. Attorney 
500 S. Australian Ave. Suite 400 
West Palm Bench. El 11,10 
1976 
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"VIllefene, Ann 
C. 
To "Jay Lefler/Ate <,llefkowilzOkIrldand.coe 
(USAFLSI• 
09/27/2007 03:06 PM 
CO 
bcc 
Subject RE: Conference Call with Bert Omitlz 
Hi Jay — I already told Bert that there is no indictment and, as I 
mentioned, he doesn't really need to/want to see the entire plea 
agreement, just the relevant paragraphs so that he understands what 
the scope of his representation will be. I think they would be 
happy knowing that their hourly rate will be paid when it is billed. 
The concern is, if all 40 girls decide they want to sue, they don't 
want to be in a situation where Mr. Epstein says this is getting too 
expensive, we won't pay any more attorneys' fees. 
Two suggestions, that I haven't run past Bert, are: 
1. 
Mr. Epstein signs a standard fee agreement, where 
one of his attorneys or accountants who is not working on 
the damages litigation receives a monthly bill with 
attorney's fees charged at an hourly rate and costs billed 
monthly. The bills will have any privileged information 
redacted. If there is a dispute about a bill that cannot be 
resolved, it will be submitted to a mediator for resolution. 
2. 
If that is too open-ended for Mr. Epstein, do the 
hourly/monthly billing until Bert has had a chance to confer 
with all of the girls to determine how many want him to 
represent them. Once it is known how many girls will be 
represented by Bert; and maybe who those girls are, there 
can be a more educated discussion about estimated fees and 
costs. 
Just some food for thought. I will be out of the office tomorrow, 
but I will be reachable by cell phone. I will make sure Bert is 
available and confirm the time with you. 
A. 
Assistant U.S. Attorney 
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d 
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
DELIVERY BY ELECTRONIC MAIL 
Jay P. Lefkowitz, Esq. 
Kirkland & Ellis LLP 
Citigroup Center 
New York, New York 10022-4675 
Re: 
Jeffrey Epstein 
Dear Jay: 
300 S. Australian Ave, Ste 400 
West Palm Beach, FL 33401 
Facsimile: 
December 13, 2007 
I am writing not to respond to your asserted "policy concerns" regarding Mr. Epstein's Non-
Prosecution Agreement, which will be addressed by the United States Attorney, but the time has 
come for me to respond to the ever-increasing attacks on my role in the investigation and 
negotiations. 
It is an understatement to say that I am surprised by your allegations regarding my role 
because I thought that we had worked very well together in resolving this dispute. I also am 
surprised because I feel that I bent over backwards to keep in mind the effect that the agreement 
would have on Mr. Epstein and to make sure that you (and he) understood the repercussions of the 
agreement. For example, I brought to your attention that one potential plea could result in no gain 
time for your client; I corrected one of your calculations of the Sentencing Guidelines that would 
have resulted in Mr. Epstein spending far more time in prison than you projected; I contacted the 
Bureau of Prisons to see whether Mr. Epstein would be eligible for the prison camp that you desired; 
and I told you my suspicions about the source of the press "leak" and suggested ways to avoid the 
press. Importantly, I continued to work with you in a professional manner even after I learned that 
you had been proceeding in bad faith for several weeks — thinking that I had incorrectly concluded 
that solicitation of minors to engage in prostitution was a registrable offense and that you would 
"fool" our Office into letting Mr. Epstein plead to a non-registrable offense. Even now, when it is 
clear that neither you nor your client ever intended to abide by the terms of the agreement that he 
signed, I have never alleged misconduct on your part. 
The first allegation that you raise is that I "assiduously" hid from you the fact that Bert 
Ocariz is a friend of my boyfriend and that I have a "longstanding relationship" with Mr. Ocariz. 
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• 
• 
JAY P. LEFKOW1TZ, ESQ. 
DECEMBER 13,2007 
PAGE 2 OF S 
I informed you that I selected Mr. Ocariz because he was a friend and classmate of two people 
whom I respected, and that I had never met or spoken with Mr. Ocariz prior to contacting him about 
this case. All of those facts are true. I still have never met Mr. Ocariz, and, at the time that he and 
I spoke about this case, he did not know about my relationship with his friend. You suggest that 
should have explicitly informed you that one of the referrals came from my "boyfriend" rather than 
simply a "friend," which is the term I used, but it is not my nature to discuss my personal 
relationships with opposing counsel. Your attacks on me and on the victims establish why I wanted 
to find someone whom I could trust with safeguarding the victims' best interests in the face of 
intense pressure from an unlimited number of highly skilled and well paid attorneys. Mr. Ocariz 
was that person. 
One of your letters suggests a business relationship between Mr. Ocariz and my boyfriend. 
This is patently untrue and neither my boyfriend nor I would have received any financial benefit 
from Mr. Ocariz's appointment. Furthermore, after Mr. Ocariz learned more about Mr. Epstein's 
actions (as described below), he expressed a willingness to handle the case pro bono, with no 
financial benefit even to himself. Furthermore, you were given several other options to choose from, 
including the Podhurst firm, which was later selected by Judge 
. You rejected those other 
options. 
You also allege that I improperly disclosed information about the case to Mr. Ocariz. I 
provided Mr. Ocariz with a bare bones summary of the agreement's terms related to his appointment 
to help him decide whether the case was something he and his firm would be willing to undertake. 
I did not provide Mr. Ocariz with facts related to the investigation because they were confidential 
and instead recommended that he "Google" Mr. Epstein's name for background information. When 
Mr. Ocariz asked for additional information to assist his firm in addressing conflicts issues, I 
forwarded those questions to you, and you raised objections for the first time. I did not share any 
further information about Mr. Epstein or the case. Since Mr. Ocariz had been told that you 
concurred in his selection, out of professional courtesy, I informed Mr. Ocariz of the Office's 
decision to use a Special Master to make the selection and told him that the Office had made contact 
with Jude 
. We have had no further contact since then and I have never had contact with 
Judge 
I understand from you that Mr. Ocariz contacted Judge 
. You criticize his 
decision to do so, yet you feel that you and your co-counsel were entitled to contact Judge 
to 
by to "lobby" him to select someone to your liking, despite the fact that the Non-Prosecution 
Agreement vested the Office with the exclusive right to select the attorney representative. 
Another reason for my surprise about your allegations regarding misconduct related to the 
Section 2255 litigation is your earlier desire to have me perform the role of "facil itator" to convince 
the victims that the lawyer representative was selected by the Office to represent their interests alone 
and that the out-of-court settlement of their claims was in their best interests. You now state that 
doing the same things that you had asked me to do earlier is improper meddling in civil litigation. 
Much of your letter reiterates the challenges to Detective Rccarey's investigation that have 
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a 
JAY P. LEFKOWITZ, ESQ. 
DECEMBER 13, 2007 
PAGE 3 OF 5 
already been submitted to the Office on several occasions and you suggest that I have kept that 
information from those who reviewed the proposed indictment package. Contrary to your 
suggestion, those submissions were attached to and incorporated in the proposed indictment 
package, so your suggestion that I tried to hide something from the reviewers is false. I also take 
issue with the duplicity of stating that we must accept as true those parts of the Recarey reports and 
witness statements that you like and we must accept as false those parts that you do not like. You 
and your co-counsel also impressed upon me from the beginning the need to undertake an 
independent investigation. It seems inappropriate now to complain because our independent 
investigation uncovered facts that are unfavorable to your client. 
You complain that I "forced" your client and the State Attorney's Office to proceed on 
charges that they do not believe in, yet you do not want our Office to inform the State Attorney's 
Office of facts that su ort the additional char e nor do ou want any of the victims of that charge 
to contact Ms. 
or the Court. Ms. 
opinion may change if she knows the full 
scope of your client's actions. You and I spent several weeks trying to identify and put together a 
plea to federal charges that your client was willing to accept. Yet your letter now accuses me of 
"manufacturing" charges of obstruction of justice, making obscene phone calls, and violating child 
privacy laws. When Mr. Lourie told you that those charges would "embarrass the Office," he meant 
that the Office was unwilling to bend the facts to satisfy Mr. Epstein's desired prison sentence — a 
statement with which I agree. 
I hope that you understand how your accusations that I imposed "ultimatums" and "forced" 
you and your client to agree to unconscionable contract terms cannot square with the true facts of 
this case. As explained in letters from Messrs. MI and 
the indictment was postponed 
for more than five months to allow you and Mr. Epstein's o er attorneys to make presentations to 
the Office to convince the Office not to prosecute. Those presentations were unsuccessful. As you 
mention in your letter,l—a simple line AUSA — handled the primary negotiations for the Office, and 
conducted those negotiations with you, Ms. Sanchez, Mr. Lewis, and a host of other highly skilled 
and experienced practitioners. As you put it, your group has a "combined 250 years experience" to 
my fourteen. The agreement itself was signed by Mr. Epstein, Ms. Sanchez, and Mr. Lefcourt, 
whose experience speaks for itself. You and I spent hours negotiating the terms, including when to 
use "a" versus "the" and other minutiae. When ou and 1 could not reach a cement, you repeatedly 
went over my head, involving Messrs. Louric, 
and 
in the negotiations at 
various times. In any and all plea negotiations e e en ant understan s t at his options are to 
plead or to continue with the investigation and proceed to trial. Those were the same options that 
were proposed to Mr. Epstein, and they are not "persecution or intimidation tactics." Mr. Epstein 
chose to sign the agreement with the advice of a multitude of extremely noteworthy counsel. 
You also make much of the fact that the names of the victims were not released to Mr. 
Epstein prior to signing the Agreement. You never asked for such a term. During an earlier 
meeting, where Mr. Black was present, he raised the concern that you now voice. Mr. Black and 
I did not have a chance to discuss the issue, but I had already conceived of a way to resolve that 
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• 
JAY P. LEFKUWITZ, ESQ. 
DECEMBER 13,2007 
PAUL 4 or 5 
issue if it were raised during negotiations. As I stated, it was not, leading me to believe that it was 
not a matter of concern to the defense. Since the signing of the Non-Prosecution Agreement, the 
agents and I have vetted the list of victims more than once. In one instance, we decided to remove 
a name because, although the minor victim was touched inappropriately by Mr. Epstein, we decided 
that the link to a payment was insufficient to call it "prostitution." I have always remained open to 
a challenge to the list. so your suggestion that Mr. Epstein was forced to write a blank check is 
simply unfounded. 
Your last set of allegations relates to the investigation of the matter. For instance, you claim 
that some of the victims were informed of their right to collect damages prior to a thorough 
investigation of their allegations against Mr. Epstein. This also is false. None of the victims was 
informed of the right to sue under Section 2255 prior to the investigation of the claims. Three 
victims were notified shortly after the signing of the Non-Prosecution Agreement of the general 
terms of that Agreement. You raised objections to any victim notification, and no further 
notifications were done. Throughout this process you have seen that 1 have prepared this case as 
though it would proceed to trial. Notifying the witnesses of the possibility of damages claims prior 
to concluding the matter by plea or trial would only undermine my case. If my reassurances arc 
insufficient, the fact that not a single victim has threatened to sue Mr. Epstein should assure you of 
the integrity of the investigation.' 
'There are numerous other unfounded allegations in your letter about document demands, 
the money laundering investigation, contacting potential witnesses, speaking with the press. and the 
like. For the most part, these allegations have been raised and disproven earlier and need not he 
readdressed. However, with respect to the subpoena served upon the private investigator, contrary 
to your assertion, and as your co-counsel has already been told, 1 slid consult with the Justice 
Department riot to issuing the subpoena and I was told that because I was Laa subpoenaing an 
attorney's office ur an office physically located within an attorney's office, and because the business 
did private investigation work for individuals (rather than working exclusively for Mr. Black), I 
could issue a grand jury subpoena in the normal course, which is what I did. I also did not 
"threaten" the State Attorney's Office with a grand jury subpoena, as the correspondence with their 
grand jury coordinator makes perfectly clear. 
With regard to your allegation of my filing the 
'with the court knowing that the public could access it," I do not know to what you 
are referring. all documents related to the 
investigation have been filed tinder seal, and 
the 
has never been filed with the Court. 
If, in fact, you arc referring to the 
should have access to it except the Court and myself. Those documents are still in the Corm file 
only because you  have violated one of the terms of the Agreement by failing to - withdraw 
(Epstein's] pending motion to intervene and to quash certain 
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JAY P. LEFKOWI Z, ESQ. 
DECEMBER 13, 2007 
PAVE 5 OF 5 
With respect to 
I contacted her attorney — who was paid for by Mr. Epstein and 
was directed by counsel for Mr. Epstein to demand immunity — and asked only whether he still 
represented 
and if he wanted me to send the victim notification letter to him. He asked 
what the letter would say and I told him that the letter would be forthcoming in about a week and 
that I could not provide him with the terms. With respect to 
deltas as a victim, you 
again want us to accept as true only facts that are beneficial to your client and to reject as false 
anything detrimental to him. 
nark a number of statements that arc contradicted by 
documentary evidence and a review of her recorded statement shows her lack of credibility with 
respect to a number of statements. Based upon all of the evidence collected, 
s classified 
as a victim as defined by statute. Of course, that does not mean that 
considers herself 
a victim or that she would seek damages from Mr. Epstein. I believe that a number of the identified 
victims will not seek damages, but that does not negate their legal status as victims. 
I hope that you now understand that your accusations against myself and the agents are 
unfounded. In the future, I recommend that you address your accusations to me so that I can correct 
any misunderstandings bcforc you make false allegations to others in the Department. I hope that 
we can move forward with a professional resolution of this matter, whether that be by your client's 
adherence to the contract that he signed, or by virtue of a trial. 
a 
cc: 
Sincerely, 
United States Attorney 
By: 
slA 
Villa win 
A. 
Assistant United States Attorney 
U.S. Attorney 
Jeffrey 
First Assistant U.S. Attorney 
You also accuse me of "broaden[ing] the scope of the investigation without any foundation 
for doing so by adding charges of money laundering and violations u fa money transmitting business 
to the investigation." Again, I consulted with the Justice Department's Money Laundering Section 
about my analysis before expanding that scope. 'the duty attorney agreed with my analysis. 
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(USAFLS) 
From: 
Jeff (USAFLS) 
Sent: 
r 28, 2007 4:35 PM 
To: 
(USAFLS) 
Subject: 
w. pew  
Can u send Jay the proposed letter and redact the names? Thx, Jeff 
Sent from my BlackBerry Wireless Handheld 
Original Message  
Lefkowitz <lLefkowitz@kirkland.com> 
, Jeff (USAFLS) 
(USAFLS) 
Sent: Wed Nov 28 16:29:09 2007 
Subject: Re: Epstein 
Dear Jeff: 
I received your email yesterday and was a little surprised at the tone of 
your letter, given the fact that we spoke last week and had what I thought was a 
productive meeting. I was especially surprised given that your letter arrived on 
only the second day back to work after the Thanksgiving Holiday, and yet your 
demands regarding timing suggest that I have been sitting on my hands for days. 
You should know that the first time I learned about Judge 
selection of Podhurst and Josephsberg, and indeed the first time I ever eard 
their names, was in our meeting with you on Wednesday of last week. 
Nevertheless, I have now been able to confer with my client, and we have 
determined that the selection of Podhurst and Josephsberg are acceptable to us, 
reserving, of course, our previously stated objections to the manner in which you 
have interpreted the section 2255 portions of the Agreement. 
We do, however, strongly and emphatically object to your sending a letter 
to the alleged victims. Without a fair opportunity to review and the ability to 
make objections to this letter, it is completely unacceptable that you would send 
it without our consideration. Additionally, given that the US Attorney's office 
has made clear it cannot vouch for the claims of the victims, it would be 
incendiary and inappropriate for your Office to send such a letter. Indeed, 
because it is a certainty that any such letter would immediately be leaked to the 
press, your actions will only have the effect of injuring Mr. Epstein and 
promoting spurious civil litigation directed at him. We believe it is entirely 
unprecedented, and in any event, inappropriate for the Government to be the 
instigator of such lawsuits. 
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Finally, we disagree with your view that you are required to notify the 
alleged victims pursuant to the Justice for All Act of 2004. First, 18 USC 
section 2255, the relevant statute under the Non-Prosecution Agreement for the 
settlement of civil remedies, does not have any connection to the Justice for All 
Act. Section 2255 was enacted as part of a different statute. Second, the 
Justice for All Act refers to restitution, and section 2255 is not a restitution 
statute. It is a civil remedy. As you know, we had offered to provide a 
restitution fund for the alleged victims in this matter; however that option was 
rejected by your Office. Had that option been chosen, we would not object to 
your notifying the alleged victims at this point. At this juncture, however, we 
do not accept your contention that there is a requirement that the government 
notify the alleged victims of a potential civil remedy in this case. 
Accordingly, for all the reasons we have stated above, we respectfully --
and firmly -- object to your sending any letter whatsoever to the alleged victims 
in this matter. Furthermore, if a letter is to be sent to these individuals, we 
believe we should have a right to review and make objections to that submission 
prior to it being sent to any alleged victims. We also request that if your 
Office believes that it must send a letter to go to the alleged victims, who 
still have not been identified to us, it should happen only after Mr. Epstein has 
entered his plea. This letter should then come from the attorney representative, 
and not from the Government, to avoid any bias. 
As you know, Judge Starr has requested a meeting with Assistant Attorney 
General Fisher to address what we believe is the unprecedented nature of the 
section 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. 
Thanks very much, 
Jay 
Jeff (USAFL5)" • 
11/27/2007 01:55 PM 
To 
"lay Lefko
z" <JLefkowitz@kirkland.com> cc 
(USAFLS)" 
Epstein 
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DECLARATION OF 
1. My name is 
and I was born 
2. I was molested by Jeffrey Epstein as a minor on dozens of 
occasions in his mansion in Palm Beach, Florida from around 2002 
to 2005. I understand that evidence collected from Mr. Epstein's 
home showed conclusively that I was there as a minor, along with 
many other underage girls. Given how many girls Epstein was 
abusing, there could not have been any doubt in anyone's mind that 
had access to the testimonial and other evidence that Epstein 
molested me (and many others). 
3. I cooperated fully with the FBI while they investigated Epstein's 
illegal activities with minors. 
4. During the investigation, Epstein had investigators following and, 
harassing me. I continued to cooperate with the investigation 
despite this intimidation. 
5. In late 2007, FBI agents met in person with me. During this 
meeting, the agents explained that Epstein was also being charged 
in State court and may plea to state charges related to some of his 
other victims. I knew the State charges had nothing to do with me. 
During this meeting, the Agents did not explain that an agreement 
had already been signed that precluded any prosecution of Epstein 
for federal charges against me. I did not get the opportunity to 
meet or confer with the prosecuting attorneys about any potential 
federal deal that related to me or the crimes committed against me. 
6. My understanding of the agents' explanation was that the federal 
investigation would continue. I also understood that my own case 
would move forward towards prosecution of Epstein. 
7. Confirming my understanding, in about January 2008, I received a 
letter from the FBI that told me that "this case is currently under 
investigation. This can be a lengthy process and we request your 
continued patience while we conduct a thorough investigation." 
My understanding of this letter was that my case was still being 
investigated and the FBI and prosecutors wcrc moving forward on 
the Federal prosecution of Epstein for his crimes against me. 
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8. At this time, I was not told about any non-prosecution agreement 
or any potential resolution of the federal criminal investigation I 
was cooperating in. If I had been told about a non-prosecution 
agreement, I would have objected. 
9. Criminal prosecution of Epstein for crimes against me was 
extremely important to me. I wanted to be consulted by the 
prosecutors before any resolution. In light of the letter I had 
received, I had confidence that I would be contacted by the federal 
government before it reached any final resolution of the 
investigation into my case and that I would likely be needed to 
testify if the case went to trial, which I was willing and anxious to 
do. 
10. 
When I had not heard from the prosecuting attorney for a 
while, I met with attorney Brad Edwards wanting him to find out 
when Epstein was going to be federally charged and prosecuted for 
the crimes he committed against me and others. Epstein's 
investigators were harassing me, and that interfered with my life 
dramatically. My attorney, Mr. Edwards, was hired to make sure 
the prosecutor knew how eager I was to have Jeffrey Epstein 
prosecuted, and I understand that he did convey that to the 
prosecutors numerous times in around June 2008. 
11. 
At some point, I understood that Mr. Edwards was getting 
responses from the prosecutor that were making him suspicious of 
the motivations of the U.S. Attorney's Office. I then understood 
that Mr. Edwards' suspicions were that the prosecutors were 
conferring with Epstein and not with me and the other victims. 
12. 
I authorized Mr. Edwards to do anything possible to ensure 
that Epstein was prosecuted, and that I was able to meet with 
prosecutors and participate in the process. I agreed to file a lawsuit 
against the U.S. Attorney's Office to get them to speak with me 
about any possible case resolution or the terms and to answer 
questions about the case, and to generally treat me fairly, to notify 
me about any court hearing, and to otherwise enforce my rights as 
a crime victim. 
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13. 
Towards the end of June, 2008, I did not attend Jeffrey 
Epstein's guilty plea hearing in state court involving another 
victim of Epstein's abuse. I did not have reasonable notice of the 
hearing, and I did not have any reason to attend that hearing 
because no one had told me that this guilty plea was related to the 
FBI's investigation of Epstein's abuse of me. I had always 
understood generally that the State and Federal criminal systems 
were different and that one had nothing to do with the other. 
Based on what the FBI had been telling me, I thought they were 
still investigating my case. If I had been told that this plea had 
some connection to blocking the prosecution of my case, I would 
have attended and tried to object to the judge and prevent that plea 
from going forward. Many other victims would have done the 
same. I think that after hearing from me and some of the other 
girls who were abused by Epstein, a judge would not have allowed 
such a plea deal to go forward. It is my belief that the US 
Attorney's Office and Epstein's attorneys conspired to prevent my 
attendance at this hearing as well as the attendance of the many 
other victims. 
14. 
I learned about the existence of a secret non-prosecution 
agreement only in July 2008, after my lawyer had filed court 
pleadings trying to give me a chance to talk to prosecutors about 
my case. I would never have learned of that agreement if I had not 
authorized my attorney to sue the United States. Nobody would 
have. 
15. 
I wanted to cooperate in the prosecution more than anything 
else in my life; I was scared of Epstein; I was scared of what he 
had done to me and others, and of how he was continuing to harass 
me, and also what he could do to me and others. The criminal case 
against Epstein was my main focus in life. 
16. 
When I attended a court hearing with Mr. Edwards in federal 
court, I learned for the first time that my rights had been 
extinguished through a secret deal between the prosecutors and Mr. 
Epstein. I received no explanation about exactly how the deal 
occurred or about whether my rights were gone forever. The 
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Case 9:08-cv-80736-KAM Document 361-26 Entered on FLSD Docket 02/10/2016 Page 5 of 5 
prosecutors were, at that time, trying to even keep me from seeing 
a copy of the secret plea deal. I wanted to meet with the 
prosecutors and tell them why they should prosecute my case, but 
it became clear that without ever talking to me, they had bargained 
my case away. 
17. 
In about 2.(10 I had the chance to meet with the U.S. 
Attorney, Mr. 
I told him all about how T had been 
mistreated in the process. Mr. -seemed to be interested in 
this, hut nothing ever came of the meeting. And unfortunately it 
seems to me that Mr. 
office is continuing to try to block 
me and other girls from learning anything about the secret deal 
with Epstein or how our rights were violated, even though they 
know what they did was wrong. 
18. 
I later came to understand that crime victims in the federal 
system have the right to meaningfully confer with the prosecutor 
for the government in the case, which at least means to explain 
how my case would be concluded; the right to be heard at 
important hearings; and the right to be treated with "fairness." I 
strongly believe that the way I was treated was unfair and violated 
my rights. 
19. 
I think that the secret non-prosecution agreement should be 
declared illegal and that I should have the right to have crimes 
against me prosecuted by the U.S. Attorney's Office, and that Mr. 
Epstein should be treated the same as other defendants with less 
money and connections are treated for these crimes. 
20. 
I declare under penalty of perjury that the foregoing is true 
and correct to the best of my knowledge and belief. 
Executed this 
2P — 
, day of January, 2015. 
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EXHIBIT 
27 
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