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FBI VOL00009
EFTA00185206
310 sivua
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U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 Facsimile: January 24, 2007 DELIVERY BY HAND James L. Eisenberg, Esq. 250 S Australian Ave, Ste 704 West Palm Beach, FL 33401-5007 Re: Federal Grand Jury Subpoena Dear Jim: A new grand jury has been aneled and I have enclosed a new subpoena for . As I mentioned earlier, Ms. is not a target of this investigation and the United States seeks her testimony solely as, a victim/witness. During our last conversation regarding Ms. , you indicated that she was unwilling to speak with us pursuant to a Kastigar letter and that she also was unwilling to speak with.the grand jury and intends to invoke the Fifth Amendment if questioned. Please confer with her to confirm whether this remains her position. If it is, please advise in writing. Even if Ms. is inclined to invoke her Fifth Amendment rights, she must still appear pursuant to the subpoena so that I may ask her questions that would not require the invocation of the Fifth Amendment. If she still invokes, I intend to move to compel her answers. If you or your client is unavailable on February 6, 2007, please let me know of another Tuesday when you are available. I also am concerned about a potential conflict of interest in your representation of Ms. M . In case of future litigation regarding this issue, please provide me with information regarding who is paying (directly or indirectly) for your services on behalf of Ms. M, the scope of your representation and whether you are taking .direction on this matter from anyone other than Ms. If any formal or informal joint defense agreements exist, whether in writing or otherwise, please provide a copy of such agreements. If the agreement is purely oral, please provide a written summary of its terms. I! GOVERNMENT EXHIBIT 1 EFTA00185326
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JAMES EISENBERG, ESQ. • JANUARY 24, 2007 PAGE 2 I look forward to your response. Sincerely, R. Alexander Acosta By: Assistant United States Attorney EFTA00185327
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United States District Court SOUTHERN DISTRICT OF FLORIDA TO: SUBPOENA TO TESTIFY SUBPOENA FOR: PERSON X DOCUMENTS OR OBJECT[SJ YOU ARE HEREBY COMMANDED to appear and testify before theMofthe United States DiStrict Court at the place, date'and time Specified below. PLACE: United States District Courthouse 701 Clematis Street West Palm Beach, Florida 33401 ROOM: DATE AND TIME:. February 6, 2007 1:00pm* YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s): ANY AND ALL NOTES, LE HS YOU HAVE RECEIVED FROM JEFFREY EPSTEIN, • PRINTED OR DIGITAL, OF JEFFREY EPSTEIN, ANY AND ALL 13-MAILS, INSTANT MESSAGES, CHATS, TEXT MESSAGES, VOICEMAILS; OR TELEPHONE MESSAGES THAT YOU HAVE SENT TO AND/OR RECEIVED FROM JEFFREY EPSTEIN, *Please coordinate your compliance with this subpoena and confirm the date and time , and location of our appearance with Special Agent Federal Bureau of Investigation, Telephone: This su bpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf of the court. This subpoena is issued upon application of the United States of 'Ca Name Address and Phone Ndmber of Assistant U.S. Attorney Assistant U.S. Attorney 500 So. Australian Avenue, Suite 400 West Palm Beach FL 33401-6235 x3047 Fax: *If not applicable, enter "none" To be wed la Neu arAO110 FORM ORD-2/7 JAN.86 EFTA00185328
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EISENBERG & FOUTS, P.A. Attorneys At Law JAMES L. EISENBERG Florida Bar Board Certified Criminal Trial Lawyer National Board Of Trial Advocacy Certified Criminal Trial Advocate KAI LI ALOE FOUTS One Marini°, Centre, Suite 704, 250 Australian Avenue South, West Palm Beach, 171,33401 Fax: February 1, 2007 Asst. U.S. Attorney 500 South Australian Avenue, Suite 400 West Palm Beach, FL 33401 Re: Grand Jury Subpoena for Dear M, I received your letter dated January 24, 2007 with regard to . I must admit I forced myself to wait several days to respond inmtder to "cool. off' and not say anything I would regret later. 116W thatiime has passed; allow ma to respond appropriately. . • . . • d. 1. • If you want to force Ms.• M, a single mother, to come to the grand jury room to personally invoke her Fifth Amendment rights, she will be there: That does remain her position. My only request is that syr it.rovide a babysitter service for her child. I will be there, but I am not paid to babysit and Ms. should not have to someone. It is this type of attitude, that your office refuses to accept the fact that it is Ms. decision not to cooperate with the government that upsets her. Your office fails to recognize that merely coming to court is a problem for a single mother like Ms. and, under these circumstances, appears to be a waste of time at best and, in her mind, personal harassment. 2. Rest assured that there is no conflict of interest in my representation of Ms. . In this case I have always been asked and always will exercise independent judgment to follow my client's independent will. The remainder of your questions as to this matter are really none of the Government's business. 3. I will share with you that one of the reasons for our firm position that Ms. will invoke her Fifth Amendment right and choose not to voluntarily cooperate with the Government is our concern that the Government is not exercising independent judgment in this case. The hiStory of this case his been in the:newspapers., The case is being prosecuted in State court. Despite the state emit pinsecution; the Town of Palm Beach Police Chief went on what can only be • r GOVERNMENT EXHIBIT 1 2 EFTA00185329
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EMI , Asst. U.S. Attorney February 1, 2007 Page Two described as a public rampage in the newspaper when the case was not prosecuted to his liking that reminded me of a small child having a public temper tantrum. In my thirty years of experience, I have never seen a law enforcement officer like this publicly make what appeared to be a political case in the newspaper for a prosecution and publicly criticize anyone who got in his way, including the elected State Attorney. This resulted in a federal investigation on a topic no one remembers the Federal Government ever being interested in prosecuting before. Although I am certain that you personally have not had your decision-making process compromised, the appearance that your office is being influenced by the Town of Palm Beach Police Chief's agenda is very real. Under these drcumstance4 don't see how any lawyer; could advise• any client to voluntarily cooperate. Of special contact is that the Town of Palm Beach Police have promoted prosecuting at least one of the girls who allegedly gave massages. One final thought. My client and my fear that Ms. could be prosecuted is enhanced by the demand for the personal appearance made in your letter. Your initial Kastiger letter fell far short of granting the functional equivalent of DOJ immunity. Several months ago I was given the distinct impression through our conversations that you were going to obtain DOS immunity for Ms. Now the government is changing course for no apparent reason. This leads to speculation that the only reason for the turnabout is that prosecution in either state or federal court is being considered by someone. None of the above directed at you personally. I want to repeat that you have always treated us with respect. jvlaybe ur, office should advise the Town Police Chief to act in a similar fashion. EFTA00185330
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U.S. Department of Justice United States Attorney Southern District of Florida A. 500 South Australian Ave, Suite 400 West Palm Beach, Florida 33401 Facsimile FACSIMILE COVER SHEET TO: JIM EISENBERG, ESQ. DATE: # OF PAGES: PHONE NO. RE: FAX NO. February 5, 2007 FROM: PHONE NO. ASSISTANT U.S. ATTORNEY COMMENTS : 141 Jilt) — So e- tike cY)44/ti_ bAof -50lArd- a _abet tr have_ Bar's av~S cifignir afrug ocryteLa / GOVERNMENT EXHIBIT EFTA00185331
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U.S. Department of Justice United States Attorney Southern District of Florida DELIVERY BY HAND Ms. do James L. Eisenberg, Esq. 250 S Australian Ave, Ste 704 West Palm Beach, FL 33401-5007 Re: Grand Jury Testimony of Dear Ms. 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 Facsimile: February 5, 2007 This letter confirms the understanding between yourself and the United States Attorneys Office for the Southern District of Florida. You have represented that you will truthfully answer questions of the federal government in its investigation of the procurement of prostitutes, amongst others. You will supply complete and truthful information to the attorneys and law enforcement officers of the federal government and to any Federal Grand Jury which may conduct an investigation, as well as in any other proceeding related to or growing out of this investigation. The obligation of truthful disclosure includes your obligation to provide the attorneys and law enforcement officers of the federal government with any documents, records or other tangible evidence within your custody or control relating to the matters about which you are questioned. You will neither attempt to protect any person or entity through false information or omission, nor falsely implicate any person or enfity. No statements provided by you on this date in this matter pursuant to this agreement will be offered into evidence in any criminal case against you, except during a prosecution for perjury and/or diving a false statement. Hoirever, if it is determined that you have materially violated any provision of this agreement, all statements made by you shall be admissible in evidence against you in any proceeding. The federal government remains free to use information derived from the grand jury testimony directly or indirectly for the purpose of obtaining leads to other evidence, which may be used against you. You expressly waive any right to claim that such evidence should not be introduced because it was obtained as a result of the grand jury testimony. Furthermore, the federal government may use statements made in the grand jury testimony and all evidence derived directly or indirectly therefrom for the purpose of cross-examination, if you testify at any trial or if you EFTA00185332
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MS. FEBRUARY 5, 2007 PAGE 2 suborn testimony that contradicts your prior statements and testimony. No additional promises, agreements and conditions have been entered into other than those set forth in this letter and none will be entered into unless in writing and signed by all parties. Sincerely, R. Alexander Acosta United States Attorney BY Assistant United States Attorney I have read this agreement and discussed it with my attorney, and I hereby acknowledge that it fully sets forth my agreement with the office of the United States Attorney for the Southern District of Florida. I state that there have been no additional promises, agreements or representations made to me by any officials of the United States in connection with this matter. Dated: February 2007 West Palm Beach, Florida Witnessed by: James L. Ms,. Attorney for EFTA00185333
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U.S. Department of Justice
United States Attorney
Southern District of Florida
500 South Australian Ave., Suite 400
West Palm Beach, FL 33401
Facsimile:
February 5, 2007
DELIVERY BY HAND
James L. Eisenberg, Esq.
250 S Australian Ave, Ste 704
West Palm Beach, FL 33401-5007
Re:
n
Dear Mr. Eisenberg:
I am writing to clarify the ground rules for the interview with your client
("your client"), to occur February
, 2007.
As I mentioned earlier, Ms.
is not a target or subject of this investigation, but
instead is being interviewed solely as a victim/witness. However, to address your concern
about criminal exposure, if your client complies with every provision of this agreement, then
the United States Attorney's Office for the Southern District of Florida ("this Office") will
treat all statements made by your client during the interview as statements made pursuant to
Rule 11(f) of the Federal Rules of Criminal Procedure. This is not a grant of immunity,
which can be given only with approval of the Justice Department, but protects your client
from having the statements made by her during the interview from being used against her
directly. To guard against any misunderstandings concerning the interview of your client,
this letter sets forth the terms of this agreement.
Your client agrees to be fully interviewed, that is, to provide information concerning
your client's laniviledge of, and participation in criminal activity, including but not limited
to the procurement of prostitutes. The protection of this letter applies to an interview that
will be conducted by this Office, Special Agents of the Federal Bureau of Investigation, and
any other federal law enforcement agency this Office may require. Under this agreement,
no information disclosed by your client during the interview will be offered in evidence
against her in any criminal or civil proceeding, provided that your client complies with this
agreement and that the information your client furnishes is truthful, complete, and accurate.
If, however, your client gives materially false, incomplete, or misleading information,
EFTA00185334
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JAMES L. EisENBERo, ESQ. RE: FEBRUARY 2, 2007 PAGE 2 then this Office may use such information in any matter or proceeding and your client is subject to prosecution for perjury, obstruction of justice, and making false statements to government agencies. Any such prosecution may be based upon information provided by your client during the course of the interview, and such information, including your client's statements, will be admissible against your client in any grand jury or other proceeding. The government also may use statements made by your client in the interview and all evidence derived directly or indirectly therefrom for the purpose of impeachment or cross-examination if she testifies at any trial or hearing, and/or in any rebuttal case against your client in a criminal trial in which she is a defendant or a witness. These provisions are necessary to ensure that your client does not make or offer any false representation or statement in any proceeding or to a government agency or commit perjury during any testimony. Your client further agrees that attorneys for the United States may be present at the interview, and agrees not to seek disqualification of any such government attorney from any proceeding or trial because of their participation at the interview. The entire agreement between the United States and your client is set forth in this letter. No additional promises, agreements, or conditions have been entered into and none will be entered into unless in writing and signed by all parties. If the foregoing accurately reflects the understanding and agreement between this Office and your client, it is requested that you and your client execute this letter as provided below. Sincerely, R. Alexander Acosta United States Attorney By: Assistant United States Attorney I have received this letter from my attorney, James L. Eisenberg, Esquire, have read it and discussed it with my attorney, and I hereby acknowledge that it fully sets forth my understanding and agreement with the Office of the United States Attorney for the Southern EFTA00185335
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JAMES L. EISENBERG, ESQ. EB: FEBRUARY 2, 2007 PAGE 3 District of Florida. I state that there have been no additional promises or representations made to me by any official of the United States Government or by my attorney in connection with this matter. Dated: Witnessed by: James L. Eisenberg, Esquire EFTA00185336
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U.S. Department of Justice Authorization for Reimbursement of Unusual Expenses of Fact. Witnesses Request for Unusual Expense(s) of Fact Witness (For United States Attorney's Office Use Only) Control # 1. Case Name tiDia 2. Court Docket Number 3 i A -4. L Wesi- ation of Court Floc ding PoIni 5. Contact Person 6. Contact Person Number 7. Witness Name & Address, Phone #, SSN 8. Vendor Name & Address, Phone #, TIN/SSN 9. Pa ment to be made to: 10. Receipt/Invoice Is: 11. Type of Unusual Expense: Medically Necessary Item (Attached Supporting Statement) laDependent Care Excess Lodging/Per Diem Travel & Transportation Pretrial Conference Waiver Other 12. Explanation: VAL (A)190,44 h t4 a n 0.014 hitt "II) OYU. (AA CC CA:tia Go/AA,t.e. ski. tecithicoLetel- tfta k i l fhe 40Mtd- • 13. Start Date of Service (MO/DANR) ZIG /0 7 14. End Date of Service (MO/DANR) 2-/‘ A) 7 15. Amount 16. Justification: 17. I hereby certify that the expenses and services listed on this document are appropriate and are within the Federal laws and regulations. I fully understand that I can be held personally liable or be subject to disciplinary action for improperly using government funds or services that exceed delegated authority or that violate Federal laws or regulations. Signature of Requesting AUSA Date 18. Name & Title of Approving Official 19. Date (MO/DA/YR) 20. Signature of Approving Official GOVERNMENT EXHIBIT EFTA00185337
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EISENBERG & FOUTS, P.A. Attorneys At Law JAMES L. EISENBERG Florida Bar Board Certified Criminal Trial Lawyer National Board Of Trial Advocacy Certified Criminal Trial Advocate KM LI ALOE POUTS One Cleariake Centre,Suite 704,250 Australian Avenue Soutb,WestPalm Beach,FL33401 February 12, 2007 Asst. U.S. Attorney 500 South Australian Avenue, Suite 400 West Palm Beach, FL 33401 Re: Grand Jury Subpoena for Dear MO AsakvayS, it was;a pleasure speaking to you the other day. Pursuant to. our telephone conference I am writing this letter to.proffer my:concerns for should she testify without immunity before a federal grandjurt.:Tberefore, allowme to reiterate at Ms.:Ivallerwill refuse to voluntarily cooperate with the federal government She has a good faith basis for her position under the Fifth Amendment to the United States. Constitution. We, of course, do not live or work in a vacuum. We have read many inflammatory remarks the Town of Palm Beach Police Chief has made to the media about the state court's handling of the Jeffrey Epstein investigation. The police chiefs remarks frighten both myself and my client. I am aware that the town police have prepared documents to charge at least one of Mr. Epstein's lady friends in state court. If they can push to have one lady charged I remain unconvinced that they do not have the ability or political clout to push to have other ladies such as Ms. charged. The proffered facts that raise my concerns are being provided via this proffer letter. Pursuant to our telephone conference agreement, this letter and its contents cannot be used against Mr. Ms. is not at all certain of dates. She does remember meeting Mr. Epstein about three years ago. She is not certain of her age, it could have been when she was sixteen. A girlfriend asked her if she wanted a job giving massages. Ms. agreed because she had knowledge of massages through her mother, who was a masseuse. Ms went tolvtrEpstein?s house via taxi. Ms. girlfiiendinstnieted Ms: that, if asked,. she had to tell Mr.Epstein that she - was eighteen. years old. The.II. was nineteen years old and looked old forher age, so passing for eighteen was not a problem. At [ ! GOVERNMENT I EXHIBIT i 5 EFTA00185338
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the home Ms. net Mr. Epstein and later gave him a massage. The friend had told Ms. to give the message topless. Mr. Epstein told that if she were at all uncomfortable. topless, not to do it and it was not a requirement o employment as a masseuse. Ms. ever touched Mr. Epstein in a sexual way and Mr. Epstein never touched Ms. t all. one point, Mr. Epstein did ask Ms. =her age. Ms. =insisted that she was et teen years old. Ms. =continuqd to see Mr. Epstein over time and massages were given in a similar fashion. She was later asked if her friends wanted to work in a similar way and she asked some girls who did give Mr. Epstein massages. Ms. was never asked to bring girls of any age to Mr. Epstein's home. When she did have her friends ome over, she instructed all of them that if asked, they insist that they were eighteen years old. She is not certain at all of any of these girls' real ages. In summary, our concern is that if the government believes that Mr. Epstein committed some federal offense, Meals. =could he considered a co-conspirator. We believe no crime was committed. The Fifth Amendment was not intended to protect the guilty, however. It was enacted to protect citiwms who fear prosecution notwithstanding their innocence. Our fear of any prosecution, especially ' f the Town police chiefs public remarks, is clearly in good faith. EFTA00185339
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA n> 0 0 ....-.1 • :!. Iv, Z., on-: :1•• Ci NORTHERN (WEST PALM BEACH) DIVISION O ; ; - 0 7.0..0 -..: I FGJ 07-103(WPB) r- • • CI I • -O I IN RE: GRAND JURY PROCEEDINGS SEALED ORDER On Application of the United States Attorney for the Southern District of Florida, and it appearing to the satisfaction of the Court: 1. That has been called to testify and to provide other information before the United States District Court for the Southern District of Florida, including a Grand Jury impanelled therein; and 2. That in the judgment of the said United States Attorney, has refused to testify and provide other information on the basis of her privilege against self-incrimination; and 3. That in the judgment of the said United States Attorney, the testimony and other information from may be necessary to the public interest; and 4. That the aforesaid Application has been made with the approval of the Assistant Attorney General in charge of the Criminal Division of the Department of Justice or a duly designated Acting Assistant Attorney General, pursuant to the authority vested in him by Title 18, United States Code, Section 6003, and Title 28, Code of Federal Regulations, Sections 0.175 and 0.132(e). NOW, THEREFORE, it is ordered pursuant to Title 18, United States Code, Section 6002, that give testimony and provide other information which she refuses to give or to GOVERNMENT EXHIBIT EFTA00185340
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provide on the basis of her privilege against self-incrimination, as to all matters about which she may be interrogated before said United States District Court, including a Grand Jury impaneled therein, as well as any subsequent proceeding or trial. However, no testimony or other information compelled under this Order (or any information directly or indirectly derived from such testimony or other information) may be used against in any criminal case, except a prosecution for perjury, giving a false statement, or otherwise failing to comply with this Order. IT IS FURTHER ORDERED the this Order shall be SEALED in accordance with Fed. R. Crim. P. 6(e)(6), except that a copy of this Order shall be provided to counsel for the United States, who may disclose the existence of the Order to members of the Grand Jury, to the witness, to counsel for the witness, and to law enforcement officers engaged in the investigation pending before the Grand Jury. Those persons may review the Order, but may not retain a copy of the Order, nor may they disclose the existence of the Order to any others. cc: DONE and ORDERED this AUSA day of April, 2007 t Palm Beach, Florida. 2 DONALD M. MIDDLEBROOKS UNITED STATES DISTRICT JUDGE EFTA00185341
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United States District Court SOUTHERN DISTRICT OF FLORIDA TO: SUBPOENA TO TESTIFY BEFORE GRAND JURY FGJ 07-103(WPB)-Tues./No. OLY-13/2 SUBPOENA FOR: PERSON et DOCUMENTS OR OBJECTS] YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District Court at the place, date'and time Specified below. 'PLACE: United States District Courthouse 701 Clematis Street West Palm Beach, Florida 33401 ROOM: Grand Jury Room • DATE AND TIME:, February 6, 2007 1:00pm" YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s): ANY AND ALL NOTES, L RS CARDS GIFTS PAYMENTS AND PHO RAPHS YOU HAVE RECEIVED FROM JEFFREY EPSTEIN, PRINTED OR DIOITAL, OF JEFFREY EPSTEIN, AND • • ANY/a ntRTHER ANY AND ALL E-MA1LS, INSTANT MESSAGES, CHATS, TEXT MESSAGES, VOICEMAILS .EP MESSAGES THAT YOU HAVE SENT TO t hiliffa RECEIVED FROM JEFFRECY EPSTEIN, AND/OR • *Please coordinate your compliance with this sub oena and confirm the date and time , and location of our a earance with Special Agent Federal Bureau of Investigation, Telephone: This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf of the court. This subpoena is issued upon application of the United States of America •If not applicable, enter"none. To Fc us< Name Address and Phone Number of Assistant U.S. Attorney Assistant U.S. Attorney 500 So. Australian Avenue, Suite 400 West Palm Beach. FL 33401-6235 • Tel: Fax: lieu of AO! 30 FORM ORD-227 IAN.86 EFTA00185342
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Respondent's Exhibit A Case No. 08-80736-CIV-MARFtA UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 AND JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. DECLARATION E. declares as follows: I. I am a Special Agent in the Federal Bureau of Investigation (FBI) and have been so employed since 1997. I am currently assigned to the West Palm Beach office of the FBI Miami Field Division. 2. In 2006, I was assigned as the case agent in an investigation into allegations that Jeffrey Epstein had engaged in unlawful sexual contact with girls under the age of 18. The case was called Operation Leap Year. FBI Special Agent and I conducted most of the investigation, and worked with the U.S. Attorney's Office, on Operation Leap Year. 3. Over the course of the investigation, the FBI obtained hundreds of documents through the use of grand jury subpoenas, public records, and law enforcement databases. FBI agents conducted interviews with females believed to have been sexually abused by Mr. Epstein and underage at the time of the assault, as well as other individuals who might have relevant information. The interviews are memorialized and prepared by the interviewing FBI agent. The interview reports of the young women interviewed contain highly personal and intimate details, EFTA00185343
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Respondent's Exhibit A Case No. 08-80736-CIV-MARRA which would cause embarrassment to the young women if disclosed to third parties. For those interviewed who did not reveal any intimate details, many will be displeased if their cooperation with the FBI is made public. In my experience, individuals are reluctant to cooperate with law enforcement for fear of being singled out, harassixl, embarrassed, or subjected to retaliation if their cooperation is disclosed to third parties. 4. The case file on Operation Leap Year also contains FBI agents' analysis of information obtained during the course of the investigation. These written analyses of the evidence reveal potential theories of criminal liability based on the evidence uncovered in the case. Information contained within FBI investigative files can also reveal sensitive FBI investigative and operational methods, procedures and techniques. While it is publically known that the FBI conducts investigations into the type of criminal wrongdoing committed by Jeffrey Epstein, disclosing the precise details of the sensitive methods, procedures and techniques employed during an investigation might compromise their future effective use. It is critical that the FBI's investigative tools remain confidential to both retain an element of surprise and to prevent countermeasures to such tools from being employed by targets and suspects. 5. During the course of Operation Leap Ycar, I interviewed and heard the personal account of sexual abuse committed by Mr. Epstein on the young women. They suffered emotionally, and some were referred by the FBI to mental health professionals because of the psychologically harmed caused by Mr. Epstein. In at least one instance, mental health professionals were involved to help prevent one young woman from physically harming herself. 6. The disclosure of personal information, contained in the FBI investigative file, to third parties would not merely cause further embarrassment but could result in additional psychological trauma, disruption of family relationships, disruption of professional careers and 2 EFTA00185344
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Respondent's Exhibit A Case No. 08-80736-CN-IAARRA possible public release of personal information. 7. Operation Leap Year remains an open case. 8. I declare under penalty of perjury that the foregoing is true and correct. EXECUTED on September 3, 2013. pedal gent Federal Bureau of Investigation West Palm Beach, Florida 3 EFTA00185345