EFTA00190318

Terms of the Agreement: 
1. 
Epstein shall plead guilty (not nob contendere) to the Indictment as 
currently pending against him in the 15th Judicial Circuit in and for 
Palm Beach County (Case No. 2006-cf-009495AXXXMB) charging 
one (1) count of solicitation of prostitution, in violation of Fl. Stat. § 
796.07. In addition, Epstein shall plead guilty to an Information filed 
by the State Attorney's Office charging Epstein with an offense that 
requires him to register as a sex offender, that is, the solicitation of 
minors to engage in prostitution, in violation ofFlorida Statutes Section 
796.03; 
2. 
Epstein shall make a binding recommendation that the Court impose a 
thirty (30) month sentence to be divided as follows: 
(a) 
(b) 
Epstein shall be sentenced to consecutive terms of twelve (12) 
months and six (6) months in county jail for all charges, without 
any opportunity for withholding adjudication or sentencing, and 
without probation or community control in lieu of 
imprisonment; and 
Epstein shall be sentenced to a term of twelve (12) months of 
community control consecutive to his two terms in county jail 
as described in Term 2(a), supra. 
3. 
This agreement is contingent upon a Judge of the 15th Judicial Circuit 
accepting and executing the sentence agreed upon between the State 
Attorney's Office and Epstein, the details of which are set forth in this 
agreement. 
4. 
The terms contained in paragraphs 1 and 2, supra, do not foreclose 
Epstein and the State Attorney's Office from agreeing to recommend 
any additional charge(s) or any additional term(s) of probation and/or 
incarceration. 
5. 
Epstein shall waive all challenges to the Information filed by the State 
Attorney's Office and shall waive the right to appeal his conviction and 
sentence, except a sentence that exceeds what is set forth in paragraph 
(2), supra. 
6. 
Epstein shall provide to the U.S. Attorney's Office copies of all 
Page 3 of 7 
EFTA00190618

proposed agreements with the State Attorney's Office prior to entering 
into those agreements. 
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 arc 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 
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. 
11. 
Epstein shall use his best efforts to enter his guilty plea and be 
Page 4 of 7 
EFTA00190619

sentenced not later than October 26, 2007. The United States has no 
objection to Epstein self-reporting to begin serving his sentence not 
later than January 4, 2008. 
12. 
Epstein agrees that he will not be afforded any benefits with respect to 
gain time, other than the rights, opportunities, and benefits as any other 
inmate, including but not limited to, eligibility for gain time credit 
based on standard rules and regulations that apply in the State of 
Florida. At the United States' request, Epstein agrees to provide an 
accounting of the gain time he earned during his period of 
incarceration. 
13. 
The parties anticipate that this agreement will not be made part of any 
public record. If the United States receives a Freedom of Information 
Act request or any compulsory process commanding the disclosure of 
the agreement, it will provide notice to Epstein before making that 
disclosure. 
Epstein understands that the United States Attorney has no authority to require the 
State Attorney's Office to abide by any terms of this agreement. Epstein understands that 
it is his obligation to undertake discussions with the State Attorney's Office and to use his 
best efforts to ensure compliance with these procedures, which compliance will be necessary 
to satisfy the United States' interest. Epstein also understands that it is his obligation to use 
his best efforts to convince the Judge of the 15th Judicial Circuit to accept Epstein's binding 
recommendation regarding the sentence to be imposed, and understands that the failure to 
do so will be a breach of the agreement. 
In consideration of Epstein's agreement to plead guilty and to provide compensation 
in the manner described above, if Epstein successfully fulfills all of the terms and conditions 
of this agreement, the United States also agrees that it will not institute any criminal charges 
against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, 
Adriana Ross, Lesley Groff, or Nadia Marcinkova. Further, upon execution of this 
agreement and a plea agreement with the State Attorney's Office, the federal Grand Jury 
investigation will be suspended, and all pending federal Grand Jury subpoenas will be held 
in abeyance unless and until the defendant violates any term of this agreement. The 
defendant likewise agrees to withdraw his pending motion to intervene and to quash certain 
grand jury subpoenas. Both parties agree to maintain their evidence, specifically evidence 
requested by or directly related to the grand jury subpoenas that have been issued, and 
including certain computer equipment, inviolate until all of the terms of this agreement have 
been satisfied. Upon the successful completion of the terms of this agreement, all 
outstanding grand jury subpoenas shall be deemed withdrawn. 
Page 5 of 7 
EFTA00190620

By signing this agreement, Epstein asserts and certifies that each of these terms is 
material to this agreement and is supported by independent consideration and that a breach 
of any one of these conditions allows the United States to elect to terminate the agreement 
and to investigate and prosecute Epstein and any other individual or entity for any and all 
federal offenses. 
By signing this agreement, Epstein asserts and certifies that he is aware of the fact that 
the Sixth Amendment to the Constitution of the United States provides that in all criminal 
prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further 
is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court 
may dismiss an indictment, information, or complaint for unnecessary delay in presenting 
a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein 
hereby requests that the United States Attorney for the Southern District of Florida defer such 
prosecution. Epstein agrees and consents that any delay from the date of this Agreement to 
the date of initiation of prosecution, as provided for in the terms expressed herein, shall be 
deemed to be a necessary delay at his own request, and he hereby waives any defense to such 
prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of 
the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the 
United States to a speedy trial or to bar the prosecution by reason of the running of the statute 
of limitations for a period of months equal to the period between the signing of this 
agreement and the breach of this agreement as to those offenses that were the subject of the 
grand jury's investigation. Epstein further asserts and certifies that he understands that the 
Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all 
felonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees 
and consents that, if a prosecution against him is instituted for any offense that was the 
subject of the grand jury's investigation, it may be by way of an Information signed and filed 
by the United States Attorney, and hereby waives his right to be indicted by a grand jury as 
to any such offense. 
//I 
Page 6 of 7 
EFTA00190621

By signing this agreement, Epstein asserts and certifies that the above has been read 
and explained to him. Epstein hereby states that he understands the conditions of this Non-
Prosecution Agreement and agrees to comply with them. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated: 
 
By: 
Dated:  ya,__
Dated: 
Dated: 
A. MARIE VILLAFARA 
ASSISTANT U.S. ATTORNEY 
GERALD LEFCOURT, ESQ. 
COUNSEL TO JEFFREY EPSTEIN 
LILLY ANN SANCHEZ, ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
Page 7 of 7 
EFTA00190622

By signing this agreement, Epstein asserts and certifies that the above has been read 
and explained to him. Epstein hereby states that he understands the conditions of this Non-
Prosecution Agreement and agrees to comply with them. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated: 
 
By: 
Dated: 
Dated:  7 it 9.10 7 
Dated: 
A. MARIE VILLAFARA 
ASSISTANT U.S. ATTORNEY 
JEFFREY EPSTEIN 
RALD'LEFCOIDR 
ESQ. 
OUNSEL TO .M.FER Y EPSTEIN 
LILLY ANN SANCHEZ, ESQ. 
ATTORNEY FOR. JEFFREY EPSTEIN 
Page 7 of 7 
EFTA00190623

By signing this agreement, Epstein asserts and certifies that the above has been read 
and explained to him. Epstein hereby states that he understands the conditions of this Non-
Prosecution Agreement and agrees to comply with than. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated: 
A. MARIE VILLAFAIIA 
ASSISTANT U.S. ATTORNEY 
Dated: 
JEFFREY EPSTEIN 
Dated: 
GERALD LEFCOURT, ESQ. 
COUNSEL TO JEFFREY EPSTEIN 
Dated:q—A y 0? —
SAi 
, ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
Page 7 of 7 
EFTA00190624

IN RE: 
INVESTIGATION OF 
JEFFREY EPSTEIN 
ADDENDUM TO THE NON-PROSECUTION AGREEMENT 
IT APPEARING that the parties seek to clarify certain provisions of page 4, paragraph 7 
of the Non-Prosecution Agreement (hereinafter "paragraph 7"), that agreement is modified as 
follows: 
7A. 
The United States has the right to assign to an independent third-party the responsibility 
for consulting with and, subject to the good faith approval of Epstein's counsel, selecting 
the attorney representative for the individuals identified under the Agreement. If the 
United States elects to assign this responsibility to an independent third-party, both the 
United States and Epstein retain the right to make good faith objections to the attorney 
representative suggested by the independent third-party prior to the final designation of 
the attorney representative. 
7B. 
The parties will jointly prepare a short written submission to the independent third-party 
regarding the role of the attorney representative and regarding Epstein's Agreement to 
pay such attorney representative his or her regular customary hourly rate for representing 
such victims subject to the provisions of paragraph C, infra. 
7C. 
Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the attorney 
representative selected by the independent third party. This provision, however, shall not 
obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus, 
if after consideration of potential settlements, an attorney representative elects to file a 
contested lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested 
remedy, the paragraph 7 obligation of the Agreement to pay the costs of the attorney 
representative, as opposed to any statutory or other obligations to pay reasonable 
attorneys fees and costs such as those contained in s 2255 to bear the costs of the attorney 
representative, shall cease. 
EFTA00190625

By signing this Addendum, Epstein asserts and certifies that the above has been read and 
explained to him. Epstein hereby, states that he understands the clarifications to the Non-
Prosecution Agreement and agrees to comply with them. 
R. ALEXANDER ACOSTA 
UNTIED STATES ATTORNEY 
Dated: 
 
By: 
A. MARIE VIUAPANA 
ASSISTANT U.S. ATTORNEY 
Dated: /12.-
Dated: 
Dated: 
GERALD LEFCOURT, ESQ. 
COUNSEL TO JEFFREY EPSTEIN 
LILLY ANN SANCHEZ, ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
EFTA00190626

By signing this Addendum, Epstein asserts and certifies that the above has been read and 
explained to him. Epstein hereby states that he understands the clarifications to the Non-
Prosecution Agreement and agrees to comply with them. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated: 
 
By: 
A. MARIE VILLAFARA 
ASSISTANT U.S. ATTORNEY 
Dated: 
JEFFREY EPSTEIN 
Dated: 
Dated: 
RALD LEFCO RT ESQ. 
COUNSEL TO JEFFR Y EPSTEIN 
LILLY ANN SANCHEZ, ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
EFTA00190627

By signing this Addendum, Epstein asserts and certifies that the above has boon read and 
explained to him. Epstein hereby states that he understands the clarifications to the Non-
Prosecution Agreement and agrees to comply with them. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated: 
 
By: 
Dated: 
Dated: 
Dated: ifr_an"" 
A. MARIE VILLAFARA 
ASSISTANT U.S. ATTORNEY 
JEFFREY EPSTEIN 
GERALD LEFCOURT, ESQ. 
COUNSEL TO JEFFREY EPSTEIN 
LILLY ANNSANCHEZ, ESQ 
ATTORNEY FOR JEFFREY EPSTEIN 
EFTA00190628

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
DELIVERY BY FACSIMILE 
Lilly Arm Sanchez 
Fowler White Burnett, PA 
1395 Brickell Ave, 14th Floor 
Miami, FL 33131 
Re: 
Jeffrey Epstein 
Dear Ms. Sanchez: 
99 N E 4 Saw 
FL 33/32 
(305)961.9I00. Telephone 
(305)530-6444 - Fatima. 
December 19, 2007 
I write to follow up on the December 14" meeting between defense counsel and the Eps 
prosecutors, as well as our First Assistant, the Miami FBI Special A ent in Charge and mysel 
all11111111111t 
2 Section 2255 provides that: "Hay 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." 
EFTA00190629

With this in mind, I have considered defense counsel arguments regarding the Section 2255 
portions of the Agreement. As I previously observed, our intent has been to place the victims in the 
same position as they would have been had Mr. Epstein been convicted at trial. No more; no less. 
From our meeting, it appears that the defense agrees that this was the intent. During the course of 
negotiations that intent was reduced to writing in Paragraphs 7 and 8, which as 1 wrote previously, 
appear far from simple to understand. I would thus propose that we solve our disagreements over 
interpretations by saying precisely what we mean, in a simple fashion. I would replace Paragraphs 7 
and 8 with the following language: 
"Any person, who while a minor, was a victim of a violation of an offense enumerated in 
Title 18, United States Code, Section 2255, will have the same rights to proceed under 
Section 2255 as she would have had, if Mr. Epstein been tried federally and convicted of an 
enumerated offense. For purposes of implementing this paragraph, the United States shall 
provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an 
Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority 
interpreting this provision, including any authority determining which evidentiary burdens if 
any a plaintiff must meet, shall consider that it is the intent of the parties to place these 
identified victims in the same position as they would have been had Mr. Epstein been 
convicted at trial. No more; no less." 
2 
EFTA00190630

align"
/111111111/11 
.
1111111
1.11alar 
Sincerely, 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
3 
EFTA00190631

Villafana, Ann Marie C. (USAFLS) 
From: 
Acosta, Alex (USAFLS) <AAcosta@usa.doj.gov> 
Sent: 
Wednesday, August 13, 2008 6:03 PM 
3c 
To: 
Atkinson, Karen (USAFLS); Senior, Robert (USAFLS); Sloman, Jeff (USAFLS); Lee, Dexter 
(USAFLS) 
Cc: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
Re: Epstein 
This is why we need to get agreement on the final version of the agreement. 
--- Original Message 
From: Atkinson, Karen (USAFLS) 
To: Acosta, Alex (USAFLS); Senior, Robert (USAFLS); Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS) 
Cc: Villafana, Ann Marie C. (USAFLS) 
Sent: Wed Aug 13 17:39:5 I 2008 
Subject: Epstein 
Marie and I just got off the phone with Jay-he is not on the civil case. After discussing the hearing for tomorrow and being told that if 
we had to supply the agreement it would be all three documents he again said that we should talk because that was not their view of 
the agreement. He said a unilateral change in the agreement in the letter from Alex (although he knew that Alex did not want to hurt 
Jeffery) could not change the terms of the agreement and put Jeffery in a worse position. Marie pointed out that the letter sent to the 
victims and approved by Goldberger and others quoted from that letter. He said he had not seen it so Marie is sending him the 
paperwork. It seems clear that they want all the advantages in subsequent agreements and none of the disadvantages. He thinks this is 
like a Chinese menu family style—pick and chose what you want from columns A & B. Back to wiretaps!! 
320 
EFTA00190632

Villafana, Ann Marie C. (USAFLS) 
From: 
Senior, Robert (USAFLS) <RSenior@usa.doj.gov> 
Sent: 
Wednesday, August 13, 2008 6:09 PM 
To: 
Atkinson, Karen (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Lee, Dexter 
(USAFLS) 
Cc: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
RE: Epstein 
OK, so now it has been flushed out and we can deal with it directly. We need to get this formally 
resolved. Marie/Karen, let's discuss tomorrow morning. 
From: Atkinson, Karen (USAFLS) 
Sent: Wednesday, August 13, 2008 5:40 PM 
To: Acosta, Alex (USAFLS); Senior, Robert (USAFLS); Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS) 
Cc: Villafana, Ann Marie C. (USAFLS) 
Subject: Epstein 
Marie and I just got off the phone with Jay-he is not on the civil case. After discussing the hearing for 
tomorrow and being told that if we had to supply the agreement it would be all three documents he again said 
that we should talk because that was not their view of the agreement. He said a unilateral change in the 
agreement in the letter from Alex (although he knew that Alex did not want to hurt Jeffery) could not change 
the terms of the agreement and put Jeffery in a worse position. Marie pointed out that the letter sent to the 
victims and approved by Goldberger and others quoted from that letter. He said he had not seen it so Marie is 
sending him the paperwork. It seems clear that they want all the advantages in subsequent agreements and 
none of the disadvantages. He thinks this is like a Chinese menu family style—pick and chose what you want 
from columns A & B. Back to wiretaps!! 
321 
EFTA00190633

Villafana, Ann Marie C. (USAFLS) 
From: 
Senior, Robert (USAFLS) <RSenior@usa.doj.gov> 
Sent: 
Thursday, August 14, 2008 9:59 AM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
Re: Agreement 
Ok 
 
Original Message 
From: Villafana, Ann Marie C. (USAFLS) 
To: Senior, Robert (USAFLS) 
Sent: Thu Aug 14 09:58:36 2008 
Subject: Agreement 
Hi Bob — Just talked to Dexter and he disagrees with our strategy. He is going to call and explain his reasoning. Here are the three 
documents. 
«Epstein Agnnt001.pdr, > 
A. Marie Villafana 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209.1047 
Fax 561 820-8777 
322 
EFTA00190634

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.gov> 
Sent: 
Thursday, August 14, 2008 2:45 PM 
To: 
Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen 
(USAFLS); Acosta, Alex (USAFLS) 
Subject: 
FW: Follow-up point 
Ahh, the plot thickens. Apparently December is looking better than October. 
I will draft a response and send to you shortly. 
A. Marie Villafalia 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
From: Jay Lefkowitz [mailto:JLefkowit@kirkland.com] 
Sent: Thursday, August 14, 2008 2:39 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Cc: Atkinson, Karen (USAFLS); lefkowitz@kirkland.com 
Subject: Re: Follow-up point 
Marie - In reviewing your December proposal, there are a couple of things I don't understand. 
What limits are placed upon individuals who proceed under 2255 as if "Mr. Epstein had been tried federally and convicted 
of an enumerated offense." In other words, what individuals would have this right? And would these individual only 
have this right if they proceeded exclusively under 2255? Also, to what enumerated offenses do you think would Mr. 
Epstein have to make constructive admissions of conviction? and how many such offenses? And against 
whom? Remember that while you may have investigated various offenses, he only plead guilty to certain state crimes. 
Finally, would paragraphs 8-10 of the September Agreement still be operative? 
I am trying hard to understand what you have intended by the December letter. Alex has says he thinks it benefits Jeffrey, 
and I am open to understanding it that way. But I would like some clarity on these issues. 
Thanks -- Jay 
"Villalana, Ann Mario C. (USAFLS)" 
<Ann.Mario.C.Viltafaratteuadoj.gove 
08114200812:44 PM 
To clelkowitz@kirMand.come 
cc "Atkinson. Karen (USAFLS)- <Karen.Alkinson@usclojpov> 
Subject Follow-up point - 
I I i Jay — I forgot to mention that 1 can no longer argue that the Court shouldn't force us to produce the 
325 
EFTA00190635

agreement because we have already provided the victims with the relevant portion when I now understand from 
you that I have NOT provided them with the relevant portion. 
A. Marie Vi 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
******41Wilei************* 
***** 
i********* 
********** 
********* 
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the use of the addressee. It is the property of 
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Unauthorized use, disclosure or copying of this 
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communication in error, please notify us immediately by 
return e-mail or by e-mail to postmaster@kirkland.com, and 
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including all attachments. 
326 
EFTA00190636

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.gov> 
Sent: 
Thursday, August 14, 2008 3:06 PM 
To: 
Senior, Robert (USAFLS); Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS); Atkinson, Karen 
(USAFLS); Lee, Dexter (USAFLS) 
Subject: 
FW: Follow-up point 
Here is my proposed response. 
Dear Jay: 
Pursuant to the December letter, only those "individuals whom [the United States] was prepared to name in an 
Indictment as victims of an enumerated offense" are the beneficiaries of the agreement. That is the list of 
names that I provided to Messrs. Goldberger and Tein following the change of plea. Under the 
September/October agreement, all "individuals whom [the United States] has identified as victims" are the 
beneficiaries, so I would prepare a supplement to the earlier list to include identified victims whom we were not 
yet prepared to name in an indictment. 
The December modification replaces paragraphs 7 and 8 of the Agreement, including paragraphs 7A through 
7C that are included in the October Addendum. This means that Mr. Epstein's waiver of "his right to contest 
damages up to an amount as agreed to between the identified individual and Epstein" will no longer exist, nor 
will Mr. Epstein's obligation to pay for the victims' counsel. Paragraphs 9 and 10 are still in effect. This 
includes the statement that there is no admission of civil or criminal liability, and that, "[e]xcept as to those 
individuals who elect to proceed EXCLUSIVELY under 18 USC § 2255, ... Epstein's signature [cannot] be 
construed as admissions or evidence of civil or criminal liability." I believe that this means that Mr. Epstein's 
agreement that the individuals on our list are "victims" as defined by statute applies only if the victims proceed 
exclusively under 18 USC 2255. 
I don't think that Mr. Epstein has to make any constructive admissions of conviction. He only needs to admit 
that the 32 girls whose names I have provided to Mr. Goldberger are "victims" of an offense listed in 18 U.S.C. 
2255. 
Please let me know if you have any additional questions. Thank you. 
A. Marie Villafalia 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
From: Jay Lefkowltz [malltoilefkowItz@kirkland.com] 
Sent: Thursday, August 14, 2008 2:39 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Cc: Atkinson, Karen (USAFLS); lefkowitz@kiridand.com 
Subject: Re: Follow-up point 
Marie - In reviewing your December proposal, there are a couple of things I don't understand. 
327 
EFTA00190637