EFTA00191396

LAW OFIKCS OF 
GERALD B. LEFCOURT. PC. 
N 
Jeffrey Sloman, Esq. 
Matthew Menchel, Esq. 
Andrew Lourie, Esq. 
A. Marie Villafatia, Esq. 
The United States Attorney's Office 
Southern District of Florida 
July 6, 2007 
Page 13 
1299 (11th Cir. 2003) (scienter requirement discourages "unscrupulous enforcement" and 
clarifies §2422(b)). Directed towards those who commit "the most serious crimes against 
children," it cannot properly be used as a trap for the unwary, sweeping within its net all 
who may — even unwittingly and unintentionally — communicate or otherwise interact 
improperly with persons who turn out to be minors. 
A prosecution of Mr. Epstein would violate the teachings of Bailey and Panfil. As 
we believe we persuaded you at the June 26th meeting, Mr. Epstein never targeted minors. 
On the contrary, what he did — at worst — was akin to putting up a sign saying to all, come 
in if you are interested in giving a massage for $200. A few among those who accepted 
the general invitation may have in fact been under 18 (though they lied about that age and 
said they were 18), but that is, at its worst, comparable to "post[ing] messages for all 
Internet users, either adults or children, to seek out and read at their discretion," which the 
courts have held does not violate §2422(b). 
Thus, for this reason as well, Mr. Epstein's case is far outside the parameters of 
the §2422(b) cases that have been prosecuted. A key factor common to cases brought 
under §2422(b) is not present here: Prosecutions under this statute have focused on a 
sexual predator who used the intemet to identify and to communicate with a child or 
purported child (or a person with influence over such child or purported child), and did so 
with the intent to arrange to engage in sexual activity with the child, with full knowledge 
that sexual activity with an individual of that age was illegal. In light of this common and 
well-accepted understanding, the cases decided under §2422(b) take as a given that its 
proper application lies only where the defendant knows or believes the person with whom 
he is interacting is a child. 
Virtually all of the prosecutions brought under §2422(b) resulting in published 
decisions have involved undercover "sting" operations, involving an essentially standard 
fact pattern in which over an extended period of time and in the course of multiple 
conversations on line an undercover agent pretends to be a young teenager. In each of the 
cases, the prosecution had, from the very words used by the defendant, an all but 
irrefutable case showing the clear knowledge and intent of the defendant. A prototypical 
case is United States' Farner, 251 F.3d 510 (5th Cir. 2001), where the defendant 
participated, over time, in instant messaging, e-mail, and follow-up telephone calls with a 
person who identified herself as 14 years old, engaged in explicit intemet conversation, 
sent her pornographic pictures, persuaded her to meet with him for sexual activity, 
arranged such a meeting, and traveled to the meeting place. The Fifth Circuit held that 
MIA_CEOS_00089 
EFTA00191456

LAW orrice, or 
ERALD B. LEIPCOURT. PC. 
Jeffrey Sloman, Esq. 
Matthew Menchel, Esq. 
Andrew Lourie, Esq. 
A. Marie Villafafta, Esq. 
The United States Attorney's Office 
Southern District of Florida 
July 6, 2007 
Page 14 
defendant's §2422(b) attempt conviction was valid; it mattered not that the 14 year old 
was really an adult FBI agent engaged in a sting operation, for the defendant "believed 
Cindy to be a minor and acted on that belief." 251 F.3d at 512. Our own survey of the 
cases brought in this district under §2422(b) confirms that prosecutions in this District 
have also been all but limited to intemet sting cases. See Tab "B". 
In the context of this standard fact pattern involving the intemet's use by 
predators, other Circuits, including the Eleventh, have been unanimous in holding that the 
non-existence of an actual minor was of no moment; defendant's belief that h n was 
dealing with a minor was sufficient to make out the crime. See United States I Root, 296 
F.3d 1222, 1227-32 (11th Cir. 2002); United States 
I
 
Sims, 428 F.3d 945, 919 (10th Cir. 
2005); United States I Helder, 452 F.3d 751 (8th Cir. 2006); United States 
Meek, 366 
F.3d 705, 717-20 (9th Cir. 2004). Likewise, the Circuits have rejected void for vagueness, 
overbreadth, and First Amendment challenges to the statute, brought in the context of 
these prototypical prosecutions where the intemet was the vehicle of communication and 
enticement, and the defendant demonstrated in writing his belief that he was dealing with 
a child well below the age of consent. E.g., United States I Tiikarsky, 446 F.3d 458, 473 
(3d Cir. 2006); United States 
I
 
Thomas, 410 F.3d 1235, 1243-44 (101° Cir. 2005); United 
States I Panful, supra, 338 F.3d at 1300-01 (11th Cir. 2003)." 
II There are approximately two dozen Eleventh Circuit cases that include a prosecutio under 
§2422(b), most of which involve the prototypical fact pattern. See, e.g., United States Morton, 
364 F.3d 1300 (11ih 
2004), judgment vacated for Booker consideration, 12, S. Ct. 1338 
(2006); United States' Orrega, 363 F.3ds1093 (11th Cir. 2004); United States Miranda, 348 
F.3d 1322 (11th Cir. 2003); United States I Tillman, 195 F.3 640 (11th Cir. 1999); United States , 
Pali!, supra, 338 F. d 1299 (11'h Cir. 2003); United States Garrett, 190 F.3 1220 (11th Cir. 
1999); United States  Burgess, 175 F.3d 261 (116 Cir. 1999); United States' Rojas, 145 Fed. 
Appx. 647 (11th Cir. 2005); United States' Root, 296 F.3d 1222 (11th Cir. 2002). 
United States 
I
 
Murrell, 368 F.3d 1283 (I 
Cir. 2004), is in the same mold, except that, in that 
sting operation, the defendant communicated, not with the purported 13 year old girl, but with an 
undercover agent holding himself out to be the imaginary girl's father. The initial contacts 
between Murrell and the agent occurred in intemet chatrooms named "family love" and "Rent F 
Vry Yng." Over time, Murrell sought to make arrangements with the girl's father to make his 
daughter available for sex in exchange for money. After the initial intemet communications 
concerning renting the girl for sexual purposes, further negotiations between the defendant and 
the undercover occurred via the phone, per the defendant's suggestion. The Eleventh Circuit, 
framing the issue to be whether the defendant must communicate directly with the minor or 
supposed minor to violate §2422(b), answered the question in the negative, reasoning that "the 
MIA_CEOS_00090 
EFTA00191457

LAW OFFICES Or 
OERALD B. LEFCOUBT. P.C. 
Jeffrey Sloman, Esq. 
Matthew Menchel, Esq. 
Andrew Lourie, Esq. 
A. Marie Villafana, Esq. 
The United States Attorney's Office 
Southern District of Florida 
July 6, 2007 
Page 15 
In light of this common and well-accepted understanding, the cases decided under 
§2422(b) take as a given that its proper application lies only where the facts demonstrate 
beyond dispute that the defendant knows or believes the person with whom he is 
interacting is a minor. 
The Ninth Circuit has so held. United States' Meek, 366 F.3d 705, 718 (9th Cir. 
2004), held that the term "knowingly" refers both to the verbs — "persuades", "induces", 
"entices", or "coerces" — as well as to the object — "a person who has not achieved the 
age of 1§ years," citing United States' X-Citement ildeo, Inc., 513 U.S. 64 (1994), and 
Staples 
United States, 511 U.S. 606 (1994). The Meek Court wrote: 
The statute requires mens rea, that is, a guilty mind. The 
guilt arises from the defendant's knowledge of what he 
intends to do. In this case, knowledge is subjective — it is 
what is in the mind of the defendant.'
The very lengthy sentence under §2422(b) speaks against strict liability, 
especially since it applies in cases where there is no sexual contact at all with any 
person, let alone with a real minor. The Eleventh Circuit's' decision in United States
Murrell, supra, reflects this same understanding of the statute. The Murrell court wrote 
that, under the "plain language" of §2422(b), "to prove an attempt the government must 
efficacy of §2422(b) would be eviscerated if a defendant could circumvent the statute simply by 
employing an intermediary to carri out his intended objective. Id. at 1287. Fact patterns similar 
to Murrell's exist in United States Hornaday, 392 F.3d 1306 (11i6 Cir. 2004); United States
Houston, 177 Fed. Ari,. 57 (11th Cir. 2006); United States! Searcy, 418 F.3d 193 (11th Cir. 
2005); United States Scott, 426 F. 3d 1324 (116 Cir. 2005 ; and United States 
Bolen, 136 Fed. 
Appx. 325 (11' Cir. 2002). 
12 Several Courts of Appeal have held that, in a prosecution under §2422(a), the defendant need 
not know that the individual that a defendant has persuaded, induced, enticed, or coerced to 
travel in interstate commerce is under the age of 18. United States' Jones, 471 F.3d 535 (4°' 
Cir. 2006), is one of these cases, though its facts are very different, and much more egregious 
than Mr. Epstein's. Assuming Jones was correctly decided and that the government need not 
prove defendant's knowledge under §2422(a), that still does not answer the question under 
§2422(b). The two are very different statutes, with different histories and different purposes. 
And §2422(a), unlike subsection (b), carries no mandatory minimum sentence, let alone ten years. 
MIA_CEOS_00091 
EFTA00191458

LAW onsets or 
GERALD B. LEFCOURT. PC. 
Jeffrey Sloman, Esq. 
Matthew Menchel, Esq. 
Andrew Lourie, Esq. 
A. Marie Villafafia, Esq. 
The United States Attorney's Office 
Southern District of Florida 
July 6, 2007 
Page 16 
first prove that Murrell, using the Internet, acted with a specific intent to persuade a 
minor to engage in unlawful sex." 368 F.3d at 1286 (emphasis added).13 United States 
Root, supra, 296 F.3d at 1227, follows this pattern, and confirms that, at the time the 
defendant induces or entices the minor, he must intend to have sexual conduct with a 
minor or one he believes to be a minor and know that such conduct is proscribed. 
("Root's statement to task force agents upon his arrest confirmed that he believed he 
would meet a 13-year-old girl for sex, which he said he knew was wrong but 'exciting"). 
See also United States': Rojas, 145 Fed. Appx. 647 (11th Cir. 2005) (unpublished). This 
mens rea requirement applies equally where the completed crime occurs.14
Finally, actus non Tacit ream, nisi mens sit rea — the act alone does not amount to 
guilt; it must be accompanied by a guilty mind. This principle of concurrence mandates 
that the actus reus and the mens reus concur in time. See Paul H. Robinson, Criminal 
Law §4.1 at 217 (1997) (concurrence requirement "means that the required culpability as 
to the element must exist at the time of the conduct constituting the offense"); LaFave, 
Substantive Criminal Law §3.11(a) (West 1986) (noting that Concurrence is a basic 
principle of criminal law and "the better view is that there is concurrence when tke 
defendant's mental state actuates the physical conduct"). See also United States,. Bailey, 
supra, 444 U.S. at 402. In this case, the requisite actus reus is absent; likewise the 
required mental state. Even if those two fatal defects could be set aside, nevertheless, 
there was no concurrence of guilty mind and evil act, providing an additional reason why 
a successful prosecution under §2422(b) could not be brought. 
6. Conclusion 
In Mr. Epstein's case, there was no use of the intemet to induce, etc., and, given 
the legislative history and purpose, that is itself dispositive. Nor does the case present 
any of the dangers associated with intemet predators and cyberspace. Not surprisingly 
13 Otherwise, the police could, for example, conduct a sting operation with a 17 year-old 
pretending to be an 18 year-old. Such an absurd operation is surely not intended by the statute. 
14 Even the completed crime does not require any sexual activity. Arguably, one commits the 
attempt offense when the actor, on the intemet, asks a known or believed-to-be minor to have sex, 
even if she says no. The completed offense occurs when he takes an additional step, even before 
any sexual activity and regardless of whether one ever takes place. 
MIA_CE0S_00092 
EFTA00191459

LAW OIACCS OF 
ERALD a LEFCOURT. PC. 
Jeffrey Sloman, Esq. 
Matthew Menchel, Esq. 
Andrew Lourie, Esq. 
A. Marie Villafaiia, Esq. 
The United States Attorney's Office 
Southern District of Florida 
July 6, 2007 
Page 17 
then, the statutory language does not fit: Mr. Epstein did not use any facility of interstate 
commerce to do the forbidden act — to persuade, entice, induce, or coerce — nor did he 
attempt to do so. Others did use the telephone to make a variety of arrangements for Mr. 
Epstein's residence in Palm Beach, including getting the house ready for his arrival, 
checking movie schedules, and making telephone calls to schedule doctor's 
appointments, personal training, physical therapy and massages. Even if Mr. Epstein 
could be held responsible for the use of the telephone on his behalf, nevertheless, calls 
made by others regarding massages were not the statutorily proscribed persuasions or 
enticements of a known minor to do acts known to be illegal. Within his home, even if 
Mr. Epstein may arguably have persuaded or induced individuals to engage in forbidden 
conduct with him, he did not violate §2422(b). If he engaged in such persuasion or 
inducement, it occurred only face to face and spontaneously. 
If such conduct constituted a crime, it would be a classic state offense. The state 
is the appropriate forum for addressing these issues. Though in our meeting it was 
asserted that cases under §2422(b) are often brought where there was simply use of a 
telephone, and casual use at that, it would not from our survey appear to be so on either 
count — that is, use of a telephone rather than the intemet, and use of the means of 
communication remote from the enticing, etc. This is neither the defendant, nor the 
factual context, to break new ground. 
H. 
Mr. Epstein Warrants Declination to Prosecute as Exercise of Discretion. 
We believe strongly that no federal case would lie under the facts here. Moreover, 
as we discussed, there is a pending state case against Mr. Epstein which can be resolved 
in a way that vindicates the state's rights and obligations in this matter. 
In considering an appropriate disposition in a case such as this, where the 
applicability of the statute, both legally and as a matter of policy, raise serious questions, 
and both the reliability and admissibility of much of the evidence is in doubt, it is useful 
to consider how best to use the broad discretion you enjoy in choosing whether to 
prosecute. In this regard, we suggest that having a greater understanding of who Jeffrey 
Epstein is as a person may help inform how best to proceed. 
Jeffrey Epstein was raised in a middle class neighborhood in Brooklyn, New 
York, by hardworking parents. His father was a laborer and his mother a secretary. They 
lived comfortably, but were by no means well off. Mr. Epstein's parents instilled a strong 
work ethic in him, and growing up he held a variety of jobs to support himself, from 
MIA_CEOS_00093 
EFTA00191460

Law/ OFFICES or 
GERALD B. LEFCOLTHT. PC. 
N 
Jeffrey Sloman, Esq. 
Matthew Menchel, Esq. 
Andrew Lourie, Esq. 
A. Marie Villafafia, Esq. 
The United States Attorney's Office 
Southern District of Florida 
July 6, 2007 
Page 18 
driving a taxi cab to working as a mechanic. Any notion that he was born with a "silver 
spoon in his mouth" should be dismissed. 
Although Mr. Epstein is self-made and worked long and hard, he could not have 
achieved his successes without the personal guidance and support of others. These key 
people first identified the promise in Mr. Epstein and brought him to Bear Steams and 
Company, Inc. There, starting in 1976 at the age of 23 as a floor trader's junior assistant, 
he became in 1980 a limited partner. Among the very many benefits that his experience 
there provided was an introduction to the people who ultimately became his clients. 
Early in his professional career, Mr. Epstein realized the profound impact that 
even one person can have on the life of another. His gratitude for the assistance he 
personally received, and his sense of obligation to provide similar assistance and 
guidance to others, is in large part, the motive for the primacy of philanthropy in his life 
or his particular philanthropic interests. Mr. Epstein has devoted a substantial portion of 
his time, efforts and financial resources to helping others, both on an individual basis and 
on a more far reaching scope. Mr. Epstein gives generously, of both his time and his 
financial resources equally to individuals whom he knows personally and well and to 
those with whom he has had little or no personal contact. Just a few examples: 
Some time ago, the two year old son of an employee was diagnosed with retinal 
blastoma. When told, Mr. Epstein not only gave the employee unlimited time off to 
attend to his son and promised whatever financial support was needed, but Mr. Epstein 
made the full list of his medical and research contacts available. The employee was put 
in contact with a former colleague who was then conducting eye research at Washington 
University. Mr. Epstein organized several meetings to determine how the colleague could 
be of assistance, including by arranging for further meetings with experts at Washington 
University. Though the employee's son lost one eye, he is now an otherwise normal 
twelve year old who attends private school along with his five siblings, the expenses of 
which are borne by Mr. Epstein. 
Several years ago, a new employee with whom Mr. Epstein had little or no prior 
contact approached Mr. Epstein to request a change in his medical insurance. It was soon 
revealed that the employee and his wife were experiencing fertility problems and they 
were seeking treatments that cost nearly $15,000 per month. Mr. Epstein insisted on 
paying directly for the treatments, and did so month after month. After each 
unsuccessful cycle, Mr. Epstein sat with the employee, exploring available alternatives, 
including adoption, and encouraging the employee to continue additional cycles at Mr. 
Epstein's. Mr. Epstein referred the employee to medical experts with whom Mr. Epstein 
MIA_CEOS_00094 
EFTA00191461

LAW OIIICCC OF 
N 
Jeffrey Sloman, Esq. 
Matthew Menchel, Esq. 
Andrew Lourie, Esq. 
A. Marie Villafaiia, Esq. 
The United States Attorney's Office 
Southern District of Florida 
July 6, 2007 
Page 19 
was acquainted and assigned personnel to assist the employee with administrative and 
secretarial needs that arose in seeking a solution to the problem. Mr. Epstein is now the 
godfather of the employee's seven-year old twins. 
Recently, both a second employee and a consultant of Mr. Epstein each confided 
that they and their respective spouses were experiencing similar fertility problems. 
Again, Mr. Epstein offered to pay the uncovered medical costs. The consultant and his 
wife are now expecting their first child. The second employee continues with infertility 
treatments. 
Two years ago, a building workman approached Mr. Epstein with news that the 
workman's wife needed a kidney transplant and that the workman's sister-in-law in 
Colombia was a willing donor. The non English speaking workman had neither the 
financial resources nor the know-how to get the sister-in-law to the United States. Mr. 
Epstein arranged for immigration counsel to expedite a visa for the sister-in-law and 
purchased the plane tickets for the sister-in-law's visit to the United States. The surgery 
was a success and both patients recovered completely. The sister-in-law flew back to 
Colombia at Mr. Epstein's expense. 
Mr. Epstein is a devoted advocate of personal improvement through education. 
As a former board member of Rockefeller University, Mr. Epstein has made available 
academic scholarships to worthy students, most of whom he has had no prior connection 
to whatsoever. In addition, Mr. Epstein covers the tuition required to send the family 
members of his employees to nursery, private elementary, middle and secondary schools 
and colleges. He has funded and personally encouraged continuing education programs 
for his adult employees and professional consultants. 
Among his other acts: 
• 
On a trip to Rwanda to inspect the genocide camps, Mr. Epstein 
approached the President of Rwanda and offered to help identify and then 
to fund two worthy Rwandan students to earn undergraduate degrees in 
the United States. The students, whom Mr. Epstein did not meet until after 
their second year of studies, both are expected to graduate with honors 
from the City University of New York in 2008. Notes from each of them 
are annexed at Tab "C". 
• 
Even to those with less lofty goals, seeking only to advance in their chosen 
paths, Mr. Epstein freely gives of his time to provide guidance and, when 
appropriate, financial support. For example, Mr. Epstein has been meeting 
MIA_CEOS_00095 
EFTA00191462

LAW OFFICES OF 
EELALD B. LEFCOURT. PC. 
Jeffrey Sloman, Esq. 
Matthew Menchel, Esq. 
Andrew Lourie, Esq. 
A. Marie Villafafia, Esq. 
The United States Attorney's Office 
Southern District of Florida 
July 6, 2007 
Page 20 
monthly with a teenage building workman whose expenses of vocational 
school are being paid by Mr. Epstein. Each month, Mr. Epstein reviews 
the workman's school progress and discusses career opportunities. One of 
the monthly reports is annexed at Tab "D". 
• 
In addition, Mr. Epstein blocks out time each week to meet with young 
professionals to discuss their career prospects and counsel them regarding 
appropriate next steps. 
Although Mr. Epstein is deeply committed to helping others in very personal and 
meaningful ways, he has also sought to use his good fortune to help others on a broader 
basis. Mr. Epstein has sponsored more than 70 athlete wellness programs, building 
projects, scholarship funds and community interest programs in the United States Virgin 
Islands alone. 
Moreover, Mr. Epstein has given generously to support philanthropic 
organizations across the United States and around the world, including America's 
Agenda; Robin Hood; Alliance for Lupus Research; Ovarian Cancer Research Fund; 
Friends of Israel Defense Forces; Seeds of Peace; the Jewish National Fund; the Hillel 
Foundation; the National Council of Jewish Women; and the Intrepid Fallen Heroes Fund 
— to name only a few. 
In a feature article about Mr. Epstein in New York Magazine, former President 
Clinton aptly described Mr. Epstein as "a committed philanthropist with a keen sense of 
global markets and an in-depth knowledge of twenty-first-century science." President 
Clinton reached this conclusion during a month-long trip to Africa with Mr. Epstein, 
which Mr. Epstein hosted. The purpose of that trip was to increase AIDS awareness; to 
work towards a solution to the AIDS crisis; and to provide funding to reduce the costs of 
delivering medications to those inflicted with the disease. 
Both before and after that trip to Africa, Mr. Epstein worked hard to achieve 
improvements in people's lives on a global basis. He actively sought advancement of his 
philanthropic goals through his participation and generous support of both the Trilateral 
Commission and the Council on Foreign Relations. As you may know, the Trilateral 
Commission was formed to foster closer cooperation among core democratic 
industrialized areas of the world in the pursuit of goals beneficial to the global 
population. The Council on Foreign Relations is an independent, national membership 
organization and a nonpartisan center for scholars dedicated to increase international 
understanding of world issues and the foreign policy decisions that affect those issues. 
MIA_CEOS_00096 
EFTA00191463

LAW orn<cs 
OF 
Jeffrey Sloman, Esq. 
Matthew Menchel, Esq. 
Andrew Lourie, Esq. 
A. Marie Villafatia, Esq. 
The United States Attorney's Office 
Southern District of Florida 
July 6, 2007 
Page 21 
Mr. Epstein was part of the original group that conceived the Clinton Global 
Initiative, which is described as a project "bringing together a community of global 
leaders to devise and implement innovative solutions to some of the world's most 
pressing challenges." Focuses of this initiative include poverty, climate change, global 
health, and religious and ethnic conflicts. 
Mr. Epstein has sought to improve people's lives through active participation in 
worthy scientific and academic research projects, as well. He spent hundreds of hours 
researching the world's best scientists, and he himself studied as a Harvard Fellow in 
order to increase his own knowledge in fields that he believed could provide solutions to 
the world's most difficult problems. He is committed to helping the right researchers find 
those solutions, especially in the fields of medical science, human behavior and the 
environment. 
In the past four years alone, Mr. Epstein has made grants to research programs at 
major institutions under the supervision of some of the most highly regarded research 
professionals and scholars in their fields, including Martin Nowak, a mathematical 
biologist who studies, among other things, the dynamics of infectious diseases and cancer 
genetics; Martin Seligman, known for his work on Positive Psychology — that is to say 
the psychology of personal fulfillment; Roger Schank, a leading researcher in the 
application of cognitive learnin theory to the curricula of formal education; the renown 
physicist/cosmologist 
Krauss, and many others. Institutions funded include 
Harvard University; Penn State University; Lenox Hill Hospital (New York); the 
Biomedical Research and Education Foundation; the Santa Fe Institute; Massachusetts 
Institute of Technology; Case Western Reserve University; and Harvard Medical School's 
Institute for Music and Brain Science. 
Moreover, Mr. Epstein has sponsored and chaired symposia that have provided a 
rare opportunity for the world's leading scholars and research professionals to share ideas 
across interdisciplinary lines. These leaders gather to discuss important and complex 
topics, including the origin of life, systems for understanding human behavior, and 
personal genomics. 
In order to expand the pool of qualified research professionals actively engaged in 
addressing the world's numerous problems, Mr. Epstein co-founded, and served as a 
trustee and actively participated in the selection committee of, the Scholar Rescue Fund. 
The Scholar Rescue Fund (SRF) is a program of the Institute of International Education, 
the group that, inter alter, administers the Fulbright Scholarship program. The SRF 
provides support and safe haven to scholars at risk from around the world. Over the past 
MIA_CEOS_00097 
EFTA00191464

LAW orncu 
OF 
Jeffrey Sloman, Esq. 
Matthew Menchel, Esq. 
Andrew Lourie, Esq. 
A. Marie Villafafia, Esq. 
The United States Attorney's Office 
Southern District of Florida 
July 6, 2007 
Page 22 
five years, SRF has made 155 grants to scholars from more than 37 countries. Scholars 
are placed at host universities in a safe country. More than 87 institutions around the 
world have hosted SRF scholars to date, including eight of the top ten universities in the 
United States. Most recently, SRF launched the Iraq Scholar Rescue Project to save 
scholars in Iraq, many of whom have been particularly targeted for kidnapping and death 
since the conflict there began. Mr. Epstein is a highly valued member of the selection 
committee. Just a few articles mentioning these and other projects are annexed at Tab 
"E". 
Even a casual review of the good works large and small in which he has involved 
himself leads one to conclude that he has a powerful instinct to help others. He does this 
not simply because he can, but because he has a deeply ingrained desire to do so. In fact, 
he believes that, as a result of his good fortune, he is obligated to do so. 
Since 2000, Mr. Epstein has funded educational assistance, science and research 
and community and civic activities. As you can see, his philanthropy is not limited to 
financial support. To the contrary, it has involved the dedication of a remarkable amount 
of his time and effort and has yielded admirable results. It is noteworthy that a majority 
of the people he has helped over the years have been those with whom he has had little or 
no contact, which further confirms that he derives no personal benefit from his good 
works, other than the personal satisfaction derived from using his good fortune to help 
others. 
The sincere devotion to others evidenced by Mr. Epstein's philanthropic activities 
is no less apparent in his interpersonal relationships. Mr. Epstein has maintained both 
long term significant, intimate as well as professional relationships. He remains close 
personal friends with people with whom he went to high school and, to this day, 
maintains close business contacts with his former colleagues at Bear Stearns. Those who 
know Mr. Epstein well describe him admittedly as quirky but certainly not immoral; and 
overall as kind, generous and warm-hearted. They have remained staunch supporters 
despite the lurid media attention during this two-year investigation. 
Mr. Epstein acknowledges that the activities under investigation, as well as the 
investigation itself, have had and continue to have an unfortunate impact on many people. 
With a profound sense of regret, Mr. Epstein hopes to end any further embarrassment to 
all who are and who may become involved in this serious matter. Resolution of the 
outstanding charges in the state would put an appropriate end to the matter for everyone. 
MIA_CEOS_00098 
EFTA00191465

LAW OMCC! 0/ 
GERALD B. LEFCOTJRT. PC. 
N 
Jeffrey Sloman, Esq. 
Matthew Menchel, Esq. 
Andrew Lourie, Esq. 
A. Marie Villafarla, Esq. 
The United States Attorney's Office 
Southern District of Florida 
July 6, 2007 
Page 23 
Again, we and our colleagues thank you for your attention at the June 26 meeting. 
I welcome any questions or comments you may have and am available to discuss this and 
any other issues at your earliest convenience. 
cc: Lilly Ann Sanchez, Esq. 
Roy Black, Esq. 
Very truly yours, 
Goudf? 
Gerald B. Lefcourt 
a
t41^- 1  A—
l  t
Alan Dershowitz 
MIA_CEOS_00099 
EFTA00191466