EFTA00225044

STATEMENT OF 
IN RESPONSE TO 
APRIL 2, 2019 LETTER FROM JEFFREY R. RAGSDALE 
To the extent possible, I have provided all information relevant to your inquiry, including 
applicable documents. Due to the passage of time, updates to various software and hardware, and 
the crash of my work laptop several years ago, I no longer have every piece of relevant material 
and my memory may be imperfect.' I have organized the response to conform with the April 2, 
2019 letter from Jeffrey R. Ragsdale to Jonathan Biran. Please note that there were numerous oral 
and written communications between others at the U.S. Attorney's Office and the Justice 
Department with counsel for Mr. Epstein. While in some cases I was told of the communications 
or cc'ed on emails or letters summarizing the communications, for many conversations, meetings, 
and emails, I do not have knowledge of what occurred. 
Introduction 
The investigation of Jeffrey Epstein and I series of co-conspirators, named "Operation 
Leap Year," officially began in May 2006. In theory, it was supposed to conclude on September 
24, 2007 with the signing of I "Non-Prosecution Agreement" ("NPA").2 As will be discussed 
below, the investigation presented several issues of first impression and challenges related to 
obtaining evidence and securing the coo eration of witnesses. Nonetheless, I felt certain that the 
agents, my co-counsel, and I had built 
ve 
strop case against Mr. Epstein and three of his 
rsonal assistants — 
and 
The case was presented for federal investigation by the Palm Beach Police Department 
after they felt that Jeffrey Epstein's legal team had put inappropriate pressure on the Palm Beach 
County State Attorney's Office to file only misdemeanor charges. Allegations of misconduct had 
been leveled against the local detective and the Police Chief and they reported being followed and 
harassed. As described below, the defense attorneys employed the same tactics at the federal level 
against myself and the FBI. 
With regard to the exhibits, whenever possible, I have used copies of original documents 
or "scanned" originals that were made at the time. In some cases, all that I have are the electronic 
documents (i.e., the Word Perfect letter that was printed, signed, and mailed or faxed). Because 
our computers no longer have Word Perfect, I have used "Quick Print" which has distorted the 
formatting. If I am providing something that I know is I "draft," I note that either in the text or in 
the exhibit list. The fact that something does not contain I signature does not mean that it is
draft, it just means that it was printed from the electronic version and I no longer have (or never 
had) 
copy of the original. For example, I often drafted letters for the signatures of 
Jeff 
, and Alex Acosta. Their assistants would have maintained the signed 
originals. In some cases, I would be provided with copies and sometimes I would not. I would 
usually notate my electronic files with "final" to know which was the final version, or the last-
modified version. 
2 For reasons set forth below, the investigation continued due to Epstein's post-NPA 
conduct. 
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EFTA00225044

Once the USAO opened the file, Epstein took the same approach that had been used with 
the State — at each level of review, he hired an attorney with I personal connection to the 
MUSA/13OJ Attorney who was conducting the review. The attorneys raised I series of 
challenges to the veracity of the victims and the veracity of the state investigators, as well as quasi-
Petite-policy arguments. When those failed, more formal legal analysis and federalism policy 
arguments were presented. 
Throughout this process, I wanted to keep my investigation as confidential as possible. For 
example, I did not see the benefit of telling Epstein's counsel that we had uncovered additional 
victims, that we had been able to corroborate victims' accounts, or the legal theories that we were 
pursuing. My objections to malS these disclosures were all overruled. Also, unbeknownst to 
me, at least one supervisory 
was engaging in plea discussions with counsel for Epstein 
without consulting with me, the agents, or the victims. These discussions led to the creation of the 
NPA — an agreement that allowed Epstein to plead guilty to state charges in exchange for immunity 
for federal prosecution by the USAO for the Southern District of Florida. 
After the NPA was signed on September 24, 2007, when I attempted to notify the victims 
and enforce the agreement, the attacks became more personal. Epstein's attorneys raised the same 
policy arguments — which could have been raised prior to signing the NPA — as high as the DAG's 
Office, and coupled them with claims of prosecutorial misconduct. As these attacks occurred, the 
USAO — U.S. Attorney Alex Acosta and later First Assistant U.S. Attorney Jeff 
offered 
Epstein the option of simply "unwinding"3 the NPA — after all, he had never performed any part 
of it. In my mind it was unfathomable that Epstein would be allowed to spend months attacking 
not just the validity of our investigation and the validity of the NPA, but also making false 
allegations of prosecutorial misconduct against myself and FAUSA 
and still be allowed 
the benefit of what was, in my opinion, an unreasonably favorable agreement. Since everyone 
from the U.S. Attorney down to me agreed that the case was headed for I trial, the investigation 
continued, including identifying additional victims, conducting interviews, issuing grand jury 
subpoenas, drafting revised indictment packages, and presenting testimony to the grand jury. 
Epstein's clear intent to go to trial was on display during this period as he deposed victims 
identified only through the federal investigation in the guise of taking discovery in the state case. 
On June 23, 2008, en 
the DAG's Office issued his letter denying Epstein's final 
appeal. While USA Acosta allowed Epstein the benefit of the NPA, Epstein still tried to avoid 
several key parts of the NPA's terms, and would have escaped them but for my insistence. 
On June 30, 2008, Epstein entered his guilty plea in state court and was sentenced to 18 
months' in the county jail in accordance with the terms of his state plea agreement and the NPA. 
Not long thereafter, I learned that Epstein had applied for work release and the Palm Beach County 
Sheriff's Office had granted the application. Prior to Epstein's guilty plea, the issue of work 
release had been specifically discussed with Epstein's counsel and they informed us that Epstein 
would not seek work release. The agents and I also met with the Sheriffs Office in advance of 
the plea and had been told that Epstein would not be eligible for work release. Accordingly, I 
provided my Notice of Breach, but was told by defense attorney Roy Black that, despite those 
specific conversations, USA Acosta himself agreed that Epstein would be eligible for any program 
3 "Unwinding" was USA Acosta's term for mutual rescission — the USAO could file its 
charges and Epstein would have no obligations to plead guilty in state or federal court. 
Page 2 of 58 
EFTA00225045

that the state offered, including work release. Because of this, I had to withdraw the Notice of 
Breach and could only write I letter to the Sheriff's Office pointing out all of the false statements 
contained in Epstein's application for work release and letters to the victims informing them that 
Epstein was in work release status. The Sheriff's Office never responded to or acknowledged my 
letter. 
On June 9, 2009, I prepared what I believe was the last Memorandum requesting 
authorization to issue I Notice of Breach and to indict Epstein. The Office authorized issuance of 
the Notice of Breach, and the Indictment Packages was re-reviewed, a roved, and signed, with 
arrest warrants for Jeffrey Epstein, 
and 
. The Notice of Breach 
was served on June 12, 2009 at I hearing on Epstein's Motion to Dismiss one of the civil suits 
filed by one of the victims identified during the federal investigation. Once again, Epstein was 
allowed to "cure" his breach, and we were not allowed to file the indictment. 
There were strong internal disagreements on I number of subjects, including: the handling 
of the meetings with Epstein's counsel; plea negotiations; the NPA generally; the failure to consult 
with the victims; continuing plea negotiations in the face of Epstein's clear bad faith; the refusal 
to defend me against personal attacks from Epstein's attorneys; the agreement to put off seeking 
Epstein's computer equipment; the consultations with Epstein's attorneys regarding victim 
notifications; the handling of the "appeals" to Washington; allowing delays during those "appeals," 
while Epstein's attorneys were harassing the victims and their family members; attempts by 
Epstein to renegotiate the term of imprisonment; attempts by Epstein to renegotiate the payment 
of damages to the victims and attorneys' fees to their attorney representative; allowing Epstein to 
participate in the work release program after specifically discussing it during plea negotiations; 
and repeatedly allowing Epstein to "cure" intentional breaches of the NPA. These were kept 
internal as I tried to deal professionally with opposing counsel. 
In the midst of all of the post-NPA back-and-forth with Epstein, was the Jane Doe. United 
States litigation.4 Despite the Office's request to be recused from the case, the Justice Department 
decided that there was no conflict of interest and I was tasked with serving as co-counsel. The 
Office asserted attorney-client, executive, work product, and deliberative process privileges, so all 
of the internal disagreements, pros memos, and indictments were not disclosed while all of my 
communications with opposing counsel (often at the behest of supervisors) were disclosed. After 
an initial flurry of filings, Brad Edwards, as counsel for the named plaintiffs, stated on the record 
that he believed that setting aside the NPA would not benefit his clients, and he sued Epstein on 
behalf of I number of victims under the NPA. I did what I could to assist Mr. Edwards, other 
attorneys, including Mr. Josefsberg, the attorney selected by the Special Master, and the Court, to 
locate victims, provide signed copies of the NPA, and answer questions. After all of the civil suits 
between Epstein and the victims were settled through the spectre of breaching the NPA, Mr. 
Edwards re-initiated the Jane Doe 
United States litigation, asserting that his clients wanted to 
4 1 
few days after Jeffrey Epstein entered his guilty plea in state court, attorney Brad 
Edwards filed suit on behalf of one of the victims identified in the federal investigation (later 
expanded to include I second victim who had been identified in the state investigation), alleging 
violations of the Crime Victims' Rights Act. The suit, which is still pending, is captioned Jane 
Doe 1 and Jane Doe 21 United States, 08-80736-CV-KAM. 
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set aside the NPA and see Mr. Epstein federally charged due to violations of the Crime Victims' 
Rights Act. 
In response to your questions, I have attempted to distill the past 13 years of emails, letters, 
research, pleadings, and conversations into I coherent document and attach the most relevant 
items. Given the sheer volume of materials involved here and the passage of time, while I have 
worked diligently to answer your questions as fully as possible, I certainly could have missed 
something amongst the thousands of pages of emails, drafts, and hard copy and electronic 
documents. 
If there are additional items or topics that need further explanation or more 
documentation, I can delve further. 
The Non-Prosecution Agreement 
1. Describe the circumstances under which the investigation of Jeffrey Epstein 
was referred to the USAO, including when, why, how, and by whom the 
referral was made. Explain why the USAO decided to initiate I federal grand 
jury investigation into this matter, including what federal interests were 
perceived to be involved, and identify the individuals participating in the 
decision. 
Some time in early 2006, FBI Special Agent E. 
approached me about 
an investigation being conducted b the Town of Palm Beach Police Department ("PBPD"). I do 
not know how or when A 
was first contacted about the matter. 
The first mentions of the investigation were just jpassing comments during meetings on 
other matters. 
and I were working on I number of different child exploitation 
matters at the time, along with ICE Special Agent David Malone. I remember generally that SA 
mentioned an investigation of I wealthy man who lived on Palm Beach and recruited 
minors for sexual activity. During these casual conversations, I do not believe that Mr. Epstein's 
name was mentioned. If it was mentioned, it held no significance for me. I recall that Si 
mentioned that PBPD had reached out to her because the Palm Beach County State 
Attorney's Office was leaning towards not charging the case at all or letting the defendant lead 
to I misdemeanor charge of solicitation of prostitution. At some point I told 
that, 
if PBPD wanted to look into federal charges, I would need more information about the allegations 
and I encouraged her to set up I meeting. I recall Si 
telling me that PBPD wanted 
to give the State Attorney's Office the opportunity to properly charge the case before presenting it 
for federal investigation and prosecution. 
In May 2006, I met with Si 
and PBPD Detective Joe 
in the 4th Floor 
Conference Room at the U.S. Attor 
Office in West Palm Beach. I do not recall whether Si 
Malone was present. Detective 
summarized the investigation into state criminal sexual 
conduct involving Epstein and his personal assistants. Briefly, Epstein, through his personal 
assistants, recruited girls and young women — mainly from I local high school — to travel to his 
residence on Palm Beach to perform erotic massages. Although they had no massage training, the 
5 I use these terms deliberately. "Girls" refers to females under the age of 18 and "young 
women" refers to females over the age of 18. When I refer to both groups jointly, I will use the 
term "females." 
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girls and young women were coached to massage Mr. Epstein in various states of undress. The 
sexual activity varied and included: Mr. Epstein masturbating himself at the end of the massage; 
having the females masturbate him; Mr. Epstein fondling the females' breasts and genitalia; using 
sex toys on the females; digital penetration of the females; sexual intercourse with Mr. Epstein; 
and Mr. Epstein observing while one of the girls had sex with one of his assistants. At the end of 
each "massage" session, Mr. Epstein or one of his assistants would pay the female involved. If 
the female involved in the massage was brought to Mr. Epstein's residence by I "recruiter," then 
the "recruiter" also would be paid. 
Detective 
did not have any information regarding an of the females traveling 
interstate or internationally to engage in sexual activity, but Det. 
reported that Mr. Epstein 
and his assistants traveled in and out of the Palm Beach International Airport on Epstein's private 
airplane. Det. 
stated that flight logs he had seen sometimes referred to passengers as 
"females," without names or ages, so it was possible that
 could have been on board, but Det. 
had not been able to confirm that. Det. 
stated that I search warrant had been 
executed on Mr. Epstein's residence and evidence had been seized, including message pads 
showing calls from females confirming that they would be coming to "work," which was the 
euphemism used for iving I "massage" — another euphemism for engaging in sexual activity for 
money. Det. 
also reported that it had appeared that Mr. Epstein had been "tipped off' 
about the coming search warrant because all of the computer CPUs had been removed from the 
residence — the keyboards and screens were still in place, just the CPUs had been taken. Det. 
also reported that some surveillance cameras were in place but they had only recovered I 
limited amount of surveillance video. Det. 
stated that between 20 and 30 females had 
been identified [NB: I believe that he told me the exact number, I just don't recall that number 
now]. 
and Det. 
asked me whether there were federal criminal charges 
that could be pursued. I remember getting up from the conference room, walking to my office, 
and getting my code book and walking back. I looked through 18 U.S.C. §§ 2422 (enticement of 
minors into prostitution/illegal sexual activity) and 2423 (travel for purposes of engaging in illegal 
sexual conduct).6 We talked through those statutes and the additional investigation that would be 
required to prove that they had been violated, but I told them that, if the evidence was there, it was 
I case that could be prosecuted federally. 
Det. 
then told me that his boss - PBPD Chief Michael 
— was still pressing 
the State Attorney's Office to arrest Epstein. Det. 
had prepared series of probable cause 
affidavits for the arrests of Jeffrey Epstein, 
and Haley Robson, charging I large 
number of state criminal violations. Chief 
had asked the Palm Beach County State Attorney, 
Barry 
to authorize the arrests and he had refused. According to Det. MI 
pressure 
had been brought to bear on SA 
bilg
es attorneys, who included Gu Fronstin and 
Jack Goldberger twopersonal friends of 
), and Alan Dershowitz. Det. 
stated 
that he and Chief 
were concerned that Epstein would be charged only with misdemeanor 
or perhaps would not be charged at all. 
6 As the investigation progressed, I looked into other federal crimes, but at that first 
meeting, I only remember looking at §§ 2422 and 2423. 
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EFTA00225048

I recommended that we begin the 
rocess of investigatin
er there was I 
jurisdictional basis for federal charges, and Si 
and Det. 
concurred. Det. 
asked that Chief 
be given an additional opportunity to convince the State Attorney 
to charge Epstein.? I explained that opening I case file and beginning I federal investigation would 
not preclude the State Attorney from charging Epstein. 
I then prepared the paperwork to open I file. The investigation was dubbed "Operation 
Leap Year" because there were approximately 29 young women and girls who had been identified 
through the State investigation. 
There were several aspects of the case that involved federal interests. First, as to the 
substantive crimes that Epstein was accused of committing, they involved the victimization of 
minor females through the use of facilities of interstate commerce (telephones and airports); and 
Epstein was traveling interstate and internationally to come to the Southern District of Florida to 
commit those offenses. During the course of the investigation, I often said that, if there were
trial, I would tell the jury that Jeffrey Epstein traveled to Florida to use Royal Palm Beach High 
School as his personal brothel. Second, the removal of the computer equipment from Epstein's 
home prior to the execution of the search warrant suggested possible public corruption at the Palm 
Beach County courthouse (where the search warrant application was signed) and also raised the 
possibility that Epstein may have been involved in the manufacture and/or possession of child 
pornography. Eradication of child pornography was I particular focus of Project Safe Childhood; 
its production and storage on computer equipment involved the use of items produced in interstate 
and foreign commerce; and child pornc
 ty was often distributed through facilities of interstate 
and foreign commerce. Third, Det. 
was suggesting that political or other pressure was 
being placed on an elected official (the State Attorney) to avoid or minimize criminal exposure for 
person who committed numerous state crimes related to the exploitation of girls and young 
women. Setting aside the issue of prostitution, the sexual activity involving girls under the age of 
16 could be charged as sex battery in the state. Ignoring those crimes suggested possible public 
corruption or, at the least] miscarriage of justice. 
With regard to the logistics of opening the case file, the opening of files in West Palm 
Beach is relatively informal. In instances where an agent approaches line 
directly (either 
because it is duty matter or because the investigation is within the 
area of expertise), 
the line 
will give his or her assistant the details of the case for the LIONS file-opening 
paperwork and then give I brief oral explanation of the case to his/her supervisor along with the 
paperwork. If the supervisor agrees that I file should al
;vned, he or she will normally sign the 
LIONS form on the spot and hand the file back to the 
In this case, I prepared I file jacket; 
my assistant did the LIONS paperwork; I signed the conflict form; briefed my supervisor, 
; and she signed the LIONS paperwork assigning the case to me. This all occurred either 
on the day of the meeting with Detective 
and SI 
or within I few days 
thereafter. Attached hereto as Exhibit 2 is the file opening paperwork and file jacket showing that 
the case was opened in LIONS on May 23, 2006. 
I do recall that at some time relatively soon after the file was opened, I did something that 
I had never done before or since. I initiated I meeting with the U.S. Attorney and the First 
7 .1111 
I did not know it at the time, on May I, 2006, Chief 
sent I letter to State 
Attorney 
asking 
to consider recusing himself from the case. (Exhibit 1.) 
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EFTA00225049

Assistant, Alex Acosta and Jeff 
where I traveled to Miami and told them about the case. 
I recall that I explained the case and how the PBPD believed that Epstein had used political or 
other pressure to avoid serious punishment in Palm Beach County state court. That possibility 
troubled me greatly; hence, my request to meet with executive mans ement. Messrs. Acosta and 
had the same reaction that I had the first time tha 
told me about Mr. Epstein 
— if I have never heard of him, how much influence could this person have? I remember 
specifically saying to them that I expected the case would be time and resource-intensive and I did 
not want to invest the time and the FBI's resources if the Office would just back down to pressure 
at the end. Messrs. Acosta and 
assured me that, if there was sufficient evidence to support 
the case, Mr. Epstein would be charged appropriately.8
2. Describe in detail your role, and the role of each other person in the USAO, the 
Federal Bureau of Investigation (FBI), and elsewhere within the Department 
of Justice — collectively herein "the government" — who was involved in the 
assessment of the viability and strength of the federal case against Mr. Epstein 
and in the decision to negotiate I pre-indictment resolution of the case. 
My Role 
I was the line 
assigned to the case. In conjunction with the case agents, I handled 
all aspects of the grand jury investigation — deciding what subpoenas to issue; whom to interview; 
whom to call to testify before the grand jury; what lines of inquiry to pursue to support various 
legal theories; I conducted legal research to support charges; I reached out to others throughout 
the Department and the federal government for information on previous investigations of Mr. 
Epstein, and for legal guidance on various aspects of the case (e.g., OEO, CEOS, SEC, SDNY, 
and AFMLS); along with the FBI agents and the FBI Victim-Witness Coordinator, I had direct 
contact with victims via interviews, meetings, and consultations regarding safety/privacy/mental 
health concerns; and I handled all court proceedings related to the investigation. When I felt that 
sufficient evidence had been collected to prove Mr. Epstein's guilt beyond I reasonable doubt, I 
drafted I prosecution memorandum, indictment, and related documents. I revised those documents 
in response to comments from those in the supervisory chain of command and, as explained below, 
after additional evidence was secured. I participated in some (but not all) of the meetings between 
members of the USAO and counsel for Jeffrey Epstein. 
I prepared briefing materials for 
management in preparation for those meetings and in response to issues raised during those 
meetings. 
Normally the assigned line 
handles plea negotiations, and I recommended that I 
enter into negotiations that would result in joint federal and state resolution (i.e.,I plea to federal 
charges in federal court and I plea to state charges in state court). I was reprimanded for doing so. 
8 I do not have I contemporaneous memorandum and cannot find the date of the meeting. 
In I July 13, 2007 email exchange between myself and Criminal Chief 
=
 
I describe 
the meeting as follows: "I summarized the case and the State Attorney's Office's handling of it. 
I acknowledged that we needed to do work to collect the evidence establishing I federal nexus, 
and I noted the time and money that would be required for an investigation. I said that I was 
willing to invest that time and the FBI was willing to invest the money, but I didn't want to get to 
the end and then have the Office be intimidated by the high-powered lawyers. I was assured that 
that would not happen." (See Exhibit 3.) 
Page 7 of 58 
EFTA00225050

Thus, as will be discussed in more detail below, I played no role in the decision to enter into I 
Non-Prosecution Agreement in exchange for Jeffrey Epstein's entry of I guilty plea to I state 
charge requiring I sentence of 18 months' imprisonment or Epstein's plea to federal charges 
resulting in I maximum sentence of 18 months' imprisonment (as will be explained below, 
Epstein's counsel repeatedly changed their minds about whether to take the federal route or the 
state route). Although I was tasked with drafting the agreements and Information, all of the 
documents were repeatedly and substantively revised by various supervisors, and I was responsible 
for incorporating those edits. I also was asked to sign the Non-Prosecution Agreement. 
When Epstein sought to have the Non-Prosecution Agreement set aside by "appealing" the 
matter to CEOS, the AAG, and the DAG, I handled the continued investigation of Epstein, 
including working with the FBI to identify additional victims, issue additional grand jury 
subpoenas, and prepare an updated indictment package. At the request of the U.S. Attorney, I also 
responded to inquiries from CEOS, the AAG, and the DAG's Office and drafted submissions on 
behalf of the USAO in response to arguments raised by Epstein's attorneys. 
I believe that I prepared I first draft of the Addendum to the Non-Prosecution Agreement, 
but others took the laboring oar on that document. I drafted numerous victim notification letters 
and responded to defense objections to those letters. I drafted the letter to the Special Master with 
the USAO's recommendations for the qualities to look for in the attorney representative for the 
victims. I monitored Epstein's compliance with the Non-Prosecution Agreement and served 
several breach notices. 
U.S. Attorney's Office Personnel 
(now retired): 
was my direct supervisor. She 
reviewed indictment packages and other court-related matters and provided guidance and 
served as I "sounding board" for many of my concerns. As will be explained below, 
did not participate in many of the meetings between the USAO and Epstein's 
counsel because Epstein's counsel "skipped her" in the chain of command, directing their 
communications to MAUSA9 
, Criminal Chief 
First 
Assistant Jeff 
and U.S. Attorney Alex Acosta. 
did participate in 
meetings with the Palm Beach Sheriff's Office about Epstein's work release and several 
conference calls with defendant attorney Roy Black and others about Epstein's breaches of 
the Non-Prosecution Agreement. 
MAUSA 
(now in private practice): MAUSA 
was my second-
line supervisor and head of the West Palm Beach office. Over the objection of myself and 
my co-counsel, he granted the request of Epstein's attorneys to meet to allow Epstein's 
attorneys to argue that the USAO should decline the matter. That began the series of 
meetings between all levels of the USAO and Epstein's counsel. MAUSA 
reviewed 
my work; asked me to conduct some specific research; and reviewed drafts of our responses 
to legal arguments raised by Epstein's counsel. MAUSA 
also participated in 
9 The Managing Assistant U.S. Attorney ("MAUSA") is the head of the West Palm Beach 
Office. 
Page 8 of 58 
EFTA00225051

conversations with the State Attorney, and directly participated in negotiations of the 
language to be used in the Non-Prosecution Agreement, federal Plea Agreement, and 
Information. He had numerous conversations with counsel for Epstein outside of my 
presence when they objected to my refusal to agree with their changes. MAUSA 
also communicated with the U.S. Attorney about the negotiations. He would then 
communicate changes from the defense and the U.S. Attorney to me to incorporate. Later, 
when E stein's attorneys appealed to AAa., 
Mr. 
was on detail as AAG 
Chief of Staff and facilitated the meeting between Epstein's counsel and the AAG. 
AAG Fisher's written response was issued while MAUSA 
was still her Chief of 
Staff. I do not know who drafted the written response. 
Acting MAUSA 
(still with the USAO): When MAUSA 
was on 
detail with AAG Fisher's Office, 
was named the Acting MAUSA. He 
participated in at least one meeting with Epstein's attorneys and the State Attorney. Mr. 
also was involved in some of the negotiations regarding the language of the Non-
Prosecution Agreement. He later reviewed at least one of the iterations of the indictment 
package and signed the indictment that was supposed to be presented to the grand July in 
June 2009. 
Criminal Chief Matthew 
(now in private practice): Criminal Chief-
was the third line supervisor of the matter. Generally, West Palm Beach indictments are 
reviewed and approved by the MAUSA and are not reviewed by Miami. However, unusual 
or especially significant indictments are reviewed by the Criminal Chief. Criminal Chief 
reviewed and commented on the first proposed indictment package. 
His 
comments were incorporated into I revised indictment, and he possibly reviewed those 
changes. Criminal Chief 
participated in numerous meetings on the case, and had 
private conversations regarding resolution of the matter with Lilly 
counsel 
to Mr. Epstein. Ms. 
had formerly served as Deputy Chief in the Major Crimes 
Section at the USAO while Mr. 
was Chief of Major Crimes. As discussed below, 
on July 26, 2007, Criminal Chief 
announced to the investigative team that U.S. 
Attorney Acosta had decided to offer I two-year plea to Mr. Epstein. On August 3, 2007, 
Mr. 
sent I letter to Ms. 
regarding that plea offer. Mr. 
left the 
U.S. Attorney's Office on that date to become partner at Kobre & Kim in New York. 
First Assistant Jeffrey 
(now in private practice): FAUSA 
(later U.S. 
Attorney 
was involved in telephone calls and meetings with counsel for Mr. 
Epstein; when Epstein's attorneys were dissatisfied with my proposed language for the 
Non-Prosecution Agreement, victim notification letters, letters to the Special Master, etc., 
they would frequently contact FAUSA 
directly to complain. FAUSA 
handled the bulk of the negotiations of the Addendum to the NPA. Epstein's attorneys 
later complained that FAUSA 
was biased because his daughter had been the victim 
of I crime. One of Epstein's attorneys also falsely accused FAUSA 
(and me) of 
promising money to l victim in exchange for her willingness to accuse Epstein. 
Page 9 of 58 
EFTA00225052

U.S. Attorney R. Alexander Acosta (now Secretary of the U.S. Department of Labor): 
USA Acosta served as the head of the U.S. Attorney's Office throughout the investigation 
of Jeffrey Epstein, including the decision to enter into I Non-Prosecution Agreement, 
negotiation of its terms, and attempts to enforce its terms. When Epstein's attorneys were 
dissatisfied with answers they received from me, MAUSA M, 
and FAUSA 
they would frequently contact USA Acosta directly. USA Acosta was directly involved in 
reviewing and revising the documents, including sending exact wording that he wanted 
incorporated into the agreement. There were some communications between USA Acosta 
and counsel for Epstein that I was not aware of at the time. For example, I did not know, 
until after I had sent I breach notice, that USA Acosta agreed that Epstein could be 
considered for work release. At some point after the NPA was signed, USA Acosta was 
recused from the Epstein matter. 
(still at USAO): Early in the investigation, I asked 
if he would serve as co-counsel on the case. Before I joined the West Palm 
Beach Office, 
had handled the bulk of the child exploitation cases in 
West Palm Beach. He and I discussed how to structure the investigation and he joined me 
in opposing meeting with Epstein's attorneys prior to the completion of the investigation. 
He attended some of the meetings with Epstein's attorneys. When the Office overruled 
our positions and when it appeared that the case was not going to be charged, 
decided that he should focus on other cases. 
(now U.S. Magistrate Judge): 
as my office 
neighbor and colleague. At one point early in the investigation (I be ievebefore I asked 
to serve as co-counsel), I sought 
counsel on strategies 
for how to handle Epstein's personal assistants — whether they should be charged or if we 
should seek immunity for them. Not long thereafter, 
came to me and said 
that he was best friends with one of Epstein's attorneys, Jack Goldberger, and accordingly 
could not discuss the Epstein case with me any further. 
left the U.S. 
Attorney's Office for private practice and later represented one of Epstein's assistants in 
the civil suits filed by Epstein's victims. 
ow retired): Asset Forfeiture 
assigned to the Epstein case. 
I had I ewbrief meetings with 
to talk about the asset forfeiture aspects of 
the case. We discussed the char es under consideration and Epstein's assets that could be 
subject to forfeiture. 
ad direct contact with the agents and the FBI's asset 
forfeiture coordinator about information/evidence that she needed to pursue forfeiture. 
provided the asset forfeiture language in the proposed indictments. 
ill at USAO): SLC 
was not directly involved in the Epstein 
investigation or negotiation of the NPA, but he has been lead counsel in the Jane Doe I 
United States litigation. SLC IN had contact with USA Acosta regarding his recusal, and 
Page 10 of 58 
EFTA00225053

with FAUSA 
and myself regarding self-reports to OPR about accusations of 
misconduct raised by Epstein's counsel. I also had contact with SLC 
regarding 
Florida Bar Complaint filed by I civil attorney for some of the victims who complained 
that my victim notification letters amounted to inappropriate business referrals to the 
attorney selected by the Special Master. lo 
Appellate SLC 
(still at USAO): SLC 
was not directly 
involved in the Epstein investigation or negotiation of the NPA. It is my understanding 
that USA Acosta asked SLC 
to check my legal analysis. I also understand that 
Criminal Chief 
contacted SLC 
about moving me to Appeals after I 
pointed out actions that I considered to be in violation of the Ashcroft memo and victims' 
rights legislation. I also understand that SLC 
ma have knowled e of USA Acosta 
providing my prosecution memorandum to 
Main 
Justice. 
(still at USAO): My legal assistant during most of the Epstein investigation 
and its aftermath. She assisted with preparing indictment packages, victim notification 
letters, grand jury subpoenas, travel, expert witness contracts, and other items. 
la 
still at USAO): Executive assistants to 
Acosta and FAUSA 
. They compiled correspondence between the USAO and 
counsel for Epstein; scheduled meetings; and dealt with inquiries from the press and DOJ. 
They may have information related to correspondence or communications between the 
Executive Division and Epstein's counsel that I am unaware of. 
FBI Personnel 
(retired from FBI): Lead case agent on Operation Leap Year. 
She presented the case to the USAO, handled the bulk of the interviews, served subpoenas, 
and testified before the grand jury. She communicated directly with victims and hand-
delivered the original victim notification letters. SI 
also participated in 
meetings with some of the 
members of the USAO and counsel for Epstein. 
SI Jason 
(still at FBI): Co-case agent with 
. Became lead 
case agent during the post-guilty plea period (i.e., the interview of 
responding to FOIA requests, etc.). He conducted interviews, prepared reports, analyzed 
1° The Florida Bar determined that my victim notification letters, which are included in the 
exhibits and advised the victims that they had the absolute right to select another attorney if they 
so desired, were not inappropriate solicitations and did not violate the Florida Bar Rules. The 
attorney who filed the complaint, Jeff Herman, later resigned from the Florida Bar due to 
disciplinary action taken against him. 
Page 11 of 58 
EFTA00225054

records, and communicated directly with victims. Si 
also participated in 
meetings with some of the 
members of the USAO and counsel for Epstein. 
ill at FBI): Co-case agent with SI 
until he was 
transferred to DC. He conducted interviews, including the original telephone interview 
with 
where she asked that the FBI have no further contact with her. He 
S/As 
andliiiso He also participated in meetings with some of the 
members of the USAO and counsel for Epstein. 
the July 26, 2007 meeting where Criminal Chief 
offer. 
She attended 
announced the two-year plea 
SI Christina 
: 
participated in the interview of 
in 
Australia. 
Sr't
(still at FBI): =imbiner 
was the case agent on Operation 
Stolen Globe, which involved the investigation of Alfredo Rodriguez (Jeffrey Epstein's 
butler), who tried to sell evidence to Brad Edwards. 
Supervisor 
etired from FBI): 
replaced GS 
s hea 
ng the post-guilty plea period. He supervised 
S/As 
Victim-Witness Coordinator 
: Ms. 
sent letters to victims, met with 
them in person, and assisted in finding counseling and other services for them. 
Justice Department Personnel 
CEOS Deputy Chief Alexandra 
(still at DOJ): Ms. 
was part of the team 
that reviewed the case and the NPA when Epstein "appealed" to DOJ. Ms. 
also is 
familiar with my work from I prior case that she and I worked on together as well as other 
PSC cases where I have consulted with her. 
CEOS Chief Drew 
(now private in-house counsel): Mr. 
reviewed and opined on the case and the NPA when Epstein "appealed" to DOJ. He also 
attended meetings in the SDFL with myself, the case agents, USAO supervisory staff, and 
counsel for Epstein. I conferred with Mr. 
about charging, staffing, and victim-
related issues. 
Page 12 of 58 
EFTA00225055

CEOS Trial Attorney 
(now at I non-profit): I first had contact with 
Ms. 
when conducting research regarding some of the legal issues raised by the case 
(she was the CEOS Duty Attorney on the day that I called). After 
left 
the case, I contacted Mr. 
about having I CEOS Trial Attorney co-chair the case 
and asked if Ms. 
was available. She participated in interviews, discussed case 
strategy, and reviewed pros memos and indictments. 
Millina
At various times, I have heard 
that USA Acosta provided my pros memo to Chiel 
and asked her to review my 
legal analysis. I have never asked Chief 
whether this actually occurred. SLC 
may know whether this occurred. 
ERMINIIIPINit (now in private practice): After CEOS rejected the "appeal" from 
Mr. Epstein's attorneys, they asked for further review by 
She met with the 
attorneys and prepared I written opinion rejecting Epstein's arguments. 
Associate De utv Attorney General Snow 
private in-house counsel): 
Following 
Epstein's attorneys asked for review by the DAG. I do 
not know whether Epstein's counsel met with the DAG, but they did present arguments to 
Mr. Roth, who was Chief of Staff/Sr. Associate Deputy Attorney General. It 
vrote 
letter rejecting Epstein's arguments. 
(now in private practice): -was 
the 
Deputy Attorney General to whom Mr. Epstein's arguments were addressed. As noted 
above, I do not know if 
met with Epstein's counsel, or if the meetings were only 
held with Mr. Roth. 
Others Whose Counsel I Sought During the Case: 
till an 
in Seattle): 
was not 
involved in the Epstein investigation. During the pendency of the Epstein investigation, 
she began investigating David Copperfield, who was I friend of Epstein, and we conferred 
with each other about strategy. I informed 
linof the difficulties in convincing the 
Office to prosecute Epstein. 
is I friend from my days at 
orseyWhitney. 
e join 
e usticeDepartment e ore I did and we have stayed in 
contact over the years. She had experience with USA Acosta when he was the head of the 
Civil Rights Section at Main Justice so I turned to her for advice in handling the Epstein 
situation. 
Assistant U.S. Attorney S. 
(still at DOJ): Mr. 
and I were dating at the time 
of the Epstein investigation. (We are now married.) He was I more 
who 
Page 13 of 58 
EFTA00225056

was familiar with some of Epstein's counsel. I sought his advice on some of the issues —
legal and non-legal — that arose during the case. 
Assistant U.S. Attorney 
(still at the USAO): Ms. 
and I 
are friends from my time in Miami. She was' supervisor in Miami although not in my 
chain of command. I would often speak or email with her just for advice. 
3. Explain fully the process and circumstances leading to the decision to resolve 
the case through I non-prosecution a reement (sometimes referred to by 
defense counsel and the government as I deferred prosecution agreement, but 
described herein as the non-prosecution agreement). 
Ex lain why the 
government initially prepared to resolve the case through 
federal plea 
agreement, but ultimately did not require Mr. Epstein to enter plea in federal 
court. The explanation should identify the parties involved in the decision, the 
individual(s) responsible for all final decisions regarding the non-prosecution 
agreement and its terms, and the basis for the decision to resolve the case 
through 
I
 
non-prosecution agreement. 
Let me preface with some background on how I normally handle investigations and 
prosecutions. When undertaking investigations, my normal practice is to meet with agents, confer 
with them about an investigative plan, and work together until the case is ready for indictment. I 
update my supervisors along the way, seek advice or guidance from supervisors and colleagues if 
an issue is especially complex or novel, and get approval for actions as required by the USAM, 
but I have always focused on learning as much as possible about the subject area, the defendant, 
and the facts related to the alleged crime — I want to be the subject matter expert in the courtroom. 
Then, once all of those items are completed, I prepare I comprehensive prosecution memo and 
proposed indictment, which are submitted for review. 
I believe strongly that investigations — especially child exploitation investigations - should 
be conducted as covertly as possible in order to protect the victims' privacy; to avoid harm to the 
accused's reputation if the accusation is determined to be false; and to maintain the sanctity of the 
investigation. In Mr. Epstein's case, these concerns were heightened for several reasons. First, 
victims identified during the state investigation had expressed fears of Epstein and building trust 
with them would require assurances that Epstein would not find out that they were talking with 
federal investigators. Second, the victims were between the ages of approximately 15 and 20" --
ages when women and girls might minimize or deny sexual abuse to avoid being labeled as "skits." 
Third, Epstein had made allegations in the state case that the victims were only after money and 
that investigators were only after fame. Maintaining the investigation's confidentiality would 
delegitimize both of those allegations. It also would avoid interference/intimidation by Epstein 
and his counsel. 
My confidentiality rule extends to pre-indictment communications with defendants and 
their attorneys. In cases where defendants are considered I flight risk, I generally have no contact 
pre-indictment. If proven, the crimes under investigation created I statutory presumption that the 
" They had been 14 to 17 years old at the time of the sexual activity, but time had passed. 
Page 14 of 58 
EFTA00225057

defendant was I risk of flight and I danger to the community, and Epstein had virtually unlimited 
resources to flee.12
Our effort to maintain the confidentiality of the investigation was thwarted almost 
immediately by PBPD Chief 
. On July 24, 2006, Chief 
sent letters to some of the 
victims identified in the state investigation informing them that the State Attorney's Office had 
decided to proceed on I single charge of solicitation of prostitution. (Exhibit 6.) Chief 
encouraged the victims to contact the State Attorney's Office with any complaints about the 
handling of the matter. Chief 
then felt the need to disclose that he did "not feel that justice 
has been sufficiently served by the indictment that has been issued. Therefore, please know that 
his [sic] matter has been referred to the Federal Bureau of Investigation to determine if violations 
of federal law have occurred." (Id.). While Chief 
did not mention the USAO, 
stein's 
counsel certainly understood that engaging the FBI meant engaging the USAO. Chief 
actions were published in the local newspaper. (Exhibit 7.) 
Because the federal investigation had been exposed by Chief = 
there was no ability 
to operate covertly, so we began serving subpoenas on persons and entities affiliated with Epstein. 
Beginning on August 2, 2006, 1 number of grand jury subpoenas were issued for bank information, 
information related to travel on Epstein's airplanes, school attendance records, rental car 
information, and other information that would corroborate statements made by victims (see Exhibit 
I 1). I subpoena also was issued for all of the evidence collected by the PBPD (see id.). Victim 
notification letters also were prepared that contained my contact information for the federal agents 
to provide to the victims identified during the PBPD investigation. (Exhibits 12 & 13.) As victims 
were interviewed by the federal agents, they would be provided with I copy of the notification 
letter. As additional victims were identified throughout the investigation, more letters were 
prepared. (Exhibits 19 & 30.) Subpoenas also were prepared for testimony and evidence from 
some victims who were believed to possess physical evidence that could corroborate contact with 
Epstein. (See Exhibit .1.) 
One of the subpoenaed victims was Individual #28, who is referred to as Jane Doe #2 in 
the Jane Doe. United States litigation. When approached for an interview, Individual #28 refused 
to speak with the agents, and I remember 
telling me that she felt that Individual 
#28 had tried to run over her foot as Individual #28 drove away. Individual #28 contacted Epstein 
when she received the letter and subpoena; Epstein put her in touch with his attorney, Jack 
Goldberger; and Goldberger had his friend, Jim Eisenberg, serve as Individual #28's lawyer while 
Epstein paid Eisenberg's fees. Individual #28 later told Brad Edwards that someone (Epstein, 
Goldberger, or Eisenberg) told her that "the government" planned to take away her baby. I don't 
know if that is true, but Eisenberg insisted that Individual #28 would not speak to us without 6001 
immunity. (Exhibit 9.) Once it was granted, Individual #28 spoke of Epstein in glowing terms 
and in I way contradicted by other witnesses and evidence. The hiring of Eisenberg, the insistence 
on 6001 immunity — something that I had never faced before or since for I child victim — and the 
false exculpatory statements — all showed me how the defense would be approaching this case. 
12 To minimize the risk of flight, I conducted research on extradition and the FBI placed
travel watch Epstein, but especially in light of Epstein's ownership of an airplane capable of 
intercontinental travel and his foreign residences, the investigative team considered Epstein to be 
I substantial flight risk. 
Page 15 of 58 
EFTA00225058

The subpoenas and interviews apparently concerned Epstein because soon after I began 
trying to set up Individual #28's testimony, Epstein hired former U.S. Attorney Guy Lewis, who 
began contacting me by phone and email, asking to meet with me. I declined to meet because it is 
my policy not to meet during the pendency of I child exploitation investigation. Mr. Lewis 
expressed his client's willingness to cooperate with the investigation. (Exhibit 10.) 
When Mr. Lewis was unable to set I meetin , Epstein hired Lilly 
, another 
former 
from the Miami USAO. Ms. 
began calling and emailing me in early 
November 2006. (Exhibit 11). Ms. 
also expressed Epstein's interest in "cooperating" 
with the investigation. I knew that feigned cooperation would be used to ask for pre-trial release, 
so I tested the veracity of the offer of cooperation l
sking for documents that would disprove 
many of Epstein's defenses.13 Sure enough, Ms. 
objected to the requests as "overbroad." 
I politely declined the request for I meeting and then delayed settingihe r uested meeting so 
that I would have time to complete the investigation. My co-counsel, 
and I agreed 
that I meeting at this early stage offered no benefit for us and only benefitted the defense. 
When Ms. 
could not set I meeting with me, she skipped my immediate supervisor 
and contacted MAUSA 
whom she knew from their time together in Miami. MAUSA 
Lefcourt. 
and I told MAUSA 
and me that he had agreed to meet with Ms. 
and Gerald 
told 
that we had made I conscious decision not 
to meet with Epstein's attorneys and that we were opposed to I meeti.was the first of many 
disagreements between management and the line AUSAs. MAUSA 
told us that we were 
"non-strategic thinkers" (his words) and that the meeting would result in convincing 
and 
Gerald Lefcourt to bring Epstein in for an interview. It was condescending and, in our opinion, 
showed I lack of understanding of sex offenders generally and I lack of knowledge of this case. 
Gerald Lefcourt has represented Martha Stewart — the last thing he would do is bring his client in 
to face I possible "perjury trap." 
In the middle of this period, which started in November 2006 and ran through January 
2007, USA Acosta and I traveled to Washington, DC at the beginning of December 2006 for the 
inaugural Project Safe Childhood Conference. Although I did not attach much significance to this 
at the time, in preparing this response, I began wondering whether the following event was 
orchestrated by Epstein and his counsel. During one of the first presentations at the conference, I 
was in I large auditorium and the speaker asked the audience I question. I man in the row in front 
of me introduced himself as the State Attorney from Palm Beach County (Barry 
and 
answered the question. I had never met Mr. 
. After the seminar ended, USA Acosta came 
over and we all introduced ourselves. Mr. 
proceeded to deride PBPD Chief 
and 
the victims in the Epstein case — referring to them by name and talking about how some were paid 
thousands of dollars, used alcohol and drugs, and looked over 18. I tried to guide the two out of 
the auditorium to I more private area because I did not think it was I conversation meant for public 
consumption but they would not move. As the PSC Coordinator, I had overseen the invitations 
13 For example, Epstein claimed that the massages were legitimate "medical" massages, so 
I wanted to see if he was taking tax deductions for medical expenses and getting other 
complementary medical treatment. Epstein also claimed that he was traveling to Florida to visit 
family and to maintain Florida residency. I asked for calendars and other documentation. 
Page 16 of 58 
EFTA00225059

for the law enforcement representatives from the S.D. Fla., and Mr. 
had not been on the 
list. So I now wonder whether this "random" meeting was staged by Epstein. 
As you will see from the timeline (Exhibit .1), in late January 2007, I created I file folder 
entitled "Research re NPAs and 6001 immunity." (Exhibit 15.) This was not research related to 
Non-Prosecution Agreements in connection with resolving the case against Epstein. In November 
and December 2006, subpoenas were served on two other Epstein employees — Janusz Banasiak 
and 
Mucinska. Both initially asked for immunity. After speaking with Banasiak's 
attorney, Mr. Banasiak was satisfied with I standard Kastigar letter, but Ms. Mucinska's attorney 
was insistent on formal immunity, and as noted above, so was Individual #28. I don't believe that, 
prior to this investigation, I had ever prepared' request for 6001 immunity, so I was researching 
the process. 
The meetingwith Ms. 
and Mr. Lefcourt was set for February 1, 2007. As noted 
above, despite Ms. 
statements of Epstein's willina to cooperate, she complained that 
my document requests were "overbroad," so MAUSA 
and I drafted I more specific list 
(Exhibit 14).14 Ms. 
also asserted that Epstein had hired attorneys for all of his current and 
prior employees, but refused to provide me with I list of those employees and attorneys, wanting 
me to give her essentially I roadmap of my investigation. I refused (Exhibits 14 and I-1). Instead, 
the agents and I continued to press forward with our investigation and I continued my extensive 
legal research in preparation for the meeting with 
and Lefcourt. 
Although materials were supposed to be provided in advance, the "talking points" for the 
meeting with 
and Lefcourt did not arrive until the morning of the February 1, 2007 
meeting (Exhibit 14 at 8-32). The main themes were: 
I. the PBPD investigation was biased; 
2. the conduct at issue was "entirely local"; 
3. Epstein did not know the victims were under 18; 
4. none of the girls traveled in interstate commerce; 
5. Epstein's travel was not for the purposes of engaging in illegal sexual activity; 
6. victim and witness credibility issues weighed against filing charges; and 
7. the Petite policy precluded prosecution (id.). 
While the letter covered all of these topics, I recall the meeting was focused primarily on 
challenges to the victims' credibility (e.g., one victim's MySpace page showed her smoking 
marijuana and posing provocatively); allegations of police overreaching; and the lack of evidence 
that Epstein knew the victims were under the age of 18. 
MAUSA 
, and I were unpersuaded by the letter and the 
presentation, but I agreed that I should carefully review transcripts of the recorded statements given 
to PBPD for Brady issues.15 Since witness credibility was clearly at the fore, I undertook efforts 
14 The requested documents and items were never provided. 
15 As the investigation continued and we located and identified more victims, we eventually 
made I strategic decision that the initial indictment should exclude the group identified by the 
PBPD and save them for I superseding indictment, if needed. At this point, however, the 
investigation was focused mainly on the same group. 
Page 17 of 58 
EFTA00225060

to corroborate our victim statements and to undermine Epstein's potential defenses through 
subpoenas for I wide variety of documents (see Exhibit &I). Subpoenas also were issued to some 
victims for photographs, gifts, and other records of direct or indirect contact with Epstein (see id.). 
Presentation of background information to the grand jury began in February 2007 (Exhibits 17, 
18, and 20). 
I continued to research potential charges against Epstein. Again, knowin how Epstein's 
attorneys would likely approach any trial in this matter, I wanted to prepare both I strong offense 
— by including all relevant charges for jury consideration and possible plea negotiations — and
strong defense — by including charges that would allow the admission of the widest range of 
relevant evidence. With that mindset, I researched money laundering and racketeering offenses in 
Chapter 95 because I knew that prostitution was I racketeering offense (see Exhibit 56). In 
addition to the IRS, I conferred with an attorney at the Asset Forfeiture and Money Laundering 
Section in DC who opined that Epstein's conduct could be l violation of 18 U.S.C. § 1960 and 2 
or another currency offense because he caused the interstate transmission of funds related to 
prostitution (see Exhibit 57).16
The investigation continued at 
brisk pace with Epstein's attorneys frequently seeking 
reviews from Messrs. 
and 
(see, e.g., Exhibit 58). [NB: They completely excluded 
my immediate supervisor, 
throughout the process.] Because of this, and because 
the grand jury was very interested in the case, I tried to keep the Miami office up to date on what 
was happening. There also had been little feedback from Miami to the proposed indictment that 
had al
irovided in late April/early May. So, for example, on May 14, 2007, I emailed 
and 
about Epstein's travel and asked whether I would be permitted to present the indictment 
the following day or proceed by way of criminal complaint (Exhibit 26 at I). Mr. 
made 
clear that neither would be allowed (id.). 
That Friday, May 18, 2007, I emailed Chief 
again, notifying him that we had 
learned that the computers missin  from Epstein's home at the time of the execution of the state 
search warrant were removed by I private investigator working for attorney Roy Black. After 
conferring with CCIPS, the Witness Immunity Unit at OEO, and my immediate supervisor, I 
planned to issue hrand jury subpoena for the equipment (id. at 2). I explained why the request 
was different than I subpoena to an attorney and how I would avoid seeking privileged information 
(id.). I specifically asked Mr. 
if he had any comments or concerns but received no 
response (id.)17
On Monday, May 21, 2007, I wrote to Chief 
and FAUSA 
for "guidance" 
and ". sense of the direction where we are headed" (id. at 3). Again, no response. On that day, 
having heard nothing in response to my 5/18/2007 email, I issued the subpoena to the private 
investigator (Exhibit 59). 
16 I mention this because my efforts to collect financial documents to support potential 
money laundering charges —and also to corroborate victim statements — were later used as evidence 
of my "overreaching." 
17 Again, I mention this because it would later be used — by Epstein's counsel and Chief 
— as evidence of overreaching. 
Page 18 of 58 
EFTA00225061

The following day, May 22, 2007, Mr. Lefcourt sent I letter to MAUSA 
stating: 
I understand from you that in the next month or two I decision will be made by 
your office whether to seek an indictment of Mr. Epstein. This will confirm that, 
prior to any such decision being made, I and other attorneys on behalf of Mr. 
Epstein will be given an opportunity to meet with you. 
Additionally, . . . if our meeting does not resolve the matter, we would like an 
opportunity to make I presentation first to Matthew 
, Chief of the Criminal 
Division, and Jeffrey 
First Assistant United States Attorney, and then, 
again, if no resolution is reached, the opportunity to meet with United States 
Attorney Alexander Acosta. 
(Exhibit 28.) 
and I were not part of the conversation where MAUSA 
disclosed 
the timeline to Mr. Lefcourt, so I was surprised by the letter, which sought multiple opportunities 
to meet with members of the Executive Division. Mr. 
responded, again, without meeting 
with 
or me, stating: "I think we are on the same page . . . I did say that if you 
want to meet with me again, I am ready to do so. The wording of your letter, however, suggests 
implicitly that I agreed to contact you before I decision is made to seek an indictment of Mr. 
Epstein. If that was your understanding, then please allow me to clarify. Our investigation is 
ongoing and if we decide to seek an indictment, we don't intend to call Mr. Epstein's 
representatives to let him know that. Of course, in the interim, if you would like to make
presentation to us, we are willing to listen. ..." (Id.). 
I strenuously objected and drafted an email setting forth the reasons why (id. . I shared it 
with my supervisor and she advised me not to send it. I orally advised MAUSA 
that I 
objected to meetings, delays, and strategic disclosures in I case like this one — I child exploitation 
case with I large number of victims. Nevertheless, the meeting was set for June 26, 2007. As I 
predicted, the defense asked Mr. 
for I list of our legal theories. I told him that I did not 
... 
want to share them, and Mr. 
directed me to give the defense the list anyway. On June 
18, 2007, I sent I letter to Gerald Lefcourt listing all the charges under investigation (Exhibit 53). 
On June 14, 2007, I emailed the supervisory chain an addendum to the prosecution memo, 
asked about whether they wanted me to revise the indictment, and asked what materials they 
wanted prepared in advance of the June 26, 2007 meeting (Exhibit 31 at 1). I don't believe I 
received any responses. 
On June 21, 2007, I emailed Chief 
again asking who would be attending the June 
26, 2007 meeting and how I could best prepare (id. at 3-4). I noted that he had been communicating 
directly with Ms. 
about the meeting (id.). 
On June 25, 2007, Gerald Lefcourt provided written arguments for why Epstein should not 
be charged federal) 
Exhibit 32). The following day, Alan Dershowitz, Roy Black, Gerald 
Lefcourt, and Lilly M 
presented their arguments to FAUSA 
and Chief 
Sil 
her supervisor, and I also attended (Exhibit 5). At some point during the 
meeting, Chief 
told the defense attorneys that they needn't address the money laundering 
statutes. I think he referred to them as "silly," without even having the benefit of my conversations 
Page 19 of 58 
EFTA00225062

with IRS and AFMLS and my legal research.18 
So Epstein's counsel focused on the child 
exploitation statutes. They falsely insisted that the use of the intemet was needed for 12422(b) 
charge and that some sort of force, fraud, or coercion was required for 11591 charge because 16-
and 17-year-old girls were "adults." They stated that there was no federal law prohibiting sex with 
children and one would be unconstitutional. 
After the meeting, MAUSA 
and I analyzed the materials (Exhibit 32). We both 
concluded that the defense had overstated the strength of their position (id.). MAUSA 
felt 
that the 2422(b) charges were stronger than the 2423(b) charges because we would need proof that 
having I sexual massage was I motivation for Epstein's travel (id.). My research showed that 
different circuits had different standards
 on the "purpose of travel" element (id.). I never 
received any feedback from Chief 
or FAUSA 
regarding Lefcourt's written 
presentation, but after the June 26, 2007 meeting, I was left with the impression that we were 
continuing towards indictment. 
On July 3, 2007, at 6:26 M., I sent an email to Jeff 
and 
advising them about calls I had received from Lilly 
seeking to delay subpoena 
responses and their plans to present our Office with additional analysis as well as their planned 
resolution with the State Attorney's Office (Exhibit 3). I informed eve one 
my proposed 
response regarding the subpoenas and that I intended to invite Lilly 
to call me to 
discuss I resolution of the federal investigation that could include concurrent time, i.e., I plea to I 
federal charge with I recommendation that the federal sentence would run concurrently with the 
state sentence (See id.) I asked whether anyone had had different conversations with any attorneys 
for Epstein so that there would not be any miscommunication. 
Later that afternoon, MI 
sent me an email (using Jeff 
Blackberry) that 
I  
read, "I told Lily that state plea with jail time and sex offender status may satisf the usa. It was 
non-starter for them 
Id. Because I was in trial, I did not see Mr. 
email, so 
aproposed email to Ms. 
, 
went out on July 4th at 4:07p.m. (Id.) After my email to Ms. 
email, and I responded with I vehement objection, telling 
him that I believed his plea offer was "completely unacceptable to the FBI, ICE, the victims, and 
me [and that these] plea negotiations violate the Ashcroft memo, the U.S. Attorney's Manual, and 
all of the various iterations of the victims' rights legislation." (Id.) I asked for the opportunity to 
make I presentation addressing the strengths of the case and the points raised by Epstein's 
attorneys - I felt that it was unfair that Epstein had been given numerous opportunities to meet 
with the management of the USAO and the victims had never had I similar chance (Id.) 
Mr. 
responded by reprimanding me, stating, "[Es you well know, the US Attorney 
has not even decided whether to go forward with I prosecution in this matter, thus you should have 
respected his position before engaging jr, 
negotiations." (Id.) I had not engaged in any plea 
negotiations, Mr. 
had. Mr.
also wrote, directly contrary to what USA Acosta 
and FAUSA 
told me at the initial meeting in Miami, "it was made clear to you by the US 
Attorney and the First Assistant from the time when you were first authorized to investigate Mr. 
Epstein that the office had concerns about taking this case because of petit [sic] policy and
number of legel issues. Despite being told these things, you reared I pros memo and indictment 
that included I definitive date for indictment." (Id.) Mr. 
also told me that my arguments 
IS Epstein's lawyers seized on this later. 
Page 20 of 58 
EFTA00225063