EFTA00225102

Criminal Procedure 6(e) list, that is, someone who is authorized to have access to the facts of the 
investigation and the materials related thereto. 
8. 
As part of the Federal Grand Jury investigation, a subpoena was issued for all of the 
physical evidence obtained by PBPD during the course of its investigation, including the evidence 
seized when PBPD executed the search warrant at Epstein's residence in October 2005. Included 
in the evidence seized during the search of the Premises were the two CompactFlash memory cards. 
I have reviewed that evidence, which included a number of photographs of topless and nude young 
women taken at Epstein's residence. The evidence, including the two CompactFlash memory cards 
that are the subject of this application, have been in the custody of the Federal Bureau of 
Investigation since August 2006 and have not been tampered with or altered. Prior to that, they were 
in the custody of the Evidence Custodian of the Palm Beach Police Department, and I understand 
that the evidence was not tampered with or altered while in PBPD's custody. 
9. 
I note that I am aware that Epstein's attorneys have alleged that Detective Recarey 
made misstatements in his application for the state search warrant, but they have not moved to 
suppress any of that evidence in connection with the prosecution of Epstein by the State Attorney's 
Office for felony solicitation of prostitution. No federal agency was involved in the application for 
or execution of the search warrant, and this application is based upon evidence obtained through the 
FBI's independent investigation. 
10. 
During the course of the federal investigation, federal agents have interviewed more 
than two dozen young women who have reported engaging in sexual activity with Jeffrey Epstein 
while they were under eighteen. All of those girls have reported essentially the same information. 
While they were under the age of eighteen (between the ages of fourteen and seventeen), they were 
-5-
EFTA00225162

approached by a colleague — either an acquaintance at school, a co-worker, a "friend of a friend," or 
the like — who told them that they could make a lot of money performing a "massage" for a wealthy 
older man who lived on Palm Beach island. In some cases the girls were told that they would have 
to remove some clothing during the massage, other girls were not told about this. The girls traveled 
to Epstein's residence and entered through a side door into the kitchen of the residence. There they 
were met by Epstein and/or one of his personal assistants, usually MM. 
The girls would be 
led up to the master bathroom area of Epstein's bedroom. The bathroom had a separate room similar 
to a dressing area where a massage table would be set up. The girls described the presence of nude 
and topless photographs of young women throughout the house. Epstein would lie face down on the 
massage table and the girl would begin by massaging his back and legs. Epstein would then turn 
over and begin to masturbate while instructing the girl to pinch his nipples or to straddle him. In 
some cases, Epstein would place a large back massager/vibrator on the victim's vagina. With some 
girls, he would digitally penetrate her vagina while he masturbated. The sexual activity with some 
minors progressed to oral sex, sexual intercourse, and the introduction of an adult female into the 
activity. With some girls, the sexual activity began with the first massage; with others, there was no 
sexual activity at first but sexual activity occurred in later massages; and in many cases, Epstein 
pushed the girls to engage in more and more sexual activity with each visit. 
11. 
Almost all of the sexual massages ended the same way, when Epstein ejaculated. 
Epstein or one of his assistants would pay the girl $200 or more, depending on how much sexual 
activity occurred. A fee of $200 also would be paid to the "recruiter" who brought the girl for the 
visit. If Epstein liked the girl, he or his assistant would ask for the girl's telephone number. Later, 
one of Epstein's assistants would call the girl directly to arrange for the girl to return. In some 
-6-
EFTA00225163

instances of scheduling a girl for "work," which was a euphemism for performing a sexual massage, 
Epstein's assistants would make the arrangement for the next time that Epstein was in Florida. 
During those calls, the assistant would invite the girl to return to Epstein's home to "work." None 
of the girls ever spontaneously went to Epstein's home to provide a sexual massage. The 
appointments were set up over the telephone. 
12. 
The victims interviewed by the federal agents were asked about Epstein's knowledge 
that they were minors. Many of the victims specifically discussed their ages with Epstein, and he 
provided them with birthday gifts, made statements about trips that he wanted to take them on when 
they were eighteen, and discussed high school events and college plans with them. For other victims, 
the subject of age was never discussed, and for others, their "recruiter" instructed them to lie and say 
they were eighteen. 
13. 
One of the young women interviewed during the course of the FBI's investigation was 
"C" who stated that she first met Epstein at the age of fourteen. Epstein paid C 5200 - $400 to 
provide him with massages. According to C, during the three years that she saw Epstein, all but 
three of the over one hundred massages she provided were sexual in nature. The sexual activity 
ranged from self masturbation on Epstein's part to Epstein touching C's vagina. On a separate 
occasion, Epstein introduce an unidentified female during a massage, who performed oral sex on C 
while Epstein had sexual intercourse with the unidentified female. 
14. 
When C was approximately sixteen years old, ■ 
M, 
Epstein's assistant, 
contacted C and told her that Epstein wanted 
to take some photographs of her. 
utilizing a digital camera, took nude photographs of C in several different locations in and around 
Epstein's Palm Beach residence. 
paid C $500 for posing for the nude photographs. Other 
-7-
EFTA00225164

victims interviewed have repeatedly pointed to the existence of the pictures of nude and semi-nude 
women throughout the residence. 
15. 
Efforts have been made to corroborate the statements of C and the other young 
women who have described their sexual relationships with Epstein. With respect to C, there are 
telephone records showing 
phone calls to C during the time period that she was seeing 
Epstein. C also described receiving gifts from Epstein via Federal Express. A grand jury subpoena 
issued to Federal Express contained records of a number of packages sent by Epstein or his assistants 
to C. Likewise, the statements of other victims have been corroborated through telephone records, 
Western Union records, travel records, credit card receipts, sales records of theaters, and rental car 
records. 
16. 
Also, during the FBI's investigation, I interviewed a young woman, "M," who had 
known Epstein several years ago, when she was in her late teens/early twenties. The woman was a 
struggling artist in New York who was specializing in painting nude portraits. Prior to preparing a 
portrait, M would take several photographic studies. Epstein was very interested in her work and 
her photographs, and also expressed an interest in the artist's younger sister, "A," who was sixteen 
years old at the time. 
17. 
Epstein and an associate/companion, Ghislaine Maxwell, made arrangements and paid 
for A to travel to one of his homes, located in New Mexico. One morning during that visit, Epstein 
got into bed with A. Mr. Epstein told A that he felt like "cuddling." A described Epstein's actions 
as "spooning" and constantly hugging her. 
18. 
Epstein and Maxwell also made arrangements and paid for M to fly home to Arizona 
for the primary purpose of taking artistic photographs of her family members in the nude. This 
-8-
EFTA00225165

included the artist's younger siblings, two sisters, A and a younger sister, age 9 or 10, and two 
brothers. Due to the sensitive nature of the photographs, M created a photo log to document each 
image and the order it was taken. Later, M learned that seven photographs, two of A and five of the 
9 or 10 year old, were missing. M, who was very upset, contacted Epstein's office and asked for one 
of Epstein's assistants to look for the missing photographs. M also confronted Epstein and Maxwell 
about the missing photographs which they claimed they did not possess. A few weeks later M 
received a telephone call from an unidentified caller who stated that the missing photographs were 
in Epstein's briefcase. The missing photographs were not recovered and M believes that Epstein is 
in possession of them. Although those photographs were artistic, rather than pornographic in nature, 
this further shows Epstein's interest in taking and maintaining nude and semi-nude photographs of 
minors. 
19. 
I have interviewed M and A about their experiences with Epstein. Both M and A are 
reluctant to divulge their experiences publically. During the interview with A, she was visibly 
disturbed when recalling an incident with Epstein at his ranch in New Mexico when she was sixteen 
years old. A stated that one evening Epstein had come into her bedroom and sat on the bed. Epstein 
stroked her hair and told her she was beautiful. A was unable to recall the remainder of any events 
that evening. M has also expressed her concern of speaking publicly against Epstein for fear of 
reprisals against her or her family. 
The Items to Be Searched and the Information Sought 
20. 
This application seeks permission to forensically examine two CompactFlash memory 
cards. Your Affiant knows that electronic media, 
i.e., CompactFlash memory cards, may be 
important to a criminal investigation because the objects may be used as storage devices that contain 
-9-
EFTA00225166

contraband, evidence, instrumentalities, or fruits of a crime in the form of electronic data. Rule 41 
of the Federal Rules of Criminal Procedure permit the government to search for and seize computer 
hardware, software, and electronic files that are evidence of crime, contraband, instrumentalities of 
crime and/or fruits of crime. I know that CompactFlash memory cards are most often used in digital 
cameras to store photographs taken with the cameras. However, memory cards can be used to store 
any type of digital data, including computer files. 
21. 
The nature of electronic media, i.e., CompactFlash memory cards, requires forensic 
analysis to employ a variety of different starch techniques. These techniques include, but are not 
limited to, opening files, reviewing directories of files, and searching for and analyzing deleted 
and/or hidden information. While conducting the analysis, data will be continuously evaluated as 
to whether or not it is within the scope of the issued search warrant. Only information within the 
scope of the search warrant will be acknowledged, shared with, or provided to, the investigators 
involved in this matter. All other information will be closed and maintained within the analytical 
unit. Forensic analysis will be conducted in close consultation with the United States Attorney's 
office for specific legal guidance throughout the analytical and reporting process. 
22. 
I understand that reviewing the contents of the CompactFlash memory cards was 
within the scope of the State search warrant that gave rise to the seizure of the cards from Epstein's 
residence, and that PBPD reviewed the contents of the cards. I also understand that an FBI agent 
conducted a similar review when all of the items were taken into federal custody pursuant to the 
federal grand jury subpoena. Those reviews did not involve a forensic examination to determine if 
there were any deleted or corrupted files, which could be recovered only via such a forensic analysis. 
I understand that the cursory reviews performed by the other law enforcement officers did not delete 
-10-
EFTA00225167

or add any files to the CompactFlash memory cards and, therefore, they contain the same information 
that they had at the time they were removed from the Epstein residence. While the cursory review 
performed by the FBI agent did not exceed the scope of the PBPD's review, and therefore did not 
require the issuance of a warrant, the forensic review that is requested by this application would 
expand that review and, accordingly, your Affiant requests the issuance of a search warrant in 
accordance with United Stalest Jacobsen, 466 U.S. 109, 115-21 (1984). 
23. 
As explained above, Epstein instructed one of his assistants to photograph C using 
a digital camera; M reported Epstein's unusual interest in, and probable theft of, nude photographs 
of the minor members of her family; and Epstein engaged in inappropriate sexual activity with 
numerous minor females. In light of Epstein's display of photographs of nude and semi-nude young 
women throughout his residence, your Affiant avers that there is probable cause to believe that 
photographs or other evidence of the victims' visits to Epstein's residence may be found on the 
CompactFlash memory cards. Accordingly, your Affiant seeks permission to forensically examine 
the CompactFlash memory cards for evidence, instrumentalities, and fruits of the crimes listed 
above, that is, the electronic information contained within the memory cards, including electronic 
files containing photographs, owner identification information, date and time information, names, 
addresses, and information regarding the source of any photographs or the persons depicted in any 
photographs. 
24. 
Although the cursory reviews did not reveal any of the items sought, your Affiant 
avers that there is probable cause to believe that a thorough forensic examination, which would 
include the recovery of any deleted or corrupted files, would result in the discovery of the data listed 
above, which is evidence, instrumentalities, and fruits of the crimes under investigation. 
-11-
EFTA00225168

WHEREFORE, your Affiant requests that this court issue a search warrant for the 
CompactFlash memory cards described in the Application for Search Warrant and for the seizure of 
the items listed above. 
FURTHER YOUR AFFIANT SAYETH NAUGHT. 
Subscribed and sworn to before me 
this  
7  day of March, 2008 
A R. JOHN 
UNITED STATES 
STRATE JUDGE 
C 
,
u
A
r
i
a
-
u
n
E. Nesbi t Kuyrkendall, S cial Agent 
Federal Bureau of Investigation 
-12-
EFTA00225169

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
No.  08-8068-LIU
IN RE 
APPLICATION FOR SEARCH WARRANT 
FOR ONE PNY TECHNOLOGIES 
128 MEGABYTE COMPACTFLASH MEMORY CARD, 
MARKED THNCF128MMA(T00CB) 999223 TAIWAN 0247 
IN THE CUSTODY 
OF THE FEDERAL BUREAU OF INVESTIGATION 
CRIMINAL COVER SHEET 
1. 
Did this matter originate from a matter pending in the United States Attorney's Office prior 
to April 1, 1999? 
Yes 
X  No 
If yes, was it pending in the Central Region? 
Yes 
No 
2. 
Did this matter originate from a matter pending in the United States Attorney's Office prior 
to April 1, 2003? 
Yes _X_ No 
3. 
Did this matter originate from a matter pending in the Narcotics Section (Miami) of the 
United States Attorney's Office prior to May 18, 2003? 
Yes 
X No 
4. 
Did this matter originate from a matter pending in the Northern Region of the United States 
Attorney's Office prior to October 14, 2003? 
Yes 
X 
No 
5. 
Did this matter originate from a matter pending in the Central Region of the United States 
Attorney's Office prior to September 1, 2007? 
Yes  
X  No 
Respectfully submitted, 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
BY: 
ASSISTANT UNITED STATES ATTORNEY 
Florida Bar No. 0018255 
500 South Australian Avenue, Suite 400 
West Palm Beach, FL 33401 
TEL (561) 820-8711 
FAX (561) 802-1787 
EFTA00225170

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
08-8068-LRJ 
IN RE: 
SEARCH WARRANT APPLICATION 
ORDER GRANTING UNITED STATES' MOTION TO SEAL 
This matter comes before the Court upon the United States' Motion to Seal the 
documents related to its Search Warrant Application. The Court being fully apprised in the 
premises, orders that the motion is hereby GRANTED. 
DONE AND ORDERED in chambers, in West Palm Beach, Florida, this  / 7 day of 
March, 2008. 
cc: 
A. Marie Villafana, AUSA 
A R. JOHNSON 
UNITED STATES MAGISTRATE JUDGE 
EFTA00225171

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Wednesday, March 05, 2008 5:58 PM 
To: 
Kuyrkendall, E N. 
Subject: 
RE: Epstein update 
I don't think we have an issue with staleness because the memory cards are fixed 
(they haven't changed since the original search warrant). 
A. Marie Villafafia 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
 
Original Message 
From: Kuyrkendall, E N. 
Sent: Wednesday, March 05, 2008 5:55 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: Re: Epstein update 
I like your style! Unsure what communication btw Jeff and Jay is about?? Also do 
we have staleness issues with SW? 
 
 Original Message  
From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov> 
To: Acosta, Alex (USA); Sloman, Jeff (USA); Oosterbaan, Andrew (CRM); Senior, 
Robert (USA) 
Cc: Garcia 
lando (USA); Atkinson, Karen (USA) 
Sent: Wed 
05 16:54:35 2008 
Subject: Epstein update 
Hi all - I wanted to update you on a couple of new developments in the Epstein 
case. First, Jeff Herman is supposed to give a press conference today announcing 
the filing of a third lawsuit against Epstein. That case also involves a victim 
whom we are no longer referring to in the indictment [Drew - 
tell 
that to the defense.] Herman seems to have latched onto the 
group 
which, as discussed in my third addendum to the pros memo, we ave a rea y 
decided to forego for the most part. 
Drew - Since I am not certain of the scope of your meeting, I do not know how 
critical it is for you to see the new facts developed in the supplemental pros 
memos (you reviewed the initial pros memo from May of last year). If you would 
like the supplements, please let me know. The legal theories have remained the 
same. 
1455 
EXHIBIT B-121 
08-80736-CV-MARRA 
P-014656 
EFTA00225172

I also wanted to call to everyone's attention the three-year statute of 
limitations in Florida for the state solicitation offenses. The statute will run 
for all the victims this summer. Once it runs we cannot insist on a state court 
plea to a new charge. It al§o means that the state cannot charge the crimes 
related to the victims discovered after the initial investigation. We have asked 
the Palm Beach Police Department to forego presenting thdse charges for state 
prosecution in deference to our prosecution. If we do not intend to go forward, 
it is imperative that we communicate that to the Police Department as soon as 
possible so they can present those victims for state prosecution. 
I have reserved time with the grand jury on the 18th. I had hoped to present the 
indictment at that time, but in light of Jeff's communication with Jay, I will 
push it off until the 25th. I would still like to start the presentation on the 
18th so we aren't accused of rushing the grand jury. So; I hope that the final 
indictment packet will be approved by that date. 
Thank you. 
A. Marie Villafaha 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
1456 
08-80736-CV-MARRA 
P-014657 
EFTA00225173

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Friday, March 14, 2008 10:18 AM 
To: 
Garcia, Rolando (USAFLS) 
Subject: 
RE: Penalty sheets, bond recommendations, and all other forms for the indictment of J.E. el 
al. 
Hi Rolando -- Shawn e-mail everything down, but I think you should fax the cover 
sheet with your signature so Bob's signature can be on there with everyone 
else's. thanks. 
A. Marie Villafaha 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
 
Original Message 
From: Garcia, Rolando (USAFLS) 
Sent: Friday, March 14, 2008 9:43 AM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: Re: Penalty sheets, bond recommendations, and all other forms for the 
indictment of J.E. et al. 
I emailed him everything you sent me and told him that I have the hard copy of 
the indictment package. 
Sent from my BlackBerry Wireless Handheld 
 
 Original Message  
From: Villafana, Ann Marie C. (USAFLS) 
To: Garcia, Rolando (USAFLS); Atkinson, Karen (USAFLS) 
Sent: Fri Mar 14 09:30:23 2008 
Subject: FW: Penalty sheets, bond recommendations, and all other forms for the 
indictment of J.E. et al. 
Rolando - Didn't you send the entire packet to Bob? Everything was in the 
packet? 
A. Marie Villafaha 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
1348 
08-80736-CV-MARRA 
EXHIBIT 13-122 
P-014712 
EFTA00225174

From: Devlin, Frederica (USAFLS) 
Sent: Thursday, March 13, 2008 8:05 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: Penalty sheets, bond recommendations, and all other forms for the 
indictment of J.E. et al. 
Marie: 
Bob wants me to put the entire indictment together along with all the forms that 
goes with the indictment. I've printed the indictment and pros memos. I do not 
have any information for the concurrence sheet but I can get that later. 
Thanks. 
Tracking: 
1349 
08-80736-CV-MARRA 
P-0147B 
EFTA00225175

Villafana, Ann Marie C. (USAFLS) 
From: 
Ball, Shawn (USAFLS) 
Sent: 
Friday, March 14, 2008 10:00 AM 
To: 
Devlin, Frederica (USAFLS) 
Cc: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
RE: Operation Leap Year Ind Package 
F3 
Indictment Blue 
Sheet--.wpd 
One more, thanks. 
From: Ball, Shawn (USAFLS) 
Sent: Friday, March 14, 7008 9:59 AM 
To: Devlin, Frederica (USAFLS) 
Cc: Villafana, Ann Marie C. (USAFLS) 
Subject: Operation Leap Year Ind Package 
« File:07 103 conc-.wpd » « File: ArrestWarranKellen.pdf » « File: ArrestWarranMarcinkova.pdf » « File: 
ArrestWarranRoss.pdf » « File: ArrestWarrantE stein.pdf » « File: Bond Rec Form E s ein.w d » « File: Bond 
Rec Form =wed » cc File: Bond Rec Form Mwpd » « File: Bond Rec Form 
.wpd » « File: 
CertificateOfTrialAttorne .w d » « File: Epstein penalty sheet dated Feb 1 0 .wpd » « File: indictment cover 06 
version.wpd » « File: 
penalty sheet date Feb 19 08.wpd » « File: 
enalt sheet page 2 dated Feb 19 
08.wpd » « File: 
penalty sheet dated Feb 19 08.wpd » « File: 
penalty sheet page 2 dated 
Feb 19 08.wpd » « File: 
penalty sheet dated Feb 19 08.wpd » « Flle: 
penalty sheet page 2 dated Feb 19 
08 .wpd » 
1351 
08-80736-CV-MARRA 
P-014714 
EFTA00225176

Villafana, Ann Marie C. (USAFLS) 
From: 
Ball, Shawn (USAFLS) 
Sent: 
Friday, March 14, 2008 9:59 AM 
To: 
Devlin, Frederica (USAFLS) 
Cc: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
Operation Leap Year Ind Package 
/3 
07 103 
conc-.wpd 
if 
El 
FL 
ArrestWarranKel ArrestWarranMa ArrestWar anRo ArrestWarrantEpBond Rec Form 
len.pdf 
rcinkova.pdf 
ss.pd 
steln.pdf 
Epsteln.wpd 
El 
El 
El 
El 
El 
Bon
orm 
Certificate0fTria Epstein penalty ndictment cover 
penalty 
penalty 
pd 
lAttorney.wpd... sheet dated Fe...06 version.wp...The 
to Feb .. 
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a4Palty 
penalty 
na ty s eet a ema 
see pageiee 
ted Feb 1a 
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1353 
08-80736-CV-MARRA 
P-014715 
EFTA00225177

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
First Assistani U.S. Marne),
99 N.& 4th Street 
Miami, FL 33132 
(305) 961-9100 
DELIVERY BY FEDERAL EXPRESS 
June 3, 2008 
Honorable Mark Filip 
Office of the Deputy Attorney Genera; 
United States Department of Justice 
950 Pennsylvania Avenue, N.W. 
Washington, El 20530 
Re: 
Jeffrey Bigwig 
Dear Judge Fi lip, 
Jeffrey Epstein was a part-time resident of Palm Beach County, Florida.' In 2006, the Federal 
Bureau of Investigation began investigating allegations that, over a two-year period, Epstein paid 
approximately 28 minor females from Royal Palm Beach High School to come to his house for 
sexual favors.2 In July 2006, the matter was presented to AUSA A. Marie V illafaiia of our West 
Palm Beach branch office to pursue a krrnal criminal investigation. That investigation resulted in 
the discovery of approximately one do ''n additional minor victims. Over the last several months, 
approximately six more minor victims 
ve been identified. 
AUSA V i Ilafafla has been ready to present an indictment to a West Palm Beach federal grand 
jury since May 2007. The prosecution memorandum and proposed indictment have been extensively 
reviewed and re-reviewed by Southern District of Florida (SDFL) Deputy Chief of the Criminal 
Epstein has not resided in Palm Beach since he learned of the instant investigation. 
2 Epstein's sexual conduct with the V tints included: instructing them to massage and pinch his 
nipples, masturbating in their presence, di 
ly penetrating them, using a vibrator on their vaginas, 
engaging in oral sex with them, having the atims perform oral sex on Epstein's adult girlfriend, and 
engaging in sexual intercourse, all in exchange for money, ranging from $200 to $1,000 per session. 
Confidential and Privileged — Attorney Work Product 
EXHIBIT B-123 
EFTA00225178

Division Andrew Lourie, Chief of the Criminal Division Matthew Menchel', First Assistant United 
States Attorney Jeffrey H. Sloman', United States Attorney R. Alexander Acosta as well as various 
members of the Child Exploitation and Obscenity Section (CEOS) at the Department of Justice 
including, but not limited to its Chief, Andrew G. Oosterbahn. Many of these legal and factual issues 
have been discussed and approved by Deputy Assistant Attorney General for the Criminal Division 
(DAAG) Sigal Mandelker and the Assistant Attorney General for the Criminal Division (AAG) 
Alice S. Fisher, as well as the Criminal Division's Appellate Section and the Office of Enforcement 
Operations regarding the petit policy. 
By May 2007, AUSA Villafafia began seeking approval from her supervisors to indict 
Epstein. Her immediate supervisor was Andrew Lourie. Mr. Lourie had served as the Chief of the 
Public Integrity Section at DOJ as well as in several supervisory positions in the SDFL. By mid-
2006, he had returned to his position as the Deputy Chief of the Criminal Division in West Palm 
Beach (head of the West Palm Beach branch office), after serving as the interim Chief of the Public 
Integrity Section at DOJ at the request of AAG Fisher. By October 2007, Mr. Lourie would leave 
the SDFL to become AAG Fisher's Chief of Staff.' Above Mr. Lourie in the SDFL's chain of 
command were Matthew Menchel, Criminal Division Chief, First Assistant USA Sloman and finally, 
U.S. Attorney Acosta. 
Prior to seeking approval to return an indictment, Epstein's legal team had been actively 
working to convince this Office that such action was not warranted. For example, at the end of 2006, 
former SDFL U.S. Attorney and EOUSA Executive Director Guy Lewis contacted former colleagues 
AUSA Villafalla and, later Deputy Criminal Chief Lourie, when he learned that they were handling 
or involved in supervising the federal investigation of Epstein. In December, former SDFL AUSA 
Lilly Ann Sanchez and Gerald Lefcourt also contacted AUSA Villafafia to set a meeting. In advance 
of that meeting, AUSA Villafaita requested documents but that request was refused. Ms. Sanchez 
then contacted AUSA Lourie, who agreed to meet with Ms. Sanchez and Mr. Lefcourt. On February 
1,2007, Ms. Sanchez and Mr. Lefcourt met with AUSAs Lourie and Villafalta, as well as a member 
of the FBI, and presented defense counsel's view of the case and promised a willingness to assist in 
the investigation. The SDFL was unpersuaded by their presentation and the investigation continued. 
By the late Spring and early Summer, the focus of the investigation shifted from investigating 
the facts of the victims' claims to Epstein's background, his asserted defenses, co-conspirators, and 
possible witnesses who could corroborate the victims' statements. The investigation also began to 
look into financial aspects of the case, requiring the issuance of several subpoenas. At the time, Mr. 
Lefcourt began leveling accusations of improprieties with the investigation and sought a meeting 
'Mr. Menchel resigned for private practice on August 3, 2007 and was replaced by Robert 
Senior. 
'Although I, Jeffrey H. Sloman, am writing this letter, I will continue to refer to myself as 
"First Assistant USA Sloman" or "FAUSA Sloman" to help reduce any confusion. 
Rolando Garcia replaced Mr. Lourie as the Deputy Chief of the Criminal Division. 
Confidential and Privileged — Attorney Work Product 
-2-
EFTA00225179

with Criminal Division Chief Matthew Menchel. By that time, the proposed initial indictment 
package had been reviewed and approved by Mr. Lourie in West Palm Beach and by attorneys with 
CEOS; however, it awaited review by Mr. Menchel and FAUSA Sloman. The SDFL deferred 
presenting the indictment to the grand jury to accommodate the Epstein legal team's request for a 
meeting. We also agreed to wait several weeks for that meeting to occur to allow four of Epstein's 
attorneys to be present and also provided counsel with a list of the statutes that were the subject of 
the investigation. 
On June 26, 2007, Mr. Menchel, Mr. Lourie, AUSA Viliafafia, and FAUSA Sloman, and two 
FBI agents met with Alan Dershowitz, Roy Black, Gerald Lefcourt, and Lilly Ann Sanchez. During 
that meeting, Professor Dershowitz and other members of the defense team presented legal and 
factual arguments against a federal indictment. Counsel for the defense also requested the 
opportunity to present written arguments, which was granted. The arguments and written materials 
provided by the defense were examined by the SDFL and rejected. 
On July 31, 2007, Mr. Menchel, Mr. Lourie, AUSA Villafafia, and FAUSA Sloman, and two 
FBI agents met with Roy Black, Gerald Lefcourt, and Lilly Ann Sanchez. On that date, the SDFL 
presented a written sheet of terms that would satisfy the SDFL's federal interest in the case and 
discussed the substance of those terms. See Tab A. One of those terms was: 
Epstein agrees that, if any of the victims identified in the federal investigation file 
suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the U.S. 
District Court for the Southern District of Florida over his person and the subject 
matter. Epstein will not contest that the identified victims are persons who, while 
minors, were victims of violations of Title 18, United States Code, §§ 2422 and/or 
2423. 
During that meeting, the focus was on Mr. Epstein's unwillingness to spend time in prison, and 
various suggestions were raised by defense counsel, including the proposal that he could serve a 
sentence of home confinement or probation. This was repeatedly mentioned by counsel for Epstein 
as being equivalent to a term of imprisonment in a state or federal prison. Epstein's counsel 
mentioned their concerns about his safety in prison, and the SDFL offered to explore a plea to a 
federal charge to allow Epstein to serve his time in a federal facility. Counsel were also presented 
with a conservative estimate of the sentence that Epstein would face if he were convicted: an 
advisory guideline range of 188 - 235 months' incarceration with a five-year mandatory minimum 
prison term, to be followed by lifetime supervised release. Counsel was told that Epstein had two 
weeks to accept or reject the proposal. 
It is critical to note that Ms. Sanchez, one of Epstein's local lawyers, seized upon this method 
of restitution as a condition of deferring federal prosecution. In referring to the 18 U.S.C. § 2255 
method of compensation, Ms. Sanchez stated: 
(OW would allow the victims to be able to promptly put this behind them and go 
forward with their lives. If given the opportunity to opine as to the appropriateness 
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of Mr. Epstein's proposal, in my extensive experience in these types of cases, the 
victims prefer a quick resolution with compensation for damages and will always 
support any disposition that eliminates the need for trial. 
See attached Tab B, August 2, 2007 letter from Lilly Ann Sanchez to SDFL Criminal Division Chief 
Menchel, p.2, fn I. Ironically, it is Epstein's "national" attorneys who are now representing to the 
Deputy Attorney General of the United States in their May 19, 2008 letter that: 
Perhaps most troubling, the USAO in Miami, as a condition of deferring prosecution, 
required a commingling of substantive federal criminal law with a proposed civil 
remedy engineered in a way that appears intended to profit particular lawyers in 
private practice in South Florida with personal relationships to some of the 
prosecutors involved. 
Not only did Epstein's lawyers like the idea of using 18 U.S.C. § 2255 to compensate the victims 
but, they also sought to make their non-incarcerative state proposal even more attractive by offering 
payments to "a charitable organization benefitting victims of sexual assault," "law enforcement 
investigative costs" and "Court and probationary costs." Id. at p. 2. 
Epstein's counsel, still dissatisfied with the Office's review of the case, demanded to meet 
with U.S. Attorney Acosta and to have the opportunity to meet with someone in Washington, II. 
To accommodate Roy Black, the meeting was put off until September 7, 2007, despite the fac 
t 
the indictment was ready for presentation to the grand jury. In the interim, AUSA V illafafta and the 
investigators met with CEOS Chief Oosterbalm, to review, yet again, the evidence and legal theories 
of prosecution. Chief Oosterbahn strongly supported the proposed indictment and even offered to 
join the trial team and provide additional support from CEOS. 
On September 7, 2007, U.S. Attorney Acosta met with Kirkland & Ellis partners Jay 
Lefkowitz and former Solicitor General Ken Starr and Ms. Sanchez, along with Chief Oosterbahn 
and AUSAs Villafana, John McMillan, and FAUSA Sloman, Messrs. Starr and Leflcowitz presented 
arguments regarding the sufficiency of the federal interest in the case and other legal and factual 
issues. We discussed those legal arguments and the unanimous opinion of all of the attorneys present 
was in favor of prosecution. During that meeting, Mr. Lefkowitz also offered a plea resolution. His 
offer, in essence, was that Epstein be subjected to home confinement at his Palm Beach home, using 
private security officers who would serve as his "wardens," if necessary. Mr. Lefkowitz expressed 
the belief that such a sentence would be particularly appropriate because, as a wealthy white man, 
he may be the subject of violence or extortion in prison. Finally, Messrs. Starr and Lefkowitz 
expressed the belief that Epstein's extensive philanthropy should be considered in our prosecution 
decision. U.S. Attorney Acosta summarily rejected these proposals, and indicated that the 24-month 
offer presented previously by the SDFL stood. 
'Roy Black did not attend. 
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