EFTA00226396

United States District Court 
SOUTHERN DISTRICT OF FLORIDA 
TO: 
SUBPOENA TO TESTIFY 
BEFORE GRAND JURY 
FGJ 05-02(WPB)-Fri./No. OLY-24 
SUBPOENA FOR:  
PERSON 
I X I DOCUMENTS OR OBJECTISI 
X 
YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District 
Court at the place, date and time specified below. 
PLACE: 
United States District Courthouse 
701 Clematis Street 
Wcst Palm Beach, Florida 33401 
ROOM: 
Grand Jury Room 
DATE AND TIME: 
December 1, 2006 
9:30 am 
YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s): 
Any and all records related to your employment with Jeffrey Epstein, including but not limited to 
paystubs, W-2 forms, correspondence, employment applications, and employment reviews. Any and all 
information regarding methods to contact Jeffrey Epstein directly or via any secretaries/assistants from 
1/1/2004 to the present, including but not limited to, telephone numbers, cellular telephone numbers, 
Blackberry addresses, e-mail addresses, and mailing addresses. Any and all information regarding 
appointments for massages performed on Jeffrey Epstein in Palm Beach, Florida or elsewhere. 
Please coordinate your compliance '
i
s 
d confirm the date and time , and location of 
your appearance with Special Agent 
, Federal Bureau of Investigation, Telephone: 
(561) 822-5946. 
This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting 
on behalf of the court. 
CLERK 
(BY) DEPUTY CLERK 
DATE: 
November 13, 2006 
This subpoena is issued upon application 
•If not applicable. ma ^none.' 
Name, Address and Phone Number of Assistant U.S. Attorney 
To be use' a int ofA0110 
5 
FORM ORD-227 
JAN.86 
Case No. 08-80736-CV-MARRA 
P-000213 
EFTA00226396

RETURN OF SERVICE' 
RECEIVED 
BY SERVER 
DATE 
PLACE 
SERVED 
DATE 
PLACE 
SERVED ON (NAME) 
SERVED BY 
TITLE 
STATEMENT OF SERVICE FEES 
TRAVEL 
SERVICES 
TOTAL 
DECLARATION OF SERVICE' 
I declare under penalty of perjury under the laws of the United States of America that the foregoing Information contained in the Return of Service and 
Statement of Service Fees is true and correct. 
Executed on 
DATE 
Signature of Server 
Address of Server 
ADDITIONAL INFORMATION 
1 As to who may serve a subpoena and the manner of Its service see Rule 17(d). Federal Rules of Criminal Procedure, or 
Rule 45(c), Federal Rules of Civil Procedure. 
2."Fees and mileage need not be tendered to the witness upon service of a subpoena Issued on behalf of the United 
States or an officer or agency thereof (Rule 45(c), Federal Rules of CND Procedure; Rule 17(d), Federal Rules of Criminal 
Procedure) or on behalf of certain Indigent parties and criminal defendants who are unable to pay such costs (28 USC 
1825, Rule 17(b) Federal Rules of Criminal Procedure)" 
Case No. 08-80736-CV-MARRA 
P-000214 
EFTA00226397

United States District Court 
SOUTHERN DISTRICT OF FLORIDA 
TO: 
SUBPOENA TO TESTIFY 
BEFORE GRAND JURY 
FGJ 05-02(WPB)-Fri./No. OLY-24 
SUBPOENA FOR: 
PERSON 
X 
X 
DOCUMENTS OR OBJECT($( 
YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District 
Court at the place, date and time specified below. 
PLACE: 
United States District Courthouse 
701 Clematis Street 
West Palm Beach, Florida 33401 
ROOM: 
Grand Jury Room 
DATE AND TIME: 
December I, 2006 
9:30 am 
YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s): 
Any and all records related to your employment with Jeffrey Epstein, including but not limited to 
paystubs, W-2 forms, correspondence, employment applications, and employment reviews. Any and all 
information regarding methods to contact Jeffrey Epstein directly or via any secretaries/assistants from 
1/1/2004 to the present, including but not limited to, telephone numbers, cellular telephone numbers, 
Blackberry addresses, e-mail addresses, and mailing addresses. Any and all information regarding 
appointments for massages performed on Jeffrey Epstein in Palm Beach, Florida or elsewhere. 
Please coordinate your compliance 
• 
• 
d confirm the date and time , and location of 
your appearance with Special Agent 
, Federal Bureau of Investigation, Telephone: 
(561) 822-5946. 
This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting 
on behalf of the court. 
CLERK 
(BY) DEPUTY CLERK 
Kos% Our 
DATE: 
November 13. 2006 
This subpoena is issued upon application 
non
•If not mastic:able, ma Woe-
Name, Address and Phone Number of Assistant U.S. Attorney 
To
 mod in le etA0110 
FORM ORD-227 
JAN.86 
Case No. 08-80736-CV-MARRA 
P-000216 
EFTA00226398

United States District Court 
SOUTHERN DISTRICT OF FLORIDA 
TO: 
SUBPOENA TO TESTIFY 
BEFORE GRAND JURY 
FGJ 05-02(WPB)-Fri./No. OLY-24-2 
SUBPOENA FOR: 
rd
PERSON 
r xi 
DOCUMENTS OR OBJECTISI 
YOU ARE HEREBY COMMANDED to appear and testifybefore the Grand Jury of the United States District 
Court at the place, date and time specified below. 
PLACE: 
United States District Courthouse 
701 Clematis Street 
West Palm Beach, Florida 33401 
ROOM: 
Grand Jury Room 
DATE AND TRAE: 
January 12, 2007 
9:30 arn• 
YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s): 
Any and all records related to your employment with Jeffrey Epstein, including but not limited to 
paystubs, W-2 forms, correspondence, employment applications, and employment reviews. Any and all 
information regarding methods to contact Jeffrey Epstein directly or via any secretaries/assistants from 
1/1/2004 to the present, including but not limited to, telephone numbers, cellular telephone numbers, 
Blackberry addresses, e-mail addresses, and mailing addresses. Any and all information regarding 
appointments for massages performed on Jeffrey Epstein in Palm Beach, Florida or elsewhere. 
*Please coordinate your compliance w't 
s 
nd confirm the date and time , and location of 
your appearance with Special Agent 
Federal Bureau of Investigation, Telephone: 
(561) 822-5946. 
This subpoena shall remain in effect until you arc granted leave to depart by the court or by an officer acting 
on behalf of the court. 
CLERK 
(BY) DEPUTY CLERK 
DATE: 
December 18, 2006 
This subpoena is issued upon application 
of the United Slates of 
•Ifnot appl tc able. enter 'none' 
TobtfdaliblavolA0116 
FORM ORD-227 
JANA6 
Case No. 08-80736-CV-MARRA 
1a-000219 
EFTA00226399

LAW OrriCES 
LYONS AND SANDERS 
CHARTERED 
DALE R. SANDERS • 
BRUCE M. LYONS •• 
HOWARD L. OREITZER 
EDWARD 0. BERGER 
11959-1907) 
'ALSO ^mimeo 
IN It/TORINO 
•• ALSO ADMITTED IN COLORADO 
February 14, 2007 
VIA US 
Re: 
600 NORTHEAST 
0 AVENUE 
1 
FORT LADMIRDALE. LORIDA 33301 
TELEPHONE (954) 487-8700 
TELEFAX 0154/ 783-4.58 
MAILING ADDRESS 
P. O. BOX 1778 
FORT LAUDERDALE. FL 33302-1778 
Grand Jury Subpoena 
Dear Ms. Villafana: 
on January 25, 2007, Agents" *Slater and 
with a grand jury'subpoena for my 
to appear on February 13,'2007. 
I 
indicate 
oss would assert her rights under the 
Fifth Amendment and on consent, the appearance has been 
extended. 
You have asked me to set out the basis for my 
request and that you apply thirugh appropriate channels for a 
ormal grant of use immunity or Ms. Ross. I do so here. 
As I indicated to you when we conversed last week, Ms. Ross is 
no longer employed by Mr. Epstein, but has read much of what 
can be found on the Internet about the investigation of Mr. 
Epstein. 
From that review, she is aware that the police 
considered charging several persons close to Mr. Epstein, 
including at least one employee. Given that, and the seemingly 
broad scope of the investigation, Ms. Ross asserts her rights 
under the Fifth Amendment. 
Indeed, considering that both the state authorities in Palm 
Beach County and your office are conducting investigations, 
there is every reason for her to be concerned and therefore to 
assert her constitutional rights. If you continue to want her 
to appear before a grand jury, be advised that she will assert 
Case No. 08-80736-CV-MARRA 
P-000220 
EFTA00226400

her rights under the Fifth Amendment unless there is a formal 
grant of immunity. 
If you should have any questions regarding the above, please 
feel free to contact me. 
Very truly your 
UCE M. LYONS 
BML/md 
Case No. 08-80736-CV-MARRA 
P-00022 I 
EFTA00226401

USAM 9-27.000. Principles of Federal Prosecution 
9-27.600 Entering into Non-prosecution Agreements in Return for Cooperation — Generally 
A. Except as hereafter provided, the attomcy for the government may, with supervisory approval, enter into a non-
prosecution agreement in exchange for a person's cooperation when, in his/her judgment, the person's timely 
cooperation appears to be necessary to the public interest and other means of obtaining the desired cooperation 
arc unavailable or would not be effective. 
B. Comment. 
Page I of 5 
I. In many cases, it may be important to the success of an investigation or prosecution to obtain the 
testimonial or other cooperation of a person who is himself/herself implicated in the criminal conduct 
being investigated or prosecuted. However, because of his/her involvement, the person may refuse to 
cooperate on the basis of his/her Fifth Amendment privilege against compulsory self-incrimination. In this 
situation, there are several possible approaches the prosecutor can take to render the privilege inapplicable 
or to induce its waiver. 
a. First, if time permits, the person may be charged, tried, and convicted before his/her cooperation is 
sought in the investigation or prosecution of others. Having already been convicted himself/herself, 
the person ordinarily will no longer have a valid privilege to refuse to testify and will have a strong 
incentive to reveal the truth in order to induce the sentencing judge to impose a lesser sentence than 
that which otherwise might be found appropriate. 
4
b. Second, the person may be willing to cooperate if the charges or potential charg against him/her are 
reduced in number or degree in return for his/her cooperation and his/her entry 
a guilty plea to the 
remaining charges. An agreement to file a motion pursuant to Sentencing Guideline 5K1.1 or Rule 
35 of the Federal Rules of Criminal Procedure after the defendant gives full and complete 
cooperation is the preferred method for securing such cooperation. Usually such a concession by the 
government will be all that is necessary, or warranted, to secure the cooperation sought. Since it is 
certainly desirable as a matter of policy that an offender be required to incur at least some liability 
for his/her criminal conduct, government attorneys should attempt to secure this result in all 
appropriate cases, following the principles set forth in USAM 9-27.430 to the extent practicable. 
c. The third method for securing the cooperation of a potential defendant is by means of a court order 
under 18 U.S.C. §§ 600126003. Those statutory provisions govern the conditions under which 
uncooperative witnesses may be compelled to testify or provide information notwithstanding their 
invocation of the privilege against compulsory self incrimination. In brief, under the so-called "use 
immunity" provisions of those statutes, the court may order the person to testify or provide other 
information, but neither his/her testimony nor the information he/she provides may be used against 
him/her, directly or indirectly, in any criminal case except a prosecution for perjury or other failure 
to comply with the order. Ordinarily, these "use immunity" provisions should be relied on in cases in 
which attorneys for the government need to obtain sworn testimony or the production of information 
before a grand jury or at trial, and in which there is reason to believe that the person will refuse to 
testify or provide the information on the basis of his/her privilege against compulsory self-
incrimination. See aSAM 9-23.000. Offers of immunity and immunity agreements should be in 
writing. Consideration should be given to documenting the evidence available prior to the immunity 
offer. 
d. Finally, there may be cases in which it is impossible or impractical to employ the methods described 
above to secure the necessary information or other assistance, and in which the person is willing to 
cooperate only in return for an agreement that he/she will not be prosecuted at all for what he/she has 
done. The provisions set forth hereafter describe the conditions that should be met before such an 
agreement is made, as well as the procedures recommended for such cases. 
Exhibit 15 
lutp://www.usdoj.gov/usao/cousa/foia_reading_room/usam/title9/27mcrm.htm 
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EFTA00226402

USAM 9-27.000. Principles of Federal Prosecution 
Page 2 of 5 
2. 
It is important to note that these provisions apply only if the case involves an agreement with a person who 
might otherwise be prosecuted. If the person reasonably is viewed only as a potential witness rather than a 
potential defendant, and the person is willing to cooperate, there is no need to consult these provisions. 
USAM 9-27.600 describes three circumstances that should exist before government attorneys enter into 
non-prosecution agreements in return for cooperation: the unavailability or ineffectiveness of other means 
of obtaining the desired cooperation; the apparent necessity of the cooperation to the public interest; and 
the approval of such a course of action by an appropriate supervisory official 
Unavailability or Ineffectiveness of Other Means. As indicated above, non-prosecution agreements are 
only one of several methods by which the prosecutor can obtain the cooperation of a person whose 
criminal involvement makes him/her a potential subject of prosecution. Each of the other methods--seeking 
cooperation after trial and conviction, bargaining for cooperation as part of a plea agreement, and 
compelling cooperation under a "use immunity" order--involves prosecuting the person or at least leaving 
open the possibility of prosecuting him/her on the basis of independently obtained evidence. Since these 
outcomes are clearly preferable to permitting an offender to avoid any liability for his/her conduct, the 
possible use of an alternative to a non-prosecution agreement should be given serious consideration in the 
first instance. 
Another reason for using an alternative to a non-prosecution agreement to obtain cooperation concerns the 
practical advantage in terms of the person's credibility if he/she testifies at trial. If the person already has 
been convicted, either after trial or upon a guilty plea, for participating in the events about which he/she 
testifies, his/her testimony is apt to be far more credible than if it appears to the trier of fact that he/she is 
getting off "scot free." Similarly, if his/her testimony is compelled by a court order, he/she cannot properly 
be portrayed by the defense as a person who has made a "deal" with the government and whose testimony 
is, therefore, suspect; his/her testimony will have been forced from him/her, not bargained for. 
In some cases, however, there may be no effective means of obtaining the person's timely cooperation 
short of entering into a non-prosecution agreement. The person may be unwilling to cooperate fully in 
return for a reduction of charges, the delay involved in bringing him/her to trial might prejudice the 
investigation or prosecution in connection with which his/her cooperation is sought and it may be 
impossible or impractical to rely on the statutory provisions for compulsion of testimony or production of 
evidence. One example of the latter situation is a case in which the cooperation needed does not consist of 
testimony under oath or the production of information before a grand jury or at trial. Other examples are 
cases in which time is critical, or where use of the procedures of 18 U.S.C. §?-6003 would unreasonably 
disrupt the presentation of evidence to the grand jury or the expeditious development of an investigation, 
or where compliance with the statute of limitat ions or the Speedy Trial Act precludes timely application 
for a court order. 
Only when it appears that the person's timely cooperation cannot be obtained by other means, or cannot be 
obtained effectively, should the attorney for the government consider entering into a non-prosecution 
agreement. 
3. Public Interest. If he/she concludes that a non-prosecution agreement would be the only effective method 
for obtaining cooperation, the attorney for the government should consider whether, balancing the cost of 
foregoing prosecution against the potential benefit of the person's cooperation, the cooperation sought 
appears necessary to the public interest. This "public interest" determination is one of the conditions 
precedent to an application under 18 U.S.C. § 6003 for a court order compelling testimony. Like a 
compulsion order, a non-prosecution agreement limits the government's ability to undertake a subsequent 
prosecution of the witness. Accordingly, the same "public interest" test should be applied in this situation 
as well. Some of the considerations that may be relevant to the application of this test are set forth in 
USAM 9-27.620. 
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1/22/2007 
EFTA00226403

USAM 9-27.000. Principles of Federal Prosecution 
Page 3 of 5 
4. Supervisory Approval. Finally, the prosecutor should secure supervisory approval before entering into a 
non-prosecution agreement. Prosecutors working under the direction of a United States Attorney must seek 
the approval of the United States Attorney or a supervisory Assistant United States Attorney. Departmental 
attorneys not supervised by a United States Attorney should obtain the approval of the appropriate 
Assistant Attorney General or his/her designee, and should notify the United States Attorney or Attorneys 
concerned. The requirement of approval by a superior is designed to provide review by an attorney 
experienced in such matters, and to ensure uniformity of policy and practice with respect to such 
agreements. This section should be read in conjunction with USAM 9-27,640, concerning particular types 
of casts in which an Assistant Attorney General or his/her designee must concur in or approve an 
agreement not to prosecute in ret urn for cooperation. 
9-27.620 Entering into Non-prosecution Agreements in Return for Cooperation - Considerations to be Weighed 
A. In determining whether, a person's cooperation may be necessary to the public interest, the attorney for the 
government, and those whose approval is necessary, should weigh all relevant considerations, including: 
I. The importance of the investigation or prosecution to an effective program of law enforcement; 
2. The value of the person's cooperation to the investigation or prosecution; and 
3. The person's relative culpability in connection with the offense or offenses being investigated or 
prosecuted and his/her history with respect to criminal activity. 
B. Comment. This paragraph is intended to assist Federal prosecutors, and those whose approval they must secure, 
in deciding whether a person's cooperation appears to be necessary to the public interest. The considerations 
listed here arc not intended to be all-inclusive or to require a particular decision in a particular case. Rather they 
are meant to focus the decision-maker's attention on factors that probably will be controlling in the majority of 
cases. 
1. Importance of Case. Since the primary function of a Federal prosecutor is to enforce the criminal law, 
he/she should not routinely or indiscriminately enter into non-prosecution agreements, which are, in 
essence, agreements not to enforce the law under particular conditions. Rather, he/she should reserve the 
use of such agreements for cases in which the cooperation sought concerns the commission of a serious 
offense or in which successful prosecution is otherwise important in achieving effective enforcement of the 
criminal laws. The relative importance or unimportance of the contemplated case is therefore a significant 
threshold consideration. 
2. Value of Cooperation. An agreement not to prosecute in return for a person's cooperation binds the 
government to the extent that the person carries out his/her part of the bargain. See Santobello v. New York 
404 U.S. 257 (1971); Wade v. United States, 112 S. Ct. 1840 (1992). Since such an agreement forecloses 
enforcement of the criminal law against a person who otherwise may be liable to prosecution, it should not 
be entered into without a clear understanding of the nature of the quid pro quo and a careful assessment of 
its probable value to the government. In order to be in a position adequately to assess the potential value of 
a person's cooperation, the prosecutor should insist on an "offer of proof' or its equivalent from the person 
or his/her attorney. The prosecutor can then weigh the offer in terms of the investi 
on or prosecution in 
connection with which cooperation is sought. In doing so, he/she should consider 
questions as 
whether the cooperation will in fact be forthcoming, whether the testimony or other information provided 
will be credible, whether it can be corroborated by other evidence, whether it will materially assist the 
investigation or prosecution, and whether substantially the same benefit can be obtained from someone 
else without an agreement not to prosecute. After assessing all of these factors, together with any others 
that may be relevant, the prosecutor can judge the strength of his/her case with and without the person's 
cooperation, and determine whether it may be in the public interest to agree to forego prosecution under 
the circumstances. 
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USAM 9-27.000. Principles of Federal Prosecution 
Page 4 of 5 
3. Relative Culpability and Criminal History. In determining whether it may be necessary to the public 
interest to agree to forego prosecution of a person who may have violated the law in return for that person's 
cooperation, it is also important to consider the degree of his/her apparent culpability relative to others who 
are subjects of the investigation or prosecution as well as his/her history of criminal involvement. Of 
course, ordinarily it would not be in the public interest to forego prosecution of a high-ranking member of 
a criminal enterprise in exchange for his/her cooperation against one of his/her subordinates, nor would the 
public interest be served by bargaining away the opportunity to prosecute a person with a long history of 
serious criminal involvement in order to obtain the conviction of someone else on less serious charges. 
These are matters with regard to which the attorney for the government may find it helpful to consult with 
the investigating agenc y or with other prosecuting authorities who may have an interest in the person or 
his/her associates. 
It is also important to consider whether the person has a background of cooperation with law enforcement 
officials, either as a witness or an informant, and whether he/she has previously been the subject of a compulsion order 
under 18 U.S.C. §?-6003 or has escaped prosecution by virtue of an agreement not to prosecute. The information 
regarding compulsion orders may be available by telephone from the Immunity Unit in the Office of Enforcement 
Operations of the Criminal Division. 
9-27.630 Entering into Non-prosecution Agreements in Return for Cooperation — Limiting the Scope of 
Commitment 
A. In entering into a non-prosecution agreement, the attorney for the government should, if practicable, explicitly 
limit the scope of the government's commitment to: 
1. Non-prosecution based directly or indirectly on the testimony or other information provided; or 
2. Non-prosecution within his/her district with respect to a pending charge, or to a specific offense then 
known to have been committed by the person. 
B. Comment. The attorney for the government should exercise extreme caution to ensure that his/her non-
prosecution agreement does not confer "blanket" immunity on the witness. To this end, he/she should, in the first 
instance, attempt to limit his/her agreement to non-prosecution based on the testimony or information provided. 
Such an "informal use immunity" agreement has two advantages over an agreement not to prosecute the person 
in connection with a particular transaction: first, it preserves the prosecutor's option to prosecute on the basis of 
independently obtained evidence if it later appears that the person's criminal involvement was more serious than 
it originally appeared to be; and second, it encourages the witness to be as forthright as possible since the more 
he/she reveals the more protection he/she will have against a future prosecution. To further encourage full 
disclosure by the witness, it should be made clear in the agreement that the government's forbearance from 
prosecution is conditioned upon the witness's testimony or production of information being complete and 
truthful, and that failure to testify truthfully may result in a perjury prosecution. 
Even if it is not practicable to obtain the desired cooperation pursuant to an "informal use immunity" agreement, 
the attorney for the government should attempt to limit the scope of the agreement in terms of the testimony and 
transactions covered, bearing in mind the possible effect of his/her agreement on prosecutions in other districts. 
It is important that non-prosecution agreements be drawn in terms that will not bind other Federal prosecutors or 
agencies without their consent. Thus, if practicable, the attorney for the government should explicitly limit the scope of 
his/her agreement to non-prosecution within his/her district. If such a limitation is not practicable and it can reasonably 
be anticipated that the agreement may affect prosecution of the person in other districts, the attorney for the 
government contemplating such an agreement shall communicate the relevant facts to the Assistant Attorney General 
with supervisory responsibility for the subject matter. United States Attorneys may not make agreements which 
prejudice civil or tax liability without the express agreement of all affected Divisions and/or agencies. See also 9-
16.000 et seq. for more information regarding plea agreements. 
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EFTA00226405

USAM 9-27.000. Principles of Federal Prosecution 
Page 5 of 5 
Finally, the attorney for the government should make it clear that his/her agreement relates only to non-
prosecution and that he/she has no independent authority to promise that the witness will be admitted into the 
Department's Witness Security program or that the Marshal's Service will provide any benefits to the witness in 
exchange for his/her cooperation. This does not mean, of course, that the prosecutor should not cooperate in making 
arrangements with the Marshal's Service necessary for the protection of the witness in appropriate cases. The 
procedures to be followed in such cases are set forth in USAM 9-21.000. 
9-27.640 Agreements Requiring Assistant Attorney General Approval 
A. The attorney for the government should not enter into a non-prosecution agreement in exchange for a person's 
cooperation without first obtaining the approval of the Assistant Attorney General with supervisory responsibility 
over the subject matter, or his/her designee, when: 
1. Prior consultation or approval would be required by a statute or by Departmental policy for a declination of 
prosecution or dismissal of a charge with regard to which the agreement is to be made; or 
2. The person is: 
a. A high-level Federal, state, or local official; 
b. An official or agent of a Federal investigative or law enforcement agency; or 
c. A person who otherwise is, or is likely to become of major public interest. 
B. Comment. USAM 9-27.640 sets forth special cases that require approval of non-prosecution agreements by the 
responsible Assistant Attorney General or his/her designee. Subparagraph (1) covers cases in which existing 
statutory provisions and departmental policies require that, with respect to certain types of offenses, the Attorney 
General or an Assistant Attorney General be consulted or give his/her approval before prosecution is declined or 
charges arc dismissed. For example, see USAM 6-4.245 (tax offenses); USAM 9-41.010 (bankruptcy frauds); 
USAM 9-90..020 (internal security offenses); (see USAM 9-2.400 for a complete listing of all prior approval and 
consultation requirements). An agreement not to prosecute resembles a declination of prosecution or the 
dismissal of a charge in that the end resu It in each case is similar: a person who has engaged in criminal activity 
is not prosecuted or is not prosecuted fully for his/her offense. Accordingly, attorneys for the government should 
obtain the approval of the appropriate Assistant Attorney General, or his/her designee, before agreeing not to 
prosecute in any case in which consultation or approval would be required for a declination of prosecution or 
dismissal of a charge. 
Subparagraph (2) sets forth other situations in which the attorney for the government should obtain the approval 
of an Assistant Attorney General, or his/her designee, of a proposed agreement not to prosecute in exchange for 
cooperation. Generally speaking, the situations described will be cases of an exceptional or extremely sensitive nature, 
or cases involving individuals or matters of major public interest. In a case covered by this provision that appears to be 
of an especially sensitive nature, the Assistant Attorney General should, in turn, consider whether it would be 
appropriate to notify the Attorney General or the Deputy Attorney General. 
http://www.usdoj.gov/usao/eousa/foia_reading_room/usam/title9/27mcrm.hun 
I /22/2007 
EFTA00226406

PART V-IMMUNITY OF WITNESSES 
Chapter 
Section 
601. Immunity of witnesses  
 6001 
HISTORICAL AND STATUTORY NOTES 
1970 Amendment 
Pub. L. 9r
2. Title 
§ 201(a), Oct. 15, 1970. 84 Stat. 
926, added 
V and items 6001 to 6005. 
CHAPTER 601-IMMUNITY OF WITNESSES 
Sec. 
6001. Definitions. 
6002. Immunity generally. 
6003. Court and grand jury proceedings. 
6004. Certain administrative proceedings. 
6005. Congressional proceedings. 
HISTORICAL AND STATUTORY NOTES 
1994 Amendments 
Pub.L. 103-322, Title )0()(III, § 330013(1), Sept. 13, 1994, 
109 Stat. 2146, added chapter heading. 
§ 6001. 
Definitions 
As used in this chapter—
(1) "agency of the United States" means any 
executive department as defined in section 101 of 
title 5, United States Code, a military department 
as defined in section 102 of title 5, United States 
Code, the Nuclear Regulatory Commission, the 
Board of Governors of the Federal Reserve System, 
the China Trade Act registrar appointed under 53 
•1.
432 (15 U.S.C. sec. 143), the Commodity 
Trading Commission, the Federal Commu-
nications Commission, the Federal Deposit Insur-
ance Corporation, the Federal Maritime Commis-
sion, the Federal Power Commission, the Federal 
Trade Commission, the Surface Transportation 
Board, tt raNn:tional Labor Relations Board, the 
National 
portation Safety Board, the Railroad 
Retirement Board, an arbitration board established 
under 48 Stat. 1193 (45 U.S.C. sec. 157), the Securi-
epi and Exchange Commission, or a board estab-
sed under 49 Stat. 31 (15 U.S.C. sec. 715d); 
(2) "other information" includes any book, paper, 
document, record, recording, or other material; 
. 
(3) "proceeding before an agency of the United 
States" means any proceeding before such an agen-
cy with respect to which it is authorized to issue 
subpenas and to take testimony or receive other 
' information from witnesses under oath; and 
(4) "court of the United States" means any of the 
following courts: the Supreme Court of the United 
States, a United States court of appeals, a United 
States district court established under chapter 5, 
title 28, United States Code, a United States bank-
ruptcy court established under chapter 6, title 28, 
United States Code, the District of Columbia Court 
of Appeals, the Superior Court of the District of 
Columbia, the District Court of Guam, the District 
Court of the Virgin Islands, the United States 
Court of Federal Claims, the Tax Court of the 
United States, the Court of International Trade, 
and the Court of Appeals for the Armed Forces. 
(Added Pub.L. 91-452, Title II, § 201(a), Oct. 15. 1970, 84 
Stat 926, and amended Pub.L. 95-406, § 25. Sept 30, 1978, 
92 Stat. 877; Pub.L. 95-598, Title III, § 314(I ), Nov. 6, 1978, 
92 Stat. 2678; Pub.L. 96-417, Title VI, `§ 601(1), Oct. 10, 
1980, 94 Stat. 1744; Pub.L. 97-164, Title 1, § 164(1), Apr. 2, 
1982, 96 Stat. 50; Pub.L. 102-550. Title 
, § 1543, Oct. 28, 
1992, 106 Stat. 4069; Pub.L. 102-572, Title DC, § 902(bX1), 
Oct. 29, 1992, 106 Stat 4519; Pub.L. 103-272, § 4(d), July 5, 
1994, 108 Stat. 1361; 
Pub.L. 103-322, Title XXXIII, 
§ 330013(2), (3). Sept- 13, 1994, 108 Stat 2146; Pub.L. 
103-337, Div. A, Title IX, § 924(d)(1)1B), Oct. 5, 1994, 108 
Stat. 2832; Pub.L. 104-88, Title III, § 303(2), Dec. 29, 1995, 
109 Stat. 943.) 
HISTORICAL AND STATUTORY NOTES 
Effective and Applicability Provisions 
1995 Acts. Amendment by Pub.L. 104-88 effective Jan. 1, 
1996, see section 2 of Pub.L. 104-88, set out as a note under 
section 701 of Title 49, Transportation. 
1992 Acts. Except as otherwise provided, amendment by 
Pub.L. 102-560 effective Oct 28, 1992, see section 2 of Pub.L. 
102-650, set out 1S a note under section 5301 of Title 42, The 
Public Health and Welfare. 
1982 Acts. Amendment by Pub.L. 97-164 effective Oct 1, 
1982, see section 402 of Pub.L. 97-164, set out as an Effec-
tive Date of 1982 Amendment note under section 171 of Title 
28, Judiciary and Judicial A ()sedum. 
1980 Acts. Amendment by Pub.L. 96-417 effective Nov. 1, 
1980, and applicable with respect to civil actions pending on 
or commenced on or after such date, see section 701(a) of 
Pub.L. 96-417, set out as an Effective Date of 1980 Amend-
ment note under section 251 of Title 28, Judiciary and 
Judicial Procedure. 
1978 Acts. Amendment by Pub.L. 95-698 effective Oct, 1, 
1979, see section 402(a) of Pub.L. 95-598, set out as an 
Effective Dates note preceding section 101 of Title 11, Bank-
ruptcy. 
Amendment by Pub.L. 95-405 effective Oct 1, 1978, see 
section 28 of Pub.L. 95-405, set out as an Effective Date of 
1978 Amendment note under section 2 of Title 7. Agriculture. 
Complete Annotation Materials, an Title IS, U.S.CA. 
1209 
• 
EFTA00226407

18 * 6001 
IMMUNITY OF WITNESSES 
Part 5 
1970 Acts. Section 260 of Pub.L. 91-452 provided that: 
"The provisions of part V of title 18, United States Code, 
added by title II of this Act [this part], and the amendments 
and repeals made by title 11 of this Act [sections 835. 89i, 
1406, 1954, 2424, 2514 and 3486 of this title, sections 16, 87( 
13.5e, 499rn(f). and 2115 of Title 7, Agriculture. section 25 f 
former Title 11. Bankruptcy, section 1820 of Title 12, Banks 
and Banking. sections 32, 33, 49, 77v, 78u(d). 79r(e), 80a-41, 
80b-9, 155, 717m, 1271. and 1714 of Title 15. Commerce and 
Trade, section srof of Title 16. Conservation, section 1333 of 
Title 19, Customs Duties, section 373 of Title 21, Food and 
Drugs. sections 4874 and 7493 of Title 26, Internal Revenue 
Code, section 161(3) of Title 29, Labor, section 506 of Title 
33, Navigation and Navigable Waters, sections 405(0 and 
2201 of Title 42, The Public Health and Welfare, sections 157 
and 362 of Title 45, Railroads, sections 827 and 1124 of TStle 
46, Shipping, section 409(1) of Tide 47, Telegraphs, Tele-
phones, and Radiotelegraphs, sections 9, 43, 46, 47. 48, 916, 
and 1017 of former Title 49, Transportation, and section 1484 
of Title 49, Appendix, section 792 of Title 50. War and 
National Defense, and sections 643a, 1152, 2026. and 2155(b) 
of Title 50, Appendix], shall take effect on the sixtieth day 
following the date of the enactment of this Act [Oct. IS, 
1970). No amendment to or repeal of any provision of law 
under tide II of this Act shall affect any immunity to which 
any individual is entitled under such provision by reason of 
any testimony or other information given before such day." 
Change of Name 
References to United States Claims Court deemed to refer 
to United States Court of Federal Claims and references to 
Claims Court deemed to refer to Court of Federal Claims, 
see section 902(b) of Pub.L. 102-572, set out as a note under 
section 171 of Tide 28, Judiciary and Judicial Procedure. 
Savings Provisions 
Amendment by section 314 of Pub.L. 95-598 not to affect 
the application of chapter 9 [§ 151 et seq.], chapter 96 
[§ 1961 et seq.], or section 2516, 3057, or 3284 of this title to 
any act of any person ( 
committed before Oct. 1, 1979, or 
(2) committed after Oct. 1. 1979, in connection with a Case 
commenced before such date, see section 403(d) of Pub.L. 
95-598, set out preceding section 101 of Title 11, Bankruptcy. 
Amendment or Repeal of Inconsistent Provisions 
Section 2.59 of Pub.L. 91-452 provided that "In addition to 
the provisions of law specifically amended or specifically 
repealed by this title [see Effective Date note set out under 
this section], any other provision of law inconsistent with the 
provisions of part V of title 18, United States Code (added by 
tide II of this Act) [this part], is to that extent amended or 
repealed." 
Abolition of the Atomic Energy Commission 
The Atomic Energy Commission was abolished and all 
functions were transferred to the Administrator of the Ener-
gy Research and Development Administration (unless other-
wise specifically provided) by section 5814 of Title 42, The 
Public Health and Welfare. 
The Energy Research and 
Development Administration was tenninated and functions 
vested by law in the Administrator thereof were transferred 
to the Secretary of Energy (unless otherwise specifically 
provided) by sections 7151(a) and 7293 of Title 42. 
Termination of Civil Aeronautics Board and Transfer of 
Certain Functior
All functions, 
wins, and duties of the Civil Aeronautics 
Board were terminated or transferred by former section 
1551 of Title 49, Transportation, effective in part on 
ec. 31, 
1981, in part on Jan. I. 1983, and in part on Jan. , 198.5. 
Termination of Federal Power Commission 
The Federal Power Commission, referred to in par. (1) was 
terminated and the functions, personnel, property, funds, 
etc.. thereof were transferred to the Secretary of Energy 
(except for certain functions which were transferred to the 
Federal Energy Regulatory Commission) by sections 
7151(6), 7171(a). 7172(a). 7291, and 7293 of Title 42, The 
Public Health and Welfare. 
Subversive Activities Control Board 
The Subversive Activities Control Board was established 
by Act Sept. 23. 1950. c. 1024, § 12, 64 Stat. 997, and ceased 
to operate June 30. 1973. 
§ 6002. 
Immunity generally 
Whenever a witness refuses, on the basis of his 
privilege against self-incrimination, to testify or pro-
vide other information in a proceeding before or ancil-
lary to—
(1) a court or grand jury of the United States, 
(2) an agency of the United States, or 
(3) either House of Congress, a joint committee 
of the two Houses, or a committee or a subcommit-
tee of either House, 
and the person presiding over the proceeding commu-
nicates to the witness an order issued under this title, 
the witness may not refuse to comply with the order 
on the basis of his privilege against self-incrimination; 
but no testimony or other information compelled un-
der the order (or any information directly or indirectly 
derived from such testimony or other information) 
may be used against the witness in any criminal case, 
except a prosecution for perjury, giving a false state-
ment, or otherwise failing to comply with the order. 
(Added Pub.L. 91-452, Title if, § 201(a), Oct. 16, 1970, 84 
Stat. 927, and amended Pub.L. 103-322, Title XXXIii, 
§ 330013(4), Sept. 13, 1994, 108 Stat 2146.) 
§ 6003. 
Court and grand jury proceedings 
(a) in the case of any individual who has been or 
may be called to testify or provide other information 
at any proceeding before or ancillary to a court of the 
United States or a grand jury of the United States, 
the United States district court for the judicial district 
in which the proceeding is or may be held shall issue, 
in accordance with subsection (b) of this section, upon 
the request of the United States attorney for such 
district, an order requiring such individual to give 
testimony or provide other information which he re-
fuses to give or provide on the basis of his privilege 
against self-incrimination, such order to become effec-
tive as provided in section 6002 of this title. 
Complete Annotation Matedals, see Thls 1% u.s.c.a. 
1210 
EFTA00226408

Ch. 601 
IMMUNITY OF WITNESSES 
18 § 6005 
(h) A I hilted States attorney may, with the approv-
al of the Attorney General, the Deputy Attorney 
General, the Associate Attorney General, or any des-
ignated Assistant Attorney General or Deputy Assis-
tant Attorney General, request an order under subsec-
tion (a) of this section when in his judgment—
(1) the testimony or other information from such 
individual may be necessary to the public interest; 
and 
(2) such individual has refused or is likely to 
refuse to testify or provide other information on the 
basis of his privilege against self-incrimination. 
(Added Pub.L. 91-452, Title ll, ¢ 201(a), Oct. 15, 1970, 84 
Stat 927, and amended Pub.L. 100-690. Title VII. 5 7020(e), 
Nov. 18, 1988, 102 Stat. 4396; Pub.L. 103-322, Title XXXIII, 
§ 330013(4), Sept. 13, 1994. 108 Stat. 2146.) 
§ 6004. 
Certain administrative proceedings 
(a) In the case of any individual who has been or 
who may be called to testify or provide other informa-
tion at any proceeding before an agency of the United 
States, the agency may, with the approval of the 
Attorney General, issue, in accordance with subsection 
(b) of this section, an order requiring the individual to 
give testimony or provide other information which he 
refuses to give or provide on the basis of his privilege 
against self-incrimination, such order to become effec-
tive as provided in section 6002 of this title. 
(b) An agency of the United States may issue an 
order under subsection (a) of this section only if in its 
judgment—
(1) the testimony or other information from such 
individual may be necessary to the public interest; 
and 
(2) such individual has refused or Ls likely to 
refuse to testify or provide other information on the 
basis of his privilege against self-incrimination. 
(Added Pub.L. 91-452, Title IL § 201(a), Oct. 15, 1970, 84 
Stat 927, and amended Pub.L. 103-3tZ, Title 
330013(4), Sept. 13, 1994, 108 Stat. 2146.) 
§ 6005. 
Congressional proceedings 
(a) In the case of any individual who has been or 
may be called to testify or provide other information 
at any proceeding before or ancillary to either House 
of Congress, or any committee, or any subcommittee 
of either House, or any joint committee of the two 
Houses, a United States district court shall issue, in 
accordance with subsection (b) of this section, upon 
the request of a duly authorized representative of the 
House of Congress or the committee concerned, an 
order requiring such individual to give testimony or 
provide other information which he refuses to give or 
provide on the basis of his privilege against self-
incrimination, such order to become effective as pro-
vided in section 6002 of this title. 
(b) Before issuing an order under subsection (a) of 
this section, a United States district court shall find 
that—
(1) in the case of a proceeding before or ancillary 
to either House of Congress, the request for such 
an order has been approved by an affirmative vote 
of a majority of the Members present of that 
House; 
(2) in the case of a proceeding before or ancillary 
to a committee or a subcommittee of either House 
of Congress or a joint committee of both Houses, 
the request for such an order has been approved by 
an affirmative vote of two-thirds of the members of 
the full committee; and 
(3) ten days or more prior to the day on which 
the request for such an order was made, the Attor-
ney General was served with notice of an intention 
to request the order. 
(c) Upon application of the Attorney General, the 
United States district court shall defer the issuance of 
any order under subsection (a) of this section for such 
period, not longer than twenty days from the date of 
the request for such order, as the Attorney General 
may specify. 
(Added Pub.L. 61-452, Title II, 1201(a), Oct. 15, 1970, 84 
Stat. 928, and amended Pub.L. 103-322, Title XXXIII, 
§ 330013(4), Sept 13, 1994, 108 Stat 2146; Pub.L. 104-292, 
§ 5, Oct. 11, 1996, 110 Stat 3460; Pub.L. 104-294, Title VI, 
605(0), Oct. 11, 1996, 110 Stat. 3510.) 
Complete Annotation Materials, see Title 18, U.S.C.A. 
1211 
EFTA00226409

United States District Court 
SOUTHERN DISTRICT OF FLORIDA 
TO: 
SUBPOENA TO TESTIFY 
BEFORE GRAND JURY 
FGJ 05-02(WPB)-Fri./No. OLY-24 
SUBPOENA FOR: 
PERSON 
X 
DOCUMENTS OR OBJECT'S] 
YOU ARE HEREBY COMMANDED to appear and testify before the G rand J ury of th e Un ited States Di strict 
Court at the place, date and time specified below. 
PLACE: 
United States District Courthouse 
701 Clematis Street 
Wcst Palm Beach, Florida 33401 
ROOM: 
Grand Jury Room 
DATE AND TIME: 
December 1, 2006 
9:30 am 
YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s): 
Any and all records related to your employment with Jeffrey Epstein, including but not limited to 
paystubs, W-2 forms, correspondence, employment applications, and employment reviews. Any and all 
information regarding methods to contact Jeffrey Epstein directly or via any secretaries/assistants from 
1/112004 to the present, including but not limited to, telephone numbers, cellular telephone numbers, 
Blackberry addresses, e-mail addresses, and mailing addresses. Any and all information regarding 
appointments for massages performed on Jeffrey Epstein in Palm Beach, Florida or elsewhere. 
ilt
Please coordinate your compliance ' 
• 
d confirm the date and time , and location of 
your appearance with Special Agent 
Federal Bureau of Investigation, Telephone: 
(561) 822-5946. 
This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting 
on behalf of the court. 
This subpoena is issued upon application 
Namc Address and P 
Attorney 
5 
•[ not applicable, enter 'none' 
To be mai stag a A 
OR -227 
JAN.86 
Case No. 08-80736-CV-MARRA 
P-000213 
EFTA00226410

RETURN OF SERVICE' 
RECEIVED 
BY SERVER 
DATE 
PLACE 
SERVED 
DATE 
PLACE 
SERVED ON (NAME) 
SERVED BY 
TITLE 
STATEMENT OF SERVICE FEES 
TRAVEL 
SERVICES 
TOTAL 
DECLARATION OF SERVICE' 
I declare under penalty of perjury under the laws of the United States of America Mal the foregoing information contained in the Return of Service and 
Statement of Service Fees is true and correct. 
Executed on 
DATE 
Signature of Server 
Address of Server 
ADDITIONAL INFORMATION 
lAs to who may serve a subpoena and the manner of Its service see Rule 17(d). Federal Rules of Criminal Procedure, or 
Rule 45(c), Federal Rules of CNII Procedure. 
2."Fees and mileage need not be tendered to the witness upon service of a subpoena Issued on behalf of the United 
States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Criminal 
Procedure) or on behalf of certain Indigent parties and criminal defendants who are unable to pay such costs (28 USC 
1825, Rule 17(b) Federal Rules of Criminal Procedure)" 
Case No. 08-80736-CV-MARRA 
P-000214 
EFTA00226411

United States 
SOUTHERN DISTRICT 
TO: 
YOU ARE HEREBY COMMANDED to appear 
Court at the place, date and time specified below. 
SUBPOENA 
District 
OF 
PERSON 
testify 
Court 
FLORIDA 
SUBPOENA 
BEFORE GRAND 
Fall 05-02(WPB)-Fri./No. 
FOR: 
r xi 
DOCUMENTS 
TO TESTIFY 
JURY 
OLY-24 
OR OBJECT [S 
Jury of the United States District 
I X i 
and 
before the Grand 
PLACE: 
United States District Courthouse 
701 Clematis Street 
West Palm Beach, Florida 33401 
ROOM: 
Grand Jury Room 
DATE AND TIME: 
December 1, 2006 
9:30 am 
YOU ARE ALSO COMMANDED to bring with you the following 
Any and all records related to your employment with Jeffrey 
paystubs, W-2 forms, correspondence, employment applications, 
information regarding methods to contact Jeffrey Epstein directly 
1/1/2004 to the present, including but not limited to, telephone 
Blackberry addresses, e-mail addresses, and mailing addresses. 
appointments for massages performed on Jeffrey Epstein 
Please coordinate your compliance liiiii 
d 
your appearance with Special Agent 
IIIIII, 
(561) 822-5946. 
This subpoena shall remain in effect until you are granted leave 
on behalf of the court. 
document(s) 
Epstein, 
and employment 
or via any 
numbers, 
Any and 
in Palm Beach, 
confirm the date 
Federal Bureau 
to depart by the 
or object(s): 
including but not limited to 
reviews. Any and all 
secretaries/assistants from 
cellular telephone numbers, 
all information regarding 
Florida or elsewhere. 
and time , and location of 
of Investigation, Telephone: 
court or by an officer acting 
• 
etspitij.
CLERK
•-• 
Ool t 
0 
i 
i 4 
S.: 
DATE: 
November 13, 2006 
(BY) DEPUTY CLERJC 
This subpoena is issued upon application 
of the U ' dStat 
f Ame ' 
Name, Address and Phone Number of Assistant U.S. Attorney 
'If 
'nom' 
boa of A0110 
FORM ORD-227 
JAN.86 
P-000216 
not applicable. alto 
To bnemele 
Casc No. 08-80736-CV-MARRA 
EFTA00226412

United States District Court 
SOUTHERN DISTRICT OF FLORIDA 
TO: 
SUBPOENA TO TESTIFY 
BEFORE GRAND JURY 
FGJ 05-02(WPB)-Fri./No. OLY-24-2 
SUBPOENA FOR: 
PERSON 
X 
X 
DOCUMENTS OR OBJECT'S] 
YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District 
Court at the place, date and time specified below. 
• 
PLACE: 
United States District Courthouse 
701 Clematis Street 
West Palm Beach, Florida 33401 
ROOM: 
Grand Jury Room 
DATE AND TIME: 
January 12, 2007 
9:30 am• 
YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s): 
Any and all records related to your employment with Jeffrey Epstein, including but not limited to 
paystubs, W-2 forms, correspondence, employment applications, and employment reviews. Any and all 
information regarding methods to contact Jeffrey Epstein directly or via any secretaries/assistants from 
1/1/2004 to the present, including but not limited to, telephone numbers, cellular telephone numbers, 
Blackberry addresses, e-mail addresses, and mailing addresses. Any and all information regarding 
appointments for massages performed on Jeffrey Epstein in Palm Beach, Florida or elsewhere. 
*Please coordinate your compliance .* 
• 
nd confirm the date and time, and location of 
your appearance with Special Agent 
, Federal Bureau of Investigation, Telephone: 
(561) 822-5946. 
This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting 
on behalf of the court. 
CLERK 
(BY) DEPUTY CLERK 
DATE: 
December 18, 2006 
This subpoena is issued upon application 
of the United States of America 
•Knot applicable. enter "none.` 
Name, Address and Phone Number of Assistant U.S. Attorney 
To beryl .r.. 
o(A0110 
FORM ORD-227 
JAN.86 
Case No. 08-80736-CV-MARRA 
P-000219 
EFTA00226413

LAW OFFICES 
LYONS AND SANDERS 
CHARTERED 
DALE R. SANDERS • 
BRUCE M. LYONS •• 
HOWARD L. ORCITZER 
COWARD 0. MERGER 
4195P-I9417) 
'ea° 
women° IN WYOMING 
•
ALSO ADMITTED IN COLORADO 
February 14, 2007 
600 NORTHEAST .3"17 AVENUE 
FORT LAUDIIILDAI.S. 
FLORIDA 
3300.1 
TELEPHONE 1954) 467-0700 
TELEFAX (984) 763-4056 
MAILING ADDRESS 
P. O. SOX 1778 
FORT LAUDERDALE, FL 33302-1776 
Re: Adrian Ross Grand Jury Subpoena 
Dear Ms. Villafana: 
indicate 
Fifth Amendment 
extended. 
You 
request and that 
formal grant of 
January 25, 2007, IIIIIIIIIIIIIIIlland 
with a grand jury subpoena for my 
to appear on February 13, 2007. 
I 
ss would assert her rights under the 
and on consent, the appearance has been 
have asked me to set out the basis for my 
you apply through appropriate channels for a 
use immunity for 
. I do so here. 
As I indicated to you when we conversed last week, 
is 
no longer employed by Mr. Epstein, but has read much o w at 
can be found on the Internet about the investigation of Mr. 
Epstein. 
From that review, she is aware that the police 
considered charging several persons close to Mr. Epstein, 
including at least one employee. Given that, and the seemingly 
broad scope of the investigation, Ms. Ross asserts her rights 
under the Fifth Amendment. 
Indeed, considering that both the state authorities in Palm 
Beach County and your office are conducting investigations, 
there is every reason for her to be concerned and therefore to 
assert her constitutional rights. If you continue to want her 
to appear before a grand jury, be advised that she will assert 
Case No. 08-80736-CV-MARRA 
P-000220 
EFTA00226414

her rights under the Fifth Amendment unless there is a formal 
grant of immunity. 
If you should have any questions regarding the above, please 
feel free to contact me. 
Very truly your 
UCE M. LYONS 
BML/md 
d 
2 
Case No. 08-80736-CV-MARRA 
P-000221 
EFTA00226415