EFTA00234570

Case 9:08-cv-80736-KAM 
Document 35 
Entered on FLSD Docket 12/22/2008 
Page 2 of 4 
4. 
On July 9, 2008, your Affiant sent a victim notification letter to Jane Doe #1, 
which contained pertinent language from "Part 3" of the Agreement (Ex. 6 to the July 9 
Decl.). 
5. 
Prior to preparing and sending that letter, your Affiant sent a draft of the letter 
to counsel for Jeffrey Epstein. On July 9, 2008, Mr. Epstein's attorney wrote to your Affiant 
objecting to parts of the draft, but accepting the part of the draft letter that contained the 
language from "Part 3" of the Agreement. Based upon that communication, your Affiant 
sent the victim notification letter to Jane Doe NI and attached it to your Affiant's July 9,2008 
Declaration. 
6. 
Although copies of all of the victim notification letters, including the one 
addressed to Jane Doe #1, were provided to Mr. Epstein's attorney, and despite the fact that 
counsel for Mr. Epstein filed a copy of your Affiant's July 9, 2008 Declaration in some of 
the civil suits filed against Mr. Epstein, none of Mr. Epstein's attorneys ever informed your 
Affiant that they considered the language in the letters and the Declaration to be inaccurate. 
7. 
In August 2008, in anticipation that the Court might order the United States to 
make the Agreement available to the victims, the United States sought to confirm that 
counsel for Mr. Epstein had filed the complete Agreement under seal with the State Court 
at the time of the entry of his guilty plea to the State charges, to insure that an exact copy of 
that Agreement would be provided in this case, should the Court order its production. 
EFTA00234650

Case 9:08-cv-80736-KAM 
Document 35 
Entered on FLSD Docket 12/22/2008 
Page 3 of 4 
8. 
On August 14,2008, Mr. Epstein's counsel communicated to your Affiant that 
Mr. Epstein did not consider the modification contained in "Part 3" to be operative. This was 
confirmed on August I8, 2008. 
9. 
Following that date, your A ffi ant prepared a corrected victim notification letter 
and worked with Mr. Epstein's counsel to resolve certain issues related to the implementation 
of the Agreement comprised only of "Parts 1 and 2." Those issues were resolved on 
September 2, 2008, and on September 3, 2008, your Affiant sent the corrected victim 
notification letter to Jane Doe 41 via her attorney, Brad Edwards, Esq. 
10. 
As explained in the July 9, 2008 Declaration, at the time that the Agreement 
was negotiated, Jane Doe #2 was represented by an attorney paid for by Mr. Epstein, and, 
accordingly, all contact with Jane Doe #2 was made through that attorney. 
I I. 
At the time that all portions of the Agreement were signed, Jane Doe #2 was 
openly hostile to the prosecution of Mr. Epstein and had provided a statement denying that 
she was a victim. Thus, she was not included in the list of victims provided to Mr. Epstein's 
counsel and did not receive either of the victim notification letters. She is, however, 
represented by Attorney Edwards who was informed of these developments and who 
received both the initial and corrected victim notification letters that were sent to Jane 
Doe #1. 
12. 
In accordance with the Court's instructions at the status conference of August 
14, 2008 and the terms of the Protective Order entered by the Court on August 21, 2008, 
EFTA00234651

Case 9:08-cv-80736-KAM 
Document 35 
Entered on FLSD Docket 12/22/2008 
Page 4 of 4 
beginning on September 2, 2008, I sent corrected Victim Notifications to all victims whom 
I knew to be represented by counsel. In those letters, I advised counsel of the Court's 
Protective Order and the procedure for obtaining a copy of the Non-Prosecution Agreement. 
Since that time, I have provided the Non-Prosecution Agreement to several attorneys, who 
represent twelve identified victims, and have received Protective Orders counter-signed by 
those attorneys and their clients. Two attorneys for other victims have not requested the 
opportunity to review the Non-Prosecution Agreement. Victims whom 1 believe are 
unrepresented have also received corrected Victim Notification letters that advise them of 
the existence of the Protective Order. No one has expressed to me any concerns regarding 
their access to the Non-Prosecution Agreement. 
13. 
I declare under penalty of perjury, pursuant to 28 U.S.C. § 1746, that the 
foregoing is true and correct to the best of my knowledge and belief. 
Executed this2b, j  day of December, 2008. 
A.A. Marie Villafafia, 
q. 
-4-
EFTA00234652

Case 9:08-cv-80736-KAM 
Document 35-2 
Entered on FLSD Docket 12/22/2008 
Page 1 of 2 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 08-80736-Civ-Marra/Johnson 
IN RE: JANE DOE, 
Petitioner. 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on December 22, 2008, I electronically filed the foregoing 
Supplemental Declaration of A. Marie Villafana with the Clerk of the Court using CM/ECF. 
According to the Court's website, counsel for all parties are able to receive notice via the 
CM/ECF system. 
s/A. Marie Villafalia 
A. MARIE VILLAFARA 
Assistant United States Attorney 
EFTA00234653

Case 9:08-cv-80736-KAM 
Document 35-2 
Entered on FLSD Docket 12/22/2008 
Page 2 of 2 
SERVICE LIST 
Jane Does I and 2'. United States 
Case No. 08-80736-CIV-MARRA/JOHNSON 
United States District Court, Southern District of Florida 
A. Marie Villafafia 
Assistant U.S. Attorney 
ann.marie.c.villafana@usdoj.gov 
U.S. Attorney's Office 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Telephone: (561) 820-8711 
Facsimile: (561) 820-8777 
Attorney for United States 
[Service via CM/ECF] 
-2-
Brad Edwards, Esq. 
be@bradedwardslaw.com 
The Law Offices of Brad Edwards & 
Associates LLC 
2028 
Street, Suite 202 
Hollywood, Florida 33020 
(954) 414-8033 
Fax: (954) 924-1530 
Attorney for Plaintiffs 
[Service via CM/ECF] 
Jay C. Howell 
Jay Howell & Associates PA 
644 Cesery Boulevard 
Suite 250 
Jacksonville , FL 32211 
Email: jay@jayhowell.com 
PRO HAC VICE 
[Service via CM/ECF] 
Paul G. Cassell 
Email: cassellp@law.utatLedu 
[Service via CM/ECF] 
EFTA00234654

Exhibit 19 
EFTA00234655

KIRKLAND & ELLIS LLP 
AND AMLIATED PARTNIASHIM 
Jay P. lefkowitz, P.C. 
To 
ly: 
lefk 
.corn 
VIA FACSIMILE 
Robert C. Josefsberg, Esq. 
Podhurst Orseck, P.A. 
City National Bank Building 
25 West Flagler Street, Suite 800 
Miami, FL 33130 
Dear Mr. Josefsberg, 
Citigroup Center 
153 East 53rd Street 
New York, New York 10022-4811 
wwwidrktand.00m 
September 8, 2008 
I write to inform you that Jeffrey Epstein has accepted the obligation of the NPA, 
including paragraph 7A of the Addendum, to pay the attorney representative for fees and 
expenses associated with consideration of and subsequent settlement of potential Section 2255 
claims. Please forward any current and future bills to me that relate to such work and I will 
arrange for payment. We reserve the right, in the future, to submit the bills to a neutral third 
party for review, but at present there is no need for such a procedure. 
Very truly yours, 
Chicago 
Kong Kong 
London 
Los Angeles 
Munich 
San Francisco 
Washington, D.C. 
EFTA00234656

Exhibit 20 
EFTA00234657

I. MICHAEL BURMAN. PA! 
GREGORY W. COLEMAN. PA. 
ROBERT D. CRITION. JRu
BERNARD LIMEDEICER 
MARK T. LUTTIER. PA. 
JEPPRBY C. PEPIN 
MICHAEL J. PIKE 
HEATHER McNAMARA RUDA 
FLORIDA MAID MIMED 
CIVR.TRIAL LAWYER 
BURMAN, CRITTON, LUTTIER 
& COLEMAN LLP 
A LIMITED LIABILITY PARTNERSHIP 
Sent by E-mail and U.S. Mail 
Robert Josefsberg, Esq. 
Podhurst Orseck, PA. 
25 West Flagler Street, Suite 800 
Miami, FL 33130 
Re: 
Epstein Matter 
Dear Bob: 
June 15, 2009 
ADELQUI J. BENAVENTE 
PARALIOAL/M55113.700. 
BARBARA M. McYJNNA 
ASHUB SIDKEN•BARMO 
BETTY STOKES 
PAPALZO&L1 
RITA H. BUDNTIC 
Or COUPRIA 
On June 8, 2009, Kathy Ezell wrote a letter to me regarding outstanding fee 
payment issues. At page 3, she stated that she was not adverse to an earlier proposal 
that had been discussed amongst the parties to rely on a Special Master to resolve 
outstanding fee-related Issues. We agree with Kathy's "proposal" that we rely on a 
Special Master to resolve all outstanding fee issues. Lets work during our Wednesday 
meeting to select an appropriate Special Master and let's agree to see whether, in the 
interim, we can resolve these issues even before they are submitted to the S.M. 
Cordially yo 
Robe 
. Callon, Jr. 
RDC/dz 
cc: 
Jack Goldberger, Esq. 
L •A•W•Y•E• 
R'S 
515 N. FLAMER DRIVE / SUM3 400 / WEST PALM BEACH, FLORIDA 33401 
TELEPHONE (561) 842-2820 FAX (561) 844-6929 
maiIebelclaw.com 
EFTA00234658

Exhibit 21 
EFTA00234659

KIRKLAND & ELLIS LLP 
AND AMLIARD PAIMWSMIPS 
Jay P. Lefkowit2 P.C. 
To 
• 
: 
I 
tz kirkland.com 
VIA FACSIMILE (305) 530-6444 
Honorable R. Alexander Acosta 
United States Attorney 
United States Attorney's Office 
Southern District of Florida 
99 NE 4th Street 
Miami, FL 33132 
Dear Alex: 
Ciegroup Center 
153 East 69rd Street 
New York, New York 10022-4611 
wwwldrldandtrom 
December 21, 2007 
Re: Jeffrey Epstein 
Facsimile: 
We again extend our appreciation for meeting with us on December 14 and for carefully 
considering the issues we have raised both at that meeting and in our submissions to your Office. 
Having received your letter of December 19, we can see that you have made a significant effort 
to address our concerns regarding the § 2255 portion of the non-prosecution agreement (the 
"Agreement"), and we recognize that you have proposed some substantial and important 
modifications. 
Respectfully, however, I would suggest that your proposal raises several 
troubling questions that require careful consideration. We are authoring this letter to respond to 
your request that we set forth our position regarding §§ 2255 and 3771 as quickly as possible. 
As we have all discovered, the problem of integrating in an unprecedented manner what 
is at its core a $150,000 minimum lump sum damage federal civil statute (§ 2255 in its current 
form) into a federal deferred/non-prosecution agreement that requires pleas of guilty to state 
criminal offenses that are correlated to state criminal restitution statutes but not to a disparate 
federal civil non-restitution statute has proved very challenging. The concomitant problem of 
how fairly to implement the § 2255 portions of the Agreement so that real victims, if any, who in 
fact suffered "personal injury as a result of [the] violation" —if any—of specified federal 
criminal statutes such as 18 U.S.C. § 2422(b) are placed in the same position as if there had been 
a trial and conviction also requires serious and careful consideration. In this letter, I want to 
highlight some specific concerns. See also Whitley Opinion. 
First, your proposal regarding the § 2255 remedy provisions continues to ask us to 
assume that each and every woman not only was a victim under 6 2255, but that the facts alleged 
could have been proven to satisfy each element of either § 2422(b) (the Internet luring statute) 
or § 2423 (the sex-tourism statute), within § 2255 of Title 18. Although we have been denied the 
Chicago 
Hong Kong 
London 
Los Angeles 
Munich 
San Francisco 
Washington, D.C. 
EFTA00234660

KIRKLAND &ELLIS LLP 
It Alexander Acosta 
December 21, 2007 
Page 2 
list of alleged "victims" (and lack definitive information as to which federal statutes would serve 
as a predicate for each particular alleged victim), or even a firm number as to how many you 
suggest there are, we strongly believe that the provable conduct of Mr. Epstein with respect to 
these individuals fails to satisfy the requisite elements of either 18 USC § 2422(b) (which we 
understand from prior discussions to be the principal predicate offense upon which the § 2255 
provisions rely) or 18 USC § 2423(b) (another predicate of § 2255 that has been the subject of 
discussions between the parties). See Stem Opinion. We believe that the problem arises from 
the incongruity that exists when attempting to fit a federal civil remedies statute into a criminal 
plea agreement. Again, I note that this problem could have been avoided had the government 
opted instead for a restitution fund as we suggested. 
Our knowledge of the "list" of alleged victims is limited 
However a prototypical 
example of a witness whom the government has requested we co 
nsate and we believe is 
inarrurately labeled as a "victim" of a federal crime is 
(whom we have been told 
remains on the government's "list"). The transcript of her interview with the Palm 
over a year before the FBI became involved in any investigation shows that Ms. 
admitted to lying about her age, that she did not engage in sexual intercourse with Mr. Epstein, 
and that she was never induced over the telephone computer or any other means of 
communication required by § 2422(b). In fact, Ms. 
came to Mr. Epstein's home on 
only one occasion. She testified that she was informed about the opportunity to give a massage 
to Mr. Epstein not on a telephone, computer or any other facility of intersta
terce, but 
rather in a face-to-face discussion with a third party who was her friend (Ms. 
and who 
told her to lie to Mr. Epstein about her age. As such, it is simply impossible to shoehorn this 
conduct into any of the above-discussed federal statutes. 
In addition, Mr. Epstein did not know of Ms. 
before she actually came to his 
home, did not induce or persuade her to come 
e, did not speak to her at all by phone prior 
to her visit, did not induce or persuade Ms. 
to bring an underage girl to his residence, 
and did not otherwise violate either the federal 
2422(b) n 
vel for the purpose 
statute § 2423 
Indeed, in her statement, Ms. 
testified: 
told me to say I was 
18 because 
1 you're not then he [Epstein] won't really let you in his house. So I 
said I was 
. 
Sworn Statement at 38-39). In fact, there is no evidence that Mr. 
Epstein expected an un erage girl to visit him prior to his regular travel to Florida, his home of 
fifteen years. Thus the travel could not have been for the purpose of having illegal sexual 
contact and § 2423(b) is no more available as a predicate for § 2255 recovery 1.122(b). 
Never having reached the threshold violations enumerated under of § 2255, Ms. 
would 
still have to 
ve that she suffered a personal injury. Further, unknown to Mr. Epstein at the 
time, Ms. 
represented herself to be 18 not only to him but also to the public on her web 
page where s e posted a nude photo clearly looking at least 18 years old. 
At the December 14 meeting, we also discussed 
as emblematic le 
concerns surrounding the government's selection of "victims." As you are aware, Ms. 
EFTA00234661

KIRKLAND & ELLIS LLP 
R. Alexander Acosta 
December 21, 2007 
Page 3 
was identified in previous correspondence as a person who remained on the Government's list of 
"victims" even after (at least according to Ms. Villafana's letter) the list was subjected to careful 
.multi-party review. Ms.. 
sworn statement clearly reflects the fact that she is not a 
"victim" under § 2422(b). She plainly admits that she suffered no injury; the conduct was 
consensual; she lied to Mr.. Epstein about her age; she instructed others to lie about their ages; 
there was no sexual contact between herself and Mr. Epstein at any time; and there was never 
any inducement over the telephone, computer or through any other means of interstate commerce 
We ask that you consider the most relevant highlights from her testimony offered below: 
• Consent 
A: I said, I told Jeffrey, I heard you like massages topless. And he's like, yeah, he 
said, but you don't have to do anythinahat you don't feel comfortable with. And I 
said okay, but I willingly took it off. I 
Sworn Statement at 10) 
• Lied About Her Age 
A: . . . I had a fake ID anyways, saying that 1 was 18. And she
 said make sure 
re
you' 18 because Jeffrey doesn't want any underage girls. 
Sworn Statement 
at 8) 
A:... of course, he thought I was 18. . . (= 
Sworn Statement at 13) 
• Instructed Others to Lie About Their Ages 
A: . . . I would tell my girlfriends just like 
approached me. Make sure you 
tell him you're 18. Well, these girls that I brow t, know that they were 18 or 19 or 
20. And the girls that I didn't know and I don'tii 
if they were lying or not, I 
would say make sure that you tell him you're 18. 
Sworn Statement at 22) 
• No Sexual Contact 
Q: He never pulled you closer to him in a sexual way? 
A: I wish. No, no, never, ever, ever, no, never. Jeffrey is an awesome man, no. 
Sworn Statement at 21) 
• No Inducement 
A: No, I gave Jeffrey my number. And I said, you kiity 
time you want me to 
give you a massage again, I'll more than welcome to. 
Sworn Statement at 8) 
EFTA00234662

KIRKLAND & ELLIS LLP 
it Alexander Acosta 
December 21, 2007 
Page 4 
A: Every 
 lthat I brought to Jeffrey, they said they were fine with it. And like, for 
instance, .= 
I 
a lot of girls begged me to bring them back. 
The wanted to come back for the money. And as far as I know, we all had fun there. 
Sworn Statement at 45) 
The sworn testimony of 
contains explicit denials from the alleged "victim" 
herself that she suffered any physical, emotional, or personal
 as required by the express 
language of § 2255. Further, the sworn testimony of Ms. 
contains a complete disavowal 
that Mr. Epstein or anyone on his behalf used a facility of interstate commerce to knowingly 
persuade, coerce, entice, or induce her to engage in sexual offenses as required by § 2422(b). 
Likewise, the transcript provides no basis for a § 2423(b) violation in that Mr. Epstein had a 
residence in Palm Beach for over 10 years at the time of these events, traveled to Palm Beach for 
a myriad of legitimate reasons ranging from medical appointments to business appointments 
having nothing to do with a sexual objective, and could not be legally charged with traveling to 
his own home particularly in the absence of any provable nexus between the travel and a 
dominant purpose to engage in illicit sexual conduct. Although Ms. Villafana informed us 
during the December 14 meeting that she had a telephone toll record showing an out-of-state call 
to or from Ms. 
phone to a phone number associated with Mr. Epstein, such a record fails 
to prove the content of the call the identity of the communicators, whether the call discussed or 
resulted in a plan for Ms. 
to visit Mr. Epstein's residence, whether any inducement 
occurred on the out of state call or, more importantly for purposes of the sex tourism
whether any travel was planned to Florida or resulted from the phone call. Ms. 
testimony is that she believed that at any time she was called by Mr.. Epstein or anyone on his 
behalf, Mr. Epstein was already in Florida. She also testified to the absence of any sexual 
contact other than topless massages (topless massages are lawful in Florida at age 16, unless the 
definition krostitution is unnaturally expanded). A complete transcript of the federal interview 
of Ms. 
has previously been provided to you. 
Your wish to put these women in the same position as they would have been had there 
been a federal conviction assumes they are each legitimate victims of at least one of the two 
specific federal crimes enumerated under § 2255. We respectfully have to disagree with that 
assumption, and even your current formulation of § 2255 would prejudice Mr. Epstein in this 
regard. 
Second, your proposal also effectively deprives Mr.. Epstein of his opportunity to test the 
validity of these womens' claims—claims that would have been 
tested at trial. In 
light of what we have already learned about 
and 
it is inappropriate 
to deny Mr.. Epstein and his counsel the ri t to test the merits of each of these womens' cases, 
in order to verify that they in fact suffered "personal injury" as required by § 2255 and to assess 
whether they are in fact victims of any violations of § 2422(b) or § 2423(b) as also required by 
EFTA00234663

KIRKLAND &ELLIS LLP 
R. Alexander Acosta 
December 21, 2007 
Page 5 
§ 2255. Given your Office's informing us that Ms. 
remained on a reduced list of federal 
"victims" and given our understanding that Ms. 
as well was one of those who is also 
on the list of persons the Government contends were victims of Mr. Epstein's alleged violation 
of federal law, we have a principled concern about adopting your recommended language which 
would leave Mr. Epstein without a basis to challenge the good faith premise of an application to 
recover $150,000. 
Third, the Agreement, even if modified in accord with your December 19 letter, would 
put the witnesses in a better position than if Mr. Epstein had been federally prosecuted rather 
than in an equal position and, in fact, encourages the witnesses to make unfounded claims with 
impunity. Had there been a conviction, these women would have been thoroughly cross-
examined, for the veracity of their statements, their credibility and the foundations, if any, for 
claiming personal injury. Also, Mr. Epstein would have received, pursuant to either Brady or 
Jencks, material in the form of prior inconsistent statements made by these women before they 
learned of any financial benefit that may be available to them—evidence that should be 
considered in determining the credibility of their application for a substantial civil recovery. 
Furthermore, Mr. Epstein would be without the means to challenge whether the claimant could 
make out a prima facie case that she was a victim of a violation by Mr. Epstein of § 2422(b) or 
'hi
ther federal statute—a denial of his rights that would insulate potential claimants such as Ms. 
and Ms. Milli 
from any challenge on this element even if under other circumstances a 
challenge would result in a summary judgment in Mr. Epstein's favor under Fed. R. Civ. P. 56. 
Lastly, the modified language recommended by you presupposes that Mr. Epstein would have 
been charged and convicted of substantive violations rather than charged and convicted of a 
conspiracy allegation. Conspiracy convictions are not amongst the predicates enumerated by 
§ 2255 and do not, without more, result in the basis for a determination of "personal injury". 
Since our request to view the draft indictment was rejected on December 14, we have no means 
to know what it contained by way of allegations. 
Fourth, I want to respond to several statements in your letter that we believe require 
immediate correction. With regard to your first footnote, I want to be absolutely clear. We do 
not believe for one moment that you had prior knowledge of the AUSA's attempt to require us to 
hire the friend of her live-in boyfriend, and pay his fees on a contingency basis to sue Mr. 
Epstein. We realize you corrected that irregular situation as soon as you discovered it. We 
thought this was precipitated by our complaint, but have no real knowledge as to the timing of 
events. Furthermore, your letter also suggests that our objection to your Office's proposed 
victims notification letter was that the women identified as victims of federal crimes should not 
be notified of the state proceedings. That is not true, as our previous letter clearly states. Putting 
aside our threshold contention that many of those to whom 3771 notification letters are intended 
are in fact not victims as defined in the Attorney General's 2000 Victim Witness Guidelines—a 
status requiring physical, emotional or pecuniary injury of the defendant—it was and remains our 
position that these women may be notified of such proceedings but since they are neither 
witnesses nor victims to the state prosecution of this matter, they should not be informed of 
EFTA00234664

KIRKLAND & ELLIS LLP 
R. Alexander Acosta 
December 21, 2007 
Page 6 
fictitious "rights" or invited to make sworn written or in-court testimonial statements against Mr. 
Epstein at such proceedings, as Ms.. Villafana repeatedly maintained they had the right to do. 
Additionally, it was and remains our position that any notification should be by mail and that all 
proactive efforts by the FBI to have communications with the witnesses after the execution of the 
Agreement should finally come to an end. We agree, however, with your December 19 
modification of the previously drafted federal notification letter and agree that the decision as to 
who can be heard at a state sentencing is, amongst many other issues, properly within the aegis 
of state decision making. 
Your December 19 letter references Professor Dcrshowitz's position on the 
inapplicability of Florida Statute § 796.03. Professor Dershowitz made such arguments in the 
context of saying that he had been unable to discern, after great effort, and supported by years of 
experience, any basis for the application of § 2422(b) or other federal sex statutes to Mr. 
Epstein's conduct and that the federal statutes required more of a stretch to fit the facts than the 
proposed state statute to which Ms. Villafana wanted Mr. Epstein to plead. 
Professor 
Dershowitz also stated that Ms. Villafana had represented that it was she who had the facts to 
support, both the threatened federal charges of § 2422 and/or § 2423 and the proposed state 
charge of § 796.03 (which the parties understood to be the state charge of soliciting a minor, as 
Ms. Villafana's last letter clearly states). Only last week we learned for the first time that Ms. 
Villafana did not realize that the charge was actually for "procuring" not "soliciting". The 
charge (a pimp statute) of procuring a prostitute for a third party for financial gain is one for 
which Ms. Villafana now states she does not have the facts to support. 
Furthermore, you suggest that we have purposefully delayed the date of Mr.. Epstein's 
plea and sentencing in breach of the Agreement and now seek an " 1 1 th hour appeal" in 
Washington. I believe we have already responded to this objection satisfactorily, both in our 
discussion earlier this week and in the email I sent to you two days ago in which I specifically 
addressed this issue. Indeed, any impediment to the resolution at issue is a direct cause of the 
disagreements between the parties as to a common interpretation of the Agreement, and we have 
at all times made and will continue to make sincere efforts to resolve and finalize issues as 
expeditiously as possible. In fact, since the initiation of negotiations between Mr.. Epstein's 
counsel and your Office, we have always proceeded in a timely manner and made several efforts 
to meet with the attorneys in your Office in person when we believed that a face-to-face meeting 
would facilitate a resolution. 
Finally, the suggestion by your staff that you hold Mr. Epstein in breach of the 
Agreement by his failure to plea and be sentenced on October 26, 2007 is directly contradicted 
by Mr.. Sloman's e-mail to me dated October 31 in which he states, "Your understanding from 
Jack Goldberger conforms to my understanding that Mr.. Epstein's plea and sentence will take 
place on the same day. I understand that the plea and sentence will occur on or before the 
January 4th date." This has been our common understanding for some time, which we have now 
EFTA00234665

KIRKLAND &ELLIS LLP 
R. Alexander Acosta 
December 21, 2007 
Page 7 
reiterated several times. With that said, please be advised that we are working for a quick 
resolution and do not seek to delay the proceedings. 
Thank you again for your time and consideration. We look forward to your response to 
the concerns we have raised that have not yet been addressed. 
I wish you a very happy and a healthy new year. 
Sincerely, 
y 
Lel-Io(0(
 tz 
cc : 
Honorable Alice Fisher, Assistant Attorney General 
Jeffrey H. Sloman, First Assistant U.S. Attorney 
EFTA00234666

Exhibit 22 
EFTA00234667

08/13/2008 21:36 FAX 1MM= 
u.s»err----omporipes FL 
KIRKLAND & ELLIS LLP 
N0.695 
e002/019 
P.2 
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
DELIVERY DY FACSIMILE 
Jay F. Lefitowitz, Esq. 
Kirkland & Ellis LLP 
Citigroup Center 
153 East 53rd Street 
New York, New York 10022-4675 
Re: 
Jeffrey Epstein 
Dear Jay: 
500 S Australian Ave, Ste 400 
Wart Palm Beach. FL 39401 
(561) 820-8711 
Paccar:Bei (561) 820-8777 
August 13, 2008 
As per your request, I am attaching several documents related to Mr. Epstein's performance 
of the Non-Prosecution Agreement. 
The first document attached hereto is the June 30, 2008 proposed Notification, which was 
hand-delivered to Jack Goldberger and Michael Tein shortly after Mt. Epstein entered hi s guilty plea. 
Following that, I have attached the July 9, 2008 response from Mr. Goldberger. I have 
highlighted two portions. The first is where Mr. Goldberger (presumably with the approval of Mr. 
Tein) approves of the portion of my proposed Notification that quotes directly from the U.S. 
Attorney's December letter to Lilly Ann Sanchez. The second portion is where Mr. Goldberger 
provides his interpretation of the Agreement, and nowhere mentions that he does not believe that the 
December letter is operative. I note that Mr. Goldberger's letter contains a notation showing that Mr. 
Epstein was provided with a copy. 
The third document I have attached is a copy of one of the notifications that was provided 
directly to a victim. Copies of all of the notifications have been provided to Mr. Goldberger, and 
neither he nor any other attorney for Mr. Epstein has ever stated that the letter misrepresents the 
Agreement between the parties or the benefit that the Agreement bestows upon the victims. 
The fourth document I have attached is a copy of a Declaration that I have filed in connection 
with the victims' lawsuit filed against the United States. This Declaration sets forth our 
understanding of the Agreement and again quotes from the U.S. Attorney's December letter. Messrs. 
Goldberger and Tein arc aware of this Declaration and have filed copies of it in connection with their 
EFTA00234668

08/13/2008 21.37 FAX 
KIRKLAND & ELLIS LLP 
Z003/0I9 
AUG.13.2008 
6:14PM 
USA() WPB FL. 
NO.695 
P.3 
JAY P. LEFKOWITL, ESQ. 
AuGum- 13, 2008 
PAGe 2 or 2 
efforts to stay all of the civil litigation. Again, neither of them ever expressed to me — or to the Court 
— that it inaccurately describes the Agreement between the United States and Mr. Epstein. 
Please contact me tomorrow morning so that we can resolve this issue. 
Sincerely, 
R. Alexander Acosta 
By: 
A. Marie Villaferfia 
Assistant United States Attorney 
cc: 
Karen Atkinson, Chief, Northern Division 
EFTA00234669