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This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →

FBI VOL00009

EFTA00181217

68 pages
Pages 1–20 / 68
Page 1 / 68
MARTIN G. WEINBERG, P.C. 
ATTORNEY AT MW 
20 PARK PLAZA, SUITE 1000 
ROSTON, MASSACUUSEITS 02116 
FAX 
NIGHT EAIERGRNCV: 
Assistant United States Attorney 
United States Attorney's Office 
Southern District of Florida 
500 S. Australian Ave. Suite 400 
West Palm Beach, Florida 33401 
Re: 
Jeffrey Epstein 
Dear Ms. 
July 22, 2011 
Roy Black forwarded to me your letter to him dated July 21, 2011, from the District 
Attorney of the County of New York. We thank you for providing notice of the intended 
disclosure but we do object to any disclosure of the Non-Prosecution Agreement and the related 
list of witness/victims on the basis of the confidentiality provisions of paragraph 13. Absent an 
enforceable subpoena - which we would have the right to move to quash in the Court from which 
it was issued - there exists no right or duty to disclose the confidential Non-Prosecution 
Agreement or the non-public witness/victim list which was referenced in paragraph 7 of the 
NPA. Further, given that the witness/victim list was compiled based on the federal grand jury 
investigation, we object under Fed. R. Crim. P. 6(e) to its disclosure absent an appropriate court 
order. 
Very truly yours, 
avic )21i id 
Martin G. Weinberg 
cc: Roy Black 
EFTA00181217
Page 2 / 68
07/22/2011 15:55 
3053582006 
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MARTIN C WEINBERG, P.C. 
ATTORNEY AT LAW 
Assistant United States Attorney 
United States Attorney's Office 
Southern District of Florida 
500 S. Australian Ave. Suite 400 
West Palm Beach, Florida 33401 
Re: 
Jeffrey Epstein 
Dear Ms. Villafafia: 
July 22, 2011 
EAVAILADDREMS 
Roy Black forwarded to me your letter to hlm dated July 21, 2011, from the District 
Attomey of the County of New York. We thank you for providing notice of the intended 
disclosure but we do object to any disclosure of the Non-Prosecution Agreement and the related 
list of witness/victims on the basis of the confidentiality provisions of paragraph 13. Absent an 
enforceable subpoena - which we would have the right to move to quash in the Court from which 
it was issued - there exists no right or duty to disclose the confidential Non-Prosecution 
Agreement or the non-public witness/victim list which was referenced in paragraph 7 of the 
NPA, Further, given that the witness/victim list was compiled based on the federal grand jury 
investigation, we object under Fed. R. Crim. P. 6(e) to its disclosure absent an appropriate court 
order. 
Very truly yours, 
/roadc 
VV 
Martin G. Weinberg 
cc: Roy Black 
EFTA00181218
Page 3 / 68
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15:55 
3053582006 
B S K S 
PAGE 01 
BLACK 
SPEBNICK 
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TRIAL ATTORNEYS 
Email: 
Roy Black 
Howard M. Srebnick 
Scott A. Kornspan 
Larry A. Stumpf 
Maria Neyra 
Jackie Perczek 
Mark A.J. Shapiro 
Jared Lopez 
Marcos Beaton, Jr. 
Jessica Fonseca•Nader 
Kathleen P. Phillips 
Jenifer J. Soulikias 
Noah Fox 
Joshua Shore 
FACSIMILERANSMITTAL SHEET 
FAX: ( 
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DATE: 
July 22, 2011 
SENDER: 
Jackie Perczek 
NO. OF PAGES (INCLUDING TRANSMITTAL SHEET): "IWO • 
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THIS PACSEMILE CONTADIA PRIVD.E0ED AHD C0NPIDENTIAL INTORMATIONANTENOED OMIT .POR THE:lust .OP THE 
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201 S. Biscayne Boulevard, Suite 1300, Miami. Florida 33131 1 (P) 305-371-G421 1 (F) 305-358-20051www.ioybiack com 
EFTA00181219
Page 4 / 68
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 S. Australian Ave, Ste 400 
West Palm Beach, FL 33401 
Facsimile: 
July 27, 2011 
DELIVERY BY FACSIMILE 
Martin G. Weinberg, Esq. 
20 Park Plaza, Suite 1000 
Boston, MA 02116 
Re: 
Jeffrey Epstein 
Dear Mr. Weinberg: 
Thank you for your letter of July 22, 2011. In order to review and address the objections that 
you raised in that letter, the Office deferred making its planned disclosure to the District Attorney 
of the County of New York of the Non-Prosecution Agreement ("Agreement") and the list of 
identified victims that was provided to Mr. Epstein pursuant to the Agreement. Nonetheless, after 
completing a full review of your objections, the Office still intends to proceed with the planned 
disclosures. 
The Agreement requires the Office only to provide Mr. Epstein with notice prior to a 
disclosure of the Agreement "[i]f the United States receives a Freedom of Information Act request 
or any compulsory process"; the Agreement does not require Mr. Epstein's concurrence in any 
disclosure. Contrary to your suggestion, the Agreement (including paragraph 13) also does not make 
the Agreement itself "confidential." On the contrary, the Agreement expressly contemplates that 
disclosures of the Agreement may be made, and the Agreement further contemplates, contrary to 
your suggestion, that such disclosures of the Agreement may be made other than in response to 
"compulsory process." Here, moreover, the District Attorney of the County of New York, as a local 
law enforcement agency, has provided a legitimate request for disclosure of the requested 
information, as well as a promise to maintain the confidentiality of the information, particularly the 
names of the minor victims. 
Your objection pursuant to Federal Rule of Criminal Procedure 6(e) also does not impact the 
planned disclosures. The victim list itself is not grand jury material, and, thus, disclosure of that list 
to the District Attorney's Office will not violate Rule 6(e). 
If you wish to supply any additional authority (other than citation to Rule 6(e) and to 
paragraph 13 of the Agreement) for your claims that the Office cannot disclose the Agreement and 
EFTA00181220
Page 5 / 68
MARTIN WEINBERG, ESQ. 
JULY 27, 2011 
PAGE 2 OF 2 
the victim list to the District Attorney of the County of New York, we would be willing to consider 
those authorities before making any disclosure, provided that any such authorities are furnished to 
us before 5:00 p.m. on July 29, 2011. Otherwise, seeing no obstacle to the previously-planned 
disclosures, the Office will be disclosing copies of both the Non-Prosecution Agreement and the list 
of identified victims that was provided to Mr. Epstein to the District Attorney of the County of New 
York at 5:00 p.m. on July 29, 2011. 
Sincerely, 
Wifredo A. Ferrer 
cc: 
United States Attome 
By: 
Assistant United States Attorney 
Chief, Northern Division 
Deborah L. Morse, Assistant District Attorney, County of New York 
Roy Black, Esq. 
EFTA00181221
Page 6 / 68
United States Attorney's Office 
Southern District of Florida 
500 S. Australian Ave., Suite 400 
West Palm Beach, FL 33401-6235 
DATE: -1
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TO: 
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ORGANIZATION: 
FAX #: 
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NUMBER OF PAGES, INCLUDING THIS PAGE:  
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EFTA00181222
Page 7 / 68
Fax Send Report 
Date/Time 
: JUL-27-2011 03:01PM WED 
Fax Number 
Fax Name 
Model Name 
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No. Name/Number 
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07-27 03:00PM 00'31 ECM 
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EFTA00181223
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United States Attorney's Office 
Southern District of Florida 
500 S. Australian Ave., Suite 400 
West Palm Beach, FL 33401-6235 
DATE: 7(2.7/ao 
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ORGANIZATION: /vets 
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EFTA00181224
Page 9 / 68
Fax Send Report 
Date/Time 
f JUL-27-2011 03:03PM WED 
Fax Number 
Fax Name 
Model Name 
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No. 
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EFTA00181225
Page 10 / 68
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
SOO S. Australian Ave, Ste 400 
West Palm Beach, FL 33401 
Facsimile: 
July 21, 2011 
DELIVERY BY ELECTRONIC MAIL 
Roy Black, Esq. 
Black Srebnick Komspan & Stumpf P.A. 
201 S. Biscayne Blvd, Suite 1300 
Miami, FL 33131 
Re: 
Jeffrey Epstein 
Dear Mr. Black: 
On July 17, 2011, the Office received a written request from the District Attorney of the 
County of New York for a copy of the signed Non-Prosecution Agreement and the list of identified 
victims that was provided to Mr. Epstein pursuant to the Non-Prosecution Agreement. Pursuant to 
the District Attorney's request, the U.S. Attorney's Office intends to disclose these items to Deborah 
L. Morse, Assistant District Attorney, at 5:00 p.m. on Friday, July 22, 2011. Pursuant to the terms 
of the Non-Prosecution Agreement, the Office is hereby giving you notice of this intended 
disclosure. 
Sincerely, 
Wifredo A. Ferrer 
United States Attorne 
B 
Assistant United States Attorney 
cc: 
, Chief, Northern Division 
Deborah L. Morse, Assistant District Attorney, County of New York 
EFTA00181226
Page 11 / 68
United States Attorney's Office 
Southern District of Florida 
500 S. Australian Ave., Suite 400 
West Palm Beach, FL 33401-6235 
DATE: 772_/40 
TO: 
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ORGANIZATION: 
FAX 
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FROM: 
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NUMBER OF PAGES, INCLUDING THIS PAGE:  Z 
COMMENTS: 
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EFTA00181227
Page 12 / 68
Fax Send Report 
Date/Time 
: JUL-21-2011 02:08PM THU 
Fax Number 
Fax Name 
Model Name 
Phaser 3300MFP 
No. Name/Number 
StartTime 
Time Mode 
Page 
Result 
211 
07-21 02:07PM 00'25 ECM 
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Southern District of Florida 
500 S. Australian Ave., Suite 400 
West Palm Reach, 
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EFTA00181228
Page 13 / 68
2123359288 
Fax; 
DISTRICT ATTORNEY 
Jul 17 2011 10:15pm P001/002 
CYRUS R. VANCE, JR. 
OSTRICT ArnCRPC 
Date: 
To: 
Fax: 
From: 
Tel #: 
OF THE 
COUNTY OF NEW YORK 
ONE HOGAN PLACE 
Now York, N. Y. 10013 
APPEALS BUREAU 
FAX DOCUMENT COVERSHEET 
FAX # 
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# of Pages 2- 
(includes cover sheet) 
K 
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Deliver Immediately 
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Discuss with Appropriate Person(s) 
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As Requested 
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For Your Approval 
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Review and Comment 
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Take Necessary Action 
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For Your Information 
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Reply Via FAX 
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File 
o 
Reply Via Messenger 
K 
Reply Directly 
o 
Progress Report 
K 
Investigate 
o 
Let's Discuss 
K 
Prepare Reply for Signature 
K 
Other Action To Be Taken/Additional Comments: 
EFTA00181229
Page 14 / 68
2123359288 
Fax: 
Jul 17 2011 10:15pa P002/002 
DISTRICT ATTORNEY 
OF THE 
COUNTY OF NEW YORK 
ONE HOGAN PLACE 
New York, N. Y. 10013 
CYRUS R. VANCE, JR, 
DISTRICT ATTOPMIY 
July 15, 2O11 
EIMI, 
Esq. 
',tent 
United States Attorney 
Office of the United States Attorney 
Southern District of Florida 
5OO S. Australian Avenue 
Suite 4OO 
West Palm Beach, Florida 334O1 
Dear Ms.MI, 
As we have discussed, I am currently working on the appeal brought 
by defendant Jeffrey Epstein in which he challenges his risk-offender 
designation under New York State's Sexual Offender Registration Act. 
The non-prosecution agreement between defendant and your Office 
would be of assistance to us in fashioning our response on appeal. I would 
appreciate it if you would send us a copy of that agreement, including the list 
of victims. 
Please let me know If you need any further information In order to 
make this material available. I appreciate your assistance, and courtesy, in 
this matter. 
Yours truly, 
Deborah L. Morse 
Assistant District Attorney 
EFTA00181230
Page 15 / 68
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 S. Australian Ave, Ste 400 
fr, FL 33401 
Facsimile: 
DELIVERY BY ELECTRONIC MAIL 
Roy Black, Esq. 
Black Srebnick Kornspan & Stumpf P.A. 
201 S. Biscayne Blvd, Suite 1300 
Miami, FL 33131 
Re: 
Jeffrey Epstein 
Dear Mr. Black: 
July 21, 2011 
On July 17, 2011, the Office received a written request from the District Attorney of the 
County of New York for a copy of the signed Non-Prosecution Agreement and the list of identified 
victims that was provided to Mr. Epstein pursuant to the Non-Prosecution Agreement. Pursuant to 
the District Attorney's request, the U.S. Attorney's Office intends to disclose these items to Deborah 
L. Morse, Assistant District Attorney, at 5:00 p.m. on Friday, July 22, 2011. Pursuant to the terms 
of the Non-Prosecution Agreement, the Office is hereby giving you notice of this intended 
disclosure. 
By: 
Sincerely, 
Wifredo A. Ferrer 
nited States Attorn 
ssistantUnited SCates 
ttorney 
cc: 
, Chief, Northern Division 
Deborah L. Morse, Assistant District Attorney, County of New York 
EFTA00181231
Page 16 / 68
DISTRICT ATTORNEY 
OF THE 
COUNTY OF NEW YORK 
ONE HOGAN PLACE 
Now York N. Y. 10013 
CYRUS R. VANCE, JR. 
0:STRICT ATTORNEY 
May 6, 2011 
Esq. 
Assistant United States Attorney 
Office of the United States Attorney 
Southern District of Florida 
500 S. Australian Avenue 
Suite 400 
West Palm Beach, Florida 33401 
Dear Ms. 
As I explained during our telephone conversation last week, I am 
currently working on an appeal brought by defendant Jeffrey Epstein. 
Defendant Epstein challenges the designation that he was given under New 
York State's Sexual Offender Registration Act. 
The underlying sexual 
misconduct at issue was the subject of an investigation and/or prosecution 
by your Office, as well as the Florida State's Attorney Office in Palm Beach 
County. 
I know that you handled the matter on behalf of your office when the 
case was presented to the federal grand jury. Those grand jury proceedings 
would be of assistance to us in fashioning our response on appeal, and I 
would appreciate it if you would send us a transcript of thoseiroceedings. If 
we furnish the minutes to the appellate court, we would do 
under seal for 
the purpose of an in camera review. 
Please let me know if you need any further information in order to 
make the materials available. I appreciate your assistance, and courtesy, in 
this matter. 
Yours truly, 
Deborah L. Morse 
Assista t District Attorney 
EFTA00181232
Page 17 / 68
DISTRICT ATTORNEY 
OF THE 
COUNTY OF NEW YORK 
ONE HOGAN PLACE 
New York, N. Y. 10013 
CYRUS R. VANCE, JR. 
CI:STRICT ATTORNEY 
August 15, 2011 
Esq. 
Assistant United States Attorney 
Office of the United States Attorney 
Southern District of Florida 
500 S. Australian Avenue 
Suite 400 
West Palm Beach, Florida 33401 
Dear Ms. 
Pursuant to our conversation, I have enclosed copies of the brief and 
appendix filed by defendant Jeffrey Epstein on appeal, as well as a copy of 
our brief in response. 
I look forward to hearing your opinion. 
Yours truly, 
(44.e 
/-C__) 
Deborah L. Morse 
Assistant District Attorney 
EFTA00181233
Page 18 / 68
New York County Clerk's Index No. 30129/2010 
Nye 1' Ink *inane (&mrt 
APPELLATE DIVISION-FIRST DEPARTMENT 
I,
14
I 
PEOPLE OF THE STATE OF NEW YORK, 
—against—
JEFFREY E. EPsTEmr, 
Respondent, 
Defendant-Appellant. 
APPENDIX 
CYRUS R. VANCE, JR. 
NEW Yon( COUNTY DISTRICT 
ATTORNEY'S OFFICE 
One Hogan Place 
New Yor New York 10013 
Attorneys for Respondent 
JAY P. LEFKOWITZ 
SANDRA LYNN Mustmen 
KIRKLAND & Rt us LLP 
601 Lexington Avenue 
New York. New York 10022 
Attorneys for Defendant-Appellant 
REPRODUCED ON RECYCLED PAPER 
EFTA00181234
Page 19 / 68
TABLE OF CONTENTS 
PAGE 
Appellant's Pre-Argument Statement, dated February 9, 2011 
Al 
Appellant's Notice of Appeal, dated February 9, 2011  
A3 
Order Appealed From, dated January 18, 2011 with Notice of Entry 
A4 
Palm Beach Police Department - Probable Cause Affidavit of 
Det. 
- Defendant 
dated May 1, 2006 
A6 
Palm Beach Sheriffs Office Booking Card for Jeffrey Epstein, 
dated July 23, 2006  
 A28 
2006 Grand Jury Indictment of Felony Solicitation of Prostitution -
Jeffrey E. Epstein 
 A29 
Information for Procuring Person under 18 for Prostitution -
Jeffrey E. Epstein, dated June 26, 2008  
 A31 
Guilty Plea for Felony Solicitation of Prostitution and Procuring 
Person under 18 for Prostitution - Jeffrey E. Epstein, 
dated June 30, 2008 
 A32 
Judgment for Procuring Person under 18 for Prostitution -
Jeffrey E. Epstein, dated June 30, 2008  
 A33 
Sentence for Procuring Person under 18 for Prostitution -
Jeffrey E. Epstein, dated June 30, 2008  
 A34 
Community Control Standard Conditions, dated June 30, 2008 
 A35 
Palm Beach Sheriffs Office Booking Card for Jeffrey Epstein, 
dated June 30, 2008 
 A47 
EFTA00181235
Page 20 / 68
UI 
PAGE 
Letter from Jay P. Leflcowitz to Hon. Ruth Pickholz Requesting a 
Continuance of the Hearing, dated September 9, 2010 
 A77 
Letter from Supreme Court to Sex Offender Registry Unit Enclosing 
Final Determinations, dated January 19, 2011  
 A78 
Court Action Sheet - Jeffrey Epstein, No. 30129-2010 
 A80 
Handwritten Notations on Court Jacket - Jeffrey Epstein, 
No. 30129-2010 
 M1 
Transcript of SORA Hearing, dated January 18, 2011  
 A82 
EFTA00181236
Pages 1–20 / 68