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and I will facilitate as much as I can getting the girls' approval of 
this procedure because, as I mentioned, I think it is probably in 
their best interests. In terms of plea agreement language, let me 
suggest the following: 
The United States agrees to make a motion seeking the 
appointment of a Guardian ad Litem to represent the identified 
victims. Following the appointment of such Guardian, the parties 
agree to work together in good faith to develop a Trust Agreement, 
subject to the Court's approyal, that would provide for any 
damages owed to the identified victims pursuant to 18 U.S.C. 
Section 2255. Then include the last two sentences of your 
paragraph 8. 
Re the two paragraphs following your paragraph 8: I will include 
our standard language regarding resolving all criminal liability and 
I will mention "co-conspirators," but I would prefer not to highlight 
for the judge all of the other crimes and all of the other persons that 
we could charge. Also, we do not have the power to bind 
Immigration and we make it a policy not to try to, however, I can 
- - 
c 
tell you that, as far as I know, there is no plan to try to proceed on 
• 
any immigration charges against either 
Also, on the' 
, I can prepare letters 
withdrawing them as of the signing of the plea agreement, but I 
would prefer to take out that language. In my eyes, once we have a 
plea agreement, the 
has ended and them 
4 
• 
• 
4 
can be no more use of the I 
I had hoped that we were far closer to resolving this than it appears 
that we are. Can I suggest that tomorrow we either meet live or via 
teleconference, either with your client or having him within a quick 
phone call, to hash out these items? I was hoping to work only a 
half day tomorrow to save my voice for Tuesday's hearing 
gaud jury, if necessary, but maybe we can set a time to meet. If 
you want to meet "off campus" somewhere, that is fine. I will 
make sure that I have all the necessary decision makers present or 
"on call," as well. 
If we can resolve some of these issues today, let's try to, and then 
save only the difficult issues for tomorrow. 
Sony for the long e-mail, and for ruining your date with your 
daughter. 
I 
US_Atty_Cor_0032 
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From: 
nt: 
ubject: 
(USAFLS) 
 
 
(USAFLS) 
Tuesday, September 18, 2007 2:53 PM 
'Jay Lefkowitz' 
Factual proffer 
Hi Jay - I didn't want us to get sidetracked during the conference call. I want to make sure that we have a 
factual basis for "harassment." 
somewhere else is a different 1512 offense 
with a 10 year cap. This is the factual proffer that I drafted up earlier this afternoon, to give you an idea of what 
it would look like. 
When I include a factual proffer in a plea agreement, I usually use prefatory language like: The parties agree 
that, had this case proceeded to trial, the United States would have proven the following facts beyond a 
reasonable doubt, and that the following facts are true and correct and are sufficient to support a plea of 
guilty . 
Epstein Plea 
Proffer.doc 
A. 
Assistant U.S. Attorney 
wi
0 S. Australian Ave, Suite 400 
est Palm Beach, FL 33401 
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From: 
nt: 
(USAFLS) 
Jay Letkowitz (JLefkowitz©kirkland.com) 
wednesomr_Sentember 19, 2007 11:36 AM 
(USAFLS) 
Re: Draft Agreements? 
Confidential - For settlement purposes only 
Still working on redline. But pls look at this: 
On August 
2007, FRI Special Agents E. 
Southern District of Florida. Mr. Epstein was informed of the service of the 
result, Mr. Epstein attempted to harass both 
receipt of a 
to attend an official proceeding, more particularly the 
I. Mr. Epstein, in particular, changed travel plans and flew with both 
-t 
to the United States Virgin Islands rather than to an airport in New Jersey in order to attempt to 
delay their receipt of what Mr. Epstein expected to be a 
Mr. Epstein further 
verbally harassed both 
in connection to this attempt to delay their voluntary 
receipt of process all in violation of IS USC 1512(d)(1). 
1 
and Jason 
traveled to the home of 
in connection with an investigation pending in the 
Asa 
delay and hinder their 
to which 
Original Message  
rom: 11 
. N(USAFLS \)" 
*lint: 
09/19/2007 11:18 AM AST 
To: Jay Lcfkowitz 
Subject: RE: Drall Agreements? 
Ili Jay - I don't know the factual basis for the alleged 
because we have no independent 
evidence of that. So, the agents need to talk to them and then I can draft up a proposed factual proffer. I have sent an e-
mail to Barry and I anna to determine their availability Thanks. 
Assistant U.S. Attorney 
..... 
*x* ******* ***•*****•*•***************•**************** 
The information contained in this communication is 
confidential, may be attorney-client privileged, may 
constitute inside information, and is intended only for 
the use of the addressee. It is the property of 
J
mirkland & Ellis LLP or Kirkland & Ellis International LLP. 
nauthorized use, disclosure or copying of this 
mmunication or any part thereof is strictly prohibited 
and may be unlawful. If you have received this 
1 
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. (USAFLS) 
From: 
ubject: 
(USAFLS) 
uesday, September 18, 2007 8:44 AM 
'Jay Lefkowite 
Draft Agreements? 
Ili Jay - I was hoping there would be things for me to read this morning, but I will try to remain patient. 
1 believe there are only two types of agreements that would apply to this case: (1) a plea agreement to a federal 
charge or charges; and (2) a non-prosecution agreement (which is really a deferred prosecution agreement 
because the defendant agrees that if he violates the agreement, the U.S. can prosecute him). 
A plea agreement is part of the court file. It is not accessible on-line via PACER, but someone can go to the 
Clerk's Office to obtain a copy. 
A non-prosecution agreement would not be made public or filed with the Court, but it would remain part of our 
case file. It probably would be subject to a FOIA request, but it is not something that we would distribute 
without compulsory process. 
On the obstruction charges, many of the facts I included in that first proffer were hypothesized based upon our 
discussions and the agents' observations ofd 
We will need to interview her to confirm the accuracy of 
those facts. On a second count, we could rely on the incident where Mr. Epstein's private investigators 
followed 
father, forcing him off the road. Or, if there is something more recent related to any 
we could consider that 
%dope that helps. 
A. 
Villafacia 
Assistant U.S. Attorne 
1 
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(USAFLS) 
crom: 
Jay Lefkowitz pLefkowitz@Mrkland.comi 
nt: 
Thursday September  13, 2007 7:35 PM 
(USAFLS) 
abject: 
Re: 
Sounds good. I will be at home. Let's talk at 9 am. 
the same statutes. 
Look forward to speaking in the morning. 
Best, Jay 
 
 Original Message  
From: ' 
Sent: 09/13/2007 07:26 PM AST 
To: Jay Lefkowitz 
Subject: RE: 
Already thinking about 
Hi Jay -- Yes, I am. I have been spending some quality time with Title 18 looking for 
misdemeanors. Do you want to take a look at 18 USC 403, 18 USC 1512(d), and 47 USC 
223(a)(1)(8) and we can talk about them tomorrow? I know that someone mentioned there being 
ctivity on an airplane, I just want to make sure that there is factual basis for the plea 
t the agents can confirm. 
I'm not sure exactly where I will be tomorrow morning, so is it alright if I call you? 
Have a good evening. 
A. 
Assistant U.S. Attorney 
 
Original Message 
From: lay Lefkowitz (mailto:llefkowitz@kirkland.comj 
Sent: Thursday, September  13, 2007 7:21 PM 
To:  
 (USAFLS) 
Subject: 
- Are you free to speak at 9 am tomorrow? 
Thanks. 
Jay 
4 e information contained in this communication is 
confidential, may be attorney-client privileged, may 
constitute inside information, and is intended only for 
1 
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the use of the addressee. It is the property of 
Kirkland & Ellis LLP or Kirkland & Ellis International LLP. 
Unauthorized use, disclosure or copying of this 
III
ommunication or any part thereof is strictly prohibited 
d may be unlawful. If you have received this 
mmunication in error, please notify us immediately by 
return e-mail or by e-mail to postmasterOkirkland.com, and 
destroy this communication and all copies thereof, 
including all attachments. 
The information contained in this communication is 
confidential, may be attorney-client privileged, may 
constitute inside information, and is intended only for 
the use of the addressee. It is the property of 
Kirkland & Ellis LLP or Kirkland & Ellis International LLP. 
Unauthorized use, disclosure or copying of this 
communication or any part thereof is strictly prohibited 
and may be unlawful. If you have received this 
communication in error, please notify us immediately by 
return e-mail or by e-mail to postmasterOkirkland.com, and 
destroy this communication and all copies thereof, 
including all attachments. 
• 
• 
2 
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"ViIlatena. Ann Marie C. 
09/12/2007 03:44 PM 
To <lofitowitz@lerkland.c4m> 
cc 
bee 
Subject Jeffrey Epstein 
Jay — It was nice seeing you again. 
and I talked with 
and Jeff. We are all satisfied in principle with the agreement, 
t 
the Office is uncomfortable with the recommended federal charge. 
Specifically, we are concerned about the effect of taking the 
position that Mr. Epstein's house Is in the special maritime and 
territorial jurisdiction of the United States, and we have no 
evidence of any assaults occurring either on Mr. Epstein's plane or 
offshore from his residence. 
We are hoping that you can find an alternative federal statute that 
can be used. I also will wait to hear from Jack Goldberger to 
discuss logistics. 
Thank you. 
A. 
Assistant U.S. Attorney 
08-80736-CV-MARRA 
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(USAFLS) 
rom: 
Jay Lefkowitz Reficowitz©kirkland.com) 
nt: 
Friday. September 14 2007 9:40 AM 
.(USAFLS) 
ubject: 
Follow up 
Confidential 
- thanks Very much for speaking this am. Have conferred with my client and I think we 
are on the same page. When you send me your draft today, would you please also include a 
paragraph with 403 in lieu of 1512. I want to understand better how you would characterize 
the 403 violation. (What was actually said?). I want to keep studying that avenue today as 
well. The other possible option is to charge three 113s. Also, one other idea. Can you 
look at 47 use 227(b), which is another 6 month statute which might work for the 6 months. 
We could do three of them, and they seem to fit the facts well. 
I will call you late this pm (if you leave me a number to reach you), and then we can plan on 
getting this done Monday. 
The information contained in this communication is confidential, may be attorney-client 
privileged, may constitute inside information, and is intended only for the use of the 
addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. 
Unauthorized use, disclosure or copying of this communication or any part thereof is strictly 
. 
rohibited and may be unlawful. If you have received this communication in error, please 
ify us immediately by return e-mail or by e-mail to postmasterOkirkland.com, and destroy 
s communication and all copies thereof, including all attachments. 
• 
1 
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(USAFLS) 
From: 
, Ann Marie C. (USAFLS) 
nt: 
4u 
Illieptember 14, 2007 9:54 AM 
leflcowliziakIrkland.coml; 'Jay Lerkowltz' 
bject: 
Plea documents 
Iii Jay — I'm not sure which of those c-mail addresses is correct. I{ere are drafts of the pica agreement and 
information. They have not yet been blessed by Miami, but they have approved of prior similar drafts, so these 
should be close to what is needed. My home e-mail is 
You also can get me 
over the weekend on my cell phone at 
Information 
arging 1512 and 
OLY Plea 
ement v4 1512 a 
aids, 
ssistant U. 
me 
Attorne 
I 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 
18 U.S.C. § 1512(d)(2) 
18 U.S.C. § 113(a)(5) 
UNITED STATES OF AMERICA 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
R 
Jk
ORMAT1ON 
The United States Attorney charges that: 
COUNT 1 
In or around October 2005, in Palm Beach County, in the Southern District of Florida, and 
elsewhere, the defendant, 
F 
JEFFREY EPSTEIN, 
did intentionally harass another person, that is, Jane Doe #1, in an attempt to delay, prevent, and 
dissuade Jane Doe #1 from reporting to a law enforcement officer of the United States the 
T
commission of a federal offense; in violation of Title 18, United Stat Code, Sections 1512(d)(2) 
and 2. 
COUNT 2 
In or around 
2005, in the special territorial jurisdiction of the United States, that 
is, in an aircraft owned by a United States citizen while in flight over the high seas, and elsewhere, 
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the defendant, 
JEFFREY EPSTEIN, 
did knowin ly commit a simple assault on a person who was over the age of 16 years, that is, 
in viola 
Title IS, United States Code, Section 113(a)(5). 
It ALEXANDER AC 
UNITED STATES ATTORNEY 
VILLAFANA 
ASSISTANT UNITED STATES ATTO11Nfi
F 
T 
2 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 
UNITE 
ATES OF AMERICA 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
PLEA AGREEMENT 
The United States Attorney for the Southern District of Florida ("the United States"), 
and Jeffrey Epstein (hereinafter referred to as th 
`defendant") enter into the following 
agreement: 
I. 
The defendant agrees to plead guilty to the Information which charges the 
defendant as follows: Count I charges that the defendant intentionally harassed another person, 
F
that is, Jane Doe #1, in an attempt to delay, prevent, and dissuade Ja 
oe # I from reporting to a 
law enforcement officer of the United States the commission of a federal offense; in violation of 
Title 18, United States Code, Sections 1512(d)(2) and 2; and Count 2 charges that the defendant, 
while in an airplane over the high seas, did knowingly commit a simple assault on a person who was 
T
over the age of 16 years, that is.; 
in violation of Title 18, United States Code, Secti 
113(a)(5). 
2. 
The defendant is aware that the sentence will be imposed by the Court after 
considering the Federal Sentencing Guidelines and Policy Statements (hereinafter 
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"Sentencing Guidelines"). The defendant acknowledges and understands that the Court will 
compute an advisory sentence under the Sentencing Guidelines and that the applicable 
guider 
ill be determined by the Court relying in part on the results of a Pre-Sentence 
Invest' ti 
by the Court's probation office, which investigation will commence after the 
guilty plea has been entered. The defendant is also aware that, under certain circumstances, 
the Court may depart from the advisory sentencing guideline range that it has computed, and 
may raise or lower that advisory se 
e under the Sentencing Guidelines. The defendant 
is further aware and understands that the Court is required to consider the advisory guideline 
range determined under the Sentencing Guidelines, but is not bound to impose that sentence; 
the Court is permitted to tailor the ultimate sentence in light of other statutory concerns, and 
such sentence may be either more severe or less 
e than the Sentencing Guidelines' 
advisory sentence. Knowing these facts, the defendant understands and acknowledges that 
the Court has the authority to impose any sentence within and up to the statutory maximum 
authorized by law for the offenses identified in paragraph 1 and tat the defendant may not 
withdraw the plea solely as a result of the sentence imposed. 
3. 
The defendant further understands and acknowledges that, as to Count 1 of the 
Information, the Court may impose a statutory maximum term of imprisonment of up to one 
(1) year, to be followed by a term of supervised release of up to a maximum o 
e T(1) year. 
In addition to terms of imprisonment and supervised release, the Court may impose a fine of 
up to $100,000. The defendant further understands and acknowledges that, as to Count 2 of 
the Information, the Court may impose a statutory maximum term of imprisonment of up to 
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six (6) months, to be followed by a term of supervised release of up to a maximum of one (1) 
year. In addition to terms of imprisonment and supervised release, the Court may impose a 
fine of n$100,000. 
41---1  The defendant further understands and acknowledges that, in addition to any 
sentence imposed under paragraph 3 of this Agreement, a special assessment in the amount 
of $50 will be imposed on the defendant, which must be paid at or before the time of 
sentencing. 
R 
5. 
The defendant understands that the Court will order that he must pay full 
restitution to all victims of the offense to which he is pleading guilty. The defendant 
understands that the amount of restitution owed to each victim will be determined at or 
before sentencing. 
A 
6. 
The parties agree to jointly recommend that the defendant receive a sentence 
of eighteen (18) months' imprisonment, to be followed by two (2) years of supervised 
release; and a fine of $200,000. 
Li
7. 
The defendant agrees that, if any of the victims identiflUn the federal investigation 
file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the jurisdiction of the U.S. 
District Court for the Southern District of Florida over his person and/or the subject matter, and the 
lite
defendant will not contest that the identified victims are persons who, while minor , e victims 
of violations of Title IS, United States Code, Sections(s) 2422 and/or 2423. The rated States 
agrees to provide the defendant's attorneys with a list of the identified victims, which will not 
exceed forty, after the defendant has signed this agreement and has been sentenced. The United 
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