EFTA00185206

EISENBERG & FOUTS, P.A. 
Attorneys At Law 
JAMES L. EISENBERG 
Florida Bar Board Certified Criminal Trial Lawyer 
National Board Of Trial Advocacy Certified Criminal Trial Advocate 
KAI LI ALOE FOUTS 
One Clearlake Centre, Suite 704,250 Australian Avenue South, West Palm Beach, FL 33401 
Fax: 
February 1, 2007 
Asst. U.S. Attorney 
500 South Australian Avenue, Suite 400 
West Palm Beach, FL 33401 
Re: 
Grand Jury Subpoena for 
Dear M, 
I received your letter dated January 24, 2007 with regard to 
I must admit I forced 
myself to wait several days to respond in order to "cool off' and not say anything I would regret 
later. Now that time has passed, allow me to respond appropriately. 
1. If you want to force Ms. =, 
a single mother, to come to the grand jury room to 
personally invoke her Fifth Amendment rights, she will be there. That does remain her position. 
My only request is that sro ttirovide a babysitter service for her child. I will be there, but I am not 
paid to babysit and Ms. 
should not have
 someone. It is this type of attitude, that your 
office refuses to accept the fact that it is Ms. 
decision not to cooperate with the government 
that upsets her. Your office fails to recognize that merely coming to court is a problem for a single 
mother like Ms. 
and, under these circumstances, appears to be a waste of time at best and, in 
her mind, personal harassment. 
2. Rest assured that there is no conflict of interest in my representation of Ms. =. 
In this 
case I have always been asked and always will exercise independent judgment to follow my client's 
independent will. The remainder of your questions as to this matter are really none of the 
Government's business. 
3. I will share with you that one of the reasons for our firm position that Ms. 
will 
invoke her Fifth Amendment right and choose not to voluntarily cooperate with the Government is 
our concern that the Government is not exercising independent judgment in this case. 
The history of this case has been in the newspapers. The case is being prosecuted in State court. 
Despite the state court prosecution, the Town of Palm Beach Police Chief went on what can only be 
ti 
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EXHIBIT 
2
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EFTA00185226

, Asst. U.S. Attorney 
February 1, 2007 
Page Two 
described as a public rampage in the newspaper when the case was not prosecuted to his liking that 
reminded me of a small child having a public temper tantrum. In my thirty years of experience, I 
have never seen a law enforcement officer like this publicly make what appeared to be a political 
case in the newspaper for a prosecution and publicly criticize anyone who got in his way, including 
the elected State Attorney. This resulted in a federal investigation on a topic no one remembers the 
Federal Government ever being interested in prosecuting before. Although 1 am certain that you 
personally have not had your decision-making process compromised, the appearance that your office 
is being influenced by the Town of Palm Beach Police Chief's agenda is very real. Under these 
circumstanceri don't see how any lawyer could advise any client to voluntarily cooperate. Of 
special concern is that the Town of Palm Beach Police have promoted prosecuting at least one of the 
girls who allegedly gave massages. 
One final thought. My client and my fear that Ms. 
could be prosecuted is enhanced by the 
demand for the personal appearance made in your letter. Your initial Kastiger letter fell far short 
of granting the functional equivalent of DOJ immunity. Several months ago I was given the distinct 
impression through our conversations that you were going to obtain DOJ immunity for Ms. 
Now the government is changing course for no apparent reason. This leads to speculation that the 
only reason for the turnabout is that prosecution in either state or federal court is being considered 
by someone. 
None of the above directed at you personally. I want to repeat that you have always treated us with 
respect. 
aybe 
office should advise the Town Police Chief to act in a similar fashion. 
Since 
ERG 
ILE 
cc: 
EFTA00185227

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 South Australian Ave, Suite 400 
h, Florida 33401 
Facsimi 
FACSIMILE COVER SHEET 
TO: 
JIM EISENBERG, ESQ. 
 DATE: 
FAX NO. 
 
 # OF PAGES: 
PHONE NO.  
 RE: 
February 5, 2007 
FROM: 
A. 
PHONE NO.  
VILLAFARA, ASSISTANT U.S. ATTORNEY 
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EFTA00185228

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 South Australian Ave., Suite 400 
West Palm Beach, FL 33401 
DELIVERY BY HAND 
Ms. a 
do James L. Eisenberg, Esq. 
250 S Australian Ave, Ste 704 
West Palm Beach, FL 33401-5007 
February 5, 2007 
Re: 
Grand Jury Testimony of IMIIM
Dear Ms. 
This letter confirms the understanding between yourself and the United States Attorneys 
Office for the Southern District of Florida. 
You have represented that you will truthfully answer questions of the federal government in 
its investigation of the procurement of prostitutes, amongst others. You will supply complete and 
truthful information to the attorneys and law enforcement officers of the federal government and to 
any Federal Grand Jury which may conduct an investigation, as well as in any other proceeding 
related to or growing out of this investigation. The obligation of truthful disclosure includes your 
obligation to provide the attorneys and law enforcement officers of the federal government with any 
documents, records or other tangible evidence within your custody or control relating to the matters 
about which you are questioned. You will neither attempt to protect any person or entity through 
false information or omission, nor falsely implicate any person or entity. 
No statements provided by you on this date in this matter pursuant to this agreement will be 
offered into evidence in any criminal case against you, except during a prosecution for perjury and/or 
giving a false statement. However, if it is determined that you have materially violated any provision 
of this agreement, all statements made by you shall be admissible in evidence against you in any 
proceeding. 
The federal government remains free to use information derived from the grand jury 
testimony directly or indirectly for the purpose of obtaining leads to other evidence, which may be 
used against you. You expressly waive any right to claim that such evidence should not be 
introduced because it was obtained as a result of the grand jury testimony. Furthermore, the federal 
government may use statements made in the grand jury testimony and all evidence derived directly 
or indirectly therefrom for the purpose of cross-examination, if you testify at any trial or if you 
EFTA00185229

MS. 
FEBRUARY 5, 2007 
PAGE 2 
suborn testimony that contradicts your prior statements and testimony. 
No additional promises, agreements and conditions have been entered into other than those 
set forth in this letter and none will be entered into unless in writing and signed by all parties. 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
By: 
Assistant United States Attorney 
I have read this agreement and discussed it with my attorney, and I hereby acknowledge that it 
fully sets forth my agreement with the office of the United States Attorney for the Southern District of 
Florida. I state that there have been no additional promises, agreements or representations made to me 
by any officials of the United States in connection with this matter. 
Dated: February 
, 2007 
West Palm Beach, Florida 
Witnessed by: 
James L. Eiser,ra
i
Attorney for 
EFTA00185230

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
DELIVERY BY HAND 
James L. Eisenberg, Esq. 
250 S Australian Ave, Ste 704 
West Palm Beach, FL 33401-5007 
Re: 
Dear Mr. Eisenberg: 
500 South Australian Ave., Suite 400 
West Palm Beach, FL 33401 
Facsimile: 
February 5, 2007 
I am writing to clarify the ground rules for the interview with your client, 
("your client"), to occur February 
2007. 
As I mentioned earlier, Ms. 
is not a target or subject of this investigation, but 
instead is being interviewed solely as a victim/witness. However, to address your concern 
about criminal exposure, if your client complies with every provision of this agreement, then 
the United States Attorney's Office for the Southern District of Florida ("this Office") will 
treat all statements made by your client during the interview as statements made pursuant to 
Rule 11(f) of the Federal Rules of Criminal Procedure. This is not a grant of immunity, 
which can be given only with approval of the Justice Department, but protects your client 
from having the statements made by her during the interview from being used against her 
directly. To guard against any misunderstandings concerning the interview of your client, 
this letter sets forth the terms of this agreement. 
Your client agrees to be fully interviewed, that is, to provide information concerning 
your client's knowledge of, and participation in criminal activity, including but not limited 
to the procurement of prostitutes. The protection of this letter applies to an interview that 
will be conducted by this Office, Special Agents of the Federal Bureau of Investigation, and 
any other federal law enforcement agency this Office may require. Under this agreement, 
no information disclosed by your client during the interview will be offered in evidence 
against her in any criminal or civil proceeding, provided that your client complies with this 
agreement and that the information your client furnishes is truthful, complete, and accurate. 
If, however, your client gives materially false, incomplete, or misleading information, 
EFTA00185231

JAMES L. EISENBERG, ESQ. 
EB: 
FEBRUARY 2, 2007 
PAGE 2 
then this Office may use such information in any matter or proceeding and your client is 
subject to prosecution for perjury, obstruction of justice, and making false statements to 
government agencies. Any such prosecution may be based upon information provided by 
your client during the course of the interview, and such information, including your client's 
statements, will be admissible against your client in any grand jury or other proceeding. 
The government also may use statements made by your client in the interview and all 
evidence derived directly or indirectly therefrom for the purpose of impeachment or 
cross-examination if she testifies at any trial or hearing, and/or in any rebuttal case against 
your client in a criminal trial in which she is a defendant or a witness. These provisions are 
necessary to ensure that your client does not make or offer any false representation or 
statement in any proceeding or to a government agency or commit perjury during any 
testimony. 
Your client further agrees that attorneys for the United States may be present at the 
interview, and agrees not to seek disqualification of any such government attorney from any 
proceeding or trial because of their participation at the interview. 
The entire agreement between the United States and your client is set forth in this 
letter. No additional promises, agreements, or conditions have been entered into and none 
will be entered into unless in writing and signed by all parties. 
If the foregoing accurately reflects the understanding and agreement between this 
Office and your client, it is requested that you and your client execute this letter as provided 
below. 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
By: 
Assistant United States Attorney 
I have received this letter from my attorney, James L. Eisenberg, Esquire, have read 
it and discussed it with my attorney, and I hereby acknowledge that it fully sets forth my 
understanding and agreement with the Office of the United States Attorney for the Southern 
EFTA00185232

JAMES L. EISENBERG, ESQ. 
RE: 
FEBRUARY 2, 2007 
PAGE 3 
District of Florida. T state that there have been no additional promises or representations ' 
made to me by any official of the United States Government or by my attorney in connection 
with this matter. 
Dated: 
Witnessed by: 
James L. Eisenberg, Esquire 
EFTA00185233

U.S. Department of Justice 
Authorization for Reimbursement 
of Unusual Expenses of Fact Witnesses 
Request for Unusual Expense(s) of Fact Witness 
(For United States Attorney's Office Use Only) 
Control # 
1. Case Name 
..., 
2. Court Docket Number 
4. Location of Court P 
ng 5. Contact Person 
Wes!- Palm 
7. Witness Name & Address, Phone #, SSN 
8. Vendor Name & Address, Phone #, TIN/SSN 
9. Payment to be made to: 
10. Receipt/Invoice is: 
11. 
12tDependent 
Illi 
Type of Unusual Expense: 
Medically Necessary Item 
(Attached Supporting Statement) 
Care
_
Excess Lodging/Per Diem 
Travel & Transportation 
Pretrial Conference Waiver 
Other 
12. Explanation: 
Wm, miniM ht4 a. sniodi cilad to 
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13. Start Date of Service (MO/DA/YR) 
ando 
7 
14. End Date of Service (MO/DA/YR) 
2-4 
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15. Amount 
16. Justification: 
17. I hereby certify that the expenses and services listed on this document are appropriate and are within the Federal laws 
and regulations. I fully understand that I can be held personally liable or be subject to disciplinary action for improperly using 
government funds or services that exceed delegated authority or that violate Federal laws or regulations. 
Signature of Requesting AUSA 
Date 
18. Name & Title of Approving Official 19. Date (MO/DA/YR) 
20. Signature of Approving Official 
4 8 
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GOVERNMENT 
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EXHIBIT 
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EFTA00185234

EISENBERG & FOUTS, P.A. 
Attorneys At Law 
JAMES L. EISENBERG 
Florida Bar Board Certified Criminal Trial Lawyer 
National Board Of Trial Advocacy Certified Criminal Trial Advocate 
KAI LI AWE FOUTS 
One Cies rim ke Centre, Suite 704,250 Australian Avenue South, West Palm Beach, FL 33401 a
Fax: 
February 12, 2007 
Asst. U.S. Attorney 
500 South Australian Avenue, Suite 400 
West Palm Beach, FL 33401 
Re: 
Grand Jury Subpoena for 
Dear 
As always, it was a pleasure speaking to you the other da 
Pursuant to our telephone conference 
I am writing this letter to proffer my concerns for 
should she testify without immunity 
before a federal grand jury. Therefore, allow me to reiterate that Ms. 
will refuse to voluntarily 
cooperate with the federal government. She has a good faith basis for her position under the Fifth 
Amendment to the United States Constitution. 
We, of course, do not live or work in a vacuum. We have read many inflammatory remarks the 
Town of Palm Beach Police Chief has made to the media about the state court's handling of the 
Jeffrey Epstein investigation. The police chiefs remarks frighten both myself and my client. I am 
aware that the town police have prepared documents to charge at least one of Mr. Epstein's lady 
friends in state court. If they can push to have one lady charged I remain unconvinced that they do 
not have the ability or political clout to push to have other ladies such as Ms. 
charged. 
The proffered facts that raise my concerns are being provided via this proffer letter. Pursuant to our 
telephone conference agreement, this letter and its contents cannot be used against Mr. M. 
Ms. 
is not at all certain of dates. She does remember meeting Mr. Epstein about three years 
ago. She is not certain of her age, it could have been when she was sixteen. A girlfriend asked her 
if she wanted a job giving massages. Ms. 
agreed because she had knowledge of massages 
through her mother, who was a masseuse. 
if asked, she had to tell Mr. Epstein that she 
was eighteen years old. The fr, 
was 
Ms. 
went to Mr. Epstein's house via taxi. M 
girlfriend instructed Ms. 
that, 
nineteen years old and 
looked old for her age, so passing for eighteen was not a problem. At 
GOVERNMENT 
EXHIBIT 
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EFTA00185235

the home Ms. 
met Mr. Epstein and later ave him a massage. The friend had told Ms. 
to give the message topless. Mr. Epstein told 
that if she were at all uncomfortable being 
topless, not to do it and it was not a requirement of employment as a masseuse. Ms. 
never 
touched Mr. Epstein in a sexual way and Mr. Et.stein never touched Ms. 
at all. At one point, 
Mr. Epstein did ask Ms. 
her age. Ms. 
insisted that she was eighteen years old. 
Ms. 
continued to see Mr. Epstein over time and massages were given in a similar fashion. 
She was later asked if her friends wanted to work in a similar way and she asked some girls who did 
give Mr. Epstein massages. Ms. 
was never asked to bring girls of any age to Mr. Epstein's 
home. When she did have her friends come over, she instructed all of them that if asked, they insist 
that they were eighteen years old. She is not certain at all of any of these girls' real ages. 
In summary, our concern is that if the government believes that Mr. Epstein committed some federal 
offense, then Ms. 
could he considered a co-conspirator. We believe no crime was committed. 
The Fifth Amendment was not intended to protect the guilty, however. It was enacted to protect 
citizens who fear prosecution notwithstanding their innocence. Our fear of any prosecution, 
especially • 11 
f the Town police chiefs public remarks, is clearly in good faith. 
EFTA00185236

UNITED STATES DISTRICT COURT 
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SOUTHERN DISTRICT OF FLORIDA 
NORTHERN (WEST PALM BEACH) DIVISION 
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IN RE: 
GRAND JURY PROCEEDINGS 
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SEALED ORDER 
On Application of the United States Attorney for the Southern District of Florida, and it 
appearing to the satisfaction of the Court: 
1. 
That 
has been called to testify and to provide other information before 
the United States District Court for the Southern District of Florida, including a Grand Jury 
impanelled therein; and 
2. 
That in the judgment of the said United States Attorney,n 
has refused 
to testify and provide other information on the basis of her privilege against self-incrimination; and 
3. 
That in the judgment of the said United States Attorney, the testimony and other 
information from 
=: 
may be necessary to the public interest; and 
4. 
That the aforesaid Application has been made with the approval of the Assistant 
Attorney General in charge of the Criminal Division of the Department of Justice or a duly 
designated Acting Assistant Attorney General, pursuant to the authority vested in him by Title 18, 
United States Code, Section 6003, and Title 28, Code of Federal Regulations, Sections 0.175 and 
0.132(e). 
NOW, THEREFORE, it is ordered pursuant to Title 18, United States Code, Section 6002, 
that 
give testimony and provide other information which she refuses to give or to 
GOVERNMENT 
EXHIBIT 
6 
EFTA00185237

provide on the basis of her privilege against self-incrimination, as to all matters about which she may 
be interrogated before said United States District Court, including a Grand Jury impaneled therein, 
as well as any subsequent proceeding or trial. 
However, no testimony or other information compelled under this Order (or any information 
directly or indirectly derived from such testimony or other information) may be used against 
in any criminal case, except a prosecution for perjury, giving a false statement, or otherwise 
failing to comply with this Order. 
I'I' IS FURTHER ORDERED the this Order shall be SEALED in accordance with Fed. 
R. Crim. P. 6(e)(6), except that a copy of this Order shall be provided to counsel for the United 
States, who may disclose the existence of the Order to members of the Grand Jury, to the witness, 
to counsel for the witness, and to law enforcement officers engaged in the investigation pending 
before the Grand Jury. Those persons may review the Order, but may not retain a copy of the Order, 
nor may they disclose the existence of the Order to any others. 
cc: 
DONE and ORDERED this 
AUSA 
day of April, 2007 
Palm Beach, Florida. 
2 
DONALD M. MIDDLEBROOKS 
UNITED STATES DISTRICT JUDGE 
EFTA00185238

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
DELIVERY BY ELECTRONIC MAIL 
Jay P. Lefkowitz, 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 
West Palm Beach, FL 3340! 
Facsimile.• 
December 13, 2007 
I am writing not to respond to your asserted "policy concerns" regarding Mr. Epstein's Non-
Prosecution Agreement, which will be addressed by the United States Attorney, but the time has 
come for me to respond to the ever-increasing attacks on my role in the investigation and 
negotiations. 
It is an understatement to say that I am surprised by your allegations regarding my role 
because I thought that we had worked very well together in resolving this dispute. I also am 
surprised because I feel that I bent over backwards to keep in mind the effect that the agreement 
would have on Mr. Epstein and to make sure that you (and he) understood the repercussions of the 
agreement. For example, I brought to your attention that one potential plea could result in no gain 
time for your client; I corrected one of your calculations of the Sentencing Guidelines that would 
have resulted in Mr. Epstein spending far more time in prison than you projected; I contacted the 
Bureau of Prisons to see whether Mr. Epstein would be eligible for the prison camp that you desired; 
and I told you my suspicions about the source of the press "leak" and suggested ways to avoid the 
press. Importantly, I continued to work with you in a professional manner even after I learned that 
you had been proceeding in bad faith for several weeks — thinking that I had incorrectly concluded 
that solicitation of minors to engage in prostitution was a registrable offense and that you would 
"fool" our Office into letting Mr. Epstein plead to a non-registrable offense. Even now, when it is 
clear that neither you nor your client ever intended to abide by the terms of the agreement that he 
signed, I have never alleged misconduct on your part. 
The first allegation that you raise is that I "assiduously" hid from you the fact that Bert 
Ocariz is a friend of my boyfriend and that I have a "longstanding relationship" with Mr. Ocariz. 
EFTA00185239

JAY P. LEFICOWITZ, ESQ. 
DECEMBER 13, 2007 
PAGE 2 OF 5 
I informed you that I selected Mr. Ocariz because he was a friend and classmate of two people 
whom I respected, and that I had never met or spoken with Mr. Ocariz prior to contacting him about 
this case. All of those facts are true. I still have never met Mr. Ocariz, and, at the time that he and 
I spoke about this case, he did not know about my relationship with his friend. You suggest that I 
should have explicitly informed you that one of the referrals came from my "boyfriend" rather than 
simply a "friend," which is the term I used, but it is not my nature to discuss my personal 
relationships with opposing counsel. Your attacks on me and on the victims establish why I wanted 
to find someone whom I could trust with safeguarding the victims' best interests in the face of 
intense pressure from an unlimited number of highly skilled and well paid attorneys. Mr. Ocariz 
was that person. 
One of your letters suggests a business relationship between Mr. Ocariz and my boyfriend. 
This is patently untrue and neither my boyfriend nor I would have received any financial benefit 
from Mr. Ocariz's appointment. Furthermore, after Mr. Ocariz learned more about Mr. Epstein's 
actions (as described below), he expressed a willingness to handle the case pro bono, with no 
financial benefit even to himself. Furthermore, you were given several other options to choose from, 
including the Podhurst firm, which was later selected by Judge Davis. You rejected those other 
options. 
You also allege that I improperly disclosed information about the case to Mr. Ocariz. I 
provided Mr. Ocariz with a bare bones summary of the agreement's terms related to his appointment 
to help him decide whether the case was something he and his firm would be willing to undertake. 
I did not provide Mr. Ocariz with facts related to the investigation because they were confidential 
and instead recommended that he "Google" Mr. Epstein's name for background information. When 
Mr. Ocariz asked for additional information to assist his firm in addressing conflicts issues, I 
forwarded those questions to you, and you raised objections for the first time. I did not share any 
further information about Mr. Epstein or the case. Since Mr. Ocariz had been told that you 
concurred in his selection, out of professional courtesy, I informed Mr. Ocariz of the Office's 
decision to use a Special Master to make the selection and told him that the Office had made contact 
with Judge Davis. We have had no further contact since then and I have never had contact with 
Judge Davis. I understand from you that Mr. Ocariz contacted Judge Davis. You criticize his 
decision to do so, yet you feel that you and your co-counsel were entitled to contact Judge Davis to 
try to "lobby" him to select someone to your liking, despite the fact that the Non-Prosecution 
Agreement vested the Office with the exclusive right to select the attorney representative. 
Another reason for my surprise about your allegations regarding misconduct related to the 
Section 2255 litigation is your earlier desire to have me perform the role of "facilitator" to convince 
the victims that the lawyer representative was selected by the Office to represent their interests alone 
and that the out-of-court settlement of their claims was in their best interests. You now state that 
doing the same things that you had asked me to do earlier is improper meddling in civil litigation. 
Much of your letter reiterates the challenges to Detective Recarey's investigation that have 
EFTA00185240

JAY P. LEFKOWITZ, ESQ. 
DECEMBER 13, 2007 
PAGE 3 OF 5 
already been submitted to the Office on several occasions and you suggest that I have kept that 
information from those who reviewed the proposed indictment package. Contrary to your 
suggestion, those submissions were attached to and incorporated in the proposed indictment 
package, so your suggestion that I tried to hide something from the reviewers is false. I also take 
issue with the duplicity of stating that we must accept as true those parts of the Recarey reports and 
witness statements that you like and we must accept as false those parts that you do not like. You 
and your co-counsel also impressed upon me from the beginning the need to undertake an 
independent investigation. It seems inappropriate now to complain because our independent 
investigation uncovered facts that are unfavorable to your client. 
You complain that I "forced" your client and the State Attorney's Office to proceed on 
charges that they do not believe in, yet you do not want our Office to inform the State Attorney's 
Office of facts that 
os
u 
rt the additional char e nor do you want any of the victims of that charge 
to contact Ms. 
or the Court. Ms. 
s opinion may change if she knows the full 
scope of your client's actions. You and I spent several weeks trying to identify and put together a 
plea to federal charges that your client was willing to accept. Yet your letter now accuses me of 
"manufacturing" charges of obstruction of justice, making obscene phone calls, and violating child 
privacy laws. When Mr. 
told you that those charges would "embarrass the Office," he meant 
that the Office was unwilling to bend the facts to satisfy Mr. Epstein's desired prison sentence — a 
statement with which I agree. 
I hope that you understand how your accusations that I imposed "ultimatums" and "forced" 
you and your client to agree to unconscionable contract terms cannot square with the true facts of 
this case. As explained in letters from Messrs. Acosta and Sloman, the indictment was postponed 
for more than five months to allow you and Mr. Epstein's other attorneys to make presentations to 
the Office to convince the Office not to prosecute. Those presentations were unsuccessful. As you 
mention in your letter, I —a simple line AUSA — handled the primary negotiations for the Office, and 
conducted those negotiations with you, Ms. Sanchez, Mr. Lewis, and a host of other highly skilled 
and experienced practitioners. As you put it, your group has a "combined 250 years experience" to 
my fourteen. The agreement itself was signed by Mr. Epstein, Ms. Sanchez, and Mr. Lefcourt, 
whose experience speaks for itself. You and I spent hours negotiating the terms, including when to 
use "a" versus "the" and other minutiae. When ou and I could not reach agreement, you repeatedly 
went over my head, involving Messrs. 
, Sloman, and Acosta in the negotiations at 
various times. In any and all plea negotiations the defendant understands that his options are to 
plead or to continue with the investigation and proceed to trial. Those were the same options that 
were proposed to Mr. Epstein, and they are not "persecution or intimidation tactics." Mr. Epstein 
chose to sign the agreement with the advice of a multitude of extremely noteworthy counsel. 
You also make much of the fact that the names of the victims were not released to Mr. 
Epstein prior to signing the Agreement. You never asked for such a term. During an earlier 
meeting, where Mr. Black was present, he raised the concern that you now voice. Mr. Black and 
I did not have a chance to discuss the issue, but I had already conceived of a way to resolve that 
EFTA00185241

JAY P. LEFKOWITZ, ESQ. 
DECEMBER 13, 2007 
PAGE 4 OF 5 
issue if it were raised during negotiations. As I stated, it was not, leading me to believe that it was 
not a matter of concern to the defense. Since the signing of the Non-Prosecution Agreement, the 
agents and I have vetted the list of victims more than once. In one instance, we decided to remove 
a name because, although the minor victim was touched inappropriately by Mr. Epstein, we decided 
that the link to a payment was insufficient to call it "prostitution." I have always remained open to 
a challenge to the list, so your suggestion that Mr. Epstein was forced to write a blank check is 
simply unfounded. 
Your last set of allegations relates to the investigation of the matter. For instance, you claim 
that some of the victims were informed of their right to collect damages prior to a thorough 
investigation of their allegations against Mr. Epstein. This also is false. None of the victims was 
informed of the right to sue under Section 2255 prior to the investigation of the claims. Three 
victims were notified shortly after the signing of the Non-Prosecution Agreement of the general 
terms of that Agreement. You raised objections to any victim notification, and no further 
notifications were done. Throughout this process you have seen that I have prepared this case as 
though it would proceed to trial. Notifying the witnesses of the possibility of damages claims prior 
to concluding the matter by plea or trial would only undermine my case. If my reassurances are 
insufficient, the fact that not a single victim has threatened to sue Mr. Epstein should assure you of 
the integrity of the investigation.' 
'There are numerous other unfounded allegations in your letter about document demands, 
the money laundering investigation, contacting potential witnesses, speaking with the press, and the 
like. For the most part, these allegations have been raised and disproven earlier and need not be 
readdressed. However, with respect to the subpoena served upon the private investigator, contrary 
to your assertion, and as your co-counsel has already been told, I &I consult with the Justice 
Department prior to issuing the subpoena and I was told that because I was not subpoenaing an 
attorney's office or an office physically located within an attorney's office, and because the business 
did private investigation work for individuals (rather than working exclusively for Mr. Black), I 
could issue a grand jury subpoena in the normal course, which is what I did. I also did not 
"threaten" the State Attorney's Office with a grand jury subpoena, as the correspondence with their 
grand jury coordinator makes perfectly clear. 
With regard to your allegation of my filing the Palm Beach Police Department's probable 
cause affidavit "with the court knowing that the public could access it," I do not know to what you 
are referring. All documents related to the grand jury investigation have been filed under seal, and 
the Palm Beach Police Department's probable cause affidavit has never been filed with the Court. 
If, in fact, you are referring to the Ex Parte Declaration of Joseph Recarey that was filed in response 
to the motion to quash the grand jury subpoena, it was filed both under seal and ex parte, so no one 
should have access to it except the Court and myself. Those documents are still in the Court file 
only because you have violated one of the terms of the Agreement by failing to "withdraw 
[Epstein's] pending motion to intervene and to quash certain grand jury subpoenas." 
EFTA00185242

JAY P. LEFKOWITZ, ESQ. 
DECEMBER 13,2007 
PAGE 5 OF 5 
With respect to Ms. =, 
I contacted her attorney — who was paid for by Mr. Epstein and 
was directed by counsel for Mr. Epstein to demand immunity — and asked only whether he still 
represented Ms. 
and if he wanted me to send the victim notification letter to him. He asked 
what the letter would say and I told him that the letter would be forthcoming in about a week and 
that I could not provide him with the terms. With respect to Ms. 
status as a victim, you 
again want us to accept as true oniyt cts that are beneficial to your client and to reject as false 
anything detrimental to him. Ms. 
made a number of statements that are contradicted by 
documentary evidence and a review of her recorded statement shows her lack of credibility with 
respect to a number of statements. Based upon all of the evidence collected Ms. 
is classified 
as a victim as defined by statute. Of course, that does not mean that Ms. 
considers herself 
a victim or that she would seek damages from Mr. Epstein. I believe that a number of the identified 
victims will not seek damages, but that does not negate their legal status as victims. 
I hope that you now understand that your accusations against myself and the agents are 
unfounded. In the future, I recommend that you address your accusations to me so that I can correct 
any misunderstandings before you make false allegations to others in the Department. I hope that 
we can move forward with a professional resolution of this matter, whether that be by your client's 
adherence to the contract that he signed, or by virtue of a trial. 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
By: 
Assistant United States Attorney 
cc: 
R. Alexander Acosta, U.S. Attorney 
Jeffrey Sloman, First Assistant U.S. Attorney 
You also accuse me of "broaden[ing] the scope of the investigation without any foundation 
for doing so by adding charges of money laundering and violations of a money transmitting business 
to the investigation." Again, I consulted with the Justice Department's Money Laundering Section 
about my analysis before expanding that scope. The duty attorney agreed with my analysis. 
EFTA00185243

Case 9:08-cv-80736-KAM Document 304-1 Entered on FLSD Docket 01/30/2015 Page 1 of 3 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 08-80736-CIV-MARRA 
JANE DOE #1 and JANE DOE #2, 
Petitioners, 
vs. 
UNITED STATES OF AMERICA, 
Respondent. 
DECLARATION OF FBI SPECIAL AGENT TIMOTHY R. 
TIMOTHY R. 
declares as follows: 
1. I am a Special Agent, Federal Bureau of Investigation (FBI), currently assigned as a 
Section Chief at FBI Headquarters, Washington. D.C. I was appointed a Special Agent in May 
1999. Upon graduation from the FBI Academy at Quantico, Virginia, in September 1999, I was 
assigned to the Detroit Field Office. I was subsequently transferred to the FBI Miami Field 
Office in May 2006. 
2. In 2006. I was assigned to work on an investigation of Jeffrey Epstein, who was 
accused of sexually abusing many young girls under the age of 18. In the course of our 
investigation, the FBI identified many potential victims of sexual abuse by Epstein. We obtained 
names by speaking to other victims, who frequently knew of friends who had also been paid 
money by Epstein to provide sexual services to him. 
3. One of the victims identified was 
In January — February 2007, I 
used various computer indices to try and locate Ms. 
By using these indices and other 
means, I found two international phone numbers which I believed were being used by Ms. 
Case r 
•; 
• 
GOVERNMENT 
EXF
HIBIT 
 • 
EFTA00185244

Case 9:08-cv-80736-KAM Document 304-1 Entered on FLSD Docket 01/30/2015 Page 2 of 3 
=Ir 
4. Sometime during January — February 2007. I called the one of the numbers, in an 
attempt to speak to Ms. 
Also in my office was FBI Special Agent 
the lead agent for the investigation of Jeffrey Epstein. I was not using a 
speakerphone when I spoke with Ms. 
I asked S/A 
to be present because 
she, as the lead agent, was thoroughly versed in the details of the entire investigation, and I might 
need her assistance to respond to a question posed by Ms. 
that I was unable to answer. 
5. When I dialed the number, a young woman answered the phone. I told her my name. 
identified myself as a Special Agent with the FBI. and asked if she was-She 
said yes. I used a technique which I employ when speaking to people on the phone, who might 
question whether I am truly an FBI agent. I provided her with the phone number of the FBI 
Field Office in Miami, Florida, and told her she could hang up and verify the number. She 
could then call me back at the number, and her call would be routed to me. Ms. 
said that 
would not be necessary. 
6. I told Ms. 
about our investigation ofJeffrey Epstein, and the allegations that 
Epstein had sexually abused many underage young girls. I told her we believed she might be a 
victim of sexual abuse by Epstein. 
7. Ms. 
answered basic questions, telling me that she did know Jeffrey Epstein. 
She quickly became uncomfortable, telling me she moved away to distance herself from this 
situation, and expressing her desire to "let this be in my past." She asked that I not bother her 
with this again. 
8. I thanked Ms. 
and told her I appreciated her time. I provided my name and 
encouraged her to call the FBI Miami Field Office, if she had any questions or needed assistance. 
2 
Govt Exhibit 0 
Case No. 08-80736-CN-MARFtA 
EFTA00185245