EFTA00206173

From: 
(USAFLS) 
Sent: Monda March 28, 2011 3:33 PM 
To: 
(USAFLS) 
(USAFLS); 
Cc: 
(USAFLS); 
. (USAFLS) 
Subject: RE: John Connolly Vanity Fair magazine -- Proposed responses 
is an individual's recusal and the basis thereof Privacy Act protected? 
After discussing with M, I am ok leaving that out. 
From: 
(USAFLS) 
Sent: Monda March 28, 2011 3:31 PM 
To: 
(USAFLS ; 
USAFLS); 
Cc: 
(USAFLS); 
. (USAFLS) 
Subject: Re: John Connolly Vanity Fair magazine -- Proposed responses 
. (USAFLS) 
. (USAFLS) 
Would the recusal request also be governed by the Privacy Act? While I do not like commenting on the 
2008 recusal in a vacuum because of the erroneous inferences to which it could lead, it also seems to 
me that we might want to say something about why we're not responding to the recusal question. It 
also seems to me that an individual's recusal and the basis thereof might potentially fall under the 
Privacy Act. 
From: 
Sent: Monda 
To: 
Cc: 
(USAFLS) 
March 28, 2011 03:16 PM 
(USAFLS); 
USAFLS); 
(USAFLS) 
(USAFLS); 
(USAFLS) 
Subject: RE: John Connolly Vanity Fair magazine -- Proposed responses 
I think we should delete the line "Mr. Acosta recused from the matter in November 2008. That recusal 
was reviewed and approved by the Department of Justice, as is the standard procedure in all recusal 
matters." We simply shouldn't comment on 2008 Alex's recusal. I am comfortable with the rest with 
one caveat. If (and only if) the Roth letter has in fact been publicly filed, we could send that as well. 
Make sense? 
EFTA00206493

From: 
Sent: Monda 
To: 
Cc: 
Subject: John Connolly Vanity Fair magazine -- Proposed responses 
(USAFLS) 
March 28, 2011 2:45 PM 
. (USAFLS ; 
(USAFLS); 
(USAFLS); 
(USAFLS) 
. (USAFLS) 
Hi guys —
Below please find my proposed answers [in red ink] to John Conolly of Vanity Fair. 
Let's discuss ASAP so I can send him a response. 
After we agree on a proposed response, I need to run this by DOJ-Public Affairs before sending out. 
Thanks 
From: john1885c [mailto: 
Sent: Frid
larch 18, 2011 1:51 PM 
To: 
,M 
(USAFLS) 
Subject: From: John Connolly Vanity Fair magazine Please confirm receipt. 
AUSA 
It was a pleasure speaking with you this morning. As per your request here are questions I 
would like to have answered for a piece I am researching on Jeffrey Epstein. As life would have it I am 
going to be on a busman's holiday this coming week on Singer Island, FL. I would like to meet you 
and whomever else you think I should speak with. If not, I understand perfectly. 
Let me preface these questions by saying that AUSA 
who was in charge of the 
investigation of Jeffrey Epstein has a remarkably record as a prosecutor. I also know that an AUSA 
does not have the authority to grant a potential defendant a non -prosecution agreement without the 
permission of higher ups in the Justice Department. 
Not quite three years ago, the US Attorney for the Southern District of Florida, granted Jeffrey Epstein 
a non-prosecution agreement in return for his accepting a FL State plea deal for his illegal acts 
regarding sex with minor females. The state case was handled by the West Palm Beach State 
Prosecutor who has since left office. 
Re terms and conditions of imprisonment: 
EFTA00206494

--Was your office aware of the extraordinary sweet deal that Mr. Epstein was granted by that state 
prosecutor? 
--Was your office at the time of the agreement aware that Mr. Epstein would not be sent to a state 
prison facility as almost all defendants who are sentenced to more that a year in prison are required to 
do? 
--Was your office aware that Mr. Epstein would serve his sentence in the local WPB jail? 
--Was your office aware that Mr. Epstein would be allowed, what most FL law enforcement officials 
describe as "beyond a sweetheart deal", in that six days a week at 7:00 AM Mr. Epstein would leave 
the the WPB jail with a corrections officer he was personally paying for, and be escorted to the office of 
attorney Jack Goldberger where he would be allowed to stay until 11:00 PM and then be returned to 
jail for the evening? 
Ostensibly this was so that Mr. Epstein could work on a new charity he had formed. This despite the 
fact that just prior to beginning his jail sentence, Mr. Epstein liquidated his charity and gave $18 million 
to a charity run by the wife of his former patron. 
--Does the US Attorney believe that Mr. Epstein was working on a charity? 
--Was Mr. Epstein doing work as a Confidential Informer for the federal government as he has in the 
past? 
Mr. Eptein was Victim # 1 in the federal indictment of two Bear Stears executives on fraud charges 
stemming from a mortgage backed fund that went under. Mr. Epstein lost almost $70 million in that 
fund. 
--Was Mr. Epstein working on the government case while working on "His Charity"? 
--Has your office ever agreed to any allow any other prisoner the same or similar sweet deal? 
--Was your office aware that in return for Mr. Goldberger's help, Mr. Epstein purchased for him a top of 
the line black BMW? (Sadly for Goldberger he was in an accident and totaled the vehicle three weeks 
later.) 
The USAO reached a NPA with Mr. Epstein in good faith. The Agreement speaks for itself about the 
expectations of the USAO regarding the length and conditions of punishment. Ultimately, the 
sentence was imposed by the State Court Judge who presided over the matter. 
At this time, we cannot comment further on your questions regarding any possible cooperation by Mr. 
Epstein, or what the USAO might have known or not known at the time of the negotiations. 
Re Alex Acosta alleged Conflict/Recusal Issue: 
It has come to my attention that the R. Alexander Acos to former Attorney General for the Southern 
District of Florida during the investigation and non-prosecution agreement with Mr. Epstein had been a 
law partner and friend of two Mr. Epstein's lawyers. Both Ken Star and Jay Lefkowitz had been 
partners with Mr. Acosta at the law firm of Kirkland & Ellis prior to his being appointed by President 
Bush. 
EFTA00206495

I have been told by sources that Mr. Acosta was the person responsible for the decision not to 
prosecute Mr. Epstein. 
I have also been told that during Mr. Starr's trip to FL to speak with federal prosecutors he complained 
to Mr. Acosta that the press coverage of his trips to FL on Mr. Epstein's private jets were being leaked 
by FBI agents. ( I can assure you that was not true.) 
--Did Mr. Acosta recuse himself from any discussions about the Epstein case so as to avoid even the 
appearance of impropriety? 
--Was the possibility of his removing himself from the case ever discussed by officials in the Justice 
Department? 
--Are there any memos regarding that? 
--Is there currently an Office of Professional Responsibility investigation into the facts surrounding the 
handling of this case and Mr. Acosta actions in it? 
Mr. Acosta recused from the matter in November 2008. That recusal was reviewed and approved by 
the Department of Justice, as is the standard procedure in all recusal matters. 
DOJ policy and the Privacy Act prohibit comment on the existence or non-existence of OPR 
investigations. However, please note that, at the request of the defense, the office of the deputy 
attorney general reviewed the U.S. Attorney's handling of this matter, including allegations of 
misconduct, and determined there was no basis to intervene in the matter. We will not be making 
additional comments. Thanks for checking with us. 
Thanks so much for your help, John Connolly 
From: 
(USAFLS) 
Sent: 
Monday, March 28, 2011 3:17 PM 
To: 
(USAFLS); 
(USAFLS); 
Cc: 
(USAFLS); 
. (USAFLS) 
Subject: 
RE: John Connolly Vanity Fair magazine -- Proposed responses 
(USAFLS) 
I think we should delete the line "Mr. Acosta recused from the matter in November 2008. That recusal 
was reviewed and approved by the Department of Justice, as is the standard procedure in all recusal 
matters." We simply shouldn't comment on 2008 Alex's recusal. I am comfortable with the rest with 
one caveat. If (and only if) the Roth letter has in fact been publicly filed, we could send that as well. 
Make sense? 
EFTA00206496

From: 
Sent: Monda 
To: 
Cc: 
Subject: John Connolly Vanity Fair magazine -- Proposed responses 
(USAFLS) 
March 28, 2011 2:45 PM 
. (USAFLS ; 
(USAFLS); 
(USAFLS); 
(USAFLS) 
. (USAFLS) 
Hi guys —
Below please find my proposed answers [in red ink] to John Conolly of Vanity Fair. 
Let's discuss ASAP so I can send him a response. 
After we agree on a proposed response, I need to run this by DOJ-Public Affairs before sending out. 
Thanks 
From: john1885c [mailto: 
Sent: Frid
larch 18, 2011 1:51 PM 
To: 
,M 
(USAFLS) 
Subject: From: John Connolly Vanity Fair magazine Please confirm receipt. 
AUSA 
It was a pleasure speaking with you this morning. As per your request here are questions I 
would like to have answered for a piece I am researching on Jeffrey Epstein. As life would have it I am 
going to be on a busman's holiday this coming week on Singer Island, FL. I would like to meet you 
and whomever else you think I should speak with. If not, I understand perfectly. 
Let me preface these questions by saying that AUSA 
who was in charge of the 
investigation of Jeffrey Epstein has a remarkably record as a prosecutor. I also know that an AUSA 
does not have the authority to grant a potential defendant a non -prosecution agreement without the 
permission of higher ups in the Justice Department. 
Not quite three years ago, the US Attorney for the Southern District of Florida, granted Jeffrey Epstein 
a non-prosecution agreement in return for his accepting a FL State plea deal for his illegal acts 
regarding sex with minor females. The state case was handled by the West Palm Beach State 
Prosecutor who has since left office. 
Re terms and conditions of imprisonment: 
EFTA00206497

--Was your office aware of the extraordinary sweet deal that Mr. Epstein was granted by that state 
prosecutor? 
--Was your office at the time of the agreement aware that Mr. Epstein would not be sent to a state 
prison facility as almost all defendants who are sentenced to more that a year in prison are required to 
do? 
--Was your office aware that Mr. Epstein would serve his sentence in the local WPB jail? 
--Was your office aware that Mr. Epstein would be allowed, what most FL law enforcement officials 
describe as "beyond a sweetheart deal", in that six days a week at 7:00 AM Mr. Epstein would leave 
the the WPB jail with a corrections officer he was personally paying for, and be escorted to the office of 
attorney Jack Goldberger where he would be allowed to stay until 11:00 PM and then be returned to 
jail for the evening? 
Ostensibly this was so that Mr. Epstein could work on a new charity he had formed. This despite the 
fact that just prior to beginning his jail sentence, Mr. Epstein liquidated his charity and gave $18 million 
to a charity run by the wife of his former patron. 
--Does the US Attorney believe that Mr. Epstein was working on a charity? 
--Was Mr. Epstein doing work as a Confidential Informer for the federal government as he has in the 
past? 
Mr. Eptein was Victim # 1 in the federal indictment of two Bear Stears executives on fraud charges 
stemming from a mortgage backed fund that went under. Mr. Epstein lost almost $70 million in that 
fund. 
--Was Mr. Epstein working on the government case while working on "His Charity"? 
--Has your office ever agreed to any allow any other prisoner the same or similar sweet deal? 
--Was your office aware that in return for Mr. Goldberger's help, Mr. Epstein purchased for him a top of 
the line black BMW? (Sadly for Goldberger he was in an accident and totaled the vehicle three weeks 
later.) 
The USAO reached a NPA with Mr. Epstein in good faith. The Agreement speaks for itself about the 
expectations of the USAO regarding the length and conditions of punishment. Ultimately, the 
sentence was imposed by the State Court Judge who presided over the matter. 
At this time, we cannot comment further on your questions regarding any possible cooperation by Mr. 
Epstein, or what the USAO might have known or not known at the time of the negotiations. 
Re Alex Acosta alleged Conflict/Recusal Issue: 
It has come to my attention that the R. Alexander Acos to former Attorney General for the Southern 
District of Florida during the investigation and non-prosecution agreement with Mr. Epstein had been a 
law partner and friend of two Mr. Epstein's lawyers. Both Ken Star and Jay Lefkowitz had been 
partners with Mr. Acosta at the law firm of Kirkland & Ellis prior to his being appointed by President 
Bush. 
EFTA00206498

I have been told by sources that Mr. Acosta was the person responsible for the decision not to 
prosecute Mr. Epstein. 
I have also been told that during Mr. Starr's trip to FL to speak with federal prosecutors he complained 
to Mr. Acosta that the press coverage of his trips to FL on Mr. Epstein's private jets were being leaked 
by FBI agents. ( I can assure you that was not true.) 
--Did Mr. Acosta recuse himself from any discussions about the Epstein case so as to avoid even the 
appearance of impropriety? 
--Was the possibility of his removing himself from the case ever discussed by officials in the Justice 
Department? 
--Are there any memos regarding that? 
--Is there currently an Office of Professional Responsibility investigation into the facts surrounding the 
handling of this case and Mr. Acosta actions in it? 
Mr. Acosta recused from the matter in November 2008. That recusal was reviewed and approved by 
the Department of Justice, as is the standard procedure in all recusal matters. 
DOJ policy and the Privacy Act prohibit comment on the existence or non-existence of OPR 
investigations. However, please note that, at the request of the defense, the office of the deputy 
attorney general reviewed the U.S. Attorney's handling of this matter, including allegations of 
misconduct, and determined there was no basis to intervene in the matter. We will not be making 
additional comments. Thanks for checking with us. 
Thanks so much for your help, John Connolly 
From: 
(USAFLS) <
Sent: 
Monday, March 28, 2011 3:31 PM 
To: 
(USAFLS); 
(USAFLS); 
Cc: 
(USAFLS); 
. (USAFLS) 
Subject: 
Re: John Connolly Vanity Fair magazine -- Proposed responses 
.(USAFLS) 
Would the recusal request also be governed by the Privacy Act? While I do not like commenting on the 
2008 recusal in a vacuum because of the erroneous inferences to which it could lead, it also seems to 
me that we might want to say something about why we're not responding to the recusal question. It 
also seems to me that an individual's recusal and the basis thereof might potentially fall under the 
Privacy Act. 
EFTA00206499

From: 
(USAFLS) 
Sent: Monda March 28, 2011 03:16 PM 
To: 
(USAFLS); 
USAFLS); 
(USAFLS) 
Cc: 
(USAFLS); 
(USAFLS) 
Subject: RE: John Connolly Vanity Fair magazine -- Proposed responses 
I think we should delete the line "Mr. Acosta recused from the matter in November 2008. That recusal 
was reviewed and approved by the Department of Justice, as is the standard procedure in all recusal 
matters." We simply shouldn't comment on 2008 Alex's recusal. I am comfortable with the rest with 
one caveat. If (and only if) the Roth letter has in fact been publicly filed, we could send that as well. 
Make sense? 
From: 
(USAFLS) 
Sent: Monda March 28, 2011 2:45 PM 
To: 
. (USAFLS); 
(USAFLS); 
Cc: 
(USAFLS); 
. (USAFLS) 
Subject: John Connolly Vanity Fair magazine -- Proposed responses 
(USAFLS) 
Hi guys —
Below please find my proposed answers [in red ink] to John Conolly of Vanity Fair. 
Let's discuss ASAP so I can send him a response. 
After we agree on a proposed response, I need to run this by DOJ-Public Affairs before sending out. 
Thanks 
From: john1885c [mailto: 
Sent: Fridl
larch 18, 2011 1:51 PM 
To: 
,M 
(USAFLS) 
Subject: From: John Connolly Vanity Fair magazine Please confirm receipt. 
AUSA 
It was a pleasure speaking with you this morning. As per your request here are questions I 
would like to have answered for a piece I am researching on Jeffrey Epstein. As life would have it I am 
going to be on a busman's holiday this coming week on Singer Island, FL. I would like to meet you 
and whomever else you think I should speak with. If not, I understand perfectly. 
EFTA00206500

Let me preface these questions by saying that AUSA 
who was in charge of the 
investigation of Jeffrey Epstein has a remarkably record as a prosecutor. I also know that an AUSA 
does not have the authority to grant a potential defendant a non -prosecution agreement without the 
permission of higher ups in the Justice Department. 
Not quite three years ago, the US Attorney for the Southern District of Florida, granted Jeffrey Epstein 
a non-prosecution agreement in return for his accepting a FL State plea deal for his illegal acts 
regarding sex with minor females. The state case was handled by the West Palm Beach State 
Prosecutor who has since left office. 
Re terms and conditions of imprisonment: 
--Was your office aware of the extraordinary sweet deal that Mr. Epstein was granted by that state 
prosecutor? 
--Was your office at the time of the agreement aware that Mr. Epstein would not be sent to a state 
prison facility as almost all defendants who are sentenced to more that a year in prison are required to 
do? 
--Was your office aware that Mr. Epstein would serve his sentence in the local WPB jail? 
--Was your office aware that Mr. Epstein would be allowed, what most FL law enforcement officials 
describe as "beyond a sweetheart deal", in that six days a week at 7:00 AM Mr. Epstein would leave 
the the WPB jail with a corrections officer he was personally paying for, and be escorted to the office of 
attorney Jack Goldberger where he would be allowed to stay until 11:00 PM and then be returned to 
jail for the evening? 
Ostensibly this was so that Mr. Epstein could work on a new charity he had formed. This despite the 
fact that just prior to beginning his jail sentence, Mr. Epstein liquidated his charity and gave $18 million 
to a charity run by the wife of his former patron. 
--Does the US Attorney believe that Mr. Epstein was working on a charity? 
--Was Mr. Epstein doing work as a Confidential Informer for the federal government as he has in the 
past? 
Mr. Eptein was Victim # 1 in the federal indictment of two Bear Stears executives on fraud charges 
stemming from a mortgage backed fund that went under. Mr. Epstein lost almost $70 million in that 
fund. 
--Was Mr. Epstein working on the government case while working on "His Charity"? 
--Has your office ever agreed to any allow any other prisoner the same or similar sweet deal? 
--Was your office aware that in return for Mr. Goldberger's help, Mr. Epstein purchased for him a top of 
the line black BMW? (Sadly for Goldberger he was in an accident and totaled the vehicle three weeks 
later.) 
The USAO reached a NPA with Mr. Epstein in good faith. The Agreement speaks for itself about the 
expectations of the USAO regarding the length and conditions of punishment. Ultimately, the 
sentence was imposed by the State Court Judge who presided over the matter. 
EFTA00206501

At this time, we cannot comment further on your questions regarding any possible cooperation by Mr. 
Epstein, or what the USAO might have known or not known at the time of the negotiations. 
Re Alex Acosta alleged Conflict/Recusal Issue: 
It has come to my attention that the R. Alexander Acos to former Attorney General for the Southern 
District of Florida during the investigation and non-prosecution agreement with Mr. Epstein had been a 
law partner and friend of two Mr. Epstein's lawyers. Both Ken Star and Jay Lefkowitz had been 
partners with Mr. Acosta at the law firm of Kirkland & Ellis prior to his being appointed by President 
Bush. 
I have been told by sources that Mr. Acosta was the person responsible for the decision not to 
prosecute Mr. Epstein. 
I have also been told that during Mr. Starr's trip to FL to speak with federal prosecutors he complained 
to Mr. Acosta that the press coverage of his trips to FL on Mr. Epstein's private jets were being leaked 
by FBI agents. ( I can assure you that was not true.) 
--Did Mr. Acosta recuse himself from any discussions about the Epstein case so as to avoid even the 
appearance of impropriety? 
--Was the possibility of his removing himself from the case ever discussed by officials in the Justice 
Department? 
--Are there any memos regarding that? 
--Is there currently an Office of Professional Responsibility investigation into the facts surrounding the 
handling of this case and Mr. Acosta actions in it? 
Mr. Acosta recused from the matter in November 2008. That recusal was reviewed and approved by 
the Department of Justice, as is the standard procedure in all recusal matters. 
DOJ policy and the Privacy Act prohibit comment on the existence or non-existence of OPR 
investigations. However, please note that, at the request of the defense, the office of the deputy 
attorney general reviewed the U.S. Attorney's handling of this matter, including allegations of 
misconduct, and determined there was no basis to intervene in the matter. We will not be making 
additional comments. Thanks for checking with us. 
Thanks so much for your help, John Connolly 
EFTA00206502

From: 
(USAFLS) ‹
> 
Sent: 
Friday, April 01, 2011 5:22 PM 
To: 
(USAFLS); 
(USAFLS); 
Cc: 
(USAFLS) 
Subject: 
FW: Doe v. USAO 
Attachments: 
WordPerfect 6.1.WPD 
(USAFLS) 
Hi everyone — This is a draft of Epstein's motion to intervene. One strategic issue. I just took a quick 
glance and noticed that some of the cases and arguments that I have in my draft (which I am about to 
send to you) are raised in Epstein's motion. I think that we should file before Epstein does. I don't 
want there to be a suggestion that we "copied" from them. 
Assistant U.S. Attorney 
Fax 
From: Jackie Perczek [mailto:JPerczek@royblack.com] 
Sent: Frida , A ril 01, 2011 4:58 PM 
To: 
. (USAFLS); 
(USAFLS) 
Cc: Roy BLACK 
Subject: Doe v. USAO 
Good afternoon 
and Ann 
Consistent with the conversation Roy and I had with 
this week, attached is a working draft of 
the motion to intervene and the objections we intend to lodge to the recent filings of Doe 1 and Doe 2 
concerning discovery and disclosure of plea negotiation letters and emails. Please let us know your 
position. 
Have a good weekend, 
Jackie 
From: 
(USAFLS) ‹
> 
Sent: 
Tuesday, April 05, 2011 9:39 AM 
To: 
(USAFLS); 
(USAFLS); 
(USAFLS) 
Subject: 
RE: Epstein 
EFTA00206503

Is there any chance that we could start at 4:30? I have an appointment at 3:45 just to have a quick blood test 
down the street, but I don't want to cut it too close. 
Assistant U.S. Attorney 
Fax 
 
Ori inal 
intment 
From: 
(USAFLS) On Behalf Of 
(USAFLS) 
Sent: Tuesda Aril 05, 2011 9:18 AM 
To: 
(USAFLS); 
(USAFLS); 
(USAFLS) 
Subject: Epstein 
When: Tuesday, April 05, 2011 4:00 PM-4:30 PM (GMT-05:00) Eastern Time (US & Canada). 
Where: = 
ofcl= 
by phone 
-----
Subject: 
Location: 
Epstein 
ofc./M by phone 
Start: 
Tue 4/5/2011 4:00 PM 
End: 
Tue 4/5/2011 4:30 PM 
Show Time As: 
Tentative 
Recurrence: 
(none) 
Organizer: 
(USAFLS) 
Required Attendees: 
(USAFLS); 
(USAFLS); 
. (USAFLS) 
When: Tuesday, A ril 05, 2011 4:00 PM-4:30 PM (GMT-05:00) Eastern Time (US & Canada). 
Where: 
()kJ= by phone 
Note: The GMT offset above does not reflect daylight saving time adjustments. 
From: 
(USAFLS) < 
Sent: 
Saturday, April 02, 2011 5:20 PM 
To: 
(USAFLS); 
(USAFLS); 
(USAFLS); 
(USAFLS); 
Cc: 
(OLP) (J MD); 
(USAEO); 
(USAEO) 
EFTA00206504

Subject: 
Attachments: 
Draft Opposition to Victims' Motion for Finding of Violations 
victims_govt_opp_motion_enforce.wpd 
Colleagues, 
Attached please find my draft opposition to the petitioners' motion for finding of violations of the CVRA. I have 
responded to the arguments in Cassell's motion, and also argued that the court lacks authority to set aside the 
non-prosecution agreement, assuming arguendo it found a violation of section 3771(a)(5). As to the 
statement of uncontroverted facts, I admitted those facts which we believe to be true, but denied as irrelevant 
those which have no bearing on the statutory interpretation issue. We could actually contend that all the 
"facts" alleged by Cassell are irrelevant, but I wanted to demonstrate good faith in agreeing to certain of the 
facts. 
I welcome your comments and suggestions. Our response is due on Thursday, April 7, 2011. I will begin 
working on the other two motions filed by Cassell. 
Thanks for your assistance. If you have any questions, please call me at 
• 
«victims_govt_opp_motion_enforce.wpd» 
From: 
(USAFLS) 
Sent: 
Tuesday, April 05, 2011 9:42 AM 
To: 
(USAFLS); 
(USAFLS); 
(USAFLS) 
Subject: 
RE: Epstein 
As soon as I am back in the office I will email all of you. 
Assistant U.S. Attorney 
Fax 
From: 
(USAFLS) 
Sent: Tuesda , A ril 05, 2011 9:41 AM 
To: 
. (USAFLS); 
(USAFLS); 
(USAFLS) 
Subject: Re: Epstein 
EFTA00206505

Ok with me (I need to leave here by 5:00 for yet another going away party but that should give is 
enough time). 
From: 
(USAFLS) 
Sent: Tuesda , A ril 05, 2011 09:39 AM 
To: 
(USAFLS); 
(USAFLS); 
(USAFLS) 
Subject: RE: Epstein 
Is there any chance that we could start at 4:30? I have an appointment at 3:45 just to have a quick 
blood test down the street, but I don't want to cut it too close. 
Assistant U.S. Attorney 
Fax 
 
Ori inal A 
ointment 
From: 
(USAFLS) On Behalf Of 
(USAFLS) 
Sent: Tuesda , A ril 05, 2011 9:18 AM 
To: 
(USAFLS); 
(USAFLS); 
. (USAFLS) 
Subject: Epstein 
When: Tuesday, A. ril 05, 2011 4:00 PM-4:30 PM (GMT-05:00) Eastern Time (US & Canada). 
Where: 
ofc./M by phone 
From: 
Sent: 
To: 
Subject: 
(USAFLS) '(
.> 
Tuesday, April 05, 2011 9:41 AM 
. (USAFLS); 
(LISAFL5); 
(LISAFLS) 
Re: Epstein 
Ok with me (I need to leave here by 5:00 for yet another going away party but that should give is 
enough time). 
From: 
(USAFLS) 
Sent: Tuesda , A ril 05, 2011 09:39 AM 
To: 
(USAFLS); 
(USAFLS); 
(USAFLS) 
Subject: RE: Epstein 
EFTA00206506

Is there any chance that we could start at 4:30? I have an appointment at 3:45 just to have a quick blood test 
down the street, but I don't want to cut it too close. 
Assistant U.S. Attorney 
Fax 
 
Ori inal 
intment 
From: 
(USAFLS) On Behalf Of 
(USAFLS) 
Sent: Tuesda Aril 05, 2011 9:18 AM 
To: 
(USAFLS); 
(USAFLS); 
(USAFLS) 
Subject: Epstein 
When: Tuesday, April 05, 2011 4:00 PM-4:30 PM (GMT-05:00) Eastern Time (US & Canada). 
Where: = 
ofc.M by phone 
From: 
(USAFLS) 
Sent: 
Sunday, April 03, 2011 2:40 PM 
To: 
(USAFLS); 
(USAFLS); 
(USAFLS); 
); 
(USAFLS) 
Cc: 
(OLP) (JMD); 
(USAEO); 
Subject: 
RE: Draft Opposition to Victims' Motion for Finding of Violations 
Attachments: 
Response to Summary Judgment Motn 4-3-2011.wpd 
Good afternoon, everyone. 
Here is my attempt at addressing the same topics. I will work with 
<<Response to Summary Judgment Motn 4-3-2011.wpd>> 
(USAFLS); 
(USAEO) 
tomorrow to meld the two into one. 
One thought on the "statement of undisputed facts," I would not respond to it at all in this response, I would only 
discuss it in the response to Docket Entry 49 ("Jane Does Motion to Have Their Facts Accepted Because of the 
Government's Failure to Contest Any of the Facts.") 
First I would hammer the fact that they told the court that there was no need for any more facts at the last hearing 
on this case. Then, I would not agree to many of their "facts" that 
has listed as admitted. In my start of a 
draft response to DE 49, which I have sent to 
I included the following: 
We note the Justice Department's policy not to comment on the guilt or innocence of an unconvicted person. 
The ABA's Model Rules of Professional Conduct on the Special Responsibilities of a Prosecutor contains similar 
guidance. For example, there has been no civil or criminal finding by any judge or jury that: 
EFTA00206507

defendant Jeffrey Epstein (a billionaire with significant with significant political connections) sexually abused 
more than 30 minor girls at his mansion in West Palm Beach (sic), Florida, and elsewhere. Epstein 
performed repeated lewd, lascivious, and sexual acts on them, including (but not limited to) 
. Because Epstein used a means of interstate commerce and 
knowingly traveled in interstate commerce to engage in abuse of Jane Doe #1 and Jane Doe #2 (and the 
other victims), he committed violations of federal law, including repeated violations of 18 U.S.C. § 2422. 
(DE48 at 3-4 ¶ 1.) Jane Does No. 1 and No. 2 had the opportunity to prove these allegations at trial but elected 
to sign confidential settlement agreements where, presumably, there was no acknowledgement of criminal or 
civil liability. Respectfully, the U.S. Attorney's Office will leave the final determinations of what, if any, crimes 
Mr. Epstein committed (other than those to which he pled guilty in Palm Beach County Circuit Court), to any 
judge and/or jury who are called upon to see and hear the evidence against Mr. Epstein. 
My concern is that if we agree to statements like these, on behalf of the Department of Justice, it can be used 
against another USAO that may try to prosecute Epstein in the future. 
Assistant U.S. Attorney 
From: 
(USAFLS) 
Sent: Saturda Aril 02 2011 5:20 PM 
To: 
(USAFLS); -.
(USAFLS); 
(USAFLS 
Cc: 
. (SMO); 
(USAEO); 
Subject: Draft Opposition to Victims' Motion for Finding of Violations 
Colleagues, 
(USAEO) 
(USAFLS); 
Attached please find my draft opposition to the petitioners' motion for finding of violations of the CVRA. I have 
responded to the arguments in Cassell's motion, and also argued that the court lacks authority to set aside the 
non-prosecution agreement, assuming arguendo it found a violation of section 3771(a)(5). As to the 
statement of uncontroverted facts, I admitted those facts which we believe to be true, but denied as irrelevant 
those which have no bearing on the statutory interpretation issue. We could actually contend that all the 
"facts" alleged by Cassell are irrelevant, but I wanted to demonstrate good faith in agreeing to certain of the 
facts. 
I welcome your comments and suggestions. Our response is due on Thursday, April 7, 2011. I will begin 
working on the other two motions filed by Cassell. 
Thanks for your assistance. If you have any questions, please call me at 
From: 
Sent: 
To: 
Subject: 
(USAFLS) 
Thursday, April 07, 2011 8:12 AM 
Fw: Blended Opposition to Motion for Finding of Violations 
EFTA00206508

Attachments: 
yictim_blended_opp_mot_enforce.wpd 
Hi 
. Since you will most likely have to defend on appeal, can you make sure everything is ok? 
From: 
(USAFLS) 
Sent: Wednesda A ril 06, 2011 04:52 PM 
To: 
. (USAFLS); 
USAFLS) 
Cc: 
(USAFLS) 
Subject: Blended Opposition to Motion for Finding of Violations 
Colleagues, 
. (USAFLS); 
(USAFLS); 
Attached please find a document integrating the draft oppositions that 
and I prepared. I deleted the 
following: (1) lack of standing argument; (2) no case or controversy argument (mootness); and (3) victims' 
exclusive remedy is to file an administrative complaint with the Attorney General. 
From 
draft, I included the procedural history, the analysis of all 8 rights and how the government either 
complied, or the right did not attach, and the analysis on separation of powers and prosecutorial discretion. 
Please let me know what you think. If you wish to discuss the revisions, please let me know. Thanks. 
<<yictim_blended_opp_mot_enforce.wpd» 
From: 
Sent: 
To: 
Subject: 
Importance: 
(USAFLS)
). 
Wednesday, April 06, 2011 8:43 PM 
(USAFLS) 
RE: Emailing: Facts Response 4-6-2011 short.wpd 
High 
Hi 
- Sorry - Still need your feedback on the question of attachments! 
My recommendations to attach to this document are: (1) the letter to Edwards notifying his clients of 
Epstein's work release; (2) the letter to PBSO asking them to keep us informed of Epstein's status so 
that we can notify the victims; (3) some sort of record showing Epstein's release from jail and 
termination of community control; and (4) [I have to ask] the John Roth letter. 
EFTA00206509

Assistant U.S. Attorney 
Fax 
From: 
(USAFLS) 
Sent: Wednesda A ril 06, 2011 7:24 PM 
To: 
. USAFLS 
Cc: 
(USAFLS); 
(USAFLS) 
Subject: RE: Emailing: Facts Response 4-6-2011 short.wpd 
Here are my thoughts. I had already gone through 90% your response this morning, so I prepared a 
redlined version of your 2 drafts and consolidated my comments/suggestions/questions. I hope it 
helps. Call me if you have any questions. 
• 
F 
 
Original Message
rom: 
. (USAFLS)
Sent: Wednesda , A ril 06, 2011 6:08 PM 
To: 
USAFLS 
(USAFLS); 
(USAFLS); 
(USAFLS) 
Subject: RE: Emailing: Facts Response 4-6-2011 short.wpd 
Poor 
M, you do not have to read the whole thing. I have 2 strategy questions for you that I would like some 
input on. First, the question regarding the attachments (see below), and second, whether or not to 
leave in footnote 8. 
Thanks. 
EFTA00206510

Assistant U.S. Attorney 
Fax 
 
Original Message 
From: 
(USAFLS) 
Sent: Wednesday, April 06, 2011 6:05 PM 
To: 
USAFLS ; 
(USAFLS); 
(USAFLS); 
. (USAFLS); 
(USAFLS) 
Cc: 
Subject: RE: Emailing: Facts Response 4-6-2011 short.wpd 
Unless there is a reason for one of us on 8 to read this and comment, I am comfortable leaving it in the 
capable hands of 
and 
. If anyone wants or needs someone on 8 to chime in, 
has 
graciously volunteered. 
 
Original Message 
From: 
(USAFLS) 
Sent: Wednesday, April 06, 2011 5:56 PM 
To: 
(USAFLS ; 
(USAFLS); 
(USAFLS); 
. (USAFLS); 
(USAFLS) 
Cc: 
Subject: Emailing: Facts Response 4-6-2011 short.wpd 
EFTA00206511

Hi everyone -- I have done a rewrite based on 
comments, but maybe take a look and give me 
some more comments. As you know everything is due tomorrow. 
My recommendations to attach to this document are: (1) the letter to Edwards notifying his clients of 
Epstein's work release; (2) the letter to PBSO asking them to keep us informed of Epstein's status so 
that we can notify the victims; (3) some sort of record showing Epstein's release from jail and 
termination of community control; and (4) [I have to ask] the John Roth letter. 
Thanks. 
Assistant U.S. Attorney 
Fax 
EFTA00206512