EFTA00224636

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Enter:inv., 
. October 9, 2007 - LAWYERS for Jeffrey Epstein - the billionaire Manhattan 
Ea investment manager who's agreed to plead guilty to soliciting underage 
prostitutes at his Palm Beach mansion in exchange for just 18 months in the 
stammer - are mulling asking federal prosecutors to drop their demand that he 
register as a sex offender. In a letter drafted, but not sent, to U.S. Attorney 
Alexander Costa and obtained by Page Six, Epstein's lawyer, Gerald 
Lefcourt, writes, "Doing so will have a profound impact [on Epstein) both 
immediately and forever after. Not only will he be restricted to a wholly 
inappropriate penal facility, but he will be required for the rest of his life to 
account for his whereabouts." Epstein, a former business partner of Daily 
News owner Mort Zuckerman, pleaded guilty to a state charge in exchange 
for the feds' dropping their probe into possible federal criminal violations. 
Lefcourt argues that only the feds have demanded that Epstein register, 
"despite the fact that the state was of the view that Mr. Epstein's conduct did 
not warrant registration." A rep for Epstein had no comment. 
NEW YORK POST Isa registered Uedemerk of NYP Holdings, kle. NYPOST.COM, NYPOSTONLINE.COM, and 
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Copyright 2008 NYP Holdings, Inc. All rights reserved 
http://www.nypost.com/php/p friendly/print.php/url=http://www.nypost.com/seven/1009200... 6/3/2008 
EFTA00224656

IN RE: 
INVESTIGATION OF 
JEFFREY EPSTEIN 
NON-PROSECUTION AGREEMENT 
IT APPEARING that the City of Palm Beach Police Department and the State 
Attorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, 
the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey 
Epstein (hereinafter "Epstein"); 
IT APPEARING that the State Attorney's Office has charged Epstein by indictment 
with solicitation of prostitution, in violation of Florida Statutes Section 796.07; 
IT APPEARING that the United States Attorney's Office and the Federal Bureau of 
Investigation have conducted their own investigation into Epstein's background and any 
offenses that may have been committed by Epstein against the United States from in or 
around 2001 through in or around September 2007, including: 
(1) 
knowingly and willfully conspiring with others known and unknown to 
commit an offense against the United States, that is, to use a facility or means 
of interstate or foreign commerce to knowingly persuade, induce, or entice 
minor females to engage in prostitution, in violation of Title 18, United States 
Code, Section 2422(b); all in violation of Title 18, United States Code, Section 
37 I ; 
(2) 
knowingly and willfully conspiring with others known and unknown to travel 
in interstate commerce for the purpose of engaging in illicit sexual conduct, as 
defined in 18 U.S.C. § 2423(9, with minor females, in violation of Title 18, 
United States Code, Section 2423(6); all in violation of Title 18, United States 
Code, Section 2423(c); 
(3) 
using a facility or means of interstate or foreign commerce to knowingly 
persuade, induce, or entice minor females to engage in prostitution; in 
violation of Title IS, United States Code, Sections 2422(b) and 2; 
(4) 
traveling in interstate commerce for the purpose of engaging in illicit sexual 
conduct, as defined in 18 U.S.C. § 2423(9, with minor females; in violation 
Page 1 of 7 
EFTA00224657

of Title 18, United States Code, Section 2423(b); and 
(5) 
knowingly, in and affecting interstate and foreign commerce, recruiting, 
enticing, and obtaining by any means a person, knowing that the person had 
not attained the age of 18 years and would be caused to engage in a 
commercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title 
18, United States Code, Sections 1591(aXI) and 2; and 
IT APPEARING that Epstein seeks to resolve globally his state and federal criminal 
liability and Epstein understands and acknowledges that, in exchange for the benefits 
provided by this agreement, he agrees to comply with its terms, including undertaking certain 
actions with the State Attorney's Office; 
IT APPEARING, after an investigation of the offenses and Epstein's background by 
both State and Federal law enforcement agencies, and after due consultation with the State 
Attorney's Office, that the interests of the United States, the State of Florida, and the 
Defendant will be served by the following procedure; 
THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for 
the Southern District of Florida, prosecution in this District for these offenses shall be 
deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the 
following conditions and the requirements of this Agreement set forth below. 
If the United States Attorney should determine, based on reliable evidence, that, 
during the period of the Agreement, Epstein willfully violated any of the conditions of this 
Agreement, then the United States Attorney may, within ninety (90) days following the 
expiration of the term of home confinement discussed below, provide Epstein with timely 
notice specifying the condition(s) of the Agreement that he has violated, and shall initiate its 
prosecution on any offense within sixty (60) days' of giving notice of the violation. Any 
notice provided to Epstein pursuant to this paragraph shall be provided within 60 days of the 
United States learning of facts which may provide a basis for a determination of a breach of 
the Agreement. 
After timely fulfilling all the terms and conditions of the Agreement, no prosecution 
for the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have 
been the subject of the joint investigation by the Federal Bureau of Investigation and the 
United States Attorney's Office, nor any offenses that arose from the Federal Grand Jury 
investigation will be instituted in this District, and the charges against Epstein if any, will be 
dismissed. 
Page 2 of 7 
EFTA00224658

Terms of the Agreement: 
I. 
Epstein shall plead guilty (not nolo contendere) to the Indictment as 
currently pending against him in the 15th Judicial Circuit in and for 
Palm Beach County (Case No. 2006-c1009495AXXXMB) charging 
one (1) count of solicitation of prostitution, in violation of Ft. Stat. § 
796.07. In addition, Epstein shall plead guilty to an Information filed 
by the State Attorney's Office charging Epstein with an offense that 
requires him to register as a sex offender, that is, the solicitation of 
minors to engage in prostitution, in violation of Florida Statutes Section 
796.03; 
2. 
Epstein shall make a binding recommendation that the Court impose a 
thirty (30) month sentence to be divided as follows: 
(a) 
Epstein shall be sentenced to consecutive terms of twelve (12) 
months and six (6) months in county jail for all charges, without 
any opportunity for withholding adjudication or sentencing, and 
without probation or community control 
in lieu of 
imprisonment; and 
(b) 
Epstein shall be sentenced to a term of twelve (12) months of 
community control consecutive to his two terms in county jail 
as described in Term 2(a), supra. 
3. 
This agreement is contingent upon a Judge of the 15th Judicial Circuit 
accepting and executing the sentence agreed upon between the State 
Attorney's Office and Epstein, the details of which are set forth in this 
agreement. 
4. 
The terms contained in paragraphs I and 2, supra, do not foreclose 
Epstein and the State Attorney's Office from agreeing to recommend 
any additional charge(s) or any additional term(s) of probation and/or 
incarceration. 
5. 
Epstein shall waive all challenges to the Information filed by the State 
Attorney's Office and shall waive the right to appeal his conviction and 
sentence, except a sentence that exceeds what is set forth in paragraph 
(2), sup-a. 
6. 
Epstein shall provide to the U.S. Attorney's Office copies of all 
Page 3 of 7 
EFTA00224659

proposed agreements with the State Attorney's Office prior to entering 
into those agreements. 
7. 
The United States shall provide Epstein's attorneys with a list of 
individuals whom it has identified as victims, as defined in 18 U.S.C. 
§ 2255, after Epstein has signed this agreement and been sentenced. 
Upon the execution of this agreement, the United States, in consultation 
with and subject to the good faith approval of Epstein's counsel, shall 
select an attorney representative for these persons, who shall be paid for 
by Epstein. Epstein's counsel may contact the identified individuals 
through that representative. 
8. 
If any of the individuals referred to in paragraph (7), supra, elects to 
file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the 
jurisdiction of the United States District Court for the Southern District 
of Florida over his person and/or the subject matter, and Epstein waives 
his right to contest liability and also waives his right to contest damages 
up to an amount as agreed to between the identified individual and 
Epstein, so long as the identified individual elects to proceed 
exclusively under 18 U.S.C. § 2255, and agrees to waive any other 
claim for damages, whether pursuant to state, federal, or common law. 
Notwithstanding this waiver, as to those individuals whose names 
appear on the list provided by the United States, Epstein's signature on 
this agreement, his waivers and failures to contest liability and such 
damages in any suit arc not to be construed as an admission of any 
criminal or civil liability. 
9. 
Epstein's signature on this agreement also is not to be construed as an 
admission of civil or criminal liability or a waiver of any jurisdictional 
or other defense as to any person whose name does not appear on the 
list provided by the United States. 
10. 
Except as to those individuals who elect to proceed exclusively under 
18 U.S.C. § 2255, as set forth in paragraph (8), supra, neither Epstein's 
signature on this agreement, nor its terms, nor any resulting waivers or 
settlements by Epstein are to be construed as admissions or evidence of 
civil or criminal liability or a waiver of any jurisdictional or other 
defense as to any person, whether or not her name appears on the list 
provided by the United States. 
II. 
Epstein shall use his best efforts to enter his guilty plea and be 
Page 4 of 7 
EFTA00224660

sentenced not later than October 26, 2007. The United States has no 
objection to Epstein self-reporting to begin serving his sentence not 
later than January 4, 2008. 
12. 
Epstein agrees that he will not be afforded any benefits with respect to 
gain time, other than the rights, opportunities, and benefits as any other 
inmate, including but not limited to, eligibility for gain time credit 
based on standard rules and regulations that apply in the State of 
Florida. At the United States' request, Epstein agrees to provide an 
accounting of the gain time he earned during his period of 
incarceration. 
13. 
The parties anticipate that this agreement will not be made part of any 
public record. If the United States receives a Freedom of Information 
Act request or any compulsory process commanding the disclosure of 
the agreement, it will provide notice to Epstein before making that 
disclosure. 
Epstein understands that the United States Attorney has no authority to require the 
State Attorney's Office to abide by any terms of this agreement. Epstein understands that 
it is his obligation to undertake discussions with the State Attorney's Office and to use his 
best efforts to ensure compliance with these procedures, which compliance will be necessary 
to satisfy the United States' interest. Epstein also understands that it is his obligation to use 
his best efforts to convince the Judge of the 15th Judicial Circuit to accept Epstein's binding 
recommendation regarding the sentence to be imposed, and understands that the failure to 
do so will be a breach of the agreement. 
In consideration of Epstein's agreement to plead guilty and to provide compensation 
in the manner described above, if Epstein successfully fulfills all of the terms and conditions 
of this agreement, the United States also agrees that it will not institute any criminal c 
es 
a ainst an 
tential co-cons irators of E 
' 
ding but not limited to 
or 
. Further, upon execution of this 
agreement and a plea agreement with the State Attorney's Office, the federal Grand Jury 
investigation will be suspended, and all pending federal Grand Jury subpoenas will be held 
in abeyance unless and until the defendant violates any term of this agreement. The 
defendant likewise agrees to withdraw his pending motion to intervene and to quash certain 
grand jury subpoenas. Both parties agree to maintain their evidence, specifically evidence 
requested by or directly related to the grand jury subpoenas that have been issued, and 
including certain computer equipment, inviolate until all of the terms of this agreement have 
been satisfied. Upon the successful completion of the terms of this agreement, all 
outstanding grand jury subpoenas shall be deemed withdrawn. 
Page 5 of 7 
EFTA00224661

By signing this agreement, Epstein asserts and certifies that each of these terms is 
material to this agreement and is supported by independent consideration and that a breach 
of any one of these conditions allows the United States to elect to terminate the agreement 
and to investigate and prosecute Epstein and any other individual or entity for any and all 
federal offenses. 
By signing this agreement, Epstein asserts and certifies that he is aware of the fact that 
the Sixth Amendment to the Constitution of the United States provides that in all criminal 
prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further 
is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court 
may dismiss an indictment, information, or complaint for unnecessary delay in presenting 
a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein 
hereby requests that the United States Attorney for the Southern District of Florida defer such 
prosecution. Epstein agrees and consents that any delay from the date of this Agreement to 
the date of initiation of prosecution, as provided for in the terms expressed herein, shall be 
deemed to be a necessary delay at his own request, and he hereby waives any defense to such 
prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of 
the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the 
United States to a speedy trial or to bar the prosecution by reason of the running of the statute 
of limitations for a period of months equal to the period between the signing of this 
agreement and the breach of this agreement as to those offenses that were the subject of the 
grand jury's investigation. Epstein further asserts and certifies that he understands that the 
Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all 
felonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees 
and consents that, if a prosecution against him is instituted for any offense that was the 
subject of the grand jury's investigation, it may be by way of an Information signed and filed 
by the United States Attorney, and hereby waives his right to be indicted by a grand jury as 
to any such offense. 
//I 
III 
Ill 
Page 6 of 7 
EFTA00224662

By signing this agreement, Epstein asserts and certifies that the above has been read 
and explained to him. Epstein hereby states that he understands the conditions of this Non-
Prosecution Agreement and agrees to comply with them. 
IL ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated: 
 
By: 
Dated:  ild9-
Dated: 
Dated: 
ASSISTANT U.S. ATTORNEY 
GERALD LEFCOURT, ESQ. 
COUNSEL TO JEFFREY EPSTEIN 
LILLY ANN SANCHI3Z, ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
Page 7 of 7 
lb
EFTA00224663

By signing this agreement, Epstein asserts and certifies that the above has been read 
and explained to him. Epstein hereby states that he understands the conditions of this Non-
Prosecution Agreement and agrees to comply with them. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated: 
 
By: 
ASSISTANT U.S. ATTORNEY 
Dated: 
Dated:  71 2-4f/ 07 
Dated: 
JEFFREY EPSTEIN 
RfLt) 
FCS
A-h/C* 
UNSEL TO JEFF 
Y EPSTEIN 
LILLY ANN SANCHEZ, ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
Page 7 of 7 
EFTA00224664

By signing this agreement, Epstein asserts and certifies that the above has been read 
and explained to hint. Epstein hereby states that he understands the conditions of this Non-
Prosecution Agreement and agrees to comply with them. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated: 
 
By: 
ASSISTANT U.S. ATTORNEY 
Dated: 
JEFFREY EPSTEIN 
Dated: 
GERALD LEFCOURT, ESQ. 
COUNSEL TO JEFFREY EPSTEIN 
Dated:q:
'-
ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
Page 7 of 7 
EFTA00224665

IN RE: 
INVESTIGATION OF 
JEFFREY EPSTEIN 
ADDENDUM TO THE NON-PROSECUTION AGREEMENT 
IT APPEARING that the parties seek to clarify certain provisions of page 4, paragraph 7 
of the Non-Prosecution Agreement (hereinafter "paragraph 7"), that agreement is modified as 
follows: 
7A. 
The United States has the right to assign to an independent third-party the responsibility 
for consulting with and, subject to the good faith approval of Epstein's counsel, selecting 
the attorney representative for the individuals identified under the Agreement. If the 
United States elects to assign this responsibility to an independent third-party, both the 
United States and Epstein retain the right to make good faith objections to the attorney 
representative suggested by the independent third-party prior to the final designation of 
the attorney representative. 
7B. 
The parties will jointly prepare a short written submission to the Independent third-party 
regarding the role of the attorney representative and regarding Epstein's Agreement to 
pay such attorney representative his or her regular customary hourly rate for representing 
such victims subject to the provisions of paragraph C, infra. 
7C. 
Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the attorney 
representative selected by the independent third party. This provision, however, shall not 
obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus, 
if after consideration of potential settlements, an attorney representative elects to file a 
contested lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested 
remedy, the paragraph 7 obligation of the Agreement to pay the costs of the attorney 
representative, as opposed to any statutory or other obligations to pay reasonable 
attorneys fees and costs such as those contained in s 2255 to bear the costs of the attorney 
representative, shall cease. 
EFTA00224666

Ey signing this Addendum, Epstein asserts and certifies that the abovo has been read and 
explained to him. Epstein hereby, states that he understands the clarifications to the Non-
Prosecution Agreement and agrees to comply with them. 
IL ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated:  /040 /07 
Dated:  /IV 
r ig —
Dated: 
Dated: 
MOJA' 
By: 
A9 9 A 
.S. A 
Y 
GERALD LEFCOURT, ESQ. 
COUNSEL TO JEFFREY EPSTEIN 
LILLY ANN SANCHEZ, ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
EFTA00224667

By signing this Addendum, Epstein asserts and certifies that the above has been read and 
explained to him. Epstein hereby states that he understands the clarifications to the Non-
Prosecution Agreement and agrees to comply with them. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated:  it 007 
By: 
Dated: 
Dated: 
ASSISTANT U.S. ATTORNEY 
JEFFREY EPSTEIN 
RALD LEFCO 
ESQ. 
COUNSEL TO JEFF 
Y EPSTEIN 
LILLY ANN SANCHEZ, ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
EFTA00224668

By signing this Addendum, Epstein asserts and certifies that the above has been read and 
explained to him. Epstein hereby states that he understands the clarifications to the Non-
Prosecution Agreement and agrees to comply with them. 
R. ALEXANDER ACOSTA 
ST L 
ATTO 
Y 
Dated:  /D 
0/0 
By: 
14 ASSISTANT U.S. ATTORNEY 
Dated: 
Dated: 
Dated: if:k_2
(73--
f4L4W 
JEFFREY EPSTEIN 
GERALD LEFCOURT, ESQ. 
COUNSEL TO JEFFREY EPSTEIN 
LILLY A 
ANCHEZ, ES 
ATTORNEY FOR JEFFREY EPSTEIN 
EFTA00224669

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
It ALEXANDER ACOSTA 
UNITED STAVES ATTORNEY 
DELIVERY BY FACSIMILE 
Lilly Ann Sanchez 
Fowler White Burnett, PA 
1395 Brickell Ave, le Floor 
Miami, FL 33131 
Re: 
Jeffrey Epstein 
Dear Ms. Sanchez: 
99 N E I Street 
Montt FL 11111 
- Telephone 
• Facsantk 
December 19, 2007 
I write to follow up on the December 146 meeting between defense counsel and the Epstein 
prosecutors, as well as our First Assistant, the Miami FBI Special Agent in Charge and myself I I 
write to you because I am not certain who among the defense team is the appropriate recipient of this 
letter. I address issues raised by several members of the defense team, and would thus ask that you 
please provide a copy of this letter to all appropriate defense team members. 
First, I would like to address the Section 2255 issue.2 As I stated in my December e letter, 
my understanding is that the Non-Prosecution Agreement entered into between this Office and Mr. 
Epstein responds to Mr. Epstein's desire to reach a global resolution of his state and federal criminal 
liability. Under this Agreement, this District has agreed to defer prosecution for enumerated sections 
Over the past two weeks, we have received several hundred pages of arguments and exhibits from defense counsel. 
This is not the forum to respond to the several items raised, and our silence should not be interpret as agreement; I 
would, however, like to address one issue. Your December I r h letter states that as a result of defense counsel 
objections to the appointment process, the USAO proposed an addendum to the Agreement to provide for the use of 
an independent third party selector. As I recall this matter, before I had any knowledge of defense counsel 
objections, I sua sponte proposed the Addendum to Mr. LeOcowitz at an October meeting in Paint Beach. I did this 
in an attempt to avoid what I foresaw would likely be a litigious selection process. It was only slier I proposed this 
change that Mr. LeOcowitz raised with me his enumerated concerns. 
2 Section 2255 provides that: "Nay person who, while a minor, was a victim of a violation of lenumemted sections 
of Title !SI and who suffers personal injury as a result of such violation . . . may sue in any appropriate United States 
District Court and shall recover the actual damages such person sustains and the cost of the suit. including a 
reasonable attorney's fee." 
EFTA00224670

of Title 18 in favor of prosecution by the State of Florida, provided that the Mr. Epstein satisfies 
three general federal interests: (1) that Mr. Epstein plead guilty to a "registerablc" state offense; (2) 
that this state plea include a binding recommendation for a sufficient term of imprisonment; and (3) 
that the Agreement not harm the interests of his victims. 
With this in mind, I have considered defense counsel arguments regarding the Section 2255 
portions of the Agreement. As I previously observed, our intent has been to place the victims in the 
same position as they would have been had Mr. Epstein been convicted at trial. No more; no less. 
From our meeting, it appears that the defense agrees that this was the intent. During the course of 
negotiations that intent was reduced to writing in Paragraphs 7 and 8, which as I wrote previously, 
appear far from simple to understand. I would thus propose that we solve our disagreements over 
interpretations by saying precisely what we mean, in a simple fashion. I would replace Paragraphs 7 
and 8 with the following language: 
"Any person, who while a minor, was a victim of a violation of an offense enumerated in 
Title 18, United States Code, Section 2255, will have the same rights to proceed under 
Section 2255 as she would have had, if Mr. Epstein been tried federally and convicted of an 
enumerated offense. For purposes of implementing this paragraph, the United States shall 
provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an 
Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority 
interpreting this provision, including any authority determining which evidentiary burdens if 
any a plaintiff must meet, shall consider that it is the intent of the parties to place these 
identified victims in the same position as they would have been had Mr. Epstein been 
convicted at trial. No more; no less." 
Second, I would like to address the issue of victim's rights pursuant to Section 3771. I 
understand that the defense objects to the victims being given notice of time and place of Mr. 
Epstein's state court sentencing hearing. I have reviewed the proposed victim notification letter and 
the statute. I would note that the United States provided the draft letter to defense as a courtesy. In 
addition, First Assistant United States Attorney 
already incorporated in the letter several 
edits that had been requested by defense counsel. I agree that Section 3771 applies to notice of 
proceedings and results of investigations of federal crimes as opposed to the state crime. We intend 
to provide victims with notice of the federal resolution, as required by law. We will defer to the 
discretion of the State Attorney regarding whether he wishes to provide victims with notice of the 
state proceedings, although we will provide him with the information necessary to do so if he wishes. 
Third, I would like to address the issue raised regarding Florida Statute Section 796.03. At 
our meeting, Professor Dershowitz took the position that Mr. Epstein believes that his conduct does 
not satisfy the elements of this offense. His assertion raises for me substantial concerns. This Office 
will not, and cannot, be a party to an agreement in which Mr. Epstein pleads guilty to an offense that 
he believes he did not commit. We are considering how best to proceed. 
2 
EFTA00224671

Finally, I would like to address a more general point. Our Agreement was first signed on 
September 24th, 2007. Pursuant to paragraph 11, Mr. Epstein was to use his best efforts to enter his 
guilty plea and be sentenced no later than October 26, 2007. As outlined in correspondence between 
our prosecutors and defense counsel, this deadline came and went. Our prosecutors reiterated to 
defense counsel several limes their concerns regarding delays, and in fact, asked me several weeks 
ago to declare the Agreement in breach because of those delays. 1 resisted that invitation. 1 share 
this fact because it is background to my frustration with what appears to be an 11'" hour appeal, 
weeks before the now scheduled January 4'h plea date. 
This said, the issues raised are important and must be fully vetted irrespective of timeliness 
concerns. We hope to preserve the January 4ih date. I understand that defense counsel shares our 
desire not to move that appearance and will work with our office to expedite this process over the 
next several days. With this in mind, and in the event that defense counsel may wish to seek review 
of our determinations in Washington D.C., I spoke this past Monday with the Assistant Attorney 
General Fisher, to inform her of a possible appeal, to ask her to grant the potential request for review, 
and to in fact review this case in an expedited manner to attempt to preserve the January 46 plea date. 
I want to again reiterate that it is not the intention of this Office ever to force the hand of a 
defendant to enter into an agreement against his wishes. Your client has the right to proceed to trial, 
and he should do so if he believes that he did not commit the elements of the charged offense. 
I will respond to the pending issues shortly. In the interim, I would ask that you 
communicate your position with respect to the sections 2255 and 3371 issues as quickly as possible. 
Sincerely, 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
cc: 
Alice Fisher. Assistant Attorney General 
First Assistant U.S. Attorney 
AUSA 
3 
EFTA00224672

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No: 
18 U.S.C. § 371 
18 U.S.C. § 1591(aX1) 
18 U.S.C. § 1591(aX2) 
18 U.S.C. § 2422(6) 
18 U.S.C. § 2423(e) 
18 U.S.C. § 2423(d) 
18 U.S.C. § 2423(6) 
UNITED STATES &AMERICA 
vs. 
JEFFREY EPSTEIN, 
and 
Defendants. 
A 
INDICTMENT 
The Grand Jury charges that: 
BACKGROUND
At all times relevant to this Indictment: 
1. 
Defendant JEFFREY EPSTEIN employed defendants 
anda 
and 
among other things, services as personal assistants. 
to perform, 
EFTA00224673

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No: 
18 U.S.C. § 371 
18 U.S.C. § 1591(a)(1) 
18 U.S.C. § 1591(a)(2) 
18 U.S.C. § 2422(b) 
18 U.S.C. § 2423(e) 
18 U.S.C. § 2423(d) 
18 U.S.C. § 2423(b) 
UNWED STATES CRAMERICA 
vs. 
JEFFREY EPSTEIN, 
dt
Mr," 
and 
Defendants. 
A 
INDICTMENT 
The Grand Jury charges that: 
BACKGROUND 
At all times relevant to this Indictment: 
I. 
Defendant JEFFREY EPSTEIN employed defendants 
aikia ‘O' 
and 
to perform, 
among other things, services as personal assistants. 
EFTA00224674

2. 
Defendant JEFFREY EPSTEIN. employed L.G. to perform, among other 
things, services as a personal assistant. 
Defendants JEFFREY EPSTEIN and 
and 
III. to perform, among other things, recruiting services. 
4. 
Defendant JEFFREY EPSTEIN owned a property located at 358 El Brillo Way, 
Palm Beach, Florida, in the Southern District of Florida (hereinafter referred to as "358 El 
Brillo Way"). 
5. 
Defendant JEFFREY EPSTEIN owned a property located at 9 East 71st Street, 
New York, New York (hereinafter referred to as "the New York residence"). 
6. 
Defendant JEFFREY EPSTEIN was the principal owner of JEGE, INC., a 
Delaware corporation. JEGE, INC.'s sole business activities related to the operation and 
ownership of a Boeing 727-31 aircrift,bearing tail number N908JE. 
7. 
Defendant JEFFREY EPSTEIN served as president, sole director, and sole 
shareholder of JEGE, INC., and had the power to direct all of its operations. 
8. 
Defendant JEFFREY EPSTEIN was the principal owner of Hyperion Air, Inc., 
a Delaware corporation. Hyperion Air, Inc.'s sole business activities related to the operation 
and ownership of a Gulfstream G-1159B aircraft bearing tail number N909JE. 
9. 
Defendant JEFFREY EPSTEIN served as president, sole director, and sole 
shareholder of Hyperion Air, Inc., and had the power to direct all of its operations. 
EFTA00224675