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543 of 1456 DOCUMENTS 
Copyright 2003 The Financial Times Limited 
Financial Times (London,England) 
August 20, 2003 Wednesday 
London Edition I 
SECTION: BACK PAGE - FIRST SECTION; Pg. 18 
LENGTH: 7'48 words 
HEADLINE.: Wall Street spearheads push to secure academic freedom: A scheme that began in the 1930s, 
and helped physicist Felix Bloch and writer Thomas Mann, seeks a Dollars 10m revival. Gary Silverman 
reports 
BYLLNE: By GARY SILVERMAN 
BODY: 
About a year and a half ago, a small circle of wealthy investors collected Dollars 2m (Pounds I.2m) to 
conduct a novel experiment on the extent of global academic freedom. 
The group, which included 
Soros, Henry Jarecki and Jeffrey Epstein established a fund to 
help scholars escape threats in their ome countries and find teaching work elsewhere. The donors made 
their offer in the spirit of the movie, Field of Dreams, which held that "if you build it, they will come'. Still, 
they were stunned by the response. 
About 300 academics from 65 countries sought help from the Scholar Rescue Fund, which is being 
administered by the non-profit Institute of International Education. 
Many of the threats to scholars came from likely suspects - African warlords, Colombian drug 
traffickers, terrorists and religious fundamentalists. But the organisers were also struck by the heartbreaking 
singularity of so many of the cases. 
A marine biologist in a former republic of the Soviet Union angered government officials by studying 
local shellfish populations. An African academic was threatened after discovering that funds had been 
stolen from a university library. One western European government even sought help for a local scholar 
who was threatened by a separatist movement. 
"The overwhelming majority of cases involve people who haven't taken sides." said Allan Goodman, 
IIE president and chief executive. 
"They just happened to be scholars who are teaching in the wrong field, or they happened to be from 
the wrong ethnic group or. in one case, they have the same surname as the leader of a faction and they have 
been targeted." 
The extent of the problem led the organisers to a sad conclusion - their work needed to take a more 
permanent form. 
They are now trying to raise a Dollars I Om endowment for the Scholar Rescue Fund. They may also 
start an index of academic freedom that would spotlight abuses in particular countries. 
"The impact and need has been greater than we expected," says Mr Soros, comparing the effort to his 
work on behalf of central and eastern European dissidents in the 1980s. 
So far, the fund has helped 30 scholars from 19 countries escape persecution and find work at 
institutions ranging from Princeton University to the Geological Survey of Norway. The rescues 
themselves can be dangerous and the IIE often turns to human rights groups for logistical help. 
EFTA00226836

The fund arranges for the scholars to get teaching positions, providing annual stipends of up to Dollars 
20,000 to smooth the transition. 
The IIE's role in helping intellectuals is not a new role as it started in the 1930s and was led by Edward 
R. Murrow, an IIE assistant director and later a legendary CBS reporter. Among those it helped were Felix 
Bloch, the physicist, theologians Martin Buber and Paul 
Tillich, Thomas Mann. the novelist, and philosopher Herbert Marcuse. 
The latest effort to rescue scholars bears the imprint of Wall Street. Tom Russo, a Lehman Brothers 
,vice-chairman and an LIE trustee, has been a prime mover in the project. He helped recruit the donors and 
define the rationale for the rescue work. For Mr Russo, academic freedom is like market transparency - a 
"source of light" that keeps society functioning smoothly. 
Deciding on which requests should receive help has been a job worthy of Solomon. The fund has heard 
from scholars who live in dangerous places but face no particular threat as individuals - a requirement for 
receiving help. Mr Goodman says this is often the case in places such as Israel's occupied territories, 
although the LIE has made one rescue there. 
Dr Jarecki, a psychiatrist who made a fortune in bullion dealing and other ventures, said the fund is 
also trying hard to avoid contributing to a "brain drain" of academic talent in developing countries. Many of 
the applicants face threats to their security, but others simply want to move for economic reasons. 
However, the organisers say they are trying to resist the temptation of being too cautious in their work. 
He says he frequently brings up the example of a 1938 conference in Evian, France, that was held to 
discuss the resettlement of German and Austrian Jews. The Dominican Republic agreed to accept between 
50,000 and 100,000 Jews. But by the time the "proper" arrangements were made, a world war was raging 
and it was too late to do much good. 
In this case, Dr Jarecki says, the fund will work out how best to achieve its aims as it goes along. But. 
he adds: "I thought we should start by doing it." 
LOAD-DATE: August 19, 2003 
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581 of 1456 DOCUMENTS 
Copyright 2003 Associated Press 
All Rights Reserved 
The Associated Press State & Local Wire 
February 7, 2003, Friday, BC cycle 
SECTION: State and Regional 
LENGTH: 200 words 
HEADLINE: Financier pledges S30 million to support Harvard researcher 
DATELINE: CA4BRIDGE, Mass. 
BODY: 
Reclusive financier Jeffrey Epstein has pledged up to S30 million to Harvard University to support a 
newly recruited professor's research in the field of mathematical biology. 
A spokeswoman for Harvard president 
H. Summers confirmed Friday that Epstein's 
contribution will support the research of Martin A. owak, who is scheduled to join the Harvard faculty on 
July 1. 
Epstein, who reportedly manages billions of dollars from his private island in the Caribbean, already 
made a donation and plans to eventually establish a 530 million endowment to support Nowak's research, 
spokeswoman Lucie McNeil said. She did not specify how much he has already given. 
Nowak, 36. currently a professor at Princeton's Institute of Advanced Study, uses advanced 
mathematics to model human behavior and to study evolutionary theory, viruses and cancers. He was 
recruited to Harvard as part of Summers' commitment to grant tenure to young professors and those who do 
interdisciplinary research. 
The self-educated Epstein is both a longtime Harvard contributor and a benefactor of Nowak, to whom 
he previously donated $500,000, the Harvard Crimson student newspaper reported. 
LOAD-DATE: February 8, 2003 
EFTA00226838

(26.) A. Sloman, "Architectural Requirements for Human-Like Agents both Natural and Artificial," K. 
Dautenhahn, Editor, Human Cognition and Social Agent Technology, John Benjamins, Amsterdam (2000), 
pp. 163-195. 
(27.) M. Minsky, "Common Sense-Based Interfaces," Communications of the ACM 43, No. 8, 67-73 
(2001). 
(28.) M. Minsky, "A Framework for Representing Knowledge," Al Laboratory Memo 306, Artificial 
Intelligence LabonaMassachusetts Institute of Technology (1974), reprinted in The Psychology of 
Computer Vision, 
Winston, Editor, McGraw-Hill. New York (1975). 
(29.) D. Riecken, "An Architecture of Integrated Agents," Communications of the ACM 37, No. 7, 
107.116 (1994). 
Accepted for publication May 17, 2002. 
J. McCarthy 
Stanford University 
Stanford, California 
M. Minsky 
Massachusetts Institute of Technology 
Cambridge, Massachusetts 
A. Sloman 
University of Birmingham 
Birmingham, UK 
L. Gong 
IBM Research Division 
Hawthorne, New York 
T. Lau 
IBM Research Division 
Hawthorne, New York 
L. Morgenstern 
IBM Research Division 
Hawthorne, New York 
E. T. Mueller 
IBM Research Division 
Hawthorne, New York 
EFTA00226839

el 
• 
D. Riecken 
IBM Research Division 
Hawthorne, New York 
M. Singh 
IBM Research Division 
Hawthorne, New York 
P. Singh 
Massachusetts Institute of Technology 
Cambridge, Massachusetts 
IAC-CREATE-DATE: September 26, 2003 
LOAD-DATE: October 07, 2003 
EFTA00226840

11:00aa 
Fron-Fowler-Vhi le Burnett 
67/16/2007 09:46 
3053582006 
Roy BLACK 
HOWARD M. aRtneadCR 
BO= A. KOlitiatud 
Lean A. Swan 
Kau Ntva 
JAcest Ptneux 
MARX A.J. SHAPIRO 
JARED Loin 
305709320) 
BLACK SREB & KORN 
BLACK 
SREBNICK 
KORNSPAN 
&STUMPF 
=PA  = 
July 13, 2007 
VIA IFAC6114772 15611802.1787 AND U.B. inn 
Assistant 
zu 
s Attorney 
Office of the United States Attorney 
Southern District of Florida 
500 South Australian Avenue, Suite 400 
West Palm Beach, Florida 33401 
Re: 
Grand Jury Subpoena - William Riley 
Dear 
1-151 
P 002/00e 
F-Eise 
PAGE 
82 
attain= Et: 
JantcA Mesta-
KAnattrr P. PHILlaa 
AARON A/MION 
Mutes BUTCH. JR. 
MArnaW P. OBRivr 
E-Mail: REttocagytovillack.com 
I represent Jeffrey Epstein, the target of a pending Grand July investigation. 
Prior to the initiation of this federal investigation, I represented Mr. Epstein on a 
Palm Beach Florida State Attorneys Office investigation and subsequently an 
Information, the factual basis of which is identical to, and gave rise to, the federal 
investigation presently underway. 
In connection with my earlier representation of Mr. Epstein, I hired Mr. 
William Riley as a private investigator to act under my direction in anticipation of 
defending Mr. Epstein against possible criminal charges and any litigation which 
may have followed. All his investigations were done as my agent and thus are 
covered by the work product privilege, and all communications to him arc 
protected by the attorney client privilege. 
Though we are not conceding the existence of any computers that would be 
4k 
2
 All, 
responsive to the subpoena served upon Mr. Riley, to the extent there are any 
such computers, they would contain documents that are privileged attorney-client / 
7CL.;>.1 
communications and attorney work-product. Your subpoena also asks fo -e
(  ). 
, 
) e 
materials describing the scope of hia investigation and thus they are our work 
j 
r 
--/ 
product.  
 
. 
20i S. Biscayne Boulevard. Suite i300 • stand. Florida llpi • Phone. 30S-37i-642I • Fax: 10S-358.2006 • unev4RoyEtlact.corn 
Case No. 08-80736-CV-MARRA 
Exhibit 34 
EFTA00226841

JJI-I6-07 
11:0lan 
Fror-Forloi-White Burnett 
305/899201 
07/16/2007 09:46 
3053582006 
BLACg SREB 2, WORN 
T-I51 
P 003/004 1819 
PAGE 
e3 
As you know, the United States Attorneys Office Manual Guidelines for 
Issuing Grand Jury and Thal Sub-poi-has to-Attorneya for Information Relating to 
the Representation of Clients, requires that the attorney client and work-product 
privilleged information sought by the Grand Jury subpoena issued to Mr. Riley 
must first be authorized by the Assistant Attorney General for the Criminal 
Division before it may issue. 
Therefore, please Ovise me as to whether the applicable sections of the 
United States Attorneys Office Manual was complied with priori° the issuance, 
of the Grand Jury subpoena to Mr. Riley. Please also advise as to the preliminarY 
steps taken in advance of the issuance of the subpoena, as required by the 
Manual. Finally, please provide me with the name of the Assistant Attorney 
General of the Criminal Division who undertook the evaluation of the request for 
the Grand Jury subpoena, as required by the same section of the Manual and, if 
an evaluation was made, the basis upon which the Assistant determined that the 
information sought in the subpoena was not protected by a valid claim of privilege. 
RS/tog 
Sincerely, 
R r Black 
Black SrebrUck. Komspan & Stumpf. P.A 
11/4) QIV) 
Case No. 08-80736-CV-MARRA 
P-011926 
EFTA00226842

LAW OF-FMCS O. 
B. LEncourrr, P.G. 
♦ PROFESSIONµ CORPORATION 
CAST 78'" STIIEET 
NEW 
. NEW YOlltooet 
GERALD U. LEI- COURT 
101071.2414)(COPRIEW corn 
SHERYL E. REICH 
michalleBourIlso art 
RENATO C. STABILE 
0 2,4013 4ekourtIrs corn 
FAITH A. FRIEDMAN 
1100dITIPATIPIEOWtlawcom 
BY HAND 
Dear Mr. Mcnchcl: 
July 25. 2007 
Jeffrey Epstein 
TELEPHONE 
12.217370400 
EAESINI-E 
(212)988.8102 
We have previously provided you with a memo as to why we believe no charge under I8 
U.S.C. §2422(b) could or should be brought against Jeffrey Epstein, even assuming the specific 
conduct that you have alleged actually occurred. In that memo, we detailed Congress's intent in 
enacting this statute. We also posited that the languSe statute would have to be stretched 
beyond recognition to fit the particular facts of Mr. 
case.t Enclosed is data that strongly 
supports the arguments we previously made. We have thoroughly analyzed every prosecution 
brought under the statute for which data could be obtained. Based on that analysis, we submit 
that the prosecutions actually brought under the statute overwhelmingly confirm the limits to 
prosecution we have previously identified.2
I For several months, we have also been consulting on this matter with Stephanie Thacker, former 
Principal Deputy Chief, Department of Justice, Child Exploitation & Obscenity Section. Ms. Thacker 
supports our position without reservation that this is not a matter upon which the federal statues should 
be brought to bear. Ms. Thacker would also welcome any questions or concerns you would like to raise 
with her. 
2 Please note that the enclosed chart amends the one provided to you earlier this week by adding 
additional details recently located. 
Exhibit 35 
EFTA00226843

1/4.1 2. 
5, 2007 LeCCouri 4 DerSkuivii-E. 
l's 1-4-e. 
EFTA00226844

LAW OFfICCli or 
GERALD B. LEFCOURT., PC. 
For example, of the 184 prosecutions in which at least one count alleges a violation of 
§2422(b), in the overwhelming majority of those cases — 160, or over 85% -- the "means" of 
interstate communication was the Internet and involved the classic "Internet trolling" — far 
different from the behavior alleged here. Of that subset, the vast majority — 113 -- were "sting" 
operations involving "children" (actually, agents) said to be between 2 and 14 years of age. The 
government in each of those instances took every precaution to verify that the defendant's actions 
were undertaken "knowingly". To the extent we can determine the facts, it appears that prior to a 
case being brought, in each instance multiple explicit (and recorded) conversations were had, so 
there could be no question as to when the inducement was attempted, whether the inducement 
was of explicit unlawful sexual activity, or what the defendant's belief was as to the age of the 
victim. Again, this has no applicability to the facts alleged here. 
The data is informative in other ways, as well. Though there are a handful of cases in 
which the telephone is one of a multiple of means of interstate communications allegedly used, in 
only two such cases, both far different from the facts here,3 was the use of the telephone the sole 
means of the wrongdoing alleged. In the remaining telephone cases, the §2422(b) count is only 
one of several amongst various charges of possession of child pornography, violence, and the 
like. 
The data from the chart also establish that in the vast majority of the cases brought, no 
sexual activity was actually consummated. That confirms that prosecutions under §2422(b) are 
focused on protecting the federal interest in preventing the means of interstate communication 
from being used to commit crimes, particularly with respect to activities that are traditionally 
difficult for the state to prosecute. A prosecution predicated on an incidental telephone call used 
as a "hook" to trigger federal jurisdiction in order to punish a defendant for the underlying sexual 
activity is well out of, not only the mainstream of §2422(b) prosecutions, but all §2422(b) cases 
that have ever been brought. Here, the state is fully able to prosecute the conduct alleged. 
We understand that the government believes it possesses proof that on various occasions 
telephone calls were allegedly made on Mr. Epstein's behalf by other persons who allegedly 
3 As detailed in the introductory section to the chart, among the differences arc that those cases involve 
pimps who conceded that their businesses hinged on the use of telephones. Moreover, it is unequivocal 
that the arrangements being made are for sexual activity with underage women. 
EFTA00226845

LAW Of IICZ• or 
GERALD B. LEPCOUET. PC. 
spoke directly or indirectly to women who were under 18. As the message books taken 
(unlawfully, in our view) during the search of Mr. Epstein's home clearly show, many women 
initiated the interactions by repeatedly calling to schedule massages. If the calls on which the 
government might seek to rely were merely "return" calls, certainly any alleged "inducement" 
would be far from unambiguous. And of course, the woman who called would have to have been 
known by Mr. Epstein to be under 18, and further, Mr. Epstein would have to have known and 
intended that a specific sexual activity unlawful under Florida law was being induced. 
Thus, contrary to there being unambiguous proof of the required elements of a §2422(b) 
violation in this case, at least the following defects exist: 
First, it is hardly the case that every massage resulted in sexual activity. Thus, merely 
because there was a telephone call, even one that might have "induced" a massage (which we 
dispute), such telephone call is not tantamount to the use of a telephone in violation of the 
statute. 
Second, even where a particular massage involved masturbation by Mr. Epstein or the 
touching of a woman, we dispute that any such conduct is a violation of any applicable Florida 
law. 
W 
focused on the evidence which reflects the sworn statement of, for 
example, 
, who told state investigators that she was asked to find women between 
18 and 20 who wo 
provide Mr. Epstein with topless massages and which sometimes involved 
their being touched. Fla. Stat. Ann. §796.07, a general statute which proscribes "prostitution" 
and "lewdness", regardless of whether an adult or minor is involved, is of very limited 
applicability here. That statute's definition of "prostitution" excludes conduct of which there 
may be evidence, specifically, a man masturbating himself while touching the breasts of another. 
Section 796.07(I)(a) defines "prostitution" as the giving or receiving of the body for sexual 
activity for hire. "Sexual activity" is defined to include "the handling or fondling of the sexual 
organ of another for the purpose of masturbation". Thus, "sexual activity" appears to cover 
situations where a woman is paid to masturbate a man but excludes the situation where the man 
masturbates himself in the presence of a woman. Any other reading of this statutory language 
would raise constitutional problems of fair warning, vagueness and lenity. 
EFTA00226846

LAW orriccs 
or 
GERALD B. LEECOURT. PC. 
We are, of course, mindful of the fact that, unbeknownst to Mr. Epstein, some of the 
women were in fact not yet 18. It is certainly not clear that any state statutes were violated by 
Mr. Epstein's conduct with any of these women, either. Florida law criminalizes relatively little 
sexual activity with persons between the ages of 16 and 18. For example, it is not a violation of 
the laws regulating sexual activity to receive a massage from a person between 16 and 18 who is 
topless or even naked. See Fla. Stat. Ann. §800.04 (lewd and lascivious conduct with a child 
between the age of 16 and 18). Nor does that statute make it a crime to touch the breasts or 
other private areas of someone between 16 and 18. Id And, of course, even if a state crime was 
committed, which we surely do not concede, that does not make out a federal crime, unless it 
could be proven that the defendant knowingly induced an illegal act over the telephone. 
Moreover, at best, the proof would show that only a small minority of massages resulted 
in what may possibly be characterized as sexual activity with a woman under the age of 18. But 
even where a massage involved sexual activity with a woman under 18, to the extent Mr. Epstein 
did not know the woman was under 18, or the telephone call did not induce the activity, or Mr. 
Epstein did not intend the sexual activity at the time the telephone call arranging the massage, or 
the person arranging the massage did not intend the sexual activity, there would be multiple 
additional barriers to a successful prosecution. 
Further, putting aside whether there is sufficient proof that Mr. Epstein knew (and not 
merely that he "should have" surmised) that any of the women were in fact under 18, the set of 
facts hypothesized above has never before provided a legally sufficient predicate for a 
prosecution under §2422(b) - or under any other federal statute. 
The enclosed chart clearly and compellingly demonstrates that every charge brought 
alleging a violation of §2422(b) is characterized by direct (not circumstantial and certainly not 
speculative) evidence of the defendant himself (not others on his behalf) using the means of 
interstate communication to communicate an unambiguous inducement to a person known to be 
underage or in the case of a sting, represented to be underage (or a person thought to be acting on 
behalf of such person) during the very communication that constitutes the required basis for 
federal jurisdiction. 
EFTA00226847

LAW OrriCCS or 
GERALD B. LEFCOURT, P.C. 
To our knowledge, the current investigation lacks any direct (or even circumstantial) 
proof that an inducement was made by Mr. Epstein during the pivotal communication that is at 
the very heart of any potential §2422(b) charge. Even if the government contends that Mr. 
Epstein induced unlawful sexual activity at some point, face to face, after a telephone call, the 
separation of the communication and the inducement takes Mr. Epstein's alleged misconduct 
outside the ambit of federal prosecution. It would be unprecedented (and unprincipled), as the 
chart demonstrates, to prosecute Mr. Epstein under §2422(b) absent proof beyond a reasonable 
doubt both that he knew the age of the person and that he intended in that communication to 
induce sexual activity that is unlawful under Florida law. It would also be unprecedented to 
prosecute Mr. Epstein under §2422(b) based on a telephone call made by a third party without 
direct proof that Mr. Epstein intended that telephone call to induce unlawful sexual activity. 
For all of these reasons, as well as those asserted at the meeting of June 26 and in our 
follow up letter dated July 6, 2007, as well as our earlier letter of June 25, we submit that no 
charge under 18 U.S.C. §2422(b) can be brought. If you have any questions or would like to 
discuss this further, we are available. 
Very truly yours, 
a
g-dtn` -2  111 
Th OlottotiZ,
Alan M. Dershowitz 
cc: Lilly Ann Sanchez, Esq. 
EFTA00226848