EFTA00230208

Nor would he discuss anything about who might or might not be representing Mr. Epstein. Weinstein 
told Mr. Thomas that he should not allow himself to be spun one way or the other in response to 
statements Mr. Thomas said he had received from attorneys who said that they represented Mr. 
Epstein. Weinstein ended the conversation by telling Mr. Thomas that he would check further into 
his sixth and final topic and get back to him later in the day. 
B. 
Afternoon ofJanuary 2, 2008. 
Weinstein informed Mr. Thomas that in regard to his sixth topic, the SDFL had no reason 
to question FAUSA Sloman's judgment or integrity. He also said that this particular subject matter 
was a private matter that FAUSA Sloman did not want to discuss with him." Mr. Thomas told him 
that if he had any further questions, he would call back. 
C. 
Afternoon of January 3, 2008. 
This call was in response to a voice mail message that Mr. Thomas had left regarding legal 
issues involving specific state and federal statutes. Specifically, Mr. Thomas had some questions 
about the burden of proof and strict liability in some state and federal statutes that governed illegal 
sexual activity. Again, Weinstein told him that he would not discuss any specific cases, but that he 
would assist him in understanding the statutes about which he had some questions. Weinstein 
explained that some statutes contained defenses that must be proven by a defendant, while there were 
other statutes that did not require a defendant to affirmatively prove a defense. The discussion 
centered around Title 18, United States Code, § 2423(g). Once again, Mr. Thomas told Weinstein 
that if he had any further questions, he would call back. 
D. 
Afternoon of January 4, 2008. 
This was another call in response to a voice mail message that Mr. Thomas had left regarding 
some additional questions. Weinstein prefaced the conversation by saying that he would not discuss 
any specific cases. The conversation centered around three specific statutes, 18 United States Code, 
§ 2422(b), 18 United States Code, § 1591, and 18 United States Code, § 2423(6) as well as the 
14 The case involving "Jonathan Zirulnikoff" involved a March 7, 2007 early morning attempted 
break-in of my/Sloman's house. Zirulnikoff, age 19 at the time, confessed and said that he wanted to 
"talk" to my daughter who was then 16. He also confessed to a prior unrelated break in which Zirulnikoff 
caressed the inner thigh of a 15 year old female. Zirulnikoff who had graduated from my daughter's high 
school in June 2006, dated my daughter's friend and had little if any contact with my daughter for over 
one year. Zirulnikoff negotiated a plea deal, over my objection, with the Miami-Dade State Attorney's 
Office to a misdemeanor trespass. That conviction resulted in a sentence of two years probation and a 
withhold of adjudication upon successful completion of his probationary period. Since this information 
was completely irrelevant to the facts and issues in the instant Epstein matter, I refused to allow Mr. 
Weinstein to comment about this matter to Mr. Thomas. Furthermore, none of this information had been 
publicized and, upon information and belief, only one member of Epstein's legal team knew anything 
about this matter, my former colleague, 
Confidential and Privileged — Attorney Work Product 
-11-
Case No. 08-80736-CV-MARRA 
P-013423 
EFTA00230328

burden of proof and the applicability of affirmative defenses. They discussed the difference between 
an attempt and a substantive charge pursuant to § 2422(b) and how that affected the government's 
burden of proof vis-a-vis the age of a child. They also discussed the fact that a charge pursuant to 
§ 1591 required the government to prove that the defendant had actual knowledge of the age of the 
victim. Finally, they discussed the fact that if the government was charging a defendant with 
traveling to engage in prostitution, pursuant to § 2423(b), there was an affirmative defense available 
to the defendant regarding the reasonable belief of the defendant about the age of the victim. 
E. 
Afternoon of January 7, 2008. 
This final call was made after the U.S. Attorney and FAUSA Sloman had received a call from 
a member of Mr. Epstein's defense team alleging that the SDFL had provided case specific 
information to the media. Weinstein called Mr. Thomas who acknowledged that both before and 
after each of the above-mentioned conversations, he had also called attorneys who were representing 
Mr. Epstein on his pending State charges. Mr. Thomas also acknowledged that all of our prior 
conversations had been about general legal issues and that Weinstein never spoke about any specific 
case. Since the January 7, 2008 conversation, Weinstein has not had any further contact with Mr. 
Thomas. 
2. 
Herman Sloman & Mermelstein (May 5, 2001 - October 1, 2001). 
Seven years ago, I resigned from the SDFL for private practice. Less than five months later, 
I resigned from the law firm and returned to the SDFL. Public records reflect the following: on May 
8, 2001, articles of amendment were filed with the Florida Division of Corporations to reflect that 
the firm name of "Herman & Mermelstein" was changed to "Herman Sloman & Mermelstein" on 
May 7, 2001. I joined the firm at that time and remained a non-equity partner until on or about 
October 1, 2001. At that time, I resigned from the firm and returned to the SDFL. Since I never had 
an equity interest in the firm, I never retained an interest in the firm. That was over six and one half 
years ago. 
Unbeknownst to FAUSA Sloman, on July 2, 2002, articles of amendment were filed with the 
Florida Division of Corporations to reflect that the firm name of "Herman Sloman & Mermelstein" 
was changed back to "Herman & Mermelstein." The article of amendment indicates the amendment 
was adopted on July 1, 2002, without shareholder action. Although the filing was not immediate 
upon my departure from the law firm, it pre-dated for years any dealings with the subject case now 
under consideration by the SDFL. Recently, I learned that there is a reference to the law firm of 
"Herman Sluman & Mermelstein" on the Florida Bar website, under a section called "Find A 
Lawyer." This reference appears when Stuart Mermelstein's name and information is accessed. To 
reiterate, since October 2001, I have had no relationship with that law firm, financial or otherwise, 
and no input or control over the firm's filings with the Florida Division of Corporations and/or the 
Florida Bar. 
On Friday, January 18, 2008, at approximately 1:15 pm, I received a call from Jeffrey 
Herman of Herman & Mermelstein. Herman said that he was planning to file a civil lawsuit the next 
Confidential and Privileged — Attorney Work Product 
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Case No. 08-80736-CV-MARRA 
P-013424 
EFTA00230329

week against Jeffrey Epstein. He said that his clients were frustrated with the lack of progress of the 
state's investigation and wanted to know whether the SDFL could file criminal charges even though 
the state was looking into the matter. I told I lerman that I would not answer any question related to 
Epstein — hypothetical or otherwise. I asked him how his clients retained him and he said that it was 
through another lawyer. I then specifically asked him whether the referral was the result of anyone 
in law enforcement contacting him and/or the other lawyer. He said "no." At the conclusion of the 
conversation, I reiterated and confirmed with him that 1 had refused to answer any questions he asked 
of me. I immediately documented this conversation and informed the U.S. Attorney who informed 
Senior Litigation Counsel and Ethics Advisor Dexter Lee. AUSA Lee opined that he did not see a 
conflict. As soon as I became aware of these allegations, I reported myself to the Office of 
Professional Regulation on or about April 21, 2008. 
3. 
The Alleged Unprecedented Extension of Federal Law and the Allegations of 
Political Motivation for the Prosecution 
It is my hope that this letter has sufficiently explained how thoroughly this matter has been 
reviewed, how seriously the issues have been considered, and how additional delays may adversely 
affect the case going forward and, more importantly, the victims. I have attached the proposed draft 
indictment for you to consider the nature and gravity of the crimes. See Tab G. 
invited to 
evaluate whether I, along with U.S. Attorney Acolliminal Division Chiefs 
 
d, later 
Deputy Criminal Division Chiefs, 
followed byl
laill
and AUSA 
somehow steered this investigation toward "an unprecedented extension of federal 
law"despite being simultaneously and/or subsequently reviewed by CEOS, DAAG Mandelker, and 
AAG Fisher. I also hope that the reputations of the above-mentioned professional prosecutors 
combined with the documented layers of methodical and thorough review of all issues raised by 
Epstein are enough to summarily dismiss the idea that this matter is politically motivated. It seems 
incomprehensible how Messrs. Starr and Whitley could expect further review when the due process 
rights of their client have been considered and reconsidered to the point of absurdity. 
With respect to the other allegations of misconduct leveled against investigators and 
prosecutors, similarly false allegations were made against the local police detective who first 
investigated the case. Those false allegations apparently were accepted as true and were not 
investigated or challenged by the State Attorney's Office and, when coupled with the immense 
pressure brought to bear upon the State Attorney by some of these same lawyers who represent 
Epstein today, resulted in a single felony charge related to only two of the more than 20 victims 
identified in the state investigation. Contrary to the claims of Epstein's attorneys, the SDFL is not 
trying to prosecute Epstein more harshly because of his political friends or his financial status; rather, 
the SDFL is attempting to follow Department policy by treating Epstein like all other criminal 
defendants — charging him with the most serious readily provable offenses. The SDFL has even 
continued to allow Epstein the opportunity to perform his obligations under the Non-Prosecution 
Agreement despite his numerous breaches of and attacks on the terms to which he already agreed. 
Without attempting to address each and every allegation, I would like to highlight some of 
the misstatements contained in counsels' letter, to provide some sense of counsels' conduct 
Confidential and Privileged — Attorney Work Product 
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Case No. 08-80736-CV-MARRA 
P-013425 
EFTA00230330

throughout this case, particularly after their attempts at legal persuasion failed. Throughout the case, 
counsel have misrepresented the facts of the case to our Office, CEOS, and the press. For example, 
Epstein's counsel reference to this case as "precedent-shattering," suggests that all of the victims 
were at least 16 years old, and that the conduct "was purely local in nature." The SDFL has 
prosecuted several "sex tourism" cases where the "john" communicated via telephone with an 
undercover "pimp" in the SDFL to meet minor females to engage in prostitution. All were charged 
and convicted of violating 18 U.S.C. § 1591. The SDFL has charged and convicted a 21-year-old 
man of violating 18 U.S.C. § 2423 when he traveled to Florida to meet his 14-year-old girlfriend and 
later digitally penetrated her. The SDFL has prosecuted numerous violations of 18 U.S.C. § 2422 
where the "facility of interstate commerce" — generally the Internet and telephones — are used by a 
defendant and an undercover pretending to be the parent of a minor, to arrange for a meeting that the 
defendant hopes will result in sexual activity. There is nothing extraordinary about Epstein's case 
except the large number of victims involved. 
Epstein's counsel neglected to inform you that the age range of the victims includes girls as 
young as 14, and glosses over the fact that Epstein did not simply engage in "solo self-pleasuring" 
in front of the victims. Instead, with each visit, he pressured the victims to allow him to engage in 
more and more sexual activity — fondling breasts and vaginas, digital penetration, use of a vibrator 
on their vaginas, performing oral sex on them, having them perform oral sex on his adult girlfriend, 
and engaging in sexual intercourse. Counsel also neglected to inform you that many girls did 
affirmatively tell Epstein their true ages and he told several that he "did not care about age." 
Epstein's conduct was not "purely local." He and his assistants called and sent text messages 
to victims in Palm Beach County from other states to arrange "appointments" for his upcoming visits 
to Palm Beach. And, while in Palm Beach, Epstein and his assistants called victims in New York 
to arrange "appointments" for his return to New York. Epstein wired money to some victims and 
sent gifts through the mails. This case falls squarely within federal jurisdiction. 
Epstein also falsely claims that certain facts related to the resolution of the case were hidden 
and later discovered by his lawyers. For example, they complain about the proposed use of a 
guardian ad litem, stating that "Mr. Epstein's counsel later established that all but one of these 
individuals were adults, not minors." It was AUSA 
who told Epstein's counsel that all of 
the victims but one had already reached the age of majority, which was one reason why the guardian 
ad litem procedure proposed by Epstein's counsel would not work. Likewise, AUSA Villafafta 
disclosed to Epstein's counsel that one of the five attorney-representatives that she recommended 
for consideration by Epstein's counsel was a "good friend" of a "good friend." Despite the disclosure 
of this relationship, Epstein's counsel selected that person, before the SDFL, on its own, decided to 
use an independent Special Master to make the selection. 
Epstein's counsel states that the "USA() eventually asserted that it could not vouch for the 
veracity of any of the claims that these women might make," but neglects to disclose that the SDFL 
made that statement at Epstein's request to avoid the suggestion that the SDFL was involving itself 
in the outcome of civil litigation. 
Confidential and Privileged — Attorney Work Product 
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Case No. 08-80736-CV-MARRA 
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EFTA00230331

Epstein's counsel have repeatedly attacked the SDFL and the FBI for classifying the victims 
as "victims." As you know, all Justice Department employees have the obligation to identify victims 
and to notify them of their rights. "Victims" are defined by law, not by self-selection. The girls 
whom have been identified by the FBI and the SDFL fall within the legal definition — they were all 
minors who engaged in illicit sexual activity with Jeffrey Epstein, at his request, in exchange for 
money. From interviewing them, the FBI Special Agents, the FBI Victim-Witness Coordinator, and 
AUSA Villafafta all feel confident that they suffered harm, in a multitude of ways, by their 
interaction with Epstein. 
Finally, in contrast to Epstein's counsel allegation that my June 2, 2008 deadline was 
"arbitrary, unfair, and unprecedented," please consider that Mr. Lefkowitz has known since February 
that in the event that CEOS disagreed with his position, Epstein would be given one-week to comply 
with the Non-Prosecution Agreement. Subsequent to the receipt of CEOS Section Chief 
Oosterbahn's May 15,2008 letter, I notified Mr. Lefkowitz that Epstein would have a full two-weeks 
to comply with the Non-Prosecution Agreement as modified by the December 19"' letter to Ms. 
Sanchez. We believe it is finally time to shift the focus from Epstein's due process rights to treating 
him like all other similarly situated criminal defendants and perhaps, most importantly, to consider 
the rights of his victims. Continued delays adversely effect the case and the victims in the following 
ways: 
(I) 
at the time of the offenses, the victims ranged in age from 14 to 17 years old. The 
change in physical appearance of many of the victims since then has been dramatic. 
Epstein has been claiming that he did not know they were minors. Obviously, the 
older they look when the case is at issue, the harder it will be to overcome that 
defense; 
(2) 
it allows Epstein's lawyers to conduct depositions of the victims in the pending state 
criminal case and allows his private investigators to further harass and intimidate the 
victims; 
(3) 
more victims will seek the services of civil lawyers to file lawsuits thus allowing 
Epstein to make more powerful arguments demeaning the credibility of the victims; 
(4) 
the prosecutors and agents may retire, transfer and/or leave the Department for other 
opportunities thus affecting the potential outcome and prosecutorial resources. 
Additionally, several of the victims have relocated thus increasing the likelihood that 
crucial witnesses will be lost; 
(5) 
the SDFL has afforded more consideration to Epstein's arguments than any other 
defendant in my years of being the FAUSA and, before that, the Chief of the 
Criminal Division (January 1, 2004 to the present). I believe that we have been 
disproportionally fair to Epstein at the expense of other matters; and 
(6) 
prolonged delay may adversely affect the statute of limitations for some of the 
victims. 
Confidential and Privileged — Attorney Work Product 
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Case No. 08-80736-CV-MARRA 
P-013427 
EFTA00230332

On behalf of the SDFL and the victims in this case, please expedite the review and decision 
of the issues under consideration. 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
Ends. 
By: 
Jeffrey H. Sloman 
First Assistant United States Attorney 
cc: 
Chief 
Cr* ' I Division 
A. 
Assistant U.S. Attorney 
Assistant U.S. Attorney 
Confidential and Privileged - Attorney Work Product 
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Case No. 08-80736-CV-MARRA 
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CONFIDENTIAL PLEA NEGOTIATIONS 
TERMS OF EPSTEIN NON-PROSECUTION AGREEMENT 
■ 
Epstein pleads guilty (not nolo contendere) to an Information filed by the 
Palm Beach County State Attorney's Office charging him with: 
(a) 
lewd and lascivious battery on a child, in violation of Fl. Stat. 
800.04(4); 
(b) 
solicitation of minors to engage in prostitution, in violation of Fl. 
Stat. 796.03; and 
(c) 
engaging in sexual activity with minors at least sixteen years of age, 
in violation of Fl. Stat. 794.05. 
■ 
Epstein and the State Attorney's Office make a joint, binding 
recommendation that Epstein serve at least two years in prison, without any 
opportunity for withholding adjudication or sentencing; and without 
probation or community control in lieu of imprisonment. 
■ 
Epstein agrees to waive all challenges to the information filed by the State 
and the right to appeal. 
■ 
Epstein agrees that, if any of the victims identified in the federal 
investigation file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest 
the jurisdiction of the U.S. District Court for the Southern District of 
Florida over his person and the subject matter. Epstein will not contest that 
the identified victims are persons who, while minors, were victims of 
violations of Title 18, United States Code, Sections(s) 2422 and/or 2423. 
■ 
After Epstein enters his state court plea and is sentenced, the FBI and the 
U.S. Attorney's Office will close their investigations. 
Case No. 08-80736-CV-MARRA 
P-013429 
EFTA00230334

FOWL E RWHITE 
Caw 
BURNETT
'
MAIN • FORT LAUDERDALE • WEST PALM BEACH • St PETERSBURG 
August 2, 2007 
Mr. 
Chief, Criminal Division 
United States Attorney's Office 
Southern District of Florida 
99 NE 4 Street 
Miami, Florida 33132 
Re: Jeffrey Epstein 
Dear Matt: 
ESPIRITO SANTO PLAZA 
FOURTEENTH FLOOR 
I 395 BRCKELL AVENUE 
Mum. FLORIO* 33131 
TELEPHONE (305) 7699200 
FACSIMILE 1305) 7899201 
MIVW.FOWLERVINITE.COM 
DIRECT MMONE No.: (305) 7609279 
DIRECT FAcsomit NO.:1305) 728.7579 
tamcmez@rowt.en-vaure.com 
As we discussed at Tuesday's meeting, and consistent with our view that no 
federal prosecution should lie in this matter, Mr. Epstein is prepared to resolve this 
matter via a state forum. We are in receipt of your memo regarding same and as the 
dynamics of the meeting did not allow for us to fully detail our proposal, we do so 
now. We believe that our respective positions are not very far apart and that a 
mutually agreeable resolution can be reached that will accomplish the interests of the 
United States Attorney's Office as well as those of the community. 
We welcomed your recognition that a state prison sentence is neither 
appropriate for, nor acceptable to, Mr. Epstein, as the dangers of the state prison 
system pose risks that are clearly untenable. We acknowledge that your suggestion 
of a plea to two federal misdemeanors was an attempt to resolve this dilemma. Our 
proposal is significantly punitive, and if implemented, would, we believe, leave little 
doubt that the federal interest was demonstrably vindicated. 
The Florida state judicial system, unlike the federal system, provides for 
numerous types of onerous sanctions after a defendant is remanded to the custody of 
the state. The sentence is tailored to the needs of the local community and the risk 
posed by a specific defendant. After a great deal of thought, our proposal consists 
of both a severe supervised custody, with an assurance that any violation would result 
in the immediate implementation of the two year period of incarceration. We must 
keep in mind that Jeffrey Epstein is a 54-year old man who has never been arrested 
before. He has lived an otherwise exemplary life, characterized by both many 
charitable contributions and philanthropic acts. His reputation has suffered 
significantly as a result of his poor judgment in these matters. He is well aware of the 
ramifications of his past behavior and, accordingly, there is no concern, whatsoever, 
that he will re-offend. 
castRIREMbifttinfAittRA 
P-013430 
EFTA00230335

Page 2 
The following proposal is offered as an assurance to the community that the 
goals of appropriate punishment and rehabilitation are attained. 
We will agree to a sentence of two years in state prison pursuant to Florida 
Statute 948.012(2) which permits a split sentence whereby Mr. Epstein will be 
sentenced to a term of supervised custody, followed by a period of incarceration. 
Supervised custody in the state system includes potential daily surveillance, 
administered by officers with restricted case loads. Supervised custody is an 
individualized program in which the freedom of Mr. Epstein is limited to the 
confines of his residence with specific sanctions imposed and enforced. See Florida 
Statute 948.001(2). Should Mr. Epstein successfully complete the terms and 
conditions of his custody, the Judge will eliminate the incarcerative portion of the 
sentence. If Mr. Epstein, however, fails to comply with the conditions of his 
supervised custody. The period of incarceration will be immediately implemented. 
We, therefore, propose the following: 
Two years supervised custody with the following mandatory and special 
conditions: 
o Confinement to home 
o Report to a community control officer at least once a week or more 
often as directed by the officer 
o Permit a community control officer to visit him unannounced at home 
at any time, day or night 
o Obtain psychological counseling 
o No unsupervised contact with all the victims in the instant case 
o Perform community service 
o Payment of Restitution 
o Application of 18 U.S.C. § 2255' 
o Payment of a contribution of a defined amount to a charitable 
• 
organization benefitting victims of sexual assault 
o Payment of Court and probationary costs 
o Payment of law enforcement investigative costs 
o Submit to random drug testing 
o Refrain from associating with persons engaged in criminal activities 
o Refrain from committing any new law offenses 
o Any other specific conditions that the Office may deem necessary 
Two additional years of reporting probation: 
18 U.S.C. 2255 provides that any minor who suffers injury as a result of the commission of certain offenses 
shall recover actual damages and the cost of any suit. It is important to note that Mr. Epstein is prepared to fully 
fund the identified group of victims which arc the focus of the Office - that is, the 12 individuals noted at the 
meeting on July 31, 2007. This would allow the victims to be able to promptly put this behind them and go 
forward with their lives. If given the opportunity to opine as to the appropriateness of Mr. Epstein's proposal, 
in my extensive experience in these types of cases, the victims prefer a quick resolution with compensation for 
damages and will always support any disposition that eliminates the need for trial. 
CasgWagtei3V-VflivrAtiRRA 
P-013431 
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Page 3 
o Mandatory conditions as provided in Florida Statute § 948.03 
o Special conditions as stated above 
If the terms of supervised custody and probation are successfully completed, 
then the two years of state prison is eliminated. 
This proposal provides for the two year imposition of the state prison sentence 
if any violation of the supervised custody or probation occurs. Accordingly, the 
Office's position that Mr. Epstein agree to a resolution that includes jail time is 
satisfied by this proposal. It would immediately bring closure to a matter that has 
been pending for over two years, allows Mr. Epstein to commence with his sentence, 
and, most significantly, allow the victims to move forward with their lives. We are 
in process of scheduling a meeting with R. Alexander Acosta, United States 
Attorney, to further discuss this matter. 
Sincerely, 
cc. 
R. Alexander Acosta 
Gerald Lefcourt 
Roy Black 
caltikingi-MittiVVIARRA 
P413432 
EFTA00230337

Page I of I 
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October 9, 2007 -- LAWYERS for Jeffrey Epstein - the billionaire Manhattan 
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 
slammer - 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. 
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are trademarks of NYP Holdings. Inc. 
Copyright 2008 NYP Holdings. Inc. Al rights reserved. 
Case No. 08-80736-CV-MARRA 
P-013433 
http://www.nypost.com/php/pfriendly/print.php?url=http://www.nypost.com/seven/1009200... 6/3/2008 
EFTA00230338

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: 
(I) 
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 I8, United States 
Code, Section 2422(b); all in violation of Title 18, United States Code, Section 
371; 
(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(f), with minor females, in violation of Title 18, 
United States Code, Section 2423(b); all in violation of Title IS, United States 
Code, Section 2423(e); 
(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 18, United States Code, Sections 2422(6) and 2; 
(4) 
traveling in interstate commerce for the purpose of engaging in illicit sexual 
conduct, as defused in 18 U.S.C. § 2423(t), with minor females; in violation 
Page I of 7 
Case No. 08-80736-CV-MARRA 
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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(cX I); in violation of Title 
18, United States Code, Sections 1591(a)(I) 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 fora 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 I 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. 
Pagc 2 of 7 
Case No. 08-80736-CV-MARRA 
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EFTA00230340

Terms of the Agreement: 
I. 
Epstein shall plead guilty (not nob contendere) to the Indictment as 
currently pending against him in the 15th Judicial Circuit in and for 
Palm Beach County (Case No. 2006-cf-009495AJOCCMB) charging 
one (I) count of solicitation of prostitution, in violation of Fl. 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) 
(b) 
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 
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 1 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), supra. 
6. 
Epstein shall provide to the U.S. Attorney's Office copies of all 
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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 are 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. 
11. 
Epstein shall use his best efforts to enter his guilty plea and be 
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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 mammy 
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 ' 
•
against any potential co-conspirators of Epstein, including but not limited 
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 surrrscful completion of the terms of this agreement, all 
outstanding grand jury subpoenas shall be deemed withdrawn. 
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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 / 
//I 
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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: 
Dated:  77a9 
Dated: 
Dated: 
A. 
ASSISTANT U.S. ATTORNEY 
GERALD LEFCOURT, ESQ. 
COUNSEL TO JEFFREY EPSTEIN 
 
ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
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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: 
Dated:  
IL‘ti 0 7 
Dated: 
xi 
ASSISTANT U.S. ATTORNEY 
JEFFREY EPSTEIN 
RA 
CO 
ESQ.
WCI
"
UNSEL TO JEFF .Y EPSTEIN 
 
 ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
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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 than. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated: 
 
By: 
Dated: 
Dated: 
Dated: -LAY -L02—
Asealigi
lLiEy 
JEFFREY EPSTEIN 
GERALD LEFCOURT, ESQ. 
COUNSEL TO JEFFREY EPSTEIN 
LILLY 
ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
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