EFTA00230786

MARTIN a WEINBERG, P.C. 
ATTORNEY AT TAW 
10 PARK PLAZA, SUITE IMO 
BOSTON, MASSACHUSETTS 02116 
FAX 
NIGHT EMERGENCY: 
Assistant United States Attorney 
United States Attorney's Office 
Southern District of Florida 
500 S. Australian Ave. 
West Palm Beach, Florida 33401 
Re: 
Jeffrey Epstein 
Dear Ms. 
July 22, 2011 
EMAIL ADDRESSES: 
MIN 
Roy Black forwarded to me your letter to him dated July 21, 2011, from the District 
Attorney of the County of New York. We thank you for providing notice of the intended 
disclosure but we do object to any disclosure of the Non-Prosecution Agreement and the related 
list of witness/victims on the basis of the confidentiality provisions of paragraph 13. Absent an 
enforceable subpoena - which we would have the right to move to quash in the Court from which 
it was issued - there exists no right or duty to disclose the confidential Non-Prosecution 
Agreement or the non-public witness/victim list which was referenced in paragraph 7 of the 
NPA. Further, given that the witness/victim list was compiled based on the federal grand jury 
investigation, we object under Fed. R. Crim. P. 6(e) to its disclosure absent an appropriate court 
order. 
Very truly yours, 
Martin G. Weinberg 
cc: Roy Black 
EFTA00231426

07/22/2011 15:55 
3053562006
BSKS 
PAGE 02 
MARTIN G. WEINBERG. P.C. 
ATTORNEY AT LAW 
nitorEnAz4surreimo 
EMAIL ADDRESSES: 
sortm. mAsuaniszny nsrn 
tAx 
MOW EVERGEACY: 
AssistarRl.:iiit 
States Attorney 
United States Attorney's Office 
Southern District of Flo • 
500 S. Australian Ave. 
West Palm Beach, Florida 33401 
Re: 
Jeffrey Epstein 
Dear Ms. 
July 22, 2011 
Roy Black forwarded to me your letter to him dated July 21, 2011, from the District 
Attorney of the County of New York. We thank you for providing notice of the intended 
disclosure but we do object to any disclosure of the Non-Prosecution Agreement and the related 
list of witness/ victims on the basis of the confidentiality provisions of paragraph 13. Absent an 
enforceable subpoena - which we would have the right to move to quash in the Court from which 
it was issued - there exists no right or duty to disclose the confidential Non-Prosecution 
Agreement or the non-public wiMessivietim list which was referenced in paragraph 7 of the 
NPA. Further, given that the witness/victim list was compiled based on the federal grand jury 
investigation, we object under Fed. R. Crim. P. 6(e) to its disclosure absent an appropriate court 
order. 
Very truly yours, 
/ m dc 
k
2
Martin G. Weinberg 
cc: Roy Black 
EFTA00231427

07/22/2011 15:55 
3053582006 
BSKS 
PAGE 01 
BLACK 
SPEBNICK 
KOPNSPAN 
STUMPF 
TRIAL ATT0RNEYS 
Email: 
Roy Black 
Howard M. Srebn'ck 
Scott A. Kornspan 
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Jackie Perczek 
Mark A.J. Shapiro 
Jared Lopez 
Marcos Reaton, Jr. 
Jessica Fonseca-Nader 
Kathleen P. Philips 
Jenifer J. Souliklas 
Noah Fox 
Joshua Shore 
FACSIMILE TRANSMITTAL SHEET 
FAX: (305) 358-2006 TELEPHONE: (305) 371-6421 
TO: 
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RE: 
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, N.v. -DAZ 
DATE: 
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MESSAGE: 
SIF YOU DO NOT RECEIVE ALL PAGES, PLEASE CALL (305) 371.6421e 
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EFTA00231428

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 S. Australian Ave, Ste 400 
West Palm Beach, FL 33401 
Facsimile: 
July 27, 2011 
DELIVERY BY FACSIMILE 
Martin G. Weinberg, Esq. 
20 Park Plaza, Suite 1000 
Boston, MA 02116 
Re: 
IttfiraMin 
Dear Mr. Weinberg: 
Thank you for your letter of July 22, 2011. In order to review and address the objections that 
you raised in that letter, the Office deferred making its planned disclosure to the District Attorney 
of the County of New York of the Non-Prosecution Agreement ("Agreement") and the list of 
identified victims that was provided to Mr. Epstein pursuant to the Agreement. Nonetheless, after 
completing a full review of your objections, the Office still intends to proceed with the planned 
disclosures. 
The Agreement requires the Office only to provide Mr. Epstein with notice prior to a 
disclosure of the Agreement "[i]f the United States receives a Freedom of Information Act request 
or any compulsory process"; the Agreement does not require Mr. Epstein's concurrence in any 
disclosure. Contrary to your suggestion, the Agreement (including paragraph 13) also does not make 
the Agreement itself "confidential." On the contrary, the Agreement expressly contemplates that 
disclosures of the Agreement may be made, and the Agreement further contemplates, contrary to 
your suggestion, that such disclosures of the Agreement may be made other than in response to 
"compulsory process." Here, moreover, the District Attorney of the County of New York, as a local 
law enforcement agency, has provided a legitimate request for disclosure of the requested 
information, as well as a promise to maintain the confidentiality of the information, particularly the 
names of the minor victims. 
/ our objection pursuant to Federal Rule of CninmaiProcedure 6(e) also does not impact the 
planned disclosures. The victim list itself is not grand jury material, and, thus, disclosure of that list 
to the District Attorney's Office will not violate Rule 6(e). 
If you wish to supply any additional authority (other than citation to Rule 6(e) and to 
paragraph 13 of the Agreement) for your claims that the Office cannot disclose the Agreement and 
EFTA00231429

MARTIN WEINBERG, ESQ. 
JULY 27, 2011 
PAGE 2 OF 2 
the victim list to the District Attorney of the County of New York, we would be willing to consider 
those authorities before making any disclosure, provided that any such authorities are furnished to 
us before 5:00 p.m. on July 29, 2011. Otherwise, seeing no obstacle to the previously-planned 
disclosures, the Office will be disclosing copies of both the Non-Prosecution Agreement and the list 
of identified victims that was provided to Mr. Epstein to the District Attorney of the County of New 
York at 5:00 p.m. on July 29, 2011. 
Sincerely, 
Wifredo A. Ferrer 
By: IIII. 
cc: 
Deborah L. Morse, Assistant District Attorney, County of New York 
Roy Black, Esq. 
EFTA00231430

United States Attorney's Office 
Southern District of Florida 
500 S. Australian Ave., 
West Palm Beach, FL 33401-6235 
DATE: 7/Z7/2
01/ 
TO: 
ititiVrim lAkiiva:XO 
ORGANIZATION: 
FAX #: 
SUBJECT: jerr" 
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FROM: 
(Fax) 
NUMBER OF PAGES, INCLUDING THIS PAGE:  3
COMMENTS: 
Original document: 
To follow via Federal Express 
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EFTA00231431

Fax Send Report 
Date/Time 
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No. Name/Number 
246 
: JUL-27-2011 03:01PM WED 
: phaser 3300PFP 
StartTime 
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Southern Ulsiriet of Florida 
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EFTA00231432

United States Attorney's Office 
Southern District of Florida 
500 S. Australian Ave., 
West Palm Beach, FL 33401-6235 
DATE: —7/2-7/Zip 
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EFTA00231433

Fax Send Report 
Date/Time 
: JUL-27-2011 03:03PM WED 
Fax Number 
Fax Name 
Model Name 
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NO. Name/Number 
startTime 
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07-27 03:01PM 00'57 ECM 
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EFTA00231434

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 S. Australian Ave, Ste 400 
West Palm Beach, FL 33401 
Facsimile: 
July 21, 2011 
DELIVERY BY ELECTRONIC MAIL 
Roy Black, Esq. 
Black Srebnick Kornspan & Stumpf P.A. 
201 S. Biscayne Blvd, Suite 1300 
Miami, FL 33131 
Re: 
,Jeffrey Epstein 
Dear Mr. Black: 
On July 17, 2011, the Office received a written request from the District Attorney of the 
County of New York for a copy of the signed Non-Prosecution Agreement and the list of identified 
victims that was provided to Mr. Epstein pursuant to the Non-Prosecution Agreement. Pursuant to 
the District Attorney's request, the U.S. Attorney's Office intends to disclose these items to Deborah 
L. Morse, Assistant District Attorney, at 5:00 p.m. on Friday, July 22, 2011. Pursuant to the terms 
of the Non-Prosecution Agreement, the Office is hereby giving you notice of this intended 
disclosure. 
By: 
Sincerely, 
Wifredo A. Ferrer 
United States Attorn 
ss►stant m 
tates ttorney 
cc: 
Deborah L. Morse, Assistant District Attorney, County of New York 
EFTA00231435

United States Attorney's Office 
Southern District of Florida 
500 S. Australian Ave., 
West Palm Beach, FL 33401-6235 
DATE: 7/21/2..0 r I 
TO: 
)1OLindri moyse 
ORGANIZATION: bi.hr/Ci - A 
FAX #: 
SUBJECT: 
FROM: 
(Fax) 
NUMBER OF PAGES. INCLUDING THIS PAGE:  2 -
COMMENTS: 
Original document: 
 
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X 
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EFTA00231436

Fax Send Report 
Date/Time 
: JUL-21-2011 02:08PM THU 
Fax Number 
Fax Name 
Model Name 
: Phaser 33001,  SP 
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StartTime 
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Result 
211 
07-21 02:07PM 00'25 ECM 
002/002 O.K 
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United Stales Attorney's Office 
Southern District Of Florida 
500 S. Australian Ave., 
West Palm Reach, VIL 33401-6235 
DATE. 7 /21/loll
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EFTA00231437

2123359288 
Fax: 
Jul 17 2011 10:15ps P001/002 
DISTRICT ATTORNEY 
CYRUS R. VANCE, JR. 
otrucT Arrow/v. 
Date: 
To: 
Fax: 
From: 
OF THE 
COUNTY OF NEW YORK 
ONE HOGAN PLACE 
New York, N. Y. 10013 
APPEALS BUREAU 
FAX DOCUMENT COVERSHEET 
FAX # 
Vi-dy /7_Zoft 
4-45,4 
Tel #: 
.335-
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# of Pages 2- 
(includes cover sheet) 
IlAre 444 
K 
URGENT 
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ROUTINE 
Deliver Immediately 
0 
Discuss with Appropriate Person(s) 
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As Requested 
Review and Comment 
K 
For Your Approval 
Take Necessary Action 
o 
For Your Information 
0 
Reply Via FAX 
K 
File 
Reply Via Messenger 
K 
Reply Directly 
K 
Progress Report 
o 
Investigate 
K 
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Other Action To Be Taken/Additional Comments: 
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EFTA00231438

2123359288 
Fax: 
DISTRICT ATTORNEY 
OF THE 
COUNTY OF NEW YORK 
ONE HOGAN PLACE 
Now York. N. Y. 10013 
CYRUS R. VANCE, JR. 
0MMUCT Arroromr 
, Esq. 
Assistant United States Attorney 
Office of the United States Attorney 
Southern District of Florida 
liaktralian 
Avenue 
West Palm Beach, Florida 334O1 
Dear Ms. 
Jul 17 2011 10:15Pa P002/002 
July 15, 2011 
As we have discussed, I am currently working on the appeal brought 
by defendant Jeffrey Epstein In which he challenges his risk-offender 
designation under New York State's Sexual Offender Registration Act. 
The non-prosecution agreement between defendant and your Office 
would be of assistance to us in fashioning our response on appeal. I would 
appreciate it if you would send us a copy of that agreement, including the list 
of victims. 
Please let me know If you need any further information in order to 
make this material available. I appreciate your assistance, and courtesy, in 
this matter. 
Yours truly, 
e 
Deborah L. Morse 
Assi 
nt District Attorney 
EFTA00231439

U.S. Department of Justice 
United Stales Attorney 
Southern District of Florida 
500 S Australian Ave, Ste 400 
West Palm Beach, FL 33401 
(56!) 820-8711 
Facsimile: 
July 21, 2011 
DELIVERY BY ELECTRONIC MAIL 
Roy Black, Esq. 
Black Srebnick Komspan & Stumpf P.A. 
201 S. Biscayne Blvd, Suite 1300 
Miami, FL 33131 
Re: 
Jeffrey Epstein 
Dear Mr. Black: 
On July 17, 2011, the Office received a written request from the District Attorney of the 
County of New York for a copy of the signed Non-Prosecution Agreement and the list of identified 
victims that was provided to Mr. Epstein pursuant to the Non-Prosecution Agreement. Pursuant to 
the District Attorney's request; the U.S. Attorney's Office intends to disclose these items to Deborah 
L. Morse, Assistant District Attorney, at 5:00 p.m. on Friday, July 22, 2011. Pursuant to the terms 
of the Non-Prosecution Agreement, the Office is hereby giving you notice of this intended 
disclosure. 
Sincerely, 
Wifredo A. Ferrer 
United States Attorne 
By: 
istant nit 
tates ttorney 
cc: 
Deborah L. Morse, Assistant District Attorney, County of New York 
EFTA00231440

DISTRICT ATTORNEY 
OF THE 
COUNTY OF NEW YORK 
ONE HOGAN PLACE 
New York, N. Y. 10013 
CYRUS R. VANCE, JR. 
OTRCT ATTORNEY 
May 6, 2011 
, Esq. 
Assistant United States Attorney 
Office of the United States Attorney 
Southern District of Florida 
500 S. Australian Avenue 
West Palm Beach, Florida 33401 
Dear Ms. 
As I explained during our telephone conversation last week, I am 
currently working on an appeal brought by defendant Jeffrey Epstein. 
Defendant Epstein challenges the designation that he was given under New 
York State's Sexual Offender Registration Act. 
The underlying sexual 
misconduct at issue was the subject of an investigation and/or prosecution 
by your Office, as well as the Florida State's Attorney Office in Palm Beach 
County. 
I know that you handled the matter on behalf of your office when the 
case was presented to the federal grand jury. Those grand jury proceedings 
would be of assistance to us in fashioning our response on appeal, and I 
would appreciate it if you would send us a transcript of those roceedings. If 
we furnish the minutes to the appellate court, we would do 
under seal for 
the purpose of an in camera review. 
Please let me know if you need any further information in order to 
make the materials available. I appreciate your assistance, and courtesy, in 
this matter. 
Yours truly, 
Deborah L. Morse 
Assistant District Attorney 
EFTA00231441

DISTRICT ATTORNEY 
OF THE 
COUNTY OF NEW YORK 
ONE HOGAN PLACE 
Now York, N. Y. 10013 
CYRUS R. VANCE, JR. 
DISTRICT AITCRMEY 
August 15, 2011 
, Esq. 
Assistant United States Attorney 
Office of the United States Attorney 
Southern District of Florida 
500 S. Australian Avenue 
West Palm Beach, Florida 33401 
Dear Ms. 
Pursuant to our conversation, I have enclosed copies of the brief and 
appendix filed by defendant Jeffrey Epstein on appeal, as well as a copy of 
our brief in response. 
I look forward to hearing your opinion. 
Yours truly, 
ti 6t 1 
of Lc.) 
Deborah L. Morse 
Assistant District Attorney 
EFTA00231442

New York County Clerk's Index No. 30129/2010 
'sin 'Dark $ig:matte &curt 
APPELLATE DIVISION-FIRST DEPARTMENT 
PEOPLE OF THE STATE OF NEW YORK, 
Respondent, 
—against—
JEFFREY E. EPsTEIN, 
Defendant-Appellant. 
APPENDIX 
CYRUS R. VANCE, JR. 
NEW YORK COUNTY DISTRICT 
ATTORNEY'S OFFICE 
One Hogan Place 
New Yor New York 10013 
Attorneys for Respondent 
JAY P. LEFKOWITZ 
SANDRA LYNN MUSUMECI 
KIR1CLAND & ELLIS LLP 
601 Lexington Avenue 
New York, New York 10022 
Attorneys for Defendant-Appellant 
REPRODUCED ON RECYCLED PAPER 
EFTA00231443

TABLE OF CONTENTS 
PAGE 
Appellant's Pre-Argument Statement, dated February 9, 2011 
Al 
Appellant's Notice of Appeal, dated February 9, 2011 
A3 
Order Appealed From, dated January 18, 2011 with Notice of Entry 
A4 
Palm Beach Police Department - Probable Cause Affidavit of 
Det. 
- Defendant 
dated May 1, 2006 
A6 
Palm Beach Sheriffs Office Booking Card for Jeffrey Epstein, 
dated July 23, 2006 
 A28 
2006 Grand Jury Indictment of Felony Solicitation of Prostitution -
Jeffrey E. Epstein 
 A29 
Information for Procuring Person under 18 for Prostitution -
Jeffrey E. Epstein, dated June 26, 2008  
 A31 
Guilty Plea for Felony Solicitation of Prostitution and Procuring 
Person under 18 for Prostitution - Jeffrey E. Epstein, 
dated June 30, 2008 
 A32 
Judgment for Procuring Person under 18 for Prostitution -
Jeffrey E. Epstein, dated June 30, 2008  
 A33 
Sentence for Procuring Person under 18 for Prostitution -
Jeffrey E. Epstein, dated June 30, 2008  
 A34 
Community Control Standard Conditions, dated June 30, 2008 
 A35 
Palm Beach Sheriffs Offiee-Beeking-Gard-for-Jeffrey--Epstein
dated June 30, 2008 
 A47 
EFTA00231444

ii 
PAGE 
Order Granting Jeffrey E. Epstein's Motion for Travel, 
dated December 18, 2009  
 A48 
Letter from Florida Department of Corrections Regarding Termination 
of Supervision, dated July 21, 2010 
 A49 
Letter from Palm Beach Sheriff's Office Regarding 
Jeffrey Epstein's Participation in the Work Release Program, 
dated August 12, 2010  
 A50 
Letter from Jack A. Goldberger to NYS Sex Offender Registry 
Regarding Florida Registration Level applicable to 
Jeffrey E. Epstein, dated August 12, 2010 
 A51 
Letter from Martin G. Weinberg to NYS Board of Examiners of 
Sex Offenders Regarding Level and Designation Determination 
for Jeffrey Epstein, dated August 16, 2010  
 A53 
Letter from Stephen R. Alexander, Psy.D. to Jack Goldberger 
Regarding Opinion of Jeffrey E. Epstein, dated August 16, 2010 
 A58 
Recommendation of Board of Examiners of Sex Offenders, Including 
Risk Assessment Instrument, dated August 19, 2010 and Case 
Summary, dated August 23, 2010 
 A62 
Letter from Supreme Court attaching Notification, Recommendation 
and Notice of Right to Appeal, dated August 26, 2010  
 A67 
Letter from Supreme Court to Jeffrey E. Epstein informing of SORA 
Level Determination Hearing, dated August 26, 2010  
 A68 
Order Sheet for Jeffrey Epstein, dated August 26, 2010 
 A69 
Letter from Supreme Court to Counsel Informing of 
SORA Level Determination Hearing (with attachment), 
dated August 26, 2010  
 A71 
EFTA00231445