EFTA00312746

KIRKLAND & ELLIS LLP 
MDMMATIDMATMASMM 
Jay P. Lalkowitz, P.C. 
To 
cay: 
MEM. 
~mundane.= 
October 28, 2010 
By E-mail and By Hand 
CONFIDENTIAL 
Jennifer Gaffney, Esq. 
Deputy Bureau Chief, Sex Crimes Unit 
New York District Attorneys Office 
One Hogan Place 
New York, NY 10013 
Patrick Egan, Esq. 
Assistant District Attorney, Sex Crimes Unit / Trial Bureau 40 
New York District Attorneys Office 
One Hogan Place 
New York, NY 10013 
Re: 
SORA Determination for Jeffrey E. Epstein, NYS1D # OS1909, 
Supreme Court Case # 30129-2010 
Dear ADA Gaffney and ADA Egan: 
As you know, we represent Jeffrey E. Epstein, who is scheduled to appear in New York 
Supreme Court, Part 66, on Tuesday, November 9, 2010 for a hearing before the Honorable Ruth 
Pickholz pursuant to New York's Sex Offender Registration Act (SORA), N.Y. Correction Law 
§ 168 et seq. (McKinney 2008). 
To follow up on our conversation in your office on October 13, and as you have 
requested, we are providing you with a select sampling of materials that we believe expose the 
stark contrast between the inflammatory, speculative case summary presented by the Board of 
Examiners in its recommendation for Mr. Epstein, and the actual evidence that exists concerning 
the alleged conduct for which New York seeks to require Mr. Epstein to register under SORA. 
We believe that these materials validate our position that Mr. Epstein should most appropriately 
be designated as a Level 1 offender. Not only is the Board's Level 3 recommendation absurd, 
given that the offense triggering the registration requirement would most likely have been a non-
registerable misdemeanor if committed in New York instead of Florida, but as laid bare by the 
attached sampling of transcript excerpts and other evidence, the Board's purported calculation is 
also unsupportable under the applicable "clear and convincing evidence" standard. 
Chicago 
Hong Kong 
London 
Los Angeles 
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Palo Alto 
San Francisco 
Shanghai 
Washington. D.C. 
EFTA00312746

KIRKLAND & ELLIS LLP 
Jennifer Gaffney, Esq. and Patrick Egan, Esq. 
October 28, 2010 
Page 2 
First, as we attempted to explain during our meeting with you, the specific conduct which 
formed the basis of Mr. Epstein's conviction requiring registration under Florida law -- a 
conviction for Procuring a Person Under 18 for Prostitution, in violation of Fla. Stat. § 796.03' --
was a consensual arrangement in whic
 . Epstein received massages and engaged in sexual 
touching in exchange for money withM., a young woman who was over New York's age of 
consent when the offense cited in 
e 
forma
abundantly 
clear b the attache excer
from 
.'s 
was certaml 
by the time events "escalated" from massages 
to sexual conduct: 
• Exhibit 
Tr. 2:5-1 
. scat' 
, which 
would have made h 
when she was 
interviewed by D et. 
). 
• 
Exhibit A, 
Tr. 3:15-20 11. stating that she first heard about Epstein from a friend 
"about a year ago"). 
• 
Exhibit A, 
Tr. 5:14-23 S. 
stating that after meeting Epstein for the first time, 
she "didn't go again for about two months or so"). 
• 
Exhibit A, 
Tr. 6:13-22 5.
 telling 
that she saw Epstein approximately 
15 times in total, and "things escalated" as time went on). 
Furthermore, the record is undisputed that.. was at leash and over New York's age of 
consent during the one time that she engaged in consensual sexual intercourse with Mr. Epstein: 
• Exhibit A 
'Jr. 8:17-9:23 
. star 
). 
• 
Exhi it A 
r. 
• 
-17 
ti 
t a all of her conduct with Epstein.' 
).2 
i 
As previously noted, Jeffrey Epstein concurrently pleaded guilty to an indictment charging him with one 
count of Felony Solicitation for Prostitution, Fla. Slat § 796.07(2Xf), (4Xc), which is not a registerable offense 
under Florida or New York law. See Ha. Stat. § 943.0435; N.Y. Correction Law § 168-a(2)(a). 
2 
Notably, in a Probable Cause Affidavit Si 
signed under oath and filed with th
 in order to 
obtain an arrest 
for Jeffrey Epstein, bet 
in discussing allegations involving M., omitted the 
material fact their:Clearly stated that her decision to engage in intercourse with Epstein was consensual. 
EFTA00312747

KIRKLAND & ELLIS LLP 
Jennifer Gaffney, Esq. and Patrick Egan, Esq. 
October 28, 2010 
Page 3 
• See also Exhibit B. 
Den. 418:14-419:5 
testi 'ng that 
told him. 
before their interview, 
w en 
. was 
ana near 
Moreover, contrary to a characterization in tl • 
• 
' Case Summary,. was 
clear in her testimony that she voluntaril 
in front of Epstein when she 
was well over 
and nearing he 
w 
Tr. 12:12-13:12 a. 
statin the last time that she saw Epstein --
hich, based on testimon cited above, was 
- was the week before 
• 
Exhibit A, 
, and further stating that the one time she was with 
the female friend was shortly before that, around October 2nd or 3rd). 
All of this conduct involving II. would have constituted, at most, a non-registerable 
misdemeanor if committed in New York instead of Florida. See N.Y. Penal Law § 230.04 
(McKinney 2004).4 Because it cannot be proven by "clear and convincing evidence (or indeed, 
by any credible evidence) that Mr. Epstein engaged in sexual conduct with 
specifically 
during the time that she was under 17, Mr. Epstein is not guilty of any registerable offense under 
New York law. See N.Y. Correction Law § 168-a(2)(a)(i). 
A brief look at the evidence concerning 
another woman who appears to play a 
significant role in the Board's recommendation, similarly demonstrates that Det. 
mischaracterized IN's claims to manufacture registerable conduct with respect to 
For 
example, 
could not provide firm or even approximate dates for her earliest interactions with 
Mr. Epstein: 
• 
Exhibit C,. 
Tr. 2:24-27 AI. stating 
r date of birth is 
which would have made her 
 when she was interviewed by Det. 
off). 
Again, the transcript oal's interview with Det 
reveals significant prejudicial Sc acies in 
Probable Cause Affidavit. For example, 
swore that 
. claimed that 
agar 
c 
ge to 
. Epstein pleaded guilty criminalizes the prostitution of a 
person who is under the age of 18 (i.e. 16 and 17 years old), see Fla. Stat. § 796.03, but under New York law, 
patronizing a prostitute is only a registerable offense where the prostitute is ander the age of 17, whether under 
2004 law or the broader scope of Penal Law § 230.04 in effect today. See Correction Law § 168-a(2)(a)(i) (stating 
that Patronizing a Prostitute in the Third Degree, N.Y. Penal Law § 230.04, is a registerable offense "where the 
person patronized is in fact less than seventeen years of age"). 
EFTA00312748

KIRKLAND & ELLIS LLP 
Jennifer Gaffney, Esq. and Patrick Egan, Esq. 
October 28, 2010 
Page 4 
• Exhibit C,11. Tr. 3:11-20 
estimating that her contact with Epstein lasted 
somewhere between a year and a half and two years). 
• 
Exhibit C,M Tr. 4:12-23 M. guessing about the timings.LheUrst meeting with 
Epstein and stating that she does not know whether she waMorill). 
• 
Exhibit 
Tr. 11:42-12:4 
1
.
.
 
saying that she cannot keep track of specifically 
when different events with Epstein took place). 
While.. could not say with certainty when she first met and massaged Mr. Epstein, 
stated definitively and unambiguously that she w 
• Exhibit C,Ill Tr. III:21-33 IE. saying that she was "definitely" 17 whe 
-but 
that she could not recall the specific date of when that took place). 
• 
See also Exhibit B, 
Dep. 407:4-411:9 
M. wasp or■ during 
date). 
In addition to establishing that.. was 17 during her interacts
 with Mr. Epsteiiiii 
therefore, Mr. Epstein's conduct toward her is not reportable), M.'s statements to 
further reveal that'll. viewed her interactions with Mr. Epstein{both sexual 
as well as her 
testifying that he understood that 
or which she could provide no specific 
• Exhibit C,. 
Tr. 15:1-21 (E. telling 
that Epstein would pay her money to 
spend time with him, relax by the pool, and eat meals, without any sexual activity, and 
• 
Exhibit C 
unless h 
Tr. 20:13.2 
et 
• Exhibit C, 
Tr. 19:13-23 
• 
F,xhibit C 
Tr. 20:35- 46 
EFTA00312749

KIRKLAND & ELLIS LLP 
Jennifer Gaffney, Esq. and Patrick Egan, Esq. 
October 28, 2010 
Page 5 
• 
Exhibit C, 
Tr. 13:28-41 ( 
statin that even after s eakin to olicc she "didn't 
• Exhibit C 
Tr. 27:12-27 ft 
The enclosed excerpts should make clear that fl
 -- inaccurately described in the Board's 
recommendation as the "16-year old victim" who went to Epstein's home "at least 100 times" --
was not, in fact, a victim of any reportable criminal conduct by Jeffrey Epstein, but rather, was 
an opportunistic young woman who, at 17 and 18 years of age, repeatedly made conscious 
decisions 
• Exhibit D, Palm Beach Police Report S 
for A. 
In short, 
was not a victim of Jeffrey Epstein, and accordingly, Mr. Epstein's conduct 
involving 
. should not factor into the SORA assessment at all. 
In fact, transcriptsigce interviews with numerous other women who are cited in the 
police reports and in the 
Probable Cause Affidavit reveal multiple other troubling 
inaccuracies and exaggerations in the police paperwork on which the Board apparently blindly 
relied in reaching its unsupportable Level 3 recommendation. The following are just a few 
examples of several such egregious misstatements and material omissions in the police 
paperwork: 
• 
Exhibit F, 
Tr. 11:25-12:21 
., who introduced Epstein to several women, 
telling police that Epstein liked girls who were "between the ages of like 18 and 20" -- a 
qualification that appears to have been deliberate)  omitted from 
statement in 
the Probable Cause Affidavit that Epstein told M., "The younger, the better"). 
EFTA00312750

KIRKLAND & ELLIS LLP 
Jennifer Gaffney, Esq. and Patrick Egan, Esq. 
October 28, 2010 
Page 6 
• 
Exhibit GIME Tr. 5:18-23, 11:6-22 (17-year-old woman stating to police that Epstein 
did not touch her inappropriately, did not try to touch her and did not masturbate while 
she gave him a massage, despite allegations in the 
Probable Cause Affidavit that 
Epst • 
• 
Exhibit II, 
Tr. 2:25-3:12, 18:7-20 (woman stating that she was 17 when she first 
met Epstein and telling police that Epstein never used any sex toys on her and touched 
her with his hands (as opposed to "something else'l. refuting a claim
Probable Cause Affidavit tha 
• 
Exhibit I, 
Tr. 12:6-12 Ian telling police that she was 17 when she first met 
Epstein, in contradiction to the IMIll Probable Cause Affidavit which states that this 
same woman was only 16 when she first met Epstein) 
• 
Exhibit J, 
Tr. 4:10-11, 11:4-7 (woman statin that her date of birth =NM 
MI, which would have made here years an' 
old during her sole contact with 
Epstein in 
and testifying that her interaction with Epstein was entirely 
consensual 
ite claim in the 
Probable Cause Affidavit that she had "just 
turn 
' and suggestion that she was coerced or tricked into interacting with 
Epstein). 
• Exhibit Ker. 
3:18-4:1, 5:6.15 (clarifying that woman wan 
years old 
during her sole encounter with Epsaid therefore, any sexual conduct with him 
described in the police report and 
Probable Cause Affidavit should not be scored 
under SORA and was not even criminal or reportable under the applicable Florida law). 
In fact, in a deposition, Det. 
himself acknowledged that there were certain other 
damning allegations contained in his police reports that he failed to correct, to the detriment of 
Mr. Epstein: 
• 
Exhibit B, 
Dep. 423:1.425:17 ( 
testifying that he knew that Epstein had 
purchased covert cameras near his desk on the first-floor of his Palm Beach home 
following a burgl 
to 2003, a fact that 
failed to mention in his police report 
when noting that MI 
"found" a covert camera located in that very location). 
• 
Exhibit 13, 
Dep. 458:8-460:18 AM. testifying that he knew that certain 
objects recovered from Epstein's garbage, which had been incorrectly identified as "anal 
EFTA00312751

KIRKLAND & ELLIS LLP 
Jennifer Gaffiiey, Esq. and Patrick Egan, Esq. 
October 28, 2010 
Page 7 
wands," were in fact broken eating utensils (not sex toys), and noting that he made no 
amendment in his police report to reflect that correction). 
also admitted in his deposition that the prosecutor handling the Epstein matter, whom 
acknowledged to be an experiencscimosecutor specializing in sex crimes cases 
involving children, expressed her view to ME 
that, "There are no real victims here." 
• 
Exhibit B, 
Dep. 484:2
3 a 
conceding that the Florida prosecutor 
handling the Epstein case told 
that there were no victims in this case). 
• 
Exhibit B, 
Dep. 506:18-507:21 .
 acknowledging that the Florida 
prosecutor handling the Epstein case had been with the State Attorney's office for 
approximately twenty years and specialized in sex crimes cases involving underage 
children). 
Indeed, the state prosecutor herself investigated and evaluated the allegations of the numerous 
women cited in Det. 
86-page police report and apparently discounted most of them, 
determining that the only charge for which he could be indicted was one count of Felony 
Solicitation for Prostitution, Fla. Stat. § 796.07 (which, as previously noted, is not a registerable 
offense under Florida law, see Fla. Stat. § 943.0435). No charge of rape or sexual contact with a 
minor was ever prosecuted in connection with any allegations made against Jeffrey Epstein, a 
fact that, in itself and by the terms of the SORA Guidelines, is compelling evidence that such 
offenses did not occur. See Sex Offender Registration Act: Risk Assessment Guidelines and 
Commentary, Commentary at 5,117 (2006). Accordingly, Jeffrey Epstein should not be scored 
for such alleged conduct that was squarely rejected by the prosecutor and/or grand jury. 
The evidence also makes abundantly clear that Jeffrey Epstein did not know that certain 
of the woman whom he hired to give him massages were underage, due in large part to the fact 
that these women lied outright and sought to deceive Mr. Epstein about their ages: 
• Exhibit F, 
Tr. 12:13-21 
. tellin 
olice that she lied to 
t 
• Exhibit J, 
Dep. 15:25-17:2 (woman testifying that she was told b 
that she 
had to be over 18 to massage Epstein, 
• Exhibit G, 
Tr. 5:5-8 (woman telling police that Epstein did not know her age). 
EFTA00312752

KIRKLAND & ELLIS LLP 
Jennifer Gaffney, Esq. and Patrick Egan, Esq. 
October 28, 2010 
Page 8 
• 
Exhibit L, 
Tr. 38:21-39:18 telling police that she told Epstein that she 
was 18 and in twelfth grade because 
told her that Epstein would not allow her in his 
house if she was under 18). 
• Exhibit M, 
Dep. 32:1119, 35:19-38:7 
testifying that she was told that 
Epstein would not allow her into his house if she was under 18, 
• Exhibit N,_Dep. 6:11-20, 7:24-8:8 (woman testifying that she was instructed to tell 
Epstein that she was 18 if she wanted to give him a massage for money 
• Exhibit O, 
Tr. 13:16-22 (woman telling police that Epstein never knew her age, 
but she was instructed to tell Epstein that she was 18 because women had to be a certain 
age to massage him). 
In fact, M, the sole 14-year-old cited in the Board's write-u h 
• 
Exhibit P, Ill's MySpace Page j rtraying 
to be age 18 ins 
when she 
• FxhibitM, 
Dep. 68:12-69:18
her MySpace page). 
• Exhibit M, 
Dep. 108:7-110:1 
• Exhibit M, 
Dep. 121:3-21 (a 
she was 14, before she ever met Epstein). 
This evidence represents just a small sampling of the materials generated during the lengthy 
investigation and prosecution of Jeffrey Epstein (as well as during the case's aftermath), but we 
believe it exposes the allegations cited in the Board's case summary as being unsubstantiated and 
utterly unreliable. The glaring discrepancies between the accounts of various women and the 
mischaracterization of their claims in the police paperwork, the lack of reliable evidence that 
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KIRKLAND & ELLIS LLP 
Jennifer Gaffney, Esq. and Patrick Egan, Esq. 
October 28, 2010 
Page 9 
certain women were underage at the time of their encounters with Mr. Epstein, and the 
questionable credibility and self-interest of many of the women cited all support the conclusion 
of the Palm Beach prosecutor that there were no victims here. Moreover, these facts cannot 
support by "clear and convincing evidence" the grossly inflated SORA risk assessment 
calculation offered by the Board. For all of the reasons set forth herein and in our letter of 
October 11, 2010, therefore, we ask you to reject the Board's recommendation outright and 
advocate for a more reasonable Level I designation, in line with what several other jurisdictions 
have already done. 
Finally, on a separate but related point, we note that upon further consideration and 
investigation, our current view is that Jeffrey Epstein should not be required to register in New 
York at all! Mr. Epstein maintains his primary residence in the U.S. Virgin Islands and does not 
actually live, work, or attend school in New York, the three measures which determine whether 
someone needs to register under SORA. See N.Y. Correction Law § 168-a(14), (15), § 168-k. 
Indeed, the New York State Department of Taxation has not recognized Mr. Epstein as a 
domiciliary of New York since 1992, despite the fact that he has maintained a vacation home in 
New York since that time: 
• 
Exhibit Q, State of New York Department of Taxation and Finance, 3/1/1996 
Statement of Personal Income Tax Audit Changes, at 1. 
Mr. Epstein has already registered as a sex offender in the jurisdiction of his residence -- the U.S. 
Virgin Islands. And the other states where he owns secondary residences -- Florida (the state of 
his offense) and New Mexico — have determined either that he should only be subject to that 
jurisdiction's lowest reporting obligations or that he is not required to register at all. Yet even 
in New Mexico, where he is not required to register, Mr. Epstein has chosen to maintain his 
registration, again, to ensure his compliance with federal law. Because it is our view that Jeffrey 
Epstein should not be required to register in New York at all, given the short temporary visits he 
makes to the state, should he be designated as anything other than a Level 1 offender, we would 
likely be compelled to challenge the initial determination of the Board concerning his obligation 
to register in New York in the first instance by filing an Article 78 proceeding. 
Thank you again for meeting with us two weeks ago and for giving us the opportunity to 
provide you with these materials. We hope that these excerpts and other documents have 
Of course, as we discussed in our meeting, Jeffrey Epstein intends to register in New York under SORA, 
whether required to or not, in order to ensure his compliance with the federal Sexual Offender Registration and 
Notification Act (SORNA), 42 U.S.C.A. § 16901 et seq., and indeed, he has voluntarily been registered with the 
N.Y.P.D.'s Sex Offender Monitoring Unit (SOMU) since May 20, 2010. 
EFTA00312754

KIRKLAND & ELLIS LLP 
Jennifer Gaffney, Esq. and Patrick Egan, Esq. 
October 28, 2010 
Page 10 
demonstrated to you that the Board's recommendation was based on an imprecise analysis of a 
flawed presentation of allegations. The evidence that we have presented reveals that the Board 
failed to scrutinize, or even consider individually, the allegations contained in the police reports, 
and as a consequence, the Board came up with a recommendation that deviates dramatically 
from the findings of the prosecutor who investigated and evaluated this case, as well as every 
other jurisdiction that has considered Mr. Epstein's registration obligations. For all of these 
reasons, we ask you to reject the unfounded recommendation of the Board of Examiners, which 
cannot be supported by clear and convincing evidence, and instead, defer to the discretion of the 
states that have a more direct nexus to Mr. Epstein and his offense by designating Mr. Epstein as 
a Level 1 under SORA. 
We are happy to meet again or schedule a call should you require additional information 
or wish to discuss this matter further. In any event, we look forward to speaking with you about 
this matter and your position on the SORA hearing in advance of our scheduled court date on 
November 9th. 
Sincerely, 
Jay P. Le t r  'tz, P.0 
Sandra Lynn Musumeci 
IPL/slm 
Attachments 
EFTA00312755

EXHIBIT A 
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Page 1 
In 8I: 
I bityrAPED 1 WE RV1Rit O1 
Sandy Rossi 
Notary Public:, state. of tic:tido 
Connor and Avow:latex 
Phone - 
J. Consor & Associates Reporting & Transcription 
561.682.0905 
choti4•00,2R-434•404-34012d 
EFTA00312757

ate 4 
5 
Q Okay. I forgot my stuff was already hem 
6 
Ashley, tight? 
7 
A Yes. 
8 
Q 
You have any identification with you? 
9 
A In my car. 
10 
Q In your cat? 
11 
A 
Yeah. 
12 
Q Okay. What's your middle name? 
13 
A 
14 
Q 
And your date of binh? 
15 
A 
Pogo 1 
15 
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16 tit ask you questions along the way. 
11 
A Okay. About a year ago -• 
18 
Q Uh•huh. 
19 
A 
a fritmd of mine told me about Jeffrey. Shc 
20 said 
like she was helping him find girls. 
14 
Q Okay. This all happened the first time you went 
I 5 or how many times have you gone/ 
16 
A 
I've been — I went the first time and then I 
17 didn't go again for shout two months or so. And then it was 
18 about once • month after that for a little while. But I 
19 haven't talked to them -- I don't know when I talked to than 
20 last actually. The act time I talked to the girl, one of 
21 the girls that stay at the house, they were out of town. I 
27 don't know what they were. And I haven't heard from them 
23 since. 
2 (Pages 2 to 5 
J. Consor & Associates Reporting & Transcription 
561.682.0905 
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EFTA00312758

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J. Consor & Associates Reporting & Transcription 
561.682.0905 
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J. Consor & Associates Reporting & Transcription 
561.682.0905 
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5 (Pages 14 to 17) 
J. Consor & Associates Reporting & Transcription 
561.682.0905 
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EFTA00312761

EXHIBIT B 
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Page 32C 
I 
IN THE. CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
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PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506. 
Electronically signed by Jeans Waded (601.280-428413/11) 
Eloctronkally algnad g Jeana RIcclutl (601-280-4264381J 
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EFTA00312763

Page 404 
Page 406 
Page 405 
Page 907 
4 
Q. La me sec 'flan find this for you. At the 
5 
bottom of page 10 of that affidavit, at September 11, 
6 
2005, WPAli, DOB,
was 
7 
Beach Police Department. Theo the 
8 
that we're talking about, correct? Ifs the very last 
9 
line. I'm only pointing out the date of birth. 
10 
A. Yes. 
11 
Q. So she was las of DecembeMM, 
12 
cared/ 
13 
A. What page was that, I'm sorry? 
14
Q. This is the bottom of le 10. 
15
A. Sbe would have been 
yes, if= 
16 
18 
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ou a dale on this one. 
17
A. 
Q. 
And when you interviewed Ms. lane Doc 
19 
Mon October 10th and October 11th, and she told you 
20 
about this one event where Were was marten 
21 
22 
23 
24 
25
Q. 
A. I can't recall if she did or she didn't. 
Italic gave you &date, it would be in the 
23 (Pages 404 to 407) 
(561) 
3 2 — 5 0 0 
PROSE COURT REPORTING AGENCY, INC. : 
(561) 832-7506 
Electronically signed by Jeans Ftleclud (601.260.428.9351) 
Electronkally signed by Jean. Ricclud(601-280-4211-9301) 
96092637.96•14$29498311-bcAS14•3144:174 
EFTA00312764

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Page 408 
1 
report —
2 
A. Yes, sir. 
3 
Q. — and if she didn't, either she didal 
remember a she wasn't asked; is that right? 
5 
MS. ARBOUR Form. . 
6 
THE WITNESS: No, !know that I would have 
7 
asked her. 
BY MR. WEINBERG: 
• 
Q. So if we doll have a date in the report as to 
how long before October 10 and 11, 2005 that single 
event occurred, then she didn't remember, is that right? 
MS. ARDOUR: Pone. 
THE WITNESS: Can you ask that question one 
more time? 
BY MR. WEINBERG: 
Q. Sure. If there's no date for that — 
A. Then she did not recall that specific date. 
Q. And therefore, since she was seeing 
Mr. Epstein, according to valet she told you, over some 
extensive period of time, it could have occurred while 
she was — befar 
or it could have 
occurred 
we just have no way of 
'mowing? 
A. It would have been before because one of the 
last times that she met with him was what she provided 
1 
2 
3 
4 
S 
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ubord 
• 
A. I'm trying to recall, because I do remember 
her stating that she was going less and less. Pm 
trying to recall, because I know she was going less and 
less to his residence. 
Q. Do you recal1writing in this 
table cause 
affidavit that events —that Jane Doe 
you 
that Ka relationship continued to escalate during the 
period she saw Mr. Epstein? 
A. Fri:intik beginning, yes. 
Q. And Ws fair to say that some subset of those 
couple of yew occurred after she turned 18, and a 
significant part of it was before she turned 18, 
correct? 
A. The s significant art I would sat — 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
35 
16 
12 
18 
19 
20 
21 
22. 
23 
24 
25 
Page 409 
Q. And when was that a high school transcript? 
The high school year ends in the spring? 
A. It would have been, yes. 
Q. And not in December? 
A. Correct 
. Q. And so if sheMIMEME 
that 
would have been in the middle of her senior year in high 
school? 
A. Correct. 
Q. And therefore, she continued to see 
Mr. Epstein after she was 18 and up to the period 
inunerlimPly before her graduation in the spring of 2005, 
correct? 
Let me date it another wa 
She was a 
freshman at college when 
A. Comet 
. Q. Therefore, she was a Senior in high school up • 
A. Correct. 
1 
of it when she was 18 
3 
4 
5 
6 
a 
9 
Pay•-• 
and par
Mil l!..was 
fore she was IS 
correct? 
A. I would assume so. 
24 (Pages 
408 to 911) 
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