EFTA00183407

r t EFTA00183407 RA. JOSEPH R.ATTERBURY JACK A. GOLDBERGER JASON S.WEISS - Road Ceo 'Hied Co ififinal lal Mot my / Member of New lersey R norm:. Bars July 21, 2008 AUSA U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 SENT A FA IMILE Re: Jeffrey Epstein Dear Ms. Enclosed please find a Motion For Return of Property that I filed in Mr. Epstein's state case. Out of abundance of caution, I am providing you a copy of the motion. Ple advise me as to what your position is on this matter. dberger G/na nclosure One Clearlake Centre, Suite 1400 250 Australian Avenue South West Palm Beach, FL 33401 • p 561.659.8300 f 561.835.8691 wwwagwpa.com EFTA00183408 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA STATE OF FLORIDA CASE NO.: 2006CF009454AXX DIVISON: "W" vs. JEFFREY EPSTEIN, Defendant. DEFENDANT'S MOTION FOR RETURN OF PROPERTY COMES NOW the Defendant, JEFFREY EPSTEIN, by and through his undersigned attorney, and moves this Honorable Court to enter an Order for return of property seized on October 20, 2005 during execution of a search warrant at the Defendant's residence. In support thereof the Defendant states as follows: 1. On October 20, 2005, the Palm Beach Police Department executed a search warrant at the Defendant's residence. During the execution of the warrant, numerous items of the Defendant's personal property were seized and impounded by the Palm Beach Police Department. A copy of the search warrant return is attached to this motion (Exhibit A). 2. On June 30, 2008, the criminal charges arising from the search warrant were resolved through a negotiated plea agreement. 3. No legal justification exists for the continued impoundment of the Defendant's personal property. The Defendant is entitled to the return of all personal property listed in Exhibit A. WHEREFORE, the Defendant, JEFFREY EPSTEIN, respectfully requests this Honorable Court to enter an Order for the return of his personal property. EFTA00183409 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Motion was sent via FAX and U.S. MAIL to Lanna Belohlavek, Esq., Assistant State Attorney, 401 North Dixie Highway, West Palm Beach, Florida 33401, this 2.\ a day of July, 2008. ATTERBURY, GOLDBERGER & WEISS, P.A. 250 ustralian Avenue South, Suite 1400 W Palm Beac Florida 33401 (56 65;-8300 J BERGER, ESQUIRE Flo Bar Number 262013 EFTA00183410 •.• PROPERTY y EVIDENCE I IDEN1743TATION NUMBER DATEITIME RECOVERED 0 3 '-M BEACH POLICE DEPARTMEN PROPERTY RECEIPT SEARCH WARRANT RETURN 0 DECEASED (Probated) 0 PERSONAL OWNER / VICTIM'S NAME 1 D.O.B. BPEOAL INSTRUCTIONS MA. QUANTITY VALUE I . 0 0 4- ' • • DETOT BUREAU • • 0 CONFISCATED 'O DEST9oY 0 STOLEN/RECOVERED . DINNER PROPERTY NUMBER Mee Bide ADDRESS ADDRESS 3515 Et. r;tzt/k.. . ADDRESS ABEECRIPTION Nelp BIN NUMBER BeavalBillic)10 PHONE NUMBER PHONE NUMBER EXHIBIT ft N o 5 FOUND PROPERTY. GLAIR 0 Nor aim 12j.1 :".7.14004fo.., i..i:Aily, • 4 ... •i•-•11S :4, .. nie isrikcticrAL:::',4647). • • 64t f-hyri.eick*40/2./7 cifrnie (ie. yr--4 :-•;-,r,-1,-.)::-2- • • ..A7l,e7:A.i;i; : ; : a -; i c 1(.:•• k ip -, ilitiOlA Ai" P .frfi;001 -'04. .41actr i@* 5/;.k . .• . . 1. . . . ; ' efri )7? 64 .. fle.in-7 . e,.. 4 ._ , . _e r I i a ... ? C‘i4.- ,-4 ')/ • a t,..;" ... ticf.i.j. 112 1-; . . • ' l afxrd-k4 S ,-. .-t - 4,--r--:;-L-4 - : ' i1671-:Winot -)i) riltt7 . • - . . • .i et) . . . . . Atli); . i t,;e2:: jog tre e . ,r'' e' l • ' f r.O? I1/44 . ..71 .. fr clin."'"' TOTAL PACKAGE WEIGHT • I hereby acknowledge that' theabove list represents ell properly taken from me and that I have received a copy of this receipt. sollysk BIGNATURE . . RECEIVED BY • abairaph Roc-arc the off; inventorrcontaihd a true. detail account of the authOrity.of thiswarrant I. hereby acknowledge that the above Est represents-all properly kyspoirded • . by me In the Shale' performance of my duly as o pollee coder. . . . . . 11.(S tY2' Sworn .to '.and .subscribed .bef this 2 j day of OP Ober -2Cia5* ' DATE/TIME RECEIVED. • • ed, do swear that• the above y taken• by me, under . Ric OILIM A &A by Whom this-warinnt the EFTA00183411 • ' a tat'. •"" • PO 152 I MA BEACH POLICE DEPARTMEI) /A€L•oZ OF • re.,, DETECTIVE BUREAU PROPERTY RECEIPT SEARCH WARRANT RETURN O PROPERTY O FOUND Q DECEASED (Probated) 0 PERSONAL 0 CONFISCATED O DESTROY 0 EVIDENCE. )21 TRIAL ' 0 IMI3ORATORY O STOLEN/RECOVERED ' C I OTHER 6 INCIDENT/CITATION tilt/BREA . O 5. 3 6 Ø DATE/IIME RECOVERED . /0' ..../5 PROPERTY NUMBER (Laws Bath) . c 11,.? L I BIN NUMBER 'Caws mania ..."- ADDRESS WHERE PROPERTY IMPOUNDED S G7 6L - rill b • DISCOVEREUBY/D.D.B: ADDRESS • Steel CIry 4 0 PHONE NUMBER . OWNER / VICILIS NAME / Dp.B. .) • I . ADDRESS • Snot CIO' . ZIP . PHONE NUMBER ECTI.S.NAME/D -20—r 7 t ......., S 4rn in ADDRESS Sao! r, 3 9?) t . 131-2( E ao . .. O PHONE NUMBER AD RiaLle / .0/ 3ti • ) . 2p . . . • • - • • ...... PHONE NUMBER • • • • SPECIAL INSTRUCTIONS . . . v.,. • ' ' ..... . . . 1 7 ' U. : - 'FOUND PROPERTY . cialmO . . .. . NOT CLAIM O • mom. QUANTITY %wag . • . . : I. ISECRIPTION 2-4-. • if ti- '. .. - • • • .r - .. 1Z • , ...fr4 . . .. rt)- ill • . "In O,...0 • • Army/' :7; fig ea. .: ce, tiiwil ''. p• a ch.* . -,t„ „reel. :,/„.. .6:;-1 4 q.. • .1 -. • I' !'reel/ i)7e.:1 • . .h,.iiir f]; :•Ph de; ,i•:. 'I.pit:rya-A • 40047 - •... tel 1:,.e, P9AL . .  Is'''. 0 • • 54_, • 1)7#554:* i? %I -7210 A. • . .... /.4( fir ... roxel..?cr• • rti r. m. • ' ink. - ..-?:.(14idki,H.4i,liep ,. . ..........,V-ty';43 . eci ..:-.4 :%• . . . . • -.t:0•4. : fPriii i - m .:ri,-0.'" i A. . .• '... ...C.•' -- .:.-% - • .:-• • 4:1. • ••• ... • ..-0 0 • 42;tt;- . ./..lefk.:• 44•5'. • 1.: 1 4'. . .. • . . i .. • . yelE. . .. ?,/ gol. ....p . . • . .. • ., .-cAn;Piel• '''...eA:, 4:,..e. pi ;,..-, :4,-.,), • - ..,.??.. T...„...„,,A,..::#40..... a ......a. -t . ';crew,:.( W.; I; ..'*i-.,•;A .1,t'i ,tti : ...i n' . : ov r • :2•.• f . x: k..co4 .. ...'n'in"-; .t.: 76€:::...•-• (i4F. PP: •• (•.' i ; - '.`"•':' - - • . ...: • .. . " ... 7,iqi; .tbreattl i :. ;e1 -: ic.c.)n. .- a • • --,-tra ...A0Y.. ,-;, •-2,,, 7 w_ ..i, : ' ( /7, (i ty,//ip .:es,,,:,N., f--,,sivist...) • . / 4 cuitir .(b-4•:icict. . t f'4:::I re? -L itgl. 6. Y. °;:i: • }.d.° i:le:-.c. 7hi'i' ' : .. `TOTAL PACKAGE WEIGHT . • . • . . • •• : . ..• /2•LeildotinH• '. . Ihmegkiammatedg elhal thaabovo ail repamnisil property taken ' front me and•that I halrooelved a copy of this receipt ' • .• . . . •• • . • . .- • . I heuxibyaoknowledgo thol the above Rat repfeser;ell property bt.into him official performance of my duty as a police oil kik Oita Impounded loot. '. •I ... .. °1 SIGNATURE. . .. • .DATE' • • ' •SIGN • LIRE IIIF • RECEIVE/at/ DATE/I-NE RECEIVED :. ••••.: . • ..044MIPIP/14 .... • • ' . ' : . .. . .. ... • .. • . . . .. . . • - . . kr . . - . . . . . • •• • • % • • ,.. -.. . • ' .'. . ' ' .- • • . ,•.-. . . ..... . .. • • . • . nt EFTA00183412 $ .e • ...LM BEACH POLICE DEPARTMEI PA- O - 3 of 6 PRETWEgig DETECTIVE -BUREAU O Pii6PERTY• O FOUND O DECEASED (Probated) 0 -PERSONAL O CONFISCATED , CI DESTROY • )ill EVIDENCE ca TRIAL . a LABORATORY . O 6113LEN/REpOVERED O OTHER :( • CI Ei ' INCIDENT/CITATION NUMBER aH„,,,_.3.6g DATEMME RECOVERED /t)-076- o PROPERTY. NUMBER (Leave sleek) oS-ioati . BIN NUMBER (Leave Bland . ADD ERE PROPERTY IMPOUNDED 2 _7 ri- 6n] - h . - . DISCOVER Bytaos. . ADDRESS SLIM . a a. • PHONE NUMBER ON/EA / VICTIM/3 wit i D.O.B. ADDRESS stoat PM . 20 . PHONE NUMBER - SPSPEDT'EHAME ! D.O.B. 0/- ;rf: 20-C ? Fir ADDRESS • 5 5• EL-13TZ SINN . . Zip - O PHONE NUMBER irsifjA • • - . • • a . • - . • • • ' • • . PHONE NUMBER • • • SPECIAL INSTRUCTIONS, • ' . • - l - • . ,FOUND . . -. . • '."' 1 - . PROPERTY CLAIM C.I • NOT CLAIM O ITEMT 'OUANnTY VAL .. ' -1 lizEscRIPTioN • :-.0"- - ' : ' • ' % .. , Z. 7 li - •••••••• Nal: • ei:hoaliamiacc kir / 01457‘ , gi oAcam lie 3* t• •-•• . ..• • •. i s' •• . • ffelfr _...• goini.cemw.x.:21. fil irlet /3 fib,Carl C ? ti-prz A Mse•-rce u k^tal • Ving. • 3 .. . .7itin/ „ , . . .• &Evart. a.... . jijkompes ip 1 3.4, x•rio ca') e .rilr• iN 7.4. annii i s..CAva• Lc le; A. iteS Mon, fifty Co,c• • .. . Net KA. rn. 4•D. ilieii;X',;;Pfill, •.:tesi '4/C1m:it< ,:vin -in ',trete kinertyri . . ; . :Iteist‘t1. 411 'Wkii , . 41;ieN A1.4::it:ie.i. er. A. g14,;;. c.missilyamsinio, -IMQ"hilz. eithisszM • ._.;.1. .. . • ..• . . : . • / l i k i t TH tirrylE:evr.4.1. A Cit Aviii-i;tv r I 0,....4, Ciit vRol er 5.0z FrogiA ni• iCttsPIT-(9)" .• .../ • . • Aty:' a) ig. re-ab;... i t4,- ,.4-8.A.4.e. • :F' to inH Ci: #A ei. ' . m • 5 fic,arie,:e pi:. ":: .. t. . .. ' ' ' ' : ! :••0. ... -.. : • rvirin.: ' O Ice tv Jc rt . I kelt. : . - - • . • • •7: `•:.fi .: • •••••''.. , t'it• Zi. ' • le Pik r • 2.elirtki .. : • ..;•"-4, 41- 7, 'i': •:'::: i v . : Z'4•'• • - i • . ." :21*(5 • teraVrAir-;geTURP4S , . . ''rai it. i c- - 49041.: 64i ty?e,. • • . -. . ‘'. c :fr4c..h;: 4r • .1 ) • • . . - • . . .., . :fr. i to - on: - 4 -;r4 rerf c :'e..2 11 - . ':?..: SP.' Ztt) ii •./C afi ::. . zei ;:ie . f C• • • r - ' • 7. , .. . (..b:5;:gi,,,,••7 .: • : - ti'l- :t.. e 6 ce . .I4.,,NNs .z5:- 14n • .Ge...A.. • • iT •. . . .... TOTACPAaKAGEVEICiHT • I: " ' Nesi ko<a<t v• I hereby acknowledge I al the above Hsi represents all property taken - horn mo rid that I have received a copy of ihisrecelpt: • I hereby acknowledge byres in the official that inn above list represents all property. impounded periounance el my duty as a police °Ulcer. • •_7: 16 . l) siGNAT RE , IINI • • , •U It.. :-.4 SIGNATURE ' LATE RECEIVED BY ' . REASON • . DATE/TIME RECEIVED . • - . . .- . : • ••• . . . • t • • . . • . . . ... .• .. . . ,. EFTA00183413 •. • % .4" 4 4:1r • 4 PBPD Fiona:* . .LM BEACR.POLICE DEPARTMEI PROPERTY RECEIPT . . • ae /tot, 6 • DETECTIVE BUREAU 0 PROPERTY 0 FOUND 0 DECEASED (Probated) 0 PERSONAL 0 CONFISCATED 0 DESTROY JP EVIDENCE y eRTRIAL OLABORATORY 0 STOLEN/RECOVERED 0 OTHER A kr: IDENTMITATION Nuo tr) '. GtE? DATEMME RECOVERED . /0 - ,?0-05 PROPERTY NUMBER (Leave Blank) g,..5,,ita_g.. , BIN NUMBER (Loavo Blank) ADDRES MIER . 2 TROPERTY IMPOUNDED 5 F • CI grd/o• DISCOVERED BY/DAB. ADDRESS City Zlo PHONE NUMBER OWNER'S NAME/ DAB.' ADDRESS. . co a PHONE NUMBER SUSPECTS NAME/MO r .ht 1 e• tt litieWt 5 Dp PHONE NUMBER .. . D.0 B. • ikg.h. ADORES ' t . . .. • .. . • v • • • -- PHONE NUMBER spapw. NSTRUCT1OM ' • • .: - - . • • - : - 'POUND PROEFITY'. CLAIM 0 ' . . . • : . . : : iiO DAYS. '• ' NOT OSAIMb : ITEM, -QUANTITY VALuE. ...TaA...,. - -: - ESCRIPTION 4 c.• fk - • •' ''-• . r 6 n 4. • itink. P w id it f ir She IREetttil .. 1. . .. . • • ... . . v C .. hi iiec 4 et. sp ex— ; ki• • - , .• 4 t er •• , ' .. ( etc :..• A<0n 6 ti P. fr•cia • , . • _ . . „t...;. . . . . . . • " " • .• e it tr ode 1••• .. :.,..4. e. µ • ... :...i i."- .i461;-' " /:i4 I:44cent r 0004? •At :. 0 % V : • t.44; - I) ' .)y .... 4 • 41114;;:i" 4 eV; litia . ". t • . *Fla , :• .a US) tie A.* 7". 7$ ' 1.4. - ' pg.e-t-NI-2PN-) • , . : . ' • - her :44l ne/ • -e" ' ' —'7 : • - . • c•fica , • r. .41" • orb • . 0 • bat t i r ge - ! A • . qt.-cr.".- :•:,:•-‘•• -:. •• '•:-PF:-..bdik -,Vitifii Iv Itt: 2(.67(.4.....cei....,ciirffee'.7126{ ,.........,...„..... ...,m)-ii- 1 e p • .1 job t „ • ; . • .. • Q.. % 7 - I . -••:• M a. . • win,A.-..ce i..d.i:-.-fr.,:g..Ys . -. • . fic : :-. 2.(bruitr„) .",:k 9 s (5-S'zkreitift;:.:..i -.,:cei2tkincr-e.:440n7g -gre • icix.‘ re of-Pi? _ tens) • • • ...• • .. • . . .. . TOTAL PACKAGE WEIGHT - ' 1 !lenity acknowledge that the above Net represents at property taken ' .. horn me and Thal I have received a copy of the receipt. in• I hereby acknowledge that the above BM rapresChts by me In the official performance of my duty as a pOke all property Impounded officer. • SIGNATURE • DATE SIG itTU ICH ' RECEIVED BY . REASON DATE/TIME RECEIVED • • • •• EFTA00183414 ...cattyvs, . • • „ . • 0 PROPERTY 7"74 .--......t. 0 FOUND ' -0 DECEASED (Probated) UPERSONAL 0 CONFISCATED • O DESTROY . EVIDENCE \yel TRIAL 0 LABORATORY 0 STOLENIFIO3OVERED 0 OTHER • k; ct to INCIDENT/CITA Ni. g 06 Y. DATEMME RECOVERED /1)- a 0 .o_s- PROPERTY NUMBER (Leave Mirk) . 6,6_ io L.1 • , •-•• BIN NUMBER (tanner* • ADDRESS Whig, RUROPERNIMPOUNDE0L. , BeY £L.- brt\ \D. • • Pahl%) 6eack- ... . . . . DISCOVERED BY//O/D.O.B. • . ADDRESS Street • . ay . -- . ERNE NUMBER ' OWNER'S NAME mom, . ADDRESS 1 Street • Cie• PHONE NUMBER ' SUSPECTS NAME/ D.O.B. 01--Z)-,516DREEIS Sirin .ri no ie fr Sweet cny a - 352t, to-a?' 110 PHONE NUMBER . •• AD Ill.. SUSPECT/we..., • ' . . • ADDRESS • SIMI City Zet. • .. PHONE NUMBER SPECIAL INSTRUCTIONS • • P :. • 1 ' . `F0UND :PR0PERTY. CLAIM ID ., ,NOT CLAIM ID / ITEM-f'. corIANTrry• VAL9E• - • ' ''' .RESCRIPT . - • ..e : sg : • PAWP 0,:. (Of i.. 4, C. P IA- # 5" 3•> 941 . A: .."--- 11; • :r fit i Prory, a -1.4.c ri I' istr k 1.1 c :itk&LN 4.e.tvi . • 5 s • f ltsi-Sakev 1 --, 1 ""." —r-:' , ..v: .- -'• — . • ; -• .-...u., . . Al 5*-g-57 -Proryi ar(1 CD - ..i.tkuvA-. . - , . • . -- • -;• ' . ..• I. . ‘.. :` .: ; .nc :P . . ki4 . .- •• • • Peack : lein-PcSot le -Pot kilt. grit+ ,_ •• I.4. • . • • ....• . . .. • . . .. . .... .... . • • • • - • •.,i • ..• . . , . • . . - - • . , . - ... QZ11124-1 . . .. • - • • ,.. - - - . .. . :. .. • • teal, • TOTAL PACKAGE WEIGHT . . I hereby acknowledge that the above list reinvents all property taken from mo nd that I have received a copy of OA receipt . I hereby acknowledge that the above list represents all property Impounded In the official performance of my duty as .a police officer. S s- t iete°.° ONA E ID/ • - . UNIT. ..44 SIGNATURE DATE RECEIVED BY DATE/TIMEREOSIVED --- • . . teiLM BEACH SLICE DEPARtMEi • • • PROPEWRECEIPT. • • AM( 5 Of 6 DETECTIVE BUREAU • z EFTA00183415 :v.., ker. St*" • ••••-, Ertl • PSPD Fars 162 PALM BEACH liOLICEPEPARTMEN PNPEert RECEIPT LITL-) a Ad; /9464s of 6 DETECTIVE BUREAU 0 PROPERTY V C FOUND CI DECEASED (Probated) 0 PERSONAL ' El CONFISCATED D DESTROY 01IMIDENCE i ciRIAb• 1 4J LABORATORY C) STOtal!FiECOVERED U OTHER (1 a 1,0 s'i INCIIDERT IVATI&I NUMBER I 0 DATETINE RECOVERED t 0 2o0 c 141,/ 0 • PROF!ERTY HUMBER - ("S - (Leave Blank) boa ci BIN NUMBER (Leave Blank) ADDRES5HgROPERTkIMPOUNDNA -dr) / i i 10 DISCOVERED BY/ D.O.B. ADDRESS Speer . 20 1 . . PHONE NUMBER OWNER'S NAME! DAB: ADDRESS Spear qty 20 PHONE NUMBER • Sr T'S NAIIF-JD.O.Ber . ./ ;,,1O. ' r? ti ADDRESS, Street . Clly L , Ik• PHONE NUMBER lipprm... SUSPECT / D.O.B, ADDRESS a ; • PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM 0 • • : •. Arr.' , 't ' 90 DAYS NOT CLAIM Cal p ME ARMY VAltUE . ;DESCRIPTION i LenA . 64/a 4ad Pkil , it >. I . . rilAotE. 44..,-Ail ' 12;iii,op;,.4 A.PACe0. _. (i•ilF. . .: -.: •::: • cf.. .. ... r ' ! • r • (74.C.: ' 7:I.-% . , tOC, fili 4 - • • :: " . . • • - • Vervir* Wilz.O4 t errir ---at •';: fr2.,;. . . , -. . iimpiii..,, r ,c2 ,••••:1••••• .:;4•;.a " k...,... :: i .:..:;:::.. - • , ..;:::.. - • rz - .,. . " - . . . . •_ _ . .. . . . .. . • , -i2c P.)I1 rj .. • .. . . - ...', • . ''..:••-f. ...;:c.:.....1,".c,:". " 2. funr-.? f t ell i ll‘i - • " ' ....;.;600. wigs-. 4: 3, . - ••• . .. . • . i-• .pcivx ' . • ft :. ,.4 TOTAL PACKAGE WEIGHT ‘., I hereby acknowledge that the above lief represorils all property taken ., from me and that I have received a copy of Iles receipt. ^. r I hereby acknowledge that the above lies represents all property Impounded by me In the official performance of my duty as a police officer. I CIIIK .... D24, SIGNATUR ID, - UNIT • SIGNATURE • DATE RECEIVED BY REASON DATE/TIME RECEIVED ob r s2.1, 2 Ely- Ea /a' op 6 - 0 c• /SO 0 ift, , EFTA00183416 LEWIS TE IN PL ATTORNEYS AT LAW July 21, 2008 Copy via facsimile NM Esq. Office of the United States Attorney 500 S. Australian Avenue West Palm Beach, Florida 33401 RE: Jeffrey Epstein Dear Ms. Thank you for your letter of July 17, 2008. In it, you ask whether Mr. Epstein "intends to fully abide by the Non-Prosecution Agreement." The answer is yes. We confirm as you state in your letter that the Agreement requires that "the federal Grand Jury investigation will remain suspended, and all pending federal Grand Jury subpoenas will be held in abeyance unless and until [Mr. Epstein] violates any term of [the Non-Prosecution Agreement]." We also confirm that under the Agreement, "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 , . . conditions and the requirements of th[e] Agreement." As you know, there la no 'provision in the Agreement referring in any way to Section 3509(k). By that statute, Congress imposed a mandatory obligation on federal district courts to stay certain civil cases. Its operation is not subject to the control or discretion of any party. Whether Title 18, United States Code, Section 3509(k) applies to this civil litigation is a question of law for resolution by Judge Marra. Accordingly, we are abiding by our ethical obligation to advise the Court of its statutory mandate under Section 3509(k). Finally, thank you for notifying me that our motion to quash technically remains outstanding. We had previously notified. the Court that the parties did not wish to argue the issue. I agree that the Agreement requires its withdrawal and we will file a formal notice withdrawing it this week. Please do not hesitate to call me if you wish further clarification of our position or to discuss this matter in any way. Until then, I remain, Very truly yours, Michael R. 'rein cc: _lick Goldberge1.1:sLi Ro Black Ls . 3069 GRAND AVENUE • SUITE 340 • COCONUT GROVE, FLORIDA 33133 TELEPHONE (305) 442.1101 • FACSIMILE (305) 442-6744 • VAVW.LEWISTEIN.COM EFTA00183417 LEWIS TE IN PL ATTORNEYS AT LAW July 21, 2008 Copy yin facsimile Mae Esq. Office of the United States Attorney 500 S. Australian Avenue West Palm Beach, Florida 33401 RE: Jeffrey Epstein Dear Ms. Thank you for your letter of July 17, 2008. In it, you ask whether Mr. Epstein "intends to fully abide by the Non-Prosecution Agreement." The answer is yes. We confirm as you state in your letter that the Agreement requires that "the federal Grand Jury investigation will remain suspended, and all pending federal Grand Jury subpoenas will be held in abeyance unless and until [Mr. Epstein] violates any term of [the Non-Prosecution Agreement]." We also confirm that under the Agreement, "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 . . . conditions and the requirements of th[e] Agreement." As you know, there is no provision in the Agreement referring in any way to Section 3509(k). By that statute, Congress imposed a mandatory obligation on federal district courts to stay certain civil cases. Its operation is not subject to the control or discretion of any party. Whether Title 18, United States Code, Section 3509(k) applies to this civil litigation is a question of law for resolution by Judge Marra. Accordingly, we are abiding by our ethical obligation to advise the Court of its statutory mandate under Section 3509(k). Finally, thank you for notifying me that our motion to quash technically remains outstanding. We had previously notified the Court that the parties did not wish to argue the issue. I agree that the Agreement requires its withdrawal and we will file a formal notice withdrawing it this week. Please do not hesitate to call me if you wish further clarification of our position or to discuss this matter in any way. Until then, I remain, Very truly yours, • Michael R. Tein • cc: Jack Goldberger, Esq. • Roy Black, Esq. Alex Acosta, Esq. 3059 GRAND AVENUE • SUITE 340 • COCONUT GROVE, FLORIDA 33133 TELEPHONE (305) 442-1101 • FACSIMILE (305) 442-6744 • WWW.LEW1STEIN.COM EFTA00183418 IN RE: INVESTIGATION OF JEFFREY EPSTEIN NON-PROSECUTION AGREEMENT IT APPEARING that the City of Palm Beach Police Department and the State Attorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey Epstein (hereinafter "Epstein"); IT APPEARING that the State Attorney's Office has charged Epstein by indictment with solicitation of prostitution, in violation of Florida Statutes Section 796.07; IT APPEARING that the United States Attorney's Office and the Federal Bureau of Investigation have conducted their own investigation into Epstein's background and any offenses that may have been committed by Epstein against the United States from in or around 2001 through in or around September 2007, including: (1) knowingly and willfully conspiring with others known and unknown to commit an offense against the United States, that is, to use a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution, in violation of Title 18, United States Code, Section 2422(b); all in violation of Title 18, United States Code, Section 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 18, 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(b) and 2; (4) traveling in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f), with minor females; in violation Page 1 of 7 EFTA00183419 of Title I8, 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. § 159 I (cX I); in violation of Title 18, United States Code, Sections 1591(a)(1) and 2; and IT APPEARING that Epstein seeks to resolve globally his state and federal criminal liability and Epstein understands and acknowledges that, in exchange for the benefits provided by this agreement, he agrees to comply with its terms, including undertaking certain actions with the State Attorney's Office; IT APPEARING, after an investigation of the offenses and Epstein's background by both State and Federal law enforcement agencies, and after due consultation with the State Attorney's Office, that the interests of the United States, the State of Florida, and the Defendant will be served by the following procedure; THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the following conditions and the requirements of this Agreement set forth below. If the United States Attorney should determine, based on reliable evidence, that, during the period of the Agreement, Epstein willfully violated any of the conditions of this Agreement, then the United States Attorney may, within ninety (90) days following the expiration of the term of home confinement discussed below, provide Epstein with timely notice specifying the condition(s) of the Agreement that he has violated, and shall initiate its prosecution on any offense within sixty (60) days' of giving notice of the violation. Any notice provided to Epstein pursuant to this paragraph shall be provided within 60 days of the United States learning of facts which may provide a basis for a determination of a breach of the Agreement. After timely fulfilling all the terms and conditions of the Agreement, no prosecution for the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office, nor any offenses that arose from the Federal Grand Jury investigation will be instituted in this District, and the charges against Epstein if any, will be dismissed. Page 2 of 7 EFTA00183420 Terms of the Agreement: 1. 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. 2006-0f-009495/UO:3(MB) charging one (1) 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 Page 3 of 7 EFTA00183421 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 Page 4 of 7 EFTA00183422 sentenced not later than October 26, 2007. The United States has no objection to Epstein self-reporting to begin serving his sentence not later than January 4, 2008. 12. Epstein agrees that he will not be afforded any benefits with respect to gain time, other than the rights, opportunities, and benefits as any other inmate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration. 13. The parties anticipate that this agreement will not be made part of any public record. If the United States receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before making that disclosure. Epstein understands that the United States Attorney has no authority to require the State Attorney's Office to abide by any terms of this agreement. Epstein understands that it is his obligation to undertake discussions with the State Attorney's Office and to use his best efforts to ensure compliance with these procedures, which compliance will be necessary to satisfy the United States' interest. Epstein also understands that it is his obligation to use his best efforts to convince the Judge of the 15th Judicial Circuit to accept Epstein's binding recommendation regarding the sentence to be imposed, and understands that the failure to do so will be a breach of the agreement. In consideration of Epstein's agreement to plead guilty and to provide compensation in the manner described above, if Epstein successfully fulfills all of the terms and conditions of this agreement, the United States also agrees that it will not institute any criminal ch es a to •o- irators of E stein including but not limited to IN or . Further, upon execution o t rs agreement and a plea agreement with the State Attorney's Office, the federal Grand Jury investigation will be suspended, and all pending federal Grand Jury subpoenas will be held in abeyance unless and until the defendant violates any term of this agreement. The defendant likewise agrees to withdraw his pending motion to intervene and to quash certain grand jury subpoenas. Both parties agree to maintain their evidence, specifically evidence requested by or directly related to the grand jury subpoenas that have been issued, and including certain computer equipment, inviolate until all of the terms of this agreement have been satisfied. Upon the successful completion of the terms of this agreement, all outstanding grand jury subpoenas shall be deemed withdrawn. Page 5 of 7 EFTA00183423 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 prosccutions 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. /II /I/ /II Page 6 of 7 EFTA00183424 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: iti/9 — Dated: Dated: ASSISTANT U.S. ATTORNEY GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANCHBZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 EFTA00183425 By signing this agreement, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the conditions of this Non- Prosecution Agreement and agrees to comply with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: By: ASSISTANT U.S. ATTORNEY Dated: Dated: 7/9-4,/ 0 7 Dated: JEFFREY EPSTEIN 9". FCOUR ESQ. OUNSEL TO JEFFR .Y EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 EFTA00183426 By signing this agreement, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the conditions of this Non- Prosecution Agreement and agrees to comply with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: By: ASSISTANT U.S. ATTORNEY Dated: JEN/REY EPSTEIN Dated: GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN Dated: q -jcit,t/P — , ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 EFTA00183427 IN RE: INVESTIGATION OF JEFFREY EPSTEIN ADDENDUM TO THE NON-PROSECUTION AGREEMENT IT APPEARING that the parties seek to clarify certain provisions of page 4, paragraph 7 of the Non-Prosecution Agreement (hereinafter "paragraph 7"), that agreement Is modified as follows: 7A. The United States has the right to assign to an independent third-party the responsibility for consulting with and, subject to the good faith approval of Epstein's counsel, selecting the attorney representative for the individuals identified under the Agreement. If the United States elects to assign this responsibility to an independent third-party, both the United States and Epstein retain the right to make good faith objections to the attorney representative suggested by the independent third-party prior to the final designation of the attorney representative. 713. The parties will Jointly prepare a short written submission to the independent third-party regarding the role of the attorney representative and regarding Epstein's Agreement to pay such attorney representative his or her regular customary hourly rate for representing such victims subject to the provisions of paragraph C, infra. 7C. Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the attorney representative selected by the independent third party. This provision, however, shall not obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus, if after consideration of potential settlements, an attorney representative elects to file a contested lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested remedy, the paragraph 7 obligation of the Agreement to pay the costs of the attorney representative, as opposed to any statutory or other obligations to pay reasonable attorneys fees and costs such as those contained in s 2255 to bear the costs of the attorney representative, shall cease. EFTA00183428 By signing this Addendum, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the clarifications to the Non- Prosecution Agreement and agrees to comply with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: By: ASSISTANT U.S. ATTORNEY Dated: JEFFREY EPSTEIN Dated: GERALD LEFCOURT, ESQ. COUNSEL 'II) JEFFREY EPSTEIN Dated: if:LaIM LILLY A ANCHEZ, ES ATTORNEY FOR JEFFREY EPSTEIN EFTA00183429 By signing this Addendum, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the clarifications to the Non- Prosecution Agreement and agrees to comply with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: Dated: Dated Dated: By: ASSISTANT U.S. ATTORNEY JEFFREY EPSTEIN ERALD LEFCO RT ESQ. COUNSEL TO JEFFR Y EPSTEIN LILLY ANN SANCHF,Z, ESQ. ATTORNEY FOR JEFFREY EPSTEIN EFTA00183430 111111111111 11 1111 .1111111111 1 0 1 11110.1 1 . 11111 . 1 . 1110 N Sincerely, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY 3 EFTA00183431 With this in mind, I have considered defense counsel arguments regarding the Section 2255 portions of the Agreement. As I previously observed, our intent has been to place the victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less. From our meeting, it appears that the defense agrees that this was the intent. During the course of negotiations that intent was reduced to writing in Paragraphs 7 and 8, which as I wrote previously, appear far from simple to understand. 1 would thus propose that we solve our disagreements over interpretations by saying precisely what we mean, in a simple fashion. I would replace Paragraphs 7 and 8 with the following language: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, wilt have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein been tried federally and convicted of an enumerated offense, For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 2 EFTA00183432 U.S. Department of Justice United States Attorney Southern District of Florida R ALEXANDER ACOSTA UNITEDSTATES ATTORNEY DELIVERY BY FACSIMILE Lilly Ann Sanchez Fowler White Burnett, PA 1395 Brickell Aye, le Floor Miami, FL 33131 Re: Jeffrey Epstein Dear Ms. Sanchez: 99 NE (Street Main& FL 13111 (105)9614100 Telephone 005)1104444 - Facsimile December 19, 2007 I write to follow up on the December le meeting between defense counsel and the Eps prosecutors, as well as our First Assistant, the Miami FBI Special Agent in Char e and mysel . 2 Section 2255 provides that: "falny person who, while a minor, was a victim of a violation of [enumerated sections of Title 18) and who suffen personal injury as a result of such violation . . . may sue in any appropriate United States District Court and shall recover the actual damages such person sustains and the cost of the suit, including a reasonable attorney's fcc " EFTA00183433 By signing this Addendum, Epstein asserts end certifies that the above has been read and explained to him. Epstein hereby, states that he understands the clarifications to the Non- Prosecution Agreement and agrees to comply with them. K. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: By' U.S. ATTORNEY Dated: / °''I 163- Dated: Dated: GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN EFTA00183434 Page 2 of 8 Westlaw West's F.S.A. § 951.24 Page 1 C Effective:Pee Text Amendments] West's Florida Statutes Annotated Currentness Title XLVII. Criminal Procedure and Corrections (Chapters 900-999) (Refs & Annos) Chapter 951. County and Municipal Prisoners (Refs & Annos) 951.24. Extend the limits of confinement for county prisoners (I) Any county shall be deemed to have a work-release program upon the motion of that county's board of county commissioners which shall require the concurrence of the sheriff of the county. (2)(a) Whenever punishment by imprisonment in the county jail is prescribed, the sentencing court, in its discre- tion, may at any time during the sentence consider granting the privilege to the prisoner to leave the confines of the jail or county facility during necessary and reasonable hours, subject to the rules and regulations prescribed by the court, to work at paid employment, conduct his or her own business or profession, or participate in an educational or vocational training program, while continuing as an inmate of the county facility in which he or she shall be confined except during the period of his or her authorized release. (b) My prisoner, at the time of sentencing or thereafter, may request the court in writing for the privilege of be- ing placed on the work-release program. The Department of Corrections, upon the request of the court, is author- ized to conduct such investigations as are necessary and to make recommendations to the court pertaining to the suitability of the plan for the prisoner and to supervise such prisoner if released under this program. Such a re- . lease may be granted by the court with the advice and consent of the sheriff and upon agreement by the prisoner. The court may withdraw the privilege at any time, with or without notice. (c) No person convicted of sexual battery pursuant to s. 794.011 is eligible for any work-release program or any other extension of the limits of confinement under this section. (3)(a) The wages or salary of prisoners employed under this program may be disbursed by the sheriff pursuant to court order for the following purposes in the order listed: I. Board of the prisoner. 2. Necessary travel expense to and from work and other necessary incidental expenses of the prisoner. 3. Support of the prisoner's legal dependents. C 2008 Thomson Reuters/West. No Claim to Orig. US Gov. Works. litim://web2.westlaw.com/nrint/nrintstream.asmanrfir-HTMT.Fkifm=hIntSetRidect nat inn 1 1 /94/WIR EFTA00183435 Page 3 of 8 West's F.S.A. § 951.24 Page 2 4. Payment, either in full or ratable, of the prisoner's obligations acknowledged by him or her in writing or which have been reduced to judgment. 5. The balance to the prisoner upon discharge from his or her sentence, or until an order of the court is entered declaring that the prisoner has left lawful confinement, declaring that the balance remaining is forfeited, and dir- ecting the sheriff to deposit the funds in the general fund of the county to be spent for general purposes. (b) The sheriff may collect from a prisoner the wages or salary earned pursuant to this program. The sheriff shall deposit the same in a trust checking account and shall keep a ledger showing the status of the account of each prisoner. Such wages and salaries shall not be subject to garnishment in the hands of either the employer or the sheriff during the prisoner's sentence and shall be disbursed only as provided in this section. (c) Every prisoner gainfully employed is liable for the cost of his or her board in the jail as fixed by the county. The sheriff shall charge the prisoner's account, if he or she has one, for such board. If the prisoner is gainfully self-employed he or she shall deposit with the sheriff an amount determined by the court sufficient to accom- plish the provisions of subparagraphs (a)I.-5., in default of which his or her privileges under this section are automatically forfeited. (d) The board of county commissioners of any county may, upon the recommendation of the sheriff, authorize the person in charge of a county stockade or workcamp to implement paragraphs (a), (b), and (c), when such fa- cility is not directly under the sheriff. (4) Any prisoner who willfully fails to remain within the extended limits of his or her confinement or to return within the time prescribed to the place of confinement shall be deemed an escapee from custody and shall be subject to punishment as prescribed by law. (5) Exchange for the purpose of work-release of county prisoners among other counties of the state that have im- plemented work-release programs is hereby authorized, with the concurrence of the sheriffs of the involved counties. For the purpose of this subsection, upon exchange, the prisoner shall be deemed a prisoner of the county where confined unless or until he or she is removed from extended confinement status. Prisoners from other jurisdictions, serving lawful sentences, may also be received into a county work-release program as above provided. (6) In carrying out the purpose of this section, any board of county commissioners may provide in its annual budget for payment to the Department of Corrections out of funds collected from those being supervised such amounts as are agreed upon by the board and department to be reasonable and necessary. County judges arc hereby authorized to levy $10 per month upon those supervised for purposes of paying for supervision under this act. CREDIT(S) 1 1 Pt A P.I."^t1 EFTA00183436 11/25/2088 15:28 3553626 U1KUUll LICIAINAL " raisin" do " • • STATE OF FLORIDA Plaintiff -VS- JEFFREY Defendant IN THE nrnarrrs JUDICIAL . CIRCUIT COURT, IN AND FOR PALM BEACH COUNTY -* CASE NUMBER IDLNACERQ2211/62Q2S12 DIVISION MCSORLEY "V PI 1,113$155 DC NUMBER CIRCUIT NUMBER: 15-4/ JAIL spur ORDER OF COMMUNITY CONTROL I This cause coming before the Court to be heard, and you, the defendant, being now present before the mutt and you. having El catered a plea of guilty to O been found guilty laYinrY verdict of O entered a plea of nolo cone sere to 0 been found guilty by tho court trying the cat without a jury of Count L isocuRtrasoN UNDERAGE_QT 18 FOR PROSTITOTIQN SECTION 3.: JUDGMENT OF GUILT El The court hereby adjudge" you to be guilty of the above offense (s). Now, therefore, it is ordered and adjudged that rho imposition of sentence is baby withheld and that you be placed on Probation I for a period of candor the supervilion of the Department of Correction", subject to Florida law. SECTION 2t ORDER WITHHOLDING ADJUDICATION O Now, therefore, it is ordered and adjudged that the adjudication of guilt is hereby withheld and that you be placed on Probation fora period of under the supervision of tho Department of Corrections, subject to Florida law. SECTION 3: INCARCERATION DURING PORTION OF SUPERVISION SENTENCE It is hereby ordered and adjudged that you be O committed to the Department of Contetions or O confined In the County Jail fore tout of with credit for jar] time. After you have served of the term, you shall be placed on Probation for a period of under the supervision of the Deportment of Cormotions, subject to Florida lbw. or • oontired in the County /all fors term of SIX (61 MONTHS AS TO COUNT 1IrOLLOWED DY TWELVE (121 MONTHS, 0212111CLUSdatigaL I CONSECUTIVE TO IMEE (121 MONTH SENTENCE IIZ CASEY! 2008CF009454AbfE with credit for ONE al DAY Jail limo, as s special condition of tutoervielon Page 1 of 8 1VHIHRID LISOBIO 13 ntinoo H3V38 W1Vd /i831S 'FOOS !IOSIMS , SS:h Hd IZ1R1800Z 03114 Form Revised 03-11-08 EFTA00183437 11/25/2066 15:2B 3553626 • • Vibiaii I " -"— ri-ikt Ott CO JEFFREY EPSTEIN CASEN50.2008CF0093814,00346 . . • • . XT 78 FURTHER ORDERED that you &sitcoms* with the following gjandard °midi dons otintervision assioxided . by Fiptida • • . . • • law: (1) You will report to the probed= office as directed. Not later than the fifth day of each month, unless othawbe littered, you Will . . . • ' make e full end ttuthfW tittOn io youryouroffice/ on the form For that purpose. . .. • . • • (2) You will pay the State °Mori& the amount of 950.00 per month, es well as 4% surcharge, toward rho post of your supervislcm fn • . • . accordance with s. 948.09,F.S,, unless otherwise exempted in compliance with Florida Statutes. . (3) You will remain in a specified piece. You will not change your residanse or employment or leave the county of your residence without first procuring th000nsent of your officer. • • • (4) You will not possess, carry or own any fires= or weapon, unless authorized by the court (5) You will live without :violating the law. A conviction in a court of law shall not be necessary for such a violation to constitute a violation of your probstiodeonunuoity cootrol. 46) You Will not *stook= win. any person engaged in any criminal activity. (7) You will not use ineoxiccetS to- excess or possess any drugs or narcotics =less prescribed by a physician. Nor will :you visit places where intoxicants, drugs or other dangerous substances are =lawfully sold, dispensed or used. (8) You will work diligently at a lawful occupation, advise your employer of your probation statue, and support any dependents to the best of your ability, as directed by your officer. (9) You will promptly and truthfully answer all inquiries directed to you by the court or the officer, and allow your officer to visit In. your borne, at your employment site or elsewhere, and you will comply with all instructions your officer may give you; (10)You will pay restitution, own costs, and/or foss in accordance with special conditions imposed or In accordance with the attached orders. (11)You will submit to random testing es directed by your officor or the professional staff of the treatment center whore he/she Is receiving treatment to determine the presence of alcohol or illegal. drugs. You will bo required to pay for the tests unless exempt by the court. (12)You will submit two biologic:Li specimens, as directed by your office?, for DNA analysis as prescribed In as, 943,325 and 948.014, F.S. (13)You will report in person within 72 hours of your release from incarceration to the probation office in BALM 131 I1 County, Florida, unless otherwise instructed by the court or department. (Ma oondition applies only if section 3 on the previous page is checked.) Marxist, yon must report immediately to the probation office located at '444 SOUTHSONGflaAlain& Toittcr. VORTIR FL 33451, Pogo 2 of 8 Form Revised 03.18-08 EFTA00183438 _ . 11/25/2008 15:2If • 3553626' • • 1:1114.311. I t.atheithiel: neon 'des cio JEFFREY EPSTEIN cASE002008CF009381AXX:Ort0 . . .............. .... , . . SPECIAL c,cisnrnpris- • - ,..., O L You must undergo a Drug and Alcohol evaluation and, if treatment is doomed necessary, you must successfully complete the treatment, and be tosponsible for the payment of any costa Maimed while receiving said evaluation anritreatmentoun1°35. waived by the court.- . . . • Additional instructioriordercdf O 2. You will make ralitution to the following viotka(s), as treeted by tho court, until the obligation is paid in full: NAME: • . TOTAL AMOUNP, S Additional inetruedone ordolod, including spoolfto monthly amount, begin date, due date, otjoint & several: • NAME'. TOTAL AMOUNT: S ' Additional instructions ordered, including spoolfie monthly amount, begin date, due date, or Joint & several: • - SPECIAL CONDMONS — CONTINUED K 3. You will enter the Dopertment of Corrootione Non-Swum Thug Treatment Program or other residential treatment program/Probation sad Restitution. Center for a period of successful completion as approved by your officer. You are to remain until you succesefully complete said Program add Aftercare. You are to oomply with all Rules and Regulations of the Program. You shall be confined In the county Jail until placement in said program, and if you are confined in theist'', the Sheriff will transpon you to said program. K 4. Yi..1 will abstain entirely from the use of alcohol and/or illegal thugs, and you will not 3330eillte with anyone who Is illegally using drugs or calumnies alcohol. O 3. You will submit to urinalysis testing on a monthly basis to determine the presence of alcohol or illegal drugs. You will be required I pay for to tens unless exempt by the court. K 6. You will not visit any establishment where the primary business is the sale and dispensing ofaleoholio beverages. O 7, You will successfully complete • haus of community service at a rate of , at a work site approved by your officer. Additional Instructions ordered: O 8, You will male at your residence between 10 p.m and 6 a.m. due to a curfew imposed unless otherwise directed by the cow. K 9. You will submit b electronic monitoring, follow the rules of electronic monitoring, and pay S pa month for the cost of the monitoring service, unless otherwise direoted by the omm. O 10. You will not associate with during the period of supervision. K IL You will have no contact (direct or indirect) with the victim or the victim's family during the period of supervision. O 12. You will have no contact (direct or indirect) with during the period of supervision. K 13. You will maintain full time omploymont or attend echoed/vocational school full time ore oombloation of school/work during the term of your supervision. K 14. You will make a good faith effort toward completing basic, or functional literacy siolb or a high school equivalency diploma. O 15. You will succomfully complete the Probation de Restitution Program, abiding by all rules and regulations. Page 3 of 8 Form Revised 03.18.0g EFTA00183439 Ili:Lb/2881dt! • lb! 21:1 • dbh-ilaZ • r b lktAlrariA.' ' JEFFREY EPSTEIN CASE#5020080F009311A=UvlB • . O 16. You will attend Alooholles Anonymous ox Narcotics Anonymous meetings at least monthly, Soso .otherodse directed by the court. • • • " • . . • .• . . O 17. You pint 3i1O0AnfullY complete MRHIlitillasna, and be rerionsible for the payment of any costs incurred while receiving said treatment, unless waived. If convicted of a Domestic Violence offense, as defined fn a. 741.28, P.S., yeti. must attend and auccesefully complete a batteries intervention proviso, unless otherwise directed by the QOWI " . .• Additional Inattuctioniorderid: • . • . O 1a, You will attend m HIV/AIDS Awareness Program'Cooststing of a elms at not leas than two (2) boors or more than four (4) boars in length, the that for which willbepald by you. O 19. You aball submit your person, mammy, place of residence, vehicle or personal effects to a warrantless search at any time, by any probadon or community control officer or any low enforcement officer. • 23 20. DEFENDANT MUST REGISTER AS A SEXUAL OFFENDER WITHIN 48 HOURS OF RELEASE C3 21. AS A SPECIALCOMMON OF HIS commurtm CONTROL, TPIE DEFENDANT IS TO WAVE NO UNSUPERVISED CONTACT WITH MINORS, ANDTHE SUPERVISING ADULT MUST BE APPROVED BY . THE DEPARTMENT OR CORRECTIONS • • • 0 22. THE DEFENDANT IS DESIGNATED AS A SEXUAL OFFENDER PURSUANT TO FLORIDA STATUTE ' 943.05 AND MUST ABIDE BY ALL THE CORRESPONDING REQUIREMENTS OF THESTATUTE, A COPY OF WHICH IS ATTACHED HERETO AND INCORPORATED HEREIN 21 23. DEFENDANT MUST PROVIDE A DNA SAMPLE IN COURT AT THE TIME OF THIS PLEA. 0 24, SPECIFIED CONTACT WITH THE PAROLE AND PROBATION OFFICER • O 25. CONFINEMENT TO AN AGRZZO•UPON RESIDENCE DURING HOUR, AWAY FROM EMPLOYMENT AND FUBLIC SERVICE Activrraks • El 25, MANDATORY PUBLIC SERVICE O 26. SUPERVISION, BY THE DEPARTMENT OF CORRECTIONS BY MEANS OF AN ELECTRONIC MONITORING DEVICE OR SYSTEM O 27. ELECTRONIC MONITORING 24 HOURS PER DAY 23 28. CONFINEMENT. TO A DESIGNATED RESIDENCE DURING DESIGNATED HOURS AND, IF PLACED ON pipci OFF_Et(Mat PROBATION YOU WILL COMPLY WITH THE FOLLOW= CONDITION OF SUPERVISION IN ADDITION TO THE STANDARD CONDITIONS LISTED ABOVE AND ANY OTHER SPECIAL CONDITIONS ORDERED )3Y THE COURT: (14)You will participate in a specialized drug treatment program, either as an In-patient or out patient, A8 rotommonded by the treatment provider. You will attend ell counseling sessions, submit to random urinalysis and, if an Impatient, you will comply with all operating rules, regulations end procedures of the treatment facility. You will pay for all costs associated with treatment and testing unless when*, directed. Additional Instructions ordered: (15) You will =MID at your residence between • p.m. and am. duo to a curfew Imposed, unless otherwise K directed by the ow. AND, W PLACED ON COMMUNITY CONTROL YOU WILL COMPLY WITH THE FOLLOWING CONDITIONS, IN ADDITION TO THE STANDARD CONDITIONS LISTED ABOVE AND ANY OTHER SPECIAL CONDITIONS ORDERED BY THE COURT: Page 4 of 8 Form Revised 0348-08 • .. EFTA00183440 '11 / 25/28100 15:28 35538.26 r • . . . . . . . • talitlUI I latilMtrint. • moan ow no JEFFREY EPSTEIN CASE#502008CF009381A7CalyiB (14)Y will repots to your officer le directed, it least Basel; unless yop have.vnitten eamentethenyba. (15)You will remain confined a your approved residence except for one half hoar before and after your approved emplortents. . Public service work, m any other special activities appioved by your officer. . . . • . . " ..(16)You will maintain an hourly accounting of all your activities on a daily lOg, which you will submit to:your caw on, request. (17) You will successfully complete bows of community service at a rite of_; at a Work site approved by your offiem, Additional inetrucnotts ordered:" ' ' ' . •• • . • (18) You will submit to electronic monitoring, follow the rules of olcotronle monitoring, and pay S per month ED for the cost of the monitoring service, unless otherwise directed by the court. AND, IF PLACED ON j rtr1BATION AA GOMMCrrr1TY CO1iTR01 FORA SH.X 0 PROVIDED IN CRAPTER . 28, a. 800.04 a. 827.071, or s,1147,0145, COMMATTED ON OR AFTER OCTOBER I. 1995 YOU WILL COMPLY WITS TAE FOLLOWING STANDARD SSX OFFENDER CONDITIONS, IN ADDITION TO THE STANDARD poNpinoNs • -LISTED ABOVE AND ANY OTICER SPECIAL CONDITIONS ORDERED BY TEE COURT: • (14)A mandatory airtime from 10 p.m. to 6 a.m. The court may designate another 8-hour period if the attendee employment . precludes the above speollied dine, and the alternative is recommended by the Department of Corrections, if the court determines that imposing a curfew would endanger the victim, the court may consider alternative unctions. (15)11 the vietim was under the age of 18, a prohibition on living within 1,000 feet of a school, day care center, pack playground. or other place when children regularly congregate, es prescribed by the taut Tho 1,000-foot distance shall be measured. in a straight line from the offender's place of residence to the nearest boundary line of the school, day care center, park, playground, or other place where children congregate. The distance may cot be measured by a pedestrian route or automobile route. (l6)Active participation in and successful completion of a sex offender yea:rent program with qualified practitioners .apecifleally trained to treat sex offenders, at the offender's own expense. If a qualified practitioner Is not available within a 50-mile radius of the offender's residence, the offender shall participate in other appropriate therapy. (17)A prohibition on any contact with the victim, directly or indirectly, including through a third person, unless approved by the victim, the offender's therapist, and the sentencing court. (18)If the victim was under the ago of 18, a prohibition on contact with a child under the age of 18 except as provided in this paragraph. The court may approve supervleed contact with -a child under the ago of 18 If the approval is based upon a recommendation for contact issued by a qualified proodtioner who is basing the recommendation on a risk as carmen'. Further, the 50% offender must be currently enrolled in or have successfully convicted a sex offender therapy programa. be court may not guard Supervised contact with a ohild if the contact is not recommended by a quadded practitioner and may deny supervised contact with a child et any time, (19)11 the victim was under ego 18, a prohibition on working for pay or as a volunteer at any place where children regularly °engage's, including, but not limited to any school, daycare center, park, playground, pot store, library, zoo,.theme park, or mall. (20)Unless otherwise indicated in the treaunent plan provided by the aerial offender treatntent program, a prohibition on viewing accessing, °voting, or potsessing any obscene, pornographic, or sexually stimulating visual or auditory material, including telephone, electronic media, computer prove:rat or computer services that are relevant to the offender's deviant behavior pattern. (21)A requirement that the offender submit two specimens of blood or other approved biological specimens to the Florida Department of Lave Enforcement to be registered with the DNA data bank. (22)A requirement that the offender make restitution to the victim, as ordered by the court under s. 775.089, Thrill necessary medical and Misted professional =vices relating to physical, psychiatric, and psychological area (23)Submission to a mummies, search by the community control or probation officer of the offender's person, residence, or vehicle. te Page 5 of 8 Form Revised 03.18.08 EFTA00183441 . . . VA . I ... W . arin 111 YD/ =OD lo: 00:•30040 • IMParb helra. - _ . . . - in« jaa ... • JEMMY EPSTEIN •• • CASE5.502008CF009381AXXXMB • • EFFECTIVE FOR PROBATIONELOR toromary CONTROLLEE WHOSE CRIME WAS COWITITED . ..• , Ann corona -LIM, AND WHO IS_PLACED ON COMMUNITY CONTROL OR SEX OFFENDER ?IODATION • FORA VIOLATION OF. CHAPTER s, s.837.071, or 8.147.0145, IN ADDITION TO. ANY oTh..TR,PRonst : . • - • l• • •a OF THIS SECTION, YOU MUST COMPLY WITH THE FOLLOWING CONDITIONS OF SUPERYISIONt7. • • . (24)Aa part of a treatment program, participation nicest manually in polygraph examinations to obtain information accessary fi 's*. management and trait:moot and to reduce the sex offonder's denial mechanisms. A polygraph examination must be conducted by a . Polygrapher trained specifically in the use of dm polygraph for the monitoring of sex offenders, whemaytillithie, end shall • - by the sex offender. .•• .•. • . (25)Maintenance of a driving log and a prohibition against driving a motor wshick alone without the prior approval of the supervising officer. (26)A prohibition against obtaining or using a post °Moe box without the prior approval of the supervising officer. (27)If there wee 'sexual 'contact, • submission to, at the offender's expense, an MY teat with the'rethlts to be released to the victim • andfor thevicthn'a pate li of guaidiais.,. . • A . • (28)Ekitronio monitoring 'when deemed 'necessary by the probation officer and supervisor, and Ordered by the court at the . . recomroendation of the Department of Corrections, . . . . . • . . (29)Effective for an offender whose crime was committed nor after July 1, 2405, and who are planed on supervision tor violation of chapter 794, s. 800.04, s. 827.071, ors. 847.0145, a prohibition on accessing the Internet or other computer servicos until the offender's sex offender treatment program, after a risk assessment is completed, approves and implements a safety plan for the offender's accessing or using the Internet or other comphter services. . (30) Effective for offenders whose crime was committed on or after September 1,2005, them is botchy Imposed, in addition to any other provision in this section, mandatory electronic monitoring as a condition of supervision for those who: An placed on supervision for a violation of chapter 794, s. 800.04(4), (5), or (6), e. 827.071, or a, 847.0145 and the uniewhti sexual activity involved a victim 15 years of age or younger and the offender b 18 years of age or older, or • Are designated as a sexual predator pursuant to a. 775.21; or • Hee proviouely been convicted o f a violation Mahatma 794, a. 800.04(4), (5), cc (6), 3. 827.071, or s. 847,0145 and the unlawful sexual activity involved a victim 15 years of age or younger and the offender is 13 years of age cr older. You are hereby placed on notke.that should you cloak your probation or community control, and the conditions set forth in a. 948.063(1) or (2) are sallefied, whether your probation or community control is revoked or not revoked, you shall be placed on • electronic monitoring in accordanoe with F.S. 948.063. • .• • YOU ARE HEREBY PLACED ON NOTICE that the court may at any time rescind or modify any of the conditions bf your' probation, or may extend the period of probation as authorized by law, or may discharge you from Author supervision If you violate any of the conditions of your probation, you may bo arrested and-the court may revoke your probation, adjudicate you guilty if. adjudication of guilt was withheld, and impose any sentence that it might have imposed before placing you on probation or require you to serve the balance of the sentence. . • Page 6 of 8 Fenn Revised 03-18-0t EFTA00183442 ,ite6;42b • i" taisidatte ' • " reathThis /Feld ' • - ; JEFFREY EPSTEIN CASENS02C08CE0O9,81A.7OOO4B • : . ..• • . • .. • . IT.ISCFUITHEN. ORDERED that When you:Mite boat instructed ai bid= conditions of probation, you shall be released froth ' t.: •••• : custody if you aro in custody; and If you enetlibityOp bond, the swedes thereon shall stand discharged from liability, (rwe . peragreph applies only if section I or section 2 is checked.) • • . if IS FURTHER ORDERED that the Week of this wart file fide order in the clerk's saes and provide certified copies ofsame the officer fbr use to compliance with the requirements of law. DONE AND °ADULT, on NEMO PRO 71.1NC D6-30-2008 :t.-e7tq< • Sandra K. MoSerley,.Ciroult dge Dint • Instructed by: Supervising Officer ? I acimowledge receipt of copy of this order and that the oonclitiom ban be plaited to me and I agree to abide by them. op/O7.02.08 Page 7 of 8 Defendant Perm Reviled 03-1 8-08 EFTA00183443 LA I :Of 212131:1 Di:ste comicoLo • . • • JEFFREY EPSTEIN CASEM502008CT00938IAXXXMB COURT ORDERED PAYMENTS CENCI( ALL. THAT AREORDERED5 : - '. —. ' '• • • . . . . • EWES ,. • $__,... Total of fines assessed in sentence, pursuant to s. 775.083 (I Xs) through (g) or Chepter 316, F.S. Statutorily mandated 3% anchors/eon iffino anniscd (on first line) pursuant to s. 938.04, P.S. • .... I. ;An Crime Stoppers Trim Fund pursuant to 3. 938.06(1), P.S. ligutorliv mondatoi if. One it hi tiontl . . , . • pin AMATORY COSTS IN Altl, CARPs ' .0 5100,00 Additional ovit'coat for felony offense, pursuant to 3. 938,05( IXo), F,8, , O i„52,12 Additional court cost for misdemeanor or criminal traffic offense, pursuant to s.938.05(1)(b) o0 (c), F.S. El 1 50.00 . Crimu Compensation Trost Fund pursuant los. 938.03( I), F,S. . . O ; 50.0Q County trims Prevention Fund pursuant toe, 775,083(2). F.S. . ' M S 3.00 Additional Court Costs Carlos Trust Fund pursuant to 1.938.01(1), F.S. . • $ 2.00 • Per month for mob month of supervision for Training Trust Fond Surcharge, pursuant to s. 998.09. P.S. MANDATORY COSTS IN SPECIFIC TYPES OF CASES Rap. Crisis Program Trutt Fond --, pursuant to t. 938.085, RS, for any violation, of ss. 784.01.4184:021, 784.03, ?NMI,. ' . • 784.045, 784.048, 784.07, 784.08,184.081, 784,082,184.083, 784.085, or 794.011, F.& . Domestic violate Trutt Fund, pursuant to a. 938.08, F.S. funny violetions of es. 784.011, 784.021, 784.03, 7114.0alr 784.046, 784.048, 784.07, 784.08, 784.081, 7K082, 784.083, 784.085, 794.011, or any offense of Galindo ViNatco described in a. .. • • . • ... .. • . • • • . . . . O SIfiLail O IMO ▪ FlOt.00 . K 311.5.00 O 3 3,00 O 0 1.-5. 2 ,22 S60Q • ; 3.00 K $ LOP K 0 $.5B4E (ES Sus 0 Other O Other: . • • Certain Crimes Anton Minors, pursuant to.. 938.10(1), P.S. for any violations of a. 784.085, chapter 787, chapter 794. 796.03, a. 800.04. chapter 827, s. 847.0145, or., 935.701. F.S. ' • DUI Court Cont, pursuant toe. 938.07, F.S. for any violations of en. 316.193 or 327.3$, P.S. • State Agency Law Enforcement Radio System Trost Fund, pursuant toe. 318.18(17), F.S, for say violations of offenserikted • Ina 318.17 including se. 316.1935, 316,027, 316.061, 8771'1, chapter 893, to. 316,193,316.192, 316.067, 316.072(3), 3 I 6.545(I), or any Ober offense in chum 316 which is classified a, a orimtnal violation. MANDATORY COURT COSTS AUTHORIZED BY LOCAL GOVERNMENTAL MT/TIES Criminal Junk' Education by Munteipstitte, and Counties. pursuant to st. 938.13, P.S. Additional court elan for looal requircmenn and other onenty funded programs pursuant to a. 939.165(1)(a), F.S. Tnn Court wants to it. 938.19(2), F.S. PISCRETIONARV Per month during the term of simertIsion to tho following nonprofit organisation erriblished for the solo purpose of Aupplospettlift Om rthablIIISINS Offorlis of the Deportment of CNTeettelle. pursuant to s. 94 8.039(2), F.S.: • Public, Defender Application Fee, If not proviously collected or waived, pursuant tor. 27.52 and a. 938.29, F.S. Public Defends!. Fen sad Costs, pursuant tot 938.29, F.S, ea determincd locally. ProseoutloofinvesdastIve Costs, mann to s. 938.27, PS. Sifbit County Alcohol and Other Drug Abuse Trust Fund, pursuant to s. 938.21 and s. 938.23, F.S. tor violations of s. 316.193, s.856.01 1 s. 855,015, or choptu 362; Charier 567, or dupter 568, F.S. 0 £100.00 Operating Mat Rood of the FOLIC, punusnt to a, 938.25, F.S. for violations oft 893.13 Wawa TOTµ 3 473.00 PAYMENT IS TO BE MADE THROUGH AND PAYABLE TO: 0 Deparirnent of Corrections or 0 Clerk or Coun (if collected by the Department of Carnation, a inkblots of 454 will be added to all Nyman ordored by the coun, pursuant to s. 945.31. P.S.) O Court Costs/Finoo Waived O Court Costs/Fines In the amount of convened to certimisisity n-tv/OC hours K Court CODS/Finci In the amount of reduced to civil judgment. SPECIFIC INSTRUCTIONS FOR PAYMENT: Page 8 of 8 Form Rcvised 03-18-08 EFTA00183444 YiaJlia • 1.: .11167-71WW . .• -6F f*. V8. • ' %/ EMS' it .flas,arinfrzeim . • • • Y:314FYJTVP ci r je-ttesig. urt f r.a ar Denied •O With rithout Prejudicet O Warrant fa Ordered O ecalled O Bo dForf OOR:Diselia nbinstated 13otid Fort Vacated Otrekious Pond Reinstated, if B . Deft Indigen't, O It A Esvaluation for: O Iftg Firth • .' O. PrekPlea • O Referred to: PTI I PAl EPP ENTERED A>≤LBA O A14.. C*30 4; ts ?NT( er lest dv of Rts O O Erg only' Pa DOCNota-Sectze: Bed ordered by/wi bit days LI • Case pla4d on th absentee docket thdrawn O •• " isistsis • ?Act' . • • :-CruRep. • • 1Reserves Ruling O Written Order to Follow, O See Bellew fiAlso Coven afili Cone OSOR:Dischaeyoked/Reinstated . • to le charges O' ,.eleased GR. / SD& • :"'• • O CdtrisApptk • NOT GUILTY ?unify O NO Cts • Waived PSI • Lesser Cie.. JOUELTY.as Charged as-to GUILTY as.Charged as t NWBBLI) as to Cts • • FOUND ANDADJUDIC.AlteD Pa& 01.N.210Ulirf fob kr:lath Control: O Ft!eyo St.i.p/Pound: (violent). • abitiral 0 l23‘111ENC:E: PBCJ PBCJ: ' .W/Credit for —one / Comte /Co-Term ickesei d Reinsta 771084 Cts: Cts• 3 Execution of Sentence Ste Youthful Off O Heidi 0438MBAINTBNCETOB ) DRIVERS LICBNSB Lessc vionput.frorkiDEVBtaffing ' I Az O•BESNItti CriTOPBB,KS Tom. : er Charge /BLED as to Cts • gz.NW.PP2Phogs b Modified Q thej4. liceeselully OJnsu • Predator ire.erfatrS t De.12.eananded totem:am . onpam • Cte Cr Sentence Suspe'ided 3 Mine sery as Mt Cts • %. O Min / Mend: as trigs Byi. O Pabadon CJ•Dnig /Sex 0046 0 Comm Control O,1 •••• Seat*. 2 USPENDHD/ RE-701031/ FOR . j {TSARS. AbA. i • a. C Deft sign q Def Co . . O A A 4 17 !Prob O. Jail O DJJ O. 0 T ' Notified by ii by: .:.. O County Courthouse • . O Courtro ' Crim kill Justice B 205 N. Dixie, West Palm Beach 38844 State.Road 80, Belle.Glade I: 3228. Gun Club at Palm-Beach 00YOURRE A PENCE WITH A OSAMU!? WHO NEEDS ANY ACCOMUKOAlthel PI ORDER TO PAARCIPATE IN THIS PROC ECOEL.TOUIARE ENTITLED, it NO COST TOYCLIJOiTiETHETRECIIITE; 't J.:ERTEN ASSISTANCE PLEASE CONTACT MARY JAFFE, ADA COORDINATOR P4 THE ADEPTSTRARTE OFFICE OF TIE tow PAYMBERCII county COURTHOUSE, smigtaarn eiviam Easm . TEST RUM MACK R. Wet; TELF.PHONE (361)E.S.4110, WITHIE 2 WORKINCIDAYSOF YOUR RECEFT OF THIS HOTICEIRYOU ;VIEW/ARM OEYOICE IMPAIRED, CALI. . • • • kr- -, ‘31 FIND lin Ilea. . , Set/tRernains S Set / Remains Se Reset • Reset ' . • • ' Div • • Div Walk 4. . -4 O POWs:pan • ' /•• ./ . . O Couritoonie Cr' vetice Complex.. 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' aSt.01. erylelcrut • • 4ettliOr.: b C .Waived lay Court. . . . . 1;0-,I.Enliii• . uceedsfully:OappletetibD-Nopie ureeed•Prograrn•andAny•Recomiciendedaftereark;t•" a FfolptiOisatocly, release onlylo DOC-Non-a ureted-prograni Officer. . . . . 0 ..Enterlifi0 Successfully Corapiete•RBSOlong./ Shod-I/Sok :Drug Farm anti-Any Rec;Afterearet74,?t. „ . 10 ForfeitWeapon /•Mbney"seized at the Arne• of aerest to: . - a Enter•andtomplete: 0 Anger Management:Program ' 0 Batterers Intententline. grar9.-c. " iii*T•beftAbatemeni Program: • • : ".. •• • .0 Defendant may apply for.Early.Terrnination after ) , provided ail conds. are satisfied. . '0 Seive • ' •• • days / month in.? Withrgradlt for -• . • • • , -days 1.minths. • • • 4 1 / 4 :1 1 °re fli S i ci • 6e114 .5i* .' •k*Sq Mit< )(viz 0 , I-) • • k -ociRS. p Q- .410)\.±- 14 0 e7)1.Se . ..., . . . • . , . . 0 • . ,. .; " " .. • . , . . • . .. , : • . • 0 . . . .. . . . • • ,,,Fyt-- 3- ••• • -- • • • 0 • .• . . .. • . ' • ,. . • • . • . . . . • .. - - • • . .. ' • - • . . . • .• • . . . . . • .7 . . , • • .. • . . • ' • ' •• - . . . • - -. . . . . • . 0 . . ‘ • I^V••• •••••0111•01 EFTA00183447 t CA ti W to EFTA00183448 (USAFLS) To: Subject: )1111.1(USAFLS), (USAFLS); (U F Follow-up point Here is my proposed response. Dear Jay: Assistant U.S. Attome From: Jay Lefkowitz [mailto Sent: Thursda Au ust 14, 2008 2:39 PM To: USAFLS) Cc: Subject: Re: Follow-up point Marie - In reviewing your December proposal, there are a couple of things I don't understand. What limits are placed upon individuals who proceed under 2255 as if "Mr. Epstein had been tried federally and convicted of an enumerated offense." In other words, what individuals would have this right? And would these individual only have this right if they proceeded exclusively under 2255? Also, to what enumerated offenses do you think would Mr. Epstein have to make constructive admissions of conviction? and how many such offenses? And against whom? Remember that while you may have investigated various offenses, he only plead guilty to certain state crimes. Finally, would paragraphs 8-10 of the September Agreement still be operative? I am trying hard to understand what you have intended by the December letter. Alex has says he thinks it benefits Jeffrey, and I am open to understanding it that way. But I would like some clarity on these issues. Thanks -- Jay 08/1412008 12:44 PM To > cc . -1c > Subiecl Follow-Lip point Hi Jay — I forgot to mention that I can no longer argue that the Court shouldn't force us to produce the agreement because we have already provided the victims with the relevant portion when I now understand from you that I have NOT provided them with the relevant portion. 1 EFTA00183449 Assistant U.S. Attorney The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to postmasterekirkland.com, and destroy this communication and all copies thereof, including all attachments. EFTA00183450 3 A EFTA00183451 U.S. Department of Justice United Slates Attorney Southern District of Florida DELIVERY BY FACSIMILE Jay P. Lefkowit; Esq. Kirkland & Ellis LLP Citigroup Center 153 East 53rd Street New York, New York 10022-4675 Re: Jeffrey Epstein Dear Jay: 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: August 13, 2008 As per your request, I am attaching several documents related to Mr. Epstein's performance of the Non-Prosecution Agreement. The first document attached hereto is the June 30, 2008 proposed Notification, which was hand-delivered to Jack Goldberger and Michael Tein shortly after Mr. Epstein entered his guilty plea. Following that, I have attached the July 9, 2008 response from Mr. Goldberger. I have highlighted two portions. The first is where Mr. Goldberger (presumably with the approval of Mr. Tein) approves of the portion of my proposed Notification that quotes directly from the U.S. Attorney's December letter to Lilly Ann Sanchez. The second portion is where Mr. Goldberger provides his interpretation of the Agreement, and nowhere mentions that he does not believe that the December letter is operative. I note that Mr. Goldberger's letter contains a notation showing that Mr. Epstein was provided with a copy. The third document I have attached is a copy of one of the notifications that was provided directly to a victim. Copies of all of the notifications have been provided to Mr. Goldberger, and neither he nor any other attorney for Mr. Epstein has ever stated that the letter misrepresents the Agreement between the parties or the benefit that the Agreement bestows upon the victims. The fourth document I have attached is a copy of a Declaration that I have filed in connection with the victims' lawsuit filed against the United States. This Declaration sets forth our understanding of the Agreement and again quotes from the U.S. Attorney's December letter. Messrs. Goldberger and Tein are aware of this Declaration and have filed copies of it in connection with their EFTA00183452 JAY P. LEFKOWITZ, ESQ. AUGUST 13, 2008 PAGE 2 OF 2 efforts to stay all of the civil litigation. Again, neither of them ever expressed to me — or to the Court — that it inaccurately describes the Agreement between the United States and Mr. Epstein. Please contact me tomorrow morning so that we can resolve this issue. Sincerely, R. Alexander Acosta By: cc: Chief, Northern Division Assistant United States Attorney EFTA00183453 U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave, Suite 400 West Palm Beach, FL 3340! (56!) 820-8711 Facsimile: June 30, 2008 IDENTIFIED S NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED STATES CODE, SECTION 3509(d) AND FLORIDA LAW, THE ATTACHED DOCUMENT IS TO BE TREATED AS CONFIDENTIAL AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTION WITH A LEGAL PROCEEDING. EFTA00183454 U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: June 30, 2008 NOTIFICATION OF IDENTIFIED VICTIMS On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf- 009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be followed by an additional six months' imprisonment, followed by twelve months of Community Control 1, with conditions of community confinement imposed by the Court. In light of the entry of the guilty plea and sentence, the United States has agreed to defer federal prosecution in favor of this state plea and sentence, subject to certain conditions. One such condition to which Epstein has agreed is the following: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." Initials of Jeffrey Epstein Initials of Jack Goldberger EFTA00183455 NOTIFICATION OF IDENTIFIED VICTIMS Junc 30, 2008 PAGE 2 OF 3 Through this letter, this Office hereby provides Notice that the individuals identified below are individuals whom the United States was prepared to name as a victim of an enumerated offense. Identified Individuals Dated: R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: ASSISTANT U.S. ATTORNEY ACKNOWLEDGMENT I have received this Notification from my attorney, Jack Goldberger, Esquire, have read it and discussed it with my attorney, and I hereby acknowledge that it accurately sets forth my understanding and agreement with the Office of the United States Attorney for the Southern District of Florida regarding the notification and rights of identified victims. I Initials of Jeffrey Epstein Initials of Jack Goldberger EFTA00183456 NOTIFICATION OF IDENTIFIED VICTIMS JUNE 30, 2008 PAGE 3 OF 3 understand that an exact copy of this Notification will be provided to each identified individual, except that the names of all other identified individuals will be redacted, and I hereby waive any evidentiary challenges to the introduction of a copy of this document—even in redacted form—in any judicial proceeding between any identified individual and myself. Dated: Jeffrey Epstein Witnessed by: Jack Goldberger, Esquire EFTA00183457 rit July 9, 2008 MM. Esq. Assistant United States Attorney United States Attorney's Office 500 South Australian Avenue 4'b Floor, Suite 400 West Palm Beach, Florida 33401 SENT VIA E-MAIL & FACSIMILE Re: Jeffrey E. Epstein Dear Ms. • JOSEPH R.A1TERBURY 'r SOCA. GOLDBERGER JASON S.WEISS Board Certified CriminaillialAttomey f Member of New Jersey & Florida Ban Thank you for your letter to me dated July 8, 2008 and the draft document dated, e-mailed and faxed to me at my office on June 30, 2008, styled "Notification of Identified Victims." I would like to address a few related issues. First, please note that we have several requests concerning any such notification. Specifically, we request that: (a) Any notification be sent to any individual by mail (or served upon their attorney, to the extent known), and we respectfully object to any service by hand, a method of service which carries the concomitant risk of conversations regarding the notification that potentially would place the federal authorities in a position of being advocates for civil litigation; (b) Any notification be effectuated by a separate mailing to each individual without the inclusion of any language that appeared on the second page of your June 30, 2008 memorandum; i.e. rather than including in each notification a large section listing "identified individuals" with redactions other than the name of the recipient (which we contend would be a clear and impermissible signal to any individual that the notification is a broad notification to numerous other alleged victims). at tlista simple one page notification directed only to the recipient, and limited to the information currently on the first page of your draft memorandum would-suiffee. One Clearlake Centre, Suite 1400 250 Australian Avenue South West Palm Beach, FL 33401 p 561.659.8300 f 561.835.8691 www.agwpa.com EFTA00183458 (c) You eliminate from any notification any language that is currently contained in the "acknowledgment" section of the June 30, 2008 memorandum; and (d) You supplement the notification with the Government's previously made representation that it is not vouching for the veracity of any claim by any identified individual. See Letter from J. Sloman to E. (10/25/07). Second, please note also that we do not understand your request that Mr. Epstein and his attorneys execute the rider / acknowledgment contained within your June 30 hand-delivered draft. Specifically, we do not believe that the Non-Prosecution Agreement requires Mr. Epstein's execution of any such additional stipulation. Because we want to ensure that Mr. Epstein continues to strictly comply with the letter of the parties' agreement, we respectfully ask that you explain why you believe that the Non-Prosecution Agreement requires execution of your stipulation. Our understanding of the Non-Prosecution Agreement is that it does not require Mr. Epstein to "acknowledge" anything not already contained within the four corners of the written agreement. The agreement certainly contains no written term obligating that he "waive any evidentiary challenge to the introduction of a copy" of any "Notification of Identified Victims" in "any judicial proceeding between any identified individual" and Mr. Epstein, as your memorandum currently requests. Further, please note that your June 30 stipulation, as drafted, is not limited to Section 2255 proceedings. Rather, your June 30 draft requires Mr. Epstein to waive evidentiary challenges in "any) judicial proceeding" - - which clearly exceeds the bounds of the parties' written agreement. Third, I would respectfully request that you provide me with the names of the "pro bono lawyers" who, you indicated to me at our June 30 meeting at my office, were intending to represent certain persons identified on your June 30 draft notification, as well as any knowledge that the Government has as to how they were selected, and what communications the Government has had with them to date. Finally, please know that it is Mr. Epstein's firm intent to fulfill strictly each term and condition of his Non-Prosecution Agreement with the Government. Nothing in this letter should be construed, however, as waiving any defense that may be available to Mr. Epstein under the parties' written agreement. I look forward to your response. Until then, I remain, trul yours, A. Goldberger cc: Jeffrey Epstein EFTA00183459 U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 3340! (561)820-8711 Facsimile: July 21, 2008 NOTIFICATION OF IDENTIFIED VICTIM NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED STATES CODE, SECTION 3509(d) AND FLORIDA LAW, THE ATTACHED DOCUMENT IS TO BE TREATED AS CONFIDENTIAL AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTION WITH A LEGAL PROCEEDING. EFTA00183460 U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561)820-8711 Facsimile: July 21, 2008 VIA UNITED STATES MAIL Missal* Re: Jeffrey Epsignagan NOTIFICATION OF IDENTIFIED VICTIM Dear Miss UMW By virtue of this letter, the United States Attorney's Office for the Southern District of Florida provides you with the following notice. On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf- 009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be followed by an additional six months' imprisonment, followed by twelve months of Community Control 1, with conditions of community confinement imposed by the Court. In light of the entry of the guilty plea and sentence, the United States has agreed to defer federal prosecution in favor of this state plea and sentence, subject to certain conditions. One such condition to which Epstein has agreed is the following: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes EFTA00183461 MISS S NOTIFICATION OF IDENTIFIED VICTIM luLy 21, 2008 PAGE 2 OF 2 of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." Through this letter, this Office hereby provides Notice that you,fl are an individual whom the United States was prepared to name as a victim of an enumerated offense. Should you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300. Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist in civil litigation; however, if you do file a claim under 18 U.S.C. § 2255 and Mr. Epstein denies that you are a victim of an enumerated offense, please provide written documentation of that