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EFTA01723879
IN RE:
JEFFREY EPSTEIN
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 thereinafter "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 ofTitle 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 ir. 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 I of 7
EFTA01723880
of Title 18, United States Code, Section 2423(b); and
(5)
knowingly, in and affecting interstate and foreign commerce, recruiting,
enticing, and obtaining by any means a person, knowing that the person had
not attained the age of 18 years and would be caused to engage in a
commercial sex act as defined in 18
§ 1591(cX1); in violation of Title
18, United States Code, Sections 1591(aX1) 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 be 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 NU-IIling 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
EFTA01723881
Terms of the Agreement:
1.
Epstein shall plead guilty (not nolo contendere) to the Indictment as
currently pending against him in the 15th Judicial Circuit in and for
Palm Beach County (Case No. 2006-cf-009495AX(XNO) charging
one (I) count of solicitation of prostitution, in violation of Fl. Stat. §
796.07. In addition, Epstein shall plead guilty to all 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 arc set forth in this
agreement.
4.
The terms contained in paragraphs I and 2, supra, do not foreclose
Epstein and the State Attorney's Office from agreeing to recommend
any additional chargc(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
EFTA01723882
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 arc 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
EFTA01723883
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.
"Ile 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 successful iy fulfills all of the terms and conditions
of this agreement, the United States also agrees that it will not institute any criminal charges
Further, upon CXCC LW
-co
irators of h stein, including but not limited to
agreement and a plea agreement wu
t e tate
rney's Office, the federal Grand Jury
investigation will be suspended, and all pending federal Onind 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 teams of this agreement have
been satisfied. Upon the successful completion of the terms of this agreement, ell
outstanding grand jury subpoenas shall be deemed withdrawn.
Page 5 of 7
EFTA01723884
By signing this agreement, Epstein asserts and certifies that each of these terms is
material to this agreement and is supported by independent consideration and that a breach
of any one of these conditions allows the United States to elect to terminate the agreement
and to investigate and prosecute Epstein and any other individual or entity for any and all
federal offenses.
By signing this agreement, Epstein asserts and certifies that he is aware of the fact that
the Sixth Amendment to the Constitution of the United States provides that in all criminal
prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further
is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court
may dismiss an indictment, information, or complaint for unnecessary delay in presenting
a charge to the Grand Jury, filing an information, or in bringing a defendant to vial. 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 r.ecessary 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 tho grand jury's investigation, it may be by way of an Information signed and Iliad
by the United States Attorney, and hereby waives his right to be indicted by a grand jury as
to any such offense.
//I
/1/
///
Page 6 of 7
EFTA01723885
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.
Dated:
Dated: 77a,„
Dated:
Dated:
Page 7 of 7
EFTA01723886
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.
Ft. ALEXANDER ACOSTA
Dated:
By:
Dated:
Dated:
/Lit/ 0 7
Dated:
[an ANN SANCHEZ, ESQ.
Pago 7 of 7
EFTA01723887
By signing this +iv-cement, Epstein asserts and certifies that the above has been read
and explained to hint Epstein hereby stales that he understands the conditions of this Non-
Prosecution Agreement and agrees to comply with them.
UNITkl STATES ATTORNEY
Dated:
BY:
Dated:
JEFFREY EPSTEIN
Dated:
Dated:4- 21*- CP-
ESQ.
Page 7 of 7
EFTA01723888
IN RE:
JEFFREY EPSTEIN
ADDENDUM TO TED3 NON•PROSECUTION AGREEMENT
IT APPEARING that the panics seek to clarify certain provisions of page 4, paragraph 7
of the Non•Ptosecution 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 patty, 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.
7B.
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 fres of the attorney
representative selected by the independeirt third party. This provision, however, shall not
obligate Epstein to pay the fees-and costs of contested litigationitied against hiMillus,
_
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 comaine.d. ins 2255 to bear the costs of the attorney
representative, shall cease.
EFTA01723889
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.
Re ALEXANDER ACOSTA
Dated:
By:
Dated:
Dated:
Dated:
EFTA01723890
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 Not:-
Prosecution Agreement and agrees to comply with them.
Dated:
By:
Dated:
JEFFREY EPSTEIN
Dated:
Dated:
COUNSEL TO JEFF
Y EPSTEIN
EFTA01723891
By signing this Addendum, Epstein 439013 and certifies that the abovo has been read and
explained to him. Epstein hereby states that ho understands the clarifications to the Non-
Prosecution Agreement and agrees to comply with them.
Dated:
Dated:
Dated:
Dated: kali'
JEFFREY EPSTEIN
EFTA01723892
Dec-OT-OT
Bil: 65pm
F torfotti et -*I to Burnett
•
308TBBBt01
T-BBB
P.003/004
F-ITS
Allinostioa
I. leffreyt Epstein do hereby Era= the Nce-Prostantion Agreement amlAcIdateluat to
Stunt Stu, October 34 2007.
.../2-Ahci—
r
EFTA01723893
IN RE:
JEFFREY EPSTEIN
NON•PROSECUTION AGREEMENT
IT APPEARING that the City of Palm Beach Police Department and the State
Attorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter,
the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey
Epstein (hereinafter "Epstein");
IT APPEARING that the State Attorney's Office has charged Epstein by indictment
with solicitation of prostitution, in violation of Florida Statutes Section 796.07;
IT APPEARING that the United States Attorney's Office and the Federal Bureau of
Investigation have conducted their own investigation into Epstein's background and any
offenses that may have been committed by Epstein against the United States from in or
around 2001 through in or around September 2007, including;
(I)
knowingly and willfully conspiring with others known and unknown to
commit an offense against the United States, that is, to use a facility or means
of interstate or foreign commerce to knowingly persuade, induce, or entice
minor females to engage in prostitution, in violation of Title 18, United States
Code, Section 2422(b); all in violation ofTitle 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 moans 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(O, with minor females; in violation
Page I of 7
EFTA01723894
of Title 18, United States Code, Section 2423(b); and
(5)
knowingly, in and affecting interstate and foreign commerce, recruiting,
enticing, and obtaining by any means a person, knowing that the person had
not attained the age of 18 years and would be caused to engage in a
commercial sex act as defined in 18 U.S.C. § 1591(0)(1); 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 certai❑
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.
A en 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
EFTA01723895
Terms of the Agreement:
1.
Epstein shall plead guilty (not cold contenders) to the Indictment as
currently pending against him in the 15th Judicial Circuit in and for
Palm Beach County (Case No. 2006•cf-009495AXXXMB) charging
one (I) count of solicitation of prostitution, in violation of Fl. Stat. §
796.07. In addition, Epstein shall plead guilty to an Information filed
by the State Attorney's Office charging Epstein with an offense that
requires him to register as a sex offender, that is, the solicitation of
minors to engage in prostitution, in violation of Florida Statutes Section
796.03;
2.
Epstein•shall make a binding recommendation that the Court impose a
thirty (30) month sentence to be divided as follows:
, (a)
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
(b)
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 Tenn 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 cor.tained in paragraphs I 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
EFTA01723896
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 1J.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 arc not to be construed as an admission of any
criminal or civil liability.
9.
Epstein's signature on this agnxment 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
EFTA01723897
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 cbligation 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 charges
an
'
anpotential co-cons yators of E stein, including but not limited to
upon exe
agree
n an ape agreement wi
ey's Offi
Fnt}te
ce, 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
EFTA01723898
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 o f the fact that
the Sixth Amendment to the Constitution of the United States provides that in all crimir.al
prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further
is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court
may dismiss an indictment, information, or complaint for unnecessary delay in presenting
a charge to the Grand Jury, filing an information, or in bringing a defendant to sial. 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 4S(b) of
the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the
United States to a speedy trial or to bar the prosecution by reason of the running of the statute
of limitations for a period of months equal to the period between the signing of this
agreement and the breach of this agreement as to those offenses that were the subject of the
grand jury's investigation. Epstein further asserts and certifies that he understands that the
Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all
felonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees
and consents that, if a prosecution against him is instituted for any offense that was the
subject of the grand jury's investigation, it may be by way of an Information signed and filed
by the United States Attorney, and hereby waives his right to be indicted by a grand jury as
to any such offense.
/I/
//I
Ill
Page 6 of 7
EFTA01723899
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.
Dated:
Dated: 74/9
—
•
Dated:
Dated:
Page 7 of 7
EFTA01723900
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.
Dated:
By:
Dated;
Dated: 7 12-tt 107
Dated:
JEFFREY EPSTEIN
RAL
EFC0t
akj.d
ESQ.
Pago 7 of 7
EFTA01723901
By signing this agreement, Epstein ascots and certifies that the above has been read
and explained to hint Epstein Ir.-lc-by states that he understands the conditions of this Non-
Prosecution Agreement and agrees to comply with them.
Dated:
Dated:
Dated:
Dated:4-n
Br
JEFFREY EPSTEIN
ESQ.
Page 7 of 7
EFTA01723902
IN RE:
JEFFREY EPSTEIN
IT APPEARING that the panics 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 objection., 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 •feeaand costs of contested litigationftled against hintaus,
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 2;55 to bear the costs of the attorney
representative, shall cease.
EFTA01723903
By signing this Addendum, Epstein asserts and certifies that the above has been read and
explained to Mm. Epstein hereby, states that he understands the clarifications to the Non.
Prosecution Agreement and agrees to comply with them.
Dated:
By:
Dated: /
Dated:
Dated:
EFTA01723904
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.
Dated:
By:
Dated:
Dated:
Dated:
JEFFREY EPSTEIN
COUNSEL TO JEFF' -Y EPSTEIN
EFTA01723905
By signing this Addendum, EpOntn assets and certifies that the above has bean mad and
explained to him. Epstein hereby states that ho understands the clarifications to the Ncm-
Prosecution Agreement and agrees to comply with them.
Dated:
BY:
Dated:
Dated:
Dated:
JEFFREY EPSTEIN
LILLY ANbPSANCHEZ, ES Q:
EFTA01723906
Ctc-97-01
04:5Spn
F roc-Fowl sr-Otto
rn t t
Affirms:Dm
396789;701
7-266
P C83/004
F-976
Alit*
Epstein do batby zoliffutt theNan-Prownun Agretnun a [ma Added= tO
r•m_ da:cd October 30, 2007,
EFTA01723907
IN RE:
JEFFREY EPSTEIN
1
• NON-PROSECUTION AGREEMENT
I
I
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 IS, United States
Code, Section 2422(b); all in violation ofTitle 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(1), 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 moans 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(O, with minor females; in violation
Page I of 7
EFTA01723908
of Title 18, United States Code, Section 2423(b); and
(5)
knowingly, in and affecting interstate and foreign commerce, recruiting,
enticing, and obtaining by any means a person, knowing that the person had
not attained the age of 18 years and would be caused to engage in a
commercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title
18, United States Code, Sections 1591(a)(I) and 2; and
IT APPEARING that Epstein seeks to resolve globally his state and federal criminal
liability and Epstein understands and acknowledges that, in exchange for the benefits
provided by this agreement, he agrees to comply with its terms, including undertaking certain
actions with the State Attorney's Office;
IT APPEARING, after an investigation of the offenses and Epstein's background by
both State and Federal law enforcement agencies, and after due consultation with the State
Attorney's Office, that the interests of the United States, the State of Florida, and the
Defendant will be served by the following procedure;
'IT LEREFORP., 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 shalt 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 Agtecthent.
A_fter timely fulfilling all the terms and conditions of the Agreement, no prosecution
for the offenses set out on pages l 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
EFTA01723909
"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-cf•009495AXXXME) charging
one (1) count of solicitation of prostitution, in violation of Fl. Stet §
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)
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
(b)
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
EFTA01723910
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 SouthemDiatriet
of Florida over his person and/or the subject matter, and Epstein**.
his right to contest liability and also waives his right to contest daniages
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 arc 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
EFTA01723911
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 carted 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 :o 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 arid conditions
of this agreement, the United States also agrees that it will not institute any criminal charges
i
'
anpotential co-co
irators of E stein, including but not limited to
or
Further, upon exec to
agreement an ape agreement wi
e
t
ey'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 ail 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
EFTA01723912
By signing this agreement, Epstein asserts and certifies that each of these terms is
material to this agreement and is supported by independent consideration and that a breach
of any one of these conditions allows the United States to elect to terminate the agreement
and to investigate and prosecute Epstein and any other individual or entity for any and all
federal offenses.
By signing this agreement, Epstein asserts and certifies that he is aware of the fact that
the Sixth Amendment to the Constitution of the United States provides that in all criminal
prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein Rather
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.
Page 6 of 7
EFTA01723913
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.
Dated:
By:
Dated: 77P/9
—
Dated:
Dated:
Page 7 of 7
It
EFTA01723914
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.
Dated:
By:
Dated;
Dated: 7 P -tt 10 7
Dated:
Laity ANN SANCHEZ, ESQ.
Pago 7 of 7
EFTA01723915
By sipping 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.
Dated:
By:
Dated:
JEFFREY EPSTEIN
Dated:
Dated:4M
ESQ.
Page 7 of 7
EFTA01723916
IN RE:
JEFFREY EPSTEIN
IT APPEARING that the parties seek to clarify certain provisions of page 4, paragraph 7
of the Non-Prosecution Agreement (hereinafter "paragraph 71, that agreement Is modified as
Vol lows:
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 preparo 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 litigatioa.ftled against hits , nig,
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 ins 2255 to bear the costs of the attorney
representative, shall cease.
EFTA01723917
By signing this Addendum, Epstein asserts and certifies that the above has been tad and
explained to him. Epstein hereby, states that he understands the clarifications to the Non-
Prosecution Agreement and agrees to comply with them.
Dated:
By:
Dated: /A' 74
Dated:
Dated:
I
EFTA01723918
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. Noe-
Prosecution Agreement and agrees to comply with them.
Dated:
By:
Dated:
Dated:
Dated:
JEFFREY EPSTEIN
EFTA01723919
By signing this Addendum, Epstein asserts and unifies that the above has been read aml
explained to him. Epstein hereby states that he understands the clarifications to the Non.
Prosecution Agreement and agrees to comply with than.
Dated:
BY:
Dated:
Dated:
Dated: IfraTh
A. MARIE YILLAFAgIA
JEFFREY EPSTEIN
LILLY A
MCKEE, ESQ:
EFTA01723920
Dac-OT-OT
04:550
F
AThrouggia
3051667101
T-;66
P.003/304
F-ITS
Jeffrey Li. Epstein do hereby meffutta the hloo-hosee at= AgtettateLt fag Adderatma
vs= dated Octabor 30, 2007.
EFTA01723921
toe
rN
-
IN RE:
JEFFREY EPSTEIN
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 ofTitle 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. 12423(1), 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 I of 7
EFTA01723922
of Title 18, United States Code, Section 2423(b); and
(5)
knowingly, in and affecting interstate and foreign commerce, recruiting,
enticing, and obtaining by any means a person, knowing that the person had
not attained the age of 18 years and would be caused to engage in a
commercial sex act as defined in 18 U.S.C. § 1591(c)(I); in violation of Title
IS, 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 Agnxment.
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
EFTA01723923
Terms of the Agreement:
1.
Epstein shall plead guilty (not nolo contendere) to the Indictment as
currently pending against him in the 15th Judicial Circuit in and for
Palm Beach County (Case No. 2006-cf-009495A)OC<M3) charging
one (I) count of solicitation of prostitution, in violation of Fl. Stat. §
796.07. In addition, Epstein shall plead guilty to an Information filed
by the State Attorney's Office charging Epstein with an offense that
requires him to register as a sex offender, that is, the solicitation of
minors to engage in prostitution, in violation of Florida Statutes Section
796.03;
2.
Epstein shall make a binding recommendation that the Court impose a
thirty (30) month sentence to be divided as follows:
(a)
Epstein shall be sentenced to consecutive terms of twelve (12)
months and six (6) months in county jail for all charges, without
i
any opportunity for withholding adjudication or sentencing, and
without probation or community control
in lieu of
;
imprisonment; and
I
!
(b)
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 chargcXs) 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
EFTA01723924
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
jurisdictioi)of the United States District Court for the Southern District
of Floridivaveithils person and/or the subject matter, and EpstelnWabier
his right to contest liability and also waives his right to contest ditinages
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
EFTA01723925
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 charges
a ainst an
otential co-cons Unto's. of E stein, including but not limited to
. or
Further, upon exe
s
ii
i
agree
n
agree ent
ey's Office, the federal Grand Jury
investigation will be suspended, and all pending federal Grand Jury fubpoenas 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
EFTA01723926
By signing this agreement, Epstein asserts and certifies that each of these terms is
material to this agreement and is supported by independent consideration and that a breach
of any one of these conditions allows the United States to elect to terminate the agreement
and to investigate and prosecute Epstein and any other individual or entity for any and all
federal offenses.
By signing this agreement, Epstein asserts and certifies that he is aware of the fact that
the Sixth Amendment to the Constitution of the United States provides that in all criminal
prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further
is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court
may dismiss an indictment, information, or complaint for unnecessary delay in presenting
a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein
hereby requests that the United States Attorney for the Southern District of Florida defer such
prosecution. Epstein agrees and consents that arty 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.
/ / /
III
Pagc 6 of 7
EFTA01723927
By signing this agreement, Epstein asserts and certifies that the above has been read
and explained to him. Epstein hereby states that he tmderstands the conditions of this Non-
Prosecution Agreement and agrees to comply with them.
Dated:
By:
Dated: 77t4/9" --
Dated:
Page 7 of 7
EFTA01723928
By signing this agreement, Epstein Men and certifies that the above has been read
and explained w him. Epstein hereby states that he understands the conditions of this N on-
Prosecution Agreement and agrees to comply with them,
Dated:
By:
Dated:
Dated: 7 / 2-91 0 7
Dated:
*At
RALD EFCOl7RVJESQ.
Page 7 of 7
EFTA01723929
By signing this agreement, Epstein asserts and certifies that the above has been read
and explained to him. Epstein hereby Mates that he understands the conditions of this Non-
Prosecution Agreement and egrets to comply with them
Dated:
By:
Datcd:
JEFFREY EPSTEIN
Dated:
Dated:
ESQ.
Page 7 of 7
EFTA01723930
IN RE:
JEFFREY EPSTEIN
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 litigaticutfiled against hiM._Th_us,
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 foes and costs such as those contained in s 2255 to bear the costs of the attorney
representative, shall cease.
EFTA01723931
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.
Dated:
By:
Dated: /At ritl -
Dated:
Dated:
EFTA01723932
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.
Dated:
By:
Dated:
Dated:
Dated:
JEFFREY EPSTEIN
RALD LEFCOtlRTI ESQ.
COUNSEL TO JEFF
Y EPSTEIN
EFTA01723933
By signing this Addendum, Epstein MOM and certifies that the above has been read and
explained to him. Epstein hereby states that ho undershancis the clarifications to the Non-
Prosecution Agreement and agrees to comply with than.
Dated:
Dated:
Dated. /Yarn'
BY:
JEFFREY EPSTEIN
ATTORNEY FOR JEFFREY BPSTED4
EFTA01723934
308788920I
-08S P.003/004
F-9/8
Affiroadon
I. hem% Web do besby midi= thoNouTrostoutiOn Avow:lad ondAddoodum
mune decd October 30, 2007.
EFTA01723935
YOU
DCA: W
YOUR RESIDENCE ADDRESSr cbiclude Name of
Subdivision, Apartment Complex arid Number,
Mobik.Nome-Park and Lot Numbers_iffipplicable):
•
,•
•
.
' • " -j etfikeeS
For Mouth
STATE OP PtOISA
.:•
" dl if'
••
Asa
EIVIPLOTBRi
SUPERVISOR'S
EMPLOYER'S ADD
2•10 .
$ 61
wa4
thi aciadt la • 32Afico .
. (Provide physical location—Watt Office Box)
TELEPHONE No.VC1
3.4:240
'
CELLULAR TELEPHONE No.
4301 1150
PAGER No.
Vehicle Make/Model/Tear/Tag I:
EMPLOYER'S TBLEPHONENo.
CELLULAR TELEPHONE No..
c %•••
ke'r
PAGER No.
,
EMPLOYER EMAIL:
• •
•
•
•
-' •
•••
$
tot)
(Gran Amieuncy ,
.z-
• 4-.42; •-
•
;VI:10,0M
Full.timeM_ Part-time
Hours•Woryter
lae:ri
.
.
.
Additional (r) employinenriniorMilloilt-
—“i••••-•
4'1
•:
t•
;
• •
4•:.
• • 4 ' tr ."7 4:
4...e'"
•
.
.
..
...
.
_
Lis full names, ages, and your relationship to
as who resided at -our reSidenced ring this monthi. .•..,:. ..... , -••;:-4....?...• 4 .
e a L-.- 63 ^ et)V--ig —1, C—Sr
—2'S' ri At
:Pk '..
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1.0 •
'7„,:4 ' ri.!. • •.: ft.:n.7.'45.; .1:•• Kr i
: • i"ft -•1 -
I
Stave you consumed alcoholic beverages?
Have you used or bought illegal drugs or controlled substances?
Have you attended educational, vocational classes or mental
health, drug, alcohol, therapy, or self-improvement programs?
(If yes, circle which one)
-
Have you been arrested or bad any contact with law enforcement during the last month?
If yes, explain what happened on separate sheet or paper, attached to report.
If you went into debt for any reason, explain:
If not working, give reason and source of income:
If you have any questions or problems to discuss with your Officer, explain:
rf i
:•
•
• 411
If monetary obligation owed, amount paid this month:
S
• • 't
Receipts are available through your probation officer. DO NOT SUBMIT CASH OR PERSONAL cliECKSF
"44 t • .0. •
Make money order payable to the Department of Corrections. -
• .
• .
If monetary obligation owed and no payment made, give reason and date when payment will be wades
•••:;'•:,•:••:••
4:!..." • •
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s 1 :
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•••: r..••••V •,•:•,.
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...5:A.*:.•:!;••••••?-4iti
•
Offici
Signature of Officer
E
Date WMR Received:
Dote WMR Due:
Comments:
5-A a
I
I certify the above to be true and Complete:
Your Signature:
Mailing Address.
State:
.
Zip:
E.Mail Address:
(if applicable)
iakti(46;:
•
•
t
•
erns-
EFTA01723936
ii:i
'ars o'd fest
EFTA01723937
.• •
YOUR NAME;
Dah Urn
-
Itudade Name of
Subdivision, Apartment CoMpier
.
0 .41477'6er.
Mobik Home Park and f
f applicable):
Ifre.41—f
ia•-r
.
•
• " ;
, •
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••
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%I..
Y. tt:44:14
.,
• .1 ,,!h:t.1?.,.•
,
•
STATE OPPLORBDA
. ;
DEPARTMENT OP C0RRECIT0NS:
EMPLOYER:. •
r )
SUEERYISCHUS NAME: 1-Abo-tb,.
I
Officer's Name:
For Mouth Ending:
Date/Time submitted:
EMPLOYER'S' ADDRESS:
•
-Le
- - : Anrvi.ein
P"'
"
)3 4.1 -J- • - •
-
( ..frr-c,
ilikbp,
EMPLOYER'STELEPHONE No. 5615 00 CY
(Provide physical Iticadon
Office Box)
TELEPHONE No. SI .
34 z!
CELLULAR TELEPHONE No. iii-4 of —
12
PAGER No.
•.
.
.
Vehicle Make/Model/Year/TIO:
CELLULAR TELEPHONE No.
PAGER No.
EMPLOYER EMAIL:
—
$ *JO k
(Gnats Amount)
Full time )6
Part-time
Hours Worked
Additional (214) employment information:
List full names, ages, and yourxtlstionship to all persons who resided at o r residence during this month:
—
•
. .
bye you consunied alcoholic beverages?
Haveyou used or bought illegal dings or controlled substances?
Have you attended educational, vocational classes or mental
health, drug, alcohol, therapy, or self-improvement programs?
(If yes; circle which one)
• •
.
.
Have you been arrested or had any contact with law enforcement during the last month?
If yes, explain whit happened on separate sheet of paper, attached. to report.
If pm: went into. debt for any reason, explain:
. .
If not working, give reason and source of income:
If you have any questions or problems to discuss with your Officer explain: •
YES
O
• If monetaryobligation owed, ambunt Pairithis month: •' "S
.
.
Receipts are available theinigh your probation officer, I00 NOT SUBMIT CASH OR PERSONAL CHECKS!
'
Make money order payable to the Department of Corrections.
If monetary obligation owed and no payment made, give reason and date when payment will be made:
Official Use Only:
Signature of Officer Receiving Report:
Date WIVIR Received:
Date WMR Due:
Comments:
C
I certify the above to b true • nd
Your Signature:
MailloWdress:
Cc,
City: VA &ea. p"
State: Cc-
Zip: 3n t •
E-Mall Address: 1P...-e-006:re .05
—
'CA
(if applicabk):-
,
EFTA01723938
YOURA.IAIVIg;
DC& IN
YOUR RESIDENCE ADDRESS: (Include Name of
Subdivision, Apartment Complex and Number,
AI bile Home Pqr,k apd Lot Nunber, if applicable):
S. Fitt &Mow
air) Poach IR-
113
DEPARTMENT
CORRECTIONS
ifficers Name:
For Mouth
`C
Date/Time submitted:
tern
EmpLoyER:F5F
(Provide physical location —NOT Post Office Box)
TELEPHONE No. (055-Map
CELLULAR TELEPHONE No.60
I
-Li 5(09
PAGER No.
•
Vehicle iVIalte/ModelfYear/Tag if:
SUPERVISOR'S NAME -
EMPLOYER'S ADDRESS:
250 S. taatrom Ave Sum Vie ft
WS-teihn &vdtft
EMPLOYER'S TELEPHONE No:a
CELLULAR TELEPHONE No.
PAGER No.
EMPLOYER EMAIL:
$ ?Pin'
(Gross Amount)
Full time
Part•titne
Hours Worked
Additional (D') employment information:
List full names, a es, and your relationship to all persons who resided at your resi
• g this month:
S
- 3/
ZG-
• 2Z
(„e
Qy. Lett.,
lave you consumed alcoholic beverages?
Have you used or bought illegal drugs or controlled substances?
Have you attended educational, vocational classes or mental
health, drug, alcohol, therapy, or self-improvement programs?
(If yes, circle which one)
•
Have you been arrested or bad any contact with law enforcement during the last month?
If yes, explain what happened on separate sheet of paper, attaelied to report.
If you went into debt for any reason, explain:
YES
O
NO
Er
If not working, give reason and source of income:
If you have any questions or problems to discuss with your Officer. explain.
If monetary obligation owed, amount paid this month:
$
Receipts are available through your probation officer. DO NOT SUBMIT CASH OR PERSONAL CHECKS!
Make money order payable to the Department of Corrections.
If monetary obligation owed and no payment made, give reason and date when payment will be mode:
Official Use Only:
Signature of Officer Receiving Report:
Date WMR Received:
Date WMR Due:
Comments:
(635kN
sji
I certify the above to be true and complete:
Your Signature:
Mailing Address:
City: V P
State: R.
&Mall Address:
Wapplicable)
EFTA01723939
o \ciAlo RP) bc4A'
EFTA01723940
COUNT #1
On or about Wednesday, August 19, 2009, at approximately 1635 hours,
noWc
f ) the Palm Beach Police Department was advised that Jeffrey Epstem was w
and on South Ocean Blvd in the area of Brazilian Avenue. Based on
p
p
s
t
e
h
rior conversations with Florida Department of Corrections Probatio
he made contact with him to discuss the possibility that this was a violation o
m s order of community control.
Wi
t this was a violation and that based on
.
.06
Jeffre Epstein should
made contact with Probation Officer Ill
who advised that in his
should be taken into custody and arrested.
advised
that he needed a
copy of the Order of Community Control in hand prior to
e arrest. At 4:42
p.m.,
received the order via email.
reviewed the order and
respo
to e area where Epstein was observed
g•
advises that at
approximately 4:53 p.m., he observed Epstein walking southboun on
uth Ocean Blvd
near the intersection of Barton Avenue. At 4:55 p.m.
requested a marked
unit respond to C k Avenue and South Ocean Blvd the ocation
ere he made contact
with Epstein.
observed that Epstein was wearin dark sweat pants and a
white t-shirt, so noting that was sweating profusely. As
approached, he
identified himself and began an on-scene investigation which e ocumented in the CAD
system, CAD #092310146, attached.
Epstein advised
..that
his probation officer, MEI
had advised him he
was allowed to
to an from work, and that he was now en-route to work. He further
questioned Epstein as to why he was not on a direct route to his work, and al
advised that his work address was on Australian Avenue in West Palm Beach.
was now walking south when he had just been walking north. Epstein stated that he had
walked to the area of the North Bridge, but considered it too busy, therefore he was
returning to the Middle Bridge to cross into West Palm Beach.
Note: At this point Jeffrey Epstein was 1.4 miles north from his
home, and 6.5 miles east from his office. At 4:45 in the afternoon,
with the average mile walk taking approximately 20 minutes a
mile, Jeffrey Epstein would have made it to his office sometime
around 7:00 p.m., which would most likely be after closing.
it l eft Palm Beach business address, he made contact wit S
rvisor
to
noticed that Epstein's location was not on any direct route from his residence
confirm the information provided to him b Probation Officer
description of the ongoi
events,
made contact wi
not speak directly to
at this time, ut”
s
advi
t t
given
permission for Epstein to walk to work, that this time o day was consistent with Epstein
EFTA01723941
traveling to work, and that even though Epstein was clearly not on a direct route to the
West Palm address, she
did not consider this a violation of his community
weekl scill.nd
I was advi
Epstein should have his schedule on his
n.
control.
question
as to what details were provided on Epstein's
noticed that Epstein did not have any schedule on his person.
did
not
ve e schedule to review either he was receiving his information
m
via
phone. Based on the information
was provided by
wo
not
consider Epstein for a Violation o
0
OIL
India
-.. c
sosior
contact with E
in he was in corance with the terms
his probation.
then questioned
as to why he could be so far off a direct
On 8/20/09,
made contact with Probation Officer
She advised
route and how mucdetail was included in
weekly schedule. She advised there was
order to avoid ongoing problems with Epstein that he wou
need a co
oil weekly
not much detail on the schedule or about the route.
advised
that in
schedule and these schedules would have to be more detailed.
further
advised
that based on based on his observations, this was a c car violation of his
community control, and that absent
direct involvement yesterday, Epstein would
have been arrested for the VOP.
advised
that she would meet with her
supervisor and attempted to provide pstein's sc
u e to him as well as improve the
detailed information contained on the schedule.
A review of the daily Department of Corrections log that is submitted by Epstein,
indicated that he was at his office from 8:00 am to 10:00 pm that date. It appears that he
falsified the document, because according to the above incident he was first walking to
work at 4:45 p.m., which was totally in conflict with him already being at work at 8:00
am. Additionally the statement made by his then probation officer that Epstein usually
goes to work that time is also false and contradictory to his daily logs. A review of the
daily logs from the time he was released from jail to the date of his incident revealed that
one day he left for work at 2:00 pm, and every other day he left prior to noon, with a
majority of the days indicating between 9am and 10am.
COUNT #2
Jeffrey Epstein, met 1.11
pstein,
and Jeffrey Epstein's
1
On August 27, 2009,
a FAA Certified Pilot who is in the employ of
0u
bodyguard
at the West Palm BeacAirr
i l
l •Puring a deposition of I=
onOctober
. 2009, he testified to this flight. He stated that he flew Jiii
,
pstem,
and
to the Sikorsky's Helicopter Company
located at 1
0 cc me wy, Jupiter, .
advised they stayed at the plant
for 3 -4 hours, receiving a tour of the plant.
indicated that the Sikorsky
Company was looking for investors for a new e copter they were developing.
According to Epstein's pilot, M.,
they left for the excursion at 9:00 a.m., and did not
go to the Science Foundation, alocation where Epstein is required to be at as his place of
business while under community control. There is no indication the Epstein ever worked
for the Sikrosky Company which is 28 miles north west of his residence. Epstein
EFTA01723942
traveled by air transportation to a place other then authorized via helicopter in violation
of the terms of his community control.
Up reviewing documents in the probation file it indicated that the date in question was
August 27, 2009. The daily log for that date indicated that he went to the Palm Beach
is
Ai ort at 8:00 and returned at 2:00 pm. According to an email from his assistant
to Probation, he went to the Sikorsky plant for business. This was a violation o
s community control that allows him to go to his business at 250 Australian Way, there
is nothing indicated in the file or court file that he does business with Sikorsky and was
allowed to fly to their manufacturing plant.
COUNT #3
On September 14, 2009,
a FAA Certified Pilot who is in the employ of
Jeffrey Epstein, met with e
y
stein and
at the West Palm Beach
Airport. During a deposition of
on cto er
2009, he testified to this
flight. He stated that he flew Je
y pstem and
is helicopter leaving
the county of Palm Beach and landing in Miami- a e ounty, onda. The pilot
left Epstein and
in Miami, and it was unknown to him when or ow
they returned to a
eac .
e ey Epstein, left the county, via air transportation in
violation of the terms of his community control.
Up reviewing documents in the probation file it indicated that the date in question was
September 14, 2009. The daily log for that date was not supplied and is missing;
however, it appears that there was no court order allowing Jeffrey Epstein to fly out of
the county that day, and according to the pilots deposition he left Epstein and
in Miami and it was unknown to him how or when he returned.
COUNT #4
On or about September 15, 2009, and through September 16, 2009, Jeffrey Epstein, a
registered sexual offender, DOC#W35755, conspired with others to perpetrate a scheme
for the sole purpose of intimidating a victim who was sexually battered by him by
making contact with the victim in violation of the terms of his community control.
On Se tember 15, 2009, the day before the deposition of Jane Doe #4, her attorney
and counsel for Jeffrey Epstein entered into a written stipulation in
w c it was agreed that "Jeffrey Epstein will not attend tomorrow's deposition of his
client, Jane Doe No. 4". Under no circumstances would he (Epstein) "be seen by his
client".
On September 16, 2009, Jane Doe #4 appeared for deposition in a civil matter where she
is suing Jeffrey Epstein. She appeared at 1:00 p.m. at 350 Australian Ave. South, Suite
115, West Palm Beach, Florida and did so without the fear or being confronted by
E steinpursuant to the court stipulation. However, when the Victim and Attorney
were in the lobby of above mentioned office building, they crossed paths with
EFTA01723943
Jeffrey Epstein and his bodyguard. At that point, Epstein stopped walking and began to
stare at the victim and ultimately intimidated the Victim Jane Doe #4, in violation of
Florida State Statute 914.22. Jane Doe No. 4 was terrified, began crying and ran outside
of the building. Epstein smirked at her and walked away. As result of this incident, Jane
Doe No. 4 was unable to give her deposition.
On that date Epstein through a sworn affidavit stated that he was aware of the protective
motion and the deposition that was to take place at 1:00 p.m., he stated that he had a
video feed of the deposition set up at his house and left work at 1:04 p.m., with his driver
!l
His daily probation log for that date indicated that he was at work, which is the
ion of the deposition from 10:00 a.m., to 5:30 p.m., and did not go home until then.
COUNT #5
On or about November 24, 2009, Jeffrey Epstein, a registered sexual offender,
DOC#W35755, intentionally confronted Jane Doe #3, a victim who was sexually battered
by him by making contact with her in violation of the terms of his community control.
On October 30, 2009 Counsel for Jeffrey Epstein scheduled an IME examination of
sexual battery victim Jane Doe #3, indicating the date, time and location where she was
to appear for her IME pursuant to the ongoing civil litigation against Epstein.
On November 5, 2009, the Court entered into a Joint agreed order, which stated that the
Defendant Jeffrey Epstein will not attend the IME's or make himself seen by the
Plaintiff's on the date of their IME's.
On November 24, 2009, Attorney
and her client Jane Doe #3, a victim of
Jeffrey Epstein's appeared for her IM
I Rlgry c started at 9:00 am and was supposed to
conclude at approximately 5:30 p.m. The location of the IME was 250 S. Australian
Ave., West Palm Beach, Florida.
Attorney
advised that, she and her client (the Victim) arrived at the above
location, on
e above mentioned date and time and made them-selves available for the
above mentioned "IME". Attorney
also advised that, her client is a cigarette
smoker and took a number of cigarette r
s during the "IME".
It was during one of these breaks, at about 4:15pm, that Attorney
advised that,
she and Jane Doe No. 3 (the Victim) walked outside of the buildinne
e "IME" was
being conducted to smoke a cigarette. While outside, Attorney
advised that, she
observed Jeffrey Epstein exit the same building through a door c osest to where they were
sifting on a bench.
Attorney
advised that, she and Epstein made eye contact at which time he glared
at her and continued to walk in their direction. When it was obvious that Epstein was not
going to stop, Attorney
advised that, she stood up and placed herself between
Epstein and her client (the Victim). Attorney
continued to describe how Epstein
EFTA01723944
made no attempt to alter his direction and in fact came as close as 5-7, feet crossing in
front of her client (the Victim).
Attorney
also advised that, when Jane Doe No. 3 (the Victim) saw Epstein, she
yelled out, "O God No!" and began to scream. She continued yelling "No! No! No!"
and began to cry out loud. Attorney
advised that, she quickly removed her client
(the Victim) from the area, away om
pstein and eventually into the lobby of the
building where she collapsed into a chair.
After numerous attempts to calm Jane Doe No. 3 (the Victim), Attorney
advised
that, she was still visibly distraught and would not be able to proceed with the
examination which was terminated.
On that date Epstein stated that he was aware of the protective motion and the deposition
that was to take place all day at his attorney's office. His daily probation log for that date
indicated that he was at his attorney's office at Bayon and Olive (Critton's Office) from
3:30 p.m., to 6:30 p.m. This would indicate that he made a special trip back to the office
where the deposition was going on and for lack of better terms bumped into Joane Doe
#3. This shows that his travels back to that location was intential and in conflict with his
probation log.
COUNT #6
On Wednesday Februa
3 2010 at 10:20 a.m. Florida State Licensed Investigators
conducted a surveillance of Jeffrey
Epstein. He was o serve
eaving his rest ence in his black Escalade, driven by his
bodyguard
They were observed to leave the County of Palm Beach and
drive direct y toteOcean 15 hotel located at 1500 Collins Avenue, Miami Beach,
Miami-Dade County, Florida. Epstein was observed exiting his vehicle and greeting
Attorney Alan Dershowitz. They remained at the hotel for ten minutes, leaving with
Dershowitz and traveling to the Intercontinental Hotel located at 201 South Biscayne
Blvd., Miami, Florida.
The Intercontinental Hotel was inundated with media and
security as the hotel was the host hotel for the New Orleans Saints who were playing in
the Super Bowl on the following Sunday. Jeffrey Epstein remained at that location until
1:40 p.m., when he was observed leaving the front of the hotel by himself. He was
picked up by his bodyguard in the Escalade and they drove North back to his residence.
On that day Epstein called probation advising his officer that he needed to go to
Walgreens for Bengay, nothing indicates on his daily log that he ever went to a
Walgreens. The daily log for that day reflects he was at probation at 8:00 a.m., which
was no true as he was under surveillance since 7:00 am. Additionally, the log indicates
that he went to Miami at 9:00 am, and returned home at 1O:00 pm. The facts are that he
left for Miami at 10:20 am and returned home at approximately 2:30 pm. The log does
not indicate who he went to Miami with, where he went when in Miami and who he met
in Miami.
EFTA01723945
COUNT #7
Feb 17, 2010, Jeffrey Epstein appeared for a Deposition if a civil matter where he is a
defendant. Prior to the onset of the de osition, Epstein was seated in an office along with
Attorney's
and Court Reporter
Jeffrey
E stei
en
e attorney's in an unsolicited conversation w
e stated "I like
our other two, I don't like them, but I like
and I would like
to
's case. Maybe me, you and my attorneys can talk about
case soon because like her." The attorney's did not respond to Epstein's statements, at
which time
swore Epstein in and began the deposition and testified as
follows:
Just a few minutes ago when you asked when you met her, you said, "I
don't know if I've ever met her," so is that your testimony, that you don't know if you
ever met M.?
Epstein:
My testimony is very clear. I must assert the rights my attorneys have
asked me to assert today, though her testimony under oath to the FBI is not what you
represented it to be, to me, and the ladies and gentlemen of the jury who are watching
this, hopefully.
Form.
We will get into that.
EPSTEIN:
Okay.
Mi
il: When you first came into the room today, didn't you look at me and say "I
sn't that the statement that you made to me?
Form. Move to strike.
EPSTEIN:
I don't believe I said that.
What is it that you believe you did say referencing M. when you sat
down in that seat prior to the cameras rolling?
Form. Counsel, I was here during that whole time and I don't recall any
sue statement.
: You weren't in the room.
EPSTEIN:
I don't remember. I don't know. Sorry.
EFTA01723946
EPSTEIN:
EPSTEIN:
So is it your testimony right now that you did not say to me "I like
That's —
Objection.
that's correct.
Do you like..?
Form, predicate, and relevance.
II?
EPSTEIN:
I would like to answer all your Questions here as I've... tried to do my
best, however, my attorneys have advised me that I must assert my Sixth Amendment,
Fourteenth Amendment and Fifth Amendment rights under the U.S. Constitution.
The Court Reporter
noted that she was just an eye witness to deponent
Jeffrey Epstein committingblatant perjury. She herself heard him say at least three times
that he liked •
By answering those questions in the manner he did and under oath, Epstein violated
Florida State Statute, 837.02 Perjury in official proceeding, therefore committing a
felony.
COUNT #8
a
: Do you know a man named
EPSTEIN: Can you spell it?
a
: He was at your house last week, does that remind you?
Form, move to strike
culation, argumentative, harassing.
Is there a question on the table,
: Yes.
Do you know him?
EPSTEIN: Can you spell his name for me, please?
I don't need to spell his name. Do you know who I'm talking about, Mr.
9
EPSTEIN: Sorry, Mr. what?
EFTA01723947
EPSTEIN: I would like to answer that question as well, but my attorneys have
counseled me today I have to assert my Sixth Amendment rights, Fifth Amendment rights
and Fourteenth Amendment rights under the U.S. Constitution or risk losing my right to
effective representation.
Note: According to the monthly probation reports submitted by Epstein IM
has residence at his residence January, February and March 2010.
COUNT #9
Feb 17, 2010, Jeffrey Epstein a
ared for a Deposition if a civil matter where he is a
defendant. The court reporter
swore Epstein in and began the deposition
and testified as follows:
Do you lcnow
EPSTEIN: Doesn't ring a bell.
a
: Former housekeeper/employee of yours, worked at the Palm Beach house?
EPSTEIN: ... Could. Don't know.
So you would be unable to answer what
did for you?
EPSTEIN: Yes.
Are you aware that our investigator spoke with
former
housekeeper for you, or house manager for you, out in California?
EPSTEIN: No.
Any reason why when asked about the activity that occurred in your
house, e would tear up and say, "I was hoping to forget everything I saw"?
Objection, argumentative. Speculative. Assumes facts not in evidence.
EPSTEIN: Again, the question?
a
: Is there any reason that when asked --
EPSTEIN: I don't know who he is.
Also, hearsay.
EFTA01723948
This person that I asked you about,
is that somebody
w o as contacted you within the last six months?
EPSTEIN: ... No.
In taking a break and thinking about some of these questions, have you
remembered who that person is, or still no real memory of him at all?
EPSTEIN: No real memory.
To the best of your knowledge, he never worked for you?
Form.
EPSTEIN: Not that I can recall, but there are lots of people who work for me, so...
On Sunday the 25th day of October 2009, Private Investigator's met with
at his home in La Quinta, California. During his interview he acknow e ge
t e worked for Jeffrey Epstein at the Palm Beach mansion from 2003 to 2005 as his
house manager.
He stated that he could not divulge what he knows due to a
confidentiality agreement he has with E stein. In December 2009 just two months before
ES
ebes deposition,
contacted the Investigators and Attorney
and advised that pstem's Attorney
was now representing him.
By answering those questions in the manner he did and under oath, Epstein violated
Florida State Statute, 837.02 Perjury in official proceeding, therefore committing a
felony.
COUNT #10
On March 10, 2010, Jeffrey Epstein submitted his daily log to the probation office the
daily log indicated that he was at his office from 8 am to 7pm. On that same date, Private
Investigators
and
established surveillance at Epstein's
residence at :
am. At :00 a.m., t e private investigators observed E rein's black
Escalade Florida Tag#Q299GT exit the driveway, being driven by
(bodyguard) with Jeffrey Epstein seated in the rear seat passenger side. T e ve
followed to Epstein's lawyer's office located on Australian Way arriving at approximately
9:30 a.m., an hour and half after the time was indicated on his daily log.
At 4:14 p.m., the private investi ators observed Epstein's Escalade exit his residence
driven by bodyguard
with no other occupants observed. The vehicle was
followed to the intersection o
anyon and North Olive, where it remained occupied by
the bodyguard and parked. Ban on and North Olive is approximately five (5) miles
southeast from Epstein's office.
pulled off the roadway and remained in the
vehicle for an hour and twenty-one minutes. At 5:35 p.m., it appeared that Jeffrey Epstein
exited the Wachovia Bank building located at 303 Banyan Blvd., and entered his vehicle,
EFTA01723949
driving off with his bodyguard.
Epstein arrived home at approximately 6:00 pm.
A
review of the daily log submitted by Epstein that date, revealed that he was at his office
until 7:00 p.m., showing no other locations, which appears that he filed a false daily log
for that particular date.
EFTA01723950
E•
epo. 4-11-2010
EFTA01723951
1
1
2
3
CASE NO. 50-2008-CA-028051 XXXX MB AB
4
5
-',
6
Plaintiff,
7
vs.
8
9
Defendant.
10
/
11
12
13
14
15
16
17
18
19
DATE: February 17, 2010
20
21
22
23
24
25
EFTA01723952
2
1
February 17, 2010
2
3
WITNESS
4
JEFFREY EPSTEIN
5
BY MR. EDWARDS
6
INDEX
4
EXHIBITS
7
PAGE
8
1
Jane Doe number 102 versus Jeffrey
Epstein complaint.
35
9
2
Document, Nonprosecution Agreement.
135
10
11
12
13
14
15
16
17
18
'19
20
21
22
23
24
25
Page
Line
61
22
123
20
146
14
148
1
153
5
159
13
162
3
EFTA01723953
3
1
The videotaped deposition of JEFFREY
2
EPSTEIN in the above-entitled and numbered cause,
3
was taken before me,
a Registered
4
Professional Reporter and Notary Public for the
5
State of Florida at Large, at 444 West Railroad
6
Avenue, in the City of West Palm Beach, Palm
7
Beach County, in the State of Florida, beginning
8
at the hour of 11:15 o'clock a.m., pursuant to
9
the Notice in said cause for the taking of said
10
deposition which is annexed to the court file
11
herein, on behalf of the PLAINTIFF in the
12
above-entitled action pending in the above-named
13
court.
14
The appearances at said time and place
15
were as follows:
16
P.L.
17
Attorneys for Plaintiff
425 North Andrews Avenue, Suite 2
18
Fort Lauderdale, Florida 33301
Tel: (954) 524-2820
19
BY:
M,
ESQ.
20
21
Attorneys for Defendant
303 Banyon Boulevard, Suite 400
22
West Palm Beach, Florida 33401
Tel: (561) 842-2820
23
BY:
, ESQ.
24
ALSO PRESENT:
videographer
25
(U.S. Legal Support)
EFTA01723954
4
1
THEREUPON,
2
JEFFREY
EPSTEIN
3
being by
first duly sworn to tell
4
the whole truth, as hereinafter certified,
S
testified as follows:
6
7
BY III
8
Q
Can you give us your name.
9
A
Jeffrey Epstein.
10
Q
Mr. Epstein, you made a comment when you
11
came in the room that you were appreciative of me
12
being respectful to your housekeeper yesterday
13
and I intend for that to be the same with you
14
today.
15
I want to start by asking you, at this
16
point we've gone through a lot of discovery in
17
this case. There aren't many disputed facts as
18
to what actually happened at your house.
19
Generally I think you would agree that you
20
derived a way for young females to come to your
21
house and engage in varying degrees of sexual
22
activity, some of the girls as young as 12, some
23
of them as old as seventeen or so, most in
24
between, but as of yet you haven't provided an
25
explanation.
EFTA01723955
S
1
I want to provide you an opportunity to
2
tell the jury at this time why you did it.
3
•
I'm going to object.
4
Confusing, compound and irrelevant, as
5
worded.
6
A
You know, I would like to answer that
7
question, frankly. However, at this time, my
8
attorneys have told me that I can't and I must
9
invoke my Fifth, Sixth and Fourteenth Amendment
10
rights or I risk losing their counsel.
11
Accordingly, I therefore assert those rights.
12
Sorry.
13
•
In addition to that I'll move
14
to strike counsel's statement as a
15
narrative, as well.
16
•
: I understand, I wanted to
17
provide him an opportunity, if today was
18
going to be the day.
19
III IIII: Same thing, move to strike.
20
Q
Mr. Epstein, how long have you been
21
sexually attractive to underage minor females?
22
Objection, harassing,
23
argumentative.
24
A
Are you kidding?
25
Q
No, I mean, I don't feel like I'm
EFTA01723956
1
divulging any secrets here, right?
2
Move to strike.
3
Q
That's the question that's pending.
4
A
I would like to answer that question as
5
well, as all your other questions today, however,
6
I have to follow my attorneys' advice. They have
7
told me I must invoke my Fifth, Sixth and
8
Fourteenth Amendment right to not answer those
9
questions today, or any questions relevant to
10
this lawsuit, so accordingly, I'm going to assert
11
those rights and -- under the constitution
12
guaranteed by the Fifth and Sixth, and Fourteenth
13
amendment.
14
Q
Would you consider yourself addicted to
15
sex with minor females?
16
Same objections.
17
A
You know, III
, again, I want to
18
be very respectful. As the current U.S. Attorney
19
has described your law firm as a criminal
20
enterprise and part of one of the largest frauds
21
in Florida's history, it has been reported that
22
your firm has fabricated multiple cases against
23
me in order to fleece unsuspecting investors out
24
of millions and millions of dollars, so
25
unfortunately at this time, although I would like
EFTA01723957
7
1
to answer that question, on advice of counsel I
2
will have to refrain and assert my Fifth, Sixth
3
and Fourteenth Amendment right.
4
Q
Can you then provide an explanation for
5
what relevance that soliloquy of yours has to,
6
whether or not you engaged in sex acts with III.
7
When she was a minor?
8
Objection, no, he cannot.
9
Argumentative. Compound, harassing.
10
III
with all due
11
respect, it was not my idea for him to give
12
this speech about a former RRA law firm I
13
was asking to elaborate on that.
14
Counsel, I'm working with
15
your follow-up question.
16
I understand.
17
I'm objecting, object to the
18
form and stating the reasons on the record
19
why the form is required to be objected to,
20
based'upon your question.
21
Will he elaborate on the
22
relevance of that soliloquy to his touching
23
when she was 13, 14 and 15 years old in
24
a sexual manner?
25
•
I'm going to object again,
EFTA01723958
" —Mires-
1
argumentative, compound, harassing and
2
irrelevant.
3
Q
You can answer.
4
A
I would like to answer, however, I'm
5
going to have to assert my Fifth Amendment, Sixth
6
Amendment, Fourteenth Amendment right as advised
7
by my counsel, otherwise I risk losing their
8
advice.
9
Q
Mr. Epstein, have you ever been
10
diagnosed with a sex addiction to minors by a
11
psychologist or other medical professional?
12
A
I intend to respond to all of your
13
questions at some relevant time; however, today
14
at the present time, my attorneys have counseled
15
me that I cannot provide answers to any questions
16
relevant to this lawsuit and I must accept their.
17
advice or risk losing my Sixth Amendment rights
18
to effective representation.
19
Accordingly, I assert my Fifth,
20
Federal -- Fifth and Sixth and Fourteenth
21
Amendment rights, to the United States
22
Constitution.
23 "
In addition to that, III
24
as the Court has ruled on several
25
matters, Mr. Epstein's medical history is
EFTA01723959
9
1
not relevant at this time nor has he placed
2
same at issue in this case.
3
: Understood.
4
Q
Mr. Epstein, were you sexually abused as
5
a minor?
6
A
Again?
7
Q
Were you sexually abused, as a minor?
8
A
You know, again, I would like to respond
9
to all -- if any questions seem to be relevant.
10
I would like to respond to any relevant question
11
at this time; however, my attorneys have
12
counseled me that I cannot provide answers to the
13
questions relevant to this lawsuit today. I must
14
accept their advice or risk losing my Sixth
15
Amendment right to effective representation.
16
Accordingly then, I assert my Fifth, Sixth and
17
Fourteenth Amendment right to the United States
18
Constitution.
19
Q
Isn't it true that you have engaged in
20
some sexual interaction with hundreds of underage
21
minor females in the last ten years of your
22
life? Is that true?
23
Objection, relevance.
24
A
the current U.S. Attorney
25
has described your law firm as a criminal
EFTA01723960
10
1
enterprise and part of the largest fraud in
2
Florida's history. It has been reported that
3
your firm fabricated multiple cases, many, many
4
multiple cases against me in order to fleece
5
unsuspecting investors out of millions and
6
millions of dollars. Unfortunately, at this time
7
in response to your question, my attorneys have
8
advised me that I must assert my Sixth Amendment,
9
Fifth Amendment, Fourteenth Amendment right.
10
Though, I believe, you know, that I would really
11
like to answer your questions today, but at this
12
moment I must assert those rights or risk having
13
my attorneys resign.
14
Q
You're invoking your Fifth Amendment
15
rights to each of these questions because you
16
know your answers will incriminate you and you
17
feel it will result in you being prosecuted for
18
your crimes; isn't that right?
19
Objection, argumentative,
20
harassing. Calls for a legal conclusion.
21
Q
You can answer.
22
A
No, in fact, the Supreme Court recently
23
said the Fifth Amendment right is there to
24
protect the innocent, so, that's the way I would
25
like to answer that.
EFTA01723961
11
1
Q
Are you actually telling the jury that
2
you didn't commit the crimes that have been
3
alleged against you by the various females that
4
were under age when you engaged in sex with
5
them? Are you telling the jury that right now?
6
Objection, argumentative,
7
harassing.
8
A
I would like to respond to that
9
question, as you know, however, at the present
10
time my attorneys have counseled me that I cannot
11
provide answers to any questions relevant to this
12
lawsuit and I must accept their advice or risk
13
losing my Sixth Amendment right to effective
14
representation. Accordingly, I assert my Fifth,
15
Sixth and Fourteenth Amendment right under the
16
United States Constitution.
17
Q
Mr. Epstein, you understand that this is
18
the video that will be played to the jury in
19
's trial against you and
wants answers.
20
The jury is going to want answers, so I know that
21
you're telling us that you're going to respond at
22
some time in the future; but the time is now.
23
Would you like this opportunity to explain why
24
you engaged in sexual activity with
25
beginning when she was 13 years old and you were
EFTA01723962