EFTA00213048

12/08/07 THU 15:22 PAZ 305 530 6440 
EXECUTIVE OFFICE 
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
la 002 
DELIVERY BY PA SIMILE 
Jay?. Lefton/its, Esq. 
Kirkland & Ellis .LLP 
Citigroup Center 
153 East 53rd Street 
New York, New York 10022-4675 
Re: 
Jeffrey Epstein 
Dear Jay: 
99 N.H. 4a Street 
FL 33132-2111 
(305) 961-9299 
Facsimile: (30S) 530-6444 
December 6, 2007 
I write in response to your recent e-mails and letters regarding victim notification and other 
issues. Our Office is trying to perform our contractual obligations under the Agreement, which we 
feel are being frustrated by defense counsel's objections. The Office also is concerned about Mr. 
Epstein's nonperformance. 
More than three weeks ago we spoke about the failure to set a timely plea and sentencing 
date. At that time, you assured me that the scheduling delay was refl.:0d by the unavailability of 
Judge MeSorley. You promised that a date would be set promptly. On November 15th, Rolando 
Garcia met with Barry Krisher on another matter, and was told by Mr. ICrisher that he had just 
spoken with Jack Goldberger, and that Mr. Epstein's plea and sentencing were set to occur on 
December 14, 2007. Since that time, we have tried to confirm the date and time of the hearing in 
order to include that information in the victim notification letters. You continue to refer to the plea 
and sentencing as though it will be in January; Mr. Krisher's office has not confirmed any date; and 
Mr. Goldberger recently told Marie Villafafia that "there is no date." 
I must reiterate that a delayed guilty plea and sentencing — now more than two months 
beyond the original deadline — is unacceptable to the Office. As you will recall, the plea and 
sentencing hearing originally was to occur in early October 2007, but was delayed until October 26th 
to allow Mr. Goldberger to attend. It was delayed again until November to allow you to attend. 
Rather than using your best efforts to insure that the plea and sentencing occur in November, we 
recently learned that a plea conference had been scheduled with Judge McSorley for November 20. 
2007, but was canceled at the request of the parties, not the judge. Judge McSorley has not been 
away for any extended period, and there is no basis for your assertion that the judge is the cause of 
EFTA00213108

12/08/07 ThU 16:23 FAX 305 630 8440 
EXECUTIVE OFFICE 
JAY P. LEEKOWITZ, ESQ. 
DECEMBER 6, 2007 
PACE 2 OF 4 
any past or figure delay. Mr. Epstein currently has four Florida Bar members on his defense team, 
so attorney scheduling is not an adequate basis for delay. 
Three weeks ago I also asked you to provide our Office with the terms of the Plea Agreement 
with the State Attorney's Office. It is now more than two months since the signing of the Non-
Prosecution Agreement and we have yet to see any formal agreement, or even a list of essential terms 
of such an agreement. 
Next, let me address your allegation that attorneys In our office and agents of the FBI have 
leaked information to the press In an effort to affect possible civil litigation with Mr. Epstein. This 
is untrue. There has been no contact between any member of the press and any employee of our 
office or the FBI since you incorrectly accused investigators of telling "Vanity Fair" about Mr. 
Starr's employment by Mr. Epstein several months ago. We intend to continue to refrain from 
commenting or providing information to the press. We would ask that your client and all of his 
representatives do the same. 
I also want to address your interpretation of several statements that were included in 
correspondence — at your insistence — as proof that the designated victims have invalid claims. Let 
me make clear that each of the listed individuals are persons whom the Office identified as victims 
as defined in Section 2255, that is, as persons "who, while a minor, was a victim of a violation of 
section ... 2422 or 2423 of this title." In other words, the Office is prepared to indict Mr. Epstein 
based upon Mr. Epstein's "interactions" with these individuals.' This conclusion is based upon a 
thorough and proper investigation — one in which w_. n9 of the victims was informed of any right to 
receive damages of any amount prior to the investigation of her claim. The Office agrees that it is 
not a party to, and will not take a role in, any civil litigation, but the Office can say, without 
hesitation, that the evidence demonstrates that each person on the list was a victim of Mr. Epstein's 
criminal behavior. Mr. Star's letter also suggests that the number of victims to whom Mr. Epstein 
is exposed by the Agreement is limitless. As you know, early drafts of the Agreement contained a 
numerical limit of 40 victims, which was removed at your request. The Office repeatedly confirmed 
that the number would not exceed 40; and the list is significantly shorter than that. Once the list is 
provided to you, if you have a good faith basis for asserting that a victim never met Mr. Epstein, we 
remain willing to listen and to modify the list if you convince us of your position. 
Finally, let me address your objections to the draft Victim Notification Letter. You write that 
you don't understand the basis for the Office's belief that it is appropriate to notify the victims. 
Pursuant to the "Justice for All Act of2004," crime victims are entitled to: "The right to reasonable, 
accurate, and timely notice of any public court proceeding ... involving the crime" and the "right 
'Unlike the State's investigation, the federal investigation shows criminal conduct by Mr. 
Epstein at least as early as 2001, so all of the victims were minors at the time of the offense. 
la)001 
EFTA00213109

12/08/07 THU 15:23 FAX 305 530 8440 
EXECUTIVE OFFICE 
JAY P. Liuxowriz, EsQ. 
Decakirmit 6, 2007 
Pnos 3 or 4 
not to be excluded from any such public court proceeding . . ." 18 U.S.C. § 3771(a)(2) & (3). 
Section 3771 also commands that "employees of the Department of Justice . . . engaged in the 
detection, investigation, orprosecution of crime shall make theirbest efforts to see that crime victims 
are notified o4 and accorded, the rights described in subsection (a)." 18 U.S.C. § 3771(cX1). 
Additionally, pursuant to the Victims' Rights and Restitution Act of 1990, our Office is 
obligated to "inform a victim of any restitution or other relief to which the victim may be entitled 
under this or any other law and [the) manner in which such relief may be obtained." 42 U.S.C. § 
10607(cX1)(13). With respect to notification of the other information that we propose to disclose, 
the statute requires that we provide a victim with the earliest possible notice of: the status of the 
investigation; the filing of charges against a snsperu-si offender; and the acceptance of a plea. 42 
U.S.C. § 10607(c)(3). Just as in 18 U.S.C. § 3771, these sections are not limited to proceedings in 
a federal district court. Our Non-Prosecution Agreement resolves the federal investigation by 
allowing Mr. Epstein to plead to a state offense. The victims identified through the federal 
investigation should be appropriately informed, and our Non-Prosecution Agreement does not 
require the U.S. Attorney's Office to forego its legal obligations. 
With respect to your assertion that we are seeking to "federalize" the state plea, our office 
is simply informing the victims of their rights. It does not command them to appear at the hearing 
or to file a victim impact statement In fact, the letter recommends the sending of any statement to 
the State Attomey's Office so that ASA 13eIohlavek can determine which, if any, statements are 
appropriate to file with the Court. 
Next, you assert that our letter miscb aractetizes Mr. Epstein's obligation to pay damages to 
the victims. To avoid that suggestion, I have asked AUSA Villafaila to simply quote the terms of 
the Agreement directly into the Notification Letter. We also have no objection to referring to Mr. 
Epstein as a "sexual offender" rather than a "predator." 
We have no objection to using the conjunction "and/or" in referring to the particular 
offense(s) of which the recipient was a victim. We will not include the language that we take no 
position as to the validity of any claims. While the Office has no intention to take any position in 
any civil litigation arising between Mr. Epstein and any individual victim, as stated above, the Office 
believes that it has proof beyond a reasonable doubt that each listed individual was a victim of Mr. 
Epstein's criminal conduct while the victim was a minor. The law requires us to treat all victims 
"with fairness and with respect for the victim's dignity andprivaey." 18 U.S.C. § 3771(a)(8). We 
will not include any language that demeans the harm they may have suffered. 
The letter's assertions regarding representation by the Podhurst firm and Mr. Iosefsberg arc 
accurate. Judge Davis conferred with Messrs. Podhurst and Josefsberg to insure their willingness 
to undertake this assignment prior to finalizing his selection. 
Q004 
EFTA00213110

12/08/07 TEO 15:23 FAX 306 630 8440 
EXECUTIVE OFFICE 
JAY P. LEFKOWTTA ESQ. 
DECEMBER 6, 2007 
P4O64 OP 4 
Lastly, you object to personal communication between the victims and federal attorneys or 
agents. We have no objection to sending the letters through the mail' but we will not remove the 
language about contacting AUSANWrilieff Special Agent Sith 
questions or 
concerns. Again, federal law requires that victims have the "reasonable right to confer with the 
attorney for the Government in this case." 18 U.S.C. § 3771(a)(5). The three victims who were 
notified prior ba your objection had questions directed to Mr. Epstein's punishment, not the civil 
litigation. Those questions are appropriately directed to law enforcement. If questions arise related 
to the civil litigation, AUSA Villafatla and Special Agent Icuyrkendall will recommend that the 
victims direct those questions to Mr. Josefsberg-
I have attached a revised letter incorporating the changes on which we can agree. Please 
provide any further comments by the closeofbusittess on Friday. In addition, pleaseprovide us with 
a definitive statement, signed by your client, of his intention to abide by each and every tarn of the 
Agreement by close of business on Friday, December 7, 2007. By that time, you must also provide 
us with the agnaernent(s) with the State Attorney's Office and a date and time certain for the plea and 
sentencing, which must occur no later than December 14, 2007. There must be closure in this 
matter. 
By: 
Enclosure 
cc: 
R. Alexander 
U.S. Attorney 
AUSA 
Sincerely, 
R. Alexander Acosta 
United States Ajtomey 
First Assistant United States Attorney 
'This is contingent, however, on being able to provide adequate notice of the change of 
plea and sentencing. The sooner that you schedule that hearing with Judge McSorley, the sooner 
we can dispatch these letters. If you delay further, we will have to rely on telephone or personal 
notification. 
a 005 
EFTA00213111

12/06/07 TRU 15:24 FAX 305 530 6440 
EXECUTIVE OFFICE 
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
SOO South Australian Ave., Suite 400 
West Palm Reach, FL 33401 
(561) 820-8711 
Facsimile: (S61) 820-8777 
December 6, 2007 
DELIVERY BY UNITED STATES MAIL 
Miss 
Re: 
Crime Victims' Rights — Notificationsr Resolution of Epstein Investigates 
Dear Miss 
. 
Several months ago, I provided you with a letter notifying you of your rights as a 
victim pursuant to the Justice for All Act of 2004 and other federal legislation, including: 
(4) 
(5) 
(6) 
(7) 
(8) 
The right to be reasonably protected from the accused. 
The right to reasonable, accurate, and timely notice of any public court 
proceeding involving the crime or of any release or escape of the accused. 
The right not to be excluded from anypublic courtproceeding, unless the court 
determines that your testimony may be materially altered if you are present for 
other portions of a proceeding. 
The right to be reasonably heard at any public proceeding in the district court 
involving release, plea, or sentencing. 
The reasonable right to confer with the attorney for the United States in the 
case. 
The right to full and timely restitution as provided in law. 
The right to proceedings free from unreasonable delay. 
The right to be treated with fairness and with respect for the victim's dignity 
and privacy. 
I am writing to inform you that the federal investigation of Jeffrey Epstein has been 
completed, and that Mr. Epstein and the U.S. Attorney's Office have reached an agreement 
containing the following terms. 
litooe 
EFTA00213112

12/08/07 THU 16:24 FAX 305 630 8440 
EXECUTIVE OFFICE 
MISS 
NOvEMBER 29,2007 
P.6462 
First, Mr. Epstein agrees that he will plead guilty to two state offenses, including the 
offense of soliciting minors to engage in prostitution, which will require him to register as 
a sexual offender for the remainder of his life. 
Second, Mr. Epstein has agreed to make a binding recommendation of 18 months' 
imprisonment to the state court judge who sentences him. Mr. Epstein will serve that 
sentence of imprisonment at the Palm Beach County Jail. 
Third, Mr. Epstein has agreed that he will compensate you for damages you have 
suffered, under the following circumstances. That portion of the agreement that relates to 
those claims reads as follows: 
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 ofthis agreement, the United States, in consultation 
with and subject to the good faith approval of Epstein's cooncel, 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 overhis person and/or the subject matter, and Epstein waives 
his right to contest liability and also waives his right to contest damages 
up to an amount as agreed to between the identified individual and 
Epstein, so long as the identified individual elects to proceed 
exclusively under 18 U.S.C. § 2255, and agrees to waive any other 
claim for damages, whether pursuant to state, federal, or common law. 
Notwithstanding this waiver, as to those individuals whose names 
appear on the list provided by the United States, Epstein's signature on 
this agreement, his waivers and failures to contest liability and such 
damages in any suit are not to be construed as an admission of any 
criminal or civil liability. 
9. 
Epstein's signature on this agreement also is not to be construed as an 
admission of civil or criminal liability or a waiver of any jurisdictional 
a007 
EFTA00213113

12/06/07 TRU 15:24 FAX 305 530 6440 
Miss 
NOVEMBER 29, 2007 
PAGE 3 
EXECUTIVE OFFICE 
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. 
Pursuant to the terms of the agreement and an addendum, to assist you in making such 
a claim, the U.S. Attorney's Office has asked an independent Special Master to select 
attorneys to represent you, Those attorneys are Aaron Podhurst and Robert ("Bob") 
Josefsberg with the law firm of Podhurst Orseck, P.A. They can be reached at (305) 358-
2800. 1 anticipate that someone from their law firm will be contacting you shortly. I must 
also advise you that you are not obligated to use these attorneys. In fact you have the 
absejuksightoseleg_yeurgmut=imayoiLenileciLti
l ej,A:imalcmga
e 
to 
Poclhurst/Josefsbera at all, or you can sneak with them and_decide at any time to use a 
different attorney. If you do decide to seek damages from Mr. Epstein and you decide to use. 
Messrs. Podhurst/Josefsberg as your atunneys, Mr. Epstein will be responsible for paying 
attorney's fees incurred during the time spent trying to negotiate a settlement. If you are 
unable to reach a settlement with Mr. Epstein, you and Mr. Josefsberg can discuss how best 
to proceed. 
As I mentioned above, as part of the resolution of the federal investigation, Mr. 
Epstein has agreed to plead guilty to state charges. Mr. Epstein's change of plea and 
sentencing will occur on December 14, 2007, at 
a.m., before Judge Sandra K. 
MeSorley, in Courtroom 11F at the Palm Beach County Courthouse, 205 North Dixie 
Highway, West Palm Beach, Florida. Pursuant to Florida Statutes Sections 960.001(1)(k) 
and 921.143(1), you are entitled to be present and to make a statement under oath. If you 
choose, you can submit a written statement under oath, which may be filed by the State 
Attorney's Office on your behalf. If you elect to prepare a written statement, it should 
address the following: 
the facts of the case and the extent of any harm, including social, 
psychological, or physical harm, financial losses, loss of earnings directly or 
indirectly resulting from the crime for which the defendant is being sentenced, 
'ilia 08 
EFTA00213114

12/06/07 THU 15:25 PAX 305 530 8440 
EXECUTIVE OFFICE 
Miss 
NOVEMBER 294007 
PAGE 4 
and any matter relevant to an appropriate disposition and sentence. Fl. Stat. 
921.143(2). 
You also are entitled to notification when Mr. Epstein is released from imprisonment 
at the end of his prison term and/or if he is allowed to participate in a work release program. 
To receive such notification, please provide the State Attorney's Office with the following 
information: 
1. 
Your name 
2. 
Your address 
3. 
Your home, work, and/or cell phone numbers 
4. 
Your e-mail address 
5. 
A notation of whether you would like to participate in the "VINE system," 
which provides automated notification calls any time an inmate is moved. (To 
use this system, your calls must go to you directly, not through a switchboard.) 
Thank you for all of your help during the course of the investigation. If you have an 
questions or concerns 
lease do not hesitate to contact me or Special Agent 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
By: 
Assistant United States Attorney 
cc: 
S cial A cnt 
F.B.I. 
Victim-Witness Coordinator, U.S. Attorney's Office 
la sop 
EFTA00213115

Exhibit 16 
EFTA00213116

IN RE: 
INVESTIGATION OF 
JEFFREY EPSTEIN 
 
1 
ADDENDUM TO THE NON-PROSECUTION AGREEMENT 
IT APPEARING that the parties seek to clarify certain provisions of page 4, paragraph 7 
of the Non-Prosecution Agreement (hereinafter "paragraph 7"), that agreement is modified as 
follows: 
7A. 
The United States has the right to assign to an independent third-party the responsibility 
for consulting with and, subject to the good faith approval of Epstein's counsel, selecting 
the attorney representative for the individuals identified under the Agreement. If the 
United States elects to assign this responsibility to an independent third-party, both the 
United States and Epstein retain the right to make good faith objections to the attorney 
representative suggested by the independent third-party prior to the final designation of 
the attorney representative. 
7B. 
The parties will jointly prepare a shott written submission to the independent third-party 
regarding the role of the attorney representative and regarding Epstein's Agreement to 
pay such attorney representative his or her regular customary hourly rate for representing 
such victims subject to the provisions of paragraph C, infra. 
7C. 
Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the attorney 
representative selected by the independent third party. This provision, however, shall not 
obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus. 
If after consideration of potential settlements, an attorney representative elects to file a 
contested lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested 
remedy, the paragraph 7 obligation of the Agreement to pay the costs of the attorney 
representative, as opposed to any statutory or other obligations to pay reasonable 
attorneys fees and costs such as those contained ins 2255 to bear the costs of the attorney 
representative, shall cease. 
EFTA00213117

By signing this Addendum, Epstein asserts and certifies that the above has been read and 
explained to Kitt. Epstein hereby. states that he understands the clarifications to the Non-
Prosecution-Ave.:anent and agrees to comply with dim 
R. ALEX/WM. ACOSTA 
UNTIED STATES ATTORNEY 
Dated: /04 0 47 
Dated: / 14 113-
‘ 
Dated: 
Dated: 
By: 
V*1
441:St24.--  math 
,f.....444R1BMWORARA-
ASSISTANT U.S. ATTORNEY 
GERALD LEMOURT, ESQ. 
COUNSEL TO JEFFREY EPSTEIN 
LILLY ANN SANCHEZ, ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
EFTA00213118

By signing this Addendum, Epstein asserts and certifies that the above has ban read and 
explained to him. Epstein hereby states that he understands the clarifications to the Non-
Prosecution Agreement and agrees to comply with than. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated:  ID h0/07 
Dated: 
Dated: 
JEFFREY EPSIEN 
RALD LEFCO RT ESQ. 
COUNSEL TO JEFF 
Y EPSTEIN 
LILLY ANN SANCHEZ, ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
EFTA00213119

By signing this Addend:on, Epstein asserts and catiSas that the above has been read and 
ea:Veined to him. Epstein hereby shifts that he understands the clarifications to the Non-
Proseadion Agreement and epees to comply with than. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated: /D /3010 '7. 
• 
Dated: 
Dated: 
Bed: 
t
ts /91W4 
BY: 4 ASSIST 
U.S. ATTORNEY 
JEFFREY EPSITaN 
GERALD LEFCOURT, ESQ. 
COUNSEL TO JEFFREYEPSTEIN 
LILLYANNSANCH87, ES 
ATTORNEY FOR JEFFREY EPSTEIN 
EFTA00213120

Exhibit 17 
EFTA00213121

10/25/07 THU 13:16 FAX 305 530 8440 
EXECUTIVE OFFICE 
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
21002 
99 ME. 4.4 Street 
Miami, F133132 
Telephone: (305) 961-9299 
Facsimile: (305) 530-6444 
October 25, 2007 
DELIVERY i3Y FACSIMILE 
The Hon. Edward B. Davis (Ret.) 
Akerman Senterfitt 
One Southeast Third Avenue, 25th Floor 
Miami, Florida 33131 
Re: 
Service as
 Masten 
Dcar Judge Davis: 
Thank you for agreeing to serve as a Special Master and for assisting the United States 
Attorney's Office in the selection of an attorney representative to represent a group of 
identified victims. This letter is meant to assist you in performing your duties by providing 
you with background information regarding the agreement between the United States and 
Jeffrey Epstein and the duties that the attorney representative will have to perform. 
The Federal Bureau of Investigation and the U.S. Attorney's Office conducted an 
investigation of Mr. Epstein. As a result of that investigation, the U.S. Attorney's Office and 
Mr. Epstein entered into a Non-Prosecution Agreement and an Addendum that contains, 
inter alia, the following terms: 
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. 
EFTA00213122

10/26/07 THU 13:18 FAX 306 630 8440 
EXECUTIVE OFFICE 
THE HON. EDWARD B. DAMS (Rzr.) 
OCTORER25,2007 
PAGE 2 OF 4 
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 7C, infra. 
7C. Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees 
of the attorney representative selected by the independent third party. This 
provision, however, shall not obligate Epstein to pay the fees and costs of 
contested litigation filed against him. Thus, if after consideration of potential 
settlements, an attorney representative elects to file a contested lawsuit 
pursuant to 18 U.S.C. § 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 § 2255 to bear 
the costs of the attorney representative, shall cease. 
8If any of the individuals referred to [in the paragraphs above] 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 agreed 
to between Epstein and the identified individual, 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, with respect 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 
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 [the above paragraphs], neither Epstein's 
003 
EFTA00213123

10/25/07 THU 13:19 FAS 305 530 8440 
EXECUTIVE OFFICE 
THE HON. EDWARD 13. DAVIS (RET.) 
OCTOBER 25, 2007 
PAGE 3 OF 4 
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. 
The most recent version of the statute referenced above, 18 U.S.C. § 2255, 
provides that: 
Any person who, while a minor, was a victim of a violation of section ... 2422 
or 2423 of this title and who suffers personal injury as a result of such 
violation, regardless of whether the injury occurred while such person was a 
minor, may sue in any appropriate United States District Court and shall 
recover the actual damages such person sustains and the cost of the suit, 
including a reasonable attomey's fee. Any person as described in the 
preceding sentence shall be deemed to have sustained damages of no less than 
$150,000 in value.' 
Section 2422 prohibits the use of a facility of interstate commerce to induce minors 
to engage in sexual activity and prostitution, and section 2423 prohibits interstate travel for 
the purpose ofengaging in sexual activity or prostitution with minors. The United States has 
identified 34 victims as defined by this statute. The United States takes no position as to the 
validity of any such claim under this statute. 
Due to the circumstances of the case and the number and caliber of the attorneys who 
represent Mr. Epstein, in selecting the victims' attorney representative, the United States 
suggests that you consider the following criteria: 
1. 
Experience doing both plaintiffs' and defense litigation. 
2. 
Experience with state and federal statutory and common law tort claims. 
3. 
The ability to communicate effectively with young women. 
4. 
Experience litigating against large law firms and high profile attorneys who 
An earlier version of this statute deems that any person described in the preceding 
sentence shall have sustained damages of no less than $50,000 in value. 
Zoos 
EFTA00213124

10/25/07 THU 13:19 FAX 305 530 5540 
EXECUTIVE OFFICE 
THE HON. EDWARD B. DAVIS (IST.) 
OCTOBER 25, 2007 
PAGE 4 OP 4 
may test the veracity of the victims' claims. 
5. 
Sensitivity to the nature of the suit and the victims' interest in maintaining 
their privacy. 
6. 
Experience litigating in federal court in the Southern District of Florida. 
7. 
The resources to hire experts and others, while working on a contingency 
fee basis, in order to prepare for trial, if a settlement cannot be reached 
(defense counsel has reserved the right to challenge such litigation). 
8. 
The ability to negotiate effectively. 
Pursuant to this letter, the United States assigns to you thc responsibility for consulting 
with and selecting the attorney representative for the individuals. The United States and 
Epstein retain the right to make good faith objections to the attorney representative you select 
prior to the final designation of the attorney representative. In that regard, after you have 
reached a decision regarding the attorney representative, please provide me with his or her 
name and contact information. 
IfI can provide you with any farther information, please do not hesitate to contact me 
and/or the U.S. Ahem and/or Jay Lefkowitz, Esq. on behalf ofEpstein. Mr. Lefkowitz can 
be reached at 
- Kirkland & Ellis LLP, Citigroup Center, 153 East 534 Street, 
Ncw York, New York 10022-4611. Thank you again for your assistance with this matter. 
cc: 
AUS 
Sincerely, 
It Alexander Acosta 
United States Qttomey 
By: -711 -67 
Jeffrey Sloman 
First Assistant United States Attorney 
40005 
EFTA00213125

Exhibit 18 
EFTA00213126

Case 9:08-cv-80736-KAM 
Document 35 
Entered on FLSD Docket 12/22/2008 
Page 1 of 4 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 08-80736-Civ-MarraMolmson 
IN RE: JANE DOE, 
Petitioner. 
SUPPLEMENTAL DECLARATION OF 
1. 
do hereby declare that I am currently employed as an 
Assistant United States Attorney ("AUSA") in the Southern District of Florida and was so 
employed during all of the events described herein, and that 1 was the AUSA assigned to the 
investigation of Jeffrey Epstein. 
2. 
This Declaration is meant to supplement the information provided in the 
Declaration that was filed on July 9, 2008, and to correct some statements in that Declaration 
based upon events that occurred after the filing of the July 9 Declaration. 
3. 
As explained in the July 9 Declaration and in Court presentations related to this 
matter, the resolution of the federal investigation of Jeffrey Epstein included a series of 
documents: (1) a September 2007 Non-Prosecution Agreement ("Part I"); (2) an October 
2007 Addendum ("Part 2"); and (3)a letter dated December 19, 2007, from the U.S. Attorney 
to Attorney Lilly Ann Sanchez, counsel to Jeffrey Epstein ("Part 3"). 
EFTA00213127