EFTA00213740

Hi Jay — In case you can't open the other version, here it is in pdf. 
«Special Master Proposal.pdf» 
Assistant U.S. Attorney 
EFTA00213760

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EFTA00213761

10/07/2007 07:42 PM 
To -Jay Leflcowite 
cc 
bcc 
Subject Call Tomorrow 
Jay — The office is closed tomorrow for Columbus Day. Can we 
reschedule for Tuesday at 10:00? Thank you. 
Assistant U.S. Attorney 
Fax 
EFTA00213762

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EFTA00213763

11/28/2007 04:46 PM 
To 
cc "Sloman, Jeff (USAFLS)" 
"Acosta, Alex (USAFLS)" 
bcc 
Subject Epstein: Victim Notification Letter 
P011 
-•-• 
aunt 
. 
Dear Jay: 
Jeff asked that I forward the victim notificgtion letter to you. It is 
attached. 
Thank you. 
<<Victim Notification Ltpdt>> 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 
Fax 
«< Attachment Victim Notification Ltr.pdf has been archived by user 
'CommonStoreilTrKhidand-Ellis' on '01/30/2008 00:30:02% >» 
EFTA00213764

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
300 South Australian Ave., Suite 400 
Wert Palm Beach FL 33401 
Facsimile: 
November 29, 2007 
DELIVERY BY HAND 
Miss 
Re: 
Crime Victims' Rights — Notification of Resolution of Epstein Investigation 
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 any public court proceeding, 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 Mr. Epstein and the U.S. Attorney's Office have reached an agreement containing 
the following terms. 
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 predator 
for the remainder of his life. 
EFTA00213765

MISS 
NOVEMBER 29, 2007 
PAGE 2 
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 not contest jurisdiction or liability if you elect to 
seek damages from him because the United States has identified you as a minor victim of certain 
federal offenses, including travel in interstate commerce to engage in prostitution with minors and 
the use of facilities of interstate commerce to induce minors to engage in prostitution. 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 
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 absolute right to select your 
own attorney, so you can decide not to speak with Mssrs. Podhurst/ Josefsberg 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 attorneys, Mr. Epstein 
will be responsible for paying attorney's fees incurred during the time spent hying 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. McSorley, 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 will 
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, 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 
EFTA00213766

Miss 
NOVEMBER 29, 2007 
PAGE 3 
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 any 
questions or concerns, please do not hesitate to contact me or Special Agent 
a 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
By: 
Assistant United States Attorney 
cc: 
Spe ' 
ent 
Ms. 
F.B.I. 
Victim-Witness Coordinator, U.S. Attorney's Office 
EFTA00213767

EFTA00213768

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11129/2007 06:30 PM 
t3
To 'Jay Lentowite 
cc 
bec 
Subject RE: Epstein: Victim Notification Letter 
AtSeni*M
1-7. 
.:4C.AVP 
g'"`I • 
Hi Jay — The only attachment is my letter, did I miss something? 
Thanks. MK: 
11/28/2007 04:46 PM 
To.Jay Letkowitz" 
ceSloman, Jeff (USAFLSY' 
"Acosta. Alex (USAFLSr 
SuEpetein: Victim Notification Letter 
bie 
ct 
Dear Jay: 
Jeff asked that I forward the victim notification letter to you. It is 
attached. 
Thank you. 
«Victim Notification Ltr.pdf» 
Assistant U.S. Attorney 
EFTA00213770

500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 
Fax 
r 
• 
The information contained in this commun.. ioation is 
confidential, may be attorney-client privileged, may 
- constitute inside information, and is intended only 
for 
the use of- the addressee. It is the property of 
Kirkland & Ellis LLP or Kirklas nd & Ellis 
International LLP. 
Unauthorized use, disclosure or copying- of this 
communication or any part thereof is strictly 
prohibited 
and may be unlawful. If you have received this 
communication in - error, please notify us immediately 
by 
return e-mail or by e-mail to - 
[email protected], and 
destroy this communication and all copie- s thereof, 
including all attachments. 
EFTA00213771

. 
EFTA00213772

12/10/2007 04:43 PM 
To -Jay Letkowite 
cc 
bcc 
Subject Meeting on Friday with Ken Starr 
Hi Jay — Will you be attending the meeting on Friday? 
Thank you. 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone-
Fax 
EFTA00213773

EFTA00213774

12/1312007 10:03AM 
To a===ft 
cc 
USAFL 
man, e 
AFLSr 
"Acosta, Alex (USAFLS)" 
bee 
Subject Correspondence 
Dear Jay: Please review the enclosed. I look forward to seeing 
you tomorrow. 
«071213 Villafana Ltr to Lefkovatz final.pdf» 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 
Eta 
Fax 
071213Vilefona Lb to Lelkowaz final.pdf 
EFTA00213775

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
FINERY BY ELECTRONIC MAIL 
Jay P. Lefkowitz, Esq. 
Kirkland & Ellis LLP 
Citigroup Center 
153 East 53rd Street 
New York, New York 10022-4675 
Re: 
Jeffrey Epstein 
Dear Jay: 
500 S Australian Ave, Ste 400 
' 
, FL 33401 
acsimi e 
December 13, 2007 
I am writing not to respond to your asserted "policy concerns" regarding Mr. Epstein's Non-
Prosecution Agreement, which will be addressed by the United States Attorney, but the time has 
come for me to respond to the ever-increasing attacks on my role in the investigation and 
negotiations. 
It is an understatement to say that I am surprised by your allegations regarding my role 
because I thought that we had worked very well together in resolving this dispute. I also am 
surprised because I feel that I bent over backwards to keep in mind the effect that the agreement 
would have on Mr. Epstein and to make sure that you (and he) understood the repercussions of the 
agreement. For example, I brought to your attention that one potential plea could result in no gain 
time for your client; I corrected one of your calculations of the Sentencing Guidelines that would 
have resulted in Mr. Epstein spending far more time in prison than you projected; I contacted the 
Bureau of Prisons to see whether Mr. Epstein would be eligible for the prison camp that you desired; 
and I told you my suspicions about the source of the press "leak" and suggested ways to avoid the 
press. Importantly, I continued to work with you in a professional manner even after I learned that 
you had been proceeding in bad faith for several weeks — thinking that I had incorrectly concluded 
that solicitation of minors to engage in prostitution was a registrable offense and that you would 
"fool" our Office into letting Mr. Epstein plead to a non-registrable offense. Even now, when it is 
clear that neither you nor your client ever intended to abide by the terms of the agreement that he 
signed, I have never alleged misconduct on your part. 
The first allegation that you raise is that I "assiduously" hid from you the fact that Bert 
Ocariz is a friend of my boyfriend and that I have a "longstanding relationship" with Mr. Ocariz. 
EFTA00213776

JAY P. LEFKOWITZ, ESQ. 
DECEMBER 13, 2007 
PAGE 2OF 5 
I informed you that I selected Mr. Ocariz because he was a friend and classmate of two people 
whom 1 respected, and that I had never met or spoken with Mr. Ocariz prior to contacting him about 
this case. All of those facts are true. I still have never met Mr. Ocariz, and, at the time that he and 
I spoke about this case, he did not know about my relationship with his friend. You suggest that I 
should have explicitly informed you that one of the referrals came front my "boyfriend" rather than 
simply a "friend," which is the term I used, but it is not my nature to discuss my personal 
relationships with opposing counsel. Your attacks on me and on the victims establish why I wanted 
to find someone whom I could trust with safeguarding the victims' best interests in the face of 
intense pressure from an unlimited number of highly skilled and well paid attorneys. Mr. Ocariz 
was that person. 
One of your letters suggests a business relationship between Mr. Ocariz and my boyfriend. 
This is patently untrue and neither my boyfriend nor I would have received any financial benefit 
from Mr. Ocariz's appointment. Furthermore, after Mr. Ocariz learned more about Mr. Epstein's 
actions (as described below), he expressed a willingness to handle the case pro bond, with no 
financial benefit even to himself. Furthermore, you were given several other options to choose from, 
including the Podhurst firm, which was later selected by Judge Davis. You rejected those other 
options. 
You also allege that I improperly disclosed information about the case to Mr. Ocariz. I 
provided Mr. Ocariz with a bare bones summary of the agreement's terms related to his appointment 
to help him decide whether the case was something he and his firm would be willing to undertake. 
I did not provide Mr. Ocariz with facts related to the investigation because they were confidential 
and instead recommended that he "Google" Mr. Epstein's name for background information. When 
Mr. Ocariz asked for additional information to assist his firm in addressing conflicts issues, I 
forwarded those questions to you, and you raised objections for the first time. I did not share any 
further information about Mr. Epstein or the case. Since Mr. Ocariz had been told that you 
concurred in his selection, out of professional courtesy, I informed Mr. Ocariz of the Office's 
decision to use a Special Master to make the selection and told him that the Office had made contact 
with Judge Davis. We have had no further contact since then and I have never had contact with 
Judge Davis. I understand from you that Mr. Ocariz contacted Judge Davis. You criticize his 
decision to do so, yet you feel that you and your co-counsel were entitled to contact Judge Davis to 
try to "lobby" him to select someone to your liking, despite the fact that the Non-Prosecution 
Agreement vested the Office with the exclusive right to select the attorney representative. 
Another reason for my surprise about your allegations regarding misconduct related to the 
Section 2255 litigation is your earlier desire to have me perform the role of "facilitator" to convince 
the victims that the lawyer representative was selected by the Office to represent their interests alone 
and that the out-of-court settlement of their claims was in their best interests. You now state that 
doing the same things that you had asked me to do earlier is improper meddling in civil litigation. 
Much of your letter reiterates the challenges to Detective Recarey's investigation that have 
EFTA00213777

JAY P. LEFKowITZ, ESQ. 
DEMMER 13, 2007 
PAGE 3 OF 5 
already been submitted to the Office on several occasions and you suggest that I have kept that 
information from those who reviewed the proposed indictment package. Contrary to your 
suggestion, those submissions were attached to and incorporated in the proposed indictment 
package, so your suggestion that I tried to hide something from the reviewers is false. I also take 
issue with the duplicity of stating that we must accept as true those parts of the Recarey reports and 
witness statements that you like and we must accept as false those parts that you do not like. You 
and your co-counsel also impressed upon me from the beginning the need to undertake an 
independent investigation. It seems inappropriate now to complain because our independent 
investigation uncovered facts that are unfavorable to your client. 
You complain that I "forced" your client and the State Attorney's Office to proceed on 
charges that they do not believe in, yet you do not want our Office to inform the State Attorney's 
Office of facts that support the additional charge nor do you want any of the victims of that charge 
to contact Ms. Belohlavek or the Court. Ms. Belohlavek's opinion may change if she knows the full 
scope of your client's actions. You and I spent several weeks trying to identify and put together a 
plea to federal charges that your client was willing to accept. Yet your letter now accuses me of 
"manufacturing" charges of obstruction of justice, making obscene phone calls, and violating child 
privacy laws. When Mr. Lourie told you that those charges would "embarrass the Office," he meant 
that the Office was unwilling to bend the facts to satisfy Mr. Epstein's desired prison sentence — a 
statement with which I agree. 
I hope that you understand how your accusations that I imposed "ultimatums" and "forced" 
you and your client to agree to unconscionable contract terms cannot square with the true facts of 
this case. As explained in letters from Messrs. Acosta and Sloman, the indictment was postponed 
for more than five months to allow you and Mr. Epstein's other attorneys to make presentations to 
the Office to convince the Office not to prosecute. Those presentations were unsuccessful. As you 
mention in your letter, I -a simple line AUSA —handled the primary negotiations for the Office, and 
conducted those negotiations with you, Ms. Sanchez, Mr. Lewis, and a host of other highly skilled 
and experienced practitioners. As you put it, your group has a "combined 250 years experience" to 
my fourteen. The agreement itself was signed by Mr. Epstein, Ms. Sanchez, and Mr. Lefcourt, 
whose experience speaks for itself. You and I spent hours negotiating the terms, including when to 
use "a" versus "the" and other minutiae. When you and I could not reach agreement, you repeatedly 
went over my head, involving Messrs. Lourie, Menchel, Sloman, and Acosta in the negotiations at 
various times. In any and all plea negotiations the defendant understands that his options are to 
plead or to continue with the investigation and proceed to trial. Those were the same options that 
were proposed to Mr. Epstein, and they are not "persecution or intimidation tactics." Mr. Epstein 
chose to sign the agreement with the advice of a multitude of extremely noteworthy counsel. 
You also make much of the fact that the names of the victims were not released to Mr. 
Epstein prior to signing the Agreement. You never asked for such a term. During an earlier 
meeting, where Mr. Black was present, he raised the concern that you now voice. Mr. Black and 
I did not have a chance to discuss the issue, but I had already conceived of a way to resolve that 
EFTA00213778

JAY P. LEFKOWITZ, ESQ. 
DECEMBER 13, 2007 
PAGE 4 OF 5 
issue if it were raised during negotiations. As I stated, it was not, leading me to believe that it was 
not a matter of concern to the defense. Since the signing of the Non-Prosecution Agreement, the 
agents and I have vetted the list of victims more than once. In one instance, we decided to remove 
a name because, although the minor victim was touched inappropriately by Mr. Epstein, we decided 
that the link to a payment was insufficient to call it "prostitution." I have always remained open to 
a challenge to the list, so your suggestion that Mr. Epstein was forced to write a blank check is 
simply unfounded. 
Your last set of allegations relates to the investigation of the matter. For instance, you claim 
that some of the victims were informed of their right to collect damages prior to a thorough 
investigation of their allegations against Mr. Epstein. This also is false. None of the victims was 
informed of the right to sue under Section 2255 prior to the investigation of the claims. Three 
victims were notified shortly after the signing of the Non-Prosecution Agreement of the general 
terms of that Agreement. You raised objections to any victim notification, and no further 
notifications were done. Throughout this process you have seen that I have prepared this case as 
though it would proceed to trial. Notifying the witnesses of the possibility of damages claims prior 
to concluding the matter by plea or trial would only undermine my case. If my reassurances are 
insufficient, the fact that not a single victim has threatened to sue Mr. Epstein should assure you of 
the integrity of the investigation) 
'There are numerous other unfounded allegations in your letter about document demands, 
the money laundering investigation, contacting potential witnesses, speaking with the press, and the 
like. For the most part, these allegations have been raised and disproven earlier and need not be 
readdressed. However, with respect to the subpoena served upon the private investigator, contrary 
to your assertion, and as your co-counsel has already been told, I dig consult with the Justice 
Department prior to issuing the subpoena and I was told that because I was nos subpoenaing an 
attorney's office or an office physically located within an attorney's office, and because the business 
did private investigation work for individuals (rather than working exclusively for Mr. Black), I 
could issue a grand jury subpoena in the normal course, which is what I did. I also did not 
"threaten" the State Attorney's Office with a grand jury subpoena, as the correspondence with their 
grand jury coordinator makes perfectly clear. 
With regard to your allegation of my filing the Palm Beach Police Department's probable 
cause affidavit "with the court knowing that the public could access it," 1 do not know to what you 
are referring. Ali documents related to the grand jury investigation have been filed under seal, and 
the Palm Beach Police Department's probable cause affidavit has never been filed with the Court. 
If, in fact, you are referring to the Ex Pane Declaration of Joseph Recarey that was filed in response 
to the motion to quash the grand jury subpoena, it was filed both under seal and ex parte, so no one 
should have access to it except the Court and myself. Those documents are still in the Court file 
only because ysa_have violated one of the terms of the Agreement by failing to "withdraw 
[Epstein's] pending motion to intervene and to quash certain grand jury subpoenas." 
EFTA00213779