EFTA00224636

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
First AuLstant U.S. 4liortrty 
99 NE thStreti 
Miam& FL 31132 
DELIVERY BY FEDERAL EXPRESS 
June 3, 2008 
Honorable Mark Filip 
Office of the Deputy Attorney General 
United States Department of Justice 
950 Pennsylvania Avenue, N.W. 
Washington, D.C. 20530 
Re: 
Jeffrey Epstein 
Dear Judge Filip, 
Jeffrey Epstein was a part-time resident of Palm Beach County, Florida.' In 2006, the Federal 
Bureau of Investigation began investi tin alle ations that over a two-year period, Epstein paid 
approximately 28 minor females 
to come to his house for 
sexual favors? In July 2006, the matter was presented to AUSA 
of our West 
Palm Beach branch office to pursue a formal criminal investigation. That investigation resulted in 
the discovery of approximately one dozen additional minor victims. Over the last several months, 
approximately six more minor victims hive been identified. 
AUSA 
has been ready to present an indictment to a West Palm Beach federal grand 
jury since May 2007. The prosecution memorandum and proposed indictment have been extensively 
reviewed and re-reviewed by Southern District of Florida (SDFL) Deputy Chief of the Criminal 
'Epstein has not resided in Palm Beach since he learned of the instant investigation. 
2 Epstein's sexual conduct with the victims included: instructing them to massage and pinch his 
nipples, masturbating in their presence, digitily penetrating them, using a vibrator on their vaginas, 
engaging in oral sex with them, having the victims perform oral sex on Epstein's adult girlfriend, and 
engaging in sexual intercourse, all in exchange for money, ranging from $200 to $1,000 per session. 
Confidential sod Privileged — Attorney Work Product 
EXHIBIT B-123 
EFTA00224636

Division 
hi f o the Criminal Division 
, First Assistant United 
States Attorney 
, United States Attorney R. Alexander Acosta as well as various 
members of the Child Exploitation 
e i 
Sectio (CEOS) at the Department of Justice 
including, but not limited to its Chief, 
. Many of these legal and factual issues 
have been discussed 
roved by Deputy Assistant Attorney General for the Criminal Division 
and the Assistant Attorney General for the Criminal Division (AAG) 
(DAAG) 
Alice S. Fisher, as well as the Criminal Division's Appellate Section and the Office of Enforcement 
Operations regarding the petit policy. 
By May 2007, AUSA 
be an seekin approval from her supervisors to indict 
Epstein. Her immediate supervisor was 
. Mr. 
had served as the Chief of the 
Public Integrity Section at DOJ as well as in several supervisory positions in the SDFL. By mid-
2006, he had returned to his position as the. Deputy Chief of the Criminal Division in West Palm 
Beach (head of the West Palm Beach branch office), after serving as the interim Chief of the Public 
Integrity Section at DOJ at the request of AAG Fisher. By October 2007 Mr. 
would leave 
command were 
Criminal Division Chief, First Assistant USA 
the SDFL to become AG Fi her's Chief of Staffs Above Mr. 
in the SDK's chain of 
and finally, 
U.S. Attorney Acosta. 
Prior to seeking approval to return an indictment, Epstein's legal team had been actively 
working to convince this Office that such action was not warranted. For example, at the end of 2006, 
former Ill 
Attorney and EOUSAExecutiveiiirr Guy Lewis contacted former colleagues 
AUSA 
and, later Deputy Criminal Chief 
when he learned that they were handling 
or involved in supervising the federal investigation of Epstein. In December, former SDFL AUSA 
Lilly Ann Sanchez and 
court also contacted AUSA 
to set a meeting. In advance 
of that meeting, AUSA 
requested documents but that request was refused. Ms. Sanchez 
then contacted AUSA 
, who agreed to meet with M 
hez and Mr. Lefcourt. On February 
1, 2007, Ms. Sanchez and Mr. Lefcourt met with AUSAs 
and 
. as well as a member 
of the FBI, and presented defense counsel's view of the case and promised a willingness to assist in 
the investigation. The SDFL was unpersuaded by their presentation and the investigation continued. 
By the late Spring and early Summer, the focus of the investigation shifted from investigating 
the facts of the victims' claims to Epstein's background, his asserted defenses, co-conspirators, and 
possible witnesses who could corroborate the victims' statements. The investigation also began to 
look into financial aspects of the case, requiring the issuance of several subpoenas. At the time, Mr. 
Lefcourt began leveling accusations of improprieties with the investigation and sought a meeting 
'Mr. 
resigned for private practice on August 3, 2007 and was replaced by 
'Although I,
 am writS this letter, I will continue to refer to myself as 
"First Assistant USA 
' or "FAUSA 
' to help reduce any confusion. 
replaced Mr. 
as the Deputy Chief of the Criminal Division. 
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EFTA00224637

with Criminal Division Chief 
that time, the proposed initial indictment 
package had been reviewed and approved by Mr. 
in West Palm Beach and by attorneys with 
CEOS; however, it awaited review by Mr. 
and FAUSA 
. The SDFL deferred 
presenting the indictment to the grand jury to accommodate the Epstein legal team's request for a 
meeting. We also agreed to wait several weeks for that meeting to occur to allow four of Epstein's 
attorneys to be present and also provided counsel with a list of the statutes that were the subject of 
the investigation. 
On June 26, 2007, Mr. 
Mr. M, 
AUSA 
and FAUSA—, and two 
FBI agents met with Alan Dershowitz, Roy Black, Gerald Lefcourt, and Lilly Ann Sanchez. During 
that meeting, Professor Dershowitz and other members of the defense team presented legal and 
factual arguments against a federal indictment. Counsel for the defense also requested the 
opportunity to present written arguments, which was granted. The arguments and written materials 
provided by the defense were examined by the SDFL and rejected. 
On July 31, 2007, Mr. 
Mr. =, 
AUSA
, and FAUSA 
, and two 
FBI agents met with Roy Black, Gerald Lefcourt, and Lilly Ann Sanchez. On that date, the SDFL 
presented a written sheet of terms that would satisfy the SDFL's federal interest in the case and 
discussed the substance of those terms. See Tab A. One of those terms was: 
Epstein agrees that, if any of the victims identified in the federal investigation file 
suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the U.S. 
District Court for the Southern District of Florida over his person and the subject 
matter. Epstein will not contest that the identified victims are persons who, while 
minors, were victims of violations of Title 18, United States Code, §§ 2422 and/or 
2423. 
During that meeting, the focus was on Mr. Epstein's unwillingness to spend time in prison, and 
various suggestions were raised by defense counsel, including the proposal that he could serve a 
sentence of home confinement or probation. This was repeatedly mentioned by counsel for Epstein 
as being equivalent to a term of imprisonment in a state or federal prison. Epstein's counsel 
mentioned their concerns about his safety in prison, and the SDFL offered to explore a plea to a 
federal charge to allow Epstein to serve his time in a federal facility. Counsel were also presented 
with a conservative estimate of the sentence that Epstein would face if he were convicted: an 
advisory guideline range of 188 - 235 months' incarceration with a five-year mandatory minimum 
prison term, to be followed by lifetime supervised release. Counsel was told that Epstein had two 
weeks to accept or reject the proposal. 
It is critical to note that Ms. Sanchez, one of Epstein's local lawyers, seized upon this method 
of restitution as a condition of deferring federal prosecution. In referring to the 18 U.S.C. § 2255 
method of compensation, Ms. Sanchez stated: 
[t]his would allow the victims to be able to promptly put this behind them and go 
forward with their lives. If given the opportunity to opine as to the appropriateness 
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of Mr. Epstein's proposal, in my extensive experience in these types of cases, the 
victims prefer a quick resolution with compensation for damages and will always 
support any disposition that eliminates the need for trial. 
See attached Tab B, August 2, 2007 letter from Lilly Ann Sanchez to SDFL Criminal Division Chief 
p.2, fn 1. Ironically, it is Epstein's "national" attorneys who are now representing to the 
Deputy Attorney General of the United States in their May 19, 2008 letter that: 
Perhaps most troubling, the USAO in Miami, as a condition of deferring prosecution, 
required a commingling of substantive federal criminal law with a proposed civil 
remedy engineered in a way that appears intended to profit particular lawyers in 
private practice in South Florida with personal relationships to some of the 
prosecutors involved. 
Not only did Epstein's lawyers like the idea of using 18 U.S.C. § 2255 to compensate the victims 
but, they also sought to make their non-incarcerative state proposal even more attractive by offering 
payments to "a charitable organization benefitting victims of sexual assault," "law enforcement 
investigative costs" and "Court and probationary costs." Id. at p. 2. 
Epstein's counsel, still dissatisfied with the Office's review of the case, demanded to meet 
with U.S. Attorney Acosta and to have the opportunity to meet with someone in Washington, D.C. 
To accommodate Roy Black, the meeting was put off until September 7, 2007, de ite the fact that 
the indictment was ready for prefer 
o t 
h grand jury. In the interim, AUSA 
and the 
investigators met with tltiwC
f 
to review, yet again, the evidence an ega theories 
of prosecution. Chief 
strongly supported the proposed indictment and even offered to 
join the trial team and provide additional support from CEOS. 
On September 7, 2007, U.S. Attorney Acosta met with Kirkland & Ellis partners hi 
Lefkowitz 
rd. 
Ken Starr and Ms. Sanchez, along with Chief 
and AUSAsNigga
 
and FAUSA 
"Messrs. Starr and Lefkowitz present 
arguments regarding the sufficiency of the federal interest in the case and other legal and factual 
issues. We discussed those legal arguments and the unanimous opinion of all of the attorneys present 
was in favor of prosecution. During that meeting, Mr. Lefkowitz also offered a plea resolution. His 
offer, in essence, was that Epstein be subjected to home confinement at his Palm Beach home, using 
private security officers who would serve as his "wardens," if necessary. Mr. Lefkowitz expressed 
the belief that such a sentence would be particularly appropriate because, as a wealthy white man, 
he may be the subject of violence or extortion in prison. Finally, Messrs. Starr and Lefkowitz 
expressed the belief that Epstein's extensive philanthropy should be considered in our prosecution 
decision. U.S. Attorney Acosta summarily rejected these proposals, and indicated that the 24-month 
offer presented previously by the SDFL stood. 
'Roy Black did not attend. 
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II 
The issue of the inclusion of a restitution-type remedy for the victims pursuant to 18 U.S.C. 
§ 2255 inoilically raised and discussed at the September 
meeting, and Mt Starr thanked 
AUSA 
for bringing it to his attention as a novel approach to allowing the victims to receive 
essentially federal restitution while allowing a plea to a state charge. After considering everything 
said and written by Epstein's legal team, and after conferring with Chief 
, U.S. Attorney 
Acosta informed Epstein's counsel that the SDFL still intended to proceed to indictment. Since 
counsel indicated a desire to appeal the matter to the Attorney General, the Deputy Attorney General, 
or the Assistant Attorney General for the Criminal Division, U.S. Attorney Acosta agreed to delay 
the presentation of the indictment for two weeks to allow them to speak with someone in 
Washington, D.C., if they so chose. 
Instead, Mr. Epstein elected to negotiate thearosecution A 
ment, and on September 
12, 2007, counsel for the SDFL (AUSAs 
, and 
and counsel for Epstein 
(Messrs. Lefcourt, Leficowitz, and Goldber e 
et with Palm Beach County State Attorney Barry 
Krisher and Assistant State Attorney 
to discuss a plea to an Information in the 
state court that would satisfy the federal interest in the case. As noted on the term sheet of July 31" 
(Tab A), one of those essential terms was a guilty plea to a charge requiring sex offender registration. 
During that meeting, the issue of sex offender registration was raised, and Mr. Goldberger told the 
federal prosecutors that there was no problem, Mr. Epstein would plead guilty to the charge of 
procurement of minors for prostitution (Fl. Stat. 796.03), which was one of the statutes listed on the 
original term sheet. Although the SDFL had wanted Epstein to plead guilty to three different 
offenses, we agreed to this compromise' Of course, the SDFL later learned that, at the time Mr. 
Goldberger made that statement, he incorrectly believed, based upon a statement from ASA 
that Fl. Stat. § 796.03 did not require sex offender registration. 
The parties then began working first on a plea agreement to a federal charge and, when it was 
clear that there was no guarantee that Epstein would serve his sentence in a minimum security prison 
camp, the discussion turned to a Non-Prosecution Agreement. Both the federal plea agreement and 
the Non-Prosecution Agreement included references to § 2255 because neither the contemplated 
federal charges nor the proposed state charges encompassed all of the identified victims. If Epstein 
had been prosecuted under the planned indictment, the identified victims would have been eligible 
for restitution and damages under § 2255. As explained above, one of our interests, which had to 
be satisfied by the Non-Prosecution Agreement, was providing appropriate compensation to the 
victims. This provision of the Agreement was heavily negotiated. As Mr. Lefkowitz wrote in his 
November 2r e-mail to FAUSA 
, Epstein "offered to provide a restitution fund for the 
alleged victims in this matter; however, that option was rejected by [our] Office." That option was 
rejected for several reasons. First, the SDFL does not serve as legal representatives to the victims and 
has no authority to bind victims, nor could it provide a monetary figure that would represent a "loss" 
amount for restitution purposes. Second, there would be no legal basis for federal restitution without 
7 Another significant compromise reached at the meeting was a reduction in the amount of jail 
time - from 24 months down to 18 months, which would be served at the Palm Beach County Jail rather 
than a state prison facility. 
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I. a 
a conviction for a federal offense. And, third, it was the U.S. Attorney's belief that the SDFL should 
not be put in the position of administering a restitution fund. Our § 2255 proposal put the victims 
in the same position that they would have been in if we had proceeded to trial and convicted Epstein 
of his crimes, with the exception that the victims were provided with counsel. The appointment of 
counsel was not such a benefit to the victims but, rather, was done, in part, to benefit Epstein by 
allowing him to try to privately negotiate a group resolution of all claims with one attorney. Epstein 
and his lawyers agreed with this alternative. 
The negotiation of the Agreement was lengthy and difficult. Mr. Lefkowitz and AUSA 
went through several drafts of both a federal plea agreement and a Non-Prosecution 
Agreement. Throughout these negotiations, when a member of the defense team was dissatisfied 
with the SDFL's position, it was repeatedly appealed throughout the Office. So several members of 
the defense team spoke with the chain of command regarding the terms of the Agreement, including 
the § 2255 provisions. At the eleventh hour, when Epstein's legal team realized that Fl. Stat. 796.03 
would require him to register as a sex offender, they sought to change the most essential term of the 
agreement - a term that Messrs. Goldberger, Lefkowitz, and Lefcourt had specifically agreed to at 
the September 12:' meeting with the State Attorney's Office - asking to allow Epstein to plead to a 
charge that would not require registration. When this was rejected, several members of the defense 
team appealed directly to U.S. Attorney Acosta which also failed. When that failed, according to 
press reports, apparently Mr. Lefcourt "leaked" a letter intended for the U.S. Attorney to the press 
containing the reasons why he/Lefcourt did not believe Epstein should have to register. See October 
9, 2007 New York Post article attached at Tab C. 
Prior to signing the Non-Prosecution Agreement, Mr. Epstein's defense team included Ken 
Starr, Jay Lefkowitz, Lilly Ann Sanchez, Alan Dershowitz, Gerald Lefcourt, Roy Black, Guy Lewis, 
Martin Weinberg, Jack Goldberger, Stephanie Thacker', and the associates at Kirkland & Ellis who 
conducted research on discrete issues. This impressive legal team reviewed the Agreement and 
counseled Epstein. Based upon that counsel, Epstein decided that it was in his best interest to execute 
the Non-Prosecution Agreement which was signed on September 24, 2007 by Mr. Lefcourt, Ms. 
Sanchez and Epstein. A copy of which is attached hereto as Tab D. The core principles of the 
Agreement are incarceration, registration as a sex offender and a method of compensation.' 
Furthermore, and significantly, Epstein agreed that he had the burden of ensuring compliance of the 
:Ms. Thacker had recently resigned from CEOS as a Trial Attorney and entered private practice. 
9 Specifically, the Agreement mandates, inter alia, (I) a guilty plea in Palm Beach County 
Circuit Court to solicitation of prostitution (Fl. Stat. § 796.07) and procurement of minors to engage in 
prostitution (Fl. Stat. § 796.03) (an offense that requires him to register as a sex offender); (2) a 30-
month sentence including 18 months' incarceration in county jail; (3) a methodology to compensate the 
victims identified by the United States utilizing 18 U.S.C. Section 2255 such that they would be placed in 
the same position as if Epstein had been convicted of one of the enumerated offenses set forth in Title 
18, United States Code, § 2255; (4) entry of the guilty plea and sentence no later than October 26, 2007; 
and (5) the start of the above-mentioned sentence no later than January 4, 2008. 
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Agreement with the Palm Beach County State Attorney's Office and the Judge of the I5°' Judicial 
Circuit and "that the failure to do so will be a breach of the agreement' (emphasis added). To this 
day, the SDFL has never divulged its evidence to Epstein's lawyers. 
Within a week of the execution of the Agreement, the SDFL unilaterally proposed to divest 
its right to select the attorney representative for the victims. Contrary to Messrs. Starr and Whitley's 
recent assertion that this was "engineered in a way that appears intended to profit particular lawyers 
in private practice in South Florida with personal relationships to some of the prosecutors involved," 
it was done to avoid even the appearance of favoritism in the selection of the attorney representative. 
As a result, the parties executed an addendum which documented the SDFL's right to assign the 
selection of an attorney representative to an independent third-party. A copy of the October 29,2007 
Addendum is attached hereto as Tab E. The parties subsequently agreed that retired Federal District 
Court Jude Edward B. 
should be that independent third-pasty/special master. Ultimately, 
Judge 
selected Robert C. Josefsberg of the law firm of Podhurst, Orseck, Josefsberg, et a1.10
During this same time frame, Epstein lawyer Jay Lefkowitz sought to delay the entry of his guilty 
plea and sentence. After the SDFL accommodated his request (from October 26"' to November 20th), 
Mr. Starr began taking issue with the methodology of compensation, notification to the victims, and 
the issues that had been previously considered and rejected during negotiations, i.e., that the conduct 
does not require registration and the contemplated state and federal statutes have no applicability to 
the instant matter. 
In response to Mr. Starr's protests, the SDFL offered numerous and various reasonable 
modifications and accommodations which ultimately resulted in U.S. Attorney Acosta's December 
19, 2007 letter to Lilly Ann Sanchez. See attached Tab F. In that letter, U.S. Attorney Acosta tried 
to eliminate all concerns which, quite frankl the SDFL was not obligated to address, let alone 
consider. In consultation with DAAG 
Mr. Acosta proposed the following language 
regarding the 2255 provision: 
"Any person, who while a minor, was a victim of a violation of an offense 
enumerated in Title 18, United States Code, § 2255, will have the same rights to 
proceed under § 2255 as she would have had, if Mr. Epstein been tried federally and 
convicted of an enumerated offense. For purposes of implementing this paragraph, 
the United States shall provide Mr. Epstein's attorneys with a list of individuals 
whom it was prepared to name in an Indictment as victims of an enumerated offense 
by Mr. Epstein. My judicial authority interpreting this provision, including any 
authority determining which evidentiary burdens if any a plaintiff must meet, shall 
consider that it is the intent of the parties to place these identified victims in the same 
position as they would have been had Mr. Epstein been convicted at trial. No more; 
no less." 
I° Due to the subsequent objections raised by Epstein's counsel, Mr. Josefsberg was never given 
the opportunity to become the attorney representative. 
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Mr. Starr also objected to the SDFL's intention to notify the victims pursuant to 18 U.S.C. 
§ 3771. In response to Mr. Starr's concerns, USA Acosta again consulted with DAAG 
who advised him to make the following proposal: "[w]e will defer to the discretion of the State 
Attorney regarding whether he wishes to provide victims with notice of the state proceedings, 
although we will provide him with the information necessary to do so if he wishes." These proposals 
were immediately rejected by Epstein in Mr. Leflcowitz's December 26, 2007 correspondence to 
USA Acosta. 
At our December 14, 2007 meeting at the U.S. Attorney's Office in Miami, counsel for 
Epstein articulated that it was a "profound injustice" to require Epstein to register as a sex offender 
and reiterated that no federal crime, especially 18 U.S.C. § 2422(b), had been committed since the 
statute is only violated if a telephone or means of interstate commerce is used to do the persuading 
or inducing. This particular attack on this statute had been previously raised and thoroughly 
considered and rejected by the SDFL and CEOS prior to the execution of the Agreement. Epstein's 
lawyers also argued that the facts were inapplicable to the contemplated state statutes and that he 
should not have been allowed to have been induced into the Agreement because the facts were not 
what he understood them to be. To reiterate, the SDFL has never divulged its evidence to anyone on 
the Epstein legal team. Once counsel for Epstein failed to persuade us that federal involvement was 
inappropriate, they mounted an aggressive campaign to defer federal prosecution. When we refused 
to compromise on anything except the length of incarceration, they finally executed the Non-
Prosecution Agreement. 
Subsequent to the December 14, 2007 meeting, the SDFL received three letters from Mr. 
Letkowitz and/or Mr. Starr which expanded on some of the themes announced in the December 14" 
meeting. Essentially, trying to portray the SDFL as trying to coerce a plea to unknown allegations 
and incoherent theories. In his December 17, 2007 correspondence, Mr. Letkowitz decreed that 
Epstein's conduct did not meet the requirements of one of the state statutes Epstein agreed to plead 
guilty to - procurement of minors to engage in prostitution (Fl. Stat. § 796.03); that Epstein's 
conduct does not require registration under Florida law in contravention of the September 241h
Agreement; and the State Attorney's Office does not believe the conduct is registrable. On December 
21, 2007, Mr. Lefkowitz rejected the U.S. Attorney's proposed resolution of the 2255 provision 
because they "strongly believe that the provable conduct of Mr. Epstein with respect to these 
individuals fails to satisfy the requisite elements of either 18 U.S.C. Section[s] 2422(b) ... or ... 
2423(6)." In his December 26, 2007 correspondence, he stated that "we have reiterated in previous 
submissions that Mr. Epstein does not believe he is guilty of the federal charges enumerated under 
section 2255" and requiring "Mr. Epstein to in essence admit guilt, though he believes he did not 
commit the requisite offense." 
The SDFL reiterated time and time again that it had never wanted nor expected Epstein to 
plead guilty to a charge he did not believe he committed and repeatedly offered to dissolve the 
agreement to allow Epstein to contest the charges in the court system. As a result, the SDFL obliged 
his request for an independent de now review of the investigation and facilitated such a review at 
the highest levels of the Department of Justice. As you know, on May 15, 2008, after months of 
considering the matter, the Criminal Division considered whether there is a legitimate basis for the 
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SDFL to proceed with a federal prosecution of Mr. Epstein. CEOS Section Chief 
concluded that "federal prosecution 
improper or inappropriate."See attached May 15, 
2008 letter from CEOS Section Chief 
to Jay Lefkowitz. On May 19, 2008, I notified Mr. 
Lefkowitz that the SDFL would give Epstein a full two weeks (close of business on Monday, June 
2, 2008) to comply with the terms and conditions of the Non-Prosecution Agreement, as modified 
by the USA's December 10 letter to Ms. Sanchez." Therefore, despite the fact that the investigation 
has identified several more victims, the SDFL is still offering Epstein the opportunity to comply with 
the terms and conditions of the Non-Prosecution Agreement. 
The SDFL was recently notified that the Office of the Deputy Attorney General has agreed 
to consider additional allegations not considered by CEOS which were recently raised in 
correspondence by two former high-ranking members of the Department of Justice - Ken Starr and 
Joe Whitley. On May 28,2008,1 notified Mr. Letkowitz by e-mail that the SDFL has postponed the 
June 2, 2008 deadline until the DAG's Office has completed its review of this matter. Their 
correspondence to the DAG alleges that the SDFL's investigation lacks integrity because it has 
leaked "highly ill 
al aspects" of the investigation and negotiations to the New York Times 
and that FAUSA 
directed some of the victims to my former law firm. They also claim that 
the "unprecedented extension of federal law" by the SDFL suggests that this is politically motivated 
because Epstein is a prominent figure with "c
 ties to former President Clinton." Messrs. Starr 
and Whitley go on to claim that FAUSA 
unilaterally, arbitrarily and unnecessarily imposed 
a June 2, 2008 deadline in order to prevent Epstein from seeking your Office's review and that "the 
unnecessary deadline is even more problematic because Mr. Epstein's effort to reconcile the state 
charge and sentence with the terms of the Agreement requires an unusual and unprecedented 
threatened application of federal law." 
1. 
The Alleged "Leak" to the New York Times. 
AUSA 
became involved in this matter in his capacity as back up for the 
District's Public Information Officer (PIO). While the District's PIO was on annual leave, he was 
the acting PIO during the first week of January 2008. The entirety of his conduct in connection with 
the Epstein matter began on January 2, 2008 and ended on January 7, 2008." Specifically, his 
contact involved five telephone conversation with Landon Thomas, a reporter for the New York 
Times. These conversations occurred on I) the morning of January 2, 2008, 2) the afternoon of 
January 2, 2008, 3) the afternoon of January 3, 2008, 4) the afternoon of January 4, 2008, and 5) the 
afternoon of January 7, 2008. 
" Mr. Lefkowitz was placed on notice on February 25, 2008, that in the event that CEOS 
disagreed with Epstein's position, Epstein would have one week to comply with the terms and conditions 
of the Agreement, as modified by the USA's December 19' letter to Ms. Sanchez. 
"AUSA 
has self-reported to the Office of Professional Responsibility. 
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A. 
The Morning ofJanuary 2, 2008. 
AUSA 
began his conversation with Mr. Thomas by explaining that he was the 
acting PIO for the week and that he had received Mr.Thomas's December 31, 2007 e-mail requesting 
an interview and asking for comments on the following five statements." First, "that in the summer 
of 2005 the palm 
lice de rtment referred the Epstein case to you." Second, "that the case 
is being overseen by 
, and above him, R. Alexander Acosta." Third, "that Mr. Acosta 
has made child pornography a focus are [sic) for your office." Fourth, "that this summer your office 
gave Mr. Epstein an ultimatum: plead guilty to a charge that would require him to register as a sex 
offender, or the government would release a 52 page indictment, charging him with crimes that could 
include procuring sex for a third party or engaging in sexual tourism. Both of these charges carry jail 
sentences of as much as 15 years." Fifth, "that your office S. 
Epstein and his lawyers: we are 
ready to pull the trigger!" Sixth, "I also wanted to ask Mr. 
about his role in a case involving 
Jonathan Zirulnikoff and his daughter earlier this year!' 
At the outset, 
said that he could not comment on any specific pending matters and 
that he would do his best to answer some of his questions. Thomas said that his questions were 
based, in part, upon conversations that he had already had with members of Mr. Epstein's defense 
team, prior published reports of a pending State case against Mr. Epstein and public information 
available through the State Court system. 
refused to answer the first question. As to the second question, 
told him 
that any matter arising out of conduct in Palm Beach County, was prosecuted by our West Palm 
Beach branch office. He also told him that as First Assistant, the FAUSA had supervisory authority 
over all AUSAs throughout the District. In turn, the FAUSA answered directly to the U.S. Attorney. 
In response to the third 
discussed the difference between child 
exploitation and child pornography. 
said that federal crimes involving child exploitation 
were one of several focus points of our Office. He further explained that in addition to traditional 
federal areas of prosecution the other focus points included health care fraud and gang prosecutions. 
refused to answer the fourth and fifth topics but did discuss the general nature of 
pre-trial proceedings in federal court. He said that the SDFL does not offer ultimatums, nor are we 
in the business of issuing ultimatums. He explained that in cases where a party wants to plead guilty 
prior to indictment, we will discuss the parameters of guilty pleas and that people always have the 
to trial if they choose to do so and that we do not favor one resolution over the other. 
told Mr. Thomas that he would not discuss his specific question about Mr. Epstein's 
lawyer's statement that someone from our Office told them that "we are ready to pull the trigger." 
"After reviewing his e-mail, AUSA 
discussed the matter with U.S. Attorney Acosta. 
Pursuant to USAM 1-7.530 and the Media Relations Guide, Section Ill D2, after consultation with and 
prior approval from the US Attorney, he called Mr. Thomas on the morning of January 2nd. 
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Nor would he discuss anything about who might or might not be representing Mr. Epstein. 
told Mr. Thomas that he should not allow himself to be spun one way or the other in response to 
statements Mr. Thomas said he had received from attorneys who said that they represented Mr. 
Epstein. 
ended the conversation by telling Mr. Thomas that he would check further into 
his sixth and final topic and get back to him later in the day. 
B. 
Afternoon ofJanuary 2, 2008. 
informed Mr. Thomas that in regard to his sixth topic, the SDFL had no reason 
to question FAUSA 
judgment or integrity. He also said that this particular subject matter 
was a private matter that FAUSA 
did not want to discuss with him." Mr. Thomas told him 
that if he had any further questions, he would call back. 
C. 
Afternoon ofJanuary 3, 2008. 
This call was in response to a voice mail message that Mr. Thomas had left regarding legal 
issues involving specific state and federal statutes. Specifically, Mr. Thomas had some questions 
about the burden of proof and strict liability in some state and federal statutes that governed illegal 
sexual activity. Again, 
told him that he would not discuss any specific cases, but that he 
would assist him in understanding the statutes about which he had some questions. 
explained that some statutes contained defenses that must be proven by a defendant, while there were 
other statutes that did not require a defendant to affirmatively prove a defense. The discussion 
centered around Title 18, United States Code, § 2423(g). Once again, Mr. Thomas told 
that if he had any further questions, he would call back. 
D. 
Afternoon ofJanuary 4, 2008. 
This was another call in response to a voice mail message that Mr. Thomas had left regarding 
some additional questions. 
prefaced the conversation by saying that he would not discuss 
any specific cases. The conversation centered around three specific statutes, 18 United States Code, 
§ 2422(b), 18 United States Code, § 1591, and 18 United States Code, § 2423(b) as well as the 
The case involving "Jonathan Zirulnikoff" involved a March 7, 2007 early morning attempted 
break-in of my' 
house. Zirulnikoff, age 19 at the time, confessed and said that he wanted to 
"talk" to my daughter who was then 16. He also confessed to a prior unrelated break in which Zirulnikoff 
caressed the inner thigh of a 15 year old female. Zirulnikoff who had graduated from my daughter's high 
school in June 2006, dated my daughter's friend and had little if any contact with my daughter for over 
one year. Zirulnikoff negotiated a plea deal, over my objection, with the Miami-Dade State Attorney's 
Office to a misdemeanor trespass. That conviction resulted in a sentence of two years probation and a 
withhold of adjudication upon successful completion of his probationary period. Since this information 
'mi
ddy irrelevant to the facts and issues in the instant Epstein matter, I refused to allow Mr. 
to comment about this matter to Mr. Thomas. Furthermore, none of this information had been 
publicized and, upon information and belief, only one member of Epstein's legal team knew anything 
about this matter, my former colleague, Lilly Ann Sanchez. 
Confidential and Privileged— Attorney Work Product 
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EFTA00224646

burden of proof and the applicability of affirmative defenses. They discussed the difference between 
an attempt and a substantive charge pursuant to § 2422(b) and how that affected the government's 
burden of proof vis-a-vis the age of a child. They also discussed the fact that a charge pursuant to 
§ 1591 required the government to prove that the defendant had actual knowledge of the age of the 
victim. Finally, they discussed the fact that if the government was charging a defendant with 
traveling to engage in prostitution, pursuant to § 2423(b), there was an affirmative defense available 
to the defendant regarding the reasonable belief of the defendant about the age of the victim. 
E. 
Afternoon of January 7, 2008, 
This final call was made after the U.S. Attorney and FAUSA 
bad received a call from 
a member of Mr. Epstein's defense team alleging that the SDFL had provided case specific 
information to the media. 
called Mr. Thomas who acknowledged that both before and 
after each of the above-mentioned conversations, he had also called attorneys who were representing 
Mr. Epstein on his pending State charges. Mr. Thomas also acknowledged that all of our prior 
conversations had been about general legal issu an t at 
never spoke about any specific 
case. Since the January 7, 2008 conversation, 
has not had any further contact with Mr. 
Thomas. 
2. 
(May 5, 2001- October 1, 2001). 
Seven years ago, I resigned from the SDFL for private practice. Less than five months later, 
I resigned from the law firm and returned to the SDFL. Public records reflect the following: on May 
8, 2001, articles of a 
ent w e fi 
with the Florida Division of 
rations to reflect that 
the firm name of ' 
' was changed to ` 
' on 
May 7, 2001. I joined the firm at that time and remained a non-equity partner until on or a ut 
October 1, 2001. At that time, 1 resigned from the firm and returned to the SDFL. Since I never had 
an equity interest in the firm, I never retained an interest in the firm. That was over six and one half 
years ago. 
Unbeknownst to FAUSA 
, on July 2, 2002, articles 
amen 
ent were filed with the 
Florida Division of 
o fl
t the firm name of 
was changed back to 
" The article of amendment indicates the amen ment 
was adopted on July 1, 2002, without shareholder action. Although the filing was not immediate 
upon my departure from the law firm, it pre-dated for years any dealings with the subject case now 
r on i 
in 
h
DF 
Recently, I learned that there is a reference to the law finn of 
' on the Florida Bar website, under a section called "Find A 
Lawyer." This reference appears when Stuart Mermelstein's name and information is accessed. To 
reiterate, since October 2001, I have had no relationship with that law firm, financial or otherwise, 
and no input or control over the firm's filings with the Florida Division of Corporations and/or the 
Florida Bar. 
On 
08, at approximately 1:15 pm, I received a call from Jeffrey 
Herman of 
. Herman said that he was planning to file a civil lawsuit the next 
Confidential and Privileged— Attorney Work Product 
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week against Jeffrey Epstein. He said that his clients were frustrated with the lack of progress of the 
state's investigation and wanted to know whether the SDFL could file criminal charges even though 
the state was looking into the matter. I told Herman that I would not answer any question related to 
Epstein — hypothetical or otherwise. I asked him how his clients retained him and he said that it was 
through another lawyer. I then specifically asked him whether the referral was the result of anyone 
in law enforcement contacting him and/or the other lawyer. He said "no." At the conclusion of the 
conversation, I reiterated and confirmed with him that I had refused to answer any questions he asked 
of me. I immediately documented this conversation an informed the U.S. Attorney who informed 
Litigation Counsel and Ethics Advisor 
. AUSA ■ 
opined that he did not see a 
conflict. As soon as I -became aware of these allegations, I reported myself to the Office of 
Professional Regulation on or about April 21, 2008. 
3. 
The Alleged Unprecedented Extension of Federal Law and the Allegations of 
Political Motivation for the Prosecution. 
It is my hope that this letter has sufficiently explained how thoroughly this matter has been 
reviewed, how seriously the issues have been considered, and how additional delays may adversely 
affect the case going forward and, more importantly, the victims. I have attached the proposed draft 
indictment for you to consider the nature and gravity of the crimes. See Tab G. You are invited to 
evaluat w 
er I, along with U.S. Attorney A
minal DivisiSiefs 
and, later 
Deputy Criminal Division Chiefs 
followed by 
and AUSA 
have somehow steered this investigation toward "an unprecedented extension of federal 
law"despite being simultaneously and/or subsequently reviewed by CEOS, DAAG 
, and 
AAG Fisher. I also hope that the reputations of the above-mentioned professional prosecutors 
combined with the documented layers of methodical and thorough review of all issues raised by 
Epstein are enough to summarily dismiss the idea that this matter is politically motivated. It seems 
incomprehensible how Messrs. Starr and Whitley could expectfiirther review when the due process 
rights of their client have been considered and reconsidered to the point of absurdity. 
With respect to the other allegations of misconduct leveled against investigators and 
prosecutors, similarly false allegations were made against the local police detective who first 
investigated the case. Those false allegations apparently were accepted as true and were not 
investigated or challenged by the State Attorney's Office and, when coupled with the immense 
pressure brought to bear upon the State Attorney by some of these same lawyers who represent 
Epstein today, resulted in a single felony charge related to only two of the more than 20 victims 
identified in the state investigation. Contrary to the claims of Epstein's attorneys, the SDFL is not 
trying to prosecute Epstein more harshly because of his political friends or his financial status; rather, 
the SDFL is attempting to follow Department policy by treating Epstein like all other criminal 
defendants — charging him with the most serious readily provable offenses. The SDFL has even 
continued to allow Epstein the opportunity to perform his obligations under the Non-Prosecution 
Agreement despite his numerous breaches of and attacks on the terms to which he already agreed. 
Without attempting to address each and every allegation, I would like to highlight some of 
the misstatements contained in counsels' letter, to provide some sense of counsels' conduct 
Confidential and Privileged —Attorney Work Product 
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EFTA00224648

throughout this case, particularly after their attempts at legal persuasion failed. Throughout the case, 
counsel have misrepresented the facts of the case to our Office, CEOS, and the press. For example, 
Epstein's counsel reference to this case as "precedent-shattering," suggests that all of the victims 
were at least 16 years old, and that the conduct "was purely local in nature." The SDFL has 
prosecuted several "sex tourism" cases where the "john" communicated via telephone with an 
undercover "pimp" in the SDFL to meet minor females to engage in prostitution. All were charged 
and convicted of violating 18 U.S.C. § 1591. The SDFL has charged and convicted a 21-year-old 
man of violating 18 U.S.C. § 2423 when he traveled to Florida to meet his 14-year-old girlfriend and 
later digitally penetrated her. The SDFL has prosecuted numerous violations of 18 U.S.C. § 2422 
where the "facility of interstate commerce" — generally the intemet and telephones — are used by a 
defendant and an undercover pretending to be the parent of a minor, to arrange for a meeting that the 
defendant hopes will result in sexual activity. There is nothing extraordinary about Epstein's case 
except the large number of victims involved. 
Epstein's counsel neglected to inform you that the age range of the victims includes girls as 
young as 14, and glosses over the fact that Epstein did not simply engage in "solo self-pleasuring" 
in front of the victims. Instead, with each visit, he pressured the victims to allow him to engage in 
more and more sexual activity — fondling breasts and vaginas, digital penetration, use of a vibrator 
on their vaginas, performing oral sex on them, having them perform oral sex on his adult girlfriend, 
and engaging in sexual intercourse. Counsel also neglected to inform you that many girls did 
affirmatively tell Epstein their true ages and he told several that he "did not care about age." 
Epstein's conduct was not "purely local." He and his assistants called and sent text messages 
to victims in Palm Beach County from other states to arrange "appointments" for his upcoming visits 
to Palm Beach. And, while in Palm Beach, Epstein and his assistants called victims in New York 
to arrange "appointments" for his return to New York. Epstein wired money to some victims and 
sent gifts through the mails. This case falls squarely within federal jurisdiction. 
Epstein also falsely claims that certain facts related to the resolution of the case were hidden 
and later discovered by his lawyers. For example, they complain about the proposed use of a 
guardian ad litem, stating that "Mr. Epstein's 
established that all but one of these 
individuals were adults, not minors." It was AUcSilli 
who told Epstein's counsel that all of 
the victims but one had already reached the age of majority, which was one reason why the guardian 
ad litem procedure proposed by Epstein's counsel would not work. Likewise, AUSA 
disclosed to Epstein's counsel that one of the five attorney-representatives that she recommen 
for consideration by Epstein's counsel was a "good friend" of a "good friend." Despite the disclosure 
of this relationship, Epstein's counsel selected that person, before the SDFL, on its own, decided to 
use an independent Special Master to make the selection. 
Epstein's counsel states that the "USA() eventually asserted that it could not vouch for the 
veracity of any of the claims that these women might make," but neglects to disclose that the SDFL 
made that statement at Epstein's request to avoid the suggestion that the SDFL was involving itself 
in the outcome of civil litigation. 
Confidential sod Privileged — Attorney Work Product 
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Epstein's counsel have repeatedly attacked the SDFL and the FBI for classifying the victims 
as "victims." As you know, all Justice Department employees have the obligation to identify victims 
and to notify them of their rights. "Victims" are defined by law, not by self-selection. The girls 
whom have been identified by the FBI and the SDFL fall within the legal definition — they were all 
minors who engaged in illicit sexual activity with Jeffrey Epstein, at his request, in exchange for 
money. From interviewing them, the FBI Special Agents, the FBI Victim-Witness Coordinator, and 
AUSA 
all feel confident that they suffered harm, in a multitude of ways, by their 
interaction with Epstein. 
Finally, in contrast to Epstein's counsel allegation that my June 2, 2008 deadline was 
"arbitrary, unfair, and unprecedented," please consider that Mr. Lefkowitz has known since February 
that in the event that CEOS disagreed with his position, Epstein would be given one-week to comply 
with the Non-Prosecution Agreement. Subsequent to the receipt of CEOS Section Chief 
May 15, 2008 letter, I notified Mr. Lefkowitz that Epstein would have a MI two-weeks 
to comply with the Non-Prosecution Agreement as modified by the December 19' letter to Ms. 
Sanchez. We believe it is finally time to shift the focus from Epstein's due process rights to treating 
him like all other similarly situated criminal defendants and perhaps, most importantly, to consider 
the rights of his victims. Continued delays adversely effect the case and the victims in the following 
ways: 
(1) 
at the time of the offenses, the victims ranged in age from 14 to 17 years old. The 
change in physical appearance of many of the victims since then has been dramatic. 
Epstein has been claiming that he did not know they were minors. Obviously, the 
older they look when the case is at issue, the harder it will be to overcome that 
defense; 
(2) 
it allows Epstein's lawyers to conduct depositions of the victims in the pending state 
criminal case and allows his private investigators to further harass and intimidate the 
victims; 
(3) 
more victims will seek the services of civil lawyers to file lawsuits thus allowing 
Epstein to make more powerful arguments demeaning the credibility of the victims; 
(4) 
the prosecutors and agents may retire, transfer and/or leave the Department for other 
opportunities thus affecting the potential outcome and prosecutorial resources. 
Additionally, several of the victims have relocated thus increasing the likelihood that 
crucial witnesses will be lost; 
(5) 
the SDFL has afforded more consideration to Epstein's arguments than any other 
defendant in my years of being the FAUSA and, before that, the Chief of the 
Criminal Division (January 1, 2004 to the present). I believe that we have been 
disproportionally fair to Epstein at the expense of other matters; and 
(6) 
prolonged delay may adversely affect the statute of limitations for some of the 
victims. 
Confidential and Privileged - Attorney Work Product 
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EFTA00224650

On behalf of the SDFL and the victims in this case, please expedite the review and decision 
of the issues under consideration. 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
Ends. 
cc: 
Chief 
Assistant U.S. Attorney 
Assistant U.S. Attorney 
By: 
First Assistant United States Attorney 
Confidential and Privileged — Attorney Work Product 
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EFTA00224651

CONFIDENTIAL PLEA NEGOTIATIONS 
TERMS OF EPSTEIN NON-PROSECUTION AGREEMENT 
■ 
Epstein pleads guilty (not nolo contendere) to an Information filed by the 
Palm Beach County State Attorney's Office charging him with: 
(a) 
lewd and lascivious battery on a child, in violation of Fl. Stat. 
800.04(4); 
(b) 
solicitation of minors to engage in prostitution, in violation of Fl. 
Stat. 796.03; and 
(c) 
engaging in sexual activity with minors at least sixteen years of age, 
in violation of Fl. Stat. 794.05. 
■ 
Epstein and the State Attorney's Office make a joint, binding 
recommendation that Epstein serve at least two years in prison, without any 
opportunity for withholding adjudication or sentencing; and without 
probation or community control in lieu of imprisonment. 
■ 
Epstein agrees to waive all challenges to the information filed by the State 
and the right to appeal. 
■ 
Epstein agrees that, if any of the victims identified in the federal 
investigation file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest 
the jurisdiction of the U.S. District Court for the Southern District of 
Florida over his person and the subject matter. Epstein will not contest that 
the identified victims are persons who, while minors, were victims of 
violations of Title 18, United States Code, Sections(s) 2422 and/or 2423. 
■ 
After Epstein enters his state court plea and is sentenced, the FBI and the 
U.S. Attorney's Office will close their investigations. 
EFTA00224652

cy g FOWLERWHITE 
BURNETT 
MUMM • FORT LAUDERDALE • WEST PALM BEACH • ST. PETERSBURG 
August 2, 2007 
Mr. 
Chief, Criminal Division 
United States Attorney's Office 
Southern District of Florida 
99 NE 4 Street 
Miami, Florida 33132 
Re: Jeffrey Epstein 
ESPIINIO SANTO PLAZA 
FOurnEENTII FLOOR 
1 395 BRICKELL AVE Nur 
MIAMI FLORIDA 3313 I 
TELEPHONE 
FACSImitE 
YNAV.FOWLERoATIITE.COM 
LILLY ANN SANCHEZ 
DIRECT PRONE NO.: 
DIRECT FACSIMILE No.: 
Dear.: 
As we discussed at Tuesday's meeting, and consistent with our view that no 
federal prosecution should lie in this matter, Mr. Epstein is prepared to resolve this 
matter via a state forum. We are in receipt of your memo regarding same and as the 
dynamics of the meeting did not allow for us to fully detail our proposal, we do so 
now. We believe that our respective positions are not very far apart and that a 
mutually agreeable resolution can be reached that will accomplish the interests of the 
United States Attorney's Office as well as those of the community. 
We welcomed your recognition that a state prison sentence is neither 
appropriate for, nor acceptable to, Mr. Epstein, as the dangers of the state prison 
system pose risks that are clearly untenable. We acknowledge that your suggestion 
of a plea to two federal misdemeanors was an attempt to resolve this dilemma. Our 
proposal is significantly punitive, and if implemented, would, we believe, leave little 
doubt that the federal interest was demonstrably vindicated. 
The Florida state judicial system, unlike the federal system, provides for 
numerous types of onerous sanctions after a defendant is remanded to the custody of 
the state. The sentence is tailored to the needs of the local community and the risk 
posed by a specific defendant. After a great deal of thought, our proposal consists 
of both a severe supervised custody, with an assurance that any violation would result 
in the immediate implementation of the two year period of incarceration. We must 
keep in mind that Jeffrey Epstein is a 54-year old man who has never been arrested 
before. He has lived an otherwise exemplary life, characterized by both many 
charitable contributions and philanthropic acts. His reputation has suffered 
significantly as a result of his poor judgment in these matters. He is well aware of the 
ramifications of his past behavior and, accordingly, there is no concern, whatsoever, 
that he will re-offend. 
FOWLER WHITE BURNETT P.A. 
EFTA00224653

Page 2 
The following proposal is offered as an assurance to the community that the 
goals of appropriate punishment and rehabilitation arc attained. 
We will agree to a sentence of two years in state prison pursuant to Florida 
Statute 948.012(2) which permits a split sentence whereby Mr. Epstein will be 
sentenced to a term of supervised custody, followed by a period of incarceration. 
Supervised custody in the state system includes potential daily surveillance, 
administered by officers with restricted case loads. Supervised custody is an 
individualized program in which the freedom of Mr. Epstein is limited to the 
confines of his residence with specific sanctions imposed and enforced. See Florida 
Statute 948.001(2). Should Mr. Epstein successfully complete the terms and 
conditions of his custody, the Judge will eliminate the incarcerative portion of the 
sentence. If Mr. Epstein, however, fails to comply with the conditions of his 
supervised custody. The period of incarceration will be immediately implemented. 
We, therefore, propose the following: 
Two years supervised custody with the following mandatory and special 
conditions: 
o Confinement to home 
o Report to a community control officer at least once a week or more 
often as directed by the officer 
o Permit a community control officer to visit him unannounced at home 
at any time, day or night 
o Obtain psychological counseling 
o No unsupervised contact with all the victims in the instant case 
• 
Perform community service 
o Payment of Restitution 
o Application of 18 U.S.C. § 2255' 
• 
Payment of a contribution of a defined amount to a charitable 
organization benefitting victims of sexual assault 
o Payment of Court and probationary costs 
o Payment of law enforcement investigative costs 
o Submit to random drug testing 
o Refrain from associating with persons engaged in criminal activities 
o Refrain from committing any new law offenses 
o Any other specific conditions that the Office may deem necessary 
Two additional years of reporting probation: 
18 U.S.C. 2255 provides that any minor who suffers injury as a result of the commission of certain offenses 
shall recover actual damages and the cost of any suit. It is important to note that Mr. Epstein is prepared to fully, 
fund the identified group of victims which are the focus of the Office - that is, the 12 individuals noted at the 
meeting on July 31, 2007. This would allow the victims to be able to promptly put this behind them and go 
forward with their lives. If given the opportunity to opine as to the appropriateness of Mr. Epstein's proposal, 
in my extensive experience in those types of cases, the victims prefer a quick resolution with compensation for 
damages and will always support any disposition that eliminates the need for trial. 
FOWLER WHITE BURNETT P.A. 
EFTA00224654

Page 3 
o Mandatory conditions as provided in Florida Statute § 948.03 
o Special conditions as stated above 
If the terms of supervised custody and probation are successfully completed, 
then the two years of state prison is eliminated. 
This proposal provides for the two year imposition of the state prison sentence 
if any violation of the supervised custody or probation occurs. Accordingly, the 
Office's position that Mr. Epstein agree to a resolution that includes jail time is 
satisfied by this proposal. It would immediately bring closure to a matter that has 
been pending for over two years, allows Mr. Epstein to commence with his sentence, 
and, most significantly, allow the victims to move forward with their lives. We are 
in process of scheduling a meeting with R. Alexander Acosta, United States 
Attorney, to further discuss this matter. 
Sincerely, 
Lilly Ann Sanchez 
cc. 
R. Alexander Acosta 
Gerald Lefcourt 
Roy Black 
FOWLER WHITE BURNETT P.A.
EFTA00224655