EFTA00225378

EPSTEIN INVESTIGATION TIMELINE 
Date 
To 
From 
Re: 
Exhibit # 
8/24/2011 
Wilfredo Ferrer 
(U.S. Attorney, 
SDFL), Robert 
O'Neill (U.S. 
Attorney, 
MDFL), 
Benjamin 
Greenberg 
(FAUSA, 
SDFL), and Lee 
Bentley 
(FAUSA, 
MDFL) 
Richard Sudder 
Email regarding Formal Notice of Office-wide Recusal of Southern District of 
Florida. Cc's David MSODAG), Jay Macklin (USAEO), Thomas 
Anderson (USAEO), 
Tapken (USAEO), and James Read (USAEO) 
Privileged Confidential 
Page 51 of 51 
Contains 6(e) Material 
EFTA00225478

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
FGJ 07-103(WPB) 
U.S. District Judge Donald M. Middlebrooks 
IN RE: 
GRAND JURY PROCEEDINGS 
SEALED ORDER GRANTING APPLICATION FOR PERMISSION TO DISCLOSE 
GRAND JURY MATERIAL 
THIS MATTER has come before the Court on the United States' Sealed Application for 
Permission to Disclose Grand Jury Material and for Entry of a Protective Order. The Court has 
considered the Motion and finds that: 
(I) 
the United States has shown a "particularized need" for the limited disclosure of 
materials related to matters occurring before the Grand Jury; 
(2) 
the United States has shown that the disclosure is "in connection with a judicial 
proceeding," that is, in connection with an administrative proceeding conducted by the Justice 
Department's Office of Professional Responsibility (OPR) arising out of a decision by United 
States District Judge Kenneth A. Marra in the matter of Jane Doe 1 and Jane Doe 2I United 
States, S.D. Fla. Case No. 08-80736-Civ-Marra; 
(3) 
the materials are needed to avoid an injustice in another proceeding, that is, the 
OPR administrative proceeding and any referrals to state bar authorities, other government 
agencies for law enforcement purposes, courts, and grand juries in accordance with OPR's Policies 
and Procedures; 
(4) 
the need for disclosure is greater than the need for continued secrecy; and 
(5) 
the request is structured to cover only the needed materials. 
EFTA00225479

Accordingly, the United States Attorney's Office for the Southern District of Florida, 
including Assistant United States Attorney A. Marie Villafafia, and the Justice Department's 
Office of Professional Responsibility may disclose to attorney Jonathan Biran matters occurring 
before the grand jury necessary to: (a) allow AUSA Villafafia to respond to OPR's written 
questions; (b) prepare for OPR's interview of AUSA Villafarla; and (c) participate fully in OPR's 
interview of AUSA Villafaiia. 
Disclosure shall be limited as set forth in the attached Protective Order. 
To the extent that AUSA Villafafla's May 10, 2019 Response to OPR's written questions 
and any drafts thereof disclosed any material that arguably referred to matters occurring before the 
grand jury, this Order is entered nuns pro tune to authorize those disclosures to Mr. Biran. 
This Order and the attached Protective Order shall be SEALED, except that copies may be 
provided to the U.S. Attorney's Office for the Southern District of Florida, which may provide 
copies to OPR and attorney Jonathan Biran. 
IT IS SO ORDERED. 
Done and Ordered in West Palm Beach, Fl 
ay of May, 2 19. 
Certified Copies Furnished to: 
AUSA A. Marie Villafaila 
ALD M. MIDDLEBROOKS 
UNITED STATES DISTRICT TT 1111W 
Certified to be a true and 
correct copy of the document on file 
Angola E. Noble, Clerk, 
Distri 
C 
2 
EFTA00225480

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
FGJ 07-103(WPB) 
U.S. District Judge Donald M. Middlebrooks 
IN RE: 
GRAND JURY PROCEEDINGS 
SEALED PROTECTIVE ORDER 
This matter came before the Court on the United States' Sealed Application for Permission 
to Disclose Grand Jury Material and for Entry of a Protective Order. Having granted the 
Application to Disclose Grand Jury Material in a separate Order, the Court hereby enters the 
following Protective Order, which governs the conditions for disclosure, maintenance, and 
destruction of any material containing "matters occurring before the grand jury" (hereinafter 
referred to as "grand jury material"). 
Accordingly, it is HEREBY ORDERED THAT: 
1. 
The government is authorized nunc pro tune to produce to attorney Jonathan Biran 
of Baker Donelson grand jury material relevant to his representation of Assistant U.S. Attorney A. 
Marie Villafafia that is necessary to: (a) allow AUSA Villafafia to respond to OPR's written 
questions; (b) prepare for OPR's interview of AUSA Villafaila; and (c) participate fully in OPR's 
interview of AUSA Villafafia. 
2. 
The government and Mr. Biran shall make efforts to minimize the amount of grand 
jury material produced to or maintained by Mr. Biran. Mr. Biran shall not be given copies of 
subpoenas, documents produced in response to subpoenas, transcripts, proposed or completed 
indictments, prosecution memoranda, or items prepared for use in front of the grand jury, but these 
Page 1 of 2 
EFTA00225481

items may be shown to Mr. Biran and discussed in preparation sessions and during interviews. 
3. 
Any hard copies of grand jury material provided to Mr. Biran shall not be 
photocopied and shall be securely maintained. 
4. 
Any digital copies of grand jury material provided to Mr. Biran shall be encrypted. 
5. 
Any grand jury material provided to Mr. Biran can only be reviewed by him and 
not by anyone else in his firm. 
6. 
At the conclusion of the OPR proceedings and any related proceedings wherein Mr. 
Biran represents AUSA Villafaha, all grand jury material in Mr. Biran's possession shall be 
destroyed. Hard copy documents must be shredded and electronic documents must be deleted 
and purged. 
DONE AND ORDERED this  ,i li day of May, 
Certified to be a true and 
correct copy of the document on file 
Angela E. Noble, Clerk, 
U S. Distr ct C 
ALD M. MIDDLEBROOKS 
UNITED STATES DISTRICT JUDGE 
I certify that I have read and agree to be bound by the terms of this Protective Order: 
Date: 
Jonathan Biran, Esq. 
Baker Donelson 
Page 2 of 2 
EFTA00225482

STATEMENT OF A. MARIE VILLAFARA IN RESPONSE TO 
APRIL 2, 2019 LETTER FROM JEFFREY It RAGSDALE 
To the extent possible, I have provided all information relevant to your inquiry, including 
applicable documents. Due to the passage of time, updates to various software and hardware, and 
the crash of my work laptop several years ago, I no longer have every piece of relevant material 
and my memory may be imperfect.' I have organized the response to conform with the April 2, 
2019 letter from Jeffrey R. Ragsdale to Jonathan Biran. Please note that there were numerous oral 
and written communications between others at the U.S. Attorney's Office and the Justice 
Department with counsel for Mr. Epstein. While in some cases I was told of the communications 
or cc'ed on emails or letters summarizing the communications, for many conversations, meetings, 
and emails, I do not have knowledge of what occurred. 
Introduction 
The investigation of Jeffrey Epstein and a series of co-conspirators, named "Operation 
Leap Year," officially began in May 2006. In theory, it was supposed to conclude on September 
24, 2007 with the signing of a "Non-Prosecution Agreement" ("NPA").2 As will be discussed 
below, the investigation presented several issues of first impression and challenges related to 
obtaining evidence and securing the cooperation of witnesses. Nonetheless, I felt certain that the 
agents, my co-counsel, 
'it a very strong case ag 
three 
rsonal assistants — 
Adriana Ross, a/k/a " 
and 
The case was presented for federal investigation by the Palm Beach Police Department 
after they felt that Jeffrey Epstein's legal team had put inappropriate pressure on the Palm Beach 
County State Attorney's Office to file only misdemeanor charges. Allegations of misconduct had 
been leveled against the local detective and the Police Chief and they reported being followed and 
harassed. As described below, the defense attorneys employed the same tactics at the federal level 
against myself and the FBI. 
With regard to the exhibits, whenever possible, I have used copies of original documents 
or "scanned" originals that were made at the time. In some cases, all that I have are the electronic 
documents (i.e., the Word Perfect letter that was printed, signed, and mailed or faxed). Because 
our computers no longer have Word Perfect, I have used "Quick Print" which has distorted the 
formatting. If I am providing something that I know is a "draft," I note that either in the text or in 
the exhibit list. The fact that something does not contain a signature does not mean that it is a 
draft, it just means that it was printed from the electronic version and I no longer have (or never 
had) a copy of the original. For example, I often drafted letters for the signatures of Andrew 
Lourie, Jeff Sloman, and Alex Acosta. Their assistants would have maintained the signed 
originals. In some cases, I would be provided with copies and sometimes I would not. I would 
usually notate my electronic files with "final" to know which was the final version, or the last-
modified version. 
2 For reasons set forth below, the investigation continued due to Epstein's post-NPA 
conduct. 
Page 1 of 58 
EFTA00225483

Once the USAO opened the file, Epstein took the same approach that had been used with 
the State — at each level of review, he hired an attorney with a personal connection to the 
AUSA/USAJDOJ Attorney who was conducting the review. The attorneys raised a series of 
challenges to the veracity of the victims and the veracity of the state investigators, as well as quasi-
Petite-policy arguments. When those failed, more formal legal analysis and federalism policy 
arguments were presented. 
Throughout this process, I wanted to keep my investigation as confidential as possible. For 
example, I did not see the benefit of telling Epstein's counsel that we had uncovered additional 
victims, that we had been able to corroborate victims' accounts, or the legal theories that we were 
pursuing. My objections to making these disclosures were all overruled. Also, unbeknownst to 
me, at least one supervisory AUSA was engaging in plea discussions with counsel for Epstein 
without consulting with me, the agents, or the victims. These discussions led to the creation of the 
NPA — an agreement that allowed Epstein to plead guilty to state charges in exchange for immunity 
for federal prosecution by the USAO for the Southern District of Florida. 
After the NPA was signed on September 24, 2007, when I attempted to notify the victims 
and enforce the agreement, the attacks became more personal. Epstein's attorneys raised the same 
policy arguments — which could have been raised prior to signing the NPA — as high as the DAG's 
Office, and coupled them with claims of prosecutorial misconduct. As these attacks occurred, the 
USAO — U.S. Attorney Alex Acosta and later First Assistant U.S. Attorney Jeff Sloman offered 
Epstein the option of simply "unwinding"3 the NPA — after all, he had never performed any part 
of it. In my mind it was unfathomable that Epstein would be allowed to spend months attacking 
not just the validity of our investigation and the validity of the NPA, but also making false 
allegations of prosecutorial misconduct against myself and FAUSA Sloman and still be allowed 
the benefit of what was, in my opinion, an unreasonably favorable agreement. Since everyone 
from the U.S. Attorney down to me agreed that the case was headed for a trial, the investigation 
continued, including identifying additional victims, conducting interviews, issuing grand jury 
subpoenas, drafting revised indictment packages, and presenting testimony to the grand jury. 
Epstein's clear intent to go to trial was on display during this period as he deposed victims 
identified only through the federal investigation in the guise of taking discovery in the state case. 
On June 23, 2008, John Roth in the DAG's Office issued his letter denying Epstein's final 
appeal. While USA Acosta allowed Epstein the benefit of the NPA, Epstein still tried to avoid 
several key parts of the NPA's terms, and would have escaped them but for my insistence. 
On June 30, 2008, Epstein entered his guilty plea in state court and was sentenced to 18 
months' in the county jail in accordance with the terms of his state plea agreement and the NPA. 
Not long thereafter, I learned that Epstein had applied for work release and the Palm Beach County 
Sheriff's Office had granted the application. Prior to Epstein's guilty plea, the issue of work 
release had been specifically discussed with Epstein's counsel and they informed us that Epstein 
would not seek work release. The agents and I also met with the Sheriff's Office in advance of 
the plea and had been told that Epstein would not be eligible for work release. Accordingly, I 
provided my Notice of Breach, but was told by defense attorney Roy Black that, despite those 
specific conversations, USA Acosta himself agreed that Epstein would be eligible for any program 
3 "Unwinding" was USA Acosta's term for mutual rescission — the USAO could file its 
charges and Epstein would have no obligations to plead guilty in state or federal court. 
Page 2 of 58 
EFTA00225484

that the state offered, including work release. Because of this, I had to withdraw the Notice of 
Breach and could only write a letter to the Sheriff's Office pointing out all of the false statements 
contained in Epstein's application for work release and letters to the victims informing them that 
Epstein was in work release status. The Sheriff's Office never responded to or acknowledged my 
letter. 
On June 9, 2009, I prepared what I believe was the last Memorandum requesting 
authorization to issue a Notice of Breach and to indict Epstein. The Office authorized issuance of 
the Notice of Breach, and the Indictment Packs es was re-reviewed a roved, and signed, with 
arrest warrants for Jeffrey Epstein, 
and 
The Notice of Breach 
was served on June 12, 2009 at a hearing on pstein's Motion to Dismiss one of the civil suits 
filed by one of the victims identified during the federal investigation. Once again, Epstein was 
allowed to "cure" his breach, and we were not allowed to file the indictment. 
There were strong internal disagreements on a number of subjects, including: the handling 
of the meetings with Epstein's counsel; plea negotiations; the NPA generally; the failure to consult 
with the victims; continuing plea negotiations in the face of Epstein's clear bad faith; the refusal 
to defend me against personal attacks from Epstein's attorneys; the agreement to put off seeking 
Epstein's computer equipment; the consultations with Epstein's attorneys regarding victim 
notifications; the handling of the "appeals" to Washington; allowing delays during those "appeals," 
while Epstein's attorneys were harassing the victims and their family members; attempts by 
Epstein to renegotiate the term of imprisonment; attempts by Epstein to renegotiate the payment 
of damages to the victims and attorneys' fees to their attorney representative; allowing Epstein to 
participate in the work release program after specifically discussing it during plea negotiations; 
and repeatedly allowing Epstein to "cure" intentional breaches of the NPA. These were kept 
internal as I tried to deal professionally with opposing counsel. 
In the midst of all of the post-NPA back-and-forth with Epstein, was the Jane Doel United 
States litigation.° Despite the Office's request to be recused from the case, the Justice Department 
decided that there was no conflict of interest and I was tasked with serving as co-counsel. The 
Office asserted attorney-client, executive, work product, and deliberative process privileges, so all 
of the internal disagreements, pros memos, and indictments were not disclosed while all of my 
communications with opposing counsel (often at the behest of supervisors) were disclosed. After 
an initial flurry of filings, Brad Edwards, as counsel for the named plaintiffs, stated on the record 
that he believed that setting aside the NPA would not benefit his clients, and he sued Epstein on 
behalf of a number of victims under the NPA. I did what I could to assist Mr. Edwards, other 
attorneys, including Mr. Josefsberg, the attorney selected by the Special Master, and the Court, to 
locate victims, provide signed copies of the NPA, and answer questions. After all of the civil suits 
between Epstein and the victims were settled through the spectre of breaching the NPA, Mr. 
Edwards re-initiated the Jane Doe' United States litigation, asserting that his clients wanted to 
4 A few days after Jeffrey Epstein entered his guilty plea in state court, attorney Brad 
Edwards filed suit on behalf of one of the victims identified in the federal investigation (later 
expanded to include a second victim who had been identified in the state investigation), alleging 
violations of the Crimelictims' Rights Act. The suit, which is still pending, is captioned Jane 
Doe I and Jane Doe 2 
United States, 08-80736-CV-KAM. 
Page 3 of 58 
EFTA00225485

set aside the NPA and see Mr. Epstein federally charged due to violations of the Crime Victims' 
Rights Act. 
In response to your questions, I have attempted to distill the past 13 years of emails, letters, 
research, pleadings, and conversations into a coherent document and attach the most relevant 
items. Given the sheer volume of materials involved here and the passage of time, while I have 
worked diligently to answer your questions as fully as possible, I certainly could have missed 
something amongst the thousands of pages of emails, drafts, and hard copy and electronic 
documents. 
If there are additional items or topics that need further explanation or more 
documentation, I can delve further. 
A. The Non-Prosecution Agreement 
1. Describe the circumstances under which the investigation of Jeffrey Epstein 
was referred to the USAO, including when, why, how, and by whom the 
referral was made. Explain why the USAO decided to initiate a federal grand 
jury investigation into this matter, including what federal interests were 
perceived to be involved, and identify the individuals participating in the 
decision. 
Some time in early 2006, FBI Special Agent E. Nesbitt Kuyrkendall approached me about 
an investigation being conducted by the Town of Palm Beach Police Department ("PBPD"). I do 
not know how or when S/A Kuyrkendall was first contacted about the matter. 
The first mentions of the investigation were just passing comments during meetings on 
other matters. S/A Kuyrkendall and I were working on a number of different child exploitation 
matters at the time, along with ICE Special Agent David Malone. I remember generally that S/A 
Kuyrkendall mentioned an investigation of a wealthy man who lived on Palm Beach and recruited 
minors for sexual activity. During these casual conversations, I do not believe that Mr. Epstein's 
name was mentioned. If it was mentioned, it held no significance for me. I recall that S/A 
Kuyrkendall mentioned that PBPD had reached out to her because the Palm Beach County State 
Attorney's Office was leaning towards not charging the case at all or letting the defendant plead 
to a misdemeanor charge of solicitation of prostitution. At some point I told S/A Kuyrkendall that, 
if PBPD wanted to look into federal charges, I would need more information about the allegations 
and I encouraged her to set up a meeting. I recall S/A Kuyrkendall telling me that PBPD wanted 
to give the State Attorney's Office the opportunity to properly charge the case before presenting it 
for federal investigation and prosecution. 
In May 2006, I met with S/A Kuyrkendall and PBPD Detective Joe Recarey in the 4th Floor 
Conference Room at the U.S. Attorney's Office in West Palm Beach. I do not recall whether S/A 
Malone was present. Detective Recarey summarized the investigation into state criminal sexual 
conduct involving Epstein and his personal assistants. Briefly, Epstein, through his personal 
assistants, recruited girls and young womens — mainly from a local high school — to travel to his 
residence on Palm Beach to perform erotic massages. Although they had no massage training, the 
5 I use these terms deliberately. "Girls" refers to females under the age of 18 and "young 
women" refers to females over the age of 18. When I refer to both groups jointly, I will use the 
term "females." 
Page 4 of 58 
EFTA00225486

girls and young women were coached to massage Mr. Epstein in various states of undress. The 
sexual activity varied and included: Mr. Epstein masturbating himself at the end of the massage; 
having the females masturbate him; Mr. Epstein fondling the females' breasts and genitalia; using 
sex toys on the females; digital penetration of the females; sexual intercourse with Mr. Epstein; 
and Mr. Epstein observing while one of the girls had sex with one of his assistants. At the end of 
each "massage" session, Mr. Epstein or one of his assistants would pay the female involved. If 
the female involved in the massage was brought to Mr. Epstein's residence by a "recruiter," then 
the "recruiter" also would be paid. 
Detective Recarey did not have any information regarding any of the females traveling 
interstate or internationally to engage in sexual activity, but Det. Recarey reported that Mr. Epstein 
and his assistants traveled in and out of the Palm Beach International Airport on Epstein's private 
airplane. Det. Recarey stated that flight logs he had seen sometimes referred to passengers as 
"females," without names or ages, so it was possible that girls could have been on board, but Det. 
Recarey had not been able to confirm that. Det. Recarey stated that a search warrant had been 
executed on Mr. Epstein's residence and evidence had been seized, including message pads 
showing calls from females confirming that they would be coming to "work," which was the 
euphemism used for giving a "massage" — another euphemism for engaging in sexual activity for 
money. Det. Recarey also reported that it had appeared that Mr. Epstein had been "tipped oft" 
about the coming search warrant because all of the computer CPUs had been removed from the 
residence — the keyboards and screens were still in place, just the CPUs had been taken. Det. 
Recarey also reported that some surveillance cameras were in place but they had only recovered a 
limited amount of surveillance video. Det. Recarey stated that between 20 and 30 females had 
been identified [NB: I believe that he told me the exact number, I just don't recall that number 
now]. 
S/A Kuyrkendall and Det. Recarey asked me whether there were federal criminal charges 
that could be pursued. I remember getting up from the conference room, walking to my office, 
and getting my code book and walking back. I looked through 18 U.S.C. §§ 2422 (enticement of 
minors into prostitution/illegal sexual activity) and 2423 (travel for purposes of engaging in illegal 
sexual conduct).6 We talked through those statutes and the additional investigation that would be 
required to prove that they had been violated, but I told them that, if the evidence was there, it was 
a case that could be prosecuted federally. 
Det. Recarey then told me that his boss - PBPD Chief Michael Reiter — was still pressing 
the State Attorney's Office to arrest Epstein. 
d p 
' of probable cause 
affidavits for the arrests of Jeffrey Epstein, 
and 
charging a large 
number of state criminal violations. Chief Reiter ad asked the Palm Beach County State Attorney, 
Barry Krischer, to authorize the arrests and he had refused. According to Det. Recarey, pressure 
had been brought to bear on SA Krischer by Epstein's attorneys, who included Guy Fronstin and 
Jack Goldberger (two personal friends of Krischer), and Alan Dershowitz. Det. Recarey stated 
that he and Chief Reiter were concerned that Epstein would be charged only with a misdemeanor 
or perhaps would not be charged at all. 
6 As the investigation progressed, I looked into other federal crimes, but at that first 
meeting, I only remember looking at §§ 2422 and 2423. 
Page 5 of 58 
EFTA00225487

I recommended that we begin the process of investigating whether there was a 
jurisdictional basis for federal charges, and S/A Kuyrkendall and Det. Recarey concurred. Det. 
Recarey asked that Chief Reiter be given an additional opportunity to convince the State Attorney 
to charge Epstein.' I explained that opening a case file and beginning a federal investigation would 
not preclude the State Attorney from charging Epstein. 
I then prepared the paperwork to open a file. The investigation was dubbed "Operation 
Leap Year" because there were approximately 29 young women and girls who had been identified 
through the State investigation. 
There were several aspects of the case that involved federal interests. First, as to the 
substantive crimes that Epstein was accused of committing, they involved the victimization of 
minor females through the use of facilities of interstate commerce (telephones and airports); and 
Epstein was traveling interstate and internationally to come to the Southern District of Florida to 
commit those offenses. During the course of the investigation, I often said that, if there were a 
trial, I would tell the jury that Jeffrey Epstein traveled to Florida to use Royal Palm Beach High 
School as his personal brothel. Second, the removal of the computer equipment from Epstein's 
home prior to the execution of the search warrant suggested possible public corruption at the Palm 
Beach County courthouse (where the search warrant application was signed) and also raised the 
possibility that Epstein may have been involved in the manufacture and/or possession of child 
pornography. Eradication of child pornography was a particular focus of Project Safe Childhood; 
its production and storage on computer equipment involved the use of items produced in interstate 
and foreign commerce; and child pornography was often distributed through facilities of interstate 
and foreign commerce. Third, Det. Recarey was suggesting that political or other pressure was 
being placed on an elected official (the State Attorney) to avoid or minimize criminal exposure for 
a person who committed numerous state crimes related to the exploitation of girls and young 
women. Setting aside the issue of prostitution, the sexual activity involving girls under the age of 
16 could be charged as sex battery in the state. Ignoring those crimes suggested possible public 
corruption or, at the least, a miscarriage of justice. 
With regard to the logistics of opening the case file, the opening of files in West Palm 
Beach is relatively informal. In instances where an agent approaches a line AUSA directly (either 
because it is a duty matter or because the investigation is within the AUSA's area of expertise), 
the line AUSA will give his or her assistant the details of the case for the LIONS file-opening 
paperwork and then give a brief oral explanation of the case to his/her supervisor along with the 
paperwork. If the supervisor agrees that a file should be opened, he or she will normally sign the 
LIONS form on the spot and hand the file back to the AUSA. In this case, I prepared a file jacket; 
my assistant did the LIONS paperwork; I signed the conflict form; briefed my supervisor, Karen 
Atkinson; and she signed the LIONS paperwork assigning the case to me. This all occurred either 
on the day of the meeting with Detective Recarey and S/A Kuyrkendall or within a few days 
thereafter. Attached hereto as Exhibit 2 is the file opening paperwork and file jacket showing that 
the case was opened in LIONS on May 23, 2006. 
I do recall that at some time relatively soon after the file was opened, I did something that 
I had never done before or since. I initiated a meeting with the U.S. Attorney and the First 
7 Although I did not know it at the time, on May I, 2006, Chief Reiter sent a letter to State 
Attorney Krischer asking Krischer to consider recusing himself from the case. (Exhibit 1.) 
Page 6 of 58 
EFTA00225488

Assistant, Alex Acosta and Jeff Sloman, where I traveled to Miami and told them about the case. 
I recall that I explained the case and how the PBPD believed that Epstein had used political or 
other pressure to avoid serious punishment in Palm Beach County state court. That possibility 
troubled me greatly; hence, my request to meet with executive management. Messrs. Acosta and 
Sloman had the same reaction that I had the first time that Det. Recarey told me about Mr. Epstein 
— if I have never heard of him, how much influence could this person have? I remember 
specifically saying to them that I expected the case would be time and resource-intensive and I did 
not want to invest the time and the FBI's resources if the Office would just back down to pressure 
at the end. Messrs. Acosta and Sloman assured me that, if there was sufficient evidence to support 
the case, Mr. Epstein would be charged appropriately.8
2. Describe in detail your role, and the role of each other person in the USAO, 
the Federal Bureau of Investigation (FBI), and elsewhere within the 
Department of Justice — collectively herein "the government" — who was 
involved in the assessment of the viability and strength of the federal case 
against Mr. Epstein and in the decision to negotiate a pre-indictment 
resolution of the case. 
My Role 
I was the line AUSA assigned to the case. In conjunction with the case agents, I handled 
all aspects of the grand jury investigation — deciding what subpoenas to issue; whom to interview; 
whom to call to testify before the grand jury; what lines of inquiry to pursue to support various 
legal theories; I conducted legal research to support charges; I reached out to others throughout the 
Department and the federal government for information on previous investigations of Mr. Epstein, 
and for legal guidance on various aspects of the case (e.g., OEO, CEOS, SEC, SDNY, and 
AFMLS); along with the FBI agents and the FBI Victim-Witness Coordinator, I had direct contact 
with victims via interviews, meetings, and consultations regarding safety/privacy/mental health 
concerns; and I handled all court proceedings related to the investigation. When I felt that 
sufficient evidence had been collected to prove Mr. Epstein's guilt beyond a reasonable doubt, I 
drafted a prosecution memorandum, indictment, and related documents. I revised those documents 
in response to comments from those in the supervisory chain of command and, as explained below, 
after additional evidence was secured. I participated in some (but not all) of the meetings between 
members of the USAO and counsel for Jeffrey Epstein. 
I prepared briefing materials for 
management in preparation for those meetings and in response to issues raised during those 
meetings. 
Normally the assigned line AUSA handles plea negotiations, and I recommended that I 
enter into negotiations that would result in a joint federal and state resolution (i.e., a plea to federal 
8 I do not have a contemporaneous memorandum and cannot find the date of the meeting. 
In a July 13, 2007 email exchange between myself and Criminal Chief Matt Menchel, I describe 
the meeting as follows: "I summarized the case and the State Attorney's Office's handling of it. 
I acknowledged that we needed to do work to collect the evidence establishing a federal nexus, 
and I noted the time and money that would be required for an investigation. I said that I was 
willing to invest that time and the FBI was willing to invest the money, but I didn't want to get to 
the end and then have the Office be intimidated by the high-powered lawyers. I was assured that 
that would not happen." (See Exhibit 3.) 
Page 7 of 58 
EFTA00225489

charges in federal court and a plea to state charges in state court). I was reprimanded for doing so. 
Thus, as will be discussed in more detail below, I played no role in the decision to enter into a 
Non-Prosecution Agreement in exchange for Jeffrey Epstein's entry of a guilty plea to a state 
charge requiring a sentence of 18 months' imprisonment or Epstein's plea to federal charges 
resulting in a maximum sentence of 18 months' imprisonment (as will be explained below, 
Epstein's counsel repeatedly changed their minds about whether to take the federal route or the 
state route). Although I was tasked with drafting the agreements and Information, all of the 
documents were repeatedly and substantively revised by various supervisors, and I was responsible 
for incorporating those edits. I also was asked to sign the Non-Prosecution Agreement. 
When Epstein sought to have the Non-Prosecution Agreement set aside by "appealing" the 
matter to CEOS, the AAG, and the DAG, I handled the continued investigation of Epstein, 
including working with the FBI to identify additional victims, issue additional grand jury 
subpoenas, and prepare an updated indictment package. At the request of the U.S. Attorney, I also 
responded to inquiries from CEOS, the AAG, and the DAG's Office and drafted submissions on 
behalf of the USAO in response to arguments raised by Epstein's attorneys. 
I believe that I prepared a first draft of the Addendum to the Non-Prosecution Agreement, 
but others took the laboring oar on that document. I drafted numerous victim notification letters 
and responded to defense objections to those letters. I drafted the letter to the Special Master with 
the USAO's recommendations for the qualities to look for in the attorney representative for the 
victims. I monitored Epstein's compliance with the Non-Prosecution Agreement and served 
several breach notices. 
U.S. Attorney's Office Personnel 
AUSA Karen Atkinson (now retired): AUSA Atkinson was my direct supervisor. She 
reviewed indictment packages and other court-related matters and provided guidance and 
served as a "sounding board" for many of my concerns. As will be explained below, AUSA 
Atkinson did not participate in many of the meetings between the USAO and Epstein's 
counsel because Epstein's counsel "skipped her" in the chain of command, directing their 
communications to MAUSA9 Andrew Lourie, Criminal Chief Matt Menchel, First 
Assistant Jeff Sloman, and U.S. Attorney Alex Acosta. AUSA Atkinson did participate in 
meetings with the Palm Beach Sheriff's Office about Epstein's work release and several 
conference calls with defendant attorney Roy Black and others about Epstein's breaches of 
the Non-Prosecution Agreement. 
MAUSA Andrew Lourie (now in private practice): MAUSA Lourie was my second-
line supervisor and head of the West Palm Beach office. Over the objection of myself and 
my co-counsel, he granted the request of Epstein's attorneys to meet to allow Epstein's 
attorneys to argue that the USAO should decline the matter. That began the series of 
meetings between all levels of the USAO and Epstein's counsel. MAUSA Lourie reviewed 
my work; asked me to conduct some specific research; and reviewed drafts of our responses 
9 The Managing Assistant U.S. Attorney ("MAUSA") is the head of the West Palm Beach 
Office. 
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to legal arguments raised by Epstein's counsel. MAUSA Lourie also participated in 
conversations with the State Attorney, and directly participated in negotiations of the 
language to be used in the Non-Prosecution Agreement, federal Plea Agreement, and 
Information. He had numerous conversations with counsel for Epstein outside of my 
presence when they objected to my refusal to agree with their changes. MAUSA Lourie 
also communicated with the U.S. Attorney about the negotiations. He would then 
communicate changes from the defense and the U.S. Attorney to me to incorporate. Later, 
when Epstein's attorneys appealed to AAG Alice Fisher, Mr. Lourie was on detail as AAG 
Fisher's Chief of Staff and facilitated the meeting between Epstein's counsel and the AAG. 
AAG Fisher's written response was issued while MAUSA Lourie was still her Chief of 
Staff. I do not know who drafted the written response. 
Acting MAUSA Rolando Garcia (still with the USAO): When MAUSA Lourie was on 
detail with AAG Fisher's Office, Rolando Garcia was named the Acting MAUSA. He 
participated in at least one meeting with Epstein's attorneys and the State Attorney. Mr. 
Garcia also was involved in some of the negotiations regarding the language of the Non-
Prosecution Agreement. He later reviewed at least one of the iterations of the indictment 
package and signed the indictment that was supposed to be presented to the grand jury in 
June 2009. 
Criminal Chief Matthew Menchel (now in private practice): Criminal Chief Menchel 
was the third line supervisor of the matter. Generally, West Palm Beach indictments are 
reviewed and approved by the MAUSA and are not reviewed by Miami. However, unusual 
or especially significant indictments are reviewed by the Criminal Chief. Criminal Chief 
Menchel reviewed and commented on the first proposed indictment package. His 
comments were incorporated into a revised indictment, and he possibly reviewed those 
changes. Criminal Chief Menchel participated in numerous meetings on the case, and had 
private conversations regarding resolution of the matter with Lilly Ann Sanchez, counsel 
to Mr. Epstein. Ms. Sanchez had formerly served as Deputy Chief in the Major Crimes 
Section at the USAO while Mr. Menchel was Chief of Major Crimes. As discussed below, 
on July 26, 2007, Criminal Chief Menchel announced to the investigative team that U.S. 
Attorney Acosta had decided to offer a two-year plea to Mr. Epstein. On August 3, 2007, 
Mr. Menchel sent a letter to Ms. Sanchez regarding that plea offer. Mr. Menchel left the 
U.S. Attorney's Office on that date to become a partner at Kobre & Kim in New York. 
First Assistant Jeffrey Sloman (now in private practice): FAUSA Sloman (later U.S. 
Attorney Sloman) was involved in telephone calls and meetings with counsel for Mr. 
Epstein; when Epstein's attorneys were dissatisfied with my proposed language for the 
Non-Prosecution Agreement, victim notification letters, letters to the Special Master, etc., 
they would frequently contact FAUSA Sloman directly to complain. FAUSA Sloman 
handled the bulk of the negotiations of the Addendum to the NPA. Epstein's attorneys 
later complained that FAUSA Sloman was biased because his daughter had been the victim 
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of a crime. One of Epstein's attorneys also falsely accused FAUSA Sloman (and me) of 
promising money to a victim in exchange for her willingness to accuse Epstein. 
U.S. Aftorney R. Alexander Acosta (now Secretary of the U.S. Department of Labor): 
USA Acosta served as the head of the U.S. Attorney's Office throughout the investigation 
of Jeffrey Epstein, including the decision to enter into a Non-Prosecution Agreement, 
negotiation of its terms, and attempts to enforce its terms. When Epstein's attorneys were 
dissatisfied with answers they received from me, MAUSA Lourie, and FAUSA Sloman, 
they would frequently contact USA Acosta directly. USA Acosta was directly involved in 
reviewing and revising the documents, including sending exact wording that he wanted 
incorporated into the agreement. There were some communications between USA Acosta 
and counsel for Epstein that I was not aware of at the time. For example, I did not know, 
until after I had sent a breach notice, that USA Acosta agreed that Epstein could be 
considered for work release. At some point after the NPA was signed, USA Acosta was 
recused from the Epstein matter. 
AUSA John McMillan (still at USA0): Early in the investigation, I asked AUSA 
McMillan if he would serve as co-counsel on the case. Before I joined the West Palm 
Beach Office, AUSA McMillan had handled the bulk of the child exploitation cases in 
West Palm Beach. He and I discussed how to structure the investigation and he joined me 
in opposing meeting with Epstein's attorneys prior to the completion of the investigation. 
He attended some of the meetings with Epstein's attorneys. When the Office overruled 
our positions and when it appeared that the case was not going to be charged, AUSA 
McMillan decided that he should focus on other cases. 
AUSA Bruce Reinhart (now U.S. Magistrate Judge): AUSA Reinhart was my office 
neighbor and colleague. At one point early in the investigation (I believe before I asked 
AUSA McMillan to serve as co-counsel), I sought AUSA Reinhart's counsel on strategies 
for how to handle Epstein's personal assistants — whether they should be charged or if we 
should seek immunity for them. Not long thereafter, AUSA Reinhart came to me and said 
that he was best friends with one of Epstein's attorneys, Jack Goldberger, and accordingly 
could not discuss the Epstein case with me any further. AUSA Reinhart left the U.S. 
Attorney's Office for private practice and later represented one of Epstein's assistants in 
the civil suits filed by Epstein's victims. 
AUSA Toni Barnes (now retired): Asset Forfeiture AUSA assigned to the Epstein case. 
I had a few brief meetings with AUSA Barnes to talk about the asset forfeiture aspects of 
the case. We discussed the charges under consideration and Epstein's assets that could be 
subject to forfeiture. AUSA Barnes had direct contact with the agents and the FBI's asset 
forfeiture coordinator about information/evidence that she needed to pursue forfeiture. 
AUSA Barnes provided the asset forfeiture language in the proposed indictments. 
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SLC Dexter Lee (still at USAO): SLC Lee was not directly involved in the Epstein 
investigation or negotiation of the NPA, but he has been lead counsel in the Jane Doe'. 
United States litigation. SLC Lee had contact with USA Acosta regarding his recusal, and 
with FAUSA Sloman and myself regarding self-reports to OPR about accusations of 
misconduct raised by Epstein's counsel. I also had contact with SLC Lee regarding a 
Florida Bar Complaint filed by a civil attorney for some of the victims who complained 
that my victim notification letters amounted to inappropriate business referrals to the 
attorney selected by the Special Master.1°
Appellate SLC Anne Ruth Schultz (still at USAO): SLC Schultz was not directly 
involved in the Epstein investigation or negotiation of the NPA. It is my understanding 
that USA Acosta asked SLC Schultz to check my legal analysis. I also understand that 
Criminal Chief Matt Menchel contacted SLC Schultz about moving me to Appeals after I 
pointed out actions that I considered to be in violation of the Ashcroft memo and victims' 
rights legislation. I also understand that SLC Schultz may have knowledge of USA Acosta 
providing my prosecution memorandum to Criminal Appellate Chief Patty Stemler at Main 
Justice. 
Shawn Ball (still at USAO): My legal assistant during most of the Epstein investigation 
and its aftermath. She assisted with preparing indictment packages, victim notification 
letters, grand jury subpoenas, travel, expert witness contracts, and other items. 
Cyndee Campos/Annette Castillo (both still at USAO): Executive assistants to AUSA 
Acosta and FAUSA Sloman. They compiled correspondence between the USAO and 
counsel for Epstein; scheduled meetings; and dealt with inquiries from the press and DOJ. 
They may have information related to correspondence or communications between the 
Executive Division and Epstein's counsel that I am unaware of. 
FBI Personnel 
S/A Nesbitt Kuyrkendall (retired from FBI): Lead case agent on Operation Leap Year. 
She presented the case to the USAO, handled the bulk of the interviews, served subpoenas, 
and testified before the grand jury. She communicated directly with victims and hand-
delivered the original victim notification letters. S/A Kuyrkendall also participated in 
meetings with some of the senior members of the USAO and counsel for Epstein. 
1° The Florida Bar determined that my victim notification letters, which are included in the 
exhibits and advised the victims that they had the absolute right to select another attorney if they 
so desired, were not inappropriate solicitations and did not violate the Florida Bar Rules. The 
attorney who filed the complaint, Jeff Herman, later resigned from the Florida Bar due to 
disciplinary action taken against him. 
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S/A Jason Richards (still at FBI): Co-case agent with S/A Kuyrkendall. Became lead 
case agent during the post-guilty plea period (i.e., the interview of 
responding to FOIA requests, etc.). He conducted interviews, prepared reports, analyzed 
records, and communicated directly with victims. S/A Richards also participated in 
meetings with some of the senior members of the USAO and counsel for Epstein. 
S/A Tim Slater (still at FBI): Co-case agent with S/A Kuyrkendall until he was 
trans 
I e conducted interviews, including the original telephone interview 
with 
where she asked that the FBI have no further contact with her. He 
also prepared reports and analyzed records. 
Group Supervisor Eliasib ("Junior") Ortiz (still at FBI): GS Ortiz supervised S/As 
Kuyrkendall, Richards, and Slater. He also participated in meetings with some of the senior 
members of the USAO and counsel for Epstein. 
ASAC Valerie Parlave (still at FBI): ASAC Parlave supervised GS Ortiz. She attended 
the July 26, 2007 meeting where Criminal Chief Menchel announced the two-year plea 
offer. 
S/A 
Pryor: S/A Pryor participated in the interview of 
in 
Australia. 
S/A Gavin Gumbiner (still at FBI): S/A Gumbiner was the case agent on Operation 
Stolen Globe, which involved the investigation of Alfredo Rodriguez (Jeffrey Epstein's 
butler), who tried to sell evidence to Brad Edwards. 
Group Supervisor Michael Donohoe (retired from FBI): GS Donohoe replaced GS 
Ortiz as head of the violent crime group during the post-guilty plea period. He supervised 
S/As Richards, Pryor, and Gumbiner. 
Victim-Witness Coordinator Twiler Smith: Ms. Smith sent letters to victims, met with 
them in person. and assisted in finding counseling and other services for them. 
Justice Denar ment Personnel 
CEOS Deputy Chief 
Gelber (still at DOJ): Ms. Gelber was part of the team 
that reviewed the case and the NPA when Epstein "appealed" to DOJ. Ms. Gelber also is 
familiar with my work from a prior case that she and I worked on together as well as other 
PSC cases where I have consulted with her. 
CEOS Chief Drew Oosterbaan (now private in-house counsel): Mr. Oosterbaan 
reviewed and opined on the case and the NPA when Epstein "appealed" to DOJ. He also 
attended meetings in the SDFL with myself, the case agents, USAO supervisory staff, and 
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counsel for Epstein. I conferred with Mr. Oosterbaan about charging, staffing, and victim-
related issues. 
CEOS Trial Attorney Myesha Braden (now at a non-profit): I first had contact with 
Ms. Braden when conducting research regarding some of the legal issues raised by the case 
(she was the CEOS Duty Attorney on the day that I called). After AUSA McMillan left 
the case, I contacted Mr. Oosterbaan about having a CEOS Trial Attorney co-chair the case 
and asked if Ms. Braden was available. She participated in interviews, discussed case 
strategy, and reviewed pros memos and indictments. 
Criminal Appellate Chief Patty Stemler (still at DOJ): At various times, I have heard 
that USA Acosta provided my pros memo to Chief Stemler and asked her to review my 
legal analysis. I have never asked Chief Stemler whether this actually occurred. SLC Anne 
Schultz may know whether this occurred. 
AAG Alice Fisher (now in private practice): After CEOS rejected the "appeal" from 
Mr. Epstein's attorneys, they asked for further review by AAG Fisher. She met with the 
attorneys and prepared a written opinion rejecting Epstein's arguments. 
Senior Associate Deputy Attorney General John Roth (now private in-house counsel): 
Following AAG Fisher's rejection, Epstein's attorneys asked for review by the DAG. I do 
not know whether Epstein's counsel met with the DAG, but they did present arguments to 
Mr. Roth, who was Chief of StafPSr. Associate Deputy Attorney General. Mr. Roth wrote 
a letter rejecting Epstein's arguments. 
Deputy Attorney General Mark Filip (now in private practice): Mark Filip was the 
Deputy Attorney General to whom Mr. Epstein's arguments were addressed. As noted 
above, I do not know if Mr. Filip met with Epstein's counsel, or if the meetings were only 
held with Mr. Roth. 
Others Whose Counsel I Sought During the Case: 
Assistant U.S. Attorney Susan Roe (still an AUSA in Seattle): AUSA Roe was not 
involved in the Epstein investigation. During the pendency of the Epstein investigation, 
she began investigating David Copperfield, who was a friend of Epstein, and we conferred 
with each other about strategy. I informed AUSA Roe of the difficulties in convincing the 
Office to prosecute Epstein. 
Attorney Advisor Tammie Gregg (still at DOJ): Ms. Gregg is a friend from my days at 
Dorsey & Whitney. She joined the Justice Department before I did and we have stayed in 
contact over the years. She had experience with USA Acosta when he was the head of the 
Civil Rights Section at Main Justice so I turned to her for advice in handling the Epstein 
situation. 
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Assistant U.S. Attorney E.J. Yera (still at DO.)): Mr. Yera and I were dating at the time 
of the Epstein investigation. (We are now married.) He was a more senior AUSA who 
was familiar with some of Epstein's counsel. I sought his advice on some of the issues —
legal and non-legal — that arose during the case. 
Assistant U.S. Attorney Lynn Kirkpatrick (still at the USAO): Ms. Kirkpatrick and I 
are friends from my time in Miami. She was a supervisor in Miami although not in my 
chain of command. I would often speak or email with her just for advice. 
3. Explain fully the process and circumstances leading to the decision to resolve 
the case through a non-prosecution agreement (sometimes referred to by 
defense counsel and the government as a deferred prosecution agreement, but 
described herein as the non-prosecution agreement). 
Explain why the 
government initially prepared to resolve the case through a federal plea 
agreement, but ultimately did not require Mr. Epstein to enter a plea in federal 
court. The explanation should identify the parties involved in the decision, the 
individual(s) responsible for all final decisions regarding the non-prosecution 
agreement and its terms, and the basis for the decision to resolve the case 
through a non-prosecution agreement. 
Let me preface with some background on how I normally handle investigations and 
prosecutions. When undertaking investigations, my normal practice is to meet with agents, confer 
with them about an investigative plan, and work together until the case is ready for indictment. I 
update my supervisors along the way, seek advice or guidance from supervisors and colleagues if 
an issue is especially complex or novel, and get approval for actions as required by the USAM, 
but I have always focused on learning as much as possible about the subject area, the defendant, 
and the facts related to the alleged crime — I want to be the subject matter expert in the courtroom. 
Then, once all of those items are completed, I prepare a comprehensive prosecution memo and 
proposed indictment, which are submitted for review. 
I believe strongly that investigations — especially child exploitation investigations — should 
be conducted as covertly as possible in order to protect the victims' privacy; to avoid harm to the 
accused's reputation if the accusation is determined to be false; and to maintain the sanctity of the 
investigation. In Mr. Epstein's case, these concerns were heightened for several reasons. First, 
victims identified during the state investigation had expressed fears of Epstein and building trust 
with them would require assurances that Epstein would not find out that they were talking with 
federal investigators. Second, the victims were between the ages of approximately 15 and 20" --
ages when women and girls might minimize or deny sexual abuse to avoid being labeled as "sluts." 
Third, Epstein had made allegations in the state case that the victims were only after money and 
that investigators were only after fame. Maintaining the investigation's confidentiality would 
delegitimize both of those allegations. It also would avoid interference/intimidation by Epstein 
and his counsel. 
" They had been 14 to 17 years old at the time of the sexual activity, but time had passed. 
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My confidentiality rule extends to pm-indictment communications with defendants and 
their attorneys. In cases where defendants are considered a flight risk, I generally have no contact 
pre-indictment. If proven, the crimes under investigation created a statutory presumption that the 
defendant was a risk of flight and a danger to the community, and Epstein had virtually unlimited 
resources to flee.'2
Our effort to maintain the confidentiality of the investigation was thwarted almost 
immediately by PBPD Chief Reiter. On July 24, 2006, Chief Reiter sent letters to some of the 
victims identified in the state investigation informing them that the State Attorney's Office had 
decided to proceed on a single charge of solicitation of prostitution. (Exhibit 6.) Chief Reiter 
encouraged the victims to contact the State Attorney's Office with any complaints about the 
handling of the matter. Chief Reiter then felt the need to disclose that he did "not feel that justice 
has been sufficiently served by the indictment that has been issued. Therefore, please know that 
his [sic] matter has been referred to the Federal Bureau of Investigation to determine if violations 
of federal law have occurred." (Id.). While Chief Reiter did not mention the USAO, Epstein's 
counsel certainly understood that engaging the FBI meant engaging the USAO. Chief Reiter's 
actions were published in the local newspaper. (Exhibit 7.) 
Because the federal investigation had been exposed by Chief Reiter, there was no ability 
to operate covertly, so we began serving subpoenas on persons and entities affiliated with Epstein. 
Beginning on August 2, 2006, a number of grand jury subpoenas were issued for bank information, 
information related to travel on Epstein's airplanes, school attendance records, rental car 
information, and other information that would corroborate statements made by victims (see Exhibit 
A-1). A subpoena also was issued for all of the evidence collected by the PBPD (see id.). Victim 
notification letters also were prepared that contained my contact information for the federal agents 
to provide to the victims identified during the PBPD investigation. (Exhibits 12 & 13.) As victims 
were interviewed by the federal agents, they would be provided with a copy of the notification 
letter. As additional victims were identified throughout the investigation, more letters were 
prepared. (Exhibits 19 & 30.) Subpoenas also were prepared for testimony and evidence from 
some victims who were believed to possess physical evidence that could corroborate contact with 
Epstein. (See Exhibit A-1.) 
One of the subpoenaed victims was Individual #28, who is referred to as Jane Doe #2 in 
the Jane Doe' United Stales litigation. When approached for an interview, Individual #28 refused 
to speak with the agents, and I remember S/A Kuyrkendall telling me that she felt that Individual 
#28 had tried to run over her foot as Individual #28 drove away. Individual #28 contacted Epstein 
when she received the letter and subpoena; Epstein put her in touch with his attorney, Jack 
Goldberger; and Goldberger had his friend, Jim Eisenberg, serve as Individual #28's lawyer while 
Epstein paid Eisenberg's fees. Individual #28 later told Brad Edwards that someone (Epstein, 
Goldberger, or Eisenberg) told her that "the government" planned to take away her baby. I don't 
know if that is true, but Eisenberg insisted that Individual #28 would not speak to us without 6001 
immunity. (Exhibit 9.) Once it was granted, Individual #28 spoke of Epstein in glowing terms 
12 To minimize the risk of flight, I conducted research on extradition and the FBI placed a 
travel watch Epstein, but especially in light of Epstein's ownership of an airplane capable of 
intercontinental travel and his foreign residences, the investigative team considered Epstein to be 
a substantial flight risk. 
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