Tämä on FBI:n tutkinta-asiakirja Epstein Files -aineistosta (FBI VOL00009). Teksti on purettu koneellisesti alkuperäisestä PDF-tiedostosta. Hae lisää asiakirjoja →
FBI VOL00009
EFTA00233329
549 sivua
Sivut 1–20
/ 549
Sivu 1 / 549
:%W OFFICE • Olier,leittea/di • A N I) ASSOCIATES July 3, 2008 United States Attorney's Office Dear VIA CERTIFIED MAIL RETURN RECEIPT REQUESTED 7007 2680 0002 5519 8503 As you are aware, we represent several of the young girls that were victimized and abused by Jeffrey Epstein. While we are aware of his recent guilty plea and conviction in his State Court case, the sentence imposed in that case is grossly inadequate for a sexual predator of this magnitude. The information and evidence that has come to our attention in this matter leads to a grave concern that justice will not be served in this cause if Mr. Epstein is not aggressively prosecuted and appropriately punished. Based on our investigation and knowledge of this case, it is apparent that he has sexually abused more than 100 underage girls, and the evidence against him is overwhelmingly strong. As former Assistant State Attorneys with seven years' prosecution experience, we believe that the evidence against Mr. Epstein is both credible and deep and that he may be the most dangerous sexual predator of children that our country has ever seen. The evidence suggests that for at least 4 years he was sexually abusing as many as three to four girls a day. It is inevitable that if he is not confined to prison, he will continue to manipulate and sexually abuse children and destroy more lives. He is a sexual addict that focused all of his free time on sexually abusing children, and he uses his extraordinary wealth and power to lure in poor, underprivileged little girls and then also uses his wealth to shield himself from prosecution and liability. We are very concerned for the health and welfare of the girls he has already victimized, and concerned that if justice is not properly served now and he is not imprisoned for a very long time, he will get a free pass to sexually abuse children in the future. Future abuse and victimization is obvious to anyone who really reviews the evidence in this case, and future sexual abuse of minors is inevitable unless he is prosecuted, tried and appropriately sentenced. Money and power should not allow a man to make his own laws, and he has clearly received preferential treatment at every step up to this point. If he were a man of average wealth or the abused girls were from middle or upper class families, then this man would spend the rest of his life in prison. In a country of true, blind justice, those distinctions are irrelevant, and we really hope he does not prove the point that a man can commit heinous crimes against children and buy his way out of it. If the Department of Justice's recent commitment to the protection of our children from child molesters is to be more than rhetoric, then this is the time and the case where the Department must step forward. We urge the Attorney General and our United States BEOBRADEDWARDSLAW.COM EFTA00233329
Sivu 2 / 549
United States Attorney's Office Page Two Attorney to consider the fundamental import of the vigorous enforcement of our Federal laws. We urge you to move forward with the traditional indictments and criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take the steps necessary to protect our children from this very dangerous sexual perpetrator. We will help you to do this in any way possible to ensure that true Justice is served in this case. Sincerely, Brad Edwards, Esquire Jay Howell, Esquire 2028 HARRISON STREET,SUITE 202, HOLLYWOOD, FLORIDA 33020 OFFICE: 954-414-8033/305-935-2011 FAX: 954-924-1530/305-935-4227 BEOBRADEDWARDSLAW.COM EFTA00233330
Sivu 3 / 549
LAW OFFICE • Ofikeaceigh • AND ASSOCIATES October 15, 2008 United States Attorney's Office 99 N.E. 4th Street Miami, Florida 33132 Re: Jane Doe # and Jane Doe #2'. United States of America Case No.: 08-80736-CIV-MARRA/JOHNSON Dear Mr I am writing to inquire about whether Mr. Epstein has violated his Non-Prosecution Agreement with the Government. As you know, the Government has repeatedly described the Non-Prosecution Agreement as guaranteeing to the victims of Epstein's sexual abuse at least $150,000 in civil damages. The Government has made these representations in reliance on a current provision in the U.S. Code — 18 U.S.C. § 2255(a) — which provides for an automatic amount of damages of at least $150,000. At the time that the Non-Prosecution Agreement was drafted and signed, that was the law that was in effect. In Epstein's latest filing in federal court, however, he takes the position that the pre-2006 Amendments version of the law applies. See Defendant Epstein's Motion to Dismiss, for Moir Definite Statement and To Strike Directed to Plaintiff Jane Doe's Complaint at 9, Jane Doe Jeffrey Epstein, No. 08-CIV-80893-Marra/Johnson (discussing § 2255 and stating that the "applicable version of the statute" is "pre-2006 Amendments"). The 2006 Amendments altered § 2255(a), by increasing the presumed minimum damages from $50,000 to $150,000. See Pub. L. 109-248, Title VII, § 707(b), (c), July 27, 2006, 120 Stat. 650. In light of Epstein's latest filing, I write to ask several questions: (1) Would you stipulate that you told me several times that Epstein had agreed to pay at least $150,000 to the identified victims of his abuse? (2) Did Epstein in fact agree to pay damages to the identified victims of his abuse at least $150,000? (3) Did the Government tell victims, either directly or through counsel, that Epstein had agreed to pay his victims at least $150,000? BEG B RAD EDWARDS LAW.COM EFTA00233331
Sivu 4 / 549
EFTA00233332
Sivu 5 / 549
Sent: To: Cc: Subject: Dear Thl trreInt• hints 10 00(10 A-AA Du vu, Hahn 1v. t 1 LO) Epstein Case I just wanted to let you know that Karen and I spoke with Roy Black yesterday regarding the Epstein case Roy asked whether there was a way to resolve the federal and state litigation simultaneously and mentioned your desire to wrap up the case before you retired. We informed him that the Office's position is that if Epstein promptly abides by the terms of the signed non-prosecution agreement entered into by the Office and Mr. Epstein, we will end our investigation. If Mr. Epstein chooses to go forward with a different plea in the State, that is his prerogative, but we will consider it a breach of the federal non-prosecution agreement and will proceed accordingly. The federal non-prosecution agreement signed by Mr. Epstein and his counsel requires Mr. Epstein to plead guilty to the current state indictment and also to an information charging a state offense that requires sex offender registration, specifically the charge of procuring minors to engage in prostitution, at least 18 months imprisonment, and an agreement that the victims can pursue damages claims as though Mr. Epstein had been convicted of the federal offenses. Our agreement does not address probationary periods following the term of incarceration. Those are statutorily set on the federal side, so we have left that issue to the defense to negotiate with you. If you have any questions, please let me know. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 ( 1) LA-pka.:k. O fctrAroo Tracking: EFTA00233333
Sivu 6 / 549
Recipient Road Road: 6/19/2008 4:48 PM Read. 6/19/2008 4:47 PM 2 EFTA00233334
Sivu 7 / 549
IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT, 1525 PALM BEACH LAKES BLVD., WEST PALM BEACH, FL 33401 September 2, 2009 CASE NO.: 4D09-2554 L.T. No. : 20098CF009381A JEFFREY EPSTEIN 1. STATE OF FLORIDA, ET AL. Appellant / Petitioner(s), BY ORDER OF THE COURT: Appellee I Respondent(s). ORDERED that appellee E.W.'s motion filed July 13, 2009, to file portion of response under seal is hereby determined to be moot; further, ORDERED that appellant's agreed motion filed July 14, 2009, to file one reply supporting petiton for writ of certiorari and for the time to run from service of the last- filed response is hereby granted; further, ORDERED that appellee B.B.'s motion filed August 5, 2009, to supplement the record is hereby granted; further, ORDERED that appellee E.W.'s motion filed July 27, 2009, for attorney's fees and costs is hereby denied; further, ORDERED that appellee B.B.'s motion filed July 23, 2009, for attorneys' fees and costs is hereby denied; further, ORDERED that appellee Palm Beach Newspapers, Inc. d/b/a The Palm Beach Post's motion filed July 21, 2009, for attorneys' fees and costs is hereby denied. I HEREBY CERTIFY that the foregoing is a true copy of the original court order. Served: Barbara J. Compiani Robert D. Critton, Jr. Witham J. Berger State Attomey.P.B. Michael J. Pike Jeffrey H. Sloman Ic Jane Kreusler•Walsh Deanna K. Shullman U.S. Attorney'S Office Bradley J. Edwards James B. Lake Hon. Jeffrey J. Colbath Jack A. Goldberger Diana Martin Spencer T. Kuvin Rebecca Mercier Vargas R. Alexander Acosta EFTA00233335
Sivu 8 / 549
DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT July Term 2009 JEFFREY EPSTEIN, Appellant, 1. STATE OF FLORIDA, E.W. B.B. and PALM BEACH NEWSPAPERS, INC., d/b/a THE PALM BEACH POST, Appellees. No. 4D09-2554 (September 2, 2009j PER CURIAM. We treat petitioner's petition for writ of certiorari as a full appeal and affirm. HAZOURI, DAMOORGIAN and LEVINE, JJ., concur. Appeal from the Circuit Court for the Fifteenth Judicial Circuit, Palm Beach County; Jeffrey J. Colbath, Judge; L.T. Case Nos. 502006CF009454AXXMB & 502008CF009381AXXMB. Jane Kreusler-Walsh and Barbara J. Compiani of Kreusler-Walsh, Compiani 8s Vargas, P.A., Robert D. Critton of Burman, Critton, Littler & Coleman, and Jack A. Goldberger of Atterbury, Goldberger 8s Weiss, P.A., West Palm Beach, for appellant. James B. Lake and Deanna K. Shullman of Thomas, LoCicero & Bralow, PL, Fort Lauderdale, for appellee Palm Beach Newspapers, Inc., d/b/a The Palm Beach Post. William J. Berger of Rothstein Rosenfeldt Adler, Fort Lauderdale, for appellee E.W. Diana L. Martin and Spencer T. Kuvin of Leopold-Kuvin, P.A., Palm Beach Gardens, for appellee B.B. EFTA00233336
Sivu 9 / 549
Not final until disposition of timely filed motion for rehearing. 2 EFTA00233337
Sivu 10 / 549
•freA A - Swaramearas FUL N BELITTENMUU_ER, Clerk Fourth District Court of Appeal EFTA00233338
Sivu 11 / 549
THE PALM BEACH POST • FRIDAY, SEPTEMBER 4.2009 Appeals court backs unsealing of Epstein's '07 deal with feds By SUSAN SPENCER-WENDEL Palm Brack Post Staff Miler WEST PALM BEACH — An appeals court has affirmed a lower court ruling unsealing the con- fidential deal Jeffrey Ep- stein struck with federal prosecutors to avoid being charged by them. The 4th District Court of Appeal this week up- held Circuit Judge Jeffrey Colbath's earlier decision to unseal the agreement. Attorneys for the mon- ey manager of billionaires have fought vigorously against the agreement's release. They have 15 days to request a rehear- ing with the 4th District Court of Appeal. Absent that, it will be- come public. Epstein's local criminal defense attorney Jack Goldberger did not return a call seeking comment. Epstein's own attorneys, in federal filings, have See EPSTEIN, 66 ► Epstein Attorneys for the Palm Beach money manager have 15 days to seek a rehearing. Civil litigation intensifies, deposition ends abruptly ► EPSTEIN from 1B referred to his confiden- tial deferred prosecution agreement with the US. Attorney's Office, struck in September 2007, as "un- precedented" and "highly unusual." Attorneys for The Palm Beach Past as well as al- leged victims of Epstein's sexual advances sought to have the deal unsealed in state court. Colbath found that the proper. sealing procedures had not been followed by an earlier judge. "There is nothing more fundamentally important than for the public and press to observe how the government is doing its job," Post attorney Deanna Shullman has said. "There is great public interest in how everybody in this case is doing their job." According to various media accounts, Epstein moved in circles that in- cluded President Clinton, 4 An attorney's questioning of Epstein becomes personal. Donald 'frump and Prince Andrew. "International Moneyman of Mystery," declared a 2002 New York magazine profile of Ep- stein. He pleaded guilty in 2008 to procuring teens for prostitution and was sentenced to 18 months in jail, but allowed out ex- tensively for work release. Epstein was released in late July, after serving '13 months of the sentence. He now faces civil lawsuits filed by young women allegedly lured to his Palm Beach home and paid to perform massages and other acts. That civil litigation is. intensifying. This week, while Ep- stein was being deposed by attorney Spencer Kuvin, who represents an alleged victim identified only as "B.B.", Kuvin questioned Epstein about the shape of his genitalia and the deposition abruptly ended, according to a transcript. Kuvin has since made a motion in court to be able to inspect Epstein's genitalia. Kuvin said Thursday he seeks to corroborate a de- scription one woman gave Palm Beach police. Because Epstein is in- voking his right to remain silent in depositions, this is the only way to do it, Kuvin said. 'We want to corroborate what those girls saw,' Kuvin said. O susan_spencer wendel@ pbpost.com EFTA00233339
Sivu 12 / 549
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 2008CF009381A STATE OF FLORIDA vs. JEFFREY EPSTEIN, Defendant. AGREED ORDER This cause came on to be heard upon the agreement of the parties, Jack Goldberger representing Jeffrey Epstein and -representing the State of Florida, and the Court being fully advised that the parties have reviewed both the plea agreement and the transcript of the plea conference in the Defendants case and have confirmed that the requirement of "mandatory public service" as a special condition of community control checked off on the Order Placing the Defendant on Community Control was due to a clerical error. Accordingly, it is hereby ordered and adjudged that the special condition of "mandatory public service" is deleted. The Court being further advised that the Order Placing the Defendant on Community Control did not address the Defendant's travel outside the State of Florida for work or business purposes and the parties desire to clarify that omission, it is hereby ordered and adjudged that the Defendant is authorized to travel outside the State of Florida for business and work purposes if allowed by his community control officer. At least 48 hours before the need to travel outside the State of Florida for work purposes the Defendant shall first obtain the permission of his community control officer and then follow any instructions or EFTA00233340
Sivu 13 / 549
requirements imposed on him by his community control officer. DONE AND ORDERED in West Palm Beach, Palm Beach County, Florida on this day of September, 2009. JEFFREY COLBATH Circuit Court Judge Copies: Jack A. Goldberger, Esquire ASA Department of Corrections EFTA00233341
Sivu 14 / 549
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CRIMINAL DIVISION "W" CASE NO. 502008CF00938IAXXMB 502006CF009454AXXMB STATE OF FLORIDA, vs. JEFFREY EPSTEIN, Defendant ORDER RELEASING DOCUMENTS UNDER SEAL THIS MATTER came before the Court as a result of the Fourth District Court of Appeal's per curiam affirmance of the trial court's order, wherefore it is ORDERED AND ADJUDGED that the documents referred to as A. "Non-Prosecution Agreement" filed under seal in the court file on July 2, 2008, B. "The Addendum to the Non-Prosecution Agreement" filed under seal in the court filed on August 25, 2008, shall be released. The Court notes that neither the Agreement nor the Addendum contain the names of any alleged juvenile victims. These documents will be released contemporaneously with this order. DONE AND ORDERED in West Palm Beach, Palm Beach County, Florida this day of September, 2009. JEFFREY COLBATH Circuit urt Judge Copies furnished: R. Alexander Acosta, U.S. Attorney's Office - Southern District 500 South Australian Avenue, Suite 400 West Palm Beath, FL 33401 EFTA00233342
Sivu 15 / 549
Page Two Case No. S02008CF009381AXXMB/502006CF0094S4AXXMB Order Releasing Documents Under Seal ., State Attorney's Office William J. Berger, Esq. Bradley J. Edwards, Esq. Rothstein Rosen(eldt Adler Robert O. Critton, Esq. Critton, turner & Coleman Jack A. Goldberger, Esq. oldber er & Weiss, P.A. Spencer T. Kuvin, Esq. Id-Kuvin, P.A. Deanna K. Shullman, -sq. EFTA00233343
Sivu 16 / 549
A111-30-Z008(408) 10:06 P. 006/0'd I • IN RE: INVESTIGATION OF JEFFREY EPSTEIN NOIN:PROSECIPTION AGEEE8tENT IT APPEARING that the City of Palm Beach Police Department and the State Attorney's Office for the 15th Judicial Circuit in and for Patrn Belch County (hereinafter, the "State Attorney's Office") have conducted an investigation into the conduct of Jeffry Epstein (hereinafter "Epstein"); ITAPPEARING that the State Attorney's Office has charged Epstein by indictmem with solicitation of prostitution, in violation of Florida Statutes Section 796.07; IT APPEARING that the United Stattz Attorney's Office and the Federal Bureau of Investigation have conducted their own investigation into Epstein's teckground and any offenses thut may have been committed by Epstein against the United States from in or around 2001 through in or around September 2007, including: i (1) knowingly and willfully conspiring with others known and unknown to commit an offense against the United States, that is, to use a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution, in violation of Title 18, United States Code, Section 2422(b); all in violation of Title18,United States Code, Section 371; (2) (3) knowingly and wilfully conspiring with others known and unknown to travel in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 § 2423(f), with minor females, in violation of Title 18, United States Code, Section 2423(b); all in violation of Title 18, Urited States Code, Section 2423(e); using a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution; in violation of Title I R, United States Code, Sections 2422(b) and 2; (4) traveling in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 § 2423(1), with minor females; in violation Page 1 of 7 EFTA00233344
Sivu 17 / 549
106130-2008(014) I Or 06 P. 007/0I4 of Title 18, United States Code, Section 2423(b); and (5) lemwingly, in and affecting interstate and foreign commerce, retaining. enticing, and obtaining by any means a person, knowing that the person bad not attained the age of 16 years and would be caused to engage in a commercial sex act as defined in 18 U.S.C. §1591(c)(1); in violation of Title IS, United States Code, Sections 1591(a)(1) and 2; and rr APPEARING that Epstein seeks to resolve globally his state and federal criminal liability and Epstein undo-Minds and acknowledges that, in exchange for the benefits provided by this agreement, he agrees lo comply with its terms, including undertakingcertain actions with the State Attorney's Office; IT APPEARING, after an investigation of the offenses and Epstein's background by both Stare rind Federal law enforcement agencies, raid after due consultation with the State Attorney's Office, that the interests of the United States, the State of Florida, and the Defendant will be served by the following procedure; THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the following conditions and the requirements of this Agreement set forth *below. If the United States Attorney should determine, based on reliable evidence, that, during the period of the Agreement, Epstein wi Wilily violated any of the conditions of this Agreement, then the United States Attorney may, within in'nety (90) days following the expiration of the term of home confinement discussed below, provide Epstein with timely notice specifying the condition(s) of the Agreement that he has violated, and shall initiate its prosecution on any offense within sixty (60) days' of giving notice of the violation. Any notice provided to Epstein pursuant to this paragraph shall be provided within 60 days of the United States learning of facts which may provide a basis for a determination of a brtach of the Agreement. After timely fulfilling all the terms and conditions of the Agreement, no prosecution for the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United Stares Attorney's Office, nor any offenses that arose from the Perim-al Grand Jwy investigation will be instituted in this District, and the charges against Epstein if any, will be dismissed. Page 2 of 7 EFTA00233345
Sivu 18 / 549
JO-30-2008(MON) 10:06 Terms of the Agreement: P. 008/Olt 1. Epstein shall plead guilty (not nolo contendere) to the indicanent as currently pending against him in the 15th Judicial Circuit in and for Palm Bench County (Case No. 2006-cl-009495AX/03M) charging one (1) count of solicitation of 'restitution, in violation of FL Salt § 796.07. In addition, Epstein shall plead guilty to an Information filed by the State Attorney's Office charging Epstein with an offense that requires him to register as a sex offender, that is, the solicitation of minors to engage in prostitution, in violation offloads StatutesSection 796.03; 2. Epstein shall make a binding recommendation that the Court impose a thirty (30) month sentence to be divided as follows: (a) Epstein shall be sentenced to consecutive terms of twelve (12) months and six (6) months in county jail for all charges, without any opportunity for withho/dingadjudiention or sentencing, and without probation or community control in lieu of imprisonment; and (b) Epstein shall be sentenced to a twat of twelve (12) months of community control consecutive to his two turns in county jail as described in Term 2(n), supra 3. This agreement is contingent upon a Judge of the 15th Judicial Circuit accepting and executing the sentence agreed upon between the State Attorney's Office and Epstein, the details of which arc set forth in this agreement. 4. The terms contained in paragraphs 1 and 2, supra, do not foreclose Epstein and the State Attorney's Office from agreeing to recommend any additional charge(s) or any additional tenn(s) of probation and/or incarceration. 5. Epstein shall waive all challenges to the Information filed by the State Attorney's Office and shall waive the right to appeal his conviction and sentence, except a sentence that exceeds what is set forth, in paraimiph (2), supra. 6. Epstein shall provide to the U.S. Attorney's Office copies of all Page 3 of 7 EFTA00233346
Sivu 19 / 549
JUN-30-2008(M0N) 10:06 • proposedagreementswiththe Stale Attorney's Office priorto entering into those agreements. 7 The United States shall provide Epstein's attorneys with a list of individuals whom it has identified as victims, as 4-fined in 18 U.S.C. § 2255, after Epstein has signed this agreement and been sentenced. Uponthe execution ofthis agrecsnent,the United States, in consultation with and subject to the good faith approval of Epstein's counsel, shall select an attomeyrepresentative forthesepersons, who shall be paid For by Epstein. Epstein's counsel may contact the identified individuals through that representative. 8. If any of the individuals referred to in paragraph. (7) sups, elect to Me suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction oftheUtrited States District Court fortbe Southern District *Merida over his person and/or the subject matter ,andEp stein waives bisrightto contemliability and also waives hi-slight to contest damages up to an ammmt as agreed to between the identified individual and Epstein, so long as the identified individual elects to ptocced exclusively under 18 U.S.C. § 2255, and agrees to waive any other claim for damagas, whether pursuant to state, federal, or common law. Notwithstanding this waiver, as to those individuals whom names appear on the list provided by theUnited States, Epstein's signature on this agreement his waivers and failures to contest liability and such damages in any suit are not to be construed as an admission of any criminal or civil liability. 9. Epstein's signature on this afire anent also is notto be construed as an admission of civil or criminal liability or a waiver of anyjurisdietional or other defense as to any person whose name does not appear on the list provided by the United States. 10. Except as to those individuals who eJed to proceed exclusively under § 2255, as set forth paragraph (0, supra, neither Epstein's signature onthis agreement, nor its teens, nor any resulting waivers or settlements by Epstein are to be construed as admissions or evidence of civil or criminal liability or a waiver of any jarisdictional or other defense as to any person, whether or not her name appears oa the list provided by the United Slates. 11. Epstein shall use his best efforts to enter his guilty plea and be Page 4 of 7 P. 009/014 EFTA00233347
Sivu 20 / 549
..1N- 30-2008180O 10:06 P. CI 0/014 serattemed not litter than October 26, 2007. The United States has no objection to Epstein self-reporting,ro_bcginsenang hic_senteset not later than January 4, 2008. 12. Epstein agrees that he will not be afforded any benefits with respect to pin time, other than the rights, opportunities, and benefits as any other inmate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the. United States' request, Epstein agrees to provide an accounting of the pin time be earned during his period of incarceration. 13. The patties anticipate that this agreement -will not be made part of any public record. If the United Stuns receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before making that disclosure. Epstein understands that the United States Attorney has no authority to require the State Attomey's Office to abide by any testis of this agreement Epstein understands that it is his obligation to undertake discussions with the State Attorney's Office and to use his bestefforts to ensure compliance with thesepareedures, whichcompliancewilt bettor:may to satisfy the United States' interest. Epstein also understands that it is lds obligation to use his best efforts to convince the Judge of the 15th Judicial Circuit to accept Epstein's binding recommendation regarding the sentence to be imposed and understands that the failure to do so will be a breach of the agreement. In consideration of Epstein's agreement to plead guilty and to provide compensation in the manner described above, if Epstein successfully fulfills all of the terms and conditions ti the United States also agrees that it will not institute any g but not limited t Further, upon execution of this agreement an a tit with the State Attorney's Office, the federal Grand Jury investigation will be suspended, and all pending federal Grand Jury subpoenas will be held in abeyance unless and until the defendant violates any tam of this agreement. The defendant likewise agrees to withdraw his pending motion to intervene and to quash eensin grand jury subpoenas. Both parties agree to maintain their evidence, rpm, ificaEy evidence requested by or directly related to the grand jury subpoenas that have been issued, and including certain computer equipment, inviolateuntil all of the terms of this agreement have been satisfied. Upon the successful completion of the terms of this agreement, all outstanding grand jury subpoenas shall be deemed withdrawn. Page 5 of 7 EFTA00233348
Sivut 1–20
/ 549