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EFTA00233329

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:%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
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EFTA00233332
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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
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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
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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. 
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