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EFTA00233329

549 sivua
Sivut 21–40 / 549
Sivu 21 / 549
JUN-30-t008(MOH) 10106 
P 011/014 
By signing this ageernent, Epstein assets and certifies that each of these terms is 
material to this agreement and is supported by independent consideration and that a breach 
of any one of these conditions allows the United States to elect to terminate the agreement 
and to investigate and prosecute Epstein and any other individual or entity for any and all 
federal offenses. 
By signing this agreement, Epstein asserts and certifies that he is aware of the fact that 
the Sixth Amendment to the Constitution of the United States provides that in all criminal 
prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein finthcr 
is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court 
may dismiss an indictment, information, or complaint for unnecessary delay in presenting 
a chargcto the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein 
bezebyrequests thattheUnitedStatmAttomcy forth:: South= District ofFlorida defer such 
prosecution. Epstein agrees and consents that any delay from the dale of this Agreement to 
the date of initiation of prosecution, as provided for in the terms expressed herein, shall be 
deemedto be a necessary delay at his own request, and he hereby waives any defense to such 
prosecution on the ground that such delay operated to deny him rights under Rule 45(b) of 
the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the 
United States to a speedy trial or to bar the prosecution by reason of the running of the statute 
of limitations for a period of months equal to the period between the signing of this 
agree:mot and the breach of this agreement as to those offenses that were the subject of thc 
gaud jury's investigation. Epstein further asserts and certifies that he understands that the 
Fifth Amendmmt and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all 
felonies must he charged in an indictment presented to a grand jury. Epstein hereby agrees 
and consents that, if a pmsec-ution against him is instituted for any offense that was the 
subject of the grand jury's investigation, it may be by way of an Information signed and filed 
by the United States Attorney, and hereby waives his right to be indicted by a grand jury as 
to any such offense. 
11f 
'II 
/11 
Page 6 of 7 
EFTA00233349
Sivu 22 / 549
JON-:30-2008O401O 10:06 
By signing this agreement, Epstein asserts and certifies that the above has been read 
and explained to him. Epstein hereby states that he enderstaads the conditions of this Non-
Prosecution Agreement and agrees to comply with them. 
Dated: 
 
By: 
Dated:  772",,_.
Dated: 
Dated: 
R. ALECANDER.ACOSTA 
UNITED STATES ATTO}WEY 
ASSISTANT U.S. ATTO 
GERALD LEFCOURT, ESQ. 
COUNSEL TO JEFFREY FESTEIN 
LILLY ANN SANCHEZ, ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
Page? of 7 
ro
P. Olii014 
EFTA00233350
Sivu 23 / 549
J0*-30-2008(MON) 10:07 
P. 013/Old 
By signing this agreement. Epstein asserts and certifiesthat the above has bean read 
and explained to him. Epstein hereby states that he understands the conditions of this Non-
Prosecution Agreement and agrees to comply with then 
Dated: 
Dated: 
Dated: 
Dated: 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
BY: 
ASSISTANT U . 
Lg.LY ANN SANetrPt ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
Pagel of 7 
EFTA00233351
Sivu 24 / 549
JUt'-30-2008(NON) 10:0? 
P.014/014 
By signing this 38TCC333Cilt, Epstein melts and catifres that the above has been read 
and explained to him. Epstein bereby statcs that he understands the conchae= of thisN'on-
Prosecution Agrectinent and agrees to comp)), with them. 
ALEXANDER ACOSTA 
MUTED STATES ATTORNEY 
Doted: 
Dated: 
Dated: 
Dated:q-M 
. 
BY: 
ASSISTANT 
. 
JEFFREY EPSTEIN 
GERALD LEECOGRT, ESQ. 
COUNSEL. TO JEPFREY BESTEDT 
• ESQ. 
ATTORNEY FORIERFREY EPSTEIN 
Page 7417 
EFTA00233352
Sivu 25 / 549
IN RE: 
INVESTIGATION OR 
JEFFREY EPSTEIN 
ADDENDUM TO THE NON-PROSECUTION AGREEMENT 
IT APPEARING that the parties seek to clarify certain provisions of page 4, paragraph 7 
of the Non-Prosecution Agreement (hereinafter "paragraph 7'), that agreement is modified as 
follows: 
7A. 
The United States has the right to assign to an independent third-party the responsibility 
for consulting with and, subject to the good faith approval of Epstein's counsel, selecting 
the attorney representative for the individuals identified under the Agreement. If the 
United States elects to assign this responsibility to an independent third-party, both the 
United States and Epstein retain the right to make good faith objections to the•attomey 
representative suggested by the independent third-party prior to the final designation of 
the attorney representative. 
7B. 
The parties will jointly prepare a short written submission to the independent third-party 
regarding the role of the attorney representative and regarding Epstein's Agreement to 
pay such attorney representative his or her regular customary hourly rate for representing 
such victims subject to the provisions of paragraph C, infra. 
7C. 
Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the attorney 
representative selected by the independent third party. This provision, however, shall not 
obligate Epstein to pay the foes and costs of contested litigation filed against him. Thus, 
if after consideration of potential settlements, an attorney representative elects to file a 
contested lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested 
remedy, the paragraph 7 obligation of the Agreement to pay the costs of the attorney 
representative, as opposed to any statutory or other obligations to pay reasonable 
attorneys fees and costs such as those contained in s 2255 to bear the costs of the attorney 
representative, shall cease. 
EFTA00233353
Sivu 26 / 549
By signing this Addendum, Epstein asserts and certifies that the above has been read and 
explained to him. Epstein hereby states that he understands the clarifications to the Non-
Prosecution Agreement and agrees to comply with them. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated: 
 
By: 
ASSISTANT U.S. ATTORNEY 
Dated: 
JEFFREY EPSTEIN 
Dated: ( 0/ 11/07 
Dated: 
ERALD LEFCO RT ESQ. 
COUNSEL TO MEER Y EPSTEIN 
LILLY ANN SANCHEZ, ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
EFTA00233354
Sivu 27 / 549
THE PALM BEACH POST 
• 
SATURDAY, SEPTEMBER.19, 2009 
Epstein's secret pact with feds 
reveals `highly unusual' terms 
Epstein 
Faces many 
civil lawsuits 
filed by some 
of the 30 to 
40 women 
identified as 
victims in 
the federal 
investigation. 
By SUSAN SPENCER-WENDEI 
Palm Brock Post Staff Writer 
WEST PALM BEACH - A secret non-prosecution 
agreement multimillionaire financier Jeffrey Ep-
stein struck with federal prosecutors is being called 
"highly unusual" by former federal prosecutors and 
downright outrageous by attorneys now represent-
ing young women who serviced him. 
The deal reveals that the FBI and the US. At-
torney's Office investigated him for several federal 
crimes; including engaging minors in commercial 
sex. The crimes are punishable by anywhere from 
10 years to life in prison. 
But federal prosecutors backed down aixl agreed 
to recall grand jury subpoenas if Epstein pleaded 
guilty to prostitution-related felonies in state court, 
which he ultimately did. lie received an 18-month 
jail sentence, of which he served 13 months. 
See EPSTEIN, 12A ► 
EFTA00233355
Sivu 28 / 549
Tension between prosecutors, police 
IP. EPSTEIN from IA 
The 
US. 
Attorney's 
Office also agreed not to 
charge any of Epstein's 
' le 
•onspirators: 
in part by heavyweight 
New York cri mi nal defense 
attorney Gerald Lefcourt. 
Unsealed on Friday af-
ter attorneys for some of 
Epstein's victims and The 
Palm Beath Post sought 
its release, it offers the 
first public look at the deal 
Epstein% 
high-powered 
, legal counsel brokered on 
his behalf. 
Mark Johnson of Stuart, 
a former federal prosecu-
tor, described the dispar-
ity in potential sentences 
' as unusual, but even more 
so a provision on attorney 
payment. 
The first draft of the 
ent in September 
261.ft:enquired that Epstein 
pay an attorney — tapped 
by the US. Attorney's Of-
fice and approved by Ep-
stein — to represent some 
of the victims. That attor-. 
ney is prominent Miami 
lawyer Bob Josefsberg. 
But an addendum to 
the agreement signed the 
following month struck 
Epstein% duty to pay 
Josefsberg if he and the 
victims did not accept 
settlements —' capped at 
$150,000 — and instead 
pursued lawsuits. 
Johnson said it appears 
the government was try-
ing to balance the lesser 
sentence for Epstein with 
recovering $150,000 for 
each victim. "I've never, 
ever seen anything like 
that in my life," he said. 
"It's highly unusual." 
The deal does not say 
whether any victims were 
contacted or consulted be-
fore the deal was made. 
Attorney Brad Edwards 
of Fort Lauderdale, who 
represents three of the 
young women, believes 
that none of the 30 to 40 
women identified as vic-
tims in the federal inves-
tigation were told ahead 
of time. Edwards said his 
clients received letters 
from the US. Attorney's 
Office months after the 
deal was signed, assuring 
them Epstein would be 
prosecuted. 
"Never consulting the 
victims is probably the 
most outrageous aspect 
of it," Edwards said. "It 
taught them that someone 
with money can buy his 
way out of anything. It's 
outrageous and embar-
rassing for United States 
Attorney's Office and the 
State Attorney% Office." . 
Epstein 
now 
faces 
many civil lawsuits filed 
by the women, who are 
represented by a variety 
of attorneys. In many, the 
allegations are the same: 
that Epstein had a predi-
lection for teenage girls, 
identified poor, vulnerable 
ones and used other young 
women to lure them to 
his Palm Beach mansion. 
They walked away with 
between $200 and $1,000. 
Former Circuit Judge 
Bill Berger, also represent-
ing victims, called the 
agreement a "sweetheart 
deal." 
"Why was it so impor-
tant for the government 
to make this deal?" Berger 
asked rhetorically. "We 
have not yet had an hon-
est explanation by any 
public official as to why it 
was made ... and why the 
victims were sold down 
the river." 
Former federal pros-
ecutor Ryon McCabe de-
scribed the agreement as 
"very unorthodox." Such 
agreements, he said, are 
usually reserved for corpo-
rations, not individuals. 
"It's very, very rare. I've 
never seen or heard of the 
procedure that was set up 
here," said McCabe, who 
has no involvement in any 
Epstein litigation. 
"He% essentially avoid-
ing federal prosecution 
because he ..can afford, to 
pay that many lawyers to 
help those victims review 
their cases. ... If a person 
has no money, he couldn't 
be able to strike a deal like 
this and avoid federal pros-
ecution." 
The 
backroom 
deal 
with federal prosecutors 
is all the more interesting 
in light of the legal power-
houses who have worked 
for 
Epstein, 
including 
Harvard professor Alan 
Dershowitz and Bill Clin-
ton investigator Kenneth 
EFTA00233356
Sivu 29 / 549
Starr. Lefcourt is a past 
president of the National 
Association of Criminal 
Defense Lawyers. 
Epstein's local defense 
aitorney, Jack Goldberger, 
issued a statement Fri-
day saying he had fought 
the release of the sealed 
agreement, to protect the 
third parties named there. 
"Mr. Epstein has fully 
abided by all of its terms 
and conditions. I-fe is look-
ir%forward to putting this 
difficult period in his life 
behind him. lie is con-
tinuing his long-standing 
history of science philan-
thropy." 
The investigation trig-
gered tensions between 
police and prosecutors, 
with then-Palm Beach 
Chief Michael Reiter say-
ing in a May 2006 letter 
to 
then-State 
Attorney 
Barry Krischer that the 
chief prosecutor shoukl 
disqualify himself. 
continue to find your 
office's treatment of these 
cases highly unusual," Re-
iter wrote. He then asked 
for and got the federal 
investigation that ended in 
the sealed deal.
"The Jeffrey Epstein 
matter was an experience 
of what a many-million-
dollar defense can accom-
plish," Reiter told the Palm 
Beach Daily Nem upon his 
retirement. 
e Susan_spencer wendei 
apbposi.com 
Former Judge Bill Berger, representing victims, 
called the agreement a 'sweetheart deal.' 
.MRoeraed otht Epstein
agreetnt that 
Was unsealed Friday. 
la Get past coverage on the 
the Jeffrey Epstein case. 
PalmGeachPost.com/epsteth 
• See video of Epstein 
being questioned about 
his manhood. 
Page2lIve.com 
EFTA00233357
Sivu 30 / 549
12A 
THE PALM BEACH POST 
• 
TUESDAY. SEPTEMBER 22.2009 
The Palm Beach Post 
TIM BURKE, Executive Editor 
RANDY SCHULTZ Editor of the Editorial Page 
Sleazy perp, sleazier deal 
On the second page of the secret 
deal between federal prosecutors 
and Jeffrey Epstein, we read that the 
agreement will serve the interests 
of "the United States, the State of 
Florida, and the Defendant? Wrong 
on the first two, right on the third. 
Until Friday, the public didn't know 
the terms of the deal that finalized 
the case of the Palm 
Beacher who arranged 
to have girls brought to 
his house for sex and 
massages. Only Epstein% 
platoon of lawyers, the 
US. Attorney% Office 
Epstein 
for the Southern District 
• 
of Florida and the Palm 
Beach County Clare Attorney's Office 
knew the details. And now we know 
why the perpetrators of this outrage 
didn't want the public to know. 
The deal is an indictment of a 
system that did much more for a 
criminal than for his victims. Jeffrey 
Epstein — officially a registered sex 
offender but in plain terms a pervert 
— escaped what should have been 
serious prison time. Instead, the fed-
eral deal allowed him to plead guilty 
to light charges in state court. He 
spent just 13 months — nights only 
— in the Palm Beach County Jail. 
Meanwhile, the government tried to 
help Epstein buy off the young girls 
whom Epstein had exploited. 
Several of those girls have filed 
civil suits against Epstein. (Their 
lawyers and lawyers for The Post sued 
to make the plea deal public) In the 
agreement, the government proposes 
to identify all the alleged victims and 
steer them to a lawyer, whose ex-
penses Epstein would pay. In return, 
however, the victims would withdraw 
all lawsuits from state court and 
agree to a settlement in federal court 
of no more than $150,000 each. Even 
then, of course, Epstein would not 
acknowledge any "liability" 
Government acted like 
Epstein's go-betweens. 
The agreement thus placed the 
Department of Justice in a role simi-
lar to those of the four women who 
procured girls for Epstein. If there's a 
precedent in this or any of the other 
92 United States attorney% offices, 
we'd like to hear it. Not surprisingly, 
R. Alexander Acosta also agreed not 
to prosecute those women. 
If the outcome is frustrating, so 
is the lack of accountability. Mr. 
Acosta's name is on the deal, but he's 
now the dean of Florida International 
University% law school. A call to his 
office for comment Monday was not 
returned. The name of Assistant US. 
Attorney A. Marie Villafana is on 
the deal. She still works as a federal 
prosecutor in West Palm Beach, but 
Alicia Valle, the office's special coun-
sel, said in an e-mail, "We cannot 
comment on your questions." Didn't 
she really mean tall not? 
This case got into the federal 
system because former Palm Beach 
Police Chief Michael Reiter believed 
that Palm Beach County State At-
torney Barry Krischer wasn't moving 
aggressively enough. Mr. Krischer 
retired last year. The assistant state 
attorney who oversaw the race is no 
longer with the office. 
At this point, the public must hope 
that the civil suits suck as much money 
from Epstein as possible. Money seems 
to be all that he understands. Also, Jef-
frey Simian is serving as the acting 
US. attorney for the Southern District 
of Florida until President Obatua nomi-
nates a permanent replacement for 
confirmation by the Senate. It would 
be good to know that whoever follows 
Mr. Acosta is on record that the Jeffrey 
Epstein deal did not serve the interests 
of the United States. 
TALK 
BACK! 
How much of a break did the system 
give Jeffrey Epstein? 
http://blogs.Pal mBeachPost.corn/opinionzono 
EFTA00233358
Sivu 31 / 549
M
A
N
D
A
T
E 
from 
DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA 
FOURTH DISTRICT 
This cause having been brought to the Court by appeal, and after due 
consideration the Court having issued its opinion; 
YOU ARE HEREBY COMMANDED that such further proceedings be had in 
said cause as may be in accordance with the opinion of this Court, and with the 
rules of procedure and laws of the State of Florida. 
WITNESS the Honorable Robert M. Gross, Chief Judge of the District Court 
of Appeal of the State of Florida, Fourth District, and seal of the said Court at West 
Palm Beach, Florida on this day. 
DATE: 
CASE NO.: 
COUNTY OF ORIGIN: 
T.C. CASE NOS.: 
STYLE: 
ORIGINAL TO: 
cc: 
Barbara J. Compiani 
Deanna K. Shullman 
Spencer T. Kuvin 
Michael J. Pike 
September 18, 2009 
4D09-2554 
Palm Beach 
502006CF009454AXXMB and 502008CF009381AXXMB 
JEFFREY EPSTEIN 
STATE OF FLORIDA, ET AL. 
t
 41414 
Aterea/vhbaeth t 
MARILYN BEUTTENMULLER, Clerk 
Fourth District Court of Appeal 
Sharon R. Bock, Clerk 
Jane Kreusler-Walsh 
Diana Martin 
State Attorney-P.B. 
James B. Lake 
Jack A. Goldberger 
William J. Berger 
Bradley J. Edwards 
R. Alexander Acosta 
Robert D. Critton, Jr. 
U.S. Attorney'S Office 
Rebecca Mercier Vargas 
kg 
EFTA00233359
Sivu 32 / 549
THE PALM BEACH POST 
• 
FRIDAY, SEPTEMBER 18, 2009 
ti)t'TjM
... Just don't ask millionaire 
Palm Beach sex offender Jeffrey 
Epstein about his pri-
vates. Local attorney 
Spencer Kurth did dur-
ing a deposition Sept. 
2, and Epstein walked 
out— 100 seconds 
after it started. And 
it was all caught on a 
video posted on Page 
71ea% online sister, 
page2live.com. Epstein did answer 
the first question: "What is your 
name?" But he balked at the sec-
ond: "Is it true that ... you 
have an egg-shaped penis?" 
Epstein took off his microphone 
and left. And it cost the Wall Street 
prodigy Epstein: He was fined 
Epstein 
$800 by the West Palm Beach 
court currently hearing civil 
lawsuits filed by women whom Ep-
stein paid for sex when they were 
underage. "It absolutely was an im-
portant question," said Kuvin. "If 
he claims to have never met them, 
then we should know whether the 
victim is telling the truth."The 
deposition has been reset for Oct. 
8, and Epstein should expect the 
same question ... Burt Reynolds 
was back in rehab Thursday. It was 
just for a daylong refresher at the 
Hanley Center in WPB. Reynolds, 
73, admitted himself at Hanley for 
a 30-day program in mid-August 
and was released last week. He 
admitted to battling an addiction 
to pain pills ... 
WEST PALM BEACH -- Finan-
cier and sex offender Jeffrey 
Epstein's secret deal struck 
with federal prosecutors Is 
due to be released to the 
pubik today. Circuit Judge 
Jeffery Colbath ruled the 
document was improp-
erly sealed and should be 
released, and an appellate 
court agreed. Under the 
deal, Epstein avoided fed-
eral charges and pleaded 
guilty in state court to 
fFlorn, solicitation of pros-
titution and procuring a 
person under the age of 
18 for prostitution. In July 
2008, he was sentenced 
to 18 months in jail and 
later allowed out up to 
six days a week on work 
release. He now faces at 
least 20 civil lawsuits filed 
by women who say they 
were victims. 
EFTA00233360
Sivu 33 / 549
THE PALM BEACH YOST 
• 
FRIDAY, UNE 26.2009 
Judge agrees 
Epstein's sex 
By SUSAN SPENCER-WENDEL 
Palm Rear* Past Stqff Writer 
WEST 
PALM 
BEACH 
— A circuit judge agreed 
Thursday to unseal a deal 
billionaire Jeffrey Epstein 
struck with federal pros-
ecutors to avoid their fil-
ing of charges in the wake 
of his sex scandal with 
underage girls. 
Circuit Judge Jeff Col-
bath said he would not re-
lease Epstein% agreement 
with federal prosecutors 
until Monday, allowing 
him time to redact the 
to unseal 
scandal deal 
Epstein 
names of vic-
tims. Colbath 
ruled that the 
deal had not 
been 
sealed 
properly. 
Jack 
Goldberger, 
Epstein% at-
torney, immediately asked 
for a stay of Colbath% deci-
sion to unseal the agree-
ment in order to appeal it. 
A hearing on that request 
is set for this morning 
See EPSTEIN, 5B to 
Epstein scheduled 
fbr release in July 
00. EPSTEINfrom 113 
Attorneys for women 
now suing Epstein, as well 
as attorneys for The Palm 
Beach Post, had asked Col-
bath to release the deal, 
arguing the pUblic and 
the victims have a right 
to see it. 
"There is nothing more 
fundamentally important 
than for the public and 
press to observe how the 
governntent is doing its 
job," IS attorney Deanna 
Shullman said. "There 
is great public interest 
in how everybody in this 
rage is doing their job." 
Goldberger argued that 
the confidential agreement 
Epstein struck with federal 
prosecutors should remain 
confidential. Included in it, 
Goldberger said, are ref-
erences to federal grand 
jury proceedings, which 
are secret and protected 
by federal rules. A federal 
judge should decide the 
issue, he said. 
Attorneys 
Spencer 
Kuvin and Brad Edwards, 
who represent some of the 
women now suing Epstein, 
both said they were 'not 
surprised by Epstein% at-
torney moving to appeal 
"Any chance to stall 
in any way and keep the 
agreement out of public 
disclosure, they will take 
it," said Edwards outside 
court. 
He will have served 
about 13 months of an 
18-month sentence. 
Epstein pleaded guilty 
nearly one year ago to 
solicitation of prostitution 
and procuring teenagers 
for prostitution and was 
sentenced to 18 months in 
prison. 
A sheriff§ office official 
confirmed Thursday that 
Epstein will be release( 
from the Palm Bead 
County Stockade on Jul-
22 — nearly 13 month 
into his sentence. 
Sheriff's office spoke 
person Eric Davis sa' 
Epstein has earned ga 
time for good behavi 
and for participating in 
work-release program. 
The 
began ye; 
ago aftesraglm Beach 
lice began investigati 
reports that young won 
were being brought to 
manse on El Brillo Wa; 
massage him and have 
with him in exchange 
money. 
Displeased with 
way the state atton 
office handled the t 
Palm Beach police 
forwarded informatk 
the Federal Bureau 
vestigation. 
O susall -50encel wade( 
Opbbpost.com 
EFTA00233361
Sivu 34 / 549
Akerman Senterfitt 
Re: Jeffrey Epstein 
Dear Judge Davis: 
). MICHAEL BURMAN. PA" 
GREGORY W. COLEMAN. M. 
ROBERT D. CRITTON4IL. PA ' 
BERNARD A. LEBEDEKER 
MARK T. LUTTIER. PA. 
MICHAEL ). PIKE 
MICHAEL L. SCHEVE 
DEAN T. XENICK 
DAVID A. YAREMA 
I t LORIDA BOARD CERTNIED CIVIL TRIAL LAWYER 
2ADmITTED TO PRACTICE IN FLORIDA AND COLORADO 
BURMAN, CRITTON 
LUTTIER&COLEMAN,LLP 
YOUR TRUSTED ADVOCATES 
A LIMITED LIABILITY PARTNERSHIP 
May 25, 2010 
Honorable Edward B. Davis 
Sent by email and 
by U.S. Mail to Judge Davis only 
ADELQVI J. BENAVENTE 
PARAUGAtliNVESTIGATOR 
JESSICA CADWELL 
BOBBIE M. MCKENNA 
ASHLIE STOKEN•BARING 
BETTY STOKES 
PARALEGALS 
RITA H. BUDNYK 
OF COUNSEL 
EDWARD M. RICCI 
Of COUNSEL 
We are in receipt of Mr. Josefsberg's letter to you dated May 21, 2010. We confirm that 
Mr. Epstein settled each and every case brought by the attorney-representative selected by you. 
We write this response only to advise you that Mr. Epstein has never refused to pay 
reasonable settlement-related fees that are within the scope of the NPA. He has already paid 
the attorney-representative $526,000. The attorney-representative has not yet presented him 
with a final invoice for settlement-related work. The incomplete invoices that have been 
presented seek $2,000,000 in additional fees. Mr. Epstein has been advised by his attorneys 
that the requested fees include duplicative work, charges that relate to preparation for litigation 
not settlement (thus outside his NPA-fee obligations) and charges that are unreasonable and 
that should be reviewed by a Court rather than simply paid without meaningful review. A 
significant amount of the total fees (over $1,000,000) is for legal work that the invoices 
document were done by two outside attorneys who are not even attorneys with the Podhurst 
Orseck, P.A. law firm. 
Mr. Epstein's disputes the necessity for and redundancy of these 
charges. 
We respect Your Honor's selection and regret that the issue of disputed fees has resulted 
in litigation. Mr. Epstein is committed to paying whatever fees and costs are determined by the 
EFTA00233362
Sivu 35 / 549
May 25, 2010 
Page 2 
Court to be his obligation, if any, but he is not required to simply write a blank check. I have 
filed a motion in the case pursuant to F.R.Civ.P. 67, to allow him to deposit $2,000,000 in Trust 
with the Court pending the outcome of the Complaint which confirms his commitment. 
Cordially yo 
Rob 
D. Critton, Jr. 
RDC/JPL:ab 
Cc 
AUSA - 
, AUSA — 
Jack Goldberger, Esq. 
Robert Josefsberg, Esq 
EFTA00233363
Sivu 36 / 549
1 
1 
IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT 
2 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CRIMINAL DIVISION 
3 
4 
STATE OF FLORIDA 
) 
5 
) 
vs 
) 
CASE NO. 06 CF9454AMB 
6 
) 
08 9381CFAMB 
JEFFREY EPSTEIN 
) 
7 
) 
Defendant. 
) 
8 
) 
9 
PLEA CONFERENCE 
10 
11 
PRESIDING: HONORABLE DEBORAH DALE PUCILLO 
12 
APPEARANCES: 
13 
ON BEHALF OF THE STATE: 
BARRY E. KRISCHER, ESQUIRE 
14 
State Attorney 
401 North Dixie Highway 
15 
West Palm Beach, Florida 33401 
By: 
LANNA BELOHLAVEK, ESQUIRE 
16 
Assistant State Attorney 
17 
ON BEHALF OF THE DEFENDANT: 
ATTERBURY, GOLDBERGER & WEISS,P.A. 
18 
250 Australian Avenue South 
Suite 1400 
19 
West Palm Beach, Florida 33401 
By: JACK GOLDBERGER, ESQUIRE 
20 
21 
CERTIFIE
D  COPY
22 
23 
June 30, 2008 
24 
Palm Beach County Courthouse 
West Palm Beach, Florida 33401 
25 
Beginning at 8:40 o'clock, a.m. 
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER 
EFTA00233364
Sivu 37 / 549
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BE IT REMEMBERED that the following 
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proceedings were had in the above-entitled cause 
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before the HONORABLE DEBORAH DALE PUCILLO, one of 
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the judges of the aforesaid court, at the Palm 
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Beach County Courthouse, located in the City of 
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West Palm Beach, State of Florida on June 20, 2008 
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beginning at 8:40 o'clock, a.m. with appearances 
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as hereinbefore noted, to wit: 
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THEREUPON: 
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MR. GOLDBERGER: Good morning, Judge, 
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Jack Goldberger on behalf of Jeffrey 
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Epstein. 
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THE COURT: Good morning. 
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MR. GOLDBERGER: Your Honor, we are 
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here for a plea conference. 
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THE COURT: Raise your right hand. 
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THEREUPON: 
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JEFFREY EPSTEIN, 
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after being called as a witness by the Defense and 
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after being first duly sworn by the Court, was 
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examined and testified as follows: 
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THE DEFENDANT: Yes, ma'am. 
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THE COURT: 
Is this one case or two? 
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MS. BELOHLAVEK: Two. 
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THE COURT: May I see the PC 
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER 
EFTA00233365
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degree felony, punishable by a maximum 
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penalty of five years in the Department of 
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Corrections, and a minimum, probation. No 
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mandatory minimums, correct? 
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MS. BELOHLAVEK: Correct. 
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THE COURT: The defendant has no 
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prior criminal record? 
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MS. BELOHLAVEK: Correct. 
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MR. GOLDBERGER: Yes, Your Honor. 
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THE COURT: You checked the NCIC as 
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well as State records? 
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MS. BELOHLAVEK: Yes. 
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THE COURT: And the guideline score 
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sheet I have before me shows 21.5 months in 
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the Department of Corrections as the lowest 
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permissible prison sentence in months. 
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Both sides agree to the preparation of the 
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guideline score sheet? 
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MR. GOLDBERGER: We so agree, Your 
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Honor. 
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MS. BELOHLAVEK: Yes. 
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THE COURT: What is proposed -- it 
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goes on for pages. 
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MR. GOLDBERGER: Your Honor, much of 
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the documentation is acknowledgement by my 
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER 
EFTA00233366
Sivu 39 / 549
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affidavit in both cases, please? 
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MS. BELOHLAVEK: There are no PC 
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affidavits. There was originally an 
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Indictment, the second charge was filed 
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arising out of the booking. It was all 
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testimony presented to the grand jury. 
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THE COURT: Let me see the Indictment 
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then? 
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I have one Indictment, one 
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Information? 
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MS. BELOHLAVEK: Correct. 
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THE COURT: So one case is charged by 
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Indictment, one is charged by Information? 
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MS. BELOHLAVEK: Correct. 
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THE COURT: In case 2006036744 you 
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are charged with procuring a person under 
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18 for prostitution, a second degree 
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felony, maximum penalty of fifteen years 
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Department of Corrections; minimum, some 
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period of probation. No mandatory minimum 
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apply, is that correct, State? 
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MS. BELOHLAVEK: Correct. 
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THE COURT: And in case number 06 
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9454CF, you are charged with felony 
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solicitation to prostitution, a third 
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER 
EFTA00233367
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client to community control, sex offender 
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status. 
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THE COURT: I understand. 
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Okay. What is proposed -- those 
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are the maximums and minimums, Mr. Epstein. 
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What is proposed is that you will be 
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pleading guilty to felony solicitation to 
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prostitution and procuring a person under 
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18 for prosecution. A PSI would be waived, 
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you would be adjudicated guilty of both 
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felonies, is that correct? 
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MS. BELOHLAVEK: Correct. 
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THE COURT: And on 06 9454, the 
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defendant to be sentenced to 12-months in 
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the Palm Beach County -- detention 
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facility? He's going to do time in the 
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jail? 
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MS. BELOHLAVEK: Yes. 
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THE COURT: With credit for one day 
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served. And on 08 9381, he is to be 
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sentenced to six months in the Palm Beach 
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County jail detention facility, with credit 
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for one day served. And the six month 
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sentence is to be served consecutive to the 
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12 month sentence? 
PHYLLIS A. DAMES, OFFICIAL COURT REPORTER 
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