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FBI VOL00009
EFTA00259984
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• .0.01-30-2008(808) 10:06 P. 009/01a • proposed agreements with the State Attorney's Office prior to entering into those agreements. The United States shall provide Epstein's attorneys with a list of individuals whom it has identified as victims, as defined in 18 U.S.0 § 2255, after Epstein has signed this agreement and been sentenced. Upon the emecution.ofthis agreement, the United States, in consultation with and subject to the good faith approval of Epstein's counsel, shall select an attomeyrepresentative forthesepersons, who shall bepaid for by Epstein. Epstein's counsel may contact the identified individuals through that representative. If any of the individuals refitted to in paragraph (7), supra, elects to file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction ofthe United States District Courtforthe Southern District ofFlorida over his person sneVorthesubjectmater,and Epstein waives hisrightto contest liability and also waives his rightto contcstdamagea up to an amount as agreed to between the identified individual and Epstein, so long as the identified individual elects to proceed exclusively under 18 U.S.C. § 2255, and agates to waive any other claim for damages, whether pursuant to state, federal, or common law. Notwithstanding this waiver, as to those individuals whose names appear on the listprovided by the United States, Epstein's signature on this agreement, bis 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 agreement also is not to be construed as an admission of eivil or criminal liability or a waiver of anyjwisdictional 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 elect to proceed exclusively under 18 U.S.C. § 2255, as set forth in paragraph (8), supra, neitherEpstein's signature onthis agreement, nor its tetras, nor any resulting waivers or settlements by Epstein are to be construed asadmissions or evidence of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person, whether or not her name appears on the list provided by the United States. 11. Epstein shall use his best efforts to enter his guilty plea and be Page 4 of 7 EFTA00260004
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JO-30-2008 (MO4 ) 10:05 P.010/014 • sentenced not later than October 26, 2007. The United States has no ahJectiott to-Epstein self-reportingro-beginseridng_hissemenet. not later than January 4, 2008. 12. Epstein agrees that he will max afforded am, benefits with respect to gain time, other than the rights, opportunities, andbenefits as any other inmate, including but not limited to, eligibility for gain time medit 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 gain time he camel during his period of incarceration_ 13. The parties anticipate that this agreement will not be made part of any public record. If the United States receives a Freedom of informatirm Act request or any compulsory process commanding the disclosure of the agreement, it will provide no dee to Epstein before making that Epstein understands that the United States Attorney has no authority to require the State Attorney's Office to abide by any tams of this agreement Epstein uaderatands that it is his obligation to undertake discussions with the State Attorney's Office and to use his best efforts to ensure compliance with these procedures, which compliance will be necessary to satisfy the United States' interest. Epstein also uncle:mugsthat his his 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 pleadguilty and to provide compensation in the manner described above, ifEpstein successfully fulfills all of theterms and conditions ofthis agreemnit the United States also agrees that it will not institute any criminalc es but not limited to Further, upon executioner -this agreement and a plea agreement a 's Office, the federal Gland Jury investigation will be suspended, and all pending federal Grand Jury subpoenas will be held in abeyance unless and until the defendant violates any term of this agreement The defendant likewise agrees to withdraw his pending motion to intervene and to quash certain grand jury subpoenas. Both parties agree to maintain their evidence, specifically evidence requested by or directly related to the grand jury subpoenas that have been issued, and including certain computer equipment, inviolatetmtil allofthe terms ofthis agreement have been satisfied_ Upon the successful completion of the terms of this agreement, all outstanding grand jury subpoenas shall be deemed withdrawn. Page $ of EFTA00260005
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. MI-30-200804M 10:06 By signing this agreement, Epstein asserts and certifies that each of these tents 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 certifiesthathe is aware of the factfoat 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 fluter is aware that Role 4g(b) of the Federal Rules of Criminal Procedure provides that the Court may dismiss an indictment, information, or complaint for thmecessary delay in presenting a charge to the Grand Jury, filing an information, or in bringing a defendran to trial. Epstein herebyrequests that theUnited States Attorney forthe SouthanDistrict ofFloridadefersuch prosecution. Epstein agrees and consents that any delay from the daze of this Agreement to the date of initiation of prosecution, as provided for in the tetras expressed herein, shall bc deemedto be a necessary delay at his own request, andhe hereby waives any defense to such prosecution on the groundthat such delay operatedto deny biro rights under Rule 48(b) of the Federal Rules ofCriminal Procedure and the Sixth Amendment to the Constitution ofthe United States to a speedy trial or to berths prosecutionly reason of the running ofthestatutc of limitations for a period of months equal to the period between the signing of this agreement and the breach of this agreement as to those offenses that were the subject of the grand jury's investigation. Epstein further asserts and certifies that he understands that the Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all felonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees and. consents that, if a prosecution against him is instituted for any offense that was the subjectof the grand jury's investigation, itmay be by way ofanInfommtion signed and filed by the United States Attorney, and hereby waives his right lobe indicted by a grand jury as to any such offanc. Page 6 of 7 EFTA00260006
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.1014-30-200 NM 10:06 P. 012/016 By signing this agreement, Epstein asserts and ratifies that the above has bcen read and explainedto him. Epstein hereby states that be understands the condbions of this Non- Prosecution Agreement and amt es to comply with then Dated: Data Dated: Dated: R. ALEXANDER-ACOSTA UNITED STATES ATTORMY GERALD LEFCOURT, ESQ. COUNSEL. TO JEFFREY EPSTEIN LILLY ANN SANMZ, ESQ. ATTORNEY FOR JEFFREY FiSTEIN Page 7 of 7 EFTA00260007
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• JUN-30-2008(10N) 10:07 P. 013/ula . • By siMing this agreement, Epstein asserts and certifies that the above has ban read and explained to him. Epstein hereby states that be anderstrads the conditions of this Non- Prosecution Agreesaent and agrees to comply with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: By: Dated; Dated: (119-(tio7 Dated: LILLYANNSANCLIEZ. ESQ. ATTORNBYPOR JEFFREY EPSTEIN Rasa 7 of 7 .1 EFTA00260008
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IN RE: INVESTIGATION OF 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 theattorney representative suggested by the independent third-party prior to the final designation of the attorney representative. TB. 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 representativeselected by the independent third party. This provision, however, shall not obligate Epstein to pay the fees 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. EFTA00260010
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t. By signing this Addendum, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states thai he understands the clarifications to the Non- Prosecution Agreement and agrees to comply with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: Dated: Dated: Dated: By: 1.11. TTORNEY . JEFFREY EPSTEIN ERALD LEFCO RT ESQ. COUNSEL TO JEFFR Y EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN EFTA00260011
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THAT'S THE STORY Storyteller Jim Weiss brings famous literary characters to life. Academia, Page 5 A 'DYNAMO' Bobbi Horwich finds exercise helps her deal with personal struggles. Health, Page 8 Palm Beach Dail Established 1897 MBeachnai yNews.co- THE SHINY SHEET® TUESDAY, DEC. 15, 2009 News 50 cents Push made to keep bars open late Nick Coniglio, sisters start campaign urging Town Council to allow establisments to stay open until 3 a.m. By WILLIAM KELLY Daily News Staff Writer The Coniglio family, which owns two businesses on Royal Poinciana Way, is waging a petition and letter-writing cam- paign urging the Town Council to allow bars to stay open until 3 a.m. The council has been flooded with let- ters from residents protesting any attempt to dose the town's bars at 1 a.m. Nick Coniglio, who manages Cucina Dell 'Arte and Nick and Johnnie's, said Monday he and his sisters encouraged the letters to be written, and will present a pe- tition with more than 100 signatures to the council on Thursday, when the subject is on the meeting agenda. The meeting be- gins at 9:30 a.m. in the Emergency Opera- tions Center at the Central Fire Station. "We sent out a couple of emails and said. 'fawns, watt attnrann me what wa an?* MENORAH LIT AT HANUKKAH CELEBRATION Hundreds gather at Bradley Park event Above: Robert and Silvia Robbins of Boca Raton watch the festivities Monday during the 12th annual Hanukkah celebration at Bradley Park. Six synagogues participated in the annual event. EFTA00260012
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Jeffrey Epstein settles two lawsuits Page 1 of 2 PalmBeactiDailyflrics9m Jeffrey Epstein settles two lawsuits By MICHELE DARGAN Daily News Staff Writer Monday, December 21, 2009 Updated 5:45 p.m. ca PRINTTHIS Powered by ClIckabllity Sex offender Jeffrey Epstein has settled a lawsuit filed by a young woman who alleged that at 15-years-old she became what amounted to a sex slave for Epstein, according to court documents. The lawsuit — filed by Jane Doe 102 in May by Miami attorney Robert Josefsberg — was dismissed Dec. 8 by a signed order from U.S. District Judge Kenneth Marra, closing the case. The order was dismissed with prejudice, meaning the case cannot be refiled. Court records show Epstein settled another case with sexual abuse allegations brought by Jane Doe 101, a case filed in April by Josefsberg. Marra signed that dismissal order with prejudice on the same day as Doe 102. Epstein's civil attorney Robert Critton was unavailable for comment. Josefsberg did not return calls for comment. The Doe 102 complaint alleged that Epstein enticed the victim to quit her job as a changing room assistant at the Mar-A-Lago Club, where in 1998 she earned $9 an hour. The lawsuit said the girl was recruited at the club by Epstein's then-companion Ghislaine Maxwell, who told the girl she could learn massage therapy and earn a "great deal of money." In addition to Palm Beach, Epstein took the girl to New York City; Santa Fe, N.M.; Los Angeles,; San Francisco; St. Louis; Europe; the Caribbean and Africa, according to the lawsuit. The lawsuit alleged that in all of these locations she was required to engage in sex acts with him and other women, including other minors. The lawsuit also alleged that the victim was not only required to satisfy Epstein's "every sexual whim," but that she also was exploited by Epstein's adult male peers. They included royalty, politicians, academicians, businessmen and others in various locations around the world, the suit said. The lawsuit, like the more than a dozen other lawsuits filed against the billionaire money manager, says his modus operandi in the initial visit was the same: the minor girl was taken to Epstein's mansion on El Brillo Way and led upstairs to a spa room by one of Epstein's assistants, where he would ask the girl to perform massages and/or various sex acts, for which he would pay her. http://cox.printthis.elickability.com/pt/ept?action=cpterritle=Jeffrey+Epstein+settles+two... 12/22/2009 EFTA00260013
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.• Jeffrey Epstein settles two lawsuits Page 2 of 2 The allegations in the Jane Doe 101 complaint say the victim was a 17-year-old high school student when she was brought to Epstein's mansion in spring 2003. According to the complaint, Epstein asked her what year she would graduate high school, to which she replied 2004. She gave Epstein a massage, which involved him touching himself and her while she was naked from the waist up. She was paid $200 and was "lured" back to the mansion on at least one other occasion. Epstein, 56, was released from the Palm Beach County Stockade in July, after serving less than 13 months of his 18-month sentence for procuring a minor for prostitution and soliciting prostitution. He is serving one year of probation in his Palm Beach mansion. Find this article at: http://www.palmbeachdailynews.cominewskontentinewsf2009/12/21twebepsteinslave122109.html LI Check the box to include the list of links referenced in the article. Copylight 2008 Palm Beath Daily News. All rights reserved. http://cox.printthis.clickability.corn/pt/cpt?action=cpt&title=Jeffrey+Epstein+settles+two... 12/22/2009 EFTA00260014
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• GOING BACK 'TO ITS ROOTS' - AND RULES Paradise Ball to be smaller, more sophisticated. Shannon Donnelly, Page 6 Palm Bea TIMELY AWARD First Serve honors volunteer of the year prior to Pro-Am tennis tournament. Page 9 PalmBeachDailyNews.com WEDNESDAY, DEC. 9, 2009 10 Pages 50 cents `SURFING WITH FRIENDS IS LIKE SURFING WITH FAMILY' •iiitt'sfar - at a • _ ehla • ar - 19'1 ---• a..- 'a' • te. 4. a*. 1 dtacitsifi say Above: Surfers from the same West Palm Beach neighborhood gather Sunday on the beach near Clarke Avenue. Left: Chris Lorenz catches a wave during a rough, windy day. Daily News Photos by Jeffrey Langlois Ex-exec: Overturn my fraud conviction Conrad Black's attorney tells U.S. Supreme Court honest services fraud statute 'vague,' but Justice Department defends law. By MICHELE DARGAN Daily News Staff Writer In his quest to overturn his fraud con- viction, jailed media mogul Conrad Black challenged the validity of honest services fraud, the federal law used to put three Palm Beach County commissioners behind bars. In oral arguments to the U.S. Supreme Court Thesday, the jai led press baron Is asking to have his conviction thrown out. Black's attorney Miguel Estrada called the statute "vague In all of its applications." Black Imprisoned at Coleman Correctional Institution since March 2008. Lai EFTA00260015
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•••11 ••••P 4 GOING BACK 'TO ITS ROOTS' - AND RULES Paradise Ball to be smaller, more sophisticated. Shannon Donnelly, Page 6 TIMELY AWARD First Serve honors volunteer of the year prior to Pro-Am tennis tournament. Page 9 Palm Beach Dail Established 189 THE SHINY SHEEN) WEDNESDAY, DEC. 9, 2009 News 10 Pages 50 cents `SURFING WITH FRIENDS IS LIKE SURFING WITH FAMILY' -*OS it "et' 41. • "la 144 Above: Surfers from the same West Palm Beach neighborhood gather Sunday on the beach near Clarke Avenue. Left: Chris Lorenz catches a wave during a rough, windy day. Daily News Photos by Jeffrey Langlois • Crifini un Iniairliec 1i-1'4-Sunday ritual V. MI, Ex-exec: Overturn my fraud conviction Conrad Black's attorney tells U.S. Supreme Court honest services fraud statute 'vague,' but Justice Department defends law. By MICHELE DARGAN Dail) Yeas Stall Writer In his quest to overturn viction, jailed media mogul Conrad Black challenged the validity of honest services fraud, the federal law used to put three Palm Beach County commissioners behind bars. In oral arguments to the U.S. Supreme Court Tuesday, the jailed press baron is asking to have his conviction thrown out. Black's attorney Miguel Estrada called the statute "vague in all of its applications." Justices appeared to agree with Black — that the law is vague and has been used his fraud con- Black Imprisoned at Coleman Correctional Institution since March 2008. • • EFTA00260016
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A6 Palm Beach Daily News, Sunaayktober 18,2009 PALM BEACH GOVERNMENT Sewers, beach, pensions challenge budgets Council faces future choice of services vs. property tax hikes. By WILUAM KELLY Daib News Staff Writer The biggest challenge before the Town Council this season is the need to put the town's long-term fi- nances on a sound footing. The $67 million operat- ing budget for the year that began Oct. 1 is balanced, but Town Manager Peter Elwell has said the council must devote more funds to long-term capital improve- ment needs — $6 million a year instead of the current $2.6 million. The capital needs include a townwide replacement of the sani- tary sewer system, tagged at about $25 million. Also looming are ero- sion-control costs that could exceed $100 million over the next 10 years. The council is considering es- tablishing a townwide tax district to assess all property owners to meet those costs. In addition to capi- tal and coastal needs, the town also must address personnel and escalating employee costs if it is to keep the budget balanced, Elwell has said. If the pension costs aren't addressed, the town could be faced with a deficit as early as 2012, the Finance Department has warned. The council this year held the line on property taxes even as other coun- ty taxing districts, in- cluding the Palm Beach County Commission, de- cided to hike their rates to cover revenue losses tied to the poor economy. The question before the Palm Beach council is, how ZONING can It meet its long-term commitments without in- creasing taxes or compro- mising services to town residents? Governmental tional expenses already have been cut back. About 10 vacant employ- ee positions were eliminated this year, a two-year hiring freeze re- mains in effect, and health ben- efits have been trimmed. The council re- cently told Elwell to develop a plan that shows a bal- anced budget for the next five fiscal years. The town has hired a consultant to review its pen- sions and report by Oct. 31. The report will be reviewed Nov. 11.13 by the town's PB considering more flexibility in use of solar-panels on roofs By WILLIAM KELLY Daily News Staff Writer I In a town that prizes aes- thetics more than most, the use of solar power is restrict- ed by an ordinance that lim- its panels to a maximum of 15 percent of roof coverage. Town officials are con- sidering loosening the re- striction so the town is more accommodating to solar technology. That is one of the items before the Planning and . Zoning Commission and town staff this season. The town staff are studying an amendment that would ex- pand the cap to 30 percent of the roof. State law does not al- low the town to prohibit so- According to Castro, a major obstacle to solar pan- el installation has nothing to do with town law: The panels must be bolted to roof trusses, which causes homeowners to lose their roof warranty. Other study topics this season include: • A reduction in re- quired parking garage spaces for single-family homes on smaller lots. The change would allow more flexible use of property without an increase in den- sity, Castro said. • A reduction in the front setback for single- family homes in the R-B zoning district to allow the opportunity for larger back yards. The district Is mainly structures east or partial- ly east of the state Coastal Construction Control Line. Under the change, base- ments or sub-basements would count as a story. But the change would not allow an increase in building or story heights as measured from a public street. — [email protected] ADVERTISEMENT zair— Discover Worth Avenue's Remarkable Charms Worth Avenue is known worldwide for fine innrbandise and extroordinety opera- Elwell Says town met budget more ix long-term capral improvement threepension boards, who will ccept comment from the µblic and town em- ployes, Elwell said in a re- centhterview. Mpecial council meet- ing will focus on the pension issue on Dec. 17. 'We want a menu of options as broad as possible that will identify the savings and potential impact in terms of mar- ketplace competi- tiveness: Elwell said. The town can't cut costs by re- ducing benefits that already have accped. But it can alter beSits for existing and fu- t urtemployees effective on sore future date, he said. Aside from the budget, othr high-profile issues before the council this year include possible creation of a 30-acre zoning overlay in the Royal Poinciana Way business district. The overlay would pro- vide height and densi- ty incentives for property owners whose redevelop- ment plans include char- acteristics desired by the town, such as vies or exten- sive landscaping. The overlay incentives have sparked debate be- tween those who say the street is in decline and those who want to protect it from over-development. The council had sched- uled a Nov. 18 special meet- ing to take up the issue, but that has been canceled to give the Planning and Zon- ing Commission more time to work with town cqnsul- tant Marcela Camblor on zoning amendments tied to the overlay. 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