EFTA01247988

LAW OVINCE• or 
Grateap B. LErcouirr, P.0 
A PROFZIISIONAL CORPORATION 
I•8 EAST 711`.• 
NEW YOBIELNEW YORK 1002E 
GERALD B. LEICOURT 
lelcougloIskourlaw.00in 
SHERYL C. REICH 
mkbeslonliammon 
Ft CHAT° C. STAIIILE 
IA.
FAITH A. FRIEDMAN 
BY HAND DELIVERY 
June 25, 2007 
q., First Assistant United States Attorney 
Esq., Chief, Criminal Division 
The United States Attorney's Office 
Southern District of Florida 
99 NE 4th Street 
Miami, Florida 33132 
Deputy Chief, Northern Region 
Assistant United States Attorney 
...
r
e
tates Attorney's Office 
Southern District of Florida 
500 South Australian Avenue, Suite 400 
West Palm Beach, Florida 33401 
Dear 
Re: Jeffrey E Epstein 
SELEFIMONC 
(2121 7370400 
FACSIMILE 
(21210/1243122 
As you are aware, we represent Jeffrey E. Epstein in connection with your ongoing 
investigation. We write to you in advance of our June 26, 2007, meeting to address some of the 
concerns that have been raised during our recent conversations. Although not exhaustive of all 
the issues we wish to discuss, or points we intend to raise, we believe this submission will 
facilitate a more productive meeting by giving you an overview of our position and the materials 
we plan to present in order to demonstrate that none of the statutes identified by you can rightly 
be applied to the conduct at issue here. We are prepared to discuss the issues raised herein 
further at tomorrow's meeting as well as to discuss additional concerns you may voice, all for the 
purpose of demonstrating why no federal prosecution should lie. 
The Federal Criminal Statutes Identified Should Not Be Applied Here 
It is clear from both the fundamental principles of federal criminal law and the specific 
statutes in question that federal law is not intended to prohibit, nor does it prohibit, all 
"wrongful" sexual activity. Indeed, there is no federal crime of sex with an underage person — 
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EFTA01247988

taw Of • CS 00 
GERALD a T savors-sr, P.C. 
Office of the United States Attorney 
Southern District of Florida 
June 25, 2007 
Page 2 
even assuming such an act took place in this case — nor could there be such a crime under the 
United States Constitution.' By and large, the delineation of such conduct (that is, determining 
what conduct is wrongful), and the prosecution for such conduct, have been delegated to the 
states. Such conduct is punishable under state laws, under which the age of consent varies from 
14 to 18 with many states making sex with a 16 year old completely lawful regardless of the age 
of the other person .2 In short, the role of federal law in this area is carefully circumscribed. 
The legislative history of the federal "sex" statutes at issue evinces no federal concern 
with the prevalent local phenomenon of young adults — 16 or 17 years of age — voluntarily 
choosing to engage in sexual contact with anyone they desire. This is strictly a state concern, 
which some states have chosen to criminalize, while others have not, and some local prosecutors 
have chosen to prosecute, while others have not. It is not an accident that, as far as we have been 
able to determine, there is no federal case involving a defendant who maintains a reasonable 
mistake of fact defense, where that defendant reasonably believed the other person was 18 years 
of age. The federal statutes were not meant to apply in those circumstances as such conduct is a 
matter of state law. The federal statutes were intended to address those cases involving sexual 
activity with children. Indeed, the federal concerns intended to be redressed by these statutes, as 
evidenced by the legislative history; the advisory titles of the statutes; and even their sometimes 
broad language, are: the use of coercion and violence to lead children into a life of prostitution 
(12, 13, or 14 years old, or younger); sex trafficking and slavery of children; interstate or foreign 
travel to have sex with children (or engage in other illegal sexual activity); and trolling for 
children on the intemet in order to have sex with them. None of these concerns is present here.' 
These constitute the paradigmatic federal concerns, mainly because the states are ill 
prepared to deal effectively with interstate and international trafficking of children. On the other 
hand, the states are fully capable of deciding how to deal with entirely local matters relating to 
men who allegedly have inappropriate sexual contact with local young women. To disregard 
thcsc concerns, to ignore congressional purpose, and attempt to give the federal statutes their 
broadest possible interpretation would cause the undesired result of criminalizing federally 
virtually all acts of prostitution or sexual misconduct — a result not intended by Congress and 
United States v. Lopez 514 U.S. 549 (1995). 
2 Notably, Chapter 109A statutes, e g.. §§ 2241.2245, to which § 2423(b) inherently refers, each deal in terms of 
force and/or age. A review of these statues demonstrates that in each instance unless force is involved, the victim 
must be under 16 years old fora prosecution to lie. 
We understand the Office has taken the view that Mr. Epstein targeted underage high school students. This was 
absohnely not the case and we will be prepared to discuss at our meeting the objective evidence demonstrating no 
such targeting occurred. 
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EFTA 0()094216 
EFTA01247989

Loa/ ocroccs a 
GERALD H. bLecourr, 
Office of the United States Attorney 
Southern District of Florida 
June 25, 2007 
Page 3 
unlikely to be sanctioned by the courts.4 To stretch the statutes in the unprecedented way it 
appears is contemplated would do just that. 
Although in this memo we have focused primarily on the federal sex statutes, in the same 
way that those statutes cannot logically be expanded to cover the conduct at issue, neither can the 
statutes governing monetary transactions. These latter statutes, designed to curb the use of what 
would appear to be otherwise innocent financial transactions to disguise proceeds of unlawful 
activity and avoid internal Revenue Code requirements, have no place in this case. The ills 
sought to be remedied by these statutes are far removed from the conduct in which Mr. Epstein 
purportedly engaged. 
We address each statute in turn, starting with those regulating monetary transactions. 
18 U.S.C. § 1956(aX3) • The Money Laundering Statute - Does 
Not Apply to Mr. Epstein's Alleged Misconduct 
No reasonable reading of the money laundering statute can countenance such a charge 
against Mr. Epstein, for the statute on its face, or as even applied by the courts, has absolutely no 
application to the alleged misconduct. Under the facts of this case, to charge Mr. Epstein with 
violating the money laundering statute would be both unprecedented and inappropriate. 
The money laundering statute was designed to be used and has been construed as a 
"concealment" statute, not a spending statute. See United Slates v. Shepard, 396 F.3d 1116 (10th 
Cir.), cert. denied, 545 U.S. 1110 (2005); United States v. Hall, 434 F.3d 42 (1st Cir. 2006) 
(money laundering statute does not criminalize the mere spending or investing of illegally 
obtained assets. Instead, at least one purpose for the expenditure must be to conceal or disguise 
the assets). 
The Eleventh Circuit has held that "[tjo prove money laundering under § 1956(aX3), the 
government must show that the defendant (I) conducted or attempted to conduct a financial 
transaction (2) involving property represented to be the proceeds of specified unlawful activity, 
(3) with the intent (a) 'to promote the carrying on of specified unlawful activity,' (b) 'to conceal 
or disguise the nature, location, source, ownership, or control of property believed to be the 
"Section 1591 does not criminalize all acts of prostitution (a vice traditionally governed by state regulation). 
Rather, its mach is limited to sex trafficking that involves children or is accomplished by force, fraud, or coercion". 
United States v. Evans, 076 F.3d 1176, 1179 a I (I I* Cir. 2007). Nor, has the Department of Justice deemed it 
appropriate. See. e.g. linked Stales Department of Justice Civil Rights Division Antl-Trafficking News Bulletin, 
August/September 2004, Vol. 1. Nos. 8 and 9. at 2 (in order to address the demand for prostitution the federal 
government must work with the state. as it is state law that controls). 
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EFTA 0(1(194217 
EFTA01247990

LAW Orria• 
OF 
Oman) B. InCOUBT, P.G. 
Office of the United States Attorney 
Southern District of Florida 
June 25, 2007 
Page 4 
proceeds of specified unlawful activity,' or (c) 'to avoid a transaction reporting requirement 
under State or Federal law"'. United States v. Puche, 350 F.3d 1137 (II Cir. 2003);$ see also 
United States v. Arditti, 955 F.2d 331 (51° Cir.), reh'g denied, cert. denied 506 U.S. 998 (1992), 
cert. denied 506 U.S. 1054, reh'g denied 507 U.S. 967 (1993) (undercover agent's representation 
that he was in the cocaine business and that the initial S15,000 were the proceeds of a collection 
satisfied requirement for establishing basis for money laundering "sting" operations that 
government agent represent that property involved in the transaction was the "proceeds of 
specified unlawful activity, or property used to conduct or facilitate specified unlawful activity"). 
Thus, it is clear that the statute unquestionably and explicitly requires (a) the use of 
proceeds of specified unlawful activity, or (b) cash which is or was represented to be the product 
of unlawful activity, with neither paradigm being applicable in the case. That this was how the 
statute was intended to be used and is understood is further evidenced by section 9-105 of the 
United States Attorney's Manual, which states: 
Sections 1956 and 1957 both require that the property involved in 
the money laundering transaction be the proceeds of specified 
unlawful activity at the time that the transaction reins. The statute 
does not define when property becomes "proceeds," but the context 
implies that the property will have been derived from an already 
completed offense, or a completed phase of an ongoing offense, 
before it is laundered. Therefore, as a general rule, neither § 1956 
nor § 1957 should be used where the same financial transaction 
represents both the money laundering offense and a part of the 
specified unlawful activity generating the proceeds being 
Laundered 
The allegations of this case simply do not support a money laundering charge. My 
attempt to make such a charge would constitute inappropriate overreaching and would stretch the 
statute beyond its intended purpose. Unlike the typical money laundering case, Mr. Epstein did 
not receive money or funds from any criminal conduct which he then used in a financial 
transaction. See, e.g., United States v. Taylor, 239 F. 3d 994 (9th Cir. 2001) (defendant charged 
with running an illegal escort service and using proceeds from that business to pay credit cards 
Instructive is Eleventh Circuit Pattern Jury Instruction 70A which states that the defendant can be found guilty of § 
I 956(aX3XA) only if (1) he knowingly conducted a financial transaction; (2) the transaction involved property 
represented to be the proceeds of specified unlawfill activity or that was used to conduct or facilitate specified 
unlawful activity; and (3) the defendant engaged in the uarsaction with the intent to promote the carrying on of 
specified unlawful activity. 
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00094215
EFTA01247991

LAW Or r las coy 
Guitar, a Lzroocarr, P.G. 
Office of the United States Attomcy 
Southern District of Florida 
June 25, 2007 
Page 5 
used to purchase airline tickets to fly prostitutes to Las Vegas). Nor did Mr. Epstein use money 
he knew otherwise to be unlawfully tainted in a financial transaction designed to facilitate, 
conduct, or promote prostitution or other criminal conduct. Rather, to the extent the evidence 
may show that Mr. Epstein paid for sexual services, he most certainly did so with untainted, 
legitimately earned funds. 
In addition, unlike the typical "sting" case, which 1956(a)(3) was enacted to address, 
there is no evidence that Mr. Epstein was aware, or that government or law enforcement 
personnel made him aware of circumstances from which he could reasonably have inferred that 
the funds were from specified unlawful activity. This is not a case where large amounts of cash 
of questionable origin were repeatedly delivered to Mr. Epstein in small denominations in duffel 
bags and boxes. See. e.g., Puche, supra, 350 F. 3d 1137; see also United States v. Rahseparian, 
231 F. 3d 1257 (10th Cir. 2000) (government failed to prove that defendant knew that money 
was obtained by mail fraud, the unlawful activity underlying money laundering count). 
To proceed under a view that the statute covers such behavior would lead to the 
unintended result of making use of a credit card or wire transfer to pay for sexual services 
provided by a prostitute money laundering. That was surely not what Congress intended, how 
the courts have interpreted the language of the statute, or even how it is viewed by the 
Department of Justice. 
18 U.S.C. § 1960 - Prohibition of Unlicensed Money Transmitting Business Does Not 
Apply to Mr. Epstein's Alleged Misconduct 
Likewise, a prosecution under § 1960 cannot lie. 
18 
§ 1960 is a regulatory statute that was enacted in order to combat the growing 
use of money transmitting businesses for the purpose of transferring large sums of illegally 
obtained monies and to avoid the strictures of the Internal Revenue Code, as well to fund 
terrorism. The type of business contemplated by Congress is one which, for a fee, accepts funds 
for transfer within or outside the United States. See United States v. Talebnejad 460 F.3d 563, 
565 (4°' Cir. 2006); United States v. Valastegut, 199 F.3d 590 (2d Cir. 1999). Once the money 
transmitter receives the fee and the money from the customer, a third party at the recipient 
location then pays the money to the designee or the transmitter wires the money directly to the 
recipient 
These formal and informal businesses are often operated for the purpose of sending 
money to an individual's home country from the United States. See, e.g., Talebnejad, supra, 460 
Cue M, 03407)44W.MARRA 
1, 0:451 I 
350 I. 182-094 
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EFTA 0(1(194219 
EFTA01247992

IA* °malt oe 
GERALD a Lzroornrr, P.G. 
Uthce of the United
es Attorney 
Southern District of Florida 
June 25, 2007 
Page 6 
F.3d at 567 (Iranian immigrants operated money transmitting business in Maryland); Velastegui, 
199 F.3d at 593 (money transferred to Mexico by unlicensed agent); United States v. Balt, 2007 
U.S. Dist. LEXIS 25274 (S.D.N.Y. 2007) (defendant operated restaurant in New York which also 
transmitted cash overseas); United States v. Abdullah, 2006IJ.S. Dist. LEXIS 47493 (W.D.Va. 
2006) (Iraqi defendant charged customers a fee for transferring money from the United States to 
Middle Eastern countries). However, as noted, in many instances, due to the lack of uniform 
regulation, these businesses have served to transfer funds which were the proceeds of illegal 
activity. See United States v. Valdes, 2006 U.S. Dist. LEXIS 12432 (S.D.N.Y. 2006) (defendants 
transmitted proceeds of drug trafficking to Colombia); see also P.L 103-325, Title IV, § 408, 
108 Stat. 2252. In response to the growing concern about this improper use of these businesses, 
Congress enacted § 1960, in conjunction with § 5330, establishing a regulatory scheme to assist 
in the effective enforcement of criminal, tax, and other laws and prevent such businesses from 
participating in any illegal enterprises. Id. 
It is clear that § 1960 does not apply, and was never intended to apply, to Mr. Epstein's 
purported misconduct. Mr. Epstein did not own or operate a "money transmitting business" as 
defined in § 5330. Nor was he in the money transmitting business. Mr. Epstein was not 
providing check cashing, currency exchange, or money transmitting or remittance services. Nor 
was he issuing or redeeming money orders, travelers chocks, or other similar instruments, or 
acting as a person engaged as a business in the transmission of funds. 
Indeed, he was not carrying on a business at all through these transfers. The term 
"business" is defined as an "activity or enterprise for gain, benefit, advantage or livelihood" 
(Black's Law Dictionary (7th S. 2007)) or as "a usually commercial or mercantile activity 
engaged in as a means of livelihood". Merriam-Webster's Online Dictionary. The only funds 
transferred were Mr. Epstein's personal monies, monies he lawfully earned. He did not profit 
from the transmission of this money. Nor was the act of transmitting the money a means of his 
livelihood. He simply took legitimate money and used it to meet his financial obligations. 
At best, the evidence demonstrates that Mr. Epstein transmitted funds from personal 
accounts in New York to accounts in Florida in order to pay for personal expenses — food, 
flowers, household upkeep, etc. This cannot be viewed as anything different from giving cash to 
a family member, or transferring money fiom a savings or brokerage account to a checking 
account, in order to pay bills and expenses. Under no reading of the facts can Mr. Epstein's 
conduct in transferring money between his accounts constitute a "business", much less a money 
transmitting business. As such, a prosecution under the statute should not lie. 
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LMV Of • MCI. Of 
GERALD B. LEPOOURT, P.C. 
Office of the United States Attorney 
Southern District of Florida 
June 25, 2007 
Page 7
18 U.S.C. § 1591 — The Misconduct Alleged Does Not Fall Within the Ambit 
of the Statute 
18 U.S.C. § 1591 - "Sex Trafficking of Children or by Force, Fraud, or Coercion" — was 
passed as part of the Trafficking Victims Protection Act ("TVPA") to address a problem far 
removed from the present set of circumstances: human trafficking, in general, and human sex 
trafficking, in particular, involving both a commercial and coercive component. The statutory 
scheme was designed to prevent the organized exploitation of women and children for profit and 
was not intended to address the conduct alleged here: 
The central principle behind the Trafficking Victims Protection Act 
is that criminals who knowingly operate enterprises that profit 
from sex acts involving persons who have been brought across 
international boundaries for such purposes by force or fraud, or 
who force human beings into slavery, should receive punishment 
commensurate with the penalties for kidnapping and forcible rape. 
147 Cong. Rec. E2179.02; see also United States Department of Justice Civil Rights Division 
Anti-Trafficking News Bulletin, April 2005, Vo. 2, No. 1 at ; July 2004, Vol. I, No 7. at 6; and 
January 2004, Vol. I, No. 1, at I, 3 (reflecting the positions of President Bush, Attorney General 
Gonzalez, former Attorney General Ashcroft, and former Assistant Attorney General for the 
Civil Rights Division Acosta that human trafficking involves force, fraud and coercion, and is a 
form of modern day slavery). The behavior and actions of Mr. Epstein are far removed from the 
human trafficking concerns addressed by Congress in enacting § 1591. Any attempt to prosecute 
him under this section would be unprecedented and highly irregular. 
Not surprisingly, the case law does not support any such prosecution. Nationwide there 
are relatively few appellate decisions dealing with prosecutions under § 1591. In the Eleventh 
Circuit, there are only a handful, several of which arc unpublished. A review of these cases 
reveals that the paradigmatic case for enforcement falls into one of two categories.6 The first 
involves defendants who have engaged in a highly predatory sort of business — prostituting 
underage persons, either by force, fraud, or coercion. These cases bear no relationship to the 
circumstance at issue here. See, e.g., United Slates v. Norris, 188 Fcd. Appx. 822 (I I a' Cir. 2006) 
(unpublished)(prosecution of several men for conspiracy to hold young women in peonage, and 
to traffic them for commercial sex acts, involving force and threats; bail issue); United Stores v. 
° A review of the United States Department of Justice Civil Rights Division Anti-Trafficking 'News Bulletins 
confirms that this same pattern exists nationwide. We will be prepared to discuss these cases further at our meeting 
and will supply deceits about the cases upon request 
Case No. 01140736-CV•MARRA 
P-008523 
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EFTA_0009422 I 
EFTA01247994

0, 
GERALD D. Lzercouter, P.C. 
Office of the United States Attorney 
Southern District of Florida 
June 25, 2007 
Page 8 
Sims, 161 Fed. Appx. 849, 2006 WL 14581 (1I th Cir. 2006) (unpublished). See also Evans, 
supra, 476 F.3d 1176. The second involves sex tourism sting operations where the defendants 
signal up for a "Taboo Vacation," usually to go to Costa Rica to have sex with children. in these 
cases the state interest is relatively minimal and United States treaty obligations have made 
federal intervention a high priority. See, e.g., United States v. Clarke, 159 Fed. Appx. 128, 2005 
WL 3438434 (11 a' Cir. 2005)(unpublished); United States v. &revel& 185 Fed. Appx. 841, 2005 
WL 1697529 (11th Cir. 2006Xunpublished), cert. denied, 127 U.S. 692 (2006). No such federal 
interest is implicated in the purely local case of Mr. Epstein. 
Here, there was no trafficking — no "force, fraud or coercion"; no threats; no sexual 
servitude; no financial venture; no profit from a financial venture; no forced work in the 
commercial sex industry; and no transporting of children from underdeveloped countries to the 
linked States or even across state lines. Nor was there any conduct which can be considered so 
extremely abusive or violent, that an expansion of the statutes beyond their intended purpose 
would be warranted. 
18 U.S.C. § 2421 — Mann Act — The Statute Was Not Intended To Address 
The Misconduct Alleged Here 
My attempt to charge Mr. Epstein under 18 U.S.C. § 2421 would violate both the spirit 
and purpose of the statute. Section 2421 was first enacted by Congress in 1910 to prevent the use 
of interstate commerce to facilitate prostitution, concubinage, or other forms of inunorality. 
Hoke v. United States, 227 U.S. 308 (1913); Wilson v. United States, 232 U.S. 563 (1914); 
Caminetti v. United States, 242 U.S. 470 (1917). The statute's primary purpose was to address 
the so-called commercial case of transporting females for immoral purposes. Cleveland v. 
United States, 329 U.S. 14 (1946) (even though the Act includes some non-commercial cases 
within its scope, its primary focus is commercial sexual activity); United States v Jamerson, 60 P 
Supp 281 (D.C. Iowa 1944). However, it has also served to protect women against conduct, 
whether commercial or not, that involves transportation and is exploitive or violent. See. e.g., De 
Vault v. United States, 338 F.2d 179, 180 (10th Cir. 1964) (applying the Act to protect girl who 
was raped). 
The Mann Act is a relatively antiquated morality statute that, despite its overly broad 
language, is wisely used only sparingly. Notably, the most recent reported decision in the 1 Ith
Circuit involving the Mann Act was decided in 1984. United States v. Phelps, 733 F.2d 1464 
(I 
Cir. 1984). 
Case No. 08-807364:V-MARRA 
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LAW OPIUM, Or 
GERALD B. lawcotra-r, PL. 
Office of the United States Attorney 
Southern District of Florida 
June 25, 2007 
Page 9 
Indeed, a nationwide search of reported prosecutions and convictions under the Act 
reveals that the statute has primarily been limited to cases involving prostitution rings/businesses 
and their owners. United States v. Holland 381 F.3d 80 (2d Cu. 2004) (woman running 
prostitution business convicted for recruiting and transport of prostitutes under § 2421); United 
States v. Footman, 215 F.3d 145 (Ig Cir. 2000) (pimp who ran a prostitution ring convicted of 
violating § 2421). Likewise, in keeping with its purpose and tide, the statute has been used in 
sex trafficking cases involving the exploitation of the poor and disadvantaged from foreign 
countries. See, e.g., United States v. Julian, 427 F.3d 471 (71" Cir. 2005) (sex tourism operator in 
Mexico facilitating travel of poor Mexican boy for sexual relationship in the United States 
violated § 2421). On the other hand, other cases which have targeted non-owners of prostitution 
rings, have anther limited § 2421 prosecutions to circumstances involving egregious conduct, 
such as the use of force or kidnapping. See, e.g, United States v. Lowe, 145 F.3d 45 (1g Cir. 
1998) (defendant transported woman across state lines against ha will and then raped her). See 
also Poindexter v United States, 139 F.2d 158 (8th Cir. 1943) (transportation by defendant of 
woman across state line with purpose of raping her violated 18 U.S.C. § 2421 since statute 
covers interstate transportation of woman without pecuniary motive where intent is to have illicit 
relations with her by force or otherwise); Brown v United States, 237 F.2d 281 (8m Cir. 1956) 
(the defendant violated the Act when he tricked woman into his car and drove her across state 
lines where he threatened, choked, struck and raped her, and then drove her back to the bus depot 
where he had picked her up). As we have previously pointed out, the allegations being levied 
against Mr. Epstein involve no such misconduct. 
We have found no reported decision in the past 20 years in which an individual was 
prosecuted under the Mann Act for simply traveling across state lines with a woman whom he 
paid for sexual services — even assuming the evidence shows this to be the case here. To use the 
Act to prosecute Mr. Epstein, where he was neither the owner nor operator of a prostitution ring, 
and where there are no allegations of kidnapping, force, or violence, would be unprecedented and 
would stretch the statute beyond what all understand is its modern day intended purpose. 
18 U.S.C. § 2422(b) — The Misconduct Alleged Does Not Fall Within 
the Ambit of the Statute 
In enacting the interne trolling statute, 18 U.S.C. § 2422(b), Congressional concerns 
were focused on a very specific and recent phenomenon: young people using the Internet in 
ever-increasing numbers, and attracting sexual predators out of the woodwork. Disturbingly, 
computers and the intemet made it frighteningly easy for sexual predators to enter into the homes 
of families, undetected by parents, and prey on these children in cyberspace. As Congress 
recognized, with so many children online, the intemet provided predators a new place - 
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LAW OFFICES OF 
GERALD H. Learocitarr, P.G 
Office of the United States Attorney 
Southern District of Florida 
June 25, 2007 
Page 10 
cyberspace - to target children for criminal acts. Congress enacted the internet trolling statute to 
combat the alarming increase in Internet predators, who were able to maintain their anonymity, 
while making unwanted sexual solicitations of vulnerable youngsters. 
The statutory language and reported decisions confirm the statute's important, but 
narrow, focus. Section 2422(b) does not establish any federal sex crimes with a minor, which 
remain a matter of state, not federal, concern. Instead, as the reported cases reveal, it defines a 
crime of communication, not of sexual contact. Indeed, what all of the cases have in common is 
that the defendant used the internet to communicate with a child or purported child (or a person 
with influence over such a child or purported child), and with the intent to arrange a sexual tryst 
with the child, with both the belief that the person was a child and with full knowledge that 
sexual activity with an individual of that age was illegal - precisely the situation the statute was 
designed to reach. 
Mr. Epstein's case lies far outside those parameters, and far outside the language and 
intended reach of the statute. In Mr. Epstein's case, even if there were inappropriate sexual 
contact with one or more 16 or 17 year olds, there was no use of the Internet to lure young 
victims, and no danger presented by Internet predation. 
18 U.S.C. § 2423(b) — No Travel For The Purpose of Engaging In Illicit 
Sexual Conduct, As Required By The Statute 
The linchpin of a prosecution under § 2423(b) is "travel for the purpose of engaging in .. 
. illicit sexual conduct". The evidence overwhelmingly demonstrates that no case can be made 
that Mr. Epstein ever traveled to Florida in order to engage in illicit sexual conduct. 
Elimination of the "purpose" requirement of the statute would undermine congressional 
intent, as recently expressed and re-affirmed in the Trafficking Act of 2002 and PROTECT Act 
of 2003.' Unlike subsections (a) and (b), § 2423(c), makes it unlawful to travel in foreign 
commerce and engage in illicit sexual conduct, without any proof of intent or purpose. It was 
enacted in response to the extraordinary difficulties the Department of Justice had faced in 
proving a defendant's intent or purpose in traveling when prosecuting foreign travel cases. 
Significantly, Congress did not amend § 2423(b), which continues to require purpose where the 
travel is interstate. Thus, Congress recognized the state's primary interest in proscribing illicit 
sexual conduct occurring within the state, unless one traveled to the state for that purpose. 
' Prosecutorial Remedies and Other Tools to End the Exploitation of Children Today Act of 2003, Pub. L. No. 108-
21, 117 SW. 650 (2003). See generally United States v. Clark, 43> F.3 1100 (96 Cir. 2006). 
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IA. Orr all 
or 
GiestArn B. Lncotrn, P.G 
Office of the United States Attorney 
Southern District of Florida 
June 25, 2007 
Page 11 
Legislative intent, and concepts of federalism, would be undermined if interstate travel with only 
incidental sexual conduct were prosecuted. 
The nature and scope of Mr. Epstein's activities in Florida do not support the conclusion 
that any purported illicit sexual conduct was an "important" "purpose of the travel, a significant 
motivating factor", or in other words, more than merely incidental. See United States v. 
Horschauer, 2007 WL 979931 (1101 Cir. 2007) (unpublished). 
We understand from conversations with Ms. Yillafaila that she believes that Mr. Epstein 
was and is a resident of New York, and that all trips to other homes were trips "away from 
home," undertaken for a limited period and with a specific purpose. The evidence clearly does 
not support this view!' 
Mr. Epstein has owned a home in Florida since September, 1990 — longer than any other 
residence he has owned — when he purchased the property on El Brillo Way. He spent 
substantial amounts of money during the relevant period to improve and to maintain this home. 
In addition, his travel records demonstrate that during the relevant period Mr. Epstein both spent 
the majority of his weekends, and additional time in Florida. Although he left Florida for 
business and other projects, he consistently returned to Florida, weekend after weekend, year 
after year. Specifically, the flight logs establish that for the period 2003 - 2005 (through 
September) Y, there is no month when he did not spend at least one long weekend in Florida, 
including in the summer months, and that he spent well over half of all weekends in Florida.10
Upon returning to Florida, Mr. Epstein routinely visited with various family members and 
close friends, all of whom reside or have homes in Florida, saw his primary care physician for 
checkups and prescribed tests, and frequented movie theaters and comedy clubs. Notably, during 
the relevant period, Mr. Epstein's mother took seriously ill, was often hospitalized, and 
convalesced in Florida until she died in 2004. A principal reason for Mr. Epstein's travels to 
I Although the locus of one's residency for tax purposes is not conclusive on the question of where one in fact 
resides, on a number of occasions since 1995 the taxing authorities of New York State have determined that Mr. 
Epstein did not spend sufficient time in New York to be considered • resident of New York for tax purposes. Since 
1999, Mr. Epstein has qualified under the applicable test as a domiciliary of the United States Virgin Islands and 4 
therefore entitled to the tax advantages being a domiciliary there affords. 
Mr. Epstein stopped traveling to Florida beginning in October, 2005. 
1e In 2003, there were 31 multi-day trips to Florida, 29 of which were for multi-day weekends; in 2004,37 multi-day 
nips to Florida, 36 of which were muhi-day weekends; and in 2005 (nine months), 20 multi-day trips to Florida, 21 
of which were multi-day weekends. 
Case No. 0840736-CV-MARRA 
F-008527 
3501.182-094 
Page 11 of 19 
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4.4w Or Pia* or 
(.tL13 B. Ix:root:rut, P.G. 
Office of the United States Attorney 
Southern District of Florida 
June 25, 2007 
Page 12 
Florida during that time was to visit with and attend to his mother's needs, see to her funeral 
arrangements, and address matters relating to her estate. 
In recognition of the amount of time he spent in Florida, during the relevant period Mr. 
Epstein worked with several local real estate agents to purchase a larger home. For example, in 
2004, as publicly reported, he attempted to acquire the Gosman Estate, a unique property that 
was eventually auctioned by the Bankruptcy Court. 
Similarly, due to the extensive amount of time he spent in Florida and his desire to have 
his pilots close by and available should a flight out of Florida be required, the home base for Mr. 
Epstein's flight operations was Florida. Routine maintenance of the aircraft, periodic FAA 
inspections, and interior refittings were all carried out in Florida. Indeed, the regular crew 
members — the pilots and engineer — all resided in Florida, as did the majority of contract crew 
members who were hired from time to time. Both Hyperion Air Inc. (legal owner of Mr. 
Epstein's Gulfstream G-BB), and JEGE, Inc. (legal owner of Mr. Epstein's Boeing 727), rent 
office space and a storage facility in Florida for the purpose of housing airplane records, 
including flight logs and wiring drawings, and providing the crew with a local office. 
The amount of time Mr. Epstein spent at his home in Florida, and the extensive list of 
Florida-based activities clearly undermines the contention that Mr. Epstein is a New York 
resident and defeats the notion that his purpose in traveling to Florida was to engage in illicit 
sexual conduct. On the contrary, Mr. Epstein returned to Florida to engage in the routine 
activities of daily living. We do not believe that the government could overcome the many 
substantial hurdles to be encountered when attempting to prove that a specific trip to Florida was 
for the required statutory "purpose" of engaging in specific "illicit sexual conduct"." 
Improprieties Surrounding The Search Warrant 
We previously referred to the many irregularities, misrepresentations and omissions 
which tainted the state's case. These irregularities would have a significant impact on any 
federal prosecution. For example, early on in any prosecution, the legality of the initial search 
There are, of
 a number of other ways in which Mr. Epstein's conduct did not violate 4 2423(b). For 
instance, we anticipate that it will be difficult to show wider the fens that at the time he initiated his travel to Florida, 
he knew the woman from whom he would later receive a massage, if at all, WAS at the time under the age of 18, or 
that he would engage in "illicit sexual conduct as defined by that statute. Similarly, and again assuming that it could 
be shown that one of his purposes in traveling to Florida was to receive a manage, given that the activities during 
many of the manages varied, we do not believe it can be established that his purpose (or even one of his purposes) 
in traveling was to engage in l'a sex act", however that term is ultimately defined 
Cast No. 08410736-CV-MARRA 
Y-008528 
3501.182-094 
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LAW Off 00111,21,
GERALD B. Lure-our, P.G. 
Office of the United States Attorney 
Southern District of Florida 
June 25, 2007 
Page 13 
conducted pursuant to the state search warrant would need to be litigated. The warrant suffers 
from such substantial glaring, facial deficiencies that a motion to suppress would likely result in 
the suppression of all items seized during the search of 358 El Brills; as well as all evidence 
derived from the search, both physical and testimonial. 
In addition, the affidavit prepared by Det. Recarey in support of the search warrant is 
replete with material misstatements and omissions which, if not intentional, at a minimum, were 
made with reckless disregard for the truth. The principal misstatements and omissions all 
involve Det. Recarey's assertions of what the women interviewed said in their recorded sworn 
statements, statements taken by Det. Recarey himself and with which he was fully familiar. 
However, a comparison of the transcripts of those interviews with the information set forth in the 
affidavit reveals many instances in which Det. Recarey represented to the issuing judge that the 
women interviewed said things which they did not in fact say, or failed to reveal material 
information contained in those same statements that would have been important for the judicial 
officer to know in determining whether the warrant should issue at all and, if so, whether the 
seizure of the broad categories of items outlined in the warrant should be authorized. 
Additionally, the execution of the warrant resulted in the seizure of a number of items which 
clearly fell outside the scope of the warrant, thus, requiring suppression of these unlawfully 
seized items. 
The material misstatements and omissions fall into three categories: (I) the 
mischaracterization of the significance of surveillance/videotape equipment located in Mr. 
Epstein's home; (2) the rnischaracterization and misrepresentation of facts associated with the 
ages of the women and Mr. Epstcin's claimed knowledge of their ages; and (3) the 
mischaracterization and misrepresentation of facts concerning the conduct in which Mr. Epstein 
allegedly engaged with these women. We take each in turn. 
Misrepresentations Regarding The Surveillance Equipment 
In an attempt to justify a seizure of computers at Mr. Epstein's residence —despite the 
fact that there was no misconduct alleged in connection with the use of computers — Det. Recarey 
affirmed that he 
. recalled working a previous case within Epstein's residence on 
October 5, 2003, when Epstein reported a theft from within his 
house. A former, disgruntled houseman was suspected in stealing 
monies from the house. At that time, I observed several covert 
cameras which, would capture and record images of anyone within 
Case No. 08-80736-C V-SIARRA 
P-008529 
3501.182-094 
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EFTA_00094227 
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LSW Of FCC! Of 
GERALD B. Ln000nr, 
Uttice of e United States Attorney 
Southern District of Florida 
lune 25, 2007 
Page 14 
the residence. Epstein had purchased coven cameras which were 
built in wall clocks and table clocks 
These images were then 
downloaded onto proprietary spyware software for later viewing. 
(Affidavit at ID). 
The clear implication of Dec Reearey's statement is that images of the purported "victims" may 
have been captured on the cameras and downloaded to computers where they remained, and 
could be seized, pursuant to a warrant. 
De. Recarey, however, knew full well, but failed to inform the court, that the cameras 
were part of a security system installed with the assistance of the Palm Beach Police Department 
and were located in only two areas of the house - Mr. Epstein's office and the garage. Det. 
Recarey was also aware - but did not tell the court - that none of the women interviewed alleged 
that she visited, much less engaged in illicit conduct, with Mr. Epstein in either location. Finally, 
none of the witnesses ever claimed, even when asked, that Mr. Epstein videotaped her, or 
evidenced any knowledge whatsoever that he may have videotaped her visit. There can be no 
doubt that his misstatements and omissions were intentional and designed to establish probable 
cause that did not exist and to overcome staleness concerns. 
Misrepresentations Regarding The Age Of The Witnesses and Mr. 
Epstein's Knowledge 
Det. Recarey affirmed that Haley Robson claimed: 
[Mr. Epstein] told her the younger the better. (Affidavit at 4) 
And, that: 
Robson stated she once tried to bring a 23 year old female and 
Epstein stated that the female was too old. (Affidavit at 4) 
What Dd. Recarcy, no doubt intentionally, omitted was Robson'sfurther explanation, which 
rendered Mr. Epstein's comments innocuous: 
A: 
Let me put it this way, he - I tried to bring him a woman 
who was 23 and he didn't really like it. 
Q: 
Ile didn't go for it? 
A: 
It's not that he didn't go for it. It's just that he didn't care 
for it. And he likes the girls that are between the ores of 
18 and 20. (Robson Statement at 12) (emphasis added) 
Case No. 08-80736-CV-MARRA 
1)-008530 
3501.182-094 
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LAW OFIICIS or 
GICRALD B. Loran:an P.C. 
Office of the United States Attorney 
Southern District of Florida 
June 25, 2007 
Page 15 
I lad that critical information — information that turns allegedly illegal conduct into more innocent 
conduct — been included it would have seriously undermined the probable cause for the search 
warrant. 
Similarly, and equally problematic, Det. Recarey refused to include statements 
demonstrating that when asked by Mr. Epstein, the girls affirmatively misrepresented their ages 
as being 18, andlor Mr. Epstein was not aware of their true ages. (Gonzales Statement at 39, 
Robson Statement at 12, Pentek Statement at 5, Laduke Statement at 9). Indeed, although he 
noted that Gonzales had told Mr. Epstein she was 18, omitted from the affidavit why she lied: 
Haley said tell him you're 18 because if you're not, he won't let 
you in his house. So I said I was 18. As I was giving him a 
massage, he was like how old are you. And then l was 18. But 1 
kind of said it really fast because I didn't want to make it sound 
like I was lying or anything. (Gonzales Statement at 39). 
Misrepresentations Regarding The Conduct In Which Mr. Epstein Purportedly 
Engaged 
In the following statement Det. Recarey affirmatively misrepresented what Alexandra 
Hall stated: 
"Hall states Epstein would photograph them naked and having sex 
and proudly display the photographs within the home". (Affidavit 
at 9). 
Ms. Hall actually made the following statement: 
A: 
I was just like, it was me standing in front of a big white 
marble bathtub ... And it, it wasn't like I was you know 
spreading my legs or anything for the camera, I was like, I 
was standing up. I think I was standing up and I just like it, 
it was me kind of like looking over my shoulder kinda 
smiling, and that was that. (Hall Statement at 35). 
Det. Recarey further swore in his affidavit that Fayth Pentek 
Advised that sometime during the massage, Epstein grabbed her 
buttocks and pulled her close to him. (Affidavit at 6). 
Case No. 08.80736•CV•MARRA 
P-005531 
3501.182-094 
Page 15 of 19 
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EFTA 0(1(194229 
EFTA01248002

tart sena,* or 
GICRAT.D Fl Ix:mot:on, PG. 
Office of the United States Attorney 
Southern District of Florida 
June 25, 2007 
Page 16 
Fayth Pentek squarely denied being touched "inappropriately" or otherwise by Mr. Epstein: 
Q: 
Ile did not touch you inappropriately? 
A: 
No. (Pentek Statement at ll). 
These misrepresentations were compounded by Det. Recarey's failure to include accounts 
by the witnesses that Mr. Epstein did nor in fact engage in illicit conduct during their encounters. 
Specifically, Dct. Recarey did not inform the cowl that witnesses stated: (I) they were not asked 
to and did not touch Mr. Epstein's genitals, (Gonzales Statement at 43, Robson Statement at 12); 
(2) they did not have sex with Mr. Epstein, (Gonzales Statement at 43); (3) Mr. Epstein did not 
masturbate during the massage, (Pentek Statement at 11; Siciliano Statement at 13; and Laduke 
Statement at 7); and, (4) Mr. Epstein did not touch them inappropriately. (Pentek Statement at 
11; Siciliano Statement at 13, IS; Gonzales Statement at 42). 
After all the misstatements arc corrected, the omissions included, and the irrelevant facts 
omitted, what is left is an equivocal account of an encounter eight months prior to the warrant 
application and an equally unreliable account of an encounter which, even assuming arguendo it 
occurred, was more than eleven months old. Surely this evidence was too stale to support 
issuance of a search warrant, as it did not provide probable cause to believe that any items 
evidencing a violation of the subject statutes — let alone any items of the type described as "kept 
and used" in such violations — would still be on the premises at the time of the search. 
Unlawful Search Of The Second Residence 
The officers executing the search warrant exceeded the scope of the warrant when they 
entered and proceeded to search the second residence on Mr. Epstein's property. Even if those 
agents did not know in advance that the building was a second residence, which they did,12 that 
fact would have been immediately obvious to them upon entry. Notwithstanding such 
knowledge, they disregarded the terms of the warrant and proceeded to search the second 
residence. 
There was no probable cause for a search of that residence and thus, both the search and 
seizure of items found therein violated the Fourth Amendment. 
" A review of the videotape of the pre-search walk-thus of El Brills reveals that officers knew prior to searching the 
second residency and seizing items located therein, that this was the living quanta of someone other than Mr. 
Epstein. This is corroborated by the Palm Beach Police Report in which Officer Michael Dawson recounts "I 
assisted in the search of Banasiak's living quartets. Numerous cd's along with a message book was seized". Police 
Report at 46; see also Police Report at 45. 
Case No. 08.80736-CV-MA R RA 
P-008532 
3501.182-094 
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law tames 
or 
Comitax.n B. Leiromnrr, 
Office of the United States Attorney 
Southern District of Florida 
June 25, 2007 
Page 17 
However, even assuming the warrant could possibly be read to encompass the search of 
the second residence, the affidavit is completely devoid of probable cause to search it. "(W)hen 
law enforcement wishes to search two houses or two apartments, it must establish probable cause 
as to each". United States v. Cannon, 264 F.3d 875, 879 (9th Cir. 2001). 
There Was No Probable Cause To Seize Many Of The Items Listed In The Warrant 
In addition, there was no probable cause to search for videotapes since all the women 
who were asked whether the had been videotaped denied knowledge of any videotaping. These 
are crucial facts which Det. 
rmilted from his affidavit. Moreover, as noted, 
had actual knowledge from s 
prior investigation that that were a limited number oti videc 
cameras located in the house and they were focused only on Mr. Epstein's desk and the garage —
two locations where money was kept and where no one alleged any wrongdoing took place. 
Likewise, nothing in the affidavit could support a finding of probable cause to believe 
that computers or computer-related items were used in the commission of the alleged offenses. 
The seizure and subsequent search of the computers and computer-related items clearly violated 
the Fourth Amendment. See. e.g., United States v. Riccardi, 405 F.3d 852, 862-63 (10th Cir. 
2005) (warrant authorizing seizure of computer, all electronic and magnetic media stored therein, 
and a host of external storage devices without limitation unconstitutional as authorizing general 
search); United States v. Joe, 2007 WL 108465 at *7 (N.D.Cal. January 10, 2007) ("computers 
and related or similar devices, and information on hard or floppy drives, which may contain any 
documents and records ...." overbroad and ordering suppression); United States v. Slaty, 433 
F.Supp.2d 499, 500 (E.D.Pa. 2006) ("[a3ny records, documents, materials and files maintained on 
a computer" overbroad because it authorized agents to seize everything, even if unrelated to the 
offense under investigation and even if wholly personal); United States v. Clough, 246 F.Supp.2d 
84, 87-88 (D.Me. 2003)(warrant to search computers which contained no limitations on the 
search was unconstitutionally overbroad); United States v. liwuer, 13 F.Supp.2d 574, 584 (D.Vt. 
I 998)(section of warrant which authorized seizure of all computers, all computer storage devices, 
and all computer software systems was unconstitutionally overbroad). 
Finally, there was no probable cause to believe that "hair fiber, semen, or other bodily 
fluids" would likely to be at Mr. Epstein's residence some eight months or more after the alleged 
criminal violations. 
There are serious hurdles to a federal prosecution, including the way the federal 
investigation was initiated, namely by Palm Beach Police Detective Recarey. Although Det. 
questionable actions undermined the state proceeding, his work was provided to your 
Office "on a silver platter". Even though the FBI conducted its own investigation, that 
Case No. 08-80736CV•MARRA 
P-008533 
3501.182-094 
Page 17 of I9 
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EFTA_00094231 
EFTA01248004

LAW Offal 
Or 
GERALD D. Lataccoura, P.C. 
Office of the United States Attorney 
Southern District of Florida 
June 25, 2007 
Page 18 
investigation cannot avoid being tainted by Det.M 
actions. Many of die leads the FBI 
followed, the witnesses it interviewed, and the documents it subpoenaed all inexorably flowed 
directly from the fruits of Det. Ma 
investigation. 
Det 
credibility is interwoven in the federal investigation given the overlap of 
witnesses and documentary evidence with the antecedent state investigation. Not only would a 
federal prosecution implicate issues of the scope of taint of both physical evidence and witness 
testimony emanating from the 
eral prosecution would inexorably result in 
scrutiny of the extent to which 
rc-search investigation was adversely 
compromised by his zeal to prosecute Mr. Epstein. 
That 
desire to prosecute Mr. Epstein ran so deep is no more evident than 
through his participation in the unprecedented, selective, and prejudicial public release of 
materials such as the Palm Beach Police Reports and Probable Cause Affidavits. These 
documents, like the search warrant affidavit, were replete with material misstatements and 
omissions, one of the most glaring of which was the reference in the Police Reports to the 
discovery of a "sex toy" in Mr. Epstein's trash. Through the execution of the search warrant, it 
was discovered that the "sex toy" purportedly found in a trash pull was in fact only a piece of a 
broken salad fork. Despite this discovery, Del. Mil 
bent on painting the facts to support Mr. 
Epstein's prosecution, never took any steps to correct the Police Report and note the innocent 
nature of the item. 
Petite Policy 
We have previously submitted extensive materials regarding the role the Petite Policy 
should play in this matter. Rather than restate our position, we would like to discuss it in detail 
at the meeting. 
Conclusion 
This case started as and should end as a state matter. It involves local issues which are 
best addressed by state law. The statutes identified were never intended to be applied in 
circumstances such as these, where the federal interests intended to be redressed by the statues 
are not present. We hope that after a full and candid discussion with your office you too will sec 
the inadvisability of proceeding with a federal indictment. We are prepared to address any of the 
subjects touched on above and welcome any additional issues you wish to raise. We are also 
prepared to make a fuller written or oral presentation on all the issues we have raised herein or 
any other lingering concerns you have. 
Case No. 0840736-CV-MARRA 
P-008534 
3501.182-094 
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Loa. C!/,C[• Or 
GERALD B. Lszoozarr, 
Office of the United States Attorney 
Southern District of Florida 
June 25, 2007 
Page 19 
Thank you for your cooperation in this matter. We look forward to meeting on June 26, 
2007. If you have any questions, please do not hesitate to call. 
cc: 
Lilly Ann Sanchez Esq. 
Roy Black, Esq. 
Alan Dershowitz, Esq. 
Case No. 0.3430736-CV-MARRA 
IL.008535 
3501.182-094 
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EFTA_00094233 
EFTA01248006