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This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →

FBI VOL00009

EFTA00185206

310 pages
Pages 121–140 / 310
Page 121 / 310
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 South Australian Ave., Suite 400 
West Palm Beach, FL 33401 
Facsimile: 
January 24, 2007 
DELIVERY BY HAND 
James L. Eisenberg, Esq. 
250 S Australian Ave, Ste 704 
West Palm Beach, FL 33401-5007 
Re: 
Federal Grand Jury Subpoena 
Dear Jim: 
A new grand jury has been 
aneled and I have enclosed a new subpoena for 
. As I mentioned earlier, Ms. 
is not a target of this investigation and the United 
States seeks her testimony solely as, a victim/witness. During our last conversation regarding 
Ms. 
, you indicated that she was unwilling to speak with us pursuant to a Kastigar 
letter and that she also was unwilling to speak with.the grand jury and intends to invoke the 
Fifth Amendment if questioned. Please confer with her to confirm whether this remains her 
position. If it is, please advise in writing. Even if Ms. 
is inclined to invoke her Fifth 
Amendment rights, she must still appear pursuant to the subpoena so that I may ask her 
questions that would not require the invocation of the Fifth Amendment. If she still invokes, 
I intend to move to compel her answers. If you or your client is unavailable on February 6, 
2007, please let me know of another Tuesday when you are available. 
I also am concerned about a potential conflict of interest in your representation of Ms. 
M . In case of future litigation regarding this issue, please provide me with information 
regarding who is paying (directly or indirectly) for your services on behalf of Ms. M, 
the 
scope of your representation and whether you are taking .direction on this matter from 
anyone other than Ms. 
If any formal or informal joint defense agreements exist, 
whether in writing or otherwise, please provide a copy of such agreements. If the agreement 
is purely oral, please provide a written summary of its terms. 
I! 
GOVERNMENT 
EXHIBIT 
1 
EFTA00185326
Page 122 / 310
JAMES EISENBERG, ESQ. 
• JANUARY 24, 2007 
PAGE 2 
I look forward to your response. 
Sincerely, 
R. Alexander Acosta 
By: 
Assistant United States Attorney 
EFTA00185327
Page 123 / 310
United States District Court 
SOUTHERN DISTRICT OF FLORIDA 
TO: 
SUBPOENA TO TESTIFY 
SUBPOENA FOR: 
PERSON 
X 
DOCUMENTS OR OBJECT[SJ 
YOU ARE HEREBY COMMANDED to appear and testify before theMofthe 
United States DiStrict 
Court at the place, date'and time Specified below. 
PLACE: 
United States District Courthouse 
701 Clematis Street 
West Palm Beach, Florida 33401 
ROOM: 
DATE AND TIME:. 
February 6, 2007 
1:00pm* 
YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s): 
ANY AND ALL NOTES, LE 
HS YOU HAVE RECEIVED 
FROM JEFFREY EPSTEIN, 
• 
PRINTED OR DIGITAL, OF JEFFREY EPSTEIN, 
ANY AND ALL 13-MAILS, INSTANT MESSAGES, CHATS, TEXT MESSAGES, VOICEMAILS; OR TELEPHONE 
MESSAGES THAT YOU HAVE SENT TO AND/OR RECEIVED FROM JEFFREY EPSTEIN, 
*Please coordinate your compliance with this subpoena and confirm the date and time , and location of 
our appearance with Special Agent 
Federal Bureau of Investigation, Telephone: 
This su
bpoena 
shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf 
of the court. 
This subpoena is issued upon application 
of the United States of 
'Ca 
Name Address and Phone Ndmber of Assistant U.S. Attorney 
Assistant U.S. Attorney 
500 So. Australian Avenue, Suite 400 
West Palm Beach FL 33401-6235 
x3047 
Fax: 
*If not applicable, enter "none" 
To be wed la Neu arAO110 
FORM ORD-2/7 
JAN.86 
EFTA00185328
Page 124 / 310
EISENBERG & FOUTS, P.A. 
Attorneys At Law 
JAMES L. EISENBERG 
Florida Bar Board Certified Criminal Trial Lawyer 
National Board Of Trial Advocacy Certified Criminal Trial Advocate 
KAI LI ALOE FOUTS 
One Marini°, Centre, Suite 704, 250 Australian Avenue South, West Palm Beach, 171,33401 
Fax: 
February 1, 2007 
Asst. U.S. Attorney 
500 South Australian Avenue, Suite 400 
West Palm Beach, FL 33401 
Re: 
Grand Jury Subpoena for 
Dear M, 
I received your letter dated January 24, 2007 with regard to 
. I must admit I forced 
myself to wait several days to respond inmtder to "cool. off' and not say anything I would regret 
later. 116W thatiime has passed; allow ma to respond appropriately. 
. 
• . . • 
d. 
1. • If you want to force Ms.• M, 
a single mother, to come to the grand jury room to 
personally invoke her Fifth Amendment rights, she will be there: That does remain her position. 
My only request is that syr it.rovide a babysitter service for her child. I will be there, but I am not 
paid to babysit and Ms. 
should not have to
 someone. It is this type of attitude, that your 
office refuses to accept the fact that it is Ms. 
decision not to cooperate with the government 
that upsets her. Your office fails to recognize that merely coming to court is a problem for a single 
mother like Ms. 
and, under these circumstances, appears to be a waste of time at best and, in 
her mind, personal harassment. 
2. Rest assured that there is no conflict of interest in my representation of Ms. 
. In this 
case I have always been asked and always will exercise independent judgment to follow my client's 
independent will. The remainder of your questions as to this matter are really none of the 
Government's business. 
3. I will share with you that one of the reasons for our firm position that Ms. 
will 
invoke her Fifth Amendment right and choose not to voluntarily cooperate with the Government is 
our concern that the Government is not exercising independent judgment in this case. 
The hiStory of this case his been in the:newspapers., The case is being prosecuted in State court. 
Despite the state emit pinsecution; the Town of Palm Beach Police Chief went on what can only be 
• 
r 
GOVERNMENT 
EXHIBIT 
1  2
EFTA00185329
Page 125 / 310
EMI
, Asst. U.S. Attorney 
February 1, 2007 
Page Two 
described as a public rampage in the newspaper when the case was not prosecuted to his liking that 
reminded me of a small child having a public temper tantrum. In my thirty years of experience, I 
have never seen a law enforcement officer like this publicly make what appeared to be a political 
case in the newspaper for a prosecution and publicly criticize anyone who got in his way, including 
the elected State Attorney. This resulted in a federal investigation on a topic no one remembers the 
Federal Government ever being interested in prosecuting before. Although I am certain that you 
personally have not had your decision-making process compromised, the appearance that your office 
is being influenced by the Town of Palm Beach Police Chief's agenda is very real. Under these 
drcumstance4 don't see how any lawyer; could advise• any client to voluntarily cooperate. Of 
special contact is that the Town of Palm Beach Police have promoted prosecuting at least one of the 
girls who allegedly gave massages. 
One final thought. My client and my fear that Ms. 
could be prosecuted is enhanced by the 
demand for the personal appearance made in your letter. Your initial Kastiger letter fell far short 
of granting the functional equivalent of DOJ immunity. Several months ago I was given the distinct 
impression through our conversations that you were going to obtain DOS immunity for Ms. 
Now the government is changing course for no apparent reason. This leads to speculation that the 
only reason for the turnabout is that prosecution in either state or federal court is being considered 
by someone. 
None of the above directed at you personally. I want to repeat that you have always treated us with 
respect. jvlaybe 
ur, office should advise the Town Police Chief to act in a similar fashion. 
EFTA00185330
Page 126 / 310
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
A. 
500 South Australian Ave, Suite 400 
West Palm Beach, Florida 33401 
Facsimile 
FACSIMILE COVER SHEET 
TO: 
JIM EISENBERG, ESQ. 
 DATE: 
# OF PAGES: 
PHONE NO.  
 RE: 
FAX NO. 
February 5, 2007 
FROM: 
PHONE NO. 
ASSISTANT U.S. ATTORNEY 
COMMENTS : 141 Jilt) 
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GOVERNMENT 
EXHIBIT 
EFTA00185331
Page 127 / 310
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
DELIVERY BY HAND 
Ms. 
do James L. Eisenberg, Esq. 
250 S Australian Ave, Ste 704 
West Palm Beach, FL 33401-5007 
Re: 
Grand Jury Testimony of 
Dear Ms. 
500 South Australian Ave., Suite 400 
West Palm Beach, FL 33401 
Facsimile: 
February 5, 2007 
This letter confirms the understanding between yourself and the United States Attorneys 
Office for the Southern District of Florida. 
You have represented that you will truthfully answer questions of the federal government in 
its investigation of the procurement of prostitutes, amongst others. You will supply complete and 
truthful information to the attorneys and law enforcement officers of the federal government and to 
any Federal Grand Jury which may conduct an investigation, as well as in any other proceeding 
related to or growing out of this investigation. The obligation of truthful disclosure includes your 
obligation to provide the attorneys and law enforcement officers of the federal government with any 
documents, records or other tangible evidence within your custody or control relating to the matters 
about which you are questioned. You will neither attempt to protect any person or entity through 
false information or omission, nor falsely implicate any person or enfity. 
No statements provided by you on this date in this matter pursuant to this agreement will be 
offered into evidence in any criminal case against you, except during a prosecution for perjury and/or 
diving a false statement. Hoirever, if it is determined that you have materially violated any provision 
of this agreement, all statements made by you shall be admissible in evidence against you in any 
proceeding. 
The federal government remains free to use information derived from the grand jury 
testimony directly or indirectly for the purpose of obtaining leads to other evidence, which may be 
used against you. You expressly waive any right to claim that such evidence should not be 
introduced because it was obtained as a result of the grand jury testimony. Furthermore, the federal 
government may use statements made in the grand jury testimony and all evidence derived directly 
or indirectly therefrom for the purpose of cross-examination, if you testify at any trial or if you 
EFTA00185332
Page 128 / 310
MS. 
FEBRUARY 5, 2007 
PAGE 2 
suborn testimony that contradicts your prior statements and testimony. 
No additional promises, agreements and conditions have been entered into other than those 
set forth in this letter and none will be entered into unless in writing and signed by all parties. 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
BY
Assistant United States Attorney 
I have read this agreement and discussed it with my attorney, and I hereby acknowledge that it 
fully sets forth my agreement with the office of the United States Attorney for the Southern District of 
Florida. I state that there have been no additional promises, agreements or representations made to me 
by any officials of the United States in connection with this matter. 
Dated: February 
2007 
West Palm Beach, Florida 
Witnessed by: 
James L. Ms,. 
Attorney for 
EFTA00185333
Page 129 / 310
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 South Australian Ave., Suite 400 
West Palm Beach, FL 33401 
Facsimile: 
February 5, 2007 
DELIVERY BY HAND 
James L. Eisenberg, Esq. 
250 S Australian Ave, Ste 704 
West Palm Beach, FL 33401-5007 
Re: 
n 
Dear Mr. Eisenberg: 
I am writing to clarify the ground rules for the interview with your client 
("your client"), to occur February 
, 2007. 
As I mentioned earlier, Ms. 
is not a target or subject of this investigation, but 
instead is being interviewed solely as a victim/witness. However, to address your concern 
about criminal exposure, if your client complies with every provision of this agreement, then 
the United States Attorney's Office for the Southern District of Florida ("this Office") will 
treat all statements made by your client during the interview as statements made pursuant to 
Rule 11(f) of the Federal Rules of Criminal Procedure. This is not a grant of immunity, 
which can be given only with approval of the Justice Department, but protects your client 
from having the statements made by her during the interview from being used against her 
directly. To guard against any misunderstandings concerning the interview of your client, 
this letter sets forth the terms of this agreement. 
Your client agrees to be fully interviewed, that is, to provide information concerning 
your client's laniviledge of, and participation in criminal activity, including but not limited 
to the procurement of prostitutes. The protection of this letter applies to an interview that 
will be conducted by this Office, Special Agents of the Federal Bureau of Investigation, and 
any other federal law enforcement agency this Office may require. Under this agreement, 
no information disclosed by your client during the interview will be offered in evidence 
against her in any criminal or civil proceeding, provided that your client complies with this 
agreement and that the information your client furnishes is truthful, complete, and accurate. 
If, however, your client gives materially false, incomplete, or misleading information, 
EFTA00185334
Page 130 / 310
JAMES L. EisENBERo, ESQ. 
RE: 
FEBRUARY 2, 2007 
PAGE 2 
then this Office may use such information in any matter or proceeding and your client is 
subject to prosecution for perjury, obstruction of justice, and making false statements to 
government agencies. Any such prosecution may be based upon information provided by 
your client during the course of the interview, and such information, including your client's 
statements, will be admissible against your client in any grand jury or other proceeding. 
The government also may use statements made by your client in the interview and all 
evidence derived directly or indirectly therefrom for the purpose of impeachment or 
cross-examination if she testifies at any trial or hearing, and/or in any rebuttal case against 
your client in a criminal trial in which she is a defendant or a witness. These provisions are 
necessary to ensure that your client does not make or offer any false representation or 
statement in any proceeding or to a government agency or commit perjury during any 
testimony. 
Your client further agrees that attorneys for the United States may be present at the 
interview, and agrees not to seek disqualification of any such government attorney from any 
proceeding or trial because of their participation at the interview. 
The entire agreement between the United States and your client is set forth in this 
letter. No additional promises, agreements, or conditions have been entered into and none 
will be entered into unless in writing and signed by all parties. 
If the foregoing accurately reflects the understanding and agreement between this 
Office and your client, it is requested that you and your client execute this letter as provided 
below. 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
By: 
Assistant United States Attorney 
I have received this letter from my attorney, James L. Eisenberg, Esquire, have read 
it and discussed it with my attorney, and I hereby acknowledge that it fully sets forth my 
understanding and agreement with the Office of the United States Attorney for the Southern 
EFTA00185335
Page 131 / 310
JAMES L. EISENBERG, ESQ. 
EB: 
FEBRUARY 2, 2007 
PAGE 3 
District of Florida. I state that there have been no additional promises or representations 
made to me by any official of the United States Government or by my attorney in connection 
with this matter. 
Dated: 
Witnessed by: 
James L. Eisenberg, Esquire 
EFTA00185336
Page 132 / 310
U.S. Department of Justice 
Authorization for Reimbursement 
of Unusual Expenses of Fact. Witnesses 
Request for Unusual Expense(s) of Fact Witness 
(For United States Attorney's Office Use Only) 
Control # 
1. Case Name 
tiDia 
2. Court Docket Number 
3 
i 
A 
-4. L 
Wesi-
ation of Court Floc ding 
PoIni 
5. Contact Person 
6. Contact Person Number 
7. Witness Name & Address, Phone #, SSN 
8. Vendor Name & Address, Phone #, TIN/SSN 
9. Pa ment to be made to: 
10. Receipt/Invoice Is: 
11. Type of Unusual Expense: 
Medically Necessary Item 
(Attached Supporting Statement) 
laDependent Care 
Excess Lodging/Per Diem 
Travel & Transportation 
Pretrial Conference Waiver 
Other 
12. Explanation: 
VAL (A)190,44 h
t4 a 
n
 0.014 
hitt 
"II) OYU. (AA 
CC 
CA:tia 
Go/AA,t.e. ski. 
tecithicoLetel- 
tfta k
i l fhe 
40Mtd- • 
13. Start Date of Service (MO/DANR) 
ZIG /0 7 
14. End Date of Service (MO/DANR) 
2-/‘ 
A) 7 
15. Amount 
16. Justification: 
17. I hereby certify that the expenses and services listed on this document are appropriate and are within the Federal laws 
and regulations. I fully understand that I can be held personally liable or be subject to disciplinary action for improperly using 
government funds or services that exceed delegated authority or that violate Federal laws or regulations. 
Signature of Requesting AUSA 
Date 
18. Name & Title of Approving Official 19. Date (MO/DA/YR) 
20. Signature of Approving Official 
GOVERNMENT 
EXHIBIT 
EFTA00185337
Page 133 / 310
EISENBERG & FOUTS, P.A. 
Attorneys At Law 
JAMES L. EISENBERG 
Florida Bar Board Certified Criminal Trial Lawyer 
National Board Of Trial Advocacy Certified Criminal Trial Advocate 
KM LI ALOE POUTS 
One Cleariake Centre,Suite 704,250 Australian Avenue Soutb,WestPalm Beach,FL33401 
February 12, 2007 
Asst. U.S. Attorney 
500 South Australian Avenue, Suite 400 
West Palm Beach, FL 33401 
Re: 
Grand Jury Subpoena for 
Dear MO 
AsakvayS, it was;a pleasure speaking to you the other day. Pursuant to. our telephone conference 
I am writing this letter to.proffer my:concerns for 
should she testify without immunity 
before a federal grandjurt.:Tberefore, allowme to reiterate at Ms.:Ivallerwill refuse to voluntarily 
cooperate with the federal government She has a good faith basis for her position under the Fifth 
Amendment to the United States. Constitution. 
We, of course, do not live or work in a vacuum. We have read many inflammatory remarks the 
Town of Palm Beach Police Chief has made to the media about the state court's handling of the 
Jeffrey Epstein investigation. The police chiefs remarks frighten both myself and my client. I am 
aware that the town police have prepared documents to charge at least one of Mr. Epstein's lady 
friends in state court. If they can push to have one lady charged I remain unconvinced that they do 
not have the ability or political clout to push to have other ladies such as Ms. 
charged. 
The proffered facts that raise my concerns are being provided via this proffer letter. Pursuant to our 
telephone conference agreement, this letter and its contents cannot be used against Mr. 
Ms. 
is not at all certain of dates. She does remember meeting Mr. Epstein about three years 
ago. She is not certain of her age, it could have been when she was sixteen. A girlfriend asked her 
if she wanted a job giving massages. Ms. 
agreed because she had knowledge of massages 
through her mother, who was a masseuse. 
Ms 
went tolvtrEpstein?s house via taxi. Ms. 
girlfiiendinstnieted Ms: 
that, 
if asked,. she had to tell Mr.Epstein that she 
- was eighteen. years old. The.II. was 
nineteen years old and 
looked old forher age, so passing for eighteen was not a problem. At 
[
! GOVERNMENT 
I 
EXHIBIT 
i  5
EFTA00185338
Page 134 / 310
the home Ms. net 
Mr. Epstein and later gave him a massage. The friend had told Ms. 
to give the message topless. Mr. Epstein told 
that if she were at all uncomfortable. 
topless, not to do it and it was not a requirement o employment as a masseuse. Ms. 
ever 
touched Mr. Epstein in a sexual way and Mr. Epstein never touched Ms. 
t all. 
one point, 
Mr. Epstein did ask Ms. =her 
age. Ms. =insisted that she was et teen years old. 
Ms. =continuqd to see Mr. Epstein over time and massages were given in a similar fashion. 
She was later asked if her friends wanted to work in a similar way and she asked some girls who did 
give Mr. Epstein massages. Ms. 
was never asked to bring girls of any age to Mr. Epstein's 
home. When she did have her friends ome over, she instructed all of them that if asked, they insist 
that they were eighteen years old. She is not certain at all of any of these girls' real ages. 
In summary, our concern is that if the government believes that Mr. Epstein committed some federal 
offense, Meals. =could he considered a co-conspirator. We believe no crime was committed. 
The Fifth Amendment was not intended to protect the guilty, however. It was enacted to protect 
citiwms who fear prosecution notwithstanding their innocence. Our fear of any prosecution, 
especially ' 
f the Town police chiefs public remarks, is clearly in good faith. 
EFTA00185339
Page 135 / 310
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
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0 
....-.1 
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Z., 
on-: 
:1•• 
Ci 
NORTHERN (WEST PALM BEACH) DIVISION 
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I 
FGJ 07-103(WPB) 
r-  • 
• 
CI 
I
• 
-O 
I 
IN RE: 
GRAND JURY PROCEEDINGS 
SEALED ORDER 
On Application of the United States Attorney for the Southern District of Florida, and it 
appearing to the satisfaction of the Court: 
1. 
That 
has been called to testify and to provide other information before 
the United States District Court for the Southern District of Florida, including a Grand Jury 
impanelled therein; and 
2. 
That in the judgment of the said United States Attorney, 
has refused 
to testify and provide other information on the basis of her privilege against self-incrimination; and 
3. 
That in the judgment of the said United States Attorney, the testimony and other 
information from 
may be necessary to the public interest; and 
4. 
That the aforesaid Application has been made with the approval of the Assistant 
Attorney General in charge of the Criminal Division of the Department of Justice or a duly 
designated Acting Assistant Attorney General, pursuant to the authority vested in him by Title 18, 
United States Code, Section 6003, and Title 28, Code of Federal Regulations, Sections 0.175 and 
0.132(e). 
NOW, THEREFORE, it is ordered pursuant to Title 18, United States Code, Section 6002, 
that 
give testimony and provide other information which she refuses to give or to 
GOVERNMENT 
EXHIBIT 
EFTA00185340
Page 136 / 310
provide on the basis of her privilege against self-incrimination, as to all matters about which she may 
be interrogated before said United States District Court, including a Grand Jury impaneled therein, 
as well as any subsequent proceeding or trial. 
However, no testimony or other information compelled under this Order (or any information 
directly or indirectly derived from such testimony or other information) may be used against 
in any criminal case, except a prosecution for perjury, giving a false statement, or otherwise 
failing to comply with this Order. 
IT IS FURTHER ORDERED the this Order shall be SEALED in accordance with Fed. 
R. Crim. P. 6(e)(6), except that a copy of this Order shall be provided to counsel for the United 
States, who may disclose the existence of the Order to members of the Grand Jury, to the witness, 
to counsel for the witness, and to law enforcement officers engaged in the investigation pending 
before the Grand Jury. Those persons may review the Order, but may not retain a copy of the Order, 
nor may they disclose the existence of the Order to any others. 
cc: 
DONE and ORDERED this 
AUSA 
day of April, 2007 
t Palm Beach, Florida. 
2 
DONALD M. MIDDLEBROOKS 
UNITED STATES DISTRICT JUDGE 
EFTA00185341
Page 137 / 310
United States District Court 
SOUTHERN DISTRICT OF FLORIDA 
TO: 
SUBPOENA TO TESTIFY 
BEFORE GRAND JURY 
FGJ 07-103(WPB)-Tues./No. OLY-13/2 
SUBPOENA FOR: 
PERSON 
et 
DOCUMENTS OR OBJECTS] 
YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District 
Court at the place, date'and time Specified below. 
'PLACE: 
United States District Courthouse 
701 Clematis Street 
West Palm Beach, Florida 33401 
ROOM: 
Grand Jury Room 
• 
DATE AND TIME:, 
February 6, 2007 
1:00pm" 
YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s): 
ANY AND ALL NOTES, L 
RS CARDS GIFTS PAYMENTS AND PHO 
RAPHS YOU HAVE RECEIVED 
FROM JEFFREY EPSTEIN, 
PRINTED OR DIOITAL, OF JEFFREY EPSTEIN, 
AND
• • ANY/a
ntRTHER
ANY AND ALL E-MA1LS, INSTANT MESSAGES, CHATS, TEXT MESSAGES, VOICEMAILS 
.EP 
MESSAGES THAT YOU HAVE SENT TO t hiliffa RECEIVED FROM JEFFRECY EPSTEIN, 
AND/OR 
• 
*Please coordinate your compliance with this sub oena and confirm the date and time , and location of 
our a 
earance with Special Agent 
Federal Bureau of Investigation, Telephone: 
This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf 
of the court. 
This subpoena is issued upon application 
of the United States of America 
•If not applicable, enter"none. 
To Fc us< 
Name Address and Phone Number of Assistant U.S. Attorney 
Assistant U.S. Attorney 
500 So. Australian Avenue, Suite 400 
West Palm Beach. FL 33401-6235 • 
Tel: 
Fax: 
lieu of AO! 30 
FORM ORD-227 
IAN.86 
EFTA00185342
Page 138 / 310
Respondent's Exhibit A 
Case No. 08-80736-CIV-MARFtA 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 08-80736-CIV-MARRA 
JANE DOE #1 AND JANE DOE #2, 
Petitioners, 
vs. 
UNITED STATES, 
Respondent. 
DECLARATION
E. 
declares as follows: 
I. I am a Special Agent in the Federal Bureau of Investigation (FBI) and have been so 
employed since 1997. I am currently assigned to the West Palm Beach office of the FBI Miami 
Field Division. 
2. In 2006, I was assigned as the case agent in an investigation into allegations that 
Jeffrey Epstein had engaged in unlawful sexual contact with girls under the age of 18. The case 
was called Operation Leap Year. FBI Special Agent 
and I conducted most of the 
investigation, and worked with the U.S. Attorney's Office, on Operation Leap Year. 
3. Over the course of the investigation, the FBI obtained hundreds of documents through 
the use of grand jury subpoenas, public records, and law enforcement databases. FBI agents 
conducted interviews with females believed to have been sexually abused by Mr. Epstein and 
underage at the time of the assault, as well as other individuals who might have relevant 
information. The interviews are memorialized and prepared by the interviewing FBI agent. The 
interview reports of the young women interviewed contain highly personal and intimate details, 
EFTA00185343
Page 139 / 310
Respondent's Exhibit A 
Case No. 08-80736-CIV-MARRA 
which would cause embarrassment to the young women if disclosed to third parties. For those 
interviewed who did not reveal any intimate details, many will be displeased if their cooperation 
with the FBI is made public. In my experience, individuals are reluctant to cooperate with law 
enforcement for fear of being singled out, harassixl, embarrassed, or subjected to retaliation if 
their cooperation is disclosed to third parties. 
4. The case file on Operation Leap Year also contains FBI agents' analysis of 
information obtained during the course of the investigation. 
These written analyses of the 
evidence reveal potential theories of criminal liability based on the evidence uncovered in the 
case. Information contained within FBI investigative files can also reveal sensitive FBI 
investigative and operational methods, procedures and techniques. While it is publically known 
that the FBI conducts investigations into the type of criminal wrongdoing committed by Jeffrey 
Epstein, disclosing the precise details of the sensitive methods, procedures and techniques 
employed during an investigation might compromise their future effective use. It is critical that 
the FBI's investigative tools remain confidential to both retain an element of surprise and to 
prevent countermeasures to such tools from being employed by targets and suspects. 
5. During the course of Operation Leap Ycar, I interviewed and heard the personal 
account of sexual abuse committed by Mr. Epstein on the young women. They suffered 
emotionally, and some were referred by the FBI to mental health professionals because of the 
psychologically harmed caused by Mr. Epstein. In at least one instance, mental health 
professionals were involved to help prevent one young woman from physically harming herself. 
6. The disclosure of personal information, contained in the FBI investigative file, to 
third parties would not merely cause further embarrassment but could result in additional 
psychological trauma, disruption of family relationships, disruption of professional careers and 
2 
EFTA00185344
Page 140 / 310
Respondent's Exhibit A 
Case No. 08-80736-CN-IAARRA 
possible public release of personal information. 
7. Operation Leap Year remains an open case. 
8. I declare under penalty of perjury that the foregoing is true and correct. 
EXECUTED on September 3, 2013. 
pedal gent 
Federal Bureau of Investigation 
West Palm Beach, Florida 
3 
EFTA00185345
Pages 121–140 / 310