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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

EFTA00213048

135 pages
Pages 41–60 / 135
Page 41 / 135
Mr. Lefkowitz, 
05/28/2008 04:51 PM 
To 
cc 
bcc 
Subject Jeffrey Epstein 
The United States Attorney's Office for the Southern District of Florida was 
recently notified that the Office of the Deputy Attorney General, at your request, 
intends to review certain aspects of the investigation involving Mr. Epstein's sexual 
conduct involving minor victims. Naturally, until the DAG's Office has completed 
its review, this Office has postponed the current June 2, 2008 deadline requiring 
compliance by your client with the terms and conditions of the September 24, 2007 
global resolution of state and federal liabilities, as modified by the United States 
Attorney's December 19, 2007 letter to Lilly Ann Sanchez, Esq. 
Sincerely, 
Jeffrey H. Sloman 
First Assistant US Attorney 
Southern District of Florida 
EFTA00213088
Page 42 / 135
Exhibit 10 
EFTA00213089
Page 43 / 135
Jack Goldberger 
From: 
Jack Goldberger 
Sent: 
Friday, June 27, 2008 10:22 AM 
To: 
Jack Goldberger 
Subject: 
FW: Have a great weekend! 
Attachments: 
PLEA.Epsteln.doc 
From: 
Sent Friday, June 27, 2008 10:00 AM 
To: Jack Goldberger 
Subject Have a great weekend! 
EFTA00213090
Page 44 / 135
Exhibit 11 
EFTA00213091
Page 45 / 135
Jack Goldberger 
Sent: 
mas...J11:31 AM 
From: 
SAFLS) 
To: 
Jack Goldberger 
Cc: 
USAFLS); RBlack©RoyBlack.com 
Subject: 
Re: Notice of Non-Compliance 
Dear Jack: 
I have conferred with a state court practitioner who stated that there is nothing that 
prohibits you from agreeing to a consecutive six-month sentence of incarceration followed by 
one year of community control as specified in the non-prosecution agreement. 
If you elect to proceed with the plea agreement as currently drafted, we ask that you insert 
the word "imprisoned" following the words "six months" in the second sentencing paragraph. 
Please confirm that this change is acceptable. Thank you. 
 
 Original Message  
From*
Goldberger 
To: 
Ann Mart..... 
Cc: Jack Goldberger 
Sent: Sat Jun 28 08:49:55 2008 
Subject: RE: Notice of Non-Compliance 
Dear Ms 
please allow this e-mail to confirm our telephone conference of 6:30 pm on June 27 wherein we 
discussed the Epstein plea agreement and we agreed that the Epstein state plea agreement was 
in compliance with the September 2007 non-prosecution agreement entered into between Mr. 
Epstein and the USAO for the Souhern District of Florida. 
Jack Goldberger 
From: EMS 
C. (USAFLS) 
Sent: Fri 6/27/2008 5:45 PM 
To: Jack Goldberger; Roy BLACK 
Cc: 
Notice o Non-Compliance 
Dear Messrs. Goldberger and Black: 
Please see the attached Notification Letter. 
«080627 Goldberger Black notification ltr.pdf» 
Assistant U.S. Attorney 
1 
EFTA00213092
Page 46 / 135
Exhibit 12 
EFTA00213093
Page 47 / 135
PLEA IN THE CIRCUIT COURT 
THE FOLLOWING IS TO REFLECT ALL TERMS OF THE NEGOTIATED SETTLEMENT 
Name: JeffreyE. Epstein 
Plea: Guilty 
Case No. 
Charge 
Count Lesser 
Degree 
06CF009454AMB 
Felony Solicitation of Prostitution 
1 
No 
3 FEL 
08CF009381AM8 
Procuring Person Under 18 for Prostitution 1 
No 
2 FEL 
PSI: Waived/Not Required X 
Required/Requested 
ADJUDICATION: 
Adjudicate [x 
SENTENCE: 
On 06CF009454AMB, the Defendant is sentenced to 12 months in the Palm Beach County 
Detention Facility, with credit for 1 (one) day time served. 
On 08CF009381AMB, the Defendant is sentenced to 18 months Community Control 1 (one). As 
a special condition of this Community Control, the Defendant must serve the first 6 
months in the Palm Beach County Detention Facility, with credit for 1 (one) day time 
served. This sentence is to be served consecutive to the 12 month sentence in 
06CF009454AMB. The conditions of community control are attached hereto and 
incorporated herein. 
OTHER COMMENTS OR CONDITIONS; 
Court Costs: $474.00 
Cost of Prosecution: $50.00 
Drug Trust Fund: $50.00 
As a special condition of his community control, the Defendant is to have no unsupervised 
contact with minors, and the supervising adult must be approved by the Department of 
Corrections. 
The Defendant is designated as a Sexual Offender pursuant to Florida Statute 943.0435 and 
must abide by all the corresponding requirements of the statute, a copy of which is attached 
hereto and incorporated herein. 
The Defendant must provide a DNA sample in court at the time of this plea. 
Assistant State Attorney 
Attorney for the Defendant 
Date of Plea 
Defendant 
EFTA00213094
Page 48 / 135
PLEA Ilk THE CIRCUITCOURT 
THE FOLLOWING IS TO REFLECT ALL TERMS OF THE NEGOTIATED SETTLEMENT 
Name: Jeffrey E Epstein 
Plea: Gusty 
Dfle No. 
Charge 
Count Lester 
Degree 
C6CF039454AMB 
Felony Solicitation of Prostitution 
1 
No 
3 FEL 
OSCF0D9361AMB 
Pr curing Person Under 1S for Prostitution 1 
No 
2 FEE. 
PSI: tribNedfNot Required X 
Required/Requested 
ADJUDICATION: 
Adjudicate (x 
SENTENCE: 
On D6CF03945/4AMB, the Defendant Is sentenced to 12 months in the Palm Beads County 
Detention FaSty, with credt for 1 (one) day time served. 
On U8C,F009381AlvlB, the Defendant is sentenced to 6 months in the Palm Beach County 
Detention Facility, vsti men for 1 (one) day time served. This 6 month sentence Is to b 
served =nsevartive to the 12 month sentence in OSCF0394-50.AMB. Fotroviiing this 6 
• 
. 
. 
• . 
month sentence, the Defendant will be placed on 12 months Community Control 1 (one). 
The conditions of community ,..„.inhul are attached hereto and incorporated herein. 
OTHER CONVENTS OR CONDITIONS: 
As a special condition of his community control, the De 
dant is to have no unsupervised 
contact with minors, and the supervisirrg adult must be pproved by the Department of 
Conedions. 
The Defendant is designated as a Sexual Offender pursuant to Florida Statute 943.0435 and 
must abkle by all the corresponding requirements of the statute, a copy of which is attached 
hereto and incorporated herein. 
t
The Defendant must provide a DNA sample in court at the time of ' 
V 
.
• !iiah 
Assitetaittlaie Adorn,* • 
/c://. 
O f 
Defendant 
EFTA00213095
Page 49 / 135
Exhibit 13 
EFTA00213096
Page 50 / 135
KIRKLAND 8. ELLIS LLP 
AND At TILIATED PAIONIASMItS 
Jay P. lielcowitt, P.C. 
To 
. 
Cingroup Center 
163 East SW Street 
New York, New York 10022-4811 
www.kirklancLeom 
Octobcr 10, 2007 
VIA E-MAIL 
R. Alexander Acosta 
United States Attorney's Office 
Southern District of Florida 
500 South Australian Avenue, Suite 400 
West Palm Beach, Florida 33401 
Re: Jeffrey Epstein 
Dear Alex: 
Facsimile: 
Dlr. Fax 
Confidential. For Settlement 
Purposes Only, Pursuant to Rule 408. 
I write as a follow up to our conversation yesterday regarding the open issues that remain 
M
m 
in 
stein matter. As you are aware, we continue to have serious disagreements with Ms. 
regarding the nature of the settlement process for identified individuals' § 2255 claims. 
representation in a lawsuit was never contemplated by the Federal Plea Agreement (the 
"Agreement,. Over the course of the negotiations of the Agreement, the parties worked 
diligently to create an alternative dispute resolution for those identified individuals seeking a civil 
remedy for the conduct at issue, in an effort to avoid long drawn out disputes over liability in 
public adversarial litigations. Initially, we proposed that Mr. Epstein create a trust whereby a 
trustee would be appointed by the Circuit Court to disperses 
to the identified individuals 
based on a good faith showing of injury. In response, t
 proposed the appointment of 
a guardian ad litem to represent the identified individuals, not an attorney, which suggests that 
litigation was never contemplated by either party. Ultimately, the parties agreed to Paragraphs 7 
and 8 of the Agreement, which allow for a single attorney representative to settle the claims of the 
identified individuals and create a procedural alternative to public adversarial litigation. 
In keeping with the parties' understanding of Paragraphs 7 and 8, you should know that 
we are in agreement with your choice of Judge Edward Davis, but we believe Judge Davis should 
act as the attorney representative to settle claims pursuant to the Agreement and the parties' 
longstanding understanding of the settlement process. Because the process we have agreed to 
does not contemplate litigation with respect to the attorney representative, Judge Davis can work 
to negotiate settlements with the identified individuals without further involvement by the 
government or its agents. Below, I've outlined our main areas of concern with the approach Ms. 
Chicago 
Hong Kong 
London 
Los Angeles 
Munich 
San Francisco 
Washington, D.C. 
EFTA00213097
Page 51 / 135
Confidential. For Settlement Purposes Only, Pursuant to Rule 008. 
It Alexander Acosta 
October 10, 2007 
Page 2 
a
lias taken regarding the role of the attorney representative and the settlement process for 
§ 2255 claims pursuant to Paragraphs 7 and 8 of the Agreement. 
First Issue: The Settlement Process and the Role of the Attorney Representative. The 
settlement procedure we propose, and which we believe is made clear by the Agreement, is 
reasonable and consistent with the intention of the parties: the attorney representative will 
represent the identified individuals provided they opt to enter into a settlement agreement with 
Mr. Epstein with respect to their § 2255 claims. The attorney representative will negotiate a total 
settlement amount with Mr. Epstein. Once the United States has formally declined to prosecute 
Mr. Epstein in this matter, and each identified individual electing to settle has waived her right to 
pursue any other claims against Mr. Epstein, the attorney representative will distribute the 
proceeds in the manner he sees fit. If the identified individuals cannot settle or opt not to settle on 
a damages amount with Mr. Epstein, then the attorney representative may not continue his 
representation and is barred from filing lawsuits pursuant to § 2255 and the identified individuals 
would not be suing under § 2255 as contemplated by Paragraph 8. 
Based on the specific language in the contract and the intent of both parties, we believe 
that the Agreement clearly provides that the identified individuals may opt to make use of the 
attorney representative so long as they can reach a settlement agreement with Mr. Friein. If the 
parties cannot settle on a damages amount with Mr. Epstein, then the attorney representative may 
not continue his representation and is barred from filing lawsuits pursuant to § 2255. 
The provisions of the Agreement make clear that the role of the attorney representative is 
limited to cipnling claims brought by identified individuals pursuant to the Agreement. While 
Paragraph 7 defines who may be represented by the attorney representative, Paragraph 8 outlines 
the scope of that representation. Paragraph 7 states: 
The United States shall provide Epstein's attorneys with a list of individuals whom it has identified 
as victims, as defined in IS U.S.C. § 2255, after Epstein has signed this agreement and has been 
sentenced. Upon the execution of this agreement, the United States, in consultation with and 
subject to the good faith approval of Epstein's counsel, shall select an attorney representative for 
these persons, who shall be paid for by Epstein. Epstein's counsel may contact the identified 
individuals through that representative. 
Under Paragraph 8 of the Agreement, which provides the terms of the representation, the 
attorney representative is only appointed to protect the interests of those identified individuals 
who elect to waive any claim for damages other than the damages agreed to by the parties. 
Paragraph 8 states: 
If any of the individuals referred to in paragraph (7), supra, elects to file suit pursuant to 18 U.S.C. 
§ 2255, Epstein will not contest the jurisdiction of the United States District Court for the Southern 
District of Florida over this person and/or the subject matter, and Epstein waives his right to contest 
liability and also waives his right to contest damages up to an amount as agreed to between the 
EFTA00213098
Page 52 / 135
ConfidentlaL For Settlement Purposes Only, Pursuant to Rule 408. 
R. Alexander Acosta 
October 10, 2007 
Page 3 
identified individual and Epstein, so long as the identified individual elects to proceed exclusively 
under 18 US.C. § 2255, and agrees 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 list provided by the United States, Epstein's signature on this agreement, his waivers 
and failures to contest liability and such damages in any suit arc not to be construed as an admission 
of any criminal or civil liability. 
Paragraph 8 addresses how Mr. Epstein's waivers are triggered pursuant to a settlement 
with each identified individual. Paragraph 8 is clear that Mr. Epstein will only waive § 2255 
liability "so long as" each identified individual proceeds exclusively under § 2255 and agrees to 
waive damages other than "an amount as agreed to between the identified individual and 
Epstein." The Agreement's silence with respect to what happens if the parties cannot settle on a 
damages amount indicates that the parties intended for the scope of the attorney representative's 
representation to be limited to settling claims with Mr. Epstein, not representing these identified 
individuals in § 2255 lawsuits. 
MIMS 
however, insists that the attorney representative's duties include pursuing a 
lawsuit un 
§ 2255 on behalf of each identified individual in the event that settlement talks are 
unsuccessful. This interpretation is incorrect because Ms.IIM ignores Paragraph 8, which 
limits the scope of the attorney representative's representation. 
The longstanding intention of the parties is also consistent with our interpretation of the 
Agreement based on prior iterations of the Agreement, which only refer to appointing a trustee or 
a guardian ad litem to protect the interests of the identified individuals. Thus, legal representation 
in a lawsuit was never contemplated under the Agreement. Also, Mr. Epstein's agreement to pay 
the attorney representative's fees reaffirms that the parties never intended for the attorney 
int. 
representative to bring lawsuits. § 2255 includes a provision for attorne 's fees, but only if there 
is a monetary recovery. If the Agreement contemplates, as Ms. 
suggests, that the 
attorney representative could file suit on behalf of each identified • 
ss 
, Mr. Epstein would 
never have agreed to pay attorneys fees for those that being suit and lose. It is clear that Mr. 
Epstein agreed to pay the attorney representative's fees because he assumed that each identified 
individual represented by the attorney representative would recover something by settling on their 
respective damages claim.
Ms. 
interpretation of the Agreement would also trigger profound ethical 
problems due to the conflicts of interests that would arise. For instance, if Mr. Epstein agrees to 
pay for the attorney representative's fees and monthly expenses in any potentially litigated matter, 
then the attorney representative would effectively be incentivized to reject settlement 'under § 
2255 in an effort to draw out the lawsuits and incur more fees. If the lawyer were allowed to 
represent the identified individuals in a lawsuit, the best interests of each identified individual 
might not be served, because the attorney representative will always be more interested in 
pursuing lawsuits in lieu of settling claims against Mr. Epstein efficiently and fairly. This conflict 
EFTA00213099
Page 53 / 135
Confidential. For Settlement Purpose.. Only, Pursuant to Rule 408. 
R. Alexander Acosta 
October 10, 2007 
Page 4 
could compromise the attorney representative's duty of loyalty. See ABA Annotated Model 
Rules of Professional Conduct, Rule 1.8(O ("A lawyer shall not accept compensation for 
representing a client from one other than the client unless... there is no interference with the 
lawyer's independence of professional judgment or with the client-lawyer relationship"). And Mr. 
Epstein would essentially be paying the attorney representative to sue himself. Such a result is 
inappropriate and unconscionable. 
The attorney representative will face other conflicts as well. As a general matter, multiple 
representation of a group of individuals that elects to settle on damages as well as one or more 
individuals who reject settlement carries with it the heightened potential for irreparable conflicts. 
For example, the ethics rules preclude an attorney from simultaneously representing parties that 
are likely to end up in conflict. See ABA Annotated Model Rules of Professional Conduct, Rule 
1.7 ("A lawyer shall not represent a client if...there is a significant risk that the representation of 
one or more clients will be materially limited by the lawyer's responsibilities to another client, a 
former client or a third person or by a personal interest of the lawyer."). Here, I can imagine a 
case where one of the identified individuals is called as a witness by Mr. Epstein to dispute an 
allegation by another identified individual who is a party to the case. The attorney representative 
would have to cross examine the witness, who is also his client. In another scenario, the attorney 
representative may receive privileged information from one identified individual, which precludes 
him from using that information with rospect to another identified individual. In each scenario, 
the attorney representative will be simultaneously representing parties that may be in conflict, in 
violation of Rule 1.7. 
For these reasons, we believe that Ms. Villafana's interpretation of the Agreement in 
connection with the attorney representative's role in the settlement process must be rejected. 
Second Issue: Waiver of Liability. Ms. 
incorrectly alleges that Mr. Epstein 
has waived liability even when claims are not sett) 
ant to the Agreement, if the identified 
individuals choose not to settle with Mr. Epstein, he will not waive liability for those individuals 
whose claims are not settled by the attorney representative. Paragraph 8 is clear that Mr. Epstein 
will only waive § 2255 liability so long as each identified individual proceeds exclusively under § 
2255 and agrees to waive damages other than "an amount as agreed to between the identified 
individual and Epstein." (Paragraph 8, Agreement) Consequently, those identified individuals 
who choose not to settle with Mr. Epstein are not covered by the terms of the Agreement and will 
have to prove, among other things, that they are victims under the enumerated statutes. 
Third Issue: Communication to Identified Individuals. Ms. 
proposes that 
either she or federal agents will speak with the identified individuals regarding the settlement 
process. We do not think it is the government's place to be co-counsel to the identified 
individuals, nor should the FBI be their personal investigators. Neither federal agents nor anyone 
from your Office should contact the identified individuals to inform them of the resolution of the 
EFTA00213100
Page 54 / 135
Confidential. For Settlement Purposes Only, Pursuant to Rile 408. 
Alexander Acosta 
October 10, 2007 
Page 5 
case, including appointment of the attorney representative and the settlement process. Not only 
would that violate the confidentiality of the Agreement, but Mr. Epstein also will have no control 
over what is communicated to the identified individuals at this most critical stage. We believe it 
is essential that we participate in crafting a mutually acceptable communication to the identified 
individuals. We further believe that communications between your Office or your case agents 
and the identified individuals might well violate Rule 6(eX2)(B) of the Federal Rules of Criminal 
Procedure. The powers of the federal grand jury should not, even in appearance, be utilized to 
advance the interests of a party to a civil lawsuit. 
We propose that the following joint communication be made to Judge Davis, who will act 
as the attorney representative and communicate accordingly with the identified individuals: 
As counsel for the United States of America and Jeffrey Epstein, we jointly write 
to you to provide information relevant to your services as the attorney 
representative to represent certain identified individuals who may have a civil 
claim against Mr. Epstein. 
The United States has conducted an investigation of Mr. Epstein regarding his 
solicitation of females, some of whom the government alleges were underage, to 
engage in prostitution in his Palm Beach County home. 
Based on this 
investigation, the United States has identified certain individuals who may be 
eligible to seek a civil remedy against Mr. Epstein pursuant to 18 U.S.C. § 2255. 
The United States and Mr. Epstein have agreed to a resolution of this investigation. 
As part of the resolution of this matter, the parties have agreed to a settlement 
process for these identified individuals. The parties agree that you will contact 
each identified individual and explain the nature of the resolution of this matter, 
including the settlement process, in accordance with a joint communication drafted 
by the United States and Mr. Epstein. The parties further agree that you will 
interview each identified individual to confirm that they have a viable claim 
against Mr. Epstein pursuant to 18 U.S.C. § 2255. 
Pursuant to the resolution of this matter, you will represent only those identified 
individuals who elect to settle their claims with Mr. Epstein, and your duties will 
be limited to negotiating a settlement on the identified individuals' behalf and 
dispersing the settlement proceeds. Mr. Epstein has agreed that he will not contest 
jurisdiction in the Southern District of Florida, and he will not contest liability 
pursuant to 18 U.S.C. § 2255 for those identified individuals who elect to settle all 
potential claims against him regarding this matter. Mr. Epstein has also agreed to 
pay reasonable attorney's fees and expenses that you incur as a result of settlement 
negotiations and settlement administration of this matter. 
EFTA00213101
Page 55 / 135
Confidential. For Settlement Purposes Only, Pursuant to Rule 403. 
R. Alexander Acosta 
October 10, 2007 
Page 6 
To settle these claims, the parties agree that you will negotiate a total settlement 
amount with Mr. Epstein for each identified individual who elects to settle. After 
the United States formally declines to initiate any prosecution against Mr. Epstein 
related to this matter and each identified individual you represent executes a 
waiver of all rights to pursue any litigation regarding this matter, you may then 
distribute the proceeds from the total settlement amount to the identified 
individuals in the manner you see fit. 
For those identified individuals who elect not to settle their claims, Mr. Epstein 
will not waive his right to contest jurisdiction, liability or damages. Furthermore, 
Mr. Epstein will not pay for their attorney's fees or expenses, and you may not 
represent these individuals in any capacity. Each of these individuals will be 
responsible for finding, hiring and paying for her own attorney. 
The details regarding the United State's investigation of this matter and its 
resolution with Mr. Epstein is confidential. You may not make public statements 
regarding this matter. If you have any questions regarding this matter, including 
the settlement process, you must contact Mr. Epstein's counsel and request a joint 
clarification from said counsel and the United States. You should not contact the 
United States directly. The parties will make every effort to answer your questions 
via a joint communication. 
Alex, as you know, when Mr. Epstein signed the Agreement, he did so in order to reach 
finality with your Office and with the express representation that the federal investigation against 
him would cease. To that end, I would like your assurance that after you and I agree to the issues 
raised in this letter, that it will be the end of the United States' involvement barring a willful 
breech of the Agreement. Specifically, the government or any of its agents will not make any 
further communications to the identified individuals and will not make any ex parte 
communications with Judge Davis. 
I look forward to resolving these open issues with you during our 4:30 call today. 
Sincerely, 
P. Leflcowitz 
EFTA00213102
Page 56 / 135
Exhibit 14 
EFTA00213103
Page 57 / 135
*2 
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 South Australian Ave., Suite 400 
West Palm Beach, FL 33401 
(561) 820.8711 
Facsimile: (561) 820-8777 
November 29, 2007 
DELIVERY BY HAND 
Miss 
Re: 
Crime Victims' Rights — Notification of Resolution of Epstein Investigation 
Dear Miss 
Several months ago, I provided you with a letter notifying you of your rights as a victim 
pursuant to the Justice for All Act of 2004 and other federal legislation, including: 
(1) 
The right to be reasonably protected from the accused. 
(2) 
The right to reasonable, accurate, and timely notice of any public court proceeding 
involving the crime or of any release or escape of the accused. 
(3) 
The right not to be excluded from any public court proceeding, unless the court 
determines that your testimony may be materially altered if you are present for other 
portions of a proceeding. 
(4) 
The right to be reasonably heard at any public proceeding in the district court 
involving release, plea, or sentencing. 
(5) 
The reasonable right to confer with the attorney for the United States in the case. 
(6) 
The right to full and timely restitution as provided in law. 
(7) 
The right to proceedings free from unreasonable delay. 
(8) 
The right to be treated with fairness and with respect for the victim's dignity and 
privacy. 
I am writing to inform you that the federal investigation of Jeffrey Epstein has been 
completed, and Mr. Epstein and the U.S. Attorney's Office have reached an agreement containing 
the following terms. 
First, Mr. Epstein agrees that he will plead guilty to two state offenses, including the offense 
of soliciting minors to engage in prostitution, which will require him to register as a sexual predator 
for the remainder of his life. 
EFTA00213104
Page 58 / 135
MISS 
NOVEMBER 29,2007 
PAGE 2 
Second, Mr. Epstein has agreed to make a binding recommendation of 18 months' 
imprisonment to the state court judge who sentences him. Mr. Epstein will serve that sentence of 
imprisonment at the Palm Beach County Jail. 
Third, Mr. Epstein has agreed that he will not contest jurisdiction or liability if you elect to 
seek damages from him because the United States has identified you as a minor victim of certain 
federal offenses, including travel in interstate commerce to engage in prostitution with minors and 
the use of facilities of interstate commerce to induce minors to engage in prostitution. To assist you 
in making such a claim, the U.S. Attorney's Office has asked an independent Special Master to 
select attorneys to represent you. Those attorneys are Aaron Podhurst and Robert ("Bob") 
Josefsberg with the law firm of Podhurst Orseck, P.A. They can be reached at (305) 358-2800. I 
anticipate that someone from their law firm will be contacting you shortly. J must also advise you 
that you are not obligated to use these attorneys. In fact. you have the absolute right to select your 
own attorney. so yon_can decide not to—sneak with Rom. Podhurst/ Josefsberg at all. or you can
speak with them and decide at any time to use a different attorney If you do decide to seek damages 
from Mr. Epstein and you decide to use Messrs. Podhurst / Josefsberg as your attorneys, Mr. Epstein 
will be responsible for paying attorney's fees incurred during the time spent trying to negotiate a 
settlement. If you are unable to reach a settlement with Mr. Epstein, you and Mr. Josefsberg can 
discuss how best to proceed. 
As I mentioned above, as part of the resolution of the federal investigation, Mr. Epstein has 
agreed to plead guilty to state charges. Mr. Epstein's change of plea and sentencing will occur on 
December 14,2007, at 
a.m., beforeJudge Sandra K. McSorley, in Courtroom 11F atthe Palm 
Beach County Courthouse, 205 North Dixie Highway, West Palm Beach, Florida. Pursuant to 
Florida Statutes Sections 960.001(1)(k) and 921.143(1), you are entitled to be present and to make 
a statement under oath. If you choose, you can submit a written statement under oath, which will 
be filed by the State Attorney's Office on your behalf. If you elect to prepare a written statement, 
it should address the following: 
the facts of the case and the extent of any harm, including social, psychological, or 
physical harm, financial losses, loss of earnings directly or indirectly resulting from 
the crime for which the defendant is being sentenced, and any matter relevant to an 
appropriate disposition and sentence. Fl. Stat. 921.143(2). 
You also are entitled to notification when Mr. Epstein is released from imprisonment at the 
end of his prison term and/or if he is allowed to participate in a work release program. To receive 
such notification, please provide the State Attorney's Office with the following information: 
1. 
Your name 
2. 
Your address 
3. 
Your home, work, and/or cell phone numbers 
EFTA00213105
Page 59 / 135
MISS 
NOVEMBER 29, 2007 
PAGE 3 
4. 
Your e-mail address 
5. 
A notation of whether you would like to participate in the "VINE system," which 
provides automated notification calls any time an inmate is moved. (To use this 
system, your calls must go to you directly, not through a switchboard.) 
Thank you for all of your help during the course of the investigation. If you have any 
questions or concerns, please do not hesitate to contact me or Special Agent Nesbitt Kuyrkendall 
at (561) 822-5946. 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
By: 
fl
. I VAY{ 
Assistant United States Attorney 
cc: 
EFTA00213106
Page 60 / 135
Exhibit 15 
EFTA00213107
Pages 41–60 / 135