EFTA00225672

08/OP/08 YON 
r5n8a MOEN 
n5127/26(4 12 18 b).8 
EXECUTIVE OFFICE 
UOJIODAG 
12002 
lä003/.0i 3 
tomp,"liva. 
Kenneth W. Starr 
Kirkland tV hill i 1.1.1' 
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(2021 $14-040 
I loatmtble Mark Filip 
)I lice OI the Dupnly Attorney General 
(haled titates Department tif Just ice 
050 Pennsylvania Avenue, N.W. 
Washington. 0.4'. 70530 
Dc.ir Judy.: Filip: 
May :7, 2008 
Pk 0. 
I: it /c., 
 
 & Bird LLP 
The t dated Kidder: 
' 19. 1 .mteet. NW 
*.e .!:“;;;;;Pti. ; 
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rdh 
-i1P"-; 
pv who lin.w.d.e. y 
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C'ONI•%p/::'\'7'/..11.
•_ 
• 
'Ibis letter briefly supplements ttttt prior submission to 
u dated May I.1. 2008. 
OW! 
conirmaneation. we urgently requested that your Office etualuel an independent 'reeitm 
the 
moused federal pro•annitIon of our client. Miley Epstein. The dual Iti:INONIS Jill' 
that 
you review this newer am lit the bedrock need fin integrity in the enfiteentrat 
flitfe: ud 
ell "'MI laws. and iiil the prOfteind questions raised hy the unprecedented eKlcumeem id' federal 
taw by the t 
Siats Attorney> Office in Mimed (the 
ESAU') tu a preminem public figure
who 
•:h1µ Iles 11, 'boner President 
'Mc need for review is now all the more eNigent. Ou Monday. MaY 19. 2008. 
Assistant JetTrey Shaun af the t ;SAO responded m an email from JD) I.elkowiitittfintuitu; k 
Attorney Alex Aeostu that we wnuld he seekinG your Oilliee's review. Mr. Slonew's letter. 
tvhkh improa:d a deadline of June 2. 2008 to comply with all the terms of the k.ue: cm von. 
Prosecution Agreement (die - Ago:emu:tn. pies new unilateral modifications, an pain of being 
deemed in breach 
Mat Agreement. ;Appeal, lo hove been deliberately designed to deprive UN Of 
an adequate opportunity Iu aret. your Office's review in ibis minter. 
(.!SAO'S desire to foreclose a complete revielk is widerstancLible. give!) den ibe 
Child Esplibitation and Obscenity Section retiON.3 has already delenemed that our subsiaite 
arg.1111148118 retarding WilY 
a ((:terot prosecution of mr. upsigin is not warranted were 
• 
nelling.- I Inwever. in contradiction w Mr. Sloman's assertion that 8ä0S luad provided an 
independent. dr Jew° 
(RÖS made clear that it did not do so. indeed. elifiR declined ut 
examine several of the more troubling aspgets of the investigation al' Mr. Upstem. 
the 
deliberate leak In the New York Times of mInterous highly vontidetekil aspects of the 
i 'west; gati un and nettothu kin:; Ec t," 3.41 I h e punk% US Weil US tie i«unt coll., of c 
kw,:'IrisK 
filed againu Mr. Epstein by Mr. Sloman's former law partner. 
The t ttttt eeessary anti arbitrarily imposed deadline set by the I /SIMI was done without any 
ruspee4 an' (lie turmal rum:tip ll tt 
and scheduling of state judicial neuters. It require< den 
Mr. Ep stein's counsel persuade the Slate Attorney of l'alen peach tu issue a criminal in !brit union 
EFTA00225692

uoiuzive AWN 14:3a /AA 305 530 6440 
EXECUTIVE OFFICE 
(moot 
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
UNITED STATES ATTORNEY'S OFFICE 
SOUTHERN DISTRICT OF FLORIDA 
99 NE 4Th STREET 
MIAMI, FLORIDA 33132-2111 
Jeffrey H. Sloman 
First Assistant U.S. Attorney 
305 961 9299 
Cyndee Campos 
Staff Assistant 
fax 
FACSIMILE TRANSMISSION 
COVER SHEET 
DATE: 
June 2, 2008 
TO: 
Villafana 
FAX NUMBER: 
(561) 820 8777 
SUBJECT: 
Epstein 
NUMBER OF PAGES, INCLUDING THIS PAGE: 9 
Message/Comments: 
This facsimile contains PRIVILEGED AND CONFIDENTIAL INFORMATION intended only for the use of the 
Addressee(s) named above. If you am not the intended recipient of this facsimile, or the employee or agent responsible 
for delivering it to the intended recipient, you are hereby notified that any dissemination or coping of this facsimile is 
strictly prohibited. If you have received this facsimile in error, please immediately notify us by telephone and return the 
original facsimile to us at the above address via (ho U.S. Postal Service. Thank you. 
EFTA00225693

51z7bb SrauS...644issJoN 
To n 44 
tXHIBIT 
11 
EFTA00225694

JAY P. LEFKOWITZ, ESQ. 
May 19, 2008 
PAGE 6 OF 6 
Conclusion 
On February 25, 2008, I sent you an e-mail setting forth a timetable for moving forward in 
the event that CEOS disagreed with your position. That time is now. As you know, my February 25"' 
email stated that I would give you one week to comply with the terms and conditions of the 
Agreement, as modified by the USA's December I94 letter to Ms. Sanchez. In light of the upcoming 
Memorial Day weekend, I have decided to extend that timetable to the close of business on Monday, 
June 2, 2008, which is a full two weeks. 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
By: 
Jeffrey H. Sloman 
First Assistant United States Attorney 
cc: 
R. Alexander Acosta 
United States Attorney 
A. 
Villafana 
Assistant U.S. Attorney 
Karen Atkinson 
Assistant U.S. Attorney 
EFTA00225695

JAY P. LEFKOWITZ, ESQ. 
May 19, 2008 
PAGE 5 OF 6 
C. 
"Mr. Epstein Does Not Believe He Is Guilty Of The Federal Charges Enumerated 
Under Section 2255." 
At our December 14, 2007 meeting at the U.S. Attorney's Office in Miami, counsel for 
Epstein announced, inter alia, that it was a "profound injustice" to require Epstein to register as a 
sex offender and reiterated that no federal crime, especially 18 U.S.C. Section 2422(6), had been 
committed since the statute is only violated if a telephone or means of interstate commerce is used 
to do the persuading or inducing. This particular attack on this statute had been previously raised and 
thoroughly considered and rejected by the SDFL and COS prior to the execution of the Agreement. 
You also argued that the facts were inapplicable to the contemplated state statutes and that Epstein 
should not have been allowed to have been induced into the Agreement because the facts were not 
what he understood them to be, It should be noted that the SDFL has never provided you with any 
evidence suppolg its investigation. This is not, and has never been, an Alford plea situation (see 
North Carolina 
Alford, 400 U.S. 25, 91 S.Ct: 160 (1970)). Ultimately, you requested an 
independent review. 
Subsequent to the above-mentioned meeting, the SDFL received three letters from you and/or 
Mr. Starr which expanded on some of the themes announced in the December 14th meeting. 
Essentially, you portrayed the SDFL as trying to coerce a plea to unknown allegations and incoherent 
theories. On December 17, 2007, you decreed that Epstein's conduct did not meet the requirements 
of solicitation of minors to engage in prostitution (Fl. Stat. Section 796.03) one of the enumerated 
crimes Epstein had previously agreed to plead guilty to; that Epstein's conduct does not require 
registration under Florida law; and the State Attorney's Office does not believe the conduct is 
registrable. On December 21, 2007, you rejected the USA's proposed resolution of the 2255 
provision because you "strongly believe that the provable conduct of Mr. Epstein with respect to 
these individuals fails to satisfy the requisite elements of either 18 U.S.C. Section[s] 2422(6) ... or 
... 2423(6)." In your December 26, 2007 correspondence you stated that "we have reiterated in 
previous submissions that Mr. Epstein does not believe he is guilty of the federal charges enumerated 
under section 2255" and requiring "Mr. Epstein to in essence admit guilt, though he believes he did 
not commit the requisite offense." 
As the SDFL has reiterated time and time again, it does not want, nor does it expect, Epstein 
to plead guilty to a charge he does not believe he committed. As a result, we obliged your request 
for an independent de novo review of the investigation and facilitated such a review at the highest 
levels of the Department of Justice. It is our understanding that that independent review is 
complete and a determination has been made that there arc no impediments to a federal prosec 
by the SDFL. 
EFTA00225696

JAY P. I.F.FKOWITZ, ESQ. 
May 19, 2008 
PAGE 4 OF 6 
B. 
Method of Compensation and Notification. 
During this same time period, you and others, including the former Solicitor General of the 
United States Kenneth Starr, took issue with the implementation of the methodology of 
compensation (hereinafter "the 2255 provision")3 and the SDFL's intention to notify the victims 
under 18 U.S.C. Section 3771 (you objected to victims being notified of time and place of Epstein's 
state court sentencing hearing). In response, the SUFI, offered, in my opinion, numerous and various 
reasonable modifications and accommodations which ultimately resulted in United States Attorney 
R. Alexander Acosta's' December 19, 2007 letter to Lilly Ann Sanchez. In that letter, the United 
States Attorney tried to eliminate all concerns which, quite frankly, the SDFL was not obligated to 
address, let alone consider. He proposed the following language regarding the 2255 provision: 
"Any person, who while a minor, was a victim of a violation of an offense enumerated in 
Title 18, United States Code, Section 2255, will have the same rights to proceed under 
Section 2255 as she would have had, if Mr. Epstein been tried federally and convicted of an 
enumerated offense. For purposes of implementing this paragraph, the United States shall 
provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in 
an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority 
interpreting this provision, including any authority determining which evidentiary burdens 
if any a plaintiff must meet, shall consider that it is the intent of the parties to place these 
identified victims in the same position as they would have been had Mr. Epstein been 
convicted at trial. No more; no less." 
Regarding the issue of notice to the victims, USA Acosta proposed to notify them of the 
federal resolution as required by law; however, "rwle will defer to the discretion of the State 
Attorney regarding whether he wishes to provide victims with notice of the state proceedings, 
although we will provide him with the information necessary to do so if he wishes." As you know, 
you rejected these proposals as well. See December 26, 2007 correspondence from Jay Lefkowitz 
to USA Acosta. 
3 Prior to any issues arising concerning the implementation of the 2255 provision, the SDP', 
unilaterally agreed to assign its responsibility to select the attorney representative for the alleged victims 
to an independent third-party. This was done to avoid even the appearance of favoritism in the selection 
of the attorney representative. As a result, on October 29, 2007, the parties executed an Addendum 
wherein it was mutually agreed that former United States District Court Judge Edward B. 
would 
serve as the independent third-party. Judge Davis selected the venerable law firm of Podhurs and 
Josefsberg to represent the approximately 34 alleged identified victims. 
EFTA00225697

JAY P. LEFKOWITZ, ESQ. 
May 19, 2008 
PAGE 3 OF 6 
of the guilty plea and sentence no later than October 26, 2007; and (5) the start of the above-
mentioned sentence no later than January 4, 2008. 
Furthermore, and significantly, Epstein agreed that he had the burden of ensuring compliance 
of the Agreement with the Palm Beach County State Attorney's Office and the Judge of the 15111
Judicial Circuit and "that the failure to do so will be a breach of the agreement" (emphasis added). 
Post-Execution of the Agreement 
Within weeks of the execution of the Agreement, you sought to delay the entry of Epstein's 
guilty plea and sentence. After the SDFL agreed to accommodate your request, counsel for Epstein 
began taking issue with the methodology of compensation, notification to the victims, and the issues 
that had been previously considered and rejected during negotiations, i.e., that the conduct does not 
require registration and the contemplated state and federal statutes have no applicability to the instant 
matter. 
A. 
Delay. 
The Agreement required that "Epstein shall use his best efforts to enter his guilty plea and 
be sentenced not later than October 26, 2007. The United States has no objection to Epstein self-
reporting to begin serving his sentence not later than January 4, 2008." Agreement, pages 4-5, 
paragraph I I (emphasis added). After the Agreement was executed, the SDFL accommodated your 
request to extend the October 26th plea deadline to November 20111 based upon, what seemed to be, 
reasonable scheduling conflict issues.' By early November, you represented that the presiding state 
court judge would not "stagger the plea and sentencing as contemplated in the Agreement."Al though 
the Agreement clearly did not contemplate a staggered "plea and sentencing," the SDFL again agreed 
to accommodate Epstein's request to appear in state court for plea and sentencing on January 4, 
2008.2
I "Accordingly, I have now confirmed with Mr. Epstein's Florida counsel that the state's 
attorney's office and the court will be available to have him enter his plea on November 20. So we will 
plan to proceed on one that date." October 18, 2007 email from Jay Lefkowitz to USA R. Alexander 
Acosta. 
On the same day, Mr. Lelkowitz confirmed with First Assistant Jeffrey H. Sloman that this 
postponement " will not affect when Epstein begins serving his sentence." 
2 Correspondence from Jay Lefkowitz to FAUSA Sloman dated November 8, 2007 ("the judge 
has invited the parties to appear for the plea and sentencing on January 4th, we do not anticipate any delay 
beyond that date.") 
EFTA00225698

JAY P. LEFKOWITZ, ESQ. 
May 19, 2008 
PAGE 2 OF 6 
Background 
The Agreement was the product of months of negotiations. Specifically, you requested and 
received numerous meetings, at the highest levels of the SDFL and DOJ's Child Exploitation and 
Obscenity Section (CEOS) concerning claims that (a) the investigation merely produced evidence 
of relatively innocuous sexual conduct with some minors who, unbeknownst to Epstein, 
misrepresented their ages; (b) the authorities investigating Epstein engaged in misconduct; (c) the 
contemplated federal statutes have no applicability to this matter; and (d) the federal authorities 
disregarded the fundamental policy against federal intervention with state criminal proceedings. 
After careful review, the SDFL ultimately rejected those claims. Subsequent to its decision, however, 
but before proceeding any further, the SIMI, provided you with 30 days to appeal the decision to the 
Assistant Attorney General of the United States, Alice Fisher. As you recall, you chose to forego an 
appeal to AAG Fisher, and instead pursued a negotiated resolution which, ultimately, resulted in the 
execution of the Agreement. 
The Negotiation Phase 
During negotiations, you tried to avoid a resolution that called for incarceration and 
registration as a sexual offender — both of which would be triggered by a successful federal 
prosecution. The SDFL believed and continues to believe that should this matter proceed to trial, 
your client would be convicted of the federal statutes identified in the Agreement. In order to achieve 
a global resolution, the SDFL indicated a willingness to defer to the State the length of incarceration; 
however, it remained adamant that Epstein register as a sex offender and that all victims identified 
during the investigation remain eligible for compensation. In order to achieve this result, the parties 
considered two alternatives, a plea to federal charges that limited Epstein's sentencing exposure, or, 
as suggested by you, a plea to state charges encompassing Epstein's conduct. Ultimately, the parties 
agreed to, inter alia, a plea to the state charges outlined in the Agreement, registration and a method 
of compensation. 
The Agreement 
The crux of the Agreement defers in favor of the State federal prosecution of Epstein for his 
sexual conduct involving those minor victims identified as of September 24, 2007, in exchange for 
a guilty plea to a state offense that requires registration as a sex offender; a sufficient term of 
imprisonment; and a method of compensation for the victims such that they would be placed in the 
same position as if Epstein had been convicted of one of the enumerated offenses set forth in Title 
18, United States Code, Section 2255. Specifically, the Agreement mandates, inter alia, (1) a guilty 
plea in Palm Beach County Circuit Court to solicitation of prostitution (Fl. Stat. Section 796.07) and 
procurement of minors to engage in prostitution (Fl. Stat. Section 796.03) (an offense that requires 
him to register as a sex offender); (2) a 30-month sentence including IS months' incarceration in 
county jail; (3) a methodology to compensate the victims identified by the United States; (4) entry 
EFTA00225699

U.S. Department of Justice 
United Slates Attorney 
Southern District of Florida 
First As,ramt US Attorney 
DELIVERY BY FACSIMILE 
Jay P. Lefkowitz, Esq. 
Kirkland & Ellis LLP 
Cifigroup Center 
153 East 53rd Street 
New York, New York 10022-4675 
Re: 
Jeffrey Epstein 
Dear Mr. Lefkowitz, 
99 N.F.. a Suter 
Mw ,v. Fl. 33132 
961-9/00
May 19, 2008 
I am in receipt of your e-mail dated May 19, 2008 to the United States Attorney. The U.S. 
Attorney would like me to advisearthat all communications and inquiries related to the Epstein 
matter, will be handled by AUSA 
Villafana and/or her supervisor, Karen Atkinson, so he does 
not intend to respond to your e-mail or calls unless AUSA Villafana and/or her supervisors advise 
him otherwise. Furthermore, you make reference to "our July 8 deadline." Respectfully, the United 
States Attorney's Office for the Southern District of Florida ("SDFL") has never agreed to any such 
deadline. Should you decide to provide the SDFL with any additional information, please do so 
through AUSA Villafana, and, in her absence, AUSA Atkinson. 
On September 24, 2007, your client, Jeffrey Epstein, in consultation with Gerald Lefcourt, 
Esq. and Lilly Ann Sanchez, Esq., as well as numerous other nationally-renowned lawyers, including 
but not limited to Harvard Law Professor Alan Dershowitz, former Independent Counsel and 
Solicitor General of the United States Kenneth Starr, just to name a few, entered into a global 
resolution of state and federal liabilities faced by your client ("the Agreement') with the SDFL. 
Although you and other members of the defense team have since claimed that the Agreement was 
the product of adhesion, the following facts demonstrate that Epstein knowingly and voluntarily 
entered into the Agreement in order to avoid a federal indictment regarding his sexual conduct 
involving minor victims. Despite the fact that by signing the Agreement, Epstein gave up the right 
to object to its provisions, the SDFL bent over backwards to exhaustively consider and re-consider 
your objections. Since these objections have finally been exhausted and Epstein has previously 
expressed his intent to not comply with several of the terms and conditions of the Agreement as set 
forth below, the SIN!, hereby notifies you that unless he complies with all of the terms and 
conditions of the Agreement, as modified by the United States Attorney's December 19, 2007 letter 
to Ms. Sanchez by close of business on Monday, June 2, 2008, the SDFL will elect to terminate the 
Agreement. 
EXHIBIT B-32 
EFTA00225700

JAY P. LEFKOWITZ, ESQ. 
May 19, 2008 
PAGE 6 OF 6 
Conclusion 
On February 25, 2008, I sent you an e-mail setting forth a timetable for moving forward in 
the event that CEOS disagreed with your position. That time is now. As you know, my February 25th
email stated that I would give you one week to comply with the terms and conditions of the 
Agreement, as modified by the USA's December 19th letter to Ms. Sanchez. In light of the upcoming 
Memorial Day weekend, I have decided to extend that timetable to the close of business on Monday, 
June 2, 2008, which is a full two weeks. 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
By: 
Jeffrey H. Sloman 
First Assistant United States Attorney 
cc: 
R. Alexander Acosta 
United States Attorney 
A. 
Villafana 
Assistant U.S. Attorney 
Karen Atkinson 
Assistant U.S. Attorney 
EFTA00225701

JAY P. LEFICOWITZ, ESQ. 
May 19, 2008 
PAGE 5 OF 6 
C. 
"Mr. Epstein Does Not Believe lie Is Guilty Of The Federal Charges Enumerated 
Under Section 2255." 
At our December 14, 2007 meeting at the U.S. Attorney's Office in Miami, counsel for 
Epstein announced, inter alia, that it was a "profound injustice" to require Epstein to register as a 
sex offender and reiterated that no federal crime, especially 18 U.S.C. Section 2422(6), had been 
committed since the statute is only violated if a telephone or means of interstate commerce is used 
to do the persuading or inducing. This particular attack on this statute had been previously raised and 
thoroughly considered and rejected by the SDFL and CEOS prior to the execution of the Agreement. 
You also argued that the facts were inapplicable to the contemplated state statutes and that Epstein 
should not have been allowed to have been induced into the Agreement because the facts were not 
what he understood them to be, It should be noted that the SDFL has never provided you with any 
ii
evidence support g its investigation. This is not, and has never been, an Alford plea situation (see 
North Carolina 
Alford, 400 U.S. 25, 91 S.Ct: 160 (1970)). Ultimately, you requested an 
independent review. 
Subsequent to the above-mentioned meeting, the SDFL received three letters from you and/or 
Mr. Starr which expanded on some of the themes announced in the December 14" meeting. 
Essentially, you portrayed the SDFL as trying to coerce a plea to unknown allegations and incoherent 
theories. On December 17, 2007, you decreed that Epstein's conduct did not meet the requirements 
of solicitation of minors to engage in prostitution (Fl. Stat. Section 796.03) one of the enumerated 
crimes Epstein had previously agreed to plead guilty to; that Epstein's conduct does not require 
registration under Florida law; and the State Attorney's Office does not believe the conduct is 
registrable. On December 21, 2007, you rejected the USA's proposed resolution of the 2255 
provision because you "strongly believe that the provable conduct of Mr. Epstein with respect to 
these individuals fails to satisfy the requisite elements of either 18 U.S.C. Section[s] 2422(6) ... or 
2423(b)." In your December 26, 2007 correspondence you stated that "we have reiterated in 
previous submissions that Mr. Epstein does not believe he is guilty of the federal charges enumerated 
under section 2255" and requiring "Mr. Epstein to in essence admit guilt, though he believes he did 
not commit the requisite offense." 
As the SDFL has reiterated time and time again, it does not want, nor does it expect, Epstein 
to plead guilty to a charge he does not believe he committed. As a result, we obliged your request 
for an independent de novo review of the investigation and facilitated such a review at the highest 
levels of the Department of Justice. It is our understanding that that independent review is now 
complete and a determination has been made that there arc no impediments to a federal prosecution 
by the SDFL. 
EFTA00225702

JAY P. LEFKOWITL, ESQ. 
May 19, 2008 
PAGE 4 OF 6 
B. 
Method of Compensation and Notification. 
During this same time period, you and others, including the former Solicitor General of the 
United States Kenneth Starr, took issue with the implementation of the methodology of 
compensation (hereinafter "the 2255 provision")3 and the SDFL's intention to notify the victims 
under 18 U.S.C. Section 3771 (you objected to victims being notified of time and place of Epstein's 
state court sentencing hearing). In response, the SDFL offered, in my opinion, numerous and various 
reasonable modifications and accommodations which ultimately resulted in United States Attorney 
R. Alexander Acosta's December 19, 2007 letter to Lilly Ann Sanchez. In that letter, the United 
States Attorney tried to eliminate all concerns which, quite frankly, the SDFL was not obligated to 
address, let alone consider. He proposed the following language regarding the 2255 provision: 
"Any person, who while a minor, was a victim of a violation of an offense enumerated in 
Title 18, United States Codc, Section 2255, will have the same rights to proceed under 
Section 2255 as she would have had, if Mr. Epstein been tried federally and convicted of an 
enumerated offense. For purposes of implementing this paragraph, the United States shall 
provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in 
an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority 
interpreting this provision, including any authority determining which evidentiary burdens 
if any a plaintiff must meet, shall consider that it is the intent of the parties to place these 
identified victims in the same position as they would have been had Mr. Epstein been 
convicted at trial. No more; no less." 
Regarding the issue of notice to the victims, USA Acosta proposed to notify them of the 
federal resolution as required by law; however, "rwle will defer to the discretion of the State 
Attorney regarding whether he wishes to provide victims with notice of the state proceedings, 
although we will provide him with the information necessary to do so if he wishes." As you know, 
you rejected these proposals as well. See December 26, 2007 correspondence from Jay Lefkowitz 
to USA Acosta. 
3 Prior to any issues arising concerning the implementation of the 2255 provision, the SDFL 
unilaterally agreed to assign its responsibility to select the attorney representative for the alleged victims 
to an independent third-party. This was done to avoid even the appearance of favoritism in the selection 
of the attorney representative. As a result, on October 29, 2007, the parties executed an Addendum 
wherein it was mutually agreed that former United States District Court Judge Edward B. 
would 
serve as the independent third-party. Judge Davis selected the venerable law firm of Podhurs and 
Josefsberg to represent the approximately 34 alleged identified victims. 
EFTA00225703

JAY P. LEFKOWITZ, ESQ. 
May 19, 2008 
PAGE 3 OF 6 
of the guilty plea and sentence no later than October 26, 2007; and (5) the start of the above-
mentioned sentence no later than January 4, 2008. 
Furthermore, and significantly, Epstein agreed that he had the burden of ensuring compliance 
of the Agreement with the Palm Beach County State Attorney's Office and the Judge of the 15'h
Judicial Circuit and "that the failure to do so will be a breach of the agreement" (emphasis added). 
Post-Execution of the Agreement 
Within weeks of the execution of the Agreement, you sought to delay the entry of Epstein's 
guilty plea and sentence. After the SDFL agreed to accommodate your request, counsel for Epstein 
began taking issue with the methodology of compensation, notification to the victims, and the issues 
that had been previously considered and rejected during negotiations, i.e., that the conduct does not 
require registration and the contemplated state and federal statutes have no applicability to the instant 
matter. 
A. 
Delay. 
The Agreement required that "Epstein shall use his best efforts to enter his guilty plea and 
be sentenced not later than October 26. 2007. The United States has no objection to Epstein self-
reporting to begin serving his sentence not later than January 4, 2008." Agreement, pages 4-5, 
paragraph I 1 (emphasis added). After the Agreement was executed, the SDFL accommodated your 
request to extend the October 26th plea deadline to November 20'h based upon, what seemed to be, 
reasonable scheduling conflict issues.' By early November, you represented that the presiding state 
court judge would not "stagger the plea and sentencing as contemplated in the Agreement."Although 
the Agreement clearly did not contemplate a staggered "plea and sentencing," the SDFL again agreed 
to accommodate Epstein's request to appear in state court for plea and sentencing on January 4, 
2008.2
I "Accordingly, I have now confirmed with Mr. Epstein's Florida counsel that the state's 
attomey's office and the court will be available to have him enter his plea on November 20. So we will 
plan to proceed on one that date." October 18, 2007 email from Jay Lefkowitz to USA R. Alexander 
Acosta. 
On the same day, Mr. Lefkowitz confirmed with First Assistant Jeffrey H. Sloman that this 
postponement " will not affect when Epstein begins serving his sentence." 
2 Correspondence from Jay Lefkowitz to FAUSA Sloman dated November 8, 2007 ("the judge 
has invited the parties to appear for the plea and sentencing on January 41, we do not anticipate any delay 
beyond that date.") 
EFTA00225704

JAY P. LEFKOWIT7., ESQ. 
May 19, 2008 
PAGE 2 OF 6 
Background 
The Agreement was the product of months of negotiations. Specifically, you requested and 
received numerous meetings, at the highest levels of the SDFL and DOJ's Child Exploitation and 
Obscenity Section (CEOS) concerning claims that (a) the investigation merely produced evidence 
of relatively innocuous sexual conduct with some minors who, unbeknownst to Epstein, 
misrepresented their ages; (b) the authorities investigating Epstein engaged in misconduct; (c) the 
contemplated federal statutes have no applicability to this matter; and (d) the federal authorities 
disregarded the fundamental policy against federal intervention with state criminal proceedings. 
After careful review, the SDFL ultimately rejected those claims. Subsequent to its decision, however, 
but before proceeding any further, the SDFL provided you with 30 days to appeal the decision to the 
Assistant Attorney General of the United States, Alice Fisher. As you recall, you chose to forego an 
appeal to AAG Fisher, and instead pursued a negotiated resolution which, ultimately, resulted in the 
execution of the Agreement. 
The Negotiation Phase 
During negotiations, you tried to avoid a resolution that called for incarceration and 
registration as a sexual offender — both of which would be triggered by a successful federal 
prosecution. The SDFL believed and continues to believe that should this matter proceed to trial, 
your client would be convicted of the federal statutes identified in the Agreement. In order to achieve 
a global resolution, the SDFL indicated a willingness to defer to the State the length of incarceration; 
however, it remained adamant that Epstein register as a sex offender and that all victims identified 
during the investigation remain eligible for compensation. In order to achieve this result, the parties 
considered two alternatives, a plea to federal charges that limited Epstein's sentencing exposure, or, 
as suggested by you, a plea to state charges encompassing Epstein's conduct. Ultimately, the parties 
agreed to, inter alia, a plea to the state charges outlined in the Agreement, registration and a method 
of compensation. 
The Agreement 
The crux of the Agreement defers in favor of the State federal prosecution of Epstein for his 
sexual conduct involving those minor victims identified as of September 24, 2007, in exchange for 
a guilty plea to a state offense that requires registration as a sex offender; a sufficient term of 
imprisonment; and a method of compensation for the victims such that they would be placed in the 
same position as if Epstein had been convicted of one of the enumerated offenses set forth in Title 
18, United States Code, Section 2255. Specifically, the Agreement mandates, inter alia, (1) a guilty 
plea in Palm Beach County Circuit Court to solicitation of prostitution (Fl. Stat. Section 796.07) and 
procurement of minors to engage in prostitution (Fl. Stat. Section 796.03) (an offense that requires 
him to register as a sex offender); (2) a 30-month sentence including 18 months' incarceration in 
county jail; (3) a methodology to compensate the victims identified by the United States; (4) entry 
EFTA00225705

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
First Assistant U.S. Attorney 
DELIVERY BY FACSIMILE 
Jay P. Lefitowitz, Esq. 
Kirkland & Ellis LLP 
Citigroup Center 
153 East 53rd Street 
New York, New York 10022-4675 
Re: 
Jeffrey Epstein 
Dear Mr. Leficowitz, 
99114E. 4 Street 
Mann. FL 13132 
(305) 961.9100 
May 19, 2008 
I am in receipt of your e-mail dated May 19, 2008 to the United States Attorney. The U.S. 
Attorney would like me to advisesithat all communications and inquiries related to the Epstein 
matter, will be handled by AUSA 
Villafana and/or her supervisor, Karen Atkinson, so he does 
not intend to respond to your e-mail or calls unless AUSA Villafana and/or her supervisors advise 
him otherwise. Furthermore, you make reference to "our July 8 deadline." Respectfully, the United 
States Attorney's Office for the Southern District of Florida ("SDFL") has never agreed to any such 
deadline. Should you decide to provide the SDFL with any additional information, please do so 
through AUSA Villafana, and, in her absence, AUSA Atkinson. 
On September 24, 2007, your client, Jeffrey Epstein, in consultation with Gerald Lefcourt, 
Esq. and Lilly Ann Sanchez, Esq., as well as numerous other nationally-renowned lawyers, including 
but not limited to Harvard Law Professor Alan Dershowitz, former Independent Counsel and 
Solicitor General of the United States Kenneth Starr, just to name a few, entered into a global 
resolution of state and federal liabilities faced by your client ("the Agreement") with the SDFL. 
Although you and other members of the defense team have since claimed that the Agreement was 
the product of adhesion, the following facts demonstrate that Epstein knowingly and voluntarily 
entered into the Agreement in order to avoid a federal indictment regarding his sexual conduct 
involving minor victims. Despite the fact that by signing the Agreement, Epstein gave up the right 
to object to its provisions, the SDFL bent over backwards to exhaustively consider and re-consider 
your objections. Since these objections have finally been exhausted and Epstein has previously 
expressed his intent to not comply with several of the terms and conditions of the Agreement as set 
forth below, the SDFL hereby notifies you that unless he complies with all of the terms and 
conditions of the Agreement, as modified by the United States Attorney's December 19, 2007 letter 
to Ms. Sanchez by close of business on Monday, June 2, 2008, the SDFL will elect to terminate the 
Agreement. 
EXHIBIT B-32 
EFTA00225706

FD-302 (Rev. 10495) 
-1-
FEDERAL BUREAU OF INVESTIGATION 
Date of transcription 
10/04/2007
LANE RIVERA, date of birth 06/17/1988, Social 
Security Accoun Number 593-70-9393, telephone number (561)689-
4717, was contacted telephonically regarding a federal 
investigation involving the sexual exploitation of minors. After 
being advised of the identity of the interviewing agent and the 
nature of the interview, RIVERA stated that she would not provide 
any info 
' 
regarding JEFFREY EPSTEIN. The interviewing agent 
provided 
with FBI contact information. RIVERA was informed 
to contac t e BI should she decide to cooperate with authorities. 
It should be noted that RIVERA had an active warrant with 
the State of Florida for failure to appear regarding an arrest for 
shoplifting. 
Investigation on 
 10/02/2007 
 at  West Palm Beach, Florida 
(telephonically) 
Aka 31E-MM-108062 
by 
SA E. Nesbitt Kuyrkendall 
Date dictated 
10/02/2007 
This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; 
it and its contents are not to be distributed outside your *racy 
CAN No 011-110716CV.MARRA 
P.012645 
EFTA00225707

FD•302a (Rev 10.6-931 
31E-MM-108062 
Comirusion of FD•302 of 
hair. 
hair. 
Molls/ Smythe 
.On  06/12/2001  .Pagc  
3 
described one of the UWFs as tan with long brown 
er UWF was described as having short, bobbed, blonde 
said that both UWFs spoke with an accent. 
SMYTHE believed that an individual named STEPHANIE LNU, 
who is FIGUEROA's age, also provided 
believed she drove a Jeep Cherokee. 
female shay 
have provided 
name was 
drug over 
EPSTEIN told 
with massages. She 
knew of only one other 
N with massages. Her 
She was a student at RPBHS who died of a 
that he was a scientist. 
Case No 08-607M,CV•MARR 
EFTA00225708

FD-302a (Rev. 10-645) 
31E-MM-108062 
Continuation of FD-302 or 
Moll, Smythe 
On  06/12/2007  .Par  
2 
he responded by telling her to relax. 
EPSTEIN told 
ral 
times to ref 
STEIN also insinuated that he wan 
to 
touch him. 
stated that she believed EPSTEIN wante 
o 
do more than u 
massage him. She said that EPSTEIN propositioned 
her when he told her that she would get more money if she did more. 
She understood that to 
x. SMYTHE viewed EPSTEIN climax and 
the massa 
over. 
believed EPSTEIN got up and took a 
shower. 
did not 
de EPSTEIN with any further massages 
because s e i not want to be put in that position again. 
was unsure who paid her 
I
for providing 
TEIN with the massage. 
0.00 she received 
hat FIGUEROA 
was also paid $200.00. This was the only 
provided 
EPSTEIN with a massage. After departing the re 
, FIGUEROA 
stated that she coul 
ore money if she was willing to do 
ording to 
ke of an exgirlfriend, 
dentified 
who had gone to EPSTEIN's 
rest 
many occasions. 
said that was the reas 
that 
had so much money and was able to support him. 
state 
a 
0BERTS had a nice apartment and nice clothes. 
believed ROBERTS had sex with EPSTEIN. 
and 
IIIIIII 
den i ie as 
oo 
er shirt off w en prove ing P 
she might have to do the same. She told 
age she should say she was eighteen and t 
back she co 
eive more money. FIGUEROA and 
pool while 
massage. 
received for 
friend, 
at she 
e mas age and that 
that if asked her 
called 
sat by the 
went upstairs to provide EPSTEI wi i the 
receiIIIIIII.00 from FIGUEROA's $200.00 he 
ringing
to EPSTEIN. 
went to ROYAL PALM BEACH HIGH 
complet 
grade and a few classes during 
year. 
was unable to recall her exac 
provide 
IN with a massage. However, 
vided EPSTEIN with a massage shortly e 
about massaging EPSTEIN. 
III 
left her jewelry on a bench at EPSTEIN's residence 
during one o 
er visits to the EPSTEIN residence. She and 
FIGUEROA returned to the residence to retrieve her jewelry. 
SCHOOL where she 
her eleventh grade 
t the time she 
ore 
recalled that she 
ore she approached 
Cast No 01407364N.MARRA 
P-012644 
EFTA00225709

FD-302 (Rev. 10-645) 
-t-
FEDERAL BUREAU OF INVESTIGATION 
Dale or vansalPhon 
06/12/2007
regarding 
of minors. 
agent and 
following 
MOLLY 
was interviewed in West Palm Beach, Florida, 
a fede 
investigation involving the sexual exploitation 
After being advised of the Mr
 of the interviewing 
the nature of the interview, 
provided the 
information: 
was introduced to JEFFREY E 
by a friend of 
hers, "TON 
tified as TONY FIGUEROA). 
stated that she 
knew FIGUEROA through her neighbors. She ha 
nown FIGUEROA for 
about a year when he said that she could make some easy 
providing a massage to a guy who lived in Palm Beach. 
said 
that FIGUEROA used the name "JEFFREY". She was aware o 
IN's 
last name only because she saw it in a Vanity Fair magazine she was 
looking at on 
and visit to Epstein's Palm Beach residence. 
FIGUEROA told 
that she would make $200.00 for providing the 
massage. He a s 
d her if asked her age she was to say she was 
eighteen. 
Prior to going to the residence with FIGUEROA, 
that she had "smoked weed" with FIGUEROA to calm her own. 
said that during that time in her life she believed she was 
so using Cocaine and Ecstasy. Once at the residence, EPSTEIN 
walked her through the house and upstairs to the spa/bathroom. One 
of two Unidentified White Females(UWFs).she had met previously 
downstairs was upstairs preparing the room for the massage. The 
UWF, who was topless, set ou 
lotions to be used during the 
massag 
UWF "coached" 
and had her remove her shirt and 
bra. 
was very nervous an 
ensed 
he UWF started to 
perform 
e massage on EPSTEIN. Later, 
began providing 
EPSTEIN with the massage and the UWF lef 
e room. 
EP 
egan the massage by lying on his stomach and 
instructing 
to perform the massag 
r and lower down on 
his back. 
o 
point, EPSTEIN asked 
to t 
his 
towel. After a short time EPSTEIN turne o r and 
continued 
the massage. EPSTEIN soon began to mas 
while 
E was 
performing the massage. Epstein asked 
if she 
rvous 
because she did not watch him while he mas ur ated. 
said 
that 
told 
breas s. 
IIIIIII 
feeling uncomfortable. During the massage, 
STEIN 
she had nice shaped breasts. EPSTEIN fondled her 
told EPSTEIN again that she was uncomfortable and 
maminmomml  06/12/2007 
 at  West Palm Beach, Florida 
Filer 31E-MM-108062 
SA E.1Ntsbitt Kuyrkendall 
by 
SA Jason R. Richards 
Date dictated 06/12/2007 
This document contains neither rceonunendations nor conclusions of the FBI. It is the properly of the FBI and is loaned to your agency; 
it and its contents are not to be distributed outside your aaencv. 
Cu No 0840716,CV•MARRA 
P.012641 
EFTA00225710

FD-302 (Rev. 104-95) 
FEDERAL BUREAU OF INVESTIGATION 
Om 
trainctwoon 
10/04/2007
AMANDA BJORKLAND FREELING, date of birth 08/22/1987, 
Social Security Account Number 594-56-7772, cellular telephone 
number ( 
FREELING's father, MARK LNU's telephone 
number ( 
was interviewed telephonically regarding a 
federal i 
n involving the sexual exploitation of minors. 
After being advised of the identity of the interviewing agent and 
the nature of the interview, FREELING provided the 
following information: 
FREELING currently resides with her husband, BRAD 
FREELING, at GROTON NAVY BASE located in Connecticut. The 
interviewing agent inquired if FREELING was able to speak freely 
over the phone with her husband in the car with her. FREELING 
stated she was fine. When FREELING was asked about JEFFREY 
EPSTEIN, she told the interviewing agent that she believed she knew 
an EPSTEIN that had been a math teacher in the middle school she 
had attended. FREELING stated that she could not recall traveling 
with her friend ALEX HALL to EPSTEIN's Palm Beach residence. 
FREELING stated that she could not recall providing EPSTEIN with a 
massage. She asked the interviewing agent if she could take some 
time to think about it. At this time, FREELING was advised that 
she was not in any trouble but that she needed to be completely 
honest with the interviewing agent. FREELING stated that she was 
unable to remember any details regarding a JEFFREY EPSTEIN that 
resided in Palm Beach. 
The interview was concluded. 
Investigation on 
 10/02/2007 
at Groton Base, Connecticut 
ifts 31E-MM-108062 
by 
SA E. Nesbitt Kuyrkendall 
Date dictated 
10/02/2007 
This document contains neither recommendations nor conclusions of the FBI It is the progeny of the FBI and is loaned to your agency: 
it and its contents are not to be distributed outside your agency. 
Case No 08 SO lo ( 
ARR A 
P.012642 
EFTA00225711