EFTA00230494

Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 40 of 42 
CERTIFICATE OP CONFERENCE 
As recounted above, counsel for Jane Doe #1 and Jane Doe #2 have approached the U.S. 
Attorney's Office for more than two and a half years in an effort to reach stipulated facts. The 
U.S. Attorney's Office ultimately terminated those efforts on March 15, 2011, taking the position 
that the facts of the case are irrelevant and that, on any set of facts, It did not violate the CVRA. 
CONCLUSION 
For all the foregoing reasons, the Court should find the U.S. Attorney's Office violated 
Jane Doe #1 and Jane Doe #2's rights under the Crime Victims Rights Act and then schedule an 
appropriate hearing on the remedy for these violations. The scope of the remedy that is 
appropriate may depend in part of the scope of the violations that the Court finds. For this 
reason, it makes sense for the Court to bifincate the process and determine, first, the extent of the 
violations and then, second, the remedy appropriate for those violations. If the Court would 
prefer to see more immediate briefing on remedy issues, the victims stand prepared to provide 
that briefing at the Court's direction. 
difficulties if as the [DIFi&ancescoj Court explained .. . the defendant is 'charged 
with knowledge of the statute and its 
. provisions, and has no expectation of 
finality in his sentence until the [review by writ] is concluded .. .."' 
LAFAVE ET AL., CRIMINAL Procedure § 26.7(b) (Nov. 2010) (quoting United States 
Dihancesco, 449 U.S. 117, 146 (1980)). 
40 
08-80736-CV-MARRA 
000710 
EFTA00230534

• • 
. 
Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 03/2 1/201 1 Page 41 of 42 
DATED: Much 21.2011 
Respectfully Submitted, 
s/ Bradley J. Edwards 
Bradley J. Edwards 
FARMER, JAFFE, WEISSIN0, 
EDWARDS, FISTOS & LEHRMAN, P.L. 
425 North Andrews Avenue, Smite 2 
Fort Lauderdale, Florida 33301 
Telephone (954) 524-2820 
Facsimile (954) 524-2822 
Florida Bar No.: 542075 
E-mail: brad®pathtojustice.com 
and 
Paul G. Cassell 
Pro MX Vice 
S.J. Quinnoy College of Law at the 
University of Utah 
332 S. 1400 E. 
Salt Lake City, UT 84112 
Telephone: 801-585-5202 
Facsimile: 801-585-6833 
E-Mail: cassellAtaw.tibah.edtt
Attorneys for Jane Doe #1 and Jane Doe 42 
41 
08-80736-CV-MARRA 
000711 
EFTA00230535

Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 42 of 42 
CERTIFICATE OF SERVICE 
The foregoing document was served on March 21, 2011, on the following using the Court's 
CM/ECF system: 
A. Marie Villefafla 
Assistant U.S. Attorney 
500 S. Australian Ave., Suite 400 
West Palm Beach, FL 33401 
(561)820-8711 
Fax: (561) 820-8777 
E-mail: gartmarie.c.viltafana(gusdoj.gov 
Attorney for the Government 
Joseph L. Ackerman, Jr. 
Joseph Ackerman, Jr. 
Fowler White Burnett PA 
777 S. Flagler Drive, West Tower, Suite 901 
West Palm Beach, FL 33401 
Criminal Defense Counsel for Jeffrey Epstein 
(courtesy copy of pleading via U.S. mail) 
42 
08-80736-CV-MARRA 
000712 
EFTA00230536

1 
Case 9:08-cv-80736-KAM Document 48-2 Entered on FLSD Docket 03/21/2011 Page 1 of 6 
JANE DOE NI AND JANE DOE /WS MOTION FOR FINDING OF VIOLATIONS OF THE 
CRIME VICTIMS' RIGHTS ACT AN)) REQUEST FOR A HEARING ON APPROPRIATE 
REMEDIES 
CASE NO: 08-80736-Civ-Marra/Johnson 
EXHIBIT B 
08-80736-CV-MARRA 
000713 
EFTA00230537

• 
Case 9:08-cv-80736-KAM Document 48-2 Entered on FLSD Docket 03/21/2011 Page 2 of 6 
FD-302 (ar. 10-6.95) 
.1 -
math BUREAU OF INVESTIGATION 
Due of trancnPuon 
08/14/2007
Florida, rjligIll
eral investigation involving the sexual 
a
as interviewed in West Palm Beach,
ir 
exploitation of minors. After being advised of the identity of.the 
interviewing agents and the nature of the interview, t 
provided 
the following information: 
' 
In 2003 or 20D4 Warms introduced to JEFFREY EPSTEIN 
for the purpose of providing im with personal massages. cg, was 
approached at a party by a female she believed was named 
ISE. 
She described the female as havin 
r 
hair and taller. The 
female was later identified as 
. SS 
told 
Weilland la's friend, mils mos, that they could make money by 
providing massages to EPSTEIN. gellIMSP told lam that she could 
provide the massages with her clothes on or off. WS, who was 
fifteen years old, believed that she was close to turning sixteen 
when she first met EPSTEIN. However, during Wilpis first contact 
with EPSTEIN, she told him that she had just turned eighteen. 
and Willi traveled to EPSTEIN's residence in Palm 
Beach by taxi. 
way_pregnant at the time. Once at the 
residence, age took Willi,Upstairs. EPSTEIN entered the room 
wearin only a ro . Once EPSTEIN had removed the robe, both 
and WIlleprovided EPSTEIN with a massage. Both ANIMINP 
and Wiellhad removed their clothing and remained only in their 
underwear. EPSTEIN asked ato 
leave. Once alone with Wilik 
EPSTEIN began to masturbate. WillIlwas uncomfortable. 
After 
EPSTEIN climaxed the massage was over. WOW believed that Sib 
had mentioned EPSTEIN might masturbate during the massage but she 
was still very surprised when he masturbated. EPSTEIN paid Wall 
$200.00. EPSTEIN did not touch'flduring that massage. WIMP 
departed EPSTEIN's residence with two men that worked for EPSTEIN. 
They drove WIEMPto a Shell Cap Station located near Okeechobee 
Boulevard and the Florida Turnpike. 
Prior to departing the residence, wileprovided her 
telephone number to one of EPSTEIN's assistants, OMMINIMOW 
(PHONETIC) . 
Wdedescribed her as a very pretty Hispanic female in 
her early twenties, with long brown hair, and approximately 5'5" to 
5'6" tall. WAIMOstated that SARAH KELLEN, another of EPSTEIN's 
assistants, or EPSTEIN would usually contact her. KELLEN would 
telephone and ask if she was available or if she had any other 
ufluiscioeut,  08/07/2007 
 a  West Palm Beach, Florida 
Filet 31E-MM-108062 
Damaimmo 08/07/2007 
SA E. Nesbitt Kuyrkendali 
by 
SA Jason R. Richards 
Ibis document *Wants neither recommendations tor °menials of the FBI. It is the prorgny of ,hr FBI and is loaned to Now sync). 
it and its IX/Malts OH not to be distributed outside your agency. 
08-80736-CV-MARRA 
000714 
EFTA00230538

ettx4fOOOV4.. 
Case 9:08-cv-80736-KAM Document 48-2 
Entered on FLSD Docket 03/21/2011 Page 3 of 6 
, 
FD-302. (Rn. IC-6.95) 
31E-n4-108062 
Canon of FD•302 of 
a
 1. 
.on  08/07/2007 
 .Ptic  
2 
x. 
1 
girls she could bring; When EPSTEIN telephoned, he usually asked 
for Pato 
come over. According to WSW EPSTEIN's house 
telephone number began with the di its 655. She would call 
sometimes and leave a message. WINIstated that when they 
telephoned her they would inform her of when they would be coming 
back to town and if she might have anyone new. WIMMadid not 
believe that EPSTEIN ever really liked her. 
Wfl traveled to the EPSTEIN's residence during 2003 and 
2004 over twenty five times. WAIllobelieved that she provided 
EPSTEIN with approximately 10-15 massages. EPSTEIN initially 
started out touching MEMO breasts but gradually the massages 
became more sexual. EPSTEIN would instruct WIMMOon how and what to 
do during the massages. He would request WOMMOto rub his chest and 
nipples. WOMOOstated that on approximately two occasions, EPSTEIN 
asked that WS remove her underwear and provide the massage nude. 
WOMMOcomplied. WOMMIstated that EPSTEIN would make her feel that 
she had the option to do what she wanted. 
During one massage. WOMOstated that she had been.givi1.g 
EPSTEIN a massage for approximately 30-40 minutes when instead of 
EPSTEIN turning over to masturbate, EPSTEIN brought another female 
into the massage area. illOWdescribed the female as a beautiful 
blonde girl, a "Cameron Diaz° type. 19 years of age, bright blue 
eyes, and speaking with an accent. EPSTEIN had Wile straddle the 
female on the massage table. EPSTEIN wanted Walito touch the 
females breast. According to we, EPSTEIN "pleasured" the female 
while Wailawas straddled on top of the female. 
Vi 
stated she 
could hear what she believed to be a vibrator. WIllasaid for 
EPSTEIN it was all about pleasuring the female. After the female 
climaxed, EPSTEIN patted I 
on the shoulder and she removed 
herself from the table. The female got up from the table and went 
into the spa/sauna. EPSTEIN commented to willothat in a few 
minutes the female would realize what had just happened to her. 
Wilftreceived $200.00. 
WOMMIadvised the interviewing agents that EPSTEIN had 
used a back massager on her vagina. EPSTEIN asked her first if he 
could use the massager on her. h. 
stated that she had held her 
breath when EPSTEIN used the back massager on her. Wiestated 
that at no time during any of the massages had EPSTEIN caused her 
to climax. 
During another massage, samobelieved by this time she 
was seventeen, EPSTEIN placed his hand on willip vagina, touching 
08-80736-CV-MARRA 
000715 
EFTA00230539

Case 9:08-cv-80736-KAM Document 48-2 Entered on FLSD Docket 03/21/2011 Page 4 of 6 
DIC2a ()Icy I 6.6-95) 
37.E-MM-208062 
Cownatation of FD-)02 or 
.On  08/07/2007 
 "me  
3 
Align clitoris. WillOwas uncomfortable and told him to stop. 
EPSTEIN complied. WOMOstated that the incident freaked her out. 
, 
willpstated that EPSTEIN was upset because she was upset. Was 
never return to the residence. Winistated that she did not deal 
with EPSTEIN anymore after that incident. 
EPSTEIN gave both ampand MMOMOMPeach a book entitled 
"Massage for Dummies". 
They received the books on the same visit. 
EPSTEIN also commented how strong Ins hands were when it came to 
her providing his massages. 
On another occasion, WOMOOmentioned to EPSTEIN that she 
was looking at a car, a Toyota Corolla. EPSTEIN provided V 
- with 
$600.00 - $700.00. NOMMstated that EPSTEIN gave her the money 
after the incident with the other female. 
According to Willi EPSTEIN would ask her to bring him 
other girls. Imp who started dancing at strip clubs when she was 
16, brought girls from the club as well as from other sources. 
WILD stated she brought girls from fifteen years of age to twenty-
five years of age. l 
stated that EPSTEIN would get frustrated 
with„her if she did not have new females for him. On one instance, 
EPSTEIN hung is on her because she could not provide him with 
anyone new. Willostated that EPSTEIN's preference was short, 
little, white girls. Willestated that EPSTEIN was upset when one 
of the other girls brought a black girl. WIMMOstated that EPSTEIN 
did not want black girls or girls with tatoos. 
Oilleatated that one of the girls she stayed with on 
occasion,
 also started providing EPSTEIN with 
massages. A telephone number for awas 
minummomp. Holm 
said that her family resides in 
, Florida, possibly 
WIMMOalso stayed with 
during this same 
time period. However,
 never went to EPSTEIN's house or 
provided him with massages. isillithas a Yacht Club address. 
Another girl that Wallehad taken to EPSTEIN's residence 
was LOMMUNOLast Name Unknown(LNU). According to Sall EPSTEIN 
liked LOIMMOOLNU a lot. Milesaid that she was never a favorite of 
EPSTEIN. EPSTEIN offered WIMID$300.00 to brirlsplIMMUMOLNu. 
LNU was a couple years younger than Pa 
W 
believed that she 
was either 16 or 17 when she first went to EPSTEIN's residence. 
NINNWsaid that LIIIMMILNU went 2-3 times but that she did not want 
any part of it after that. Willi believes she could identify la 
LNU if she saw her photograph. Waft also stated that LAIIIIIrLAu at 
08-80736-CV-MARRA 
000716 
EFTA00230540

. 
7 -ire,: 
Case 9:08-cv-80736-KAM Document 48-2 
Entered on FLSD Docket 03/21/2011 Page 5 of 6 
. PD•Xr2a (Rev. 10-6-951 
31E-MM-108062 
CaminuabondRYX0of 
a
 all 
.0n08/07/2007  .Par 
4 
one time attended 
HIGH SCHOOL. WIMMWalso 
believed that they had met through a group of friends while 
attending 
- a dropout prevention school. 
WOMIPmentioned another girl by the name of c_
imps EPSTEIN distinguished the two warn, 
by referring to 
IMINIMPas 
alla 
worked at an ice cream 
shop. WAMOstated that she did not like I.110111 and that Jamminsr 
was a storyteller and a bad liar. WIMMOstated that enever 
really wanted to go to EPSTEIN's residence but she went anyway. 
WOOMPsaid that she had not taken a good look at EPSTEIN'S 
penis. wOOM0explained that it seemed like he would always try and 
hide his penis. Wis stated that EPSTEIN never asked her for sex. 
WOMMOstarted dancing when she was sixteen at 
immOMMOM, The owner, OS 
let her dance. WISMOhas also 
worked at fa 
located pr - 
Nin Boynton 
Beach, Florida. 
WOMOlused illegal drugs during the years she provided 
EPSTEIN with massages. wegolosiAid that EPSTEIN tried to provide her 
with advice regarding controlled substances. 
—stated that she met with EPSTEIN's attorneys, sow 
ROMMMOMpand a unidentified female(UF), at the ALE HOUSE RESTAURANT. 
willopmet with them after she contacted KELLEN, who confirmed that 
they were really working for EPSTEIN. Willipstaced that KELLEN also 
balked of her twin boys and stated that she was living in 
Manhattan. WMOMPfound out that Sand 
the OF are employed by 
 
 
They asked a lot of questions. They 
specifically asked about LIMO and a GlIMILNU. KMONereiterated 
her dislike for a 
WIIIMPalso informed the interviewing agents that she had 
spoken to Moshe 
believed before the fourth of July. M 
told wilimpthat she had met with investigators and that they had 
videoed her. 
numbers: 
Welleconfirmed her association to the following telephone 
Old cellular number - (561) 
Possibly an old cellular number - (561) 
as 
telephone number - (561)11111.111.5
08-80736-CV-MARRA 
000717 
EFTA00230541

twerr 
--- 7 ' 
• 
Case 9:08-cv-80736-KAM Document 48-2 Entered on FLSD Docket 03/21/2011 Page 6 of 6 
FT). 302. (Rev 10-6-95) 
31E-MM-108062 
Con0nnanon of PD-302 of 
C
le-- 
.On  08/07/2007  .flw  
S 
• 
• 
I 
• 
' 
• 
08-80736-CV-MARRA 
000718 
EFTA00230542

4 
cmuai 
Cif/X4441, 4.1-..,% 
• 
--- 1 
Case 9:08-cv-80736-KAM Document 48-3 Entered on FLSD Docket 03/21/2011 Page 1 of 3 
JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF THE 
CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE 
REMEDIES 
CASE NO: 08-80736-av-Marra/Johtuon 
EXHIBIT C 
08-80736-CV-MARRA 
000719 
EFTA00230543

07/09/2008 15:13 FAX 5818059848 
115110 WPB CONFRM 
Case 8:08-Cv-80736-KAM •ument 48-3 
Entered on FLSD Diie1 03/21/ 
U.S. Department of Justice 
United Slates Attorney 
Southern District of Florida 
SOO South Australian Ave.. Suite 400 
West Palm Beach. FL 3)401 
(561)820-8711 
Facsimile- (361)820-8777 
June 7, 2007 
PELIVERI 8Y,$AND 
Miss eateal 
Re: 
Crime Victims' and Witnesses' jghts 
Dear Miss WIN 
Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense, 
you have a number of rights. Those rights are: 
(I) 
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 cnme 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 righi to proceedings free from unreasonable delay. 
(8) 
The right to be treated with fairness and with respect for the victim's dignity and 
privacy 
li 
• 
Members of the U.S. Department of Justice and other federal investigative agencies, 
including the Federal Bureau of Investigation, must use their best efforts to make sure that these 
rights are protected. If you have any concerns in this regard, please feel free to contact me at 561 
209-1047, or Special Agent Nesbitt Kuyrkendall from•the Federal Bureau of Investigation at 561 
822-5946. You a:so- can contact the Justice Department's Office for Victims of Crime in 
Washington, D.C. at 202-307-5983. That Office has a website at www.ovc.gov. 
You can seek.che advice of an attorney with respect to the right's listed above and, if you 
believe that the rights set forth above are being violated, you have the right to petition the Court for 
relief. 
ii)022 
08-80736-CV-MARRA 
000720 
EFTA00230544

07/09/2008 15:14 FAX 5618059846 
US40 WPB COMPRI 
Case 9:08-cv-80736-KAM fitment 48-3 
Entered on F LSD Dart 03/21/2011 Page 3 of.3 
Mess Stab 
_limn 7. 2007 
PAGE 2 
In addition to these rights, you are entitled to counseling and medical services, and protection 
from intimidation and harassment. If the Court determines that you arc a victim, you also may be 
entitled to restitution from the perpetrator. A list of counseling and medical service providers can 
be provided to you, if you so desire. If. you or your family is subjected to any intimidation or 
harassment, please contact Special Agent Kuyrkendall or myself immediately. It is possible that 
someone working on behalf of the targets of the investigation may contact you. Such cdntact does 
not violas4e law?. However, if you are contacted, you have the choice of speaking to that person 
or refusing tett° do: If you refuse and feel that you arc being threatened or harassed, then please 
. . contact Special Agent Kuyrkendall or myself. 
You also are entitled to notification of upcoming ease events. At this time, your case is under 
investigation) If anyone is charged in connection with the investigation, you will be notified. 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
By: 
cc: 
Special Agent Nesbitt ICuydrendall, 
A. Marie Villafana 
Assistant United States Attorney 
08-80736-CV-MARRA 
000721 
EFTA00230545

- 
Case 9:08-cv-80736-KAM Document 48-4 
Entered on FLSD Docket 03/21/2011 Page 1 of 3 
JANE DOE 01 AND JANE DOE NI MOTION FOR FINDING OF VIOLATIONS OF THE 
CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE 
REMEDIES 
C4SE NO: 08-80736-Clv-Marra/Johnson 
EXHIBIT D 
08-80736-CV-MARRA 
000722 
EFTA00230546

-
-
•
 
07/09/2008 15:14 FAX 5018059848 
USAO WPB CONFRN 
Case 9:08-cv-80736-KAM Viument 48-4 
Entered on FLSD DOet 03/21/ 
U.S. Department of Justice 
United States Attorney 
Southern District of Ronda 
500 South Australian Are., Suite 000 
West Palen Beach. FL 33401 
(560 870-871 
Facsimile: (561)820-8777 
August 11, 2006 
DELIVERY BY HAND 
Miss TOMS 
Re: 
Crime Victims' and Witnesses' Rights 
Dear Miss Mats 
Pursuant to the Justice for All Act of 2004, as a victim and/or witness Ma federal offense, 
you have a number of rights. Those rights are: 
(I) 
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 arc 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 fell 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. 
Members of the U.S. DepartMent of Justice and other fedond investigative agencies, 
including the Federal Bureau of Investigation, must use their best efforts to make sure that these 
rights are protected. If you have any concerns in this regard, please feel free to contact me at 561 
209-1047, or Special Agent Nesbitt Kuyrkcndall from the Federal Bureau of Investigation at 561 
822-5946. 
You also can contact the Justice Department's Office for Victims of Crime in 
Washington, D.C. at 202-307-5983. That Office has a website at www.ovc.gov. 
You can seek the advice of an attorney with respect to the rightalisted above and, if you 
believe that the rights set forth above are being violated, you have the right to petition the Court for 
relief. 
024 
08-80736-CV-MARRA 
000723 
EFTA00230547

• 
07/09/2008 15:14 FAX 5618059846 
119A0 WPB CONFRM 
025 
Case 9:08-cv-80736-KAM fitment 484 Entered on FLSD Duet 03/21/2011 Page 3 of 3 
MISS Men 
AUGUST 11, 2006 
PAGE 2 
In addition to these nghts, you are entitled to counseling arid medical services, and pr of 
• 
from intimidation and harassment. If the Court determines that you arc a victim, you afiro t 
# 
entitled to restitution from the perpetrator. A list of counseling and medical service pm% ilk 
be provided to you, if you so desire. If you or your family is subjected to any Ultimo: 
•
harassment, please contact Special Agent Kuyrkendall or myself immediately. It is rier,•ri 
someone working on behalf of the targets of the investigation may contact you. Such cuill 
. 
not violate the law. However, if you are contacted, you have the choice of speaking to dui tj 
or refusing to do so. If you refuse and feel that you are being threatened or harassed, the:; ri • 
iontact Special Agent Kuyrkendall or myself. 
You also are entitled to notification of upcoming case events. At this time, your c. .-
investigation. If anyone is charged in connection with the investigation, you will he no', 
By: 
cc: 
Special Agent Nesbitt Kuyrkendall, F.B.I. 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
A. Marie Villafafia 
Assistant United States Attorney 
f f 
08-80736-CV-MARRA 
000724 
EFTA00230548

Case 9:08-cv-80736-KAM Document 48-5 Entered on FLSD Docket 03/21/2011 Page 1 of 15 
JANE DOE #1 AND JANE DOE n'S MOTION FOR FINDING OF VIOLATIONS OF THE 
CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE 
REMEDIES 
CASE NO: 0840736CIv-Marra/Jobaien 
EXHIBIT E 
08-80736-CV-MARRA 
000725 
EFTA00230549

Case 9:08-cv-80,736-KAM Document 48-5 
Entered on FLSD Docket 03/21/2011 Page 2 of 15 
' 
IN RE: 
INVESTIGATION OF 
JEFFREY EPSTEIN 
I 
NON-PROSECUTION AGREEMENT 
IT APPEARING that the City of Palm Beach Police Department and the State 
Attorney's Office for the 15th Judicial Circuit in and for Palm Beach County (tereinaRer, 
the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey 
Epstein (hereinafter "Epstein"); 
IT APPEARING that the State Attorney's Of fice has charged Epstein by indictment 
with solicitation of prostitution, in violation of Florida Statutes Section 796.07; 
IT APPEARING that the United States Attorney's Office and the Federal Bureau of 
Investigation have conducted their own investigation into Epstein's background and any 
offenses that may have been committed by Epstein against the United States from in or 
around 2001 through in or around September 2007, including: 
(1) 
knowingly and willfully conspiring with others known and unknown to 
commit an offense against the United States, that is, to use a facility or means 
of interstate or foreign commerce to knowingly persuade, induce, or entice 
minor females to engage in prostitution, in violation of Title IS, United States 
Code, Section 2422(b); all in violation ofTitle 18, United States Code, Section 
371; 
(2) 
knowingly and willfully conspiring with others known and unknown to travel 
in interstate commerce for the purpose of engaging in illicit sexual conduct, as 
defined in IS U.S.C. § 2423(0, with minor females, in violation of Title 18, 
United States Code, Section 2423(b); all in violation of Title 18, United States 
Code, Section 2423(e); 
(3) 
using a facility or means of interstate or foreign commerce to knowingly 
persuade, induce, or entice minor females to engage in prostitution; in 
violation of Title 18, United States Code, Sections 2422(b) and 2; 
(4) 
traveling in interstate commerce for the purpose of engaging in illicit sexual 
conduct, as defined in 18 U.S.C. § 2423(1), with minor females; in violation 
Page 1 of 7 
0S-80736-CV-MARRA 
000726 
EFTA00230550

• . 
0;04 7 --- 7 --- 
----- . 
Case 9:08-cv-80736-KAM Document 48-5 Entered on FLSD Docket 03/21/2011 Page 3 of 15 
of Title 18, United States Code, Section 2423(b); and 
(5) 
knowingly, in and affecting interstate and foreign commerce, recruiting, 
enticing, and obtaining by any means a person, knowing that the person had 
not attained the age of 18 years and would be caused to engage in a 
commercial sex act as defined in 18 U.S.C. § 1591(cXl); in violation of Title 
18, United States Code, Sections 1591(a)(1) and 2; and 
IT APPEARING that Epstein seeks to resolve globally his state and federal criminal 
liability and Epstein understands and acknowledges that, in exchange for the benefits 
provided by this agreement, he agrees to comply with its terms, including undertaking certain 
actions with the State Attorney's Office; 
IT APPEARING, after an investigation of the offenses and Epstein's background by 
both State and Federal law enforcement agencies, and after due consultation with the State 
Attorney's Office, that the interests of the United States, the State of Florida, and the 
Defendant will be saved by the following procedure; 
THEREFORE, on the authority of IL Alexander Acosta, United States Attorney for 
the Southern District of Florida, prosecution in this District for these offenses shall be 
deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the 
following conditions and the requirements of this Agreement set forth below, 
If the United States Attorney should detennine, based on reliable evidence, that, 
during the period of the Agreement, Epstein willfully violated any of the conditions of this 
Agreement, then the United States Attorney may, within ninety (90) days following the 
expiration of the term of home confinement discussed below, provide Epstein with timely 
notice specifying the condition(s) of the Agreement that he has violated, and shall initiate its 
prosecution on any offense within sixty (60) days' of giving notice of the violation. Any 
notice provided to Epstein pursuant to this paragraph shall be provided within 60 days of the 
United States learning of facts which may provide a basis for a determination of a breach of 
the Agreement. 
After timely fulfilling all the terms and conditions of the Agreement, no prosecution 
for the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have 
been the subject of the joint investigation by the Federal Bureau of Investigation and the 
United States Attorney's Office, nor any offenses that arose from the Federal Grand Jury 
investigation will be instituted in this District, and the charges against Epstein if any, will be 
dismissed. 
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Terms of the Agreement 
t. 
Epstein shall plead guilty (not nob contendere) to the Indictment as 
currently pending against him in the 15th Judicial Circuit in and for 
Palm Beach County (Case No. 2006-cf-009495A)OO(MB) charging 
one (I) count of solicitation of prostitution, in violation of Fl. Stat. § 
796.07. In addition, Epstein shall plead guilty to an Information filed 
by the State Attorney's Office charging Epstein with an offense that 
requires him to register as a sex offender, that is, the solicitation of 
minors to engage in prostitution, in violation of Florida Statutes Section 
796.03; 
2. 
Epstein shall make a binding recommendation that the Court impose a 
thirty (30) month sentence to be divided as follows; 
(a) 
(b) 
Epstein shall be sentenced to consecutive terms of twelve (12) 
months and six(6) months in county jail for all charges, without 
any opportunity for withholding adjudication or sentencing, and 
without probation or community control in lieu of 
Imprisonment; and 
Epstein shall be sentenced to a tam of twelve (12) months of 
community control consecutive to his two terms in county jail 
as described in Term 2(a), supra. 
3. 
This agreement is contingent upon a Judge of the 15th Judicial Circuit 
accepting and executing the sentence agreed upon between the State 
Attorney's Office and Epstein, the details of which are set forth in this 
agreement. 
4. 
The terms contained in paragraphs 1 and 2. supra, do not foreclose 
Epstein and the State Attorney's Office from agreeing to recommend 
any additional charge(s) or any additional term(s) of probation and/or 
incarceration. 
5. 
Epstein shall waive all challenges to the Information filed by the State 
Attorney's Office and shall waive the right to appeal his conviction and 
sentence, except a sentence that exceeds what is set forth in paragraph 
(2), supra. 
6. 
Epstein shall provide to the U.S. Attorney's Office copies of all 
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proposed agreements with the State Attorney's Office prior to entering 
into those agreements. 
7. 
The United States shall provide Epstein's attorneys with a list of 
individuals whom it has identified as victims, as defined in 18 U.S.C. 
§ 2255, after Epstein has signed this agreement end 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 enemy representative for thesepersons, who shall be paid for 
by Epstein. Epstein's counsel may contact the identified individuals 
through that representative. 
8. 
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 conteat the 
jurisdiction of the United States District Court for the SouthernDistrict 
of Florida over his 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 identified Individual and 
Epstein, so long as the identified individual elects to proceed 
exclusively under 18 U.S.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 are not to be construed as an admission of any 
criminal or civil liability. 
9. 
Epstein's signature on this agreement also Is not to be construed as an 
admission of civil or criminal liability or a waiver of any jurisdictional 
or other defense as to any person whose name does not appear on the 
list provided by the United States. 
I O. 
Except as to those individuals who elect to proceed exclusively under 
18 U.S.C. § 2255, as set forth in paragraph (8), supra, neither Epstein's 
signature on this agreement, nor its terms, nor any resulting waivers or 
settlements by Epstein are to be construed as admissions or evidence of 
civil or criminal liability or a waiver of any jurisdictional or other 
defense as to any person, whether or not her name appears on the list 
provided by the United States. 
11. 
Epstein shall use his best efforts to enter his guilty plea and be 
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