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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

EFTA00259984

34 pages
Pages 21–34 / 34
Page 21 / 34
• 
.0.01-30-2008(808) 10:06 
P. 009/01a 
• 
proposed agreements with the State Attorney's Office prior to entering 
into those agreements. 
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.0 
§ 2255, after Epstein has signed this agreement and been sentenced. 
Upon the emecution.ofthis agreement, the United States, in consultation 
with and subject to the good faith approval of Epstein's counsel, shall 
select an attomeyrepresentative forthesepersons, who shall bepaid for 
by Epstein. Epstein's counsel may contact the identified individuals 
through that representative. 
If any of the individuals refitted to in paragraph (7), supra, elects to 
file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the 
jurisdiction ofthe United States District Courtforthe Southern District 
ofFlorida over his person sneVorthesubjectmater,and Epstein waives 
hisrightto contest liability and also waives his rightto contcstdamagea 
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 agates 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 listprovided by the United States, Epstein's signature on 
this agreement, bis 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 eivil or criminal liability or a waiver of anyjwisdictional 
or other defense as to any person whose name does not appear on the 
list provided by the United States. 
10. 
Except as to those individuals who elect to proceed exclusively under 
18 U.S.C. § 2255, as set forth in paragraph (8), supra, neitherEpstein's 
signature onthis agreement, nor its tetras, nor any resulting waivers or 
settlements by Epstein are to be construed asadmissions 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 
Page 4 of 7 
EFTA00260004
Page 22 / 34
JO-30-2008 (MO4 ) 10:05 
P.010/014 
• 
sentenced not later than October 26, 2007. The United States has no 
ahJectiott to-Epstein self-reportingro-beginseridng_hissemenet. not 
later than January 4, 2008. 
12. 
Epstein agrees that he will max afforded am, benefits with respect to 
gain time, other than the rights, opportunities, andbenefits as any other 
inmate, including but not limited to, eligibility for gain time medit 
based on standard rules and regulations that apply in the State of 
Florida. At the United States' request, Epstein agrees to provide an 
accounting of the gain time he camel during his period of 
incarceration_ 
13. 
The parties anticipate that this agreement will not be made part of any 
public record. If the United States receives a Freedom of informatirm 
Act request or any compulsory process commanding the disclosure of 
the agreement, it will provide no dee to Epstein before making that 
Epstein understands that the United States Attorney has no authority to require the 
State Attorney's Office to abide by any tams of this agreement Epstein uaderatands that 
it is his obligation to undertake discussions with the State Attorney's Office and to use his 
best efforts to ensure compliance with these procedures, which compliance will be necessary 
to satisfy the United States' interest. Epstein also uncle:mugsthat his his obligation to use 
his best efforts to convince the Judge of the 15th Judicial Circuit to accept Epstein's binding 
recommendation regarding the sentence to be imposed, and understands that the failure to 
do so will be a breach of the agreement. 
In consideration of Epstein's agreement to pleadguilty and to provide compensation 
in the manner described above, ifEpstein successfully fulfills all of theterms and conditions 
ofthis agreemnit the United States also agrees that it will not institute any criminalc 
es 
but not limited to 
Further, upon executioner -this 
agreement and a plea agreement 
a 
's Office, the federal Gland Jury 
investigation will be suspended, and all pending federal Grand Jury subpoenas will be held 
in abeyance unless and until the defendant violates any term of this agreement The 
defendant likewise agrees to withdraw his pending motion to intervene and to quash certain 
grand jury subpoenas. Both parties agree to maintain their evidence, specifically evidence 
requested by or directly related to the grand jury subpoenas that have been issued, and 
including certain computer equipment, inviolatetmtil allofthe terms ofthis agreement have 
been satisfied_ Upon the successful completion of the terms of this agreement, all 
outstanding grand jury subpoenas shall be deemed withdrawn. 
Page $ of 
EFTA00260005
Page 23 / 34
. 
MI-30-200804M 10:06 
By signing this agreement, Epstein asserts and certifies that each of these tents is 
material to this agreement and is supported by independent consideration and that a breach 
of any one of these conditions allows the United States to elect to terminate the agreement 
and to investigate and prosecute Epstein and any other individual or entity for any and all 
federal offenses. 
By signing this agreement, Epstein asserts and certifiesthathe is aware of the factfoat 
the Sixth Amendment to the Constitution of the United States provides that in all criminal 
prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein fluter 
is aware that Role 4g(b) of the Federal Rules of Criminal Procedure provides that the Court 
may dismiss an indictment, information, or complaint for thmecessary delay in presenting 
a charge to the Grand Jury, filing an information, or in bringing a defendran to trial. Epstein 
herebyrequests that theUnited States Attorney forthe SouthanDistrict ofFloridadefersuch 
prosecution. Epstein agrees and consents that any delay from the daze of this Agreement to 
the date of initiation of prosecution, as provided for in the tetras expressed herein, shall bc 
deemedto be a necessary delay at his own request, andhe hereby waives any defense to such 
prosecution on the groundthat such delay operatedto deny biro rights under Rule 48(b) of 
the Federal Rules ofCriminal Procedure and the Sixth Amendment to the Constitution ofthe 
United States to a speedy trial or to berths prosecutionly reason of the running ofthestatutc 
of limitations for a period of months equal to the period between the signing of this 
agreement and the breach of this agreement as to those offenses that were the subject of the 
grand jury's investigation. Epstein further asserts and certifies that he understands that the 
Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all 
felonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees 
and. consents that, if a prosecution against him is instituted for any offense that was the 
subjectof the grand jury's investigation, itmay be by way ofanInfommtion signed and filed 
by the United States Attorney, and hereby waives his right lobe indicted by a grand jury as 
to any such offanc. 
Page 6 of 7 
EFTA00260006
Page 24 / 34
.1014-30-200 NM 10:06 
P. 012/016
By signing this agreement, Epstein asserts and ratifies that the above has bcen read 
and explainedto him. Epstein hereby states that be understands the condbions of this Non-
Prosecution Agreement and amt es to comply with then 
Dated: 
Data 
Dated: 
Dated: 
R. ALEXANDER-ACOSTA 
UNITED STATES ATTORMY 
GERALD LEFCOURT, ESQ. 
COUNSEL. TO JEFFREY EPSTEIN 
LILLY ANN SANMZ, ESQ. 
ATTORNEY FOR JEFFREY FiSTEIN 
Page 7 of 7 
EFTA00260007
Page 25 / 34
• 
JUN-30-2008(10N) 10:07 
P. 013/ula 
. • 
By siMing this agreement, Epstein asserts and certifies that the above has ban read 
and explained to him. Epstein hereby states that be anderstrads the conditions of this Non-
Prosecution Agreesaent and agrees to comply with them. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated: 
 
By: 
Dated; 
Dated: (119-(tio7
Dated: 
LILLYANNSANCLIEZ. ESQ. 
ATTORNBYPOR JEFFREY EPSTEIN 
Rasa 7 of 7 
.1 
EFTA00260008
Page 26 / 34
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EFTA00260009
Page 27 / 34
IN RE: 
INVESTIGATION OF 
JEFFREY EPSTEIN 
ADDENDUM TO THE NON-PROSECUTION AGREEMENT 
IT APPEARING that the parties seek to clarify certain provisions of page 4, paragraph 7 
of the Non-Prosecution Agreement (hereinafter "paragraph 7"), that agreement is modified as 
follows: 
7A. 
The United States has the right to assign to an independent third-party the responsibility 
for consulting with and, subject to the good faith approval of Epstein's counsel, selecting 
the attorney representative for the individuals identified under the Agreement. If the 
United States elects to assign this responsibility to an independent third-party, both the 
United States and Epstein retain the right to make good faith objections to theattorney 
representative suggested by the independent third-party prior to the final designation of 
the attorney representative. 
TB. 
The parties will jointly prepare a short written submission to the independent third-party 
regarding the role of the attorney representative and regarding Epstein's Agreement to 
pay such attorney representative his or her regular customary hourly rate for representing 
such victims subject to the provisions of paragraph C, infra. 
7C. 
Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the attorney 
representativeselected by the independent third party. This provision, however, shall not 
obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus, 
if after consideration of potential settlements; an attorney representative elects to file a 
contested lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested 
remedy, the paragraph 7 obligation of the Agreement to pay the costs of the attorney 
representative, as opposed to any statutory or other obligations to pay reasonable 
attorneys fees and costs such as those contained in s 2255 to bear The costs of the attorney 
representative, shall cease. 
EFTA00260010
Page 28 / 34
t. 
By signing this Addendum, Epstein asserts and certifies that the above has been read and 
explained to him. Epstein hereby states thai he understands the clarifications to the Non-
Prosecution Agreement and agrees to comply with them. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated: 
Dated: 
Dated: 
Dated: 
By: 
1.11.
TTORNEY
. 
JEFFREY EPSTEIN 
ERALD LEFCO RT ESQ. 
COUNSEL TO JEFFR Y EPSTEIN 
LILLY ANN SANCHEZ, ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
EFTA00260011
Page 29 / 34
THAT'S THE STORY 
Storyteller Jim Weiss brings famous 
literary characters to life. 
Academia, Page 5 
A 'DYNAMO' 
Bobbi Horwich finds exercise helps 
her deal with personal struggles. 
Health, Page 8 
Palm Beach Dail 
Established 1897 
MBeachnai yNews.co-
THE SHINY SHEET® 
TUESDAY, DEC. 15, 2009 News 
50 cents 
Push 
made to 
keep bars 
open late 
Nick Coniglio, sisters start 
campaign urging Town Council to 
allow establisments to stay open 
until 3 a.m. 
By WILLIAM KELLY 
Daily News Staff Writer 
The Coniglio family, which owns two 
businesses on Royal Poinciana Way, is 
waging a petition and letter-writing cam-
paign urging the Town Council to allow 
bars to stay open until 3 a.m. 
The council has been flooded with let-
ters from residents protesting any attempt 
to dose the town's bars at 1 a.m. 
Nick Coniglio, who manages Cucina 
Dell 'Arte and Nick and Johnnie's, said 
Monday he and his sisters encouraged the 
letters to be written, and will present a pe-
tition with more than 100 signatures to the 
council on Thursday, when the subject is 
on the meeting agenda. The meeting be-
gins at 9:30 a.m. in the Emergency Opera-
tions Center at the Central Fire Station. 
"We sent out a couple of emails and 
said. 'fawns, watt attnrann me what wa an?* 
MENORAH LIT AT HANUKKAH CELEBRATION 
Hundreds gather at 
Bradley Park event 
Above: Robert and Silvia Robbins of Boca Raton 
watch the festivities Monday during the 12th 
annual Hanukkah celebration at Bradley Park. Six 
synagogues participated in the annual event. 
EFTA00260012
Page 30 / 34
Jeffrey Epstein settles two lawsuits 
Page 1 of 2 
PalmBeactiDailyflrics9m 
Jeffrey Epstein settles two lawsuits 
By MICHELE DARGAN 
Daily News Staff Writer 
Monday, December 21, 2009 
Updated 5:45 p.m. 
ca PRINTTHIS 
Powered by 
ClIckabllity 
Sex offender Jeffrey Epstein has settled a lawsuit filed by a young woman who alleged that at 
15-years-old she became what amounted to a sex slave for Epstein, according to court 
documents. 
The lawsuit — filed by Jane Doe 102 in May by Miami attorney Robert Josefsberg — was 
dismissed Dec. 8 by a signed order from U.S. District Judge Kenneth Marra, closing the case. 
The order was dismissed with prejudice, meaning the case cannot be refiled. 
Court records show Epstein settled another case with sexual abuse allegations brought by 
Jane Doe 101, a case filed in April by Josefsberg. Marra signed that dismissal order with 
prejudice on the same day as Doe 102. 
Epstein's civil attorney Robert Critton was unavailable for comment. Josefsberg did not return 
calls for comment. 
The Doe 102 complaint alleged that Epstein enticed the victim to quit her job as a changing 
room assistant at the Mar-A-Lago Club, where in 1998 she earned $9 an hour. The lawsuit 
said the girl was recruited at the club by Epstein's then-companion Ghislaine Maxwell, who 
told the girl she could learn massage therapy and earn a "great deal of money." 
In addition to Palm Beach, Epstein took the girl to New York City; Santa Fe, N.M.; Los 
Angeles,; San Francisco; St. Louis; Europe; the Caribbean and Africa, according to the 
lawsuit. The lawsuit alleged that in all of these locations she was required to engage in sex 
acts with him and other women, including other minors. 
The lawsuit also alleged that the victim was not only required to satisfy Epstein's "every 
sexual whim," but that she also was exploited by Epstein's adult male peers. They included 
royalty, politicians, academicians, businessmen and others in various locations around the 
world, the suit said. The lawsuit, like the more than a dozen other lawsuits filed against the 
billionaire money manager, says his modus operandi in the initial visit was the same: the 
minor girl was taken to Epstein's mansion on El Brillo Way and led upstairs to a spa room by 
one of Epstein's assistants, where he would ask the girl to perform massages and/or various 
sex acts, for which he would pay her. 
http://cox.printthis.elickability.com/pt/ept?action=cpterritle=Jeffrey+Epstein+settles+two... 12/22/2009 
EFTA00260013
Page 31 / 34
.• 
Jeffrey Epstein settles two lawsuits 
Page 2 of 2 
The allegations in the Jane Doe 101 complaint say the victim was a 17-year-old high school 
student when she was brought to Epstein's mansion in spring 2003. According to the 
complaint, Epstein asked her what year she would graduate high school, to which she replied 
2004. She gave Epstein a massage, which involved him touching himself and her while she 
was naked from the waist up. She was paid $200 and was "lured" back to the mansion on at 
least one other occasion. 
Epstein, 56, was released from the Palm Beach County Stockade in July, after serving less 
than 13 months of his 18-month sentence for procuring a minor for prostitution and soliciting 
prostitution. He is serving one year of probation in his Palm Beach mansion. 
Find this article at: 
http://www.palmbeachdailynews.cominewskontentinewsf2009/12/21twebepsteinslave122109.html 
LI Check the box to include the list of links referenced in the article. 
Copylight 2008 Palm Beath Daily News. All rights reserved. 
http://cox.printthis.clickability.corn/pt/cpt?action=cpt&title=Jeffrey+Epstein+settles+two... 12/22/2009 
EFTA00260014
Page 32 / 34
• 
GOING BACK 'TO ITS 
ROOTS' - AND RULES 
Paradise Ball to be smaller, more sophisticated. 
Shannon Donnelly, Page 6 
Palm Bea 
TIMELY AWARD 
First Serve honors volunteer of 
the year prior to Pro-Am tennis 
tournament. Page 9 
PalmBeachDailyNews.com 
WEDNESDAY, DEC. 9, 2009 
10 Pages 50 cents 
`SURFING WITH FRIENDS IS LIKE SURFING WITH FAMILY' 
•iiitt'sfar 
- 
at 
a 
• 
_ 
ehla  
• 
ar  - 
19'1
---• a..-
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4.
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1 
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say 
Above: Surfers from the same West 
Palm Beach neighborhood gather 
Sunday on the beach near Clarke 
Avenue. 
Left: Chris Lorenz catches a wave 
during a rough, windy day. 
Daily News Photos by Jeffrey Langlois 
Ex-exec: 
Overturn 
my fraud 
conviction 
Conrad Black's attorney tells U.S. 
Supreme Court honest services 
fraud statute 'vague,' but Justice 
Department defends law. 
By MICHELE DARGAN 
Daily News Staff Writer 
In his quest to overturn his fraud con-
viction, jailed media 
mogul Conrad Black 
challenged the validity 
of honest services fraud, 
the federal law used to 
put three Palm Beach 
County commissioners 
behind bars. 
In oral arguments to 
the U.S. Supreme Court 
Thesday, the jai led press 
baron Is asking to have 
his conviction thrown 
out. 
Black's 
attorney 
Miguel Estrada called 
the statute "vague In all 
of its applications." 
Black 
Imprisoned 
at Coleman 
Correctional 
Institution since 
March 2008. 
 
Lai 
EFTA00260015
Page 33 / 34
•••11
••••P 
4 
GOING BACK 'TO ITS 
ROOTS' - AND RULES 
Paradise Ball to be smaller, more sophisticated. 
Shannon Donnelly, Page 6 
TIMELY AWARD 
First Serve honors volunteer of 
the year prior to Pro-Am tennis 
tournament. Page 9 
Palm Beach Dail 
Established 189
THE SHINY SHEEN) 
WEDNESDAY, DEC. 9, 2009 News 
10 Pages 50 cents 
`SURFING WITH FRIENDS IS LIKE SURFING WITH FAMILY' 
-*OS 
it 
"et' 
41. 
• 
"la 
144 
Above: Surfers from the same West 
Palm Beach neighborhood gather 
Sunday on the beach near Clarke 
Avenue. 
Left: Chris Lorenz catches a wave 
during a rough, windy day. 
Daily News Photos by Jeffrey Langlois 
• 
Crifini un Iniairliec 1i-1'4-Sunday ritual 
V. 
MI, 
Ex-exec: 
Overturn 
my fraud 
conviction 
Conrad Black's attorney tells U.S. 
Supreme Court honest services 
fraud statute 'vague,' but Justice 
Department defends law. 
By MICHELE DARGAN 
Dail) Yeas Stall Writer 
In his quest to overturn 
viction, jailed media 
mogul Conrad Black 
challenged the validity 
of honest services fraud, 
the federal law used to 
put three Palm Beach 
County commissioners 
behind bars. 
In oral arguments to 
the U.S. Supreme Court 
Tuesday, the jailed press 
baron is asking to have 
his conviction thrown 
out. 
Black's 
attorney 
Miguel Estrada called 
the statute "vague in all 
of its applications." 
Justices appeared to agree with Black 
— that the law is vague and has been used 
his fraud con-
Black 
Imprisoned 
at Coleman 
Correctional 
Institution since 
March 2008. 
• 
• 
EFTA00260016
Page 34 / 34
A6 
Palm Beach Daily News, Sunaayktober 18,2009 
PALM BEACH GOVERNMENT 
Sewers, beach, pensions challenge budgets 
Council faces future 
choice of services vs. 
property tax hikes. 
By WILUAM KELLY 
Daib News Staff Writer 
The biggest challenge 
before the Town Council 
this season is the need to 
put the town's long-term fi-
nances on a sound footing. 
The $67 million operat-
ing budget for the year that 
began Oct. 1 is balanced, 
but Town Manager Peter 
Elwell has said the council 
must devote more funds to 
long-term capital improve-
ment needs — $6 million a 
year instead of the current 
$2.6 million. The capital 
needs include a townwide 
replacement of the sani-
tary sewer system, tagged 
at about $25 million. 
Also looming are ero-
sion-control 
costs 
that 
could exceed $100 million 
over the next 10 years. The 
council is considering es-
tablishing a townwide tax 
district to assess all property 
owners to meet those costs. 
In addition to capi-
tal and coastal needs, the 
town also must address 
personnel and escalating 
employee costs if it is to 
keep the budget balanced, 
Elwell has said. 
If the pension costs 
aren't addressed, the town 
could be faced with a deficit 
as early as 2012, the Finance 
Department has warned. 
The council this year 
held the line on property 
taxes even as other coun-
ty taxing districts, in-
cluding the Palm Beach 
County Commission, de-
cided to hike their rates to 
cover revenue losses tied to 
the poor economy. 
The question before the 
Palm Beach council is, how 
ZONING 
can It meet its long-term 
commitments without in-
creasing taxes or compro-
mising services to town 
residents? 
Governmental 
tional 
expenses 
already have been 
cut back. About 
10 vacant employ-
ee positions were 
eliminated 
this 
year, a two-year 
hiring freeze re-
mains in effect, 
and health ben-
efits have been 
trimmed. 
The council re-
cently told Elwell 
to develop a plan 
that shows a bal-
anced budget for 
the next five fiscal years. 
The town has hired a 
consultant to review its pen-
sions and report by Oct. 31. 
The report will be reviewed 
Nov. 11.13 by the town's 
PB considering more flexibility 
in use of solar-panels on roofs 
By WILLIAM KELLY 
Daily News Staff Writer 
I 
In a town that prizes aes-
thetics more than most, the 
use of solar power is restrict-
ed by an ordinance that lim-
its panels to a maximum of 15 
percent of roof coverage. 
Town officials are con-
sidering loosening the re-
striction so the town is more 
accommodating to solar 
technology. 
That is one of the items 
before the Planning and 
. Zoning Commission and 
town staff this season. The 
town staff are studying an 
amendment that would ex-
pand the cap to 30 percent 
of the roof. 
State law does not al-
low the town to prohibit so-
According to Castro, a 
major obstacle to solar pan-
el installation has nothing 
to do with town law: The 
panels must be bolted to 
roof trusses, which causes 
homeowners to lose their 
roof warranty. 
Other study topics this 
season include: 
• A reduction in re-
quired 
parking 
garage 
spaces for single-family 
homes on smaller lots. The 
change would allow more 
flexible use of property 
without an increase in den-
sity, Castro said. 
• A reduction in the 
front setback for single-
family homes in the R-B 
zoning district to allow the 
opportunity for larger back 
yards. The district Is mainly 
structures east or partial-
ly east of the state Coastal 
Construction Control Line. 
Under the change, base-
ments or sub-basements 
would count as a story. But 
the change would not allow 
an increase in building or 
story heights as measured 
from a public street. 
— [email protected] 
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opera-
Elwell 
Says town met 
budget more ix 
long-term capral 
improvement 
threepension boards, who 
will ccept comment from 
the µblic and town em-
ployes, Elwell said in a re-
centhterview. 
Mpecial council meet-
ing will focus on 
the pension issue 
on Dec. 17. 
'We want 
a 
menu of options as 
broad as possible 
that will identify 
the savings and 
potential impact 
in terms of mar-
ketplace competi-
tiveness: 
Elwell 
said. 
The town can't 
cut costs by re-
ducing 
benefits 
that already have 
accped. But it can alter 
beSits for existing and fu-
t urtemployees effective on 
sore future date, he said. 
Aside from the budget, 
othr high-profile issues 
before the council this year 
include possible creation of 
a 30-acre zoning overlay in 
the Royal Poinciana Way 
business district. 
The overlay would pro-
vide height and densi-
ty incentives for property 
owners whose redevelop-
ment plans include char-
acteristics desired by the 
town, such as vies or exten-
sive landscaping. 
The overlay incentives 
have sparked debate be-
tween those who say the 
street is in decline and 
those who want to protect it 
from over-development. 
The council had sched-
uled a Nov. 18 special meet-
ing to take up the issue, but 
that has been canceled to 
give the Planning and Zon-
ing Commission more time 
to work with town cqnsul-
tant Marcela Camblor on 
zoning amendments tied to 
the overlay. 
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Pages 21–34 / 34