EFTA01089193

12/06/07 THU 15:23 PAX 
JAYP.LEFKOVATZ,ESQ. 
DECEMBER 6, 2007
PACE 2 OF 4 
EXECUTIVE OFFICE 
any past or future delay. Mr. Epstein currently has fan• Florida Bar members on his defense team, 
so attorney scheduling is not an adequate basis for delay. 
Three weeks ago lalso asked you to provide our Office with the terms of the Plea Agreement 
with the State Attorney's Office. It is now more than two months since the signing of the Non-
Prosecution Agreement and we havo yet to see any tonna! agreement, or evcna list of essential terms 
of such an agreement. 
Next, let me address your allegation that attorneys in our office and agents of tho FBI have 
leaked information to the press in an effort to affect possible civil litigation with Mr. Epstein. This 
is untrue. There has been no contact between any member of the press and any employee of our 
office or the FBI since you incorrectly accused investigators of telling 'Vanity Fair" about Mr. 
Starts employrbent by Mr. Epstein several months ago. We intend to continue to refrain from 
commenting or providing information to the press. We would ask that your client and all of his 
representatives do the same. 
I also want to address your interpretation of several statements that were included in 
correspondence — at your insistence— as proof that the designated victims have invalid claims. Let 
me make clear that each of the listed individuals are persons whom the Office identified as victims 
as defined in Section 2255, that is, as persons "who, while a minor, was a victim of a violation of 
section ... 2422 or 2423 of this title." In other words, the Office is prepared to indict Mr. Epstein 
based upon Mr. Epstein's "interactions" with these individuals) This conclusion is based upon a 
thorough and proper investigation — one in which aom of the victims was informed of any right to 
receive damages of any amount prior to the investigation of het claim. The Office agrees that it is 
not a party to, and will not take a role in, any civil litigation, but the Office can say, without 
hesitation, that the evidence demonstrates that each person on the list was a victim ofMr. Epstein's 
criminal behavior. Mr. Stair's letter also suggests that the number of victims to whom Mr. Epstein 
is exposed by the Agreement is limitless. As you know, early drafts of the Agreement contained a 
numerical limit of40 victims, which was removed at your request. The Office repeatedly confumed 
that the number would not exceed 40; and the list is significantly shorter than that. Once the list is 
provided to you, if you have a good faith basis for asserting that a victim never met Mr. Epstein, we 
remain willing to listen and to modify the list if you convince us of your position. 
Finally, let me address your objections to the draft Victim Notification Letter. You write that 
you don't understand the basis for the Office's belief that it is appropriate to notify the victims. 
Pursuant to the "Justice for All Act of 20047crime victims arc entitled to: "The right to reasonable, 
accurate, and timely notice of any public court proceeding ... involving the crime' and the "right 
'Unlike the State's investigation, the federal/ investigation shows criminal conduct by Mr. 
Epstein at least as early as 2001, so all of the victims were minors at the time of the offense. 
a003 
EFTA01089293

12/06/07 THU 16:23 FAX 
JAY P. LEP/COMTE, ESQ. 
DECEMBER 6, 2007 
NOSH OP4 
EXECUTIVE OFFICE 
not to be excluded from any such public court proceeding 
." 18 U.S.C. § 3771(aX2) & (3). 
Section 3771 also commands that "employees of the Department of Justice . 
engaged in the 
detection, investigation, or prosecution ofcrime shall make their best efforts to see that crime victims 
are notified of, and accorded, the rights described in subsection (a)." 18 U.S.C. § 3771(cXl). 
Additionally, pursuant to the Victims' Rights and Restitution Act of 1990, our Office is 
obligated to "inform a victim of any restitution or other relief to which the victim may be entitled 
under this or any other law and [thej manner in which such relief may be obtained  " 42 U.S.C. § 
10607(cX1)03). With respect to notification of the other information that we propose to disclose, 
the statute requires that we provide a victim with the earliest possible notice of: the status of the 
investigation; the filing of charges against a suspected offender; and the acceptance of a plea. 42 
U.S.C. § 10607(c)(3). Just as in 18 U.S.C. § 3771, these sections are not limited to proceedings in 
a federal district court. Our Non-Prosecution Agreement resolves the federal investigation by 
allowing Mr. Epstein to plead to a state offense. The victims identified through the federal 
investigation should be appropriately informed, and our Non-Prosecution Agreement does not 
require the U.S. Attorney's Office to forego its legal obligation 
With respect to your assertion that we are seeking to "federalize" the state plea, our office 
is simply informing the victims of their rights. It does not command than to appear at the hearing 
or to file a victim impact statement. In 
t 
recommends the sending of any statement to 
the State Attorney's Office so that 
can determine which, if any, statements are 
app., up, late to file with the Court 
Next, you assert that our letter mischatactetizes Mr. Epstein's obligation to pay damages to 
the victims. To avoid that suggestion, I have asked AUSA Villafaila to simply quote the terms of 
the Agreement directly into the Notification Letter. We also have no objection to referring to Mr. 
Epstein as a "sexual offender tether than a "predator." 
We have no objection to using the conjunction "and/of' in relaxing to the particular 
offense(s) of which the recipient was a victim. We will not include the language that we take no 
position as to the validity of any claims. While the Office has no intention to take any position in 
any civillitigation arising between Mr. Epstein and any individual victim, as stated above, the Office 
believes that it has proof beyond a reasonable doubt that each listed individual was a victim of Mr. 
Epstein's criminal conduct while the victim was a minor. The law requires us to treat all victims 
"with fairness and with respect for the victim's dignity and privacy." 18 U.S.C. §3771(aXn We 
will not include any language that demeans the harm they may have suffered. 
The let ' 
.ons regarding representation by the Podhurst Sinn and Mr. losefsberg are 
accurate. 
conferred with Messrs. Podhurst and losefsberg to insure their willingness 
to undertake 
assignment prior to finalizing his selection. 
@0n 
EFTA01089294

12/08/07 TEU 15:23 FAX 
JAY P. LERgowrn, ESQ. 
DECEMBER 6, 2007 
PAGE4 0174 
EXECUTIVE OFFICE 
Lastly. you object to personal communication between the victims and federal attorneys or 
agents. We have no objection to sendin the letters throw 
the 
language about contacting 
or 
ma • 
"II not remove the 
with questions or 
concerns. Again, federal 
quires 
t vue • 
sera e n t to confer with the 
attorney for the Govemtnent in this case." 18 U.S.C. § 3771(aXS). The three victims who were 
notified prior to your objection had questions directed to Mr. Epstein's punishment, not the civil 
litigation. Those questions are appropriately directed to law enforcement. If questions arise related 
to the civil litigation, 
md 
will recommend that the 
victims direct those questions to Mr. JostlE 
I have attached a revised letter incorporating the changes on which we can agree. Please 
provide any further commentsby the closeofbnsiness on Friday. In addition, pleaseprovide us with 
a definitive statement, signed by ow- client, of his intention to abide by each and every term of the 
Agreement by close of business on Friday, December 7,2007. By that time, you must also provide 
us with the agreanent(s) with the State Attorney's Office and a date and time certain for the plea and 
sentencing, which must occur no later than Decanber 14, 2007. That must he closure in this 
matter. 
By: 
Enclosure 
cc: 
R. Alexander Ac
Attorney 
Sincerely, 
R. Alexander Acosta 
First Assistant United States Attorney 
This is contingent, however, on being able to provide adequate notice o 
ge of 
plea and sentencing. The sooner that you schedule that hearing with 
the sooner 
we can dispatch these letters. If you delay further, we will have to re on 
ep ne or personal 
notification. 
®cos 
EFTA01089295

12/00/07 THU 15:24 PAZ 
BIBC1771VE OFFICE 
U.S. Department ofJustice 
United States Attorney 
Southern District of Florida 
December 6, 2007 
DELIVERY BY UNITED STATES MAU 
Miss 
Re: 
("rime Victims' Rinhts — Notification of Resolution of Epstein Investigation 
Dear Miss
Several months ago, I provided you with a letter notifying you of your rights as a 
victim pursuant to the Justice for All Act of 2004 and other federal legislation, including: 
(1) 
The right to be reasonably protected from the accused. 
(2) 
The right to reasonable, accurate, and timely notice of any public court 
proceeding involving the crime or of anyrelease or escape of the accused. 
(3) 
The right nom be excluded from anypublic court proceeding, unlessthe court 
determines that your testimony maybe materiallyaltered ifyou are present for 
otter portions of a proceeding. 
(4) 
The right to be reasonably heard at any public proceeding in the district court 
involving release, plea, or sentencing. 
(5) 
The reasonable right to confer with the attorney for the United States in the 
case. 
(6) 
The right to full and timely restitution as provided in law. 
(7) 
The right to proceedings free from unreasonable delay. 
(8) 
The right to be treated with fairness and with respect for the victim's dignity 
and privacy. 
I am writing to inform you that the federal investigation of Jeffrey Epstein has been 
completed, and that Mr. Epstein and the U.S. Attorney's Office have reached an agreement 
containing the following terms. 
ooe 
EFTA01089296

12/06/07 THU 16:24 PAZ 
MISS 
NOvaiRea 29,2007 
PAG62 
aracurive 0PPICE 
First, Mr. Epstein agrees that he will plead guilty to two state offenses, including the 
offense of soliciting minors to engage in prostitution, which will require him to register as 
a sexual offender for the remainder of his life. 
Second, Mr. Epstein has agreed to make a binding recommendation of 18 months' 
imprisonment to the state court judge who sentences him. Mr. Epstein will serve that 
sentence of imprisonment at the Palm Beach County Jail. 
Third, Mr. Epstein has agreed that he will compensate you for damages you have 
suffered, under the following circumstances. That portion of the agreement that relates to 
those claims reads as follows: 
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 and been sentenced. 
Upon the execution ofthis agreement, theUnited States, in consultation 
with and subject to the good faith approval of Epstein's counsel, shall 
select an attorney representative for these persons, who shall be paid for 
by Epstein. Epstein's counsel may contact the identified individuals 
through that representative. 
8. 
If any of the individuals referred to in paragraph (7), supra, eltcts to 
file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the 
jurisdiction of the United States District Court for the Southern District 
of Florida over his person and/or the subject matter, and Epstein waives 
his rig/MG 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 
0007 
EFTA01089297

12/06/07 THU 15:26 FAX 
MISS 
NOVEMBER 29, 2007 
PAGE 3 
EXECUTIVE OFFICE 
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, 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. 
Pursuant to the terms of the agreement and an addendum, to assist you in making such 
a claim, the U.S. Attorney's Office has asked an independent Special Master to select 
attorneys to represent you. Those attorneys are Aaron Podhurst and Robert ("Bob") 
Josefsberg with the law firm of Podhntst °neck, P.A. They can be reached at P.M 
In 
1 anticipate that someone from their law fum will be contacting you shortly. I must 
also advise you thatyou are not oblismted to use these attorneys. In fact you have the 
absolute right to select voursovirtattorney—sct you can decide motto speak with Messrs, 
llorgutrWatatannou 
can speak with_thern and decide at any time to use a 
different attorney. If you do decide to seek damages from Mr. Epstein and you decide to use 
Messrs. Podhurst/Josefsberg as your attorneys, Mr. Epstein will be responsible for paying 
attorney's fees incurred during the time spent trying to negotiate a settlement. If you are 
unable to reach a settlement with Mr. Epstein, you and Mr. Josefsberg can discuss how best 
to proceed. 
As I mentioned above, as part of the resolution of the federal investigation, Mr. 
Epstein has agreed to plead guilty to state charges. Mr. Epstein's change of lea and 
scntencin¢ will occur on December 14, 2007, at  
 a.m., before Judlte 
Palm Beach County Courthouse, 
Pursuant to Florida Statutes Sections 
.001(1Xk) 
, you are entitled to be present and to make a statement under oath. If you 
choose, you can submit a written statement under oath, which may be filed by the State 
Attorney's Office on your behalf If you elect to prepare a written statement, it should 
address the following: 
the facts of the case and the extent of any harm, including social, 
psychological, or physical harm, financial losses, loss of earnings directly or 
indirectly resulting from the crime for which the defendant is being sentenced, 
ens 
EFTA01089298

12/08/07 THU 15:28 PAX 
MISS 
NOvEMBERZA2007 
PAGE4 
EXECUTIVE OFFICE 
and any matter relevant to an appropriate disposition and sentence. Fl. Stat. 
921.143(2). 
You also am entitled to notification when Mr. Epstein is released from imprisonment 
at the end of his prison term and/or if he is allowed to participate in a work release program. 
To receive such notification, please provide the State Attorney's Office with the following 
information: 
1. 
Your name 
2. 
Your address 
3. 
Your home, work, and/or cell phone numbers 
4. 
Your e-mail address 
5. 
A notation of whether you would like to participate in the "VINE system," 
which provides automated notification calls any time an inmate is moved. (To 
use thi a system, your calls must go to you directly, not through a switchboard.) 
Thank you for all of your help during the course of the investigation. If you have an 
questions or 
not hesitate to contact me or 
Sincerely, 
It Alexander Acosta 
United States Attorney 
rs t mte States Attorney 
in
U.S. Attorney's Office 
By: 
cc: 
?loos 
EFTA01089299

Exhibit 16 
EFTA01089300

IN RE: 
INVESTIGATION OF 
JEFFREY EPSTEIN 
 
I 
ADDENDUM TO TIE NON-PROSECUTION AGREEMENT 
IT APPEARING that the parties seek to clarify certain provisions of page 4, paragraph 7 
of the Non-Prosecution Agreement (hereinater "paragraph 7"), that agreement is modified as 
follows: 
7A. 
The United Slates 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 the attorney 
representative suggested by the independent third-party prior to the final designation of 
the attorney representative. 
7B. 
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 ha 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 
representative selected 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, 
Wafter 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 ins 2255 to bear the costs of the attorney 
representative, shall case. 
EFTA01089301

By signing 114 Acklenthim, Epstein asserts and certifies that the above has been read and 
explained to him. Epstein hereby. states that he understands the clarifications to the Non-
Prosec-odortAgreament and agrees to comply kith them. 
AttettNtaacca 
UNWEI? STATES ATTOBSIBI 
Dated:  /OA 0 47 
Dated: P4 r i fi  
Dated: 
Dated: 
• 
US. ATTORNEY 
GERALD LEFCOURT, ESQ. 
COUNSEL TO JEFFREY EPSTEIN 
LILLY ANN SANCHEZ, ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
EFTA01089302

By signing this Addendum, Epstein asserts and certifies that the above has been read and 
explained to him. Epstein hereby states that he understands the clarifications to the Noa-
Prosecution Agreement and agrees to comply with them. 
ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated:  iv °An 
ASSISTANT U.S. ATTORNEY 
Dated: 
JEFFREY EPSTEIN 
Dated: 
c*PALD LEFOO RT ESQ: 
COUNSEL TO 
YEPSPEJN 
LILLY ANN SANCHEZ, ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
EFTA01089303

By signing this Addendtan, Epstein asserts tad eatifies thd the above has beta read and 
explained to him. Epstein hereby states dat he andessiands the ~ions 
to the Non-
Preeecation Agreement aid agrees to comply with tisto. 
•
 
R. ALIOCANDERACOSTA 
uNrnin STATES ATTORNEY 
Dined: aihdfl
P/• 
• 
AS ISTANT U.S. ATTORNEY 
Dated: 
JEFFREY EPSTEIN 
Dated: 
GERALD LEFCOURT, ESQ. 
vas:~ 
ATTORNEY FOR JEFFREY EMT/UN 
EFTA01089304

Exhibit 17 
EFTA01089305

10/25/07 THU 13:15 FAX 
EXECUTIVE OFFICE 
U.S. Department of Justice 
United StatesAttorney 
Southern District of Florida 
cot 
DELIV 
Y A 
erman 
Re: 
Service as a SoccialMaster 
Dear 
October 25, 2007 
Thank you for agreeing to serve as a Special Master and for assisting the United States 
Attorney's Office in the selection of an attorney representative to represent a group of 
identified victims. This letter is meant to assist you in performing your duties by providing 
you with background information regarding the agreement between the United States and 
Jeffrey Epstein and the duties that the attorney representative will have to perform. 
The Federal Bureau of Investigation and the U.S. Attorney's Office conducted an 
investigation of Mr. Epstein. As a result of that investigation, the U.S. Attorney's Office and 
Mr. Epstein entered into a Non-Prosecution Ard. .meat and an Addendum that contains, 
truer alia, the following terms: 
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 Ole United States and Epstein 
retain the right to make good faith objections to the attorney representative 
suggested by the independent third-party prior to the final designation of the 
attorney representative. 
EFTA01089306

10/25/07 THU 13:15 FAX 
BER 25, 2007 
PAGE 2 OE 4 
EXECUTIVE OFFICE 
7B. 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 7C, infra. 
7C. Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees 
of the attorney representative selected 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. § 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 § 2255 to bear 
the costs of the attorney representative, shall cease. 
Elf any of the individuals referred to [in the paragraphs above] elects to file 
suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of 
the United States District Court for the Southern District of Florida over 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 agreed 
to between Epstein and the identified individual, 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, with respect 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 
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. 
10. Except as to those individuals who elect to proceed exclusively under 18 
U.S.C. § 2255, as set forth in [the above paragraphs], neither Epstein's 
tit 003 
EFTA01089307

10/25/07 
THU 13:19 FAX 
EXECUTIVE OFFICE 
OCTOBEk25,2007 
PAGE30F4 
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. 
The most recent version of the statute referenced above, 18 U.S.C. § 2255, 
provides that: 
Any person who, while a minor, was a victim of a violation of section... 2422 
or 2423 of this title and who suffers personal injury as a result of such 
violation, regardless of whether the injury occurred while such person was a 
minor, may sue in any appropriate United States District Court and shall 
recover the actual damages such person sustains and the cost of the suit, 
including a reasonable attorney's fee. Any person as described in the 
preceding sentence shall be deemed to have sustained damages of no less than 
$150,000 in value.' 
Section 2422 prohibits the use of a facility of interstate commerce to induce minors 
to engage in sexual activity and prostitution, and section 2423 prohibits interstate travel for 
the purpose of engaging in sexual activity or prostitution with minors. The United States has 
identified 34 victims as defined by this statute. The United States takes no position as to the 
validity of any such claim under this statute. 
Due to the circumstances of the case and the number and caliber of the attorneys who 
represent Mr. Epstein, in selecting the victims' attorney representative, the United States 
suggests that you consider the following criteria: 
. 
Experience doing both plaintiffs' and defense litigation. 
2. 
Experience with state and federal statutory and common law tort claims. 
3. 
The ability to communicate effectively with young women. 
4. 
Experience litigating against large Jaw firms and high profile attorneys who 
An earlier version of this statute deems that any person described in the preceding 
sentence shall have sustained damages of no less than $50,000 in value. 
Z004 
EFTA01089308

10/25/07 THU 13:19 FAX 
Gerona25,2001 
PAGE4OF4 
EXECUTIVE OFFICE 
aces 
may test the veracity of the victims' claims. 
5. 
Sensitivity to the nature of the suit and the victims' interest in maintaining 
their privacy. 
6. 
Experience litigating in federal court in the Southern District of Florida. 
7. 
The resources to hire experts and others, while working on a contingency 
fee basis, in order to prepare for trial, if a settlement cannot be reached 
(defense counsel has reserved the right to challenge such litigation). 
8. 
The ability to negotiate effectively. 
Pursuant to this letter, theUnited States assigns to youtheresponsibility forconsulting 
with and selecting the attorney representative for the individuals. The United States and 
Epstein retain the right to make good faith objections to the attorney representative you select 
prior to the final designation of the attorney representative. In that regard, after you have 
reached a decision regarding the attorney representative, please provide me with his or her 
name and contact information. 
If] can provide you with any further information, please do not hesitate to contact me 
and/or the U.S. Attorney and/oriayLe-flcowitz, Esq. on behalf ofE stein. 
be reached at 
Kirkland & Ellis LLP, 
Thank you again or your assistance with this matter. 
Sincerely, 
IL Alexander Acosta 
By: 
nt m 
States Attorney 
cc: 
EFTA01089309

Exhibit 18 
EFTA01089310

Case 9:08-cv-80736•KAM 
Document 35 
Entered on FLSD Docket 12/22/2008 
Page 1 of 4 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 0840736-Civ-Marra/Johnson 
IN RE: JANE DOE, 
Petitioner. 
SUPPLEMENTAL DECLARATION OF 
do hereby declare that I am currently employed as an 
Assistant United States Attorney ("AUSA") in the Southern District of Florida and was so 
employed during all of the events described herein, and that 1 was the AUSA assigned to the 
investigation of Jeffrey Epstein. 
2. 
This Declaration is meant to supplement the information provided in the 
Declaration that was filed on July 9, 2008, and to correct some statements in that Declaration 
based upon events that occurred after the filing of the July 9 Declaration. 
3. 
As explained in the July 9 Declaration and in Court presentations related to this 
matter, the resolution of the federal investigation of Jeffrey Epstein included a series of 
documents: (I) a September 2007 Non-Prosecution Agreement ("Part 1"); (2) an October 
2007 Addendum ("Part 2"); and (3)a letter dated December 19, 2007, from the U.S. Attorney 
to Attorney Lilly Ann Sanchez, counsel to Jeffrey Epstein ("Part 3"). 
EFTA01089311

Case 9:08-cv-8O736-KAM 
Document 35 
Entered on FLSD Docket 12/22/2008 
Page 2 of 4 
4. 
On July 9, 2008, your Affiant sent a victim notification letter to Jane Doe #1, 
which contained pertinent language from "Part 3" of the Agreement (Ex. 6 to the July 9 
Decl.). 
5. 
Prior to preparing and sending that letter, your Affiant sent a draft of the letter 
to counsel for Jeffrey Epstein. On July 9, 2008, Mr. Epstein's attorney wrote to your Affiant 
objecting to parts of the draft, but accepting the part of the draft letter that contained the 
language from "Part 3" of the Agreement. Based upon that communication, your Affiant 
sent the victim notification letter to Jane Doc 41 and attached it to your Affiant's July 9,2008 
Declaration. 
6. 
Although copies of all of the victim notification letters, including the one 
addressed to Jane Doe #1, were provided to Mr. Epstein's attorney, and despite the fact that 
counsel for Mr. Epstein filed a copy of your Affiant's July 9, 2008 Declaration in some of 
the civil suits filed against Mr. Epstein, none of Mr. Epstein's attorneys ever informed your 
Affiant that they considered the language in the letters and the Declaration to be inaccurate. 
7. 
In August 2008, in anticipation that the Court might order the United States to 
make the Agreement available to the victims, the United States sought to confirm that 
counsel for Mr. Epstein had filed the complete Agreement under seal with the State Court 
at the time of the entry of his guilty plea to the State charges, to insure that an exact copy of 
that Agreement would be provided in this case, should the Court order its production. 
EFTA01089312