EFTA01718407.pdf

EFTA01718407  (USAFLS) From: (USAFLS) Sent: . 2007 12:47 PM To: Subject: Hi — I still am having trouble with my voice and am headed home now. Here is the latest: hat is probably coming late tonight or ear y tomorrow morning. The hearing is off for tomorrow, as is the grand jury time. When you have a chance, can ou sto b and :et from a co. of the draft indictment, co ies of the and transcripts, and a o you can start on that while I am laid up. Thank you. Assistant U.S. Attorney est am eac Phone Fax EFTA01718408  SEP-12-2008 08:18 RIID-WINCEESTER P.001 • ' ' • FD;448 FEDERAL BUREAU OF INVESTIGATION Revised 10-274004 FACSIMILE COVER SHEET PRECEDENCE C Priority 2 Routine ImMeMee (7! CLASSIFICATION (7 Top Secret C Secret SK Confidential r. senaive C Unclassified Number of Pages; (including cover) Subject: SICtrk— I d Specla Handling Instructions: ! Brief DeSCriptioniof Commuinication Faxed: Cop( v4 !e>c : #FC)//1 rtect)unt I I ' I I : • WARNING Information attached) to the cover sheet is U.S. Government Property. If you are not the Intended recipient Of this Information disclosure, reproduction, distribution, är use of this information is prohibited (16.1.1SC, § 641). Please notify the originator or local FBI Office Immediately to arrange forproper disposition. ! ; ; I. ; I M ! FD-448 (RevISS 10-27;;2004) Page 1 of DERAL BUREAU OF INVESTIGAUON I EFTA01718409 WY. • •• an/••••• %OW • • Yr n UV ire • • nea.ne • ••••• • J ;! LEWIS TEINPL ATTORNEYS AT LAW July 28,42008 Via fearx; • Record/information Dissemination Section FOIA Request Coordinator Federal Bureau of Investi eon, Miami Field Office ort t iami eac t, 9 Re: Freedoth of Information Act/Privacy Act Request ..Seeking:Documentsfrom a USA° / FBIInvestigation in the Southern District ofFlorida. ! • To Whom it Miy Concern: We write on behalf of our client,ltfaSt, to request certain records under the Freedom of Information Act and Privacy Act. Mr. Epstein has been the focus of a joint investigation by the U.S. Attorney's Office for the Southern District of Florida ("USAO") and Federal Bureau of Investigation ("FBI"). The USAO and/or FBI may have in its possession original (or copies of original) documents in paper anctlectronic form seized from Mr. Epstein pursuant to a searchi warrant executed on his Palm Aback Florida home on October 20, 2005. We request copies of these paper and electronic documents • Further; the USAO and/or FBI ma y have interviewed (ii (DOB (DOB (iii) a/k/a (DOB (iv) (DOB's), (v) anc/ (vi • ME), (DOB (vii) (DOB (DOB lx) Sida DOB We believe t cse interviews would have taken place between 2006 and the present. Under FOIA/PA, we request copies of all interview notes and RBI 302s concerning these interviews. We are enclosing Mr. Epstein's fully executed Certification of Identity (Fokt DOJ -361). . ! • Copies it'llany records,responsive to this FOIA/PA request should be sent to my attention at the address:listed below. Thank you for your courtesy. • • Very truly yours, Un TCLCOHON; l • FACSIMILE COCONUT GROVE, r_OR IDA 33133 • WWW.LEWISTE1N .00 M EFTA01718410  Old 14 - 4VVV VO . 14 Wi n 14/ 4.11;c0 I LS% Oa I I • US. Department of Justice Certification of Identity I • - • • • • • i Prey Act Stalentent.In accordance with 28 CFR Section 16.41(d) personal data sufficient to identify the individuals submitting requests by mail underithe Orivacy Act of 1074,5 U.S.C. Section 552a, is required. The purpose of this solicitation is to ensure that the records of ind vidnann who arc the subject of US. Department of Justice systems of records me not wrongfully diet/O;Od by the Department. Failure to furnish this informittlon will result-in no attics being taken on the requaa. False infornuttroo on this form may subject the requester to crim- inal realties Under IS LES.C. Section 1001 and/or 5 U.S.C. Section 552a6X3). , ! Paine reporting burden for this collection of information is estimated to average 0.50 hours per response, including the time for review- inninstructions. sdarciiirig existing data sources. gathering and mainthioing the data needed, and completing and reviewing the collo:lion of 'nforrnation. StiggestiOns for reducing this burden may be submitted to Director. Facilities and Administrative Services Staff, Justice Mt nags rent pivjsion: V.S. Department ofJusiice. Washington. DC 20530 and the Office of Information and Regulatory Allairs. Office of Management and Sfudget. Public Use Reports Project (1103.0016), Washington, DC 20503. i . F11 Name bf requester I I • CitizenshipiStatus 2 • tbliAta 3 :412.• f Social Security Number' Cunent A4mit Cocoa,, 74- 6h,e_ FC33(13 I Date of Bitfh is„ 20) 1453 Place of Binh M t.) kfr-k • : f declare under penalty of perjury under the laws of the United Slates of America that the foregoing hs true and COTTOCI. and that I am the pe n named ahoive, ind I understand that any falsification of this statement is punishable under the Provisions of 18 U.S.C. Section 1001 by fine of net more than S10.000 or by imprisonment of not more than live years or both, and that requesting or obtaining tiny rarord(s) u cr false dierenles is Punishahlo under the provisions of 5 UU..S.C. SS2a(iX3) by a fine of not more than $5,000. : • Signature / Date /.7/O OPTIONAL: A.utStion.to Release Information to Another Person i • This form is also to be 'aiimpleted by a requester who is authorizing information relating to himself or herself to he released to another person. pars"I Further. ! to 5 U.S.0 Section 5Sia(ti),l authorize the U.S. Department of Justice to release any and all information relating to me to: I • . I Print or Type Marne I Maw of individual who is the subject of the record sought fadiViclual:SolioliCling a request under the Privacy Act of 1974 must he either "a citizen of the United States or an alien lawfully admitted for bermunentlyesidence," pursuant to S U.S.C. Section 552a(aX7.). Requests will be processed as Freedom of Information Act :Tests pursuantito U.S.C. Section 552. rather than Privacy Act requests, for individuals who are not Unitt4 States citizens or aliens la ally admittedIfor pirmanent residence. 3 Providing your soclid security number is voluntary. You arc caked to provide your social security number only to facilitate the identilitatiOnlot bloandsirelating to you. Without your social security number. the Department missy be unable to locate any or all records pertaining to you.l i I 4 Signature of individual who is the subject of the record sought. MAPP*Olitp CMS NO. 110.44:114 FORM ea 361 ITXPIRIS e31107 :irlT 04 TOTAL P.004 EFTA01718411  idea L - toVVO 110 • SU AMP IN nvlit30 IJA trh P 4- I U.S. Departnitnt of Justice Certification of Identity i II I; Privacy Act StateinentIn accordance with 28 aelt Section 16.41(d) personal data sufficient to identify the individuals submitting requests by Imail undei the Privacy Act of 1974, 5 U.S.C. Section 552a, 'et required. The purpose of Ibis solicitation is to ensure that the records of individuals wbo arc thd snbject of U.S. Department of Justice systems of records are not wrongfully disclosed by the Department. Failure to famish this informittion will result in no action being taken on the request. False information on this form may subject the requester to crim- inal penalties undei• 18 U.S.0 Sidon 1001 and/or 5 U.S.C. Section 552a(iX3). I • 1 : • I Public reporting Mader for this collection of information is estimated to average 0.50 hews per response, including the time for review. inj insuuctioists, starching existing data sources. gathering and maintaining the data needed• and completing and reviewing the collection of information. SuggeStiOns for reducing this burden may be submitted to Dictator. Facilities and Administrative Services Staff. Justice Mtpagement Piv.ision. U.S. Department of Justice. Washington. DC 20530 and the Office of Information and Regulatory Affairs. Office of Management al Budget. Public Use Reports Project (1103.0016). Washington. DC 20503. : I Full Name of gagriester t erFF-rt Cy enrerr 1 4/.) • i i I t i. . 'I .„_ ' a itzenstup1Status 2 LS/..64O.PC's STATES Social Security Number 3 ; , 1 I ' ...,/ Current Address CQ Le Li.):3 Teri ermur Et 33135 1 i I Date of Biril . T. o......t.... '2./N l'9_17...3 Place of Birth A./_e_w qock i .I i I 7 ; i I • i 1 ( clan under penury of perjury under the laws of the United States of Ameriel that the foregoinglis true and correct, and that I am the poison named abire. and I understand that any falsification of this statement is punishable under the provisions of 18 U.S.C. Section 1001 byla fine of not mist than 510.000 or by imprisonment of not more titan five years or both, and that requesting or obtaining any record(s) under false pictensts ii.Punishable under the provisions of S U.S.C. 552.3(iX3) by a fine of not more than S5.000. i I • I .------ 7 _______ Signature, i Date )/i 7 hi 1 i OPTIONAL:. ittothorizau a n to Release Information to Another Person I 1 This form is alsotip be riposted by a reethetter who is authorizing information rehiring to himself or h:nsetf lo be released to another person. I Further. PursWint I? 5 Onie Section 55240.1authorize the US. Dethutment of Justice to release any and all information relating to me to: ' I .1 • Print or Type Name Name of individual who is the subject of the record sought 2 Indivicival:submitting a request under the Privacy Act of 1974 must be either "tt citizen of the United States or an allot lawfully admitted for bernianeithwidcooc." pursuant to 5 U.S.C. Section.552a(a)(2). Requests will be processed as freedom of Information Act rohnsts purSitantito S 9.s.c. Section 552. rather than Privacy Act requests. for individuals who arc not United States citizens or aliens lawfully admitted for permanent residence. Providing ){our social security number is voluntary. You are asked to provide your social seetiiity number only to facilitate the identifiattionl of thank; relating to you. Without your social security number. the Department may Se unable to locate any or all records pertaining to,pion.: . 4 SignotOre of individual who is the subject of the record sought. I ' FORM APPROVIDD m aW. 11014:016 FORM 001•361 contES441/07 • sm.% EFTA01718412  Embassy of the United States of America Office of the Legal Attaché US Consulate File No. 03 December 2008 ActingCoordinator Americas, Europe, Middle East & Africa Desk Australian Federal Police Canberra, ACT Australia Re: Jeffrey Epstein Dear Mr. The United States Attorney's Office, West Palm Beach, Florida re uests the assistance of the Australian Federal Police (AFP) in delivering the enclosed letter to Ms. DOB of Canberra, Australia; telephone numbers an e letter references the outcome of a Non-Prosecution Agreement entered into by the U.S. Government and Mr. Jeffrey Epstein. The letter provides Ms. with the terms of the Agreement and contact information should she have any questions. On 24/07/06, the Federal Bureau of Investigation (FBI) Palm Beach Resident Agency (PBRA) opened an investigation involving the illegal sexual activity between multimillionaire Jeffrey Epstein and minor aged children. At the conclusion of the sexual activity, the minors were aid sums of money ranging from $200 - $1,000. Testimony from multi le witnesses indicate that a minor at the time, was one of Jeffrey Epstein's victims. Ms. . Epstein is currently incarcerated at the Palm Beach County Stocks e serving an mont t prison sentence, followed by a year of house arrest. Mr. Epstein will also be a life time registered sex offender. If you have any uestions regarding this request, please contact Assistant Legal Attaché Matthew C. Witt, at telephone Sincerely yours, UIitta By: Wstantlell iAttache Enc. I 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 agency. EFTA01718413  U.S. Department of Justice Federal Bureau of Investigation File No. 25 August 2008 Mr. Federal Agent Australian Federal Police Americas, Europe and Middle East.Desk Canberra, ACT, Australina Dear Federal Agent M ., The Miami Division of the Federal Bureau of Investigation (FBI) requests the assistance of the Australian Federal Police (AFP) in delivering a Victim Notification Letter and brochure to date of birth who has been contacted in the past at and/or On 24 July 2006, the Federal Bureau of Investigation (FBI), Palm Beach Resident Agency(PBCRA)opened an investigation involving the illegal sexual activity between multi- millionnaire Jeffrey Epstein and minor aged children. At the conclusion of the sexual activity, the minors were paid sums of mono ranging from $200.00-$1,000.00. Testimony from multiple witnesses indicate hat a minor at the time, was one ofJeffrey Epstein's victims. Mr. Epstein is believed to have had contact with during the years of 1998/99 - 2003/04. Under United States Code Title 18 Section 771,4 victim o a crime in the United States has a number of rights which are deiailed in the enclosed letter and brochures. It is requested that the Australian Federal Police locate and deliver the enclosed letter and brochure. If you have any questions regarding this request, please contact Assistant Legal Attache Matthew C. Witt at Sincerely, Assistant Leg Attache , EFTA01718414 12/07/07 FRI 15:31 FAX 1 Mel R I RRLAND&ELLI S LLP 91002 KIRKLAND & ELLIS LLP AHD Nnunre> IARMILINP1 Lffill~ere, pofnia Ken oth W. Styr To *Writrr I ctly: Feciarn,EIT. vrawie.rkland.cam December 7, 2007 VIA FACS1 E Honorable R. Alexander costa United States Attorney United States Attorney's Office South istrict of Florida 2 Rc: Jeffrey Epstein Dear Alex: As we discussed b hon earlier tody we • • • u issions with res et to an 11 We propose to have both submissions to you by no la -0 on Monde December 10. In the rn e wi O OW up with you y p one regar ng our su missions e ore ecoseobusiness on Monday. As , discussed • 4.1 Z712a...t1 Kenneth W. Starr cc: Honorable Alice Fisher, Assistant Attorney General , First Assistant U.S. Attorney Chicago Hong Kong London Mandl Nvei 'fork San Francisco WashIng:on, D.C. EFTA01718415  Fron-Fowler-White Burnett T-966 P.003/004 BiTe Dec-B7-117 finrfBna Affirmation I, Jeffrey E. Epstein do hereby re-affamt the Non-Prosecution Agreement and Addendum w same dared October 30, 2007. Aq- EFTA01718416 12/07/07 FRI 15:31 FAX 1 XIRRLAND&ELLI LLP 001 KIRKLAND & ELLIS LLP , Fax Transmittal Please notify us Immediately If any pages aro not received. THE INFORMATION CONTAINED IN THIS COMMUNICATION IS CONFIDENTIAL, MAY BE ATTORNEY-CLIENT PRIVILEGED, MAY CONSTITUTE INSIDE INFORMATION, AND IS INTENDED ONLY FOR THE USE OF THE ADDRESSEE. UNAUTHORIZED USE, DISCLOSURE OR COPYING IS STRICTLY PROHIBITED. AND MAY BE UNLAWFUL. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NO DIATELY AT: To: Company: Fax #: Direct VI: Hon. R.. Alexander Acosta United States Attorney's Office Southern District of Florida From: Pages Date: Fax #: Direct #: tover Kenneth W. Starr December 7, 2007 34 Message: O EFTA01718417 12/07/07 FRI 15:31 FAX 1 KIRRLAND&ELLIS LLP 2i003 Privileged and Confidential Attorney-Client Work Product ALSTON&BIRD LLP PROCEDURAL HISTORY Atlanta • Charlatt• Dallas! NawYork • Resenchlthingle•Maablageon,D.0 wwmeslarttom EFTA01718418  VICTIMS ge: 14 Sexual Contact with Epstein: (Epstein) watched as Epstein pstem Introduced unidentifi em e w o w e Epstein had with the um en m e -Epstein Ma Age: 17 Sexual Contact with E stein: - pstem tout Age: 17 Sexual Contact with Epstein: Epstein ( "rlfriendfassistant -E stein introduced to where they engaged in the RIMPAge: 16 Sexual Contact with E stein: Age: 17 EFTA01718419 Rete: 14 MIM I Age: 17 Sexual Contact with Epstein: tein by Epstein watched as Epstein engaged in with (girlfriend/assistant) -Epstein paid($200.00 for 5 minutes). Illa Age: 16 Sexual Contact with Epstein: stein 'PIM Age: 16 Sexual Contact with Epstein: Ma Age: 16 Sexual Contact with Epstein: stein pstein NOM Age: 15 Sexual Contact with Epstein: (Epstein) EFTA01718420 RPM. Age: 17 Sexual Contact with Epstein: E INN Age: 16 Sex Contact with Epstein: stein - patent ME M Age: 15 Sexual Contact with E stein: with when she was 17 years of age Wan Age: 17 Sexual Contact with Epstein: (Epstein) anAge: 17 Sexual Contact with Epstein: Epstein RIMI M Age: 16 Sexual Contact with Epstein: (Epstein) DOB: Age: 15 Sexual Contact with Epstein: (Epstein -Epstein instructed EFTA01718421 MEL Age: 16 Sexual Contact with Epstein: -Masturbation ***AGE is the age the Victim first encountered Epstein EFTA01718422 12/11/2007 11:37 FAX 002/099 KIRKLAND & ELLIS LLP L,,,Ngwub. ONJp,nPa007 Kenya W. Shan I o Call Wrier ForiChunile: ww....atioracom AS ": December I I. 2007 I lonorabic R. Alexander Acosta United Stales Attorney United States Attorney's Orrice Southern District of Florida , 33132 Re! Jeffrey F.pstein Ikar Alce: As we discussed during nur telephone eunversatiuns 011 both Friday and Monday (yesterday). we are ibminine two sc vale ctic that address nur broad areas of deep concern this flintier c arc grateful or your courtesy in agreeing to receive atld consider these submissions, and then to ineet to diszuss ihent. As you undertake your study and reflection. kindly allow me to make this pivotal point: Chicago Hong Kong London Munkh Nova York San Francom wahnngion. O C EFTA01718423  JEFFREY EPSTEIN Timeline-Summary 2/20/2007--Meeting (US: and 'I'll' DEF: Lilly Sanchez and Gerald Lefcourt). 6/26/2007--Meeting (US: , DEF: Alan Dershowitz, Roy Black, Gerald Lefcourt and Lilly Sanchez). 7/26/2007--Meeting (US: (conference call), and ). 7/31/2007--Meeting (US: and DEF: Roy Black, Gerald Lefcourt and Lilly Sanchez 8/31/2007--Meeting (US: and 9/7/2007--Meeting (US: Alexander Acosta, DEF: Kenneth Starr, Jay Lefkowitz, Lilly Sanchez). EFTA01718424 9/12/2007--Meeting (US: and , DEF: Jay Lefkowitz, Gerald Lefcourt and Jack Goldberger, STATE OF FLORIDA: Barry Krisher and Lanna Belohlavek). 9/18/2007--Rescheduled date for computer hearing.(Hearing initially set for 9/13/2007). 9/24/2007--Non-Prosecution Agreement signed. 9/25/2007--Scheduled date for Federal Indictment. EFTA01718425  JEFFREY EPSTEIN Timeline-Summary 2/20/2007--Meeting (US: and DEF: Lilly Sanchez and Gerald Lefcourt). 6/26/2007--Meeting (US: DEF: Alan Dershowitz, Roy Black, Gerald Lefcourt and Lilly Sanchez). 7/26/2007--Meeting (US: (conference call), and 7/31/2007--Meeting (US: and DEF: Roy Black, Gerald Lefcourt and Lilly Sanchez 8/31/2007--Meeting (US: and 9/7/2007--Meeting (US: Alexander Acosta, DEF: Kenneth Starr, Jay Lefkowitz, Lilly Sanchez). EFTA01718426 9/12/2007--Meeting (US: and DEF: Jay Lefkowitz, Gerald Lefcourt and Jack Goldberger, STATE OF FLORIDA: Barry Krisher and Lanna Belohlavek). 9/18/2007--Rescheduled date for computer hearing.(Hearing initially set for 9/13/2007). 9/24/2007--Non-Prosecution Agreement signed. 9/25/2007--Scheduled d'ate for Federal Indictment. EFTA01718427 Timeline-Summary 2/20/2007--Meeting (US: a and DEF: Lilly Sanchez and Gerald Lefcourt). 6/26/2007--Meeting (US: a MEIM. DEF: Alan Dershowitz, Roy Black, Gerald Lefcourt and Lilly Sanchez). 7/26/2007--Meeting (US: (conference call), and ). 7/31/2007--Meetin S: , , , En Sid DEF: Roy Black, erlitcWand Lilly Sanchez). 8/31/2007--Meeting (US: = , and O• 9/7/2007--Meeting (US: Alexander Acosta, Acosta, DEF: Kenneth Starr, Jay Le 9/12/2007—Meeting (US: and DEF: Jay Lefkowitz, Gerald Lefcourtgll Aoldberger, i STATE OF FLORIDA: Barry Krisher and Lanna Belohlavek). 9/18/2007—Scheduled date for computer hearing. 9/24/2007—Non-Prosecution Agreement signed. 9/25/2007-Scheduled date for Federal Indictment. EFTA01718428  U.S. Department of Justice United States Attorney Southern District of Florida unm 2-2111 (lam e: mom November 13, 2007 DELIVERY BY FACSIMILE Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP New York, New York 10022-4675 Re: Jeffrey Epstein Dear Jay: I write in response to your letter of November 8, 2007. Most importantly, I want to re-iterate Please advise me of the new date and time so that someone from our Office can be present. Your letter asserts that EFTA01718429 JAY P. LEFKOWITZ, ESQ. NOVEMBER 13,2007 PAGE 2 OF 3 Finall as to the matters related to EFTA01718430 JAY P. LEFKOWITZ, ESQ. NOVEMBER 13, 2007 PAGE 3 OF 3 Lastly, the statement at the end of your letter that you Please clarify your position on this point. Sincerely, R. Alexander Acosta United States Attorney By: First Assistant United States Attorney cc: It Alexander Acosta U.S. Attorney AUSA EFTA01718431 %to KIRKLAND 8. ELLIS LLP AND AMA= PAAMUSIOPS Jay P. Letkowitz, P.C. New or -4611 To Illy: Facsimile: www.ilitkland.com November 8, 2007 VIA E-MAIL • IL g .t ta nrney's Office Southern District of Florida MM 3132-2111 Re: Jetty Epstein Dear. I write in res onse to ,our recent letter dated November 5 2007. I want to make clear at the outset that o, iowever, want to a ress eac o e points you raise in your e er. Chicago Hong Kong London Los Angeles Munich San Francisco Washington, D.C. EFTA01718432  KIRKLAND & ELLIS LLP oven•007 Page 2 EFTA01718433  KIRKLAND & ELLIS LLP November 8, 2007 Page 3 I look forward to continuing to work with your Office to resolve any outstanding issues, and I sincerely anticipate a conclusion of this matter in the very near future. Sincerely, EFTA01718434  U.S. Department of Justice United States Attorney Southern District of Florida Miami, Fl33132-2111 November 5, 2007 DELIVERY BY FACSIMILE Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP New York, New York 10022-4675 Re: Jeffrey Epstein Dear Jay: EFTA01718435 L JAY P. LEFKOWITZ, ESQ. NOVEMBER 5, 2007 PAGE 2 OF 2 Sincerely, R. Alexander Acosta United States Attorney By: irst Assistant United States Attorney cc: R. Alexander Acos U.S. Attorney AUSA EFTA01718436  FW: Epstein settlement agreement Page 1 of 2 - FW: Epstein settlement agreement (USAFLS) @usdoj.gov] Sent: Friday, November 02, 2007 9:56 AM To: Importance: High DRAFT FYI. It went out this morning. Assistant U.S. Attorney est a m cac Phone Fax From: USAFLS) Sen 007 9:51 AM To: Cc: SAFLS) Sub] ps ein se ement agreement Dear Lanna: I was just informed that. a case d sition conference has been set in the Epstein case on Janu 2008. I also would appreciate it if you could send me a copy of the plea agreement, the Information that you plan to file (if it hasn't been filed already), and any factual proffer or other documents related to the plea. Please also let me know the date and time of the plea and sentencing so that someone from our office can attend and insure Mr. Epstein's compliance with the terms of his federal non-prosecution agreement. If you need any information regarding the federal investigation, or if you have any questions about the terms of the federal non-prosecution agreement, please do not hesitate to contact me at the number below or Marie in the West Palm Beach office. Thank you, irst is an ntted States Attorney larm, 10111132 ... 11/9/2007 EFTA01718437  FW: Epstein settlement agreement Page 2 of 2 4 •-te' 4 14/ Phone sststant U.S. Attome K. 1:• Li':. id 4. .1 .P " est • 173:=1;$ 4I Phone Fax From Sen r 29, To: USAFLS) Sub ps n settlement agreement Good evening. I am the ASA with the stein case in Palm Beach Coun . The ne otiated settlement is a definite o. ere ore, t e case was set or e rst wee o anuaty, ut e pea an sentence definitely occur efore the January 4th date that was agreed on by all for the sentencing. If you have any questions, please contact me at or Lanna Belohlavek ... 11/9/2007 EFTA01718438  UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No: 18 U.S.C. § 371 18 U.S.C. § 2423(e) 18 U.S.C. § 2423(d) 18 U.S.C. § 1591(a)(2) 18 U.S.C. § 2422(b) 18 U.S.C. § 2423(b) 18 U.S.C. § 1591(a)(1) UNITED STATES OF AMERICA vs. JEFFREY EPSTEIN, a/k/a and Defendants. INDICTMENT The Grand Jury charges that: BACKGROUND At all times relevant to this Indictment: 1. Defendant JEFFREY EPSTEIN employed defendants = a/k/a ' and to perform, among other things, services as personal assistants. 2. Defendant JEFFREY EPSTEIN owned a property located at Palm Beach, Florida, in the Southern District of Florida. EFTA01718439  3. Defendant JEFFREY EPSTEIN was the principal owner ofJEGE, INC., a Delaware corporation. JEGE, INC.'s sole business activities related to the operation and ownership of a Boeing 727-31 aircraft bearing tail number N908JE. 4. Defendant JEFFREY EPSTEIN served as president, sole director, and sole shareholder of JEGE, INC., and had the power to direct all of its operations. 5. Defendant JEFFREY EPSTEIN was a principal owner of Hyperion Air, Inc., a Delaware corporation. Hyperion Air, Inc.'s sole business activities related to the operation and ownership of a Gulfstream G-1159B aircraft bearing tail number N909JE. 6. Defendant JEFFREY EPSTEIN served as president, sole director, and sole shareholder of Hyperion Air, Inc., and had the power to direct all of its operations. 7. Pursuant to Florida Statutes Section 794.05, a "person 24 years of age or older who engages in sexual activity with a person 16 or 17 years of age commits a felony of the second degree." For purposes of "this section, `sexual activity' means oral, anal, or vaginal penetration by, or union with, the sexual organ of another; however, sexual activity does not include an act done for a bona fide medical purpose." Florida Statutes Section 794.021 states that "ignorance of the age [of the victim] is no defense," and that neither "misrepresentation of age by [the victim] nor a bona fide belief that such person is over the specified age [shall] be a defense." 8. Pursuant to Florida Statutes Sections 800.04(5)(a) and 800.04(5)(c)(2), an adult "who intentionally touches in a lewd or lascivious manner the breasts, genitals, genital area, or buttocks, or the clothinE covering them, of a person less than 16 years of age, or forces or 2 EFTA01718440 entices a person under 16 years of age to so touch the perpetrator, commits lewd or lascivious molestation," which is a felony of the second degree if the victim is 12 years of age or older but less than 16 years of age. 9. Pursuant to Florida Statutes Sections 800.04(6)(a) and 800.04(6)(b), an adult "who [i]ntentionally touches a person under 16 years of age in a lewd or lascivious manner or [s]olicits a person under 16 years of age to commit a lewd or lascivious act commits lewd or lascivious conduct," which is a felony of the second degree. 10. Pursuant to Florida Statutes Sections 800.04(7)(a) and 800.04(7)(c), an adult "who: (1) [i]ntentionally masturbates; (2) [i]ntentionally exposes the genitals in a lewd or lascivious manner; or (3) [i]ntentionally commits any other sexual act that does not involve actual physical or sexual contact with the victim, including, but not limited to . . . the simulation of any act involving sexual activity in the presence of a victim who is less than 16 years of age, commits lewd or lascivious exhibition," which is a felony of the second degree. 11. Pursuant to Florida Statutes Section 800.04(2), "[n]either the victim's lack of chastity nor the victim's consent is a defense to the crimes proscribed by [Section 800.04]." 12. Pursuant to Florida Statutes Section 800.04(3), "[t]he perpetrator's ignorance of the victim's age, the victim's misrepresentation of his or her age, or the perpetrator's bona fide belief of the victim's age cannot be raised as a defense in a prosecution under [Section 800.04]." 13. Pursuant to Florida Statutes Section 800.02, a "person who commits any unnatural and lascivious act with another person commits a misdemeanor of the second degree." 14. Defendant JEFFREY EPSTEIN was over the age of 24 and did not have any medical licensure. 3 EFTA01718441  15. During the period of their involvement with the Defendants, Jane Does # 3 and 10 attended in Palm Beach County. 16. During the periods of their involvement with the Defendants, Jane Does # 5, 6, 8, 12, 13, 14, 15, 16, 17, 18, and 19 attended in Palm Beach County. 17. During the period of her involvement with the Defendants, Jane Doe #7 attended in Palm Beach County. 18. During the period of her involvement with the Defendants, Jane Doe #9 attendec in Palm Beach County. 19. During the period of her involvement with the Defendants, Jane Doe #11 attended in Palm Beach County. COUNT 1 (Conspiracy: 18 U.S.C. § 371) 20. Paragraphs 1 through 19 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 21. From at least as early as 2001, the exact date being unknown to the Grand Jury, through in or around October 2005, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREaiaY:IEPSTEIN, I .a f did knowingly and willfully combine, conspire, confederate and agree with each other and with others known and unknown to commit an offense against the Unite