EFTA00183038.pdf

ROY BLACK BLACK JESSICA FONSECA-NADER HOWARD M. SREBNICK SaYIT A. KORNSPAN SREBNICK KATHLEEN P. PHILLIPS AARON ANTHON LARRY A. STUMPY? KORNSPAN MARCOS BEATON, JR. MARIA NEYRA JENIPER J. SOULUCIAS JACKIE PERCZEK STUMPF NOAH FOX MARK A.J.lAPIRO P.A. JOSHUA SHORE JARED E-Mail: RBlack(lfioyBlack.com May 18, 2010 VIA EMAIL AND U.S. MAIL Jeff Sloman, Esq. Assistant United States Attorney United States Attorney United States Attorney's Office 99 N.E. 4th Street Southern District of Florida Miami, FL 33132 500 South Australian Avenue Suite 400 West Palm Beach, Florida 33401 Assistant United States Attorney 99 N.E. 4th Street Miami, FL 33132 RE: Jeffrey Epstein Dear Counsel: We received notice this morning that Podhurst Orseck, P.A. has filed a civil complaint seeking over $2,000,000 in addition to the $526,000 they have already been paid by Jeffrey Epstein for their work as attorney representatives. As we communicated to you during our February 3, 2010 meeting and both before (January 20, 2010) and thereafter (February 18, 2010) by letter, see appended letters, there exists significant differences between fees that Mr. Epstein and his civil counsel believe are within his NPA obligations and additional amounts which the attorney representative is claiming are due. Mr. Epstein has in the past attempted to resolve issues relating to the outstanding invoices through efforts to review the particulars in the unpaid bills with the attorney representative, through settlement discussions with the attorney representative, and through his signing on February 16, 2010 a Special Masters Agreement which would allow a neutral third party to make a binding determination as to what portions of the invoices at issue were reasonable, non- 201 S. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131 • Phone: 305.371.6421 • Fax: 305•358-2006 • wm.RoyBlack.com EFTA00183038 Jeff Sloman. Esq. May 18, 2010 Page 2 duplicative, and within Mr. Epstein's NPA-obligations. As a preliminary matter, Mr. Epstein had been requesting, but did not receive, an invoice including billing dating back to the end of 2009 until May 11, 2010 - and even this invoice was without the charges of certain of the outside contractors relied upon by the Podhurst firm. We regret that these efforts did not resolve the matter and that Podhurst Orseck, P.A. elected instead to litigate. Mr. Epstein is today, in response to the lawsuit, filing a motion for authority to place $2,000,000 in an account maintained at the Clerk's Office for the United States District Court pending the results of the litigation. Mr. Epstein has always agreed that he is entirely responsible for any settlement-related fees that are not excessive and will take no litigation position inconsistent with that understanding. However, we have contended as a matter of principle that given the unexpected enormity of the claims for legal fees, that absent additional detail on why the invoiced fees were not duplicative and excessive and outside the ambit of Mr. Epstein's NPA obligations, payment should depend on either an agreement with the attorney representative which never occurred or a determination by a neutral third party. Mr. Epstein will pay whatever amount Judge Gold or any selected Master determine he owes under the NPA. Respectfully submitted, /wg Black, Srebnick. Kornspan & Stumpf, P.A. EFTA00183039  BURMAN, CRITTON LUTTIER&COLEMAN, LLP YOUR TRUSTED ADVOCATES A LIMITED LIABILITY PARTNERSHIP J. MICHAEL BURMAN. PA" ADELQ0 J. BENAVENTE PARALEGAVINvISTIGAToR GREGORY W. COLEMAN. RA. ROBERT D. CRITTON. JR. PA I JESSICA C.ADWELL BERNARD A. LEBEDEKER BOBBIE M. MCKENNA MARK T. LUTTIER. P.A. ASHLIE STOKEN•BARING MICHAEL J. PIKE BETTY STOKES PARALEGALS MICHAEL L. SCHEVE DEAN T. XENICK RITA H. BuDNYK or COUNSEL DAVID A. YAREMA May 25, 2010 EDWARD M. RICCI or COUNSEL 'FLORIDA WARD CERTIFIED CIVIL TRIM lAvAIR 2ADMITTED 70 PRACTICE IN FLORIDA AND COLORADO Honorable Edward B. Sent by email and Akerman Senterfitt by U.S. Mail to Judge only One SE Third Avenue Floor 28 Miami, FL 33131-1715 Re: Jeffrey Epstein Dear Judge We are in receipt of Mr. Josefsberg's letter to you dated May 21, 2010. We confirm that Mr. Epstein settled each and every case brought by the attorney-representative selected by you. We write this response only to advise you that Mr. Epstein has never refused to pay reasonable settlement-related fees that are within the scope of the NPA. He has already paid the attorney-representative $526,000. The attorney-representative has not yet presented him with a final invoice for settlement-related work. The incomplete invoices that have been presented seek $2,000,000 in additional fees. Mr. Epstein has been advised by his attorneys that the requested fees include duplicative work, charges that relate to preparation for litigation not settlement (thus outside his NPA-fee obligations) and charges that are unreasonable and that should be reviewed by a Court rather than simply paid without meaningful review. A significant amount of the total fees (over $1,000,000) is for legal work that the invoices document were done by two outside attorneys who are not even attorneys with the Podhurst Orseck, P.A. law firm. Mr. Epstein's disputes the necessity for and redundancy of these charges. We respect Your Honor's selection and regret that the issue of disputed fees has resulted in litigation. Mr. Epstein is committed to paying whatever fees and costs are determined by the 303 BANYAN BOULEVARD • SUITE 400 • WEST PALM BEACH. FL 33401 PHONE: 561-842-2820 • FAX: 561.844.6929 • [email protected] VVWW.BCLCLAW.COM EFTA00183040 May 25, 2010 Page 2 Court to be his obligation, if any, but he is not required to simply write a blank check. I have filed a motion in the case pursuant to F.R.Civ.P. 67, to allow him to deposit $2,000,000 in Trust with the Court pending the outcome of the Complaint which confirms his commitment. Cordially yo Rob D. Critton, Jr. RDC/JPL:ab Cc EFTA00183041 L EFTA00183042  . (USAFLS) From: Acosta, Alex (USAFLS) Sent: 811:55 AM To: . (USAFLS); Sloman, Jeff (USAFLS); (USAFLS); Lee, exter inson, Karen (USAFLS) Subject: RE: New proposed response to Jay How about a slightly different version: Thank you for your response. Our communications with Roy Black and later with you were solely to determine what Mr. Epstein considered to be the terms of the Non-Prosecution Agreement. We appreciate your answering our question with finality. You have now made clear that Mr. Epstein did not accept the December modification, and accordingly, we will now consider that modification to be a nullity. Pursuant to our Agreement, I will prepare an Amended Notification that contains the name of additional identified victims. In accordance with Paragraph 7B, please provide me with a proposed written submission to the Special Master by Monday afternoon. Finally, as you are aware, yhe United States has been ordered to produce the Non-Prosecution Agreement. In accordance with that Order, we will produce the September Agreement with the October Addendum signed by your client. We understand that Mr. Goldberg may not have provided the state court with a true copy of the complete Agreement, and he should take steps to correct that error. From: . (USAFLS) Sent: Friday, August 15, 2008 11:42 AM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Subject: New proposed response to Jay Dear Jay: Thank you for your response. Our communications with Roy Black and later with you were solely to determine what Mr. Epstein considered to be the terms of the Non-Prosecution Agreement. You have now made clear that Mr. Epstein did not accept the December modification and does not intend to perform the obligations set forth therein. The Office is not going to continue negotiating the terms of the Agreement. We only sought finality and you have answered our question. Accordingly, the December proposed modification is hereby withdrawn. The United States has been ordered to produce the Non-Prosecution Agreement and, in accordance with that Order, will produce the September Agreement with the October Addendum signed by your client. Mr. Goldberger should be advised that we understand he has not provided the state court with a true copy of the complete Agreement, and he should take steps to correct that error. I will prepare an Amended Notification that contains the name of additional identified victims and will provide that to you promptly. In accordance with Paragraph 7B of the Agreement, please provide me with a proposed written submission to the Special Master by Monday afternoon. We will expect a showing of good faith in the selection of the 1 EFTA00183043 attorney representative and all other terms of the Agreement and excessive delays, like those that have occurred in the past, will be considered a breach of that duty of good faith. Sincerely, Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West P 33401 Phone Fax 561 820-8777 2 EFTA00183044  LAW OFFICE • aittel&Atter444 AND ASSOCIATES July 3, 2008 VIA CERTIFIED MAIL United States Attorney's Office RETURN RECEIPT REQUESTED 500 South Australian Avenue 7007 2680 0002 5519 8503 West Palm Beach, Florida 33401 Dear Ms. Villafana: As you are aware, we represent several of the young girls that were victimized and abused by Jeffrey Epstein. While we are aware of his recent guilty plea and conviction in his State Court case, the sentence imposed in that case is grossly inadequate for a sexual predator of this magnitude. The information and evidence that has come to our attention in this matter leads to a grave concern that justice will not be served in this cause if Mr. Epstein is not aggressively prosecuted and appropriately punished. Based on our investigation and knowledge of this case, it is apparent that he has sexually abused more than 100 underage girls, and the evidence against him is overwhelmingly strong. As former Assistant State Attorneys with seven years' prosecution experience, we believe that the evidence against Mr. Epstein is both credible and deep and that he may be the most dangerous sexual predator of children that our country has ever seen. The evidence suggests that for at least 4 years he was sexually abusing as many as three to four girls a day. It is inevitable that if he is not confined to prison, he will continue to manipulate and sexually abuse children and destroy more lives. He is a sexual addict that focused all of his free time on sexually abusing children, and he uses his extraordinary wealth and power to lure in poor, underprivileged little girls and then also uses his wealth to shield himself from prosecution and liability. We are very concerned for the health and welfare of the girls he has already victimized, and concerned that if justice is not properly served now and he is not imprisoned for a very long time, he will get a free pass to sexually abuse children in the future. Future abuse and victimization is obvious to anyone who really reviews the evidence in this case, and future sexual abuse of minors is inevitable unless he is prosecuted, tried and appropriately sentenced. Money and power should not allow a man to make his own laws, and he has clearly received preferential treatment at every step up to this point. If he were a man of average wealth or the abused girls were from middle or upper class families, then this man would spend the rest of his life in prison. In a country of true, blind justice, those distinctions are irrelevant, and we really hope he does not prove the point that a man can commit heinous crimes against children and buy his way out of it. If the Department of Justice's recent commitment to the protection of our children from child molesters is to be more than rhetoric, then this is the time and the case where the Department must step forward. We urge the Attorney General and our United States 2028 'N STREET,SUITE 202, HOLLYWOOD, FLORIDA 33020 OFFIOEt 954-414-8033/305-935-2011 FAX* 954-924-1530/305-935-4227 BEOBRADEDWARDSLAW.00M EFTA00183045 United States Attorney's Office Page Two Attorney to consider the fundamental import of the vigorous enforcement of our Federal laws. We urge you to move forward with the traditional indictments and criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take the steps necessary to protect our children from this very dangerous sexual perpetrator. We will help you to do this in any way possible to ensure that true Justice is served in this case. Sincerely, Brad Edwards, Esquire Jay Howell, Esquire 2028 8TRERT,SUITII 202, HOLLYWOOD, FLORIDA 33020 OFFICE: 954-414-8033/305-935-2011 FAX: 954-924-1530/305-935-4227 BRORADEDWARD8LAW.OO11 EFTA00183046  LAW OFFICE • Olierateeds • AND ASSOCIATES October IS, 2008 AUSA United States Attorney's Office 99 N.E. 4th Street Miami, Florida 33132 Re: Jane Doe # and Jane Doe #21. United States of America Case No.: 08-80736-CIV-MARRA/JOHNSON Dear Mr. Lee: I am writing to inquire about whether Mr. Epstein has violated his Non-Prosecution Agreement with the Government. As you know, the Government has repeatedly described the Non-Prosecution Agreement as guaranteeing to the victims of Epstein's sexual abuse at least $150,000 in civil damages. The Government has made these representations in reliance on a current provision in the U.S. Code — 18 U.S.C. § 2255(a) — which provides for an automatic amount of damages of at least $150,000. At the time that the Non-Prosecution Agreement was drafted and signed, that was the law that was in effect. In Epstein's latest filing in federal court, however, he takes the position that the pre-2006 Amendments version of the law applies. See Defendant Epstein's Motion to Dismiss, for Mo Definite Statement and To Strike Directed to Plaintiff Jane Doe's Complaint at 9, Jane Doe'. Jeffrey Epstein, No. 08-CIV-80893-Marrallohnson (discussing § 2255 and stating that the "applicable version of the statute" is "pre-2006 Amendments"). The 2006 Amendments altered § 2255(a), by increasing the presumed minimum damages from $50,000 to $150,000. See Pub. L. 109-248, Title VII, § 7070:0, (c), July 27, 2006, 120 Stat. 650. In light of Epstein's latest filing, I write to ask several questions: (1) Would you stipulate that you told me several times that Epstein had agreed to pay at least $150,000 to the identified victims of his abuse? (2) Did Epstein in fact agree to pay damages to the identified victims of his abuse at least $150,000? (3) Did the Government tell victims, either directly or through counsel, that Epstein had agreed to pay his victims at least $150,000? 2028 STREET, SUITE 202, HOLLYWOOD, FLORIDA 33020 • OFFICE: 034-414-8033/305-935.-2011 FAX: 354.-924-1530/308-938-4227 • B EDE RADED WARDS LAW. COM EFTA00183047  , AUSA United States Attorney's Office October 15, 2008 Page Two (4) Is Epstein in compliance with his Non-Prosecution Agreement with the Government when he is now taking the legal position, through his attorneys, that he only has to pay the victims $50,000 damages under § 2255? Thank you for any clarification you can provide on these questions. Sincerely, BE/sg Brad Edwards cc: United States Attorney's Office 500 South Australian Avenue West Palm Beach, Florida 33401 2028 STREET,SUITE 202, HOLLYWOOD, FLORIDA 33020 OFFICE: 954-414-8033/305-935-2011 FAX: 954-924-1530/305-935-4227 BEOBRADEDWARDSLAW.COM EFTA00183048  U.S. Department of Justice United States Attorney Southern District ofFlorida 500 South Australian Ave, Suite 400 West Palm Beach, FL 33401 (561)820-8711 Facsimile: (561) 820-8777 June 27, 2008 VIA FACSIMILE Jack A. Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. One Clearlake Centre, Suite 1400 250 Australian Ave S. West Palm Beach, FL 33401-5015 Roy Black, Esq. Black Srebnick Kornspan & Stumpf P.A. 201 S. Biscayne Blvd, Suite 1300 Miami, FL 33131 Re: Jeffrey Epstein Dear Messrs. Goldberger and Black: I write to follow up on my e-mail correspondence of June 24 and June 26, and my message this morning. As of 3:15 p.m., Friday, June 27, 2008, the Office still has not received a copy of a proposed plea agreement between Mr. Epstein and the State Attorney's Office, nor has the Office received notice of a date and time for a change of plea. As you know, the Non-Prosecution Agreement between Mr. Epstein and the Office called for Mr. Epstein to plead, be sentenced, and begin serving his sentence not later than January 4, 2008—almost six months ago. The Office has continued that deadline to allow Mr. Epstein to raise various issues with the Department of Justice, but repeatedly advised that, once those appeals were completed, Mr. Epstein would need to perform the terms of the agreement within a short window thereafter. Now that those appeals have been exhausted, we promptly informed counsel for Mr. Epstein that he must enter his plea, be sentenced, and begin serving his sentence by 5:00 on Monday, June 30, 2008. This week I have sent two e-mails and left a message with Mr. Black's receptionist asking for the date and time of the change of plea and for a copy of the proposed plea agreement between Mr. Epstein and the State Attorney's Office in accordance with the terms of the Non-Prosecution Agreement. I have received no response to any of those requests. EFTA00183049 JACK GOLDBERGER, ESQ. ROY BLACK, ESQ. Jut€ 27, 2008 PAGE 2 OF 2 I have received correspondence from counsel for a witness asking to cancel or continue the witness's appearance because he "understand[s] that there has been a recent development with respect to Mr. Epstein in that he intends to plead guilty in Florida state court on Monday pursuant to a deferred prosecution agreement with your office that has already been executed" and that he has "learned from Mr. Epstein's attorney that the plea is scheduled to take place on Monday morning." I also understand that there is an entry on Judge McSorley's docket that a hearing is scheduled for 8:30 a.m. on Monday. Both parties have agreed that it is a material term of the Non-Prosecution Agreement that the United States shall have the right to review the terms of any agreements between Epstein and the State Attorney's Office prior to entering into those agreements. If, indeed, the change of plea is set for 8:30 Monday morning, the agreement with the State Attorney's Office must be provided to the Office by 4:30 today to allow adequate time to review and comment. Failure to provide this opportunity shall be deemed a breach of the Agreement. Accordingly, I again ask that you provide me with a copy of the Plea Agreement with the State Attorney's Office and notification of the date and time of the change of plea. Thank you. Sincerely, R. Alexander Acosta United States Attorney By: Assistant United States Attorney cc: AUSA EFTA00183050  THE PALM BEACH POST • FRIDAY, SEPI EMBER 4 2009 Appeals court backs unsealing of Epstein's '07 deal with feds By SUSAN SPENCER-WENDEL ey manager of billionaires Palm Reath Post Staff Writer have fought vigorously WEST PALM BEACH — against the agreements An appeals court has release. They have 15 affirmed a lower court days to request a rehear- ruling unsealing the con- ing with the 4th District fidential deal Jeffrey Ep- Court of Appeal. stein struck with federal Absent that, it will be- Epstein prosecutors to avoid being come public. Attorneys charged by them. Epstein local criminal for the The 4th District Court defense attorney jack • Palm Beach of Appeal this week up- Goldberger did not return money held Circuit Judge Jeffrey a call seeking comment manager Colbathb earlier decision Epstein own attorneys, have 15 to unseal the agreement in federal filings, have days to seek Attorneys for the mon- See EPSTEIN, 6B ► a rehearing. Civil litigation intensifies; deposition ends abruptly ► EPSTEIN from IB referred to his confiden- An attorney's questioning tial deferred prosecution of Epstein becomes personal. agreement with the U.S. Attorney's Office, struck in September 200Z as "un- precedented" and "highly Donald 'frump and Prince who represents an alleged unusual." Andrew. "International victim identified only as Attorneys for The Palm Moneyman of Mystery," "B.B.", Kuvin questioned Beach Post as well as al- declared a 2002 New York Epstein about the shape leged victims of Epsteinb magazine profile of Ep- of his genitalia and the sexual advances sought to stein. deposition abruptly ended, have the deal unsealed in He pleaded guilty in according to a transcript. state court 2008 to procuring teens Kuvin has since made Colbath found that the for prostitution and was a motion in court to be proper.sealing procedures sentenced to 18 months able to inspect Epstein had not been followed by in jail, but allowed out ex- genitalia. an earlier judge. tensively for work release. Kuvin said Thursday he "There is nothing more Epstein was released in seeks to corroborate a de- fundamentally important late July, after serving'13 scription one woman gave than for the public and months of the sentence. Palm Beach police. press to observe how the He now faces civil Because Epstein is in- government is doing its lawsuits filed by young voking his right to remain job," Post attorney Deantia women allegedly lured to silent in depositions, this Shullman has said. "There his Palm Beach home and is the only way to do it, is great public interest paid to perform massages Kuvin said. in how everybody in this and other acts. "We want to corroborate case is doing their job." That civil litigation is. what those girls saw," According to various intensifying Kuvin said. media accounts, Epstein This week, while Ep- moved in circles that in- stein was being deposed e susan_spencer weneleUt cluded President Clinton, by attorney Spencer Kuvin, pbposl.com 4 EFTA00183051  U.S. Department of Justice United States Attorney Southern District ofFlorida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: (561) 820-8777 June 27, 2008 VIA FACSIMILE AND ELECTRONIC MAIL Jack A. Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. One Clearlake Centre, Suite 1400 250 Australian Ave S. West Palm Beach, FL 33401-5015 Roy Black, Esq. Black Srebnick Kornspan & Stumpf P.A. 201 S. Biscayne Blvd, Suite 1300 Miami, FL 33131 Re: Jeffrey Epstein Dear Messrs. Goldberger and Black: Thank you for providing me with the proposed plea agreement between Mr. Epstein and the State Attorney's Office. The U.S. Attorney's Office hereby provides Notice that the proposed sentencing provision does nit comply with the terms of the Non-Prosecution Agreement. The second sentencing paragraph of the proposed plea agreement reads: On 08CF009381AMB, the Defendant is sentenced to 18 months Community Control I (one). As a special condition of this Community Control, the Defendant must serve the first 6 months in the Palm Beach County Detention Facility . The Non-Prosecution Agreement specifically provides: Epstein shall be sentenced to consecutive terms of twelve (12) months and six (6) months in county jail for all charges, . . . without probation or community control in lieu of imprisonment. Thus, the proposed plea agreement with the State Attorney's Office does not comply with the terms of the Non-Prosecution Agreement. To comply with the Agreement, Mr. Epstein must make a binding recommendation of eighteen months imprisonment, which means confinement twenty-four EFTA00183052 JACK GOLDBERGER, ESQ. ROY BLACK, ESQ. JUNE 27, 2008 PAGE 2 OF 2 hours a day at the County Jail, and the judge must accept that recommendation. Community control must follow that term of incarceration. Secondly, we have not been provided with a copy of the Information filed in case number 08CF009381AMB. I want to confirm that Mr. Epstein is being charged with the substantive offense of procuring minors to engage in prostitution, not attempted procurement. Accordingly, please provide me with a copy of the Information at your earliest opportunity. I will be available via e-mail throughout the weekend or you may reach me on my cell phone at 561 601-2301. Thank you. Sincerely, R. Alexander Acosta United States Attorney By: Assistant United States Attorney cc: AUSA EFTA00183053  U.S. Department of Justice United States Attorney Southern District ofFlorida 500 South Australian Ave., Suite 400 West Palm Beach FL 33401 (561)8204711 Facsimile: (561) 820-8777 July 17, 2008 VIA FA SIMILE , Esq. Lewis Tein, P.L. 3059 Grand Avenue, Suite 340 Coconut Grove, FL 33133 Re: Jeffrey Epstein Dear Mr. Tein: The Office has reviewed your "Notice of Continued Pendency of Federal Criminal Action," and we feel that it misrepresents the posture of the federal investigation. For example, you cite toIn re Grand Jury, No. FGJ 07-103 (WPB), as evidence that the federal criminal action remains pending. That is a citation to Mr. Epstein's Motion to Quash a subpoena for computer equipment removed from Mr. Epstein's home after he and his attorneys were aware of the existence of the state investigation. Pursuant to the Non- Prosecution Agreement, that motion was supposed to have been withdrawn several months ago, and, therefore, is not "pending" in our estimation. The Non-Prosecution Agreement calls for deferment of federal prosecution "in favor of prosecution by the State of Florida, provided that Epstein abides by the [enumerated] conditions and the requirements of th[e] Agreement . .." (Non-Prosecution Agreement, p. 2 (emphasis added).) One of those conditions is Epstein's agreement that the subject Jane Does, while minors, were victims of a violation of an offense enumerated in Title 18, United States Code Section 2255, and that they "will have the same rights to proceed under Section 2255 as [they] would have had if Mr. Epstein had been tried and convicted of an enumerated offense." (United States Attorney's December 19, 2007 letter to Lilly Ann Sanchez.) If, in fact, your position is that the federal criminal action is still pending such that the Court must stay the civil proceedings, then the Office proposes that we seek the prompt resolution of the Motion to Quash, so that the computer equipment can be analyzed and the EFTA00183054 MICHAEL TEIN, ESQ. JULY 17, 2008 PAGE 2 federal investigation can continue. If, instead, Mr. Epstein intends to fully abide by the Non- Prosecution Agreement, then the "federal Grand Jury investigation will remain suspended, and all pending federal Grand Jury subpoenas will be held in abeyance unless and until [Epstein] violates any term of [the Non-Prosecution Agreement]." (Non-Prosecution Agreement, page 5.) Please advise whether you intend to correct the representations to the Court regarding the status of the federal investigation. Sincerely, R. Alexander Acosta United States Attorney Assistant United States Attorney cc: Jack Goldber er, Esq. , Esq. EFTA00183055  U.S. Department of Justice United Stales Attorney Southern District ofFlorida A. Mark PiIktfaila 500 S. Australian Ave, 4th Floor West Palm Reach, Florida 33401 (561) 8204711 Facsimile (S61) 820-8777 FACSIMILE COVER SHEET TO: FAX NO. PHONE NO. TO: Jack Alan Goldbereer FAX NO. PHONE NO. DATE: July 17, 2008 N OF PAGES: 3 RE: Jeffrey Epstein FROM: . Assistant U.S. Attorney PHONE NO. COMMENTS: EFTA00183056 UY/17/011 18:17 PAX 150111594528 USAO WEST PALM a001 ********************* s** TX REPORT **s ********************* TRANSMISSION OK TX/RX NO 3957 CONNECTION TEL 8358091 SUDADDRESS CONNECTION ID ST. TIME 07/17 18:16 USAGE T 00'42 PGS. SENT 3 RESULT OK U.S. Department of Justice United States Attorney Southern District of Florida A. Marie Pi/Jolene 500 S. Australian Ave, 4th Floor West Palm Beach, Florida 33401 (561) 820-8711 Facsimile (361)820-8777 FACSIMILE COVER SHEET TO: FAX NO. PHONE NO. TO: Jack Alan Goldberger FAX NO. PHONE NO. DATE: July 17, 2008 # OF PAGES: 3 RE: Jeffrey Epstein FROM: Assistant U.S. Attorney PHONE NO. EFTA00183057 07/17/08 18:18 FAX 15618594526 USAO WEST PALM [6001 *** TX REPORT *44 TRANSMISSION OK TX/RX NO 3958 CONNECTION TEL 13054426744 SUBADDRESS CONNECTION ID ST. TIME 07/17 18:17 USAGE T 01'04 PGS. SENT 3 RESULT OK U.S. Department of Justice United States Attorney Southern District of Florida A. Marie Villa/aft 500£ Australian Ave, 4th Floor West Palm Beach, Florida 3340! (561) 820-8711 Facsimile (561)8204777 FACSIMILE COVER SIIEET TO: FAX NO. PHONE NO. TO: Jack Alan Goldberzer FAX NO. PHONE NO. DATE: July 17. 2008 # OF PAGES: 3 RE: Jeffrey Epstein FROM: Assistant U,S. Attorney PHONE NO. EFTA00183058  IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CRIMINAL DIVISION "W" CASE NO. 502008CF009381AXXINB 502006CF009454AXXMB STATE OF FLORIDA, vs. JEFFREY EPSTEIN, Defendant / ORDER RELEASING DOCUMENTS UNDER SEAL Fourth District Court of THIS MATTER came before the Court as a result of the , wherefore it is Appeal's per curiam affirmance of the trial court's order red to as ORDERED AND ADJUDGED that the documents refer file on July 2, 2008, A. "Non-Prosecution Agreement" filed under seal in the court r seal in the court B. "The Addendum to the Non-Prosecution Agreement" filed unde filed on August 25, 2008, shall be released. ndum contain the names of The Court notes that neither the Agreement nor the Adde be released contemporaneously with this any alleged juvenile victims. These documents will order. County, Florida this DONE AND ORDERED in West Palm Beach, Palm Beach I a day of September, 2009. JEFFREY .. COLBATH Circuit 'ourt Judge Copies furnished: District R. Alexander Acosta, U.S. Attorney's Office - Southern 500 South Australian Avenue, Suite 400 West Palm Beach, FL 33401 EFTA00183059 Page Two )0(MB Case No. 502008CF009381A)C<MB/502006CF009454A Order Releasing Documents Under Seal Barbara Burns, Esq., State Attorney's Office 401 North Dixie Highway West Palm Beach, FL 33401 William J. Berger, Esq. Bradley J. Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard., Suite 1650 Ft. Lauderdale, FL 33394 Robert D. Critton, Esq. Burman, Critton, Luttier & Coleman 515 North Flagler Drive, Suite 400 West Palm Beach, FL 33401 Jack A. Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Spencer T. Kuvin, Esq. Leopold-Kuvin, P.A. 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, FL 33410 Deanna K. Shullman, Esq. P. O. Box 2602 Tampa, FL 33602 EFTA00183060  P. 006/01S •J0.8-30-200801011) 10:06 IN RE: LNYESTIGATION OF JEFFREY EPSTEIN NataRGSECE1013AGREEITEIE and the State IT APPEARING that the City of Palm Beach Police Department and for Palm Beach Count y (hereinafter, Attorney's Office for the 15th Judicial Circuit in condu ct of Jeffrey investi gation into the the "State Attorney's Office") have conducted an Epstein (hereinafter "Epstein"); d Epstein by indictment IT APPEARING that the State Attorney's Office has charge s Sectio n 796.07; with solicitation of prostitution, in violation of Florida Statute and the Federal Bureau of IT APPEARING that the United States Attorney's Office into Epstei n's background and any Investigation have conducted their own invesdgation United States from in or offenses that may have been committed by Epstein against the around 2001 through in or around September 2007, including: wn to (1) knowingly and willfully conspiring with others known and unkno is, to use a facility or means commit an offense against the United States, that , or entice of interstate or foreign commerce to knowingly persuade, induce States violatio n of Title 18, United minor females to engage in prostitution, in Code, Section 2422(b); all in violationof Title 18,Un ited States Code, Section 371; wn to travel (2) lmowingly and willfblly conspiring with others known and unkno in interstate commerce for the ptnpos e of eogagi ng in illicit scared conduct, as female s, in violati on of Title 18, defined in 18 U.S.C. § 2423(9, with minor all in violatio n of Title 18, United States United States Code, Section 2423(6); Code, Section 2423(e); knowingly (3) using a facility or means of interstate or foreign commerce to persuade, induce, or entice minor female s to engag e in prostit ution; in s 2422(b ) and 2; violation of Title 18, United States Code, Section sexual (4) traveling in intestate commerce for the purpose of engaging in