MEMY-1805 marker2-fixhub ds9 (pepper 16-core): 34000/34090

marker2-fixhub/ds9/EFTA00189243/EFTA00189243.md

@@ -0,0 +1,32 @@
+**Villafana, Ann Marie C. (USAFLS)**
+
+---
+
+**From:** Villafana, Ann Marie C. (USAFLS)  
+**Sent:** Wednesday, December 19, 2007 12:56 PM  
+**To:** Acosta, Alex (USAFLS)  
+**Cc:** Sloman, Jeff (USAFLS); Leclainche, Janice (USAFLS)  
+**Subject:** Issue raised by Epstein's defense team
+
+On Friday, Mr. Epstein's defense team argued for the first time that the state charge contained in the Non-Prosecution Agreement does not apply to the facts of his case. As an ethical matter, the Office does not want a defendant to plead guilty to a crime that he did not commit; however, we are not experts in the interpretation of the Florida Criminal Code, so we look to you for guidance. To assist, I have listed the statute below and summarize the arguments of Mr. Epstein's attorneys. I also have included the factual proffer that Ms. Belohlavek requested so you can determine whether, in your opinion, there is a sufficient factual basis for a plea.
+
+Fl. Stat. 796.03 states: "A person who procures for prostitution, or causes to be prostituted, any person who is under the age of 18 years commits a felony of the second degree . . ."
+
+Fl. Stat. 777.011 states: "Whoever commits any criminal offense against the state, whether felony or misdemeanor, or aids, abets, counsels, hires, or otherwise procures such offense to be committed, and such offense is committed or is attempted to be committed, is a principal in the first degree and may be charged, convicted, and punished as such, whether he or she is or is not actually or constructively present at the commission of such offense."
+
+Mr. Epstein's counsel state that Section 796.03 applies only to procuring a minor to engage in a sex act with a third party, not with the defendant himself, relying on Kobel v. State, 745 So.2d 979, 982 (Fla. 4{sup}`th` DCA 1999), and Register v. State, 715 So.2d 274, 278 (Fla. 1{sup}`st` DCA 1998). They also assert that a commercial motive must be shown.
+
+Please consider whether the following facts are sufficient to prove a violation of Section 796.03, when read in conjunction with Section 777.011:
+
+From at least as early as 2001 through October 2005, the defendant, Jeffrey Epstein, procured at least 30 identified minor females between the ages of 14 and 17 in Palm Beach County to come to his home in Palm Beach to engage in sexual conduct in exchange for money. In particular, the defendant would pay females, including minors, \$200 to recruit other females, including minors, to come to his house to engage in sexual activity. The minors who were procured would receive between \$200 and \$1,000 depending upon the type of sexual activity that they engaged in. Several victims have stated that, when they were unwilling to engage in sexual activity with the defendant, the defendant would ask them to bring other girls instead, and promised to pay them \$200 for each girl whom they brought. Mr. Epstein would regularly ask his recruiters to find new girls for him because he wanted "fresh faces."
+
+In some instances, the defendant did not know the correct age of the minor female who was procured as a prostitute, but in more than half of the instances he did. For example, the defendant purchased gifts for some girls for their 18th birthdays, promised to send them on trips when they turned 18, talked with them about activities at their high schools; and provided transportation for those who could not drive.
+
+The sexual activity the defendant engaged in with the minor females included: requiring minor females to perform topless or nude massages while the defendant masturbated himself; fondling the breasts and vaginas of the minor females; digital penetration of the vaginas of minors; the use of a massaging device on the vaginas of minors; requiring a minor female to pose for nude photographs; requiring minor females to watch others (including the defendant) engage in sexual intercourse; requiring minor females to fondle the breasts of the defendant's adult female companion; performing oral sex on minor females; requiring minor females to perform oral sex on the defendant's adult female companion; and sexual intercourse with minor females. There are four minor females who engaged in vaginal intercourse with the defendant in exchange for money. None of the minor females who was brought to Mr. Epstein's house had ever engaged in prostitution prior to being procured by one of Mr. Epstein's recruiters.
+
+*A. Marie Villafaña*  
+Assistant U.S. Attorney  
+500 S. Australian Ave, Suite 400  
+West Palm Beach, FL 33401  
+Phone 561 209-1047  
+Fax 561 820-8777

marker2-fixhub/ds9/EFTA00189243/EFTA00189243.receipt.json

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marker2-fixhub/ds9/EFTA00189245/EFTA00189245.md

@@ -0,0 +1,165 @@
+## Villafana, Ann Marie C. (USAFLS)
+
+From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, December 20, 200711:01 AM To: Sloman, Jeff (USAFILS) Subject: RE: State of Florida I Jeffrey Epstein. Case No. 2006CF009454AXX
+
+I like it. I don't know about trying to limit its distribution, but maybe add something like, "1 hope that you. Mr. Krischer. and I will have a chance to discuss this openly and objectively before Mr. Epstein's counsel provides us with their slanted view."
+
+A. Marie Villalaila Assistant U.S. Attornel 500 S. Australian Ave. Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+From: Sloman, Jeff (USAFLS) Sent: Thursday, December 20, 2007 10:54 AM To: Villafana, Ann Marie C. (USAFLS) Subject: State of Florida I Jeffrey Epstein, Case No. 2006CF009454AXX
+
+Marie.
+
+I've tailored your email for Lana a little bit. Before I press send, please take a look one more time. Perhaps we should include some caveat to prohibit further distribution. What do you think?
+
+Jeff
+
+Ms. Belohlavek,
+
+I called you this morning and left a message. I wanted to inform you that on Friday, December 14, 2007, Jeffrey Epstein's defense team argued, for the first time, that the state charge contained in the Non-Prosecution Agreement does not apply to the facts of his case. As an ethical matter, the U.S. Attorney's Office for the Southern District of Florida does not want a defendant to plead guilty to a crime that he did not commit; however, we are not experts in the interpretation of the Florida Criminal Code, so we look to you for guidance. To assist, I have listed the statute below and summarized the arguments of Mr. Epstein's attorneys. I also have included the factual proffer that you have previously requested so that you can determine whether, in your opinion, there is a sufficient factual basis for a plea.
+
+Fl. Stat. 796.03 states: "A person who procures for prostitution, or causes to be prostituted, any person who is under the age of 18 years commits a felony of the second degree ..."
+
+Fl. Stat. 777.011 states: "Whoever commits any criminal offense against the state, whether felony or misdemeanor, or aids, abets, counsels, hires, or otherwise procures such offense to be committed, and such offense is committed or is attempted to be committed, is a principal in the first degree and may be charged, convicted, and punished as such, whether he or she is or is not actually or constructively present at the commission of such offense."
+
+Mr. Epstein's counsel state that Section 796.03 applies only to procuring a minor to engage in a sex act with a third party, not with the defendant himself, relying on Kobel State, 745 So.2d 979, 982 (Fla. 4{sup}`th` DCA 1999), and Register v. State, 715 So.2d 274, 278 (Fla. 1{sup}`st` DCA 1998). They also assert that a commercial motive must be shown. Please consider whether the following facts are sufficient to prove a violation of Section 796.03, when read in conjunction with Section 777.011.
+
+From at least as early as 2001 through October 2005, the defendant, Jeffrey Epstein, procured at least 30 identified minor females between the ages of 14 and 17 in Palm Beach County to come to his home in Palm Beach to engage in sexual conduct in exchange for money. In particular, the defendant would pay females, including minors, \$200 to recruit other females, including minors, to come to his house to engage in sexual activity. The minors who were procured would receive between \$200 and \$1,000 depending upon the type of sexual activity that they engaged in. Several victims have stated that, when they were unwilling to engage in sexual activity with the defendant, the defendant would ask them to bring other girls instead, and promised to pay them \$200 for each girl whom they brought. Mr. Epstein would regularly ask his recruiters to find new girls for him because he wanted "fresh faces."
+
+In some instances, the defendant did not know the correct age of the minor female who was procured as a prostitute, but in more than half of the instances he did. For example, the defendant purchased gifts for some girls for their 18th birthdays, promised to send them on trips when they turned 18, talked with them about activities at their high schools; and provided transportation for those who could not drive.
+
+The sexual activity the defendant engaged in with the minor females included: requiring minor females to perform topless or nude massages while the defendant masturbated himself; fondling the breasts and vaginas of the minor females; digital penetration of the vaginas of minors; the use of a massaging device on the vaginas of minors; requiring a minor female to pose for nude photographs; requiring minor females to watch others (including the defendant) engage in sexual intercourse; requiring minor females to fondle the breasts of the defendant's adult female companion; performing oral sex on minor females; requiring minor females to perform oral sex on the defendant's adult female companion; and sexual intercourse with minor females. There are four minor females who engaged in vaginal intercourse with the defendant in exchange for money. None of the minor females who was brought to Mr. Epstein's house had ever engaged in prostitution prior to being procured by one of Mr. Epstein's recruiters.
+
+**From:** Lanna Belohlavek [mailto:Lbelohla@sa15.state.fl.us]  
+**Subject:** RE: RE: Epstein settlement agreement
+
+The plea and sentence will both occur on the same date and that date will be before January 4th.
+
+
+**From:** lbelohlavek@bellsouth.net [mailto:lbelohlavek@bellsouth.net]  
+**Subject:** FW: RE: Epstein settlement agreement
+
+----- Forwarded Message: -----
+
+To: <lbelohlavek@bellsouth.net>  
+Cc: "Villafana, Ann Marie C. (USAFLS)" <Ann.Marie.C.Villafana@usdoj.gov>  
+Date: Fri, 2 Nov 2007 13:58:13 +0000
+
+Dear Lanna:
+
+I was just informed that a case disposition conference has been set in the Epstein case on January 7, 2008. Our agreement with Mr. Epstein contemplated a simultaneous plea and sentencing for October (or, as we later agreed, November), followed by Mr. Epstein self-surrendering to begin serving his sentence not later than January 4, 2008. From your last e-mail, it appeared that the judge was under the impression that Mr. Epstein could not be sentenced before January 2008. We are hoping that Judge McSorley would consider conducting the simultaneous plea and sentencing some time before January 4, 2008, so that Mr. Epstein can comply with the terms of our agreement and begin serving his sentence on January 4, 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,
+
+*Jeffrey H. Sloman*,  
+First Assistant United States Attorney  
+99 N.E. 4{sup}`th` Street  
+Miami, Florida 33132  
+Phone (305) 961-9299
+
+*A. Marie Villafaña*  
+Assistant U.S. Attorney  
+500 S. Australian Ave, Suite 400  
+West Palm Beach, FL 33401  
+Phone 561 209-1047  
+Fax 561 820-8777
+
+
+**From:** lbelohlavek@bellsouth.net [mailto:lbelohlavek@bellsouth.net]  
+**Sent:** Monday, October 29, 2007 9:22 PM  
+**To:** Sloman, Jeff (USAFLS)  
+**Subject:** Epstein settlement agreement
+
+Jeff,
+
+Good evening. I am the ASA with the Epstein case in Palm Beach County. The negotiated settlement is a definite go. A difficulty arose last week at a conference with the judge on the case. She wants the plea and sentence to occur concurrently; not a plea with a sentencing at a later date. Therefore, the case was set for the first week of January, but the plea and sentence will definitely occur before the January 4th date that was agreed on by all for the sentencing.
+
+If you have any questions, please contact me at 561-355-7376 or lbelohla@sa15.statenus.
+
+Lanna Belohlavek
+
+## Villafana, Ann Marie C. (USAFLS)
+
+From: Sloman, Jeff (USAFLS) Sent: Thursday, December 20, 2007 10:54 AM To: Villafana. Ann Mine C. (USAFLS) Subject: State of Florida I Jeffrey Epstein, Case No. 2006CF009454AXX
+
+Marie,
+
+I've tailored your email for Lana a little bit. Before I press send, please take a look one more time. Perhaps we should include some caveat to prohibit further distribution. What do you think?
+
+Jeff
+
+Ms. Belohlavek,
+
+I called you this morning and left a message. I wanted to inform you that on Friday, December 14, 2007, Jeffrey Epstein's defense team argued, for the first time, that the state charge contained in the Non-Prosecution Agreement does not apply to the facts of his case. As an ethical matter, the U.S. Attorney's Office for the Southern District of Florida does not want a defendant to plead guilty to a crime that he did not commit; however, we are not experts in the interpretation of the Florida Criminal Code, so we look to you for guidance. To assist, I have listed the statute below and summarized the arguments of Mr; Epstein's attorneys. I also have included the factual proffer that you have previously requested so that you can determine whether, in your opinion, there is a sufficient factual basis for a plea.
+
+Fl. Stat. 796.03 states: "A person who procures for prostitution, or causes to be prostituted, any person who is under the age of 18 years commits a felony of the second degree .. ."
+
+Fl. Stat. 777.011 states: "Whoever commits any criminal offense against the state, whether felony or misdemeanor, or aids, abets, counsels, hires, or otherwise procures such offense to be committed, and such offense is committed or is attempted to be committed, is a principal in the first degree and may be charged, convicted, and punished as such, whether he or she is or is not actually or constructively present at the commission of such offense."
+
+Mr. Epstein's counsel state that Section 796.03 applies only to rocuring a minor to engage in a sex act with a third party, not with the defendant himself, relying on Kobel 745 So.2d 979, 982 (Fla. 4a' DCA 1999), and Register v. State. 715 So.2d 274. 278 (Fla. DCA 1998). They also assert that a commercial motive must be shown. Please consider whether the following facts are sufficient to prove a violation of Section 796.03, when read in conjunction with Section 777.011.
+
+From at least as early as 2001 through October 2005, the defendant, Jeffrey Epstein, procured at least 30 identified minor females between the ages of 14 and 17 in Palm Beach County to come to his home in Palm Beach to engage in sexual conduct in exchange for money. In particular, the defendant would pay females, including minors, \$200 to recruit other females, including minors, to come to his house to engage in sexual activity. The minors who were procured would receive between \$200 and \$1,000 depending upon the type of sexual activity that they engaged in. Several victims have stated that, when they were unwilling to engage in sexual activity with the defendant, the defendant would ask them to bring other girls instead, and promised to pay them \$200 for each girl whom they brought. Mr. Epstein would regularly ask his recruiters to find new girls for him because he wanted "fresh faces."
+
+In some instances, the defendant did not know the correct age of the minor female who was procured as a prostitute, but in more than half of the instances he did. For example, the defendant purchased gifts for some girls for their 18th birthdays, promised to send them on trips when they turned 18, talked with them about activities at their high schools; and provided transportation for those who could not drive.
+
+The sexual activity the defendant engaged in with the minor females included: requiring minor females to perform topless or nude massages while the defendant masturbated himself; fondling the breasts and vaginas of the minor females; digital penetration of the vaginas of minors; the use of a massaging device on the vaginas of minors; requiring a minor female to pose for nude photographs; requiring minor females to watch others (including the defendant) engage in sexual intercourse; requiring minor females to fondle the breasts of the defendant's adult female companion; performing oral sex on minor females; requiring minor females to perform oral sex on the defendant's adult female companion; and sexual intercourse with minor females. There are four minor females who engaged in vaginal intercourse with the defendant in exchange for money. None of the minor females who was brought to Mr. Epstein's house had ever engaged in prostitution prior to being procured by one of Mr. Epstein's recruiters.
+
+**From:** Lanna Belohlavek [mailto:Lbelohla@sa15.state.fl.us]  
+**Subject:** RE: RE: Epstein settlement agreement
+
+The plea and sentence will both occur on the same date and that date will be before January 4th.
+
+
+**From:** lbelohlavek@bellsouth.net [mailto:lbelohlavek@bellsouth.net]  
+**Subject:** FW: RE: Epstein settlement agreement
+
+----- Forwarded Message: -----
+
+From: "Sloman, Jeff (USAFLS)" <Jeff.Sloman@usdoj.gov>  
+To: <lbelohlavek@bellsouth.net>  
+Cc: "Villafana, Ann Marie C. (USAFLS)" <Ann.Marie.C.Villafana@usdoj.gov>  
+Date: Fri, 2 Nov 2007 13:58:13 +0000
+
+Dear Lanna:
+
+I was just informed that a case disposition conference has been set in the Epstein case on January 7, 2008. Our agreement with Mr. Epstein contemplated a simultaneous plea and sentencing for October (or, as we later agreed, November), followed by Mr. Epstein self-surrendering to begin serving his sentence not later than January 4, 2008. From your last e-mail, it appeared that the judge was under the impression that Mr. Epstein could not be sentenced before January 2008. We are hoping that Judge McSorley would consider conducting the simultaneous plea and sentencing some time before January 4, 2008, so that Mr. Epstein can comply with the terms of our agreement and begin serving his sentence on January 4, 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,
+
+Jeffrey H. Sloman, First Assistant United States Attorney 99 N.E. 4th Street Miami, Florida 33132 Phone (305) 961-9299
+
+A. Marie VillafaRa Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+From: lbelohlayek@bellsouth.net [mallto:lbelohlavek@bellsouth.net]
+
+Sent: Monday, October 29, 2007 9:22 PM
+
+To: Sloman, Jeff (USAFLS)
+
+Subject: Epstein settlement agreement
+
+Jeff,
+
+Good evening. I am the ASA with the Epstein case in Palm Beach County. The negotiated settlement is a definite go. A difficulty arose last week at a conference with the judge on the case. She wants the plea and sentence to occur concurrently; not a plea with a sentencing at a late? date. Therefore, the case was set for the first week of January, but the plea and sentence will definitely occur before the January 4th date that was agreed on by all for the sentencing.
+
+If you have any questions, please contact me at 561-355-7376 or lbelohlaasal5.state.fl.us.
+
+Lanna Belohlavek
+
+## Villafana, Ann Marie C. (USAFLS)
+
+From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday. December 20, 2007 8:35 AM To: Sloman, Jeff (USAFLS) Subject: Epstein thought
+
+Hi Jeff—Only one obsessive thought last night. When you talk to Lanna, you might want to convince her that (assuming she agrees wi h is) the evidence in the state case is enough to support the charge, especially the taped statement of and others who talked about recruiting other girls. I definitely do not want Epstein's camp to use is as an excuse to view all of our evidence, then withdraw from the plea, and then go to trial.
+
+Thanks.
+
+A. Marie Villafafla Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777

marker2-fixhub/ds9/EFTA00189245/EFTA00189245.receipt.json

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marker2-fixhub/ds9/EFTA00189253/EFTA00189253.md

@@ -0,0 +1,51 @@
+From: Anderson. James C. (USAWY) Sent: Tuesday. December 18. 2007 10:22 AM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: 2422(b) based upon telephone contact
+
+In Wyoming we just prosecuted the following 2422(b) case based only on a telephone:
+
+U.S. Block, USDC-WY-07CR00208-B (we plea bargained the case and allowed defen 1 ant to plead to distribution of obscene material due to problems related to the victim)
+
+
+From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, December 18, 2007 7:07 AM To: USAEO-PSC-Coordinators Subject: 2422(b) based upon telephone contact
+
+Hi everyone -- Sorry to trouble you, but I have a defense attorney who is claiming that NO ONE has ever been prosecuted anywhere in the United States for a violation of 2422(b) based exclusively on the use of a telephone as the facility of interstate commerce. I know that is false because I have prosecuted two of these, but it would be really helpful if you could provide me with examples of other cases throughout the country.
+
+
+A. Marie Villafana Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+From: Hurd, Marcia (USAMT) Sent: Tuesday, December 18, 2007 10:21 AM To: Villatana. Ann Marie C. (USAFLS) Subject: RE: 2422(b) based upon telephone contact
+
+Hey there! I'm getting ready to charge one here, he is obviously out of touch--
+
+
+From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, December 18, 2007 7:07 AM To: USAEO-PSC-Coordinators Subject: 2422(b) based upon telephone contact
+
+Hi everyone -- Sorry to trouble you, but I have a defense attorney who is claiming that NO ONE has ever been prosecuted anywhere in the United States for a violation of 2422(b) based exclusively on the use of a telephone as the facility of interstate commerce. I know that is false because I have prosecuted two of these, but it would be really helpful if you could provide me with examples of other cases throughout the country.
+
+
+A. Marie Villafaha Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+From: Levy, Mike (USAPAE) Sent: Tuesday, December 18. 2007 9:54 AM To: Villafana. Ann Marie C. (USAFLS) Subject: RE: 2422(b) based upon telephone contact Attachments: Second Superseding Indictment.wpd
+
+Look at counts 11 and 12. Defendant was convicted.
+
+
+From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, December 18, 2007 9:07 AM To: USAEO-PSC-Coordinators Subject: 2422(b) based upon telephone contact
+
+Hi everyone -- Sorry to trouble you, but I have a defense attorney who is claiming that NO ONE has ever been prosecuted anywhere in the United States for a violation of 2422(b) based exclusively on the use of a telephone as the facility of interstate commerce. I know that is false because I have prosecuted two of these, but it would be really helpful if you could provide me with examples of other cases throughout the country.
+
+
+A. Marie Villafana Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+From: Martin. Kim (USAKS) 2 Sent: Tuesday, December 18, 2007 9:51 AM To: Villafana, Ann Marie C (USAFLS) Subject: RE: 2422(b) based upon telephone contact
+
+Hi Ann Marie,
+
+I Charged th a few years back. It is a published case in the 10th Cir. United States Riccardi. I hope that is helpful. Let me know if you need any additional information!!
+
+
+From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, December 18, 2007 8:07 AM To: USAEO-PSC-Coordinators Subject: 2422(b) based upon telephone contact
+
+Hi everyone -- Sorry to trouble you, but I have a defense attorney who is claiming that NO ONE has ever been prosecuted anywhere in the United States for a violation of 2422(b) based exclusively on the use of a telephone as the facility of interstate commerce. I know that is false because I have prosecuted two of these, but it would be really helpful if you could provide me with examples of other cases throughout the country.
+
+
+A. Marie Villafaha Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777

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marker2-fixhub/ds9/EFTA00189257/EFTA00189257.md

@@ -0,0 +1,123 @@
+From: Acosta, Alex (USAFLS) Sent: Wednesda Janua 02 2008 3:28 PM To: Cc: Subject: :Found it.
+
+Thanks. I have your file as well.
+
+From Sent: Wednesday, January 02, 2008 3:06 PM To: Acosta, Alex (USAFLS); file--- Ing (I (CAM C Subject: Found It!
+
+Finally — Here is the letter from Chief Reiter and some other items.
+
+<.< File: Reiter hr to Victims.pdf >> <<File: ABC News Coverage.pdf >> a File: FOXNews\_com - Another Outrageous Legal Situation in Florida - Bill O'Reilly The O'Reilly Factor.htm >> << File: Dec 10 2007 NY Magazine Article.pdf>>
+
+Let me know what else you need.
+
+Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+From:
+
+Sent:
+
+To: Subject: ne ay. anuary M
+
+Acosta. Alex (USAFLS).
+
+Found it!
+
+Finally — Here is the letter from Chief Reiter and some other items.
+
+![](_page_1_Picture_7.jpeg)
+
+Reiter Itr to Victims.pdf ABC News FOXNews\_com • Dec 10 2007 NY Coverage.pdf ,other Outrageotilagazine Arta..
+
+![](_page_1_Picture_9.jpeg)
+
+![](_page_1_Picture_11.jpeg)
+
+![](_page_1_Picture_13.jpeg)
+
+Let me know what else y ou need.
+
+Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+From: Sent: To: Subject: Ana•Mene•roa•Ar.irro) Wednesday, January 02, 2008 1 55 PM Acosta. Alex (USAFLS), RE Epstein Press Coverage
+
+•
+
+![](_page_2_Picture_2.jpeg)
+
+Here are all of the items from the Palm Beach Post that I could track down. including the letter that Chief Reiter sent to Barry Krischcr.
+
+Reiter It to Aug 14 2006 PB Aug 14 2006 PB Aug 8 2006 PB Aug 4 2006 P8 Jul129, 2006 PBJuly 26 2006 PB Krischer.pdf Post Article.pd... Post Article 2.... Post Artide.pdf..Post Artide.pdf... Post Article.... Post Artide.p...
+
+![](_page_2_Picture_4.jpeg)
+
+July 25 2006 PB Post Attide.p...
+
+The agents are out of town right now. I could call the Chief or the Detective. 'And I will keep searching the Internet. too. Let me know if you want me to call the Police Dept.
+
+What are Epstein's people up to?
+
+Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach. FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+From: Acosta, Alex (USAFLS) Sent: Wednesday, January 02, 2008 1:52 PM Subject: RE: Epstein Press Coverage
+
+Any way to get the letter, without pursuing from public sources? Would FBI have it?
+
+From: Sent: Wednesday, January 02, 2008 1:28 PM To: Acosta, Alex (USAFLS); Subject: Epstein Press Coverage •nmlanF rvm, ItIPIIC
+
+Here are the documents that I have electronically. The "Jeffrey Epstein Archives- document has several stories contained within it.
+
+I do not have the letter that the Chief handed out, but some of these stories reference the letter. I do not believe that the letter mentioned any specifics. But, when the State Attorney's Office basically shut down the case, the Chief deemed the police investigation "closed," which meant that the PC affidavits for the arrests Epstein, -Kellett;-and Ihaphoplsecame public. "The Smoking Gun" published the redacted PC affidavits and later published a portion of the Incident Report. Here are links to their stories. httv://www.thesmok inggun.com/archive/0726062eosteinl.html
+
+http://www.thesmokinggun.comiarchive/072706lepsteinl.html
+
+<< File: Leap Year Press Coverage.doc >> << File: ABC Blotter Article 2.doc >> .c< File: New York Epstein article.doc >> << File: Jeffrey Epstein article.doc >>
+
+<< File: Jeffrey Epstein Archives.doc >> << File: 071116 Epstein Editorial.pdf >>
+
+Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+From: Acosta, Alex (USAFLS) Sent: Wednesday, January 02, 2008 1:52 PM To: Subject: !Pr
+
+Any way to get the letter, without pursuing from public sources? Would FBI have it?
+
+From. Sent: Wednesday, January 02, 2008 1:28 PM To: Acosta, Alex (USAFLS); iss Elailiatram Subject: Epstein Press Coverage
+
+Here are the documents that I have electronically. The "Jeffrey Epstein Archives" document has several stories contained within it.
+
+I do not have the letter that the Chief handed out, but some of these stories reference the letter. I do not believe that the letter mentioned any specifics. But, when the State Attorney's Office basically shut down the case, the Chief deemed the police investigation "closed," which meant that the PC affidavits for the arrests of Epstein, WM, and•Neyiley became public. "The Smoking Gun" published the redacted PC affidavits and later published a portion of the Incident Report. Here are links to their stories. http://www.thesmokinggun.com/archive/0726062epsteinl.html
+
+htto://www.thesmok n gau n.com/arch ive/072706le DStei n1.html
+
+<< File: Leap Year Press Coverage.doc >> << File: ABC Blotter Article 2.doc >> << File: New York Epstein article.doc >> << File: Jeffrey Epstein article.doc >> << File: Jeffrey Epstein Archives.doc >> << File: 071116 Epstein Editorial.pdf >>
+
+Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+From: Sent: Wednesday, January 02, 2008 1 28 PM To: Acosta, Alex (USAFLS), Subject: Epstein Press Coverage
+
+Here are the documents that I have electronically. The "Jeffrey Epstein Archives" document has several stories contained within it.
+
+I do not have the letter that the Chief handed out, but some of these stories reference the letter. I do not believe that the letter mentioned any specifics. But, when the State Attorney's Office basically shut down the case, the Chief deemed the police investigation "closed," which meant that the PC affidavits for the arrests of Epstein, nd fl ame public. "The Smoking Gun" published the redacted PC affidavits and later published a portion of the Incident Report. Here are links to their stories. httolAvww.thesmokinaitun.com/archive/0726062epstein I .html
+
+http://www.thesmokingaun.com/archive/072706I =stein I .html
+
+![](_page_5_Picture_4.jpeg)
+
+Leap Year Press ABC Blotter
+
+![](_page_5_Picture_6.jpeg)
+
+![](_page_5_Picture_8.jpeg)
+
+Coverage.doc Artide 2.doc Epstein artide.doc article.doc
+
+![](_page_5_Picture_10.jpeg)
+
+![](_page_5_Picture_12.jpeg)
+
+Jeffrey Epstein 071116 Epstein Archives.doc Editorial.pdf
+
+![](_page_5_Picture_14.jpeg)
+
+New York Jeffrey Epstein
+
+Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777

marker2-fixhub/ds9/EFTA00189257/EFTA00189257.receipt.json

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marker2-fixhub/ds9/EFTA00189263/EFTA00189263.md

@@ -0,0 +1,218 @@
+From: Sent: Thursday, January 03.2008 1:51 PM To: Acosta. Alex (USAFLS) Subject: RE: Memo to File
+
+Sounds great. Thank you.
+
+Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401
+
+
+
+Sent: Thursda , Januar 03, 2008 1:50 PM
+
+To:
+
+Subject: Re: Memo to File
+
+Its at 3 30. No need to travel here. We can loop you in by phone.
+
+
+
+From:
+
+
+Sent: Thu Jan 03 13:42:49 2008
+
+Subject: RE: Memo to File
+
+What time should I be there? And is there anything that I should bring with me? Did Jay give you a sense of where they are headed?
+
+
+Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401
+
+
+
+Sent: Thursday, January 03, 2008 1:35 PM
+
+To: Subject: Re: Memo to File
+
+Yes. We spoke today only to reschedule to monday because jeff was out.
+
+
+
+From: To: Acosta, Alex (USAFLS) Sent: Thu Jan 03 12:41:33 2008 Subject: RE: Memo to File
+
+Hi Alex -- Does this mean that we will be having another call on Monday?
+
+Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 3401
+
+
+From: Acosta, Alex (USAFLS) Sent: Thursda Januar 03 2008 12:39 PM To: Subject: Fw: Memo to File
+
+Had a 3 min call today to schedule our monday call. Want to memorialize the following statement from jay.
+
+
+
+From: Acosta, Alex (USAFLS) To: Acosta, Alex (USAFLS) Sent: Thu Jan 03 12:01:04 2008 Subject: Memo to File
+
+
+"I may have made a mistake 6 months ago. Lana told us solicitation not registrable. It turns out that the actual offense charged it."
+
+
+From: Acosta. Alex (USAFLS) Sent: Thursda . Janua 03. 2008 1:50 PM To: Subject: e: emo o ie
+
+Its at 3 30. No need to travel here. We can loop you in by phone.
+
+
+
+From: To: Acosta, Alex (USAFLS) Sent: Thu Jan 03 13:42:49 2008 Subject: RE: Memo to File
+
+What time should I be there? And is there anything that I should bring with me? Did Jay give you a sense of where they are headed?
+
+
+Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401
+
+
+From: Acosta, Alex (USAFLS) Sent: Thursday, January 03, 2008 1:35 PM To: Subject: Re: Memo to File
+
+Yes. We spoke today only to reschedule to monday because jeff was out.
+
+
+
+From: To: Acosta, Alex (USAFLS) Sent: Thu Jan 03 12:41:33 2008 Subject: RE: Memo to File
+
+Hi Alex -- Does this mean that we will be having another call on Monday?
+
+Assistant . . Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401
+
+
+
+Sent
+
+To:
+
+Subject: Fw: Memo to File
+
+Had a 3 min call today to schedule our monday call. Want to memorialize the following statement from jay.
+
+
+
+
+
+
+
+
+"I may have made a mistake 6 months ago. Lana told us solicitation not registrable. It turns out that the actual offense charged it."
+
+
+From: Sent: Thursday, January 03. 2008 1:43 PM To: Acosta, Alex (USAFLS) Subject: RE: Memo to File
+
+What time should I be there? And is there anything that I should bring with me? Did Jay give you a sense of where they are headed?
+
+
+Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401
+
+
+From: Acosta, Alex (USAFLS) Sent: Thursday, January 03, 2008 1:35 PM To: Subject: Re: Memo to File
+
+Yes. We spoke today only to reschedule to monday because jeff was out.
+
+
+
+From: To: Acosta, Alex (USAFLS) Sent: Thu Jan 03 12:41:33 2008 Subject: RE: Memo to File
+
+Hi Alex -- Does this mean that we will be having another call on Monday?
+
+Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401
+
+
+From: Acosta, Alex (USAFLS) Sent To:
+
+■
+
+Had a 3 min call today to schedule our monday call. Want to memorialize the following statement from jay.
+
+
+
+
+
+
+
+
+"I may have made a mistake 6 months ago. Lana told us solicitation not registrable. It turns out that the actual offense charged it."
+
+
+From: Sent: To: Subject: Acosta, Alex (USAFLS) Thursday. January 03, 2008 1:35 PM
+
+Yes. We spoke today only to reschedule to monday because Jeff was out.
+
+
+
+From: To: Acosta, Alex (USAFLS) Sent: Thu Jan 03 12:41:33 2008 Subject: RE: Memo to File
+
+Hi Alex -- Does this mean that we will be having another call on Monday?
+
+Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401
+
+
+From: Acosta, Alex (USAFLS) Sent: Thursday, January 03, 2008 12:39 PM To: S Subject: Fw: Memo to File
+
+Had a 3 min call today to schedule our monday call. Want to memorialize the following statement from jay.
+
+
+
+From: Acosta, Alex (USAFLS) To: Acosta, Alex (USAFLS) Sent: Thu Jan 03 12:01:04 2008 Subject: Memo to File
+
+
+"I may have made a mistake 6 months ago. Lana told us solicitation not registrable. It turns out that the actual offense charged it."
+
+From: Sent: Thursday, January 03, 2008 12:42 PM To: Acosta, Alex (USAFLS) Subject: RE: Memo to File
+
+Hi Alex -- Does this mean that we will be having another'call on Monday?
+
+IMPRIPPRRIMPIE Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 3401
+
+Original Message From: Acosta, Alex (USAFLS) Sent: Thursda Januar 03 2008 12:39 PM To: Subject: Fw: Memo to File
+
+Had a 3 min call today to schedule our monday call. Want to memorialize the following statement from jay.
+
+
+Original Message From: Acosta, Alex (USAFLS) To: Acosta, Alex (USAFLS) Sent: Thu Jan 03 12:01:04 2008 Subject: Memo to File
+
+
+"I may have made a mistake 6 months ago. Lana told us solicitation not registrable. It turns out that the actual offense charged it."
+
+
+From: Acosta. Alex (USAFLS) Sent: Thursday, January 03, 2008 12.40 PM To: Acosta. Alex (USAFLS): Subject: RE: Memo to File -- ion
+
+-- final word is "is", not "it"
+
+
+"I may have made a mistake 6 months ago. Lana told us solicitation not registrable. It turns out that the actual offense charged is."
+
+
+
+
+Sent: Thursda Januar 03 2008 12:39 PM
+
+To: Subject: Fw: Memo to File
+
+Had a 3 min call today to schedule our monday call. Want to memorialize the following statement from jay.
+
+
+
+
+
+
+
+
+"I may have made a mistake 6 months ago. Lana told us solicitation not registrable. It turns out that the actual offense charged is."
+
+
+From: Sent: To: Subject: Acosta, Alex (USAFLS) Thursday. January 03, 2008 12:39 PM Fw: Memo to File
+
+Had a 3 min call today to schedule our monday call. Want to memorialize the following statement from jay.
+
+
+Original Message From: Acosta, Alex (USAFLS) To: Acosta, Alex (USAFLS) Sent: Thu Jan 03 12:01:04 2008 Subject: Memo to File
+
+
+"I may have made a mistake 6 months ago. Lana told us solicitation not registrable. It turns out that the actual offense charged it."

marker2-fixhub/ds9/EFTA00189263/EFTA00189263.receipt.json

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marker2-fixhub/ds9/EFTA00189274/EFTA00189274.md

@@ -0,0 +1,444 @@
+From: Sent: n 008 11:35AM Cc: R. To: USA Subject: RE Epstein
+
+M.
+
+It was a pleasure meeting you on Friday, as well as the agents. Let's plan for me to be in Florida on the 23i0 and 24th and I will get the remaining 302s at that time. As for meeting with the girls. I am available the entire week of the 28th and will leave it to the agents to make arrangements with the girls and let me know when to come down.
+
+From what I could tell during the meeting on Friday, I am guessing that you have already done everything that we need to do and obtained whatever evidence that we need to have. It's probably just a matter of doubling back to make sure that everything is still 'fresh' and. in this case, making sure that things have not begun to vanish. I will be able to speak more definitively once I've made a bigger dent in the materials that you sent back with me.
+
+Take care,
+
+From: (USAFLS) (mallto:Ann goy] Sen 11:22 AM To: Cc: E N.; Subject: Epstein R.
+
+Hi — I have one more book of 302s that wouldn't fit into the bag that I gave you on Friday. Please let me now i you would like me to send it or if you want to wait until you return next week. Except for a lunchtime dental appointment on Tuesday the 22thl, I will be around all week, and I will keep my schedule open as much as possible. During the week of the 28t ,1 have a suppression hearing on the morning of 1/30, but I am otherwise around.
+
+I have cc'd and on this e-mail so you will have their e-mail/Blackberry addresses.
+
+I will ask them to talk with all of the girls and to do more in-depth interviews with those victims for whom they only did short interviews before and to update the evidence summary chart for all of the victims. Speaking with Virginia in Australia and the girls in New York are the next priorities. We also need to "audit" the grand jury responses to see what it missing.
+
+I will start working on revising the indictment taking into account your suggestions and ■ suggestions. 1 also want to do an application to get the tax returns for all of the defendants, since pstein's corporations have refused to obey the grand jury subpoenas.
+
+Is there anything else that I should or should not be doing?
+
+Thank you, and it was so nice to meet you in person on Friday.
+
+
+
+
+
+
+![](_page_1_Picture_4.jpeg)
+
+Fax 561 820-8777
+
+•
+
+. (USAFLS)
+
+From: Sent: n n . 008 1 11FITAM To: Cc: , a R. Subject: ps on
+
+I I i - I have one more book of 302s that wouldn't fit into the bag that I gave you on Friday. Please let me you would like me to send it or if you want to wait until you return next week. Except for a lunchtime dental appointment on Tuesday the 22"°. I will be around all week, and I will keep my schedule open as much as possible. During the week of the 28th, I have a suppression hearing on the morning of 1/30, but I am otherwise around.
+
+I have cc'd and on this e-mail so you will have their e-mail/Blackberry addresses.
+
+I will ask them to talk with all of the girls and to do more in-depth interviews with those victims for whom they only did short interviews before and to update the evidence summary chart for all of the victims. Speaking with Virginia in Australia and the girls in New York are the next priorities. We also need to "audit" the grand jury responses to see what it missing.
+
+I will start working on revising the indictment taking into account your suggestions and suggestions. I also want to do an application to get the tax returns for all of the defendan s, since pstein's corporations have refused to obey the grand jury subpoenas.
+
+Is there anything else that I should or should not be doing?
+
+Thank you, and it was so nice to meet you in person on Friday.
+
+A. Villafana Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone Fax 561 820-8777
+
+From: Sent: To: Subject: aisr n 2008 3:02 PM (USAFLS) RE: Tomorrow
+
+Since the meeting is informal, should I dress casually or is it business as usual?
+
+From: (USAFLS) [mallto:Ann nuary r, 2008 3:00 PM To: Subject: RE: Tomorrow
+
+Great. I will see you then.
+
+From: =, Sent: Thursda Janus 10, 2008 2:59 PM To: (USAFLS) Sub ect: RE: Tomorrow
+
+US Air Flight 1223 arrives at 12:43PM. I have the pr memo and indictment. They.are pretty thick, so I think that's all I need between now and tomorrow. My cell number is
+
+
+From: W. (USAFLS) [mailto Seni um sauary , 2008 2:54 PM To: SubMeTon,rrow
+
+Absolutely. lust send me the flight info. My cell number is
+
+You have the pros memo, I think. Do you want me to send you anything else?
+
+From: =, Sent: Thursda Janus 10, 2008 2:53 PM To: (USAFLS) Subject: RE: Tomorrow
+
+Let's go ahead and stick with tomorrow. Are you available at 12:45 to pick me up from the airport?
+
+From: (USAFLS) [mailto Sent: urssi guary , 2008 2:51 PM To: SublillE!Icriorrow
+
+Do you want to do that? Or do you want to wait? I haven't heard back from the agents yet.
+
+From: Sent: l lMy/Mary i 10, 2008 2:50 PM To: (USAFLS)
+
+Sub : Tomorrow
+
+M.
+
+There is a flight out of DC arriving in Palm Beach tomorrow at 12:45. Therefore, I can make a 1:30 meeting.
+
+M
+
+From: IMscla MI aJ nuary 1 U(30S8A3FL0S0) Sent: PM . To: Subject: RE: Tomorrow
+
+Great. I will see you then.
+
+From: Sen 0, 2008 2:59 PM To: (USAFLS) Sub : : omorrow
+
+US Air Flight 1223 arrives at 12 43PM. I have the pr 1 i dictment. They are pretty thick. so I think that's all I need between now and tomorrow. My cell number is
+
+
+From: (USAFLS) [mailto Senim a anuary t, 2008 2:54 PM To: Sub ME: ec Tomorrow
+
+Absolutely. Just send me the flight info. My cell number is
+
+You have the pros memo, I think. Do you want me to send you anything else?
+
+From: UM, Sen • Thr a Janua 10, 2008 2:53 PM To: (USAFLS) Subject: RE: Tomorrow
+
+Let's go ahead and stick with tomorrow. Are you available at 12:45 to pick me up from the airport?
+
+From: (USAFLS) [mailto Sen • January , 2008 2:51 PM To: Subject: E omorrow
+
+Do you want to do that? Or do you want to wait? I haven't heard back from the agents yet.
+
+From: Sen l irra 10, 2008 2:50 PM To: (USAFLS) Sub ect:Tomorrow
+
+There is a flight out of DC arriving in Palm Beach tomorrow at 12:45. Therefore, I can make a 1:30 meeting.
+
+From: Sent: Iht.a Janua 10 2008 2:59 PM To: (USAFLS) Subject: : omorrow
+
+US Air Flight 1223 arrives at 12:43PM. I have the pros memo and indictment. They are pretty thick, so I think that's all I need between now and tomorrow. My cell number is
+
+
+From: Sent.i Hoary , 2008 (USAFLS) 2: 54 Ill To: SubjecnrAE: Tomorrow
+
+Absolutely. Just send me the flight info. My cell number is a.
+
+You have the pros memo, I think. Do you want me to send you anything else?
+
+From: Sen : Janua i 10, 2008 2:53 PM To: (USAFLS) Sub ect: RE:Tomorrow
+
+Let's go ahead and stick with tomorrow. Are you available at 12:45 to pick me up from the airport?
+
+From: (USAFLS) [mailto Sen • num), , 2008 2:51 PM To: Sub ect: E:Tomorrow
+
+Do you want to do that? Or do you want to wait? I haven't heard back from the agents yet.
+
+From: Sent: Th Janua 10, 2008 2:50 PM To: (USAFLS) Subject: Tomorrow
+
+There is a flight out of DC arriving in Palm Beach tomorrow at 12:45. Therefore, I can make a 1:30 meeting.
+
+From: (USAFLS)
+
+Sent: I lLSRMI lua , 2008 2:55 PM
+
+To: (E. : (Mt Richards2 fi itgov
+
+Subject: Forget the earlier e-mail
+
+can make the meeting tomorrow. I have to pick her up at the airport at 12:45, so I probably can't do lunch.
+
+. (USAFLS)
+
+From: (USAFLS) Sent: ur ay. January 1 , 2008 2:54 PM To: Subject: Tomorrow
+
+Absolutely. Just send me the flight info. My cell number is
+
+You have the pros memo, I think. Do you want me to send you anything else?
+
+From: =, Sentn0, 2008 2:53 PM To: =IMMO (USAFLS) Subject: RE: Tomorrow
+
+Lets go ahead and stick with tomorrow. Are you available at 12:45 to pick me up from the airport?
+
+From: (USAFLS) (mailto Sent: nuary I, 2008 2:51 PM To: Subject: RE: Tomorrow
+
+Do you want to do that? Or do you want to wait? I haven't heard back from the agents yet.
+
+From: MI, Sen : Th J n 10, 2008 2:50 PM To: (USAFLS) Sub ect: Tomorrow
+
+There is a flight out of DC arriving in Palm Beach tomorrow at 12:45. Therefore. I can make a 1:30 meeting.
+
+From: Sent: 2008 2:53 PM To: (USAFLS) Subject: omorrow
+
+Lets go ahead and stick with tomorrow. Are you available at 12:45 to pick me up from the airport?
+
+From: (USAFLS)ill .gov] Sent: Thursitary W, 2008 2:51 To: Subject: RE: Tomorrow
+
+Do you want to do that? Or do you want to wait? I haven't heard back from the agents yet.
+
+From: Sen • n 10, 2008 2:50 PM To: (USAFLS) Subject: Tomorrow
+
+There is a flight out of DC arriving in Palm Beach tomorrow at 12:45. Therefore. I can make a 1:30 meeting.
+
+From: Sent: 1. nu 1 2008 2:50 PM To: .(USAFLS) Subject: Tomorrow
+
+There is a flight out of DC arriving in Palm Beach tomorrow at 12:45. Therefore. I can make a 1:30 meeting.
+
+## Villafana, Ann Marie C. (USAFLS)
+
+From: (USAFLS) Sent: hur January . 2008 2:51 PM To: Subject: :Tomorrow
+
+Do you want to do that? Or do you want to wait? l haven't heard back from the agents yet.
+
+From: Myesha Sent: u y, January 10, 2008 2:50 PM To: S Ann Marie C. (USAFLS) Subject: Tomorrow
+
+There is a flight out of DC arriving in Palm Beach tomorrow at 12:45. Therefore. t can make a 1:30 meeting.
+
+From:
+
+Sent:
+
+To:
+
+Subject:
+
+(USAFLS)
+
+hu rsda 1 2008 2:42 PM
+
+ur (E. (MLRichards2
+
+c
+
+Meeting Change -- Urgent!
+
+Hi guys - The attorney from CEOS would like to attend the meeting, but getting down here from DC tomorrow would be difficult. Can we do Monday? I know the other agents are coming, but I was hoping maybe first thing in the morning?
+
+From: (USAFLS) Sent: Ihurs.PEIMI lua , 2008 2:30 PM To: Subject: :Epstein case
+
+Thanks, Drew. I look forward to meeting her in person.
+
+From: O s Sent\* 2008 2:27 PM To: (USAFLS) Subject: Re: Epstein case
+
+Well, it sounds like will be ideal. I've given her the assignment and she'll call you short y. e plans on attending the meeting tomorrow.
+
+If you need any other help just let me know.
+
+I'll talk to you soon. Best of luck.
+
+Drew
+
+From. (USAFLS) < To: Sent: Wed Jan 09 1 :27:59 2008 Subject: RE: Epstein case
+
+That sounds perfect. I actually like the written stuff, so I can work on that with backup help for the flood of motions I expect.
+
+One other strategic thing. I want the judge and jury to see that, rather than the big bad government vs. the poor little defense attorney, it is the big bad defense attorneys ganging up on the nice, polite, hard-working government.
+
+
+A. Ass stantill ilorney 500 S. Australian Ave, Suite 400 West P h FL 33401 Phone Fax 561 820-8777
+
+0 sage
+
+From: AndIll Sent: Wednesday, January 09, 2008 5:51 PM 1916 To: (USAFLS)
+
+Subject: Re: Epstein case
+
+Well, has those qualities - and there isn't a federal prosecutor in the land w o nows more about dealing with teenaged victims of prostitution offenses. That said, this matter is unique for reasons you know better than anyone. Writ' nses to complex legal claims - bogus or otherwise - is definitely not strength. On the other hand, she's ely good in court. I told Jeff a perhaps it's best to partner you with and give you back up on motions and other legal pleadings from someone e se in my section with that strength. How do you feel about that?
+
+From (USAFLS) <
+
+To: Sent: Wed Jan 09 17:42:07 2008 Subject: RE: Epstein case
+
+I thought she was great, but I leave it completely to your discretion. I am happy for all the help I can get. You kind of know the lay of the land on the case, and I think we will get either Judge Middlebrooks, Judge Marra, or Judge Hurley. Tenacity, patience, and an ability to work with troubled young women will be key.
+
+
+A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm B ach FL 33401 Phone Fax 561 820-8777
+
+O s From: iiilll Sent' 2008 5:30 PM To: (USAFLS) Subject: Re: Epstein case
+
+
+I just got off the phone with Jeff. I wanted to discuss my options with him a bit. I plan to assign it in the morning, and I will do whatever I cililliret the TA down there for the meeting Friday. Do you have a preference for given your experience with her? She does know the area well. Thanks. Drew
+
+IIIIIIIIIIIieAP I From\* (USAFLS) < To:
+
+Sent: Wed Jan 09 15:59:06 2008
+
+Subject: Epstein case
+
+Hi Drew - I hear that you are coming into the fray. I haven't heard fro ne from your office yet about a meeting. I just wanted to remind you that Braden and I talked about the case a few times and she was a great help.
+
+I am hoping to get all the evidence back from tomorrow, so I will have everything back up here in West Palm by Friday morning. I am meeting with the agents and group supervisor on Friday afternoon for a strategy session. Any chance my CEOS colleague can participate? At least by phone?
+
+
+
+
+
+
+Pho
+
+From: Sent: ur a anua 0 2008 2:27 PM To: (USAFLS) Subject: e:Epstein case
+
+MI Well, it sounds like will be ideal. I've given her the assignment and she'll call you short y. e plans on attending the meeting tomorrow.
+
+If you need any other help just let me know.
+
+I'll talk to you soon. Best of luck.
+
+Drew
+
+From. To: Sent: wed Jan 09 18:27:59 2008 Subject: RE: Epstein case (USAFLS) < .gov>
+
+That sounds perfect. I actually like the written stuff, 5o I can work on that with backup help for the flood of motions I expect.
+
+One other strategic thing. I want the judge and jury to see that, rather than the big bad government vs. the poor little defense attorney, it is the big bad defense attorneys ganging up on the nice, polite, hard-working government.
+
+
+A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West P lm Beach FL 33401 Phone Fax 561 820-8777
+
+From: Original Messiiiiii Sent. y 2008 5:51 PM To: (USAFLS) Subject: Re: Epstein case
+
+Well, has those qualities and there isn't a federal prosecutor in the land w o nows more about dealing with teenaged victims of prostitution offenses. That said, this matter is unique for reasons you know better than anyone. Writ nses to complex legal claims - bogus or otherwise - is definitely not strength. On the other hand, she's extremely good in court. I told
+
+Jeff that perhaps it's best to partner you with and give you back up on motions and other legal pleadings from someone e se in my section with that strength. How do you feel about that?
+
+From. (USAFLS) <Ann.I=. ..gov> To: Sent: wed Jan 09 17:42:07 2008 Subject: RE: Epstein case
+
+I thought she was great, but I leave it completely to your discretion. I am happy for all the help I can get. You kind of know the lay of the land on the case, and I think we will get either Judge Middlebrooks, Judge Marra, or Judge Hurley. Tenacity, patience, and an ability to work with troubled young women will be key.
+
+
+A. Assistant U. . orney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+O s From: Sent\* To: Subject: Re: Epstein case 2008 5:30 PM (USAFLS)
+
+
+I just got off the phone with Jeff. I wanted to discuss my options with him a bit. I plan to assign it in the morning, and I will do whatever I c et the TA down there for the meeting Friday. Do you have a preference for given your experience with her? She does know the area well. Thanks. Drew
+
+From\* (USAFLS) < To: Sent: We Jan 9 1 : :06 2008 Subject: Epstein case
+
+I haven't heard fro ne from your office yet about a meeting. I just wanted to remind you that Hi Drew - I hear that you are coming into the fray. Braden and I talked about the case a few times and she was a great help.
+
+I am hoping to get all the evidence back from tomorrow, so I will have everything back up here in West Palm by Friday morning. I am meeting with the agents and group supervisor on Friday afternoon for a strategy session. Any chance my CEOS colleague can participate? At least by phone?
+
+
+
+
+
+
+Phone 561 209-1047
+
+From: (USAFLS) Sent: MIW IP A, I 2008 6:28 PM To: Subject: : pstem case
+
+That sounds perfect. I actually like the written stuff, so I can work on that with backup help for the flood of motions I expect.
+
+One other strategic thing. I want the judge and jury to'see that, rather than the big bad government vs. the poor little defense attorney, it is the big bad defense attorneys ganging up on the nice, polite, hard-working government.
+
+
+A. Assistant U. . Attorney 500 S. Australian Ave, Suite 400 West P L 33401 Phone Fax 561 820-8777
+
+Sent\* To: Subject: Re: Epstein case 2008 5:51 PM (USAFLS)
+
+Well, has those qualities - and there isn't a federal prosecutor in the land w o nows more about dealing with teenaged victims of prostitution offenses. That said, this matter is unique for reasons you know better than anyone. Writ' nses to complex legal claims - bogus or otherwise - is definitely not iiir strength. On the other hand, she's ely good in court. I told Jeff a perhaps it's best to partner you with and give you back up on motions and other legal pleadings from someone e se n my section with that strength. How do you feel about that?
+
+From: To: Sent: Wed Jan 09 17:42:07 2008 Subject: RE: Epstein case (USAFLS) < .gov>
+
+I thought she was great, but I leave it completely to your discretion. I am happy for all the help I can get. You kind of know the lay of the land on the case, and I think we will get either Judge Middlebrooks, Judge Marra, or Judge Hurley. Tenacity, patience, and an ability to work with troubled young women will be key.
+
+
+A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West P L 33401 Phone Fax 561 820-8777
+
+Ori inal Messiii
+
+From: Sent' y , 2008 5:30 PM To: (USAFLS) Subject: Re: Epstein case
+
+
+I just got off the phone with Jeff. I wanted to discuss my options with him a bit. I plan to assign it in the morning, and I will do whatever I cillilliet the TA down there for the meeting Friday. Do you have a preference for given your experience with her? She does know the area well. Thanks. Drew
+
+From: To: Sent: Wed Jan 09 Subject: Epstein case 15:59:06 2008 (USAFLS) <
+
+Hi Drew - I hear that you are coming into the fray. I haven't heard fro ne from your office yet about a meeting. I just wanted to remind you that Braden and I talked about the case a few times and she was a great help.
+
+I am hoping to get all the evidence back from ■ **so I will have everything back up here in West Palm by Friday morning. am mee ing with the agents and group supervisor on Friday afternoon for a strategy session. Any chance my CEOS colleague can participate? At least by phone?** 
+
+**Thanks.** 
+
+**A.** 
+
+**Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone** 
+
+From: Sent: 9.2008 5:51 PM To: (USAFLS) Subject: e: pstein case
+
+Well, has those qualities - and there isn't a fedqral prosecutor in the land w o nows more about dealing with teenaged victims of prostitution offenses. That said, this matter is unique for reasons you know better than anyone. Writ nses to complex legal claims - bogus or otherwise - is definitely not strength. On the other hand, she's ely good in court. I told Jeff t at perhaps it's best to partner you with and give you back up on motions and other legal pleadings from someone e se in my section with that strength. How do you feel about that?
+
+From: To: Ooster Sent: Wed Jan 09 17:42:07 2008 Subject: RE: Epstein case (USAFLS) <
+
+I thought she was great, but I leave it completely to your discretion. I am happy for all the help I can get. You kind of know the lay of the land on the case, and I think we will get either Judge Middlebrooks, Judge Marra, or Judge Hurley. Tenacity, patience, and an ability to work with troubled young women will be key.
+
+
+A. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 Wes FL 33401 Ph Fax 561 820-8777
+
+From: sent y , 2008 5:30 PM To: (USAFLS) Subjec psr iri case
+
+a i ms
+
+
+I just got off the phone with Jeff. I wanted to discuss my options with him a bit. I plan to assign it in the morning, and I will do whatever I c et the TA down there for the meeting Friday. Do you have a preference for given your experience with her? She does know the area well. Thanks. Dr w
+
+From. (USAFLS) < .gov>
+
+To:
+
+Sent: Wed Jan 09 15:59:06 2008
+
+Subject: Epstein case
+
+Hi Drew - I hear that you are coming into the fray. I haven't heard fro ne from your office yet about a meeting. I just wanted to remind you that Braden and I talked about the case a few times and she was a great help.
+
+I am hoping to get all the evidence back from so I will have everything back up here in West Palm by Friday morning. am mee ing with the agents and group supervisor on Friday afternoon for a strategy session. Any chance my CEOS colleague can participate? At least by phone?
+
+
+
+
+
+
+
+From: RIA.MVSAFLS) Sent: nes a anus . 2008 5:42 PM To: Subject: Epstein case
+
+I thought she was great, but I leave it completely to your discretion. I am happy for all the help I can get. You kind of know the lay of the land on the case, and I think we will get either Judge Middlebrooks, Judge Marra, or Judge Hurley. Tenacity, patience, and an ability to work with troubled young women will be key.
+
+
+ey 500 S. Austra Ian Ave, Suite 400 West Palm Beach FL 33401 Phone Fax 561 820-8777
+
+From: °Iiiiiiiiiiisiiiill Sent . y , 2008 5:30 PM To: (USAFLS) Subject: Re: Epstein case
+
+
+I just got off the phone with Jeff. I wanted to discuss my options with him a bit. I plan to assign it in the morning, and I will do whatever I c et the TA down there for the meeting Friday. Do you have a preference for given your experience with her? She does know the area well. Thanks. Drew
+
+From: To: Ooster aan, Sent: Wed Jan 09 15:59:06 2008 Subject: Epstein case (USAFLS) < .gov>
+
+Hi Drew - I hear that you are coming into the fray. I haven't heard fro ne from your office yet about a meeting. I just wanted to remind you that Braden and I talked about the case a few times and she was a great help.
+
+I am hoping to get all the evidence back from tomorrow, so I will have everything back up here in West Palm by Friday morning. I am meeting with the agents and group supervisor on Friday afternoon for a strategy session. Any chance my CEOS colleague can participate? At least by phone?
+
+
+A. Marie
+
+
+
+
+Pho
+
+From: Sent: To: Subject: 9, 2008 5:30 PM (USAFLS)
+
+
+I just got off the phone with Jeff. I wanted to discuss my options with him a bit. I plan to assign it in the morning, and I will do whatever I "Wet the TA down there for the meeting Friday. Do you have a preference for given your experience with her? She does know the area well. Thanks. Drew
+
+From\* To: Sent: Wed Jan 09 Subject: Epstein case 15:59:06 2008 (USAFLS) v>
+
+Hi Drew - I hear that you are coming into the fray. I haven't heard fro ne from your office yet about a meeting. I just wanted to remind you that Braden and I talked about the case a few times and she was a great help.
+
+I am hoping to get all the evidence back from tomorrow, so I will have everything back up here in West Palm by Friday morning. I am meeting with the agents and group supervisor on Friday afternoon for a strategy session. Any chance my CEOS colleague can participate? At least by phone?
+
+
+
+
+

marker2-fixhub/ds9/EFTA00189274/EFTA00189274.receipt.json

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marker2-fixhub/ds9/EFTA00189301/EFTA00189301.md

@@ -0,0 +1,83 @@
+(USAFLS)
+
+From: Sent: To: Subject: : eeting c ue
+
+Where do you want to meet? I am thinking that the FBI office might be safer than our office. What do you think?
+
+Assistant U.S. Attorney West Palm Beach. H. 33401
+
+From: Sen • M n nary 28, 2008 6:11 PM To: Cc: Subj : : ee ing c e u e
+
+Okay My flight leave at 3.40. but if we run over, I can catch the 6 15
+
+From Sen • a 28 2008 6:04 PM To Cc Su ec : : ee ing e u e
+
+FYI =not a strong yes) but said that she would meet us Friday @ 2:00pm.
+
+From: Sen 2008 3:57 PM To Cc Subject: RE: Meeting Schedule
+
+This looks good to me See you on Thursday
+
+From Ser • To Cc:
+
+Hi IM
+
+Thursday, January 31, 2008
+
+1:30pm S o
+
+4:00pm
+
+6:30pm
+
+Friday, February 01, 2008
+
+9:30am
+
+12:30pmM
+
+So I think you will be fine to fly in Thursday morning and back out on Friday. Let me know if there are any problems.
+
+From: Sent: To: Subject:
+
+Where do you want to meet? I am thinking that the FBI office might be safer than our office. What do you think?
+
+Assistant U.S. Attorne
+
+West Palm Beach. 1-1...).3401
+
+1=1 .
+
+From: Sen ry 28, 2008 6:11 PM To: Cc: (USAFLS) Subject: RE: Meeting Schedule
+
+Okay My flight leave at 3 40. but if we run over. I can catch the 6:15.
+
+From: Sen To: Cc: [mallto:E.Kuyrkendall@icibi.goy] 28, 2008 6:04 PM (USA) Subject: RE: Meeting Schedule
+
+•
+
+FYI 'Snot a strong yes) but said that she would meet us Friday @ 2:00pm.
+
+From: Sen To: Cc: [Myesha.Braden@usdoj.gov] ry 28, 2008 3:57 PM (USA) Subject: RE: Meeting Schedule
+
+This looks good to me See you on Thursday.
+
+From: Sen 28, 2008 3:55 PM To: Cc: (USA) Subject: Meeting Schedule [mailto:E.Kuyrkendall@lc.fbi.gov]
+
+Hi M,
+
+Thursday, January 31, 2008
+
+1:30pm TBD
+
+4:00pm
+
+6:30pm
+
+Friday, February 01, 2008
+
+9:30am
+
+12:30pma.
+
+So I think you will be fine to fly in Thursday morning and back out on Friday. Let me know if there are any problems.

marker2-fixhub/ds9/EFTA00189301/EFTA00189301.receipt.json

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marker2-fixhub/ds9/EFTA00189305/EFTA00189305.md

@@ -0,0 +1,109 @@
+From: Sent: To: Subject: n ay, rebruary ot, zoos a:
+
+Everyone, keep your fingers crossed. Maybe we will get some movement today. (See below)
+
+Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+Ori inal Messa e
+
+From: Sent: 008 9:07 PM To: Subj
+
+Thanks . I reached out today to Ito do just that. Let's chat tomorrow.
+
+
+Original Message
+
+From: AF LS) To: (USAFLS); Acosta, Alex (USAFLS) Sent: Thu Jan 31 19:33:12 2008 Subject: Epstein
+
+Hi Jeff and Alex - We just finished interviewing three of the girls. I wish you could have been there to see how much this has affected them.
+
+One girl broke down sobbing so that we had to stop the interview twice within a 20 minute span. She regained her composure enough to continue a short time, but she said that she was having nightmares about Epstein coming after her and she started to break down again, so we stopped the interview.
+
+The second girl, who has a baby girl of her own, told us that she was very upset about the 18 month deal she had read about in the paper. She said that 18 months was nothing and that she had heard that the girls could get restitution, but she would rather not get any money and have Epstein spend a significant time in jail.
+
+The FBI's victim-witness coordinator attended and she has arranged for counseling for several of the girls.
+
+Please reach out to Alice to make her decision. These girls deserve so much better than they have received so far, and I hate feeling that there is nothing I can do to help them.
+
+We have four more girls coming in tomorrow. Can I persuade you to attend?
+
+IIIIIIIIIIIIMI 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+[REDACTED]
+
+From: [REDACTED]  
+Sent: Thursday, January 31, 2008 9:07 PM  
+To: [REDACTED]  
+Subject: [REDACTED]
+
+Thanks Marie. I reached out today to Drew to do just that. Let's chat tomorrow.
+
+-----  
+
+----- Original Message -----
+
+From: Will [REDACTED]  
+To: [REDACTED]; Acosta, Alex (USAFLS)  
+Sent: Thu Jan 31 19:33:12 2008  
+Subject: Epstein
+
+Hi [REDACTED] and Alex - We just finished interviewing three of the girls. I wish you could have been there to see how much this has affected them.
+
+One girl broke down sobbing so that we had to stop the interview twice within a 20 minute span. She regained her composure enough to continue a short time, but she said that she was having nightmares about Epstein coming after her and she started to break down again, so we stopped the interview.
+
+The second girl, who has a baby girl of her own, told us that she was very upset about the 18 month deal she had read about in the paper. She said that 18 months was nothing and that she had heard that the girls could get restitution, but she would rather not get any money and have Epstein spend a significant time in jail.
+
+The FBI's victim-witness coordinator attended and she has arranged for counseling for several of the girls.
+
+Please reach out to Alice to make her decision. These girls deserve so much better than they have received so far, and I hate feeling that there is nothing I can do to help them.
+
+We have four more girls coming in tomorrow. Can I persuade you to attend?
+
+[REDACTED]
+
+Assistant U.S. Attorney  
+500 S. Australian Ave, Suite 400  
+West Palm Beach, FL 33401  
+Phone 561 209-1047  
+Fax 561 820-8777
+
+From: Sent: To: Subject: Cletrw•An Inf4 (1 ICA Thursday. January 31, 2008 9:07 PM Ina
+
+Thanks Marie. i reached out today to Drew to do just that. Let's chat tomorrow.
+
+
+Original Message
+
+From: SUS (USAFLS) To: IIISUSAFLS); Acosta, Alex (USAFLS) Sent: Thu Jan 31 19:33:12 2008 Subject: Epstein
+
+Hi Jeff and Alex - We just finished interviewing three of the girls. I wish you could have been there to see how much this has affected them.
+
+One girl broke down sobbing so that we had to stop the interview twice within a 20 minute span. She regained her composure enough to continue a short time, but she said that she was having nightmares about Epstein coming after her and she started to break down again, so we stopped the interview,
+
+The second girl, who has a baby girl of her own, told us that she was very upset about the 18 month deal she had read about in the paper. She said that 18 months was nothing and that she had heard that the girls could get restitution, but she would rather not get any money and have Epstein spend a significant time in jail.
+
+The FBI's victim-witness coordinator attended and she has arranged for counseling for several of the girls.
+
+Please reach out to Alice to make her decision. These girls deserve so much better than they have received so far, and I hate feeling that there is nothing I can do to help them.
+
+We have four more girls coming in tomorrow. Can I persuade you to attend?
+
+Assistant . . Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+V II VIA IVA. IAA ? I II IF nm.w v. wvrI a-vJ
+
+From: (USAFLS) Sent: Thursda Janua 31. 2008 7:33 PM To: ; Acosta, Alex (USAFLS) Subject: Epstein
+
+Hi Mind Alex — We just finished interviewing three of the girls. I wish you could have been there to see how much this has affected them.
+
+One girl broke down sobbing so that we had to stop the interview twice within a 20 minute span. She regained her composure enough to continue a short time, but she said that she was having nightmares about Epstein coming after her and she started to break down again, so we stopped the interview.
+
+The second girl, who has a baby girl of her own, told us that she was very upset about the 18 month deal she had read about in the paper. She said that 18 months was nothing and that she had heard that the girls could get restitution, but she would rather not get any money and have Epstein spend a significant time in jail.
+
+The FBI's victim-witness coordinator attended and she has arranged for counseling for several of the girls.
+
+Please reach out to Alice to make her decision. These girls deserve so much better than they have received so far, and I hate feeling that there is nothing I can do to help them.
+
+We have four more girls coming in tomorrow. Can I persuade you to attend?
+
+tr.t!. .Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777

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marker2-fixhub/ds9/EFTA00189310/EFTA00189310.md

@@ -0,0 +1,549 @@
+From: Sent: r 1 2008 2:03 PM To: (USAFLS) Subject: esponse to questions
+
+Hope you had a great weekend.
+
+Well it has not been easy and I dont know if you can make any sense of it.
+
+Facts: i ll eand lid contact 9 times between (7/15/2004 - 10/26/2004) a had contact 1 time (10/26/2004) This is appears to be. father's phone. We believe we have cel one at the time and no calls with •
+
+Testimony:
+
+brought) stated Spring of her Junior year. (Estimated to be Spring 2004)
+
+and I. stated sophomore year -( this time line does not fit at all)Mand both estimated to be ',ores
+
+IRstated she went between January and May of Senior year which is believed to be Jan - May 2005. She turned 2005. I do not know if she was being truthful about the time of the year or if she was more concerned about when she turned 18.
+
+SO00000who knows....
+
+Bom in 1986
+
+ni aduated from 11 {sup}`004` graduated from 2004
+
+From: Sent: To: Subject: =0rie: an more 1 1.ues ions
+
+I just recvd about 5 emails from you. I do not have my books here. I will look at things first thing tues and answer whatever we did not aliiiiii talk about. We did hear back from amazon and they would like cc info, will work with them next week. Sorry I did not get your emails sooner.
+
+Original Messa :e
+
+From: To: Sent: Fri Fe• 15 12:56:16 Subject: RE: I am back with more questions
+
+Hi They both other says MSS Just one more question, I hope. Where did e same school, but one says And do you know what year s o to school? High and the ey graduated?
+
+
+
+
+From: Sent: To: Subject: Re: I am back with 2008 10:36 AM more questions
+
+Only pbpd spoke with III (She was 18 @ the time) but we will think she will be cooperative. We dont have time frame for betwn 10/03-05/04. last visit. interview her and I went
+
+From: To: Sent: Fri Feb 15 0:14 2008 Subject: RE: I am back with more questions (USAFLS) V>
+
+
+Do we have any time frame, messages, or phone calls for ?
+
+From: Sent: n r 1 2008 4:48 PM To: Subject: coos
+
+grade year while attending 11th) believes she may have starting going her 10th y ■ **her arideaear(both 11 girls born In 87) and** 
+
+bo **went with**
+
+From: Sent: To: Subject: chools
+
+Thank you so much! Have a good weekend. I am headed out now, but will work on this at home.
+
+
+From: Sent: Fri Feb 5 2008 4:48 PM To: Sub ect: High Schools
+
+grade year while attending stated that bo 11th) - believes she may have starting going her 10th taken by III her. Ile year(both girls born in 87) and :went with II)
+
+From: Sent: To: Subject: (USAFLS) n ru , 008 1:38 PM Imeline
+
+Hi — I read =E's statement. She says she first went with End.between January and May of her senior year.
+
+She says on the second visit she went with This is weird because says she went with
+
+She says on the third visit, she went v. ith
+
+Assuming is correct about the order of visits and thatEwas with them on that trip, we are looking around July 2004 (becaus called t in July 2004).
+
+Is it safe to say that these events took place In or around the first half of 2004?
+
+From: USAFLS)
+
+Sent: na er , 008 1:08 PM
+
+To:
+
+Subject: o we have a time fame or any numbers or calls for
+
+
+From: (USAFLS
+
+Sent: Enda Febr 15 " 008 1 09 PM
+
+To:
+
+Subject: RE Do we have a timeframe or any numbers or calls fo-
+
+thanks.
+
+From: Sent: To: Subject: RE. I am back with more questions
+
+Hi Just one more question, I hope. Where did o to school? They both e same school, but one says High and the other says . And do you know what year s ey graduated?
+
+
+
+
+From: Sent\* Februar III To: Subject: e: am back with more questions 15. 2008 10:36 AM
+
+Only pbpd spoke with. (She was 18 @ the time) but we will interview her and I think she will be cooperative. We dont have time frame for went betwn 10/03-05/04. last visit.
+
+
+From: To: Sent: Fri Fe• 15 : Subject: RE: I am back with more questions
+
+
+
+
+From: Sent: n r 1 008 11.48 AM To: Subject: e: am ack wi more questions
+
+only 1 message no date possible 05/05
+
+From: To: Sent: Fri Feb 15 11:06:06 2008 Subject: RE: I am back with more questions
+
+What is MIIs phone number? Thanks.
+
+
+
+From: Sent\* February III To: Subject: e: am back with more questions 15, 2008 10:36 AM
+
+Only pbpd spoke within. (She was 18 @ the time) but we will interview her and I think she will be ciiierative. We dont have time frame for III Illand . went betwn 10/03-05/04. s last visit.
+
+essage
+
+From: To: Sent: Fri Feb 15 10:10:14 2008 Subject: RE: I am back with more questions j.gov>
+
+
+
+
+From: Sent: ay. 8 11:20 AM To: Subject: h more questions
+
+I thought I had a complete set of the message pads here, but I only have the copies of the messages that have identified girls' names. Can you look through the message pads and tell me what the ones from say?
+
+Thank you (so sorry)
+
+
+
+From: Sent • February 15, 2008 10:36 AM To: Subject: Re: am back with more questions
+
+Only pbpd spoke with (She was 18 @ the time) but we will interview her and I think she will be cooperative. We dont have time frame for went betwn 10/03-05/04. last visit.
+
+From. To: Sent: Fri Feb 15 1,:10:14 2008 Subject: RE: I am back with more questions
+
+
+
+
+
+From: (USAFLS) im S Sent: 11. a. 1a 1.00 To: Subject: RE::1 am with more questions
+
+What is Mil's phone number? Thanks.
+
+
+
+From: Sent\* February 15, 2008 10:36 AM To: (USAFLS) Subject: Re: I am back with more questions
+
+Only pbpd spoke within (She was 18 @ the time) but we will interview her and I think she will be cooperative. We dont have time frame for went betwn 10/03-05/04. last visit.
+
+
+From: USAFLS) < To: Sent: Subject: RE: I am back with more questions
+
+
+
+
+From: Sent: To: Subject: riday. February 15 2008 10:36 AM e: I am back with more questions
+
+Only pbpd spoke with (She was 18 @ the time) but we will interview her and I think she will be iiirerative. We dont have time frame for ent betwn 10/03-05/04. s last visit.
+
+From: > To: Sent: Fri Feb 15 10:10:14 2008 Subject: RE: I am back with more questions
+
+Did you ever talk to .?
+
+Do we have any time frame, messages, or phone calls for a
+
+
+From: Sent: To: (USAFLS) n rui 08 10:31 AM
+
+Hi — Didn't you tell me that stimated that she brought 100 girls? It isn't in the 302. And did she explain what happened during that e with Epstein?
+
+
+From: Sent: To: Subject: Fnda e rua . RE I am back with more questions
+
+
+Do we have any time frame, messages, or phone calls fora.?
+
+
+From: Sent: hur Fe r ry 14, 2008 5:29 PM To: Subject: rat vert cts
+
+•
+
+Hi guys — Here is the most recent draft. I have only looked at the overt acts sections for the girls we are keeping. Can you go through those and check the facts? Also, can you figure out which trips we can drop from the oven acts? I think I only have 2 phone calls from so if there are some calls I can add, please point those out, too.
+
+I will turn to the new girls tomorrow.
+
+
+![](_page_15_Picture_4.jpeg)
+
+080214 revised indict men .pdf
+
+From: Sent: Thursday. urs February 14. 2008 3:13 PM To: Subject: RE: List of names
+
+I am having a really hard time e-mailing you guys. My e-mails are getting bounced back so I have to re-send numerous times until it goes through. Do you know if there is something wrong with the FBI's server?
+
+
+Oillos im
+
+From: (USAFLS) Sent: T urs a February 14, 2008 3:11 PM To: Subject: RE: List of names
+
+
+inal
+
+F Sent\* , Februar 14, 2008 3:10 PM To: Subject: Re: list o names
+
+NYC or MOM
+
+To: Sent: T u Fe 14 14:57:31 2008 Subject: RE: List of names
+
+From: (USAFLS) Sen • • To: Subject: List of names
+
+![](_page_17_Picture_34.jpeg)
+
+( [REDACTED] eyewitness info only)
+
+![](_page_17_Picture_36.jpeg)
+
+- initials only, not a listed Jane Doe
+
+![](_page_17_Picture_38.jpeg)
+
+Not all will be in substantive counts, but they will be mentioned in the overt acts.
+
+![](_page_17_Picture_40.jpeg)
+
+![](_page_17_Picture_42.jpeg)
+
+![](_page_17_Picture_44.jpeg)
+
+
+**From:** [REDACTED]  
+**Sent:** Thursday, February 14, 2008 3:11 PM  
+**Subject:** RE: List of names
+
+
+
+-----Original Message-----
+
+**From:** [REDACTED]  
+**Sent:** Thursday, February 14, 2008 3:10 PM  
+**To:** [REDACTED] (USAFLS)  
+**Subject:** Re: List of names
+
+[REDACTED] P?? NYC or [REDACTED]
+
+----- Original Message -----
+
+**From:** [REDACTED] (USAFLS) <[REDACTED]>  
+**Sent:** Thu Feb 14 14:57:31 2008  
+**Subject:** RE: List of names
+
+**From:** [REDACTED] (USAFLS)  
+**Sent:** Thursday, February 14, 2008 1:43 PM  
+**Subject:** List of names
+
+Here are the names of people I am intending to keep in the indictment:
+
+[REDACTED] eyewitness info only)
+
+
+- initials only, not a listed Jane Doe
+
+
+![](_page_19_Picture_0.jpeg)
+
+Not all will be in substantive counts, but they will be mentioned in the overt acts.
+
+![](_page_19_Picture_2.jpeg)
+
+![](_page_19_Picture_4.jpeg)
+
+From: Sent: To: Subject: is names
+
+Sent: t o iFi To: Subject: List of names
+
+Here are the names of people I am intending to keep in the indictment:
+
+eyewitness info only) — initials only, not a listed Jane Doe
+
+Not all will be in substantive counts, but they will be mentioned in the oven acts.
+
+From:
+
+Sent:
+
+To: Subject: Th r Februa 14 2008 2:39 PM
+
+now you to n when I do this, but ...
+
+I always seem to notice something new when I go through these records. In Janusz's notes, he shows a payment to Golden Cab on 6/17/05. Can you call and see if they have an ill s or any trips tcl-EI Brillo Way? Or a Dennis working there? And that long string of unknown numbers on . s cell phone. Could those be a group of lines for Yellow Cab?
+
+
+I am almost finished with the changes to the girls we are keeping. I will send that to you and then when I finish the new girls, I will send that portion.
+
+From: Sent: To: Subject: List of names
+
+Here are the names of people I am intending to keep in the indictment:
+
+( eyewitness info only)
+
+— initials only, not a listed Jane Doe
+
+Not all will be in substantive counts, but they will be mentioned in the overt acts.
+
+From: Sent: To: Subject:
+
+Eli guys — sorry to bother you. On some of the new girls I don't have dobs.
+
+(the 302 says her dob
+
+(and do we have a phone number?)
+
+Have you guys ever talked to or MI Should I include them?
+
+. (USAFLS)
+
+From: Sent: To: Subject: RE Epstein Indictment 2008 1:21 PM
+
+Hi — I didn't send the indictment 's et. I was just asking for input on who to include and who to exclude.
+
+How old was when she went with
+
+Assistant U.S. Attorne)
+
+From: Sen 14, 2008 1:00 PM To: Subject: RE: Epstein Indictment
+
+Hey =,
+
+There was no indictment attached to your email. Can you send it again.
+
+In addition to the two calls from on her cell phone 41/04 at 1:35 pm and 5/2/04 at 10:32 am, we have two telephone calls from 9:46 am and 2:30 pm. ( boyfriend) telephone on 03/04/2004 at
+
+Message pads reflect 10 i es from inning 03/11/2003 ending 03/01/2006. Individuals identified as taking the messages are Michae , and Alfredo Rodnguez.
+
+From: Sen To: Su : RE: Epstein Indictment AM
+
+FYI — Tell me what you think. Also, can you pull the messages from what the dates are and who took the messages? Thanks. and see if you can tell
+
+at we have only two phone calls with M? 4/23/04 and 5/2/04
+
+
+Froi LWILMI (USAFI.S) Sent u y,February 14, 2008 11:22 AM To: Subject: Epstein Indictment
+
+H i — Our server was down for a few hours this morning, so I am very behind on my revisions. I wanted to talk about whic • Is we should drop.
+
+and are the girls who have filed lawsuits. I have excluded them.
+
+With respect to the other girls brought by , here are my thoughts. We c and a. very easily. Both only gave I or 2 massages and did not disclose their ages. is a good witness because she shows that, if you aren't willing to do more sexual activity, Epstein stops the massage and doesn't want to see you anymore. She seems like someone whom we could get in as 404(b) because the probative nature outweighs its p
+
+I think we should drop because I don't believe she will ever be completely amount of sexual activity that occurred. (She is the girl that one of the witnesses described as ...)
+
+That only leaves who cried for the entire interview. I think that she may be worth keepi such good documents evidence related to her — message 'pads, car rental records, 156 calls wit and 2 calls wit (we have very few phone calls with so this is M).
+
+What • {sup}`9`
+
+From: Sent: Thur d 2008 1:00 PM To: (USAFLS) Subject: pstein ndictment
+
+Hey
+
+There was no indictment attached to your email. Can you send it again.
+
+In addition to the two calls from on her cell phone 4/23/04 at 1:35 pm and 5/2/04 at 10:32 am, we have two telephone calls fro to ( boyfriend) telephone on 03/04/2004 at 9:46 am and 2:30 pm.
+
+Message pads reflect 10 messages from inning 03/11/2003 ending 03/01/2006. Individuals identified as taking the messages are Michael, rand Alfredo Rodnguez.
+
+From: (USAFLS) [Ann. Sen • AM To: Sub : RE: Epstein Indictment
+
+FYI — Tell me what you think. Also. can you pull the messages from what the dates arc and v'ho took the messages? Thanks. and see if you can tell
+
+And am I correct that we have only two phone calls with 4/23/04 and 5/2/04
+
+
+From: (USAFLS) Sent: urs ay, February 14, 2008 11:22 AM To: Subject: Epstein Indictment
+
+Hi — Our server was down for a few hours this morning, so I am very behind on my revisions. I wanted to talk about which girls we should drop.
+
+and a are the girls who have filed lawsuits. I have excluded them.
+
+With respect to the other girls brought by M, here are my thoughts. We c and very easily. Both only gave I or 2 massages and did not disclose their ages. S. is a good witness because she shows that, if you aren't willing to do more sexual activity, Epstein stops the massage and doesn't want to see you anymore. She seems like someone whom we could get in as 404(b) because the probative nature outweigh its p e.
+
+drop sexual activity that occurre . (She is the girl that one of the witnesses described as' I think we shouldrop because I don't believe she will ever be completely amount of
+
+That only leaves who cried for the entire interview. I think that she may be worth keeping. We have such good documentary evidence related to her — message pads, car rental records, 156 calls
+
+with key). and 2 calls wit we have very few phone calls with a so this is
+
+From: Sent: To: Subject: Thur F r 14, 2008 12:37 PM (USAFLS) pstein ndictment
+
+I'm not supposed to be involved in tantive decisions until I get word from "on high\*. However, my general thoughts are that you are correct. ie of th vidence and will be a good witness, reluctant one. Am I correct to assume that and are still in? Their past history will have to be dealt with and it won't be easy, but I agree that they s ou be left in. The fact that their were post-Epstein is good but his attorrsiare going to try to destroy them Is n as well? I thought t at s e was truthful. What about IM ?
+
+From: sent:imrs,,wc.rbiciw M{sup}`t` jaryINI , (U200SA8F1LS1:)22(maAmilto=a To: Subject: Epstein Indictment
+
+Hi Our server was down for a few hours this morning. so I am very behind on my revisions. I wanted to talk about which girls we should drop.
+
+and MI. are the girls who have filed lawsuits. I have excluded them.
+
+With respect to the other girls brought by , here are my thoughts. We can drop and IMIE very easily. Both only gave I or 2 massages and did not disclose their ages. is a good witness because she shows that, if you aren't willing to do more sexual activity, Epstein stops the massage and doesn't want to see you anymore. She seems like someone whom we could get in as 404(b) because the probative nature outweighs its prejudice.
+
+I think we should drop a because I don't believe she will ever be completely truthful about the amount of sexual activity that occurred. (She is the girl that one of the witnesses described as' a")
+
+That only leaves who cried for the entire interview. I think that she may be worth keepin . We have such good documents evidence related to her — message pads, car re with and 2 calls with we have very few phone calls wit , 156 calls o this is key).
+
+
+From: (USAFLS) Sent: h r Fe r 14 2008 11:41 AM To: Subject: •pstein n is men
+
+FYI - Tell me what you think. Also, can you pull the messages from dates are and who took the messages? Thanks. and see if you can tell what the
+
+And am I correct that we have only two phone calls with M! 4/23/04 and 5/2/04
+
+Assi tant U.S. Attorney
+
+From: (USAFLS) Sent: urs ay, ruary 14, 2008 11:22 AM To: Subject: Epstein Indictment
+
+Hi — Our server was down for a few hours this morning, so I am very behind on my revisions. I wanted to talk about which girls we should drop.
+
+and L. are the girls who have filed lawsuits. I have excluded them.
+
+With respect to the other girls brought by here are my thoS can drop and RIP very easily. Both only gave 1 or 2 massages and did not disclose their ages. is a good witness because s e shows that, if you aren't willing to do more sexual activity, Epstein stops the massage and doesn't want to see you anymore. She seems like someone whom we could get in as 404(b) because the probative nature outweighs its prejudice.
+
+I think we should drop W. because I don't believe she will ever be complete) truthful about the amount of sexual activity that occurred. (She is the girl that one of the witnesses described as 4 ")
+
+That only leavea who cried for the entire interview. I think that she may be worth and 2 calls wit kee in . We have suchgood documentary evidence related to her — message (we have very few phone calls wit I records, 156 calls with this is key).
+
+
+From: (USAFLS) Sent: 14, 2008 11:28 AM To: Subject: : psi
+
+FYI — Tell me what you think. Also, can you pull the messages fromdates are and who took the messages? Thanks. and see if you can tell what the
+
+And am I correct that we have only two phone calls with 4/23/04 and 5/2/04
+
+
+Frt il tIMMEIC Sent: u JSARS) February 14, 2008 11:22 AM To Subject: Epstein Indictment
+
+HUM- Our server was down for a few hours this morning, so I am very behind on my revisions. I wanted to talk about which girls we should drop.
+
+and are the girls who have filed lawsuits. I have excluded them.
+
+With respect to the other girls brought by here are my th e can drop and a very easily. Both only gave I or 2 massages and did not disclose their ages. is a good witness because she shows that, if you aren't willing to do more sexual activity, Epstein stops the massage and doesn't want to see you anymore. She seems like someone whom we could get in as 404(b) because the probative nature outweighs its prejudice.
+
+think we should drop because I don't believe she will ever be corn ount of sexual activity that occurred. Is the girl that one of the witnesses described as' ")
+
+That only leaves We have such g and 2 calls with who cried for the entire interview. I think that she may be worth kee in . idence related to her — message pa tal records, 156 calls with we have very few phone calls with so this is key).
+
+
+From: (USAFLS) Sent: 2008 11:22 AM To: Subject: Epstein Indictment
+
+Hi — Our server was down for a few hours this morning, so I am very behind on my revisions. I wanted to talk about which girls we should drop.
+
+and =. are the girls who have filed lawsuits. I have excluded them.
+
+With respect to the other girls brought by M, here are my thoughts. We can drop and very easily. Both only gave I or 2 massages and did not disclose their ages. is a good witness because she shows that, if you aren't willing to do more sexual activity. Epstein stops the massage an doesn't want to see you anymore. She seems like someone whom we could get in as 404(b) because the probative nature outweighs its prejudice.
+
+I think we should drop because I don't believe she will ever be completely truthful about the amount of sexual activity that occurred. (She is the girl that one of the witnesses described as' ")
+
+That only leaves who cried for the entire interview. I think that she may be worth keeoinQ.
+
+We have suchgood documents evidence related to her — message pads car rental records, 156 calls with and 2 calls wit we have very few phone calls with so this is key).
+
+
+From: Sent: muesca imes . 201 L) 08 4:31PM To: Subject: rme numbers
+
+Dr. Bard
+
+Can you e-mail me your summary chart, too? The Excel spreadsheet.
+
+
+From: (USAFLS) Sent: luesc uary , 2008 4:33 PM To: Subject: e ephone num ers
+
+Can you e-mail me your summary chart, too? The Excel spreadsheet.
+
+
+From: (USAFLS) Sent: ry , 2008 3:19 PM To: Subject: e one charts an' phone records
+
+Hi - I am t in to et this indictment package finalized. Can ou e-mail to me the final telephone charts for all of the girls and Also, do you have all of records electronically? Maybe we can search for phone numbers for some of the new girls, even though we don't have their phone records yet.
+
+Also, can you check on the lead to New York? Ideally, I would like to turn the package in on Thursday, so I need to know if we can include any of those girls.
+
+When you have a chance, please give me a call. I am in the U.S. Attorney's Office —
+
+From: Sent: To: Subject: Wows e. hone call in o
+
+Ill fax it in 5 min(what fax U?)
+
+From: (USAFLS) < To: Sent: Fri Feb 22 14:07:06 2008 Subject: Phone call info
+
+Hi - Can you e-mail or fax me the dates of the calls? I can add them to the indictment today. I think is going to try to finish her review over the weekend.
+
+
+
+500 S. Australian Ave, Suite 400
+
+West Palm Beach, FL 33401
+
+Phone 561 209-1047
+
+Fax
+
+From: (USAFLS) Sent: 1.111.11008 210 PM To: Subject: : one ca in o
+
+Thanks
+
+ssis an . . orney
+
+Ori inal Messa
+
+From: Sent' 2008 2:08 PM To: . (USAFLS) Subject: Re: Phone call info
+
+Ill fax it in 5 min(what fax #?)
+
+From: (USAFLS) < To: Sent: Fri Feb 22 14:07:06 2008 Subject: Phone call info
+
+Hi 11111111- Can you e-mail or fax me the dates of the calls? I can add them to the indictment today. I think is going to try to finish her review over the weekend.
+
+
+
+500 S. Australian Ave, Suite 400
+
+West Palm Beach, FL 33401
+
+Phone 561 209-1047
+
+Fax
+
+USAF LS)
+
+From: (USAFLS) Sent: 08 2:07 PM To: Subject: ne ca in
+
+Hi you e-mail or fax me the dates of the calls? I can add them to the indictment today. I think s going to try to finish her review over the weekend.
+
+
+From: (USAFLS) Sent: To: Subject: t tie e x records
+
+Ma ss last name is and her phone number is Mice number, not a cell phone number). They also show another corporate name: "
+
+They show a phone number for Epstein and Eric Gany as
+
+illhave an e-mail address for-as: and show her phone number as
+
+The notes show that the credit card was declined and then they show Bella Tsukeman at with company name "NYSG LLC"
+
+They want us to be more specific about individual shipment records, so we will have to comb through what they gave us to identify specific shipments.
+
+I am running to lunch but will be back this afternoon.

marker2-fixhub/ds9/EFTA00189310/EFTA00189310.receipt.json

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marker2-fixhub/ds9/EFTA00189349/EFTA00189349.md

@@ -0,0 +1,9 @@
+C. (USAFLS)
+
+From: C. (USAFLS) Sent: uesd yieliary 26. 2008 10'05 AM To: Subject: pstein
+
+Hi I won't even tell you about how today is starting off badly on this case (politics, of course, not facts . ut, in any event, the word is that CEOS is going to undertake an "independent review" of the case and meet with Epstein's attorneys some time next week. My supervisor is finishing the review of the indictment package and I know she caught some typos. When I finish those revisions, I will e-mail to you the entire indictment package, and you can find out what Drew wants to look at. I have one real concern, however. As you know, there are several girls that are still unknown to the defense. I want to avoid si possibility that those names might be disclosed. Should I redact the names of all of the girls from the pros memos that I send to you?
+
+Thank you,
+
+Assistant U.S. Attorney 500 S. Australian Ave Suite 400 West Pa Fax 561 820-8777

marker2-fixhub/ds9/EFTA00189349/EFTA00189349.receipt.json

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marker2-fixhub/ds9/EFTA00189350/EFTA00189350.md

@@ -0,0 +1,23 @@
+From ) Sent: Tuesday, February 9:41 AM To: Sloman Jeff USAFLS) Cc: FLS) Stabled: E. Confidential
+
+• Why would we possibly let him keep the same deal after all he has put us through? And after we have discovered 6 new girls, plus another 3 probable victims in New York?
+
+Assistant U.S. 500 S. Australian Ave. Suite 400 West Palm Beach. FL 33401 Fax 561 820-8777
+
+From: Sloman, Jeff (USAFLS) Sen iii b jSUZZ ua To: Subject: Confidential
+
+FYI
+
+From: Sloman, Jeff (USAFLS) Sent: Monday, February 25, 2008 7:43 PM To: JLefkowitz@kirkland.com Cc: Oosterbaan, Andrew Subject: Epstein
+
+Jay,
+
+The Section Chief of DOJ's Child Exploitation Obscenity Section (CEOS) notified me today that he will review the matter involving your client Jeffrey Epstein. The Section Chief has indicated that he is ready to proceed immediately, and I understand you are in the process of providing him this week with a summary of issues to be reviewed, and expect to meet with him next week.
+
+The Section Chief also indicated that you would be calling this Office regarding the upcoming March 3, 2008 court date in the Fifteenth Judicial Circuit, in and for Palm Beach County. As you know, the Agreement entered into by your client originally provided that the United States
+
+Attorney's Office for the Southern District of Florida (this Office) would defer prosecution if your client pled guilty to enumerated state charges by October 26, 2007. Since then, that date has been postponed for a number of reasons. At this juncture, it would not be reasonable to keep the current March 3'd date as a deadline for compliance with the Agreement. That said, this Office is very concerned about additional delays. Despite this concern, I want to assure you that if counsel for Mr. Epstein meets with CEOS next week (the week of March 3rd), this Office will extend the time for compliance with the Agreement to provide CEOS time to engage in a thorough review.
+
+It goes without saying that in the event that CEOS decides that a federal prosecution should not be undertaken against Mr. Epstein, this Office will close its investigation. However, should CEOS disagree with Mr. Epstein's position, Mr. Epstein shall have one week to abide by the terms and conditions of the September 24, 2007 Agreement as amended by letter from United States Attorney Acosta to Jay Lefkowitz.
+
+Jeffrey H. Sloman First Assistant U.S. Attorney Southern District of Florida

marker2-fixhub/ds9/EFTA00189350/EFTA00189350.receipt.json

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marker2-fixhub/ds9/EFTA00189352/EFTA00189352.md

@@ -0,0 +1,156 @@
+(USAFLS)
+
+From: (USAFLS) Sent: m 2008 5:58 PM To: Subject: :Epstein u ate
+
+I don't think we have an issue with staleness because the memory cards are fixed (they haven't changed since the original search warrant).
+
+Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm h FL 33401
+
+Ori inal Messa e
+
+From: Sent\* 2008 5:55 PM To: (USAFLS) Subject: Re: Epstein up ate
+
+I like your style! Unsure what communication btw we have staleness issues with SW? is about?? Also do
+
+o e
+
+Cc: Sent: Wed Mar 05 16:54:35 2008 Subject: Epstein update
+
+Hi all - I wanted to update you on a couple of new developments in the Epstein case. First, Jeff Herman is supposed to give a press conference today announcing the filing of a third lawsuit against Epstein. That case also involves a victim whom we are no longer referring to in the indictment [Drew - tell that to the defense.] Herman seems to have latched onto the group which, as discussed in my third addendum to the pros memo, we ave a rea y decided to forego for the most part.
+
+Drew - Since I am not certain of the scope of your meeting, I do not know how critical it is for you to see the new facts developed in the supplemental pros memos (you reviewed the initial pros memo from May of last year). If you would like the supplements, please let me know. The legal theories have remained the same.
+
+I also wanted to call to everyone's attention the three-year statute of limitations in Florida for the state solicitation offenses. The statute will run for all the victims this summer. Once it runs we cannot insist on a state court plea to a new charge. It also means that the state cannot charge the crimes related to the victims discovered after the initial investigation. We have asked the Palm Beach Police Department to forego presenting thdse charges for state prosecution in deference to our prosecution. If we do not intend to go forward, it is imperative that we communicate that to the Police Department as soon as possible so they can present those victims for state prosecution.
+
+I have reserved time with the grand jury on the 18th. I had hoped to present the indictment at that time, but in light of IIIMMOIcommunication with I will push it off until the 25th. I would still like to start the presentation on the 18th so we aren't accused of rushing the grand jury. So; I hope that the final indictment packet will be approved by that date.
+
+
+[REDACTED] (USAFLS)
+
+From: [REDACTED]  
+Sent: Wednesday, March 05, 2008 5:55 PM  
+To: [REDACTED] (USAFLS)  
+Subject: Re: Epstein update
+
+I like your style! Unsure what communication btw [REDACTED] is about?? Also do we have staleness issues with SW?
+
+----- Original Message -----
+
+Endm: [REDACTED]  
+
+Sent: Wed Mar 05 16:54:35 2008  
+Subject: Epstein update
+
+Hi all - I wanted to update you on a couple of new developments in the Epstein case. First, Jeff Herman is supposed to give a press conference today announcing the filing of a third lawsuit against Epstein. That case also involves a victim whom we are no longer referring to in the indictment [Drew - please do not tell that to the defense.] Herman seems to have latched onto the [REDACTED] group which, as discussed in my third addendum to the pros memo, we have already decided to forego for the most part.
+
+Drew - Since I am not certain of the scope of your meeting, I do not know how critical it is for you to see the new facts developed in the supplemental pros memos (you reviewed the initial pros memo from May of last year). If you would like the supplements, please let me know. The legal theories have remained the same.
+
+I also wanted to call to everyone's attention the three-year statute of limitations in Florida for the state solicitation offenses. The statute will run for all the victims this summer. Once it runs we cannot insist on a state court plea to a new charge. It also means that the state cannot charge the crimes related to the victims discovered after the initial investigation. We have asked the Palm Beach Police Department to forego presenting those charges for state prosecution in deference to our prosecution. If we do not intend to go forward, it is imperative that we communicate that to the Police Department as soon as possible so they can present those victims for state prosecution.
+
+I have reserved time with the grand jury on the 18th. I had hoped to present the indictment at that time, but in light of Jeff's communication with Jay, I will push it off until the 25th. I would still like to start the presentation on the 18th so we aren't accused of rushing the grand jury. So, I hope that the final indictment packet will be approved by that date.
+
+
+(USAFLS)
+
+From: (USAFLS) Sent: n rc , 2008 10:39 AM To: Subject: RE Epstein
+
+Sounds good. I think it is worth doing the search warrant. Can Jason get the cards out of evidence when he is down there?
+
+Do you have a copy of your affidavits that we submitted on the computer issue? I think those are a good stan for the search warrant affidavit. Thanks.
+
+> to 400 01
+
+From: Sen 05, 2008 10:35 AM To: (USAFLS) Subject: RE: Epstein
+
+Marie,
+
+Still no word from Mr. Herman. Just to clarify about the memory cards - Joe and Jason have both reviewed the evidence some time ago. There is no significant photographs on the cards. However, a forensic analysis was not done which would show any deleted photos. Jason has to go tomorrow to Miami. I have asked him to pick up the copies of documents, obtain the copyright date for the "Massage for Dummies" book and get a description of the memory cards should we decide to go ahead with a search warrant. We're still working on obtainirsi of the girls' phone records. I have put Hauge on standby to put together the travel/phone charts once we have and Jennifers' records. I'll give you a call once I have spoken with Herman.
+
+From: (USAFLS) Sen • , 08 12:15 PM To: Su : RE: Epstein
+
+Thank you for the update. On the statute of limitations. it doesn't matter for the pending charges because they were indicted in time, it just matters to adding new charges.
+
+Can you call Mr. I lerman and see if he will give us the following items without a subpoena?
+
+- I. Copy of deposition transcript
+- 2. Copy of any vi eo and/or audiorccording of that deposition
+- 3. Transcript(s) of any other depositions taken in that suit
+- 4. Copies of any e-mails and correspondence sent to or received from Epstein or his lawyers
+- 5. Co ies of an agreements formal or informal entered into between Epstein/his lawyers and dad/their lawyers.
+
+
+![](_page_5_Picture_2.jpeg)
+
+From: Sen ii 2(0u0sA8 Flis1:2)4 AM To: Subject: Epstein
+
+Hey
+
+I Just heard from Joe that Mr. Herman is holding another press conference tomorrow at Palm Beach Town Mat 1:00pm. He called the Town of Palm Beach to see if he could hold it at EPSTEIN's residence. They told him "NO".
+
+From: Sent: W n r h . 2008 10:35 AM To: (USAFLS) Subject: pstein
+
+Marie,
+
+Still no word from Mr. Herman. Just to clarify about the memory cards - Joe and JaOri have both reviewed the evidence some time ago. There is no significant photographs on the cards. However, a forensic analysis was not done which would show any deleted photos. Jason has to go tomorrow to Miami. I have asked him to pick up the copies of documents, obtain the copyright date for the "Massage for Dummies" book and get a description of the memory cards should we decide to go ahead with a search warrant. We're still walking on obtain of the iris' records. I have put Hauge on standby to put together the travel/phone charts once we have a records. I'll give you a call once I have spoken with Herman.
+
+From: (USAFLS)■ **Sen i 8 12:15 PM To: Subject: RE: Epstein** 
+
+**Thank you for the update. On the statute of limitations. it doesn't matter for the pending charges because they were indicted in time. it just matters to adding new charges.** 
+
+**Can you call Mr. Herman and see if he will give us the following items without a subpoena?** 
+
+- **I. Copy o deposition transcript**
+- **2. Copy of any video and/or audiorecording of that deposition**
+- **3. Transcript(s) of any other depositions taken in that suit**
+- **4. Copies of any e-mails and correspondence sent to or received from Epstein or his lawyers**
+- **5. Co ies of any agreements formal or informal entered into between Epstein/his lawyers and dad/their lawyers.**
+
+**And maybe you can ask him why there will be a press conference?** 
+
+**Thank you.** 
+
+![](_page_6_Picture_9.jpeg)
+
+**From: Sen To: Sub : Epstein 2008 11:24 AM (USAFLS)** 
+
+**Hey** 
+
+![](_page_6_Picture_12.jpeg)
+
+I just heard from Joe that Mr. Herman is holding another press conference tomorrow at Palm Beach Town at 1:00pm. He called the Town of Palm Beach to see if he could hold it at EPSTEIN's residence. They told him NO'.
+
+[REDACTED] (USAFLS)
+
+**From:** [REDACTED] (USAFLS)  
+**Sent:** Tuesday, March 04, 2008 12:16 PM  
+**To:** [REDACTED]  
+**Subject:** RE: Epstein
+
+Thank you for the update. On the statute of limitations, it doesn't matter for the pending charges because they were indicted in time, it just matters to adding new charges.
+
+Can you call Mr. Herman and see if he will give us the following items without a subpoena?
+
+1. 1. Copy of [REDACTED] deposition transcript
+2. 2. Copy of any video and/or audiorecording of that deposition
+3. 3. Transcript(s) of any other depositions taken in that suit
+4. 4. Copies of any e-mails and correspondence sent to or received from Epstein or his lawyers
+5. 5. Copies of any agreements – formal or informal – entered into between Epstein/his lawyers and [REDACTED] dad/their lawyers.
+
+And maybe you can ask him why there will be a press conference?
+
+
+
+**From:** [REDACTED]  
+**Sent:** Tuesday, March 04, 2008 11:24 AM  
+**To:** [REDACTED] (USAFLS)  
+**Subject:** Epstein
+
+Hey Marie,
+
+I just heard from Joe that Mr. Herman is holding another press conference tomorrow at Palm Beach Town [REDACTED] at 1:00pm. He called the Town of Palm Beach to see if he could hold it at EPSTEIN's residence. They told him "NO".
+
+From: Sent: ue da r 4 8 11:24 AM To: (USAFLS) Subject: pstein
+
+Hey Marie,
+
+I just heard from Joe that Mr. Herman is holding another press conference tomorrow at Palm Beach Town Nat 1:00pm. He called the Town of Palm Beach to see if he could hold it at EPSTEIN's residence. They told him NO".

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marker2-fixhub/ds9/EFTA00189362/EFTA00189362.md

@@ -0,0 +1,733 @@
+From: Villafana, Ann Marie C. (USAFLS) Sent: Friday. March 21 2008 3.47 PM To: Gelber. Subject: RE: Follow up
+
+Eli — Don't worry, I have decided to just wait to see your result. I think the state charges don't fit the crime anyw y, and I have the tapes of the grand jury presentation, where the Assistant State Attorney crossexamined the victims instead of simply presenting the case. (The defense doesn't know that we have those tapes.) The State's handling of the case was one of the reasons why we looked into this in the first place.
+
+As I mentioned earlier, I will be out next week. Starting on late Tuesday or Wednesday, I should be able to check e-mail, so feel free to contact me that way. My cell phone is 561 601-2301, and you can reach Nesbitt on her cell phone at 954 553-3471.
+
+Thanks again.
+
+A. Marie Villaptia Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777
+
+From: Gelber, Sent: Friday, a , 2008 3:20 PM To: Villafana, Ann Marie C. (USAFLS); Oosterbaan, Andrew Cc: Sloman, Jeff (USAFLS); Senior, Robert (USAFLS) Subject: RE: Follow up
+
+Thanks Marie, that is very helpfuL Please don't take my question as a su:,:estion that the state drop the charges — I just needed this information to round out the discussion about the petite policy.
+
+From: Villafana, Ann Marie C. (USAFLS) rmailto:Ann.Marie.C.Villafana@usdolgov] Sent: Frida ch 21, 2008 3:15 PM To: Gelber, Oosterbaan, Andrew Cc: Sloman, IS); Senior, Robert (USAFLS) Subject: RE: Follow up
+
+I I i Here is the info that I have. Jeopardy attaches at the start of the presentation of evidence at trial, so that show not be an issue.
+
+The bigger problem is the statute of limitations. A defendant can waive his right to challenge the statute under Florida law. but I don't think that Epstein will be willing to do so.
+
+At this point he also could demand a speedy trial. Once he has done so, if the trial is not held very quickly. he can move for "discharge." Once -discharged." Epstein cannot be prosecuted on the crime charged or any other crimes that could have been charged as a result of the same conduct or criminal episode. The State cannot avoid this bar by filing a "Nolle Prosequi" and then trying to re-file the same or different charges based on the same conduct or criminal episode.
+
+*A. Marie Villafaña*  
+
+**From:** Gelber, [REDACTED]  
+**Sent:** Friday, March 21, 2008 11:51 AM  
+
+One more question – do you know when double jeopardy attaches under Florida law? More specifically, if the state charges were dropped now, could they be dropped without prejudice?
+
+---
+
+**From:** Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie.C.Villafana@usdoj.gov]  
+
+Hi [REDACTED] – The state indictment is related to two girls. One of those girls is included in the federal indictment, the other is not. The state indictment charges solicitation of adult prostitution, it does not charge any child exploitation offense, despite the fact that, under Florida law, neither lack of knowledge of age nor affirmative misrepresentation of age by the victim is a defense.
+
+The victim from the state case who is referenced in the federal indictment told Epstein her true age and he engaged in full sexual intercourse with her a few days shy of her 18{sup}`th` birthday. For that birthday, he gave her a series of gifts, including lingerie. The other 18 girls named in the current indictment are not part of the state indictment.
+
+The state case currently has a trial date set for July. Before we got involved, the police were told that Epstein was going to plead to a misdemeanor and get no jail time. (That is one of the reasons why they asked the FBI to step in.) Since the federal investigation began, Epstein's counsel have continued the case repeatedly on the basis that they cannot resolve that case until the federal case is resolved. As part of the non-prosecution agreement that the Office put together with Epstein, the federal case was supposed to be resolved if Epstein agreed to three main terms: (1) he had to plead to a state offense for which sex offender registration was required, specifically, the procurement of minors to engage in prostitution; (2) he had to agree to an 18-month term of incarceration; and (3) he had to agree to pay restitution and damages to the victims. After the agreement was signed, he then tried to escape all three requirements.
+
+He objected to pleading to the state charge, claiming that the facts did not apply, and asked to plead to a non-registrable offense instead. When we responded that there were four other registrable offenses where the facts certainly fit, those were rejected because (1) they required registration and (2) the state sentencing guidelines for those offenses were too high.
+
+He tried to arrange to get out on work release, which would allow him to "work" anywhere he liked during the day and sleep in a halfway house, rather than a jail, at night. When he learned that sex offenders
+
+weren't allowed to be a part of the work release program, he started complaining about the jail time. He now wants to get a "suspended sentence" and/or home confinement, instead.
+
+He complained that he should be able to fully litigate the issues of liability and damages with regard to the third term of the agreement, despite his agreement directly to the contrary.
+
+With respect to the current status of the state case, other than the new trial date, all that I know is that Epstein is now subpoenaing victims for depositions who are not included in the state indictment. (Under Florida law, defense counsel are allowed to depose witnesses, including victims, prior to trial.) He seems to be trying to use that process to get information about the federal investigation. I do not know whether Epstein's misdemeanor deal is back on the table because the defense demanded that we have no contact with the State Attorney's Office, so I haven't spoken with the ASA in over 6 months.
+
+I wish I had more information to give you. If you would like me to reach out to either the local detective on the state case or the Assistant State Attorney, please let me know. Or, if you would like their contact info, I can forward that to you, too.
+
+Thank you. 1 will be back in the office tomorrow and you can call me there with any other questions.
+
+A. Ma►ie **Villafaiia** 
+
+**Assistant U.S. Attorney** 
+
+**561 209-1047** 
+
+**Fax 561 820-8777** 
+
+**From: Gelber,** 
+
+**Sent: Thursday, March 20, 2008 11:49 AM** 
+
+**To: Oosterbaan, Andrew; Villafana, Ann Marie C. (USAFLS)** 
+
+**Cc: Sloman, Jeff (USAFLS)** 
+
+**Subject: RE: Follow up** 
+
+**Marie,** 
+
+**Two quick questions: Could you clarify whether any of the victims that are included in the state indictment would also be included in any federal indictment? If you know, what is the status of the state case?** 
+
+**Thanks,** 
+
+**From: Oosterbaan, Andrew** 
+
+**Sent: Wednesday, March 19, 2008 7:17 PM** 
+
+**To: VillafanaAnn Marie C. (USAFLS)** 
+
+**Cc: Gelber, Sloman, Jeff (USAFLS)** 
+
+**Subject: RE: Follow up** 
+
+**I'm running out the door, but I wanted to get a response off. Sorry for not updating you sooner. The meeting went well enough. They wanted to 'complete the record" with some written material, which we expect to have by Monday. Were putting together our response to their arguments and we should be ready to issue it as soon as we get and digest their final submissions. Assuming we get the submissions by Monday. I expect to have our position to you by the middle of next week.** 
+
+So far we've not had any questions we couldn't answer with the materials at hand. but we'll reach out to you promptly if we need to
+
+Thanks, Mane
+
+From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marte.C.Villafanagiusdolgov]
+
+
+
+
+Hi Drew — Sorry to bother you. I know you had mentioned that you might have some questions for me after your meeting. I am going to be out most of the day tomorrow and then back on Friday and then I will be out for a week, so I wanted to get stuff to you before I leave. Do you need anything from me or the investigators?
+
+
+
+
+
+
+
+From: Gelber. Sent: Friday, March 21, 2008 3.20 PM To: Villafana, Ann Marie C. (USAFLS); Oosterbaan, Andrew Cc: Sloman, Jeff (USAFLS); Senior, Robert (USAFLS) Subject: RE: Follow up
+
+Thanks Marie, that is very helpful. Please don't take my question as a suggestion that the state drop the charges — I just needed this information to round out the discussion about the petite policy.
+
+From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie.C.Villafana@usdoj.gov] Sent: Fridaiiii, 2008 3:15 PM To: Gelber, Oosterbaan, Andrew Cc: Sloman, Jeff (USAFLS); Senior, Robert (USAFLS) Subject: RE: Follow up
+
+Eli - I lere is the info that I have. Jeopardy attaches at the start of the presentation of evidence at trial. so that should not be an issue.
+
+The bigger problem is the statute of limitations. A defendant can waive his right to challenge the statute under Florida law, but I don't think that Epstein will be willing to do so.
+
+At this point he also could demand a speedy trial. Once he has done so, if the trial is not held very quickly. he can move for "discharge." Once "discharged." Epstein cannot be prosecuted on the crime charged or any other crimes that could have been charged as a result of the same conduct or criminal episode. The State cannot avoid this bar by filing a "Nolle Prosequi" and then trying to re-file the same or different charges based on the same conduct or criminal episode.
+
+
+A. Marie l'ilicfrafia Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach. FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+From: Gelber, Sent: Friday, March 21, 2008 11:51 AM To: Vlllafana, Ann Marie C. (USAFLS); Oosterbaan, Andrew Cc: Sloman, Jeff (USAFLS); Senior, Robert (USAFLS) Subject: RE: Follow up
+
+One more question - do you know when double jeopardy attaches under Florida law? More specifically. if the state charges were dropped now, could they be dropped without prejudice?
+
+From: Villafana, Ann Marie C. (USAFLS) [mallto:Ann.Marie.C.VIllafana@usdo).gov) Sent: Thu 20, 2008 4:39 PM To: Gelber, Oosterbaan, Andrew
+
+Hi — The state indictment is related to two girls. One of those girls is included in the federal indic men e other is not. The state indictment charges solicitation of adult prostitution, it does not charge any child exploitation offense, despite the fact that, under Florida law, neither lack of knowledge of age nor affirmative misrepresentation of age by the victim is a defense.
+
+The victim from the state case who is referenced in the federal indictment told Epstein her true age and he engaged in full sexual intercourse with her a few days shy of her 18th birthday. For that birthday, he gave her a series of gifts, including lingerie. The other 18 girls named in the current indictment are not part of the state indictment.
+
+The state case currently has a trial date set for July. Before we got involved, the police were told that Epstein was going to plead to a misdemeanor and get no jail time. (That is one of the reasons why they asked the FBI to step in.) Since the federal investigation began, Epstein's counsel have continued the case repeatedly on the basis that they cannot resolve that case until the federal case is resolved. As part of the non-prosecution agreement that the Office put together with Epstein, the federal case was supposed to be resolved if Epstein agreed to three main terms: (I) he had to plead to a state offense for which sex offender registration was required, specifically, the procurement of minors to engage in prostitution; (2) he had to agree to an I8-month term of incarceration; and (3) he had to agree to pay restitution and damages to the victims. After the agreement was signed, he then tried to escape all three requirements.
+
+He objected to pleading to the state charge, claiming that the facts did not apply, and asked to plead to a non-registrable offense instead. When we responded that there were four other registrable offenses where the facts certainly rut, those were rejected because (I) they required registration and (2) the state sentencing guidelines for those offenses were too high.
+
+He tried to arrange to get out on work release, which would allow him to "work" anywhere he liked during the day and sleep in a halfway house, rather than a jail, at night. When he learned that sex offenders weren't allowed to be a part of the work release program, he started complaining about the jail time. He now wants to get a "suspended sentence" and/or home confinement, instead.
+
+He complained that he should be able to fully litigate the issues of liability and damages with regard to the third term of the agreement, despite his agreement directly to the contrary.
+
+With respect to the current status of the state case, other than the new trial date, all that I know is that Epstein is now subpoenaing victims for depositions who are not included in the state indictment. (Under Florida law, defense counsel are allowed to depose witnesses, including victims, prior to trial.) He seems to be trying to use that process to get information about the federal investigation. I do not know whether Epstein's misdemeanor deal is back on the table because the defense demanded that we have no contact with the State Attorney's Office, so I haven't spoken with the ASA in over 6 months.
+
+I wish I had more information to give you. If you would like me to reach out to either the local detective on the state case or the Assistant State Attorney, please let me know. Or, if you would like their contact info, I can forward that to you, too.
+
+Thank you. I will be back in the office tomorrow and you can call me there with any other questions.
+
+A. Marie Villafafia Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777
+
+From: Gelber, sent: Thursday, March 20, 2008 11:49 AM To: Oosterbaan, Andrew; Villafana, Ann Marie C. (USAFLS) Cc: Sloman, Jeff (USAFLS) Subject: RE: Follow up
+
+Marie.
+
+Two quick questions: Could you clarify whether any of the victims that are included in the state indictment would also be included in any federal indictment? If you know, what is the status of the state case?
+
+
+From: Oosterbaan, Andrew Sent: Wednesday, March 19, 2008 7:17 PM To: Villafana Ann Marie C. (USAFLS) Cc: Gelber, Sloman, Jeff (USAFLS) Subject: RE: Follow up
+
+I'm running out the door, but I wanted to get a response off. Sorry for not updating you sooner. The meeting went well enough. They wanted to 'complete the record" with some written material, which we expect to have by Monday. We're putting together our response to their arguments and we should be ready to issue it as soon as we get and digest their final submissions. Assuming we get the submissions by Monday, I expect to have our position to you by the middle of next week.
+
+So far we've not had any questions we couldn't answer with the materials at hand. but we'll reach out to you promptly if we need to.
+
+Thanks, Mane.
+
+From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie.C.Villafana@usdco.gov] Sent: Wednesday, March 19, 2008 6:30 PM To: Oosterbaan, Andrew Subject: Follow up
+
+Hi Drew — Sorry to bother you. I know you had mentioned that you might have some questions for me after your meeting. I am going to be out most of the day tomorrow and then back on Friday and then I will be out for a week, so I wanted to get stuff to you before I leave. Do you need anything from me or the investigators?
+
+
+
+
+
+
+
+From: Gelber, Sent: Friday, Iarch 2008 3:20 PM To: Villafana, Ann Marie C. (USAFLS); Oosterbaan, Andrew Cc: Sloman, Jeff (USAFLS); Senior, Robert (USAFLS) Subject: RE: Follow up
+
+Thanks Marie, that is very helpful. Please don't take my question as a suggestion that the state drop the charges - I just needed this information to round out the discussion about the petite policy.
+
+From: Villafana, Ann Marie C. (USAFLS) (mailW:Ann.Marie.C.Villafana@usdoLgov]
+
+Sent: Fridax,nati\_?), 2008 3:15 PM
+
+To: Gelber, MINES Oosterbaan, Andrew
+
+Cc: Sloman, Jeff (USAFLS); Senior, Robert (USAFLS)
+
+
+Ili Here is the info that I have. Jeopardy attaches at the start of the presentation of evidence at trial. so that should not be an issue.
+
+The bigger problem is the statute of limitations. A defendant can waive his right to challenge the statute under Florida law. but I don't think that Epstein will be willing to do so.
+
+At this point he also could demand a spee4' trial. Once he has done so, if the trial is not held very quickly. he can move for "discharge." Once -discharged," Epstein cannot be prosecuted on the crime charged or any other crimes that could have been charged as a result of the same conduct or criminal episode. The State cannot avoid this bar by filing a "Nolle Prosequi" and then trying to re-file the same or different charges based on the same conduct or criminal episode.
+
+
+A. Marie VillajeMa
+
+
+
+West Palm Beach. Fl. 33401
+
+
+
+
+Sent: Friday, March 2008 11:51 AM
+
+To: Villafana, Ann Marie C. (USAFLS); Oosterbaan, Andrew
+
+Cc: Sloman, Jeff (USAFLS); Senior, Robert (USAFLS)
+
+
+One more question - do you know when double jeopardy attaches under Florida law? More specifically, if the state charges were dropped now, could they be dropped without prejudice?
+
+From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie.C.Villafana@usdcl.gov]
+
+Sent: Thursiih 20, 2008 4:39 PM
+
+To: Gelber, Oosterbaan, Andrew
+
+Hi — The state indictment is related to two girls. One of those girls is included in the federal indic c . e other is not. The state indictment charges solicitation of adult prostitution, it does not charge any child exploitation offense, despite the fact that, under Florida law, neither lack of knowledge of age nor affirmative misrepresentation of age by the victim is a defense.
+
+The victim from the state case who is referenced in the federal indictment told Epstein her true age and he engaged in full sexual intercourse with her a few days shy of her 18th birthday. For that birthday, he gave her a series of gifts, including lingerie. The other 18 girls named in the current indictment are not part of the state indictment.
+
+The state case currently has a trial date set for July. Before we got involved, the police were told that Epstein was going to plead to a misdemeanor and get no jail time. (That is one of the reasons why they asked the FBI to step in.) Since the federal investigation began, Epstein's counsel have continued the case repeatedly on the basis that they cannot resolve that case until the federal case is resolved. As part of the non-prosecution agreement that the Office put together with Epstein, the federal case was supposed to be resolved if Epstein agreed to three main terms: (I) he had to plead to a state offense for which sex offender registration was required, specifically, the procurement of minors to engage in prostitution; (2) he had to agree to an I8-month term of incarceration; and (3) he had to agree to pay restitution and damages to the victims. After the agreement was signed, he then tried to escape all three requirements.
+
+He objected to pleading to the state charge, claiming that the facts did not apply, and asked to plead to a non-registrable offense instead. When we responded that there were four other registrable offenses where the facts certainly fit, those were rejected because (I ) they required registration and (2) the state sentencing guidelines for those offenses were too high.
+
+He tried to arrange to get out on work release, which would allow him to "work" anywhere he liked during the day and sleep in a halfway house, rather than a jail, at night. When he learned that sex offenders weren't allowed to be a pan of the work release program, he started complaining about the jail time. He now wants to get a "suspended sentence" and/or home confinement, instead.
+
+He complained that he should be able to fully litigate the issues of liability and damages with regard to the third term of the agreement, despite his agreement directly to the contrary.
+
+With respect to the current status of the state case, other than the new trial date, all that I know is that Epstein is now subpoenaing victims for depositions who are not included in the state indictment. (Under Florida law, defense counsel are allowed to depose witnesses, including victims, prior to trial.) He seems to be trying to use that process to get information about the federal investigation. I do not know whether Epstein's misdemeanor deal is back on the table because the defense demanded that we have no contact with the State Attorney's Office, so I haven't spoken with the ASA in over 6 months.
+
+I wish I had more information to give you. If you would like me to reach out to either the local detective on the state case or the Assistant State Attorney, please let me know. Or, if you would like their contact info, I can forward that to you, too.
+
+Thank you. I will be back in the office tomorrow and you can call me there with any other questions.
+
+A. Marie Villajafia
+
+
+561 209-1047 Fax 561 820-8777
+
+From: Gelber, Sent: Thursday, March 20, 2008 11:49 AM To: Oosterbaan, Andrew; Villafana, Ann Marie C. (USAFLS) Cc: Sloman, Jeff (USAFIS) Subject: RE: Follow up
+
+
+Two quick questions: Could you clarify whether any of the victims that are included in the state indictment would also be included in any federal indictment? If you know, what is the status of the state case?
+
+
+From: Oosterbaan, Andrew Sent: Wednesday, March 19, 2008 7:17 PM To: Villafana Ann Mane C. (USAFLS) Cc: Gelber, Sloman, Jeff (USAFLS) Subject: RE: Fo ow up
+
+I'm running out the door, but I wanted to get {sup}`a`response off. Sorry for not updating you sooner. The meeting went well enough. They wanted to 'complete the record\* with some written material, which we expect to have by Monday. We're putting together our response to their arguments and we should be ready to issue it as soon as we get and digest their final submissions. Assuming we get the submissions by Monday, I expect to have our position to you by the middle of next week.
+
+So far we've not had any questions we couldn't answer with the materials at hand, but we'll reach out to you promptly if we need to.
+
+
+From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie.C.Villafana@usdolgov] Sent: Wednesday, March 19, 2008 6:30 PM To: Oosterbaan, Andrew Subject: Follow up
+
+Hi Drew — Sorry to bother you. I know you had mentioned that you might have some questions for me after your meeting. I am going to be out most of the day tomorrow and then back on Friday and then I will be out for {sup}`a`week, so I wanted to get stuff to you before I leave. Do you need anything from me or the investigators?
+
+
+A. Marie Villafraa
+
+
+
+
+From: Villafana, Ann Marie C. (USAFLS) Sent: Friday. 2008 3:15 PM To: Gelber. ; Oosterbaan. Andrew Cc: Sloman, a (U AFLS); Senior, Robert (USAFLS) Subject: RE: Follow up
+
+Ili Alexandra — I 'ere is the info that I have. Jeopardy attaches at the start of the presentation of evidence at trial. so that should not be an issue.
+
+The bigger problem is the statute of limitations. A defendant can waive his right to challenge the statute under Florida law. but I don't think that Epstein will be willing to do so.
+
+At this point he also could demand a speedy trial. Once he has done so, if the trial is not held very quickly. he can move for "discharge." Once "discharged," Epstein cannot be prosecuted on the crime charged or any other crimes that could have been charged as a result of the same conduct or criminal episode. The State cannot avoid this bar by filing a "Nolle Prosequi" and then trying to re-file the same or different charges based on the same conduct or criminal episode.
+
+
+A. Marie l'illafaha Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach. FL 33401 Phone 56I 209- I 047 Fax 561 820-8777
+
+From: Gelber, Sent: Friday, March 21, 2008 11:51 AM To: Villafana, Ann Mane C. (USAFLS); Oosterbaan, Andrew Cc: Sloman, Jeff (USAFLS); Senior, Robert (USAFLS) Subject: RE: Follow up
+
+One more question - do you know when double jeopardy attaches under Florida law? More specifically, if the state charges were dropped now, could they be dropped without prejudice?
+
+From: Villafana, Ann Mane C. (USAFLS) [mallto:Ann.Made.C.VIllafana@usdoj.gov] Sent: Thu 20, 2008 4:39 PM To: Gelber, Oosterbaan, Andrew Cc: Sloman, Jeff (USAFLS); Senior, Robert (USAFLS) Subject: RE: Follow up
+
+Hi Alexandra — The state indictment is related to two girls. One of those girls is included in the federal indictment, the other is not. The state indictment charges solicitation of adult prostitution, it does not charge any child exploitation offense, despite the fact that, under Florida law, neither lack of knowledge of age nor affirmative misrepresentation of age by the victim is a defense.
+
+The victim from the state case who is referenced in the federal indictment told Epstein her true age and he engaged in full sexual intercourse with her a few days shy of her 18'" birthday. For that birthday, he gave her 1270
+
+a series of gifts, including lingerie. The other 18 girls named in the current indictment are not part of the state indictment.
+
+The state case currently has a trial date set for July. Before we got involved, the police were told that Epstein was going to plead to a misdemeanor and get no jail time. (That is one of the reasons why they asked the FBI to step in.) Since the federal investigation began, Epstein's counsel have continued the case repeatedly on the basis that they cannot resolve that case until the federal case is resolved. As part of the non-prosecution agreement that the Office put together with Epstein, the federal case was supposed to be resolved if Epstein agreed to three main terms: (I) he had to plead to a state offense for which sex offender registration was required, specifically, the procurement of minors to engage in prostitution; (2) he had to agree to an I8-month term of incarceration; and (3) he had to agree to pay restitution and damages to the victims. After the agreement was signed. he then tried to escape all three requirements.
+
+He objected to pleading to the state charge, claiming that the facts did not apply, and asked to plead to a non-registrable offense instead. When we responded that there were four other registrable offenses where the facts certainly fit, those were rejected because (I) they required registration and (2) the state sentencing guidelines for those offenses were too high.
+
+He tried to arrange to get out on work release, which would allow him to "work" anywhere he liked during the day and sleep in a halfway house, rather than a jail, at night. When he learned that sex offenders weren't allowed to be a part of the work release program, he started complaining about the jail time. He now wants to get a "suspended sentence" and/or home confinement, instead.
+
+He complained that he should be able to fully litigate the issues of liability and damages with regard to the third term of the agreement, despite his agreement directly to the contrary.
+
+With respect to the current status of the state case, other than the new trial date, all that I know is that Epstein is now subpoenaing victims for depositions who are not included in the state indictment. (Under Florida law, defense counsel are allowed to depose witnesses, including victims, prior to trial.) He seems to be trying to use that process to get information about the federal investigation. I do not know whether Epstein's misdemeanor deal is back on the table because the defense demanded that we have no contact with the State Attorney's Office, so I haven't spoken with the ASA in over 6 months.
+
+I wish I had more information to give you. If you would like me to reach out to either the local detective on the state case or the Assistant State Attorney, please let me know. Or, if you would like their contact info, I can forward that to you, too.
+
+Thank you. I will be back in the office tomorrow and you can call me there with any other questions.
+
+A. Marie Villafaila
+
+
+
+
+
+Sent: Thursday, 10, 2008 11:49 AM
+
+To: Oosterbaan, Andrew; Villafana, Ann Marie C. (USAFI.S)
+
+
+
+Two quick questions: Could you clarify whether any of the victims that are included in the state indictment would also be included in any federal indictment? If you know, what is the status of the state case?
+
+
+From: Oosterbaan, Andrew Sent: Wednesday, March 19, 2008 7:17 PM To: Villafana Ann Mane C. (USAFLS) Cc: Gelber, Sloman, Jeff (USAFLS) Subject: RE: Fo ow up
+
+I'm running out the door, but I wanted to get a response off. Sorry for not updating you sooner. The meeting went well enough. They wanted to "complete the record" with some written material, which we expect to have by Monday. We're putting together our response to their arguments and we should be ready to issue it as soon as we get and digest their final submissions. Assuming we get the submissions by Monday, I expect to have our position to you by the middle of next week.
+
+So far we've not had any questions we couldn't answer with the materials at hand, but we'll reach out to you promptly if we need to.
+
+
+From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie.C.Villafana@usdoj.gov) Sent: Wednesday, March 19, 2008 6:30 PM To: Oosterbaan, Andrew Subject: Follow up
+
+Hi Drew — Sorry to bother you. I know you had mentioned that you might have some questions for me after your meeting. I am going to be out most of the day tomorrow and then back on Friday and then I will be out for a week, so I wanted to get stuff to you before I leave. Do you need anything from me or the investigators?
+
+
+A. Marie VillaJaha
+
+
+
+
+
+
+From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, M 1 2008 1:58 PM To: Gelber, . 0osterbaan, Andrew Cc: Sloman, a FLS); Senior, Robert (USAFLS) Subject: RE: Follow up
+
+I will need to look into that, but I do know that there is a 3-year statute of limitations on the state prostitution charges. That limitations period has already run for several of our victims (we have victims going back to 2001). The girls who arc charged in the state indictment saw him in February and September 2005.
+
+I will get the other info to you asap. Give me about 30 minutes.
+
+A. Marie VH14E:act Assistant U.S. Attorney 500 S. Australian Ave. Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+From: Gelber, ap Sent: Friday, a , 2008 11:51 AM To: Villafana, Ann Marie C. (USAFLS); Oosterbaan, Andrew Cc: Sloman, Jeff (USAFLS); Senior, Robert (USAFLS) Subject: RE: Follow up
+
+One more question - do you know when double jeopardy attaches under Florida law? More specifically, if the state charges were dropped now, could they be dropped without prejudice?
+
+From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie.C.Villafana@usdoj.goy] Sent: Thu March 20, 2008 4:39 PM To: Gelber, oosterbaan, Andrew Cc: Sloman, LS); Senior, Robert (USAFLS) Subject: RE: Follow up
+
+Hi - The state indictment is related to two girls. One of those girls is included in the federal intim . e other is not. The state indictment charges solicitation of adult prostitution, it does not charge any child exploitation offense, despite the fact that, under Florida law, neither lack of knowledge of age nor affirmative misrepresentation of age by the victim is a defense.
+
+The victim from the state case who is referenced in the federal indictment told Epstein her true age and he engaged in full sexual intercourse with her a few days shy of her 18th birthday. For that birthday, he gave her a series of gifts, including lingerie. The other 18 girls named in the current indictment are not pan of the state indictment.
+
+The state case currently has a trial date set for July. Before we got involved, the police were told that Epstein was going to plead to a misdemeanor and get no jail time. (That is one of the reasons why they asked the FBI to step in.) Since the federal investigation began. Epstein's counsel have continued the case repeatedly on the basis that they cannot resolve that case until the federal case is resolved. As part of the non-prosecution agreement that the Office put together with Epstein, the federal case was supposed to be resolved if Epstein
+
+agreed to three main terms: (I) he had to plead to a state offense for which sex offender registration was required, specifically, the procurement of minors to engage in prostitution; (2) he had to agree to an 18-month term of incarceration; and (3) he had to agree to pay restitution and damages to the victims. After the agreement was signed, he then tried to escape all three requirements.
+
+He objected to pleading to the state charge, claiming that the facts did not apply, and asked to plead to a non-registrable offense instead. When we responded that there were four other registrable offenses where the facts certainly fit, those were rejected because (1 ) they required registration and (2) the state sentencing guidelines for those offenses were too high.
+
+He tried to arrange to get out on work release, which would allow him to "work" anywhere he liked during the day and sleep in a halfway house, rather than a jail, at night. When he learned that sex offenders weren't allowed to be a part of the work release program, he started complaining about the jail time. He now wants to get a "suspended sentence" and/or home confinement, instead.
+
+He complained that he should be able to fully litigate the issues of liability and damages with regard to the third term of the agreement, despite his agreement directly to the contrary.
+
+With respect to the current status of the state case, other than the new trial date, all that I know is that Epstein is now subpoenaing victims for depositions who are not included in the state indictment. (Under Florida law, defense counsel are allowed to depose witnesses, including victims, prior to trial.) He seems to be trying to use that process to get information about the federal investigation. I do not know whether Epstein's misdemeanor deal is back on the table because the defense demanded that we have no contact with the State Attorney's Office, so I haven't spoken with the ASA in over 6 months.
+
+I wish I had more information to give you. If you would like me to reach out to either the local detective on the state case or the Assistant State Attorney, please let me know. Or, if you would like their contact info, I can forward that to you, too.
+
+Thank you. I will be back in the office tomorrow and you can call me there with any other questions.
+
+A. Mark Vilkfalla Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777
+
+From: Gelber, Sent: Thursday, March 20, 2008 11:49 AM To: Oosterbaan, Andrew; Villafana, Ann Mane C. (USAFLS) Cc: Sloman, Jeff (USAFLS) Subject: RE: Follow up
+
+
+Two quick questions: Could you clarify whether any of the victims that are included in the state indictment would also be included in any federal indictment? If you know, what is the status of the state case?
+
+
+From: Oosterbaan, Andrew Sent: Wednesday, March 19, 2008 7:17 PM To: Villafana Ann Mane C. (USAFLS) Cc: Gelber, Sloman, Jeff (USAFLS) Subject: RE: Follow up
+
+I'm running out the door, but I wanted to get a response off. Sorry for not updating you sooner. The meeting went well enough. They wanted to 'complete the record' with some written material, which we expect to have by Monday. Were putting together our response to their arguments and we should be ready to issue it as soon as we get and digest their final submissions. Assuming we get the submissions by Monday, I expect to have our position to you by the middle of next week.
+
+So far we've not had any questions we couldn't answer with the materials at hand, but we'll reach out to you promptly if we need to.
+
+
+From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie.C.Villafana@usdoj.gov] Sent: Wednesday, March 19, 2008 6:30 PM To: Oosterbaan, Andrew Subject: Follow up
+
+Hi Drew — Sorry• to bother you. I knoW you had mentioned that you might have some questions for me after your meeting. I am going to be out most of the day tomorrow and then back on Friday and then I will be out for a week, so I wanted to get stuff to you before I leave. Do you need anything from me or the investigators?
+
+
+A. Marie VillafaAa
+
+
+
+West Palm Beach, Fl. 33401
+
+
+
+**From:** Gelber, [REDACTED]  
+**Sent:** Thursday, March 20, 2008 7:45 PM  
+
+Thanks Marie, that is very helpful.
+
+---
+
+**From:** Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie.C.Villafana@usdoj.gov]  
+
+Hi [REDACTED] – The state indictment is related to two girls. One of those girls is included in the federal indictment, the other is not. The state indictment charges solicitation of adult prostitution, it does not charge any child exploitation offense, despite the fact that, under Florida law, neither lack of knowledge of age nor affirmative misrepresentation of age by the victim is a defense.
+
+The victim from the state case who is referenced in the federal indictment told Epstein her true age and he engaged in full sexual intercourse with her a few days shy of her 18{sup}`th` birthday. For that birthday, he gave her a series of gifts, including lingerie. The other 18 girls named in the current indictment are not part of the state indictment.
+
+The state case currently has a trial date set for July. Before we got involved, the police were told that Epstein was going to plead to a misdemeanor and get no jail time. (That is one of the reasons why they asked the FBI to step in.) Since the federal investigation began, Epstein's counsel have continued the case repeatedly on the basis that they cannot resolve that case until the federal case is resolved. As part of the non-prosecution agreement that the Office put together with Epstein, the federal case was supposed to be resolved if Epstein agreed to three main terms: (1) he had to plead to a state offense for which sex offender registration was required, specifically, the procurement of minors to engage in prostitution; (2) he had to agree to an 18-month term of incarceration; and (3) he had to agree to pay restitution and damages to the victims. After the agreement was signed, he then tried to escape all three requirements.
+
+He objected to pleading to the state charge, claiming that the facts did not apply, and asked to plead to a non-registrable offense instead. When we responded that there were four other registrable offenses where the facts certainly fit, those were rejected because (1) they required registration and (2) the state sentencing guidelines for those offenses were too high.
+
+He tried to arrange to get out on work release, which would allow him to "work" anywhere he liked during the day and sleep in a halfway house, rather than a jail, at night. When he learned that sex offenders weren't allowed to be a part of the work release program, he started complaining about the jail time. He now wants to get a "suspended sentence" and/or home confinement, instead.
+
+He complained that he should be able to fully litigate the issues of liability and damages with regard to the third term of the agreement, despite his agreement directly to the contrary.
+
+With respect to the current status of the state case, other than the new trial date, all that I know is that Epstein is now subpoenaing victims for depositions who are not included in the state indictment. (Under Florida law, defense counsel are allowed to depose witnesses, including victims, prior to trial.) Ile seems to be trying to use that process to get information about the federal investigation. I do not know whether Epstein's misdemeanor deal is back on the table because the defense demanded that we have no contact with the State Attorney's Office. so I haven't spoken with the ASA in over 6 months.
+
+I wish I had more information to give you. If you would like me to reach out to either the local detective on the state case or the Assistant State Attorney, please let me know. Or, if you would like their contact info, I can forward that to you, too.
+
+Thank you. I will be back in the office tomorrow and you can call me there with any other questions.
+
+A. Mark Villafatla
+
+
+
+
+From: Gelber, =3
+
+Sent: Thursday, March 20, 2008 11:49 AM
+
+To: Oosterbaan, Andrew; Villafana, Ann Mane C. (USAFLS)
+
+
+
+
+Two quick questions: Could you clarify whether any of the victims that are included in the state indictment would also be included in any federal indictment? If you know, what is the status of the state case?
+
+
+
+
+
+
+
+I'm running out the door, but I wanted to get a response off. Sorry for not updating you sooner. The meeting went well enough. They wanted to 'complete the record\* with some written material, which we expect to have by Monday. We're putting together our response to their arguments and we should be ready to issue it as soon as we get and digest their final submissions. Assuming we get the submissions by Monday. I expect to have our position to you by the middle of next week.
+
+So far we've not had any questions we couldn't answer with the materials at hand, but we'll reach out to you promptly if we need to
+
+
+From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie.C.Villafana@usdoj.gov]
+
+
+
+
+Hi Drew — Sorry to bother you. I know you had mentioned that you might have some questions for me after your meeting. I am going to be out most of the day tomorrow and then back on Friday and then I will be out for a week, so I wanted to get stuff to you before I leave. Do you need anything from me or the investigators?
+
+
+
+
+
+
+
+From: Gelber, Sent: Thursday, arc 2008 7:45 PM To: Villafana, Ann Marie C. (USAFLS): Oosterbaan, Andrew Cc: &omen, Jeff (USAFLS); Senior, Robert (USAFLS) Subject: RE: Follow up
+
+Thanks Marc, that is very helpful.
+
+From: Vlllafana, Ann Marie C. (USAFLS) [mailto:Ann.Marle.C.VIllafana@usdoj.gov]
+
+Sent: Thur 20, 2008 4:39 PM
+
+To: Gelber, Oosterbaan, Andrew
+
+Cc: Sloman, Jeff (USAFLS); Senior, Robert (USAF' S)
+
+
+III — The state indictment is related to two girls. One of those girls is included in the federal ind . e other is not. The state indictment charges solicitation of adult prostitution, it does not charge any child exploitation offense, despite the fact that, under Florida law, neither lack of knowledge of age nor affirmative misrepresentation of age by the victim is a defense.
+
+The victim from the state case who is referenced in the federal indictment told Epstein her true age and he engaged in full sexual intercourse with her a few days shy of her lit birthday. For that birthday, he gave her a series of gifts, including lingerie. The other 18 girls named in the current indictment are not part of the state indictment.
+
+The state case currently has a trial date set for July. Before we got involved, the police were told that Epstein was going to plead to a misdemeanor and get no jail time. (That is one of the reasons why they asked the FBI to step in.) Since the federal investigation began, Epstein's counsel have continued the case repeatedly on the basis that they cannot resolve that case until the federal case is resolved. As part of the non-prosecution agreement that the Office put together with Epstein, the federal case was supposed to be resolved if Epstein agreed to three main terms: (I) he had to plead to a state offense for which sex offender registration was required, specifically, the procurement of minors to engage in prostitution; (2) he had to agree to an I8-month term of incarceration; and (3) he had to agree to pay restitution and damages to the victims. After the agreement was signed, he then tried to escape all three requirements.
+
+He objected to pleading to the state charge, claiming that the facts did not apply, and asked to plead to a non-registrable offense instead. When we responded that there were four other registrable offenses where the facts certainly fit, those were rejected because (I) they required registration and (2) the state sentencing guidelines for those offenses were too high.
+
+He tried to arrange to get out on work release, which would allow him to "work" anywhere he liked during the day and sleep in a halfway house, rather than a jail, at night. When he learned that sex offenders weren't allowed to be a part of the work release program, he started complaining about the jail time. He now wants to get a "suspended sentence" and/or home confinement, instead.
+
+He complained that he should be able to fully litigate the issues of liability and damages with regard to the third term of the agreement. despite his agreement directly to the contrary.
+
+With respect to the current status of the state case, other than the new trial date, all that I know is that Epstein is now subpoenaing victims for depositions who are not included in the state indictment. (Under Florida law, defense counsel are allowed to depose witnesses, including victims, prior to trial.) He seems to be trying to use that process to get information about the federal investigation. I do not know whether Epstein's misdemeanor deal is back on the table because the defense demanded that we have no contact with the State Attorney's Office, so I haven't spoken with the ASA in over 6 months.
+
+I wish I had more information to give you. If you would like me to reach out to either the local detective on the state case or the Assistant State Attorney, please let me know. Or, if you would like their contact info, I can forward that to you, too.
+
+Thank you. I will be back in the office tomorrow and you can call me there with any other questions.
+
+A. Mark Vfflajafia Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777
+
+From: Gelber, Sent: Thursday, March 20, 2008 11:49 AM To: Oosterbaan, Andrew; Villafana, Ann Marie C. (USAFLS) Cc: Sloman, Jeff (USAFLS) Subject: RE: Follow up
+
+
+Two quick questions: Could you clarify whether any of the victims that are included in the state indictment would also be included in any federal indictment? If you know, what is the status of the state case?
+
+
+From: Oosterbaan, Andrew Sent: Wednesday, March 19, 2008 7:17 PM To: Villafana Ann Marie C. (USAFLS) Cc: Gelber, Sloman, Jeff (USAFLS) Subject: RE: Follow up
+
+I'm running out the door, but I wanted to get a response off. Sorry for not updating you sooner. The meeting went well enough. They wanted to `complete the record' with some written material, which we expect to have by Monday. Were putting together our response to their arguments and we should be ready to issue it as soon as we get and digest their final submissions. Assuming we get the submissions by Monday. I expect to have our position to you by the middle of next week.
+
+So far we've not had any questions we couldn't answer with the materials at hand, but we'll reach out to you promptly if we need to.
+
+
+From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie.C.Villafana@usdoj.gov] Sent: Wednesday, March 19, 2008 6:30 PM
+
+
+
+Hi Drew — Sorry to bother you. I know you had mentioned that you might have some questions for me after your meeting. I am going to be out most of the day tomorrow and then back on Friday and then I will be out for a week, so I wanted to get stuff to you before I leave. Do you need anything from me or the investigators?
+
+
+A. Marie Villafaita
+
+
+
+West Palm Beach. FL 33401
+
+
+**From:** Villafana, Ann Marie C. (USAFLS)  
+
+Hi [REDACTED] – The state indictment is related to two girls. One of those girls is included in the federal indictment, the other is not. The state indictment charges solicitation of adult prostitution, it does not charge any child exploitation offense, despite the fact that, under Florida law, neither lack of knowledge of age nor affirmative misrepresentation of age by the victim is a defense.
+
+The victim from the state case who is referenced in the federal indictment told Epstein her true age and he engaged in full sexual intercourse with her a few days shy of her 18{sup}`th` birthday. For that birthday, he gave her a series of gifts, including lingerie. The other 18 girls named in the current indictment are not part of the state indictment.
+
+The state case currently has a trial date set for July. Before we got involved, the police were told that Epstein was going to plead to a misdemeanor and get no jail time. (That is one of the reasons why they asked the FBI to step in.) Since the federal investigation began, Epstein's counsel have continued the case repeatedly on the basis that they cannot resolve that case until the federal case is resolved. As part of the non-prosecution agreement that the Office put together with Epstein, the federal case was supposed to be resolved if Epstein agreed to three main terms: (1) he had to plead to a state offense for which sex offender registration was required, specifically, the procurement of minors to engage in prostitution; (2) he had to agree to an 18-month term of incarceration; and (3) he had to agree to pay restitution and damages to the victims. After the agreement was signed, he then tried to escape all three requirements.
+
+He objected to pleading to the state charge, claiming that the facts did not apply, and asked to plead to a non-registrable offense instead. When we responded that there were four other registrable offenses where the facts certainly fit, those were rejected because (1) they required registration and (2) the state sentencing guidelines for those offenses were too high.
+
+He tried to arrange to get out on work release, which would allow him to "work" anywhere he liked during the day and sleep in a halfway house, rather than a jail, at night. When he learned that sex offenders weren't allowed to be a part of the work release program, he started complaining about the jail time. He now wants to get a "suspended sentence" and/or home confinement, instead.
+
+He complained that he should be able to fully litigate the issues of liability and damages with regard to the third term of the agreement, despite his agreement directly to the contrary.
+
+With respect to the current status of the state case, other than the new trial date, all that I know is that Epstein is now subpoenaing victims for depositions who are not included in the state indictment. (Under Florida law, defense counsel are allowed to depose witnesses, including victims, prior to trial.) He seems to be trying to use that process to get information about the federal investigation. I do not know whether Epstein's misdemeanor deal is back on the table because the defense demanded that we have no contact with the State Attorney's Office, so I haven't spoken with the ASA in over 6 months.
+
+I wish I had more information to give you. If you would like me to reach out to either the local detective on the state case or the Assistant State Attorney, please let me know. Or, if you would like their contact info, I can forward that to you, too.
+
+Thank you. I will be back in the office tomorrow and you can call me there with any other questions.
+
+A. Mark 'Whir:fief
+
+
+
+
+
+Sent: Thursday, Mardi 20, 2008 11:49 AM
+
+To: Oosterbaan, Andrew; Villafana, Ann Marie C. (USAFLS)
+
+
+
+
+Two quick questions: Could you clarify whether any of the victims that are included in the state indictment would also be included in any federal indictment? If you know, what is the status of the state case?
+
+
+
+
+
+
+
+I'm running out the door, but I wanted to get a response off. Sorry for not updating you sooner. The meeting went well enough. They wanted to 'complete the record\* with some written material, which we expect to have by Monday. Were putting together our response to their arguments and we should be ready to issue it as soon as we get and digest their final submissions. Assuming we get the submissions by Monday, I expect to have our position to you by the middle of next week.
+
+So far we've not had any questions we couldn't answer with the materials at hand. but we'll reach out to you promptly if we need to.
+
+
+From: Villafana, Ann Marie C. (USAFLS) [mallto:Ann.Marle.C.Villafana@usdoj.gov]
+
+
+
+
+Hi Drew — Sony to bother you. I know you had mentioned that you might have some questions for me after your meeting. I am going to be out most of the day tomorrow and then back on Friday and then I will be out for a week, so I wanted to get stuff to you before ! leave. Do you need anything from me or the investigators?
+
+
+
+
+
+West Palm Beach. FL 33401
+
+
+
+From: Villafana. Ann Marie C. (USAFLS) Sent: Thursday. March 20, 2008 4:18 PM To: Oosterbaan, Andrew Subject: RE: Follow up
+
+Thank you. Drew.
+
+A. Marie Villafana Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777
+
+From: Oosterbaan, Andrew Sent: Wednesday, March 19, 2008 7:17 PM To: Villafana Ann Marie C. (USAFLS) Cc: Gelber, MEM Sloman, Jeff (USAFLS) Subject: RE: Follow up
+
+I'm running out the door, but I wanted to get a response off. Sorry for not updating you sooner. The meeting went well enough. They wanted to "complete the record" with some written material, which we expect to have by Monday. Were putting together our response to their arguments and we should be ready to issue it as soon as we get and digest their final submissions. Assuming we get the submissions by Monday, I expect to have our position to you by the middle of next week.
+
+So far we've not had any questions we couldn't answer with the materials at hand, but we'll reach out to you promptly if we need to.
+
+
+From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie.C.Villafana@usdoj.gov) Sent: Wednesday, March 19, 2008 6:30 PM To: Oosterbaan, Andrew Subject: Follow up
+
+Hi Drew — Sorry to bother you. I know you had mentioned that you might have some questions for me after your meeting. I am going to be out most of the day tomorrow and then back on Friday and then I will be out for a week, so I wanted to get stuff to you before I leave. Do you need anything from me or the investigators?
+
+
+
+
+
+
+From: Villafana. Ann Marie C. (USAFLS) Sent: Thursday, March 20, 2008 4 18 PM To: Kuyrkendall, E N . Richards. Jason R Senior. Robed (USAFLS). Kirkpatrick. Lynn (USAFLS) Subject: FW: Follow up
+
+FYI — Bob, you probably already received this from JetT, but just in case. And Jason and Nesbitt, here is the latest.
+
+If you want to discuss further, I will be back in tomorrow.
+
+A. Marie Malefic
+
+
+
+
+
+
+
+
+
+I'm running out the door, but I wanted to get a response off. Sorry for not updating you sooner. The meeting went well enough. They wanted to "complete the record' with some written material, which we expect to have by Monday. We're putting together our response to their arguments and we should be ready to issue it as soon as we get and digest their final submissions. Assuming we get the submissions by Monday. I expect to have our position to you by the middle of next week.
+
+So far we've not had any questions we couldn't answer with the materials at hand, but we'll reach out to you promptly if we need to.
+
+
+From: Villafana, Ann Marie C. (USAFLS) imailto:Ann.Marie.C.Villafana@usdoj.gov]
+
+
+
+
+Hi Drew — Sony to bother you. I know you had mentioned that you might have some questions for me after your meeting. I am going to be out most of the day tomorrow and then back on Friday and then I will be out for a week, so I wanted to get stuff to you before I leave. Do you need anything from me or the investigators?
+
+
+A. Marie Villafafta
+
+
+
+
+
+
+From: Gelber, Sent: Thursday, March 20, 2008 11:49 AM To: Oosterbaan, Andrew; Villafana, Ann Marie C. (USAFLS) Cc: Sloman, Jeff (USAFLS) Subject: RE: Follow up
+
+
+Two quick questions: Could you clarify whether any of the victims that arc included in the state indictment would also be included in any federal indictment? If you know, what is the status of the state case?
+
+
+From: Oosterbaan, Andrew Sent: Wednesday, March 19, 2008 7:17 PM To: Villafana Ann Marie C. (USAFLS) Cc: Gelber, II= Sloman, Jeff (USAFLS) Subject: RE: Follow up
+
+I'm running out the door, but I wanted to get a response off. Sorry for not updating you sooner. The meeting went well enough. They wanted to \*complete the record' with some written material, which we expect to have by Monday. We're putting together our response to their arguments and we should be ready to issue it as soon as we get and digest their final submissions. Assuming we get the submissions by Monday, I expect to have our position to you by the middle of next week.
+
+So far we've not had any questions we couldn't answer with the materials at hand. but we'll reach out to you promptly if we need to.
+
+
+From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marle.CVIllafana@usdoj.gov) Sent: Wednesday, March 19, 2008 6:30 PM To: Oosterbaan, Andrew Subject: Follow up
+
+Hi Drew — Sony to bother you. I know you had mentioned that you might have some questions for me after your meeting. I am going to be out most of the day tomorrow and then back on Friday and then I will be out for a week, so I wanted to get stuff to you before I leave. Do you need anything from me or the investigators?
+
+
+
+
+
+
+
+From: Gelber, Sent: Thursday, •20, 2008 11:49 AM To: Oosterbaan, Andrew; Villafana, Ann Marie C. (USAFLS) Cc: Sloman, Jeff (USAFLS) Subject: RE: Follow up
+
+
+Two quick questions: Could you clarify whether any of the victims that are included in the state indictment would also be included in any federal indictment? If you know, what is the status of the state case?
+
+
+From: Oosterbaan, Andrew Sent: Wednesday, March 19, 2008 7:17 PM To: Villafana Ann Mane C. (USAFLS) Cc: Gelber, Sloman, Jeff (USAFLS) Subject: RE: Follow up
+
+I'm running out the door, but I wanted to get a response off. Sorry for not updating you sooner. The meeting went well enough. They wanted to 'complete the record' with some written material, which we expect to have by Monday. We're putting together our response to their arguments and we should be ready to issue it as soon as we get and digest their final submissions. Assuming we get the submissions by Monday, I expect to have our position to you by the middle of next week.
+
+So far we've not had any questions we couldn't answer with the materials at hand but we'll reach out to you promptly if we need to.
+
+
+From: VIllafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie.C.Villafana@usdoj.gov] Sent: Wednesday, March 19, 2008 6:30 PM To: Oosterbaan, Andrew Subject Follow up
+
+Hi Drew — Sorry to bother you. I know you had mentioned that you might have some questions for me after your meeting. I am going to be out most of the day tomorrow and then back on Friday and then I will be out for a week, so I wanted to get stuff to you before I leave. Do you need anything from me or the investigators?
+
+
+
+
+
+
+From: Oosterbaan. Andrew Sent: Wednesday. March 19, 2008 7:17 PM To: Villafana Ann Marie C. (USAFLS) Cc: Gelber. ; Sloman, Jeff (USAFLS) Subject: RE: Follow up
+
+I'm running out the door, but I wanted to get a response off. Sorry for not updating you sooner. The meeting went well enough. They wanted to "complete the record' with some written material, which we expect to have by Monday We're putting together our response to their arguments and we should be ready to issue it as soon as we get and digest their final submissions. Assuming we get the submissions by Monday, I expect to have our position to you by the middle of next week
+
+So far we've not had any questions we couldn't answer with the materials at hand, but we'll reach out to you promptly if we need to.
+
+
+From: Villafana, Ann Marie C. (USAFLS) (mailto:Ann.Marie.C.Villafana@usdoj.gov] Sent: Wednesday, March 19, 2008 6:30 PM To: Oosterbaan, Andrew Subject: Follow up
+
+Hi Drew - Sorry to bother you. I know you had mentioned that you might have some questions for me after your meeting. I am going to be out most of the day tomorrow and then back on Friday and then I will be out for a week, so I wanted to get stuff to you before I leave. Do you need anything from me or the investigators?
+
+
+A. Marie Villafitha
+
+
+
+
+Phone 561 209- I 047
+
+From: Oosterbaan, Andrew Sent: Wednesday. March 19, 2008 7:17 PM To: Villafana Ann Marie C. (USAFLS) Cc: Gelber. Sloman, Jeff (USAFLS) Subject: RE Follow up
+
+I'm running out the door, but I wanted to get a response off Sorry for not updating you sooner. The meeting went well enough. They wanted to 'complete the record' with some written material, which we expect to have by Monday. We're putting together our response to their arguments and we should be ready to issue it as soon as we get and digest their final submissions. Assuming we get the submissions by Monday, I expect to have our position to you by the middle of next week.
+
+So far we've not had any questions we couldn't answer with the materials at hand, but we'll reach out to you promptly if we need to.
+
+Thanks. Marie
+
+From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie.C.Villafana@usdoj.gov]
+
+
+
+
+Hi Drew — Sorry to bother you. I know you had mentioned that you might have some questions for me after your meeting. I am going to be out most of the day tomorrow and then back on Friday and then I will be out for a week, so I wanted to get stuff to you before I leave. Do you need anything from me or the investigators?
+
+
+.4. Marie Villajaila
+
+
+
+
+
+From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday. March 19, 2008 6:30 PM To: Oosterbaan, Andrew Subject: Follow up
+
+Hi Drew — Sorry to bother you. I know you had mentioned that you might have some questions for me after your meeting. I am going to be out most of the day tomorrow and then back on Friday and then I will be out for a week, so I wanted to get stuff to you before I leave. Do you need anything from me or the investigators?
+
+
+A. Marie Villafafia Assistant U.S. Attorney 500 S. Australian Ave. Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777

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marker2-fixhub/ds9/EFTA00189400/EFTA00189400.md

@@ -0,0 +1,108 @@
+From:
+
+Sent:
+
+To: Cc:
+
+Subject:
+
+
+143 PM
+
+ps ein
+
+Jay and Ken Starr called Alex yesterday. Alex did not return the call. Instead, at my direction, Marie called them back. They demurred and said they wanted to talk to Alex. Marie emailed them and said "the USA reiterated that he would like me to handle all communications and inquiries related to the Epstein matter, so he does not intend to return your call unless I advise him that neither I nor my Chief in WPB is able to answer your question."
+
+Since then we have heard nothing. Without impinging on your deliberations, do you have a sense as to what they are up to? Thanks,
+
+
+From: Sent: Friday, April 04. 2008 1:44 PM To: afiekewersiferes(4641.1.6 Subject: FW: Epstein
+
+FYI
+
+Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+
+From: rienugm Sent: Friday, April 04, 2008 1:43 PM To: Leg baan, A" icw Cc: Subject: Epstein
+
+
+lay and Ken Starr called Alex yesterday. Alex did not return the call. Instead, at my direction, Marie called them back. They demurred and said they wanted to talk to Alex. Marie emailed them and said "the USA reiterated that he would like me to handle all communications and inquiries related to the Epstein matter, so he does not intend to return your call unless I advise him that neither I nor my Chief in WPB is able to answer your question."
+
+Since then we have heard nothing. Without impinging on your deliberations, do you have a sense as to what they are up to? Thanks,
+
+
+From: Sent: To: Cc: Subject: RE: Epstein
+
+I have no idea.
+
+Our draft letter is with the DAAG, who participated in the meetings with Epstein's lawyers. She's had it for a few days, so I expect to have her approval very soon.
+
+
+From: Sloman, Jeff (USAFLS) [mailto:Jeff.Sloman@usdoj.gov]
+
+Sent: Friday, April 04, 2008 1:43 PM
+
+To: Nigestambs"Sols
+
+Cc: Subject: Epstein
+
+
+Jay and Ken Starr called Alex yesterday. Alex did not return the call. Instead, at my direction, Marie called them back. They demurred and said they wanted to talk to Alex. Marie emailed them and said "the USA reiterated that he would like me to handle all communications and inquiries related to the Epstein matter, so he does not intend to return your call unless I advise him that neither I nor my Chief in WPB is able to answer your question."
+
+Since then we have heard nothing. Without impinging on your deliberations, do you have a sense as to what they are up to? Thanks,
+
+
+From: Sent: To: Subject: ' " " I"" -1"1 Friday. April 04, 2008 2.18 PM tle;rie.e.r. linen., (I MAC! 9 FW: Epstein
+
+FYI
+
+Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+
+From: Sent: Frida A ril 04 2008 2:16 PM To: Cc: Sub
+
+I have no idea.
+
+Our draft letter is with the DAAG, who participated in the meetings with Epstein's lawyers. She's had it for a few days, so I expect to have her approval very soon.
+
+
+From: clnman loff (HCAPIcl imailtn.lpff ClrimanticAn4 Sent: Friday, April 04, 2008 1:43 PM To: Oalebouppomlasima Cc: Subject: Epstein gnu]
+
+
+Jay and Ken Starr called Alex yesterday. Alex did not return the call. Instead, at my direction, Marie called them back. They demurred and said they wanted to talk to Alex. Marie emailed them and said "the USA reiterated that he would like me to handle all communications and inquiries related to the Epstein matter, so he does not intend to return your call unless I advise him that neither I nor my Chief in WPB is able to answer your question."
+
+Since then we have heard nothing. Without impinging on your deliberations, do you have a sense as to what they are up to? Thanks,
+
+From: Sent: To: Subject: Monday. April 07, 2008 3:32 PM ps can
+
+Hi Bob — is this okay to send to Drew?
+
+Hi Drew — FYI — There was an article in Sunday's Palm Beach Post about Epstein's state case. Epstein's attorney is quoted as saying that Epstein is being "treated more harshly because he is wealthy."
+
+I am leaving on a three-week vacation in around 5 weeks, and I wanted to have the case at least past the discovery phase by the time I left, so I would really like to present the indictment to the grand jury a week from tomorrow (since Jeff promised them a week from the time of your decision). Has the DAAG made a decision? Any chance it will happen today?
+
+Thank you, and sorry to be a pest.
+
+Assistant U.S. pttorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+From:
+
+Sent: Monday. April 07, 200810:36 AM
+
+To: Acosta, Alex (USAFLS);
+
+Subject: Epstein
+
+FYI — There was an article in Sunday's Palm Beach Post about Epstein's state case. Epstein's attorney is quoted as saying that Epstein is being "treated more harshly because he is wealthy."
+
+Any word from DC? Can we push for an answer today so I can present on the 15th? (one week from tomorrow)
+
+Assistant U.S. Attorney
+
+500 S. Australian Ave, Suite 400
+
+West Palm Beach, FL 33401
+
+Phone 56I 209-1047
+
+Fax 561 820-8777

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marker2-fixhub/ds9/EFTA00189406/EFTA00189406.md

@@ -0,0 +1,158 @@
+From: Villafana, Ann Marie C. (USAFLS) Sent: Friday. May 02, 200811:41 AM To: Sloman, Jeff (USAFLS) Subject: RE: One other thing
+
+Thanks. Jeff Except for the fact that it is now, sigh. May. the letter looks perfect.
+
+Is Alice's departure going to slow things down even more. do you think? I spent the past few days organizing the file and saw that Lilly's first request for a meeting (which I denied. of course). was in November 2006. and Andy's first meeting with them was in February 2007. I wonder how much JE has paid for his extra 15 months of freedom.
+
+.4. A/ark I7114idia Assistant U.S. Attorney 561 209-1047
+
+From: Sloman, Jeff (USAFLS) Sent: Friday, May 02, 2008 11:02 AM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: One other thing
+
+Thanks. Here's the revised final. Let me know if you spot anything else. 8TW, I preserved your grammatical honor.« File: EpsteinNoticeLtr0408.wpd »
+
+From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, April 30, 2008 11:24 AM To: Sloman, Jeff (USAFLS) Subject: RE: One other thing
+
+Hi Jeff — I like it. especially all of the quotes of their language. I just changed a few spacing issues, but I wanted to leave the substantive edits up to you.
+
+- I. In your listing of attorneys, I didn't know if you wanted to add Mr. Starr's name up there (I know it is mentioned later), as well as adding "former U.S. Attorney Guy Lewis, and noted criminal defense attorneys Roy Black and Marty Weinberg (I need to check on his name)"
+- 2. Under "The Negotiation Phase," you say that one of the options Epstein was presented with was a Rule I I plea to a federal charge, but that isn't correct. At that time, Alex was unwilling to do a Rule I I plea, so we were left with trying to find federal charges that he could plead to that resulted in the agreed imprisonment term. Maybe write: "In order to achieve this result, the parties considered two alternatives, a plea to federal charges that limited Epstein's sentencing exposure, or, as suggested by you, a plea to state charges encompassing Epstein's conduct." [Much later. Alex changed his mind, but by that time, Epstein's crew was on the "he didn't do anything wrong" bandwagon.)
+- 3. Under "Delay," you may want to quote the language of the agreement. which clearly DID NOT contemplate a staggered plea and sentencing. [The true reason why they didn't plead on the November date was because the judge would have remanded him on that date, rather than let him stay out until January. Quite simply, this was not our problem, we have always maintained that the state court judge
+
+should do her own thing. so it wasn't a legitimate reason for further delay, but it essentially would have eliminated Epstein's plan to never spend a day in jail.)
+
+- 4. In your conclusion, you may want to make one specific term explicit: "Therefore, as I proposed in my email to you on February 25, 2008, you shall have until , to comply with all of the terms and conditions of the Agreement, including plea, sentence, and incarceration, as modified by the USA's December 19'h letter to Ms. Sanchez.-
+- 5. Not substantive, but I feel the need to defend my "grammar honor" so I know that you, Andy, and Alex (as well as defense counsel) all think that I have made up the word "registrable," but, according to The Oxford American Dictionary, the adjective form of "register" is "registrable."
+
+
+A. Marie Villafafia
+
+
+
+
+From: Sloman, Jeff (USAFLS)
+
+Sent: Tuesday, April 29, 2008 5:19 PM
+
+To: Villafana, Ann Marie C. (USAFLS)
+
+Subject: RE: One other thing
+
+<< File: EpsteinNoticeLtr0408.wpd »
+
+From: Villafana, Ann Marie C. (USAFLS)
+
+Sent: Tuesday, April 29, 2008 12:52 PM
+
+To: Senior, Robert (USAFLS); Sloman, Jeff (USAFLS)
+
+Cc: Atkinson, Karen (USAFLS)
+
+Subject: One other thing
+
+One of our New York girls was contacted by someone claiming to represent Epstein. None of us (here in Florida) have ever disclosed to Epstein's group that we were even LOOKING at New York, so I am concerned that someone in DC may have leaked it, possibly involuntarily.
+
+Jeff— I haven't told the FBI about your one-week to take the deal thing. because they will not be happy. Can I take a look at your letter before you send it?
+
+
+A. Marie Villafafia
+
+
+500 S. Australian Ave, Suite 400
+
+West Palm Beach, FL 33401
+
+Phone 561 209-1047
+
+
+**From:** Sloman, Jeff (USAFLS)  
+**Sent:** Friday, May 02, 2008 11:02 AM  
+
+Thanks. Here's the revised final. Let me know if you spot anything else. BTW, I preserved your grammatical honor.
+
+![](_page_2_Picture_17.jpeg)
+
+EpsteinNoticeLtr  
+0408.wpd
+
+---
+
+**From:** Villafana, Ann Marie C. (USAFLS)  
+
+Hi Jeff – I like it, especially all of the quotes of their language. I just changed a few spacing issues, but I wanted to leave the substantive edits up to you.
+
+1. 1. In your listing of attorneys, I didn't know if you wanted to add Mr. Starr's name up there (I know it is mentioned later), as well as adding "former U.S. Attorney Guy Lewis, and noted criminal defense attorneys Roy Black and Marty Weinberg (I need to check on his name)"
+2. 2. Under "The Negotiation Phase," you say that one of the options Epstein was presented with was a Rule 11 plea to a federal charge, but that isn't correct. At that time, Alex was unwilling to do a Rule 11 plea, so we were left with trying to find federal charges that he could plead to that resulted in the agreed imprisonment term. Maybe write: "In order to achieve this result, the parties considered two alternatives, a plea to federal charges that limited Epstein's sentencing exposure, or, as suggested by you, a plea to state charges encompassing Epstein's conduct." [Much later, Alex changed his mind, but by that time, Epstein's crew was on the "he didn't do anything wrong" bandwagon.]
+3. 3. Under "Delay," you may want to quote the language of the agreement, which clearly DID NOT contemplate a staggered plea and sentencing. [The true reason why they didn't plead on the November date was because the judge would have remanded him on that date, rather than let him stay out until January. Quite simply, this was not our problem, we have always maintained that the state court judge should do her own thing, so it wasn't a legitimate reason for further delay, but it essentially would have eliminated Epstein's plan to never spend a day in jail.]
+4. 4. In your conclusion, you may want to make one specific term explicit: "Therefore, as I proposed in my email to you on February 25, 2008, you shall have until \_\_\_\_\_, to comply with all of the terms and conditions of the Agreement, including plea, sentence, and incarceration, as modified by the USA's December 19{sup}`th` letter to Ms. Sanchez."
+5. 5. Not substantive, but I feel the need to defend my "grammar honor" so -- I know that you, Andy, and Alex (as well as defense counsel) all think that I have made up the word "registrable," but, according to The Oxford American Dictionary, the adjective form of "register" is "registrable."
+
+
+**A. Marie Villafaña**
+
+Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777
+
+From: Sloman, Jeff (USAFLS) Sent: Tuesday, April 29, 2008 5:19 PM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: One other thing
+
+« File: EpsteinNoticeLtr0408.wpd »
+
+From: villafana, Ann Marie C. (USAFLS) Sent: Tuesday, April 29, 2008 12:52 PM To: Senior, Robert (USAFLS); Sloman, Jeff (USAFLS) Cc: Atkinson, Karen (USAFLS) Subject: One other thing
+
+One of our New York girls was contacted by someone claiming to represent Epstein. None of us (here in Florida) have ever disclosed to Epstein's group that we were even LOOKING at New York, so I am concerned that someone in DC may have leaked it, possibly involuntarily.
+
+Jeff— I haven't told the FBI about your one-week to take the deal thing, because they will not be happy. Can I take a look at your letter before you send it?
+
+
+A. Marie Villafana Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+**From:** Villafana, Ann Marie C. (USAFLS)  
+
+Hi Jeff – I like it, especially all of the quotes of their language. I just changed a few spacing issues, but I wanted to leave the substantive edits up to you.
+
+1. 1. In your listing of attorneys, I didn't know if you wanted to add Mr. Starr's name up there (I know it is mentioned later), as well as adding "former U.S. Attorney Guy Lewis, and noted criminal defense attorneys Roy Black and Marty Weinberg (I need to check on his name)"
+2. 2. Under "The Negotiation Phase," you say that one of the options Epstein was presented with was a Rule 11 plea to a federal charge, but that isn't correct. At that time, Alex was unwilling to do a Rule 11 plea, so we were left with trying to find federal charges that he could plead to that resulted in the agreed imprisonment term. Maybe write: "In order to achieve this result, the parties considered two alternatives, a plea to federal charges that limited Epstein's sentencing exposure, or, as suggested by you, a plea to state charges encompassing Epstein's conduct." [Much later, Alex changed his mind, but by that time, Epstein's crew was on the "he didn't do anything wrong" bandwagon.]
+3. 3. Under "Delay," you may want to quote the language of the agreement, which clearly DID NOT contemplate a staggered plea and sentencing. [The true reason why they didn't plead on the November date was because the judge would have remanded him on that date, rather than let him stay out until January. Quite simply, this was not our problem, we have always maintained that the state court judge should do her own thing, so it wasn't a legitimate reason for further delay, but it essentially would have eliminated Epstein's plan to never spend a day in jail.]
+4. 4. In your conclusion, you may want to make one specific term explicit: "Therefore, as I proposed in my email to you on February 25, 2008, you shall have until \_\_\_\_\_, to comply with all of the terms and conditions of the Agreement, including plea, sentence, and incarceration, as modified by the USA's December 19{sup}`th` letter to Ms. Sanchez."
+5. 5. Not substantive, but I feel the need to defend my "grammar honor" so -- I know that you, Andy, and Alex (as well as defense counsel) all think that I have made up the word "registrable," but, according to The Oxford American Dictionary, the adjective form of "register" is "registrable."
+
+
+***A. Marie Villafaña***  
+
+---
+
+**From:** Sloman, Jeff (USAFLS)  
+**Sent:** Tuesday, April 29, 2008 5:19 PM  
+
+<< File: EpsteinNoticeLtr0408.wpd >>
+
+From: Villafana, Ann Mane C. (USAFLS) Sent: Tuesday, April 29, 2008 12:52 PM To: Senior, Robert (USAFLS); Sloman, Jeff (USAFLS) Cc: Atkinson, Karen (USAFLS) Subject: One other thing
+
+One of our New York girls was contacted by someone claiming to represent Epstein. None of us (here in Florida) have ever disclosed to Epstein's group that we were even LOOKING at New York, so I am concerned that someone in DC may have leaked it, possibly involuntarily.
+
+Jeff— I haven't told the FBI about your one-week to take the deal thing, because they will not be happy. Can I take a look at your letter before you send it?
+
+
+A. Marie Villafetha Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+From: Sent: To: Subject: Sloman, Jeff (USAFLS) Tuesday. April 29, 2008 5:19 PM Villafana, Ann Marie C. (USAFLS) RE: One other thing
+
+![](_page_6_Picture_2.jpeg)
+
+EpsteinNoticeLtr 0408.wpd
+
+From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, April 29, 2008 12:52 PM To: Senior, Robert (USAFLS); Sloman, Jeff (USAFLS) Cc: Atkinson, Karen (USAFLS) Subject: One other thing
+
+One of our New York girls was contacted by someone claiming to represent Epstein. None of us (here in Florida) have ever disclosed to Epstein's group that we were even LOOKING at New York, so I am concerned that someone in DC may have leaked it, possibly involuntarily.
+
+Jeff — I haven't told the FBI about your one-week to take the deal thing, because they will not be happy. Can I take a look at your letter before you send it?
+
+
+A. Marie Villafatla Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, April 29, 2008 12:52 PM To: Senior. Robert (USAFLS); Sloman, Jeff (USAFLS) Cc: Atkinson, Karen (USAFLS) Subject: One other thing
+
+One of our New York girls was contacted by someone claiming to represent Epstein. None of us (here in Florida) have ever disclosed to Epstein's group that we were even LOOKING at New York, so I am concerned that someone in DC may have leaked it, possibly involuntarily.
+
+Jeff— I haven't told the FBI about your one-week to take the deal thing, because they will not be happy. Can I take a look at your letter before you send it?
+
+
+A. Marie VHS: Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777

marker2-fixhub/ds9/EFTA00189406/EFTA00189406.receipt.json

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marker2-fixhub/ds9/EFTA00189414/EFTA00189414.md

@@ -0,0 +1,106 @@
+From: lill inas Sent: Friday, May 09, 2008 453 PM To: megegirnliellIMIIIIIIIMI Subject: RE: Epstein
+
+Another deeeeppppp sigh. Have a beer for me.
+
+
+Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+From: Sent: Friday, May 09, 2008 4:18 PM To: Subject: RE: Epstein
+
+Nothing. Not a damned thing.
+
+Fro Sent: To: Subject: RE: Epstein
+
+Hi Bob - Before you go out carousing over the end of EARS week, any news? 1 leave on vacation tomorrow but I went and got myself a Blackberry so you can get me via e-mail. Karen Atkinson has been suffering through this with me, so you can also contact her with news/questions/etc.
+
+Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+From: senior, Kooerr tvoArLo) Sent: Wednesday, May 07, 2008 6:26 PM To: Cr Subject: FW: Epstein
+
+Update following my call today to Drew. Cm thinking of calling Sigal tomorrow Jeff just to get it from her directly. Again, whatever the outcome is we need to have some decision.
+
+From Sent: " . To: OleleutildreeM Subject: Epstein
+
+Bob,
+
+I got your message. According to DRAG Sigal Mandelker, Alice promised to get our letter on the Epstein matter out the door this week. Apparently she's reviewing all the material presented by the defense as well as what we've given her.
+
+I regret the delay.
+
+Drew
+
+From: Sent: To: Subject: Villafana. Ann Marie C. (USAFLS) RE: Epstein
+
+Hi Bob — Before you go out carousing over the end of EARS week, any news? 1 leave on vacation tomorrow hut I went and got myself a Blackberry so you can get me via e-mail. Karen Atkinson has been suffering through this with me. so you can also contact her with news/questions/etc.
+
+Assistant U.S. Attorney 500 S. Australian Me. Suite 400 West Palm Beach. FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+From: Sent: Wednesday, May 07, 2008 6:26 PM To Cc Subject: FW: Epstein
+
+Update following my call today to Drew. I'm thinking of calling Sigal tomorrow Jeff just to get it from her directly. Again, whatever the outcome is we need to have some decision.
+
+From: Sent: Wednesday, May 07, 2008 6:23 PM To' Senior Rohert flICAR 5) Subject: Epstein
+
+Bob,
+
+I got your message. According to DAAG Sigel Mandelker, Alice promised to get our letter on the Epstein matter out the door this week. Apparently she's reviewing all the material presented by the defense as well as what we've given her.
+
+I regret the delay.
+
+Drew
+
+From: Sent: To: Subject: Wednesday, May 07, 2008 5 09 PM JGIIIUI , IlVUI.I L VOrNI 1.-J) RE: Epstein
+
+How are things going down there? Our group just left today.
+
+Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach. FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+Fro Sent: Wednesday, May 07, 2008 5:06 PM To: eilisifmenimeonsISIMIS Subject: RE: Epstein
+
+Sorry, had yet another session with the EARS folks. I have heard nothing.
+
+From: Sent: To: SubjSp: . seir
+
+Hi Bob — Since we didn't get to talk in person, I am bothering you via e-mail. We have a new development that I want to talk to you about. I am just about to start a conference call, but I will give you a ring around 3:45 or so. Hopefully by then you will have heard from DC???
+
+
+Assistant U.S. Attorney 500 S. Australian Ave. Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+From: Villafana, Ann Marie C. (USAFLS) Sent Wednesday. May 07, 2008 3:14 PM To: qpninr Pnhart II 'Carl CI Subject: Epstein
+
+Hi Bob - Since we didn't get to talk in person, I am bothering you via e-mail. We have a new development that 1 want to talk to you about. I am just about to start a conference call, but I will give you a ring around 3:45 or so. Hopefully by then you will have heard from DC???
+
+
+Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777
+
+From:
+
+Sent:
+
+To:
+
+Subject:
+
+agMeferferAnn-Merte-9—tWEAFL-6)
+
+Wednesday. May 07. 2008 1 07 PM
+
+4
+
+Yoiur meeting
+
+Hi guys — I plan to call gam around 2:00. Did anything interesting happen today that I can fill him in on? Thanks.
+
+Arleirtrilififfeff
+
+Assistant U.S. Attorney
+
+500 S. Australian Ave, Suite 400
+
+West Palm Beach, FL 33401
+
+Phone 561 209-1047
+
+Fax 561 820-8777
+
+U

marker2-fixhub/ds9/EFTA00189414/EFTA00189414.receipt.json

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marker2-fixhub/ds9/EFTA00189420/EFTA00189420.md

@@ -0,0 +1,69 @@
+11.1•J
+
+From: Sent: on ay, ay To: SAFLS) Subject: Epstein
+
+Hi karen. Lucky you. You get to be the contact person re epstein while I am gone. I just talked to Jeff and bob. They are getting ready to send out the letter to lefkowitz regarding the plea deal. The letter tells epstein's people to communicate only with you and me. I asked IPPOwto call ME and tell her what is going on. So she can lose her mind with him. I am sure that you enjoyed reading lefkowitz's email where he refers to our last call with him and starr as alex shunting them off to members of alex's staff. Lovely
+
+I
+
+From: Sent: To: Subject: Wednesday. May 21. 2008 5.03 PM Any word?
+
+Hi all. Any response to letter yet? And jeff have you spoken with nesbitt yet? I would like to ask get a bunch of stuff ready for june 3rd.
+
+Thank you.
+
+P.s. I just heard from the ausa in seattle and the copperfield investigation is continuing.
+
+From: Sent: To: Subject: Wednesday. May 21. 2008 5 10 PM Re: Any word?
+
+How did she take it?
+
+Fro To: USAFLS) Sent: Wed May 21 17:04:16 2008 Subject: RE: Any word?
+
+
+No response to the letter yet. I spoke to and explained everything.
+
+
+From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, May 21, 2008 5:03 PM To: 1-- Subject: Any word?
+
+Hi all. Any response to Oweeds letter yet? And yet? I would like to ask her to get a bunch of Thank you. P.s. I just heard from the ausa in seattle and continuing. jeff have you spoken with nesbitt stuff ready for june 3rd. the copperfield investigation is
+
+IIIOICIIPI AIRI ma,l .
+
+From: Sent: To: Subject: Wednesday. May 21, 2008 5 13 PM yw
+
+Hi karen. I am waiting for the demand to meet with the ag. The 3rd is perfect. Thank you!
+
+
+From: MLT AIIJVII, NOILH (USAFLS) To: C. (USAFLS) Sent: Wed May 21 17:11:12 2008 Subject: RE: Any word?
+
+Haven't heard a word but I am so unworthy they won't call me. Jeff said he talked to iggiir. The subpoenas we are doing, do you want the girls from New York to come down on the 3rd? Hope you are having a great time. Have a glass of wine for me!!!! Karen
+
+Ori inal Messa e
+
+From: Vi . (USAFLS) Sent: Wednesday, May 21, 2008 5:03 PM To: Sub
+
+Hi all. Any response to wetter yet? And have you spoken with nesbitt yet? I would like to ask her to get a bunch of stuff ready for june 3rd. Thank you. P.s. I just heard from the ausa in seattle and the copperfield investigation is continuing.
+
+From: mIONekeemiweellemeremp000110. Sent: Thumdey,May22,2008222AM To: C. ' """^"'") Subject: Re: Any word?
+
+Excellent. Thank you.
+
+
+From: rr 1"r"-'`) To: (USAFLS) Sent: Wed May 21 17:15:06 2008 Subject: RE: Any word?
+
+Very well. She understood that some view the Agreement as still in play since we've allowed them to contest various issues. As a result, we decided to give them a reasonable period of time (two weeks) to comply. I explained that I would keep her apprised of any further developments and in the meantime she should plan for June 3rd.
+
+
+From: Villafanm Ann Mmnia C. (USAFLS) Sent: Wednesday, May 21, 2008 5:10 PM To: Slumou, Jcff (USAFLS) Subject: Re: Any word?
+
+How did she take it?
+
+
+From: To: (USAFLS) Sent: Wed May 21 17:04:16 2008 Subject: RE: Any word?
+
+No response to the letter yet. I spoke to Nesbitt and explained everything.
+
+From: (USAFLS) Sent: Wednesday, May 21, 2008 5:03 PM To: (USAFLS); Subject: Any word? (USAFLS); Sorkmaresj.lieboese(USAFLS)
+
+Hi all. Any response to letter yet? And Jeff have you spoken with nesbitt yet? I would like to ask her to get a bunch of stuff ready for june 3rd. Thank you. P.s. I just heard from the ausa in seattle and the copperfield investigation is continuing.

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marker2-fixhub/ds9/EFTA00189721/EFTA00189721.md

@@ -0,0 +1,247 @@
+![](_page_0_Picture_0.jpeg)
+
+rl Members of the U.S. Department of Justice and other federal investigative agencies, including the Federal Bureau of Investigation, must use their best efforts to make sure that these s are protected. If you have an concerns in this regard, please feel free to contact me at, or Special Agent from the Federal Bureau of Investigation at You also can contact the Justice Department's Office for Victims of Crime in Washington, D.C. at . That Office has a website at www.ovc.gov.
+
+
+March 15, 2007
+
+### DELIVERY BY HAND
+
+Miss B=
+
+
+Dear Miss BM
+
+Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense, you have a number of rights. Those rights are:
+
+- (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 any release or escape of the accused.
+- (3) The right not to be excluded from any public court proceeding, unless the court determines that your testimony may be materially altered if you are present for other portions of a proceeding.
+- (4) The right to be reasonably heard at any public proceeding in the district court involving release, plea, or sentencing.
+- (5) The reasonable right to confer with the attorney for the United States in the case.
+- (6) The right to full and timely restitution as provided in law.
+- (7) The 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.
+
+MISS B [REDACTED]  
+MARCH 15, 2007  
+
+In addition to these rights, you are entitled to counseling and medical services, and protection from intimidation and harassment. If the Court determines that you are a victim, you also may be entitled to restitution from the perpetrator. A list of counseling and medical service providers can be provided to you, if you so desire. If you or your family is subjected to any intimidation or harassment, please contact Special Agent [REDACTED] or myself immediately. It is possible that someone working on behalf of the targets of the investigation may contact you. Such contact does not violate the law. However, if you are contacted, you have the choice of speaking to that person or refusing to do so. If you refuse and feel that you are being threatened or harassed, then please contact Special Agent [REDACTED] or myself.
+
+You also are entitled to notification of upcoming case events. At this time, your case is under investigation. If anyone is charged in connection with the investigation, you will be notified.
+
+
+
+
+
+
+
+![](_page_2_Picture_0.jpeg)
+
+
+
+### DELIVERY BY HAND
+
+Miss C
+
+
+Dear Miss
+
+Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense, you have a number of rights. Those rights are:
+
+- (I) The right to be reasonably protected from the accused.
+- (2) The right to reasonable, accurate, and timely notice of any public court proceeding involving the crime or of any release or escape of the accused.
+- (3) The right not to be excluded from any public court proceeding, unless the court determines that your testimony maybe materially altered if you are present for other portions of a proceeding.
+- (4) The right to be reasonably heard at any public proceeding in the district court involving release, plea, or sentencing.
+- (5) The reasonable right to confer with the attorney for the United States in the case.
+- (6) The right to full and timely restitution as provided in law.
+- (7) The right to proceedings free from unreasonable delay.
+- (8) The right to be treated with fairness and with respect for the victim's dignity and privacy.
+
+Members of the U.S. Department of Justice and other federal investigative agencies, including the Federal Bureau of Investigation, must use their best efforts to make sure that these gets are protected. If you have an concerns in this regard, please feel free to contact me at, or Special Agent from the Federal Bureau of Investigation at . You also can contact the Justice Department's Office for Victims of Crime in Washington, D.C. at . That Office has a website at www.ovc.gov.
+
+Miss Cil= A JUNE 7, 2007 PAGE 2
+
+In addition to these rights, you are entitled to counseling and medical services, and protection from intimidation and harassment. If the Court determines that you are a victim, you also may be entitled to restitution from the perpetrator. A list of counseling and medical service providers can be provided to you, if you so desire. If u or ur family is subjected to any intimidation or harassment, please contact Special Agent or myself immediately. It is possible that someone working on behalf of the targets of the investigation may contact you. Such contact does not violate the law. However, if you are contacted, you have the choice of speaking to that person or refusing to do so. If u refuse and feel that you are being threatened or harassed, then please contact Special Agent or myself.
+
+You also are entitled to notification of upcoming case events. At this time, your case is under investigation. If anyone is charged in connection with the investigation, you will be notified.
+
+
+United States Attorn
+
+
+
+cc: Special Agent M=MI, F.B.I.
+
+![](_page_4_Picture_0.jpeg)
+
+
+
+### DELIVERY BY HAND
+
+Miss a
+
+
+Dear Miss C—
+
+Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense, you have a number of rights. Those rights are:
+
+- (I) The right to be reasonably protected from the accused.
+- (2) The right to reasonable, accurate, and timely notice of any public court proceeding involving the crime or of any release or escape of the accused.
+- (3) The right not to be excluded from any public court proceeding, unless the court determines that your testimony may be materially altered if you are present for other portions of a proceeding.
+- (4) The right to be reasonably heard at any public proceeding in the district court involving release, plea, or sentencing.
+- (5) The reasonable right to confer with the attorney for the United States in the case.
+- (6) The right to full and timely restitution as provided in law.
+- (7) The right to proceedings free from unreasonable delay.
+- (8) The right to be treated with fairness and with respect for the victim's dignity and privacy.
+
+Members of the U.S. Department of Justice and other federal investigative agencies, including the Federal Bureau of Investigation, must use their best efforts to make sure that these ts arc protected. If you have an concerns in this regard, please feel free to contact me at , or Special Agent from the Federal Bureau of Investigation at . You also can contact the Justice Department's Office for Victims of Crime in Washington, D.C. at . That Office has a website at www.ovc.gov.
+
+Ma= JUNE 7, 2007 PAGE 2
+
+In addition to these rights, you are entitled to counseling and medical services, and protection from intimidation and harassment. If the Court determines that you are a victim, you also may be entitled to restitution from the perpetrator. A list of counseling and medical service providers can be provided to you, if you so desire. If ou or our family is subjected to any intimidation or harassment, please contact Special Agent or myself immediately. It is possible that someone working on behalf of the targets of the investigation may contact you. Such contact does not violate the law. However, if you are contacted, you have the choice of speaking to that person or refusing to do so. If ou refuse and feel that you are being threatened or harassed, then please contact Special Agent or myself.
+
+You also are entitled to notification of upcoming case events. At this time, your case is under investigation. If anyone is charged in connection with the investigation, you will be notified.
+
+
+
+
+
+cc: Special Agent F.B.I.
+
+![](_page_6_Picture_0.jpeg)
+
+
+
+# DAL.nairD
+
+Miss P
+
+
+Dear Miss I
+
+Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense, you have a number of rights. Those rights are:
+
+- (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 any release or escape of the accused.
+- (3) The right not to be excluded from any public court proceeding, unless the court determines that your testimony may be materially altered if you are present for other portions of a proceeding.
+- (4) The right to be reasonably heard at any public proceeding in the district court involving release, plea, or sentencing.
+- (5) The reasonable right to confer with the attorney for the United States in the case.
+- (6) The right to full and timely restitution as provided in law.
+- (7) The right to proceedings free from unreasonable delay.
+- (8) The right to be treated with fairness and with respect for the victim's dignity and privacy.
+
+Members of the U.S. Department of Justice and other federal investigative agencies, including the Federal Bureau of Investigation, must use their best efforts to make sure that these tints are protected. If you have an concerns in this regard, please feel free to contact me at , or Special Agcnt from the Federal Bureau of Investigation at You also can contact the Justice Department's Office for Victims of Crime in Washington, D.C. at . That Office has a website at www.ovc.gov.
+
+MISS L [REDACTED] P [REDACTED]  
+
+In addition to these rights, you are entitled to counseling and medical services, and protection from intimidation and harassment. If the Court determines that you are a victim, you also may be entitled to restitution from the perpetrator. A list of counseling and medical service providers can be provided to you, if you so desire. If you or your family is subjected to any intimidation or harassment, please contact Special Agent [REDACTED] or myself immediately. It is possible that someone working on behalf of the targets of the investigation may contact you. Such contact does not violate the law. However, if you are contacted, you have the choice of speaking to that person or refusing to do so. If you refuse and feel that you are being threatened or harassed, then please contact Special Agent [REDACTED] or myself.
+
+You also are entitled to notification of upcoming case events. At this time, your case is under investigation. If anyone is charged in connection with the investigation, you will be notified.
+
+
+
+By: [REDACTED]
+
+
+![](_page_8_Picture_0.jpeg)
+
+
+
+### DcirdsgailitY s
+
+
+Dear Miss a
+
+Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense, you have a number of rights. Those rights are:
+
+- (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 any release or escape of the accused.
+- (3) The right not to he excluded from any public court proceeding, unless the court determines that your testimony may be materially altered if you arc piesent for other portions of a proceeding.
+- (4) The right to be reasonably heard at any public proceeding in the district court involving release, plea, or sentencing.
+- (5) The reasonable right to confer with the attorney for the United States in the case.
+- (6) The right to full and timely restitution as provided in law.
+- (7) The right to proceedings free from unreasonable delay.
+- (8) The right to be treated with fairness and with respect for the victim's dignity and privacy.
+
+Members of the U.S. Department of Justice and other federal investigative agencies, including the Federal Bureau of Investigation, must use their best efforts to make sure that these en[s arc protected. If you have an concerns in this regard, please feel free to contact me at , or Special Agent from the Federal Bureau of Investigation at You also can contact the Justice Department's Office for Victims of Crime in Washington, D.C. at . That Office has a website at www.ovc.gov.
+
+MISS RE [REDACTED] S [REDACTED]  
+
+In addition to these rights, you are entitled to counseling and medical services, and protection from intimidation and harassment. If the Court determines that you are a victim, you also may be entitled to restitution from the perpetrator. A list of counseling and medical service providers can be provided to you, if you so desire. If you or your family is subjected to any intimidation or harassment, please contact Special Agent [REDACTED] or myself immediately. It is possible that someone working on behalf of the targets of the investigation may contact you. Such contact does not violate the law. However, if you are contacted, you have the choice of speaking to that person or refusing to do so. If you refuse and feel that you are being threatened or harassed, then please contact Special Agent [REDACTED] or myself.
+
+You also are entitled to notification of upcoming case events. At this time, your case is under investigation. If anyone is charged in connection with the investigation, you will be notified.
+
+
+
+
+
+
+![](_page_10_Picture_0.jpeg)
+
+
+
+### DELIVERY BY HAND
+
+Miss MMS
+
+Re: Crime Victims' and Witnesses' Riehts
+
+Dear Miss a
+
+Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense, you have a number of rights. Those rights are:
+
+- (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 any release or escape of the accused.
+- (3) The right not to be excluded from any public court proceeding, unless the court determines that your testimony maybe materially altered if you are present for other portions of a proceeding.
+- (4) The right to be reasonably heard at any public proceeding in the district court involving release, plea, or sentencing.
+- (5) The reasonable right to confer with the attorney for the United States in the case.
+- (6) The right to full and timely restitution as provided in law.
+- (7) The right to proceedings free from unreasonable delay.
+- (8) The right to be treated with fairness and with respect for the victim's dignity and privacy.
+
+Members of the U.S. Department of Justice and other federal investigative agencies, including the Federal Bureau of Investigation, must use their best efforts to make sure that these rights are protected. If you have an concerns in this regard, please feel free to contact me at , or Special Agent from the Federal Bureau of Investigation at You also can contact the Justice Department's Office for Victims of Crime in Washington, D.C. at That Office has a website at www.ovc.gov.
+
+MISS M [REDACTED] S [REDACTED]  
+
+In addition to these rights, you are entitled to counseling and medical services, and protection from intimidation and harassment. If the Court determines that you are a victim, you also may be entitled to restitution from the perpetrator. A list of counseling and medical service providers can be provided to you, if you so desire. If you or your family is subjected to any intimidation or harassment, please contact Special Agent [REDACTED] or myself immediately. It is possible that someone working on behalf of the targets of the investigation may contact you. Such contact does not violate the law. However, if you are contacted, you have the choice of speaking to that person or refusing to do so. If you refuse and feel that you are being threatened or harassed, then please contact Special Agent [REDACTED] or myself.
+
+You also are entitled to notification of upcoming case events. At this time, your case is under investigation. If anyone is charged in connection with the investigation, you will be notified.
+
+
+
+
+
+
+![](_page_12_Picture_0.jpeg)
+
+
+
+## DELIVERY BY HAND
+
+Miss CI NEM
+
+
+Dear Miss WM
+
+Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense, you have a number of rights. Those rights are:
+
+- (4)
+- (5)
+- (6)
+- (7)
+- (8) The right to be reasonably protected from the accused. The right to reasonable, accurate, and timely notice of any public court proceeding involving the crime or of any release or escape of the accused. The right not to be excluded from any public court proceeding, unless the court determines that your testimony may be materially altered if you are present for other portions of a proceeding. The right to be reasonably heard at any public proceeding in the district court involving release, plea, or sentencing. The reasonable right to confer with the attorney for the United States in the case. The right to full and timely restitution as provided in law. The right to proceedings free from unreasonable delay. The right to be treated with fairness and with respect for the victim's dignity and privacy.
+
+Members of the U.S. Department of Justice and other federal investigative agencies, including the Federal Bureau of Investigation, must use their best efforts to make sure that these rights are protected. If you have an concerns in this regard, please feel free to contact me at
+
+or Special Agent from the Federal Bureau of Investigation at You also can contact the Justice Department's Office for Victims of Crime in Washington, D.C. at . That Office has a website at www.ovc.gov.
+
+In addition to these rights, you are entitled to counseling and medical services, and protection from intimidation and harassment. If the Court determines that you are a victim, you also may be entitled to restitution from the perpetrator. A list of counseling and medical service providers can be provided to you, if you so desire. If u or ur family is subjected to any intimidation or harassment, please contact Special Agent or myself immediately. It is possible that someone working on behalf of the targets of the investigation may contact you. Such contact does not violate the law. However, if you are contacted, you have the choice of speaking to that person or refusing to do so. If u refuse and feel that you are being threatened or harassed, then please contact Special Agent or myself.
+
+You also are entitled to notification of upcoming case events. At this time, your case is under investigation. If anyone is charged in connection with the investigation, you will be notified.
+
+
+
+
+
+cc: Special Agent F.B.I.

marker2-fixhub/ds9/EFTA00189721/EFTA00189721.receipt.json

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marker2-fixhub/ds9/EFTA00189735/EFTA00189735.md

@@ -0,0 +1,64 @@
+![](_page_0_Figure_26.jpeg)
+
+- [Real Estate](#)
+- [Marketplace](#)
+- [Classifieds](#)
+- [Automotive](#)
+- [Advertise](#)
+
+![](_page_0_Picture_28.jpeg)
+
+[Religion](#) | [Archives](#)
+
+Advertisement  
+Advertisement
+
+[E-mail this page](#) | [Print this page](#) | [Most popular](#)
+
+[Redacted text block]
+
+Two alleged victims of Palm Beach billionaire Jeffrey Epstein's sexual abuse have filed court papers seeking to unseal an agreement under which federal prosecutors agreed not to pursue federal charges against Epstein.
+
+The deferred prosecution agreement, reached between the U.S. Attorney's Office and Epstein's lawyers before he pleaded guilty to state felony charges, is under seal in Epstein's state criminal case.
+
+Epstein, 55 is serving 18 months in jail in the state case. He pleaded guilty June 30 to two felony counts: soliciting prostitution and procuring a person under 18 for prostitution.
+
+Under the agreement, federal prosecutors agreed to defer any prosecution on federal charges until 90 days after Epstein completes all requirements of his sentence. If he abides by all court
+
+Aside from the criminal case, there are nine federal and six state lawsuits pending against the Manhattan money manager. All contain similar allegations: Epstein, through his employees and assistants, brought minor girls to his Palm Beach home at 358 El Brillo Way for erotic massages and sometimes sex.
+
+Representing victims Jane Doe No. I and Jane Doe No. 2, Hollywood attorney Brad Edwards asked the court to unseal the agreement so he can effectively represent his clients. He said he wants to be able to confer with other victims, their attorneys and the National Alliance of Victims' Rights Attorneys on strategy.
+
+"The victims can find no legitimate basis for the document to be sealed," Edwards wrote.
+
+In his response filed Wednesday, Assistant U.S. Attorney sought to keep the agreement sealed.
+
+"The non-prosecution agreement has never been filed under seal in federal court," and "the government accuratel described the provisions of the agreement at the time the responses were filed with the court," wrote.
+
+On Aug. 14, U.S. District Judge Kenneth Marra ruled that the non-prosecution agreement should be unsealed for Edwards and any of the victims who want to see it.
+
+But the ruling bars Edwards and anyone else who sees the document from disclosing the terms to anyone.
+
+Edwards also asked the agreement be unsealed because "the government has inaccurately described the agreement."
+
+Edwards referred to an earlier filing by Assistant U.S. Attorney stating that the agreement contains a provision to protect the victims and that the victims were told of that language in October 2007.
+
+"Having now reviewed the non-prosecution agreement, the government's response to the victims' motion and the accompanying sworn declaration are simply untrue," Edwards wrote. "... The government should be required to correct its previously filed pleadings to accurately recount the non-prosecution agreement that it reached with Epstein."
+
+In the government's response,. wrote that, since the document is under seal in state court, the motion to unseal it in federal court is irrelevant.
+
+"The parties who negotiated the agreement, the United States Anorney1Oflice and Jeffrey Epstein, determined that the agreement should remain confidential," wrote.
+
+He also dismissed the claim that Edwards needs to unseal the agreement in order to confer with other victims and their attorneys, because Marra's ruling "provides for a very simple procedure to allow other victims and their lawyers to see the agreement."
+
+contends Edwards' assertion that the government inaccurately described the agreement is merit less.
+
+lie explained that there's been an ongoing dispute between Epstein's attorneys and the government about what comprises the agreement.
+
+The government believes there are three parts to the agreement executed in September 2007, October 2007 and December 2007; while Epstein's lawyers contend the agreement only consists of parts one and two.
+
+Victim notification letters and earlier court filings contain language from part three,. wrote. Because Epstein's lawyers believe the agreement consists only of parts one and two, those were the portions disclosed to Edwards, said in his court filing.
+
+"The fact that an erroneous disclosure was inadvertently made to one petitioner after Epstein had already entered his guilty plea ... does not create an injury where one did not exist before," wrote.
+
+> By using this service you accept the terms of our YjnEthAggsailaa. Copyright 2007 Palm Beach Daily News. All rights reserved. The Palm Beach Daily News Ethagy-EnliCy I About this sireI Write to its

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marker2-fixhub/ds9/EFTA00189738/EFTA00189738.md

@@ -0,0 +1,119 @@
+## IN RE: INVESTIGATION OF JEFFREY EPSTEIN
+
+/
+
+## NON-PROSECUTION AGREEMENT
+
+IT APPEARING that the City of Palm Beach Police Department and the State Attorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey Epstein (hereinafter "Epstein");
+
+IT APPEARING that the State Attorney's Office has charged Epstein by indictment with solicitation of prostitution, in violation of Florida Statutes Section 796.07;
+
+IT APPEARING that the United States Attorney's Office and the Federal Bureau of Investigation have conducted their own investigation into Epstein's background and any offenses that may have been committed by Epstein against the United States from in or around 2001 through in or around September 2007, including:
+
+- (1) knowingly and willfully conspiring with others known and unknown to commit an offense against the United States, that is, to use a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution, in violation of Title 18, United States Code, Section 2422(b); all in violation of Title 18, United States Code, Section 371;
+- (2) knowingly and willfully conspiring with others known and unknown to travel in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f), with minor females, in violation of Tide 18, United States Code, Section 2423(b); all in violation of Title 18, United States Code, Section 2423(e);
+- (3) using a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2;
+- (4) traveling in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f), with minor females; in violation
+
+of Title 18, United States Code, Section 2423(b); and
+
+- (5) knowingly, in and affecting interstate and foreign commerce, recruiting, enticing, and obtaining by any means a person, knowing that the person had not attained the age of 18 years and would be caused to engage in a commercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title 18, United States Code, Sections 1591(a)(1) and 2; and
+
+IT APPEARING that Epstein seeks to resolve globally his state and federal criminal liability and Epstein understands and acknowledges that, in exchange for the benefits provided by this agreement, he agrees to comply with its tents, including undertaking certain actions with the State Attorney's Office;
+
+IT APPEARING, after an investigation of the offenses and Epstein's background by both State and Federal law enforcement agencies, and after due consultation with the State Attorney's Office, that the interests of the United States, the State of Florida, and the Defendant will be served by the following procedure;
+
+THEREFORE, on the authority of United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the following conditions and the requirements of this Agreement set forth below.
+
+If the United States Attorney should determine, based on reliable evidence, that, during the period of the Agreement, Epstein willfully violated any of the conditions of this Agreement, then the United States Attorney may, within ninety (90) days following the expiration of the term of home confinement discussed below, provide Epstein with timely notice specifying the condition(s) of the Agreement that he has violated, and shall initiate its prosecution on any offense within sixty (60) days' of giving notice of the violation. Any notice provided to Epstein pursuant to this paragraph shall be provided within 60 days of the United States learning of facts which may provide a basis for a determination of a breach of the Agreement.
+
+After timely fulfilling all the terms and conditions of the Agreement, no prosecution for the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office, nor any offenses that arose from the Federal Grand Jury investigation will be instituted in this District, and the charges against Epstein if any, will be dismissed.
+
+## Terms of the Agreement:
+
+- 1. Epstein shall plead guilty (not nob contendere) to the Indictment as currently pending against him in the 15th Judicial Circuit in and for Palm Beach County (Case No. 2006-cf-009495A)OCXMB) charging one (1) count of solicitation of prostitution, in violation of Fl. Stat. § 796.07. In addition, Epstein shall plead guilty to an Information filed by the State Attorney's Office charging Epstein with an offense that requires him to register as a sex offender, that is, the solicitation of minors to engage in prostitution, in violation of Florida Statutes Section 796.03;
+- 2. Epstein shall make a binding recommendation that the Court impose a thirty (30) month sentence to be divided as follows:
+  - (a) Epstein shall be sentenced to consecutive terms of twelve (12) months and six (6) months in county jail for all charges, without any opportunity for withholding adjudication or sentencing, and without probation or community control in lieu of imprisonment; and
+  - (b) Epstein shall be sentenced to a term of twelve (12) months of community control consecutive to his two terms in county jail as described in Term 2(a), supra.
+- 3. This agreement is contingent upon a Judge of the 15th Judicial Circuit accepting and executing the sentence agreed upon between the State Attorney's Office and Epstein, the details of which are set forth in this agreement.
+- 4. The terms contained in paragraphs 1 and 2, supra, do not foreclose Epstein and the State Attorney's Office from agreeing to recommend any additional charge(s) or any additional term(s) of probation and/or incarceration.
+- 5. Epstein shall waive all challenges to the Information filed by the State Attorney's Office and shall waive the right to appeal his conviction and sentence, except a sentence that exceeds what is set forth in paragraph (2), supra.
+- 6. Epstein shall provide to the U.S. Attorney's Office copies of all
+
+proposed agreements with the State Attorney's Office prior to entering into those agreements.
+
+- 7. The United States shall provide Epstein's attorneys with a list of individuals whom it has identified as victims, as defined in 18 U.S.C. § 2255, after Epstein has signed this agreement and been sentenced. Upon the execution of this agreement, the United States, in consultation with and subject to the good faith approval of Epstein's counsel, shall select an 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, 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 as agreed to between the identified individual and Epstein, so long as the identified individual elects to proceed exclusively under 18 U.S.C. § 2255, and agrees to waive any other claim for damages, whether pursuant to state, federal, or common law. Notwithstanding this waiver, as to those individuals whose names appear on the list provided by the United States, Epstein's signature on this agreement, his waivers and failures to contest liability and such damages in any suit are not to be construed as an admission of any criminal or civil liability.
+- 9. Epstein's signature on this agreement also is not to be construed as an admission of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person whose name does not appear on the list provided by the United States.
+- 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.
+- 11. Epstein shall use his best efforts to enter his guilty plea and be
+
+sentenced not later than October 26, 2007. The United States has no objection to Epstein self-reporting to begin serving his sentence not later than January 4, 2008.
+
+1. 12. Epstein agrees that he will not be afforded any benefits with respect to gain time, other than the rights, opportunities, and benefits as any other inmate, including but not limited to, eligibility for gain time credit 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 earned during his period of incarceration.
+2. 13. The parties anticipate that this agreement will not be made part of any public record. If the United States receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before making that disclosure.
+
+Epstein understands that the United States Attorney has no authority to require the State Attorney's Office to abide by any terms of this agreement. Epstein understands 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 understands that it is 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 plead guilty and to provide compensation in the manner described above, if Epstein successfully fulfills all of the terms and conditions of this agreement, the United States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to [REDACTED], [REDACTED], [REDACTED], or [REDACTED]. Further, upon execution of this agreement and a plea agreement with the State Attorney's Office, the federal Grand 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, inviolate until all of the terms of this agreement have been satisfied. Upon the successful completion of the terms of this agreement, all outstanding grand jury subpoenas shall be deemed withdrawn.
+
+By signing this agreement, Epstein asserts and certifies that each of these terms 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 certifies that he is aware of the fact that 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 further is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court may dismiss an indictment, information, or complaint for unnecessary delay in presenting a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein hereby requests that the United States Attorney for the Southern District of Florida defer such prosecution. Epstein agrees and consents that any delay from the date of this Agreement to the date of initiation of prosecution, as provided for in the terms expressed herein, shall be deemed to be a necessary delay at his own request, and he hereby waives any defense to such prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the United States to a speedy trial or to bar the prosecution by reason of the running of the statute 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 subject of the grand jury's investigation, it may be by way of an Information signed and filed by the United States Attorney, and hereby waives his right to be indicted by a grand jury as to any such offense.
+
+
+
+
+By signing this agreement, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the conditions of this Non-Prosecution Agreement and agrees to comply with them.
+
+[Redacted]
+
+
+
+By: \_\_\_\_\_
+
+[Redacted]
+
+
+
+9/24/07
+
+
+\_\_\_\_\_  
+GERALD LEFCOURT, ESQ.  
+COUNSEL TO JEFFREY EPSTEIN
+
+
+\_\_\_\_\_  
+LILLY ANN SANCHEZ, ESQ.  
+ATTORNEY FOR JEFFREY EPSTEIN
+
+By signing this agreement, Epstein asserts and certifies that the above has been read and explained to hint Epstein hereby states that he understands the conditions of this Non-Prosecution Agreement and agrees to comply with them.
+
+
+Dated: By:
+
+
+
+Dated: /9-'t I 0 7
+
+
+Q. OUNSEL TO JEFFREY EPSTEIN
+
+LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN
+
+By signing this agreement, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the conditions of this Non-Prosecution Agreement and agrees to comply with them.
+
+
+Dated: By:
+
+
+
+JEFFREY EPSTEIN
+
+
+GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN
+
+Dated:q—A 00?"
+
+ATTORNEY FOR JEFFREY EPSTEIN

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marker2-fixhub/ds9/EFTA00189747/EFTA00189747.md

@@ -0,0 +1,15 @@
+**Subject:** Epstein -- Rule 6(e) issue
+
+Good afternoon, everyone.
+
+Well, I still have not received everything that Epstein intends to produce, but I have reviewed about 60 pages worth of documents. Most are letters and emails related to the negotiation of the non-prosecution agreement and Epstein's post-agreement efforts to have the office or the Justice Department set aside the non-prosecution agreement and let him walk without any punishment (by alleging misconduct by myself, [REDACTED], the Palm Beach Police Department, etc.). [REDACTED]
+
+There are copies of grand jury subpoenas and letters related to grand jury subpoenas that were send to some of Epstein's employees who were represented by attorneys who also represented Epstein. There are some cases that say that grand jury subpoenas themselves, and the identities of grand jury witnesses are confidential as per Rule 6(e). However, Rule 6(e)'s confidentiality requirements do not extend to the witnesses/subpoenaed party. Thus, the subpoenaed party could have made the subpoena and correspondence available to Epstein and, now that it is in Epstein's custody, the civil plaintiff can obtain the documents from Epstein also without running afoul of Rule 6(e).
+
+If you would like me to file an emergency pleading with the Court seeking to stop the production of the 6(e) material, I can do so, but I don't think it will succeed. [REDACTED] – **Can one of you advise?** Epstein's counsel is producing the documents at the close of business today.
+
+Thank you.
+
+### Assistant U.S. Attorney
+
+[Redacted text block]

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marker2-fixhub/ds9/EFTA00189748/EFTA00189748.md

@@ -0,0 +1,19 @@
+![](_page_0_Picture_0.jpeg)
+
+Washington, D.C. 20530
+
+June 23, 2008
+
+Jay Lefkowitz, Esq. Kenneth Starr, Esq. Kirkland and Ellis LLP 777 South Figueroa Street Los Angeles, CA 90017
+
+Gentlemen:
+
+This Office has completed a thorough review of the U.S. Attorney's handling of the matter involving your client, Jeffrey Epstein. We have received and reviewed your letters of May 19, June 3 and June 19, 2008, the attachments to the June 19 letter, as well as your submissions to the Criminal Division and the U.S. Attorney's Office. Additionally, we have reviewed an extensive set of materials provided by the U.S. Attorney's Office and conferred with a number of highly experienced Department attorneys about this matter. The Deputy Attorney General has also been briefed.
+
+As you know, the Department of Justice vests considerable discretion in its U.S. Attorneys, and the Deputy Attorney General will intervene in only the most unusual of circumstances. We do not believe such intervention is warranted here. Even if we were to substitute our judgment for that of the U.S. Attorney, we believe that federal prosecution of this case is appropriate. Moreover, having reviewed your allegations of prosecutorial misconduct, and the facts underlying them, we see nothing in the conduct of the U.S. Attorney's Office that gives us any reason to alter our opinion.
+
+Sincerely,
+
+Senior Associate Deputy Attorney General
+
+cc:

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marker2-fixhub/ds9/EFTA00189749/EFTA00189749.md

@@ -0,0 +1,351 @@
+#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE No. 101,
+
+Case No.: 9:09-CV-80591-KAM
+
+Plaintiff,
+
+v.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+#### DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT
+
+Defendant JEFFREY EPSTEIN, by and through his undersigned counsel, moves to dismiss or, alternatively, for a more definite statement of, the First Amended Complaint. Fed. R. Civ. RR. 12(b)(6) & 12(e) (2009); Loc. Rule 7.1 (S.D. Fla. 2009). In support, Defendant states:
+
+## Pleading Standard & Summary of Argument
+
+The First Amended Complaint ("FAC") alleges claims under 18 U.S.C. § 2255 that explicitly incorporate, and thus necessarily require Plaintiff to prove that Defendant is guilty of violating, specific criminal prohibitions set forth in Title 18 of the U.S. Code. While the Supreme Court has held that every complaint "'must contain something more than a statement of facts that merely creates a suspicion of a legally cognizable right of action," Bell Atlantic Corp. v. Twombly, 550 U.S. 544. 555 (2007), and just last week made clear that "Twombly expounded the pleading standard for 'all civil actions' and not just pleadings made in the context of an antitrust dispute," Ashcroft v. Iqbal, No. 07-1015 (U.S. May 18, 2009) (slip op. at 20) (quoting Fed. R. Civ. P. 1), the need to enforce these pleading requirements is especially acute in this context. After all, the defendant in a § 2255 action is essentially being put on trial for violating criminal laws, and the statutory penalty is obviously and intentionally punitive.
+
+unlawfully-harmed-me accusation" before allowing plaintiffs to launch a fishing expedition for evidence of possible crimes, lqbal, slip op. at 14 (citing Thvombly, 550 U.S. at 555), but essential that the accused be given "'such a statement of the facts and circumstances as will inform [him] of the specific offense ... with which he is charged," including a "specific identification of fact[s]" required to establish "fully, directly, and expressly, without any uncertainty or ambiguity, ... all the elements nececsary to constitute the offence." Russell v. United States, 369 U.S. 749, 764-65 (1962) (quoting United States v. Hess, 124 U.S. 483, 487 (1888); United States v. Carll, 105 U.S. 611, 612 (1881)). The FAC does not come close to discharging that burden.
+
+A. The applicable version of § 2255 only permits "minors" to sue: "Any minor who is a victim of a violation of [certain criminal statutes] and who suffers personal injury as a result of such violation may sue." 18 U.S.C. § 2255(a) (2003) (emphasis added). Yet the FAC affirmatively admits that Plaintiff is over the age of 18. See FAC 1 18 ("Plaintiff was first brought to Defendant's mansion in or about the spring of 2003, when she was merely 17 years old."). Plaintiff is bound by that admission, and the FAC must be dismissed with prejudice. Best Canvas Prods. & Supplies, Inc. v. Ploof Truck Lines. Inc., 713 F.2d 618, 621 (11th Cir. 1983) ("[A] party is bound by the admissions in his pleadings.").
+
+B. Nor is Plaintiff the "victim of a violation" of a predicate criminal statute within the meaning of § 2255. 18 U.S.C. § 2255(a). In our system of justice, those accused of "violating" a criminal statute are innocent until proven guilty beyond a reasonable doubt in a criminal court. With due respect to the courts that have concluded otherwise, it defies common sense to think that Congress intended to invert that fundamental legal norm, and the legislative history of § 2255 expressly confirms that Congress intended to condition § 2255 actions on an antecedent criminal conviction. The FAC therefore must be dismissed because it does not—and cannot allege that Defendant has been convicted of a predicate criminal offense.
+
+absence of a predicate conviction, the FAC not only fails to meet the modest pleading standards elucidated by Twombly and Iqbal, but—even taken as true—would not establish a legally "plausible" claim that Plaintiff is a victim of any predicate criminal offense giving rise to a § 2255 cause of action. See Iqbal, slip op. at 15 (explaining that every civil complaint must state "a plausible claim for relief," and that "where the well-pleaded facts do not permit the court to infer more than the mere possibility of misconduct, the complaint has alleged—but it has not `shown'—`that the pleader is entitled to relief.") (quoting Fed. It. Civ. P. 8(aX2)).
+
+k Finally, Plaintiffs attempt to multiply the penalties recoverable under § 2255(a) by pleading six separate counts is inconsistent with the language and structure of § 2255. The law allows for a single action predicated on any and all predicate criminal acts, and entitles the plaintiff only to a single recovery of actual damages (subject only to a presumptive minimum).
+
+## I. THE COMPLAINT MUST BE DISMISSED BECAUSE PLAINTIFF IS NOT A MINOR.
+
+#### A. The Version of 18 U.S.C. § 2255 In Effect When The Predicate Acts Allegedly Were Committed Allowed Only "Minors" To File Suit.
+
+The FAC is predicated exclusively on acts that allegedly occurred in 2003. FAC ¶ 18 ("Plaintiff was first brought to Defendant's mansion in ... the spring of 2003."); id. ¶ 19 ("Defendant thereafter lured [Plaintiff] to [his home] on at least one and perhaps two other occasions in the spring and/or summer of 2003."). At that time, 18 U.S.C. § 2255(a) provided:
+
+Any minor who is a victim of a violation of [certain specified federal statutes] and who suffers personal injury as a result of such violation may sue in any appropriate United States District Court and shall recover the actual damages such minor sustains and the cost of the suit, including a reasonable attorney's fee. Any minor as described in the preceding sentence shall be deemed to have sustained damages of no less than \$50,000 in value.
+
+It is well settled that in interpreting a statute, the court's inquiry begins with the text and structure of the law. CBS, Inc. v. Prime Time 24 Venture, 245 F.3d 1217, 1222 (11th Cir. 2001) ("We begin our construction of [a statutory provision] where courts should always begin the process of legislative interpretation, and where they often should end it as well, which is with the words of the statutory provision.") (quoting Harris v, Gamer, 216 F.3d 970, 972 (11th Cir. 2000) (en bane)) (first alteration omitted). In this case, the plain text of the 2003 statute is both clear and unmistakable. It allowed only minors (or the representative of a then-minor, see Fed R. Civ. P. 17(c)) to initiate suit under § 2255. It provided only that "any minor ... may sue" and that "any minor ... shall recover the actual damages such minor sustains" as a result of the predicate acts. Id. (emphasis added). The law's use of the present tense further underscored its limited scope: It spoke of "any minor who is a victim," provided that "such minor ... shall recover" damages arising from the underlying offense, and stated that "any minor ... shall be deemed" to have sustained at least \$50,000 in damages. Id. (emphasis added). Where the statute's words are unambiguous—as the are here--the "judicial inquiry is complete." Merritt v, Dillard Paper Co., 120 F.3d 1181, 1186 (11th Cir. 1997) (citation omitted)). Under the 2003 version of the statute, only minors could initiate suit.
+
+To the extent there is any ambiguity in the text—and there is none—the law's legislative history further underscores Congress's intent to limit the right of action to minors: "Current law provides for a civil remedy for personal injuries resulting from child pornography offenses. This section expands the number of sex offenses in which a minor may pursue a civil remedy for personal injuries resulting from the offense." H.R. Rep. 105-557, at 23 (1998), as reprinted in 1998 U.S.C.C.A.N. 678, 692. And perhaps most telling, Congress amended § 2255 in 2006 three years after the alleged misconduct in this case supposedly took place—to make the civil action available to persons who had turned 18 by the time they filed suit:
+
+(a) In general.—Any person who, while a minor, was a victim of a violation of section 2241(c), 2242, 2243, 2251, 2251A, 2252, 2252A, 2260, 2421, 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.
+
+18 U.S.C. § 2255 (2006) (emphasis added).
+
+The contrast between the 2003 and 2006 versions of § 2255 is stark. The 2006 law replaces each of the 2003 law's uses of the term "minor with the term "person." Where the 2006 law does refer to a "minor," it changes the 2003 law's present-tense references ("is") to past-tense references ("was"). And the 2006 law's new language now makes clear that, unlike the 2003 statute, those victimized while under the age of 18 may sue after they turn 18. Given that amendments must be interpreted "to have real and substantial effect," Stone v. I.N.S., 514 U.S. 386, 397 (1995), there can be no doubt that Congress recognized the prior statute's strict limitations and for the first time expanded the right of action to adults.
+
+Indeed, the history of the 2006 amendments clearly shows that Congress intended to change the law, not merely to clarify it. Those amendments were made by § 707 of the Adam Walsh Child Protection and Safety Act, Pub. L. No. 109-248, 120 Stat. 587, 650 (2006), and are known as "Masha's Law." As Senator Kerry—the author of Masha's Law-e xplained:
+
+What Masha's law does, and what is incorporated in here, is it changes "any minor" to "any person," so that if a minor is depicted in photographs pornographically that are distributed over the Internet, but by the time the abuser is caught, the minor is an adult, they can still recover. They cannot listbv and that is ridiculous. It makes sure that recovery on the part of a minor can take place when they become an adult....
+
+Although I don't think there is any price too high to cost an individual who would take advantage of a minor, I think it is only appropriate to ... make sure that reaching the age of adulthood does not exempt someone from recovery. It is a tribute to continuing to do what this bill does, and that is look after the protection of minors and ensure that those who violate them are caught and punished and have to pay to the maximum extent.
+
+152 Cong. Rec. S8012-02 at 88016 (July 20, 2006) (statement of Sen. Kerry) (emphasis added).
+
+Courts typically give special weight to the statements of a bill's sponsor, Corley v, U.S. 129
+
+S.Ct. 1558, 1569 (Apr. 6, 2009) ("[Al sponsor's statement to the full Senate carries considerable weight.")) There is no basis to depart from that rule here.
+
+It thus is no answer that the 2003 statute's limitations clause provided that "in the case of a person under a legal disability, [the complaint may be filed] not later than three years after the disability," 18 U.S.C. § 2255(b) (2003), such that the unamended version of the law implicitly must have permitted victims to sue even after they turned 18. That interpretation not only would render Masha's Law superfluous; it would make Masha's Law's internally redundant, because Masha's Law retained the "legal disability" language from the 2003 version of § 2255(b). See 18 U.S.C. § 2255(b) (2006). In short, the retained "legal disability" language in § 2255(b) of the 2006 statute would be entirely redundant were it construed to do implicitly what the law elsewhere did expressly. In these circumstances, the traditional rules against surplusage and redundancy apply with double force. See, e.g., Duncan v. Walker, 533 U.S. 167, 174 (2001). The "legal disability" language in § 2255(b) should be interpreted to reference classic legal disabilities like insanity, mental disability, or imprisonment—not age.
+
+Indeed, that is precisely how Congress typically uses the term "legal disability": most federal statutes that use the term make clear that it doesn't include age. See, e.g., 25 U.S.C. § 590c ("A share or interest payable to enrollees less than eighteen years of age or under legal
+
+Similarly, the official summary prepared by the Congressional Research Service ("CRS") explained that Masha's Law Itievises provisions allowing victims of certain sex-related crimes to seek civil remedies to: (I) allow adults as well as minors to sue for injuries; and (2) increase from \$50,000 to \$150,000 the minimum level of damages." Official Summary of Pub. Law No. 109.248 (July 27, 2006), as reprinted at http://thornas.loc.gov/cgi-bintbdquerylz?d109:11R04472:®®®L&summ2=m& (emphasis added) (last visited May 10, 2009). Courts have long consulted official CRS summaries to assess legislative intent, see. e.g., &nig v. Pension Ben. Guar. Com. 744 F.2d 133, 145 & n.7 (D.C. Cr. 1984); DIRECTV Inc. v. Cigoarella No. Civ.A 03-2384, 2005 WL 1252261 at \*7 (D.NJ. May 24, 2005); Clohessv v. St Francis Host & Healthcare No. 98-C-4818, 1999 In 46898'2-•3 (ND. III. Jan. 28, 1999), and there is good reason to do so. By design, CRS summaries are intended to "objectively describe} the measure's ... effect upon ... current law" so that Congress can make informed judgments about the impact of proposed bills. See The Library of Congress, About CRS Summary, available at http://thomas.loc.gov/bsdabt dgetlitnil (last visited May 10, 2009).
+
+disability shall be paid ....") (emphasis added); id. § 783 ("Funds payable under sections 781 to 785 of this title to minors or to persons under legal disability shall be paid...?" (emphasis added); id. § 1128 ("Sums payable to enrollees ... who are less than eighteen years of age or who are under a legal disability shall be paid....") (emphasis added); id. § 1253 ("Sums payable ... to enrollees ... who are less than eighteen years of age or who are under a legal disability shall be paid....' (emphasis added); id. § 1273 (same); id. § 1283 (same); id. § 1295 (same); id. § 1300a-3 (same); id. § 1300c-3 (same); id. § 1300d-7 (same); see also 38 U.S.C. § 3501.
+
+Needless to say, Congress would not have had to address age expressly in any of these statutes if the term "legal disability" necessarily included one's status as a minor; instead, Congress's mere use of the term "legal disability" already would account for a would-be plaintiffs minority status. Given the rule "against reading a text in a way that makes part of it redundant," Nat'l Ass'n of Home Builders v. Defenders of Wildlife, 551 U.S. 644 (2007) (citing TRW Inc. v. Andrews, 534 U.S. 19, 31 (2001)), and the canon that "where words are employed in a statute which had at the time a well-known meaning ... in the law of this country, they are presumed to have been used in that sense," Standard Oil Co. v. United States, 221 U.S. 1, 59 (1911), § 2255's reference to "legal disability" can only be interpreted as a reference to classic disabilities like insanity or mental incapacity, but not age.
+
+But this Court need not even reach that issue in this case. Regardless of whether § 2255(b) would allow a minor to sue within three years of turning 18, that carve-out would not help Plaintiff in this case. After all, she openly admits that she was 17 years-old in 2003. FAC 11 18, 19. That means that she was either 22 or 23 when she filed this case in April 2009—at least a titll year beyond the three-year period set forth in § 2255(b), regardless of how the "legal disability" language in that subsection of the statute is construed. In short, and under any reasonable interpretation of the law, the version of the statute in effect at the time of the alleged criminal conduct giving rise to this suit would preclude Plaintiff from maintaining this action.
+
+## B. Masha's Law Does Not Apply To This Case.
+
+The presumption against retroactivity and the Ex Post Facto clause preclude application of Masha's Law in this case, where the alleged predicate conduct was completed before 2006.
+
+## 1. Congress Did Not Intend To Apply Masha's Law Retroactively.
+
+It is axiomatic that "retroactivity is not favored," Bowen v. Georgetown Univ. Hosp., 488 U.S. 204, 208 (1988), and the "traditional presumption teaches that [an amended statute] does not govern absent clear congressional intent favoring such a result." Landgraf v. USI Film Prods., 511 U.S. 244, 280 (1994). As the Supreme Court has explained, this presumption
+
+embodies a legal doctrine centuries older than our Republic. Elementary considerations of fairness dictate that individuals should have an opportunity to know what the law is and to conform their conduct accordingly; settled expectations should not be lightly disrupted. For that reason, the "principle that the legal effect of conduct should ordinarily be assessed under the law that existed when the conduct took place has timeless and universal appeal." Kaiser Alum. & Chem. Corp. v. Bonjorno, 494 U.S. 827, 855 (1990) (Scalia, J., concurring).
+
+Id. at 265 (footnote omitted). Courts therefore apply the statute in effect at the time of the underlying conduct unless there is a clear statement that an amendment should apply retroactively to pre-enactment conduct. See, e.g., Hughes Aircraft Co. v. United States ex rel. Schumer, 520 U.S. 939, 952 (1997) ("Given the absence of a clear statutory expression of congressional intent to apply the 1986 amendment to conduct completed before its enactment, we ... hold that, under the relevant 1982 version of the [statute], the District Court was obliged to dismiss this action.").
+
+There is no clear indication that Congress intended Masha's Law to apply retroactively. Unlike the many cases in which Congress has specified that a particular amendment applies in proceedings "commenced on or after the date of enactment," Tello v. Dean Witter Reynolds,. Inc., 410 F.3d 1275, 1283 (11th Cir. 2005) (collecting examples), Masha's Law was subject only to a standard effective date provision that sheds no light on its retroactivity. See Landgraf, 511 U.S. at 1493 ("A statement that a statute will become effective on a certain date does not even arguably suggest that it has any application to conduct that occurred at an earlier date.").
+
+Far more important, the only expression of congressional intent regarding retroactivity strongly suggests that Congress did not intend Masha's Law to apply retroactively. As set forth above, Masha's Law was enacted as part of the Adam Walsh Act. The centerpiece of that Act was an expanded sex-offender registry ("SORNA") intended to bolster tracking of convicted sex offenders. See Pub. L. 109-248 §§ 1-155, 120 Stat. 587, 590-611 (2006). To effectuate SORNA, Congress provided that offenders must register "before completing a sentence of imprisonment with respect to the offense giving rise to the registration requirement, or not later than 3 business days after being sentenced" if no prison term was imposed. 42 U.S.C. § 16913(b). It also imposed penalties on offenders who fail to register. See 18 U.S.C. § 2250(a). At the same time, and of particular relevance in this case, Congress recognized that applying SORNA to past offenders would raise retroactivity concerns. It therefore addressed retroactivity expressly:
+
+The Attorney General shall have the authority to specify the applicability of the requirements of this subchapter to sex offenders convicted before July 27, 2006 or its implementation in a particular jurisdiction, and to prescribe rules for the registration of any such sex offenders.
+
+42 U.S.C. § 16913 (d).
+
+While Congress clearly provided that SORNA could be applied retroactively, it did not do so with respect to Masha's Law. As the Supreme Court and the Eleventh Circuit have long observed, "'where Congress includes particular language in one section of a statute but omits it in another section of the same Act, it is generally presumed that Congress acts intentionally and purposefully in the disparate inclusion or exclusion."' United States v. Jordan, 915 F.2d 622, 628 (11th Cir. 1990) (quoting Rodriguez v. United States, 480 U.S. 522, 525 (1987) (itself quoting Russello v. United States, 464 U.S. 16, 23 (1983))). There is no basis for departing from that rule. Given the strong evidence that Congress did not intend retroactively to apply Masha's Law, the 2003 version of § 2255 supplies the governing law.
+
+## 2. The Ex Post Facto Clause Bars Application Of Masha's Law.
+
+Even if Congress did intend Masha's Law to apply retroactively, doing so would violate the Ex Post Facto clause. U.S. CONST. art. 1, § 9, cl. 3. As the Eleventh Circuit has explained:
+
+[The] Constitution provides that "[n]o Bill of Attainder or ex post facto Law shall be passed" by Congress. U.S. Const. art. I, § 9, cl. 3. A law violates the Ex Post Facto Clause if it "'applies to events occurring before its enactment and disadvantages the offender affected by it' by altering the definition of criminal conduct or increasing the punishment for the crime." Lynce v. Mathis, 519 U.S. 433, 441 (1997) (quoting Weaver v. Graham 450 U.S. 24, 29 (1981)).
+
+United States v. Siegel 153 F.3d 1256, 1259 (11th Cir. 1998) (emphasis added; internal alterations omitted). Even though this case nominally involves a civil cause of action, the Ex Post Facto Clause is triggered both because Masha's Law dramatically increased the penalties for predicate criminal violations and because its retroactive application would revive Defendant's exposure to penalties that previously had become barred as a matter of law.
+
+### a. Retroactive Application Of Masha's Law Would Increase The Penalties For Violating The Predicate Criminal Statutes.
+
+While the 2003 statute provided that "[a]ny minor ... shall be deemed to have sustained damages of no less than \$50,000," 18 U.S.C. § 2255 (2003) (emphasis added), Masha's Law trebles the minimum statutory damages by providing that plaintiffs "shall be deemed to have sustained damages of no less than \$150,000." Id. (2006) (emphasis added). As a result, the enhanced monetary penalties provided by Masha's Law "increas[e] the punishment for the crime," Lvnce, 519 U.S. at 441, and make "the punishment for crimes committed before its enactment `more onerous' than the punishment would have been under the unamended statute. Id. at 442 (quoting Weaver, 450 U.S. at 36). Those penalties are the direct consequence of a defendant's commission of a predicate criminal offense and form a deliberate part of the punishment for that crime. See, e.g., 134 Cong. Rec. S372-01 (Feb. 1, 1998) (statement of Sen. Grassley) ("(T]he sanctions provided for in my bill, such as ... the amended civil remedy section ... provide much needed criminal enforcement tools.") (emphasis added); 152 Cong. Rec. S8012-02 at 58016 (July 20, 2006) (statement of Sen. Kerry) ("[Masha's Law] raises from \$50,000 to \$150,000 the penalty ... if, in fact, someone ... is caught and convicted.") (emphasis added). Accordingly, Masha's Law cannot lawfully be applied in this case.
+
+The Eleventh Circuit's decision in United States v. Siegel, 153 F.3d 1256 (11th Cir. 1998), is virtually on point. hi Siegel the defendant pleaded guilty to charges under 18 U.S.C. § 371 and § 1956(aX1)(A) that arose out of actions taken he took between February 1, 1988 and May 1, 1990. Id. at 1259. Under the restitution statute in effect when the crimes were committed ("VWPA"), courts had discretion "to order `that the defendant make restitution to any victim of the offense!" Id. at 1259 (citing 18 U.S.C. § 3663 (1985)). But that discretion was limited: "In exercising this discretion, the court was required to consider `the amount of the loss sustained by any victim as a result of the offense, the financial resources of the defendant, the financial needs and earning ability of the defendant and the defendant's dependents, and such other factors as the court deems appropriate,' before fixing the amount of the restitution, if any, that the defendant was required to pay." Id. at 1260 (citing 18 U.S.C. § 3664(a) (1985)).
+
+Before Siegel pleaded guilty in July 1996, Congress passed the Mandatory Victims Restitution Act ("MVRA"). Id. at 1258-59 (citing Pub. L. No. 104-132, § 211). That law mandated the award of full restitution without regard to the defendant's economic circumstances. Id. at 1260. Congress expressly made those changes "effective for sentencing proceedings in cases in which the defendant is convicted on or after April 24, 1996." Id. at 1258 (quoting statute; alteration omitted). The district court applied MVRA at Siegel's sentencing and ordered him to pay restitution totaling \$1,207,000 without considering his inability to do so. Id. at 1258. The Eleventh Circuit reversed, holding that MVRA "cannot be applied to a person whose criminal conduct occurred prior to [its effective date]." Id. at 1260. It explained:
+
+At the time [of sentencing], the amended VWPA thus had the potential to increase the amount of restitution they would have to pay, from an amount set by the court by taking into account appellants' financial circumstances, to full restitution.
+
+Accordingly, if the court determines that the VWPA should apply to this case, it must use the old version to avoid running afoul of the Ex Post Facto Clause.
+
+Id. (quoting United States v. Baggett, 125 F.3d 1319, 1322 (9th Cir. 1997)).
+
+This case is indistinguishable from Siegel. As in Siegel, Masha's Law caused "a substantive change ... to [defendant]'s detriment," by trebling the minimum statutory penalty payable to the victim of a predicate crime. Id. at 1260. As in Siegel, Masha's Law thus has "the potential to increase the amount of restitution [defendants] would have to pay" to victims of a predicate crime. Id. Accordingly, and as in Siegel, Masha's Law cannot be applied where the predicate criminal conduct allegedly occurred prior to the amended statute's effective date.
+
+It is no answer that the law at issue in Siegel provided "restitution" to the victim of a criminal offense while this statute provides "damages" to the victim of a criminal offense; by definition, damages paid by an offender to the victim of a criminal offense are restitution. See Black's Law Dict. (8th ed. 2004) (defining restitution as "[c]ompensation for loss; esp., full or partial compensation paid by a criminal to a victim."). Indeed, the case for applying a post facto principles is even stronger here than in Siegel: While MVRA mandated the award of actual damages to the victim, Masha's Law mandates the payment of at least \$150,000 to the victim even if the victim did not actually sustain \$150,000 in damages. See 18 U.S.C. § 2255 (2006) ("Any [victim] shall be deemed to have sustained damages of no less than 8150,000 in value.") (emphasis added). Given its obviously penal nature, there is little wonder why Senator Kerry repeatedly described Masha's Law as increasing "the penalty" for persons convicted of a predicate crime. 152 Cong. Rec. 58012-02, 58016 (July 20, 2006) (statement of Sen. Kerry).
+
+Because applying the 2006 amendments would increase the punishment for violating a predicate criminal statute, Masha's Law cannot lawfully be applied in this case
+
+- b. Retroactively Applying Masha's Law Impermissibly Would Revive Defendant's Exposure To Previously Barred Penalties For His Alleged Violation Of The Predicate Criminal Statutes.
+
+Perhaps more important, the Er Post Facto clause precludes application of Masha's Law here because it would revive Defendant's exposure to penalties that previously had become barred by operation of law—no matter their amount. As set forth above, the 2003 statute allowed only "minors" to file suit. Because Plaintiff was 17 when the predicate offenses allegedly were committed, she could have sought the statutory penalty under the 2003 version of § 2255. Once Plaintiff turned 18, however, she lost her ability to sue. That extinguished Defendant's exposure to penalties for his alleged crimes. Applying Masha's Law thereby would revive Defendant's exposure to penalties in direct contravention of the Er Post Facto clause.
+
+The Supreme Court's decision in California v. Stogner, 539 U.S. 607 (2003), perfectly illustrates the point. In Stogner, the defendant was charged in 1998 based on sex crimes that he allegedly committed between 1955 and 1973. While the original three-year statute of limitations for those offenses long had lapsed, a California law purported to "revive" stale claims by authorizing the filing of charges within one year of a new police report alleging past child sexual abuse. 539 U.S. at 609-10 (discussing Cal. Penal Code Ann. § 803(g) (2003)). The defendant moved unsuccessfully to dismiss the indictment, and later appealed to the Supreme Court.
+
+That Court reversed, explaining that "the new statute threatens the kinds of harm that ... the Ex Post Facto Clause seeks to avoid," because its revival of previously barred claims would subject the defendant to penalties for criminal conduct "after the State has assured `a man that he has become safe from its pursuit," and thus would "deprive the defendant of the `fair warning' that might have led him to preserve exculpatory evidence." 539 U.S. at 611 (quoting Falter v United States, 23 F.2d 420, 426 (2d Cir. 1928) (Hand, J.) and Weaver, 450 U.S. at 28). More important, the Court observed, California's revival of otherwise barred claims fell squarely within a category of ex post facto laws condemned by the Supreme Court's seminal ex post facto decision, Calder v. Bull—namely, laws providing for "punishments, where the party was not, by law, liable to any punishment." Id. at 612 (quoting Calder, 3 Dall. 386, 391 (1798)).
+
+The second category—including any "law that aggravates a crime, or makes it greater than it was, when committed," describes California's statute as long as those words are understood as Justice Chase understood them—i.e., as referring to a statute that "intlict[s] punishments, where the party was not, by law, liable to any punishment." After (but not before) the original statute of limitations had expired, a party such as Stogner was not "liable to any punishment." California's new statute therefore "aggravated" Stogner's alleged crime, or made it "greater than it was, when committed," in the sense that, and to the extent that, it "inflicted punishment" for past criminal conduct that (when the new law was enacted) did not trigger any such liability.
+
+Id. at 613 (quoting Calder, 3 Dail. at 391) (internal citations omitted). The Court held that the Ex Post Facto clause precludes the revival of claims predicated on past crimes.
+
+The precise concerns animating Stogner are present in this case. As in Stogner, Defendant was liable to punishment" under § 2255 before Plaintiff turned 18, but once she attained that age, he no was longer "liable to punishment" under § 2255 for his alleged commission of the predicate crimes against her. And as in Stogner retroactively applying Masha's Law in a manner that would revive Defendant's exposure to statutory penalties would "aggravate" his alleged crimes "in the sense, and to the extent that, it `inflicted punishment' for past criminal conduct that (when the new law was enacted) did not trigger any such liability." Id. (quoting Calder, 3 Dail. at 391). At bottom, then, well-settled retroactivity and ex post facto principles preclude application of Masha's Law to Defendant's alleged pre-enactment conduct.
+
+# C. The MC Must Be Dismissed Because Plaintiff Concededly Is Not A Minor.
+
+As the FAC makes clear, Plaintiff was 17 in the spring of 2003, and she thus was either 22 or 23 when she filed this suit in April 2009. FAC ¶ 18. Because Masha's Law cannot lawfully be applied to the alleged conduct in this case, and because the prior statute provided that only "minors" may sue, the FAC must be dismissed with prejudice.
+
+## IL THE FAC MUST BE DISMISSED BECAUSE DEFENDANT HAS NOT BEEN CONVICTED OF A PREDICATE OFFENSE.
+
+Even if Plaintiff were entitled to maintain this suit—and without regard to which version of § 2255 applies—the FAC still would fail as a matter of law because it does not (and cannot
+
+consistent with Rule 11) allege that Defendant is guilty of "a violation" of a predicate statute. See 18 U.S.C. § 2255(a) (2003 & 2006) (plaintiff must be "a victim of a violation of [certain federal statutes]"). As set forth below, the plain text of the statute and its legislative history demonstrate that § 2255 is conditioned on a prior federal conviction. Because Defendant has never been convicted of a predicate federal offense, the FAC must be dismissed.
+
+## A. The Statute Requires Proof Of A Prior Federal Conviction.
+
+By its plain terms, § 2255 only permits "a victim of a violation" of certain federal criminal statutes to seek statutory penalties. See 18 U.S.C. § 2255(a) (2003 & 2006). Given the presumption of innocence that animates our system of criminal justice, Congress's reference to "a victim of a violation" of a criminal statute can only be interpreted to require proof that the defendant has been convicted of a predicate federal offense against the plaintiff. After all, an individual accused of "violating" a criminal statute is deemed innocent until proven guilty beyond a reasonable doubt. It would turn that principle upside down if plaintiffs could sue in the absence of an antecedent criminal conviction. Given that "Congress is understood to legislate against a background of common-law adjudicatory principles," Astoria Fed. Say. & Loan Assn. v. Solimino, 501 U.S. 104, 108 (1991), "the courts may take it as given that Congress has legislated with an expectation that the principle will apply except 'when a statutory purpose to the contrary is evident.'" Id. (quoting Isbrandtsen Co. v. Johnson 343 U.S. 779, 783 (1952)).
+
+In this case, however, the Court need not take anything "as given." Even if the statute's language were not clear—which it is—§ 2255's legislative history confirms that Congress intended to require a prior criminal conviction. While the history accompanying the wage of the original 1986 statute is sparse--§ 2255 was inserted with little debate into an omnibus appropriations bill for 1987, see Pub. L No. 99-500, 100 Stat. 1783 (1986)—the 1998 and 2006 extensions of § 2255 produced clear statements regarding Congress's intent. In 1998, for instance, Congress added additional predicate statutes to § 2255. Senator Grassley, who wrote
+
+the amendments, explained that "the sanctions provided for in my bill, such as ... the amended civil remedy section [would] provide much needed criminal enforcement tools" against convicted offenders. 134 Cong. Rec. 5372-01 (Feb. 1, 1998) (statement of Sen. Grassley). Not surprisingly, the House Report accompanying that legislation used classic terms associated with an adjudicated conviction in order to make clear that the bill targeted those convicted of the predicate crimes: "It is the intention of the Committee that only the offender who perpetrated the offense against the minor is liable for damages under this section." H.R. Rep. 105-557, P.L. 105-314: Protection of Children From Sexual Predators Act of 1998, at 23 (emphasis added).
+
+The legislative history of Masha's Law is even more explicit:
+
+What Masha's law does, and what is incorporated in here, is it ... makes sure that recovery on the part of a minor can take place when they become an adult, whether or not the guilty person is incarcerated. It raises from \$50,000 to \$150,000 the penalty for which that individual can be recompensated if in fact,, someone who depicts that picture and puts it on the Internet and uses them & caught and convicted.
+
+152 Cong. Rec. S8012-02 at S8016 (July 20, 2006) (statement of Sen. Kerry). These references could hardly be clearer: for the statute to apply, the defendant must be arrested, tried, and found "guilty"—the "penalty" is available only "if, in fact, someone ... is caught and convicted." Id. As noted above, courts give special weight to the statements of a bill's sponsor. Corley, 129 S.Ct. at 1569. Given these clear statements from Senator Kerry, the only plausible conclusion is that § 2255 requires proof of an antecedent criminal conviction.
+
+That having been said, we do recognize that two district courts have held that plaintiffs may pursue a § 2255 action even without a prior conviction. Smith v. Husband. 376 F. Supp. 2d 603 (E.D. Va. 2005); Doe v, Liberatore, 478 F. Supp. 2d 742 (ED. Pa. 2007). But with due respect, these decisions overlook the relevant legislative history set forth above and rely instead on legislative history that is at best inapposite, and at worst irrelevant. In particular, Smith and Liberatore (which itself rested entirely on Smith) hinge on two pieces of legislative history relating to unenacted drafts of the legislation. See Smith, 376 F. Supp. 2d at 610-12• Liberatore, 478 F. Supp. 2d at 754-55.
+
+First, both courts found it significant that § 2255 initially was proposed as an amendment to the civil RICO statute, and in particular that an early draft of the legislation allowed "[a]ny person injured (1) personally by reason of a violation of [RICO] if such injury results from an act indictable under sections 2251 and 2252 of this title (relating to sexual exploitation of children) ... [to] sue therefor." Smith, 276 F. Supp. 2d at 611 (quoting 132 Cong. Rec. E1983-01 (June 5, 1986) (statement of Rep. Siljander during extension of remarks)); Liberatore, 478 F. Supp. 2d at 755 (relying on Smith, 276 F. Supp. 2d at 611). As Smith concluded, "[t]his language ... indicates that it was not Congress's intent that a conviction under the other sexual exploitation statutes be a prerequisite to the initiation of a civil suit for damages," because the draft bill grounded the cause of action on "an act indictable' under the statute" instead of one that actually produced an indictment and conviction. Smith, 276 F. Supp. 2d at 612.
+
+Smith's analysis draws precisely the wrong conclusion from this unenacted draft language. After all, the law Congress actually passed did not contain the language on which Smith and Liberatore relied. Instead, it allowed only by minors injured by an actual "violation" of the predicate statutes to sue—not those who merely alleged that a defendant could have been indicted (but was neither indicted nor convicted) for conduct that allegedly breached those statutes. It is odd to treat the removal of language from draft legislation as proof that the enacted bill carried the same meaning. Instead, courts draw the opposite inference. Russello 464 U.S. at 23-24 ("Where Congress includes limiting language in an earlier version of a bill but deletes it prior to enactment, it may be presumed that the limitation was not intended.").
+
+Smith and Liberatore also relied on excerpts from a CRS report analyzing another early draft of the legislation. Smith, 376 F. Supp. 2d at 611 (citing 132 Cong. Rec. E3242-02 (Sept. 23, 1986) (statement of Rep. Green during extension of remarks)); see also Liberatore, 478 F. Supp. 2d at 755 (citing Smith). According to Smith, the CRS report stated that "violations are to be determined by a preponderance of the evidence. Successful plaintiffs are entitled to recover the cost of the suit, including a reasonable attorney's fee, from those found guilty of a violation." Id. (quoting 132 Cong. Rec. E3242-02 (Sept. 23, 1986)). Smith thus held that "Whe analysis of that proposed draft indicated that a violation under § 2255 was to be proven only by a preponderance of the evidence," and "indicates that 18 U.S.C. § 2255 was intended to provide a remedy ... without requiring a criminal conviction." Id. at 611-12.
+
+Set aside that Congress eventually deleted from the bill the preponderance-of-theevidence standard discussed in the CRS report; while that alone renders this portion of the CRS report irrelevant, the key point here is that Smith's analysis of the report is flawed on its own terms. To begin with, the fact that draft's proposed preponderance-of-the-evidence standard does not remotely prove that Congress sought to permit § 2255 actions in the absence of a predicate criminal conviction. To the contrary, requiring a prior criminal conviction is perfectly consistent with such a standard, since the plaintiff in a § 2255 case could simply introduce proof of the prior conviction and thereby discharge her burden of proving a violation under a preponderance-of-the-evidence standard. As a result, the (never adopted) preponderance-of-theevidence standard on its own sheds no light on the question.
+
+Moreover, the Smith court overlooked the key line in its quotation from the CRS report namely, the report's statement that the draft version of § 2255 would allow plaintiffs to recover penalties from "'those found guilty of a violation.'" Smith, 376 F. Supp. 2d at 611 (emphasis added) (quoting 132 Cong. Rec. E3242-02 (Sept. 23, 1986) (statement of Rep. Green during extension of remarks)). Needless to say, civil courts do not find defendants "guilty"—only criminal courts do. On this point, the report's explicit reference to adjudicated guilt in connection with the statute's use of the term "violation" provides clear and obvious evidence that Congress intended to require proof of a criminal violation as a precondition to suit.
+
+Finally—and perhaps most important—Smith's selective quotation from the CRS report omitted key language showing Congress's intent to require proof of an antecedent criminal conviction. Quoted in its entirety, the relevant portion of the CRS report explained:
+
+For purposes of this section, violations are to be determined by a preponderance of the evidence. Successful plaintiffs are entitled to recover the cost of the suit, including a reasonable attorney's fee, from those found guilty of a violation. Proposed § 2250(d) states that a defendant found guilty in any criminal proceeding brought by the United States under this chapter is estopped from denying the essential allegations of the criminal offense in any subsequent civil proceeding. Since the standard of proof in criminal cases, "beyond a reasonable doubt," is stronger than the "preponderance of the evidence" standard contained in proposed § 2255, this relieves the plaintiff from having to establish those facts which have already been proven under a higher standard of proof in a finalized criminal proceeding.
+
+132 Cong. Rec. E3242-02 (Sept. 23, 1986) (statement of Rep. Green) (emphasis added).
+
+As the omitted language makes clear, the whole point of the proposed preponderance-ofthe-evidence standard was that it would work hand-in-glove with the draft legislation's estoppel provision in order to ensure that plaintiffs would not have to replicate proof of guilt after the defendant was convicted in a prior criminal case. Thus, to the extent the draft bills that eventually led to § 2255 have any bearing on the meaning of the language that Congress actually enacted, the legislative history relied upon by Smith and Liberatore makes clear that Congress intended to authorize a "subsequent civil proceeding" only after a defendant had been convicted "beyond a reasonable doubt ... in a finalized criminal proceeding." Id. (emphasis added).
+
+At bottom, the plain text and legislative history clearly show that § 2255 authorizes an action only after the defendant has been convicted of violating a predicate criminal statute.
+
+## B. Defendant's Plea To Certain State-Law Offenses Is Insufficient To Authorize Suit Under 18 U.S.C. § 2255.
+
+The FAC seeks to overcome this hurdle by asserting that Defendant "entered pleas of 'guilty' to various Florida state crimes involving the solicitation of minors for prostitution and the procurement of minors for the purposes of prostitution [and therefore] is in the same position
+
+as if he had been tried and convicted of the sexual offenses committed against Plaintiff and, as such, must admit liability unto Plaintiff." FAC 124. While it generally is true that a complaint's allegations must be taken as true, "unwarranted deductions of facts or legal conclusions masquerading as facts will not prevent dismissal." Oxford Asset Mgnt., Ltd. v. Jaharis, 297 F.3d 1182, 1188 (11th Cir. 2002). Courts likewise may take note of public-record materials subject to judicial notice—even if those materials were not attached to the Complaint. Id. (citing cases).
+
+The key point, then, is that Defendant's plea to two single-count charges under Florida law (one involving solicitation of prostitution — without regard to the prostitute's age — and one involving procurement of a minor for prostitution) does not remotely establish that Defendant committed any offense against Plaintiff much less that Defendant was convicted of violating any predicate federal statute that can give ground liability under § 2255. The official Florida judgment of conviction contains no reference to Plaintiff. See Exh. A. The official transcript of Defendant's plea colloquy makes clear that the state-law offenses to which he pleaded guilty took place in 2004 and 2005—years after the events alleged to give rise to this case.
+
+THE COURT: State, please give me a factual basis.
+
+MS. BELOHLAVEK: In 069454 CF AMB, between August 1, 2004 and October 31, 2005, the defendant in Palm Beach County did solicit or procure someone to commit pros[titution] on three or more occasions. And in 08 CF 9381 CF AMB between August 1, 2004 and October 9, 2005, the defendant did procure a minor under the age of 18 to commit prostitution in Palm Beach County also.
+
+Exh. B at 41-42; compare id. with FAC 9 18 ("Plaintiff was first brought to Defendant's mansion in or about the spring of 2003.1 (emphasis added) and FAC ¶ 19 ("Defendant thereafter lured [Plaintiff] to [his home] on at least one and perhaps two other occasions in the spring and/or summer of 2003.") (emphasis added). These official records are subject to judicial notice, see, e.g., Coney v. Smith, 738 F.2d 1199, 1200 (11th Cir. 1984) (citing Moore v. Estelle, 526 F.2d 690, 694 (5th Cir. 1976)), and this Court can and should take note of them. Oxford Asset Mgnt., 297 F.3d at 1188.
+
+But even if Defendants' state-law pleas did involve state-law offenses against Plaintiff which they did not—§ 2255 only authorizes suit based on predicate convictions under certain federal statutes: "Any minor who is a victim of a violation of section 2241(c), 2242, 2243, 2251, 2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title ... may sue." 18 U.S.C. § 2255 (2003 & 2006). Needless to say, a conviction under Florida law is not a conviction under federal law, and there is no basis for accepting Plaintiffs assertion that Defendant's Florida pleas put him "in the same position as if he had been tried and convicted of the sexual offenses committed against Plaintiff and, as such, must admit liability unto Plaintiff." FAC ¶ 24. To reiterate, this Court may not accept "unwarranted deductions of facts or legal conclusions masquerading as facts" Oxford Asset Mgnt., 297 F.3d at 1188 (citing Fernandez-Montes, 987 F.2d at 284), and Plaintiffs contrary assertions "will not prevent dismissal." Id.
+
+Because Plaintiff has not alleged—and cannot allege—that Defendant has been convicted of committing a predicate federal criminal offense against her, the FAC must be dismissed.
+
+### III. COUNT ONE OF THE FAC MUST BE DISMISSED BECAUSE IT DOES NOT PLEAD A VIOLATION OF 18 U.S.C. § 2422(b).
+
+Count I of the FAC asserts a cause of action under 18 U.S.C. § 2255 predicated on a claim that Defendant violated 18 U.S.C. § 2422(b). As set forth above, this Count is legally unsustainable for the simple reason that Defendant has never been convicted of an offense under 18 U.S.C. § 2422(b). Supra at § II. In the alternative, Count I must be dismissed because the FAC does not make factual allegations that, even if true, would establish that Defendant violated § 2422(b) or that Plaintiff is the victim of such a violation. That statute provides:
+
+Whoever, using the mail or any facility or means of interstate ... commerce ... knowingly persuades, induces, entices, or coerces any individual who has not attained the age of 18 years, to engage in prostitution or any sexual activity for which any person can be charged with a criminal offense, or attempts to do so, shall be fined under this title and imprisoned.
+
+As the statute's text makes clear, the essence of this crime is the misuse of an interstate facility to communicate prohibited things—that is, the using of a means or facility of interstate commerce to persuade, induce, entice or coerce a person known by the defendant to be a minor to engage in prohibited sexual conduct—rather than the sexual conduct itself. As a result, the communication (the inducement of a known minor to engage in prohibited sexual conduct) must occur through the interstate facility (the mail, phone, or intemet)—not thereafter—and the scienter element must be present while the facility is being used. See United States v. Murrell, 368 F.3d 1283, 1286 (11th Cir. 2004) ("[T]he government must first prove that [Defendant], using the Internet, acted with a specific intent to persuade, induce, entice, or coerce a minor to engage in unlawful sex.") (emphasis added); United States v, Davis, 165 Fed. Appx. 586, 588 (10th Cir. 2006) ("[T]he government must show: `(1) use of a facility of interstate commerce; (2) to knowingly persuade, induce, entice, or coerce; (3) any individual who is younger than 18; (4) to engage in any sexual activity for which any person can be charged with a criminal offense, or attempting to do so.") (quoting United States v. Thomas, 410 F.3d 1235, 1245 (10th Cir. 2005)).
+
+A simple example illustrates this point. Suppose that a "John" walks to a downtown area where prostitutes are known to gather. He approaches several women, and asks each one how old she is. The first few women state that they are 18, but eventually one states that she is 16. The "John" then threatens to call the police unless she has intercourse with him. She does so; he pays her \$200 and walks away. There is no question that the "John" has knowingly solicited (and, indeed, coerced) prostitution from a minor in violation of state law. But there also is no question that the "John" cannot be convicted under 18 U.S.C. § 2422(b), because he did not use a facility of interstate commerce to coerce the victim: he merely talked to her in person. This point helps explain why the Eleventh Circuit recently noted that federal law "does not criminalize all acts of prostitution (a vice traditionally governed by state regulation)." United States v. Evans 476 F.3d 1176, n.1 (11th Cir. 2007); see also Offense Instruction 80, Eleventh
+
+Circuit Pattern Jury Instructions—Criminal (2003) (instructing jury that it must find beyond reasonable doubt that "the Defendant knowingly used [the mail] [a computer] [describe other interstate facility as alleged in indictment] to attempt to persuade, induce, entice [or coerce] an individual under the age of eighteen (18) to engage in sexual activity") (emphasis added).
+
+While the statute is unambiguous on this point, it bears note that this plain-text reading of the law finds additional support in the law's legislative history. Congress first enacted § 2422(b) as part of the Telecommunications Act of 1996 to combat sexual predators who solicit minors over the Internet. See H.R. Conf. Rep. No. 104-458, at 193 (1996) (expressing "the need for Congress to take effective action to protect children and families front online harm") (emphasis added); see also United States v. Searcy, 418 F.3d 1193, 1197 (11th Cir. 2005) (noting that Congress enacted § 2422(b) "after the Senate Judiciary Committee held a hearing regarding child endangerment via the Internet) (emphasis added). Prior to that time, § 2422 targeted only inducements to travel across state or national borders: "Whoever knowingly persuades, induces, entices or coerces any individual to travel in interstate or foreign commerce ... to engage in prostitution or any [criminal] sexual activity ... shall be fined under this title or imprisoned not more than five years, or both." 18 U.S.C. § 2422 (1995). With no nexus to use of an interstate instrumentality, the existing law did nothing to address the problem of internet predators, whose conduct might have nothing to do with interstate or transnational travel.
+
+Accordingly, when Congress added § 2422(b), it borrowed the predecessor statute's language about knowing persuasion, and—with an eye to online communications—criminalized the use of an interstate facility to knowingly persuade a minor to engage in otherwise unlawful conduct. Congress clearly was aiming at the use of the interne. to recruit minors into unlawful sexual activity—not in-person solicitation. See, e.g., 144 Cong. Rec. H4491-03, H4491 (statement of Rep. McCollum) (June 11, 1998) ("H.R. 3494 targets pedophiles who stalk children on the Internet. It prohibits contacting a minor over the Internet for the purposes of engaging in illegal sexual activity.").
+
+This simple point is dispositive. The FAC never alleges that Defendant "persuade[d], induce[d], entice[d], or coerce[d]" Plaintiff to engage in prohibited sexual conduct "using the mail or any facility or means of interstate or foreign commerce." 18 U.S.C. § 2422(b). It does not allege that Defendant ever mailed Plaintiff anything, much less that he coerced her to engage in prohibited sexual activity by doing so. It does not allege that Defendant ever called or textmessaged Plaintiff, much less that he coerced her to engage in prohibited sexual activity by doing so. It does not allege that Defendant ever e-mailed or instant-messaged Plaintiff, much less that he coerced her to engage in prohibited sexual activity using any intemet technology.
+
+To the contrary, the FAC alleges that Defendant's efforts to induce Plaintiff to engage in prohibited sexual conduct took place exclusively in person, without any use of an interstate means or facility. The FAC alleges that "in or about the spring of 2003," Plaintiff "was recruited by one of Defendant's agents to give Defendant a massage for compensation," and that Defendant's agent "drove [Plaintiff] to [Defendant's] mansion." FAC S 18. After she allegedly was led to the massage room, the FAC alleges that a topless woman "with dark hair [and] an accent ... tried to coax Plaintiff to remove her shirt." Id. Defendant entered the room, and eventually asked Plaintiff to massage his buttocks. Id. He then allegedly "ordered Plaintiff to remove her clothes," "began masturbating and fondling her breasts," and "asked her to do more," but "she adamantly declined." Id. She allegedly was paid \$200, and then driven away by Defendant's agent. Id. Plaintiff further alleges that she was "lured" to the mansion "on at least one and perhaps two other occasions in the spring and/or summer of 2003," but provides no details regarding those alleged encounters. Id. ¶ 19. Given the lack of any claim that Defendant used the mail, phone, or intemet to induce Plaintiff to engage in prohibited sexual conduct—and the FAC's admission that all alleged inducements and solicitations occurred in person, without use of an interstate instrumentality—Count One must be dismissed because it fails to provide
+
+factual allegations that, if true, would show that Plaintiff is the victim of a violation of § 2242(b).
+
+To be sure, Plaintiff does allege that "Defendant or an authorized agent would call and alert Defendant's assistants shortly before or after he arrived at his Palm Beach residence," FAC ¶ I I —just like any professional would alert his or her administrative assistant that he or she was coining to town. But Congress has not made that a crime, and even if Defendant's assistants later "would seek out economically disadvantaged and underage girls from West Palm Beach," id., it cannot reasonably be said that Defendant was "using the mail or any facility or means of interstate ... commerce [to] knowingly persuade[], induce[], entice[], or coerce[ a minor] to engage in prostitution or any sexual activity." 18 U.S.C. § 2242(b). Again, the statute only prohibits online or telephonic contact with minors—not with one's secretary.
+
+Nor is it sufficient that Plaintiff baldly asserts that Defendant "traveled to his mansion in Palm Beach for the purpose of luring minor girls," and "used the telephone to contact these minor girls for the purpose of coercing them into acts of prostitution." 18 U.S.C. § 2242(b). These bald allegations cannot survive a motion to dismiss. See Jabal, slip op. at 14 ("Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice."); Twombly, 550 U.S. at 561 (it is not enough that "the pleadings le[ave] open the possibility that a plaintiff might later establish some set of undisclosed facts to support recovery") (quotation and alteration omitted). And even if they could, these unsupported claims do not demonstrate that this Plaintiff is entitled to relief: whether or not Defendant ever used to phone to contact some minor, a bare allegation that he called someone, sometime, does not remotely establish that he called Plaintiff—much less that he used the phone to coerce Plaintiff into engaging in prohibited sexual contact.
+
+The bottom line is that Plaintiff would have alleged that Defendant called her and induced her over the phone to commit a prohibited sex act if she could, and she would have done so with at least the same amount of detail with which she has alleged the single encounter she
+
+describes. But she hasn't—because she can't—and Count I must be dismissed with prejudice.
+
+## IV. COUNT TWO MUST BE DISMISSED BECAUSE IT DOES NOT PLEAD A VIOLATION OF 18 U.S.C. § 2423(b).
+
+Count II of the FAC asserts a cause of action under 18 U.S.C. § 2255 predicated on a claim that Defendant violated 18 U.S.C. § 2423(6). Again, as set forth above, this Count is legally unsustainable for the simple reason that Defendant has never been convicted under § 2423(b). Supra at § II. In the alternative, Count II still must be dismissed because the FAC does not make factual allegations that, even if true, would establish that Defendant violated § 2423(b) or that Plaintiff is the victim of such a violation.
+
+As a threshold matter, however, it bears note that the FAC's factual allegations arc so vague that it cannot be determined which version of 18 U.S.C. § 2423(b) even applies to this Count. Prior to April 30, 2003,18 U.S.C. § 2423(b) provided that:
+
+A person who travels in interstate commerce, or conspires to do so, or a United States citizen or an alien admitted for permanent residence in the United States who travels in foreign commerce, or conspires to do so, for the purpose of engaging in any sexual act (as defined in section 2246) with a person under 18 years of age that would be in violation of chapter 109A if the sexual act occurred in the special maritime and territorial jurisdiction of the United States shall be fined under this title, imprisoned not more than 15 years, or both.
+
+18 U.S.C. § 2423(b) (2002) (emphasis added). On April 30, 2003, the Prosecutorial Remedies and Other Tools to end the Exploitation of Children Today Act of 2003, or "PROTECT Act," Pub. L. No. 108-21, 117 Stat. 650, became effective, and § 2423 was amended to read:
+
+A person who travels in interstate commerce or travels into the United States, or a United States citizen or an alien admitted for permanent residence in the United States who travels in foreign commerce, for the purpose of engaging in any illicit sexual conduct with another person shall be fined under this title or imprisoned not more than 30 years, or both.
+
+18 U.S.C. § 2423(b) (2003) (emphasis added).
+
+The obvious problem is that Plaintiff has not pleaded the dates on which the alleged travel or resulting sexual activity occurred. She merely alleges that she "was first brought to Defendant's mansion in or about the spring of 2003," FAC ¶ 18, and that she later was "lured ... to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003." Id. ¶ 19. Since these vague allegations leave open the possibility that the alleged predicate conduct could have occurred either before or after the PROTECT Act's effective date, it is impossible to determine what law governs. No matter how generously one construes the pleading standards, they at least require allegations that are sufficiently precise to permit the Court to determine what law governs. Yet without alleging any specific dates, the FAC falls well short of that mark and ought to be dismissed for that reason alone.
+
+Under either version of the statute, however, the key point is that § 2423 does not prohibit interstate travel that merely happens to result in illicit sexual conduct. Instead, the courts repeatedly have held that the statute applies only if the defendant's dominant motive for interstate travel was to engage in unlawful sexual activity. See, e.g., United States v. Tvkarsky, 446 F.3d 458, 471 (3d Cir. 2006) ("[T]he government must show that the criminal sexual act was a dominant purpose of the trip, not a merely incidental one.") (citing United States v. Hayward, 359 F.3d 631, 638 (3d Cir. 2004)) (emphasis added). That interpretation of the law is obviously correct. While § 2423(b) is relatively new—it first was enacted as part of the Violent Crime Control and Law Enforcement Act of 1994, Pub. L. No. 103-322, 108 Stat 1796, 2037—it was added to the Mann Act (first passed in 1910) and uses the identical "for the purpose of language set forth in the original version of that statute. See 18 U.S.C. § 2423(a) (1986). Accordingly, courts addressing § 2423(b) have relied on longstanding case law interpreting the Mann Act's use of the statutory phrase. See, e.g., United States v. Garcia-Lopez, 234 F.3d 217, 220 n.3 (5th Cir. 2000); United States v. yang, 128 F.3d 1065, 1069-70 (7th Cir. 1997); United States v. Ellis, 935 F.2d 385, 389-90 (1st Cir. 1991); see also United States v. Hoschouer, 224 Fed. Appx. 923, 926-27 (11th Cir. 2007) (unpublished opinion); cf. Gustafson v. Allovd Co.. Inc., 513 U.S. 561, 570 (1995) ("[W]e adhere[' to the normal rule ... that "identical words used in different parts of the same act are intended to have the same meaning.") (quotation and citation omitted).
+
+Two Mann Act cases are particularly apt. In Hansen v. Half, 291 U.S. 559 (1934), the Government charged the defendant with violating the Mann Act after she returned to the country with a man with whom she was having "illicit relations." Id. at 561. Despite the fact that the woman intended to "continue her irregular and improper conduct [after] returning," the Court held that she had not violated the Act: "People not of good moral character like others, travel from place to place and change their residence. But to say that, because they indulge in illegal or immoral acts, they travel for that purpose, is to emphasize that which is incidental and ignore what is of primary significance." Id. at 562-63. Likewise, in Mortensen v. United States, 322 U.S. 369 (1944), defendants were convicted after two women they employed as prostitutes at their Nebraska brothel traveled to Utah and back, where they resumed their unlawful activities. Id. at 372. Again, the Supreme Court reversed: "An intention that the women or girls shall engage in the conduct outlawed by [the Mann Act] must be found to exist before the conclusion of the interstate journey and must be the dominant motive of such interstate movement. And the transportation must be designed to bring about such result." Id. at 374.
+
+The FAC does not remotely allege that Defendant's dominant motive for traveling to Palm Beach "in or about the spring of 2003" was to engage in unlawful sexual activity. FAC ¶ 18. Instead, as the FAC makes clear, Defendant is a successful businessman who maintains homes and properties around the world. Id. q 8. Even if the FAC's fanciful allegations regarding Defendant's conduct while at those homes were true, the FAC does not remotely allege that his dominant motive for travel was to engage in illicit sexual acts (much less that he traveled with the dominant purpose of engaging in illicit activities with Plaintiff) or that his travel was specifically "designed to bring about such a result." Mortenson, 322 U.S. at 374. As lqbal and Twombly make clear, plaintiffs cannot withstand a motion to dismiss by baldy asserting that an offense occurred and holding out hope that they "might later establish some set of undisclosed
+
+facts" to support the claim. Instead, each element must be supported by an adequate factual allegation. Twombly, 550 U.S. at 561; see also Iqbal, slip op. at 14 ("The plausibility standard ... asks for more than a sheer possibility that a defendant has acted unlawfully. Where a complaint pleads facts that are `merely consistent with' a defendant's liability, it `stops short of the line between possibility and plausibility of `entitlement to relief."') (quoting Twombly, 550 U.S. at 557 (alteration in original)).
+
+Indeed, Twombly itself supplies an excellent parallel. Plaintiffs there alleged that the defendants engaged in coordinated activities that violated the antitrust laws, and asserted that defendants thus must have agreed to restrain trade. As the Court observed, however, plaintiffs' otherwise specific allegations of parallel conduct were as likely innocent as they were consistent an agreement to restrain trade:
+
+[Ain allegation of parallel conduct and a bare assertion of conspiracy will not suffice. Without more, parallel conduct does not suggest conspiracy, and a conclusory allegation of agreement at some unidentified point does not supply facts adequate to show illegality. Hence, when allegations of parallel conduct are set out..., they must be placed in a context that raises a suggestion of a preceding agreement, not merely parallel conduct that could just as well be independent.
+
+Id. at 556-57.
+
+So too here. The mere fact that Defendant traveled between his residences and allegedly engaged in illicit conduct while at his homes hardly suggests that the dominant purpose of his travel was to engage in illicit sexual activity. Instead, Defendant's travel is equally consistent with the truth: that his vast business operations and charitable activities required frequent travel, and that any sexual activity—legal or not—that occurred was incidental to the legitimate purposes that motivated his trips. See, e.g., Hansen, 291 U.S. at 562-63 ("[TJo say that, because [persons) indulge in illegal or immoral acts, they travel for that purpose, is to emphasize that which is incidental and ignore what is of primary significance."). Without more, the FAC thus fails to allege facts that, even if true, would establish that Defendant engaged in the sort of sex
+
+tourism that violates 18 U.S.C. § 2423(b), or that Plaintiff herself is the victim of such an offense. See Twombly, 550 U.S. at 557. Count II muse be dismissed.
+
+## V. COUNT THREE MUST BE DISMISSED BECAUSE IT DOES NOT PLEAD A VIOLATION OF 18 U.S.C. § 2251.
+
+Count III of the FAC asserts a cause of action under 18 U.S.C. § 2255 predicated on allegations that Defendant violated 18 U.S.C. § 2251. Again, as set forth above, this Count is legally unsustainable for the simple reason that Defendant has never been convicted under § 2251. Supra at § II. In the alternative, Count III still must be dismissed because the FAC does not make factual allegations that, even if true, would establish that Defendant violated 18 U.S.C. § 2251 or that Plaintiff is the victim of such a violation.
+
+Yet again, Plaintiff's failure adequately to plead the dates on which the alleged predicate conduct occurred makes it impossible to detennine which version of § 2251 applies in this case. Prior to April 30, 2003, § 2251 provided that:
+
+Any person who employs, uses, persuades, induces, entices, or coerces any minor to engage in ... any sexually explicit conduct for the purpose of producing any visual depiction of such conduct, shall be punished ... if such person knows or has reason to know that such visual depiction will be transported in intestate or foreign commerce or mailed, if that visual depiction was produced using materials that have been mailed, shipped, or transported in interstate or foreign commerce by any means, including by computer, or if such visual depiction has actually been transported in interstate or foreign commerce or mailed.
+
+18 U.S.C. § 2251 (2002) (emphasis added). As with § 2423(b), however, Congress made significant changes to the statute when the PROTECT Act became effective on April 30, 2003:
+
+My person who employs, uses, persuades, induces, entices, or coerces any minor to engage in ... any sexually explicit conduct for the purpose of producing any visual depiction of such conduct or for the purpose of transmitting a live visual depiction of such conduct, shall be punished ... if such person knows or has reason to know that such visual depiction will be transported or transmitted using any means or facility of interstate or foreign commerce or in or affecting interstate or foreign commerce or mailed, if that visual depiction was produced or transmitted using materials that have been mailed, shipped, or transported in or affecting interstate or foreign commerce by any means, including by computer, or if such visual depiction has actually been transported or transmitted using any means or facility of interstate or foreign commerce or in or affecting interstate or foreign commerce or mailed.
+
+18 U.S.C. § 2251 (2003) (emphasis added; underscored to denote amended text).
+
+Under either version, however, Count III must be dismissed because Plaintiff fails to plead that Defendant's dominant motive for enticing her to engage in sexual conduct was to produce images of that conduct; that Defendant actually produced an image of Plaintiff; or that Defendant either knew that the resulting images would be transported in interstate commerce or actually transported or transmitted those photographs in interstate commerce. Instead, the FAC alleges only that Defendant displayed photos of other women in his homes and on his computer, see FAC at ¶¶ 14 & 16, and "may have taken lewd photographs of Plaintiff ... and may have transported lewd photographs of Plaintiff ... to his other residences and elsewhere using a facility or means of interstate and/or foreign commerce." Id. ¶¶ 16 & 34 (emphasis added).
+
+Those speculative assertions are insufficient to sustain Plaintiff's burden at the pleading stage. In our legal system, defendants cannot properly be subjected to the burden and expense of discovery—and the accompanying pressure to settle��based on claims that they "may have" done something wrong. Instead, "the complaint's allegations must plausibly suggest that the plaintiff has a right to relief, raising that possibility above a speculative level; if they do not, the plaintiffs complaint should be dismissed." James River Ins. Co. v. Ground Down Ena'a, Inc., 540 F.3d 1270, 1274 (11th Cir. 2008) (citation and quotation omitted); see also Iqbal, slip op. at 15 (complaint must be dismissed "where the well-pleaded facts do not permit the court to infer more than the mere possibility of misconduct") (emphasis added); Bawa v. U.S., No. C 07- 00200 WHA, 2007 WL 1456040, \*5 (N.D. Cal. May 17, 2007) (dismissing complaint alleging that defendant "may have played a substantial role" in the underlying crime).
+
+Plaintiff has not remotely alleged that a crime actually was committed, and if she could have done so in good faith, there is little doubt that she would have. Having failed to push her claims from the realm of the possible into the realm of the plausible, there is no basis for allowing Plaintiff to proceed. Count III must be dismissed with prejudice.
+
+## VI. COUNTS FOUR AND FIVE MUST BE DISMISSED BECAUSE THEY DO NOT PLEAD VIOLATIONS OF 18 U.S.C. §§ 2252(aX1) OR 2252A(aX1).
+
+Count IV of the FAC asserts a cause of action under 18 U.S.C. § 2255 predicated on allegations that Defendant violated 18 U.S.C. § 2252(aX1). Count V of the FAC asserts a cause of action under 18 U.S.C. § 2255 predicated on allegations that Defendant violated 18 U.S.C. § 2252A(a)(1). Again, as set forth above, these Counts are legally unsustainable for the simple reason that Defendant has never been convicted under § 2252(aXI) or § 2252A(a)(1). Supra at § II. In the alternative, Counts IV and V still must be dismissed because the FAC does not make factual allegations that, even if true, would establish that Defendant violated either statute or that Plaintiff is a victim of such a violation. By its plain terms, § 2252(aX1) provides:
+
+Any person who ... knowingly transports or ships using any means or facility of interstate or foreign commerce ... any visual depiction, if ... the producing of such visual depiction involves the use of a minor engaging in sexually explicit conduct and ... such visual depiction is of such conduct ... shall be punished as provided in subsection (b) of this section.
+
+18 U.S.C. § 2252(a)(1) (2002 & 2003) (emphasis added). Similarly, the pre- and post-PROTECT Act versions of § 2252A(aX1) provide:
+
+Any person who ... knowingly mails, or transports or ships in interstate or foreign commerce by any means, including by computer, any child pornography ... shall be punished as provided [by law].
+
+18 U.S.C. § 2252A(aX1) (2002 & 2003) (emphasis added). In turn, the term "child pornography" was defined both pm- and post-PROTECT Act, and in relevant part, as:
+
+any visual depiction, including any photograph, film, video, picture, or computer or computer-generated image or picture... of sexually explicit conduct, where ... the production of such visual depiction involves the use of a minor engaging in sexually explicit conduct.
+
+18 U.S.C. § 2256(8) (2002 & 2003).
+
+As with Count III, however, the MC does not remotely allege that Plaintiff is a victim of a violation of §§ 2252(aX1) or 2252A(aX1). Instead, the FAC alleges only that Defendant
+
+displayed photos of other unidentified women in his homes and on his computer, see FAC at 111 14 & 16, and "may have taken lewd photographs of Plaintiff ... with his hidden cameras and may have transported lewd photographs of Plaintiff ... to his other residences and elsewhere using a facility or means of interstate and/or foreign commerce." FAC ¶1 16, 38, 43 (emphasis added). Again, it simply is not enough to allege that Defendant "may have" done something wrong: "the complaint's allegations must plausibly suggest that the plaintiff has a right to relief, raising that possibility above a speculative level; if they do not, the plaintiff's complaint should be dismissed." James River Ins. Co., 540 F.3d at 1274 (citation and quotation omitted); see also lqbal, slip op. at 15 (holding the a complaint must be dismissed "where the well-pleaded facts do not permit the court to infer more than the mere possibility of misconduct") (emphasis added). Because the FAC only speculates that Defendant "may have" committed a crime, and because Plaintiff surely would have charged that Defendant actually committed a crime if she had a good-faith basis for doing so, Counts IV and V must be dismissed with prejudice.
+
+### VII. COUNT SIX MUST BE DISMISSED BECAUSE 18 U.S.C. § 2252A(g) WAS NOT ENACTED UNTIL 2006.
+
+Count VI of the FAC asserts a cause of action under 18 U.S.C. § 2255 predicated on allegations that Defendant violated 18 U.S.C. § 2252A(g). Again, as set forth above, this Count is legally unsustainable for the simple reason that Defendant has never been convicted under § 2251. Supra at § H. In the alternative, Count VI still must be dismissed because § 2252A(g) was not enacted until 2006—three years after the alleged conduct underlying this case took place. See Pub. L. 109-248, Title VII, § 701, July 27, 2006, 120 Stat. 614, 647. As set forth above, supra § I.B.2, the Ex Post Facto Clause flatly precludes the application of new statutes to conduct completed prior to the statute's enactment, and there is any event no indication that Congress intended to apply this provision of the Adam Walsh Act retroactively to completed conduct. See supra § 1.8.1 (noting that Congress expressly made certain provisions of the Adam Walsh Act retroactive, but not others). Thus, while Plaintiff has not adequately pleaded a violation of § 2252A(g) in the first place, there is no lawful basis under which she could assert a cause of action predicated on that statute. Count VI must be dismissed with prejudice.
+
+## VIII. ANY SURVIVING COUNTS SHOULD BE MERGED INTO A SINGLE COUNT.
+
+While we respectfully submit that none of the FAC's counts are viable and that each should be dismissed with prejudice, this Court should require the merger of all claims into a single count to the extent it rejects the foregoing analysis and allows more than one count to proceed. Contrary to Plaintiff's attempt to multiply her recovery by asserting six separate counts, § 2255 creates a single cause of action with a single penalty for all violations of a predicate offense, not separate causes of action and separate recoveries on a "per violation" basis. We have not found a single precedent where a § 2255 plaintiff has been allowed to assert claims on a "per violation" basis—each of the prior cases (including the prior cases involving this defendant in this Court) involved a single count predicated on multiple alleged violations of predicate criminal statutes. See Tilton v. Playboy Entertainment Grotto. Inc., 554 F.3d 1371 (11th Cir. Jan. 15, 2009); Smith, 428 F. Supp. 2d at 432; Doe, 478 F. Supp. 2d at 754; Doe No. 2 v. Epstein, 2009 WL 383332 (S.D. Fla. Feb. 12, 2009); Poe No. 3 v. Epstein, 2009 WL 383330 (S.D. Fla. Feb. 12, 2009); Doe No. 4 v. Epstein, 2009 WL 383286 (S.D. Fla. Feb. 12, 2009); and Poe No. 5 v. Epstein 2009 WL 383383 (S.D. Fla. Feb. 12, 2009).
+
+There is no basis for indulging Plaintiff's contrary approach. Instead, the plain language and structure of the statute foreclose Plaintiff's unprecedented approach. First, the order of the two sentences establishing the statutory penalty under § 2255(a) demonstrate that Congress did not mean to allow for a minimum mandatory recovery in the amount of \$50,000 for each predicate violation. The first sentence provides that "[a]ny person who ... suffers personal injury as a result of such violation ... shall recover the actual damages such person sustains and the cost of the suit, including a reasonable attorney's fee." 18 U.S.C. § 2255(a) (emphasis added).
+
+Then, in recognition of the fact that damages in these cases may be hard to prove, the second sentence provides for recovery of a minimum amount: "Any minor as described in the preceding sentence shall be deemed to have sustained damages of no less than \$50,000." Id. Together, these provisions indicate that Congress intended to provide restitution to victims—that is, to award them "actual damages"—but that where actual damages were less than \$50,000 or otherwise impossible to prove, the statute would guarantee a lump-sum, make-whole penalty of \$50,000 for all injuries sustained as a result of the predicate acts.
+
+Moreover, the fact that Congress did not expressly provide for damages on a "per violation" basis further underscores the fact that Congress sought to provide only a lump-sum recovery for all injuries sustained by a victim. After all, while Congress knows exactly how to provide for damages on a "per violation" basis when it wants to, it did not do so here. See, e.g., 18 U.S.C. § 216 (authorizing a "civil action ... against any person who engages in conduct constituting an offense under" specified sections of the bribery, graft, and conflicts of interest statutes, and authorizing "a civil penalty of not more than \$50,000 for each violation or the amount of compensation which the person received or offered for the prohibited conduct, which ever amount is greater") (emphasis added); see also 18 U.S.C. § 49; 18 U.S.C. § 1034; 18 U.S.C. § 2318. As the Eleventh Circuit repeatedly has explained, "where Congress knows how to say something but chooses not to, its silence is controlling." Delgadq\_v. United States Att'y Gen., 487 F.3d 855, 862 (11th Cir. 2007) (quoting CBS. 245 F.3d at 1226 (itself quoting Griffith, 206 F.3d at 1394 with citation and quotations omitted))) (alteration omitted).
+
+Because the statute provides a single cause of action with a single remedy, this Court should order Plaintiff to merge all surviving claims—if any—into a single count.
+
+**Certificate of Service**
+
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this 26th day of May, 2009
+
+Robert C. Josefsberg, Esq.  
+Katherine W. Ezell, Esq.  
+Podhurst Orseck, P.A.  
+25 West Flagler Street, Suite 800  
+Miami, FL 33130  
+305 358-2800  
+Fax: 305 358-2382  
+rjosefsberg@podhurst.com  
+kezell@podhurst.com  
+*Counsel for Plaintiff*
+
+Jack Alan Goldberger, Esq.  
+Atterbury Goldberger & Weiss, P.A.  
+250 Australian Avenue South  
+Suite 1400  
+West Palm Beach, FL 33401-5012  
+561-659-8300  
+Fax: 561-835-8691  
+jagesq@bellsouth.net  
+*Counsel for Defendant Jeffrey Epstein*
+
+Respectfully submitted:
+
+By:
+

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marker2-fixhub/ds9/EFTA00189785/EFTA00189785.md

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+U.SAO System — Microsoft Outlook:
+
+Email Messages
+
+O Notes
+
+IS Calendar items
+
+O Public Folders
+
+# USER LITIGATION HOLD NOTICE AND CERTIFICATION FORM
+
+### PRIVACY ACT PROTECTED
+
+### I. NOTICE
+
+Please be advised that, by and through this Notice, we, the United States Attorney's Office for the Southern District of Florida ("USAO"), have instituted a 'Litigation Holt in connection with the claims set forth in Jane Does #1 and #21 United States, Case No.: 08-80736-CIV-MARRA/Johnson regarding alleged violation of the petitioners' rights under the Crime Victim's Rights Act ("CVRA").
+
+To institute this Litigation Hold, we are implementing preservation procedures regarding any and all records, data, or other information, whether they exist In paper form or as electronically stored information (-ESI"), within the USAO's possession. custody or control relating to the Complaint/Claims (collectively, "Information"). The USAO's obligation to preserve this information pertains not only to paper copies, or "hard copies" (whether in draft or final, partial or complete, versions), but also to ESI in its originally-created, or "native" format, as it exists on any computer system (whether it be on the USAO's system or your personal computer), as well as removable or portable electronic storage media. Specific examples of information subject to this Litigation Hold include, but are not limited to, e-mails and other electronic communications, word processing documents, records, spreadsheets, databases, calendars, telephone logs, Internet usage files, network access Information, and Information on other kinds of media, including PDAs (such as Palm Pilots, BlackBerries, and cell phones), thumb drives, CDs, as well as digital voicemail and text messages.
+
+Because the USA° must take reasonable steps to preserve such information in whatever form it has been created and maintained, the USAO's Ut Hold Coordinator and Systems Manager must coordinate with all those who may have such Information. We therefore require your assistance to both identify and preserve any and all Information relating to the Complaint/Claims, whether or not the Information is ultimately discoverable. Furthermore, we must confirm that you understand and accept your preservation obligations under this Litigation Hold.
+
+Accordingly, you are required to take the two following steps: (1) Identify to us all such information and where It resides (in Section Ii below); and (2) Certify having received notice of this Litigation Hold and understanding and accepting your preservation obligations under this Litigation Hold (in Section III below). [NOTE: While seeking to identify all such In motion, please refrain to the maximum extent possible from opening entails/files u believe to be relevant.)
+
+## II. IDENTIFY ALL INFORMATION SUBJECT TO THE LITIGATION HOLD
+
+Please identify all locations where the Information described above may exist: CHECK ALL THAT APPLY
+
+Hord Copy Clocumenti: S Printed Emails NI Case Files/Logs O Calendars/Appointment Books O Other
+
+I./SAOSystem - EVoiP:
+
+0 Tasks O Telephone Data
+
+O Contacts
+
+O PST Files ("Archive") O Office Communicator
+
+(continued on next page)
+
+(continued from previous page)
+
+USAO System —Network Data li.e, documents/files and folders r siding on network drives(:
+
+El Personal (N, H & M) Drive Document/Files/Folders ❑ Shared Files/Folders ❑ UONs/Alcatraz/USA-5 ❑ Inter- and Intr•net ❑ Other
+
+IMO System —Mobile PIWSMS: USAO System —Classified/Spec/of Doto:
+
+❑ Blackberry/Other ❑ Document/Files/Folders/Other
+
+Non-Network Data documents/files and folders residina on local hard drives and thumb drives)•
+
+❑ Local (C & D) Drives ❑ Portable Media/Thumb Drives ❑ Deleted Items (Recycle Bin)
+
+personal Non-Network Data /located or residina somewhere other than the MAO System(:
+
+❑ Document/Files/Folders ❑ Internet ❑ Email Messages ❑ Portable Media/Thumb Drives ❑ PDAs/Other
+
+### III. CERTIFICATION
+
+By this Notice and Certification, I acknowledge that I have received, understand, and accept my obligations to preserve any and all Information (as defined above) I may have now, as well as all such Information I may subsequently receive, create or modify. I further understand and accept that my continuing Litigation Hold obligations require that I preserve all such Information in "native" format and, conversely, that I not delete or destroy any such Information until I receive formal written notice that this Litigation Hold is discontinued. To fulfill these continuing obligations, I will undertake the necessary steps to preserve this Information, be it "hard copy" and/or ESI, in coordination with the USAO's Lit Hold Coordinator and Systems Manager.
+
+en
+
+Please be advised that failure to preserve and retain this Information may result in sanctions and/or implicate professional conduct rules. Consequently, if you are unsure whether certain information should be preserved, err on the side of caution and preserve the information until you have spoken to the USAO's Lit Hold Coordinator about it. If you have any questions about whether to preserve certain ESI, or its native formatting, please contact the USAO's Ut Hold Coordinator or Systems Manager.
+
+Please sign below to acknowledge you have read this Notice and Certification and understand and accept your preservation obligations, then return the executed copy to the USAO's Ut Hold Coordinator. Thank you.
+
+User Signat
+
+![](_page_1_Picture_17.jpeg)
+
+Date of User gnature:
+
+ff ' 5V/ 0
+
+cc: USAO Lit old Coordinator National Preservation Officer USAO Systems Manager
+
+INFORMATION CONTAINED IN THIS FORM MAY CONSTITUTE PRIVATE, CONFIDENTIAL AND/OR SENSITIVE, AS WELL AS PERHAPS ALSO PRIVILEGED AND/OR OTHERWISE PROTECTED, INFORMATION

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