diff --git "a/vision-fixhub/ds9-unparsed-05/9f0eb34b7878d57a070d539fe70d0dce7643f2e6f19f4eabecf3f96445da1d3c.md" "b/vision-fixhub/ds9-unparsed-05/9f0eb34b7878d57a070d539fe70d0dce7643f2e6f19f4eabecf3f96445da1d3c.md" new file mode 100644--- /dev/null +++ "b/vision-fixhub/ds9-unparsed-05/9f0eb34b7878d57a070d539fe70d0dce7643f2e6f19f4eabecf3f96445da1d3c.md" @@ -0,0 +1,2012 @@ +UNITED STATES OF AMERICA +VS. +JEFFREY EPSTEIN, +Defendant. +/ +PLEA AGREEMENT +The United States Attorney for the Southern District of Florida ("the United +States"), and Jeffrey Epstein (hereinafter referred to as the "defendant") enter into the +following agreement: +The defendant agrees to plead guilty to the Information which charges the +defendant with two counts of knowingly and intentionally violating the privacy protection +accorded to child victims by 18 U.S.C. § 3509; in violation of Title 18, United States +Code, Section 403. +The defendant is aware that the sentence will be imposed by the Court after +considering the Federal Sentencing Guidelines and Policy Statements (hereinafter +"Sentencing Guidelines"). The defendant acknowledges and understands that the Court +will compute an +advisory sentence under the Sentencing Guidelines and that the +applicable guidelines will be determined by the Court relying in part on the results of a +Pre-Sentence Investigation by the Court's probation office, which investigation will +commence after the guilty plea has been entered. The defendant is also aware that, under +9/13/2007 6:36pm +1 + + +certain circumstances, the Court may depart from the advisory sentencing guideline range +that it has computed, and may raise or lower that advisory sentence under the Sentencing +Guidelines. The defendant is further aware and understands that the Court is required to +consider the advisory guideline range determined under the Sentencing Guidelines, but is +not bound to impose that sentence; the Court is permitted to tailor the ultimate sentence in +light of other statutory concerns, and such sentence may be either more severe or less +severe than the Sentencing Guidelines' advisory sentence. Knowing these facts, the +defendant understands and acknowledges that the Court has the authority to impose any +sentence within and up to the statutory maximum authorized by law for the offenses +identified in paragraph 1 and that the defendant may not withdraw the plea solely as a +result of the sentence imposed +3. +The defendant further understands and acknowledges that, as to cach of +Counts 1 and 2 of the Information, the Court may impose a statutory maximum term of +imprisonment of up to one (1) year, to be followed by a term of supervised release of up +to a maximum of one (1) year. In addition to terms of imprisonment and supervised +release, the Court may impose a fine of up to $100,000 as to each count. +4. +The defendant further understands and acknowledges that, in addition to +any sentence imposed under paragraph 3 of this Agreement, a special assessment in the +amount of $50 will be imposed on the defendant, which must be paid at or before the +time of sentencing. +The defendant understands that the Court will order that he must pay full +restitution to all victims of the offense to which he is pleading guilty. The defendant +understands that the amount of restitution owed to cach victim will be determined at or +before sentencing. +The defendant agrees that, if any of the victims identified in the federal +investigation file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the +2 +• + + +jurisdiction of the U.S. District Court for the Southern District of Florida over his person and/or +the subject matter, and the defendant will not contest that the identified victims are persons who, +while minors, were victims of violations of Title 18, United States Code, Sections(s) 2422 and/or +2423. The United States agrees to provide the defendant's attorneys with a list of the identified +victims, which will not exceed forty, after the defendant has signed this agreement and has been +sentenced. The United States further agrees to make a motion with the United States District +Court for the Southern District of Florida for the appointment of a guardian ad litem for the +identified victims and the defendant's counsel may contact the identified victims through that +guardian. +The defendant agrees to plead guilty (not nolo contendere) to an Information +filed by the Palm Beach County State Attorney's Office charging an offense for which the +defendant must register as a sex offender, that is, solicitation of minors to engage in prostitution, +in violation of Fl. Stat. 796.03. The defendant and the Palm Beach County State Attorney's +Office shall make a joint, binding recommendation that the Court impose a sentence of at least +thirty (30) months, to be divided as follows: +(a) +the defendant shall begin by serving at least twenty (20) months in prison, +without any opportunity for withholding adjudication or sentencing, and +without probation or community control in lieu of imprisonment; and +(b) +following the term of imprisonment, the defendant shall serve ten (10) +months of community control/home confinement with electronic +monitoring. +8. +The defendant 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 in the state +court. +The defendant shall provide to the U.S. Attorney's Office copies of all proposed +3 + + +agreements with the Palm Beach County State Attorney's Office prior to entering into those +agreements. +The United States reserves the right to inform the Court and the probation +office of all facts pertinent to the sentencing process, including all relevant information +concerning the offenses committed, whether charged or not, as well as concerning the +defendant and the defendant's background, and to respond to any questions from the +Court and the Probation Office and to any misstatements of fact or law. Subject only to +the express terms of any agreed-upon sentencing recommendations contained in this +Agreement, this Office further reserves the right to make any recommendation as to the +quality and quantity of punishment. +11. The defendant is aware that the sentence has not yet been determined by the +Court. The defendant also is aware that any estimate of the probable sentencing range or +sentence that the defendant may receive, whether that estimate comes from the +defendant's attorney, the government, or the probation office, is a prediction, not a +promise, and is not binding on the government, the probation office or the Court. The +defendant understands further that any recommendation that the government makes to the +Court as to sentencing, whether pursuant to this agreement or otherwise, is not binding on +the Court and the Court may disregard the recommendation in its entirety. The defendant +understands and acknowledges, as previously acknowledged in paragraph 2 above, that +the defendant may not withdraw his plea based upon the Court's decision not to accept a +sentencing +recommendation made by the defendant, the government, or a +recommendation made jointly by both the defendant and the government. +12. +WAIVER OF RIGHT TO APPEAL AND COLLATERALLY +ATTACK THE SENTENCE. The defendant is aware that Title 18, United States Code, +Section 3742 affords the defendant the right to appeal the sentence imposed in this case. +Acknowledging this, in exchange for the undertakings made by the United States in this +4 + + +plea agreement, +the defendant hereby waives all rights conferred by Section 3742 to +appeal any sentence imposed, including any restitution order, or to appeal the manner in +which the sentence was imposed, unless the sentence exceeds the maximum permitted by +statute or is the result of an upward departure or upward variance from the guideline +range that the Court establishes at sentencing. The defendant further voluntarily and +expressly waives, to the maximum extent permitted by federal law, the right to +collaterally attack his sentence in any postconviction proceeding, including a motion on any ground brought under 28 U.S.C. § +2254, 28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18 U.S.C. § 3771. The defendant further +understands that nothing in this agreement shall affect the government's right and/or duty +to appeal as set forth in Title 18, United States Code, Section 3742(b). However, if the +United States appeals the defendant's sentence pursuant to Section 3742(b), the defendant +shall be released from the above waiver of appellate rights. By signing this agreement, +the defendant acknowledges that he has discussed the appeal waiver set forth in this +13. +If the defendant fails in any way to fulfill each one of his obligations under +this Plea Agreement, +, the United States, and only the United States, may elect to be +released from its commitments under this Plea Agreement. If the United States elects to +void the Plea Agreement because of a breach by the defendant, then the United States +agrees not to use the defendant's guilty plea against him. However, the United States +may prosecute the defendant for any and all Federal crimes that he has committed related +to this case and may seek any sentence for such crimes up to and including the statutory +maximums. +The defendant expressly waives any statute of limitations defense and any +constitutional or statutory speedy trial defense to such a prosecution, except to the extent +that such a defense exists as of the date he signs this Plea Agreement. Finally, the +defendant understands that his violation of the terms of this Plea Agreement would not +5 + + + + +14. This is the entire agreement and understanding between the United States +and the defendant. There are no other agreements, promises, representations, or +BY: R. ALEXANDER ACOSTA +UNITED STATES ATTORNEY +7 + + +UNITED STATES OF AMERICA +VS. +JEFFREY EPSTEIN, +Defendant. +PLEA AGREEMENT +The United States Attorney for the Southern District of Florida ("the United +States"), and Jeffrey Epstein (hereinafter referred to as the "defendant") enter into the +following agreement: +The defendant agrees to plead guilty to a two-count Information which +charges that the defendant intentionally harassed two other persons, that is, S.K. and +N.M., in an attempt to delay, prevent, and dissuade those persons from reporting to a law +enforcement officer of the United States the commission of a federal offense; in violation +of Title 18, United States Code, Sections 1512(d)(2) and 2. +2. +The defendant agrees and understands that the above charges involve his +conduct, and the criminal conduct of others, between in and around early 2001 through in +and around September 2007. This agreement resolves the federal criminal liability of the +defendant and any co-conspirators in the Southern District of Florida growing out of any +criminal conduct by those persons known to the United States Attorney's Office for the +Southern District of Florida as of the date of this plea agreement. +9/20/2007 3:52pm +1 +ETA00194612 + +The United States agrees that, upon entry of the defendant's guilty plea, its +Grand Jury investigation will be suspended, and all pending litigation between the parties +will be held in abeyance unless and until the defendant violates any term of this +agreement, as explained in paragraph 18, infra. Both parties agree to maintain their +evidence inviolate until all of the terms of this agreement have been satisfied. +4. +The defendant is aware that the sentence will be imposed by the Court after +considering the Federal Sentencing Guidelines and Policy Statements (hereinafter +"Sentencing Guidelines"). The defendant acknowledges and understands that the Court +will compute an advisory sentence under the Sentencing Guidelines and that the +applicable guidelines will be determined by the Court relying in part on the results of a +Pre-Sentence Investigation by the Court's probation office, which investigation will +commence after the guilty plea has been entered. The defendant is also aware that, under +certain circumstances, the Court may depart from the advisory sentencing guideline range +that it has computed, and may raise or lower that advisory sentence under the Sentencing +Guidelines. The defendant is further aware and understands that the Court is required to +consider the advisory guideline range determined under the Sentencing Guidelines, but is +not bound to impose that sentence; the Court is permitted to tailor the ultimate sentence in +light of other statutory concerns, and such sentence may be either more severe or less +severe than the Sentencing Guidelines' advisory sentence. Knowing these facts, the +defendant understands and acknowledges that the Court has the authority to impose any +sentence within and up to the statutory maximum authorized by law for the offenses +identified in paragraph 1 and that the defendant may not withdraw the plea solely as a +result of the sentence imposed. +The defendant further understands and acknowledges that, as to cach of +Counts 1 and 2 of the Information, the Court may impose a statutory maximum term of +imprisonment of up to one (1) year, to be followed by a term of supervised release of up +2 + + +to a maximum of one (1) year. In addition to terms of imprisonment and supervised +release, the Court may impose a fine of up to $100,000 as to each count. +The defendant further understands and acknowledges that, in addition to +any sentence imposed under paragraph 4 of this Agreement, a special assessment in the +amount of $50 will be imposed on the defendant, which must be paid at or before the +time of sentencing. +The defendant understands that the Court will order that he must pay full +restitution to all victims of the offenses to which he is pleading guilty. The defendant +understands that the amount of restitution owed to each victim will be determined at or +before sentencing. +8. +The parties agree to jointly recommend that the defendant receive a +sentence of eighteen (18) months' imprisonment, to be followed by one (1) year of +supervised release, and a fine of $200,000. The parties' further agree to jointly +recommend that the Court impose one year of home confinement as a special condition of' +supervised release. +The defendant agrees that, if any of the victims identified in the federal +investigation file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the +jurisdiction of the U.S. District Court for the Southern District of Florida over his person +and/or the subject matter, and the defendant will not contest that the identified victims are +persons who, while minors, were victims of violations of Title 18, United States Code, +Sections(s) 2422 and/or 2423. The United States agrees to provide the defendant's +attorneys with a list of the identified victims, which will not exceed forty, after the +defendant has signed this agreement and has been sentenced. The United States further +agrees to make a motion with the United States District Court for the Southern District of +Florida for the appointment of a guardian ad litem for the identified victims and the +defendant's counsel may contact the identified victims through that guardian. +3 + + +10. The United States has reached this agreement with the defendant in +response to the defendant's request to globally resolve his state and federal criminal +liability. To do so, the defendant further understands and acknowledges that he must +undertake certain actions with the State Attorney's Office for the 15th Judicial Circuit in +and for Palm Beach County (hereinafter, "State Attorney's Office"). +In addition to entering a guilty plea in the instant case, the defendant agrees +that, prior to his sentencing on the federal charges, he will plead guilty to an Information +filed by the State Attorney's Office charging an offense for which the defendant must +register as a sex offender, that is, solicitation of minors to engage in prostitution, in +violation of FI. Stat. 796.03. The defendant agrees that he will waive all challenges to the +Information filed by the State Attorney's Office and waive the right to appeal his +conviction and sentence in the state court. +12. The defendant agrees that he will make a binding recommendation that the +15th Judicial Circuit Court impose a sentence of at least eighteen (18) months' +imprisonment to be followed by at least twelve (12) months of community control/home +confinement to be served upon the defendant's release from federal prison. The +defendant further represents that he has had discussions with the State Attorney's Office, +which has agreed to likewise make this recommendation. The sentences imposed by the +15th Judicial Circuit Court may run concurrently with the federal sentence imposed +pursuant to this agreement. +13. +The defendant agrees to 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. +The defendant agrees that the timely completion of these actions 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 +4 + + +investigate and prosecute the defendant for any and all federal offenses. +15. +The United States reserves the right to inform the Court and the probation +office of all facts pertinent to the sentencing process, including all relevant information +concerning the offenses committed, whether charged or not, as well as concerning the +defendant and the defendant's background, and to respond to any questions from the +Court and the Probation Office and to any misstatements of fact or law. Subject only to +the express terms of any agreed-upon sentencing recommendations contained in this +Agreement, this Office further reserves the right to make any recommendation as to the +quality and quantity of punishment. +16. The defendant is aware that the sentence has not yet been determined by the +Court. The defendant also is aware that any estimate of the probable sentencing range or +sentence that the defendant may receive, whether that estimate comes from the +defendant's attorney, the government, or the probation office, is a prediction, not a +promise, and is not binding on the government, the probation office or the Court. The +defendant understands further that any recommendation that the government makes to the +Court as to sentencing, whether pursuant to this agreement or otherwise, is not binding on +the Court and the Court may disregard the recommendation in its entirety. The defendant +understands and acknowledges, as previously acknowledged in paragraph 4 above, that +the defendant may not withdraw his plea based upon the Court's decision not to accept a +sentencing +recommendation +made by the defendant, the government, or a +recommendation made jointly by both the defendant and the government. +17. +WAIVER OF RIGHT TO APPEAL AND COLLATERALLY +ATTACK THE SENTENCE. The defendant is aware that Title 18, United States Code, +Section 3742 affords the defendant the right to appeal the sentence imposed in this case. +Acknowledging this, in exchange for the undertakings made by the United States in this +plea agreement, the defendant hereby waives all rights conferred by Section 3742 to +5 + + +appeal any sentence imposed, including any restitution order, or to appeal the manner in +which the sentence was imposed, unless the sentence exceeds the maximum permitted by +statute. The defendant further voluntarily and expressly waives, to the maximum extent +permitted by federal law, the right to collaterally attack his sentence in any +post-conviction proceeding, including a motion on any ground brought under 28 U.S.C. § +2254, 28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18 U.S.C. § 3771. The defendant further +understands that nothing in this agreement shall affect the government's right and/or duty +to appeal as set forth in Title 18, United States Code, Section 3742(b). However, if the +United States appeals the defendant's sentence pursuant to Section 3742(b), the defendant +shall be released from the above waiver of appellate rights. By signing this agreement, +the defendant acknowledges that he has discussed the appeal waiver set forth in this +18. +If the defendant fails in any way to fulfill each one of his obligations under +this Plea Agreement, +, the United States, and only the United States, may elect to be +released from its commitments under this Plea Agreement. If the United States elects to +void the Plea Agreement because of a breach by the defendant, then the United States +agrees not to use the defendant's guilty plea against him. However, the United States +may prosecute the defendant for any and all Federal crimes that he has committed related +to this case and may seek any sentence for such crimes up to and including the statutory +maximums. +The defendant expressly waives any statute of limitations defense and any +constitutional or statutory speedy trial defense to such a prosecution, except to the extent +that such a defense exists as of the date he signs this Plea Agreement. Finally, the +defendant understands that his violation of the terms of this Plea Agreement would not +19. +This is the entire agreement and understanding between the United States +There are no other agreements, promises, representations, or + + +R. ALEXANDER ACOSTA +UNITED STATES ATTORNEY +A. MARIE VILLAFAÑA +ASSISTANT UNITED STATES ATTORNEY +By: - +COUNSEL TO DEFENDANT +7 + + +UNITED STATES OF AMERICA +VS. +JEFFREY EPSTEIN, +Defendant. +PLEA AGREEMENT +The United States Attorney for the Southern District of Florida ("the United +States"), and Jeffrey Epstein (hereinafter referred to as the "defendant") enter into the +following agreement: +The defendant agrees to plead guilty to a two-count Information which +charges that the defendant intentionally harassed two other persons, that is, S.K. and +N.M., in an attempt to delay, prevent, and dissuade those persons from reporting to a law +enforcement officer of the United States the commission of a federal offense; in violation +of Title 18, United States Code, Sections 1512(d)(2) and 2. +2. +The defendant agrees and understands that the above charges involve his +conduct, and the criminal conduct of others, between in and around carly 2001 through in +and around September 2007. This agreement resolves the federal criminal liability of the +defendant and any co-conspirators in the Southern District of Florida growing out of any +criminal conduct by those persons known to the United States Attorney's Office for the +Southern District of Florida as of the date of this plea agreement. +9/20/2007 1:17pm + + +The United States agrees that, upon entry of the defendant's guilty plea, its +Grand Jury investigation will be suspended, and all pending litigation between the parties +will be held in abeyance unless and until the defendant violates any term of this +agreement, as explained in paragraph 18, infra. Both parties agree to maintain their +evidence inviolate until all of the terms of this agreement have been satisfied. +4. +The defendant is aware that the sentence will be imposed by the Court after +considering the +Federal Sentencing Guidelines and Policy Statements (hereinafter +"Sentencing Guidelines"). The defendant acknowledges and understands that the Court +will compute an advisory sentence under the Sentencing Guidelines and that the +applicable guidelines will be determined by the Court relying in part on the results of a +Pre-Sentence Investigation by the Court's probation office, which investigation will +commence after the guilty plea has been entered. The defendant is also aware that, under +certain circumstances, the Court may depart from the advisory sentencing guideline range +that it has computed, and may raise or lower that advisory sentence under the Sentencing +Guidelines. The defendant is further aware and understands that the Court is required to +consider the advisory guideline range determined under the Sentencing Guidelines, but is +not bound to impose that sentence; the Court is permitted to tailor the ultimate sentence in +light of other statutory concerns, and such sentence may be either more severe or less +severe than the Sentencing Guidelines' advisory sentence. Knowing these facts, the +defendant understands and acknowledges that the Court has the authority to impose any +sentence within and up to the statutory maximum authorized by law for the offenses +identified in paragraph 1 and that the defendant may not withdraw the plea solely as a +result of the sentence imposed. +The defendant further understands and acknowledges that, as to each of +Counts 1 and 2 of the Information, the Court may impose a statutory maximum term of +imprisonment of up to one (1) year, to be followed by a term of supervised release of up +2 + + +to a maximum of one (1) year, In addition to terms of imprisonment and supervised +release, the Court may impose a fine of up to $100,000 as to each count. +The defendant further understands and acknowledges that, in addition to +any sentence imposed under paragraph 4 of this Agreement, a special assessment in the +amount of $50 will be imposed on the defendant, which must be paid at or before the +time of sentencing. +The defendant understands that the Court will order that he must pay full +restitution to all victims of the offenses to which he is pleading guilty. The defendant +understands that the amount of restitution owed to each victim will be determined at or +before sentencing. +8. +The parties agree to jointly recommend that the defendant receive a +sentence of eighteen (18) months' imprisonment, to be followed by one (1) year of +supervised release, and a fine of $200,000. The parties' further agree to jointly +recommend that the Court impose one year of home confinement as a special condition of +supervised release. +The defendant agrees that, if any of the victims identified in the federal +investigation file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the +jurisdiction of the U.S. District Court for the Southern District of Florida over his person +and/or the subject matter, and the defendant will not contest that the identified victims are +persons who, while minors, were victims of violations of Title 18, United States Code, +Sections(s) 2422 and/or 2423. The United States agrees to provide the defendant's +attorneys with a list of the identified victims, which will not exceed forty, after the +defendant has signed this agreement and has been sentenced. The United States further +agrees to make a motion with the United States District Court for the Southern District of +Florida for the appointment of a guardian ad litem for the identified victims and the +defendant's counsel may contact the identified victims through that guardian. +3 + + +10. The United States has reached this agreement with the defendant in +response to the defendant's request to globally resolve his state and federal criminal +liability. To do so, the defendant further understands and acknowledges that he must +undertake certain actions with the State Attorney's Office for the 15th Judicial Circuit in +and for Palm Beach County (hereinafter, "State Attorney's Office") in order to satisfy the +United States' federal interest in the investigation and prosecution of his offenses, in +accordance with the Justice Department's Petite policy. +11. +In addition to entering a guilty plea in the instant case, the defendant agrees +that, prior to his sentencing on the federal charges, he will plead guilty to an Information +filed by the State Attorney's Office charging an offense for which the defendant must +register as a sex offender, that is, solicitation of minors to engage in prostitution, in +violation of Fl. Stat. 796.03. The defendant agrees that he will waive all challenges to the +Information filed by the State Attorney's Office and waive the right to appeal his +conviction and sentence in the state court. +12. The defendant agrees that he will make a binding recommendation that the +15th Judicial Circuit Court impose a sentence of at least eighteen (18) months' +imprisonment to be followed by at least twelve (12) months of community control/home +confinement to be served upon the defendant's release from federal prison. The +defendant further represents that he has had discussions with the State Attorney's Office, +which has agreed to likewise make this recommendation. The sentences imposed by the +15th Judicial Circuit Court may run concurrently with the federal sentence imposed +pursuant to this agreement. +13. The defendant agrees to 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. +The defendant agrees that the timely completion of these actions is material +4 + + +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 the defendant for any and all federal offenses. +15. +The United States reserves the right to inform the Court and the probation +office of all facts pertinent to the sentencing process, including all relevant information +concerning the offenses committed, whether charged or not, as well as concerning the +defendant and the defendant's background, and to respond to any questions from the +Court and the Probation Office and to any misstatements of fact or law. Subject only to +the express terms of any agreed-upon sentencing recommendations contained in this +Agreement, this Office further reserves the right to make any recommendation as to the +quality and quantity of punishment. +16. +The defendant is aware that the sentence has not yet been determined by the +Court. The defendant also is aware that any estimate of the probable sentencing range or +sentence that the defendant may receive, whether that estimate comes from the +defendant's attorney, the government, or the probation office, is a prediction, not a +promise, and is not binding on the government, the probation office or the Court. The +defendant understands further that any recommendation that the government makes to the +Court as to sentencing, whether pursuant to this agreement or otherwise, is not binding on +the Court and the Court may disregard the recommendation in its entirety. The defendant +understands and acknowledges, as previously acknowledged in paragraph 4 above, that +the defendant may not withdraw his plea based upon the Court's decision not to accept a +sentencing +recommendation made by the defendant, the government, or a +recommendation made jointly by both the defendant and the government. +17. +WAIVER OF RIGHT TO APPEAL AND COLLATERALLY +ATTACK THE SENTENCE. The defendant is aware that Title 18, United States Code, +5 + + +Section 3742 affords the defendant the right to appeal the sentence imposed in this case. +Acknowledging this, in exchange for the undertakings made by the United States in this +plea agreement, the defendant hereby waives all rights conferred by Section 3742 to +appeal any sentence imposed, including any restitution order, or to appeal the manner in +which the sentence was imposed, unless the sentence exceeds the maximum permitted by +statute. The defendant further voluntarily and expressly waives, to the maximum extent +permitted by federal law, the right to collaterally attack his sentence in any +post-conviction proceeding, including a motion on any ground brought under 28 U.S.C. § +2254, 28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18 U.S.C. § 3771. The defendant further +understands that nothing in this agreement shall affect the government's right and/or duty +to appeal as set forth in Title 18, United States Code, Section 3742(b). However, if the +United States appeals the defendant's sentence pursuant to Section 3742(b), the defendant +shall be released from the above waiver of appellate rights. By signing this agreement, +the defendant acknowledges that he has discussed the appeal waiver set forth in this +18. +If the defendant fails in any way to fulfill each one of his obligations under +this Plea Agreement, the United States, and only the United States, may elect to be +released from its commitments under this Plea Agreement. If the United States elects to +void the Plea Agreement because of a breach by the defendant, then the United States +agrees not to use the defendant's guilty plea against him. However, the United States +may prosecute the defendant for any and all Federal crimes that he has committed related +to this case and may seek any sentence for such crimes up to and including the statutory +maximums. +The defendant expressly waives any statute of limitations defense and any +constitutional or statutory speedy trial defense to such a prosecution, except to the extent +that such a defense exists as of the date he signs this Plea Agreement. Finally, the +defendant understands that his violation of the terms of this Plea Agreement would not + + +19. This is the entire agreement and understanding between the United States +There are no other agreements, promises, representations, or +R. ALEXANDER ACOSTA +UNITED STATES ATTORNEY +A. MARIE VILLAFAÑA +ASSISTANT UNITED STATES ATTORNEY +BY JEFFREY EPSTEIN, DEFENDANT +. By: +COUNSEL TO DEFENDANT +7 + + +Case No. _ +UNITED STATES OF AMERICA +VS. +JEFFREY EPSTEIN, +Defendant. +PLEA AGREEMENT +The United States Attorney for the Southern District of Florida ("the United +States"), and Jeffrey Epstein (hereinafter referred to as the "defendant") enter into the +following agreement: +The defendant agrees to plead guilty to a two-count Information which +charges the defendant as follows. Count 1 charges that the defendant intentionally +harassed another person, that is, L.G., in an attempt to delay, prevent, and dissuade L.G. +from attending or testifying in an official proceeding, that is a Federal Grand Jury +appearance in the Southern District of Florida, in violation of Title 18, United States +Code, Sections 1512(d)(2) and 2; and Count 2 charges that the defendant intentionally +harassed another person, that is, N.M., in an attempt to delay, prevent, and dissuade N.M. +from reporting to a law enforcement officer of the United States the commission of a +federal offense; in violation of Title 18, United States Code, Sections 1512(d)(2) and 2. +The defendant agrees and understands that the above charges involve his +conduct, and the conduct of others, between in and around early 2001 through in and +9/18/07 12:22pm +1 + + +around September 2007 involving a conspiracy to solicit minors to engage in prostitution +and to travel in interstate commerce to engage in illicit sexual conduct. _This agreement +resolves the federal criminal liability of the defendant and any co-conspirators in the +Southern District of Florida growing out of any criminal conduct by those persons known +to the United States Attorney's Office for the Southern District of Florida as of the date of +this plea agreement, including but not limited to the above-described scheme. +The United States agrees that, upon entry of the defendant's guilty plea, its +Grand Jury investigation will be suspended, and all pending Grand Jury subpoenas will +be held in abeyance unless and until the defendant violates any term of this agreement, as +explained in paragraph 19, infra. The defendant likewise agrees to withdraw his pending +motion to intervene and to quash certain grand jury subpoenas. The defendant further +agrees that the current custodian of certain computer equipment shall maintain that +evidence inviolate until all of the terms of this agreement have been satisfied. +4. The defendant is aware that the sentence will be imposed by the Court after +considering the Federal Sentencing Guidelines and Policy Statements (hereinafter +"Sentencing Guidelines"). The defendant acknowledges and understands that the Court +will compute an advisory sentence under the Sentencing Guidelines and that the +applicable guidelines will be determined by the Court relying in part on the results of a +Pre-Sentence Investigation by the Court's probation office, which investigation will +commence after the guilty plea has been entered. The defendant is also aware that, under +certain circumstances, the Court may depart from the advisory sentencing guideline range +that it has computed, and may raise or lower that advisory sentence under the Sentencing +Guidelines. The defendant is further aware and understands that the Court is required to +consider the advisory guideline range determined under the Sentencing Guidelines, but is +not bound to impose that sentence; the Court is permitted to tailor the ultimate sentence in +light of other statutory concerns, and such sentence may be either more severe or less +2 + + +severe than the Sentencing Guidelines' advisory sentence. Knowing these facts, the +defendant understands and acknowledges that the Court has the authority to impose any +sentence within and up to the statutory maximum authorized by law for the offenses +identified in paragraph 1 and that the defendant may not withdraw the plea solely as a +result of the sentence imposed. +The defendant further understands and acknowledges that, as to each of +Counts 1 and 2 of the Information, the Court may impose a statutory maximum term of +imprisonment of up to one (1) year, to be followed by a term of supervised release of up +to a maximum of one (1) year. In addition to terms of imprisonment and supervised +release, the Court may impose a fine of up to $100,000 as to each count. +The defendant further understands and acknowledges that, in addition to +any sentence imposed under paragraph 3 of this Agreement, a special assessment in the +amount of $50 will be imposed on the defendant, which must be paid at or before the +time of sentencing. +7. +The defendant understands that the Court will order that he must pay full +restitution to all victims of the offense to which he is pleading guilty. The defendant +understands that the amount of restitution owed to each victim will be determined at or +before sentencing. +8. +The parties agree to jointly recommend that the defendant receive a +sentence of eighteen (18) months' imprisonment, to be followed by two (2) years of +supervised release; and +a fine of $200,000. The parties' further agree to jointly +recommend that the Court impose one year of home confinement as a special condition of +supervised release. +9. +The defendant agrees that, if any of the victims identified in the federal +investigation file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the +jurisdiction of the U.S. District Court for the Southern District of Florida over his person +3 + + +and/or the subject matter, and the defendant will not contest that the identified victims are +persons who, while minors, were victims of violations of Title 18, United States Code, +Sections(s) 2422 and/or 2423. The United States agrees to provide the defendant's +attorneys with a list of the identified victims, which will not exceed forty, after the +defendant has signed this agreement and has been sentenced. The United States further +agrees to make a motion with the United States District Court for the Southern District of +Florida for the appointment of a guardian ad litem for the identified victims and the +defendant's counsel may contact the identified victims through that guardian. +10. The defendant further understands and acknowledges that he must +undertake certain actions with the State Attorney's Office for the 15th Judicial Circuit in +and for Palm Beach County (hereinafter, "State Attorney's Office") in order to satisfy the +United States' federal interest in the investigation and prosecution of his offenses, in +accordance with the Justice Department's Petite policy. Epstein understands and +acknowledges 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 discussion with the State Attorney's Office to ensure +compliance with these procedures. +11. +In addition to entering a guilty plea in the instant case, the defendant agrees +to plead guilty to an Information filed by the Palm Beach County State Attorney's Office +charging an offense for which the defendant must register as a sex offender, that is, +solicitation of minors to engage in prostitution, in violation of Fl. Stat. 796.03. The +defendant must enter this guilty plea before he is sentenced on the federal offenses. +12. м +The defendant agrees that he and the Palm Beach County State Attorney's +Office will make a joint, binding recommendation that the Court impose a sentence of at +least eighteen (18) months' imprisonment to be followed by at least twelve (12) months +of community control/home confinement to be served upon the defendant's release from +4 + + +federal prison. Those sentences may run concurrently with the federal sentence imposed +pursuant to this agreement. [NB: The other option is: The defendant and the Palm +Beach County State Attorney's Office shall make a joint, binding recommendation +that the Court impose a sentence of at least sixty (60) months' probation, which will +include at least twelve (12) months of community control/home confinement to be +served upon the defendant's release from federal prison.] +13. +The defendant agrees to waive all challenges to the Information filed by the +State Attorney's Office and to waive the right to appeal his conviction and sentence in the +state court. +The defendant agrees to provide to the U.S. Attorney's Office copies of all +proposed agreements with the Palm Beach County State Attorney's Office prior to +entering into those agreements. +15. +The defendant agrees that the timely completion of these actions 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 for any and all federal offenses. +16. +The United States reserves the right to inform the Court and the probation +office of all facts pertinent to the sentencing process, including all relevant information +concerning the offenses committed, whether charged or not, as well as concerning the +defendant and the defendant's background, and to respond to any questions from the +Court and the Probation Office and to any misstatements of fact or law. Subject only to +the express terms of any agreed-upon sentencing recommendations contained in this +Agreement, this Office further reserves the right to make any recommendation as to the +quality and quantity of punishment. +17. +The defendant is aware that the sentence has not yet been determined by the +Court. The defendant also is aware that any estimate of the probable sentencing range or +5 + + +sentence that the defendant may +receive, whether that estimate comes from the +defendant's attorney, the government, or the probation office, is a prediction, not a +promise, and is not binding on the government, the probation office or the Court. The +defendant understands further that any recommendation that the government makes to the +Court as to sentencing, whether pursuant to this agreement or otherwise, is not binding on +the Court and the Court may disregard the recommendation in its entirety. The defendant +understands and acknowledges, as previously acknowledged in paragraph 4 above, that +the defendant may not withdraw his plea based upon the Court's decision not to accept a +sentencing +recommendation made by the defendant, the government, or a +recommendation made jointly by both the defendant and the government. +WAIVER OF RIGHT TO APPEAL AND COLLATERALLY +ATTACK THE SENTENCE. The defendant is aware that Title 18, United States Code, +Section 3742 affords the defendant the right to appeal the sentence imposed in this case. +Acknowledging this, in exchange for the undertakings made by the United States in this +plea agreement, the defendant hereby waives all rights conferred by Section 3742 to +appeal any sentence imposed, including any restitution order, or to appeal the manner in +which the sentence was imposed, unless the sentence exceeds the maximum permitted by +statute. The defendant further voluntarily and expressly waives, to the maximum extent +permitted by federal law, the right to collaterally attack his sentence in any +post-conviction proceeding, including a motion on any ground brought under 28 U.S.C. § +2254, 28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18 U.S.C. § 3771. The defendant further +understands that nothing in this agreement shall affect the government's right and/or duty +to appeal as set forth in Title 18, United States Code, Section 3742(b). However, if the +United States appeals the defendant's sentence pursuant to Section 3742(b), the defendant +shall be released from the above waiver of appellate rights. By signing this agreement, +the defendant acknowledges that he has discussed the appeal waiver set forth in this +6 + + +19. +If the defendant fails in any way to fulfill each one of his obligations under +this Plea Agreement, +the United States, and only the United States, may elect to be +released from its commitments under this Plea Agreement. If the United States elects to +void the Plea Agreement because of a breach by the defendant, then the United States +agrees not to use the defendant's guilty plea against him. However, the United States +may prosecute the defendant for any and all Federal crimes that he has committed related +to this case and may seek any sentence for such crimes up to and including the statutory +maximums. The defendant expressly waives any statute of limitations defense and any +constitutional or statutory speedy trial defense to such a prosecution, except to the extent +that such a defense exists as of the date he signs this Plea Agreement. Finally, the +defendant understands that his violation of the terms of this Plea Agreement would not +20. +This is the entire agreement and understanding between the United States +and the defendant. There are no other agreements, promises, representations, or +R. ALEXANDER ACOSTA +UNITED STATES ATTORNEY +BY JEFFREY EPSTEIN, DEFENDANT +7 + + +8 + + +UNITED STATES OF AMERICA +VS. +JEFFREY EPSTEIN, +Defendant. +PLEA AGREEMENT +The United States Attorney for the Southern District of Florida ('the United +States"), and Jeffrey Epstein (hereinafter referred to as the "defendant") enter into the +following agreement: +The defendant agrees to plead guilty to a two-count Information which +charges the defendant as follows. Count 1 charges that the defendant intentionally +harassed another person, that is, L.G., in an attempt to delay, prevent, and dissuade L.G. +from attending or testifying in an official proceeding, that is a Federal Grand Jury +appearance in the Southern District of Florida, in violation of Title 18, United States +Code, Sections 1512(d)(2) and 2; and Count 2 charges that the defendant intentionally +harassed another person, that is, Jane Doe #1, in an attempt to delay, prevent, and dissuade Jane +Doe #1 from reporting to a law enforcement officer of the United States the commission of a +federal offense; in violation of Title 18, United States Code, Sections 1512(d)(2) and 2. +2. +The defendant agrees and understands that the above charges involve +his conduct, and the conduct of others, between in and around early 2001 through +1 +9/18/07 12:07pm + + +in and around September 2007 involving a conspiracy to solicit minors to engage +in prostitution and to travel in interstate commerce to engage in illicit sexual +conduct. _This agreement resolves the federal criminal liability of the defendant +and any coconspirators in the Southern District of Florida growing out of any criminal +conduct by those persons known to the United States Attorney's Office for the +Southern District of Florida as of the date of this plea agreement, including but not +limited to the above-described scheme. +3. +The United States agrees that, upon entry of the defendant's guilty +plea, its Grand Jury investigation will be suspended, and all pending Grand Jury +subpoenas will be held in abeyance unless and until the defendant violates any +term of this agreement, as explained in paragraph _ below. The defendant +likewise agrees to withdraw his pending motion to intervene and to quash certain +grand jury subpoenas. The defendant further agrees that the current custodian of +certain computer equipment shall maintain that evidence inviolate until all of the +terms of this agreement have been satisfied. +4. The defendant is aware that the sentence will be imposed by the Court after +considering the Federal Sentencing Guidelines and Policy Statements (hereinafter +"Sentencing Guidelines"). The defendant acknowledges and understands that the Court +will compute an advisory sentence under the Sentencing Guidelines and that the +applicable guidelines will be determined by the Court relying in part on the results of a +Pre-Sentence Investigation by the Court's probation office, which investigation will +commence after the guilty plea has been entered. The defendant is also aware that, under +certain circumstances, the Court may depart from the advisory sentencing guideline range +that it has computed, and may raise or lower that advisory sentence under the Sentencing +Guidelines. The defendant is further aware and understands that the Court is required to +2 + + +consider the advisory guideline range determined under the Sentencing Guidelines, but is +not bound to impose that sentence; the Court is permitted to tailor the ultimate sentence in +light of other statutory concerns, and such sentence may be either more severe or less +severe than the Sentencing Guidelines' advisory sentence. Knowing these facts, the +defendant understands and acknowledges that the Court has the authority to impose any +sentence within and up to the statutory maximum authorized by law for the offenses +identified in paragraph 1 and that the defendant may not withdraw the plea solely as a +result of the sentence imposed. +5. +The defendant further understands and acknowledges that, as to each of +Counts 1 and 2 of the Information, the Court may impose a statutory maximum term of +imprisonment of up to one (1) year, to be followed by a term of supervised release of up +to a maximum of one (1) year. In addition to terms of imprisonment and supervised +release, the Court may impose a fine of up to $100,000 as to each count. +The defendant further understands and acknowledges that, in addition to +any sentence imposed under paragraph 3 of this Agreement, a special assessment in the +amount of $50 will be imposed on the defendant, which must be paid at or before the +time of sentencing. +7. +The defendant understands that the Court will order that he must pay full +restitution to all victims of the offense to which he is pleading guilty. The defendant +understands that the amount of restitution owed to each victim will be determined at or +before sentencing. +The parties agree to jointly recommend that the defendant receive a +sentence of eighteen (18) months' imprisonment, to be followed by two (2) years of +supervised release; and a fine of $200,000. The parties' further agree to jointly +recommend that the Court impose one year of home confinement as a special condition of +supervised release. +3 + + +The defendant agrees that, if any of the victims identified in the federal +investigation file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the +jurisdiction of the U.S. District Court for the Southern District of Florida over his person and/or +the subject matter, and the defendant will not contest that the identified victims are persons who, +while minors, were victims of violations of Title 18, United States Code, Sections(s) 2422 and/or +2423. The United States agrees to provide the defendant's attorneys with a list of the identified +victims, which will not exceed forty, after the defendant has signed this agreement and has been +sentenced. +• The United States further agrees to make a motion with the United States District +Court for the Southern District of Florida for the appointment of a guardian ad litem for the +identified victims and the defendant's counsel may contact the identified victims through that +guardian. +10. The defendant further understands and acknowledges that he must +undertake certain actions with the State Attorney's Office for the 15th Judicial Circuit in +and for Palm Beach County (hereinafter, "State Attorney's Office") in order to satisfy the +United States' federal interest in the investigation and prosecution of his offenses, in +accordance with the Justice Department's Petite policy. Epstein understands and +acknowledges 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 discussion with the State Attorney's Office to ensure +compliance with these procedures. +11. +In addition to entering a guilty plea in the instant case, the defendant agrees +to plead guilty to an Information filed by the Palm Beach County State Attorney's Office +charging an offense for which the defendant must register as a sex offender, that is, solicitation +of minors to engage in prostitution, in violation of Fl. Stat. 796.03. The defendant must enter +this guilty plea before he is sentenced on the federal offenses. +12. +The defendant agrees that he and the Palm Beach County State Attorney's Office +4 + + +will make a joint, binding recommendation that the Court impose a sentence of at least eighteen +(18) months' imprisonment to be followed by at least twelve (12) months of community +control/home confinement to be served upon the defendant's release from federal prison. Those +sentences may run concurrently with the federal sentence imposed pursuant to this agreement. +[NB: The other option is: The defendant and the Palm Beach County State Attorney's +Office shall make a joint, binding recommendation that the Court impose a sentence of at +least sixty (60) months' probation, which will include at least twelve (12) months of +community control/home confinement to be served upon the defendant's release from +federal prison.] +13. +The defendant agrees to waive all challenges to the Information filed by the State +Attorney's Office and to waive the right to appeal his conviction and sentence in the state court. +The defendant agrees to provide to the U.S. Attorney's Office copies of all +proposed agreements with the Palm Beach County State Attorney's Office prior to entering into +those agreements. +15. +The defendant agrees that the timely completion of these actions 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 for any and all federal offenses. +16. +The United States reserves the right to inform the Court and the probation +office of all facts pertinent to the sentencing process, including all relevant information +concerning the offenses committed, whether charged or not, as well as concerning the +defendant and the defendant's background, and to respond to any questions from the +Court and the Probation Office and to any misstatements of fact or law. Subject only to +the express terms of any agreed-upon sentencing recommendations contained in this +Agreement, this Office further reserves the right to make any recommendation as to the +quality and quantity of punishment. +5 + + +17. The defendant is aware that the sentence has not yet been determined by the +Court. The defendant also is aware that any estimate of the probable sentencing range or +sentence that the defendant may receive, whether that estimate comes from the +defendant's attorney, the government, or the probation office, is a prediction, not a +promise, and is not binding on the government, the probation office or the Court. The +defendant understands further that any recommendation that the government makes to the +Court as to sentencing, whether pursuant to this agreement or otherwise, is not binding on +the Court and the Court may disregard the recommendation in its entirety. The defendant +understands and acknowledges, as previously acknowledged in paragraph 2 above, that +the defendant may not withdraw his plea based upon the Court's decision not to accept a +sentencing +recommendation +made by the defendant, the government, or a +recommendation made jointly by both the defendant and the government. +18. WAIVER OF RIGHT TO APPEAL AND COLLATERALLY +ATTACK THE SENTENCE. The defendant is aware that Title 18, United States Code, +Section 3742 affords the defendant the right to appeal the sentence imposed in this case. +Acknowledging this, in exchange for the undertakings made by the United States in this +plea agreement, the defendant hereby waives all rights conferred by Section 3742 to +appeal any sentence imposed, including any restitution order, or to appeal the manner in +which the sentence was imposed, unless the sentence exceeds the maximum permitted by +statute. The defendant further voluntarily and expressly waives, to the maximum extent +permitted by federal law, +the right to collaterally attack his sentence in any +post-conviction proceeding, including a motion on any ground brought under 28 U.S.C. § +2254, 28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18 U.S.C. § 3771. The defendant further +understands that nothing in this agreement shall affect the government's right and/or duty +to appeal as set forth in Title 18, United States Code, Section 3742(b). However, if the +United States appeals the defendant's sentence pursuant to Section 3742(b), the defendant +6 + + +shall be released from the above waiver of appellate rights. By signing this agreement, +the defendant acknowledges that he has discussed the appeal waiver set forth in this +19. +If the defendant fails in any way to fulfill each one of his obligations under +this Plea Agreement, the United States, and only the United States, may clect to be +released from its commitments under this Plea Agreement. If the United States elects to +void the Plea Agreement because of a breach by the defendant, then the United States +agrees not to use the defendant's guilty plea against him. However, the United States +may prosecute the defendant for any and all Federal crimes that he has committed related +to this case and may seek any sentence for such crimes up to and including the statutory +maximums. The defendant expressly waives any statute of limitations defense and any +constitutional or statutory speedy trial defense to such a prosecution, except to the extent +that such a defense exists as of the date he signs this Plea Agreement. Finally, the +defendant understands that his violation of the terms of this Plea Agreement would not +20. +This is the entire agreement and understanding between the United States +There are no other agreements, promises, representations, or +R. ALEXANDER ACOSTA +UNITED STATES ATTORNEY +7 + + + + +UNITED STATES OF AMERICA +VS. +JEFFREY EPSTEIN, +Defendant. +PLEA AGREEMENT +The United States Attorney for the Southern District of Florida ("the United +States"), and Jeffrey Epstein (hereinafter referred to as the "defendant") enter into the +following agreement: +The defendant agrees to plead guilty to the Information which charges the +defendant as follows: Count 1 charges that the defendant intentionally harassed another +person, that is, L.G., in an attempt to delay, prevent, and dissuade L.G. from attending or +testifying in an official proceeding, that is a Federal Grand Jury appearance in the +Southern District of Florida, in violation of Title 18, United States Code, Sections +1512(d)(2) and 2; and Count 2 charges that the defendant, while in the special aircraft +jurisdiction of the United States, did knowingly commit a simple assault on a person who +was over the age of 16 years, that is, N.M., in violation of Title 18, United States Code, +Section 113(a)(5); all in violation of Title 49, United States Code, Section 46506(1). +2. +The defendant is aware that the sentence will be imposed by the Court after +considering the Federal Sentencing Guidelines and Policy Statements (hereinafter +1 +9/16/07 4:42pm + + +"Sentencing Guidelines"). The defendant acknowledges and understands that the Court +will compute an advisory sentence under the Sentencing Guidelines and that the +applicable guidelines will be determined by the Court relying in part on the results of a +Pre-Sentence Investigation by the Court's probation office, which investigation will +commence after the guilty plea has been entered. The defendant is also aware that, under +certain circumstances, the Court may depart from the advisory sentencing guideline range +that it has computed, and may raise or lower that advisory sentence under the Sentencing +Guidelines. The defendant is further aware and understands that the Court is required to +consider the advisory guideline range determined under the Sentencing Guidelines, but is +not bound to impose that sentence; the Court is permitted to tailor the ultimate sentence in +light of other statutory concerns, and such sentence may be either more severe or less +severe than the Sentencing Guidelines' advisory sentence. Knowing these facts, the +defendant understands and acknowledges that the Court has the authority to impose any +sentence within and up to the statutory maximum authorized by law for the offenses +identified in paragraph 1 and that the defendant may not withdraw the plea solely as a +result of the sentence imposed. +The defendant further understands and acknowledges that, as to Count 1 of +the Information, the Court may impose a statutory maximum term of imprisonment of up +to one (1) year, to be followed by a term of supervised release of up to a maximum of one +(1) year. In addition to terms of imprisonment and supervised release, the Court may +impose a fine of up to $100,000. The defendant further understands and acknowledges +that, as to Count 2 of the Information, the Court may impose a statutory maximum term +of imprisonment of up to six (6) months, to be followed by a term of supervised release +of up to a maximum of one (1) year. In addition to terms of imprisonment and supervised +release, the Court may impose a fine of up to $100,000. +4. The defendant further understands and acknowledges that, in addition to +2 + + +any sentence imposed under paragraph 3 of this Agreement, a special assessment in the +amount of $50 will be imposed on the defendant, which must be paid at or before the +time of sentencing. +5. +The defendant understands that the Court will order that he must pay full +restitution to all victims of the offenses to which he is pleading guilty. The defendant +understands that the amount of restitution owed to each victim will be determined at or +before sentencing. +The parties agree to jointly recommend that the defendant receive a +sentence of eighteen (18) months' imprisonment, to be followed by two (2) years of +supervised release; and a fine of $200,000. +7. +The defendant agrees that, if any of the victims identified in the federal +investigation file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the +jurisdiction of the U.S. District Court for the Southern District of Florida over his person +and/or the subject matter, and the defendant will not contest that the identified victims are +persons who, while minors, were victims of violations of Title 18, United States Code, +Sections(s) 2422 and/or 2423. The United States agrees to provide the defendant's +attorneys with a list of the identified victims, which will not exceed forty, after the +defendant has signed this agreement and has been sentenced. The United States further +agrees to make a motion with the United States District Court for the Southern District of +Florida for the appointment of a guardian ad litem for the identified victims and, the +defendant's counsel may contact the identified victims through that guardian. +8. +The defendant agrees to plead guilty to the criminal charges in the +Indictment as currently pending against him in the 15" Judicial Circuit in and for Palm +Beach County and, in addition, agrees to plead guilty to a one-count Information charging +the knowing procurement of a person under the age of 18 to engage in prostitution, in +violation of F.S.A. § 796.03. +3 + + +The defendant agrees that he and the Palm Beach County State Attorney's +Office will resolve the criminal charges pending against him as follows: +(a) +the defendant will enter a plea agreement with the Palm Beach +County State Attorney's Office forthwith and thereafter enter his +plea of guilty to the indictment currently pending against him in the +15"h Judicial Circuit in and for Palm Beach County (Case No. +2006cf009495AXXXMB), and further agrees to plead guilty to a +onecount information charging the knowing procurement of a person +under the age of 18 to engage in prostitution, in violation of F.S.A. § +796.03 on a date after his sentencing in the instant case; +(b) +within seven days of the defendant's sentencing in the instant case, +but before the defendant begins serving his federal sentence, he will +enter his plea of guilty to the indictment and information filed in the +15h Circuit Judicial Court as described in paragraph (a); +(c) +the defendant and the Palm Beach County State Attorney's Office +will make a joint, binding recommendation that the 15" Judicial +Circuit Court impose a sentence as follows: +(i) +the defendant shall be placed on five (5) years' probation, +with the following special conditions; +(ii) +the defendant shall serve the first eighteen (18) months of +probation in custody, which will be served concurrently with +the federal sentence imposed in the instant case; +(iii) +immediately following his release from custody, the +defendant shall begin serving one (1) year of community +control with electronic monitoring. +4 + + +9. +The defendant agrees to waive all challenges to the Information filed by the +State Attorney's Office and to waive the right to appeal his conviction and sentence, +unless the 15"h Judicial Circuit Court imposes a sentence that exceeds the terms of the +joint recommendation in the state court. +10. The defendant agrees that he will provide to the U.S. Attorney's Office +copies of all proposed agreements with the Palm Beach County State Attorney's Office +prior to entering into those agreements. +11. The United States reserves the right to inform the Court and the probation +office of all facts pertinent to the sentencing process, including all relevant information +concerning the offenses committed, whether charged or not, as well as concerning the +defendant and the defendant's background, and to respond to any questions from the +Court and the Probation Office and to any misstatements of fact or law. Subject only to +the express terms of any agreed-upon sentencing recommendations contained in this +Agreement, this Office further reserves the right to make any recommendation as to the +quality and quantity of punishment. +12. The defendant is aware that the sentence has not yet been determined by the +Court. The defendant also is aware that any estimate of the probable sentencing range or +sentence that the defendant may receive, whether that estimate comes from the +defendant's attorney, the government, or the probation office, is a prediction, not a +promise, and is not binding on the government, the probation office or the Court. The +defendant understands further that any recommendation that the government makes to the +Court as to sentencing, whether pursuant to this agreement or otherwise, is not binding on +the Court and the Court may disregard the recommendation in its entirety. The defendant +understands and acknowledges, as previously acknowledged in paragraph 2 above, that +the defendant may not withdraw his plea based upon the Court's decision not to accept a +sentencing +recommendation +made by the defendant, +the government, +a +5 + + +recommendation made jointly by both the defendant and the government. +13. WAIVER OF RIGHT TO APPEAL AND COLLATERALLY +ATTACK THE SENTENCE. The defendant is aware that Title 18, United States Code, +Section 3742 affords the defendant the right to appeal the sentence imposed in this case. +Acknowledging this, in exchange for the undertakings made by the United States in this +plea agreement, +, the defendant hereby waives all rights conferred by Section 3742 to +appeal any sentence imposed, including any restitution order, or to appeal the manner in +which the sentence was imposed, unless the sentence exceeds the maximum permitted by +statute or is the result of an upward departure or upward variance from the guideline +range that the Court establishes at sentencing. The defendant further voluntarily and +expressly waives, to the maximum extent permitted by federal law, the right to +collaterally attack his sentence in any postconviction proceeding, including a motion on any ground brought under 28 U.S.C. § +2254, 28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18 U.S.C. § 3771. The defendant further +understands that nothing in this agreement shall affect the government's right and/or duty +to appeal as set forth in Title 18, United States Code, Section 3742(b). However, if the +United States appeals the defendant's sentence pursuant to Section 3742(b), the defendant +shall be released from the above waiver of appellate rights. By signing this agreement, +the defendant acknowledges that he has discussed the appeal waiver set forth in this +If the defendant fails in any way to fulfill each one of his obligations under +this Plea Agreement, the United States, and only the United States, may elect to be +released from its commitments under this Plea Agreement. If the United States elects to +void the Plea Agreement because of a breach by the defendant, then the United States +agrees not to use the defendant's guilty plea against him. However, the United States +may prosecute the defendant for any and all Federal crimes that he has committed related +6 + + +to this case and may seek any sentence for such crimes up to and including the statutory +maximums. The defendant expressly waives any statute of limitations defense and any +constitutional or statutory speedy trial defense to such a prosecution, except to the extent +that such a defense exists as of the date he signs this Plea Agreement. Finally, the +defendant understands that his violation of the terms of this Plea Agreement would not +15. +This is the entire agreement and understanding between the United States +and the defendant. There are no other agreements, promises, representations, +or +R. ALEXANDER ACOSTA +UNITED STATES ATTORNEY +7 + + +UNITED STATES OF AMERICA +VS. +JEFFREY EPSTEIN, +Defendant. +PLEA AGREEMENT +The United States Attorney for the Southern District of Florida ("the United +States"), and Jeffrey Epstein (hereinafter referred to as the "defendant"') enter into the +following agreement: +1. +The defendant agrees to plead guilty to the Information which charges the +defendant as follows: Count 1 charges that the defendant intentionally harassed another +person, that is, L.G., in an attempt to delay, prevent, and dissuade L.G. from attending or +testifying in an official proceeding, that is a Federal Grand Jury appearance in the +Southern District of Florida, in violation of Title 18, United States Code, Sections +1512(d)(2) and 2; and Count 2 charges that the defendant, while in the special aircraft +jurisdiction of the United States, did knowingly commit a simple assault on a person who +was over the age of 16 years, that is, N.M., in violation of Title 18, United States Code, +Section 113(a)(5); all in violation of Title 49, United States Code, Section 46506(1). +2. +The defendant is aware that the sentence will be imposed by the Court after +considering the Federal Sentencing Guidelines and Policy Statements (hereinafter +9/16/2007 12:09pm +1 + + +"Sentencing Guidelines"). The defendant acknowledges and understands that the Court +will compute an advisory sentence under the Sentencing Guidelines and that the +applicable guidelines will be determined by the Court relying in part on the results of a +Pre-Sentence Investigation by the Court's probation office, which investigation will +commence after the guilty plea has been entered. The defendant is also aware that, under +certain circumstances, the Court may depart from the advisory sentencing guideline range +that it has computed, and may raise or lower that advisory sentence under the Sentencing +Guidelines. The defendant is further aware and understands that the Court is required to +consider the advisory guideline range determined under the Sentencing Guidelines, but is +not bound to impose that sentence; the Court is permitted to tailor the ultimate sentence in +light of other statutory concerns, and such sentence may be either more severe or less +severe than the Sentencing Guidelines' advisory sentence. Knowing these facts, the +defendant understands and acknowledges that the Court has the authority to impose any +sentence within and up to the statutory maximum authorized by law for the offenses +identified in paragraph 1 and that the defendant may not withdraw the plea solely as a +result of the sentence imposed. +The defendant further understands and acknowledges that, as to Count 1 of +the Information, the Court may impose a statutory maximum term of imprisonment of up +to one (1) year, to be followed by a term of supervised release of up to a maximum of one +(1) year. In addition to terms of imprisonment and supervised release, the Court may +impose a fine of up to $100,000. The defendant further understands and acknowledges +that, as to Count 2 of the Information, the Court may impose a statutory maximum term +of imprisonment of up to six (6) months, to be followed by a term of supervised release +of up to a maximum of one (1) year. In addition to terms of imprisonment and supervised +release, the Court may impose a fine of up to $100,000. +4. +The defendant further understands and acknowledges that, in addition to +2 + + +any sentence imposed under paragraph 3 of this Agreement, a special assessment in the +amount of $50 will be imposed on the defendant, which must be paid at or before the +time of sentencing. +The defendant understands that the Court will order that he must pay full +restitution to all victims of the offenses to which he is pleading guilty. The defendant +understands that the amount of restitution owed to each victim will be determined at or +before sentencing. +The parties agree to jointly recommend that the defendant receive a +sentence of eighteen (18) months' imprisonment, to be followed by two (2) years of +supervised release; and a fine of $200,000. +The defendant agrees that, if any of the victims identified in the federal +investigation file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the +jurisdiction of the U.S. District Court for the Southern District of Florida over his person +and/or the subject matter, and the defendant will not contest that the identified victims are +persons who, while minors, were victims of violations of Title 18, United States Code, +Sections(s) 2422 and/or 2423. The United States agrees to provide the defendant's +attorneys with a list of the identified victims, which will not exceed forty, after the +defendant has signed this agreement and has been sentenced. The United States further +agrees to make a motion with the United States District Court for the Southern District of +Florida for the appointment of a guardian ad litem for the identified victims and the +defendant's counsel may contact the identified victims through that guardian. +8. +The defendant agrees to plead guilty (not nolo contendere) to an +Information filed by the Palm Beach County State Attorney's Office charging an offense +for which the defendant must register as a sex offender, that is, solicitation of minors to +engage in prostitution, in violation of Fl. Stat. 796.03. The defendant agrees that he and +the Palm Beach County State Attorney's Office will make a joint, binding +3 + + +recommendation that the Court impose a sentence of at least thirty (30) months, to be +divided as follows: +(a) +the defendant shall begin by serving at least twenty (20) months in +prison, without any opportunity for withholding adjudication or +sentencing, and without probation or community control in lieu of +imprisonment; and +(b) +following the term of imprisonment, the defendant shall serve ten +(10) +months +of community control/home confinement with +electronic monitoring. +9. +The defendant agrees to waive all challenges to the Information filed by the +State Attorney's Office and to waive the right to appeal his conviction and sentence in the +state court. +The defendant agrees that he will provide to the U.S. Attorney's Office +copies of all proposed agreements with the Palm Beach County State Attorney's Office +prior to entering into those agreements. +11. +The United States reserves the right to inform the Court and the probation +office of all facts pertinent to the sentencing process, including all relevant information +concerning the offenses committed, whether charged or not, as well as concerning the +defendant and the defendant's background, and to respond to any questions from the +Court and the Probation Office and to any misstatements of fact or law. Subject only to +the express terms of any agreed-upon sentencing recommendations contained in this +Agreement, this Office further reserves the right to make any recommendation as to the +quality and quantity of punishment. +12. +The defendant is aware that the sentence has not yet been determined by the +Court. The defendant also is aware that any estimate of the probable sentencing range or +sentence that the defendant may +• receive, whether that estimate comes from the +4 + + +defendant's attorney, the government, or the probation office, is a prediction, not a +promise, and is not binding on the government, the probation office or the Court. The +defendant understands further that any recommendation that the government makes to the +Court as to sentencing, whether pursuant to this agreement or otherwise, is not binding on +the Court and the Court may disregard the recommendation in its entirety. The defendant +understands and acknowledges, as previously acknowledged in paragraph 2 above, that +the defendant may not withdraw his plea based upon the Court's decision not to accept a +sentencing +recommendation made by the defendant, the government, or a +recommendation made jointly by both the defendant and the government. +13. WAIVER OF RIGHT TO APPEAL AND COLLATERALLY +ATTACK THE SENTENCE. The defendant is aware that Title 18, United States Code, +Section 3742 affords the defendant the right to appeal the sentence imposed in this case. +Acknowledging this, in exchange for the undertakings made by the United States in this +plea agreement, the defendant hereby waives all rights conferred by Section 3742 to +appeal any sentence imposed, including any restitution order, or to appeal the manner in +which the sentence was imposed, unless the sentence exceeds the maximum permitted by +statute or is the result of an upward departure or upward variance from the guideline +range that the Court establishes at sentencing. The defendant further voluntarily and +expressly waives, to the maximum extent permitted by federal law, the right to +collaterally attack his sentence in any postconviction proceeding, including a motion on any ground brought under 28 U.S.C. § +2254, 28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18 U.S.C. § 3771. The defendant further +understands that nothing in this agreement shall affect the government's right and/or duty +to appeal as set forth in Title 18, United States Code, Section 3742(b). However, if the +United States appeals the defendant's sentence pursuant to Section 3742(b), the defendant +shall be released from the above waiver of appellate rights. By signing this agreement, +5 + + +the defendant acknowledges that he has discussed the appeal waiver set forth in this +If the defendant fails in any way to fulfill each one of his obligations under +this Plea Agreement, the United States, and only the United States, may elect to be +released from its commitments under this Plea Agreement. If the United States elects to +void the Plea Agreement because of a breach by the defendant, then the United States +agrees not to use the defendant's guilty plea against him. However, the United States +may prosecute the defendant for any and all Federal crimes that he has committed related +to this case and may seek any sentence for such crimes up to and including the statutory +maximums. The defendant expressly waives any statute of limitations defense and any +constitutional or statutory speedy trial defense to such a prosecution, except to the extent +that such a defense exists as of the date he signs this Plea Agreement. +Finally, the +defendant understands that his violation of the terms of this Plea Agreement would not +15. This is the entire agreement and understanding between the United States +and the defendant. There are no other agreements, promises, representations, or +R. ALEXANDER ACOSTA +UNITED STATES ATTORNEY +6 + + +7 + + +UNITED STATES OF AMERICA +VS. +JEFFREY EPSTEIN, +Defendant. +/ +PLEA AGREEMENT +The United States Attorney for the Southern District of Florida ("the United +States"), and Jeffrey Epstein (hereinafter referred to as the "defendant") enter into the +following agreement: +1. +The defendant agrees to plead guilty to the Information which charges the +defendant with two counts of intentionally harassing another person, that is, Jane Does #1 and +2, in an attempt to delay, prevent, and dissuade Jane Does #1 and 2 from reporting to a law +enforcement officer of the United States the commission of a federal offense; in violation of Title +18, United States Code, Sections 1512(d)(2) and 2. +2. +The defendant is aware that the sentence will be imposed by the Court after +considering the Federal Sentencing Guidelines and Policy Statements (hereinafter +"Sentencing Guidelines"). The defendant acknowledges and understands that the Court +will compute an advisory sentence under the Sentencing Guidelines and that the +applicable guidelines will be determined by the Court relying in part on the results of a +Pre-Sentence Investigation by the Court's probation office, which investigation will +9/14/2007 8:53am +1 + + +commence after the guilty plea has been entered. The defendant is also aware that, under +certain circumstances, the Court may depart from the advisory sentencing guideline range +that it has computed, and may raise or lower that advisory sentence under the Sentencing +Guidelines. The defendant is further aware and understands that the Court is required to +consider the advisory guideline range determined under the Sentencing Guidelines, but is +not bound to impose that sentence; the Court is permitted to tailor the ultimate sentence in +light of other statutory concerns, and such sentence may be either more severe or less +severe than the Sentencing Guidelines' advisory sentence. Knowing these facts, the +defendant understands and acknowledges that the Court has the authority to impose any +sentence within and up to the statutory maximum authorized by law for the offenses +identified in paragraph 1 and that the defendant may not withdraw the plea solely as a +result of the sentence imposed +The defendant further understands and acknowledges that, as to each of +Counts 1 and 2 of the Information, the Court may impose a statutory maximum term of +imprisonment of up to one (1) year, to be followed by a term of supervised release of up +to a maximum of one (1) year. In addition to terms of imprisonment and supervised +release, the Court may impose a fine of up to $100,000 as to each count. +4. +The defendant further understands and acknowledges that, in addition to +any sentence imposed under paragraph 3 of this Agreement, a special assessment in the +amount of $50 will be imposed on the defendant, which must be paid at or before the +time of sentencing. +The defendant understands that the Court will order that he must pay full +restitution to all victims of the offense to which he is pleading guilty. The defendant +understands that the amount of restitution owed to each victim will be determined at or +before sentencing. +The defendant agrees that, if any of the victims identified in the federal +2 + + +investigation file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the +jurisdiction of the U.S. District Court for the Southern District of Florida over his person and/or +the subject matter, and the defendant will not contest that the identified victims are persons who, +while minors, were victims of violations of Title 18, United States Code, Sections(s) 2422 and/or +2423. The United States agrees to provide the defendant's attorneys with a list of the identified +victims, which will not exceed forty, after the defendant has signed this agreement and has been +sentenced. The United States further agrees to make a motion with the United States District +Court for the Southern District of Florida for the appointment of a guardian ad litem for the +identified victims and the defendant's counsel may contact the identified victims through that +guardian. +The defendant agrees to plead guilty (not nolo contendere) to an Information +filed by the Palm Beach County State Attorney's Office charging an offense for which the +defendant must register as a sex offender, that is, solicitation of minors to engage in prostitution, +in violation of FI. Stat. 796.03. The defendant and the Palm Beach County State Attorney's +Office shall make a joint, binding recommendation that the Court impose a sentence of at least +thirty (30) months, to be divided as follows: +(a) +the defendant shall begin by serving at least twenty (20) months in prison, +without any opportunity for withholding adjudication or sentencing, and +without probation or community control in lieu of imprisonment; and +(b) +following the term of imprisonment, the defendant shall serve ten (10) +months of community control/home confinement with electronic +monitoring. +8. +The defendant 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 in the state +court. +The defendant shall provide to the U.S. Attorney's Office copies of all proposed +3 + + +agreements with the Palm Beach County State Attorney's Office prior to entering into those +agreements. +The United States reserves the right to inform the Court and the probation +office of all facts pertinent to the sentencing process, including all relevant information +concerning the offenses committed, whether charged or not, as well as concerning the +defendant and the defendant's background, and to respond to any questions from the +Court and the Probation Office and to any misstatements of fact or law. Subject only to +the express terms of any agreed-upon sentencing recommendations contained in this +Agreement, this Office further reserves the right to make any recommendation as to the +quality and quantity of punishment. +11. The defendant is aware that the sentence has not yet been determined by the +Court. The defendant also is aware that any estimate of the probable sentencing range or +sentence that the defendant may receive, whether that estimate comes from the +defendant's attorney, the government, or the probation office, is a prediction, not a +promise, and is not binding on the government, the probation office or the Court. The +defendant understands further that any recommendation that the government makes to the +Court as to sentencing, whether pursuant to this agreement or otherwise, is not binding on +the Court and the Court may disregard the recommendation in its entirety. The defendant +understands and acknowledges, as previously acknowledged in paragraph 2 above, that +the defendant may not withdraw his plea based upon the Court's decision not to accept a +sentencing +recommendation +made by the defendant, the government, or a +recommendation made jointly by both the defendant and the government. +12. WAIVER OF RIGHT TO APPEAL AND COLLATERALLY +ATTACK THE SENTENCE. The defendant is aware that Title 18, United States Code, +Section 3742 affords the defendant the right to appeal the sentence imposed in this case. +Acknowledging this, in exchange for the undertakings made by the United States in this +4 + + +plea agreement, the defendant hereby waives all rights conferred by Section 3742 to +appeal any sentence imposed, including any restitution order, or to appeal the manner in +which the sentence was imposed, unless the sentence exceeds the maximum permitted by +statute or is the result of an upward departure or upward variance from the guideline +range that the Court establishes at sentencing. The defendant further voluntarily and +expressly waives, to the maximum extent permitted by federal law, the right to +collaterally attack his sentence in any post-conviction proceeding, including a motion on +any ground brought under 28 U.S.C. § 2254, 28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18 +U.S.C. § 3771. The defendant further understands that nothing in this agreement shall +affect the government's right and/or duty to appeal as set forth in Title 18, United States +Code, Section 3742(b). However, if the United States appeals the defendant's sentence +pursuant to Section 3742(b), the defendant shall be released from the above waiver of +appellate rights. By signing this agreement, the defendant acknowledges that he has +discussed the appeal waiver set forth in this agreement with his attorney. +13. +If the defendant fails in any way to fulfill each one of his obligations under +this Plea Agreement, the United States, and only the United States, may elect to be +released from its commitments under this Plea Agreement. If the United States elects to +void the Plea Agreement because of a breach by the defendant, then the United States +agrees not to use the defendant's guilty plea against him. However, the United States +may prosecute the defendant for any and all Federal crimes that he has committed related +to this case and may seek any sentence for such crimes up to and including the statutory +maximums. The defendant expressly waives any statute of limitations defense and any +constitutional or statutory speedy trial defense to such a prosecution, except to the extent +that such a defense exists as of the date he signs this Plea Agreement. Finally, the +defendant understands that his violation of the terms of this Plea Agreement would not +5 + + + + +This is the entire agreement and understanding between the United States +There are no other agreements, promises, representations, or +BY: R. ALEXANDER ACOSTA +UNITED STATES ATTORNEY +7 + + +D +UNITED STATES OF AMERICA +VS. +JEFFREY EPSTEIN, +Defendin +PLEA AGREEMENT +The United States Attorney forthe Southern District of Florida ("the United States"), +and Jeffrey Epstein (hereinafter referred to as the "defendant") enter into the following +agreement: +The defendant agrees to plead guilty to the Information which charges the +defendant as follows: Count 1 charges that thalfendant knowingly and intentionally +violated the privacy protection accorded to child victims by 18 U.S.C. § 3509; in violation +of Title 18, United States Code, Sections 403 and 2; and Count 2 charges that the defendant, +while in an airplane over the high seas, did knowingly commit a simple assault on a person +who was over the age of 16 years, that is, S.K.; in violation of Title 18, United States Code, +Section 113(a)(5). +The defendant is aware that the sentence will be imposed by the Court after +considering the Federal Sentencing Guidelines and Policy Statements (hereinafter + +9/15/20072:46pm + + +"Sentencing Guidelines"). The defendant acknowledges and understands that the Court will +compute an advisory sentence under the Sentencing Guidelines and that the applicable +guide if Till determined by the Court relying in part on the results of a PreSentence +Investigation by the Court's probation office, which investigation will commence after the +guilty plea has been entered. The defendant is also aware that, under certain circumstances, +the Court may depart from the advisory sentencing guideline range that it has computed, and +may raise or lower that arisory sentence under the Sentencing Guidelines. The defendant +is further aware and understands that the Court is required to consider the advisory guideline +range determined under the Sentencing Guidelines, but is not bound to impose that sentence; +the Court is permitted to tailor the ulfugate sentence in light of other statutory concerns, and +such sentence may be either more severe or less severe than the Sentencing Guidelines' +advisory sentence. Knowing these facts, the defendant understands and acknowledges that +the Court has the authority to impose any sentencerwithin and up to the statutory maximum +authorized by law for the offenses identified in paragraph 1 and that the defendant may not +withdraw the plea solely as a result of the sentence imposed. +The defendant further understands and acknowledges that, as to Count 1 of the +Information, the Court may impose a statutory maximum term of imprisonment of up to one +(1) year, to be followed by a term of supervised release of up to a maximum of one (1) year. +In addition to terms of imprisonment and supervised release, the Court may impose a fine of +up to $100,000. The defendant further understands and acknowledges that, as to Count 2 of +the Information, the Court may impose a statutory maximum term of imprisonment of up to + + + +six (6) months, to be followed by a term of supervised release of up to a maximum of one (1) +year. In addition to terms of imprisonment and supervised release, the Court may impose a +Tine of i 2 100,000. +The defendant further understands and acknowledges that, in addition to any +sentence imposed under paragraph 3 of this Agreement, a special assessment in the amount +of $50 will be imposed on the defendant, which must be paid at or before the time of +sentencing. +R +The defendant understands that the Court will order that he must pay full +restitution to all victims of the offense to which he is pleading guilty. The defendant +understands that the amount of restition owed to each victim will be determined at or +before sentencing. +The parties agree to jointly recommend that the defendant receive a sentence +of eighteen (18) months' imprisonment, to be foltowed by two (2) years of supervised +release; and a fine of $200,000. +The defendant agrees that, if any of the victims identified in the federal +investigation file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the +jurisdiction of the U.S. District Court for the Southern District of Florida over his person +and/or the subject matter, and the defendant will not contest that the identified victims are +persons who, while minors, were victims of violations of Title 18, United States Code, +Sections(s) 2422 and/or 2423. The United States agrees to provide the defendant's attorneys +with a list of the identified victims, which will not exceed forty, after the defendant has + + + +signed this agreement and has been sentenced. The United States further agrees to make a +motion with the United States District Court for the Southern District of Florida for the +appointment of a guardian ad litem for the identified victims and the defendant's counsel may +contact the identified victims through that guardian. +8. +The defendant agrees to plead guilty (not nolo contendere) to an Information +filed by the Palm Beach County State Attorney's Office charging an offense for which the +defendant must register as a sex offender, that is, solicitation of minors to engage in +prostitution, in violation of Fl. Stat. 796.03. The defendant agrees that he and the Palm +Beach County State Attorney's Office will make a joint, binding recommendation that the +Court impose a sentence of at least thirty (30) months, to be divided as follows: +(a) +the defendant shall begin by serving at least twenty (20) months in +prison, without any opportunity for withholding adjudication or +sentencing, and without probation or community control in lieu of +imprisonment; and +(b) +following the term of imprisonment, the defendant shall serve ten (10) +months of community control/home confinement with electronic +monitoring. +T +The defendant agrees to waive all challenges to the Information filed by the +State Attorney's Office and to waive the right to appeal his conviction and sentence in the +state court. +The defendant agrees that he will provide to the U.S. Attorney's Office copies + + + +of all proposed agreements with the Palm Beach County State Attorney's Office prior to +entering into those agreements. +D +The United States reserves the right to inform the Court and the probation +office of all facts pertinent to the sentencing process, including all relevant information +concerning the offenses committed, whether charged or not, as well as concerning the +defendant and the defendant's background, and to respond to any questions from the Court +and the Probation Orite and to any misstatements of fact or law. Subject only to the express +terms of any agreed-upon sentencing recommendations contained in this Agreement, this +Office further reserves the right to make any recommendation as to the quality and quantity +of punishment. +A +12. +The defendant is aware that the sentence has not yet been determined by the +Court. The defendant also is aware that any estimate of the probable sentencing range or +sentence that the defendant may receive, whether that estimate comes from the defendant's +attorney, the government, or the probation office, is a prediction, not a promise, and is not +binding on the government, the probation office or the Court. The defendant understands +further that any recommendation that the government makes to the Court as to sentencing, +Whether pursuant to this agreement or otherwise, is not binding ole the Court and the Court +may disregard the recommendation in its entirety. The defendant understands and +acknowledges, as previously acknowledged in paragraph 2 above, that the defendant may not +withdraw his plea based upon the Court's decision not to accept a sentencing +recommendation made by the defendant, the government, or a recommendation made jointly + + + +by both the defendant and the government. +13. +WAIVER OF RIGHT TO APPEAL AND COLLATERALLY ATTACK +THE SIN UNCE. The defendant is aware that Title 18, United States Code, Section 3742 +affords the defendant the right to appeal the sentence imposed in this case. Acknowledging +this, in exchange for the undertakings made by the United States in this plea agreement, the +defendant hereby waives all rights conferred by Section 3742 to appeal any sentence +imposed, including any postitution order, or to appeal the manner in which the sentence was +imposed, unless the sentence exceeds the maximum permitted by statute or is the result of +an upward departure or upward variance from the guideline range that the Court establishes +at sentencing. The defendant further yoluntarily and expressly waives, to the maximum +extent permitted by federal law, the right to collaterally attack his sentence in any postconviction proceeding, including a motion on any ground brought under 28 U.S.C. § 2254, +28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18 U.S.C. §B771. The defendant further understands +that nothing in this agreement shall affect the government's right and/or duty to appeal as set +forth in Title 18, United States Code, Section 3742(b). However, if the United States appeals +the defendant's sentence pursuant to Section 3742(b), the defendant shall be released from +the above waiver of appellate rights. By signing this agreement, the defendant acknowledges +that he has discussed the appeal waiver set forth in this agreement with his attorney. +If the defendant fails in any way to fulfill each one of his obligations under this +Plea Agreement, the United States, and only the United States, may elect to be released from +its commitments under this Plea Agreement. If the United States elects to void the Plea + + + +Agreement because of a breach by the defendant, then the United States agrees not to use the +defendant's guilty plea against him. However, the United States may prosecute the defendant +for any indull Federal crimes that he has commited related to this case and may seck any +sentence for such crimes up to and including the statutory maximums. The defendant +expressly waives any statute of limitations defense and any constitutional or statutory speedy +trial defense to such a prosecution, except to the extent that such a defense exists as of the +date ho signs this Pleasemen. Final, the defendant understand that his violation of +the terms of this Plea Agreement would not entitle him to withdraw his guilty plea. +15. This is the entire agreement and understanding between the United States and +the defendant. There are no other agents, promises, representations, or understandings. +R. ALEXANDER ACOSTA +UNITED STATES ATTORNEY +T +JAY LEFKOWITZ., ESQ. + + + +UNITE +BOATES OF AMERICA +VS. +JEFFREY EPSTEIN, +Defendant. +R +PLEA AGREEMENT +The United States Attorney for the Southern District of Florida ("the United States"), +and Jeffiey Epstein (hercinafter refered to as thefitorindant) enter into the following +agreement: +The defendant agrees to plead guilty to the Information which charges the +defendant as follows: Count 1 charges that the defendant intentionally harassed another person, +that is Jane Doe 41, in an attempt to delay, prevent, and dissuade Jar-Doe t from reporting to a +law enforcement officer of the United States the commission of a federal offense; in violation of +Title 18, United States Code, Sections 1512(d)(2) and 2; and Count 2 charges that the defendant, +while in an airplane over the high seas, did knowingly commit a simple assault on a person who was +overthe as hat's ki idion of it 8, ried sues code, sociate s +2. +The defendant is aware that the sentence will be imposed by the Court after +considering the Federal Sentencing Guidelines and Policy Statements (hereinafter + +9/14/20079:48am + + +"Sentencing Guidelines"). The defendant acknowledges and understands that the Court will +compute an advisory sentence under the Sentencing Guidelines and that the applicable +guidelines will be determined by the Court relying in part on the results of a Pre-Sentence +Investigation by the Court's probation office, which investigation will commence after the +guilty plea has been entered. The defendant is also aware that, under certain circumstances, +the Court may depart from the advisory sentencing guideline range that it has computed, and +may raise or lower that advisary secule under the sentencing Guidelines. The defendant +is further aware and understands that the Court is required to consider the advisory guideline +range determined under the Sentencing Guidelines, but is not bound to impose that sentence; +the Court is permitted to tailor the ultimate sentence in light of' other statutory concerns, and +such sentence may be either more severe or less +severe than the Sentencing Guidelines' +advisory sentence. Knowing these facts, the defendant understands and acknowledges that +the Court has the authority to impose any sentence within and up to the statutory maximum +authoried by lav for the fires ioni red in pargriph andey he defendant may not +withdraw the plea solely as a result of the sentence imposed. +The defendant further understands and acknowledges that, as to Count 1 of the +Information, the Court may impose a statutory maximum term of imprisonment of up to one +(1) year, to be followed by a term of supervised release of up to a maximum of go (1) year. +In addition to terms of imprisonment and supervised release, the Court may impose a fine of +up to $100,000. The defendant further understands and acknowledges that, as to Count 2 of +the Information, the Court may impose a statutory maximum term of imprisonment of up to + + + +six (6) months, to be followed by a term of supervised release of up to a maximum of one (1) +year. In addition to terms of imprisonment and supervised release, the Court may impose a +The defendant further understands and acknowledges that, in addition to any +sentence imposed under paragraph 3 of this Agreement, a special assessment in the amount +of $50 will be imposed on the defendant, which must be paid at or before the time of +sentencing. +R +The defendant understands that the Court will order that he must pay full +restitution to all victims of the offense to which he is pleading guilty. The defendant +understands that the amount of restitution owed to each victim will be determined at or +before sentencing. +The parties agree to jointly recommend that the defendant receive a sentence +of eighteen (18) months' imprisonment, to be followed by two (2) years of supervised +release; and a fine of $200,000. +7. +The drea to oh, ray of victim let re into federal investigation. +file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the jurisdiction of the U.S. +District Court for the Southern District of Florida over his person and/or the subject matter, and the +defendant will not contest that the identified victims are persons who, while minors, were victims +of violations of Title 18, United States Code, Sections(s) 2422 and/or 2423. The United States +agrees to provide the defendant's attorneys with a list of the identified victims, which will not +exceed forty, after the defendant has signed this agreement and has been sentenced. The United + + + +States further agrees to make a motion with the United States District Court for the Southern District +of Florida for the appointment of a guardian ad litem for the identified victims and the defendant's +counsel may contact the identified victims through that guardian. +The defendant agrees to plead guilty (not nolo contendere) to an Information filed +by the Palm Beach County State Attorney's Office charging an offense for which the defendant must +register as a sex offender, that is, solicitation of minors to engage in prostitution, in violation of Fl. +Stat. 796.03. The defendant agrees that he and the Palm Beach County State Attorney's Office will +make a joint, binding recommendation that the Court impose a sentence of at least thirty (30) +months, to be divided as follows: +(a) +the defendant shall begin by serving at least twenty (20) months in prison, +without any opportunity for withholding adjudication or sentencing, and +without probation or community control in lieu of imprisonment; and +(b) +following the term of imprisonment, the defendant shall serve ten (10) +months of community control/home confinement with electronic monitoring. +9. +The defendant agrees to waive all challenges to the Information filed by the State +Attorney's Office and to waive the right to appeal his conviction and sentence in the state court. +The defendant agrees that he will provide to the U.S. Attorney's Office copies of all +proposed agreements with the Palm Beach County State Attorney's Office prior to entering into +those agreements. +The United States reserves the right to inform the Court and the probation +office of all facts pertinent to the sentencing process, including all relevant information +concerning the offenses committed, whether charged or not, as well as concerning the + + + +defendant and the defendant's background, and to respond to any questions from the Court +and the Probation Office and to any misstatements of fact or law. Subject only to the express +terms ofany agreed-upon sentencing recommendations contained in this Agreement, this +Office fürther reserves the right to make any recommendation as to the quality and quantity +of punishment. +The defendant is aware that the sentence has not yet been determined by the +Court. The defendant also is award hilt any estimate of the probable sentencing range or +sentence that the defendant may receive, whether that estimate comes from the defendant's +attorney, the government, or the probation office, is a prediction, not a promise, and is not +binding on the government, the probation office or the Court. The defendant understands +further that any recommendation that the governmen makes to the Court as to sentencing, +whether pursuant to this agreement or otherwise, is not binding on the Court and the Court +may disregard the recommendation in its entirety. The defendant understands and +acknowledges, as previously acknowledged in paragraph 2 above that the defendant may not +withdraw his plea based upon the Court's decision not to accept a sentencing +recommendation made by the defendant, the government, or a recommendation made jointly +by both the defendant and the government. +13. +WAIVEROF RIGHT TO APPEAL AND COLLATERAL ATTACK +THE SENTENCE. The defendant is aware that Title 18, United States Code, Section 3742 +affords the defendant the right to appeal the sentence imposed in this case. Acknowledging +this, in exchange for the undertakings made by the United States in this plea agreement, the + + + +defendant hereby waives all rights conferred by Section 3742 to appeal any sentence +imposed, including any restitution order, or to appeal the manner in which the sentence was +imposed, +-unless the sentence exceeds the maximum permitted by statute or is the result of +an upward departure or upward variance from the guideline range that the Court establishes +at sentencing. The defendant further voluntarily and expressly waives, to the maximum +extent permitted by federal law, the right to collaterally attack his sentence in any postconviction proceeding, including a pillon on any ground brought under 28 U.S.C. 2254, +28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18 U.S.C. § 3771. The defendant further understands +that nothing in this agreement shall affect the government's right and/or duty to appeal as set +forth in Title 18, United States Code, Section 3742(b). However, if the United States appeals +the defendant's sentence pursuant to Section 3742 b) the defendant shall be released from +the above waiver of appellate rights. By signing this agreement, the defendant acknowledges +that he has discussed the appeal waiver set forth in this agreement with his attorney. +If the defendant fails in any way to fulfill each one of his obligations under this +Plea Agreement, the United States, and only the United States, may elect to be released from +its commitments under this Plea Agreement. If the United States elects to void the Plea +Agreement because of a breach by the defendant, then the United States agrees not to use the +defendant's guilty pleagainsthim. However, the United States may prosecute ledetendant +for any and all Federal crimes that he has committed related to this case and may seek any +sentence for such crimes up to and including the statutory maximums. The defendant +expressly waives any statute of limitations defense and any constitutional or statutory speedy + + + +• trial defense to such a prosecution, except to the extent that such a defense exists as of the +date he signs this Plea Agreement. Finally, the defendant understands that his violation of +the terms of this Plea Agreement would not entitle him to withdraw his guilty plea. +This is the entire agreement and understanding between the United States and +the defendant. There are no other agreements, promises, representations, or understandings. +R. ALEXANDER ACOSTA +UNITED STATES ATTORNEY +JEFFRI APSTEIN, DEFENDANT +ATTORNEY FOR DEEMDANT +T + + + +Case No. _ +UNITED STATES OF AMERICA +VS. +JEFFREY EPSTEIN, +Defendant. +PLEA AGREEMENT +The United States Attorney for the Southern District of Florida ("the United +States"), Jeffrey Epstein (hereinafter referred to as the "defendant"), and counsel for the +defendant, subject to approval by the Court, have agreed upon a negotiated plea pursuant +to Rule 11 of the Federal Rules of Criminal Procedure and governed in part by Rule +11(c)(1)(C), the terms of which are as follows: +1. The defendant agrees to plead guilty to the Information which charges that +the defendant did knowingly and willfully combine, conspire, confederate and agree with +persons 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, +and entice individuals who had not attained the age of 18 years 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 37l. +The defendant is aware that the statutory maximum sentence for the offense +listed in paragraph one is five (5) years' imprisonment, to be followed by up to three +1 +9/7/2007 9:31am + + +years' supervised release. In addition to terms of imprisonment and supervised release, +the Court may impose a fine of up to $250,000. +The defendant also has been advised and understands that under the Sex +Offender Registration and Notification Act, he must register as a sex offender and keep +the registration current in each of the following jurisdictions: where he resides; where he +is an employee; and where he is a student. The defendant understands and acknowledges +that the requirements for registration include providing his name, his residence address, +and the names and addresses of any places where he is or will be an employee or a +student, among other information. The defendant further understands that, not later than +three business days after any change of name, residence, employment, or student status, +he must inform at least one jurisdiction in which he resides, is an employee, or is a +student of such change. The defendant has been advised, and understands, that failure to +comply with these obligations subjects him to prosecution for failure to register under +federal law, 18 U.S.C. § 2250, which is punishable by a fine or imprisonment, or both. +4. +The defendant further understands and acknowledges that, in addition to +any sentence imposed under paragraph 2 of this Agreement, a special assessment in the +amount of $100 will be imposed on the defendant, which must be paid at or before the +time of sentencing. +The defendant understands that the Court will order that he must pay full +restitution to all victims of the offense to which he is pleading guilty. The defendant +understands that the amount of restitution owed to cach victim will be determined at or +before sentencing. +This Plea Agreement is governed, in part, by Federal Rule of Criminal +Procedure 11(c)(1)(C). The parties have agreed that the defendant's sentence imposed by +the Court shall be two (2) years' imprisonment to be followed by three (3) years' +supervised release, and a $250,000 fine. If the Court accepts and imposes the agreed +2 + + +term of imprisonment, the defendant may not withdraw this plea. +The United States reserves the right to inform the Court and the probation +office of all facts pertinent to the sentencing process, including all relevant information +concerning the offenses committed, whether charged or not, as well as concerning the +defendant and the defendant's background, and to respond to any questions from the +Court and the Probation Office and to any misstatements of fact or law. +8. +The defendant understands and agrees that federal law mandates that he be +taken into federal custody upon the entry of his guilty plea. +WAIVER OF RIGHT TO APPEAL AND COLLATERALLY +ATTACK THE SENTENCE. The defendant is aware that Title 18, United States Code, +Section 3742 affords the defendant the right to appeal the sentence imposed in this case. +Acknowledging this, in exchange for the undertakings made by the United States in this +plea agreement, the defendant hereby waives all rights conferred by Section 3742 to +appeal any sentence imposed, including any restitution order, or to appeal the manner in +which the sentence was imposed, unless the sentence exceeds the maximum permitted by +statute or is the result of an upward departure or upward variance from the guideline +range that the Court establishes at sentencing. The defendant further voluntarily and +expressly waives, to the maximum extent permitted by federal law, the right to +collaterally attack his sentence in any postconviction proceeding, including a motion on any ground brought under 28 U.S.C. § +2254, 28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18 U.S.C. § 3771. The defendant further +understands that nothing in this agreement shall affect the government's right and/or duty +to appeal as set forth in Title 18, United States Code, Section 3742(b). However, if the +United States appeals the defendant's sentence pursuant to Section 3742(b), the defendant +shall be released from the above waiver of appellate rights. By signing this agreement, +the defendant acknowledges that he has discussed the appeal waiver set forth in this +3 + + +If the defendant fails in any way to fulfill each one of his obligations under +this Plea Agreement, the United States, and only the United States, may elect to be +released from its commitments under this Plea Agreement. If the United States elects to +void the Plea Agreement because of a breach by the defendant, then the United States +agrees not to use the defendant's guilty plea against him. However, the United States +may prosecute the defendant for any and all Federal crimes that he has committed related +to this case and may seek any sentence for such crimes up to and including the statutory +maximums. +The defendant expressly waives any statute of limitations defense and any +constitutional or statutory speedy trial defense to such a prosecution, except to the extent +that such a defense exists as of the date he signs this Plea Agreement. Finally, the +defendant understands that his violation of the terms of this Plea Agreement would not +11. +This is the entire agreement and understanding between the United States +There are no other agreements, promises, representations, or +R. ALEXANDER ACOSTA +UNITED STATES ATTORNEY +A. MARIE VILLAFAÑA +ASSISTANT UNITED STATES ATTORNEY +4 + + + + +UNITED STATES OF AMERICA +VS. +JEFFREY EPSTEIN, +Defendant. +PLEA AGREEMENT +The United States Attorney for the Southern District of Florida ("the United +States"), Jeffrey Epstein (hereinafter referred to as the "defendant"), and counsel for the +defendant, subject to approval by the Court, have agreed upon a negotiated plea pursuant +to Rule 11 of the Federal Rules of Criminal Procedure and governed in part by Rule +11(c)(1)(C), the terms of which are as follows: +1. +The defendant agrees to plead guilty to the Information which charges that +the defendant did knowingly and willfully combine, conspire, confederate and agree with +persons 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, +and entice individuals who had not attained the age of 18 years 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. +The defendant is aware that the statutory maximum sentence for the offense +listed in paragraph one is five (5) years' imprisonment, to be followed by up to three +1 +9/7/2007 1:17pm + + +years' supervised release. In addition to terms of imprisonment and supervised release, +the Court may impose a fine of up to $250,000. +The defendant also has been advised and understands that under the Sex +Offender Registration and Notification Act, he must register as a sex offender and keep +the registration current in each of the following jurisdictions: where he resides; where he +is an employee; and where he is a student. The defendant understands and acknowledges +that the requirements for registration include providing his name, his residence address, +and the names and addresses of any places where he is or will be an employee or a +student, among other information. The defendant further understands that, not later than +three business days after any change of name, residence, employment, or student status, +he must inform at least one jurisdiction in which he resides, is an employee, or is a +student of such change. The defendant has been advised, and understands, that failure to +comply with these obligations subjects him to prosecution for failure to register under +federal law, 18 U.S.C. § 2250, which is punishable by a fine or imprisonment, or both. +The defendant further understands and acknowledges that, in addition to +any sentence imposed under paragraph 2 of this Agreement, a special assessment in the +amount of $100 will be imposed on the defendant, which must be paid at or before the +time of sentencing. +The defendant understands that the Court will order that he must pay full +restitution to all victims of the offense to which he is pleading guilty. The defendant +understands that the amount of restitution owed to each victim will be determined at or +before sentencing. +This Plea Agreement is governed, in part, by Federal Rule of Criminal +Procedure 11(c)(1)(C). The parties have agreed that the defendant's sentence imposed by +the Court shall be two (2) years' imprisonment to be followed by three (3) years' +supervised release, and a $250,000 fine. If the Court accepts and imposes the agreed +2 + + +term of imprisonment, the defendant may not withdraw this plea. If the Court rejects the +agreement, and the defendant elects to withdraw his plea, the United States may +prosecute the defendant for any and all Federal crimes that he has committed related to +this case and may seek any sentence for such crimes up to and including the statutory +maximums. +The United States reserves the right to inform the Court and the probation +office of all facts pertinent to the sentencing process, including all relevant information +concerning the offenses committed, whether charged or not, as well as concerning the +defendant and the defendant's background, and to respond to any questions from the +Court and the Probation Office and to any misstatements of fact or law. +8. +The defendant understands and agrees that federal law mandates that he be +taken into federal custody upon the entry of his guilty plea. +WAIVER OF RIGHT TO APPEAL AND COLLATERALLY +ATTACK THE SENTENCE. The defendant is aware that Title 18, United States Code, +Section 3742 affords the defendant the right to appeal the sentence imposed in this case. +Acknowledging this, in exchange for the undertakings made by the United States in this +plea agreement, the defendant hereby waives all rights conferred by Section 3742 to +appeal any sentence imposed, including any restitution order, or to appeal the manner in +which the sentence was imposed, unless the sentence exceeds the maximum permitted by +statute or is the result of an upward departure or upward variance from the guideline +range that the Court establishes at sentencing. The defendant further voluntarily and +expressly waives, to the maximum extent permitted by federal law, the right to +collaterally attack his sentence in any postconviction proceeding, including a motion on any ground brought under 28 U.S.C. § +2254, 28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18 U.S.C. § 3771. The defendant further +3 + + +understands that nothing in this agreement shall affect the government's right and/or duty +to appeal as set forth in Title 18, United States Code, Section 3742(b). However, if the +United States appeals the defendant's sentence pursuant to Section 3742(b), the defendant +shall be released from the above waiver of appellate rights. By signing this agreement, +the defendant acknowledges that he has discussed the appeal waiver set forth in this +If the defendant fails in any way to fulfill each one of his obligations under +this Plea Agreement, the United States, and only the United States, may elect to be +released from its commitments under this Plea Agreement. If the United States elects to +void the Plea Agreement because of a breach by the defendant, then the United States +agrees not to use the defendant's guilty plea against him. However, the United States +may prosecute the defendant for any and all Federal crimes that he has committed related +to this case and may seek any sentence for such crimes up to and including the statutory +maximums. The defendant expressly waives any statute of limitations defense and any +constitutional or statutory speedy trial defense to such a prosecution, except to the extent +that such a defense exists as of the date he signs this Plea Agreement. Finally, the +defendant understands that his violation of the terms of this Plea Agreement would not +11. This is the entire agreement and understanding between the United States +There are no other agreements, promises, representations, or +R. ALEXANDER ACOSTA +UNITED STATES ATTORNEY +4 + + +5 \ No newline at end of file