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: 18 U.S.C. § 371 18 U.S.C. § 1591(aX1) 18 U.S.C. § 1591(aX2) 18 U.S.C. § 2422(6) 18 U.S.C. § 2423(e) 18 U.S.C. § 2423(d) 18 U.S.C. § 2423(6) UNITED STATES &AMERICA vs. JEFFREY EPSTEIN, and Defendants. A INDICTMENT The Grand Jury charges that: BACKGROUND At all times relevant to this Indictment: 1. Defe
ession. Confidential sod Privileged — Attorney Work Product EXHIBIT B-123 EFTA00224636 Division hi f o the Criminal Division , First Assistant United States Attorney , United States Attorney R. Alexander Acosta as well as various members of the Child Exploitation e i Sectio (CEOS) at the Department of
mate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration. 13. The parties anticipate that t
ge 19 at the time, confessed and said that he wanted to "talk" to my daughter who was then 16. He also confessed to a prior unrelated break in which Zirulnikoff caressed the inner thigh of a 15 year old female. Zirulnikoff who had graduated from my daughter's high school in June 2006, dated my daughter's fr
s Code, § 2423(b) as well as the The case involving "Jonathan Zirulnikoff" involved a March 7, 2007 early morning attempted break-in of my' house. Zirulnikoff, age 19 at the time, confessed and said that he wanted to "talk" to my daughter who was then 16. He also confessed to a prior unrelated break in whi
ATTORNEY FOR JEFFREY EPSTEIN EFTA00225211 U.S. Department nfitist ire United States Attorney Southern District of Florida R ALEXANDER ACOSTA UNITEDSTATES ATTORNEY DELIVERY BY FACSIMILE Lilly Ann Sanchez Fowler White Burnett, PA 1395 Brickell Ave, 14th Floor Miami, FL 33131 Re: Jeffrey Epstein D
leged — Attorney Work Product EXHIBIT B-123 EFTA00225178 Division Andrew Lourie, Chief of the Criminal Division Matthew Menchel', First Assistant United States Attorney Jeffrey H. Sloman', United States Attorney R. Alexander Acosta as well as various members of the Child Exploitation and Obscenity Section (
mate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration. 13. The parties anticipate that t
423(b) as well as the 14 The case involving "Jonathan Zirulnikoff " involved a March 7, 2007 early morning attempted break-in of my/Sloman's house. Zirulnikoff, age 19 at the time, confessed and said that he wanted to "talk" to my daughter who was then 16. He also confessed to a prior unrelated break in whi
ge 19 at the time, confessed and said that he wanted to "talk" to my daughter who was then 16. He also confessed to a prior unrelated break in which Zirulnikoff caressed the inner thigh of a 15 year old female. Zirulnikoff who had graduated from my daughter's high school in June 2006, dated my daughter's fr
e following language regarding the 2255 provision: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Tide 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein been tried federally and convicted
enses that must be proven The case involving "Jonathan Zirulnikoff" involved a March 7, 2007 early morning attempted break-in of my/Sloman's house. Zirulnikoff, age 19 at the time, confessed and said that he wanted to `talk" to my daughter who was then 16. He also confessed to a prior unrelated break in whi
ge 19 at the time, confessed and said that he wanted to `talk" to my daughter who was then 16. He also confessed to a prior unrelated break in which Zirulnikoff caressed the inner thigh of a 15 year old female. Zirulnikoff who had graduated from my daughter's high school in June 2006, dated my daughter's fr
following language regarding the 2255 provision: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein been tried federally and convicted
es that must be proven 8 The case involving "Jonathan Zirulnikoff • involved a March 7, 2007 early morning attempted break-in of my/Sloman's house. Zirulnikoff, age 19 at the time, confessed and said that he wanted to "talk° to my daughter who was then 16. He also confessed to a prior unrelated break in whi
ge 19 at the time, confessed and said that he wanted to "talk° to my daughter who was then 16. He also confessed to a prior unrelated break in which Zirulnikoff caressed the inner thigh of a 1 S year old female. Zirulnikoff who had graduated from my daughter's high school in June 2006, dated my daughters fr
following language regarding the 2255 provision: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, § 2255, will have the same rights to proceed under § 2255 as she would have had, if Mr. Epstein been tried federally and convicted of an enume
of a child. They also 14 The case involving "Jonathan Zirulnikoff" involved a March 7, 2007 early morning attempted break-in of my/Sloman's house. Zirulnikoff, age 19 at the time, confessed and said that he wanted to "talks to my daughter who was then 16. He also confessed to a prior unrelated break in whi
ge 19 at the time, confessed and said that he wanted to "talks to my daughter who was then 16. He also confessed to a prior unrelated break in which Zirulnikoff caressed the inner thigh of a 15 year old female. Zirulnikoff who had graduated from my daughter's high school in June 2006, dated my daughter's fr
following language regarding the 2255 provision: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein been tried federally and convicted
ses that must be proven 8 The case involving "Jonathan Zirulnikoff" involved a March 7, 2007 early morning attempted break-in of my/Sloman's house. Zirulnikoff, age 19 at the time, confessed and said that he wanted to "talk" to my daughter who was then 16. He also confessed to a prior unrelated break in whi
ge 19 at the time, confessed and said that he wanted to "talk" to my daughter who was then 16. He also confessed to a prior unrelated break in which Zirulnikoff caressed the inner thigh of a 15 year old female. Zirulnikoff who had graduated from my daughter's high school in June 2006, dated my daughter's fr
following language regarding the 2255 provision: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, § 2255, will have the same rights to proceed under § 2255 as she would have had, if Mr. Epstein been tried federally and convicted of an enume
of a child. They also 14 The case involving "Jonathan Zirulnikoff • involved a March 7, 2007 early morning attempted break-in of my/Sloman's house. Zirulnikoff, age 19 at the time, confessed and said that he wanted to "talk" to my daughter who was then 16. He also confessed to a prior unrelated break in whi
ge 19 at the time, confessed and said that he wanted to "talk" to my daughter who was then 16. He also confessed to a prior unrelated break in which Zirulnikoff caressed the inner thigh of a 15 year old female. Zirulnikoff who had graduated from my daughter's high school in June 2006, dated my daughter's fr
mate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration. 13. The parties anticipate that t
2423(b) as well as the " The case involving "Jonathan Zirulnikoff" involved a March 7, 2007 early morning attempted break-in of my/Sloman's house. Zirulnikoff, age 19 at the time, confessed and said that he wanted to "talk" to my daughter who was then 16. He also confessed to a prior unrelated break in whi
ge 19 at the time, confessed and said that he wanted to "talk" to my daughter who was then 16. He also confessed to a prior unrelated break in which Zirulnikoff caressed the inner thigh of a 15 year old female. Zirulnikoff who had graduated from my daughter's high school in June 2006, dated my daughter's fr
Entities connected to both United States and Zirulnikoff

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATIONLeon Black
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Alexander Acosta
PERSONJane Doe
PERSONFBI
ORGANIZATION
Kenneth Marra
PERSON
New York
LOCATION
Bill Clinton
PERSONJack Goldberger
PERSON
Virginia Giuffre
PERSON
Joe Biden
PERSONMartin Weinberg
PERSON
Jay Lefkowitz
PERSON
A. Marie Villafana
PERSON
the United States District Court
ORGANIZATION