Case 9:08-cv-80736-KAM Document 361-50 Entered on FLSD Docket 02/10/2016 Page 3 of 7 Recipient Read Gerald Lefcourt Sloman, Jeff (USAFLS) Read: 9110/2007 5:23 PM Lourie, Andrew (USAFLS) Read: 0J10/2007 10:47 PM Vera, E.J. (USAFLS) 2 RFP MIA 000059 EFTA00184669

Case 9:08-cv-80736-KAM Document 361-50 Entered on FLSD Docket 02/10/2016 Page 4 of 7 IN RE: INVESTIGATION OF JEFFREY EPSTEIN I NON-PROSECUTION AGREEMENT IT APPEARING that Jeffrey Epstein (hereinafter "Epstein") has committed offenses against the United States from in or around 2001 through in or around October 2005, including: (I) knowingly and willfully conspiring with others known and unknown to commit an offense against the United States, that is, to use a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution, in violation of Title 18, United States Code, Section 2422(b); all in violation of Title 18, United States Code, Section 371; (2) knowingly and willfully conspiring with others known and unknown to travel in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(0, with minor females, in violation of Title 18, United States Code, Section 2423(b); all in violation of Title 18, United States Code, Section 2423(e); (3) using a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2; (4) traveling in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f), with minor females; in violation of Title 18, United States Code, Section 2423(b); and (5) knowingly, in and affecting interstate and foreign commerce, recruiting, enticing, and obtaining by any means a person, knowing that the person had not attained the age of 18 years and would be caused to engage in a commercial sex act as defined in 18 U.S.C. § 1591(c)(I); in violation of Title 18, United States Code, Sections 1591(a)(I) and 2; and IT APPEARING that Epstein has accepted responsibility for his behavior by his signature on this Agreement; and Page 1 of 4 RFP MIA 000060 EFTA00184670

Case 9:08-cv-80736-KAM Document 361-50 Entered on FLSD Docket 02/10/2016 Page 5 of 7 IT APPEARING, after an investigation of the offenses and Epstein's background, that the interest of the United States and Epstein's own interest and the interest of justice will be served by the following procedure; THEREFORE, on the authority of , United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the following conditions and the requirements of this Agreement set forth below. Should Epstein violate any of the conditions of this Agreement, the United States Attorney may at any time initiate prosecution against Epstein for any offense. In this case, the United States Attorney will furnish Epstein with notice specifying the condition(s) of the Agreement that he has violated. After timely fulfilling all the terms and conditions of the Agreement, no prosecution for the offenses set out on page I of this Agreement will be instituted in this District, and the charges against Epstein if any, will be dismissed. Terms of the Agreement: 1. Epstein shall plead guilty (not nob contendere) to an Information filed by the State Attorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, the "State Attorney's Office")charging violations of the following Florida Statutes: (a) (b) lewd and lascivious battery on a child, in violation of Fl. Stat. 800.04(4); solicitation of minors to engage in prostitution, in violation of Fl. Stat. 796.03; and (c) engaging in sexual activity with minors at least sixteen years of age, in violation of Fl. Stat. 794.05. 2. Epstein and the State Attorney's Office shall make a joint, binding recommendation that the Court impose a thirty (30) month sentence to be divided as follows: (a) Epstein 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, Epstein shall serve ten (10) Page 2 of 4 RFP WA 000061 EFTA00184671

Case 9:08-cv-80736-KAM Document 361-50 Entered on FLSD Docket 02/10/2016 Page 6 of 7 a months of community control. 3. Epstein shall waive all challenges to the Information filed by the State Attorney's Office and shall waive the right to appeal his conviction and sentence. 4. Epstein shall provide to the U.S. Attorney's Office copies of all proposed agreements with the State Attorney's Office prior to entering into those agreements. 5. Epstein agrees that, if any of the victims identified in the federal investigation file suit pursuant to 18 U.S.C. § 2255, Epstein 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 Epstein 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. 6. The United States shall provide Epstein's attorneys with a list of the identified victims, which will not exceed forty, after Epstein has signed this agreement and has been sentenced. The United States shall 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 Epstein's counsel may contact the identified victims through that counsel. 7. Epstein shall enter his guilty plea and be sentenced not later than September 28, 2007, and shall begin service of his sentence not later than October 15, 2007. 8. With credit for gain time, Epstein shall serve at least 17 months in a state correctional institution. By signing this agreement, Epstein asserts and certifies that each of these terms is material to this agreement and is supported by independent consideration and that a breach of any one of these conditions allows the United States to elect to terminate the agreement and to investigate and prosecute Epstein for any and all federal offenses. By signing this agreement, Epstein asserts and certifies that he is aware of the fact that the Sixth Amendment to the Constitution of the United States provides that in all criminal prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further is aware that Rule 48(b) of the Federal Rules of Crimi nal Procedure provides that the Court may dismiss an indictment, information, or complaint for unnecessary delay in presenting a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein hereby requests that the United States Attorney for the Southern District of Florida defer such prosecution. Epstein agrees and consents that any delay from the date of this Agreement to the date of initiation of prosecution, as provided Page 3 of 4 RFP MIA 000062 EFTA00184672

Case 9:08-cv-80736-KAM Document 361-50 Entered on FLSD Docket 02/10/2016 Page 7 of 7 for in the terms expressed herein, shall be deemed to be a necessary delay at his own request, and he hereby waives any defense to such prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the United States to a speedy trial or to bar the prosecution by reason of the running of the statute of limitations for a period of months equal to the period between the signing of this agreement and the breach of this agreement. Epstein further asserts and certifies that he understands that the Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all felonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees and consents that, if a prosecution against him is instituted, it may be by way of an Information signed and filed by the United States Attorney, and hereby waives his right to be indicted by a grand jury. By signing this agreement, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the conditions of this Non-Prosecution Agreement and agrees to comply with them. Dated: JEFFREY EPSTEIN Dated: GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN Dated: UNITED STATES ATTORNEY Page 4 of 4 RFP MIA 000063 EFTA00184673

Case 9:08-cv-80736-KAM Document 361-51 Entered on FLSD Docket 02/10/2016 Page 1 of 3 EXHIBIT 511 ( EFTA00184674

Case 9:08-cv-80736-KAM Document 361-51 Entered on FLSD Docket 02/10/2016 Page 2 of 3 (USAFLS) i ron fr Jay Lefkowitz PLeflowltz(gkIrkland.com] t c Wednesday. September 12, 2007 5:55 PM .(USAFLS) c: Laurie, Andrew (USAFLS) Subject: Re: Jeffrey Epstein - meant to copy you on my first attempt to respond to M. We appreciate the courtesy of today's meeting and your agreement and M. •We understand the concerns you are raising and will work over the next few days to come up with a mutually acceptable solution. I will speak with you no later than Monday, and in the interim, if we come up with a solution, we will be in touch with you. Best, Jay coal ----- From: a Ann C. XUSAFLS\)" I Sent: 09/12/2007 03:43 PM AST To: Jay Lefkowitz Cc: "Laurie, Andrew XUSAFL.S1)" Subject: Jeffrey Epstein lik — It was nice seeing you again. and I talked with I and Jeff. We are all satisfied in principle with the agreement, but the Office is unc 'table with the rec nded federal charge. Specifically, we are concerned about the effect of taking the position that Mr. Epstein's house is in the special maritime and territorial jurisdiction of the United States, and we have no evidence of any assaults occurring either on Mr. Epstein's plane or offshore from his residence. We are hoping that you can find an alternative federal statute that can be used. I also will wait to hear from Jack Goldberger to discuss logistics. Thank you. A. Assistant U.S. Attorney 4, RFP MIA 000072 EFTA00184675

Case 9:08-cv-80736-KAM Document 361-51 Entered on FLSD Docket 02/10/2016 Page 3 of 3 *********************************** ************ ************ The information contained in this communication is 4 fi attorney-client dential, may be atto e ey-client privileged, may stitute inside inforrnation, and is intended only for use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to postmasterakirkland.com, and destroy this communication and all copies thereof, including all attachments. ******** ***** ***** ** ***** ********************************** 2 RFP MIA 000073 EFTA00184676

Case 9:08-cv-80736-KAM Document 361-52 Entered on FLSD Docket 02/10/2016 Page 1 of 10 EXHIBIT 52 EFTA00184677

Case 9:08-cv-80736-KAM Document 361-52 Entered on FLSD Docket 02/10/2016 Page 2 of 10 D vs. JEFFREY EPSTEIN; Defendant. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA. CASE NO. 18 U.S.C. § 403 18 U.S.C. § 113(a)(5) UNITED STATES ORRICA A INFORMATION The United States Attorney charges that: COUNT 1 In or around August 2006, in Palm Beach CoE. , in the Southern District of Florida,. ajd _ elsewhere, the defendant, JEFFREY EPSTEIN, T did knowingly and intentionally violate the privacy protection acco y 18 U.S.C. § 3509 to a child victim, that is, Jane Doe #1; in violation of Title 18, United Stat Code, Sections 403 and 2. COUNT 7 In or around 2005, in the special territorial jurisdiction of the United States, that is, in an aircraft owned by a United States citizen while in flight over the high seas, and elsewhere, the defendant, JEFFREY EPSTEIN, 08-80736-CV-MARRA RFP WPB 000066 EFTA00184678

Case 9:08-cv-80736-KAM Document 361-52 Entered on FLSD Docket 02/10/2016 Page 3 of 10 did knowingly commit a simple assault on a person who was over the age of 16 years, that is, in violation of Title 18, United States Code, Section 113(a)(5). D V11,IA FARA ASSISTANT UNITED STATES ATTORNEY A T 2 08-80736-CV-MARRA RFP WPB 000067 EFTA00184679

Case 9:08-cv-80736-KAM Document 361-52 Entered on FLSD Docket 02/10/2016 Page 4 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA D Case No. UNITED STATES OF AMERICA vs. JEFFREY EPSTE Defen • PLEA AGREEMENT The United States Attorney for e Southern District of Florida ("the United States"), and Jeffrey Epstein (hereinafter r to as the "defendant") enter into the following agreement: 1. The defendant agrees to plead guilty to the Information which charges the the as follows: Count I charges that the d fendant 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, ample in an airplane over the high seas, did knowingly commit assault on a person who was over the age of 16 years, that is, in violation of Title 18, United States Code, Section 1 13(a)(5). 2. The defendant is aware that the sentence will be imposed by the Court after considering the Federal Sentencing Guidelines and Policy Statements (hereinafter Page 1 of 7 08-80736-CV-MARRA RFP WPB 000068 EFTA00184680

Case 9:08-cv-80736-KAM Document 361-52 Entered on FLSD Docket 02/10/2016 Page 5 of 10 "Sentencing Guidelines"). The defendant acknowledges and understands that the Court will compute an advisory sentence under the Sentencing Guidelines and that the applicable guide ill 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 fr m the advisory sentencing guideline range that it has computed, and may raise or lower th isory 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 ul te 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 sentenc 1thin 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 acknowled es that, as to Count 1 of the p Information, the Court may impose a statutory maximum term of r prisonment 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 Page 2 of 7 08-80736-CV-MARRA REP WPB 000069 EFTA00184681

Case 9:08-cv-80736-KAM Document 361-52 Entered on FLSD Docket 02/10/2016 Page 6 of 10 sentencing. 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 on$100,000. 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 impo ed on the defendant, which must be paid at or before the time of k 5. 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 res in ion owed to each victim will be determined at or before sentencing. 6. The parties agree to jointly recommend that the defendant receive a sentence of eighteen (18) months' imprisonment, to be r, wed 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 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 Page 3 of 7 08-80736-CV-MARRA REP WPB 000070 EFTA00184682

Case 9:08-cv-80736-KAM Document 361-52 Entered on FLSD Docket 02/10/2016 Page 7 of 10 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 appom 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 regi a sex offender, that is, solicitation of minors to engage in prdstitution, 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 (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 p 'on or community control in lieu of ph imprisonment; and (b) following the term of imprisonment, the defendant shall serve ten (10) months of community control/home confinement with electronic T 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. 10. The defendant agrees that he will provide to the U.S. Attorney's Office copies Page 4 of 7 08-80736-CV-MARRA RFP WPB 000071 EFTA00184683

Case 9:08-cv-80736-KAM Document 361-52 Entered on FLSD Docket 02/10/2016 Page 8 of 10 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 hot, as well as concerning the defendant and the de endant's background, and to respond to any questions from the Court and the Probation O d 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 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 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 Page 5 of 7 08-80736-CV-MARRA RIP WPB 000072 EFTA00184684

Case 9:08-cv-80736-KAM Document 361-52 Entered on PLSD. Docket 02/10/2016 Page 9 of 10 by both the defendant and the government. 13. WAIVER OF RIGHT TO APPEAL AND COLLATERALLY ATTACK THE DUNCE. 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 w ' all rights conferred by Section 3742 to appeal any sentence imposed, including titution 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 furthAluntarily 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. 1. 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, thLdefendant acknowledges that he has discussed the appeal waiver set forth in this agreement with his attorney. 14. 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 Page 6 of 7 08-80736-CV-MARRA RFP WPB 000073 EFTA00184685

Case 9:08-cv-80736-KAM Document 361-52 Entered on FLSD Docket 02/10/2016 Page 10 of 10 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 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 rosecution, except to the extent that such a defense exists as of the 1 t date he signs this Pie eement. Finally, the defendant understands 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 a ents, promises, representations, or understandings. Date: By: R. ALL ER UNIT TATES ATTORNEY Date: By: JEFFREY EPSTEIN, DEFENDANT T Date: By: JAY LEFKOWITZ, ESQ. ATTORNEY FOR DEFENDANT Page 7 of 7 08-80736-CV-MARRA RFP WPB 000074 EFTA00184686

Case 9:08-cv-80736-KAM Document 361-53 Entered on FLSD Docket 02/10/2016 Page 1 of 4 EXHIBIT 53 EFTA00184687

&mg 9:ftpy6gp,tratildusDocument 361-53 Entered on FLSD Docket 02/10/2016 ell b,Cat isk Re: JE negotiations 1 message Ann Ann Sun, Sep 16,2007 at 11:41 AM To: Jay Lefkowitz <[email protected]> Hi Jay -- I looked up some 11th Circuit cases on simple assault and found some good language. I also learned that, every moment that one is aboard an enclosed civil airplane, they are in the "special aircraft jurisdiction of the United States," so the assault charge is really a violation of 49 USC 46506, which doesn't change the penalties. I have drafted up a factual proffer that I would use at the change of plea based upon our brief conversation and the agents' interaction with at her home. The agents and I would need to speak with Ms. briefly to confirm that these facts are true. Feel free to make suggestions. On an "avoid the press" note, I believe that Mr. Epstein's airplane was in Miami on the day of the a' telephone call. If he was in Miami-Dade County at the time, then I can file the charge In the District Court in Miami, which will hopefully cut the press coverage significantly. Do you want to check that out? I will talk to you later. Thanks. fin Epstein Plea Proffer.doc 21K EFTA00184688

Case 9:08-cv-80736-KAM Document 361-53 Entered on FLSD Docket 02/10/2016 Page 3 of 4 UNITED STATES vs. JEFFREY EPSTEIN PLEA PROFFER On August 2007, FBI Special Agents E. MEI and Jason a traveled to the home of to serve her with a subpoena in connection with an investigation pending in the Southern District of Florida. works as the personal assistant of the defendant. began speaking with the agents and then excused herself to go upstairs to check on her sleeping child. While upstairs, telephoned the defendant, Jeffrey Epstein, and informed him that the FBI agents were at her home. Mr. Epstein was then aboard a civilian aircraft in the Southern District of Florida, and was about to return to Teterboro, New Jersey. Mr. Epstein instructed not to speak with the agents and reprimanded her for allowing them into her home. Mr. Epstein then re-directed his airplane, traveling to the C.S. Virgin Islands instead of the New York City area, thereby keeping the Special Agents from serving target letters on that flight, while in the special_ aircraft jurisdiction_ of the United_States, the defendant telephoned 1 and applied pressure to keep her from complying with the that the agents had served upon her. In particular, Mr. Epstein warned against turning over documents and electronic evidence responsive to the and pressured her to delay her appearance before the federal in the Southern District of Florida. Also during that flight, while in the special aircraft jurisdiction of the United States, the defendant became angry regarding the federal investigation and became verbally abusive and threatening towards his female companion, 08-80736-CV-MARRA RFP WPB 000125 EFTA00184689

Case 9:08-cv-80736-KAM Document 361-53 Entered on FLSD Docket 02/10/2016 Page 4 of 4 although he did not intend to strike her. Based upon Mr. Epstein's words, Ms. reasonably was in fear that Mr. Epstein was about to touch her offensively. 08-80736-CV-MARRA RFP WPB 000126 EFTA00184690

Case 9:08-cv-80736-KAM Document 361-54 Entered on FLSD Docket 02/10/2016 Page 1 of 2 EXHIBIT 54 EFTA00184691

Case 9:08-cv-80736-KAM Document 361-54 Entered on FLSD Docket 02/10/2016 Page 2 of 2 "Ann MI Materna 09/16/200711:41 AM To "Jay Lotkowitz" <[email protected]> cc bcc Subject Re: JE negotiations _,,,,Xigredasiwtha,Wypiligpit t hasogifogo ; RiV.Wiallar '! Lea egt:W*, -vat Iii Jay -- I looked up some 11th Circuit cases on simple assault and found some good language. I also learned that, every moment that one is aboard an enclosed civil airplane, they are in the "special aircraft _jurisdiction of the United States," so the assault charge is really a violation of 49 USC 46506, which doesn't change the penalties. I have drafted up a factual proffer that I would use at the change of plea based upon our brief conversation and the agents' interaction with Ms. at her home. The agents and I would need to speak with Ms. I f briefly to confirm that these facts are true. Feel free to make suggestions. On an "avoid the press" note, I believe that Mr. Epstein's airplane was in Miami on the day of the 'telephone call. If he was in Miami-Dade County at the time, then I can file the charge in the District Court in Miami, which will hopefully cut the press coverage significantly. Do you want to check that out? I will talk to you later. Thanks. «< Attachment 'Epstein Plea Proffer.doe has been archived by Haft tommenStore/IT/Kirklamil:filis' on '11126120Q7 01:08:17_, US_Atty_Cor_0029 EFTA00184692

Case 9:08-cv-80736-KAM Document 361-55 Entered on FLSD Docket 02/10/2016 Page 1 of 2 EXHIBIT 55 EFTA00184693