JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE REMEDIES CASE NO: 0840736-Civ-Marra/Johnson EXHIBIT A Filed Under Seal EFTA00235326

C) 09/12/2007 03:44 PM To < cc "alikUSAFLS1r bcc Subject Jeffrey Epstein Jay —lavas nice seeing you again. -.Nand I tallced with Alex and We are all satisfied in principle with the agreement, but the Office is uncomfortable with the recommended 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. I- Assistant U.S. Attorney West Palm Beach, FL 33401 US_Atty_Cor_001 EFTA00235327

usdo Egov, 09/13/2007 07:27 PM To "Jay Lelkowile cc bcc Subject RE: Hi Jay -- Yes, I am. I have been spending some quality time with Title 18 looking for misdemeanors. Do you want to take a look at 18 USC 403, 18 USC 1512(d), and 47 EEC 223(a)(1)(B) and we can talk about them tomorrow? I know that someone mentioned there being activity on an airplane, I just want to make sure that there is factual basis for the plea that the agents can confirm. I'm not sure exactly where I will be tomorrow morning, so is it alright if I call you? Have a good evening. 33401 Original Message From: Jay Lefkowitz fmailto: Sentil rl ll13, . 2007 7:21 PM To: (USAFLS) Subject: The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the 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 [email protected], and US_Atty_Cor_002 EFTA00235328

0 destroy this communication and all copies thereof, including all attachments. * • fa * • US_Atty_Cor_003 EFTA00235329

09119/2007 12:14 PM To cc bee Subject RE: Meeting "Jay Lelkovatt Judge Johnson has duty next week. Jay — !hate to have to be firm about this, but we need to wrap this up by Monday. I will not miss my indictment date when this has dragged on for several weeks already and then, if things fall apart, be left in a less advantageous position than before the negotiations. I have had an 82-page pros memo and 53-page indictment sitting on the shelf since May to engage in these negotiations. There has to be an ending date, and that date is Monday. Villqfcrifa MS Attorney Sent: 09/19/2007 11:51 AM AST To: Jay Letkowitz Subject: Meeting SAFLS\)" is available Monday morning. Our most flexible West Palm Beach magistrate is on duty on Monday, so, assuming we have signed documents by 1:30 or so, we should be able to get Mr. Epstein arraigned on Monday. I doubt that we will be able to get everything finished up here, get down to Miami, and try to find a Miami mag by close of business on Monday. US_Atty_Cor_004 EFTA00235330

Q9/14t2007 09:55 AM To "Jay Le&ovate cc bce SubOct Pile documents Hi Jay — I'm not sure which of those e-mail addresses is correct Here are drafts of the plea agreement and information. They have not yet been blessed by Miami, but they have approved of prior similar drafts, so these should be close to what is needed. My You also can get home e-mail is me over the weekend on my cell phone at <<infomuttion charging 1512 and 113.pdf>> <<OLY Plea Agreement v4 1512 and 113 violations.pdf>> Regards, Assistant U.S. Attorney West Palm Beach, FL 33401 Information charging 1512 and 113.pdt OLY Plea Agreement v4 1512 and 113 vlolatlons.pdf US_Atty_Cor_005 EFTA00235331

D UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 18 U.S.C. § 1512(dX2) 18 U.S.C. § 113(aX5) UNITED STATES OF AMERICA vs. JEFFREY EPSTEIN, Defendant. R The United States Attorney charges that: COUNT I In or around October 2005, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendant, F JEFFREY EPSTEIN, did intentionally harass another person, that is, Jane Doe #I, in an attempt to delay, prevent, and dissuade Jane Doe #1 from reporting to a law enforcement officrer of the United States the ]g l commission of a federal offense; in violation of Title 18, United Slat ode, Sections 1512(O2) and 2. COUNT 2 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, US_Atty_Cor_006 EFTA00235332

the defendant, JEFFREY EPSTEIN, did kno ly commit a simple assault on a person who was over the age of 16 years, that is, M.; in violat • Title IS, United States Code, Section 113(aX5). R. ALEXANDER AC UNITED STATES ATTORNEY VILLAFARA ASSISTANT UNITED STATES ATT 2 F T US_Atty_Cor_007 EFTA00235333

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA UNITDATES OF AMERICA vs. JEFFREY EPSTEIN, Defendant. Case 1'0'0. R, PLEA AGREEMENT The United States Attorney for the Southern District of Florida ("the United States"), and Jeffrey Epstein (hereinafter referred to as thitfendant") 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, Jane Doe #1, in an attempt to delay, prevent, and dissuade J ill 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 T over the age of 16 years, that is, M.; in violation of Title 18, United States Code, Secti I I 3(aX5). 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 US_Atty_Cor_008 EFTA00235334

"Sentencing Guidelines"). The defendant acknowledges and understands that the Court will compute an advisory sentence under the Sentencing Guidelines and that the applicable guideli ill be determined by the Court relying in part on the results of a Pre-Sentence Investi 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 soft 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 seven or less re 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 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 Count 1 of the Information, the Court may impose a statutory maximwn term of imprisonment of up to one (I) year, to be followed by a term of supervised release of up to a maximum off (I) 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 US_Atty_Cor_009 EFTA00235335

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 $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 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 restitution owed to each victim will be determined at or before sentencing. A 6. 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 agreesthat,ifanyoftheviictimsidentiAbdinthefederal 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 noT e defendant will not contest that the identified victims are persons who, while mi , victims of violations of Title 18, United States Code, Sections(s) 2422 and/or 2423. The hod 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 Page 3 of 7 US_Atty_Cor_001 EFTA00235336

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 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 tha d the Palm Beach County State Attorney's Office will make a joint, binding recommended 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 wit olding adjudication or sentencing, and without probation or oammu • c t of 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 s tation filed by the State Attorney's Office and to waive the right to appeal his conviction anJ H entence 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 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 Page 4 of 7 US_Atty_Cor_0011 EFTA00235337

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 agreed-upon sentencing recommendations contained in this Agreement, this Office 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 a 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 govern r rnakes 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 abov the defendant may not withdraw his plea based upon the Court's decision no 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 ACK 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 Page 5 of 7 US_Atty_Cor_0012 EFTA00235338

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 impos ess the sentence exceeds the maximum permitted by statute or is the result of eiwk) an upw parture 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 on 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 374 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. 14. If the defendant fails in any way to fulfill each on and • obligations under this 1.,34., Plea Agreement, the United States, only the United States, 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 mayprosecute'i efendant 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 Page 6 of 7 US_Atty_Cor_001 3 EFTA00235339