(USAFLS) From: Senior, Robert (USAFLS) Sent: 8 3:25 PM To: (USAFLS); Sloman, Jeff (USAFLS) Cc: t inson, aren LS) Subject: RE: Epstein Marie, are you back ? We need to spend some time together on the indictment. I was planning on Monday because I thought you were back that day but if you're already back let me know. By the way, Jeff and Alex have been very clear that we are not negotiating with this guy any more in any way. Thx. Bob Original Message From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, May 27, 2008 2:54 PM To: Sloman, Jeff (USAFLS); Senior, Robert (USAFLS) Cc: Atkinson, Karen (USAFLS) Subject: Epstein Hi jeff. Karen sent me an email about epstein wanting to do less time. I hope that his request will be denied. The original deal was supposed to be 2 years so he has already gotten a big break. Plus we have identified more victims since we agreed to the 18 months. Please keep me posted. Thanks. 1014 EXHIBIT B-34 EFTA00225681

g9N-15in -Lri. ID 'OS WIN 13:20 FAX I 21a 0a0 $500 EMAGIVE OFFICE IIVJIUD OT KIRK, AND&10 L I S Quiz 013/013 et 00U Honorable Mark Filip May 19. 2008 Page 8 prosecution is fair and appropriate has been placed, once again, in U.S. Attorney Acosta's hands. in light of the foregoing, we respectfully ask that you review this matter and discontinue all federal involvement so that the State cam appropriately bring this matter to closure. We would greatly appreciate the opportunity to meet With you to discuss these important issues. Such it meeting would provide the Department with an opportunity to review the paramotun issues of federalism and the appearance of selectivity that are generated by the unprecedented attempts to broaden the ambit of federal statutes to places that they have never before reached. We sincerely appreciate your attention to this matter. ttespeetililly submitted, Kenneth W. Starr Kirkland & Ellis LLP Joc D. Whitley Alston & Bird LIP EFTA00225682

tAVULfUO WAN £O:VL CAA OU0 0001 OGSV otp. in • n8 WIN 13:211 PAX 1 213 080 8500 well namvullro urrimx, 1@012/01a ........ I KLANUSLE1.1.1 S I.LJ WOOS Honorable Mark Filip May 19, 2008 Page 7 Government's confidential "list of victims." Most of these lawsuits seek S50 million in money damages" • Assistant U.S. Attorney David Weinstein spoke about the case in great detail to Landon Thomas, a reporter with the New York nines, and revealed confidential information about she Government's allegations against Mr. Epstein. The Assistant U.S. Attorney also revealed the substance of confidential plea negotiations. • When counsel for Mr. Epstein complained about the media leaks, First Assistant Stomata responded by assening that "Mr. l'homas was given, pursuant to his request, non-case specific information concerning specific federal statutes." Based on Mr. Thomas' contemporaneous notes. that assertion appears to be false. For example, Mr. Weinstein told Mr. Thomas that federal authorities believed that Mr. Epstein had hired girls over the telephone and traveled in interstate corn incite for the purpose of engaging in underage sex. lie recounted to Mr. Themes the USAO's theory of prosecution against Mr. F Lein, replete with an analysis of the key statutes being considered. Furtherm after Mr. Epstein's defrost team complained about the leak to the USAO, . Weinstein, in Mr. Thomas' own description, then admonished him for talking to the defense, and getting him in trouble, Mr. Weinstein further told him not to believe the "spin" of Mr, Epsteites "high-priced attorneys,' and then, according to Mr. Thomas. Mr. Weinstein forcefully "reminded" Mr. Thomas - that all prior conversations were merely hypothetical. We are constrained to conclude that the actions of federal officials in this case strike at the heart of one of the vitally important, enduring values in this country: the honest enforcement of federal law, free of political considerations and free of the taint of personal financial motivations on the part of federal prosecutors that, at a minimum, raise the appearance of serious impropriety. We were told by U.S. Attorney Acosta that as part of the retie he requested, the Department had the authority, and his consent, to make any determination it tried appropriate te regarding this matter, including a decision to decline federal prosecution. Yet, CEOS's only conclusion, based on its limited review of the investigation, is that U.S. Attorney Acosta would not abuse his discretion by proceeding against Mr. Epstein. Thus, the decision of Ithother As recently as two months ago. Mr. Women Was still lined publicly os t pan of his former law firm. While wv assume this was an oversight, Mr. Stoma identification as pan or the firm raises the appearance of impropriety. EFTA00225683

06/02/08 MON 15:02 FAX ol3/28/201:18 00:10 FAX 202 • ps, LION IA:Z5 FAA 1 =13 ONO 8500 EXECUTIVE OFFICE b0.1/00AC KIRKIANDMILLTS 1d1010 gtolvols 4g u87 Honorable Mark Hip May 19, 2008 Page 6 • Federal prosecutors made the unprecedented demand that Mr. Epstein pay u minimum of 5150,000 per person to an unnamed list of women they referred to as minors and whom they insisted required representation by a guardian ad them. Mr. Epstein's counsel later established that all but one of these individuals were actuully adults, not minors. Even then, though demanding payment to the women, the USAO eventually asserted that it could not vouch for the veracity of any of the . claims that these women might make. • Federal prosecutors made the highly unusual demand that Mr. Epstein pay the fees of a civil gamey chosen by the prosecutors to represent these alleged "victims" should the choose to bring any civil litigation against him. They also proposed t sending a ties to the alleged "victims," stating, in an underlined sentence, that should they choose their own attorney, Mr. Epstein would not be required to pay their tees. The prosecutors fitrther demanded that Mr. Epstein Waive his right to challenge any of the allegations made by these "victhns." • The Assistant U.S. Attorney involved in this matter recommended for the civil attorney, a highly lucrative position, an individual that we later discovered was closely and personally connected to the Assistant U.S. Attorney's Own boyfriend. • Federal prosecutors represented to Mr. Epstein's counsel that they had identified (and later rechecked and re-identitied) several alleged -victims" of federal crimes that qualified for payment under 18 U.S.C. § 2255, a civil remedy designed to provide financial benefits to victims. Daly through state discovery previsions did we later learn that many of the women on the rechecked "victim list" could not possibly qualify under § 2255. The reason is that they, themselves, testified that they did not suffer any type of harm whatsoever, a prerequisite for civil recovery under § 2255. Moreover, these women stated that they did not, no or in the past, ti consider themselves to-be victims. • During the last few months, Mr. Mennen, First Assistant Sloroan's former law partner, has tiled several civil lawsuits against Mr. Epstein on behalf of the alleged "victims." ft is our understanding that each of Mr. Herman's clients arc on the EFTA00225684

UO/V4IV9 sun CAA OVO 00V O1%V 05/28/2008 00:09 FAX 2026161230 DA VON 13:24 KAX 1 :13 660 6500 LSGVUAAVD UrrAteta DOJ/ODAC K I RKI.AND&ELI-1 S 1.1-P Wt", O 490Oi/013 Ciijurni • Honorable Mark Filip May 19. 2008 Page 5. In fact, recent testimony of several alleged "victims" contradicts claims made by federal prosecutors during the negotiations of a deterred prosecution agreement. The consistent representations of key Government wimesses (such as Tatum Miller. Brittany Beak, Saige Gonzalez. and Jennifer Laduke) confirm the following critical points: First, there was no communication, telephonic or otherwise, that meets the requirements of § 2422(b). Par instance. Ms. Gonzalez confirmed that Mr. Epstein never entailed, text-messaged, or used any facility of interstate commerce whatsoever. before or after her one (and. only) visit to his home. Gonzalez Tr. (deposition) at 30. Second, the women who testified admitted that they lied to Mr. Epstein about their age in order to gain admittance into his home. Indeed. the women who brought their underage friends to Mr. Epstein testified that they would counsel their friends to lie about their ages as well. Ms. Miller stated the following: "I would tell my girlfriends just like Carolyn approached me. Make sure you tell hint you're. 18. Well, these girls that I brought, i know that they were 18 or 19 or 20. And the girls that !didn't !mow and I don't know if they were lying or not, 1 would say make sure that you tell him you're 18." Miller Tr. at 22. Third, there was no routine or habit of improper cotrununication expressing an intent to transfomi a massage into an illegal sexual act. In bet, there was often no sexual activity at all daring the massage. Ms. Miller testified that "(s)ometimes [Mr. Epstein) just wanted his feet massaged. Sometimes he just wanted a back massage." Miller Tr. at 19. Jennifer Laduke also stated that Mr. Epstein "never touched (her) physically" and that all she did was -massage( ) his back. his chest and his thighs and that was it." Laduke Tr. at 12-13. Finally, there was no force, coercion, fraud: violence, drugs, or even alcohol present in connection with Mr. Epstei 'S encounters with these women. Ms. Beak stated that "[Mr. Epstein) never tried to force me to u anything." Bale Tr. A at 12. These accounts are far from the usual testimony in sex slaver Internet stings and sex tourism cases previously brought. The women in actuality were not younger than 16, which is the age of consent hi most of the 50 states, and the sex activity was in'egular and in large parr. consisted of solo self-pleasuring. The recent crop of civil suits brought against Mr. Epstein confirm that the plaintiffs did not discuss any sexually-related activities with anyone prior to arriving at Mr. Epstein's residence. This reinforces our contention that no telephonic or Internet persuasion, inducement, enticement or coercion of a minor, or of any other individual, occun'ed. In addition, Mr. Jeffrey Merman, the former law partner of one of the federal prosecutors involved in this matter and the attorney fyq most of the civil complainants (as described in derail below), was quoted in the Palm Beach Pe). as saying that "k doesn't matter" that his clients lied about their ages and told Mr. 1 Epstein the''{{ they were 18 or 19. Not only is a federal prosecution or this matter unwarranted, but the irregularity of conduct by prosecutors and the unorthodox terms of the deferred prosecution agreement. arc beyond any reasonable interpretation of the scope of a.prosecutor's responsibilities. The list of improprieties includes, but.is not limited to, the following facts: EFTA00225685

06/02/08 MON 15:01 FAX EXECUTIVE OFFICE 05/28/2008 00:09 FAX 202 1 39 DOVODAC in.na. NOS 1312A VAN : 213 680 A500 KIRKLANDWILIS 1.11' 10 008 ei 009/013 CO 005 Honorable Mark Fi I ip May 19, 2003 l'age 4 These statutes are intended to tuna crimes of a truly national and international scope. Specifically, § 1591 was enacted to combat human trafficking, § 2422 is aimed at sexual predation of minors through the Internet. and § 2473 deals with sex tourism. The nature of these crimes results in multi-jurisdictional problems that state and local authorities cannot effectively confront on their own. However, Mr. Epstein's conduct was purely local in nature and, thus. does not implicate federal involvement. After researching every reported ease brought under I3 U.S.C. §§ 1591, 2422(b), and 2423(b), we found that not a single cast involves facts or a scenario similar to the situation at hand. Our review of each precedent reflects that there have been no reported prosecutions un r § 1591 of a 'john' whose conduct with u minor lacked force. coercion_ or fraud and who as not profiling from commercial sexual trafficking. There have likewise been no eases undo • 2422(b)—a crime of communication—where th c was no sus inducing use: of the Internet. and where the content of phone communications did not contain ri or enticing of a minor to have illegal sexual activity as expressly required by the language of the statute. l'urtherniore, the Government's contention that "routine and habit" can fill the factual and legal void created by the lack of evidence that such a communication ever occurred sets this case apart from every reported case brought under § 2422(6). Lastly, there arc no reported eases of violations of § 2423(b) of a person whose dominant purpose in traveling was merely to go to his own home.3 Although these matters were within the scope of the CEOS review, rather than cunsideting whether federal prosecution is appropriate, CEOS only determined that U.S. Attorney Acosta "would not be abusing his prosecutorial discretion should he authorize. federal prosecution" iu this case. The "abuse of discretion" standard constitutes an extremely low bar of evaluation and while it may be appropriate when the consideration of issues are exclusively factual in nature, this standard fails to address concerns particular to this situation, namely the -novel application" of federal statutes. The "abuse of discretion" standard in such pure legal matters of statutory application risks causing a lack of uniformity. The same federal statutes that would be stretched beyond their bounds in Miami have been limited to their heartland in each of the other federal districts. Also, because this case implicates broader issues of the administration of equal justice, federal prosecution in this matter risks the appearance of selectivity in its stretching of federal law to fit these facts. federal prosecution of a man who engaged in consensual conduct in. his borne that amounted (0, at most, the *elicitation of prostitution. is unprecedented. Since prostitution is fundamentally a suite concern. (sek United Slights it Evan; 476 F.3d I 176, r..l (nth Cir. 2001) (federal law "does not criminalize all acts of prostitution (a vice traditionally governed by state regulations)). and thoro is no evidence that Palm Beach County authorities and Florida prOSocutors cannot cifectively prosecute and punish the conduct, there is no reason why this matter should be extracted from the hands ornate prosecutors in Florida. EFTA00225686

EXECUTIVE OFFICE 00J/OD5C lalthEAND&ELL.15 1.1.P ID 007 fsbo08/0.1.3 0114 06/02/08 VON 15:00 FAX 05/28/2008 09:05 PAX 202 ,'05 JO;08 80‘ 13:23 FAN I 213 080 8500 . , Honorable Mark lip May 19, 2008 Page 3 private practice in South Florida wit sonal relationships to some of the prosecutors involved. Federal prosecutors then leaked hi sensitive information about the case to a New York Times reporter.' The immediate re f this confluence of extraordinary circumstances is an onslaught of civil lawsuits, all save one brought by the First Assistant's former boutique law Jim in Miami. The facts in this case all revolve around the classic state crime of solicitation of prostitution? The State Attorney's Office in Palm Beach County had conducted a diligent investigation, convened a Grand Jury that returned an indictment, and made a final determination about how to proceed. That is where, in our federal republic, this matter should rest. Mr. Epstein faces a felony conviction in state court by virtue of his conduct, and the only reason the Suite has not resolved this matter is that the federal prosecutors in Miami have continued to insist that wt, Mr. Epstein's counsel, approach and demand from the State Attorney's Office a harsher charge and a more severe punishment than that Office believes are appropriate under the circumstances. Yet despite the USAO's refusal to allow the State to resolve this matter on the terms the State has determined are appropriate, the USAO has not made any attempt to coordinate its efforts with the State. In fact, the USAO mandated that any federal agreement would he conditioned on Mr. Epstein persuading the State to seek a criminal punishment unlike that imposed on other defendants within rho jurisdiction of the State Attorney for similar conduct. From the inception of the USAO's involvement in this case, which at the end of the day is a case about solicitation of prostitution within the confines of paten Beech County, Florida, we have asked ourselves why the Department of Justice is involved. Regrettably, we are unable to suggest' any appropriate basis for the Department's involvement. Mr. Epstein has no criminal histo whatsoever. Also, Mr. Epstein has never been the subject of general media interest until a few ears ago. after it was widely perceived by the public that he was a close friend of former President Bill Clinton. The conduct at issue is simply not within the purview of federal jurisdiction and lies outside the heartland of the three federal statutes that have been identified by prosecutors-1S U.S.C. 1591.2422(b), and 2423(b). (Inv of the other members of Mr. Epstein's defense team, Jay Letkowitz, has personally reviewed tho reporter's contemporaneous news. Although some of the women alleged to he involved were 16 arid 17 years of age, several of these women openly admitted to lying to Mr. Epstein about their age in their recent sworn statement:. EFTA00225687

VV/ 4/VO nun tO;VV 'MA ova coy ••• 1/40,0•0 . ,et • •40 4 ran auceinAcJv , b3. 19•SIN NOS t3:22 PAX I I.113 can 4500 AADVLIAATZ UltrAtoG IMJ, UVAG HXLANII&EIJ.IS 1.1? WA LW In007/013 4L1"3 Honorable Murk Pilip May 19. ZOOS Page 2 By way of background. we were informed by Mr. Acosta that, at his request, CEOS would be conducting a review to determine whether federal prosecution was both appropriate and, in his words. --fair." That is not what occurred. instead, CEOS has now acknowledged that we had raised "many compelling arguments" against the USAO's suggested "novel application" of federal law in this matter. Even so. CEOS concluded. in minimalist fashion. that "we do not see anything that says to us categorically that a federal case should not be brought" and that the C.S. Anoint) "would no he abusing his prosecutorial discretion should he authorize federal prosecution of Mr. Epstein!' thus delegating back to Mr. Acosta the decision of whether federal prosecution was warranted (emphasis added). Rather than assessing whether prosecution would he appropriate, CEOS. using a lowbaseline for its evaluation, determined only that "it would not be impossible to prove . . ." certain allegations made against Mr. Epstein. The CEOS review failed to address the significant problems involving the appearance of impermissible selectivity that would necessarily result from a federal prosecution of Mr. Epstein. We respect CEOS's conclusion that its authority to review "misconduct" issues wes precluded by Criminal Division practice. We further respect CEOS's view that it understood its mission as significantly limited. Specifically, the contemplated objective was to determine I tether the I.:SAO would he.abusing its discretion by bringing a federal prosecution rather than eking its own de novo recommendations on the appropriate reach of federal law. However. we respectfully submit that a full review of all the facts is urgently needed at senior levels of the Justice Department. in an effort to inform you of the nature of the fcder investigation against Mr. Epstein, we summarize the facts and circumstances of this matter bolo The two base-level concerns we hold are Ihat (1) federal prosecution of this matter is not warranted based on the purely-local conduct and the unprecedented application of federal statutes to facts such as these and (2) the actions of federal authorities are both highly questionable and give rise to an appearance of substantial impropriety. The issues that we have raised, but which have not yet been addressed or resolved by the Department, are more than isolated allegations of professional mistakes or misconduct. These issues, instead, affect the appearance and administration of criminal justice with profound consequences beyond the resolution in the matter at hand. 1 In a. precedenr-shattering investigation of Jeffry Epstein that raises important policy questions—and serious issues as to the fair and honor le enforcement of federal law—the USAO in Miami is considering extending federal law beyond the bounds of precedent and reason. Federal prosecutors stretched the underlying facts in ways that raise fundamental questions of basic professionalism. Perhaps most troubling, the USAO in Miami, as a condition of deferring prosecution, required a commingling of substantive federal criminal law with a proposed civil remedy engineered in a way that appears intended to profit particular lawyers in EFTA00225688

na,4 Piz VUo Ile, I *ON • • win 14:0V rAA 000 04U 044U VW: u / resa ZUZ0 1 U I Za NON 1:1:22 PAS I 218 tc$o 85o0 tsr.'AuS1rc urr . sun DOJ/ODAu xl iaii.ANDV.I.I.1 5 In' III IMO klionarn13 4000 Kenneth W. Starr Kirkland & Ellis LLP 777 South Fisncrou Street LOR A11,50liat LA _90017..5800 Phone: 21.3-ette 8440 Fax: :au- 680-8500 kstarrekirkiand.com VIA FACST/tell...? (2021 51441467 I lonorable Mark Filip Office of the Deputy Attorney General United States Department of Justice 950 Pennsylvania Avenue, N,W. Washington, D.C. 20530 May 19. 2008 Joe D. Whitley Alston & Bird LIP The Atlantic Building 95o 17 Street, NW Washington, DC aotiottacit Ph: 202.756-3189 Fax: 2W-654.48149 joc.whillty@aiXtmeum CONFIDENTML DearJudgeFiliee In his confirmation hearings Jest dill, Judge Mukascy admirably lifted up rim finest traditions of the Department of Justice in assuring the United States Senate, and the American people, of his solemn intent to ensure fairness and integrity in the administration of justice. Your own confirmation hearings echoed that bedrock determination to assure that the Department conduct itself with honor and integrity, especially in the enforcement of federal criminal law. We come to you in that spirit and respectfully ask for a review of the federal involvement in a quintessentially stale matter involving our client, Jeffrey Epstein. While we arc well aware of the rare instances in which a review of this sort is justified, we arc confident that the circumstances at issue such au examination. Based on our collective experiences, as well as those of other former senior Justice Department officials whose advice we have sought, we have never before seen a case more appropriate for oversight and review. Thus, while neither of us has previously made such a request. we do so now in the recognition that both the Department's reputation, as well as the due process rights of our client, are at issue. Recently, the Criminal Division concluded a very limited review of this matter tit the request of U.S. Attorney Alex Acosta. Critically, however, this review deliberately excluded many important aspects of this ease. Just this past Friday, on May 16, 2008, we received a tenet- from the head of CEOS informing us that CF-OS had conducted a review of this case. By its own admission, the CEOS review was "limited, both factually and legally." Part of the self-imposed limitation was CEOS's abstention from addressing our "allegations of professional misconduct by federal prosecutors".—even though such misconduct was, as we contend it is, inextricably intertwined with the credibility of the accusatio being made against Mr. Epstein by the United State:: Attorney's Office in Miami ("USAO"). oreover, CEOS did not assess the terms of the Deferred Prosecution Agreement now in effect or did CEOS review the federal prosecutors' inappropriate efforts to implement those tenns. We detail this point below. EFTA00225689

06/02/08 MON 1459 FAX nafieti/zutnr ou:os FAX 20 05 19 OR MON 13:21 FAX 1 '113 88e 8508 EXECUTIVE OFFICE DU/08AG KIRKLANORALLIS LLF td)004 46ouS/013 KIRKLAND & FILLS LLA Fax Transmittal 777 South Figueroa Street Los Angeles, California 00017 Phone, (213) 680-8400 Fax: (213) 680-8500 Please notify us Immediately If any pages aro not r000lved. 511? gw310 es. THE INFORMATION CONTAINED IN THIS COMMUNICATION IS CONFIDENTIAL. MAY 13E ATTORNEY-CLIENT PRIVILEGED. MAY CONSTITUTE INSIDE INFORMATION. AND IS INTENDED ONLY FOR THE USE OF THE ADDRESSEE UNAUTHORIZED USE. DISCLOSURE OR COPYING IS STRICTLY PROHIBITED AND MAY BE UNLAWFUL. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY AT: (213) 680-8400. To: Honorable Mark Filip From: Kenneth W. Stun- Company: Office of the Deputy Attorney General United States Department oflusticc Date: May 19, 2008 Pages vetoven Fax II: Direct It: (202) 514-(1467 (202) 514-2101 Fax g: Direct #: 9 (313)680.8500 (213) 680-8440 Message. EFTA00225690

• ona wh;27,200R 1? II! AX . UVJ I VOM: 0004/013 is vin/ uvs I fortnrahle Mark »bly 27. 200.1i Page 2 tu a charge thai the State .• nonie)• hus not. despiic a lera yxar vesiigalion. tijiemitut;41 ett eec approprime. Mr. I ipStein's enunrcl must also strecessfully espediteg pka of y lo this charuc • on :e date prior in dirly S. 20024. which ie lite date pre enly set hy tbc siste enurt Judge. i:tirther, the unnecessary deadline is ewn more Fobi:made because Mr, itgejn"s cffnn tu real:lede the state charge mul seneene with the terms of Mc A:tm:entent requitea an tmustral und unprecedented threatened application of federal IZW:. Thi;. it place,. Mr Pitstein in the I eilddy ueittate:ol position of havinp to thanand thai the State :amok:see to a mon; set etc punishmeni ;han •Itad alrendy delermined was approprime. We hatt attempted to resolve Mest: tu id ca I eur i>sues thrkettgl i die USA0 avd (EON, ruising our eorreernx ahnut the LISAC's inappropritue eunduel will: respeet lo (hi) maltet. not Omse avenue; have now been shut dumt. Mr. Slontan'n letter purpnns to prohihit ann lurdur contael hetween Mr. Papskin' S defense team mul :.S. Anomi:y Aerma. and insieart repures us ta eommunicate with the USA° only thouph Mr. ..Chennta s stihrirdinmen. 11 'hi it pain:: tis In :my this, this mis)tuided proseention fi om Ilie omse: gives the alme:trance thai it may havt helst poliiiesilly intiriwired Mr. Rpercin is :e highiy surxeS:dni. Sel r, made businessman and philanihropist who entered the public- ansrui oniy inne of hk ck..? personal as:mej:diam with former President Bill Clinton. nerv is litile dt. tt! Il; uur minds thai the IN-N() nevet would hatt conrempiated a proNecution in this case if Mr. Epstein teer:: just anm her lolla.- t AltnnieY Aeosin previnusly has slated thai hr is "sympatin:lie- lo om Federalism• related eoneents. but he has token the position that his audtority is lintiicd bt enfon:ement policirx set inritt in Washington. D.C. As expresse4 in our prior conumenicatinn oml. tve helieve i hat a crunrilele and independent apprnisul and n:solution of this case most appropriateb would be undertaken by your Office heginniny with the reseission of the arhirrury. unfair. and improeedenred deadline that Mr, ~Inman demands to have iinpn.sed in this At die verv leas(. etc would apprcciate a killing of the arbitnm, timeline impost:d till our ciiew hy the I :SA() in order to allow tisne: for your office to soplider eau: Amnesi Ittel klit: Ill itteriake te ryt len of th is cam;. Titank you for your time and attention. gaspeelfully sulunicted. Kenneth W. Starr K iddand I .LP Cr V -1\-7 , .106 I) WhitiCy Alslup Bird IL EFTA00225691

08/OP/08 YON r5n8a MOEN n5127/26(4 12 18 b).8 EXECUTIVE OFFICE UOJIODAG 12002 lä003/.0i 3 tomp,"liva. Kenneth W. Starr Kirkland tV hill i 1.1.1' ; , NI :vet ‘nrolue.....:.^. 901/4:17 .3kirr n •IIV. 4:13. tS;Kt‘ .7;1 -1O A:•. rItAne. S 1 e'.5(11-46".: 11.e•• :1 ; (NC $/:f.t: baarraktrkl.ta.kom VIA r kcst (2021 $14-040 I loatmtble Mark Filip )I lice OI the Dupnly Attorney General (haled titates Department tif Just ice 050 Pennsylvania Avenue, N.W. Washington. 0.4'. 70530 Dc.ir Judy.: Filip: May :7, 2008 Pk 0. I: it /c., & Bird LLP The t dated Kidder: ' 19. 1 .mteet. NW *.e .!:“;;;;;Pti. ; ":5‘4 rdh -i1P"-; pv who lin.w.d.e. y 1 .1 C'ONI•%p/::'\'7'/..11. •_ • 'Ibis letter briefly supplements ttttt prior submission to u dated May I.1. 2008. OW! conirmaneation. we urgently requested that your Office etualuel an independent 'reeitm the moused federal pro•annitIon of our client. Miley Epstein. The dual Iti:INONIS Jill' that you review this newer am lit the bedrock need fin integrity in the enfiteentrat flitfe: ud ell "'MI laws. and iiil the prOfteind questions raised hy the unprecedented eKlcumeem id' federal taw by the t Siats Attorney> Office in Mimed (the ESAU') tu a preminem public figure who •:h1µ Iles 11, 'boner President 'Mc need for review is now all the more eNigent. Ou Monday. MaY 19. 2008. Assistant JetTrey Shaun af the t ;SAO responded m an email from JD) I.elkowiitittfintuitu; k Attorney Alex Aeostu that we wnuld he seekinG your Oiliee's review. Mr. Slonew's letter. tvhkh improa:d a deadline of June 2. 2008 to comply with all the terms of the k.ue: cm von. Prosecution Agreement (die - Ago:emu:tn. pies new unilateral modifications, an pain of being deemed in breach Mat Agreement. ;Appeal, lo hove been deliberately designed to deprive UN Of an adequate opportunity Iu aret. your Office's review in ibis minter. (.!SAO'S desire to foreclose a complete revielk is widerstancLible. give!) den ibe Child Esplibitation and Obscenity Section retiON.3 has already delenemed that our subsiaite arg.1111148118 retarding WilY a ((:terot prosecution of mr. upsigin is not warranted were • nelling.- I Inwever. in contradiction w Mr. Sloman's assertion that 8ä0S luad provided an independent. dr Jew° (RÖS made clear that it did not do so. indeed. elifiR declined ut examine several of the more troubling aspgets of the investigation al' Mr. Upstem. the deliberate leak In the New York Times of mInterous highly vontidetekil aspects of the i 'west; gati un and nettothu kin:; Ec t," 3.41 I h e punk% US Weil US tie i«unt coll., of c kw,:'IrisK filed againu Mr. Epstein by Mr. Sloman's former law partner. The t ttttt eeessary anti arbitrarily imposed deadline set by the I /SIMI was done without any ruspee4 an' (lie turmal rum:tip ll tt and scheduling of state judicial neuters. It require< den Mr. Ep stein's counsel persuade the Slate Attorney of l'alen peach tu issue a criminal in !brit union EFTA00225692

uoiuzive AWN 14:3a /AA 305 530 6440 EXECUTIVE OFFICE (moot U.S. Department of Justice United States Attorney Southern District of Florida UNITED STATES ATTORNEY'S OFFICE SOUTHERN DISTRICT OF FLORIDA 99 NE 4Th STREET MIAMI, FLORIDA 33132-2111 Jeffrey H. Sloman First Assistant U.S. Attorney 305 961 9299 Cyndee Campos Staff Assistant fax FACSIMILE TRANSMISSION COVER SHEET DATE: June 2, 2008 TO: Villafana FAX NUMBER: (561) 820 8777 SUBJECT: Epstein NUMBER OF PAGES, INCLUDING THIS PAGE: 9 Message/Comments: This facsimile contains PRIVILEGED AND CONFIDENTIAL INFORMATION intended only for the use of the Addressee(s) named above. If you am not the intended recipient of this facsimile, or the employee or agent responsible for delivering it to the intended recipient, you are hereby notified that any dissemination or coping of this facsimile is strictly prohibited. If you have received this facsimile in error, please immediately notify us by telephone and return the original facsimile to us at the above address via (ho U.S. Postal Service. Thank you. EFTA00225693

51z7bb SrauS...644issJoN To n 44 tXHIBIT 11 EFTA00225694

JAY P. LEFKOWITZ, ESQ. May 19, 2008 PAGE 6 OF 6 Conclusion On February 25, 2008, I sent you an e-mail setting forth a timetable for moving forward in the event that CEOS disagreed with your position. That time is now. As you know, my February 25"' email stated that I would give you one week to comply with the terms and conditions of the Agreement, as modified by the USA's December I94 letter to Ms. Sanchez. In light of the upcoming Memorial Day weekend, I have decided to extend that timetable to the close of business on Monday, June 2, 2008, which is a full two weeks. Sincerely, R. Alexander Acosta United States Attorney By: Jeffrey H. Sloman First Assistant United States Attorney cc: R. Alexander Acosta United States Attorney A. Villafana Assistant U.S. Attorney Karen Atkinson Assistant U.S. Attorney EFTA00225695

JAY P. LEFKOWITZ, ESQ. May 19, 2008 PAGE 5 OF 6 C. "Mr. Epstein Does Not Believe He Is Guilty Of The Federal Charges Enumerated Under Section 2255." At our December 14, 2007 meeting at the U.S. Attorney's Office in Miami, counsel for Epstein announced, inter alia, that it was a "profound injustice" to require Epstein to register as a sex offender and reiterated that no federal crime, especially 18 U.S.C. Section 2422(6), had been committed since the statute is only violated if a telephone or means of interstate commerce is used to do the persuading or inducing. This particular attack on this statute had been previously raised and thoroughly considered and rejected by the SDFL and COS prior to the execution of the Agreement. You also argued that the facts were inapplicable to the contemplated state statutes and that Epstein should not have been allowed to have been induced into the Agreement because the facts were not what he understood them to be, It should be noted that the SDFL has never provided you with any evidence suppolg its investigation. This is not, and has never been, an Alford plea situation (see North Carolina Alford, 400 U.S. 25, 91 S.Ct: 160 (1970)). Ultimately, you requested an independent review. Subsequent to the above-mentioned meeting, the SDFL received three letters from you and/or Mr. Starr which expanded on some of the themes announced in the December 14th meeting. Essentially, you portrayed the SDFL as trying to coerce a plea to unknown allegations and incoherent theories. On December 17, 2007, you decreed that Epstein's conduct did not meet the requirements of solicitation of minors to engage in prostitution (Fl. Stat. Section 796.03) one of the enumerated crimes Epstein had previously agreed to plead guilty to; that Epstein's conduct does not require registration under Florida law; and the State Attorney's Office does not believe the conduct is registrable. On December 21, 2007, you rejected the USA's proposed resolution of the 2255 provision because you "strongly believe that the provable conduct of Mr. Epstein with respect to these individuals fails to satisfy the requisite elements of either 18 U.S.C. Section[s] 2422(6) ... or ... 2423(6)." In your December 26, 2007 correspondence you stated that "we have reiterated in previous submissions that Mr. Epstein does not believe he is guilty of the federal charges enumerated under section 2255" and requiring "Mr. Epstein to in essence admit guilt, though he believes he did not commit the requisite offense." As the SDFL has reiterated time and time again, it does not want, nor does it expect, Epstein to plead guilty to a charge he does not believe he committed. As a result, we obliged your request for an independent de novo review of the investigation and facilitated such a review at the highest levels of the Department of Justice. It is our understanding that that independent review is complete and a determination has been made that there arc no impediments to a federal prosec by the SDFL. EFTA00225696

JAY P. I.F.FKOWITZ, ESQ. May 19, 2008 PAGE 4 OF 6 B. Method of Compensation and Notification. During this same time period, you and others, including the former Solicitor General of the United States Kenneth Starr, took issue with the implementation of the methodology of compensation (hereinafter "the 2255 provision")3 and the SDFL's intention to notify the victims under 18 U.S.C. Section 3771 (you objected to victims being notified of time and place of Epstein's state court sentencing hearing). In response, the SUFI, offered, in my opinion, numerous and various reasonable modifications and accommodations which ultimately resulted in United States Attorney R. Alexander Acosta's' December 19, 2007 letter to Lilly Ann Sanchez. In that letter, the United States Attorney tried to eliminate all concerns which, quite frankly, the SDFL was not obligated to address, let alone consider. He proposed the 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 of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." Regarding the issue of notice to the victims, USA Acosta proposed to notify them of the federal resolution as required by law; however, "rwle will defer to the discretion of the State Attorney regarding whether he wishes to provide victims with notice of the state proceedings, although we will provide him with the information necessary to do so if he wishes." As you know, you rejected these proposals as well. See December 26, 2007 correspondence from Jay Lefkowitz to USA Acosta. 3 Prior to any issues arising concerning the implementation of the 2255 provision, the SDP', unilaterally agreed to assign its responsibility to select the attorney representative for the alleged victims to an independent third-party. This was done to avoid even the appearance of favoritism in the selection of the attorney representative. As a result, on October 29, 2007, the parties executed an Addendum wherein it was mutually agreed that former United States District Court Judge Edward B. would serve as the independent third-party. Judge Davis selected the venerable law firm of Podhurs and Josefsberg to represent the approximately 34 alleged identified victims. EFTA00225697

JAY P. LEFKOWITZ, ESQ. May 19, 2008 PAGE 3 OF 6 of the guilty plea and sentence no later than October 26, 2007; and (5) the start of the above- mentioned sentence no later than January 4, 2008. Furthermore, and significantly, Epstein agreed that he had the burden of ensuring compliance of the Agreement with the Palm Beach County State Attorney's Office and the Judge of the 15111 Judicial Circuit and "that the failure to do so will be a breach of the agreement" (emphasis added). Post-Execution of the Agreement Within weeks of the execution of the Agreement, you sought to delay the entry of Epstein's guilty plea and sentence. After the SDFL agreed to accommodate your request, counsel for Epstein began taking issue with the methodology of compensation, notification to the victims, and the issues that had been previously considered and rejected during negotiations, i.e., that the conduct does not require registration and the contemplated state and federal statutes have no applicability to the instant matter. A. Delay. The Agreement required that "Epstein shall use his best efforts to enter his guilty plea and be sentenced not later than October 26, 2007. The United States has no objection to Epstein self- reporting to begin serving his sentence not later than January 4, 2008." Agreement, pages 4-5, paragraph I I (emphasis added). After the Agreement was executed, the SDFL accommodated your request to extend the October 26th plea deadline to November 20111 based upon, what seemed to be, reasonable scheduling conflict issues.' By early November, you represented that the presiding state court judge would not "stagger the plea and sentencing as contemplated in the Agreement."Al though the Agreement clearly did not contemplate a staggered "plea and sentencing," the SDFL again agreed to accommodate Epstein's request to appear in state court for plea and sentencing on January 4, 2008.2 I "Accordingly, I have now confirmed with Mr. Epstein's Florida counsel that the state's attorney's office and the court will be available to have him enter his plea on November 20. So we will plan to proceed on one that date." October 18, 2007 email from Jay Lefkowitz to USA R. Alexander Acosta. On the same day, Mr. Lelkowitz confirmed with First Assistant Jeffrey H. Sloman that this postponement " will not affect when Epstein begins serving his sentence." 2 Correspondence from Jay Lefkowitz to FAUSA Sloman dated November 8, 2007 ("the judge has invited the parties to appear for the plea and sentencing on January 4th, we do not anticipate any delay beyond that date.") EFTA00225698

JAY P. LEFKOWITZ, ESQ. May 19, 2008 PAGE 2 OF 6 Background The Agreement was the product of months of negotiations. Specifically, you requested and received numerous meetings, at the highest levels of the SDFL and DOJ's Child Exploitation and Obscenity Section (CEOS) concerning claims that (a) the investigation merely produced evidence of relatively innocuous sexual conduct with some minors who, unbeknownst to Epstein, misrepresented their ages; (b) the authorities investigating Epstein engaged in misconduct; (c) the contemplated federal statutes have no applicability to this matter; and (d) the federal authorities disregarded the fundamental policy against federal intervention with state criminal proceedings. After careful review, the SDFL ultimately rejected those claims. Subsequent to its decision, however, but before proceeding any further, the SIMI, provided you with 30 days to appeal the decision to the Assistant Attorney General of the United States, Alice Fisher. As you recall, you chose to forego an appeal to AAG Fisher, and instead pursued a negotiated resolution which, ultimately, resulted in the execution of the Agreement. The Negotiation Phase During negotiations, you tried to avoid a resolution that called for incarceration and registration as a sexual offender — both of which would be triggered by a successful federal prosecution. The SDFL believed and continues to believe that should this matter proceed to trial, your client would be convicted of the federal statutes identified in the Agreement. In order to achieve a global resolution, the SDFL indicated a willingness to defer to the State the length of incarceration; however, it remained adamant that Epstein register as a sex offender and that all victims identified during the investigation remain eligible for compensation. In order to achieve this result, the parties considered two alternatives, a plea to federal charges that limited Epstein's sentencing exposure, or, as suggested by you, a plea to state charges encompassing Epstein's conduct. Ultimately, the parties agreed to, inter alia, a plea to the state charges outlined in the Agreement, registration and a method of compensation. The Agreement The crux of the Agreement defers in favor of the State federal prosecution of Epstein for his sexual conduct involving those minor victims identified as of September 24, 2007, in exchange for a guilty plea to a state offense that requires registration as a sex offender; a sufficient term of imprisonment; and a method of compensation for the victims such that they would be placed in the same position as if Epstein had been convicted of one of the enumerated offenses set forth in Title 18, United States Code, Section 2255. Specifically, the Agreement mandates, inter alia, (1) a guilty plea in Palm Beach County Circuit Court to solicitation of prostitution (Fl. Stat. Section 796.07) and procurement of minors to engage in prostitution (Fl. Stat. Section 796.03) (an offense that requires him to register as a sex offender); (2) a 30-month sentence including IS months' incarceration in county jail; (3) a methodology to compensate the victims identified by the United States; (4) entry EFTA00225699

U.S. Department of Justice United Slates Attorney Southern District of Florida First As,ramt US Attorney DELIVERY BY FACSIMILE Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP Cifigroup Center 153 East 53rd Street New York, New York 10022-4675 Re: Jeffrey Epstein Dear Mr. Lefkowitz, 99 N.F.. a Suter Mw ,v. Fl. 33132 961-9/00 May 19, 2008 I am in receipt of your e-mail dated May 19, 2008 to the United States Attorney. The U.S. Attorney would like me to advisearthat all communications and inquiries related to the Epstein matter, will be handled by AUSA Villafana and/or her supervisor, Karen Atkinson, so he does not intend to respond to your e-mail or calls unless AUSA Villafana and/or her supervisors advise him otherwise. Furthermore, you make reference to "our July 8 deadline." Respectfully, the United States Attorney's Office for the Southern District of Florida ("SDFL") has never agreed to any such deadline. Should you decide to provide the SDFL with any additional information, please do so through AUSA Villafana, and, in her absence, AUSA Atkinson. On September 24, 2007, your client, Jeffrey Epstein, in consultation with Gerald Lefcourt, Esq. and Lilly Ann Sanchez, Esq., as well as numerous other nationally-renowned lawyers, including but not limited to Harvard Law Professor Alan Dershowitz, former Independent Counsel and Solicitor General of the United States Kenneth Starr, just to name a few, entered into a global resolution of state and federal liabilities faced by your client ("the Agreement') with the SDFL. Although you and other members of the defense team have since claimed that the Agreement was the product of adhesion, the following facts demonstrate that Epstein knowingly and voluntarily entered into the Agreement in order to avoid a federal indictment regarding his sexual conduct involving minor victims. Despite the fact that by signing the Agreement, Epstein gave up the right to object to its provisions, the SDFL bent over backwards to exhaustively consider and re-consider your objections. Since these objections have finally been exhausted and Epstein has previously expressed his intent to not comply with several of the terms and conditions of the Agreement as set forth below, the SIN!, hereby notifies you that unless he complies with all of the terms and conditions of the Agreement, as modified by the United States Attorney's December 19, 2007 letter to Ms. Sanchez by close of business on Monday, June 2, 2008, the SDFL will elect to terminate the Agreement. EXHIBIT B-32 EFTA00225700

JAY P. LEFKOWITZ, ESQ. May 19, 2008 PAGE 6 OF 6 Conclusion On February 25, 2008, I sent you an e-mail setting forth a timetable for moving forward in the event that CEOS disagreed with your position. That time is now. As you know, my February 25th email stated that I would give you one week to comply with the terms and conditions of the Agreement, as modified by the USA's December 19th letter to Ms. Sanchez. In light of the upcoming Memorial Day weekend, I have decided to extend that timetable to the close of business on Monday, June 2, 2008, which is a full two weeks. Sincerely, R. Alexander Acosta United States Attorney By: Jeffrey H. Sloman First Assistant United States Attorney cc: R. Alexander Acosta United States Attorney A. Villafana Assistant U.S. Attorney Karen Atkinson Assistant U.S. Attorney EFTA00225701

JAY P. LEFICOWITZ, ESQ. May 19, 2008 PAGE 5 OF 6 C. "Mr. Epstein Does Not Believe lie Is Guilty Of The Federal Charges Enumerated Under Section 2255." At our December 14, 2007 meeting at the U.S. Attorney's Office in Miami, counsel for Epstein announced, inter alia, that it was a "profound injustice" to require Epstein to register as a sex offender and reiterated that no federal crime, especially 18 U.S.C. Section 2422(6), had been committed since the statute is only violated if a telephone or means of interstate commerce is used to do the persuading or inducing. This particular attack on this statute had been previously raised and thoroughly considered and rejected by the SDFL and CEOS prior to the execution of the Agreement. You also argued that the facts were inapplicable to the contemplated state statutes and that Epstein should not have been allowed to have been induced into the Agreement because the facts were not what he understood them to be, It should be noted that the SDFL has never provided you with any ii evidence support g its investigation. This is not, and has never been, an Alford plea situation (see North Carolina Alford, 400 U.S. 25, 91 S.Ct: 160 (1970)). Ultimately, you requested an independent review. Subsequent to the above-mentioned meeting, the SDFL received three letters from you and/or Mr. Starr which expanded on some of the themes announced in the December 14" meeting. Essentially, you portrayed the SDFL as trying to coerce a plea to unknown allegations and incoherent theories. On December 17, 2007, you decreed that Epstein's conduct did not meet the requirements of solicitation of minors to engage in prostitution (Fl. Stat. Section 796.03) one of the enumerated crimes Epstein had previously agreed to plead guilty to; that Epstein's conduct does not require registration under Florida law; and the State Attorney's Office does not believe the conduct is registrable. On December 21, 2007, you rejected the USA's proposed resolution of the 2255 provision because you "strongly believe that the provable conduct of Mr. Epstein with respect to these individuals fails to satisfy the requisite elements of either 18 U.S.C. Section[s] 2422(6) ... or 2423(b)." In your December 26, 2007 correspondence you stated that "we have reiterated in previous submissions that Mr. Epstein does not believe he is guilty of the federal charges enumerated under section 2255" and requiring "Mr. Epstein to in essence admit guilt, though he believes he did not commit the requisite offense." As the SDFL has reiterated time and time again, it does not want, nor does it expect, Epstein to plead guilty to a charge he does not believe he committed. As a result, we obliged your request for an independent de novo review of the investigation and facilitated such a review at the highest levels of the Department of Justice. It is our understanding that that independent review is now complete and a determination has been made that there arc no impediments to a federal prosecution by the SDFL. EFTA00225702

JAY P. LEFKOWITL, ESQ. May 19, 2008 PAGE 4 OF 6 B. Method of Compensation and Notification. During this same time period, you and others, including the former Solicitor General of the United States Kenneth Starr, took issue with the implementation of the methodology of compensation (hereinafter "the 2255 provision")3 and the SDFL's intention to notify the victims under 18 U.S.C. Section 3771 (you objected to victims being notified of time and place of Epstein's state court sentencing hearing). In response, the SDFL offered, in my opinion, numerous and various reasonable modifications and accommodations which ultimately resulted in United States Attorney R. Alexander Acosta's December 19, 2007 letter to Lilly Ann Sanchez. In that letter, the United States Attorney tried to eliminate all concerns which, quite frankly, the SDFL was not obligated to address, let alone consider. He proposed the 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 Codc, 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 of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." Regarding the issue of notice to the victims, USA Acosta proposed to notify them of the federal resolution as required by law; however, "rwle will defer to the discretion of the State Attorney regarding whether he wishes to provide victims with notice of the state proceedings, although we will provide him with the information necessary to do so if he wishes." As you know, you rejected these proposals as well. See December 26, 2007 correspondence from Jay Lefkowitz to USA Acosta. 3 Prior to any issues arising concerning the implementation of the 2255 provision, the SDFL unilaterally agreed to assign its responsibility to select the attorney representative for the alleged victims to an independent third-party. This was done to avoid even the appearance of favoritism in the selection of the attorney representative. As a result, on October 29, 2007, the parties executed an Addendum wherein it was mutually agreed that former United States District Court Judge Edward B. would serve as the independent third-party. Judge Davis selected the venerable law firm of Podhurs and Josefsberg to represent the approximately 34 alleged identified victims. EFTA00225703

JAY P. LEFKOWITZ, ESQ. May 19, 2008 PAGE 3 OF 6 of the guilty plea and sentence no later than October 26, 2007; and (5) the start of the above- mentioned sentence no later than January 4, 2008. Furthermore, and significantly, Epstein agreed that he had the burden of ensuring compliance of the Agreement with the Palm Beach County State Attorney's Office and the Judge of the 15'h Judicial Circuit and "that the failure to do so will be a breach of the agreement" (emphasis added). Post-Execution of the Agreement Within weeks of the execution of the Agreement, you sought to delay the entry of Epstein's guilty plea and sentence. After the SDFL agreed to accommodate your request, counsel for Epstein began taking issue with the methodology of compensation, notification to the victims, and the issues that had been previously considered and rejected during negotiations, i.e., that the conduct does not require registration and the contemplated state and federal statutes have no applicability to the instant matter. A. Delay. The Agreement required that "Epstein shall use his best efforts to enter his guilty plea and be sentenced not later than October 26. 2007. The United States has no objection to Epstein self- reporting to begin serving his sentence not later than January 4, 2008." Agreement, pages 4-5, paragraph I 1 (emphasis added). After the Agreement was executed, the SDFL accommodated your request to extend the October 26th plea deadline to November 20'h based upon, what seemed to be, reasonable scheduling conflict issues.' By early November, you represented that the presiding state court judge would not "stagger the plea and sentencing as contemplated in the Agreement."Although the Agreement clearly did not contemplate a staggered "plea and sentencing," the SDFL again agreed to accommodate Epstein's request to appear in state court for plea and sentencing on January 4, 2008.2 I "Accordingly, I have now confirmed with Mr. Epstein's Florida counsel that the state's attomey's office and the court will be available to have him enter his plea on November 20. So we will plan to proceed on one that date." October 18, 2007 email from Jay Lefkowitz to USA R. Alexander Acosta. On the same day, Mr. Lefkowitz confirmed with First Assistant Jeffrey H. Sloman that this postponement " will not affect when Epstein begins serving his sentence." 2 Correspondence from Jay Lefkowitz to FAUSA Sloman dated November 8, 2007 ("the judge has invited the parties to appear for the plea and sentencing on January 41, we do not anticipate any delay beyond that date.") EFTA00225704

JAY P. LEFKOWIT7., ESQ. May 19, 2008 PAGE 2 OF 6 Background The Agreement was the product of months of negotiations. Specifically, you requested and received numerous meetings, at the highest levels of the SDFL and DOJ's Child Exploitation and Obscenity Section (CEOS) concerning claims that (a) the investigation merely produced evidence of relatively innocuous sexual conduct with some minors who, unbeknownst to Epstein, misrepresented their ages; (b) the authorities investigating Epstein engaged in misconduct; (c) the contemplated federal statutes have no applicability to this matter; and (d) the federal authorities disregarded the fundamental policy against federal intervention with state criminal proceedings. After careful review, the SDFL ultimately rejected those claims. Subsequent to its decision, however, but before proceeding any further, the SDFL provided you with 30 days to appeal the decision to the Assistant Attorney General of the United States, Alice Fisher. As you recall, you chose to forego an appeal to AAG Fisher, and instead pursued a negotiated resolution which, ultimately, resulted in the execution of the Agreement. The Negotiation Phase During negotiations, you tried to avoid a resolution that called for incarceration and registration as a sexual offender — both of which would be triggered by a successful federal prosecution. The SDFL believed and continues to believe that should this matter proceed to trial, your client would be convicted of the federal statutes identified in the Agreement. In order to achieve a global resolution, the SDFL indicated a willingness to defer to the State the length of incarceration; however, it remained adamant that Epstein register as a sex offender and that all victims identified during the investigation remain eligible for compensation. In order to achieve this result, the parties considered two alternatives, a plea to federal charges that limited Epstein's sentencing exposure, or, as suggested by you, a plea to state charges encompassing Epstein's conduct. Ultimately, the parties agreed to, inter alia, a plea to the state charges outlined in the Agreement, registration and a method of compensation. The Agreement The crux of the Agreement defers in favor of the State federal prosecution of Epstein for his sexual conduct involving those minor victims identified as of September 24, 2007, in exchange for a guilty plea to a state offense that requires registration as a sex offender; a sufficient term of imprisonment; and a method of compensation for the victims such that they would be placed in the same position as if Epstein had been convicted of one of the enumerated offenses set forth in Title 18, United States Code, Section 2255. Specifically, the Agreement mandates, inter alia, (1) a guilty plea in Palm Beach County Circuit Court to solicitation of prostitution (Fl. Stat. Section 796.07) and procurement of minors to engage in prostitution (Fl. Stat. Section 796.03) (an offense that requires him to register as a sex offender); (2) a 30-month sentence including 18 months' incarceration in county jail; (3) a methodology to compensate the victims identified by the United States; (4) entry EFTA00225705

U.S. Department of Justice United States Attorney Southern District of Florida First Assistant U.S. Attorney DELIVERY BY FACSIMILE Jay P. Lefitowitz, Esq. Kirkland & Ellis LLP Citigroup Center 153 East 53rd Street New York, New York 10022-4675 Re: Jeffrey Epstein Dear Mr. Leficowitz, 99114E. 4 Street Mann. FL 13132 (305) 961.9100 May 19, 2008 I am in receipt of your e-mail dated May 19, 2008 to the United States Attorney. The U.S. Attorney would like me to advisesithat all communications and inquiries related to the Epstein matter, will be handled by AUSA Villafana and/or her supervisor, Karen Atkinson, so he does not intend to respond to your e-mail or calls unless AUSA Villafana and/or her supervisors advise him otherwise. Furthermore, you make reference to "our July 8 deadline." Respectfully, the United States Attorney's Office for the Southern District of Florida ("SDFL") has never agreed to any such deadline. Should you decide to provide the SDFL with any additional information, please do so through AUSA Villafana, and, in her absence, AUSA Atkinson. On September 24, 2007, your client, Jeffrey Epstein, in consultation with Gerald Lefcourt, Esq. and Lilly Ann Sanchez, Esq., as well as numerous other nationally-renowned lawyers, including but not limited to Harvard Law Professor Alan Dershowitz, former Independent Counsel and Solicitor General of the United States Kenneth Starr, just to name a few, entered into a global resolution of state and federal liabilities faced by your client ("the Agreement") with the SDFL. Although you and other members of the defense team have since claimed that the Agreement was the product of adhesion, the following facts demonstrate that Epstein knowingly and voluntarily entered into the Agreement in order to avoid a federal indictment regarding his sexual conduct involving minor victims. Despite the fact that by signing the Agreement, Epstein gave up the right to object to its provisions, the SDFL bent over backwards to exhaustively consider and re-consider your objections. Since these objections have finally been exhausted and Epstein has previously expressed his intent to not comply with several of the terms and conditions of the Agreement as set forth below, the SDFL hereby notifies you that unless he complies with all of the terms and conditions of the Agreement, as modified by the United States Attorney's December 19, 2007 letter to Ms. Sanchez by close of business on Monday, June 2, 2008, the SDFL will elect to terminate the Agreement. EXHIBIT B-32 EFTA00225706

FD-302 (Rev. 10495) -1- FEDERAL BUREAU OF INVESTIGATION Date of transcription 10/04/2007 LANE RIVERA, date of birth 06/17/1988, Social Security Accoun Number 593-70-9393, telephone number (561)689- 4717, was contacted telephonically regarding a federal investigation involving the sexual exploitation of minors. After being advised of the identity of the interviewing agent and the nature of the interview, RIVERA stated that she would not provide any info ' regarding JEFFREY EPSTEIN. The interviewing agent provided with FBI contact information. RIVERA was informed to contac t e BI should she decide to cooperate with authorities. It should be noted that RIVERA had an active warrant with the State of Florida for failure to appear regarding an arrest for shoplifting. Investigation on 10/02/2007 at West Palm Beach, Florida (telephonically) Aka 31E-MM-108062 by SA E. Nesbitt Kuyrkendall Date dictated 10/02/2007 This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its contents are not to be distributed outside your *racy CAN No 011-110716CV.MARRA P.012645 EFTA00225707

FD•302a (Rev 10.6-931 31E-MM-108062 Comirusion of FD•302 of hair. hair. Molls/ Smythe .On 06/12/2001 .Pagc 3 described one of the UWFs as tan with long brown er UWF was described as having short, bobbed, blonde said that both UWFs spoke with an accent. SMYTHE believed that an individual named STEPHANIE LNU, who is FIGUEROA's age, also provided believed she drove a Jeep Cherokee. female shay have provided name was drug over EPSTEIN told with massages. She knew of only one other N with massages. Her She was a student at RPBHS who died of a that he was a scientist. Case No 08-607M,CV•MARR EFTA00225708

FD-302a (Rev. 10-645) 31E-MM-108062 Continuation of FD-302 or Moll, Smythe On 06/12/2007 .Par 2 he responded by telling her to relax. EPSTEIN told ral times to ref STEIN also insinuated that he wan to touch him. stated that she believed EPSTEIN wante o do more than u massage him. She said that EPSTEIN propositioned her when he told her that she would get more money if she did more. She understood that to x. SMYTHE viewed EPSTEIN climax and the massa over. believed EPSTEIN got up and took a shower. did not de EPSTEIN with any further massages because s e i not want to be put in that position again. was unsure who paid her I for providing TEIN with the massage. 0.00 she received hat FIGUEROA was also paid $200.00. This was the only provided EPSTEIN with a massage. After departing the re , FIGUEROA stated that she coul ore money if she was willing to do ording to ke of an exgirlfriend, dentified who had gone to EPSTEIN's rest many occasions. said that was the reas that had so much money and was able to support him. state a 0BERTS had a nice apartment and nice clothes. believed ROBERTS had sex with EPSTEIN. and IIIIIII den i ie as oo er shirt off w en prove ing P she might have to do the same. She told age she should say she was eighteen and t back she co eive more money. FIGUEROA and pool while massage. received for friend, at she e mas age and that that if asked her called sat by the went upstairs to provide EPSTEI wi i the receiIIIIIII.00 from FIGUEROA's $200.00 he ringing to EPSTEIN. went to ROYAL PALM BEACH HIGH complet grade and a few classes during year. was unable to recall her exac provide IN with a massage. However, vided EPSTEIN with a massage shortly e about massaging EPSTEIN. III left her jewelry on a bench at EPSTEIN's residence during one o er visits to the EPSTEIN residence. She and FIGUEROA returned to the residence to retrieve her jewelry. SCHOOL where she her eleventh grade t the time she ore recalled that she ore she approached Cast No 01407364N.MARRA P-012644 EFTA00225709

FD-302 (Rev. 10-645) -t- FEDERAL BUREAU OF INVESTIGATION Dale or vansalPhon 06/12/2007 regarding of minors. agent and following MOLLY was interviewed in West Palm Beach, Florida, a fede investigation involving the sexual exploitation After being advised of the Mr of the interviewing the nature of the interview, provided the information: was introduced to JEFFREY E by a friend of hers, "TON tified as TONY FIGUEROA). stated that she knew FIGUEROA through her neighbors. She ha nown FIGUEROA for about a year when he said that she could make some easy providing a massage to a guy who lived in Palm Beach. said that FIGUEROA used the name "JEFFREY". She was aware o IN's last name only because she saw it in a Vanity Fair magazine she was looking at on and visit to Epstein's Palm Beach residence. FIGUEROA told that she would make $200.00 for providing the massage. He a s d her if asked her age she was to say she was eighteen. Prior to going to the residence with FIGUEROA, that she had "smoked weed" with FIGUEROA to calm her own. said that during that time in her life she believed she was so using Cocaine and Ecstasy. Once at the residence, EPSTEIN walked her through the house and upstairs to the spa/bathroom. One of two Unidentified White Females(UWFs).she had met previously downstairs was upstairs preparing the room for the massage. The UWF, who was topless, set ou lotions to be used during the massag UWF "coached" and had her remove her shirt and bra. was very nervous an ensed he UWF started to perform e massage on EPSTEIN. Later, began providing EPSTEIN with the massage and the UWF lef e room. EP egan the massage by lying on his stomach and instructing to perform the massag r and lower down on his back. o point, EPSTEIN asked to t his towel. After a short time EPSTEIN turne o r and continued the massage. EPSTEIN soon began to mas while E was performing the massage. Epstein asked if she rvous because she did not watch him while he mas ur ated. said that told breas s. IIIIIII feeling uncomfortable. During the massage, STEIN she had nice shaped breasts. EPSTEIN fondled her told EPSTEIN again that she was uncomfortable and maminmomml 06/12/2007 at West Palm Beach, Florida Filer 31E-MM-108062 SA E.1Ntsbitt Kuyrkendall by SA Jason R. Richards Date dictated 06/12/2007 This document contains neither rceonunendations nor conclusions of the FBI. It is the properly of the FBI and is loaned to your agency; it and its contents are not to be distributed outside your aaencv. Cu No 0840716,CV•MARRA P.012641 EFTA00225710

FD-302 (Rev. 104-95) FEDERAL BUREAU OF INVESTIGATION Om trainctwoon 10/04/2007 AMANDA BJORKLAND FREELING, date of birth 08/22/1987, Social Security Account Number 594-56-7772, cellular telephone number ( FREELING's father, MARK LNU's telephone number ( was interviewed telephonically regarding a federal i n involving the sexual exploitation of minors. After being advised of the identity of the interviewing agent and the nature of the interview, FREELING provided the following information: FREELING currently resides with her husband, BRAD FREELING, at GROTON NAVY BASE located in Connecticut. The interviewing agent inquired if FREELING was able to speak freely over the phone with her husband in the car with her. FREELING stated she was fine. When FREELING was asked about JEFFREY EPSTEIN, she told the interviewing agent that she believed she knew an EPSTEIN that had been a math teacher in the middle school she had attended. FREELING stated that she could not recall traveling with her friend ALEX HALL to EPSTEIN's Palm Beach residence. FREELING stated that she could not recall providing EPSTEIN with a massage. She asked the interviewing agent if she could take some time to think about it. At this time, FREELING was advised that she was not in any trouble but that she needed to be completely honest with the interviewing agent. FREELING stated that she was unable to remember any details regarding a JEFFREY EPSTEIN that resided in Palm Beach. The interview was concluded. Investigation on 10/02/2007 at Groton Base, Connecticut ifts 31E-MM-108062 by SA E. Nesbitt Kuyrkendall Date dictated 10/02/2007 This document contains neither recommendations nor conclusions of the FBI It is the progeny of the FBI and is loaned to your agency: it and its contents are not to be distributed outside your agency. Case No 08 SO lo ( ARR A P.012642 EFTA00225711

FD.302 (Rev. 10-6-95) - - FEDERAL. BUREAU OF INVESTIGATION Date of transcription _10/04/2007 AMANDA LASZLO, date of birth 01/21/1986, Social Security Accost ular telephone number (561)577- 0988, LNU's cellular number (954)436-9315 was in rviewe e p onica y regarding a federal investigation involving the sexual exploitation of minors. After being advised of the identity of the interviewing agent and the nature of the interview, LASZLO provided the following information: LASZLO informed the interviewing agent that she was at her new job, GROUND WORKS, a landscaping business, and did not want to get involved in an investigation regarding JEFFREY EPSTEIN. The interviewing agent attempted to set up a better time for the Illi • ew but LASZLO did not want to be interviewed. However, i een confirmed that she first met JEFFREY EPSTEIN when she was or sixteen years old. She was take STEIN's residence in Palm Beach by one of her good friends. stated that she provided EPSTEIN with massages and that she a provided these massages alone. LASZLO stated that EPSTEIN had not inappropriately her and that EPSTEIN had not masturbated in her presence. said that her friend was paid more so s ght more was a ing place between her friend and EPSTEIN. again stated to the interviewing agent that she did not wan involved and was not going to provide anymore information. said, "good luck with the case" and disconnected from the 1 invemigmwnon 10/03/2007 at Boynton Beach, FL (telephonically) Filet 31E-MM-108062 10/03/2007 Date dictated by SA E. Nesbitt Kuyrkendall This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency, it and its contents am not to be distributed outside your agency. Caw No 0849716.MMARRA P.01]611 EFTA00225712

FD-302. (RA 10.6-95) - I • FEDERAL BUREAU OF INVESTIGATION Date of transcription 10/29/2007 PIPPR date of birth 05/30/1986, Social Security Account Nu er - - 3, cellular telephone number (561)294- 8542, telephone number (561)863-9461(aunt), and telephone number (561)718-7220(father), was interviewed in West Palm Beach, Florida, regarding a federal investigation involving the sexual exploitation of minors. After being advised of the identity of the interviewing agents and the nature of the interview, HENDERSON provided the following information: believed she was first approached about N with a massage during her Junior year in as sixte friend, by drove HENDERSON and another friend, to residence. EPSTEIN gave them a tour o e ouse. recalled naked photographs of girls, especially in the here she would later provide EPSTEIN with a massage. visit, she and RADABAUGH stayed downstairs and e• vile went upstairs. providing High School. when she first met she could state IN. make at leas A few days to a e returned to EPSTEIN's residence with taken upstairs by EPSTEIN. HENDERSON began e massage y massaging EPSTEIN's feet and lower legs. EPSTEIN wearing only a towel was lying on his stomach and talking on the telephone. After approximately 10-15 minutes on the telephone, EPSTEIN hung up and turned over. EPSTEIN asked HENDERSON if she had been told t uld remove her told EPSTEIN that ve her shirt. uneasy and upset, was pal• $100.00. shirt when providing him the massage she was not told that and that she w EPSTEIN stood up completely told EPSTEIN, "I'm done." • ely ten minutes residence and AMEN department s p one number. department they contacted to repor with EPSTEIN. after leaving EPSTEIN's 911 to get the police was unsure of which police e incident that had occurred stated that there from EPSTE or is assistants. were no telephone calls to or Influigationm 10/03/2007 at West Palm Beach, rite a 31E-MM-108032 SA E. Nesbitt Kuyrkendall by SA Jason R. Richards Florida Dale dictated 10/03/2007 This document contains neither recommendations nor conclusions of the FRI IL is the property of the FBI and is loaned to your agency. it and its contents arc not to be distributed outside your agency. Case No. 08-80736-C V-MA RRA I'-012640 EFTA00225713

FD•302a (Re. 10-6-951 31E-MM-108062 Continuation of FD-302 of Danielle DICENSO .0010/25/2007 Mr 2 pulled her underwear to side, and stroked her vagina. EPSTEIN also fondled DICENSO's breasts. DICENSO stated that EPSTEIN climaxed during both massages and that he would make really weird noises while masturbating. DICENSO said that GARCIA and EPSTEIN argued. DICENSO believed GARCIA stood up for herself regarding the payment of a girl GARCIA brought to EPSTEIN to provide him with a massage. DICENSO received $200.00 each time she provided EPSTEIN with a massage. She believed GARCIA received the same amount. According to DICENSO, KELLEN may have paid their taxi fare. DICENSO stated that would call her once in a while on her cellphone to see if she vailable to provide a massage. DICENSO said that EPSTEIN told her that he was a Brain Scientist. Case No. 08-80736-CV-MARRA l'-012639 EFTA00225714

FD-302 (Rev 10-6-95) -1- FEDERAL BUREAU OF INVESTIGATION Date of transcription 10/26/2007 DANIELLE DICENSO, maiden name HEDRICK, dob 08/15/2007, 4608 Diana Drive, Apartment 3, Great Falls, Montana 59405, cellular telephone (954)801-0217, was interviewed telephonically regarding a federal investigation involving the sexual exploitation of minors. After being advised of the identity of the interviewing agents and the nature of the interview, DICENSO provided the following information: DICENSO learned through friends that there was a rich guy in Palm Beach that had a lot of models at his house and that his house was a place to hang out and have fun. DICENSO and a friend, ANGELIQUE GARCIA, maiden name CAVALLARO, traveled to JEFFREY EPSTEIN's residence in Palm Beach via a taxi cab. DICENSO believed this occurred during her 10th grade year, while attending Wellington High School. DICENSO stated that SARAH LNU(identified as ans he door and showed the girls around ouse. ven ua ly, took DICENSO and GARCIA upstairs. The girls IIIIII were sitting on ! e couch when EPSTEIN entered the room. He told them he had just come from a run and needed to shower. After showering, EPSTEIN entered the room wearing a towel. EPSTEIN conversed with DICENSO and GARCIA. DICENSO stated that when EPSTEIN asked her age she told him her true age at that time. She believed she was sixteen when she went to his residence. Later during the massage, EPSTEIN asked both girls to remove their tops. DICENSO complied with EPSTEIN's request. DICENSO stated that GARCIA refused. DICENSO believed that GARCIA was self conscious about being heavy. Both girls continued to massage EPSTEIN. At one point, EPSTEIN turned over on to his back and began to masturbate while the girls massaged him. He instructed them to massage and touch his chest. EPSTEIN rubbed and touched the girls legs and buttocks during the massage. DICENSO believed the massage lasted approximately twenty to thirty minutes. On the second visit to EPSTEIN's reside believed she accompanied her friends, GARCIA and EPSTEIN again took a shower and wore a towel. Pe request, DICENSO provided EPSTEIN with a massage wearing only her underwear. During the massage, EPSTEIN put DICENSO on the table, Invesugatmn on 10/25/2007 .t West Palm Beach, Florida (telephonically) ▪ 31E-MM-108062 Date euma 10/25/2007 SA E. Nesbitt Kuyrkendall by SA Jason R Richards This document contains neither recommendations nor conclusions of the FBI It is the property of the FBI and is loaned to your agency; it and its contents are not to be distributed outside your agency. Case No. 08-80736-CV-MARRA P-012638 EFTA00225715

FD-302• (Rev. 10-6-9S) 31E-MM-108062 CominuationaF0.Med Ellen Pitts .Oo 10/02/2007 .Par touched her. stated that when Epstein noticed she was uneasy uld pull er ack closer to him. Epstein continued to touch and digitally pe ted her vag Epstein also placed a vi rating massager on ' vagina. ' ated that Epstein touched her for approxima ely 2-5 minu es. descri he massager as a large, white back massager. Eps ein told 114 t be nervous." Epstein made a comment about how muc he liked body and how good it felt. Epstein commented that he liked e arge, firm breasts and firm butt. Pitts had no knowledge that Epstein might attempt to touch her the way he did and she believed she would only provide him a massage in nderwear. At the conclusion of the massage, Epstein paid $200-$300 in one hundred dollar bills and he asked, "does h have your numb s not recall providing her former tele mber, to anyone at the Epstein residence. was also -$300 by someone at the residence. Pitts nt Pitts believed times. Pitts be ieve Epstein's residence a coup Garcia. Garcia North Carolina. Wellingto months. Epstein's I'll' later heard that Epstein sometimes had multiple massage sessions in a day and would masturbate during each massage but would not ejaculate until the final massage of the day. Pitts stated Epstein's penis was really little and there wasn't much there. to Epstein's residence on one occasion. 's residence multiple e gone to e o Imes. married Andy is serving in the military an• may be based in Garcia formerly lived at Bahia Bay Circle, is pregnant and due in a couple of (phonetic) may have also gone to III stated she went to a Florida Marlins baseball game the weekena er her visit to Epstein's residence. Casc No. 08-80736-CV-MARRA P-012637 EFTA00225716

FO-101(Rev.10-6-91) - FEDERAL BUREAU BUREAU OF INVESTIGATION Date of transcription 10/18/2007 Pursuant to a 'nvestigation regarding the sexual exploitation of minors, Ellen Pitts, was interviewed by the Federal Bureau of In iga ion (FBI). After being advised of the identit the interviewing agents and purpose of the interview, voluntarily provided the following information: Spring drove ori r e e. Eps e went inside the residence. in engaged in cony Pitts. Epstein as t ' life plans and her wanted to know wha ig school they attended. ana is were in high Epstein was aware both attended Palm Beach Central High School. ' Junior year of high school, o Jeffrey Epstein's ch, n answered the door and and anon with interests. becaige and described the house as maze-like and "kind of creepy." peared that Epstein had girls living at the residence wi m. Pitts also observed many vehicles at the residence. walked through the main part of the house and sat on a couch w ere she began reading a magazine to try to learn little bit about Epstein. While she was seated on the couch met Sarah Last Name Unknown(LNU). glass naked room. remove her c o ing. and were wearing oniy their thong panties when Eps el ered e shower area wearing his sweat pants and a T-shirt. Epstein disrobed an aring towel when he laid down on the massage table. gave guidance and th began m • Epstein's egs. Epstein later asked to leave. put her clothes on and left Pitts alone wi pstein. went upstairs with Hedrick to an area that had two showers, a massage table and a couch. There were pictures of gib shelf located next to the couch in tower o fo tein and told to knew After left the shower area, Pitts continued massaging Epstein s egs. Epstein told Pitt "come here" and he began masturbating. Epstein began touching ' body all over. Pitts thought to herself, "Oh my god, I'm go hrow up." Epstein grabbe butt, touched her breasts and tried to pull her panties off. was very uneasy and pulled away from Epstein when he Investigation on 10/02/2007 at Palm Beach Gardens, Florida coda 31E-MM-108062 SA E. Nesbitt Kuyrkendall by SA Jason R. Richards Date dimmed 10/18/2007 This document contains neither recommendations nor conclusions of the FBI It is the property of the FBI and is loaned to your agency: it and its contents are not to be distributed outside your agency. Case No. 08-80736-CV-MARRA P-012636 EFTA00225717

FD-302a (Rev 104.9S) 31E-MM-108062 Continuation of FD-302of Sabrina Marie Ewart told that she also was ng someone you'll and did not talk much . 0a10/26/2007 .Pap 2_ paid that evening. 'lilt told get $200." Ewart was upset with on the cab ride home. App • tely one week la pstein's assistant named Sarah called Sarah invited to come back to the residence and her if you come ac with a friend he will pay Ewa ieved Sarah obtained her telephone number from s telephone number may have be -676-5619 or a• e mov oat of state to get Sarah to stop ca ing. Sarah called 2-3 more times. toll she . did not return to Epstein's residence. you. ii. was aware that Angelique and Hedrick ha een to Epstein's residence. a so hear rumors that Carrie Kincaid, who was older than had sex with Epstein. ted her mother message th had sent her. reference to to Jeffrey's h time the cab would pick her up. going downtown. was suspicious about a text The text message was in IIIIIrt a certain time and the told her mother she was Approximately two months ago, Ewart was contacted by private investigators working on behalf of Epstein. She met with a female and a male investigator and told them the details of her relationship with Epstein. She described the male private investigator as an older man. Casc No. 08-80736-C V-MARRA P-012635 EFTA00225718

FD-302 (Rcv 10-6-95) - I - FEDERAL BUREAU OF INVESTIGATION Date of transcription 10/29/2007 Pursuant to a on regarding the sexual exploitation of minors, was interviewed by the Federal Bureau of Investiga i er being advised of the identity of the interviewing agents and purpose of the interview, Ewart voluntarily provided the following information: Ewart was introduced to Jeffrey Epstein when she approximately 16 or 17 years old. During the begi 11th year at Palm Beach Central High School, told about a "filthy rilllifuy who would pay girlsrror ge. Miller told she could make $300 by giving jiving him a Epstein a massage. raveled with Miller to Epstein's residence in a taxi cab. ' the kitchen area of the residence prior to going upstairs. noticed pictures of naked women in the upstairs room. S o observed a massage table and a shower/sauna area in the room. Epstein entered the massage room wearing a robe and told ;I'll he w ing to take a shower. Epstein disrobed and took a s ower as waited. He finished showering and placed a towel around his w 1 t. Epst ' on his back on the massage table. Epstein inquired about interests and she told him she wanted to be a Pharmaceu Ica epresentative. Epstein offered to send her books regarding Pharmaceutical Representatives. Epstein instructed to massage ' est and asked her to remove her shirt. Dur e massage, was wearing her sports bra, a skirt and thong panties. Ewart s a ed she was very uncomfortable. Epstein also asked Ewart to remove her underwear. Epstein removed his towel expos s penis and began masturbating. Epstein fondled by reaching under her skirt and touching her butt and rubbi r vagina over her underwear. Mi n pulled her underwear to the side and rubbed her vagina. backed away from Epstein multiple times but he continued persuading her. in stated, "this is normal, nothing's wrong." Epstein fondled for approximately 5- utes as he masturbated. Epstein ejaculated and paid 00-$300. observed Epstein get the cash from a desk. left the residence with Miller in a taxi cab. On the ca ide home Miller Investigation on 10/26/2007 at West Palm Beach, Florida idea 31E-MM-108062 SA E. Nesbitt Kuyrkendall by SA Jason R. Richards Date dictated 10/29/2007 This document contains neither recommendations nor conclusions of the FBI. It is the propeny of the FBI and is loaned to your agency, it and its contents are not to be distributed outside your agency. Case No. 08-80736-CV-MARRA I'-012634 EFTA00225719

FD-30≥ (Rev. I0-6-95) FEDERAL BUREAU OF INVESTIGATION Date of transcription 1Q/10/2007 JENNIFER AMENOLD was interviewed in Royal Palm Beach, Florida regarding a federal investigation involving the sexual exploitation of minors. After being advised of the identity of the interviewing agents and the nature of the interview, AMENOLD provided the following information: was first approached to provide massages to y her brother's friend, TONY FIGUEROA. FIGUEROA that she would receive $ or providing the only other instruction was told by FIGUEROA she should say she was eight asked by EPSTEIN. MI stated that she provided EPSTEIN with less than ten massages. OLD was paid $200.00 for each massage. After the first massage EPSTEIN asked AMENOLD for her number. AMENOLD was unsure of how she provided EPSTEIN with her phone number. AMENOLD that FIGUEROA was paid for bring her to the residence. IIIIIIIr provided EPSTEIN with a false name, Veronica. EPSTEIN r called her on providing a false name to him. She believed NOI 's assistant discovered her true name when leaving her a massage regarding massage appointments. AMENOLD could tuber the cellular telephone number she was using at that time. JEFF told massa was that said as the massages with EPSTEIN progressed they became more an more sexual. During the second to last massage AMENOLD provided to EPSTEIN, EPSTEIN digitally penetrated AMENOLD. EPSTEIN would also masturbate during the massages. The last time AMENOLD went to EPSTEIN's residence friends(later identified as NICOLE RADABAUGH and AMENOLD's friends refused EPSTEIN's sexu requ s. stated that EPSTEIN called her upstairs and was upset with her cause her friends refused him. Upon leaving EPSTEIN's residence, contacted ROYAL PALM BEACH POLICE DEPARTMENT referred them to PALM BEACH POLICE DEPARTMENT to recall what official they spoke with re transpired between EPSTEIN and the girls. they had provided false names when making IIIIIIIIIIIpher friends BPD . AMENOLD was unable what had also stated that rt. Investigation on 10/10/2007 at Royal Palm Beach, Florida File a 31E-MM-108062 by SA E. Nesbitt Kuyrkendall Date dictated 10/10/2007 This document contains neither recommendations nor conclusions of the FBI It is the properly of the FBI and is loaned to your agency. it and its contents are not to be distributed outside your agency. Case No. 08-80736-CV-MARRA 1,-012633 EFTA00225720

FD-302a (Rev. 10-6-95) 31E-MM-108062 Continuation of FD-302 of .On 03/25/2008 .Pail° other girlfriends to massage him. He told her she could accompany any of the girls she referred. After that second time of going by hersel ded not to return by herself and that is when she took with her for the third session with JEFFREY. DANIELLE claimed she did not refer other girls to JEFFREY because all her other friends were from the Performing Arts School and they were very "straightlaced kids with good morals an 1111 inging". The only friend she referred to JEFFREY was DANIELLE was asked if she ever heard about JEFFREY taking pictures or videos of the girls who provided massage services. She stated she had no knowledge regarding that aspect of JEFFREY EPSTEIN's life. Case No. 08-80736-CV-MARRA P-0)2632 EFTA00225721

FD•302 (Rev. 10-6-95) FEDERAL BUREAU OF INVESTIGATION Date of transcription 03/26/2008 (hereafter referred to as DANIELLE), a e o it c o er 11, 1986, address 405 W. 45th , New York, NY 10019, cellular telephone number telephonically contacted Special Agent (SA) MARIA he New York Division of the Federal Bureau of Investigation (FBI). DANIELLE provided the following information: DANIELLE stated her friend had called her after DANIELLE had spoken to FBI agen s on arc 20, 2008. She stated they spoke briefly about captioned investigation but did not "swap notes" about details of the information they provided to interviewing agents. DANIELLE informed SA JOHNSON that she was concerned about providing the correct time frame regarding her involvement with JEFFREY EPSTEIN. DANIELLE stated AMANDA had told her it was sometime in the summer months of 2004 when she first met JEFFREY EPSTEIN because she recalled it was hot and sunny outside. DANIELLE then remembered purchasing a summer sleeveless dress during that time frame and she had worn tank tops and short skirts whenever she visited JEFFREY at his home. DANIELLE apologized for the confusion of the time line. If this time line is correct, she was 17 years old when she first met JEFFREY. DANIELLE stated she had also recalled a particularly embarrassing situation she had not disclosed to interviewing agents when she first spoke to them (SAs JOHNSON AND KRISTINA L. NORRIS) on March 20, 2008. She stated she wanted to block that memory because she was ashamed. DANIELLE added that on the second occasion when she had gone to JEFFREY's home, by herself to give him a massage, he had masturbated in front of her. DANIELLE stated he had disrobed in front of her and laid down on the massage table with a towel around his mid-section face down. After a few minutes, JEFFREY had placed his hand underneath him and started stroking his penis. He began making sounds and she stopped massaging him. He then asked her if she was uncomfortable and she answered "yes". He then got upset, stopped masturbating, and paid her $300.00. She asked if she could leave and he told her that he did not want her to massage him anymore. However, he offered to pay her $200.00 if she referred Inwsuption on 03/25/2008 Aka 31E-MM-108062 at New York, NY (telephonically) by Maria E. Johnson Date dictated This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its contents are not to be distributed outside your agency. Case No. 08-80736-CV-MARRA P-012631 EFTA00225722

FD-302. (Rcv. 104.95) 31E-MM-108062 cominoaionofF63020f M. Hannah Benskv .O" 03/20/2008 Pate 6 Nonetheless, is cognizant that JEFFREY has a lot of money and power and now a this has come to light, she fears him and fears for her safety. DANIELLE stated she was not in contact with most of the girls aforementioned but stated that GIL CASTILLANE, cell phone number (Iiillif6-7743 would probably have contact information for MARINA, and LEANNE. DANIELLE provided the number for LESLIE LNU, JEFFREY's assistant as (212) 838-9514 which she believes was JEFFREY's office number and AMANDA LNU's number which is (631) 889- 1868. Case No. 08-80736-CV-MARRA P-012630 EFTA00225723

10-302a (Rev. 104-95) 31E-MM-108062 Continuation of FD-302 of Hannah Benskv .On 03/20/2008 .ftst 5 also lived in Queens, NY. It is her belief that MARINA was recruited by another female (name unknown) who went to high school in Queens, NY, DANIELLE never met this other female. MARINA then seemed to be the one recruiting more girls for JEFFREY by the time DANIELLE met MARINA. MARINA did not graduate high school and seemed content enough to make money giving JEFFREY massages. DANIELLE heard through". that nMARINA, and LEANNE "would do things with JEFF When hat she meant by that she replied they would have sex with him. Moreover, DANIELLE went with AMANDA to JEFFREY's office to collect money he owed her. She described the building being located on 53rd street between Madison and Park avenues in NYC. She remembered seeing the exterior of the building as marble with large columns on either side. She believes this was the only occasion she was ever in his office building. When was asked whether she had ever been asked to take trips with outside of NYC she stated she had not. However, she had overheard MARINA brag to the other girls about going on a trip with JEFFREY to West Palm Beach, Florida. She was going on about going to West Palm Beach on a boat and having a great time in Florida. DANIELLE believes that MARINA probably went on a trip if not several trips with JEFFREY to Miami and West Palm Beach, FL but did not have further information on this matter. Once DANIELLE disassociated herself from those girls, she never heard anymore details of the trips. She stated that once she refused to take LESLIE's or JEFFREY's calls and did not refer any more girls to his house, she stopped hanging around so much with the other girls who did. The last time she saw MARINA was at a club when DANIELLE was 19 years old. She does not keep in contact with her but she knows that GIL is still very good friends with MARINA. DANIELLE stated that JEFFREY EPSTEIN used to like to boast about all the celebrities he knew and loved to "name drop" and make calls to celebrities in the movie industry while he was getting a massage. JEFFREY at one point had claimed to know, GELSEY KIRKLAND, a famous ballet star, KIERA ng others. He thought this would impress her but since mother was in show business for a long time she was not ease y impressed. Case Nu. 08-80736-CV-MARRA 1,-0I 2629 EFTA00225724

FD4Cta(tcli. IG-6-95) 31E-MM-108062 Continuation of FD-302 of Hannah Benskv .0n03/20/2008 thy 4 worked at JEFFREY EPSTEIN's office and he was the same JEFFREY that she had met and had massaged. MARINA told her to give LESLIE a call to make an appointment. DANIELLE called the number on her caller ID and it was the business number for JEFFREY's office. A woman by the name of CECILIA LNU called and said LESLIE would call her right back. LESLIE immediately called and told her that she needed to contact AMANDA to make ano er appointment and needed her cell phone number which DANIELLE provided. A few minutes later, AMANDA called DANIELLE and asked that she go with her to JEFFREY'S house. DANIELLE agreed and it was the same scenario as the previous visit. Once again, after a few minutes of DANIELLE in the mass m she was asked to leave. When she returned to the room, and JEFFREY were both nude. they got paid $300.00 eac . AMANDA again refused to tell IIIIIIII( w ened once she left the room. DANIELLE recalled going wi h to JEFFREY's house a total of three times. DANIEL- from talking to the other girls like MARINA and LEANNE that was still going to JEFFREY's house even after DANIELLE stopped going. On one occasion AMANDA went to see JEF d she came home crying. She stated that JEFFREY had asked to straddle him on the massage table and simulate sexual in e with him. AMANDA became very upset and JEFFREY ended up throwing the money at her and yelled for her to get out of his home. DANIELLE added JEFFREY called her directly on her cell phone and asked her to refer more girls to him. DANIELLE stopped taking calls from JEFFREY or any of his assistants because she did not want to refer any other girls to JEFFREY. She stated she had made a mistake by giving out AMANDA's number to LESLIE i first place and did not want to make the same mistake again. recalls getting paid about $1000.00 in the few months she a visited JEFFREY's home. DANIELLE stated that her apartment was like a revolving door where all her friends stopped by. DANIELLE would hear things about JEFFREY once the girls and some of the boys (like CHRIS TROUSDALE and GIL). She recalled that one of MARINA's friends, who was about 15 at the time, would also give JEFFREY massages. DANIELLE did not know her very well but knew that she Case No. 0840736-CV-MARRA P-012628 EFTA00225725

FD-302a (Rev. 10.6.95) 31E-MM-108062 Continuation of FD-302 of Hannah Benskv .on 03/20/2008 "iv 3 towel he had wrapped around his waist. JEFFREY ' on the massage table face down and kept the towel on. then massaged his back and legs. JEFFREY at no time ouc e er or disrobed in front of her. After 20 minutes of being massaged he got off the table and paid her $300.00 in $100.00 bills. (It should be noted that JEFFREY always paid her using $100.00 bills only). After the massage was over, JEFFREY told DANIELLE he did not want her to massage him again because she reminded him of his niece. He told her that he wanted her to bring him other girls instead. At no time did he discuss her age or asked about the ages of her friends. He did not ask that he bring a girl with a specific hair color or age but did ask for slim and petite girls. About a week later, MARINA called DANIELLE again ld her she had set up another appointment. DANIELLE had told about it and said that she should go with her and they coul o make some easy money. DANIELLE told AMANDA about her experience and since he never touched her or tried anything sexual with her, she thought it was okay to get AMANDA involved. The girls then went to JEFFREY's apartment and he again led them to the massage room. He asked them both to take their clothes off which they refused. They came to a compromise and they agreed to strip down to their bras and panties. JEFFREY then went to the other room, and came back undressed with a towel wrapped around his waist. iris then began to massage ' d then JEFFREY asked to leave the room and for to stay. After some t m , ELLE went back into the room an she noticed that both AMANDA and JEFFREY were nude. JEFFREY was on the massage table and AMANDA was closer to the door. JEFFREY then paid each girl $400.00 in $100.00 bills. The girl ssed and left JEFFREY'S home. AMANDA refused to tell what had happened in the room but she seemed upset. About a week later, DANIELLE received a call from a LESLIE LNU, who identified herself as calling on behalf of JEFFREY EPSTEIN's office. She left a message on DANIELLE's cell phone (which is the same number she has currently) telling her that she needed to call LESLIE back as soon as possible. DANIELLE did not return her call as she did not know who these people were. A few minutes later, MARINA called DANIELLE. MARINA told her LESLIE LNU Case No. 08.80736-CV-MARRA P-012627 EFTA00225726

FD-302a (Rev. 104-95) 31E-MM-108062 Continuation or FD-302 of Hannah Henskv .0n03/20/2008 .Page 2 MARINA told the girls that she and LEANNE knew a man by the name of JEFFREY LNU who would IIIIIII0.00 to girls who would give him a massage. MARINA told and DANIELLE that it was very legitimate and that he never touched them, he just wanted to see a pretty girl giving him a massage at home. DANIELLE was suspicious and wondered why he would pay so much money just for a just a massage. MARINA told her it was very easy money and she required to do anything else but massage him. MARINA told that JEFFREY just wanted to have pretty young girls around About a week later, MARINA called DANIELLE and told her that she had made an appointment for DANIELLE to go to JEFFREY's house to give him a massage. DANIELLE had never agreed to this but felt obligated to go to the appointment now that MARINA had set it up. MARINA gave her the address of JEFFREY's apartment which was located on 63rd street at Central Park East (from what she can recall). She also remembered the apartment was adjacent to the Ralph Lauren store in the Upper East Side, NYC. DANIELLE was still apprehensive about going but since the appointment was during the day she figured nothing bad could happen. She recalled that the apartment was a four story brownstone and when she pressed the buzzer a maid answered the door. She noticed two security cameras facing the front doorstep. The maid asked her to sit in the foyer and then the maid left. DANIELLE was very nervous and she sent a text to AMANDA telling her that she was nervous and was thinking about leaving. After five minutes she got up to leave but just then the maid showed up and told her that JEFFREY would be with her shortly and not to leave. In a minute or so JEFFREY came downstairs and introduced himself. She described him as a man in his 60's with salt and pepper hair and about 5'9". He then led her to an elevator where they went up to the fourth floor. He then took her to a room that was set up like a massage parlor complete with massage table and an assortment of massage oils, lotions, and other aroma-therapy products. JEFFREY then explained that he wanted her to strip to her underwear and massage him. DANIELLE declined but did take some of her clothes off. She left on a tank top and what she called "booty shorts" which she was wearing underneath her clothes. JEFFREY then left the room and returned fully undressed with the exception of a Casc No. 08-80736-CV-MARRA P-012626 EFTA00225727

FD-302 (Rev. 104-95) • I - FEDERAL BUREAU OF INVESTIGATION Dace of transcripcion 03/24/2008 DANIELLE HANNAH BENSKY (hereafter referred to as date of birth October 11, 1986, address 405 W. 45th ree , pt. 6A, New York, NY 10019, cellular telephone number (646) 226-1463, was interviewed at the New York Office of the Federal Bureau of Investigation (FBI), located at 26 Federal Plaza, New York, NY 10278. After being advised of the ident he interviewing agents and the nature of the interview, provided the following information: DANIELLE stated she is currently employed at the 49 Grove Street club (located at that address) in New York, NY and is also a student at H.B. Studios studying to be an actor. DANIELLE added that prior to that she was a student at the Professional Performing Arts School (PPAS) located on 48th Street between 8th and 9th avenues in New York City (NYC). DANIELLE added she was not living with her parents while attending high school; she lived with her then boyfriend, CHRIS TROUSDALE (he was in a boy band called Dream Street) and her friend AMANDA LAST NAME UNKNOWN (LNU). All three lived in an apartment located at 218 East 96th Street between 2nd and 3rd avenues in NYC. DANIELLE had a best friend by the name of GIL CASTILLANE. He attended a high school (name unknown) in Queens, NY and it was through GIL that DANIELLE met a girl by the name of MARINA LNU. GIL and MARINA LNU had met at middle school (name unknown) also in Queens, NY and since they both had moved from NYC, they had this bond and became very close friends. was about 17 years of age when she met MARINA LNU who was a u or 15 years old at the time, but who was very street savvy. DANIELLE stated that MARINA LNU hung out with an older crowd and was smart beyond her years. DANIELLE stated that she actually deferred to her whenever they went out "to party" because MARINA seemed to know everyone in the club scene. DANIELLE stated she and AMANDA LNU began hanging out with MARINA LNU and her friend LEANNE LNU. She recalled that sometime after her 18th birth e sometime in November 2004), MARINA, LEANNE, AMANDA, AND were taking a cab to a club. MARINA and LEANNE were talk a something in a quiet tone and DANIELLE asked them what was going on. After some hesitation, Investigation on 03/20/2008 at New York, NY File i 31E-mm-108062 Maria E. Johnson by Kristina L. Norris Date dictated This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its contents arc not to be distributed outside your agency. Case No. 08-80736-CV-MARRA P-0 12625 EFTA00225728

FD-302 (Rev. 104-95) -I- FEDERAL BUREAU OF INVESTIGATION Data or irmutrimicm 10 /09 / 2007 date of birth 10/11/1986, was telephonica y in iewe regarding a federal investigation involving the sexual exploitation of minors. After being advised of the identity of the interviewing agent and the nature of the interview, BENSKY provided the following information: BENSKY believed she first met JEFFREY EPSTEIN during the end of her Junior Year. BENSKY was attending the Professional Performing Art School located near 48th Street and 8th or 9th Avenue. LEANN Last Name Unknown(LNU) told BENSKY she could make a lot of money providing a quick massage. BENSKY was taken by LEANN LNU to EPSTEIN's residence. BENSKY only provided EPSTEIN with a massage on one occasion. EPSTEIN told BENSKY that he would pay her to find and bring him other girls. BENSKY believed she was paid $200.00. BENSKY stated that there were other girls she was aware of that had provided EPSTEIN with massages prior to her. LEANN LNU attended Queens High School, Astoria, New York. ENISA LNU who was at least a year younger than BENSKY also attended Queens High School. MARINA LNU, who was taught from home, brought and f birth 10/08/1986, old cellular M itt number like MARINA LNU, was also being taught from home. s at hat ould go to EPSTEIN's residence weekly. BENSKY stated that wou d be paid more money by EPSTEIN. BENSKY believed the amount was $300.00. BENSKY told the interviewing agents that11111as had a difficult time coping with her contact with EPSTEIN. BENSKY stated that they would telephone CEICLA LNU or LESLIE LNU, EPSTEIN's assistants, to schedule appointments with EPSTEIN. LESLIE LNU would also contact BENSKY to set up appointments. EPSTEIN told BENSKY that he could trust her to find new girls. EPSTEIN would also ask BENSKY, "When are you getting more girls?" Investigation on 10/05/2007 at File a 31E-MM-108062 (telephonically) by SA E. Nesbitt Kuyrkendall Date dictated 10/05/2007 This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its contents arc not to be distributed outside your agency. Case No. 08-80736-CV-MARRA RX I I I Rf f 13-31 EFTA00225729

a. A parcel of land located at 358 El Brillo Way, Palm Beach, Florida 33480, including all buildings, improvements, fixtures, attachments, and easements found therein eon, and more particularly described as: Being all of Lot 40 and the West 24.3 feet of Lot 39, El Bravo Park, as recorded in Plat Book 9, Page 9, in the records of Palm Beach County, Florida and BEING that portion lying West of Lot 40, El Bravo Park, in Section 27, Township 43 South, Range 43 East, as recorded in Plat Book 9, Page 9, Public Records of Palm Beach County, Florida, being bounded on the West by the West si fan existing concrete seawall and the northerly extension thereof as sho the Adair & Brady, Inc., drawing IS-1298, dated March 25, 1981, and bounded on the East by the shoreline as shown on the plat of El Bravo Park, and bounded on the North and South by the Westerly extensions of the North and South lines respectively of Lot 40, containing 0.07 acres, more or less. Pursuant to Title 18, United States Code, Section 1594(b). A A TRUE BILL. FOREPERSON R. ALEXANDER ACOSTA UNITED STATES ATTORNEY A. MARIE VILLAFANA ASSISTANT UNITED STATES ATTORNEY 54 EFTA00225730

(a) cannot be located upon the exercise of due diligence; has been transferred or sold to, or deposited with, a third person; has been placed beyond the jurisdiction of the Court; (d) has been substantially diminished in value; or (e) has been commingled with other property which cannot be divided without difficulty; it is the intent of the United States, pursuant to Title 18, United States Code, Section 2253(o), to seek forf of any other property of said defendant up to the value of the above forfeitable property. Pursuant to Title 18, United States Code, Section 2253. FORFEITURE 3 Upon conviction of any of thAolations alleged in Counts 2-11 of this indictment, the defendants, JEFFREY EPSTEIN, (b) MS and shall forfeit to the United States any property, real or personal, that was used or intended to be used to commit or to facilitate the commission of such violation; and any property, real or personal, constituting or derived from any proceeds that such person obtafed, directly or indirectly, as a result of such violation, including but not limited to the following: 53 EFTA00225731

a/k/a ' and shall forfeit to the United States any property, real or personal, constituting or traceable to gross profits or other procee fined from such offense; and any property, real or personal, used or intended to be used to commit or to promote the commission of such offense, including but not limited to the following: a. A parcel of land located at 358 El Brillo Way, Palm Beach, Florida 33480, including all buildings, improvements, fixtures, attachments, and easements found therein or thereon, re particularly described as: Being all of Lot 40 and the West 24.3 feet of Lot 39, El Bravo Park, as recorded in Plat Book 9, Page 9, in the records of Palm Beach County, Florida and BEING that portion lying West of Lot 40, El Bravo Park, in Section 27, Township 43 South, Range 43 East, as recorded in Plat Book 9, Page 9, Public Records of Palm Bea County, Florida, being bounded on the West an by the West side of exis g ncrete seawall and the northerly extension thereof as shown on the Adair & Brady, Inc., drawing IS-1298, dated March 25, 1981, and bounded on the East by the shoreline as shown on the plat of El Bravo Park, and bounded on the North and South by the Westerly extensions of the North and South lines respectively of Lot 40, containing 0.07 acres, more or less. Pursuant to Title 18, United States Code, Section 2253. If any of the forfeitable property desEed in the forfeiture section of this indictment. as a result of any act or omission of the defendants JEFFREY EPSTEIN, and 52 EFTA00225732

Pursuant to Title 28, United States Code, Section 2461; Title 18, United States Code. Section 981(aX1)(C); and Title 21, United States Code, Section 853. property described above as being subject to forfeiture, as a result of any act or omission of the defendants, JEFFREY EPSTEIN, ,* and cannot be located upon the exercise of due diligence; (1) (2) has beektl9nsferred or sold to, or deposited with a third person; (3) has been placed beyond the jurisdiction of the Court; (4) has been substantially diminished in value; or (5) , ADRIANA has been commingled with other property which cannot be subdivided without difficulty; A it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), to seek forfeiture of any other property of the defendants up to the value of the above forfeitable property. All pursuant to Title 28 United States Code, Section 2461; Title 18, United States Code, Section 981(a)(1)(C); and Title 21 United ates Code, Section 853. FORFEITURE 2 Upon conviction of any of the violations alleged in Counts 12-29 of this indictment, the defendants, JEFFREY EPSTEIN, ADRIANA ROSS, 51 EFTA00225733

sexual conduct as defined in 18 U.S.C. § 2423(f), with a person under 18 years of age, that is, the person(s) listed in each count below: ( min Date(s) Minor(s) Involved Defendant(s) 26 7/16/2004 Jane Doe #7 Jane Doe #8 Jane Doe #9 Jane Doe #10 JEFFREY EPSTEIN 27 3/31/2005 R Jane Jane Doe #14 Jane Doe #15 Doe #16 JEFFREY EPSTEIN ng 9 18/2005 Jane Doe #16 JEFFREY EPSTEIN SARAH KELLEN ADRIANA 29 9/29/05 Jane Doe #16 .A JEFFREY EPSTEIN Sta All in violation of Title 18, United States Code, Sections 2423(b) and 2. FORFEITURE 1 Upon conviction of the violation alleged in Count I of this indictment, the defendants, JEFFREY EPSTEIN, SARAH KELFN, Mucinska," and , shall forfeit to the United States any property, real or personal, which constitutes or is derived from proceeds traceable to the violation. 50 EFTA00225734

18 U.S.C. § 2423(f), with another person, in violation of Title 18, United States Code, Section 2423(6); all in violation of Title 18, United States Code, Section 2423(e). COUNT 25 D(Facilitation of Unlawful Travel of Another: 18 U.S.C. § 2423(d)) 61. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 62. From at least as early as in or about 2001 through in or around October 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere efendant, did, for the purpose of commercial advantage or private financial gain, arrange and facilitate the travel of a person, that is Defendant Jeffrey Epstein, knowing that such person was traveling in na interstate commerce for the purpose of gaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f); in violation of Title 18, U ' tates Code, Section 2423(d). COUNTS 26 THROUGH 29 (Travel to Engage in Illicit Sexual Conduct: 18 U.S.C. § 2423(6)) 63. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 64. On or about the dates enumerated to F each count listed below, from a place outside the Southern District of Florida to a place inside the Southern District of Florida, the Defendant(s) listed below traveled in interstate commerce for the purpose of engaging in illicit 49 EFTA00225735

COUNT 23 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 57. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by refereniphough fully set forth herein. 58. From in or around August 2003 through in or around February 2004, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, R JEFFREY EPSTEIN, and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #18, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 24 (ravel: 18 U.S.C. § 2423(e)) 59. Paragraphs 1 through 25 of this indictment are re-alleged and incorporated by reference as fully set for the herein. 60. From at least as early as 2001 through in or around October 2005, the exact dates being unknown to the Grand Jury, the Defendants, JEFFREY EP IN, did knowingly and willfully conspire with each other and with others known and unknown to travel in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 48 EFTA00225736

JEFFREY EPSTEIN, SARAH ICE and did us acility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce or entice Jane Doe #16, who was a person who had not attained the age of 18 years, to engage in prostitution and in a sexual activity for which a person can be charged with a criminal offense, that is a violation of Florida Statutes Section 794.05; in violation of Title 18, Red States Code, Sections 2422(b) and 2. COUNT 22 (Enticement of a Minor: 18 U.S.C. § 2422(6)) 55. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 56. From in or around Feb 2005 through in or around April 2005, the exact dates being unknown to the Grand Jury, in alm Neach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN, and did use a facility or means of interstate commerce, 7 s, the telephone, to knowingly persuade, induce and entice Jane Doe #17, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. 47 EFTA00225737

COUNT 20 (Enticement of a Minor: 18 U.S.C. § 2422(b)) b Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by referen though fully set forth herein. 52. From in or around December 2004 through on or about June 5, 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, R JEFFREY EPSTEIN, and ADRIANA ROSS, aThia did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #I5, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. 41/4 OUNT 21 (Enticement o a inor: 18 U.S.C. § 2422(b)) 53. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 54. From in or around February 2005 through in or around the first week of October 2005, the exact dates being unknown to e Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, 46 EFTA00225738

did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #13, who was a person who had not attained the age of 18 years, to engage 'stitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 19 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 49. Paragraphs I through 25 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. i 50. From i around November 2004 through in or around March 2005, the exact dates being unknown e Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN, and did use a facility or means of interstate otnrnerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #I4, wh a person who had not attained the age of 18 years, to engage in prostitution and in a sexual activity for which a person can be charged with a criminal offense, that is a violation of Florida Statutes Section 794.05; in violation of Title 18, United States Code, Sections 2422(b) and 2. F 45 EFTA00225739

COUNT 17 (Enticement of a Minor: 18 U.S.C. § 2422(b)) b Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by referen though fully set forth herein. 46. From in or around the middle of 2004 through on or about April 22, 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, R JEFFREY EPSTEIN and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #12, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. OUNT 18 (Enticement of inor: 18 U.S.C. § 2422(b)) 47. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 48. From in or around August 2004 through on or about May 27, 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of F Florida, and elsewhere, the defendants, JEFFREY EPSTEIN and 44 EFTA00225740

engage in prostitution and in a sexual activity for which a person can be charged with a criminal offense, that is a violation of Florida Statutes Section 794.05; in violation of Title 18, United States CDSections 2422(b) and 2. COUNT 16 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 43. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 44. From i around July 2004 through on or about January 31, 2005, the exact dates being unknown c Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN and did use a facility or means of interstate oturnerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #10, wh a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. F 43 EFTA00225741

(Enticement of a Minor: 18 U.S.C. § 2422(6)) 39. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by refe as though fully set forth herein. 40. From in or around July 2004 through in or around October 2004, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, R JEFFREY EPSTEIN and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #8, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 15 (Enticement ofieVinon 18 U.S.C. § 2422(b)) 41. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 42. From in or around July 2004 through on or around December 29, 2004, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, F JEFFREY EPSTEIN and SARAH KELLEN, did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #9, who was a person who had not attained the age of 18 years, to 42 EFTA00225742

36. From in or around the spring of 2003 through on or about October 2, 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of FloridaEylsewhere, the defendants, JEFFREY EPSTEIN and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #3, who was a person who had not attained the age of 18 years, to engage in prostitution ' Rn a sexual activity for which a person can be charged with a criminal offense, that is violations of Florida Statutes Sections 800.04(5)(a), 800.04(6)(a), and 800.04(7)(a); in violation of Tide 18, United States Code, Sections 2422(b) and 2. COUNT 13 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 37. Paragraphs 1 through of this Indictment are re-alleged and incorporated by reference as though fully set fo ein. 38. In or around July 2004, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN and SARAH KEIT, did use a facility or means of interstate commerce, t at is, the telephone, to knowingly persuade, induce and entice Jane Doe #7, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 14 41 EFTA00225743

COUNT 11 (Sex Trafficking: 18 U.S.C. § 1591(a)(2)) b Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by re refen though fully set forth herein. 34. From at least as early as in or about 2001 through in or about October 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, J DRIANA did knowingly benefit, financially or by receiving anything of value, from participation in a venture, as defined in 18 U.S.C. §1591(cX3), which had engaged in an act described in violation of 18 U.S.C. §1591(aX1), that is, the recruiting, enticing, providing, and obtaining by any means a person, in or affecting interstate An erce, knowing that the person or persons had not attained the age of 18 years and would be caused to engage in a commercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title 18, United States Code, Sections 1591(a)(2), 1591(6)(2), and 2. COUNT 12 (Enticement of a Minor: ltp.S.C. § 2422(b)) 35. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 40 EFTA00225744

Count Date(s) Minor Involved Defendant(s) 2004 5D July 2004 through January 31, 2005 Jane Doe #10 JEFFREY EPSTEIN SARAH KELLEN 6 Mid-2004 through April 22, 2005 Jane Doe #12 JEFFREY EPSTEIN 7 August May 2004 005 Jane Doe #13 JEFFREY EPSTEIN 8 November 2004 through March 2005 Jane Doe #14 JEFFREY EPSTEIN 9 December 2004 through June 5, 2005 Jane Doe # I5 JEFFREY EPSTEIN 10 February 2005 through first week of October 2005 Jane Doe #16 JEFFREY EPSTEIN SARAH KELLEN All in violation of Title 18, United States bode, Sections 1591(a)(1) and 2. 39 EFTA00225745

from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. D All in violation of Title 18, United States Code, Section 371. COUNTS 2 THROUGH 10 (Sex Trafficking: 18 U.S.C. § 1591(a)(1)) 31. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. itz th 32. On or t the dates enumerated as to each count listed below, the exact dates being unknown to e Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the Defendants listed below did knowingly, in and affecting interstate and foreign commerce, recruit, entice, provide, and obtain by any means a person, that is, the person in each count listed below, knowing that the person had not attained the age of 18 years and wAl be caused to engage in a commercial sex act as defined in 18 U.S.C. § 1591(c)(1): Count Date(s) Minor Involved Defendant(s) 2 2001 - 2004 Jane Doe #2 JEFFREY EPSTEIN 3 January 2004 through July 2004 Jane Doe F JEFFREY EPSTEIN SARAH KELLEN 4 July 2004 through December 29, Jane Doe #9 JEFFREY EPSTEIN SARAH KELLEN 38 EFTA00225746

New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Hyperion Air, Inc. LL (220) On or about June 30, 2005, Defendants JEFFREY EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (221) On or about July 22, 2005, Defendants JEFFREY EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream raft owned by Hyperion Air, Inc. (222) On or about August 18, 2005, Defendants JEFFREY EPSTEIN, " and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (223) On or about SAther 3, 2005, Defendants JEFFREY EPSTEIN and " traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (224) On or about September 18, 2005, Defendants JEFFREY EPSTEIN, and " traveled from Westchester County, New York to Palm BeF County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (225) On or about September 29, 2005, Defendants JEFFREY EPSTEIN, " and traveled 37 EFTA00225747

traveled from New York, New York to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC. i iiL (214) On or about February 21, 2005, Defendants JEFFREY EPSTEIN, , and traveled from the U.S. Virgin Islands to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC. (215) On or about February 24, 2005, Defendants JEFFREY EPSTEIN, and traveled from Teterboro, New Jersey to Palm Beach Cotmty,Rda, aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (216) On or about March 4, 2005, Defendants JEFFREY EPSTEIN, ADRIANA " and traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (217) On or about ivf t 18, 2005, Defendant JEFFREY EPSTEIN traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (218) On or about March 31, 2005, Defendant JEFFREY EPSTEIN traveled from New York, New York to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC. F (219) On or about May 19, 2005, Defendants JEFFREY EPSTEIN, and 36 " traveled from Teterboro, EFTA00225748

(208) On or about January 1, 2005, Defendants JEFFREY EPSTEIN, and traveled from Anguilla, British D Indies to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (209) On or about January 6, 2005, Defendant JEFFREY EPSTEIN traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (210) R about January 14, 2005, Defendants JEFFREY EPSTEIN, " and traveled from the U.S. Virgin Islands to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC. (211) On or about January 19, 2005, Defendants JEFFREY EPSTEIN, ADRIANA ROSS " and traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (212) On or about February 3, 2005, Defendants JEFFREY EPSTEIN, SARAH and d from Columbus, Ohio, to Palm Beach County, Florida, aboard the Boeing 727 aircra€ owned by JEGE, INC. (213) On or about February 10, 2005, Defendants JEFFREY EPSTEIN, ADRIANA ," and 35 EFTA00225749

(202) On or about October 29, 2004, Defendants JEFFREY EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach ty, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (203) On or about November 10, 2004, Defendants JEFFREY EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (204) On or about November 18, 2004, Defendants JEFFREY EPSTEIN, SARAH ICELR, " and NADIA traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (205) On or about December 3, 2004, Defendants JEFFREY EPSTEIN, and ADRIANA ROX, a/k/a traveled from New York, New York to Palm Beach COly, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (206) On or about December 13, 2004, Defendant JEFFREY EPSTEIN traveled from the U.S. Virgin Islands to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (207) On or about December 17, 004, Defendants JEFFREY EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. 34 EFTA00225750

(196) On or about July 4, 2004, Defendants JEFFREY EPSTEIN, , and traveled from Aspen, Colorado to Palm County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (197) On or about July 16, 2004, Defendants JEFFREY EPSTEIN, , and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (198) R about July 22, 2004, Defendants JEFFREY EPSTEIN, , and traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (199) On or about August 19, 2004, Defendants JEFFREY EPSTEIN and pv ed from Van Nuys, California to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (200) On or about August 25, 2004, Defendants JEFFREY EPSTEIN, and traveled from Ecuador to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (201) On or about October 2, 2004Ffendants JEFFREY EPSTEIN, , and traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. 33 EFTA00225751

(190) On or about March 5, 2004, Defendant JEFFREY EPSTEIN verbally reprimanded Jane Doe #18 for bringing Jane Doe #19 to 358 El Brillo Way when she was lling to undress for him. The Defendants' Travel (191) On or about March I 1. 2004, Defendants JEFFREY EPSTEIN, and traveled from Teterboro, New Jersey, to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, (192) On or about May 1, 2004, Defendants JEFFREY EPSTEIN, and traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (193) On or about May 14, 2004, Defendants JEFFREY EPSTEIN, and NA traveled from Canada to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (194) On or about June 11, 2004, Defendants JEFFREY EPSTEIN and traveled from Chicago, Illinois to Palm Beach County, Florida aboard the Gulfstream aircraft owned by renon Air, Inc. (195) On or about June 20, 2004, Defendants JEFFREY EPSTEIN and traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. 32 EFTA00225752

Jane Does #18 and #19 (182) In or around the last half of 2003, Jane Doe #18 was approached by A.F. D as asked whether she would be willing to provide a massage to Defendant JEFFREY EPSTEIN in exchange for $200. (183) In or around the last half of 2003, Defendant JEFFREY EPSTEIN asked Jane Doe #18 to provide her telephone number. (184) On or around August 27, 2003, Defendant placed a telephone call telephone used by Jane Doe #18. (185) In or around the last half of 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #18, who was then a seventeen-year-old-girl. (186) On or around November 16, 2003, Defendant placed a telephone call to a telephone used by Jane Doe #18. (187) In or around Mast half of 2003, Defendant JEFFREY EPSTEIN digitally penetrated Jane Doe #18, who was then a seventeen-year-old-girl. (188) In or around the last half of 2003, Defendant JEFFREY EPSTEIN asked Jane Doe #18 to recruit other females to travel to 358 El Brillo Way. (189) On or about March 5, 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #19, who was then a seventeen-lar-olFrl, to leave when she refused to remove her shirt. 31 EFTA00225753

(174) On or about September 30, 2005, Defendant a/k/a ," placed a telephone call to a telephone used by Jane Doe #16. (175) On or about October 1, 2005, Defendant left a telephone message for Defendant JEFFREY EPSTEIN stating: "[Jane Doe #15] confirmed at 11 AM and [Jane Doe #16] - 4PM". (176) On or about October 2, 2005, Defendant SARAH placed a telephone call to a telephone used by Jane Doe #I6. (177) It about October 3, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. (178) On or about October 3, 2005, Defendant left a telephone message for Defendant JEFFREY EPSTEIN stating: "[Jane Doe #16] will be 'h hour late". (179) In or around tfie t week of October, 2005, Defendant JEFFREY EPSTEIN engaged in sexual intercourse with Jane Doe #16, who was then a seventeen-year-old girl. (180) In or around the first week of October, 2005, Defendant JEFFREY EPSTEIN made a payment of $350.00F Jane Doe #16, who was then a seventeen-year-old girl. (181) In or around the first week of October, 2005, Defendant JEFFREY EPSTEIN provided a gift of Secret lingerie to Jane Doe #16 for her eighteenth birthday. 30 EFTA00225754

(164) On or about June 30, 2005, Defendant telephone call to a telephone used by Jane Doe #16. D telephone call to a telephone used by Jane Doe #16. (166) On or about July 22, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. (167) On or about August 18, 2005, Defendant placed a telephone call telephone used by Jane Doe #16. (168) On or about August 19, 2005, Defendant " placed a telephone call to a telephone used by Jane Doe #16. (169) On or about August 21, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. (170) On or about Amber 3, 2005, Defendant a/k/a " placed a telephone call to a telephone used by Jane Doe #16. (165) On or about July 2, 2005, Defendant SARAH placed a placed a (171) On or about September 18, 2005, Defendant telephone call to a telephone used by Jane Doe #16. (172) On or about September 19, 2005, Defendant message to a telephone used by Jane Doe #1E (173) On or about September 29, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. 29 placed a sent a text EFTA00225755

(156) In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doe #16, who was then nteen-year-old girl. (157) In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN asked Jane Doe #16, who was then a seventeen-year-old girl, how old she was, and she responded that she was seventeen years old. (158) In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN engRin sexual activity with Defendant in the presence of Jane Doe #16, who was then a seventeen-year-old girl. (159) In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN asked Jane Doe #16, who was then a seventeen-year-old girl, to touch the breast of Defendant (160) On or about AA, 2005, Defendant ," placed a telephone call to a telephone used by Jane Doe #16. (161) On or about April 11, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. (162) On or about April 11, 2005, Defendant left a message for Defendant JEFFREY EPSTEIN statingFpane Doe #16) can work tomorrow at 4pm." (163) On or about May 19, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #I6. 28 EFTA00225756

girl. and Jane Does #16 & #17 (149) In or around February 2005, Defendant JEFFREY EPSTEIN rbated in the presence of Jane Doe #16, who was then a seventeen-year-old (150) In or around the first quarter of 2005, Defendants JEFFREY EPSTEIN caused Jane Doe #16 to place a telephone call to Jane Doe #17 to ask her to travel to 358 El Brillo Way. (151) R around the first quarter of 2005, Defendant JEFFREY EPSTEIN caused a payment to be made to Jane Doe #16 for recruiting Jane Doe #17 to travel to 358 El Brillo Way. (152) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #17, who was then a sixteen-year-old girl. (153) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN instructed Jane Doe #17, who was then a sixteen-year-old girl, to remove all of her clothing. (154) In or around the first quarteir 2005, Defendant JEFFREY EPSTEIN placed a massaging device on the vagin of Jane Doe #17, who was then a sixteen-year-old girl. (155) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #17, who was then a sixteen-year-old girl. 27 EFTA00225757

(139) On or about February 4, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #15. D (140) On or about February 10, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #15. (141) On or about February 21, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #15. (142) On or about February 24, 2005, Defendant placed a telephone call tRlephone used by Jane Doe #15. (143) On or about March 17, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #15. (144) On or about March 30, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #15. (145) On or about A 31, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #15. (146) On or about March 31, 2005, Defendant ," placed a telephone call to a telephone used by Jane Doe #15. (147) On or about April 1, 2005, one of Defendant JEFFREY EPSTEIN's employees prepared a note for Defendan FFREY EPSTEIN's review that read: "10:30 [Jane Doe #15]/[Jane Doe #10] on Fri around 2'Oclock". (148) In or around June 2005, Defendant JEFFREY EPSTEIN provided Jane Doe #15 with a gift of Secret lingerie for her eighteenth birthday. 26 EFTA00225758

(131) On or about March 29, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #I4. Jane Doe #15 (132) On or about December 6, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #15. (133) On or about December 14, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #15. (134) R around the first half of 2005, Defendant led Jane Doe #15 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (135) In or around the first half of 2005, Defendant JEFFREY EPSTEIN instructed Jane Doe #15, whoAs then a seventeen-year-old girl, to pinch his nipples while he masturbated. (136) In or around the first half of 2005, Defendant JEFFREY EPSTEIN fondled the breasts of Jane Doe #15. (137) In or around the first half of 2005, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #15. 14 F (138) On or about January 7, 2005, Defendant a/k/a Doe #15. " placed a telephone call to a telephone used by Jane 25 EFTA00225759

(122) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN performed oral sex on Jane Doe #14, who was then a seventeen-year-old girl. D (123) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN made a payment of $600 to Jane Doe #14. (124) On or about January 8, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #14. (125) On or about January 9, 2005, Defendant ," plaR telephone call to a telephone used by Jane Doe #14. (126) On or about January 26, 2005, one of Defendant JEFFREY EPSTEIN's employees prepared a written telephone message for Defendant review regarding a call received from Jane Doe #14 that read: "She is confirming for 5:30". (127) On or about 26, 2005, Defendant " placed a e ep one call to a telephone used by Jane Doe #14. (128) On or about February 1, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #14. (129) On or about March 1, 2005, Defendant ," placed a telephone call to a telepIF used by Jane Doe #14. (130) On or about March 21, 2005, Defendant a/lc/a 'SI' placed a telephone calls to a telephone used by Jane Doe #14. 24 EFTA00225760

(114) In or around the last half of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #14, who was then a seventeen-year-old girl, to pinch his nipples. D (115) In or around the last half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #14, who was then a seventeen-year old girl. (116) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe #14. (117) In or around the end of 2004 and the beginning of 2005, Defendant JEFFREY ERIN digitally penetrated Jane Doe #14, who was then a seventeen-year-old girl. (118) In or around the end of 2004 and the beginning of 2005, Defendant JEFFREY EPSTEIN asked Jane Doe #14, who was then a seventeen-year-old girl, whether she had any plans for her eighteenth birthday and acknowledged that she had not yet turned eighteen. A (119) On or about December 23, 2004, Defendant JEFFREY EPSTEIN caused a Western Union wire transfer order to be sent to Jane Doe #14. (120) In or around the first quarter of 2005, Defendant JEFFREY tr EPSTEIN placed a massaging device on agina of Jane Doe #14, who was then a seventeen-year-old girl. (121) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN engaged in sexual intercourse with Jane Doe #14, who was then a seventeen-year-old girl. 23 EFTA00225761

(106) In or around the end of 2004, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doe #13, who was then a seventeen-year-old girl. D (107) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #13. (108) In or around the last half of 2004, Defendant JEFFREY EPSTEIN digitally penetrated Jane Doe #13, who was then a seventeen-year-old girl. (109) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #13, was then a seventeen-year-old girl, about her age. (110) In or around the last half of 2004, Defendant JEFFREY EPSTEIN told Jane Doe #13 that he wanted to take her to Paris but he could not because Jane Doe #13 was not yet eighteen years old. (111) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #13 to bring her frAto his home, especially "girls who looked like [Jane Doe #13]." Jane Doe #14 (112) In or around the last half of 2004, Defendant led Jane Doe #14 from the kitchen of 358 El Grillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 ElFillo Way. (113) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #14 to provide her telephone number. 22 EFTA00225762

(97) On or about August 21, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #13. D (98) In or around the last half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #12, who was then a seventeen-year-old girl. (99) In or around the last half of 2004, Defendant JEFFREY EPSTEIN digitally penetrated Jane Doe #12, who was then a seventeen-year-old girl. (100) R around the last half of 2004, Defendant JEFFREY EPSTEIN attempted to place a massaging device on the vagina of Jane Doe #12, who was then a seventeen-year-old girl. (101) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #12. (102) In or around thA half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #12, who was then a seventeen-year-old girl, about her age. (103) In or around the last half of 2004, Defendant JEFFREY EPSTEIN told Jane Doe #12 that he would take her to Los Angeles when she turned eighteen. (104) In or around the last half of 2004, Defendants JEFFREY EPSTEIN and caused Jane Doe 12 to recruit Jane Doe #13 to travel to 358 El Brillo Way. (105) In or around the last half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #13, who was then a seventeen-year-old girl. 21 EFTA00225763

(91) In or around 2004, Defendant JEFFREY EPSTEIN told Jane Doe #11 that he would pay her to find and bring him more girls. D (92) In or around 2004, Defendant JEFFREY EPSTEIN paid $200 to Jane Doe #11 for recruiting a minor female to travel to his New York home. (93) In or around 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #11 when she would be getting more girls. (94) On or about April 5, 2005, one of Defendant JEFFREY EPSTEIN's employees premed a written message for Defendant JEFFREY EPSTEIN's review regarding a telephone call received from Jane Doe #11 that read: "Re does she have any new friends you can meet - I was away over the weekend so I have not spoken to anyone new. But, [unidentified Jane Doe] will be around later today and I know she really wants to work. The others should be back around Thursday. Let me know about [unidentified Jane Doe]." A (95) On or about June 22, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #11. Jane Does #12 and #13 (96) On or about August 2, 2004, an employee of Defendant JEFFREY EPSTEIN prepared a written telephoF message for Defendant JEFFREY EPSTEIN's review regarding a telephone call received from T.M. and Jane Doe #12 that stated: "They are available all weekend and maybe pane Doe #13] too". 20 EFTA00225764

(83) On or about December 30, 2004, Defendants JEFFREY EPSTEIN and caused the purchase of Broadway tickets as an eighteenth birthday r Jane Doe #9. (84) In or around the last half of 2004 or January 2005, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #10, who was then a seventeen-year-old girl. (85) In or around the last half of 2004 or January 2005, Defendant JEFFREY EPSTEIN fondR e breasts of Jane Doe #10, who was then a seventeen-year-old girl. (86) On or about January 14, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #10. (87) On or about January 27, 2005, Defendant a/k/a ," placed one or more telephone calls to a telephone used by Jane Doe #10. (88) On or about January 28, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #10. (89) On or about February 1, 2005, Defendant placed one or more telephone calls to a telep used by Jane Doe #10. r (90) In or around February 200 , efendant JEFFREY EPSTEIN caused a payment of $200 to be made to Jane Doe #9 for recruiting Jane Doe #16 to travel to 358 El Brillo Way. Jane Doe #11 19 EFTA00225765

and (75) In or around the last half of 2004, Defendants JEFFREY EPSTEIN engaged in oral sex and sexual intercourse in the ce of Jane Doe #9, who was then a seventeen-year-old girl. (76) In or around the last half of 2004, Defendant JEFFREY EPSTEIN forcibly inserted his penis into the vagina of Jane Doe #9, who was then a seventeen-year-old girl. (77) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe #9. (78) R around the last half of 2004, Defendant JEFFREY EPSTEIN rubbed the vagina of Jane Doe #10, who was then a seventeen-year-old girl. (79) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #10. (80) On or about vember 28, 2004, Defendant JEFFREY EPSTEIN A arranged for one of his emplo e provide an envelope filled with cash to Jane Doe #9. (81) On or about December 4, 2004, Defendant provided a written message to Defendant JEFFREY EPSTEIN regarding Jane Does # 9 and 10, stating: "[Jane Doe #10] would like to work @ 4:00 pm if possible. [[Jane Doe #9] is scheduled for 5:00 today.] the movie is @11 (82) On or about December 29, 2 , Defendant placed a telephone call to a telephone used by Jane Doe #9. 18 EFTA00225766

Jane Does #9 and #10 (66) On or about July 15, 2004, Defendant a re telephone calls to a telephone used by Jane Doe #9. (67) On or about July 16, 2004, Defendant placed one caused Jane Doe #9 to make one or more telephone calls to a telephone used by Jane Doe #10. (68) On or about July 17, 2004, Defendant telephone call to a telephone used by Jane Doe #9. (69) placed a about July 18, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #9. (70) On or about July 22, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #9. (71) In or around JA004, Defendant JEFFREY EPSTEIN fondled the breasts of Jane Doe #9, who was then a seventeen-year-old girl. (72) In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #9, who was then a seventeen-year-old girl. (73) In or around July 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #9. F (74) On or about July 22, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #10. 17 EFTA00225767

(64) In or around July 2004, Defendant JEFFREY EPSTEIN told Jane Doe #7 that if she reported to anyone what had occurred at Defendant JEFFREY EPSTEIN's 12 bad things could happen to her. (65) On or about July 24, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #8. R A F 16 EFTA00225768

(55) On or about July 15, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #8. D (56) On or about July 15, 2004, Defendant placed a telephone call to a telephone used by T.M. (57) On or about July 16, 2004, Defendant placed one or more telephone calls to a telephone used by Jane Doe #7. (58) On or about July 16, 2004, Defendant placed a telephone call telephone used by T.M. (59) On or about July 17, 2004, one of Defendant JEFFREY EPSTEIN's employees prepared a written telephone message for Defendant JEFFREY EPSTEIN's review regarding a telephone call received from T.M. that read: "Me & [Jane Doe #7] A can come tomorrow any time or .M.] alone". (60) In or around y 04, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #7, who was then a sixteen-year-old girl. (61) In or around July 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #7, who was then a sixteen-year-old girl, to rub his nipples. nti (62) In or around July 2004, Defe JEFFREY EPSTEIN stroked the vagina of Jane Doe #7, who was then a sixteen-year girl. (63) In or around July 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #7. 15 EFTA00225769

(46) In or around July 2004, Defendant JEFFREY EPSTEIN led T.M., who was then a fifteen-year-old girl, and Jane Doe #7, who was then a n-years-old girl, from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (47) On or about July 4, 2004, Defendant made one or more telephone calls to a telephone used by Jane Doe #7. (48) On or about July 5, 2004, Defendant placed a telephone call R:lephone used by T.M. (49) In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #8, who was then a seventeen-year-old girl. (50) In or around July 2004, Defendant JEFFREY EPSTEIN stroked the vagina of Jane Doe #8, who was then a eventeen-year-old girl. (51) In or around` y 2004, Defendant JEFFREY EPSTEIN paid approximately $200 to Jane Doe #8. (52) In or around July 2004, Defendant JEFFREY EPSTEIN paid $200 to T.M. for recruiting Jane Doe #8 to travel to 358 El Brillo Way. (53) In or around July 2004, Def t SARAH told Jane Doe #8 Tin that Defendant JEFFREY EPSTEIN would p Jane Doe #8 if she returned with a friend. (54) On or about July 15, 2004, Defendant placed one or more telephone calls to a telephone used by Jane Doe #7. 14 EFTA00225770

(37) In or around the first half of 2004, Defendant JEFFREY EPSTEIN stroked the vagina of Jane Doe #4, who was then a seventeen-year-old girl. D (38) In or around the first half of 2004, Defendant JEFFREY EPSTEIN paid $200 to Jane Doe #4. (39) In or around the first half of 2004, Defendant JEFFREY EPSTEIN paid $200 to Jane Doe #5. (40) In or around the first half of 2004, Defendant JEFFREY EPSTEIN asked Jane DR -what high school she attended. (41) In or around the first half of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #4 to leave so that Jane Doe #6 could massage him alone. (42) In or around the first half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presenceitne Doe #6, who was then a sixteen-year-old girl. (43) In or around the first half of 2004, Defendant JEFFREY EPSTEIN digitally penetrated Jane Doe #6, who was then a sixteen-year-old girl. (44) In or around the first half of 2004, Defendant JEFFREY EPSTEIN placed a large vibrating massager on the vagina of Jane Doe #6, who was then a sixteen-year-old girl. F (45) In or around the first half of 2004, Defendant JEFFREY EPSTEIN caused a payment of $200 to be paid to Jane Doe #6. Jane Does #7 and #8 13 EFTA00225771

(30) On or about January 14, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #3. D (31) employees prepared a written telephone message for Defendant JEFFREY EPSTEIN's review regarding a telephone call received from Jane Doe #3 that read: "I have a female for him." On or about January 29, 2005, one of Defendant JEFFREY EPSTEIN's Jane Does #4, #5, and #6 (32) Raround the first half of 2004, Defendant led Jane Doe #4 and Jane Doe #5 to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (33) In or around the first half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #4 about her age, and Jane Doe #4 responded with her true age. (34) In or around thirst half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #4, who was then a seventeen-year-old-girl, and Jane Doe #5, who was then a seventeen-year-old girl. (35) In or around the first half of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #4, who was then a e nteen-year-old girl, to play with his nipples. F (36) In or around the first half of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #4, who was then a seventeen-year-old girl, to remove her clothing. 12 EFTA00225772

(22) On or about October 30, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #3. D (23) In or around 2004, Defendant JEFFREY EPSTEIN directed Jane Doe #3, who was then a sixteen- or seventeen-year-old girl, to straddle an adult female and to touch the adult female's breasts. (24) In or around 2004, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of an adult female in the presence of Jane Doe #3, who was then a sixteen- or seven-year-old girl. (25) In or around 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #3. (26) In or around 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #3 to rub his nipples. (27) In or around 2ADefendant JEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doe #3, who was then a sixteen- or seventeen-year-old girl. (28) In or around 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #3 to recruit additional females to come to 358 El Brillo Way. (29) On or about November 8, 2004, one of Defendant JEFFREY EPSTEIN's employees prepared a written telephone mge for Defendant JEFFREY EPSTEIN's review regarding a telephone call received from Jane Doe #3 that read: "I have a female for him? 11 EFTA00225773

(13) In or around 2003, Defendant told Jane Doe #2 that Defendant JEFFREY EPSTEIN had asked to take nude photographs of Jane (14) In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #2, who was then a sixteen-year-old girl. (15) In or around 2003, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #2, who was then a sixteen-year-old girl. (16) Raround 2003, Defendant placed a telephone call to a telephone used by Jane Doe #2 to make an appointment for Jane Doe #2 to travel to 358 El Brillo Way. (17) On or about April 23, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #2. (18) On or about A 2, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #2. Jane Doe #3 (19) In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #3, who was then a fifteen-year-old girl. (20) In or around 2003, DefendFJEFFREY EPSTEIN made a payment of $200 to Jane Doe #3. (21) On or about October 26, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #3. 10 EFTA00225774

(6) In or around 2001, Defendant placed a telephone call to a telephone used by Jane Doe #2 to make an appointment for Jane Doe #2 to travel to D I Brillo Way. (7) In or around 2001, JEFFREY EPSTEIN engaged in sexual intercourse with an unidentified female in the presence of Jane Doe #2, who was then a fourteen-year-old girl. (8) In or around 2001, Defendant JEFFREY EPSTEIN paid $300 to Jane Doe #2, who was thRourteen-year-old girl, for allowing an unidentified female to perform oral sex on Jane Doe #2 in EPSTEIN's presence. (9) On or about March 11, 2003, an employee of Defendant JEFFREY EPSTEIN prepared a written telephone message for Defendant JEFFREY EPSTEIN's review regarding a telephone call received from Jane Doe #2. (10) In or around A Defendant JEFFREY EPSTEIN asked Jane Doe #2 if she had any younger friends who would be interested in engaging in similar activities with him. (II) In or around 2003, Defendant took nude photographs r of Jane Doe #2, who was then a sixteen-year girl. (12) In or around 2003, Defendant RAH made a payment of $500 to Jane Doe #2 in exchange for posing for nude photographs. 9 EFTA00225775

(e) It was further a part of the conspiracy that Defendant JEFFREY EPSTEIN would pay minor females to engage in lewd conduct with Defendant to satistyndant JEFFREY EPSTEIN's prurient interests. Overt Acts 30. In furtherance of this conspiracy and to effect the objects thereof, there was committed by at least one of the co-conspirators herein, at least one of the following overt acts, among others, in the Southern District of Florida, and elsewhere: R Jane Does #1 and #2 (1) In or around the beginning of 2001, Defendant JEFFREY EPSTEIN engaged in sexual activity with Jane Doe #1, who was then a seventeen-year-old girl, in the presence of Jane Doe #2, who was then a fourteen-year-old girl. (2) In or around 2001, Defendant led Jane Doe #2 from the kitchen of 358 El Brillo WayAtairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (3) In or around 2001, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #2, who was then a fourteen-year-old girl. (4) In or around 2001, Defendant JEFFREY EPSTEIN asked Jane Doe #2, who was then fourteen years' old, to pitch his nipples while he masturbated. (5) In or around 2001, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe #2. 8 EFTA00225776

29. The manner and means by which the Defendants and other participants sought to accomplish the purpose and object of the conspiracy included the following: (a) It was part of the conspiracy that Defendants " , and other participants would contact minor females via the use of cellular and other telephones to arrange appointments for minor females to travel to 358 El Brillo Way and the New York residence to allow Defendant JEFFREY EPSTEIN to engage in lewd conduct with them. (b) I as further a part of the conspiracy that Defendants JEFFREY EPSTEIN, and • and other participants would make payments to, or cause payments to be made to, minor females in exchange for engaging in lewd conduct. (c) It was further a part of the conspiracy that Defendants JEFFREY EPSTEIN, AD 1A and other participants would ask females to recruit other minor females to engage in lewd conduct with Defendant JEFFREY EPSTEIN. (d) It was further a part of the conspiracy that Defendants JEFFREY EPSTEIN, and other F participants would make payments to, or cause p ents to be made to, the recruiters for bringing additional minor females to 358 El Brillo Way and the New York residence to engage in lewd conduct with Defendant JEFFREY EPSTEIN. 7 EFTA00225777

COUNT 1 (Conspiracy: 18 U.S.C. § 371) Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by refe as though fully set forth herein. 27. From at least as early as 2001, the exact date being unknown to the Grand Jury, through in or around October 2005, in Palm Beach County, in the Southern District of Florida, and elsewhere, the Defendants, JEFFREY EPSTEIN, R DRIANA ROSS, aAc/a " did knowingly and willfully combine, conspire, confederate and agree with each other and with others known and unknown to commit an offense against the United States, that is, to use a facility or means of ingrate 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(h). Purpose and Object of the Conspiracy 28. It was the purpose and object of the conspiracy to procure females under the age of 18 to travel to 358 El Brillo Way and the New Fic residence so that JEFFREY EPSTEIN could, in exchange for money, engage in lewd conduct with those minor females in order to satisfy JEFFREY EPSTEIN's prurient interests. Manner and Means 6 EFTA00225778

23. During the period of her involvement with the Defendants, Jane Doe #10 attended Lake Worth High School in Palm Beach County. D During the period of her involvement with the Defendants, Jane Doe #11 attended the Professional Performing Arts School, a public high school, located in New York, New York. 25. During the period of her involvement with the Defendants, Jane Doe #13 attended John I. Leonard High School in Palm Beach County. R A F 5 EFTA00225779

of any act involving sexual activity in the presence of a victim who is less than 16 years of age, commits lewd or lascivious exhibition," which is a felony of the second degree. I) Pursuant to Florida Statutes Section 800.04(2), InJeither the victim's lack of chastity nor the victim's consent is a defense to the crimes proscribed by [Section 800.04]." 15. Pursuant to Florida Statutes Section 800.04(3), "[t]he perpetrator's ignorance of the victim's age, the victim's misrepresentation of his or her age, or the perpetrator's bona fide belief of the victim's age cannot be raised as a defense in a prosecution under [Section 800.04]." R 16. Pursuant Florida Statutes Section 800.02, a "person who commits any unnatural and lascivious act with another person commits a misdemeanor of the second degree." 17. Defendant JEFFREY EPSTEIN was over the age of 24 and did not have any medical license. 18. During the period of her involvement with the Defendants, Jane Doe #4 attended Wellington High School and Palm Bekentral High School in Palm Beach County. 19. During the period of her involvement with the Defendants, Jane Doe #5 attended Wellington High School in Palm Beach County. 20. During the period of their involvement with the Defendants, Jane Does # 6, 8 and 12 attended Palm Beach Central High School in Palm Beach County. 21. During the period of her involveFt with the Defendants, Jane Doe #7 attended William T. Dwyer High School in Palm Beach County. 22. During the periods of their involvement with the Defendants, Jane Does # 9, 14, 15, 16, 17, 18, and 19 attended Royal Palm Beach High School in Palm Beach County. 4 EFTA00225780