CONFIDENTIAL PLEA NEGOTIATIONS TERMS OF EPSTEIN NON-PROSECUTION AGREEMENT ■ Epstein pleads guilty (not nolo contendere) to an Information filed by the Palm Beach County State Attorney's Office charging him with: (a) lewd and lascivious battery on a child, in violation of Fl. Stat. 800.04(4); (b) solicitation of minors to engage in prostitution, in violation of Fl. Stat. 796.03; and (c) engaging in sexual activity with minors at least sixteen years of age, in violation of Fl. Stat. 794.05. ■ Epstein and the State Attorney's Office make a joint, binding recommendation that Epstein serve at least two years in prison, without any opportunity for withholding adjudication or sentencing; and without probation or community control in lieu of imprisonment. ■ Epstein agrees to waive all challenges to the information filed by the State and the right to appeal. ■ Epstein agrees that, if any of the victims identified in the federal investigation file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the U.S. District Court for the Southern District of Florida over his person and the subject matter. Epstein will not contest that the identified victims are persons who, while minors, were victims of violations of Title 18, United States Code, Sections(s) 2422 and/or 2423. ■ After Epstein enters his state court plea and is sentenced, the FBI and the U.S. Attorney's Office will close their investigations. Case No. 08-80736-CV-MARRA P-013429 EFTA00230334

FOWL E RWHITE Caw BURNETT ' MAIN • FORT LAUDERDALE • WEST PALM BEACH • St PETERSBURG August 2, 2007 Mr. Chief, Criminal Division United States Attorney's Office Southern District of Florida 99 NE 4 Street Miami, Florida 33132 Re: Jeffrey Epstein Dear Matt: ESPIRITO SANTO PLAZA FOURTEENTH FLOOR I 395 BRCKELL AVENUE Mum. FLORIO* 33131 TELEPHONE (305) 7699200 FACSIMILE 1305) 7899201 MIVW.FOWLERVINITE.COM DIRECT MMONE No.: (305) 7609279 DIRECT FAcsomit NO.:1305) 728.7579 [email protected] As we discussed at Tuesday's meeting, and consistent with our view that no federal prosecution should lie in this matter, Mr. Epstein is prepared to resolve this matter via a state forum. We are in receipt of your memo regarding same and as the dynamics of the meeting did not allow for us to fully detail our proposal, we do so now. We believe that our respective positions are not very far apart and that a mutually agreeable resolution can be reached that will accomplish the interests of the United States Attorney's Office as well as those of the community. We welcomed your recognition that a state prison sentence is neither appropriate for, nor acceptable to, Mr. Epstein, as the dangers of the state prison system pose risks that are clearly untenable. We acknowledge that your suggestion of a plea to two federal misdemeanors was an attempt to resolve this dilemma. Our proposal is significantly punitive, and if implemented, would, we believe, leave little doubt that the federal interest was demonstrably vindicated. The Florida state judicial system, unlike the federal system, provides for numerous types of onerous sanctions after a defendant is remanded to the custody of the state. The sentence is tailored to the needs of the local community and the risk posed by a specific defendant. After a great deal of thought, our proposal consists of both a severe supervised custody, with an assurance that any violation would result in the immediate implementation of the two year period of incarceration. We must keep in mind that Jeffrey Epstein is a 54-year old man who has never been arrested before. He has lived an otherwise exemplary life, characterized by both many charitable contributions and philanthropic acts. His reputation has suffered significantly as a result of his poor judgment in these matters. He is well aware of the ramifications of his past behavior and, accordingly, there is no concern, whatsoever, that he will re-offend. castRIREMbifttinfAittRA P-013430 EFTA00230335

Page 2 The following proposal is offered as an assurance to the community that the goals of appropriate punishment and rehabilitation are attained. We will agree to a sentence of two years in state prison pursuant to Florida Statute 948.012(2) which permits a split sentence whereby Mr. Epstein will be sentenced to a term of supervised custody, followed by a period of incarceration. Supervised custody in the state system includes potential daily surveillance, administered by officers with restricted case loads. Supervised custody is an individualized program in which the freedom of Mr. Epstein is limited to the confines of his residence with specific sanctions imposed and enforced. See Florida Statute 948.001(2). Should Mr. Epstein successfully complete the terms and conditions of his custody, the Judge will eliminate the incarcerative portion of the sentence. If Mr. Epstein, however, fails to comply with the conditions of his supervised custody. The period of incarceration will be immediately implemented. We, therefore, propose the following: Two years supervised custody with the following mandatory and special conditions: o Confinement to home o Report to a community control officer at least once a week or more often as directed by the officer o Permit a community control officer to visit him unannounced at home at any time, day or night o Obtain psychological counseling o No unsupervised contact with all the victims in the instant case o Perform community service o Payment of Restitution o Application of 18 U.S.C. § 2255' o Payment of a contribution of a defined amount to a charitable • organization benefitting victims of sexual assault o Payment of Court and probationary costs o Payment of law enforcement investigative costs o Submit to random drug testing o Refrain from associating with persons engaged in criminal activities o Refrain from committing any new law offenses o Any other specific conditions that the Office may deem necessary Two additional years of reporting probation: 18 U.S.C. 2255 provides that any minor who suffers injury as a result of the commission of certain offenses shall recover actual damages and the cost of any suit. It is important to note that Mr. Epstein is prepared to fully fund the identified group of victims which arc the focus of the Office - that is, the 12 individuals noted at the meeting on July 31, 2007. This would allow the victims to be able to promptly put this behind them and go forward with their lives. If given the opportunity to opine as to the appropriateness of Mr. Epstein's proposal, in my extensive experience in these types of cases, the victims prefer a quick resolution with compensation for damages and will always support any disposition that eliminates the need for trial. CasgWagtei3V-VflivrAtiRRA P-013431 EFTA00230336

Page 3 o Mandatory conditions as provided in Florida Statute § 948.03 o Special conditions as stated above If the terms of supervised custody and probation are successfully completed, then the two years of state prison is eliminated. This proposal provides for the two year imposition of the state prison sentence if any violation of the supervised custody or probation occurs. Accordingly, the Office's position that Mr. Epstein agree to a resolution that includes jail time is satisfied by this proposal. It would immediately bring closure to a matter that has been pending for over two years, allows Mr. Epstein to commence with his sentence, and, most significantly, allow the victims to move forward with their lives. We are in process of scheduling a meeting with R. Alexander Acosta, United States Attorney, to further discuss this matter. Sincerely, cc. R. Alexander Acosta Gerald Lefcourt Roy Black caltikingi-MittiVVIARRA P413432 EFTA00230337

Page I of I EPSTEIN EYES SEX-RAP RELIEF Business- Bundle-A-Day GIVEAWAY Enter daily to win an incredible prize package for your office. There's a new winner every business day! Home October 9, 2007 -- LAWYERS for Jeffrey Epstein - the billionaire Manhattan investment manager who's agreed to plead guilty to soliciting underage prostitutes at his. Palm Beach mansion in exchange for just 18 months in the slammer - are mulling asking federal prosecutors to drop their demand that he register as a sex offender. In a letter drafted, but not sent, to U.S. Attorney Alexander Costa and obtained by Page Six, Epstein's lawyer. Gerald Lefcourt, writes, "Doing so will have a profound impact (on Epstein) both immediately and forever after. Not only will he be restricted to a wholly inappropriate penal facility, but he will be required for the rest of his life to account for his whereabouts." Epstein, a former business partner of Daily News owner Mort Zuckerman, pleaded guilty to a state charge in exchange for the feds' dropping their probe into possible federal criminal violations. Lefcourt argues that only the feds have demanded that Epstein register. "despite the fact that the state was of the view that Mr. Epstein's conduct did not warrant registration." A rep for Epstein had no comment. NEW YORK POST is a registered trademark of NYP Holdings. Inc. NYPOST.COM. NYPOSTONLINE.COK and NEWYORKPOST.COM are trademarks of NYP Holdings. Inc. Copyright 2008 NYP Holdings. Inc. Al rights reserved. Case No. 08-80736-CV-MARRA P-013433 http://www.nypost.com/php/pfriendly/print.php?url=http://www.nypost.com/seven/1009200... 6/3/2008 EFTA00230338

IN RE: INVESTIGATION OF JEFFREY EPSTEIN NON-PROSECUTION AGREEMENT IT APPEARING that the City of Palm Beach Police Department and the State Attorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey Epstein (hereinafter "Epstein"); IT APPEARING that the State Attorney's Office has charged Epstein by indictment with solicitation of prostitution, in violation of Florida Statutes Section 796.07; IT APPEARING that the United States Attorney's Office and the Federal Bureau of Investigation have conducted their own investigation into Epstein's background and any offenses that may have been committed by Epstein against the United States from in or around 2001 through in or around September 2007, including: (I) knowingly and willfully conspiring with others known and unknown to commit an offense against the United States, that is, to use a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution, in violation of Title I8, United States Code, Section 2422(b); all in violation of Title 18, United States Code, Section 371; (2) knowingly and willfully conspiring with others known and unknown to travel in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18, United States Code, Section 2423(b); all in violation of Title IS, United States Code, Section 2423(e); (3) using a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(6) and 2; (4) traveling in interstate commerce for the purpose of engaging in illicit sexual conduct, as defused in 18 U.S.C. § 2423(t), with minor females; in violation Page I of 7 Case No. 08-80736-CV-MARRA P-013434 EFTA00230339

of Title 18, United States Code, Section 2423(b); and (5) knowingly, in and affecting interstate and foreign commerce, recruiting, enticing, and obtaining by any means a person, knowing that the person had not attained the age of 18 years and would be caused to engage in a commercial sex act as defined in 18 U.S.C. § 1591(cX I); in violation of Title 18, United States Code, Sections 1591(a)(I) and 2; and IT APPEARING that Epstein seeks to resolve globally his state and federal criminal liability and Epstein understands and acknowledges that, in exchange for the benefits provided by this agreement, he agrees to comply with its terms, including undertaking certain actions with the State Attorney's Office; IT APPEARING, after an investigation of the offenses and Epstein's background by both State and Federal law enforcement agencies, and after due consultation with the State Attorney's Office, that the interests of the United States, the State of Florida, and the Defendant will be served by the following procedure; THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the following conditions and the requirements of this Agreement set forth below. If the United States Attorney should determine, based on reliable evidence, that, during the period of the Agreement, Epstein willfully violated any of the conditions of this Agreement, then the United States Attorney may, within ninety (90) days following the expiration of the term of home confinement discussed below, provide Epstein with timely notice specifying the condition(s) of the Agreement that he has violated, and shall initiate its prosecution on any offense within sixty (60) days' of giving notice of the violation. Any notice provided to Epstein pursuant to this paragraph shall be provided within 60 days of the United States learning of facts which may provide a basis fora determination of a breach of the Agreement. After timely fulfilling all the terms and conditions of the Agreement, no prosecution for the offenses set out on pages I and 2 of this Agreement, nor any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office, nor any offenses that arose from the Federal Grand Jury investigation will be instituted in this District, and the charges against Epstein if any, will be dismissed. Pagc 2 of 7 Case No. 08-80736-CV-MARRA P-013435 EFTA00230340

Terms of the Agreement: I. Epstein shall plead guilty (not nob contendere) to the Indictment as currently pending against him in the 15th Judicial Circuit in and for Palm Beach County (Case No. 2006-cf-009495AJOCCMB) charging one (I) count of solicitation of prostitution, in violation of Fl. Stat. § 796.07. In addition, Epstein shall plead guilty to an Information filed by the State Attorney's Office charging Epstein with an offense that requires him to register as a sex offender, that is, the solicitation of minors to engage in prostitution, in violation of Florida Statutes Section 796.03; 2. Epstein shall make a binding recommendation that the Court impose a thirty (30) month sentence to be divided as follows: (a) (b) Epstein shall be sentenced to consecutive terms of twelve (12) months and six (6) months in county jail for all charges, without any opportunity for withholding adjudication or sentencing, and without probation or community control in lieu of imprisonment; and Epstein shall be sentenced to a term of twelve (12) months of community control consecutive to his two terms in county jail as described in Term 2(a), supra. 3. This agreement is contingent upon a Judge of the 15th Judicial Circuit accepting and executing the sentence agreed upon between the State Attorney's Office and Epstein, the details of which are set forth in this agreement. 4. The terms contained in paragraphs 1 and 2, supra, do not foreclose Epstein and the State Attorney's Office from agreeing to recommend any additional charge(s) or any additional term(s) of probation and/or incarceration. 5. Epstein shall waive all challenges to the Information filed by the State Attorney's Office and shall waive the right to appeal his conviction and sentence, except a sentence that exceeds what is set forth in paragraph (2), supra. 6. Epstein shall provide to the U.S. Attorney's Office copies of all Page 3 of 7 Case No. 08-80736-CV-MARRA P-013436 EFTA00230341

proposed agreements with the State Attorney's Office prior to entering into those agreements. 7. The United States shall provide Epstein's attorneys with a list of individuals whom it has identified as victims, as defined in 18 U.S.C. § 2255, after Epstein has signed this agreement and been sentenced. Upon the execution of this agreement, the United States, in consultation with and subject to the good faith approval of Epstein's counsel, shall select an attorney representative for these persons, who shall be paid for by Epstein. Epstein's counsel may contact the identified individuals through that representative. 8. If any of the individuals referred to in paragraph (7), supra, elects to file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the United States District Court for the Southern District of Florida over his person and/or the subject matter, and Epstein waives his right to contest liability and also waives his right to contest damages up to an amount as agreed to between the identified individual and Epstein, so long as the identified individual elects to proceed exclusively under 18 U.S.C. § 2255, and agrees to waive any other claim for damages, whether pursuant to state, federal, or common law. Notwithstanding this waiver, as to those individuals whose names appear on the list provided by the United States, Epstein's signature on this agreement, his waivers and failures to contest liability and such damages in any suit are not to be construed as an admission of any criminal or civil liability. 9. Epstein's signature on this agreement also is not to be construed as an admission of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person whose name does not appear on the list provided by the United States. 10. Except as to those individuals who elect to proceed exclusively under 18 U.S.C. § 2255, as set forth in paragraph (8), supra, neither Epstein's signature on this agreement, nor its terms, nor any resulting waivers or settlements by Epstein are to be construed as admissions or evidence of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person, whether or not her name appears on the list provided by the United States. 11. Epstein shall use his best efforts to enter his guilty plea and be Page 4 of 7 Case No. 08-80736-CV-MARRA P-013437 EFTA00230342

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. 12. Epstein agrees that he will not be afforded any benefits with respect to gain time, other than the rights, opportunities, and benefits as any other inmate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration. 13. The parties anticipate that this agreement will not be made part of any public record. If the United States receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before making that disclosure. Epstein understands that the United States Attorney has no authority to require the State Attorney's Office to abide by any terms of this agreement. Epstein understands that it is his obligation to undertake discussions with the State Attorney's Office and to use his best efforts to ensure compliance with these procedures, which compliance will be mammy to satisfy the United States' interest. Epstein also understands that it is his obligation to use his best efforts to convince the Judge of the 15th Judicial Circuit to accept Epstein's binding recommendation regarding the sentence to be imposed, and understands that the failure to do so will be a breach of the agreement. In consideration of Epstein's agreement to plead guilty and to provide compensation in the manner described above, if Epstein successfully fulfills all of the terms and conditions of this agreement, the United States also agrees that it will not institute any ' • against any potential co-conspirators of Epstein, including but not limited or Further, upon execution of this agreement and a plea agreement with the State Attorney's Office, the federal Grand Jury investigation will be suspended, and all pending federal Grand Jury subpoenas will be held in abeyance unless and until the defendant violates any term of this agreement. The defendant likewise agrees to withdraw his pending motion to intervene and to quash certain grand jury subpoenas. Both parties agree to maintain their evidence, specifically evidence requested by or directly related to the grand jury subpoenas that have been issued, and including certain computer equipment, inviolate until all of the terms of this agreement have been satisfied. Upon the surrrscful completion of the terms of this agreement, all outstanding grand jury subpoenas shall be deemed withdrawn. Page 5 of 7 Case No. 08-80736-CV-MARRA P-013438 EFTA00230343

By signing this agreement, Epstein asserts and certifies that each of these terms is material to this agreement and is supported by independent consideration and that a breach of any one of these conditions allows the United States to elect to terminate the agreement and to investigate and prosecute Epstein and any other individual or entity for any and all federal offenses. By signing this agreement, Epstein asserts and certifies that he is aware of the fact that the Sixth Amendment to the Constitution of the United States provides that in all criminal prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court may dismiss an indictment, information, or complaint for unnecessary delay in presenting a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein hereby requests that the United States Attorney for the Southern District of Florida defer such prosecution. Epstein agrees and consents that any delay from the date of this Agreement to the date of initiation of prosecution, as provided for in the terms expressed herein, shall be deemed to be a necessary delay at his own request, and he hereby waives any defense to such prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the United States to a speedy trial or to bar the prosecution by reason of the running of the statute of limitations for a period of months equal to the period between the signing of this agreement and the breach of this agreement as to those offenses that were the subject of the grand jury's investigation. Epstein further asserts and certifies that he understands that the Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all felonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees and consents that, if a prosecution against him is instituted for any offense that was the subject of the grand jury's investigation, it may be by way of an Information signed and filed by the United States Attorney, and hereby waives his right to be indicted by a grand jury as to any such offense. / I / //I Page 6 of 7 Case No. 08-80736-CV-MARRA P-013439 EFTA00230344

By signing this agreement, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the conditions of this Non- Prosecution Agreement and agrees to comply with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: By: Dated: 77a9 Dated: Dated: A. ASSISTANT U.S. ATTORNEY GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 Case No. 08-80736-CV-MARRA P-013440 EFTA00230345

By signing this agreement, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the conditions of this Non- Prosecution Agreement and agrees to comply with them. IL ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: By: Dated: Dated: IL‘ti 0 7 Dated: xi ASSISTANT U.S. ATTORNEY JEFFREY EPSTEIN RA CO ESQ. WCI " UNSEL TO JEFF .Y EPSTEIN ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 Case No. 08-80736-CV-MARRA P-013441 EFTA00230346

By signing this agreement, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the conditions of this Non- Prosecution Agreement and agrees to comply with than. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: By: Dated: Dated: Dated: -LAY -L02— Asealigi lLiEy JEFFREY EPSTEIN GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 Case No. 08-80736-CV-MARRA P-013442 EFTA00230347

IN RE: INVESTIGATION OF JEFFREY EPSTEIN ADDENDUM TO THE NON-PROSECUTION AGREEMENT IT APPEARING that the parties seek to clarify certain provisions of page 4, paragraph 7 of the Non-Prosecution Agreement (hereinafter "paragraph 7"), that agreement is modified as follows: 7A. The United States has the right to assigm to an independent third-party the responsibility for consulting with and, subject to the good faith approval of Epstein's counsel, selecting the attorney representative for the individuals identified under the Agreement If the United States elects to assign this responsibility to an independent third-party, both the United States and Epstein retain the right to make good faith objections to the attorney representative suggested by the independent third-party prior to the final designation of the attorney representative. 713. The parties will jointly prepare a short written submission to the independent third-party regarding the role of the attorney representative and regarding Epstein's Agreement to pay such attorney representative his or her regular customary hourly rate for representing such victims subject to the provisions of paragraph C, infra. 7C. Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the attorney representative selected by the independent third party. This provision, however, shall not obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus, if after consideration of potential settlements, an attorney representative elects to file a contested lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested remedy, the paragraph 7 obligation of the Agreement to pay the costs of the attorney representative, as opposed to any statutory or other obligations to pay reasonable attorneys fees and costs such as those contained in s 2255 to bear the costs of the attorney representative, shall cease. Case No. 08-80736-CV-MARRA P-013443 EFTA00230348

By signing this Addendum, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby, states that he understands the clarifications to the Non- Prosecution Agreement and agrees to comply with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: /O/3 0 k 7 Dated: / 6/ 2' Dated: Dated: By: 1€ A. ASSISTANT U.S. ATTORNEY GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN ESQ. ATTORNEY FOR. JEFFREY EPSTEIN -416 54>stexw mucf4- Case No. 08-80736-CV-MARRA P-013444 EFTA00230349

By signing this Addendum, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the clarifications to the Non- Prosecution Agreement and agrees to comply with them. R. ALEXANDER AQOSTA UNITED STATES ATTORNEY Dated: /3 0%7 Dated: Dated: Dated: By: —16 / 10 44 FA OSA oi A. ASSISTANT U.S. ATTORNEY JEFFREY EPSTEIN BRAID LEI:CO RT ESQ. COUNSEL TO JEFFREY EPSTEIN ESQ. ATTORNEY FOR JEFFREY EPSTEIN Case No. 08-80736-CV-MARRA P-013445 EFTA00230350

By signing this Addendum, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the clarifications to the Non- Prosecution Agreement and agrees to comply with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: /D /3 0/0'7 Dated: Dated: Dated: )(yam By: 4 A. ASSISTANT U.S. ATTORNEY JEFFREY EPSTEIN GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY A ANCHEZ, ESQ ATTORNEY FOR JEFFREY EPSTEIN Case No. 08-80736-CV-MARRA P-013446 EFTA00230351

U.S. Department of Justice United Slates Attorney Southern District of Florida R ALEXANDER ACOSTA UNITEDSTATES ATTORNEY DELIVERY BY FACSIMILE Fowler White Burnett, PA 1395 Brickell Ave, I4th Floor Miami, FL 33131 Re: Jeffrey Epstein Dear Ms. Sanchez: 99N E 'Sweet Sham. FL i1111 (l05)90-000 Telephone (105)530.6144 - FOCJIII I lit December 19, 2007 I write to follow up on the December 14th meeting between defense counsel and the Epstein prosecutors, as well as our First Assistant, the Miami FBI Special Agent in Charge and myself.' I write to you because I am not certain who among the defense team is the appropriate recipient of this letter. I address issues raised by several members of the defense team, and would thus ask that you please provide a copy of this letter to all appropriate defense team members. First, I would like to address the Section 2255 issue.2 As I stated in my December 4th letter, my understanding is that the Non-Prosecution Agreement entered into between this Office and Mr. Epstein responds to Mr. Epstein's desire to reach a global resolution of his state and federal criminal liability. Under this Agreement, this District has agreed to defer prosecution for enumerated sections I Over the past two weeks, we have received several hundred pages of arguments and exhibits from defense counsel. This is not the forum to respond to the several items raised, and our silence should not be interpret as agreement; I would, however, like to address one issue. Your December I i th letter states that as a result of defense counsel objections to the appointment process, the USAO proposed an addendum to the Agreement to provide for die use of an independent third party selector. As I recall this matter, before I had any knowledge of defense counsel objections, I sun sponte proposed the Addendum to Mr. Lelkowitz al an October meeting in Palm Beach. I did this in an attempt to avoid what I foresaw would likely be a litigious selection process. It was only after I proposed this change that Mr. Letkowitz raised with me his enumerated concerns. 2 Section 2255 provides that: "falny person who, while a minor, was a victim of a violation of [enumerated sections of Title Si and who suffers personal injury as a result of such violation • .. may sue in any appropriate United States District Court and shall recover the actual damages such person sustains and the cost of the suit, including a reasonable attorney's fee." Case No. 08-80736-CV-MARRA P-013447 EFTA00230352

of Title 18 in favor of prosecution by the State of Florida, provided that the Mr. Epstein satisfies three general federal interests: (I) that Mr. Epstein plead guilty to a "registerable" state offense; (2) that this state plea include a binding recommendation fora sufficient term of imprisonment; and (3) that the Agreement not harm the interests of his victims. With this in mind, I have considered defense counsel arguments regarding the Section 2255 portions of the Agreement. As I previously observed, our intent has been to place the victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less. From our meeting, it appears that the defense agrees that this was the intent. During the course of negotiations that intent was reduced to writing in Paragraphs 7 and 8, which as I wrote previously, appear far from simple to understand. I would thus propose that we solve our disagreements over interpretations by saying precisely what we mean, in a simple fashion. I would replace Paragraphs 7 and 8 with the following language: "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." Second, I would like to address the issue of victim's rights pursuant to Section 3771. I understand that the defense objects to the victims being given notice of time and place of Mr. Epstein's state court sentencing hearing. I have reviewed the proposed victim notification letter and the statute. I would note that the United States provided the draft letter to defense as a courtesy. In addition, First Assistant United States Attorney Sloman already incorporated in the letter several edits that had been requested by defense counsel. I agree that Section 3771 applies to notice of proceedings and results of investigations of federal crimes as opposed to the state crime. We intend to provide victims with notice of the federal resolution, as required by law. We 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. Third, I would like to address the issue raised.regarding Florida Statute Section 796.03. At our meeting, Professor Dershowitz took the position that Mr. Epstein believes that his conduct does not satisfy the elements of this offense. His assertion raises for me substantial concerns. This Office will not, and cannot, be a party to an agreement in which Mr. Epstein pleads guilty to an offense that he believes he did not commit. We are considering how best to proceed. 2 Case No. 08-80736-CV-MARRA P-013448 EFTA00230353

Finally, I would like to address a more general point. Our Agreement was first signed on September 24th, 2007. Pursuant to paragraph I I , Mr. Epstein was to use his best efforts to enter his guilty plea and be sentenced no later than October 26, 2007. As outlined in correspondence between our prosecutors and defense counsel, this deadline came and went. Our prosecutors reiterated to defense counsel several times their concerns regarding delays, and in fact, asked me several weeks ago to declare the Agreement in breach because of those delays. I resisted that invitation. I share this fact because it is background to my frustration with what appears to be an I Id' hour appeal, weeks before the now scheduled January 4th plea date. This said, the issues raised are important and must be fully vetted irrespective of timeliness concerns. We hope to preserve the January 4'h date. I understand that defense counsel shares our desire not to move that appearance and will work with our office to expedite this process over the next several days. With this in mind, and in the event that defense counsel may wish to seek review of our determinations in Washington D.C., I spoke this past Monday with the Assistant Attorney General Fisher, to inform her of a possible appeal, to ask her to grant the potential request for review, and to in fact review this case in an expedited manner to attempt to preserve the January 4th plea date. I want to again reiterate that it is not the intention of this Office ever to force the hand of a defendant to enter into an agreement against his wishes. Your client has the right to proceed to trial, and he should do so if he believes that he did not commit the elements of the charged offense. I will respond to the pending issues shortly. In the interim, I would ask that you communicate your position with respect to the sections 2255 and 3371 issues as quickly as possible. Sincerely, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY cc: Alice Fisher, Assistant Attorney General First Assistant U.S. Attorney AUSA Case No. 08-80736-CV-MARRA P-013449 EFTA00230354

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No: 18 U.S.C. § 371 18 U.S.C. § 1591(a)(1) 18 U.S.C. § 1591(2)(2) 18 U.S.C. § 2422(b) 18 U.S.C. § 2423(e) 18 U.S.C. § 2423(d) 18 U.S.C. § 2423(b) UNITED STATES OF AMERICA vs. JEFFREY EPSTEIN, if and Defendants. INDICTMENT The Grand Jury charges that: BACKGROUND At all times relevant to this Indictment: I. Defendant JEFFREY EPSTEIN employed defendants , a/Ida ' and among other things, services as personal assistants. to perform, Case No. 08-80736-CV-MARRA P-013450 EFTA00230355

2. Defendant JEFFREY EPSTEIN. employed L.G. to perform, among other things, services as a personal assistant. Defendants JEFFREY EPSTEIN and if -.4' paid T. M., H.R., and A.F. to perform, among other things, recruiting services. 4. Defendant JEFFREY EPSTEIN owned a property located at 358 El Brillo Way, Palm Beach, Florida, in the Southern District of Florida (hereinafter referred to as "358 El Brillo Way"). 5. De fendantjEFFREY EPSTEIN owned a property located at 9 East 71st Street, New York, New York (hereinafter referred to as "the New York residence"). 6. Defendant JEFFREY EPSTEIN was the principal owner of JEGE, INC., a Delaware corporation. JEGE, INC.'s sole business activities related to the operation and ownership of a Boeing 727-31 aircraft bearing tail number N908JE. 7. Defendant JEFFREY EPSTEIN served as president, sole director, and sole shareholder of JEGE, INC., and had the power to direct all of its operations. 8. Defendant JEFFREY EPSTEIN was the principal owner of Hyperion Air, Inc., a Delaware corporation. Hyperion Air, Inc.'s sole business activities related to the operation and ownership of a Gulfstream G-1159B aircraft bearing tail number N909JE. 9. Defendant JEFFREY EPSTEIN served as president, sole director, and sole shareholder of Hyperion Air, Inc., and had the power to direct all of its operations. 2 Case No. 08-80736-CV-MARRA P-013451 EFTA00230356

10. Pursuant to Florida Statutes Section 794.05, a "person 24 years of age or older who engages in sexual activity with a person 16 or 17 years of age commits a felony of the second degree." For purposes of "this section, `sexual activity' means oral, anal, or vaginal penetration by, or union with, the sexual organ of another; however, sexual activity does not include an act done for a bona fide medical purpose." Florida Statutes Section 794.021 states that "ignorance of the age [of the victim] is no defense," and that neither "misrepresentation of age by [the victim I nor a bona fide belief that such person is over the specified age [shall] be a defense." 11. Pursuant to Florida Statutes Sections 800.04(5)(a) and 800.04(5)(cX2), an adult "who intentionally touches in a lewd or lascivious manner the breasts, genitals, genital area, or buttocks, or the clothing covering them, of a person less than 16 years of age, or forces or entices a person under 16 years of age to w touch the perpetrator, commits lewd or lascivious molestation," which is a felony of the second degree if the victim is 12 years of age or older but less than 16 years of age. 12. Pursuant to Florida Statutes Sections 800.04(6Xa) and 800.04(6Xb), an adult "who [i]ntentionally touches a person under 16 y of age in a lewd or lascivious manner or [s]olicits a person under 16 years of age to commit a lewd or lascivious act commits lewd or lascivious conduct," which is a felony of the second degree. 3 Case No. 08-80736-CV-MARRA P413452 EFTA00230357

13. Pursuant to Florida Statutes Sections 800.04(7)(a) and 800.04(7Xc), an adult "who: (I) [i]ntentionally masturbates; (2) [i]ntentionally exposes the genitals in a lewd or lascivious manner; or (3) [i]ntentionally commits any other sexual act that does not involve actual physical or sexual contact with the victim, including, but not limited to . . . the simulation 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. 14. Pursuant to Florida Statutes Section 800.04(2), "[n]either 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]." 16. Pursuant to 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 I icense. 4 Case No. 08-80736-CV-MARRA P-013453 EFTA00230358

18. During the period of her involvement with the Defendants, Jane Doe #4 attended Wellington High School and Palm Beach Central 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 involvement 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 I ligh School in Palm Beach County. 23. During the period of involvement with the Defendants, Jane Doe #10 attended Lake Worth High School in Palm Beach County. 24. 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. 5 Case No. 08-80736-CV-MARRA P-013454 EFTA00230359

COUNT 1 (Conspiracy: 18 U.S.C. § 371) 26. Paragraphs I through 25 of this Indictment arc re-alleged and incorporated by reference 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, PRIMPV PIKTPINI a/k/a " and 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 interstate dr foisteign commerce to knowingly persuade, induce, and entice individuals who had not attained the age of 18 years to engage in prostitution, in violation of Title 18, United States Code, Section 2422(b). 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 York 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. 6 Case No. 08-80736-CV-MARRA P-013455 EFTA00230360

Manner and Means 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 a/k/a 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) It was further a part of the conspiracy that Defendants JEFFREY EPSTEIN, and a/k/a and other participants would make payments to, or cause payments to be made to, minor females in exchanggifor engaging in lewd conduct. EPSTEIN, (c) It was further a part of the conspiracy that Defendants JEFFREY a/k/a 44j ' and other participants would ask females to recruit other minor females to engage in lewd conduct with Defendant JEFFREY EPSTEIN. EPSTEIN, , (d) It was further a part of the conspiracy that Defendants JEFFREY a/k/a ' and other participants would make payments to, or cause payments to be made to, the recruiters for 7 Case No. 08-80736-CV-MARRA P-013456 EFTA00230361

bringing additional minor females to 358 El Brillo Way and the New York residence to engage in lewd conduct with Defendant JEFFREY EPSTEIN. (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 satisfy Defendant 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: Jane Does #1 and #2 (1) In or around the beginning of 2001, Defendant JEFFREY EPSTEIN engaged in sexual activity with lane Doe # I, 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 Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (3) In or around 2001, DefendantJEFFREY 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 pinch his nipples while he masturbated. 8 Case No. 08-80736-CV-MARRA P-013457 EFTA00230362

(5) In or around 2001, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe #2. (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 358 El 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 then a fourteen-year-old girl, for allowing an unidentified female to perform oral sex on Jane Doe #2 in EPSTEIN's presence. (9) On or about Mitich 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 2003, Defendant JEFFREY EPSTEIN asked Jane Doe #2 if she had any younger friends who woup, be interested in engaging in similar re-4 activities with him. (11) In or around 2003, Defendant of Jane Doe #2, who was then a sixteen-year-old girl. 9 took nude photographs Case No. 08-80736-CV-MARRA P-013458 EFTA00230363

(12) In or around 2003, Defendant nade a payment of $500 to Jane Doe #2 in exchange for posing for nude photographs. (13) In or around 2003, Defendant al told Jane Doe #2 that Defendant JEFFREY EPSTEIN had asked KELLEN to take nude photographs of Jane Doe #2. (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) In or around 2003, Defendan 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 May 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. 10 Case No. 08-80736-CV-MARRA P-013459 EFTA00230364

(20) In or around 2003, Defendant JEFFREY 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. (22) On or about October 30, 2004, Defendant laced a telephone call to a telephone used by Jane Doe #3. (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 seventeen-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 2004, DefendaneJEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doc #3, who was then a sixteen- or seventeen-year-old girl. 11 71'1 Case No. 08-80736-CV-MARRA P-013460 EFTA00230365

(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 message for Defendant JEFFREY EPSTEIN's review regarding a telephone call received from Jane Doe #3 that read: "I have a female for him." (30) On or about January 14, 2005, Defendan placed a telephone call to a telephone used by Jane Doe #3. (31) On or about January 29, 2005, one of Defendant JEFFREY EPSTEIN's 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." / Jane Does #4, #5. and #6 (32) In or around 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 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #4 about her age, and Jane Doe #4 responded with her true age. 12 Case No. 08-80736-CV-MARRA P-013461 EFTA00230366

(34) In or around the first half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #4, who was then a seventeen-year-old-girl, afid 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 seventeen-year-old girl, to play with his nipples. (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. (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. (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 Doe #6 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. 13 Case No. 08-80736-CV-MARRA P-013462 EFTA00230367

(42) In or around the first half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane 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. (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 (46) In or around July 2004, Defendant JEFFREY EPSTEIN led T.M., who was then a fifteen-year-old gitlt and Jane Doe #7, who was then a sixteen-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 to a telephone used by T.M. 14 Case No. 08-80736-CV-MARRA P-013463 EFTA00230368

(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 seventeen-year-old girl. (51) In or around July 2004, Defendant JEFFREY EPSTEIN paid approximately $200 to Jane Doe #8. (52) Ip pi. 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, Defendant told Jane Doe #8 that Defendant JEFFREY EPSTEIN would pay Jane Doe #8 if she returned with a friend. (54) On or about July 15, 2004, Defendant more telephone calls to a telephone used by Jane Doe #7. (55) On or about July 15, 2004, Defendant telephone call to a telephone used by Jane Doe #8. (56) On or about July 15, 2004,pDefendant telephone call to a telephone used by T.M. placed one or placed a placed a (57) On or about July 16, 2004, Defendant placed one or more telephone calls to a telephone used by Jane Doe #7. 15 Case No. 08-80736-CV-MARRA P-013464 EFTA00230369

(58) On or about July 16, 2004, Defendant placed a telephone call to a telephone used by T.M. ¶3 (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] can come tomorrow any time or [T.M.] alone". (60) In or around July 2004, 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. (62) In or around July 2004, Defendant JEFFREY EPSTEIN stroked the vagina of Jane Doe #7, who was then a sixteen-year-old girl. (63) In or around July 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #7. (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 home, 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. 16 Case No. 08-80736-CV-MARRA P-013465 EFTA00230370

Jane Does #9 and #10 (66) On or about July 15, 2004, Defendant SARAH KELLEN placed one or more telephone calls to a telephone used by Jane Doe #9. (67) On or about July 16, 2004, Defendan 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 placed a telephone call to a telephone used by Jane Doe #9. (69) On or 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 July 2004, 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. (74) On or about July 22, 2004, Defendant telephone call to a telephone used by Jane Doe #10. 17 placed a Case No. 08-80736-CV-MARRA P-013466 EFTA00230371

(75) In or around the last hal f of 2004, Defendants JEFFREY EPSTEIN and NADIA MARCINKOVA engaged in oral sex and sexual intercourse in the presence 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 hal f of 2004, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe #9. (78) In or 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 hal f of 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #10. (80) On or about November 28, 2004, Defendant JEFFREY EPSTEIN arranged for one of his employees to provide an envelope filled with cash to Jane Doe #9. r (81) On or about December 4, 20 fendant 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 @ 7:30". (82) On or about December 29, 2004, Defendant placed "TT a telephone call to a telephone used by Jane Doe #9. 18 Case No. 08-80736-CV-MARRA P-013467 EFTA00230372

(83) On or about December 30, 2004, Defendants JEFFREY EPSTEIN and caused the purchase of Broadway tickets as an eighteenth birthday gift for 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 fondled the breasts of Jane Doe #10, who was then a seventeen-year-old girl. (86) On or about January 14, 2005, Defendant or more telephone calls to a telephone used by Jane Doe #10. (87) On or about January 27, 2005, Defendant placed one , a/k/a placed one or more telephone calls to a telephone used by Janc Doe #10. (88) On or about January 28, 2005, Defendanil laced 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 telephone used by Jane Doe #10. (90) In or around February 2005, Defendant JEFFREY EPSTEIN caused a payment of $200 to be made to Jane Doe #9 for recruiting Jane Doe #I6 to travel to 358 El Brillo Way. 19 Case No. 08-80736-CV-MARRA P-013468 EFTA00230373

Jane Doe #11 (91) In or around 2004, Defendant JEFFREY EPSTEIN told Jane Doe #1I St lie would pay her to find and bring him more girls. 4I (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 wou e getting more girls. (94) &Tar about April 5, 2005, one of Defendant JEFFREY EPSTEIN's employees prepared 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, [unideped 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]." (95) On or about June 22, 2005, Defendant 1placed a telephone call to a telephone used by Jane poe #11. Jane Does #12 and #13 (96) On or about August 2, 2004, an employee of Defendant JEFFREY EPSTEIN prepared a written telephone 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 [Jane Doe #18] too". 20 Case No. 08-80736-CV-MARRA P-013469 EFTA00230374

(97) On or about August 21, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #13. (98) In or around the last half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence ofJane Doe #I2, 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) In or around the last half of 2004, Defendant JEFFREY EPSTEIN attempted to place a massaging device on the vagina ofJane 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 thdast half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #I2, 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 ofJane Doe #I3, who was then a seventeen-year-old girl. 21 Case No. 08-80736-CV-MARRA P-013470 EFTA00230375

(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. (107) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #I3. (108) In or around the last half of 2004, Defendant JEFFREY EPSTEIN digitally penetrated Jane Doe #I3, who was then a seventeen-year-old girl. (109) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #13, who 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 yearitbld. (111) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #13 to bring her friends to 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 Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (113) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #14 to provide her telephone number. 22 Case No. 08-80736-CV-MARRA P-013471 EFTA00230376

(114) In or around the last half of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #I4, who was then a seventeen-year-old girl, to pinch his nipples. (115) In or around the last half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #I4, who was then a seventeen-year old girl. (116) In or around the last hal f 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 EPSTEIN 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 fol:Eer eighteenth birthday and acknowledged that she had not yet turned eighteen. (119) On or about December 23, 2004, Defendant JEFFREY EPSTEIN caused a Western Union wire transfer order to be sent to Jane Doe #I4. (120) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doe #I4, 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 #I4, who was then a seventeen-year-old girl. 23 Case No. 08-80736-CV-MARRA P-013472 EFTA00230377

(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. (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 #I4. (125) On or about January 9, 2005, Defendant "Adriana Mueibika," placed a telephone call to a telephone used by Jane Doe #I4. a/k/a (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". t< (127) On or about January 26, 2005, Defendant , a/k/a placed a telephone 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 , a/k/a " placed a telephone call to a telephone used by Jane Doe #I4. (130) On or about March 21, 2005, Defendant a/k/a ' placed a telephone calls to a telephone used by Jane Doe #14. 24 Case No. 08-80736-CV-MARRA P-013473 EFTA00230378

(131) On or about March 29, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #14. Jane Doe #15 (132) On or about December 6, 2004, Defendant 4 placed a telephone call to a telephone used by Jane Doe #15. (133) On or about December 14, 2004, Defendant' " " """ 1- placed a telephone call to a telephone used by Jane Doe #15. (134) In Cir 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 #I5, whoWas 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 #15.1 it (138) On or about January 7, 2005, Defendant #15. a/lc/a " placed a telephone call to a telephone used by Jane Doe 25 Case No. 08-80736-CV-MARRA P-013474 EFTA00230379

(139) On or about February 4, 2005, Defendant telephone call to a telephone used by Jane Doe #15. (140) On or about February 10, 2005, Defendant a telephone call to a telephone used by Jane Doe #15. (141) On or about February 21, 2005, Defendant a telephone call to a telephone used by Jane Doe #15. (142) On or about February 24, 2005, Defendan T;) a telephone call 'o a telephone used by Jane Doe #15. (143) On or about March 17, 2005, Defendant telephone call to a telephone used by Jane Doe #I5. (144) On or about March 30, 2005, Defendant telephone call to a telephone used by Jane Doe #15. (145) On or about March 31, 2005, Defendant telephone call to a telephone used by Jane Doe #15. (146) On or about March 31, 2005, Defendant placed a placed placed placed placed a placed a placed a a/k/a 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 Defendant JEFFREY 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 #I5 with a gift of Victoria's Secret lingerie for her eighteenth birthday. A 26 Case No. 08-80736-CV-MARRA P-013475 EFTA00230380

Jane Does #16 & #17 (149) In or around February 2005, Defendant JEFFREY EPSTEIN Masturbated in the presence of Jane Doe #16, who was then a seventeen-year-old girl. (150) In or around the first quarter of 2005, Defendants JEFFREY EPSTEIN and caused Jane Doe #16 to place a telephone call to Jane Doe #I7 to ask her to travel to 358 El Brillo Way. (151) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN -4 :1, caused a paymentto be made to Jane Doe #I6 for recruiting Jane Doe #I7 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 EPSTEM instructed Jane Doe #17, who was then a sixteen-year-old girl, to remove all of her clothing. (154) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doe #I7, 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 #I7, who was then a sixteen-year-old girl. 27 Case No. 08-80736-CV-MARRA P-013476 EFTA00230381

(156) In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doe #I6, who was then a seventeen-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 engaged in 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 April 1 1, 2005, Defendant , a/k/a " placed a telephone call to a telephone used by Jane Doe #I6. placed a (161) On or about April 11, 2005, Defendant telephone call to a telephone used by Jane Doe #16. (162) On or about April 11, 2001, Defendant left a message for Defendant JEFFREY EPSTEIN stating: "[Jane 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 Case No. 08-80736-CV-MARRA P-013477 EFTA00230382

(164) On or about June 30, 2005, Defendant telephone call to a telephone used by Jane Doe #16. (165) On or about July 2, 2005, Defendant telephone call to a telephone used by Jane Doe #16. (166) On or about July 22, 2005, Defendant telephone call to a telephone used by Jane Doe #16. (167) On or about August 18, 2005, Defendant telephone call to a telephone used by Jane Doe #16. (168) On or about August 19, 2005, Defendant placed a placed a placed a placed a a/k/a 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 September 3, 2005, Defendant• 44 a/k/a placed a telephone call to a telephone used by Jane Doe #I6. (171) On or about September 18, 2005, Defendant a telephone call to a telephone used by Jane Doe #16. (172) On or about September 19, 2005, Defendant text message to a telephone used by Jane Doe #I6. (173) On or about September 29, 2005, Defendant a telephone call to a telephone used by Jane Doe #16. 29 placed sent a blaced Case No. 08-80736-CV-MARRA P-0 13478 EFTA00230383

(174) On or about September 30, 2005, Defendan 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 laced a telephone call to a telephone used by Jane Doe #16. (177) (icor about October 3, 2005, Defendan placed a telephone call to a telephone used by Jane Doe #16. (178) On or about October 3, 2005, Defendant SARAH KELLEN left a telephone message for Defendant JEFFREY EPSTEIN stating: "[Jane Doe #16] will be 'A hour late". A (179) In or around the first 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 $350.00 to JCe 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 Victoria's Secret lingerie to Jane Doe #16 for her eighteenth birthday. 30 Case No. 08-80736-CV-MARRA P-013479 EFTA00230384

Jane Does #I8 and #19 (182) In or around the last half of 2003, Jane Doe #I8 was approached by A.F. and was asked whether she would be willing to provide a massage to Defendant JEFFREY EPSTEIN in exchange for $200. (183) In or around the last hal f 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 to• a 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 telephorybsed by Jane Doe #18. (187) In or around the last half of 2003, Defendant JEFFREY EPSTEIN digitally penetrated Jane Doe #I8, who was then a seventeen-year-old-girl. (188) In or around the last hal f 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, Dtfendant JEFFREY EPSTEIN asked Jane Doe #19, who was then a seventeen-year-old girl, to leave when she refused to remove her shirt. rir 31 Case No. 08-80736-CV-MARRA P-013480 EFTA00230385

(190) On or about March 5, 2004, Defendant JEFFREY EPSTEIN verbally reprimanded Jane Doe #18 for bringing Jane Doe #I9 to 358 El Brillo Way when she was not willing to undress for him. The Defendants' Travel (191) On or about March 11, 2004, Defendants JEFFREY EPSTEIN, and aveled from Teterboro, New Jersey, to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (192) On or about May 1, 2004, Defendants JEFFREY EPSTEIN, SARAH KELLEN, anti traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (193) On or about Mai 14, 2004, Defendants JEFFREY EPSTEIN, SARAH 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 I Iyperion 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 Case No. 08-80736-CV-MARRA P-013481 EFTA00230386

(196) On or about July 4, 2004, Defendants JEFFREY EPSTEIN, =I an raveled from Aspen, Colorado to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (197) On or about July 16, 2004, Defendants JEFFREY EPSTEIN, , and 1 raveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (198) LC about July 22, 2004, Defendants JEFFREY EPSTEIN, SARAH KELLEN, an cll raveled 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 traveled 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 1 'traveled from Ecuador to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (201) On or about October 2, 2004, Defendants JEFFREY EPSTEIN, and Iraveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, 33. Case No. 08-80736-CV-MARRA P-013482 EFTA00230387

(202) On or about October 29, 2004, Defendants JEFFREY EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach County, 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, a/k/a "i ' and a. 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 a/k/a " " traveled from New York, New York to Palm Beach County, 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, 2004, Defendants JEFFREY EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. 34 Case No. 08-80736-CV-MARRA P-013483 EFTA00230388

(208) On or about January 1, 2005, Defendants JEFFREY EPSTEIN, and raveled from Anguilla, British West Indies tc) Isa,lm 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) or about January 14, 2005, Defendants JEFFREY EPSTEIN, SARAH KELLEN, , a/k/a ' and lila 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, a/k/a " and— traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. a On or about February 3, 2005, Defendants JEFFREY EPSTEIN, , and 1 A traveled from Columbus, Ohio, to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC. (213) On or about February 10, 2005, Defendants JEFFREY EPSTEIN, a/k/a 35 " and MI Case No. 08-80736-CV-MARRA P-013484 EFTA00230389

traveled from New York, New York to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC. (214) On or about February 21, 2005, Defendants JEFFREY EPSTEIN, , and raveled 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, SARAH KEISEN, and raveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (216) On or about March 4, 2005, Defendants JEFFREY EPSTEIN, ADRIANA ROSS, a/k/a "Adriitna Mucinska," 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 March 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. 36 Case No. 08-80736-CV-MARRA P-013485 EFTA00230390

(219) On or about May 19, 2005, Defendants JEFFREY EPSTEIN, and a/k/a " traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (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) (in or about July 22, 2005, Defendants JEFFREY EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (222) On or about August 18, 2005, Defendants JEFFREY EPSTEIN, a/k/a and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (223) On or about September 3, 2005, Defendants JEFFREY EPSTEIN and , aAda" ' 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 , a/k/a " I," traveled from rr-, 37 Case No. 08-80736-CV-MARRA P-013486 EFTA00230391

Westchester County, New York to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. L b (225) On or about September 29, 2005, Defendants JEFFREY EPSTEIN, a/k/a `1 and I aveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. All in violation of Title 18, United States Code, Section 371. COUNTS 2 THROUGH 10 (Sex Trafficking: 18 U.S.C. § 159100(1)) 31. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 32. On or about the dates enumerated as to each count listed below, the exact dates A being unknown to the Grand Jury, in$alm 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 would 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 112 JEFFREY EPSTEIN SARAH KELLEN 38 Case No. 08-80736-CV-MARRA P-013487 EFTA00230392

Count Date(s) Minor Involved Defendant(s) 3 January 2004 through July 2004 Jane Doe #4 JEFFREY EPSTEIN 4 July 2004 through December 29, 2004 Jane Doe #9 JEFFREY EPSTEIN 5 July 2004 through January 31, 2005 Jane Doe #10 JEFFREY EPSTEIN 6 Mid-2004 through April 22, 2005 Jane Doe #12 J.ill 7 August 2004 through May 27, 2005 Jane Doe #13 JEFFREY EPSTEIN 8 November 2004 through March 2005 Jane Doe #14 JEFFREY EPSTEIN a/k/111111' 9 December 2004 through June 5, 2005 Jane Doe #15 JEFFREY EPSTEIN I i) February 2005 through first week of October 2005 Jane Doe #16 JEFFREY EPSTEIN All in violation of Title 18, United States Code, Sections 1591(a)(1) and 2. 39 Case No. 08-80736-CV-MARRA P-013488 EFTA00230393

COUNT 11 (Sex Trafficking: 18 U.S.C. § 1591(a)(2)) 33. Paragraphs I through 25 of this Indictment are re-alleged and incorporated by reference as 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, a/lcia " and 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(a)(1), thitt is, the recruiting, enticing, providing, and obtaining by any means a person, in or affecting interstate commerce, 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(b)(2), and 2. COUNT F2 (Enticement of a Minor: 18 U.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 Case No. 08-80736-CV-MARRA P-013489 EFTA00230394

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 Florida, "nd elsewhere, 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 and in 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(7Xa); in violation of Title 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 25 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 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 did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #7, who was a person who had not attained the age of 41 Case No. 08-80736-CV-MARRA P-013490 EFTA00230395

18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 14 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 39. Paragraphs I through 25 of this Indictment are re-alleged and incorporated by reference 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, JEFFREY EPSTEIN and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doc #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 of a Minor: 18 U.S.C. § 2422(b)) 41. Paragraphs 1 through 25 of this Indi ent 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, 42 Case No. 08-80736-CV-MARRA P-013491 EFTA00230396

JEFFREY EPSTEIN and S 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 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. 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 in or around July 2004 through on or about January 31, 2005, 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 did use a facility or means of interstate comme that is, the telephone, to knowingly persuade, induce and entice Jane Doe #10, 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. 43 Case No. 08-80736-CV-MARRA P-013492 EFTA00230397

COUNT 17 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 45. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as 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, 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. COUNT 18 (Enticement of a Minor: 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 thrdugh on or about May 27, 2005, 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 44 Case No. 08-80736-CV-MARRA P-013493 EFTA00230398

did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #I3, 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(h) and 2. COUNT 19 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 49. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as though fftet forth herein. 50. From in or around November 2004 through in or around March 2005, 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 a/k/a " did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #14, 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 violatifof Florida Statutes Section 794.05; in violation of Title 18, United States Code, Sections 2422(b) and 2. 45 Case No. 08-80736-CV-MARRA P-013494 EFTA00230399

COUNT 20 (Enticement of a Minor: 18 U.S.C. § 2422(6)) 51. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as 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, JEFFREY EPSTEIN, and ailcia " SS did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #15, 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 21 (Enticement of a Minor: 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 the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, 46 Case No. 08-80736-CV-MARRA P-013495 EFTA00230400

JEFFREY EPSTEIN, ; • ), did use lea Acility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce or entice Jane Doe #I6, 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, United States Code, Sections 2422(b) and 2. COUNT 22 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 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 February 2005 through in or around April 2005, 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, ARII a/k/a " , did use a facility or means of interstate commerce, that is, 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. r 47 Case No. 08-80736-CV-MARRA P-013496 EFTA00230401

COUNT 23 (Enticement of a Minor: 18 U.S.C. § 2422(6)) 57. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as though 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, \. JEFFREY EPSTEIN, and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #I8, 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 (Conspiracy to Travel: 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 thro in or around October 2005, the exact dates being unknown to the Grand Jury, the Defendants, JEFFREY EPSTEIN, , a/k/a cind 48 Case No. 08-80736-CV-MARRA P-013497 EFTA00230402

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 U.S.C. § 2423(f), with another person, in violation of Title 18, United States j Code, Section 2423(b); all in violation of Title 18, United States Code, Section 2423(e). COUNT 25 (Facilitation of Unlawful Travel of Another: 18 U.S.C. § 2423(d)) 61. Paragraphs I through 25 of this Indictment are re-alleged and incorporated by reference as though full$ 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, the Defendant, 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 interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f); in violation of Title 18, United States Code, Section 2423(d). COUNTS 26 THROUGH 29 (Travel to Engage in Illicit Sexual Conduct: 18 U.S.C. § 2423(b)) 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 as to each count listed below, from a place outside the Southern District of Florida to a place inside the Southern District of Florida, the 49 Case No. 08-80736-CV-MARRA P-013498 EFTA00230403

Defendant(s) listed below traveled in interstate commerce for the purpose of engaging in illicit 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: Defendant(s) Count Date(s) Minor(s) Involved 26 7/16/2004 Jane Doe #7 Jane Doe #8 Jane Doe 119 Jane Doe #10 JEFFREY EPSTEIN MN= 27 3/31/2005 Jane Doe #14 Jane Doe #15 Jane Doe #16 JEFFREY EPSTEIN 28 9/18/2005 Jane Doe #I6 JEFFREY EPSTEIN 29 9/29/05 Jane Doe it 16 JEFFREY EPSTEIN 11 . 111 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, S a/lc/a and shall forfeit to the United States any property, real or personal, which constitutes or is derived from proceeds traceable to the violation. 50 Case No. 08-80736-CV-MARRA P-013499 EFTA00230404

Pursuant to Title 28, United States Code, Section 2461; Title 18, United States Code, Section 981(a)(1)(C); and Title 21, United States Code, Section 853. If the property described above as being subject to forfeiture, as a result of any act or omission of the defendants, JEFFREY EPSTEIN, a/lc/a " and (1) cannot be located upon the exercise of due diligence; (2) has been transferred 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) has been commingled with other property which cannot be subdivided without difficulty; it is the intent of the United States, purtuant 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(aX I XC); and Title 21 United States Code, Section 853. FORFEITURE 2 Upon conviction of any of the violations alleged in Counts 12-29 of this indictment, the defendants, JEFFREY EPSTEIN, a/k/a al and all forfeit to the United States any property, real or personal, constituting or traceable to gross profits or other proceeds obtained from such 51 Case No. 08-80736-CV-MARRA P-013500 EFTA00230405

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, 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 side of an existing concrete 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 IS, United States Code, Section 2253. If any of the forfeitable property described in the forfeiture section of this indictment, as a result of any act or omission of the defendants JEFFREY EPSTEIN, a/k/a ' ," and (a) cannot be located upon the exercisegof due diligence; (b) has been transferred or sold to, or deposited with, a third person; (c) has been placed beyond the jurisdiction of the Court; (d) has been substantially diminished in value; or 52 Case No. 08-80736-CV-MARRA P-013501 EFTA00230406

(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 forfeiture of any other property of said defendant up to the value of the above forfeitable property. Pursuant to Title IS, United States Code, Section 2253. FORFEITURE 3 ei✓ t Upon conviction bf any of the violations alleged in Counts 2-11 of this indictment, the defendants, JEFFREY EPSTEIN, a/k/a '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 obtained, directly or indirectly, as a result of such violation, 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, 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 Book9, Page 9, Public Records of Palm Beach County, Florida, being bounded on the West by the A 53 Case No. 08-80736-CV-MARRA P-013502 EFTA00230407

West side of an existing concrete seawall and the northerly extension thereof as shown on the Adair & Brady, Inc., drawing IS-I298, 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 TRUE BILL. FOREPERSON R. ALEXANDER ACOSTA UNITED STATES ATTORNEY A. ASSISTANT UNITED STATES ATTORNEY 54 Case No. 08-80736-CV-MARRA P-013503 EFTA00230408

Case No. 08-80736-CV-141.11.5 P-013504 EFTA00230409

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• Case No. 08-80736-CV-MARRA P-01508 EFTA00230413