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08/16/2007 17:97 FAX 5618021787 USAO WPB FL : 007
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
INRE FEDERAL GRAND JURY SUBPOENA
OLY-65/2
ADDRESSED TO NES, LLC
CERTIFICATION REGARDING D
08/16/2007 17:07 FAX 5618021787 USAO WPB FL.- 4008.
4. I further certify that NES, LLC has no documents responsive to request number(s)
in Grand Jury Subpoena number 65/2. [Fill in or strike out as
ao
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
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
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 f
10.
11.
proposed agreements with the State Attorney’s Office prior to entering
into those agreements.
The United States shall provide Epstein’s attorneys with a list of
Pp
through that representat
JAY P. LEFKOWITZ, Eso.
DECEMBER 13, 2007
PAGE 4 OF 5
issue if it were raised during negotiations. As I stated, it was not, leading me to believe that it was
not a matter of concern to the defense. Si
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 chargi
ATTACHMENT TO GRAND JURY SUBPOENA OLY-85/1
ADDRESSED TO
PLEASE BRING THE FOLLOWING DOCUMENTS, ITEMS, AND INFORMATION WITH YOU
TO YOUR GRAND JURY APPEARANCE:
l. Any and.all notes, letters, cards, gif
JAY P. LEFKOWITZ, Eso.
DECEMBER 13, 2007
PAGE 2 OF 5
I informed you that I selected Mr. Ocariz because he was a friend and classmate of two people
whom I respected, and that I had never met or spoken
=AO110 (Rev. 04/07) Subpoena tn Testify Before Grand Jury = _. ; cee
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
TO:
po SUBPOENA TO TESTIFY.
BEFORE GRAND JURY
FGI 07-103 (WPB)-Tues. No
JUN-20-2007 11:19 FBI WEST PALM BEACH RA P.@5
ATTACHMENT A
SUBPOENA TO PAUL A. LAVERY
1. All computer equipment and electronic storage media removed from the
residence located at 358 E] Brillo Way,
“JUN-26-2807 11:19 FBI WEST PALM BEACH RA P.@3
ATTACHMENT A
SUBPOENA TO PAUL A. LAVERY
I, Al} computer equipment and electronic storage media removed from the
residence located at 358 El Brillo Way,
11/16/2008 16:31 FAX 5618021787 USAO WPB FL (003
LILLy ANN SANCHEZ, Esq.
NOVEMBER 16, 2006
PAGE 20F 3
5. Information and billing statements for any “fand lines,” cellular telephones,
Blackberry uni
. JUN-26~26@7 11:18 FRI WEST PALM BEACH RA P.@L
FU-448 (Kev. -2-¥/)
FBI FACSIMILE
COVER SHEET
PRECEDENCE CLASSIPICATION
LI immediate LJ Top Seeret Time Transmitted:
CI Priority LJ Secret Sender's I
~0929104. TXT
9 Q. Didn't Detective Recarey have to come to
10 your house to pick you up to get you to testify in front
11 of the Grand Jury?
12 A. Possibly, maybe because | didn't have a
13. ride.
10
14
12
13
14
15
16
17
18
19
20
21
22
23
24
25
—_
oO Oo ON OF OH FF WwW DN
~0929104. TXT
Q. Is that your testimony under oath?
A. Yes.
Q. Did you take your MySpace page down because
you thought
~0929104.TXT
56
1 has been marked for identification yet.
2 BY MR. TEIN:
3 0. i
4 MR. LEOPOLD: Hold on just a second. Just
5 so the record is clear --
6 MR. TEIN: I'm not speaking to you.
7 MR. LEQPO
———~
oO ~~ OM oO FF W PY
~0929104 . TXT
coincidence, was wearing your name tag?
A. Yes, sir.
Q. And just by coincidence, you were wearing
her name tag, correct?
A. Yes.
Q. Your testimony under
18
19
20
21
22
23
24
25
—_
oo Oo OA NN OD oO Fe WwW NY
~0929104. TXT
answer the question, because any of those
conversations involve her counsel.
MR. TEIN: Certify that.
MR. LEOPOLD: Please.
BY M
—
fr o™
2007-04-25 | ae
2
1 (Taped statement as follows:)
2 AGENT RICHARDS: This is Special Agent Jason
3 Richards with the FBI along with Special Agent
4 Nesbit Kirkendul and Assistant United
003/003
11/05/2007 11:27 FAX ; ; .
A1/05/707 MON 10:06 FAX 305 530 6440 EXECUTIVE OFFICE
NOVEMBER 5, 2007
PAGE 2 OF 2
=pstein had to begin his term of incarceration not later than January 4, 2008,
002/004
11/05/2007 11:27 FAX anceps p pean
11/05/07 MON 10:05 FAX $05 530 6440 EXECUTIVE OFFICE
United States Attorney
Southern District of Florida
99 NLD. 2" Street
Miami, FL §317452.2132
(305) 96
_ Jay P. LEFKOWITZz, Esq.
May 19, 2008
PAGE 2 OF 6
Background
_ The Agreement was the product of months of negotiations. Specifically, you requested and
received numerous meetings, at the highest l
JAY P. LEFKOWITZ, Esq.
May 19, 2008
PAGE 4 OF 6
B. Method of Compensation and Notification.
During this same time period, you and others, including the former Solicitor General of the
United States
oo™
JAY P. LEFKOWITZ, ESQ.
May 19, 2008
PAGE 3 OF 6
of the guilty plea and sentence no later than October 26, 2007; and (5) the start of the above-
mentioned sentence no later than January 4, 2008.
ALLEN GUTHRIE MCHUGH & THOMAS, PLLC
Mr. John Roth
June 19, 2008
Page 11
aid tell him you’re 18 because if you’re not, he won’t let you in his house.
So I said I was 18. As I was giving him a massage
U.S. Department of Justice
United States Attorney
Southern District of Florida
First Assistant U.S. Attorney 7 99 N.E. 4 Street
Miami, FL 33132
(305) 961-9100
DELIVERY BY FACSIMILE May 19, 2008
Jay
a
ALLEN GUTHRIE MCHUGH & THOMAS, PLLC
Mr. John Roth
June 19, 2008
Page 10
of all of the facts in order to have a defense in the event of a subsequent prosecution.”). Thus, the
facts preclude relian
ALLEN GUTHRIE MCHUGH & THOMAS, PLLC
Mr. John Roth
June 19, 2008
Page 2
Act. Later, while at the Department of Justice, I co-authored the Department’s Federal Child
Support Prosecution Handbook.
My
KIRKLAND & ELLIS LLP
describes the additional charge to which Mr. Epstein is required to plead guilty
under the Deferred Prosecution Agreement as “procurement of minors to engage
in prostitution” or
KIRKLAND & ELLIS LLP
Agreement to Defer Prosecution to the State, an agreement without precedent and fraught
with substantial practical and legal hurdles to its implementation.
6. THE SDFL DID NOT D
KIRKLAND & ELLIS LLP
same individual had previously fled the home of another neighbor after entering that
house uninvited, when, looking for the bedroom of their 17-year-old daughter, he
mistakenly en
21s
28.
oe.
30.
31.
Bes
33.
34.
KIRKLAND & ELLIS LLP
“[t]here is too great a chance of an appearance of impropriety.” See Tab 28, September
26, 2007 Email from M. Villafana to J. Lefkowitz.
T
12.
13.
14,
15.
16.
KIRKLAND & ELLIS LLP
In August 2007, in a clear attempt to coerce a state settlement, Ms. Villafana threatened
to broaden the investigation to include a money laundering viol
KIRKLAND & ELLIS LLP
SUMMARY OF MISCONDUCT ISSUES IN THE MATTER OF JEFFREY E. EPSTEIN
The manner in
which federal prosecutors have pursued the allegations against Mr. Epstein is highly irregular
and
KIRKLAND & ELLIS LLP
Mr. Epstein is Required to Ag ree to Civil Liability In Order to Avoid a Federal Indictment
10.
11,
On July 31, 2007, during negotiations over a possible federal plea agreemen
KIRKLAND & ELLIS LLP
Most important, however, is that the extraordinary nature of this misconduct, so unusual
in ordinary federal prosecutions, raises the gravest of concerns about why prosecutors wo
KIRKLAND & ELLIS LLP
MMMM. at 6, 8, 22, 45; Tab 7, MEEr. 13; Tab SI Tr. at 8; Tab 9, MN Tr. at 5; and
Tab 10, QJ Tr. at 14-15 (excerpts from these transcripts are included below). Furthermore,
the wo
KIRKLAND & ELLIS LLP
John Roth, Esq.
June 19, 2008
Page 2
As you are likely aware, the Department’s prior review of this matter was incomplete
and, by its own admission, not “de novo.” See Tab 38, M
KIRKLAND & ELLIS LLP
John Roth, Esq.
June 19, 2008
Page 3
prosecution as a result of Mr. Epstein's having entered into the September 24, 2007 Non
Prosecution Agreement with the USAO.
Notably, the N
KIRKLAND & ELLIS LLP
John Roth, Esq.
June 19, 2008
Page 2
As you are likely aware, the Department’s prior review of this matter was incomplete
and, by its own admission, not “de novo.” See Tab 38, M
KIRKLAND & ELLIS LLP
John Roth, Esq.
June 19, 2008
Page 3
prosecution as a result of Mr. Epstein's having entered into the September 24, 2007 Non
Prosecution Agreement with the USAO.
Notably, the N
While “Jane Doe #3” is unidentified in this week’s court filing, her story appears to track with
that of a woman who sued Epstein in 2009 and settled with him later that year. She apparently
granted a
http:/Avww.politico.com/blogs/under-the-radar/2014/12/court-filing-levels-sex-claims-at-
alan-dershowitz-200495.html
Woman who sued convicted billionaire over
sex abuse levels claims at his friends
On July 7, 2008, Edwards and I filed a petition alleging that Jane Doe No. 1 was a victim of
federal sex crimes committed by Epstein and that the United States had wrongfully excluded her
from plea ne
in the conjunction of Rule 410, the work-product privilege, and the Sixth Amendment right to
the effective assistance of counsel in the plea bargaining process,” but this novel argument fails
too. As
http://www. washingtonpost.com/news/volokh-conspiracy/wp/20 | 4/04/2 | /eleventh-circuit-rules-
that-discovery-can-move-forward-on-my-crime-victims-rights-act-case/
The Volokh Conspiracy
Eleventh Ci
http://files.wallstreetfolly.com/wordpress/2007/10/jeffrey-
epstein-doesnt-want-to-be-branded-as-a-sex-offender-for-
life-and-no-hes-not-a-modeling-agency-secret-sugar-daddy-
or-so-its-owners-say/
Je
Unfortunately, he made the offer to an undercover cop, and was subsequently charged with
“obstruction of official proceedings” for withholding information that could have advanced the
criminal investi