EFTA00183407
r t
EFTA00183407
RA.
JOSEPH R.ATTERBURY
JACK A. GOLDBERGER
JASON S.WEISS
-Road Ceo 'Hied Co ififinal lal Mot my
/ Member of New lersey R norm:. Bars
July 21, 2008
AUSA
U.S. Department of Justice
United States Attorney
Southern District of Florida
500 South Australian Avenue, Suite 400
West Palm Beach, Florida 33401
SENT A FA IMILE
Re: Jeffrey Epstein
Dear Ms.
Enclosed please find a Motion For Return of Property that I filed in Mr. Epstein's state case. Out
of abundance of caution, I am providing you a copy of the motion.
Ple advise me as to what your position is on this matter.
dberger
G/na
nclosure
One Clearlake Centre, Suite 1400 250 Australian Avenue South West Palm Beach, FL 33401
•
p 561.659.8300 f 561.835.8691 wwwagwpa.com
EFTA00183408
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT,
IN AND FOR PALM BEACH COUNTY, FLORIDA
STATE OF FLORIDA CASE NO.: 2006CF009454AXX
DIVISON: "W"
vs.
JEFFREY EPSTEIN,
Defendant.
DEFENDANT'S MOTION FOR RETURN OF PROPERTY
COMES NOW the Defendant, JEFFREY EPSTEIN, by and through his undersigned
attorney, and moves this Honorable Court to enter an Order for return of property seized on
October 20, 2005 during execution of a search warrant at the Defendant's residence. In support
thereof the Defendant states as follows:
1. On October 20, 2005, the Palm Beach Police Department executed a search warrant at
the Defendant's residence. During the execution of the warrant, numerous items of the
Defendant's personal property were seized and impounded by the Palm Beach Police
Department. A copy of the search warrant return is attached to this motion (Exhibit A).
2. On June 30, 2008, the criminal charges arising from the search warrant were resolved
through a negotiated plea agreement.
3. No legal justification exists for the continued impoundment of the Defendant's
personal property. The Defendant is entitled to the return of all personal property listed in
Exhibit A.
WHEREFORE, the Defendant, JEFFREY EPSTEIN, respectfully requests this
Honorable Court to enter an Order for the return of his personal property.
EFTA00183409
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Motion was sent via
FAX and U.S. MAIL to Lanna Belohlavek, Esq., Assistant State Attorney, 401 North Dixie
Highway, West Palm Beach, Florida 33401, this 2.\ aday of July, 2008.
ATTERBURY, GOLDBERGER & WEISS, P.A.
250 ustralian Avenue South, Suite 1400
W Palm Beac Florida 33401
(56 65;-8300
J BERGER, ESQUIRE
Flo Bar Number 262013
EFTA00183410
•.• PROPERTY
yEVIDENCE
I IDEN1743TATION NUMBER DATEITIME RECOVERED
0 3 '-M BEACH POLICE DEPARTMEN
PROPERTY RECEIPT
SEARCH WARRANT RETURN
0 DECEASED (Probated) 0 PERSONAL
OWNER / VICTIM'S NAME 1 D.O.B.
BPEOAL INSTRUCTIONS
MA. QUANTITY VALUE I. 0 04-
' • • DETOT BUREAU • •
0 CONFISCATED 'O DEST9oY
0 STOLEN/RECOVERED . DINNER
PROPERTY NUMBER Mee Bide
ADDRESS
ADDRESS
3515 Et. r;tzt/k... ADDRESS
ABEECRIPTION
Nelp BIN NUMBER BeavalBillic)10
PHONE NUMBER
PHONE NUMBER
EXHIBIT
ft No 5
FOUND PROPERTY. GLAIR 0
Nor aim
12j.1 :".7.14004fo. ., i..i:Aily, • 4 ... •i•-•11S :4, ..
nie isrikcticrAL:::',4647) . • •
64t f-hyri.eick*40/2./7 cifrnie (ie. yr--4 :-•;-,r,-1,-.)::-2- • •
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Atli); . i t,;e2:: jog tree . ,r'' e'l • ' f r.O? I1/44. ..71 .. fr clin."'"'
TOTAL PACKAGE WEIGHT •
I hereby acknowledge that' theabove list represents ell properly taken
from me and that I have received a copy of this receipt.
sollysk
BIGNATURE
. . RECEIVED BY •
abairaph Roc-arc the off;
inventorrcontaihd a true. detail account of
the authOrity .of thiswarrant I. hereby acknowledge that the above Est represents -all properly kyspoirded • .
by me In the Shale' performance of my duly as o pollee coder. .
. .
. .
11.(S tY2'
Sworn .to '.and .subscribed .bef
this 2 j day of OP Ober -2Cia5* ' DATE/TIME RECEIVED . • •
ed, do swear that• the above
y taken• by me, under .
Ric OILIM A &A by Whom this-warinnt
the
EFTA00183411
• ' a tat'. •""
• PO 152 I MA BEACH POLICE DEPARTMEI) /A€L•oZ OF• re.,,
DETECTIVE BUREAU PROPERTY RECEIPT SEARCH WARRANT RETURN
O PROPERTY O FOUND Q DECEASED (Probated) 0 PERSONAL 0 CONFISCATED O DESTROY
0 EVIDENCE. )21 TRIAL ' 0 IMI3ORATORY O STOLEN/RECOVERED ' CI OTHER
6 INCIDENT/CITATION tilt/BREA
. O 5. 3 6 Ø DATE/IIME RECOVERED
. /0' ..../5 PROPERTY NUMBER (Laws Bath) .
c 11,.? LI BIN NUMBER 'Caws mania
..."- ADDRESS WHERE PROPERTY IMPOUNDED
S G7 6L- rill b • DISCOVEREUBY/D.D.B: ADDRESS • Steel CIry 40 PHONE NUMBER .
OWNER / VICILIS NAME / Dp.B.
.) • I . ADDRESS • Snot CIO' . ZIP
. PHONE NUMBER
ECTI.S.NAME/D -20—r 7
t.......,
S 4rnin ADDRESS Sao! r,
3 9?) t. 131-2( E ao . ..
OPHONE NUMBER
AD RiaLle / .0/ 3ti
• ) .2p . . . • • - • • ...... PHONE NUMBER
• • • •
SPECIAL INSTRUCTIONS . . . v.,. • ' ' ..... ... 17 'U. : - 'FOUND PROPERTY . cialmO . ....
NOT CLAIM O
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`TOTAL PACKAGE WEIGHT . • . • . . • •• : . ..• /2•LeildotinH• '..
Ihmegkiammatedg elhal thaabovo ail repamnisil property taken ' front me and•that I halrooelved a copy of this receipt ' • .•
. . . •• • . • . .- • . I heuxibyaoknowledgo thol the above Rat repfeser;ell property
bt.into him official performance of my duty as a police oil
kik Oita Impounded
loot.'.
•I ... ..
°1
SIGNATURE . . .. • .DATE' • • ' •SIGN • LIRE IIIF
• RECEIVE/at/ DATE/I-NE RECEIVED :. ••••.: . • ..044MIPIP/14
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EFTA00183412
$ .e
• ...LM BEACH POLICE DEPARTMEI PA- O - 3 of 6
PRETWEgig DETECTIVE -BUREAU
O Pii6PERTY• O FOUND O DECEASED (Probated) 0-PERSONAL O CONFISCATED , CI DESTROY •
)ill EVIDENCE ca TRIAL . a LABORATORY . O 6113LEN/REpOVERED O OTHER :( • CI Ei '
INCIDENT/CITATION NUMBER
aH„,,,_.3.6g DATEMME RECOVERED
/t)-076- o PROPERTY. NUMBER (Leave sleek)
oS-ioati . BIN NUMBER (Leave Bland
. ADD ERE PROPERTY IMPOUNDED
2_7 ri- 6n] -
h . - .
DISCOVER Bytaos. . ADDRESS SLIM . a a.
• PHONE NUMBER
ON/EA / VICTIM/3 wit i D.O.B. ADDRESS stoat PM . 20 . PHONE NUMBER -
SPSPEDT'EHAME ! D.O.B. 0/-
;rf: 20-C ?
Fir ADDRESS •
5 5• EL-13TZ SINN . . Zip -
O PHONE NUMBER
irsifjA • •
- . • • a . • - . • •
• ' • • . PHONE NUMBER
• • •
SPECIAL INSTRUCTIONS, • ' . • - l - • .,FOUND
. . -. .
• '."' 1 - . PROPERTY CLAIM C.I •
NOT CLAIM O
ITEMT 'OUANnTY VAL .. ' -1 lizEscRIPTioN • :-.0"- - ' : ' • ' % ..
, Z.7 li- •••••••• Nal: • ei:hoaliamiacc kir/ 01457‘, gioAcam lie 3* t••-•• . ..• • •.
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Ving. • 3 .. . .7itin/ „ , ...• &Evart. a....
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:Iteist‘t1.
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iT •. . . .... TOTACPAaKAGEVEICiHT • I: " ' Nesi ko<a<t v•
I hereby acknowledge I al the above Hsi represents all property taken -
horn mo rid that I have received a copy of ihisrecelpt:
• I hereby acknowledge
byres in the official that inn above list represents all property. impounded
periounance el my duty as a police °Ulcer.
•
•_7:16 . l)
siGNAT RE , IINI • • , •U It.. :-.4 SIGNATURE ' LATE
RECEIVED BY ' . REASON • . DATE/TIME RECEIVED . • - .
. .-
. : • •••
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• . . • . . . ... .• .. . . ,.
EFTA00183413
•. •
%
.4" 4 4:1r •
4
PBPD Fiona:* . .LM BEACR.POLICE DEPARTMEI
PROPERTY RECEIPT . .
• ae /tot, 6 •
DETECTIVE BUREAU
0 PROPERTY 0 FOUND 0 DECEASED (Probated) 0 PERSONAL 0 CONFISCATED 0 DESTROY
JPEVIDENCE yeRTRIAL OLABORATORY 0 STOLEN/RECOVERED 0 OTHER A kr:
IDENTMITATION Nuo
tr)'. GtE? DATEMME RECOVERED .
/0 - ,?0-05PROPERTY NUMBER (Leave Blank)
g,..5,,ita_g.., BIN NUMBER (Loavo Blank)
ADDRES MIER . 2 TROPERTY IMPOUNDED
5 F • CI grd/o• DISCOVERED BY/DAB. ADDRESS City Zlo PHONE NUMBER
OWNER'S NAME/ DAB.' ADDRESS. . co a PHONE NUMBER
SUSPECTS NAME/MO r .ht 1
e• ttlitieWt 5 Dp PHONE NUMBER
.. .
D.0 B. • ikg.h.ADORES ' t . .
.. • .. .
• v
• • • --PHONE NUMBER
spapw. NSTRUCT1OM ' • • .: - - . ••
-: - 'POUND PROEFITY'. CLAIM 0 '
.. .
• :..:: iiO DAYS. '• ' NOT OSAIMb
: ITEM, -QUANTITY VALuE....TaA...,.--: - ESCRIPTION
4c.• fk - •
•' ''-• . r 6 n4. • itink. P w id it f ir She IREetttil .. 1. . ... • • ... . . v C .. hi iiec 4 et. sp ex—
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4 • 41114;;:i" 4 eV; litia .
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Q..% 7 - I . -••:•Ma..
• win,A.-..ce i..d.i:-.-fr.,:g..Ys . -. • .
fic : :-. 2.(bruitr„) .",:k 9 s
(5-S'zkreitift;:.:..i-.,:cei2tkincr-e.:440n7g -gre • icix.‘ re of-Pi? _ tens)
• • • ...• • .. • . ... . TOTAL PACKAGE WEIGHT - '
1 !lenity acknowledge that the above Net represents at property taken ' ..
horn me and Thal I have received a copy of the receipt. in• I hereby acknowledge that the above BM rapresChts
by me In the official performance of my duty as a pOke all property Impounded
officer.
•
SIGNATURE • DATE SIG itTU ICH
' RECEIVED BY . REASON DATE/TIME RECEIVED •
• •••
EFTA00183414
...cattyvs,
. •
•
„ .
•
0 PROPERTY 7"74 .--......t.
0 FOUND ' -0 DECEASED (Probated) UPERSONAL 0 CONFISCATED • O DESTROY .
EVIDENCE \yel TRIAL 0 LABORATORY 0 STOLENIFIO3OVERED 0 OTHER • k; ct to INCIDENT/CITA Ni.g
06 Y.DATEMME RECOVERED
/1)- a 0 .o_s- PROPERTY NUMBER (Leave Mirk) .
6,6_ io L.1 • , •-•• BIN NUMBER (tanner*
• ADDRESS Whig, RUROPERNIMPOUNDE0L. ,
BeY £L.- brt\ \D. • •
Pahl%) 6eack-... . . . . DISCOVERED BY//O/D.O.B. • . ADDRESS Street • . ay . -- . ERNE NUMBER '
OWNER'S NAME mom,
. ADDRESS 1 Street • Cie• PHONE NUMBER
'
SUSPECTS NAME/ D.O.B. 01--Z)-,516DREEIS
Sirin .rinoie fr Sweet cny a -
352t, to-a?' 110 PHONE NUMBER
. ••
AD Ill.. SUSPECT/we..., • '
. . • ADDRESS • SIMI City Zet.
• .. PHONE NUMBER
SPECIAL INSTRUCTIONS • • P :.
• 1 ' . `F0UND :PR0PERTY. CLAIM ID
., ,NOT CLAIM ID
/ ITEM-f'. corIANTrry• VAL9E• - • ' ''' .RESCRIPT .
- • ..e:sg: • PAWP 0,:. (Of i.. 4, C. P IA- # 5" 3•> 941
. A: .."--- 11; • :r fit i Prory, a -1.4.c ri I' istr k 1.1 c :itk&LN
4.e.tvi . • 5 s • f ltsi-Sakev 1
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. • . -- • -;• ' . ..• I.. ‘.. :` .: ; .nc:P.. ki4
. .- •• • • Peack : lein-PcSot le -Pot kilt. grit+
,_ •• I.4. • . • • ....• . . .. • . . .. . .... .... . • • • •
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• . . - - • . , . - ... QZ11124-1 .. .. • - •
• ,..
- -
- . .. . :. .. • • teal,
• TOTAL PACKAGE WEIGHT . .
I hereby acknowledge that the above list reinvents all property taken
from mo nd that I have received a copy of OA receipt
. I hereby acknowledge that the above list represents all property Impounded
In the official performance of my duty as .a police officer.
Ss- tiete°.°
ONA E ID/ • - . UNIT...44 SIGNATURE DATE
RECEIVED BY DATE/TIMEREOSIVED
---
•
. . teiLM BEACH SLICE DEPARtMEi
• • • PROPEWRECEIPT. • • AM( 5 Of 6
DETECTIVE BUREAU
• z
EFTA00183415
:v.., ker. St*" •
••••-, Ertl
•
PSPD Fars 162PALM BEACH liOLICEPEPARTMEN
PNPEert RECEIPT
LITL-) a Ad; /9464s of 6
DETECTIVE BUREAU
0 PROPERTY
V C FOUND CI DECEASED (Probated) 0 PERSONAL ' El CONFISCATED D DESTROY
01IMIDENCE iciRIAb• 1 4J LABORATORY C) STOtal!FiECOVERED U OTHER (1 a 1,0
s'i INCIIDERT IVATI&I NUMBER
I 0 DATETINE RECOVERED
t 0 2o0 c 141,/ 0 • PROF!ERTY HUMBER
- ("S - (Leave Blank)
boa ci BIN NUMBER (Leave Blank)
ADDRES5HgROPERTkIMPOUNDN A
-dr)/ i
i 10
DISCOVERED BY/ D.O.B. ADDRESS Speer . 20
1 . . PHONE NUMBER
OWNER'S NAME! DAB: ADDRESS Spear qty 20 PHONE NUMBER
•
Sr T'S NAIIF-JD.O.B er. ./ ;,,1O. ' r?
ti ADDRESS, Street . Clly
L, Ik• PHONE NUMBER
lipprm... SUSPECT / D.O.B, ADDRESS a; • PHONE NUMBER
SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM 0
• •
: •. Arr.' ,
't ' 90 DAYS NOT CLAIM Cal
p ME ARMY VAltUE . ;DESCRIPTION iLenA
.
64/a 4ad Pkil, it>. I. . rilAotE. 44..,-Ail ' 12;iii,op;,.4
A.PACe0. _.
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terrir ---at
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. " - . . . . •_ _ . .. . . . .. . • , -i2c P.)I1 rj
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...', • . ''..:••-f. ...;:c.:.....1,".c,:". " 2. funr-.?
ft ellill‘i
- • " ' ....;.;600. wigs-. 4: 3, . - ••• . .. . • . i-• .pcivx
' . • ft :.
,.4
TOTAL PACKAGE WEIGHT
‘., I hereby acknowledge that the above lief represorils all property taken .,
from me and that I have received a copy of Iles receipt.
^. r I hereby acknowledge that the above lies represents all property Impounded
by me In the official performance of my duty as a police officer.
ICIIIK .... D24, SIGNATUR ID, - UNIT •
SIGNATURE • DATE
RECEIVED BY REASON DATE/TIME RECEIVED
ob r s2.1, 2 Ely- Ea
/a' op 6 - 0 c• /SO 0 ift,
,
EFTA00183416
LEWIS TE IN PL ATTORNEYS AT LAW
July 21, 2008
Copy via facsimile
NM Esq. Office of the United States Attorney
500 S. Australian Avenue
West Palm Beach, Florida 33401
RE: Jeffrey Epstein
Dear Ms.
Thank you for your letter of July 17, 2008. In it, you ask whether Mr. Epstein "intends to fully
abide by the Non-Prosecution Agreement." The answer is yes.
We confirm as you state in your letter that the Agreement requires that "the federal Grand Jury
investigation will remain suspended, and all pending federal Grand Jury subpoenas will be held
in abeyance unless and until [Mr. Epstein] violates any term of [the Non-Prosecution
Agreement]." We also confirm that under the Agreement, "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 , . . conditions and the requirements of th[e] Agreement."
As you know, there la no 'provision in the Agreement referring in any way to Section 3509(k).
By that statute, Congress imposed a mandatory obligation on federal district courts to stay
certain civil cases. Its operation is not subject to the control or discretion of any party. Whether
Title 18, United States Code, Section 3509(k) applies to this civil litigation is a question of law
for resolution by Judge Marra. Accordingly, we are abiding by our ethical obligation to advise
the Court of its statutory mandate under Section 3509(k).
Finally, thank you for notifying me that our motion to quash technically remains outstanding.
We had previously notified. the Court that the parties did not wish to argue the issue. I agree that
the Agreement requires its withdrawal and we will file a formal notice withdrawing it this week.
Please do not hesitate to call me if you wish further clarification of our position or to discuss this
matter in any way. Until then, I remain,
Very truly yours,
Michael R. 'rein
cc: _lick Goldberge1.1:sLi
Ro Black Ls .
3069 GRAND AVENUE • SUITE 340 • COCONUT GROVE, FLORIDA 33133
TELEPHONE (305) 442.1101 • FACSIMILE (305) 442-6744 • VAVW.LEWISTEIN.COM
EFTA00183417
LEWIS TE IN PL ATTORNEYS AT LAW
July 21, 2008
Copy yin facsimile
Mae Esq. Office of the United States Attorney
500 S. Australian Avenue
West Palm Beach, Florida 33401
RE: Jeffrey Epstein
Dear Ms.
Thank you for your letter of July 17, 2008. In it, you ask whether Mr. Epstein "intends to fully
abide by the Non-Prosecution Agreement." The answer is yes.
We confirm as you state in your letter that the Agreement requires that "the federal Grand Jury
investigation will remain suspended, and all pending federal Grand Jury subpoenas will be held
in abeyance unless and until [Mr. Epstein] violates any term of [the Non-Prosecution
Agreement]." We also confirm that under the Agreement, "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 ... conditions and the requirements of th[e] Agreement."
As you know, there is no provision in the Agreement referring in any way to Section 3509(k).
By that statute, Congress imposed a mandatory obligation on federal district courts to stay
certain civil cases. Its operation is not subject to the control or discretion of any party. Whether
Title 18, United States Code, Section 3509(k) applies to this civil litigation is a question of law
for resolution by Judge Marra. Accordingly, we are abiding by our ethical obligation to advise
the Court of its statutory mandate under Section 3509(k).
Finally, thank you for notifying me that our motion to quash technically remains outstanding.
We had previously notified the Court that the parties did not wish to argue the issue. I agree that
the Agreement requires its withdrawal and we will file a formal notice withdrawing it this week.
Please do not hesitate to call me if you wish further clarification of our position or to discuss this
matter in any way. Until then, I remain,
Very truly yours,
•
Michael R. Tein •
cc: Jack Goldberger, Esq.
• Roy Black, Esq.
Alex Acosta, Esq.
3059 GRAND AVENUE • SUITE 340 • COCONUT GROVE, FLORIDA 33133
TELEPHONE (305) 442-1101 • FACSIMILE (305) 442-6744 • WWW.LEW1STEIN.COM
EFTA00183418
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:
(1) knowingly and willfully conspiring with others known and unknown to
commit an offense against the United States, that is, to use a facility or means
of interstate or foreign commerce to knowingly persuade, induce, or entice
minor females to engage in prostitution, in violation of Title 18, United States
Code, Section 2422(b); all in violation of Title 18, United States Code, Section
371;
(2) knowingly and willfully conspiring with others known and unknown to travel
in interstate commerce for the purpose of engaging in illicit sexual conduct, as
defined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18,
United States Code, Section 2423(b); all in violation of Title 18, United States
Code, Section 2423(e);
(3) using a facility or means of interstate or foreign commerce to knowingly
persuade, induce, or entice minor females to engage in prostitution; in
violation of Title 18, United States Code, Sections 2422(b) and 2;
(4) traveling in interstate commerce for the purpose of engaging in illicit sexual
conduct, as defined in 18 U.S.C. § 2423(f), with minor females; in violation
Page 1 of 7
EFTA00183419
of Title I8, 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. § 159 I (cX I); in violation of Title
18, United States Code, Sections 1591(a)(1) 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 for a 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 1 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.
Page 2 of 7
EFTA00183420
Terms of the Agreement:
1. 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. 2006-0f-009495/UO:3(MB) charging
one (1) 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
EFTA00183421
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
EFTA00183422
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 necessary
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 criminal ch es
a to•o- irators of E stein including but not limited to IN
or . Further, upon execution o t rs
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 successful completion of the terms of this agreement, all
outstanding grand jury subpoenas shall be deemed withdrawn.
Page 5 of 7
EFTA00183423
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
prosccutions 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.
/II
/I/
/II
Page 6 of 7
EFTA00183424
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: iti/9 —
Dated:
Dated: ASSISTANT U.S. ATTORNEY
GERALD LEFCOURT, ESQ.
COUNSEL TO JEFFREY EPSTEIN
LILLY ANN SANCHBZ, ESQ.
ATTORNEY FOR JEFFREY EPSTEIN
Page 7 of 7
EFTA00183425
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:
ASSISTANT U.S. ATTORNEY
Dated:
Dated: 7/9-4,/ 0 7
Dated: JEFFREY EPSTEIN
9". FCOUR ESQ.
OUNSEL TO JEFFR .Y EPSTEIN
LILLY ANN SANCHEZ, ESQ.
ATTORNEY FOR JEFFREY EPSTEIN
Page 7 of 7
EFTA00183426
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:
ASSISTANT U.S. ATTORNEY
Dated:
JEN/REY EPSTEIN
Dated:
GERALD LEFCOURT, ESQ.
COUNSEL TO JEFFREY EPSTEIN
Dated: q-jcit,t/P —
, ESQ.
ATTORNEY FOR JEFFREY EPSTEIN
Page 7 of 7
EFTA00183427
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 assign 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.
EFTA00183428
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: By:
ASSISTANT U.S. ATTORNEY
Dated:
JEFFREY EPSTEIN
Dated:
GERALD LEFCOURT, ESQ.
COUNSEL 'II) JEFFREY EPSTEIN
Dated: if:LaIM
LILLY A ANCHEZ, ES
ATTORNEY FOR JEFFREY EPSTEIN
EFTA00183429
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:
Dated:
Dated
Dated: By:
ASSISTANT U.S. ATTORNEY
JEFFREY EPSTEIN
ERALD LEFCO RT ESQ.
COUNSEL TO JEFFR Y EPSTEIN
LILLY ANN SANCHF,Z, ESQ.
ATTORNEY FOR JEFFREY EPSTEIN
EFTA00183430
111111111111 11 1111 .1111111111 101
11110.1 1.11111 .1.1110 N
Sincerely,
R. ALEXANDER ACOSTA
UNITED STATES ATTORNEY
3
EFTA00183431
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. 1 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, wilt 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."
2
EFTA00183432
U.S. Department of Justice
United States Attorney
Southern District of Florida
R ALEXANDER ACOSTA
UNITEDSTATES ATTORNEY
DELIVERY BY FACSIMILE
Lilly Ann Sanchez
Fowler White Burnett, PA
1395 Brickell Aye, le Floor
Miami, FL 33131
Re: Jeffrey Epstein
Dear Ms. Sanchez: 99 NE (Street
Main& FL 13111
(105)9614100 Telephone
005)1104444 - Facsimile
December 19, 2007
I write to follow up on the December le meeting between defense counsel and the Eps
prosecutors, as well as our First Assistant, the Miami FBI Special Agent in Char e and mysel .
2 Section 2255 provides that: "falny person who, while a minor, was a victim of a violation of [enumerated sections
of Title 18) and who suffen 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 fcc "
EFTA00183433
By signing this Addendum, Epstein asserts end 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.
K. ALEXANDER ACOSTA
UNITED STATES ATTORNEY
Dated: By'
U.S. ATTORNEY
Dated: /°''I163-
Dated:
Dated: GERALD LEFCOURT, ESQ.
COUNSEL TO JEFFREY EPSTEIN
LILLY ANN SANCHEZ, ESQ.
ATTORNEY FOR JEFFREY EPSTEIN
EFTA00183434
Page 2 of 8
Westlaw
West's F.S.A. § 951.24 Page 1
C
Effective:Pee Text Amendments]
West's Florida Statutes Annotated Currentness
Title XLVII. Criminal Procedure and Corrections (Chapters 900-999) (Refs & Annos)
Chapter 951. County and Municipal Prisoners (Refs & Annos)
951.24. Extend the limits of confinement for county prisoners
(I) Any county shall be deemed to have a work-release program upon the motion of that county's board of
county commissioners which shall require the concurrence of the sheriff of the county.
(2)(a) Whenever punishment by imprisonment in the county jail is prescribed, the sentencing court, in its discre-
tion, may at any time during the sentence consider granting the privilege to the prisoner to leave the confines of
the jail or county facility during necessary and reasonable hours, subject to the rules and regulations prescribed
by the court, to work at paid employment, conduct his or her own business or profession, or participate in an
educational or vocational training program, while continuing as an inmate of the county facility in which he or
she shall be confined except during the period of his or her authorized release.
(b) My prisoner, at the time of sentencing or thereafter, may request the court in writing for the privilege of be-
ing placed on the work-release program. The Department of Corrections, upon the request of the court, is author-
ized to conduct such investigations as are necessary and to make recommendations to the court pertaining to the
suitability of the plan for the prisoner and to supervise such prisoner if released under this program. Such a re-.
lease may be granted by the court with the advice and consent of the sheriff and upon agreement by the prisoner.
The court may withdraw the privilege at any time, with or without notice.
(c) No person convicted of sexual battery pursuant to s. 794.011 is eligible for any work-release program or any
other extension of the limits of confinement under this section.
(3)(a) The wages or salary of prisoners employed under this program may be disbursed by the sheriff pursuant to
court order for the following purposes in the order listed:
I. Board of the prisoner.
2. Necessary travel expense to and from work and other necessary incidental expenses of the prisoner.
3. Support of the prisoner's legal dependents.
C 2008 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
litim://web2.westlaw.com/nrint/nrintstream.asmanrfir-HTMT.Fkifm=hIntSetRidect nat inn 1 1 /94/WIR
EFTA00183435
Page 3 of 8
West's F.S.A. § 951.24 Page 2
4. Payment, either in full or ratable, of the prisoner's obligations acknowledged by him or her in writing or
which have been reduced to judgment.
5. The balance to the prisoner upon discharge from his or her sentence, or until an order of the court is entered
declaring that the prisoner has left lawful confinement, declaring that the balance remaining is forfeited, and dir-
ecting the sheriff to deposit the funds in the general fund of the county to be spent for general purposes.
(b) The sheriff may collect from a prisoner the wages or salary earned pursuant to this program. The sheriff shall
deposit the same in a trust checking account and shall keep a ledger showing the status of the account of each
prisoner. Such wages and salaries shall not be subject to garnishment in the hands of either the employer or the
sheriff during the prisoner's sentence and shall be disbursed only as provided in this section.
(c) Every prisoner gainfully employed is liable for the cost of his or her board in the jail as fixed by the county.
The sheriff shall charge the prisoner's account, if he or she has one, for such board. If the prisoner is gainfully
self-employed he or she shall deposit with the sheriff an amount determined by the court sufficient to accom-
plish the provisions of subparagraphs (a)I.-5., in default of which his or her privileges under this section are
automatically forfeited.
(d) The board of county commissioners of any county may, upon the recommendation of the sheriff, authorize
the person in charge of a county stockade or workcamp to implement paragraphs (a), (b), and (c), when such fa-
cility is not directly under the sheriff.
(4) Any prisoner who willfully fails to remain within the extended limits of his or her confinement or to return
within the time prescribed to the place of confinement shall be deemed an escapee from custody and shall be
subject to punishment as prescribed by law.
(5) Exchange for the purpose of work-release of county prisoners among other counties of the state that have im-
plemented work-release programs is hereby authorized, with the concurrence of the sheriffs of the involved
counties. For the purpose of this subsection, upon exchange, the prisoner shall be deemed a prisoner of the
county where confined unless or until he or she is removed from extended confinement status. Prisoners from
other jurisdictions, serving lawful sentences, may also be received into a county work-release program as above
provided.
(6) In carrying out the purpose of this section, any board of county commissioners may provide in its annual
budget for payment to the Department of Corrections out of funds collected from those being supervised such
amounts as are agreed upon by the board and department to be reasonable and necessary. County judges arc
hereby authorized to levy $10 per month upon those supervised for purposes of paying for supervision under this
act.
CREDIT(S)
1 1 Pt A P.I."^t1
EFTA00183436
11/25/2088 15:28 3553626 U1KUUll LICIAINAL " raisin" do "
•
•
STATE OF FLORIDA
Plaintiff
-VS-
JEFFREY
Defendant IN THE nrnarrrs JUDICIAL
. CIRCUIT COURT, IN AND FOR
PALM BEACH COUNTY -*
CASE NUMBER IDLNACERQ2211/62Q2S12
DIVISION MCSORLEY "V PI
1,113$155 DC NUMBER
CIRCUIT NUMBER: 15-4/ JAIL spur
ORDER OF COMMUNITY CONTROL I
This cause coming before the Court to be heard, and you, the defendant, being now present before the mutt and you.
having
El catered a plea of guilty to O been found guilty laYinrY verdict of
O entered a plea of nolo cone sere to 0 been found guilty by tho court trying the cat without a jury of
Count L isocuRtrasoN UNDERAGE_QT 18 FOR PROSTITOTIQN
SECTION 3.: JUDGMENT OF GUILT
El The court hereby adjudge" you to be guilty of the above offense (s).
Now, therefore, it is ordered and adjudged that rho imposition of sentence is baby withheld and that you be placed
on Probation I for a period of candor the supervilion of the Department of Correction", subject to Florida law.
SECTION 2t ORDER WITHHOLDING ADJUDICATION
O Now, therefore, it is ordered and adjudged that the adjudication of guilt is hereby withheld and that you be placed on
Probation fora period of under the supervision of tho Department of Corrections, subject to Florida law.
SECTION 3: INCARCERATION DURING PORTION OF SUPERVISION SENTENCE
It is hereby ordered and adjudged that you be
O committed to the Department of Contetions
or
O confined In the County Jail
fore tout of with credit for jar] time. After you have served of the term, you shall be placed on
Probation for a period of under the supervision of the Deportment of Cormotions, subject to Florida lbw.
or
• oontired in the County /all
fors term of SIX (61 MONTHS AS TO COUNT 1IrOLLOWED DY TWELVE (121 MONTHS,
0212111CLUSdatigaL I CONSECUTIVE TO IMEE (121 MONTH SENTENCE IIZ
CASEY! 2008CF009454AbfE with credit for ONE al DAY Jail limo, as s special condition of
tutoervielon
Page 1 of 8 1VHIHRID LISOBIO
13 ntinoo H3V38 W1Vd
/i831S 'FOOS !IOSIMS ,
SS:h Hd IZ1R1800Z
03114 Form Revised 03-11-08
EFTA00183437
11/25/2066 15:2B 3553626 • • Vibiaii I " -"— ri-ikt Ott CO
JEFFREY EPSTEIN
CASEN50.2008CF0093814,00346 . . • • .
XT 78 FURTHER ORDERED that you &sitcoms* with the following gjandard °midi dons otintervision assioxided. by Fiptida • • . . • •
law:
(1) You will report to the probed= office as directed. Not later than the fifth day of each month, unless othawbe littered, you Will . . .
• ' make e full end ttuth
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[Image 2] The image shows a document with a vertical orientation, which appears to be a photograph of a paper. The document has a series of lines and what seems to be a header or title at the top. There is a visible date in the upper right corner, but the resolution is too low to read the text clearly. The document has a crease running down the middle, indicating it may have been folded. The background is i
[Image 3] The image appears to be a document scan, specifically a form or a letter. It is heavily damaged with visible creases, stains, and discoloration, suggesting it has been handled roughly or has been exposed to various elements. The text is partially obscured and difficult to read due to the damage. There are no visible names, dates, places, or logos that can be discerned from this image. The document
[Image 4] The image appears to be a document scan, specifically a form or a certificate. It contains various fields with handwritten text and checkboxes. The visible text includes names, dates, and possibly some form of identification or certification. The document is old, as indicated by the faded ink and the aged paper. The handwriting is somewhat difficult to decipher due to the quality of the scan.
[Image 5] The image shows a document that appears to be a form or a list with various sections and checkboxes. There are handwritten notes and corrections on the document, indicating that it has been reviewed or edited. The text is not entirely legible due to the quality of the image and the handwriting. The document seems to be a form of some sort, possibly related to an application, registration, or a lis
[Image 6] The image shows a document that appears to be a police report or incident report. The document is titled "INCIDENT REPORT" and includes sections for "INCIDENT NUMBER," "DATE," "TIME," "LOCATION," "VICTIM," "SUSPECT," "OFFENSE," and "REPORTING OFFICER." There are handwritten notes and corrections on the document, indicating that it has been reviewed or revised. The visible text includes names, date