Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of Case ocument Entered on FLSD Doot Page of First that the defendant concealed a record document or other object with the intent to impair the objects availability for use in an official proceeding or otherwise obstructed or impeded that proceeding Second that the defendant did so corruptly that is wrongfully and with improper purpose and Third that the defendants conduct had a relationship in time causation or logic with the official proceeding that is that the endeavor had the natural and probable effect of interfering with the due administration of justice Statutory Penalties The defendant understands and acknowledges that as to the charge contained in the Information the Court may impose a maximum sentence of twenty years imprisonment to be followed by a term of supervised release ofup to three years and may impose a fine ofup to The defendant also understands that in addition to any term of imprisonment and supervised release and/or any fine that is imposed the Court may order him to pay restitution to any victim of his offense as required by law The defendant understands and acknowledges that a violation of the tenns of his supervised release can result in additional criminal penalties Special Assessment The defendant further understands and acknowledges that in addition to the sentence imposed under paragraph of this Agreement a special assessment in the amount of will be imposed The defendant agrees that any special assessment imposed shall be paid at the time of sentencing Applicability of Sentencing Guidelines The defendant is aware that the Page of Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of Case ocument Entered on FLSD Do.t Page of sentence will be imposed by the Court after considering the Federal Sentencing Guidelines and Policy Statements hereinafter Sentencing Guidelines The defendant acknowledges and understands that the Court will compute an advisory sentence under the Sentencing Guidelines and that the applicable guidelines will be detem1ined by the Court relying in part on the results of a Pre-Sentence Investigation by the Courts Probation Office which investigation will commence after the entry of the defendants guilty plea The defendant is also aware that under certain circumstances the Court may depart from the advisory sentencing guideline range that it has computed and may raise or lower that advisory sentence under the Sentencing Guidelines The defendant further understands that the Court is required to consider the advisory guideline range determined under the sentencing guidelines but is not bound to impose that sentence the Court is permitted to tailor the ultimate sentence in light of other statutory concerns and such sentence may be either more severe or less severe than the Sentencing Guidelines advisory sentence Knowing these facts the defendant understands and acknowledges that the Court has the authority to impose any sentence within and up to the statutory maximum authorized by law for the offense identified in paragraph and that the defendant cannot withdraw his guilty plea solely as a result of the sentence imposed Rights Waived by Pleading Guilty The defendant understands that by pleading guilty he knowingly and voluntarily waives the following rights a the right to plead not guilty and to persist in a plea of not guilty the right to a speedy and public trial before a jury of his peers Page of I Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of Case ocument Entered on FLSD Do.t Page of the right to the effective assistance of counsel at trial including if the defendant could not afford an attorney the right to have the Conrt appoint an attorney for the defendant the right at trial to be presumed innocent until guilt has been proven beyond a reasonable doubt by the United States the right at trial to confront and cross-examine witnesses against the defendant the right to compel or subpoena the testimony of witnesses and other evidence to present at trial the right at trial to testify or to remain silent and the right that such silence could not be used against the defendant the right to challenge the sufficiency of the Information and the right to appeal any pretrial rulings or a finding of guilt Governments Right to Disclose Infonnation to the Court The Office of the United States Attorney for the Southern District of Florida hereinafter Office reserves the right to inform the Court and the Probation Office of all facts pertinent to the sentencing process including all relevant information concerning the offenses committed whether charged or not as well as concerning the defendant and the defendants background Subject only to the express terms of any agreed-upon sentencing recommendations contained in this Agreement this Office further reserves the right to make any recommendation as to the quality and quantity of punishment Page of i Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of Case ocument Entered on FLSD Do.t Page of t,.cceptance of Responsibility The United States and the defendant agree that although not binding on the Probation Office or the Court they will jointly recommend that the Court should reduce by two levels the sentencing guideline level applicable to the defendants offense pursuant to Section of the Sentencing Guidelines based upon the defendants recognition and affirmative acceptance of personal responsibility If at the time of sentencing the defendants offense level is determined to be or greater and the defendant complies with the requirements of Section 3El.l the government will make a motion requesting an additional one-level decrease pursuant to Section 3El.J of the Sentencing Guidelines stating that the defendant has assisted authorities in the investigation or prosecution of his own misconduct by timely notifying authorities of his intention to enter a plea of guilty thereby pennitting the government to avoid preparing for trial and permitting the government and the Court to allocate their resources efficiently Limitation on Joint Sentencing Recommendations The defendant understands and agrees that the United States will not be required to make the motion and sentencing recoJlilendation set forth in paragraph if the defendant a fails orrefuses to make a full accurate and complete disclosure to the Probation Office of the circumstances surrounding the relevant offense conduct is found to have misrepresented facts to the government prior to entering this plea agreement colits any misconduct after entering into this plea agreement including but not limited to conunitting a state or federal offense violating any term ofrelease or making false statements or misrepresentations to any governmental entity or official or fails to provide infonnation when requested to do so by this Office Page of I I i I Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of Case ocument Entered on FLSD Dool Page of Factual Proffer The defendant his counsel and the United States further agree that had this case proceeded to trial the United States would have introduced the following evidence which is sufficient to support a plea of guilty and proves beyond a reasonable doubt that the defendant is guilty of the charge contained in the Information a The defendant was formerly employed as a prope1iy manager by Jeffrey Epstein Epstein and lived and worked at Epsteins residence in Palm Beach Florida in the Southern District of Florida in and In the defendant was interviewed by members of the Town of Pahn Beach Police Department regarding allegations of illicit sexual conduct between Epstein and several minor females On January Special Agents of the Federal Bureau of Investigation also interviewed the defendant in connection with a federal grand jury investigation of Epsteins criminal activity The defendant was asked by law enforcement to produce any information or evidence in his possession related to Epsteins criminal activity The defendant also was provided with contact information for FBI Special Agents and was asked to contact them ifhe remembered or discovered any farther infonnation In July and August the defendant was snbpoenaed to appear for deposition in connection with several civil lawsuits filed against Epstein by minor female victims of his criminal conduct The subpoenas called for the defendant to appear and produce documents related to Epstein The defendant appeared for deposition but did not produce any documents Beginning in August after the conclusion of the second deposition Page of Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of Case ocument Entered on FLSD Dool Page of the defendant contacted a cooperating witness CW and informed the CW that he had additional infonnation that he had not previously disclosed to any law enforcement agency or any of the civil attorneys including lists of hundreds of additional victims and their telephone numbers The defendant agreed to tum this information over to the CW in exchange for The CW tried to convince the defendant to turn over the material voluntarily but the defendant refused The CW then approached law enforcement During a consensually monitored telephone call on October the CW told the defendant that he would be contacted by an associate of the CW regarding the purchase of the material The associate was in fact an undercover Special Agent of the Federal Bureau ofinvestigation UCB On October the UCB contacted the defendant via telephone The defendant again explained that he would only tum over the information in exchange for monetary compensation During the conversation the defendant admitted that he knew that the information was relevant to the FBIs criminal investigation and was called for by the investigation The defendant explained that he had not turned over the information to the FBI because it was his property and he should be compensated for it and he was afraid that Epstein would make him disappear or otherwise harm him and the infom1ation was his insurance policy On November the defendant met with the UCE at a predetermined location During the meeting the defendant produced a small bound book and several sheets of!egal pad paper containing hand-written notes The defendant discussed in Page of I I Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of Case c,cument Entered on FLSD Dool Page of detail the infom1ation contained within the book which he admitted removing from Epsteins home without Epsteins permission and identified important infom1ation to the UCE In addition the defendant admitted that he had previously lied to the FBI during the course of the federal criminal investigation of Epstein The defendant asked the UCE about the took possession of the money and began counting it The defendant was then detained for Obstrnction of Official Prnceedings in violation ofTitle United States Code Section and questioned After Miranda 267wamings were administered by agents the defendant waived his rights and signed a written waiver of those rights The defendant admitted that he had the documents and book in his possession and had never turned them over to local law enforcement or the FBI In addition the defendant advised he had witnessed naked girls whom he believed were minors at the pool area of Epsteins home knew that his former employer was engaging in sexual contact with underage girls and had viewed pornographic images of underage girls on computers in Epsteins home The items that the defendant attempted to sell to the UCB were reviewed by an FBI Special Agent involved in the federal grand jury investigation of Epstein As the defendant had described the items contained infonnation material to the Epstein investigation including names of material witnesses and additional victims The items also would have co1Toborated testimony of victims already identified Had the items been produced in response to the inquiries of the state or federal authorities or if the defendant had contacted the federal authorities at any time after his initial interview to produce these items the materials would have been presented to the federal grand jury Page8of JO I Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of Case c,cument Entered on FLSD Doot Page of No Promises or Representations Regarding Ultimate Sentence The defendant is aware that the sentence has not yet been determined by the Court The defendant also is aware that any estimate of the probable sentencing range or sentence that the defendant may receive whether that estimate comes from the defendants attorney the government or the probation office is a prediction not a promise and is not binding on the government the probation office or the Com1 The defendant understands further that any recommendation that the government makes to the Court as to sentencing whether pursuant to this agreement or otherwise is not binding on the Court and the Court may disregard the recommendation in its entirety The defendant acknowledges that no one has promised or guaranteed what sentence the Court will impose The defendant understands and acknowledges as previously acknowledged in paragraph above that the defendant may not withdraw his plea based upon a the Courts decision not to accept a sentencing recommendation made by the defendant and/or the government or the fact that he received an inconect estimate of the sentence that he would receive whether that estimate came from his attorney the United States and/or the Probation Office Volm1tariness of Plea The defendant agrees that he has entered into this Plea Agreement freely and voluntarily and that no threats or promises other than the promises contained in this written Plea Agreement were made to induce the defendant to enter his plea of guilty Consent to ofltems The defendant agrees to forfeit all interests in any items seized during the course of this investigation whether the Page of Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of Case IJument Entered on FLSD Do Page of defendant currently owns has previously owned or over which the defendant currently or has in the past exercised control directly or indirectly Defendant agrees to hold the United States its agents and employees hannless from any claims whatsoever in connection with the forfeiture seizure or destruction of property covered by this agreement The defendant agrees that this property may be destroyed or disposed of in accordance with the policies and procedures of the custodial agency The defendant further agrees to waive all constitutional and statutory challenges in any manner including direct appeal habeas corpus or any other means to any destruction or disposal of property carried out in accordance with this Plea Agreement on any grounds including that the forfeiture constitutes an excessive fine or punishment Defendant acknowledges that all property covered by this agreement is subject to forfeiture as property involved in illegal conduct giving rise to forfeiture Entire Agreement This is the entire agreement and understanding between the United States and the defendant There are no other agreements promises representations or understandings Date Date Date lo Page of
