Document Text Content
TAB 1
HOUSE OVERSIGHT 012197
First Assistant U.S. Attorney
DELIVERY BY FACSIMILE
Jay P. Lefkowitz, Esq.
Kirkland & Ellis LLP
Citigroup Center
153 East 53rd Street •
New York, New York 10022-4675
Re: Jeffrey Epstein
U.S. Department of Justice
United States Attorney
Southern District of Florida
99 PIE. 4 Street
Miami, FL 33132
(305) 961-9100
May 19, 2008
Dear Mr. Lefkowitz,
I am in receipt of your e-mail dated May 19, 2008 to the United States Attorney. The U.S.
Attorney would like me to advise you that all communications and inquiries related to the Epstein
matter, will be handled by AUSA Marie Villafana and/or her supervisor, Karen Atkinson, so he does
not intend to respond to your e-mail or calls unless AUSA Villafana and/or her supervisors advise
him otherwise. Furthermore, you make reference to "our July 8 deadline." Respectfully, the United
States Attorney's Office for the Southern District of Florida ("SDFL") has never agreed to any such
deadline. Should you decide to provide the SDFL with any additional information, please do so
through AUSA Villafana, and, in her absence, AUSA Atkinson.
On September 24, 2007, your client, Jeffrey Epstein, in consultation with Gerald Lefcourt,
Esq. and Lilly Ann Sanchez, Esq., as well as numerous other nationally-renowned lawyers, including
but not limited to Harvard Law Professor Alan Dershowitz, former Independent Counsel and
Solicitor General of the United States Kenneth Starr, just to name a few, entered into a global
resolution of state and federal liabilities faced by your client ("the Agreement") with the SDFL.
Although you and other members of the defense team have since claimed that the Agreement was
the product of adhesion, the following facts demonstrate that Epstein knowingly and voluntarily
entered into the Agreement in order to avoid a federal indictment regarding his sexual conduct
involving minor victims. Despite the fact that by signing the Agreement, Epstein gave up the right
to object to its provisions, the SDFL bent over backwards to exhaustively consider and re-consider
your objections. Since these objections have finally been exhausted and Epstein has previously
expressed his intent to not comply with several of the terms and conditions of the Agreement as set
forth below, the SDFL hereby notifies you that unless he complies with all of the terms and
conditions of the Agreement, as modified by the United States Attorney's December 19,2007 letter
to Ms. Sanchez by close of business on Monday, June 2, 2008, the SDFL will elect to terminate the
Agreement.
HOUSE OVERSIGHT 012198
JAY P. LEFKOWITZ, ESQ.
May 19, 2008
PAGE 2 OF 6
Background
The Agreement was the product of months of negotiations. Specifically, you requested and
received numerous meetings, at the highest levels of the SDFL and DOJ's Child Exploitation and
Obscenity Section (CEOS) concerning claims that (a) the investigation merely produced evidence
of relatively innocuous sexual conduct with some minors who, unbeknownst to Epstein,
misrepresented their ages; (b) the authorities investigating Epstein engaged in misconduct; (c) the
contemplated federal statutes have no applicability to this matter; and (d) the federal authorities
disregarded the fundamental policy against federal intervention with state criminal proceedings.
After careful review, the SDFL ultimatelyrejected those claims. Subsequent to its decision, however,
but before proceeding any further, the SDFL provided you with 30 days to appeal the decision to the
Assistant Attorney General of the United States, Alice Fisher. As you recall, you chose to forego an
appeal to AAG Fisher, and instead pursued a negotiated resolution which, ultimately, resulted in the
execution of the Agreement.
The Negotiation Phase
During negotiations, you tried to avoid a resolution that called for incarceration and
registration as a sexual offender — both of which would be triggered by a successful federal
prosecution. The SDFL believed and continues to believe that should this matter proceed to trial,
your client would be convicted of the federal statutes identified in the Agreement. In order to achieve
a global resolution, the SDFL indicated a willingness to defer to the State the length of incarceration;
however, it remained adamant that Epstein register as a sex offender and that all victims identified
during the investigation remain eligible for compensation. In order to achieve this result, the parties
considered two alternatives, a plea to federal charges that limited Epstein's sentencing exposure, or,
as suggested by you, a plea to state charges encompassing Epstein's conduct. Ultimately, the parties
agreed to, inter alio, a plea to the state charges outlined in the Agreement, registration and a method
of compensation.
The Agreement
The crux of the Agreement defers in favor of the State federal prosecution of Epstein for his
sexual conduct involving those minor victims identified as of September 24, 2007, in exchange for
a guilty plea to a state . offense that requires registration as a sex offender; a sufficient term of
imprisonment; and a method of compensation for the victims such that they would be placed in the
same position as if Epstein had been convicted of one of the enumerated offenses set forth in Title
18, United States Code, Section 2255. Specifically, the Agreement mandates, inter alia, (1) a guilty
plea in Palm Beach County Circuit Court to solicitation of prostitution (Fl. Stat. Section 796.07) and
procurement of minors to engage in prostitution (Fl. Stat. Section 796.03) (an offense that requires
him to register as a sex offender); (2) a 30-month sentence including 18 months' incarceration in
county jail; (3) a methodology to compensate the victims identified by the United States; (4) entry
HOUSE OVERSIGHT 012199
JAY P. LEFKOWITZ, ESQ.
May 19, 2008
PAGE 3 OF 6
of the guilty plea and sentence no later than October 26, 2007; and (5) the start of the above-
mentioned sentence no later than January 4, 2008.
Furthermore, and significantly, Epstein agreed that he had the burden of ensuring compliance
of the Agreement with the Palm Beach County State Attorney's Office and the Judge of the 15th
Judicial Circuit and "that the failure to do so will be a breach of the agreement" (emphasis added).
Post-Execution of the Agreement
Within weeks of the execution of the Agreement, you sought to delay the entry of Epstein's
guilty plea and sentence. After the SDFL agreed to accommodate your request, counsel for Epstein
began taking issue with the methodology of compensation, notification to the victims, and the issues
that had been previously considered and rejected during negotiations, i.e., that the conduct does not
require registration and the contemplated state and federal statutes have no applicability to the instant
matter.
A. Delay.
The Agreement required that "Epstein shall use his best efforts to enter his guilty plea and
be sentenced not later than October 26, 2007. The United States has no objection to Epstein self-
reporting to begin serving his sentence not later than January 4, 2008." Agreement, pages 4-5,
paragraph 11 (emphasis added). After the Agreement was executed, the SDFL accommodated your
request to extend the October 26th plea deadline to November 20th based upon, what seemed to be,
reasonable scheduling conflict issues.' By early November, you represented that the presiding state
courtjudge would not "stagger the plea and sentencing as contemplated in the Agreement."Although
the Agreement clearly did not contemplate a staggered "plea and sentencing," the SDFL again agreed
to accommodate Epstein's request to appear in state court for plea and sentencing on January 4,
2008.2
I "Accordingly, I have now confirmed with Mr. Epstein's Florida counsel that the state's
attorney's office and the court will be available to have him enter his plea on November 20. So we will
plan to proceed on one that date." October 18;2007 email from Jay Lefkowitz to USA R. Alexander
Acosta.
On the same day, Mr. Lefkowitz confirmed with First Assistant Jeffrey H. Sloman that this
postponement " will not affect when Epstein begins serving his sentence."
2 Correspondence from Jay Lefkowitz to FAUSA Sloman dated November 8, 2007 ("the judge
has invited the parties to appear for the plea and sentencing on January 41, we do not anticipate any delay
beyond that date.")
HOUSE OVERSIGHT 012200
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 Kenneth Starr, took issue with the implementation of the methodology of
compensation (hereinafter "the 2255 provision")3 and the SDFL's intention to notify the victims
under 18 U.S.C. Section 3771 (you objected to victims being notified of time and place of Epstein' s
state court sentencing hearing). In response, the SDFL offered, in my opinion, numerous and various
reasonable modifications and accommodations which ultimately resulted in United States Attorney
R. Alexander Acosta's December 19, 2007 letter to Lilly Ann Sanchez. In that letter, the United
States Attorney tried to eliminate all concerns which, quite frankly, the SDFL was not obligated to
address, let alone consider. He proposed the following language regarding the 2255 provision:
"Any person, who while a minor, was a victim of a violation of an offense enumerated in
Title 18, United States Code, Section 2255, will have the same rights to proceed under
Section 2255 as she would have had, if Mr. Epstein been tried federally and convicted of an
enumerated offense. For purposes of implementing this paragraph, the United States shall
provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in
an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority
interpreting this provision, including any authority determining which evidentiary burdens
if any a plaintiff must meet, shall consider that it is the intent of the parties to place these
identified victims in the same position as they would have been had Mr. Epstein been
convicted at trial. No more; no less."
Regarding the issue of notice to the victims, USA Acosta proposed to notify them of the
federal resolution as required by law; however, IN* will defer to the discretion of the State
Attorney regarding whether he wishes to provide victims with notice of the state proceedings,
although we will provide him with the information necessary to do so if he wishes." As you know,
you rejected these proposals as well. See December 26, 2007 correspondence from Jay Lefkowitz
to USA Acosta.
3 Prior to any issues arising concerning the implementation of the 2255 provision, the SDFL
unilaterally agreed to assign its responsibility to select the attorney representative for the alleged victims
to an independent third-party. This was done to avoid even the appearance of favoritism in the selection
of the attorney representative. As a result, on October 29, 2007, the parties executed an Addendum
wherein it was mutually agreed that former United States District Court Judge Edward B. Davis would
serve as the independent third-party. Judge Davis selected the venerable law firm of Podhurst and
Josefsberg to represent the approximately 34 alleged identified victims.
HOUSE OVERSIGHT 012201
JAY P. LEFKOWITZ, ESQ.
May 19, 2008
PAGE 5 OF 6
C. "Mr. Epstein Does Not Believe He Is Guilty Of The Federal Charges Enumerated
Under Section 2255."
At our December 14, 2007 meeting at the U.S. Attorney's Office in Miami, counsel for
Epstein announced, inter alia, that it was a "profound injustice" to require Epstein to register as a
sex offender and reiterated that no federal crime, especially 18 U.S.C. Section 2422(b), had been
committed since the statute is only violated if a telephone or means of interstate commerce is used
to do the persuading or inducing. This particular attack on this statute had been previously raised and
thoroughly considered and rejected by the SDFL and CEOS prior to the execution of the Agreement.
You also argued that the facts were inapplicable to the contemplated state statutes and that Epstein
should not have been allowed to have been induced into the Agreement because the facts were not
what he understood them to be. It should be noted that the SDFL has never provided you with any
evidence supporting its investigation. This is not, and has never been, an Alford plea situation (see
North Carolina v. Alford, 400 U.S. 25, 91 S.Ct. 160 (1970)). Ultimately, you requested an
independent review.
Subsequent to the above-mentioned meeting, the SDFL received three letters from you and/or
Mr. Starr which expanded on some of the themes announced in the December 14th meeting.
Essentially, you portrayed the SDFL as trying to coercea plea to unknown allegations and incoherent
theories. On December 17, 2007, you decreed that Epstein's conduct did not meet the requirements
•of solicitation of minors to engage in prostitution (Fl. Stat. Section 796.03) one of the enumerated
crimes Epstein had previously agreed to plead guilty to; that Epstein's conduct does not require
registration under Florida law; and the State Attorney's Office does not believe the conduct is
registrable. On December 21, 2007, you rejected the USA's proposed resolution of the 2255
provision because you "strongly believe that the provable conduct of Mr. Epstein with respect to
these individuals fails to satisfy the requisite elements of either 18 U.S.C. Section[s] 2422(b) ... or
2423(b)." In your December 26, 2007 correspondence you stated that "we have reiterated in
previous submissions that Mr. Epstein does not believe he is guilty of the federal charges enumerated
under section 2255" and requiring "Mr. Epstein to in essence admit guilt, though he believes he did
not commit the requisite offense."
As the SDFL has reiterated time and time again, it does not want, nor does it expect, Epstein
to plead guilty to a charge he does not believe he committed. As a result, we obliged your request
for an independent de novo review of the investigation and facilitated such a review at the highest
levels of the Department of Justice. It is our understanding that that independent review is now
complete and a determination has been made that there are no impediments to a federal prosecution
by the SDFL.
HOUSE OVERSIGHT 012202
JAY P. LEFKOWITZ, ESQ.
May 19, 2008
PAGE 6 OF 6
Conclusion
On February 25, 2008, I sent you an e-mail setting forth a timetable for moving forward in
the event that CEOS disagreed with your position. That time is now. As you know, my February 25th
email stated that I would give you one week to comply with the terms and conditions of the
Agreement, as modified by the USA's December 19th letter to Ms. Sanchez. In light of the upcoming
Memorial Day weekend, I have decided to extend that timetable to the close of business on Monday,
June 2, 2008, which is a full two weeks.
Sincerely,
R. Alexander Acosta
United States Attorney.
By:
Jeffrey H. Sloman
First Assistant United States Attorney
cc: R. Alexander Acosta
United States Attorney
A. Marie VilIafana
Assistant U.S. Attorney
Karen Atkinson .
Assistant U.S. Attorney
HOUSE OVERSIGHT 012203
TAB 2
HOUSE OVERSIGHT 012204
11/05/2007 11:26 FAX
11/05/07 MON 1005 FAX 305 330 6440 EXECUTIVE OFFICE
on /003
I'dj001
U.S. Department of Justice
United States Attorney
Southern District of Florida
UNITED STA.TE,S ATTORNEY'S OFFICE
SOUTHERN DISTRICT OF FLORIDA
99 NE 41-TH STREET
WAKE, FLORIDA 33132-2111
Jeffrey H. Slo ma n
First Assistant U.S. Attorney
305 961 9299
Cynciee Campos
Staff Assistant
305 961 9461
305 530-6444 fax
FACSIMILE TRANSMISSION
COVER SHEET
DATE: November 5, 2007
TO: Jay Lefkowitz, Esquire
FAX NUMBER: (212) 446 4900
SUBJECT: Jeffrey Epstein
NUMBER OF PAGES, INCLUDING THIS PAGE: 3
Message/Comments:
Inesiniiie contains PRIVFLEGIM 4ND CONFIDENTIAL INPORMA"I'ION intended only for thc LISC of the
A ddreswe(s) named Qbove. If you arc not the intended recipient of this caesimile, or the employee or agent respomsible
for delivering, it to the intended recipient, you are hereby notified that any clisttcrnination or coping of this faesimile is
strictly prohibited nyou ha vc received thiN facsimile Lit eTTOT, please immediately notify wi by telephone and return the
onal thesimileto os at the above address via the, U.S. POsial Service, Thank you,
HOUSE OVERSIGHT 012205
11/05/2007 11:27 FAX
11/05/07 MON 10:05 FAX 305 530 6440 EXECUTIVE OFFICE
U.S. Department of Justice
DELIVERY.ByFACSIMTI...E
Jay P. Lefkowitz, Esq.
Kirkland Lk,: Ellis
Citigroup Center
153 East 53r.l Street
New York, New York 10022-4675
Jeffry Epstei
Dear Jay:
United States Attorney
Southern District of Florida
991V.E. 4th Street
Miami, FL 33132-2111
(305) 961-9299
Far:sin:tie: (305) 530-6444
November 5, 2007
• • •
a 002/003
411002
Several things have come to my attention that seem contrary to your client intending to abide
by his obligations under the Non-Prosecution Agreement. As you know, that agreement requires our
Office to inform you of potential breaches to give you and your client the opportunity to respond
before an indictment is filed. At this time, I do not believe that the agreement has been breached;
however, I have sufficient concerns that need to be addressed.
First, I understand that private investigators working for Mr. Epstein have contacted victims
to ask them whether any detectives or FBI agents have discussed a financial settlement with them.
On one occasion, the private investigators told the parent of a victim that she should get an attorney
for her daughter and she should do so right away. These actions are troublesome because the FBI
agents legally are required to advise the victims of the resolution or the matter, which includes
informing them that, as part of the resolution, that Mr. Epstein has agreed to pay damages in some
circumstances. Furthermore, Mr. Epstein well knows that we are in the process of selecting an
attorney to represent the victims and, but for the inordinate amount of time spent negotiating the
Addendum, that attorney would already have been selected. Paragraph 7 of the Non-Prosecution
Agreement explicitly provides that contact with the victims shall be through that counsel.
Accordingly, please confirm that there will be no further efforts to contact any victims until Judge
Davis selects the attorney representative and that, thereafter, contact will be made only through that
counsel.
Second, the Non-Prosecution Agreement requires Mr. Epstein to use his best efforts to enter
his guilty plea and to be sentenced not later than October 26, 2007. Despite this obligation, the
Office agreed that Mr. Epstein could postpone this deadline to November, but reiterated that Mr.
HOUSE OVERSIGHT 012206
11/05/2007 11:27 FAX
11/05/07 MON 10:00 FAX 305 530 6440
EXECUTIVE OFFICE
el 003/003
VI nos
JAY P. IxpKowrinz, ESQ.
Nov2mt:IER 5, 2007
PACE 2 OF 2
Epstein had to begin his term of incarceration not later than January 4, 2008. I have learned that the
November hearing has been removed from the calendar and the next case disposition conference has
not been set until January 7, 2008. This delay is unacceptable, and, pursuant to your obligations, the
Office requests that you confer with the State Attorney's Office to try to find a date in November
when the judge is available to conduct a simultaneous plea and sentencing, if you cannot find such
a date, please provide documentation of your efforts to abide by the terms of the Non-Prosecution
Agreement.
Third, there have been several press reports that Mr. Epstein no longer intends to enter a
guilty plea. Normally I would not pay any attention to such reports, but your recent correspondence
attempting to restrict our office from communicating with the State .Attorney's Office and the
allusion to the imposition of sentences that clearly fall outside the terms of the Non-Prosecution
Agreernent raises concern. Please confirm that Mr. Epstein intends to abide by his agreement to
plead guilty to the specified charges and to make a binding recommendation that the Court impose
a sentence of 18 months of continuous confinement in the county jail.
Finally, the Non-Prosecution Agreement requires that you provide the Office with copies of
all proposed agreements with the State Attorney's Office before Mr. Epstein signs any such
agreements. To date, no such agreements have been received. Please provide me with copies of any
and all agreements with the State Attorney's Office for our review. The Office also would like to
have someone present at the change ofplea and sentencing to monitorMr, Epstein's compliance with
the terms of the Non-Prosecution Agreement, so please keep me informed of the date, time, and
location of the hearing.
Please provide me with a written response, adopted by Mr. Epstein, addressing these
concerns and reiterating Mr. Epstein's intention to comply with the tenns of the Non-Prosecution
Agreement by November 8, 2007.
By:
CO: R. Alexander Acosta, U.S. Attorney
AUSA A. Marie Villafalia
Jeffrey S ornan
Sincerely,
R. Alexander Acosta
United States A omey
First Assistant linited States Attorney
HOUSE OVERSIGHT 012207
TAB 3
HOUSE OVERSIGHT 012208
TOLL RECORDS OF SARAH KELLEN'S CALLS
• MR. EPSTEIN DID NOT KNOW WHO WOULD BE COMING TO GIVE HIM A MASSAGE.
(561) 635-
Wednesday, April 27, 2005 9:02AM 3454
(561) 801-
Wednesday, April 27, 2005 9:03AM 3590
(561) 714-
Wednesday, April 27, 2005 12:14PM 0546
(561) 714-
Wednesday, April 27, 2005 12:15PM 0546
(561) 309-
Wednesday, April 27, 2005 3:16PM 0079
(561) 309-
Wednesday, April 27, 2005 3:20PM 0079
(561) 644-
Thursday, May 05, 2005 3:28PM 3713
(561) 644-
Thursday, May 05, 2005 8:43PM 3713
(561) 644-
Thursday, May 05, 2005 8:48PM 3713
(561) 644-
Thursday, May 05, 2005 9:13PM 3713
(561) 644-
Thursday, May 05, 2005 10:03PM 3713
(561) 389-
Friday, May 06, 2005 8:30AM 6874
(561) 644-
Friday, May 06, 2005 8:59AM 3713
(561) 714-
Friday, May 06, 2005 9:33AM 0546
(561) 389-
Friday, May 06, 2005 9:34AM 6874
(561) 309-
Friday, May 06, 2005 9:35AM 0079
(561) 644-
Friday, May 06, 2005 10:58AM 3713
(561) 644-
Friday, May 06, 2005 5:35PM 3713
(561) 644-
Friday, May 06, 2005 7:50PM 3713
(561) 644-
Saturday, May 07, 2005 11:03AM 3713
(561) 389-
Saturday, May 07, 2005 11:04AM 6874
(561) 262-
Sunday, May 08, 2005 11:39AM 6186
(561) 684-
Sunday, May 08, 2005 12:28PM 6642
(561) 262-
Sunday, May 08, 2005 3:20PM 6186
(561) 262-
Sunday, May 08, 2005 3:21PM 6186
1 Mr. Rofrano is Mr. Epstein's chiropractor.
HOUSE OVERSIGHT 012209
• MR. EPSTEIN DID NOT TARGET ANY ONE PARTICULAR INDIVIDUAL, NOR DID HE TARGET MINORS.
ALL OF THE CALLS BELOW WERE MADE TO WOMEN OVER THE AGE OF 18.
(561) 389-
Saturday, July 02, 2005 9:50AM 6874 cell
(561) 635-
Saturday, July 02, 2005 11:33AM 3454 cell
(561) 856-
Saturday, July 02, 2005 11:54AM 2974 cell
(561) 635-
Saturday, July 02, 2005 12:03PM 3454 cell
(561) 324-
Saturday, July 02, 2005 1:49PM 7996 cell
(561) 324-
Saturday, July 02, 2005 3:21 PM 7996 cell
(561) 635-
Saturday, July 02, 2005 3:22PM 3454 cell
(561) 324-
Saturday, July 02, 2005 3:58PM 7996 cell
(561) 262-
Saturday, July 02, 2005 4:10PM 6186 cell
(561) 635-
Saturday, July 02, 2005 4:11 PM 3454 cell
(561) 302-
Saturday, July 02, 2005 6:20PM 1844 cell
(561) 389-
Saturday, July 02, 2005 9:25PM 6874 cell
(561) 324-
Sunday, July 03, 2005 1:14PM 7996 cell
(561) 574-
Sunday, July 03, 2005 1:44PM 0142 cell
(561) 262-
Sunday, July 03, 2005 9:57PM 6186 cell
(561) 714-
Sunday, September 18, 2005 9:58AM 0546 cell
(561) 324-
Sunday, September 18, 2005 9:59AM 7996 cell
(561) 635-
Sunday, September 18, 2005 9:59AM 3454 cell
(561) 801-
Sunday, September 18, 2005 10:02AM 3590 cell
(561) 662-
Sunday, September 18, 2005 10:04AM 3098 cell
(561) 302-
Sunday, September 18, 2005 10:44AM 1844 cell
(561) 389-
Sunday, September 18, 2005 1:10PM 6874 cell
(561) 389-
Sunday, September 18, 2005 4:10PM 6874 cell
(561) 324-
Sunday, September 18, 2005 5:17PM 7996 cell
(561) 714-
Sunday, September 18, 2005 9:36PM 0546 cell
(561) 714-
Sunday, September 18, 2005 9:45PM 0546 cell
HOUSE OVERSIGHT 012210
TAB 4
HOUSE OVERSIGHT 012211
6
7
8
9
10
11
12
13
14
16
17
18
19
20
21
22
23
1 MP: Detective Michele Pagan
2
3 KB: Kathy Back
4
5 MP: I_D. #8059, reference case number 05-368. The time now, by my watch, is
approximately 6 minutes past 2pm on 3/15/05. (Inaudible) High Ridge Family
Center, Sable Palm School.
UNK: Just High Ridge Family Center.
MP: Okay, the High Ridge Family Center. Present also is. could you state your name
please?
MP: Spell your name please?
MP: And your date of birth?
MP: And you are?
CB: Cathy Back, Family Therapist.
MP: Could you spell your name please?
KB: K-A-T-H-Y B-A-C-K.
MP: And you're her family therapist? Am I correct?
KB: Yes.
MP: Okay. l'm here today and I have stated briefly why I'm here is in
reference to an incident that happened to a friend of yours, or a girl you know_
Page 1 of 43
05118
HOUSE OVERSIGHT 012212
2 3 I'm not sure if she's friend of yours or not, by the name of=. Do you know what I'm talking about? Yes.
11 MP: Okay. I hear your voice got very low all of a sudden so if you don't mind..
5 Oh, okay.
6 MP: I'll even hold it. Okay. Can you tell me how you know=
7 She's my ex-boyfriend's cousin.
8 MP: And what's your ex-boyfriend's name?
9 Zack=
10 MP: Is that his last name?
11 Yes.
12 MP: What school does he go to?
13 (inaudible) Summit Christian School.
14 MP: And you said he's your ex-boyfriend. How long ago was that?