EFTA00230786

EFTA00230786 U.S. Department of Justice United States Attorney Southern District of Florida 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 Facsimile: June 12, 2009 DELIVERY BY HAND Jack A. Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. One Clearlake Centre, Suite 1400 250 Australian Ave S. West Palm Beach, FL 33401-5015 Re: Jeffrey Epstein Dear Mr. Goldberger: Pursuant to the terms of the Non-Prosecution Agreement, the United States Attorney's Office for the Southern District of Florida hereby provides you with notice that the United States Attorney has determined, based on reliable evidence, that Jeffrey Epstein has willfully violated one of the conditions of the Non-Prosecution Agreement. Specifically, on May 26, 2009, Jeffrey Epstein, through his counsel, filed a "Motion to Dismiss the First Amended Complaint or, in the Alternative, for a More Definite Statement," in the matter of Jane Doe No. 101 v. Jay Epstein, Court File No. 09-CV-80591-ICAM. "Jane Doe No. 101" was on the list provided to Mr. Epstein's attorneys of individuals whom the United States had identified as victims, as defined in 18 U.S.C. § 2255, and "Jane Doe No. 101" has elected to proceed exclusively under 18 U.S.C. § 2255. By filing the Motion to Dismiss, Mr. Epstein is contesting liability and, therefore, has violated Term 8 of the Non-Prosecution Agreement. Based upon Mr. Epstein's breach of that term, the U.S. Attorney's Office will pursue its remedies. The U.S. Attorney's Office also is continuing its review of Mr. Epstein's filings in the civil suits to determine whether additional breaches have occurred. If any are EFTA00230787 JACK GOLDBERGER, ESQ. JUNE 12, 2009 PAGE 2 OF 2 identified, they will be communicated to you in accordance with the terms of the Non￾Prosecution Agreement. Sincerely, Acting United States Attorney cc: Roy Black, Esq. By: Assistant United States Attorney EFTA00230788 07/28/2011 13: 11 FAX Idlootio04 KIRKLAND & ELLIS LLP Fax Transmittal 300 North LaSalle Street Chicago, Illinois 60654 Phone: (312) 862-2000 Fax: (312) 862-2200 Please notify tm Immediately if any pages are not received. THE INFORMATION CONTAINED IN THIS COMMUNICATION IS CONFIDENTIAL, MAY BE ATTORNEY-CLIENT PRIVILEGED, MAY CONSTITUTE INSIDE INFORMATION, AND IS INTENDED ONLY FOR THE USE OF THE ADDRESSEE. UNAUTHORIZED USE, DISCLOSURE OR COPYING IS STRICTLY PROHIBITED AND MAY BE UNLAWFUL. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY AT: (312) 862-2000, To: CC: Martin G. Weinberg, Esq. Company: United States Attorney, Southern District of Florida Company: Fax #: Direct #: Fax #: Direct tt: From: Sandra Musumeci for Jay P. Lefkowitz, P.C. Message: Date: July 29, 2011 Pages Weaver: 4 Fax Direct Please see the attached letter, in response to your letter to Martin Weinberg of July 27, 2011, concerning Jeffrey Epstein. Thank you. Docuracna EFTA00230789 07/23/2011 13:12 FAX lit) 0 0 2/0 0 4 Jay P. LalloyeAtt P.C. To Cady: latielkowitoakiddand.cat KIRKLAND & ELLIS LLP ANDAMATIDPARTNEWWWS 601 Lexington Avenue New York, New Yuck 10022 vevnv.kirkland.corn July 29, 2011 Facsinlie: Delivery by Facsimile CONFIDENTIAL Assistant United States Attorney United States Attorney, Southern District of Florida 500 S. Australian Avenue West Palm Beach, FL 33401 Re: Jeffrey Epstein Dear Ms. Thank you for your letter of July 27, 2011 to my co-counsel Martin Weinberg concerning the request by the New York District Attorney for copies of the Non-Prosecution Agreement ("NPA") and the "victim list" in regards to Mr. Epstein. We continue for the reasons stated herein to believe that any such disclosure would violate the confidentiality agreement between your Office and Mr. Epstein as well as the provisions of Fed. R. Crim. P. 6(e). As to the NPA, you have repeatedly asserted in Doe v United States, No. 9:08-cv-80736- KAM, that the NPA was a confidential document. For instance, in paragraph 6 of Document 14, your own Declaration, you stated that the NPA contained "an express confidentiality provision!' In opposing the Motion to Unseal the NPA that was filed by Jane Doe, you stated that you had informed Judge Marra of the confidentiality provision during an earlier telephonic slat is conference occurring on August 14, 2008 which "the United States was obligated to honor," Document 29 at 1, and that "the parties who negotiated the Agreement, the United States Attorney's Office and Jeffrey Epstein, determined that the Agreement should remain confidential," Document 29 at 2. Further, you deemed the NPA "confidential," for understandable purposes, in your September 3, 2008 letter to Robert Josefsberg in which you informed him that Judge Marra had set forth procedures for providing the NPA only to those counsel and "victims" who executed a Protective Order preventing its subsequent disclosure. The New York Assistant District Attorney, Ms. Morse, is representing the prosecution in an appeal regarding a sex offender registration determination, and any disclosure of the NPA to her has the potential to result in its use in that appeal and the real risk that the appellate court will unseal it. We believe it to violate both the spirit and the most logical interpretation of the NPA, Chicago Hong KOng London Los Angeles Munich Palo Alto San Francisco Shanghei Washington D.C. Ka2 19419748.2 EFTA00230790 07/29/2011 13: 12 FAX e 003/004 KIRKLAND & ELLIS LLP A. Vitiate& July 29, 2011 Page 2 paragraph 13, for you to disclose it absent a subpoena -- which we could oppose in the jurisdiction from which it emanated. We further believe that when parol evidence supplements the text of paragraph 13 of the NPA, it is perfectly apparent from your prior submissions that you as well as we believed the NPA to contain "an express confidentiality provision" that your current willingness to disclose absent court process violates. As to the "victim list," again, not only is it confidential given its nexus to the NM, but your own prior letters tie the list to the Federal Grand Jury investigation and thus to the non￾disclosure provisions of Fed. R. Crim. P. 6(e). On July 8, 2008, you wrote to Jack A. Goldberger, Esq., and informed him that on June 30, 2008, "the United States Attorney's Office provided [him] with a list of thirty-one individuals 'whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein.'" (emphasis added). On July 9, 2008, you wrote in a follow-up letter to Mr. Goldberger that "the U.S. Attorney's modification of the 2255 portion of the Agreement now limits our victim list to those persons whom the United States was prepared to include in an indictment. This means that, pursuant to Justice Department policy, these are individuals for whom the United States believes it has proof beyond a reasonable doubt that each of them w v n enumerated offense." (emphasis added). First Assistant United States Attorney used similar language in tying the names ', victims" to the basis for a potential indictment, see December 6, 2007 letter from Mr. to Mr. Lefkowitz at 2, 3; see aiv your email to Mr. Lcfkowitz and Mr. Black on August 14, 2008 at 3:27 p.m., where you state that the list contains "only those 'individuals whom [the United States] was prepared to name in an Indictment...,'" thus clearly providing the nexus between the list and the Grand Jury investigation and its corollary, the protections from non￾disclosure enumerated in Fed. R. Crim. P. 6(e). In terms of case law, the names of witnesses that either testified or were identified during Grand Jury proceedings are subjec secrecy provisions of Fed. R. Crim. P. 6(e). $se, e.g., In re Grand Jury Subpoena, Judith, 438 F.3d 1138, 1140 (D.C. Cir. 2006) ("Consistent with these purposes, we have recognized that grand jury secrecy covers 'the identities of witnesses or jurors, the substance of testimony as well as actual transcripts, the strategy or direction of the investigation, the deliberations or questions of jurors, and the like.") (citing in re Dow Jones & Co., Inc„ 142 F.3d 496, 500 (D.C. Cir. 1998)); sce alsq SEC v Dresser hglustr, inc„ 628 F.2d 1368, 1382 (D.C. Cir. 1980); fund for Constitutional Gov't v Nat'l Archives & Records Serif., 656 F.2d 856, 869 (D.C. Cir. 1981). Indeed, it is generally recognized that the scope of protection accorded to Grand Jury proceedings under Rule 6(e) is broad and encompasses, among other things, information such as the "victim list" at issue here: Kea. 104397482 EFTA00230791 07 /29/2011 13:12 FAX 21004/004 KIRKLAND & ELLIS LLP July 29, 2011 Page 3 We construe the secrecy provisions of Rule 6(e) to apply not only to disclosures of events which have already occurred before the grand jury, such as a witness's testimony, but also to disclosures of matters which will occur, such as statements which reveal the identity of persons who will be called to testify or which report when the grand jury will return an indictment. In re Grand Jury Investigation 610 F.2d 202, 216-17 (5th Cir. 1980).1 We believe that confidentiality applies to the requested information. We believe that any non-compulsory handover of the list or NPA is inconsistent with the positions you have previously taken in related litigation. Accordingly, we request that you reconsider and decline the request of the New York District Attorney. Sincerely, P. Le owitz, P.C. Cc: Martin G. Weinberg JPL/slm Decisions of the United States Court of Appeals for the Fifth Circuit handed down prior to September 30, 1981, are binding as precedent in the Eleventh Circuit. Den Donner v. City of Prichard. Ala. 661 F.2d 1206, 1207 (11th Cir. 1981). K&E 194397482 EFTA00230792 Roy BLACK HOWARD M. SREBNICK Scan A. KORNSPAN LARRY A. STUMPF MARIA NEYRA JAC/OE PERCZEK MARK A.J. SHAPIRO JARED BLACK SREBNICK KORNSPAN STUMPF P.A September 1, 2009 Assistant U.S. Attorney United States Attorney's Office 99 N.E. 4th Street Miami, Florida 33132 RE: Jeffrey Epstein Dear M: JESSICA FONSECA-NADER KATHLEEN P. PHILLIPS AARON AMNON MARCOS BEATON, JR. MATOIEW P. CYBRIEN JENIPER J. SOLILIKIAS NoAH Fox E-Mail: Once again I need to send you a note about Jeffrey Epstein, mainly to keep you in the loop. we don't inadvertently violate any provision of his agreement with your office. As I am sure you are aware, Mr. Epstein has finished the incarceration portion of his sentence and is now serving the one year of community control as mandated by both his state plea and the terms of the non￾prosecution agreement with the United States Attorney's Office for the Southern District of Florida. Mr. Epstein is in compliance with all terms of his community control and is applying for transfer of his supervision from the State of Florida to his primary residence, the Virgin Islands. This transfer is being requested through the Intrastate Compact for Transfer of Adult Supervision (ICAOS). The ICAOS is the mechanism for which transfers of probation and community control are effectuated. The process requires the offender to seek the approval of the sending state (in this case Florida) and, if they agree, the receiving state (in this case the United States Virgin Islands) and the United States Virgin Islands after investigation has pre-approved the transfer under the same exact conditions of supervision as imposed in Mr. Epstein's community control sentence in the State of Florida. Even though Mr. Epstein is requesting the transfer he is still at the home 201 5. Bisare Boulevard. Suite 1300 • Miami. Florida 33131 • Phone: • Fax: • www.Royalack.com EFTA00230793 September 1, 2009 Page 2 in Palm Beach following the rules of state community control. As Mr. Epstein's lawyers, we believe that his request to administratively transfer his community control is in full compliance with both his state plea agreement and the non￾prosecution agreement with the United States Attorney's Office. Nonetheless we have taken to heart your previous suggestion of erring on the side of caution and thus we are advising you of this request. I am happy to discuss this with you at any time. I did not want to set an appointment to see you on this issue since I imagine you have more pressing matters to deal with than a transfer of a state community control matter. RB/wg Very I Roy Black Black. SrebnIck, Komspan & Stumpf. PA EFTA00230794 ROY BUCK HOWARD M. SREBNICK SCOTT A. KORNSPAN LARRY A. STUMPF MARIA NEYRA JACKIE PERCZEK MARK A.J. SHAPIRO JARED BLACK SREBNICK KORNSPAN & STUMPF —PA— February 18, 2010 Esq. Assistant United States Attorney 99 N.E. 4th Street Miami, FL 33132 RE: Jeffrey Epstein Dear Ms I .: JESSICA FONSECA-NADER KATHLEEN P. PHIWPS AARON AMNON MARCOS BEATON, JR. MATTHEW P. O'BRIEN JEMPER J. Soutaas NOAH Fox E-Mail: Thank you for your letter of February 11, 2010. We write to update you about ongoing efforts to reach an agreement with Robert Josefsberg regarding the amount of fees and costs properly owed to him by Mr. Epstein pursuant to the NPA. On February 16, 2010 Mr. Epstein's principal civil counsel Bob Critton advised Mr. Josefsberg in writing that he and Mr. Epstein would meet with Mr. Josefsberg on two occasions between now and March 1, 2010 to review Mr. Josefsberg's outstanding bills on a line-by-line basis and attempt to reach a non￾adversarial resolution of all outstanding fee issues. Mr. Critton also transmitted to Mr. Josefsberg an Agreement for Special Master to Determine Amount of Attorneys' Fees and Costs ("Special Master Agreement", signed by Mr. Epstein, containing terms and conditions previously agreed to by Mr. Josefsberg, which would mandate binding mediation before a neutral third party in the event the proposed settlement discussions did not resolve all outstanding issues in an expeditious manner. We want to assure you that Mr. Epstein fully intends to fulfill his obligations under the NPA. We regret that issues remain unresolved regarding whether all of the fees and costs being sought by the attorney representative - which now total $1,947,000 exclusive of the $526,466 already paid by Mr. Epstein - meet the criteria set forth by the NPA. We assure you that both Mr. Epstein's prior civil counsel, Jay Lefkowitz, who, with you, was a primary negotiator of the NPA language, and Mr. Critton, each strongly believe that significant amounts of the fees and costs billed by Mr. Josefsberg are outside the scope of Mr. Epstein's fee￾201 S. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131 • Phone: • Fax: • www.RoyBlack.com EFTA00230795 Esq. February 18, 2010 Page 2 related payment obligations under the NPA. We hope that the fee-related issues can be resolved by further settlement discussions or by relying on the Special Master Agreement signed Tuesday February 16, 2010 by Mr. Epstein. Mr. Epstein and his counsel believe that these options are consistent with the NPA, are good alternatives to contested litigation, and are reasonable given the unexpected magnitude of the bills and their inclusion of charges for legal work that was clearly related to the preparation of litigation and thus outside Par 7C of the Addendum as well as for extensive work performed by attorneys from outside Mr. Josefsberg's law firm. Mr. Josefsberg previously advocated for settling outstanding issues through a Special Master Agreement nearly identical to the one executed Tuesday by Mr. Epstein. In fact, Mr. Josefsberg and Mr. Epstein had each agreed in the past to a specific Master as a third-party neutral to conduct proceedings to resolve the fee issues. However, the selected Master withdrew. We hope that the Special Master Agreement will provide a basis for a prompt resolution of any issue not resolved by the parties through further discussions. Respectfully submitted, MARTIN WEINBERG, ESQ. ROY LACK, ESQ. /wg co: By Black, Srcbnick. Kornspan & Stumpf, P.A. EFTA00230796 EFTA00230797 EFTA00230798 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 Police Case#: 05-368 (1) Defendant: Race/Sex: DOB: Charges: Jeffrey Epstein White Male 01-20-1953 Unlawful Sexual Activity with a Minor (4) counts Lewd and Lascivious Molestation From March 15, 2005, through February 2006, the Palm Beach Police Department conducted a sexual battery investigation involving Jeffrey Epstein, and Sworn taped statements were taken from five victims and seventeen witnesses concerning massages an un awful sexual activity that took place at the residence of Jeffrey Epstein, 358 El Brillo Way, Palm Beach. Several of the victims were recruited by and brought to the residence by to perform massages for Epstein, for which received monetary compensation. During the visit they would be introduced to , Epstein's assistant, who in turn would record their telephone numbers and name. The victims would be brought to Epstein's bedroom to provide the massage. Epstein would enter the room and order the victims to remove their clothin to rovide the massage. As the victims complied and provided the massages, E stein would On occasion, Epstein would introduce a massager/vibrator and rovided the masse e. On three separate occasions, Epstein had intercourse and . At the conclusion of the massages the victims were paid sums of money ranging from $200 - $1,000. The facts, as reported, are as follows: On 03/15/2005, A fourteen year old white female, hereinafter referred to as and her family reported unlawful sexual activity which occurred at a residence within the Town of Palm Beach. reported that a subject known to her as "Jeff' had touched her while within his residence. "Jeff' was later identified as Jeffrey Epstein through a photo line up. During a sworn taped interview, Estated that a cousin of boyfriend and classmate at Ro 1 Palm Beach High School, worked for a wealthy man and did sexual avors for him. She also admitted that had offered her an opportunity to make money. During the beginning of the month of February 2005, xplained that she was first approached bye go with her to Epstein's house. •stated that a ong with a Hispanic female, later identified at pick her up at her father's house on a un ay. was not sure of the exact dates but knew it was a un ay. told her father that they were going shopping but in reality =drove them to Palm Beach. During the drive a e fm egoing 1113 I uifl u Wab anw o to. affirm before me this 1" day of May, 2006 by County of Palm Beach Det , who is personally known to me. Signature of Police Officer (F.S.S. 117.10) Signature/Arresting Officer Date: 05/01/2006 Page of 22 EFTA00230799 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 conversation occurred between and whereas" 'eportedly told Ethat if Jeff asked her age, she should say she was eighteeni,vas later confirmed by the Ms father that picked his daughter up on February 6, 2005. According to Is father, drove a pick up truck. •described Epstein's house as a two-story pink house with a Cadillac Escalade parked in the driveway. She recalled that Jeffs house was on a dead end street. Upon arriving at the house stated that they walked up a driveway, past what appeared to be a small guard/security room. A male approaching them asking what they wanted, IM stated they were there to see Epstein. The male allowed them to continue walking up to the house. tated the man told them that Epstein was not there but was expected back. He allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside. i Shortl thereafter, Epstein and his assistant, described as white female with blond hair and later identified as , entered the kitchen. Epstein introduced himself to . nlescribed Epstein as being approximately forty-five years old, having a long face and bushy eyebrows, with graying hair. _and Epstein left the kitchen leaving Mitlone in the kitchen. They returned a short time later. They all spoke briefly in the kitchen. Mvas instructed to follow upstairs. 'ecalled walking up a flight of stairs, lined with photographs, to a room that had a massage table in it. Upon entering the room there was a large bathroom to the right and a hot pink and green sofa in the room. There was a door on each side of the sofa. Mecalled there, a mural of a naked woman in the room, as well as several photographs of naked women on a shelf. told the victim that Epstein would be up in a second. Epstein entered the room wearing only a towel and told Mto take off her clothes. stated Epstein was stem when he told her to take off her clothes. Maid she did not know what to do as e was the only one there in the room she took off her shirt leaving her bra on. Epstein had removed his towel and told the Eto take off everything. astated Epstein was nude when he took his towel off, placing it on the floor as he laid down on the table. Whited she then removed her pants leaving her thon anties on. Epstein then instructed her to give him a massage pointin to a specific lotion for her to use. As began to give E stein the masse e, he told her to get on his back. tated she straddled herself on Epstein's ack whereby S aid Epstein was specific in his instruction to her on how to massage him, telling her to go clockwise or counter clockwise. Epstein then turned over and instructed.0 massage his chest. vas now standing on the ground and resumed massaging Epstein's chest area. tated Epstein held onto the small of her back as she massaged his chest and shoulder area. Epstein then turn to his side and started to rub his penis in an up and down motion. Epstein then pulled out a purple vibrator and began to The foregoing tests urnent was SWUM lu VI aflII in before me this 1" day of May, 2006 by Det EM, who is personally known to me. of-Florida County of Palm Beach Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230800 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 R IE tated there was no penetration as the Mrecal e pstein ejaculating ecause he had to use the towel to wipe himself as he of off the table. Epstein then left the room and . got dressed. She went back downstairs where she met with Msaid she was paid three hundred ollars in cash from Epstein. Before she left, Epstein asked o leave her phone number. AsMand were leaving the house, latold • she received two hundred dollars that day for bringing her. During the course of the investigation, parental consent was granted for to assist with the investi ation. At our direction conducted controlled taped phone calls to s cellular telephone . lispoke with in an attempt to arrange another meeting wit Epstein. Masked what di she need to do to make more money. gtated, "the more you do, the more you get paid." had subsently called back Nand left a voice mail message for her indicating that she had set up an appointment v for o go to Epstein's house at 11:00 am on April 5, 2005. This message was recorded from mail. Based on the above, trash pulls were established at Epstein's residence with Supervisor Tony Higgins of the Sanitation Bureau of the Town of Palm Beach. The trash pull from April 5, 2005 revealed a telephone message for Epstein which stated and Niname at 11:00 am. This was the time frame Shad informed El to be ready to go work at Epstein's house. On October 3, 2005, Sgt % and I went to il!! residence and viewed her vehicle parked in the driveway, a red Dodge Neon. Sgt. and I knot door and met wia =Sivas told that we were investigating a claim involving Jeffrey Epstein of El Brillo Way, in Palm Beach. _was asked if she would accompany us back to the police station for further questioning. She was also told that at the conclusion of the interview she would be returned home. =voluntarily came with us back to the Palm Beach Police Department. Upon our arrival at the police station, as brought to the interview room in the Detective Bureau where I obtained a taped, sworn statement. I egan e interview by asking 'M'ow she became acquainted with Epstein. en named that approximately two years ago, just after she turned 17 of age, she was approached by a en named et the Canopy Beach Resort in Rivera Beach. was asked if she wanted to make money. She was told she would have to provide a massage and should make $200.00. a hought about the offer and agreed to meet with Jeffrey. I he foregoing Instrument was ffirnied before me this 1" day of May, 2006 by County of Palm Beach Det State of-Florida , who is personally known to me. Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230801 Probable Cause Affidavit Palm Beach Police Department Agency OR1F FLO 500600 nknown last name) and Tony (Unknown last name) picked up and she was taken to Epstein s house. Upon her arrival to the house she was introduced to Epstein in the kitchen of the house. She was also introduced to a white female known to her as She was led upstairs to the main bedroom known to her as Jeff Epstein's bedroom. arranged the massage table and covered the table with a sheet. She brought out the massage oils and laid them next to the massage bed. then left the room and informed Jeff would be in, in a minute. Jeff entered the bedroom wearing only a towel. He removed the towel and laid nude on the massage table. He laid on the table onto his stomach and picked a massage oil for to rub on him. Durin the massage, tated "He tried to touch me and I stopped him." I asked how he tried to touch her. stated thatEpstein and she felt uncomfortable. old Epstein, I'll massage you but I don't want to be touched. tated she performed the massage n ed. At the conclusion of the massage, Epstein paid $200. After the massage Epstein stated toathat he understood she was not comfortable, but he would pay her if she brought over some girls. He told her the younger the better. tated she once tried to bring a 23 year old female and Epstein stated that the female was too old. stated that in total she only remembers six girls that she brought to see Epstein, each time she was paid $200. tated she had brought the following girls: said that at the time she brought these girls to Epstein's house they were a1114 through 16 years of age. I asked-which one was the youngest. _advised was the youngest as she was fourteen when the massage occurred. stated every girl she brought knew what to expect when they arrived. They were told they would provide a e, possibly naked, and allow some touching. I asked her i as aware. She stated every girl she brought knew what to expect. She explained she knew that. want make money. She approached d explained about going to work for Jeff, agreed and arrangements were made to bring her to Epstein's house on a weekend. tated that she and (Later identified as picked up EU her house. tated that at that time she was driving a red pickup truck. They traveled tcatein's house and entered rou the kitchen door. They met with the house chef and Epstein's assistant =. Was introduced to Epstein while they were in the kitchen area. led Elipstairs and Epstein went upstairs. When the massage was over eturned to the kitchen area. stated she was paid $200.00 for bringing .to Epstein's house. tated Mtold her she was paid $300.00 for the massage. dated thatavas the last person she brought to Epstein's house. She had changed her cellular number to avoid being contacted by She continued stating that she had no direct contact with Epstein I tie foregoing instrument was swui u to in -affirmed State of Florida before me this 1" day of May, 2006 by County of Palm Beach Det , who is personally known to me. Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230802 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 when he was going to travel to Palm Beach. aid when Epstein announces to his assistant that he is traveling to Palm Beach, would en contact to arrange girls to "work" for Epstein. stated that once her arents discovered that she was visiting Epstein, they disapproved of the encounters wi and she stopped. further stated that still tries to call house and leaves messages. Sgt entered the room and explained to at based on her own statements, she had implicated herself by bringing underage girls to Epstem's ouse. provided cellular telephone numbers for the girls she had mentioned previously. Additionally, she also provided possible addresses and areas in which they lived. Asians being taken home in the vehicle, a tape recorder was placed within the vehicle to record any conversations within the vehicle. During the drive back to her home, made the comment " I'm like a Heidi Fleiss." (Hollywood Madam who sent girls to clients for sexual favors in California). was dropped off at her house without incident. On October 3, 2005, Sgt and I went to speak with a sixteen year-old female who was brought to Epstein's residence b} We met with other at their front door. We ex ined the ongoing investigation and asked to speak with Mas we had in ormation that she had "worked" for MI Mrs.Mintroduced us to her husband and allowed us entry into the home. We sat in the dining room and met with As she was under the age of eighteen, Mrs ,wasadvised we would be speaking with her. She expresse if her daughter had information, she wanted to assist. We interviewed. who denied having any inappropriate encounters with Jeff (Epstein). She stated she had gone to Jeff's house with pproximately eight months ago and sat in the kitchen with the house chef, but nothing happened. s e p ere present during the interview, we felt that as withholding information from us. She made several comments as to putting the entire incident behind her. eft my tel hone number and advised should she wish to speak with me again to telephone me. Sgt and I thanked Mrs or her time and left the area. She stated she would askliagain after we left as to what happened at Epstein's ouse. I informed her that, had my telephone number and hopefully she would call. On October 4, 2005, Det and I drove to the During a sworn taped statement, when she was seventeen years old, she was taken to a house by because they both attend Royal Palm Beach High School. ome and met with and stated approximately a year ago tated she knows She was told she could make money working before me this 1" day of May, 2006 by Det who is personally known to me. Signature of Police Officer (F.S.S. 117.10) County of Palm Beach Signature/Arresting Officer Date: 05/01/2006 Page of 22 EFTA00230803 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 her clothes on during the masse e. She advised sometime during the massage, Epstein pulled her close to him. said she was uncomfortable b L.xt te incident involving Jeff. At the conclusion of the massage, she was pai .00 for the massage. I asked ME if she has any formal training in massages to which she r lied no. I asked her if received any monies for taking her to perform the massage. stated Ireceived money for taking her there but was unsure in the returned to Epstein's house on another occasion wit d another irl, she waited in the kitchen with while-was taken upstairs by massage once as she was uncom orta le with the whole experience. she was brow t to the kitchen area by They met with the house c of who was already in the kitchen for Jeff. She was told she would have ',vide a massage to Jeff. stated upon her arrival to the house area. tated-would wait for her in the kitchen. was introduced to, Jeff's assistant, who brought her upstairs to the master bedroom. prepared the room and massage table for a massage. Epstein entered the room wearing only a towel and she provided a massage. tated she kept and tated she dated tated s e on y did the At the conclusion of the interview, the tape was stopped. I was informed that had attempted to reachnilvia cell phone. A voice mail messa e on October 4, 2005 at 10:59 am, revealed a female voice who identified herself as who requested o call her back reference the police questionin provided the incoming telephone number as tated she inadvertently told about the police investigation because had called her to iter about how she just received a rental car from Jeff Epstein called her to tell her that she was given a rental car, a 2005 Silver Nissan Sentra, to utilize to visit family stated a visit Epstein. asked her what was oin then called Jeff and on at the house that the police would be asking questions. and asked what was going on reference the ongoing police investigation. Accordin to a has since then been trying to contact her to ask about the police questions. I instructed tot to contact and do not provide any more information ton she would notify Jeff Epstein and On October4, 2005, I made telephone contact with.who had left several messages for me to contact her. During the message, she advised she was not completely truthful when we met in person but would like to speak with me to advise what had happened. She further advised she did not want to speak of this incident in front of her mother. At approximately 3:48 pm I made telephone contact with MI During a taped recorded statement tated the following: approximately a year ago, when she was sixteen years of ageaook her to Epstein s ouse twice. She knows because they both attend Royal Pal Beach High School. The first time she went, lalrove to the house. They entered through the kitchen area where she was what was transpiring. i be foregoing instrument was Satan tv ur affl. tiled before me this 1" day of May, 2006 by County of Palm Beach Oct who is personally known to me. State-of-Florida Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230804 Probable Cause Affidavit Palm Beach Police Department Agency ORD FLO 500600 introduced to and Epstein. She was taken upstairs to a bedroom by who set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for .to rub on him. At one point during the massage he tried to remove her shirt, at which point she became very upset and discontinued the massage. Both d Epstein had a verbal disagreement, at which time she left without being paid. She got with ho was sitting in the kitchen and told her "let's go." Iltdvised she received no money for that day. 'so said that - had told her if she was uncomfortable with what was going on, to let him know and he'll stop. She knew that the more u do the more you get paid. Madvised that several weeks later she agreed to be taken a second time by Once they arrived at the residence,MMEllat in the kitchen and took her upstairs to e mas er bedroom again. set the mom up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and icked out a lotion for to rub on him. At one point during the massage he tried to touch her buttocks. As as wearing tight jeans and had a tight belt on Epstein was unable to touch her buttocks. Epstein then rolled onto his back during the massage and then attempted to touch her breasts. then became upset again and told Epstein she didn't want to be touched. discontinued the massage and was paid $200.00. ',then went downstairs where as waiting for her. She tol he wanted to leavelliaid she never returned to the house. tated she is aware that her frier as also at the house and had a problem with Epstein. I later researched and met with her at her residence. During a sworn taped statement, tated the following: on or about November 2004, she was approached at Royal Palm Beach High School a fellow student. Ilnitsked f she wanted to make money. She agreed and was told she would provide a massage to wealthy man in Palm Beach. _picked her up and drove her to a house in Palm Beach. She was browht into the kitchen area of the house. She further stated that fellow Royal Palm Beach High School student and.......came with them. They were brought into the kitchen where she was introduced to pstein and other females. ;tated she was introduced to a female helper of Epstein, the female was described as white female (unknown name ), with blond hair. She stated that the assistant was familiar with The assistant brought her upstairs into a master bedroom area. The assistant set up the massage table and put out lotions to be used. She told Epstein would be available in a minute. Epstein entered the room wearing only a towel. Epstein removed his towel, and laid naked on the massage table and picked a lotion to nib on his thighs and back. further stated during the massage, Epstein asked her to remove her clothes. Shc complied and removed her pants and blouse. laidn't remember if she had removed her bra but feels that she did. _was certain that she stayed in her thong underwear. ...continued the massage and at one point she climbed onto the massage The foregoing instrument was sworn to or-affirmed before me this 1" day of May, 2006 by Det who is personally known to me. &VP of Florida County of Palm Beach Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230805 Probable Cause Affidavit Palm Beach Police Department Agency ORO FLO 500600 table, straddling Epstein to massage his back. While doing this was instructed to return to the ground at which time Epstein turned to have his chest rubbed. advised she was sure he was masturbating based on his hand movements going up and down on his penis area. aid not want to look at his penis area because she was uncomfortable. Epstein removed a la e white vibrator which was next to the massy e table and turned it on. IMIstated Epstein began . Shortly thereafter, Epstein ejaculated and removed himself from the table. He walked over to where the shower was and opened the glass door. She waited as he was taking a shower in her direct view. When I asked =low old she was when this occurred, she stated she had just turned seventeen. At the conclusion of the shower,—was paid either $350.00 or $400.00. She stated she wasn't sure, but knows it was close to $400.00. stated she never returned to provide a massage for Epstein. At approximately 2:10 pm, Det and I met with at her residence. As g was only seventeen years of age, I had notified her mother, that she would be interviewed reference an ongoing investigation in Palm Beach. I assured her that her daughter was not a suspect. I explained the possibility of her being either a witness or victim. Mrs Madvised she wanted Into cooperate and consented to the interview. During a sworn taped statement, t ated the following: at the age of sixteen, during the month of September 2004, she was approached by or a chance to make money. Was friends with associates ofIMMind knew the same people. had been previously told by her friends from Royal Palm Beach High School, what MMIdid for Epstein. fl ailed a person known togas and scheduled the appointment. 'icked Eup and drove her to Palm Beach to a street called "Brillo Way". They drove to the end of the street and entered a large drivewa . They entered the kitchen area of the house and met with Epstein. -vas introduced to Jeff Epstein. led upstairs to the main bedroom area and set up the room with a massage table and set out the of s. ted that while going up the stairs and into the bedroom she observed numerous photographs of naked young girls.lanuned the lights and turned on soft music. Mix ited the room and Epstein entered the room wearing only a towel. Epstein picked oils and instructed her to ru his legs, under his buttocks, back and chest area. Epstein asked her to get comfortable. advised she did not remove her clothes. She was wearing tight jeans and a cropped tank top exposing her belly area. During the massage, Epstein removed his towel and laid on the massage table naked. As ebbed Epstein's chest area, he attempted to reach down her pants to touch her buttocks area however was unable to due I due to the tightness of the jeans and a tight belt. Advised Epstein began to masturbate as she rubbed his chest. Epstein moaned as she rubbed his chest. She observed he was continuing to masturbate and the loregottig InsRamentwas SW0111 to or a hi State-of Florida before me this 1" day of May, 2006 by County of Palm Beach Det , who is personally known to me. Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230806 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 attempted to reach up her tank top and touch her breasts. tIllt ulled back and Epstein stopped, however he kept masturbating until he climaxed. He cleaned himsel wi the towel he was previously wearing. ll was paid $200.00 for the massage and left the area. She met withMvho was waiting in the kitchen area and left the house. with hen ex lained she never provided another massage for Epstein. She did however, go to the house d s they took another friend of IMMEMiclvised she was present when went to work or Epstein. She advised she rode over and sat in the kitchen area with to wait fo advised while they waited fot=nthe house chef prepared lunch for them as it was almost lunchtime when they went. When Mayas finished with the massa e they left the area. I asked.(.if M ever told her what would be expected when she provided a massage. 'tated yes, told her that a massage would be expected, possibly naked and possibly some touching involved. as no onnal training in providing massages. Spoke about a third and last time she went to Epstein's house. drove another girl, sixteen years of age) who is 'rend, to Epstein's house. 1.1tated knew that made money massaging Epstein and wanted to make money herself. ...took them in the kitchen area of the house and introduced-to . and took Mupstairs to the main bedroom. II advised she doesn't know what happened as i not speak about what happened in the room. Received $100.00 frou or going with her to Epstein's house and recommending On October 6, 2005, at 11:45 am, I met with and explained to her why we there to interview her. She advised she was aware o t e ongoing investigation. stated she had previously spoken with ho told her she was interviewed by detectives. During a sworn taped statement,Mtated she knew a worked for Jeff Epstein in Palm Beach. advised she originally been taken to the Epstein house by whom she met when they both attended Royal Palm Beach High School. She began going to the house when she was sixteen years of age and stated she had been there a lot of times to provide massages over the past two years. I asked her if she had formal training in providing massages, whichatated she had not =advised she was told what was expected of her by providing massages and she would have to remove clothing but if she felt uncomfortable just to say, and Epstein would stop pushing the issue. =began providing massages and advised she kept her clothes on. She considered Epstein a pervert and he kept pushing to go further and further. =explained she would keep telling him she had a boyfriend and would not be right to her boyfriend. It wasn't until recently that Illbegan removing her clothes and staying in her thong underwear to provide a massage. Illexplained The foregoing mstrumen was swo before me this 1" day of May, 2006 by Det who is personally known to me. Signature of Police Officer (F.S.S. 117.10) Florida County of Palm Beach Signature/Arresting Officer Date: 05/01/2006 Page of 22 EFTA00230807 Probable Cause Affidavit Palm Beach Police Department Agency ORI# no 500600 Epstein wanted to be rubbed on his back and recently he began turning over and have her rub his chest as he masturbated. He would try to touch her breasts as she rubbed his chest. stated "Jeff would try to get away with more and more on each massage". need E stein would try to touch her more and on one occasion he attempted to use a massager/vibrator on her. drovelMo the house for the original massage. left her cell phone number and every time stem would come into town, would call her for an appointment to "work". Each time she wen would meet her at the kitchen door area. She would bring her upstairs and r are the massage table. advised E stein would ask herquestions about herself. Epstein knew she was and would be attending . I asked f and Epstein knew her real age stated Epstein did didn't care. The most recent massage she prow w as on October 1, 2005. 12: massage, she asked Epstein if she could borrow one of his vehicles to visit her family and boyfriend in Florida Epstein had told her she could borrow one of his vehicles but later stated he would rent her a car. She continued with the massage as Epstein and . I asked -if she was wearing undergarments to which she replied her thong underwear. Once he tried to touch her breasts, she would pull away from him and he would stop. was asked if he ever used a vibrator on her. Si vas aware of the vibrator but advised she never would allow him to on her. She described the vibrator as the large white vibrator with a huge head on the tip of the vibrator. She stated he kept the vibrator in a closet near the massage table. tatcd that on October 3, 2005, she was contacted by Epstein's assistant, who informed her that E stein had rented her a new Nissan Sentra and she should come by the house to pick it up. informed she would have the car for a month. tated Epstein knew her car was not working properly and that s etbaad missed appointments in the past because of her car being inoperable. explained the car is currently parked next to the Gym field. I asked her if she ever took any one to the house. explained she took friend of hers who attended Royal Palm Beach High School, who has relocated to Orlando to atten co ege. I asked if she ever allowed another female in the room. .dvised no one was brought into the room with her. At the conclusion of the interview, Det and I went to the gym area of and located the Silver Nissan Sentra bearing Florida tag . The vehicle is registered to Dollar Rent a Car out of the Palm Beach International Airport. The vehicle was rented by Janusz Banasiack, later learned to be Epstein's houseman, and paid with Epstein's credit card. On September 11, 2005, w/f was arrested by the Palm Beach Police Department 1 he foregoing Instrument was sworn to or affil med before me this 1" day of May, 2006 by Det EM, who is personally known to me. State of Florida County of Palm Beach Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230808 Probable Cause Affidavit Palm Beach Police Department Agency ORI# PLO 500600 for misdemeanor possession of marijuana. During the arrest Mtold the arresting officer that she had information about sexual activity taking place at the residence of Jeffrey Epstein. Additionally, during the ongoing trash pulls from Epstein's residence, discarded papers were found which contained M name and cell phone number. On October, 11, 2005, Det IIIL and I met with Nand obtained a sworn taped statement. explained she had been going to Epstein s ouse since 2002, when she was sixteen years of age. Since t en she has gone to the house hundreds of times. Elstated she became his "number one girl." She explained that on her first visit she was brought to the house by fellow Royal Palm Beach High School classmate, said she was brought through the kitchen area where she met . for the first time! aa l lsill t e master bedroom, Epstein s room. explained that as she was walking up the stairs she observed several photographs of naked women aloag the walls and tables of the house. further explained that she was brought into the bedroom, where = prepared the room by setting up the massage table and provided the oils for her to rub on Epstein. -xplained she remembered the steam room area, which contained two large showers. Epstein entered the room from the steam room area and introduced himself. Epstein lay on the table and told her to get comfortable. emoved her skirt and kept her shirt on. Epstein then instructed her to remove her shirt. ',removed hers in and remembered she was not wearing a bra. ted she provided the massage wearing only her anties. She continued rubbing his legs, thighs and feet a d vised he turned over onto his back. Epstein and began to masturbate. Epstein ejaculated which meant the masse e was over. At the conclusion of the massage, as paid $200.00. They walked together downstairs where and were waiting. stated Mreceived an unknown amount of money for taking her to Epstein. Epstein instructed to leave her cellular telephone number, that he could contact her when he is in town. Mtated that during her many visits a routine was established between her and Epstein. She would enter the house and get naked in the bedroom. She would then start with a back massage. Epstein would roll on to his back and allow her to massage his chest area. tated Epstein would then began to masturbate himself and at the same time would insert .xplained Epstein would continue this process until he ejaculated. He would then utilize a . Madvised that during her frequent visits, E stein asked for her real age, stated she was sixteen. would instruct and pay e. advised that thin s escalated w the home as Epstein , . xplained the Epstein advised her not to tell an one her real a intercourse included using stra on dildos, large rubber penis' and other devices that Epstein ad at his disposal. Epstein would watch them and masturbate himself . Occasionally, Epstein would then join in I he foregoing instrument was swot o to or afftr med before me this 1" day of May, 2006 by Det who is personally known to me. State of flori County of Palm Beacb Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230809 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 during the f male on female intercourse and provide oral sex to both. and This occurred during the time as sixteen years of age. vised this continued to escalate during two years. The routine became familiar to Epstein's assistant would telephone her every time Epstein was in the Town of Palm Beach and would place appointments for her to visit and work for Epstein. Each time something new was introduced, additional monies were produced and offered for■ to allow the acts to happen. :onsented to perform all these acts but was adamant that there was an understanding with Epstein that no vaginal penetration would occur explained that Epstein's penis was deformed. explained that his penis was oval shaped. aimed when ■ Epstein's penis was erect, it was thick toward the bottom but was thin and small toward the hea called E stein's penis "egg-shaped." Estated Epstein would photo aph and her and proudly display the photographs within the home. ated during one visit to Epstein's house in which she provided a massage to E stein, his female friend and her would l provided the massage in which so enjoy. Towards the end of this massage, Epstein grabbed massage table and forcibly became upset over this. She said her head was , as he continued . She screamed "No!" and Epstein stopped. She told him that she did not want to Epstein did not ejaculate inside of her and apologized for his actions and subsequently paid her a thousand dollars for that visit. tated she knows he still displays her photographs through out the house. was a resent. for Epstein to d turned her over onto her stomach on the stated Epstein began to On October 12, 2005, Det and I met wi who stated during a sworn taped statement, that nothing happened between her an Epstein. appeare nervous during the interview. I assured her that I have spoken with other people who advised differently. stated on several occasions she provided a massage to Epstein. She stated she was brought to the Epstein house in March of 2005. classmate at Royal Palm BeachEa School, approached her and asked her if she wanted to "work". ade the arrangements with =, Epstein's assistant. ho has no formal training in providing massages, stated she provided a massage, fully clothed for $2 . . I sensed hesitancy in her answers, I asked .1 f she had been contacted by anyone from Epstein's organizations or his house. tated she was interviewed already by a private investigator for E stein. He identified himself as 'IM" 0inan wired about the police investigation, and left his telephone number f rovided no additional information, as it appeared her responses were almost seri; for additional contact. the foregoing instrument was sworn to or-af II use before me this 1" day of May, 2006 by County of Palm Beach Det who is personally known to me. 1-Flori Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230810 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 On November 6, 2005, at approximately 3:30 pm, I met with at the Palm Beach Police Department. as identified as a potential witness/victim ou m onnation obtained during the trash pulls. urm sworn taped statemenadvised she was at Jeffrey Epstein's house one time, approximately two months ago. She was approached by a girl ho was dating a oommate, for an opportunity to make some quick money. =lavis s e n ed to make some quick cash to make the rent that month. She agreed to go to the house. She had been told by at the massage would have to be done in her underwear. She advis rove with her and brow t er into the house. They walked into the kitchen area, and took the stairs upstairs. further stated she was brought into a master bedroom area. She advised she recalled seeing portraits o n women throughout the room. A massage table was already out near the sauna/shower area in the master bedroom. Epstein entered the room wearing only a towel and introduced himself as "Jeff." At Epstein's direction, =and removed their clothing down to their panties, Epstein laid on his stomach area and they provided a massage on s legs and feet area. I askeaf she had any formal massage training and she replied "no." advised she was topless and the panties she wore were the boy shorts lace panties. She andeontinued the massage until the last ten minutes of the massage, Epstein, told ao leave the room, that could finish the massage. got dressed, and left the room as Epstein turned over onto his back. Epstein then removed the towel and _stated , Epstein, began masturbating. tated Epsteinli pulled his chest down her boy short panties, and he produced a lar e white vibrator a naked . E stein requested that area. with a lar e head. She stated it was within his reach in a drawer in his master bathroom. He vised he never with the vibrator. He continued to as e continued to masturbate. tated she was very uncomfortable during the incident but knew it was almost over. Epstein climaxed and started to remove himself from the table. He wiped himself with the towel he had on previously and went into the shower area. got dressed and met with the kitchen area. Epstein came into the kitchen and provided 200.00 for bringing and pai 00.00 to for providing the massage. lavas told to leave her telephone number with for future contact. provided her cellular telephone number. was asked if she was recently contacted about this investigation by an one from the Epstein organization. She replied she was called but it was for work. She stated she was called by for her to return to "work" for Epstein. tated "work" is the term used by to provide the massages and other things. 'dvised she ec ine as she was not comfortable in providing that type of "work." On November 7, 2005, Det and I met with uring a sworn taped statement, stated she met Jeffrey Epstein through when they were still 'Mr worn to-or-affirmed before me this 1" day of May, 2006 by Det who is personally known to me. State of Florida County of Palm Beach Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230811 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 attending Royal Palm Beach High School. would approach females who wished to work for Epstein. tated she was offered to work for Epstein but declined. explained that "work" means ive massages. She was asked about any formal training in providing massages which she said "no." said she accompanied aid other females who were taken to Epstein's house to provide massages. further stated she had been to the house a roximately 4 or 5 times in the past year. She accompani with Each time the girls were taken over, they were previously told they would have to prow e a massage, posse y naked. They were also told that should Epstein require them to do anything extra, and they were not comfortable just to tell him and he would stop. statedlMireceived $200.00 for each girl she brought over to massage Jeffrey Epstein. When I asked which girl appeared to be the youngest, she replied, ho was really young, fifteen years old at the most. further stated each time she went to the house, she sat in the kitchen and waited with until the massage was over. She further stated that the cook would make lunch or a snack for them as they waited. I asked her if there was anything that caught her attention within the home. stated there were a lot of naked girls in photographs throughout the house. On November 8, 2005, at approximately 2:00pm , I met with t the Palm Beach Police Department. During a sworn taped statement, stated she had met Epstein approximately two years ago when she was first approached b classmate at Royal Palm Beach High School. _approached her about working for Epstein and providing a massage to him for $200.00. ad made the arrangements however was unable to take her the day the arrangements were made. ad ake also attended Royal Palm Beach High School and was familiar wi pstein. ecalled s e was row it there and entered through the back kitchen door. She had met with an assistant and another assistant brought her upstairs as she observed several photographs of naked females throw out the house. stated Epstein came in the room, wearing only a towel, and laid on the table. tated he picked out the oils he wanted her to use and requested she iemove her clothing toprovide the massage. stated that on the first massage she provided she did not remove her clothing. tated she had returned several times after that. Each time she returned it was more than a massage. Epstein would walk into the master bedroom/bathroom area wearing only a towel. He would masturbate as she provided a massage. stated she was unsure if he climaxed as he masturbated under the towel. Additionally, she never looked below his waist. She claimed that Epstein would convince her to remove her clothes. She eventually removed her clothes and stayed in her thong panties. On occasion,ign would use a massa er/vibrator, which she described as white in color and a large head. Epstein would as he would masturbate. Stated she had been to the house The g og instrvuieot Nit:Ismaili-to-or-affirmed before me this 1" day of May, 2006 by County of Palm Beach Det who is personally known to me. State-of Florida Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230812 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 numerous times. Maidded she has no form in providing a massage. aced she brought two female's during her visits to provide massages. tated she brought a girl nam Militom Royal Palm Beach High School. tated she received $200.00 for eac girl s e rou . On November 8, 2005, I met with at the Palm Beach Police Department. During a sworn taped statement, stated she had met Jeffrey Epstein approximately one year ago. She was approached by a subject known to her as aad asked her if she wanted to make money providing massages to Epstein. had heard that several girls from Ro I Palm Beach High School were doing this and making money. She agreed and was taken to the house by introduced her to and Epstein and brought her upstairs to a master bedroom where a massage to e was prepared and the proper oils were selected. eft the room and waited downstairs for her. -stated Epstein entered the room wearing a towel and laid on his stomach. She provided a massage wearing only her thong panties. advised Epstein had masturbated every time she provided a massage. She stated Epstein continued to masturbate until he climaxed. Once that occurred the massage was over. She felt the whole situation was weird but she advised she was aid $200.00 for providing the massage. She also stated Novas paid $200.00 by Epstein for bringing fated she had gone a total of 15 times to Epstein s residence to provide a massage and things had escalated from just providing a masse e. E stein be an touchin grabbed her closer to him as he masturbated. Epstein also and and with his hands as she provided the massage. ated on one occasion, while she was only seventeen years of age, he offered extra monies to have va • al intercourse. She stated this all occurred on the massage table. stated Epstein and be an until he reached the point of climax. Epstein removed and climaxed onto the massage table. i eceived $350.00 for her massage. I asked her if she had any formal training in providing massages, ted she did not. ontinued to state on one other occasion, Epstein introduced his girlfriend, into the massa e. was brought into room with to provide a massage. Epstein had them ey provided a massage to Epstein. Epstein, watched and masturbated as this occurred. On other occasions E stein, introduced the large white vibrator/massager in the massage. Epstein as she provided the massage. On November 14, 2005, Det and I met with During a sworn taped statement she advised she started going to the house approximately one year ago and has been there approximately five or six times lso stated she was sixteen years old when she first went to Epstein's house. On her first visit she was ou by a fellow student from Royal Palm Beach High School known to her The foregoing instrument was sworn to or Sib wed before me this l m day of May, 2006 by Det EM, who is personally known to me. State of Florida County of Palm Beach Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230813 Probable Cause Affidavit Palm Beach Police Department Agency O1110 FLO 500600 tated Mil brought her into the house and she was introduced to then brou ter upstairs into a master athroom, located within the bedroom. stated she met Epstein in the bathroom. He laid on the table and picked the massage oils. She provided the massage as he laid naked on the massage bed. She stated she rubbed his calves and back area. Upon the end of the massage, Epstein removed himself from the massage table and paid her $300.00 for the massage. -aid each subsequent time she went to the house, she was notified by that Epstein was in town and would like her to "work". ated she returned to the house and was again led upstairs by . She provided the massage, clothed. ;as asked if she ever removed her clothing toprovide a massage. -tated it was not until theta at she went that she removed her clothing. tated she d by that Epstein wanted her to come to work. She arrived at the house an was led u stairs by She started providing the massage when Epstein asked her to remove her clothing. removed her pants, shirt and bra. She staved in her thong anties and Epstein turned over onto his back and she tated she knew he was masturbating himself as she providing the massage. tated she believed he climaxed based on his breathing. She did not want to view either the climax or t e act t at he was masturbating. stated once the breathing relaxed he got up and told her to get dressed. She was paid $300.00 for her services. tated on the last time she went to provide a massage, she was notified by to come to the house and "work". tated she was now dating her current boyfriend and did not feel comfortable going. She recalled it was approximately January 2005. She said she went, already thinking that this would be the last time. She went upstairs and went into the master bathroom. She met with Epstein, who was wearing only a towel, and laid onto the table. Mstated Epstein caught her looking at the clock on several occasions. Epstein asked her if she was in a hurry. stated her boyfriend was in the car waiting for her. enjoying the massage. She told him that she didn' to leave as she was mining his massage. pm stated , although she had a falling out sin Epstein, she still received a Christmas bonus from Epstein. stated she was wired money from Western Union for her Christmas bonus. Subpoena results from es ern nion revealed money was sent from Jeffrey Epstein on December 23, 2004. received $200.00 from Epstein for her Christmas bonus. er stated that Epstein got upset as he wasn't ntinue and she would not be back. Epstein told her wised she had no formal training in providing any massages. On November 15, 2005, Det. and I met wi During a sworn taped statement, tated she met Jeffrey Epstein over a year ago. She was sixteen years of age and was approach y fellow Royal Palm Beach High School student, who informed her that she could make $200.00 providing a massage to Epstein. had informed her that she would have to provide this egoinginsh awueut nab bill u to oI a :. State-of-Florida before me this 1" day of May, 2006 by County of Palm Beach Det who is personally known to me. Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230814 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 massage topless. made the arrangements with Epstein and his assistants and took Mio the house. stated end she entered through a glass door that led into a kitchen. She was taken upstairs by master bedroom. She recalled the master bathroom had a large pink couch, sauna and matching shower. Epstein entered into the room wearing only a towel. Eand=removed their clothing remaining only in thong underwear. She further stated that Epstein laid on his chest on the table. The oils were selected on which ones to use. Both aand■provided the massage on his legs, back and feet. Forty minutes into the massage, Epstein turned over onto his back and requested wait downstairs in the kitchen area for Epstein instructed ao finish the massage. As of dressed, tartin rubbing Epstein's chest. left the room, and Epstein began masturbating as . tated Epstein continued masturbating until he climaxed on the towel he was wearing. When asked if he ha removed the towel she stated he turned the towel around, that the opening would allow him to expose himself. After he cleaned himself off with the towel he instructed the massage was done and to get dressed and meet with him downstairs. got dressed and met with Epstein in the kitchen area. She was paid $200.00 dollars for providing the massage. stated she was aware that so received monies for the same thing. The second time she went to the house she was again approached b advised if she wanted to return to the house to vide another massage. agreed and the arrangements were made byEEfor her to return to the house. tated drove her to the house and knocked on the same glass door which leads to the kitchen area. They were allowed entry into the house by one of the staff members. led her upstairs to the master bedroom and master bathroom area. left E this time to do the massage alone. Epstein entered the room again wearing only a towel. Megan removing her clothing as she did the last time she was at the house. Epstein instructed her to get naked. He laid on the table onto his stomach as ',began massaging his legs and back. As Ininished with Epstein's back and legs, Epstein then turned over onto his back. started to rub his chest and he began masturbating. As bbed his chest, Epstein leaned over and produced a massager/vibrator. He turned it on and began rubbing gina and masturbating himself at the same time. al stated she as this was occurring. She described the vibrator/massager as large grey with a large head. Epstein for approximately two to three minutes with the massager/vibrator. He then removed the and concentrated on masturbating himself. Mated Epstein climaxed onto the got dressed and met with who was waiting id she never returned to the house and had no formal massage training. She advised she had tated he knew, as he asked her questions towel again and informed her that the massage was done. in the kitchen area. She received $200.00 for the massage. desire to return to the house. was asked if she received an no formal training. Was asked if Epstein knew her real age. about herself and high school. He was aware she attended, and is still attending Royal Palm Beach High School. I he foregoing Instr u e ref-firmed before me this 1" day of May, 2006 by County of Palm Beach Det IMM, who is personally known to me. State or Fig-trifle Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230815 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 During the course of the investigation a search warrant was executed at Jeffrey Epstein's home located at 358 El Brillo Way in Palm Beach. While in the home I observed the pink and green couch within the master bedroom area just as the girls previously mentioned. The stairway, which is located from the kitchen area to the master bedroom area, is lined with photos of naked young girls. Additionally, numerous photographs of naked young females, some of which appeared to be the girls I previously interviewed, were on display throughout the house. Also located in the house were various phone message books. The telephone message books have a duplicate copy (Carbon Copy) which, once a phone message is written into the book, the top copy is then torn on the perforated edge and the carbon copy is left in the book. First names of girls, dates and telephone numbers were on the copy of the messages. I recognized various numbers and names of girls that had already been interviewed. The body of the messages were time of the day that they called for confirmation of "work." Other names and telephone numbers were located in which the bod of the messages were, "I have girls for him" or "I have 2 girls for him." These messages were taken by , who signed the bottom of the messages. During the execution of the warrant, I located a Royal Palm Beach High School transcript for■n Epstein's bedroom desk. This desk had stationary marked Jeffrey E Epstein. I located a wood colored armoire beside Epstein's bed that contained a bottle of "Joy Jelly," which is used to provide a warm massage. Several massage tables were located throughout the second floor of the residence, including a massage table found in Epstein's bedroom. On the first floor of the residence I found two covert cameras hidden within clocks. One was located in the garage and the other located in the library area on a shelf behind Epstein's desk. A computer was located which was believed to contain the ima es from the covert cameras. The computer's hard drive was reviewed which showed several images o d other witnesses that have been interviewed. All of these images appeared to come from the camera positioned behind Epstein's desk. On December 13, 2005, Det. and I met with During a sworn taped statement,Mstated that when she was sixteen years old she was taken to Epstein's house to provide a massage for money. Entated it was before Christmas last year (2004) when an associate, li tapproached her and asked if she needed to make money for Christmas. arrangements to take o the house and drove ■to the house to "work." They were encounter y a white female with long blond hair. as unable to remember the name of the white female with blond hair but knew she was Epstein's assistant. S e was led upstairs by the white female who explained that there would be lotions out already and Epstein would choose the lotion he wanted her to use. She was led through a spiral staircase which led to a master bedroom and bathroom. The massage table was already set up in the bathroom...described the bathroom as a large spacious bathroom with a steam mom and shower beside it. IN was introduced to Epstein who was on the phone when she entered the room. Epstein was wearing a white towel and laid on his stomach I that may ne foregoing lost u went worn-to-or affirmed State of Florida before me this 1" day of May, 2006 by County of Palm Beach Det , who is personally known to me. Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230816 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 massage his feet and calves. Mstarted the massage with the oils Epstein chose and rubbed his feet and calves. Epstein got off the phone and requested she massage his back as well. Megan rubbing his back and got to the small of his back. Duriniie rubbing of his back, Epstein asked her to get comfortable. He requested she re move her pants and shirt. t moved her shirt and pulled her pants off stayed in her bra and thong panties. As she finished massaging the small of Epstein's back, he then turned onto his back. Epstein instructed IIII.o rub his chest and pinch his nipples. As she , Epstein asked her questions about herself. remembered telling him she attended Royal Palm Beach High School. Epstein asked her if she was sexually active. BeforeMcould answer, he also asked what sexualposition does she enjoy. stated she was shy and didn't like talking about those things. She continued . Epstein reached u and unsn ed her bra from the front. •xplained the bra she used had a front snapping device. Epstein and asked her if she like having . aid "no, I don't like that." Epstein then removed his towel and laid on the bed naked exposing his penis to He be an touching his enis and masturbated as he -explained Epstein then touched ensed up and stated Epstein was aware that she was uncomfortable. stated that Epstein said to her, "Relax, I'm not going inside." She further explained Epstein commented to her how beautiful and sexy she was. Epstein then moved her thong panties to one side and began —aid, "He commented how ." He then . She tried pulling back to . Epstein and aooloeized for MOtime, he kept his stated he as he was masturbating. aid he climaxed onto the towel he had been previously wearing and got up from the table. Epstein told her there was $200.00 dollars for her on the dresser within the master bathroom. Epstein also told her that there was an additional $100.00 that was to be given toilfor bringing her there to massage him. Epstein told her to leave her telephone number with his assistant as he wanted to see her again. Epstein stated his assistant would contact her to work again soon. I asked her if she ever received any formal massage training to which Mstated she did not. -tated it was the only time she ever went to work for Jeff and knew what happened to her was wrong. She further stated that she had never been contacted for any additional work. On January 9, 2006, I located and interviewed another victim, as identified as a potential victim/witness from information obtained during trash pulls from Epstein's residence. Mtated she met Epstein when she was fifteen years of age. She was approached by a friend from Royal Palm Beach High Schoolao be taken to Jeffrey Epstein's house to work. She was originally told she would be able ----The-toregeing-instritniont was sworn *9 or affirmed before me this 1" day of May, 2006 by Det who is personally known to me. State of Flnrida County of Palm Beach Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230817 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 to model linglrie for a wealthy Palm Beecher. vas taken to Epstein's house located on El BrilloWay. introduced.to Jeffrey Epstein. Epstein had his personal chef prepare dinner fond At the conclusion of dinner,and Epstein broughtMpstairs into a master bedroom area. •bserved a large massage table with a sheet on it. Epstein entered through a door and exited wearing only a towel. informed that they were oing to provide a massage on Epstein.=isked why were they doing this instead of modeling lingerie. xplaincd to. that this was his routine and to rub his calves and feet. Epstein had toketo get comfortable. removed her pants and blouse. Mtated she stayed only in panties as she did • not wear a bra that evening. stated while rubbin his calves and feet, Epstein turned over onto his back. Epstein told Etc rub his chest and nib his ni les. tated that as she started Epstein began masturbating himself . Epstein and with his fingers. E stein continued to masturbate himself as he . Epstein ejaculated on his towel and paid .$200.00 for the massage. ii: toldnhat if she told anyone what happened at his house that bad things could happen. d ere brought home by Epstein's houseman and Ewes afraid that Epstein knew where she lived. stated that several days later she received a telephone call from who nated for Etc, return to "work." Mretumed to the house and was brought to Epstein's bedroom area by who prepared the room for the massage. Epstein entered the room wearing only a towel. Epstein ha move her clothing and provide the massage naked. e an rubbing his feet and calves and Epstein turned over onto his back. Epstein downward motion on his penis. Epstein continuedE stein be to masturbate himself with an upwards and with one hand and masturbate with the other hand. Once Epstein ejaculated onto the towel he was wearing, the massage was over. Elwas paid $200.00 for the massage. Epstein again told.not to speak of what happened at his house or bad things would happen. Mvanted to notify authorities however she was afraid of what would happen to either her or her family. During the course of the investigation, several subjects were identified as a potential witness/victim through information obtained during the trash pulls, physical surveillance and telephone message books retrieved from the search warrant. While conducting research on the subjects, I discovered that the females were age eighteen or older. Interviews were conducted on the consenting adults whose statements provided the same massage routine when they went to "work" for Epstein. The females would be notified by , and made appointments for the females to "work" for Epstein. The females would come to Epstein's house and were led upstairs, through a stairwell from the kitchen area, by to Epstein's bedroom. Epstein would then enter the mom wearing only a towel, and ask them to et comfortable. The females would then provide the massage naked as Epstein would either and/or utilize the massager/vibrator on The-foregoing-instrument-was-sworn-to-or-affir-med before me this 1" day of May, 2006 by Det who is personally known to me. State of Florida County of Palm Beach Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230818 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 . He would masturbate dining the massage and upon his climaxing, the massage would end. The girls were then paid two or three hundred dollars for the massage. On November 21, 2005 I interviewed Jose Alessi, a former houseman for Jeffrey Epstein. Alessi stated he was employed for eleven years with Mr. Epstein, from approximately 1993 through 2004. Alessi stated he was the house manager, driver and house maintenance person. It was his responsibility to prepare the house for Epstein s arrival. When asked about cooks or assistants, Alessi stated they traveled with Epstein on his private plane. I asked Mr. Alessi about the massages that have occurred at Epstein's home. Alessi stated Epstein receives three massages a day. Each masseuse that visited the house was different. Alessi stated that towards the end of his employment, the masseuses were younger and younger. When asked how young, Mr. Alessi stated they appeared to be sixteen or seventeen years of age at the most. The massages would occur in Epstein's bedroom or bathroom. He knew this because he often set up the massage tables. I asked if there were things going on other than a massage. Alessi stated that there were times towards the end of his employment that he would have to wash off a massager/vibrator and a long rubber penis, which were in the sink after the massage. Additionally, he stated the bed would almost always have to be made after the massage. On January 4, 2006 I interviewed another former houseman, Mr Alfredo Rodriguez. During a sworn taped statement, Mr. Rodriguez stated he was employed by Jeffrey Epstein for approximately six months, from November 2004 through May of 2005. His responsibilities as house manager included being the butler, chauffeur, chef, houseman, run errands for Epstein and provide for Epstein's guests. I asked Rodriguez about masseuses coming to the house. Rodriguez stated Epstein would have two massages a day. Epstein would have one massage in the morning and one massage in the afternoon everyday he was in residence. Rodriguez stated he would be informed to expect someone and make them comfortable until either or Epstein would meet with them. Rodriguez stated once the masseuses would arrive, he would allow them en into the kitchen area and offer them something to drink or eat. They would then be encountered by either or Epstein. They would be taken upstairs to provide the massage. I asked Rodriguez if any of the masseuses appeared young in age. Rodriguez stated the girls that would come appeared to be too young to be masseuses. He stated one time under Epstein's direction, he delivered a dozen roses to Royal Palm Beach High School for one of the girls that came to provide a massage. He knew the girls were still in high school and were of high school age. I asked Rodriguez about the massages. He felt there was a lot more going on than just massages. He would often clean Mr. Epstein's bedroom after the alleged massages and would discover massagers/vibrators and sex toys scattered on the floor. He also said he would wipe down the vibrators and sex toys and put them away in an armoire. He described the armoire as a small wood armoire which was on the wall close to Epstein's g g fiStritinent -Was-SWern-te-Oraffinned State of Florida before me this 1" day of May, 2006 by County of Palm Beach Det , who is personally known to me. Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230819 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 bed. On one occasion E stein ordered Rodriguez to go to the Dollar rent a car and rent a car for the same girl he brought the roses to, that she could drive her self to Epstein's house without incident. Rodriguez said the girl always needed rides to and from the house. Rodriguez produced a green folder which contained documents, and a note with Mr. Epstein's stationary with direction to deliver a bucket of roses to Royal Palm Beach High School after Ehigh school drama performance. Also in that same note was direction to rent a car for and direction to extend the rental contract. During the course of the investigation, subpoenas were obtained for cell hone and home phone records from several victims and witnesses along with the cell phone records of An anal is of these records was conducted which found numerous telephone calls were made between and the victims. These records indicate the dates the calls were made are consistent with the dates and times they victims/witnesses stated they were contacted. Specifically, The phone records showed called uring the exact times and dat w occurred. also coordinated t e encounters with uring the time frame the girls stated they occurred. Pursuant to a lawful subpoena I obtained Epstein's private plane records for 2005 from Jet Aviation. The plane records show arrival and departure of Epstein's lane at Palm Beach International airport. These records were corncompared to the cell phone records of This comparison found that all the phone calls made to d the victims were made in the days just prior to their arrival or during the time Epstein was in Palm Beac . Therefore, as Jeffrey Epstein, who at the time of these incidents was fift one years of age, did have vaginal intercourse either with his penis or digitally with who were minors at the time this occurred, there is sufficient probable cause to charge le y Epstein with four counts of Unlawful Sexual Activity with a Minor, in violation of Florida State Statute 794.05(1), a second degree felony. As Epstein, who at the time of the incident was fifty two years of age, did use a vibrator on the external vaginal area of MI fourteen year old minor, there is sufficient probable cause to charge him with Lewd and Lascivious Molestation, in violation of Florida State Statute 800.04 (5), a second degree felony. The foregoing-instrument-was-aworn-te-er-affirm before me this 1" day of May, 2006 by Det EM, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) lid County of Palm Beach Signature/Arresting Officer Date: 05/01/2006 Page of 22 EFTA00230820 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 Police Case*: 05-368 (2) Defendant: - Race/Sex: White Female DOB: Charges: Principal in the 1" Unlawful Sexual Activity with a Minor (4) counts Principal in the I" Lewd and Lascivious Molestation (1) count From March 15, 2005, through February 2006, the Palm Beach Police De ent conducted a sexual battery investigation involving Jeffrey Epstein, and Sworn taped statements were taken from five victims and seventeen witnesses concerning massages and unlawful sexual activity that took place at the residence of Jeffrey Epstein, 358 El Brillo Way, Palm Beach. Several of the victims were recruited by and brought to the residence by perform massages for E stein for which eceived monetary compensation. During t e visit ey would be introduced to Epstein's assistant, who in turn would record their telephone numbers and name. The victims would be brought to Epstein's bedroom to provide the massage. Epstein would enter the room and order the" victims to remove their clothing to provide the massage. As the victims complied and provided the massages, Epstein would introduce a massager/vibrator and as they provided the massage. On three separate occasions, Epstein had intercourse and inserted his penis/fingers in the victims vaginas. At the conclusion of the massages the victims were paid sums of money ranging from $200 - $1,000. The facts, as reported, are as follows: On occasion, Epstein would On 03/15/2005, A fourteen year old white female, hereinafter referred to as and her famil reported unlawful sexual activity which occurred at a residence within the Town of Palm Beach. ported that a subject known to her as "Jeff' had touched her vaginal area with a vibrator massager while within his residence. "Jeff' was later identified as Jeffrey Epstein through a photo line up. During a sworn taped interview, Mated that cousin of.. boyfriend and classmate at Royal Pal mit igh Sc , d did sexual favors for him. She also admitted that offered her an opportunity to make mone . During the beginning of the month of February xplained that she was first approached by go with her to E stein's house. ntated that long with a Hispanic female, later identified at pick hens at her father's house on a Sunday. as not sure of the exact dates but knew it was a Sunday. = told her father that they were going shopping but in reality ove them to Palm Beach. During the drive a conversation occurred between ad hereas The foregoing instrument-was sworn-to-or-affwmed State of Florida before me this I' day of May, 2006 by County of Palm Beach Det , who is personally known to me. Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230821 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 a reportedl toldWhat if Jeff asked her age, she should say she was eighteen. It was later confirmed by the father at _picked his daughter up on February 6, 2005. According toMather, ove a pick up truck. described Epstein's house as a two-story pink house with a Cadillac Escalade parked in the driveway. She recalled that Jeffs house was on a dead end street. Upon arriving at the houseatated that they walked up a driveway, past what ap ed to be a small guard/security room. A male approaching them asking what they wanted. fated they were there to see Epstein. The male allowed them to continue walking up to the house. ted the man told them that Epstein was not there but was expected back. He allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside. Shortly thereafter, Epstein and his assistant, described as white female with blond hair and later identified as , entered the kitchen. Epstein introduced himself to Mdescribed Epstein as being approximately forty-five years old, having a long face and bushy eyebrows, with graying hair. d Epstein left the kitchen leavingnione in the kitch y returned a short time later. !Woke briefly in the kitchen. Mwas instructed to follow upstairs. •recalled walking up a flight of stairs, lined with photographs, to a room that had a massage table in it. Upon entering the room there was a large bathroom to the right and a hot pink and green sofa in the room. There was a door on each side of the sofa. Mrecallecl there. a mural of a naked woman in the room, as well as several photographs of naked women on a shelf. told the victim that Epstein would be up in a second. Epstein entered the room wearing only a towel and told o take off her clothes. stated Epstein was stern when he told her to take off her clothes. she did not know what to do as she was the only one there in the room, she took off her shirt eaving her bra on. Epstein had removed his towel and told theNto take off everything. 'Stated Epstein was nude when he took his towel off, placing it on the floor as he laid down on the table. Mistated she then removed her pants leaving her thong panties on. Epstein then instructed her to give him a massage pointing to a specific lotion for her to use. AsWegan to give Epstein the mass e he told her to et on his back. ted she straddled herself on Epstein's back whereby . said Epstein was specific in his instruction to her on how to masse e him, telling her to go clockwise or counter clockwise. Epstein then turned over and instructed o masse chest. Moms now standing on the ground and resumed massaging Epstein's c est area. fated Epstein held onto the small of her back as she massaged his chest and shoulder area. Epstein then turned to his side and started to rub his penis in an up and down motion. Epstein then pulled out a purple vibrator ana The foregoing-instrument was sworn to-o-raffirmed State or r lorlda before me this P day of May, 2006 by County of Palm Beach Det , who is personally known to me. Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230822 Probable Cause Affidavit Palm Beach Police Department Agency OFt111 FLO 500600 . stated there was no penetration as the called Epstein ejaculating because he had to use the towel to wipe himself as he got off the table. E stein then left the room an' got dressed. She went back downstairs where she met with d she was paid three hundred dollars in cash from Epstein. Before shifi, E stein asked cave er phone number. As ere leaving the house, old. she received two hundred dollars that ay or ringing er. During the course of the investigation, parental consent was granted for o assist with the investigation. At our directionaconducted controlled taped phone calls to llular t 561 poke with an an attempt to arras e another meeting with Epstein. asked i phone e need to do to make more mc, ated, "the more you do, the more you get par . 'ad subsequentlycalled back left a voice mail message for her indicating that she had set up an appointment for o go to Epstein's house at 11:00 am on April 5, 2005. This message was recorded fro oice mail. Based on the above, trash pulls were established at Epstein's residence with Supervisor Tony Higgins of the Sanitation Bureau of the Town of Palm Beach. The trash pull from April 5, 2005 revealed 'S ie message foirstein which stated=md name at 11:00 am. This was the time frame ad informed to be ready to go work at Epstein's house. On October 3, 2005, Sgt and I went tsz residence and viewed her vehicle parked in the driveway, a red Dodge Neon. Sgt. and I knocked on the door and met with was told that we were investigating a claim involving Jeffrey Epstein of El Brillo Way, in Palm Beach. as asked if she would accompany us back to the police station for further questioning. She was also told that at the conclusion of the interview she would be returned home. voluntarily came with us back to the Palm Beach Police Department. Upon our arrival at the police stationMwas brought to the interview room in the Detective Bureau where I obtained a taped, sworn statement. I began the interview by asking=Elow she became acquainted with Epstein. Mstated that approximately two years ago, just after she turned 17 years of age, she was approached by a friend named t the Canopy Beach Resort in Rivera Beach. !Was asked if she wanted to make money. S e was told she would have to provide a massage and ake $200.00. Mhought about the offer and agreed to meet with Jeffrey. Unknown last name) and Tony (Unknown last name) picked 'p and she was taken to Epstein s ouse. Upon her arrival to the house she was introduced to Eps m m e kitchen of the TIre-foregoing-instrumenrwas-sworn to or affirmed before me this 1" day of May, 2006 by Det , who is personally known to me. Srate of Flortdr County of Palm Beach Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230823 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 house. She was also introduced to a white female known to her as . She was led upstairs to the main bedroom known to her as Jeff Epstein's bedroom. arranged the massage table and covered the table with a sheet. She brought out the massage oils and laid them next to the massage bed. M, then left the room and informed IN would be in, in a minute. •entered the bedroom wearing only a towel. He removed the towel and laid nude on the massage table. He laid on the table onto his stomach and picked a massage oil for a rub on him. burin mgif sage, ted "He tried to touch me and I stopped him." I asked how he tried to touch her. star tt tEpstein and she felt uncomfortable. old Epstein, I'll massage you but I don't want to be touched stated she performed the massage naked. At the conclusion of the massage, Epstein paid $200. After the massage Epstein stated to Mi that he understood she was not comfortable, but he would pay her if she brought over some gir s. e told her the younger the better. ted she once tried to bring a 23 year old female and Epstein stated that the female was too old. tared that in total she only remembers six girls that she brought to see E stein each time she was paid $200. stated she had brought the following girls: a16 year old female), El(a 16 year old female) and id that at the time she brought these girls to a s house the avesre a1114 through 16 years of age. I asked ahich one was the oungest. advised the youngest as she was fourteen when the massage occurred. 'tated every girl she brought knew what to expect when they arrived. They were told they would provide a massage, possibly naked, and allow some touching. I asked her if was aware. She stated every girl she brought knew what to expect. She explained she knew that wanted to make money. She approachedeand explained about going to work for Jeff, Migreed and arrangements were made to s br her Epstein's house on a weekend. tated that she anda(Later identified as picked up=t her house. a ed that at that time she was driving a red pickup truck. They traveled to Epsteiin house and entered through the kitchen door. They met with the house chef and E stein's assistant ...vas introduced to Epstein while they were in the kitchen area. led rs and Epstein went upstairs. When the massage was over.returned to the kitchen area. fated she was paid $200.00 for bringing.o Epstein's house. ted.told her she was paid $300.00 for the massage. red that .was the last person she brought to Epstein's house. She had changed her cellular num to avoid being contacted by She continued stating that she had no direct contact with Epstein when he was going to travel to Palm Beach. d when E stein announces to his assistant, MI, that he is traveling to Palm Beach, en contact arrange girls to "work" for Epstein. stated that once her parents discovered that she was visiting Epstein, they —The-foregoiug lash mutat was swur u to or-affirmed before me this l" day of May, 2006 by Det who is personally known to me. Late of Flus id County of Palm Beach Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230824 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 aw ed of the encounters with him and she stopped. further stated that still tries to call house and leaves messages. Sgt entered the room and explained to that based on her own statements, she had implicated herself by bringing underage girls to Epstein's house. •-.)rovided cellular telephone numbers for the girls she had mentioned previously. Additionally, she also provided possible addresses and areas in which they lived. As vas being taken home in the vehicle, a tape recorder was pl al ' i• nthe vehicle to record any conversations within the vehicle. During the drive back to her home, ade the comment " I'm like a Heidi Fleiss." (Hollywood Madam who sent girls to clien or sexual favors in California). was dropped off at her house without incident. On October 3, 2005, Sgt and I went to speak wi m a sixteen year-old female who was brought to Epstein's residence by We met wi other at their front door. We explained the ongoing investigation and asked to speak with we had information that she had "worked" for Jeff. Mrs.. ed us entry into the home. We sat in the dining room and met wi As she was under the age of eighteen, was advised we would be mg wi er. e exp i her daughter had information, she wanted to assist. We interviewed ho denied having an inappropriate encounters with Jeff (Epstein). She stated she had gone to Jeff's house with proximately eight months ago and sat in the kitchen with the house chef, but nothing ppen . the parents were present during the interview, we felt that.was withholding information from us. She made several comments as to putting the entire incident behind her. I left my telephone number and advised should she wish to speak with me again to telephone me. Sgt and I thanked for her time and left the area. She stated she would ask again after we left as to what happened at Epstein's house. I informed her thatElhad my telephone number and hopefully she would call. On October 4 2005 Det and I drove to the and During a sworn taped statement, stated a roximately a year ago when she was seventeen years old, she was taken to a house by tated she Icnows ecause they both attend Royal Palm Beach High School. She was told she could make money working for Jeff. She was told she would have to provide a massage to Jeff. tated upon her arrival to the house she was brought to the kitchen area b they met wit ouse chef who was already in the kitchen area. tated would wait for her in the kitchen. was introduced to , Jeffs asst an , who ug er upstairs to the master bedroom. M prepared The-foregoing instrument was sworn to or-affirmed before me this 1" day of May, 2006 by Det who is personally known to me. ate of Flot ida County of Palm Beach Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230825 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 the room and massage table for a massage. Epstein entered the room wearing only a towel and she provided a massage. ted she kept her clothes on during the massage. She advised sometime during the massage, Wn grabbed her buttocks and pulled her close to him. said she was uncomfortable by the incident involving Jeff. At the conclusion of the massage, she was paid $200.00 for the mas. aske she has any formal training in massages to which she replied no. I asked her if eceiv any monies for taking her to perform the massy e. stated receiv5roney for taking her there but was unsure in the amount. tat she return to Epstein's house on another occasion with d another girl tated she waited in the kitchen withehile en upstairs by stated she only did the massage once as she was uncomfortable with the whole experience. nclusion of the interview, the tape was stopped. I was informed that had attempted to rear is cell phone. A voice mail messy e on October 4 2005 at 10:59 am, revealed a female voice o i entified herself as who requested o call her back reference the police questioning. rovided the incoming telephone num r as ____ tated she inadvertently to ut the police investig: • • • .......• is I a ed her to tell her about how she just received a rental car from Jeff Epstein. ri : .2 her to tell her he was given a rental car, a 2005 Silver Nissan Sentra, to utilize to visit amily and visit E stein. her what was going on at the house that the police would be asking questions. tate ii.cordin to then called Jeff and and asked what was going on reference the ongoing police investigation. instruct not to contact arah has since then been trying to contact her to ask about testions. I and do not provide any more information to she would notify Jeff Epstem and Sarah what was transpiring. On October4, 2005, I made telephone contact with who had left several messages for me to contact her. During the message, she advised she was not completely truthful when we met in person but would like to speak with me to advise what had happened. She further advised she did not want vst eak of this incident in front of her mother. At approximately 3:48 pm I made telephone contact with. During a taped recorded statement ted the following: approximately a ear a o when she was sixteen years of age took er Epstein's house twice. She knows use they both attend Royal Pal B School. The first time she went, rove to the house. They entered through the kitchen area where she was introduced to and Epstein. She was taken upstairs to a bedroom by who set the room up with a massage bed and brought out the oil t use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for.o rub on him. At one point during the massage he tried to remove her shirt, at which point she became very upset and discontinued the massage. Both End Epstein had a verbal disagreement, at which time she left without e tbreguing Instrument was sworn to or affirmed State-of Florida before me this 1" day of May, 2006 by Det , who is personally known to me. County of Palm Beach Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230826 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 being paid. She got with ho was sitting in the kitchen and told her "let's go." I. advised she received no money or t at y. DIso said that told her if she was uncomfortable with what was going on, to let him know and e stop. e ew that the more you do the more ou get paid. .dvised that several weeks later she agreed to be taken a second time by Once they arrived at the residence, sat in the kitchen and took her upstairs to the master bedroom again. set the room up with a massage bed and brought out the oils to use Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for, to rub on him. At one point during the massage he tried to touch her buttocks. As was wearing tight jeans and had a fight belt on Epstein was unable to touch her buttocks. Epstein then rolled onto his back during the massage and then attem ted to touch her breasts., then became upset again and told Epstein she didn't want to be touched. discontinued the massage and was paid $200.00. then went downstairs where was waiting for her. She told IMMIl she wanted to leave. said she never returned to the house. I stated she is aware that her friend, was also at the house and had a problem with Epstein. I later researched, dob , and met with her at her residence. During a sworn taped statement, stated the following: on or about November 2004, she was approached at Royal Palm Beach High School by , a fellow student. asked if she wanted to make money. She agreed and was told she would provide a massage to wealthy man in Palm Beach. picked her up and drove her to a house in Palm Beach. She was brought into the kitchen area of the house. She further stated that fellow Royal Palm Beach High School students and MIM) came with them. They were brought into the kitchen where she was introduced to Epstein and other females. stated she was introduced to a female helper of Epstein, the female was described as white female (unknown name ), with blond hair. She stated that the assistant was familiar with The assistant brought her upstairs into a master bedroom area. The assistant set up the massage table and put out lotions to be used. She told , Epstein would be available in a minute. Epstein entered the room wearing only a towel. Epstein removed his towel, and laid naked on the massage table and picked a remove her clothes. She complied and removed her pants and blouse. didn't further stated during the sae, Epstein asked her to remember if she had lotion to rub on his thighs and back. removed her bra but feels that she did. was certain that she stayed in her thong underwear. continued the massage and at one oint she climbed onto the mass e table, straddling Epstein to massage his back. While doing this was instructed to return to the ground at which time Epstein turned to have his chest rubbed. advised she was sure he was masturbating based on his hand movements going up and down on his penis area. did not want to look at his penis area because she was uncomfortable. Epstein removed a lar e white vibrator which was next to the massage table and turned it on. stated Epstein began e toregomg instrument was sworn to or*ttt~m before me this 1" day of May, 2006 by Det , who is personally known to me. Signature of Police Officer (F.S.S. 117.10) ate of r loricht County of Palm Beach Signature/Arresting Officer Date: 05/01/2006 Page of 22 EFTA00230827 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 Shortly thereafter, Epstein ejaculated and removed himself from the table. He walked over to where the shower wassl opened the glass door. She waited as he was taking a shower in her direct view. When I asked how old she was when this occurred, she stated she had just turned seventeen. At the conclusion of the shower, wei.deither $350.00 or $400.00. She stated she wasn't sure, but knows it was close to $400.00. stated she never returned to provide a massage for Epstein. At approximately 2:10 pm, Det and I met with M, dob at her residence. As was only seventeen years of age, I had notified her mother, that she would be interviewed reference an ongoing investigation in Palm Beach. I assured her that her daughter was not a suspect. I explained the possibility of her being either a witness or victim. advised she wanted to cooperate and consented to the interview. During a sworn taped statement, stated the following: at the age of sixteen, durin the month of September 2004 she was approached by for a chance to make money. was friends with associates of and knew the same people. had beetwieviously told by her friends from Royal Palm Beach High School, what did for E=ein. called a person known to as and scheduled the appointment. picked up and drove her to Palm Beach to a street called "Brillo Way". They drove to the end of the street and entered a hire driveway. The entered the kitchen area of the house and met with Epstein. was introduced to Epstein. led upstairs to the main bedroom area and set up the room with a massage table and set out the oils. stated that whaling up the stairs and into the bedroom she observed numerous photographs of naked young girls. dimmed the lights and turned on soft music. exited the room and Epstein entered the room wearing only a towel. Epstein picked oils and instructed her to rub his legs, under his buttocks, back and chest area. Epstein asked her to get comfortable. IN advised she did not remove her clothes. She was wearing tight jeans and a cropped tank top exposin her bell area. Dunn the massage, Epstein removed his towel and laid on the massage table naked. As area, he attempted to reach down her pants to touch her buttocks area however was unable to due due to the tightness of the jeans and a tight belt. advised Epstein began to masturbate as she rubbed his chest. Epstein moaned as she rubbed his chest. She observed he was continuing to masturbate and attempted to reach up her tank top and touch her breasts. M, pulled back and Epstein stopped, however he kept masturbating until lie climaxed. He cleaned himself with the towel he was previously wearing. IN was paid $200.00 for the massage and left the area. She met with who was waiting in the kitchen area and left the house. The foregoing instrument was sworn to or affirmed State of Florida before me this 1" day of May, 2006 by County of Palm Beach Det who is personally known to me. Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230828 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 • then ex lained she never provided another massage for Epstein. She did however, go to the house with and as they took another friend of . • advised she was present when went to work for Epstein. She advised she rode over and sat in the kitchen area with to wait for . advised while they waited for the house chef prepared lunch for them as it was almost lunchtime when they went. When was finished with the massage they left the area. I asked rf ever told her what would be expected when she provided a massage. . stated yes, told her that a massage would be expected, ssibly naked and possibly some touching involved. has no formal training in providing massages.. spoke about a third and last time she went to Epstein's house. drove another girl, M, (sixteen years of age) who is friend, to Epstein's house. stated knew that . had made money massaging Epstein and wanted to make monsLterself. took them in the kitchen area of the house and introduced . to and = took upstairs to the main bedroom. advised she doesn't know what happened as did not speak about what happened in the room. received $100.00 from for going with her to Epstein's house and recommending M. On October 6, 2005, at 11:45 am, I met with , dob , at and explained to her why we there to interview her. She advised she was aware of the ongoing investigation. stated she had previously spoken with who told her she was interviewed by detectives. During a sworn taped statement, stated she knew that worked for Epstein in Palm Beach. advised she originally had been taken to the Epstein house by whom she met when they both attended Royal Palm Beach High School. She began going to the house when she was sixteen years of age and stated she had been there a lot of times to provide massages over the past two ears. I asked her if she had formal training in providing massages, which stated she had not. advised she was told what was expected of her by providing maccages and she would have to remove clothing but if she felt uncomfortable just to say . and Epstein would stop pushing the issue. began providing massages and advised she 4 her clothes on. She considered Epstein a pervert and he kept pushing to go further and further. explained she would keep telling him she had a boyfriend and would not be right to her boyfriend. It wasn't until recently that began removing her clothes and staying in her thong underwear to provide a massage. explained Epstein wanted to be rubbed on his back and recently he began turning over and have her rub his chest as he masturbated. He would try to touch her breasts as she rubbed his chest. stated "Jeff would try to get away with more and more on each massage". stated Epstein would try to touch her more and on one occasion he attempted to use a massager/vibrator on her. drove to the house for the original massage. left her cell phone number and every time E stein would come into town, would call her for an appointment to "work". Each time she went, would meet her at the kitchen door area. She would bring her upstairs and prepare the massage table. advised Epstein would ask her questions The foregoing instrument was-sworn-to-or affirmed before me this 1" day of May, 2006 by Det who is personally known to me. Signature of Police Officer (F.S.S. 117.10) County of Palm Beach Signature/Arresting Officer Date: 05/01/2006 Page of 22 EFTA00230829 Probable Cause Affidavit Palm Beach Police Department Agency oRIN FLO 500600 about herself. Epstein knew she was and would be attending . I asked if Epstein knew her real age. stated Epstein did and didn't care. The most recent massage she provided was on October 1, 2005. During the massage, she asked Epstein if she could borrow one of his vehicles to visit her family and boyfriend in , Florida. Epstein had told her she could borrow one of his vehicles but later stated he would rent her a car. She continued with the massage as Epstein and . I asked if she was wearing undergarments to which she replied her thisunderwear. Once he tried to touch her breasts, she would pull away from him and he would stop. was asked if he ever used a vibrator on her. was aware of the vibrator but advised she never would allow him to on her. She described the vibrator as the large white vibrator with a huge head on the tip of the vibrator. She stated he kept the vibrator in a closet near the massage table. stated that on October 3, 2005, she was contacted by Epstein's assistant, who informed her that Jeff Epstein had rented her a new Nissan Sentra and she should come by the house to pick it up. informed she would have the car for a month. stated Epstein knew her car was not working properly and that she had missed appointments in the ast because of her car being inoperable. explained the car is currently parked next to the Gym field. I asked her if she ever took any one to the house. explained she took , a friend of hers who attended Royal Palm Beach High School, who has relocated to to attend college. I asked if she ever allowed another female in the room. advised no one was brought into the room with her. At the conclusion of the interview, Det and I went to the gym area of and located the Silver Nissan Sentra bearing Florida tag . The vehicle is registered to Dollar Rent a Car out of the Palm Beach International Airport. The vehicle was rented by Janusz Banasiack, later learned to be Epstein's houseman, and paid with Epstein's credit card. On September 11, 2005, w/f., dob was arrested bale Palm Beach Police Department for misdemeanor possession of marijuana. During the arrest told the arresting officer that she had information about sexual activity taking place at the residence of Jeffrey Epstein. Additionally, during the ongoing trash pulls from Epstein's residence, discarded papers were found which contained M's name and cell phone number. On October, 11, 2005, Det and I met with • and obtained a sworn taped statement. explained she had been going to Epstein's house since 2002, when she was sixteen years of age. Since then she has gone to the house hundreds of times. • stated she became his "number one girl." She explained that on her first visit she was brought to the house by fellow Royal Palm Beach High School The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det who is personally known to me. State of F onda County of Palm Beach Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230830 Probable Cause Affidavit Palm Beach Police Department Agency ORM PLO 500600 classmate, said she was brought through the kitchen area where she met for the first time. was led to the master bedroom, Epstein s room. explained that as she was walkin u the stairs she observed several photographs of naked women alo the walls and tables of the house. further explained that she was brought into the bedroom, where prepared the room by setting up the massage table and provided the oils for her to rub on Epstein. explained she remembered the steam room area, which contained two large showers. Epstein entered the room from the steam room area and introduced himself. Epstein lay on the table and told her to get comfortable. • removed her skirt and kept her shirt on. Epstein then instructed her to remove her shirt. removed her shirt and remembered she was not wearing a bra. • stated she provided the massage wearing only her panties. She continued rubbing his legs, thighs and feet. • advised he turned over onto his back. Epstein and began to masturbate. Epstein ejaculated which meant the massage was over. At the conclusion of the massage, was aid $200.00. They walked together downstairs where and Shady were waiting. stated received an unknown amount of money for taking her to Epstein. Epstein instructed to leave her cellular telephone number, that he could contact her when he is in town. stated that during her many visits a routine was established between her and Epstein. She would enter the house and get naked in the bedroom. She would then start with a back massage. Epstein would roll on to his back and allow her to massy e his chest area. stated E stein would then began to masturbate himself and at the same time would with his explained Epstein would continue this process until he ejaculated. He would then . • advised that during her frequent visits, Epstein asked for her real age, stated she was sixteen. Epstein advised her not to tell an one her real e. advised that things escalated within the home as Epstein would instruct and pay to . • explained the intercourse included that Epstein had at his disposal. Epstein would watch them and masturbate himself . 0ccasionall E stein would then join in during the to both U and . This occurred dining the time was sixteen years of age. advised this continued to escalate during two years. The routine became familiar to U. Epstein's assistant would telephone her every time Epstein was in the Town of Palm Beach and would place appointments for her to visit and work for Epstein. Each time something new was introduced, additional monies were produced and offered for • to allow the acts to happen. • consented to perform all these acts but was adamant that there was an understanding with Epstein that no vaginal penetration would occur explained that Epstein's penis was deformed. • The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det who is personally known to me. State of Honda County of Palm Beach Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230831 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 explained that his penis was oval shaped. IN claimed when E stein's penis was erect, it was thick toward the bottom but was thin and small toward the head portion. called E stein's penis "egg-shaped." • stated Epstein would photograph and her and proudly display the photographs within the home. masse e to E stein, his female friend which and her would end of this massy e E stein bbed stated durin one visit to Epstein's house in which she provided a was also resent. provided the massage in for Epstein to enjoy. Towards the and tamed her over onto her stomach on the massy e table and stated E stein be an to became u set over this. She said her head was , as he continued to . She screamed "No!" and Epstein stopped. She told him that she did not want to have his penis inside of her. Epstein did not ejaculate inside of her and apologized for his actions and subsequently paid her a thousand dollars for that visit. • stated she knows he still displays her photographs through out the house. On October 12, 2005, Det and I met with dob , who stated during a sworn taped statement, that nothing happened between her and Epstein. appeared nervous during the interview. I assured her that I have spoken with other people who advised differently. stated on several occasions she rovided a massage to Epstein. She stated she was brought to the Epstein house in March of 2005. , a classmate at Royal Palm Beach High School approached her and asked her if she wanted to "work". made the arrangements with =, Epstein's assistant. who has no formal training in providing massages, stated she provided a massage, fully clothed for $200.00 . As I sensed hesitancy in her answers, I asked if she had been contacted by anyone from Epstein's organizations or his house. stated she was interviewed already by a private investigator for Epstein. He identified himself as " and inquired about the police investigation, and left his telephone number for additional contact. provided no additional information, as it appeared her responses were almost scripted. On November 6, 2005, at approximately 3:30 pm, I met with , dob , at the Palm Beach Police Department. was identified as a potential witness/victim through information obtained during the trash pulls. During the sworn taped statement, advised she was at Jeffrey Epstein's house one time, approximately two months ago. She was approached by a irl , who was dating M' roommate, for an opportunity to make some quick money. advised she needed to make some uick cash to make the rent that month. She agreed to go to the house. She had been told by that the massage would have to be done in her underwear. She advised drove with her and brought her into the house. They walked into the kitchen area, and took the stairs upstairs. further stated she was brought into a master bedroom area. She advised she - The fuwegoing ins I umenl was o or affirmed before me this 1" day of May, 2006 by Det who is personally known to me. Signature of Police Officer (F.S.S. 117.10) of Florida County of Palm Beach Signature/Arresting Officer Date: 05/01/2006 Page of 22 EFTA00230832 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 recalled seeing portraits of naked women throughout the room. A massage table was already out near the sauna/shower area in the master bedroom. E stein entered the room wearing only a towel and introduced himself as "Jeff." At Epstein's direction, and removed their clothing down to their ties, Epstein laid on his stomach area and they provided a massa eon his legs and feet area. I asked if she had any formal moccage training and she replied "no." advised she was topless and the panties she wore were the boy shorts lace ties. She and continued the massage until the last ten minutes of the massage, Epstein, told to leave the room that could finish the massage. got dressed, and left the room as Epstein turned over onto his back.isein then removed the towel and laid naked . Epsteiniabested that Epstein, began masturbating. stated Epstein pulled down her boy short panties, and he produced a rub his chest area. stated , large white vibrator with a large head. She stated it was within his reach in a drawer in his master bathroom. He with the vibrator. He continued to stated she was very uncomfortable during the incident but knew it was almost over. Epstein climaxed and started to remove himself from the table. He wiped himself with the towel he had on previously and went into the shower area. Epstein came into the kitchen and provided folibriding the mscsage. advised he never as he continued to masturbate. got dressed and met with in the kitchen area. $200.00 for bringing and paid $200.00 to was told to leave her telephone number with for future contact. provided her cellular telephone number. was asked if she was recently contacted about this investigation by anyone from the Epstein organization. She replied she was called but it was for work. She stated she was called by for her to return to "work" for E .s . stated "work" is the term used by to provide the massages and other things. advised she declined as she was not comfortable in providing that type of "work." On November 7 2005 Det and I met with During a sworn taped statement, stated she met Jeffrey Epstein through when they were still attendingifialm Beach High School. would approach females who wished to work for Epstein. stated she was offered to work for Epstein but declined. explained that "work" means ive massages. She was asked about any formal training in providing massages which she said "no." said she accompanied and other females who were taken to Epstein's house to provide massages. further stated she had been to the house approximately 4 or 5 times in the ast ear. She accompanied with , , M, and . Each time the girls were taken over, they were previously told they would have to provide a massage, possibly naked. They were also told that should Epstein them to do anything extra, and they were not comfortable just to tell him and he would stop. stated received $200.00 for each girl she brought over to massage Jeffrey Epstein. When I asked which girl appeared to be the e foregoIng Instrument wanworn to or affirmed State of Florida before me this 1" day of May, 2006 by County of Palm Beach Det who is personally known to me. Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230833 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FIXI 500600 youngest, she replied, who was really young, fifteen years old at the most. further stated each time she went to the house, she sat in the kitchen and waited with until the maccage was over. She further stated that the cook would make lunch or a snack for them as they waited. I asked her if there was anything that caught her attention within the home. stated there were a lot of naked girls in photographs throughout the house. On November 8, 2005, at approximately 2:00pm , I met with , dob at the Palm Beach Police Department. During a sworn taped statemen stated she had met Epstein approximately two years ago when she was first approached by , a classmate at Royal Palm Beach High School. for $200.00. approached her about working for Epstein and providing a massage to him had made the arras ements however was unable to take her the day the arrangements were made. had also attended Royal Palm Beach High School and was familiar with Epstein. recalled she was brought there and entered through the back kitchen door. She had met with an assistant and another assistant brought her upstairs as she observed several photographs of naked females throw hout the house. wanted her to use and requested she remove her clothing to provide the massage. stated he Iced out the oils he stated Epstein came in the room, wearing only a towel, and laid on the table. stated that on the first massage she provided she did not remove her clothing. stated she had returned several times after that. Each time she returned it was more than a massage. Epstein would walk into the master bedroom/bathroom area wearing only a towel. He would masturbate as she provided a massage. stated she was unsure if he climaxed as he masturbated under the towel. Additionally, she never looked below his waist. She claimed that Epstein would convince her to remove her clothes. She eventually removed her clothes and stayed in her thong panties. On occasion, Epstein would use a massager/vibrator, which she described as white in color and a laze head. Epstein would as he would masturbate. stated she had been to the house numerous times. added she has no formal training soviding ir a massage. stated she brow t two females durin her visits to provide massages. stated she brought a girl named and from Royal Palm Beach High School. stated she received $200.00 for each girl she brought. On November 8, 2005, I met with , W/F, 10/10/1987, at the Palm Beach Police Department. During a sworn taped statement, stated she had met Jeffrey Epstein approximately one year ago. She was approached by a subject known to her as S. • had asked her if she wanted to make money providing massages to Epstein. had heard that several girls from Royal Palm Beach High School were t4 this and making money. She agreed and was taken to the house bye. • had introduced her to and Epstein and brought her upstairs to a master bedroom where a massage table e foregoing instrument was sworn to or affirmed State of Honda before me this 1" day of May, 2006 by County of Palm Beach Det , who is personally known to mc. Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230834 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 was prepared and the proper oils were selected. left the room and waited downstairs for her.' stated Epstein entered the room wearing a towel and laid on his stomach. She provided a massage wearing only her thong panties. advised Epstein had masturbated every time she provided a massage. She stated Epstein continued to masturbate until he climaxed. Once that occurred the massage was over. She felt the whole situation was weird but she advised she was :1 $200.00 for providing the massage. She also stated was paid $200.00 by Epstein for bringing =. stated she had gone a total of 15 times to Epstein's residence to provide a massage and things had escalated from just providing a massage. Epstein began touchin masturbate.astein also and with his hands as she provided the massage. stated on one occasion, while she was only seventeen years of age, he offered extra monies to have va final intercourse. She stated this all occurred on the masse e table. stated Epstein and began until he reached the and climaxed onto the massage table. received $350.00 for her massage. I asked her if she had any formal training in providing massages, stated she did not. continued to state on one other occasio Epstein introduced his girlfriend, into the massage. was brought into room with to provide a massage. Epstein had them as they provided a massage to Epstein. Epstein, watched and masturbated as this occurred. On other occasions. E stein, introduced the large white vibrator/massager in the massage. Epstein on vagina as she provided the maccage and grabbed her closer to him as he point of climax. Epstein removed On November 14, 2005, Det and I met with dob During a sworn taped statement she advised she startedgoing to the house approximately one year ago and has been there approximately five or six times. N=I also stated she was sixteen years old when she first went to Epstein's house. On her first visit she was broil" fellow student from Royal Palm Beach High School known to her .ria stated brought her into the house and she was introduced to . then brought her upstairs into a master bathroom, located within the bedroom. stated she met Epstein in the bathroom. He laid on the table and picked the massage oils. She provided the massage as he laid naked on the massage bed. She stated she rubbed his calves and back area. Upon the end of the am i, Epstein removed himself from the massage table and paid her $300.00 for the massage. said each subsequent time she went to the house, she was notified by that Epstein was in town and would like her to "work". stated she returned to the house and was again led upstairs by . She provided the massage, clothed. was asked if she ever removed her clothing to provide an e. stated it was not until the third time that she went that she removed her clothing. a stated she was notified by that Epstein wanted her to come to work. She arrived at the house and was led upstairs by She started providing the massage The guinginstrnment-was sworn to or affirmed before me this 1" day of May, 2006 by Det who is personally known to me. Signature of Police Officer (F.S.S. 117.10) etc of Florida County of Palm Beach Signature/Arresting Officer Date: 05/01/2006 Page of 22 EFTA00230835 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 when Epstein asked her to remove her clothin . removed her pants, shirt and bra. She sta ed in Sion .panties and . Epstein turned over onto his back and she stated she knew he was masturbating himself as she providing the massage. stated she believed he climaxed based on his breathing. She did not want to view either the climax or the fact that he was masturbating. stated once the breathing relaxed he got up and told her to get dressed. She was paid $300.00 for her services. stated on the last time she went to provide a massage, she was notified by to come to the house and "work". stated she was now dating her current boyfriend and did not feel comfortable going. She recalled it was approximately January 2005. She said she went, already thinking that this would be the last time. She went upstairs and went into the master bathroom. She met with Epstein, who was wearing only a towel, and laid onto the table. statecabtein caught her looking at the clock on several occasiorStein asked her if she was in a hurry. stated her boyfriend was in the car waiting for her. further stated that Epstein got upset as he wasn't enjoying the massage. She told him that she didn't want to continue and she would not be back. Epstein told her to leave as she was ruining his massage. advised she had no formal training in providing any massages. stated although she had a falling out with Epstein, she still received a Christmas bonus from Epstein. stated she was wired money from Western Union for her Christmas bonus. Sub tresults from Western Union revealed money was sent from Jeffrey Epstein on December 23, 2004. received $200.00 from Epstein for her Christmas bonus. On November 15, 2005, Det. and I met with E, dob During a sworn taped statement, E stated she met Jeffrey Epstein over a year ago. She was sixteen years of age and was approached by a fellow Royal Palm Bead, School student, who informed her that she could make $200.00 providing a massage to Epstein. had informed her that she would have to provide this massage topless. made the arrangements with Epstein and his assistants and took E to the house. and she entered through a glass door that led into a kitchen. She was taken upstairs by to a master bedroom. She recalled the master bathroom had a large. couch, saunaand matching shower. Epstein entered into the room wearing only a towel. • and , removed their clothing remaining only in thong underwear. She further stated that E stein laid on his chest on the table. The oils were selected on which ones to use. Both and M provided the massage on his legs, back and feet. Forty minutes into the massage, Epstein turned over onto his back and requested wait downstairs in the kitchen area for E. L in instructed El to finish the massage. As E got dressed startin rubbin Epstein's chest. = left the room, and Epstein began masturbating as . IE stated Epstein continued masturbating until he climaxed on the towel he was wearing. When asked if he had removed the towel she stated he turned the towel around . that the opening would allow him to expose himself. After he cleaned himself off with the Tee foregoing instrument was sworn to or anwmed before me this 1" day of May, 2006 by Det who is personally known to me. State of Ftonda County of Palm Beach Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230836 Probable Cause Affidavit Palm Beach Police Department Agency 0111$ FLO 500600 towel he instructed . the massage was done and to get dressed and meet with him downstairs. • got dressed and met with Epstein in the kitchen area. She was paid $200.00 dollars for providing the massage. • stated she was aware that also received monies for the same thing. The second time she went to the house she was again a roached by advised if she wanted to return to the house to provide another maii. M agreed and the arrangements were made by for her to return to the house.. stated drove her to the house and knocked on the same glass door which leads to the kitchen area. They were allowed entry into the house b one of the staff members. led her upstairs to the master bedroom and master bathroom area. left • this time to do the massage alone. Epstein entered the room again wearing only a towel. began removing her clothing as she did the last time she was at the house. Epstein instructed her to get naked. He laid on the table onto his stomach as El began massaging his le sand back. As . finished with Epstein's back and legs, E stein then turned over onto his back.. started to rub his chest and he began masturbating. As M rubbed his chest, Epstein leaned over and produced a massager/vibrator. He turned it on and be an rubbing vagina and masturbating himself at the same time. • stated she as this was occurring. She described the vibrator/massager as large grey with a large head. Epstein for approximately two to three minutes with the massager/vibrator. He then removed the and concentrated on masturbating himself.. stated Epstein climaxed onto the towel again and informed her that the massage was done.. got dressed and met with who was waiting in the kitchen area. She received $200.00 for the massage.. said she never returned to the house and had no desire to return to the house. % was asked if she received any formal mas training. She advised she had no formal training. was asked if Epstein knew her real age. IMI stated he knew, as he asked her questions about herself and high school. He was aware she attended, and is still attending Royal Palm Beach High School. During the course of the investigation a search warrant was executed at Jeffrey Epstein's home located at 358 El Brillo Way in Palm Beach. While in the home I observed the pink and green couch within the master bedroom area just as the girls previously mentioned. The stairway, which is located from the kitchen area to the master bedroom area, is lined with photos of naked young girls. Additionally, numerous photographs of naked young females, some of which appeared to be the girls I previously interviewed, were on display throughout the house. Also located in the house were various phone message books. The telephone message books have a duplicate copy (Carbon Copy) which, once a phone message is written into the book, the top copy is then torn on the perforated edge and the carbon copy is left in the book. First names of girls, dates and telephone numbers were on the copy of the messages. I recognized various numbers and names of girls that had already been interviewed. The body of the messages were time of the day that they called for confirmation of "work." Other names and telephone numbers were located in which the body of the messages were, "I have girls for him" or "I have 2 girls for him." These The-for eguing illb I uuncul was SW Ot n to us affil before me this 1" day of May, 2006 by County of Palm Beach Det , who is personally known to me. Florida Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230837 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 messages were taken by , who signed the bottom of the messages. During the execution of the warrant, I located a Royal Palm Beach High School transcript for in Epstein's bedroom desk. This desk had stationary marked Jeffrey E Epstein. I located a wood colored armoire beside Epstein's bed that contained a bottle of "Joy Jelly," which is used to provide a warm massage. Several massage tables were located throughout the second floor of the residence, including a massage table found in Epstein's bedroom. On the first floor of the residence I found two covert cameras hidden within clocks. One was located in the garage and the other located in the library area on a shelf behind Epstein's desk. A computer was located which was believed to contain the images from the covert cameras. The computer's hard drive was reviewed which showed several images of and other witnesses that have been interviewed. All of these images appeared to come from the camera positioned behind Epstein's desk. On December 13, 2005, Det. and I met with dob . During a sworn taped statement, stated that when she was sixteen years old she was taken to Epstein's house tt2rovide a massage for money. • stated it was before Christmas last year (2004) when an associate, M, approached her and asked if she needed to make money for Christmas. made arrangements to take • to the house and drove to the house to "work." They were encountered by a white female with long blond hair.. was unable to remember the name of the white female with blond hair but knew she was Epstein's assistant. She was led upstairs by the white female who explained that there would be lotions out already and Epstein would choose the lotion he wanted her to use. She was led through a spiral staircase which led to a master bedroom and bathroom. The massage table was already set up in the bathroom.. described the bathroom as a large spacious bathroom with a steam room and shower beside it. • was introduced to Epstein who was on the phone when she entered the room. Epstein was wearing a white towel and laid on his stomach, that • may massage his feet and calves. started the massage with the oils Epstein chose and rubbed his feet and calves. Epstein got off the phone and requested she massage his back as well. • began rubbing his back and got to the small of his back. During the rubbing of his back, Epstein asked her to get comfortable. He requested she remove her pants and shirt. • removed her shirt and pulled her pants off. • stayed in her bra and thong panties. As she finished massaging the small of Epstein's back he then turned onto his back. Epstein instructed • to rub his chest and pinch his nipples. As she Epstein asked her questions about herself. remembered telling him she attended Royal Palm Beach High School. Epstein asked her if she was sexually active. Before could answer, he also asked what sexual position does she enjoy. stated she was shy and didn't like talking about those thin s. She continued Epstein reached up and unsna her bra from the front. explained the bra she used had a front snapping device. Epstein and asked her if she like having . • said "no, I don't like that." Epstein then removed his towel and laid on the bed naked exposing his penis to He began touching his penis and masturbated as he . explained Epstein then c furcgoing ins t umeut WV'S swot u to m waled State of Flori before me this 1" day of May, 2006 by County of Palm Beach Det , who is personally known to me. Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230838 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 touched tensed up and stated Epstein was aware that she was uncomfortable. stated that Epstein said to her, "Relax, I'm not going inside." She further explained Epstein commented to her how beautiful and sexy she was. Epstein then moved her thong panties to one side and be an said, "He commented how " He then ulling back to and apologized for kept his and continued to rub her vagina. stated he as he was masturbating. said he climaxed onto the towel he had been previously wearing and got up from the table. Epstein told her there was $200.00 dollars for her on the dresser within the master bathroom. Epstein also told her that there was an additional $100.00 that was to be given to . for bringing her there to massage him. Epstein told her to leave her telephone number with his assistant as he wanted to see her again. Epstein stated his assistant would contact her to work 22in soon. I asked her if she ever received any formal massage training to which. stated she did not.. stated it was the only time she ever went to work for sand knew what happened to her was wrong. She further stated that she had never been contacted for any additional work. On January 9, 2006, I located and interviewed another victim, ., dob . was identified as a potential victim/witness from information obtained during trash pulls from Epstein's residence. . stated she met Epstein when she was fifteen years of age. She was approached by a friend from Royal Palm Beach High School, , to be taken to Jeffrey Epstein's house to work. She was originally told she would be able to model lingerie for a wealthy Palm Beacher. . was taken to Epstein's house located on El BrilloWay. introduced . to Jeffrey Epstein. Epstein had his rsonal chef prepare dinner for . and At the conclusion of diluter, and Epstein brought . upstairs into a master bedroom area observed a linassage table with a sheet on it. Epstein entered through a door and exited wearing only a towel. informed . that they were go' to provide a massage on Epstein.. asked why were they doing this instead of modeling linzrie. explained to li that this was his routine and to nib his calves and feet. Epstein had told IMI to get comfortable. removed her pants and blouse. . stated she stayed only in panties as she did not wear a bra that evening. . stated while rubbing his calves and feet, Epstein tuned over onto his back. Epstein told IMI to rub his chest and rub his ni les. stated that as she started Epstein began masturbating himself. Epstein and with his fingers. Epstein continued to masturbate himself as he . Epstein ejaculated on his towel and paid MI $200.00 for the mass e. Epstein told that if she told anyone what happened at his house that bad things could happen.. and were brought home by Epstein's houseman and . was afraid that Epstein knew where she lived. stated that several days later she received a telephone call from 1 ne foregoing instrument was sworn to or affirmed before me this ld day of May, 2006 by Det who is personally known to me. State orb fortda County of Palm Beach Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230839 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 who coordinated for & to return to "work." . returned to the house and was brought to Epstein's bedroom area by who prepared the room for the massage. Epstein entered the room wearing only a towel. Epstein had . remove her clothing and provide the massage naked. • began mruba his feet and calves and Epstein turned over onto his back. Epstein Epstein continued with one hand and masturbate with the other hand. Once Epstein Epstein be an to masturbate himself with an upwards and downward motion on his penis. ejaculated onto the towel he was wearing, the massage was over. . was paid $200.00 for the massage. Epstein again told . not to speak of what happened at his house or bad things would happen. . wanted to notify authorities however she was afraid of what would happen to either her or her family. During the course of the investigation, several subjects were identified as a potential witness/victim through information obtained during the trash pulls, physical surveillance and telephone message books retrieved from the search warrant. While conducting research on the subjects, I discovered that the females were age eighteen or older. Interviews were conducted on the consenting adults whose statements provided the same massage routine when they went to "work" for Epstein. The females would be notified by , and made appointments for the females to "work" for Epstein. The females would come to Epstein's house and were led upstairs, through a stairwell from the kitchen area, by to Epstein's bedroom. Epstein would then enter the room wearing only a towel, and ask them to et comfortable. The females would then • rovide the massa:e naked as E 'stein would either and/or . He would masturbate during the massage and upon his climaxing, the massage would end. The girls were then paid two or three hundred dollars for the massage. On November 21, 2005 I interviewed Jose Alessi, a former houseman for Jeffrey Epstein. Alessi stated he was employed for eleven years with Mr. Epstein, from approximately 1993 through 2004. Alessi stated he was the house manager, driver and house maintenance person. It was his responsibility to prepare the house for Epstein s arrival. When asked about cooks or assistants, Alessi stated they traveled with Epstein on his private plane. I asked Mr. Alessi about the massages that have occurred at Epstein's home. Alessi stated Epstein receives three massages a day. Each masseuse that visited the house was different. Alessi stated that towards the end of his employment, the masseuses were younger and younger. When asked how young, Mr. Alessi stated they appeared to be sixteen or seventeen years of age at the most. The massages would occur in Epstein's bedroom or bathroom. He knew this because he often set up the massage tables. I asked if there were things going on other than a massage. Alessi stated that there were times towards the end of his employment that he would have to wash off a massager/vibrator and a long rubber penis, which were in the sink after the massage. Additionally, he stated the bed would almost always have to be made after the massage. 1 he foregoing instrument was sworn to or affirmed before me this r day of May, 2006 by Det who is personally known to me. State o londa County of Palm Beach Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230840 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 On January 4, 2006 I interviewed another former houseman, Mr Alfredo Rodriguez. During a sworn taped statement, Mr. Rodriguez stated he was employed by Jeffrey Epstein for approximately six months, from November 2004 through May of 2005. His responsibilities as house manager included being the butler, chauffeur, chef, houseman, run errands for Epstein and provide for Epstein's guests. I asked Rodriguez about masseuses coming to the house. Rodriguez stated Epstein would have two massages a day. Epstein would have one massage in the morning and one massage in the afternoon everyday he was in residence. Rodriguez stated he would be informed to expect someone and make them comfortable until either or Epstein would meet with them. Rodriguez stated once the masseuses would arrive, he would allow them entry into the kitchen area and offer them something to drink or eat. They would then be encountered by either or Epstein. They would be taken upstairs to provide the massage. I asked Rodriguez if any of the masseuses appeared young in age. Rodriguez stated the girls that would come appeared to be too young to be masseuses. He stated one time under Epstein's direction, he delivered a dozen roses to Royal Palm Beach High School for one of the girls that came to provide a massage. He knew the girls were still in high school and were of high school age. I asked Rodriguez about the massages. He felt there was a lot more going on than just massages. He would often clean Mr. Epstein's bedroom after the alleged massages and would discover massagers/vibrators and sex toys scattered on the floor. He also said he would wipe down the vibrators and sex toys and put them away in an armoire. He described the armoire as a small wood armoire which was on the wall close to Epstein's bed. On one occasion Epstein ordered Rodriguez to go to the Dollar rent a car and rent a car for the same girl he brought the roses to, I that she could drive her self to Epstein's house without incident. Rodriguez said the girl always needed rides to and from the house. Rodriguez produced a green folder which contained documents, and a note with MrSstein's stationary with direction to deliver a bucket of roses to Royal Palm Beach Higachool after high school drama performance. Also in that same note was direction to rent a car for and direction to extend the rental • contract. During the course of the investigation, subpoenas were obtained for cell hone and home phone records from several victims and witnesses along with the cell phone records of . An analysis of these records was conducted which found numerous telephone calls were made between and the victims. These records indicate the dates the calls were made are consistent with the dates and times the victims/witnesses stated they were contacted. Specificall . The phone records showed called during the exact times and dates when victim advised the incident occurred. also coordinated the encounters with M, and during the time frame the girls stated they occurred. Pursuant to a lawful subpoena I obtained Epstein's private plane records for 2005 from Jet The toregomg instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det , who is personally known to me. State of Florida County of Palm Beach Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230841 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 Aviation. The plane records show arrival and departure of Epstein's lane at Palm Beach International airport. These records were compared to the cell phone records of This comparison found that all the phone calls made to and the victims were made in the days just prior to their arrival or during the time Epstein was in Palm Beach. Jeffrey Epstein, who at the time of these incidents was fifty one years of age, did have vaginal intercourse either or digitally with...and =, who were minors at the time this occurred, and who at the time of the incident was fifty two years of a e did use a vibrator on the external vaginal area of a fourteen year old minor. Therefore, as coordinated and aided in the recruitment of minors to frequent Epstein's house, that sexual services were provided to Epstein, scheduled the said minors to return to the work for Epstein, secured their appointments for the purpose of sexual activity and lewd and lascivious acts and arranged the bedroom for said minors, there is sufficient probable cause to charge with four counts of Principal in the 1 3' degree Unlawful Sexual Activity with a Minor, in violation of Florida State Statute 794.05(1) , a second degree felony and there is sufficient probable cause to charge her with Lewd and Lascivious Molestation, in violation of Florida State Statute 800.04 (5), a second degree felony. The foregoing instrument was sworn to or affirmed before me this 15' day of May, 2006 by Det who is personally known to me. State of Florida County of Palm Beach Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00230842 0 4 1 EFTA00230843 t REQUEST FOR WARRANT DEFENDANT: Jeffrey Esptein DATE OF BIRTH 01-20-1953 HABITUAL OFFENDER: YES NO A/K/A VICTIM RELATED / ACQUAINTED WITH DEFENDANT? AGENCY CASE NUMBER: 05.368 (1) LEAD OFFICER: Del. AGENCY: _PALM BEACH POLICE DEPARTMENT YES XX NO PHONE NUMBER: (561) 838-5454 CURRENT SHIFT HOURS: 8 am TO 5 pm DAYS OFF: LEAVE / SHIFT CHANGE INFO: WAS ARREST MADE FOR, OR IN CONJUNCTION WITH ANOTHER AGENCY. IF `WHAT AGENCY?: SENTENCING RECOMMENDATIONS: CONTACT DETECTIVE ADDITIONAL COMMENTS: FILING DOCUMENTS ATTACHED: X ARREST FORM Y P.C. AFFIDAVIT (2 COPIES) • •JC wiTINE,SS / EVIDENCE LIST ihtegrouSty wen It ASA eMsilnimpat￾SWORN STATEMENT OF MATERIAL WITNESS(ES) `JC OFFENSE REPORT (2 COPIES) ACCIDENT REPORTS (ALL) WITNESS STATEMENTS (ALL) FCIONQC CRIMINAL HISTORY PaVI(.M Rt44UESTIvFOARStONVII en 3CTIat SIT% RS )( PROPERTY RECEIPT Pastultv-S given rt. Asa. so Loptutvere_ VEHICLE TOW RECEIPT OTHER ATTACHMENTS INCLUDE: INITIAL FOR COMPLETENESS: JR OPPICER RECEIVED, STATE ATTORNEY'S OFFICE. ON: ; • - 7915 ID, 050106 DATE DATE EFTA00230844 I DEFENDANT I ADIAINISTRATIVF I OBIS Writer i i i i i i 1 1 ARREST / NOTICE TO APPEAR t Ansi 3 Retail IV WWI Juvenile Referral Report 2 N T A 4 Regal Ica Ceps Ft A..... r ! Agency OM Nunes FLOL 5'0,01_6 L0 i 0 AWCY Wm* 'Agency PALM BEACH POLICE DEPARTMENT i Ripon NUMB (N.TA'soir) 7 i 6 H 1 Hi I Li I I(1 A i PaTtYPe 0 I. Felony a 3. Sesdentsasior 0 S °Omni* ? raaay 0 2. Traffic FROM 0 4. Trek Misdemeanor 0 6 Other I Weapon Sized I E w Type citiliv ia Localion of MOM (Inducing Name ol Begonia) _ LOCabOn of Mines Mustiest Name. AddrOSS) Imitator Date ol Anal I I LA I Time ol Ansel 1 I I _._ Boating DIN Booking Time Jet Dale Jail Tone LocMon of While Name Mast. Fist Mc/cIN) ANN Nome. DOB. Sou Sec. I. Elm.) Race W • VONe I - Amettan Indent B. Black 0 - OneraaVAsian I Sin Oa to of Awe, 1 1 1 1 1 imqN wave EY• caber . Re* COY COmplealoo Bold Start Maas, Tattoos. UnCue Physical reatufes iLecalwo. Type Descriptor , MAIN Sulu Religion p mc Intlicuenr in ionof gi tg, taw in uenci LOS AskteSS (Sift. NS ) 'Cry) ISrate) . IDTil Phone (' ibeeklence Type￾Cowl. 3. Rorie 2. 4. Cke fo Sligo I PermaneN Mien (Street. Ai Numbed ic.t, i iStaull (ZIP) . Phone ( ) Address Source Buenas Address (Name. DIN) ION (Stale) OP/ Patina Occupation D/L Number. Star Scc Sec Marts r Numb, lin of eirth (Ott Star) Cotenant) LL Co-Defendent Name (Last. Feel MildNI ' Rice • Die ol Sri lc a l; 8 i fird2....... uremia OP011erchlal Nan* (Last. Fat. Middle) _ Rem _ Sex Ow aWM 81: At dy elided O and 0 5 Jw. tfr E Po I D Parent flame DASD (rash (Mile) Resoeuce Phone Ad S IDIOM 8IN Number/ MAN ODIN (Zip) eivameSs Phone I I TOT JAC Ir a Time The Sim adOdili MS provillid by 0 clerenclam and / or ocienrciarts parents. The trite and log peen) was NM lo Neap Me Juvenae Cool One Ofte (Phone 355.2526) intermediate damps 8 Simla 0 bee, by: Pets) 0 Nv(leaSon) Scicol Aperp GraN Properly Dare JONCrDeOn 0 yet 0 NO a Property Woe Ol Promo 2 !W elmtY I: But a ossrTIgi K &tsgr s utt IA Isprulacare, P. Poseeful T. italic E. UN Z Other Ensdil' ype Enarteurate 14 Hahobnopen p Par cheniaka u Lvoimoso C Cocaine M Mareuana Earcmrit 7 Oln..., A Amphetamine E. Heron 0 Opt.eetwe S S Meet U Charge Desoipton Casa I Corneae CleirliN DNA* Valabrwl Nuenbm L I ' ILL i 1 i I(I i i t V)vatoen VORD • Mc Activity Drug Type Amount/Unit Mem 0 Warrant :Capes Number 111./nos Charge Deecaplon Coups Domes& 6r8N Datul• .hoaabon fawner I t. il . 1 ., I w t 1 1 ) vair..)n pi ORO ft g Drug AdMy Dug Type Amount /Unit lollena a Orana /Cap., Mantel I Saw lE12104 Charge DeeerlpOrn Cane DOmOince Viole lie 0 Y ON DahAe Uolabon Number I 1 1.1 I I 1 Id t I I I jY \i/Olehri or ORD a Drug Adivey IDIrg Type Amount/Um Wares I . Warrant / Capin Swinger 11 Bonil Charge Dasaptin _ Capra DOMINO V rIBN Della Volition Number t i l-l i i t i(I ! ! i Vi.118:Ce Voile / ) Ow ANN.!), Dug Typo Amount / Un I rw.. I/ Warrant / Cages Numbr lioit 1 0 *- sY 2 El Instruct No. I MenOaloryAppearanCe in Can " locoman (Coo . Room Hunter. ablikete) tiretin,...?....COull DA MN coin* Atli insouciant an Reverse S. CDPITDOMialleill Day Year in PAL I AGREE TO APPEAR AT THE TIME AND PLACE DESIGNATED TO ANSWER THE OFFENSE CHARGED OR TO PAY THE FINE SUBSCRIBED I UNDERSTAND THAT SHOULD I VALLFULLY FAL TO APPEAR BEFORE THE COURT AS REQUIRED BY THIS N2110E TO APPEARTWIN...Y8E HELD IN CONTEMPT OF COURT AND A WARRANT FOR MY ARREST SHALL BE ISSUED. Signature of Defender* (Or AMINO and Patera / Oacian),. Deb Sped HOLD lot other Agency Nana' SOnate °Mincing Oats x NOON VablIcalOr. (POMO by Amon) 3 0 Dardesous 0 Rued Amost ,fee Of Arreatalo Ulcer (MINI I.D./ . (PRINT) 0 soca& 0 NW: PAGE Deputy LO. I 1NriSpOillnp Otter 1 D a Agency A Intake 'Pouch Walesa Ave I subsea paned was an-r" OF DISTRIBUTION: WHITE — ccunT con GREEN — STATE ATTORNEY YELLOW — AGENCY PINK — JAIL GOLD- DEFENDANT RATA:* GNU) EFTA00230845 ADMINISTRATIVE i —offs tOnber I ARREST / NOTICE TO APPEAR I Mete 3 Repast to Werent A Juvenile Referral Report 2 N TA 4 Regan* for Caps ri Annie r-- NOM ORI WOW FLOtalasat 6 1 0 1 0 AWL./ Name PALM BEACH POLICE DEPARTMENT renCy Report Number (N.TAN agy) 7 I .6 H L ii 1 k I 1 li l t I) StralsTany 0 1 Maw 0 3. lasclemeeny . 0 5. Ordnance as apperi 0 2. Trate Felony OA TraMedenteatter Oa Other II Weepon Send rultgle Enter Type insca( ance a Location d Anesi Oncluclinp Name cd Buskins) Mann 01 Monet (Busmen newt Address) Date or Arrest a tm_ hens cil Amill La i SOONN Date I ticeldrg nee Jed Date 1Jail Time lloasbakolVehge . o 2W 1. " O Name (Last Fitt. Mont Matt Pint DOB. Soc Sec I. Etc) Race W . Wm I • ArneeCan ni 8. Black O. Orem.* f Sea Date ol Bah I I I _i_ 1 Wogs En Cola Hair ONor Complexion Fluid Scars. Mans. Tattoos. Unique Abysmal Features (LOCaben. TRW Wenn` I MAW Sty us IRegon Irdeetion ob Alekhol Mace gi A I. leluente Local Maas (Street Apt Number) (Caii) (Stara (4) Phone ( ) Reselense Toe: 1. Cifkr ) nOddll P COW& 4. Out of Sime I Pennon MOna Inn. ApI. NuMbled (OW !Slate) an Phone ( ) Address Source Business Mtress (Nan. Sae.) CUP .srai? (DPI Phone f / Octuorlun DA. Magda Slate Soc. Sec. Nutt. INS Mater Pan a am (City. State) — CezenshiP Ii Junta, g Co. Defendant Name (Lam Fret Wet Race Sex Date of farm ..te 81: Mined Q3 mozo.„,, ooPefervani Name (Leal Fret Whentl Race Sex Date aBeth I Attested I Felony 2. M Lyre 4. Motleireener 5. Small W ..a ti .... j Name (Lash (RFO ORLON p sPafc,..,cd.. Retnerte Penn ( I mos. (Snt. Act. Nunn) (Cu) (Mate) an Bunsen Peon I ) TOT JAC Oat. Time •=a1The I Min edam was Fanged by °defendant and i or C) delondanfs parents The Chn and i w parent was too 10 keep Pe Jenne Cowl Peek Mos (Phone 355-2526) ullormeciol any Own. ol Add of s 0 Yea bit Melt 0 No Messonl Schaaf emanate Grade Many Came Oesnoon of Property 0 Yes OS Value of Property ki t s ^. i.s . moan K. Dispenser LI Minute:NW P. Patten i lia c Veer Mann Procne/ Z. Other Urug Type nage,* at HalLancgen Pl'amphismaket att RA .ne C. Pawn M. Manena Am . NMgin 0 OPurnMerh S. U. Unknown 2. Cnhef g Charge 0- Onambon Comet Doman VTR Masa Vnellen Pa me I s n a i l III I I 1 Monica 0/ ORO t ....4 owe Mbar rirug Typo Amount / Une CNIerwa I Warrant )Capes Monter [Bona § Change DesanOn Ones Dann O Ca'r& nine Vdation Monter I I H i l l 1(1 I I I ) McCaw or ORO t I Oit U ANN/grins; Type 'Amount/UM °Wee I y Warrant / Caress Number lI Bonn W Change 1 0 onaipoon Count Oommec tneree OY ON Stems Mormon Margo: I I 1-1 I I I 1(1 I i i valor or ORD I ) Drug Aging Drug Type Anon/On Plena I Warrant i Cane Rumba a=nt CHARGE I 'Charge Dentine _ County Danistic ern. , Same Motion Nub. Voir I 1_ I.1 1_ 1 t 1(1 1 1 i or or One. ) Drug Activity On Type Anne/ Unit OfNmeil Waitaki /Capes tante Burg NOTICE TO APPEAR 0 insauction No. I Mandatory Apoew &not in Cowl Location (Cow; Room Number, Maass) laJesauctIottNa. ne Ned ^ 0 I aPPew Si Cowl but must comply with instructions on Rowse Side .a0weDis wallets Day Year lime An PM. I AGREE TO APPEAR AT THE TIME AND PLACE DESIGNATED TO ANSWER THE OFFENSE CHARGED OR TO MY THE FWE SUBSCRIBED. I UNDERSTAND THAT SHOULD I WILLRA.LY FAR. TO APPEAR WORE THE COURT AS REWIRED BY THIS NOTICETOAPPEAR, THAT I MAY BE HELD IN CONTEMPT OF COURT AND A WARRANT FOR MY ARREST SHALL BE ISSUED. Saran ol Delenclanl (or Juvefile an Parent/Calm] Date Signed i 0 a re NOSS for oils Agency Rent Signature of Mese% Officer x Name Verification (Printed by Annan pangs/Cos 0 Rented Ater Name of Meting One( (Ring ID. I (PRINT) O &NSW O Other: PArA rave Naar I.D. I I Poch Trimaran% Caber I.O. I Agency Wiwi's' Mee t i wood sigma with an -X'. - oc -- DISTRIBUTION: WHITE — COURT COPY GREEN — STATE ATTORNEY YELLOW — AGENCY PINK — JAIL GOLD DEFENDANT ROAN ONLY) EFTA00230846 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 Police Case#: 05-368 (1) Defendant: Race/Sex: DOB: Charges: Jeffrey Epstein White Male 01-20-1953 Unlawful Sexual Activity with a Minor (4) counts Lewd and Lascivious Molestation From March 15, 2005, through February 2006, the Palm Beach Police Department conducted a sexual battery investigation involving Jeffrey Epstein, and . Sworn taped statements were taken from five victims and seventeen witnesses concerning massages and unlawful sexual activity that took place at the residence of Jeffrey stein 358 El Brillo Way, Palm Beach. Several of the victims were recruited by and brought to the residence by to perform massages for Epstein, for which received monetary compensation. During the visit they would be introduced to , Epstein's assistant, who in turn would record their telephone numbers and name. The victims would be brought to Epstein's bedroom to provide the massage. Epstein would enter the room and order the victims to remove their clothing to provide the massage. As the victims complied and provided the massages, E stein would On occasion, Epstein would introduce a massager/vibrator and as they provided the massage. On three separate occasions, Epstein had intercourse and inserted his penis/fingers in the victims vaginas. At the conclusion of the massages the victims were paid sums of money ranging from $200 - $1,000. The facts, as reported, are as follows: On 03/15/2005, A fourteen year old white female, hereinafter referred to as "U," dob and her family reported unlawful sexual activity which occurred at a residence within the Town of Palm Beach. reported that a subject known to her as "Jeff' had touched her vaginal area with a vibrator/massager while within his residence. "Jeff" was later identified as Jeffrey Epstein through a photo line up. During a sworn taped interview, stated that dob 04/09/1986, a cousin of Ks boyfriend and classmate at Ro al Palm Beach High School, worked for a wealthy man and did sexual favors for him. She also admitted that had offered her an opportunity to make mone . During the beginning of the month of February 2005 explained that she was first approached by to o with her to Epstein's house. stated that along with a Hispanic female, later identified at ick her up at her father's house on a Sunday. was not sure of the exact dates but knew it was a Sunday. IN told her father that they were going shopping but in reality drove them to Palm Beach. During the drive a The foregoing instrument was sworn to or warmed before me this 1" day of May, 2006 by Det who is personally known to me. Signature of Police Officer (F.S.S. 117.10) Page 1 of 22 EFTA00230847 Signature of Police Officer (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 conversation occurred between and whereas she should say she was eighteen. It was later confirmed by the . = i III father that picked his daughter up i ortedly told that if asked her age, on February 6, 2005. According to father, drove a pick up truck. . described Epstein's house as a two-story pink house with a Cadillac Escalade parked in the driveway. She recalled that Jeff's house was on a dead end street. Upon arriving at the house M stated that they walked up a driveway, past what appeared to be a small guard/security room. A male approaching them asking what they wanted. stated they were there to see Epstein. The male allowed them to continue walking up to the house. stated the man told them that Epstein was not there but was expected back. He allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside. Shortly thereafter, Epstein and his assistant, described as white female with blond hair and later identified as entered the kitchen. Epstein introduced himself to M. • described Epstein as being approximately forty-five years old, having a long face and bushy eyebrows, with graying hair. and Epstein left the kitchen leaving alone in the kitchen. They returned a short time later. They all spoke briefly in the kitchen. was instructed to follow upstairs. recalled walking up a flight of stairs, lined with photographs, to a room that had a massage table in it. Upon entering the room there was a large bathroom to the right and a hot pink and green sofa in the room. There was a door on each side of the sofa. recalled there Sb t a mural of a naked woman in the room, as well as several photographs of naked women on a shelf. told the victim that Epstein would be up in a second. Epstein entered the room wearing only a towel and told . to take off her clothes. . stated Epstein was stem when he told her to take off her clothes. . said she did not know what to do as she was the only one there in the room I she took off her shirt leaving her bra on. Epstein had removed his towel and told the. . to take off everything. stated Epstein was nude when he took his towel off, placing it on the floor as he laid down on the table. stated she then removed her pants leaving her thong panties on. Epstein then instructed her to give him a massage pointing to a specific lotion for her to use. As . began to give E stein the massage, he told her to get on his back. U stated she straddled herself on Epstein's back whereby . . said Epstein was specific in his instruction to her on how to massage him, telling her to go clockwise or counter clockwise. Epstein then turned over and instructed . to massage his chest. . was now standing on the ground and resumed massaging Epstein's chest area. . stated Epstein held onto the small of her back as she massaged his chest and shoulder area. Epstein then turned to his side and started to rub his penis in an up and down motion. Epstein then pulled out a purple vibrator and began to The foregoing instrument was sworn tiFfir affirme before me this 1" day of May, 2006 by Det who is personally known to me. State-ol-Fiorida— Signat Date: 0 ting Officer 1/2006 Page2of 22 EFTA00230848 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 stated there was no penetration as the recalled Epstein ejaculating because he had to use the towel to wipe himself as he of off the table. Epstein then left the room and . got dressed. She went back downstairs where she met with M said she was paid three hundred dollars in cash from Epstein. Before she le Epstein asked to leave her phone number. As M, and were leaving the house, told M she received two hundred dollars that day for bringing her. During the course of the investigation, parental consent was granted for to assist with the ai iiation. At our direction conducted controlled taped phone calls to cellular telephone . . spoke with in an attemSange another meeting with Epstein. . asked , what did she need to do to make more money stated, "the more you do, the more you get paid." had sub uently called back . and left a voice mail message for her indicating that she had set up an mointment for. to go to Epstein's house at 11:00 am on April 5, 2005. This message was recorded from Es voice mail. Based on the above, trash pulls were established at Epstein's residence with Supervisor Tony Higgins of the Sanitation Bureau of the Town of Palm Beach. The trash pull from April 5, 2005 revealed a tele hone message for Epstein which stated and name at 11:00 ant This was the time frame had informed to be ready to go work at Epstein's house. On October 3, 2005, Sgt and 1 went to residence and viewed her vehicle parked in the driveway, a red Dodge Neon. Sgt. and I knocked on the door and met with was told that we were investigating a claim involving Jeffrey Epstein of El Brillo Way, in Palm Beach. was asked if she would accompany us back to the police station for further questioning. She was also told that at the conclusion of the interview she would be returned home. voluntarily came with us back to the Palm Beach Police Department. Upon our arrival at the police station, was brought to the interview room in the Detective Bureau where I obtained a taped, sworn statement. I began the interview by asking how she became acquainted with Epstein. stated that approximately two years ago, just after she turned 17 of age, she was approached by a friend named at the Canopy Beach Resort in Rivera Beach. was asked if she wanted to make money. She was told she would have to provide a massage and should make $200.00. thought about the offer and agreed to meet with Jeffrey. The foregoing instrument was sworn to or a before me this 1" day of May, 2006 by Det who is personally known to me. g Officer Signature of Police Officer (F.S.S. 117.1.0) Date: 1/2006 Page3of 22 EFTA00230849 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 (Unknown last name) and Tony (Unknown last name) picked up and she was taken to Epstein's house. Upon her arrival to the house she was introduced to Epstein in the kitchen of the house. She was also introduced to a white female known to her as . She was led upstairs to the main bedroom known to her as •Epstein's bedroom. arranged the massage table and covered the table with a sheet. She brought out the massage oils and laid them next to the massage bed. , then left the room and informed Mwould be in, in a minute. Centered the bedroom wearing only a towel. He removed the towel and laid nude on the massage table. He laid on the table onto his stomach and picked a massage oil for to rub on him. Durinamassage, stated "He tried to touch me and I stopped him." I asked how he tried to touch her. stated that Epstein and she felt uncomfortable. told Epstein, I'll massage you but I don't want to lx Jo ached. stated she performed the massage naked. At the conclusion of the massage, Epstein paid $200. After the massage Epstein stated to that he understood she was not comfortable, but he would pay her if she brought over some girls. He told her the younger the better. stated she once tried to bring a 23 year old female and Epstein stated that the female was too old. stated that in total she only remembers six girls that she brou ht to astein, se each time she was paid $200. stated she had brought the followin irls: , I. ( al6 year old female), (a 16 year old female) and . said that at the time site brought these girls to Epstein's house they were all14 , through 16 years of age. I asked which one was the youngest. advised • was the youngest as she was fourteen when the massage occurred. stated every girl she brought knew what to expect when they arrived. They were told they would provide a massage, possibly naked, and allow some touching. I asked her if • was aware. She stated every girl she brought knew what to expect. She exained she knew that wanted to make money. She approached • and explained about going to work for N, . agreed and arrangements were made to brio her to Epstein's house on a weekend. stated that she and (Later identified as picked up • at her house. stated that at that time she was driving a red pickup truck. They traveled tcastein's house and entered through the kitchen door. They met with the house chef and Epstein's assistant =. • was introduced to Epstein while they were in the kitchen area. led • upstairs and Epstein went upstairs. When the massage was over returned to the kitchen area. stated she was paid $200.00 for bringing • to Epstein's house. stated . told her she was paid $300.00 for the massage. stated that • was the last person she brought to Epstein's house. She had changed her cellular number to avoid being contacted by . She continued stating that she had no direct contact with Epstein The foregoing instrument was sworn 16-araffIrmed before me this 1" day of May, 2006 by Det -,who is personally known to me. Signature of Polic Officer F.S.S. 117.10) State-of Florida Co Signatur Date: 0 ng Officer 06 Pagetiof 22 EFTA00230850 Probable Cause Affidavit Palm Beach Police Department Agency GRIN FLO 500600 when he was going to travel to Palm Beach. said when Epstein announces to his assistant, that he is traveling to Palm Beach, would then contact to arrange girls to "work" for Epstein. stated that once herparents discovered that she was visiting Epsteinailisapproved of the encounters with him and she stopped. further stated that still tries to call house and leaves messages. Sgt entered the room and explained to that based on her own statements, she had implicated herself by bringing underage girls to Epstein's house. provided cellular telephone numbers for the girls she had mentioned previously. Additionally, she also provided possible addresses and areas in which they lived. As was being taken home in the vehicle, a tape recorder was ?.laced within the vehicle to record any conversations within the vehicle. During the drive back to her home, made the comment " I'm like a Heidi Fleiss." (Hollywood Madam who sent girls to clients for sexual favors in California). was dropped off at her house without incident. On October 3, 2005, Sgt and I went to speak with , a sixteen year-old female who was brought to Epstein's residence by We met with mother at their front door. We ex lamed the on oing investigation and asked to speak with, as we had information that she had "worked" for N. introduced us to her husband and allowed us entry into the home. We sat in the dining room and met with Date of Birth . As she was under the age of eighteen, was advised we would be speaking with her. She expressed if her daughter had information, she wanted to assist. We interviewed., who denied havin any inappropriate encounters with M(Epstein). She stated she had gone to Jeff's house with approximately eight months ago and sat in the kitchen with the house chef, but nothing happened. As the parents were present during the interview, we felt that, was withholding information from us. She made several comments as to putting the entire incident behind her. I left myarne number and advised should she wish to speak with me again to telephone me. Sgt and I thanked for her time and left the area. She stated she would ask. again after we left as to what happened at Epstein's house. I informed her that, had my telephone number and hopefully she would call. On OctoberL42005, Det and I drove to the home and met with and dob . During a sworn taped statement, stated proximately a year ago when she was seventeen years old, she was taken to a house by . stated she knows because they both attend Royal Palm Beach High School. She was told she could make money working The foregoing instrument was sworn to or affirmed before me this r day of May, 2006 by Det who is personally known to me. Signature of Police inter (F.S.S. 117.10) Signatur Date: 05 i 06 g Officer PageSof 22 EFTA00230851 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 for Jeff. She was told she would have tipnide a massage to Jeff. stated upon her arrival to the house she was brought to the kitchen area by . They met with the house chef who was already in the kitchen area. stated would wait for her in the kitchen. was introduced to , Jeff's assistant, who brought her upstairs to the master bedroom. prepared the room and massage table for a massage. Epstein entered the room wearing only a towel and she provided a massage. stated she ke her clothes on during the massa e. She advised sometime during the massage, Epstein pulled her close to him. said she was uncomfortableitlie incident involving At the conclusion of the massage, she was paid $200.00 for the mange. I asked if she has any formal training in massii es which she re lied no. I asked her if received any monies for taking her to perform the massage. i stated had received money for taking her there but was unsure in the amount. stated she returned to Epstein's house on another occasion with and another • I stated she waited in the kitchen with , while was taken upstairs by stated she only did the massage once as she was uncomfortable with the whole experience. At the conclusion of the interview, the tape was stopped. I was informed that had attempted to reach via cell phone. A voice mail message on October 4, 2005 at 10:59 am, revealed a female voice who identified herself as who requested provided the incoming telephone number as about the police investigation because had called her to tell her about how she just received a rental car from MEpstein. had called her to tell her that she was given a rental car, a 2005 Silver Nissan Sentra, to utilize to visit family visit Epstein. be asking questions. stated asked her what was out on at the house that the police would then called Jeff and and asked what was going on reference the ongoing police investigation. AccoS to = has since then been trying to contact her to ask about the. , questions. I instructed M not to contact and do not provide any more information to as she would notify Jeff Epsteinand what was transpiring. to call her back reference the police questionin stated she inadvertently told and On October4, 2005, I made telephone contact with, who had left several messages for me to contact her. During the message, she advised she was not completely truthful when we met in person but would like to speak with me to advise what had happened. She further advised she did not want to speak of this incident in front of her mother. At approximately 3:48 pm I made telephone contact with During a taped recorded statement stated the following: approximately a year ago, when she was sixteen years of age, took her to Epstein's house twice. She knows because they both attend Royal Pal Beach High School. The first time she went, drove to the house. They entered through the kitchen area where she was The foregoing instrument was sworn to or a 3irm before me this 1" day of May, 2006 by Det who is personally known to me. Signature of Police t ficer '.S.S. 117.10) ate of Florida Coun of Palm Beach Signatur g Officer Date: 05,06 Pageloof 22 EFTA00230852 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 introduced to and Epstein. She was taken upstairs to a bedroom by who set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for, to rub on him. At one point during the massage he tried to remove her shirt, at which point she became very upset and discontinued the massage. Both and E stein had a verbal disagreement, at which time she left without being paid. She got with who was sittin in the kitchen and told her "let's go." advised she received no money for that day. also said that had told her if she was uncomfortable with what was going on, to let him know and he'll stop. She knew that the more ou do the more you get paid. advised that several weeks later she agreed to be taken a second time by . Once they arrived at the residence, sat in the kitchen and took her upstairs to the master bedroom again. set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for to rub on him. At one point during the massage he tried to touch her buttocks. As i was wearing tight jeans and had a tight belt on Epstein was unable to touch her buttocks. Epstein then rolled onto his back during the massage and then attempted to touch her breasts., then became u2set again and told Epstein she didn't want to be touched. discontinued the massage and was paid $200.00. then went downstairs where was waiting for her. She told she wanted to leave. said she never returned to the house. stated she is aware that her friend, was also at the house and had a problem with Epstein. I later researched , dob , and met with her at her residence. During a sworn taped statement, stated the following: on or about November 2004, she was approached at Royal Palm Beach High School by a fellow student asked if she wanted to make money. She agreed and was told she would provide a massage to wealthy man in Palm Beach. picked her up and drove her to a house in Palm Beach. She was brou h t into the kitchen area of the house. She further stated that fellow Royal Palm Beach High School students and ) came with them. They were brought into the kitchen where she was introduced to Epstein and other females. stated she was introduced to a female helper of Epstein, the female was described as white female (unknown name ), with blond hair. She stated that the assistant was familiar with . The assistant brought her upstairs into a master bedroom area. The assistant set up the massage table and put out lotions to be used. She told , Epstein would be available in a minute. Epstein entered the room wearing only a towel. Epstein removed his towel, and laid naked on the massage table and picked a lotion to rub on his thighs and back. further stated durhishe massage, Epstein asked her to remove her clothes. She complied and removed her pants and blouse. didn't remember if she had removed her bra but feels that she did. was certain that she stayed in her thong underwear. continued the massage and at one point she climbed onto the massage The foregoing instrument was swum filmed before me this 1" day of May, 2006 by Det , who is personally known to me. Signature of Police Officer .S. 117.10) Page-tot 22 EFTA00230853 Signature of Police Officer .S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency ORIN PLO 500600 table, straddling Epstein to massage his back. While doing this was instructed to return to the ground at which time Epstein turned to have his chest rubbed. advised she was sure he was masturbating based on his hand movements going up and down on his penis area. did not want to look at his penis area because she was uncomfortable. Epstein removed a large white vibrator which was next to the massa e table and turned it on. stated Epstein began . Shortly thereafter, Epstein ejaculated and removed himself from the table. He walked over to where the shower was and opened the glass door. She waited as he was taking a shower in her direct view. When I asked how old she was when this occurred, she stated she had just turned seventeen. At the conclusion of the shower, was paid either $350.00 or $400.00. She stated she wasn't sure, but knows it was close to $400.00. stated she never returned to provide a massage for Epstein. At approximately 2:10 pm, Det and I met with t dob , at her residence. As • was only seventeen years of age, I had notified her mother, that she would be interviewed reference an ongoing investigation in Palm Beach. I assured her that her daughter was not a suspect. I explained the possibility of her being either a witness or victim. advised she wanted to cooperate and consented to the interview. During a sworn taped statement, September 2004, she was approached by associates of and knew the same people. Beach High School, what did for Epstein. scheduled the appointment. They drove to the end of the street and entered a large drivewa . The entered the kitchen area of the house and met with Epstein. was introduced to Jeff Epstein. led upstairs to the main bedroom area and set up the room with a massage table and set out the oils. stated that while going up the stairs and into the bedroom she observed numerous photographs of naked young girls. dimmed the lights and turned on soft music. exited the room and Epstein entered the room wearing only a towel. Epstein picked oils and instructed her to rub his legs, under his buttocks, back and chest area. Epstein asked her to get comfortable. advised she did not remove her clothes. She was wearing tight jeans and a cropped tank top exposin.erbelly area. During the massage, Epstein removed his towel and laid on the massage table naked. As area, he attempted to reach down her pants to touch her buttocks area however was unable to due due to the tightness of the jeans and a tight belt. advised Epstein began to masturbate as she rubbed his chest. Epstein moaned as she rubbed his chest. She observed he was continuing to masturbate and stated the following: at the age of sixteen, during the month of for a chance to make money. was friends with had been previously told by her friends from Royal Palm called a person known to ■ as and picked up and drove her to Palm Beach to a street called "Brillo Way". The foregoing instrument was sworn to or affi— d before me this 1" day of May, 2006 by Det known to me. State-of-Florida Pagetoof 22 EFTA00230854 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 attempted to reach up her tank top and touch her breasts. • pulled back and Epstein stopped, however he kept masturbating until he climaxed. He cleaned himself with the towel he was previously wearing. was paid $200.00 for the massage and left the area. She met with who was waiting in the kitchen area and left the house. then ex lained she never provided another massage fain. She did however, go to the house with and as they took another friend of . . advised she was present when went to work for Epstein. She advised she rode over and sat in the kitchen area with to wait for . • advised while they waited for the house chef prepared lunch for them as it was almost lunchtime when they went. When was finished with the massagithey left the area. I asked . if ever told her what would be expected when she provided a massage.. stated yes, told her that a massage would be expected, ossibly naked and possibly some touching involved. . has no formal training in providin massages. . spoke about a third and last time she went to Epstein's house. drove another girl, (sixteen years of age) who is friend, to Epstein's house. M stated knew that U had made money massaging Etstein and wanted to make money herself. took them in the kitchen area of the house and introduced. to and took U upstairs to the main bedroom. M advised she doesn't know what happened as did not speak about what happened in the room. M received $100.00 from for going with her to Epstein's house and recommending E. On October 6, 2005, at 11:45 am, I met with , dob , at and explained to her why we there to interview her. She advised she was aware of the ongoing investigation. stated she had previouslzmoken with who told her she was interviewed by detectives. During a sworn taped statement, stated she knew that worked for MEpstein in Palm Beach. advised she originally had been taken to the Epstein house by , whom she met when they both attended Royal Palm Beach High School. She began going to the house when she was sixteen years of age and stated she had been there a lot of times to provide massages over the past two years. I asked her if she had formal training in providing massages, which stated she had not. advised she was told what was expected of her by providing massages and she would have to remove clothing but if she felt uncomfortable just to say and Epstein would stop pushing the issue. began providing massages and advised she kept her clothes on. She considered Epstein a pervert and he kept pushing to go further and further. explained she would keep telling him she had a boyfriend and would not be right to her boyfriend. It wasn't until recently that began removing her clothes and staying in her thong underwear to provide a massage. explained The foregoing instrument was sworn t47-61rafflutred before me this 1" day of May, 2006 by Det who is personally known to me. Signature fficer Signature of Police Officer F.S.S. 117.10) Date: 05/0 Pagetiof 22 EFTA00230855 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 Epstein wanted to be rubbed on his back and recently he began turning over and have her rub his chest as he masturbated. He would try to touch her breasts as she rubbed his chest. stated "I.would try to get away with more and more on each massage". stated Epstein would try to touch her more and on one occasion he attempted to use a massager/vibrator on her. drove to the house for the original massage. left her cell phone number and every time E stein would come into town, would call her for an appointment to "work". Each time she went, would meet her at the kitchen door area. She would bring her upstairs and prepare the massage table. advised Epstein would ask herfiestions about herself. Epstein knew she was and would be attending . I asked if Epstein knew her real age. stated Epstein did and didn't care. The most recent massage she provided was on October 1, 2005. During the massage, she asked Epstein if she could borrow one of his vehicles to visit her family and boyfriend in , Florida. Epstein had told her she could borrow one of his vehicles but later stated he would rent her a car. She continued with the massage as Epstein and . I asked if she was wearing undergarments to which she replied her thong underwear. Once he tried to touch her breasts, she would pull away from him and he would stop. was asked if he ever used a vibrator on her. was aware of the vibrator but advised she never would allow him to on her. She described the vibrator as the large white vibrator with a huge head on the tip of the vibrator. She stated he kept the vibrator in a closet near the massage table. stated that on October 3, 2005, she was contacted by Epstein's assistant, who informed her that Jeff Ean had rented her a new Nissan Sentra and she should come by the house to pick it up. informed she would have the car for a month. stated Epstein knew her car was not working properly and that she had missed appointments in the past because of her car being inoperable. explained the car is currently parked next to the Gym field. I asked her if she ever took any one to the house. explained she took , a friend of hers who attended Royal Palm Beach High School who has relocated to to attend college. I asked if she ever allowed another female in the room. advised no one was brought into the room with her. At the conclusion of the interview, Det and I went to the gym area of and located the Silver Nissan Sentra bearing Florida tag . The vehicle is registered to Dollar Rent a Car out of the Palm Beach International Airport. The vehicle was rented by Janusz Banasiack, later learned to be Epstein's houseman, and paid with Epstein's credit card. On September 11, 2005, dob was arrested by the Palm Beach Police Department The foregoing instrument was swornao r 'rime before me this 1" day of May, 2006 by Det who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State-of-Florida County of Palm Beach Signal ng Officer Date: /2006 Page leof 22 EFTA00230856 Signature of Police S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency ORD/ no 500600 for misdemeanor possession of marijuana. During the arrest told the arresting officer that she had information about sexual activity taking place at the residence of Jeffrey Epstein. Additionally, during the ongoing trash pulls from Epstein's residence, discarded papers were found which contained name and cell phone number. On October, 11, 2005, Det and I met with . and obtained a sworn taped statement. explained she had been going to Epstein's house since 2002, when she was sixteen years of age. Since then she has gone to the house hundreds of times. • stated she became his "number one girl." She explained that on her first visit she was brought to the house by fellow Royal Palm Beach Hi h School classmate, said she was brought through the kitchen area where she met . for the first time. was led to the master bedroom, Epstein s room. • explained that as she was walking up the stairs she observed several photographs of naked women alone. walls and tables of the house. • further explained that she was brought into the bedroom, where prepared the room by setting up the massage table and provided the oils for her to rub on Epstein. • explained she remembered the steam room area, which contained two large showers. Epstein entered the room from the steam room area and introduced himself. Epstein lay on the table and told her to get comfortable. . removed her skirt and kept her shirt on. Epstein then instructed her to remove her shirt. • removed her shirt and remembered she was not wearing a bra. stated she provided the massage wearing only her anties. She continued rubbing his legs, thighs and feet. advised he turned over onto his back. Epstein and be an to masturbate. Epstein ejaculated which meant the massage was over. At the conclusion of the massage, was paid $200.00. They walked together downstairs where and Shady were waiting. stated received an unknown amount of money for taking her to Epstein. Epstein instructed to leave her cellular telephone number, that he could contact her when he is in town. Elstated that during her many visits a routine was established between her and Epstein. She would enter the house and get naked in the bedroom. She would then start with a back massage. Epstein would roll on to his back and allow her to massage his chest area. • stated E • stein would then began to masturbate himself and at the same time would with his fin ex lained E • tein would continue this process until he ejaculated. He would then advised that during her frequent visits, Epstein asked for her real age, stated she was sixteen. Epstein advised her not to tell an one her real advised that thins escalated within the home as Epstein would instruct and pa IN explained the intercourse included that Epstein had at his disposal. Epstein would watch them and masturbate himself . Occasionally, Epstein would then join in The foregoing instrument was sworn t4:757.1iffilnittl before me this 1" day of May, 2006 by Det EM, who is personally known to me. State of Florida Co Signatur Date: 05/01/2006 Dicer Pagel% of 22 EFTA00230857 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 during the the time was sixteen years of age. to both and . This occurred during advised this continued to escalate during two years. The routine became familiar to E. Epstein's assistant would telephone her every time Epstein was in the Town of Palm Beach and would place appointments for her to visit and work for Epstein. Each time something new was introduced, additional monies were produced and offered for . to allow the acts to happen. • consented to perform all these acts but was adamant that there was an understanding with Epstein that no vaginal penetration would occur . . explained that Epstein's penis was deformed. • explained that his penis was oval shaped. claimed when Epstein's penis was erect, it was thick toward the bottom but was thin and small toward the head portion. called Epstein's penis "egg-shaped." • stated Epstein would photograph and her and proudly display the photographs within the home. stated during one visit to Epstein's house in which she provided a massage to Epstein, his female friend, Nada was also present. • provided the massage in which and her would for Epstein to enjoy. Towards the end of this massage, Epstein grabbed and turned her over onto her stomach on the massage table and stated Epstein began to became upset over this. She said her head was , as he continued to . She screamed "No!" and Epstein stopped. She told him that she did not want to . Epstein did not ejaculate inside of her and apologized for his actions and subsequently paid her a thousand dollars for that visit. • stated she knows he still displays her photographs through out the house. On October 12, 2005, Det and I met with , dob , who stated during a sworn taped statement, that nothing happened between her and Epstein. appeared nervous during the interview. I assured her that I have spoken with other people who advised differently. stated on several occasions sheprovided a massage to Epstein. She stated she was brought to the Epstein house in March of 2005. a classmate at Royal Palm Beach High School, approached her and asked her if she wanted to "work". made the arrangements with , Epstein's assistant. , who has no formal training in providing inasages, stated she provided a massage, fully clothed for $200.00 . As I sensed hesitancy in her. answers, I asked if she had been contacted by anyone from Epstein's organizations or his house. stated she was interviewed already by a private investigator for Epstein. He identified himself as'.' and inquired about the police investigation, and left his telephone number for additional contact. provided no additional information, as it appeared her responses were almost scripted. The foregoing instrument was sworn to or a before me this ls' day of May, 2006 by Det who is personally known to me. Signature of Police Officer .S.S. 117.10) County of Palm B ch Date: 05/01/2006 ficer Paget2of 22 EFTA00230858 Probable Cause Affidavit Palm Beach Police Department Agency OR]# FLO 500600 On November 6, 2005, at a roximately 3:30 pm, I met with , dob , at the Palm Beach Police Department. was identified as a potential witness/victim through information obtained during the trash pulls. During the sworn taped statement, advised she was at Jeffrey Epstein's house one time, approximately two months ago. She was approachedSigirl, , who was dating roommate, for an opportunity to make some quick money. advised she needed to make some quick cash to make the rent that month. She agreed to go to the house. She had been told by that the massage would have to be done in her underwear. She advised drove with her and brought her into the house. They walked into the kitchen area, and took the stairs upstairs. further stated she was brought into a master bedroom area. She advised she recalled seeing portraits of naked women throughout the room. A wearing only a towel and introduced himself as "M." At Epstein's direction, massage table was already out near the sauna/shower area in the master bedroonaiin entered the room and removed their clothing down to their panties, Epstein laid on his stomach area and they provided ante e on his legs and feet area. I asked if she had any formal massage training and she replied "no." advised she was topless and the panties she wore were the boy shorts lace panties. She and continued the massage until the last ten minutes of the massage, Epstein, told to leave the room that could finish the massage. got dressed, and left the room as turned over onto his back. Epstein then removed the towel and laid naked . Epstein requested that rub his chest area. stated , Epstein, began masturbating. stated Epstein pulled down her boy short panties, and he produced a large white vibrator with a large head. She stated it was within his reach in a drawer in his master bathroom. He advised he never with the vibrator. He continued to as he continued to masturbate. stated she was very uncomfortable during the incident but knew it was almost over. Epstein climaxed and started to remove himself from the table. He wiped himself with the towel he had on previously and went into the shower area. got dressed and met with in the kitchen area. Epstein came into the kitchen and provided $200.00 for bringing and paid $200.00 to for providing the massage. was told to leave her telephone number with for future contact. provided her cellular telephone number. was asked if she was recently contacted about this investigation by an one from the Epstein organization. She replied she was called but it was for work. She stated she was called by for her to return to "work" for Epstein. stated "work" is the term used by to provide the massages and other things. advised she declined as she was not comfortable in providing that type of "work." On November 7, 2005, Det and I met with dob . During a sworn taped statement, stated she met Jeffrey Epstein through when they were still The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det who is personally known to me. Signature of Police Officer (F.S.S. 117.10) STiffeFturida Signatu Date: 0 /2006 Officer Page lAif 22 EFTA00230859 Signature of Police 6fficer (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 attending Royal Palm Beach High School. stated she was offered to work for Epstein but declined. would approach females who wished to work for Epstein. explained that "work" meansgive massages. She was asked about any formal training in providing massages which she said "no." said she accompanied and other females who were taken to Epstein's house to provide massages. with further stated she had been to the house a roximat 4 or 5 times Aistyear. ir She accompanied M, ad . Each time the girls were taken over, they were previously told they would have to provide a massage, possibly naked. They were also told that shouldist.require them to do anything extra, and they were not comfortable just to tell him and he would stop. stated received $200.00 for each girl she brought over to massage Jeffrey Epstein. When I asked which girl appeared to be the youngest, she replied, M, who was really young, fifteen years old at the most. further stated each time she went to the house, she sat in the kitchen and waited with until the massage was over. She further stated that the cook would make lunch or a snack for them as they waited. I asked her if there was anything that caught her attention within the home. stated there were a lot of naked girls in photographs throughout the house. On November 8, 2005, at approximately 2:00pm , I met with Palm Beach Police Department. During a sworn taped stateme approximately twox ears ago when she was first approached by High School. approached her about working for Epstein and providing a massage to him for $200.00. had made the arrangements however was unable to take her the day the arrangements were made. with Epstein. with an assistant photographs of naked females throw out the house. towel, and laid on the table. stated rcked out the oils he wanted her to use and requested she remove her clothing to rovide the massage. MI stated that on the first massage she provided she did not remove her clothing. stated she had returned several times after that. Each time she returned it was more than a massage. Epstein would walk into the master bedroom/bathroom area wearing only a towel. He would masturbate as she provided a massage. stated she was unsure if he climaxed as he masturbated under the towel. Additionally, she never looked below his waist. She claimed that Epstein would convince her to remove her clothes. She eventually removed her clothes and stayed in her thong panties. On occasion,ign would use a massa er/vibrator, which she described as white in color and a large head. Epstein would as he would masturbate. stated she had been to the house take recalled she was brou and another assistant , dob at the stated she had met Epstein a classmate at Royal Palm Beach also attended Royal Palm Beach High School and was familiar there and entered through the back kitchen door. She had met brought her upstairs as she observed several stated Epstein came in the room, wearing only a The foregoing instrument was sworn to or affirmed before me this r day of May, 2006 by Det , who is personally known to me. State of Honda Cou Signature/ fficer Date: 05/01/2006 Page ttSf 22 EFTA00230860 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 numerous times. added she has no formal training in providing a massage. stated she brow t two females during her visits to provide massages. stated she brought a girl named ' ' and from Royal Palm Beach High School. stated she received $200.00 for each girl she brought. On November 8, 2005, I met with , W/F, , at the Palm Beach Police Department. During a sworn taped statement, stated she had met Jeffrey Epstein approximately one year ago. She was approached by a sulkknown to her as M. • had asked her if she wanted to make money providing massages to Epstein. had heard that several girls from Roill Palm Beach High School were doing this and making money. She agreed and was taken to the house by M.. had introduced her to - and Epstein and brou t her upstairs to a master bedroom where a massage table was prepared and the proper oils were selected. left the room and waited downstairs for her. stated Epstein entered the room wearing a towel and laid on his stomach. She provided a massage wearing only her thong panties. advised Epstein had masturbated every time she provided a massage. She stated Epstein continued to masturbate until he climaxed. Once that occurred the massage was over. She felt the whole situation was weird but she advised she was $200.00 for providing the massage. She also stated . was paid $200.00 by Epstein for bringing . stated she had gone a total of 15 times to Epstein's residence to rovide a massage and things had escalated from just providing a massa e. E stein be an touchin and grabbed her closer to him as he masturbated. Epstein also and with his hands as she provided the massage. stated on one occasion, while she was only seventeen years of age, he offered extra monies to have vaginal intercourse. She stated this all occurred on the massage table. stated and began until he reached the point of and climaxed onto the massage table. received $350.00 for her massage. 1 asked her if she had any formal training in providing massa es stated she did not continued to state on one other occasion, Epstein introduced his girlfriend, , into the massage. was brought into room with to provide a massage. Epstein had them as they provided a massage to Epstein. Epstein, watched and masturbated as this occurred. On other occasioniiiein, introduced the large white vibrator/massager in the massage. Epstein on vagina as she provided the massage. On November 14, 2005, Det and I met with , dob . During a sworn taped statement she advised she started going to the house approximately one year ago and has been there approximately five or six times. also stated she was sixteen years old when she first went to Epstein's house. On her first visit she was brought by a fellow student from Royal Palm Beach High School known to her The foregoing instrument was sworn to or affirmed a e o o before me this 1" day of May, 2006 by Cou Det who is personally known to me. Sig Officer Date: 0 006 Paget5of 22 EFTA00230861 Signature of Police ficer ( .S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency ORIN FIX) 500600 as stated brought her into the house and she was introduced to then brought her upstairs into a master bathroom, located within the bedroom. stated she met Epstein in the bathroom. He laid on the table and picked the massage oils. She provided the massage as he laid naked on the massage bed. She stated she rubbed his calves and back area. Upon the end of the massage, Epstein removed himself from the massage table and paid her $300.00 for the massage. said each subsequent time she went to the house, she was notified by that Epstein was in town and would like her to "work". stated she returned to the house and was again led upstairs by . She provided the massage, clothed. was asked if she ever removed her clothing to rovide a massage. stated it was not until the third time that she went that she removed her clothing. stated she was notified by that providing the massage when Epstein asked her to remove her clothing. Epstein wanted her to come to work. She arrived at the house and was ledisairs by . She started removed her pants, shirt and bra. She sta ed in her ad inties and . Epstein turned over onto his back and she stated she knew he was masturbating himself as she providing the massage. stated she believed he climaxed based on his breathing. She did not want to view either the climax or the fact that he was masturbating. stated once the breathing relaxed he got up and told her to get dressed. She was paid $300.00 for her services. stated on the last time she went to provide a massage, she was notified by to come to the house and "work". stated she was now dating her current boyfriend and did not feel comfortable going. She recalled it was approximately January 2005. She said she went, already thinking that this would be the last time. She went upstairs and went into the master bathroom. She met with Epstein, who was wearing only a towel, and laid onto the table. stated Epstein caught her looking at the clock on several occasions. Epstein asked her if she was in a hurry. stated her boyfriend was in the car waiting for her. further stated that Epstein got upset as he wasn't enjoying the massage. She told him that she didn't want to continue and she would not be back. Epstein told her to leave as she was ruining his massage. advised she had no formal training in providing any massages. stated although she had a falling out with Epstein, she still received a Christmas bonus from Epstein. stated she was wired money from Western Union for ber Christmas bonus. Sub oena results from Western Union revealed money was sent from Jeffrey Epstein on December 23, 2004. received $200.00 from Epstein for her Christmas bonus. On November 15, 2005, Det. and I met with II, dob . During a sworn taped statement, MI stated she met Jeffrey Epstein over a year ago. She was sixteen years of age and was approached by , a fellow Royal Palm Beach High School student, who informed her that she could make $200.00 providing a massage to Epstein. had informed her that she would have to provide this The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det who is personally known to me. State of Florida County of Palm B > ch Signatur Date: 05/0 /2006 Officer I to Page of 22 EFTA00230862 Probable Cause Affidavit Palm Beach Police Department Agency ORIM FLO 500600 massage to made the arrangements with Epstein and his assistants and took . to the house. stated = and she entered through a glass door that led into a kitchen. She was taken upstairs by , to a master bedroom. She recalled the master bathroom had a large ink couch, sauna and matching shower. Epstein entered into the room wearing only a towel. • and removed their clothing remaining only in thong underwear. She further stated that Epstein laid on his chest on the table. The oils were selected on which ones to use. Both and . provided the massage on his legs, back and feet. Forty minutes into the massage, Epstein turned over onto his back and r nested wait downstairs in the kitchen area for Epstein instructed . to finish the massage. As ot dressed, startinigLubbing Epstein's chest. left the room, and Epstein began masturbating as M stated Epstein continued masturbating until he climaxed on the towel he was wearing. When asked if he had removed the towel she stated he turned the towel around 16that the opening would allow him to expose himself. After he cleaned himself off with the towel he instructed the massage was done and to get dressed and meet with him downstairs. ot dressed and met with Epstein in the kitchen area. She was paid $200.00 dollars for providing the massage. stated she was aware that also received monies for the same thing. The second time she went to the house she was again approached by advised if she wanted to return to the house tlEovide another massage.. agreed and the arrangements were made by for her to return to the house. M stated drove her to the house and knocked on the same glass door which leads to the kitchen area. They were allowed entry into the house one of the staff members. led her upstairs to the master bedroom and master bathroom area. left . this time to do the massage alone. Epstein entered the room again wearing only a towel. • began removing her clothing as she did the last time she was at the house. Epstein instructed her to get naked. He laid on the table onto his stomach as . began massagni: his legs and back. As . finished with Epstein's back and legs, Epstein then turned over onto his back. M started to rub his chest and he began and began rubbing s vagina and masturbating himself at the same time. • stated she masturbating. As li trubbed his chest, Epstein leaned over and produced a massager/vibrator. He turned it on as this was occurring. She described the vibrator/massager as large grey with a large head. Epstein roximately two to three minutes with the massager/vibrator. He then removed the and concentrated on masturbating himself. • stated Epstein climaxed onto the towel again and informed her that the massage was done. ot dressed and met with who was waiting in the kitchen area. She received $200.00 for the massage. said she never returned to the house and had no desire to return to the house.. was asked if she received any formal massage training. She advised she had no formal training. • was asked if Epstein knew her real age. • stated he knew, as he asked her questions about herself and high school. He was aware she attended, and is still attending Royal Palm Beach High School. The foregoing instrument was sworn to or affirmed State of Florida before me this 1" day of May, 2006 by Co Det , who is personally known to me. Signature of Police Officer .S.S. 117.10) Signatur 7 g Officer Date: 0 01 006 Page of 22 EFTA00230863 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 During the course of the investigation a search warrant was executed at Jeffrey Epstein's home located at 358 El Brillo Way in Palm Beach. While in the home I observed the pink and green couch within the master bedroom area just as the girls previously mentioned. The stairway, which is located from the kitchen area to the master bedroom area, is lined with photos of naked young girls. Additionally, numerous photographs of naked young females, some of which appeared to be the girls I previously interviewed, were on display throughout the house. Also located in the house were various phone message books. The telephone message books have a duplicate copy (Carbon Copy) which, once a phone message is written into the book, the top copy is then torn on the perforated edge and the carbon copy is left in the book. First names of girls, dates and telephone numbers were on the copy of the messages. I recognized various numbers and names of girls that had already been interviewed. The body of the messages were time of the day that they called for confirmation of "work." Other names and telephone numbers were located in which the bod of the messages were, "I have girls for him" or "I have 2 girls for hint" These messages were taken by , who signed the bottom of the messages. During the execution of the warrant, I located a Royal Palm Beach High School transcript for in Epstein's bedroom desk. This desk had stationary marked Jeffrey E Epstein. I located a wood colored armoire beside Epstein's bed that contained a bottle of "Joy Jelly," which is used to provide a warm massage. Several massage tables were located throughout the second floor of the residence, including a massage table found in Epstein's bedroom. On the first floor of the residence I found two covert cameras hidden within clocks. One was located in the garage and the other located in the library area on a shelf behind Epstein's desk. A computer was located which was believed to contain the ima es from the covert cameras. The computer's hard drive was reviewed which showed several images of and other witnesses that have been interviewed. All of these images appeared to come from the camera positioned behind Epstein's desk. On December 13, 2005, Det. and I met with dob . During a sworn taped statement, stated that when she was sixteen years old she was taken to Epstein's house to provide a massage for money. stated it was before Christmas last year (2004) when an associate, approached her and asked if she needed to make money for Christmas. made arrangements to take to the house and drove to the house to "work." They were encountered by a white female with long blond hair.. was unable to remember the name of the white female with blond hair but knew she was Epstein's assistant. She was led upstairs by the white female who explained that there would be lotions out already and Epstein would choose the lotion he wanted her to use. She was led through a spiral staircase which led to a master bedroom and bathroom. The massage table was already set up in the bathroom.. described the bathroom as a large spacious bathroom with a steam room and shower beside it. • was introduced to Epstein who was on the phone when she entered the room. Epstein was wearing a white towel and laid on his stomach, that ■ may The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det who is personally known to me. State of Florida Coun of Palm Be h Si Signature of Police Gfftcer (F.S.S. 117.10) Date: 05 Dicer Page of 22 EFTA00230864 Probable Cause Affidavit Palm Beach Police Department Agency ORD FLO 500600 massage his feet and calves. • started the massage with the oils Epstein chose and rubbed his feet and calves. Epstein got off the phone and requested she massage his back as well. • began rubbing his back and got to the small of his back. During the rubbing of his back, Epstein asked her to gtcomfortable. He requested she remove her pants and shirt. • removed her shirt and pulled her pants off. • stayed in her bra and thong panties. As she finished massaging the small of Epstein's back, he then turned onto his back. Epstein instructed to rub his chest and pinch his nipples. As she Epstein asked her questions about herself. • remembered telling him she attended Royal Palm Beach High School. Epstein asked her if stated she was shy and didn't like talking about those things. She continued she was sexually active. Before could answer, he also asked what sexualposition does she enjoy. • . Epstein reached u and uns her bra from the front. • explained the bra she used had a front snapping device. Epstein and asked her if she like having said "no, I don't like that" Epstein then removed his towel and laid on the bed naked exposing his penis to . He be an touchin his enis and masturbated as he explained Epstein then touched tensed up and stated Epstein was aware that she was uncomfortable. stated that Epstein said to her, "Relax, I'm not going inside." She further explained Epstein commented to her how beautiful and sexy she was. Epstein then moved her thong panties to one side and began said, "He commented how " He then . She tried pulling back to Epstein and apologized for siDurn llis time, he kept his and continued to rub her vagina. stated he as he was masturbating. said he climaxed onto the towel he had been previously wearing and got up from the table. Epstein told her there was $200.00 dollars for her on the dresser within the master bathroom. Epstein also told her that there was an additional $100.00 that was to be given to for bringing her there to massage him. Epstein told her to leave her telephone number with his assistant as he wanted to see her again. Epstein stated his assistant would contact her to work again soon. I asked her if she ever received any formal massage training to which stated she did not. stated it was the only time she ever went to work for and knew what happened to her was wrong. She further stated that she had never been contacted for any additional work. On January 9, 2006, I located and interviewed another victim, dob . was identified as a potential victim/witness from information obtained during trash pulls from Epstein's residence. stated she met Epstein when she was fifteen years of age. She was approached by a friend from Royal Palm Beach High School, to be taken to Jeffrey Epstein's house to work. She was originally told she would be able The foregoing instrument was sworn to or affirmed State of Florida before me this ln day of May, 2006 by Coun Det who is personally known to me. Signature of Police Officer F.S.S. 117.10) Signatur Dicer Date: 05 Pagel9of 22 EFTA00230865 Probable Cause Affidavit Palm Beach Police Department Agency ORIN PLO 500600 to model fin erie for a wealthy Palm Beacher. . was taken to Epstein's house located on El BrilloWay. introduced to Jeffrey Epstein. Epstein had his ersonal chef prepare dinner for . and . At the conclusion of dinner, = and Epstein brought . upstairs into a master bedroom area. observed a large massage table with a sheet on it. Epstein entered through a door and exited wearing only a towel. informed . that they were oing to provide a massage on Epstein.. asked why were they doing this instead of modeling lingerie. ex lathed to . that this was his routine and to rub his calves and feet. Epstein had told . to get comfortable. removed her pants and blouse. . stated she stayed only in panties as she did not wear a bra that evening. stated while rubbing his calves and feet, Epstein turned over onto his back. Epstein told . to rub his chest and rub his ni les. stated that as she started , Epstein began masturbating himself . Epstein and with his fingers. Eetein continued to masturbate himself as he Epstein ejaculated on his towel and paid . $200.00 for the massage. Sa in told . that if she told anyone what happened at his house that bad things could happen. and = were brought home by Epstein's houseman and . was afraid that Epstein knew where she lived.i i stated that several days later she received a telephone call from who coordmated for to return to "work." . returned to the house and was brought to Epstein's bedroom area by who prepared the room for the massage. Epstein entered the room wearing only a towel. Epstein had remove her clothing and provide the massa e naked. be an rubbing his feet and calves and Epstein turned over onto his back. Epstein . E stein be an to masturbate himself with an upwards and downward motion on his penis. Epstein continued with one hand and masturbate with the other hand. Once Epstein ejaculated onto the towel he was wearing, the massage was over. . was paid $200.00 for the massage. Epstein again told . not to speak of what happened at his house or bad things would happen. . wanted to notify authorities however she was afraid of what would happen to either her or her family. During the course of the investigation, several subjects were identified as a potential witness/victim through information obtained during the trash pulls, physical surveillance and telephone message books retrieved from the search warrant. While conducting research on the subjects, I discovered that the females were age eighteen or older. Interviews were conducted on the consenting adults whose statements provided the same massage routine when they went to "work" for Epstein. The females would be notified by and made appointments for the females to "work" for Epstein. The females would come to Epstein's house and were led upstairs, through a stairwell from the kitchen area, by to Epstein's bedroom. Epstein would then enter the room wearing only a towel, and ask them to et comfortable. The females would then provide the massage naked as Epstein would either and/or utilize the massager/vibrator on The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det , who is personally known to me. Signature of Police fficer (F.S.S. 117.10) Fltieftta County of Palm Bea Signal Date: 05/0 Page2f 22 EFTA00230866 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 He would masturbate during the massage and upon his climaxing, the massage would end. The girls were then paid two or three hundred dollars for the massage. On November 21, 2005 I interviewed Jose Alessi, a former houseman for Jeffrey Epstein. Alessi stated he was employed for eleven years with Mr. Epstein, from approximately 1993 through 2004. Alessi stated he was the house manager, driver and house maintenance person. It was his responsibility to prepare the house for Epstein s arrival. When asked about cooks or assistants, Alessi stated they traveled with Epstein on his private plane. I asked Mr. Alessi about the massages that have occurred at Epstein's home. Alessi stated Epstein receives three massages a day. Each masseuse that visited the house was different. Alessi stated that towards the end of his employment, the masseuses were younger and younger. When asked how young, Mr. Alessi stated they appeared to be sixteen or seventeen years of age at the most. The massages would occur in Epstein's bedroom or bathroom. He knew this because he often set up the massage tables. 1 asked if there were things going on other than a massage. Alessi stated that there were times towards the end of his employment that he would have to wash off a massager/vibrator and a long rubber penis, which were in the sink after the massage. Additionally, he stated the bed would almost always have to be made after the massage. On January 4, 2006 I interviewed another former houseman, Mr Alfredo Rodriguez. During a sworn taped statement, Mr. Rodriguez stated he was employed by Jeffrey Epstein for approximately'six months, from November 2004 through May of 2005. His responsibilities as house manager included being the butler, chauffeur, chef, houseman, run errands for Epstein and provide for Epstein's guests. I asked Rodriguez about masseuses coming to the house. Rodriguez stated Epstein would have two massages a day. Epstein would have one massage in the morning and one massage in the afternoon everyday he was in residence. Rodriguez stated he would be informed to expect someone and make them comfortable until either or Epstein would meet with them. Rodriguez stated once the masseuses would arrive, he would allow them en into the kitchen area and offer them something to drink or eat. They would then be encountered by either or Epstein. They would be taken upstairs to provide the massage. I asked Rodriguez if any of the masseuses appeared young in age. Rodriguez stated the girls that would come appeared to be too young to be masseuses. He stated one time under Epstein's direction, he delivered a dozen roses to Royal Palm Beach High School for one of the girls that came to provide a massage. He knew the girls were still in high school and were of high school age. I asked Rodriguez about the massages. He felt there was a lot more going on than just massages. He would often clean Mr. Epstein's bedroom after the alleged massages and would discover massagers/vibrators and sex toys scattered on the floor. He also said he would wipe down the vibrators and sex toys and put them away in an armoire. He described the armoire as a small wood armoire which was on the wall close to Epstein's The foregoing instrument was sworn to or a wme before me this 1" day of May, 2006 by Det , who is personally known to me. Signature of Police (flee (F.S.S. 117.10) PageL‘f 22 EFTA00230867 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 bed. On one occasion E stein ordered Rodriguez to go to the Dollar rent a car and rent a car for the same girl he brought the roses to, i that she could drive her self to Epstein's house without incident. Rodriguez said the girl always needed rides to and from the house. Rodriguez produced a green folder which contained documents, and a note with Mr. Epstein's stationary with direction to deliver a bucket of roses to Royal Palm Beach Hi gil chool after high school drama performance. Also in that same note was direction to rent a car for and direction to extend the rental contract. During the course of the investigation, subpoenas were obtained for cell hone and home phone records from several victims and witnesses along with the cell phone records of An anal sis of these records was conducted which found numerous telephone calls were made between and the victims. These records indicate the dates the calls were made are consistent with the dates and times they victims/witnesses stated they were contacted. Specificall i ri, The phone records showed called during the exact times and dates when victim advised the incident occurred. also coordinated the encounters with ., ., m and during the time frame the girls stated they occurred. Pursuant to a lawful subpoena I obtained Epstein's private plane records for 2005 from Jet Aviation. The plane records show arrival and departure of Epstein's lane at Palm Beach International airport. These records were coria.to the cell phone records of This comparison found that all the phone calls made to and the victims were made in the days just prior to their arrival or during the time Epstein was in Palm Beach. Therefore, as Jeffrey E stein who at the time of these incidents was" one years of age, did have vaginal intercourse either or digitally with and , who were minors at the time this occurred, there is sufficient probable cause to charge Jeffrey Epstein with four counts of Unlawful Sexual Activity with a Minor, in violation of Florida State Statute 794.05(1), a second degree felony. As Epstein, who at the time of the incident was fifty two years of age, did use a vibrator on the external vaginal area of a fourteen year old minor, there is sufficient probable cause to charge him with Lewd and Lascivious Molestation, in violation of Florida State Statute 800.04 (5), a second degree felony. The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det , who is personally known to me. Signature of Poli State of Florida Cou Signa ure r j s tar .S.117.10) Date: 05/ Page24f 22 EFTA00230868 IN 9 ; EFTA00230869 REQUEST FOR WARRANT DEFENDANT: DATE OF BIRTH HABITUAL OFFENDER: YES NO A/K/A VICTIM RELATED / ACQUAINTED WITH DEFENDANT? YES AGENCY CASE NUMBER: 95-368 (3) LEAD OFFICER: XX NO AGENCY: PALM BEACH POLICE DEPARTMENT CURRENT SHIFT HOURS: 8 am TO 5 um PHONE NUMBER: DAYS OFF: LEAVE / SHIFT CHANGE INFO: WAS ARREST MADE FOR, OR IN CONJUNCTION WITH ANOTHER AGENCY. IF SO, WHAT AGENCY?: SENTENCING RECOMMENDATIONS: CONTACT DETECTIVE ADDITIONAL COMMENTS: FILING DOCUMENTS ATTACHED: 1 ARREST FORM P.C. AFFIDAVIT (2 COPIES) WITNESS / EVIDENCE LIST Pfte41O49.:( Qs) lb NA. Waoli(ainne SWORN STATEMENT OF MATERIAL WITNESS(FS) )( OFFENSE REPORT (2 COPIES) ACCIDENT REPORTS (ALL) WHIM, STATEMENTS (ALL) zagatigraggazi mArca047 REQUEST FOR CONVICTION LETTERS PROPERTh RECkIPT/K2VICItay 5 hal VEILFLE 74/ REdflevele￾OTHER ATTACHMENTS INCLUDE: INITIAL FOR COMPLETENESS: DELIVERED BY: JR gat re os Vs res": tux￾MAUI_ RECEIVED, STATE ATM • T Kl% ,~'S OFFICE ON: r 51%t ix te" r•-• f:4 o'14r.; OFFICER DATE 7915 IDS 050106 ID r DATE BY: EFTA00230870 LCO-DEF. I DEFENDANT I ADMINISTRATIVF I eraTaarter , , . 1 1 1_ 1 1_ ARREST/ NOTICE TO APPEAR I Mott 3 Reguerg for Warrant Juvenile Referral ROCCA 2 N T A 4 Rogues t lot Loa ri Mn. -- ! Agercy OP4 WNW R.O I 5'0,0'6'0.0 Agency Name PALM BEACH POLICE DEPARTMENT rem*/ Regal *new (N.T.A a catty) 7 16H t LI l i_ i l i I(I_ 1 I) toher.T_T0T :0 1. Felony o a Maclernearta OS. Ofgaance i„,-.701.,—, _coa 7,06,Famy 0 4. Trartrt Medemeanot o 1 new 'Ens lir Wagon Soma Type 1_48a"- i Woman darns/ (Waft laac4 asSineal Lannon Cl Menses (Duane% Name. Maws) Inscaor _ • Date of Acres( Time of Anal Beau% Dam Seelefc al* ail Dale Jar lime Lorton of Vehicle • urge • rrf aria ❑ CaDelenasni Name Bast. Aral WPM/ _i Race Set DLO of Rum LL I. ARMS . FelOny OZ. AI Law 4. tesciameanOf 5 awn'. Paint Nan* BAS) (verve) pane) Wm Prone § M cCUAIOSfin ( I to Artdreiss (Street. API- Nunn') (OM (Steil Rol Sueness Plana II ) : L: 1.1 TOT JAC Due =ins above WSW was prowled by O defranclan and /or ID Oehicrtani s parents Pre crap and / or parent was laid to keep Ole AAP.* Gain 0464 Oera Mane 3%2526) Warted Cl any Change Cl ad Fl Yea, by Pen) U No (Reason) Grade Regan, Crime? j Deeapeon of Property 0 Yee 0 No LchociAffsert•CI Vette of Rtgany R. Smuggle K I:Alpena, 1.1 Man-is:NW Ptigah" S. t Tantrfic 0. P. Peewee Ustnr '' O.w0Ae GPI Z Other Drug Type B. Use H. HalluDagan P Paragnernater U Unworn-. N NA C. Cocaine A. Arrpaytanyne E. Henan M. Macipana Eguaneet O OpurryDeriy. S meoc Z Other 8 Chap Desaplin Cats n IC:maw Nana Y 0_11 Sow* Vlolton Hurter . - I 1 1. 1 I 1 I Ill I 1_ I Nation dORD a 1CMG eaney DripType Amount/Unit Offense a Tense(Cams Norte Bonn C :- *ANN °snow, _ Counts oc r ?In N Statute Yetabon Number I I IA 1 I i Ill I 1 I ) v.aaeo' Cl OP D e Drug Acetify Drip Type Mown / UNI Cana I Warrant /OWNS Numb. I Borg 11 CHARGEtamp 04.0100o Counts Doane< 8°1'11'16 N Statute Voblion Kong. I I I - I 1 I 1 III 1 1 I Holahan o OFI0 a ) Drug Acaly Drug Type lArroal / Ufa _tonna I Waren( / Capes Number Bong w ° Charge Dasataton Cases j Oomalie o _ %ler 6N Sala VIcisoon Nolte L i_ II 1_ i i El 1_ 1 _Lt Yolnon of ORD a 1 rDrug Amery Drug Pipe row/ LIM Maw a !Named I GOSS None arc Q 0 Instrusion No. I Mialleaaffearence In Cast 0 2 ata vou Loose (C Room Nuinbit. Pee/ ri nif,kabitf_ . 'DOW but MIMI Can DWI and DIM 44-- O WNW an m' : aloe. _ Lae DeT War Time A.M. PM I' O ID ft I AGREE TO APPEAR AT THE TIME AND PLACE DESIGNATED TO ANSWER THE OFFENSE CHARGED OR TO PAY TIE FINE SUBSCRIBED I UNDERSTAND THAT SHOULD I WILLFULLY FAIL TO APPEAR BEFORE THE COURT AS REWIRED BY THIS NOTICE TO APPEAR. THAT I MAY BE HELD IN CONTEMPT OF COURT AID A WARRANT FOR MY ARREST SHALL BE ISSUED. 2 Swabs' a Deterclant for arena and Parini i CoPecten) Dale Signed HOLD for other Agency Nano: Scow...a of Artesag Oats x ire Yenficaeon (POND by Mellen) 3 0 Dangerous 0 ROSINS Melt Nana of Atrefitag Carter (Print) I.D. 0 (PRINT) i 0 Emoidal 0 Ohan : - PAGE Intalw Gip* Me Pouch Tansport," Officer (0. 1 Agency Wawa here d sub*. signed *eh an 'X'. OF DISTRIBUTION: WHITE — COURT COPY GREEN — STATE ATTORNEY YELLOW — AGENCY — JAM. .3.21.0 • DEFENDANT (N.T.Aa ONLY) EFTA00230871 cots Numbs _a_ i ARREST / NOTICE TO APPEAR 1 Meg 3 Request for Warren. Juvenile Referral Report 2 N TA 4 Request for _ Juvenile r g Agency OM Monism FLOI 5 1 0 10 16, 0 1 01 Ppm lime Ripon PALM BEACH POLICE DEPARTMENT 1_7_i_B Number (N.T.A's only) id i I-I 1 t i 1 i 1(1 L I) = ITTmien " 01. Felony 0 3. Modeareanor Os Ordinance eli rnter Tgme %%von Seized M D2. Trate/ Felony 0 4. Tr c Mrsdeneenor OS Other E Lb) :00 r:Z:r C I of Arrest (Indueleg Named fluoneeg tlecelion el Climes Mumma Name. Address) I S LOCUM Deis of Amest I rm TOM CO Arreel I I I 1BookIng Dam Booking Ime Jet Dew ,Nil Tbne Localion or %Wide Name (Last Rest meow Aids (Num. DOG. Soc. Sec. I. El4 Rao, . Whim I . Mumma Indere B- Bleck 0 - Cromal/Aszenl Sex ID* et EMS 1 _1 1 1 _1 1 Hii,tt En Color Her Color Congemion Bub W Sart Marks. Tattoos. Unique Penns' Feidures (Location. Type. Desartlom I rat Siam ROOM Indicabon ol: Alcottl Miura PI ugt 0114 (MOW 0 0 il8 Meal Aches (Street. Apt Number) (O1Y) • Stale) (re) Phone ( ) Residence Type: I. ON 3. Florida 2. County 4. Oul °law Penning' Address (StreetAm Nurrton (City) ,S(4(0, (20P) Phsne ( ) Address Scarce Business Address (Name. Street) (City) : Stat0i (DO) Phone ( ) OCcumbon OA. Number. State Sec Sec Hunter ttuS Number Nem of Dinh (Otte Stele) u: 8 g Co-Defendant Name (Lest flit 04.000 Race Sex Date ol Eton (JlyCeuenehip 8 ;. Z`"" 1[41,d.. Co-Delelidant Hartselle:A Ent. lAdezet Race Sea Date ot Gm B :rite] 3. rear 4. Marmon*: ILI z i L Na na (Last) (Fag goads) p p O al mpustodian Residence Prone I 1 Address (Steel. API. Number) (Oh/ (Swig 00) 13411(4443 PhOnt ( I TOT JAC ale Tem 1T0he ab seep t heseadrerzycialri outdid fi.mks Viri9 idrendvit arc la 0 delibriclar warms. sgnoT :t, Mid and/or parent was me 0 Yes, by: (Narnt 0 No (Reason) Wag Aliemleil Grade PrOIX44/ ChM'? 0 Yee 0 No of Popery Value ol Property OM,* 8 selD•Sai0on IDA_ H. Smuggle K Casperde M. Manlarr i e. LOMB Dave Eitype EL gartitursie N. NelUoinogen P. Paraphernalia/ U Uranown paVAAe C. Cocaine 1A Manson Eoupment P Possess T. T o E Use Pera 2 Other A Amphetamine E. Heroin 0. 9;ilurniDerie S i c i g 0.2* Charge DescadeOn Oomeelic I Caunis [VR Staiube %baton Mate i I U I 1_ i RI i I I - Wolabon of COD r -1 0.4 1,- , ,....-,v- Cieense a Warrant /Copies Number Bond I o Charge Desoipeon Cants Domestic Wym 0 Y ON Mabee Noielion MAYON I I_ U I I 1_ PI 1 _1 I Memnon co ORD • Ong earn I Diug Type !Amount r UM Offense I Wamrd / Capes 1411111014 Bend I . Charge Desageroll Counts Domestic Whence OY ON Statute McMahon Number I I 11 I i i Id I_ 1 1 Von,/ of ORD • 0 Drug Away I Drug Type Amount/Unit Oflense i Warrant /CCM& Number Deed Champ Desonotion Counts Domesto vil3 m Sine Stelatton Patents i I 1.1 1 i t 1 (1 1 1 1 AVolabon tit ORD a I Ong AcMity J Drug 7gbe Amount / UM Meng lt Weleill / Cala Menhir I Bond 1 2 U I sir,. 0 Ineem Merdel zeon It. I aYAPPelrent• in Caul Lemon (Coen. 41O4411Ntentel. Address, 0 instuction No. 2 You need hot epos in Court tut mat Can Dale end lime --toreplyvies b......ols... -,.. Rea.— OS. Month Day Year Time AM. PAC I AGREE TO APPEAR AT TIE TIME AND PLACE DESIGNATED TO ANSWER TIE OFFENSE CHARGED OR TO PAY TIE FINE SUBSCRIBED. I UNDERSTAND THAT SHOULD 1 WILLRALY FAL TO APPEAR BEFORE THE COURT AS REQUIRED BY THIS NONCE TO APPEAR THAT I MAY BE HELD IN CONTEMPT OF COURT AND A WARRANT FOR MY ARREST SHALL BE ISSUED. of Defendant (or Jimmie end Parse ?Custodian) Dale Shred i 5 3 < HOLD for other Agency Name: Sonatina of Artes:mg Ofrcer X Name WirtiabOtt (Printed by Armor* t—, O oanopious 0 Radii° Arrest NM, Ol Arresting Once (Prop I.D. it (PRINT) 0 Suickla 0 any . PAGE intake Cucuta I D e Pouch Transponing Officer ID. a *MI Wives here i awed Signed non an t. —CC — DISTRIBUTION: WHITE — COURT COPY GREEN — STATE ATTORNEY YELLOW — AGENCY PINK — JAL GOLD. DEFENDANT Mike OILY) EFTA00230872 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 Police Case#: 05-368 (3) Defendant: Race/Sex: White Female DOB: Charges: Lewd and Lascivious Act on a child under 16 years of age 800.04(6)(2b) From March 15, 2005, through February 2006, the Palm Beach Police Department conducted a sexual battery investigation involving Jeffrey Epstein, and . Sworn taped statements were taken from five victims and seventeen witnesses concerning massages and unlawful sexual activity that took place at the residence of Jeffrey E stein, 358 El Brillo Way, Palm Beach. Several of the victims were recruited by and brought to the residence by to perform massages for Epstein, for which received monetary compensation. During the visit they would be introduced to , Epstein's assistant, who in turn would record their telephone numbers and name. The victims would be brought to Epstein's bedroom to provide the mac-gage. Epstein would enter the room and order the victims to remove their clothing to provide the massage. As the victims complied and provided the massages, E stein would On occasion, Epstein would introduce a massager/vibrator and as they provided the massage. On three separate occasions, Epstein had intercourse and inserted his penis/fingers in the victims vaginas. At the conclusion of the massages the victims were paid sums of money ranging from $200 - $1,000. The facts, as reported, are as follows: On 03/15/2005, A fourteen year old white female, hereinafter referred to as.," dob , and her family reported unlawful sexual activit which occurred at a residence within the Town of Palm Beach. reported that a stitect known to her as "M' had touched her vaginal area with a vibrator/massager while within his residence. "M' was later identified as Jeffrey Epstein through a photo line up. During a sworn taped interview, stated that dob , a cousin of boyfriend and classmate at Ro al Palm Beach High School, worked for a wealthy man and did sexual favors for him. She also admitted that had offered her an opportunity to make mone . During the beginning of the month of February 2005 explained that she was first approached by to o with her to Epstein's house. stated that alial with a Hispanic female, later identified at , rck her up at her father's house on a Sunday. IN was not sure of the exact dates but knew it was a Sunday. i told her father that they were going shop", in reality drove them to Palm Beach. Durirsthe drive a conversation occurred between and whereas reportedly told that if Masked her age, The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by D Ily known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida Date: 05/01/2006 Pagel of 22 EFTA00230873 Probable Cause Affidavit Palm Beach Police Department Agency ORM F1A) 500600 she should say she was eighteen. It was later confirmed by the S's father that picked his daughter up on February 6, 2005. According to father, drove a pick up truck. ISdescribed Epstein's house as a two-story pink house with a Cadillac Escalade parked in the driveway. She recalled that Jeffs house was on a dead end street. Upon arriving at the house stated that they walked up a driveway, ast what appeared to be a small guard/security room. A male approaching them asking what they wanted. stated they were there to see Epstein. The male allowed them to continue walking up to the house. stated the man told them that Epstein was not there but was expected back. He allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside. Shorn thereafter, Epstein and his assistant, described as white female with blond hair and later identified as , entered the kitchen. Epstein introduced himself to S. described Epstein as being approximately forty-five years old, having a long face and bushy eyebrows, with graying hair. and Epstein left the kitchen leaving alone in the kitchen. They returned a short time later. They all spoke briefly in the kitchen. was instructed to follow upstairs. recalled walking up a flight of stairs, lined with photographs, to a room that had a massage table in it. Upon entering the room there was a largamthroom to the right and a hot pink and green sofa in the room. There was a door on each side of the sofa. recalled there S1 t: a mural of a naked woman in the room, as well as several photographs of naked women on a shelf. told the victim that Epstein would be up in a second. Epstein entered the room wearing only a towel and told S to take off her clothes. S stated Epstein was stem when he told her to take off her clothes. IS said she did not know what to do as she was the only one there in the room, she took off her shirt leaving her bra on. Epstein had removed his towel and told the S to take off everything. i stated Epstein was nude when he took his towel off, placing it on the floor as he laid down on the table. stated she then removed her pants leaving her thotpanties on. Epstein then instructed her to give him a massage pointin to a specific lotion for her to use. As . began to give E stein the massage, he told her to et on his back. stated she straddled herself on Epstein's back whereby . said Epstein was specific in his instruction to her on how to massage him, telling her to go clockwise or counter clockwise. Epstein then turned over and instructed S to massage his chest. S was now standing on the ground and resumed massaging Epstein's chest area. S stated Epstein held onto,the small of her back as she massaged his chest and shoulder area. Epstein then turned to his side and started to rub his penis in an up and down motion. Epstein then pulled out a purple vibrator and The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Coun of m Beach Det who is personally known to me. State of Florida Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Pag62 of 22 EFTA00230874 Signature of Police Officer (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency ORO FLO 500600 IMIstated there was no penetration as the recalled Epstein ejaculating because he had to use the towel to wipe himself as h of he table. Epstein then left the room and . got dressed. She went back downstairs where she met with. . said she was paid three hundred dollars in cash from Epstein. Before she left, Epstein asked ve her phone number. As M, and were leaving the house, told M she received two hundred dollars that day for bringing her. During the course of the investigation, parental consent was granted for to assist with the investi ation. At our direction conducted controlled taped phone calls to cellular telephone . . spoke with in an attemsrange another meeting with Epstein. . asked , what did she need to do to make more money. stated, "the more you do, the more you get paid." had sub uently called back . and left a voice mail message for her indicating that she had set up an a intment for IN to go to Epstein's house at 11:00 am on April 5, 2005. This message was recorded from s voice mail. Based on the above, trash pulls were established at Epstein's residence with Supervisor Tony Higgins of the Sanitation Bureau of the Town of Palm Beach. The trash pull from April 5, 2005 revealed Mone message for Epstein which stated and n's name at 11:00 am. This was the time frame had informed to be ready to go work at Epstein's house. On October 3, 2005, Sgt % and I went to residenceand viewed her vehicle parked in the driveway, a red Dodge Neon. Sgt. and I knocked on the door and met with was told that we were investigating a claim involving Jeffrey Epstein of El Brillo Way, in Palm Beach. was asked if she would accompany us back to the police station for further questioning. She was also told that at the conclusion of the interview she would be returned home. voluntarily came with us back to the Palm Beach Police Department. Upon our arrival at the police station, was brought to the interview room in the Detective Bureau where I obtained a taped, sworn statement. I began the interview by asking how she became acquainted with Epstein. stated that approximately two years ago, just after she turned 17 of age, she was approached by a friend named at the Canopy Beach Resort in Rivera Beach. was asked if she wanted to make money. She was told she would have to provide a massage and should make $200.00. thought about the offer and agreed to meet with Jeffrey. The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Coun of 1m Bea h Det , who is personally known to me. State of Florida Signature Officer Date: 05/01/2006 Page3 of 22 EFTA00230875 Signature of Police Officer (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency ORIN PLO 500600 (Unknown last name) and Tony (Unknown last name) picked up and she was taken to Epstein's house. Upon her arrival to the house she was introduced to Epstein in the kitchen of the house. She was also introduced to a white female known to her as . She was led upstairs to the main bedroom known to her as .Epstein's bedroom. arranged the massage table and covered the table with a sheet. She brought out the massage oils and laid them next to the massage bed. , then left the room and informed would be in, in a minute. • entered the bedroom wearing only a towel. He removed the towel and laid nude on the massage table. He laid on the table onto his stomach and picked a massage oil for to rub on him. Duritlamassage, stated "He tried to touch me and I stopped him." I asked how he tried to touch her. stated that Epstein and she felt uncomfortable. told Epstein, I'll massage you but I don't want to be touched. stated she performed the massage naked. At the conclusion of the massage, Epstein paid $200. After the massage Epstein stated to that he understood she was not comfortable, but he would pay her if she brought over some girls. He told her the younger the better. stated she once tried to bring a 23 year old female and Epstein stated that the female was too old. stated that in total she only remembers six girls that she brow t to .pstein, se each time she was paid $200. stated she had brought the followin irls: , ( al6 year old female), (a 16 year old female) and ar said that at the time she brought theseg to Epstein's house they were a1114 through 16 years of age. I asked which one was the youngest. advised was the youngest as she was fourteen when the massage occurred. stated every girl she brought knew what to expect when they arrived. They were told they would provide a massage, possibly naked, and allow some touching. I asked her if was aware. She stated every girl she brought knew what to expect. She lained she knew that wanted to make money. She approached and explained about going to work for M, agreed and arrangements were made to brin her to Epstein's house on a weekend. stated that she and (Later identified as ) picked up at her house. stated that at that time she was driving a red pickup truck. They traveled tatein's house and entered through the kitchen door. They met with the house chef and Epstein's assistant was introduced to Epstein while the were in the kitchen area. led upstairs and Epstein went upstairs. When the massage was over returned to the kitchen area. stated she was paid $200.00 for bringing to Epstein's house. stated told her she was paid $300.00 for the massage. stated that was the last person she brought to Epstein's house. She had changed her cellular number to avoid being contacted by She continued stating that she had no direct contact with Epstein The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Co Det , who is personally knoll n to me. State of Florida Signature icer Date: 05/01/2006 Paget tof 22 EFTA00230876 Signature of PoliceOfficer (F.S. '. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency OWN FLO 500600 when he was going to travel to Palm Beach. said when Epstein announces to his assistant, that he is traveling to Palm Beach, would then contact to arrange girls to "work" for Epstein. stated that once her parents discovered that she was visiting Epstein, the disapproved of the encounters with him and she stopped. further stated that still tries to call house and leaves messages. Sgt entered the room and explained to that based on her own statements, she had implicated herself by bringing underage girls to Epstein's house. provided cellular telephone numbers for the girls she had mentioned previously. Additionally, she also provided possible addresses and areas in which they lived. As was being taken home in the vehicle, a tape recorder was laced within the vehicle to record any conversations within the vehicle. During the drive back to her home, made the comment " I'm like a Heidi Fleiss." (Hollywood Madam who sent girls to clients for sexual favors in California). was dropped off at her house without incident. On October 3, 2005, Sgt and I went to speak with a sixteen year-old female who was brought to Epstein's residence by We met with mother at their front door. We explained the ongoing investigation and asked to speak with I as we had information that she had "worked" for Jeff. Mrs. ,S introduced us to her husband and allowed us entry into the home. We sat in the dining room and met with., Date of Birth . As she was under the age of eighteen, was advised we would be speaking with her. She expressed if her daughter had information, she wanted to assist. We interviewed,, who denied havin any inappropriate encounters with Jeff (Epstein). She stated she had gone to Jeff's house with approximately eight months ago and sat in the kitchen with the house chef, but nothing happened. As the parents were present during the interview, we felt that, was withholding information from us. She made several comments as to putting the entire incident behind her. I left my telephone number and advised should she wish to speak with me again to telephone me. Sgt and I thanked for her time and left the area. She stated she would ask, again after we left as to what happened at Epstein's house. I informed her that I had my telephone number and hopefully she would call. On October 4, 2005, Det and I drove to the dob During a sworn taped statemen when she was seventeen years old, she was taken to a house by because they both attend Royal Palm Beach High School. home and met with and state.pproximately a year ago stated she knows She was told she could make money working The foregoing instrument was sworn to or affirmed before me this P' day of May, 2006 by Det who is personally known to me. State of Florida Coun of P Beach Signatur Date: 05 /2006 Officer PageCof - 22 EFTA00230877 Signature of Police Officer (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 for e She was told she would have to provide a massage to II. stated upon her arrival to the house she was brought to the kitchen area by . They met with the house chef who was already in the kitchen area. stated would wait for her in the kitchen. was introduced to , Jeff's assistant, who brought her upstairs to the master bedroom. prepared the room and massage table for a massage. Epstein entered the room wearing only a towel and she provided a massage. stated she ke her clothes on during the massage. She advised sometime during the massage, Epstein the massage, she was paid $200.00 for the massage. I asked pulled her close to him. said she was uncomfortable .he incident involving . At the conclusion of if she has any formal training in massy which she lied no. I asked her if received any monies for taking her to perform the massage. f re , stated had received money for taking her there but was unsure in the amount. stated she returned to Epstein's house on another occasion with and another irl stated she waited in the kitchen with , while IM was taken upstairs by stated she only did the massage once as she was uncomfortable with the whole experience. At the conclusion of the interview, the tape was stopped. I was informed that had attempted to reach via cell phone. A voice mail messy e on October 4, 2005 at 10:59 am, revealed a female voice who identified herself as who requested to call her back reference the police question provided the incoming telephone number as stated she inadvertently told about the police investi ation because had called her to tell her about how she just received a rental car from Epstein. had called her to tell her that she was given a rental car, a 2005 Silver Nissan Sentra, to utilize to visit family visit Epstein. asked her what was oin on at the house that the police would be asking questions. stated then called and asked what was going on reference the ongoing police investigation. Accordin to has since then been trying to contact her to ask about the lice questions. I instructed not to contact and do not provide any more information to as she would notify Epstein and what was transpiring. and On October4, 2005, I made telephone contact with, who had left several messages for me to contact her. During the message, she advised she was not completely truthful when we met in person but would like to speak with me to advise what had happened. She further advised she did not want to speak of this incident in front of her mother. At approximately 3:48 pm I made telephone contact with During a taped recorded statement, stated the following: approximately a year ago, when she was sixteen years of age, took her to Epstein's house twice. She knows because they both attend Royal Pal Beach High School. The first time she went, drove to the house. They entered through the kitchen area where she was The foregoing instrument was sworn to or affirmed before me this Pt day of May, 2006 by Coun of Palm Beach Det , who is personally known to me. State of Florida ignatur cer Date: 05/01/2006 Page l'of 22 EFTA00230878 Signature of Police Officer (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 introduced to and Epstein. She was taken upstairs to a bedroom by who set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for, to rub on him. At one point during the massage he tried to remove her shift, at which point she became very upset and discontinued the massage. Both and E stein had a verbal disagreement, at which time she left without being paid. She got with kitchen and told her "let's go." I advised she received no money for that day. also said that who was si • in the had told her if she was uncomfortable with what was going on, to let him know and he'll stop. She knew that the more ou do the more you get paid. I advised that several weeks later she agreed to be taken a second time by . Once they arrived at the residence, sat in the kitchen and took her upstOss to the master bedroom again. set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for, to rub on him. At one point during the massage he tried to touch her buttocks. As, was wearing tight jeans and had a tight belt on Epstein was unable to touch her buttocks. Epstein then rolled onto his back during the massage and then attempted to touch her breasts.. then became set again and told Epstein she didn't want to be touched. discontinued the massage and was paid $200.00.. then went downstairs where was waiting for her. She told she wanted to leave. . said she never returned to the house. stated she is aware that her friend, was also at the house and had a problem with Epstein. I later researched , dob , and met with her at her residence. During a sworn taped statement, stated the following: on or about November 21304 she was approached at Royal Palm Beach High School by , a fellow student. asked if she wanted to make money. She agreed and was told she would provide a massage to wealthy man in Palm Beach. picked her up and drove her to a house in Palm Beach. She was brou t into the kitchen area of the house. She further stated that fellow Royal Palm Beach High School students srand ) came with them. They were brought into the kitchen where she was introduced to Epstein and other females. stated she was introduced to a female helper of Epstein, the female was described as white female (unknown name ), with blond hair. She stated that the assistant was familiar with . The assistant brought her upstairs into a master bedroom area. The assistant set up the massage table and put out lotions to be used. She told , Epstein would be available in a minute. Epstein entered the room wearing only a towel. Epstein removed his towel, and laid naked on the massage table and picked a lotion to rub on his thighs and back. further stated durSlie massage, Epstein asked her to remove her clothes. She complied and removed her pants and blouse. didn't remember if she had removed her bra but feels that she did. was certain that she stayed in her thong underwear. continued the massage and at one point she climbed onto the massage The foregoing-instrument-wit cwnrn fa or affirmed before me this 1" day of May, 2006 by Det , who is personally known to me. State of Florida Date: 05/01/2006 Pag;-)of12 EFTA00230879 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 table, straddling Epstein to massage his back. While doing this was instructed to return to the ground at which time Epstein turned to have his chest rubbed. advised she was sure he was masturbating based on his hand movements going up and down on his penis area. did not want to look at his penis area because she was uncomfortable. Epstein removed a lar e white vibrator which was next to the masse e table and turned it on. stated Epstein began . Shortly thereafter, Epstein ejaculated and removed himself from the table. He walked over to where the shower was and opened the glass door. She waited as he was taking a shower in her direct view. When I asked how old she was when this occurred, she stated she had just turned Signature of Police Officer (P.S.S. 117.10) seventeen. At the conclusion of the shower, wasn't sure, but knows it was close to $400.00. Epstein. was paid either $350.00 or $400.00. She stated she stated she never returned to provide a massage for At approximately 2:10 pm, Det and ! met with M, dob , at her residence. As was only seventeen years of age, I had notified her mother, that she would be interviewed reference an ongoing investigation in Palm Beach. I assured her that her daughter was not a suspect. I explained the possibility of her being either a witness or victim. advised she wanted • to cooperate and consented to the interview. During a sworn taped statement, stated the following: at the age of sixteen, during the month of September 2004 she was approached by for a chance to make money. was friends with associates of and knew the same people. had been previously told by her friends from Royal Palm Beach High School, what did for Epstein. called a person known to • as and scheduled the appointment. picked up and drove her to Palm Beach to a street called "Brillo Way". They drove to the end of the street and entered a large drivewa . The entered the kitchen area of the house and met with Epstein. IN was introduced to MIEpstein. led upstairs to the main bedroom area and set up the room with a massage table and set out the oils. stated that while going up the stairs and into the bedroom she observed numerous photographs of naked young girls. dimmed the lights and turned on soft music. exited the room and Epstein entered the room wearing only a towel. Epstein picked oils and instructed her to rub his legs, under his buttocks, back and chest area. Epstein asked her to get comfortable. IN advised she did not remove her clothes. She was wearing tight jeans and a cropped tank top ex ni.ter belly area. During the massage, Epstein removed his towel and laid on the massage table naked. As area, he attempted to reach down her pants to touch her buttocks area however was unable to due due to the tightness of the jeans and a tight belt. advised Epstein began to masturbate as she rubbed his chest. Epstein moaned as she rubbed his chest. She observed he was continuing to masturbate and The foregoing- nstrument wassworn-to or affirmed before me this day of May, 2006 by Coun of Palm Beach Det -,who is personally known to me. State of Florida gnat Date: 1/2006 cer Page;f 22 EFTA00230880 Signature of Police Officer (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 attempted to reach up her tank top and touch her breasts. E, pulled back and Epstein stopped, however he kept masturbating until he climaxed. He cleaned himself with the towel he was previously wearing. was paid $200.00 for the massage and left the area. She met with who was waiting in the kitchen area and left the house. with then explained she never provided another massage for E stein. She did however, go to the house and as they took another friend of . . advised she was present when went to work for Epstein. She advised she rode over and sat in the kitchen area with to wait for . • advised while they waited for the house chef prepared lunch for them as it was almost lunchtime when they went. When was finished with the massaEthey left the area. I asked . if ever told her what would be expected when she provided a massage. . stated yes, told her that a massage would be expected, ossibly naked and possibly some touching involved. . has no formal training in providiniLnassages. . spoke about a third and last time she went to Epstein's house. drove another girl, M, (sixteen years of age) who is M friend, to Epstein's house. . stated knew that . had made money massaging frit= and wanted to make money herself took them in the kitchen area of the house and introduced . to and took IN upstairs to the main bedroom. . advised she doesn't know what happened as did not speak about what happened in the room. . received $100.00 from for going with her to Epstein's house and recommending M. On October 6, 2005, at 11:45 am, I met with , dob at and explained to her why we there to interview her. She advised she was aware of the ongoing investigation. stated she had previousl2s ken with who told her she was interviewed by detectives. Duras sworn taped statement, stated she knew that worked for MEpstein in Palm Beach. o advised she originally had been taken to the Epstein house by , whom she met when they both attended Royal Palm Beach High School. She began going to the house when she was sixteen years of age and stated she had been there a lot of times to provide massages over the past two years. I asked her if she had formal training in providing massages, which stated she had not. advised she was told what was expected of her by providing massages and she would have to remove clothing but if she felt uncomfortable just to say, and Epstein would stop pushing the issue. began providing massages and advised she kept her clothes on. She considered Epstein a pervert and he kept pushing to go further and further. explained she would keep telling him she had a boyfriend and would not be right to her boyfriend. It wasn't until recently that began removing her clothes and staying in her thong underwear to provide a massage. explained —The-foregatag instrument wac cwnrn to or affirmed before me this 1" day of May, 2006 by Det , who is personally known to me. State of Florida County of Palm Beach Signat ng Officer Date: 0 i 1/2006 Page1 of 22 EFTA00230881 Signature of Police Officer W.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 Epstein wanted to be rubbed on his back and recently he began turning over and have her rub his chest as he masturbated. He would try to touch her breasts as she rubbed his chest. stated "would try to get away with more and more on each massage". stated would try to touch her more and on one occasion he auntttempted to use a massager/vibrator on her. drove to the house for the original massage. left her cell phone number and every time E stein would come into town, would call her for an appointment to "work". Each time she went, would meet her at the kitchen door area. She would bring her upstairs and re are the massage table. knew she was and would be attending advised E stein would ask herstastions about herself. Epstein . I asked if Epstein knew her real age. stated Epstein did and didn't care. The most recent massage she provided was on October 1, 2005. During the massage, she asked Epstein if she could borrow one of his vehicles to visit her family and boyfriend in , Florida. Epstein had told her she could borrow one of his vehicles but later stated he would rent her a car. She continued with the massage as Epstein and . I asked if she was wearing undergarments to which she replied her thong underwear. Once he tried to touch her breasts, she would pull away from him and he would stop. was asked if he ever used a vibrator on her. was aware of the vibrator but advised she never would allow him to on her. She described the vibrator as the large white vibrator with a huge head on the tip of the vibrator. She stated he kept the vibrator in a closet near the massage table. stated that on October 3, 2005, she was contacted by Epstein's assistant, that E:p n had rented her a new Nissan Sentra and she should come by the house to . picwkhitouipn her . formed informed she would have the car for a month. M stated Epstein knew her car was not working properly and that she had missed appointments in the past because of her car being inoperable. explained the car is currently parked next to the Gym field. I asked her if she ever took any one to the house, explained she took , a friend of hers who attended Royal Palm Beach High School who has relocated to to attend college. I asked if she ever allowed another female in the room. advised no one was brought into the room with her. At the conclusion of the interview, Det and I went to the gym area of and located the Silver Nissan Sentra bearing Florida tag . The vehicle is registered to Dollar Rent a Car out of the Palm Beach International Airport. The vehicle was rented by Janusz Banasiack, later learned to be Epstein's houseman, and paid with Epstein's credit card. On September 11, 2005, w/f E, dob was arrested by the Palm Beach Police Department The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det , who is personally known to me. State of Florida Coun of Palm Beach Officer Pagdeof 22 EFTA00230882 Probable Cause Affidavit Palm Beach Police Department Agency OFtln FIX) 500600 for misdemeanor possession of marijuana. During the arrest . told the arresting officer that she had information about sexual activity taking place at the residence of Jeffrey Epstein. Additionally, during the ongoing trash pulls from Epstein's residence, discarded papers were found which contained M's name and cell phone number. On October, 11, 2005, Det and I met with . and obtained a sworn taped statement. explained she had been going to Epstein's house since 2002, when she was sixteen years of age. Since then she has gone to the house hundreds of times. • stated she became his "number one girl." She explained that on her first visit she was brought to the house by fellow Royal Palm Beach Hi School classmate, • said she was brought through the kitchen area where she met . for the first time. was led to the master bedroom, Epstein s room. • explained that as she was walking up the stairs she observed several photographs of naked women alon. walls and tables of the house.. further explained that she was brought into the bedroom, where prepared the room by setting up the massage table and provided the oils for her to rub on Epstein. • explained she remembered the steam room area, which contained two large showers. Epstein entered the room from the steam room area and introduced himself. Epstein lay on the table and told her to get comfortable. • removed her skirt and kept her shirt on. Epstein then instructed her to remove her shirt. • removed her shirt and remembered she was not wearing a bra. IIstated she provided the massage wearing only her antics. She continued rubbing his legs, thighs and feet. advised he turned over onto his back. Epstein and be an to masturbate. Epstein ejaculated which meant the masse e was over. At the conclusion of the massage, was paid $200.00. They walked together downstairs where and Shady were waiting. stated received an unknown amount of money for taking her to Epstein. Epstein instructed to leave her cellular telephone number I that he could contact her when he is in town. stated that during her many visits a routine was established between her and Epstein. She would enter the house and get naked in the bedroom. She would then start with a back massage. Epstein would roll on to his back and allow her to masse e his chest area. stated E stein would then began to masturbate himself and at the same time would with his fingers. U explained Epstein would continue this process until he ejaculated. He would then advised that during her frequent visits Epstein asked for her real age, stated she was sixteen. Epstein advised her not to tell an one her real a e. advised that thin s escalated within the home as Epstein would instruct and pa . • explained the intercourse included that Epstein had at his disposal. Epstein would watch them and masturbate himself . Occasionally, Epstein would then join in The foregoing_inctrumput_wsc cwnrn to or affirmed State of Florida before me this 1" day of May, 2006 by Det , who is personally known to me. Co Signatur r, ing a fficer Signature of Police Officer (F.S.S. 117.10) Date: i i /2006 Page"of 22 EFTA00230883 Probable Cause Affidavit Palm Beach Police Department Agency °Rift FLO 500600 during the the time was sixteen years of age. to both III and This occurred during advised this continued to escalate during two years. The routine became familiar toe. Epstein's assistant i would telephone her every time Epstein was in the Town of Palm Beach and would place appointments for her to visit and work for Epstein. Each time something new was introduced, additional monies were produced and offered for to allow the acts to happen. • consented to perform all these acts but was adamant that there was an understanding with E stein that no vaginal penetration would occur explained that Epstein's penis was deformed. explained that his penis was oval shaped. Epstein's penis was erect, it was thick toward the bottom but was thin and small toward the head called E stein's penis "egg-shaped." • stated Epstein would photo raph and her and proudly display the photographs within the home. in which she provided a massage to E stein, his female friend provided the massage in which and her would enjoy. Towards the end of this massage E stein bbed and turned her over onto her stomach on the massage table and stated E • stein be an to became upset over this. She said her head was claimed when rtion. stated during one visit to Epstein's house was also .resent. for Epstein to , as he continued to . She screamed "No!" and Epstein stopped. She told him that she did not want to . Epstein did not e'aculate inside of her and apologized for his actions and subsequently paid her a thousand dollars for that visit. stated she knows he still displays her photographs through out the house. On October 12, 2005, Det and I met with dob who stated during a sworn taped statement, that nothing happened between her and Epstein. appeared nervous during the , interview. I assured her that I have spoken with other people who advised differently. stated on several occasions she rovided a massage to Epstein. She stated she was brought to the Epstein house in March of 2005. a classmate at Royal Palm Beach Hi School, approached her and asked her if she wanted to "work". made the arrangements with =, Epstein's assistant. , who has no formal training in providing massa es stated she provided a massage, fully clothed for $200.00 . As I sensed hesitancy in her answers, I asked if she had been contacted by anyone from Epstein's organizations or his house. stated she was interviewed already by a private investigator for E stein. He identified himself as `M" amSuired about the police investigation, and left his telephone number for additional contact. provided no additional information, as it appeared her responses were almost scripted. The-foregoing-instrument wasswarti to ror affirmed before me this I" day of May, 2006 by Det , who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida Coun of Palm Beach Date: 05/01/2006 cer Pagel2of 22 EFTA00230884 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 On November 6, 2005, at approximately 3:30 pm, I met with dob 08/24/1985, at the Palm Beach Police Department. was identified as a potential witness/victim through information obtained during the trash pulls. During the sworn taped statement, advised she was at Jeffrey Epstein's house one time, approximately two months ago. She was approachedlligirl, , who was dating roommate, for an opportunity to make some quick money. advised she needed to make some quick cash to make the rent that month. She agreed to go to the house. She had been told by that the massage would have to be done in her underwear. She advised drove with her and brought her into the house. They walked into the kitchen area, and took the stairs upstairs. further stated she was brought into a master bedroom area. She advised she recalled seeing portraits of naked women throughout the room. A massage table was already out near the sauna/shower area in the master bedroonSein entered the room wearing only a towel and introduced himself as "Jeff." At Epstein's direction, and removed their clothing down to their panties, Epstein laid on his stomach area and they provided a massage on his legs and feet area. I asked if she had any formal massage training and she replied "no." advised she was topless and the panties she wore were the boy shorts lace panties. She and continued the massage until the last ten minutes of the massage, Epstein, told to leave the room that could finish the massage. got dressed, and left the room .a itein turned over onto his back. Epstein then removed the towel and laid naked . stein that rub his chest area. stated , Epstein, began masturbating. stated Epstein pulled down her boy short panties, and he produced a large white vibrator with a large head. She stated it was within his reach in a drawer in his master bathroom. He advised he never with the vibrator. He continued to as he continued to masturbate. stated she was very uncomfortable during the incident but knew it was almost over. Epstein climaxed and started to remove himself from the table. He wiped himself with the towel he had on previously and went into the shower area. got dressed and met with in the kitchen area. Epstein came into the kitchen and provided $200.00 for bringing and paid $200.00 to for providing the massage. was told to leave her telephone number with for future contact. provided her cellular telephone number. was asked if she was recently contacted about this investigation by an one from the Epstein organization. She replied she was called but it was for work. She stated she was called by for her to return to "work" for Epstein. stated "work" is the term used by to provide the massages and other things. advised she declined as she was not comfortable in providing that type of "work." On November 7, 2005, Det and I met with dob . During a sworn taped statement, stated she met Jeffrey Epstein through when they were still The foregoing internment was sworn to or affirmed before me this 1" day of May, 2006 by Coun of Palm Beach Det EM, who is personally known to me. State of Florida Signatur leer Signature of Police Officer (F.S.S. 117.10) Date: 05/ 1/2006 Pagd1 of 22 EFTA00230885 Signature of Police Officer (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 attending Royal Palm Beach High School. a would approach females who wished to work for Epstein. stated she was offered to work for Epstein but declined. explained that "work" means ye massages. She was asked about any formal training in providing massages which she said "no." said she accompanied and other females who were taken to Epstein's house to provide massages. further stated she had been to the house a roximatx 4 or 5 times .iegyear. in tl She accompanied with , M, and . Each time the girls were taken over, they were previously told they would have to provide a massage, possibly naked. They were also told that shouldist.require them to do anything extra, and they were not comfortable just to tell him and he would stop. stated received $200.00 for each girl she brought over to massage Jeffrey Epstein. When I asked which girl appeared to be the youngest, she replied, MI, who was really young, fifteen years old at the most. further stated each time she went to the house, she sat in the kitchen and waited with until the massage was over. She further stated that the cook would make lunch or a snack for them as they waited. I asked her if there was anything that caught her attention within the home. stated there were a lot of naked girls in photographs throughout the house. On November 8, 2005, at approximately 2:00pm , I met with , dob at the Palm Beach Police Department. During a sworn taped statement stated she had met Epstein approximately ears ago when she was first approached by , a classmate at Royal Palm Beach Hi School. approached her about working for Epstein and providing a massage to him for $200.00. had made the arrangements however was unable to take her the day the arrangements were made. had take also attended Royal Palm Beach High School and was familiar with Epstein. recalled she was brow ht there and entered through the back kitchen door. She had met with an assistant and another assistant brought her upstairs as she observed several photographs of naked females throw hout the house. stated Epstein came in the room, wearing only a towel, and laid on the table. stated hi,ced out the oils he wanted her to use and requested she remove her clothing toe, the massage. stated that on the first massage she provided she did not remove her clothing. stated she had returned several times after that. Each time she returned it was more than a massage. Epstein would walk into the master bedroom/bathroom area wearing only a towel. He would masturbate as she provided a massage. stated she was unsure if he climaxed as he masturbated under the towel. Additionally, she never looked below his waist. She claimed that Epstein would convince her to remove her clothes. She eventually removed her clothes and stayed in her thong panties. On occasion,isstein would use a massa er/vibrator which she described as white in color and a large head. Epstein would as he would masturbate. stated she had been to the house The foregoing instrument was sworn to or affirmed before me this ln day of May, 2006 by Det who is personally known to me. State of Florida Signatur Date: 05/01/2006 g Officer PagPlof 22 EFTA00230886 Signature of Police Officer (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency OR!# FLO 500600 numerous times. added she has no formal training in providing a massage. stated she brow t two females during her visits to provide massages. stated she brought a girl named'" and from Royal Palm Beach High School. stated she received $200.00 for each girl she brought. On November 8, 2005, I met with , W/F, at the Palm Beach Police Department. During a sworn taped statement, stated she had met Jeffrey Epstein approximately one year ago. She was approached by a stiesknown to her as M. • had asked her if she wanted to make money providing massages to Epstein. had heard that several girls from Roil! Palm Beach High School were doing this and making money. She agreed and was taken to the house by E. had introduced her to and Epstein and brotlilit her upstairs to a master bedroom where a mile table was prepared and the proper oils were selected. left the room and waited downstairs for her. stated Epstein entered the room wearing a towel and laid on his stomach. She provided a massage wearing only her thong panties. advised Epstein had masturbated every time she provided a massage. She stated Epstein continued to masturbate until he climaxed. Once that occurred the massage was over. She felt the whole situation was weird but she advised she was $200.00 for providing the massage. She also stated was paid $200.00 by Epstein for bringing stated she had gone a total of 15 times to Epstein's residence to rovide a massage and things had escalated from just providing a massy e. E stein be an touchin and grabbed her closer to him as he masturbated. Epstein also and with his hands as she provided the massage. stated on one occasion, while she was only seventeen years of age, he offered extra monies to have vaginal intercourse. She stated this all occurred on the massage table. stated and began until he reached the point of and climaxed onto the massage table. received $350.00 for her massage. I asked her if she had any formal training in providing massy es, stated she did not. continued to state on one other occasion, Epstein introduced his girlfriend, into the massy e. was brought into room with to provide a massage. Epstein had them as they provided a massage to Epstein. Epstein, watched and masturbated as this occurred. On other occasions, E stein, introduced the large white vibrator/massager in the massage. Epstein on vagina as she provided the massage. Epstein climax. Epstein removed On November 14, 2005, Det and I met with dob . During a sworn taped statement she advised she started going to the house approximately one year ago and has been there approximately five or six times. also stated she was sixteen years old when she first went to Epstein's house. On her first visit she was brought by a fellow student from Royal Palm Beach High School known to her The Owegning instrument was sworn to or affirmed before me this P' day of May, 2006 by Det who is personally known to me. State of Florida Signatu g Officer Date: 05/01/2006 Page of 22 EFTA00230887 Probable Cause Affidavit Palm Beach Police Department Agency oiw FLO 500600 as stated brought her into the house and she was introduced to then brought her upstairs into a master bathroom, located within the bedroom. stated she met Epstein in the bathroom. He laid on the table and picked the massage oils. She provided the massage as he laid naked on the massage bed. She stated she rubbed his calves and back area. Upon the end of the massage, Epstein removed himself from the massage table and paid her $300.00 for the massage. said each subsequent time she went to the house, she was notified by that Epstein was in town and would like her to "work". stated she returned to the house and was again led upstairs by . She provided the massage, until the third time that she went that she removed her clothing. was asked if she ever removed her clothing to Sde a massage. stated she was notified by that clothed. stated it was not providing the massage when Epstein asked her to remove her clothing. Epstein wanted her to come to work. She arrived at the house and was lediairs by . She started removed her pants, shirt and bra. She sta ed in her atianties tl and . Epstein turned over onto his back and she stated she knew he was masturbating himself as she providing the massage. stated she believed he climaxed based on his breathing. She did not want to view either the climax or the fact that he was masturbating. stated once the breathing relaxed he got up and told her to get dressed. She was paid $300.00 for her services. stated on the last time she went to provide a massage, she was notified by to come to the house and "work". stated she was now dating her current boyfriend and did not feel comfortable going. She recalled it was approximately January 2005. She said she went, already thinking that this would be the last time. She went upstairs and went into the master bathroom. She met with Epstein, who was wearing only a towel, and laid onto the table. stated Epstein caught her looking at the clock on several occasions. Epstein asked her if she was in a hurry. stated her boyfriend was in the car waiting for her. further stated that Epstein got upset as he wasn't enjoying the massage. She told.him that she didn't want to continue and she would not be back. Epstein told her to leave as she was ruining his massage. advised she had no formal training in providing any massages. stated although she had a falling out with Epstein, she still received a Christmas bonus from Epstein. stated she was wired money from Western Union for her Christmas bonus. Sub ena results from Western Union revealed money was sent from Jeffrey Epstein on December 23, 2004. received $200.00 from Epstein for her Christmas bonus. • On November 15, 2005, Det. and I met with E, dob 04/21/1988. During a sworn taped statement, E stated she met Jeffrey Epstein over a year ago. She was sixteen years of age and was approached by , a fellow Royal Palm Beach High School student, who informed her that she could make $200.00 providing a massage to Epstein. had informed her that she would have to provide this Thelon-going instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det , who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida Cou of Palm Beach Signature/ Officer Date: 05/01/2006 Pagel 4)122 EFTA00230888 Signature of Police Officer (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 massage to made the arrangements with Epstein and his assistants and took II to the house. • stated = and she entered through a glass door that led into a kitchen. She was taken upstairs by to a master bedroom. She recalled the master bathroom had a large ink couch, sauna and matching shower. Epstein entered into the room wearing only a towel. • and removed their clothing remaining only in thong underwear. She further stated that Epstein laid on his chest on the table. The oils were selected on which ones to use. Both and . provided the massage on his legs, back and feet. Forty minutes into the massage, Epstein turned over onto his back and r uested wait downstairs in the kitchen area for Epstein instructed . to finish the massage. As got dressed, starting rubbing Epstein's chest. left the room, and Epstein began masturbating as . • stated Epstein continued masturbating until he climaxed on the towel he was wearing. When asked if he had removed the towel she stated he turned the towel around 1 that the opening would allow him to expose himself. After he cleaned himself off with the towel he instructed the massage was done and to get dressed and meet with him downstairs. • of dressed and met with Epstein in the kitchen area. She was paid $200.00 dollars for providing the massage. stated she was aware that also received monies for the same thing. The second time she went to the house she was again approached by advised if she wanted to return to the house tulovide another massage.. agreed and the arrangements were made by for her to return to the house. M stated drove her to the house and knocked on the same glass door which leads to the kitchen area. They were allowed entry into the house one of the staff members. led her upstairs to the master bedroom and master bathroom area. left . this time to do the massage alone., Epstein entered the room again wearing only a towel. • began removing her clothing as she did the last time she was at the house. Epstein instructed her to get naked. He laid on the table onto his stomach as . began masse in his legs and back. As . fmished with Epstein's back and legs, Epstein then turned over onto his back. M started to rub his chest and he began masturbating. As li nrubbed his chest, Epitein leaned over and produced a massager/vibrator. He turned it on and began rubbing vagina and masturbating himself at the same time. IN stated she as this was occurring. She described the vibrator/massager as large grey with a large head. Epstein for approximately two to three minutes with the massager/vibrator. He then removed the and concentrated on masturbating himself. • stated Epstein climaxed onto the towel again and informed her that the maccage was done. il igot dressed and met with who was waiting in the kitchen area. She received $200.00 for the massage. said she never returned to the house and had no desire to return to the house. IN was asked if she received any formal massage training. She advised she had no formal training. • was asked if Epstein knew her real age. • stated he knew, as he asked her questions about herself and high school. He was aware she attended, and is still attending Royal Palm Beach High School. Thfiz foregoingnstroment i was sworn to or affirmed before me this 1" day of May, 2006 by Det , who is personally known to me. State of Florida C Date: 05/01/2006 Pagnof 22 EFTA00230889 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 During the course of the investigation a search warrant was executed at Jeffrey Epstein's home located at 358 El Bulb Way in Palm Beach. While in the home I observed the pink and green couch within the master bedroom area just as the girls previously mentioned. The stairway, which is located from the kitchen area to the master bedroom area, is lined with photos of naked young girls. Additionally, numerous photographs of naked young females, some of which appeared to be the girls I previously interviewed, were on display throughout the house. Also located in the house were various phone message books. The telephone message books have a duplicate copy (Carbon Copy) which, once a phone message is written into the book, the top copy is then torn on the perforated edge and the carbon copy is left in the book. First names of girls, dates and telephone numbers were on the copy of the messages. I recognized various numbers and names of girls that had already been interviewed. The body of the messages were time of the day that they called for confirmation of "work." Other names and telephone numbers were located in which the body of the messages were, "I have girls for him" or "I have 2 girls for him." These messages were taken by , who signed the bottom of the messages. During the execution of the warrant, I located a Royal Palm Beach High School transcript for e in Epstein's bedroom desk. This desk had stationary marked Jeffrey E Epstein. I located a wood colored armoire beside Epstein's bed that contained a bottle of "Joy Jelly," which is used to provide a warm massage. Several massage tables were located throughout the second floor of the residence, including a massage table found in Epstein's bedroom. On the first floor of the residence I found two covert cameras hidden within clocks. One was located in the garage and the other located in the library area on a shelf behind Epstein's desk. A computer was located which was believed to contain the ima es from the covert cameras. The computer's hard drive was reviewed which showed several images of and other witnesses that have been interviewed. All of these images appeared to come from the camera positioned behind Epstein's desk. On December 13, 2005, Det. and I met with le, dob During a sworn taped statement, stated that when she was sixteen years old she was taken to Epstein's house to provide a massage for money. stated it was before Christmas last mr (2004) when an associate, approached her and asked if she needed to make money for Christmas. made arrangements to take to the house and drove leto the house to "work." They were encountered by a white female with long blond hair. le was unable to remember the name of the white female with blond hair but knew she was Epstein's assistant. She was led upstairs by the white female who explained that there would be lotions out already and Epstein would choose the lotion he wanted her to use. She was led through a spiral staircase which led to a master bedroom and bathroom. The massage table was already set up in the bathroom. described the bathroom as a large spacious bathroom with a steam room and shower beside it. was introduced to Epstein who was on the phone when she entered the room. Epstein was wearing a white towel and laid on his stomach that may The foregoing instrument was.sworo to nr affirmed before me this 1" day of May, 2006 by Coun of Palm Beach Det who is personally known to me. State of Florida Signature of Police fficer (F.S.S. 117.10) Signature/ ng Officer Date: 05 06 Paget o f 22 EFTA00230890 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 massage his feet and calves. III started the massage with the oils Epstein chose and rubbed his feet and calves. Epstein got off the phone and requested she massage his back as well. • began rubbing his back and got to the small of his back. During the rubbing of his back, Epstein asked her to get comfortable. He requested she remove her pants and shirt. removed her shirt and pulled her pants off. El stayed in her bra and thong panties. As she finished massaging the small of Epstein's back he then turned onto his back. Epstein instructed to rub his chest and pinch his nipples. As she , Epstein asked her questions about herself. • remembered telling him she attended Royal Palm Beach High School. Epstein asked her if she was sexually active. Before could answer, he also asked what sexualposition does she enjoy. • stated she was shy and didn't like talking about those things. She continued . Epstein reached u and unsna her bra from the front. • explained the bra she used had a front snapping device. Epstein and asked her if she like having said "no, I don't like that." Epstein then removed his towel and laid on the bed naked exposing his penis to . He be an touchin his nis and masturbated as he explained Epstein then touched . 5 tensed up and stated Epstein was aware that she was uncomfortable. stated that Epstein said to her, "Relax, I'm not going inside." She anther explained Epstein commented to her how beautiful and sexy she was. Epstein then moved her thong panties to one side and be said, "He commented how " He then . She tried pulling back to and apologized for and continued to rub her vagina. stated he as he was masturbating. said he climaxed onto the towel he had been previously wearing and got up from the table. Epstein told her there was $200.00 dollars for her on the dresser within the master bathroom. Epstein also told her that there was an additional $100.00 that was to be given to5for bringing her there to massage him. Epstein told her to leave her telephone number with his assistant as he wanted to see her again. Epstein stated his assistant would contact her to work again soon. I asked her if she ever received any formal massage training to which stated she did not. • stated it was the only time she ever went to work for e and knew what happened to her was wrong. She further stated that she had never been contacted for any additional work. . Epstein Ducting this time, he kept his On January 9, 2006, I located and interviewed another victim, 5, dob . was identified as a potential victim/witness from information obtained during trash pulls from Epstein's residence. stated she met Epstein when she was fifteen years of age. She was approached by a friend from Royal Palm Beach High School, to be taken to Jeffrey Epstein's house to work. She was originally told she would be able The foregoing inent-was-sworn-to_or affirmed before me this 1" day of May, 2006 by Cou Det who is personally known to me. State of Florida Signature g Officer Signature of Poli e Officer (F.S.S. 117.10) Date: 05/ 1/2006 Fag:S of 22 EFTA00230891 Probable Cause Affidavit Palm Beach Police Department Agency OltPt FLO 500600 to model lin erie for a wealthy Palm Beecher. was taken to Epstein's house located on El BrilloWay. introduced to leffrzlEstein. Epstein had hiszrsonal chef prepare dinner for and . At the conclusion of dinner, and Epstein brought upstairs into a master bedroom area. observed a large massage table with a sheet on it. Epstein entered through a door and exited wearing only a towel. informed that they were oing to provide a massage on Epstein.. asked why were they doing this instead of modeling lingerie. ex lained to that this was his routine and to rub his calves and feet. Epstein had told to get comfortable. removed her pants and blouse. stated she stayed only in panties as she did not wear a bra that evening. stated while rubbing his calves and feet, Epstein turned over onto his back. Epstein told. to rub his chest and rub his ni les. stated that as she started , Epstein began masturbating himself . Epstein and with his fingers. Ezstein continued to masturbate himself as he . Epstein ejaculated on his towel and paid $200.00 and for the massage. told 'that if she told anyone what happened at his house that bad things could happen. were brought home by Epstein's houseman and was afraid that Epstein knew where she lived. stated that several days later she received a telephone call from who coordinated for to return to "work." returned to the house and was brought to Epstein's bedroom area by who prepared the room for the massage. Epstein entered the room wearing only a towel. Epstein had remove her clothing and provide the massa e naked. be an rubbing his feet and calves and Epstein turned over onto his back. Epstein . E stein be an to masturbate himself with an upwards and downward motion on his penis. Epstein continued with one hand and masturbate with the other hand. Once Epstein ejaculated onto the towel he was wearing, the massage was over. was paid $200.00 for the massage. Epstein again told not to speak of what happened at his house or bad things would happen. wanted to notify authorities however she was afraid of what would happen to either her or her family. During the course of the investigation, several subjects were identified as a potential witness/victim through information obtained during the trash pulls, physical surveillance and telephone message books retrieved from the search warrant. While conducting research on the subjects, I discovered that the females were age eighteen or older. Interviews were conducted on the consenting adults whose statements provided the same massage routine when they went to "work" for Epstein. The females would be notified by , and made appointments for the females to "work" for Epstein. The females would come to Epstein's house and were led upstairs, through a stairwell from the kitchen area, by to Epstein's bedroom. Epstein would then enter the room wearing only a towel, and ask them to et comfortable. The females would then provide the massage naked as Epstein would either and/or utilize the massager/vibrator on o'ng-instrument-was-SWOrtI4o-or-affirmed State of Florida before me this 1" day of May, 2006 by Con of Palm Beach Det , who is personally known to me. Signa ure Signature o o e leer .S. 117.10) Date: 05/ 006 g fficer Pagielciof 22 EFTA00230892 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 He would masturbate during the massage and upon his climaxing, the massage would end. The girls were then paid two or three hundred dollars for the massage. On November 21, 2005 I interviewed Jose Alessi, a former houseman for Jeffrey Epstein. Alessi stated he was employed for eleven years with Mr. Epstein, from approximately 1993 through 2004. Alessi stated he was the house manager, driver and house maintenance person. It was his responsibility to prepare the house for Epstein s arrival. When asked about cooks or assistants, Alessi stated they traveled with Epstein on his private plane. I asked Mr. Alessi about the massages that have occurred at Epstein's home. Alessi stated Epstein receives three massages a day. Each masseuse that visited the house was different. Alessi stated that towards the end of his employment, the masseuses were younger and younger. When asked how young, Mr. Alessi stated they appeared to be sixteen or seventeen years of age at the most. The massages would occur in Epstein's bedroom or bathroom. He knew this because he often set up the massage tables. I asked if there were things going on other than a massage. Alessi stated that there were times towards the end of his employment that he would have to wash off a massager/vibrator and a long rubber penis, which were in the sink after the massage. Additionally, he stated the bed would almost always have to be made after the massage. On January 4, 2006 I interviewed another former houseman, Mr Alfredo Rodriguez. During a sworn taped statement, Mr. Rodriguez stated he was employed by Jeffrey Epstein for approximately six months, from November 2004 through May of 2005. His responsibilities as house manager included being the butler, chauffeur, chef, houseman, run errands for Epstein and provide for Epstein's guests. I asked Rodriguez about masseuses coming to the house. Rodriguez stated Epstein would have two massages a day. Epstein would have one massage in the morning and one massage in the afternoon everyday he was in residence. Rodriguez stated he would be informed to expect someone and make them comfortable until either or Epstein would meet with them. Rodriguez stated once the masseuses would arrive, he would allow them en into the kitchen area and offer them something to drink or eat. They would then be encountered by either or Epstein. They would be taken upstairs to provide the massage. I asked Rodriguez if any of the masseuses appeared young in age. Rodriguez stated the girls that would come appeared to be too young to be masseuses. He stated one time under Epstein's direction, he delivered a dozen roses to Royal Palm Beach High School for one of the girls that came to provide a massage. He knew the girls were still in high school and were of high school age. I asked Rodriguez about the massages. He felt there was a lot more going on than just massages. He would often clean Mr. Epstein's bedroom after the alleged massages and would discover massageis/vibrators and sex toys scattered on the floor. He also said he would wipe down the vibrators and sex toys and put them away in an armoire. He described the armoire as a small wood armoire which was on the wall close to Epstein's The foregoing-instroment-was-swornes-or affirmed before me this 1" day of May, 2006 by Det , who is personally known to me. Signa tire o • o ice leer 117.10) State of Florida ignatu re ng 1 fficer Date: /2006 Pag?'of 22 EFTA00230893 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 bed. On one occasion Ertein ordered Rodriguez to go to the Dollar rent a car and rent a car for the same girl he brought the roses to, that she could drive her self to Epstein's house without incident. Rodriguez said the girl always needed rides to and from the house. Rodriguez produced a green folder which contained documents, and a note with Mr. Epstein's stationary with direction to deliver a bucket of roses to Royal Palm Beach Hi School after high school drama performance. Also in that same note was direction to rent a car for • and direction to extend the rental contract. During the course of the investigation, subpoenas were obtained for cell phone and home phone records from several victims and witnesses along with the cell phone records of records was conducted which found numerous telephone calls were made between and the victims. These records indicate the dates the calls were made are consistent with the dates and times they victims/witnesses stated they were contacted. Specificall , The phone records showed called during the exact times and dates when victim advised the incident occurred. also coordinated the encounters with M, and during the time frame the girls stated they occurred. . An analysis of these Pursuant to a lawful subpoena I obtained Epstein's private plane records for 2005 from Jet Aviation. The plane records show arrival and departure of Epstein's lane at Palm Beach International airport. These records were compared to the cell phone records of This comparison found that all the phone calls made to and the victims were made in the days just prior to their arrival or during the time Epstein was in Palm Beach. As Epstein who at the time of the incident was fifty two years of age, did commit lewd and lascivious molestation on E, a fourteen year old minor, by using a vibrator on her external vaginal area and as recruited, set up the appointment and drove to Epstein's residence, knowing that was fourteen years old and knowing there would be unlawful sexual activity between and Epstein that received monetary corn nation for taking said fourteen year old female by Epstein, there is sufficient probable cause to arrest for Lewd and Lascivious Act on victim under 16 years of age in violation of Florida State Statue 800.04 (6)(2b) a second degree felony. cgvius, instrument-wits-swern4e-or-affirmed State of Florida before me this 1" day of May, 2006 by Det , who is personally known to me. Signature of Polic Office (F.S.S. 117.10) Co of Palm Beach Signatu Date: 05/01/2006 Officer PagPof 22 EFTA00230894 $ EFTA00230895 1 REQUEST FOR WARRANT DEFENDANT: DATE OF BIRTH HABITUAL OFFENDER: YES NO MC/A VICTIM RELATED / ACQUAINTED WITH DEFENDANT? AGENCY CASE NUMBER: LEAD OFFICER: AGENCY: PALM BEACH POLICE DEPARTMENT 05-368 (21 YES XX NO PHONE NUMBER: CURRENT SHIFT HOURS: 8 am TO 5 rim DAYS OFF: LEAVE / SHIFT CHANGE INFO: WAS ARREST MADE FOR, OR IN CONJUNCTION WITH ANOTHER AGENCY. IF M, WHAT AGENCY?: SENTENCING RECOMMENDATIONS: CONTACT DETECTIVE ADDITIONAL COMMENTS: FILING DOCUMENTS ATTACHED: X ARREST FORM P.C. AFFIDAVIT (2 COPIES) X WITNESS / EVIDENCE LIST ?WAWA 51" 4 lb Kt+ (:)64-Di34/ ./....it C.- SWORN STATEMENT OF MATERIAL WITNESSES) X OFFENSE REPORT (2 COPIES) ACCIDENT REPORTS (ALL) WITNESS STATEMENTS (ALL) ) 4 fele/NM CRIMINAL HISTORY/LoVituar &kWh% `IN £36 eA3104mtent￾REQUEST FOR CONVICTION LETTERS x PROPERTY RECEIPT PariAltipuSty at') ID ASA tp et VEHICLE TOW OTHER ATTACHMENTS INCLUDE: JR INITIAL FOR COMPLETENESS: OFFICER 7915 050106 IMO DAIS DELIVERED BY: rt, A rr„.114, kAw 1.1;1,V r; 4 qtr,-. RECEIVED, STATE ArrOkAY'gOFFICE ON: U ID' DATE 7915 050106 ID. BY: DATE . EFTA00230896 OBTS Nano« I L l _e 1 I e t ARREST / NOTICE TO APPEAR : Ames, 3 ReQuIltl MY Wynne JUVellile Referral Repon 2 N T A 4 Peosast toe Own J,,,0N,I, DI re Agency OM Numesx FLO, 5 1 0 L 0 i _6 i 0, 0 ~my Nine PALM BEACH POLICE DEPARTMENT 4Oe*Clr RØ Nsnom 04 T en Only) 7A 0 LI I LI i _I li f.„,,,..IS! L I'. 2 c~* Tyree -0 1. Ftleeny 0 3. Mesdnamt 05 Orcimnee C.1~ as many as aPPIT 0 Z Traffic Felbey ❑0 4. Traffic MyclernmAce Ott. Ober II Weapon &Mod En.« Type Channco i 2 5 å Lake ol Ansi ~rip Name el Businsul Locum s d Mares (Sans Name AddeloSs) mura:sr I i Dais or Mest 1_ I R J R Tema of Arnesi I I. 1 Boolong Ore Booking Time Jal Dale J, hem _ LOCabOn cr VONCI• _ w￾z wrE o 2 w LLW 0 iw 8 IL au 0 CoDersinam Name Sast. Fist. Wile) Rare Se, 0a:e o' & r r Q I. Arnaffii D2 Ai Ley !: mi FEz ertmano, Pet: n' 0 CeDelenelanl Name (IASI. Fårsi. Seaciffi Rate I Sex DAIS ot Beth I I 07.AI M = 4 Medomeanor S. ~RN NENILE I Parem ,. Name hash (MINI IMOMel Ll Otner tet c,......n Riasaaince Phone ( ) ~red (Steel Apt. Number: PIN :See) (AR Reruns Phone I I TOT JAC role Time The ahem atkaoss wattweyidEll by 0 dedetalanl and /0rOdalandaren patent The Meld and /ea won was beel io keep me Junnt Cam OW. Office Rhone 35525261 Ø Of AM chare el eSenell 0 Yea, be (Name) CI No: %Reason) SIØAMØ Grade ik Property Come? 0 Ybs 0 No dffiception ol Properly Vow. of Prcereny v r.91.:Zeinit). 5.5a H. 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Rearm) .2 Yeu need n0l sØ in Court Ca Inuit any* se n instreceons on Rosen* Sde L.: ~ and Teat Day Yee Tee PM -e al CI R. _AM. i AZIFEE TO APPEAR AT THE TIME AND PLACE DESIGNATED TO ANSWER THE OFFENSE CHARGED OR TO PAY THE FINE SUBSCRIBED. i UNDERSTAND THAT SHOULD I WILLFULLYFAIL TO APPEAR BEFORE DE &VEIT AS REQUIRED BY THIS NOTICETO APPEAR. THAT I MAY BE HELD IN CONTEMPT OF COURT AND A WARRANT FOR MY ARREST SHALL BE LSSuED. 2 Swan of °Mandan Si JUvellee and Pan« /Custodian) DOM %rid HOLD ICIIOLIS Agency Name: Skonit" ol ArreslIng Office X Name Yorilkalion (Paned by Aneesel ± La em Dangerous ID ReSiSIKI Arrest Nam* ol Mersin; Otani IPTenh ID 1 , (PRINT) l 0 SOWS CI One, PAGE vela OWN I 0 I Path Transp.nmy OlIce. LO. I Agency \linen Weakens:1 soused *eh an IC. _OF__ . DISTRIBUTION: WHITE — COURT COPY GREEN — STATE ATTORNEY YELLOW — AGENCY PIP( — JAIL GOLD • DEFENDANT (UA% ONLY) EFTA00230897 OBIS Number e t a t l _L i i ARREST / NOTICE TO APPEAR i anew 3 Rawest tor Warrant Juvenile Referral Report 2 PVT a 4 Rawest to: Capra n J,Aersle [--- P g * & Agency ORI Mambo FLO; 5 s 0 a 0, 6 I 0, 0 Agency Name PALM BEACH POLICE DEPARTMENT Agency PeoOn Numetke IN .T A .5 only. 7 16iikki i 1 1 i i Lfl I I) =rat manY O I. Felony 0 3. Lisclemeartet O a oionane. Kat O 2 Vatic Felony 0 4. Treat redernwice 0 S. Other 1 Weapon Sear Enwiype Muutte Cleararoe i InOca locabon a Mem pretaging Nam* or SWISS) Locallon el Offenses (Business _ Name. Memo w I i Dale o'ail I I _I_ I I Anal e- I_ I_ Booking Date Bowing Time Jail Oct Jail lime Location of lericke ne Maine (Last. Fret. WON Alias (Name. 00B. Soc. Sec. I. Etc ) RW aceWNW I . Arnencen Indent B - BIM' 0 - OneniWAssan I Sex Dale of Nth _ L IM Hognt Weer Eye Color Her Crib Complexion Buhl Scars. Maths. Tattoos. Union Physical real ten !Location. Type, Dospipaom Mantel Status Wigton me Iragabohloinntitence a El Llak Drop Influence 0 LJ 2Sw ''' O Local AOSess (Sweet. Apt Hunts) (CRY) (Stale) go) Om" 1 ) Restoonoe Ty0e: i. City 2. Cask 3. Rata Out of State 1 Permanent Actress (Sheet, Apt Noreen lOt0 (Stale) (be) Ph*" ( J Address Source Business Saban (Name. SIMI) ION) (SINE (Zlp) Phone f 1 Occupabon 0/1. Nunes. Stile SOC. Sala Number r Number 'Piece of Orr (City. Seel Creaser u 81 g Go.Delenclant Name (Last. Fen Male) Race Sex Date CI Beth L. At i Felony nor 5 Juvenile Co-Delenclant Name (Last lost McKie/ Race ion Dare of Beth _ . sc lo ie ny SIM= 4. Le rrearce 3 Fe 5. !writ u t Name Aar (Ertl (Mire) § MOrlocIan Residence Phone I I Adder (SIMI AP. MMS3 MIN/ (Basil MP/ OusInees Mike l / JUVENII TOT JAG DO* Brno The awaken was provkle5by0delendent and / or n clelenclanta ems The Chia anandt Or Parenl was low to keep the awe,* Cowl Clint, Offroe When, 3S5-2526) eta riled a af,7Change 01 aadeSS 0 Yes. by. (Nemo) (3 No (Reason) SchootAllenclecl Grade Property Crone? Descnpaon of Property 0 Yes O No Wire of Property g Q R. DSLouvcergle K Dispense' IA (ptanutrurcii I Ph!' tikll, ,‘ty0e B. barium, H. ISuonogen P Panmhematil U lkanawn ??Itue cav" li. S.' &PL OwtWx P. Possess T. Train° E. Use Cultivate C. Cocaine M. Marano El:hammy Z. Other . A Amphetamine E. Heron a columned.. S S Meer 0 Change Gesalohon Counts D0.71034,C Morro i Y :1 N Stabile NSW Nun** I I 11 I I I 111 I I I Volabon of ORO u g 0 n y a ACrevaly Drug Typo Amount r UM Offense o Warrant / Capes Number Bowl 0 Chime Desonchon Cos Dommilac 811 It Smite %Sawn NurrOef I I 1.1 _I I A 111 I 1 I ) voiation of ORD • Ong Activity Dna; Type Amount/sty Orense e Waned /Capin Minter I Goa I UIdig Charge Desaletoe Gourds Comer on N , „ H_ 10 _,„) Statute Volabon Vaunter „., voation of 0110 1 AdSy I Drug Type Arrount/ use Oxen.° V Warrant /COOS Nora? Bo's Charge DOSCegbon ICCunts Omar OX ON Slagle Marlon Hunter I I Ill I I I l(l I I I ) v., etc- c• ORD s ! Drug Army Ong Type AniOunt I UM Offense a Werrarti f Cages Plumber Stec] NOTICE TO APPEAR I O Instructor. No. I Mandatory Appearance m can Locason (Ccon, Room Number. AdOreSS) o Instrucbon No. 2 You need not Wear in Cowl but most comply with untruceons on Reverse Selo Can DM and Time WWI Day Year Time AM P.M. AGREE TO APPEAR AT TI* ASMC PLACE OESIGNATED TO ANSWER THE OFFENSE CHARGED OR TO PAY THE FINE SUBSCRIBE°. !UNDERSTAND THAT SHOULO I WILLFULLY FALTO APPEAR BEFORE INE COURT AS REQUIRED BY THIS NOTICE TO APPEAR, THAT tatAY BE HELD IN CONTEMPT OF COURT AND A WARRANT FOR MY ARREST SHALL BE ISSUED. Signature of Delerelent Coe Junrele and Pont" / Guardia) ale Seined HOLD of OM*Agency Nan*: Scrotum ct Arresting Me X Name Verlication (Prior:11Y M 41041 O bentraus O Rowed km.' Name of Arrest.% Officer (Pont) 1.0. 1 (PRWT) O Surber O Ca Mr PAGE rake Deputy I.D. e Pouch Transporting Officer L0.1 Arne? Witness here a;Ora war wen an IT OF DISTRIBUTION: WHITE — COURT COPY GREEN — STATE ATTORNEY YELLOW — AGENCY PINK — JAIL MO DEFENDANT IN .T A s ONLY. EFTA00230898 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 Police Case#: 05-368 (2) Defendant: Race/Sex: White Female DOB: Charges: Principal in the 1" Unlawful Sexual Activity with a Minor (4) counts Principal in the 1" Lewd and Lascivious Molestation (1) count From March 15, 2005, through February 2006 the Palm Beach Police Department conducted a sexual battery investigation involving Jeffrey Epstein, =I= and . Sworn taped statements were taken from five victims and seventeen witnesses concerning massages and unlawful sexual activity that took place at the residence of Jeffrey E stein 358 El Brillo Way, Palm Beach. Several of the victims were recruited by and brought to the residence by to perform massages for Epstein for which received monetary compensation. During the visit they would be introduced to ==, Epstein's assistant, who in turn would record their telephone numbers and name. The victims would be brought to Epstein's bedroom to provide the massage. Epstein would enter the room and order the victims to remove their clothing to provide the massage. As the victims complied and provided the massages, E stein would On occasion, Epstein would introduce a massager/vibrator and as they provided the massage. On three separate occasions, Epstein had intercourse and inserted his penis/fingers in the victims vaginas. At the conclusion of the massages the victims were paid sums of money ranging from $200 - $1,000. The facts, as reported, are as follows: On 03/15/2005, A fourteen year old white female, hereinafter referred to as "M," dob and her family reported unlawful sexual activSwhich occurred at a residence within the Town of Palm Beach. reported that a stitect known to her as "M' had touched her vaginal area with a vibrator/massager while within his residence. ' was later identified as Jeffrey Epstein through a photo line up. During a sworn taped interview, stated that , dob a cousin of boyfriend and classmate at Ro al Palm Beach High School, worked for a wealthy man and did sexual favors for him. She also admitted that had offered her an opportunity to make mone During the beginning of the month of February 2005 explained that she was first approached by to o with her to Epstein's house. stated that alon with a Hispanic female, later identified at tck her up at her father's house on a Sunday. was not sure of the exact dates but knew it was a Sunday. i told her father that they were going shopping but in reality drove them to Palm Beach. During the drive a The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det , who is personally known to me. State of Florida Signature of Police Officer (F.S.S. 117.10) coun Signa 7jesting Officer Date: t 01/2006 Pagel of 22 EFTA00230899 Signature of Police Officer (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 conversation occurred between and whereas she should say she was eighteen. It was later confirmed by the father that . re rtedly told ilihat if M asked her age, picked his daughter up on February 6, 2005. According to father, drove a pick up truck. . described Epstein's house as a two-story pink house with a Cadillac Escalade parked in the driveway. She recalled that Jeffs house was on a dead end street. Upon arriving at the house . stated that they walked up a driveway, ast what appeared to be a small guard/security room. A male approaching them asking what they wanted. stated they were there to see Epstein. The male allowed them to continue walking up to the house. stated the man told them that Epstein was not there but was expected back. He allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside. Short! thereafter, Epstein and his assistant, described as white female with blond hair and later identified as , entered the kitchen. Epstein introduced himself toe. . described Epstein as being approximately forty-five years old, having a long face and bushy eyebrows, with graying hair. and Epstein left the kitchen leaving . alone in the kitchen. They returned a short time later. They all spoke briefly in the kitchen. . was instructed to follow upstairs. . recalled walking up a flight of stairs, lined with photographs, to a room that had a massage table in it. Upon entering the room there was a large bathroom to the right and a hot pink and green sofa in the room. There was a door on each side of the sofa. . recalled there .b a mural of a naked woman in the room, as well as several photographs of naked women on a shelf. told the victim that Epstein would be up in a second. Epstein entered the room wearing only a towel and told . to take off her clothes. . stated Epstein was stem when he told her to take off her clothes. IMI said she did not know what to do as she was the on! one there in the room, she took off her shirt leaving her bra on. Epstein had removed his towel and told the . to take off everything. I stated Epstein was nude when he took his towel off, placing it on the floor as he laid down on the table. stated she then removed her pants leaving her thou antics on. Epstein then instructed her to give him a massage pointin to a specific lotion for her to use. As II began to give E stein the massa e, he told her to et on his back. stated she straddled herself on Epstein's back whereby . . said Epstein was specific in his instruction to her on how to massage him, telling her to go clockwise or counter clockwise. Epstein then turned over and instructed . to massage his chest. IN was now standing on the ground and resumed massaging Epstein's chest area. IMI stated Epstein held onto the small of her back as she massaged his chest and shoulder area. Epstein then turned to his side and started to rub his penis in an up and down motion. Epstein then pulled out a purple vibrator and began to The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det who is personally known to me. State of Florida Page 2of 22 EFTA00230900 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 . stated there was no penetration as the recalled Epstein ejaculating because he had to use the towel to wipe himself as he of off the table. Epstein then left the room and . got dressed. She went back downstairs where she met with. . said she was paid three hundred dollars in cash from Epstein. Before she left, Epstein asked to leave her phone number. As M, and were leaving the house, told • she received two hundred dollars that day for bringing her. During the course of the investigation, parental consent was granted for to assist with the investi ation. At our direction conducted controlled taped phone calls to cellular telephone . . spoke with in an attemsnange another meeting with Epstein. . asked , what did she need to do to make more money. stated, "the more you do, the more you get paid." had subs uently called back ill and left a voice mail message for her indicating that she had set up an gmintment for El to go to Epstein's house at 11:00 am on April 5, 2005. This message was recorded from voice mail. Based on the above, trash pulls were established at Epstein's residence with Supervisor Tony Higgins of the Sanitation Bureau of the Town of Palm Beach. The trash pull from April 5, 2005 revealed a telephone message for Epstein which stated and name at 11:00 am. This was the time frame had informed to be ready to go work at Epstein's house. On October 3, 2005, Sgt and I went to residence and viewed her vehicle parked in the driveway, a red Dodge Neon. Sgt. and I knocked on the door and met with . was told that we were investigating a claim involving Jeffrey Epstein of El Brillo Way, in Palm Beach was asked if she would accompany us back to the police station for further questioning. She was also told that at the conclusion of the interview she would be returned home. voluntarily came with us back to the Palm Beach Police Department. Upon our arrival at the police station, was brought to the interview room in the Detective Bureau where I obtained a taped, sworn statement. I began the interview by asking how she became acquainted with Epstein. stated that approximately two years ago, just after she turned 17 of age, she was approached by a friend named at the Canopy Beach Resort in Rivera Beach. was asked if she wanted to make money. She was told she would have to provide a massage and should make $200.00. thought about the offer and agreed to meet with Jeffrey. The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by County of Pal Beach Det who is personally known to me. State of Florida g Officer Sign .10) Date: /2006 Page3of 22 EFTA00230901 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 (Unknown last name) and Tony (Unknown last name) picked up and she was taken to Epstein's house. Upon her arrival to the house she was introduced to Epstein in the kitchen of the house. She was also introduced to a white female known to her as . She was led upstairs to the main bedroom known to her asEEpstein's bedroom. arranged the massage table and covered the table with a sheet. She brought out the massage oils and laid them next to the massage bed. then left the room and informed E would be in, in a minute. •entered the bedroom wearing only a towel. He removed the towel and laid nude on the massage table. He laid on the table onto his stomach and picked a massage oil for to rub on him. Durin massage, stated "He tried to touch me and I stopped him." I asked how he tried to touch her. stated that Epstein and she felt uncomfortable. told Epstein, I'll massage you but I don't want to be touched. stated she performed the massage naked. At the conclusion of the massage, Epstein paid $200. After the massage Epstein stated to that he understood she was not comfortable, but he would pay her if she brought over some girls. He told her the younger the better. stated she once tried to bring a 23 year old female and Epstein stated that the female was too old. stated that in total she only remembers six girls that she brou ht to .pstein, se each time she was paid $200. stated she had brought the followin irls: . , , M. ( al6 year old female), (a 16 year old female) and . said that at the time she brought thesLFIs o Epstein's house they were a1114 through 16 years of age. I asked which one was the youngest. advised E was the youngest as she was fourteen when the massage occurred. stated every girl she brought knew what to expect when they arrived. They were told they would provide a massage, possibly naked, and allow some touching. I asked her if E was aware. She stated every girl she brought knew what to expect. She exSined she knew that wanted to make money. She approached E and explained about going to work for M, E agreed and arrangements were made to bring her to Epstein's house on a weekend. stated that she and (Later identified as picked up E at her house. stated that at that time she was driving a red pickup truck. They traveled to tein's house and entered through the kitchen door. They met with the house chef and Epstein's assistant . IN was introduced to Epstein while the were in the kitchen area. led E upstairs and Epstein went upstairs. When the massage was over returned to the kitchen area. stated she was paid $200.00 for bringing E to Epstein's house. stated E told her she was paid $300.00 for the massage. stated that E was the last person she brought to Epstein's house. She had changed her cellular number to avoid being contacted by . She continued stating that she had no direct contact with Epstein The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det who is personally known to me. Signature of Police ficer 117.10) State of Florida C each Signatu ing Officer Date: 0 i 1/2006 Page tiof 22 EFTA00230902 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 when he was going to travel to Palm Beach. said when Epstein announces to his assistant, that he is traveling to Palm Beach, would then contact to arrange girls to "work" for Epstein. stated that once her arents discovered that she was visiting Epstein,alisapproved of the encounters with him and she stopped. further stated that still tries to call house and leaves messages. Sgt entered the room and explained to that based on her own statements, she had implicated herself by bringing underage girls to Epstein's house. provided cellular telephone numbers for the girls she had mentioned previously. Additionally, she also provided possible addresses and areas in which they lived. As was being taken home in the vehicle, a tape recorder wiled within the vehicle to record any conversations within the vehicle. During the drive back to her home, made the comment " I'm like a Heidi Fleiss." (Hollywood Madam who sent girls to clients for sexual favors in California). was dropped off at her house without incident. On October 3, 2005, Sgt and I went to speak with , a sixteen year-old female who was brought to Epstein's residence by . We met with mother at their front door. We exatined the ongoing investigation and asked to speak with. as we had information that she had "worked" for N. introduced us to her husband and allowed us entry into the home. We sat in the dining room and met with •, Date of Birth . As she was under the age of eighteen, was advised we would be speaking with her. She expressed if her daughter had information, she wanted to assist. We interviewed., who denied havin any inappropriate encounters with (Epstein). She stated she had gone to Jeff's house with approximately eight months ago and sat in the kitchen with the house chef, but nothing happened. As the parents were present during the interview, we felt that • was withholding information from us. She made several comments as to putting the entire incident behind her. I left my alone number and advised should she wish to speak with me again to telephone me. Sgt and I thanked for her time and left the area. She stated she would ask i again after we left as to what happened at Epstein's house. I informed her that. had my telephone number and hopefully she would call. On October 4 2005, Det and I drove to the , dob . During a sworn taped statement, when she was seventeen years old, she was taken to a house by because they both attend Royal Palm Beach High School. home and met with and stated approximately a year ago stated she knows She was told she could make money working The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det , who is personally known to me. Signature o o ice leer . . 7.10) State of Florida Page Sof 22 EFTA00230903 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 for E. She was told she would have to provide a massage to stated upon her arrival to the house she was brought to the kitchen area by . They met with the house chef who was already in the kitchen area. stated would wait for her in the kitchen. was introduced to , Jeff's assistant, who brought her upstairs to the master bedroom. prepared the room and massage table for a massage. Epstein entered the room wearing only a towel and she provided a massage. stated she ke t her clothes on during the massage. She advised sometime during the massage, Epstein and pulled her close to him. the massage, she was paid $200.00 for the massage. I asked said she was uncomfortablei the incident involving At the conclusion of if she has any formal training in mass es to which she re no. I asked her if received any monies for taking her to perform the massage. stated had received money for taking her there but was unsure in the amount. stated she returned to Epstein's house on another occasion with and another rl, stated she waited in the kitchen with , while was taken upstairs by stated she only did the massage once as she was uncomfortable with the whole experience. At the conclusion of the interview, the tape was stopped. I was informed that had attempted to reach via cell phone. A voice mail messa e on October 4, 2005 at 10:59 am, revealed a female voice who identified herself as who requested to call her back reference the police questionin provided the incoming telephone number as stated she inadvertently told about the police investi ation because had called her to tell her about how she just received a rental car from MEpstein. had called her to tell her that she was given a rental car, a 2005 Silver Nissan Sentra, to utilize to visit familand visit Epstein. be asking questions. stated asked her what was oin on at the house that the police would then called and and asked what was going on reference the ongoing police investigation. Accordin to has since then been trying to contact her to ask about theSquestions. I instructed not to contact and do not provide any more information to as she would notify Epstein and what was transpiring. On October4, 2005, I made telephone contact with who had left several messages for me to contact her. During the message, she advised she was not completely truthful when we met in person but would like to speak with me to advise what had happened. She further advised she did not want to speak of this incident in front of her mother. At approximately 3:48 pm I made telephone contact with During a taped recorded statement stated the following: approximately a year ago, when she was sixteen years of age, took her to Epstein's house twice. She knows because they both attend Royal Pal Beach High School. The first time she went, drove to the house. They entered through the kitchen area where she was The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Coun of Pal Beach Det , who is personally known to me. State of Florida Signature o o is ice . . 117.10) gna u 1 'I mg Officer Date: 05 /2006 Page4of 22 EFTA00230904 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 introduced to and Epstein. She was taken upstairs to a bedroom by who set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for to rub on him. At one point during the massage he tried to remove her shirt, at which point she became very upset and discontinued the massage. Both and E stein had a verbal disagreement, at which time she left without being paid. She got with who was sitting in the kitchen and told her "let's go." advised she received no money for that day. also said that had told her if she was uncomfortable with what was going on, to let him know and he'll stop. She knew that the more ou do the more you get paid. advised that several weeks later she agreed to be taken a second time by . Once they arrived at the residence, sat in the kitchen and took her upstairs to the master bedroom again. set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for to rub on him. At one point during the massage he tried to touch her buttocks. As, was wearing tight jeans and had a tight belt on Epstein was unable to touch her buttocks. Epstein then rolled onto his back during the massage and then attempted to touch her breasts.. then became ui set again and told Epstein she didn't want to be touched. discontinued the massage and was paid $200.00. then went downstairs where was waiting for her. She told she wanted to leave. said she never returned to the house. stated she is aware that her friend, was also at the house and had a problem with Epstein. I later researched dob , and met with her at her residence. During a sworn taped statement, stated the following: on or about November 2004 she was approached at Royal Palm Beach High School by , a fellow student. asked if she wanted to make money. She agreed and was told she would provide a massage to wealthy man in Palm Beach. picked her up and drove her to a house in Palm Beach. She was brow ht into the kitchen area of the house. She further stated that fellow Royal Palm Beach High School students and came with them. They were brought into the kitchen where she was introduced to Epstein and other females. stated she was introduced to a female helper of Epstein, the female was described as white female (unknown name ), with blond hair. She stated that the assistant was familiar with . The assistant brought her upstairs into a master bedroom area. The assistant set up the massage table and put out lotions to be used. She told Epstein would be available in a minute. Epstein entered the room wearing only a towel. Epstein removed his towel, and laid naked on the massage table and picked a lotion to rub on his thighs and back. further stated duridihe massage, Epstein asked her to remove her clothes. She complied and removed her pants and blouse. didn't remember if she had removed her bra but feels that she did. was certain that she stayed in her thong underwear. continued the massage and at one point she climbed onto the massage The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det , who is personally known to me. State of Florida Cou f alm J each Si g Officer Signature to oh e ter .S. 117.10) Date: 05 006 Pagel of 22 EFTA00230905 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 table, straddling Epstein to massage his back. While doing this was instructed to return to the ground at which time Epstein turned to have his chest rubbed. advised she was sure he was masturbating based on his hand movements going up and down on his penis area. did not want to look at his penis area because she was uncomfortable. Epstein removed a lar e white vibrator which was next to the massage table and turned it on. stated Epstein began Shortly thereafter, Epstein ejaculated and removed himself from the table. He walked over to where the shower was and opened the glass door. She waited as he was taking a shower in her direct view. When I asked how old she was when this occurred, she stated she had just turned seventeen. At the conclusion of the shower, was paid either $350.00 or $400.00. She stated she wasn't sure, but knows it was close to $400.00. stated she never returned to provide a massage for Epstein. At approximately 2:10 pm, Det and I met with M, dob , at her residence. As was only seventeen years of age, I had notified her mother, that she would be interviewed reference an ongoing investigation in Palm Beach. I assured her that her daughter was not a suspect. I explained the possibility of her being either a witness or victim. advised she wanted to cooperate and consented to the interview. During a sworn taped statement, stated the following: at the age of sixteen, during the month of September 2004, she was approached by for a chance to make money. was friends with associates of and knew the same people. had been previously told by her friends from Royal Palm Beach High School, what did for Epstein. called a person known to as and scheduled the appointment. picked up and drove her to Palm Beach to a street called "Brillo Way". They drove to the end of the street and entered a large drivewa . The entered the kitchen area of the house and met with Epstein. was introduced to Epstein. led upstairs to the main bedroom area and set up the room with a massage table and set out the oils. stated that while going up the stairs and into the bedroom she observed numerous photographs of naked young girls. dimmed the lights and turned on soft music. exited the room and Epstein entered the room wearing only a towel. Epstein picked oils and instructed her to rub his legs, under his buttocks, back and chest area. Epstein asked her to get comfortable. advised she did not remove her clothes. She was wearing tight jeans and a cropped tank top ex asinnier it belly area. During the massage, Epstein removed his towel and laid on the massage table naked. As area, he attempted to reach down her pants to touch her buttocks area however was unable to due due to the tightness of the jeans and a tight belt. advised Epstein began to masturbate as she rubbed his chest. Epstein moaned as she rubbed his chest. She observed he was continuing to masturbate and The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Coun of Pal Beach Det , who is personally known to me. State of Florida Si S g ng Officer 17.10) Date: 05/ 006 PageSof 22 EFTA00230906 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 attempted to reach up her tank top and touch her breasts. M, pulled back and Epstein stopped, however he kept masturbating until he climaxed. He cleaned himself with the towel he was previously wearing. was paid $200.00 for the massage and left the area. She met with who was waiting in the kitchen area and left the house. then ex lained she never provided another massage ftStein. She did however, go to the house with and as they took another friend of . M advised she was present when went to work for Epstein. She advised she rode over and sat in the kitchen area with to wait for M advised while they waited for the house chef prepared lunch for them as it was almost lunchtime when they went. When was finished with the massalithey left the area. I asked MI if ever told her what would be expected when she provided a massage.. stated yes told her that a massage would be expected, ssibly naked and possibly some touching involved. I has no formal training in providi massages. . spoke about a third and last time she went to Epstein's house. drove another girl„ (sixteen years of age) who is friend, to Epstein's house. M stated knew that M had made money massaging EE to and took M upstairs to the main bedroom. stein and wanted to make money herself. took them in the kitchen area of the house and introduced advised she doesn't know what happened as did not speak about what happened in the room. M received . . $100.00 from for going with her to Epstein's house and recommending M. On October 6, 2005, at 11:45 am, I met with dob , at and explained to her why we there to interview her. She advised she was aware of the ongoing investigation. stated she had previously spoken with sworn taped statement, stated she knew that who told her she was interviewed by detectives. Duly worked for Epstein in Palm Beach. advised she originally had been taken to the Epstein house by , whom she met when they both attended Royal Palm Beach High School. She began going to the house when she was sixteen years of age and stated she had been there a lot of times to provide massages over the past two years. I asked her if she had formal training in providing massages, which stated she had not. advised she was told what was expected of her by providing massages and she would have to remove clothing but if she felt uncomfortable just to say and Epstein would stop pushing the issue. began providing massages and advised she kept her clothes on. She considered Epstein a pervert and he kept pushing to go further and further. explained she would keep telling him she had a boyfriend and would not be right to her boyfriend. It wasn't until recently that began removing her clothes and staying in her thong underwear to provide a massage. explained The foregoing instrument was sworn to or affirmed State of Flo ida before me this 1" day of May, 2006 by Det , who is ersonally known to me. Si 7.10) Coun Beach Sign esting Officer Date: 05/ i 1/2006 Page? of 22 EFTA00230907 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 Epstein wanted to be rubbed on his back and recently he began turning over and have her rub his chest as he masturbated. He would try to touch her breasts as she rubbed his chest. stated "MI would try to get away with more and more on each massage". stated would try to touch her more and on one occasion he sainted to use a massager/vibrator on her. drove. to the house for the original massage. left her cell phone number and every time Epstein would come into town, would call her for an appointment to "work". Each time she went, r would meet her at the kitchen door area. She would bring her upstairs and re are the massage table. advised Epstein would ask her questions about herself. Epstein knew she was and would be attending . I asked if Epstein knew her real age. stated Epstein did and didn't care. The most recent massage she provided was on October 1, 2005. During the massage, she asked Epstein if she could borrow one of his vehicles to visit her family and boyfriend in Florida. Epstein had told her she could borrow one of his vehicles but later stated he would rent her a car. She continued with the massage as Epstein and . I asked if she was wearing undergarments to which she replied her thong underwear. Once he tried to touch her breasts, she would pull away from him and he would stop. IM was asked if he ever used a vibrator on her. was aware of the vibrator but advised she never would allow him to on her. She described the vibrator as the large white vibrator with a huge head on the tip of the vibrator. She stated he kept the vibrator in a closet near the massage table. stated that on October 3, 2005, she was contacted by Epstein's assistant, , who informed her that Jeff Estein had rented her a new Nissan Sentra and she should come by the house to pick it up. informed she would have the car for a month. stated Epstein knew her car was not working properly and that she had missed appointments in the past because of her car being inoperable. explained the car is currently parked next to the Gym field. I asked her if she ever took any one to the house. explained she took a friend of hers who attended Royal Palm Beach High School, who has relocated to to attend college. 1 asked if she ever allowed another female in the room. advised no one was brought into the room with her. At the conclusion of the interview, Det and I went to the gym area of and located the Silver Nissan Sentra bearing Florida tag . The vehicle is registered to Dollar Rent a Car out of the Palm Beach International Airport. The vehicle was rented by Janusz Banasiack, later learned to be Epstein's houseman, and paid with Epstein's credit card. On September 11, 2005, w/f e, dob a, was arrested by the Palm Beach Police Department The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det , who is personally known to me. State of Florida Con ach Sign g Officer Signature of Po ice leer .S.S. 17.10) Date: 05 /2006 Pagel0of 22 EFTA00230908 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 for misdemeanor possession of marijuana. During the arrest. told the arresting officer that she had information about sexual activity taking place at the residence of Jeffrey Epstein. Additionally, during the ongoing trash pulls from Epstein's residence, discarded papers were found which contained name and cell phone number. On October, 11, 2005, Det and I met with M and obtained a sworn taped statement. explained she had been going to Epstein's house since 2002, when she was sixteen years of age. Since then she has gone to the house hundreds of times. • stated she became his "number one girl." She explained that on her first visit she was brought to the house by fellow Royal Palm Beach Hi School classmate, said she was brought through the kitchen area where she met . for the first time. was led to the, master bedroom, Epstein s room. • explained that as she was walking up the stairs she observed several photographs of naked women along the walls and tables of the house.. further explained that she was brought into the bedroom, where prepared the room by setting up the massage table and provided the oils for her to rub on Epstein. • explained she remembered the steam room area, which contained two large showers. Epstein entered the room from the steam room area and introduced himself. Epstein lay on the table and told her to get comfortable. • removed her skirt and kept her shirt on. Epstein then instructed her to remove her shirt.. removed her shirt and remembered she was not wearing a bra. stated she provided the massage wearing only her anties. She continued rubbing his legs, thighs and feet. advised he turned over onto his back. Epstein and be an to masturbate. Epstein ejaculated which meant the massage was over. At the conclusion of the massage, was paid $200.00. They walked together downstairs where and Shady were waiting. stated received an unknown amount of money for taking her to Epstein. Epstein instructed to leave her cellular telephone number so that he could contact her when he is in town. stated that during her many visits a routine was established between her and Epstein. She would enter the house and get naked in the bedroom. She would then start with a back massage. Epstein would roll on to his back and allow her to massa e his chest area. stated E stein would then began to masturbate himself and at the same time would with his fin ers. ex lained E stein would continue this process until he ejaculated. He would then . • advised that during her frequent visits Epstein asked for her real age, Epstein advised her not to tell anyone her real age. would instruct and pa to intercourse included Epstein would watch them stated she was sixteen. advised that things escalated within the home as Epstein explained the that Epstein had at his disposal. and masturbate himself . Occasionally, Epstein would then join in The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det , who is personally known to me. State of Florida Coun ach Signature ng Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/ 006 Paget) of 22 EFTA00230909 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FIX) 500600 during the the time was sixteen years of age. to both • and a. This occurred during % advised this continued to escalate during two years. The routine became familiar toe. Epstein's assistant would telephone her every time Epstein was in the Town of Palm Beach and would place appointments for her to visit and work for Epstein. Each time something new was introduced, additional monies were produced and offered for . to allow the acts to happen. • consented to perform all these acts but was adamant that there was an understanding with E stein that no vaginal penetration would occur • . explained that Epstein's penis was deformed.. explained that his penis was oval shaped. claimed when Epstein's penis was erect, it was thick toward the bottom but was thin and small toward the head portion. called E stein's penis "egg-shaped." . stated Epstein would photo ph and her and proudly display the photographs within the home. stated during one visit to Epstein's house and her would in which she provided a masse e to E stein, his female friend, was also resent. provided the massage in which for Epstein to enjoy. Towards the end of this masse e, E stein rabbed and turned her over onto her stomach on the massa• e table and stated E stein be an to became upset over this. She said her head was , as he continued to . She screamed "No!" and Epstein stopped. She told him that she did not want to . Epstein did not eiLculate inside of her and apologized for his actions and subsequently paid her a thousand dollars for that visit. IMI stated she knows he still displays her photographs through out the house. On October 12, 2005, Det and I met with dob , who stated during a sworn taped statement, that nothing happened between her and Epstein. appeared nervous during the interview. I assured her that I have spoken with other people who advised differently. stated on several occasions she rovided a massage to Epstein. She stated she was brought to the Epstein house in March of 2005. MI classmate at Royal Palm Beach Hi approached her and asked her if she wanted to "work". MI made the arrangements with , Epstein's assistant. , who has no formal training in providing masse es stated she provided a massage, fully clothed for $200.00 . As I sensed hesitancy in her answers, I asked if she had been contacted by anyone from Epstein's organizations or his house. stated she was interviewed already by a private investigator for E stein. He identified himself as'." and in about the police investigation, and left his telephone number for additional contact. provided no additional information, as it appeared her responses were almost scripted. The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Cou Det who is personally known to me. State of Florida Signature/ Signature of Police fficer F.S.S. 117.10) Date: 05/01 g Officer Page 13)f 22 EFTA00230910 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 On November 6, 2005, at approximately 3:30 pm, I met with , dob Palm Beach Police Department. was identified as a potential witness/victim through information obtained during the trash pulls. During the sworn taped statement, advised she was at Jeffrey Epstein's house one time, approximately two months ago. She was approachedlys&I, , who was dating • roommate, for an opportunity to make some quick money. advised she needed to make some quick cash to make the rent that month. She agreed to go to the house. She had been told by that the massage would have to be done in her underwear. She advised drove with her and brought her into the house. They walked into the kitchen area, and took the stairs upstairs. further stated she was brought into a master bedroom area. She advised she recalled seeing portraits of naked women throughout the room. A massage table was already out near the sauna/shower area in the master bedroonSin entered the room wearing only a towel and introduced himself as "Jeff." At Epstein's direction, and removed their clothing down to their panties, Epstein laid on his stomach area and they provided a mass e on his legs and feet area. I asked if she had any formal massage training and she replied "no." advised she was topless and the panties she wore were the boy shorts lace panties. She and continued the massage until the last ten minutes of the massage, Epstein, told to leave the room I that could finish the massage. got dressed, and left the room.sEritein turned over onto his back. Epstein then removed the towel and laid naked . stem that rub his chest area. stated , Epstein, began masturbating. stated Epstein pulled down her boy short panties, and he produced a large white vibrator with a large head. She stated it was within his reach in a drawer in his master bathroom. He advised he never with the vibrator. He continued to as he continued to masturbate. stated she was very uncomfortable during the incident but knew it was almost over. Epstein climaxed and started to remove himself from the table. He wiped himself with the towel he had on previously and went into the shower area. got dressed and met with in the kitchen area. Epstein came into the kitchen and provided $200.00 for bringing paid $200.00 to for providing the massage. was told to leave her telephone number with for future contact. provided her cellular telephone number. was asked if she was recently contacted about this investigation by ansfrom the Epstein organization. She replied she was called but it was for work. She stated she was called by for her to return to "work" for Epstein. stated "work" is the term used by to provide the massages and other things. advised she declined as she was not comfortable in providing that type of "work." On November 7 2005 Det and I met with sworn taped statement, stated she met Jeffrey Epstein through , dob . During a when they were still The foregoing instrument was sworn to or affirmed before me this V' day of May, 2006 by County of Pal Beach Det , who is personally known to me. State of Florida Signature of Police Officer .S.S. 117.10) Signatu m ing Officer Date: 05/01/2006 Page nof 22 EFTA00230911 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 attending Royal Palm Beach High School. would approach females who wished td work for Epstein. stated she was offered to work for Epstein but declined. explained that "work" means ive massages. She was asked about any formal training in providing massages which she said "no." said she accompanied and other females who were taken to Epstein's house to provide massages. with further stated she had been to the house a roximat& 4 or 5 times .teist in tl year. She accompanied , and . Each time the girls were taken over, they were previously told they would have to provide a massage, possibly naked. They were also told that should E stein require them to do anything extra, and they were not comfortable just to tell him and he would stop. stated received $200.00 for each girl she brought over to massage Jeffrey Epstein. When I asked which girl appeared to be the youngest, she replied, E, who was really young, fifteen years old at the most. further stated each time she went to the house, she sat in the kitchen and waited with until the massage was over. She further stated that the cook would make lunch or a snack for them as they waited. I asked her if there was anything that caught her attention within the home. stated there were a lot of naked girls in photographs throughout the house. On November 8, 2005, at approximately 2:00pm , I met with , dob , at the Palm Beach Police Department. During a sworn taped statement stated she had met Epstein approximatelyakears ago when she was first approached by , a classmate at Royal Palm Beach Hi School. approached her about working for Epstein and providing a massage to him for $200.00. had made the arrangements however was unable to take her the day the arrangements were made. had take also attended Royal Palm Beach High School and was familiar with Epstein. recalled she was brow t there and entered through the back kitchen door. She had met with an assistant and another assistant brought her upstairs as she observed several photographs of naked females throe out the house. stated Epstein came in the room, wearing only a towel, and laid on the table. stated he icked out the oils he wanted her to use and requested she remove her clothing to rovide the massage. stated that on the first massage she provided she did not remove her clothing. stated she had returned several times after that. Each time she returned it was more than a massage. Epstein would walk into the master bedroom/bathroom area wearing only a towel. He would masturbate as she provided a massage. stated she was unsure if he climaxed as he masturbated under the towel. Additionally, she never looked below his waist. She claimed that Epstein would convince her to remove her clothes. She eventually removed her clothes and stayed in her thong panties. On occasion,lign would use a masse er/vibrator, which she described as white in color and a large head. Epstein would as he would masturbate. stated she had been to the house The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Coun of Pall Beach Det who is • ersonall known to me. State of Florida Sig ing Officer Signature of Policeofficer .S.S. 117.10) Date: 05 7 /2006 Page/yof 22 EFTA00230912 Signature of PolicE Officer (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 numerous times. added she has no formal tr in providing a massage. stated she brou t two females during her visits to provide massages. stated she brought a girl named ' and from Royal Palm Beach High School. stated she received $200.00 for each girl she brought. On November 8, 2005,1 met with , W/F, , at the Palm Beach Police Department. During a sworn taped statement, stated she had met Jeffrey Epstein approximately one year ago. She was approached by a suleiknown to her as M. • had asked her if she wanted to make money providing massages to Epstein. had heard that several girls from Ro l Palm Beach High School were doing this and making money. She agreed and was taken to the house by M.. had introduced her to and Epstein and brou t her upstairs to a master bedroom where a masse table was prepared and the proper oils were selected. left the room and waited downstairs for her. stated Epstein entered the room wearing a towel and laid on his stomach. She provided a massage wearing only her thong panties. advised Epstein had masturbated every time she provided a massage. She stated Epstein continued to masturbate until he climaxed. Once that occurred the massage was over. She felt the whole situation was weird but she advised she wild $200.00 for providing the massage. She also stated El was paid $200.00 by Epstein for bringing . stated she had gone a total of 15 times to Epstein's residence to provide massage and things had escalated from just providing a masse e. E stein be an touchin grabbed her closer to him as he masturbated. Epstein also and and with his hands as she provided the massage. stated on one occasion, while she was only seventeen years of age, he offered extra monies to have vaginal intercourse. She stated this all occurred on the massage table. stated Epstein and be an until he reached the point of climax. Epstein removed and climaxed onto the massage table. received $350.00 for her massage. I asked her if she had any formal training in providing massy es, stated she did not. continued to state on one other occasion, Epstein introduced his girlfriend, into the massage. was brou t into room with to provide a massage. Epstein had them as they provided a massage to Epstein. Epstein, watched and masturbated as this occurred. On other occasions, introduced the large white vibrator/massager in the massage. Epstein on vagina as she provided the massage. On November 14, 2005, Det and I met with dob During a sworn taped statement she advised she started going to the house approximately one year ago and has been there approximately five or six times. also stated she was sixteen years old when she first went to Epstein's house. On her first visit she was brought by a fellow student from Royal Palm Beach High School known to her The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Co Det who is personally known to me. State of Florida Date: 0 2006 Officer PageI9 f 22 EFTA00230913 Probable Cause Affidavit Palm Beach Police Department Agency ORO FLO 500600 as stated brought her into the house and she was introduced to then brought her upstairs into a master bathroom, located within the bedroom. stated she met Epstein in the bathroom. He laid on the table and picked the massage oils. She provided the massage as he laid naked on the massage bed. She stated she rubbed his calves and back area. Upon the end of the massage, Epstein removed himself from the massage table and paid her $300.00 for the massage. said each subsequent time she went to the house, she was notified by that Epstein was in town and would like her to "work". stated she returned to the house and was again led upstairs by She provided the massage, clothed. was asked if she ever removed her clothing to aa •ri massage. stated it was not until the third time that she went that she removed her clothing. stated she was notified by that Epstein wanted her to come to work. She arrived at the house and was led aL irs by . She started providing the massage when Epstein asked her to remove her clothing. removed her pants, shirt and bra. She sta ed in her sit tI anties and . Epstein turned over onto his back and she stated she knew he was masturbating himself as she providing the massage. stated she believed he climaxed based on his breathing. She did not want to view either the climax or the fact that he was masturbating. stated once the breathing relaxed he got up and told her to get dressed. She was paid $300.00 for her services. stated on the last time she went to provide a massage, she was notified by to come to the house and "work". stated she was now dating her current boyfriend and did not feel comfortable going. She recalled it was approximately January 2005. She said she went, already thinking that this would be the last time. She went upstairs and went into the master bathroom. She met with Epstein, who was wearing only a towel, and laid onto the table. stated Epstein caught her looking at the clock on several occasions. Epstein asked her if she was in a hurry. stated her boyfriend was in the car waiting for her. further stated that Epstein got upset as he wasn't enjoying the massage. She told him that she didn't want to continue and she would not be back. Epstein told her to leave as she was ruining his massage. advised she had no formal training in providing any massages. stated although she had a falling out with Epstein, she still received a Christmas bonus from Epstein. stated she was wired money from Western Union for her Christmas bonus. Sub ena results from Western Union revealed money was sent from Jeffrey Epstein on December 23, 2004. received $200.00 from Epstein for her Christmas bonus. On November 15, 2005, Det. and I met with M, dob 04/21/1988. During a sworn taped statement, stated she met Jeffrey Epstein over a year ago. She was sixteen years of age and was approached by , a fellow Royal Palm Beach High School student, who informed her that she could make $200.00 providing a massage to Epstein. had informed her that she would have to provide this The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Coun Det who is personally known to me. State of Florida Sign Signature of Police Officer (F.S.S. 117.10) Date: 05/0 06 ach g Officer Paget/prof 22 EFTA00230914 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 massailess. made the arrangements with Epstein and his assistants and took . to the house. U stated and she entered through a glass door that led into a kitchen. She was taken upstairs by to a master bedroom. She recalled the master bathroom had a tar". couch, sauna and matching shower. Epstein entered into the room wearing only a towel.. and removed their clothing remaining only in thong underwear. She further stated that Epstein laid on his chest on the table. The oils were selected on which ones to use. Both and . provided the massage on his legs, back and feet. Forty minutes into the massage, Epstein turned over onto his back and re uested wait downstairs in the kitchen area for Epstein instructed . to finish the massage. As ot dressed starti rubbing Epstein's chest. left the room, and Epstein began masturbating as . stated Epstein continued masturbating until he climaxed on the towel he was wearing. When asked if he had removed the towel she stated he turned the towel around th at the opening would allow him to expose himself. After he cleaned himself off with the towel he instructed the massage was done and to get dressed and meet with him downstairs. ot dressed and met with Epstein in the kitchen area. She was paid $200.00 dollars for providing the massage. stated she was aware that also received monies for the same thing. The second time she went to the house she was again approached by advised if she wanted to return to the house tlEovide another massage.. agreed and the arrangements were made by for her to return to the house. M stated drove her to the house and knocked on the same glass door which leads to the kitchen area. They were allowed entry into the house one of the staff members. led her upstairs to the master bedroom and master bathroom area. = left . this time to do the massage alone. Epstein entered the room again wearing only a towel. • began removing her clothing as she did the last time she was at the house. Epstein instructed her to get naked. He laid on the table onto his stomach as . began masse his legs and back. As . finished with Epstein's back and legs, Epstein then turned over onto his back. M started to rub his chest and he began masturbating. As ru bbed his chest, Epstein leaned over and produced a massager/vibrator. He turned it on and began rubbing vagina and masturbating himself at the same time. . stated she as this was occurring. She described the vibrator/massager as large grey with a large head. Epstein ximately two to three minutes with the massager/vibrator. He then removed the and concentrated on masturbating himself. • stated Epstein climaxed onto the towel again and informed her that the massage was done. ot dressed and met with who was waiting in the kitchen area. She received $200.00 for the massage. said she never returned to the house and had no desire to return to the house. • was asked if she received any formal massage training. She advised she had no formal training. • was asked if Epstein knew her real age. • stated he knew, as he asked her questions about herself and high school. He was aware she attended, and is still attending Royal Palm Beach High School. The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Court Det , who is personally known to me. State of Florida Signa Signa 117.10) Date: 05 006 g Officer Page if 22 EFTA00230915 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 During the course of the investigation a search warrant was executed at Jeffrey Epstein's home located at 358 El Brillo Way in Palm Beach. While in the home I observed the pink and green couch within the master bedroom area just as the girls previously mentioned. The stairway, which is located from the kitchen area to the master bedroom area, is lined with photos of naked young girls. Additionally, numerous photographs of naked young females, some of which appeared to be the girls I previously interviewed, were on display throughout the house. Also located in the house were various phone message books. The telephone message books have a duplicate copy (Carbon Copy) which, once a phone message is written into the book, the top copy is then torn on the perforated edge and the carbon copy is left in the book. First names of girls, dates and telephone numbers were on the copy of the messages. I recognized various numbers and names of girls that had already been interviewed. The body of the messages were time of the day that they called for confirmation of "work." Other names and telephone numbers were located in which the bod of the messages were, "I have girls for him" or "I have 2 girls for him." These messages were taken by , who signed the bottom of the messages. During the execution of the warrant, I located a Royal Palm Beach High School transcript for in Epstein's bedroom desk. This desk had stationary marked Jeffrey E Epstein. I located a wood colored armoire beside Epstein's bed that contained a bottle of "Joy Jelly," which is used to provide a warm massage. Several massage tables were located throughout the second floor of the residence, including a massage table found in Epstein's bedroom. On the first floor of the residence I found two covert cameras hidden within clocks. One was located in the garage and the other located in the library area on a shelf behind Epstein's desk. A computer was located which was believed to contain the ima es from the covert cameras. The computer's hard drive was reviewed which showed several images of and other witnesses that have been interviewed. All of these images appeared to come from the camera positioned behind Epstein's desk. On December 13, 2005, Det. and I met with M, dob . During a sworn taped statement, stated that when she was sixteen years old she was taken to Epstein's house to provide a massage for money. stated it was before Christmas last ear (2004) when an associate, approached her and asked if she needed to make money for Christmas. made arrangements to take to the house and drove to the house to "work." They were encountered by a white female with long blond hair.. was unable to remember the name of the white female with blond hair but knew she was Epstein's assistant. She was led upstairs by the white female who explained that there would be lotions out already and Epstein would choose the lotion he wanted her to use. She was led through a spiral staircase which led to a master bedroom and bathroom. The massage table was already set up in the bathroom.. described the bathroom as a large spacious bathroom with a steam room and shower beside it. • was introduced to Epstein who was on the phone when she entered the room. Epstein was wearing a white towel and laid on his stomach, that may The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det who is personally known to me. Signature of Folic Office (F.S.S. 117.10) State of Florida Cou each Sign ing Officer Date: 0 0l i 06 Pagetef 22 EFTA00230916 Signature of Polite Offie (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency ORD/ FLO 500600 massage his feet and calves. U started the massage with the oils Epstein chose and rubbed his feet and calves. Epstein got off the phone and requested she massage his back as well. • began rubbing his back and got to the small of his back. Dunn e rubbing of his back, Epstein asked her to fet He requested she remove her pants and shirt. removed her shirt and pulled her pants off stayed in her bra and thong panties. As she finished massaging the small of Epstein's back, he then turned onto his back. Epstein instructed to rub his chest and pinch his nipples. As she , Epstein asked her questions about herself. • remembered telling him she attended Royal Palm Beach High School. Epstein asked her if stated she was shy and didn't like talking about those things. She continued she was sexually active. Before could answer, he also asked what sexualposition does she enjoy. • . Epstein reached u and unsn d her bra from the front. • explained the bra she used had a front snapping device. Epstein and asked her if she like having said "no, I don't like that." Epstein then removed his towel and laid on the bed naked exposing his penis to . He be an touchin his nis and masturbated as he explained Epstein then touched . tensed up and stated Epstein was aware that she was uncomfortable. stated that Epstein said to her, "Relax, I'm not going inside." She further explained Epstein commented to her how beautiful and sexy she was. Epstein then moved her thong panties to one side and began said. "He commented how " He then . She tried pulling back to Epstein and apologized for Ainillis Di time, he kept his and continued to rub her vagina. stated he as he was masturbating. said he climaxed onto the towel he had been previously wearing and got up from the table. Epstein told her there was $200.00 dollars for her on the dresser within the master bathroom. Epstein also told her that there was an additional $100.00 that was to be given to for bringing her there to massage him. Epstein told her to leave her telephone number with his assistant as he wanted to see her again. Epstein stated his assistant would contact her to work again soon. I asked her if she ever received any formal massage training to which stated she did not. stated it was the only time she ever went to work for M and knew what happened to her was wrong. She further stated that she had never been contacted for any additional work. On January 9, 2006, I located and interviewed another victim, dob . was identified as a potential victim/witness from information obtained during trash pulls from Epstein's residence. ■ stated she met Epstein when she was fifteen years of age. She was approached by a friend from Royal Palm Beach High School, to be taken to Jeffrey Epstein's house to work. She was originally told she would be able The foregoing instrument was sworn to or affirmed State of Florida before me this 1" day of May, 2006 by Coun Det who is personally known to me. Signat Date: 05/0 06 titer Pageoof 22 EFTA00230917 Probable Cause Affidavit Palm Beach Police Department Agency ORM PLO 500600 to model limrie for a wealthy Palm Beacher. . was taken to Epstein's house located on El Brill°Wayll= introduced IN to Jeffriastein. Epstein had hiszrsonal chef prepare dinner for • and . At the conclusion of dinner, and Epstein brought . upstairs into a master bedroom area. observed a large massage table with a sheet on it. Epstein entered through a door and exited wearing only a towel. informed . that they were oing to provide a massage on Epstein.. asked why were they doing this instead of modeling lingerie. ex lained to IMI that this was his routine and to rub his calves and feet. Epstein had told . to get comfortable. removed her pants and blouse. . stated she stayed only in panties as she did not wear a bra that evening. stated while rubbing his calves and feet, Epstein turned over onto his back. Epstein told . to rub his chest and rub his ni les. stated that as she started Epstein began masturbating himself . Epstein and with his fingers. E tein continued to masturbate himself as he . Epstein ejaculated on his towel and paid . $200.00 for the massage. 1 . stein told . that if she told anyone what happened at his house that bad things could happen. li and = were brought home by Epstein's houseman and . was afraid that Epstein knew where she lived. stated that several days later she received a telephone call from who coordinated for to return to "work." . returned to the house and was brought to Epstein's bedroom area by who prepared the room for the massage. Epstein entered the room wearing only a towel. Epstein had remove her clothing and provide the massa e naked. be an rubbing his feet and calves and Epstein turned over onto his back. Epstein downward motion on his penis. Epstein continued . E stein be an to masturbate himself with an upwards and with one hand and masturbate with the other hand. Once Epstein ejaculated onto the towel he was wearing, the massage was over. . was paid $200.00 for the massage. Epstein again told . not to speak of what happened at his house or bad things would happen. . wanted to notify authorities however she was afraid of what would happen to either her or her family. During the course of the investigation, several subjects were identified as a potential witness/victim through information obtained during the trash pulls, physical surveillance and telephone message books retrieved from the search warrant. While conducting research on the subjects, I discovered that the females were age eighteen or older. Interviews were conducted on the consenting adults whose statements provided the same massage routine when they went to "work" for Epstein. The females would be notified by , and made appointments for the females to "work" for Epstein. The females would come to Epstein's house and were led upstairs, through a stairwell from the kitchen area, by to Epstein's bedroom. Epstein would then enter the room wearing only a towel, and ask them to et comfortable. The females would then provide the massage naked as Epstein would either and/or utilize the massager/vibrator on The foregoing instrument was sworn to or affirmed State of Florida before me this 1" day of May, 2006 by County Det , who is personally known to me. Signatu fficer Signature of Polie icer ( . . . 117.10) Date: 05/01/ i Pagyepf 22 EFTA00230918 Probable Cause Affidavit Palm Beach Police Department Agency OR!$ FLO 500600 . He would masturbate during the massage and upon his climaxing, the massage would end. The girls were then paid two or three hundred dollars for the massage. On November 21, 2005 I interviewed Jose Alessi, a former houseman for Jeffrey Epstein. Alessi stated he was employed for eleven years with Mr. Epstein, from approximately 1993 through 2004. Alessi stated he was the house manager, driver and house maintenance person. It was his responsibility to prepare the house for Epstein s arrival. When asked about cooks or assistants, Alessi stated they traveled with Epstein on his private plane. I asked Mr. Alessi about the massages that have occurred at Epstein's home. Alessi stated Epstein receives three massages a day. Each masseuse that visited the house was different. Alessi stated that towards the end of his employment, the masseuses were younger and younger. When asked how young, Mr. Alessi stated they appeared to be sixteen or seventeen years of age at the most. The massages would occur in Epstein's bedroom or bathroom. He knew this because he often set up the massage tables. I asked if there were things going on other than a massage. Alessi stated that there were times towards the end of his employment that he would have to wash off a massager/vibrator and a long rubber penis, which were in the sink after the massage. Additionally, he stated the bed would almost always have to be made after the massage. On January 4, 2006 I interviewed another former houseman, Mr Alfredo Rodriguez. During a sworn taped statement, Mr. Rodriguez stated he was employed by Jeffrey Epstein for approximately six months, from November 2004 through May of 2005. His responsibilities as house manager included being the butler, chauffeur, chef, houseman, run errands for Epstein and provide for Epstein's guests. I asked Rodriguez about masseuses coming to the house. Rodriguez stated Epstein would have two massages a day. Epstein would have one massage in the morning and one massage in the afternoon everyday he was in residence. Rodriguez stated he would be informed to expect someone and make them comfortable until either or Epstein would meet with them. Rodriguez stated once the masseuses would arrive, he would allow them entry into the kitchen area and offer them something to drink or eat. They would then be encountered by either or Epstein. They would be taken upstairs to provide the massage. I asked Rodriguez if any of the masseuses appeared young in age. Rodriguez stated the girls that would come appeared to be too young to be masseuses. He stated one time under Epstein's direction, he delivered a dozen roses to Royal Palm Beach High School for one of the girls that came to provide a massage. He knew the girls were still in high school and were of high school age. I asked Rodriguez about the massages. He felt there was a lot more going on than just massages. He would often clean Mr. Epstein's bedroom after the alleged massages and would discover massagers/vibrators and sex toys scattered on the floor. He also said he would wipe down the vibrators and sex toys and put them away in an armoire. He described the armoire as a small wood armoire which was on the wall close to Epstein's The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Coun net , who is personally known to me. State of Florida Signature of Police Office (F.S.S. 117.10) Signature/ g Officer Date: 05/01 06 Page2fof 22 EFTA00230919 Probable Cause Affidavit Palm Beach Police Department Agency ORD FLO 500600 bed. On one occasion EEtein ordered Rodriguez to go to the Dollar rent a car and rent a car for the same girl he brought the roses to, that she could drive her self to Epstein's house without incident. Rodriguez said the girl always needed rides to and from the house. Rodriguez produced a green folder which contained documents, and a note with Mr. Epstein's stationary with direction to deliver a bucket of roses to Royal Palm Beach High School after IE high school drama performance. Also in that same note was direction to rent a car for El and direction to extend the rental contract. During the course of the investigation, subpoenas were obtained for cell hone and home phone records from several victims and witnesses along with the cell phone records of . An anal sis of these records was conducted which found numerous telephone calls were made between and the victims. These records indicate the dates the calls were made are consistent with the dates and times they victims/witnesses stated they were contacted. Specificall , The phone records showed called during the exact times and dates when victim advised the incident occurred. also coordinated the encounters with E, E, and during the time frame the girls stated they occurred. Pursuant to a lawful subpoena I obtained Epstein's private plane records for 2005 from Jet Aviation. The plane records show arrival and departure of Epstein's lane at Palm Beach International airport. These records were cors.ars.d to the cell phone records of This comparison found that all the phone calls made to and the victims were made in the days just prior to their arrival or during the time Epstein was in Palm Beach. Jeffrey E stein, who at the time of these incidents was fifty one years of age, did have vaginal intercourse either or digitally with E, E and , who were minors at the time this occurred, and who at the time of the incident was fifty two ears of age, did use a vibrator on the external vaginal area of E, a fourteen year old minor. Therefore, as coordinated and aided in the recruitment of minors to frequent Epstein's house so that sexual services were provided to Epstein, scheduled the said minors to return to the work for Epstein, secured their appointments for the purpose of sexual activity and lewd and lascivious acts and arranged the bedroom for said minors, there is sufficient probable cause to charge with four counts of Principal in the 1" degree Unlawful Sexual Activity with a Minor, in violation of Florida State Statute 794.05(1) , a second degree felony and there is sufficient probable cause to charge her with Lewd and Lascivious Molestation, in violation of Florida State Statute 800.04 (5), a second degree felony. The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Coun Det , who is personally known to me. State of Florida Signa Signature of Poli e Offic (F.S.S. 117.10) Date: 05/0 g Officer Page2zof 22 EFTA00230920 1 ltr :01L EFTA00230921 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 1 Program: CMS301L Case No SPECIAL NOTES : Occur To Date : Day Of Week . : Common/Location: City • Location Type : Beat Assignment: DETECTIVE BUREAU Map Reference Dept Class . . : SEXUAL BATTERY Report Officer Case Status . ACTIVE Case Status Dt : 3 14 05 Supervisory Dt.: Jill. 3/14/05 Entry Date . . : OREGERO, 4/06/05 Names" • Property? . . Vehicles? . . : Offenses? . . Narrative? . . : Related Cases? ********* IEHI C L E I N F ORMATION # 1 ********************* Case number . : 1-05-000368 Category . . . : State Veh Type : Year • 0 Make Model Model Name . . : Permit Number Style • Color - Top Color - Bottom : License # . VIN Stolen value • : 0 Disposition Insured . . Insured by . . : Keys in car Vehicle locked : Lein holder . Date recovered : 0/00/00 Recovery value : 0 Street number : City Recovery code : NCIC number . : Be On Look Out?: 1-05-000368 DO NOT RELEASE 1/27/05 0000 Thursday 358 EL BRILLO WY PALM BEACH, FL RESIDENCE-SINGLE FAMILY Occur From Date: 1/27/05 0000 Report Date . : 3/14/05 1600 ********* PERSON REPORT Case Number . Street Number City BEACH, FL Birth Date/Age : 24 Occupation . . Home Phone No. Sex • Female Weight • 0 ************** SUSPECT/ARRE Case Number . Street_Number Oper Lic No. . : Race Height • Other Phone Nbr: STEE IN F 0 Prompt valid in: City Birth Date . BEACH, 18 FL Maximum Age . : Employer? . Occupation . . : Oper Lic No. . FL Home Phone No. : Other Phone Nbr: Sex • Female Race Minimum Height • : Minimum Weight : 0 Maximum Height : I N G I N F O - ********* Last Name . . : Employer? . White 0 18 White 0 0 FL # 1 * * EFTA00230922 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 2 Incident Report Program: CMS301L Case No Maximum Weight : Aliases' Hair Color . . : Hair Style . . : Glasses . . . : Facial Hair . : Teeth Hat Shirt Shoes Body Marks #2 : Body Marks #4 : Arrest Case No.: ************** S Case Number . : Street Number : City • Birth Date . . : Employer? . . : Oper Lic No. . : HA Other Phone Nbr: 561 000-0000 Sex Female Minimum Weight : 0 Maximum Weight : 0 Aliases' Hair Color . Hair Style . Glasses . . Facial Hair • Teeth • Hat • Shirt • Shoes Body Marks #2 : Body Marks #4 : Arrest Case No.: (Continued) Misc. ID# . . MO/Crime Spec? : Hair Length Eye Color . : Complexion Build Speech Coat Pants Body Marks Body Marks Status Additional UCR?: /ARRESTEE IN Prompt valid ************** S Case Number . : Street Number : City Birth Date . . : Employer? . . Oper • Other Phone Nbr: Sex Minimum Weight : Maximum Weight : Aliases' Hair Color . . Hair Style . . 1-05-000368 0 USPECT 1-05-000368 358 EL BRILLO WY H, FL 000033480 25 Maximum Age Occupation . . Home Phone No Race Minimum Height Maximum Height Misc. ID# MO/Crime Spec? Hair Length Eye Color Complexion Build Speech Coat Pants Body Marks #1 : Body Marks #3 : Status STILL SUSPECT Additional UCR?: #1 : #3 : • STILL SUSPECT • • inF O illilili* 25 PERSONAL ASST/EPSTEIN 561/000-0000 White 0 0 USPECT/ARRESTEE INFORMATION- # 3 ** 1-05-000368 Prompt valid in: EPSTEIN, JEFFREY 358 EL BRILLO WY PALM BEACH, FL 000033480 1/20/1953 52 Maximum Age : 52 Occupation . . : FL Home Phone No Race White Male Minimum Height : 0 0 Maximum Height : 0 0 Misc. ID# . . MO/Crime Spec? : Hair Length . Eye Color . . : EFTA00230923 Date: 7/25/06 Time: 8:47:53 Incident Report PALM BEACH POLICE DEPARTMENT Page: 3 Program: CMS301L Case No Glasses . . . : Facial Hair . Teeth Hat Shirt Shoes Body Marks #2 : Body Marks #4 : Arrest Case No.: ************** Case Number . : Prompt valid in: Street Number : City Birth Date/Age : Occupation . . : Home Phone No. : Sex • Weight Be On Look Out?: Victim Type . Residency Sts Can Identify . Injury Extent Injury Type 2 Med Treatment Phys Last Name ************** V Case Number . : Street Number : City Birth Date/Age : Occupation . . Home Phone No. : Sex Weight Be On Look Out?: Victim Type . : Residency Sts : Can Identify . : Injury Extent : Injury Type 2 : Med Treatment : Phys Last Name : ************** • 1-05-000368 ICTI FL Complexion Build Speech Coat Pants Body Marks #1 : Body Marks #3 : Status Additional UCR?: (Continued) STILL SUSPECT M INFORMATION - #1******************** 6 WEST PALM BEACH, 5/13/1990 14 Female 0 JUVENILE ICTIM 1-05-000368 18 FL 561/000-0000 Female 0 ADULT VICTIM Case Number . : 1-05-000368 Street Number : City H, FL 000033480 Birth Date/Age : 16 • Employer? Employer? . Oper Lic No. Race Height Misc. ID# . . : Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: White 0 INFORMATION -# Prompt valid in: 000033480 Employer? . . Oper Lic No. Race White Height 0 Misc. ID# . . Other Phone Nbr: 561/000-0000 Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: ******************** INFORMATION -# ******************** Prompt valid in: EFTA00230924 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 4 Incident Report Program: CMS301L Case No 1-05-000368 Occupation Home Phone No. : 561/000-0000 Sex Female Weight 0 Be On Look Out?: Victim Type . : JUVENILE Residency Sts : Can Identify . Injury Extent Injury Type 2 : Med Treatment : Phys Last Name : ************** Case Number Street Number City Birth Date/Age : Occupation . . Home Phone No. : Sex Weight Be On Look Out?: Victim Type . : Residency Sts : Can Identify . : Injury Extent : Injury Type 2 : Med Treatment : Phys Last Name : ************** Case Number . : Street Number : City • Birth Date/Age : Occupation . . : Home Phone No. : Sex • Weight Be On Look Out?: Victim Type . : Residency Sts : Can Identify . : Injury Extent Injury Type 2 : Med Treatment : Phys Last Name : VICTIM : 1-05-000368 17 FL 561/000-0000 Female 0 JUVENILE ICTIM 1-05-000368 (Continued) Oper Lic No. . : Race • White Height 0 Misc. ID# . . Other Phone Nbr: 561/000-0000 Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: INFORMATION PALM BEACH, FL 9/21/1986 18 561/000-0000 Female 0 ADULT ************** V I C T I M Case Number . : - - 68 Prompt valid in: - # 4 ******************** Prompt valid in: 000033480 Employer? . . : Oper Lic No. Race White Height 0 Misc. ID# . . Other Phone Nbr: 561/000-0000 Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: INFORMATION - Prompt valid in: 000033480 # ******************** Employer? Oper Lic No. . : Race White Height 0 Misc. ID# . Other Phone Nbr: 561/000-0000 Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: INFORMATION -# 6******************** EFTA00230925 Date: 7/25/06 Time: 8:47:53 Case No Street Number City • : PALM BEACH POLICE DEPARTMENT Incident Report 1-05-000368 PALM BEACH, FL 000033480 Page: 5 Program: CMS301L (Continued) Birth Date/Age : 7/28/1988 16 Employer? . Occupation . . Oper Lic No. Home Phone No. : 561/000-0000 Race White Sex Female Height 0 Weight 0 Misc. ID# . Be On Look Out?: Other Phone Nbr: 561/000-0000 Victim Type . : JUVENILE Residency Type : Residency Sts : File Charges . : Can Identify . Victim Sobriety: Injury Extent : Injury Type 1 : Injury Type 2 : Hospital ID . : Med Treatment : Phys First Name: Phys Last Name : ************** Case Number . Street Number City • Birth Date/Age : Occupation . . : Home Phone No. : Sex Weight Be On Look Out?: Victim Type . Residency Sts Can Identify . Injury Extent Injury Type 2 Med Treatment Phys Last Name ************** Case Number . Street Number : City PALM BEACH, FL Birth Date/Age : 2/29/1988 16 Occupation . . Home Phone No. : 561/000-0000 Sex Female Weight 0 Be On Look Out?: Victim Type . : JUVENILE Residency Type : Residency Sts : File Charges . : Can Identify . : Victim Sobriety: Injury Extent : Injury Type 1 : Injury Type 2 : Hospital ID . : Med Treatment : Phys First Name: Phys Last Name : IICTIM : 1-05-000368 17 FL 561/000-0000 Female 0 JUVENILE INFORMATION - #Z******************** IICTIM 1-05-000368 Prompt valid 000033480 INFO Employer? . Oper Lic No. Race Height Misc. ID# . . : Other Phone Nbr: 561/000-0000 Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: in: White 0 RMAT Prompt 000033480 I O N - # ******************** valid in: Employer? Oper Lic No. Race • White Height 0 Misc. ID# . . Other Phone Nbr: 561/000-0000 **************VICTIM INFORMATION -# 9******************** EFTA00230926 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 6 Incident Report Program: CMS301L Case No Case Number . : Street Number : City • Birth Date/Age : Occupation . . : Home Phone No. : Sex • Weight Be On Look Out?: Victim Type . : Residency Sts : Can Identify . : Injury Extent : Injury Type 2 : Med Treatment : Phys Last Name : ************** Case Number . : Prompt valid in: Street Number : City • Birth Date/Age : Occupation . . : Home Phone No. : Sex • Weight Be On Look Out?: Victim Type . : Residency Sts : Can Identify . : Injury Extent Injury Type 2 : Med Treatment : Phys Last Name : ************** Case Number . Street Number City Birth Date/Age Occupation . . Home Phone No Sex Weight Be On Look Out?: Victim Type . : ADULT Residency Sts : Can Identify . : Injury Extent : Injury Type 2 : Med Treatment : 1-05-000368 1-05-000368 PALM BEACH, FL 6/06/1987 17 561/000-0000 Female 0 JUVENILE Prompt valid in: 000033480 Employer? Oper Lic No. . Race White Height 0 Misc. ID# . . : Other Phone Nbr: 561/000-0000 Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: ICTIM INFORMATION PALM BEACH, FL 6/18/1987 17 561/000-0000 Female 0 JUVENILE VICTIM : 1-05-000368 • PALM BEACH, FL : 8/09/1986 18 : 561/000-0000 • Female • 0 000033480 Employer? . Oper Lic No. Race White Height 0 Misc. ID# . . Other Phone Nbr: 561/000-0000 Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: - # 10 ******************* INFORMATION - # 11 ******************* Prompt valid in: 000033480 Employer? . . Oper Lic No. . Race • White Height 0 Misc. ID# . -Other -Phone Nbr: 5611000-0000 Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: EFTA00230927 Date: 7/25/06 Time: 8:47:53 Incident Report PALM BEACH POLICE DEPARTMENT Page: 7 Program: CMS301L Case No Phys Last Name : ************** V Case Number . : Street Number : City PALM BEACH, FL Birth Date/Age : 6/01/1986 18 Occupation . . Home Phone No. : 561/000-0000 Sex Female Weight 0 Be On Look Out?: Victim Type . Residency Sts Can Identify . Injury Extent Injury Type 2 Med Treatment Phys Last Name 1-05-000368 ************** Case Number . : 1-05-000368 Street Number : City Birth Date/Age : 16 FL Occupation . . : Home Phone No. : 561/000-0000 Sex Female Weight 0 Be On Look Out?: Victim Type . Residency Sts Can Identify . Injury Extent Injury Type 2 Med Treatment Phys Last Name ICTIM 1-05-000368 : ADULT VICTIM (Continued) INFORMATION -# 12 ******************* Prompt valid in: ************** Case Number . : Street Number : City • Birth Date/Age : Occupation . . Home Phone No. : Sex • Female Weight • 0 Be On Look Out?: Victim Type . : JUVENILE Residency Sts : Can Identify . : Injury Extent : JUVENILE ICTIM 1-05-000368 000033480 Employer? . . : Oper Lic No. . : Race Height Misc. ID# . . : Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: White 0 561/000-0000 INFORMATION -# ******************* Prompt valid in: 000033480 Employer? . . Oper Lic No. Race Height Misc. ID# . : Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: White 0 561/000-0000 INFORMATION -# ******************* Prompt valid in: H, FL 000033480 16 Employer? Oper Lic No. 561/000-0000 Race • White Height • -0-- Misc. ID# . . : Other Phone Nbr: 561/000-0000 Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : . : . : EFTA00230928 Date: 7/25/06 Time: 8:47:53 Incident Report PALM BEACH POLICE DEPARTMENT Page: 8 Program: CMS301L Case No • 1-05-000368 Injury Type 2 : Med Treatment : Phys Last Name : ************** V Case Number . : Street Number : City Birth Date/Age : Occupation . . Home Phone No. : Sex Weight Be On Look Out?: Victim Type . : Residency Sts : Can Identify . : Injury Extent : Injury Type 2 : Med Treatment : Phys Last Name : ************** Case Number . : Street Number : City Birth Date/Age : Occupation . . : Home Phone No. : Sex Weight Be On Look Out?: Victim Type . : JUVENILE Residency Type : Residency Sts File Charges . : Can Identify . : Victim Sobriety: Injury Extent : Injury Type 1 : Injury Type 2 : Hospital ID . : Med Treatment : Phys First Name: Phys Last Name : ************** V ICTIM Case Number . : 1-05-000368 INFORMATION -# Prompt valid in: **************.*** Street Number : City Birth Date/Age : H, 16 FL 000033480 Employer? . Occupatioa . . @per-₹tic NO. Home Phone No. : 561/000-0000 Race White Sex Female Height 0 Weight Be On Look Out?: 0 Misc. ID# . . Other Phone Nbr: 561/000-0000 Victim Type . : JUVENILE Residency Type : Residency Sts : File Charges . : ICTIM 1-05-000368 PALM BEACH, FL 8/24/1985 19 561/000-0000 Female 0 ADULT ICTIM 1-05-000368 (Continued) Hospital ID . : Phys First Name: INFORMATION - # 15 ******************* Prompt valid in: Hi FL 7 561/000-0000 Female 0 000033480 I N Employer? . Oper Lic No. • Race White Height 0 Misc. ID# . Other Phone Nbr: 561/000-0000 Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: FORMATION - # *************S**** Prompt valid in: 000033480 Employer? . Oper Lic No. Race Height Misc. ID# . Other Phone Nbr: White 0 561/000-0000 EFTA00230929 Date: 7/25/06 Time: 8:47:53 Incident Report PALM BEACH POLICE DEPARTMENT Page: 9 Program: CMS301L Case No • 1-05-000368 Can Identify . : Injury Extent : Injury Type 2 : Med Treatment : Phys Last Name : *********OTHER PERS Case Number . : Street Number : City Birth Date/Age : Occupation . . : Home Phone No. : Sex • Weight Other Phone Nbr: ********* O Case Number . : Street Number : City Birth Date/Age : Occupation . . : Home Phone No. : Sex Female Weight 0 Other Phone Nbr: T H ********* Case Number . : Street Number City Birth Date/Age : 35 • M BEACH, FL Occupation . . : Home Phone No. : Sex Weight Other Phone Nbr: OTHER (Continued) Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: O N I N F O R M A T - ********* Last Name BEACH, FL 14 MI= Female 0 E R PERSON 1-05-000368 358 EL BRILLO WY Employer? . . : Oper Lic No. : Race • Height • Person Type . : White 0 OTHER PERSON INFORMAT - ********* Last Name . . : H, FL 000033480 19 Employer? . • Oper Lic No. : Race White Height 510 Person Type : OTHER PERSON PERSON ********* Female OTHER PERSON Case Number . : Street Number : City Birth Date/Age : Occupation . . : Home PhOh - NO7 Sex • Weight • Other Phone Nbr: Last Name FL I N F O R M A Last Name Employer? . . T : - ********* Oper Lic No. . : Race Height Person Type • • : White 0 OTHER PERSON BEACH, FL Employer? . . : Oper Lic No. : ice Height Person Type • • . : White 0 OTHER PERSON 37 PAINTER Male 0 *********OTHER PERSON Case Number . : 1-05-000368 INFORMAT IiiiiNIIIII5********* Last Name . . EFTA00230930 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 10 Incident Report Program: CMS301L Case No • 1-05-000368 Street Number : City Birth Date/Age Occupation . . Home Phone No Sex Weight Other Phone Nbr: Case Number . Employer Name Address . . . City/State/zip Phone Number . * ***** * * * O T H Case Number . : Street Number : City Birth Date/Age : Occupation . : Home Phone No. : Sex Weight Other Phone Nbr: 0/00/0000 0 Employer? . FAMILY THERAPIST Oper Lic No. 561/000-0000 Race • White Female Height • 0 0 Person Type . : OTHER PERSON 561/000-0000 (Continued) ***EMPLOYER INFORMATION*** 1-05-000368 PBC DIVISON OF YOUTH AFFAIRS 4200 N AUSTRALIAN AV ACH, FL 33407 E R PERS NI FL 6 Male 0 Case Number . : 1-05- Address . . . : 4900 City/State/Zip : WEST Phone Number . : . : . : O N I N F O R M A T - ********* Last Name . . : Employer? . Oper Lic No. Race • White Height • 0 Person Type : OTHER PERSON ***EMPLOYER INFORMATION*** 000368 Employer Name SUMMIT BV PALM BEACH, FL 33415 SCHOOL ********* OTHER PERSON INFORMAT - ***1***** Case Number . : Street Number : Last Name . . City Birth Date/Age : WEST PALM BEACH, 0/00/0000 0 FL Employer? . . : Occupation . . Oper Lic No. . : Home Phone No. : Sex • Weight • Other Phone Nbr: Male 0 Race Height Person Type • • : White 0 OTHER PERSON *********OTHER PERSON -Cfae Dumber . : - - Last Name . . : Street Number : City • Birth Date/Age : WEST PALM BEACH, 0/00/0000 0 FL Employer? . . : Occupation . . Oper Lic No. . : Home Phone No. Sex • Female Race Height • 0 EFTA00230931 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 11 Incident Report Program: CMS301L Case No • 1-05-000368 Weight • 0 Other Phone Nbr: (Continued) Person Type . : OTHER PERSON ********* OTHER P E R S O N INFORMAT ********* Case Number . : - - Last Name Street Number : 39 City Birth Date/Age : BEACH, FL 33417 16 Occupation . . : Home Phone No. : Sex Weight Other Phone Nbr: Employer? Oper Lic No. 561/000-0000 Race • White Female Height • 0 0 Person Type . : OTHER PERSON 561/000-0000 . : . : FL **************************** N A R R A *************************** Original Report LO Reported By: D. 9/20/05 Entered By.: D. 9/20/05 On 03/14/2005, I received a call from d not wish to identify herself (later identified as ). She still fourteen year old step daughter (later identified as possibly been molested in Palm Beach by a wealthy man. According to , she learned of the possible molestation ) by a third party. She explained that she had received a call from the mother of her stepdaughter's friend. The mother claimed to have overheard a conversation between her daughter and a male nd; they were talking about IIII. The conversation was about how had met with a 4 - - ld man and had sex with him and was paid for it. I advised that I would l eet with her to obtain a more detailed statement iiili and facts. stated she did not know what d had to discuss the matter with her husband. At this point did not provide me with a call back number or any other information. She sta iiiat she would contact me once she had spoken with her husband and mother. On 03/14/2005 received a call from Mr. & Mrs They slid r right to spill Her mother • daughter via cell phone had been made aware of the case. o meet me at the police department later this date. /2005, Mr. accompanied by his wife came to the Palm Beach Police Department where they advised me that they believed their fourteen year old daughter may have had some type of sexual relationship with an older male who resided in Palm Beaar. Neither knew the suspeuL'b dame or addiebs. —Both—stated that their daughter did not talk to them about the incident, nor would she admit to it. .tified ilehis s idaughter.as er at , RPB, . is a twin, EFTA00230932 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 12 Program: CMS301L Case No -000368 her sister resides with Mr. currently attending High Ridge vocational involuntary admitted juvenile educational (21alinued) Both IIIII and IIII are school, whi s an facility. stays at the SS during the week and comes home on the weekend. According to , she was admitted to the school because of disciplinary problems that recently escalated. The facility also coordinates with the families to provide one on one as well as family counseling. According to Mrs. , she be the inc' occurred on Sunday, Feb 6, 2005. A riend of named picked her up at their house and left. They believe initiate the relati • with the older gentleman, though they save any proof. s close by with her further explained t at was , a boy dating goes to . Mrs. IIIIIIII continued that on Sunday, picke. up , and drove to Palm Beach where they met the man. Supposedly, t e man h of of money and often has young girls come over to his house. offers these girls a way to make fast cash. The man starts wit a If he likes them, he keeps the d and does more. The anv information on other than she lives on has ). talked of a r that she had with , the mother of , a former friend of . She found it strange that they were no longer friends until she received the calli i her mother telling her of the conversation she overheard between and a boy named Zach. told me of an incident that occurred on 02/09/2005. IIII got into a fight at school (iiiil Palm HS). Principal, found over $300.00 in s purse. Ili's. Brown Assistant gave different explanations for the large sum of money. Initially the school administration thought iLagas drug related but then dismissed the claim. Since that day, IIII did not return to school; she ran away Thursday, 02/10th or Friday 02/11 and returned to her mot use later that night after ' ' . It was t' call from lia r' fight with at she learned was the giiii t got int e The fight was instigated when accused of being a prostitute. , who has legal joint custody of his daughter , signed the affidavit of prosecution indicating he wished to prosecute against the inappropriate sexual behavior with his --fourteen-year old daughter. Mr. state at he had no objections wi gency speaking is daug about the incident. Mr. stated that mother is aware of egations and also was willing to cooperate. According to Mrs. , she does not believe her daughter had any additional contact with the suspect as she was with EFTA00230933 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 13 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) her mother and then placed into High Ridge. I contacted the School Board Police who provided me the information for Sable Palm, also known as High Ridge Family Center 844 - 4540. 4200 N Australian Avenue,gagt Palii cill da. Checking the school board records for and , there was no disciplinary record found. I was advised if no disciplinary action was taken for a fight, such as an expulsion or detention, the incident may not have been recorded. This was at the discretion of the individual school security and principal. 03/15/2005, I called t message for PBSP Sgt. On 03/1 0 female therapist. During an about the allegations anything had identify owed. tified boyfriend . She ultimately worked for a wealth and possibly also admitted that had offered money. ach County Sheriff's Office and left a , Child Abuse Unit. to High Ridge/Sabl re ' h white Also present was audiotaped interv'mmmm.mmirffle with that were made. initially denied y admitting to going with IIIII ( ch to pick up money was as the cousin of her o admitted to knowing that ffs., did sexual favors for him. She her an opportunity to make identified boss as a white male named "Jeff" who ' Palm Beach (later positively identified as y Epstein). explained that she was first a ed by to go with eff's house, when they were at house. Acc to she was not su ac as going on with but agreed to th her. he heard inviting to boyfriend) angry when any eyed it was to pick told her that wassise to picked her up up money the man owed stated she would pick her up at her house on Sunday. exact dates but knew it was a Sunday. According along with an unkno ' ly ' 'c female, at her father's house on . told her y were shopping. It was ater confirmed by that picked his daughter up. According to Mr drove a pick up truck. drove on the w whereby (IIIIIIII) ager, she along with the unknown female to a conversation occurred between and told that if Jeff asked her should say she was eighteen. recalled that Jeff's house was on a dead end street. All three girls walked up a drivewa guard/security room. In fact, them asking what they wanted. Jeff. The male allowed them to what appeared to be a small recalled a male approaching stated they were there to see continue walking up to the house. EFTA00230934 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 14 Time: 8:47:53 Incident Report Program: CMS301L Case . : 1-05-000368 (Continued) stated the man told them that Epstein was not there but was expected back. He allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside. Shortly after, Epstei oman, described as white with blond hair entered hen. ill lilf believed the woman was Epstein's Assistant. • added that the woman did not seem friendly and kep response and direct. Epstein introduced himse as Jeff . g 'mpression that Epstein and friend knew each other. described Epstein as being approximately forty-five years old, a long face, and bushy eyebrows, with graying hair. and Epstein left the kitchen leaving and _Mhile_s friend alone in the kitchen. They returned a short time They all spoke briefly in the kitchen. peaking to me, became upset and started to cry. IIIIIIII stated the womaa.lagLLucted her to follow her upstairs, which she did. According to IIIIIIII, the woman led her to a room that had a massage table in it. The woman started to fix up the room, the covers on the table and taking lotions out. She then told that Epstein would be up in a second. left the room, and soon afteill in walked in and told to take off her clothes. As was telling me what had happened, she looked away from with a pointed finger, repeatedly pressed it into her thigh. when he told her to take off her clothes. know what to do as she was the only one there. shirt leaving her bra take off everything. her thong panties on. massage pointing to a the table, face down. he told her to get o ted he was stern she did not took off her iiiiiiiitein, dressed in a towel told her to stated she removed her pants leaving Epstein then instructed her to give him a spec' • ion for her to use. Epstein laid on As to give Epstein the massage, giving Epstein the massage, later explained that wacking off was masturbating). stated she was di y Epstein's actions but did not say anything. According to Ili. Epstein told her that she "had a really hot body." Epstein excused himself and went to the bathroom where she believed he masturbated again. Epstein returned to the room and told that he was done and gave h re hundred dollars. They went back down Ili' where . Epstein said good-bye and theyef When told asked how did it go and asked what did she t ein asked for a massage, y stated ow." stated they then went shopping. stated also giii d, but that she did not know why since she was confident that did not do anything. described Epstein's house as a two story pink house with a Cadillac Escalade parked in the drivew re were gates leading into the property. From the kitchen, recalled walking up a flight of stairs, lined with photographs, to a room. Upon entering EFTA00230935 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 15 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) the room there was a large bathroom to the right. recalled a hot pink an sofa in the room. There was a door on each side of the sofa. recalled there being a mural of a naked woman in the room, as well as several photographs of naked women on a shelf. stated Epstein did not eh • front of her but did take off his towel, exposing himself. recalled Epstein being hairy especially on his ches ein also had a hairline that contin is buttocks. admitted to seeing his penis. I asked if she knew what being circumcised meant and she stated no. then said that she thought Epstein was on steroids he was a "really built guy and his wee wee was very tiny." illillil would explain that when she stated "wee wee" she meant penis. stated Epstein exposed himself when he took his towel off, placing it on the floor as he laid down on the table. said Epstein was specific in his i ' n to her on how to massage, telling her to go clockwise, etc. recalled that Epstein got up from the table and went to the bathroom where she heard him making, what she believed to be sexual type of noises. (moaning) He then returned to the room where he ag down on the table. • rned over and instructed to massage his boobs. , Epstein continued to make moaning noises. resumed massaging his chest area. was now standing on the ground. Epstein turned to his side, and with the to he ground started to rub his penis in an up and down motion. stated Epstein held on to the s er back as she massaged his chest, back and shoulder area. recalled Epstein ejaculating because o use the towel to wipe himself as he got off the table. also recalled Epstein having a noticeable freckle on his chest. Epstein then left the roo downstairs where she met admitted to getting paid three h Before they left, Epstein asked As they were leaving the hou and how much she was paid. us when she told her that stated received onl stated that she believed bringing her. to be rich; sure where never saw not spoken I asked in the room got dressed. She went and the unknown white female. ollars in cash from Epstein. to r phone number. asked what had happened stated seemed upset or she received three hundred hundred dollars that day. . was paid two hundred dollars for that if they do this every Saturday, they could agreed. They then went shoppiagsmIL2agh she is not ably at TJ Maxx or Marshall's. I'll'''. stated she .Agala as she got into a fight at school. She had with IIIIII either as her mother took away her cell phone. if she was aware of any video equipment while she was . She stated no. EFTA00230936 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 16 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) stated she was afraid amily if she ever went stated that her fatha admitted to According to in the wall. that would retaliate against her to the police regarding the incident. ' vehicle was recently vandalized. what had happened with Epstein. became angry a set, punching guessed that it was who told about the incident, and now there were rumors in school about and what she did with Epstein. I then talked to about d lying. We talked about the color sweater she was wearing. denied having with Epstein. She denied touching his penis. sexual again admitted to observing Epstein masturbate. agree ooperating with the police department in placing a phone call to in a controlled setting s. and advised her of the families' as well as Back willingness to cooperate with this investigation. Copies of this interview were placed into evidence. I made contact with , mother of advised her briefly of my investigation. She was aware of incident and stated that she overheard a porti that her daughter was having with a boy named that it was her opinion that both girl recalled hearing her daughter calling a whore. admitted that she did not listen to the entire conversation but did confront her daughter about i somethinii ieffect that money. statue her daughter. It was , I the tion stated told her mother that had slept with an older man for he would not object to me speaking with s belief that everyone in the school Ste kn t this because of the fight t i iiiughter and had gotten into. I reminded that this was an ongoing investigation and requested she not discuss the fact that I had contacted her. She agreed. On 03/16/2005, PBSO Sgt. eft a message that he was returning my call. I spoke with and discussed the case with him and inquired if he had alig2pen allegations or cases where t uspect resided in Palm Beach. III. state was unaware of any. offered any assistance if needed. stated it was his experience that due to the age of the parties involved, it would be difficult to interview them and expect the investigation to remain confidential. Because of the time delay, there was no need for the victim to be taken to a medical facility for a physical for the purpose of obtaining evidence. There was also no need to take her to CPT as she was already in a juvenile facility, with an assigned therapist, in which coordinating a day and time to obtain a statement could be made. On 03/17/2005, I queried Jeffery Epstein on the internet and obtained EFTA00230937 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 17 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Cowed) of Epstein to be used in a photo line up. I met with at which time she viewed the photo line up. allajamgdiately recognized Epstein and pointed to him (Position #5). IIIIIIII signed the photo line up under Epstein's picture. This signed line up was placed into evidence. On 03/18/2005, I met with placing a controlled call to and asked if she could arrange another meeting with stated that she would have to call him and make the copy of this conversation was placed into evidence. 03/19/20iiiii k and and was uncle. is scheduled to return to Florida on 03/27/2005 advised ettestate to visit with her aunt and for the purp spoke Jeff. arrangements. A 03/21/2005, I coordinated with PB BSF Unit and OCVAN to initiate surveillance on 358 El Brillo. 03/21/2005, Coordinated with Det. III r ' pulls from 358 El Brillo. On this same d I called to schedule an appointment to speak with . She stated t e school guidance counselor was reluctant to ave police presence at the school. I assured her that I would respond to the school in civilian clothes and an unmarked vehicle. called a dvised that I did not need to make an appointment to see ' ed a return phone call from stating would be attending the family t erapy sessions with that I received messages from I conducted a computer query on Epstein. The results of this query indicated the most recent driver's license on file for Epstein was for the state of Florida, which had expired. A cross reference of Epstein s residence, revealed the following affiliated nam 02/21/1985, Mark L. Epstein, w/m dob Maxwell, uk/f, dob 12/25/1961. A computer history. On 03/23/2005, I spoke with requestedliiii she not discuss the daughter as I did ant t told at this times.1LAt and to the fact that IIIII has ecided Palm Beach, , w/f, dob , & Ghislaine N. query for both returned no cell phone wk . I ncident with anyone including her investigation compromised. I was have not been getting along due to continue living with her father. /2005, I placed telephone calls to both the residences requesting to speak with them regarding and the EFTA00230938 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 18 Program: CMS301L Case No 1-05-000368 (Continued) inves . I received return phone calls from Mrs. and advised them that I would be contacting family therapist to coordinate a t eet wi This was at the request of both Back and Mrs. that strict classroom and therapy schedule be disrupted as little a le. I ated them to the investigation thus far. Both and stated th o objection to my meeting with In Ms. , she identified thel l umber of asbeing the phone assigned to . Ms. had no objections and provided consent to giving it to the polic ment for the use of placing controlled phon lls from it. stated the phone had been taken away from as part uniiiient for not doing well in school. According to , used to be an excellent student, but in the past two months has 'rritable, verbally abusive to the family and has run away. stated her daug ecent behavior is the opposite of what she normally is. stated they are going ' through family therapy sessions with the school buL.algaa. of this had come up. Arrangements were made for Det. Captain IIIIII to retrieve the cell phone from at her place of employment. I called High Ridge Family Center, and requested to speak with Ms. Back. Upon speaking with Ms. Back she advised me that she was in the middle of therapy sessions and would call me back once the sessions were completed. Ms. Back stated the sessions should be concluded by 7:00 PM. At approximately 8:00PM I had called Ms. Back at which time I left a message voice mail requesting a return phone call. I spoke with Ms. and advised her that I did not meet with her daughter aug that I would againALLempt to coordinate a h the counselor II as not to disrupt IIII s school sc had no objections. Shortly after speaking with Ms. gg illl. I explained the si tion and requested a ti to meet with Back reviewed s schedule and I received a call from Ms. Bac advised that IIII would be available after 3:00PM. On 03/30/2005, I met with and at High Family Center. I d of her conversation with During this time initiated a conversation with me in which she admitted that she was not telling me everything that h ed during the time she was alone with Epstein. According to was no penetration as the if Epstein ever stated she told whyschool she was in, grade at Wellington. During stated Epstein told her that Epstein used there . I asked her age and she stated he had. was eighteen. When Epstein asked responded she was in the WWI ourse of this incident, had worked for him for years. We then continued wit trolled call to At imately 3- er cell phone, li l a call to s home, was not home. was told EFTA00230939 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 19 Incident Report Program: CMS301L Case No. . that cell phone, Olive Garden and she had heard rumors th asked if they, meaning claimed to Jeffrey. told know anything about Epstein. someone to work tomorrow and asked if she wa ble. stated she would call Epstein and then call back. During the course of these conversations with she would at times appear to be articulate and well spoken. She would then start to act in an immature mann attention, drawing on a paper. whenever she claimed to have to afternoon at Epstein's house. would sit in the chair, with her knees propped up to her chest as she admitted that she did not tell me the all the details of her encounter with Epstein during our eting. As a means of positive reinforcement I would high five On 03/31/2005, subpoena aisgS - 0: D T-MQ]ailtWirelida and Cingular Wireless, (111111 and phone numbers) were drafted. Restaurant, -000368 (Continued) orking a could be reached on her . W/F, is employed at The located on Forest Hi is Blvd in Wellington. During d ersation between , what happened, stating that going to press charges. , knew about Jeffery. father had found out about that t parents) did not told that Epiiiiii needed ooking around, not paying would offer me a high five e truth in the details of the On 04/01/2005, I met with members of PB BSF Unit for the purpose of conducting surveillance on 358 El Brillo. Cross-reference supplement On 04/01/2005, I met with Det. of the Palm Beach Police Department who provided me a copy of the concealed weapons permit for Mr. Epstein. It revealed Epstein had a valid permit. There was no current photo attached to the renewal notice. On this same date identification of 358 El Brillo described bywis I queried various different web sites for a possible the purple item retrieved from the trash pull from 'tem was similar in description as the one and used by Epstein. I made contact with Spicygear.com and spoke with the owner John. I emailed a photograph of the item for his opinion. He identified the items as a Jelly Anal Wand of some sort. The item is easily available at sex shops in South Florida. 04/06/2005, I conducted business queries into Epstein utilizing the internet. I located articles relating to financial reports. There was no local history. On 04/01/2005 - 04/03/2005, with the assistance of BSF, there was EFTA00230940 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 20 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) continued surveillance on the property. On 04/04/2005, cop it messages, dated 03/31 and 04/01 f to ale identifying herself as states that she could pick up to take her to Epstein's house for an eleven o clock appointment. A copy of this was placed into evidence. On 04/05/2005, a trash pull was conducted at 358 El Brillo by Det. III IIIII and me. There were several messag.gagLitten on vari forms of papers. There was a message from , indicating 11:00. The following was additional information obtaine r- '- -. from 358 El Brillo: Jean Luc 0 - - -.- - ; a message receipt d She is looking to speak to you .; On 04/06/ I fax ena requests to SA office for E ( , ds. numbers & ). Qam04/06/2005, I called School, , ext III, and spoke with Princ . He confirmed that they had a student by the name of . He requested a written request prior leasing any additional information. On this same e I a requgglim4or student and parent information on IIIII. I advised IIIII that due to this being an open investigation he was not to discuss the matter with anyone. On 04/08/2005, I receive siiiiirom e owing information: , w/m DOB ton, Fl ' . Parents name: , work provided me with trash obtained from 358 El Brillo for 04/06 he following information was retrieved: Jet Aviation itinerary, indicating a departure date of 04/05/2005 at 4:00 PM with an arrival in New York City of 6:15PM. Flight crew captain David Rodgers, co-captain, Larry Visoski, flight engineer orrison. Call sign N908JE; a note stating Bye J. thank you Business , leaves ; Mrs. . There was no trash for 04/08/05. ived the results of a subpoena request from Bellsouth for The results only provided subscriber information. I contacted Alice Grant Investigative Subpoena Compliance Center who stated the request was not complete and the results would be sent to EFTA00230941 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 21 Program: CMS301L Case No • 1-05-000368 me as soon as the query was finished. (Continued) Cross-referencing the names and as well as phone numbers, which were obtained from message notes via trash pulls, I identified the before mentio divid ing ac omeon El Br FL DL and III* DOB are bot above t legal age o consent. On 05/03/2005, I ith and updated her on the investigation. stated that was doing well in the school. Her contact wiiiiihe outside is limited as they do not have access to the phones. comes home on the weekends and she is not allowed to go anywhere alone. On 05/11/2005, I made arrangements to meet with and On Thursday, 05/12/05, I spoke with regarding the case. They will be moving to GA in July 2005. They will be very busy over the next few weeks but would be available via phone. Will coordinate a date to meet to discuss the matter further. During this week I conducted surveillance at Epstein s residence and at the airport, but there was nothing to indicate that Epstein was in town. Due to co " appointments, rescheduled until 06/02/2005, to meet with Ms. I also spoke with and updated her to the investigation. On 06/02/2005, I met with and . Sandborn advised that she could be reached via her cell phone until she is able to provide me with her new contact information. I also received a message from . Attempted call back but the line was busy. June 14, 2005, I received informa n that Epstein's plane was at Jet Aviation. I spoke with Det. regarding surveillance. I called the Olive Garden and asked for advised she was not working today. This would indicate that was still employed there. On 07/07/ I faxed anhnoena requests to SA office for s ph (Phone numbers and . The original subpoena requests only provided subscriber and billing information. On 07/20/2005, conducted a trash pull arranged by Ofc. III. Inside there were misc. papers with phone numbers and names. There were EFTA00230942 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 22 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) misc. female hygiene products in the trash. Based on a prior Auto Track report risible subject residing at the residence is fit the description provided by officers who had conducted surveillance in the area of a female seen entering and leaving the residence. On 07/21/05, I received the Duces Tecum dated 07/18/05, which was clerked by ASO On 07/26/2005, I received the results of Bell South Subpoena. On 08/04/05, I received DHL Express from T mobile with the results of the query. I spoke with who confirmed that was still living out of state. It appeared that all was going well. I left a message for at On 08/08/2005, I received the results of Cingular cell phone subpoena. During the week of 09/08/2005, I checked 358 El Brillo and the Palm Beach International Airport but there was no direct indication that Epstein was in town. On 09/08/2005, I reviewed th otes of this file, as the case will be turned over to Det. On 09/11/2005, while on patrol, I conducted a check at Epstein's residence and found that it still had the hurricane shutters on. On a drive by the Palm Beach International Airport later that afternoon, I did not observe Epstein's plane. On 09/14/2005, I conducted a check at the Palm Beach International Airport but did not see Epstein s plane. On 09/19/2005, I spoke with to keep her updated an find out if there was any change of a•• -s •.•ne n . I was told no. I left a message for at , in order to provide her with Detective s information. **************************** NA NARRA *************************** Reported By: 9/21/05 Entered By.: 9/21/05 On September 19, 2005, I met with Officer and received the information pertaining to this case. Members of the Burglary Strike ad previou en conducting surveillance on both Epstein and Officer assigned to monitor the E ' home and Sgt and Officer were assigned to monitor . Both teams provided a surveillance log that will be placed into the EFTA00230943 NA Reported By: Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 23 Incident Report Program: CMS301L Case No 1-05-000368 attachment file. (Continued) Det. was assigned to relieve Officer at 4:00 pm; he informe me that at approximately 8:00 pm, Epstein had left for the airport and his private jet was sitting on the tarmac. Epstein's private vehicle drove to the jet and unloaded packages into the jet. It appeared that Epstein left the county at this time. Surveillance will continue to determine when Epstein will return. Inv Continues. **************************** N A R R A # ******** ******************* lilt II 9/23/05 Entered By.: 9/23/05 On Friday, September 23, 2005 at approximately 1:45 p.m., I began to copy a tape micro cassette, under case number 05-368 and property number 05-243, tape number 1. I placed the tape in the telex copy-et, series 2 machine and began to go through the copying process. Approximately 1/2 through the tape, the tape wrapped around the spindle and became locked and stretched the tape. I examined it and determined that it was in the best interest to leave it is as a prior copy had been made and turned ov Sergeant . I immediately took the tape to Sergeant and allow to examine it and then obtained the copy from him and Detective and brought the copy of the tape down and made a copy for him based on that. The tape was placed back in the original container and is retained in the evidence bag under the previously mentioned property number of 05-243. It is not advisable to attempt to copy this tape as further damage could result to the recorded material and there is an existing copy anyway. **************************** N A R R A T I V E NA Reported By: Entered By.: ********************** A. 9/26/05 9/26/05 On 3-24-05 at pm, a copy of tape 2 (c • ' - 94) had been made for Det. by Eviden ialist The copy was turned over to Detective iiiiiii . . On Friday, 09-23-05 at approimately 2:15 pm, I was in the process of reproducing audio tapes (micro and standard) to standard size when it wim3--discovered, in the-LagLreview pro hat tape number -a-was and ------- blank. I notified Sgt. IIIII Det. . I was informed that I ry had a prior copy and I could use it to make a master tape. I did and when reviewinii i signing the evidence sheet, I noticed Evidence Specialist had written "#2 is blank." I obtained that copy from Det. and made a new copy on a standard size tape. The new copy was placed in the evidence bag under EFTA00230944 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 24 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) property number 05-294 with the blank tape. ************** ***** ********* NARRA *************************** NA Copies of Reported By: 9/26/05 Entered By.: A. 9/28/05 the tapes that were submitted into evidence were requested. y, trash pulls were started on September 21, 2005. Sgt. made telephone contact with Tony Higgins, Supervisor of the Sanitation Department, and requested that trash be collected at ' House located at 358 El Brillo i ach. Sgt met with Sanitation worker, Jeff and him enter the property at 358 El Brillo. Shortly thereafter, nl iii exited the property and placed t white trash bags in the empty well in t he truck. then drove away where he met with Sgt. who removed the bags from the well and placed them into one large black trash bag. The bag was returned to the Police Station where I was waiting for him. Upon his arrival, we inspected the bags where several notes and papers were found. These notes cont note from names iiiiirls with times. Additionally, there was a and t ey Epiiiii on , which stated,"For a good time call IIIIIII and simgALLL ." Also, there was another telephone number note Also found was a written note, stated, can not come at 7 p.m. tomorrow because of . These items were written on notepads that contain Jeffrey Epstein on the bottom of the notes. These items were placed into evidence for future follow up. I requested subpoenas for subscriberyilQagation.2a.rwhe telephone numbers listed n the m 1111111 and IIIII. The cellular telephones and are both assigned to Cingular Cellular Service. Other notes were found within the trash on Jeffrey Epstelajlag, paper contained telephone numbers. One note had "IIIIII" with written on it. This cellular number gned to Cingular Cellular Service. Another sheet had written which is assigned to Bell South Telecommunications. The subpoenas were picked up and submitted to Cingular and Bell South Telecommunication for subscriber information. On September 22, 2005, I was informed by Sgt. that there would be no trash pick up as it was recycle pick up day. A request for copies of the micro and standard size cassettes were requested from crime scene to familiarize myself with the interviews conducted. On September 23, 2005, the tapes were received and I beg become familiar with the interviews that were conducted. Det. had met wit-h—Trrn—of-ralTrt Beach Sanitation worker, Jeff Williams and o him enter the property of 358 El Brillo. Shortly thereafter, exited the property and placed t white trash bags in the empty well in th of the truck. then drove away where he met with Det. who removed the bags from the well and placed them into one large black trash bag. The bag was returned to the Police Station where I was waiting for him. Upon his arrival, we inspected EFTA00230945 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 25 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) the bags where several notes and papers were found. The notes will be inspected for future use. The items collected were placed into evidence. It became evident that some of the recordings were recorded with background noise and some interference. The calls most the control phone calls from the victim to the suspect I obtained the graphic equalizer and discovered that the calls are able to be legible with the use of the equalizer by lowering the background noise and increasing voice gain. I also learned that a tape was broken during the coping of the tape. I returned the copy of the tape marked Property Number 05-243 to have it recopied to have an original in evidence and a working copy with the file. earching the file, it was discovered that the suspect, cellular cal oenaed incorrectly. The suspect er was and the original request was for I requested the information through Cingular Cellular Service from Febr 005 through the present. The purpose was to have a record of making calls to victim, Jeffrey Epstein and the frequency of calls. The request was submitted to the State Attorney's Office. Investigation Continues.... **************************** N A R R A *************************** NA Reported By: 10/06/05 Entered By.: A. 10/06/05 On or about September 23, 2005 at approximately 0915 hours, I d t Brillo and met with PB Sanitation worker Jeff . had been previously notified to assist in trash pulls at the resi enc frey Epstein, 358 El Brillo, Palm Beach, Florida. I observed enter the driveway of 358 El Brillo and remove several plastic bags of trash and place the contents into the back of an empty sanitation truck. I then followed to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There was a total of 4 white in color plastic bags and each contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. Alli hts of evidentiary value were removed and turned over-to Det. --fog--follow-up. On or about September 26, 2005 at approximately 0900 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jessie Jones. Jones had been previously notified to assist in trash pulls at the residence of Jeffrey Epstein, 358 El Brillo, Palm Beach, Florida. I observed Jones enter the driveway of 358 El Brillo, where no trash was located within the receptacles. I left the area without incident EFTA00230946 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 26 Incident Report Program: CMS301L • Case No • 1-05-02211A.. and notified Det. IIIIIII to that affect. On or about September 27, 2005 at approximately 0915 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jesse Jones. I observed Jones enter the driveway of 358 El Brillo and remove one plastic bag of trash and place it in the back of an empty sanitation truck. (Continued) I then followed Jones to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There was a total of 1 white in color plastic bag which contained correspondence for 358 El Brillo. All ts of evidentiary value were removed and turned over to Det. for follow-up. On or about Monday October 3, 2005 at approximately 0915 hour d to 358 El Br' met with PB Sanitation worker I observed enter the driveway of 358 El Brillo and remove several plastic ags o trash and place the contents into the back of an empty sanitation truck. I then followed to a predetermined location and seized the trash from the truc . The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There was a total of 7 white in color plastic bags with a red tie and 1 black in color bag which contained 2 white in color plastic bags with a red tie. Each of the bags contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. Inside of one of the white in color bags, I located a broken piece of a hard plastic or clear acrylic stick, which was shaped with small ridges. This device is commonly used as a sexual toy which is inserted into the vagina or anus for stimulation. This item, along with all ts of evidentiary value were removed and turned over to Det. for follow-up. On or about Tuesday October 4, 2005 at approximately 0928 hours, I d to 358 El Br' met with PB Sanitation worker Jeff I observed MO enter the driveway of 358 El Brillo and remove several plastic ags o trash and place the contents into the side well of the sanitation truck. This side of the truck is separate from the rear of the truck and does not come into contact with other trash. I then followed to a predetermined location and seized the _trasiiiromthe truck— The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There was a total of 2 white in color plastic bags which were tied at the top. Each of the bags contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. A ments of evidentiary value were removed and turned over to Det. for follow-up. On or about Wednesday October 5, 2005 at approximately 0928 hours, I EFTA00230947 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 27 Incident Report Program: CMS301L Case No 1-05-000368 (continued) d to 358 El Br met with PB Sanitation worker Jeff . I observed enter the driveway of 358 El Brillo and remove several plastic bags of trash and place the contents into the bed of the sanitation truck. I then followed to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department w egan sifting through its contents, with the assistance of Det. There were a total of 2 bags, one of which was white in color and tied in a knot at the top, and the other was a black in color bag, which contained two white in color trash bags along with loose debris. Each of the bags contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. All nts of evidentiary value were removed and turned over to Det. for follow-up. ******** ******* *************NARRA 4 7***********************r*** MI NA Reported By: 10/07/05 Entered By.: A. 10/07/05 I met with Det. and requested further assistance to maintain trash collections at Epstein's residence at 358 El Brillo Road. On iiiiier 3, 2005, at approximately 10:30 am, I was contactca.LiimSgt. to and to the Palm Beach Police Station. Det. IIIIII had observed Epstein riding his bicycle on South County Road. Upon my arrival, I met wit in Town; we interview ho advised, as Epstein was currently as to her involvement with Epstein Wile girls that are brought to his house. As we were to interview in the county, (outside of our jurisdiction), I contacted the State Attorney s Office Investigat' , and made contact with . . . Assistant Supervisor Inv for . I requested assistance to interview as the interview may occur 'n the county. Supervisor assigned I us at the location and interview of Det. had responded to the a vehicle parked in the g Florida Tag of in Loxahatchee. Sgt y. s par an gator to assist f and viewed her vehicle a red Plym ked in the driv d to and awaited the arrival of Investigator . Upon his arrival, he was briefed that should she wish tiiiiiinterviewed within her home he would be needed. However, should agree to return to the ce station for further questioning, he wou edeilliiit. and I knocked on the door and met with . was told that we were investigatilasplaim involving Jeffrey Epstein of El Brillo in Palm Beach. IIIIII was asked if she wanted to accompany us back to the police station for further questioning. She was also told that at the conclusion of the interview she would be returned home. She agreed and wished to change her clothes prior to accompanying us back to the police station. At the conclusion of her changiLg.. clothes, she advised she was ready to go. I thanked Inv. IIIIII and advised she was going to voluntarily return to the police station. EFTA00230948 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 28 Program: CMS301L Case No 1-05-000368 Upon IIIIII s entry in the unmarked Detective vehicle, recorder within the vehicle to record any conversation vehicle. During station, ng at the and is majoring in journalism. (Continued) I placed a tape in the vised Upon our arrival at the police station, was broug interview room in the Detective Bureau. I explained to appreciated her willingness to assist us ang.informed her she desire to leave at any time she may do II. I fur the interview room door is only closed for priv understood. During the taped sworn iew, she came in contact with Epstein. state 17 years of age she was approac a friend Beach Resort in Rivera Beach. was asked if money. the that I that should lained stated she was asked how when she turned in the Canopy she wanted to make She was to would have to provide a massage and should make $200.00. thought about the offer and agreed to meet with Jeffrey. (Unknown last name) and Tony (Unknown last name) picked her up and she was taken to Epstein's house. Upon her arrival at the house, she was introduced to Epstein in the kitchen of the e. She was also introduced to a white female known to her aim , . She was led u irs to the main bedroom known to her as Epstein s bedroom. arranged the massage table and covered the table with a sheet. She b ht out the massage oils and laid them next to the massage bed. then left the room and informed her Jeff would be in a minute. Jeff entered the bedroom wearing only a towe lay on the table onto his stomach an ' ed massage oil for to rub on him. During the massage, stated, He tried opped him. I asked how he triiiiiii touch her. He and she felt uncomfortable. also stated Epstein has a vi rator, which is large and white in color. told Epstein, I'll massage you but I don't want to be touched. stated she performed t sage naked. At the conclusion of the massage, Epstein paid $200.00 for the massage. He explained, I know you re not comforts e, but I'lljugaou if you bring some girls. He told her the younger the better. IIIIII stated she once tried to bring ear-old female and Epstein stated that the female was too was asked how many girls she brought in total to Epstein. , l d t c "mis ra Iliii! and t e victim in t i s case e . I asked whicii i was the youngest. advised the victim was the youngest. stated every girl she brought knew what to expect when they arrived. They were told they would provide a massage, possibly naked, and some touching. I asked her if the victim was aware. She stated every girl she brought knew what to expect. She explained she knew the victim wanted to make money. She approached the victim and explained about going to work for Jeff. The EFTA00230949 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 29 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) victim agreed and arrangements Epstein's house on a ade to bring the victiiiii, stated that she and (later identified as picked up the victim at the victim s house. They traveled to Epstein's House and entered through the kitchen or. They met with the house chef and Epstein s assistant The v in the kitchen area. m was introduced to Epstein while they were led the victim upstairs and Epstein went upstairs. When the massage was over, the victim returned to the kitchen area. stated she was paid $200.00 for bring the victim to Epstein's. stated the victimiiiiii her she was paid $300.00 for the massage. Back in the vehicle, asked the victim what happened. iiiiiictim told her about the massage and then they went shopping. stated the victim was the last person she brought to Epstein. She further stated t she had changed her cellular number to avoid being contacted by announces to h' istant that . She continued that when Epstiii, he is traveling to P iieach, would contact range girls foriiiiiiiiii, had told , later identified as Date of Birth that Je ikes to have his fun with the girls. IIIIII stated that once her parents discovered that she was visiting iiiiiin, they disapproved o e encounters with him and she stopped. further stated that III' still tri call the house and leaves me the were , and DOB DOB Sgt entered the room and explained that based on her own statements, she ha icated herself with bringing underage girls to Epstein's house. was aware of what she had state wished to assist further in opes to receive a lesser charge. provided cellular telephone numbers for the girls she had mentioned previously. Additionally, she iiiiirovided possible addresses and areas in which they lived. As was being taken home in the vehicle, a tape recorder was placed within the vehicle to record any conversations within the vehicle. During the drive back to her home, made the comment I m like a Heidi Fliess. (Hollywiiiiiidam who sent girls to clients for sexual favors in California). was dropped off at her house without incident. Sgt Flori and I went to at speak with Mrs. s Mother) at th door. We explained the ongoing investigation and felt that may have additional on as we had information that she ad worked for . Mrs. introduced us to her husband and allo n the home. We sat Mit firth was advised if her daugh interviewed encounters with • ing room and met with As she was under the age of eighteen, Mrs we would be speaking with her. She expressed, ahatchee, We met with n she wanted to assist. As we , she denied having any inappropriate (Epstein). She stated she had gone to Jeff s EFTA00230950 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 30 Incident Report Program: CMS301L Case No (Continued) House with approximately eight months ago and sat in the kitchen with the house chef but nothing hap s the parents were present during the interview, we felt that was withholding information from us. She made several comments as to she has put the entire incident behind her. I left my direct telephone number and iiiiied should she wish t ith me again to telephone me. Sgt and I thanked Mrs. for her time and left the area. She stated she would ask her again after as to what happened at Epstein s house. I informed her that had my telephone number and hopefully she would call. and I then attempted con in Loxahat We met with at ho stated was her daughter. was at the Wellington Mall a s not home. We explained the ongoing investigation and felt the may have additional information as we had information that she had worked for . We left our phone numbers and asked her to telephone me upon her daughter's return. We then left the area. On October 4, 2005, at app 05 am, Sgt had retrieved a voice mail message from She stated she had spoken with her daughter and ation as to what occurred at Jeff s house. I contacted who stated her was in the shower at the moment and would be traveling back to to attend college. I informe Det. I would be en route ibis home in I drove to the home and met and . During a sw tement, stated she was taken to the h y She was told she could make money working for. She was told she would have to provide a massage to stated er arrival to the house she was brought to the kitchen area by . They met with ho .ef and stayed in the kitchen. She was assistant and was brought upstairs to the mater bedroom. prepared the room and massage table for a massage. Epstein entered the room and she provided a massage. stated she kept her clothes on durin stated sometime during the age Epstein and pulled her close Se m. said she was wierded out by the incident involving . At the conclusion e massage, she was paid $200.00 for the massage. I asked if she has a al training in massages to which she replied no. I asked her i rece any monies for taking her to perform the ma stated eceived money for t stated she we th and another girl, t stated she w d iii kitchen with , whi u iwas taken upstairs by . stated she only did the massage once, as she was wierded out by the whole experience. At the conclusi of the interview and the tala gas stopped, I was informed that had attempted to reach IIIII via cell phone. A voice mail message on October 4, at 10:59 am, revealed a female voice who identified herself as who requested her to call her back reference the introduced to EFTA00230951 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 31 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) police questioning. This voice mail message was recorded onto a micro vided the incoming telephone n stated she i ently told about the police investigation because had called her to to about how she just received a rents car from Jeff Epstein. had called her to tell her that she was given a rental car,Iiii005 iiiiir Nissan Sentra, to utilize to visit family and visit . asked her what wising on al111pakouse that the ice w be asking questions. ill stated 1111111 then called and and asked what was going on r nc e ongoing police investigation. According to has since then been g to contact her ask about the police questions. I instructs not to contact Iiii lit not provide more information to as she would notify Epstein and what was transpiring. Investigation Continues... ****************************NARRA 8 *************************** NA Reported By: 10/07/05 Entered By.: A. 10/07/05 On March 30, 2005, I was asked by Sgt. to conducting surveillance and trash pulls reference Detective conducting a criminal investigation involving Jeffrey Epstein. I was advised that Epstein was possibly engaging in sexual contact with young females. On March 30, 2005, I made contact with Town of Palm Beach Sanitation Office Supervisor Tony Higgins and requested trash pulls for 358 El Brillo Way to begin on March 31, 2005. On March 31, 2005 at 9:20 a.m., I responded to the area of 358 El Brillo W et with Town o each sanitation employee, Jeffrey . I observed il ii enter the driveway of 358 El Brillo Way, collect the trash bags from Epstein's propert ace the contents into an empty sanitation truck. I followed to a nearby area, were he turned over seventeen white plastic trash bags, which were collected from Epstein's property. I took the trash bags to the sanitation department were I sifted through its contents. it correspondence from Armani Exchange addressed , Jeffrey E. Epstein notepaper with , an important message notepaper addressed to J.E dated 03 29 05 at 8:15 p.m. reference Peggy Seagal, U.S Airways boarding pass copy for passenger, Janusz Banasiak, Montgomery County, Maryland Health Department food service ID NO#40820 for Janusz Banasiak and Ghislaine Maxwell notepaper with names and phone numbers. Photocopiejliiithe trash collected were attached with the supplement. Detective was advised of the contents that were collected for evidentiary value. EFTA00230952 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 32 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) On March 31, 2005, Sgt. requested that I set up a surveillance vehicle on El Erillo Way and conduct video surveillance of the front exterior of Epstein's residence. At 3:00 p.m., I set up a surveillance vehicle equipped with a video monitoring device. The surveillance vehicle was parked on El Brillo Way approximately fifty feet east of Epstein's driveway. The purpose of the video surveillance was to gather investigative intelligence by monitoring and recording all vehicle and pedestrian traffic entering and leaving Epstein's property. The video surveillance tapes were changed daily with a new Maxell T-160 VHS tape. Video surveillance was established for Epstein s from March 31, 2005 through April 05, 2005. On April 05, 2005, video surveillaniiiiis concluded. I reviewed the video tapes and advised Detective the surveillance videos yielded no evidentiary value. On April 01, 2005 at 9:30 a.m., I responded to the area of 358 El Brillo Way to meet with Town of Palm Beach sanitation employee, Jessie Jones. While parked in the area of 358 El Brillo Way waiting to col • trash, I observed a white female, who I recognized as fr ida driver's license photograph. I made no contact with While parked in the area, I also observed Epstein s GMC Yukon truck leave the property as well as other vehicles arrive and park across the street from the property. The occupants of these vehicles appeared to be housekeepers, maintenance men, and gardeners. At 9:38 a.m., I met with Town of Palm Beach sanitation employee, Jessie Jones. I observed Jones enter the driveway of 358 El Brillo Way and collect the trash from Epstein s property. I followed Jessie to a predetermined area at which time I collected the trash bags from the sanitation truck. I transported the trash bags to the sanitation department, where I sifted through its contents. I collected mail correspondences addressed to Jeffrey Epstei • records and personal documents for Janusz Banasiak and as well as Epst ' aper with the names and appointment times for and . No last names or other personal information was written on the notepaper. While sifting through Epstein s trash, I also collected a three-inch purple finger size object, which had a broken end. The object appeared to be a broke piece from a sexual toy similar to a (Cyclone Vibrator) possibly used for rec atification. The sexual object was photographed for Detective "lir packaged in a biohazard evidence bag (possible body fluids) and secured as investigative evidence. All a011ebteAlfrom Epstein s trash were turned over to Detective for evidentiary purposes. On April 05, 2005 at 9:18 a.m., I sanitation employee, Jessie Jones. driveway of 358 El Brillo Way and property. I followed Jessie to a met with Town of Palm Beach I observed Jones enter the collect the trash from Epstein s predetermined area at which time I EFTA00230953 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 33 Incident Report Program: CMS301L Case No 1-05-000368 (Continued) collected the trash bags from the sanitation truck. I transported the trash bags to the sanitation department, where I sifted through its contents. I collected mail correspondences addressed to Jeffrey Epstein as well as notepaper (Important Message) with names and telephone numbers. The following are items collected from Epstein s trash. ( blank piece o paper ( ) black paper black p ) David ( ) MSN Hotmail web page with email address ( ) The following items were documented for Detective investigation for evidentiary purposes. On April 06, 08, 11, 12, 13, 15, 2005, at approximately 9:30 a.m, I met with Town of Palm Beach sanitation employees. I observed the employee enter the driveway of 358 El Brillo Way and collect the trash from Epstein's property. I followed the employee to a predetermined area at which time I collected the trash bags from the sanitation truck. I transported the trash bags to the sanitation department, where I sifted through its contents. All of the documents collected from Epstealakamtrash during my assistance were turned over to Detective IIIII for evidentiary purposes. On June 14, 2005, Detective contacted me and advised that the airplane belonging to Jeffrey Epstein of 358 El Brillo Way was parked at the Palm Beach International Airport. Detective requested that I begin trash pulls for the purpose of gathering evidence and intelligence. I made contact with Town of Palm Beach Sanitation Office Supervisor Tony Higgins and requested trash pulls for 358 El Brillo Way to begin on June 15, 2005. On June 15, 2005, I met with a sanitation employee. I observed the employee enter the driveway of 358 El Brillo Way and collect the trash from Epstein s property. I followed the employee to a predetermined area at which time I collected the trash bags from the sanitation truck. I transported the trash bags to the sanitation department, where I sifted through its contents. The trash yielded negative results and no evidence was collected. No further trash was collected throughout the week due to the fact that Epstein s security gates remained closed throughout the week; therefore, the sanitation employees were unable to gain access onto the property for collection of the trash. EFTA00230954 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 34 Program: CMS301L Case No • 1-05-000368 (Continued) All evidence and intelligence gathered by this officer has been turned over to the detective bureau and no further action has been taken by this officer. End of supplement. NA Reported By: Entered By.: A. **************************** N A R R A *************************** MI 10/07/05 10/10/05 On October 4, 2005, I made telephone contact with who had left several messages on voice mail. During the message, she advised she was not completely truthful when we met in person but would like to speak with me to advise what had happened. She further advised she did not want to speak of this incident in front of her imat , I made telephone contact with t . During a taped recorded lowing: Approximate ear ago, her to house statement, stated when she was sixteen years of age twice. The first time she went, They ered through the kitchen area w ere she waaIatroduced to and . She was taken upstairs to a bedroom by IIII who seLIle room up with a massage bed and brought out the oils to use. IIII then entered the r ing a towel. He lay on the table and picked out a lotion for to rub on him. At one point during the massage, he tried to remove her shirt at ' int she became very upset and discontinued the massage. Both and Jeffrey had a verbal at which time she le t wit out being paid. She met with who was sitting in the kitchen and told he ' o. received no money for that day. also said that had told her if she was uncomfortable with what was going on, to let him know and he'll stop. She knew that the more you do the more you are paid. advised she agreed to be tak second ii lley arrived at the residence, sat took her upstairs to the master bedroom again. use. the room up with a massage bed and brought out the oils to then entered the ring a towel. He lay on the table and picked out a lotion for to rub on him. At during the massage, he tried to touch her bu ' ks. As was wearing tight j and had a tight belt on was unable to touch her buttocks. then rolled onto his bac during the massage; he attempted to touc her breasts. Sicilian came upset again and them, downstairs where told she w discontinued the retu nd, She provide . She of drove to the house. told him she didn't want to be was paid $200.00. waiting for her leave. said she never house and had a problem with stated she is aware that her se. was also at the a telephone number EFTA00230955 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 35 Incident Report Program: CMS301L Case No. : 1-05-000368 (Continued) for The interview was concluded and the micro cassettes were turn in as evidence. On Octobeilill2 researched the incoming telephone had left a message. The telephone number, was assigned to ATT Cingular Cellular service. I prepared a subpoena request and faxed the request to the State Attorney s Office. Information requested was subscriber information as well as all incoming and outgoing calls for the months of September and October 2005. I later researche and discovered she resides in Royal t. and I r lm Beach and met with at her residence in Royal Palm Beach. agreed to warglimwith us in the kitchen area. During a sworn taped statement, IIIIII star wing: On or about November 2004, she was approached by and asked if she wanted to make money. She agreed and ld she would provide a massage to wealthy man in Palm Beach. picked her up and drove her to a house in Palm Beach. She was br iintiiiii kite house. She further stated that ( ) andill Iiil ) went with themillihey were brought into Itchen where she was introduced to and oth emales. Iliiili stated she was introduced to a helper of 'ill; the female was described as white female (unknown n with blond hair. She stated that the assistant was familiar The assistaiii he massage table and put out lotions to be used. She told woulg.ayailable in a minute. IIII entered the room wearing only a towel. IIII lay on the wo e table and picked a lotion to rub on hialLighs and back. her clothes. She complied and removed her pants and blouse. further stated that during the massage IIII asked her tiiiiiive didn't remember if she had removed her bra but feels that shill, was certain that she stayed in her thong underwear. continued add 'm to massage his back, was instructed to returniiiiiie ground at which time rubbed. turned to have his chest masturbating. Ailed it was at this time she is sure he was di t want to look at his penis area because she was uncomfortable. removed aiiiiirned Shortly thereafter, ejaculated and removed himself rom the table. He walked over to where the shower was and opened the glass door. Sh gailed as he was taking a shower in her direct view. When I asked IIIIII how old she was when this occurred, she stated d just turned seventeen. At tM conclusion of the shower, was paid either $350.00 or $400.00. She stated she wasn't sure, but ws it was close to $400.00. At the w, stated she never returned to . She advised she was ashamed and conclusion of the inte provide a massage for uncomfortable with the situation. EFTA00230956 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 36 Incident Report Program: CMS301L Case No. . • 1-05-000368 (Continued) Det. and I then 1 e area and responded to the Royal Palm Beach High School where and all the above- ' d girls had attended. I met with Schoo Police Officer, Off . I explained I was looking for a previou o attended Royal Palm Beach High School. I inquired about iiiiiii iii I further explained that I was working a case in which most of the girls I hav interviewed are either es or victims and felt that may be one as wel researched his previous student records and found . She attended the same year and graduated in the same as the other girls. I was provided the last known address of At approximate) and I met with at her residence, in Royal Palm Beach. As IIII! was seventeen years of age, I had notified her mother, Mrs. , that she would be interviewed reference an ongoing investigation in Palm Beach. I assured her that her daughter was not a suspect. I explained the possibility oflig ing either a witness or victim. Mrs. advised she wanted IIIIIII to cooperatiiiiiii minted to the interview. During a sworn taped statement, stated the following: at the age during the month of September 200 e was approached by chance to make money. was friends with the friends of ill and knew the eople. ha did for previously told by her friends whaill, cal and scheduled the appointment. person to IIIII as picked up and drove her to Palm Beach to a street called Brillo Way. They drove to the end of the street and entered a large ewailliihey entered the kitiiii mil the,. and met with led . was introduced to . with a massage table and se upstairs to the main bedrooil and set up the room the oils. di the lights and turned on soft music. exited the room and entered the room wearing only a towel. picked oils and ins ted her to rub his legs, under hi tocks, back and chest area. asked her to get comfortable. advised she did not remove her clothes. She was wearing tight jeans andliiiropped tank top exposing biiiii, thiassage, removed his towel. As , attempted to reach down her pants through the buttocks area, howe as unable due to the tightness of the jeans and a tight belt. advised began to masturbate as she rubbed his chest. moaned as she rubbed his chest. She observed he was continuing to mas and touch her breasts. to and attempted each up her tank top pulled back and stopped. However, he kept masturbating until he climaxed. H aned himself with the towel he was previously wearing. I asked if she knew the ' ce betweeiliircumcised and -not c cised. -She ekplained she knew and advised was circumcised. massage and left the area. She met with kitchen area and left the house. as paid $200.00 for the who was waiting in the then explained she never provided another . She did however, go to the house with IIIIII and ) as they EFTA00230957 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 37 Incident Report Program: CMS301L Case No • 1-05-000368 fend of went to work sat in the kitchen area wit that while they waited for , the chef prepared lunch for them, as it was almost lunchtime. As wa shed with the massage, they left the area. I asked if ii eggLaold what would ected of her when she provided a massage. IIIII stated yes, told her that a massage wo e expected possibly naked and possibly some touching involved. ill has no formal training in providing massages. spoke about a third drove an". girl, house. ted she knew that providing girls for Si and she wanted to t ' the hen ar and took a she doesn t know wha what happened in t oom. going with her to unable to remember (Continued) advised she was present when . She advi r rhhiver and to wait for advised is went to house. friend, to had made money do the sam he house and introduced upstairs to pened as did no about received 100.116 for ouse and recommending 11 was s telephone number. The interview was concluded and we left the area. Investigation Continues... ililli **************************** N A R R A ************************** NA Reported By: 10/09/05 Entered By.: A. 10/10/05 in bedroom. On October 6, 2005, Det. in Boca Rato explained to Town of Palm Beach and informa on the the time of our arrival. in class a ing her to interview in an empty and I went to located with Dean of Students, Paul Turner. I that we were investi e within the felt that a s t, , may have o is a student and currently She was in computer clash,'" Turner sent ' guard to locate the office. allowed us to conference room. At 11:45 am I met with and explained to her why we there to interview her e advised she was aware of the ongoing igation. who told h stated she had previously spoken with taped statement, e was interviewed by diiiiiiihituring a sworn ted she knew that worked for Jeff in Palm Beach. advised she has been there many times for massages. Sled her if she had fo raining in providing massages, stated she did not. advised she was told what was expected of her by providing massages and wouldjaave to remove clothing but if she feltuncomfortable just to say II and Jeff would stop pushing the issue. began pro". massages and advised she kept her clothes on. She considered a pervert who kept EFTA00230958 Date: 7/25/06 Time: 8:47:53 Incident Report Page: 38 Program: CMS301L PALM BEACH POLICE DEPARTMENT Case No • 1-05-000368 pushing to go further and further. telling him she had a boyfriend and t boyfriend. It wasn t until recently (Continued) explained she would keep 't would not be right to her admitted to removing her es and stay in her thong underwear to provide a massage. explained wanted to be rubbed on his back and recently he began turning over to have her rub his chest as he mastur . He would try to touch her breasts as she rubbed his chest. stated, Jeff would t get away with more and more on each massage. iiiiinally, left her cell phone number and every time Jeff would come drove her to the house for the original massage. would call her for an appointment. Each time she went, would meet her at the kitchen door . She would bring her upstairs and prepare the massage table. ould ask her questions a He knew she ditillifil and would ttending . I asked if he knew her real age, stated Jeff didn t care. The most recent massage she provided was on October 1, 2005. During the massage she asked Jeff if she bor one of his vehicles to visit her family and boyfriend in . had told she could borrow one of his vehicles but later st er a car satlairigarstjajjig massage as Jef and Il IMIMI . I asked if she was wearing undergarments to which she replied her Once he tried to h her breasts she would pull uld stop. was asked if he ever used a w w vibrator but advised she him to on her. She described the into t thong underwear. away from him and vibrator on her. never would allow vibrator as a large white vibrator with a huge head on the tip of the vibrator. She s he kept the vibrator in a closet near the massage table. advised she had been doing the massage for approximately two years, which meant she would have started doing massages for Jeff at the age of sixteen. stated she w ontacted by on October 3, 2005. had informed her that had rented her a n issan SentLaAad she should come by the ouse to it up. informed I'll' she would have the car for a month. stated knew her car was not working properly and had mi appointments in the past because of her car being inoperable. explained the car is currently parked next to field. I as e her ' M toak any one to the house. ed she took , a friend of hers who has returned to to at c ed she ever allowed another female in the room. advised no one was bro nto the room with her. At the conclusion of the interview, Det. and I went to the and located the Silver Nissan Sentra bearing Florida tag The vehicle is registered to Dollar rent a car out. of-the Palm Beach—International Airport. ntact was made with , the victim's mother, at . I explained to her that I was following up on this case and provided a complete update on the case. Investigation Continues. EFTA00230959 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 39 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) ****************************NARRA ************ ***** ********* NA Reported By: ill 10/21/05 Entered By.: A. 10/21/05 On October 10 roximately 2:30 p.m., I made tel ne contact with . During a taped conversation, was told of an ongoing investigation which I felt she had information pertaining to Jeffrey Epstein. explained she met Eps en just sixteen years of age. She was approached by , a nd who also had previously gone to Epstein's house for massages. advised was working at the Wellington Mall when she was approached. ssage to Epstein and s e would have to perform this massage naked. thought about the offer and stated she could make $200.00 for WWIminutes of work. She agreed to perform the age and set the appointment for her that same day. remember was a weekend as she only worked at the mall on th ek took her to the house where she was introduced to Epstein's took her upstairs to a master bedroom. , assistant. explained that as she was walking up the stairs she observed several lillographs of naked women along the walls and tables of the house. further explained that she was brought into the bedroom where prepared the room by setting up the massage table and provided the oils for her to rub on Epstein. Epstein entered the room and introduced elf. Epstein lay on the table and told her to get comfortable. could remember if he was naked or if he entered the room with a towel. stated she provided the massage wearing y her panties. She continued rubbing his legs, thighs and feet. advised he turned ove back. iiiiiiitinued to rub his legs with the oil and began to masturbate. I ask Epstein if she knew what circumcised and un-circumcised meant. stated circumcised is n the penis has no foreskin and head of the penis is visible. said Epstein is circumcised. began to cry on the telephone and stated she had been to his house hundreds of times over a two-year period. Unclaimed to have made thousands of dollars during her visits. stated she could not remember how many times exactly she went to Epstein's home but said it was a lot. became more ujuin nying hysterically and state and instructed to with Epstein's assistant. by Epstein. Eps • them . himself as they things escalated further an as vibrators, "ler penises Additionally, state She claimed he (Epstein) masturbated in an attempt to make her climax. and wanted some time to regain her composure. take her time. After taking several minutes , told her that she would have to provide and masturbated stated that 1 toys such erous times. while he could not continue I explained to IIII to to regain her composure I EFTA00230960 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 40 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) explained that I would travel to meet with her in person as I felt she had additional information to provide. I met with Sgt. wand explained the importance to meet with agr ' ents for Det. and I to meet with in 2005, at 4:10 p. and I met with r f d, 1 Kingsley Road in wanted to ave present for support. I fined to her that I did not have iiiioblem as long as she wanted present during the inte stated she wanted her present. I explained that as was present she was not allowed to comment or any questions during the interview. She was only there to comfort should the interview upset her. During a sworn taped statement, explained how everything be She said she was brought through the kitchen area where she met for the st time. She was led to the master bedroom, Epstein s room. explained that as she was walking up the stairs she observed severa of the house. person. Sgt. otographs of naked women along the walls and tables further explained that she was brought into the bedroom, where prepared the room by setting u e massage table and provided the oils for her to rub on Epstein. explained she remembered the steam room area, which contained two large showers. Epstein entered the room from the steam room area and introduced elf. Epstein lay on the table and told her to get comfortable. removed her skirt and kept her shirt on. She could not remember if he was naked or if he entered the room with a towel. Epstein then instructed her to remove her shirt. remembered she was not wearing a bra. stated she provided the massage wearing on er panties. She continued rubbing his legs, thighs and feet. advised he turned over onto continued to rub his legs with the oils. Epstein and began to masturbate. Epstein ejaculated • h meant t e massage was over. At the conclusion of the ma e, 200.00. They walke gether 'rs where and were waiting. stated received an unknown amount o money for taking her to Epsligin. Epstein instructed to leave her cellular telephone number II that he could contact her when he is in town. explained that she continued to go to Epstein s house and became a regular at the house. She could not provide an exact number but claimed she had been their hundreds of times. She claimed sexual activities did not occur every time she was the There were times she went to dinners and parties with Epstein. explained that things began to escalate more than t e e nters included bringing in his assistant, . explained Epstein had purchased her from her family in Yugoslavia. Epstein bragged he b ht her into the United States to be his Yugoslavian sex slave. advise aked in the bedroom, she entered and removed her clothing. lied t steam room area already naked. He instructed to on emoved her shirt and EFTA00230961 Date: 7/25/06 Time: 8:47:53 Incident Report PALM BEACH POLICE DEPARTMENT Page: 41 Program: CMS301L Case 1 00368 refused to per an additional $111,0 utiill (Continued) Epstein d her explained that Epstein would masturbate while he watched them perform sexual acts. Things continued to escalate by purchasing sex toys. had massagers, vibrators and strap on rubber penises Each time somet and offered for d she new was introduced additional m ews re produced to allow the acts to happen. was adamant that she performs all these acts but there was an understanding will, Epstein that no vaginal penetration would occu with his penis. explained that Epstein's penis was deformed. explained that his penis was oval shaped. She claimed when Epstein's penis was erect, it was thick toward the bottom but was thin and small toward the head portion. She called it egg-shaped. continued that th xual encounters with her became a rit would arrive at the house upstairs, where and Epstein were wai clothing and join them and she would begin by tiled sex toys were bro • • pstein or uld begin . Epstein would on either person depending who was on top during the intercourse. Halls explanation revealed they were in a missionary position. advised one day, (i was unable to state and e date when this incident occurred), she came to the house after had informed her that Epstein had arrived. Shiliirived at the house and went macrer bedroom. advised she immediately removed were already naked in the e a sexual remembered from the massage table. assage table in the and she were. Ensrein upstairs to the her clothiugs.as bedroom. IIII explai encou ' ude and was removing her asked for a sheet of paper an master broom and where Epstein, stomach on the massage bed and stated Epstein began to , Epstein and aiiimgalk herself gm.' would She scre She told him that she did not want to . Epstein apologized for his actions and subsequently paid her a thousand dollars for that visit. Addititsselly, shortly thereafter, Epslein- gave -a -2-crarnage Neon, blue in color for her personal use. advised there miggIe times that she einii l iouse. IIII advised she was II advised she had difficulty walkiiilio the car after leaving the house because she was sore. advised that other EFTA00230962 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 42 Incident Report Program: CMS301L a hello, how are contact from the area. The tapes Case No • 1-05-000368 l than that one time, when Epstein there was no other penile intercourse. provided name girls p that she knew o f rovided the name of gone to Epstein's house. and feels she l m going to the house to massage Epstein. According to , " is still sucking his dick." asked if she had been recently cont d by anyone of the house, ived an email from , from , which is her email account. The email was just you doing type of email. There had been other house. The interview was concluded and left the and drawing were submitted into evidence. Investigation continues... ***************** ****** *****NARRA ************************** Mt NA Reported By: 11/01/05 Entered By.: A. 11/07/05 On October 12, 2005, Det. area and made telephone contact agreed to meet with us as we were in area. rovided directions to her apartment. Det. an I met with who stated, during a taped statement that nothing happenedbetween her and Epstein. appeared nervous during the interview. I assure that I had spoken with other people who advised differently. il i stated she only went a couple of times and provided a massage to Epstein. e was brought to the Ep ouse in March of 2005. brought o work. has no formal training in providing r massages. Ili stated she provided a massage, fully for $200.00. sensed I hesit As ancy in her answers, r if she had been contacted by anyone from the house. stated she was interviewed already by an investigat Epstein. He met with her on Octobeili, 2005, at a Roadhouse in He identified himself as and ' out the police investigation . ft his telephone number for additional contact. provided no additional information, as it appeared her responses were almost scripted. We left the area and returned to Palm Beach Police Department. Based on the information acquired during the interviews, a search warrant was prepared for entry at the Epstein home. On October 18, 1- met- with-Judge-Laura Johnson who reviewed the warrant request. She found there was sufficient probable cause and signed the warrant request. On October 20, 2005, at approximately 9:36 am, members of the Palm Beach Police Investigations Unit executed the search warrant at 358 El Bril • ' Palm B Membeiiiii the Inyggligations Unit f aPt met. Det , the crime scene unit and myself. , IIIIII, EFTA00230963 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 43 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) As we entered onto the property, we encountered the house manager, Janusz Banasiak who was in the guest portion of the house. The guesthouse section had open doors and no f was made. I ' Banasiak, Date of Birth Fl DL , and informed him of the search warrant for the premises. T e members of the Police Department entered the residence and announced we had a search warrant. A safety search was done and ited the home. I read the search warrant to Banasiak as Mgr x videotaped the search warrant execution. Several interior decorators were located on the property. I spoke with Mark Zeff, of 515 W 20th Street in New York. Mr. Zeff stated he is the designer for Mr. Epstein's homes. He advised he was contacted in March of 2005 to do a complete overhaul on the house. He advised he was on the phone with Mr. Epstein when officers announced the search warrant. Mr. Epstein was then made aware of the search warrant. Mr. Zeff advised, his contact with Epstein is strictly business and he has never witnessed Epstein with any girls except for his assistants, or I then interviewed Daniel Estes, of 315 Mr. Estes stated he has worked for Zeff he personally worked on the New York Epstein. He has previously met with assistants in New York and in Florida. Epstein everywhere he goes. East 14th Street in New York. for seven years. He advised Palm e for Mn. and , Epstein's Estes stated they travel with s iewed of 35 Riverside Jersey City, New Jersey. tated she just arrived from Scotland and has worked with Zeff for only one month. She stated she has never met Epstein and has not seen him. The interview was then concluded. I then spoke with Douglas Schoettle of 243 Riverside Dr in New York City. Schoettle stated he has been Epstein's Architect for seven years. He further stated he deals with Epstein's assistants and speakillitii ein on the phone. Schoettle stated he mainly speaks with , Epstein s main assistant, who travels with Epstein. Schoettle stated he only has contact with Epstein when his services are needed. At approximately 10:30 am, I was informed that the videotaping was concluded. I entered the residence and located two covert (hidden) cameras. The first camera was a covert wall clock in the garage area. I traced the wire behind the clock and removed the RCA wire and unplu.ged the camera. The other covert _camera was located_within a desk clock beside Epstein's desk. I traced the wire behind the clock and unplugged the RCA wire. I could not locate another camera. I then began with the search of the residence for the specified evidence. My search consisted of the second floor. Det. and I began in the master bedroom area where several items were located. They were EFTA00230964 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 44 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) marked to be retrieved by the evidence custodian. In the master desk with Epstein's notepads marked Jeffrey Epstein we locate • of transcript from Royal Palm Beach High School for . Also in the room, was the dresser /armoire where we located a bottle of peach flavored Joy Jelly (Sexual Lubricant). Additionally, there were several photographs of young naked teenage girls within the closet, which was consistent with what the witnesses said. The massage table was also located within the master bedroom. Video tapes were located beside the television, which were also collected. An itemized list of the property and locations was prepared on the property receipts. At approximately 2:55 pm, the house was secured; the exit of the residence was videotaped. Upon our exit of the property, I encountered Atty. Guy Fronstein who advised he was representing Mr. Epstein. He provided a business card and provided his assistance with the investigation. NA Due to Hurricane Wilma, which struck South Florida causing massive power outages, the courthouse was closed due to the lack of power. was previously told that the Chief Judge had extended the filing deadlines due to the hurricane and the Courthouse being closed. On October 27, and 28, 2005 the courthouse was closed and I could not file the search warrant and inventory at the clerk's office. On October 31, 2005, I responded to the courthouse and filed the paperwork along with an order to seal, signed by Judge Johnson, to deny any release of any paperwork on this case. INV CONTINUES.. Mr ****************************NARRA # ************************** Reported By: , A. 10/20/05 Entered By.: A. 11/07/05 On October 20, 2005, at imately 8:30 a.m., Thursday morning, I was advised by Captain that a search warrant would be executed and that I was to assemble the Crime Scene Investigative Team and stand by the south s"lding ready to go. I designated Evidence Specialist to handle the inventory return, the documentation of the property receipts and the collectio ing of the evidence at the scene. I further instructed CSI , ID # 8807, to accompany us and perform the role of photographing t e scene and i may be taken into custody by the affiant, Detective , ID # 7915. My responsibility was to go through from the reading of the warrant to the _final_exit_from the residence and perform a video recording of the reading of the warrant, the initial walk through of the residence showing the current condition and then finally a walk through of the residence at the time of the police exit. We started out towards the residence, which was located at 358 El Brillo and arrived at approximately 9:33 a.m. The searciiiii, conducted, items were collected by Evidence Specialists EFTA00230965 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 45 Incident Report Program: CMS301L Case No • 1-05-000 (Continued) photographed by CSI and then videotaped by myself. T was concluded at approximately 3:05 p.m. whereupon Detective and I were the last two officers in the house. Upon securing the residence with the gentleman who identified himself to Detective as the lawyer for the defendant and he was informed that the residence was secured and that copies of the inventory return had been left on the first floor table of the personal assistant's office. Detective and I returned to Police Headquarters and secured for the day. **************************** N A R R A ************************** NA Reported By: 11/07/05 Entered By.: 11/07/05 On October 20, 2005, I assisted Defective in the execution of a search warrant at 358 El Brillo Way, Palm Beach, Florida, 33480. Upon the announcement of the search warrant, immediate contact was made with three white males who came out of the house or surrounding structures. Those males were identified as Janusz Banasiak, Estes, and Mark Zeff. As other members of the police department cleared the home, I kept watch over these three males. e house was cleared, those males were turned over to Detective Detective and I were assigned to assist in the search of main house, the cabana and the servant's quarters. We started garage. All areas of the garage were searched to include four vehicles. These vehicles were three black Mercedes Benz cars registered to Jeffrey Epstein. The fourth vehicle was a Harley Davidson motorcycle, green in color, registered to Jeffrey Epstein. Nothing was recovered from the garage. the in the A towel closet and pantry located off the kitchen were searched and yielded negative results. The kitchen was searched and taken into evidence was a phone message book that was located near a house phone. North of the kitchen was an office room which contained a computer. The room had a closet that contained a locked gun locker. combination was entered by Banasiak in the presence of Sgt. and the safe was opened. Items were taken from the room. See the completed property receipt for a detailed list. A green bathroom located on the first floor was searched and nothing was taken. A closet located just west of the green bathroom was searched. Two massage tables were located in the closet along with a photo of a nude EFTA00230966 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 46 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) female from the waist up. See the property receipt for details. I searched two bedrooms and their adjoining bathrooms, which were located on the second floor on the East side of the house. In the Northeast bedroom closet I found adult sex toys called Twin Torpedoes. Soap made in the shape of a penis and vagina were also found in these upstair bedrooms. See the property receipt for details. I searched the pool cabana located on the South side of the pool. Photos were taken from the wall. See the property receipt for details. I assisted in the search of Banasiak's living quarters. Numerous CD s along with a message book was seized. See the property receipt for details. ****************************NARRA ************************** illit NA Reported By: 11/08/05 Entered By.: 11/08/05 On November 1, 2005, I was contacted by Atty. Gus Fronstin, who advised he was willing to assist with the investigation. Atty. Fronstin advised he would try to have his client, Jeffrey Epstein available to be interviewed. I explained I would be interested in conducting an interview with his client as well as other employees that are employed within the house. Atty. Fronstin advised he would return my call once he received confirmation on the interviews. On November residence. retur from with provide an Palm Beach allowed to 6, 2005, I attempted contact with I left a business card for her to retu lice department, I had re I returned her call at . She made arrangements to respond to interview. At approximately 3:30 pm, she arrived at the Police Station with her boyfrieniiiiiir boyfriend was sit in the lobby area while Ms. was interviewed. rn my at her call. Upon ephone call and spoke the station to I took Ms to the Detective Bureau Interview room. I closed the door for privacy and explained to her that I appreciated her coming to the police station for the interview. During the sworn taped statement, she advised she was at Jeffrey Epstein s house o imately two months ago, she was approached by a girl, who was dating her roommate, to make some quick money. advised she was in need to make some quick cash to make the rill She agreed to go to the house. She had been told by tige massage would have to be done in her underwear. She advised drove with her and brought her into the house y walked into the kitchen areaand took the stairs upstairs. ...M further stated she was brought into a master bedroom area. She advised she recalled seeing portraits of naked women throughout the room. A massage table was already out near the sauna/shower area in the master bedroom. Epstein entered the room wearing only a towel and EFTA00230967 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 47 Incident Report Program: CMS301L Case No • 1-05-00036 (Conti introduced himself as advised she recalled she and removed their clothing down to their panties, Epstein lay on his stomac and they provided a massage on his legs and feet area. I asked if she had any formal massage training and she replied no. advised she was toples the panties she wore were the boy shorts lace panties. She and il continued t ssage until the 1 t ten mialgas of the massage, Epstein, told to leave the room II that IIIIII could finish the massage. got dressed and Epstein turned over onto his back. Epstein then removed the towel, which had be and his waist. Epsteiiiiiii there n ted that rub his chest area. stated rubbed his chest. stated and he produced a large white vibrator with a large • awe is master bathroo . advised he never with the vibrator. He continued as he continued to masturbate. stated she was very uncomfortable during the incident but knew it was almost over. Epstein climaxed and started to remove himself from the table. He wiped himse h the towel he had on previo and went into the shower area. got dressed and met with in the kitchen area. DaLgin came into the kitc d provided $200.00 for bLijggyag IIIIII and paid $200.00 to for providin massage. IIIIII was told to leave ephone number with , his assistant for future contact provided her cellular telephone number for future contact. was asked if she was recently contacted about this investigation by anyone from the Epstein organization. She repli e was called but it was for work. She sta e was called by for her to to work for Epstein. stated is the term used by to provide the massage in underwear. advised she declined, as she was not comfortable in providing that type of work. The interview was concluded and the videotape was placed into evidence. Investigation Continues.. **************************** NA MI NARRA ************************** Reported By: 11/10/05 Entered By.: A. 11/10/05 On November 7, 2005, I made telephone contact with advised she would be able to meet with me at her home. Det. veled to her home in Royal Palm Be ade contact with During a swor eme stated she met Jeffrey Epstein through would approach females who wished to work stated she was asked to work for him but declined. explained that work means give massages. She was asked y formal training inpiiiiiing massages to which she said no. said she accompanied and other females EFTA00230968 Date: 7/25/06 Time: 8:47:53 Incident Report PALM BEACH POLICE DEPARTMENT Page: 48 Program: CMS301L Case No 1-05-000368 inued) who were taken to Epstein s house to provide massages. further stated she had been to t se app es in r accompanied with , the 14-year-old victim, and Each time the girls were taken over, they were previously told they would have to provide a massage, possibly naked. It was also told that should Epstein require them to do anything extra were not table just to tell him and he would stop. stated received $200.00 for each girl she brought over to massage Jeffrey Epstein. When I asked which girl appeared to be the youngest, she replied, the victim, as she stat as fifteen years old at the most; she looked really young. further stated ea e she went to the house, she sat in the kitchen and waited with until the massage was over. She further stated that the cook would make lunch or a snack for them as they waited. I asked here was anything that caught her attention within the home. stated there were a lot of naked girls in photographs throughout the house. The interview was concluded and the tape was turned into evidence. Investigation Continues.. **************************** NA Reported By: Entered By.: NARRA ************************** 11/10/05 11/10/05 Det. and I attempted contact with al Palm Beach. I left my business card at her front door. Ms returned my call and arranged a meeting with me at the Palm Beach Department for November 8, 2005. At approximately 2:00pm, arrived at the Palm Beach Police Department. She was brought into the interview room and the door was closed for privacy. She was told that I appreciated her coming to the police station for questioning regarding an on going investigation. She was told that I was investigating a crime involving Jeffrey Epstein and knew, based on the investigation, that she had silers with him in the past. During a sworn taped statement, stated she had met Epstein t rs ago. She was first introduced to Epstein by approached her about working for Epstein and assage to him for $200.00. The arrangements were made coulii iiakel iihe day the arrangements were made, took . also attended Royal Palm Beach High School and was familiar with Epstein. recalled she was brought there and eniiiii through the back kitchen do -- ha with an assistant and another assistant . brought her upstairs as she obse several photographs of naked females throughout the house. stated E ' came in the room, wearing only a towel, and laid on the table. stated he picked out the oils he wanted her , and requested she remove her clothing to provide the massage. . stated that on the first massage she provided she did not remove her EFTA00230969 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 49 Incident Report Program: CMS301L Case No - m 00368 (Continued) clothing. stated she had returned sev 'mes after that. Each time s!!'!!!!rned more things happened. stated that the same thing would happen. Epstein would walk into t e master bedroom/bathroom area we ' ly a towel. He would masturbate as she provided a massage. stated she was unsure if he climaxed as he masturbated under the towel. Additionally she never looked blow his waist. She claimed that Epstein would convince her to remove her clothes. She eventually removed her clothes and stayed in her thong panties. On occasion, Epstein would use a massager tor, which she described as white in color with a large . Every time she provided a massage he would masturbat added she has no formal training in providing a massage. sta two females during he 'sits ges. brought ,stated she brought a girl and from Royal Palm Beach High School. st he received $200.00 for each girl she brought. Additionally, was given $200.00 for taking her in the very beginning. The interview was concluded and the tape was placed into evidence. Investigation continues... Mil ************** ****** ********NARRA ************* ****** ******* NA Reported By: 11/13/05 Entered By.: 11/14/05 at her residence. 8, 2005, I made telephone contact with !MINIM', W/F, responded to t e police station for an interview reference an ongoing investigation. At approximately 2:30 pm, she arrived at the Palm Beach Police Station and was brought into the interview room for the interview. The door was closed for privacy and she was told that I appreciated her cooperation in this case. During a sworn taped statement, stated she had met Jeffrey Epstein approximately yeiiligo. She was approached by a had a her if she wanted to make money providing massages to Epstein. had heard that several girls from Royal Palm Beach High School were doiiiiihisiiii making money. She agr d was taken to the house by . had introduced her to linand Epstein and brought her upstairs to a master bedroom and Master bathroom wh a massage table was prepared and the proper i werii en out. left the room and waited downstairs for . stated Epstein entered the room wearing a and she provided a massage wearing only her thong panties. advised Epstein had masturbated every time she provided a massage-. She-stated Epstein continued to masturbate until he - climaxed; once that occurred the massage was over. She felt the whole situation was weird but she advised she was paid $200.00 for p‘ggiging the massage. She also stated IIII received $200.00 for bring IIIII to Epstein. stated she had gone a total of 15 times to his residence to provide a massage and things had escalated from just providing a EFTA00230970 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Incident Report Page: 50 Program: CMS301L Case No • 1-05-000368 massage. Epstein began touching e masturbated. Epstein also wit stated on one occasion course. She sta Epstein removed massage table. if she had any formal did not. (Continued) er d h his hands as she provided the massage. , he offered extra monies to have vaginal table. and began hed the point of climax. and climaxed onto the receive• 350.00 or her massagelliilasked her training in providing massages, stated she conti to state on one othe casion, Epstein introduced his tant, into the massage. ilii was b ' • h to nrov~de a massage. Epstein had them as they provided a massage to Epstein. Epstein, watched and masturbated as this occurred. On other occasions, Epstein introduced " sage during the massage. Epstein on vagina as she provided the massage. with I stated the last time she spoke with anyone at the , was stated she had names o ti i ple t and Epstein house. She provided the (unknown last should b noted, had been previously identified as and had been previously interviewed. The interview was concluded and the videotape was placed into evidence via the locker system. On November 9, 2005, Sgt and I traveled to 6791 Fairway Lakes Drive in Boynton Beach, Florida in hopes to interview Juan Alessi, the former houseman of Epstein's home. As no one was home, a business card was left for him to return my call. We then traveled to 11349 SW 86th Lane in Miami in hopes to interview Alfredo Rodriguez, a former house man of Epstein. We did not locate them at home. I left a business card for him to return my call. traveled to , We requested to speak with Dea mi Students, Ill . was re interviewed, as she still was i session of thil tal car that Epstein had acquired for her. stated that , Epstein's assistant, had called her on her cellular telephone and informed her that rental was extended for her. stated she had paid an additional $625.00 for her to keep the rental an extra month. was asked if she had any additi contact with either Epstein or anyone from his organization. stated she did not, other than the telephone i informing her that she could keep the car for an extra month. did not provide any additional information. On November 10, 2005, at approximately 9:47 am, Alfredo Rodriguez had telephoned reference my business card found on his door. Rodriguez stated he had worked with Epstein for approximately six months after EFTA00230971 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 incident Report Case No • 1-05-000368 Page: 51 Program: CMS301L (continued) the previous houseman left. Rodriguez stated that it was his responsibility to keep the identity of the masseuses private. Mr. Epstein had a massage in the morning and one in the afternoon. Mr. Rodriguez stated he would rather speak about this in private. He advised he would come to the police station to speak with me. Rodriguez stated he would return my call on Monday, November 14, 2005. I then made telephone contact with Juan Alessi. He advised he found my card on his door and wanted to know what I needed to speak with him about. I explained to Alessi that I was conducting an investigation on his former employer, Mr. Epstein. Alessi stated he would return my call shortly as he was in the middle of a project at his hom received a telephone call from Attorney Donald Morrell from . Mr. Morrell stated he represented Mr. Alessi and did not want me speaking with his client. I then made telephone contact with the State Attorney s Office and confirmed that subpoenas would be issued to the former employees to assist in the investigation. I then made telephone contact with Attorney Guy Fronstin, attorney for Mr. Epstein. I explained to Mr. Fronstin that I would like to speak with Mr. Epstein. He stated Mr. Epstein is not in residence in Florida at this time and would check with him to ascertain if he could be here by Wednesday November 16, 2005 for an interview. Mr. Fronstin stated he would return my call should Mr. Epstein decide to come in to the police station for an interview. Investigation continues. ************x***************NARRA NA Reported By: Entered By.: St ************************** 11/15/05 . 11/16/05 and I tra and spoke with She was told of the ongoing investigation involving Epstein. advised she had gone to the house on several occasions. During a sworn taped statement, she advised she start g to the house approxi one yea and was brought by (Unknown last name). stated ought her into the h and she was introduced to a girl named . Once she , brought her upstairs into a master bedroom bathroom. stated she met Jeffrey in the bathroom. He lay on the table and picked the massage oils. She provided the massage, as he lay naked on the massage bed. She stated she rubbed his calves and back area. Upon the end of the massage, Epstein removed himself from the massage table and paid her $300.00 for the sudssage. sta six times. notified by , Epstei ' stant, that Epstein was in town and would like her to work. stated she returned to the house and was again led upstairs by . She provided the massage, clothed. had only been at the house approximately five or said each time she went to the house she was EFTA00230972 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 52 Program: CMS301L Case . : 1-05-000368 ued) advised it wasn't really weird until later on. asked if she ever removed her clothing to provide a massage. stated it w ntil the third time she went", she removed her clothing. stated she was notified by that Epstein wanted her time to work. She arrived at the house and was led upstairs by . She started pro he massage when Epstein asked her to remove her clothing. removed shirt She stayed in her thong panties and in turned over onto his back and she stated s he was masturbating himself as she providing the massage. stated she believed he climaxed based on his breathing. She did not w iew either the climax or the fact that he was masturbating. stated once the breathing relaxed he got up and told her to get dressed. She was paid $300.00 for her services. stated was notified by e last time she went to provide a , she to come to the house and work. stated she was now dating her current boyfriend and did not feel comfortable going. She recalled it was approximately January 2005. She said she went, already.thinking that this would be the last time. She went upstairs and went into the master bathroom. She met with Epstein, who was ' only a towel as he entered the room to lie on the table. stated Epstein caught her looking at the cloc several occasions. Epstein asked her if she was in a stated her boyfriend was in the car waiting for her. further stated that Epstein got upset, as she wasn't enjoying the massage. She told him that she didn't want to continue and she would not be back. Epstein told her to leave as she was ruining his massage. I asked her if she had any contact with Epstein's organization, she stated she received $200.00 from Neste in Royal Palm Beach and Okeechobee Blvd as a Christmas gift. ised she had no formal training in provide any massages. also stated she was sixteen years old when she first went to Epstein's house. At ' ately 4:22 pm, I made telephone contact with at suggested she come to the police station for an interview. . She agreed to meet with me at a public place. " III, did not want to meet at the police station. I recommended we meet at the Palm Beach Gardens Mall in the food court area. She agreed and an appointment was made for November 15, 2005 at 5:00 pm at the food court. Investigations Continue. ****************************NARRA ***** *** ************* NA Reported By: R. 11/16/05 Entered By.: A. 11/17/05 On 10/20/2005, I assisted executing a search warrant at 358 El Brillo Way in the Town of Palm Beac ch County Florida under the direction of affiant Detective EFTA00230973 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 53 Program: CMS301L Case No • 1-05-000368 (Continued) Detective and I searched the pantry room that is west next to the kitchen. This room had all white cabinets with a dark grey and black counter top. We did not find anything in this room. We searched the yellow and blue room that is west next to the pantry room. This room had a very large statue of man with a bow. Taken into evidence from this room were nine photographs in frames of various women. We searched the main entrance foyer that is to the north of the yellow and blue room. This room contained two bamboo chairs and ottomans with cushions. It also contained a round table with numerous books. We searched another blue room that is west of the foyer. This room had a stereo system and book shelves that were from the floor to the ceiling. Taken into evidence from this room were eight photographs in frames of various women and/or Epstein, the owner of the residence. We searched the room to the west of the blue room that has sliding glass doors that lead out to the pool. In this room in a dresser were two DVD's and two VCR tapes. These items were taken into evidence. searched a 2004 black Chevy Suburban bearing Florida tag , registered to Jeffrey Epstein DOB 01/20/53, which was located on the east side of the driveway facing south. I found a Thrifty rental agreement between the passenge iddle from . The phone number on the rental agreement was The laillialg rented was a white 2005 Chrysler Sebring bearing Florida tag I'll'. The vehicle was rented on 9/25/05 at 17:58 hours and was returned on 9/26/ t 16:52 hours. T ur numbers of the credit card used are . Detective found a piece of paper in the middle console that used the cash in here to fill up the tank and was signed by ched the 2005 black Cadillac Escalade ESV bearing Florida tag , registered to Jeffrey Epstein dob 01/20/53, which was located on the west side of the driveway facing south. I did not find anything in this vehicle. All of the items that were taken into evidence were photographed in the place they were located and then turned over to crime scene. Si **************************** N A R R A ************************** NA Reported By: 11/17/05 Entered By.: 11/17/05 EFTA00230974 Date: 7/25/06 Time: 8:47:53 Incident Report Page: 54 Program: CMS301L Case No • 1-05-000368 vember 15, 2005, Det. and I in Royal Palm Beach. We met with seventeen-year old juvenile who was cold from which she was suffering. skis speak with her in reference to an ongoing subject she would know as Jeffrey Epstein. her, I explained that because of the fact needed to speak with her pa , on his cell phone and an• I were there to speak with her. on t e telephone and informed him I needed to s h his daughter in reference to an ongoing investigation. Mr. advised he had no problem with us speaking with his daughter. telephoned her father, Mr. explained to him I spoke with Mr. PALM BEACH POLICE DEPARTMENT (Continued) , a chool this day due to a was told that I needed investigation involving a Prior to speaking with that she is a minor, I speaking with her. She to During a sworn taped statement, stated she met Jeffrey Epstein over She was sixteen years of age and was approached by who informed her t he could make monies providing a massage to Epstein for $200.00. had ' rmed her that she would have to provide this massage topless. de the arrange ' h Epstei house. stated his assistants and took to the d she entered through a glass door that led into a kitchen. took her upstairs, to a master bedroom and master bathroom. She recalled the bathroom had a large pink couch, sauna and matchi r. Eiiiiin entered into the room wearing only a towel. and removed their clothing remaining only in thong underwear. She further stated that Epstein lay on his chest on table in selected which oils to use for the massage. Both and provided the massage on his legs, back and feet. Forty minut to the massage, Epstein turned over onto ' and requested th sage. stairs in the kitchen are . Ep ' s As got dressed, tei masturbating himself as stated he continued masturbating until he c imaxe on the towel he was wearing. When ask if he had removed the towel she stated he turned the towel around II that the opening would allow him to expose off with the towel, he instructed get dressed and met with him downstairs. with Epstein in the kitc providing the massage. . She was paid $200.00 dol i for stated she was aware that also received monies for the same thing. After he cleaned himself sage was done and to got dressed and met 7 co me she went to the house she was again approached by ask• • e wanted to return to the house to provide 'miler massage; agreed and th ements wade by for her to return to the house. stated drove her to the house and knocked on the same glass oor that leads to the kitchen area. Tiiiiiere allowed entry into the house by one of the staff members. led her upstairs to the master bedroom and EFTA00230975 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 55 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) master bathroom area. left this time to do the alone. Epstein entered the room again wearing only a towel. began removing her clothing as she did the last time she was at the house. Epstein . ted her to get naked. He lay on the table on his stomach as began massaging his legs and back. ovelitT ilis back. ted to rub his chest and he began As finished ' tein's back and legs, Epstein then turned masturbating himself. As rubbed his chest, Epstein leaned ger vi rator. He turned it on and began self at the same time. NA She desc massager as arge, Epstein for approximately assager vibrator. He then removed the and concentrated on masturbating himself. climaxe he towel again and informe done. got dressed and met with kitchen area. She received $200.00 for the massage. she never ed to the house and had no desire to house. was asked if she received any forma e training. She advised she had l training. was asked if Epstein knew her real age. stated he knew as he asked her questions about herself and hig schoo . He was aware she attended and is still attending Royal Palm Beach High School. as this was occurring. grey with a large head. stated he massage was in the said return to the The interview was concluded. I suggeste of what occurred at the Epstein house. her father as he was unaware this had occurre . I left my business card for any questions they may have. We left the area and returned to the police station. The tape was placed into evidence. Investigation Continues. Mt ****************************NARRA ************************** inform her parents stated she would tell Reported By: 11/17/05 Entered By.: A. 11/17/05 On November 15, 2005, Officer and I re e Palm Beach Gardens Mall food court s to meet with . At approxi 5:10 p.m., arrived and met with us at the food court. provided a sworn taped statement in which she stated she had been at the Epstein house over fifty times. She going to Epstein's house when she turned eighteen years was asked if she knew of the on-going investigation. stated she -was aware-there-was- an-investigation as she had been told by other girls that were interviewed. Additionally, she has had several telephone conversations with Epstein's assistants as to what had been going on during the investigation. I asked how she was introduced to Epstein. stated she did not want to disclose who brought her to the house ut she would EFTA00230976 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 56 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) respon y other questions. When I asked her what happened at the house, stated everything happened. It all began with the massages. Each time she went more things happened. She would massage Epstein and he would mastur ' She stated things escalated from there. She on Epstein and he lso use a NA mall were massager vibrator He introduced his assist with . She sta (synthetic penis) to w' to masturbate herself as Epstein and . All this was done at Epstein's direction. could ovide ex stated as she massaged any vaginal intercourse Lth him. She did admit When I asked her if there hill, billeted she did not , his assistant. stated not every time she went involved sexual favors. Sometimes she would just talk with him and get paid. I asked kit much she was paid each time she went to Epstein s residence. stated she got paid $300.00 every time she went to the She was told to bring other girls to him to provide massages. declined stating that she does what she doeiliiildid not want to introduce anyone else to do what she does. stated she had never received any formal training in providing massages. I showed IIIIII a photo line up in which was placed in position six_ reviewed the six photographs and imm ately as the person with whom she . Additionally, it was the same person she watche with Epstein. She signed the photo line-up under s photo as the person she identified. We then left the and returned to the police station. The photo line up and tape placed in to evidence. Investigation Continues... to have would utilize a strap-on lilt ****************************NARRA ************************** Reported By: 11/29/05 Entered By.: A. 12/01/05 On November 17, 2005, I received a phone message from Atty. Guy Fronstin who advised to call his cellular phone reference his client Jeffrey Epstein. I telephoned his cell phone and left a message for him to return my call. I did not receive a call back on Thursday, November 17, 2005. On Friday, November 18 2005, I retrieved another voice mail from my work phone from Mr. Fronstin advising he would not produce his client Jeffrey Epstein for any statement. Fronstin stated he had spoken with ASA Lana Belohlavek and expressed Mr. Epstein has a passion for massages. I called ASA Lana Belohlavek and confirmed that EFTA00230977 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 57 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) Fronstin had telephoned her reference this case. Although nothing was discussed, Mr. Fronstin did advise her that Epstein is very passionate about massages. I also spoke with ASA Daliah Weiss reference the previous employees, Juan and Maria Alessi. She advised that they had been served through a subpoena process server. They were both scheduled to appear on Monday November 21, 2005 at 12:00 p.m. On November 21, 2005, I met with ASA Weiss, Atty. Donnie Murrell and Juan and Maria Alessi at the State Attorney Office. ASA Weiss had requested a court reporter to be present to take the statement of the Alessi s. I spoke with Maria Alessi, in the presence of her attorney, Donnie Murrell. She advised she had worked for Epstein for eight years, from the period of 1994 through 2002. She advised she had never had any direct conversations with him. She stated it was her husband who spoke directly with Epstein. Her work consisted of doing house cleaning, shopping and other preparations when Epstein would arrive in town. Alessi stated the preparations consisted of preparing the house and bathrooms for his arrival. She advised she did view several masseuses that arrived at the house. She advised that two or three girls would come during a day and provide the massages. The girls that arrived looked young in age. Mrs. Alessi did not know any of the girls personally and were always different. She was told that when Epstein was in residence he did not want to encounter the Alessis during his stay in Palm Beach. I then spoke with Mr. Alessi in the presence of his attorney, Donnie Murrell. Mr. Alessi stated that he was employed for eleven years with Mr. Epstein. He originally was hired as a part time employee and then moved up into a full time position. His duties included everything. Alessi stated he was the house manager, driver and house maintenance person. It was his responsibility to prepare the house for Epstein s arrival. When asked about cooks or assistants, Alessi stated they traveled with Epstein on his private plane. He remembered dealing with his girlfriend, Ms. Maxwell originally and then dealt with Epstein directly. I asked Mr. Alessi about massages that occurred within the home. Mr. Alessi stated Mr. Epstein had up to three massages a day. Each masseuse that visited the house was different. Alessi stated that towards the end of his employment, the masseuses were younger and younger. When asked how young, Mr. Alessi stated they appeared to be sixteen or seventeen years of age at the most. The massages would occur in Epstein's bedroom or bathroom. There were times he recalled mat he would set upthe massage tables either in Epstein s bedroom or in his bathroom. I asked if there were things going on other than a massage. Alessi stated that there were times towards the end of his employment that he would have to wash off a massager/vibrator and a long rubber penis, which were in the sink after the massage. Additionally, he stated the bed would almost always have to be made after the massage. Alessi was never privy to what went on during the EFTA00230978 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 58 Time: 8:47:53 Incident Report Program: CMS301L Case No 1-05-000368 (Continued) massages. He was asked if he remembered any names of the girls that massaged Epstein. He tried to remember and was unable to provide any exact names of any girls. Alessi was asked about any contact with anyone from the Epstein organization. Alessi said he did speak with Mr. Epstein shortly after my initial contact with him to find out what was going on. Alessi also stated that approximately on November 11, 2005, he was contacted by a private investigator from the Law Office of Roy Black. The investigator had called him to meet with him to ascertain what he was going to tell the police. Alessi stated they met at the Carrabba s Restaurant in Boynton Beach and discussed the same questions I was asking him. I informed Mr. Alessi and Mr. Morrell that as this is an ongoing investigation and anything we discuss should be confidential. They both acknowledged the fact that the information would be kept confidential. It should be noted that a court reporter was present during the interviews and would be providing a copy of the statements to me when they become available. On November 21, 2005, I received a voice mail from Mr. Fronstin who advised he would not be making Mr. Epstein available for any statements. He did have some words that he wanted to relay on behalf of Mr. Epstein. I telephoned his office and left a message for him to return my call. On November 29, 2005, I received a call back from Mr. Fronstin who left a voice mail after hours on November 28, 2005, advising he would return my call during normal business hours to speak with me reference the case on November 29, 2005. NA iiii ****************************NARRA ************************** Reported By: 11/29/05 Entered By.: 12/01/05 On November 29, 2005, at approximately 2:30 p.m. I received a telephone call on the department issued cell phone. Mr. Fronstin stated he was calling to relay information that Mr. Epstein wished he could relay. Mr. Fronstin stated that he would not allow Mr. Epstein to speak with me at this time. He further stated that Mr. Epstein is very passionate about massages. He continued that Mr. Epstein had allegedly donated over $100,000 to the Ballet of Florida for massages. The massages are therapeutic and spiritually sound for him that is why he has had many massages. Mr. Fronstin stated he appreciated the way the investigation has not been leaked out into the media. I explained to Mr. Fronstin that it is as important to protect the innocent if the allegations are not substantiated. Mr. Fronstin was told of the allegations that the private investigators assigned to the case have been portraying themselves as police officers. Additionally, I explained that my cell phone had been called by the private investigators. Mr. Fronstin advised he was not aware of that and advised they were under the direction of Attorney Roy Black in EFTA00230979 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 59 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) Miami. Mr Fronstin further stated Epstein had originally called Mr. Dershorwitz in Boston, who recommended Roy Black in Miami, who asked Mr. Fronstin to assist. I informed him that if and when any charges would be presented I would notify him. The call was then terminated. Investigation continues. ialt **************************** N A R R A ************************** NA Reported By: 12/15/05 Entered By.: A. 12/16/05 A review of the telephone message books, which were obtained during the search warrant, was conducted in which various messages from different dates were made to Jeffrey Epstein. The telephone message books have a duplicate copy (Carbon Copy) which, once a phone message is written into the book, the top copy is then torn on the perforated edge and the carbon copy is left in the book. First names of girls, dates and telephone numbers were on the copy of the messages. I recognized various numbers and names of girls that had already been interviewed. The body of the messages was time of the day that they called for confirmation of "work." Other names and telephone numbers were located in which the body of the messages were, "I have girl,r him" or "I have 2 girls for him." These messages were taken by for Jeffrey Epstein. Based on the context of the body of the messages, I requested subpoenas for subscriber information on the telephone numbers and the time frame involved. Copies of the messages were made for evidentiary purposes. I obtained Royal Palm Beach High School yearbooks for 2005, 2004 and 2003. I first reviewed the 2005 yearbook and loca girls I had spoken with. Additionally, I located ill . Based on the corrected name spelling, I was able to 1 er to her residence in . On December 8, 2005, Det I responded to in Loxahatchee. I located at her home. She advised she is attending Roy Palm Beach High and is participating in the early release program she can maintain her part time job. As she is still a minor, I 0eft my business card to have her mother return my call to request an interview with her daughter. We then left the area. I also had previo ed the telephone number for " " and telephone numbe A subpoena had been issued for the - of elephone numbe registered to query of Mille/ ievea e ughter of and currently residing at in West Palm Beach. Det. ' and I attempted contact with with negative results. I left my business card on esting she return my call. We then responded to in West Palm Beach. I also attempted contact with Mr. with negative results. I left my business card for him to return my call. on EFTA00230980 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 60 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) 05, I received a telephone call from mother, who e aware of the on going investigation in Palm Beach. advised she was told of everything that occurred at Epstein's house involving Epstein and his staff. She advised she would allow me to question her daug out what occurred and ooperate with the investigation. provided me with cellular telephone number to schedule an appointment for an official interview. I telephoned her cellular telephone and made a tentative appointment for Monday, December 12, 2005. ilitil received a telephone call from , father of , who stated he found the business car on is door. I expla that I was conducting an investigation and needed to speak with as she maiiiiii information that could assist in the investigation. Mr. stated that his daughter no longer resides with him and has her own trailer in another trailer park. He advised he would tell her to call me. On December 12, 2005, d o ' t with schedules, arrangements were made to meet with o day, December 13, 2005 at 5:00 pm. On December and I traveled to Loxahatchee et with . During a sworn taped statement, stated that when she was sixteen years o e was taken to Epstein's house to provide a massage stated it was before Christmas last year when roached her and asked if she needed to make money for Christ stated she did and agreed to de a massage for money. made arrangement ake to the house and drove to the house to "work." stated s e could not remember the street name but would be able to drive to the street. They drove to the last house on the street and pulled in the last house on left side. They walked up the driveway and entered through a side gate which led to a kitchen door y knocked on the door and were encountered by an employee who described as a "Spanish looking lady." They informed her that they were expectedly were then encountered by a white female with long blond hair. was unable to remember the name of the white female with blond hair but knew she was Epstein's assistant. She was led upstairs by the white female who explained that there would be lotions out already and Epstein would choose the lotion he wanted her to use. She was led through a spiral staircase which led to a master bedroom iiiiiithroom. The massage table was already set up in the bathroom. described the bathroom as a large spacious bathroom with a steam room and shower beside it with a sink to the right. Zicata was intreduced to Jeff who was on the phone whthiTili enter eff was wearing a white towel and l his stomach that may massage his feet and calves. started the massage with the massage oil Jeff chose and r e is feet and calves ...Ai got off the phone and requested she massage his back as well. began rubbing his back and got to the small of his back. During the rubbing of his back Jeff asked her to get comfortable. He EFTA00230981 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 61 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) requested she remove her p d shirt. removed her shirt and pulled her pants off. stayed inilliiira and thong panties. As she finished the small of the back, Jeff then turned onto his he rub his chest and pinch his nipples. As she , Jeff asked her questions about herself. remembered telling him she attended Royal Palm Beach School. Jeff asked her if she was sexually active. Before "III answer, he also asked what sexual positions does she enjoy. sta continued from the front. snappin having Epstein area by rubbing thong panties. was uncomfortable. idn't like talking about those things. She Epstein reached up and unsnapped her bra e used had a front and asked her if she like said "no, I don't like that." towel and lay on the bed naked exposing his ouching his penis and masturbated as he explained Jeff then touched her vagina gina with his fingers on the outside of her tensed up and stated Jeff was aware that she stated that Jeff told her , "Relax, I'm not going inside." She further explained Jeff commented to her how beautiful and sexy she he ...g panties to one side and ...-sted and apologized . Pur .. .is time he ke stated he as he was masturbating. said he climaxed onto. the towel he had been previously wearing and got up from the table. Jeff told her there was $200.00 dollars for her on the dresser within the master bathroom. Jeff also her that there was an additional $100.00 that was to be given to for bringing her there to massage him. Jeff told her to leave her telephone number with his assistant as he wanted to see her again. Jeff stated his assistant would contact her to work again soon. Wit her if she ever receiiiiiiny formal massage training to which stated she did not. stated it was the only time she ever went to work for Jeff and knew happened to her was wrong. iiiiitated she no longer speaks to Iiiii because she was upset that took her there. She further stated that she had never been contacted for any additional work. The interview was terminated and we lcfI Lhe-area. Investigation Continues... **************************** N A R R A ************************** NA Reported By: 12/18/05 Entered By.: A. 12/19/05 EFTA00230982 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 62 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) On 102005 at approx 0930hrs I assisted with the execution of a search warrant at 358 El Brillo Ave, Palm Beach. Initially I was assigned to enter the residence and conduct a sweep.2l.Le premises for safety purposes. i then accompanied CSEU tech IIIIII while she photographed the exterior of the house. Once this was ciiiiiie I was assigned to search certain areas of the house with Det. as part of the search warrant. We began in the garage, searching three Mercedes Benz vehicles, a Harley Davidson motorcycle and adjacent closets in the garage. Nothing of evidentiary value was located. We then searched two closets off the kitchen area on the east side. These can best be described as pantry or storage closets. Nothing of evidentiary value was obtained. A small office with adjoining bath was then searched. In the bath area I located a phone message book with recent messages. This item was seized as evidence. Please note this bath and shower area are not used as designed but are storage areas containing a variety of items to include a gun safe in the shower and assorted household items. We then searched a bath area and closet at the base of the main stairs in the foyer. Inside the closet two massage tables were located as well as partial nude female photographs. These items were later seized as evidence. Nothing of evidentiary value was noted in the bathroom. We then searched two bedrooms upstairs on the east side of the residence. Located in the bath room of the south bedroom was penis shaped soap. Located in the bedroom of the northern bedroom was penis and vagina shaped soap as well as an adult sex toy. These items were seized as evidence. We then searched the pool cabana located in the south west corner of the property. Several photographs of nude females were seized as evidence. I was then assigned to stand by with a person I believe was Douglas Schoettle. Mr. Schoettle was in the residence at the beginning of the search warrant. He was present during the warrant service and subsequent search. I stood by with him until the search was completed and I departed the residence. I had no conversation with -Kiln regarding-the reason for our presence. Regarding seized evidence, all items were photographed in place and then collected by CSEU personnel. This concludes my involvement in this case. EFTA00230983 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 63 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) **************************** NARRA ************************** NA Reported By: 12/21/05 Entered By.: II 12/21/05 On Thursday, October 20, 2005 at approximately 0936 hours, I assisted in the execution of a search warrant located at 358 El Brillo Way, Palm Beach, Floridasildis. Jeffrey Epstein. I was instructed by Case Agent Det. , to secure all computer and media related material from the residence. Upon my arrival I was directed by Det. to a room designated as the Kitchen Staff Office. I observed a, Silver in color, CPU with the left side cover removed, exposing the CPU s hardware sitting on floor next to a glass type desk. The CPU had no discernable identifiers or features indicating a make or model. This CPU was powered off with the power cord not plugged in. The keyboard and mouse were atop the CPU. It should be noted that the CPU was not connected to a monitor, printer, or other media device. On the back Panel of the CPU, I observed an A/V card with RCA jacks attached. This type of hardware would allow audio and video to be downloaded onto the CPU s hard disk. The ends of the RCA jacks were unattached at the time of the search and no external camera was located within this room. The CPU was located on the right side of a desk that held a flat panel LCD screen. The desk also held another keyboard and mouse, indicative of a second computer; however, no other computer was found. It appeared as though a second computer had been recently removed as the cables ends from the monitor, keyboard and mouse were in the same area. A further search of the room revealed no media storage devices, i.e. CD s, Floppy Disks, Zip Disks, etc. This type of media is commonly stored in an area where computers are placed, yet no media was found. After completing a search of this room, I secured the CPU and turned all items over to the Evidence Custodian for future forensic analysis via a property receipt. I was then directed by Det. to a room designated as the Garden Room, where I observed a wooden desk facing west. The desk held a flat screen LCD monitor, keyboard, mouse, media card reader and printer; however, no CPU was located. All of the cables were removed from an area where a computer had once been. A search of the desk area revealed no signs of any media devices. Det. directed me to a third location designated as the Cabana room, which is detached from the residence and located just south of the pool. In the South East corner of the room, I observed an office type setting, with an L-shaped desk holding a flat screen LCD monitor, keyboard, mouse and printer; however, no CPU was located. All of the cables were removed from an area where a computer had once been. A search of the desk area revealed no signs of any media devices. EFTA00230984 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Case No • 1-05-000368 Page: 64 Program: CMS301L (Continued) Det. directed me to a second detached structure located on the South East corner of the property. This area of this structure was assigned with single letters to identify a particular part of the room. In the office area, designated as Room B, I observed a powered on Dell Dimension 2350, attached to an LCD flat panel monitor. The screen displayed an open Microsoft Internet Explorer browser with URL address of http://home.bellsouth.net/. I observed no other active windows in the Start panel window and photographed screen. The power cord was removed from the back of the Dell CPU and I disconnected the cable modem to prevent rem ss. At that time, the Dell CPU, marked with Serial Number was secured and turned over the evidence custodian for future forensic analysis via property receipt. I also located several media related items within Room B, which were recorded onto a property receipt and turned over the Evidence Custodians. I then responded to a Bedroom designated as Room F, where I observed a white in color CPU marked Premio. The Premio CPU was in a computer desk which held a white CRT monitor, both of which were powered on. The CRT monitor displayed a message from Norton Antivirus software, warning of an expired subscription. I observed no other active windows in the Start panel window and photographed screen. I removed the power cable from the back of the Premio CPU an all other media. The Premio CPU, marked with Serial Number , was secured and turned over the evidence custodian for future forensic analysis via property receipt. I also located several media related items within Room F, which were recorded onto a property receipt and turned over the Evidence Custodians. This concluded my participation in the search of the residence. ****************************NARRA ************************** NA Reported By: 12/21/05 Entered By.: A. 12/21/05 On December 20, 2005, I contacted ASA Daliah Weiss in an attempt to subpoena the Epstein former houseman, Alfredo Rodriguez. Rodriguez, who resides in Miami, had eluded the process servers previously and was not served the investigative subpoena. A telephone message was left as she is not available dur' of 12/19/2005. I made contact with State Attorney Inv and requested the same via telephone message. I then researched the victim's II cellular telephone subpoena data which had been received from a previous subp . I analyzed the records which depict several calls from . The telephone calls start on February 6, 2005 at 12:49 pm.; the same day which the victim and the victim's father stated the in ccurred at Epstein s irst incoming call was from residence at killail. The second incoming call from EFTA00230985 Date: 7/25/06 Time: 8:47:53 Incident Report PALM BEACH POLICE DEPARTMENT Page: 65 Program: CMS301L Case No • 1-0 - (Continued) cellular phone occurred at 1:02 pm. The call durations were one minute or ess. The ti e was within thirteen minutes apart. It should be noted that s residence was in close proximity to the v. ' 's. The next call occurred at 5:50 pm when the victim telephoned s residence. Several calls were made after the above mentioned calls both incoming and outgoing Further analysis showed no telephone calls to either cellular telephone or residence were registered prior to February 6, 2005. I also conducted an analysis on the telephone calls from The subscriber information confirmed that the number is registers to Paul A Lavery from Hialeah, Florida. The address was crossed referenced to the Office of Kiraly and Riley Private Investigators. I researched the web page www.rileykiraly.com which also showed various cases in which they assisted. I also located another web site under www.coralspringssparklandrotary.org in which Mr. Riley attended a Miami Rotary meeting and confirmed Atty. Roy Black is among his clientele. air eves and ad telephone contact with either just after I attempted to interview them, or just prior. A background was conducted on Lavery which revealed he holds a current Private Investigator License. A criminal arrest record revealed he had been previously arrested for possession of cocaine and solicitation of prostitution. i also researched the girls using www.myspace.com. This web site is a new social networking service that allows members to create unique personal profiles online in order to find and communicate with old and new friends. The site allows one to establish your own myspace.com page and decorate the page any way one wishes. I received a Cingular Wireless packet which contained a CD which ' e results of the subpoena request for verbatim calls on . An analysis will be conducted in the near future on the phone numbers called. Investigation Continues. ******t********** ,t********** N A R RA **************t*********** NA Reported By: 12/27/05 Entered By.: 12/29/05 Upon doing research on the message b ocated the identity was registered to seventeen years old and is atten•lng t vered in the search " The telephone number 's EFTA00230986 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 66 Incident Report Program: CMS301L Case No (Continued) responded to , also known as thrills locate t e Simon Yout Foundation. I located inside the foundation and informed her that I was investigatin e against Jeffrey Epstein and knew she had been at the house. started to cry and advised she had put that part of her life e in her. I explained that although she is seventeen years old I needed to inform her parents that she would be interviewed. She provided her home telephone number. I attempted contact and left voice mail messages at the house to speak with her parents. Det at about Jef rey Epstein. She advised she is • in love with Epstein and would do anything for him. She further explained that she would not speak with us about him either negative or positive. She asked us to leave her property. I informed her that although she did not wish to speak with us, I had sufficient information at this point in the investigation to know she was at Epstein's house and provided girls to Epstein to work. I also explained that prior to rrival residence I had telephone contact with he , who was told she would be interviewed. is currently seventeen years old and as a juvenile, parental notification would be required. We then left the area and returned to the police station. d I then located at her residence located in West Palm Beac . I attempted to intervi er the police station, I left another parents. I began an an one. The telephone number and the financially response• e party is Jeffrey Epstein of 457 Madison Ave. in New York City, New York. The time frame which was subpoenaed was September 2005, through October 2005. There were eighty seven pages of calls made either to the cell phone or from the cell phone. The local (561) numbers were analyzed. A spread sheet was prepared and placed into the attachment file of who was called. The unknown numbers were researched using FoneFinder.com and subpoenas were requested to determine subscriber information. This was done to Wily additional victims or witnesses. The analysis revealed that had called the victim/witnesses frequently when Epstein was in the Town of Palm Beach to "work." Thiii firms what the girls interyiewed had previously stated. would notify them when Epstein was in town and their willingness to "work." The CD was placed into evidence. Investigation Continues. ***************** ****** ***** NA N A R R A • ************************** Reported By: 1/03/06 Entered By.: 1/03/06 On December 29, 2005, I received a facsimile from National Compliance EFTA00230987 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Incident Report Page: 67 Program: CMS301L Case No • 1-05-000368 Center from Cingular Wireless was the teleR4one number for during the time frame when the victim, II, was brought to the Epstein house to "work." An analysis of the phone records, of all incoming and ou oing calls, showed that on ary 6, 2005, t to first called at t 12:50 pm (EST). The next call was made to Epstein's house in Palm Biirh, at 12:52 pm (EST). The following call was made to the victim, , at 1:01 pm (EST) and at 1:02 pm (EST). This confirms the information provided by the victim and victim's father. I photo copiedi iiecords and enlarged the page 8 of 10 to show the calls made by on February 6, 2005. tinued) e number . This ictim, •, was brought , Epstein's assistant, To this date, I have not heard from parents. I will attempt to establish contact with them during the evening hours. I received a package from Atty. Guy Fronstin, which was hand delivered at the police station. Within the package, was a letter from Alan Der were that of wo profiles. The profiles and . MySpace.com is a social networking service that allows me ers to create unique personal profiles online in order to find and communicate with old and new friends. This package was in response to a previous meeting in which Mr. Dershowitz called to assist in the investigation in providing any additional witnesses such as house employees who have been reluctant to speak with law enforcement. " I reviewed the p Mr. Deriiiiifz enclosed. , who designed her blog to be Fucking ," still attends Royal Palm Beach High School, sends and receives messages from friends which contain some profanity. Upon reviewing her friends' comments section from Myspace, most of her good friends sent messages to establish contact and invite her to go out. I then reviewed web blog which ded by Mr. Dershowitz. Ms. designed her blog to be " ' " Her blog states that her interests inclu usic, theater and weed (Marijuana). I reviewed her packet in which iill declares her love for her live￾end. She also describes using marijuana with her boyfriend The letter Mr. Dershowitz sent advised he was looking into the allegation that one of the private investigators used by the private attorneys of Epstein, attempted to impersonate or state that they were police officers from Palm Beach. 'tz advised that the investigators used to interview had "quite a distinct speech impediment", did not claim to be nor did they impersonate themselves as a police officer. This package was sent to both ASA Lana Belohlavic and ASA Daliah Weiss at the State Attorney's Office. I made telephone contact with ASA Weis package and request an interview with and Janusz Banasiak. She advised she would assist in attempting to EFTA00230988 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 68 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 contact Mr Dershowitz. (Continued) On January 3, 2006, I received a telephone call from ASA Weiss who informed me that she made telephone contact with Mr. Dershowitz. She had requested the employees be available the week of January 3, 2006. Mr. Dershowitz informed her that the assistants are out of the country and would require additional time to locate them and make them available. Investigation Continues. ****************************NAREA E ************************** NA Reported By: Entered By.: ■ 1/03/06 1/03/06 On Thursday, 03/31/05, I started conducting surveillance at 358 El Brillo. his point I observed at 1155 hours, tima bearing FL tag in Roadway, B bearing FL tag in drive, Tan Honda Civic bearing FL tag in Roadway, Black Chevy Suburban in driveway and a Black Cad lade in driveway. At 1325 Hours I observed Tan Honda Civic in roadway, Black Chevy Suburban in driv eack Caddy Escalade in drive and a White Kia ciiiiiiring FL tag . At 1615 hours I observed a Tan Honda Civic, in roadway, Black Chevy Suburban ive, Black Caddy Escalade in driveway and a White Kia car in roadway. On Friday, 04/01/05, I continued surveillance at 358 E1 o. At 1130 hours I observed a Tan Honda Civic bearing FL tag IIIIII in roadway, Black Escalade in driveway and a Tan unknown make/model bearing FL t in roadway. At 1227 hours, I observed a Tan Honda Civic in roadway, Black Caddy Escalade in driveway and a Black Chevy SUV located be • e Escalade. At 1345 hours, I observed a Tan Honda Civic in roadway and a Blac SW in driveway. At 1558 hours, I observed a Tan Honda Civic in roadway, Black Chevy SW in driveway, Black Caddy Escalade in driveway and a dark unknown model/make car parked in garage. On Saturday, 04/02/05, I continued surveillance at 35 rillo. At 0713 hours, I observed a Red Explorer bearing FL tag in roadway and a Black Caddy scalade in driveway. At 0814 hours, I observed a roadway, Black Caddy Escalade in driveway and a nda Civic At 0952 hours, I observed a Red Explorer in roadway, Black Caddy Escalade in driveway, Tan Honda Civic in roadway and also a Grey unknown make/model with a B.M in trunk retrieving landscaping tools. At 1155 hours, I observed a Grey Camaro bearing FL tag , parking in the roadway in front of 358 El Brillo. A W/F, blond hair, teens to early 20's, thin and tall wearing a white tank top and short blue jean shorts, exited the vehicle annulled to the rear of the house. I also observed a Red Explorer IIII in roadway, Tan Honda Civic in roadway and a Black Caddy Escalade in driveway. At 1310 hours, I Red Explorer EFTA00230989 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 69 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) observed a Red Explorer W/F driver lea e area, Tan subcompact on roadway and a Red Neon bearing FL tag Then observed 3 W/Fs, approximately 16 to 18 years of age jogging. All 3 females ran into the driveway. There were 2 with blond hair and one brown hair. On Sunday, 04/03/05, I continued surveil at 358 El Brillo. At 0719 hours I observed a Tan Honda Civic in roadway and ck Caddy Escalade. At 0934 hours, I observed a Tan Honda Civic in roadway and a Black Caddy Escalade reway. At 1057 hours I observed only the Tan Honda Civic On Tuesday, 04/05/05, I continued sure ce at 358 El Brillo. At 1052 hours, I observed a lorer in roadway, a Green Expl Baring FL tag in roadw Grey Altima bearing FL tag in roadway, White Ford Truck in roadway, Black Mercedes in driveway being washed by a B M and an unknown dark car parked in the garage. At 1059 hours a Blue Chevy Suburban drove to the house of 358 El Brillo and p in the driveway. At 1119 hours, I observed the White Fort Truck leave the area and the drive was the pool man. At 1126 hours, I observed a Grey unknown make/model car park in roadway. W/M got out of the car and walked to a house on the south side of El Brillo. At 1406 hours, I observed a Red Explorer parked on roadway and a large white box truck parked behind the surveillance suburban. ***** ***** **** ***** *********NARRATIVE # 32 ************************** NA Reported By: C . 1/03/06 Entered By.: A. 1/03/06 On 03/31/05, at approximately 1500 hours while conducting surveillance at 358 El Brillo, I observed a Black Cadillac Escalade, unknown tag, a Chevrolet Suburban, unknown tag, a Black Mercedes $600 FL tag parked in the east dri ext to the 3-car garage. There was a Tan Honda Civic FL tag parked on the street in front of the residence. At approximately 1700 hours, I observed the Black Suburban, Black Escalade, Black Mercedes and Tan Honda Civic parked in the same place. At 1750 hours, there was no change in vehicles. At 1840 hours, I observed the Black Escalade, Black S an d Black Mercedes along with a Silver Hyundai Accent FL tag parked_in_the east driveway and a Red Ford Explorer FL parked on the street in front of the residence. At 2000 hours, I observed the Black Escalade, Black Suburban parked in the ease driveway and the Red Explorer and Tan Civic parked on the street. On Friday, 04/01/05 at approximately 1700 hours, I observed the Black EFTA00230990 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 70 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) Escalade and Black Suburban parked in the east driveway and the Tan Honda Civic parked on the street in front of the residence. At 1820 hours, I observed the S and Civic in the same place and a Gold Chevrolet Camaro FL tag parked on the street in front of the residence. At 2250 there was no change. At 2330, I observed the Black Escalade parked in the driveway and the Red Explorer parked on the street in front of the residence. On Saturday, 04/02/05 at approximately 1700 hours, I observed a Black Escalade, unknown tag, parked in the driveway and a Tan Honda Civic FL tag X98AMP parked in the street in front of the residence. At 1805 hours the Escala Civic were in the same position and the Black Mercedes FL tag was also parked in the east driveway. At 1920 hours the Escalade and Civic were the only vehicles and both were in the same position. At 2030 hours and 2145 hours there were no vehicles observed. At 2115 hours, I ed a Black Mercedes, 4-door parked in the east driveway FL tag At 2300 hours, 2350 hours and 0045 hours, the Black Mercedes was the only vehicle observed. **************************** NARRA ************************** NA Reported By: 1/05/06 Entered By.: 1/05/06 I made contact with Mr. , father of , who was told that I wished to interview his daughter. Mr. stated he was aware and had spoken with his daughter about the incident. He stated that his daughter had previously told him she was hired to model lingerie at a Palm Beach mansion. Mr. stated he kn ing else about what she did when she went to "work." Mr. advised he would cooperate with the investigation and make his daughter availa interviews. I asked if she was available for an interview, stated she was not at home at the mome informed him I wou make contact with her at a later time. Mr. expressed his interest in the resolution in this matter as he stated this information has affected his daughter emotionally. On January 4, 2005, I acquired the subpoenas from the State Attorney's Office for Cingular Wireless, Metro PCS, Verizon, Bell South ' ions and Sprint for the unknown telephone numbers from cellular telephone. The subpoenas were sent to the respective telephone carriers for subscriber information. I received a -teIeplibne call from State Attorney's Office, who informed me that the former houseman for Jeffrey Epstein, Alfredo Rodriguez, was present at the State Attorney's Office for an interview. Rodriguez was issued an investigative subpoena for an interview on the on-goings at Epstein's house during his employ. I responded to the State Attorney's Office and encountered Mr. Rodriguez waiting in the lobby. I brought Mr. Rodriguez to the interview room. EFTA00230991 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 71 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) During a sworn taped statement, Mr. Rodriguez stated he was employed by Jeffrey Epstein for approximately six months. He was referred by associates and his employment lasted the months of November 2004 through May 2005. His responsibilities as house manager included being the butler, chauffer, chef, houseman, run errands for Mr. Epstein and provide for Epstein's guests. Rodriguez advised he had very limited contact with Mr. Epstein. If Rodriguez needed to relay a message to Mr. Epstein, he would have to notify Epstein's secretary "Leslie" in York City, who would then notify Epstein's personal assistant, who would relay the message to Epstein. Rodriguez stated Epstein id not want to see or hear the staff when he was in residence. I asked Rodriguez if Epstein received many guests during his stay in Palm Beach. Rodriguez advised he had many guests. I asked specifically about masseuses coming to the house. Rodriguez stated he would have two massages a day. Epstein would have one massage in the morning and one massage in the afternoon everyday he was in residence. Rodriguez stated he wouldkginformed to expect someone and make them comfortable until either IIIII or Epstein would meet with them. Rodriguez stated once the masseuses would arrive, he would allow them entry into the kitchen area and offer the ething to drink or eat. They would then be encountered by either or Epstein. They would be taken upstairs to provide the massage. I asked Rodriguez if any of the masseuses appeared young in age. He advised he didn't ask their ages but felt they were very young. Rodriguez stated they ate like his own daughter who is in high school. Rodriguez stated they would eat tons of cereal and drink milk all the time. Rodriguez stated the girls that would come appeared to be too young to be masseuses. He stated one time under Epstein's direction, he delivered a dozen roses to Royal Palm Beach High School for one of the girls that came to provide a massage. He knew the girls were still in high school and were of high school age. I asked Rodriguez about the massages. He felt there was a lot more going on than just massages. He would clean Mr. Epstein's bedroom after the alleged massages and would discover massager/vibrators and sex toys scattered on the floor. He also said he would wipe down the vibrators and sex toys and put them away in an armoire. He described the armoire as a small wood armoire which was on the wall close to Epstein's bed. Epstein ordered Rodriguez to go to the Dollar r t a car and rent a car for the same girl he brought the roses to, that she could drive her self to Epstein's house without incident. RoPariguez said _the girl__ always needed rides to and from the house. Rodriguez referred himself as a "human ATM machine" and was ordered by Epstein to maintain a minimum balance of $2,000 dollars on him at all times. When a girl would come by the house and Mr. Epstein was either not in residence or was not at home at the time, Rodriguez was to provide the girl (masseuse) several hundred dollars for their time and to notify Epstein the amount they were given. Epstein also ordered Rodriguez to EFTA00230992 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 72 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) purchase several gifts and provide them as tips to the girls. I asked what kind of gifts. Rodriguez stated he purchased IPODS, jewelry, anything the girls would want. Rodriguez stated the amount of girls that came to the house was approximately fifteen. Each of the girls knew each other and all seemed to know at Royal Palm Beach High School who Mr. Epstein was. When asked to identify these girls, Rodriguez stated he could not at the moment but knew he wrote their names down on a journal he kept during his employ with Mr. Epstein. He kept a journal in the event he needed to explain either to Mr. Epstein or his assistants what was done at the house or who visited the house as he stated he was in-charge of Mr. Epstein's personal security while in Palm Beach. I informed him I would need to view this journal to which he stated he would research the book and contact me to provide the book. The interview was concluded and left the area. i returned back to the police station where the micro cassette was placed into evidence. At approximately 7:20 pm, I was notified Rodriguez located the journal and would call me on January 5, 2005 to provide the journal. Investigation Continuesa& lalt **************************** N A R R A ************************** NA Reported By: 1/09/06 Entered By.: A. 1/10/06 On January 5, 2006, I attempted to meet with Alfredo Rodriguez to recover the folder or journal in which he kept the notes that were given to him during his employ with Mr. Jeffrey Epstein. He kept this folder to justify what he did during his employ should the need arise to justify what occurred with the monies he had to keep or any questions as to the petty cash he withdrew from the household account from the bank. At approximately 10:00 pm, I attempted contact with Mr. Rodriguez and discovered he was assisting his wife at her place of employment and would not be able to meet with me. Mr. Rodriguez stated he would meet with me on January 6, 2006, in Broward County, in the morning hours. On January 6, 2006, at approximately 9:00 am, I received a telephone call from Mr. Rodriguez who advised he had the file in hand and would be traveling northbound to meet with me in Broward County. At 10:50 am, I met with Alfredo Rodriguez at the parking lot of Bank of America in Boca Raton on Yamato Road and Military Trail (known as the Polo Center). Rodriguez produced a green folder which contained documents, a note with Mr. Epstein's stationary with direction toagliger bucket of roses to Royal Palm Beach High -Salool after (iill) high school drama ( or e. Also in that same note was direction to rent a car for ) and direction to extend the rental contract. I returned to the Palm Beach Police Station and placed the folder into evidence. I received a fax from Verizon from the subpoena request sent on EFTA00230993 Date: 7/25/06 Time: 8:47:53 Incident Report PALM BEACH POLICE DEPARTMENT Page: 73 Program: CMS301L Case No • 1-05-000368 01-04-06, for telephone number registered to Dr Perry Bard, from West chiropractor and has an office located Palm Beach. The cellular number is Dr number. (Continued) The phone number is Palm Beach. Dr. Bard is a 4275 Okeechobee Blvd in West Bard's personal cellular On January 9, 2006, Det. and I tray Palm Beach Gardens in an attempt to locate , who been previously seen on the property and identified through her Florida Drivers License and Florida license Plate. A business card was left for her to return my Youth Foundation and located speak with us and in a private taped statement. in had travelled o the Simon agreed to room within the school provided us a During the statement, advised that when she was fifteen or sixteen yea a en to Jeffrey Epstein's house by her associate, stated this occurred late May 2004 or early June 2004. She was told she could model lingerie for money for a wealthy Palm Beacher. She remembered they traveled by yellow cab from their residence in West Palm Beach to Epstein's house. She remembered encountering Epstein at the front door during the evening hours. He introduced himself and brought them into the kitchen II that the ould prepare somethin em to eat. After having a meal, and Epstein brought upstairs to a master bedroom which had a large bathroom. She observed a large style shower, sauna and there was a large massage bed also in the bathroom. Epstein iiiiiid a room within the bathroom and came out wearing oniiiiiiiwel. said they would p a massage on his feet. her this was part of asked why they are doing this. told tine and told her to rub his comfortable. Epstein's direction, by herself. Epstein told to get comfort her blouse and pants and stayed in her panties. stated she was not wearing a bra. She believed she was g panties. onto his back and heaan and began stein Epstein•• to get calvea and feet. At left the room leaving there removed ; he but stayed on anties. During the first massage, she stated Epstein was and began masturbating himself at the same time. He put his hands_ under the dowel and______ as to ' if however she never saw his penis. She continued until he grabbed her and pulled her closer to him. He appeared to have climaxed because after he pulled her closer to him the massage was over. Epstein had told her that there was two hundred dollars for her on the dresser. He told her that she could not teliiiiiiie what happened at the house or bad things could happen. stated she went to Epstein's house three EFTA00230994 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 74 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) or four times total. was very scared and felt very nervous. She knew because of Epstein's money he was powerful. After the massage, Epstein ordered his houseman at the time to drive the girls home. The employee was to drop off the girls at their house and watch them go inside their house. IIIIIII could not er who the houseman was. She stated Epstein and his assistant would call her at her father's house to arrange for her to come and "work." She advised 'me she returned to the house, Epstein would do the same thing. stated it was a routine with Epstein. She es. He would then turn over and begin to . The only differ one wit out panties. Epstein's fingers would as he would masturbate and finally climax and the massage woul be over. She was paid $200.00 each time she went. Each time she went she was reminded not to speak of what happened at the house and that she would be co ed again. She began to purposely miss the calls when ' or Epstein would call her. She once brought a friend, " " un no work for Epstein. She was paid $200.00 MOor ringing nailliii stated she no longer retuned to work for Epstein. She a so stated . wanted to notify the police of what happened at the house. stated she was scared of what could have happened to her or her family if she notified authorities. On January 10, 2006, I received the results BellSouth Telecommunicatio number is assigned to Mr. Beach Gardens. I also received t confirmed the money order sent to from Jeffrey Epstein in New York City. The "wire" was sent by Jeffrey Epstein of 457 Madison Ave in New York City on December 23, 2004 at 12125 pm. t of $222.00 was charged to Epstein's credit card II that ncould receive $200.00 in Royal Palm Beach. The twenty-two dollars was for processing and local fees to send ey via Western Union. A copy of the check presented to attached to the receipt of the wire. This confirmed w at advised she received as a Christmas bonus from Epstein. from t from . The 's father in Palm estern Union which Investigation continues. **************************** NA l NARRA ************************** Reported By: 1/10/06 Entered By.: A. 1/10/06 I received and reviewed the Cingular Wireless results from the cribe and , is assigned to Janusz Banasiak Epstein of 457 Madison Ave in New York City. houseman/house mans El Brillo Way The second number, , is assigned for telephone numbers The first number, in care of Jeffrey Banasiak is the current in 3480. to of EFTA00230995 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 75 Program: CMS301L Case iiIIIIIIIIiiiiI5-000368 nued) in West Palm Beach. Research conducted on revealed she is a licensed Massage 'stile Florida conditional/active license number . had been previously arrested for battery / unwanted touching and DUI. Requests for copies of the reports involving the arrests were reques Palm Beach County Sheriff's Office. The last number is assigned to Thomas Rofrano of 9850 Alt AlA in Palm Beach Gardens. Research on Mr. Rofrano, revealed that he is a Florida Chiropractic Physician. Vehicles that were previously documented on the property while surveillance was being conducted were rese I determined a tan Chevrolet Camaro, bearing Florida license , was seen on the property in which a young white female was seen entering the Epstein property. Res onducted which reveal at the vehicle is ' to and La_Mr. has two daughters, is currently residing in Connecticut and residing with her father in Lake Worth. Research on revealed she was recently involved in a traffic stop in Lake Clarke Shores in May 19, 2005. A request to discover any information from the stop was requested. I spoke with ASA Daliah Weiss who informed me that Janusz Banasiak will be available for an interview tomorrow at the State Attorney's Office in West Palm Beach at 1:30 pm. I informed her that I would be at her office for the interview. **************************** N A R R A 35_************************** NA Reported By: MI 1/23/06 Entered By.: A. 1/23/06 2006, Det. and I at in Palm Beach Gardens. h was identified as a licensed massage therapist who had previously b n on Epstein's property when physical surveillance was done. was told of the on going investigation and I felt she may hav information pertaining to the case. During a sworn taped statement, stated she met Epstein three years ago when Ghaline Maxwell approached her while she was attending Palm Beach Atlantic College to work around Epstein's house. Maxwell had told her that they needed irls to work at the house to answer phones and run errands. accepted the job Sian working at Epstein's house on El Brillo in Palm Beach. stated it was a part time job during the time she went to Palm Beach Atlantic College. She continued going to Epstein's ho would be notified when Epstein would travel to Palm advised she would be notified by Maxwell, Epstei , his assistant, when he would travel to Palm Beach. stated she began providing massages to Epstein before she became a massage limpli o licontin iving massages noti liow2sti.cnd o to and his what occurred during the massages. Ili, stated as she was twenty EFTA00230996 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 76 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) three years old when she met Epstein, anything that happened was between two consenting adults. I explained to her that she was not in any trouble however as t of this investigation, I needed to ask certain questions. stated that there were times that Epstein would ask her to per orm uring the massage.Iiiiiiiuld instruct her to rub his nipples as he masturbated himself. stated she felt "grossed" ab i behavior but as she was getting paid, she just continued. also advised she would on occasion perform the massages naked. Epstein would on occasion, utilize the r/massager on her vagina area when she performed the massages. explained that Epstein never exposed himself to her as he maintained himself covered under the towel he would be wearing. When Epstein would masturbate he would be covered. I asked if Epstein. Epstein took She received ever received any gifts, or any gratuities from advised aside from being paid well, she advised care of her tuition from Palm Beach Atlantic College. a rental car for a week when her scooter broke down. Additionally she received other gifts from Epstein. Epstein also recommended her to another client who resides at Breakers Row in Palm Beach. The client she was referred to was "Glenn" unknown last name, and his wife, who she provided a massages to. The statement was concluded and placed into evidence upon our return to the Palm Beach Police Department. While at the police station, I researched Florida tag which was also previously seen on the property when there was physical e being done at the property. The vehicleiiiiiegistered to r. and the „ of Lake Worth, Florida. vehicle revealed that his daughter, had been driving ' the vehicle and was cited for unlawful speed in Lake Clark Sho, eh is a tan, Camaro, 2-doo date o •' th, , resides at space page called . In her web page, shows various photos of photographed at a beach. An interview is forthcoming. A review of the video disks which was extracted at the Palm Beach County Sheriff's Office Computer Crime Unit revealed that only one hidden camera was functional at the time. Several image ' work' ii"iit e were seen. Additional footage of and was seen. There was other footage of females seen. The identity of the females is unknown at this time, until such time as I meet with certain—females to show the video footage to confiiilifiliiiirct, • ' n the video. At this time it appears that and are seen sitting with Epstein beside his desk in the evening hours. Due to poor lighting, a direct confirmation cannot be made at this time. Inv. Continues. EFTA00230997 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 77 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 **************************** N A R R A NA Reported By: Entered By.: (Continued) MI ************************** 1/30/06 II 1/30/06 anuary 25, 2006, Det nde in Lake Worth and met with ilii, stated last year, when she was seventeen e, met Jeffrey Epstein through her former roo a was allegedly dating Epstein at the time. and once cohabitated together when they modeled. explain called her on her telephone dvised her that s e was in Palm Beach and requested to slit made arrangements to m ith . at Ep 's house. arrived and met Epstein and went to Palm Beach Mall togetherand went shopping. advised that and she had received money from Epstein to go to the mall. They visited Victoria's Secret and purchased undergarments from the store utilizing s given by Epstein. advised she purchased one item and purchase various items. The money used to purchase the items was the money given by Epstein. a continued shopping and having a day together. stated explained how she and Epstein been dat ach other and he has een paying all of her bills. claimed advised they met in New York and had been dating ever since. They later returned to Epstei ome and encountered Epstein. He had a brief conversation with out her modeling career. He knew of her modeling career from . He requested to see her modeling olio and explaine that he coulgjaglp her with modeling jobs. had her book with her to show IIIII and showed the book to E n. He commented negatively about her photographs and portfolio. felt uncomfortable with the comments made as she had been working with other professional modeling companies who had offered her work from her photograph stein requested to see what was purchased at the mall. took out the undergarments which were purchased. She immediately showed E ' different s urchased. Epstein then requested to view what purchased. was reluctant to show the outfit however since it was Epstein's money that purchased the i she pulled ' t of the bag. Epstein asked her to try it on. looked at who told her "yeah, try it on." Feeling compelled to try the un ergarment outfit on; she went to another room and put on the bra and panty set. She walked out to the living room where they were sitting, and modeled the suit. She then ack into the other room and chan ack into her clothes. returned into the room andliiii she would be going home. scheduled another day for to return for massages with her. stated within t ame week, she returned to meet with and have a massage. had told her that she would be unable to with her as she would be going on a bike ride with Epstein. explained she could stay at the house and take advantage of the massage. EFTA00230998 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 78 Incident Report Program: CMS301L Case 1-05-000368 (Continued) stated she met with an unknown ma therapist and had the table already set up in a guest room. removed her clothing, leaving he ties on, and wrapped herself with a towel for the massage. remembered that the door to the guest room was closed but not loc ed. As the therapist was working ack, the door was opened by Epstein and entered into the room. was trying to conceal herself as Epstein was talking to her a out his opractic session. Epstein told turn over onto her back. eas Epstein as he stated Epstein " removed her self the table, got dressed and left occasions to to her back to Epstein's house to which further stated had attempted to call her " 'm busy." advised she has not had contact with either Jeffrey Epstein. It should be noted that her mother, was present during the interview. The interview was and we thanked them her for their time. the house. several concluded **************************** N A R R A NA Reported By: Entered By.: A. On 0 ade telephone contact with at is a licensed massag apist who frequented the home of Jeffrey Epstein. Ms. has been meet with me in Palm Beach County, and because she lives and Port cie, a telephone interview was conducted. I explained to Ms. that there was an on going investigation involving Jeffrey Epstein. stated she knows Epstein and has been approximately three years. Epstein has paid Massages (Deep Tissue) on him and other guests. approximately three year ago she met Ghislaine Maxwe Epstein through a mutuiiiiiiend. Epstein and Maxwell were looking for a massage therapist. stated si t time, she is notified when Epstein is coming to Palm Beach. d she comes to his house and provides the massage or massages explained she has also massaged his guests and assistants. continued that she is paid $100.00 and hour for the massage. I asked if anything occ during the massage that would have made her feel uncomfortable. stated she only provided massages lind that was it. -She never was approached for anything else. I iced if Epstein ever asked her to rub his chest she sta., would not rub his chest as that is not part of her massage. explained that she was not Epstein's type. The girls she would mil Epstein's house were very thin, beautiful and without tattoos. explained she has several tattoos that are visible. Maxwell and Epstein have commented negatively about her tattoos previously when she has provided massages. 1/31/06 1/31/06 had unable to works in ed by him for perform Swedish explained that and Jeffrey EFTA00230999 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 79 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) stated she only provided massages for Epstein andliiii, associates and nothing happened during those massages. stated as she does Swedish style massages, the patient is usually sore after the massages. I thanked her for her assistance and the interview was concluded at this time. I recei ile from T-Mobile Cellular service on telephone number , which is assigned to David Rodgers, pilot for Mr. Epstein, who resides in Lake Wo s' telephone number was dialed on several occasions by . A background on Rodgers indicated he has a valid FAA pi of icense First Class for the Southern FAA Region. Rodgers has another historical FAA license for Airline Transport Pilot. Investigation Continues. NA all ****************************NARRA ************************** Reported By: 2/14/06 Entered By.: A. 2/16/06 uary 3, 2006, I had made arrangements to meet with at the Palm Beac 'on. At approximately 1:00pm, and her friend, arrived at the police station. During an interview with , she stated she met Epstein when she turned eighteen years old and was brought to Epstein's house to provide She advised this occurred on May of 2005. She advised informed her if she wanted to provide a massage for $200.00. eed and was brought to Epstein's house to provide a massage. stated she to the house on many occasions during the massage sessions. also state uld remove her clothing to provide the massage on Epstein. advised Epstein would pay her $300.00 to rub his back, legs and chest. During the massages, Epstein would mast ' she rubbed his chest. her if Epstein ever during the massages. replie n " I askegIImher • ' or massaged her vagina. stated . I asked her i r penetrated her with either his stated that during a massage he she massaged him. She stated this occurred one time only. stated the massage over when Epstein would climax onto a towel. I asked if she ha al massage training to which she replied that she did not. then asked if she ever brought anyone to the house to "work." stated she brought two people to the house. She advis eceived money-for-bringing e house to "w her friend stated she brought a gir Pectin-eat and was still wa r in the lobby of the police station. I thanked o her time and her cooperation and escorted her to the lobby. I asked Ms if I could speak with her about this investigation. I EFTA00231000 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 80 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) brought her to the interview room and explained to her that I was conducting an investigation on Jeffrey Epstein and felt she may have information " o the investigation. Ms identified herself as and resides in Wellington, Florida. She advised approximately a year lire was brought to Epstein's house to provide a massage for money. stated she ded to make money and felt it was a quick way some money. stated she was brought to the house by and was intro uced to Epstein and his assistant. She was broug t to his main bathroom and provi a massage. I as v aked. ted she did. She I asked if Epstein touched er uring t e massage. id not, however he did masturbate himself as she . Once he climaxe e massage was over. She was pal her money and left the area. advised it occurred one time and she n returned to Epstein's ouse. The interview was concluded and was escorted to the lobby. I located a telephone number for pted to contact ligL2n several occasions. I called and spoke with Ms. who advised she would speak with me in Deerfield Beach where she resides. Due to a scheduling conflict, we were unable to meet. I informed her I would contact her to schedule another appointment to speak with her about this investigation. I have attempted to meet with her and make telephone contact with negative results. On February 13, 2006, I met with David Rodgers at 7318 Heathley Drive in Lake Worth. Rodgers was identified as Epstein's pilot. I spoke with Rodgers who advised he has been employed with Epstein since 1991. He flies both planes for Epstein depending where he wants to fly to. Rodgers was asked about passengers in the plane heLliaa. Rodgers stated unless Epstein flew to his island off of St there would be no way of knowing who the passengers were. I menti ent flight to Ohio, where Rodgers flew to Ohio to pick up Rodgers s he recalled flying on several occasions and did remember . Rodgers stated once he is in the cockpit, he does not know who the passengers are. When he prepares the passenger mani e lists Epstein and his assistants he knows by name, and . Rodgers stated he would list either female or male passengers on the manifests only to keep a count on the passengers. Mrs. Rodgers came into the living room and recommended that her husband consult with an attorney. Mr. Rodgers agreed he would speak with the family attorney to inform him of this questioning. I explained to Mr. Odgers that he was not the suspect ih this investigation and ceased all questions. Based on the fact Rodgers could not advise who passengers were in the plane, I then left the area. I attempted to locate at in Wellington. I left my business card for her to return my call. February 14, 2006, at 12:06 pm, I received a call back from Ms. EFTA00231001 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 81 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-00036Ammm. (Continued) on my ' • Ms IIIII left her telephone number for a return call . I left her a message to return call. Investigation Continues.. Mt ***************** ******* ****NARRA ************************** NA Reported By: 2/21/06 Entered By.: A. 2/22/06 On February 15, 2006, I made telephone contact with who provided dire • could locate her. Det I ded to in La rk to meet with i Upon my arrival, I met with in the parking lot directly behind MAACO Auto Painting. She was advised I was there to speak with her about an 2againg investigation that concerned Jeffrey Epstein in Palm Beach. IIIII stated she knows Epstein very well and did not want to speak with me about Mr. Epstein. She was very fond of Epstein and did not want to speak with me about anything concerning Jeffrey Epstein. I explained to her that she was seen at the house and I would like to speak with her. She stated she knew there was an investigation and that I had spoken with other iiiiie and therefore I should know what happened at Epstein's house. ended the conversation and ack into her boyfriends business, Blanton Automotive. Det and I left the area and returned to the police station. Investigation continues. ****************************NARRA ************************** NA Reported By: 4/10/06 Entered By.: 4/10/06 A Grand Jury Session was requested during the month of February 2006, in which all the girls that had been interviewed would have been called to testify before the Grand Jury to seek an indictment against Jeffrey Epstein. Due to subsequent meetings with the State Attorney's Office and Defense Attorney Alan Dershowitz the Grand Jury was postponed until a later time. Dershowitz had provided a package of material on the main victims in this case in which they appear on myspace.com and speak about alcohol use and some marijuana use. The State Attorney's Office wanted time to review the material. I requested additional subpoenas from the State Attorney's Office in which I requested information from Dollar Rent a Car and Jet Aviation. The lfiformation requested from Dolma Rent a Car was for the rented vehicle by Alfredo Rodriguez while under the employ of Epstein for one of the victims. The other subpoena requested was for Jet Aviation for dates and times when Epstein's planes were in Palm Beach County. I continued to research other names that were acquired either from interviews or intelligence gathered during the investigation. I EFTA00231002 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Incident Report Page: 82 Program: CMS301L lila Case No. . ed) in Royal Palm Beach. I responded (Co in Royal Palm Beach. During the interview stated she knew I would be speaking with her. stated she ' introduced to Epstein when she turned eighteen years old. stated she was sure of her age as it was her senior year in Royal Palm Beach High School. She advised she was brought there to make money and was told she would have to provide a massage to this each guy. She remembered she met Epstein and his assistant in itchen area. She stated she was taklajay one of her friends, She stated she went upstairs with while got ready for the massage. He exited his bathroom naked and . IIIII • ound. Epstein asked her if being naked offended her. stated it made her omf able. Epstein then put on a towel and lay on the table. stated she rubbed his back and e stated she had no massage training or experience. buttocks. s during the massage, • ouch her pulled away as . She told him again she was uncomfortable with him touching her. Epstein then cut the massage short and became upset with her. Epstein ' $200.00 for the massage and told her to leave the house. ed to the house. She did advise of time she went with , however she waited in the car for she did not want to go into the house. clusion of visit with Epstein they left the area. stated she had heard from other girls that have gone to the house t at Epstein now required them to do the massage naked and allow him to touch the ' 'r private areas for monies. The interview was concluded as did not have any other information to provide. I then learned from the original victim, II, the defense attorney had learned of her identity. I spoke with the father of the victim, who stated there has been a private investigator on his house photographing his family and chas itors who come to the house. He provided a Florida License of . This vehicle is registered to Ivan Robles of West Palm Beach. Robles is a private investigator intern who is licensed by the state. I informed the State Attorney's Office of the above information. I received the Grand Jury subpoenas to be delivered to three victims for a Grand Jury session to be held on April 18, through April 20, 2006. Investigation continues. Ili tt*********** ****** rtrt*1-**It N -A--R -R- A *4************* ***** ****** NA Reported By: 4/14/06 Entered By.: A. 4/18/06 The Grand Jury Subpoenas were personally served to the individuals they were issued to. On April 5, 006, at approximately 7:30 p.m., I personally served the parents of II, who had informed me that the private investigators were still photographing the family. On April EFTA00231003 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 83 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) 10, 2006, at approximately 2:30 p.m., I served II at her Issidence in Royal Palm Beach. The subpoena was given to her mother, III. I learned through one of the victims (*) that she was personally contacted through a.gource that has maintained contact with Epstein. The source assured II she would receive monetary comp sation for her assistance in not cooperating with law enforcement. II also stated she was told, "Those who help him wile compensated and those who hurt him will be dealt with." I told III that tampering with a witness/victim is an arrestable offense an ery serious. I asked her who approached her during this encounter. II originally was reluctant to provide the name of the person who approached her to offer her not to testify because she felt they were still friends. On April 11, 2006, Det I traveled e, Florida with the victim, identified , W/F, as the person w o approached her in Rayal Palm Beach while want to pursue the intimidation charges on was III o slated she did not II she was home during Spring Break in March 2006. concerned that the defense attorney was given a copy of the report as certain things she had told me in confidence were repeated to her by . Prior to our departure, the victim was given a copy of her subpoena for the Grand Jury which was scheduled to commence April 18, 2006. Upon our return from Tallahassee, I notified the State Attorney's Office of what was told to me. I also notified them that the subpoenas were delivered to the witnesses and they would be calling for arrangements for the date and time needed for the Grand Jury. I spoke with ASA Weiss and informed her of the possible intimidation by the defense. On April 13, and April 14, 2006 I attempted contact on several occasions with ASA Weiss and ASA Belohlavic to ascertain when the victims needed to report for Grand Jury testimony. Messages were left on their voicemail. On April 17, 2006, during the hours of 9:00 am and 11:30 am, I again left messages for ASA Weiss and ASA Belohlavic for either of them to return my call as I had not heard from the State Attorney's Office as to the time and date of the Grand Jury. At approximately 12:30 pm, I went to the State Attorney's Office and located ASA Weiss and ASA Belohlavic in their offices. I entered ASA Belohlavic's office who informed me that she was going to return my call. She explained that an offer was made to the defense, Atty Guy Fronstin and Atty Alan Dershowitz. The offer is 1 count of Agg_ Assault with intent to commit a felony,-TiVe years pra5rfiOn, with adjudication withheld. Epstein would have to submit to psychiatric/sexual evaluation and no unsupervised visits with minors. When asked about the all the other victims, ASAmSelohlavic stated that was the only offer made as to one victim, II. ASA Belohlavic cell phone rang and went to voice mail. She checked her voice mail and played the message on speaker. The caller identified himself as EFTA00231004 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 84 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) Atty Guy Fronstin and acknowledged the deal made between them. Fronstin stated in the message, he spoke with his client, Jeffrey Epstein, and agreed to the deal. Fronstin asked to call off the grand jury as they would accept this deal. Belohlavic stated a probable cause would be needed to book Epstein in the county jail and would let me know as to when it would be needed. I explained my disapproval of the deal and not being consulted prior to the deal being offered. However I expressed that was only my opinion and the final approval come from the Chief of Police. She explained to have Chief call Barry Krisher about the deal. I left the area and returned to the police station where I briefed the Chief about the deal offered. I checked my voice mail me ges and discovered a message from II, stepmother for the victim II. She was calling because the State Attorney's Office still had not returned any of her calls as to when they are needed for this case. I then called ASA Belohlavic's office and left messages for her to call the victims on this case and explained to them what the State Attorney's Office had done. On April 17, oximately 4:30 pm, State Attorney Investigator called to officially notify me of the cancellation of t e Grand Jury. He requested I contact the victims that ha ved to appear, to notify them of the cancellation. advised that as this Grand Jury session was called based on the State Attorney's Office decision to have the victims heard by the Grand Jury that I felt it was the States Attorney's Office responsibility to contact the victims and advise them of the reason they were no longer needed. NA Mk ****************************NARRA ********** ****** ********** Reported By: 5/04/06 Entered By.: 5/04/06 As I had not received any contact from anyone at the State Attorney's Office, on May 1, 2006, I prepared three arrest warrant requests and submitted them to the State Attorney's Office. The packages were delivered to the Crimes against Children Unit in care of ASA Lana Belohlavek. Jeffrey Epstein's arrest warrant was requested for 4 counts of Unlawful Sexual activity wi minors and one count of Lewd and Lascivious Molestation. , Epstein's assistant's, arrest warrant request was for 4 counts of Principal in the 1st degree Unlawful Sexual activity with certain minors and one • ipal in the 1st degree Lewd and Larivious Molestai- inn arrest warrant request was for Lewd and Lascivious Acts on a victim under 16 years of age. The receipt of delivery was signed and brought back to the records division at the police department. On May 3, 2006, at approximately 2:54 pm, I received a telephone call from ASA Daliah Weiss on my cellular telephone. ASA Weiss advised she EFTA00231005 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 85 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) has been taken off the Jeffrey Epstein case because her husband is employed with Attorney Jack Goldberger. Attorney Goldberger is the attorney of record for Jeffrey Epstein. His previous attorney, Guy Fronstin, has been fired from representation. ASA Lana Belohlavek has been assigned the case. ASA Weiss stated she can no longer speak about the Epstein case with me. I thanked her for her telephone call. ASA Weiss further stated that ASA Belohlavek would be calling me. ****************************NAREATI■ E # 4 ************************** NA Reported By: 5/15/06 Entered By.: 5/15/06 On May 10, 2006, information was received that Epstein's associate, Leslie Wexner, The Limited Inc, CEO's, plane had arrived in West Palm Beach, PBIA. The plane, a Gulfstream 4 bearing a N900LS registration, was on the tarmac at Galaxy Aviation. As Epstein had recently acquired the services of a new attorney, and the fact that Epstein's house is currently under remodeling, it was believed that Epstein may be in Palm Beach. I conducted physical surveillance at the residence, 358 El Brillo Way. I observed a large construction crew conducting remodeling at the house. The contractor, David Norr, was observed driving a Ford E , white in color. The vehicle has a Florida registration of r left Epstein's house and traveled north on County Road. Det and I conducted surveillance on Norr. Norr traveled to several construction sites and check ertain jobs. Surveillance was discontinued on Norr and Det and I traveled to Galaxy Aviation. I observed the white plane with a blue stripe along the body and tail of the plane; the tail number was visible on the bottom of the tail, closer to the body of the plane. We maintained visual surveillance on the plane until 4:57 p.m., when a caravan of Cadillac Escalades drove onto the tarmac. We observed several people exit the vehicles and discovered that they were part of the executive team for Limited Inc. The executives were in Palm Beach County for an executive meeting for the day. They arrived in Palm Beach County on May 9, 2006 at 9:30 pm and were scheduled to leave on the 10th at 5:00 pm. On May 12, 2006, I met with ASA Lana Belohlavek at the State Attorney's Office. She explained that her boss, Barry Krischer, was requesting this case be taken to the Grand Jury again. I o her ted arrest warrants for Jeffrey Epstein, and sm I asked that she either issue the warrants or direct file, as II much time has elapsed since the original request to the Grand Jury _l__explained that the Palm Beach Police Department--had--- concluded the case in December of 2005 and has been waiting for the case to go forward. Belohlavek stated the original offer was again offered to the new defense attorney. She was waiting for their answer by Friday May 19, 2006. She stated she would advise me of the answer. **************************** N A R R A # 45 ************************** NA Reported By: 6/05/06 EFTA00231006 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 86 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) Entered By.: 6/06/06 On Mali 2006, I received several phone calls throughout the day from , who ed he had been followed aggressively by a private investigator. stated that as he drove to and from work and running errands t roughout the county, the same vehicle was behind him • other vehicles off the road in an attempt not to lose sight of vehicle. I explained to him as Mr. Epstein had retained new legal council it was possible it would be new private investigators following him to observe his daily activities. I also explained to him that there was a meeting scheduled with ASA Lana Belohlavek and Attorney Jack Goldberger at Mr. Krischer's office scheduled on June 1, 2006 at 9:00 am. I attempted to call ASA Lana.galohlavek to inform her of the private investigators following IIIII however; she was on her vacation during the week of May 22 through May 30 2006. On May 23, 2006, I received other phone calls from Mr. and who advised they were able to acquire the private investigators license plate information. The t following them was again driving very aggressively and caused to run off the road. the vehicle is a green Chevy Monte Carlo bearing Florida tag The vehicle is registered to Zachary Bechard of Jupiter Florida. Bechard is employed with Candor Investigations from Jupiter, Florida. Bechard is a licensed Private Investigator in the State of Florida. Since the diacovery of the threat made against one of the victims in this case ( ) subpoenas for all calls made to and received from during the month of M her and home phone. I had confirmed with the exact dates of Spring Break for 2006. The Spring Break was from March 4, 2006 through March 12, 2006. I received a subpoena from Sprint/Nextel with all calls made during the month of March 2006. I reviewed the 989 calls made and received during the month of March 2006. I observed on March 7, 2006, made and received thirty five calls during that day. Date Time Seconds 7-Mar-06 11:03 AM 492 In/Out Outbound 7-Mar-06 11:16 AM 6 Inbound 7-Mar-06 11:22 AM 887.2 Inbound 7 -Mar-06 11:37 KFU--- 48 —Outbound￾7-Mar-06 11:39 AM 28.2 Inbound 7-Mar-06 12:02 PM 727.2 Inbound To/From 561XXXX 561XXXX 561XXXX The table reflects the date of the calls, time of day (EST), duration EFTA00231007 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 87 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) of cal n econds, inbound or outbound calls and ca ade to or from ne. On March 7, 2006, at 11:03 am, made a call to the victim which lasted 492 seconds (8 minutes and 2 seconds). The victim then returned the call a •16 am which lasted 6 seconds. The victim then made contact with at 11:22 am for 877.2 seconds (14 minutes and 6 seconds). These sequences of calls were consistent with what the victim had described to me on the date of the intimidati I ' tely after speaking with the victim, makes a call to , Epstein's assistant, which lasts for forty-eight seconds. A call is then immediately received, a telephone number registered to a Corporation affiliated with Jeffrey Epstein located at 457 Madison Ave in New York. An extensive computer check revealed 457 Madison Ave is a business address in which Epstein has his corporations assigned to. Epstein had corporation attorney, Darren Indyke, register the businesses and register himself as an agent. I also observed Epstein has his El Zorro Ranch Corporation, New York Strategy Group, Ghislaine Corporation, J Epstein and Company and the Financial Strategy Group registered to this same address. Finally, a third call is received by at 12:02 pm from the same corporate number which lasts 12 minutes and 1 second. It should be noted that there is no further contact with either the victim during the month of March or April of 2006. I also noted that there was no NA further contact with or Jeffrey Epstein during the remainder of the mont o Marc or April 2006. On June 1, 2006, ASA Lana Belohlavek telephoned me to inform me of the meeting that occurred with Atty. Jack Goldberger and her reference this case. She advised she would make her determination on whether to file on this case or not by Monday June 5, 2006. Inv Continues. MI ****************************NARRA ************************** Reported By: 7/12/06 Entered By.: A. 7/12/06 On June 29, 2006, I had spoken to ASA Lana Belohlavic who informed me that the case would be sent to the Grand Jury for charges. She informed me that the grand jury would convene on July 19, 2006 to hear the Epstein case. Belohlavic stated State Attorney Barry Krisher made the determination to go the Grand Jury to hear the case. On July 12, 2006, I spoke with mother of the victim, II, who inquired about the_atatus_o_f_the _case. I explained rn her that--I-was--- told we would be going to the Grand Jury during the week of July 19, 2006. She stated she had not been contacted as of yet by the State Attorney's Office for any information. I provided her with the telephone numbers to the State Attorney's Office. Investigation continues... * * * * * * * * * * * * * * * * END OF REPORT * * * * * * * * * * * * * * * * * EFTA00231008 EFTA00231009 07/27/2006 THU 18:22 FAX 07/26/2006 15:44 5610354700 reiru Irunrnre fool A TRUE BILL IN THE NAME OF AND BY THE AUTHORITY OF THE STATE OF FLORIDA IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA For Palm Beach County, at the Spring Term thereof, in the year of our Lord Two Thousand and Six, to-wit The Grand Jurors of the State of Florida, inquiring in end for the body of said County of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid. in the Circuit and State aforesaid. COUNT ONE FELONY SOLICITATION OF PROSTITUTION on or about or between the 1st day of August in the year of our Lord Two Thousand and Four and October 31, 2005, did solicit, induce, entice, or procure another to commit prostitution lewdness, or assignation, contrary to Florida Statute 796.07(1) on three or more occasions between August 01, 2004 and October 31. 2005, contrary to Florida Statute 796.07(2)(f) and (4)(c). (3 DEG FEL)(LEVEL 1) against the form of the statute, to the evil example of all others, and against the peace and dignity of the State of Florida. I hereby certify that I have advised the Grand Jury returning this indictment as authorized and required by law. State Assistant State Attorney of the Fifteenth Judicial Circuit of the of Florldep-rosecuting 1W-the said -- Slate EFTA00231010 07/27/2008 THU 18:23 FAS 07/26/2005 15:44 5610354700 PBPD 114-11NINd rm•a• 0414,022 GRAND JURY FOREPERSON DATE Jeffrey E. Epstein, Rasa* White, Sex: Male, DOB: January 20, 1953, Issue Warrant EFTA00231011 t4 1, k-0 ) gOckin EFTA00231012 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 peangl (O1)60 D.C. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 08-80804-Civ-MARRA/JOHNSON CASE NO.: JANE DOE, aik/a JANE DOE #1, Plaintiff, vs. JEFFREY EPSTEIN and Defendants. July 18, 2008 STEVEN N. LARUAORE CLERK O.S. MST. CT. S.O. or FLA. • MIAMI NOTICE OF REMOVAL In accordance with 28 U.S.C. §§ 1441, 1446, and 1332(e), the defendants, Jeffrey Epstein, , and hereby remove this action' from Palm Beach County Circuit Court to the United States District Court for the Southern District of Florida, and respectfully state as follows: Introduction Six months ago, this plaintiff filed virtually the identical lawsuit in this Court. Sec Jane Doc III v. Epstein, Case No. 08 cv 80069 KAM (S.D. Fla. filed Doe v. Epstein et at, Case No. 50 2008 CA 006596 XXXX MB (Fla. 15th Cir. Ct. filed Mar. 6, 2008). Lewis "rein 30S9GKAKAAviAut,Suin 340,EocoorutSkOvr,FFOROA33133 1.1511 EFTA00231013 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 2 of 100 Jan. 24, 2008) (the "First Federal Action"). The First Federal Action named Jeffrey Epstein as the sole tortfeasor, made the identical operative allegations as the instant Amended Complaint, and demanded damages of $50 million. (The amount of the demand against Epstein is evidently the product of recent reports in the press that Epstein is wealthy.) The First Federal Action was quickly followed by a series of substantially identical "Jane Doe" lawsuits, all filed by the same attorney in a three-month span. Compare Jane Doe #1 v. Epstein, Case No. 08-cv-80069-KAM (S.D. Fla. filed Jan. 24, 2008), with Jane Doe #2 v. Epstein, No. 08-CV-80119-KAM (S.D. Fla. filed Feb. 6, 2008) (asserting identical causes of action based on the same operative allegations), Jane Doe #3 v. Epstein, No. 08-CV-80232-KAM (S.D. Fla. filed Mar. 5, 2008) (same), Jane Doe #4 v. Epstein, No. 08-CV-80380-KAM (S.D. Fla. filed Apr. 14, 2008) (same), and Jane Doe #5 v. Epstein, No. 08-80381-CV-KAM (S.D. Fla. filed Apr. 14. 2008) (same). On February 20, amid these filings, Jane Doe 41 was deposed in State of Florida v. Jeffrey Epstein, 502006CF009454AXXXMB (Fla. 15th Cir. Ct., filed Jul. 19, 2006), a parallel state-court criminal action. During that deposition, she made numerous admissions that completely undermined the allegations against Epstein that she had pled in her complaint. A copy of her deposition, with names 2 Lewis -rein re. 3059 Gump Avoduc Sum 140,CocoNa Gaon. Rota 33133 2.0111 EFTA00231014 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 3 of 100 redacted, is attached hereto (Exhibit A). Two days later, counsel for Jane Doe # I filed a notice of voluntary dismissal without prejudice in the First Federal Action. See Doe #1 v. Epstein, Case No. 08-CV-80069-KAM, DE 9. Two weeks later (March 6, 2008), having changed lawyers, Jane Doe #1 refiled her complaint in Florida Circuit Court as the instant case, adding two nominal defendants: Mr. Epstein's personal secretary, and , one of Jane Doe #1's contemporaries. These defendants have nothing to do with the plaintiff's case against Mr. Epstein, except that the presence of as a defendant in this new case, because she is a citizen of Florida (Am. Compl. 114), would ostensibly prevent complete diversity.2 As discussed below, however, was named in the refiled lawsuit only to destroy diversity jurisdiction, and to prevent any application of 18 U.S.C. § 3509(k), a mandatory stay provision applicable in federal court . 3 2 Defendant is a citizen of New York (Am. Compl. ¶ 5), and is therefore a nonresident defendant for purposes of diversity jurisdiction and removal. 3 Section 3509(k) of Title 18, United States Code, provides as follows: It, at any time that a cause of action for recovery of compensation for damage or injury to the person of a child exists, a criminal action is pending which arises out of the same occurrence and in which the child is the victim, the civil action shall be stayed until the end of all phases of the criminal action and any mention of the civil action during the criminal proceeding is prohibited. As used in this subsection, a criminal action is pending until its final adjudication in the trial court. 3 3059 Gino Awing. Sun 340, [adu•Gtovt, km0,433)33 344311 EFTA00231015 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 4 of 100 besides having nothing to do with the substantive allegations of the plaintiff's $50,000,000 case, is a community-college student with no assets whatever. Even if this case purports to identify a new (and strategically nondiverse) tortfeasor, the reified lawsuit is still directed against only one defendant—Jeffrey Epstein. Then and now, the operative allegations are the same: Jane Doe alleges that Jeffrey Epstein assaulted her "in violation of Chapter 800 of the Florida Statutes."4 (Am. Compl. ¶ 18.) To sharpen her lawsuit, the plaintiff says she is seeking damages in connection with a "conspiracy" (Am. Compl. ¶ 22), a "plan" (Am. Compl. ¶ 32), a "scheme" (Am. Compl. ¶ 32), and an "enterprise" (Am. Compl. ¶ 32). These theories of liability, however, cannot be supported by the allegations in the Amended Complaint. Even if everything in the Amended Complaint were true, recovery against , under any formulation, is impossible under Florida law. Focusing on the real parties to this controversy, the instant case could have (once again) been brought here in federal court- just like the four other "Jane 18 U.S.C. § 3509(k) (emphasis added). 4 Chapter 800, Florida Statutes, is entitled, "Lewdness; Indecent Exposure." 4 Lewis Tein n ..., • 3059 GRAM) AVINIR. Sum 340. Coccxyr Groa.Ftwo• 33133 40311 EFTA00231016 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 5 of 100 Doe" lawsuits presently pending against Epstein, filed by this plaintiffs former lawyer. This case is properly removed to federal court, first, because there is complete diversity among the real parties-in-interest, second, because the amount in controversy exceeds $75,000, and third, because this Notice complies with the requirements of 28 U.S.C. § 1446. Discussion A. This case is properly removable because it falls within the original jurisdiction of the United States District Court for the Southern District of Florida. A state-court case is properly removable when "it could have been brought, originally, in a federal district court." Lincoln Prop. Co.'. Roche, 546 U.S. 81, 83 (2005) (citing 28 U.S.C. § 1441(a)). This case was originally filed in federal district court, and it is the same case today. Even though it was reconfigured to look like a state-court lawsuit, this action falls squarely within the bounds of the diversity-jurisdiction statute. See 28 U.S.C. § 1332(a)(1) (establishing that federal district courts have original jurisdiction over cases where the amount in controversy [is more than $75,000] . . . and [when the controversy] is between citizens of different states"). 5 Lewis 'rein ri 3059GuADAvimist,Sunt 340,Caccour Gtove.ftota 13113 5 d 316 EFTA00231017 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 6 of 100 1. The amount in controversy in this action exceeds $75,000. This case is a duplicate of the First Federal Lawsuit. In that case, Jane Doe pled "damages in excess of $50 million." See Doe v. Epstein, No. 08-80069-KAM (S.D. Fla. filed Jan. 24, 2008) (Compl. ¶ 6). That allegation is now deleted and the Amended Complaint substitutes a generic prayer for reliefs It is clear, however, that Jane Doe still seeks more than $75,000 in damages. This case, precisely like the First Federal Action, seeks damages in connection with an alleged assault. (Am. Compl. ¶¶ 16-19.) The Amended Complaint alleges that Jane Doe "has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological, and emotional damages." (Am. Compl. ¶ 19.) These are the identical injuries Jane Doe asserted in the First Federal Action, and are no less serious simply because pled under a state-court caption. Cf., e.g., Woods v. Southwest Airlines, Co., 523 F. Supp. 2d 812, 820 (N.D. III. 2007) (determining, in the context of diversity jurisdiction, that the $75,000 threshold had been satisfied, and "clearly [surpassed]," based on "the nature of the injuries alleged" in the complaint). 5 The Complaint seeks damages for "[more than] . $15,0007 (Am. Compl. ¶ 6.) This boilerplate is routinely used in Florida pleading practice to trigger application of section 26.012, Florida Statutes, the statute that establishes the jurisdictional amount required for filing in Florida's Circuit Court (as opposed to County Court). 6 1...e364A1:Fi II rt. 3059 Game Avow. Suns 340, Cocomo Gam, rims33133 9 a/ 31$ EFTA00231018 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 7 of 100 To cement this point, the Eleventh Circuit Court of Appeals has said that "[wjhen [a] complaint does not claim a specific amount of damages, removal from state court is proper if it is facially apparent from the complaint that the amount in controversy exceeds the jurisdictional requirement." Williams v. Best Buy Co., Inc., 269 F.3d 1316, 1319 (11th Cir. 2001). This case meets that standard, and satisfies the first prong of diversity jurisdiction. 2. There is complete diversity among the real parties to this controversy. Diversity jurisdiction requires complete diversity. Carden v. Arkoma Assocs., 494 U.S. 185, 187 (1990) ("Since its enactment, we have interpreted the diversity statute to require `complete diversity' of citizenship." (citing Strawbridge v. Curtiss, 7 U.S. (3 Cranch) 267, 267-68 (1806))). See also MacGinnitie v. Hobbs Group, LLC, 420 F.3d 1234, 1239 (1 1 th Cir. 2005) (stating that "[c]omplete diversity requires that no defendant in a diversity action be a citizen of the same state as any plaintiff"). As demonstrated below, this case satisfies the statutory requirement of complete diversity. (a) PlaintiffJane Doe is a citizen of Florida. (Am. Compl. 1.) 6 6 Jane Doe may, in fact, be a citizen of Georgia, not Florida, as she pled in her Amended Complaint,—See-tiew-Kor-lc-Rostriloh-1,4008-(reperting-thaterrhirwarinhr his state-court guilty plea on June 30], Epstein was served with a copy of a lawsuit by Doe. who has since moved to another state."); Jane Doe Depo. at 77, 112 (indicating that 7 Lewis 'rein a 30596244444044,Sunt 340, COCOMO Goa.% home. 33233 70316 EFTA00231019 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 8 of 100 (13) Defendant Jeffrey Epstein is a citizen of the U.S. Virgin Islands.' (c) Defendant 3. Defendant is a citizen of New York. (Am. Compl. ¶ 5.) was fraudulently joined to defeat diversity. "A non-diverse defendant who is fraudulently joined does not defeat diversity because his citizenship is excluded from the diversity calculus." Shenkar v. Money Warehouse, Inc., No. 07-20634-CIV, 2007 WL 3023531, at *1 (S.D. Fla. her twin sister lives with her mother in Georgia); Affidavit of at ¶ I (stating, "I am the mother and natural guardian for Jane Doe #1" with jurat executed in Georgia before a Georgia notary), DE 4-2, Jane Doe No. 1 v. Epstein, Case No. 08- 80069-Civ-Marra (1/29/08); Intervenor's Complaint, at ¶ 2 (filed by "Jane Doe's Mother" and stating that "Jane Doe's Mother is a citizen and resident of the State of Georgia."), I)E 5-2, Jane Doe No. I v. Epstein, Case No. 08-80069-Civ-Marra (1/29/08); Petition for Removal of Disability of Non-Age, at ¶¶ 1, 2, 7 (filed "on behalf of S.D.G.," alleging that "The mother is , and her address is .... Ga.," and stating that "S.D.G. is also the unnamed party in a lawsuit filed by her father on her behalf in the U.S. District Court for the Southern District of Florida, Case No. 08-80069, which was filed without the consent of the mother"), In re (Palm Beach Co. Family Ct.) . If this turns out to be the case, there is complete diversity, regardless of citizenship. Although the Eleventh Circuit has recently indicated that a district court may not conduct jurisdictional discovery under such circumstances, another division of this Court has since allowed it. Compare Lowery v. Ala. Power Co., 483 F.3d 1184, 1215-16, 1221 (11th Cir. 2007) (holding that jurisdictional discovery to determine citizenship upon removal is inappropriate), with Calixto v. BASF Constr. Chemicals, LLC, slip op., Case No. 07-60077-CIV-ZLOCH, 2008 WL 1840717, *I (S.D. Fla. Apr. 22, 2008) (ordering that parties "shall engage in jurisdictional discovery for the Court to determine the citizenship of BASF and whether it has subject-matter jurisdiction over this action"). 7 The Amended Complaint erroneously states that Jeffrey Epstein is a citizen of New York. 8 Lewis "rein n. 3059 GWID AVINUI. Sum 340, Comm QomItasca 33133 101319 EFTA00231020 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 9 of 100 Oct. 15, 2007) (Moreno, J.) (citing Riley v. Merrill Lynch, Pierce, Fenner & Smith, Inc., 292 F.3d 1334, 1337 (11th Cir. 2002)); accord, e.g., Tedder v. F.M.C. Corp., 590 F.2d 115, 117 (5th Cir. 1979) (denying motion to remand where two resident defendants were joined for the fraudulent purpose of defeating federal jurisdiction). In this case, the plaintiff relies on her original allegations to support three causes of action against : civil conspiracy (Am. Comp!. II 20-23); Intentional Infliction of Emotional Distress (Am. Comp!. 23-28); and civil RICO (Am. Compl. 11: 29-34). These allegations, however, do not support these claims, or any other theory of liability that would allow recovery against . Cf. Parks v. The New York Times Co., 308 F.2d 474, 477 (5th Cir. 1962) (observing that "determination of fraudulent joinder is to be based on whether there was a real intention on colorable grounds to procure a joint judgment") (emphasis added).8 (a)Nonresident defendants have a right of removal. The removal statute was enacted specifically "to protect defendants." Legg v. Wyeth, 428 F.3d 1317, 1325 (11th Cir. 2005). Cf., e.g., Picquet v. Amoco Prod. Co., 513 F. Supp. 938, 941 (M.D. La. 1981) (explaining that courts developed the fraudulent-joinder doctrine to protect "the right [of removal] granted to In Bonner v. City of Prichard, 661 F.2d 1206, 1207 (11th Cir. 1981) (en banc), the ----E4eventh-Gireuit-Geurt-ef-Appeels-adepted-as-binding-preeedent-aIl dwisiuns of 3ho former Fifth Circuit rendered prior to October 1, 1981. 9 L.exylCrsin FL 3039 Gomm Mout. Sum 340. Coccoon Goon, Fos 33133 1@1311 EFTA00231021 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 10 of 100 [defendants] by . . . Congress"). In this case, by reconstituting her original federal lawsuit and refiling it in state Court, the plaintiff has clearly sought to avoid the strictures of the mandatory stay of this case that federal law requires under 18 U.S.C. § 3509(k).9 In federal court, pursuant to 18 U.S.C. § 3509(k), this action must be automatically stayed pending final disposition of an ongoing parallel criminal action against Mr. Epstein. See 18 U.S.C. § 3509(k) (providing that a parallel civil 9 By filing in state court, the plaintiff's attorney has also evidently sought to avoid the clear command of our local rules forbidding public comment about the merits of a pending lawsuit. Compare S.D. Fla. Local Rule 77.2(7) ("A lawyer or law firm associated with a civil action shall not during its investigation or litigation make or participate in making an extrajudicial statement, other than a quotation from or reference to public records, which a reasonable person would expect to be disseminated by means of public communication if there is a reasonable likelihood that such dissemination will interfere with a fair trial and which relates to (a) Evidence regarding the occurrence or transaction involved. (b) The character . . . of a party . . . . (d) The lawyer's opinion as to the merits of the claims ") with Ricci—Leopold Home Page, http:// www.riccilaw.com (click on "Breaking News," then access the hyperlink entitled, 03/13/08 - Consumer Justice Attorney Ted Leopold Files Case to aid Jane Doe in seeking justice against sexual predator Jeffrey Epstein and his associates. ) (describing character of party defendant Epstein as a "sexual predator" (a term defined by Florida criminal statutes) and quoting the plaintiff's attorney "Ted Leopold, managing partner" as characterizing Epstein as "an extremely powerful and wealthy man," with "vast resources," who acted "in the vilest way" at his "lavish mansion" with "lurid fantasies" and inflicting "untold damage," and opining that he should "be held accountable;" also quoting the plaintiff's attorney as opining that "[t]his case is both about justice and making sure that a wealthy and powerful man knows that he is not above the law;" also quoting the plaintiff's attorney's view of the evidence that plaintiff "continues to endure emotional trauma daily") (Web site last visited July 17, 2008). 10 1-1e3YARTeinn. 3059GasidoAvulut,Surri 340,CooNve Gaon. FLOMA 33133 100311 EFTA00231022 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 11 of 100 action arising from an alleged sexual assault of a minor "shall be stayed until the end of all phases of [any] criminal action") (emphasis added). In this case, there is a parallel federal criminal grand jury action pending in the Southern District of Florida, In re Grand Jury, No. FGJ 07-103(WPB) (S.D. Fla.), which arises out of the same allegations pled here. Thus, in resorting to fraudulent joinder, the plaintiff has sought to avoid any application of this otherwise controlling statute. cf Doe v. Francis, No. 5:03 CV 260 MCR/WCS, 2005 WI_ 517847, at *1-2 (ND. Fla. Feb. 10, 2005) (staying civil diversity action over plaintiffs' objections on grounds that "the language of 18 U.S.C. § 3509(k) is clear that a stay is required in a case . . . where a parallel criminal action is pending which arises from the same occurrence involving minor victims") (emphasis added). Even outside the context of a mandatory federal statute, "the Supreme Court [has] admonished [that] `the Federal courts should not sanction devices intended to prevent a removal to a Federal court where one has that right, and should be equally vigilant to protect the right to proceed in the Federal court.'" Legg, 428 F.3d at 1325 (citing Wecker v. Nat'l Enameling & Stamping Co., 204 U.S. 176, 186 (1907)). See also id. (observing that "Congress 'did not extend [to defendants a right of removal] with one hand, and with the other give plaintiffs a bag of tricks 11 Lewis 'Minn. 3059 Glow Am or. Sum 340. Cocis0 I Gwa.I Io6M 3)133 11 01 716 EFTA00231023 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 12 of 100 to overcome it" (quoting McKinney v. Bd. of Trustees of Maryland Ono) Coll, 955 F.2d 924, 928 (4th Cir. 1992))). To protect a nonresident defendant's right of removal, a federal court will "determine the matter of jurisdiction" by examining "the true situation both as to panics and causes of action." Bernblum v. Travelers' Inc. Co., 9 F. Supp. 34, 35 ( W.D. Mo. 1934) (emphasis added). See also id. (observing that "[t]he federal courts will . . . strike out the fiction injected into a case by a party to prevent removal"). In accordance with these principles, a plaintiff cannot destroy diversity jurisdiction simply by conjuring up a nondiverse defendant; there must be at least some "possibility that the state law might impose liability on [the nondiverse] defendant under the circumstances alleged in the complaint." Florence v. Crescent Res., LLC, 484 F.3d 1293, 1299 (11th Cir. 2007) (citations omitted). See also, Holloway v. Morrow, No. 07-0839-WS-M, 2008 WL 401305, at *5 (S.D. Ala. Feb. 11, 2008) (emphasizing that "'Nile potential for legal liability must be reasonable, not merely theoretical" (quoting Legg v. Wyeth, 428 F.3d 1317, 1325 n.5 (11th Cir. 2005))) (emphasis added). In this case, the plaintiffs have tried to whip Jane Doe's original, one￾defendant complaint into a froth that looks non-federal. Cf. Owens v. Swan, 962 F. Supp. 1436, 1439 (D. Utah 1997) (noting that "although plaintiffs' amended 12 1...evfitACCFin N. 3059 Gumo Ave nue n 340, Cocewin Gaon, host" 33133 t2 0311 EFTA00231024 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 13 of 100 complaint contains four claims for relief, the first and second claims state only one cause of action") (emphasis added). Using her original allegations and adding nothing, Jane Doe has tried to add claims against for civil conspiracy (Am. Compl. ¶1 20-23), Intentional Infliction of Emotional Distress (Am. Compl. ¶¶ 24-28), and civil RICO (Compl. ¶¶ 29-34) in order to append a nondiverse defendant to her Complaint. These claims, however, are untenable under Jane Doe's own allegations, and therefore cannot be used to destroy diversity jurisdiction. (b) There is nopossibility that the plaintiff can establish a cause of action against under Florida law. (i) The conspiracy claim against must fail. As a general rule, "[a]n actionable conspiracy [under Florida law] requires an actionable underlying tort or wrong." Wright v. Yurko, 446 So. 2d 1162, 1165 (Fla. 5th DCA 1984) (citations omitted) (emphasis added).10 10 This case is governed by the general rule. Cf. Churruca v. Miami Jai-Alai, Inc., 353 So. 2d 547, 550 (Fla. 1977) (noting that while there is "ordinarily . .. no independent ton for conspiracy," there is a narrow exception to this rule when "the plaintiff can show some peculiar power of coercion possessed by the conspirators by virtue of their combination") (emphasis added). See generally Liappas v. Augoustis, 47 So. 2d 582, 583 (Fla. 1950) (observing that -'instances of conspiracy which is in itself an independent tort are rare and should be added to with caution' (quoting Fleming v. Dane, 22 N.E.2d 609, 611, (Mails. 1939))) (emphasis added). Plainly, th;s Cat ;nvulvcs dic genera -rule, not the narrow exception, because only one person could have caused Jane Doe's injuries. CI Martin v. Marlin, 529 So. 2d 1174, 1179 (Fla. 3d DCA 1988) (upholding 13 LeNviA:Ein n. 309 Gram Avow'. Sun( 340,Cocoito Gnm. ha/a:433133 13 1315 EFTA00231025 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 14 of 100 Here, Jane Doe cannot assert a cause of action for "violation of Chapter 800, Florida Statutes" (Am. Compl. ¶ 18) because there is no private right of action under that Chapter. See generally Am. Home Assurance Co. v. Plaza Materials Corp., 908 So. 2d 360, 374 (Fla. 2005) (observing that "not every statutory violation carries a civil remedy" (citing Villazon v. Prudential Health Care Plan, Inc. 843 So. 2d 842, 852 (Fla. 2003))). See also, e.g., Miami Herald Publ'g Co. v. Ferre, 636 F. Stipp. 970 (S.D. Fla. 1985) (King, C.J.) (holding that violation of Florida's criminal extortion statute does not give rise to a civil cause of action for damages); Mantooth v. Richards, 557 So. 2d 646, 646 (Ha. 4th DCA 1990) (per curiam) (affirming dismissal of plaintiffs claim for parental kidnapping where "the mentioned statutes concern only criminal violations and do not afford a civil remedy") (citation omitted) (emphasis added); Wright v. Yurko, 446 So. 2d 1162, 1 165 (Ha. 5th DCA 1984) (holding that "[a]n act which does not constitute a basis for a cause of action against one person cannot be made the basis for a civil action for conspiracy"). In this case, Jane Doe's claim under Count H (civil conspiracy) fails because it derives exclusively from Count I (violation of Chapter 800, Florida Statutes). Cf grant of summary judgment against claim for independent conspiracy, noting that "lwihen the concerted acts of the defendants do not create a greater harm than if the acts v‘ ere committed by one person alone. then there can be no recovery"). 14 Lewis "rein it 3059 GuNoAvmvt,Suirt 340.,Cccaivr Grow. FLORIDA 33133 14 of 31$ EFTA00231026 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 15 of 100 Buchanan v. Miami Herald Publ'g Co., 230 E. 2d 9, 12 (Fla. 1969) (holding that where Count I of the complaint had failed to state a cause of action for malicious prosecution, there could be no civil-conspiracy claim in Count II "based on the allegations of Count I"). Because the statute she expressly pleads as the basis for Count I, Chapter 800, Florida Statutes, provides no civil remedy, Jane Doe cannot prevail on Count I. Therefore, she cannot prevail on her claim for conspiracy (Count II) to violate Chapter 800, Florida Statutes (Count I). (II) The laintiff cannot prevail against nondivcrsc defendant on her claim for Intentional Infliction of Emotional Distress (IIED). Even if the plaintiff, for the sake of argument, can assert an IIED claim against Jeffrey Epstein, the plaintiff still does not have a cause of action for IIED against First, the plaintiff cannot recover damages in connection with her own illegal conduct; and second, the plaintiffs purported IIED claim fails as a matter of law. 15 Le.Vp:rein n. 3059Gams Avtrout, Sun 340, COCON.J1 Gaol. 1100 D.33133 IS of 316 EFTA00231027 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 16 of 100 1. The plaintiff seeks damages in connection with her own illegal conduct. The plaintiff concedes that she went to Jeffrey Epstein's house "to give Epstein a massage for monetary compensation." (Am. Compl. ¶ 13.) The plaintiff also concedes, in the guise of an allegation, that "brought Jane Doe to Epstein's mansion in Palm Beach" to help the plaintiff execute her own plan. (Am. Compl. ¶ 13.) Yet, the plaintiff's plan was illegal: under Florida law, it is a cringe "to practice massage" without a license. § 480.047, Ha. Stat. (1997). To say it another way, the plaintiff admits that she went to Mr. Epstein's house to commit a crime. Based on these allegations, it is clear that the plaintiff seeks damages in connection with her own illegal conduct; this is enough to support a finding of fraudulent joinder. See Florence v. Crescent Resources, LLC, 484 F.3d 1293, 1298 n.3 (11th Cir. 2007) (acknowledging that "under some circumstances, application of an affirmative defense can support a finding of fraudulent joinder). This conclusion is supported by well-established principles. Under Florida law, a plaintiff cannot recover damages flowing from her own illegal conduct. See Hall v. Hall, 93 Fla. 709, 112 So. 622, 628 (1927) (referring to "the universal rule of our law that one in a court of justice cannot complain . . . of another's wrong whereof he was a partaker") (internal quotation marks and citation 16 Lewis Tein,,. 3059 Gunn Iwthui.Stalit 340. Como' i Gioia, I LOAMA 33133 16 o1316 EFTA00231028 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 17 of 100 omitted) (emphasis added); Turner v. Anderson, 704 So. 2d 748, (Ha. 4th DCA 1998) ("[N]o public policy should allow appellant to recover damages as a result of engaging in criminal conduct such as occurred in this case."). Cf Ewe!! v. Daggs, 108 U.S. 143, 149 (1883) (stating that "'[n]o court will lend its aid to a [plaintiff' who founds [a] cause of action upon an immoral or an illegal ace") (quoting Holman v. Johnson, 98 Eng. Rep. 1120 (K.B. 1775)); see also id. (explaining that this policy is "not for the sake of the defendant, but because [the courts] will not lend their aid to such a plaintiff" (quoting Holman, 98 Eng. Rep. 1120)) (emphasis added); Balas v. Ruzzo, 703 So. 2d 1076, 1082 (Fla. 5th DCA 1997) (Harris, J., concurring) (remarking in the context of an action brought against an alleged prostitution house that "the court should continue its tradition of not interceding in civil conflicts involving transactions that are either illegal or are against public policy"). Based on the foregoing, the plaintiff cannot blame someone else ( ) for the consequences of her own criminal conduct. Cf. Feld & Sons, Inc. v. Pechner, Dorfman, Wolffe, Rounick and Cabot, 458 A.2d 545, 552 (Pa. Super. Ct. 1983) (holding that law-firm clients could not recover damages flowing from their own criminal acts, even though clients' lawyers had suggested the unlawful conduct to begin with). See also Turner v. Anderson, 704 So. 2d 748, 751 (Fla. 4th 17 Lewis 'rein re • 3059 GoApAytmit,$urt 340, GXOPan Gam. ROMA 33133 11 of 316 EFTA00231029 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 18 of 100 DCA 1998) (approving reasoning in Feld & Sons, holding that "no public policy should allow [a plaintiff] to recover damages as a result of engaging in criminal conduct" where the plaintiff had provided false testimony at an arbitration proceeding). 2. The plaintiff's IIED claim fails as a matter of law. To state a cause of action for TIED, a complaint must allege four elements: I I) deliberate or reckless infliction of mental suffering; (2) outrageous conduct; (3) the conduct caused the emotional distress; and (4) the distress was severe. Metro. Life Ins. Co. v. McCarson, 467 So. 2d 277, 278 (Fla. 1985). Whether conduct is outrageous enough to support a claim of intentional infliction of emotional distress is a question of law, not a question of fact. Liberty Mut. Ins. Co. v. Steadman, 968 So. 2d 592, 595 (Fla. 2d DCA 2007) (citations omitted). In this case, without reaching the question of "outrage," the plaintiff has failed to show that conduct - - allegedly arranging an illegal sexual massage that the plaintiff herself agreed to perform - - itself caused the plaintiff to suffer any emotional distress. Even if the alleged agreement was fraudulently induced, the plaintiff's IIED claim flows from Epstein's alleged conduct, not the joint conduct of and Doe in planning the massage. 18 LewfrA,Tvinn. 3059 GaAs° Rvav E. Sun 340, (memo Glow. f 10110A 33133 1110316 EFTA00231030 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 19 of 100 (iii) The plaintiff cannot prevail on her claim for civil remedies for criminal practices or racketeering ("civil RICO") pled in Count IV. A cause of action under section 772.104, Florida Statutes ("Civil Remedies for Criminal Practices") requires a showing of direct injury. Even assuming for the sake of argument that Jane Doe can establish that the defendants engaged in a "pattern of criminal activity," she cannot establish that she was directly injured by those activities. Section 772.104 allows someone to bring a civil RICO claim only if "he or she has been injured by reason of any RICO violation. § 772.104, Fla. Stat. (2007). Here, the allegations in Count IV, even if they are true, do not add up to a civil RICO claim because there is no proximate cause between the purported "pattern of criminal activity" and Jane Doe's alleged injuries. In a doomed attempt to satisfy the extremely high burden of pleading civil RICO under Florida law, the Amended Complaint lists a series of violations rooted in Florida's prostitution statutes. (Am. Compl. 1 31.) According to the Amended Complaint, the defendants participated in a criminal enterprise . . . or conspir[acyj" (Am. Compl. 1 30) over an unspecified length of time "to repeatedly find and bring [Jeffrey Epstein) underage girls . . . in order for Epstein to solicit, coerce, entice, compel, or force such girls in acts of prostitution and/or lewdness" (Am. 19 LeNtigt,Ttin n 3059GusoAviltut,Stml 340,Cocosur Gmm, Folio. 33133 19 of 3111 EFTA00231031 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 20 of 100 Compl. ¶ 32). The alleged "pattern of criminal activity" comprises violations of Chapter 796, Florida Statutes—the chapter that proscribes various crimes of prostitution.13 These allegations do not tie directly into Jane Doe's alleged psychic injuries. In contrast to a cognizable RICO claim, this action concerns only an isolated occurrence. More important, the alleged injuries in this case are pled to have resulted from an alleged sexual assault, an assault "in violation of Chapter 800 of the Florida Statutes" (Am. Compl. ¶ 18)—not anything having to do with the facilitation of prostitution, or more succinctly, the violation of Florida's prostitution law. Civil RICO claims are extraordinarily difficult to plead successfully. There are examples in the case law of RICO claims stemming from a prostitution enterprise, but they are vastly different from what plaintiff pleads here. They involve, for example, prostitutes who sued a house of prostitution (as an "enterprise") for inflicting systematic and repetitive abuse on them, over time. See Bala: v. Ruzzo, 703 So. 2d 1076, 1077 (Fla. 5th DCA 1997) (offering an example of a civil RICO claim against the operators of an alleged "house of prostitution," 13 The Amended Complaint alleges a "pattern of criminal activity" comprising the following criminal violations: §§ 796.03, 796.07(2)0), 796.07(2)(h), 796.045, and 796.04, Fla. Stat. (Am. Comp1.1 31.) 20 LewAct:Csirt n. IDS9GUND nn SUL SUITE 340, COCONUT WOK RONDA 33133 maw EFTA00231032 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 21 of 100 where petitioners alleged that they had "suffered emotional pain, anguish, humiliation, insult, indignity, loss of self-esteem, inconvenience, hurt and emotional distress" as a result of being forced repeatedly, over time, to "perform sexual acts to retain their employment"). Here, even if the Amended Complaint can be read to plead that the defendants schemed to solicit other massages from other people (see, e.g., Am. Compl. ¶¶ 9, 11, 12, 32), those activities are not alleged in any way to have impacted Jane Doe. Cf., e.g., Palmas Y Bambu, S.A. v. E.I. Dupont De Nemours & Co., Inc., 881 E. 2d 565, 570 (Fla. 3d DCA 2004) (holding that "'indirect injuries, that is injuries sustained not as a direct result of predicate acts . . . will not allow recovery under Florida RICO."' (quoting O'Malley v. St. Thomas Univ., Inc., 599 M. 2d 999, 1000 (Fla. 3d DCA 1992))) (emphasis added). Because the Amended Complaint does not satisfy the direct-injury requirement under Florida's RICO law, Jane Doe has failed to allege a cause of action against for violation of section 772.103, Florida Statutes. B. This Notice satisfies the procedural requirements of 28 U.S.C. § 1446. 1. This notice of removal is timely. In accordance with 28 U.S.C. § 1446, this notice of removal is timely. Only defendant Epstein has been served with process. Defendants and 21 Lewis Teinn 3059 G.no AVIMA.SVIII 140, Comma Gwn, kola 33133 21 M311 EFTA00231033 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 22 of 100 have not yet been served. In a multi-defendant lawsuit, removal is timely when effected within 30 days after the last defendant is served. See Hill Dermaceuticals, Inc. v. RX Solutions, United Health Group, Inc., No. 6:08-cv-330-Or1-31KRS, 2008 WL 1744794, at *3 (M.D. Ha. Apr. 11, 2008) (concluding that removal petition was timely where it was filed within 30 days after the last defendant was served). 2. Notice has been given, and state-court papers have been filed. In accordance with 28 U.S.C. § 1446(d), defendants have served this Notice of Removal on July 18, 2008. All papers filed in State Court are attached to this Removal Petition. 3. There is unanimity among the defendants. In accordance with 28 U.S.C. § 1446(b) the undersigned are authorized to represent that all of the defendants join this Petition and consent to removal. Conclusion Because this is a civil action between citizens of different states, excluding any fraudulently joined parties, and the amount in controversy exceeds $75,000, exclusive of interests and costs, this Court has original jurisdiction over this action pursuant to 28 U.S.C. § 1332(aX1). 22 Lewis Tein 3059 GRANO Amos, Sum 340. COCONUT 69059, itos.04 33133 22 o1318 EFTA00231034 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 23 of 100 WHEREFORE, the Defendants, Jeffrey Epstein, , and , remove this case from Palm Beach Circuit Court to the United States District Court for the Southern District of Florida. Respectfully submitted, LEWIS TEIN, P.L. 3059 Grand Avenue, Suite 340 Coconut Grove, Florida 33133 Tel: Fax: • By: 1;4 • fdt￾GUY A. LEWIS Fla. Bar No. 623740 lewis@lewistein.com MICHAEL R. TEIN Fla. Bar No. 993522 ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, Florida 33401 Tel. Fax. By: Jack A. Goldberger Fla. Bar No. 262013 Attorneys for Defendant Jeffrey Epstein 23 Leal:Finn 3059 G9550 Avow. ant 340, [atom! Gam. hors 33233 23 01310 EFTA00231035 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 24 of 100 Michael R. Tein CERTIFICATE OF SERVICE I HEREBY CERTIFY that the foregoing document is being served this day, July 18, 2008, on counsel of record identified on the service list by U.S. Mail. 24 Lewis. Min II. „•••••••• ••••A 30S9GowoAwuw,Swlt 340,Cocomo Wow, kola 33333 24 01315 EFTA00231036 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 25 of 100 Service List Theodore J. Leopold, Esq. Ricci-Leopold, P.A. 2925 PGA Blvd., Suite 200 Palm Beach Gardens, FL 33410 Fax: Counsel for Plaintiff Jane Doe Douglas M. McIntosh, Esq. Jason A. McGrath, Esq. McIntosh, Sawran, Peltz & Cartaya, P.A. Centurion Tower 1601 Forum Place, Suite 1110 West Palm Beach Florida 33401 Fax. Counsel for Defendant Bruce E. Reinhart, Esq. Bruce E. Reinhart, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach Florida 33401 Fax. Counsel for Defendant Robert D. Critton, Esq. Michael J. Pike, Esq. Burman, Critton, Luttier & Coleman, LLP 515 N. Flagler Drive, Suite 400 West Palm Beach Florida 33401 Fax. Co-Counsel for Jeffrey Epstein 25 LeVykt:11:, in VI 3059 Gam Avi NJ,. 54411 340, COCONu I 61.0vT, :LOMA 33133 25 of 316 EFTA00231037 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 26 of 100 EXHIBIT A 24 ol 318 EFTA00231038 Case 9:08-cv-80804-KAM 4ti ent 1 Entered on FLSD Docket 07/21/2008 Page 27 of 100 nsor & Associates Reparaap and Transcriptice, IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 2006 CF09454AXX STATE OF FLORIDA, -vs￾JEFFREY EPSTEIN, Defendant. DEPOSITION OF Wednesday, February 20, 2008 2:00 p.m. - 4:30 p.m. Palm Beach County Courthouse 205 North Dixie Highway West Palm Beach, Florida 33401 Reported By: Judith F. Consor, FPR C PY Notary Public, State of Florida Consor ry Asociates Reporting and Transcription Phone - Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 270316 EFTA00231039 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 28 of 100 nsor & Associates Repo,.ling mid Traascii pnon. Inc Page 2 1 APPEARANCES: 2 on behalf of the State: 3 LANNA BELOHLAVEK, ESQ. ASSISTANT STATE ATTORNEY 4 401 North Dixie Highway West Palm Beach, Florida 33401 5 6 On behalf of the Defendant: MICHAEL R. TEIN, ESQ. 7 KATHRYN A. MEYERS, ESQ. LEWIS TEIN, PL 8 3059 GRAND AVENUE, SUITE 340 COCONUT GROVE, FL 33133 9 On behalf of the Defendant: 10 JACK A. GOLDBERGER, ESQ. ATTERBURY, GOLDBERGER & WEISS 11 250 AUSTRALIAN AVENUE SOUTH SUITE 1400 12 WEST PALM BEACH, FLORIDA 33401 13 14 ALSO PRESENT: ON BEHALF OF THE WITNESS: THEODORE J. LEOPOLD, ESQ. 15 KEITH J. BRETT, DIRECTOR OF MULTIMEDIA DIVISION, LEGAL-EZE 16 17 18 19 20 21 22 23 24 25 Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 2$ al MI EFTA00231040 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 29 of 100 nsor & Associates Repnrnnp and Transcri pan Inc 1 2 WITNESS: INDEX Page 3 PAGE: 3 DIRECT EXAMINATION 4 4 BY MR. TEIN: 5 6 7 NOEXHIBITS MARKED 8 - - - 9 CERTIFIED QUESTIONS 10 Page Line 53 22 11 55 1 59 2 12 111 14 112 2 13 14 15 16 17 18 19 20 21 22 23 24 25 Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 atoms EFTA00231041 Case 9:08-cv-80804-KAM 1 ent 1 Entered on FLSD Docket 07/21/2008 Page 30 of 100 nsor & Associates Roponing and Transcription. lac. Page 4 1 Deposition taken before Judith F. Consor, 2 Court Reporter and Notary Public in and for the State of 3 Florida at Large, in the above cause. 4 - - - 5 Thereupon, 6 7 having been first duly sworn or affirmed, was examined 8 and testified as follows: 9 THE WITNESS: I do. 10 DIRECT EXAMINATION 11 BY MR. TEIN: 12 Q. Good afternoon. Please tell me your full 13 name. 14 A. 15 Q. And can you please spell it. 16 A. 17 18 Q. Thank you. 19 May I call you a 20 A. Uh-huh. 21 Q. going to ask you a few 22 questions, several questions today. If at any time you 23 wan: to take a break, you just let me know. Okay? 24 A. Okay. 25 Q. If you at any time don't understand one of Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 30.1311 EFTA00231042 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 31 of 100 nsor & Associates ReportinE and Traoscripion. Inc Page 5 1 my questions, will you just please let me know? 2 A. Yes. 3 Q. And if at any time you're not feeling well 4 or something like that, you'll tell us, right? 5 A. Yes. 6 Q. Do you feel okay today? 7 A. Yes. 8 Q. Not taking any alcohol or drugs or anything 9 like that, right? 10 A. No. 11 O. II you feel ready to have your deposition 12 taken? 13 A. Yes. 14 Q. what is your address? 15 A. I'm currently living at my aunt's house and 16 I don't know it off the top of my head. 17 Q. Where is it? 18 A. In Jupiter. 19 Q. Who is your aunt? 20 A. 21 Q. Who else is living there? 22 A. my uncle. 23 Q. Anyone else living there? 24 A. No. 25 Q. The contempt motion that your mother filed Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 31 of 316 EFTA00231043 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2006 Page 32 of 100 nsor & Associates Reparnag and Transcii Nit°. Inc Page 6 1 against your father regarding your fifty million-dollar 2 lawsuit against Jeffrey Epstein says that you live with 3 your aunt and uncle and have been living there; is that 4 correct? 5 A. Yes. 6 Q. How long have you been living with your 7 aunt and uncle? 8 A. Since my father kicked me out. 9 Q. That was Thanksgiving of this past year? 10 11 12 A. Q. Yes, sir. Okay. Didn't your firefighter boyfriend get an apartment for the two of you? 13 A. No, sir. He has an apartment, but by 14 himself. 15 Q. Did he get an apartment for the two of you 16 to live in? 17 A. No, sir. 18 0. Are you planning to move in with him? 19 A. Maybe one day in the future. 20 Q. Do you have a plan to move in with him 21 presently? 22 A. No. 23 Q. Have you been to the apartment that you and have discussed moving in together? 25 A. I have been to the apartment. Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 32 al MS EFTA00231044 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 33 of 100 nsor & Associates Her:multp mid lranscripom Inc 1 Q. Where is that? 2 A. Palm Beach Lakes. 3 Q. Have you spent the night over there? 4 A. No, sir. 5 Q. Do you know the address there? 6 A. I do not. 7 Page 7 Q. Isn't your sister planning on living 8 with you and it 9 A. No. 10 Q. you know that this court case is a 11 criminal prosecution, correct? 12 A. Correct. 13 Q. And you know that it's a criminal 14 prosecution against a man who has no criminal background. 15 Do you know that? 16 A. I do now. 17 Q. You agree that court is a very serious 18 matter? 19 A. Yes. 20 Q. And you're here with your lawyer 21 Mr. Leopold, right? 22 A. Yes. 23 Q. And you know that Mr. Leopold recently 24 filed a lawsuit in federal court against Jeffrey Epstein, 25 seeking fifty million dollars. Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 1101316 EFTA00231045 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page34of100 nsor & Associates Repartinf end Transcripiina, inc. 1 MR. LEOPOLD: Let me just object. 2 3 Page 8 IIIIIIIIplet me instruct you. Anything that you have learned through conversations between you 4 and me are protected. II if you know any of that 5 information outside of those discussions, you may 6 answer. But if the only way you know it is 7 through our discussions, do not answer that 8 question. 9 BY MR. TEIN: 10 Q. you know that Mr. Leopold recently 11 filed a lawsuit in federal court on your behalf against 12 Jeffrey Epstein seeking fifty million dollars? 13 MR. LEOPOLD: Same objection. 14 If you know the answer to that outside of 15 our discussions, you may answer. If it is the 16 only way that you know the answer is through our 17 discussions, do not answer that question. 18 THE WITNESS: Okay. 19 MR. LEOPOLD: Attorney/client privilege. 20 BY MR. TEIN: 21 Q. You can answer the question unless 22 MR. LEOPOLD: Same objection. 23 MR. TEIN: Let me finish. 24 MR. LEOPOLD: Excuse me. We're -- 25 MR. TEIN: No. Let me finish. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 34 ol 116 EFTA00231046 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 35 of 100 sor & Associates Roponin and Transcri rum. Inc. Page 9 1 MR. LEOPOLD: Lewis, we're not going to do 2 3 MR. TEIN: My name is not Lewis. 4 I'm going to finish my question. Okay? 5 MR. LEOPOLD: Do not answer until you hear 6 from me. 7 BY MR. TEIN: 8 Q. Other than conversations that you have had 9 with Mr. Leopold -- I'm not asking about that -- are 10 aware that Mr. Leopold has filed a lawsuit in federal 11 court seeking fifty million dollars from Jeffrey Epstein 12 on your behalf? 13 MR. LEOPOLD: Same objection. 14 Anything that you learn through 15 conversations between you and me, do not answer. 16 Those are protected. If you know through any 17 other realm of knowledge, you may answer. 18 THE WITNESS: No. 19 BY MR. TEIN: 2 0 Q. 21 fifty million-dollar lawsuit on your behalf against 22 Jeffrey Epstein? that. you You have no idea that Mr. Leopold filed a 23 MR. LEOPOLD: Same objection. 2,1 Do not answer that question if it's through 25 discussions that you and I had. Outside of that, Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 66 o1316 EFTA00231047 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 36 of 100 nsor & Associates Reporting ad Tranxtip:inei. lac 1 2 3 4 5 6 7 8 9 10 13. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 10 you may answer. II do not answer that question if that is the only basis by which you understand that answer. THE WITNESS: No. BY MR. TEIN: Q. You didn't know that? MR. LEOPOLD: Don't answer that question. Again, it's attorney/client privilege. Any Information you've learned through conversations between you and I are protected. If you know it through any other realm, you may answer. MR. TEIN: Are you going to say that for every question in the deposition, Mr. Leopold? MR. LEOPOLD: When you ask improper questions like that without the proper -- MR. TEIN: You're going to stop your speaking objections right now. Okay? MR. LEOPOLD: Without the proper -- MR. TEIN: You need to stop your speaking objections. Let's continue. MR. LEOPOLD: Counsel, you just asked me a question and I'm going to state it on the record -- MR. TEIN: You need to stop your speaking Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 Motile EFTA00231048 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 37 of 100 nsor & Associates ReponmsrowllanwfiNum.bc 1 2 Page 11 objections. Check your rules. MR. LEOPOLD: Excuse me. For the record, 3 Counsel asked me a question. I'll state the 4 answer on the record. Be asked me the question am 5 I going to be answering that way throughout the 6 deposition. II long as there's improper 7 foundation and predicate asked by the attorney, I 8 will protect my client and I make the record where 9 appropriate. If counsel wishes to ask an 10 appropriate worded question with the proper 11 foundation and predicate, I will certainly allow 12 the client to answer the question. 13 MR. GOLDBERGER: Why don't you just state 14 attorney/client privilege and just be done with 15 it? 16 MR. LEOPOLD: I want the record to be 17 clear. 18 MR. TEIN: You want to waste time is what 19 you want to do. 20 You were supposed to be here this morning 21 and you totally broke the deal, the agreement that 22 you had with us if your hearing got cancelled. 23 But let's move on and maybe you'll stop 24 obstructing this deposition. 25 MR. LEOPOLD: I think the record is very Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 IT of 316 EFTA00231049 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 38 of 100 nsor & Associates Ripening and Transaiption. loc. 1 2 3 4 clear where we stand thus far. Is there a recording taken of this deposition? THE COURT REPORTER: Yes. Page 12 5 MR. LEOPOLD: Just make sure that's 6 preserved. 7 BY.MR. TEIN: 8 Q. Go to Exhibit 20-01 -- well, before you do 9 thate are you aware that a lawyer named Jeffrey 10 Herman filed a lawsuit on your behalf, yes or no? 11 MR. LEOPOLD: Objection. 12 13 regarding that, if that is the only way by which 14 you understand how to answer that question, do not 15 answer. It's attorney/client privilege, as well 16 as any conversations you may have had with the 17 attorney from Miami. That is also attorney/client 18 privilege. And I'm assuming -- 19 MR. TEIN: You're actually wrong about the 20 attorney/client privilege. 21 22 asking you to divulge attorney/client -- 23 MR. TEIN: Of course not. 24 BY MR. TEIN: 25 Q. a are you aware that Jeffrey Herman, Any conversations that you and I have had MR. LEOPOLD: I'm assuming Counsel is not Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 31 of 3i6 EFTA00231050 Case 9:08-cv-80804-KAM ent 1 EnteredonFLSIDDocket07/21/2008 Page 39 of 100 nsor & Associates Rein-min? and lransc option. Inc Page 13 1 an attorney, filed a fifty-million-dollar lawsuit on your 2 behalf against Jeffrey Epstein, yes or no? 3 MR. LEOPOLD: Same objection. 4 MR. TEIN: We've heard the objection 10 5 times already. 6 MR. LEOPOLD: Counsel, excuse me. 7 MR. TEIN: Just say attorney/client 8 privilege. Stop interrupting my questions. 9 MR. LEOPOLD: I'm entitled to make an 10 objection for the record, which I'm doing, and 11 I'll make the same objection. And if it calls for 12 attorney/client privilege, any conversations you 13 and I have had, do not answer the question. 14 And I think that it might be appropriate, 15 for the record, to ask questions via 16 as opposed to 11.1, I think that 17 would be more appropriate for this deposition. 18 BY MR. TEIN: 19 Q. Go ahead. Please answer yes or no. 20 A. Yes. 21 O. Thank you. 22 In fact, you know that Mr. Berman held a 23 press conference after he filed the fifty-million-dollar 24 lawsuit on your behalf, don't you? 25 A. After it happened. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 39 of 316 EFTA00231051 Case 9:08-cv-80804-KAM nt 1 Entered on FLSD Docket 07/21/2008 Page 40 of 100 nsor & Associates Roportenp and Tanscriptinn, 2 4 5 6 7 8 9 10 11 stepmother and Mr. Herman at the press conference 12 regarding your lawsuit? 13 A. Yes. 14 Q. Now you know that this is a very serious 15 matter, don't you? 16 MR. LEOPOLD: Asked and answered. 17 objection. 18 MR. GOLDBERGER: All right. You can 19 20 21 You cannot make legal objections. You have no Page 14 Q. You know that he had a press conference, don't you, yes or no? A. Yes. Q. In fact, let's go to Exhibit 20-01. MR. GOLDBERGER: Look behind you. You'll see it. BY MR. TEIN: Q. Have you ever seen that picture before? A. Yes. 22 23 24 25 Q. Is that a picture of your father, your object. You're representing a witness here, Mr. Leopold. You can object on privilege grounds. standing to do so. MR. LEOPOLD: I'm going to make them and then -- MR. GOLDBERGER: We're -- Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 40 or 314 EFTA00231052 Case 9:08-cv-80804-KAM D. ent 1 Entered on FLSD Docket 07/21/2008 Page 41 of 100 nsor & Associates Rc ponies and Transcription, Inc 1 2 3 appropriate. There's no reason to have this kind 4 of demeanor. If you want to have this kind of 5 demeanor with me -- 6 MR. TEIN: You are obstructing this 7 deposition. 8 MR. GOLDBERGER: Why don't you guys go 9 outside and just talk about -- 10 11 difficult and she's not going to be able to take 12 us both talking at the same time. 13 MR. GOLDBERGER: Off the record. 14 MR. LEOPOLD: We're not going off the 15 record, Jack. We're not, Jack. Her job is very 16 difficult. I'm going td make the record. 17 I don't think it is appropriate, especially 18 in the small confines of this room, to be very 19 aggressive with this young lady. 20 MR. TEIN: That's not happening. Stop, 21 stop actually -- 22 MR. LEOPOLD: If you're going to interrupt Page 15 MR. LEOPOLD: We're going to leave or we're going to take a break, because his demeanor is not MR. LEOPOLD: She -- her job is very 3 me, we're going to cancel this deposition 24 MR. TEIN: Stop misrepresenting. 25 THE COURT REPORTER: I need one at a time, Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 41 of 314 EFTA00231053 Case 9:08-cv-80804-KAM D jent 1 Entered on FLSD Docket 07/21/2008 Page 42 of 100 nsor & Associates Reporting and 'I ranscririon. Inc 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 2C 21 22 23 24 25 Page 16 no matter who it is MR. LEOPOLD: I think we're going to take a break. Perhaps you might want to talk to your co-counsel -- MR. TEIN: I don't need to talk to him. MR. LEOPOLD: But we're going to take a break. MR. 'FEIN: We're not taking a break unless the witness needs a break. You're obstructing this deposition, Ted. MR. LEOPOLD: Come on, You all want to continue in this demeanor -- MR. TEIN: You're obstructing the deposition. Stop making speeches. We're not discussing this with you. The questions are to your client. Go take your five-minute break. MR. LEOPOLD: Fine. We need to make sure the record's clear and clean. And I want. to make sure, as I've already asked you -- I know that you're one of the best in town -- that this audio -- this needs to be preserved. Okay? MR. TEIN: Go take your five-minute break, Mr. Leopold, now. Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 42 at 616 EFTA00231054 Case 9:O8-cv-8O8O4-KAM nt 1 Entered on FLSP Docket 07/21/2008 Page 43 of 100 nsor & Associates ReportivE aad Trauctipdm, lac. 1 2 3 back. 4 Page 17 You were supposed to be here at nine a.m.; it's now after two. Take your break and come MR. LEOPOLD: Okay. If the demeanor keeps 5 up, we will not be here beyond those five minutes. 6 7 8 relax. 9 10 break. 11 MR. GOLDBERGER: Let them take that 12 five-minute break. 13 MR. LEOPOLD: But I would suggest that you 14 take deep breaths. 15 MR. TEIN: Suggest whatever you want. Go 16 take a break. 17 (Thereupon, a recess was taken.) 18 BY MR. TEIN: 19 Q. 20 today at your deposition is something very serious, don't 21 you? 22 A. Yes. 23 Q. And you respect the court, don't you? MR. TEIN: Take your break and come back. MR. LEOPOLD: Okay. So I suggest that you MR. TEIN: I suggest that you take your rialfyou agree that giving testimony 24 A. Yes. 25 0. Let me show you Exhibit 31-001. Can you Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 430316 EFTA00231055 Case 9:08-cv-80804-KAM nt 1 Eotterod on FLSD Docket 07/21/2008 Page 44 of 100 sor H,55OClate5 Ropartrnp and 1 ranacri pnon. Inc. Page 18 1 read that out loud, please. 2 A. Okay. What do you want? 3 Q. Will you read that out loud, please. 4 A. Oh. 5 Q. Thank you. 6 A. Lol hah my baddd...lol yah i got some 7 stupid court shit on the 20th...bullshit...and damn you 8 still have court shit with him? Like after so long wow 9 im sorry... well yah well we will definitely havta make 10 plans for sure..because i miss u tons times a million and 11 no no no i love you...o and p.s. i love ur default pic 12 niggaa. Muah xo. 13 Q. Did you send that message last week to a 14 friend of yours on MySpace? 15 A. I wouldn't know. There's no dates and I've 16 deleted that MySpace, so -- 17 O. We're going to talk about that in a second. 18 A. Okay. 19 Q. Did you send that message last week -- 20 A. Right. 21 Let me finish my question. 22 Did you send that message last week to a 23 friend of yours on MySpace? 24 A. I wouldn't know the date, but obviously, 25 it's to a friend. Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 44031f EFTA00231056 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 45 of 100 sor & Associates Reponinp and Transcripaw, 1 2 3 4 5 6 7 8 Page 19 Q. Did you send that message to a friend of yo.frs on MySpace? A. Sure, yes. Q. Were you referring to this deposition? A. Yes. Q. Do you find the term n-i-g-g-e-r offensive? A. That's not anywhere in there. Q. What word did you use in there? 9 MR. LEOPOLD: Where are you referring to, 10 Counsel? There's 20 plus words in there. 11 MR. TEIN: Don't make a speaking objection. 12 THE WITNESS: Are you referring to 13 anything -- 14 MR. LEOPOLD: No, Don't -- don't 15 let him ask you the question. 16 BY MR. TEIN: 17 Q. What question were you asking, Ill? 18 MR. LEOPOLD: She doesn't ask questions. 19 You ask the questions. What is the question 20 pending? 21 BY MR. TEIN: 22 Q. what is the last word on there in 23 the text of your message—before the closing?- 24 A. Niggaa. 25 Q. Don't you find that term offensive? Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 4501316 EFTA00231057 Case 9:08-cv-80804-KAM nt 1 Entered on FLSD Docket 07/21/2008 Page 46 of 100 nsor & Associates Reportins. and Transcription, /nt Page 20 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. No. MR. LEOPOLD: Can you spell it for the record, please. THE WITNESS: N-i-g-g -- MR. TEIN: No, no, no. You are not going to be asking questions. MR. LEOPOLD: I'm not asking questions. I'm asking for the record the word to be spelled, because we don't have a video here today. MR. TEIN: These exhibits are part of the record. You -- MR. LEOPOLD: Well, it's not marked as an exhibit. MR. TEIN: Stop interrupting me, Mr. Leopold. I have marked and identified as an exhibit and you will get it. MR. LEOPOLD: There has been no identification of this document in the record. MR. TEIN: Mr. Leopold, stop interrupting this deposition. MR. LEOPOLD: What is the exhibit number marked for identification? MR. TEIN: 31-001. MR. LEOPOLD: Do we have copies? Is it on the record anywhere? Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 44.1311 EFTA00231058 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 47 of 100 nsor & Associates Reporting and Transcription, Inc. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Q. And you think this deposition is bull 19 s-h-i-t, don't you? 20 21 22 Page 21 BY MR. TEIN: Q. Let me ask you, did you in fact write your friend this message about this deposition? A. Yes. Q. So you wrote your friend that this deposition is stupid court s-h-i-t, correct? A. Yes. Q. Because you think this deposition is stupid court s-h-i-t, don't you? A. No. Q. You wrote that to your friend, didn't you? A. Yes. Q. You think that court is stupid, don't you? A. In some cases. Q. And you think that court is bull s-h-i-t, don't you? A. No. A. No. Q. You wrote that to your friend, didn't you? MR. LEOPOLD: Objection. Asked and 23 answered. 24 25 BY MR. TEIN: MR. TEIN: That's not an objection. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 47 e131$ EFTA00231059 Case 9:08-cv-80804-KAM nt 1 Entered on FLSD Docket 07/21/2008 Page48of100 sor & Associates Ropontng end Transcririon, 1. 2 .3 4 Page 22 Q. You wrote that to your friend, didn't you? MR. LEOPOLD: Objection. Asked and answered, for the fourth time. MR. TEIN: You are improperly objecting, 5 Mr. Leopold. You have no grounds to object. And 6 that's not an objection. 7 MR. LEOPOLD: It is an objection. 8 MR. TEIN: Then terminate the deposition if 9 you think it's been asked and answered. 10 N.R. LEOPOLD: Counsel, I am not precluded 11 from just making an objection to the form of the 12 question. As the courts well know, and if you 13 practice here in West Palm Beach, many of the 14 judges require you to set the objection with 15 specificity. And I will do that. And if you 16 don't want me to, you can make the record. But I 17 will do that. 18 MR. TEIN: Here's what we'll do, Ted. You 19 can -- I will allow you to reserve an objection to 20 form for every single one of my questions. 21 Otherwise, all you're doing is obstructing. 22 23 MR. TEIN: Of course; because you want to 24 obstruct. 25 MR. LEOPOLD: All right. MR. LEOPOLD: I won't do that. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 Hot316 EFTA00231060 Case 9:08-cv-80804-KAM P ent 1 Entered on FLSD Docket 07/21/2008 Page 49 of 100 nsor & Associates Roporung end ITansoription. /he 8 9 10 11 12 Page 23 1 BY MR. TEIN: 2 Q. _you think that giving testimony 3 today, under oath, is bull s-h-i-t, don't you? 4 A. No. 5 Q. And you wrote that to your friend on 6 Myspace last week, didn't you? 7 MR. LEOPOLD: Objection. Asked and answered. THE WITNESS: No, I did not. BY MR. TEIN: Q. You didn't write this exhibit? A. I wrote that, but I didn't write what you 13 said. 14 4. 15 16 you write that? 17 18 19 20 21 22 about what happened when you went to Jeff Epstein's house You wrote in this exhibit, "I got some stupid court s-h-i-t on the 20th. Bull s-h-i-t." Didn't A. Yes. Q. Referring to this deposition, didn't you? A. Referring to the court. I was later informed that it was a deposition. Q. I'm going to ask you some questions now —2-3- three years 09e.—Okey-? 24 25 A. Oh-huh. Q. When the police interviewed you one month Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 4S of 316 EFTA00231061 Case 9:08-cv-80804-KAM D ment 1 Entered on FLSD Docket 07/21/2008 Page 50 of 100 sor & Associates tenoning and Transcription. Page 24 1 after you went to Epstein's house, you swore on your 2 mother's grave that you and Epstein did not engage in sex 3 of any kind? 4 A. Yes. 5 Q. Didn't you tell that to the police? 6 A. Yes. And I will continue. I have never 7 had sex with him. 8 Q. Did what happened upstairs at Jeff 9 Epstein's house take you completely by surprise,. 10 A. Yes. 11 Q. Now the civil complaint that you filed 12 against Mr. Epstein for fifty million dollars alleged 13 that you were totally shocked by what happened when you 14 got there. 15 A. Yes. 16 Q. Were you totally shocked by what happened 17 when you got to Epstein's house? 18 A. Yes. 19 Q. You didn't expect it at all, did you? 20 A. No. 21 Q. You had absolutely no idea why your friend 22 ias taking you to Epstein's house, right? 23 A. I was informed it was a massage. 24 Q. All you thought that it was going to be was 25 a massage, correct? Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 SO of 318 EFTA00231062 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 51 of 100 nsor & Associates Repnninp and T:anictipcion, lnc. 1 A. Yes. . Page 25 Q. Before you got to Epstein's house 3 never said anything to you on the telephone about sexual 4 activity with Epstein, did she? 5 A. No. 6 Q. And before you got to Epstein's house 7 lillillinever sent you a message over the Internet about 8 sexual activity with Epstein, did she? 9 A. No. - 10 Q. Did ever try to convince you to 11 engage in any sexual activity with Epstein? 12 A. No. 13 Q. Did every try to convince 14 you to engage in any sexual activity with Epstein? 15 A. I don't know who is. 16 Q. Do you have a friend IIIII? 17 A. No. 18 Q. Okay. Before you went so Epstein's house 19 did anyone call or e-mail you to induce you to engage in 20 sexual activity with Epstein? 21 A. No. 22 Q. So you're sure that before you got to 23 Epstein's house no one tried to persuade you to engage in 24 sexual activity with Jeffrey Epstein? 25 A. No. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 el EFTA00231063 Case 9:08-cv-80804-KAM ent 1 EnteredonFLS,DDocket07/21/2008 Page 52 of 100 nsor & Associates Rept-mins and Iran:dm:dice, lmc Page 26 1 O. You're sure that -- let me ask the question 2 again. 3 You're sure that before you got to 4 Epstein's house no one tried to persuade you to engage in 5 sexual activity with Epstein for money. Are you? 6 MR. LEOPOLD: Objection. Asked and 7 answered. 8 THE WITNESS: No. And I've already 9 answered that a bazillion times. 10 BY MR. TEIN: 11 Q. He's coaching you now. So I'm going to ask 12 the question -- 13 MR. LEOPOLD: Counsel, I've made an 14 objection for the record. 15 MR. TEIN: Stop speaking. 16 MR. LEOPOLD: I'm not going to stop 17 speaking. You can't interrupt me when I'm making 18 the record. 19 MR. TEIN: You're coaching the witness. 20 MR. LEOPOLD: Counsel -- 21 MR. TEIN: Stop coaching the witness. 22 BY MR. TEIN: 23 0. UM let me ask you -- 24 MR. LEOPOLD: If you continue to -- 25 MR. TEIN: Stop interrupting my questions. Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 112of 314 EFTA00231064 Case 9:08-cv-80804-KAM gg ~r ent 1 Entered on FLSD Docket 07/21/2008 Page53of100 nsor & Associates RepartenE and Trannyipuon. Inc 1 2 3 BY MR. TEIN: Page 27 MR. LEOPOLD: If you do it one more time, we're leaving. 4 O. MP 5 MR. LEOPOLD: I'm going to make the record. 6 You cannot interrupt me when I'm making the 7 record. Out of professional conduct, you cannot 8 do that. I'm entitled to make the record. I made 9 an objection, asked and answered. Your demeanor 10 is inappropriate. You're willing and you are able 11 and you're responsible to ask a question in a 12 professional manner, and ask the question and once 13 you get the answer, to either follow up on it or 14 move on, but not continuously browbeat and ask the 15 same question over and over because you don't like 16 the answer. 17 MR. TEIN: Calm down, sir. 18 MR. LEOPOLD: Trust me, I'm very calm here. 19 When I'm not calm, you'll know it. I'm very calm. 20 So please continue on. But I will not 21 allow you to continue to harass her in the 22 demeanor that you're doing. Ask her a question 23 and move on. 24 MR. TEIN: Are you done? 25 MR. LEOPOLD: Thank you. I am. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 53 o1316 EFTA00231065 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 54 of 100 nsor & Associates Repcontnp. and Tratictirmo, Inc. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 2.3 24 25 Page 28 MR. TEIN: Stop misrepresenting the record and calm down. I'm going to ask my question. Stop it. BY MR. TEIN: Q clear. MR. LEOPOLD: I think the record is very MR. GOLDBERGER: Let me just clarify something. When you object to the form of a question, you're not instructing the witness not to answer the question, are you? MR. LEOPOLD: No. And I'm not making that objection; only on attorney/client privilege. MR. TEIN: Will you stop speaking now so I can ask my question? Are you done? Okay. I'm going to ask my question. BY MR. TEIN: Q. Listen, IIIIII-- MR. LEOPOLD: Hold on. Stop. I've been doing this for 20 plus years and have met a lot of attorneys, but I've never had an experience like this where I've -- MR. TEIN: Stop your speeches. MR. LEOPOLD: If you continue to do this, whether it's with me or with my client, I will not Ph. Fax. 1655 Palm Beach Lakes Blvd.; Suite 500 - West Palm Beach, FL 33401 5401316 EFTA00231066 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 55 of 100 nsor & Associates Raped:lop and Tranicrildion, Page 29 1 2 3 Mr. Goldberger knows all this, because I know that 4 he wouldn't do this. So I will not put up with 5 it. And I think it's highly inappropriate to do 6 this with this child sitting here, the way you're 7 acting, primarily towards me, and I will not put 8 up with it. 9 MR. TEIN: Will you please stop your speech 10 so I can ask questions? 11 MR. LEOPOLD: So long as you act 12 professionally, I will do so. But if you continue 13 to do it this way, I will leave. 14 15 BY MR. TEIN: 16 Q. are you sure that before you got to 17 Epstein's house no one tried to persuade you to engage in 18 sexual activity with Epstein for money? 19 MR. LEOPOLD: Asked and answered. 20 Objection. L1 MR. TEIN: Did you get her answer? 22 THE COURT REPORTER: No, I did not. put up with it and I don't need to put up with it and it's not appropriate. And I'm sure MR. TEIN: Suit yourself. 23 THE WITNESS: I'm sure. 24 BY MR. TEIN: 25 Q. Let me ask you a few questions about your Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 6501316 EFTA00231067 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 56 of 100 sor & Associates Reporunp mid Transcripucct Inc Page 30 1 contact with Jeffrey Epstein. Okay? 2 A. (Witness nods head up and down.) 3 Q. Jeff never e-mailed you, did he? 4 A. No. 5 Q. Jeff never text messaged you, did he? 6 A. No. 7 Q. Jeff never chatted in a chat room with you, 8 did he? 9 A. No. 10 Q. Before you got to Epstein's house you had 11 never spoken to Jeff, had you? 12 A. No. 13 Q. And before you got to Epstein's house you 14 had never met Jeff? 15 A. Correct. 16 Q. Before you got to Epstein's house you had 17 never told Jeff that you were under 18, right? 18 A. No. 19 Q. Before you got to Epstein's house had you 20 ever told Jeffrey that you were under 18? 21 A. No. I never spoke to the man before that. 22 Q. And you only went to Jeff Epstein's house 23 that one time three years ago, correct? 24 A. Yes. 25 Q. You never went there again, correct? Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 540311 EFTA00231068 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 57 of 100 nsor & Associates Reporting and Transcrtpt.nn, loc. Page 31 1 A. No. 2 Q. All right. Let me ask you two final areas 3 of questioning about this and we'll move onto something 4 else. Okay? 5 A. Uh-huh. Yes. I'm sorry. 6 Q. Before you got to Epstein's did anyone 7 associated with Epstein ever call you on the phone and 8 try to persuade, induce, entice or coerce you to engage 9 in any sexual activity? 10 A. No. 11 Q. Before you got to Epstein's did anybody 12 associated with Epstein ever contact you on the Internet 13 and try to persuade, induce, entice or coerce you to 14 engage in any sexual activity? 15 A. No. 16 O. IIIII who told you that when you got to 17 Jeff Epstein's house you should lie to Jeff about your 18 age? 19 A. 20 Q. Was it or was it the other girl in 21 the car who you rode over with to Epstein's house? 22 A. 23 Q. Who was the other girl in the car with you 24 that day? 25 A. I honestly don't know. Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 570316 EFTA00231069 Case 9:08-cv-80804-KAM ment 1 Entered on FLSD Docket 07/21/2008 Page 58 of 100 nsor & Associates Rona/in, and Traniciiption. Inc Page 32 1 Q. Had you ever seen her before? 2 A. No, sir. 3 Q. You told the police that when you rode over 4 to Epstein's you had no idea who she was, right? 5 A. Correct. 6 O. You told the police that you didn't know 7 her name, but she was like really dark, kind of like a 8 Spanish girl? 9 A. Yes. 10 Q. Those were your words, right? 11 A. Yes. 12 Q. Do you now know who she is? 13 A. No, sir. 14 Q. So it was who told you to lie about 15 your age to Jeff Epstein? 16 A. Yes, sir. 17 Q. And "Ill' told you that if you weren't 18, 18 Epstein wouldn't let you into his house, right? 19 A. That's -- yes, yes. 20 Q. All right. Let's talk for a minute about 21 when you first met Jeff. Okay? 22 A. Sure. 23 Q. When you first met Jeff he tried to find 24 out how old you were, right? 25 A. Excuse me? Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 58.4316 EFTA00231070 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 59 of 100 nsor & Associates Ropnrtinp aiul Trartscripnon. lnc. 1 2 out how old you were, right? Page 33 Q. When you first met Jeff he tried to find 3 A. Not when we first introduced each other; 4 when we get upstairs, then, yes. 5 Q. During the massage Jeff asked you how old 6 you were, correct? 7 A. Yes, yes. 8 Q. Now hadn't you already told Jeff's 9 ass:.stant, the one who walked you upstairs, that you went 10 to college and had just moved down here from Ohio? 11 A. I never spoke to the lady. 12 Q. Do you want to rethink that answer? 13 MR. LEOPOLD: Is that a question? 14 BY MR. TEIN: 15 Q. Do you want to rethink that answer? 16 A. No. I didn't really speak with her that 17 much. 18 Q. Do you want to try to refresh your memory 19 on that? 20 MR. LEOPOLD: Do you have something to 23. refresh her memory with? 22 MR. TEIN: Do you want to stop making 23 speaking objections? 24 MR. LEOPOLD: No. But to refresh someone's 25 memory, you show them a document. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 59013111 EFTA00231071 Case 9:08-cv-80804-KAM 4 Do ent 1 Entered on FLSD Docket 07/21/2008 Page 60 of 100 nsor & Associates Rowans and lraitscripacm. Inc Page 34 1 MR. TEIN: I know how to do this. 2 MR. LEOPOLD: Then show her a document. 3 MR. TEIN: Stop speaking. 4 MR. LEOPOLD: I'm not going to stop 5 speaking. I'm going to continue to make the 6 record. 7 MR. TEIN: You're obstructing. Please 8 stop. 9 MR. LEOPOLD: I'm not obstructing. But if 10 you want to refresh her recollection, you need to 11 show her something. 12 That's not a proper question. I object to 13 the foundation and the predicate of that question. 14 MR. TEIN: Are you done? 15 MR. LEOPOLD: I am now. Thank you. 16 BY MR. TEIN: 17 Q. Do you want to try to refresh your memory 18 as to whether you had any conversation with the woman who 19 walked you upstairs in Epstein's house in which you told 20 her that you went to college and had just moved down from 21 Ohio? 22 MR. LEOPOLD: Objection. Object to the 23 form of the question. Lack of foundation and 24 predicate. 25 BY MR. TEIN: Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 4001316 EFTA00231072 Case 9:08-cv-80804-KAM ent 1 teredonFLS,DDocket07/21/2008 Page 61 of 100 nsor Associates Roportiap anti Transcript'''. Inc 1 2 3 4 5 6 7 Page 35 Q. You can answer the question. A. Sure. Q. Is there anything that would refresh your memory that in fact you told Mr. Epstein's assistant, the one who walked you upstairs, that you went to college and you had just moved down here from Ohio? A. I don't remember saying that, but if you -- 8 I don't remember saying that myself, so -- 9 Q. That would be a lie, right? 10 A. No. I really don't remember. 11 Q. So you told Jeff that you were 18 years 12 old, correct? 13 A. Yes. 14 Q. Do you remember Detective of 15 the Police Department, Palm Beach Police Department? 16 A. Yes. 17 Q. Do you remember you spoke to her? 18 A. Yes. 19 Q. Do you remember that you told Detective 20 that when you lied about your age to Jeff you said 21 it really fast because you didn't want to make it sound 22 like you were lying? 23 ---Ar-I-denit remember-the-words exactly, but-I-- 24 do remember telling her I told him I was 18. 25 Q. And do you remember telling Detective Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 61 a 316 EFTA00231073 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 62 of 100 nsor & Associates Repot:ins and Transcription, Inc Page 36 1 that when you lied to Epstein about your age that you 2 said it really fast so Epstein wouldn't realize you were 3 4 A. No, I don't remember saying those words 5 exactly to her. 1 remember telling her that I told 6 Epstein I was 18. 7 0. Does it sound right to you that you told 8 Detective that you said your age really fast to 9 Epstein -- 10 MS. BELOHLAVEK: Objection. Asked and 11 answered. 12 BY .MR. TEIN: 13 Q. -- so he wouldn't think that you were 14 lying? MR. LEOPOLD: Objection. Asked and 16 answered, lack of foundation, mischaracterization 17 of her earlier testimony. She's already answered 18 that question. 19 BY MR. TEIN: 20 Q. You can answer it. 21 MR. LEOPOLD: Same objection. It's been 22 asked and answered. 23 You can answer. I'ye made the objection. 24 THE WITNESS: I forget the question, now. 25 Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 62 o1316 EFTA00231074 Case 9:08-cv-80804-KAM 4Agrnent 1 Entered on FLSD Docket 07/21/2008 Page 63 of 100 sor & Associates Rep:smut lranscririon, Inc Page 37 1 BY MR. TEIN: 2 Q. Let me put it again. 3 Does it sound right to you that you told 4 Detective that when you lied about your age to 5 Jeffrey Epstein, you said it really fast because you 6 didn't want to make it sound like you were lying? 7 MR. LEOPOLD: Objection. Lack of 8 foundation, asked and answered. 9 THE WITNESS: I could have possibly said 10 that, yes. 11 BY MR. TEIN: 12 Q. You didn't want Mr. Epstein to know that 13 you were lying about your age, right? 14 A. Correct. 15 Q. You didn't want Mr. Epstein to know that 16 you were not 18 yet, right? 17 A. Correct. 18 Q. You wanted Mr. Epstein to believe that you 19 really were 18, right? 20 A. Correct. 21 Q. Do you remember when Mr. Epstein asked 22 where you went to school? 23 A. Yes. 24 Q. And you told Mr. Epstein you went to 25 Wellington, right? Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 I33 0I111 EFTA00231075 Case 9:08-cv-80804-KAM 4D iorent 1 Entered on FLSD Docket 07/21/2008 Page 64 of 100 nsor & Associates kg:Toning add Tansciirinn, Inc Page 38 1 A. Yes. 2 Q. Was that the truth? 3 A. No. 4 Q. In fact, you went to Royal Palm, right? 5 A. Yes. 6 Q. So you lied to Mr. Epstein again, correct? 7 A. Yes. 8 Q. Is Wellington the college that you told 9 Jeff's assistant that you were attending? 10 A. I don't remember having that conversation 11 with her, so I wouldn't know if that's what I said. 12 Q. That was a lie, though, wasn't it? 13 MR. LEOPOLD: Objection to the form of the 14 question, lack of foundation. You're making an 15 assumption. She just answered you she can't tell 16 you that. 17 MR. TEIN: Speaking objection. And you 18 well know that, Mr. Leopold. 19 MR. LEOPOLD: She can't answer that 20 question. The way you phrased that question, 21 you're purposely making her not be honest in her 22 testimony. She can't answer a question like that. 23 She doesn't remember. So then you say, "So you 24 were lying." That's improper and you know that. 25 That's not a proper question. And any attorney Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 14.1311 EFTA00231076 Case 9:08-cv-80804-KAM D c went 1 Entered on FLSD Docket 07/21/2008 Page 65 of 100 sor & Associates Reporting and Triune:in:ion. Inc Page 39 1 that would do that to a witnesses or to a person 2 that's sitting in this chair is not acting 3 professionally. You can't ask a question like 4 that. You can do it, but it's not proper. And 5 I'm sure you weren't trained that way, certainly 6 not ethically. 7 MR. TEIN: Will you stop? 8 MR. LEOPOLD: I'm not going to stop, 9 because the way you're asking that question is 10 improper and you know it. 11 MR. TEIN: You're losing your cool. 12 BY MR. TEIN: 13 Q. ms. NM -- 14 MR. LEOPOLD: Trust me. I'm very calm. 15 When I lose my cool, you'll know it. 16 MR. TEIN: I do know it. 17 BY MR. TEIN: 18 Q. Ms. IIIIIIIII Mr. Epstein never asked you 19 to do anything other than massage him, correct? 20 A. incorrect; because he asked me to take off 21 my bra, so that would be two things he's asked me to do. 22 Q. Other than asking you to take your bra off, 23 Mr. Epstein never asked you to do anything with him other 24 than massage, correct? 25 MR. LEOPOLD: Objection. Foundation, Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 66 or 616 EFTA00231077 Case 9:08-cv-80804-KAM ent 1 gpteredonFL$DDocket07/21/2008 Page 66 of 100 nsor & Associates Repotting ad Tunic/intim, Inc. Page 40 1 predicate. 2 THE WITNESS: Correct. 3 BY MR. TEIN: 4 Q. You told the police, in your words, that 5 you did not whack him off, right? 6 A. Correct. 7 Q. What does that mean? 8 A. Whack, like whacking off? 9 O. Your term, what does that mean? 10 A. Masturbating. 11. Q. Mr. Epstein never tried at any time to grab 12 your hand, did he? 13 A. No. 14 Q. Mr. Epstein never tried to put your hand 15 anywhere, did he? 16 A. No. 17 Q. At no time did you touch Mr. Epstein's 18 penis, did you? 19 A. No. 20 Q. And he did not touch you, correct? 21 A. Incorrect. 22 Q. Well, you told the police, "At no time did 23 he touch me." Were you lying to the police then? 24 A. No. Well, I wasn't being fully truthful, 25 but I wasn't lying. Ph. Fax. 1655 Pam Beach Lakes Blvd., Suite 500 - West Palm Beath FL 33401 Illet316 EFTA00231078 Case 9:08-cv-80804-KAM Qgyfnent 1 Entered on FLSD Docket 07/21/2008 Page 67 of 100 nsor & Associates Repomig and Tranicription, Inc. 1 Page 41 Q. You told the police twice when you spoke to 2 that "at no time did he touch me." Didn't 3 you say that to the police? 4 A. Yeah. 5 Q. And you're saying that that was not fully 6 truthful. Is that what you're saying now? 7 8 A. Correct. Q. And you're saying if you're not fully 9 truthful, that's not a lie. Correct? 10 A. You took that out of context like really 11 bac. I didn't mean like that. Touching my legs and 12 he never kept his hands to himself the entire time. 13 That's what I'm trying to say. 14 Q. You told the police, "At no times did he 15 touch me." You agree with that, correct? 16 A. No, I don't agree with that, because he did 17 touch me. 18 Q. Did you tell the police that he did not 19 touch you, yes or no? 20 A. It's a possibility, but I do not remember. 21 Q. Okay. And you did not have any type of sex 22 with Jeff, correct? 23 A. No. 24 Q. And you did not have any type of oral sex 25 with Jeff, correct? Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 67 ol 311 EFTA00231079 Case 9:08-cv-80804-KAM D ent 1 Entered on FLSD Docket 07/21/2008 Page 68 of 100 sor & Associates Ronan Ins and Trariscripunn.loc Page 42 A. No. 2 Q. No type of intercourse with Jeff, correct? 3 A. Correct. 4 Q. All right. Let's talk about what happened 5 after the massage was over. 6 A. Okay. 7 Q. After the massage, you told Epstein that 8 you wanted to bring your twin sister back so she could 9 make some money, correct? 10 A. Incorrect. 11 Q. Your twin sister is IIIIII right? 12 A. Correct. 13 Q. And you love -very much, don't you? 14 A. Yes. 15 Q. And when you left the house you were joking 16 with the other girls, weren't you? 17 A. Incorrect. 18 Q. Well, when Mend the other girl in the 19 car that day made their statements to the police they 20 told the police that you were joking afterwards. Are you 21 saying that they were lying to the police about that? 22 A. No. But a question or -- questions from 23 like she asked me questions, but it wasn't 24 joking. She was kind of like in a happy way, like, "Oh, 25 what did you do? What did you do?" Like those kind of Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 OS of 311 EFTA00231080 Case 9:08-cv-80804-KAM Docummnt 1 Entered on FLSD Docket 07/21/2008 Page 69 of 100 nsor & Associates Roporting And Tranactiptim, ≥nr. Page 43 1 2 3 4 5 6 7 8 things, but it wasn't joking about it at all. Q. You joked about it, didn't you? A. No. Q. You said to IIIIIII that if you did this every weekend you'd be rich, didn't you? A. No. That's what told me. Q. You didn't tell that to MR. LEOPOLD: Objection. Asked and 9 answered. 10 11 BY MR. TEIN: 12 Q. After you left Epstein's house you took the 13 money and you went shopping with and the other 14 girl in the car, correct? 15 16 money. 17 Q. 16 19 Q. 20 didn't you? 21 MR. LEOPOLD: Objection. 22 THE WITNESS: No. A. Incorrect. I didn't spend any of the You went to Marshall's, didn't you? A. I went along, yes, but I didn't -- You went shopping with them at Marshall's, THE WITNESS: I guess you could say that. 23 MR. LEOPOLD: Objection. Lack of predicate 24 and foundation. Mischaracterization of earlier 25 testimony. Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 66 of 516 EFTA00231081 Case 9:08-cv-80804-KAM D ent 1 Entered on FLSD Docket 07/21/2008 Page 70 of 100 nsor & Associates Reporting, And Tranacriptton, Inc. Page 44 1 BY MR. TEIN: 2 Q. And IIIIIIrbought a purse, right? 3 A. Yes. 4 Q. And you were with her the whole time at 5 Marshall's, correct? 6 A. Yes. 7 Q. Now tell me about when the federal 8 prosecutors told you about getting reimbursed. 9 A. I have no idea what you're talking about. 10 Q. Tell me about when the federal prosecutors 11 spcke to you about getting money you feel you're entitled 12 to from Mr. Epstein. 13 A. I don't know what you're talking about. 14 Q. Do you know who is? 15 A. No, sir. 16 Q. Did you ever meet with any federal 17 prosecutors? 18 A. I think -- yeah. I think they were I 19 think they were like FBI. 20 Q. Uh-huh. Did you meet with federal 21 prosecutors? 22 A. They came to my house one time, yes. ?3 Q. When did they come to your house? 24 A. Very long ago. 25 Q. Was it this year, 2008? Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 70 of 315 EFTA00231082 Case 9:08-cv-80804-KAM ent 1 iltered on FLSD Docket 07/21/2008 Page 71 of 100 sor & Associates Repaning one Transcriptive, Inc. Page 45 1 A. It was not this year, no. 2 Q. Was it 2007? 3 A. I'd have to say at least two years ago or a 4 year ago, yeah. So it would be 2007, 2006; but it was a 5 while ago. 6 Q. How many federal prosecutors or FBI agents 7 came to your house? 8 A. I'm trying to remember. I want to say four 9 people came. 10 Q. Did they give you their business cards? 11 A. If they did, I don't remember, and they 12 weren't toward me. Maybe my parents have them. I don't 13 know. 14 Q. Did they give you their cell phone numbers? 15 A. No. 16 Q. Did you ever speak to them on their cell 17 phones? 18 A. No, sir. 19 0. Did they speak to your parents? 20 A. That's something you'd have to ask my 21 parents. 22 O. Do you know whether they spoke to your parent' 24 A. No, sir. 25 Q. You have no idea? Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 11 0131! EFTA00231083 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 72 of 100 sor & Associates Ktriormis an4 Transcriponn, inc. Page 46 1 A. No, sir. 2 MR. LEOPOLD: Objection. Asked and 3 answered. 4 BY MR. TEIN: 5 Q. So if I say the name to you 6 , you don't know who that is? 7 A. No, sir. 8 Q. How many women and how many men came to 9 your house? 10 A. : want to say two ladies and two guys. 11 Q. Did someone named come to 12 your house? 13 A. I don't know names, sir. 14 Q. Do you know who is? 15 A. No, sir. 16 Q. Do you know who Jeffrey Herman is? 17 A. Yes. 18 Q. That's the lawyer who first sued Epstein on 19 your behalf, right? 20 A. Yes. 21 Q. Has Mr. Herman advanced your family any 22 money? 23 MR. LEOPOLD: Any conversations that you've 24 had with Mr. Herman regarding that issue, you are 25 not to disclose. If you've learned in some other Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 72 of 316 EFTA00231084 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 73 of 100 sor & Associates Repartrns and Tann )nc. a 2 3 fashion, you may answer. THE WITNESS: Okay. I wouldn't know. Page 47 4 BY MR. TEIN: 5 Q. You don't know? 6 A. No. 7 MR. LEOPOLD: Objection. Foundation. 8 Attorney/client privilege. 9 BY MR. TEIN: 10 Q. And you say you don't know who 11 is? 12 A. No, sir. 13 Q. Does it refresh your recollection that he's 14 the number two prosecutor at the U.S. Attorney's Office? 15 A. No. 16 Q. That he's boss? 17 A. No. 18 Q. Does it refresh your memory that he's the 19 ex-partner of Jeff Herman, the first lawyer who sued 20 you -- sued Mr. Epstein on your behalf for fifty million • 21 dollars? 22 A. No, sir. I don't know who he is. 23 Q. Without telling me any conversations that 24 you've had with your lawyers, how is it that you selected 25 Mr. Herman as your lawyer from the 81,000 members of the Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 73 M310 EFTA00231085 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 74 of 100 nsor & Associates Reponing aid Tram ripurm, Inc 1 2 Page 48 Florida Bar? A. I did not select him. 3 Q. Who did? 4 A. My father. 5 Q. Did you ever meet Mr. Herman? 6 A. Once. 7 Q. Don't -- don't tell me what you discussed 8 with him. Where did you meet him? 9 A. I was shopping in my -- he showed up at my 10 friend's house. 11 Q. Whose house? 12 A. My friend 13 Q. Is that =from the Quarterdeck 14 Tavern? 15 A. Yes. 16 Q. And did you have a meeting with him at 17 house? 18 A. Yes. I guess you could say that. 19 Q. And who else was there? 20 A. My Aunt fia 21 Q. And what was that meeting about? 22 MR. LEOPOLD: Objection. That calls for 23 attorney/client privilege. 24 BY MR. TEIN: 25 Q. What discussions did you have with Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 74 a 316 EFTA00231086 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 75 of 100 nsor & Associates °porting nail Transcriptuon, Inc. Page 49 1 Mr. Herman in the presence of 2 A. None. 3 Q. What discussions did you have in the 4 presence of her aunt? 5 A. Of my aunt? 6 MR. GOLDBERGER: It's the witness's aunt. 7 BY MR. TEIN: 8 Q. Oh, of your aunt. 9 A. The only one that we've ever discussed or 10 ever had. 11 Q. And so you were in a conversation with 12 Mr. Herman and your aunt? 13 A. Yes, sir. 14 Q. And you discussed privileged matters during 15 that conversation? 16 MR. LEOPOLD: Object to the form. I think 17 you might have to educate her on that question. 18 BY MR. TEIN: 1.9 Q. You discussed the lawsuit? 20 A. Yes. 21 Q. Did toll you about any 22 conversations that she had with Mr. Herman? 23 A. As far as I'm concerned, she's never spoken 24 or she's never had a conversation. She only opened the 25 door and then left. She's the one who answered the door. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 7$ of 316 EFTA00231087 Case 9:08-cv-80804-KAM D ent 1 Entered on FLSD Docket 07/21/2008 Page 76 of 100 nsor & Associates Reponinp and Transcription, Inc. Page 50 1 Q. Why did the meeting take place at 2 Mouse? 3 A. I spent the night that night at her house 4 Q. And when was this? 5 A. A while ago. 6 Q. How long ago? 7 A. A month and a half ago. I'm guessing. 8 Q. A month and a half ago? 9 A. Uh-huh. 10 Q. So was it before of after Mr. Herman filed 11 the fifty-million-dollar lawsuit against Epstein? 12 A. After. 13 Q. Did you meet with an FBI agent named 14 , a woman? 15 A. I don't know. 16 Q. Did Ms. speak to you about 17 getting reimbursed from Mr. Epstein? 18 A. I've never had a discussion with anyone 19 about getting reimbursed from Mr. Epstein. 20 Q. Have you met with an agent named 21 22 A. Not to my knowledge. 23 Q. How about an agent named 24 A. No, sir. 25 Q. How about an agent named Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 lief 311 EFTA00231088 Case 9:08-cv-80804-KAM Do 4 ent 1 Entered on FLSD Docket 07/21/2008 Page 77 of 100 n5or & Associates Remitting and Trinariptiom, Inc. Page 51 A. No. 2 Q. And we've learned that many of the girls, 3 some of whom are as old as 23, were told by the 4 government that they would get money at the end of the 5 criminal prosecution. Does that sound familiar to you?' 6 A. No, sir. 7 Q. Other than Mr. Leopold here -- I'm not 8 asking about Mr. Herman either -- 9 A. Uh-huh. 10 Q. -- did anyone ever discuss with you that 11 yot could get reimbursement for your damages? 12 A. No, sir. 13 Q. Did you or any member -- 14 MR. LEOPOLD: Are you referring to a 15 criminal matter or a civil matter? 16 BY MR. TEIN: 17 Q. Did you or any member -- 18 MR. LEOPOLD: Excuse me. Let me object to 19 the form of the question. 20 BY MR. TEIN: 21 Q. Did you or any member of your family ever 22 get a victim notification letter from anyone? 23 A. I no longer live at that residence and I 24 wouldn't know. 25 Q. So your testimony is that you have never Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 77 of 316 EFTA00231089 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 78 of 100 sor & Associates Roponctip, ad Tnnuripwn,dnc. • . Page 52 1 regftytd a victim notification letter, correct? 2 rect. 3 Q. And your testimony is that you don't know 4 if your parents have ever received a victim notification 5 letter, correct? 6 A. Correct. 7 Q. Have you given any evidence to prosecutors 8 or law enforcement in this case? 9 A. What do you mean by evidence? 10 Q. Well. Anything that you can touch or feel. 11 A. No. 12 MR. LEOPOLD: Objection to the form of the 13 question. 14 BY MR. TEIN: 15 Q. So you haven't given anything physical -- 16 A. No. 17 Q. -- any item to any prosecutor, police 18 officer or law enforcement agent, correct? 19 A. My cell phone four years ago or three years 20 ago, but that's it. 21 O. You gave your cell phone to whom? 22 A. 23 Q. Did she keep it? 24 A. Ask her. 25 Q. You gave it to her and then you didn't get na4b .1•••••••• ••••• Yd.* ••••• 71 e1311 Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 EFTA00231090 Case 9:08-cv-80804-KANA Document 1 7)M 70 Entered on FLSD Docket 07/21/2008 Page 79 of 100 nsor & Associates Reporting and Transc option. Inc 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21. 22 Page 53 it back at the end of the meeting? A. No. They -- yeah. No. They have it. I'm guessing. I don't have it. Q. How much money are you hoping to get out of Mr. Epstein? MR. LEOPOLD: Objection to the form of the question. Attorney/client privilege. BY MR. TEIN: Q. How much money are you hoping to yourself, hoping to get out of Epstein? MR. LEOPOLD: Same. Same objection, attorney/client privilege. Don't answer the question. BY MR. TEIN: you. get, you, Q. I'm not asking about what your lawyer told MR. LEOPOLD: I'm instructing her not to answer the question, because any of those conversations involve her counsel. MR. TEIN: Certify that. MR. LEOPOLD: Please. CERTIFIED QUESTION 23 BY MR. TEIN: 24 Q. Now, you lied to get out of this 25 deposition, didn't you? •••••••••• Ph. Fax. . 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 I EFTA00231091 Case 9:08-cv-80804-KAM Document 1 80 of 318 Entered on FLSD Docket 07/21/2008 Page 80 of 100 sor & Associates Ropnnung and Tranticription. Inc 1 A. No, sir. 2 Q. Page 54 You didn't want to come to court today and 3 tell the story that you had told to the police under 4 oath, did you? 5 MR. LEOPOLD: Object to the form of the 6 question. Lack of foundation, predicate. 7 THE WITNESS: No. I have no problem coming 8 here and talking to you. 9 BY MR. TEIN: 10 Q. And to avoid getting served with a lawful 11 subpoena, you lied about your name, didn't you? 12 A. No. 13 Q. And in fact, just lying yourself wasn't 14 enough, was it? 15 MR. LEOPOLD: Objection to the form of the 16 question. 17 Don't answer it. It's not a question. 18 19 of foundation. 20 MR. TEIN: Are you instructing her not to 21 answer? 22 MR. LEOPOLD: I am. 23 MR. TEIN: Certify it. 24 MR. LEOPOLD: Please. 25 object to the form of the question. Lack Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 EFTA00231092 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 81 of 100 Ssor & Associates nRoporunE end Traasciipcion, Inc. Page 55 1 CERTIFIED QUESTION 2 BY MR. TEIN: Q. You asked your co-workers -- 4 MR. LEOPOLD: It's vague and ambiguous. 5 BY MR. TEIN: 6 Q. You asked your co-workers at the 7 Quarterdeck Tavern to lie for you, didn't you? 8 A. No. I informed my boss about what was 9 going on and he told me that he would help in any way 10 that he can. 11 Q. Okay. You got your friend to lie 12 by switching name tags with you, correct? 13 A. Incorrect. It was a coincidence that same 14 night she was not wearing her name tag; she was wearing 15 mine. But I was also not wearing -- I was wearing my 16 name tag. Everyone switches name tags. It just so 17 happens it was a coincidence that same night the people 18 came with the papers. 19 MR. TEIN: Will you put up Exhibit 18-001? 20 MR. GOLDBERGER: And mark 18-001 for 21 identification purposes to this deposition. 22 MR. LEOPOLD: None of them have been marked 23 yet. Can we mark them and put them as attachment 24 to the depositions? Because I think you've shown 25 three photos now. And this is the only one that Ph. Fax. 1655 Paim Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 II of 316 EFTA00231093 Case 9:08-cv-80804-KAM I D ent 1 Entered on FLSD Docket 07/21/2008 Page 82 of 100 sor 8,z Associates Rowans and Tranunpoce. lat. Page 56 1 has been marked for identification yet. 2 BY MR. TEIN: 3 Q. all -- 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. LEOPOLD: Okay. Then don't speak to me 8 then. But I'll speak to Mr. Goldberger, perhaps. 9 But at least for the record, can we put on 10 the record what the previous two photographs were 11 marked for identification? 12 MR. GOLDBERGER: We will make sure that the 3 record is clear at the end of the deposition so 14 that there's no ambiguity. 15 MR. LEOPOLD: Thank you. 16 BY MR. TEIN: 17 Q. ea I've put a photograph marked 18-001 18 up on the screen. Do you see that? 19 A. Yup. 20 Q. Who is that in the photo? 21 A. the left and me on the right. 22 Q. a right? 23 A. Yes. 24 Q. a/ your friend at the 25 Quarterdeck Tavern, right? Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 Ili WM EFTA00231094 53 04 316 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 83 of 100 4 nsor & Associates Repertins and Transcorm. bc 1 A. Yes. Page 57 2 Q. your friend, who you say the day 3 that the process servers went to serve you with a 4 subpoena for this deposition, just happened -- just by 5 coincidence, was wearing your name tag? 6 A. Yes, sir. 7 Q. And just by coincidence, you were wearing 8 her name tag, correct? 9 A. Yes. 10 Q. Your testimony under oath is that's just a 11 coincidence, right? 12 13 14 15 16 17 18 19 20 21 A. Total honesty. Q. It just happens to be the day that you were going to be served with a subpoena, correct? A. That wasn't the first day that -- MR. LEOPOLD: just answer the question. It calls for a yes or no. THE WITNESS: Yes. BY MR. TEIN: Q. You said that wasn't the first day you were going to be -- you thought you were being served with a 22 subpoena, correct? 23 A. Correct. 24 Q. You knew before the day that you switched 25 name tags with that the process servers were Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 EFTA00231095 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 84 of 100 sor & Associates Rapornna and Transtriptial. Inc. Page 58 1 looking for you, didn't you? 2 A. No. I knew -- 3 MR. LEOPOLD: Just answer it. It calls for 4 a yes or no. 5 THE WITNESS: Okay. No. 6 BY MR. TEIN: 7 Q. Now you can explain the answer that your 8 counsel stopped you from explaining. 9 A. Okay. I work at Quarterdeck and people 10 were telling me that people were looking for me. So yes, 11 I was aware that people were searching for me. But I had 12 no :dee who they were or what their intentions were. But 13 1 thought they were just people I didn't want to talk to. 14 So 1 just didn't want to talk to them. And every time 15 they'd come to work I wasn't there. And so happens the 16 night that they came in me and my friend switched name 17 tags. No big deal. 18 Q. That's a lie, isn't it? 19 MR. LEOPOLD: Objection. Don't answer that 20 question. That's harassment and I will not allow 21 it. He could ask the questions and we'll allow a 22 jury to make that determination, but not counsel. 23 I will not allow her to answer that' 24 question. 25 MR. TEIN: Certify it. 84 04 31$ Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 EFTA00231096 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 85 of 100 sor & Associates RminniumWTrammorwm3m Page 59 1 MR. LEOPOLD: I'll certify it. 2 CERTIFIED QUESTION 3 She's answered that question. She's explained it five 4 tines already. The fact that Counsel doesn't like the 5 answer, that's a different query. 6 MR. TEIN: Stop making speaking objections. 7 MR. LEOPOLD: I'm not. I'm not going to 8 put up with it, because it's in appropriate, Jack, 9 and you know it. I will not allow Counsel to 10 berate a witness, whether it's in a criminal case 11 or a civil case, whether my client or -- 12 MR. TEIN: Calm down. 13 MR. LEOPOLD: Excuse me. 14 No, I'm not going to allow it. That is not 15 proper. 16 MR. GOLDBERGER: Okay. 17 MR. LEOPOLD: If he wants to say that she's 18 lying after asking it five times and her 19 explaining in great detail, he can do that. But 20 I'm not going to allow her to answer, nor be 21 harassed by him. It's improper. 22 MR. GOLDBERGER: Okay. But your response 23 that Counsel doesn't like the question -- or 24 doesn't like the answer -- just let me finish. 25 MR. LEOPOLD: Absolutely. I wasn't going 115t4311 Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 EFTA00231097 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 86 of 100 nsor & Associates Roportins and 'Franc ripen, ine Page 60 8 al 314 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 to interrupt you. MR. GOLDBERGER: Just requires us to say we like the answer to that question. And it's not you and I or you and Mr. Tein who are testifying here. It's the witness. MR. LEOPOLD: Fine. But after the sixth time of asking the same question and then coming back and pointing a finger at her and saying, "You're a liar" -- MR. TEIN: That didn't happen. MR. LEOPOLD: That's fine. But I'm not going to allow her to answer that question, because she's answered that same question and has explained it. Now Counsel might be sitting there rubbing his head with a migraine. That's his problem. But if he can't ask a question appropriately in a professional manner, we will leave. I will not allow her to be berated like that. MR. GOLDBERGER: Actually, we're very happy with the answer. MR. LEOPOLD: That's great. MR. GOLDBERGER: Do you want us to get into that? MR. TEIN: Ted -- Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 EFTA00231098 $7 of 316 Case9:08-cv-80804-KAM 4 iument1 Entered on FLSD Docket 07/21/2008 Page87of100 bsor & Associates Repot:ins and Mimic ripm. Inc. Page 61 1 MR. LEOPOLD: This is really big stuff that 2 you're going through. But that's fine; just ask 3 your question and move on. But do it one time. 4 If you don't understand it, I'll let you follow 5 up, but I'm not going to allow you to ask the same 6 question time and again and then call her a liar. 7 Just ask the question, get the answer and move to 8 the next subject matter. 9 MR. TEIN: Ted, I'm sitting right across 10 the table from you. 11 MR. LEOPOLD: Yes, sir. 12 MR. TEIN: Please be quiet. Don't yell. 13 MR. LEOPOLD: I will not be quiet. 14 MR. TEIN: Stop yelling. 15 MR. LEOPOLD: Lewis, when I'm yelling 16 you'll know it. I will not -- 17 MR. TEIN: My name is not Lewis. 18 MR. LEOPOLD: I thought your first name was 19 Lewis, Mr. Tein. 20 MR. TEIN: You watched me for three days at 21 the evidentiary hearing where you sat in the back 22 23 MR. LEOPOLD: Well, that's the impressio 24 you must have made in the courtroom. 25 1 will not be quiet. of the courtroom. You should know who I am. Ph. - Fax. 1655 Palm Beach Lakes B'vd., Su.te 500 - West Palm Beach, FL 33401 EFTA00231099 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 88 of 100 sor & Associates Rs:parting and Transcription. Inc Page 62 1 MR. TEIN: That's obnoxious. Stop being 2 obnoxious. It's stupid. Let's go ahead with the 3 questions. 4 MR. LEOPOLD: I will make the record. 5 MR. TEIN: Let's get on with the questions. 6 MR. LEOPOLD: Do you need a break? 7 (Thereupon, a recess was taken.) 8 BY MR. TEIN: 9 Q. Okay. after you told your manager 10 at the Quarterdeck Tavern everything that was going on 11 and he told you he would help you any way he could, he 12 hid you in the kitchen from the process servers, correct? 13 A. Incorrect. 14 Q. Isn't it true that lying to avoid service 15 is a meaningless lie to 16 A. Incorrect. 17 Q. What is your manager's name? 18 A. I have three. Would you like to know 19 all -- 20 Q. Who's the one who lied for you? 21 A. IIIIIIIIr 22 Q. And what did do to lie for you? 23 A. Said I wasn't there. 24 Q. And who did he tell wasn't there? 25 A. Ask him. Illet311 Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 EFTA00231100 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 89 of 100 Snsor & Associates Ronornns and ltanxripsion. Inc Page 63 1 Q. Where were you when IIIIIIrtold this 2 soreone that you were not at the Quarterdeck Tavern? 3 A. Eating nachos. 4 Q. At the Quarterdeck Tavern? 5 A. Yes. 6 Q. What did you do so that -would lie to 7 the process servers for you? B A. Nothing. 9 Q. You just got him to lie for you, didn't 10 you? 11 A. No. I had no influence on him saying I 12 wasn't there. 13 Q. He took that upon himself? 14 Isn't it true that Mr. Epstein's process 15 servers had to ask the police to get you out of the 16 restaurant so that they could serve you? 17 MR. LEOPOLD: Objection. Lack of 18 foundation, predicate. 19 BY MR. TEIN: 20 Q. You can answer the question. 21 MR. LEOPOLD: If you know. Don't guess. 22 THE WITNESS: No. Can you repeat the 23 question? 24 MR. TEIN: Don't coach. 25 MR. LEOPOLD: Don't guess. se\ I90316 Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 EFTA00231101 Case 9:08-cv-80804-KAM Doc ment 1 Entered on FLSD Docket 07/21/2008 Page 90 of 100 sor & Associates fteponing And Tranicription, ]roc Page 64 1 MR. TEIN: That's a coaching. 2 MR. LEOPOLD: No. That's an instruction to 3 the client. 4 MR. TEIN: No. You don't do that. 5 THE WITNESS: Can you repeat the question? 6 MR. LEOPOLD: Let me just state for the 7 record -- 8 BY MR. TEIN: 9 Q. Once the police -- isn't it true that 10 Mr. Epstein's process servers had to ask the police to 11 get you out of the restaurant so that they could serve 12 you? 13 A. Incorrect. My boss called the police. 14 Q. And once the police showed up, to stop you 15 from lying to avoid service, you made up another lie that 16 the process servers had harassed you. Isn't that 17 correct? 18 A. Incorrect. 19 Q. You lie all the time, don't you? 20 MR. LEOPOLD: Objection. 21 THE WITNESS: Incorrect. 22 BY MR. TEIN: 23 Q. You have a MySpace page, don't you? 24 A. No longer do I have a MySpace page. 25 deleted it. Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 DO of 314 EFTA00231102 Case 9:08-cv-80804-KAM Dcyment1 Entered on FLSD Docket 07/21/2008 Page 91 of 100 sor & Associates Raporsins and Trauctiptian, Page 65 1 Q. When did you delete your MySpace page? 2 A. A couple days ago. 3 Q. Who told you to take your MySpace page down 4 a couple of days ago? 5 A. Nobody. I'm sick and tired of MySpace. 6 Q. You all of a sudden got sick and tired of 7 MySpace and just a few days before this deposition you 8 decided to delete your MySpace page, correct? 9 A. Correct. 10 Q. Is that your testimony under oath? 11 A. Yes. 12 Q. Did you take your MySpace page down because 13 you thought the government might subpoena it? 14 A. Incorrect. 15 Q. Hadn't your MySpace page been up for over 16 three months before you took it down? 17 A. Correct. But I also had made tons of 18 MySpaces over the last years. I just get tired of them 19 and delete them because -- drama -- and make new ones. 20 Q. We're going to talk about that. 21 So you deleted your MySpace page after you 22 were already under subpoena for this deposition, correct? 23 24 25 A. Correct. Q. What about the MySpace page didn't you want us to see, lilt Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 91 of 314 EFTA00231103 1x0716 Case 9:08-cv-80804-KAM ument 1 Entered on FLSD Docket 07/21/2008 Page 92 of 100 sor & Associates Rapanistand Tramscripmen. lac. Page 66 1 A. Nothing. 2 Q. Well, we're going to come back to MySpace 3 in a second. 4 A. You do that. 5 0. going to ask you some questions 6 abo-it why you lie about your age so often, okay? 7 MR. LEOPOLD: Objection to the form. 8 Argumentative. 9 BY MR. TEIN: 10 Q. You lie about your age all the time, don't 11 you? 12 MR. LEOPOLD: Objection, argumentative. 13 THE WITNESS: Incorrect. 14 BY MR. TEIN: 15 Q. You lie about your age to get body 16 piercings, don't you? 17 A. Incorrect. 18 Q. You have body piercings, don't you? 19 A. Yes. 20 Q. You have four body piercings; isn't that 21 right? 22 A. Five. 23 Q. Other than the piercings on your ears 24 I'm not talking about that -- 25 A. Oh, then no; just one. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 EFTA00231104 Case 9:08-cv-80804-KAM DQc ent 1 Entered on FLSD Docket 07/21/2008 Page 93 of 100 sor & Associates Reportin and Tremscriptiaman. Page 67 1 Q. And where is the one body piercing? 2 A. Belly. 3 Q. When did you get that? 4 A. For my birthday, with my stepmother and my 5 father. 6 Q. And when was that? 7 A. When I was 14. 8 Q. Okay. So you had that body piercing when 9 you met Epstein, correct? 10 A. It might have been, or maybe that yeah, 11 either my 14th birthday or my 15th. I honestly don't 12 remember. 13 Q. Now you've lied about your age to get into 14 bars by using driver's licenses that aren't yours, 15 correct? 16 A. Incorrect. 17 Q. Are you swearing under oath that you've 18 never done that? 19 A. Yes, I swear under oath. 20 O. And you've lied about your age to buy beer, 21 correct? 22 A. Incorrect. 23 Q. You're swearing under oath that you've 24 never lied to stores about your age? 25 A. I've never lied to a store about my age or Ph. Fax. 1655 Pam Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 93.13111 EFTA00231105 Case 9:08-cv-80804-KAM D ment 1 Entered on FLSD Docket 07/21/2008 Page 94 of 100 nsor & Associates Ropnruifi and Itamictspan. Inc. Page 68 1 anything. 2 Q. You try to look much older than you are, 3 don't you? 4 A. Incorrect. 5 Q. And you've lied about your age on your 6 MySpace pages, don't you? 7 A. Incorrect. 8 Q. All right. Let's look at Exhibit 26-01 9 one. 10 MS. BELOHLAVEK: 26-001? 11 MR. TEIN: Yes. 12 BY MR. TEIN: 13 Q. On this page you lied to everyone that you 14 were 18, didn't you? 15 A. Correct. 16 Q. Let's go to Exhibit 33. 17 MS. BELOHLAVEK: That's 33-001? 18 TEIN: Correct. 19 BY MR. TEIN: 20 Q. On this page you lied to everyone that you 21 were 19, didn't you? 22 A. Incorrect. 23 MR. LEOPOLD: Just answer the question. 24 THE WITNESS: Oh, incorrect. 25 BY MR. TEIN: Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 94 x1016 EFTA00231106 Case 9:08-cv-80804-KAM D * ument 1 Entered on FLSD Docket 07/21/2008 Page 95 of 100 nsor & Associates Reparunp an, Transctipturi, Inc. Page 69 1 Q. Now you can explain your answer. 2 A. I know that I have seen all of these and I 3 know that this one is mine. 4 Can you go down? 5 MR. LEOPOLD: Just for the record, you're 6 pointing to the photo. 7 THE WITNESS: I'm pointing to -- 8 BY MR. TEIN: 9 Q. You're pointing to the one where it says 10 your age is 18? 11 A. Correct. 12 Q. That's yours, right? 13 A. Correct. That's mine from a couple years 14 ago that I have not been on, because I don't use that. 15 Please keep going down, please. And I think that's it, 16 because there's no one -- just that one is mine. 17 Q. So the one you pointed to where it says 18 your age is 18, that's yours, correct? 19 A. Correct. 20 Q. And when you wrote 18 as your age on your 21 MySpace page, that was a lie, wasn't it? 22 A. Correct. 23 Q. Did you lie about your MySpace page back 24 then because you couldn't post on MySpace unless you were 25 18? Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 9501311 EFTA00231107 Case 9:08-cv-80804-KAM Doc rnent 1 Entered on FLSD Docket 07/21/2008 Page 96 of 100 nsor & Associates Rertnni kg and Transcti pm. Inc Page 70 1 A. Correct. There was a rule many years ago 2 that you had to be 18 to have a MySpace. 3 Q. So you lied about your age so you could 4 post on MySpace, right? 5 A. Yes. 6 Q. Let's go back to the top one on this page, 7 33-01. 8 Are you testifying now under oath that this 9 MySpace page where the headline says, "Twins do have more 10 fun," and the location is given as Lox, abbreviation for 11 Loxahatchee, and the age is 19, and it says 12 it your testimony that you did not post 13 that? 14 A. Correct. 15 Q. Now let's go back to the one that you were 16 pointing to before on this page, where it says your age 17 is 18 and you lied about your age to post MySpace, okay? 18 A. Uh-huh, yes. 19 Q. All right. Why did you finally put your 20 true age on your MySpace profile four days before you 21 were scheduled to testify before the Grand Jury? 22 A. I don't know what you're talking about. 23 MR. LEOPOLD: If you don't understand, ask 24 him to ask the question again. 25 MR. TEIN: Don't coach. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 911.1311 EFTA00231108 Case 9:08-cv-80804-KAM D ment 1 Entered on FLSD Docket 07/21/2008 Page 97 of 100 sor & Associates koporunp, and Transcription, Jet. 1 2 3 4 5 6 7 8 9 10 11 12 13 15 16 17 18 19 20 21 22 Page 71 THE WITNESS: I don't know which MySpace you're talking about. BY MR. TEIN: Q. The MySpace page that you're just pointing to, where it says you were 18. A. Yes. Q. And you were lying about your age, right? A. Uh-huh. Q. Why did you finally post your true age on your MySpace profile -- A. Uh 4. -- four days before you were scheduled to testify before the Grand Jury? A. I honestly don't know which MySpace, because I've had like a bazillion MySpaces, and in that year, I had two, that one and another one, and that one's been deleted. So I don't know which one you're referring to. Q. You remember that you changed your age on your MySpace page from 18 to your true age just four days before you went and testified in the Grand Jury? A. No. 23 Q. You don't remember that. 24 A. No. 25 Q. Do you remember Detective Did you Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 Sr el 316 EFTA00231109 Case 9:08-cv-80804-KAM D . ent 1 Entered on FLSD Docket 07/21/2008 Page 98 of 100 sor & Associates Rerynrtilil and Tranactiptioc. lac. Page 72 1 ever meet a Detective 2 A. I don't know the names. Q. How many different detectives have you met 4 with on this case from Palm Beach? 5 A. Probably a good six or seven, maybe. 6 Q. Did one of the detectives tell you before 7 you testified in the Grand Jury that you should take your 8 MySpace age and put your true age? 9 A. No. 10 Q. Didn't Detective have to come to 11 your house to pick you up to get you to testify in front 12 of the Grand Jury? 13 A. Possibly; maybe because I didn't have a 14 ride; I was only 14 or 15 at the time. 15 Q. Your mom didn't drive you? 16 A. No. 17 Q. Stepmom didn't drive you? 18 A. I think my dad. Oh, my dad; my dad drove 19 me. 20 Q. Your dad drove you? 21 A. Yes, sir. 22 Q. So your testimony is Detective did 23 not drive you, correct? 24 MR. LEOPOLD: Objection. /asked and 25 answered. 4..AP •••• t• • • • • • • • • • • • • • • al • • • Is •••• IMO. 61 • • •••••••• Ph. Fax. 1655 Palm Beach Lakts Blvd., Suite 500 - West Palm Beach, FL 33401 1 MOHO EFTA00231110 Case 9:08-cv-80804-KAM D ent 1 Entered on FLSD Docket 07/21/2008 Page 99 of 100 sor & Associates Ramming and Transcription. inc. • Page 73 1 THE WITNESS: No. I'm pretty sure my dad 2 drove me, because he was there with me. 3 BY MR. TEIN: 4 Q. Did any detective tell you to change your 5 age on your MySpace page, to put your true age? 6 A. No, sir. 7 Q. Now you also lied on your MySpace page 8 about your income, didn't you? 9 A. Yes. 10 Q. And you lied, saying that you made a 11 quarter million dollars a year and higher, correct? 12 A. As a joke, yes. 13 Q. That was a lie, wasn't it? 14 A. Yes. 15 Q. And you also lied on your MySpace page, 16 saying that you were married, didn't you? 17 A. Possibly. And that might have been an 18 error on my part. 19 Q. Now you also lie to the police, don't you? 20 A. No. 21 Q. Well, you lied to the police in your 22 tape-recorded statement that you gave to Detective 23 three years ago, didn't you? 24 A. To my knowledge, no, I did not. 25 Q. Well, you lied to the police when you A. l•-•.•140, Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 Ili el 314 EFTA00231111 Case 9:08-cv-80804-KAM D ent 1 Entered on FLSD Docket 07/21/2008 Page 100 of 100 ii i liii • sor & Associates Ronarnnp and Transcription .1nc Page 74 1 accused Mr. Epstein of attempting to murder your father, 2 didn't you? 3 A. No. I never heard a statement saying that 4 Mr. Epstein tried to murder my father. 5 Q. You made that statement, didn't you? 6 MR. LEOPOLD: Do you have a statement to 7 show her? That's been asked and answered. 8 MR. TEIN: I'm sorry. I didn't hear the 9 witness' answer, Mr. Leopold. 10 BY MR. TEIN: 11 Q. a you told the police, didn't you, 12 that Mr. Epstein almost killed your father, didn't you? 13 A. No. 14 Q. Three years ago, before Mr. Epstein even 15 knew about this investigation, you told the police that 16 Epstein had "already come to my dad's house and did 17 something to my dad's tires and my dad almost died. I 18 didn't want my dad to get hurt, because Jeff already 19 almost killed him." 20 Didn't you say that? 21 A. Not to my knowledge or recollection. I 22 have never said anything like that. 23 Q. That would have been a complete lie, 24 wouLdn't it have been? 25 A. Yeah. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 100 of 31$ EFTA00231112 n'd9S SUi--NoN 9d 11% 11- S,Nalcdg 1 11 0 N1 Q1 EFTA00231113 JUN-26-2009 FRI 02:28 P11 FAX NO. 5618358691 P. 01 Date: 6/26/09 ATTERBURY, GOLDBERGER & WEISS, P.A. ATTORNEY AT LAW SUITE 1400 250 AUSTRALIAN AVENUE SOUTH WEST PALM BEACH, FLORIDA 33401-5086 TELEPHONE FAX FAX COVER SHEET To: R. Alexander Acosta, Esq. USAO Barbara Burns, Esq. ASAO Bradley J. Edwards, Fsq. William J. Berger, Esq. Robert D. Critton, Esq. Spencer T. Kuvin, Esq. Subject: State of Florida v. Epstein Pages: 3 , including this cover sheet. See attached letter. ORIGINAL WILL BE SENT: YES X NO IF THERE ARE ANY PROBLEMS WITH THE TRANSMISSION, PLEASE CONTACT AS SOON AS POSSIBLE. The information contained In this facsimile message is attorney privileged and confidential information intended only for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this communication is strictly prohibited. If you have received this communication in error, please immediately notify us by telephone. Thank you. EFTA00231114 FAX NO. 661E95?691 JOSEPH R.ATTERBURY JACK &GOLDBERGER JASON S.WEISS Boani Conine Cflotooltial A, torney flembor of Now Jeray R Fleyala Bars June 26, 2009 TELECOPIED THIS DATE The Honorable Jeffrey Colbath Palm Beach County Courthouse 205 N. Dixie Highway Room 11F West Palm Beach, FL 33401 Re; State of Florida v. Jeffrey Epstein Dear Judge Colbath: On behalf of Mr. Epstein, we strongly object to the proposed order submitted by Deanna Shullman on behalf of the Palm Beach Post. The court has already entered an order dated June 25, 2009 on: a) Non-party, M.'s Motion to Vacate Order Sealing Records and Unseal Records b) Palm Beach Post's Motions to Intervene and petition for Access c) Motions to Intervene and for an order to Unseal Records d) Jeffrey Epstein's Motion to Make Court Records Confidential. The only matter before the court today was Defendant Epstein's Motion for a Stay which the court denied. Contrary to the assertions in the proposed order submitted to you by the Palm Beach Post, the court made a specific finding-that the Defendant -Epstein-has met his burden of Irreparable harm. Additionally, all of the other matters contained in the proposed order were addressed in the court's Order of June 25, 2009. It is the position of Defendant Epstein that the order on today's Motion to Stay should simply state that the Defendant's Motion to Stay is denied. In this way, the court's order of June 25, 2009 on the merits of the issue and the order of the court One Clearlake Centre, Suite 1400 250 Australian Avenue South WaSt Palm Reach. FL. 33401 P f www.agwpa.com EFTA00231115 P. 03 JUN-26-2009 FRI 02:28 Ptt The Honorable Jeffrey Colbath June 26, 2009 Page 2 FAX NO. 5618358691 denying the stay motion can properly be reviewed by the Fourth District Court of Appeal. Very truly yqurs, ACK A. GOLDBERGER JAG:cg cc: U.S. Attorney's Office (via facsimile) State Attorney's Office(via facsimile) Deanna K. Shullman, Esquire (via facsimile) Bradley J. Edwards, Esquire (via facsimile) Spencer t. Kuvin, Esquire (via facsimile) EFTA00231116 day of June, 2009. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CRIMINAL DIVISION "W" CASE NO. 502008CF009381AXXMB 502006CF009454AXXMB STATE OF FLORIDA, vs. JEFFREY EPSTEIN, Defendant ORDER DENYING MOTION TO STAY DISCLOSURE AGREEMENT THIS MATTER came before the Court at a hearing on June 26, 2009, on Jeffrey Epstein's Motion to Stay the Disclosure of the Non-Prosecution Agreement and the Addendum thereto. The Court notes the parties were present and represented by counsel. Based upon argument, it is ORDERED AND ADJUDGED that 1. The Motion to Stay is denied. 2. The Clerk of Court shall make the documents available for disclosure at noon on Thursday, July 2, 2009. It is the intent of the Court to give the Defendant, Mr. Epstein, and his attorney an opportunity to have this Court's orders reviewed by the 4th DCA. If the Clerk gets no direction from the Appellate Court, she shall disclose the documents on the date referred to above. DONE AND ORDERED in West Palm Beach, Palm Beach County, Florida this ::a3TJCDA74 D OArED JUN 2 6 2009 JEFFREY J. a/BAWL COLBATH Circuit Court Judge EFTA00231117 Page Two Case No. 502008CF009381A)0(MB/502006CF009454AXXMB Order Denying Motion to Stay Disclosure Agreement Copies furnished: R. Alexander Acosta, U.S. Attorneys Office - Southern District 500 South Australian Avenue, West Palm Beach, FL 33401 Barbara Burns, Esq., State Attorney's Office 401 North Dixie Highway West Palm Beach, FL 33401 William J. Berger, Esq. Bradley J. Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard., Suite 1650 Ft. Lauderdale, FL 33394 Robert D. Critton, Esq. Burman, Critton, Luther & Coleman 515 North Flagler Drive, West Palm Beach, FL 33401 Jack A. Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Spencer T. Kuvin, Esq. Leopold-Kuvin, P.A. 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, FL 33410 Deanna K. Shullman, Esq. P. O. Box 2602 Tampa, FL 33602 EFTA00231118 Judge Jeffrey J. Colbath 205 North Dixie Highway VVestRalm Beach, FL 33401 WESTPALMBEACWRAWDA330H MSS . $ 00.44L: R. A LEAA tett A coSTA CSCI U.S. Attorney's Office Southern District 500 S. Australian Avenue West Palm Beach, FL 33401 33401+623S EFTA00231119 0-4 fikr-elt: P Cji tv EFTA00231120 IN THE CIRCUIT COURT OF THE Ir IEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 2008CF009381A DIVISION W STATE OF FLORIDA v. JEFFREY EPSTEIN, Defendant. EPSTEIN'S MOTION TO STAY DISCLOSURE OF THE NON￾PROSECUTION AGREEMENT AND ADDENDUM PENDING REVIEW Defendant, JEFFREY EPSTEIN ("EPSTEIN"), by and through his undersigned counsel and pursuant to Rule 9.310, Florida Rules of Appellate Procedure, moves to stay disclosure of the Non-Prosecution Agreement and Addendum (collectively, the "NPA") pending review, and states: 1. In the event the Court grants Nonparty M.'s Motion to Vacate Order Sealing Records and Unseal Records, grants Palm Beach Post's Motion to Intervene and Petition for Access and/or denies EPSTEIN's Motion to Make Court Records Confidential, EPSTEIN moves to stay the disclosure of the NPA pending review by the Fourth District Court of Appeals. 2. Rule 9.310(a), Florida Rules of Appellate Procedure, provides in pertinent part, "...a party seeking to stay a final or non-final order pending review shall file a motion in the lower tribunal, which shall have continuing jurisdiction, in its discretion , to grant, modify or deny such relief." EFTA00231121 3. A stay pending review is warranted under the circumstances because of the irreparable harm that would be caused by disclosure of the NPA including, but not limited to, substantial injury to a party by disclosing matters protected by common law and privacy rights, substantial injury to a compelling government interest, substantial injury to innocent third parties and a serious imminent threat to the fair, impartial and orderly administration of justice as set forth in the hearing record date June 25, 2009. 4. In Mariner Health Care of Nashville, Inc. v. Baker 739.. 24 608, 609 (Fla. 1st DCA 1999), defendant Mariner filed a petition for writ of certiorari after the trial court compelled it to produce certain incident reports. Mariner also moved for a stay pending review pursuant to Fla. R. App. Pro. 9.310. The trial court advised the parties that Mariner would be required to submit the incident reports to the court under seal as a prerequisite to a stay. Mariner refused to produce the documents under seal and the trial court denied the motion for stay and imposed daily fines until the documents were produced. Id. The First District Court of Appeals affirmed the trial court's order and noted Mariner has failed to explain how the production of the reports under seal would result in any prejudice. To the contrary, the records will be protected from disclosure during the entire course of the certiorari proceeding before this court. No harm can be done if this court ultimately determines that the reports are protected by the work product privilege. Id. at 610. 5. In the instant case the NPA is already filed under seal. Should the Court grant Nonparty M.'s Motion to Vacate Order Sealing Records and Unseal Records, grant Palm Beach Post's Motion to Intervene and Petition for Access and/or deny 2 EFTA00231122 EPSTEIN's Motion to Make Court Records Confidential, EPSTEIN requests the Court exercise its discretion under Fla R. App. Pro. 9.310(a) and enter a stay pending review by the 4th DCA. 6. No hann will be done if the NPA remains under seal pending appellate review. To the contrary, EPSTEIN will suffer irreparable harm if a stay is not entered and the NPA is disclosed to the public. WHEREFORE, Defendant, JEFFREY EPSTEIN, respectfully requests that if the Court grants Nonparty M.'s Motion to Vacate Order Sealing Records and Unseal Records, grants Palm Beach Post's Motion to Intervene and Petition for Access and/or denies EPSTEIN's Motion to Make Court Records Confidential, the Court enter a stay pending review and grant any additional relief the Court deems just and proper. Certificate of Service WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Hand Delivery to ., United States Attorney's Office — Southern District, 500 S. Australian Avenue, West Palm Beach, FL 33401, JUDITH STEVENSON AREO, ESQ., State Attorney's Office — West Palm Beach, 401 North Dixie Highway, West Palm Beach, FL 33401, WILLIAM J. BERGER, ESQ., and BRADLEY J. EDWARDS, Rothstein Rosenfeldt Adler, 401 East Las Olas Boulevard, Suite 1650, Fort Lauderdale, FL 33394, JACK A. GOLDBERGER, ESQ., Atterbury, Goldberger & Weiss, P.A., 250 Australian Avenue South Suite 1400„ weet Palm Beach, FL 33401, SPENCER T. KUVIN, ESQ., Leopold-Kuvin, P.A., 2925 PGA Blvd., Suite 200, Palm Beach Gardens, FL 33410, and DEANNA K. SHULLMAN, 3 EFTA00231123 400 North Drive, Suite 1100, P.O. Box 2602 (33601) Tampa, FL 33602, this 25th day of June. 2009. BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 515 N. Flagler Drive, West Palm Beach, FL 401 By: Robert D. Cri n, Jr. Florida Bar 24162 Michael J. Pike Florida Bar #617296 Counsel for Defendant J6ffrey Epstein) and Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beac FL 33401-5012 Fax: Counsellor Defendant Jeffrey Epstein 4 EFTA00231124 BURMAN, CRITTON, LUTTIER & COLEMAN LLP L•A•W'Y•B•R•S 515 N. FLAMER DRIVE WEST PALM BEACH, FLORIDA 33401 I U.S. Attorney's Office Southern District 500 S. Australian Avenue West Palm Beach, FL 33401 c023 $ 00.44° r PC1A /iP C.:1;0F EFTA00231125 IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA, FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, v. STATE OF FLORIDA, Respondent. CASE NO. PALM BEACH COUNTY L.T. CASE NO. 2008 CF 009381A MOTION TO FILE UNDER SEAL Petitioner/defendant, JEFFREY EPSTEIN, moves this Court for an order allowing him to file the September 24, 2007 Non-Prosecution Agreement ("Agreement") and October 29, 2007 Addendum to the Non-Prosecution Agreement ("Addendum"), which are the subject of his contemporaneously filed emergency petition for certiorari and emergency motion to review denial of stay, under seal. 1. The Agreement and Addendum were executed by petitioner/defendant and the United States Attorney's Office in September 2007. They are attached in the sealed envelope. 2. The Agreement contains a confidentiality clause, precluding it from EFTA00231126 being disclosed to third parties or made part of any public record. Federal District Judge Marra has twice ordered the documents not disclosed to third parties. 3. Fifteenth Judicial Circuit Judge Deborah Pucillo ordered Mr. Epstein's attorney to file the documents under seal during his plea conference on June 30, 2008. 4. On June 25, 2009, Judge Colbath granted non-parties' motions to vacate the order sealing records and ordered them disclosed. 5. On June 26, 2009, Judge. Colbath denied petitioner's motion for stay, and ordered the Clerk of Court to make the documents available for disclosure at noon on Thursday, July 2, 2009, unless this Court granted a stay. 6. It is necessary that this Court review the Agreement and Addendum in conjunction with these proceedings. To protect the purpose of the petition for writ of certiorari pending before this Court, petitioner asks to file the documents under Accordingly, petitioner requests that this Court grant this motion and allow 2 EFTA00231127 him to file the Agreement and Addendum, which are separate from the appendix to his emergency petition and motion for review, under seal. I HEREBY CERTIFY that a copy of the foregoing has been sent by email and Federal Express this 30,1a... day of June, 2009, to: U.S. Attorney's Office-Southern District 500 South Australian Avenue, West Palm Beach, FL 33401 WILLIAM J. BERGER ROTHSTEIN ROSENFELDT ADLER 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33394 Counsel for SPENCER T. KUVIN LEOPOLD-KUVIN, P.A. 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, FL 33410 Counsel for M. JUDITH STEVENSON ARCO State Attorney's Office-West Palm Beach 401 North Dixie Highway West Palm Beach, FL 33401 DEANNA K. SHULLMAN 400 North Drive, Suite 1100 P. O. Box 2602 (33601) Tampa, FL 33602 Counsel for The Palm Beach Post HONORABLE JEFFREY COLBATH Palm Beach County Courthouse 205 North Dixie Highway Room 11F West Palm Beach, FL 33401 ROBERT D. CRITTON of BURMAN, CRITTON, LUTTIER & COLEMAN 515 North Flagler Drive, West Palm Beach, FL 33401 and ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 and 3 EFTA00231128 JANE KREUSLER-WALSH and BARBARA J. COMPIANI of KREUSLER-WALSH, COMPIANI & VARGAS, P.A. 501 South Flagler Drive, Suite 503 West Palm Beach, FL 33401-5913 janewalshajltwpa.com Counsel for Petitioner By: Ce i-INTE =WALSH orida Bar No. 272371 4 EFTA00231129 IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA, FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, v. STATE OF FLORIDA, Respondent. / CASE NO. PALM BEACH COUNTY L.T. CASE NO. 2008 CF 009381A MOTION TO USE ONE APPENDIX TO SUPPORT EMERGENCY PETITION FOR WRIT OF CERTIORARI AND EMERGENCY MOTION TO REVIEW DENIAL OF STAY Petitioner, JEFFREY EPSTEIN, moves to file one appendix in support of his contemporaneously filed emergency petition for writ of certiorari and emergency motion to review denial of stay. The documents in the appendix support both the petition and motion to review denial of stay. In order to expedite review, avoid duplication of paper and unnecessary expense, Mr. Epstein requests that this Court allow him to use the appendix in support of both the petition and motion to review denial of stay. I HEREBY CERTIFY that a copy of the foregoing has been sent by E-Mail and 1 EFTA00231130 Federal Express this 3**4.. day of June, 2009, to: U.S. Attorney's Office-Southern District 500 South Australian Avenue, West Palm Beach, FL 33401 WILLIAM J. BERGER ROTHSTEIN ROSENFELDT ADLER 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale FL 33394 Counsel for SPENCER T. KUVIN LEOPOLD-KUVIN, P.A. 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, FL 33410 Counsel for M. JUDITH STEVENSON ARCO State Attorney's Office-West Palm Beach 401 North Dixie Highway West Palm Beach, FL 33401 DEANNA K. SHULLMAN 400 North Drive, Suite 1100 P. O. Box 2602 (33601) Tampa, FL 33602 Counsel for The Palm Beach Post HONORABLE JEFFREY COLBATH Palm Beach County Courthouse 205 North Dixie Highway Room 11F West Palm Beach, FL 33401 ROBERT D. CRITTON BURMAN, CRITTON, LUTTIER & COLEMAN 515 North Flagler Drive, West Palm Beach, FL 33401 and JACK A. GOLDBERGER ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 and 2 EFTA00231131 JANE KREUSLER-WALSH and BARBARA J. COMPIANI of KREUSLER-WALSH, COMPIANI & VARGAS, P.A. 501 South Flagler Drive, Suite 503 West Palm Beach, FL 33401-5913 ianewalsh@jkwpa.com Counsel for Petitioner By: -i•- &A;Eel=2. --WALSH lorida Bar No. 272371 3 EFTA00231132 IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA, FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, v. STATE OF FLORIDA, Respondent. CASE NO. PALM BEACH LT. CASE NO. 2008 CF 009381A PETITIONER'S EMERGENCY MOTION TO REVIEW ORDER DENYING STAY OF DISCLOSURE OF FEDERAL NON-PROSECUTION AGREEMENT AND ADDENDUM Petitioner, JEFFREY EPSTEIN, pursuant to Florida Rule of Appellate Procedure 9.310(1), requests this Court review the order denying his Motion to Stay Disclosure of Federal Non-Prosecution Agreement and Addendum pending his contemporaneously filed petition for certiorari and grant the stay.' Mr. Epstein seeks review of the stay denial on emergency basis. The court stayed disclosure until noon on Thursday, July 2, 2009 Mr. Epstein could seek review in this Court. Absent a stay by this Court, the documents will be disclosed and there will be no adequate remedy. Petitioner, Jeffrey Epstein is referred to bxEoaname. Non-party interveners,.., M. and The Post are referred to as M., M. and The Post. All emphasis is supplied unless indicated otherwise. The following symbol is used: A — Petitioner's appendix. 1 EFTA00231133 FACTUAL BACKGROUND In 2006, a Florida state grand jury indicted Jeffrey Epstein for felony solicitation of prostitution. He was also charged by information with procuring persons under 18 for prostitution. The United States Attorney's Office for the Southern District of Florida began a federal grand jury investigation into allegations arising out of the same conduct. In September 2007, the United States Attorney's Office and Mr. Epstein negotiated and signed a non-prosecution agreement (A-7:38).2 The non-prosecution agreement contains an express confidentiality provision and makes specific reference to a grand jury investigation of Mr. Epstein (A-7:38). The United States Attorney's Office agreed to defer the federal criminal action on the condition that Mr. Epstein comply with many obligations, beginning with his pleading guilty to certain state charges in the Florida criminal action (A-7:38). A breach of any condition violates the non-prosecution agreement and criminal charges will resume (A-7:39-40). On June 30, 2008, Mr. Epstein pled guilty to felony solicitation of prostitution and procuring a minor under 18 for prostitution in the Florida criminal action (A-7; A￾2 The non-prosecution agreement and addendum are separately filed with a motion to seal. 2 EFTA00231134 8). Judge Deborah Dale Pucillo, sitting for the Fifteenth Judicial Circuit, accepted the plea (A-7). During the plea conference, Judge Pucillo asked Mr. Epstein whether any promises had been made to him besides the terms of the state plea (A-7:37-38). Mr. Epstein's attorney advised the court of the "confidential [non-prosecution agreement with the United States Attorney's Office] that the parties have agreed to." (A-7:38). He informed the court that Mr. Epstein's failure to comply with the terms of the state plea would violate the non-prosecution agreement (A-7:39-40). Judge Pucillo then instructed Mr. Epstein's attorney that she wanted "a sealed copy of that filed in this case." (A-7:40). When Mr. Epstein's attorney tried to comply and file the non-prosecution agreement with the court, the clerk advised him an order was necessary. On July 2, 2008, the court entered an "Agreed Order Sealing Document in Court File" (A-9). An addendum to the non-prosecution agreement was filed under seal on August 25, 2008. On July 7, 2008, Jane Doe 1 and Jane Doe 2 filed an independent action in the federal court to compel production of the non-prosecution agreement (A-1). Mr. Epstein was not a party to the proceeding, but the United States Attorney's Office 3 EFTA00231135 opposed disclosure (A-2). On August 16, 2008, Judge Marra of the Southern District ordered the United States Attorney's Office to produce the non-prosecution agreement to the Does' attorneys and to any other victims and their counsel, provided they not disclose the terms to anyone else (A-2). As a result of this order, all victims, including those with civil suits against Mr. Epstein, have access to the non-prosecution agreement and addendum. They just cannot share it with others. In September 2008, Jane Doe 1 and Jane Doe 2 filed motions in the federal action to unseal the non-prosecution agreement and addendum (A-3). The United States Attorney's Office opposed disclosure noting its confidentiality provision, the movant's right to access the agreement, and Judge Marra's protective order to which the movants voiced no objection (A-4). On February 12, 2009,3 Judge Marra denied the motion, stating in pertinent part: Petitioners' mere desire to discuss the Agreement with third parties is insufficient, in and of itself, to warrant the granting of such relief. If and when Petitioners have a specific tangible need to be relieved of the restrictions, they should file an appropriate motion. If a specific tangible need arises in a civil case Petitioners or other alleged victims are pursuing against Epstein, relief should be sought in that case, with notice to the United States, the other party to the Agreement. (A-6). 3The order is mistakenly dated February 12, 2008 (A-6). 4 EFTA00231136 Rather than seeking relief from Judge Marra in federal court, non-party , a victim of Mr. Epstein, filed a motion in the state criminal action on May 12, 2009, seeking to intervene and unseal the non-prosecution agreement and addendum pursuant to Florida Rule of Judicial Administration 2.420(d)(5) (A-10). E.W. alleged that the proper procedures had not been followed in sealing the documents (A-10). claimed these documents are relevant to her civil action against Mr. Epstein; that she, as a member of the public, has a right to have them unsealed; and that continued sealing violates public policy (A-10). On June 1, 2009, Palm Beach Newspapers d/b/a The Palm Beach Post ("The Post") moved in the state criminal action to intervene and access the non-prosecution agreement and addendum (A-11). The Post alleged that the procedures for sealing had not been followed and that "good cause exists for unsealing the documents because of their public significance." (A-11:3). Fifteenth Judicial Circuit Judge Jeffrey Colbath heard 's and The Post's motions in the state criminal action on June 10, 2009 (A-13). The court granted both motions to intervene, but deferred ruling on the motions to unseal pending a later hearing (A-13). 5 EFTA00231137 The next day, June 11, 2009, Mr. Epstein filed a Motion to Make Court Records Confidential (A-13). Mr. Epstein alleged that the documents should remain confidential to prevent a serious imminent threat to the fair, impartial, and orderly administration of justice; to protect a compelling government interest; to avoid substantial injury to innocent third parties; and to avoid substantial injury to a party by disclosure of matters protected by a common law and privacy right, not generally inherent in the specific type of proceeding sought to be closed (A-13). Also on June 11, non-party ■. filed motions to intervene and for an order unsealing the records, alleging grounds similar to non-parties . and The Palm Beach Post (A-12). Judge Colbath heard .'s, The Post's, and ■.'s motions to unseal and Mr. Epstein's motion for confidentiality on June 25, 2009 (A-16). The court granted .'s, The Post's, and ■.'s motions and denied Mr. Eptsein's (A-16:2). The court concluded: At the time the State court took these matters under seal, the proper procedure for sealing such documents had not been followed. Neither the State of Florida nor the U.S. Government nor Mr. Epstein have [sic] presented sufficient evidence to warrant the sealing of documents currently held by the Court. (A-16:2; A-18:43). The court ruled that "[t]his Order is in no way to be interpreted as 6 EFTA00231138 permission to not comply with U.S. District Court Kenneth Marra's previous Orders." (A-16:3). Subsequent to this oral ruling, Mr. Epstein provided the court with a Motion to Stay (A-14). The court stayed disclosure until it could hear Mr. Epstein's motion to stay, scheduled for the next day (A-16:3). The court heard Mr. Epstein's stay motion on June 26, 2009 (A-19). Mr. Epstein alleged that he will be irreparably harmed by disclosure of the non-prosecution agreement and addendum (A-14). No harm will be done if the documents remain under seal pending review by this Court (A-14). The court denied the motion, but stayed disclosure until noon on Thursday, July 2, I Mr. Epstein could seek emergency review of the denial in this Court (A-17). ARGUMENT Whether to grant a stay is discretionary with the trial court. See Pabian v. Pabian, 469 M. 2d 189, 191 (Fla. 4th DCA 1985). Factors courts consider in deciding whether to grant a stay pending appellate proceedings include the likelihood of success on the merits, the likelihood of harm if not stay is granted, and the remedial quality of any such harm. See Perez v. Perez, 769 M. 2d 389, 391 n.4 (Fla. 3d DCA 1999); see also State ex rel. Price v. McCord, 380 E. 2d 1037, 1038 n.3 (Fla. 1980). The trial court agreed that Mr. Epstein had established irreparable harm (A-17:16), denied a 7 EFTA00231139 stay. The trial court abused its discretion by denying a stay. As set forth in the contemporaneously filed petition for certiorari, Mr. Epstein will likely succeed on the merits. The trial court departed from the essential requirements of law in granting the motions to unseal the confidential federal non-prosecution agreement and addendum between the United States Attorney's Office and Mr. Epstein. These documents are subject to confidentiality provisions, which the federal court recognized and enforced when it permitted disclosure to the attorneys for Jane Doe 1 and Jane Doe 2 and to any other victims and their counsel, provided they not disclose the terms to anyone else. Disclosure violates a condition of the agreement, thereby vitiating the agreement between Mr. Epstein and the United States Attorney. Disclosure also violates Judge Main's two orders in the federal district court, denying disclosure to the parties. Judge Colbath paid lip service to this principle in stating that his "Order is in no way to be interpreted as permission to not comply with U.S. District Court Kenneth Marra's previous Orders." (A-16:3). But there is no way disclosure does not inherently violate Judge Marra's orders. The principle of supremacy required that the state court defer to the federal court 8 EFTA00231140 on this issue. U.S. Const. Art. I § 8. These documents reference federal grand jury proceedings, which are protected under Federal Rule of Criminal Procedure 6(e)(2)--an attorney for the government "must not disclose a matter occurring before the grand jury." As a consequence of the confidentiality provisions of the non-prosecution agreement, information that disclosed the existence and the subject matter of a federal grand jury proceeding which itself is protected by Federal Rule of Criminal Procedure 6(e) remains non-public, thus effectuating the privacy concerns addressed by the United States Supreme Court in Douglas and other cases. See e.g. Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 228-30 (1979). Under Rule 6(e), only a federal court can, absent findings, order the unsealing of federal grand jury proceedings. See Fed. R. Crim. P. 6(e)(3)(F), (G). Judge Colbath did not address this principle. Nor did Judge Colbath address the principle of comity, which required that the state court defer to the federal court, which has twice denied disclosure to third parties, on this issue. The court erred in concluding that the non-prosecution and agreement were not properly sealed. The non-parties filed their motions to unseal pursuant to Florida Rule of Judicial Administration 2.420(d) (A-10, A-11, A-12). They alleged that Judge Pucillo failed to properly seal the documents under the procedure set forth in that rule (Id.). By its terms, however, the procedures for sealing in Rule 2.420(d) (titled, "Request to Make Circuit and County Court Records in Non-Criminal Cases 9 EFTA00231141 Confidential") do not apply to criminal cases. See Ha. R. Jud. Admin. 2.420, 2007 Court Commentary ("New. subdivision (d) applies to motions that seek to make court records in non-criminal cases confidential in accordance with subdivision (cX9)."); see also In re Amendments to Fla. R. Jud. Admin. 2.420--Sealing of Court Records & Dockets, 954.. 2d 16, 17 & 23 (Fla. 2007) (declining to adopt specific procedure regarding the sealing of court records in criminal cases and referring the matter to rules committees for further study). Under the version of rule 2.420 in effect when the documents were sealed, there is no procedure for criminal proceedings. Even under the prior version of rule 2.420, Judge Pucillo was not required to give prior notice of her intent to seal documents during the plea hearing. Committee Notes on the 1995 amendments discussing a prior version of Rule 2.420(c)(9)(D), make clear that advance notice is not always required: Unlike the closure of court proceedings, which has been held to require notice and hearing prior to closure, see Miami Herald Publishing Co. v. Lewis, 426.. 2d I (Fla. 1982), The closure of court records has not required prior notice. Requiring prior notice of closure of a court record may be impractical and burdensome in emergency circumstances or when closure of a court record requiring confidentiality is requested during a judicial proceeding. The local administrative rule the non-parties cite, 15th Judicial Circuit 10 EFTA00231142 Administrative Order 2.303, is not applicable either. This Administrative Order addresses the procedures for sealing criminal and non-criminal court records, but was not adopted until September 29, 2008--months after Judge Pucillo sua sponte ordered the non-prosecution agreement and its addendum filed and sealed. The Administrative Order in effect when Judge Pucillo sealed these documents was 2.032-10/06. As explained above, the procedures designated therein would not apply since Judge Pucillo filed and sealed the documents sua sponte, not by motion. To the extent that the Administrative Order conflicts with the version of rule 2.420 then in effect, the rule prevails. Judge Pucillo was not required to follow Administrative Order 2.032 when she sealed the documents in June 2008. Assuming compliance with procedures for confidentiality was required, Mr. Epstein met them. At all times, the rules of judicial administration provided that court records "shall be confidential" if a court has determined that confidentiality is required. Fla. R. Jud. Admin. 2.420(cX9). Rule 2.420(cX9) provides: (c) Exemptions. The following records of the judicial branch shall be confidential: (9) Any court record determined to be confidential in case decision or court rule on the grounds that (A) confidentiality is required to (i) prevent a serious and imminent threat to the fair, impartial, and orderly administration of justice; (ii) protect trade secrets; 11 EFTA00231143 (iii) protect a compelling governmental interest; (iv) obtain evidence to determine legal issues in a case; (v) avoid substantial injury to innocent third parties; (vi) avoid substantial injury to a party by disclosure of matters protected by a common law or privacy right not generally inherent in the specific type of proceeding sought to be closed; (vii) comply with established public policy set forth in the Florida or United States Constitution or statutes or Florida rules or case law; (B) the degree, duration, and manner of confidentiality ordered by the court shall be no broader than necessary to protect the interests set forth in subdivision (A); and (C) no less restrictive measures are available to protect the interests set forth in subdivision (A). Fla. R. Jud. Admin. 2.420(c)(9). Thus, courts are required to seal court records upon a fmding that closure is need to "prevent a serious and imminent threat to the fair, impartial, and orderly administration of justice," to "avoid substantial injury to innocent third parties" or to "avoid substantial injury to a party by disclosure of matters protected by a common law or privacy right not generally inherent in the specific type of proceeding sought to be closed." Fla. R. Jud. Admin. 2.420(c)(9)(i), (v), (vi). Mr. Epstein's Motion to Make Court Records Confidential satisfied these requirements; thus, the court erred in denying it. Mr. Epstein alleged three separate grounds for confidentiality. He first argued that confidentiality is necessary to protect 12 EFTA00231144 a compelling government interest. He satisfied this prong since the United States Attorney's Office has a compelling interest in having the confidentiality provision of its contract with Mr. Epstein honored. Judge Marra already balanced that interest against arguments for disclosure and struck a balance by requiring disclosure to plaintiffs and their lawyers, but not to third parties. Secondly, Mr. Epstein contended that maintaining confidentiality will avoid injury to innocent third parties, i.e., the other persons the United States Attorney's Office agreed not to prosecute who will be harmed if the documents are unsealed. Thirdly, Mr. Epstein demonstrated that confidentiality is necessary to avoid substantial injury to a party by disclosure of matters protected by a common law or privacy right not generally inherent in the specific type of proceeding sought to be closed. Disclosure of these documents is not generally inherent in a state court plea hearing and will violate Mr. Epstein's common law right to confidentiality. Granting a stay would vindicate the values and purposes of grand jury secrecy which will be implicated, if a stay is denied, by the public disclosure of a confidential agreement that references matters related to a federal grand jury investigation. There is no prejudice to non-parties/interveners and The Post, if disclosure is stayed pending the outcome of Mr. Epstein's emergency petition for certiorari. Mr. Epstein, on the other hand, will suffer irreparable harm once the documents are produced--a fact 13 EFTA00231145 the trial court recognized (A-19:16). CONCLUSION This Court should grant review and order the trial court to stay the order unsealing the non-prosecution agreement and addendum pending certiorari review. CERTIFICATION OF EXISTENCE OF EMERGENCY Undersigned counsel certifies that the subject of this motion constitutes an emergency. The trial court's order at noon on July 2, 2009, provides that the confidential federal non-prosecution agreement and addendum will be disclosed. Once these documents are disclosed, irreparable harm will result. I HEREBY CERTIFY that a copy of the foregoing has been sent by E-Mail and Federal Express this 30:c4. day of June, 2009, to: U.S. Attorney's Office-Southern District 500 South Australian Avenue, West Palm Beach, FL 33401 WILLIAM J. BERGER ROTHSTEIN ROSENFELDT ADLER 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33394 Counsel for JUDITH STEVENSON ARCO State Attorney's Office-West Palm Beach 401 North Dixie Highway West Palm Beach, FL 33401 DEANNA K ST-IT ITIMANT. 400 North Drive, Suite 1100 P. O. Box 2602 (33601) Tampa, FL 33602 Counsel for The Palm Beach Post 14 EFTA00231146 SPENCER T. KUVIN LEOPOLD-KUVIN, P.A. 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, FL 33410 Counsel for E. HONORABLE JEFFREY COLBATH Palm Beach County Courthouse 205 North Dixie Highway Room 11F West Palm Beach, FL 33401 ROBERT D. CRITTON BURMAN, CRITTONLUTTIER & COLEMAN 515 N. Flagler Drive, West Palm Beach, FL 33401 and JACK A. GOLDBERGER ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 and JANE KREUSLER-WALSH and BARBARA J. COMPIANI of KREUSLER-WALSH, COMPIANI & VARGAS, P.A. 501 South Flagler Drive, Suite 503 West Palm Beach, FL 33401-5913 MI= Counsel for Petitioner By: NEKREUSLER-WALSH lorida Bar No. 272371 15 EFTA00231147 IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA, FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, v. STATE OF FLORIDA, Respondent. CASE NO. PALM BEACH LT. CASE NO. 2008 CF 009381A EMERGENCY PETITION FOR WRIT OF CERTIORARI Petitioner, JEFFREY EPSTEIN, seeks a writ of certiorari pursuant to Florida Rule of Appellate Procedure 9.100(cX1), to review an order compelling disclosure of a confidential federal non-prosecution agreement and addendum, pursuant to motions to unseal, filed by non-parties, M. and Palm Beach Newspapers d/b/a The Palm Beach Post ("the Pose').1 The confidential federal non-prosecution agreement and addendum between the United States Attorney's Office and Mr. Epstein were filed under seal in state court at the express directive of the judge who heard Mr. Epstein's guilty plea--"I wapt a sealed cnpy of that filed in_this_casenand_not—by— I Petitioner, Jeffrey Epstein is referred to by proper name. Non-party interveners, ., M. and The Post are referred to as ., M. and The Post. All emphasis is supplied unless indicated otherwise. The following symbol is used: A — Petitioner's appendix. EFTA00231148 motion of any party (A-7:40). Federal Court Judge Marra has twice denied public access to these documents. Mr. Epstein seeks certiorari review on an emergency basis.2 The court stayed disclosure until noon on Thursday, July 2, 2009. Once the documents are produced, there will be no adequate remedy. I. JURISDICTION Mr. Epstein seeks to invoke the certiorari jurisdiction of this Court pursuant to Florida Rules of Appellate Procedure 9.030(bX2)(A) and 9.100. Certiorari review is appropriate where, as here, an order unsealing a court record departs from the essential requirements of law and causes material injury that cannot be remedied on appeal after final judgment. See Allstate Ins. Co. v. Langston, 655 M. 2d 91, 94 (Fla. 1995). This Court should exercise its certiorari jurisdiction to quash the order unsealing the non-prosecution agreement and addendum. Production of these documents will-cause-irreparable harm ("cat oat of the bag") to Mr. Epstein. The order departs from the essential requirements of law because 2 Mr. Epstein has contemporaneously filed an emergency motion to review denial of stay. 2 EFTA00231149 the court failed to recognize principles of supremacy and comity and failed to apply the correct law as to sealing these records. Alternatively, Mr. Epstein appeals the order under Florida Rule of Appellate Procedure 9.140(b)(1XD) as an order entered after a finding of guilt in a criminal case. See Fla. R. App. P. 9.040(c) ("If a party seeks an improper remedy, the cause shall be treated as if the proper remedy had been sought. . .."). II. STATEMENT OF FACTS In 2006, a Florida state grand jury indicted Jeffrey Epstein for felony solicitation of prostitution. He was also charged by information with procuring persons under 18 for prostitution. The United States Attorney's Office for the Southern District of Florida began a federal grand jury investigation into allegations arising out of the same conduct. In September 2007, the United States Attorney's Office and Mr. Epstein executed a non-prosecution • (A-7.38) . 3 • 11 prosecution agreement contains an express confidentiality provision (A￾3 The non-prosecution agreement and addendum are separately filed with a motion to seal. 3 EFTA00231150 7:38). The United States Attorney's Office agreed to defer the federal criminal action on the condition that Mr. Epstein comply with many obligations, beginning with his pleading guilty to certain state charges in the Florida criminal action (A-7:38). A breach of any condition violates the non-prosecution agreement and criminal charges will resume (A-7:39-40). On June 30, 2008, Mr. Epstein pled guilty to felony solicitation of prostitution and procuring a minor under 18 for prostitution in the Florida criminal action (A-7; A-8). Judge Deborah Dale Pucillo, sitting for the Fifteenth Judicial Circuit, accepted the plea (A-7). During the plea conference, Judge Pucillo asked Mr. Epstein whether any promises had been made to him besides the terms of the state plea (A￾7:37-38). Mr. Epstein's attorney advised the court of the "confidential [non￾prosecution agreement with the United States Attorney's Office] that the parties have agreed to." (A-7:38). He informed the court that Mr. Epstein's failure to comply with the terms of the state plea would violate the non- -proseeution agreement (A-7:39-40). Judge Pucillo then instructed Mr. Epstein's attorney that she wanted 4 EFTA00231151 "a sealed copy of that filed in this case." (A-7:40). When Mr. Epstein's attorney tried to comply, and file the non-prosecution agreement with the court, the clerk advised him an order was necessary. On July 2, 2008, the court entered an "Agreed Order Sealing Document in Court File' (A-9). An addendum to the non-prosecution agreement was filed under seal on August 25, 2008. On July 7, 2008, Jane Doe 1 and Jane Doe 2 filed an independent action in federal court to compel production of the non-prosecution agreement (A-1). Mr. Epstein was not a party to the proceeding, but the United States Attorney's Office opposed disclosure (A-2). On August 16, 2008, Judge Marra of the Southern District ordered the United States Attorney's Office to produce the non-prosecution agreement to the Does' attorneys and to any other victims and their counsel, provided they not disclose the terms to anyone else (A-2). As a result of this order, all victims, including those with civil suits against Mr. Epstein, have access to the non￾prosecution agreement and addendum. They just cannot share it with others. In September 2008, Jane Doe 1 and Jane Doe 2 filed motions in the federal criminal action to unseal the non-prosecution agreement (A-3). The 5 EFTA00231152 United States Attorney's Office opposed disclosure noting its confidentiality provision, the movant's right to access the agreement, and Judge Marra's protective order to which the movants voiced no objection (A-4). On February 12, 2009,4 Judge Marra denied the motion, finding in pertinent part: Petitioners' mere desire to discuss the Agreement with third parties is insufficient, in and of itself, to warrant the granting of such relief. If and when Petitioners have a specific tangible need to be relieved of the restrictions, they should file an appropriate motion. If a specific tangible need arises in a civil case Petitioners or other alleged victims are pursuing against Epstein, relief should be sought in that case, with notice to the United States, the other party to the Agreement. (A-6). • Rather than seeking relief from Judge Marra in federal court, non￾party E.W., a victim of Mr. Epstein, filed a motion in the state criminal action on May 12, 2009, seeking to intervene and unseal the non-prosecution agreement and addendum pursuant to Florida Rule of Judicial Administration 2.420(dX5) (A-10)... alleged that the proper procedures had not been followed in sealing the documents (A-10). claimed these documents are relevant to her civil action against Mr. Epstein and that she, " The order is mistakenly dated February 12, 2008 (A-6). 6 EFTA00231153 as a member of the public, has a right to have them unsealed; and that continued sealing violates public policy (A-10). On June 1, 2009, Palm Beach Newspapers d/b/a The Palm Beach Post ("The Post") also moved in the state criminal action to intervene and access the agreement and addendum (A-11). The Post alleged the procedures for sealing had not been followed and that "good cause exists for unsealing the documents because of their public significance." (A-11:3). Fifteenth Judicial Circuit Judge Jeffrey Colbath heard M.'s and The Post's motions in the state criminal action on June 10, 2009 (A-13). The court granted both motions to intervene, but deferred ruling on the motions to unseal pending a later hearing (A-13). The next day, Mr. Epstein filed a Motion to Make Court Records Confidential (A-13). Mr. Epstein alleged that the documents should remain confidential to prevent a serious imminent threat to the fair, impartial, and orderly—administration of justiet—to—proteet—a—compelling -government interest; to avoid substantial injury to innocent third parties; and to avoid substantial injury to a party by disclosure of matters protected by a common 7 EFTA00231154 law and privacy right, not generally inherent in the specific type of proceeding sought to be closed (A-13). Also on June I I, non-party M. filed motions to intervene and for an order unsealing the records, alleging grounds similar to non-parties.. and The Palm Beach Post (A-12). Judge Colbath heard M.'s, The Post's, and M.'s motions to unseal, and Mr. Epstein's motion for confidentiality, on June 25, 2009 (A￾16). The court granted ■.'s, The Post's, and M.'s motions and denied Mr. Eptsein's (A-16:2). The court concluded: At the time the state court took these matters under seal, the proper procedure for sealing such documents had not been followed . . . [and that] [n]either the State of Florida nor the U.S. Government nor Mr. Epstein have [sic] presented sufficient evidence to warrant the sealing of documents currently held by the court. (A-16:2; A-18:43). The court ruled that "[t]his Order is in no way to be interpreted as pennission to not comply with U.S. District Court Kenneth --?vlarrais-previonsHardersfl-Subsequent-to-this-oral-ruling, Mr. Epstein provided the court with a Motion for Stay (A-14). The court stayed disclosure until it could hear Mr. Epstein's motion to stay, scheduled for the EFTA00231155 next day (A-16:3). The court heard Mr. Epstein's stay motion on June 26, 2009 (A-19). Mr. Epstein alleged that he will be irreparably harmed by disclosure of the non-prosecution agreement and addendum (A-14). No harm will be done if the documents remain under seal pending review by this Court (A-14). The court denied the motion, but stayed disclosure until noon on Thursday, July 2, 2009, Mr. Epstein could seek review of the denial in this Court (A-17). Mr. Epstein has filed an emergency motion to review denial of stay in this Court, contemporaneously with this motion. HI. NATURE OF RELIEF SOUGHT Mr. Epstein seeks to quash the June 25, 2009 order granting non￾parties' motions to unseal the confidential non-prosecution agreement and addendum between Mr. Epstein and the United States Attorney's Office. IV. ARGUMENT Thc trial court departed from the essential-requiivineiits of law granting the motions to unseal the confidential federal non-prosecution agreement and addendum between the United States Attorney's Office and EFTA00231156 Mr. Epstein. These documents are subject to confidentiality provisions, which the federal court recognized and enforced when it permitted disclosure to the attorneys for Jane Doe 1 and Jane Doe 2, and to any other victims and their counsel, provided they not disclose the terms to anyone else. Disclosure violates a condition of the agreement, thereby vitiating the agreement between Mr. Epstein and the United States Attorney. Disclosure also violates Judge Marra's two orders in the federal district court, denying disclosure to the parties. Judge Colbath paid lip service to this principle in stating that his "Order is in no way to be interpreted as permission to not comply with U.S. District Court Kenneth Marra's previous Orders." (A￾16:3). But there is no way disclosure does not inherently violate Judge Marra's orders. The principle of supremacy required that the state court defer to the federal court on this issue. U.S. Const. Art. I § 8. These documents reference federal grand jury proceedings, which are protected under Federal Rule of Criminal Procedure 6(e)(2)—an attorney for the government "must not disclosc a matter-occurring-before-the-grand-it onsequence of the confidentiality provisions of the non-prosecution agreement, information that disclosed the existence and the subject matter of a federal grand jury 10 EFTA00231157 proceeding which itself is protected by Federal Rule of Criminal Procedure 6(e) remains non-public, thus effectuating the privacy concerns addressed by the United States Supreme Court in Douglas and other cases. See e.g, Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 228-30 (1979). Under Rule 6(e), only a federal court can, absent findings, order the unsealing of federal grand jury proceedings. See Fed. R. Crim. P. 6(e)(3)(F), (G). Judge Colbath did not address this principle. Nor did Judge Colbath address the principle of comity, which required that the state court defer to the federal court, which has twice denied disclosure to third parties, on this issue. The court erred in concluding that the non-prosecution and agreement were not properly sealed. The non-parties filed their motions to unseal pursuant to Florida Rule of Judicial Administration 2.420(d) (A-10, A-11, A-12). They alleged that Judge Pucillo failed to properly seal the documents under the procedure set forth in that rule asL). By its terms, however, the procedures for sealing in Rule 2.420(d) (titled, "Request to Make Circuit and County Court Records-in-Nott-C-rimitral-C- asereonftdentiej-do-myt to criminal cases. See Fla. R. Jud. Admin. 2.420, 2007 Court Commentary ("New subdivision (d) applies to motions that seek to make court records in 11 EFTA00231158 non-criminal cases confidential in accordance with subdivision (cX9)."); see also In re Amendments to Fla. R. Jud. Admin. 2.420--Sealing of Court Records & Dockets, 954 2d 16, 17 & 23 (Fla. 2007) (declining to adopt specific procedure regarding the sealing of court records in criminal cases and referring the matter to rules committees for finther study). Under the version of rule 2.420 in effect when the documents were sealed, there is no procedure for criminal proceedings. Even under the prior version of rule 2.420, Judge Pucillo was not required to give prior notice of her intent to seal documents during the plea hearing. Committee Notes on the 1995 amendments discussing a prior version of Rule 2.420(cX9)(D), make clear that advance notice is not always required: Unlike the closure of court proceedings, which has been held to require notice and hearing prior to closuckisee Miami Herald Publishing Co. v. Lewis, 426 M. 2d 1 (Fla. 1982), the closure of court records has not required prior notice. Requiring prior notice of closure of a court record may be impractical and burdensome in emergency circumstances or when closure of a coin t ins. J requiring confidentiality—is requested during a judicial proceeding. The local administrative rule the non-parties cite, 15th Judicial Circuit 12 EFTA00231159 Administrative Order 2.303, is not applicable either. This Administrative Order addresses the procedures for sealing criminal and non-criminal court records, but was not adopted until September 29, 2008--months after Judge Pucillo sua sponte ordered the non-prosecution agreement and its addendum filed and sealed. The Administrative Order in effect when Judge Pucillo sealed these documents was 2.032-10/06. As explained above, the procedures designated therein would not apply since Judge Pucillo filed and sealed the documents sua sponte, not by motion. To the extent that the Administrative Order conflicts with the version of rule 2.420 then in effect, the rule prevails. Judge Pucillo was not required to follow Administrative Order 2.032 when she sealed the documents in June 2008. Assuming compliance with procedures for confidentiality was required, Mr. Epstein met them. At all times, the rules of judicial administration provided that court records "shall be confidential" if a court has determined that confidentiality is required. Fla. R. Jud. Admin. 2.420(c)(9). Rule 2.420(cX9) provides: (IL ExemptionsrThe-folluwieg ►ecords of the judicial branch shall be confidential: (9) Any court record determined to be confidential in case decision or court rule on the grounds that 13 EFTA00231160 (A) confidentiality is required to (i) prevent a serious and imminent threat to the fair, impartial, and orderly administration of justice; (ii) protect trade secrets; (iii) protect a compelling governmental interest; (iv) obtain evidence to determine legal issues in a case; (v) avoid substantial injury to innocent third parties; (vi) avoid substantial injury to a party by disclosure of matters protected by a common law or privacy right not generally inherent in the specific type of proceeding sought to be closed; (vii) comply with established public policy set forth in the Florida or United States Constitution or statutes or Florida rules or case law; (B) the degree, duration, and manner of confidentiality ordered by the court shall be no broader than necessary to protect the interests set forth in subdivision (A); and (C) no less restrictive measures are available to protect the interests set forth in subdivision (A). Fla. R. Jud. Admin. 2.420(c)(9). Thus, courts are required to seal court records upon a finding that closure is need to "prevent a serious and imminent threat to the fair, impartial, and orderly administration of justieee-teaveitl-substantittlAnjury-te-inneeent-third-partics" or to "avoid substantial injury to a party by disclosure of matters protected by a common law or privacy right not generally inherent in the specific type of proceeding 14 EFTA00231161 sought to be closed." Fla. R. Jud. Admin. 2.420(c)(9Xi), (v), (vi). Mr. Epstein's Motion to Make Court Records Confidential satisfied these requirements; thus, the court erred in denying it. Mr. Epstein alleged three separate grounds for confidentiality. He first argued that confidentiality is necessary to protect a compelling government interest. He satisfied this prong since the United States Attorney's Office has a compelling interest in having the confidentiality provision of its contract with Mr. Epstein honored. Judge Marra already balanced that interest against arguments for disclosure and struck a balance by requiring disclosure to plaintiffs and their lawyers, but not to third parties. Secondly, Mr. Epstein contended that maintaining confidentiality will avoid injury to innocent third parties, a, the other persons the United States Attorney's Office agreed not to prosecute who will be harmed if the documents are unsealed. Thirdly, Mr. Epstein demonstrated that confidentiality is necessary to avoid substantial injury to a party by disclosure of matters protected by a common law or privacy right not generally inherent in the specific type of proceeding sought to be closcd. Disclosure-cif these-documents-is-not-generally-inli in a state court plea hearing and will violate Mr. Epstein's common law right to confidentiality. 15 EFTA00231162 There is no prejudice to non-parties/interveners ., M. and The Post, if disclosure is stayed pending the outcome of Mr. Epstein's emergency petition for certiorari. Mr. Epstein, on the other hand, will suffer irreparable harm once the documents are produced—a fact the trial court recognized (A-19:16). CONCLUSION This Court should grant certiorari and quash the June 25, 2009 order granting non-parties' motions to unseal the confidential non-prosecution agreement and addendum between Mr. Epstein and the United States Attorney's Office. CERTIFICATION OF EXISTENCE OF EMERGENCY Undersigned counsel certifies that the subject of this petition constitutes an emergency. The trial court's order at noon on July 2, 2009, provides that the confidential federal non-prosecution agreement and addendum will be disclosed. Once these documents are disclosed, irreparable harm will-result. 16 EFTA00231163 I HEREBY CERTIFY that a copy of the foregoing has been sent by E-Mail and Federal Express this 3ati.day of June, 2009, to: U.S. Attorney's Office-Southern District 500 South Australian Avenue, West Palm Beach, FL 33401 WILLIAM J. BERGER ROTHSTEIN ROSENFELDT ADLER 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale. FL 33394 Counsel for SPENCER T. KUVIN LEOPOLD-KUVIN, P.A. 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, FL 33410 Counsel for M. JUDITH STEVENSON ARCO State Attorney's Office-West Palm Beach 401 North Dixie Highway West Palm Beach, FL 33401 DEANNA K. SHULLMAN 400 North Drive, Suite 1100 P. O. Box 2602 (33601) Tampa, FL 33602 Counsel for The Palm Beach Post HONORABLE JEFFREY COLBATH Palm Beach County Courthouse 205 North Dixie Highway Room I IF West Palm Beach, FL 33401 ROBERT D. CRITTON BURMAN, CRITTONLUTTIER & COLEMAN 515 N. Flagler Drive, West Palm Beach, FL 33401 and JACK A. GOLDBERGER ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 and 17 EFTA00231164 JANE KREUSLER-WALSH and BARBARA J. COMPIANI of KREUSLER-WALSH, COMPIANI & VARGAS, P.A. 501 South Flagler Drive, Suite 503 West Palm Beach, FL 33401-5913 Counsel for Petitioner B SANE It a-4-4-16 USLER-WALSH iFlorida Bar No. 272371 18 EFTA00231165 06-26-'09 13:39 FROMM & LOCICERO T-059 F001/005 F-889 THOMAS LOCICERO BRALOW 400 N. DriveeSuite 1100•Tam a FL 33602 (Phone) (Fax) Toll Free: 866.395-7100 L facsimile transmittal To: Marilyn, Judicial Assistant to Judge FAX 561-355-1616 Colbath R. Alexander Acosta, Esq., USAO Barbara Burns, Esq., ASAO Jack Alan Goldberger, Esq. Bradley J. Edwards, Esq. William J. Berger, Esq. Robert D. Critton, Esq. Spencer T. Kuvin, Esq. From: Deanna K. Shullman, Esq. Re: State v. J. Epstein Date: 06/04/2009 Pages: 5 urgent ❑ For review D Please see attached proposed Order. 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To the extent this corresponderce com ma federal tax edvict, such advice was not intended to be used, and cannot be used by any uncptyer, for the purpose of (I) avoidtg penalties under the Internal Revenue Code or (i) promoting. marketing, or recommending to another party any uansaction or matter addressed herein. !frau would like us to prepare written tax advice designed to provide penalty prorectim, please contact us and we will be happy to discuss the mesa with you bi more detail confidential EFTA00231166 06-26-'09 13:39 FROM & LOCICERO T-059 P002/005 F-889 Tamp 400 N Dr., SW. 1100, Tampa, FL 33602 THOMAS I ()CICERO P.O. x Tampa ph, fax 1-2602 toll Ft. Lauderdale BRALOW 101 N.E. INS Ave,, SW. 1500 Foht..ISSIL 101111fee New York City 220 E 42nd St.. 10th Flom New York. NY 10017 ee tax WAN/ slo1eveirm rem Dee Direct Deanna.shu„manottoiawfirm.com Reply To Tampa June 26, 2009 VIA FASCIMILE The Honorable Jeffrey Colbath Fifteenth Judicial Circuit-Palm Beach Palm Beach County Courthouse Main Judicial Complex 205 N. Dixie Highway, Room 11F West Palm Beach, FL 33401 Re: State of Florida v. Jeffrey Epstein Dear Judge Colbath: This law firm represents the Palm Beach Post in the above matter. I have prepared a proposed Order, which I believe accurately reflects your ruling at the hearing on June 26, 2009 on Defendant Jeffrey Epstein's Motion to Stay Disclosure of the Non-Prosecution Agreement and Addendum Pending Review. By copy of this letter, I am providing all counsel of record a copy of the proposed Order. If the attached Order meets with Your Honor's approval, please enter the same. If you would like to have an electronic copy of this proposed order, please have your Judicial Assistant call my office to make arrangements for us to send you the order via email. Sincerely, THOMAS, LOCICERO & BRALOW PL ,atlena.0-0 K Deanna K. Shullman EFTA00231167 06-26-'09 13:40 FROM-THOMAS & L0CICER0 T-059 P003/005 F-889 Hon. J. Colbath 06/26/09 Page 2 of 2 DKS/kb Enclosures cc: U.S. Attorney's Office (via facsimile) State Attorney's Office (via facsimile) Jack Alan Goldberger, Esq. (via facsimile) Bradley J. Edwards, Esq. (via facsimile) Deanna K. Shullman, Esq. (via facsimile) Spencer T. Kuvin, Esq. (via facsimile) EFTA00231168 06-26-'09 13:41 FROM-THOMAS & L0CICER0 T-059 P004/005 F-889 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CRIMINAL DIVISION STATE OF FLORIDA vs. JEFFREY EPSTEIN Case Nos.: 2006-CF9454-AXX & 2008-9381CF-AXX ORDER This matter came before the Court on Defendant Jeffrey Epstein's Motion to Stay Disclosure of the Non-Prosecution Agreement and Addendum Pending Review and upon further consideration of this Court's June 26, 2009 Order unsealing certain records in this case. A hearing was conducted on these matters on June 26, 2009. On June 26, 2009, this Court entered an order unsealing the non-prosecution agreement and an addendum on file in this case. Having inspected the documents, this Court finds that they do not name any victims and do not contain any material subject to confidentiality pursuant to Federal Rule of Criminal Procedure 6. Thus, the Court declines to make any redactions to the records before releasing them to the public. The Court further finds that Defendant has not demonstrated that a stay pending appeal is warranted. Defendant has not shown any irreparable harm or likelihood of success on the merits on appeal. These documents were not properly closed in the first instance, no present basis for closure exists, and good cause supports disclosure given the public interest in these proceedings and the lack of compelling interest in closure. Accordingly, it is ordered and adjudged as follows: 1. Effective at noon on July 2, 2009, the non-prosecution agreement (docketed July 2, 2008) and addendum (docketed August 25, 2008) are unsealed; EFTA00231169 06-26-'09 13:42 FROM-THOMAS & L0CICER0 T-059 P005/005 F-889 2. Defendant's Motion for Stay pending appellate review is DENIED; 3. The Clerk of Court is directed to release the documents to the public at noon on Thursday, July 2, 2009. Done and ordered this day of June, 2009 in Palm Beach County, West Palm Beach, Florida. Hon. Jeffrey Colbath CIRCUIT JUDGE cc: U.S. Attorney's Office State Attorney's Office Jack Alan Goldberger, Esq. Bradley 1. Edwards, Esq. Deanna K. Shullman, Esq. Spencer T. Kuvin, Esq. 2 EFTA00231170 KnEusixn-WALsit, COMPIANI & VARGAS, P.A. SUITE 5O3. FLAGLER CENTER 501 SOUTH FLAGLER DRIVE WEST PALM BEACH, FLORIDA 33401-5913 JANE KREUSLER-WALSH BARBARA J. COMPIANI REBECCA MERCIER VARGAS BOARD CERTIFIED APPELLATE LAWYERS By Hand Delivery Honorable Jeffrey Colbath Palm Beach County Courthouse Fifteenth Judicial Circuit 205 North Dixie Highway, Room 11F West Palm Beach, FL 33401 June 30, 2009 Re: Epstein v. State of Florida 15th Circuit Court Case No. 2008CF009381A Dear Judge Colbath: 'ELEPHONE FACSIMILE Enclosed is a copy of Epstein's Emergency Petition for Writ of Certiorari, Emergency Motion to Review Denial of Stay, Motion to Use One Appendix and Motion to Seal, as filed with the Fourth District Court of Appeal. Due to the volume of the appendix, we have only enclosed the table of contents. Please let us know if you wish to receive a copy of the appendix. Thank you. JKW/bl Enclosure seleno. Robert D. Critton Very truly yours, p1CREUSLER-WALSH Jack A. Goldber er Judith Stevenson Arco William J. Berger Deanna K. Shullman Spencer T. Kuvin EFTA00231171 IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA, FOURTH DISTRICT JEFFREY EPSTEIN, CASE NO. PALM BEACH COUNTY Petitioner, L.T. CASE NO. 2008 CF 009381A v. STATE OF FLORIDA, Respondent. APPENDIX TO EMERGENCY PETITION FOR WRIT OF CERTIORARI AND EMERGENCY MOTION TO REVIEW DENIAL OF STAY ROBERT D. CRITTON BURMAN, CRITTON, LUTTIER & COLEMAN 515 North Flagler Drive, West Palm Beach, FL 33401 and JACK A. GOLDBERGER ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 and JANE ICREUSLER-WALSH and BARBARA J. COMPIANI of KREUSTRB-WAT COMPIANI & VARGAS, P.A. 501 South Flagler Drive, Suite 503 West Palm Beach, FL 33401-5913 Counsel for Petitioner EFTA00231172 e EFTA00231173 Document Tab Proceedings in Southern District Court Victim's (Doe) Petition for Enforcement of Crime Victim's Right Act, 18 U.S.C. Section 3771 Judge Marra's Order to Compel Production and Protective Order (8/21/08) Victims' (Doe #1 and Doe #2) Motion to Unseal Non￾Prosecution Agreement (9/25/08) A-1 A-2 A-3 Respondent's (U.S. Attorney's Office) Opposition to Victims' Motion to Unseal Non-Prosecution Agreement (10/8/08) A-4 Victims' (Doe #1 and Doe #2) Reply to Respondent's A-5 Opposition to Victims' Motion to Unseal Non-Prosecution Agreement (10/16/08) Judge Marra's Order Denying Petitioners' (Doe #1 and Doe #2). Motion to Unseal Non-Prosecution Agreement (2/12/08 [sic should be 2/12/09]) Proceedings in 15th Judicial Circuit Transcript of Epstein's Plea Conference (6/30/08) Epstein's Plea (6/30/08) Agreed Order Sealing Document in Court File (7/2/08) NonParty M.'s Motion to Vacate Order Sealing Records And Unseal Records (5/12/09) A-6 A-7 A-8 A-9 A-l0 Palm Beach Post's Motion to Intervene and Petition for A-11 Access (6/1/09) Applicant, ■.'s Motion to Intervene and Supporting A-12 Memorandum of Law (6/11/09) EFTA00231174 Document Tab Epstein's Motion to Make Court Records Confidential (6/11/09) A-13 Epstein's Motion to Stay Disclosure of the Non-Prosecution A-14 Agreement and Addendum Pending Review (6/25/09) Intervener's [..] Response to Motion to Stay and Supporting Memorandum of Law (6/26/09) A-15 Order of Judge Jeffrey J. Colbath granting motions to unseal (6/25/09) A-16 Order of Judge Jeffrey J. Colbath denying motion to stay (6/26/09) A-17 Transcript on non-parties' motions to unseal and Epstein's motion for confidentiality (6/25/09) A-18 Transcript on Epstein's motion to stay (6/26/09) A-19 EFTA00231175 LEGAL RECYCLED PAPER TO REORDER CALL 954446-9399 EFTA00231176 Case 9:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 08-80736-Civ-MARRA/JOHNSON CASE NO.: IN RE: JANE DOE, Petitioner. FI cilio ELaT JULY 7, 2008 STEVEN IA. LARIUORE CLERK M.S. GIST. CS. 5.0. Or ILA. • MIAMI s,., ers end y VICTIM'S PETITION FOR ENFORCEMENT OF CRIME VICTIM'S RIGHTS ACT. 18 U.S.0 . SECTION 3771 COMES NOW the Petitioner, JANE DOE (hereinafter "Petitioner"), by and through her undersigned attorneys, pursuant to the Crime Victim's Rights Act, 18 U.S.C. Section 3771 (''CVR_A"), and files this Petition for Enforcement in the above styled action as follows: I. Petitioner, an adult, as a minor child was a victim of federal crimes committed by JEFFREY EPSTEIN (hereinafter "Defendant"). These crimes included sex trafficking of children by fraud, in violation of 18 U.S.C. § 1591, use of a means of interstate commerce to entice a minor to commit prostitution, in violation of 18 U.S.C. § 2422, as well as wire fraud, in violation of 18 U.S.C. § 1343. The Defendant committed these crimes within the jurisdiction of the Southern District of Florida in Palm Beach County, Florida. 2. Upon information and belief, the Defendant is the subject of a federal criminal investigation conducted by the United States of America in the Southern District of Florida. The Defendant has recently been prosecuted and pleaded guilty, on June 30, 2008, in the Circuit Court for Palm Beach County to various similar slate offenses including solicitation of minors for prostitution. 3. Upon information and beliefs the Defendant is engaged in plea negotiations-with the Office of the United States Attorney for the Southern District of Florida concerning federal 0110 EFTA00231177 Case 9:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 Page 2 of 10 crimes which he is alleged to have committed against minor children, including the Petitioner. Such negotiations may likely result in a disposition of the charges in the next several days. 4. Under the CVRA, before any charges are filed against the Defendant, the Petitioner has the rights (among others) to notice of her rights under the CVRA, to confer with the prosecutors, and to be treated with fairness. As soon as charges are filed, the Petitioner has the rights (among others) to timely notice of court proceedings, the right not to be excluded from such proceedings, the right to be heard at such public proceedings regarding conditions of release, any plea, and any sentence, the right to confer with the attorney for the government, the right to restitution, and the right to be treated with fairness and with respect for her dignity and privacy. 5. The Petitioner has been denied her rights in that she has received no consultation with the attorney for the government regarding the possible disposition of the charges, no notice of any public court proceedings, no information regarding her right to restitution, and no notice of rights under the CVRA, as required under law. 6. The Petitioner is in jeopardy of losing her rights, as described above, if the government is able to negotiate a plea or agreement with the Defendant without her participation and knowledge. WHEREFORE, for the reasons outlined above, the Petitioner respectfully requests this Court to grant her Petition, and to order the United States Attorney to comply with the provisions of the CVRA prior to and including any plea or other agreement with the Defendant and any attendant proceedings. 2 2.110 EFTA00231178 Case 9:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07107/2008 Page 3 of 10 MEMORANDUM I. THE CRIME VICTIMS' RIGHTS ACT MAKES CRIME VICTIMS INDEPENDENT PARTICIPANTS THROUGHOUT THE CRIMINAL JUSTICE PROCESS. In October 2004, Congress passed and the President signed into law the Crime Victims' Rights Act, Pub. L. No. 108-405, 118 Stat. 2251 (codified at 18 U.S.C. § 3771). Because this appears to be the first case involving the Act to come before this Court, a bit of background may be in order. A. The CVRA Gives Crime Victims Rights to Participate in the Criminal Justice Process. Congress passed the CVRA "to give crime victims enforceable rights to participate in federal criminal proceedings." Opinion at 14. Congress was concerned that in the federal system crime victims were "treated as non-participants in a critical event in their lives. They were kept in the dark by prosecutors too busy to care enough ... and by a court system that simply did not have a place for them." 150 CONG. REC. S4262 (Apr. 22, 2004) (statement of Sen. Feinstein). To remedy this problem, Congress gave victims "the simple right to know what is going on, to participate in the process where the information that victims and their families can provide may be material and relevant ... ." Id. The CVRA gives victims of federal crimes a series of rights, including the right to notice of court proceedings, to be heard at plea and sentencing hearings, and to reasonably "confer with the attorney for the Government in the case." 18 U.S.C. § 3771(a). Victims also have a "right of access to the terms of a plea agreement ... ." In re Interested Parry 1, 530 F.Supp. 2d 136, 2008 WL 134233 at •7 (D.D.C. 2008). The CVRA also assures victims broadly that they will "be treated with fairness." 18 U.S.C. § 377I(a)(8). 3 1010 EFTA00231179 Case 9:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 Page 4 of 10 *a/ Of course, these rights would be of little use to most crime victims unless they were told about them. To ensure that victims are notified of their rights, the CVRA directs employees of the Justice Department "and other departments and agencies of the United States engaged in the detection, investigation, or prosecution of crime" to use their "best efforts to see that crime victims are notified of the rights described (in the CVRA]." 18 U.S.C. § 3771(c)(1) (emphasis added).1 B. The CVRA Gives Victims Rights During the Investigation of a Crime. The CVRA gives victims rights during the investigation of a crime. The Fifth Circuit recently reached this conclusion, holding: The district court acknowledged that "(t]here are clearly rights under the CVRA that apply before any prosecution is underway." BP Prods., 2008 WL 501321 at '11, 200811.S. Dist. LEXIS 12893, at *36. Logically, this includes the CVRA's establishment of victims' "reasonable right to confer with the attorney for the Government." 18 U.S.C. & 3771(a)(5). At least in the posture of this case (and we do not speculate on the applicability to other situations), the government should have fashioned a reasonable way to inform the victims of the likelihood of criminal charges and to ascertain the victims' views on the possible details of a plea bargain. ha re Dean, 527 F.3d 391, 394 (5th Cir. 2008). The position that CVRA rights apply before charges have been filed is consistent with the Justice Department regulations under the CVRA, which explain that government officials "must advise a victim (about their rights under the CVRA) ... at the earliest opportunity at which it may be done without interfering with an investigation." A.G. GUIDELINES FOR VICTIM AND WrThrESS I Further supporting this requirement is another statute, 42 U.S.C. § I0607(c)(3), which directs government officials to provide victims with "the earliest possible notice of," among other things, "the filing of charges against a suspected offender." 4 loll@ EFTA00231180 Case 9:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 Page 5 of 10 yostr Nvor ASSISTANCE 23 (May 2005). And the plain language of the CVRA undergirds this conclusion, as it applies not simply to prosecutors but to government agencies "engaged in the detection [and) investigation ... of crime ... ." 18 U.S.C. § 3771(c)(1). Indeed, if there were any doubt, the plain language of the CVRA extends victims' right to situations "in which no prosecution is underway." 18 U.S.C. § 3771(dX3). H. PETITIONER IS A "VICTIM PROTECTED BY THE CVRA. Under the CVRA the crime victim is defined as "a person directly and proximately harmed as a result of the commission of a Federal offense ... ." 18 U.S.C. Section 3771(e). In particular, Defendant called Petitioner when she was a minor over a telephone (a means of interstate communication) requesting that she perform a massage in exchange for payment. As Defendant well knew, that request was fraudulent, as he not only intended to receive a massage, but also intended to have her perform sexual acts in exchange for a cash payment to Petitioner. Only when Petitioner arrived at a Defendant's mansion as directed by Defendant, did Defendant reveal his true purpose of obtaining sexual favors in exchange for payment This conduct violated 18 U.S.C. § 2422, which forbids using a means of interstate commerce to knowingly "induce" or "entice" a minor "to engage in prostitution." In addition, this conduct was both a use of "fraud" to obtain a commercial sex act, in violation of 18 U.S.0 § 1591, and use of wire communications to perpetrate a "scheme and artifice to defraud," in violation of 18 U.S.C. § 1343. It appears obvious that Petitioner was "directly and proximately" harmed by these crimes, thereby making her a victim under the CVRA. It should be emphasized that_the CVRA "was designed to be a 'broad and encompassing' statutory victims' bill of rights." United States' 5 lot 00 EFTA00231181 Case 9:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 Page 6 of 10 v Degenhardt, 405 F.Supp.2d 1341, 1342 (D. Utah 2005) (quoting 150 Cong. Rec. S4261 (daily ed. Apr. 22, 2004) (statement of Sen. Feinstein)). Congress intended the CVRA to dramatically rework the federal criminal justice system. In the course of construing the CVRA generously, the Ninth Circuit observed: "The criminal justice system has long flinctioned on the assumption that crime victims should behave like good Victorian children — seen but not heard. The Crime Victims' Rights Act sought to change this by making victims independent participants in the criminal justice process." Kenna v. U.S. Dist. Court for C.D. Cat, 435 F.3d 1011, 1013 (9th Cir. 2006). Accordingly, because the CVRA is remedial legislation, courts should interpret it "liberally to facilitate and accomplish its purposes and intent." Elliott Industries Ltd. Partnership v. BP America Production Co., 407 F.3d 1091, 1118 (10th Cir. 2005) (noting remedial legislation should be "interpreted liberally to facilitate and accomplish its purposes and intent"). The CVRA itself suggests this conclusion by requiring that courts must treat crime victims with "fairness." United States v. Patkar, 2008 WL 233062 at •3 (D. Haw. 2008) (citing United States v. Turner, 367 F.Supp.2d 319, 335 (ED.N.Y. 2005)). Not only must the CVRA as a whole be interpreted liberally, but its definition of "crime victim" requires a generous construction. After reciting the direct-and-proximate-harm language at issue here, one of the Act's two co-sponsors -- Senator Kyl -- explained that "Mills is an intentionally broad definition because all victims of crime deserve to have their rights protected ." 150 Cong. Rec. S10912 (Oct. 9, 2004) (emphasis added). The description of the victim definition as "intentionally broad" was in the course of floor colloquy with the other primary sponsor of the CVRA and therefore deserves significant weight. See Kenna, 435 F.3d at 1015T6 (discussing significance of CVRA sponsors.. floor statements). 6 EFTA00231182 Case 9:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 Page 7 of 10 4.•• The definition of "crime victims" must thus be construed broadly in favor of Petitioner. She obviously qualifies as a "victim" under the CVRA. III. PETITIONER IS ENTITLED TO NOTICE OF HER RIGHTS, AN OPPORTUNITY TO CONFER WITH THE PROSECUTORS AND TO BE TREATED WITH FAIRNESS. Because Petitioner is a "victim" under the CVRA, she has certain protected rights under the Act. Most important, the Act promises that she will have an opportunity to "confer with the attorney for the Government in the case." To date, Petitioner has not been given that right. This raises that very real possibility that the Government may negotiate and conclude a plea agreement with the Defendant without giving Petitioner her protected rights.2 Petitioner is entitled to have this conference with prosecutors before any final plea agreement is reached. The Fifth Circuit reached exactly this conclusion in a very recent case. In In re Dean, 527 F.3d 391 (5th Cir. 2008), the Government negotiated a plea agreement with the well-heeled corporate defendant without conferring with the victims. When the Government's failure was challenged in the Fifth Circuit, the Fifth Circuit concluded that the Government had indeed violated the CVRA. The Fifth Circuit observed: "in passing the [CVRAJ, Congress made the policy decision-which we are bound to enforce-that the victims have a right to inform the plea negotiation process by conferring with prosecutors before a plea agreement is reached." Id. at 394. This Court is obligated to protect the lights of Petitioner. The CVRA directs that "[i]n any court proceeding involving an offense against a crime victim, the court shall ensure that the 2 On information and belief, roughly the same crimes werc committed against several other young females. These victims, too, arc in danger of losing their right to confer under the CVRA. 7 7 of 10 EFTA00231183 Case 9:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 Page 8 of 10 crime victim is afforded the rights described in [the CVRA)." 18 U.S.C. § 3771(bX1). The CVRA also confers on crime victims the right to "assert the rights described in [the CVRA]." 18 U.S.C. § 3771(d)(I). Therefore, this Court has its own independent obligation to intercede and ensure that the Government respects the rights of Petitioner under the CVRA. CONCLUSION The Petitioner requests the intervention of this Court to ensure that her rights are respected and accorded, as promised in the Crime Victims' Rights Act. DATED this 7th day oil& 2008. Respectfully Submitted, THE LAW OFFICE OF BRAD EDWARDS & ASSOCIATES, LLC Brad Edwards, Esquire Attorney for Petitioner Florida Bar #542075 2028 Harrison Street Suite 202 Hollywood, Florida 33020 Telephone: Facsimile: 8 emu, EFTA00231184 Case 9:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 Page 9 of 10 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been provided by United States mail and via facsimile to: United States Attorney's Office, 500 South Australian Avenue, Florida 33401, this ah day of July, 2008. c410 , AUSA, West Palm Beach, Brad Edwards, Esquire Attorney for Petitioner Florida Bar No. 542075 9 EFTA00231185 cnf:8PaZgaxg4k-NWAPM§PN •.lido Ito. :MO ntered on FLSD Docket 07/07/2008 CIVIL COVER SHEET 'be44 tie IcoverslHerond she infomutIon contained herein neither replace nor supplement the flhing said servece of pleadings or other papers It I mks of coon. This form, approved by the Jadicia/ Con (nonce of ilse United Slaws in September 7974, is roamed De the use of the Crok lit civil code sheet (SEC INSTRUCTIONS on THC REVERSE or tat soar NOTICE: Attorneys MUST Indicate All Re-filed I. (a) PLAINTIFFS DEFENDANTS U. 5-67Pcs￾X , / r e: Jane Poe (b) Como) of Residence of First Listed Plaintiff fi iiffn OE %KEPT IN U.S. PLAINT'S/ CASES) (e) Anomey's.n. Num. Addina.•40 Telephone swam H 9,4 COCA lf .f erri O gamkter /issota Yrs raze barecran centre￾bart Afiyivoni, Fe 55 OZ° Ill Check Cooney Where mike Ansa Ise IAN e• DADS 3 MONROE 3 IRON/ARO /PALM BEACH 3 MARTIN 3 ST. CUM 7 INDIAN RIVER 7 OKEECHOBEE OWNLANDS II. BASIS OF JURISDICTION men .6-x^ roar air oeso III. C TIZENSHIP OF PRINCIPAL PARTIESmiletrers Oat Du Sri mow for Incas Cans Oily) sod Om Ova IMOTEN4401 U.S. thrmsmalt 3 ) Tenni ONION PT? DEI PT? REP P1000414 WS. Uovenia441 MM • P.m) CM/ 44 Yin tom 3 1 7 I Imam i• Feimmal Plea 3 4 74 LCCT EFTAWDWI 0 D.C. 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REQUESTED IN Cl CHECK IF THIS IS A CLASS ACTION DEMANDS CHECK YES only if demanded in complaint: COMPLAINT: UNDER F.R.CE 23 JURY DEMAND: O Yes 3 No SHE 0.BOVE BEST INFORMATI OF MY ONI KNOWLEDGE STRUE & CORRECT TO SIONATZ way or 1/CCORO *Ars -- 7- Ce FOR OPTIC( Fig ONLY AMOUNT 35D, RECEIPT P 774{41031" 104110 EFTA00231186 e. LEGAL RECYCLED PAPER 170, == TO REORDER CALL 954-10.9399 ry EFTA00231187 Case 9:08-cv-80736-KAM Document 26 Entered on FLSD Docket 08/21/2008 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA NO. 08-80736-CIV-MARRA/JOHNSON IN RE: JANE DOES 1 AND 2, Petitioners. I ORDER TO COMPEL PRODUCTION AND PROTECTIVE ORDER THIS CAUSE comes before the Court on the Petitioners' ore tenus motion seeking the production of the Non-Prosecution Agreement between the United States Attorney's Office for the Southern District of Florida ("USAO") and Jeffrey Epstein ("Epstein"). After consideration of the Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement, including any modifications and addenda thereto, in accordance with the following procedures: (a) The USAO shall produce a copy of the Non-Prosecution Agreement, including any modifications and addenda thereto (collectively referred to as the "Agreement"), to the attorneys for Petitioners. (b) Petitioners and their attorneys shall not disclose the Agreement or its terms to any third party absent further court order, following notice to and an opportunity for Epstein's counsel to be heard. (e) Before counsel for petitioners show the Agreement to their clients or discuss the specific terms with them, they must provide a copy of this Order to petitioners, who must review and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for petitioners must promptly provide a copy of that acknowledgment to the USAO. (d) If any individuals who have been identified by the USAO as victims of EFTA00231188 Case 9:08-cv-80736-KAM Document 26 Entered on FLSD Docket 08/21/2008 Page 2 of 2 Epstein and/or any attomey(s) for those individuals request the opportunity to review the Agreement, then the USAO shall produce the Agreement to those individuals, I long as those individuals also agree that they shall not disclose the Agreement or its terms to any third party absent further court order, following notice to and an opportunity for Epstein's counsel to be heard (e) Prior to producing the documents to any other individuals who have been identified by the USAO as victims of Epstein and/or any attomey(s) for those individuals, a copy of this Order must be provided to said individuals, who must review and acknowledge their receipt of, and agreement to abide by, the terns of this Order. Counsel for petitioners must promptly provide a copy of that acknowledgment to the USAO. DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida, this 21" day of August, 2008. Copies furnished to: all counsel of record Order. Dated: ,e, KENNETH A. MARRA UNITED STATES DISTRICT JUDGE By signing below, I certify that I have reviewed and agree to be bound by the terms of this Signed by: Printed Name: 2 EFTA00231189 RECYCLED PAPER TO REORDER CALL 954446-9199 CL.) EFTA00231190 Case 9:08-cv-80736-KAM Document 28 Entered on FLSD Docket 09/25/2008 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Petitioners, v. UNITED STATES OF AMERICA, Respondent VICTIM'S MOTION TO UNSEAL NON-PROSECUTION AGREEMENT COMES NOW the Petitioners, Jane Doe #1 and Jane Doe #2, by and through their undersigned attorneys, pursuant to the Crime Victim's Rights Act, 18 U.S.C. Section 3771 • ("CVRA"), and file this motion to unseal the non-prosecution agreement that has been provided to their attorneys under seal in this case. The agreement should be unsealed because no good cause exists for sealing it. Moreover, the Government has inaccurately described the agreement in its publicly-filed pleadings,.creating a false impression that the agreement protects the victims. Finally, the agreement should be unsPaled to facilitate consultation by victims' counsel with others involved who have information related to the case. BACKGROUND As the court is aware, this action was brought by two crime victims (hereinafter referred to as "the victims") seeking protection of their rights under the Crime Victim's Rights Act, 18 U.S.C. § 3771. At the center of this action is an agreement between the United States and Jeffrey Epstein that (as described in earlier court pleadings publicly filed by the Government) involved EFTA00231191 Case 9:08-cv-80736-KAM Document 28 Entered on FLSD Docket 09/25/2008 Page 2 of 8 Epstein's entry of guilty pleas to various state charges and an 18-month jail sentence, in exchange for which the U.S. Government apparently agreed to defer all federal prosecution — including any federal prosecution for the federal crimes committed against the victims. At a hearing held on August 14, 2008, the court ordered the Government to produce to counsel for the victims the non-prosecution agreement. That production, however, was to be done under protective order in the first instance. The agreement has now been produced. At the earlier hearing, the court recognized that the victims' counsel might at a later date seek to have the sealing lifted. That date has now arrived. ARGUMENT As the court envisioned might well happen, counsel for the victims now believe that sealing of the agreement is no longer appropriate. The non-prosecution agreement should now be unsealed for three reasons. 1. No Good Cause Has Been Shown for Sealing the Agreement. Having now reviewed the agreement, counsel for the victims can find no legitimate basis for the document to be sealed. Because it stands at the center of this litigation (as well as several related civil suits), the burden should fall on those who would keep the document sealed to show cause for doing,. No good cause has yet been shown. Cf United . States v. Ochoa-Vasque, 428 F.3d 1015 (11* Cir. 2005) (to justify sealing of court records "a court must articulate the overriding interest along with findings specific enough that a reviewing court can determine whether the closure order was properly entered"). 2. The Government Has Inaccurately Described the Agreement. In its publicly-filed pleadings in this case, the Government has inaccurately 2 EFTA00231192 Case 9:08-cv-80736-KAM Document 28 Entered on FLSD Docket 09/25/2008 Page 3 of 8 described the non-prosecution agreement, creating the false impression that it is more favorable to the victims than it actually is. Accordingly, the non-prosecution agreement should be unsealed that the true state of affairs is reflected in the court's file. In its response to the victims' petition, the Government states that the non￾prosecution agreement contains the following 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 had been hied federally and convicted of an enumerate 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 bad Mr. Epstein been convicted at trial. No more; no less. Govt's Resp. to Victim's Emergency Petition for Enforcement of Crime Victim's Right at 4. The sworn declaration of the Assistant U.S. Attorney handling this matter also recounts the same language. See Declaration of in Support of United States' Response to Victims' Emergency Petition at 3-4. The sworn declaration also states that victims were told about this language in October 2007. See Declaration of at 4 ("In October 2007, shortly after the agreement was signed, four victims were contacted and these provisions were discussed"). On July 9, 2008, the victims received notice from the Government that the above-described provision was negotiated on behalf of the victims for their protection and was 3 EFTA00231193 Case 9:08-cv-80736-KAM Document 28 Entered on FLSD Docket 09/25/2008 Page 4 of 8 thus contained in the non-prosecution agreement.1 Having now reviewed the non-prosecution agreement, the Government's response to the victims' motion and the accompanying sworn declaration are simply untrue. The above￾quoted provision simply does not appear fn the agreement anywhere. It is true that the non￾prosecution agreement contains a provision bearing on the same subject However, this provision has a number of qualifying provisos that make it far less favorable to the victims than the above-described provision. (To avoid filing a separate, sealed pleading laying out the differences, counsel for the victims have simply described the differences in general terms. We trust that the Government, in its response, will agree that it has erroneously described the agreement to the court and the victims.) The Government should be required to correct its previously-filed pirwlings to accurately recount the non-prosecution agreement that it reached with Epstein. Moreover, the Government should also be required to state forthrightly whether through the last nine months, it gave the victims (like the court) inaccurate information about what the non-prosecution agreement entailed. But most important, because the current sealing of the non-prosecution agreement creates a false and deceptive appearance about the agreement that the Government has actually reached with Epstein, the agreement should be unsealed. Indeed, it should be noted that sealing of materials in this case appears to operate in a rather peculiar fashion. The Government apparently feels free to disclose to the victims one provision in the non-prosecution agreement that it believes it is to its advantage to disclose, but not others. The Government should not be permitted to pick and choose, particularly where it I The Government has recently provided a new notice to the victim; containing different language. 4 EFTA00231194 Case 9:08-cv-80736-KAM Document 28 Entered on FLSD Docket 09/25/2008 Page 5 of 8 has inaccurately described the provision that it has chosen to disclose. 3. The Non-Prosecution Agreement Should be Unsealed To Facilitate Effective Renresemation of the Victims in this Action and Related Civil Actions. The sealing order bars the victims' counsel from "disclos[ing] the Agreement or its terms to any third party absent further court order, following notice to and an opportunity for Epstein's counsel to be heard." Order to Compel Production and Protective Order at I. Victims' counsel have scrupulously abided by that restriction. Victims' counsel would, hoWever, now like to discuss the terms of the non-prosecution agreement with third parties in making a determination about how best to proceed in this action, including what remedies to seek for the violations of victims' rights that have occurred. Counsel, therefore, respectfully seek the "further court order" that the sealing order envisions. In particular, victims' counsel would like to discuss the agreement with other victims of Epstein and their attorneys to determine whether they were likewise provided with inaccurate information about the nature of the plea agreement. Victims' counsel would also like to discuss possible legal responses to the Government with other victims' rights attorneys, including in particular the National Alliance of Victims' Rights Attorneys for possible legal approaches. See httni/www.ncvli.ont/navra.html. The sealing order would apparently block these forms of consultation, or perhaps require such burdensome non-disclosure obligations as to make the consultation difficult or impractical. Finally, victims' counsel would like to refer to the non-prosecution agreement in a parallel civil suit that is pending before this court. See Jane Doe v. Jeffrey Epstein, United States District Court, Southern District of Florida, Case No.: 08-CIV￾80893-MARILWOFINSON. To €acilitate all these discussions, the non-prosecution agreement 5 EFTA00231195 Case 9:08-cv-80736-KAM Document 28 Entered on FLSD Docket 09/25/2008 Page 6 of 8 should be unsealed. NOTICE TO EPSTEIN It is possible that Jeffrey Epstein will object to the unsealing of the agreement. Accordingly, the court should provide notice of this motion to Jeffrey Epstein, through counsel. Jeffrey Epstein's counsel has entered an appearance in several related civil suits, including Jane Doe v. Jeffrey Epstein, United States District Court, Southern District of Florida, Case No.: 08- CIY-80893-MARRA-JOMVSON. Although Epstein's counsel has not entered an appearance in this matter, as a courtesy to them, counsel for the victims' will provide a copy of this pleading at the address indicated in the related civil suit. CONCLUSION The non-prosecution agreement should be unsealed. DATED this 25th day of September 2008. Respectfully Submitted, THE LAW OFFICE OF BRAD EDWARDS & ASSOCIATES, LLC By: s/ Brad Edwards Brad Edwards, Esquire Attorney for Petitioners Florida Bar No. 542075 2028 Harrison Street Suite 202 Hollywood, Florida 33020 Telephone: Facsimile: E-Mail: 6 EFTA00231196 Case 9:08-cv-80736-KAM Document 28 Entered on FLSD Docket 09/25/2008 Page 7 of 8 Paul G. Cassell Attorney for Petitioners Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: Facsimile: E-Mail: Jay C. Howell, Esquire Attorney for Petitioners Pro Hac Vice 644 Cesery Boulevard Suite 250 Jacksonville, Florida 32211 Telephone: Facsimile: E-Mail: CERTIFICATE OF SERVICE I HEREBY CERTIFY that on September 25, 2008, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. SERVICE LIST Jane Doe 1 and Jane Doe 2 Case No.: 08-80736-CIV-MARRA/JOHNSON United States District Cowl, Southern District of Florida =ME Assistant U.S. Attorney 99 N.E. 4th Street Miami, Florida 33132 Telephone: Facsimile: 7 EFTA00231197 Case 9:08-cv-80736-KAM Document 28 Entered on FLSD Docket 09/25/2008 Page 8 of 8 AUSA United States Attorneys Office 500 South Australian Avenue West Palm Beach, Florida 33401 s/ Brad Edwards Brad Edwards, Esquire Attorney for Petitioner Florida Bar No. 542075 I HEREBY FURTHER CERTIFY that on September 25, 2008, a true and correct copy of the above and foregoing document is being provided by United States mail to: Jack Alan Goldberger, Esquire Atterbtuty, Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 W Beech Florida 33401 Michael R. Tein, Esquire Lewis Tein, P.L. 3059 Grand Avenue Suite 340 Coconut Grove. Florida 33133 Robert D. Critton, Jr., Esquire Michael J. Pike, Esquire Burman, Critton, Luttier & Coleman, LLP 515 North Flagler Drive West Palm Beac Florida 33401 s/ Brad Edwards Brad Edwards, Esquire Attorney for Petitioner Florida Bar No. 542075 8 EFTA00231198 Case 9:08-cv-80736-KAM Document 28-2 Entered on FLSD Docket 09/25/2008 Page 1 of 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80736-CIV-MARRAZIOHNSON JANE DOE #1 AND JANE DOE #2, Petitioners, v. UNITED STATES OF AMERICA, Respondent ORDER TO UNSEAL NON-PROSECUTION AGREEMENT THIS CAUSE comes before the Court on the Petitioners' Motion to Unseal Non￾Prosecution Agreement between the United States Attorneys Office for the Southern District of Florida and Jeffrey Epstein. After consideration of the Motion and the record, it is ORDERED AND ADJUDGED that the Petitioners' Motion is GRANTED and the Non￾Prosecution Agreement between the United States Attorneys Office for the Southern District of Florida and Jeffrey Epstein is hereby ordered to be unsealed. DONE AND ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida, this day of , 2008. KENNETH A. MARRA UNITED STATES DISTRICT COURT Copies furnished to: all counsel of record EFTA00231199 RECYCLED PAPER TO REORDER CALL 954446-9399 EFTA00231200 Case 9:08-cv-80736-KAM Document 29 Entered on FLSD Docket 10/08/2008 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Mana/Jolinson JANE DOES #1 and #2 Petitioners, v. UNITED STATES OF AMERICA, Respondent. RESPONDENT'S OPPOSITION TO VICTIMS' MOTION TO UNSEAL NON-PROSECUTION AGREEMENT Respondent, by and through its undersigned counsel, files its Opposition to Victims' Motion to Unseal Non-Prosecution Agreement, and states: I. THE MOTION TO UNSEAL SHOULD BE DENIED BECAUSE THE NON-PROSECUTION AGREEMENT HAS NEVER BEEN FILED UNDER SEAL IN THIS COURT. Petitioners have filed their motion to unseal the non-prosecution agreement, claiming that no good cause exists for sealing it. As an initial matter, the motion should be denied because the non-prosecution agreement entered into between the United States Attorney's Office and Jeffrey Epstein was never filed in the instant case by the United Slates, eitherunderseal or otherwiseOrr August 14, 2008, this Court held a telephonic hearing to discuss petitioners' request for a copy of the non-prosecution agreement. The United States advised the Court that the Agreement had a confidentiality provision, EFTA00231201 Case 9:08-cv-80736-KAM Document 29 Entered on FLSD Docket 10/08/2008 Page 2 of 7 which the United States was obligated to honor. The United States requested that, if the Agreement was to be produced to petitioners, it should be done pursuant to a protective order, to ensure that further dissemination of the Agreement would not occur. At that time, petitioners had no objection to such a procedure. On August 21, 2008, this Court entered its Order to Compel Production and Protective Order (DE 26). Subpart (b) of the Order provides that, "Petitioners and their attorneys shall not disclose the Agreement or its terms to any third party absent further court order, following notice to and an opportunity for Epstein's counsel to be heard." (DE 26 at 1.) Presumably, petitioners' motion to unseal is an effort to modify the terms of the Protective Order, to enable them to disclose the Agreement to third parties. Since the Agreement has not been filed under seal with this Court, the legal authority cited by petitioners regarding sealing of documents, United States'. Ochoa￾Vasque 428 F.3d 1015 (11th Cir. 2005), is inapposite. The parties who negotiated the Agreement, the United States Attorney's Office and Jeffrey Epstein, determined that the Agreement should remain confidential. They were free to do,, and violated no law in making such an agreement. Since the Agreement has become relevant to the instant lawsuit, petitioners have been given access to it, upon the condition that it not be disclosed further} Petitioners have no legal right to disclose the Agreement to third parties, or standing to challenge the confidentiality provision. `It is unclear whether the Petitioners themselves (as opposed to their attorneys) have actually reviewed the Non-Prosecution Agreement. The Court's Order to Compel Production required petitioners' counsel to review and agree to the Protective Order and to do the same with 2 EFTA00231202 Case 9:08-cv-80736-KAM Document 29 Entered on FLSD Docket 10/08/2008 Page 3 of 7 In order to have standing, petitioners must show: (1) an injury in fact, meaning an injury that is concrete and particularized, and actual or imminent (2) a causal connection between the injury and the causal conduct; and (3) a likelihood that the injury will be redressed by a favorable decision. Granite State Outdoor Advertising. Inc. v. City of Clearwater, Fla., 351 F.3d 1112, 1116 (11th Cir. 2003). Petitioners already have obtained access to the agreement,, they cannot claim a denial of access as an injury in fact. Their motion to unseal refers to their stated desire to confer with other victims of Epstein and their attorneys "to determine whether they were likewise provided with inaccurate information about the nature of the plea agreement." WE 28 at 5.) This asserted reason for needing to unseal the Agreement is baseless given that the Protective Order, at the Court's direction, specifically provides for a very simple procedure to allow other victims and their lawyers to see the Agreement. (See DE 26 at 1-2, subpart (d).) MI that is required is for any victims and/or their attorneys to review and agree to the terms of the Protective Order, and to provide the signed acknowledgment of that agreement to the United States. Petitioners' claim that they wish to discuss with others the "possible legal responses" to the Government, including the National Alliance of Victims' Rights Attorneys, also provides no basis for vacatur of the Protective Order. Petitioners contend that the "sealing order would apparently block these forms of consultation . . ." (DE 28 at their clients. Copies of those signed acknowledgements to abide by the Protective Order were then to be provided "promptly" to the United States. To date, only Attorney Brad Edwards has provided a signed acknowledgement. 3 EFTA00231203 Case 9:08-cv-80736-KAM Document 29 Entered on FLSD Docket 10/08/2008 Page 4 of 7 5.) First, there is no sealing order. Second, the Protective Order does not prevent petitioners from consulting with anyone; it only prevents them from disclosing the Agreement. Petitioners fail to mention why it is necessary for the National Alliance of Victims' Rights Attorneys to have the Agreement in hand, in order to meaningfully consult with them. Petitioners also assert that they would like to be able to reference the Agreement "in a parallel civil suit that is pending before this Court." (DE 28 at 5.) Given that the suit names Jeffrey Epstein as a defendant and is pending before the same district judge, it seems that litigation regarding the production and use of the Agreement should occur in that case, where the true party in interest, Jeffrey Epstein, is present and represented by counsel, rather than in a suit that was originally filed in July as an "Emergency Petition" under the various victims' rights laws. IL THE GOVERNMENT ACCURATELY DESCRIBED THE PROVISIONS OF THE AGREEMENT, AT THE TIME THE RESPONSES WERE FILED WITH THE COURT. Petitioners castigate the Government for inaccurately describing the non￾prosecution agreement. (DE 28 at 2-5.) They contend a particular provision cited by the Government does not appear in the copy of the Agreement produced to them. During the telephonic hearing on August 14, 2008, Government counsel advised the Court and petitioners' counsel that there was an ongoing dispute between the Government-and p o eys over what-cons d the Agreement. Government counsel advised that, in its opinion, the Agreement had three parts. The first part was 4 EFTA00231204 Case 9:08-cv-80736-KAM Document 29 Entered on FLSD Docket 10/08/2008 Page 5 of 7 executed in September 2007, the second part, an addendum, was executed in October 2007, and the third part was a December 2007 letter from the United States Attorney to Epstein's attorneys, suggesting a further modification of the Agreement. The Government advised the Court that it believed that all three parts comprised the Agreement, while it appeared that Epstein's attorneys were contending the Agreement was comprised only of parts one and two. At the commencement of the instant litigation, in July 2008, the Government believed the Agreement was comprised of all three parts mentioned above. This belief was expressed in victim notification letters, including one sent to Jane Doe #1,2 the Government's July 9, 2008 response to the Emergency Petition for Enforcement of Victims Rights Act, as well as the Declaration of Assistant U.S. Attorney, which accompanied the Government's response. This belief continued until August 2008, when the Government advised Epstein's attorneys that the victims had 2The victim notification letter was provided to Epstein's attorneys prior to being sent, who approved the language of which the petitioners now complain. Thus, petitioners' repeated assertions that the Government made these errors intentionally and/or negligently are meritless. (See, e.a., DE 28 at 4-5 ("The Government apparently feels free to disclose to the victims one provision in the non-prosecution agreement that it believes it is to its advantage to disclose, but not others. The Government should not be permitted to pick and choose, particularly where it has inaccurately described the provision that it has chosen to disclose.") The Government seeks no "advantage" in this suit brought by the two victims. Furthermore, the petitioners' original emergency petition focused on their concern about the amount of jail time that Epstein would serve. The provision that they complain of now has no relation to jail time. Furthermore, petitioners aver that the October 2007 disclosure to Jane Doe #1 contained inaccurate information, but that disclosure was made before the December 2007 letter and, therefore, did not include anything related to the U.S. Attorney's now-defunct proposed amendment to the Agreement. 5 EFTA00231205 Case 9:08-cv-80736-KAM Document 29 Entered on FLSD Docket 10/08/2008 Page 6 of 7 demanded disclosure of the Agreement to them, and discussions ensued about what constituted the Agreement. Epstein's attorneys then told the Government that Epstein believed the Agreement consisted only of the first and second parts. These were the parts disclosed to petitioners pursuant to the Protective Order in compliance with the Court's order to compel production. The fact that an erroneous disclosure was inadvertently made to one petitioner after Epstein had already entered his guilty plea, was sentenced, and surrendered to begin serving his sentence does not create an injury where one did not exist before. CONCLUSION For the foregoing reasons, the United States respectfully requests that the Court deny Petitioners' Motion to Unseal the Non-Prosecution Agreement. Respectffilly submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: 6 Assistant U.S. Attorney Fla. Bar No. 0936693 99 N.E. 4th Street 33132 Fax: E-mail: Attorney for Respondent EFTA00231206 RECYCLED PAPER 7O REORDER CALL 954406-9399 EFTA00231207 Case 9:08-cv-80736-KAM Document 30 Entered on FLSD Docket 10/16/2008 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80736-CIV-MARRA/JOHNSON JANE DOE 41 AND JANE DOE #2, Petitioners, v. UNITED STATES OF AMERICA, Respondent. VICTIMS' REPLY TO RESPONDENT'S OPPOSITION TO VICTIMS' MOTION TO UNSEAL NON-PROSECUTION AGREEMENT COME NOW the Petitioners, Jane Doe #1 and Jane Doe #2 ("the victims"), by and through undersigned counsel, and reply to the Government's Opposition to Victims' Motion to Unseal Non-Prosecution Agreement. The victims have moved for a lifting of the protective order barring them front publicly disclosing or discussing the terms of the non-prosecution agreement between Jeffrey Epstein and the United States Government. Jeffrey Epstein has made no response to this motion. The Government, however, contends that the victims' motion should be denied because the victims cannot show any injury from the protective order. The Government's position is wrong for three reasons. First, the Government bears the burden of showing some good cause for a protective order. It has utterly failed to even offer any such cause — much less show that it is good cause. Second, the Government — with the apparent contrivance of Jeffrey Epstein's attorneys — has _made inacrAirate representations about the nature of the non-prosecution agreement in itrnotices to the victims and in its filing before the Court. To set the record straight, therefore, the victims EFTA00231208 Case 9:08-cv-80736-KAM Document 30 Entered on FLED Docket 10/16/2008 Page 2 of 6 should be allowed to publicly discuss the agreement. Finally, the victims are burdened by provisions in the protective order. For all these reasons, the protective order should be lifted. I. No Good Cause Has been Shown for Sealing the Agreement. In their motion to unseal the agreement, the victims argued that there was no good reason for the protective order requiring them not to further disseminate the agreement. Curiously, the Government's response does not offer any substantive reason for the agreement to remain under seal or under a protective order.' Instead, the Government contends that victims have "no legal right to disclose the Agreement to third parties, or standing to challenge the confidentiality provision." Gov't Response at 2. But this argument has things backwards. It is not the victims' task to show some reason for not entering a protective order, rather, it is the Government's task. to show some affirmative reason for entering the order in the first place. See Fed. R. Civ. P. 26(c) (allowing for entry of a protective order upon motion for a party "for good cause shown'); see also In re Alexander Grant & Co. Litigation, 820 F.2d 352, 356 (11th Cir. 1987) ("good cause" for a protective order "generally signifies a sound basis or legitimate need to take judicial action"). Having been given the opportunity to explain why the document has to remain confidential, the Government chose not to do B And Jeffrey Epstein was served with the victims' motion, but chose not to respond. Presumably this was because Jeffrey Epstein had no real interest at stake in the confidentiality of the agreement. Therefore, the protective order should be lifted because it lacks any articulated justification — much less any justification that constitutes good cause. ' The Government prefers to view the Issues in this case as involving not the sealing of a document but rather the entry of a protective order preventing the disclosure of a document. To simplify the dispute in this case, we will proceed on the Government's view of the situation. EFTA00231209 Case 9:08-cv-80736-KAM Document 30 Entered on FLSD Docket 10/16/2008 Page 3 of 6 2. The Government. With the Apparent Aid of Epstein, Has Provided Inaccurate Information to the Victims (and to the Court). The victims also asked that the protective order be lifted to help clarify the record in this case. The Government has made public representations in its pleadings in this case about the civil remedy provision in the non-prosecution agreement. It also specifically sent notices to Jane Doe #1 and other victims of Jeffrey Epstein's crimes describing this provision in the agreement Those representations were inaccurate — as the Government now seemingly admits. See Gov't Response at 6 (referring to "erroneous disclosure" that was "inadvertently made" to Jane Doe #1). Indeed, the Government now takes the position that the responsibility for those inaccurate representations to the victim — as well as to the Court — lies with Jeffrey Epstein's attorneys'. See Gov't Response at 5 ("the [inaccurate] victim notification letter was provided to Epstein's attorneys prior to being sent, who approved the language of which the petitioners now complain.'). The apparent approval by Jeffrey Epstein's attorneys of inaccurate information being sent to crime victims (and possibly their approval of inaccurate information being provided, as a result, to the Court) raises very significant issues under the Crime Victim's Rights Act The victims have, therefore, sent a letter to the U.S. Attorney's Office requesting clarification of exactly how Jeffrey Epstein's attorneys participated in misleading the victims. See Attachment 1 (Oct. 9, 2008, Letter from Brad Edwards, Esq. to AUSA =M). Indeed, it appears that the Government may have provided an inaccurate description of another feature of the non￾prosecution agreement to the victims. See Attachment 2 (Oct 15, 2008 Letter from Brad Edwards, Esq, to AUSA (noting Goverament-s ' representeflon to victims of atight to recover at least $150,000 in damages from Jeffrey Epstein while Jeffrey Epstein's lawyers take the position that the agreement allows automatic recovery of only $50,000). In light of all these 1 it EFTA00231210 Case 9:08-cv-80736-KAM Document 30 Entered on FLSD Docket 10/16/2008 Page 4 of 6 apparent misrepresentations about precisely what the non-prosecution agreement entails, the victims should not be bound by a protective order barring their public disclosure of the agreement 3. The Protective Order Unfairly Burdens the Victims. In their motion, the victims also explained how the protective order burdened their efforts to confer with other victims' rights attorneys regarding how best to proceed in light of the non￾prosecution agreement. The Government does not seriously contest the victims' representations about the burdens imposed by the protective order. Instead, it takes the truly remarkable position that "the Protective Order does not prevent [the victims] from consulting with anyone; it only prevents them from disclosing the Agreement" Gov't Response at 4. But the whole point of the victims' motion was that the protective order places burdens on the victims in consulting with other attorneys about the agreement. Obviously, it is of no help to the victims to be able to consult with other attorneys on that issue if the agreement itself cannot be disclosed. CONCLUSION The provision in the protective order barring the victims and their attorneys from publicly disclosing the non-prosecution agreement should be lifted. DATED this 15.1 day of October 2008. Respectfully Submitted, THE LAW OFFICE OF BRAD EDWARDS & ASSOCIATES, LLC By: s/ Brad Edwards Brad Edwards, Esquire Attorney for Petitioners _Florida Bar No, 542075- 2028 Harrison Street • Suite 202 Hollywood, Florida 3 Telephone: E-Mail: EFTA00231211 1 Case 9:08-cv-80736-KAM Document 30 Entered on FLSD Docket 10/16/2008 Page 5 of 6 is Paul G. Cassell Attorney for Petitioners Pro Hac Vice 332 S. 1400 E. Salt Lake City 84112 Telephone: Facsimile: E-Mail: Jay C. Howell, Esquire Attorney for Petitioners Pro Hac Vice 644 Cesery Boulevard - Suite 250 Jacksonville, F orida 221 Telephone: Facsimile: E-Mail: CERTIFICATE OF SERVICFa I HEREBY CERTIFY that on October 16.200$, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. SERVICE LIST Jane Doe 1 and Jane Doe 2 Case No.: 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Assistant U.S. Attorney 99 N.E. 4th Street Miami, Florida Telephone: Facsimile: AUSA United States Attorney's Office 500 Australian Avenue West Palm Beach, Florida 33401 s/ Brad Edwards Brad Edwards, Esquire Attorney for Petitioner Florida Bar No. 542075 I; ! F is EFTA00231212 Case 9:08-cv-80736-KAM Document 30 Entered on FLSD Docket 10/16/2008 Page 6 of 6 I HEREBY FURTHER CERTIFY that on October 6. 2008, a true and correct copy of the above and foregoing document is being provided by United States mail to: Jack Alan Goldberger, Esquire Atterburty, Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 Florida 33401 Michael R. Tein, Esquire Lewis Tein, P.L. 3059 Grand Avenue Suite 340 33133 Robert D. Critton, Jr., Esquire Michael J. Pike, Esquire Burman, Critton, Luttier & Coleman, LLP 515 Flagler Drive West Palm Beach, Florida 33401 s/ Brad Edwards Brad Edwards, Esquire Attorney for Petitioner Florida Bar No. 542075 EFTA00231213 LEGAL ii•OPIONItileliff otoogenmeleo.••• RECYCLED PAPER II) REORDER CU I ',544i16,399 EFTA00231214 Case 9:08-cv-80736-KAM Document 36 Entered on FLSD Docket 02/12/2009 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA NO. 08-80736-CV-MARRA/JOHNSON JANE DOES #1 AND #2, Petitioners, v. UNITED STATES OF AMERICA, Respondent. ORDER THIS CAUSE comes before the Court on the Petitioners' Motion to Unseal Non-Prosecution Agreement (DE 28), filed September 25, 2008. Respondent filed its response (DE 29), on October 8, 2008, and Petitioners filed their reply (DE 30) on October 16, 2008. The Court has carefully considered the motion and the record and is otherwise fully advised in the premises. Petitioners motion seeks the Court to enter an order unsealing the Non-prosecution Agreement, including any modifications and addenda thereto (collectively referred to as the "Agreement"), between the United States Attorney's Office for the Southern District of Florida ("USAO") and Jeffrey Epstein ("Epstein'). At a hearing held on August 14, 2008, the Court ordered the USAO to produce the Agreement to counsel for the Petitioners and to any other victims identified by the USAO and their counsel, pursuant to the terms of the Court's Order. (See DE 26, August 21, 2008). Petitioners argue that the Agreement "should now be unsealed." First, as-Respondent points ""t, IL Agreement was not filed irr this-case, under al or otherwise. Petitioners also assert that the Agreement should be "unsealed" because the victims EFTA00231215 Case 9:08-cv-80736-KAM Document 36 Entered on FLSD Docket 02/12/2009 Page 2 of 2 and/or their attorneys believe the Government has mischaracterized some of its provisions. If and when such alleged mischaracterizations become relevant to an issue to be decided by the Court, the parties will be given the opportunity to advance their positions and the Court will resolve the issue. If disclosure of the Agreement will be required for the Court to resolve the issue, appropriate disclosure will be ordered. Furthermore, to the extent Petitioners are seeking modification of the restrictions placed upon their use of the Agreement by the Court's August 21,2008 order, Petitioners have not met their burden to justify a modification. Petitioners' mere desire to discuss the Agreement with third parties is insufficient, in and of itself, to warrant the granting of such relief. If and when Petitioners have a specific tangible need to be relieved of the restrictions, they should file an appropriate motion. If a specific tangible need arises in a civil case Petitioners or other alleged victims are pursuing against Epstein, relief should be sought in that case, with notice to the United States, the other party to the Agreement. Accordingly, it is ORDERED AND ADJUDGED that Petitioners' Motion to Unseal Non-Prosecution Agreement (DE 28) is DENIED. DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida, this 12th day of February, 2008. KENNETH A. MARRA UNITED STATES DISTRICT JUDGE Copies furnished to: all counsel of record 2 EFTA00231216 7 EFTA00231217 3. 2 3 4 5 6 7 8 9 IN THE CIRCUIT COURT OF THE _FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CRIMINAL DIVISION STATE OF FLORIDA vs JEFFREY EPSTEIN . Defendant. CASE NO. 06 CF9454AMB 08 9381CFAMB PLEA CONFERENCE 10 11 PRESIDING: HONORABLE DEBORAH DALE PUCILLO 12 APPEARANCES: 13 ON BEHALF OF THE STATE: BARRY E. KRISCHER, ESQUIRE 14 State Attorney 401 North Dixie Highway 15 West Palm Beach, Florida 33401 By: LANNA BELOHLAVEK, ESQUIRE 16 Assistant State Attorney 17 ON BEHALF OF THE DEFENDANT: ATTERBURY, GOLDBERGER & WEISS,P.A. 18 250 Australian Avenue South Suite 1400 19 West Palm Beach, Florida 33401 By: JACK GOLDBERGER, ESQUIRE CERTIFIED COPY 20 21 22 23 June 30, 2008 24 Palm Beach County Courthouse West Palm Beach, Florida 33401 25 Beginning at 8:40 o'clock, a.m. PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231218 2 1 BE IT REMEMBERED that the following 2 proceedings were had in the above-entitled cause _ 3 before the HONORABLE DEBORAH DALE PUCILLO, one of 4 the judges of the aforesaid court, at the Palm 5 Beach County Courthouse, located in the City of 6 West Palm Beach, State of Florida on June 20, 2008 7 beginning at 8:40 o'clock, a.m. with appearances 8 as hereinbefore noted, to wit: 9 THEREUPON: 10 MR. GOLDBERGER: Good morning, Judge, 11 Jack Goldberger on behalf of Jeffrey 12 Epstein. 13 THE COURT: Good morning. 14 MR. GOLDBERGER: Your Honor, we are 15 here for a plea conference. 16 THE COURT: Raise your right hand. 17 THEREUPON: 18 JEFFREY EPSTEIN, 19 after being called as a witness by the Defense and 20 after being first duly sworn by the Court, was 21 examined and testified as follows: 22 THE DEFENDANT: Yes, ma'am. 23 THE COURT: Is this one case or two? 24 MS. BELOHLAVEK: Two. 25 THE COURT: May I see the PC PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231219 3 4 1 affidavit in both cases, please? 2 3 4 5 MS. BELOHLAVEK: There are no PC affidavits. There was originally an Indictment, the second charge was filed arising out of the booking. It was all 6 testimony presented to the grand jury. 7 THE COURT: Let me see the Indictment 8 then? 9 10 11 12' 13 14 • 15 16 I have one Indictment, one Information? MS. BELOHLAVEK: Correct. THE COURT: II one case is charged by Indictment, one is charged by Information? MS. BELOHLAVEK: Correct. THE COURT: In case 2006036744 you are charged with procuring a person under 17 18 for prostitution, a second degree 18 felony, maximum penalty of fifteen years 19 Department of Corrections; minimum, some 20 period of probation. No mandatory minimum 21 apply, is that correct, State? 22 MS. BELOHLAVEK: Correct. 23 THE COURT: And in case number 06 24 9454CF, you are charged with felony 25 solicitation to prostitution, a third PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231220 4 1 degree felony, punishable by a maximum 2 penalty of five years in the Department of 3 Corrections, and a minimum, probation. No 4 mandatory minimums, correct? 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 MS. BELOHLAVEK: Correct. THE COURT: The defendant has no prior criminal record? MS. BELOHLAVEK: Correct. MR. GOLDBERGER: Yes, Your Honor. THE COURT: You checked the NCIC as well as State records? MS. BELOHLAVEK: Yes. THE COURT: And the guideline score sheet I have before me shows 21.5 months in the Department of Corrections as the lowest permissible prison sentence in months. Both sides agree to the preparation of the guideline score sheet? MR. GOLDBERGER: We II agree, Your 20 Honor. 21 MS. BELOHLAVEK: Yes. 22 THE COURT: What is proposed -- it 23 goes on for pages. 24 MR. GOLDBERGER: Your Honor, much of 25 the documentation is acknowledgement by my PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231221 4 5 1 client to community control, sex offender 2 status. 3 THE COURT: I understand. 4 Okay. What is proposed -- those • 5 are the maximums and minimums, Mr. Epstein. 6 What is proposed is that you will be 7 pleading guilty to felony solicitation to 8 prostitution and procuring a person under 9 18 for prosecution. A PSI would be waived, 10 you would be adjudicated guilty of both 11 felonies, is that correct? 12 MS. BELOHLAVEK: Correct. 13 THE COURT: And on 06 9454, the 14 defendant to be sentenced to 12-months in 15 the Palm Beach County -- detention 16 facility? He's going to do time in the 17 jail? 18 MS. BELOHLAVEK: Yes. 19 THE COURT: With credit for one day 20 served. And on 08 9381, he is to be 21 sentenced to six months in the Palm Beach 22 County jail detention facility, with credit 23 for one day served. And the six month 24 sentence is to be served consecutive to the 25 12 month sentence? PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231222 4 6 1 MS. BELOHLAVEK: Correct.. 2 THE COURT: falowng tie six months 3 sentence, the defendant will be placed on 4 12-months of community control one. The 5 6 7 8 conditions of the community control are attached hereto and incorporated herein. As a special condition of community control, he's to have no 9 unsupervised contact with minors and the 10 supervising adult must be approved -- and I 13. 12 13 14 15 16 would say, pre-approved, approved ahead of time, not after the fact by the Department of Corrections. And you would mean by that his community control officer? MS. BELOHLAVEK: Correct. THE COURT: The defendant is 17 designated as a sexual offender pursuant to 18 Florida Statute 943.0435. and must abide by 19 all the corresponding requirements of the 20 statute, a copy of which in attached hereto 21 and incorporated herein. The defendant 22 must provide a DNA sample in court at the 23 time of this plea. Is this the -- and the 24 attachments are the terms and conditions of 25 community control. There are some PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231223 7 1 squiggles on the bottom of the page, what 3 4 5 6 7 would those squiggles be? MR. GOLDBERGER: Thank you, Your Honor, those are my client's signature acknowledging that we have gone over all the conditions. THE COURT: One page after the plea 8 sheet that really spells out the terms and 9 conditions of community control, Florida 10 Statute 948.101, Mr. Epstein, is that 11 squiggle at the bottom your squiggle? 12 THE DEFENDANT: Yes, ma'am. 13 THE. COURT: Would those be your 14 initials? 15 THE DEFENDANT: Yes, ma'am. 16 THE COURT: Did you read all of that 17 page? 18 THE DEFENDANT: Yes, ma'am. 19 THE COURT: Can you read? 20 THE DEFENDANT: Yes, ma'am. 21 THE COURT: How far did you go in 22 school? 23 THE DEFENDANT: High school. 24 THE COURT: That's your highest 25 degree? PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231224 8 1 THE DEFENDANT: Yes. 2 THE COURT: And is this your 3 signature on the plea sheet that recites 4 the terms of the plea I just read? THE DEFENDANT: Yes, ma'am. 6 THE COURT: Did you read that 7 document as well? 8 THE DEFENDANT: Yes, ma'am. 9 THE COURT: You understand once you 10 do your 12 months followed by your six 11 months all in the Palm Beach County jail 12 you will then be put on community control 13 which involves having an electronic monitor 14 attached to you and -- 15 MR. GOLDBERGER: Actually Your Honor, 16 the agreement of the parties is to, it!s 17 community control one which is not monitor. 18 THE COURT: Oh, community control 19 one, is that spelled out in here? 20 MS. BELOHLAVEK: Yes. 21 MR. GOLDBERGER: Yes, it is, Your 22 Honor. 23 MS. BELOHLAVEK: He does not fall 24 under the Jessica Lunsford Act which 25 requires the bracelet. PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231225 9 1 THE COURT: Community control two. / ) 2 MS. BELOHLAVEK: Correct. 3 THE COURT: Community control one -- 4 that would be no electronic monitor? 5 6 7 8 9 10 11 12 13 14 15 16 MR. GOLDBERGER: That is correct. THE COURT: Now which of the terms and conditions of community control one are you incorporating? MR. GOLDBERGER: I can go through them with Your Honor. THE COURT: None of the them appear to be articulated in the plea sheet which is why I'm asking. MR. GOLDBERGER: These are the standard conditions of community control by statute would apply to anyone that goes on 17 community control and out of an abundance 18 of caution, we simply memorialized those 19 standard conditions in the plea sheet 20 agreement. 21 THE COURT: The Court shall require 22 intensive supervision and surveillance for 23 an offender placed on community control 24 which may include but is not limited to 25 specified contact with the parole and PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231226 10 1 probation officer, specified by who? 2 P-R-agicTIUN— OFF=EIC -SI:WcifiCd—by you, 3 4 5 Your Honor. THE COURT: I don't see that in the plea sheet. That's why I'm asking the 6 questions. No one has specified how often, 7 8 9 how frequently he is to have contact with his parole and probation officer. Confinement to an agreed upon residence 10 during the hours away from employment and 11 12 13 14 15 16 17 18 . 19 public service activity, has that been articulated? MS. BELOHLAVEK: I believe Judge McSorley has a standard order somewhere on the bench up there regarding this, I'm told by the prosecutor. MS. LENHARDT: Judge, usually this is the probation sheet she hands out to folks. THE COURT: I have seen those 20 sheets -- I have seen them incorporated in 21 plea agreements which is why I'm asking. 22 MR. GOLDBERGER: I see. 23 THE COURT: Is there some reason you 24 didn't use this particular document in this 25 case? PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231227 11 1 MS. BELOHLAVEK: I didn't realize 2 3 4 5 until Ms. Lenhardt just told me that Judge McSorley has that. MR. GOLDBERGER: We'd be happy to execute that document, Your Honor. We were 6 -- we overreacted by just having him sign 7 off on all conditions of community control. 8 THE COURT: Well, this is -- 9 MR.. GOLDBERGER: Perhaps the better 10 practice would be -- 11 THE COURT: This is, the reason Judge McSorley does this which makes ultimate sense is we're going to be here half the morning if we're going to decide among ourselves now what the -- MR. GOLDBERGER: That makes sense. 17 THE COURT: I'm not going to leave 18 this just unspecified. 19 MS. BELOHLAVEK: We can take care of 20 that right now if you could give us a few 12 13 14 15 16 21 minutes. 22 THE COURT: All right. 23 These are the standard conditions 24 that Judge McSorley normally uses. If you 25 like them, you need to circle the ones that PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231228 12 1 apply and everyone must initial them. We 2 will go over it. If you wish to change 3 you understand there is quite a bit of 4 latitude given the court in putting 5 somebody on community control. If you 6 agree to some change, let me know, but 7 understand at the outset that I'm a big fan 8 of specificity. I want to know what he 9 will be doing for employment. I want to 10 know exactly where he is going to be living 11 and I want it on the record now. It can 12 change but it can only change with 13 preapproval by DOC. I want it crystal 14 clear. I don't want the community control 15 officer who gets this case the day he walks 16 out the Palm Beach County to have any doubt 17 or confusion as to exactly what this 18 defendant is supposed to do, where he is 19 supposed to be when, exactly what I am 20 requesting that officer to supervise. 21 MS. BELOHLAVEK: Absolutely. 22 THE COURT: Okay. 23 MR. GOLDBERGER: We will work on it. 24 Thank you, Your Honor. 25 THE COURT: We will recall that case. PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231229 13 1 (Brief recess.) 2 MR. GOLDBERGER: Your Honor, we are 3 4 5 6 7 8 9 10 11 12 13 back on Jeffrey Epstein, actually it worked, we had an opportunity to go through Judge McSorley's conditions of community control and we asked the Department of Corrections representative to assist us to make sure we did everything properly. They were very helpful and we executed the document. MS. BELOHLAVEK: Yes, and Your Honor, this defendant doesn't fall under the sex offender probation but we have included 14 special sex offender conditions as part of 15 the community control and they are all 16 circled there. 17 . THE COURT: The plea agreement stated 18 the defendant is designated as a sexual 19 offender pursuant to Florida Statute 20 942.035. 21 MS. BELOHLAVEK: Correct. But the 22 sex offender probation, the statute is . 23 different and only applies to certain 24 offenses and this one was not enumerated. 25 THE COURT: Okay. I want to make PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231230 14 1 sure both I and the defendant are clear. 2 3 4 5 6 7 The sexual offender statute you are referring to in the plea sheet is the one that requires registration? MS. BELOHLAVEK: Correct. MR. GOLDBERGER: Correct. THE COURT: And we will talk about 8 that. 9 MR. GOLDBERGER: Okay. 10 THE COURT: But it is not the one 11 that requires the special conditions of sex 12 offender probation? 13 MS. BELOHLAVEK: Correct'. 14 THE COURT: Now, rather than 948, do 15 you want me to disregard 948? He's read 16 it? 17 MS. BELOHLAVEK: He's read it. 18 THE COURT: We will leave it in 19 there. But these conditions we are going 20 to go over right now are going to be viewed 21 in my mind, yes, and they have been signed 22 by the defendant and we will go over that 23 in a second as a part of the whole plea. 24 MS. BELOHLAVEK: Correct. 25 THE COURT: II circled are PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231231 15 1 conditions, A, you will remain confined to 2 your residence except one half hour before 3 and after your approved employment, 0 4 5 6 community service work or any other activity approved by your probation officer. 7 B, you will maintain an hourly 8 accounting of all your activities on a 9 10 . 11 12 13 daily log which you will submit to your supervising officer upon request. My understanding about the daily log, maybe I'm just confused from other cases I've heard, is the daily log is a 14 weekly log, I guess it is submitted ahead 15 of time, is that correct? 16 PROBATION, OFFICER: That is correct, 17 Your Honor. 18 THE COURT: part A, where he has 19 to stay in his residence except for one 20 hour before and after the approved 21 employment, community service work and 22 other activity. All that's information 23 that will be recorded in wil-ang and-the 24 defendant will have a copy and he will know 25 exactly where he is supposed to be when. PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231232 16 PROBATION OFFICER: That is correct, 2 Your Honor. 3 THE COURT: As will his supervising 4 probation officer. And.then to document that he's supposedly done all that he 6 himself will be keeping a daily log? 7 PROBATION OFFICER: That is correct, 8 Your Honor. 9 THE COURT: And the log form will be 10 provided by the department and he will be 11 turning that in every time he meets with 12 the probation officer? 13 PROBATION OFFICER: That is correct, 14 Your Honor. 15 THE COURT: Okay. Illthat applies 16 and F applies. Does E apply? No. 17 MS. BELOHLAVEK: Did I circle ET 18 THE COURT: No. F -- made one up, 19 the defendant will be residing at 358 El 20 Brillo Way, Palm Beach, Florida, 33480. He 21 knows now that that's where he will be 22 living when he is released after his 12 23 months and six months. 24 MR. GOLDBERGER: That is correct, 25 Your Honor. PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231233 17 1 THE COURT: That's a private 2 3 4 5 6 residence? MR. GOLDBERGER: That is his home. THE COURT: Does he own the residence? MR. GOLDBERGER: He does, Your Honor. 7 THE COURT: Is there any possibility 8 that he no longer owns the residence? 9 10 11 MR. GOLDBERGER: Not anticipated, Your Honor. THE COURT: Okay. Should he not be 12 for whatever reason -- 18-months is a long 13 time, should he not be owning that 14 residence or able to reside there, he will 15 have the obligation of notifying his 16 probation officer prior, and I emphasize 17 • this, prior to his release from custody. I 18 assume that the department will be notified 19 prior to, to his release? 20 PROBATION OFFICER: That is correct, 21 Your Honor. 22 THE COURT: And then you would need 23 to send someone to meet with him before he 24 walks out of the Palm Beach County jail and 25 verify his address and employment PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231234 18 1 information? 2 PROBATION OFFICER: That is correct. 3 THE COURT: All address -- I assume 4 all of this, to and from work and any other 5 approved activities restricts him to Palm 6 Beach County, is that correct? 7 PROBATION OFFICER: That is correct, 8 Your Honor. 9 THE COURT: II let's be clear, 10 everything, from the day he walks out 11 occurs in Palm Beach County, is that clear? 12 MR. GOLDBERGER: We understand, Your 13 Honor. That's correct. 14 THE COURT: Then the additional 15 condition of his probation, they are not 16 sex offender standard conditions, they are 17 just conditions that are being imposed 18 especially in this case? 19 MS. BELOHLAVEK: Correct. 20 THE COURT: They are as follows, you 21 shall submit to a mandatory curfew from 10 22 p.m. to 6:00 a.m. regardless of any other 23 restrictions regarding work or approved 24 activity, there will be no exceptions to 25 being at home in house from 10 p.m. to 6 1 PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231235 19 1 2 a.m., is that correct? MS. BELOHLAVEK: Yes. 7-7,1 3 THE COURT: If the victim was under 4 age of 18 years which I gather is the case because it's circled, you shall not live 6 within 1000 feet of a school, day care 7 center, park, playground or other place 8 where children regularly congregate. 9 Hai someone verified that 358 El 10 Brillo is such a place? 11 MS. BELOHLAVEK: No, but that will be 12 done prior to his release. 13 THE COURT: II 358 El Brillo will not 14 be approved if it should happen to be one 15 thousand feet from a school, day care 16 center, park, playground or other place 17 this is rather open. 18 MR. GOLDBERGER: Where children 19 gather. 20 THE COURT: Where children regularly 21 congregate. 22 MS. BELOHLAVEK: Right. 23 --TEE COURT: The Court knows 358 El 24 Brillo Way is a residential neighborhood, 25 are there areas there where children PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231236 4 1 regularly congregate? 20 2 MS. BELOHLAVEK: I personally do not 3 know. 4 THE COURT: Neither do I, which is 5 why I'm asking. Has that been 6 investigated? 7 MR. GOLDBERGER: We have done our due 8 diligence, for what it's worth, there is a 9 residential street. There are not children 10 congregating on that street. We think the 11 address applies, if it doesn't, we fully 12 recognize that he can't live there. 13 THE COURT: Okay. D is, you shall 14 not have any contact with the victim, are 15 there more than one victim? 16 MS. BELOHLAVEK: There's several. 17 THE COURT: Several, all of the 18 victims. II this should be plural. I'm 19 making that plural. You are not to have 20 any contact direct or indirect, and in this 21 day and age I find it necessary to go over 22 exactly what we mean by indirect. By 23 indirect, we mean no text messages, no 24 e-mail, no Face Book, no My Space, no 25 telephone calls, no voice mails, no PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231237 21 1 2 3 4 messages through carrier pigeon, no mews yetl through—third partl-e's7—no hey would you tell and for me, no having a friend, acquaintance or stranger approach 5 any of these victims with a message of any 6 sort from you, is that clear? 7 THE DEFENDANT: Yes, ma'am 8 9 10 11 12 THE COURT: And then it states, unless approved by the victim, the therapist and the sentencing court. Okay. THE DEFENDANT: I understand. THE COURT: And the sentencing court. 13 II, if there is a desire which, I would 14 think would be a bit strange. to have 15 contact with any of the victims the court 16 must approve it. 17 MS. BELOHLAVEK: Correct. 18 THE COURT: If the victim was under 19 the age of 18, which was the case, you 20 shall not until you have successfully 21 attended and completed the sex offender 22 program. II, is this sex offender program 23 becoming a condition of probation? 24 MS. BELOHLAVEK: That is not. I 25 don't believe I circled that one. PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231238 22 1 THE COURT: You did. 2 MR7—BULDBERGERT--Thrs a mi-Srt-ZOnr-Orl 3 our part. Actually the statute that he is 4 pleading guilty to does not require the 5 THE COURT: I understand that, but 6 you circled it. 7 MS. BELOHLAVEK: I apologize, that 8 one is not. He has already been in 9 treatment with a private psychiatrist. 10 THE COURT: Which you find to be an 11 adequate substitute for sex offender 12 program? 13 MS. BELOHLAVEK: I -- it is not 14 required and based upon the evaluation and 15 my contact with that doctor, I don't 16 believe it's necessary at this point. 17 THE COURT: Has that been -- I assume 18 .you have a law degree and do not have a 19 Ph.D in a psychology or II in psychiatry? 20 MS. BELOHLAVEK: That is correct, I 21 don't. 22 THE COURT: ■ it is just your 23 judgement -- 24 MS. BELOHLAVEK: Correct. 25 THE COURT: -- that his treatment PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231239 23 1 with some fancy private psychiatrist or 2- psychologist—in his—case—rs—ckey9 3 MS. BELOHLAVEK: That is correct. 4 THE COURT: II you are not imposing 5 E? 6 MS. BELOHLAVEK: Correct. 7 THE COURT: F, if the victim was 8 under the age of 18, you shall not work or 9 play or as a volunteer in any school, day 10 care center, park, play ground or other 11 12 place where children regularly congregate, is that understood? 13 THE DEFENDANT: Yes, ma'am. 14 THE COURT: Children will be defined 15 as anyone under the age of 18. There are a 16 lot of places where children regularly 17 congregate. What kind of.work do you do? 18 THE DEFENDANT: Banking. 19 THE COURT: Here in Palm Beach 20 County? 21 THE DEFENDANT: Virgin Islands, 22 ma'am. 23 THE COURT: You understand you will 24 not travel from Palm Beach County for the 25 duration of this? PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231240 24 1 THE DEFENDANT: Yes, ma'am. 2 MR. uritDahNvERT--Tiout—Hunur7—T- m 3 sorry to interrupt, we do cover the 4 employment later in the agreement as to 5 what he is going to be doing during the one 6 year that he is on community control. 7 THE COURT: Okay. And let me -- 8 condition G, which is circled, unless 9 otherwise indicated in the treatment plan 10 provided by sexual offender treatment 11 program. 12 MR. GOLDBERGER: That's not in there. 13 THE COURT: Is that what you want? 14 MS. BELOHLAVEK: No. 15 THE COURT: But you do want the, you 16 will not view, own or possess any obscene 17 pornographic -- 18 MS. BELOHLAVEK: Correct. 19 THE COURT: Okay. But are you saying 20 that this therapist can okay him to own 21 certain pornographic material? 22 MS. BELOHLAVEK: No, not at all. 23 MR. GOLDBERGER: No, Your Honor. 24 THE COURT: Would be really helpful 25 if people read these things before they PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231241 25 1 signed them thoroughly. 3 UffretW—D-Cherwise indicated in treatment plan. I'm just going to strike 4 out, provided by the sexual offender 5 treatment program. Is that what you 6 intend, that his therapist can 7 MS. BELOHLAVEK: No. 8 THE COURT: No? 9 MS. BELOHLAVEK: No. 10 THE COURT: Unless otherwise 11 indicated. 12 MR. GOLDBERGER: The parties have 13 agreed that during the period that he is -- c"--) 14 cannot be -- 15 THE COURT: Condition G will now 16 read, you shall not view, own, possess any 17 obscene, pornographic or sexually 18 stimulating visual or auditory material 19 including telephonic, electronic media, 20 computer program or computer services that 21 are relevant to your deviant behavior 22 pattern. And who is going to enforce that? 23 MS. BELOHLAVEK: The community 24 control officer. 25 THE COURT: How? PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231242 26 1 MS. BELOHLAVEK: They have the :1) 2 oBaliTion and ardarided-177fbere tor 3 warrantless search to check at any time his 4 home, his computer, anything he has contact 5 with. 6 THE COURT: And do they regularly do 7 that?. 8 9 10 11 12 PROBATION OFFICER: Yes, ma'am. THE COURT: Since we have the pleasure of having someone from the Department of Corrections here. Okay. H, you shall submit two 13 specimens of blood to the Florida 14 Department of Law Enforcement to be 15 registered in the DNA data bank. 16 J, you shall submit to a 17 warrantless search by your probation 18 officer or community control officer of 19 your person, residence or vehicle. 20 G -- where is the G? 21 MS. BELOHLAVEK: That was under the 22 original part, not under the sex offender 23 one. 24 THE COURT: Okay. Defendant to have 25 contact with the community control officer PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231243 27 1 at a minimum one time a week. 2 DeZendant-to.,...mozk-at_Eloxida 3 Science Foundation, 250 Australian Avenue, 4 5 6 West Palm Beach, Florida. Is that volunteer work or work for pay? MR. GOLDBERGER: It is a 501C 7 corporation that he has formed, Your Honor, 8 10 11 12 13 14 15 16 17 18 19 20 21 22 that will be doing charitable work. THE COURT: That he has formed? MR. GOLDBERGER: Yes. THE COURT: What exactly is Florida Science Foundation? MR. GOLDBERGER: Do you want to explain? THE DEFENDANT: It funds science programs around the state and the country. THE COURT: How long has it been in existence? THE DEFENDANT: Fifteen years. THE COURT: How many programs has it funded? THE DEFENDANT: Numerous, more than 23 50. 24 THE COURT: What is your position 25 with the organization? PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231244 28 1 THE DEFENDANT: President. THS--e6URIL-. Is—there—a board o-f-- 3 directors? 4 THE DEFENDANT: Yes, ma'am. 5 THE COURT: Who's on the board of 6 directors? 7 THE DEFENDANT: Two attorneys. 8 THE COURT: What exactly do you do? 9 THE DEFENDANT: I'm an investment 10 banker but my -- 11 THE COURT: No, no, I mean with the 12 science foundation. 13 THE DEFENDANT: We fund 14 science programs -- 15 THE COURT: I don't want to know what 16 we do, I want to know what you do. How 17 often are you there? 18 THE DEFENDANT: I'm there every day, 19 I research, I take in people who want to 20 make presentations about why they need 21 money for funding medical research, 22 advanced science research. My background 23 is in physics. I go through all the 24 programs in detail, review the science work 25 potentials, I follow through on a daily PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231245 • 29 1 basis with what they have been given money 2 Lo—d-u 3 THE COURT: Who are some recent 4 grantees? 5 THE DEFENDANT: Harvard University. 6 There is a full program of Evolutionary 7 Dynamics, Neuro Science Institute of 8 California, the Physics Institute, MIT. 9 THE COURT: Do you ever have occasion 10 to deal with anyone under the age of 11 eighteen? 12 THE DEFENDANT: Not very often. It 13 is, if someone is in college -- sorry. 14 THE COURT: Right, that's why I'm 15 asking the question. 16 THE DEFENDANT: Most of the people I 17 fund are all usually professors. 18 THE COURT: Thank you. You 19 understand that you can't have contact with 20 anyone if --.this organization, do they 21 ever have any involvement with high 22 schools? 23 THE DEFENDANT: No, ma'am. 24 THE COURT: Students or teachers? 25 THE DEFENDANT: No, ma'am. PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231246 30 1 THE COURT: Okay. 2 MS. BELOHLAVEK: Those are 3 duplicates, you will see those are the same 4 5 6 as the ones on the previous page, however, it was reproduced. THE COURT: The next condition, you 7 shall maintain a driving log. You shall 8 not drive a motor vehicle while alone without prior approval of your supervising 10 officer. 11 If there was sexual contact, you 12 shall submit to at probationer's or 13 community controllee's expense an HIV test 14 with results to be released to the victims, 15 victim's parent or guardian -- will be 16 victims, plural. Has that been done? 17 MR. GOLDBERGER: Not yet. 18 THE COURT: Do we have a time frame 19 on that? I would think ASAP might be good 20 on something like that. 21 MS. BELOHLAVEK: I believe they can 22 actually do that at the jail. 23 THE COURT; At his expense? 24 MS. BELOHLAVEK: Yes. 25 THE COURT: I would request that that PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231247 31 1 be done within 48 hours? You shall not obtain or use a post 3 4 5 6 7 8 9 10 11 12 13 14 15 office box without prior approval of the supervising officer. Okay. Are all those conditions you two have agreed to? MS. BELOHLAVEK: Yes, Your Honor. MR. GOLDBERGER: With the court's amendments, yes. THE COURT: Mr. Epstein, do you understand? THE DEFENDANT: Yes, ma'am. THE COURT: I need the defendant to sign number D where I had an s added to victim, and G, we struck out the otherwise 16 indicated language. Otherwise, it is as 17 you agreed. 18 Mr. Epstein, do you understand 19 this is a somewhat complicated terms of the 20 plea that you've agreed to? 21 THE DEFENDANT: Yes, ma'am 22 THE COURT: Do you have any questions 23 about the terms of the plea? 24 THE DEFENDANT: No. 25 THE COURT; Can I ask the State why PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231248 32 1 you choose -- or defense and the State 2 to her, wfly—TiThave monChrin CNT—Paam 3 Beach County jail followed by six months? 4 Why not just send him to DOC? 5 MR. GOLDBERGER: It was the agreement 6 of the parties, Your Honor. We just 7 decided that was the best way to accomplish 8 what needed to be done here and the parties 9 agreed that that sentence satisfied 10 everyone's requirements. 11 THE COURT: The taxpayers of Palm 12 Beach County is going to pay 18 months to 13 house this guy instead of DOC? 14 MS. BELOHLAVEK: Right. 15 THE COURT: You understand we're 16 losing positions left and right in county 17 government because we haven't got enough 18 money but you want -- okay. 19 His requirement to register there 20 is many, many -- there is nine pages 21 outlining the sexual offender's reauirement 22 to register with the department and 23 penalty, have you read all those, 24 Mr. Epstein? 25 THE DEFENDANT: Yes, ma'am. PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231249 33 1 THE COURT: Do you understand you 2 will be required to register and this will 3 4 S 6 7 9 be an ongoing life long obligation? THE DEFENDANT: Yes, ma'am. THE COURT: And this registration occurs when? MS. BELOHLAVEK: Within 48-hours of release. THE COURT: ■ when he gets out of 10 the Palm Beach County jail, he needs to 11 register? Okay. And the department -- who 12 is going to provide him with the form? 13 MR. GOLDBERGER: He actually \_) 14 registers out at the Sheriff's Office, Your 15 Honor, we can do it out there. 16 THE COURT: Okay. It has been 17 brought to my attention that FDLE is the 18 one who is statutorily required to handle. 19 these registrations but some of our 20 municipal jurisdictions have taken it upon 21 themselves to impose additional 22 requirements, y'all understand that? 23 24 25 MS. BELOHLAVEK: Correct. MR. GOLDBERGER: Right. THE COURT: What you are telling him PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231250 34 1 he has to do is the official State of 2 Florida reg stYrtir 3 MS. BELOHLAVEK: Correct. 4 THE COURT: Mr. Epstein, I need to 5 make sure you understand that that's what's 6 required by this plea. Anyone on 7 probation, community control is required to 8 live and abide by the laws. if a 9 jurisdiction you choose to reside in should' 10 have some additional municipal requirements 11 you will be required in order to comply 12 with the law of living there, just like you 13 can't get a parking ticket or speeding 14 ticket, to comply with those regulations 15 but I want to make sure you understand 16 because I have seen some defendants who 17 have been confused about this. If. you 18 don't, for example, if the Town of Palm 19 Beach has you register that does not take 20 care of your requirement. Your requirement 21 to register with FDLE through the Sheriff's 22 office is separate, distinct and must be 23 done on their form according to their 24 schedule. 25 THE DEFENDANT: Yes, ma'am. PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231251 35 1 THE COURT: And if my experience the 2 ITNE—tew months 3.75—al any value, they are 3 very serious about enforcing this. They 4 will be tracking you for the rest of your 5 life. Do not move. Do not go -- I don't 6 care when you are done with community 7 control, they need to know exactly where 8 you are and if you go anywhere without 9 10 11 registering, they will find and you will be locked up. THE DEFENDANT: Yes, ma'am. 12 THE COURT: Okay. Any questions 13 about that? 14 THE DEFENDANT: No, ma'am. 15 THE COURT: Did you read the plea in 16 the circuit court form that describes all 17 the rights you are giving up by entering 18 this plea? 19 THE DEFENDANT: Yes, ma'am. 20 THE COURT: I'think I asked you 21 before, can you read? 22 THE DEFENDANT: Yes. 23 THE COURT: Are you under the 24 influence of alcohol, drugs or medication 25 today? PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231252 36 1 THE DEFENDANT: No, ma'am. 2 THE —CDURT7--NUMMIly -TWKing any 3 4 5 6 7 prescribed medication? THE DEFENDANT: Only for cholesterol. THE COURT: Does that interfere with your mental ability? THE DEFENDANT: No. 8 THE COURT: Do you understand you 9 have an attorney, you have a right to trial 10 by jury, there is not going to be a jury 11 trial. There won't be witnesses called. 12 That your attorney and you would have a 13 right to confront and cross examine, do you 14 understand you have a right to call 15 witnesses of your own and the court would 16 issue subpoenas to compel their attendance 17 just like any other witness called by the 18 State, that you have the right. -- absolute 19 right to remain silent and that you would 20 not have to say or do anything at the trial 21 if there were a trial, do you understand 22 those rights? 23 THE DEFENDANT: Yes, ma'am. 24 THE COURT: Do you understand if you 25 are not a United States citizen your plea PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231253 37 1 could subject you to deportation pursuant flaws and regu aeions governing CUSS` 3 4 Naturalization Service and this court has 5 no jurisdiction or authority in such 6 matters, do you understand that? 7 THE DEFENDANT: Yes. 8 THE COURT: Has anybody threatened 9 you, coerced you or promised you anything 10 other than the terms of this plea to get 11 you to enter this plea? 12 THE DEFENDANT: No. 13 THE COURT: Do you understand this is 14 a plea in criminal court? 15 THE DEFENDANT: Yes, ma'am. 16 THE COURT: This has -- in criminal 17 court in Palm Beach County, State of 18 Florida. I have absolutely nothing to do 19 with any civil matters or matters in any 20 other jurisdiction, do you understand that? 21 THE DEFENDANT: Yes, ma'am. 22 THE COURT: Is this plea in any way United States Immigration and 23 tied to any promises or representations by 24 any civil attorneys or other jurisdictions? 25 MR. GOLDBERGER: May we come sidebar PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231254 38 1 on that, Your Honor? 3 THE COURT: IL i's--gokng—ta—b recorded. 4 MR. GOLDBERGER: That's fine. 5 THE COURT: Defendant needs to 6 approach as well. 7 (Whereupon, there was a conference at 8 the bench.) 9 MR. GOLDBERGER: The reason why I 10 asked to come sidebar, there is a 11 nonprosecution agreement with the United 12 States Attorney's office that triggers as a 13 result of this plea agreement. In other AY-N1 14 words, they have signed off and said they 15 will not prosecute Mr. Epstein in the 16 Southern District of Florida for any 17 offense upon his successful taking of this 18 plea today. That is a confidential 19 document that the parties have agreed to. 20 Just in an abundance of caution, / wanted 21 to tell the court. 22 THE COURT: I understand, that would 23 also be invalidated should he violate his 24 community control? 25 MR. GOLDBERGER: Absolutely. That PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231255 39 1 nonprosecution agreement -- ) firszronnvErr.---Th—erareann that 3 out. 4 THE COURT: Mr. Epstein needs to come 5 closer. 6 7 8 yr. Epstein, your attorney has told me that in addition to everything, we talked about another Inducement, shall we 9 say, to your taking this plea is that the 10 U.S. Attorney for the Southern District of 11 the State of Florida, federal prosecutor, 12 has agreed to a nonprosecution agreement 13 with you, meaning that if you successfully 14 complete probation and do everything you're 15 supposed to, they have, have agreed not to 16 prosecute you federally, did you understand 17 that? 18 THE DEFENDANT: Yes, ma'am. 19 THE COURT: And I would view that as 20 a significant inducement in accepting this 21 plea. 22 MS. BELOHLAVEK: They are actually in 23 court here today, also. 24 THE COURT: Okay. 25 MR. GOLDBERGER: And the plea PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231256 40 1 agreement very carefully spelled out if 2 there- was- a breach- thwt- won₹d viplatt 3 agreement, II we are well aware of it. 4 THE COURT: Okay. I would request 5 that a sealed copy of that Mr. Epstein 6 has signed that document? 7 MR. GOLDBERGER: Yes, I would.like to 8 seal the copy. 9 THE COURT: I want a sealed copy of 10 that filed in this case. That is the only 11 other condition of the agreement that is 12 influencing this defendant to make this 13 decision? 14 MR. GOLDBERGER: Absolutely. I think 15 that's the right idea. 16 (Return to open court.) 17 THE COURT: Mr. Epstein, is there 18 anything else? 19 THE DEFENDANT: No, ma'am. 20 THE COURT: Because I don't take 21 these pleas unless they are freely and 22 voluntarily made. 23 THE DEFENDANT: I understand that. 24 THE COURT: I also don't want 25 somebody or anybody coming back a year, PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231257 41 1 2 3 two years from now saying, oh no, no; they beat me over rers—Azat or if there is anything else that is influencing you to 4 make this decision, then I need to know 5 about it. 6 THE DEFENDANT: I understand that. 7 MR. GOLDBERGER: Thank you. 8 THE DEFENDANT: Thank you very much, 9 Your Honor. 10 (Return to open court.) 11 THE COURT: All right, Mr. Epstein, 12 any questions about the rights you are 13 giving up by entering this plea? 14 THE DEFENDANT: No ma'am. 15 THE COURT: State, please give me a 16 factual basis. 17 MS. BELOHLAVEK: In 069454 CF AMB, 18 between August 1, 2004 and October 31, 19 2005, the defendant in Palm Beach County 20 did solicit or procure someone to commit 21 prosecution on three or more occasions. 22 And in 08 CF 9381 CF AMB between 23 August 1, 2004 and October 9, 2005, the 24 defendant did procure a minor under the age 25 of 18 to commit prostitution in Palm Beach PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231258 42 1 County also. 2 THE—tUURTT--I —Tind a sufficient 3 factual basis to support the pleas. 4 Are all of the victims in both of 5 these cases in agreement with the terms of 6 this plea? 7 MS. BELOHLAVEK: I have spoken to 8 several myself and I have spoken to 9 10 13. counsel, through counsel as to the other victim, and I believe, yes. THE COURT: And with regard to the 12 victims under age eighteen, is that 13 • victim's parents or guardian in agreement 14 with the plea? 15 MS. BELOHLAVEK: That victim is not 16 under age 18 any more and that's why we 17 spoke with her counsel. 18 THE COURT: And she is in agreement 19 with the plea? 20 MS. BELOHLAVEK: Yes. 21 THE COURT: And community control 22 will be given information concerning how to 23 contact these victims? 24 MS. BELOHLAVEK: Yes. 25 THE COURT: Confidentially. That PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231259 43 1 2 3 4 6 7 8 information will not be related to the crefendanC—MC —WlETrUZ€ZI excrff-gr761-7 —fdY purposes of verifying compliance with this agreement? MS. BELOHLAVEK: Yes. THE COURT: Is there anything else from anybody else before I accept this plea? 9 MR. GOLDBERGER: No, Your Honor. 10 THE COURT: Mr. Goldberger, if it is 11 your desire, you may enter your client's 12 plea. 13 MR. GOLDBERGER: Thank you, Your 14 Honor, at this time we would withdraw our 15 previously entered pleas of not guilty, 16 enter pleas of guilty pursuant to 17 negotiations with the State. 18 THE COURT: Mr. Epstein, I am going 19 to accept those pleas on your behalf. I 20 find you are intelligent, alert, you 21 understand what is going on here and the 22 consequence of entering this plea, you are 23 doing it freely and voluntarily. 24 Pursuant to the plea, I am waiving 25 a PSI, I will sentence you at this time PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231260 44 1 pursuant to it. I will adjudicate you 12— gufrE7- 51— feliniy sorfol-t—ation of 3 prostitution, a third degree felony, case 4 number 06 CF 00945A -- 454 AMB, and 5 procuring a person under 18 for 6 prostitution, a second degree felony 08 CF 7 009381AMB. 8 With respect to the solicitation 9 of prosecution, I will sentence you to 10 twelve months in the Palm Beach County 11 detention facility with credit for the one 12 day served. 13 With respect to 08 CF 009381, 14 will sentence you to six months in the Palm 15 Beach County detention facility, with 16 credit for the one day served. That six 17 month sentence is to be served consecutive 18 to the twelve month sentence. 19 Following the six month sentence 20 you will be placed on 12 months of 21 community control. That will be on both 22 cases, I assume, to run concurrently, 23 correct? 24 MS. BELOHLAVEK: Only on the 08 case. 25 THE COURT: Only on the second degree PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231261 45 1 felony? 2 ----MS. ffELUHLAVEK: Correct, the one 3 that designates him a sexual offender. 4 THE COURT: Okay. II only on case 5 number 08 CF 009381AMB will you be on one 6 year community control which would then 7 invoke a potential penalty of fifteen years 8 were you to violate. 9 The special conditions are that 10 you are to have no unsupervised contact 11 with minors and the supervising adult must 12 be approved by the Department of 13 Corrections. You are to be designated a 14 sexual offender pursuant to Florida Statute 15 943.0435 and you must abide by all 16 requirements of that statute which I have 17 read and we have discussed. 18 You will remain confined to your 19 residence except one half hour before and 20 after your approved employment, community 21 service work or other activities approved 22 by your probation officer. You will 23 maintain an hourly accounting of all your 24 activity on a daily log which you submit to 25 the supervising officer upon request. PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231262 46 4. 1 1) 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 You will be residing at 358 El Weach, Ftarkda-11480. Should you desire to move or go to a different location upon release from custody, you will get preapproval of that location from the Department of Corrections. You will have to contact your community control officer a minimum of once a week, it can be more often at their discretion and you are to work at the Florida Science Foundation at 250 Australian Avenue in West Palm Beach, Florida. You will submit to a mandatory curfew of 10 p.m. to 6 a.m. You shall not live within a thousand feet of a school, day care center, park, playground or other place where 18 children congregate. You shall not have 19 any contact with the victims, directly or 20 indirectly including through a third person 21 unless approved by victim's therapist and 22 the sentencing court. 23 You shall not work for pay or as a 24 volunteer at any school, day care center 25 park, play ground, other place where PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231263 47 1 children may congregate. You shall not 2 v±ewTawn—ar possess—a-ny—obmteare 3 pornographic or sexually stimulating or 4 visual, auditory material including 5 telephone, electronic media, computer 6 programs, computer services that are 7 relevant to deviant behavior. 8 You shall submit two specimens of 9 blood to Florida Department of Law 10 11 12 Enforcement to be registered with the DNA data bank. You shall submit to a warrantless search by the probation officer 13 or community control officer of your 14 person, residence or vehicle. 15 You shall maintain a driving log. 16 You shall not drive a motor vehicle while 17 alone without prior approval of the 18 supervising officer. 19 You shall submit to, at 20 probationer or community control expense a 21 HIV test, the result of which is to be 22 released to the victims or victim's parent f I 23 or guardian. That has to be done within 48 24 hours. 25 You shall not obtain or a use post PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231264 C. 5 15 1 office box without the prior approval of 2 the—sugeivd-simg—cffrcer. 48 3 MS. BELOHLAVEK: You forgot one that 4 you may not possess, own or view sexually 5 stimulating -- I don't believe you read 6 that outloud just now. 7 THE COURT: Yes, I did. 8 MS. BELOHLAVEK: I'm .sorry, I didn't 9 hear it. I just wanted to make sure. 10 THE COURT: And the warrantless 11 search by the community control officer of 12 the person, residence or vehicle -- 13 understand the person, residence or vehicle \_) 14 includes anything you might possess like 15 computer, a cell phone and whatever other 16 elaborate devices there are to communicate 17 electronically these days, okay. Good 18 luck. 19 MR. GOLDBERGER: Thank you. 20 MS. BELOHLAVEK: Thank you. 21 THE COURT: Is there a judgment? 22 MR. GOLDBERGER: Yes, there should. be 23 judgments. 24 THE COURT: Was there a condition of 25 community control that he pay or is he PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231265 49 4 1 paying it? 2 MR GOLD.BERGER• LctUally_thers 3 cash bond posted, court cost can be 4 deducted from the cash bond. 5 THE COURT: $574 is the total? 6 MS. BELOHLAVEK: Correct. 7 THE COURT: Is that to cover both 8 cases? 9 MR. GOLDBERGER: Yes. 10 THE COURT: Thank you. 11 MR. GOLDBERGER: Thank you, Your 12 Honor. 13 (Whereupon, at 9:48 o'clock a.m. the 14 proceedings before the Court. concluded.) 15 16 17 18 19 20 21 22 23 24 25 PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231266 3. CERTIFICATE 2 3 THE STATE OF FLORIDA, 4 COUNTY OF PALM BEACH. 5 I, PHYLLIS A. DAMES, Official Court 6 Reporter for the Fifteenth Judicial Circuit, 7 Criminal Division, in and for Palm Beach County, 8 Florida; do hereby certify that I was authorized 9 to and did report the foregoing proceedings before 10 the Court at the time and place aforesaid; and 11 that the preceding pages numbered from 1 through 49, 12 inclusive, represent a true and accurate 13 transcription of my stenonotes taken at said 14 proceedings. 15 'IN WITNESS WHEREOF, I have hereunto 16 affixed my official signature this 19th day of 17 July, 2008. 18 19 20 21 PHYL S A. DAMES 22 23 24 25 PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231267 LEGAL RECYCLED PAPER TO REORDER CALL 9544/69399 EFTA00231268 PLEA IN THE CIRCUIT COURT THE FOLLOWING IS TO REFLECT ALL TERMS OF THE NEGOTIATED SETTLEMENT Name: Jeffrey E. Epstein Plea: Guilty X Case No. Charge Count Lesser Degree 06CF009454AMB Felony Solicitation of Prostitution 1 No 3 FEL 08CF009381AMB Procuring Person Under 18 for Prostitution 1 No 2 FEL PSI: Waived/Not Required X, Required/Requested ADJUDICATION: Adjudicate (x ) SENTENCE: On 06CF009454AMB, the Defendant is sentenced to 12 months in the Palm Beach County Detention Facility, with credit for 1 (one) day time served. On 08CF009381AMB, the Defendant Is sentenced to 18 months Community Control 1 (one). As a special condition of this Community Control, the Defendant must serve the first 6 months in the Palm Beach County Detention Facility, with credit for 1 (one) day time served. This sentence is to be served consecutive to the 12 month sentence in 06CF009454AMB. The conditions of community control are attached hereto and incorporated herein. OTHER COMMENTS OR CONDITIONS Court Costs: $474.00 Cost of Prosecution: $50.00 Drug Trust Fund: $50.00 As a special condition of his community control, the Defendant is to have no unsupervised contact with minors, and the supervising adult must be approved by the Department of Corrections. The Defendant is designated as a Sexual Offender pursuant to Florida Statute 943.0435 and must abide by all the corresponding requirements of the statute, a copy of which is attached hereto and incorporated herein. The Defendant must provide a DNA sample in court at the time of this plea. Assistant State Attorney Attorney for the_Defendant_ Date of Plea Defendant EFTA00231269 PLEA IN THE CIRCUIT COURT THE FOLLOWING IS TO REFLECT ALL TERMS OF THE NEGOTIATED SETTLEMENT Name: Jeffrey E. Epsteki Pies: Guilty Cease No. Charge Count Lesnr Defile/ 06CF009454AM8 Felony Solicilataon of Prostitution 1 No 3 FEL 08CF009381AMB Procuring Person Under 18 for ProstRutIon 1 No 2 FEL PSI: VVaivecUNot Required...1 Required/Requested AD4UOCATIOlit Adjudicate N SENTENCE: On 06CF0D8454AMB, the Defendant is sentenced to 12 months In the Palm Beach t:ounty Detention Facility, with credit for 1 (one) day time served. On OBCFO)9381 AMB, the Defendant is sentenced to 6 rnonthsAri the Palm Beach County Detention Faclity, with credit for 1 (one) day lime served. This 6 month sentence is to be served conasculivelo the 12 menet sentence in 06CF009454AMB. Following this 6 month sentence, the Defendant will be placed on 12 months Community Control 1 (one). The conditions of community control are attached hereto and incorporated herein. OTHER COMIKENTS OR CONOrtIONI: As a special condition of Ms community control, the Defendant is to have no unsupervised contact with minors, and the supervising adut must be approved by the Department of Corrections. The Defendant is designated as a Sexual Offender pursuant to Florida Statute 943.0435 and must abide by all the corresponding requirements of the statute, a copy of whk:h is attached hereto and Incorporated herein. The Defendant must provide a DNA sample Si court at the time EFTA00231270 948.101 Term; and condition of community control and criminal quarantine community control.-- (1) The court shall determine the terms and conditions of community control. Conditions specified in this subsection do not require oral pronouncement at the time of sentencing and may bo considered standard conditions of community control. (a) The court shall requireintensive supervision and surveillance for an offender placed Into community control, which may include but is not limited to: 1. Specified contact with the parole and probation officer. 2. Conflnemont to an agreod•upon residence during hours away from employmont and public service activities. 3. Mandatorypublic service. 4. Supervision by the Department of Corrections by means of an electronic monitoring dovico or system. 5. Tho standard conditions cf probation sat forth ins. 948.03. (b) For an offender plated on criminal quarantine community control, the court shall require: 1. elactronic monitoring 24 hours per day. 2. Confinement to a designated residence during designated (2) The enumeration of specific kinds of terms and conditions does not prevent the court from tickling thereto any other terms or conditions that the cart considers proper. However, the sentencing court may only impose a condition of supervision allowing an offender convicted of S. 794.0i1 s. 800.04_, s. 827.071, or s. 847.0145 to reside in another state if the order stipulates that it Is contingent upon the approved of the receiving sate interstate compact authority. The court may rescind or modify at any time the terms and conditions theretofore imposed by it upon the offender in community control. However, if the court withholds adjudication of guilt or imposes a period of incarceration as a condition of community control, the period may not exceed 364 days, and incarceration shall be restricted to a county facility, a probation and restitution canter under the jurisdiction of the Department of Corrections, a probation program drug punishment phase I secure residential treatment institution, or a community residential facility owned or operated by any entity providing such services. (3) The court may place a defendant who fs being sentenced for criminal transmission of HIV in violation of s. 775.0877 on criminal quarantine community control.. The Department of Corrections shall develop and administer a criminal quarantine community control. program orneriest:kg intensive supentision with 24-hounperday electronic monitoring. Criminal 4fisrantine community control status must include surveillance and may include other measures normally associated with community control., except that specific conditions necessary to monitor this popsiatfon may be ordered. EFTA00231271 '943.0435 Sexual offenders required to register with the department; penalty.-- (1) As used in this section, the term: (a)1, -Sexual offender. means a person who moots the criteria in sub-subparagraph a., sub￾subparagraph b., sub-subparagraph c., or subsubparagraph d., as follows: a. (I) Has been convicted of committing, or attempting, solidting, or conspiring to commit, any of the criminal offenses proscribed In the following statutes in this state or similar offonsos in another jurisdiction: s. 787.(11_, s. 787.02, ors. 737.025(2)(c), where the victim Is a minor and the defondant is not the victim's parent or guardian; s. 794.011, excluding s. 794.011(10); s. 794.05* s. 796.03. s. 796.035* s. 802.04* s. 825.1025; s. 827.071; s. 847.0133. s. 847.0135 excluding s. 847.0135(4);s. 847.0137. s. 847.0138. s. 847.0145. - or s. 985.701(1); or any similar offense committed in this state which has boon redesignated from a former statute number to one of those listed in this stblub-subparagraph; and (II) Has boon released on or after October 1, 1997, from the sanction imposed for any conviction of an of fans. described in sub-sdi-subparagraph (I). For purposes of sub-sub￾subparagraph (I), a sanction Imposed in this state or in any other jurisdiction includes, but Is not limited to, a fine, probation, community control, parole conditional release, control reheat°, or incarceration in a state prison, federal prison, private correctional facility, or local detention facility; b. Estabifshes or maintains a residence in this state and who has not been designated as a sexual predator by a court of this state but who has been designated as a sexual predator, as a sexually violent predator, or by another sexual offender designation in another state or .-rkl'F.fic . a ;:; jurisdiction and was, as a result of such designation, subjected to registration or community or : • r,,,, 4 .• i . ::. : l a : . public notification, or both, or would be if the person wore a resident of that state or jurisdiction, without regard to whether the person otherwise meets the criteria for registration .. . . as a sexual offender; c. Establishes or maintains a residence in this state who is in the custody or control of, or undo( the supervision of, any other state or jurisdiction as a result of a conviction for committing, or attempting, soliciting, or conspiring to commit, any of the criminal offenses proscribed in the following statutes or similar offense in another jurisdiction: s. 717.01 s. 787.02, or s. 787.025(2)(c), where the victim is a minor and the defendant is not the victim's Parent or guardian; s. 794.011, excluding s. 794.011(10); s. 794.05: s. 796.03. s. 7%.035;s. s. 825.1025;s. 927.071;s. U7.0133. s. 847.0135, excluding s. 847.0135(4);s. $47.0137;s. 847.0138;s. 847.0145; or s. 985.701(1); or any similar offense committed in this state ...Mich has been redesignated from a former statute number to one of those listed In this sub-subrateroPil; or d. On or after July 1, 2007, has been adjudicated delinquent for committing, or attempting, soliciting, or conspiring to commit, any of the criminal offenses proscribed in the following statutes in this state or similar offenses in another jurisdiction when the juvenile was 14 years of ago or older at the time of the offense: (0 Section 794.011, excluding s. 794.011(10); (I0 Section 800.04 (4)(b) whore the victim is under 12 years of age or where the court finds • saluted activity by the use of force or coercion; (10) Section 800.04(5)(c)1. whore the court finds molestation involving unclothed genitals; or EFTA00231272 (IV) Section 800.04(5)(d) where the coot finds the use of force or coercion and unclothed genitals. 2. For all qualifying offenses listed in sub-subparagraph (1 )(e)t.d., the court shell make a written finding of the ago of the offender at the time of the offense. For each violation of a qualifying offense listed in this subsection, the court shall make a written finding of the ago of the victim at the time of the offense. Fora violation of s. 800.04(4), the court shall additionally make a written finding indicating that the offenso did or did hot irholve sexual activity and indicating that the offense did or did not involve force or coercion. For a violation of s. 800.04(5), the court shall additionally make a written finding that the offense did or did not involve unclothed genitals or genital area and that the offense did or did not involve the use of force or coercion. (b) -Convicted TOWS that there has been a determination of guilt as a result of a trial or the entry of a pliof guilty or nolo contendere, regardless of whether adjudication is withheld, and in adjudication of delinquency of a juvenile as specified in this section. Conviction o a similar offense includes, but IS not limited to, a oomAction by a federal or military tribunal, including courts-martial conducted by the Armed Forces of the United States, and includes a conviction or entry of a plea of guilty or nob contendere resulting in a sanction in any state of the United States or other jurisdiction. A sanction includes, but is not limited to, a fine, probation, community control, parole, conditional release, tarboi retinae, or incarceration in a state prison, federal prison, private correctional facility, or local detention facility. (c) "Permanent residence* and 'tomporary residence have the same moaning ascribed in s. 775.21. (d) %institution of higher education' means a career center, community college, college, state university, or independent postsecondary institution. (a) 'theme in enrollment or employment status' means the commencement or termination of • erroltrnent or employment or . change in location of arrollmerrt or ornoWymont. (f) 'Electronic mall address" hos the same moaning as provided in s. 668.602. (g) instant message name moans an identifier that allows a person to communicate in real Hme with another person using the Internet. (2) A sexual offender shell: (a) Report in parson at the sheriffs office: 'I. in the county in which the offender establishes or maintains a permanent or temporary residence within MI hours after: a. Establishing permanent or temporary residence in this state; or b. Being released from the custody, control, or supervision of the Department of Corrections or from the custody of a private correctional facility; or 2. in the county where he or she was convicted within 48 hours after being convicted for • 1 . qualifying offense for registration under this section if the offender is not in tho c-ustody or EFTA00231273 control of, or under the supervision of, the Department of Corrections, or is not in the custody of a private correctional facility. Any change in the sexual offender's permanent or temporary residence, tame, any electronic mail address and any instant message name required to be provided pursuant to paragraph (4)(d), after the sexual offender reports In person at the sheriffs office, shall be accomplished in the manner provided in subsections (4), (7), and (8). (o) Provide his or her name, data of birth, social security number, race sox, height, weight, hair and Øcolor, tattoos or other identifying marks, occupation and place of employment, address of permanent or legal residence or address of any current temporary residence, within the state and out of state, including a rural route address and a post office box, any electronic mail address and any instant message name required to be provided pursuant to paragraph (4)(4), date and place of each conviction, and a brief description of the crime or crimes committed by the offender. A post office box shall not be provided in lieu of a physical residential address. 1. if the sexual offender's place of residence h a motor vehicle, trailer, mobile home, or manufactured home, as defined in chapter 320, the sexual offender shalt also provide to the department through the sheriffs ogee written notice of the vehicle identification numirer; the license tag number; the registration number; and n description, including color scheme, of the motor vehicle, trailer, mobile home, or manufectured home. If the sexual offender's place of residence is a vessel, live-aboard vessel, or houseboat, as defined in chapter 327, the sexual offender shall also provide to the department written notice of the hull identification number; the manufacturer's serial number; the name of the vessel, live-aboard vessel, or houseboat; the registration number; and a description, including color scheme, of the vessel, live-aboard WOOL, or houseboat. 2. if the sexual offender is enrolled, employed, or carrying on a vocation at an institution of higher education in this state, the sexual offender shall also provide to the department through the sheriffs office the name, address, and county of each institution, including each campus attended, and the sexual offender's enrollment or employment status. Each change in enrollment or employment status shall be reported in person at the sheriffs office, within 48 heirs after any change In status. The sheriff shall promptly notify each institution of the sexual offender's presence and arty change in the sexual offender's enrollment or employment status. When a sexual offender reports at the sheriffs office, the sheriff shall take a photograph and a set of fingerprints of the offender and forward the photographs and fingerprints to the department, along with the information provided by the sexual offender. The sheriff shall promptly provide to the department the information received from the sexual offender. (3) Within 48 hours after the report required under subsoction (2), a sexual offender shall report In person at a driver's license office of the Department of Highway Safety and Motor Vehicles, unless a driver's license or identification card that complies with the requirements of L /22OA1.(3) was previously secured or updated under s. 944.607. At the driver's license office the sexual offender shall: fa) If otherwise qualified, secure a Florida driver's license, renew a Florida driver's license, or secure an identification card. The sexual offender shall identify himself or hence as a sexual offender who is required to comply with this section and shall provide proof that the sexual offender reported as required In subsection (2). The sexual offender shall provide any of the information specified in subsection (2), if requested. The sexual offender shalt submit to the taking of a photograph for use in Issuing a driver's license, renewed license, or identification card, and for use by the department In maintaining current records of sexual offondors. EFTA00231274 (b) Pay the costs assessed by the Department of Highway Safety and Motor Vehicles for issuing or renewing a driver's license or identification card as required by this section. The driver's license or identification card Issued must be In compliance with s. 322.141(3). (c) Provide, upon request, any additional information necessary to confirm the identity of the sexual offender, including a set of fingerprints. (4)(e) Each time a sexual offender's driver's license or identification card is subject to renewal, and, without regard to the status of the offender's driver's license or identification card, within 48 hours after any change in the offender's permanent or temporary residence or charge in the offender's name by reason of marriage or other legal process, the offender stall report in person to a driver's license office, and shall be subject to the requirements specified in subsection (3). Tho Departmont of Highway Safety and Motor Vehicles shall forward to the department all photographs and information provided by sexual offenders. Notwithstanding the restrictions at forth ins. 322.142, the Department of Highway Safety and Motor Vehicles is authorized to release a reproduction of a color-photograph or digital-Image license to the 0epartment of Law Enforcement for purposes of public notification of sexual offenders as provided in this section and ss. 943.043 and 944.606. (13) A sexual offender who vacates a permanent residence and fails to establish or maintain another permanent or temporary residence shall, within 48 hours after vacating the permanent residence, report in person to the sheriffs office of the county in which he or the is located. The sexual offender stall specify the date upon which he or she intends to or did vacate such residence. The sexual offender mist provide or update all of the registration information required under paragraph (2)(b). The sexual offender mug provide an address for the residence or other location that he or she is or will be occupying during the time in which ha or she fails to establish or maintain a permanent or temporary residence. (c) A sexual offender who remains at a permanent residence after reporting his or her intent to vacate such residence shall, within 48 hours after the data upon which the offender indicated he or she would or did vacate such residence, report in person to the agency to which he or she reported pursuant to paragraph (b) for the purpose of reporting his or her address at such residence. When the sheriff receives the report, tte sheriff than promptly convey the information to the department. An offender who makes a report as required under paragraph (b) but fails to make a report as required under this paragraph commits a felony of the second degree, punishable as provided ins. 775.062, s. 775.063, or s. 775.064. (d) Asexual offender must register any electronic mail address or instant message name with the department prior to using such electronic mail address or instant message name on or after October 1, 2007. The department shill establish an online system through which sexual offenders may securely access and update all electronic mail address and instant message name information. (5) This section does not apply to offender who is also a sexual predator, as defined in S. 775.21. A sexual predator must register as required under s. 775.21. (0) County and local law enforcement agendas, in conjunction with the department, shall verify the addresses of sexual offenders who are not under the caro custody, control, or supervision of the Department of Corrections in a manner that is consistent with the provisions of the federal Adam Walsh Child Protection and Safety Act of 2006 and any other federal standards applicable to such voriflcartion or required to be met as a condition for the receipt of federal funds by the state. Local law enforcement agencies shall report to the department any failure by a sexual offender to comply with registration requirements. EFTA00231275 (7) Asexual offender who intends to establish residence in another state or jurisdiction other than the State of Florida shall report in parson to the sheriff of the county of current residence within 48 hours before the date he or she intends to leave this state to establish residence in another state or jurisdiction. Tho notification must include the address, municipality, county, and state of intended residence. The sheriff shall promptly provide to the department the information received from the sexual offender. The department shall notify the statewide law enforcement agency, or a comparable agency, in the intended state or jurisdiction of residence of the sexual offender's intended residence. The failure of a sexual offender to provide his or her intended place of residence is punishable as provided in subsection (9). (8) Asexual offender who indicates his or her intent to reside in another state or jurisdiction other than the State of Florida and Later decides to remain in this state shall., within 46 hours after the date upon which the sexual teenier indicated he or she would leave this state, report in person to the sheriff to which the seat offender reported the Intended change of residence, and report his or her intent to remain in this state. The sheriff shall promptly report this information to the department. A sexual offender who reports his or her intent to reside in another state or jurisdiction but who remains in this state without reporting to the sheriff in the manner required by this subsection commits a felony of the second degree, punishable as provided ins. 775.082, s. 775.083, or s. 775.084. (9)(e) Asexual offender who does not comply with the requirements of this section commits a felony of the third degree, punishable as provided ins. 775.062 s. T75.063 or s. 775.064. (b) A sexual offender who commits any act or omission in violation of this section may be prosecuted for the act or omission in the county in which the act or omission was committed, the county of the last registered address of the sexual offender, or the county in which the conviction occurred•for the offense or offenses that meet the criteria for designating a person as a sexual offender. (c) ill arrest on charges of failure to register when the offender has been provided and advised of h s or her statutory obligations to register under subsection (2), the service of an information or a complaint for a violation of this section, or an arraignment on charges for a violation of this section constitutes actual notice of the duty to register. A sexual offender's failure to immediately register as required by this section following such arrest, service, or arraignment constitutes grounds for a subsequent charge of failure to register. A sexual offender charged with the crime of failure to register who asserts, or intends to inert, a Lack of notice of the duty to register as a defense to of failure to register shell Immediately register as required by this section. A sexual offender who is charged with a subsequent failure to register may not assert the defense of of notice of the duty to register. (d) Registration following such arrest, service, or arraignment is not a defense and does not relieve the sexual offender of criminal liability for the failure to register. (10) The department, the Department of Highway Safety and Motor Vehicles, the Department of Corrections, the Department of Juvenile Justice, any law enforcement agency In this state, and the personnel of those departunnte an elected or appointed official, public employee, or school administrator; or an employee, agency, or any individuel or entity acting at the request or upon the direction of any law enforcement agency is immune from civil liability for damages for good faith compliance with tie requirements of this section or for the release of information under this section, and shall be presumed to have acted in good faith in compiling, recording, reporting, or releasing the information. The presumption of good faith is not overcome if a technical or clerical error is made by the department, the Department of Highway Safety and Motor Vehicles, the Department of Corrections, the Department of Juvenile EFTA00231276 Justice, the personnel of those departments, or any individual or entity acting at the request or upon the direction of any of those departments in compiling or providing information, or if information Is incomplete or incorrect because a sexual offender faits to report or falsely reports his or her current place of permanent or temporary residence, (11) Except as provided ins, 943.04354,M. offender must maintain registration with the department for the duration of his or her e, unless the sexual offender has received a full Pardon or has had a conviction sat aside in a postconviction proceeding for any offense that meets the criteria for classifying the person as a sexual offender for purposes of registration. However, a sexual offender: (a)l. Who has boon lawfully released from confinement, supervision, or sanction, whichever is later, for at least 25 years and has not boon arrested for any felony or misdemeanor offense since release, provided that the sexual offender's requirement to register was not based upon an adult conviction: a. for a violation of s. 787.01 or s. 787.02; b. Rix a violation of s. 794.011 excluding s. 794.011(10); c. For a violation of s. 800.04(4)(b) whore the court finds the offense 'waived a victim undor 12 years of age or sexual activity by the use of force or coercion; d. Fora violation of s. 800.04(S)(b); Q. Per a violation of s. 800.04(5)c.2. whore the court finds the offense involved unclothed genitals or genital area; f. For any attempt or conspiracy to commit any such offense; or g. Per a violation of similar law of another jurisdiction, may petition the criminal division of the circuit court of the circuit in which the sexual offender resides for the purpose of removing the requirement for registration as a sexual offender. 2. The court may grant or deny relief if the offender demonstrates to the court that he or she has not been arrested for any crime since release; the requested relief complies with the provisions of the federal ActagiWelsh Child Protection and Safety Act of 2006 and any other federal standards applicable I the removal of registration requirements for a sexual offender or required to be met as a condition for the receipt of federal funds by the state; and the court is otherwise satisfied that the offender is not a current or potential threat to public safety. The state attorney in the circuit in which the petition is filed must be given notice of the petition at least 3 weeks before the hearing on the matter. The state attorney may present evidence in opposition to the requested relief or may otherwise demonstrate the reasons why the petition, should be denied. If the court denies the petition, the court may set a future date at which tho sexual offender may again petition the court for relief, subject to the standards for relief provided in this subsection. 3. The department shall remove an offender from classification as a sexual offender for purposes of registration if the offender provides to the departnsent a certified copy of the courts written findings or order that indicates that the offender is no longer required to comply with the requirements for registration as a sexual offender. EFTA00231277 (b) As defined in sub-subparagraph (1)(a)1.b. must maintain registration with the department for the duration of his or her life until the person provides the department with an order issued by the court that designated the person as a sexual predator, as a sexually violent predator, or by another sexual offender designation in the state or jurisdiction in which the order was issued which states that such designation has been removed or d ates to the department that such designation, if not imposed by a court, has removed by operation of law or cowl order in the state or jurisdiction in which the designation was made, and provided such person no longer meets the criteria for registration as a sexual. offender under the laws of this state. (12) The Legislature finds that sexual offenders, especially those who haw committed offenses against minors, often pose a high risk of engaging in sexual offenses even after being released from incarceration or commitment and that protection of the public from sexual offenders is a paramount government interest. Sexual offenders haw a reduced expectation of privacy because of the public's Interest in public safety and In the effective operation of government. Releasing information concerning sexual offenders to law enforcement agencies and to persons who request such information, and the rebuts* of such information to the public by a law enforcement agency or publk agency, wet further the governmental Interests of public safety. The designation of a person as a sexual offender is not a sentence or a punishment but is simply the status of the offender which is the result of a conviction for having committed certain crimes. (13) Any person who has reason to believe that a sexual. offender is not complying, or has not complied, with the requirements of this section and who, with the intert to assist the sexual offender in eluding a law enforcement agency that is seeking to find the sexual offender to question the sexual offender about, or to arrest the sexual offender for, his or her noncompliance with the requirements of this section: (a) Withholds information frcm, or does not notify, the taw enforcement agency about the sexual offender's noncompliance with the requirements of this section, and, if known, the whereatxtrts of the sexual offender; (b) !tabors, or attempt to harbor, or assists another person in harboring or attempting to harbor, the sexual offender; or ' • ii•ra•:•., (c) Conceals or attempts to conceal, or assists another person In concealing or attempting to conceal, the sexual offender; or (d) Provides information to the law enforcement agency regarding the sexual offender that the person knows to be false information, commits a felony of the third degree, punishable as provided ins. 775.082, s. 775.063, of 5. 775.084. (14)(a) A sexual offender mint report in person each *sr during the month of the sexual offender's birthday and during the sixth month followIrq the suet offender's birth month te she sheriffs office in the county in width he or she resides or is otherwise located to reregister. (5) However, asexual offender who is required to register as a result of a conviction for: 1. Section 787.01 or s. 787,02 whore the victim Is a minor and the offender is not the victim's parent or guardian; EFTA00231278 2. Section 794.011 excluding s. 794.011(10); 3. Section 800.04(4)(b) where the court finds the offense involved a victim under 12 years of age or sexual activity by the use of force or coercion; 4. Section 800.04(5)(b);. 5. Section 800.04(5)(c)1. whore the court finds molestation involving unclothed genitals or genital area; 6. Section 800.04(5)c.2. where the court finds molestation involving unclothed genitals or genital area; 7. Section 800.04(5)(d) whore the court finds the use of force or cordon and unclothed genitals or genital area; B. Any attempt or conspiracy to commit such offense; or 9. A violation of a similar law of another jurisdiction, must reregister each year during the month of the sexual offender's birthday and every third month thereafter. (c) The sheriffs office may determine the appropriate times end days for reporting by the sexual offender, which shall be consistent with the reporting requirements of this subszetion. Fteregistration shall include any charges to that following information: 1. Name; social security number; age; race; sex; date of birth; height; weight; hair and eyo color, address of any permanent residence and address of any current temporary residence, within the state or out of state, including a rural route address and a post office box; any electronic mail address and arty instant message name required to be provided pursuant to paragraph (4)(d); date and at, of any ompLoymont; tie make, model, color, and license tag number; fingerprints; and photograph. A post office box shall not be provided In lieu of a physical residential address. 2. if the sexual offender is enrolled, employed, or carrying on a vocation at an institution of higher education in this state, the sexual offender shall also provide to the department the name, address, and county of each institution, including each campus attended, and the sexual offender's enrollment or employment status. 3. if the sexual offender's place of residence is a motor vehicle, trailer, mobile home, or manufactured home, as defined in chapter 320, the sexual offender shall also provide the whiche identification number; the license tag number, the registration number; and a . description, Including color scheme, of the motor vehicle, trailer, mobile home, or Vs 4,••rti`•:•. manufactured home. If the sexual offender's place of residence is a vessel, live-aboard veisoll or houseboat, as defined in chapter 327, the sexual offender she also provide the hull identification number; the manufacturer's serial number; the name of the yard, live-aboard • . vessel, or houseboat; the registration number; and a 4a:caption, including color scheme, of rc the vessel, lin-aboard vessel or houseboat. 4. Any sexual offender who fails to report in person as required at the sheriffs office, or who fails to respond to any address verification correspondence from the department within 3 weeks of the data of the correspondence or who faits to report electronic mail addresses or EFTA00231279 • • I. P ' • : instant message names, commits a felony of the third degree, punishable as provided in s. 775.052 s. 775.081, ors. 775.084. (d) The sheriff's office shall, within 2 worldng days, electronically submit and update aU information provided by the sexual offender to the department in a manner proscribed by the daps rtmont. EFTA00231280 • .1105/2608 15:28 3563626 • • I I. f• o STATE OF FLORIDA Plaintiff WINUJI I UNIM.I.ML rt.= ealee IN THE FIFTEZNTE JUDICIAL . CIRCUIT COURT, IN AND FOR PALM BEACH COUNTY CASE NUMBER 1921111MWDI REMLEaLlg, 'Spi DIVISION MCSORXXY "W" Defendant ' DC NUMBER W3515 - - - CIRCUIT NUMBER, 1543ALL SPLIT ORDER OF COMMUNITY CONTROL I This cause coming before the Court to be heard, and you, the defendant, being now pram before the *owl,' and you having 2 entered a plea of guilty to 0 been found guilty Injury verdict of ❑ entered a pint of solo contendere to boar rola galley by ilia court trying the cue wIthouta jury of. Count I PROCURE rzRsoll non AGE OF le FOR PRO577TUTI ON SECTION 1: JUDGMENT OF GUILT O The courthereby actiudgel you to be guilty of Ac show offose(s). Vow, therefore, it is ordered and adjudged that the tows:tido of sentence U hereby withhold and that you be placed on Probation! fix a period of under the neervieloo of the Dopartzreet of C.orreedone, subloot to Merida law. SECTION 2; ORDER WITMIOLDING ADJUDICATION CI Now, therefore, it is ordered and adjudged that the adjudication of guilt is hereby witbia and that you be placed on Probation fora period of_ under the supervision of the Depareneut of Cone:dots, su*at to Moeda low. SECTION 3: INCARCERATION DURING PORTION OF SUPERVISION SENTENCE It la hereby ordered and aciludgad that you be ❑ committed to the Departaroni of Conwdons or O confuted in the CountyJail !orate= of vildscredit tea jog ties. Aker you have tonne a Idle terse, you shall bcplaceel on Probation fora petted of « lodes the ruperviabo of the Dees malt of Corrections, subject to Florida law. or 2 confined in Sit Compost' for a term of @SIC CM MONTHS AS TO COUNTWILLOWED DT TWELVE a 21 NION-1331 COMMUNITY CONTROJ. I cor4srcunn TO THE (12) MONTH SENTENCE CAR" 2008CF0094SAAtil with mils for OW1110 DAY jail limo, Us special condition of wrowition. Fags 1 of TeNII4160 1.1110kilD 914/ tinoo witid flat 'NODE li11001-iS . SS:I wd 1 Z 1n1 BOOT aril Fan Inked 01.1t.C4 EFTA00231281 11125/2008 15:28 3553626 Ulteatn. I unman. rmoc 44, Ov 3EFPREY EPSTEIN CASEN$010011CF009381aX7O4B 28 HIRT= OthitRalbstyaiaballicogdyivlb tallorlas lillignitaoutlined' of iptgrVIA/12a as.prOilde4 by lzlcuid lass a. . . (1) You van:core to tie. pada allot as directed, Not law than the flidt daY of Oath Snorts, asks delnwillesdkopiod, you will . meke a full and Inttlablrenrt to your oflloor on the forth provided for that purpose. . . • • - (2) You will pay the Stan otFlaliti tLc eitionni a1so.00 37:r . month, is wallas 4% stnthrge, toward tho poet of your aulleatision in - - nonordormo with sr (148.09,P.S,. union otherwise oxempeod in compliance with Florida Stevan& (3) You win remain In a specified place. YOu will rot change your residence cc employment of leave the county of your eteitionce without first procuring theooneent of yew °Moe. • (4) You rant not possess, wry or own any firearm or steepen, unless authorized by the court (5) You will live without violating the law. A convktko Ina court of law shall not be necessary for sod a violation to roonatiroto a , violation of yoarprebatiodeommunity 00rerei . (6) You WW not lanolin wtG atrY person engaged In anyClinhaliente• (7) You will not oat inexiconte to extesi or pawn any drugs or narcotics stolen proscribed by a physician. „Nor Win you visit. , places where Montan% drugs or other dangerous aubstanon are trolaWittly sold, diapeoaed or used. " (I) You will work diligently at a lawful occupation, advise you: employer of your probation stems, and support any dependents to the boss of your ability, as dinned by your officer. (9) You will promptly and ttudotilbr tan all Moil:let directed to you by the tom or the of and allow your officer to visit tit ' your boat. at your employment site or elsewhere, and you wit comply with all Indtrucrlota your offka: may give you' (10YenMil pay renrudon, cam coals, and/or no to anonmen with special tor.dltIons Imposed or In accordance with the attachod orders, • • (11)You will !submit to random testing ea directed by your officer or the Professional staff of to mot= center where he/she Is !salving treatment so determine the prase= of alcohol or illegal. drop. You will be required to pey far the tests nano exempt by the court (12)You will submit two biological specimen, as tussah by your offic*, for DNA analyda as pecocribod in it. 943.32$ and 941.014. F.S. (13)You w!ll report in pram within 72 bonze of your release from inoameration to the probation ogles In BALM BEA CI3 County, Florida, unless otherwise instructed by the court or eepartmenn (This oondition implies only 3 on the previous page is oltooked.) Otbersins, yes mon report immediserly to the probation office loaned at 04441111 CONGRE§6 MIXNULA 1.447 WORTH WI. VW, Pap 1 oft Fours Reviacd 03.IR-OX EFTA00231282 11/25/26e8 16:25 3553626 l:1MW11 iattrusiir_ rMMM w/40 1VEREY IRSTEIN CASB#502008CFD09381/OOO/43 . . C. I BrICIAL. GI 1. You must undergo a Drug end Alcohol evaluation O.K0rnOriS and, If treaters:al Is deomcd nodatu.-y, you must ancoeitiblly oomplede to treatment, and be napoalblo for the paymor3 of any coat toured while rceolving said enivatlon andtreamen; unlose• .... waived by the court'. Additional hishadosii ordered:. . - • • . . .. . • • • - ..• .' 2. You iitetnea by the ablkfl. Abel the obligation is cold in 5111: : r a t Make ma/Miele trig fo3oWing .tionm(s),Ili i Nom: • . . . . • :. .• • •• . • • • • • .'• . . 0.- - • • .. TOTAL AMOUNT; $ • . • aldidocial 3.:i' • Iratmedom ordorod, including spa° m onthly amount, beep date, due dela, orJant & several:— • NAME' TOTAL AMOUNT: $ Additional kwouettom ordered, Including ypegfic monthly amount, bogie date, due date, or Joint it mend: SPECIAL CONDITIONS — CONTINUED 0 3. You will enter the. Deportment of Cantotions Non-Secure Drug Treatment Program a other residential treatment , program/Probation tad Restitution Coates' for a period of successful completion as approved by your officer. You am to remain until you suceasfaily ocirtmlete old Program and Alisr-are. Yin are to *trimly with WI Rules and Regulations of the Program You *al be confined In the county Jail wall placement in said program, and if you are confined in the Jail, the Sheriff will tramped you to skidprogram ❑ 4. You will abstain entirely from the use of dock! and/or Illegal thugs, and you will not am ste with anyone who is illegally lasing drugs orconsuming timbal O 3. You will submit to urinalysis testing on a molly' 3 basis to doiernbm the presence of alcohol or illegal drugs. You will bo squired to ay for the tau unless exact by the court. O 6. You will not visit soy establishment where the primary business is the sale and dispensing of alcohol', beverages. 0 7. You will suoassfully eompreee hours of community eervioc at a rate of at e work site approved by, your oftIcer. Addttlonal Imouotions ordered: ❑ 8. You will remain w. your fakirs bears 10 pm. and 6 aaa due iota:few imposed. talesa otherwise directed by the 001121. ❑ 9. Yon will submit m electronic monitoring, follow the rules of &carotid rnoatoring, and pay per month for the cost of the motiltoriot service, noose otherwise eithooted by the court. ❑ 10. You will not mocha with during the period of supervlsim. ❑ 11. You will have no contact (direct or indirect) with the victim or the vietlm•e family during the period of type-realm • t You will ao °antra (ditto; or Ittihad with during the ;Mod of supervision ❑ 13. You will maintain fall time employment or attend school/vocational school full time or a oombisation of schooYworle during the taros of your supervision. 0 14. You will make a good felt effort toward completing bale or fisnotiona! literary skill. or a high school equivalency diploma. O 15, You will suoceedully complete the Probation de Resdrudon Program. abiding by all net and regulation. - . . . • • .• . Page 3 of I PO= Reload O1-11.08 EFTA00231283 / 2bratrote lo: 2Id attabtet e •• • vsnwa i LACHMAINN. r meta 4rr tro JEFFREY EPSTE1N CASP.45021308CP009381A1000.113 . . . • • 16. You via ina AbohoBea Artonymoue orNuccdc. Anonymas, matbit:ta lagetOWEIFElegeleaffibigartgafåttged " •• by eho on" ". ' . . . • ' . • • • ID Il. You most slordettdly ooMplate Mott Mattlaelian: and be 0:176ndelo ior the P67/66/1: or 667 orm 78779d rtosivits Kid treitrynt, udas walvet. If convIcted of a Doroesdc Violetta ofrom, es defited It I. 74128, 7.1.1 • Mit sund and auccenetly oomplen i battcra's intenuration program, utless oflorwlos ddractod by te oiitt Additiona1 Immuodool 0rdar** • • . • :• •• • • • ' ••• • •• CI I Vou v.111 rand en MV/A/OB AnnansProgram contwing of a ohm of not less Mo two (2) hotas ar mosa thig kar . (4) bira In Isnot; te Mot for wtdob ISO betald by you. • . ❑ 19, You Mall aubmIt your porton, *pmpony, placo of naidnice, vehlric or person el efter. b to a tartan:len maroh at ny dem, by my probadon or community control officer or aay lana ertforoemant off:c MC O 20, DEPENDANT mun Rims= ASA SEXUAL «TENDER IM-1M 48 HOURS OF RELEASE 21. AS A SPECIALtonal« OF HIS COMMUKITY CONTROL, THE DEFENDANT IS TO HAVE PIO. UNSUPERYISED CONTACT WITH MINORS, AND TEFE SUPERVISINOADOLT MUST BE APPR9YED BY THE DEPARTMENT OF CORRECTION8 O 22. THE DEPENDANT IS DESIGNATED ASA SEXUAL OPFINDER PURSUANT TO FLORIDA STATUTS 943.05 AND MUST ~ZU ALL THE CORRESPONDINO R£QUIREMENTS OF THE STÄTUTE, A • COPY OF WHICH IS ATTACHED aurro AND INCORPORAT£D IIEREIN O 23. DEPENDANT MUST PROVID£ A DNA SAMPLE IN COURT AT THE TIME OF TRIS PLEA. 0 24, SPECIFIED CONTACT WITH TEC PAROLE AND PROBATION OFFICER O 23. CONFINEMENT TO AN AORIXD-UPON RESIDENCt DURING ROM AWAY FROM EMPLOYYIENT AND PUBLIC SERVICE ACTIVfTI£S 0 23. MANDATORY PUBLIC SERVICE O 26. SUPERVISION, BY THE DEPARTMENT OF CORRECTIONS BY .REANS OF AN ELECTRONIC MONITORINCDTVICE OR SYSTEM 0 27, ELECTRON1C MONITORINO 24 ROURS PER DAY Ø 28. COP/710IEMEXT To A DESIONATED Rgrorricz »mun DESIGNATED HOURS OF AND, 17 PLACED ON DRUG DEFENDER PROBATION YOU WELL COMPLY WITH THE FOLLOWING CONDITION analt:sto« IN ADDITION TO TEL STANDARD CONDITIONS LISTED ABOVE AND ANY OTHER SPErisf comorrioNs ORDERED BY TRE COURT: (14) You Mil particips» in a specialml drug atatmeotprogrom, alt« as tit In-padett or out Patient ancommondad by the . trestrone revider. Toa will otteod all council ing tenios, aubnilt to =dom urtnalysis and, If an Irroatlent, you velII ooroply talek all ogagn ruka, orgulations end procedures of the teamen: fiwility. You pay for aul coda aasoclored wIrb tresemen and intog uttas otherwhe efiretted. Addition, lostruerlau ordest; ❑ Unc:ad (IS) You w01 remøs at your raiderro bettmen sad., am. duo to a ca-few hnposod, unloss otherwis by the ooun. ADDITION AND, TI: PLACED TO ON COMMUNITY CONTROT,,, YOU WILL COMPLY WITH THE FOLLOWING CO NDMONS. IN . • IIIITSTANDAHD CONDITION0 133TED ABOVE AND ANT OTHEREIPECIALCONDITIONO ORDERS» BY THE COURT: • Pago 4 ort ?can Radad 01414 EFTA00231284 11(25/29013 15128 3663626 lataa 11 IJILPUNAL nom our oar YESPRIIY Fts7201 CASE#102008CF0119381A)703y1B • (14)You will Sepoil to you, offisef is dinged.-ahlwe sot-flan s irbek, unisnYoll have laical contented:ere/Ise (1.5) You will remain confined le your approved i nit-ince except for one half born before and after your approved employment,. .,._ • . . service work, or royalist spend activities approved by Your oiler. • : :r(16)Yon VIE Melanin on hardy account's: of all yootactivides on a dilly Log, which you will submit to.yoor office on, requ Ht. , • • . • • . . (17) Yeti will itcoessfully oomploto hours of ocuanninity service harem of_ e" I WOTic site approved by Yew officer. . Additional instructiors orate& "•• • 08) You eillrudnit to electronic monitoring, follow the rules of cleoZonk monitories, and pay $ 4" d? • fordo coat of the rnoctitodng service, Leticia otherwin directed by the court. AND, IF PLACED ON PROBATION OR COMMflTrY CONtROL FOR A Sfl onzg PROVIDED EN CHAPTER . 124. LUSK LIZ? 071 ors 047.0140, comtarrED ON OR Ann OCTOBER 1.1995 YOU WILL COMPLY WITH THE FOLLOWING rrkripARD SEX OFFENDER CONDITIONS, IN ADDITION TO THE STANDARD CONDITION? LISTED A.13OVE AND ANY OTHER SPECIAL CONDITIONS ORDERED BY THE COURT: •• (14)A mandatory outline from 10 p.m. to 6 aro. The coon may dentate Another $.hour yelled If the °Mondani employment ' precludes the above specified dine, and the alternative is recommended bY the Department of Corm:Mona If the owl determine, that imposing a curfew would endanger the viotini, the cowl may consider abernative unctions. (15)If the victim was under the age of 18, a prohibition on tiring with 1,000 feet of a school, day one center, park, playground, of other place where children regularly eon: Dugan, es prescribed by the court Tbo 1,000-foot distance shell bo measured in a might Ens tom the offender's place ofresIdence to to betrat boundary WO of the school, day can crater, par); playground, or • air place ware edlthencongtegrat Tba distance may not be eon:aid by a pedestrian route or automobile route. fleAetive partnipatian in and succestfal tompledon of a act offender ueatmant prop= with qualified practitioners speolteally trained to trod an offeaere, tt the offender's own meat If s qualified practitioner is not available within a SO-mile radius of the offender's redlenge, - the °Strider dial participate In other appropriate therroy. (:7)A orchid:ion on any coat& with the victim, directly or Indirectly, including through a third perm, unto's approved by the Stint, the offends:4 thmapisr, and the tertmrag cent (18)If the drom was under the age of DI, a prohibition on contain within:tile under the age of 18 except as provided in this puegraph. The court may approve supervised Etna with a child ander dm age of 18 if the approval it based upon a recanamendation for costars inued by a qualified praotither win is basing the reconurrandaµon on a risk assessment. Further, the tor offender mutt be ourrettly caroled in or have succeed:141y compietod a sex offender therapy program. The aunt may not ' gent 'supervised comet with a ohnd tf the contact is net ncarmeoded by a qualified practitioner and may deny supervised control with a child et any ante. • (19)if the victim was under age 18, a prohibition on working for pay or as a volunteer at any place when children regularly . eensacficle, including, but net limited to any school, day oars caner, park ploground, yet sten, library, zoo, theme park, or mall, • . .(20)Uniut otherwise Indies:1A kt the treetteett plea provided by the anal ofthrrier treatment program, a prohibition on viewing, actcuitg, owning, w PeRoalleg any c6306"; Perdetriftio, cr sexually stimulating visual or auditory material, including telephone, electronic media, computer programa or computer tervieto that are relevant to the offender's deviant behavior pattern. (21)A regniremtat that the *Ikeda submit two meadow:a; of blood or odor approved biological apeolmene to the Florida Department of Law Enforcement to be nitrated with the DNA data bank. (22) A requirement that the carder make natirulon to the victim, as ordered by the court under s. 775.089 for all nocsamuy medical and related profbstonal sr, lea Sun to physical, psychiatric, and psychological aro. (13)3%16i:elation to a unruliest Search by to conuounity coaxal or probatin officer of the offendn'apetseh residence, or vehicle, Past 3 aft Forodaleed $41 ••••.txt • EFTA00231285 11/40(400C IINAO #73#J301.0 14/ /11Who. WI %MM.@ IMO. I Ili.» Wye %Iva Y. I , I . • . • , JEFFREY EPSTEIN CA$Ea502008Cp00938JA7ODMfB • EFFECTIVE FOR PROBATIONEROR COMMUNITY CO: ROLLFE WHOSE CRIME WAS comtarceD ON ot. . , AFTER°drum I O97 AND W is PLACED ON COMMUNITY CONTROL OR SEX OFFENDER PROBATION • ;sr ' FOR A VIOLATION OF.CHAPTER ,22,f, a. L 1,37.071,, or a. J47.0145,IN ADDITION TO ANY OTHER. pRonslopi „ , " OF THIS SECTION, YOU MUST COMPLY WITH THE FOLLOWING CONDITIONS OF SUPERVISION! • . 7 • • (24) As part of. treatment program, partnipllion atleaat annually In polygraph mominations to obtain information octecaery •: ,• Managermat and tIcatmeill and to reduce the K..•t Offirld0e8 denial mechmirms. A polygraph examindon'oMet be Losucad by : •• polygnmhar trained apecifically In the me of the polygraph for the monitming of cox offenders, Mere'availidn0, shall be pt1A • • • • • ' by the sex offender. ••. . • . .(25)Mainionancek of a &Ivies kg and • prohibition against driving a motor ostanis alone without Ma FSr approval of thy stupur rlarag ore,. SA prohibition against obtaining or ming a post officebox without the prior approval of the supervising officer. • • (27)If then vnisexual 'tonne' ', • subodeSine to, at the offonciart expense, an HIV test with &rondo to be released to the victim • =For the #dotien's pitent tie pinyon% • • • • • Ca/Eleitratite Monitoring Prhen deemed neeemaly by tho probadon ofEcer and eupowlior, and ördeltid by the mint at die recornmeodadon of to Department of Cermodont• % "I • (29) Effective for gm °Milder whose crime war committed odor after July 1,2005, and who are placed on impend:Ion for violation of chapter 794,3.890.04, a. 827.871, öre. 847.014En prohibition on messing tbc Imanct or other computer z-ntcs uatd tho offordert an offender treatment program, after a risk assessment is oompleted, approves and implements a safety plan for the offenders toasting or using the ;menet or eFder compider *enlace. . (30)EfIcotIve for offenders whose crime was namnrost on or after September 1,2405, there la leoby Imposed, t addldon to any otter. provision is this station, rramdatery clectionio monitoring m a oonditIon of rimmvision for than who: .• Åm pieced on supervision far a vieJetleo of niostater 794,2. 8C0.04(4), (5), or (6), a. 821071, art 847.0145 and the unlawful mutual activity involved a victim 15 years of age or younger and tie °nod& is 18 years of ago or older, ▪ Are designated or a sexual predator purtunt m tk. 77521: or • Has previously been ecnvionad o f a violation of &motor 794,3. 800,04(4), (5), or (6), a. 827.071, or a. 847,0145 and the malawrikl aCallai activity Involved a vintim 15 yew of age or younger and rho offender b la years Otago Cr DIder. You are hereby placed on nob» that should you violate your probation or community control, and the conditions act forth in a. 948.063(1) or (2) on Palled, whether your probation or community control is rovolood or not revoked, you dull be plated on electronie monitoring in accordance with F.S. 948,063, • YOU ARE HEREBY PLACED ON NOTICE that tho mud may at any time rescind or modify any of the condition, of your" ormay card the poriol ofprobadon u authorized by law, or may discharge you from (maw supervielon, If yen violate any *ilk oandidena of your pnbadon, you may be arremed and the court may revoke yam probation, in:QtAiicats you guilty if «indication of guilt we withhid, and Impose any eenteroe that it might have Imposed before placing you on probation or require you to perm the balance of the asatmen . • . . • Pale 6 of 8 Form Iminid 03.11143 • EFTA00231286 "Tr 13./21:3/W11U lb: kV .it.b.$bzb • JEFFREY EPSTEIN CABEES02008CP009382AXENJI WAWA I calrill‘41. • rms. .ui I 90 ; :: - ' ? • • • .. ...:. .." .:. t, .. •••,..'?,:.:;;,:•••,. ...:7,:.; -. 19 :: . : „ • :. • .. ,: • . • - IT liitrit113ti oittlinD bet vbitin yotibosk; bifriiingtnattai a &the Conditions of prohaton, you thin be released Emu .t.•,n. : ' f • f. . :••• . . ourtedyeyou on in woody; eid Vivi aro Nliberg.ep boa, the 'untie, theteonhell stead distill:Pt} imp liabilitY. (nik parevaph applke only itevaloa I or "Lion 2 is °beaked.) • • • • • • • • • • • • • • IT 16 FoRTHIra ORDWID that the duke this Kat filo this order In the eletk's dike sed perthieienthattedee of amble: ' . : • • . • the officer k•r use le comilter with the requirements of la. • • ' ... *DONS AND ORDIRED, on 4 ?t t) r • • • . . • . NVNC .... TUNC 06.3O.2Dtit cfee.t-CS Data laoknowlerlse receipt of a oopy of this order all ear the Dena= hive h plairleel to me sod I agree v abide by chem. Instructed by: Supervising Moor op/07.02-0B Dttsadscit jest 7 of I Form Rorie; d 03.18-0I EFTA00231287 IAF =COMO AO: se swan 4 • 11. • • • • • JEFFREY EPSTEIN CASENS020EICF009381A.300043 ilar004.1 I •••••••••• intim I •••••••• WON •••••• COURT ORDERED PAYMENTS • ' .• • , • .• • • Cliltd(ALL THAT ARS ORDSREDt :. • " 'fl. — •:: . •• • • • EWA • • L......_ 'Total of Ann unt;ed In sentooco, outman to a. 773.083 (WONous% (S) or Chene316,f,s. . • .• • • • • • • .. .... sckt.tmly rroodsiod 5% sorrhusoisor if An wand (on first tine) pursuant to t 938,04,1% . ,...4. - . Ms . Crime nopplin Trutt Fund mount to t 93846(1), F.S. Unitarily mutt,' If a lire it Ittingggi• ...._ .. . .. .0 . : .... • :...... • ... to,....c. e.,.. . . . • . . . , - WaiiitOWSMEZIMAUSAgra • ilil52 Additional coat cost for felony offee lc puny ant a L 911,05(1)A, F,S. . , .• LS,11 Additional court con for inlidarneanor or Dir t traffic often pursuant toe. 931.05(1)(14 oe (a), F.S. ; 50.00 . Ctima Otroptandlon Trott Fund pumant a. 931.03(1), FS. . • : e s 50hQ County trims Preeentloo Food normal ma. 75.013(2) if . R L242.. Additional CootC onti Clearing Trial Fund ponwent m 8.01(1), FS. Pw month for each month of euptmlefon fee Trainlag Trott and Sureherta, PStstant t* 1 P41,439. F45. h7ANnATORY COW'S 7th SP .CTMC TYPES OP CASES p MU/ Poe CrIth Program TTRol Fond, pursuant to i. 931.085, P.S. for ny Natation of es. 784.01.1, 714:021, 714.03, 714.041, ' . • 784.045, 184,(45, 71447, 714.08, 784,081, 784.CC,714.083, 784.015, or 794.011. Fs. 0 ileAct Domestic Violin. Trarl Fund, purism' lo i.938.C8,F.S. tbr ny vlonel ons of sr 784,011, 784.021 784.01, 7191.041, 224.046, 134,04 744.07, 714.08,714.014 714,082,184.093, 714.095, 794.011, asay done of Domenic I/Inman doeorlbtd In B. . . . . . ri LW.' .• Certain Cr(ma Apart Minors, moat( IA s. 938.10(1), F.8. for axy vlectIona oft 784415, tenon 187, entry794, I. n6.03•A 800.04. 9heFttr 827, c 241 014 Cr 14 90.201, F.S. e $ 3.08 State Agents Lam Enforcement Radio Brum Treat Fond, punuent tot 3 /8.111(17). FS, for ply ylolbtlons otoffenba listed DUI Cant Cab, purses% to a. 938.07. FS. for any violations of u. 316.193 or 327.35, F.S. • let 311,17 inctudiog u. 316.1935. )16.027, 316.051, 877.1C ',chant-In 11. 314193,516.192, 316,067, 316.073(3), 316.545(I), orgy Odin offense In chapter 316 *Ida la olnellod as a omit*/ viola/los MANDATORY COURT COSTS AUTHORIZED BY LOCA I Ann NH Parrs t, narirrtrg LIM Criminal Junk. Is ha MiLl by Munleipalltie and Conn tin, punetoWs. 931.15, P.S. Sfla Additional tout ants for local requirement, and ether county fund programs puma ant to f. 939.195(1)(.), R.B. CE L192 Tun Coon ;taunt too. 938.10(2), P.S. DISCRETIONARY Pee mor0i doting the term of vitpervItion to the following dooproflt organhalloo established for the solo punnoo of atipplorrenting Cn rehabilltatlya mow of cho Dapattrient orCorreotIont. pummel 10 L 948.039(2), F,S.: Penile Defender A ppilnitloa Fee, If nxinvyloady oorecto5 or mem°, purmant to t 2742 end a. MLA P.8, Tank Deader Feel nod Cont, pursuant toe. 931.29, F.S. si deetr.ined locally. . Prootortionelnvattlgalve Coats, pursuant to L 938.27, P.S O LIM O LW SPIZ 0 Omen O other • sea ❑ 114.2 DISCRETIONARY COSTC Dna sPECTRIC TYPIS OP (1,48F,/ County Aland and Other Drug Abuts Trutt Food, portant to 8. 931.21 and L 938.33. F.B. for vloktIons of L SI 6.193, 0.156.011,s 634.015, or chapter 563, demo- 065, or chAptrs68, P.S. Ossining Trott Food of the FDLE, prim: to s. 918.2.5. P.S. Ito VatIont oft, 893.13 offenses * TOTAL S12,2A PAYMENT IS 70 BE MADE THROUGH AND PAYABLE TO:® Depantont of Corrodont or ❑ Cleric of Conti Of calkckd by the Drammen! of Owycliont, a sdrohatge era% wit be added to all payninu ordormi by the coon, pursuant to e, 945.31. KB.) ❑ Can Cau/FInes Waived O Coon Costwrinot to the amount or coverad to tiorramnIty nirYloo Leas O Con Cost:Macs la the IMMIX of Muted to cird: Jtelitmant =CRTC INSTRUCTIONS FOR PAYMENT; • . . 138.8e Lott Form Revised 03-18.48 EFTA00231288 Wq EFTA00231289 Cyr IN lE CIRCUIT COURT OF If IE FIFTEENTH Y • 1.1.OR I DA STATE OF FLORIDA CASE NO.: 2006CF009,134AXX DIVISON: - W" JEFFREY EPSTEIN, Defendant. 1 ro AG R Fn ORDER SEALING DOCUMENT IN COURT FILE THIS MATTER came before the Honorable 2008 Judge Deborah Dale Pucillo on June 30, during a plea conference in the above-referenced apprised case nu ber. The Court being fully in the circumstances, it is hereby: ORDERED CAC CNi AND ADJUDGED that thecument be sealed filed by the Defendant on July 2. 2008 by the Clerk in the court file. DONE AND ORDERED in chambers, West Palm Beach, Palm Beach County, Florida this a2 . day of July, 2008. • Copies forwarded to: Q ) /e 4S 400 BORAH DALE PUCILLO Circuit Court Judge Jock A. Goldberger. Esq. Counsel for the Defendant 230 West Australian Avenue South. Ste. 1400 Palm Beach. Florida 33401 Lanna Belohiavck. Esq. Assistant State Attorney interoffice) EFTA00231290 10 ri 1 I EFTA00231291 IN THE CIRCUIT COURT OF THE PFFPEENTH-jUDxeA-T IN AND FOR PALM BEACH COUNTY FLORIDA, CRIMINAL DIVISION STATE OF FLORIDA, vs. JEFFREY EPSTEIN, Defendant Case Nos.2006-CF9454 AXX 2008-9381CF AXX NONPARTY MOTION TO VACATE ORDER SEALING RECORDS AND UNSEAL RECORDS a nonparty, moves pursuant to the Rules of Judicial Administration Rule 2.420(d)(5) to vacate the order sealing records and unseal two documents in these files on the following grounds: 1. EW is a victim of sexual abuse by defendant who was convicted of procuring a person under .18 for prostitution and felony solicitation of prostitution. See attached judgments of conviction (Exhibit "A".) E.W. presently has a pending civil action in this court against defendant for damages. Case number 502008CA028058:OO:XMB AB. 2. On June 30, 2008 and August 25, 2008, this Court sealed two documents, a non-prosecution agreement and an addendum to non-prosecution agreement. See attached copies of envelopes containing the sealed documents and also an Agreed Order Scaling Document In Court File entered July 2, 2008 (Exhibit "B".) 3. The sealing of these documents was done without written motion required by Rule 2.420(d)(I) or notice to the public, the media, the record newspaper and the victims of defendant required by Rule 2.420(d)(2). The Agreed Order does not set forth the EFTA00231292 grounds set forth in Rule 2.420(d)(3). The clerk of court did not post a copy of the notice of the order as required by Rule 2.420(d)(4). 4. The sealing of these documents was also done contrary to the Administrative Orders of this Court, AO 2.104, 2.032, 2.303 and 11.046. 5. The request to seal the first document was made orally at the plea hearing on June 30, 2008. A copy of the relevant portion of the transcript is attached (see pages 38- 40) (Exhibit "C".) 6. It is against public policy for these documents to have been sealed and hidden from public scrutiny. As a member of the public, has a right to have these documents unsealed. Furthermore, these documents are relevant and material to E.W.'s civil action against defendant. As stated in the plea colloquy, they were an inducement for defendant to enter into his guilty pleas. They are proper objects of discovery. However, unless they are unsealed, E.W. is unable to obtain them or utilize them in her case. 7. Pursuant to Rule 2.420(dX5), the Court must hold a hearing on this motion in open court. WHEREFORE movant requests the Court vacate the order sealing records and unseal the two documents. CERTIFICATE OF SERVICE Y CERTIFY that a true and correct copy of the foregoing has been served via U.S. Mail and Facsmile this I Pday of May, 2009 to: Jack Man Goldberger, Esq., ---- Ahterbury Goldberger et al., 250 Australian Ave. South, Suite 1400, West Palm Beach, FL 33401. 2 EFTA00231293 ROMSTETtlitOSENFELDT AuL,Eit Attorneys for Plaintiff 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale. Florida 394 Telephone Telecopier Bradley J. Edwards William J. Berger EFTA00231294 • • •ora IX 7142 ivr CRIMINAL MI:HO:SOF el • AC r COL RT OF nIE FIFTEENTH JUDICIM. CIRC.( rr OP FLORIDA. IS AND FUR PALM REACH COIN FY rAAr hn OBIS NU 5019P WS XY STATR OF FLORIDA s. I PRORATION .5 24frty f/ 5 -I l/ EFENDANT 1 IOLATOR I I COMMUNITY CONTROL %IOLA FOR DA, OF IRTH RACE GENDER 11011111111MI111141111111111- CFR 20080267322 OR SK 22760 PG 1081 RECORDED 117/17/2008 08+32,30 Plan anon County, Florida Sharon R. Book, CLERK COMPTROLLE Pg 1.81, Ilpu) SOCIAL Sett erryl1l448ER JUDGMENT The above Defendant beinc.Frsonally before this Cowl it:Drew:en b Y Jr_ &C I &Ur famorneyi I I Hat ing been (tied and found guilty of /loving 4:ilkred a plea of guilty to 1 Having entered a plen of nolo the following crimetsk the following erlme(s): contendere in the following crime(!): COUNT LIMB Dl c1 (N . pk)t-ftultfr•, -79‘, OFFENSE 6 STAXL7E S.U ) siriR412. ) 1(2- DEOREEI 3or f I I I and no cause having been shown why Ow Defendant should not he &Judo:wed IT IS ORDERED THAT the D tendant Is heroh A DIVOICATEO GUILTVor the thine alines. and ha+mp been am toed or found pithy at or hating entered a plea of men ernorxh:n: it guilly.reganlless if adjudication. in mentos or inTemes Mann; towtimi battery ick :044 lewd and las:Isom candusi Oho/ murder (I - $20-11. aggravated battery ($ 734 045i. burglar) is. 310 02...aq:while I( 312 1330 or home touts. ei minier) I t 312 I 33i. nr :my; mac/ intinse ipecified in %eaten 943.323. the Jeten4sw .ball h fAl.rird to wilmot Slued lecirscii• and IT...II...tn.: ht -; •h.•.‘ 3 IT N ORDERED TR IT Anit I erA nn\ T IR: WIreeli SEN FliNi I he raurthsch:. •Ia$. and nithh.c14.• • p•wro it n(••••ctethe .1. b• .irl• •• 'la ST11PI) I I Piowitonnediw I I 5' ...II I:PAY Ihe • cat'? •-• n• a • 1 \iv ir creti--tnribtatt•iffrnir seNiesca DEFERRED ,a rant trt aernaw I ; hx•els) Jaen mown, in of •eni...r.c;a:ul ••• • •••• • • r'a Dn..? 4.0.:: ore: 4" Cl ....• 4 1.:•4.1.4''• :.4:11: $..igyea: n 4:::: . 1.../itsre .1 14/ 1:::•••.; • • he J Arp,,ai..,,, - , en 4 nt I • .4. ...d...er :rt, 44:6 • I • ...a ..): ."1 Jai: • :::::r..: • • i:To.c.frr pre1:icor.....aSwe4;.:, ..- • • tt-• ...1..J'... f 1:. \ P fr.:, 4:!••:atin 4.4a' • :‘ i• NI i' .• • a :1".' 7::: 1- i.. ' 4 e • ..f; wn •wti :n .../a-rrnot ..rr...., a".....: esrtt:t .x Mc Sw(i-.;;:: I In .; it rib-1%( c 14.1Sf• Li.,e_ l? )VI/. lithilfil •O7e ir• ;is Ptflly....14 . -.in l•••• 5 'I . . . N .% /I 6-'Ct tet.t.• MI in IN wr R HOW EFTA00231295 63role 7 RIMINAL DIVISION OF I t cocer De me c-f FIFITENTH CIRCtIrf OP FLORIDA. IN ASO FOR PALM BEACH coml . CASE NO OUTS Nl. STNCF. OF FLORIDA le ty I erkirn !WES DANT commesery CONTROL VIOLATOR I I PROBATION VIOLATOR CFN 20060267252 OR BK 22760 PO 0563 RECORDED 07/17/2618 98:06142 Pala Beach County, Florida Sharon R. Elock,CLERK & COMPTROLLER Pg 0565; (leg) DA'l E OF TH RACE GENDER SOCIAL SECURITY NUM BER JUDGMENT The above Defendant. being personally before this Court represented by I J Haling been tried and found guilty of the following eri nets): r>t. Having entered o plea of gul I I l iy to the following erinic(H: Outorne / ng entered a plea of solo contendere to the feliowl ng cri roofs): COUNT I 1-5R IN! Ere P74Y be i / / en until OFFENSE STATUTE NUNIBER(S) DECREE A. and Mt ennui having been shown why the Defendant should nin he adjudicated Wu. I7IS ORDERBD ThIAT the Defendant if birch • ADJUDICATED GUILTY of the abuse admen.. I I and hasIng ken cow sired or found gwl ty or. Of ha% i II; entered a Piet' conionjero oar siiiiiy.rry njirmor ,j,jjodirui,,,,,. to mempi s nr (strews relating to testi battery tdt 794:. Intl and !MCI% Inn% Clinaiti (ch. Mt. or murder is 732 04t. eggrasuteJ /sentry Is :84 0•15i. burgh's) is SID tr:o. catjaiking a. SI2.ISSI. or None ins dwin tither) it S 31i. or an) other offenae :peel fled in seism 943.37S. the Jefontlani 'hall mooed In ahnid Mood yroolnioni an.l yonl s.oh: Iwo.; Jul.% n rr oeneeen TIIAT A I)II l)le A nos ;tit r111t win11114f 41 • • ' • .1 • • • I It \ CH STA THU I I In: t own brioh) on). and oinkim, nrpotton 'eaten:c.o.:a c•iunti• pis.e. the thifethldni igl I I Pri 'Noon sostor I I C•011311011S i s•stsibli Whitt Uhl ,I•ren new ' 4.1P0Ihys r • "7"‘. .s% Urn seratite ,'alert SENTliNelf DERRNED I J it: Cauntigth) Jefal unrosittrin of •ont:rce mut th': :n.-or as ()roar J• h• : I.' sect San t•.• Ip!-; :••re(:: t. . • I "rU IA::••alt 4a) . to!!oto'iv Ow It Jane • •:teee.. •titn.ro•:J in-rasa:nits t•orskted IVCV4Iri t:• Arabi anon Tty nz,,, Ion e 1‘"trori 1:1 iniann 'aid 4 'Val Ath. vspst•-t 441 to `hare tiro ▪ •ritarzt,•!.• • ' 13- " A SI) URI I fp:0 r, c, • thn. a 3 p e.; •, I Mel If rill RT1. Ilia EFTA00231296 IN THE CIRCUIT COURT OF THE FIFTED PALM BEACH COUNTY STATE OF FLORIDA -5 ,2 F ; (1. ON -7.111 2-1%00? CASE NO. a 1.) (0 C DOCI S" DIVISION IA) p Psychiatric (Medical, etc.) Report dated from Presencence Investigation Report dated from zi other Non - Prosen..,1/41 lireement￾SEALED IN COURT FILE, NOT.TO BE OPENED WITHOUT ORDER OF COURT I EXIMIT B EFTA00231297 IN THE CIRCUIT COURT OF THE FIFTEEN. J.UOICIA,GEIGUIT-E,FLORIORrIN-ANITF, PALM BEACH COUNTY • CASE NO. a) C, OO 1 4-)<, ) STATE OF FLORIDA vs. DIVISION /op U Psychiatric (Medical, etc.) Report dated From Prosoritence Ihvestfgation Report dated from ,CAN F. AUG 3 0 2008 O,„„ AddemA. 4, 4, 440 SEALED IN COURT FILE, NOT TO BE OPENED WITHOUT ORDER OF COURT EFTA00231298 (2- IN PIE CIRCUIT COURT OF PIE FIFTEENTH JUDICI, laRCULT-- - lii.AILD-FLOR-Ptkerl-EtErATTI F ORI DA STATE OF FLORIDA CASE NO.: 2006CF009454AXX DIVISON: "W" JEFFREY EPSTEIN, Defendant. AG EFn ORDER SEALING DOCUMENT IN COURT FILE THIS MATTER came before the Honorable Judge Deborah Dale Pucillo on June 30, 2008 during a plea conference in the above-referenced case nu ber. The Court being fully apprised in the circumstances, it is hereby: a fiadvi ORDERED AND ADJUDGED that thndocument filed by the Defendant on July 2, 2008 be sealed by the Clerk in the court file. DONE AND ORDERED in chambers, West Palm Beach, Palm Beach County, Florida this oC7 day of July, 2008. gkes BORAH DALE PUCILLO Circuit Court Judge Copies fonsarded to: Jack A. Goldberger. Esq. Counsel fur the Defendant 250 Australian Avenue South. Ste. 1400 West Palm Beach. Florida 33401 - Lanna Belohlavek. Esq. Assistant Stale Attorney intern nice ) • - -10131- EFTA00231299 1 • 1 IN THE CIRCUIT COURT OF THE FIFTEENTH 2 JUDICIAL CIRCUIT 4 6 7 8 9 10 11 PRESIDING: 12 APPEARANCES: IN AND FOR STATE OF FLORIDA l __F_LX:LP2-12A gi tt BEACH COON DIVISION ) ) v8 ) CASE NO. 06 CF9454AMB yV JEFFREY ) 08 9381CFAM8 EPSTEIN Defendant. ) ) ) 53 ..."°14 • El i tr. PLEA CONFERENCE • HONORABLE DEBORAH DALE FOCI L r IN) 4-14 N, r^r-) 13 ON BEHALF OP THE STATE: BARRY E. KRISCHER, 14 ESQUIRE State Attorney 15 401 North Dixie Highway West Palm Beach, Florida 33401 By: LANNA BELOHLAVEK, 16 ESQUIRE Assistant State Attorney 17 ON BEHALF OF THE DEFENDANT: ATTERBURY, 18 GOLDBERGER & WEISS,P.A. 250 Australian Avenue South Suite 1400 19 West Palm Beach, Florida 33401 By: JACK GOLDBERGER, 20 ESQUIRE 21 22 23 24 25 ORIGINAL June 30, 2008 Palm Beach County Courthouse West Palm Beach, Florida 33401 Beginning at 8:40 o'clock, a.m. ..... ....... EXHIBIT PORTER PHYLLIS A. DAAES, I EFTA00231300 „ . • 38 1 on that, Your Honor? 2 THE COURT: It is 3 recorded. 4 MR. GOLDBERGER: That's fine. 5 THE COURT: Defendant needs to 6 approach as well. 7 (Whereupon, there was a conference at 8 the bench.) 9 MR. GOLDBERGER; The reason why I 10 asked to come sidebar, there is a 11 nonprosecution agreement with the United 12 States Attorney's office that triggers as a 13 result of this plea agreement. In other 14 words, they have signed off and said they 15 will not prosecute Mr. Epstein in the 26 Southern District of Florida for. any 17 offense upon his successful taking of this 18 plea today. That is a confidential 19 document that the parties have agreed to. 20 Just in an abundance of caution, I wanted 21 to tell the court. 22 THE COURT: I understand, that would 23 siS9 be invalidated should be violate his 24 community control? 25 MR. GOLDBERGER: Absolutely. That PHYLLIS A. DANES, OFFICIAL COURT REPORTER EFTA00231301 • 1 2 4 5 6 Mr. Epstein, your attorney has 7 told me that in addition to everything, we 8 talked about another Inducement, shall we 9 say, to your taking this plea is that the 10 U.S. Attorney for the Southern District of 11 the State of Florida, federal prosecutor, 12 has agreed to a nonprosecution agreement 13 with you, meaning that if you successfully 14 complete probation and do everything you're 15 supposed to, they have, have agreed not to 16 prosecute you federally, did you understand 17 that? 18 THE. DEFENDANT: Yes, ma'am. 19 THE COURT: And I would view that as 20 a significant inducement in accepting this 21 plea. 1-) 0 nonprosecution agreement -- Out. MS. BELOHLAVEK: 22 39 THE COURT: Mr. Epstein needs to come closer. MS. BELOHLAVEK: They are actually in 23 court here today,_-alsoc 24 THE COURT: Okay. 25 MR. GOLDBERGER: And the plea PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00231302 6- UP r ) , 1 agreement very carefully spelled out if 40 2 there was rh the-e-vatrirTroTiate this 3 agreement, II we are well aware of it. 4 THE COURT: • Okay. I would request 5 that a sealed copy of that -- Mr. Epstein 6 7 a 9 has signed that document? MR. GOLDBERGER: Yes, I would like to seal the copy. THE COURT: I want a sealed copy of 10 that filed in this case. That is the only 11 other condition of the agreement that is 12 influencing this defendant to make this 13 decision? 14 MR. GOLDBERGER: Absolutely, I think 15 that's the right idea. 16 (Return to open court.) 17 THE COURT: Mr. Epstein, is there 18 anything else? 19 THE DEFENDANT: No, ma'am. 20 THE COURT: Because I don't take. 21 these pleas unless they are freely and 22 voluntarily made. 23 THE DEFENDANT: -I—understa-nA—that. 24 THE COURT: I also don't want 25 . somebody or anybody coming back.a_, PHYLLIS A. Wiese OFF/CIAL COURT REPORTER. EFTA00231303 ••lik lbsi EFTA00231304 T-988 P003/007 F-845 . • • • •••1::•• ' '.••• C. • I'. 3.. '. 1.; I 4. i r FT4tiallicitS & L0CIGEBB • • • - = N THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL mean I • IN ANT) FOR PAL* BEACH COUNTY, FORMA • CRIMINAL DIVISION ' .• ! • . e k regli or runutpt: vs..: • , y • JEFFRI3YEPFTEHI ! . . • • = • ; 41 )0ticiirci rs MOTION • OD PETTTION FOR ACCESS' '41 ; • • it'. • Case Nos.: 200(1-7!)454- . • : 2007980- : • it'll' 1 • I • %I: 1 19 • L i ; : c ; v.: I I--' rysi:yriptpera, Ile., MI The Palm Beach Past citev clstn) Moves to a • ,I e. ; I t..l. n . . ling :l in this itOt API the led se of seeking access to'dOonments filed under seal. • I 1 4, • • The do nsl directly to the Def dent's guilty plea and viaitenee, Thus, the sealed • • ' : , ' i document* go to die:heart of the disposition of this case. But in nxi that Judge Pucillo • i . [ ; .1.:. : .:'a i seal "him 'document& ' . h. epatitis failed to ywitb Florida's ststoiSocedural and substantive ..: . • i.; • • : • .1.: , . i i requir ' erns for staIing,ludicial records. addition, continued aiii of these documents is ,• P ...9L.1. • -.'9., 1. •; • ' I 1!I pointless, because these documents have heen discussed type . .. ' ellqj count records, For all 'is' i ' i ..;,. ••!. of thede reasons, the documents must be a : I 11. • . , • • • • I • ;This tit :day news • L • ' • oil • . I ; ii I fi3iii.11t er InitS rea •• tbiPP??10.01reen" i ii : ! ; :: : ' • l' ' • ...., I ),:. i ,AAtienemper: or me news a, the Post has a right to intervene in criminal , I i is fOr the hotbed punxise of seeking access to proceedings 04 records. gm Barron v • '2 1 • . • I : . • ! ' ' Florida Freedom Neivspatates? Inca 531 Sc. 2d 113,118 (Fla. 1!88Vners media have standing , L. i. : • . 1 ' • • l i to challenge any closure iirdei); atMentAjigin,LL,ff ian 3i c dgiV.6 89. 2d 1,17 (Fla. 1982) '''I ' ' ' • 1 ,i':: i, I I (news Media must b* givin an opponunIty to be heard on question,f 4 • ). I • . • • . i , 1 i I • . • . 1 ' ; 1 I • ed. As grounds tit chotion, the Post states: • lti er that has covered this ' end related : , • i li d en concerning tiles, el me Post relies upon ' . • • • I .. • . f • .„ • k , • ; 1 • • rds and judicial records; i 7.1 :1, i EFTA00231305 ' 06-81-'09 15:34 FliCtl-IIIRSS 8 IXICES3 8139843670 . la ; P024/037 F—815 •••• l e a . : 3 i • • r . . I I • :•t • I ' IL • I •• .1 • : • ' I • • . . . • II. . 1 1 I a . • :14 : I f I • ."'/ II . 1: !PI I : •• • la I 'II • • • . • Tbe:pertiadar.documents er soal in this cave are prosecution agreement • lin J'f • z ' 1 i• '<ticketed . i" • " • • 04 • • • • • r.; . . .. a... • 0 that yi i. . oaddly i 2,2 8., and anAddendum docketed on Augtisi 25, 2008.. Together, pei .I ,11011 eats' iiperentlyie,saict any fec erg prosecution of the Defe jThThvdeit for offenses related • ••.• .... . I ?ol i : • It. • : ! . ......; • I 3 . % i. 1 • : . . kin ..!; l i to thecetanet to which lie pleaded guilty in this case. Judge ?ticille'isecipied the agreement for — !jag ?• • 7 • i : •• : • .' I •• • • . .1; .. f • :.: • • • ; filing during a bench conference on June 30, 2008. The agreement,4tidge isticillo Found, was "a . id:. i i';' : , I • ' • ; • • I.:I :. ; • '.. I .signitidancinducerhein lit licceptptg !his gilea." Such agreement! and ielated docutkents typically • I . • t • • , I .. . I 1 . • ; t I • i.._ • , .,• .- I ; I • I ,i,.. :. • i are pabluo record. Ehigg'9regdnian l Publishing Co. v, United States tifstri4 tonne 920 F.24 1462, ilj ; • ' ; I 14634O; li•96)("e.lea agreements hale typically been op entoirlutilion); united States v., 1.14 i; 1. ..i • i . : ! i..• : 7 - - i .. ..." ...• • : i KOWA, 7.96 tli 100, j390.91 (11th C't . 1986) (documents tel • aigi. 63 defendant is s change • of •,,., • ti , :, •,, plea and sentencing Gould be: lieldeollonly.0 n finding of a cempellini Intefreat that justified • , • it,1 1,'. . : • ' •• 1../ . !I cr. ; I &did 'if public acOekS).• '-;' : ''. I ' ' • ' I ::-, i ; • . ' ; :II I in I: ol g : art I. : tit iiiitrIpride.ecinstituiicin thed judicial britnoli rcliprils i genekally mr„tat be ill' • '' • . . .I . • • - ' :4 :1 • : k., • :; •': ifs! . 0.1bile i!?if.triCIIi. 09i:igt; /, f (a), Fla. Cana,. Closure of snit mot-dr is allowed ' Si... . i • '''•i1. ••••.: ;.] . ..;: onlyiunilet narrowolforidottinoos; such as -to "prevent a sedous anti:iiiirnitient : •• E . • .4 ;1 ' • • '' t , impardel Ind cirlerliatiMinistrtitIon of Judea," or to protect a comp.elliroxgovernmental interest. • , • i 1 .; • • : • : • , Sig Milt. Ind. Admin.' 2.412Q(oX9)(A). Additionally, closure IlmittbP . .: • • ; • : • • thanneceseary to acooniphsh dte desired purpose, and is lawflal: . • • g • c • i • mess will acicon‘lisii time pumps,. I ' •• • • 426 .2dat3.: !•I; • , I • I.' 5.' .1 .014(.4siii14/!bse4tvere 1 ' • :. ' j • I } wititoutaityorlhaneidaitafindinge. Ra ; 1 " sealed • ton :it 3 :014 Thereate., •. ' : 'I; • 1 4 dc*,3afideathd •ro • ,f • • ' is ' I • ihei hi; alid no biped,. l ess refrictive : • . Fla. R. Jud. Admin. O(o)(9)(8) (C): Lis; •• ; . : • r • 1 1 . 1 on agreement tairOntk-:,thri:eiddes;dnits wegolgeeled • , it appears froni the 646:11 documents i "i'tre represented to.Judg :Nalco that the non-. i eat" Plea Conference Transeiript page 38 2 : :it!: I .o. I " • lc.: • ; EFTA00231306 ▪ ili• t: 86-01-'89 15:34 FROC-THOMAS & LCCICERO AIM 1-488 P205/007 F-845 WO • 't • • :.; , e r • it 'e: ! I : (June 36, 2003). Such a representation faile l well short of demonstraWitTnwe3thg Ji inteiest a • • • • genulneneeeasity, nano* tailoring, and that no less restrictive mea w 1 anf:ft e. t1 I • Jdi). ; •• • C .," ollit•oVentlY, Was 'rapine* an ought to be sct 15; • • t • , . . • • • i its aildithiP,It this time goo cause exists for Unseal hfssil ocuments beca:use of • :f !::' ?• I; : ; i . • )'' ; • ; lie!! ; , • 1• stgrd . •Shop • the Defend t pleaded guilty to 'p:Ali a minor for I.' • • itgri;i at kast 2 civil lawsuits that r ges in this case — girls to e hiä home for, 8åx 1 adr' js."I At leas t • • I 4. (‘ intuit, olte of the Defendant's a4;å has alleged that : . 11 • • • :uloni,faye4 lo Conpultvdth • hkr regarding the diapesitleti ofpossible charges againtreihe Defendan.2 'State prosecutors 41so have been criticized:kite Palm Beach Police . , . . . • . : ill •:' Lfr ' • Chief,* 'faulted the Slate Altorper.s hailing of these cases as uldighty;uttusual" and called fbr . II i • 1 I:i • vitt i •;'• ' • '' ; , ' polieutoksr-Ler. yi of le publk . mid celseltut. . I —, 1: 11: :::::1;i • .. , • .. : : i • ' i — the Stalk Attorney's ilisquOlci,tiont Co equently, this cais and; ti ctieular ly tlie Defendant's .5, t .•I ; i f i. •.:., : • '4:.; ..,.. i;:. ; ' ; ..1 2 ' The Detindaida trod-prose ion agreement 'With' . proseeu also 1was I '',' Pi i''.i '.:1:: ' -I • i I 1,?: l • to Jags4' Pileill4. 'As alto holed.' the NS* 2008 plies osat ' vim? (the. . I ' .• I. •'' 1 :I:. ,' ' • I • ; . 1 inctovisnent In #41142/"?. Flea; ' • I i : /: ' I I. reniiiimi • gunglal, , IIIIIt of to OW • f..... I I with sentencing.OW §acal401 Herald Tribune: Div, , 3 ge4 " MK 'ithiti ; ;!•••, till .;.‘ I I I . .11. :i I. ' • • . :. • i See: disii.:Vie.v.:Eititielh, dam N . 08-80069 (S.D. ii'lti. 26,08); Doe No. 2 v. patchy . , CasoNo. 08-80119 (SD..Fla. 2008): E ' Case NO:08-8.0232 (S.D. Fla. 2008); • :, r . • D0öNbi. 4. v. %stein 08-80380 (S,D. Fla. 2008); Doe No. p y, Bostelni Case No. 08- . • i ' 80381 <S.D. Fla. 2008); v. Epstein, Case No. 08-80811 (S.D ,Fla 2008); Doc v. Enst_0062, I. •fIi : J ' Culp no. 08;80893 (3.D.i.Fla. 2008); lätehiniankin,caa 1,2140,993,,PP.,:n t,2,,„:29 •• 'i ; 4 • Doe Md. 6 lei EP•tat Case — - bas 09-80591 (SDI y442009); Abel N•• 102 v. 14a. 08-80994 (S.D. Fla, 2008); Poe II . °stew, yes o isiO. UnV 1 . . :'« 1 (S.D. Fla. 2009); Doh No. 101..i. Epstein., .e No. 4 : . Bostidn‘ Casie No. 0? N 8 v Enstenii,disc No. 09-80802 (S.D. -80656 (831Fla. "w) • ';' • i D" c" ' 1--- ; i t ' i i • • Fla.. ). ' : -. i . . I :• i• .:11 • • . L :. ; :2See fin ii.kh isi4stepra.ith_os acr;36 (ss. Pk iolia). 'i. }" :1: I ' ..f.: - . : • . 14 ?ii 1 • , • 3 lird • . . • • • ' ' '• A ; • i • I:: ' I .. • • : • i • i• I I .i a 1. • • il • : I • ▪ .1. • • 1 ' i I.% 14 ! .: 4 C ;.. • :i P r: I :1! I . .;C 4 g p r i e.: : I EFTA00231307 I: -Ti '6 -Bilald'i5:84 in4il-11i 511% & LOCICERb 8139843070 1 1 1 ' T- 88 PO?306/027 F-845 P p . ,'. hi, • :Ir ' ::' • . :iii 1 : , : • . ti • I • ir :1: # !! ' ; 1. f. • r ': ! ' ro . ..iit r :,.... of tits New York Times Co. v. ifoltrendori 507 So. 2d 667.668 (Fla. 12,4 D.CA 1907) ("While a : i. .: : !: 1 Judge may Impose whatever legal sentence be chooses, if such sentecee # 4ased op a tangible i • • . • r , 1 , - -r1,.. !: . I •• . proceeding or 4oettment, i is withinthe pure domain unless outermaarivileged."). In this : ' I :1 I I 4 • • caseinn inierestjuatiliee dontlatied sealing. of those "significanr.dernents that fudge Poen) - I ,.. , ..: . : • i: • coneid in m00,4.1116 plea sentencing the Defendant. '4 41 cif any sluch :. . • ' : r ; i • • • • • ; ; compelling interest •Jair.wreli as the parties failure to comply:with dig dards fOr sealing I - , documen# initialli-Iprovicio good cause i'r unsealing the dOcum 1 • I : ' time; I : t' • • II , i - • ri: I Pinal.7, oo@htue.Oclrure of these documentsis po'. , becauselimany portions ' ; •• ..., I, r • i % irt , I ' of th4 ' Id '44c44i already htnie beell made public. Forexamkle t!,•co , papers quoti;Ig i ` : 7 ' :. ". • '7 •• .L. .• I ' ( ..: - 4: ' ' i Pt ; r ; ; 1. ex o. ' cif the agrereinent haVe been madeipublic in related federaiiio0Wings.' 'As the Florida ..: • • ' t ? iF.:. , . • Suprenie Conn has rioted, "there would belittle justification for 010,04 'a pretrial hearing in I:1 je ; . prevent a '. I td only the disclosore'of detifils which had already*" Pupublicized: publicized:lthe ! 426 'Li order t . ; .. z• - I; i. c. 1 :: So. 2d t 8.'. Similarly; In tin:tear," the Intent that information avid, has been made 'public, ' F 'i l : i' . ' : ,H.• i LI — i . .- • : • • • ••• •• • • • •• • • : - - — r:” ! . : ' • , oontimted plostny is pp see S. therefor, unconstitutional. , - . . . . . . i : ,... 1 •4.1ii: • i • r I :" ! • 9. - •The Poi has no. objection l!' 1 '• . I • • I I • :. ..• • • If: ' • '-'•' b the SalecerlailmJnis. In adci(tioh, Ins° ; ' I ; q : •• V: thr • I 1*,11 CI rtart I; . :• • 11 thqt; - cloilarlia' ''' • I I ' 5' . : II IA ! : I is! :::# • • • .;. •. . • ., :.ai I ' : • a ) • 2i i .: Irth I :i -.• Hi I . I .•e. I. j *; I I . ,.. 1 ".• I re ! ! I. t r • • • .i " See, e.g. "Defendants Jag figiaa Caw Nth 00-808I r • : . : 4 : . r i • I I. ' . the redaction-ofiictimsSres (if art) that appear •elkhomey seek continued of t int Ir order to assess , tc I•iEfl1 -VI I • - , as the Defendant the documerits in • • end Sarah Kdka i'llod°° for Stay," C.M.A. v. ••• I • • 1 EFTA00231308 4. 06-21-'09 15:34 FRQM-THalAS & LOCI ...F. ' . 4 • ' • ! gl.. itii • • • •i WHERniXtV, the Post resPectfiti,y requests that this Court unseal the no. -prosecution . . . . • • .. , • . . i. • i . . • 71i.: 11.. ' i .... ! •• et I .• • • li 3.,! myisideridum'and grantthe Pot such other relief as the Court deems roper. : . i .. 1 • •'. • • . • - • I ' ,.i. • . • . ! . • r .. • i" : . : . • : 8 : I . I • ! i: • • • • i hi I . • a. • . • • II •• • • . I f ' ' • • . . , ' t I I • I ! ; • I • i: . . ' i •• I .• e. . ; • • • I. :I oi • I I • 4I • i • 4 . i I 8139843078 t• • • T-138 P9i7/007 F-.845 • • • ill; 1 I r. Respeotfthy submitted, THOMAS, LOCI131th t BRALOW PL. . eth At: O1O1 canna K. iSh .. Florida Bar No.: . 51;4462 James B. Lake. 'i!:y 1 i .. Florida Bar No.; 23477 101 N. . Third Ay.eWu , 7itn 500 I Fort Laud Telephone:, c ; • • : Facsimile: : • • • • •I :, $. . ( • I i •1 I • • 4111• . 'IL 1,;!* • , 1• P • • • •`; •. ; l• Attorneysf i or la .911 fli each post r i 1 i.lpi.• .i h :ii : . a., .r, ..,. , hys 1 . I il l I • III:11 .: i ll J. " I 'HI • %.; HI . ' ,.. 1 ; !• • : . r I.c 2) • I 1 i 1 I i If I . 44'4 I , r;. • ; .I I:: • •• ; e., r ; . .017 . ; I I: I • • l i r I a; . : r . I nERBBY dE1ITIFY that a true and correct copy of the foiegoing has been flunishad '. :II I. . , • I. .., ! ' .,. : ' " 17 t 'via fet‘mileabe U.S. Mail to:. R. Alexander Acosta; United StatcrAttoracY'i Office _Southern qh . . . .. •••• : i Thstn • . .. ; . • . :. .., '.' 1• : . ci, 500 S. Australian Ave., Ste. 400, crest Palm Beach, FL334?1(flix:a• i • . :t • • : i iiI:I Michael 111e.Anntre 1 ,)tsq4 and Judith Ste/season Arco, Erk, StatebBilnicrs Office - Walt . _ • jo : i 1 _ . • • • • ! ; i Palm Beach, 401 Notch Dixie Highway, West Pahnl3each, EL 3.340 . Ow.: ; I . • i • : • ; .141 ,.0 1 ., - ' . . i I: ! . - . : • . • - .•:il : r !, .!• . I Alan qoldberger; EN:, Atterbuty Goldberger, et al, 250 S.:AnStrialitair;Aire., Ste; 1400, West IN; ... ': ' Palm Beach, FL 33401..(4a: . ); and Bradley .11.. Ed4cliiliq. and, WIWate J. . .11 • L '; 4 i $ .. Berger, Esq., Rothstn ieRosenfeldt Adler 40 East Las Olen 131 Blvd. .it'ulie ) .650, PortPortLauderdale, : • • .. i i 040., • r. . . • 1 1 O .. l: ::41 l• FL 114(fax! on this 1st y °flute, 2009.! ;4: $ j , ii iii I I .• ii I: t . I , • )hI l .i . i p i $: I• •$ 11 :1 " b • 1'j ..11: :•' i ' • :1; li • i 'I ' 1 • . • : • 1 . ilt•ef :f. : ; • ,t • : i " • • I ll • lit : • . I. I : p-'/ : [ii . • . • *i . I ' I I. ' i. ! I . I : ' • I • • 4: • • • • it r. . . . • :1 1 I. EFTA00231309 SLEGAL RECYCLED PAPER tl TO REORDER CALL 9546/69399 ND EFTA00231310 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 2006CF009454AXX, 2008CF009381AXX STATE, vs. EPSTEIN, JEFFREY E, Defendant. MOTION TO INTERVENE AND SUPPORTING MEMORANDUM OF LAW COMES NOW, Applicant, M. and requests this Court, pursuant to Florida Rule of Civil Procedure 1.230, for leave to intervene as a party in Mr. Epstein's criminal matter for the following reasons: 1. Applicant's intervention is in subordination to, and in recognition of, the propriety of the main proceeding. 2. Applicant stands to either gain or lose by the court's direct legal operation and effect of judgment in the pending matter. 3. Applicant is not injecting a new issue into the pending matter. 4. Applicant's motion to intervene is timely. EFTA00231311 5. Defense counsel, Robert Critton, Jr. in the civil matter, does not object to Applicant's motion, but Plaintiff's counsel has not heard back from Defendant Epstein's criminal counsel, Jack Goldberger as to whether he opposes this motion. MEMORANDUM OF LAW Anyone claiming an interest in pending litigation may at any time be permitted to assert a right by intervention, but the intervention shall be in subordination to, and in recognition of, the propriety of the main proceeding, unless otherwise ordered by the court in its discretion. Fla.R.Civ.P. 1.230. "A person seeking leave to intervene must claim an interest of such a direct and immediate character that the intervenor will either gain or lose by the direct legal operation and effect of the judgment." Litvak v. Scylla Properties. LLC, 946 M.2d 1165, 1172 (Fla. 5th DCA 2006). Additionally, "an intervenor my not inject a new issue into the case." Environmental Confederation of Southwest Florida. Inc.. v. IMC Phosphates. Inc., 857 ..2d 207, 211 (Fla.ln DCA 2003). "An intervention is thus only appropriate where the issue the intervenor raises are related to the case being litigated." Racina Properties. L.P.. v. Baldwin, 885 .1.2c1881, 883 (FM. 3"1 DCA 2004). Once the trial court determines that the intervenor's interest is sufficient, it exercises its discretion to determine whether to permit intervention. Union Cent. Life Ins. Co. v, Carlisle, 593 M.2d 505, 507 (Fla. 1992). "In deciding this question the court should consider a number of factors, including the derivation of the interest, any pertinent contractual language, the size of the interest, the potential for conflicts or new issues, and any other relevant circumstance." Id. Finally, an intervention is generally considered timely if it is made before a final decree has been entered. See Technical Chemicals And Products, Inc.. v. Porchester Holdings. Inc, 748 M.2d 1090, 1091 (Ha. 4th DCA 2000). Page of 4 2 EFTA00231312 Applicant's proposed intervention is subordinate and in recognition of the propriety of the main proceeding. Additionally, Applicant will not inject any new issue into Mr. Epstein's criminal case. In fact, Applicant's intervention is for the limited purpose of joining already intervening parties M." and "the Palm Beach Post" in their arguments regarding the sealed Federal non-prosecution agreement in Mr. Epstein's criminal file. Finally, Applicant's interest is of such a direct and immediate character that the Applicant stands to either gain or lose by the court's judgment in the pending matter. The Applicant currently has a civil complaint against Mr. Epstien regarding allegations similar to those in this pending criminal mater. The sealed document may contain discoverable information or may lead to the discovery of new relevant information. ate Fla.R.Civ.P. I.280(b)(1). Additionally, the document may contain valuable impeachment information that the Applicant would intend to use if the Applicant's civil case proceeded to trial. WHEREFORE, Applicant, ■., respectfully requests the Court grant M.'s motion to intervene in the pending criminal matter. Page of 4 3 EFTA00231313 CERTIFICATE OF SERVICE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by U. S. Mail, postage prepaid, this EL day ofi02, , 31504 to Jack A. Goldberger, Esq., 250 Australian Avenue, Suite 1400, West Palm Beach, FL 334101; Bruce E. Reinhart, Esq., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401; Robert D. Critton, Jr., Michael J. Pike, 515 North Flagler Drive, West Palm Beach, FL 33401. LE0P0LD—KUVIN, P.A. 2925 PGA Boulevard Suite 200 ens, FL T. KUVIN, Esq. Florida ar No.: 089737 Prige of 4 4 EFTA00231314 RECYCLED PAPER TO REORDER CALL 954416.9399 I--` Co EFTA00231315 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 2008CF009381A DIVISION W STATE OF FLORIDA vs. JEFFREY EPSTEIN, Defendant. MOTION TO MAKE COURT RECORDS CONFIDENTIAL Comes now the Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys, pursuant to Florida Rule of Judicial Administration 2.420 and the Administrative Orders of this Court , specifically AO 2.303 and moves this Court to treat as confidential the following records. A. A document referred to as "Non-Prosecution Agreement" filed under seal in the court file on July 2, 2008. B. A document referred to as "The Addendum to the Non-Prosecution Agreement" filed under seal in the court file on August 25, 2008. 1. The above referenced documents were Ordered Sealed at a hearing held before the Honorable Judge Deborah Dale Pucillo on June 30, 2008. 2. A Motion to Vacate Order Sealing Records and Unseal Records was filed by Non-Party EW on or about May 15, 2009. 3. A Motion to Intervene and Petition for Access was filed by Non-party Palm Beach Post on June 1, 2009. 4. This Court granted Non-Party M. and Palm Bea la Motion to Intervene on June 10, 2009 but took no immediate action on Motion to Vacate Order Sealing Records and Unsealing Records or on Pam Beach Posts Petition For Access, pending a further hearing— EFTA00231316 5.. The documents should remain confidential for the following reasons: a. To prevent a serious Imminent threat to the fair, impartial, and orderly administration of justice. b. To protect a compelling government interest. c. To avoid substantial injury to Innocent third parties. d. To avoid substantial injury to a party by disclosure of matters protected by a common law and privacy right, not generally Inherent in these specific type of proceedings, sought to be closed. WHEREFORE, Defendant moves this Honorable Court to enter an Order keeping the above referenced records confidential, and maintaining them under seal. I HEREBY CERTIFY that this motion is made in good ■ and supported by a sound and factual legal basis. CK A. GOLDBERGER, ESQ. WITNESS my hand and seal in the County and State last aforesaid this 11 day of June, 2009. Notary Public State of Fl My Commission Expires EFTA00231317 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via a U.S. Mail; 0 Facsimile; o Overnight Delivery to R. Alexander Acosta, United States Attorney's Office-Southern District, 500 S. Australian Ave., West Palm Beach, FL 33401, Judith Stevenson Areo, Esq., State Attorney's Office￾West Palm Beach, 401 North Dixie Highway, West Palm Beach, FL 33401, William J Berger, Esq., ROTHSTEIN ROSENFELDT ADLER, 401 East Las Olas Blvd., Suite 1650, Fort Lauderdale, FL 33394; Bradley J. Edwards, Esq., ROTHSTEIN ROSENFELDT ADLER, 401 East Las Olas Blvd., Suite 1850, Fort Lauderdale, FL 33394; Deanna K. Shullman, 400 North Drive, Suite 1100, P.O.Box 2602 (33601) Tampa, FL 33602, Robert D. Clifton, BURMAN, CRITTON, LUTTIER, & COLEMAN, 515 N. Flagler Dr. , West Palm Beach, Florida 33401. this 11 day of June, 2009. BURMAN, CRITT IER & COLEMAN ATTERBURY, GOLDBERGER & 515 N. Flagler Dr. WEISS, P.A. West Palm Beach, on a 3401 250 Australian Avenue South Suite 1400 West Palm Beach, Florida 33401 pc￾ERT D. CRITTON, ESQ. orlda Bar No.224162 CK A. GOLDBERGER, ESQ brida Bar No. 262013 so most, cola' EFTA00231318 RECYCLED PAPER 70 REORDER CALI. 96.1416-9. EFTA00231319 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 2008CF009381A DIVISION W STATE OF FLORIDA v. JEFFREY EPSTEIN, Defendant. EPSTEIN'S MOTION TO STAY DISCLOSURE OF THE NON￾PROSECUTION AGREEMENT AND ADDENDUM PENDING REVIEW Defendant, JEFFREY EPSTEIN ("EPSTEIN"), by and through his undersigned counsel and pursuant to Rule 9.310, Florida Rules of Appellate Procedure, moves to stay disclosure of the Non-Prosecution Agreement and Addendum (collectively, the "NPA") pending review, and states: 1. In the event the Court grants Nonparty M.'s Motion to Vacate Order Sealing Records and Unseal Records, grants Palm Beach Post's Motion to Intervene and Petition for Access and/or denies EPSTEIN's Motion to Make Court Records Confidential, EPSTEIN moves to stay the disclosure of the NPA pending review by the Fourth District Court of Appeals. 2. Rule 9.310(a), Florida Rules of Appellate Procedure, provides in pertinent part, "...a party seeking to stay a final or non-final order pending review shall file a motion in the lower tribunal, which shall have continuing jurisdiction, in its discretion , to grant, modify or deny such relief." EFTA00231320 3. A stay pending review is warranted under the circumstances because of the irreparable harm that would be caused by disclosure of the NPA including, but not limited to, substantial injury to a party by disclosing matters protected by common law and privacy rights, substantial injury to a compelling government interest, substantial injury to innocent third parties and a serious imminent threat to the fair, impartial and orderly administration of justice as set forth in the hearing record date June 25, 2009. 4. In Mariner Health Care of Nashville. Inc. v. Baker, 739.. 2d 608, 609 (Fla. 1st DCA 1999), defendant Mariner filed a petition for writ of certiorari after the trial court compelled it to produce certain incident reports. Mariner also moved for a stay pending review pursuant to Fla. R. App. Pro. 9.310. The trial court advised the parties that Mariner would be required to submit the incident reports to the court under seal as a prerequisite to a stay. Mariner refused to produce the documents under seal and the trial court denied the motion for stay and imposed daily fines until the documents were produced. 14„, The First District Court of Appeals affirmed the trial court's order and noted Mariner has failed to explain how the production of the reports under seal would result in any prejudice. To the contrary, the records will be protected from disclosure during the entire course of the certiorari proceeding before this court. No harm can be done if this court ultimately determines that the reports are protected by the work product privilege. Id. at 610. 5. In the instant case the NPA is already filed under seal. Should the Court grant Nonparty M's Motion to Vacate Order Sealing Records and Unseal Records, grant Palm Beach Post's Motion to Intervene and Petition for Access and/or deny 2 EFTA00231321 EPSTEIN's Motion to Make Court Records Confidential, EPSTEIN requests the Court exercise its discretion under Fla. R. App. Pro. 9.310(a) and enter a stay pending review by the 4111DCA. 6. No harm will be done if the NPA remains under seal pending appellate review. To the contrary, EPSTEIN will suffer irreparable harm if a stay is not entered and the NPA is disclosed to the public. WHEREFORE, Defendant, JEFFREY EPSTEIN, respectfully requests that if the Court grants Nonparty M.'s Motion to Vacate Order Sealing Records and Unseal Records, grants Palm Beach Post's Motion to Intervene and Petition for Access and/or denies EPSTEIN's Motion to Make Court Records Confidential, the Court enter a stay pending review and grant any additional relief the Court deems just and proper. Certificate of Service WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Hand Delivery to ., United States Attorney's Office — Southern District, 500 S. Australian Avenue, , West Palm Beach, FL 33401, JUDITH STEVENSON AREO, ESQ., State Attorney's Office — West Palm Beach, 401 North Dixie Highway, West Palm Beach, FL 33401, WILLIAM J. BERGER, ESQ., and BRADLEY J. EDWARDS, Rothstein Rosenfeldt Adler, 401 East Las Olas Boulevard, Suite 1650, Fort Lauderdale, FL 33394, JACK A. GOLDBERGER, ESQ., Atterbury, Goldberger & Weiss, P.A., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, SPENCER T. KUVIN, ESQ., Leopold-Kuvin, P.A., 2925 PGA Blvd., Suite 200, Palm Beach Gardens, FL 33410, and DEANNA K. SHULLMAN, 3 EFTA00231322 400 North Drive, Suite 1100, P.O. Box 2602 (33601) Tampa, FL 33602, this 25th day of June, 2009. BURMAN, CR1TTON, LUTTIER & COLEMAN, LLP 515 N. Flagler Drive, West Palm Beach, FL 401 F By: Robert D. Cri on, Jr. Florida Bar 24162 Michael J. Pike Florida Bar #617296 Counsel for Defendant Jeffrey Epstein) and Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beac FL 33401-5012 Fax: Counsel for Defendant Jeffrey Epstein 4 EFTA00231323 RECYCLED PAPER TO REORDER CALA, 9M-846-9399 EFTA00231324 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 2006CF009454AXX, 2008CF009381AXX STATE, vs. EPSTEIN, JEFFREY INTERVENER'S AND S ON TO STAY OF LAW COMES NOW, Intervener, M. and fil 's Response ndant Jeffrey Epstein's Motion to Stay, and states: In their motion, Defendant asks the Court to stay it mg on the production of the NPA agreement pending review by the Fourth DCA. Since this NPA was never properly sealed in the first place, a Stay is improper because this document is a public record until such time as it has been properly sealed. Furthermore, as Defendant EPSTEIN has failed to demonstrate that he is likely to succeed on the merits of his appeal or describe how he will be harmed by this disclosure, Intervener M. respectfully requests the Court deny their Motion. -Pursuant niPlorida Rule of Appellate Procedure 9.310(a), a trial court has the discretion to enter a stay pending interlocutory review of a non-final order. The burden to satisfy the EFTA00231325 requirements for a stay rests with the party requesting the stay. A trial court is not obligated, or even encouraged, to enter such a stay as the Appellate Rules specifically provide, "In the absence of a stay, during the pendency of a review of a non•final order, the lower tribunal may proceed with all matters, including trial or final hearing; provided that the lower tribunal may not render a final order disposing of the cause pending such review." Fla. R. App. P. 9.130(1) (emphasis added). Defendants ask the Court to stay disclosure of a public document which was never properly sealed. Factors to 'doted by a court when deciding whether to enter a stay "include the moving p s likeliho success on the merits, and the likelihood of harm should a stay not be 769 U2d 389, 391 n.4 (Fla. 3d DCA 1999). Defendants fail to adequately ad s these fa rs in their motion. In fact, Defendant completely ignores the likelihood Likely this is because there is no likelihood that the Fourth District would reverse ling since the proper procedures for sealing the NPA were never followed. As to likelihood of harm, the only reference Defendan to this issue is in paragraph 3 of his motion. Here, Defendant merely m mad assertion that there will be "irreparable harm caused by the disclosure of the NPA." There is no explanation of who will be harmed or what harm will be caused. How can a public document which redacts the names of the minor victims cause harm? This necessary question is never answered. Defendant's broad and vague assertion is insufficient to grant a stay. Finally, since there has been no showing by Defendant EPSTEIN that the proper — procedure for sealing court documents were ever followed, the NPA is a public record. Page 2of 3 EFTA00231326 Therefore, Plaintiff respectfully requests the Court DENY Defendants' Motion to Stay the Proceedings. CERTIFICATE OF SERVICE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by U. S. Mail, postage prepaid, this 26 day of June, 2009 to Jack A. Goldberger, Esq., 250 Australian Avenue, Suite 1400, West Palm Beach, FL 334101; Bruce E. Reinhart, Esq., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401; Robert D. Critton, Jr., Michael J. Pike, 515 North Flagler Drive, Suit est Palm Beach, FL 33401. LEOPOLD—KM/TN, P.A. 2925 PGA Boulevard Suite 200 ens, FL 33410 (facsimile) T. KUV1N, Esq. ar No.: 089737 Page 3of 3 EFTA00231327 Page 2 of I I Wdstlaw. 76912d 389 769 2d 389 Fla. L. Weekly D2439 (Cite as: 769 ..241 389) District Court of Appeal of Florida, Third District. Deborah PEREZ, Appellant, v. Jorge M. PEREZ, Appel lee. No. 99.2182. Oct. 27, 1999. Rehearing Denied Dec. 7, 1999. Following divorce, parties agreed to modification of marital settlement agreement which specifically provided that mother could permanently relocate children to Utah. Father petitioned for modification of custody. The Circuit Court, Dade County, Eu￾gene J. Fierro, J., split custody of children, and mother appealed. Parties and guardian ad litem filed various motions. Mother moved to prohibit further involvement in appellate proceedings by guardian ad litem and counsel appearing on behalf of guardian. The District Court of Appeal, Gersten, J., held that: (I) guardian did not have authority to submit brief or motions at appellate level of child custody proceeding, and (2) there was no authority permitting guardian ad litem to retain counsel on behalf of herself in appeal. Motion granted. Sorondo, J., filed concurring opinion West Head notes Ill Appeal and Error 30 0=477 30 Appeal and Error 301X Supersedeas or Stay of Proceedings 30k476 Upon Allowance by Court or Judge 30k477 k. Authority of Court or Judge. Most Cited Cases District Court of Appeal has authority to issue stay for purpose of preserving status quo during appel￾late proceeding. West's F.S.A. R.App.P.Rule Page 1 9.310(0. [21 Appeal and Error 30 €=479(1) 30 Appeal and Error 301X Supersedeas or Stay of Proceedings 30k476 Upon Allowance by Court or Judge 30k479 Grounds for Allowance 30k479(1) It. In General. Most Cited Cases Factors which are considered by District Court of Appeal in deciding whether to grant stay include moving party's likelihood of success on merits, and likelihood of harm should stay not be granted. West's F.S.A. R.App.P.Rule 9.310(f). [31 Child Custody 76D etzz9OS 76D Child Custody 76DX111 Appeal or Judicial Review 76Dk905 k. Transfer of Cause and Proceed￾ings in General. Most Cited Cases (Formerly 134k303(3)) Father's failure to return children to mother after summer vacation, as required under parties post￾divorce visitation arrangements, and father's at￾tempts to manipulate children's custody preference were sufficient to establish that mother had likeli￾hood of success on merits of her appeal of order modifying custody, warranting issuance of stay, for purpose of preserving status quo during appellate proceeding. West's P.S.A. R.App.P.Rule 9.3100). [4.I Child Custody 76D fe=i903 76D Child Custody 76DX111 Appeal or Judicial Review 76Dk903 k. Right of Review and Parties. Most Cited Cases (Formerly 211k19.3(6)) Guardian ad litem did not have authority to submit brief or motions at appellate level of child custody proceeding. West's F.S.A. § 61.401; West's F.S.A. R.App.P.Rule 9.020. O 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works. http://web2.westlaw.com/print/printstream.aspx?prft=HTMLEecifm=NotSet&destination=... 6/25/2009 EFTA00231328 Page 3 of 11 7691.2d 389 769 .2d 389 4 Fla. L. Weekly D2439 (Cite as: 769 52d 389) [5] Infants 211 C:=85 211 Infants 211VII Actions 211k76 Guardian Ad Litem or Next Friend 21Ik85 k. Duties and Liabilities. Most Cited Cases (Formerly 211k19.2(2)) Universally recognized function of guardian ad litem in custody dispute is to protect best interests of children. (6) Infants 211 4C=.77 211 Infants 211 VII Actions 211k76 Guardian Ad Litem or Next Friend 2111O7 k. In General. Most Cited Cases (Formerly 211k19.3(1)) Guardians ad litem serve important role, under lim￾ited circumstances, by acting as representatives of children and promoting society's interest in protect￾ing children from traumas commonly associated with divorce and custody disputes. 17) Infants 211 Ca785 211 Infants 21 I V11 Actions 211k76 Guardian Ad Litem or Next Friend 211k85 k. Duties and Liabilities. Most Cited Cases (Formerly 211k19.3(1)) Duties and responsibilities of guardian ad litem are not coextensive with those of attorney. West's F.S.A. § 61.403. (8) Child Custody 76D C=.900 76D Child Custody 76DXIII Appeal or Judicial Review 76Dk900 k. In General. Most Cited Cases (Formerly 211k19.3(6)) Child Custody 761) 4C=4)03 76D Child Custody Page 2 76OX111 Appeal or Judicial Review 76O1(903 k. Right of Review and Parties. Most Cited Cases (Formerly 21Ik19.3(6)) Appellate court is not fact-finding court and there is no proper role for guardian ad litem at appellate level. West's F.S.A. § 61.403. [9] Infants 211 e=a85 211 Infants 211VII Actions 21Ik76 Guardian Ad Litem or Next Friend 211k85 k. Duties and Liabilities. Most Cited Cases (Formerly 211k19.2(2)) Guardians ad litem are required to act in the best in￾terests of children even if this conflicts with the children's wishes, and must serve as independent fact investigators. West's F.S.A. § 61.403. 110] Child Custody 761)(:=903 76D Child Custody 76OX111 Appeal or Judicial Review 76Ok903 k. Right of Review and Parties. Most Cited Cases (Formerly 211k19.3(6)) Filing of motions and brief by guardian ad 'item in appellate custody proceedings conflicts with guard￾ian's proper function of serving as independent fact investigator, and violates statutory prohibition against guardians acting as advocates. West's F.S.A. § 61.403. [11] Child Custody 761) C=409 76D Child Custody 76OV111 Proceedings 76DVIII(A) In General 76Dk409 k. Parties; Intervention. Most Cited Cases (Formerly 211k19.3(3)) Minor children in custody proceeding are not con￾sidered as "necessary parties" to action. [12] Child Custody 761) e;?903 O 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works. http://web2.westlaw.com/print/printstream.aspx?prft--HTMLE&ifm=NotSet&destination=... 6/25/2009 EFTA00231329 769'.2d 389 769 .2d 389.,24 Fla. L. Weekly D2439 (Cite as: 769 M.2d 389) 76D Child Custody 76DX111 Appeal or Judicial Review 76Dk903 k. Right of Review and Panics. Most Cited Cases (Formerly 211k19.3(6)) There is no authority permitting guardian ad litem to retain counsel on behalf of herself in appeal, where guardian is not party to proceedings, and where guardian is purportedly appearing on behalf of children who are also not parties in appellate proceedings. *390 Marsha B. Elser, Miami; Cynthia L. Greene, Miami, for appellant. Podhurst, Orseck, Josefsberg, Eaton, Meadow, Olin, & Perwin, and Joel S. Pcrwin, Miami; Bar￾ranco, Kircher, Vogelsang & Boldt, and Kimberly L. Boldt, Miami, for appellee. Before GERSTEN, SHEVIN, and SORONDO, JJ. ON APPELLANT'S RENEWED MOTION TO PRO￾HIBIT FURTHER INVOLVEMENT IN THESE AP￾PELLATE PROCEEDINGS BY THE GUARDIAN AD LITEM AND/OR COUNSEL APPEARING ON BEHALF OF THE GUARDIAN AD LITEM GERSTEN, Judge. Appellant, Deborah M. Perez ("the Former Wife"), moves this Court to prohibit further involvement in these appellate proceedings by the Guardian ad Litem ("Guardian") and counsel appearing on be￾half of the Guardian. We grant the Former Wife's motion and write further to discuss our serious con￾cerns regarding the proceedings in this case, and to clarify that there is no statutory basis for a Guardi￾an to file motions and a brief in a child custody ap￾pealfiNi FN1. Initially, we denied the Former Wife's motion to prohibit further involve￾ment by the Guardian ad Litem. However, we cautioned in our ruling that the denial Page 4 of II Page 3 was "without prejudice to renew if neces￾sary." At this stage of the proceedings, and during a flurry of emergency motions filed by the appellee. the Guardian had filed only two documents; one entitled "Guardian ad Litem's Emergency Motion for Rehearing of Stay" and one entitled "Guardian ad Litem's Emergency Motion to Relinquish Jurisdiction." Both were denied. Thereafter, the Guardian advised counsel for the Former Wife that a brief would be filed with this Court. The Former Wife then renewed her motion correctly observing that the Guardian intended to continue her wholly unauthorized and im￾proper conduct. Background Facts The Former Wife and appellee Jorge M. Perez. ("the Former Husband") divorced in 1995. The Former Wife became primary residential parent of the parties' three minor children. In November of 1996, the parties agreed to a modification of the marital settlement agreement which specifically provided that the Former Wife could permanently relocate the children to the State of Utah in June of 1998. In accordance with the 1996 agreement, the Former Wife purchased property in Utah, sold the home where she and the children were living in Miami, enrolled the children in a Utah school, and notified the Former Husband that she and the children would be relocating to Utah on June IS, 1998. However, two weeks prior to the scheduled and agreed upon departure date, the Former Husband filed a petition for modification of custody and at￾tempted on an emergency basis to enjoin the Former Wife from relocating the children. The trial court denied the emergency motion determining the parties had agreed to the relocation, and the Former Wife and children moved to Utah. Thereafter, pursuant to the parties' visitation agree- (0 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works. httplAveb2.westlaw.com/print/printstream.aspx?prft-41TMLE&ifmnNotSet&destination=... 6/25/2009 EFTA00231330 Page 5 of 11 769 .2d 389 769 2d 389a24 Fla. L. Weekly D2439 (Cite as: 769 M.2d 389) ment, the children spent thi *391 summer of 1999 visiting with the Former Husband. The children having been enrolled in school in Utah, were to be returned to the Former Wife on August 21, 1999. During this agreed summer visitation, the Former Husband's petition for modification proceeded to trial. On July 30, 1999, the trial court entered an or￾der modifying custody which is the subject of the main appeal. The order split custody of the children, awarding custody of the two sons to the Former Husband, and custody of the parties' daughter to remain with the Former Wife.mThe trial court's basis for splitting custody was the expressed preference of the two sons to live in Miami. FN2. We note that the Former Husband's petition did not seek an award of split cus￾tody. In its order, the court noted that the Guardian, Jac￾queline Valdespino, testified there was a substantial change in circumstances in accord with the Former Husband's position. However, the court explained that it did not base its decision solely on the Guard￾ian's testimony and report, because "part of her testimony at trial, as well as part of her conclusions in the Guardian Ad Litem's report ... are based partly on evidence which is clearly hearsay...." On August 9, 1999, the Former Wife filed a Motion for Rehearing and Motion For Stay Pending Appeal which was denied by the trial court on August 20, 1999,0 On August 23, 1999, the Former Wife filed her notice of appeal, and the next day filed an emergency motion seeking a stay of the trial court order, pending review in this Court. FI43. The children had been enrolled in school in Utah for over a year, and the agreement provided that they were to be returned to the Former Wife on August 21st. In spite of the fact that the trial court's custody modification order had been suspended by the filing of the Former Page 4 Wife's Motion for Rehearing, the Former Husband placed the children in school in Miami on August 18th. The children were not returned to the Former Wife, although the primary residence of the children re￾mained with the Former Wife at the time the Former Husband enrolled them in school. Appellate Proceedings: A Barrage of Motions il)[2][3i On August 24. 1999. the Former Wife filed an Emergency Motion for Stay Pending Re￾view and a Motion to Expedite Appeal. The Former Wife's motion for stay alleged a likelihood of suc￾cess on the merits, and that the best interests of the children required maintaining the status quo. Pursu￾ant to her agreement with the Former Husband, the Former Wife requested that the children resume school in Utah pending a final decision on appeal. This Court granted the Former Wife's motions or￾dering a stay pending appeal, and that the appeal be expedited.m. FI44. This Court has authority to issue a stay under Rule 9.310(f), Florida Rules of Appellate Procedure, for the purpose of preserving the status quo during an appel￾l e proceeding. See Hirsch v. flinch, 309 .2d 47 (Fla. 3d DCA 1975). Once a stay is issued, the stay remains in effect until the appellate court mandate is issued. Rule 9.310(e), Fla. R.App. P. Factors which are considered by this Court in deciding whether to grant a stay include the moving party's likelihood of success on the merits, and the likelihood of harm should a stay not be granted. See State ex rel. Price v. McCord, 380 1.2d 1037 (Fla.1980). During the course of the trial court pro￾ceedings, the children had been spending the summer with the Former Husband pursuant to the parties' visitation ar￾rangements. The Former Husband did (0 2009 Thomson Reuters/West. No Claim to Orig. US Oov. Works. http://web2.westlaw.com/print/printstream.aspx?pr11=HTMLE&ifm=NotSet&destination=... 6/25/2009 EFTA00231331 769'.24 389 769 .2d 389,_24 Fla. L. Weekly D2439 (Cite as: 769 . .2d 389) not return the children to the Former Wife, see supra note 3, and the Former Wife's motions contain facts and argu￾ments indicating the Former Husband used this summer time as a means to ma￾nipulate the children's custody prefer- ence. These facts and others were sufficient to establish the Former Wife had a likeli￾hood of success on the merits. Coupled with our additional concerns regarding the children's schooling and their best in￾terests, greater harm could result if the status quo were not p ed. See Offer￾man v. Offerman, 6433.24 1184 (Fla. 5th DCA 1994)(granting motion to stay temporary custody order). The facts raised by the Former Wife in support of her motion for a stay are most troubling, and we emphasize that this Court will not tolerate the improper use of visita￾tion to manipulate a child's custody pref￾erence. *392 This Court's order granting the stay resulted in a flood of motions, including an "Emergency Mo￾tion For Rehearing of Stay" filed by the Guardian advocating the Former Husband's position, and a "Notice of Appearance filed by an attorney on be￾half the Guardian"."a Not surprisingly, the Former Husband also filed an emergency motion for review of the order granting the stay.** On August 26, 1999, this Court denied both the Former Husband's and the Guardian's motions. PN5. The Notice of Appearance filed by the attorney stated she appeared "on behalf of the Guardian." A Notice of Appearance was also filed by the Guardian "on behalf of the minor children as Guardian Ad Litern." FN6. The Former Husband's motion has the rather lengthy title of "Emergency Mo￾tion For Rehearing and For En Banc Re￾Page 6 of 11 Page 5 view of the Court's Ex Parte Order Grant￾ing the Wife's Motion to Stay Execution of a Child Custody Order, Without Waiting for the Husband's Response to That Mo￾tion." It incorrectly states that this Court's ruling constitutes an "ex parte judicial de￾termination ... (which) is simply and flatly a violation of due process." There is no au￾thority for an "en banc review" of an order issued by an appellate panel granting a stay pending review. More importantly, this Court has the inherent authority in its dis￾cretion to enter a ruling on a motion at any time, with or without a responsive plead￾ing. in any event, the Former Husband's Emergency Motion was thoroughly con￾sidered at the time it was filed, and was denied by this Court. In accordance with this Court's mandate, the parties' two sons were sent to Utah on August 27, 1999. Three days later, on August 30th, the oldest son traveled to Miami where he was met at the air￾port by the Former Husband. This prompted the Guardian and the Former Husband to once again at￾tempt to evade the stay order. The Former Husband first filed an emergency mo￾tion in the trial court where the trial Judge held an emergency hearing by telephone. The Former Hus￾band told the trial court that the Guardian had "advised" him not to return the child to the Former Wife in Utah "before (the child sees) a professional counselor who can address his present state of mind." The trial court denied the motion finding that this Court had "effectively taken jurisdiction" over the matter, and ordered the child be returned to Utah to "comply with the law that is now the law of this case; i.e. the stay of these proceedings." Instead of returning the child, however, both the Guardian and the Former Husband then decided to file motions again in this Court. The Guardian's emergency motion asked this Court to "relinquish jurisdiction" to the trial court to consider testimony as to possible emotional damage to the parties eld￾O 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works. http://web2.westlaw.com/print/printstream.aspx?prft-HTMLE&ifm=NotSet8cdestination=... 6/25/2009 EFTA00231332 769'.2d 389 769 .2d 38924 Fla. L. Weekly D2439 (Cite as: 769 lad 389) est son. The Former Husband filed a similar motion entitled "Father/Appellee's Response in Support of Guardian Ad Litem's Emergency Motion to Relin￾quish Jurisdiction." Both the Former Husband's and the Guardian's motions were denied. Our denial of these motions was based upon what should be an obvious theorem-that parents and their minor chil￾dren must obey court orders. We are extremely concerned over this type of mo￾tion practice and caution counsel that "appellate motion practice is not a game of ping-pong in which the last law to serve wins." See Sarasota County v. Ex, 645 ..2d 7 (Fla. 2d DCA 1994). To an even greater extent, we are extremely concerned with the impact of such behavior on children. Chil￾dren should not be "played" as if in a game of ping￾pong where the parent with the greater resources to serve the greatest number of motions wins. Apparently, the Former Wife was also disturbed by the Guardian's involvement in the appellate pro￾ceedings, and moved to prohibit further involve￾ment by the Guardian when she filed her response to the Guardian's second emergency motion on September 1, 1999. Although we denied the motion to prohibit at this time, see infra note 1, the denial was "without prejudice to renew if necessary." When the Guardian notified counsel for the Former *393 Wife of her intent to file an appellate brief with this Court. the Former Wife renewed her mo￾tion. Por the reasons that follow, we grant the mo￾tion and prohibit further involvement of the Guardi￾an in these appellate proceedings. The Role of a Guardian Ad Litem In Child Cus￾tody Appellate Proceedings (4115)(6) The universally recognized function of a guardian ad litem in a custody dispute is to protect the best interests of children. Litigation involving custody issues can be particularly acrimonious and. unfortunately, children are particularly vulnerable to the harms commonly associated with hostility and conflict between parents. Guardians ad litem Page 7 of 11 Page 6 serve an important role, under limited circum￾stances, by acting as representatives of children and promoting society's interest in protecting children from the traumas commonly associated with di￾vorce and custody disputes. See Scaringe v. liar. rick. 711 p2d 204 (Fla. 2d DCA 1998); Repres￾enting C ildren: Standards For Attorneys and Guardians Ad them In Custody or Visitation Pro￾ceedings (With Commentary), 13 J. Am. Acad. Matrim. Lew. 1 (Summer 1995). (7] Once appointed, the powers and authority of a guardian ad litem include investigation, discovery matters, requesting necessary examinations of the parties or the child. obtaining impartial examina￾tions and making recommendations to the court. Sees 61.403 Fla. Stat. (1997). However, the duties and responsibilities of a guardian ad !item are not coextensive with those of an attorney. See Roski v. Roskl, 730 ..2d 413 (Fla. 2d DCA 1999); see also Representing Children.. Standards For Attorneys and Guardians Ad them In Custody or Visitation Proceedings (With Commentary), 13 J. Am. Acad. Matrim. Law. I (Summer 1995)(a guardian ad !item who is also an attorney should not combine the roles of counsel and guardian; Standard 3.1). In fact, Section 61.401, Florida Statutes (1997) spe￾cifically provides that the role of a guardian ad litem is "to act as next friend of the child, investig￾ator or evaluator, not as attorney or advocate." See also,§ 61.403 Fla. Stat. (1997). And I we come to the crux of our concerns in these proceedings. Section 61.401 states that the guardian shall not act as an advocate and the Guardian's role is defined as limited to the specific litigation in which the Guardian is appointed. See Roski v. Roski, 730 I.2d at 413; Black's Law Dic￾tionary 70 (6th ed.1990). Section 61.403 delineates the Guardian's powers and authority in the context of trial court proceedings. Nowhere is there any ref￾erence to appellate court proceedings in the statutes pertaining to the responsibilities of guardians ad FN7. The Former Husband contends that 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works. http://web2.westlaw.com/print/printstream.aspx?prft—HTMLEAtifm=NotSet&destination=... 6/25/2009 EFTA00231333 769'.2d 389 769 .2d 389 j _24 Fla. L. Weekly 132439 (Cite as: 769 M.2d 389) Section 61.401 should be interpreted broadly as permitting guardians ad them to participate in appellate proceedings, be￾cause this Section states the guardian "shall be a party to any judicial proceed￾ing." We disagree for the reasons dis￾cussed throughout this opinion, and based upon our conclusion that the statute's refer￾ence to the guardian's status as a party in judicial proceedings, refers to the trial court proceedings in which the guardian was appointed. Our interpretation is con￾sistent with the prohibition against guardi￾an's acting as advocates contained within this very same section, and with common sense. (8) An appellate court is not a fact-finding court and there is simply no proper role for a Guardian at the appellate level. The Guardian fulfilled her stat￾utorily defined duty when she completed her invest￾igation and report to the trial court-the court in which she was appointed.ra FN8. We note that the Guardian's report is part of the appellate record and is at the disposal of both the Former Husband and the Former Wife in this proceeding. (9)(10) When attorneys are appointed to serve as guardians ad litem, their roles in the litigation pro￾cess are significantly different than the roles they would otherwise assume as lawyers. Guardians ad litem are required to act in the best interestss394 of children even if this conflicts with the children's wishes, and must serve as independent fact invest￾igators. The filing of motions and a brief by the Guardian in appellate proceedings conflicts with these functions, and violates the statutory prohibi￾tion against Guardians acting as advocates. See§ 1.403 Fla. Stat. (1997); Scaringe v. Herrick, 711 Eld at 204. Simply, the Guardian does not have a statutory right to appear in these proceedings. See Betz v. Betz, 254 Neb. 341, 575 N.W.2d 406, 410 (1998)." Page 8 of II Page 7 FN9. Although Betz involved the role of the guardian Id litem at the trial court level, we find many of the observations made by the court as to the proper function of the guardian relevant to our analysis. The Betz court noted that the primary func￾tion of a guardian is to provide the ap￾pointing court with necessary information by way of admissible evidence. The court further cautioned that: "A guardian ad litem may be an attorney, but an attorney who performs the func￾tions of a guardian ad litem does not act as an attorney and is not to participate in the trial in an adversarial fashion such as calling or examining witnesses or filing pleadings or briefs." Betz v. Betz. 575 N.W.2d at 409 (emphasis added). For purposes of this decision, we agree with Betz that it is improper for a guardian ad litem to file a brief in an appellate pro￾ceeding. Such participation on appeal vi￾olates the proscription against a guardian ad litem assuming the role of an advoc￾ate, and exceeds the bounds of the guardian's limited duties toward the ap￾pointing trial court. The Guardian is further prohibited from appearing in these proceedings because she is not a proper party under Rule 9.020, Florida Rules of Appellate Procedure. It is well established that only parties (or their representatives) who have suffered an ad￾verse affect in the lower tribunal cause of action are entitled to participate in an appeal. See Sias v. Fosada, 760 M.2d 954 (Fla. 3d DCA 1999); Or￾ange County, Fla. Game and Fresh Water Fish Commission, 397 .2d 411 (Fla. 5th DCA 1981); Florida Civil Practice Guide, Vol. 6, § 143.03 (Lexis Publishing 1998). (Ill Rule 9.020 defines the "parties" to an appeal as the "appellant" and the "appellee." Neither the Former Husband nor the Former Wife sought relief against the children. Further, minor children in a 0) 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works. http://web2.westlaw.com/print/printsueam.aspx?prft=HTMLE&ifm=NotSet&destination=... 6/25/2009 EFTA00231334 Page 9 of 1 769 I 2d 389 769 .2d 389d4 Fla. L. Weekly D2439 (Cite as: 769 M.2d 389) custody proceeding are not considered as "necessary arties" to the action. See Shienvold v. liable, 622 e2d 538 (Fla. 4th DCA 1993). There￾fore, it is manifestly obvious that the minor chil￾dren in this case are not "parties" to this proceed￾ing, and thus the Guardian cannot appear on their behalf. 1121 We are also disturbed by the Guardian's reten￾tion of an attorney to represent the Guardian in the appellate proceedings. As noted earlier, on the same day the Guardian filed her notice of appearance "on behalf of the children," an attorney fled a notice of appearance "on behalf of the Guardian." However, this attorney had never been appointed by any court to serve in any capacity in this case. There is no au￾thority permitting a Guardian to retain counsel on behalf of herself in an appeal, where the Guardian is not a party to the proceedings, and where the Guardian is purportedly appearing on behalf of children who are also not parties in the appellate proceedings. See generally Betz v. Bert 254 Neb. 341, 575 N.W.2d 406, 410 (1998)(a guardian who feels the need to retain an attorney should apply to the appointing court for permission). In conclusion, there is no authority for a Guardian, or an attorney purportedly representing a Guardian, to submit motions or a brief in a child custody ap￾peal."e° Guardians*39S render an important ser￾vice to the courts of this state, and we recognize that the lines separating the functions of an attorney as Guardian and an attorney as advocate, can be￾come easily blurred. We hope the line has now be￾come more distinct. FNIO. Nothing in this opinion shall be construed as affecting the role of a Guardi￾an in other types of cases, or in the obvious situation where a child is the real party in￾terest. See generally, S.A.P. v. Stare. Delft igL Health and Rehabilitative Servs., 704 .24 583, 585 (Fla. 1st DCA I997)(minor may not bring action on her own behalf, and can only sue by and through a guardi￾an ad litem, next friend or other duly ap￾Page 8 pointed re sentative); Kingsley v. Kings￾ley, 623 .2d 780, 784 (Fla. 5th DCA 1993)(guardian ad liters or next friend is required to represent a minor in a termina￾tion (,parental rights case), review denied, 634 .2d 625 (Fia.1994);Fla. R. Civ. P., Rule I.210(b) (minors do not have legal capacity to initiate legal proceedings in their own names). The Former Wife's motion is granted. The motions filed by the Guardian are stricken, and the Guardi￾an, as well as counsel appearing on behalf of the Guardian, are prohibited from filing an appellate brief as a party in these proceedings"" Pill. The Guardian's motion for leave to file an amicus curiae brief pursuant to Florida Rule of Appellate Procedure 9.370 is granted. The Guardian is permitted to file an amicus curiae brief only. Motion to prohibit granted. SHEVIN, Judge, concurs.SORONDO, J. (specially concurring). I agree with the majority that the guardian ad litem does not have standing to file a brief in this case. I write separately because I arrive at the same con￾clusion through a somewhat different analysis. Deborah Perez (the mother), argues that the stat￾ute's mandate that the guardian "act as next friend of the child, investigator or evaluator, not as attor￾ney or advocate," in section 61.401, Florida Stat￾utes (1997), precludes the guardian from taking a position in this appeal because the guardian's argu￾ments will place her in the role of advocate.ne2 The mother further argues that the appointment of the guardian by the lower court does not authorize her to file pleadings in this Court. FN12. Needless to say, the guardian's posi￾tion in this case is contrary to that of the mother. Jorge M. Perez (the father), responds that the stat￾C 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works. http://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&ifm=NotSet8cdestination=... 6/25/2009 EFTA00231335 Page 10 of 11 769,.2d 389 769 .2d 389,24 Fla. L. Weekly D2439 (Cite as: 769 . .2d 389) ute is ambiguous because although it sets forth the language cited above, the statute also makes the guardian a "party." This elevates the guardian to the same level as the other, parties in the case, the father and the mother. As such the guardian has the right to file pleadings with this Court in furtherance of the best interest of the children. When first passed by the Florida Legislature, sec￾tion 61.401 Florida Statutes (Supp.1990), as pertin￾ent here, read as follows: Appointment of guardian ad litem.-In an action for dissolution of marriage, modification, parental re￾sponsibility, custody, or visitation, if the court finds it is in the best interest of the child, the court may appoint a guardian ad litem to represent the child. As relevant to the issues before us, section 61.401 Florida Statutes (Supp.1990), stated: Guardians ad litem; powers and authority.-A guard￾ian ad litem when appointed shall act as a repres￾entative of the child and shall act In the child's best interest. In 1994, the Legislature amended both statutes. Section 61.401 was amended to read: Appointment of guardian ad litem.-In an action for dissolution of marriage, modification, parental re￾sponsibility, custody, or visitation, if the court finds it is in the best interest of the child, the court may appoint a guardian ad them to act as next friend of the child, investigator or evaluator, not as attorney or advocate. The court in its discretion may also appoint legal counsel for the child to act as attor￾ney or advocate; however, the guardian and the legal counsel shall not be the same person. ...The guardian ad !item shall be a party to any Judicial proceeding from the date of the appointment until the date of discharge. Ch. 94-204, § 3. Laws of Ha. (amending § 61.401, Ha. Stat. (1993))(emphasis added).*396 Section 61.403, as pertinent here, was also amended: Gu ians ad litem; powers and authority. A guard￾ian litem when appointed shall act as nest friend Page 9 of the child, investigator or evaluator, not as attor￾ney or advocate but shall act in the child's best in￾terest. Ch. 94-204, § 5, Laws of Fla. (amending § 61.401, Fla. Stat. (1993)) (emphasis added). In 1994, the legislature excised all language con￾cerning the "representation" of the child, and in￾cluded language specifically stating that the guardi￾an was not to act as "attorney or advocate." The amended statute went on to provide that the trial court could appoint counsel for the child to serve that function. The legislature clearly intended that the function of the guardian be one of "next friend" to the child. This role includes the power to invest￾igate and evaluate the case, and to make recom￾mendations to the trial judge which are consistent with the best interest of the child. See§ 61.403(5), (8), Ha. Stat. (1997). In short, the guardian's role is to discover, analyze and communicate facts to the judge which will assist the trial court in the per￾formance of its duty to determine the best interest of children in divorce proceedings. The role of ad￾vocate for the child, the legislature reserved for counsel, which the court can appoint if it considers appropriate and necessary. The trial judge in this case did not appoint counsel. The father's argument that the guardian's elevation to the status of "party" gives her the right to file pleadings in this Court is unpersuasive. First, it is clear that the guardian is not a party to this action in the strict and acknowledged sense of the word. In defining the word, Black's Law Dictionary 1122 (6th ed.1990) states: "Party" is a technical word having a precise mean￾ing in the legal parlance; it refers to those by or against whom a legal suit is brought, whether in law or equity, the party plaintiff or defendant, whether composed of one or more individuals and whether natural or legal persons; all others who may be affected by the suit, indirectly or con￾sequently, are persons interested but not parties. O 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works. http://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&ifm=NotSet8cdestination=... 6/25/2009 EFTA00231336 Page 11 of 11 769 t.d 389 769 2d 389 Fla. L. Weekly D2439 (Cite as: 76962d 389) See also59 Am.Jur.2d Parties § 7 (1987)(The word party or parties "designates the opposing litigants in a judicial proceeding-the persons seeking to estab￾lish a right and those upon whom it is sought to im￾pose a corresponding duty or liability ..."). Under this definition the guardian in this case is not a party. Accordingly, the guardian is a "party" in this judicial proceeding only because the legislature has made ha such. Because this status is created by statute it can be defined by statute, and the statutes in question do just that. The legislature first chose to limit the guardian's role as a "party" by forbid￾ding her from acting in a certain way, i.e. as an ad￾vocate for the child. Next, in section 61.403(2), (3), and (6), the legislature required the guardian to pe￾tition the court and file pleadiass only through counsel-a "true" party could do pro se. Finally, the guardian does not become a party at the incep￾tion of the litigation or because she has a personal interest, she attains that status by judicial appoint￾ment and retains her identity as such only until dis￾charged by the judge. Thus, although the legislature has created this special class of "party," it has also defined its limitations. As 1 read the statute, the guardian does not have a partys right to file plead￾ings in this Court because this will, mandatorily, re￾quire her to become an advocate. The majority correctly observes that there is no role for the guardian to play in this Court because all factual issues and determinations have been fully developed below. This Court is in a position to read the record of the lower court, which contains all of the guardian's contributions to this lawsuit. A brief review of that record indicates that the guardian's position is the same as that of the father in this case and has been repeatedly and zealously expressed in both the lower court and this *397 Court. Indeed, the father relies heavily on the recommendations of the guardian. The guardian's presence in this appel￾late proceeding is therefore superfluous. I do acknowledge that in certain cases the guardian may serve a valuable role on appeal. Usually, the guardian's recommendations will bolster the legal Page 10 position of one of the parents. There are extraordin￾ary cases, however, where the guardian's conclu￾sions could be detrimental to both parents. I refer specifically to cases which contain issues concern￾ing the parents' mental and emotional stability and cases involving domestic violence and/or child ab￾use. In such cases, a guardian could recommend that neither parent be awarded custody or that cus￾tody should be predicated upon a particular parent's participation in some type of psychological coun￾seling. These cases may call for a guardian to file a brief in an appeal and this Court has the authority, which the majority has chosen to exercise in this case, to allow the guardian to appear as amicus curiae pursuant to rule 9.370 of the Florida Rules of Appellate Procedure."'" I do not believe that this appeal calls for the guardian's participation. FN13. Even under these circumstances the guardian must seek leave of court to hire counsel. I join the majority in its conclu￾sion that the guardian's sua sponte decision to hire counsel in this case, presumably at the expense of the parties, was highly im￾proper. Flail. 3 Dist.,1999. Pere . Perez 769 .2d 389, 24 Fla. L. Weekly D2439 END OF DOCUMENT 0)2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works. http://web2.westlaw.corn/print/printstream.aspx?prft=HTMLE&ifm=NotSe1&destination="... 6/25/2009 EFTA00231337 g I 2 16 EFTA00231338 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CRIMINAL DIVISION "W" CASE NO. 502008CF009381AXXMB 502006CF009454AXXMB STATE OF FLORIDA, vs. JEFFREY EPSTEIN, Defendant ORDER THIS MATTER came before the Court on the following: a) Non-party M.'s Motion to Vacate Order Sealing Records and Unseal Records b) Palm Beach Post's Motions to Intervene and Petition for Access c) B.B.'s Motions to Intervene and for an Order to Unseal Records d) Jeffrey Epstein's Motion to Make Court Records Confidential A hearing was conducted on these matters on June 25, 2009. The Court notes that Mr. Goldberger, Esq. and Mr. Critton, Esq. were present on behalf of Jeffrey Epstein. Ms. Shullman, Esq. was present on behalf of the Palm Beach Post, Mr. Berger, Esq. and Mr. Edwards, Esq. were present on behalf of M., Mr. Kuvin, Esq. was present on behalf of M., Assistant State Attorney Barbara Burns was present-on behalf-of-the State of Florida; -No appearance was filed on behalf of the United States. After giving an opportunity for all parties to be heard, the Court finds as follows: EFTA00231339 Page Two Case No. 502008CF009381/0C<MB/502006CF009454AXXMB 1. The State of Florida charged the Defendant, Jeffrey Epstein, with Felony Solicitation of Prostitution. 2. The State of Florida and Mr. Epstein came to a negotiated resolution of the charges. Part of that resolution included an agreement entered into between Mr. Epstein and the United States. At the plea conference in State court Mr. Epstein plead guilty to the State charges. At the plea conference the agreement between Mr. Epstein and the United States were made part of this Court's record. The agreement was sealed in two separate filings. At the time the State court took these matters under seal, the proper procedure for sealing such documents had not been followed. The June 25th hearing was to give Mr. Epstein, the State, and/or the United States an opportunity to comply with the well-defined and narrow parameters for sealing such documents. After hearing argument of counsel, the Court makes the following findings and rulings: 1) Neither the State of Florida nor the U.S. Government nor Mr. Epstein have presented sufficient evidence to warrant the sealing of documents currently held by the Court. 2) The Motions to_seal the Court records are-denied. 3) The Motions to intervene are granted. 4) The Motion to unseal the documents is granted. EFTA00231340 Page Three Case No. 502008CF009381AXXMB/502006CF009454AXXMB 5) The originals will not be disclosed, however the undersigned will do an in￾camera inspection and redact the names of the underage victims, if any, I their identity will be indicated by their initials. 6) This Order is in no way to be interpreted as permission to not comply with U.S. District Court Kenneth Marra's previous Orders. 7) The disclosure of the sealed documents shall be stayed at least until June 26, 2009, at 9:00 a.m., at which time the Court will hear "Epstein's Motion to Stay Disclosure of Non-Prosecution Agreement and Addendum Pending Review". DONE AND ORDERED in West Palm Beach, Palm Bea ounty, Florida this day of June, 2009. Copies furnished: R. Alexander Acosta, U.S. Attonal.fice - Southern District 500 South Australian Avenue, West Palm Beach, FL 33401 Barbara Burns, Esq., State Attorney's Office 401 North Dixie Highway West Palm Beach, FL 33401 William J. Berger, Esq. Bradley 1. Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard., Suite 1650 Ft. Lauderdale, FL 33394 Robert D. Critton, Esq. Burman, Critton, Luttier & Coleman 515 North Flagler Drive, West Palm Beach, FL 33401 EFTA00231341 Page Four Case No. S02008CF009381AXXMB/502006CF0094S4AXXMB Jack A. Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Spencer T. Kuvin, Esq. Leopold-Kuvin, P.A. 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, FL 33410 Deanna K. Shullman, Esq. P. O. Box 2602 Tampa, FL 33602 EFTA00231342 17 EFTA00231343 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA _ __ ___ _ .. CRIMINAL DIVISION1Yr_ .. CASE NO. 502008CF009381AXXMB 502006CF009454A)C<MB STATE OF FLORIDA, vs. JEFFREY EPSTEIN, Defendant ORDER DENYING MOTION TO STAY DISCLOSURE AGREEMENT THIS MATTER came before the Court at a hearing on June 26, 2009, on Jeffrey Epstein's Motion to Stay the Disclosure of the Non-Prosecutionl.Aieement and the Addendum thereto. The Court notes the parties were present and represented by counsel. Based upori argument, it is ORDERED AND ADJUDGED that 1. The Motion to Stay is denied. 2. The Clerk of Court shall make the documents available for disclosure at noon on Thursday, July 2, 2009. It Is the intent of the Court to give the Defendant, Mr. Epstein, and his attorney an opportunity to have this Court's orders reviewed by the 4th DCA. If the Clerk gets no direction front the Appellate Court, she shall disclose the documents on the date referred to-above. DONE AND ORDERED in West Palm Beach, Palm BeachsiCGoNuZ,Zi ldrEapt ED ~tND JUN 2 6 2009 his day of June, 2009. JEFFREY J. CO allEFFREY1 COMM Circuit Court Judge EFTA00231344 Page Two Case No. 502008CF009381AAMB/502006CF009454A)0(MB Order Denying Motion to Stay Disclosure Aoreernent Copies furnished: R. Alexander Acosta, U.S. Attorri,rice - Southern District 500 South Australian Avenue, West Palm Beach, FL 33401 Barbara Burns, Esq., State Attorney's Office 401 North Dixie Highway West Palm Beach, FL 33401 William J. Berger, Esq. Bradley J. Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard., Suite 1650 Ft. Lauderdale, FL 33394 Robert D. Critton, Esq. Burman, Critton, Luther & Coleman 515 North Flagler Drive, West Palm Beach, FL 33401 Jack A. Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Spencer T. Kuvin, Esq. Leopold-Kuvin, P.A. 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, FL 33410 Deanna K. Shullman, Esq. P. O. Box 2602 Tampa, FL 33602 1 EFTA00231345 EFTA00231346 1 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 2 IN AND FOR PALM BEACH COUNTY, FLORIDA CRIMINAL DIVISION 3 STATE OF FLORIDA ) 4 ) vs. ) CASE No. 2008CF009381AXX 5 ) JEFFREY EPSTEIN, ) 6 ) CERTIFIED COPY Defendant. ) 7 ) 8 PROCEEDINGS BEFORE THE COURT 9 PRESIDING: HONORABLE JEFFREY COLBATH 10 APPEARANCES: 11 ON BEHALF OF THE STATE: 12 BARRY E. KRISCHER, ESQUIRE State Attorney 13 401 North Dixie Highway West Palm Beach, Florida 33401 14 By: BARBARA BURNS, ESQUIRE Assistant State Attorney 15 ON BEHALF OF THE DEFENDANT: 16 JACK GOLDBERGER, ESQUIRE 250 S Australian Ave Ste 1400 17 West Palm Beach, Florida 33401 And 18 ROBERT CRITTON, ESQUIRE 515 N Flagler Dr Ste 400 19 West Palm Beach, Florida 33401 20 ON BEHALF OF THE PALM BEACH POST: DEANNA SHULLMAN, ESQUIRE 21 Thomas, LoCicero & Bralow 101 N.E. 3rd Avenue - Ste 1500 22 Fort Lauderdale, Florida 33301 23 ON BEHALF OF EW, THE INTERVENER: WILLIAM J. BERGER, ESQUIRE 24 BRAD EDWARDS, ESQUIRE 225 NE Mizner Blvd Ste 675 25 Boca Raton, Florida 33432 SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231347 2 1 ON BEHALF OF EB, MOTION INTERVENER'S PLEADING: 2 SPENCER KUVIN, ESQUIRE 2925 PGA Blvd Ste 200 3 Palm Beach Gardens, Florida 33410 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 June 25, 2009 24 Palm Beach County Courthouse West Palm Beach, Florida 33401 25 Beginning at 1:50 o'clock, p.m. SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231348 3 1 BE IT REMEMBERED that the following 2 proceedings were had in the above-entitled cause 3 before the HONORABLE JEFFREY COLBATH, one of the 4 judges of the aforesaid court, at the Palm Beach 5 County Courthouse, located in the City of West 6 Palm Beach, State of Florida on June 25, 2009 7 beginning at 1:50 o'clock, p.m. with appearances 8 as hereinbefore noted, to wit: 9 THEREUPON: 10 THE COURT: Let me call up the case 11 of the state of Florida versus Jeffrey 12 Epstein. Let me have counsel announce 13 their appearances for the record. 14 MS. SHULLMAN: Deanna Shullman of 15 Thomas, LoCicero & Bralow on behalf of the 16 Palm Beach Post. 17 THE COURT: Ms. Shullman, nice to see 18 you again, good morning. 19 MS. SHULLMAN: You too. 20 MR. GERBER: William J. Berger for 21 EW, the intervener. 22 MR. EDWARDS: Brad Edwards also on 23 behalf of the EW. 24 MR. KUVIN: Spencer Kuvin on behalf 25 of EB, motion intervener's pleading. SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231349 4 1 MR. GOLDBERGER: Good afternoon, 2 Judge, Jack Goldberger and Robert Critton 3 on behalf of Jeffrey Epstein. 4 THE COURT: And I'm guessing that, 5 Mr. Kuvin, if I grant the motion to unseal 6 that which has been sealed, your motion to 7 intervene will be moot. 8 MR. KUVIN: Will be. 9 THE COURT: I thought II. This is 10 what I'm thinking and -- oh, we've got 11 more. 12 MS. BURNS: One more appearance, 13 excuse me, Judge, Barbara Burns on behalf 14 of the state of Florida, the state 15 attorney's office of the 15th Judicial 16 Circuit. 17 THE COURT: All right. Procedurally, 18 I think the way that this came to us is 19 that at the conclusion or at some point 20 during a plea conference between the state 21 of Florida and Mr. Epstein, the state and 22 the defense hand an agreed order to 23 Judge Puccillo. 24 MS. BURNS: Puccillo. 25 THE COURT: And asked her to sign an SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231350 5 1 agreement to seal some portion of some 2 documents, which she signed off on and now 3 it is the intervener's and the Post's 4 motion to unseal those documents; is that 5 kind of procedurally where we are? 6 MR. GOLDBERGER: Procedurally not 7 exactly correct, I don't know if you want 8 me to clarify that. 9 THE COURT: Please do. 10 MR. GOLDBERGER: Your Honor, this 11 started during the course of a plea 12 colloquy in Mr. Epstein's state proceeding 13 before Judge Puccillo, who is a retired 14 senior judge who was filling in for 15 Judge McSorley on that day, who was the 16 judge assigned to this division. It was a 17 plea agreement with the state attorney's 18 office and it is normal and consistent with 19 any plea colloquy Judge Puccillo asked the 20 defense whether there were any other 21 promises or inducements for Mr. Epstein to 22 enter into his plea agreement other than 23 what was contained in the state standard 24 plea agreement that we had. I felt 25 obligated under the circumstances to alert SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231351 6 1 to the Court that there was a confidential 2 agreement between Mr. Epstein's -- 3 Mr. Epstein's attorneys and the United 4 States attorney's office for the Southern 5 District of Florida which would have been 6 triggered upon the successful taking of the 7 plea by Judge Puccillo. 8 In other words, if the plea was 9 accepted by Judge Puccillo, there's a 10 confidential agreement between U.S. 11 attorney's office and the defense that 12 would be triggered and they would agree not 13 to take some actions against Mr. Epstein. 14 I advised Judge Puccillo of that, and at 15 that time she said she would like to see 16 the matter sealed in the court file. I 17 said fine, and then we later -- I then 18 filed that document, and the clerk's office 19 notified me and said we need an order 20 sealing this, and we submitted an order to 21 seal the document. 22 THE COURT: All right. Is there 23 anybody here from the U.S. attorney's 24 office? Has anybody notified them, or is 25 there a dog in this fight or do they care? SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231352 7 1 If they're a party to this confidential 2 thing, wouldn't you think that they might 3 be. 4 MR. GOLDBERGER: Your Honor, they 5 have been noticed. They have taken a 6 position in parallel proceedings that this 7 matter should remain confidential, and they 8 have done that in federal court, and I 9 believe that is their position still. 10 MR. EDWARDS: Your Honor, I have been 11 in communication with the U.S. attorney's 12 office, and they are not taking a position 13 on this issue, which is why they're not in 14 court right now. 15 THE COURT: What's going on in 16 federal court? 17 MR. GOLDBERGER: There are a number 18 of civil cases that are pending right now. 19 THE COURT: And they're talking about 20 the same documents that are under seal here 21 in our court? 22 MR. EDWARDS: Yes. 23 MR. GOLDBERGER: Yes, your Honor, and 24 I will address that at the appropriate time 25 what's going on here. SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231353 8 1 THE COURT: All right. thank you, 2 Mr. Goldberger for getting that 3 straightened out. 4 MR. GERBER: Judge, just to clarify 5 one other point. 6 THE COURT: Sure. 7 MR. GERBER: I think actually there's 8 an additional step because Mr. Goldberger 9 on behalf of Mr. Epstein or Mr. Critton I 10 believe filed motion, and I think that that 11 will tell us who goes first today and who 12 has the burden today. 13 THE COURT: This is -- and I'm 14 thinking outloud that my take on that is 15 that my review of the file shows that the 16 appropriate steps to seal these documents 17 wasn't followed initially. I'm looking at 18 it as it would be whoever's moving to have 19 them sealed, it's their burden to prove the 20 steps that you have to prove to get things 21 sealed by the Court, and II that's -- I 22 hinted last meeting that we all had 23 together but that's where I'd go, I'd 24 shift the burden over to the federal 25 government and to Mr. Epstein, that's what SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231354 9 1 I'm thinking. Let me ask first go over to 2 the Post, Ms. Shullman, what are your 3 thoughts on that procedure? 4 MS. SHULLMAN: Your Honor, I think 5 that's the correct procedure here. I think 6 Mr. Epstein's motion to make court records 7 confidential tacitly admits what we 8 suspected last time, which was that the 9 initial closure of the documents was not 10 done pursuant to the acceptable procedures. 11 THE COURT: All right. Mr. Berger, 12 Mr. Edwards, that's all right with you? 13 MR. EDWARDS: We agree. 14 MR. GERBER: That's what my point 15 was, yes, your Honor, thank you. 16 THE COURT: Mr. Goldberger, what do 17 you think? 18 MR. GOLDBERGER: That's fine, your 19 Honor, with the -- I'll wait until after 20 the proceeding. 21 THE COURT: All right. You may 22 proceed. 23 MR. GOLDBERGER: Judge, as I said to 24 clarify the record, this matter started 25 during the course of Mr. Epstein's plea SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231355 10 1 colloquy in state court and just II that 2 the record was clear that all inducements 3 for Mr. Epstein's plea was on the record 4 when Judge Puccillo asked me if there had 5 been any promises made to Mr. Epstein, I 6 think properly and ethically we told the 7 Court that there was an agreed -- 8 confidential agreement with the federal 9 government that was in place that basically 10 said we will not prosecute Mr. Epstein for 11 federal offenses if the state plea 12 agreen4nt is accepted by the Court and 13 Mr. Epstein's sentence is imposed. 14 The state proceeding was over at the 15 time that I advised Judge Puccillo that, in 16 other words, we had gone through the plea 17 colloquy and I simply was advising her of 18 this other agreement. It was 19 Judge Puccillo who then asked us to 20 approach, and the Court has a copy of that 21 transcript, I believe. It was 22 Judge Puccillo that said I'd like to have 23 that document sealed in the court file, and 24 I acquiesced to that, I said that's fine. 25 ■, first, as a preliminary matter, SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231356 1 2 3 11 it wasn't like we were coming into court on that day and asking to seal something, ■ it would have been presumptuous of me to 4 file something to request to have something S 6 7 8 9 sealed when it came up during the course of the proceeding, and, in fact, the committee notes on the rule of judicial administration talk about that and say matters come up all the time during the 10 course of hearings and the fact that 11 something is not filed in advance does not 12 necessarily taint the entire process, II we 13 . agreed to come forward and file our motion 14 to seal after the fact, because we didn't 15 know this matter would be coming up. 16 But having said that, Judge, this 17 confidential agreement was not part of any 18 state plea agreement, it's not part of the 19 proceedings, it was ancillary to the state 20 proceedings and it had nothing to do with 21 the state proceedings. As an accommodation 22 to Judge Puccillo, we filed it in the court 23 file. Quite frankly, it's unnecessary, it 24 doesn't need to be there, and the simplest 25 approach would be to simply remove it from SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231357 12 1 the court file at this point. We didn't 2 have for it to be there. It's not part of 3 the plea, it's not part of the state 4 resolution of the case, and that would be 5 the simple logical approach to that. 6 If the Court is inclined not do that 7 or if the parties object to that, then I 8 think we move onto some other very, very 9 important issues in this case and for both 10 the intervenors in this case as well as the 11 Palm Beach Post motion for access to this 12 proceeding for really two very, very 13 significant reasons, they are in the wrong 14 place and they're attempting to march up 15 the wrong hill here, your Honor. 16 This matter needs to -- has to be 17 litigated in federal court before 18 Judge Marra who has already heard hearings 19 on this matter. Now, at our last 20 abbreviated hearing two weeks ago, I told 21 you for the first time that there have been 22 two hearings in front of Judge Marra on 23 this very issue, whether this 24 nonprosecution agreement and that's the 25 matter that is sealed in your court file, SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231358 13 1 whether this nonprosecution agreement 2 should be released to the plaintiffs for 3 their use. 4 Judge Marra heard two hearings on 5 this matter and the court has those orders. 6 And in the first hearing Judge Marra very, 7 very, carefully balanced the 8 confidentiality issues of the 9 nonprosecution agreement, the intent of the 10 parties as well of the rules of criminal 11 procedure that I will talk about in a 12 moment, with the plaintiff's right to know 13 what's going on and to have access to this 14 agreement. And Judge Marra crafted an 15 order and in the nature of a protective 16 order and said, plaintiffs, you can have 17 this nonprosecution agreement, you can use 18 it, you can review it, you cannot give it 19 to anyone else other than your clients, and 20 if you want to use it or you want to give 21 it to your clients, you need to tell them 22 about this order that is not to be 23 disclosed to anybody else. And these 24 plaintiffs that are sitting here will tell 25 you that from day one they have had this SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231359 14 1 nonprosecution agreement, they have it for 2 their use, they know every clause that's in 3 that nonprosecution agreement, and I 4 suggest to the Court as to their motions 5 why are we here; they have an agreement 6 already. 7 They went back to Judge Marra 8 sometime thereafter and asked the Court to 9 expand their use of the nonprosecution 10 agreement, and they said, Judge Marra, we 11 have the nonprosecution agreement but we 12 would like to be able to disclose that 13 agreement to other sides, and Judge Marra 14 in another carefully crafted order said, 15 nuh-uh, no, you have not satisfied your 16 burden, you cannot disseminate this to 17 anyone else, and the order that I have 18 entered remains in place, but most 19 significantly he said, you know what, this 20 is without prejudice. 21 If you have some basis, you have some 22 need that you have not briefed, you have 23 not litigated with me yet concerning 24 dissemination of nonprosecution agreement, 25 come back to me and I'll review it for you. SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231360 15 1 And they have every right to do II, and 2 they have not done II, and it is this 3 motion to intervene that they filed in this 4 court is simply an effort to skirt and to 5 avoid and to go behind the order of 6 Judge Marra that dealt with this issue 7 already. 8 And I think just for the purpose of 9 our hearing, we need to have the two orders 10 of Judge Marra entered into the record of 11 this proceeding. I know I gave copies to 12 the Court, but I have additional copies. 13 MR. GOLDBERGER: Your Honor, I 14 believe there is no objection from either 15 of the parties. 16 THE COURT: Thank you much. Let's 17 go ahead and mark these as Defendant's 18 Exhibits No. 1 and 2 for identification 19 purposes. Anybody object to me taking 20 judicial notice of Judge Marra's order? By 21 hearing no objection, I'll go ahead and 22 take judicial notice of it. 23 MR. GOLDBERGER: ■, your Honor, 24 Judge Marra has dealt with this issue 25 squarely, there's a procedure in place and SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231361 16 1 these matters should be litigated in front 2 of the district court judge that has 3 already heard these matters. 4 THE COURT: Well, let's say that may 5 be true as it relates to these individual 6 plaintiffs in the federal litigation, what 7 about the Post's and the press's -- the 8 media's right to take a look at these 9 things? 10 MR. GOLDBERGER: Your Honor, and this 11 is the second reason why not only the 12 plaintiffs but the Post appear to be 13 marching up the wrong hill here. The Palm 14 Beach Post has filed a motion for access to 15 these documents and they certainly do have 16 first amendment rights and no one would 17 dispute that they have first amendment 18 rights to access to public records, 19 however, most significantly in this case is 20 that the nonprosecution agreement which we 21 gave the court permission to review two 22 weeks ago and presumably the Court has had 23 an opportunity to take a look at it, the 24 nonprosecution agreement talks about and 25 relates to a grand jury matter that is SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231362 17 1 absolutely 100 percent protected from 2 disclosure by Federal Rule of Criminal 3 Procedure Six. I have a copy of that rule 4 for the Court. 5 THE COURT: Let me take a look of 6 that, please. 7 MR. GOLDBERGER: Give us one moment, 8 your Honor, we have it here somewhere. 9 MR. KUVIN: Your Honor, just briefly 10 while they're looking on behalf of the 11 plaintiff EB, I just wanted to point out on 12 my client motion to intervene, we are not 13 party to the federal action. She only has 14 a state court claim. She's not bound by 15 any federal court order, she is not with 16 the federal court on their claim, ■ as to 17 that issue, my client stands here 18 synonymous with the Post. 19 THE COURT: Thank you for pointing 20 that out to me. 21 MR. GOLDBERGER: We'll have it for 22 you in one moment, your Honor. 23 Your Honor, Federal Rule of Criminal 24 Procedure Six is a rule that deals with 25 grand jury proceedings, and it confers in SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231363 18 1 the federal system secrecy of all grand 2 jury matters and it's pretty clear in this 3 case that the nonprosecution agreement 4 specifically talks about a grand jury 5 investigation of Mr. Epstein, there's 6 specific reference to a grand jury 7 investigation in the nonprosecution 8 agreement. 9 The rule does not prevent us from 10 telling the Court that there was a grand 11 jury investigation of Mr. Epstein, but what 12 it prevents us from doing, what it prevents 13 this Court from doing, I believe, is 14 disclosing the content of the grand jury 15 investigation, and the agreement itself is 16 very specific as to the grand jury 17 investigation of Mr. Epstein. 18 However, all is not lost for the Palm 19 Beach Post and the intervenors, for that 20 matter. The rule has a specific procedure 21 that allows you to go to the district court 22 where the grand jury is convened, in this 23 case it would be in the Southern District 24 of Florida before Judge Marra and that is 25 under Rule 6E, your Honor, I think it's 6E SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231364 19 1 3E actually. It says: In limited 2 circumstances the Court may authorize 3 disclosure of grand jury matters under 4 request made in connection with the 5 judicial proceeding, II -- and the rule 6 goes onto clearly say, that request must be 7 filed in the district where the grand jury 8 is proceeding. 9 ■ the first -- you know the Palm 10 Beach Post may have first amendment rights 11 to access but those first amendment rights 12 cannot circumvent the federally protected 13 secrecy of grand jury proceedings and 14 that's what the Post is doing by making 15 this request before this Court. 16 This matter has been sealed for 17 almost a year now, 11 months and some days 18 and the Palm Beach Post has not filed 19 anything in this matter until most 20 recently, and their remedy is to go into 21 the federal court and invoke the process of 22 Rule Six and asked Judge Marra to make a 23 limited disclosure of the nonprosecution 24 agreement and the grand jury matters that 25 are contained therein. Who knows whether SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231365 1 2 3 he will do it, but that's where thi need to be fought. As a matter of comity.- your 1---r a n 4 this Court should defer to J 5 because, A, he has already r 6 disclosure of the nonpros ag 7 8 9 udge Ma tiled on. -t 1- reement even more importantly, the s -up remac -yam a requires you to defer to the federa ::It_ 1 of criminal procedure that say thes 10 matters should be protected and sho 11 be disclosed unless the district co 12 13 If the Court is going to go c="" 14 wants to go to the issues that wou 1 e￾a 15 contained if it were not dealing wi 16 grand jury proceeding, obviously th ••- r e 17 test that the Court must then use un. e 18 Rules of Judicial Administration andL 19 says matters can be sealed but they 20 be sealed if there's a compel ling 21 government interest or if the sealin_ h 22 important to the administration of 1._.2. s 23 There's a couple other criteria , lou . - t 24 ones obviously that would app 1 Y in _.._ 1.-a. i. 25 case are the compelling government SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT P. PORTEI .___ EFTA00231366 20 1 he will do it, but that's where this battle 2 need to be fought. 3 As a matter of comity, your Honor, 4 this Court should defer to Judge Marra 5 because, A, he has already ruled on the 6 disclosure of the nonpros agreement, but 7 even more importantly, the supremacy clause 8 requires you to defer to the federal laws 9 of criminal procedure that say these 10 matters should be protected and should not 11 be disclosed unless the district court says 12 13 If the Court is going to go on and 14 wants to go to the issues that would be 15 contained if it were not dealing with a 16 grand jury proceeding, obviously there's a 17 test that the Court must then use under the 18 Rules of Judicial Administration and it 19 says matters can be sealed but they should 20 be sealed if there's a compelling 21 government interest or if the sealing is 22 important to the administration of justice. 23 There's a couple other criteria, but the 24 ones obviously that would apply in this 25 case are the compelling government SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231367 21 1 interest, and the importance to the 2 administration of justice. 3 Again, we are dealing with a secret 4 grand jury matter. We cannot circumvent 5 that secrecy by asking the Court to invoke 6 its unsealing power. 7 THE COURT: Thank you. 8 MR. GOLDBERGER: Thank you, your 9 Honor. 10 THE COURT: Let me go over to the 11 other parties and we'll get back to 12 Mr. Goldberger and his client. Post, who 13 wants to go first? 14 MS. SHULLMAN: Mr. Edwards. 15 THE COURT: Mr. Edwards. 16 MR. EDWARDS: Your Honor, inasmuch as 17 Mr. Epstein is relying on Judge Marra's 18 order to support the argument that the 19 nonprosecution agreement needs to remain 20 sealed, I'd like to address that if you are 21 inclined to be persuaded by that argument 22 at all. 23 The orders that have now been moved 24 into evidence are in case No. 80736, and 25 just to put that order in context in SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231368 22 1 actuality, the order says -- specifically 2 puts it back on this Court and confers 3 authority on this Court over this 4 particular document, when in the second 5 page of the February 12th, 2009 order, it's 6 misdated 2009 but it's a 2009 order, and 7 the last two sentences read: If and when 8 petitioners have a specific tangible need 9 to be relieved of the restrictions, they 10 should file an appropriate motion, which we 11 believe we have done in this case, if a 12 specific tangle need arises in the civil 13 cases, which are in circuit court in Palm 14 Beach County, then relief should be sought 15 there and notice to all parties, II to give 16 the Court context for that order, there was 17 a state court plea taken June 30th, 2008, 18 where Mr. Epstein pled guilty to the state 19 court cases as it related to two victims. 20 Now, parallel to that, there was an 21 investigation in federal court where the 22 United States attorney's office and the FBI 23 had more than 30 victims of sex abuse of 24 Mr. Epstein's and they were working with 25 these girls and their cases. Now, several SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231369 23 1 of those girls came to me and said, hey, 2 we're worried that there's a secret deal 3 going on between Epstein and the U.S. 4 attorney's office, so I filed an emergency 5 petition against the U.S. attorney's office 6 asking the federal court to intervene and 7 get in the middle of this and not let this 8 deal go forward without meaningfully 9 conferring with these girls because I was 10 alleging it violated the Crimes Victim's 11 Rights Act; these girls have a right to be 12 heard. That emergency motion was filed 13 July 7th, 2008, and I have that for the 14 Court, and I'd like to enter that into 15 evidence as well. 16 THE COURT: We'll mark that as EW's 17 Exhibit No. 1. 18 MR. EDWARDS: And an emergency 19 hearing was held four days later in front 20 of Judge Marra, who was randomly assigned 21 to this case at the time the plea was taken 22 and the prosecution agreement was sealed. 23 Judge Marra had nothing to do with the 24 agreement, with Epstein, he didn't know 25 anything about it. SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231370 24 1 II four days later now we're in front 2 of him and the United States attorney's 3 office says for the first time, sorry, 4 girls, you are too late, the deal has 5 already been done as to all of your federal 6 cases and it resulted in the nonprosecution 7 agreement that is attached in the state 8 court case. Judge Marra turned to us and 9 said, what is your remedy. 10 At that point in time I said we don't 11 know because we don't know what protections 12 are inside that agreement, II we want you 13 to unseal it, that's where the motion for 14 protective order came about where he gave 15 us the agreement II we can look at it and 16 determine what remedy, if any, was 17 available. Once we had that agreement 18 under the caveat that we were not able to 19 disseminate to third parties and reviewed 20 it and saw there is very little protection 21 for the girls, we asked to unseal it 22 completely, ll that we can talk to third ------------- 23 parties, to victim's rights groups and get 24 some insight as to what our possible remedy 25 would be. SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231371 25 1 And II our reason for wanting him to 2 unseal it at that time was we want to be 3 able to talk to other people, and that's 4 where this order from February 12th, 2009, 5 came in, and he denied that motion to 6 unseal it for three reasons. 7 First and foremost, this 8 nonprosecution agreement was not sealed in 9 my Court, you are talking to the wrong 10 judge, you need to go back, ll we're 11 getting the back and forth here and it's 12 not in my court, I can't mess with some 13 other judge's order. Obviously, there was 14 a hearing held and that document was sealed 15 for a reason, I'm not privy for those 16 reasons, II I'm not going to override 17 whatever that judge was thinking when they 18 sealed that document. 19 Second, your reason is you just want 20 to talk to other people about them, and if 21 I'm going to override some other judge's 22 order, I need to have a more compelling 23 reason than you just want to talk to people 24 about. 25 Third, if and when a specific need SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231372 26 1 arises in any of the civil cases, which by 2 the time this order was coming about they 3 were stacking up in state and federal court 4 against Mr. Epstein, petition that court, 5 petition the appropriate court, and he 6 implies that appropriate court is this 7 court where it was initially sealed, which 8 we've done in this case. 9 This court has none of the problems 10 that Judge Marra had in that it was sealed 11 in this courtroom. We have noticed 12 Mr. Epstein to be heard at this hearing, 13 which is one of the requirements that 14 Judge Marra placed on us, and a specific 15 need has arisen. It has been sealed for 16 over a year now, correct, Mr. Goldberger is 17 correct, but the specific need is arising 18 because we are in the middle of discovery. 19 And this document is, as Mr. Goldberger 20 said, a great inducement to Mr. Epstein 21 pleaing guilty to sex crimes in state 22 court, and to ultimately being labeled a 23 sex offender, and the only document that 24 pertains to my clients, my client as a 25 victim of Mr. Epstein's sex crime, II at SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231373 27 1 the very least, we should be allowed to ask 2 people in deposition and do discovery about 3 how this document came about. There is a 4 need here. 5 THE COURT: I don't quite get -- I 6 don't think it's relevant to what my task 7 is here, but I don't get how it's relevant 8 in the civil cases what the federal 9 government did or didn't do with regard to 10 prosecuting Mr. Epstein. I don't get that, 11 but I don't know that I need to. 12 MR. EDWARDS: The standard for 13 discovery is just reasonably calculated to 14 lead to discovery of admissible evidence 15 and without going in depth we do have 16 intention -- 17 MR. GERBER: Your Honor, can I 18 MR. EDWARDS: And with respect to the 19 grand jury argument, you've seen the 20 document, it's only page five and six that 21 it's even referred to. 22 THE COURT: All right. Let me turn 23 it over to -- does the Post want to speak? 24 MS. SHULLMAN: I do, but I think he 25 wants to go first II whenever. SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231374 28 1 THE COURT: I haven't considered your 2 motion to intervene yet. 3 MR. KUVIN: I don't believe it was an 4 objection. When it was filed, there was no objection by Mr. Goldberger or Mr. Critton. 6 THE COURT: Are you going to advocate 7 by motion to intervene or are you going to 8 be jumping into the merits of the sealing? 9 MR. KUVIN: I'll jump right into the 10 merits, I'm not going to duplicate anything 11 that was just raised or anything that the 12 press is going to raise, I have an 13 individual interest. 14 THE COURT: All right. Go ahead 15 Mr. Kuvin. 16 MR. KUVIN: Very briefly, your Honor. 17 I represent II who has filed only a state 18 court action, she is not under the federal 19 jurisdiction of Judge Marra, she does not 20 subject herself to the federal jurisdiction 21 of Judge Marra, she was never provided an 22 opportunity to brief any issues before 23 Judge Marra with respect to that order that 24 was entered by Judge Marra or either order. 25 In addition, what's also very important is SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231375 29 1 she has never seen this document, so she 2 does not know what is in the contents of 3 the order, so the issue is raised by 4 Mr. Goldberger about the girls are able to 5 6 7 8 9 .10 11 12 see the document and evaluate how they might need to evaluate this document does not apply to my client because she has never seen it and, frankly, without subjecting herself voluntarily to the jurisdiction of Judge Marra, which she chooses not to do, then she cannot get this document, otherwise she would have to go to 13 federal court, submit herself to the 14 jurisdiction of the federal court to then 15 see a state court document, which does not 16 make any sense because if it is a state 17 court document in state court, as 18 previously stated under Judge Marra's 19 order, it is within your purview and your 20 jurisdiction to rule on a state court 21 document. 22 Finally, with respect to why the 23 document may be relevant, the contents of 24 that document speak to the issues of 25 whether or not Mr. Epstein can or cannot SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231376 30 1 assert his fifth amendment right against 2 self incrimination, and we believe on a 3 good faith believe that on the contents of 4 that document speak to the issues of 5 whether or not he can or cannot deny the 6 claims that have been brought against him 7 both in state and federal court. In other 8 words, whether or not he must, in fact, 9 admit that he molested these 14 year old 10 girls, so, therefore, the content of that 11 document is paramount as to the issues in 12 the civil proceedings that are currently 13 pending in state court which is why we 14 would like that document. 15 THE COURT: Okay. Thank you. Thank 16 you so very much. Ms. Shullman from the 17 Post. 18 MS. SHULLMAN: Thank you, your Honor. 19 I feel a little bit like I have stepped 20 into the twilight zone here, so I'd like to 21 address a couple of the things we've 22 addressed and get us to what we are really 23 here to do today. 24 THE COURT: I don't know if you are 25 referring specifically to the courtroom or SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231377 31 1 the convoluted situation that brings us to 2 the courtroom. 3 MS. SHULLMAN: Just this whole 4 federal state situation. There is no hill 5 for the public and the press to march up in 6 Judge Marra's court as Mr. Edwards pointed 7 out, Judge Marra has specifically held the 8 agreement was not filed in this case under 9 seal or otherwise, so were I to march into 10 Judge Marra's courtroom and do my whole 11 public access spiel, he would say take it 12 to you, your Honor, because it's not a 13 record in my court. It is a record here, 14 and in the state court as we talked about 15 the last time, we were here, there's a 16 presumption of openness. The burden is on 17 Mr. Epstein to overcome that presumption. 18 While he filed a very brief memorandum 19 after our last hearing, which identified 20 for interest, he has by no means met the 21 test of either establishing those interest 22 or establishing the remainder of that test 23 which woad be that closures no broader 24 than necessary ineffective no other 25 reasonable alternatives, so if I could, I'd SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231378 32 1 like to sort of focus us back to the 2 inquiry we're here to make today in this 3 court, and that is whether your Honor is 4 going to provide public access to two 5 records that are, I think, indisputably in 6 your Honor's court file in this court's 7 file. 8 It's a plea agreement and an 9 addendum; those are historically and 10 typically open records. 11 Mr. Goldberger mentioned that the 12 plea agreement was sort of incidentally 13 filed in this court file, and that it was 14 sort of an afterthought that happened. He 15 never came into court intending that it 16 even be part of the court file, but 17 Judge Pucillo specifically said, this is a 18 significant inducement to accepting the 19 plea in my court. This agreement that you 20 have with federal prosecutors is 21 significantly the reason why you're 22 entering this plea before me. And she took 23 those records into the court file 24 presumably because they are significant to 25 this litigation. Even if there was an SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231379 33 1 incidental filing, which cannot possibly be 2 the case here, there is no mechanism in 3 Florida law to call a Mulligan and to pull 4 it out of the court file. As you know, the 5 Floridians have a constitutional right of 6 access, there's no mechanism in that law to 7 just say, oopsy, let's take it out of the 8 file, so they have to meet their burden and 9 they have to show under Rule 2.420 that one 10 of those interests is satisfied. They have 11 identified four here. I have not heard 12 them discuss them at any great length. But 13 I will go through them quickly. 14 The imminent threat to the fair, 15 impartial orderly administration of 16 justice, or to protect a compelling 17 government interest. As your Honor is 18 aware, the federal government is not here 19 today. I have spoken with the state 20 attorney's office who has indicated that 21 their only interest is in protecting to the 22 extent necessary because I've not seen 2-1 these documents the identity of the victims 24 of these crimes. 25 The Post in its motion to intervene SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231380 34 1 has already set forth that we have no 2 objection to redacting the victim's names 3 if, in fact, that is required because we 4 haven't seen the agreement. To avoid 5 substantial injury to innocent third 6 parties, again, absolutely no showing on 7 that test. I have no burden at this point, 8 but I will simply state that the law in 9 Florida is clear that Mr. Epstein doesn't 10 have standing to assert that interest. 11 And, finally, something else I heard 12 nothing about to avoid substantial injury 13 to a party which, I guess, presumably would 14 be Mr. Epstein by disclosure of matters 15 protected by a privacy right not generally 16 inherent in this specific type of 17 proceedings. Again, I have not heard any 18 attempt to meet the burden on that issue, 19 however, Florida law is equally clear that 20 participants in crimes lose their privacy 21 interest in the matters and facts and 22 circumstances of the commission of those 23 crimes, so Mr. Epstein surely cannot 24 establish that there is a separate privacy 25 interest not inherent in a criminal SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231381 35 1 prosecution regarding the molestation of 2 young girls. 3 The circumstances under which closure 4 is allowed in Florida are exceedingly 5 narrow. We first -- and before we do 6 anything else -- have to find that one of 7 those interests is met here, that it exists 8 and that the movant has met its burden in 9 demonstrating that it's significant enough 10 to require the court to consider closure. 11 That's not the end of inquiry. And, of 12 course, I have not yet heard anything else 13 about that second half of the test which 14 talks about the idea that closure is no 15 broader than necessary to protect that 16 interest and that it would be effective and 17 that there are no other alternatives. 18 In speaking of the federal litigation 19 there are instances when both Mr. Epstein's 20 lawyers and the federal prosecutors have 21 placed portions of the agreement into the 22 public court file. There are -- thus 23 attempts to seal those records in the • 24 federal litigation have been unsuccessful, 25 so part of this agreement the cat is SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231382 36 1 already out of the bag. But there is also 2 an enormous public interest in what's going 3 on here, apart from the idea that this man 4 is accused of having many, many victims who 5 were all young children which, of course, 6 in itself creates a lot of public concern, 7 the chief of police at the time sent a 8 letter to the state prosecutors and said, 9 what are you guys doing, how are you 10 handling this, this is highly unusual; I 11 don't like what I'm seeing here. And even 12 went so far as to say, state attorney's 13 office, should you all step away from this 14 case. 15 So we have public interest from the 16 perspective of the police chief questioning 17 the state attorney's office about whether 18 it's doing its job. We have public 19 interest that's spurned by the idea that 20 some of the victims in the federal 21 prosecution -- in the federal court claimed 22 they weren't aware of it, we just heard — 23 — Mr. Edwards talk about the fact that his 24 clients weren't aware of the agreement 25 unless it all went down, so we have a SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231383 37 1 significant public interest about how 2 everybody in this litigation is doing their 3 job. There is nothing more fundamentally 4 important than the ability of the public 5 and the press to observe how its 6 government, all branches of its government, 7 do its job. 8 There are multiple, as Mr. Edwards 9 also mentioned, multiple civil lawsuits 10 that have spurned as a result of 11 Mr. Epstein's conduct, and, again, the 12 public has an interest in what's going on 13 in civil litigation matters. 14 In short, this matter involves a 15 major public interest from a lot of 16 different levels. There is no basis for 17 closure that has been asserted here. It's 18 a heavy burden to meet. We start with the 19 idea that openness is the right thing to do 20 but there is essentially no purpose served 21 at this point by keeping these agreements 22 sealed in this case. 23 Unless your Honor has any questions, 24 I think that's it. 25 THE COURT: Okay. Thank you so very SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231384 38 1 much. Ms. Burns, on behalf of the state of 2 Florida, anything you'd like to add or 3 advocate? 4 MS. BURNS: If I may, your Honor. 5 THE COURT: Sure. 6 MS. BURNS: Good afternoon, your 7 Honor. 8 THE COURT: Good afternoon. 9 MS. BURNS: Your Honor, the State is 10 not here to take a position on whether or 11 not this court should seal -- continue to 12 seal the records or unseal the records. We 13 are here merely to uphold the state laws 14 which require all of us as members of the 15 judicial system to protect the rights of 16 the confidentiality of the victims. I do 17 see two issues here, your Honor. 18 One is if you decide to unseal the 19 records based upon the arguments that have 20 been presented to you, then the State would 21 ask that the court first do an incamera 22 viewing, not just merely open up that 23 portion of the file for viewing by all 24 interested parties, first, that the Court 25 do an incamera viewing to make two SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231385 39 1 evaluations. 2 Number one, does the document, in 3 fact, have a relationship to the criminal 4 case in the state matter. And, number two, 5 evaluate the right of public access versus 6 the victim's right to confidentiality. If 7 this Court does decide to unseal those 8 records, then the State would ask that this 9 Court before making the document public 10 access, then make certain that in place is 11 that the victim's identities are amended to 12 initials if their names are used. 13 The State does have a concern 14 regarding the argument of the Federal Rule 15 Six in that is this Court bound by a 16 federal rule which perhaps has been made 17 unenforcible by virtue of making it a part 18 of the state file, so I think the Court 19 also would need to address that issue 20 before making its ruling. 21 THE COURT: All right, great. Thank 22 you so much. 23 MS. BURNS: Thank you, Judge. 24 THE COURT: One last chance for the 25 federal government, they're not here and SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231386 40 1 I'll let rebuttal of any other 2 presentation, Mr. Goldberger, or, 3 Mr. Critton, you'd like to make. 4 MR. GOLDBERGER: Thank you, your 5 Honor. As to the last argument made by 6 Ms. Burns as to the applicability of 7 Federal Rule 6 of the Rules of Federal 8 Criminal Procedure it's something that we 9 learned in the law school that the 10 supremacy clause controls and to the extent 11 there's a conflict between the federal 12 doctrine and the state doctrine, the 13 supremacy clause requires the federal rule 14 of law to apply and to control. And 15 certainly in this case you cannot use a 16 state procedure to circumvent a federal 17 rule of criminal procedure that confers 18 secrecy to a grand jury proceeding. 19 And the Palm Beach Post response to 20 the argument never made note of the grand 21 jury rule, they simply avoided that issue 22 and that in our mind is equally important 23 as the fact in the interest of comity this 24 Court should defer to the rulings of 25 Judge Marra already. SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231387 41 1 As to Mr. Kuvin's argument that he 2 has a client that is in state court and is 3 not in federal court and therefore he 4 doesn't have a remedy in federal court. 5 With all due respect to Mr. Kuvin, that's 6 similarly wrong. Judge Marra's order 7 spebifically dealt with a class of 8 individuals who were identified as victims 9 of Mr. Epstein's conduct, and Judge Marra's 10 order says that anyone who's been 11 identified by the United States attorney's 12 office as a victim has right to the 13 nonprosecution agreement under the same 14 rules. 15 Just so the Court understands, I know 16 we are talking like the Court understands 17 everything about this case. There was a 18 list of victims that was created at the 19 time that the nonprosecution agreement was 20 entered into and Mr. Kuvin's client is on 21 that list. That list was created by the 22 U.S. attorney's office. He has the same 23 rights to the nonprosecution agreement as 24 if he filed this case in federal court and 25 he knows that we've told him that he has SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231388 42 1 that access. 2 As to the fact that the 3 nonprosecution agreement is presumably not 4 filed in the federal case in our last 5 hearing in front of Judge Marra on June 5th 6 -- I'm sorry, June 12th, Mr. Edwards 7 advised Judge Marra that he had, in fact, 8 filed a nonprosecution agreement to no 9 one's surprise under seal in the federal 10 file, so the nonprosecution agreement 11 according to Mr. Edwards' declaration at 12 that hearing is contained in the federal 13 court system. 14 For all of those reasons, your Honor, 15 and the reasons that I previously indicated 16 to the Court, we would ask the Court to 17 defer to the federal court in this matter. 18 THE COURT: Okay. Thank you very 19 much. Here is what I'm planning on doing, 20 so you know where I'm going on this. I'll 21 make an oral announcement and I'll follow 22 it up with a written order so that you all 23 can have something to take to wherever you 24 want to take it. 25 I find that the appropriate procedure SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231389 43 1 to seal or close these documents has not 2 been met, so I'll deny the motion to seal 3 the documents. I'll grant the motion to 4 unseal them. I will take a look at the 5 documents. I will redact out of them 6 the -- what I'll do is, I'll leave the 7 originals intact sealed in the court file 8 to protect the names of any underage 9 victims. 10 I will make copies of those. I'll 11 redact out the names leaving -- expose the 12 initials of any of the individuals. I'll 13 get that done -- I'll get my written order 14 out granting and denying the respective 15 motions hopefully by the end of today. If 16 not today, tomorrow. I plan on releasing 17 the redacted versions probably Monday, so 18 that those will be available for public 19 consumption on Monday. 20 MR. GOLDBERGER: Your Honor, thank 21 you. Thank you for the oral pronouncement. 22 Your Honor, based on the Court's ruling, we 23 do have a motion to stay disclosure of the 24 nonprosecution agreement. The rules of 25 appellate procedure require us to file that SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231390 44 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 before, your Honor. Your Honor, we do intend to take certiorari on this to the Fourth District Court. THE COURT: That's why I figure between the written rule and the disclosure give you a chance to catch your breath and do that. I guess you might want that. Is Monday 5 p.m. enough time for you to get over to the DCA? MR. GOLDBERGER: Actually, your Honor, the Rule of Appellate Procedure maintains matter to THE jurisdiction with you on this entertain the motion to stay. COURT: So I need to handle the motion to stay? MR. GOLDBERGER: Correct, your Honor. THE COURT: Do you want to argue that now? Do you want to take a look at that, catch your breath, come back and see me Monday sometime; what's your pleasure? MR. GOLDBERGER: We're ready to do it now, your Honor. We're ready to do it now. THE COURT: All right. Interveners, your thoughts. SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231391 45 1 MR. KUVIN: Matter of procedure 2 point, I just want to make sure that the 3 motion to intervene is, in fact, granted. 4 THE COURT: You're motion to 5 intervene is granted. Do you have a 6 written order for me to sign off on there? 7 MR. KUVIN: I can submit that. 8 THE COURT: Why don't you catch your 9 breath and come back tomorrow and I'll hear 10 argument. It will give me a chance to read 11 the motion, check out the rules, take a 12 look, got to get myself gassed up. Anybody 13 want to drop anything off for me to read 14 before the hearing, please do that. Why 15 don't we do that tomorrow morning, and why 16 don't we reconvene here tomorrow at 1:30 on 17 the motion to stay. 18 MR. GOLDBERGER: That's fine. 19 THE COURT: How does your schedule 20 look? 21 MR. GERBER: Your Honor, is it 22 possible to have it a little later, perhaps 23 an hour later tomorrow? 24 THE COURT: 2:30. 25 MR. GERBER: If possible. SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231392 46 1 THE COURT: How about a little later 2 than that still, let me take a look at our 3 official calendaring system here. 4 MR. CRITTON: Judge Colbath, I'm gone 5 tomorrow, I'm going to Gainesville at one 6 or 12:30-ish. I told my wife I would be 7 home at one. My daughter's birthday, 21, 8 she's having a party, I plan to be there. 9 Can we do it tomorrow morning any time, it 10 would be great. 11 THE COURT: Tomorrow morning is ugly. 12 This isn't going to take long. 13 MS. BURNS: This is a five-minute 14 motion. 15 THE COURT: Why don't we do this, 16 meet at 8:15? 17 MS. SHULLMAN: Your Honor, I'm not 18 going to be able to get my kids to school 19 if I have to be here at 8:15. My husband 20 is in California right now. 21 MR. GOLDBERGER: I don't mean to jump 22 in. I wonder if we can do some of this -23 telephonically. 24 MS. SHULLMAN: Yes, I can appear by 25 phone or I can have one of my partners. SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231393 47 1 THE COURT: In the morning what would 2 be a good start time for you? 3 MS. SHULLMAN: Nine would be getter. 4 I can't drop them off before eight. 5 THE COURT: It's going to be brief 6 argument, let's do it 9:00 tomorrow 7 morning; 9:00 work for you? 8 MR. CRITTON: Yes, sir. Thank you. 9 MR. GOLDBERGER: Just very briefly, 10 the Court is going to look at the 11 nonprosecution agreement and do some 12 redacting, I believe. I just need to 13 advise the court in addition to Mr. Epstein 14 and perhaps victims mention the 15 nonprosecution agreement, there are third 16 parties who the Court needs to look about 17 redacting their names also, and that's 18 contained in the nonprosecution agreement. 19 In other words, there are other 20 people beside Mr. Epstein and Mr. Victims 21 whose names are mentioned in the 22 nonprosecution agreement, and I would ask 23 the Court to look at those names also for 24 the purpose of redacting. 25 THE COURT: I'll like a look. SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231394 48 1 MR. EDWARDS: Your Honor, those are 2 not names of victims, those are 3 co-conspirators as listed in the agreement 4 and we would object to any redaction of those names. I don't think there's any 6 standing to ask for that. 7 THE COURT: I'll take a look. All 8 right. See you all tomorrow morning at 9 nine. If you want to send anything to me 10 later this afternoon or tomorrow morning 11 before we take the bench, I'm happy to 12 receive it. Have a good afternoon. 13 (Proceedings concluded.) 14 15 16 17 18 19 20 21 22 - 24 25 SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231395 49 1 2 CERTIFICATE 3 4 THE STATE OF FLORIDA, 5 COUNTY OF PALM BEACH. 6 I, SUSAN S. WIGGINS, R.P.R. Official 7 Court Reporter for the Fifteenth Judicial Circuit, 8 Criminal Division, in and for Palm Beach County, 9 Florida; do hereby certify that I was authorized 10 to and did report the foregoing proceedings before 11 the Court at the time and place aforesaid; and 12 that the preceding pages numbered from 1 to 48, 13 inclusive, represent a true and accurate 14 transcription of my steno notes taken at said 15 proceedings. 16 IN WITNESS WHEREOF, I have hereunto 17 affixed my official signature this 29th day of 18 June, 2009. 19 20 21 (7).#/4" (13 tt) CAA 22 SUSAN S. WIGGINS, .P.R. 23 24 25 SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231396 LEGAL RECYCLED PAPER .................. •111 I° REORDER ( 9.544;46,3,n. EFTA00231397 1 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 2 IN AND FOR PALM BEACH COUNTY, FLORIDA CRIMINAL DIVISION 3 STATE OF FLORIDA ) 4 ) vs. ► CASE No. 2008CF009381AXX 5 ) JEFFREY EPSTEIN, ► 6 ) Defendant. ) 7 CERTIFIED COPY 8 PROCEEDINGS BEFORE THE COURT 9 PRESIDING: HONORABLE JEFFREY COLBATH 10 APPEARANCES: 11 ON BEHALF OF THE STATE: 12 BARRY E. KRISCHER, ESQUIRE State Attorney 13 401 North Dixie Highway West Palm Beach, Florida 33401 14 By: BARBARA BURNS, ESQUIRE Assistant State Attorney 15 ON BEHALF OF THE DEFENDANT: 16 JACK GOLDBERGER, ESQUIRE 250 S Australian Ave Ste 1400 17 West Palm Beach, Florida 33401 And 18 ROBERT CRITTON, ESQUIRE 515 N Flagler Dr Ste 400 19 West Palm Beach, Florida 33401 20 ON BEHALF OF THE PALM BEACH POST: DEANNA SHULLMAN, ESQUIRE 21 Thomas, LoCicero & Bralow 101 N.E. 3rd Avenue - Ste 1500 22 Fort Lauderdale, Florida 33301 23 ON BEHALF OF EW, THE INTERVENER: WILLIAM J. BERGER, ESQUIRE 24 BRAD EDWARDS, ESQUIRE 225 NE Mizner Blvd Ste 675 25 Boca Raton, Florida 33432 SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231398 2 1 ON BEHALF OF EB, MOTION INTERVENER'S PLEADING: 2 SPENCER KUVIN, ESQUIRE 2925 PGA Blvd Ste 200 3 Palm Beach Gardens, Florida 33410 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 June 26, 2009 24 Palm Beach County Courthouse West Palm Beach, Florida 33401 25 Beginning at 9:59 o'clock, a.m. SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231399 3 1 BE IT REMEMBERED that the following 2 proceedings were had in the above-entitled cause 3 before the HONORABLE JEFFREY COLBATH, one of the 4 judges of the aforesaid court, at the Palm Beach 5 County Courthouse, located in the City of West 6 Palm Beach, State of Florida, on June 26, 2009, 7 beginning at 9:59 o'clock, a.m., with appearances 8 as hereinbefore noted, to wit: 9 THEREUPON: 10 THE COURT: Epstein. 11 MR. GOLDBERGER: Yes, your Honor. 12 THE COURT: Let me call up the State 13 of Florida versus Epstein. Let's have 14 everyone announce their appearance, please, 15 name on the record. 16 MR. CRITTON: Robert Critton and Jack 17 Goldberger on behalf of Mr. Epstein as well 18 as Barbara Compiani from the office of Jane 19 Walsh. 20 MS. SHULLMAN: Deanna Shullman of 21 Thomas, LoCicero and Bralow on behalf of 22 the Palm Beach Post. 23 MR. KUVIN: Spencer Kuvin on behalf 24 of the intervener ■. 25 MS. BURNS: Barbara Burns on behalf SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231400 4 1 of the State of Florida. 2 THE COURT: That's it. 3 MR. CRITTON: That's it, it's a wrap. 4 THE COURT: Okay. Orders. Who's not 5 here that I have to mail it to? 6 MR. GOLDBERGER: Mr. Edwards is not 7 here, your Honor. 8 THE COURT: Okay. Mr. Berger, 9 Mr. Edwards. Did I give you enough copies 10 of the order? 11 MR. GOLDBERGER: I ran out. I have 12 just enough. Do you want me to get a copy 13 to Mr. Edwards? 14 THE COURT: Yes, if you'd mail a copy 15 to Mr. Edwards. I got spares if anybody's 16 interested. Anybody need a spare? 17 MR. GOLDBERGER: We're good, your 18 Honor. 19 THE COURT: All right. Motion to 20 Stay, Mr. Goldberger. 21 MR. GOLDBERGER: Thank you, your 22 Honor. 23 THE COURT: Mr. Critton. 24 MR. CRITTON: Good morning, Judge 25 Colbath, do you have a copy of our Motion SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231401 5 1 to Stay? 2 THE COURT: I do, the one that was 3 handed up to me yesterday? 4 MR. CRITTON: Yes, sir, and I have a 5 proposed order in the event the Court 6 chooses to grant; may I provide that to the 7 Court as well? 8 Your Honor, as you know, 9 Mr. Goldberger and I represent Mr. Epstein. 10 We have hired Ms. Walsh and Ms. Compiani as 11 appellate counsel to assist in the filing 12 of a writ of certiorari. I know that comes 13 as no surprise to the Court in that whoever 14 prevailed and lost yesterday, I think the 15 Court recognized we probably filed a writ 16 of certiorari. 17 THE COURT: Let me ask real quick. 18 Anybody objecting to the defendant having 19 the ability to have my decision reviewed by 20 the appellate court before I release these 21 things? I mean, it seems pretty straight 22 forward. 23 MS. SHULLMAN: We have an objection, 24 your Honor, to some extent. The -- you 25 know, the procedure in place here is very SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231402 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 similar to that for which they would have to obtain a preliminary injunction. THE COURT: Right. MS. SHULLMAN: So to demonstrate likelihood of success and irreparable harm, I don't think they can do that. I think the plan that you put in -- proposed yesterday is a good one, that is you redact and you release on Monday and that gives them today and Monday to get to the Fourth, otherwise, we're stuck in a position where we have a 30-day window to appeal, and we are all delay, delay, delay. THE COURT: What if I do that? I don't know if it's a difference with that or distinction, but, procedurally, I was thinking I was leaning yesterday towards issuing the order that I just issued. I think that that's a fairly accurate rendition of the written version of my oral pronouncement yesterday, but I order that nothing -- that the redacted orders not be released until -- I'll make it, you know, five of five Monday. That will give you Monday to get down to the Fourth to get SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231403 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 them to stop this from being released; what do you think? MR. CRITTON: Here's what the problem is, Judge, is Ms. Compiani and Ms. Walsh spoke to them yesterday and today, we need a transcript from the hearing yesterday which has not yet been obtained. They need the underlying motions, they need some time to research. It's not a matter of simply filing a writ of petition and that stays the release of the order. There would have to be a separate motion that would be filed with the Appellate Court. The Motion to Stay that we file under 9.310, subsection A, it party that seeks review Appellate Rule provides that the shall come to the lower tribal, which is the trial court, which is you, in this instance, and then it's within your discretion either to stay or not to stay under the circumstances, and we simply don't have the time within which to file the appeal under those 23 circumstances. 24 There are two criteria that have 25 to be met here, one is the likelihood of SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231404 8 1 2 3 harm where no stay is granted, and the second criteria, not necessary mutually exclusive; that is, you don't have to have 4 both of them, but you certainly have to 5 give an indicia of both of them. The 6 second one is the likelihood of success on 7 the merits. 8 we believe that based upon the 9 Court decision, respectfully, that the 10 Court, that the Appellate Court, will quash 11 your order, for the reasons Judge Puccillo 12 was the one who requested that the document 13 in this -- this was argued yesterday, so 14 I'm going to be very brief. She is the one 15 who requested post sentencing, that the 16 document be filed under seal. It was her 17 request that the defense seceded to that 18 under the circumstances. That certainly 19 was inadvertent, could have just as easily 20 remained under seal with Mr. Goldberger or 21 with the State Attorney under those 22 circumstances. 23 Secondly, that it relates to the 24 portions of it, specifically, within the 25 MPA to deal with the grand jury proceeding, SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231405 9 1 that would be a violation of Federal Rule 2 Six. I note you just handed us your order 3 about two minutes ago, Judge, so no one's 4 had an opportunity to review it, certainly 5 appellate counsel has not had an 6 opportunity to review it. I don't know if 7 you dealt with the appellate rule, but I do 8 note that within your written order, that 9 you, basically, said that in the second to 10 last page, you said this order is no way to 11 be interpreted as permission not to comply 12 with U.S. District Court Judge Marra's 13 previous orders. 14 We respectfully submit that it would 15 not comply with Judge Marra's previously 16 issued orders. We also believe that the 17 supremacy clause, as Mr. Goldberger argued 18 yesterday in conjunction with comity 19 principle, that we think that there's a 20 substantial likelihood on success of the 21 merits on this. 22 with regard to the likelihood of 23 harm, this is a paramount issue here. It's 24 undisputed that this was a confidential 25 agreement. It's a confidential contract SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231406 10 1 between Mr. Epstein and the United States. 2 United States vigorously defended 3 Mr. Edwards when he came into federal court 4 and filed an action to have the MPA 5 released, Judge Marra subsequently entered 6 an order. Another attempt that was made to 7 make the MPA public again. 8 All plaintiffs' counsel has it. 9 The only ones that don't have it is the 10 Post, under the circumstances, and public 11 under the circumstances, but all the 12 plaintiffs' lawyers of the alleged victims, 13 they either have the MPA and the addendum, 14 which I will refer to as the MPA, or they 15 have the ability to get that. That is very 16 clear from Judge Marra's order. 17 So there's certainly no harm to 18 the plaintiffs from under these 19 circumstances. And the harm in this 20 instance is only to Mr. Epstein under the 21 circumstances because as Judge Letz 22 (phonetic) once said, it's very much like 23 an attorney/client privilege or a privilege 24 document where once the proverbial horse is 25 out of the barn, you can't get him back in. SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231407 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 11 We cited a case called mariner versus Baker 3 -- So. 39, So.2d 608 First District 1989. In the Mariner case, this was not a usual incident report and the Court, I know your Honor previously did a great deal of personal injury work and related work, you're very familiar. In fact, you commented yesterday and said, I don't see how the MPA is going to be admissible in a civil proceeding anyway. Again, you're not ruling on that ultimately, the judges in both the State and federal court cases will do that. In the Mariner case, the judge ordered that the defendants object at the direction of incident reports. The judge said, sorry, you've got to produce those incident reports. And the Court said, give them to me under seal because, again, we are talking about incident reports as distinct from an agreement between two parties which was deemed to be confidential 23 between the United States government and 24 Mr. Epstein. Only irreparable harm here as 25 to Mr. Epstein because if it's released, SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231408 12 1 you cannot remedy that harm on appeal. 2 And in the Mariner case, if the judge 3 said, if you put the documents under seal, 4 which is exactly the situation we have now 5 is, I will grant the stay and let the 6 appellate court determine whether or not 7 incident reports, which have a much lower 8 threshold for production or for discovery 9 reasons, and, again, there's no harm in an 10 instance like that, even in an incident 11 report came out in the Mariner cases, so 12 what. It won't be used, you can't use any 13 of the information you obtained. In this 14 particular instance, because it is 15 confidential, there is no way the Court can 16 remedy the harm. 17 With regard to the defendants in this 18 case, again, I think we've demonstrated 19 both irreparable harm, and we believe a 20 substantial likelihood on the success. 21 Again, how do you demonstrate a substantial 22 likelihood on the success? The fact that 23 we would -- if this Court thought that we 24 should prevail, my guess, you would not 25 have ruled as you did, but as the Court is SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231409 13 1 aware, oh, surprise to all of the lawyers 2 here. Sometimes judges get reversed. I 3 know that's a shock to most of the lawyers 4 in this room and most of the courts, but 5 that happens on occasion, and, therefore, 6 we believe we can show through the 7 supremacy clause, the grand jury reference 8 that we will prevail and that your order 9 will be quashed. 10 With regard to alleged harm by any 11 other party, the Post in this instance 12 reported at the sentencing of Mr. Epstein 13 on or about June 30th of 2008. They waited 14 until June 1st of '09. This was such a 15 pressing issue, the Post wanted to get this 16 desperately out to the public, they were so 17 anxious to do it, that they waited 11 18 months before they did anything. 19 Mr. Edwards, who is not here 20 today, filed a federal court action and 21 those issues were talked about and 22 discussed at some length with regard to 23 Judge Marra's two orders. 24 Judge Marra's rule, you can't get 25 them, if you want to get them, go to that SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231410 14 1 case, that would be Judge Hafele or two of 2 Mr. Edwards' cases are where is Mr. Kuvin's 3 case is or Judge Marra, where Mr. Edwards' 4 case is. Judge Marra can certainly control 5 whether or not they should be released, and 6 I've covered Mr. -- oh, and Mr. Edwards 7 because he could have gone back to Judge 8 Marra because he's got one federal court 9 case -- did he try for that form and get 10 it no, they came in here. He tried to 11 do it in a run around Judge Marra. 12 He didn't file his motion until 13 late May of '09. My guess is it was 14 Mr. Edwards who probably said to the Post, 15 gee, why don't you join in this, you 16 haven't been here for 11 months, why don't 17 you come in now, maybe intervene. And then 18 Mr. Kuvin, on behalf of his client, II 19 estate court case, came in on June 11th, 20 again, almost a year to the date after 21 Mr. Epstein's sentence. 22 It's no burning issue, there's no 23 fire here to put out, giving us 30 days, or 24 at least a reasonable period of time to 25 file petition for writ, and then if the SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231411 15 1 Court denies our stay at least asking the 2 appellate court for stay under the 3 circumstances. There's no harm to them. 4 The harm is only to Mr. Epstein, and we 5 think as a substantial likelihood, that we 6 would succeed. 7 Therefore, we would request the 8 Court grant a stay as I've suggested in my 9 proposed order for 30 days of giving 10 Ms. Walsh and Ms. Compiani an opportunity 11 to actually do their job under the 12 circumstances, so the court reporter 13 doesn't have to work over the weekend to 14 expedite transcripts for us, and secondly, 15 if we file within the 30 days, then let the 16 appellate court determine whether or not 17 the stay remains or not. 18 THE COURT: Thank you much. 19 Ms. Shullman, don't worry about 20 responding to the issue of motive or 21 seeking this relief or the timing of your 22 request or party's request. I don't think 23 that bears upon the merits of either 24 parties. 25 MS. SHULLMAN: The constitutional SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231412 16 1 2 3 4 5 right of access doesn't have a waiver provision, your Honor. THE COURT: Well, go ahead. Let me hear -- I'm on board so far with Mr. Critton's version of, Judge, if you let 6 it out, you let it out, so irreparable harm 7 8 9 10 11 is kind of easy. I think that it is a two-prong test. I think he's got to jump over both hurdles. I think he's got to show some likelihood of success. If you want to spend some energy arguing that 12 there's no irreparable harm, you may do so, 13 but if I hand it out today and everybody 14 gets to see it, you can't fix that 15 tomorrow. 16 MS. SHULLMAN: Sure. 17 THE COURT: So I think they've 18 established that. 19 MS. SHULLMAN: Let me address that 20 very briefly first, your Honor, to remind 21 you in meeting this burden that they failed 22 to meet yesterday, they identified four 23 interests which they liken now to the 24 motion to stay to the four harms. 25 One, of -- for the first three of SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231413 17 1 them, they mentioned they have no standing 2 to assert the compelling government 3 interest, the government didn't show up, 4 the imminent threat to the administration 5 of justice, again, that's the government's 6 issue. The innocent third party privacy 7 rights, they have no standing. The only 8 one is, he's not really articulated today 9 it's some sort of invasion of Mr. Epstein's 10 privacy rights. 11 Florida law is clear that those 12 who are participants in crimes do not have 13 privacy rights with respect to the facts 14 and circumstances surrounding those crimes. 15 So unless I'm going hear something outside 16 of the context of Mr. Epstein's criminal 17 prosecution, he has no privacy right in 18 this agreement. 19 THE COURT: Let me share with you 20 what I'm thinking about doing, even at the 21 conclusion of Mr. Critton's presentation, 22 and that is deny the motion to stay, but 23 delay the release of the records in 24 question until noon Friday. That will give 25 them a little bit of time to see if the SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231414 18 1 Fourth sees this case from a different 2 vantage point, a different light, and maybe 3 they'll look down and say, oh, Judge 4 Colbath, you missed it and, you know, stay 5 the matter. That will give them a 6 reasonable amount of time to get the 7 transcripts to go to the Fourth because I'm 8 a big fan of appellate review and making 9 case law. 10 MS. SHULLMAN: And I understand, your 11 Honor, if you are suggesting a week from 12 today, that's a little bit long. Remember 13 the status quo here, we are in sort of a 14 strange procedural posture because your 15 Honor decided that the initial closure was 16 improper, but the recent request for 17 closure was denied, so instead of a status 18 quo where we have a document that should be 19 released, it's under seal where it 20 shouldn't be, so any moment that it is kept 21 under seal is a serious deprivation of the 22 public and the press's right to access, 23 which you have already determined they 24 have, we think you are correct, of course, 25 so I would ask that any stay -- SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231415 19 1 MR. CRITTON: She's pandering, your 2 Honor. 3 MS. SHULLMAN: I will say he 4 respectfully disagreed with you, so I think 5 a week is too long. I do this day in and 6 day out, I have spent many a weekend on 7 these matters in my career. If you want to 8 give them till Tuesday, I'll be kind, but 9 the Fourth will act quickly on this. I 10 don't think that a week's delay is 11 necessary. I think, in fact, it under 12 minds the public purpose here. 13 THE COURT: All right. Any other 14 respondents want to go anything further? 15 MS. SHULLMAN: The State Attorney's 16 office also advises me that Friday is a 17 holiday and the courts are closed. 18 THE COURT: Thank you for telling me 19 that. Friday is a holiday. 20 MR. KUVIN: July 4th. 21 THE COURT: The day of the birth of 22 our constitution. 23 MR. KUVIN: Good morning, your Honor. 24 On behalf of intervenor II, obviously, the 25 Court is inclined to delay the disclosure SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231416 20 1 of this, but under Rule 9.310, if your 2 Honor were to issue such a stay, we would 3 point out the provision C of the rule, 4 which requires a posting of the bond. 5 We not only agree with your Honor's 6 ruling, but we believe such appeal they are 7 filing is absolutely frivolous and we are 8 going to be requesting fees and cost for 9 the filing of that appeal, so as a result, 10 we are requesting a bond be posted if a 11 stay of any type is issued in this case 12 because of the fact that we want to make 13 sure that our attorneys' fee and costs are 14 covered for the frivolous nature of the 15 appeal. And it's dictated strictly in 16 subsection A. It gives the Court the 17 authority. It says: 18 A stay pending review may be 19 conditioned upon a good and sufficient 20 bond, other conditions or both. Therefore, 21 we believe your Honor does have the 22 authority to issue such a requirement that 23 the posting of a bond be issued. 24 THE COURT: All right. Thank you 25 very much. I will deny the motion to stay. SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231417 21 1 I will delay the release of the documents 2 until noon Thursday. I will deny the 3 request to compel the movant, the 4 defendant, Mr. Epstein, to post a bond, and 5 I'll let the appellate court tell us and 6 teach us what the law on this case will be. 7 It's always interesting how these 8 cases unfold and come to us a little 9 different than everyone else. Now, let me 10 have the attorneys come up here and 11 approach. 12 (The following proceedings were held 13 sidebar, out of the hearing of the jury.) 14 THE COURT: I reviewed the two 15 documents, I didn't see any kids' names in 16 there. Everybody was hinting the 17 children's names or the initials' names. I 18 had my big black highlighter out, I don't 19 see anything worth redacting, so. 20 MR. GOLDBERGER: it's the plaintiff's 21 document that identifies the children's 22 names. It's a letter to me actually. 23 THE COURT: I was wondering if 24 everybody thought there was something in 25 there that wasn't in there. SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231418 22 1 MR. CRITTON: It's a test of your 2 skills, your Honor. 3 THE COURT: You're right, exactly. 4 One is page one through seven, and the 5 second one is just two pages that's not 6 even signed by everybody. 7 MR. GOLDBERGER: While we're all up 8 here chatting, there are references to 9 other names up here. 10 THE COURT: Yes, Mr. Goldberger, and 11 no one has identified in the document says 12 these are people that are not going to be 13 prosecuted. Mr. Kuvin made the argument 14 that these are co-conspirators. These are 15 innocent people that have nothing to do 16 with these proceedings. They have nothing 17 to do with -- 18 MS. SHULLMAN: They have a standing. 19 THE COURT: I will renew my ruling 20 that I gave you yesterday, and deny your 21 request to redact those names out of there. 22 All right, so I'll hang on to these till 23 Thursday at noon, and anybody that comes 24 wants to come and get them, I don't know if 25 there's a mechanism for -- I stand on the SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231419 23 1 courthouse steps and pass them out. 2 MS. SHULLMAN: If there are no 3 redactions to be made. 4 THE COURT: No redaction. 5 MS. SHULLMAN: I would do an order 6 directing the Court to release them and 7 they may become unsealed. You don't 8 need -- 9 MS. COMPIANI: Your Honor, are you 10 going to write up a written order 11 denying -- 12 MR. GOLDBERGER: Are you going to do 13 that? 14 THE COURT: Put together a written 15 order? 16 MS. SHULLMAN: Denying the stay? 17 THE COURT: Yes, A, denying the stay; 18 B, delaying the disclosure or unsealing of 19 these documents until noon Thursday; C, 20 denying the motion for bond. 21 MR. GOLDBERGER: And you'll need that 22 order quickly. 23 THE COURT: Yeah, fax that and we'll 24 get it signed quick today. 25 MR. GOLDBERGER: Are you forcing the SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231420 24 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 court reporter to work over the weekend so we can get a transcript? MR. CRITTON: Thank you, your Honor, for moving us this morning. (Side bar conference held outside the hearing of the jury concluded.) SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231421 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 June 2009. 19 20 21 22 23 24 25 CERTIFICATE THE STATE OF FLORIDA, COUNTY OF PALM BEACH. I, SUSAN S. WIGGINS, R.P.R., Official Court Reporter for the Fifteenth Judicial Circuit, Criminal Division, in and for Palm Beach County, Florida; do hereby certify that I was authorized to and did report the foregoing proceedings before the Court at the time and place aforesaid; and that the preceding pages numbered from 1 to 24, inclusive, represent a true and accurate transcription of my stenonotes taken at said proceedings. IN WITNESS WHEREOF, I have hereunto affixed my official signature this 29th day of (C-aecktfi (23 60 SUSAN S. WIGGINS R.P.R. SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00231422 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been sent by E-Mail and Federal Express this Sox. day of June, 2009, to: U.S. Attorney's Office-Southern District 500 South Australian Avenue, West Palm Beach, FL 33401 WILLIAM J. BERGER ROTHSTEIN ROSENFELDT ADLER 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale FL 33394 Counsel for SPENCER T. KUVIN LEOPOLD-KUVIN, P.A. 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, FL 33410 Counsel for M. JUDITH STEVENSON ARCO State Attorney's Office-West Palm Beach 401 North Dixie Highway West Palm Beach, FL 33401 DEANNA K. SHULLMAN 400 North Drive, Suite 1100 P. O. Box 2602 (33601) Tampa, FL 33602 Counsel for The Palm Beach Post HONORABLE JEFFREY COLBATH Palm Beach County Courthouse 205 North Dixie Highway Room 11F West Palm Beach, FL 33401 ROBERT D. CRITTON BURMAN, CRITTON, LUTTIER & COLEMAN 515 North Flagler Drive, West Palm Beach, FL 33401 and JACK A. GOLDBERGER ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 and EFTA00231423 JANE KREUSLER-WALSH and BARBARA J. COMPIANI of KREUSLER-WALSH, COMPIANI & VARGAS, P.A. 501 South Flagler Drive, Suite 503 West Palm Beach, FL 33401-5913 Counsel for Petitioner By: - 751SL‘-• ICUI-S. W4 ALSH lorida Bar No. 272371 EFTA00231424 EFTA00231425 MARTIN a WEINBERG, P.C. ATTORNEY AT TAW 10 PARK PLAZA, SUITE IMO BOSTON, MASSACHUSETTS 02116 FAX NIGHT EMERGENCY: Assistant United States Attorney United States Attorney's Office Southern District of Florida 500 S. Australian Ave. West Palm Beach, Florida 33401 Re: Jeffrey Epstein Dear Ms. July 22, 2011 EMAIL ADDRESSES: MIN Roy Black forwarded to me your letter to him dated July 21, 2011, from the District Attorney of the County of New York. We thank you for providing notice of the intended disclosure but we do object to any disclosure of the Non-Prosecution Agreement and the related list of witness/victims on the basis of the confidentiality provisions of paragraph 13. Absent an enforceable subpoena - which we would have the right to move to quash in the Court from which it was issued - there exists no right or duty to disclose the confidential Non-Prosecution Agreement or the non-public witness/victim list which was referenced in paragraph 7 of the NPA. Further, given that the witness/victim list was compiled based on the federal grand jury investigation, we object under Fed. R. Crim. P. 6(e) to its disclosure absent an appropriate court order. Very truly yours, Martin G. Weinberg cc: Roy Black EFTA00231426 07/22/2011 15:55 3053562006 BSKS PAGE 02 MARTIN G. WEINBERG. P.C. ATTORNEY AT LAW nitorEnAz4surreimo EMAIL ADDRESSES: sortm. mAsuaniszny nsrn tAx MOW EVERGEACY: AssistarRl.:iiit States Attorney United States Attorney's Office Southern District of Flo • 500 S. Australian Ave. West Palm Beach, Florida 33401 Re: Jeffrey Epstein Dear Ms. July 22, 2011 Roy Black forwarded to me your letter to him dated July 21, 2011, from the District Attorney of the County of New York. We thank you for providing notice of the intended disclosure but we do object to any disclosure of the Non-Prosecution Agreement and the related list of witness/ victims on the basis of the confidentiality provisions of paragraph 13. Absent an enforceable subpoena - which we would have the right to move to quash in the Court from which it was issued - there exists no right or duty to disclose the confidential Non-Prosecution Agreement or the non-public wiMessivietim list which was referenced in paragraph 7 of the NPA. Further, given that the witness/victim list was compiled based on the federal grand jury investigation, we object under Fed. R. Crim. P. 6(e) to its disclosure absent an appropriate court order. Very truly yours, / m dc k 2 Martin G. Weinberg cc: Roy Black EFTA00231427 07/22/2011 15:55 3053582006 BSKS PAGE 01 BLACK SPEBNICK KOPNSPAN STUMPF TRIAL ATT0RNEYS Email: Roy Black Howard M. Srebn'ck Scott A. Kornspan Larry A. Stumpf Maria Neyra Jackie Perczek Mark A.J. Shapiro Jared Lopez Marcos Reaton, Jr. Jessica Fonseca-Nader Kathleen P. Philips Jenifer J. Souliklas Noah Fox Joshua Shore FACSIMILE TRANSMITTAL SHEET FAX: (305) 358-2006 TELEPHONE: (305) 371-6421 TO: AUSA ~., Esq. RE: )epaeti , N.v. -DAZ DATE: July 22, 2011 SENDER: Jackie Perczek NO. OF PAGES (INCLUDING TRANSMITTAL SHEET): 17/JO . MESSAGE: SIF YOU DO NOT RECEIVE ALL PAGES, PLEASE CALL (305) 371.6421e PACETIMS CORTADIS PRIMA:~ Ani C0111.21tanu, INTORRIATION 3Olt ORLY.POIL nopostor tki rzerviounot ABOVE. DT TRE RITADER OP THISPAOSIRHE inbOT T8E reut= Iterntlft OR PM ~LOM% OR »Mrt R6BPOR8BLS TOR DILIVICRINO IT TO TIM INTATORWRIORIPIMT, YOU Ans tamari Neem= THAT ARY MISIISTIRATTOR OR OOM«) 01 TIMPACEITIMS IS ITTRICTLY PITOICOMRD. &POR Adat MCLIVIW tuis PAOSIIMS ERROR. PLEAMISTERIAISLIMOTHTUSZY TICLEPHON; ARO RiprIMIT taz °MIMI MOSHILLR TOUR AT TM AZOVITADDRISS VIA 111Z 17.S. PORTAL ~Ot. TRAM TOR. Y 201 S. Eliscayne Boulevard. Suite 1300, Miami. Florida 33131 (F) iwww.royblack tom EFTA00231428 U.S. Department of Justice United States Attorney Southern District of Florida 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 Facsimile: July 27, 2011 DELIVERY BY FACSIMILE Martin G. Weinberg, Esq. 20 Park Plaza, Suite 1000 Boston, MA 02116 Re: IttfiraMin Dear Mr. Weinberg: Thank you for your letter of July 22, 2011. In order to review and address the objections that you raised in that letter, the Office deferred making its planned disclosure to the District Attorney of the County of New York of the Non-Prosecution Agreement ("Agreement") and the list of identified victims that was provided to Mr. Epstein pursuant to the Agreement. Nonetheless, after completing a full review of your objections, the Office still intends to proceed with the planned disclosures. The Agreement requires the Office only to provide Mr. Epstein with notice prior to a disclosure of the Agreement "[i]f the United States receives a Freedom of Information Act request or any compulsory process"; the Agreement does not require Mr. Epstein's concurrence in any disclosure. Contrary to your suggestion, the Agreement (including paragraph 13) also does not make the Agreement itself "confidential." On the contrary, the Agreement expressly contemplates that disclosures of the Agreement may be made, and the Agreement further contemplates, contrary to your suggestion, that such disclosures of the Agreement may be made other than in response to "compulsory process." Here, moreover, the District Attorney of the County of New York, as a local law enforcement agency, has provided a legitimate request for disclosure of the requested information, as well as a promise to maintain the confidentiality of the information, particularly the names of the minor victims. / our objection pursuant to Federal Rule of CninmaiProcedure 6(e) also does not impact the planned disclosures. The victim list itself is not grand jury material, and, thus, disclosure of that list to the District Attorney's Office will not violate Rule 6(e). If you wish to supply any additional authority (other than citation to Rule 6(e) and to paragraph 13 of the Agreement) for your claims that the Office cannot disclose the Agreement and EFTA00231429 MARTIN WEINBERG, ESQ. JULY 27, 2011 PAGE 2 OF 2 the victim list to the District Attorney of the County of New York, we would be willing to consider those authorities before making any disclosure, provided that any such authorities are furnished to us before 5:00 p.m. on July 29, 2011. Otherwise, seeing no obstacle to the previously-planned disclosures, the Office will be disclosing copies of both the Non-Prosecution Agreement and the list of identified victims that was provided to Mr. Epstein to the District Attorney of the County of New York at 5:00 p.m. on July 29, 2011. Sincerely, Wifredo A. Ferrer By: IIII. cc: Deborah L. Morse, Assistant District Attorney, County of New York Roy Black, Esq. EFTA00231430 United States Attorney's Office Southern District of Florida 500 S. Australian Ave., West Palm Beach, FL 33401-6235 DATE: 7/Z7/2 01/ TO: ititiVrim lAkiiva:XO ORGANIZATION: FAX #: SUBJECT: jerr" EeSTE/P4 FROM: (Fax) NUMBER OF PAGES, INCLUDING THIS PAGE: 3 COMMENTS: Original document: To follow via Federal Express To follow via hand delivery Nothirino follow, FAX = original EFTA00231431 Fax Send Report Date/Time Fax Number Fax Name Model Name No. Name/Number 246 : JUL-27-2011 03:01PM WED : phaser 3300PFP StartTime Tine Mode Page Result 07-27 03:00PM 00'31 ECM (lotted Stale> AIN: ney's Office Southern Ulsiriet of Florida 500 S. Australiau Ave., West Palm Beach, Pl. 33401-0235 DATE. -7/£272Ciel— _. • — 70. Ates7a illeavApeit ORGANIZATION: FAX,: SIAUFCT: tirefflt feSX09_ .11— ( f"Afeje (Fax) FROM: NUMBER OF PAGES. INCLUDING t11IS PAGE: 3 - COMMENTS: Origentallocunmot 7u Sew via fagot.). snarl To foam via Federal ExweAS 7o Meow via hand Mine X Meiji° toast FAX r ()Arai 003/003 CO( EFTA00231432 United States Attorney's Office Southern District of Florida 500 S. Australian Ave., West Palm Beach, FL 33401-6235 DATE: —7/2-7/Zip TO: belockain 11- ORGANIZATION: ive (A) 0,4( 6(5/rid orAtt FAX It: SUBJECT: sreri FROM: A . Marie Vi &AA-ex MI (Fax) NUMBER OF PAGES, INCLUDING THIS PAGE: 3 COMMENTS: Original document: Tn follow via rcgul To follow via Federal Express To follow via hand delivery X Nothinrto follow, FAX = original EFTA00231433 Fax Send Report Date/Time : JUL-27-2011 03:03PM WED Fax Number Fax Name Model Name : Phaser 3300MFP NO. Name/Number startTime Time Mode Page Result 247 07-27 03:01PM 00'57 ECM lifiered Slam Alloracy's Office Somber,' NisINN of Ala 500 S. Austrahau Ave., West Palm Beach, 8.334014235 cals. 77/1 .7 4-00 — 1O: bakomin_ ORGANIZATION- tJQW etbisterlettlitenstiPEitii FAX a: SUBJECT- tT6..6r FROM￾rax) NUMBER OF PAGES. INCLUDING THIS PAGE:.. _ _ COMMENTS: OrigitutIclownieni: x To letlow Ina 'oval mac lo follow wa Feder?' express To follow era hand delivery Nottunrio fNbw. FAX 's origwed 003/003 O.K EFTA00231434 U.S. Department of Justice United States Attorney Southern District of Florida 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 Facsimile: July 21, 2011 DELIVERY BY ELECTRONIC MAIL Roy Black, Esq. Black Srebnick Kornspan & Stumpf P.A. 201 S. Biscayne Blvd, Suite 1300 Miami, FL 33131 Re: ,Jeffrey Epstein Dear Mr. Black: On July 17, 2011, the Office received a written request from the District Attorney of the County of New York for a copy of the signed Non-Prosecution Agreement and the list of identified victims that was provided to Mr. Epstein pursuant to the Non-Prosecution Agreement. Pursuant to the District Attorney's request, the U.S. Attorney's Office intends to disclose these items to Deborah L. Morse, Assistant District Attorney, at 5:00 p.m. on Friday, July 22, 2011. Pursuant to the terms of the Non-Prosecution Agreement, the Office is hereby giving you notice of this intended disclosure. By: Sincerely, Wifredo A. Ferrer United States Attorn ss►stant m tates ttorney cc: Deborah L. Morse, Assistant District Attorney, County of New York EFTA00231435 United States Attorney's Office Southern District of Florida 500 S. Australian Ave., West Palm Beach, FL 33401-6235 DATE: 7/21/2..0 r I TO: )1OLindri moyse ORGANIZATION: bi.hr/Ci - A FAX #: SUBJECT: FROM: (Fax) NUMBER OF PAGES. INCLUDING THIS PAGE: 2 - COMMENTS: Original document: To follow via Federal Express To follow via hand delivery X Nothirrto follow, FAX = original EFTA00231436 Fax Send Report Date/Time : JUL-21-2011 02:08PM THU Fax Number Fax Name Model Name : Phaser 33001,SP NO. Name/Number StartTime Time Mode Page Result 211 07-21 02:07PM 00'25 ECM 002/002 O.K United Stales Attorney's Office Southern District Of Florida 500 S. Australian Ave., West Palm Reach, VIL 33401-6235 DATE. 7 /21/loll TO: Dineati n / /kwve ORGANIZAI ION: FAX 0: SUBJECT: FROM. NUMBBROFPAGESJNCLUDINGTHSP COMMENTS: . avinardmmmat To w nr rirqu r via Fel J-r Express To via h. n d Avery Offikraw, AN'HorIgMal EFTA00231437 2123359288 Fax: Jul 17 2011 10:15ps P001/002 DISTRICT ATTORNEY CYRUS R. VANCE, JR. otrucT Arrow/v. Date: To: Fax: From: OF THE COUNTY OF NEW YORK ONE HOGAN PLACE New York, N. Y. 10013 APPEALS BUREAU FAX DOCUMENT COVERSHEET FAX # Vi-dy /7_Zoft 4-45,4 Tel #: .335- 921.3 # of Pages 2- (includes cover sheet) IlAre 444 ❑ URGENT ❑ ROUTINE Deliver Immediately 0 Discuss with Appropriate Person(s) o As Requested Review and Comment ❑ For Your Approval Take Necessary Action o For Your Information 0 Reply Via FAX ❑ File Reply Via Messenger ❑ Reply Directly ❑ Progress Report o Investigate ❑ Let's Discuss ❑ Prepare Reply for Signature o Other Action To Be Taken/Additional Comments: art/7i - 6.4 AiA.. Atio eAkoj e A 414 he ?PAS. -rs IA/c /sorer, 2 • lg. t un, eirkedele. rem_ Of ratio.; --4 )ciporA4 dictre—, EFTA00231438 2123359288 Fax: DISTRICT ATTORNEY OF THE COUNTY OF NEW YORK ONE HOGAN PLACE Now York. N. Y. 10013 CYRUS R. VANCE, JR. 0MMUCT Arroromr , Esq. Assistant United States Attorney Office of the United States Attorney Southern District of Florida liaktralian Avenue West Palm Beach, Florida 334O1 Dear Ms. Jul 17 2011 10:15Pa P002/002 July 15, 2011 As we have discussed, I am currently working on the appeal brought by defendant Jeffrey Epstein In which he challenges his risk-offender designation under New York State's Sexual Offender Registration Act. The non-prosecution agreement between defendant and your Office would be of assistance to us in fashioning our response on appeal. I would appreciate it if you would send us a copy of that agreement, including the list of victims. Please let me know If you need any further information in order to make this material available. I appreciate your assistance, and courtesy, in this matter. Yours truly, e Deborah L. Morse Assi nt District Attorney EFTA00231439 U.S. Department of Justice United Stales Attorney Southern District of Florida 500 S Australian Ave, Ste 400 West Palm Beach, FL 33401 (56!) 820-8711 Facsimile: July 21, 2011 DELIVERY BY ELECTRONIC MAIL Roy Black, Esq. Black Srebnick Komspan & Stumpf P.A. 201 S. Biscayne Blvd, Suite 1300 Miami, FL 33131 Re: Jeffrey Epstein Dear Mr. Black: On July 17, 2011, the Office received a written request from the District Attorney of the County of New York for a copy of the signed Non-Prosecution Agreement and the list of identified victims that was provided to Mr. Epstein pursuant to the Non-Prosecution Agreement. Pursuant to the District Attorney's request; the U.S. Attorney's Office intends to disclose these items to Deborah L. Morse, Assistant District Attorney, at 5:00 p.m. on Friday, July 22, 2011. Pursuant to the terms of the Non-Prosecution Agreement, the Office is hereby giving you notice of this intended disclosure. Sincerely, Wifredo A. Ferrer United States Attorne By: istant nit tates ttorney cc: Deborah L. Morse, Assistant District Attorney, County of New York EFTA00231440 DISTRICT ATTORNEY OF THE COUNTY OF NEW YORK ONE HOGAN PLACE New York, N. Y. 10013 CYRUS R. VANCE, JR. OTRCT ATTORNEY May 6, 2011 , Esq. Assistant United States Attorney Office of the United States Attorney Southern District of Florida 500 S. Australian Avenue West Palm Beach, Florida 33401 Dear Ms. As I explained during our telephone conversation last week, I am currently working on an appeal brought by defendant Jeffrey Epstein. Defendant Epstein challenges the designation that he was given under New York State's Sexual Offender Registration Act. The underlying sexual misconduct at issue was the subject of an investigation and/or prosecution by your Office, as well as the Florida State's Attorney Office in Palm Beach County. I know that you handled the matter on behalf of your office when the case was presented to the federal grand jury. Those grand jury proceedings would be of assistance to us in fashioning our response on appeal, and I would appreciate it if you would send us a transcript of those roceedings. If we furnish the minutes to the appellate court, we would do under seal for the purpose of an in camera review. Please let me know if you need any further information in order to make the materials available. I appreciate your assistance, and courtesy, in this matter. Yours truly, Deborah L. Morse Assistant District Attorney EFTA00231441 DISTRICT ATTORNEY OF THE COUNTY OF NEW YORK ONE HOGAN PLACE Now York, N. Y. 10013 CYRUS R. VANCE, JR. DISTRICT AITCRMEY August 15, 2011 , Esq. Assistant United States Attorney Office of the United States Attorney Southern District of Florida 500 S. Australian Avenue West Palm Beach, Florida 33401 Dear Ms. Pursuant to our conversation, I have enclosed copies of the brief and appendix filed by defendant Jeffrey Epstein on appeal, as well as a copy of our brief in response. I look forward to hearing your opinion. Yours truly, ti 6t 1 of Lc.) Deborah L. Morse Assistant District Attorney EFTA00231442 New York County Clerk's Index No. 30129/2010 'sin 'Dark $ig:matte &curt APPELLATE DIVISION-FIRST DEPARTMENT PEOPLE OF THE STATE OF NEW YORK, Respondent, —against— JEFFREY E. EPsTEIN, Defendant-Appellant. APPENDIX CYRUS R. VANCE, JR. NEW YORK COUNTY DISTRICT ATTORNEY'S OFFICE One Hogan Place New Yor New York 10013 Attorneys for Respondent JAY P. LEFKOWITZ SANDRA LYNN MUSUMECI KIR1CLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022 Attorneys for Defendant-Appellant REPRODUCED ON RECYCLED PAPER EFTA00231443 TABLE OF CONTENTS PAGE Appellant's Pre-Argument Statement, dated February 9, 2011 Al Appellant's Notice of Appeal, dated February 9, 2011 A3 Order Appealed From, dated January 18, 2011 with Notice of Entry A4 Palm Beach Police Department - Probable Cause Affidavit of Det. - Defendant dated May 1, 2006 A6 Palm Beach Sheriffs Office Booking Card for Jeffrey Epstein, dated July 23, 2006 A28 2006 Grand Jury Indictment of Felony Solicitation of Prostitution - Jeffrey E. Epstein A29 Information for Procuring Person under 18 for Prostitution - Jeffrey E. Epstein, dated June 26, 2008 A31 Guilty Plea for Felony Solicitation of Prostitution and Procuring Person under 18 for Prostitution - Jeffrey E. Epstein, dated June 30, 2008 A32 Judgment for Procuring Person under 18 for Prostitution - Jeffrey E. Epstein, dated June 30, 2008 A33 Sentence for Procuring Person under 18 for Prostitution - Jeffrey E. Epstein, dated June 30, 2008 A34 Community Control Standard Conditions, dated June 30, 2008 A35 Palm Beach Sheriffs Offiee-Beeking-Gard-for-Jeffrey--Epstein dated June 30, 2008 A47 EFTA00231444 ii PAGE Order Granting Jeffrey E. Epstein's Motion for Travel, dated December 18, 2009 A48 Letter from Florida Department of Corrections Regarding Termination of Supervision, dated July 21, 2010 A49 Letter from Palm Beach Sheriff's Office Regarding Jeffrey Epstein's Participation in the Work Release Program, dated August 12, 2010 A50 Letter from Jack A. Goldberger to NYS Sex Offender Registry Regarding Florida Registration Level applicable to Jeffrey E. Epstein, dated August 12, 2010 A51 Letter from Martin G. Weinberg to NYS Board of Examiners of Sex Offenders Regarding Level and Designation Determination for Jeffrey Epstein, dated August 16, 2010 A53 Letter from Stephen R. Alexander, Psy.D. to Jack Goldberger Regarding Opinion of Jeffrey E. Epstein, dated August 16, 2010 A58 Recommendation of Board of Examiners of Sex Offenders, Including Risk Assessment Instrument, dated August 19, 2010 and Case Summary, dated August 23, 2010 A62 Letter from Supreme Court attaching Notification, Recommendation and Notice of Right to Appeal, dated August 26, 2010 A67 Letter from Supreme Court to Jeffrey E. Epstein informing of SORA Level Determination Hearing, dated August 26, 2010 A68 Order Sheet for Jeffrey Epstein, dated August 26, 2010 A69 Letter from Supreme Court to Counsel Informing of SORA Level Determination Hearing (with attachment), dated August 26, 2010 A71 EFTA00231445 in PAGE Letter from Jay P. Leflcowitz to Hon. Ruth Pickholz Requesting a Continuance of the Hearing, dated September 9, 2010 A77 Letter from Supreme Court to Sex Offender Registry Unit Enclosing Final Determinations, dated January 19, 2011 A78 Court Action Sheet - Jeffrey Epstein, No. 30129-2010 A80 Handwritten Notations on Court Jacket - Jeffrey Epstein, No. 30129-2010 M1 Transcript of SORA Hearing, dated January 18, 2011 A82 EFTA00231446 Al Appellant's Pre-Argument Statement, dated February 9, 2011 [pp. Al-A21 SUPREME COURT FOR THE STATE OF NEW YORK COUNTY OF NEW YORK PEOPLE OF THE STATE OF NEW YORK, Plaintiff-Respondent, -against￾JEFFREY E. EPSTEIN, Defendant-Appellant. Index No.: 30129-2010 PRE-ARGUMENT STATEMENT 1. TITLE OF ACTION: As set forth in caption. 2. FULL NAMES OF ORIGINAL PARTIES AND ANY CHANGE IN THE PARTIES: As set forth in caption. There has been no change in the parties. 3. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR APPELLANT OR PETTTIONER: Jay P. Leflcowitz, P.C. Sandra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, Ne 4611 Telephone: Facsimile: 4. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR RESPONDENT: Cyrus R. Vance, Jr. NEW YORK DISTRICT ATTORNEY'S OFFICE One Hogan Place New York, NYiiii m Telephone: 5. COURT AND COUNTY, OR ADMINISTRATIVE BODY, FROM WHICH APPEAL IS TAKEN: New York Supreme Court (Criminal Term), New York County. 6. THE NATURE AND OBJEGF-OF-ThE-C-AUSE-OF ACTION OR SPECIAL PROCEEDING: Sex Offender Registration Act (SORA) hearing, pursuant to Article 6-C of the Correction Law. 7. RESULT REACHED IN THE COURT OF ADMINISTRATIVE BODY BELOW: Supreme Court, New York County, adjudged appellant Jeffrey E. Epstein to be a Level 3 sexual offender, without additional designation. 8. GROUNDS FOR SEEKING REVERSAL, ANNULMENT, OR MODIFICATION: The Court's designation of appellant Jeffrey E. Epstein as a Level 3 sexual offender was an abuse of EFTA00231447 A2 discretion and constituted reversible legal error based, in part, on the following: (1) the Court improperly relied on untrustworthy double and triple hearsay contained in the recommendation of the Board of Examiners of Sex Offenders, even though the District Attorney, as the party appearing on behalf of the State, rejected much of the Board's recommendation as not constituting clear and convincing evidence to support a Level 3 designation where such hearsay allegations were rejected as a basis for state prosecution; (2) the Court failed to provide the parties with an opportunity to present evidence on contested issues, as required by statute, and instead relied wholesale upon the recommendation of the Board, over the objection of the District Attorney, without any inquiry; (3) the Court did not apply the guidelines established by the Board, as required by statute; and (4) the Court failed to set forth the findings of fact and conclusions of law on which its determinations in support of a Level 3 designation were based, as required by statute. 9. THERE IS NO RELATED ACTION OR PROCEEDING NOW PENDING IN ANY COURT OF THIS OR ANY OTHER JURISDICTION. 10. THERE IS NO ADDITIONAL APPEAL PENDING IN THIS ACTION. Dated: February 9, 2011 Ja . Leficowitz, P.C. S Lynn Musumeci KIRKLAND t ELLIS LLP 601 Lexington Avenue New York, Neal -4611 Telephone: Facsimile: Attorneys for Defendant-Appellant Jeffrey E. Esptein. -2- EFTA00231448 A3 Appellant's Notice of Appeal, dated February 9, 2011 SUPREME COURT FOR THE STATE OF NEW YORK COUNTY OF NEW YORK THE PEOPLE OF THE STATE OF NEW YORK, Plaintiff, - against - JEFFREY E. EPSTEIN, Defendant. NOTICE OF APPEAL Index No. 30129-2010 CRIMINAL TERM PART 66 JUSTICE RUTH PICKHOLZ PLEASE TAKE NOTICE that the above named defendant, Jeffrey E. Epstein, hereby appeals to the Appellate Division of the New York Supreme Court in and for the First Department, from an order entered in the above entitled action in the office of the Clerk of New York County on the 18th day of January 2011, which order adjudged defendant Jeffrey E. Epstein to be a Level 3 sexual offender pursuant to Article 6-C of the Correction Law, and this appeal is taken from each and every part of that order as well as from the whole thereof. Dated: February 9, 2011 To: Clerk, New York County Cyrus R. Vance, Jr. NEW YORK DISTRICT ATTORNEY'S OFFICE One Hogan Place New York, NY Telephone: Lefkowitz, P.C. a Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, Ne Telephone: Faccim; Attorneys for Defendant Jeffrey E. E P'ILED FEB OP SISUPREME COURT NOW YORK COUNTY APPA'ALV: ro.thant.m) EFTA00231449 A4 Order Appealed From, dated January 18, 2011 with Notice of Entry Ipp. ASUPERVIGINGp.ff.F10ER: -km.. rh•• . '‘ C.; ''g;C: •!. ' §UPERVISING AGE Y, Le NONE ; OFFENDEipp UNS • ,:. ' ttitl'i it0 :" ' 4. ' )ft'i '4'. i - cA: 114aboliii:rekerOnoed,I id . ;o54ntitteistan oflatala amulet midi_ keitaliliihetiesT eh 4Stite:at Ulkaddnisilicsflpikekft tia:lstridethmgned.3_ ' ..r. ,113fit Vender!kri quirad tc1,1". ister''and b.e..W Tak r ... in„,ixeria. a lilt Cave) :lac eacti(Madiga:/ et • ottendeld Hew Y iiii . 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WhitilialkatclettirminaliOns:aratlatiseditafral Ws. sUbmitted to' the' Divisioff: of "CHmilialrJtiatia6ZSgvial'AV 0tit WI py'llhic.00titC, inf.' ditItin,' please: compete and; attach this ttorni•IndVilitict:Ife7offeh&I'Mrt • natlo ii.to,thaiark.buler P Please distribideNiernainktutcOisiis indicatiiitiajkA2, *014iff•:4 4::I'Tssia44-:, !.t.r)Fri'?- 4.:';4:It t ."Ft:"":\i?'‘‘::wi3;:-.?* 'f.. .",,; W401/sA; OiSit.k1 :Inz FINAkRISIC LEVED,DETE iNAllati Miele Calie • ile;Ve4Wr'• bESIGNATIO :4.1leAse,check• h that applir pUrstiantto A • 4.,..tas ' t" t Otipation. ow ts.to.bopomple K", tf-wtet EFTA00231450 A5 SUPREME COURT FOR THE STATE OF NEW YORK COUNTY OF NEW YORK THE PEOPLE OF THE STATE OF NEW YORK, Plaintiff, - against - JEFFREY E. EPSTEIN, Defendant. NOTICE OF ENTRY Index No. 30129-2010 CRIMINAL TERM PART 66 JUSTICE RUTH PICKHOLZ PLEASE TAKE NOTICE that the within is a copy of an order entered in this action on the 18th day of January 2011, in the office of the Clerk of the County of New York. Dated: February 9, 2011 To: Clerk, New York County Cyrus R. Vance, Jr. NEW YORK DISTRICT ATTORNEY'S OFFICE One Hogan Place New York, NYaili m Telephone: Jar. Lefkowitz, P.C. Sandra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, Neill -4611 Telephone: Facsimile: Attorneys for Defendant Jeffrey E. Epstein FI LED FEB op 2811 New„ abme cou, ANP `Jr* a aAte srcou Wiry ev r Dvra,u EFTA00231451 A6 Palm Beach Police Department - Probable Cause Affidavit of Det. dated May 1, 2006 [pp. A6-A271 Probable Cause Affidavit Palm Beach Police Department Agency OM FLO 500600 - Defendant Police Case#: 05-368 (2) Defendant: Sarah Race/Sex: White Female DOB: Charges: Principal in the 1" Unlawful Sexual Activity with a Minor (4) counts Principal in the 1e1Lewd and Lascivious Molestation (1) count From March 15, 2005, through February 2006 the Palm Beach Police Department conducted a sexual battery investigation involving Jeffrey Epstein, a and Sworn taped statements were taken from five victims and seventeen witnesses concerning massages and unlawfbl sexual activity that took place at the residence of Jeffrey stein, 358 El Brillo Way, Palm Beach. Several of the victims were recruited by and brought to the residence by to perform massages for Epstein for which at received monetary compensation. During the visit they would be introduced to a, Epstein's assistant, who in turn would record their telephone numbers and name. The victims would be brought to Epstcin's bedroom to provide the massage. Epstein would enter the room and order the victims to remove their ciothin to •rovide the massage. As the victims complied and provided the massages, stein would On occasion, Epstein would introduce a massa et/vibrator and vided the .m o. On three separate occasions, Epstein . At the conclusion of the massages the victims were paid sums of money ranging front $200 - $1,000. The facts, as reported, are as follows: On 03/15/2005, A fourteen year old white female, hereinafter referred to est." dob 05/13/1990, and her family reported unlawful sexual activity which occurred at a residence within the Town of Palm Beach. reported that a subject known to her as "Jeff" had t while within his residence. "Jeff' was later identified as Jeffrey Epstein through a photo line up. During a sworn taped interview, ■ stated that-, dab a cousin of SCI's boyfriend and classmate at Ro al Palm Beach High School, worked for a wealthy man and did sexual favors for him. She also admitted that had offered her an opportunity to make money. During the beginning of the month of February 2005 explained that she was first approached by to go with her to Epstein's house, stated that alo with a Hi anic female, later identified at .. her up at her father's house on a Sunday. was not sure of the exact dates but knew it was a Sunday. told her sp fathet that they were going shopping but in reality drove them to Palm Beach. During the drive a The foregoing instrument was sworn to or affirmed info a thi " day of May, 2006 by Det who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida al Beach Signature Date: 05/To 006 Officer Pagc I of 22 EFTA00231452 Signature of Poli e Officer (F.S.S. 1.1.7.10) A7 Probable Cause Affidavit Palm Beach Police Department Agency ORIM FLO $00400 conversation occurred between and II whereas reportedly toldlihat if tasked her age, she should say she was eighteen. It was later confirmed by the that picked his daughter up on February 6, 2005. According to M father, drove a pick up truck. . described Epstein's house as a two-story pink house with a Cadillac Escalade parke in the driveway. She recalled that . house was on a dead end street. Upon arriving at the house . stated that they walked up a driveway, ast what appeared to be a small guard/security room. A male approaching them asking what they wanted. stated they were there to sec Epstein. The male allowed them to continue walking up to the house. stated the man told them that Epstein was not there but was expected back. He allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside. Short( thereafter, Epstein and his assistant, described as white fe ale vS,I) blond hair and later identified as entered the kitchen. Epstein introduced himself to M.. described Epstein as being approximately forty-five years old, having a long face and bushy eyebrows, with graying hair. and Epstein left the kitchen leaving. alone in the kitchen. They returned a short time later. They all spoke briefly in the kitchen. . was instructed to follow upstairs: . recalled walking up a flight of stairs, lined with photographs, to a room that had a massage table in it. Upon entering the room there was a larlbathroom to the right and a hot pink and green sofa in the room. There was a door on each side of the sofa. recalled there al a mural of a naked woman in the room, as well as several photographs of naked women on a shelf. told the victim that Epstein would be up in a second. Epstein entered the room wearing only a towel and told. to take off her clothes.. stated Epstein was stern when he told her to take off her clothes. M said she did not know what to do as she was the onlune there in the room, she took off her shirt leaving her bra on. Epstein had removed his towel and told the. to take off everything. ilstated Epstein was nude when he took his towel off, placing it on the floor as he laid down on the table. stated she then removed her pants leaving her thonsjanties on. Epstein then instructed her to give him a massage poirW to a specific lotion for her to use. As IN began to giv ' e, he told her to t on his back. . stated she straddled herself on Epstein's back whereby Epstein's bare buttocks. M said Epstein was specific in his instruction to her on how to massage him, telling her to go clockwise or counter clockwise. Epstein then turned over and instructed. to massage his chest m was now standing on the ground and resumed massaging Epstein's chest area. M stated Epstein held onto the small of her back as she massaged his chest and shoulder area. Epstein then brined to his side and started to rub his penis in an up and down motion. Epstein then pulled out a purple vibrator and began to The foregoing instrument was sworn to or affirmed before rue this in day of May, 2006 by Det Joe Recarcy, wholipersonalfy known to mc. Page 2of 22 Date: 05 006 Slate of Florida Court of Palm B ach Officer EFTA00231453 A8 Probable Cause Affidavit Palm Beach Police Department Agoney ORIN FLO 500600 stated there was no penetration as the recalled Epstein ejaculating because he had to use the towel to wipe himself as he of off the table. Epstein then left the room and . got dressed. She went back downstairs where she met with was paid old El said she number. :::1 an were leaving the house, told shc received two hundred from Epstein. Before s surked to leave her phone dollars that y or aging er. During the course of the investigation, parental consent was granted for to assist with the ?stn. At our direction conducted controlled taped phone calls to cellular telephone . dig • II spoke with in an attemaiange another meeting with Epstein.. asked Robson, she need to do to make more ney. stated, "the more you do, the more you get paid." had subs uently called back U and left a voice mail message for her indicating that she had set up an ointment for . to go to Epstcht's house at 11:00 am on April 5, 2005. This message was recorded from voice mail. Based on the above, trash pulls were established at Epstein's residence with Supervisor Tony Higgins of the Sanitation Bureau of the Town of Palm Beach. The trash pull from April 5, 2005 revealed a message W pstcin which stated -and. name at 11:00 am. This was the time frame had informed to be ready to go work at Epstein's house. On October 3, 2005, Sgt and I went to residence and viewed her vehicle parked in the driveway, a red Dodge Neon. Sgt and I knocked on the door and met with was told that we were investigatinga claim involving Jeffrey Epstein of El Brillo Way, in Palm Beach was asked if she would accompany us back to the police station for further questioning. She was also told at at the conclusion of the interview she would be returned home. voluntarily came with us back to the Palm Beach Police Department. Upon our arrival at the police station, was brought to the interview room in the Detective. Bureau where I obtained a taped, statement. I began the interview by asking how she became acquainted with Epstein. stated that approximately two years ago, just after she turned 17 years of age, she was approached by a friend named at the Canopy Beach Resort in Rivera Beach. was asked iiimanted to make money. She was told she would have to provide a massage and should make $200.00. thought about the offer and agreed to meet with Jeffrey. The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to inc. Signature of Police (ricer i.S.S. 117.10) State of Florida County of Palm Beach Signature Officer Date: 05/0 006 Page3of 22 EFTA00231454 A9 Probable Cause Affidavit Palm Beach Police Department Agency O1U0 FLO 500600 (Unknown last name) and Tony (Unknown last name) picked up and she was taken to Epstcin's house. Upon her arrival to the house she wait ' uced to Epstein in the kitchen of the house. She was also introduced to a white female known to her as . She was led upstairs to the main bedroom known to her as Jeff Epstcin's bedroom. arranged the massage table and covered the table with a sheet. She brow t out the massage oils and laid them next to the massage bed. MI, then left the room and informed Jeff would be in, in a minute. Jeff entered the bedroom wearing only a towel. He removed the and laid nude on the massage table. He laid on the table onto his stomach and picked a massage oil for to rub on him. Durnmassage, tried to touch her. stated that Epstein stated "He tried to touch me and I stopped him." I asked how he and she felt uncomfortable. told Epstein, NI massage you but I don't want to he touched, stated she performed the massage naked. At the conclusion of the massage, Epstein paid $200. After the massage Epstein stated to that he understood she was not comfortable, but he would pay her if she brought over some girls. He told her the younger the better. stated she once tried to bring a 23 year old female and Epstein stated that the female was too old. stated that in total she only remembers six girls that she brought to see Epstein, each time site was paid $200. stated she had brought the following girls: - ' • - ' , • , M. ( al6 year old female), (a 16 year old female) and :.._.* - . said that at the time she brought these girls to Epstein's house they werea1114 through 16 years of age. ! asked which one was the youngest. =I advised. was the youngest as she was fourteen when the massage occurred. stated every girl she brought knew what to expect when they a ted. They were told they would provide a massage, possibly naked, and allow some touching. I asked her If . was aware. She stated every girl she brought knew what to expect. She ex lamed she knew that. wanted to make money. She approached. and explained about going to work for .. agreed and arrangements were made to bring her to Epstein's house on a weekend. stated that she and .__ (Later identified as -,..:... 71„,. .. . ) picked up. at her house. stated that at that time she was driving a red pickup truck. They traveled 6: Stein's house and entered through the kitchen door. They met with the lieheld Epstein's assistant =.. was introduced to Epstein while they were in the kitchen area. upstairs and Epstein went upstairs. When the massage was over returned to the kitchen area. stated she was paid $200.00 for bringing. to Epstein's house. stated. told her she was paid $300.00 for the massage. stated that. was the last person she brought to Epstein's house. She had changed her cellular number to avoid being contacted by =. She continued stating that she had no direct contact with Epstein The foregoing instrument was sworn to or affirmed before me this l w day of May, 2006 by bet Joe Recarey, who is personally known to me. Signature of Police filet (F.S.S. 117.10) State of Florida Coun of Palm Beach Signatur Date: 05/01/2006 g Officer PageSof 22 EFTA00231455 A10 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 when he was going to travel to Palm Beach. =said when Epstein announces to his assistant, he is traveling to Palm Beach, would then contact to arrange girls to "work" for Epstein'. stated that once her parents discovered that she was visiting Epstein, they disapproved of the encounters with him and she stopped. further stated that still tries to call Robson.'s house and leaves messages. Sgt . entered the room and explained to that based on her own statements, she had implicated herself by bringing underage girls to Epstem's house. provided cellular telephone numbers for the girls she had mentioned previously. Additionally, she also provided possible addresses and areas in which they lived. As was being taken home in the vehicle, a tape recorder was laced within the vehicle to record any conversations within NI the vehicle. During the drive back to her home, made the co " I'm like a Heidi Plass." (Hollywood Madam who sent girls to clients for sexual favors in California). was dropped off at her house without incident. On October 3, 2005, Sgt and I went to speak with a sixteen year-old female who was brought to Epstein's residence by . We met with mother at their front door. We explained the ongoing investigation and asked to speak with, as we had information that she had "worked" for Jeff. introduced us to her husband and allowed us entry into the home. tfalgt in the dining room and met with Date of Birth . As she was under the age of eighteen, = was advised we would be speaking with her. She expressed if her daughter had information, she wanted to assist. We interviewed,, who denied havi any inappropriate encounters with Jeff (Epstein). She stated she had gone to Jeff's house with approximately eight months ago and sat in the .was with the house chef, but nothing happened. As the parents were present during the interview, we felt that withholding information from us. She made several comments as to putting the entire incident behind her. I left myarne number and advised should she wish to speak with me again to telephone me. Sgt NI and I thanked for her time and left the area. She stated she would ask, again after we left as to what happened at Epstein's house. I informed her that I had my telephone number and hopefully she would call. On OctoberS2005, Da. and I drove to the — dob . During a sworn taped statement stated approximately a year ago. when _ she was seventeen years old, she was taken to a house by . stated she knows because they both attend Royal Palm Beach High School. She was told she could make money working '• home and met with ' and The foregoing instrument was sworn to or affirmed before me this I" day of May, 2006 by Del who is personally known to me. Signature of Police t7Mcer .5.5. 117.10) State of Florida Date: 05/01/2006 PageSof 22 EFTA00231456 All Probable Cause Affidavit Palm Beach Police Department Agency OM PLO 500‘00 for Jeff She was told she would have to rovide a massage to Jeff. 7_, stated upon her arrival to the house she was brought to the kitchen area by . They met with the house chef who was alreadyApshe kitchen area. stated would wait for her in the kitchen. I . was introduced to =, Jeff's assistant, who brought her upstairs to the master bedroom. prepared the room and massage table for a , massage. Epstein entered the room wearing only a towel and she provided a massage. - t her clothes on during the massage. She advised sometime during the massage Epstein and pulled her close to him. r said she was uncomfortable by the incident involving Jeff At the conclusion of the massage, she was paid $200.00 for the massage. I asked : ... : . if she has any formal training in massages to which s! hed no. I asked her if received any monies for taking her to perform the massage. stated had received money for taking her there but was unsure in the amount. ic stated she returned to Epstein's house on another occasion with and another 'z stated she waited in the kitchen with , while was taken upstairs by . stated she only did the massage once as she was uncomfortable with the whole experience. At the conclusion of the interview, the tape was stopped. I was informed that had attempted to reach *.: via cell phows 4 voice mail message on October 4, 2005 at 10:59 am, revealed a female voice who identified herself as who requested : to call her back reference the police questioning. T...'t provided the Incoming telephone number as . • . stated she inadvertently told'. ...._ about the police investigation because had called her to tell her about how she just received a rental car from Jeff Epstein. had called her to tell her that she was given a rental car, a 2005 Silver Nissan Sentra, to utilize to visit family and visit Epstein. : asked her what wasgoing on at the house that the police would be asking questions. . • stated . then called Jeff and and asked what was going on reference the ongoing police investigation. According to has since then been trying to contact her to ask about the police questions. I instructed ' ' not to contact and do not provide any more information to as she would notify Jeff Epstein and what was transpiring. On October4, 2005, I made telephone contact with who had left several messages for me to contact her. During the message, she advised she was not completely truthful when we met in person but would like to speak with me to advise what had happened. She .further advised she did not want to speak of this incident in front of heir )(Aber. At approximately 3:48 pm I made telephone contact with,. During a taped recorded statement ■ stated the following: approximately a year ago, when she was sixteen years of age, stook her time she went• drove to the house. They entered through the kitchen area where she was to Epstein's ho • knows because they both attend Royal Pal Beach High Soho° The first The foregoing instrument was sworn to or affirmed before me this In day of May, 2006 by Det • who is personally known to me. Signature of Police facer . 117.10) State of Florida Court otPahn Reach Signatur Date: 05/01/2006 g Officer Page 40122 EFTA00231457 Al2 Probable Cause Affidavit Palm Beach Police Department Agawy OM PLO 500600 introduced to and Epstein. She was taken upstairs to a bedroom by who set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for, to rub on him. At one point during the sage he tried to remove her shirt, at which point she became very upset and discontinued the massage. Both and stein had a verbal disagreement, at which time she left without being paid. She got with who was sittin in the kitchen and told her "let's ga." JS advised she received no money for that day. also said that had told her if she was uncomfortable with what was going on, to let him know and he'll stop. She knew that the 'more you do more you get paid. JS advised that several weeks later she agreed to be taken a second time by Haley Once they arrived at the residence, aitobson sat in the kitchen and took her upstairs to the master bedroom again. set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for, to rub on him. At one point during the massage he tried to touch her buttocks. M I was wearing tight Jeans and had a tight belt on Epstein was unable to touch her buttocks. Epstein then rolled onto his back during the massage and &n. attempted to touch her breasts., then became upset again and told Epstein she didn't want to be touched. discontinued thmage and was paid S200.00. . then went downstairs where for her. She told was waiting she wanted to leave. I said she never returned to the house. stated she is thaw that her friend, _____. : was also at the house and had a problem with Epstein. 1- 1 later researched :, dob IIMS and met with her at her residence. During a sworn taped statement, T• ' ' lowing, on or aboalmember 2004, she was approached at Royal Palm Beach High School by a fellow student M asked - ' ' if she wanted to make money. She agreed and was told she would provide a massage to wealthy man in Palm Beach. picked her up and drove her to a house in Palm'Beach. She was brwht into the kitchen area of the house. She further stated that follow Royal Palm Beach High School students MI and ' .) came with them. They were brought into the kitchen where she was introduced to Epstein and other females. _ . : stated she was introduced to a female helper of Epstein, the female was described as white female (unknown name ), with blond hair. She stated that the assistant was familiar with . The assistant brought her upstairs into a master bedroom area. The assistant set up the massage table and put out lotions to be used. She told' • Epstein would be available in a minute. Epstein entered the room wearing only a towel. Epstein removed his towel, and laid naked on the massage table and picked a lotion to rub on his thighs and back. . " ' I further stated during the massage, Epstein asked her to remove her clothes. She complied and removed her pants and blouse. didn't remember if she had removed her bra but feels that she did. .: . ' ' was certain that she stayed in her thong underwear. ' ' continued the massage and at one point she climbed onto the massage The foregoing instrument was sworn to or affirmed hero this 1" day of May, 2006 by p t . who is ersonally known to me. State of Florida of Palm Be h Signatur g Officer Signature of Police Office (F.S.S. 117.10) Date: 0510 12006 Pagel of 22 EFTA00231458 A13 Probable Cause Affidavit Palm Beach Police Department Agency OWN FLO 500600 table, straddling Epstein to massage his back. While doing this ' was instructed to return to the ground at which time Epstein turned to ve his chest rubbed. : . ' ' : advised she was sure he was masturbating based on his band movements going up and down on his penis area. :... • ' did not want to look at his penis area because she was.uncomfortable. Epstein re v a ' ' was next to the mesas e table and turned it on. :..,..2L L. stated Epstein began . Shortly thereafter, Epstein ejaculated and removed himself from the table. He walked over to where the shower was and opened the glass door. She waited as he was taking a shower in her direct view. When I asked 1_2. ' how old she was when this occurred, she stated she had just turned seventeen. At the conclusion of the shower, •_. : was paid either $350.00 or $400.00. She stated she wasn't sure, but knows it was close to $400.00. stated she never returned to provide a massage for Epstein. At approximately 2:10 pm, Dct and I met withSdob at her residence. As. was only seventeen years of age, I had notified her mother, that she would be interviewed reference an ongoing investigation in Palm Beach. I assured her that her daughter was not a suspect. I explained the possibility of her being either a witness or victim. advised she wanted . to cooperate and consented to the interview: During a sworn taped statement, . stated the following: at the age of sixteen,Aring the month of September 2004 she was approached by Haley Robson for a chance to make money. . was friends with associates of and knew the same people, en previously told by her end Royal Palm Beach High School, what did for Epstein. called a person known to M as fsi ifir and scheduled the appointment. picked El up and drove her to Palm Beach to a street called "Brillo Way". They drove to the end of the street and entered a large drivewa . Th entered the kitchen area of the house and met with Epstein.. was introduced to Jeff Epstein. led upstairs to the main bedroom area and set up the room with a massage table and set out the oils. stated that white going up the stairs and into the bedroom she observed numerous photographs of naked young girls. dimmed the lights and turned on soft mused. Mi exited the room and Epstein entered the room wearing only a towel. Epstein picked oils and instructed her to rub his legs, under his buttocks, back and chest area Epstein asked her to get comfortable. M advised she did not remove her clothes. She was wearing tight jeans and a cropped tank top exposing her belly e massage, Epstein removed his towel and laid on the massage table naked. As M arca, he attempted to reach down her pan to touch her buttocks area however was unable to due due to the tightness of the jeans and a tight belt. advised Epstein began to masturbate as she rubbed his chest. Epstein moaned as she rubbed his chest She observed he was continuing to masturbate and The foregoing instrument was sworn to or affirmed before me this 1" day of May, .21106 by Det , who ispersonally. known to me. Signature of Police dicer .Ss. 111.10) State of Florida Date: 05/01/2006 Page8of 22 EFTA00231459 A14 Signature of Poli e Office (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency 01W FLO 500600 , attempted to reach up her tank top and touch her breasts. epulled back and Epstein stopped, howev-slie kept masturbating until he climaxed. He cleaned himself wi I he was previously wearing. I. was paid $200.00 for the massage and left the area. She met with who was' waiting in the kitchen area and left the house. then explained she never provided another massage for Epstein. She did however, go to the house with and 1-_______ ;77.....; as they took another friend of Robson's. . advised she was present when . : went to work for Epstein. She advised she rode over and sat in the kitchen area with to wait for 1. ' ' ,. . advised while they waited for L • ' the house chef prepared lunch for them as it 'l unchtime when they went. When L.... ' was finished with the mass they left the asked if ever told her what would be expected when she provided a massage.. stated y told her that a massage would be expecte ossibly naked and possibly some touching Involved. ll has no formal training in providinssnassages. . spoke about a third and last time she went to Epstein's house. Robson ye another girl, M, (sixteen years of age) who is. friend, to Epstein's house.. stated . knew that had made money massaging i stein and wanted to e oney herself took them in the kitchen area of the house and introduced to and took . upstairs to the main m. III advised she doesn't know what happened as did not speak about what happened in the room. received $100.00 from for going with her to pstein's house and recommending On October 6, 2005, at 11:45 am, I met with -. . :, dob a, at and explained to her why we there to interview her. She advised she was aware of the ongoing investigation. ...::_,; stated she had previously spoken with . , L.7 .... ' . who told she was interviewed by detectives. During a sworn taped statement, , stated she knew that worked for Jeff Epstein in Palm Beach. advised she originally had been taken to the Epstein house by whom She met when they both attended Royal Palm Beach High School. She began going to the house when she was sixteen years of age and stated she had been there a lot of times to provide massages over the past two ybars. I asked her if she had formal training in providing massages, which stated she had not advised she was told what was expected of her by providing massages and she would have to remove clothing but if she felt uncomfortable just to say so and Epstein would stop pushing the issue. - . began providing massages and advised she kept her clothes on. She considered Epstein a pervert and he kept pushing to go further and further. • explained she would keep telling him she had a boyfriend and would not be right to her boyfriend. It wasn't until recently that began removing her clothes and staying in her thong underwear to provide a massage. explained The foregoing instrument was sworn to or affirmed before me this ln day of May, 2006 by Bet , who is personally known to me. State of Florida ach Signatur Ing Officer Date: 0510112006 Pagelof 22 EFTA00231460 A 1 5 Probable Cause Affidavit Palm Beach Police Department Agency OFUN FLO 500600 Epstein wanted to be rubbed on his back and recently he began turning over and have her rub his chest as he masturbated. He would try to touch her breasts as she rubbed his chest. stated "Jeff would try to get away with more and more on each massage". 2:: stateStein would try to touch her more and on one occasion he at tett to use a massager/vibrator on her. dmve to the house for the original massage. LC_ left her cell phone number and every ti e stein would come into town, would call her for an appointment to "work". Each time she went, would meet her at the kitchen door area. She would bring her upstairs and re arc the massage table. 2.: advised stein would ask her questions about herself Epstein knew she was and would be attending . I asked : if Epstein knew her real age. ,.stated Epstein did and didn't care. The most recent massage she provided was on October 1, 2005. During the massage, she asked Epstein if she could borrow one of his vehicles to visit her family and boyfriend in , Florida. Epstein had told her she could borrow one of his vehicles but later stated he would rent her a car. She continued with the massage as Epstein and . I asked - if she was wearing undergarments to which she replied her thong underwear. Once he tried to touch ber breasts, she would pull away from hint and he would stop. ; was asked if he ev used a vibrator on her. . was aware of the vibrator but advised she never would allow him to on her. She described the vibrator as the large white vibrator with a huge head on the tip of the vibrator. She stated he kept the vibrator in a closet near the massage table. stated that on October 3, 2005, she was contacted by Epstein's assistant, who informed her that Jeff Epstein had rented her a new Nissan Sentra and she should come by the house to pick it up. informed ' she would have the car for a month. . stated Epstein knew her car was not working properly and that she had missed appointments in the past because of her car being inoperable. explained the car is • currently parked next to the Gym field. 1 asked her if she ever took any one to the house. . • explained sit. len of hers who attended Royal Palm Beach High School, who has relocated to to attend college. I asked if she ever allowed another female in the room. . :advised no one was brought into the room with her. At the conclusion of the interview, Det and I went to the gym area of Lynn. University and located the Silver Nissan Sentra bearing Florida tag . The vehicle is registered to Dollar Rent a Car out of the Palm Beach International Airport. The vehicle was rented by Janusz Banasiack, later learned to be Epstein's houseman, and paid with Epstein's credit card. On September I I, 2005, w/f dob la was arrested by the Palm Beach Police Department The foregoing instrument was sworn to or iffirmed before me this I" day of May, 2006 by Det who is personally known to me. Signature of Pali e Officer (F.S.S. 117.1 State of Florida Date: 05/01/2006 Pagel0of 22 EFTA00231461 Signature of Police Officer (P.S.S. 117.10) A16 Probable Cause Affidavit Palm Beach Police Department Agency ORD tIA) soda) for misdemeanor possession of marijuana. During the atrest. told the arresting officer that she had information about sexual activity taking place at the residence of Jeffrey Epstein. Additionally, during the ongoing trash pulls frcim Epstein's residence, discarded papers were found which contained AH's name and cell phone number. On October. 11, 2005, Det and I met with and obtained a sworn taped statement explained she had been going to Epstein' e since 2002, when she was sixteen years of age. Since then she has gone to the house hundreds of times. usstated she became his "number one girl." She explained that on jafirst visit she was brought to the house by fellow Royal Palm eac chool classmate, . said she was brought through the en area where she met for the first time. Ewes led to the master bedroom, Epstein s room. explained that as she was walkin up the stairs she observed several photographs of naked women along the walls and tables of the house. further explained that she was brought into the bedroom, where Sarah prepared the room by setting up the massage table and provided the oils for her to tub on Epstein. IN explained she remembered the steam room area, which contained two large showers. Epstein entered the to from the steam room area and introduced himself. Epstein lay on the table and told her to get comfortable. IN removed her skid and kept her shirt on. Epstein then instructed her to remove her shirt. removed her shirt and remembered she was not wearing a bra. stated she provided the massage wearing only her panties. She continued rubbing his legs, thighs and feet All advised he turned over onto his back. Epstein touched her breasts and be an to masturbate. Epsteth ejaculated which meant the 1118S At the conclusion of the massage, was paid 5200.00. They walked thgether downstairs where MIIIM and were waiting. stated ..... received an unknown amount of money for taking her to Epstein. Epstein instructed to leave her cellular telephone number, that he could contact her when he is in town. stated that during her many visits a routine was established between her and Epstein. She would enter the house and get naked in the bedroom. She would then start with a back Epstein would toll onto his back and allow her to massase his chest area. stated Epstein would then began to masturbate himself and at the same time would with his fingers. •ex lained Epstein taut this process until he ejaculated. He would then advised that during her frequent visits Epstein asked for her real age, stated she was sixteen. II anyone her real age. advised that thin escalated within the home as Epstein with his female friend . ■ explained the that Epstein had at his disposal. and masturbate himself . Occasionally, Epstein would then join in Epstein advised her no would instruct and pa included Epstein would watch them The (ongoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det who is personally known to me. State of Florida County of Palm Beach SIgnatu g Officer Date: 05/01/2006 Pageljof 22 EFTA00231462 A17 Probable Cause Affidavit Palm Beach Police Department Agency ORD, FLO sonata during ii ale on female intercourse and provide oral sex to bothEland Marcinkova. This occurred during the time r was sixteen years of age. advised this continued to evtalate during two years. The routine became familiar to Il. Epstein's assistant i would telephone her every time Epstein was in the Town of Palm Beach and would place appointments for her to visit ork for Epstein. Each timeisiething new was introduced, additional monies were produced and offered for to allow the acts to happen.. consented to perform all these acts but was adamant that there was an understanding with ein that no vaginal penetration would occ . An explained that Epstein's penis was deformed, . explained that his penis was oval shaped. claimed when tut called stein's penis "egg-shaped." . stated Epstein would photo ph Epstein's penis was erect, it was thick i ward the bottom but was thin and siiiiiiithe head and her and proudly display the photographs within the home. in which she provided a massage to Epstein, his•female friend, stated during one visit to Epstein's house was also present • provided the massage in which and her would fondle each others breasts and kiss for Epstein to en o . Towards the end of this massage, Epstein tttabbed and c upset over this. She said her bead was . She screamed "Not" and Epstein stopped. She told him that she did not want to . Epstein did not eSulate inside of her and apologized for his actions and subsequently paid her a thousand dollars for that visit. stated she knows he still displays her photographs through out the house. On October 12, 2005, Det and I met with . , dob who stated during a sworn taped statement, that nothing happened between her and Epstein. , appeared nervous during the interview. I assured her that I have spoken with other people who advised differently. _ , stated on several occasions she provided a massage to Epstein. Sherstated she was brought to the Epstein house in March of 2005. , a classmate at Royal Palm Beach Hi t School, approached her and asked her if she wanted to "work". made the arrangements with Epstein's assistant. , -, who has no formal training in providing massages, stated she provided a massage, fully clothed for $200.00 . As I sensed hesitancy in her answers, I asked if she had been contacted by anyone from Epstein's organizations or his house. stated she was interviewed already by a private investigator for Epstein. He identified himself as "Paul". and inquired about the police investigation, and left his telephone number for additional contact. • provided no additional information, as it appeared her responses were almost scripted. The foregoing instrumisvas sworn to or affirmed before me this 1" day 2006 by Act who is personally known to me. Signature of Police Officer I.S.S. 117.10) State of Florida Date: 05/01/2006 Page I 3)f 22 EFTA00231463 A18 Probable Cause Affidavit Palm Beach Police Department . Agency ORIN PLO 500600 On November 6, 2005, at approximately 3:30 pm, I met with dob-, at the Palm Beach Police Department. 1::. was identified as a potential witness/victim through information obtained during the trash pulls. During the sworn taped statement, .:. • advised she was at Jeffrey Epstein's house one time, approximately two months ago. She was approached by a girl, _ .1_, who was dating ' roommate, for an opportunity to make some quick money. 7 ; advised she needed to make some quick cash to make the rent that month. She agreed to go to the house. She had been told by ... that the massage would have to be done in her underwear. She advised "2 . :3 drove with her and brought her into the house. They walked into the kitchen area, and took the stairs upstairs. further stated she was brought into a master bedroom area. She advised she recalled seeing portraits of naked women throughout the room. A massage table was already out near the sauna/shower area in the master bedroom. Epstein entered the room wearing only a towel and introduced himself as "Jeff" At Epstein's direction, , and , ; removed their clothing down to their panties, Epstein laid on his stomach area and they provided a massage on his legs and feet area. I asked if she had any formal massage training and she replied "no." .... advised she was topless and the panties she wore were the boy shorts lace panties. She and: ' continued the massage until the last ten minutes of the massage, Epstein, told to leave the mom so that' could finish the massage. • got dressed, and left the room as Epstein turned over onto his back. Epstein then removed the towel and laid naked . Epstein requested that . rub his chest S. - -gated as she did this, Epstein, began masturbating. stated Epstein pulled down her boy short panties, and be produced a ler e white vibrator • She stated it was within his reach in a drawer in his master bathroom. advised he never penetrated her vagina with the vibrator. He continued to nib hei vagina with the vibrator as he continued to masturbate. stated she was very uncomfortable during the • incident but knew it was almost over. Epstein climaxed and started to remove himself from the table. He wiped himself with the towel he bad on previously and went into the shower area. got dressed and met with in the kitchen area. Epstein came into the kitchen and provided $200.00 for bringing = • and paid $200.00 to for providing the massage. was told to leave her telephone number with for future contact. -irovided her cellular telephone number. was asked if she was recently contacted about this investigation by m the Epstein organization. She replied she was called but it VMS for work. She e was called by for her to return to "work" for Epstein. stated "work" is the term used bslito provide the massages and other things. advised she declined as she was not comfortable in providing that type of "work." On November 7, 2005, Det Mt and I mct with dob During a sworn taped statement, _ . stated she met Jeffrey Epstein through when ey were still The foregoing instrument was sworn to or affirmed before me this l" day of May, 2006 by Det who is personally knolwn to me. Signature of Police dfficer (F.S.S. 117.40) State of Florida Date: 05/01/2006 tcer Page r3o f 22 EFTA00231464 Probable Cause Affidavit Palm Beach Police Department Agency ORTN FL O 500600 attending Royal Palm Beach High School. would approach females who wished to work for Epstein. • stated she was offered to work for Epstein but declined — - explained that "work" means give massages. She was asked about any formal training in providing massages which she said "no." • said she accompanied and other females who were taken to Epstein's house to provide massages. ' further stated she had been to the house approximate) 4 or 5 times in the past year. She accompanied with M, and. Each time the girls were taken over, they were previously told they woulJ have to provide a massage, possibly naked. They were also told that should Epstein require them to do anything extra, and they were not comfortable just to tell him and he would stop. . .• . stated received $200.00 for each gid she E> ght over to massage Jeffrey Epstein. When I asked which girl appeared to be the youngest, she replied, who was really young, fifteen years old at the most. • further stated each time she went to the house, s e sat in the kitchen and waited with until the massage was over. She further stated that the cook would make lunch or a snack for them as they waited. I asked her if there was anything that caught hcr attention within the home. stated there were a lot of naked girls in photographs throughout the house. On November 8, 2005, at approximately 2:00pin , I met with ,, dob , at the Palm Beach Police Department. During a sworn taped statemen , a classmate at Royal Palm Beach stated she had met Epstein approximately two ago when she was first approached by High School. approached her about working for Epstein and providing a massage to him for $200.00. bad made the arrangements however was unable to take her the day the arrangements were made. had take , . • also attended Royal Palm Beach High School and was familiar with Epstein. , recalled she was brow t there and entered through the back kitchen door. She had met with an assistant and another assistant . brought her upstairs as she observed several photographs of naked females throughout the house. ;fated Epstein came in the room, wearing only a towel, and laid on the table. stated he picked out the oils he wanted her to use and requested she remove her clothing to provide the massage. stated that on the first massage she provided she did not remove her clothing. stated she had returned several times after that. Each time she returned it was more than a massage. Epstein would walk into the master bedromn/bathroom area wearing only a towel. He would masturbate as she provided a massage. stated she was unsure if he climaxed as he masturbated under the towel. Additionally, she never looked below his waist. She claimed that Epstein would convince her to remove her clothes. She eventually removed her clothes and stayed in her thong panties. On occasion, Epstein e vibrator which she described as white in color and a large head. Epstein would as he would masturbate. stated she had been to the house The foregoing instrument was sworn to or affirmed before me this In day of May, 2006 by Oct . , who is personally known to me. Signature of Police Offieer P.S.S. 31 -1 ) State of Florida Date: 05/01/2006 Pageitiof 22 EFTA00231465 A20 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 numerous times. added she has no formal training in providing a massage. - stated she brought two females during her visits to provide massages. stated she brought a girl named ".' ." and from Royal Palm Beach High School. stated she received $200.00 for each girl she brought. On November 8, 2005, I met with . ' — W/F, at the Palm Beach Police Department. During a sworn taped statement' had met Jeffrey Epstein approximately one year ago. She was approached by a subject known to her as had asked her if she wanted to make money providing massages to Epstein. — had heard that seve girls from 11.2. I Palm Beach High School were doing this and making money. She agreed and was taken to the house by had introduced her to and Epstein and bra ht her upstairs to a master bedroom where a massage table was prepared and the proper oils were selected. left the room and waited downstairs for her. - stated Epstein entered the room wearing a towel and laid on his stomach. She provided a massage wearing only her thong panties. advised Epstein had masturbated every time she provided a massage. She stated Epstein continued to masturbate until he climaxed. Once that occurred the massage was over. She felt the whole situation was weird but she advised she was paid $200.00 for providing the massage. She also stated was paid $200.00 by Epstein for bringing - - stated she had gone a total of 15 times to Epstein's residence to rovide a massage and things had escalated from just providing a masse e. stein be an touchin and grabbed her closer to him as he masturbated. Epstein also and with his bands as she provided the massage. stated on one occasion, while she was only seventeen years of age, he offered extra monies to have vaginal intercourse. She stated this all occurred on the massage table. stated and be an and climaxed onto the massage table. , received $350.00 for her massage. I asked her if she had any formal training in providing masse es : stated she did of . continued to state on one other occasion, Epstein introduced his girlfriend, into the massage. was brought into room with to provide a massage. Epstein had them as they provided a massage to Epstein. Epstein, watched and masturbated as ' ions, Epstei.trodueed the large white vibrator/massager in the massage. Epstein on as she provided the massage. On November 14, 2005, Dct and I met with , deb . During a sworn taped statement she advised she started going to the house approximately one year ago and has been there approximately five or six times. also stated she was sixteen years old when she first went to Epstein's house. On her first visit she was brought by a fellow student from Royal Palm Beach High School known to her until he reached the point of The foregoing instrument was sworn to or affirmed befo e e this 1" day of May, 2006 by Oct who is personally known to me. Signature of Police Meer .S.S. 117.10) State of Florida Con of Palm Beach Signatur Officer Date: 05/01/2006 Page igif 22 EFTA00231466 A21--- Probable Cause Affidavit Palm Beach Police Department Agency ORiM PLO 500600 • as gated • brought her into the house and she was introduced to then brought her upstairs into a master bathroom, located within the bedroom. stated she met Epstein in the bathroom. He laid on the table and picked the massage oils. She provided the massage as he laid naked on the massage bed. She stated she rubbed his calves and back area. Upon the end of the massage, Epstein removed himself from the massage table and paid her $300.00 for the massage. , • said each subsequent time she went to the house, she was notified by that Epstein was in town and would like her to "work". • stated she returned to the house and was again led upstairs by Sarah. She provided the massage, clothed. . . was asked if she ever removed her clothing to provide a massage. Sated it MS not until the third time that she went that she removed her clothing. stated she was notified by that Epstein wanted her to come to work. She arrived at the house and was led upstairs by =. She started providing the massage when Epstein asked her to remove her clothing. removed her pants, shirt and bra. She sta ed in her thong panties and . Epstein turned over onto his back and she stated she knew he was masturbating himself as she providing the mas stated she believed he climaxed based on his breathing. She did not want to view either the or the fact that he was masturbating. stated once the breathing relaxed he got up and told her to get dressed. She was paid $300.00 for her services. stated on the last time she went to provide a massage, she was notified by MM. to come to the house and "work". stated she was now dating het current boyfriend and did not feel comfortable going. She recalled it was approximately January 2005. She said she went, already thinking that this would be the last time. She went upstairs and went into the master bathroom. She met with Epstein, who was wearing only a towel, and laid onto the table. stated Epstein caught her looking at the clock on several occasions. Epstein asked her if she was in a hurry. stated her boyfriend was in the car waiting for her. further stated that Epstein got upset as he wasn't enjoying the massage. She told him that she didn't want to continue and she would not be back. Epstein told her to leave as she was ruining his massage. advised she had no formal training in providing any massages. stated although she had a falling out with Epstein, she still received a Christmas bonus from Epstein. stated she was wired money from Western Union for her Christmas bonus. Subpoena results from Western Union revealed money was sent from Jeffrey Epstein on December 23, 2004. .. received $200.00 from Epstein for her Christmas bonus. On November 15, 2005, Pet. and f met with dob 04/21/1988. During a sworn taped statement, ■ stated she met Jeffrey pstein over a year ago. e was sixteen years of age and was approached by ' , , a fellow Royal Palm Beach High School student, who informed her that she could make $200.00 providing a massage to Epstein. ' had informed her that she would have to provide this The foregoing instrument was sworn to or affirmed trek " day eilMay, 2006 by Co Palm Bench ' Det who is ersonally known to me. Signature of Poll... Officer .S.S. 117.10) State of Florida Signatu fieer Date: 05/01/2006 Pagekof 22 EFTA00231467 A22, Probable Cause Affidavit Palm Beach Police Department Agency ORD/ FLO S00600 massagetopless. — '. made the arrangements with Epstein and his assistants and took. to the house.. stated — ' and she entered through a glass door that led into a kitchen. She was taken upstairs by ........4 to a master bedroom. She recalled the master bathroom had a large pink couch, sauna and matching shower. Epstein entered into the room wearing only a towel. . and : ' removed their clothing remaining only in thong underwear. She further stated that Epstein laid on his chest on the table. The oils were selected on which ones to use. Both - and . provided the massage on his legs, back and feet. Forty minutes into tl massage, Epstein turned over onto his back and requested . , wai wnstairs in the kitchen area for IMI. Epstein instructed . to finish the massage. As : . ' of dress startingLubbing Epstein's chest. left the room, and Epstein began masturbating as . M stated Epstein continued masturbating until he climaxed on the towel he was wearing. When asked if he had removed the towel she stated he turned the towel around 1 that the opening would allow him to expose himself. After he cleaned himself off with the towel he instructed the massage was done and to get dressed and meet with him downstairs. pof dressed and met with Epstein in the kitchen area. She was paid $200.00 dollars for providing the manage. . stated she was aware that also received monies for the same thing. The second time she went to the house she was again approached by ... advised if she wanted to return to the house tchgovide another massage.. agreed and the arrangements were made by for her to return to the house. M stated , - drove her to the house and knocked on the same glass door which leads to the kitchen area. They were allowed entry into the house by one of the staff members. . led her upstairs to the master bedroom and master bathroom area. :-. _. I. left . this time to do the message alone. Epstein entered the room again wearing only a towel. 5 began removing her clothing as she did the last time she was at the house. Epstein instructed her to get naked. He laid on the table onto his stomach as . began massy his legs and back. As . finished with Epstein's back and legs, Epstein then turned over onto his back. M started to rub his chest and he began masturbatin . As rubbed his chest, Epstein leaned over and produced a massager/vibrator. He turned it on and began and masturbating himself at the same time. 5 stated she as this was occurring. She described the vibrator/massager as large grey with a large head. Epstein rnately two to three minutes with the massager/vibrator. He then removed the and concentrated on masturbating himself. MD stated Epstein climaxed onto the towel again and informed her that the massage was done. li got dressed and met with : _ _ who was waiting in the kitchen area. She received $200.00 for the massage. said she never returned to the house and had no desire to return to the house. 1.was asked if she received any formal massage training. She advised she had no formal training. 5 was asked if Epstein knew her real age. 5 stated he knew, as he asked her questions about herself and high school. He was aware she attended, and is still attending Royal Palm Beach High School. The foregoing instrument was sworn to or affirmed before me this day of May, 2006 by Det who is personally known to me. Signature of Polict Officer (F.S.S. 117.10) State of Florida Co f Palm Beach Signs ng Officer Date: 0 i 1/2006 Paget? f 22 EFTA00231468 A23 Probable Cause Affidavit Palm Beach Police Department Arg.aey ORI# PLO 500600 During the course of the investigation a search warrant was executed at Jeffrey Epstein's home located at 358 El Brillo•Way in Palm Beach. While in the home I observed the pink and green couch within the master bedroom area just as the girls previously mentioned. The stairway, which is located from the kitchen area to the master bedroom area, is lined with photos of naked young girls. Additionally, numerous photographs of naked young females, some of which appeared to be the girls I previously interviewed, were on display throughout the house. Also located in the house were various phone message books. The telephone message books have a duplicate copy (Carbon Copy) which, once a phone message is written into the book, the top copy is then torn on the perforated edge and the carbon copy is left in the book. First names of girls, dates and telephone numbers were on the copy of the messages. I recognized various numbers and names of girls that had already been interviewed. The body of the messages were time of the day that they called for confirmation of "work." Other names and telephone numbers were located in which the bed of the messages were, "I have girls for him" or "I have 2 girls for him." These messages were taken by who signed the bottom of messages. During the execution of the warrant, I located a Royal Palm Beach High School transcript for in Epstein's bedroom desk. This desk had stationary marked Jeffrey E Epstein. I located a wood colored armoire beside Epstein's bed that contained a bottle of "Joy Jelly," which is used to provide a warm massage. Several massage tables were located throughout the second floor of the residence, including a massage table found in Epstein's bedroom. On the first floor of the residence I found two covert cameras hidden within clocks. One was located in the garage and the other located in the library area on a shelf behind Epstein's desk. A computer was located which was believed to contain the ima es from the covert cameras. The computer's bard drive was reviewed which showed several images of and other witnesses that have been interviewed. All of these images appeared to come from the camera positioned behind Epstein's desk. On December 13, 2005, Det and I met with ML, dob . During a sworn taped statement, stated that when she was sixteen years old she was taken to Epstein's house to provide a massage for money. stated it was before Christmas last af r (2004) when an associate, approached her and ed if she needed to make money for Christmas.. made arrangements to take to the house and drove to the house to "work." They were encountered by a white female with long blond hair.. was unable to remember the name of the white female with blond hair but knew she was Epstein's assistant. She was led upstairs by the white female who explained that there would be lotions out already and Epstein would choose the lotion he wanted her to use. She was led through a spiral staircase which led to .a master bedroom and bathroom. The massage table was already set up in the bathroom. NI described the bathroom as a large spacious bathroom with a steam room and shower beside it.. was introduced to Epstein who was on the phone when she entered the room. Epstein was wearing a white towel and laid on his stomach so that . may The foregoing instrument was sworn to or affirmed before me this In day of May, 2006 by pet who is personally known to me. Signature of Police r fficer .S.S. 117.10) State of Florida Signatur ng Officer Date: 05 s /2006 Page ler 22 EFTA00231469 A24 Probable Cause Affidavit Palm Beach Police Department Agency 0RDI Ft O 500600 massage his feet and calves. ■ started the massage with the oils Epstein chose and rubbed his feet and calves. Epstein got off the phone and requested she massage his back as well. ■ began rubbing his back and got to the small of his back. Durinhe rubbing of his back, Epstein asked her to gLcomfortable. He requested she remove her pants and shirt removed her shirt and pulled her pants off. stayed in her bra and thong panties. As she finished massaging the small of Epstein's back, be then turned onto his back. Epstein instructed ■ to rub his chest and pinch his nipples. As she began to rub his chest, Epstein asked her questions about herself I. remembered telling him she attended Royal Palm Beach High School. Epstein asked her if she was sexually active. Before could answer, he also asked what sexu a e enjoy. 1. stated she was shy and didn't like talking about those things. She continued . Epstein reached her bra from the front. ■ expl and asked her if she like having d a front snapping deviee, Epstein • said "no, I don't like that." Epstein then removed his towel and laid on the bed naked exposing his penis to . He an touchin his nis and en touched tensed up and stated Epstein was aware that she was uncomfortable. stated that Epstein said to her, "Relax, I'm not going inside.". She further explained Epstein co utiful and sexy she was. Epstein then moved ber thong panties to one side "He commented how c." He then She tried pulling back to Epstein and apologized for Dining this time, he kept his and continued to rub her vagina. stated he ribbed her really hard as he was masturbating. said he climaxed onto the towel he had been previously wearing and got up from the table, Epstein told her there was $200.00 dollars for her on the dresser within the master bathroom. Epstein also told her that there was an additional $100.00 that was to be given to YT, for bringing her there to massage him. Epstein told her to leave her telephone number with his assistant as he wanted to see her. again. Epstein stated his assistant w uld contact her to work again soon. I asked her if she ever received any formal massage training to which IN stated she did not. stated it was the only time she ever went to work for. and knew what happened to her was wrong. She further stated that she had never been contacted fir any additional work. On January 9, 2006, I located and interviewed another victim, dob was identified as a potential vietim/witness from information obtained during trash pulls from Epstein's residence. stated she met Eps • was fifteen years of age. She was approached by a friend from Royal Palm Beac High School, to be taken to Jeffrey Epstein's house to work. She was originally told she would be able The foregoing instrument was sworn to or affirmed befo e this 1" day of May, 2006 by Det , who is personally known to me. Signature of PoliceOfficer (F.S.S. 117.10) State of Florida Co ach Signatur mg Officer Date: 05 /2006 Pagcoof 22 EFTA00231470 A25 Probable Cause Affidavit Palm Beach Police Department Agency 0RO FLO 500600 lo model lingerie for a wealthy Palm Reacher.. was taken to Epstein's house 1 on lloWay. introduced . to Jeffrey Epstein. Epstein had hilarsonal chef prepare dinner foli dand . At the conclusion of dinner, and Epstein brought . upstairs into a master bedroom area. obs . large massage table with a sheet on it. Epstein entered through a door and exited wearing only a towel . informed. that they were oing to provide a massage on Epstein N asked why were they doing this instead of modeling lingerie, explained to. that this was his routine and to rub his calves and feet. Epstein had told. to get comfortable. removed her pants and blouse. CL stated she stayed only in panties as she did not wear a bra that evening. stated while rubbing his calves and feet, Epstein turned ve his back. Epstein told. to rub his chest and rub his ni les. stated that as she started Epstein began masturbating himself. Epstein and with his fingers. LLstein continued to masturbate himself as he . Epstein ejaculated on histowel and paid . $200.00 for the massage. stein told. that if she told anyone what happened at his house that bad things could happen. and =I were brought home by Epstein's houseman and . was afraid that Epstein knew where she lived, stated that several days later she received a telephone call from who coordinatectfor . to return to "work," . returned to the house and was brought to Epstein's bedroom area by who prepared the room for the massage. Epstein entered the morn wearing only a towel. Epstein had remove her clothing and provide the massy e naked.. began rubbing his feet and calves and Epstein turned over onto his back Epstein with his forgers. E in be an to masturbate himself with an upwards and downward motion on his penis. Epstein continued with one hand and masturbate with the other hand. Once Epstein ejaculated onto the towel be was wearing, the massage was over.. was paid $200.00 for the massage. Epstein again told. not to speak of what happened at his house or bad things would happen.. wanted to notify authorities however she was afraid of what would happen to either her or her family. During the course of the investigation, several subjects were identified as a potential witness/victitn through information obtained during the trash pulls, physical surveillance and telephone message books retrieved from the search warrant. While conducting research on the subjects, I discovered that the females were age eighteen or older. Interviews were conducted on the consenting adults whose statements provided the same massage routine when they went to "work" for Epstein. The females would be notified by , and made appointments for the female's to "work" for Epstein. The females would come to Epstein's house and were led upstairs, through a stairwell from the kitchen area, by to Epstein's bedroom. Epstein would then enter the room wearing only a towel, and ask them to et comfortable. The females would then provide the massage naked as Epstein would either and/or utilize the The foregoing instrument was sworn to or affirmed State of Florida before me this I" day of May, 2006 by Del , who is personally known to mo. Signa ur er Signature of Police Officer (F.S.S. 117.10) Date: 0 7 /2006 Pag5t pf 22 EFTA00231471 Uge Lilt LUAU 1V:.71 JoAatKituuu A26 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 300600 He would masturbate during the massage and upon his climaxing, the massage would end. The girls were then paid two or three hundred dollars for the massage. On November 21, 2005 I interviewed Jose Alessi, a former houseman for Jeffrey Epstein. Alessi stated he was employed for eleven years with Mr. Epstein, from approximately 1993 through 2004. Alessi stated he was the house manager, driver and house maintenance person. it was his responsibility to prepare the house for Epstein s arrival. When asked about cooks or assistants, Alessi stated they traveled with Epstein on his private plane. I asked Mr. Alessi about the massages that have occurred at Epstein's home. Alessi stated Epstein receives three massages a day. Each masseuse that visited the house was different. Alessi stated that towards the end of his employment, the masseuses were younger and younger. When asked how young, Mr. Alessi stated they appeared to be sixteen or seventeen years of age at the most. The massages would occur in Epstein's bedroom or bathroom. He knew this because he often set up the massage tables. I asked if there were things going on other than a massage. Alessi stated that there were times towards the end of his employment that he would have to wash off a massager/vibrator and a long rubber penis, which were in the sink after the massage. Additionally, he stated the bed would almost always have to be made after the massage. On January 4, 2006 I interviewed another former houseman, Mr Alfredo Rodriguez. During a sworn taped statement, Mr. Rodriguez stated he was employed by Jeffrey Epstein for approximately six months, from November 2004 through May of 2005. His responsibilities as house manager included being the butler, • chauffeur, chef, houseman, run errands for Epstein and provide for Epstcin's guests. I asked Rodriguez about masseuses coining to the house. Rodriguez stated Epstein would have two massages a day. Epstein would have one massage in the morning and one massage in the afternoon everyday he was in residence. Rodriguez stated he would be informed to expect someone and make them comfortable until either or Epstein would meet with them. Rodriguez stated once the masseuses would arrive, he would allow them entr into the kitchen area and offer them something to drink or eat. They would then be encountered by either or Epstein. They would be taken upstairs to provide the massage. I asked Rodriguez if any of the masseuses appeared young in age. Rodriguez stated the girls that would come appeared to be too young to be masseuses. He stated one time under Epstein's direction, he delivered a dozen roses to Royal Palm Beach High School for one of the girls that came to provide a massage. He knew the girls were still in high school and were of high school age. I asked Rodriguez about the massages. He felt there was a lot more going on than just massages. He would often clean Mr. Epstein's bedroom after the alleged massages and would discover massagers/vibrators and sex toys scattered on the floor. He also said he would wipe down the vibrators and sex toys and put them away in an armoire. He described the armoire as a small wood armoire which was on the wall close to Epstein's The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det , who is personally known to me. Signature of Polie Office .SS. 117.10) State of Florida C Signs tu f Palm Beach ng Officer Date: 05/01/2006 Page21of 22 EFTA00231472 A27 I I ' MUG JO/ c.cU Signature of Folic Officer (F.S.S. 117.10) Probable Cause /Affidavit Palm Beach Police Department Agency 010K FLO 500600 bed. On one occasion Epstein ordered Rodriguez to go to the Dollar rent a car and rent a car for the same girl he brought the roses to, so that she could drive her self to Epstein's house without incident. Rodriguez said the girl always needed rides to and from the house. Rodriguez produced a green folder which contained documents, and a note with Mr. Epstein's stationary with direction to deliver a bucket of roses to Royal Palm Beach High School after AB high school drama performance. Also in that same note was direction to rent a car for. and direction to extend the rental contract During the course of the investigation, subpoenas were obtained for cell hone and home phone records from several victims and witnesses along with the cell phone records of An anal sis of these records was conducted which found numerous telephone calls were made between and the victims. These records indicate the dates the calls were made arc consistent with the dates and times they victims/witnesses stated they were contacted. Specificall , The phone records showed % called during the exact times and dates wh victi advised the incident occurred. also coordinated the encounters with E, . stated they ocarred. and x , during the time frame the girls Pursuant to a lawful subpoena l obtained Epstein's private plane records for 2005 from Jet Aviation. The plane records show arrival and departure of Epstein's lane at Palm Beach International airport. These records were compared to the cell phone records of made to e victims were in the days just prior to their • ' g the time E stei This comparison found that all the phone calls was in Paint Beath in, who at the ti f 'dents was fifty one years of age, did have vaginal intercourse either lail or digitally with, and I _ ...., who were minors at the time this occurred, end who at the time of the incident was fi two ars of age, did use of SG, a fourteen year old minor. Therefore, as coordinated and aided in the recruitment of minors to frequent Epstein's house so that sexual services were provided to Epstein, scheduled the said minors to return to the work for Epstein, secured their appointments for the purpose of sexual activity and lewd and lascivious acts and arranged the bedroom for said minors, there is sufficient probable cause to charge with four counts of Principal in the I" degree Unlawful Sexual Activity with a Minor, in violation of Florida State Statute 794.05(1) , a second degree felony and there is sufficient probable cause to charge her with Lewd and lascivious Molestation, in violation of Florida State Statute 800.04 (5), a second degree felony. The. foregoing instrument was sworn to or affirmed before me this I" day of May, 2006 by Oct , who is personally known to me. State of Florida Signet tang Officer Date: i /01/2006 Page2Lof 22 EFTA00231473 A28 Palm Beach Sheriffs Office Booking Card for Jeffrey Epstein, dated July 23, 2006 v -v• le a eLgo.b•J 14. 01 UJJ ...EPSTEIN, JEFFREY ALIAS PLUME OVER tunics. O JACKET ft: 0338617 - -7 t 2006036744 NONE. SUndsy, July 23. 2006 20244 AM INCARCERATION DATEMLIE 07/23/2006 1:56 PRISONER TYPE LOCAL CHARGES DOB: 01/20/1953 WPA AGE 63 HEIGHT: BROM 53N: WEIGHT: 180 ADDRESS: 358 EL BRILLO WY A: 20080723017 SID ALIEN 0: FBI P: POUCH 1291 AFIS: U.S MARSHAL If: oust ARREST ADDRESS3228 GUN CLUB ROAD ARREST DATE: 07/23/2000 BKG. DATE 0723/2006 WARRANT/CASEO: 06009454CFA99 W ARREST WINGER: CASTILLO TRANS OFFICER: SELF SURRENDER :ASE TYPE: FELONY cite STATUTE COUNTSESCRIPTIOR PALM BEACH SHERIFFS OFFICE BOOKING CARD 0103.1.0C: MDC INTAKE 8103 ID*: 6199 MR COLOR GRY EVE COLOR Ku CRY: PALM BEACH STATE: FL ZIP: 33480 NCIC: DOC INCIDENT ft CITY: WPB STATE: in. ZIP: 33406 ARREST TIME 1:30 EKG. TIME 1:56 CURRENT BOND' $3,000.00 COURT DIVISION: T - MARX, KRISTA ARREST AGENCY: 01 • P/3130 TRANS. AGENCY: CASE RAG 796.01 22 (FT) 1 PROSTITUTION-OFFER COMMIT ENGAGE 3RD SUMO OFF 0 0 0 "SEALED INDICTMENT" NO INFORMATION GIVEN" SEALED INDICTMENT JUDGE KROLL 0 CTI) FELONY SOLICITATION OF PROSTITUTION (3F) 1OLDS: HOLD °AMENS HOLD BY: HOLD DEPT.: KID REILDATERNE: HOW RDA. BY: HOLD RE/4. DEPT: ALERT DESCRIPTION: ALERT NARRATIVE: VER 3 ALERTS: KEEP SEPARATE FROM: NONE VER 6 NAMES: SSIGNED HOUSING: NTA DATFJTIME: NTA LOC: CIC INTAKE: NCIC RELEASE: P.P.ENTERED: en' ARMS REU PHOTO ID: CIASSIPICATION: 11LID.O.EAR IN' ED. CLEAR Ate RELEASE MOVE: ?LEASE DATER1ME: . RELEASE INFORMATION: 3URT DATEMME: COURT LOCATION CLERK 0 WARRANTS D STATE Ally U CENTRAL RCOS 1] CLASS Ill EFTA00231474 A29 2006 Grand Jury Indictment of Felony Solicitation of Prostitution - Jeffrey E. Epstein [pp. A29-A301 us..rine...0W £4:J1 OvI.J.J41U4J A TRUE BILL IN THE NAME OF AND BY THE AUTHORITY OF THE STATE OF FLORIDA IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA For Palm Beach County, at the Spring Term thereof, in the year of our Lord Two Thousand and Six, to-wit The Grand Jurors of the State of Florida, inquiring in and for the body of said County of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid, in the Circuit and State aforesaid, COUNT ONE FELONY SOLICITATION OF PROSTITUTION on or about or between the 1st day of August in the year of our Lord Two Thousand and Four and October 31, 2005, did solicit, Induce, entice, or procure another to commit prostitution lewdness, or assignation, contrary to Florida Statute (96.07(1) on three or more occasions between August 01, 2004 and October 31, 2005, contrary to Florida Statute 796.07(2)(f) and (4)(c). (3 DEG FEL)(LEVEL 1) against the form of the statute, to the evil example of all others, and against the peace and dignity of the State of Florida. I hereby certify that I have advised the Grand Jury returning this indictment as authorized and required by law. Assistant State Attorney of the Fifteenth Judicial Circuit of the ' of Florida, prosecuting for the said Stale EFTA00231475 A30 GRAND JURY FOREPERSON DATE Jeffrey E. Epstein, Race: White, Sex: Male, OOB: January 20, 1953, Issue Warrant EFTA00231476 A31 Information for Procuring Person under 18 for Prostitution - Jeffrey E. Epstein, dated June 26, 2008 STATE OF FLORIDA vs. JEFFREY E EPSTEIN, W/M, 01/20/1953, IN THE CIRCUIT-COURT OF THE FIFTEENTH TUDICM CIRCUIT • IN AND FOR PALM BEACH COUNTY, STATE OF FLORIDA CRIMINAL DIVISION "W" (LB) OYCF 9 3P / MUSES FROM BOOKING NO.: 2006036744 / INFORhiATION FOR: 1) PROCURING PERSON UNDER 18 FOR PROSTITUION al r- - O m ==. (.4 In the Name and by Authority of the State of Florida: rOrTi 00 BARRY E. KRISCHER, State Attorney for the Fifteenth Judicial Circuit, Palm Beach Pfnty1Florida, by and through his undersigned Assistant State Attorney, charges that JEFFREY E EPSTEIN on or about or between the day of August in the year of our Lord Two Thousand and Four and October 9, 2005, did blowing!), and unlawfully procure for prostitution, or caused to be prostituted, gm a person under the age of 18 years, contrary to Florida Statute 796.03. (2 DEG FEL) P. O. FL. BAR NO. 0776726 Assistant State Attorney STATE OF FLORIDA COUNTY OF PALM BEACH Appeared before me, LANNA BELOHLAVEK Assistant State Attorney for Palm Beach County, Florida, personally known to me, who, being first duly sworn, says that the allegations as set forth in the foregoing information are based upon facts that have been sworn to asjae, and which, if true, would constitute the offense therein charged, that this prosecution is instituted in good M, and certifies that testimony under oath has been received from the material witness or wltnesgds for the 7 off Assistant State Attorney Dawes P'na Olutenatt 00120191 £10211 LB/dp • AUVLIIt 2, 2010 le14/ KOCOMVIICIIMINOULWX .c FCIC REFERENCE NUMBERS: 1) FELONY SOLICITATION OF PROSTITUTION 3699 Sworn to and subscribed to before me thiatti4Lday ofJune, 2008. r(Intniu:O NOTARY PUBLIC, e of Pion a eifiA II IN 9 A noon EFTA00231477 A32 Guilty Plea for Felony Solicitation of Prostitution and Procuring Person under 18 for Prostitution - Jeffrey E. Epstein, dated June 30, 2008 I Lame... PLEA in THE CIRCUrt COURT THE FOLLOWING IS TO REFLECT ALL TERMS OF THE NEGOTIATED SETTLEMEN1 Name: Jeffrey E. Epstein Plea: May _X Ca-re•S GITAtZi Count Lesser _11:.qtM 06CF009454AM8 Felony Solicitation of Prostrtution 1 No 3 FEL 08CF003381AM8 Procuring Person Under 18 for ProstRuflon 1 No 2 Fri PSI: Watvednibt Required _X RequIrechRequested L±Dfl110M: kIL Adjudicate [x J SENTENCE: On 06c80094.54AMEI, the Oeferadant Ls sentenced to 12 months in the Palm Beech County Detention Facility, with crecla fort (one) day tent served, On 08CFC09361AMB, the 13efendent in seirtnntaad to 6 morntniln the Patin Beach County Detention Facility, with credit for 1 (one) day time served. This 6 month sentence Is to he served consecutive to the 12 month sentence In 06CF0094S4AMEL Following thls 8 month sentence, the Defendant wit be placed on 12 months Community Control 1 (one). The cone/bens of community control are attached hereto and Incorporated Well. 0ThErt COMMENTS OR CtONDMONS: As a special conclAbn of his community control, the Defendant Is to have no 'ninon/heel contact with minors, and the supervhIng adult must be approved by the Depa.tient cf Correctlerns, The Defendant designated as a Sexual Offender pursuant to Fbrida Statute 943.0435 and must abide by al the corresponding requirements of the shrtuto, a copy of which trt attached hereto and incorporated herein. The Defendant must provide a DNA sample In court at the time of EFTA00231478 DA A33 Judgment for Procuring Person under 18 for Prostitution, dated June 30, 2008 04/26/2018 14:51 3553626 CIRCUIT CRIMINAL PAGE 06/20 ("HEQR NAL DIVISION OF THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA. IN AND FOR PALM ElEAC14 COUNTY CASE NO. OUTS Ha STATE OF FLORIDA f i ff-yey C r erft;n EFEN ANT TH RACE GENDER I I COMMUNITY CONTROL VIOLATOR II PROBATION VIOLATOR CPR 20080267252 OR BR 22760 PG 0565 RECORDED 97/17/2•08 eat 06s 42 Pali Bract County, Florida Sharon R. Bock, CLERK IL CORPTROLLER Pa 0565; (lpg) JUDGMENT The above Defendant being riersonally before this Court represented b I V V I J Having been tried and kund rainy of the following erime(sk tyl, Having entered a plea of guilty to the folios. ing crime(s): ( ) Having entered a plea of nolo contcsadero to the following erimc(s): 5.01/k atame COUNT ;Isr, o Iv f l fastAduk, OFFENSE STATUTE NtiMBER(S) 7111/.0 DECREE ZDF >c I I and no cause having been shown why the Defendant should nor bc adjudicated guilty. IT IS ORDERED THAT the Defendant is hereby ADJUDICATED GUILTY of the shove erimeks. and 113%bIlS ban entitled or fond guilty of. or having entered n plea of nolo contenders or guiltyscrudksi of adjudication. to initnIptS ar orgenses relating to icnnal baticti Wt. 794). kwd and lascivious conduct (ch. 300). or manor (s. 78.1.0-1). aggravated Snug CA. 734.0.1 ). burglary (s. 31Ø.0P. catjaeking (s. 1313.1.131. or Mme imØsion fhhhCfy 613.1351. or any roha offense specified in"Section 943.325. the defendant shall he required to submit blood specimens. • I I and good Cann being shown. IT IS ORDERED THAT ADJUDICATION OF GUILT BE WITHHELp JUN 4 u SENTENCE I I The Court herds, stays and withholds IMPOShiOft of sentence al to auras' and Ones the Defendant art . • STAYED ) Probation andtfor I I Community Control under the supervision of the Dept of Carreeinik (conditions af probation set forth in separate order). SENTENCE DEFERRED I I The Court hereby deters impurites' of sentence until The Defendant in Open Coon was advised of his right to appeal from the Judgment by fling notice of Ciptlini with the Clerk of Court within thin) days Miming the date sentence is imposed or probation is mitered pursuant to this adjudication. The defendant was aka advised rif his tight to the af$1,1:111CC of maul In taking said appeal at the expense or the State upon showing of indigency. VE AND ORD riD in Open Courtin Palette eh County. Florida. this 3 7) day tari-a.in.-4 . 200 flacon.enr rItT RIDGE. JUL U Pl3" EFTA00231479 A34 Sentence for Procuring Person under 18 for Prostitution - Jeffrey E. Epstein, dated June 30, 2008 04/26/2010 14:51 3553626 CIRCUIT CRIMINAL PAC£ 07/20 IN THE CIRC.' COURT OF THE FIFTEENTH ALL CIRCUIT. IN AND FOR PALM BEACH COUNTY, FLORIDA SENTENCE (As to Count(s) ) DefendanDE Aey Ep 4?)-) Case NumbeCAUger 93314-14( °FITS Number The Defendant, being personally before this Coon, accompanied by the defendant's attorney of record, ‘Z-7rankle< and having been adjudicated guilty herein, and the Court having given the Defendant an opportunity to be heard and to offer matters in mitigation of sentence, and to show cause why defendant should not be sentenced as provided by law, and no cause being shown, IT IS THE SENTENCE OF THE COURT that The Defendant pay a fine of $ pursuant to § , Florida Statutes, plus all costs and additional charges as outlined in the Order assessing additional charges, costs and fines as set forth in a separate order entered herein The Defendant is hereby committed to the custody of the I ',Department of Corrections (4 Sheriff of Palm Beach County, Florida ( J Depament of Corrections as a youthful offender for a term of (1t47O5 . It is further ordered that the Defendant shall be allowed a total of / days as credit for time incarcerated prior to imposition of this sentence. Eris further ordered that the composite term of all sentences imposed for the counts specified in the order {hall run ()(1 consecutive to ( J concurrent with (check one) the following: Any active sentence being served. JUN 3 y Specific sentences: arn forf - 77.70,90( In the event the above sentence is to the Department of Corrections. the Sheriff of Palm Beach County, Florida is hereby ordered and directed to deliver the Defendant to the Department of Corrections together with a copy of the Judgment and Sentence, and any other documents specified by Florida Statute. Additionally, pursuant to 4947.16(4), Florida Statutes, the Court retains jurisdiction over the Defendant. I 1 Pursuant to §§322.055, 322.056. 322.26. 322.274, Fla. Stat., the Department of Highway Safety and Motor Vehicles is directed to revoke the Defendant's pnvilcgc to drive. The Clerk of the Court is Ordered to report the conviction and revocation to the Department of Highway Safety and Motor Vehicles. Die defendant in Open Court was advised of the right to appeal from this Sentence by fi ling notice of appeal within .hirty days from this date with the Clerk of the Court. The Defendant was also advised of the right to the assistance of :ounsel in taking said appeal at the expense of the State upon showing of indigency. ()ONE AND ORDERED in Open Court at West Palm Beath, Palm . 2oe. diLA'4 h a -h County. rids thist y of Form Circuit 5 (rev 8/2000) n CIRCUIT COURT JUDGE . EFTA00231480 A35 Community Control Standard Conditions, dated June 30, 2008 (pp. A35-A46J 04/26/2010 14:51 3553626 PAGE 09/ 20 criactscr CRIMINAL Kama o *Lump nua yop sum. COMPLY WITH TEE FOLLOWINGSNDITIONS•OF SUPERVISE:) It. .• /. • • ci.4MUNITY CONTROL AINDAPD CONDMONS: • • You will remain confined to your residence except one but hour before and after you approved ounoloym„r, community service work. or any other activities approved by your probation officer. You will maintain an barfly ucouotiog of all your actiMties on a daily log which you will submit to your supervising officer upon :squad. • The Dedurnent of Carnations. may it its discretion, places you on Electronic Monitoring during the term of your Community Control. If placed on Mecum& Monitoriug, you will wear ► monitor et all times. y ou will maintain a private phone line, be financially responsible for any lost or damaged equipment and follow all rules and regulations as instracted. The telephone will be available within five working days of being platten Electronic Monitoring Program. • white on electronic monitoring you will remain confined to your residence and are prohibited from being outside the residential walls. : (d) If while being monitored and the monk* is found to have been tampered with you be taken into custody immedi fitly, if the officer determines that your were not at your schedules place of work or school while allowed to be outside the residence then in that event you Shall be taken into custody immediately. If taken into custody, you shall be held without bond and shall, on the next working day, brought before a ludee treat:ling over his or her cue for further ) If placed on Electrordc Monitoring you will pay to the Sam of Florida, for the east of Electronic Monitoring 31.00 per A'S•1 day, perFS. 946.09, ..1. De fencitAft. 4. (Asa be. fc Ci ' 4-:11 I. IT Way, • ; oln— (c) It CONDITIONS (a) Yon will submit to sod, unless otherwise waived, be fmancially responsible for drug testieg, urinalysis at least on a monthly basis, and counseling if dernird appropriate by your supervising officer. (b) You will eater and successfully complete a trothsesure or inpatient drug treatment program if deemed appropriate by yow officer. • (o) Yoe will comply with any curfew restrictions, confinement approved residence or travel istrictions' as instructed by your officer and approved by the Officer's Supervisor. sos•oFemmail-rmthwhime-e.et-mirierisr 51you shall submit to amnia curfew from 10:00 PM to 6:00 AM . . (if the victim maunder the age of Ilyears) you shall not live within 1000 feet of a school, day care center. park, playgroand. or other place where children regularly congregate.. (C) you shall 'teat actively participate in. and succcssfuily complete isex offender rre rogram with a theapiit perticularly trained to treat sex offender. at probatiowa's or communitycontrolets . no shall Dothan any comet with the vialfaCdirectly or Indirectly. including through a third person, unless approaed by the victim, the thetapist and sentencing court . . . (if the victim was wader the ago of 18 years) you shall not, until you successfully auend end complete the sex offender progrini, have any utanpervirod contact with a child under the age of 18 years, ortled authorized by the sentencing court, without an adult present who is responsible Sr the child's welfare sad which adult has been advised of the crime • • and is approved by the sentencing court • . the victim was under the age of IS years) you shall not woik for pay or as a volunteer to any school, day care center, Irlefers-etheaadmindinalietiady—txrannempleyosuislad-by. a wk. playground, or other place where children regularly congregate. Re.- the enennui . or posses any obscene, pornographic or steamily stimulating Meal or auditory material, including t:lelephone. hn epahonucet view. . electronic media, computer programs or computer rate= that ire relevatto your deviant behavior patter° Yob shall submit two specimens of blOod to the FloridaDepartment of Lai Enfacement to be registered with the DNA ' (1) You Mall Make restitution to the victim as ordered by this court pursuant to P.S. 775.029 for all necessary medical and related prof:earnest service relating midis phYsical, psychiatric and psirs.hoiorical eve of the victim. You shall submit to a iclaantleSS search by your probation officer or community control officer of r5 moo t ) cal.:tun, or vehicle. . . , CO groAr••• 14/ 8.Jetfe 0 . Ddakdtah: 1- 413 k9- -- ca -4 -eiWi- te..) taft- L-Z 1 TfaelAS6O" -- ifieCCA 1 tit- a- rYt.i.A.;An. 14/1 An, b,!,.6- 11 ALS 6k- • tArCeek-• • y 0 Dtkn Qat*" 0 7 . laCref t- grill .4.1 Sejeq Ot ft Weld okji 61 -‘) ACn kaC471.41/ OA An.. nr./A Fe • EFTA00231481 A36 rt 04/26/2010 14:51 3553626 CIRCUIT CRIMINAL PAGE 10/20 you shall submit to a mandatary curfew from 10:00 PM to 6:00 AM <if the victim was under the age of 18 years) you shall not live within 1000 feet of a school. day care center. park. playground, Or other place where children regularly congregate. (u) you shalt enter, actively participate in, and successfully complete a sex offender treatment program with a therapist particularly trained to treat sex Offender, at probationer's or community contrition expense (d) you Shall not have any contact with the victim, directly or indirectly, including through a third person, Unless approved by the victim. the therapist and sentencing court. (e) (if the victim was under the age of 18 years) you shall not. until you successfully attend and complete the scroffehder program, have any unsupervised contact with a child under age of 18 yeari, unless authorized by the sentencing ,.....--‘,.. court, Without an adult present who is responsible for the child's welfare and which adult has been advised of thecrimc • and is wproved by the sentencing court. . . VI 0 (if the Pedro was under the age of 18 years). yoti shall not work for pay or es a volunteer it any school, daycare center. park, playground, or other place where children regularly congregate. p (g) Unless otherwise indicated in the treatment plan provided by the sexual offender treatment program, you shall not view. 1• own, or posses any obscene, pornographic at sexually stimulating visual or auditory material, including telephone, electronic media, comptiter programs or computer services that are relevant to your deviant behavior patient. 1 (hi You shall submit two spite ens of bloodso the fltmida Data Bank. (1) ' You shall make restitution to-the victim as ordered by this court pursuant to F.S. 775.089 for all necessary medical and related professional. modem relating to the physical, psychiatric and psychological'cere of the victim. ‘ ---1' 6 ) You shall submit to a Warrantless search by your probation officer or community control officer of yens person, ------ resideaccor vehicle_ - -------WthrifiAl, as part of a treatment program. participate once/lance annually in polygraph examination to obtain information uncesary for risk management and treatment and to educe your denial mechanisms-. Your polygraph examinations must be conducted by a polygraphs trained specifically in the use of polygraph for monitoring Mx Offendeseattd It shall be paid by you. The results of the polygraph examination shall not be used as evidenced in court to prove that a violation .of coma:amity supervision occurred. . . You stall maintain a driving log, you shall not drive &Motor vehicle while alone without prior approval of your supervising officer. . . . . fug i, (if there was seXual contact) you shall submit to, at probationer's or community contralti's expense, an FEY test with . . the results to be released to the victim,. or the victim's parents or guardian. . • • You will not obtain or use a Post Office Box without the prior approval of the supervising officer. ( Yoti.will submit to electronic monitoring what deemed necessary by the community control or probation officer and his or her supervisor, and ordered by the court at the recommendation of the Department of Corrections. ' . . • bet • 1/2.6 COURT RpsygRVBS THE RIGHT TO RESCIND, MODIFY, OR REWOR.E S ONE AND oRDORED AT West Pak:IIeach, Palm Beach County. Florida, this one Pro Tunic: .1211O05... lYint TO t•IT PROVIDED DY LAN 0 . Honorable Sandra It McSorter Jod,gc; Circuit Court have received a copy of the terms and conditions of toy supervision. I have toad and understand these coedit:Tun n- agree to report to the Deportment of erections probation Office for further instructions. Also. I hereby consent to the disclosure of any alcohol and abase ratient roc •-di. the cooRdennality ( which is isssicopy regulated under 42CPR, Pod If, for the duration of my u Trion (:: 1 DATE UCTED BY EFTA00231482 A37 04/26/2010 14:51 3553626 CIRCUIT CRIMINAL PAGE 11/20 S 948.101 Teen and conditions of community control and criminal quarantine community control — (1) The court shall determine the tams and conditions of community control. Conditions specified In this subsection do not require and pronouncernunt at the tine of sentoncing and may ba considered standard conditions of community control. at) The court shall require intensive supervision and unilateral for an offoridor placed into community control, which may include but Is not limit:rad to: I. Specified contact with the parole and probation officer. I. Cr:incitement to en agreed-upon roddonco during hours away from employment and public sonic* act:leftism 3. Mandatory public service. 4. Supervision by the Departnsast of Conatiuns by means of an electronic monitoring dovIca or system. 5. The standard conditions of probation set forth in s. 944.03. (b) For an eftander plead on criminal cperentine community control, the court shell coquina: 1. eloc-trordc monitoring 24 hours per day. 2. Cordirtement to a designated residence during declaimed hours. (2) The entameation of specific kinds of terms and condition does not prevent the court from adding thereto any other tarn or conditions that the court considers proper. flowervor, the sentencing court may only Immo a condition of supervision allowing an offondor convicted of 5. 794.011 L 800.04 s. 127.071 or s. 847.0145 to reside In another state If the ardor stipulates that it Is contingent upon the approved of the readying Mate Intorstato compact authority. The coat may ,.scrod or modify at any time the term and conditions thasitoforo imposod by It upon the offondur in carrimunity motel. fioWenter. If the court withholds adjudication of guilt or Imposes it period of incur rotation as a condition of community control, the period may not woad 364 days, and Incarceration shell be restricted to a county a probation and restitution cants under the jurisdiction of the Department of Corrections, a Probation Program drug punishment phase I seams residential troebnont institution, or a commtmity reside stial facility owned or opureted by any entity isivvidire such services. 13) The court may place a defendant who is being sweated for criminal transmission of MN in violation of s. 775.0177 on criminal quarantine community rtwitml. The Department of Corrections shaU develop and administer a criminal quarantine community control program emPhadoing intombe supervision with 24-frotr per-day electronic monitoring. Criminal Tarantino caMintrilty control status roust InTcludo cured Lance and may Include oder measures normally ainectotrad with community control, except that specific comfitions necessary to monitor this population may be ordered. EFTA00231483 A38 04/2E/2010 14:51 3553626 • CIRCUIT CRIMINAL PAGE 12/20 '943.0414 Sexual &ganders required to rimester with this department penalty-.. (1) As used in this section, tho tarm: (a)l. 'Sexual %Wonder moans a parson who moots tho criteria In sub-subparagraph a., sub￾subparagraph b., sub-subparagraph c., ar sub-subparagraph d., as follows: a.(1) ties been conslctad of committing, or attempting, soliciting, a conspiring to commit, any of the criminal offenses proscribed In the following statutes In this stet* or similar ottoman in anottmer jurisdiction: s. 787.01, s 787.02, ors 787.025(2)(I, whore the victim Is st minor and the doh: meant fs not the victim's parent or guardian; s. 794.011 *selecting 1. 794.011(10); s. 794.05; s. 796.03• s. 796.035' s. 800.04; s. 825.1025; s. 877.071* t. 847.0133* s. 847:0i 35, oncluding s. 847.0135(4); s. 847.0137- s. 847.01387s. 847.0145- or s. 485.701(0; or any similar offense committed in this slate which has bean redesignated from a forme statute number to ono of those listed in this sob-subssubssieregraph; and ibm bean rotamed on or after October 1, 1997, from the sanction Imposed for any conviction of an offense described In subsub-subparagraph (I). For purposes of sub-stels￾subparagraph (i), le sanction imposed In this stets or in any other jurisdiction includes, but is not limited to, a fine, probation, community control, payola, conditional release, control redeem, or Incarceration in a state prison, foderal prison, private corroctionel facility, or local detention facility; b. establishes: or maintains a renderco in this state and who has rot ban designated as a awed predator by a court of this state but who has bean delis/noted as a sexual predator, as a "mouelly distant predator, or by another seined offend& designation In enothor states or jUirildiction and was, as a mutt of such designation, subjactod to raghtration or community nr public notification, or both, or would be if de person were a resident of that state or jurisdiction, without regard to whathar the parson others/due meets the criteria for registration as a sexual offlinelor; c. estabtishin or maintains a residence in this state who Is In the custody a control of, or under the supervision of, any other stater or jurisdlcdon as a result of a conviction for committing, ar attenptIne, soliciting, ar conspiring to commis, any of the criminal offenses proscribed In the following statutes or similar efforts, In another jurisdiction; s. 787.01, s. 787.M m. s. 787377.5(2)(c), whin the victim fs • minx and the defendant Is nohvctim's ~ant or guanfing s 794.011, excluding s. 794.011(10); s. 794.05 t 796.03; s 796.035. s. 800.04; s. 825.1025- s. 027.071' s. 847.013). s. 847.0135, excluding s. 847.0135(4); t. 847.til37; s. 847.01311; s. 847.0145' ors. 985.70111h or any similar &ferns committed in this stato which has boon nedaiignebed from a forme statute number to one of those flood In this suk-subnatier•Ph; or d. On or after July 1, 2007, het been adjudicated delinqu for committing, a attempting, soliciting, or conspiri commis, any of the criminal offense[ proscribed in the following statutes in this state or tnflar offenses in another jurisdiction whim the juvenile was 14 years of age or older at the time of tun offers.: (I) Section 794.011, excluding s. 794.011( I 01; (11) Section 8(flp411)ib) whore the victim is under 12 years of ago or wiser* the) court finds sexual activity by the use of force or coercion; fill) Section 800.04(5)(c)1. when the court finds molestation involving unclothed gonna EFTA00231484 A39 04/26/2010 14:51 3.55:1626 I CIRCUIT CRIMINAL PAGE 13/20 (IV) Section 800.O4(5)(d) whom the colas finds the too of force or coercion and unclothed genitals 2. Inc all qualifying offonsos listed in sub-subparagraph )(a ltd., the court shall make a written finding of the ago of the ofTsndor et the time of the, °thort s'. fa each violation of a qualifying offoma Listed In this subsection, the court shall make a written finding of the ago of the victim at the lima of tho offense. for a violation of t. 800.04(4), the coirt 31.41 additionally make a writton finding indicating that the offo■ did or did riot imolso son* activity and Indkating that the offense did or did not involve force or coercion. For a violation of s. 300.04(9, tho court shall additionally make a *Titian finding that the offense did or did not Imolae unclothed genitals or genital aro, and that the offense did or did not involve the uses of force or coercion. (b) 'Convicted" moron that than has boon a datormination of silt al a rosult of a trial or the orrery of a plea of guilty or nolo contoortona, niggard's'. of whothar adjudication is withheld, and includn an aditofication of definquoncy of a "uvanila as specified In this 'action. Conviction of a similar off ine' includes, but Is not limited to, a conviction by a federal or military trIbtrud, Including courts-martial conducted by the Aimed Forces of the United Staten, and Includes a conviction or entry of a plea of guilty or nolo contender* resulting in a sanction in any state of the United States or other jurisdiction. A sanction Includes, but is not limited to, a fine, probation, cormunity control, parole, conditional release, control release, or incarceration Ina state prison, federal prison, private correctional facility, or tote detention (c) 'Permanent residence- and "temporary residence have the carne moaning ascribed /7S.21_. (ct) institution of higher( education .mans a trainer coated, cOMMunity collogo, college, state university. 0: indopondere postsecondary institution. (o) 'Chicly in onnsitITIOnt or employment Sinful- moans the commencement or termination of urnaltrant or ornplaymont, ore choir in location of ortroliment of oloplornOnt. (f) -Lloctrnitic mall address" ha the same rnocurirg as provided fn s. 668.602. (g) instant message roamer morn an idardifior that allows a person, communicate to tool time with anothor panon using the Intornot. (2) A sexual offorrior (a) Racal in parson at the sheriffs officer 1. In the county in which the offender ostablIchen ti maintains a permanent or temporary residence within AS hours a. Establishing permanent or tompantry resitionso in this state; or b. tong released from tho custody, control, or lurarrvislon of the Onpartment of Corrections or from the custody of a private torrortional facility; or 2 In the county whore be or the was ronvictod within VI hOlitt after being convicted for a qualifying offense for agistration undue tilts toction if the offender fs not In the rottotly or EFTA00231485 A40 04/26/2010 14:51 3553625 control of, or under the mpordsion of, the persimmons of Corrections, or Is not In the custody of a private correctional facility. Any change In the sexual offender's permanent or temporary reside/err, name, any eiectronic mail address and any instant message name required to be provided pursuant to paragraph (4)(d), after the snood offender reports In person at the sheriffs office, shall ho accomplished in the manner provided In subsections 141, 17 ), and (8). ID) Provide his or he name, data of birth, social security nurnber, race, sax, height, weight, heir and aya color, tattoos or other Identifying marks, occupation and place of employment, address of permanent or legal residence or address of any current temporary residence, within the state and nut of state, irwfuding a oral route. address and a pest office box, any oierctrocric mail address and any instant massage name raguirod to be provided pursuant to paragraph (4)(d), data and place of each conviction, and a brief description of the crime or trifffill committed by the offender. A post office boa shall mt be provided In lieu of a physical residential address 1. If the sexual offender's place of residence is a motor rotrirlo, trailer, mobile home, or (manufactured borne, as defined in chapter 120, the sexual offender shall sire provide to the department through the sheriffs office written notice of the vehicle klantification number; tho linear-a tag number; the registration roanhar: and a description, Including color schen*, of the motor vehicle, trait IAA tooling home, or manufactured home If the sexual offender\ place of ras:lance is a vend, live aboard vest, or houseboat, as refined in chapter 127, the sexual offender shall also provide to the department written notice of the hull identification nuniber; the manufacturer's serial !lumbar; the name of the vessel. -aboard vecteil, or houseboat; the naghtnitIon number; and a description, Including color scheme, of the vessel, 11w-aboard vessel, or hearsaberrt. 7. tf the sexual offender is enrolled, employed, or carrying on a vocation at an institution of higher education in this state, the onus/ offersder shall also provide to the department ftrough the sheriff e ofFre the name, address, and county of each institution, including each campus attended, and the rental offender's onrofiroont or employment states. Each change in enrollment or employment status shell be reported in parson at the sheriffs office, within 48 hours ',tor any chantin stabn. The sheriff shall promptly notify each Institution of the sexual offender's proms. e any change In the sexual offender's enrollment or employment status. When a sexual offender reports at the sheriffs office, the sheriff shall take a photograph and a set of fingerprirrts of the offorder and forward the pictographs and fingerprints to the department, along with the information provided by the sense offender. The sheriff shall promptly provide to the department the Information received from the sexual offender. (3) Within a hours after the report rewind under subsection (2), asexual offender shall report in person at a driver's license office of the Department of IMgtiway Safety and Motor Vehicles, unless a drive's Deere or idemtlfication card that complies with the requirements of s. 322.141(3) was previously secured or updated under s. 944.607. At the driver's license office the sexual offender fa) If ntharwisa qualified, secure a Florida drives license, ranee a Florida driver's license, or agate an Identification card. Thu Anted offender shall identify himself or herself as a sax LIZ: OM/Mier who Is required to comply with this section and shall provide proof that the sexual offewier reported in rrnoirtad in subsection en The rem& offender shalt provide any of tho information specified in stAr,etion (2), If requested. That sexual offender shall submit to tho taking of a photograph for use In haring a drivels (inane, renewed license, or Identification card, and for use by the department In maintaining current records of sexual offenders. PAGE 14/20 . EFTA00231486 A41 04/16!2910 14:51 355362E CIRCUIT CRIMINAL PAGE 15/20 I (b) Pay the costs assessed by the 0opartmare of Highway Safety and Motor Vehicles for issuing or renewing a driver's license or idontificatIon card as required by this section. The drive's license or identification card Issued rant be In compliance with s. 122.141(3). Provide, upon request, any additional information necessary to confirm the Identity of the sexual offender, Including a sot of Rn0trprints. 14)41 Each time a sexual offenders drissoes licenser or ideretificatfon nerd is subject to renewal, and, without regard to the status of the offender's driver% license or Identification card, within 411 hours after any change in the offenders permanent or temporary residence or change fn the offender's name by reason of marriage, or other legal proton, the offers-dor shell report In parson to a drivers license office, and shall be subject, the requirements specified fn subsection (3). The Department of tlighvery Safety and Motor Voidctos shall forward to the department ad photographs and information provided by sexual offerideo. Notwithstanding the restrictions sat forth In s. 322.142,, the Department of Highway Safety and Motor Vehicles is authorized to release a reproduction of a color-photagraph or digital-Image If cone to tic Department of law Enforcement for purposes of public nodfication of sexual offenders as prodded in this section and n. 943.043 and 944.606. Asexual offender who mentos a permanent residence and falls to establish or maintain another permanent or temporary residence shell, within 48 hoses after vacating the permanent reddens.; report In person to the sheriffs office of the malty in which he or she Is located rho sexual *Horde dell specify the date upon which he or the intends to or did vacate such resfidence The se suit offender mud prowid• or update all of the nagistraition Information required trodw paragraph (2)(b). Tho sexual offender must provide an address for the rostdonco or other location that he or she is or will be occupying during the time In which he or she falls to estabesh or maintain a pannorsont or temporary residence. (c) A ,,anal offordor who nenalm et a permanent nrsitiverre after reporting his or her intent to vacate inch residence dial, within 48 horn after the date upon whi offender m indfeated he or she would or did ante such residence, report In person I the agency I which he or she mooned pinata to panzgraph (b) for the purpcno of 'tangling his or her address at such reddonce. Wien the :hair tore/errs the repent, tie dioriff than promptly Cony the it theb department_ An offender who makes a report an required under paragraph (h) het falls make a report as required under this paragraph commits a felony of the second degree, la as prearead In s. 77S.C112, s. 775.003 or s. 775.034. Id) awned offender must rocas:ter any dertrorric mall orfdross or Instant massage name with the deportment prior to using such oloctronic mall addnasa or Instant massage name on or alter October I, 20177. That departmorrt shalt establish an online system through which sexual offenders may securely otos% and update all electronic mall address and instant massage name information. (5) This section does not apply to a sexual offordrw who is also a sexual pmdator, as dofirind in s. 275.21. A sexual predator mint rnsettw m required under s. 775.21. fiS1 County astipcallmar onfercernewit agendas, in conjunetten with the department, shah weeny do se of sexual offenders who we net under the can, custody, control, or iwarefsion of the Department of Corrections In a manner that is consistent with the provision of the faire! Adam Walsh Chfld Protection and Safety Act of 2036 end any nthor Federal standards npplicnel• to such verification or required m bo met as a c on fax the receipt of federal funds by the state. local law enforcement agendas shall report tho department nary failure by a lasted offender to comply with registration roquiromontS. ace EFTA00231487 A42 04/26/2010 14:51 3553626 • CIRCUIT CRIMINAL PAGE 16/20 (7) Asexual offender who intends to ostablIslt oxidant* in soothe state or jurisdiction otter than the State of Florida shall roport in person to die sheriff of the county of current residence within 48 hours before the data ho or she intends to leave this state to establish residence in another state or jurisdiction. The notification most include the addron, municipality, county, and state of intended residents. The sheriff shall promptly provide to the dopertrnont the Information rocdvod from the sexual offender- The doparunont shell notify the statewide Ore onforcernent agency, or a comparable agency, in the intended state or Jurisdiction of residorice of the soxtred offender's intended reside ace. The failure of a sexual offender to provide his or her Intl:portal place of rasidenco is punishable as provided In subsection (9). (S) A tutsl offender who Indicates his or bar intent to reside in another state or jurisdiction other than the State of Florida and later decides to remain in this state shall, within 48 hours after the date upon which the sexual offender indicated ho or sho would loan/ this state, report in person to the sheriff to which the sexual offender reported the 'Melded change of resistant°, and his or her Intent to remain in this state. The sheriff shall promptly report this informatIonro deportment_ A toxinl attendee who reports his or her intont to nrcicki in another stow or Jurisdiction but who remains in this state without reporting to the sheriff In the manna- roquirod by this subsactIon ratrnits n felony of the socond degree, punistvildo as provided ins. 775.no, s, 775_081, me s. 775)184. 19ga) A sons! offender who dues not romp!), with the requirement, of this sartion commits a fobany of this third rfogroe, punishahte as provided ins 775.082, s 775.083 or s. 775.084, (b) A sexual offondor who commits any act or remission fn violation of this suction may bo prosecuted for tin act or omission In the county In which the act or omission was committod, the county of the last noginored address of the sexual offender, or the county in wirch the conviction oscierrod for tier offsets. or &fawn that moot the criteria for designating a parson as a sexual offender. IC) An arrest on charges of failure to register when the offender has boon provided and advitod of his or her statutory elongations to register under subset-Hon (7), the service of an information or a complaint for a violation of this section, or an arraignment on charges for n dolletion of this section constituters actual notice of the duty to rogistor. A sexual offorideis failura to immediately register as required by this section following such arrest, service, or arningnment constitutes grounds for a Subsequent charge of failure to register. A sexual offender charred with the crime of failure us regent who assorts, or Intends to meat, a lack of notice of the duty to register as a deforno to a charge of failure to register deli immediately registrar as required by this section. A sexual offender who fs charged with a subsequent falba° to reefstor may not assert the defense of e lac* of notice of the duty to register. Id) Roitistratfoin following such arrest, service, or arraignment Is not a defense and does not 'elite the soineil offender of criminal liability for the failure to register. (10) The department, the Oopartmerrt of Highway Safety and Motor Vehicles, the Department of Corrections, the DePartmord of Juvonilo Justice, any law arrforcornore agency fn this stale, and this parsonriol of those dopartmontr an alerted or appointed official, public employe*, or ichoof ridministrator: or an ofriployoe, agency, or any individual or entity acting at the request or upon the direction of any lair enforcornont agency is immure from civil liability for damages for good faith rem/Mance with the requfrornents of this :action or for the 'Satre of information under et section, and shall be presumed to have retort in good faith in compiling, recording, rapornng, or releasing the information. Tin prersurnption of good faith is not overcome If a technical or clerical curer Is rondo by the department, the Department of Ifilililway Safety and 4,trw eohichrs, the Dopartroont of Corrections, the Dopartrnent of Juverio EFTA00231488 A43 04/26/2010 14:51 3553626 CIRCUIT CRIMINAL PAGE 17/20 Justice, the pantheist of those departments, or any Individual or entity acting at the request or upon the direction of any of those departments in compiling or providing information, or it information Is Incomplete or incorrect because a sexual offender has to report o falsely reports his or Ina current place of permanent or temporary residence. (II) Except as presided in s. 943.043S4, a sexual offender must maintain registration with the department for the duration of Ms or her life, uMess the sexual offender has received a full pardon or has had a conviction set aside in a prnacerwiction proceeding for airy efforts that meets tile criteria for dorsi fry the person as a sexual offender for purposes of registration. Howes, a sexual offsmdari (all. Who hes been lawfully released from confinement, supervision, or sanction, whichever is later, for at toast a peen and his not boat arrested for any felony or misdemeanor offense since release, provided that the fasted offenders requirement to register was net based upon an adult conviction: a. fora violation of s. 767.01 or s. 717.02; b. For a violation of s. 794.011 Including s. 791.011(1th; t. Fora violation of S. 500.O1(01fb) where the court finds the offense Involsod a victim under 12 roars of age or metal activity by the use of force or coercion; d. For a violation of I. 603.01(5)(b); o. For a violation of s. 500.O4(5)c7. whore the court finds the offense Involved unclothed genitals or genital area; f. For any attempt a conspiracy to commit any such offense; or g. For a violation of limiter law of another Jurisdiction, may petition the criminal rlMsfon of On circuit cant of the circuit In which the unmet offender rankles for the purpose of removing the requirement for registration as ai/XS offender. Z. The court m■y grant or deny relief If the offender demonstrators to the court that ho or she has not been arrested for any crime since release; the requested relief compiles with the thevitioni of the Wand Moat Walsh Child Protection and Safety Act of 2006 and any other Wend standards applicable to the removal of registration requirements for a sexual offender or required to be met as a condition for the receipt ef federal funds by the state; and the court it otherwise whited that the offender is not a current or potential threat to public safety rho state attorney in the circuit In which the petition is filed must be given notice of the petition at hied 3 weeks before the hearing on the matter. The state attorney may present oWdonca in opposition to the requested relief or may otherwise demonstrate the reasons why the petition should be denied. If the court denies the petition, the court may seta futuro date at which the vacua offender may again petition the court for relief. subject to the standards for relief provided in this subsection. 1 The department shall remove an offender from clarification as a sexual offender for purposes of registration If the offender provides to the department a cortiflod copy of the touts written findings or order that indicates that the offender is no longer required to comply with the requirements for registration es a sainted offender. EFTA00231489 A44 04/26/2018 14:51 3553626 CIRCUIT CRIMINAL PAGE 18/22 (b) A. defined in sub subparagraph (1)(a)t.b. must maintain registration with the department for the duration af his or her life until the meson provides thee daporuourt with an order issued by the court that dotignertad the person es a sexual predator, as et soruatly violent piedatot, or by another waned offoricior dadirsation In the state or jurisdiction in which the order( wet issued which staters that such doslorestion has boon removed or domonstrates to the clepartmont that such dedonation, if not imposed by a court, has boon removed by operation of law or court ordve in the state or jurisdiction in which the designation was matlo, and provided such perton no loofa, masts the criteria he registration as a sextal offuntior undo, the laws of this stabs. (121 The Legislature fin* that sexual offondars, especially those who have committod offenses against minors, ofton poso a high risk of ongeging in Sekel offomos own after being rotated from incarceration or commitment and that protection of the public from Untied offandors is in futtornourd ~rind interest. Sexual offenders have • reduced exportation of privacy became of the public's Internist In public safot-y and In the offoctivo oporotion of goverrenont. itotatising information ooncorrfrwj sexual offordors to law rerforcomont agoncios and to porsnns who melon* such Information, ard the release of such Information to oho public by a tow onforcomard regency or public agency, will further the ganartmontal interests of public %minty. rho designation of a person as a sexual offender Is note sentence nr e punIshmont but is amply the status of the °fielder which is nos rasarit of a conviction for having tommittod contain trimos. (13) Any parson who has rental to bolinvo that a sexual offender is not complying, rw has lot cortlottod, with the roquirernents of this section and who, with the Intent to assist the :astral offerflor in eliding a law onforcornant neonry that is sou:king to find the sexual offender to quentlen the sowed offerdl oboe*, or to arrest the sexual offender for, his or bar noncompliance with the rallartirrbaIna of this suction: In) Withirstris information from, or does not notify, the law ent n anent agency shoot the sent& offender's noncompliance with the requiromonts of this section, and, if known, thy ~suborns of the sexual offends; (b) Harbor; or attempts to harbor, or assists another parson its harboring or attempting to harbor, the sexual off:ender; or IC) Concoals or attempts to concad, or assists another person In conr.oaling or attempting to rancor:I, the sauna/ offends; or (ef) Provides information to the law anforcornwit twenty regarding the sexual offender that the parson knows to be tilso Information, commlb a felony of the third ~roe, pun:Feb(0 as provided In s 775.få2. S. 775.01q, 77S.Ø. (141(e) X sexual offender must report in person each year during the month of the sexual offervireis birthday and during the sixth month following the sexual often-for': birth month ro the shat!(, offIci In the county In which ho or she resides or Is otherwise located to near star • Ihl 114)~4W, el sexual offender who Is unwired to register as a result of a conviction for: 1. Suction 717.01 on. 217.02 whom the victim Is a minor and the offondor is not the victim s parent or gtsardtatl; EFTA00231490 A45 04/26/2010 14:51 3553626 2. Section 79.4.011_, cutcludIrq t. 794.011(101i CIRCUIT CRIMTNAL RAGE 19/20 3. Secticriii00.04(4)(b) vetoro the court fint the orlon» ineolted a victfm under 12 »am of ager or =tutl activity by the uno of force or ~ion; 4. Sortien 800.O4(51(b); 5. Sort-ion 200,0415)6r11. rettere the court finds molostation 1nwlvfnp unclothod genitalt m genital ara; 6. Soct3on 800.O4(Sk.2. whoro ~court finds molintstfon imolving unclothod genitalt or ~tat eire; 7. SØL-Urin 1100,0/(51(d) ildne' the court finfis the uro of forco or coorcion and unclothed ~tols ce ga nital erma; 8. Any istternpt or compirecy to cernmft such oRonto; or 9. A videt:lon of • Tit lier lave of amt,» Jurildlction, must reraghter sefir year during the month of the »etsel oftare:bfr% birthday and ovary (hird month thereafts. (c) The sheriff, °Rica mey detormin• the appropnate times and days fer roporting hy the »mal °Reder, eitt 'hall bo tomtstam with tho roporting requinansents of this subsoctf on. Sarogistration Matt include any degos to tho folioar:ni information: 1. Nome; social socuritynumber; ago; race; an; dato of birth; helg»; weight; hair and sto talort addrems of any permanent roddonts and tecichedt of eny curront tomporary rositioncri, within the state or out of state, IncludIng • rural tout* addrou and a post office bot; arry olectronic mad address and any fr/stant messet* nome niquIrod to ba provided ptesuent to peragraph (4)(d1; date and piece of am ompleyrnent; ~ici. make, modal, «4«, and Iktane tall humle»; fingormintig and photograph. A port office box tall not bm providad in tf ou of a phydcal roddarstlat addraa. 2. M tf» strata t offertaler is onrolluid, eamployed, ar canyIng anser atten at an Inst:nation of bitar ocluctition In tidt *sto, the sexual Difonder shell als* provide to the departrriant the name, addnaa, and county of °sch inst:hutla% Including lunch campus attandod, and the eintal ofIendor's nollmont or amplayrnont statut. 3. ti the ~tal ollonder's piece of rusidancer isa motor veit», trailer, mobil. home, or manufacturod horr», as delire» in chaptsr 320, the sexual offside sirat' else provide the »ihfclo fdontifkation nurnber; tho licens. tag numbar; tho nagling/don nurober; and a det-ript/on, Including cola schame, of the motor volt», trener, mobil* homo, ror manufactur4» hon». If the »smal offendor's plata of resident* It • nø«, linaboard vond, or househoitt, ert &dim» in chapter 327, tho losna, offerder gein abo provida tir hutt (drntifiratfori number; Ula inanufacturoit turist nu=lim; the name of the anal, live-aboai d »stel, or housaboat; the registration nurober; and e dowriptIon, Irctuding cola schema, of tho sn», tiviwaboard sl or tau soboat 4. My samd offonder who falls ta ropert in parton as tamil-od et the sheriffs office, or who feilt to 'mani to any addron wirificatIon corrosnondento from ti» department within ~okt of the date of ti» corrersponcienco or who født to rotta« oloctranic mail addrasws or EFTA00231491 A46 04/26/2018 14:51 3553626 CIRCUIT CRIMINAL PAGE 20/2e 11 IØ ~Ps names, commits a felony of the third darer, punishable es provided In s. 775.082 t. 775.081, at t. 775.084. (d) Thu sheriffs office shall, within 2 ~Aloe days, sibictrenladly submit and update all inforinatfon provided by the segued offender to the department in a manna proscribed by the ~ant. EFTA00231492 A47 Palm Beach Sheriffs Office Booking Card for Jeffrey Epstein, dated June 30, 2008 04/26/2010 14:51 3553626 NAME: EPSTEIN, JEFFREY ALMS NAMES: OVER 8 NANCE EPSTE7. JEFFREY - EPSTEIN. JEFFREY EDWARD￾MORday. Aim 30. 2008 I I:33:10 AM iNCARcEFLATiON DATE/TIME 06/30/2008 11:12 PRISONER /WE: LOCAL CHARGES 000 01/204953 AGE: 55 8514 ADORES& 358a BRIU.0 WY JACKET P CIRCUIT CRIMINAL 0338617* tiP 2008039316 PALM BEACH SHERIFFS OFFICE BOOKING CARO Ws: WAS HEIGMT: 6 II 0 In WEIGNT: 200 OTT: PALM BEACH elcosoc: MOBILE BOOKING 'MID,: 8540 NAM COLOR: PRY EYE COLOR: °to STATE FL RP 33480 CITIZEN COUNTRY: us* PAGE 04/20 20080030001 SID 06587245 AUEN► FBOr 7870751(6 POUCH 3050 M/S: 2006038144 U.S. MARSOL It COTS It ARREST ADDRESS:205 N DIXIE HWY (MAIN CT HOUSE) am WPB ARREST DATE: 06/30/2008 am DATE: 06/30/2008 viARRANT7CASEA: ARREST OFFICER, DM DEPLATO TRANS. OFFICER: 01S MCINTOSH ARREST 14815 14(c. Win. 11:12 COURT CfYISION: ARREST AGENCY: 01-PESO TRANS. AGENCY: 01 PeSO CASE TYPE RECOMMIT-FELONY NOTE STATUTE; CT: DESCRIPTION. CASERAG: MO 13000 9999.0004 (141) 1 -RECOMMT :121:440 I -50.00 II 0 PROCURE PERSON UNDER AGE CO IS FOR PAOSTIRITIONNCASE 2OO8CFOO9381~.~ NCIC: DOC I: WEENY 0: STATE: FL nP, CURRENT BOND 10.00 HOLDS: 14010 DATEMME MOLD ST: 1 3 ALE. DESCRIPTION; 31 3 OVER-TOW/ KEEP SEPARATE PROM NONE Mil' 5 iiktifiT NssmiNteo HOUSING: ICIC 'wince - ALMS REL.: TEO. CLEAR REL: ELEASE a.remme CURT OATENIME: CLERK -3 HOLD OPT: HOW RE7ACIATE/11ME • <—> • O CORtöt40: . • : • -5• 1 1,4 NO REN. SY: MOLD REM.`EEPT: - sterrtaniumut DNA NOT ON —•-- FILE/FELONY CONVICTION NTA 0AlfiRME: reac RELEASE: P1CTO 10: RELEASE MOVE: • • ••• RELEASE trocomanan COURT LOCATION: WARRANTS • 4. . • • • • tv CJ . " 7---- FA. ENTERED CLASSMCATION STATE AM' CENTRAL RCDS CLASS i" NTA LOCI • •. • • F.P. CLEAR: MED.CLEINI IN: Ix, JUL: .1 NOB EFTA00231493 A48 Order granting Jeffrey E. Epstein's Motion for Travel, dated December 18, 2009 tf IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA - CRIMINAL DIVISION CASE NO: STATE OF FLORIDA V5. TeCafte) Deiendant. ?-04 qv cs1Mc tti .02 O? nts „ DER ON MOTION 0 FILED chtuit Criminal Department Ott: 1 8 2009 SHARON R. BOCK Clerk & Comptroller Palm Beach County THIS MATTER comes before the COurl upon AV on - The Court, having been made aware that both counsel haVe agreed to said motion.. Accordingly, It is hereby: ORDERED and ADJUDGED that Ct nitsAton 1.) Jh-r - l) ./ \PC/ DONE and ORDERED in Chambers, esl Palm Beach, Palm Beach County, Florida, this day of rcuit Court JixIge AAA SI EFTA00231494 2601 Blair Stone Road Tallahassee. FL 32399-2500 Date 7/21/201Q MthalaS 358 El Byillio Way palm Beach. FL 33480 A', Siegel OpportemRp Ertiployer A49 Letter from Florida Department of Corrections Regarding Termination of Supervision, dated July 21, 2010 DEPARTMENTo FLORIDA CORRECTIONS f pesA2tte fiFeei:gta. rif, Etld relfb5Ft CitibiltiAL. Governor CRARLIE CRIST Secretary JAMES R McDONOUGIL httpirrwvnyricstaterrus RE: TERMINATION OF SUPERVISION Das W35755 DOCKET/UC NO(S)122441anatna Dear mr, Eostrag Yotare hereby notified that, you hive completed your term(s) of supervision, as referenced above, and are no longer under the supervision of the Department of Corrections. If you were adjudicated guilty of a felony offense, your name will be submitted to the Florida Parole Commission for consideration for restoration of the civil rights that you lost as * result of your felony conviction (right to vote, right to hold public office, and the right to serve on a jury). If your rights are restored, a certificate of restoration of civil rights will be mailed by the Office of Executive Clemency to your last malting address of record usually within one year following the termination of supervision. If your rights are not restored through this initial referral, you will be notified by the Florida Parole Commission and furnished an additional application for submission for restoration of civil rights with a hearing. If you have any questions about your civil rights, you may contact the Office of Executive Clemency for further information by calling (850) 488-2952 or by writing to that office at Florida Parole Commission, 2601 Blair Stone Road, Building C, Tallahassee, Florida 32399-2450. Information and application forms may be accessed through the following web site: wwwatitty.firigfordexclem.html. After eight (8) years from termination of your supervision, you may apply to regain your right to own firearms. Applications can be obtained from the Office of Executive Clemency or be accessed by the web site noted above. If adjudication was withheld, you did not lose your civil rights, however, the Florida Department of Law Enforcement (FDLE) may refuse the right for you to purchase a firearm following successful completion of supervision, pursuant to Section 790.065 Florida Statutes. Contact your local FDLE office if you have questions regarding this law. I would IiIn t en to youl Sincerely, V lit Candice Elkins wishes for a very successful future. th--) El If you were on supervision for a sexual offense, attached Is a copy of the Notice of Responsibilities, which outlines your continued responsibilities in accordance with Florida Statutes. 0 If you were sentenced as a eaten offender, attached is a copy of the Career Offender Notice of Responsibilities, which outlines your continued responsibilities in accordance with Florida Statutes. Original: Offender Copy. Offender File Florida Parole Commission (if applicable) Clerk of Court (if required) (Revised 03/03) EFTA00231495 A50 Letter from Palm Beach Sheriff's Office Regarding Jeffrey Epstein's Participation in the Work Release Program, dated August 12. 2010 esSitE—.RWP 1 .1"%r S OEOe r RiC L. BRADSHAW. SIIERIIT FAX: August 12th 2010 To Whom It May Concern: DEPUTY 3656 ALTERNATIVE ST D UNIT PHONE: Jeffery Epstein DOB 01/20/53 was a participant of the Palm Beach County Sheriff's Office work release program. Epstein was a participant of the work release program starting 10/10/08 and ending 07/22/09. If you have any questions or concerns please contact me. Deputy 3228 Gum Club Road • West Patin Beach, Florida 33406-3001 • • http://vesettpbso.org - - WM014 donne* EFTA00231496 A51 Letter from Jack A. Goldberger to NYS Sex Offender Registry Regarding Florida Registration Level applicable to Jeffrey E. Epstein, dated August 12, 2010 A51-A52 ACTERBURY GO i DBERGER WE SS, R AT TERBURY ' I JACK A. GOLDBERGER ' JASON S.WEISS ' Board Certified Crimwai TrialAttorney I Member cd New Jersey a Florida Bars August 12, 2010 New York State Division of Criminal Justice Services Sex Offender Registry 4 Tower Place Albany, N.Y. 12203 RE: Jeffrey E. Epstein To Whom It May Concern: The undersigned represented Jeffrey E. Epstein in the investigation that lead to his entry of a guilty plea on June 30, 2008 to a felony charge in the State of Florida that required sex offender registration. The purpose of this letter is to clarify the level of registration that was applicable to Mr. Epstein's case Under Florida's registration scheme there are two levels of registration available based on a risk assessment. Florida characterizes these two levels as sexual predator and sexual offender. The sexual predator designation is obviously the more serious classification. Mr. Epstein, based on the offense on which his guilty plea was entered, was classified as a sexual offender, Florida's lowest level of sexual registration. In fact, within the sexual offender designation there are two sub-levels of reporting requirements. One classification requires reporting to the local Sheriffs Office twice a year and one requires reporting four times a year. In Mr. Epstein's case he is required to report at the lowest level, two times per year. Accordingly, under the Florida registration scheme, Mr. Epstein's registration requirements are at the lowest level for a person for whom registration is required. During the incarcerative portion of Mr. Epstein's sentence, he was allowed to participate in the Sheriffs Office work release program, an option thatwould not have been available to him had he been at a higher registration level. Additionally, while Mr. Epstein was in probationary status, he was allowed to travel on a limited basis for business purposes. This would not have been available to him had he been classified as a sexual predator. One Clearlake Centre. Suite 1400 250 Australian Avenue South West Palm Beach. H. 33401 P www.agwpa.com EFTA00231497 A52 hope this information assists your department in determining the registration requirements for Mr. Epstein. Should you desire to speak to me or need any further information, please feel free to contact me. V JAG/slm s, Jack A. Goldberger EFTA00231498 A53 Letter from Martin G. Weinberg to NYS Board of Examiners of Se: Offenders Regarding Risk Level and Designation Determination for Jeffrey Epstein, dated August 16, 2010 [pp. A53-A57] MARTIN G. WEINBERG, P.C. ATTORNEY AT LAW 20 PARK PLAZA. SUITE 1000 EMAIL ADDRESSES: BOSTON, MASSACHUSETTS 02116 FAX NIGHT EMERGENCY. August 16, 2010 New York State Board of Examiners of Sex Offenders 4 Tower Place Albany, New York 12203-3764 Re: Jeffrey Epstein NYSID N OS1909 Dear Sir or Madam: MIS This letter and the accompanying materials are submitted to the Board pursuant to its notice of August 2, 2010, concerning the risk level and designation determination to be made with respect to Jeffrey Epstein. Their purpose is to demonstrate to the Board that, based upon Mr. Epstein's history and personal characteristics, the circumstances of the offense which triggered the registration requirement, his acceptance of responsibility, his successful completion of his sentence and subsequent supervision, and the extraordinary unlikelihood of his ever again reoffending, the appropriate risk level designation is level 1. Overview Mr. Epstein, who is presently 58 years old, is a successful and respected financial advisor who also founded and heads a philanthropic organization, the C.O.U.Q. Foundation, Inc. which funds medical, educational, and advanced scientific research. The offense which led to the requirement that he register as a sex offender in Florida, which in turn triggered this state's reporting requirement, ended almost five years ago and involved an exchange of money and consensual conduct with a young woman who, for all but a few months of the prostitution offense charged, was over the age of 17. Notably, as addressed in greater detail, infra, the conduct which occurred after A.D. reached the age of 17 would not even have been a misdemeanor under the cognate New York statute at the time the offense was committed. Mr. Epstein pled guilty to that offense in the Circuit Court for Palm Beach County, Florida, and has fully and sincerely accepted responsibility for his conduct. There have been no subsequent incidents of criminal misconduct of any description. EFTA00231499 A54 Florida has classified Mr. Epstein as its lowest level sex offender, with the lowest level of reporting requirement, as verified by the attorney who represented Mr. Epstein in the Florida proceedings: Under Florida's registration scheme there are two levels of registration available based on a risk assessment. Florida characterizes these two levels as sexual predator and sexual offender. The sexual predator designation is obviously the more serious classification. Mr. Epstein, based on the offense on which his guilty plea was entered was classified as a sexual offender, Florida's lowest level of sexual registration. In fact, within the sexual offender designation there are two-sub-levels of reporting requirements. One classification requires reporting to the local Sheriff's Office twice a year and one requires reporting four times a year. In Mr. Epstein's case, he is required to report at the lowest level, two times per year. Accordingly, under the Florida registration scheme, Mr. Epstein's registration requirements are at the lowest level for a person for whom registration is required. Letter of Jack A. Goldberger, Esq., Ex. A. That Florida authorities did not — and do not — believe that Mr. Epstein presented a risk of reoffense is evidenced not just by Mr. Epstein's lowest-level reporting designation but also by the fact that he was permitted, while serving his sentence in the West Palm Beach County Jail, to leave the jail on a daily basis on work release for most of the period of his 13-month incarceration and that during his subsequent year of community control supervision (a probationary-typesentence), both the court and his probation officer agreed to permit him to travel outside Florida for business purposes on a significant number of occasions. He has now completed his year of community control supervision, having fully complied with all the requirements and obligations imposed on him. In addition, Mr. Epstein has participated in therapy with a clinical psychologist, Stephen R. Alexander, Psy. D., who, based on his evaluation of, and therapy sessions with, Mr. Epstein and his long experience as a forensic psychologist, attests that Mr. Epstein presents no threat to the community and that the risk of his reoffending is "negligible": Since my initial assessment of Mr. Epstein he has been extremely cooperative with all of the services provided to him. He has spent a great deal of time and energy focusing on his behavior and the attitudes, beliefs and expectations that undergird his approach to life. He has examined his priorities and undergone a comprehensive self-exploration on more than one occasion, primarily because of the vast changes that have occurred in his life and the upheaval these events have caused. Throughout it all Mr. Epstein has remained willing to focus on himself and how to turn even the most dire personal circumstances into productive experiences to the fullest extent possible. In my opinion Mr. Epstein has been highly cooperative with and benefited from the treatment provided. Relying upon my 25 years of experience as a forensic psychologist and the plethora of data gathered by me, 1 state with confidence that Mr. Epstein poses no threat to himself or the community. It is abundantly clear that he has learned his lesson and the probability of his reoffending is negligible. Mr. 2 EFTA00231500 A55 Epstein poses no threat to either himself or the general community, and he requires no additional intervention or treatment for his no-risk/low-risk status to be maintained into the future. Letter of Stephen R. Alexander, Psy. D., submitted herewith as Ex. B. All of these circumstances — Mr. Epstein's low-risk classification in Florida, the state where the offense was committed, the low-risk assessment inherent in the decisions of Florida authorities responsible for the protection of the community, who knew him first-hand, to admit him to work release during his period of incarceration and to permit him to travel outside of Florida during his period of community control supervision, Dr. Alexander's well-supported judgment that Mr. Epstein presents little or no risk of reoffense, the fact that the offense ended almost five years ago, and there has been no subsequent criminal misconduct of any kind, and the fact that Mr. Epstein is a mature, responsible, professional adult who uses neither alcohol nor drugs all support the conclusion that the supervision which accompanies a level I designation will more than suffice to serve the purposes of SORA. That conclusion is supported by the calculation of Mr. Epstein's risk assessment guidelines score. The Conduct Underlying the Offense Trigeerine the Florida Registration Requirement Would For the Most Part Not Even Have Been a Registerable Offense in New York. Had the Conduct Occurred in New York The offense which required Mr. Epstein to register as a sex offender in the state of Florida was a violation of Fla. Stat. §796.03, which criminalizes procuring a person under the age of 18 (the age of consent in Florida) for prostitution, specifically, here, one "A.D." The nearest New York cognate among the registerable offenses listed in N.Y. Correction Law §168-a is N.Y. Penal Law §230.04 (patronizing a prostitute). The information to which Mr. Epstein pled guilty charged that the offense occurred between August 1, 2004, and October 9, 2005, see Information, Ex. C, that latter date being the day before A.D.'s 18th birthday: Thus, for almost all of the duration of the charged offense, A.D. was over the age of 17, and the wholly consensual conduct in exchange for money which occurred between the two would not even have been a registerable offense in New York. See §168-a(2XaX0(§230 .04 a registerable offense only if "person patronized" is in fact under 17 years old). Indeed, at the time of the offense at issue, the conduct which occurred after A.D. turned 17 years of age would not even have been a crime under that statute if the conduct had taken place in New York.2 Mr. Epstein's offense ranks among the least serious of those which trigger the requirement of SORA registration. The single Florida offense which required registration involved ' Dr. Alexander's CV is included in Ex. B. VMS 8171 e o ex e i coverage to prostitution offenses involving individuals of any age, not just those under the age of 17, as the statute was written when Mr. Epstein's offense was committed in 2004-05. Under §230.04 as written in 2004-05, the offense, to the extent that A.D. was in the last three months of her 16th year, would only have been a misdemeanor had it been committed in New York. 3 EFTA00231501 A56 only one woman, and there was no force or violence involved at any time, nor did A.D. suffer from any mental disability, mental incapacity, or physical helplessness. The points attributable to the Current Offense factors (factors 1-7) total less than 70. Criminal History Prior to the offense at issue, Mr. Epstein had no prior criminal history whatsoever. Mr. Epstein's date of birth is January 20, 1953, and he was, accordingly, more than twenty years of age when the offense at issue was committed. Mr. Epstein does not use alcohol or illegal drugs and has no history of either drug or alcohol abuse. Accordingly, Mr. Epstein should be scored at zero for the Criminal History factors (factors 8-11). Post-Offense Behavior On June 30, 2008, Mr. Epstein pled guilty to the offense which subjected him to the requirement that he register as a sex offender in Florida and has fully accepted responsibility for his conduct. Mr. Epstein served approximately 13 months in a West Palm Beach County jail (rather than in a state correctional facility). During most of his period of confinement, from October 10, 2008, through July 22, 2009, the date of his release, Mr. Epstein participated in the jail's work release program, see Letter of Deputy MI, Ex. D, which permitted him to leave the jail in the morning six days a week for his place of employment, the Florida Science Foundation, and return in the evening. That Mr. Epstein satisfactorily complied with the requirements of the program is evidenced by the fact that he remained in the work release program up to the time of his release from custody. After his release on July 22, 2009, Mr. Epstein was subject to a one-year period of community control, which required, among other conditions, that he maintain contact with the probation office as required, that he be confined to his residence during the hours when he was not working or performing public service, that he not leave his county of residence without the consent of bis probation officer, that he commit no further violations of the law, and that he maintain employment. During Mr. Epstein's period of community control from July 22, 2009, through July 21, 2010, he was permitted by the court, with the assent of his probation officer and without opposition by the state's attorney, to travel (including overnight stays) to New York and to the Virgin Islands for business purposes on a number of occasions, thus demonstrating a substantial level of trust by both the court and his supervising probation officer in Mr. Epstein's ability to refrain from unlawful conduct of any kind and to conform his conduct to the terms of his community control order and to the orders authorizing his travel, which he did on every such occasion.' Mr. Epstein successfully completed his term of community control on July, 21, 2010, see Florida Department of Corrections Termination of Supervision notice, Ex. F, having at all times fully complied with all obligations and restrictions imposed upon him. Mr. Epstein has never refused or been expelled from any treatment since the time of his sentencing (factor 12(2)); See pages 2-3, supra. Based on his professional expertise and the 3 One such travel order is attached as Ex. E. 4 EFTA00231502 A57 substantial time he has spent with Mr. Epstein, Dr. Alexander is able to state unequivocally that Mr. Epstein has learned his lesson, that he presents no threat to the community, and that there is negligible risk that he will ever reoffend. Accordingly, Mr. Epstein should be scored at zero for the Post-Offense Behavior factors (factors 12-13). Release Environment Factor 14 contemplates that the risk level assessment will be made, as required under New York law, prior to the offender's release from incarceration. Here, as the preceding section shows, Mr. Epstein was released from jail more than a year ago and was subject to close supervision for a period of one year afterwards. During the same time, he continued to meet with Dr. Alexander. The score for factor 14.should, accordingly, be zero. Mr. Epstein maintains a vacation residence in Manhattan, which he owns, as well as residences in Florida and the Virgin Islands. Mr. Epstein's interactions in connection with both his employment and philanthropic work are with adult business professionals, scientists, and educators. There is nothing in either Mr. Epstein's living or employment situations which could even remotely be considered "inappropriate." The score on factor 15 too should be zero. Overrides None of the listed factors are of any relevance or applicability to Mr. Epstein's risk level designation. Conclusion Based on all the relevant factors, Mr. Epstein should be classified as a level 1 sex offender. Even should the Board somehow conclude that Mr. Epstein's risk assessment guidelines score exceeds 70, the circumstances addressed in this letter differentiate this case, markedly from the norm of level 2 sex offenders that the Board should recommend a level I classification, as it is empowered to do under the Sex Offender Guidelines. The ultimate issue is the risk that the offender will reoffend, and the information provided to the Board with this letter persuasively demonstrates that such a risk is virtually nonexistent in this case. itt ruly yourk einberg tr 5 EFTA00231503 A58 Letter from Stephen R. Alexander, Psy.D. to Jack Goldberger Regarding Opinion of Jeffrey E. Epstein, dated August 16, 2010 1pp. A58-A611 Stephen R. Alexander, Psy.D. Clinical Psychologist 1825 Forest Hill Boulevard, Suite 204 West Palm Beach, Florida 33406 561 -433-2355 August 16, 2010 Jack Goldberger, Esq. Atterbury, Goldberger and Weiss, P.A. 250 South Australian Avenue, Suite 1400 West Palm Beach, Florida 33401 Re.: Jeffrey Epstein Dear Mr. Goldberger: Since my initial assessment of Mr. Epstein he has been extremely cooperative with all of the services provided to him. He has spent a great deal of time and energy focusing on his behavior and the attitudes, beliefs and expectations that undergird his approach to life. He has examined his priorities and undergone a comprehensive self-exploration on more than one occasion, primarily because of the vast changes that have occurred in his life and the upheaval these events have caused. Throughout it all Mr. Epstein has remained willing to focus on himself and how to turn even the most dire personal circumstances into productive experiences to the fullest extent possible. In my opinion Mr. Epstein has been highly cooperative with and benefited from the treatment provided. Relying upon my 25 years of experience as a forensic psychologist and the plethora of data gathered by me, I state with confidence that Mr. Epstein poses no threat to himself or the community. his abundantly clear that he has learned his lesson and the probability of his reoffending is negligible. Mr. Epstein poses no threat to either himself or the general community, and he requires no additional intervention or treatment for his no-risk/low-risk status to be maintained into the future. If any questions remain or I can be of additional assistance, please contact my office. Sincerely, Stephen R. Alexander, Psy.D. Clinical Psychologist SRA/b1 Epst 66.060174 lA EFTA00231504 A59 Stephen It Alexander, Psy.D. Clinical Psychologist 1825 Forest Hill Boulevard, Suite 204 West Palm B ludda 33406 F EDUCATION Psy.D. Florida Institute of Technology; Clinical Psychology, 1985 M.S. Eastern Kentucky University; Clinical Psychology, 1980 B.A. University of North Carolina at Chapel Hill; 1977 LICENSURE Florida Board of Psychological Examiners: Psychologist, PY0003713 CERTIFICATIONS Supreme Court of Florida: Family Court Mediator 19355 CF Supreme Court of Florida: County Court Mediator 19355 CF PROFESSIONAL EXPERIENCE Clinical Psychologist: Private practice providing services to children, adolescents, adults and families. Specialization in psychodiagnostic evaluations (personality, forensic, psychoeducational), forensic psychology, and psychotherapy. July 1989 to present. Chief Psychologist: Juvenile and Family Divisions of the Fifteenth Judicial Circuit and Division of Youth Affairs, Palm Beach County, Florida. September 1987 to July 1989. Duties: Supervise Psychological Services provided to Juvenile and Family Court including psychological evaluations of children, adolescents and adults in delinquency, dependency, custody, and sex abuse cases; testimony as Expert Witness. Program Supervision of Sable Palm Youth Service Center, a 48 bed residential treatment program for emotionally and behaviorally disturbed adolescents; family therapy approach to treatment. Program Supervision of the Youth ServiceSureau, a community based family counseling/delinquency prevention program. Directing program evaluation and basic research within the Division of Youth Affairs. Directing APA Approved continuing education office for professional staff under the Chief Psychologist (5 Psy.D./Ph.D. psychologists, and 20 M.A./M.S.W. counselors). EFTA00231505 A60 Court Psychologist: Juvenile and Family Divisions of the Fifteenth Judicial Circuit and the Division of Youth Affairs, Palm Beach County, Florida. October 1985 to September 1987. Duties: Psychodiagnostic evaluations of children, adolescents and adults for the court in delinquency, dependency, custody and sex abuse cases. Clinical Supervisor of the Sable Palm Youth Service Center. Staff Psychologist: Scotland County Mental Health Center, Laurinberg, North Carolina February to August 1982. Duties: Individual and family psychotherapy (60% child services, 40% adult outpatient). Consultant to Scotland County School system. Competency evaluations for courts. Staff Psychologist: Robeson County Mental Health Center, Lumberton, North Carolina. August 1980 to July 1981. Duties: Outpatient Individual and family psychotherapy (60% child services, 40% adult outpatient). Psychodiagnostic evaluations for Center patients, local courts, and the Division of Vocational Rehabilitation. Pro evaluation of 15 Head Start Centers in a four county area for Consultant to Red Springs City School system, Southeastern Sheltered Workshop, and Robeson County Group Homes. INTERNSHIP Louisiana State University Medical School (APA Approved): New Orleans, Louisiana. September 1984 to August 1985. Training consisted of equal time spent in three rotations: Adult, Child and Neuropsychology. Year long training in outpatient psychotherapy and community mental health services at West Jefferson Mental Health Center (1 day per week), psychoanalytic treatment of adults at LSU Medical Center, weekly psychoanalytic psychotherapy seminars and weekly psychodiagnostics seminars. PRACTICUM PLACEMENTS Neuropsychiatry Unit: Wuesthoff Memorial Hospital, Rockledge, Florida. 20 hours per week (200 total hours); January to March, 1984. EFTA00231506 A61 Center for Student Development Florida Institute of Technology, Melbourne, Florida 10 hours per week (200 total hours); June to December 1983. Melbourne Head Start Center: Melbourne, Florida. 10 hours per week (100 total hours); September to December 1983. Robeson County Mental Health Center: Lumberton, North Carolina. 40 hours per week (1040 total hours); January to June 1980. University of Kentucky Medical Center (Outpatient Psychiatry): Lexington, Kentucky. 20 hours pa week (640 total hours); January to December 1979. PUBLICATIONS & RESEARCH PAPERS Alexander, S. & Wiatrowski, M. (1989). Delinquency prevention in a Youth Service Bureau. Unpublished manuscript. Alexander, S. (1992). Choosing and using experts. In, Child Custody and Visitation in Florida. Eau Claire, WI: National Business Institute, Inc. AWARDS 1993 Special Service Award presented by the Legal Aid Society and the Palm Beach County Bar Association for pro bono services to the community. PROFESSIONAL POSITIONS Education Chair of the Palm Chapter of the Florida Psychological Association, 1994. President of the Palm Chapter of the Florida Psychological Association, 1995. COMMUNITY SERVICE POSITIONS Board of Directors Fern House, West Palm Beach, Florida. Fern House is a residential rehabilitation center for male alcoholics and drug addicts. 2004 to present. EFTA00231507 Offender Name: JEFFREY E EPSTEIN NYSID #: O51909 1ST Reviewer Initials: -SOW The following is the Board of Examiners of Sex Offenders' recommendation pursuant to Section 168.1 of Article 6-C of the NYS Correction Law as to whether the offender shall be designated a Sexually Violent Offender, Predicate Sex Offender, or Sexual Predator as defined in subdivision seven of Section 168-a or whether the offender does not fit any of those categories due to his conviction. Please check all that apply: 1. O Sexually Violent Offender - 11 sex offender who has been convicted of a sexually violent offense defined la Correction Law section 168-a Please check which conviction(s) apply, also please indicate whether the conviction was for an attempt at an offense: Atamut Altittnni 130.35 - Rape 1st degree 130.50 - Sodomy 1st degree/Criminal Sexual Act 1st degree 130. 65 - Sexual Abuse 1st degree 130.66 - Aggravated sexual abuse 3rd degree 130.67- Aggravated sexual abuse 2nd degree 130.70 - Aggravated sexual abuse 1st degree 130.75 - Course of sexual conduct against a child 1st degree 130.80 - Course of sexual conduct against a child 2nd degree 130.53 - Persistent sexual abuse 130.65-a - Aggravated sexual abuse 4th degree 130.90 - Facilitating a sex offense with a controlled substance a conviction of or a conviction for an attempt to commit any provisions of the — foregoing sections committed or attempted as a hate crime defined in sectiose485.05 of the penal law or as a crime of terrorism defined in section 490.25 of such law. a conviction of an offense in any other jurisdiction which includes all of the — essential elements of any such felony provided for above or conviction of a felony in any other jurisdiction for which the offender is requited to register as a sex offender in the jurisdiction which the conviction occurred. 2. O Predicate Sex Offender - a sex offender who has been convicted of an offense set forth in subdivision 2 or 3 of Correction Law Section 168-a when the offender has bean previously convicted of an offense set forth in subdivision 2 or 3 of Section 168-a, regardless of the date of the prior conviction and regardless of whether the offender was required to register for the previous conviction. Please identity below the offenders previous qualifying conviction(s) as well as the offender's current qualifying conviction, also please indicate whether the conviction was for an attempt at an offense: Current ebth981 Attenmt 130.20 - Sexual Misconduct 130.25 - Rape 3rd degree 130.30 - Rape 2nd degree 130.40 - Sodomy 3rd degree/ — Criminal Sexual Act 3rd 130.45 - Sodomy 2nd degree/ — Criminal Sexual Act 2nd Current previous Aim! 130.60 - Sexual Abuse 2nd degree 255.25 - Incest Article 263 offense - Sexual Performance by a Child 135.05 - Unlawful Imprisonment 2nd degree 135.10 - Unlawful Imprisonment 1st degree CurrentPrevious to 2 O O. se O Attempt IR el, 0 <0<g) 135.20 - Kidnapping 2nd deg: et, 2 n o co, 135.25 - Kidnapping 1st degree (•Note: 135.05. 135.10. 135.20. 135.25 - the victim must be less than I I years old and the offender must not be the parent of the victim) Continued on the next page. n EFTA00231508 2. (Cont'd) Current Previous Attempt Current Previous Attempt 130.35 - Rape 1st degree 130.50 - Sodomy 1st degree/Criminal Sexual Act 1st degree 130. 65 - Sexual Abuse 1st degree 130.66 - Aggravated sexual abuse 3rd degree 130.67- Aggravated sexual abuse 2nd degree 230.04 Patronizing a prostitute 3rd degree (victim <17 years old) 230.05 Patronizing a prostitute 2nd degree 230.06 Patronizing a prostitute 1st degree 230.30 )- Promoting prostitution 2nd degree 230.32 Promoting prostitution 1st degree 235.22 -Disseminating indecent material to minors 1st degree 130.70 - Aggravated sexual abuse 1st degree a conviction of or a conviction for an attempt to commit any provisions of a 130.75 - Course of sexual conduct against a child 1st degree — listed see offense committed or attempted as a hate crime defined in section 485.05 of of such the penal law or as a crime of terrorism defined in section 490.25 130.80 • Course of sexual conduct against a child 2nd degree aw. J 130.53 - Persistent sexual abuse 130.52 Forcible touching (victim<I8 years old) 130.55 Sexual abuse 3rd degree (victim<18 130.65-a - Aggravated sexual abuse 4th degree years old) tT W 130.90 - Facilitating a sex offense with a controlled substance Conviction/Attempt — penal to commit any provision of 130.52 or 130.55 of the law regardless of age of victim and the offender has previously been a conviction of or a conviction for an attempt to commit any convictec of: (i) a sex offense provisions of a sexually violent offense as set forth in Correction listed in Correction Law Section 168-a (2), or (ii) a sexually violent offense listed in Correction Law Section 168-a (3), or Law Section 168-a (3) committed or attempted as a hate crime (Iii) any of the provisions of section 130.52 or 130.55 of the penal law or an defined in section 485.05 of the penal law or as a crime of attempt thereof. terrorism defined in section 490.25 of such law. A conviction of (i) an offense in any other jurisdiction which includes all of the — essential elements of any such crime provided for in Correction Law Section 168-a (2) 'a), or (ii) a felony in any other jurisdiction for which the offender is required to register as a sex offender in the jurisdiction in which the conviction occurred, Or (iii) any of the provisions of 18 U.S.C. 2251, 18 U.S.C. 2251A. IS U.S.C. 2252, 18 U.S.C. 2252A, or IS U.S.C. 2260 provided the elements of such crime of conviction are substantially the same as those which are part of such offense as of March 11, 2002. a conviction of an offense in any other jurisdiction which includes — all of the essential elements of any such felony provided for above or conviction of a felony in any other jurisdiction for which the offender is required to register as a sex offender in the jurisdiction which the conviction occurred. 250.45(2),(3)and(4) - Unlawful surveillance 2nd degree 250.50 - Unlawful surveillance 1st degree 3. O Sexual Predator - a sex offender who has been convicted of a sexually violent offense defined in Correction Law Section 168-a (3) and who suffers from a mental abnormality or personality disorder that makes him or her likely to engage in predatory sexually violent offenses. 4. None of the above. EFTA00231509 SEX OFFENDER REGISTRATION Act RISK ASSESSMENT INSTRUMENT RISK FACTOR VALUE SCORE I. CURRENT OFFENSE'S) I. Use of Violence Used forcible compulsion 'Minted physical injury Armed with a dangerous instrument +10 X +15 CO +30 2. Sexual Contact with Victim Contact over clothing Contact under clothing Sexual intercourse, deviate sexual intercourse or aggravated sexual abuse +5 25 +10 +25 X 3. Number of Victims Two Three or more +20 30 +30 X 4. Dorados of offense conduct with victim Continuing cane of sexual misconduct +20 X 20 5. Age of victim I I through 16 . tO or less, 63 orison +20 X 20 +30 6. Other victim characteristics Victim suffered Born mental disability a • incapacity or from physical helplessness +20 0 7. Relatioaship with victim Stranger or established for pispose of victimizing or professional relationship +20 X 20 IL CRIMINAL HIS I ORY 8. Age at first act of sexual misconduct 20 or less +10 . 0 9. Number and nature of prior crimes Prior history/no sex climes or Bionic, Prior historyinon-violent felony Prior violent felony, or misdemeanor sex crime or endangering welfare of a child +5 X +15 5 +30 to. Reency of prior offense Las dun 3 yeas +10 0 II. Dreg or Alcohol abuse, History of abase +15 0 COLUMNS I- II SUBTOTAL 130 SEX OFFENDER REGISTRATION ACT RISK ASSESSMENT INSTRUMENT RISK FACTOR VALUE SCORE III. POSE-OFFENSE BEHAVIOR 12. Acceptance of Responsibility Not accepted responsibility Not accepted responsibility I refined or expelled from treatment - 10 0 -15 +10 13. Conduct while confined / supervised Unsatisfactory . Unsatisfactory with sexual misconduct 0 +20 IV. RELEASE ENVIRONMEN1 14. Supervision Release with specialized supervision Release with supervision Release without supervision 0 4:5 0 +15 IS. IJving / employment situation Living or employment inappropriate +10 e 0 • COLUMNS 12-15 SUBTOTAL COLUMNS I-II SUBTOTAL 130 TOTAL RISK FACTOR SCORE (add 2 mdstotals) 130 1 2 X Offender Name: JEFFREY E EPSTEIN NYSID OS1909 Docket #: RISK LEVEL: Assessor's Signature Date: 3 to A Overrides (If any event& is circled, offender is presumptively a Level 3) 1. Offender has a prior felony conviction for a sex crime 2. Offender inflicted serious physical injury or caused death 3. The offender has made a recent threat that he will reoffend by committing asexual or violent crime 4. There has been a clinical assessment that the offender has a psychological, physical, or organic abnormality that decreases ability to control impulsive sexual behavior B. Departure I. A departure from the risk level is warranted Yes El No Level I flow) 0 to +70 2. If yes, circle the appropriate risk level I 2 3 Level 2 (moderate ) +75 to +105 Level 3 (high) +I l0 to +300 3 If yes. explain the basis for departure ( Sec Summary) Note: The Sex Offender Registration Act requires the court or Board of Examiners of Sex Offenders to consider any victim impact statement in determining a sex offenders level of risk. CPN EFTA00231510 A65 RE: JEFFREY E EPSTEIN NYSID #: OS1909 DATE: 8/23/2010 CASE SUMMARY This assessment is based upon a review of the inmate's file which may include but is not limited to the pre-sentence investigation, prior criminal history and post-offense behavior. Jeffrey Epstein is a 57-year-old sex offender who pled guilty in the state of Florida on 6/30/2008 to two felony sex offenses, Procuring a Person Under I8, for Prostitution and Felony Solicitation of Prostitution. He was sentenced toll months in jail followed by 12 months of Community Control. It would appear he was convicted in London England of Unlawful Possession of an Offensive Weapon, a Sword Stick, and was sentenced to a Conditional Discharge on 1/4/1973. Regarding the instant offense, Epstein was approximately 51 years of age on or about the year 2005 when he sexually assaulted numerous females between the approximate ages of 14 and 17. Most of the victims were recruited by one of Epstein's female employees from a local high school in the Palm Beach Florida area. Some of the female uarticiaants were age 18 or older. The contact included the The available police reports from the Palm Beach Police Department include conversations with numerous female victims who in most cases, did not know Epstein when they were victimized. Most of the females were embarrassed to speak with police regarding what had happened to them while they were at Epstein's home. Sworn statements were taken from at least five victims and seventeen witnesses concerning massages and unlawful sexual activity that took place at the residence of Jeffrey Epstein. Most of the victims were paid at least $200.00 each time they performed a massage. The victims were told they would be giving Epstein a massage and they were escorted to his bedroom. Most victims noted numerous pictures of naked young females, (some of the photos depicted females who would be eventually interviewed by police), on display throughout the home. The offender would enter the room only wearing a towel. In most cases he would remove the towel and ask the victim to remove her clothing. In some cases he would masturbate into a towel while receiving a massage. In other cases he would of the victim with his hands or . One 14 year old.described how Epste and thereafter, when contacted by law enforcement, she had to identify the offender through the use of a to arra . Another 16- ear-old victim described giving Epstein massages for two years and at times, he and as she gave him a masse e. Another 16-year-old described going to the offender's home at least 100 times. He would and sometimes on her while masturbating. He would also a this undera e victim to with a female friend while he watched. Occasionally, he would and the both. This 16- ear-old victim described for police how one time, Epstein turned her over on zWhenblic Mdl‘dITICA. "NO; he etitteut y apulugiced fur his actions. The offenders conduct while on Community Control will be considered satisfactory and he does not have a history of substance abuse. Based upon his plea of guilty, Epstein will be credited with accepting responsibility for his actions. He will be scored for sexual and deviate sexual intercourse, forcible compulsion, numerous victims and their ages, a continued course of sexual misconduct, a prior misdemeanor conviction in England absent specific information, for his stranger relationship to most victims and for establishing a relationship with these underage girls for the purpose of victimization. The Board acknowledges correspondence received from the offender's attorney. EFTA00231511 A66 RE: JEFFREY E EPSTEIN NYSID #: 051909 DATE: 8/23/2010 CASE SUMMARY Jeffrey Epstein used his wealth and power in such a way so that he could take advantage of many teenage girls to satisfy his own sexual perversions. He scores as a Level 111 Sex Offender with absolutely no basis for downward departure. EFTA00231512 A67 Utter from Supreme Court attaching Notification, Recommendation and Notice of Right to Appeal, dated August 26,2010 Supreme Court -- of -tl(r Aloft of pet), ' ark 100 CENTRE STREET NEW YORK. N.Y. 10013 TO: PART 66 FROM: CORRESPONDENCE UNIT SUBJECT: SEX OFFENDER RISK ASSESSMENT RE: Jeffrey Epstein SCID. $ 30129-2010 Please refer to the attached: I) Notification to sex offender, defense attorney and D.A.'s office of the scheduled risk assessment; 2.) Recommendation from Board of Examiners 3.) Notice of Right to Appeal and Appeal Application. Please be advised that the above named defendant, his assigned counsel, Sex Crimes Unit of the D.A.'s office, City and State Correctional Facilities have been notified of the sex offender risk level assessment hearing which has been scheduled in your part. Upon completion of the risk assessment, you must endorse the calendar and worksheet and forward the COURT FILE AND ASSESSMENTDOCUMENTSto this office. BE-FURTHER-*DVISED- THA-T- 11.1B DIVISION QF-7AItOLE MAY HOLD THE DEFENDANT UNTIL A RISK LEVEL HAS BEEN ASSIGNED. A REQJEST FOR 18B ASSIGNMENT HAS BEEN MADE. ONCE YOU IF SEND THE ATTACHED NO IFICATION LETTER AND BOARD OF EXAMINER'S PACKAGE TO HIM/HER EFTA00231513 A68 Letter from Supreme Court to Jeffrey E. Epstein Informing of SORA Level Determination Hearing, dated August 26, 2010 Supreme gnarl of tht Stott of 41eb twit August _26. 2_0111' LOO CENTRE STREET NEW YORK. N.Y. WOO Mr. Jelimy Epstein 9 East 71' Street New York. N.Y. 10021 Re: SCID # 30129-2010 Dear Mr. Epstein: Please be advised that pursuant to the 1996 Sex Offender Registration Act. the court must conduct a hearing to determine whether you wi II be classi lied as a level 1, 2 or 3 sex offender and i [you will he designated as a sexual predator. a sexually violent offender or a predicate sex offender. 'Ike owl's decision will detennine how long you must reg ister as a sex offender and how much in forma it in can he provided 10 the public concerning your registration. The courrsdetemination may be higher. It over or the same as the one recommended by the Board of Examiners. Your hearing has been scheduled for September 15.2010 at 9:30 a.m.. bclhre the Hon. Ruth l'ickholz in part 66 located at 111 Centre Street. New York, N.Y. You have a right to attend this hearing. Ifyou wish to waive your appearance for the hearing enclosed is a waiver form which must he not:wind and returned to this office within ten days of receipt. A request has been made for an attorney to represent you at this hearing. • If you WI to appear at this proceeding, without sufficient excuse, it shall be held in your absence. Failure to appear may molt in a longer period ofregistration or a higher level of community notification because you are not present to offer evidence or contest evidence offered by the District Attorney. iinclosed please find the Board of Examiners summary with their ft:commendation that you he assigned a risk level of3 and a document which describes what yourduties will be after you arc assigned ;i risk At the conclusion only detenn inat ion hearing you will receive a copy of the cotes final met ocndatinn will) a notice to appeal. Very truly yours. Mary A. Price. CC'S encs. Supreme Court - Criminal Tenn. New York ( aunty EFTA00231514 A69 Order Sheet for Jeffrey Epstein, dated August 26, 2010 [pp. A69-A70] ORDER SHEET Court Supreme Court. Criminal Term Date August 26. 2010 County New York Pan ('orrespondence f Mil The People of the State of New York. Jeffrey Ir:pstein I2efentlant I lianicide Highest Charge (Penal I .aw) Felony Special Proceeding Docker Ind./4 30129.20W Nisdcmcanwr Sex Offender Hearing Being satisfied after a review of the financial status of the defendant named. that he is financially unable r.t obtain counsel. and upon his request for the appointment of counsel, it is, Ordered that the following member of the Bat be and hereby is appointed to represent such defendant in all nutters pertaining ro this action: leagatia si.. if Aatittsi Adjourned Date Sept. K. 2016 Defendant's Status: I hfendaties Atkin-as. Paniled Adjourned Part 66 Ruth Pickholi ISniled a IncarccrucdI-1 9 Emu 71 Strum New York N.Y A:re I— (lodes Name: Mary A. Price. CCS Telephone IS 646-386-3860 EFTA00231515 A70 TRANSMISSION VERIFICATION REPORT TIME : 08/26/2018 18:58 FNAX TEL SERA, : BROK5J356431 DATE. TIME FAX if). MAW DURATION PAGE (G) RESULT MODE 08/26 10:58 186 ASSI9€D 00:80:18 01 OK STANDARD ECM Colin Supreme Court, Criminal Term County New York ORDER SHEET Date August 26.2010 11w People of the Sow of New York. vs. icffrey Rrstein Defending I Tumid& Highest Charge (Penal Law) Part Ccwresporide.nce Unit Docket Instil 30129.20t0 Felnny Nfiaderneanor LI Special Procoxling .!4ex Offender I letting V101261,fl Being satisfied after a review of the financial status of the defendant owned, that he it financially ambit to obtain counsel. and upon his respect fox rlw appointment of counsel, it is. Mimed that the following manber of the flaw be and hacby is appointed to represent such defendant in ill smote= pertaining to this action: • J•-••••••••.1 • ••••••• eent IS 7(110 MliOUMCCI Pan EFTA00231516 A71 Letter from Supreme Court to Counsel Informing of SORA Level Determination Hearing (with attachments), dated August 26, 2010 [pp. A71-A761 Supreme Court of a (Nth lgurit 100 CENTRE STREET NEW YORK. N.Y. 10013 August 26. 2010 Defense Attorney 18B To Be Assigned Ms. Inn-Young Park NYC District Attorneys Office I Hogan Place. Room 831 New York. N.Y. 10013 Re: Jeffrey Epstein SCID it 30129-2010 Dear Sir/Madam: The above named defendant is scheduled for a Sex Offender Risk Level Determination before the Hon. Ruth Pickholz in part 66 on September 15, 2010 at 9:30 a.m. The defendant has been notified under separate cover of this hearing and fonvarded a copy of the Board of Examiners recommendation. advised of his/her right to appear. advised of the name and address of the attorney assigned to represent him or that one is being assigned. risk level guidelines, and of his right to waive his appearance. Enclosed please find a copy of the Board of Examiners recommendation. '.ry trt,y you, . Mary A. Price. CCS Supreme Court - Criminal Term New York County EFTA00231517 Offender Name: JEFFREY E EPSTEIN NYSID ft: O51909 1ST Reviewer Initials: lie following is the Board of Examiners of Sex Offenders' recommendation pursuant to Section 168-I of Article 6-C of the NYS Correction Law as to whether the offender shall be esignated a Sexually Violent Offender. Predicate Sex Offender, or Sexual Predator as defined in subdivision seven of Section 168-a or whether the offender does not fit any of those ategories due to his conviction. 'lease check all that apply: O Sexually Violent Offender - a sex offender who has been convicted of a sexually violent offense defined in Correction Law section 168-a 13). Please check which convictionts) appl . also please indicate whether Me conviction was for an attempt at an offense: Attempt 130.35 - Rolm 1st degree 130.50- Sodomy Is! degree/Criminal Sexual Act 1st degree 13U. 65 - Sexual Abuse 1st degree 130.66 - Aggravated sexual abuse 3rd degree 130.67- Aggravated sexual abuse 2nd degree 130.70- Aggravated sexual abuse 1st degree 130.75 - Course of sexual conduct against a child 1st degree 130.80 - Course of sexual conduct against a child 2nd degree BMW 130.53 - Persistent sexual abuse 130.654 - Aggravated sexual abuse 4th degree 130.90 - Facilitating a sex offense with a controlled substance a conviction of or a conviction for an attempt to commit any provisions of the — foregoing sections committed or attempted as a hate crime defined in section 485.05 of the penal law or as a crime of terrorism defined in section 490.25 of such law. a conviction of an offense in any other jurisdiction which includes all of the essential elements of any such felony provided for above or conviction of a felony in any other jurisdiction for which the offender is required to register as a sex offender in the jurisdiction which the conviction occurred. 2. El Predicate Sex Offender - a sex offender who bas been convicted of an offense set forth in subdivision 2 or 3 of Correction Law Section 168-a when the offender has been previously convicted of an offense set forth in subdivision 2 or 3 of Section 168-a. regardless of the date of the prior conviction and regardless of whether the offender was required to register for the previous conviction. Please identify below the offenders previous qualifying conviction(s) as well as the offender's current qualifying conviction. also please indicate whether the conviction was for ar. attempt at an offense: :.umm Previous Aiwa 130.20 - Sexual Misconduct 130.25 - Rape 3rd degree 130.30 - Rape 2nd degree 130.40 - Sodomy 3rd degree/ Criminal Sexual Act 3rd 130.45 - Sodomy 2nd degree/ Criminal Sexual Act 2nd CurrergPrevious ago 130.60 - Sexual Abuse 2nd degree 255.25 - Incest Anide 263 offense • Sexual Performance by a Child 135.05 - Unlawful Imprisonment 2nd degree 135.10 - Unlawful Imprisonment 1st degree currentPreviou$ Attempt 133.20 - Kidnapping 2nd degree 135.25 - Kidnapping 1st degree (•Note: 135.05.135.10.135.20.135.2S - the victim must befits than 17 years old and the offender must not he the puent of the victim) Continued on the next page. EFTA00231518 2. Wooed, -urrant tat>: Anemia 230.04 Patroni7ing a prostitute 3rd degree (victim <17 years old) 23(1.05 Patronizing a prostitute 2nd degree 230.16 Patronizing a prostitute 1st decree 230.30 ) • Promoting prostitution 2nd degree 230.32 Promoting prostitution IS degree 235.22 Disseminating indecent material to minors 1st degree a conic ion of or a conviction for an attempt to commit any provisions of a — listed se offense committed or attempted as a hate crime defined in section 485.05 f the penal law or as a crime of terrorism defined in section 490.25 of such 130.52 Forcible touching (victim<18 years old) 130.55 -(Sexual abuse 3rd degree (victim<III years old) Convietl penal la convict (ii) a sex (iii) any attempt A convict{ — essential e 168-a (2) required t occurred. U.S.C. 22 such trim such ofTen Attempt to commit any provision of 130.52 or 130.55 of the regardless of age of victim and the offender has previously been of: (i) a sex offense listed in Correction Law Section 168-a (2), or fly violent offense listed in Correction Law Section 168-a (3), or the provisions of section 130.52 or 130.55 of the penal law or an ereof n of 6) an offense in any other jurisdiction which includes all of the meats of any such crime provided for in Correction Law Section or (ii) a felony in any other jurisdiction for which the offender is register as a sex offender in the jurisdiction in which the conviction r (iii) any of the provisions of 18 U.S.C. 2251.18 U.S.C. 225IA. 18 2. IS U.S.C. 2252A. or 18 U.S.C. 2260 provided the elements of of conviction are substantially the same as those which are part of as of March 11.2002. Current Previous ATICMDI 130.35 • Rape 1st degree 130.50 • Sodomy 1st degree/Criminal Sexual Act IA degree 130. 65 - Sexual Abuse Is degree 130.66 - Aggravated sexual abuse 3rd degree 130.67- Aggravated sexual abuse 2nd degree 130.70 - Aggravated sexual abuse I SI degree 130.75 - Course of sexual conduct against a child 1 n degree 130.80 - Course of sexual conduct against a child 2nd degree 130.53 - Persistent sexual abuse 130.65-a - Aggravated sexual abuse 4th degree 130.90 - Facilitating a sex offense with a controlled substance a conviction of or a conviction for an attempt to commit any provisions of a sexually violent offense as set forth in Correction Por Section 168-a (3) committed or attempted as a hate crime defined in section 485.05 of the penal law or as a crime of terrorism defined in section 490.25 of such law. a conviction of an offense in any other jurisdiction which includes — all of the essential elements of any such felony provided for above or conviction of a felony in any other jurisdiMion for which the offender is required to register as a sex offender in the jurisdiction which the conviction occurred. 250.45(2).13)and(4) - Unlawful surveillance 2nd degree 250.50 - Unlawful surveillance 1st degree Sexual Predator - a sex o ender who has been convicted of a sexually violent offense defined in Correction Law Section 168-a (3) and who soften from a mental abnormality or personality disorder that ekes him or her likely to engage in predatory sexually violent offenses. Ej None of the above. EFTA00231519 SEX OFFENDER REGISTRATION MT RISK ASSESSSIENT iNsTRuNnorr RISK FACTOR VALUE SCORE I. csiRREKI OF FENSEIS) I . Use of Violence Used forcible compulsion +10 X Inflicted physical injury 4-15 10 Armed with a dangerous instrument +30 Z. Sexual Contact with Victim Contract over clothing +5 contact wider clothing +10 oig Sexual imerconr1c. deviate sexual intaciAllsc or aagravaled sexual abuse +15 X 3. Number of Victims . Two +20 30 Three or more +30 X 4. Duration of offense conduct with - — victim Continuing course of sexual misconduct +20 X 20 5. Age of victim - I I through 16 +20 X 20 I0 a less. 63 or more +30 6. Other victim characteristics Victim suffered from mental disability or incapacity or from physical helplessness +20 0 - .... ... 7. Relationship with victim Stranger or established for purpose of victimizing or professional relationship +20 X 20 ii. CRIMINAL FRSIOW% 8. Age at first act of sexual misconduct 20 or less +10 0 9. Number and nature of prior crimes Price history/no sex crimes or felonies +5 X Prior history/norwviolem felony +15 5 Prior violent felony. or misdemeanor sex crime or endangering welfare of • child +30 i . . .. 10. Recency of prior offense ......... _ _ - ._. Less than 3 years +10 0 II. Drag or Alcohol abuse History of abuse - -- +15 -- - 0 — .. . . COLUMNS 1- II SUBTOTAL 130 SEX OFFENDER REGISTRATION ACT RISK ASSESSMENT INSTRUMENT RISK FACTOR VALUE SCORE III. POST-OFFENSL BEHAVIOR 12. Acceptance of Responsibility Not accepted responsihility +10 Not accepted responsibility / refused or 0 expelkd from utalsneni -FI5 i3. Conducfvehile.ioniinedisupereised . - . - — ' Unsatisfactory +10 Unsatisfactory with sexual misconduct 0 +20 Ix. RELEASE ENVIRONMEN 1 14. Supervision Release with specialized supervision 0 Release with supervision 4:5 0 Release without supervision _. +15 _ _ ... IS. Living/ employment situation Living or employment inappropriate +10 0 COLUMNS I2-IS SUBTOTAL • 0 . COLUMNS I-II SUBTOTAL ........ .... .._. . ____... —.—.. 130 .. _._ ._. .____._ TOTAL RISK FACTOR SCORE (add 2 subtotals) 130 I 2 X Offender Name: JEFFREY E EPSTEIN NYSID N: 0S1909 Docket k: RISK LEVEL: Assessor's Signature Date: 3 A. Overrides or any override is circled. offender is presumptively a Level 3 I. Offender has a prior felony conviction for a sex crime 2. Offender inflicted serious physical injury or caused death 3. The offender has made a recent threat that he will reoffend by committing a sexual or violent crime 4. There has been a clinical assessment that the offender has a psychological, physical. or organic abnormality that decreases abilhy to control impulsive sexual behavior B. Departure I. A departure from the risk level is warranted CD Yes Level I (low) w 0 10 +70 Level 2 2. If yes. circle the appropriate risk level 1 2 3 (modermc ) - +73 to +105 Level 3 (high) = +110 to +300 3. If yes. explain the basis for departure ( Sec Summary) Note: The Sex Offender Registration Act requires the court or Board of Examiners of Sex Offenders to consider any victim impact statement In detennlning a sex offender's level of risk. -4 EFTA00231520 A75 RE: JEFFREY E EPSTEIN NYSID 0S1909 DATE: 8/23/201(1 CASE SUMMARY This assessment is based upon a review of the inmate's file which may include but is not limited to the pre-sentence investigation. prior criminal history and post-offense behavior. Jeffrey Epstein is a 57-year-old sex offender who pled guilty in the state of Florida on 6/30/2008 to two felony sex offenses. Pmvuring a Person Under 18 for Prostitution and Felony Solicitation of Prostitution. He was sentenced toll months in jail followed by 12 months of Community Control. It would appear lie was convicted in London England of Unlawful Possession of an Offensive Weapon, a Sword Stick, and was sentenced to a Conditional Discharge on 1/4/1973. Regarding the instant offense, Epstein was approximately 51 years of age on or about the year 2005 when he sexually assaulted numerous females between the approximate ages of 14 and 17: Most of the victims were recruited by one of Epstein's female employees from a local high school in the Palm Beach Florida area. Some of the female narticioants were age 18 or older. The contact included the . The available police reports from the Palm Beach.Police Department include conversations with numerous female victims who in most cases, did not know Epstein when they were victimized. Most of the females were embarrassed to speak with police regarding what had happened to them while they were at Epstein's home. Sworn statements were taken from at least five victims and seventeen witnesses concerning massages and unlawful sexual activity that took place at the residence of Jeffrey Epstein. Most of the victims were paid at least $200.00 each time they performed a massage. The victims were told they would be giving Epstein a massage and they were escorted to his bedroom. Most victims noted numerous pictures of naked young females, (some of the photos depicted females who would be eventually interviewed by police), on display throughout the home. The offender would enter the room only wearing a towel. In most cases he would remove the towel and ask the victim to remove her cl thin cases he would masturbate into a towel while receiving a massage. In other cases he would of the victim with his hands or One 14 year old described how Epstein when contacted by law enforcement, she had to identify the offender through the use of a hoto arra . Another 16- ear-old victim described giving Epstein massages for two years and at times, he and as she gave him a masse e. Another 16-year-old described going to the offender's home at least 100 times. He would and sometimes on her while masturbating. He would • underage victim to with a female friend while he watched. Occasionally, he would and on both. This I 6-year-old victim described for police how one time, Epstein turned her over on the massaue table and . When she screamed "NO "he tiepredned sobsetiatolyapologized for his actions. The offenders conduct while on Community Control will be considered.satisfactory and he does not have a history of substance abuse. Based upon his plea of guilty. Epstein will be credited with accepting responsibility for his actions. lie will be scored for sexual and deviate sexual intercourse, forcible compulsion, numerous victims and their ages. a continued course of sexual misconduct. a prior misdemeanor conviction in England absent specific information. for his stranger relationship to most victims and for establishing a relationship with these underage girls for the purpose of victimization. The Board acknowledges correspondence received from the offender's attorney. EFTA00231521 A76 RE: JEFFREY E EPSTEIN NYSID#: O81909 DATE: 8/23/2010 CASE SUMMARY . . • Jeffrey Epstein used his wealth and power in such a way so that he could take advantage of many teenage girls to satisfy his own sexual perversions. l le scores as a Level ill Sex Offender with absolutely no basis for downward departure. EFTA00231522 A77 Letter from Jay P. Lefkowitz to Hon. Ruth Pickholz Requesting a Continuance of the Hearing. dated September 9, 2010 09/0T/2010 09:55 FAX rihon2,,no2 KIRKLAND & ELLIS LLP ANO AffittATED PAATtaltgilaS Sal Lexengten Avenue Nov York. New York 10O22 Jay P. LeRoy/It. P.C. F acsnole www.larklancl.ccm September 7, 2010 BY FACSIMILE The Honorable Ruth Pickholz New York County Supreme Court Pan 66 III Centre Street New York, NY 10013 Re: SCID No. 30129-2010 Dear Justice Pickholz: I am writing regarding the hearing for Mr. Jeffrey Epstein in the above-referenced matter, which is currently scheduled for 9:30,a.m. on Wednesday, September 15, 2010. We respectfully request a continuance of the hearing. Kirkland & Ellis was only recently retained by Mr. Epstein to represent him in this matter and due to the holidays this week and because the matter arises out of Florida, we will need some time in order to collect information to prepare for the hearing. We are available on or after October 4, 2010 for a hearing on this matter if that would be acceptable to the Court. We are available to discuss at the Court's convenience. Respectfully submitted, Lefkowitz, P.C. Chicago Hong Kong Lor1000 Los Angeles Memel Palo Alto San Francisco Shanghai Washington. 0 C. EFTA00231523 A78 Letter from Supreme Court to Sex Offender Registry Unit Enclosing Final Determinations, dated January 19, 2011 [pp. A78-A79] .Supreutr CMITi of fifr gfinle of Nit 'ark IDOCENTRE Stfil:ET IIFWYORK NY 141.3 January 19, 2011 Sex Offender Registry Unit NYS Division of Criminal Justice Services 4 Tower Place Albany, NY 12203 Dear Sir/Madam: Enclosed please find the Final Determinations on the following cases: Name Jeffrey Epstein End. cc: Mr. Jeffrey Epstein 9 East 71st Street New York, NY 10021 Ind.# Risk Level 30129-2010 Three (3) Respectfully yours. F. Haiwick, SCC Correspondence Unit Supreme Court, Criminal Term E EFTA00231524 A79 PE SI N''' GpEFICER 44: %.'14% • -SOPERMSIIN.A4040Yi• ONE; 6FFErtiDgii-P-UIIS PERMS •, Fr . • t; 4 renceiHHI 11;idusd ;ohm...I:tatted: an offense in anoThher ris Stets at the: addrestiridkadeek.Jt he beenTdetarinfrtad,thitt.thetoftendir larritsq akatOi'ottendetraj Hew Yoi .0/ :1104YS Hoard 0 EktiiPitieft rlil ittiraittrandififi a Oak' vitlariel. *abort. age i en,thlettlettaillisk eigetem inatriarrieittf se. =Sri and Oland 10:form.T. litilfil 4 dcitfec.(161130 fill384(Pr: the CountyOr Si4rirta taudlicatiCaduntiorirettdericri'lotth‘offendin4 l oeliereinw.ftci7Sifitietert › eniesigiiatioolftwpeul ..m eliistOaternWeirhethei:the ':offandeCnieeti- theideffriitio :61.'se'xiiiiruCtisTAI >. • jatecileate sex OfttdOcr•sexuathiodatonalket forth in Cortlort Liar Sectain 163-apli '' Sci ,**StiikgrZ744;.Vt , tccalA , PleadatiteerAgumbrAiydria0epsitVetthelliiiI0OW -OE tiegobeitiOilk ,ei tp . ; ,tbrielq6qhmraltieerrantandartt404041.that Ihn:pitirt;dhafiliorlatiat tlie!taitlinfcrilldfdardaliaBair Satirinkh 1 a .., :f itqfkOhai;.hovimbein'olven nolicelnOtidniitthri'aate;':dinaanci:place'of the gigefreorriigliKtoispisodspgremitienf, .9.-•?cf, • .* hate hOdSialddagdiiike,dit d . . rptieizgisiffinditesitidc last, 'it itothmunity notifitatIOW6 olPEtir t&INAViONOi'r%'*APre ..-e... 4"12A.:.13IIikO11 491.,' hit;; of;the'ordertaiWpg fort Mei arid designation.detrarhinitronsA ' sing 'lin nc #,414606a0466011hatiogsAtrtglideidi'lharbOhhtMad OttiDlyisioillSof,:‘ ieJaitbogs4musw oe'. by :: '.. WI' thibii? pleriiii.coniplatelinictfillidillair*In tli Alie:(4)kgidirveror .tdeelebeabwokirare:btebr 044mmegebtople,totisopbelei#4, be , ib Ppxosty4crro mN.!-- -,; -try..?,?isit.......t- y.......4...ilte.,,t74t ,,,,p; 47., ottr — 4 A.',:iiVikir%.Mkp..IP4;4.ift r.÷:.?Ine,,Stinarlic 14 41iffiatt fir,?*...., ado below ittebatompiR Sep Cow: collity, 4‘i. ' gf,:t ITIV*S0 INAVON. . cycl oriel . .tsV'7,;•44' :i•• ?.: - ,.. .e. • . g • ii.7-4..tr. . . 0 .1 DESIGNATIOtikOsiatii,Clieckithy i itk) r r.stiarittiMiticip 6-O1:ifikiNyt. orreicil cr "...n . lyrt -praty;,. seal . 404244 .r•htiaift?;1101.a: - it I. igz,'Mpti No ds . EFTA00231525 A80 Court Action Sheet - Jeffrey Epstein, No. 30129-2010 ' COUNTY OF 4444.49retcp PEOPLE,VS -##Ale•Cp a c r... :, ,.. NO. .3 01015 'A Cli 0 NYS I D NO. DATE OF BIRTH SEX 11 ADDRESS plOTICE OF APPEARANCE 20 FILED BY • ADDRESS • TELEPHONE NO. RET 0 L.A. 0 18B 0 SUBSTITUTION 20 FILED BY ADDRESS TELEPHONE RET 0 L.A. 0 ISO 1.3 T IRKLAND & ELLIS LLP ND MITI ;Ann exeuxt val JAY P. LEFKOWITZ. P.C. or)O0 • Vote 10022 601 Av Tel • Fax RECOGNIZANCE ROR 20 BAIL FIXED AMOUNT COURT CLERK COUNSEL PRESENT JUSTICE ON CONSENT OF ADA COURT REPORTER BAILED 20 SURETY C INTERPRETER COURT CLERK COURT CLERK ROR REVOKED.BW 20 JUSTICE BAIL FORF..BW 20 JUSTICE BAIL EXONERATED JUSTICE SURR. BY SURETY 20 ARTICLE 730 EXAMINATION ORDERED 2O JUSTICE COURT CLERK COURT REPORTER SUBSEQUENT ACTION RE RECOGNIZANCE PART 20 JUSTICE ADM PRESENT COUNSEL PRESENT COURT REPORTS' COURT CLERK ORDERED 20 JUSTICE COURT CLERK COURT REPORTER COMMITTED TO COMMISSIONER OF MENTAL HYGIENE: PART 20 JUSTICE ADA PRESENT COUNSEL PRESENT EFTA00231526 A81 Handwritten Notations on Court Jacket - Jeffrey Epstein, No. 30129-2010 iC t`r3 te j vt ti 4 \ I.... 4 \-) `6 )) 1 ,..) , S.? ', , ‘1 • 3 1.3. -'\ T.- -.,-. 1 I. a '• i._ I 0 4 U -1 n i r a c EFTA00231527 A82 Transcript of SORA Hearing, dated January 18, 2011 (pp. A82-A96( S0RA HEARING page 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 SUPREME COURT NEW YORK COUNTY TRIAL TERM PART 66 x THE PEOPLE OF THE STATE OF NEW YORK: INDICTMENT # : 30129/2010 • AGAINST • JEFFREY EPSTEIN • Defendant. BEFORE: x SORA HEARING 111 Centre Street New York, New York 10013 January 18, 2011 HONORABLE RUTH PICKHOLZ Justice of the Supreme Court APPEARANCES: For the People: For the Defense: CYRUS R. VANCE, JR., ESQ., New York County District Attorney One Hogan Place New York, New York 10013 BY: JENNIFER GAFFNEY, ESQ. Assistant District Attorney KIRKLAND & ELLI, LLP 153 East 53rd Street New York, New York 10022 BY: JAY LEFKGAUTZ, ESQ. SANDRA MUSUMECI, ESQ. Vikki J. Benkel Senior Court Reporter Vtkki J. Benkel Senior Court Reporter EFTA00231528 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 -23 24 25 A83 SORA HEARING page 2 COURT CLERK: This is number two on the calendar, matter of Jeffrey Epstein. Your appearances please. MS. GAFFNEY: Jennifer Gaffney for the People. Good afternoon, Your Honor. MR. LEFKOWITZ: Jay Lefkowitz and Sandra Musumeci for Mr. Epstein. THE COURT: Mr. Epstein is not here. MR. LEFKOWITZ: That's correct. THE COURT: Are you waiving his appearance? MR. LEKWOWITZ: Yes. MS. GAFFNEY: Your Honor, this case is on for a SORA hearing this afternoon. The People did receive the board's recommendation of a Level Three. However, we received the underlying information from them and also had some contact with Florida, and we don't believe that we can rely on the entire probable cause affidavit. I don't know if the board sent that to you as well. THE COURT: I don't know why you cannot rely on it. MS. GAFFNEY: Because in- Florida-of-all of the - victims in that probable cause affidavit, they actually only went forward on one case. There was only an indictment for Vikki J. Benkel Senior Court Reporter EFTA00231529 A84 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 SORA HEARING page 3 one victim and that is what the defendant plead to. So it is unlike a situation where everything MS indicted and then we get to sort of assess points for all of the victims, if it was part of a plea bargain. They did not actually choose to go forward on any except for the one victim. So under the board guidelines, the risk assessment interim guidelines, it actually says, you know, by way of contrast if an offender is not indicted for an offense, it is strong evidence that the offense did not occur and I don't think -- THE COURT: Do you find that if somebody is not indicted it is strong evidence that it did not occur? MS. GAFFNEY: I don't know that we can rely on it as clear and convincing evidence if the prosecutor's office never went forward on it. The prosecution said that the victims, although they spoke to the police early on, did not cooperate with them. So we don't have any follow up information. THE COURT: But the board found a Level Three. I have to tell you, I am a little overwhelmed because I have never seen the prosecutor's office do anything like this. I have never seen it. I had a case with one instance it was a marine who went to a bar, and I wish I had the case before me, but he went to a bar and a 17 Vikki J. Benkel Senior Count Reporter EFTA00231530 A85 SORA HEARING page 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 year old, he was an adult obviously, he was a Marine, a 17 year old came up to him and one thing lead to another and he had sex with her and the People would not agree to a downward modification on that. So I am a little overwhelmed here because I see -- I mean I read everything here, I am just a little overwhelmed that the People are making this application. I could cite many many, I have done many SORAs much less troubling than this one where the People would never make a downward argument like this. MS. GAFFNEY: I agree with Your Honor, it is incredibly unusual for us to make a downward argument. But the problem is the one thing that we have from the board is it seems to be in contradiction to their own guidelines which if something was not indicted, you are not supposed to rely on it. THE COURT: They obviously took that into consideration. MS. GAFFNEY: And I tried to reach -- I reached the authorities in Florida to try to see if they had all the interview notes or other things that we can then subsequently rely on that might be considered clear and _convincing evidence---if they -had Interviewed these women on their own, and they never did. No one was cooperative and they did not go forward on any of the cases and none of them Vikki J. Benkel Senior Court Reporter EFTA00231531 A86 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 SORA HEARING page 5 were indicted. So I don't knaN. THE COURT: And you spoke to the prosecutor? MS. GAFFNEY: The actual prosecutor left the office. I spoke to the prosecutor that took over the case. THE COURT: Maybe you can find the prosecutor that left the office. You have done more in other cases looking into it. I have never seen the prosecutor's office do this. I have to tell you, I am shocked. MS. GAFFNEY: Right, but I spoke to the prosecutor that took over the case and they don't have anything, any affidavits, any statements, any notes. THE COURT: Why don't you speak to the prosecutor that did do the case, I am sure you could find that prosecutor. MS. GAFFNEY: I can find her, but based upon what the other prosecutor said, they did not speak to that prosecutor either. THE COURT: You did not speak to the prosecutor yourself, you did not speak to them, that is hearsay. You did not speak to the prosecutor that handled the case. MS. GAFFNEY: That's right. THE COURT: I don't think you did much of an investigation here. MS. GAFFNEY: I mean I called the prosecutor. Vikki J. Benkel Senior COUrt Reporter EFTA00231532 A87 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 SORA HEARING Even though the first prosecutor left, presumably the prosecutor's office has the file. THE COURT: I would still call the prosecutor. MS. GAFFNEY: Anything from these women they would have forwarded it to us. THE COURT: I don't know that, I think you have to speak to the prosecutor. But be that as it may, I hear your argument. Anything else? MS. GAFFNEY: I mean that is why I don't think we can, I don't think we are entitled to rely on this because they did not go forward. THE COURT: The board made a recommendation. MS. GAFNEY: Correct. MS. MUSUMECI: May I speak, Your Honor? THE COURT: Yes. MS. MUSUMECI: Good afternoon. I would like to bring a few additional points to Your Honor's attention that don't come across in the board recommendation. The first is that Mr. Epstein is not a resident of New York, unlike most of these out of state, he has not changed-his address-and moved to New York, he maintains a vacation home in New York. His primary residence is the U.S. Virgin Islands. page 6 Vikki I Bunke! Senior Court Reporter EFTA00231533 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A88 SORA HEARING page 7 He is registered in the U.S. Virgin Islands, he has been since his release from jail. He notifies the Virgin Island authorities every time he leaves that jurisdiction. Virgin Island authorities rated him at the lowest level of registration. He also registered in Florida, which is the state of this particular offense, and the only reason that this conviction is even before Your Honor. The offense for which he was convicted is not a registrable offense in New York. He is only registrable here arguably because based on the provision of SORA that says if a crime is registrable in the state of conviction, then it is registrable here in New York. And the Florida authorities that considered that rated him at the lowest level of their SORA statute. He additionally has a vacation home in New Mexico and is registered in New Mexico. The New Mexican authorities when they considered his offenses, determined he need not register at all. Nevertheless, he has voluntarily registered with New Mexico and maintains that registration. Additionally, because of his possession of a vacation home in New York, he has been voluntarily registered with New York SOMU, the Sex Offender Monitoring Unit since May of this year. He notifies them whenever he comes to travel to New York. He never comes to New York for Vikkt J. Benkel Senior Court Reporter EFTA00231534 A89 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 SORA HEARING page 8 more than seven days or at least he has not since he has been registered. He has no intention to ever be here for longer than a period of ten days. Like I said, he does notify the authorities when he is here. He fully understands the reason for voluntary registration, he wants to be compliant with the Federal SORA law which requires wherever you own a property to register. To require Mr. Epstein to register as a Level Three offender in New York would actually require him to come to New York more than he does normally, it would require him to come every 90 days and renew his registration. He is very diligent in registering with New York authorities. All of the other jurisdictions that have considered his case have determined that he either not register at all or register at the lowest level, and he has been more than compliant with all of those requirements. Your Honor, we would join in the prosecutor's application. THE COURT: I am sure you would. MS. MUSUMECI: By way of background, we have been in contact-with the-prosecutor's office on-this matter -since-- I believe certainly since Mr. Epstein got his notification, which I believe was in August. We have met with the Vikki J. Benkel Senior Court Reporter EFTA00231535 A90 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 SORA HEARING prosecutor and provided numerous materials for the prosecutor to consider. We have included in that a deposition from the detective who headed this investigation who acknowledged in a sworn deposition that the lead prosecutor who originally had the case, whose name I cannot pronounce, Lanna Belohlavek, I apologize for the mispronunciation, said to the detective after her investigation, there are no real victims here. All of the alleged conduct that is cited in the board's write up MS commercial conduct. All of the alleged conduct the women went voluntarily, there are no allegations of force certainly none. THE COURT: There was no allegation of force in the marine either, who met a girl in a bar, a young girl 17, there was no force there. MS. MUSUMECI: It is our understanding that the prosecutor in Florida conducted a full investigation, as full as she was able with the cooperation afforded by these complainants, and determined that the only case that she could present to the grand jury was this indictment for a non registrable offense then -- THE COURT: But it is registrable here. I don't know what you mean non registrable offense. MS. MUSUMECI: Let me explain, Your Honor. Yikki r. Berke! Senior Colin Reporter page 9 EFTA00231536 A91 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 SORA HEARING page 10 Mr. Epstein plead to two charges, one was an indictment which is an offense that is not registrable, it is a Florida indictment for -- THE COURT: Then why does he have to register here? MS. MUSUMECI: It was a second offense that he plead to -- THE COURT: That is registrable. MS. MUSUMECI: That is registrable. That offense was by information and that is the only registrable offense, that is what the DA's office is considering in doing their scoring. The indictment which was the only case that the prosecutor even prosecuted through grand jury is not even a registrable offense. THE COURT: He plead guilty to a registrable offense. MS. MUSUMECI: Yes. THE COURT: What did he plead guilty to? MS. GAFFNEY: He plead guilty to the procuring a person under 18 for prostitution. THE COURT: Procuring a person under 18 for prostitution. MS. GAFFNEY: Right. THE COURT: How old was she? Vikki J. Benket Senior Court Reporter EFTA00231537 A92 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 SORA HEARING page 11 MS. GAFFNEY: It appears the first time they met she was either 16 or 17, then for the remainder of their relationship she was probably 17. THE COURT: How long was their relationship? MS. GAFFNEY: She met, she gave him approximately 15 massages, including with sexual contact, and ultimately when she is 17 had intercourse with him. THE COURT: She is a child. MS. MUSUMECI: Your Honor, I would note that under SORA it is clear that prostitution offenses are only registrable when in fact by clear and convincing evidence the women or victim is 17, is under 17. THE COURT: Well, she met him at 16, he procured her at 16 from what I read. MS. MUSUMECI: There is evidence we challenged. THE COURT: He plead guilty to that, didn't he? MS. MUSUMECI: He plead guilty to under 18, which is the law in Florida, which is a different standard than what the law is in New York. And there is no evidence, there is no clear and convincing evidence as to her specific age at the time of the specific conduct. THE COURT: Well, the DA just told me she was most likely 17, she just said it on the record. MS. MUSUMECI: Your Honor, we agree that the evidence is that she was 17 on the one occasion she had VOX J. Benke! Senior Court Reporter EFTA00231538 A93 SORA HEARING page 12 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 consensual intercourse with him and 17 is not registrable or criminal under New York law. And the prostitution aspect of having intercourse with a 17 year old is not registrable conduct. THE COURT: Why does he have to register here? MS. GAFFNEY: Because it is a register able offense in Florida, New York State board of examiners THE COURT: Recognizes it. MS. GAFFNEY: Recognizes it, yes. THE COURT: I have had many cases like that where it was not registrable here but it was in the state where the person came from and New York recognized that. MS. MUSUMECI: Your Honor, we are not saying that he should not register. Mr. Epstein has already registered and recognizes his duty to register. THE COURT: I am glad of that, very glad of that. I am sorry he may have to come here every 90 days. He can give up his New York home if he does not want to come every 90 days. Anything else? I rely on the board. MS. MUSUMECI: Your Honor, we would reserve our --Tight—to appeal YboUr Honor's ruling. THE COURT: Of course, do so. MS. GAFFNEY: For the record, Your Honor, he is Vikki J. Benke! Senior Cowl Reporter EFTA00231539 RECORD PRESS, INC., 229 West 36th Street, N.Y. 10018-28829 www.recordpress.com EFTA00231540 To be Argued By: JAY P. LEFKOWITZ New York County Clerk's Index No. 30129/2010 Xeftr larrrit $upratte Txxurt APPELLATE DIVISION—FIRST DEPARTMENT PEOPLE OF THE STATE OF NEW YORK, —against— JEFFREY E. EPSTEIN, Respondent, Defendant-Appellant. BRIEF FOR DEFENDANT-APPELLANT JAY P. LEFKOWITZ SANDRA MUSUMECI KritnANn & Fans LLP 601 Lexington Avenue New York New York 10022 'ay.leflcowitz@kirkland.com Attorneys for Defendant-Appellant REPRODUCED ON RECYCLED PAPER • EFTA00231541 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 QUESTIONS PRESENTED 2 STATEMENT OF FACTS 3 I. The Underlying Offense 4 II. Sex Offender Registration 6 III. The Board's Recommendation 7 IV. Pre-Hearing Investigation By the District Attorney 11 V. SORA Hearing 12 ARGUMENT 16 I. THE COURT'S LEVEL 3 DETERMINATION IS NOT SUPPORTED BY CLEAR AND CONVINCING EVIDENCE AS REQUIRED BY SORA AND AS A MATTER OF FEDERAL CONSTITUTIONAL LAW 17 A. The People's Investigation Revealed That The Board's Recommendation Could Not Be Proven By Clear and Convincing Evidence. 20 B. The Court Improperly Relied on the Board's Recommendation Where the Facts Cited Therein Were Disputed and No Further Evidence Was Presented. 25 C. Determining Appellant To Be a Level 3 Offender Based on Factors That Were Not Proven by Clear and Convincing Evidence Violated Appellant's Federal Due Process Rights. 32 IL THE COURT BASED ITS LEVEL 3 DETERMINATION UPON IMPROPER CONSIDERATIONS. 36 A. The Court Improperly Assessed Points Against Appellant for Conduct That Is Not Scoreable Under SORA. 36 i EFTA00231542 B. The Court Improperly Allowed Personal Feelings and Matters Outside the Record to Influence Its SORA Determination 38 III. THE COURT'S ORDER DOES NOT COMPLY WITH THE MANDATES OF SORA AND CONSTITUTIONAL DUE PROCESS AND MUST BE VACATED. 45 CONCLUSION 49 EFTA00231543 TABLE OF AUTHORITIES Cases Doe v. Pataki, 3 F. Supp. 2d 456 (S.D.N.Y. 1998) 32, 33, 35, 36 E.B. v. Verniero, 119 F.3d 1077 (3d Cir. 1997), cert. denied, 522 U.S. 1109 (1998) 34, 35 Fresh Del Monte Produce N.V. v. Eastbrook Caribe, 40 A.D.3d 415 (1st Dep't 2007) 43 Goldberg v. Kelly, 397 U.S. 254 (1970) 48 Matthews v. Eldridge, 424 U.S. 319 (1976) 32 New York State Bd. of Sex Exam'rs v. Ransom, 249 A.D.2d 891 (4th Dep't 1998) 18 People v: Arotin, 19 A.D.3d 845 (3d Dep't 2005) 24 People v. Boncic, 15 Misc. 3d 1139(A), 841 N.Y.S.2d 281 (Sup. Ct. N.Y. Cty. 2007) 31 People v. Brooks, 308 A.D.2d 99 (2d Dep't 2003) People v. Coffey, 45 A.D.3d 658 (2d Dep't 2007) 24 People v. Curthoys, 77 A.D.3d 27 People v. David W., 95 N.Y.2d 130 (2000) 32 iii EFTA00231544 People v. Dominie, 42 A.D.3d 589 (3d Dep't 2007) 19 People v. Donk, 39 A.D.3d 1268 (4th Dep't 200'7) 31 People v. Ferguson, 53 A.D.3d 571 (2d Dep't 2008) 39 People v. Gilbert, 78 A.D.3d 1584 (4th Dep't 2010) 47 People v. Jimenez, 178 Misc. 2d 319, 679 N.Y.S.2d 510 (Sup. Ct. Kings Cty. 1998) 18 People v. Johnson, 11 N.Y.3d 416 (2008) 18 People v. Jordan, 31 A.D.3d 1196 (4th Dep't 2006) 39 People v. Judson, 50 A.D.3d 1242 (3d Dep't 2008) 27 People v. Mabee, 69 A.D.3d 820 (2d Dep't 2010) 97 People v. Mingo, 12 N.Y.3d 563 (2009) People v. Miranda, 24 A.D.3d 909 (3d Dep't 2005) 47 People v. Rampino, 55 A.D.3d 348 (1st Dep't 2008) 43 People v.-Redcross, 54 A.D.3d 1116 (3d Dep't 2008) 31 People v. Sherard, 73 A.D.3d 537 (1st Dep't 2010) 43 iv EFTA00231545 People v. Smith, 66 A.D.3d 981 (2d Dep't 2009) 24 People v. Strong, 77 A.D.3d 717 (2d Dep't 2010) 47 People v. Wasley, 73 A.D.3d 1400 (3d Dep't 2010) 27 Rossi v. Hartford Fire Ins. Co., 103 A.D.2d 771 (2d Dep't 1984) Solomon v. State of New York, 146 A.D.2d 439 (let Dep't 1989) Statutes 14 V.I.C. § 1722(b) 19 19 14 V.I.C. § 1724(d) 7 14 V.I.C. § 1724(e) 7 Correction Law § 168-a(2) 9 Correction Law § 168-a(2)(a) 5, 9 Correction Law § 168-a(2)(a)(i) 3, 37 Correction Law § 168-a(2)(d)(ii) 9, 17 Correction Law § 168-a(7) 45 Correction Law § 168-k 17, 45 Correction Law § 168-k(2) Correction Law passim - 8 Correction Law § 168-1(6)(c) 8 Correction Law § 168-n 45 V EFTA00231546 Correction Law § 168-n(2) 16, 18 CPLR 5513 16 CPLR 5515 16 Fla. Stat. § 775.21 6 Fla. Stat. § 794.05(1) 21, 28 Fla. Stat. § 796.03 1, 4, 6 Fla. Stat. § 796.07(2)(f) 1 Fla. Stat. § 796.07(4)(c) 4 Fla. Stat. § 800.04(5) 21, 28 Fla. Stat. § 943.0435 4, 5, 6, 9 N.Y. Penal Law § 230.25 9 Rules Prince, Richardson on Evidence § 3-205 (Farrell 11th ed.) 19 Sex Offender Registration Act: Risk Assessment Guidelines and Commentary, Commentary (2006) 22, 31, 41 vi EFTA00231547 PRELIMINARY STATEMENT Appellant Jeffrey E. Epstein seeks to vacate the final decision and order of the New York Supreme Court, Criminal Term, New York County, determining him to be a Level 3 sex offender, without designation, under New York's Sexual Offender Registration Act (SORA), Correction Law Article 6-C, based on a 2008 Florida conviction by plea of guilty to Procuring a Person Under 18 for Prostitution, Fla. Stat. § 796.03, and Felony Solicitation of Prostitution, Fla. Stat. § 796.07(2)(f), for which Appellant was sentenced to consecutive terms of 12 months and 6 months incarceration, followed by 12 months of Community Control. (Pickholz, J. at SORA hearing). Appellant seeks to vacate the Order because the Court's risk level determination was not supported by clear and convincing evidence, was based on improper considerations, and was made without affording the parties an opportunity to present evidence concerning disputed relevant issues. More specifically, in making its determination, the Court summarily adopted the recommendation of the Board of Examiners of Sex Offenders (the "Board"), notwithstanding the position of the District Attorney's Office that the Board's recommendation was legally infirm 1 EFTA00231548 and not supported by provable evidence. Additionally, the Court issued a facially defective Order that fails to set forth findings of fact and conclusions of law, as required by law. Accordingly, the Order determining Appellant to be a Level 3 offender should be vacated, and Appellant's risk level should be recalculated based solely on those factors that may be properly considered under SORA and which are proven by clear and convincing evidence. QUESTIONS PRESENTED 1. May the Court determine Appellant's risk level under SORA based on factors that are not proven by clear and convincing evidence? 2. Is the Court entitled to adopt the Board's recommendation in full, without hearing any further evidence, where Appellant disputes numerous unprosecuted allegations contained therein and the District Attorney, as representative of the State, disclaims the Board's recommendation as unreliable, based on allegations that were determined to be not prosecutable, and not provable by clear and convincing evidence? 3. In calculating Appellant's risk level under SORA, may the Court score points for consensual prostitution-related conduct involving 2 EFTA00231549 women who were seventeen years of age or over, particularly where SORA provides that such conduct is only registerable where the person patronized "is in fact less than seventeen years of age," Correction Law § 168-a(2)(a)(i)? 4. Where the Court's Order assigning Appellant a risk level of 3 under SORA does not include any findings of fact or conclusions of law to support a Level 3 determination, must that Order be vacated? STATEMENT OF FACTS Defendant-Appellant Jeffrey E. Epstein is a 58-year old financial advisor and philanthropist whose primary residence is in the U.S. Virgin Islands and who also maintains vacation properties in New York and Florida. See A.53 (Letter of M. Weinberg of Aug. 16, 2010).1 Appellant does not live in New York, and since the commission of the Florida offense that forms the basis of this matter, he has not stayed at his New York property for periods of ten days or more at a time. See A.53 (Letter of M. Weinberg of Aug. 16, 2010); A.87:21-25, 88:21- 89:3frr.), References to the Record on appeal are denoted herein as "A." followed by the applicable Appendix number. 2 References to the transcript of the January 18, 2011 SORA hearing are denoted herein as "Fr." followed by the applicable page and line citation. 3 EFTA00231550 I. The Underlying Offense On June 30, 2008, Appellant pleaded guilty in the Circuit Court for Palm Beach County, Florida under an Information to the charge of Procuring a Person Under 18 for Prostitution, Fla. Stat. § 796.03, an offense which required him to register under Florida's sexual offender registration statute, Fla. Stat. § 943.0435. See A.31 (Information for Procuring Person Under 18 for Prostitution, dated June 26, 2008); A.32 (Guilty Plea, dated June 30, 2008). This single registerable charge was brought in connection with a consensual, commercial arrangement in which Appellant received massages and engaged in sexual conduct with A.D., a young woman who was over the age of consent under New York law but just under 18 when the offense in the Information occurred back in 2005. See A.53 (Letter from M. Weinberg, dated Aug. 16, 2010, at 1, 3). Appellant concurrently pleaded guilty to an Indictment charging him with one count of Felony Solicitation for Prostitution, Fla. Stat. §§ 796.07(2)(f), (4)(c) -- a solicitation offense which does not include any elements of sexual contact with underage women and which is not registerable under either Florida or New York law. See A.26 (2006 Grand Jury Indictment of Felony Solicitation of Prostitution); A.32 EFTA00231551 (Guilty Plea, dated June 30, 2008); Fla. Stat. § 943.0435; Correction Law § 168-a(2)(a). Despite an extensive investigation by Florida prosecutors regarding various other complaints alleged against him and reported in police paperwork, Appellant was never charged with any other crimes or prosecuted on allegations made by any other complainants. See A.26 (2006 Grand Jury Indictment of Felony Solicitation of Prostitution); A.31 (Information for Procuring Person Under 18 for Prostitution, dated June 26, 2008); A.83:23-84:6, 85:19- 86:1, 90:16-91:15, 95:14-18 (Tr.). As a result of his two concurrent Florida convictions -- the first and only criminal convictions of his life -- Appellant was sentenced to consecutive terms of 12 months and 6 months incarceration in a Palm Beach County Detention Facility, followed by 12 months of Community Control supervision. See A.32 (Guilty Plea, dated June 30, 2008); A.34 (Sentence, dated Jun. 30, 2008). Appellant satisfactorily served 13 months of incarceration (during which time he was granted permission to participate in the Sheriff's work release program) and completed a subsequent period of 12 months Community Control (during which the Court trusted him, for business purposes, to travel outside of Florida 5 EFTA00231552 with prior notice and approval by his supervising probation officer) without incident. See A.49 (Letter from Florida Department of Corrections, dated Jul. 21, 2010); A.50 (Letter from Palm Beach Sheriffs Office, dated Aug. 12, 2010); A.51 (Letter from J. Goldberger, dated Aug. 12, 2010); A.48 (Order Granting Motion for Travel, dated Dec. 18, 2009); A.53 (Letter from M. Weinberg, dated Aug. 16, 2010, at 4). Appellant has had no subsequent instances of misconduct of any kind. See A.53 (Letter from M. Weinberg, dated Aug. 16, 2010, at 1). II. Sex Offender Registration As required under Florida law in connection with his conviction for Procuring a Person Under 18 for Prostitution, Fla. Stat. § 796.03, Appellant registered as a sex offender with Florida authorities and was designated at the lowest level under that state's sex offender registration act. See A.88:6-15 (Tr.); see also A.51 (Letter from J. Goldberger, dated Aug. 12, 2010); Fla. Stat. §§ 775.21, 943.0435. Appellant also registered in his home jurisdiction of the U.S. Virgin Islands (where Appellant maintains his primary residence and actually lives), where authorities reviewed Appellant's Florida offenses and 6 EFTA00231553 determined that he is only subject to that jurisdiction's lowest reporting obligations. See A.88:1-5 (Tr.); see also 14 V.I.C. §§ 1722(b), 1724(d), (e). Although he does not actually reside in New York, before the completion of his term of Community Control, Appellant notified the New York State Division of Criminal Justice Services ("the Division") of his registerable Florida conviction and his ownership of a secondary residence in New York. See A.88:21-24 (fr.). Since May 2010, Appellant has been registered with the Sexual Offender Monitoring Unit (SOMU) of the New York Police Department. See A.88:21-89:3 ('It). III. The Board's Recommendation On or about August 26, 2010, Appellant received notice that a SORA hearing had been scheduled to determine a risk assessment level, accompanied by a copy of the recommendation of the Board. See A.67 (Letter from Supreme Court, dated Aug. 26, 2010); A.65 (Recommendation of Board of Examiners of Sex Offenders ("Board Recommendation").). In stark contrast to the other jurisdictions to have considered Appellant's Florida convictions (including Florida), the Board recommended that Appellant be assigned the highest risk level -- EFTA00231554 Level 3, representing a high risk of repeat offense -- without further designation.3 See A.67 (Letter from Supreme Court, dated Aug. 26, 2010); A.65 (Board Recommendation); see also Correction Law § 168- 1(6)(c). The Board's recommendation included a Risk Assessment Instrument (RAI) that improperly calculated a total risk factor score of 130. See A.65 (Board Recommendation). Almost all of the points scored by the Board were based on "Current Offense" factors,4 including: 10 points for "Use of Violence" (forcible compulsion); 25 points for "Sexual Contact with Victim" (sexual intercourse and deviate sexual intercourse); 30 points for "Number of Victims" (3 or more); 20 points for "Duration of Offense Conduct with Victim" (continuing course of sexual misconduct); and 20 points for "Age of Victim" (11 through 16). See A.65 (Board Recommendation). The Board's RAI did not assign Appellant 3 SORA requires the Board to recommend an offender's notification level of 1, 2, or 3, pursuant to Correction Law § 108-1(0), mid L iewnnaend whether any designations defined in Correction Law § 168-a(7) apply. See Correction Law §§ 168-k(2), 168-n(2). 4 The Board also assessed Appellant 5 points for "Criminal History," even though the Board itself noted that it was assessing points "absent specific information." See A.65 (Board Recommendation). Appellant submits that this scoring is unsupported by the Record. 8 EFTA00231555 any points under the "Post-Offense Behavior" and "Release Environment" categories. See A.65 (Board Recommendation). In its "Case Summary," the Board noted that Appellant was convicted of just two Florida sex offenses: (1) Procuring a Person Under 18 for Prostitution, and (2) Felony Solicitation of Prostitution.6 See A.65 (Board Recommendation). The Board then aggregated into just over a single page a host of uncharged allegations made by "numerous females," including "female participants [who] were age 18 or older," regarding "massages and unlawful sexual activity" that allegedly took place at Appellant's Florida residence. See A.65 (Board Recommendation). The case summary referred to "vaginal intercourse" and various other forms of sexual contact allegedly taking place without connecting specific females to such allegations, and more significantly, without identifying the age of the participants -- some of whom the Board noted were "age 18 or older" -- specifically at the time of such 6 Only one of these charges -- the procurement charge -- is registerable under SORA, and that charge is registerable under SORA only because it is registerable in Florida. See Coned-Iva Law § 1C8 a(2)(aably r the-New-Yerk.-cognate_of___ this offense, Promoting Prostitution in the Third Degree, N.Y. Penal Law § 230.25, is not itself a registerable offense under SORA. See Correction Law § 168.a(2).) The charge of Felony Solicitation of Prostitution, Fla. Stat. § 796.07(2)(f), (4)(c) -- which does not include any age-related elements and pertains solely to consensual, commercial conduct -- is not a registerable offense under either Florida or New York law. See Fla. Stat. § 943.0435; Correction Law § 168-a(2)(a). 9 EFTA00231556 I alleged conduct. See A.65 (Board Recommendation). Although Appellant was only convicted of two prostitution-related offenses and was neither charged with nor convicted of any rape, sexual abuse, or violent offenses,6 the case summary highlighted hearsay-based claims in police paperwork -- namely a probable cause affidavit signed by a Palm Beach Police detective that did not result in any of the charges sought -- involving alleged sexual abuse of underage girls and an alleged forcible rape (which claims were found by the Florida prosecutors to be unreliable to support charges against Appellant), and assessed points against Appellant based on these unprosecuted allegations. See A.65 (Board Recommendation). The Board recognized Appellant's conduct on Community Control as satisfactory and noted that he has no history of substance abuse. See A.65 (Board Recommendation). The Board also credited Appellant with accepting responsibility for his actions. See A.65 (Board Recommendation). 6 The only registerable charge for which Appellant was prosecuted and convicted pertained to consensual, commercial, non-violent interaction with one woman, A.D., who was 17 years old (and therefore over the age of consent in New York but not in Florida) at the time of the relevant conduct. See A.31 (Information for Procuring Person Under 18 for Prostitution, dated June 26, 2008); A.53 (Letter of M. Weinberg of Aug. 16, 2010, at 1, 3); A.91:20-92:7 (Pr.). 10 EFTA00231557 IV. Pre-Hearing Investigation By the District Attorney The SORA hearing, originally scheduled for September 15, 2010, was adjourned on consent of the parties until January 18, 2011 to provide the New York District Attorney ("the People"), which represented the State of New York at the SORA hearing, an opportunity to investigate Appellant's Florida convictions and assess the validity of the Board's recommendation. See A.81 (Handwritten Notations on Court Jacket); A.89:22-90:8 (Tr.). As part of their investigation, the People were in contact with members of the Palm Beach County State's Attorney's Office to understand the investigation and prosecution of the allegations at issue in this SORA matter. See A.83:14-84:19 (Tr.). Based on these interactions with Florida prosecutors, the People determined that they could not rely on the Board's recommendation and the underlying probable cause affidavit (which the Florida prosecutors determined not to be reliable, and which therefore certainly could not satisfy the heightened standard of clear and convincing evidence), and would score Appellant based only on the conduct for which he was actually prosecuted, and not on the 11 EFTA00231558 unprosecuted allegations in the probable cause affidavit cited by the Board. See A.83:14-84:19 (Tr.). Although the People presented Appellant a new SORA risk assessment instrument (RAI) immediately before the SORA hearing itself, scoring Appellant as a Level 1, the People apparently did not present their proposed alternative RAI or any other written submission setting forth their departure from the Board's recommendation to the Court, as no such statement is in the Court's file. See Appendix generally. I. SORA Hearing On January 18, 2011, a SORA hearing was conducted in New York Supreme Court, Criminal Term, New York County, Part 66 before Hon. Ruth Pickholz. See A.81 (Handwritten Notations on Court Jacket); A.82 (Tr. generally). At the hearing, the People made a record that based on their investigation and contact with the Florida authorities who handled Appellant's prosecution, the probable cause affidavit underlying the Board's recommendation could not be relied upon. See A.83:14-18 (Tr.). Specifically, the People informed the Court that many of the women referenced as complainants in the police 12 EFTA00231559 affidavit were not cooperative with Florida prosecutors, and accordingly, the Florida authorities chose not to prosecute any allegations other than those reflected by the two offenses to which Appellant ultimately pleaded guilty. See A.84:2-6, 14-19 (Tr.). The People further noted that in light of Florida's decision not to prosecute the majority of the allegations in the affidavit, (and under the SORA statute and guidelines), only the conduct pertaining to the sole registerable crime for which Appellant was charged and to which he pleaded -- Procuring a Person Under 18 for Prostitution, involving a single complainant -- could be proven and should be considered in evaluating Appellant's SORA score. See A.85:11-16, 85:24-86:1 (Tr.). Counsel for Appellant corroborated the record made by the People that the Florida Assistant State Attorney who prosecuted Appellant determined, after a full investigation, that there were "no victims" and that the only crime that could be presented to the grand jury was the single solicitation offense to which Appellant pleaded guilty. See A 89.22-90:21. 95:12-18 (Tr.). Appellant disputed many of the allegations contained in the Board's case summary, both with respect to specific facts (such as the suggestion of any forcible compulsion and the 13 EFTA00231560 exact age of complainant A.D. at the time of specific conduct) and more broadly by noting that the Board's recommendation was based on police documentation that was not credible and that contained hearsay allegations that the lead sex crimes prosecutor in Florida decided not to prosecute. See A.90:9.12, 92:13-21, 95:12-18 (Tr.). Further, Appellant advised the Court that there was sworn testimony from many of the women referenced in the police paperwork and the Board's case summary which expressly disclaimed allegations attributed to them. See A.95:19-23 (Tr.). Notwithstanding the clear record that facts underlying the Board's recommendation were disputed, the Court announced that it was relying on the Board's case summary and adopting the Board's calculation and recommendation in full. See A.93:21, 94:6-95:9 (Tr.). The Court did not conduct any factual hearing as to specific claims for which points were assessed. See A.82 (Fr. generally). The Court scored Appellant for factors such as number of victims, use of violence / forcible compulsion, duration of offense, and sexual intercourse, based on allegations that the People -- as the party bearing the burden of proof -- asserted on the record could not be supported by clear and convincing 14 EFTA00231561 evidence. See A.94:7-95:9 (Tr.). Despite the legal and factual position of the People that the Board's recommendation could not be relied on and that allegations concerning all complainants but the one in the Information could not be proven, the Court ruled that it was relying on the Board's recommendation in full and adjudicating Appellant a Level 3 sex offender with no additional designation. See A.93:21, 93:25-94:3 CPO. On the record, the Court recited the scoring of the Board in abbreviated form, without identifying any particular facts or allegations to support each factor. See A.94:6-95:9 (Fr.). In its written Order, the Court indicated a final risk level determination of Level 3 by merely circling a pre-printed form. See A.4 (Order Appealed From, dated Jan. 18, 2011). The Court failed to articulate any findings of fact or conclusions of law, as required under SORA. See A.4 (Order Appealed From, dated Jan. 18, 2011); A.82 (Tr. generally). Appellant was served with a copy of the Court's Order on or about January 1 ik 2011. See A.78 (Letter from Supreme Court, dated Jan. 19, 2011). Appellant served a Notice of Entry of the Court's Order on February 9, 2011, and on the same day filed a Notice of Appeal to 15 EFTA00231562 invoke this Court's jurisdiction. See A.4 (Order of Appealed From, dated Jan. 18, 2011, with Notice of Entry); A.3 (Appellant's Notice of Appeal, dated Feb. 9, 2011). Appellant now respectfully files this appeal as of right, pursuant to Correction Law §§ 168-k(2), 168-n(2) and CPLR 5513, 5515, to vacate the legally erroneous and factually unsupportable Order and re-calculate Appellant's SORA risk level based solely on those factors that may properly be considered under SORA and that have been proven by clear and convincing evidence.? ARGUMENT The Court's reliance on allegations that were flatly rejected by the Florida prosecutors who investigated them and which, by the People's own admission, could not be proven by clear and convincing evidence, constitutes clear legal error and a violation of Appellant's due process rights, warranting vacatur of the Court's Order. Specifically, the Court calculated a risk assessment score based on untrustworthy double and 7 Appellant asks this Court to render its own findings of fact and conclusions of law •• absiguing a zibk Level 1 bayed nri An ApprnpriSitArt consideration of the undisputed facts in the Record proven by clear and convincing evidence concerning Appellant's conviction. To the extent this Court is unable to issue findings of fact and conclusions of law based on the present Record, Appellant seeks remand to the lower court before a different Justice for a recalculation in which the parties are afforded an opportunity to present evidence regarding contested relevant issues, if necessary. See Section II(B), infra. 16 EFTA00231563 triple hearsay allegations cited in the Board's recommendation that were squarely rejected as a basis for state prosecution in Florida, were disputed by Appellant, and did not constitute registerable conduct under New York law, all in violation of SORA and its guidelines and Appellant's constitutionally guaranteed right to due process. Moreover, the Court abused its discretion and failed to abide by the guidelines and mandates set forth in SORA, including by improperly considering factors outside the record and issuing a legally deficient Order that fails to set forth the findings of fact and conclusions of law on which the Court's determination was based. I. THE COURT'S LEVEL 3 DETERMINATION IS NOT SUPPORTED BY CLEAR AND CONVINCING EVIDENCE AS REQUIRED BY SORA AND AS A MATTER OF FEDERAL CONSTITUTIONAL LAW. The SORA statute sets forth a formal procedure to determine the required level of notification for those individuals convicted of a qualifying out-of-state offense,8 based on a systematic assessment of the risk of reoffense posed by the particular individual. See Correction Law § 168-k. After t e ar genera 8 Appellant's Florida conviction for Procuring a Person Under 18 for Prostitution is a qualifying "sex offense" under SORA solely pursuant to Correction Law § 168-a(2)(d)(ii), which makes an out-of-state offense registerable under SORA if that particular offense is registerable in the jurisdiction where it was committed. 17 EFTA00231564 its review of the out-of-state offense and other factors, the Court has the duty of conducting a hearing to consider the Board's recommendation and other evidence presented in order to reach its own independent determination of an offender's SORA registration level. See Correction Law §§ 168-k(2), 168-n(2); People v. Johnson, 11 N.Y.3d 416, 421 (2008) (holding that "the Board's duty is to make a recommendation to the sentencing court... and the court, applying a clear and convincing evidence standard, is to make its determination after considering that recommendation, and any other materials properly before it") (internal statutory citation omitted); see also New York State Bd. of Sex Exam'rs v. Ransom, 249 A.D.2d 891, 891-92 (4th Dep't 1998) (holding the "Board ... serves only in an advisory capacity ... similar to the role served by a probation department in submitting a sentencing recommendation."); see also People v. Jimenez, 178 Misc. 2d 319, 322-23, 679 N.Y.S.2d 510, 513 (Sup. Ct. Kings Cty. 1998) (observing "the Legislature did not intend to place upon the criminal courts of this State a burden to act merely as a regulatory body to confirm the determination of the Board," and noting that a SORA hearing is a "judicial proceeding in which the court must make a de novo determination."). Yet the Court's authority 18 EFTA00231565 to determine a SORA risk level is not unfettered; instead, SORA requires the Court to determine an offender's risk level based on an evaluation of evidence in accordance with the guidelines promulgated by the Board. See Correction Law §§ 168-k(2), 168-n(2) ("It shall be the duty of the court applying the guidelines established [by the Board under SORA] to determine the level of notification...."). Moreover, the Court's determination must be wholly based on facts that are provable by clear and convincing evidence. See Correction Law §§ 168-k(2), 168- n(2). Under New York law, "clear and convincing evidence" is defined as evidence that makes it "'highly probable' that the alleged activity actually occurred." People v. Dominie, 42 A.D.3d 589, 590 (3d Dep't 2007); see also Prince, Richardson on Evidence § 3-205, at 104 (Farrell 11th ed.). Clear and convincing evidence is "a higher, more demanding standard" than the preponderance standard, Rossi v. Hartford Fire Ins. Co., 103 A.D.2d 771, 771 (2d Dep't 1984), in that it is evidence "that is neither equivocal nor open to opposing presumptions." Solomon v. State of New York, 146 A.D.2d 439, 440 (1st Dep't 1989). Under SORA, the "burden of proving the facts supporting the determinations sought by 19 EFTA00231566 clear and convincing evidence" is assigned to the District Attorney, which represents the State in the proceeding. Correction Law i§ 168- k(2), 168-n(2). In the instant case, the Court did not conduct its own inquiry of relevant facts to determine Appellant's risk level in accordance with the SORA guidelines. Instead, as described further below, the Court improperly adopted a Board recommendation that had been rejected by both the People and Appellant as unreliable. Without any meaningful consideration of other evidence, the Court made its risk assessment determination based on allegations that did not -- and indeed could not, as a matter of law -- constitute clear and convincing evidence. Such a determination was made in contravention of SORA and its guidelines and violated Appellant's federal due process rights under the U.S. Constitution. For these reasons, the Court's determination should be vacated. A. The People's Investigation Revealed That The Board's Recommendation Could Not Be Proven By Clear and Convincing Evidence. The People began the SORA hearing by advising the Court that their own investigation and communications with the Florida State 20 EFTA00231567 Attorney's Office that handled Appellant's case revealed that the majority of allegations in the Board's recommendation (and in the police affidavit on which the recommendation was based9) were not prosecuted by Florida authorities and could not be proven by other evidence. See A.83:14-84:19 (Tr.). In relevant part, the People made the following record: I tried to reach -- I reached the authorities in Florida to try to see if they had all the interview notes or other things that we can then subsequently rely on that might be considered clear and convincing evidence, if they had interviewed these women on their own, and they never did. No one was cooperative and they did not go forward on any of the cases and none of them were indicted. So I don't know. A.85:19-86:1 (Tr.). As explained by the People, Appellant's Florida case was not one where a host of allegations were encompassed within a plea deal, but rather, the only charges that were determined to be It bears noting that the police affidavit upon which the Board based its case summary and recommendation appears not even to have been drafted to sustain charges against Appellant, but instead, recited numerous allegations based on double and triple hearsay directed toward filing charges against a defendant named . See AM (Palm Beach Police Department Probable Cause Affidavit of ornwo the Florida State Attorney iitly rejected the claims asserted in the police affidavit (which sought to charge as an accomplice to Appellant) by determining that there was not sufficient probable cause and not charging Appellant with the serious second-degree felony offenses which the affidavit sought to support, to wit, Unlawful Sexual Activity with a Minor, Fla. Stat. § 794.05(1), and Lewd and Lascivious Molestation, Fla. Stat. § 800.04(5). 21 EFTA00231568 prosecutable were the charges for which Appellant was ultimately convicted: So it is unlike a situation where everything was indicted and then we get to sort of assess points for all of the victims, if it was part of a plea bargain. They did not actually choose to go forward on any except for the one victim. A.84:2-6 (Tr.). Given this history, the People advised the Court that it should depart from the Board's recommendation, both as a matter of fact and as a matter of law, in accordance with the SORA guidelines. See A.88:14-84:19, 85:11-16, 87:10-12 (Pr.). The SORA guidelines are intended to provide clear guidance to the Court and the parties with respect to how various potential risk factors should be evaluated, including allegations that have not been prosecuted. While, in general, conduct not directly encompassed by the crime of conviction may be considered in scoring for given factors on the RAI, the SORA guidelines deem, "Points should not be assessed for a factor... unless there is clear and convincing evidence of the existence of that factor." Sex Offender Registration Act: Risk Assessment Guidelines and Commentary, Commentary (2006), at 5, ¶ 7 (emphasis added). Indeed, in deciding how to evaluate allegations outside of the crime of 22 EFTA00231569 conviction, the SORA guidelines expressly caution, "the fact that an offender was arrested or indicted for an offense is not, by itself, evidence that the offense occurred." Sex Offender Registration Act: Risk Assessment Guidelines and Commentary, Commentary (2006), at 5, ¶ 7. More to the point here, the guidelines emphasize, "[T]he fact that an offender was not indicted for an offense may be strong evidence that the offense did not occur," amplified with a relevant example: For example, where a defendant is indicted for rape in the first degree on the theory that his victim was less than 11 [years old], but not on the theory that he used forcible compulsion, the Board or court should be reluctant to conclude that the offender's conduct involved forcible compulsion. Sex Offender Registration Act: Risk Assessment Guidelines and Commentary, Commentary (2006), at 5, ¶ 7 (emphasis in original, internal statutory citations omitted ).t0 In other words, SORA and its guidelines clearly prescribe that where allegations were reported to and investigated by law enforcement but not prosecuted (and not encompassed within a broader plea w Of note, at one point during the SORA proceeding, the Court seemingly dismissed out of hand the SORA guidelines concerning uncharged allegations. See A.84:7-13 (Tr.) (Court expressing skepticism toward the Board's guidelines that "if somebody is not indicted it is strong evidence that it did not occur."). 23 EFTA00231570 bargain), they should not be scored on the RAI or factored into a risk determination in the absence of other evidence to corroborate their validity. See Sex Offender Registration Act: Risk Assessment Guidelines and Commentary, Commentary (2006), at 5, ¶ 7; see also People v. Smith, 66 A.D.3d 981, 983 (2d Dep't 2009) (holding that defendant's alleged use of knife was not proven by clear and convincing evidence and could not be scored against defendant in SORA hearing where testimony about use of knife was presented to grand jury but grand jury did not indict on weapons charge); People v. Coffey, 45 A.D.3d 658 (2d Dep't 2007) (holding that it was improper for court to consider allegations concerning a charge that was dismissed in evaluating defendant's SORA risk level); People v. Arotin, 19 A.D.3d 845 (3d Dep't 2005) (holding that defendant could not be scored under SORA for deviate sexual intercourse where defendant was not indicted for such an offense and the only evidence of such conduct came from triple hearsay in a police report used by the Board). Significantly, here, the People did not merely apply the SORA guideline suggesting that uncharged allegations may not be reliable evidence of an offense. Instead, the People had actual information from 24 EFTA00231571 the Florida State Attorney's Office that the complainants referenced by the Board in connection with uncharged claims were not cooperative with authorities, prompting the Florida State Attorney's Office to decide not to pursue charges in connection with those unsupported allegations. See A.84:14-19, 85:19-86:1, 86:10-12 (Tr.). Moreover, the People acknowledged that they had no corroborating materials -- such as interview notes, sworn statements, or affidavits -- which would permit them to meet their burden of proving disputed allegations by clear and convincing evidence. See A.84:14-19, 85:19-86:1, 86:10-12 (Fr.). As a result, the People advanced the position that the law compelled they take -- advising the Court that the Board's recommendation was wrong and that a Level 3 determination was not supported by the provable evidence. B. The Court Improperly Relied on the Board's Recommendation Where the Facts Cited Therein Were Disputed and No Further Evidence Was Presented. Notwithstanding the reasoned, evidence-based disavowal by the People of the Board's recommendation (based on the People's communications with the Florida prosecutor), the SORA Court relied wholesale upon the Board's recommendation. See A.93:21, 94:6-95:9 25 EFTA00231572 (Tr.). The Court improperly overlooked the burden of proof statutorily imposed on the People and its own duty to evaluate the evidence, and adopted the Board's recommendation, seemingly as a per se matter. See A.85:11-18 (Tr.) (the Court opining, without factual basis, that the Board "obviously took [their own guidelines] into consideration" when assessing points for uncharged conduct). Indeed, although the Court cited no specific information to suggest that the Board itself communicated with Florida prosecutors in preparing the case summary, the Court attempted to justify its blind reliance on the Board's recommendation by stating, "I feel the board looked into all of this, made their recommendation, found him to have 130 points and I see no reason to disturb that." A.96:11-13 (Tr.). While the Court of Appeals has recognized that a Board-generated case summary may constitute "reliable hearsay" upon which the Court may base a SORA risk calculation, the law is equally clear that a Board's case summary is not per se reliable, particularly in the face of rnnntervailing evidence. See People v. Mingo, 12 N.Y.3d 563, 572-73, (2009) ("Of course, information found in a case summary ... need not always be credited -- it may be rejected when it is unduly speculative or 26 EFTA00231573 its accuracy is undermined by other more compelling evidence'); see also People v. Mabee, 69 A.D.3d 820 (2d Dep't 2010) (finding Board's case summary did not constitute clear and convincing evidence to support scoring under SORA where it provided only very limited information pertaining to the particular factor). Indeed, information contained in a Board's case summary does not by itself clear the hurdle of "clear and convincing evidence" -- a higher standard than mere "reliable evidence" -- where the offender disputes the relevant contents of that evidence. See People v. Judson, 50 A.D.3d 1242 (3d Dep't 2008) (holding that case summary alone could not satisfy state's burden of proving factors by clear and convincing evidence to support level 3 determination where defendant contested certain factual allegations related to those factors); cf. People v. Wasley, 73 A.D.3d 1400, 1401 (3d Dep't 2010) (holding "evidence included in the case summary may provide clear and convincing evidence in determining a defendant's risk assessment level where defendant did not dispute its contents insofar as relevant.") (emphasis added); People v. Curthoys, 77 A.D.3d 1215, 1216 (3d Dep't 2010) (noting that the "uncontested contents of a case summary can satisfy the People's burden of demonstrating . . . clear and convincing 27 EFTA00231574 evidence") (emphasis added). Thus, it certainly follows that a Board's case summary cannot, as a matter of law, constitute the sole requisite "clear and convincing evidence" required to support a SORA determination where the People, as the party representing the Board, also expressly disclaim the reliability of that case summary. Here, the Board's case summary was based almost entirely on double and triple hearsay allegations described in an affidavit submitted by police to the Florida prosecutor. See A.65 (Board Recommendation); A.6 (Palm Beach Police Department - Probable Cause Affidavit of u , dated May 1, 2006). The allegations, even when aggregated, were not deemed by the Florida prosecutor who reviewed them to constitute sufficient "probable cause" to warrant the return of a complaint, information, or indictment as to any of the charges that the affidavit sought." And, of course, because the requested charges were never brought, no court ever reviewed or authorized the affidavit's allegations to make a judicial finding of "probable cause" as to any such allegations. Even had the Florida u Although the affidavit considered by the Board was submitted with respect to a defendant other than Appellant, it appears that the allegations in the affidavit were intended to establish probable cause to charge Appellant with Unlawful Sexual Activity with a Minor, Fla. Stat. § 794.05(1), and Lewd and Lascivious Molestation, Fla. Stat. § 800.04(5) -- charges that were never brought. 28 EFTA00231575 prosecutor decided to arrest and charge Appellant based on allegations contained in the affidavit, the mere fact of an arrest or charge is not sufficiently trustworthy by itself to support the assessment of points against Appellant under SORA. See Sex Offender Registration Act: Risk Assessment Guidelines and Commentary, Commentary (2006), at 5, ¶ 7 ("the fact that an offender was arrested or indicted for an offense is not, by itself, evidence that the offense occurred"). Such allegations cannot be deemed reliable -- never mind satisfying the elevated standard of clear and convincing evidence -- where, as here, the People had specific information from the Florida prosecutor that Florida made the decision not to pursue such charges based precisely on the insufficiency of the evidence. See A.83:23-84:19, 85:19-86:1 (Tr.). In short, the People directly disputed the reliability of the Board's case summary and recommendation, based on information that was not before the Board following communications with the Florida prosecutor. See A.83:14-84:19, 85:11-87:12 (Tr.); see also A.65 (Board Recommendation) (noting that Board's assessment was based on review of "inmate's file" and not citing specific contact with Florida authorities). Appellant also disputed the validity of many of the 29 EFTA00231576 allegations contained therein, both generally and with regard to specific allegations. See A. 90:942, 92:13-21, 95:12-18 (Tr.). Notwithstanding the obvious existence of disputed relevant issues, the Court did not provide the parties with any opportunity to present evidence on contested issues, nor did the Court conduct any factual inquiry on its own. Even though there was no sufficient evidentiary basis to support the Board's recommendation, the Court announced that it was relying on the Board's case summary and adopting the Board's calculation and SORA determination in full. See A.93:21, 96:11-13 (Tr.). Indeed, at one point in adopting the Board's scoring, the Court openly acknowledged that it was assessing points against Appellant in the face of the People's position that the evidence of that factor was "not reliable": Number of victims, three or more. He only plead [sic] guilty to one, but apparently there were more than one and I think the People concede that although they say it was not reliable. A.94:10-13 (Tr.). This reliance on alleged conduct that the People, as the party bearing the burden of proof, e p bly-stateel-they-eeuld-not--- prove by clear and convincing evidence, was plainly erroneous as a matter of law. See Correction Law §§ 168-k(2), 168-n(2) (stating that 30 EFTA00231577 the facts supporting the court's determination shall be supported by clear and convincing evidence). Accordingly, the Court's Level 3 determination, based specifically on unproven alleged conduct, cannot stand, and the Court's Order should be vacated.12 12 Even if the Court had a lawful evidentiary basis to adopt the Board's case summary in full (which it did not), the case summary does not establish by clear and convincing evidence all of the factors for which points were assessed against Appellant. For example, the facts alleged in the case summary, even if taken as true, do not set forth, by clear and convincing evidence, a continuing course of sexual misconduct, which requires a specific finding of either "(i) two or more acts of sexual contact, at least one of which is an act of sexual intercourse, oral sexual conduct, anal sexual conduct, or aggravated sexual contact, which acts are separated in time by at least 24 hours, or (ii) three or more acts of sexual contact over a period of at least two weeks" with an underage victim. See Sex Offender Registration Act: Risk Assessment Guidelines and Commentary, Commentary (2006), at 10 ("Factor 4: Duration of Offense Conduct with Victim"); see also People v. Redcross, 54 A.D.3d 1116 (3d Dep't 2008) (holding that continuing course of sexual misconduct was not supported by clear and convincing evidence where record was silent as to dates that incidents of sexual conduct occurred in relation to each other); People u. Donk, 39 A.D.3d 1268, 1269 (4th Dep't 2007) (modifying SORA risk assessment where there was not clear and convincing evidence to establish continuing course of sexual misconduct under specific definition set forth by SORA); People v. Boncic, 15 Misc. 3d 1139(A), 841 N.Y.S.2d 281 (Sup. Ct. N.Y. Cty. 2007) (holding that there must be a finding of "actual sexual contact" with the underage victim to score for the continuing course of conduct factor under SORA). Here, the case summary only speaks of certain allegations generally and provides no detail regarding the timing of specific alleged acts of sexual contact, the number of times Appellant allegedly engaged in specific acts with individual complainants, or the age of the complainants at the time of the relevant acts. Similarly, the case ther factors for which points were assessed against Appellant, including the "use of violence" (e.g. case summary provides only conclusory allegations of "forcible rape" without establishing the element of "forcible compulsion"); "sexual contact with victim" (e.g. case summary does not specify the age of each complainant at the time of alleged relevant sexual contact to determine whether each complainant was underage and therefore a "victim"); "number of victims" (same); and "age of victim" (same). 31 EFTA00231578 C. Determining Appellant To Be a Level 3 Offender Based on Factors That Were Not Proven by Clear and Convincing Evidence Violated Appellant's Federal Due Process Rights. In addition, the Court's assessment of points against Appellant based on allegations that were not and could not be proven by clear and convincing evidence constituted a clear violation of Appellant's federal due process rights. It is settled as a matter of federal constitutional law that those persons convicted of a sex offense and required to register under a state registration and notification scheme like SORA have a protected liberty interest that entitles them to procedural due process. See Doe v. Pataki, 3 F. Supp. 2d 456, 468 (S.D.N.Y. 1998); see also People v. David W, 95 N.Y.2d 130, 138 (2000) (holding that the imposition of a Level 3 SORA determination implicates liberty interests and triggers due process safeguards). Courts evaluating that liberty interest under the procedural due process analysis articulated by the U.S. Supreme Court in Matthews v. Eldridge, 424 U.S. 319 (1976) (balancing the private interest affected by state action, the risk of erroneous deprivation of that interest, and the interests of the state) have determined that "the nature of the [sex offender] classification proceeding is serious enough" 32 EFTA00231579 and "carries with it a high risk of error," such that the state must afford an individual facing such a risk classification a constitutionally￾mandated minimum level of due process. Doe, 3 F. Supp. 2d at 469, 471 (citing Doe v. Poritz, 142 N.J. 1, 662 A.2d 367 (1995)). While "the due process protections required for a risk level classification proceeding are not as extensive as those required in a plenary criminal or civil trial," Id. at 470, federal due process is only satisfied when a person being assessed under SORA is afforded a "pre-notification hearing accompanied by a comprehensive set of procedural safeguards," including each of the following: (1) a judicial determination of his risk level classification [by hearing]; (2) notice of the classification proceeding, sufficiently in advance of the hearing to... prepare a challenge; (3) notice of the proceeding must contain a statement of [its] purpose and the Board's recommended risk level classification; (4) an opportunity to retain counsel; (5) pre-hearing discovery; (6) the state must prove the facts supporting each risk factor by clear and convincing evidence; and (7) the right to appeal. 33 EFTA00231580 See id. at 471-72 (articulating the above seven procedures as essential to satisfy procedural due process when assigning risk levels under SORA) (emphasis added); see also People v. Brooks, 308 A.D.2d 99, 103 (2d Dep't 2003) (same). This sixth constitutional factor -- the requirement that the State bear the burden of proof and prove the facts supporting each risk factor upon which a risk assessment is based by the elevated standard of clear and convincing evidence -- is of particular significance, in that it is a recognition of the severe injurious impact upon liberty, reputation, and opportunity that an unjustified notification level can have on an offender: Because "the possible injury to the individual [registrant] is significantly greater than any possible harm to the state," the registrant, consistent with due process, cannot "be asked to share equally with society the risk of error" . . . . It necessarily follows that the Due Process Clause requires that the state prove its case by clear and convincing evidence in a Megan's Law proceeding. KB.-44-41ernier-o,-14.9a3c1407.7r 1111-(3d-Girr1997), eertreleniedr 622 U.S. 1109 (1998) (citing Addington v. Texas, 441 U.S. 418, 427 (1979)); see also Brooks, 303 A.D.2d at 105 (observing "a SORA determination 34 EFTA00231581 undeniably has a profound impact on a defendant's liberty interest due to the registration and community notification provisions"). In other words, because a SORA hearing "threaten[s] the individual involved with a significant deprivation of liberty or stigma," due process demands "more than average certainty on the part of the factfinder." E.B., 119 F.3d at 1110-11 (citing Santosky v. Kramer, 455 U.S. 745, 756- 58 (1982)). Accordingly, "registrants are entitled to have the burden of persuasion placed on the state, with the state obligated to prove the proposed level and manner of notification by clear and convincing evidence." Doe, 3 F. Supp. 2d at 471; see also David W, 95 N.Y.2d at 140 (holding "Due process requires that the State bear the burden of proving, at some meaningful time, that a defendant deserves the classification assigned."). Here, the Court's Level 3 determination, made without regard to the People's presentation and advocacy at the hearing and unsupported by clear and convincing evidence, failed to satisfy these basic constitutional requirements regarding both the allocation of the burden of persuasion (upon the People) and the standard of proof (by clear and convincing evidence) for a SORA hearing. The Court's complete 35 EFTA00231582 reliance on the unsupported, unprosecuted, and disputed hearsay allegations in the Board's case summary to buttress a Level 3 determination violated Appellant's due process rights, as set forth by Doe v. Pataki, and accordingly, the Court's Order should be reversed. II. THE COURT BASED ITS LEVEL 3 DETERMINATION UPON IMPROPER CONSIDERATIONS. In addition to basing Appellant's risk level determination on uncharged allegations that, both in fact and as a matter of law could not be proven by clear and convincing evidence, the Court improperly assessed Appellant as a Level 3 offender based on additional factors and considerations that should not have weighed into its RAI calculation. Namely, the Court improperly penalized Appellant for conduct that was not scoreable under SORA, even with respect to the complainant from his single registerable crime of conviction. In addition, the record lays bare that the Court allowed personal bias and irrelevant factors outside the record in Appellant's case to influence the Court's SOFA determination. e ou proper y sesse oin s tuns ppe lant for Conduct That Is Not Scoreable Under SORA. First, the SORA Court improperly scored Appellant for alleged conduct that is not registerable, and in some cases is not even criminal, 36 EFTA00231583 under New York law with respect to the sole complainant at issue in Appellant's single registerable Florida conviction. For example, the Court adopted the Board's assessment of points for "sexual intercourse," even though the People themselves conceded that the complainant at issue was 17 (and therefore over New York's age of consent) when she allegedly engaged in consensual intercourse with Appellant. See A.92:1-7 (Tr.). This scoring for sexual intercourse was in clear contravention to the SORA statute, which states that prostitution offenses are only registerable under SORA where there is clear and convincing evidence that the prostitute was "in fact" under 17 at the time of the alleged sexual conduct. Correction Law § 168-a(2)(a)(i).'3 Additionally, the Court appears to have scored Appellant 20 points for this same complainant under the "age of victim" factor, even though the People made a record that the complainant was "either 16 or 17' when she met Appellant for the first time. A.92:1-3 (Tr.). The fact that, even in the People's view, the specific age of the complainant when la Of rourser the_exact-allegations-for--which4he-Court-assessed-points-against Appellant are nearly impossible to identify given the Court's failure to articulate findings of fact and conclusions of law supporting its scoring of particular factors. See A.4 (Order Appealed From, dated Jan. 18, 2011); A.82 ('Fr. generally); see also Section III, infra. Nor did the Board's recommendation tie its scoring to particular facts in its case summary, which lumped a host of facts together in the aggregate. See A.65 (Board Recommendation). 37 EFTA00231584 she first met Appellant -- no less when she may have engaged in sexual conduct with him -- could not be ascertained precludes a finding that this element was proven by clear and convincing evidence. See Solomon u. State of New York, 146 A.D.2d 439, 440 (1st Dep't 1989) (defining clear and convincing evidence as evidence "that is neither equivocal nor open to opposing presumptions"). Yet the Court disregarded the burden of proof and made clear that it was scoring Appellant for this factor.14 See A.92:13-93:12 (Tr.). These improper assessments of points on the RAI should render the Court's Level 3 determination invalid. B. The Court Improperly Allowed Personal Feelings and Matters Outside the Record to Influence Its SORA Determination. Next, the Court abused its discretion by allowing an apparent personal distaste for Appellant, the nature of the crime for which he pleaded guilty and was convicted, and the quantity and nature of unproven, unprosecuted allegations cited in the Board's recommendation to impinge upon the Court's duty to follow the law. The Court demonstrated a remarkable disdain and lack of judicial 14 Again, the specific basis upon which the Court scored Appellant for certain factors cannot be ascertained from the legally deficient Order, see A.4 (Order Appealed From, dated Jan. 18, 2011), although the Court's comments at the hearing revealed the Court's belief that points should be assessed against Appellant for "procuring" this complainant when "she was either 16 or 17." See A.92:1-23 (Tr.). 38 EFTA00231585 objectivity in its response to hearing the District Attorney disavow the reliability of the Board's recommendation, in receiving the arguments of counsel for Appellant, and in rendering its Order as a whole. First, although the SORA statute clearly contemplates that the District Attorney may depart from the Board's recommendation based upon its own evaluation of the evidence,15 see Correction Law §§ 168- 16 For example, SORA expressly provides, "If the district attorney seeks a determination that differs from the recommendation submitted by the board, at least ten days prior to the determination proceeding the district attorney shall provide to the court and the sex offender a statement setting forth the determinations sought by the district attorney together with the reasons for seeking such determinations." Correction Law §§ 168-k(2), 168-n(2). While the more common application of this provision involves the People seeking a higher risk level than the Board, the provision clearly encompasses any deviation from the Board's recommendation, including the People's discretion to recommend a lower risk level. See, e.g., People v. Ferguson, 53 A.D.3d 571, 572 (2d Dep't 2008) (holding that 10- day notice requirement applies not only to changes in RAI scoring, but to changes in factual predicates for RAI scoring). Incidentally, it bears noting that the People failed to comply with these procedural mandates, constituting a further procedural flaw in these proceedings. See Correction Law §§ 168-k(2), 168-n(2). While the People provided Appellant with a written alternative RAI immediately prior to the SORA hearing -- and not ten days prior to the hearing, as required by SORA -- it appears that the People failed to submit their RAI to the Court at all. See Appendix generally. Before rejecting out of hand the People's stance that a Level 3 determination could not be supported by sufficient evidence, the Court should have adjourned the matter to receive and review a written statement of the People's recommended determination and order where defendant and court did not receive proper 10-day notice of People's revised RAI); cf. People v. Jordan, 31 A.D.3d 1196, 1196 (4th Dep't 2006) (holding People's failure to provide sufficient notice of revised RAI was cured where Court adjourned matter to allow meaningful opportunity to consider revised RAI). The Court's failure to enforce the procedural mandates of the SORA statute was prejudicial to Appellant, in that the Court did not have sufficient opportunity to 39 EFTA00231586 k(2), 168-n(2), here, the Court rejected the investigation and advocacy of the People. Indeed, the Court went so far as to express "shock" that the People would support a lower risk level determination than that recommended by the Board, almost as a matter of principle. See A.86:9 (Tr.). The Court disregarded the detailed evidentiary investigation and careful parsing of allegations that the People undertook in evaluating the Board's recommendation. Ignoring the record at issue concerning Appellant and the evidence pertaining to him, the Court focused instead on the irrelevant facts of some unidentified case completely unrelated to Appellant's: I have to tell you, I am a little overwhelmed because I have never seen the prosecutor's office do anything like this. I have never seen it. I had a case with one instance it was a marine who went to a bar, and I wish I had the case before me, but he went to a bar and a 17 year old, he was an adult obviously, he was a Marine, a 17 year old came up to him and one thing lead [sic] to another and he had sex with her and the People would not agree to a downward modification on that. understand the compelling reasons for the alternative RAI calculation that the People promoted. See id. 40 EFTA00231587 So I am a little overwhelmed here because I see -- I mean I read everything here, I am just a little overwhelmed that the People are making this application. I could cite many many, I have done many SORAs much less troubling than this one where the People would never make a downward departure like this.16 A.84:21-85:10 (Tr.). Later, when Appellant's counsel disputed that there were any credible -- much less prosecuted -- allegations that Appellant ever used force, the Court again began comparing Appellant's case to the same irrelevant case about "a marine" -- a matter completely unknown to Appellant and having no connection whatsoever to Appellant's case -- seemingly to suggest that Appellant should nevertheless be scored as Level 3 under SORA: There was no allegation of force in the marine either, who met a girl in a bar, a young girl 17, there was no force there. 16 Notably, the People were not asking the Court to make a downward departure from the RAI calculation, but were advising the Court that the evidence required a recalculation of Appellant's risk level based on the RAI factors. See Sex Offender Registration Act: Risk Assessment Guidelines and Commentary, Commentary (2006) at 4-5, ¶¶ 5, 6. 41 EFTA00231588 A.90:13-15 (Tr.).17 The Court's subjective comparison of Appellant's case to some unidentified, unrelated case was improper and highly irregular, and it clearly interfered with the Court's duty to make an assessment based on the law. Similarly, in response to an argument by counsel regarding the implications that a Level 3 assignment would have on Appellant, who does not actually reside in New York, the Court abandoned any semblance of judicial objectivity by dismissively suggesting that he should "give up his New York home if he does not want to come every 90 days." A.93:18-19 (Pr.). Rather than giving reasoned consideration to whether Appellant's residence outside of New York might be a relevant factor in its overall risk assessment (such as for a downward departure from an RAI calculation), the Court improperly allowed its judgment to be clouded by apparent personal disdain for Appellant. Furthermore, the Court's apparent distaste for Appellant has eliminated any likelihood that Appellant will receive a fair redetermination hearing should this matter be remanded back to the '7 Significantly, the Court in fact scored 10 points against Appellant for forcible compulsion, despite the parties' agreement that there was no legitimate evidentiary basis to score Appellant for the use of force or violence. See A.94:7-8 ('Fr.). 42 EFTA00231589 same Justice. Indeed, this Court has recognized that reassignment of a matter to a different Justice following appeal is warranted and appropriate where the apparent impartiality of the lower court has been legitimately questioned, as it most certainly has here. See, e.g., People v. Rampino, 55 A.D.3d 348, 349 (1st Dep't 2008) (remanding resentencing matter to a different Justice where the "appearance of fairness and impartiality [was] compromised by the actions of the Justice to whom defendant's application was assigned"); Fresh Del Monte Produce N.V. v. Eastbrook Caribe, 40 A.D.3d 415, 421 (1st Dep't 2007) (remanding matter to a different Justice where "a reasonable concern about the appearance of impartiality" had been raised on appeal). Accordingly, should this Court deem remand the only appropriate mechanism for recalculating Appellant's risk assessment level, Appellant respectfully asks that the SORA proceeding be reassigned to a different Justice. In sum, a court only has discretion to go beyond the factors outlined in the SORA guidelines in evaluating a person's risk level where justified by clear and convincing evidence. See People v. Sherard, 73 A.D.3d 537, 537 (1st Dep't 2010) (citing People v. Miller, 854 N.Y.2d 43 EFTA00231590 138 (2008), lv. denied 10 N.Y.3d 711, 860 N.Y.S.2d 483 (2008)) (holding that where a court exercises discretion to depart from the evidence￾based scoring of an RAI, the court must base such departure on "clear and convincing evidence of aggravating factors to a degree not taken into account" in the RAI); see also Sex Offender Registration Act: Risk Assessment Guidelines and Commentary, Commentary (2006) at 4-5, ¶¶ 5, 6. Here, the Court's SORA determination, made in the express absence of clear and convincing evidence, 18 constituted an abuse of discretion, warranting reversal of the Court's Level 3 determination and Order. Moreover, given the Court's demonstrated lack of judicial objectivity toward Appellant, should remand be required, Appellant respectfully requests that this matter be reassigned to a different Justice in the Supreme Court. le The Court did not -- and could not -- cite any factors within or outside of the Revnyl's ennsirieratinn, prriven by Clear and convincing evitionen, flint would justify .a Level 3 determination under RAI scoring or constitute lawful grounds for an upward departure. See A.82 (Tr. generally). Instead, the Court fully adopted the Board's calculation, scoring Appellant a presumptive rating of Level 3, without meaningful inquiry into any of the underlying allegations or any consideration of other evidence which could bear upon Appellant's risk level. See A.93:21, 94:6-95:9, 96:11.13 (Tr.). 44 EFTA00231591 III. THE COURTS ORDER DOES NOT COMPLY WITH THE MANDATES OF SORA AND CONSTITUTIONAL DUE PROCESS AND MUST BE VACATED. Finally, the Court's Order determining Appellant to be a Level 3 sex offender is itself facially defective in numerous regards and should be vacated as legally invalid. In addition, the Court's failure to set forth any factual basis for its Level 3 determination renders the Order constitutionally infirm, warranting reversal on federal due process grounds as well. SORA provides that it is the "duty of the court" to determine, pursuant to the SORA guidelines, both the "level of notification" required of an offender and whether any designations defined in section 168-a(7) apply. Correction Law §§ 168-k(2), 168-n(2). In addition, SORA mandates that the court "render an order" which sets forth "its determinations and the findings of fact and conclusions of law on which the determinations are based." Correction Law §§ 168-k, 168-n. Here, the Court's compliance with these requirements fell woefully short. The only order issued by the Court in this matter was a standard boilerplate form where the Court circled a pre-printed number and provided a signature and date. See A.4 (Order Appealed From, 45 EFTA00231592 dated Jan. 18, 2011). Indeed, upon close examination of the only "order" in this matter, it appears that the form Order is actually intended to be a cover sheet to accompany a more formal order, with written findings of fact and conclusions of law, upon submission to the Division. See A.4 (Order Appealed From, dated Jan. 18, 2011) (stating, "A copy of the order setting forth the risk level and designation determinations, and the findings and conclusions of law on which such determinations are based, shall be submitted to the Division of Criminal Justice Services' Sex Offender Registry Unit by the Court. In addition, please complete and attach this form indicating the offender's risk level and designation to the Court's order."). Yet this legally insufficient Order was served on Appellant following the SORA proceeding and was sent to the Division so that the Level 3 determination could be executed and enforced. See A.78 (Letter of Supreme Court, dated Jan. 19, 2011). The appellate courts have consistently held that cursory, non￾specific "findings" issued after SORA hearings -- including the wholesale adoption of a Board recommendation or recitation of RAI factors without further explanation, as the Court offered here -- are 46 EFTA00231593 legally insufficient under SORA. See, e.g. People v. Strong, 77 A.D.3d 717, 717-18 (2d Dep't 2010) (reversing SORA order issued without findings of fact and conclusions of law, where court relied on RAI but failed to introduce the RAI in evidence or indicate any evidence relied upon); People v. Gilbert, 78 A.D.3d 1584, 1584 (4th Dep't 2010) (holding that the SORA court's conclusory recitation that it reviewed the parties' submissions and was adopting the Board's case summary and recommendation was insufficient to fulfill SORA's statutory mandate); People v. Miranda, 24 A.D.3d 909, 910-11 (3d Dep't 2005) (holding that the court's adoption of the Board's RAI scores and "generic listing of factors" failed to "fulfill the statutory mandate" of SORA and precluded "meaningful appellate review of the propriety of the court's risk level assessment"). In addition, the Order in this case is constitutionally deficient, in that the Court's failure to set forth any factual or legal bases for its Level 3 determination falls short of the minimum due process rights guaranteed by the U.S. Constitution. In the landmark case of Goldberg v. Kelly, the U.S. Supreme Court held that, in relevant part, to demonstrate compliance with the procedural due process requirement 47 EFTA00231594 that the decision maker's conclusion rest solely on the legal rules and evidence adduced at hearing, "[the] decision maker should state reasons for his determination and indicate evidence he relied on, though his statement need not amount to a full opinion or even formal fmdings of fact and conclusions of law." Goldberg v. Kelly, 397 U.S. 254, 271 (1970) (internal citations omitted).19 In short, the minimal due process requirement that the order set forth the basis for the court's determination is designed to provide some assurance that the court's conclusion rested on sufficient reliable evidence--which in Appellant's case, it did not. The utterly deficient Order issued by the Court in this matter itself provides an independent basis for reversal of the Court's Level 3 determination, on both state statutory and federal constitutional grounds. 19 SORA, by specifically requiring the Court to issue findings of fact and conclusions of law to support its determination, therefore sets forth a higher standard than is required by federal due process. See Correction Law if 168-k, 168- n (requiring the court to "render an order setting forth its determinations and the findings of fact and conclusions of law on which the determinations are based"). 48 EFTA00231595 CONCLUSION For the reasons stated herein, Appellant Jeffrey E. Epstein respectfully submits that the January 18, 2011 Order of the New York Supreme Court determining Appellant Jeffrey E. Epstein to be a Level 3 sex offender, without designation, should be vacated, and Appellant's SORA level should be recalculated -- either by this Court based on the present record or upon remand to a different Justice in the lower court -- in accordance with the law, based solely on the evidence that can be proven by clear and convincing evidence, to wit, the undisputed conduct encompassed by Appellant's registerable crime of conviction. February 22, 2011 Respectfully submitted, Sandra nn Musumeci kland.com KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022 Telephone: Facsimile: Counsel for Defendant-Appellant Jeffrey E. Epstein EFTA00231596 PRINTING SPECIFICATION STATEMENT This computer generated brief was prepared using a proportionally spaced typeface. Name of Typeface: Century Schoolbook Point Size: 14-point type Line Spacing: Double-spaced The total number of words in the brief, inclusive of point headings and footnotes and exclusive of pages containing the table of contents, table of authorities, and printing specification statement is 10,522. 50 EFTA00231597 CERTIFICATE OF DIGITAL-SUBMISSION COMPLIANCE The undersigned hereby certifies that: (1) all required privacy redactions have been made and, with the exception of those redactions, every document submitted in Digital Form or scanned PDF format is an exact copy of the written document filed with the Clerk; and (2) the digital submissions have been scanned for viruses with the most recent version of a commercial virus scanning program (McAfee Enterprise 8.5 Virus Scan, updated as of March 9, 2009) and, according to the program, are free of viruses. Jay PJLefkowitz, P.C. Sandra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022 Telephone: Facsimile: EFTA00231598 SUPREME COURT FOR THE STATE OF NEW YORK COUNTY OF NEW YORK PEOPLE OF THE STATE OF NEW YORK, Plaintiff-Respondent, - against - JEFFREY E. EPSTEIN, Defendant-Appellant. Index No.: 30129-2010 PRE-ARGUMENT STATEMENT 1. TITLE OF ACTION: As set forth in caption. 2. FULL NAMES OF ORIGINAL PARTIES AND ANY CHANGE IN THE PARTIES: As set forth in caption. There has been no change in the parties. 3. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR APPELLANT OR PETITIONER: Jay P. Lefkowitz, P.C. Sandra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, Neirri4611 Telephone: Facsimile: 4. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR RESPONDENT: Cyrus R. Vance, Jr. NEW YORK DISTRICT ATTORNEY'S OFFICE One Hogan Place New York, NYilli m Telephone: 5. COURT AND COUNTY, OR ADMINISTRATIVE BODY, FROM WHICH APPEAL IS TAKEN: New York Supreme Court (Criminal Term), New York County. 6. THENATURE AND OBJECTOF THE CAUSE OF-ACTION OR SPECIAL PROCEEDING: Sex Offender Registration Act (SORA) hearing, pursuant to Article 6-C of the Correction Law. 7. RESULT REACHED IN THE COURT OF ADMINISTRATIVE BODY BELOW: Supreme Court, New York County, adjudged appellant Jeffrey E. Epstein to be a Level 3 sexual offender, without additional designation. 8. GROUNDS FOR SEEKING REVERSAL, ANNULMENT, OR MODIFICATION: The Court's designation of appellant Jeffrey E. Epstein as a Level 3 sexual offender was an abuse of EFTA00231599 discretion and constituted reversible legal error based, in part, on the following: (1) the Court improperly relied on untrustworthy double and triple hearsay contained in the recommendation of the Board of Examiners of Sex Offenders, even though the District Attorney, as the party appearing on behalf of the State, rejected much of the Board's recommendation as not constituting clear and convincing evidence to support a Level 3 designation where such hearsay allegations were rejected as a basis for state prosecution; (2) the Court failed to provide the parties with an opportunity to present evidence on contested issues, as required by statute, and instead relied wholesale upon the recommendation of the Board, over the objection of the District Attorney, without any inquiry; (3) the Court did not apply the guidelines established by the Board, as required by statute; and (4) the Court failed to set forth the findings of fact and conclusions of law on which its determinations in support of a Level 3 designation were based, as required by statute. 9. THERE IS NO RELATED ACTION OR PROCEEDING NOW PENDING IN ANY COURT OF THIS OR ANY OTHER JURISDICTION. 10. THERE IS NO ADDITIONAL APPEAL PENDING IN THIS ACTION. Dated: February 9, 2011 Ja . Lefkowitz, P.C. S dra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, Nellii4611 Telephone: Facsimile: Attorneys for Defendant-Appellant Jeffrey E. Esptein. -2- EFTA00231600 March 20, 2011 To whom it may concern: I served as U.S. Attorney for the Southern District of Florida from 2005 through 2009. Over the past weeks, I have read much regarding Mr. Jeffrey Epstein. Some appears true, some appears distorted. I thought it appropriate to provide some background, with two caveats: (i) under Justice Department guidelines, I cannot discuss privileged internal communications among Department attorneys and (ii) I no longer have access to the original documents, and as the matter is now nearly 4 years old, the precision of memory is reduced. The Epstein matter was originally presented to the Palm Beach County State Attorney. Palm Beach Police alleged that Epstein unlawfully hired underage high-school females to provide him sexually lewd and erotic massages. Police sought felony charges that would have resulted in a term of imprisonment. According to press reports, however, in 2006 the State Attorney, in part due to concerns regarding the quality of the evidence, agreed to charge Epstein only with one count of aggravated assault with no intent to commit a felony. That charge would have resulted in no jail time, no requirement to register as a sexual offender and no restitution for the underage victims. Local police were dissatisfied with the State Attorney's conclusions, and requested a federal investigation. Federal authorities received the State's evidence and engaged in additional investigation. Prosecutors weighed the quality of the evidence and the likelihood for success at trial. With a federal case, there were two additional considerations. First, a federal criminal prosecution requires that the crime be more than local; it must have an interstate nexus. Second, as the matter was initially charged by the state, the federal responsibility is, to some extent, to back-stop state authorities to ensure that there is no miscarriage of justice, and not to also prosecute federally that which has already been charged at the state level. After considering the quality of the evidence and the additional considerations, prosecutors concluded that the state charge was insufficient. In early summer 2007, the prosecutors and agents in this case met with Mr. Epstein's attorney, Roy Black. Mr. Black is perhaps best known for his successful defense of William Kennedy Smith. The prosecutors presented Epstein a choice: plead to more serious state felony charges (that would result in 2 years' imprisonment, registration as a sexual offender, and restitution for the victims) or else prepare for a federal felony trial. What followed was a year-long assault on the prosecution and the prosecutors. I use the word assault intentionally, as the defense in this case was more aggressive than any winch i, or the prosecutors in my office, had previously encountered. Mr. Epstein hired an army of legal superstars: Harvard Professor Alan Dershowitz, former Judge and then Pepperdine Law Dean Kenneth Starr, former Deputy Assistant to the President and then Kirkland & Ellis Partner Jay Lefkowitz, and several others, including prosecutors who had formally worked in the U.S. EFTA00231601 Attorney's Office and in the Child Exploitation and Obscenity Section of the Justice Department. Defense attorneys next requested a meeting with me to challenge the prosecution and the terms previously presented by the prosecutors in their meeting with Mr. Black. The prosecution team and I met with defense counsel in Fall 2007, and I reaffirmed the office's position: two years, registration and restitution, or trial. Over the next several months, the defense team presented argument after argument claiming that felony criminal proceedings against Epstein were unsupported by the evidence and lacked a basis in law, and that the office's insistence on jail-time was motivated by a zeal to overcharge a man merely because he is wealthy. They bolstered their arguments with legal opinions from well￾known legal experts. One member of the defense team warned me that the office's excess zeal in forcing a good man to serve time in jail might be the subject of a book if we continued to proceed with this matter. My office systematically considered and rejected each argument, and when we did, my office's decisions were appealed to Washington. As to the warning, I ignored it. The defense strategy was not limited to legal issues. Defense counsel investigated individual prosecutors and their families, looking for personal peccadilloes that may provide a basis for disqualification. Disqualifying a prosecutor is an effective (though rarely used) strategy, as eliminating the individuals most familiar with the facts and thus most qualified to take a case to trial harms likelihood for success. Defense counsel tried to disqualify at least two prosecutors. I carefully reviewed, and then rejected, these arguments. Despite this army of attorneys, the office held firm to the terms first presented to Mr. Black in the original meeting. On June 30, 2008, after yet another last minute appeal to Washington D.C. was rejected, Epstein pled guilty in state court. He was to serve 18 months imprisonment, register as a sexual offender for life and provide restitution to the victims. Some may feel that the prosecution should have been tougher. Evidence that has come to light since 2007 may encourage that view. Many victims have since spoken out, filing detailed statements in civil cases seeking damages. Physical evidence has since been discovered. Had these additional statements and evidence been known, the outcome may have been different. But they were not known to us at the time. A prosecution decision must be based on admissible facts known at the time. In cases of this type, those arc unusually difficult because victims are frightened and often decline to testify or if they do speak, they give contradictory statements. Our judgment in this case, based on the evidence known at the time, was that it was better to have a billionaire serve time in jail, register as a sex offender and pay his victims restitution than risk a trial with a reduced likelihood of success. I supported that judgment then, and based on the state of the law as it then stood and the evidence known at that time, I would support that judgment again. Epstein's treatment, while in state custody, likewise may encourage the view that the office should have been tougher. Epstein appears to have received highly unusual treatment while in jail. Although the terms of confinement in a state prison are a matter appropriately left to the EFTA00231602 State of Florida, and not federal authorities, without doubt, the treatment that he received while in state custody undermined the purpose of a jail sentence. Some may also believe that the prosecution should have been tougher in retaliation for the defense's tactics. The defense, arguably, often failed to negotiate in good faith. They would obtain concessions as part of a negotiation and agree to proceed, only to change their minds, and appeal the office's position to Washington. The investigations into the family lives of individual prosecutors were, in my opinion, uncalled for, as were the accusations of bias and / or misconduct against individual prosecutors. At times, some prosecutors felt that we should just go to trial, and at times I felt that frustration myself. What was right in the first meeting, however, remained right irrespective of defense tactics. Individuals have a constitutional right to a defense. The aggressive exercise of that right should not be punished, nor should a defense counsel's exercise of their right to appeal a U.S. Attorney to Washington, D.C. Prosecutors must be careful not to allow frustration and anger with defense counsel to influence their judgment. After the plea, I recall receiving several phone calls. One was from the FBI Special Agent-In￾Charge. He called to offer congratulations. He had been at many of the meetings regarding this case. He was aware of the tactics of the defense, and he called to praise our prosecutors for holding firm against the likes of Messrs. Black, Dershowitz, Lefkowitz and Starr. It was a proud moment. I also received calls or communications from Messrs. Dershowitz, Le&owitz and Starr. I had known all three individuals previously, from my time in law school and at Kirkland & Ellis in the mid 90s. They all sought to make peace. I agreed to talk and meet with each of them after Epstein pled guilty, as I think it important that prosecutors battle defense attorneys in a case and then move on. I have tried, yet I confess that has been difficult to do fully in this case. The bottom line is this: Mr. Jeffrey Epstein, a billionaire, served time in jail and is now a registered sex offender. He has been required to pay his victims restitution, though restitution clearly cannot compensate for the crime. And we know much more today about his crimes because the victims have come forward to speak out. Some may disagree with the prosecutorial judgments made in this case, but those individuals are not the ones who at the time reviewed the evidence available for trial and assessed the likelihood of success. Respectfully, R. Alexander Acosta Former U.S. Attorney Sothern District of Florida EFTA00231603 U S.J. QUINNEY COLLEGE OF LAW , THE UNIVERSITY OF UTAH Wifredo A. Ferrer United States Attorney Southern District of Florida 99 N.E.4th Street Miami, FL 33132 PAUL G. CASSELL Ronald N. Boyce Presidential Professor of Criminal Law Telephone: September 29, 2011 Re: Follow-up on leffre,y Epstein Dear Mr. Ferrer: As you know, Brad Edwards and I represent Jane Doe #1 and Jane Doe #2 in their efforts to protect their rights under the Crime Victims' Rights Act. You were nice enough to meet with Jane Doe #1 in December 2010 on that case, and we appreciate that. At the conclusion of that meeting I also provided you with a letter presenting my grave concerns about possible improper influences being brought to bear on your Office during its negotiation of the Jeffrey Epstein non-prosecution agreement. (For your convenience, I attach a copy of that letter.) It was my understanding that you deemed my allegations serious enough to forward my letter to the Office of Professional Responsibility (OPR) for further investigation, and it was my impression that 0PR was going to look into the allegations raised in my letter. I must say that I was surprised to receive a letter five months later from 0PR indicating that my concerns were not being investigated. On May 6, 2011, OPR stated that it was their policy "to refrain from investigating issues or allegations that were, are being, or could have been addressed in the court of litigation, unless a court has made a specific finding of misconduct by a DOJ attorney ... or there are present other circumstances." 0PR stated that my allegations fell into the category of allegations that were being litigated because Jane Doe #1 and Jane Doe #2 were raising these issues in their CVRA case. Accordingly, OPR indicated it was not going to review the allegations that I presented. I am writing now to request the opportunity to meet with you further and to pass along additional information in support of my concerns. I wanted to follow up with you to make sure that someone was looking into my allegations about improper influences affecting your Office's decision to accord Jeffrey Epstein an extraordinarily lenient plea. It may well be that 0PR has some policy precluding an investigation. But will your Office then investigate these issues? I am also writing to alert you to additional information that continues to lead me to believe that something was rotten with the way this case was handled. 1 www.law.utah.edu • Main Office • Facsimile 332 South 1400 East, Room 101 • Salt Lake City, Utah 84112-0730 EFTA00231604 As you may know, was a senior prosecutor and supervisor in your Office when the non-prosecution agreement with Jeffrey Epstein was approved. It is our impression that he was directly involved in supervising the Epstein investigation as the former Chief of the Criminal Division of your Office. It has been our understanding for quite some time that he frequently corresponded with Epstein's attorneys, especially Lily Ann Sanchez, during the plea discussions, and it is our understanding that he left your Office around the time the non-prosecution agreement was signed. Our private investigator has recently learned that a left your office to work at a New York law firm representing white collar criminals. He also learned that M's quite expensive apartment in New York City is located in close proximity to real estate properties (specifically condos) owned by Jeffrey Epstein. The location of M's apartment, his role during the Epstein negotiations and his departure immediately after the NPA was signed, leads us to believe that and Epstein may have had a business or other relationship either during or after time in the Office. If that is the case, then we would appreciate you providing the information that you have in that regard voluntarily, as opposed to us having to conduct formal discovery to get it. As you also know, Judge Marra has recently ordered discovery to proceed in this case. We obviously would like for that process to go as smoothly as possible and want to avoid becoming involved in true adversary litigation with your Office. On behalf of our clients, we just want to get to the bottom of this, and we feel safe in assuming that you do too at this point For all these reasons, I am writing to request another chance to meet with you about our concerns and about making the discovery process go smoothly. Thank you in advance for considering this request I would be happy to provide any other additional information that would be useful to you. Sincerely, 4 Paul G. Casse I cc: Assistant U.S. Attorney cc: Assistant U.S. Attorney 2 EFTA00231605 U,, S.J.QUINNEY COLLEGE OF LAW THE UNIVERSITY OF UTAI I 'Wifredo A. Ferrer United States Attorney Southern District of Florida 99 N.E.4th Street Miami, FL 33132 PAUL G. CASSELL Ronald N. Boyce Presidential Professor of Criminal Law Telephone: December 10, 2010 Re: Request for Investigation of Jeffrey Epstein Prosecution Dear Mr. Ferrer: I am writing as someone with extensive experience in the federal criminal justice system — as a former Associate Deputy Attorney General, Assistant United States Attorney, federal judge, and currently criminal law professor — to alert you to what seems to be the most suspicious criminal case I have ever encountered. I ask that you investigate whether there were improper influences and actions during your office's criminal investigation of Jeffrey Epstein, particularly regarding the decision to enter into a binding non-prosecution agreement blocking his prosecution for numerous federal sex offenses he committed over many years against more than thirty minor girls. As I am sure you are well aware, in 2006 your office opened a criminal investigation with the FBI into allegations that for years Jeffrey Epstein sexual abused dozens of minor girls in his West Palm Beach mansion. The FBI soon developed compelling evidence that Epstein had in fact committed numerous federal sex offenses with more than 30 minor girls. And yet, your office ultimately entered into a plea arrangement which allowed Epstein escape with a non￾prosecution agreement that ensured he would have no federal criminal liability and would spend no more than 18 months in state jail. For sexual offenses of this magnitude — in a case with more than 30 witnesses providing interlocking testimony, all made automatically admissible by virtue of Fed. R. Evid. 414 —this is an extraordinary outcome. Why did your office enter into this highly unusual non-prosecution arrangement with Epstein? Suspicion begins with the point that Epstein is a politically-connected billionaire. But that wouldn't be troubling without considerable other evidence that something went terribly wrong with the prosecution for other, improper reasons. Consider the following highly unusual facts: First, it appears that Epstein was tipped off before th xecution ofTfCaritiwsrrefrar------ his home. We know that lead state police officers -- Detective and Police Chief - complained that the house was "sanitized" by the time they arrived to serve a search warrant for child pornography. This sanitation was evident by the various computer wires hanging with no computers attached. Housekeeper Janusz Banasiak later testified hi a civil unvynlaw.utalt.eclu • Main Office • Facsimile 332 South 1400 East, Room 101 • Salt Lake City, Utah 134112-0730 EFTA00231606 deposition that Epstein's assistant, (E) and another man (unknown) were instructed to remove, and did in fact remove, multiple computers from Epstein's home shortly before the search warrant was served. The fact that there could well have been a tip off is apparently suspected by federal authorities. Second, there is evidence that one of the senior prosecutors in your office joined Epstein's payroll shortly after important decisions were made limiting Epstein's criminal liability — and improperly represented people close to Epstein. During the federal investigation of Epstein, Bruce Reinhart was a senior Assistant U.S. Attorney in your office. As we understand things, he was a direct supervisor of the line prosecutor handling the case and thus was well aware of details of the Epstein investigation and plea negotiations. We further believe that he was consulted on issues related to the prosecution of Epstein and Epstein's co-conspirators, including specifically issues related to whether Epstein employees and pilots should be prosecuted for their involvement in Epstein's sexual offense. We further believe that he personally and substantially participated in making such decisions about the course of the criminal investigation. Within months after the non-prosecution agreement was signed by your office, Reinhart left your office and immediately went into private practice as a white collar criminal defense attorney. His office coincidentally happened to be not only in the same building (and on same floor) as Epstein's lead criminal defense counsel, lack Goldberger, but it was actually located right next door to the Florida Science Foundation -- an Epstein-owned and -run company where Epstein spent his "work release." While Working in this office adjacent to Epstein's, Reinhart undertook the representation of numerous Epstein employees and pilots during the civil cases filed against Epstein by the victims — cases that involved the exact same crimes and exact same evidence being reviewed by the U.S. Attorney's office when he was employed there. Specifically, he represented (Epst4in's number one co-conspirator who was actually named as such in the NPA), his housekeeper (Louella Ruboyo), his pilots Larry Morrison, Larry Visoski, David Rogers, William Hammond and Robert Roxburgh. (Hammond and Roxburgh were not deposed but the others were.) Our understanding is that his representation of these individuals was paid for, directly or indirectly, by Epstein. Reinhart was well aware of what evidence your office and federal investigator had collected against Epstein and about the minor girls who were his victims. As a consequence, he knew what evidence the attorneys for the victims were using. He also knew what each of those witnesses had said, it anytfiirign, federafarrd statc ;Irvestigators-duriag-thettiminal investigation. We have been unable to place our fingers on the federal regulations governing such later representation. We do know, however, that such actions appear to be in direct contravention of the Florida ethical rules regarding attorneys who leave government employment. For 2 EFTA00231607 example, Florida R. Prof. Conduct 4-1.11(a) provides "[a) lawyer shall not represent a private client in connection with a matter in which the lawyer participated personally and substantially as a public officer or employee unless the appropriate government agency consents after consultation." Similarly, Florida R. Prof. Conduct 4-1.11(b) provides that "[a) lawyer having information that the lawyer knows is confidential government information about a person acquired when the lawyer was a public officer or employee may not represent a private client whose interests are adverse to that person in a matter in which the information could be used to the material disadvantage of that person." Both these rules appear to have been violated. But entirely apart from the details of ethical rules, the fact that one of your prosecutors was involved in making important decisions aboUt the scope of criminal liability for Epstein and his associates and then — after criminal liability was significantly limited — representing numerous people at Epstein's behalf raises serious questions. At the very least, there is the strong appearance that Reinhard may have attempted to curry favor with Epstein and then reap his reward through favorable employment. At the very worst, there may have been advance discussions — we simply don't know at this point. Third, Epstein appears to have deliberately kept from victims in the case correspondence with your office and the Justice Department that might have shed light on improper influences. Along with other capable attorneys, I was involved in representing one of Epstein's victims (..) who filed a federal civil case against Epstein. Suspecting that Epstein may have improperly influenced your office, we immediately served discovery requests on Epstein for all the correspondence with yoUr office regarding the plea negotiations. Eleven months of hard litigation ensued, in which Epstein made every conceivable argument against production. Finally, late in June of this year, his appeals exhausted, Epstein produced the correspondence to us. However, in violation of the court order, he redacted the correspondence so that he provided only emails and other statements from your office — not his emails and statements to your office. More significantly, even though he was under court order to produce all correspondence between his attorneys and your office, Epstein secretly withheld correspondence by several of his most ht h-powered attorneys — namely Ken Starr and Lilly Ann Sanchez. Epstein settled the case with M. within days after this limited production, and we did not realize the absence of what must have been critical discussions between your office and Starr and Snachez (among others). Epstein's refusal to allow us to see that information raises the suspicion in our minds that there must have been unusual pressures being brought to bear during the plea discussions that would have been revealed had Epstein complied with his production obligations. Fourth, there appears to have been an unprecedented level of secrecy between your office and the Fed&II-Bureau of hivestiKativii during-this-ease. The Ffll-wacre-spcuisible—alon with state and local police agencies, for building the case against Epstein. They appear to have developed an overwhelming criminal against him. And Yet, when your office signed the non￾prosecution agreement with him, it is not clear to us that the FBI was consulted about this decision. Indeed, we have suspicions that the FBI was not informed of this decision until, perhaps, months later. 3 EFTA00231608 Supporting this suspicion is our on-going litigation regarding the treatment of the victims in this case. As you know from our draft pleadings that we have discussed with your office, we believe there is compelling evidence that the victims and their attorneys were deceived about the existence of a non-prosecution agreement for months in order to avoid what certainly would have been a firestorm of controversy about such lenient treatment of a repeat sex offender. Our impression from the evidence we have been able to obtain so far is that the FBI was similarly kept in the dark — not consulted about or even told about the NPA. While a certain amount of tension has always existed between federal prosecuting and investigating agencies, not even informing the FBI about the Epstein NPA seems highly unusual. All of these strange facts -- as well as the facts that we are alleging in our crime victims' litigation — lead us to think that there was something rotten with the way this case was handled. Epstein could have faced years and years in prison for numerous federal sex offenses. And yet he managed to contrive to walk away with no federal time at all (and only minimal state time). We respectfully ask you to investigate through appropriate and independent channels the handling of the Epstein (non)prosecution. Thank you in advance for considering this request. I would be happy to provide any other additional information that would be useful to you. Sincerely,a Paul Cassel 4 EFTA00231609 SJ. QUINNEY COLLEGE OF LAW THE UNIVERSITY OF UTAH March 1, 2011 Wifredo A. Ferrer United States Attorney Southern District of Florida 99 N. E.4thStreet Miami, FL 33132 PAUL G. CASSELL Ronald N. Boyce Presidential Professor of Criminal Law Telephone: Re: Jane Doe #1 and Jane Doe #2 vs. United States, No. 09-80736 Dear Mr. Ferrer: We are writing to you personally on behalf of Jane Doe #1 and Jane Doe #2 in one last effort to try and narrow our range of difference in the pending Crime Victims Rights Act case regarding Jeffrey Epstein. We make two requests: First, we are requesting that you agree to our proposal for narrowing the range of disputes between your Office and the victims, Jane Doe #1 and Jane Doe #2. Second, If you are unable to agree to our proposal, we request that you agree not to withhold information in your Office's possession that would support their claims under the Crime Victims Rights Act (CVRA). By way of background, as you know, we have been attempting to work with your Office for more than two-and-a-half years to reach a stipulated set for facts in this CVRA case that would avoid the need for any public battle between your Office and the victims . Indeed, we reached out to you for a personal meeting to try to avoid a fight, and you were kind enough to meet with Jane Doe #1 and her undersigned attorneys. During that meeting, we expressed our intention to go the extra mile to try and avoid any fight with your Office and to see if there was a way to fight only Jeffrey Epstein the sex offender, rather than the prosecutors who work for you. Today we had a telephone conference call with two of your attorneys, and in which they told us that we would not be receiving any cooperation from your Office on our CVRA case and that, in short, we would have to "see you in court." We were also told that your Office was taking the position that it could, and would, withhold from the victims information in your Office's possession that would support their claims under the CVRA. After receiving approval from and , we wanted to write to you personally in one last effort to see if we can narrow our differences on these two Issues and avoid a disappointing battle. Narrowing the Issues in Dispute During today's conference call, it appeared that there was some confusion from and as to precisely what the victims were proposing. Our proposal is simply this: that www.law.utah.edu • Main Office • Facsimile 332 South 1400 East, Room 101 • Salt Lake City, Utah 84112-0730 EFTA00231610 your Office and Jane Doe #1 and Jane Doe #2 would stipulate to a set of facts to provide context for the Court while we litigate the legal issue in dispute, that is whether the CVRA applies even though no federal charges were ultimately filed. If your Office prevails on that Issue, the victims would obviously have no claim under the CVRA. The victims would then pursue their appellate rights in the Eleventh Circuit. If, however, the victims prevail on that issue, then your Office would take "no position" on the remedy sought by the victims for the violation of their rights afforded them under the Act. Your Office would essentially stand aside and agree not to take any position on the victims' request to set aside the NPA as a remedy for that violation of the victims' rights. We understood from our meeting with you in December that you wanted to do what you could to help the victims in this case. Yet as we understood and today, they were taking the position that we would receive no cooperation of any sort from your Office. And we further understood from them that your Office was now going to take the position that even if the victims' congressionally-mandated rights were violated, there is simply no remedy for those violations and thus the victims should have no recourse for the violations. On behalf of our clients, we want to once again reach out and make sure that your Office wants to move to an adversarial litigation posture on these issues. We simply don't understand why your Office is now going to take a litigating position hostile to ours on issues beyond the legal question of when CVRA rights attached in this case. We appreciate that the Department has institutional concerns about the timing of CVRA rights. But we don't understand why your Office is now going to fight against the victims in their efforts seeking to overturn a NPA that by any measure is unfair. This is not simply our view — the unfairness of the NPA has now attracted comment literally throughout the world, including serving as the basis for an unfavorable portrayal in a recent Law and Order: Special Victim Episode and a feature story yesterday in the London-based Sunday Mail. We are not asking your Office to join us in our efforts to throw out this unjust agreement. But can't your Office simply stand on the sidelines and let us make our case against Epstein. Fighting a politically well-connected billionaire is difficult enough, without having the weight of the U.S. Attorney's Office for the Southern District of Florida thrown against us too. We respectfully make one last request for you to move forward with our proposal for narrowing differences between us. Withholding Favorable Evidence If you feel that your Office must fight us in court on every possible issue, then we are respectfully writing to request that we resolve one issue outside of court: Whether your Office can withhold from the victims evidence in its possession that is favorable to their CVRA case. During our conference call with and , we pointed out that if we were criminal defense attorneys representing criminals, your Office would promptly turn over to us all information in its possession that was helpful to these criminals under the Brady and Giglio decisions. We asked your Office to extend to the victims the same assistance that it would provide to criminals — i.e., we asked and to voluntarily provide to us information 2 EFTA00231611 in your Office's possession that was helpful the victims' CVRA case. We were informed that your Office will be taking the position in Court that it can and will withhold from the victims such information, apparently on the theory that victims lack due process or other "discovery" rights under the CVRA. We believe that the position that your Office can suppress relevant evidence is legally unfounded for four reasons and, in any event, is unsound policy at odds with promises that the Attorney General has made to crime victims and to the public. With regard to the legal problems in this position, first, the CVRA promises victims of crime that they will be "treated with fairness." 18 U.S.C. § 3771(a)(8). The clear intent of Congress in passing this provision was to provide a substantive "due process" right to crime victims. As one of the CVRA's co-sponsors (Senator Kyl) explained, "The broad rights articulated in this section are meant to be rights themselves and are not intended to just be aspirational. One of these rights is the right to be treated with fairness. Of course, fairness includes the notion of due process. Too often victims of crime experience a secondary victimization at the hands of the criminal Justice system. This provision is Intended to direct Government agencies and employees, whether they are in executive or judiciary branches, to treat victims of crime with the respect they deserve." 150 CONG. REC. 54269 (Apr. 22, 2004) (emphasis added). Because the CVRA extends a "due process" right to crime victims like Jane Doe #1 and Jane Doe #2, victims have a right to fair access to evidence to prove their case. The very foundation of the Brady obligation is due process: "[T]he suppression by the prosecution of evidence favorable to an accused violates due process where the evidence is material either to guilt or to punishment." Brady v. Maryland, 373 U.S. 83, 87 (1963). It would similarly violate due process for the prosecution to suppress evidence favorable to a crime victim where the evidence is material either to proving a CVRA violation or to the remedy for a violation. Second, entirely apart from whether the victims have a right to obtain such information, your Office has an affirmative obligation to disclose it to victims. The CVRA directly commands that "[o]fficers and employees of the Department of Justice and other departments and agencies of the United States engaged in the detection, investigation, or prosecution of crime shall make their best efforts to see that crime victims are notified of, and accorded, the rights described In [the CVRA]." 18 U.S.C. § 3771(c)(1) (emphasis added).1 It is simply impossible for As you can see from this language, the CVRA applies not only to the U.S. Attorney's Office for the Southern District of Florida but also to the relevant office of the FBI. We are "cc'ing" a copy of this letter to the FBI so that they can be informed of our view that they should provide assistance to the victims in this matter as well, rather than Join your Office in any effort to withhold evidence. We understand that your Office represents the FBI on these issues, andTre-hapy to continue our discussions with you regarding the FBI obligations In this area. At the appropriate time, however, if we are unable to reach agreement, we would like to have this discussion with a representative of the FBI to see whether they are in accord with your position. It is our understanding that the appropriate person would be the "special agent-In-charge of the division having primary responsibility for conducting the investigation." ATTORNEY GENERAL GUIDELINES FOR VICTIM AND WITNESS ASSISTANCE 11 (May 2005). 3 EFTA00231612 your Office to make its "best efforts" to accord victims their rights while simultaneously withholding evidence that would help them obtain those rights in court. Third, the attorneys In your Office have duties of candor to the Court that would not permit It to present evidence or testimony that is known to be false. Fla. Bar Rule 4-3.3(a)(4). Allowing the victims access to evidence favorable to their claim will insure compliance with this rule. Similarly, in an ex parte proceeding, a lawyer must inform the court of all material facts known to the lawyer that will enable the court to make an Informed decision "whether or not the facts are adverse." Fla. Bar. Rule 4-3.3(d). If your Office is correct that we are not entitled to access to favorable evidence, then the proceedings involving that evidence are essentially ex parte — requiring your Office to make disclosure to the Court. Surely the more appropriate way to proceed is to simply disclose those materials in the first instance to the victims. Fourth and finally, your Office has previously taken the position that the CVRA petition filed by the victims is covered by the civil rules. If so, then the victims can serve discovery requests as in any other civil cases. The victims can likewise take depositions of witnesses who possess relevant evidence to their claims. Indeed, under Fed. R. Civ. P. 26(a)(1)(A), your Office would be required to automatically produce such information. For all these reasons, it is our considered opinion that your Office does not have a legally well-founded position to withhold evidence from the victims in this case. Even If the Office did have such a position, however, we are mystified as to why your Office would want to assert such a position. Attorney General Holder has recently publicly discussed the Department's obligations regarding production of exculpatory information to criminals, explaining "We're not here to win cases, but to do justice." Attorney General Holder Discusses Efforts to improve Prosecutor Training, WALL ST. J., Apr. 30, 2010. With all respect, we submit that your Office should seek to do justice not merely for criminals, but also for the victims of those criminals. We therefore respectfully request that you simply provide this information to us as a matter of justice, avoiding the need for us to litigate this question. To avoid burdening your Office, we would be happy to provide a specific list of the information that we believe is material to the victims' CVRA case — a limited amount of information that could be swiftly located by your Office. Conclusion We frankly believe we have been very patient on this case and have gone to the extra mile to avoid an unnecessary fight with your Office. But our clients are asking us what the status of their case is, and we have an obligation to proceed diligently. Our first choice is to work something out with you. But if your Office is for some reason unwilling or unable to do that, we believe we have an overwhelming case of clear cut CVRA violations — a case that we will present to the Court. 4 EFTA00231613 As we told and even though your Office has refused to provide any accommodations to us, we will continue to discuss with them our proposed statement of facts, with the aim of removing Information that they believe is damaging to your Office and that we can leave out as unessential to our case. We hope that you will favorably consider our requests in this letter and try to find an approach that will minimize our need to become embroiled in a court dispute between crime victims and the prosecutors who aim to protect them. If we are unable to do so, our intention is to file our "summary Judgment" pleadings (which we provided in their entirety to your Office as a courtesy six months ago) on March 18, 2011. Sincerely, s it74, Bradley J. dwards ?c' Paul . Cassell Co-Counsel for Jane Doe #1 and Jane Doe #2 Cc: Special Agent in Charge John V. Gillies Miami FBI Field Office 16320 NW 2nd Avenue North Miami Beach, FL 33169 The views expressed in this letter are solely those of its authors. 5 EFTA00231614 • C. (USAFLS) From: Paul Cassell 1.1....] Sent: Monday,aarc 07, 5: 3 To: IMI, IIIIM (USAFLS); IMI C. (USAFLS) Cc: Brad Edwards Subject: Motion to Make Our Pleading Available to the Public - Government Position Dear and We are writing to inquire about the government's position on a motion that we will be filing on March 18 along with our "summary judgment" motion. As you know, the summary judgment motion will contain quotations from e-mails that are under the magistrate judge's order requiring prior notice to the court before they are disclosed. Accordingly, on March 18, we will be filing a full, unredacted summary judgment motion under seal with Judge Marra and, for the public PACER file, a summary judgment motion with quotations from the e-mails redacted. We will be filing simultaneously a motion for with the court for unsealing of the unredacted motion. We will provide (at least) three ground for unsealing. First, the confidentiality order was only based on an agreement to give advance notice to Epstein before using materials. Once advance notice has been given, there is no basis for confidentiality. Second, there is truly world-wide interest in the handling of the Epstein prosecution, and • our pleading should not remain under seal — instead the public should have access to it i that they can assess how this case was handled. Third, keeping the pleading under seal complicates the ability of Jane Does' attorneys to consult with victims' rights specialist about how best to proceed in the case. We are writing to determine the Government's position on our motion to unseal the redacted pleading that we can include that position in our motion. We hope that you will not oppose the motion, which might produce the need for further litigation. As you know, Judge Marra has promptly unsealed other pleadings in this matter when the Government tried to object. Sincerely, Cassell Co-Counsel for Jane Doe #1 and Jane Doe #2 G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah 332 South 1400 East, Room 101 Salt Lake City, UT 84112-0730 Voice: Fax: Email: htto://www.law.utah eduThrofilesidefault asp2PersonID—=57Rmamp=taccell,Paul CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message Thank you EFTA00231615 Case 9:08-cv 1 2 3 4 80119-KAM Document 180 Entered UNITED STATES SOUTHERN DISTRICT WEST PALM CASE NO. 08-80119-CIV-MARRA on FLSD Docket 06/24/2009 Page 1 of 51 DISTRICT COURT OF FLORIDA BEACH DIVISION WEST PALM BEACH, FLORIDA 5 JANE DOE, et al., 6 Plaintiffs, JUNE 12, 2009 7 VS. 8 JEFFREY EPSTEIN, 9 Defendant. 10 11 TRANSCRIPT OF MOTION HEARING BEFORE THE HONORABLE KENNETH A. MARRA, 12 UNITED STATES DISTRICT JUDGE APPEARANCES: 13 14 FOR THE PLAINTIFFS: ADAM D. HOROWITZ, ESQ. Mermelstein & Horowitz 15 18205 Biscayne Boulevard Miami, FL 33160 305.931.2200 16 For Jane Doe 17 BRADLEY J. EDWARDS, ESQ. Rothstein Rosenfeldt Adler 18 401 East Las Olas Boulevard Fort Lauderdale, FL 33301 19 Jane Doe 3, 4, 5, 6, 7 20 ISIDRO M. GARCIA, ESQ. 21 Garcia Elkins Boehringer 224 Datura Avenue West Palm Beach, FL 33401 22 Jane DOE II 561.832.8033 23 RICHARD H. WILLITS, ESQ. 24 2290 10th Avenue North Lake Worth, FL 33461 25 For C.M.A. 561.582.7600 TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231616 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 2 of 51 1 ROBERT C. JOSEFSBERG, ESQ. 2 Podhurst Orseck Josefsberg 25 West Flagler Street 3 Miami, FL 33130 For Jane Doe 101 305.358.2800 4 (Via telephone) 5 KATHERINE W. EZELL, ESQ. Podhurst Orseck Josefsberg 6 25 West Flagler Street Miami, FL 33130 7 For Jane Doe 101 305.358.2800 8 FOR THE DEFENDANT: ROBERT D. CRITTON, JR., ESQ. MICHAEL BURMAN, ESQ. 9 Burman Critton, etc. 515 North Flagler Street 10 West Palm Beach, FL 33401 11 JACK A. GOLDBERGER, ESQ. 12 Atterbury Goldberger Weiss 250 Australian Avenue South 13 West Palm Beach, FL 33401 14 As Amicas cuicmie: , ESQ. 15 Assistant U.S. Attorney 500 East Broward Boulevard 16 Fort Lauderdale, FL 33394 For U.S.A. 954.356.7255 17 MARTIN G. WEINBERG, ESQ. 18 20 Park Plaza Boston MA 02116 19 (Via telephone) 20 JAY LEFKOWITZ, ESQ. (Via telephone) 21 REPORTED BY: LARRY HERR, RPR-RMR-FCRR-AE 22 Official United States Court Reporter Federally Certified Realtime Reporter 23 400 North Miami Avenue, Room 8N09 Miami, FL 33128 305.523.5290 24 25 TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231617 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 3 of 51 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22- 23 24 25 THE COURT: We are here in the various Doe vs. Epstein cases. May I have counsel state their appearances? MR. HOROWITZ: Adam Horowitz, counsel for plaintiffs Jane 2 through Jane Doe 7. THE COURT: Good morning. MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane Doe. THE COURT: Good morning. MR. GARCIA: Good morning, Your Honor. Sid Garcia for Jane Doe II. THE COURT: Good morning. MR. WILLITS: Good morning, Your Honor. Richard Willits, here on behalf of the plaintiff C.M.A.. THE COURT: Good morning. MS. EZELL: Good morning, Your Honor. I'm Katherine Ezell from Podhurst Orseck, here with Amy Adderly and Susan Bennett, and I believe my partner, Bob Josefsberg, is going to appear by telephone. THE COURT: Mr. Josefsberg, are you there? MR. JOSEFSBERG: I am, Your Honor. Int Lu RI: -Good morning-. MR. JOSEFSBERG: Good morning. THE COURT: All right. Do we have all the plaintiffs stated their appearances? Okay. TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231618 Case 9:08-cv 80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 4 of 51 4 1 Defense? 2 MR. CRITTON: Your Honor, Robert Critton on behalf of 3 Mr. Epstein, and my partner, Michael Burman. 4 THE COURT: Good morning. 5 MR. GOLDBERGER: Good morning, Your Honor. Jack 6 Goldberger on behalf of Mr. Epstein. 7 THE COURT: I see we have some representatives from 8 the United States Attorney's Office here. 9 MS. : Good morning, Your Honor. • 10 for the U.S. Attorney's office. 11 THE COURT: Good morning. 12 Who else do we have on the phone? 13 MR. CRITTON: Your Honor, we have two members of the 14 defense team are on the phone, also. 15 THE COURT: Who do we have on the phone? 16 MR. WEINBERG: Martin Weinberg. Good morning, Your 17 Honor. 18 MR. LEFKOWITZ: Jay Lefkowitz. Good morning, Your 19 Honor. 20 THE COURT: Good morning. 21 I scheduled this hearing for very limited issues 22- VITich, as you all know, -t1 n a o DITTspstei 23 stay the civil proceedings against him. The one issue I have 24 concern about is Mr. Epstein's contention or assertion that by 25 defending against the allegations in the civil proceedings, he TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231619 Case 9:08-cv 80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 5 of 51 5 1 may expose himself to an allegation by the United States in the 2 non-prosecution agreement that he's violated that agreement and 3 therefore would subject himself to potential federal charges. 4 I had asked for some briefing on this. I asked the 5 United States to present its position to me. And I received 6 the Government's written response, which I frankly didn't find 7 very helpful. And I still am not sure I understand what the 8 Government's position is on it. 9 first let me hear from Mr. Epstein's attorneys as 10 to what do you believe the concern is. I don't believe the 11 non-prosecution agreement has ever been filed in this Court; am 12 I correct? 13 MR. CRITTON: To my knowledge, Your Honor, it has not. 14 THE COURT: II I don't believe I've ever seen the 15 entire agreement. I've seen portions of it. 16 MR. EDWARDS: Your Honor, I believe that it was filed 17 under Jane Doe 1 and 2 vs. United States of America, case under 18 seal in your court. 19 THE COURT: Okay. 20 MR. EDWARDS: In a separate case. 21 THE COURT: In that case, okay. Was it actually filed 22- -in- that case( 23 MR. EDWARDS: I filed it under seal. 24 THE COURT: In any event, what's Mr. Epstein's concern 25 about if you defend the civil actions, you're going to expose TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231620 Case 9:08-cv 80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 6 of 51 6 1 yourself to a claim for a breach by the United States of the 2 non-prosecution agreement? 3 MR. CRITTON: Robert Critton. 4 Your Honor, our position on this case is, I'd say is 5 somewhat different. When this issue originally came before the 6 Court, as you are aware prior to my firm's involvement in the 7 case, there was a motion filed on behalf of Mr. Epstein seeking 8 a stay. And I think it was in Jane Doe 102 and then 9 subsequently Jane Doe 2 through 5 because all of those cases 10 were filed on or about the same time. 11 And at that time the Court looked at the issue and it 12 was based upon a statutory provision at that time. And the 13 Court said I don't find that it's applicable, or for whatever 14 L reason I think the Court said I don't consider that to be a 15 pending proceeding or a proceeding at that particular time. 16 In that same order, which was in Jane Doe 2, I 17 believe it's -- not I believe, I know it's docket entry 33, the 18 Court also went on to talk about at that particular point in 19 time dealt with the issue of the discretionary stay. 20 And the Court said at that time, I'm paraphrasing, but 21 the Court also does not believe a discretionary stay is 22 at the Court went on to sap is that if 23 defendant does not breach the agreement, then he should have no 24 concerns regarding his Fifth Amendment right against 25 self-incrimination. TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231621 Case 9:08-cv 80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 7 of 51 1 The fact that the U.S. Attorney or other law 2 enforcement officials may object to some discovery in these 3 civil cases is not in and of itself a reason to stay the civil 4 litigation, II that any such issue shall be resolved as they 5 arise in the course of the litigation. 6 And I would respectfully submit to the Court that the 7 position that the Government has taken in its most recent 8 filings changes the playing field dramatically. Because what 9 the Government in essence has said as distinct from the U.S. 10 saying is, well, we object to some discovery, or we may object 11 to some discovery in the civil cases. 12 what they have, in essence, said is if you take some 13 action, Mr. Epstein, that we believe unilaterally, and this is 14 on pages 13 and 14 of their pleading or of their response memo 15 to the Court's inquiry, they say if Mr. Epstein breaches the 16 agreement. They said it's basically like a contract, and if 17 one side breaches, the other side can sue. 18 In this instance what the Government will do is if we 19 believe that Mr. Epstein has breached the agreement, we'll 20 indict him. We will indict him. And his remedy under that 21 circumstance, which is an incredible and catastrophic catch 22 22 s, Andict him and- than he can -move to dismiss-. Tharys- a 23 great option. 24 In this particular instance my mandate in defending -- 25 and that's a dramatic change in the Government's position, TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231622 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page8of51 1 because the Government is not saying, and the Court was pretty 2 specific in what you asked the Government for in its response 3 is, in essence, and it's the same question in a more limited 4 fashion you're posing today is whether Mr. Epstein's defense of 5 the civil action violates the NPA agreement, the 6 non-prosecution agreement, between the U.S. and Mr. Epstein. 7 And the Government refuses to answer that question. 8 They won't come out and say, yes, it will, or no, it won't. 9 What they're doing is they want to sit on the sideline, and as 10 their papers suggest is, they want us to lay in wait and that 11 if, in fact, they believe he violates a provision of the NPA as 12 it relates to the defense of this case or these multitude of 13 cases, then they can come in and indict him -- no notice, no 14 opportunity to cure. 15 We don't think that's what the NPA says, but that's 16 certainly what their papers say. We'll indict him, no notice, 17 I no opportunity to cure. We will indict him, and his remedy 18 under that circumstance is that he can move to dismiss the 19 indictment. 20 Well, that's great except Mr. Epstein, his mandate to 21 me and I know his mandate to his criminal lawyers, is: Make 22 o anything, in particular in these civil cases 23 that would in any way suggest that I am in willful violation of 24 the NPA. 25 Now, in the Court's prior ruling in the docket entry TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231623 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 9 of 51 9 1 33, certainly some aspects of the NPA are within Mr. Epstein's 2 control. There's no question about that. But aspects that 3 relate to the defense of these cases, either in terms of the 4 civil lawyers who are defending these, I think there's 12 or 13 5 pending cases in front of you, there's another four cases in 6 the state court, is the risk is substantial, it's real, and it 7 presents a chilling effect for the civil lawyers in moving 8 forward to determine whether or not we're taking some action 9 that in some way may be a violation of the NPA. 10 And the Government's, again, refusal or non-position 11 with regard to past acts that have been taken in the civil case 12 with regard to the defense or future acts that we may take with 13 regard to these contested litigation casts an extraordinary 14 cloud of doubt and uncertainty and fear that the defense of 15 these cases could jeopardize Mr. Epstein and put him in the 16 irreparable position of violating the NPA and then subsequently 17 being indicted. 18 In this particular instance, again, Mr. Epstein has no 19 intention of willfully violating the NPA, but it's of great 20 concern to him. And I'd say with the position that the 21 Government has taken, no notice, no cure period, no opportunity 22 -to discuss. .Again, we think that's not what the NPA provides, 23 it's not what the deal was between the two contracting parties, 24 the United States and Mr. Epstein. But that's clearly what 25 their papers say under the circumstances, and it would create TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231624 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 10 of 51 jo 1 this irreparable harm to Mr. Epstein under the circumstances. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 In essence, we're left with a catch 22 in defending the civil cases. We have a mandate to take no action, to take any action which may be deemed to be a violation of the NPA, either in the past or in the future, which would in any way risk Mr. Epstein being indicted by the United States. He has the clear risk of an indictment based upon the papers that the Government filed. It's real, it's not remote, and it's not speculative. It chills the action of the defense in this instance of both Mr. Epstein and his attorneys in trying to defend these cases and decide under the circumstances can we do this, can we take this position with regard to depositions, can we take this legal position with regard to motions to dismiss, with regard to responses, with regard to replies? And we send out paper discovery. Is this in some way if we contact someone who may be an associate of these individuals as part of our investigation, is that potentially in any way a violation of the NPA? Again, we don't think II. And, obviously, again, my direction has been from my client: Don't take any action that would result in me being indicted un ex Lhe NPA. Well, LiaLts- great. But; generally, civil lawyers or civil lawyers in defending a personal injury case or a tort case, which is exactly what these are, and from a practical standpoint, we use various tools to do discovery. TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231625 Case 9:08-cv-80119-KAUA Document 180 Entered on FLSD Docket 06/24/2009 Page 11 of 51 1 1 They're standard. They're specific. They're very temporary. 2 Very typical. 3 But in this instance, as the Court knows, things are 4 not typical with regard to this case in any way, shape or form. 5 We can't even serve subpoenaes, there's objections and there's 6 we can't even serve objections to third parties II we can 7 obtain documents unless we have to filter it through the B I plaintiffs' attorneys. They won't allow us to use their 9 clients' names, even in a subpoena that would never be filed in 10 the court. 11 How do we do a deposition of a third party? We wanted 12 to take the deposition of Jane Doe 4. Well, who is she? Well, 13 we can't tell you that. Well, who's the defendant? Well, we 14 can't tell you that because nobody wants anybody to know 15 anything about the case. They want to present it strictly 16 through rose-colored glasses. 17 And in this particular instance, we simply can't 18 defend this case or take certain action with the spector 19 hanging over us that, in fact, the Government may deem it to be 20 a violation of the NPA, because very clearly in their response 21 papers, they don't say. They say we don't take the position, 22- e-a substantial position is -wErthink-there's----- 23 not all that substantial factors that would entitle him to a 24 stay. 25 Except for the one major issue which the Court posed TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231626 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 12 of 51 12 in the question is, is can he defend these cases? That's what I really want to know. Can he defend these cases and, in 1 2 3 essence, what he has done in the past or what his defense team 4 has done in the past and what they're going to do in the 5 future, can you give him, Epstein, assurances that the 6 Government under this situation, whatever he does, based on 7 advice of counsel, that that cannot be a willful violation of 8 the NPA, which they can -- they, the U.S. -- can then turn 9 around and say that's a violation of the agreement and, 10 therefore, we're going to go proceed to indict you under the 11 circumstances. 12 Our position is, Your Honor, is that the U.S. has now 13 cavalierly suggested that, as they did in picking up on the 14 court's docket entry or prior order, is, look, compliance with 15 the NPA is solely up to Mr. Epstein. In this type of balance 16 of equities, it doesn't speak in favor of a stay. 17 Well, that's great. And maybe that was the position 18 back in '08, on August 5th of '08, when the issue came up in 19 front of the Court with regard to the initial stay. 20 But the Government's papers under these circumstances 21 suggested a very different set of circumstances. Their own 22 -tmi-latera-1, wliiclris -the-issue Lhat - we argued -in the-motion fur 23 stay, is that the Government's position is that we can 24 unilaterally indict this man if we think he's breached the NPA. 25 We don't think that's right, but we have no buffer TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231627 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page13O151 13 1 between us and the Government. They'll say, and as the Court 2 knows, the Government has substantial power. The Government 3 does what it wants. Most of the time hopefully they're right. 4 Sometimes they make mistakes. 5 But in this particular instance, my client has rights. 6 we think that there's notice provisions, we think there's cure 7 provisions under the NPA. That's not what their paper says 8 under the circumstances. 9 And what we'd like to know from the Government, and 10 maybe the answer is basically what the Court asks is, let the 11 Government come forward today and say, based on the knowledge 12 that we have, or as of today's date, June 12th, 2009, we, the 13 Government, agree that there is no set of circumstances, not 14 that we're not aware of, but as of today's date, there is 15 nothing that exists that would be a violation of the NPA. 16 THE COURT: Well, that's way beyond what I'm 17 interested in. I don't know what Mr. Epstein may have done 18 outside the context of defending this case that may constitute 19 a violation. And if he has done something outside the context 20 of defending this case that's a violation, I don't care. 21 That's between the United States and Mr. Epstein. 22 —fl onty-concerned-about-wherher-anything he dows- lu 23 defending these civil actions is going to be a violation of the 24 non-prosecution agreement. If he has done something else, it's 25 none of my business, and I don't care, and I'm not going to TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231628 Case 9:08-cv-80119-KAM 1 2 3 Document 180 Entered on FLSD Docket 06/24/2009 Page 14 of 51 even ask the Government to give you an assurance that he hasn't done anything that might have violated the agreement up till today. I'm only interested in defending these civil actions. MR. CRITTON: Then I would respectfully submit to the 5 Court that the Government be asked in that limited context, are 6 they as of today, whether there were or not, but as of today is 7 there anything that has been done or will you take the 8 position, the United States, that any position that Mr. Epstein 9 has taken with regard to defending these civil cases is in any 10 way a violation of the NPA? 11 THE COURT: Well, I'm not sure what they're going to 12 say, but that might -- that cures the problem up to this point. 13 But then we have to deal with what's going to happen from here 14 on in. And that's another issue that we have to deal with. 15 II I understand your position. 16 But has anyone suggested to you on behalf of the 17 United States that there is something that you've done in 18 defending this case that they believe may or could be construed 19 as a violation of the non-prosecution agreement? Has anyone 20 pointed to anything that you've done? For example, the fact 21 that you've wanted to take their -- I don't know if you've -22 s--or-not- in- thircase7--but--tf- you've- sent- -- 23 notice of taking deposition, if you sent requests for 24 production of documents, if you sent interrogatories, if you 25 issued third party subpoenas? Is anything you've done thus far 14 TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231629 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 15 of 51 is 1 in the context of this case been brought to your attention as a 2 potential violation? 3 MR. CRITTON: I have received no notification nor am I 4 aware that we've received any notification of any action that 5 we have taken today. As I suggested to the Court, I don't know 6 when they've done or not. And in their papers they suggested, 7 well, we don't know everything that's gone on in the civil 8 litigation. 9 But from a practical standpoint, it was a number of 10 comments that were made in their papers is, we can indict, we 11 can see if there's a breach. 12 Judge, I may have some -- 13 THE COURT: Before you go on. 14 MR. CRITTON: I'm sorry. 15 THE COURT: You've focused a great deal on the 16 Government's response to my inquiry as supporting your position 17 that you're in jeopardy. But you've made the suggestion, even 18 before this brief was filed, that defending the case was going 19 to potentially result in an assertion or allegation that you 20 breached the non-prosecution agreement. 21 II what was it that caused you to make that initial 22- -assertion? Because-that' s-what caught Try attention, -was not 23 this brief that the Government has filed was in response to 24 something that you filed initially in your most recent motion 25 for a stay which raised the issue. TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231630 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 16of51 16 1 II what was it that gave you some concern to even 2 raise the issue that defending this case is going to constitute 3 a breach? 4 MR. CRITTON: Because there are other instances where 5 counsel other than myself, not in the civil aspects, where 6 allegations have been made and letters have been sent by the 7 United States suggesting that there's been a violation of the 8 NPA. And under those circumstances, some notification was 9 provided. 10 THE COURT: Did it have anything to do with defending 11 the civil actions? 12 MR. CRITTON: It did not. 13 THE COURT: then why was that issue raised by you 14 in the first instance? 15 MR. CRITTON: Because of the prospect that the 16 defendant could take, that the U.S. would take the position 17 under the circumstances that a position that we took with 18 regard to the contested litigation may well impact, that the 19 Government may have a very different view of what the 20 interpretation of the agreement is. 21 And as an example is a number of the parties, and I 22 ••esn•t want-to—get into a -discusston, the issuer-- 23 is, is under 2255 is that from the defendant's perspective the 24 deal that was cut on that, it was a very specific deal. It 25 dealt with both consensual and contested litigation. It dealt TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231631 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 17 of 51 17 1 with a secret list of individuals who we had no idea who was on 2 the list, and a commitment that he would under certain 3 circumstances be required to pay a minimum amount of damages, 4 which our position is under 2255 based upon the statute that 5 was in effect at the time, a $50,000 as to anyone who wanted -- 6 who came forward who was on the list and met certain criteria. 7 The position that now has been asserted by a number of B the plaintiffs under the circumstances, and it's been pled, and 9 actually a number of the complainants is, is Epstein agreed, 10 and they cite to a letter that was sent by ms. from 11 the Government, that says he has to plead guilty or he can't 12 contest liability. That may be true under very, very limited 13 or specific circumstances. 14 But what the plaintiffs have done in a number of the 15 cases, and these are pending motions, is they've said is, well, 16 we think C.M.A. cases is a good example, they've pled 30 17 separate counts of 2255 alleged violations. And they're saying 18 under the circumstances is, therefore, we have 2255 violations, 19 there's 30 of them, II 30 times 150, or should be, or whether 20 it's 150, that's the amount of money that we want, II maybe $15 21 million, or whatever the number is. • he- other p -laintl -ffs • lawyers have been - even￾23 more creative. They've said is, well, we'll agree that it's 24 only one cause of action but that each number of violations; 25 that is, if 20 alleged incidents occurred, that we would TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231632 Case 9:08-cv-80119-KAM 1 2 3 Document 180 Entered on FLSD Docket 06/24/2009 Page 18 of 51 consider to be, or that we will argue are violations, then we can take 20 times the 50, or the 150, depending on which statute is applicable. 4 II the Government under that set of circumstance could 5 say, and, again, this is one of the reasons that we raised it, 6 they could say, look, our deal with you was that you couldn't 7 contest liability, that you were waiving liability, or your 8 ability to contest an enumerated offense under 2255. 9 Again, part of the deal was as to an enumerated 10 offense. Okay. Well, what's that mean? What did he plead to? 11 Well, he really didn't plead to anything, which is another 12 issue associated with the 2255. But if the Government comes in 13 and says, no, wait a minute, our position was, is that you're 14 stuck with 2255 and the language within the NPA. And, 15 therefore, whether it's an offense or whether it's multiple 16 offenses or violations or each one represents an individual 17 cause of action, if the Government takes the position that's 18 adverse to what we think the clear reading of the agreement was 19 under those circumstances, they could claim a violation. 20 And as a result -- and that's one of the reasons we 21 put -- that was the most glaring one to us, II we raised that 22- issue. And Lien when- the GuveLLmIe,1t•s response came with 23 regard to, is we can just proceed to indict if we think that 24 there's been a breach of the agreement. 25 That puts us at substantial risk and chills our 18 TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231633 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 19 of 51 19 3 5 ability to move forward. Thank you, Your Honor. THE COURT: Thank you. Who wants to be heard from the plaintiffs first? Is there any plaintiff's attorney who is contending that the defense of these civil actions by Mr. Epstein is going 6 to constitute a breach of the non-prosecution agreement? MR. JOSEFSBERG: Your Honor, this is Bob Josefsberg. 8 May I speak? THE COURT: Yes, sir. 10 MR. JOSEFSBERG: We're not quite confident that any 11 breaches of any agreement, which were third-party 12 beneficiaries, should be resolved by you. We're not saying it 13 shouldn't. But we have not raised any breach of agreement. we 14 think that is between the United States and Mr. Epstein. 15 What I find incredulous and disingenuous is that 16 Mr. Epstein is saying that he wants a stay because he may be 17 forced into taking actions in the defense of this case that 18 would violate the agreement. 19 And let me make our position clear on that. If he 20 wants to move to take depositions, interrogatories, production, 21 and they are according to your rulings appropriate, not -22 rivacy of- someone, and they are relevant, ,MI. 23 I don't know how those could in any way be violations of the 24 agreement. 25 What I find hypocritical is that there are two parts TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231634 Case 9:08-cv-80119-KAM 1 2 3 Document 180 Entered on FLSD Docket 06/24/2009 Page 20 of 51 20 to the agreement that I am a beneficiary of. One of them is that he has agreed that on any action brought in the 2255, he will admit to liability. 4 And I received on May 26 a motion to dismiss, which 5 we're prepared to respond to and disagree with, but totally 6 contesting liability, saying that the statute doesn't apply 7 because the girls are no longer minors and saying, and this is 8 the great one, saying that the predicate of the conviction 9 under 2255 has not been satisfied. 10 Now, the understanding that I have is the agreement 11 between the Government and Mr. Epstein was that the Government 12 desired to see these victims made whole, and wanted them to be 13 in the same position as if Mr. Epstein had been prosecuted and 14 pled or convicted. And they would be able to have the 15 predicate of that criminal conviction, which just as a matter 16 of liability would just be introduced as proof that he's done 17 this. 18 They, under the agreement, are supposed to admit to 19 liability on limited something that's under 2255. He has 20 filed, but since there is no conviction, there can be no civil 21 suit under 2255, with which we disagree. But it is totally in -22- laik; 23 The second part is there are many young ladies, and 24 this perhaps he can use this to his great advantage, who are 25 humiliated about this entire situation. Some of them won't TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231635 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 21 of 51 2 1 come forward. 2 We were appointed by Judge as a Special Master 3 I to represent these young ladies. And some of them don't even 4 want to file suit. They don't even want to be known as Jane 5 Doe 103. They don't want any of the risks for these motions 6 that are pending. 7 And part of the agreement was that if we represented it 8 them and they settle, Mr. Epstein would pay our fees. And he 9 has written us as of yesterday that he is under no obligation 10 to pay our fees on settling cases. 11 Now, those two matters, I believe, may be breaches. 12 But I am not asking this Court at this time to do anything 13 about them. Nor am I telling the Government, I'm not running 14 to the Government and saying indict him because I want you to 15 pressure him to do what he agreed to. 16 I'm a third-party beneficiary for that agreement, and 17 I may move to enforce certain parts of it. But as far as the 18 issue of staying the litigation, that is the exact opposite of 19 the intent and the letter of the NPA. The purpose of the NPA 20 was II that these 34 young ladies, these victims who have been 21 severely traumatized, may move on with their lives. 22 tay-this-actton-woult -be-the- exact opposite- of 23 the purpose of that agreement and would be horrible 24 psychologically for all of my clients. 25 THE COURT: Mr. Josefsberg, I understand your TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231636 Case 9:08-cv-80119-KAM 1 2 3 Document 180 Entered on FLSD Docket 06/24/2009 Page 22 of 51 position. And I don't want to argue the merits of whether a stay should or should not be granted. I'm just trying to understand what the ground rules 4 are going to be if I grant a stay or if I deny a stay. And 5 I've already denied a stay once. I have to decide this current 6 motion, and I just want to know what is going to happen if I 7 deny the stay in terms of Mr. Epstein's exposure under the 8 non-prosecution agreement. That's my concern. 9 II if you're telling me that you're not going to urge 10 the United States, on behalf of any of your clients, to take 11 the position that he's breached the agreement because he's 12 taking depositions, because he's pursuing discovery, because 13 he's conducting investigations that anyone in any other type of 14 civil litigation might conduct with respect to plaintiffs that 15 are pursuing claims against a defendant, that those typical 16 types of actions, in your judgment, are not breaches of the 17 agreement and that he can go forward and defend the case as any 18 other defendant could defend, and you're not going to run to 19 the United States and say, hey, he's breaching the agreement by 20 taking depositions and he's breaching the agreement by issuing 21 subpoenas to third parties in order to gather information 22- necessary- to defend, then -I don-4t have a -problem-. -But tf he's 23 going to be accused of breaching the agreement because he sends 24 out a notice of deposition of one of your clients, how is he 25 supposed to defend the case? 22 TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231637 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 23 of 51 23 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 23 24 25 MR. JOSEFSBERG: Your Honor, you're totally correct. He can depose my client. That's not a problem. But the problem is that these are not typical clients and this is not a typical case. He has written in his pleadings that he wants to publish the names of these girls in the newspapers II that other people may come forward to discuss their sexual activities with these different plaintiffs. That's not your typical case. But are rulings that you'll make in this case, and they're not part of the TPA. As far as my going to the Government is concerned, I find it very uncomfortable for me to use the Government to try to pursue my financial interest in litigation. And I know that Mr. Epstein and his counsel will make much ado about it. I am not going to be running there. However, if they start taking depositions regarding liability, I will consider that to be a breach because they're supposed to have admitted liability. THE COURT: But, again, I don't have the agreement and I don't remember reading the agreement. But what I'm being told is the part of the agreement that admits liability is only as to a 2255 claim, and there are numerous other personal injusytort c ms- other than 225- cl im . And there's a limit of damages on the 2255 claim, as I understand it, but I presume that all the plaintiffs are going to seek more than the limited or capped amount of damages in TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231638 Case9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 24 of 51 24 1 the non-prosecution agreement as to the other claims. 2 And II why aren't they entitled to defend and limit 3 the amount of damages that your client is seeking on the 4 non-2255 tort claims? 5 MR. JOSEFSBERG: Your Honor, you are correct. On 6 non-2255 tort claims, they are permitted to do the defense, 7 whatever is appropriate. 8 My cases are pure 2255 on which liability under the 9 agreement is supposed to be admitted. Now, as to the amount of 10 damages, there are legal issues that will be before you and 11 under the C.M.A. cases that are getting before you, as to 12 whether it is 50 or 150. That has nothing to do with the NPA. 13 There are legal issues that are before you as to 14 whether it is per statute, per count. or per incident or per 15 plaintiff. Those have nothing to do with the NPA. There is no 16 amount in NPA. Those will be resolved. 17 Anyone who has brought a case that is outside of 2255, 18 the defense is permitted to contest liability under the NPA. 19 That's no violation. 20 Under the NPA if someone brought a case under just 21 2255, Mr. Epstein, if he is to keep his word, cannot contest 2 ltty. And here-wou₹d-no need—to—stay this. Because it 23 is a self-fulfilling agreement. He can contest liability. And 24 as far as the amount of damages, anyone that wants to go over 25 the statutory minimums, of course, he can contest that in any TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231639 Case 9:08-cv-80119-KAM 1 2 3 Document 180 Entered on FLSD Docket 06/24/2009 Page25of51 25 way that is proper under the Rules of Evidence and your rulings. The NPA has no limitation on his contesting damages above the minimum statutory amount. 4 The only thing that he has done is in his actions of 5 refusing to pay for settling defendants, and in his saying that 6 he has no liability under 2255, those appear to be contrary to 7 what's in the NPA. 8 But I'm not in any position right now to claim a 9 breach, and I don't know whether I'd be claiming a breach or 10 enforcing it in front of you, suing him for fees, asking you to 11 have him admit liability, or complaining to the Government. 12 And that's why I'm not that helpful in this situation because I 13 think it's the Government's role. 14 But I do not waive the right to be a third-party 15 beneficiary because pursuant to my appointment, which was 16 agreed to by Mr. Epstein, I and my clients have certain rights, 17 and we want to enforce them. 18 But his defending this lawsuit will not in any way be 19 a violation. His getting this lawsuit stayed would be a 20 violation of the spirit of taking care of these girls, and 21 there would be other issues. Like if there is a stay, Your -22 Honor, -would-he be—posting a bond? 23 THE COURT: We don't need to talk about those issues. 24 That's not my concern. 25 MR. JOSEFSBERG: I agree, Your Honor, we don't. TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231640 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 26 of 51 26 1 THE COURT: That's not my concern. II, again, I just 2 want to make sure that if the cases go forward and if 3 Mr. Epstein defends the case as someone ordinarily would defend 4 a case that's being prosecuted against him or her, that that in 5 and of itself is not going to cause him to be subject to 6 criminal prosecution. 7 MR. JOSEFSBERG: I agree, Your Honor. 8 THE COURT: Any other plaintiff's counsel want to 9 chime in? 10 MR. WILLITS: Richard Willits on behalf of C.M.A.. I 11 would join, to weigh in on what Mr. Josefsberg said. 12 MR. JOSEFSBERG: Your Honor, I could not hear. 13 THE COURT: We'll get him to a microphone. 14 Mr. Willits is speaking. 15 MR. WILLITS: On behalf of my client, C.M.A., we join 16 in what Mr. Josefsberg said, and we also want to point out 17 something to the Court. 18 First, we want to make a representation to the Court, 19 we have no intention of complaining to the U.S. Attorney's 20 Office, never had that intention, don't have that intention in 21 the future, but, of course, subject to what occurs in the 22 23 I want to point out to the Court that Mr. Epstein went 24'x, into this situation with his eyes wide open, represented by 25 counsel, knowing that civil suits had to be coming. If he TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231641 Case9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 27 of 51 27 1 didn't know it, his lawyers knew it. 2 He appears to be having second thoughts now about he 3 could have negotiated this way or he could have negotiated that 4 way with the U.S. Attorney's Office. And they want to impose 5 their second thoughts on the innocent plaintiffs. We don't 6 think that's fair. We think it's in the nature of invited 7 error, if there was any error whatsoever. 8 Thank you. 9 THE COURT: You agree he should be able to take the 10 ordinary steps that a defendant in a civil action can take and 11 not be concerned about having to be prosecuted? 12 MR. WILLITS: Of course. And we say the same thing 13 Mr. Josefsberg said. It's all subject to your rulings and the 14 direction of this Court as to what is proper and what is not 15 proper. And we're prepared to abide by the rulings of this 16 Court, and we have no intention of running to the State's 17 Attorney. 18 THE COURT: The U.S. Attorney? 19 MR. WILLITS: I'm sorry. The U.S. Attorney. 20i THE COURT: Mr. Garcia. 21 MR. GARCIA: Thank you, Your Honor. briefly7- 1--ttrindt-perhaps -defense counsel - 23 forgot about this, but on pages 17 and 19 of my memorandum of 24 law in opposition to the motion to dismiss, I did make 25 reference to the non-prosecution agreement, and I did say that TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231642 Case9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 28 of 51 28 1 2 3 4 5 6 7 8 9 10 11 12 the contesting of the jurisdiction of this Court was a potential breach of the non-prosecution agreement. my client happens to have, and they have filed with the Court a copy of her state court complaint, given the fact that the non-prosecution agreement limits the non-contesting of jurisdiction to claims exclusively brought under the federal statute. I'm going to go ahead and withdraw those contentions on pages 17 and 19 of my memo of law because it doesn't apply to my case. II to the extent that I raised this issue with defense counsel and the Court, I'm going to withdraw that aspect of it. 13 THE COURT: Can you file something in writing on that 14 point with the Court? 15; MR. GARCIA: Yes. 16 THE COURT: What do you say about this issue that 17 we're here on today? 18 MR. GARCIA: I think that the problem that I have with 19 it is that this non-prosecution agreement is being used by 20 defense counsel for the exact opposite purpose that it was 21 intended. My perception of this thing, and I wasn't around, is 22 Eusenzially bought ?MT -way out of a criminal 23 prosecution, which is wonderful for the victims in a way, and 24 wonderful for him, too. 25I Now he's trying to use the non-prosecution agreement TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231643 Case 9:08-cv-80119-KAM 1 2 3 4 5 Document 180 Entered on FLSD Docket 06/24/2009 Page 29 of 51 as a shield against the plaintiffs that he was supposed to make restitution for. And, certainly, he can take my client's depo. He's done extensive discovery in the state court case -- very intrusive, I might add. And we don't care, because we can win 6 this case with the prosecution agreement or without the 7 prosecution agreement. We are ready to go forward. 8 THE COURT: You're not going to assert to the United 9 States Government that what he's doing in defending the case is 10 a violation for which he should be further prosecuted? 11 MR. GARCIA: Absolutely not. 12 THE COURT: Anyone else for the plaintiffs? 13 MR. HOROWITZ: Judge, Adam Horowitz, counsel for 14 plaintiffs Jane Doe 2 through 7. 15 I just wanted to address a point that I think you've 16 articulated it. I just want to make sure it's crystal clear, 17 which is that we can't paint a broad brush for all of the 18 cases. 19 The provision relating to Mr. Epstein being unable to 20 contest liability pertains only to those plaintiffs who have 21 chosen as their sole remedy the federal statute. My clients, 22- tr--7,---have -elected- to--bring additions₹ cause-s---- 23 of action, and it's for that reason we were silent when you 24 said does anyone here find Mr. Epstein to be in breach of the 25 non-prosecution agreement. That provision, as we understand 29 TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231644 Case 9:08-cv-80119-KAM 1 2 3 Document 180 Entered on FLSD Docket 06/24/2009 Page 30 of 51 it, it doesn't relate to our clients. THE COURT: Okay. But, again, you're in agreement with everyone else II far that's spoken on behalf of a 4 plaintiff that defending the case in the normal course of 5 conducting discovery and filing motions would not be a breach? 6 MR. HOROWITZ: Subject to your rulings, of course, 7 yes. 8 THE COURT: Thank you. 9 Anyone else have anything to say from the plaintiffs? 10 Ms. , if you would be II kind as to maybe 11 help us out. I appreciate the fact that you're here, and I 12 know you're not a party to these cases and under no obligation 13 to respond to my inquiries. But as I indicated, it would be 14 helpful for me to understand the Government's position. 15 MS. . Thank you, Your Honor. And we, of 16 course, are always happy to try to help the Court as much as 17 possible. But we are not a party to any of these lawsuits, and 18 in some ways we are at a disadvantage because we don't have 19 access. My access is limited to what's on Pacer. I don't 20 really know what positions Mr. Epstein may have taken either in 21 correspondence or in discovery responses that aren't filed in 2- -the case file. 23 But your first order was really just what do you think 24 about a stay, and then the second order related to this hearing 25 and asked a much more specific question, which is whether we 30 TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231645 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 31 of 51 31 1 believe that Mr. Epstein's defense was a breach of the 2 agreement. 3 And I've tried to review as many of the pleadings as 4 possible. As you know, they're extremely voluminous. And I 5 haven't been through all of them. But we do believe that there 6 has been a breach in the filing that Mr. Josefsberg referred 7 to, and contrary to Mr. Critton, we do understand that we have 8 an obligation to provide notice, and we are providing notice to 9 Mr. Epstein today. 10 The pleading that we found to be in breach -- the 11 non-prosecution agreement, sought to do one thing, which was to 12 place the victims in the same position they would have been if 13 Mr. Epstein had been convicted of the federal offenses for 14 which he was investigated. 15 And that if he had been federally prosecuted and 16 convicted, the victims would have been entitled to restitution, 17 regardless of how long ago the crimes were committed, 18 regardless of how old they were at the time, and how old they 19 are today, or at the time of the conviction. 20 And it also would have made them eligible for damages 21 under 2255. 22 idea was, our hope was -that -we -could-set￾23 a system that would allow these victims to get that restitution 24 without having to go through what civil litigation will expose 25 them to. TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231646 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 32 of 51 32 1 You have a number of girls who were very hesitant 2 about even speaking to authorities about this because of the 3 trauma that they have suffered and about the embarrassment that 4 they were afraid would be brought upon themselves and upon 5 their families. 6 we did through the non-prosecution agreement tried 7 to protect their rights while also protecting their privacy. 8 ■, pursuant to the non-prosecution agreement -- on the other 9 hand, we weren't trying to hand them a jackpot or a key to a 10 bank. It was solely to sort of put them in that same position. 11 II we developed this language that said if -- that 12 provided for an attorney to represent them. Most of the 13 victims, as you know from the pleadings, come from not wealthy 14 circumstances, may not have known any attorneys who would be in 15 a position to help them. 16 we went through the Special Master procedure that 17 resulted in the appointment of Mr. Josefsberg, and the goal was 18 that they would be able to try to negotiate with Mr. Epstein 19 for a fair amount of restitution/damages. And if Mr. Epstein 20 took the position, which apparently he has, which is that the 21 $50,000 or $150,000 floor under 2255 also would be a cap. That 22 if they were to proceed to file suit in Federal Court to get 23 fair damages under 2255, Mr. Epstein would admit liability, but 24 he, of course, could fight the damages portion, which means 25 that, of course, he would be entitled to depositions; of TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231647 Case9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 33 of 51 33 1 course, he would be entitled to take discovery, and we don't 2 believe that any of that violates the non-prosecution 3 agreement. 4 The issue with the pleading that he filed, the motion 5 to dismiss the case, I believe it's Jane Doe 101, represented 6 by Mr. Josefsberg, is that that is a case that was filed 7 exclusively under 18 U.S.C., Section 2255. She met that 8 requirement. Mr. Epstein is moving to dismiss it, not on the 9 basis of damages, he is saying that he cannot be held liable 10 under 2255 because he was not convicted of an offense. 11 The reason why he was not convicted of an offense is 12 because he entered into the non-prosecution agreement. II that 13 we do believe is a breach. 14 The issue really that was raised in the motion to stay 15 and that I addressed in our response to the motion to stay is 16 that Mr. Epstein's -- Mr. Epstein wants to stay the litigation 17 in order to leave, in order to sort of attack the cases of the 18 victims whether they are fully within the non-prosecution or 19 not, non-prosecution agreement or not, and leave the Government 20 without a remedy if he does, in fact, breach those terms. And 21 that is why we opposed the stay. -THE COURT:- I'm not sure what you mean by that last 23 statement. 24 MS. : Well, because this issue related to 25 the motion to dismiss on Mr. Josefsberg's client came up after TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231648 Case9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page34of51 34 1 we had filed that response. And what we said in the response 2 to the motion to stay is that the reason why he wants to stay 3 the litigation is II that the non-prosecution agreement 4 terminates based on a period of time, as he puts it. And then 5 afterwards he would be able to come in here and make all of 6 these arguments that clearly violate the non-prosecution 7 agreement but we would be without remedy. 8 THE COURT: But you're not taking the position that 9 other than possibly doing something in litigation which is a 10 violation of an express provision of the non-prosecution 11 agreement, any other discovery, motion practice, investigations 12 that someone would ordinarily do in the course of defending a 13 civil case would constitute a violation of the agreement? 14 MS. No, Your Honor. I mean, civil 15 litigation is civil litigation, and being able to take 16 discovery is part of what civil litigation is about. And while 17 there may be, for example, if someone were to try to subpoena 18 the Government, we would obviously resist under statutory 19 reasons, all that sort of stuff. But, no, Mr. Epstein is 20 entitled to take the deposition of a plaintiff and to subpoena 21 1 records, etc. T: And even if he seeks-discovery -a ------ 23 Government agency, you have the right to resist it under the 24 rules of procedure but that would not constitute a violation, 25 again unless there's a provision in the prosecution agreement TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231649 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 35 of 51 35 1 that says I can't do this? 2 MS. : Correct. 3 THE COURT: That's your position? 4 MS. : Yes. 5 THE COURT: Thank you. 6 MS. : Thank you, Your Honor. 7 THE COURT: Mr. Critton, did you want to add anything? 8 MR. CRITTON: Yes, sir. Just a few responses to some 9 of the issues that have been raised. 10 The most glaring, at least from our perspective, is 11 both Mr. Josefsberg's comments that he believes that there's a 12 violation of the NPA as well as Ms. with regard to 13 Jane Doe 101. 14 Mr. Josefsberg, while he was the attorney rep who was 15 selected by Judge to represent a number of individuals, 16 alleged victims that may have been on the list, he represents 17 many of them. And the type of response that was filed in 101 18 would probably be very similar to what we will file if he 19 files -- and he filed 102 as well. But if he files 103, 104 20 and 105, or whatever number he files, we may well take that 21 same legal position in our motions and in our response or in 22-I rep y. 23 And what we've been, in essence, told today is we 24 consider that to be a violation of the NPA under the 25 circumstances. TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231650 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 36 of 51 36 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 102 is a perfect example that he filed is, we have e-mails going back and forth between the Government and my clients' attorneys at the time that suggested that 102 probably doesn't even fit within the statute of limitations. II under Mr. Josefsberg's argument is as well, we've only brought a 2255 claim. We don't care whether she's within or is outside the statute of limitations. Because she was on the list and under the circumstances, he has to admit liability, which we contest is under that set of circumstances you're stuck with it. You can fight damages if you can, but she's a real person and you can't raise statute of limitations. The other point that kind of strikes out is there's probably a difference. And I'm happy to provide a copy of the NPA or a redacted portion of the NPA which deals with the civil issues, which are paragraphs 7, 8, 9 and 10, and the entire addenda in camera for the Court to look at, if plaintiff's counsel and the Government, I guess, really, because they're not a party, is if they have no objection because they all have access based on a prior court order to the non-prosecution agreement. II I'm happy to provide that to the Court today and show it to counsel so Ehat the Court can review that-. But our position with regard to the 2255 claims is that -- there were two types of claims that could be filed, one was consensual litigation, the second was contested litigation. TOTALACCESSCOURTROOMNEnNORKRENJIMETRANSCRIFTION EFTA00231651 Case9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 37 of 51 37 1 And under the consensual, in essence, which Mr. Epstein did, is 2 he's offered $50,000 of the statutory minimum for that time 3 period to all of those individuals. 4 THE COURT: Can I interrupt you a second? 5 MR. CRITTON: Yes, sir. 6 THE COURT: I'm not here, and I don't believe it's my 7 role to decide whether or not there is or is not a breach of 8 the agreement. I'm just trying to understand what the 9 Government's position is regarding your defending these cases. 10 Now, I'm just saying this as an example. If, for 11 example, in the non-prosecution agreement there was a provision 12 that said explicitly: Jeffrey Epstein shall not move to 13 dismiss any claim brought under 2255 by any victim no matter 14 how long ago the allegations or the acts took place, period. 15 If that was in the agreement and you filed a motion to 16 dismiss by someone who brought a claim, it might sound like it 17 'i might be a violation. 18 MR. CRITTON: I agree. 19 THE COURT: II you would know that when you filed your 20 motion because it was right there for you to read. 21 And II to stay the case because I want to do something 22 t at t e contract expressly prohibits me from doing, II it-AYr 23 the case until the agreement expires II then I can do something 24 that the agreement said I couldn't do II you won't be in fear 25 of prosecuting, I'm not sure that that is what I'm concerned TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231652 Case9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 38of51 38 1 about. 2 I'm concerned about discovery, investigation, motion 3 practice, that's not prohibited by a provision of the 4 agreement. If there's something that's prohibited by the 5 agreement that you, knowing what the agreement says, go ahead 6 and do, anyway, I guess that's a risk you're going to have to 7 take. If there's a legitimate dispute about it, I guess some 8 I arbiter is going to decide whether it's a breach or not. 9 But, again, that's something you and Mr. Burman, 10 Mr. Goldberger, and you are all very good lawyers, and he's got 11 a whole list of lawyers representing him, and you've got the 12 i agreement and you're going to make legal decisions on how to 13 proceed, and you're going to have to go and make your own 14 decisions. 15 I'm concerned about things that aren't in the 16 agreement, that aren't covered, that you're going to be accused 17 of violating because, again, you take depositions, you send out 18 subpoenas, you file motions that are not prohibited by the 19 agreement. And that's what I'm concerned about. 20 MR. CRITTON: And I understand that, Your Honor. 21 But at the same time, it's as if the lawyers and the c ien s, •ase• upon our interpretation of the agreement, and, 23 believe me, we would not have filed 101, the motion to dismiss, 24 but for believing that there was a good basis to do that 25 under the circumstances. TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231653 Case9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 39 of 51 39 1 And now, in essence, we're being accused not only by 2 -- not accused, but it's been suggested that there's a breach 3 of the NPA, not only by Mr. Josefsberg on behalf of 101, but as 4 well Ms. on behalf of the United States. 5 That's the perfect example. They're basically saying 6 we think you violated. We may send you notice under the 7 circumstances. II does that mean that on 101 we have to back 8 off of it because we think in good that it's a motion and 9 is that something that this Court ultimately will rule? 10 THE COURT: I don't know that I'm the one who is going 11 to make that decision. Again, that's not the kind of thing 12 that I was concerned about. I was more concerned about the 13 normal, ordinary course of conducting and defending a case that 14 would not otherwise expressly be covered under the agreement, 15 that you're going to then have someone say, II, he's sent a 16 notice of deposition, he's harassing the plaintiffs. I don't 17 know if there's a no contact provision in the agreement or no 18 harassment type of provision in the agreement. II, this is a 19 breach because you sent discovery, or he's issuing subpoenas to 20 third parties trying to find out about these victims' 21 backgrounds, he's breaching the agreement. 22 T ose are e kind of things that I was worries a•ou 23 MR. CRITTON: The concern that we have is as part of 24 doing this general civil litigation, it's not just the 25 discovery process. And I understand the issues that the Court TOTAL ACCESS COURTROOM NETWORKREALTIMETRANSCRIPT1ON EFTA00231654 Case 9:08-cv-80119-KAM 1 2 3 Document 180 Entered on FLSD Docket 06/24/2009 Page40of5140 has raised. But part of it is that often cases are disposed of either on a summary basis or certainly legal issues that come 4 before the Court during the course of the case, just like in a 5 criminal case. That's clearly part of the, I'd say the defense 6 of the case under the circumstances; and if, in fact, an 7 individual can't legally bring a cause of action for certain 8 reasons, such as has been suggested in 101, and may be 9 suggested in 102 when that pleading is filed, that certainly is 10 a position that puts my client at risk. 11 As another example that I use with C.M.A., that they 12 filed this 30-count complaint. Now, they have the state court 13 claims as well. But they, in essence, have said they filed 14 another pleading with the Court that says depending on what the 15 Court rules, in essence, on whether we can file multiple claims 16 or one cause of action with multiple violations, we may dump 17 the state court claims and, therefore, we'll just ride along on 18 that. That's a very different -- 19 Mr. Epstein would never have entered into, nor would 20 his attorneys have allowed him to enter into that agreement 21 under those circumstances where he had this unlimited -22 ia•1 1 y. a clear-Iywas never envisioned by any o£ the 23 defendants -- by the defendant or any of his lawyers under the 24 circumstances. 25 And if that's claimed to be a violation, either by the TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231655 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 41 of 51 41 1 attorneys; i.e., he's not recapitulating on liability under the 2 2255, and that's all we have now. That's our exclusive remedy. 3 I And the Government says, yeah, that's right, that's a 4 violation of the NPA. It again chills us from moving forward, 5 filing the necessary motion papers and taking legal positions 6 that may put my client at risk for violating the NPA and then 7 creating the irreparable harm of, after having been in jail, 8 after having pled guilty to the state court counts, after 9 registering on release as a sex offender, he's complied and 10 done everything, taken extraordinary efforts to comply with the 11 NPA, puts him at substantial risk. And that's what our worry 12 is moving forward. 13 MR. JOSEFSBERG: Your Honor, may I be heard. May I 14 make three comments? It will take less than a minute. 15 THE COURT: Yes, sir. 16 MR. JOSEFSBERG: Mr. Critton refers to the alleged 17 victims. I want you to know that our position is that pursuant 18 to the NPA they're not alleged victims. They are actual, real 19 victims, admitted victims. 20 Secondly, he argues about the statute of limitations 21 on 102. I know that you don't want to hear about that, and I'm 22 no going o commen about it. Milt please don't take our lack 23 of argument about this as being we agree with anything. 24 Last and most important, we totally agree with 25 Mr. Critton in his suggestion that he hand you a copy of the TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231656 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 42 of 51 42 1 NPA. I think that many of the questions you asked will be 2 answered when you read the NPA, and I think it's very unfair of 3 everyone who is sitting in front of you who have the NPA to be 4 discussing with you whether it's being breached, whether there 5 should be a stay when you're not that familiar with it. 6 If we would give you a copy of it, I think it would be 7 much more helpful in making your ruling. 8 THE COURT: Maybe Judge Colvat will resolve this issue 9 for me. 10 MR. JOSEFSBERG: Even if he doesn't, Your Honor, I 11 believe we are allowed to show it to you. 12 THE COURT: I'll tell you what: I'll wait for Judge 13 Colvat to rule, and then if he rules that it should remain 14 sealed, then I'll consider whether or not I want to have it 15 submitted to me in camera. 16 Anything else, Mr. Josefsberg? 17 MR. JOSEFSBERG: No. I thank you on behalf of myself 18 and the other counsel on the phone for permitting us to appear 19 by phone. 20 THE COURT: All right. Anyone else have anything they 21 want to add? 22 MR. isUNARDST--Bi-ad Edwards on beElliM Jane Doe. 23 I only had one issue here, and when I read your motion 24 that you wanted to hear on the narrow issue of just defense in 25 the civil actions filed against him violates the TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00231657 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 43 of 51 43 1 non-prosecution agreement, I was expecting that we were going 2 to hear something from the Government similar to the affidavit 3 that was filed by Mr. Epstein's attorneys wherein he indicates 4 as of the day of this affidavit attached to the motion to stay, 5 the U.S. Attorney's Office has taken the position that Epstein 6 has breached the non-prosecution agreement and it names 7 specifically investigation by Epstein of this plaintiff and 8 other plaintiffs, Epstein's contesting damages in this action. 9 Epstein, or his legal representatives, making statements to the 10 press. And we didn't hear any of those things. 11 So that's what I was expecting that the U.S. 12 Attorney's Office was going to expound on and say, yes, we've 13 made some communications to Epstein. He's violating. 14 1 What we're hearing right now, today, just so that I'm 15 clear, and I think the Court is clear now, is that the 16 non-prosecution agreement is what it is. There have been no 17 violations, but for maybe what Mr. Josefsberg brought up. 18 But there are very few restrictions on Mr. Epstein. 19 He went into this eyes wide open. And whether or not I agree 20 with the agreement, how it came to be in the first place, is 21 neither here nor there. 2-2 ere—have been no violations or -breaches up to 23 this point. And his affidavit that was filed, I'm just 24 troubled by where it even came from. I mean, it's making 25 j specific allegations that the U.S. Attorney's Office is TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION _we EFTA00231658 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 44 of 51 44 1 4 5 6 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 threatening a breach, and this is part of the motion to stay, which we're all battling here. So I just wanted to indicate to the Court or remind the Court that there have been specific allegations made, the United States Attorney's Office is making these allegations of breach, which we haven't heard any of the evidence of. Thank you. THE COURT: All right Ms. , did you want to respond to that suggestion that there were other allegations of breach besides the one that you've just mentioned today? MS. : No, Your Honor. THE COURT: Thank you. I appreciate your giving me the information, which I think has been very helpful today, and I'll try and get an order out as soon as possible. (Court adjourned at 11:10 a.m.]. CERTIFICATE I hereby certify that the foregoing is an accurate transcription of proceedings in the above-entitled matter. DATE s/Larry Herr LARRY HERR, RPR-CM-RMR-FCRSC Official United States Court Reporter 400 N. Miami Avenue Miami, FL 33128 - 305/523-5290 (Fax) 305/523-5639 email: Lindsay165eaol.com Quality Assurance by Proximity Lingulbase Technologies EFTA00231659 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 45 ota, against 4:23,25 6:24 22:15 26:4 29:1 42:25 16:10 18:11 21:12 301 35:7 4123 42:16,20 43:6 bindle 7:15.17 19:11 21:11 22:16 A B abide 27:15 ability 18:8 19:1 back 12:18 36:2 39:7 backgrounds 39:21 able 20:14 27:9 agency 34:23 anyway 38:6 balance 12:15 4322 32:18 34:5,15 ago 31:17 37:14 apparently 32:20 bank 32:10 breaching 22:19,20 about 4:24 5:25 6:10 agree 13:13 17:23 appear 3:1925:6 based 6:12 10:7 12:6 22:23 39:21 6:18 9:2 11:15 25:25 26:7 27:9 42:18 13:11 17:4 34A brief 15:18,23 13:22 20:25 21:13 37:18 41:23,24 appearance 1:12 36:19 38:22 briefing 5:4 23:13 25:23 27:2 43:19 3:3,25 basically 7:16 13:10 briefly 27:22 27:11,23 28:16 agreed 179 202 appears 27:2 39:5 bring 29:2240:7 30:24 32:2,2,3 21:15 25:16 applicable 6:13 18:3 basis 33:9 38:24 broad 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Entered on FLSD Docket 06/24/2009 Page 46 o 46 29:3 40:3,9 committed 31:17 course 7:5 24:25 21:2 35:15 39:19,25 Certified 2:22 communications 2621 27:12 30:4,6 day 43:4 discretionary 6:19 certify 44:18 43:13 30:1632:24,25 deal 9:23 14:13,14 6:21 change 7:25 complainants 17:9 33:1 34:1239:13 15:15 16:24,24 discuss 9:2223:6 changes 7:8 complaining 25:11 40:4 18:6,9 discussing 42:4 charges 5:3 26:19 court 1:1 2:22 3:1,6 deab 36:14 discussion 16:22 chilling 9:7 complaint 28:4 3:9,12,15,20,22,24 dealt 6:19 16:25,25 disingenuous 19:15 chills 10:9 18:25 40:12 4:4,7,11,15,20 decide 10:11 22:5 dismiss 7:22 8:18 41:4 compliance 12:14 5:11,14,18,19,21 37:7 38:8 10:14 20:4 27:24 chime 26:9 complied 41:9 5246:6,11,13,14 decision 39:11 33:5,8,2537:13,16 chosen 29:21 comply 41:10 6:18,20,21,22 7:6 decbioas 38:12,14 38:23 circumstance 7:21 concern 4:24 5:10,24 8:1 9:6 11:3,10,25 deem 11:19 disposed 40:2 8:18 18:4 9:20 16:1 22:8 12:1913:1,10,16 deemed 10:4 dispute 38:7 circumstances 9:25 25:24 26:1 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QUINNEY COLLEGE OF LAW THE UNIVERSITY OF UTAH Wifredo A. Ferrer United States Attorney Southern District of Florida 99 N.E.4th Street Miami, FL 33132 G. CASSELL Ronald N. Boyce Presidential Professor of Criminal Law Telephone: December 10, 2010 Re: Request for Investigation of Jeffrey Epstein Prosecution Dear Mr. Ferrer: I am writing as someone with extensive experience in the federal criminal justice system — as a former Associate Deputy Attorney General, Assistant United States Attorney, federal judge, and currently criminal law professor — to alert you to what seems to be the most suspicious criminal case I have ever encountered. I ask that you investigate whether there were improper influences and actions during your office's criminal investigation of Jeffrey Epstein, particularly regarding the decision to enter into a binding non-prosecution agreement blocking his prosecution for numerous federal sex offenses he committed over many years against more than thirty minor girls. As I am sure you are well aware, in 2006 your office opened a criminal investigation with the FBI into allegations that for years Jeffrey Epstein sexual abused dozens of minor girls in his West Palm Beach mansion. The FBI soon developed compelling evidence that Epstein had in fact committed numerous federal sex offenses with more than 30 minor girls. And yet, your office ultimately entered into a plea arrangement which allowed Epstein escape with a non￾prosecution agreement that ensured he would have no federal criminal liability and would spend no more than 18 months in state jail. For sexual offenses of this magnitude — in a case with more than 30 witnesses providing interlocking testimony, all made automatically admissible by virtue of Fed. R. Evid. 414 — this is an extraordinary outcome. Why did your office enter into this highly unusual non-prosecution arrangement with Epstein? Suspicion begins with the point that Epstein is a politically-connected billionaire. But that wouldn't be troubling without considerable other evidence that something went terribly wrong with the prosecution for other, improper reasons. Consider the following highly unusual facts: First, it appears that Epstein was tipped off before the execution of a search warrant at his home. We know that lead state police officers -- Detective and Police Chief Michael -- complained that the house was "sanitized" by the time they arrived to serve a search warrant for child pornography. This sanitation was evident by the various computer wires hanging with no computers attached. Housekeeper Janusz Banasiak later testified In a civil www.law.utah.edu • Main Office • Facsimile 332 South 1400 East, Room 101 • Salt Lake City, Utah 84112-0730 EFTA00231667 deposition that Epstein's assistant, (M) and another man (unknown) were instructed to remove, and did in fact remove, multiple computers from Epstein's home shortly before the search warrant was served. The fact that there could well have been a tip off is apparently suspected by federal authorities. Second, there is evidence that one of the senior prosecutors in your office joined Epstein's payroll shortly after important decisions were made limiting Epstein's criminal liability — and improperly represented people close to Epstein. During the federal investigation of Epstein, Bruce Reinhart was a senior Assistant U.S. Attorney in your office. As we understand things, he was a direct supervisor of the line prosecutor handling the case and thus was well aware of details of the Epstein investigation and plea negotiations. We further believe that he was consulted on issues related to the prosecution of Epstein and Epstein's co-conspirators, including specifically issues related to whether Epstein employees and pilots should be prosecuted for their involvement in Epstein's sexual offense. We further believe that he personally and substantially participated in making such decisions about the course of the criminal investigation. Within months after the non-prosecution agreement was signed by your office, Reinhart left your office and immediately went into private practice as a white collar criminal defense attorney. His office coincidentally happened to be not only in the same building (and on same floor) as Epstein's lead criminal defense counsel, Jack Goldberger, but it was actually located right next door to the Florida Science Foundation -- an Epstein-owned and -run company where Epstein spent his "work release." While working in this office adjacent to Epstein's, Reinhart undertook the representation of numerous Epstein employees and pilots during the civil cases filed against Epstein by the victims — cases that involved the exact same crimes and exact same evidence being reviewed by the U.S. Attorney's office when he was employed there. Specifically, he represented Kellen (Epstein's number one co-conspirator who was actually named as such in the NPA), his housekeeper (Louella Ruboyo), his pilots Larry Morrison, Larry Visoski, David Rogers, William Hammond and Robert Roxburgh. (Hammond and Roxburgh were not deposed but the others were.) Our understanding is that his representation of these individuals was paid for, directly or indirectly, by Epstein. Reinhart was well aware of what evidence your office and federal investigator had collected against Epstein and about the minor girls who were his victims. As a consequence, he knew what evilience-the-atter-neys-forthe-victiras.-wete I Sine _FlealsoinesKwhat each of those witnesses had said, if anything, to federal and state investigators during the criminal investigation. We have been unable to place our fingers on the federal regulations governing such later representation. We do know, however, that such actions appear to be in direct contravention of the Florida ethical rules regarding attorneys who leave government employment. For 2 EFTA00231668 example, Florida R. Prof. Conduct 4-1.11(a) provides "[a) lawyer shall not represent a private client in connection with a matter in which the lawyer participated personally and substantially as a public officer or employee unless the appropriate government agency consents after consultation." Similarly, Florida R. Prof. Conduct 4-1.11(6) provides that "[a] lawyer having information that the lawyer knows is confidential government information about a person acquired when the lawyer was a public officer or employee may not represent a private client whose interests are adverse to that person in a matter in which the information could be used to the material disadvantage of that person." Both these rules appear to have been violated. But entirely apart from the details of ethical rules, the fact that one of your prosecutors was involved in making important decisions about the scope of criminal liability for Epstein and his associates and then — after criminal liability was significantly limited — representing numerous people at Epstein's behalf raises serious questions. At the very least, there is the strong appearance that Reinhard may have attempted to curry favor with Epstein and then reap his reward through favorable employment. At the very worst, there may have been advance discussions — we simply don't know at this point. Third, Epstein appears to have deliberately kept from victims in the case correspondence with your office and the Justice Department that might have shed light on improper influences. Along with other capable attorneys, I was involved in representing one of Epstein's victims (..) who filed a federal civil case against Epstein. Suspecting that Epstein may have improperly influenced your office, we immediately served discovery requests on Epstein for all the correspondence with your office regarding the plea negotiations. Eleven months of hard litigation ensued, in which Epstein made every conceivable argument against production. Finally, late in June of this year, his appeals exhausted, Epstein produced the correspondence to us. However, in violation of the court order, he redacted the correspondence so that he provided only emails and other statements from your office — not his emails and statements to your office. More significantly, even though he was under court order to produce all correspondence between his attorneys and your office, Epstein secretly withheld correspondence by several of his most high-powered attorneys — namely Ken Starr and Lilly Ann Sanchez. Epstein settled the case with M. within days after this limited production, and we did not realize the absence of what must have been critical discussions between your office and Starr and Snachez (among others). Epstein's refusal to allow us to see that information raises the suspicion in our minds that there must have been unusual pressures being brought to bear during the plea discussions that would have been revealed had Epstein complied with his production obligations. mirth, t vre-appears le-have-been-an-imprecefientpti level of secrecy between your office and the Federal Bureau of Investigation during this case. The FBI was responsible, along with state and local police agencies, for building the case against Epstein. They appear to have developed an overwhelming criminal against him. And yet, when your office signed the non￾prosecution agreement with him, it is not clear to us that the FBI was consulted about this decision. Indeed, we have suspicions that the FBI was not informed of this decision until, perhaps, months later. 3 EFTA00231669 Supporting this suspicion is our on-going litigation regarding the treatment of the victims in this case. As you know from our draft pleadings that we have discussed with your office, we believe there is compelling evidence that the victims and their attorneys were deceived about the existence of a non-prosecution agreement for months in order to avoid what certainly would have been a firestorm of controversy about such lenient treatment of a repeat sex offender. Our impression from the evidence we have been able to obtain so far is that the FBI was similarly kept in the dark — not consulted about or even told about the NPA. While a certain amount of tension has always existed between federal prosecuting and investigating agencies, not even informing the FBI about the Epstein NPA seems highly unusual. All of these strange facts -- as well as the facts that we are alleging in our crime victims' litigation — lead us to think that there was something rotten with the way this case was handled. Epstein could have faced years and years in prison for numerous federal sex offenses. And yet he managed to contrive to walk away with no federal time at all (and only minimal state time). We respectfully ask you to investigate through appropriate and independent channels the handling of the Epstein (non)prosecution. Thank you in advance for considering this request. I would be happy to provide any other additional information that would be useful to you. 4 EFTA00231670 3- EFTA00231671 U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., West Palm Beach, FL 33401 Facsimile: December 5, 2008 VIA ELECTRONIC MAIL Brad Edwards Esq. 2028 Street, Suite 202 Hollywood, Florida 33020 Re: Jeffrey Epstein,. Shawna Rivera. and Notification of Work Release Dear Mr. Edwards: By virtue of this letter, the United States Attorney's Office for the Southern District of Florida asks that you provide the following notice to your clients, , Shawna Rivera, and . The U.S. Attorney's Office has learned that Jeffrey Epstein has applied to participate in the Palm Beach County Sheriff's Office's ("PBSO") work release program, and PBSO has granted that application. Mr. Epstein is reportedly working for The Florida Science Foundation at 250 South Australian Avenue, Suite 1404, West Palm Beach, FL 33401. After work each day, Mr. Epstein returns to the Palm Beach County Stockade. While outside the Stockade, Mr. Epstein is electronically monitored via a GPS system and an ankle bracelet. Pursuant to the work release rules, Mr. Epstein is to go directly from the Stockade to his office, remain at the office throughout the work day, and then return directly to the Stockade. We regret that we were unable to inform your client of these developments prior to Mr. Epstein's release, but our Office was never notified of Mr. Epstein's application, and we only learned of his release more than six weeks after he began participating in the program. Should you or your client haveiniquestions regarding the work release program, please direct your inquiries to Captain David , Palm Bcach Sheriff's Office, 561-688-3595. Sincerely, R. Alexander Acosta United States Attorney By: oarliSaa Assistant U.S. Attorney EFTA00231672 U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., West Palm Beach, FL 33401 Facsimile: December 11, 2008 VIA HAND DELIVERY Captain David Palm Beach Sheriffs Office Corrections Division 3228 Gun Club Road West Palm Beach, FL 33406 Re: Work Release Application of Jeffrey Epstein Dear Captain The U.S. Attorney's Office recently learned that Inmate Jeffrey Epstein applied for and was approved for participation in the Palm Beach Sheriffs Office's ("PBSO") work release program. Through a request for public records, I have received a copy of Mr. Epstein's work release file. After doing some Internet research of public records and making a few telephone calls, I discovered some inaccuracies and omissions in Mr. Epstein's file that I wanted to bring to your attention. During a recent meeting, Roy Black, one of Mr. Epstein's attorneys, invited us to share our concerns with PBSO. Eligibility for Participation I understand that Mr. Epstein would be ineligible for participation in the work release program if he committed three violations of F.S.S. 796 within the past five years. Mr. Epstein has been charged with and convicted of a felony violation of F.S.S. 796.07. In order to be convicted of a felony violation of that statute, one must commit "a third or subsequent violation." In other words, Mr. Epstein has committed at least three violations of Section 796.07, and in his "Alternative Custody Program Placement Synopsis," Mr. Epstein's charges are described as "Recommit: Prostitution." In addition to those three violations, Mr. Epstein also has been convicted of violating F.S.S. 796.03, procuring a person under the age of 18 for prostitution. Throughout his EFTA00231673 CAPTAIN DAVID DECEMBER I I, 2008 PAGE 2 paperwork, this violation is referred to simply as "prostitution." The charge is not a solicitation of prostitution charge, it is a procurement of a minor to engage in prostitution. Florida courts have defined the offense as "inducing a victim to engage in sexual activity" for money and "persuading, inducing, or prevailing upon a person to do something sexual" for financial gain. In other words, the statute addresses the recruiting of minors who have not previously been involved in prostitution to engage in sexual activity for commercial gain to a recruiter or "pimp"/"madame." The Florida Legislature has acknowledged the significant difference between solicitation under F.S.S. 796.07 and procurement of minors under F.S.S. 796.03 by requiring persons convicted of violating F.S.S. 796.03 to register as sex offenders. The distinction may be meaningful to the victims of Mr. Epstein's offenses, who could feel that they are being stigmatized as "prostitutes." Inaccuracies and Omission in Work Release Application and Related Documents Throughout the records related to Mr. Epstein's work release placement, he is alternatively referred to as working for "The Florida Science Foundation" or "self￾employed," and Mr. Epstein lists his salary as $250,000. Mr. Epstein describes himself as "returning to work" and "eligible for re-employment" at The Florida Science Foundation. Please be advised that the only W-2 that Mr. Epstein provided is from Financial Trust Company, Inc., which shows that Mr. Epstein was employed in the U.S. Virgin Islands at a salary of $180,785.62, not $250,000. Mr. Epstein provided to you no documentation regarding his pre-incarceration employment with "The Florida Science Foundation" or its corporate alter-ego, "The C.O.U.Q. Foundation, Inc." As you will see, the Foundation, its offices, and Mr. Epstein's purported job schedule were all created on the eve of Mr. Epstein's incarceration in order to provide him with a basis for seeking work release. The Florida Science Foundation was not registered with the State of Florida and had no office space or telephone number until after Mr. Epstein was already incarcerated. The application filed with the State of Florida and signed under penal of r'u b Richard Kahn lists Mr. Kahn's and the Foundation's telephone number as ." That is the telephone number of Atterbury, Goldberger and Weiss-one of the law firms representing Mr. Epstein. Richard Kahn is a partner at the law firm of Sullivan and Cromwell in New York and has no association with the Atterbury firm. Checking public records available on the Internet, I located the IRS returns of "The C.O.U.Q. Foundation, Inc." for fiscal years 1999 through 2006 (which covers the period EFTA00231674 CAPTAIN DAVID DECEMBER II, 2008 PAGE 3 through 2/28/07).' These sworn filings show that Mr. Epstein worked for the Foundation for only one hour per week and earned no compensation. (Sag page 6 of each return.) All of these returns were signed under penalty of perjury by either Mr. Epstein or Darren Indyke, who is listed in Mr. Epstein's work release file as Mr. Epstein's "supervisor." Mr. Epstein's representations concerning his prior work duties and salary may violate the salary and employment verification requirements of C.O.P. #926.01(V)(CX7) and (8). In response to your requirement of "a detailed work schedule," Mr. Indyke has provided the following two sentences: [Mr. Epstein's] duties will require him to work six days a week, Monday through Saturday, at the Foundation's office located at 250 S. Australian Avenue, Suite 1404, West Palm Beach, Florida from the hours of 8:00 A.M. to 8:00 P.M. As President of the Foundation, Mr. Epstein will be responsible for the general oversight and management of the Foundation, and particularly, to seek out, evaluate and determine worthy charitable causes to which the Foundation may make contributions. Mr. Indyke did not disclose that Mr. Epstein only worked one hour per week prior to his incarceration and has provided no explanation of why Mr. Epstein could perform these duties in one hour per week before he was incarcerated but now needs to spend 72 hours each week to do the same job. Again, this appears to be inconsistent with C.O.P. #926.011)(CX7). Mr. Indyke has signed the "Alternative Custody Unit Program Agreement" as Mr. Epstein's "employer." In that Agreement, Mr. Indyke promises to "notify the Alternative 'The returns are available online at the following public websites: FY2006: http://www.guidestar.org/FinDocuments/2007/133/996/2007-133996471-0391c8db-F.pdf FY2005: http://www.guidestar.org/FinDocuments/2006/133/996/2006-133996471-02c9625e-F.pdf FY2004: http://www.guidestar.org/FinDocuments/2005/133/996/2005-133996471-02056acf-F.pdf . up. .guidestar.org/Fmnocumentsi2u04/ 33/996/ZUU4-1339964 /1-1 -k.pdt FY 2002: http://www.guidestatorg/FinDocuments/2003/133/996/2003-133996471-1-F.pdf FY2001: http://www.guidestar.orgifinDocuments/2002/133/996/2002-133996471-1-F.pdf FY2000: http://www.guidestar.org/FinDocuments/2001/133/996/2001-133996471-1-F.pdf FY1999: http://www.guidestar.org/FinDocuments/2000/133/996/2000-133996471-1-F.pdf FYI998: http://www.guidestar.org/FinDocuments/1999/133/996/1999-133996471-1-F.pdf EFTA00231675 CAPTAIN DAVID DECEMBER I I, 2008 PAGE 4 Custody Unit immediately if the Participant: (1) Fails to appear for work at the scheduled time; and (2) Leaves the place of employment prior to the scheduled time." Both in this form and in Mr. Indyke's letter in support of Mr. Epstein's application, Mr. Indyke neglects to inform the Sheriff's Office of two significant facts. First, Mr. Indyke lives and works in the New York metropolitan area. He likely will not be present at Mr. Epstein's workplace, so he may not know if Mr. Epstein "fails to appear for work" or "leaves the place of employment." In that event, Mr. Indyke also will not be able to supervise Mr. Epstein's actual work to determine whether he is truly doing the work of The Florida Science Foundation.2 Second, Mr. Indyke does not "employ" Mr. Epstein. Instead, Mr. Epstein "employs" Mr. Indyke. Mr. Epstein is the President and founder of The Florida Science Foundation and Mr. Indyke is its Vice President. More importantly, Mr. Epstein is also the founder and President of the Financial Trust Company, his for-profit corporation. Mr. Indyke is Mr. Epstein's subordinate at that entity as well. One of Mr. Epstein's attorneys has suggested that Mr. Epstein is using his time on work release to manage investments resulting in investment income of millions of dollars. If that is true, then Mr. Epstein is acting outside of the scope of his employment with The Florida Science Foundation. Instead, that would be in keeping with Mr. Epstein's work for his for-profit corporation, which would inure to the benefit of Mr. Indyke. Because that work would result in a financial benefit to him, and because he is Mr. Epstein's subordinate at that corporation, Mr. Indyke may be reluctant to inform the Sheriffs Office of this violation of the terms of Mr. Epstein's Work Release contract. The "references" listed by Mr. Epstein all appear to have the same conflict of interest. Mr. Epstein did not list any past or present co-workers, supervisors, or clients. Instead, he has listed four attorneys who are currently retained—and paid—by Mr. Epstein. Their attorney￾client privilege obligations might further restrain them from notifying the Sheriffs Office if Mr. Epstein was not abiding by the work release rules. As I previously mentioned to Colonel Gauger, the decision regarding work release is completely within the discretion of the Sheriff's Office. The purpose of this letter is simply to provide you with information concerning Mr. Epstein's offenses and his work situation. Judge Pucillo, who conducted the change of plea and sentencing, heard the factual proffer and imposed Mr. Epstein's sentence. She has not been consulted regarding Mr. Epstein's 20n the application for registration of the Florida Science Foundation with Florida's Department of State, Mr. Indyke lists his true address in Livingston, New Jersey. EFTA00231676 CAPTAIN DAVID DECEMBER II, 2008 PAGE 5 application for work release. I understand that Judge McSorley's standing order states that she "takes no position with respect to the eligibility of any inmate sentenced in this Division unless specifically stated at time of sentencing." Because of her absence, Judge McSorley did not conduct the sentencing and, therefore, did not have the opportunity to weigh any objections to work release at that hearing. It is unclear whether Judge Pucillo was aware of Judge McSorley's standing order when she imposed sentence. In utilizing your discretion, you may or may not choose to consult with the appropriate judge on this matter. Request for Notification As I had previously asked of Colonel Gauger, I would appreciate if you would keep me informed of any changes to Mr. Epstein's release status so that I may fulfill my obligations to keep the victims identified through the federal investigation informed of Mr. Epstein's status. I have informed all of the known victims of Mr. Epstein of the change in his incarceration status and that you are the contact person if they have any questions. Some may ask that their locations be amongst the "Exclusionary Zones" programmed into Mr. Epstein's GPS unit. If you need their addresses, please let me know. Please feel free to contact me with any questions or concerns. Sincerely, R. Alexander Acosta United States Attorney By: Assistant United States Attorney cc: Colonel I EFTA00231677 EFTA00231678 U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., West Palm Beach, FL 33401 Facsimile: December 11, 2008 VIA HAND DELIVERY Captain David Palm Beach Sheriff's Office Corrections Division 3228 Gun Club Road West Palm Beach, FL 33406 Re: Work Release Application of Jeffrey Epstein Dear Captain The U.S. Attorney's Office recently learned that Inmate Jeffrey Epstein applied for and was approved for participation in the Palm Beach Sheriff's Office's ("PBSO") work release program. Through a request for public records, I have received a copy of Mr. Epstein's work release file. After doing some intemet research of public records and making a few telephone calls, I discovered some inaccuracies and omissions in Mr. Epstein's file that I wanted to bring to your attention. During a recent meeting, Roy Black, one of Mr. Epstein's attorneys, invited us to share our concerns with PIM. Eligibility for Participation I understand that Mr. Epstein would be ineligible for participation in the work release program if he committed three violations of F.S.S. 796 within the past five years. Mr. Epstein has been charged with and convicted of a felony violation of F.S.S. 796.07. In order to be convicted of a felony violation of that statute, one must commit "a third or subsequent violation." In other words, Mr. Epstein has committed at least three violations of Section /90.0 1, andin his "Alternative Custody Program Placement Synopsis," Mr. bpstem's charges are described as "Recommit: Prostitution." In addition to those three violations, Mr. Epstein also has been convicted of violating F.S.S. 796.03, procuring a person under the age of 18 for prostitution. Throughout his EFTA00231679 CAPTAIN DAVID DECEMBER I I, 2008 PAGE 2 paperwork, this violation is referred to simply as "prostitution." The charge is not a solicitation of prostitution charge, it is a procurement of a minor to engage in prostitution. Florida courts have defined the offense as "inducing a victim to engage in sexual activity" for money and "persuading, inducing, or prevailing upon a person to do something sexual" for financial gain. In other words, the statute addresses the recruiting of minors who have not previously been involved in prostitution to engage in sexual activity for commercial gain to a recruiter or "pimp"/"madame." The Florida Legislature has acknowledged the significant difference between solicitation under F.S.S. 796.07 and procurement of minors under F.S.S. 796.03 by requiring persons convicted of violating F.S.S. 796.03 to register as sex offenders. The distinction may be meaningful to the victims of Mr. Epstein's offenses, who could feel that they are being stigmatized as "prostitutes." Inaccuracies and Omission in Work Release Application and Related Documents Throughout the records related to Mr. Epstein's work release placement, he is alternatively referred to as working for "The Florida Science Foundation" or "self￾employed," and Mr. Epstein lists his salary as $250,000. Mr. Epstein describes himself as "returning to work" and "eligible for re-employment" at The Florida Science Foundation. Please be advised that the only W-2 that Mr. Epstein provided is from Financial Trust Company, Inc., which shows that Mr. Epstein was employed in the U.S. Virgin Islands at a salary of $180,785.62, not $250,000. Mr. Epstein provided to you no documentation regarding his pre-incarceration employment with "The Florida Science Foundation" or its corporate alter-ego, "The C.O.U.Q. Foundation, Inc." As you will see, the Foundation, its offices, and Mr. Epstein's purported job schedule were all created on the eve of Mr. Epstein's incarceration in order to provide him with a basis for seeking work release. The Florida Science Foundation was not registered with the State of Florida and had no office space or telephone number until after Mr. Epstein was already incarcerated. The application filed with the State of Florida and signed under penal of e .11 b Richard Kahn lists Mr. Kahn's and the Foundation's telephone number as ' ." That is the telephone number of Atterbury, Goldberger and Weiss—one of the law firms representing Mr. Epstein. Richard Kahn is a partner at the law firm of Sullivan and Cromwell in New York and has no association with the Atterbury firm. Checking public records available on the internet, I located the IRS returns of "The C.O.U.Q. Foundation, Inc." for fiscal years 1999 through 2006 (which covers the period EFTA00231680 CAPTAIN DAVID DECEMBER 11, 2008 PAGE 3 through 2/28/07).' These sworn filings show that Mr. Epstein worked for the Foundation for only one hour per week and earned no compensation. (See page 6 of each return.) All of these returns were signed under penalty of perjury by either Mr. Epstein or Darren Indyke, who is listed in Mr. Epstein's work release file as Mr. Epstein's "supervisor." Mr. Epstein's representations concerning his prior work duties and salary may violate the salary and employment verification requirements of C.O.P. #926.01(V)(C)(7) and (8). In response to your requirement of "a detailed work schedule," Mr. Indyke has provided the following two sentences: [Mr. Epstein's] duties will require him to work six days a week, Monday through Saturday, at the Foundation's office located at 250 S. Australian Avenue, Suite 1404, West Palm Beach, Florida from the hours of 8:00 A.M. to 8:00 P.M. As President of the Foundation, Mr. Epstein will be responsible for the general oversight and management of the Foundation, and particularly, to seek out, evaluate and determine worthy charitable causes to which the Foundation may make contributions. Mr. Indyke did not disclose that Mr. Epstein only worked one hour per week prior to his incarceration and has provided no explanation of why Mr. Epstein could perform these duties in one hour per week before he was incarcerated but now needs to spend 72 hours each week to do the same job. Again, this appears to be inconsistent with C.O.P. #926.01(V)(C)(7). Mr. Indyke has signed the "Alternative Custody Unit Program Agreement" as Mr. Epstein's "employer." In that Agreement, Mr. Indyke promises to "notify the Alternative 'The returns are available online at the following public websites: FY2006: http://www.guidestar.org/FinDocuments/2007/133/996/2007-133996471-0391c8db-F.pdf FY2005: http://www.guidestar.org/FinDocuments/2006/133/996/2006-133996471-02c9625e-F.pdf FY2004: http://www.guidestar.org/FinDocuments/2005/133/996/2005- 13399647 l -02056acf-F.pdf u3. http.//www.guidestar.org/PinVocumentsf2UU4/133/996/2004-133996471-1-F.pdf FY 2002: http://www.guidestar.org/FinDocuments/2003/133/996/2003-133996471-1-F.pdf FY2001: http://www.guidestar.org/FinDocuments/2002/133/996/2002-133996471-1-F.pdf FY2000: http://www.guidestar.org/FinDocuments/2001/133/996/2001-133996471-1-F.pdf FY1999: http://www.guidestar.org/FinDocuments/2000/133/996/2000-133996471-1-F.pdf FY1998: http://www.guidestar.org/FinDocuments/1999/133/996/1999-133996471-1-F.pdf EFTA00231681 CAPTAIN DAVID DECEMBER 11, 2008 PAGE 4 Custody Unit immediately if the Participant: (1) Fails to appear for work at the scheduled time; and (2) Leaves the place of employment prior to the scheduled time." Both in this form and in Mr. Indyke's letter in support of Mr. Epstein's application, Mr. Indyke neglects to inform the Sheriff's Office of two significant facts. First, Mr. Indyke lives and works in the New York metropolitan area. He likely will not be present at Mr. Epstein's workplace, so he may not know if Mr. Epstein "fails to appear for work" or "leaves the place of employment." In that event, Mr. Indyke also will not be able to supervise Mr. Epstein's actual work to determine whether he is truly doing the work of The Florida Science Foundation.2 Second, Mr. lndyke does not "employ" Mr. Epstein. Instead, Mr. Epstein "employs" Mr. Indyke. Mr. Epstein is the President and founder of The Florida Science Foundation and Mr. Indyke is its Vice President. More importantly, Mr. Epstein is also the founder and President of the Financial Trust Company, his for-profit corporation. Mr. Indyke is Mr. Epstein's subordinate at that entity as well. One of Mr. Epstein's attorneys has suggested that Mr. Epstein is using his time on work release to manage investments resulting in investment income of millions of dollars. If that is true, then Mr. Epstein is acting outside of the scope of his employment with The Florida Science Foundation. Instead, that would be in keeping with Mr. Epstein's work for his for-profit corporation, which would inure to the benefit of Mr. Indyke. Because that work would result in a financial benefit to him, and because he is Mr. Epstein's subordinate at that corporation, Mr. Indyke may be reluctant to inform the Sheriff's Office of this violation of the terms of Mr. Epstein's Work Release contract. The "references" listed by Mr. Epstein all appear to have the same conflict of interest. Mr. Epstein did not list any past or present co-workers, supervisors, or clients. Instead, he has listed four attorneys who are currently retained—and paid—by Mr. Epstein. Their attorney￾client privilege obligations might further restrain them from notifying the Sheriff's Office if Mr. Epstein was not abiding by the work release rules. As I previously mentioned to Colonel Gauger, the decision regarding work release is completely within the discretion of the Sheriff's Office. The purpose of this letter is simply to provide you with information concerning Mr. Epstein's offenses and his work situation. Judge Pucillo, who conducted the change of plea and sentencing, heard the factual proffer and imposed Mr. Epstein's sentence. She has not been consulted regarding Mr. Epstein's 'On the application for registration of the Florida Science Foundation with Florida's Department of State, Mr. Indyke lists his true address in Livingston, New Jersey. EFTA00231682 CAPTAIN DAVID DECEMBER I I, 2008 PAGE 5 application for work release. I understand that Judge McSorley's standing order states that she "takes no position with respect to the eligibility of any inmate sentenced in this Division unless specifically stated at time of sentencing." Because of her absence, Judge McSorley did not conduct the sentencing and, therefore, did not have the opportunity to weigh any objections to work release at that hearing. It is unclear whether Judge Pucillo was aware of Judge McSorley's standing order when she imposed sentence. In utilizing your discretion, you may or may not choose to consult with the appropriate judge on this matter. Request forNotification As I had previously asked of Colonel Gauger, I would appreciate if you would keep me informed of any changes to Mr. Epstein's release status so that I may fulfill my obligations to keep the victims identified through the federal investigation informed of Mr. Epstein's status. I have informed all of the known victims of Mr. Epstein of the change in his incarceration status and that you are the contact person if they have any questions. Some may ask that their locations be amongst the "Exclusionary Zones" programmed into Mr. Epstein's GPS unit. If you need their addresses, please let me know. Please feel free to contact me with any questions or concerns. Sincerely, R. Alexander Acosta United States Attorney By: cc: Colonel I Assistant United States Attorney EFTA00231683 FBI PALM BEACH COUNTY RA JEFFREY E. EPSTEIN 31E-MM EFTA00231684 EFTA00231685 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: Incident Report Program: CMS3 Case No SPECIAL NOTES Occur To Date Day Of Week . Common/Location: City • Location Type : Beat Assignment: Dept Class . . : Case Status . Supervisory Dt.: Entry Date . Names"' Vehicles? . . Narrative? . . 1-05-000368 : DO NOT RELEASE Occur From Date: 1/27/05 0000 : 1/27/05 0000 Report Date . : 3/14/05 1600 : Thursday 358 EL BRILLO WY PALM BEACH, FL RESIDENCE-SINGLE DETECTIVE BUREAU SEXUAL BATTERY A *********VEHICLE Case number . : 1-05-000368 State Veh Type : Make Model Name . . : Style • Color - Bottom : VIN Dir isition . : Ins_red by . . Vehicle locked : Date recovered : 0/00/00 Street number : City Recovery code : Be On Look Out?: ********* Case Number . : Street Number : City BEACH, FL Birth Date/Age : 24 Occupation . . Home Phone No. Sex • Female Weight • 0 N F FAMILY Map Reference Report Officer Case Status Dt 3/14/05 4/06/05 Property? . . Offenses? . . Related Cases? : 3 14 05 ORMATION # Category . . . : Year Model • Permit Number : Color - Top . License # . . : Stolen value . : 0 Insured . . . : Keys in car . : Lein holder . : Recovery value : 0 PERSON REPORT ************** Case Number . —St-reet Number City Birth Date . . Employer? . Ope- Lic No. . Oti : Phone Nbr: Sex • Female Minimum Weight : 0 1 ***************,r***** • 0 NCIC number . : I N G I N F O - ********* Last Name . . : Employer? . Oper Lic No. Race Height Other Phone White • 0 Nbr: SUSPECT/ARRESTEE IN : 1-05-000368 Prompt valid :--12-24-7-TZMD CT NORTH-- • M BEACH, FL 334121460 18 Maximum Age Occupation . FL Home Phone No. : Race Minimum Height : Maximum Height : F 0 in: : 18 White 0 0 FL # 1 ** EFTA00231686 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 2 Incident Report Program: CNIS301L Case No Maximum Weight : 0 Aliases9 Hair Color . Hair Style . . : Glasses . . Facial Hair Teeth • Hat Shirt • Shoes • Body Marks #2 : Body Marks #4 : Arrest Case No.: ************** S Case Number . : Street Number : City Birth Date . . : Employer? . . : Oper Lic No. . : Other Phone Nbr: Sex Mir'mum Weight : Ma) SUM Weight : Aliases9 • Hair Color . Hair Style . Glasses . . Facial Hair . Teeth • Hat • Shirt • Shoes Body Marks #2 : Body Marks #4 : Arrest Case No.: ************** Case Number . Street Number City Birth Date . Employer? . Oper L Other Phone Nbr: Sex • Male Minimum Weight : 0 Maximum Weight : 0 Al ses9 Hair Color . . : Hair Style . . : S • . E123425530200 1-05-000368 USPECT/ 1-05-000368 358 EL BRILLO WY FL 25 HA 561 000-0000 Female 0 0 Misc. ID# MO/Crime Spec? : Hair Length Eye Color Complexion Build Speech Coat Pants Body Marks #1 : Body Marks #3 : Status Additional UCR?: ARRESTEE INFO Prompt valid in: 000033480 Maximum Age . Occupation . . Home Phone No Race Minimum Height : Maximum Height : Misc. ID# . . MO/Crime Spec? : Hair Length Eye Color Complexion Build Speech Coat Pants Body Marks #1 : Body Marks #3 : Status STILL SUSPECT Additional UCR?: • • • • (Continued) STILL SUSPECT 25 PERSONAL ASST/EPSTEIN 561/000-0000 White 0 0 USPECT/ARRESTEE INFORMATION- # 3 ** 1-05-000368 Prompt valid in: EPSTEIN, JEFFREY 358 EL BRILLO WY PALM BEACH, FL 000033480 1/20/1953 52 Maximum Age Occupation . . FIT Home-Phone No. Race Minimum Height Maximum Height Misc. ID# MO/Crime Spec? Hair Length . Eye Color . . : 52 White 0 0 EFTA00231687 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 3 Time: 8:47:53 Incident Report Program: CM5301L Case No • 1-05-000368 (Continued) Glasses . . . Facial Hair Teeth Hat Shirt Shoes Body Marks #2 : Body Marks #4 : Arrest Case No.: ************** I Case Number . : Prompt valid in: Street Number : City Birth Date/Age : Occupation . . Home Phone No. : Sex Weight Be On Look Out?: Victim Type . : Residency Sts : Car Tdentify . ry Extent : Injury Type 2 : Med Treatment : Phys Last Name : ************** V Case Number . : Street Number : City Birth Date/Age : Occupation . . : Home Phone No. : Sex Weight Be On Look Out?: Victim Type . : Residency Sts : Can Identify . : Injury Extent : Injury Type 2 : --Med-Treatment---: Phys Last Name : ************** ICTI Complexion Build Speech Coat Pants Body Marks #1 : Body Marks #3 : Status • STILL SUSPECT Additional UCR?: INFORMATION -# ******************** WEST PALM BEACH, FL 5/13/1990 14 Female 0 JUVENILE ICTIM 1-05-000368 FL 18 561/000-0000 Female 0 ADULT Employer? . Oper Lic No. Race Height Misc. ID# . . : Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: . : . : • White • 0 INFORMATION -# ******************** Prompt valid in: VICTIM Casc Number . : 1-05-000368 St. Number : City H, FL 000033480 Birth Date/Age : 16 • Employer? 000033480 Employer? . Oper Lic No. Race Height Misc. ID# . Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . Phys First Name: . : . : White 0 561/000-0000 INFORMATION - # ****************** Prompt valid in: EFTA00231688 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 4 Time: 8:47:53 Incident Report Program: CMS301L Can.= No 1-05-000368 Occupation Home Phone No. : 561/000-0000 Sex Female Weight 0 Be On Look Out?: Victim Type : JUVENILE Residency Sts Can Identify . : Injury Extent Injury Type 2 : Med Treatment : Phys Last Name : ************** V Case Number . : Street Number : City Birth Date/Age : Occupation . . : Home Phone No. : Sex Weight Be On Look Out?: Vir'im Type Rea lency Sts : Can Identify . : Injury Extent : Injury Type 2 : Med Treatment : Phys Last Name : ************** Case Number . : Street Number : City • Birth Date/Age : Occupation . . : Home Phone No. : Sex • Weight Be On Look Out?: Victim Type . : Residency Sts : Can Identify . Injury Extent￾Injury Type 2 Med Treatment : Phys Last Name : (Continued) Oper Lic No. . Race White Height 0 Misc. ID# . . Other Phone Nbr: 561/000-0000 Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: I C T I M INFORMATION -# ******************** 1-05-000368 FL 17 561/000-0000 Female 0 JUVENILE ICTIM 1-05-000368 PALM BEACH, FL 9/21/1986 18 561/000-0000 Female 0 ADULT ** •*********VICTIM Case Number . : - - 68 Prompt valid in: Prompt valid in: 000033480 Employer? . Oper Lic No. Race Height Misc. ID# Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: White 0 561/000-0000 INFORMATION - # *************A****** Prompt valid in: , 000033480 Employer? . Oper Lic No Race Height Misc. ID# . Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type — Hospital ID . : Phys First Name: White 0 561/000-0000 INFORMATION -# 6******************** EFTA00231689 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 5 Incident Report Program: CMS301L Casc No Street Number City Birth Date/Age : Occupation . . Home Phone No. : Sex Weight Be On Look Out?: Victim Type . : Residency Sts : Can Identify . Injury Extent : Injury Type 2 : Med Treatment : Phys Last Name : ************** V Case Number . : Street Number : City • Birth Date/Age : Occupation . . : Home Phone No. : 561/000-0000 Ser Female 0 Be On Look Out?: Victim Type . : Residency Sts Can Identify . Injury Extent : Injury Type 2 : Med Treatment : Phys Last Name : 1-05-000368 PALM BEACH, FL 7/28/1988 16 561/000-0000 Female 0 JUVENILE ************** V Case Number . : 1-05-000368 Street Number : City • PALM BEACH, FL Birth Date/Age : 2/29/1988 16 Occupation . . : Home Phone No. : 561/000-0000 Sex • Female Weight 0 Be On Look Out?: Victim Type . -4-JUVENILE￾Residency Sts : Can Identify . : Injury Extent : Injury Type 2 : Mec :reatment : Phys Last Name : ICTIM 1-05-000368 JUVENILE ICTIM FL 17 000033480 Employer? . Oper Lic No. Race White Height 0 Misc. ID# . . Other Phone Nbr: 561/000-0000 Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID : Phys First Name: (Continued) INFORMATION -# ******************** Prompt valid in: ************** V I C T I M 000033480 Employer? . Oper Lic No. Race White Height 0 Misc. ID# . . Other Phone Nbr: 561/000-0000 Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: . : . : INFORMATION -# ******************** Prompt valid in: 000033480 Employer? . Oper Lic No. Race White Height 0 Misc. ID# . . Other Phone Nbr: 561/000-0000 Residency Type . File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: . : . : INFORMATION -# 9 ******************** EFTA00231690 Date: 7/25/06 Time: 8:47:53 Incident Report PALM BEACH POLICE DEPARTMENT Page: 6 Program: CMS301L Case No Case Number . : Street Number : City • Birth Date/Age : Occupation . . Home Phone No. : Sex Weight Be On Look Out?: Victim Type . Residency Sts Can identify . Injury Extent Injury Type 2 Med Treatment Phys Last Name ************** Case Number . : Prompt valid in: Street Number : City • Birth Date/Age : Oc' ration . . : Hoh._. Phone No. : Sex • Weight Be On Look Out?: Victim Type . : Residency Sts : Can Identify . : Injury Extent Injury Type 2 : Med Treatment : Phys Last Name : ************** V Case Number . : Street Number : City Birth Date/Age : Occupation . . Home Phone No. : 561/000-0000 Sex Female Weight 0 Be On Look Out?: Victim Type . : Residency Sts : Car Identify . In ry Extent : Injury Type 2 : Med Treatment : 1-05-000368 1-05-000368 PALM BEACH, FL 6/06/1987 17 561/000 0000 Female 0 JUVENILE Prompt valid in: 000033480 Employer? . Oper Lic No. Race White Height 0 Misc. ID# . . : Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: ICTIM INFOR PALM BEACH, FL 6/18/1987 17 561/000-0000 Female 0 JUVENILE ICTIM 1-05-000368 PALM BEACH, FL 8/09/1986 18 ADULT 000033480 MATION . : . : 561/000-0000 - # 10 ******************* Employer? . . : Oper Lic No. . : Race Height Misc. ID# . . : Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: White 0 561/000-0000 INFORMATION - # ******************* Prompt valid in: 000033480 Employer? . Oper Lic No. Race Height Misc. ID# . . Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . Phys First Name: • White - 0 561/000-0000 EFTA00231691 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Incident Report Page: 7 Program: 0 01S301L Case No • Phys Last Name : ************** V Case Number . : Street Number : City Birth Date/Age : Occupation . . Home Phone No. : Sex Weight Be On Look Out?: Victim Type . Residency Sts Can Identify . Injury Extent Injury Type 2 Med Treatment Phys Last Name 1-05-000368 ICTIM 1-05-000368 PALM BEACH, FL 6/01/1986 18 561/000-0000 Female 0 : ADULT ************** V Case Number . : Street Number : Cit FL Date/Age : • 16 Occupation . . : Home Phone No. : 561/000-0000 Sex Female Weight 0 Be On Look Out?: Victim Type . Residency Sts Can Identify . Injury Extent Injury Type 2 Med Treatment Phys Last Name ************** ICTIM 1-05-000368 : JUVENILE VICTIM Case Number . : 1-05-000368 Street Number : City FL Birth Date/Age : • 16 Occupation . . : -Home Phone—No. 561/000-0000 Sex Female Weight 0 Be On Look Out?: Victim Type . : JUVENILE Re: lency Sts : Can Identify . Injury Extent : (Continued) INFORMATION - # *************-****** Prompt valid in: 000033480 Employer? . . : Oper Lic No. . Race Height Misc. ID# . . : Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: White 0 561/000-0000 INFORMATION - # ******************* Prompt valid in: 000033480 Employer? . . : Oper Lic No. . : Race • Height Misc. ID# . . : Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: White 0 561/000-0000 INFORMATION - # ******************* Prompt valid in: 000033480 Employer? . . Oper Lic No. . -Race Height Misc. ID# . . : Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : White 0 561/000-0000 EFTA00231692 Date: 7/25/06 Time: 8:47:53 Cas.. No PALM BEACH POLICE DEPARTMENT Incident Report 1-05-000368 Page: 8 Program: CMS301L (Continued) Injury Type 2 : Hospital ID . : Med Treatment : Phys First Name: Phys Last Name : ************** ICTIM INFORMATION -# ******************* Case Number . : 1-05-000368 Prompt valid in: Street Number : City Birth Date/Age Occupation . . • : : PALM BEACH, 8/24/1985 19 FL 000033480 Employer? Oper Lic No. Home Phone No. : 561/000-0000 Race White Sex • Female Height 0 Weight 0 Misc. ID# . . : Be On Look Out?: Other Phone Nbr: 561/000-0000 Victim Type . : Residency Sts : Can Identify . : Injury Extent : Injury Type 2 : Med Treatment : Phys Last Name : ************** ADULT VICTIM Car Number . : Sti ,t Number : City Birth Date/Age : Occupation . . : Home Phone No. : Sex Weight Be On Look Out?: Victim Type . : Residency Sts : Can Identify . : Injury Extent : Injury Type 2 : Med Treatment : Phys Last Name : ************** 1-05-000368 17 FL 561/000-0000 Female 0 JUVENILE VICTIM Case Number . : 1-05-000368 Street Number : City Birth Date/Age Occupation . . : Home Phone No. : Sex Weight Be . Look Out?: Victim Type . : Residency Sts : Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: INFORMATION - # ******************* Prompt valid in: 000033480 Employer? . . Oper Lic No. Race White Height 0 Misc. ID# . . Other Phone Nbr: 561/000-0000 Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: INFORMATION -# ************** ** Prompt valid in: H, FL 000033480 16__.__..__ ___Pripinyar7 Oper Lic No. : 561/000-0000 Race White Female Height 0 0 Misc. ID# . . Other Phone Nbr: 561/000-0000 JUVENILE Residency Type : File Charges . : EFTA00231693 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 9 Incident Report Program: CMS301L Cast No • 1-05-000368 Can Identify . Injury Extent Injury Type 2 Med Treatment : Phys Last Name : ********* Case Number . : Street Number : City BEACH, FL Birth Date/Age : ass 14 Occupation . . : Home Phone No. : Sex Female Weight 0 Other Phone Nbr: OTHER PERSON ********* O Case Number . : 1-05-000368 Street Number : 358 EL BRILLO WY City : H, FL 000033480 Birth Date/Age 19 Employer? . Occupation . . : Oper Lic No. Hor Phone No. : Race Sex Female Weight 0 Other Phone Nbr: THER PERSON ********* O THER PERSON Case Number . : - - Street Number : City Birth Date/Age : 35 • M BEACH, FL Occupation . . : Home Phone No. Sex Weight Other Phone Nbr: ********* O Case Number . Street Number : City Birth Date/Age : • M BEACH, FL 37 Occupation . Home Phone No. : Sex Weight Other Phone Nbr: Female THER PERSON IN= Male 0 Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: (Continued) I N F O R M A T - ********* Last Name Employer? . Oper Lic No. Race White Height 0 Person Type : OTHER PERSON INFORMAT Iiiii iiiiiii iiii********* Last Name . . : • White Height • 510 Person Type : OTHER PERSON INFO Last Name FL R M A T - ********* Employer? . Oper Lic No. Race • White Height • 0 Person Type . : OTHER PERSON . : . : INFORMATilik- ********* Last Name . . : L Employer? Oper-Lic—No. Race • White Height • 0 Person Type . : OTHER PERSON *********OTHER PERS Case Number . : 1-05-000368 ON INFORMATION - # 5 ********* Last Name . . : BACK, KATHY EFTA00231694 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Incident Report Page: 10 Program: CMS301L Casc No Street Number • : 1-05-000368 (Continued) City Birth Date/Age : 0/00/0000 0 Employer? . . : Occupation . . : FAMILY THERAPIST Oper Lic No. . : Home Phone No. : Sex Weight Other Phone Nbr: 561/000-0000 Female 0 561/000-0000 Race Height Person Type . • • : White 0 OTHER PERSON Case Number . Employer Name Address . . . City/State/Zip Phone Number . ********* O T H Case Number . Street Number : City Birth Date/Age : Occupation . . : Home Phone No. : Ser • Wei _it Other Phone Nbr: ***EMPLOYER INFORMATION*** 1-05-000368 PBC DIVISON OF YOUTH AFFAIRS 4200 N AUSTRALIAN AV FL 33407 E R PERSO WELLIN N, FL Male 0 N INFORMAT - ********* Last Name . . : 16 Employer? . Oper Lic No. Race White Height 0 Person Type . : OTHER PERSON ***EMPLOYER INFORMATION*** . : . : Case Number . : 1-05-000368 Employer Name : Address . . : 4900 SUMMIT BV City/State/Zip : WEST PALM BEACH, FL 33415 Phone Number . : ********* O T H E R PERSON INFO RMAT - SCHOOL ***A***** Case Number . : Last Name . . : Street Number : City Birth Date/Age : WEST PALM BEACH, 0/00/0000 0 FL Employer? . . : Occupation . . : Oper Lic No. . : Home Phone No. : Sex Weight Other Phone Nbr: Male 0 Race Height Person Type • • : White 0 OTHER PERSON *********_OTHE-R, : INFORMA A'Tit # *** * Case Number . ---R-ERSO—N - - Last Name . . Street Number : City Birch Date/Age • : WEST PALM BEACH, 0/00/0000 0 FL Employer? . . : H . ?ation . . Home Phone No. Sex • Female Oper Lic No. Race Height • 0 EFTA00231695 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 11 Incident Report Program: CMS301L Cas No • 1-05-000368 Weight • 0 Other Phone Nbr: (Continued) Person Type . : OTHER PERSON ********* OTHER P E R S O N I N F O R M A T - ********* Case Number . Last Name . . : , Street Number : iliall 39 City : • BEACH, FL 33417 Birth Date/Age 16 Employer? Occupation . . : Oper Lic No. : FL Home Phone No. : 561/000-0000 Race White Sex • Female Height 0 Weight 0 Person Type : OTHER PERSON Other Phone Nbr: 561/000-0000 ****************************NARRA *************************** Original Report LO Reported By: D. Entered By.: D. 9/20/05 9/20/05 On 03/14/2005, I received a call from d not wish to identify herself (later identified as ). She still fourteen year old step daughter later identified as ) possibly been molested in Palm Beach by a wealthy man. According to , she learned of the possible molestation by a third party. S e exp ained that she had received a call from the mother of her stepdaughter's friend. The mother claimed to have overheard a convers between her daughter and a male L6lind; they were talking about . The conversation was about how IIII had met with a 4 - - ld man and had sex with him and was paid for it. I advised that I would l' eet with her to obtain a more detailed statement and facts. stated she did not know what d had to discuss the matter with her husband. At this point did not provide me with a call back number or any other information. She sta at she would contact me once she had spoken with her husband and mother. On 03/14/2005 received a call from Mr. & Mrs . They slid l right to spilt Her mother ' daughter via cell phone had been made aware of the case. o meet me at t e police department later this date. /2005, Mr. accompanied by his wife came to the Palm Beach Police Department where they advised me that they believed their fourteen year old daughter may have had sometypeof sexual relationship with an older male wha resided i.n------- Palm Beach. Neither knew the suspect's name or address. Both stated that their daughter did not talk to them about the incident, nor would she admit to it. !!!Ill • tifiedi s at , RPB, , er . is a twin, EFTA00231696 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 12 Incident Report Program: CMS301L Case No -000368 (goiLinued) her sister resides with Mr. . Both and IIII are currently attending High Ridge vocational school, whigjays an involuntary admitted juvenile educational facility. IIII stays at the • ' during the week and comes home on the weekend. According to , she was admitted to the school because of disciplinary problems that recently escalated. The facility also coordinates with the families to provide one on one as well as family counseling. According to Mrs. , she be Sunday, Feb 6, 2005. A friend of their house and left. They believe with the older gentleman, though they s close by with her (goes to ' , plays er. was by , a boy dating eball). Mrs. continued that on Sunday, picked up , and drove to Palm Beach where they met the man. Supposedly, the man haililiot of money and often has young girls come over to his house. offers these girls a way to make fast cash. The man starts with a If he likes them, he keeps the d and does more. The anv ;nformation on other than she lives on a i ves the incident occurred on named Haley picked her up at initiated the relationship ave any proof. further explained that ) . iiiIIIIIIIII talked of aim , that she had with the of a former friend of . She found it strange that they were no longer friends until she received the calli her mother telling her of the conversation she overheard between and a boy named Zach. told me of an incident that occurred on 02/09/2005. WI got into a fight at school 1 Palm HS). Mrs. Brown Assistant Principal, found over $300.00 in s purse. Sage gave different explanations for the large sum o money. Initially the school administration thought i s drug related but then dismissed the claim. Since that day, ill' did not return to school; she ran away Thursday, 02/10th or Friday 02/11 and returned to her mot use later that night after ' ' . It was t call from milvalar, fight with . The fight was instigated when accused at she learned IIIIII was the giiii t got int'. of being a prostitute. , who has legal joint custody of his daughter , signed the affidavit of prosecution indicating he wished to prosecute against the inappropriate sexual behavior with his fourteen-year-old daughter. Mr. state at he had no objections wi gency speaking is daugh about the incident. Mr. stated that mother is aware of egations and also was willing to cooperate. According to Mrs. , she does not believe her daughter had any additional contact with the suspect as she was with EFTA00231697 Date: Time: -- — Case 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 13 8:47:53 Incident Report Program: CV1S301L No 1-05-000368 (Continued) her mother and then placed into High Ridge. I contacted the School Board Police who provided me the ' 'on for Sable Palm, also known as High Ridge Family Center 4200 N Australian Avenue, dygt Pal c Checking the school board records for IIII and , there was no disciplinary record found. I was advised if no disciplinary action was taken for a fight, such as an expulsion or detention, the incident may not have been recorded. This was at the discretion of the individual school security and principal. 03/15/2005, I called t ach County Sheriff's Office and left a message for PBSP Sgt. , Child Abuse Unit. On 03/1.0 t female therapist. During an about the allegations anything had h identif' owed. boyfriend worked for a wealt also admitted that money. to High Ridge/Sabl re white Also present was • h audiotaped interv* poke with that were made. initially denied y admitting to going with IIIII ( ) ch to pick up money ilk' was as the cousin of her fo . She u timate y admitted to knowing that and possibly did sexual favors for him. She had offered her an opportunity to make identified boss as a white male named "Jeff" who Palm Beach a er positively identified as iiiiiiy Epstein). ained that she was first aiiiiiiied by house, when they were at house. Acc to to go with she was not su ac as going on with but agreed to with her. boyfriend) ngry when he heard inviting to any it was to pick up money the man owed stated ed told her that she would pick her up at her house on Sunday. was e exact dates but knew it was a Sunday. According to , along with an unkno ly c female, picked her up at her father's house on . told her ey were shopping. It was later confirmed by that picked his daughter up. According to Mr. drove a pick up truck. droveIII on the whereby ) age, sr,!!M along with the unknown female to re, a lion occurred between and told that if Jeff asked her ould say s e was eighteen. recalled that IIIIIE house was on a dead end street. All three girls walked up a drivewa what appeared to be a small guard/security room. In fact, recalled a male approaching asking what they wanted. stated they were there to see . The male allowed them to continue walking up to the house. EFTA00231698 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 14 Time: 8:47:53 Incident Report Program: CMS301L Case . : 1-05-000368 (Continued) stated the man told them that Epstein was not there but was expected back. He allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside. Shortly after, Epstein oman, described as white with blond hair entered ' en. believed the woman was Epstein's Assistant. added that t e woman did not seem friendly and kep onse and direct. Epstein introduced himse as knew each other. g 'mpression that Epstein and described Epstein as being approximately friend forty-five years old, a long face, and bushy eyebrows, with graying hair. and Epstein left the kitchen leaving and friend alone in the kitchen. They returned a short time They all spoke briefly in the kitchen. peaking to me, became upset and started to cry. stated the wo ucted her to follow her upstairs, which she did. According to , the woman led her to a room that had a massage table in it. The woman started to fix up the room, the covers on the table and taking lotions out. She then told that Epstein would be up in a second. n left the room, and soon afte it walked in and told to take off_ her clothes. As was telling me with a pointed finger, ted he was stern she did not took off her tein, dressed in a towe cold her to stated she removed her pants leaving Epstein then instructed her to give him a spec' • ion for her to use. Epstein laid on As to give Epstein the massage, what had happene , she looked away fro repeatedly pressed it into her thigh. when he told her to take off her clothes. know what to do as she was the only one there. shirt leaving her bra take oft everything. her thong panties on. massage pointing to a the table, face down. he told her to et o giving Epstein the massage, later explained that wacking off was masturbating). stated she was di Epstein's actions but did not say anything. According to Epstein told her that she "had a really hot body." Epstein excused himself and went to the bathroom where she bel masturbated again. Epstein returned to the room and told OM that he was done and gave her three hundred dollars. They went back down where . Epstein said good-bye and they When told asked how ill go and asked what did she Ni y t ein asked for a massage, y statediiiiiow." stated they then went shopping. stated also glair, but that she did not know why since she was confident that did not do anything. described Epstein's house as a two story pink house with a Cadillac Escalade parked in the drivew re were gates leading into the property. From the kitchen, SW recalled walking up a flight of stairs, lined with photographs, to a room. Upon entering EFTA00231699 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 15 Incident Report Program: CMS301L Case No 1-05-000368 (Continued) the room there was a large bathroom to the right. recalled a hot pink and sofa in the room. There was a door on each side of the sofa. recalled there being a mural of a naked woman in the room, as well as several photographs of naked women on a shelf. stated Epstein did not c front of her but did take off his towel, exposing himself. recalled Epstein being hairy especially on his ches ein also had a hairline that conti is buttocks. admitted to seeing his penis. I aske if she knew what being circumcised meant and she stated no. then said that she thought Epstein was on steroids he was a "really built guy and his wee wee was very tiny." IIIIIIII would explain that when she stated "wee wee" she meant penis. stated Epstein exposed himself when he took his towel off, placing it on the floor as he laid down on the table. said Epstein was specific in his in n to her on how to massage, telling her to go clockwise, etc. recalled that ' Epstein got up from the table and went to the bathroom where she heard him making, what she believed to be sexual type of noises. (moaning) He then returned to the room where he ag " down on the table. ' rned over and instructed to massage his boobs. , Epstein continued to make moaning noises. resumed massaging his chest area. was now standing on the ground. Epstein turned to his side, and with the to he ground started to rub his penis in an up and down motion. stated Epstein held on to the s er back as she massaged his chest, back and shoulder area. recalled Epstein ejaculating because o use the towel to wipe himself as he got off the table. also recalled Epstein having a noticeable freckle on his chest. Epstein then left the roo got dressed. She went downstairs where she met l an the unknown white female. admitted to getting paid three ollars in cash from Epstein. Before they left, Epstein asked to r phone number. As they were leaving the hou asked what had happened and how much she was paid. stated seemed upset or us when she told her that she received three hundred... stated received onlyliga hundred dollars that day. stated that she believed IIIII was paid two hundred dollars for bringing her. to be rich; sure where never saw not spoken with that if they do this every Saturday, they could agreed. They the pi gh she is not ibly at TJ Maxx or stated she as she got into a fight at school. She had either as her mother took away her cell phone. I asked if she was aware of any video equipment while she was in the room. She stated no. EFTA00231700 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 16 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) stated she was afraid that would retaliate against her amily if she ever went to the police regarding the incident. stated that her fath vehicle was recently vandalized. admi to ' what had happened with Epstein. According to became angry a set, punch' in the wall. guessed that it was who told about the inci ent, and now there were rumors in school about and what she did with Epstein. I then talked to about d lying. We talked about the color sweater she was wearing. denied having sexu intercourse with Epstein. She denied touching his penis. al again admitted to observing Epstein masturbate. agree ooperating with the police department in placing a phone call to in a controlled setting„I met with Ms. Back and advised her of the families' as well as willingness to cooperate with this investigation. Copies of this interview were placed into evidence. I made contact with , mother of , I advised her briefly of my investigation. She was aware of the incident and stated that she overheard a porti f a tion that her daughter was having with a boy named . stated that it was her opinion that both girlalyjiga . recalled hearing her daughter calling IIIIIIII a whore. admitted that she did not listen to the • e conversation but did confront her daughter about i told her mother that somethin effect that ha slept with an older man for money. stat he would not object to me speaking with her daughter. It was s belief that everyone in the school ve knalgaa.agat t is ecause of the fight th ughter and IIIIIIII had gotten into. I reminded that this was an ongoing investigation and requested she not discuss the fact that I had contacted her. She agreed. On 03/16/2005, PESO Sgt. eft a message that he was returning my call. I spoke wit and discussed the case with him and inquired if he had a pen a egations or cases where t uspect resided in Palm Beach. state was unaware of any. offered any assistance if needed. stated it was his experience that due to the age of the parties involved, it would be difficult to interview them and expect the investigation to remain confidential. Because of the time delay, there was no need for the victim to be taken to a medical facility for a physical for the purpose of obtaining evidence. There was also no need to take her to CPT as she was already in a juvenile facility, with an assigned therapist, in which coordinating a day and time to obtain a statement could be made On 03/17/2005, I queried Jeffery Epstein on the internet and obtained EFTA00231701 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 17 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Coiiiiued) of Epstein to be used in a photo line up. I met with at which time she viewed the photo line up. diately recognized Epstein and pointed to him (Position #5). signed the photo line up under Epstein's picture. This signed line up was placed into evidence. On 03/18/2005, I met with placing a controlled call to and asked if she could arrange another meeting with stated that she would have to call him and make the copy of this conversation was placed into evidence. advised uncle. is sc eduled 03/21/2005, I coordinated with surveillance on 358 El Brillo. for the purp spoke • Jeff. arrangements. A and IIII and was t t e state to visit with her aunt and to return to Florida on 03/27/2005 PB BSF Unit and OCVAN to initiate 03/21/2005, Coordinated with Det. r pulls from 358 El Brillo. On this same d I ca l lid to schedule an appointment to speak with . She stated the school guidance counselor was reluctant to ave police presence at the school. I assured her that I would respond to the school in civilian clothes and an unmarked vehicle. called a dvised that I did not need to make an appointment to see ed a return phone call from stating till.' would be attending the fami y t erapy sessions with I received messages from I conducted a computer query on Epstein. The results of this query indicated the most recent driver's license on file for Epstein was for the state of Florida, which had expired. A cross reference of Epstein s residence, revealed the following affiliated nam 02/21/1985, Mark L. Epstein, w/m dob Maxwell, uk/f, dob 12/25/1961. A computer history. On 03/21/2O95, I spoke with requeste she not discuss the daughter as I did want t told at t is timell t and to the fact that has decided Palm Beach, , w/f, dob , & Ghislaine N. query for both returned no cell phone wk . I Incident with anyone including her I nvestigation compromised. I was have not been getting along due to continue living with her father. I placed telephone calls to both the and residences requesting to speak with them regarding the EFTA00231702 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 18 Time: 8:47:53 Incident Report Program: CM1S301L Case No • 1-05-000368 (Continued) . I received return phone calls from Mrs. and advised them that I would be contacting family therapist to coordinate a t' eet wi This was at the request of both Back and Mrs. that strict classroom and therapy schedule be disrupted as little a le. I also undated them to the investigation thus far. Both and stated th o objection to my meeting with In with Ms. , she identified the l umber of as being the phone assigned to . Ms. had no objections and provided consent to giving it to the polic ent for the use of placing controlled phon lls from it. stated the phone had been taken away from as part un ent for not doing well in school. According to , used to be an excellent student, but in the past two months has 'rritable, verbally abusive to the family and has run away. stated her daug , ecent behavior is the opposite of what she normally is. stated they are going through family therapy sessions with t e school builiiii of this had come up. Arrangemen made for Det. Captain to retrieve the cell phone from at her place of employment. I called High Ridge Family Center, and requested to speak with Ms. Back. Upon speaking with Ms. Back she advised me that she was in the middle of therapy sessions and would call me back once the sessions were completed. Ms. Back stated the sessions should be concluded by 7:00 PM. At approximately 8:00PM I had called Ms. Back at which time I left a message voice mail requesting a return phone call. I spoke with Ms. and advised her that I did not meet with her daughter and that I would again.ALLempt to coordinate a ' • the counselor so as not to disrupt IIII s school sc had no objections. Shortly after speaking with Ms. I received a call from Ms. Bac I explained the s' tion and requested a tiiiito meet with illl . Back reviewed s schedule and advised that would be available after 3:00PM. On 03/30/2005, I met with M and at High Family Center. I d of her conversation with . During this time initiated a conversation with me in which s she admitted that she was not telling me everything that ned during the time she was alone with Epstein. According to h , and Epstein used I there tion as the . I if Epstein ever asked her age and she stated he had. stated she told ' was eighteen. When Epstein asked what school she was in, responded she was in the grade at Wellington. During ourse of this incident, stated Epstein told her that had worked for him for years. We then continued wit ntrolled call to imately 3. . , er cell phone, mit call to s home, was not home. . At was told EFTA00231703 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 19 Program: CMS301L Case No. . • - -000368 that was working a cell phone, . W/P, Olive Garden Restaurant, ocated on Forest Hi During and she had heard rumors th asked if they, meaning claimed to a hat Jeffrey. told know anything a out Epstein. someone to work tomorrow and as stated she would call Epstein an (Continued) could be reached on her is employed at The is Blvd in Wellington. ersation between , what happened, starsna that going to press charges. , knew about Jeffery. father had found out about that t parents) did not told that Epiiiiiineeded if she wa ble. d then call back. During the course of these conversations with , she would at times appear to be articulate and well spoken. She would then start to act in an immature man ooking around, not paying attention, drawing on a paper. would offer me a high five whenever she claimed to have to e truth in the details of the afternoon at Epstein's house. would sit in the chair, with her knees propped up to her chest as she admitted that she did not tell me the all the details of her encounter with Epstein during our eting. As a means of positive reinforcement I would high five On 03/31/2005, subpoena zstaatig. -n- T-111. and phone Wirel and Cingular Wireless, IIIIIIIIIIIIII. ( e numbers) were drafted. On 04/01/2005, I met with members of PB BSF Unit for the purpose of conducting surveillance on 358 El Brillo. Cross-reference supplement On 04/01/2005, I met with Det. of the Palm Beach Police Department who provided me a copy of the concealed weapons permit for Mr. Epstein. It revealed Epstein had a valid permit. There was no current photo attached to the renewal notice. On this same date identification of described by 358 El Brills", I queried various different web sites for a possible the purple item retrieved from the trash pull from 'tem was similar in description as the one and used by Epstein. I made contact with Spicygear.com and spoke with the owner John. I emailed a photograph of the item for his opinion. He identified the items as a Jelly Anal Wand di some sort: The item is easily available at sex shops in South Florida. 04/06/2005, I conducted business queries into Epstein utilizing the internet. I located articles relating to financial reports. There was no local history. On 04/01/2005 - 04/03/2005, with the assistance of BSF, there was EFTA00231704 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 20 Incident Report Program: CMS301L Case No • 1-05-000368 continued surveillance on the property. On 04/04/2005, cop and 04/01 f to herself as states that she could pick Epstein's house for an eleven o clock appointment. placed into evidence. On 04/05/2005, a trash pull was conducted at 358 El Brillo by Det. III and me. There were several messages written on vari forms of papers. There was a message from indicating ii. 11:00. The following was additional information obtaine from 358 El Brillo: Jean Luc • 0 • • ; a message receipt d She is looking to speak to you .; • On 04/06/ I fax ena requests to SA office for (Continued) it messages, dated 03/31 ale identifying up to take her to A copy of this was • 1. 04/06/2005, I called , and spoke with Princ a student by the name of School, , ext He confirmed that they had . He requested a written request prior lialeasing any additional information. On this sameile I a requ or student and parent information on Ilk. I advised that due to this being an open investigation he was not to discuss the matter with anyone. On 04/08/2005, I receive siiiiirom following information: , w/m DOB F1 ' . Parents name: work Det. provided me with trash obtained from 358 El Brillo for 04/06 he following information was retrieved: Jet Aviation itinerary, indicating a departure date of 04/05/2005 at 4:00 PM with an arrival in New York City of 6:15PM. Flight crew captain David Rodgers, co-captain, Larry Visoski, flight engineer ...1orrison. Call sign N908JE; a note stating Bye J. thank you , hand written notes & messages 11-Gle •30 chicken, Melis , 3 September B & J, Big Screen x8, 9 . school @ • ; Business , leaves e here tomorrow @ 10:30 Am; Mrs. . There was no trash for 04/08/05. eived the results of a subpoena request from Bellsouth for The results only provided subscriber information. I contacted Alice Grant Investigative Subpoena Compliance Center who stated the request was not complete and the results would be sent to EFTA00231705 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 21 Program: CMS301L Case No 1-05-000368 me as soon as the query was finished. Cross-referencing the names and well as phone numbers, which were o tattle from message trash pulls, I identified the before mentioned 'ndivid acq omeon El Br' DL and , DOB both above the legal age of consent. On 05/03/2005, I ith and updated her on the investigation. stated that was doing well in the school. Her contact wt he outside is limited as they do not have access to the phones. comes home on the weekends and she is not allowed to go anywhere alone. On 05/11/2005, I made arrangements to meet with and On Thursday, 05/12/05, I spoke with regarding the case. They will be moving to GA in July 2005. They will be very busy over the next few weeks but would be available via phone. Will coordinate a date to meet to discuss the matter further. (Continued) as notes via ing FL are During this week I conducted surveillance at Epstein s residence and at the airport, but there was nothing to indicate that Epstein was in town. Due to co appointments, rescheduled until 06/02/2005, to meet with Ms. I also spoke with and updated her to the investigation. On 06/02/2005, I met with and . Sandborn advised that she could be reached via her cell phone until she is able to provide me with her new contact information. I also received a message from but the line was busy. June 14, 2005, I received informa n that Epstein's plane was at Jet Aviation. I spoke with Det. regarding surveillance. Attempted call back I called the Olive Garden and asked for advised she was not working today. This would indicate that was still employed there. On 07/07/ I faxed subpoena requests to SA office for s ph (Phone numbers and . The original subpoena requests only provided subscriber and billing information. On 07/20/2005, conducted a trash pull arranged by Ofc. III. Inside there were misc. papers with phone numbers and names. There were EFTA00231706 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 22 Incident Report Program: CMS301L Case No 1-05-000368 (Continued) misc. female hygiene products in the trash. Based on a prior Auto Bril a sible subject residing at the fit the description provided ucted surveillance in the area of a female Track report residence is by officers who had con seen entering and leaving the residence. On 07/21/05, I received the Duces Tecum dated 07/18/05, which was clerked by ASO On 07/26/2005, I received the results of Bell South Subpoena. On 08/04/05, I received DHL Express from T mobile with the results of the query. I spoke with who confirmed that was still living out of state. It appeared that all was going well. I left a message for at On 08/08/2005, I received the results of Cingular cell phone subpoena. During the week of 09/08/2005, I checked 358 El Brillo and the Palm Beach International Airport but there was no direct indication that Epstein was in town On 09/08/2005, I reviewed th otes of this file, as the case will be turned over to Det. On 09/11/2005, while on patrol, I conducted a check at Epstein's residence and found that it still had the hurricane shutters on. On a drive by the Palm Beach International Airport later that afternoon, I did not observe Epstein's plane. On 09/14/2005, I conducted a check at the Palm Beach International Airport but did not see Epstein s plane. On 09/19/2005, I spoke with to keep her updated an find out if there was any change of a•• e n . I was told no. I left a message for at , in order to provide her with Detective s information. **************************** N NA ARRA Reported By: Entered By.: 9/2l/05 A. 9/21/05 On September 19, 2005, I met with Officer and received the information pertaining to this case. Members of the Burglary Strike ad previou en conducting surveillance on both Epstein and Officer assigned to monitor the E • home and Sgt and Officer were assigned to monitor . Both teams provided a surveillance log that will be placed into the EFTA00231707 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 23 Incident Report Program: CMS301L Case No 1-05-000368 attachment file. (Continued) Det. was assigned to relieve Officer at 4:00 pm; he informed me that at approximately 8:00 pm, Epstein had left for the airport and his private jet was sitting on the tarmac. Epstein's private vehicle drove to the jet and unloaded packages into the jet. It appeared that Epstein left the county at this time. Surveillance will continue to determine when Epstein will return. Inv Continues. **************************** N A R R A # *************************** NA NA Reported By: , A. 9/23/05 Entered By.: A. 9/23/05 On Friday, September 23, 2005 at approximately 1:45 p.m., I began to copy a tape micro cassette, under case number 05-368 and property number 05-243, tape number 1. I placed the tape in the telex copy-et, series 2 machine and began to go through the copying process. Approximately 1/2 through the tape, the tape wrapped around the spindle and became locked and stretched the tape. I examined it and determined that it was in the best interest to leave it is as a prior copy had been made and turned oviiiii Sergeant . I immediately took the tape to Sergeant and allow ' to examine it and then obtained the copy from him and Detective and brought the copy of the tape down and made a copy for him based on that. The tape was placed back in the original container and is retained in the evidence bag under the previously mentioned property number of 05-243. It is not advisable to attempt to copy this tape as further damage could result to the recorded material and there is an existing copy anyway. lil l ****************************NARRA # *************************** Reported By: , A. 9/26/05 Entered By.: A. 9/26/05 On 3-24-05 at Illaa pm, a copy of tape 2 (c - 94) had been made for Det. IIIII by Eviden ialist The copy was turned over to Detective . On Friday, 09-23-05 at approimately 2:15 pm, I was in the process of reproducing audio tapes (micro and standard) to standard size when it was discovered, in the review pro at tape number 2 was blank. I notified Sgt. and Det. le I was informed that I ey had a prior copy and I could use it to make a master tape. I did and when reviewin signing the evidence sheet, I noticed Evidence Specialist had written "#2 is blank." I obtained that copy from Det. and made a new copy on a standard size tape. The new copy was placed in the evidence bag under EFTA00231708 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 24 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) property number 05-294 with the blank tape. **************************** NA Reported By: Entered By.: ilial A. NARRA *************************** Copies of the 9 /26/05 9/28/05 the tapes that were submitted into evidence were requested. y, trash pulls were started on September 21, 2005. Sgt. made telephone contact with Tony Higgins, Supervisor of Sanitation Department, and requested that trash be collected at House located at 358 El Briliiiin ach. Sgt met with Sanitation worker, and him enter the property at 358 El Brillo. Shortly t ereafter, exited the property and placed t white trash bags in the empty well in th he truck. with Sgt. who removed the bags from the well and placed them into one large black trash bag. The bag was returned to the Police Station where I was waiting for him. Upon his arrival, we inspected the bags where several notes and papers were found. These notes cont ames QL.girls with times. Additionally, there was a note from and IIIII t ey Ep on which stated,"For a good time call and " Also, , there was another telephone number note . Also found was a written note, which stated, can not come at 7 p.m. tomorrow because of soccer. These items were written on notepads that contain Jeffrey Epstein on the bottom of the notes. These items were placed into evidence for future follow up. I requested subpoenas for subscriber ation he telephone numbers listed n the m and . The cellular telephones and are both assigned to Cingular Cellular Service. Other notes were found within the trash on Jeffrey EpsteiaLag, paper contained telephone numbers. One note had "IIIIII" with written on it. This cellular number ' gned to Cingular Cellular Service. Another sheet had written which is assigned to Bell South Telecommunications. The subpoenas were picked up and submitted to Cingular and Bell South Telecommunication for subscriber information. then drove away where he met On September 22, 2005, I was informed by Sgt. that there would be no trash pick up as it was recycle pick up day. A request for copies of the micro and standard size cassettes were requested from crime scene to familiarize myself with the interviews conducted. On September 23, 2005, the tapes were received and I beg become familiar with the interviews that were condliglia had met with Town of Palm Beach Sanitation worker, IIIIIIIiiill and o him enter the property of 358 El Brillo. Shortly thereafter, exited the property and placed t white trash bags in the empty well in the rear of the truck. then drove away where he met with Det. who removed the ags rom the well and placed them into one large lack trash bag. The bag was returned to the Police Station where I was waiting for him. Upon his arrival, we inspected EFTA00231709 Date: Time: Case 7/25/06 8:47:53 PALM BEACH POLICE DEPARTMENT Incident Report Page: 25 Program: ams3olL No • 1-05-000368 (Continued) the bags where several notes and papers were found. The notes will be inspected for future use. The items collected were placed into evidence. It became evident that some of the recordings were recorded with background noise and some interference. The calls most the control phone calls from the victim to the suspect I obtained the graphic equalizer and discovered that th ac lls are able to be legible with the use of the equalizer by lowering the background noise and increasing voice gain. I also learned that a tape was broken during the coping of the tape. I returned the copy of the tape marked Property Number 05-243 to have it recopied to have an original in evidence and a working copy with the file. earching the file, it was discovered that the suspect, cellular cal oenaed incorrectly. The suspect number was and the original request was for I requested the information through Cingular Cellular Service from FebruaLa.Z005 through the present. The purpose was to have a record of IIIIII making calls to victim, Jeffrey Epstein and the frequency of calls. The request was submitted to the State Attorney's Office. Investigation Continues.... ****************************NARRA *************************** NA Reported By: Entered By.: . A. 10/06/05 10/06/05 On or about September 23, 2005 at approximately 0915 hours, I iiiiiiiir t Brillo and met with PB Sanitation worker . had been previously notified to assist in trash rimr:m:r the rest enc frey Epstein, 358 El Brillo, Palm Beach, Florida. I observed enter the driveway of 358 El Brillo and remove several plastic bags of trash and place the contents into the back of an empty sanitation truck. I then followed to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There was a total of 4 white in color plastic bags and each contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. All is of evidentiary value were removed and turned over to Det. for follow-up. On or about September 26, 2005 at approximately 0900 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jessie Jones. Jones had been previously notified to assist in trash pulls at the residence of Jeffrey Epstein, 358 El Brillo, Palm Beach, Florida. I observed Jones enter the driveway of 358 El Brillo, where no trash was located within the receptacles. I left the area without incident EFTA00231710 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 26 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-011111., (Continued) and notified Det. to that affect. On or about September 27, 2005 at approximately 0915 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jesse Jones. I observed Jones enter the driveway of 358 El Brillo and remove one plastic bag of trash and place it in the back of an empty sanitation truck. I then followed Jones to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There was a total of 1 white in color plastic bag which contained correspondence for 358 El Brillo. All Smiis of evidentiary value were removed and turned over to Det. for follow-up. On or about Monday October 3, 2005 at approximately 0915 hour d to 358 El Br'" met with PB Sanitation worker I observed il enter the driveway of 358 El Bri lo and remove several plastic bags lo trash and place the contents into the back of an empty sanitation truck. I then followed to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There was a total of 7 white in color plastic bags with a red tie and 1 black in color bag which contained 2 white in color plastic bags with a red tie. Each of the bags contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. Inside of one of the white in color bags, I located a broken piece of a hard plastic or clear acrylic stick, which was shaped with small ridges. This device is commonly used as a sexual toy which is inserted into the vagina or anus for stimulation. This item, along with all is of evidentiary value were removed and turned over to Det. for follow-up. On or about Tuesday October 4, 2005 at approximately 0928 house d to 358 El Br met with PB Sanitation worker . I observed enter the driveway of 358 El Brillo and remove several plastic bags of trash and place the contents into the side well of the sanitation truck. This side of the truck is separate from the rear of the truck and does not come into contact with other trash. I then followed to a predetermined location and seized the trAth from the ruc . The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There was a total of 2 white in color plastic bags which were tied at the top. Each of the bags contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. F. nents of evidentiary value were removed and turned over to Det. for follow-up. On or about Wednesday October 5, 2005 at approximately 0928 hours, I EFTA00231711 NA SI **************************** N A R R A *************************** Reported By: 1O/07/05 Entered By.: A. 1O/07/05 I met with Det. and requested further assistance to maintain trash collections at Epstein's residence at 358 El Brillo Road. On iiiiier 3, 2005, at approximately 10:30 am, I was contactgajpy.Sgt. to and to the Palm Beach Police Station. Det. 'I'll' had observed Epstein ridin bicycle on South County Road. Upon my arrival, I met wit in Town; we interview e girls that are roug t to his in the county, (outside of our State Attorney s Office Investigat Assistant Supervisor Inves tigator assistance to intery us at the of assigned I ator to assist ocation and interview county. Supervisor had responded to the a ho advised, as Epstein was currently as to her involvement with Epstein house. As we were to interview jurisdiction), I contacted the and made contact with I requested as the interview the Date: 7/25/06 Time: 8:47:53 Incident Report Page: 27 Program: CMS301L Case No • 1-05-000368 d to 358 El Br I observed remove several plastic bags of bed of the sanitation truck. I then followed trash from the true . Police Department w assistance of Det. PALM BEACH POLICE DEPARTMENT (C nued) met with PB Sanitation worker enter the driveway of 358 El Brillo and trash and place the contents into the to a predetermined location and seized the The trash was transported to the Palm Beach egan sifting through its contents, with the There were a total of 2 bags, one of which was white in co or and tied in a knot at the top, and the other was a black in color bag, which contained two white in color trash bags along with loose debris. Each of the bags contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. All ts of evidentiary value were removed and turned over to Det. for follow-up. ' g Florida Tag of sill Det. vehicle parked in the in Loxahatchee. Sgt and awaited the arrival of Investigator was briefed that should she wish t would be needed. However, should station for further questioning, he wou, and/ knocked_ on_ the__door and met with_ that we were investigat claim involving Jeffrey Epstein of El Brillo in Palm Beach. was asked if she wanted to accompany us back to the police station or further questioning. She was also told that at the conclusion of the interview she would be returned home. She agreed and wished to change her clothes prior to accompanying us back to the police station. At the conclusion of her changing clothes, she advised she was ready to go. I thanked Inv. and advised she was going to voluntarily return to the police station. y. and viewed her vehicle a red Plym in the driv d to and Upon his arrival, he terviewed within her home he agree to return to the ce nc ede t. wastrad_ EFTA00231712 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 28 Program: CMS301L Case No • 1-05-000368 (Continued) Upon IIIIII s entry in the unmarked Detective vehicle, I placed a tape recorder within the vehicle to record any conversation in the vehicle. During ' ' station, vised ng at the and is majoring in journalism. Upon our arrival at the police station, was broug the interview room in the Detective Bureau. I explained to that 1 appreciated her willingness to assist us an informed her that should she desire to leave at any time she may do II. I fur xplained the interview room door is only closed for priv stated she understood. During the taped sworn iew, was asked how she came in contact with Epstein. state k when she turned 17 years of age she was approac a riend in the Canopy Beach Resort in Rivera Beach. was asked i she wanted to make money. She was to $200.00. Jeffrey. (Unknown last name) and Tony (Unknown last name) picked her up and she was taken to Epstein's house. Upon her arrival at the r. house, she was introduced to Epstein in the kitchen of the female introduced She to also known a her washite . She was led u irs to the main bedroom known to her as Epstein s bedroom. arranged the massage table and covered the table with a sheet. She b ht out the massage oils and laid them to the massage bed. would be in a minute. hen left the room and informed her entered the bedroom wearing only a towel lay on the table onto his stomach nicked massage oil for to rub on him. During the massage, stated, He tried opped him. I asked how he tri touch her. He and she felt uncomfortable. also stated Epstein has a vibrator, which is large and white in color. told Epstein, I'll massage you but I don't want to be touched. stated she performed t sage naked. At the conclusion of the massage, Epstein paid $200.00 for the massage. He explained, I know you re not comfort e, but I'll ou if you bring some girls. He told her the younger the better. stated she once tried to bring ear-old female and Epstein stated that the female was too was asked how many girls she t in total to Epstein. Ill, , t 7a e and the victim in this case. would have to provide a massage and should make thought about the offer and agreed to meet with I asked whicLmaaamwas the youngest. advised the victim was the youngest. IIIIII stated every girl she brought knew what to expect when they arrived. They were told they would provide a massage, possibly naked, and some touching. I asked her if the victim was aware. She stated every girl she brought knew what to expect. She explained she knew the victim wanted to make money. She approached the victim and explained about going to work for Jeff. The EFTA00231713 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 29 Incident Report Program: CMS301L Case No • 1-05-000368 victim agreed and arrangements Epstein's house on a (later identified as victim s house. They traveled to Epstein's House and entered through the kitche or. They met with the house chef and Epstein s assistant . The v was introduced to Epstein while they were in the kitchen area. led the victim upstairs and Epstein went upstairs. When assage was over, the victim returned to the kitchen area. stated she was paid $200.00 for bring the victim to Epstein's. stated the victi her she was paid $300.0O for the massage. Back in the vehicle,m asked the victim what happened. iiiiiictim told her about the massage and then they went shopping. stated the victim was the last person she brought to Epstein. She further state (Continued) ade to bring the viol". stated that she and picked up the victim at the t she had changed her cellular number to avoid being contacted by announces to h' . She continued that when Epstiiii would contact istant that he is traveling to P each, range girls for , later identified as Date of Birth had told that Jeff likes to have his fun with the girls. , stated that once her parents discovered that she was visiting like, they disapproved oil encounters with him and she stopped. further stated that still tri call the house and leaves me the were DOB DOB and DOB Sgt statements, she ha Epstein's house. to assist further in entered the room and explained that based on her own icated herself with bringing underage girls to was aware of what she had state wished opes to receive a lesser charge. provided cellular telephone numbers for the girls she had mentioned previously. Additionally, she iiiiiirovided possible addresses and areas in which they lived. As was being taken home in the vehicle, a tape recorder was placed within the vehicle to record any cations within the vehicle. During the drive back to her home, sent girls to clients for sexual favors in California). made the comment I m like a Heidi Fliess. (Hollywiiiiiidam who was dropped off at her house without incident. Sgt and I went to ahatchee, Florida.12..m.attamiglLa speak with . We met with Mrs. IIIIIIIII ( s Mother) at thil i door. We explained the ongoing investigation and felt that may have additional as we had information that-she had worked for Jef€. Mrs home. We sat . introduced us to her husband and allo n the • ing room and met with firth As she was under the age of eighteen, Mrs. was advised we would be speaking with her. She expressed, I . n interviewed if her daugh she wanted to assist. As we , she denied having any inapprw=ate encounters with (Epstein). She stated she had gone to IIII s EFTA00231714 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 30 Incident Report Program: CM0301L Case No 111010 (Continued) House with approximately eight months ago and sat in the kitchen wit t e ouse chef but nothing hap s the parents were present during the interview, we felt that was withholding information from us. She made several comments as to she has put the entire incident behind her. I left my direct telephone number and Med should she wish t ith me again to telephone me. Sgt and I thanked Mrs. for her time and left the area. She stated she would ask her again after as to what happened at Epstein s house. I informed her that had my telephone number and hopefully she would call. and I then attempted con in Loxahatiiii, We met with her daughter. was at the Wellington Ma a explained the ongoing investigation and felt the additional information as we had information that Jeff. We left our phone numbers and asked her to her daughter's return. We then left the area. On October 4, 2005, at app a voice mail message from with her daughter and s house. I contacted shower at the moment and wou College. I informe Det. and state she was to en to the house by told she could make money working fo f. S have to provide a massage to Jeff. stated the house she was brought to the kitchen area by I would be en route I drove to the During a sw at stated was s not home. We may have she had worked for telephone me upon :05 am, Sgt had retrieved . She stated she had spoken ation as to what occurred at Jeff who stated her d was in the e traveling back to to attend home in home and met d atement, She was e was told she would er arrival to They met with ouse chef and stayed in the kitchen. She was introduced to Jeff's assistant and was brought upstairs to the mater bedroom. prepared the room and massage table for a massage. Epstein entered the room and she provided a massage. stated she kept her clothes on durin stated sometime during the age Epstein and pulled her close to him. I said she was wierde out by the incident involving Jeff. At the conclusion e massage, she was paid $200.00 for the massage. i asked if she has an al training in massages to which she replied no. I asked her i rece any monies for taking her to perform the ma stated received money for t re. and another girl, stated she wisifh_____ stated she w ' d i kitchen wit , while 's holiiiiiii was taken upstairs by stated she only did the massage once, as she was wierded out by the whole experience. At the conclusiiil of the interview and the t as stopped, I was informed that had attempted to reach kill via cell phone. A voice mail message on October 4, at 10:59 am, revealed a female voice who identified herself as who requested her to call her back reference the Min EFTA00231715 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 31 Program: CMS301L Case No • 1-05-000368 (Continued) police ques 'ng. This voice mail message was recorded onto a micro vided the incoming telephone n stated she inadvertently told about the police investigation because had calledher to tell her about how she just received a rental car from Epstein. Vans:sat had called her to tell her that she was given a AS Silver Nissan Sentra, to utilize to visit family and visit rtayn asl an v t w in g on a house that the be asking questions. stated then called ice w and and asked what was going on me e ongoing police investigation. According to has since then been g to contact her ask about the police questions. I instructe not she would notify Jeff Epstein and and do not provide, more information to as what was transpiring. to contact Investigation Continues... ****************************NARRA V 8 *************************** NA Reported By: 10/07/05 Entered By.: A. 10/07/05 On March 30, 2005, I was asked by Sgt. to n conducting surveillance and trash pulls reference Detective conducting a criminal investigation involving Jeffrey Epstein. I was advised that Epstein was possibly engaging in sexual contact with young females. On March 30, 2005, I made contact with Town of Palm Beach Sanitation Office Supervisor Tony Higgins and requested trash pulls for 358 El Brillo Way to begin on March 31, 2005. On March 31, 2005 at 9:20 a.m., I responded to the area of 358 El Brillo W et with Town o each sanitation employee, Jeffrey . I observed enter the driveway of 358 El Brillo Way, collect the trash bags from Epstein's propert ace the contents into an empty sanitation truck. I followed to a nearby area, were he turned over seventeen white plastic trash bags, which were collected from Epstein's property. I took the trash bags to the sanitation department were I sifted through its contents. it correspondence from Armani Excha d , Jeffrey E. Epstein notepaper with , an important message notepaper addressed to J.E dated 03 29 OS at 0.15-rm.-reference Peggy Seaga-1-7 U.S A rways￾boarding pass copy for passenger, Janusz Banasiak, Montgomery County, Maryland Health Department food service ID NO#40820 for Janusz Banasiak and Ghislaine Maxwell notepaper with names and phone numbers. Photocopie the trash collected were attached with the supplement. Detective was advised of the contents that were collected for evidentiary value. EFTA00231716 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 32 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) On March 31, 2005, Sgt. requested that I set up a surveillance vehicle on El Brill...conduct video surveillance of the front exterior of Epstein's residence. At 3:00 p.m., I set up a surveillance vehicle equipped with a video monitoring device. The surveillance vehicle was parked on El Brillo Way approximately fifty feet east of Epstein's driveway. The purpose of the video surveillance was to gather investigative intelligence by monitoring and recording all vehicle and pedestrian traffic entering and leaving Epstein's property. The video surveillance tapes were changed daily with a new Maxell T-160 VHS tape. Video surveillance was established for Epstein s from March 31, 2005 through April 05, 2005. On April 05, 2005, video surveillan s concluded. I reviewed the video tapes and advised Detective the surveillance videos yielded no evidentiary value. On April 01, 2005 at 9:30 a.m., I responded to the area of 358 El Brillo Way to meet with Town of Palm Beach sanitation employee, Jessie Jones. While parked in the area of 358 El Brillo Way waiting to col trash, I observed a white female, who I recognized as fr ida driver's license photograph. I made no contact with While parked in the area, I also observed Epstein s GMC Yukon truck leave the property as well as other vehicles arrive and park across the street from the property. The occupants of these vehicles appeared to be housekeepers, maintenance men, and gardeners. At 9:38 a.m., I met with Town of Palm Beach sanitation employee, Jessie Jones. I observed Jones enter the driveway of 358 El Brillo Way and collect the trash from Epstein s property. I followed Jessie to a predetermined area at which time I collected the trash bags from the sanitation truck. I transported the trash bags to the sanitation department, where I sifted through its contents. I collected mail correspondences addressed to Jeffrey Epstei i records and personal documents for Janusz Banasiak and as well as Epstein notepaper with the names and appointment times for and Brittany. No last names or other personal information was written on the notepaper. While sifting through Epstein s trash, I also collected a three-inch purple finger size object, which had a broken end. The object appeared to be a broke piece from a sexual toy similar to a (Cyclone Vibrator) possibly used for rectalmaratification. The sexual object was photographed for Detective packaged in a biohazard evidence --bag-Apessible body fluids) and secured-as investigative-evidence. -All collected from Epstein s trash were turned over to Detective for evidentiary purposes. On April 05, 2005 at 9:18 a.m., I sanitation employee, Jessie Jones. driveway of 358 El Brillo Way and property. I followed Jessie to a met with Town of Palm Beach I observed Jones enter the collect the trash from Epstein s predetermined area at which time I EFTA00231717 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 33 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) collected the trash bags from the sanitation truck. I transported the trash bags to the sanitation department, where I sifted through its contents. I collected mail correspondences addressed to Jeffrey Epstein as well as notepaper (Important Message) with names and telephone numbers. The following are items collected from Epstein s trash. . ( blank piece o paper ( black paper black p David MSN Hotmail web page with email address ( The following items were documented for Detective investigation for evidentiary purposes. On April 06, 08, 11, 12, 13, 15, 2005, at approximately 9:30 a.m, I met with Town of Palm Beach sanitation employees. I observed the employee enter the driveway of 358 El Brillo Way and collect the trash from Epstein's property. I followed the employee to a predetermined area at which time I collected the trash bags from the sanitation truck. I transported the trash bags to the sanitation department, where I sifted through its contents. All of the documents collected from Epste trash during my assistance were turned over to Detective for evidentiary purposes. On June 14, 2005, Detective contacted me and advised that the airplane belonging to Jeffrey Epstein of 358 El Brillo Way was parked at the Palm Beach International Airport. Detective requested that I begin trash pulls for the purpose of gathering evidence and intelligence. I made contact with Town of Palm Beach Sanitation Office Supervisor Tony Higgins and requested trash pulls for 358 El Brillo Way to begin on June 15, 2005. On June 15, 2005, I met with a sanitation employee. I observed the employee enter the driveway of 358 El Brillo Way and collect the trash from Epstein s property. I followed the employee to a predetermined area at which time I collected the trash bags from the sanitation truck. I transported the trash bags to the sanitation department, where I sifted through its contents. The trash yielded negative results and no evidence was collected. No further trash was collected throughout the week due to the fact that Epstein s security gates remained closed throughout the week; therefore, the sanitation employees were unable to gain access onto the property for collection of the trash. EFTA00231718 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 34 Incident Report Program: CMS301L Case No 1-05-000368 NA All evidence and intelligence gathered by this officer over to the detective bureau and no further action has this officer. End of supplement. MI **************************** N A R R A *************************** (Continued) has been turned been taken by Reported By: 10/07/05 Entered By.: A. 10/10/05 On October 4, 2005, I made telephone contact with who had left several messages on voice mail. During the message, she advised she was not completely truthful when we met in person but would like to speak with me to advise what had happened. She further advised she did not want to speak of this incident in front of her imat • , I made telephone contact with t . During a taped recorded : Approximate ear ago, when she was sixteen years of age her to house statement, stated the fol twice. The first time she went, drove to the house. TheymgaLered through the kitchen area where she waalatroduced to and IIII. She was taken upstairs to a bedroom by IIII who se e room up with a massage bed and brought out the oils to use. IIII then entered the r ing a towel. He lay on the table and picked out a lotion for to rub on him. At one point during the massage, he tried to remove her shirt' at ' int she became very upset and discontinued the massage. Both and Jeffrey had a verbal at which time she left without being paid. She met with who was sitting in the kitchen and told he o. received no money for that day. ill.' also said that had told her if she was uncomfortable with what was going on, to let him know and he'll stop. She knew that the more you do the more you are paid. Several she agreed to be takaa.a.second time by Once they arrived at the residence, IIIII sat iiiiie kitchen and took her upstairs to the master bedroom again. use. i the room up with a massage bed and brought out the oils to then entered the ring a towel. He lay on the table and picked out a lotion for to rub on him. At • during the massage, he tried to touch her bu ks. As was wearing tight j and had a tight belt on was unable to touch her buttocks. then rolled o ack during the massage; he attempted to touch her breasts. came upset again and told him she didn't want to be discontinued the was paid $200.00. the waiting for her. She told m" leave. said she never retu stated she is aware that her LLignd, house and had a problem with IIII. She provided downstairs where she wails se. was also at the a telephone number EFTA00231719 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 incident Report Page: 35 Program: CMS301L Cat No. : 1-05-000368 (Continued) for IIIIII. The interview was concluded and the micro cassettes were turn in as evidence. On Octobeilill2 researched the incoming telephone had left a message. The telephone number, , was assigned to ATT Cingular Cellular service. I prepared a subpoena request and faxed the request to the State Attorney s Office. Information requested was subscriber information as well as all incoming and outgoing calls for the months of September and October 2005 I later researched and discovered she resides in Royal t, and I dr lm Beach and met with at her residence in Royal Palm Beach. agreed to i with us in the kitchen area. During a sworn taped statement, stat wing: On or about November 2004, she was approached by and asked if she wanted to make money. She agreed and ld she would provide a massage to wealthy man in Palm Beach. Milk picked her up and drove her to a house in Palm Beach. She was br ' til l kitc house. She further stated that ( ) andhill ) went with them hey were brought intol iiitchen where she was introduced to and other females. stated she was introduced to a helper of Jeff; the female was described as white female (unknown n ith blond hair. She stated that the assistant was familiar with . The assist put out 1 ns to be used. She tolda he massage table and woul ailable in a minute. IIII entered the room wearing only a towel. lay on the mime table and picked a lotion to rub on hi ighs and back. further stated that during the massage asked her tiiiiiive her clothes. She complied and removed her pants and blouse. remember if she had removed her bra but feels that shill" was certain that she stayed in her thong underwear. continued his back, add m to massage was instructed to return e ground at which time turned to have his chest rubbed. Iiiiiimaggyged it was at this time she is sure he was masturbating. IIIIII digmagt want to look at his penis area because ortable. IIII removed and turned thong ejaculated she was it on. underwear Shortly thereafter, and removed himself from the table. He walked over to where the shower was and opened the shower in her direct view. this occurred, she stated conclusion of the shower, She stated she wasn't sure conclusion of the inte provide a massage for uncomfortable with the situation. glass door. She ed as he was taking a When I asked how old she was when d just turned seventeen. At the was paid either $350.00 or $400.00. , big knows it was close to $400.00. At the stated she never returned to She advised she was ashamed and EFTA00231720 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 36 Incident Report Program: CMS301L Case No. . • 1-05-000368 (Continued) Det. IIIIII and I then 1 e area and responded to the Royal Palm Beach High School where and all the above d girls had attended. I met with School Police Officer, Off - • . I explained I was looking for a previou o attended Royal Palm Beach High School. I inquired about illiiiiiilit I further explained that I was working a case in which most of the girls I hays, interviewed are either es or victims and felt that may be one as wel researched his previous student records and found . She attended the same year and graduated in the same as the other girls. I was provided the last known address of . her residence, in Royal Palm Beach. As Illp at was seventeen years of age, I had notified her mother, Mrs. At approximate) and I met with , that she would be interviewed reference an ongoing investigation in Palm Beach. I assured her that her daughter was not a suspect. I exp d the possibility of ing either a witness or victim. Mrs. advised she wanted to cooperat minted to the interview. During a sworn statement, stated the following: at the age during the month of September 200 e was approached by chance to make money. was friends with the friends of ill and knew the eople. did for ha previously told by her fr whim , cal erson kigagamto as and scheduled the appointment. picked IIIII up and drove her to Palm Beach to a street called Brillo Way. They drove to the end of the street and entered a large mi ewailliihey entered the kitiiii l the e and met with was introduced to . led upstairs to the main bedroo mALga and set up the room and turned on soft music. the oils. IIIIII dimiiii the lights exited the room and entered the with a massage table and se room wearing only a towel. picked oils and ins ted her to rub his legs, under hi tocks, back and chest area. asked her to get comfortable. advised she did not remove her clothes. She was wearing tight jeans andliiiropped tank top exposing biiiii, thillissage' removed his towel. As , attempted to reach down her pants through the buttocks area, howe as unable due to the tightness of the jeans and a tight belt. advised began to masturbate as she rubbed his chest. moaned as she rubbed his chest. She observed he was continuing to mas to and attempted each up her tank top and touch her breasts. pulled back and stopped. However, he kept masturbating until he climaxed. H towel he was previously wearing. I asked difference betweeiliircumcised and not c' knew and advised was circumcised. massage and left the area. She met with kitchen area and left the house. ',Waned himself with the if she knew the cised. She explained she as paid $200.00 for the who was waiting in the then explained she never provided another . She did however, go to the house with IIIIII and ) as they • EFTA00231721 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Incident Report Page: 37 Program: CMS301L Cad No • 1-05-000368 fend of advised she was went She advi sat in the kitchen area wit to wait for r that while they waited for , the them, as it was almost lunchtime. As massage, they left the area. I asked if would expected of her when she provided a massage. e liold what stated told her that a massage wo e expected possibly naked (Continued) present when r ver and advised yes, and possibly some touching involved. has no formal training in providing massages. spoke about a third a e went to house. drove an girl, is friend, to house. died she knew that had made providing girls for and she wanted to do the same t ' the hen ar he house and introduced and took bedroom. advised she doesn t know wha upstairs to pened as did no k about what happened in t oom. received $100. for going with her to ouse and recommending was unable to remember s telephone number. The interview was concluded and we le t t e area. chef prepared lunch for waiiiiiished with the Investigation Continues... ****************************NARRA ************************** Mt NA Reported By: 10/09/05 Entered By.: A. 10/10/05 On October 6, 2005, Det. and I went to located in Boca Rato with Dean of Students, . I explained to that we were investi e within the Town of Palm Beach and felt that a s t, , may have informs o is a student and currently on the She was in computer clas the time of our arrival. Turner sent a guard to locate in class a ing her to the office. allowed us to interview in an empty conference room. At 11:45 am I met with and explained to her why we there to interview here advised she was aware of the ongoing igation. IIIII stated she had previously spoken with who told h e was interviewed by During a sworn d_statement, tadshe_knew that rked for in Palm Beach. advised she has been there many times for massages. lilted her if she had fo raining in providing massages, stated she did not. advised she was told what was expected of her by providing massages and would have to remove clothing but if she felt uncomfortable just to say so and Jeff would stop pushing the issue. IIIII began providing massages and advised she kept her clothes on. She considered Jeff a pervert who kept EFTA00231722 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 38 Incident Report Program: CMS301L Ca. No • 1-05-000368 pushing to go further and further. telling him she had a boyfriend and t boyfriend. It wasn t until recently (Continued) explained she would keep t would not be right to her admitted to removing her iiiiies and staying in her thong underwear to provide a massage. explained Jeff wanted to be rubbed on his back and recently he began turning over to have her rub his chest as he mastur . He iiiid try to touch her breasts as she rubbed his chest. would t get away with more and more on each massage. stated, nally, drove her to the house for the original massage. left her cell phone number and every time IIII would come would call her for an appointment. Each time she went, would meet her at the kitchen door . She would bring her upstairs and prepare the massage table. ould ask her questions e knew she and would ttending . I asked if he knew her real age, stated didn t care. The most recent massage sh provided was on October 1, 2005. During the massage she asked ll if she orrow one of his vehicles to visit her family and boyfriend in . Jeff had told she could borrow one of his vehicles but later stated er a as Jef asked if she was wearing undergarments to which she replied her thong underwear. Once he tried toile her breasts she would pull away from him and uld stop. was asked if he ever used a vibrator on her. III" w vibrator but advised she never would allow him to on her. She described the vibrator as a large white vibrator with a huge head on the tip of the vibrator. She sill he kept the vibrator in a closet near the massage table. advised she had been doing the massage for approximately two years, which meant she would have started doing massages for Jeff at the age of sixteen. into t and IIIII stated she was contacted by informed her that Jeff had rented her a n Nissan SentgAAgd she should come by the house to it up. informed IIIII she would have the car for a month. stated Jeff knew her car was not working properly and had mi appointments in the past because of her car being inoperable. explained the car is currently parked next to Wild field. I as house. her took any one to the oiled she took , a friend of hers who has returned to to at college. I asked she ever allowed another female in the room. advised no one was bro into the room with her. At the conclusion of the interview, Det. and I went to the and located the Silver Nissan Sentra bearing Florida tag The vehicle is registered to Dollar rent a car out of the Palm Beach rhternational Airport. massage . I on October 3, 2005. had tact was made with , the victim's mother, at I explained to her that I was following up on this case and provided a complete update on the case. Investigation Continues. EFTA00231723 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 39 Incident Report Program: CMS301L Cas. No • 1-05-000368 NA (Continued) alli ****************************NARRA ************************** Reported By: 10/21/05 Entered By.: A. 10/21/05 On October 10 roximately 2:30 p.m., I made tel ne contact with . During a taped conversation, was told of an ongoing investigation which I felt she had information pertaining to Jeffrey Epstein. explained she met Eps en just sixteen years of age. She was approached by , a friend who also had previously gone to Epstein's house for massages. advis was working at the Wellington Mall when she was approached. , told her that she would have to provide sage to Epstein an e would have to perform this massage naked. thought about the offer and stated she could make $200.00 for minutes of work. She agreed to perform the image and set the appointment for her that same day. remembiiiiiii was a weekend as she only worked at the mall on th ekends. took her to house where she was introduced to Il l Epstein's assistant. WI took her upstairs to a master bedroom. ' explained that as she was walking up the stairs she observed several 1 ographs of naked women along the walls and tables of the house. further explained that she was brought into the bedroom where prepared the room by setting up the massage table and provided t 0 e oils for her to rub on Epstein. Epstein entered the room and introduced Wagelf. Epstein lay on the table and told her to get comfortable. IIII could aQ/remember if he was naked or if he entered the room with a towel. IIII stated she provided the massage wearing y her panties. She continued rubbing his legs, thighs and feet. advised he turned ove • back. tinued to rub his legs with the oil Epstein and began to masturbate. I ask if she knew what circumcised and un-circumcised meant. stated circumcised is n the penis has no foreskinand head of the penis is visible. said Epstein is circumcised. began to cry on the telephone and stated she had been to his house hundreds of times over a two-year period. &claimed to have made thousands of dollars during her visits. stated she could not remember how many times exactly she went to Epstein's home but said it was a lot. became more u ying hysterically and state and instructed to with Epstein's ass by Epstein. Epstein them himself as they things escalated further an urther. Epstein use• s-. -1 toys such as vibrators, er penises Additionally, state She claimed he Epstein) masturbated in an attempt to ma e er c imax. and wanted some time to regain her composure. take her time. After taking several minutes and masturbated . She urt_er stated that erous times. while he could not continue I explained to IIII to to regain her composure I EFTA00231724 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 40 Incident Report Program: CMS301L Casc No • 1-05-000368 (Continued) explained that I would travel to meet with her in person felt she had additional information to provide. met with Sgt. explained the importance to meet with n person. Sgt. agr ' ents for Det. and I to meet with in 2005, at 4:10 p. and I met with r f d, 1 Kingsley Road in wanted to ave present for support. I fined to her that I did not have oblem as long as she wanted present during the inte stated she wanted her present. I explained that as was present she was not allowed to comment or ',any questions during the interview. She was only there to comfort should the interview upset her. During a sworn taped statement, explained how everything be She said she was brought through the kitchen area where she met for their time. She was led to the master bedroom, Epstein s room. explained that as she was walking up the stairs she observed severs otographs of naked women along the walls and tables of the house. further explained that she was brought into the bedroom, where prepared the room by setting u e massage table and provided the oils for her to rub on Epstein. explained she remembered the steam room area, which contained two large showers. Epstein entered the room from the steam room area and introduced iiii •• elf. Epstein lay on the table and told her to get comfortable. removed her skirt and kept her shirt on. She could not remember if he was naked or if he entered the ith a towel. Epstein then instructed her to remove her shirt. removed her shirt and remembered she was not wearing a bra. stated she provided the massage wearing on er panties. She continued rubbing his legs, thighs and feet. advised he turned over onto continued to rub his legs with the oils. Epstein ' and began to masturbate. Epstein ejaculated awah meant the massage was over. At the conclusion of the ma e, IIII was 200.00. They walkeilligether 'rs where and Shady were waiting. stated received an unknown amount of money for taking her to Eps in. Epstein instructed to leave her cellular telephone number II that he could contact her when he is in town. explained that she continued to go to Epstein s house and became a regular at the house. She could not provide an exact number but claimed she had been their hundreds of times. She claimed sexual activities did not occur every time she was the i There were times she went to dinners and parties mdth Epstein. explained that things began to escalate more than t e e nters included bringing in his assistant, . explained Epstein had purchased her from her family in Yugoslavia. Epstein bragged he b ht her into the United States to be his Yugoslavian sex slave. advise aked in the bedroom, she entered and removed her clothing. eiiiied t steam room area already naked. He instructed to on EFTA00231725 Date: 7/25/06 Time: 8:47:53 Incident Report PALM BEACH POLICE DEPARTMENT Page: 41 Program: CMS301L Case 1-1,00368 refused to per an additional $11,0 nut • explained that Epstein watched them perform sexual acts. would masturbate while he Things continued to escalate by purchasing sex toys. had massagers, vibrators and strap on rubber penises Each time someth new was introduced additional m s were produced and offered for to allow the acts to happen. was adamant that she performs all these acts but there was a Epstein that no vaginal penetration would occu explained that Epstein's penis was deformed. penis was oval shaped. She claimed when Epstein's penis was erect, it was thick toward the bottom but was thin and small toward the head portion. She called it egg-shaped. continued that t xual encounters with , Epstein and upstairs, her became a rit where would arrive at the house aillialk herself and Epstein were wai• • would clothing and join them and she would begin by fined sex toys were bro ' ' pstein or uld begin . Epstein would on either person depending who was on top during the intercourse. Halls explanation revealed they were in a missionary position. IIII advised one day, (IIII was unable to state and eAsaL date when this incident occurred), she came to the house after IIII had informed her that Epstein had arrived. Sh rived at the house and went upstairs to the advised she immediately removed her clothiags.as were already naked in the bedroom. IIII explal encou ude e i a sexual that asked for a sheet of paper an massage table in the master room and where Epstein, and she ein and was removing her self from the massageremembered t . able stomach on the massage bed and stated Epstein began to (Continued) twin offered her She scre She told him that she did not want to . Epstein apologized for his . actions and subsequently paid her a thousand dollars for that visit. Additionally, shortly thereafter, Epstein gave a 2005 Doge Neon, blue in color for her personal use. advised thereggLe times that she eini ouse. IIII advised she was . advised she had difficulty walki o the car after leaving the house because she was so sore. advised that other EFTA00231726 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 42 Time: 8:47:53 Incident Report Program: CMS301L Cas No • 1-05-000368 than that one time, when Epstein there was no other penile intercourse. provided name girls that she knew oil ti i gone to Epstein's house. provided the name of and feels she l miiiiii going to the house to massage Epstein. According to , is still sucking his dick." asked if she had been recently contacted by anyone of the house, ived an email from IIII, from , which is her email account. The email was just a hello, how are you doing type of email. There had been other contact from the house. The interview was concluded and left the area. The tapes and drawing were submitted into evidence. Investigation continues... *********************** ***** NA NARRA Reported By: Entered By.: 1 11/01/05 e , ************************** A. 11/07/05 On October 12, 2005, Det. ed area and made telephone contact agreed to meet with us as we were in area. rovided directions to her apartment. Det. and I met with who stated, during a taped statement that nothing happened between her and Epstein. appeared nervous during the interview. I assure that I had spoken with other people who advised differently. stated she only went a couple of times and provided a massage to Epstein. e was brought to the Epglgia.house in March of 2005. broughtLgLLo work. IIIIII has no formal training in providing massages. IIIIII stated she provided a massage, fully d for $200.00. As I sensed hesitancy in her answers, Wild if she had been contacted by anyone from the house. stated she was interviewed already by an investigatiuml2.LmEpstein. He met with her on October 8, 2005, at a Roadhouse in IIIIIII. He identified himself as Paul Mi and iiiout the police investigation ft his telephone number for additional contact. provided no additional information, as it appeared her responses were almost scripted. We left the area and returned to Palm Beach Police Department. Based on the information acquired during the interviews, a search warrant was prepared for entry at the Epstein home. On October 18, :mos, I met with Judge Laura Johnson who reviewed the warrant request. She found there was sufficient probable cause and signed the warrant request. On October 20, 2005, at approximately 9:36 am, members of the Palm Beach Police Investigations Unit executed the search warrant at 358 El Bril Palm B Membeiiiii the Ings-Allaations Unit , Det. , Det. , Det. Det. , the crime scene unit and myself. IIIIII EFTA00231727 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 43 Incident Report Program: CMS301L Caber No • 1-05-000368 (Continued) As we entered onto the property, we encountered the house manager, Janusz Banasiak who was in the guest portion of the house. The guesthouse section had open doors and no f y was made. I ' Banasiak, Date of Birth , Fl DL , and informed him of the search warrant for the premises. The members of the Police Department entered the residence and announced we had a search warrant. A safety search was done and ited the home. I read the search warrant to Banasiak as Mgr videotaped the search warrant execution. Several interior decorators were located on the property. I spoke with Mark Zeff, of 515 W 20th Street in New York. Mr. Zeff stated he is the designer for Mr. Epstein's homes. He advised he was contacted in March of 2005 to do a complete overhaul on the house. He advised he was on the phone with Mr. Epstein when officers announced the search warrant. Mr. Epstein was then made aware of the search warrant. Mr. Zeff advised, his contact with Epstein is strictly business and he has nes., iiiiessed Epstein with any girls except for his assistants, or I then interviewed Daniel Estes, of 315 Mr. Estes stated he has worked for Zeff he personally worked on the New York Epstein. He has previously met with assistants in New York and in Florida. Epstein everywhere he goes. East 14th Street in New York. for seven years. He advised Palm agaalimjaame for Mr. and Epstein's Estes stated they travel with sewed of 35 Riverside Jersey City, New Jersey. stated she just arrived from Scotland and has worked with Zeff for only one month. She stated she has never met Epstein and has not seen him. The interview was then concluded. I then spoke with Douglas Schoettle of 243 Riverside Dr in New York City. Schoettle stated he has been Epstein's Architect for seven years. He further stated he deals with Epstein's assistants and speakiiiit ein on the phone. Schoettle stated he mainly speaks with , Epstein s main assistant, who travels with Epstein. Schoettle stated he only has contact. with Epstein when his services are needed. At approximately 10:30 am, I was informed that the videotaping was concluded. I entered the residence and located two covert (hidden) cameras. The first camera was a covert wall clock in the garage area. I traced the wire behind the clock and removed the RCA wire and unplugged the camera. The other covert camera was located within a desk clock beside Epstein's desk. I traced the wire behind the clock and unplugged the RCA wire. I could not locate another camera. I then began with the search of the residence for the specified evidence. My search consisted of the second floor. Det. and I began in the master bedroom area where several items were located. They were EFTA00231728 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 44 Program: CMS301L Cast No • 1-05-000368 (Continued) marked to be retrieved by the evidence custodian. In the master desk with Epstein's notepads marked Jeffrey Epstein we locate of transcript from Royal Palm Beach High School for Also in the room, was the dresser /armoire where we ocated a ottle of peach flavored Joy Jelly (Sexual Lubricant). Additionally, there were several photographs of young naked teenage girls within the closet, which was consistent with what the witnesses said. The massage table was also located within the master bedroom. Video tapes were located beside the television, which were also collected. An itemized list of the property and locations was prepared on the property receipts. At approximately 2:55 pm, the house was secured; the exit of the residence was videotaped. Upon our exit of the property, I encountered Atty. Guy Fronstein who advised he was representing Mr. Epstein. He provided a business card and provided his assistance with the investigation. Due to Hurricane Wilma, which struck South Florida causing massive power outages, the courthouse was closed due to the lack of power. was previously told that the Chief Judge had extended the filing deadlines due to the hurricane and the Courthouse being closed. On October 27, and 28, 2005 the courthouse was closed and I could not file the search warrant and inventory at the clerk's office. On October 31, 2005, I responded to the courthouse and filed the paperwork along with an order to seal, signed by Judge Johnson, to deny any release of any paperwork on this case. INV CONTINUES.. ****************************NARRA #13 ************************** Mr NA Reported By: , A. 10/20/05 Entered By.: A. 11/07/05 On October 20, 2005, at ximately 8:30 a.m., Thursday morning, I was advised by Captain that a search warrant would be executed and that I was to assemble the Crime Scene Investigative Team and stand by the south s' 'lding ready to go. I designated Evidence Specialist to handle the inventory return, the documentation of the property receipts and the collectio ing of the evidence at the scene. I further instructed CSI , ID # 8807, to accompany us and perform the role of photographing the scene and e may be taken into custody by the affiant, Detective , ID # 7915. My responsibility was to go through from the reading of the warrant to the final exit from the residence and perform a video recording of the reading of the warrant, the-iniEial walk through of the residence showing the current condition and then finally a walk through of the residence at the time of the police exit. We started out towards the residence, which was located at 358 El Brillo and arrived at approximately 9:33 a.m. The searc conducted, items were collected by Evidence Specialists EFTA00231729 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Cab._ No 1-05-000 photographed by CSI and then videotaped by myself. Page: 45 Program: CMS301L (Continued) Th was concluded at approximately 3:05 p.m. whereupon Detective and I were the last two officers in the house. Upon securing the residence as the gentleman who identified himself to Detective as the lawyer for the defendant and he was informed that the residence was secured and that copies of the inventory return had been left on the first floor table of the personal assistant's office. Detective and I returned to Police Headquarters and secured for the day. **************************** N A R R A ************************** NA Reported By: 11/07/05 Entered By.: 11/07/05 On October 20, 2005, I assisted Defective in the execution of a search warrant at 358 El Brillo Way, Palm Beac , Florida, 33480. Upon the announcement of the search warrant, immediate contact was made with three white males who came out of the house or surriiiiiig structures. Those males were identified as Janusz Banasiak, Estes, and Mark Zeff. As other members of the police department cleared the home, I kept watch over these three males. e house was cleared, those males were turned over to Detective Detective and I were assigned to assist in the search of the main house, the cabana and the servant's quarters. We started in the garage. All areas of the garage were searched to include four vehicles. These vehicles were three black Mercedes Benz cars registered to Jeffrey Epstein. The fourth vehicle was a Harley Davidson motorcycle, green in color, registered to Jeffrey Epstein. Nothing was recovered from the garage. A towel closet and pantry located off the kitchen were searched and yielded negative results. The kitchen was searched and taken into evidence was a phone message book that was located near a house phone. North of the kitchen was an office room which contained a computer. The room had a closet that contained a locked gun locker. Tiro , combination was entered by Banasiak in the presence of Sgt. and the safe was opened. items were taken from the room. See the compited- property receipt for a detailed list. A green bathroom located on the first floor was searched and nothing was taken. A closet located just west of the green bathroom was searched. Two massage tables were located in the closet along with a photo of a nude EFTA00231730 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 46 Program: CMS301L Case No • 1-05-000368 (Continued) female from the waist up. See the property receipt for details. I searched two bedrooms and their adjoining bathrooms, which were located on the second floor on the East side of the house. In the Northeast bedroom closet I found adult sex toys called Twin Torpedoes. Soap made in the shape of a penis and vagina were also found in these upstair bedrooms. See the property receipt for details. I searched the pool cabana located on the South side of the pool. Photos were taken from the wall. See the property receipt for details. I assisted in the search of Banasiak's living quarters. Numerous CD s along with a message book was seized. See the property receipt for details. **************************** N A R R A ************************** illit NA Reported By: 11/08/05 Entered By.: 11/08/05 On November 1, 2005, I was contacted by Atty. Gus Fronstin, who advised he was willing to assist with the investigation. Atty. Fronstin advised he would try to have his client, Jeffrey Epstein available to be interviewed. I explained I would be interested in conducting an interview with his client as well as other employees that are employed within the house. Atty. Fronstin advised he would return my call once he received confirmation on the interviews. On November residence. retur from with provide an Palm Beach allowed to 6, 2005, I attempted contact with I left a business card for her to lice department, I had re . I returned her call at return my at her call. Upon ephone call and spoke She made arrangements to respond to the station to interview. At approximately 3:30 pm, she arrived at the Police Station with her boyfrien r boyfriend was sit in the lobby area while Ms. was interviewed. I took Ms to the Detective Bureau Interview room. I closed the door for privacy and explained to her that I appreciated her coming to the police station for the interview. During the sworn taped statement, she advised she was at Jeffrey Epstein s house o imately two months ago, she was approached by a girl, • who was dating her roommate, to make some quick money. advised she was in need to make some quick cash to make the r at She agreed to go to the house---She-had been told by t ke massage would have to be done in her underwear. She advised drove with her and brought her into the house y walked into the kitchen areaand took the stairs upstairs. further stated she was brought into a master bedroom area. She advised she recalled seeing portraits of naked women throughout the room. A massage table was already out near the sauna/shower area in the master bedroom. Epstein entered the room wearing only a towel and EFTA00231731 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 47 Incident Report Program: CMS301L Cam No • 1-05-000368 (Conti introduced himself as Jeff. advised she recalled she and removed their clothing down to their panties, Epstein lay on his stoma and they provided a massage on his legs and feet area. I asked if she had any formal massage training and she replied no. advised she was toples the panties she wore were the boy shorts lace panties. She and continued tiiiiissage until the last ten iiiiiis of the massage, Epstein, told room so that could finish the massage. to leave the got dressed and Epstein turned over onto his back. Epstein then removed the towel, which had be and his waist. Epsteiiiiiii there naked ted that rub his chest area. stated rubbed his chest. stated and he produced a large white vibrator with a large • awe is master bathroo advised he never with the vibrator. He continued as he continued to masturbate. stated s e was very uncomfortable during the incident but knew it was almost over. Epstein climaxed and started to remove himself from the table. He wiped himse h the towel he had on previo and went into the shower area. got dressed and met with in the kitchen area. in came into the kitc d provided $200.00 for b ' ' g and paid $200.00 to for providin massage. was told to leave h ephone number with , his assistant for future contact provided her cellular to ephone number for future contact. was asked if she was recently contacted about this investigation by anyone from the Epstein organization. She repli e was called but it was for work. She stated e was called by for her to to work stated is the term used by to to provide the massage in un erwear. advised she declined, as she was not comfortable in providing that type of work. The interview was concluded and the videotape was placed into evidence. for Epstein. Investigation Continues.. ****************************NARRA # 16 ************************** ill NA Reported By: 11/10/05 Entered By.: On November 7, 2005, I made telephone contact with advised she would be able to meet with me at her home. Det. aveld to her home in Royal Palm Be . During a swor Jeffrey Epstein through who wished to work him but declined. state explained that work means give massages. She was asked y formal training in p ng massages to which she said no. said she accompanied and other females 11/10/05 ade contadt- with stated she met would approach females she was asked to work for EFTA00231732 Date: 7/25/06 Time: 8:47:53 Incident Report PALM BEACH POLICE DEPARTMENT Page: 48 Program: CMS301L Cab.: No • 1-05-000368 inued) who were taken to Epstein s house to provide massages. further stated she had been to t se app es in semi accompanied with , the 14-year-old victim, and Each time the girls were taken over, they were previously told they would have to provide a massage, possibly naked. It was also told that should Epstein require them to do anything extra were not table just to tell him and he would stop. stated received $200.00 for each girl she brought over to massage Jeffrey Epstein. When I asked which girl appeared to be the youngest, she replied, the victim, as she stat as fifteen years old at the most; she looked really young. further stated ea she went to the house, she sat in the kitchen and waited with r until the massage was over. She further stated that the cook would make lunch or a snack for them as they waited. I asked here was anything that caught her attention within the home. stated there were a lot of naked girls in photographs throughout the house. The interview was concluded and the tape was turned into evidence. Investigation Continues.. ****************************NARRA NA Reported By: Entered By.: Det. and I attempted contact with al Palm Beachill' illeft my business card at her front oor. Ms returned my call and arranged a meeting with me at the Palm Beach epartment for November 8, 2005. At approximately 2:00pm, arrived at the Palm Beach Police Department. She was brought nto the interview room and the door was closed for privacy. She was told that I appreciated her coming to the police station for questioning regarding an on going investigation. She was told that I was investigating a crime involving Jeffrey Epstein and knew, based on the investigation, that she had ers with him in the past. During a sworn taped statement, stated she had met Epstein t rs ago. She was irst introduced to Epstein by approached her about working for Epstein and pray assage to him for $200.00. The arrangements were made coul rkeliiiiihe day the arrangements were made, took A. 11/10/05 11/10/05 also attended Royal Palm Beach High School and was familiar with Epstein. ITIR do h a with an assistant and another recalled she was brought there and en through the back assistant . brought her upstairs as she obse several photographs J imralred females throughout the house. stated came in the room, wearing only a towel, and laid on the table. stated he picked out the oils he wanted her and requested she remove her clothing to provide the massage. stated that on the first massage she provided she did not remove her EFTA00231733 Date: 7/25/06 Time: 8:47:53 Incident Report PALM BEACH POLICE DEPARTMENT Page: 49 Program: CMS301L Ca:. No 00368 (Continued) clothing. stated she had returned sev mes after that. Each time she returned more things happened. stated that the same thing would happen. Epstein would walk into the master bedroom/bathroom area wea ' ly a towel. He would masturbate as she provided a massage. stated she was unsure if he climaxed as he masturbated under the towel. Additionally she never looked blow his waist. She claimed that Epstein would convince her to remove her clothes. She eventually removed her clothes and stayed in her thong panties. On occasion, Epstein would use a massag tor, which she described as white in color with a large . Every time she provided a massage he would masturbat added she has no formal training in providing a massage. stated she brought two females during he 'sits ges. 1111111 stated she brought a girl and from Royal Palm Beach High School. st he received $200.00 for each girl she brought. Additionally, was given $200.00 for taking her in the very beginning. The interview was concluded and the tape was placed into evidence. Investigation continues... **************************** N A R R A ************************** NA Reported By: 11/13/05 Entered By.: 11/14/05 8, 2005, I made tel e contact with , W/F, ilailif at her residence. responded to the police station for an interview reference an ongoing investigation. At approximately 2:30 pm, she arrived at the Palm Beach Police Station and was brought into the interview room for the interview. The door was closed for privacy and she was told that I appreci her cooperation in this case. During a sworn taped statement, stated she had met Jeffrey Epstein approxi i iiii yeitigo. She was approached by a subject known to her as . had aalgamher if she wanted to make money providing massages to Epstein. IIIII had heard that several girls from Royal Palm Beach High School were doiiiiihisiiii making money. She agreed and was taken to the house by had introduced her to and Epstein and brought her upstairs to a master bedroom and Master bathroom whiiiia massage table was prepared and the proper wer en out. left the room and waited downstairs for . stated Epstein entered the room wearing a and she provided a massage wearing only her thong panties. advised Epstein had masturbated every time she provided a massage. She stated Epstein continued to masturbate until he climaxed; once that occurred the massage was over. She felt the whole situation was weird but she ad d she was paid $200.00 for p&pagiging the massage. She also stated received $200.00 for bring IIIII to Epstein. stated she had gone a total of 15 times to his residence to provide a massage and things had escalated from just providing a EFTA00231734 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Incident Report Page: 50 Program: CMS301L Ca- No • 1-05-000368 massage. Epstein began touching (Continued) ' e masturbated. Epstein also with his hands as she provide the massage. stated on one occasion, he offered extra monies to have vaginal course. She sta Epstein removed massage table. if she had any forma did not. table. hed the point and climaxed receive• 350.00 or her massage training in providing massages, er and began of climax. onto the ...irked her stated she d conti to state on one othe , casion, Epstein introduced his tant, into the massage. was b ' h ' had them as they provided a massage to Epstein. Epstein, watched and masturbated as this occurred. On other occasions, Epstein introduced ' ' sage during the massage. Epstein on 's vagina as she provided the massage. ed the last time she spoke with anyone with during the weekend of October 2 or 3, she had brought ple t and Epstein house. (unknown last had been previous and had and the • names o noted, y identified as been previously interviewed. The interview was concluded videotape was placed into evidence via the locker system. On November 9, 2005, Sgt and I traveled to 6791 Fairway Lakes Drive in Boynton Beach, Florida in hopes to interview Juan Alessi, the former houseman of Epstein's home. As no one was home, a business card was left for him to return my call. We then traveled to 11349 SW 86th Lane in Miami in hopes to interview Alfredo Rodriguez, a former house man of Epstein. We did not locate them at home. I left a business card for him to return my call. We requeste to spea with traveled to • Dealliii Students, was re interviewed, as she still was i session o t ',tad car that Epstein had acquired for her. stated that , Epstein's assistant, had called her on her cellular telephone and informed her that rental was extended for her. IIIII stated she had paid an additional $625.00 for her to keep the rental an extra month. ■ was asked if she had any additiiiiii contact with either Epstein or anyone 'tom his organization. stated he did- not, other than the telephone informing her that she could keep the car for an extra month. did not provide any additional information. On November 10, 2005, at approximately 9:47 am, Alfredo Rodriguez had telephoned reference my business card found on his door. Rodriguez stated he had worked with Epstein for approximately six months after at the was 2005. stated She provided the hould EFTA00231735 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 51 Incident Report Program: CMS301L Ca-. No • 1-05-000368 (Continued) the previous houseman left. Rodriguez stated that it was his responsibility to keep the identity of the masseuses private. Mr. Epstein had a massage in the morning and one in the afternoon. Mr. Rodriguez stated he would rather speak about this in private. He advised he would come to the police station to speak with me. Rodriguez stated he would return my call on Monday, November 14, 2005. I then made telephone contact with Juan Alessi. He advised he found my card on his door and wanted to know what I needed to speak with him about. I explained to Alessi that I was conducting an investigation on his former employer, Mr. Epstein. Alessi stated he would return my call shortly as he was in the middle of a project at his hom received a telephone call from Attorney Donald Morrell from Mr. Morrell stated he represented Mr. Alessi and did not want me speaking with his client. I then made telephone contact with the State Attorney s Office and confirmed that subpoenas would be issued to the former employees to assist in the investigation. I then made telephone contact with Attorney Guy Fronstin, attorney for Mr. Epstein. I explained to Mr. Fronstin that I would like to speak with Mr. Epstein. He stated Mr. Epstein is not in residence in Florida at this time and would check with him to ascertain if he could be here by Wednesday November 16, 2005 for an interview. Mr. Fronstin stated he would return my call should Mr. Epstein decide to come in to the police station for an interview. Investigation continues. all , **************************** N A R R A ************************** NA Reported By: 11/15/05 Entered By.: 11/16/05 and I tra and spoke with She was told of the ongoing investigation involving Epstein. advised she had gone to the house on several occasions. During a sworn taped statement, she advised she startiiiiiing to the house approxi one yea and was brought by (Unknown last name). stated ought her into the h iand she was introduced to a girl named . Once she brought her upstairs into a master bedroom bathroom. stated she met Jeffrey in the bathroom. He lay on the table and picked the massage oils. She provided the massage, as he lay naked on the massage bed. She stated she rubbed his calves and back area. Upon the end of the massage, Epstein removed himself from the massage table and paid her $300.00 for the riiassa—g . sta six times. notified by , Epstei ' *stant, that Epstein was in town and would like her to work. stated she returned to the house and was again led upstairs by . She provided the massage, clothed. ad only been at the house approximately five or said each time she went to the house she was EFTA00231736 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Cat_ . : 1-05-000368 Page: 52 Program: CMS301L advised it wasn't really weird until later on. asked if she ever removed her clothing to provide a massage. stated it w ntil the third time she went she removed her clothing. stated she was notified by that Epstein wanted her time to work. She arrived at the house and was led upstairs by . She started pro " he massage when Epstein asked her to remove her clothing. re shirt She stayed in her thong panties and in turned over onto his back and she stated s providing the massage. on his breathing. She did not fact that he was masturbating. relaxed he got up and told her for her services. he was masturbating himself as she stated she believed he climaxed based wane rn view either the climax or the stated once the breathing to get dressed. She was paid $300.00 stated r last time she went to p was notified by rovide a , she to come to the house and work. stated she was now dating her current boyfriend and did not feel comfortable going. She recalled it was approximately January 2005. She said she went, already thinking that this would be the last time. She went upstairs and went into the master bathroom. She met with Epstein, who was ' only a towel as he entered the room to lie on the table. stated Epstein caught her looking at the cloc several occasions. Epstein asked her if she was in a stated her boyfriend was in the car waiting for her. further stated that Epstein got upset, as she wasn't enjoying the massage. She told him that she didn't want to continue and she would not be back. Epstein told her to leave as she was ruining his massage. I asked her if she had any contact with Epstein's organization, she stated she received $200.00 from Weste in Royal Palm Beach and Okeechobee Blvd as a Christmas gift. ised she had no formal training in provide any massages. also stated she was sixteen years old when she first went to Epstein's house. At ' tely 4:22 pm, I made telephone contact with at . She agreed to meet with me at a public place. suggested she come to the police station for an interview. did not want to meet at the police station. I recommended we meet at the Palm Beach Gardens Mall in the food court area. She agreed and an appointment was made for November 15, 2005 at 5:00 pm at the food court. Investigations Continue. MI **************** ************NARRA ************************ ** NA Reported By: 11/16/05 Entered By.: 11/17/05 On 10/20/2005, I assisted executing a search warrant at 358 El Brillo Way in the Town of Palm Beac ch County Florida under the direction of affiant Detective . EFTA00231737 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Cas- No • 1-05-000368 Page: 53 Program: CMS301L (Continued) Detective and I searched the pantry room that is west next to the kitchen. T is room had all white cabinets with a dark grey and black counter top. We did not find anything in this room. We searched the yellow and blue room that is west next to the pantry room. This room had a very large statue of man with a bow. Taken into evidence from this room were nine photographs in frames of various women. We searched the main entrance foyer that is to the north of the yellow and blue room. This room contained two bamboo chairs and ottomans with cushions. It also contained a round table with numerous books. We searched another blue room that is west of the foyer. This room had a stereo system and book shelves that were from the floor to the ceiling. Taken into evidence from this room were eight photographs in frames of various women and/or Epstein, the owner of the residence. We searched the room to the west of the blue room that has sliding glass doors that lead out to the pool. In this room in a dresser were two DVD's and two VCR tapes. These items were taken into evidence. searched a 2004 black Chevy Suburban bearing Florida tag , registered to Jeffrey Epstein DOB 01/20/53, which was located on the east side of the driveway facing south. I found a Thrifty rental agreement between the passenge froe from The phone number on the rental agreement was . The rented was a white 2005 Chrysler Sebring bearing F orida tag The vehicle was rented on 9/25/05 at 17:58 hours and was returne on 9/26/ t 16:52 hours. T ur numbers of the credit card used are . Detective found a piece of paper in the middle console that used the cash in here to fill up the tank and was signed by ched the 2005 black Cadillac Escalade ESV bearing Florida tag , registered to Jeffrey Epstein dob 01/20/53, which was located on the west side of the driveway facing south. I did not find anything in this vehicle. Ali of the items that were taken into evidence were photographed in the place they were located and then turned over to crime scene. **% ************************NARRA ************************** NA Reported By: 11/17/05 Entered By.: 11/17/05 EFTA00231738 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Incident Report Page: 54 Program: CMS301L Cas_ No • 1-05-000368 iiiiivember 15, 2005, Det. and I in Royal Palm Beach. We met with , a seventeen-year old juvenile who was ' chool this day due to a cold from which she was suffering. was told that I needed to speak with her in reference to an ongoing investigation involving a subject she would know as Jeffrey Epstein. Prior to speaking with her, I explained that because of the fact that she is a minor, I needed to speak with her pa o speaking with her. She telephoned her father, Mr. , on his cell phone and explained to him and I were there to speak with her. I spoke with Mr. on the telephone and informed him I needed to s ' h his daughter in reference to an ongoing investigation. Mr. advised he had no problem with us speaking with his daughter. During a sworn taped statement, stated she met Jeffrey Epstein over a She was sixteen years of age and was approached by who informed her t he could make monies providing a massage to Epstein for $200.00. had ' rmed her that she would have to provide this massage top ess. de the arrange ' h Epstei house. stated his assistants and took to the nd she entered through a glass door that led into a kitchen. took her upstairs, to a master bedroom and master bathroom. She reca led the bathroom had a large pink couch, sauna and matchi r. Eggggin entered into the room wearing only a towel. and IIIII removed their clothing remaining only in thong underwear. She further stated that Epstein lay on his chest on table in selected which oils to use for the massage. Both and provided the massage on his legs, back and feet. Forty minutiiiiito the massage, Epstein turned over ontoand requested stairs in the kitchen areiliii Ep th sage. As got dressed, (Continued) masturbating imse f as stated he continued masturbating until he climaxed on the towe e was wearing. When askgg if he had removed the towel she stated he turned the towel around II that the opening would allow him to expose After he cleaned himself off with the towel, he instructed sage was done and to get dressed and met with him downstairs. got dressed and met with Epstein in the kitc i . She was paid 200.00 dollars for providing the massage. stated she was aware that also received monies for the same thing. ecoilme she went to the house she was again approached by . ask ' e wanted to return to the house to provide er massage; agreed and th ements wagggade by for her to return to the house. stated IIIII drove her to the house and knocked on the same glass door that leads to the kitchen area. Tiiiiiere allowed entry into the house by one of the staff members. led her upstairs to the master bedroom and EFTA00231739 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 55 Time: 8:47:53 Incident Report Program: CMS301L Ca. No • 1-05-000368 (Continued) master bathroom area. left this time to do the alone. Epstein entered t e room again wearing only a towel. began removing her clothing as she did the last time she was at the house. Epstein ' ted her to get naked. He lay on the table on his stomach as began massaging his legs and back. As finished ' tein's back and legs, Epstein then turned over onto his back. ted to rub his chest and he began masturbating himself. As rubbed his chest, Epstein leaned ger vibrator. He turned it on and began self at the same time. as this was occurring. She desc massager as large, grey with a large head. Epstein for approximately WImassager vibrator. He then removed the and concentrated on masturbating himself. stated he climaxe he towel again and informe that the massage was done. got dressed and met with who was in the She received $200.00 for the massage. , • ' said she neve ed to the house and had no desire to return to the house. was asked if she received any forma e training. She advised she had 1 training. il was asked if Epstein knew her real age. 'il stated he knew as he asked her questions about herself and high school. He was aware she attended and is still attending Royal Palm Beach High School. The interview was concluded. I suggested inform her parents of what occurred at the Epstein house. tated she would tell her father as he was unaware this had occurred. I left my business card for any questions they may have. We left the area and returned to the police station. The tape was placed into evidence. kitchen area. Investigation Continues. ****************************NARRA ************************** lik NA Reported By: 11/17/05 Entered By.: ■ 11/17/05 On November 15, 2005, Officer and I reiiiiieiliiiihe Palm Beach Gardens Mall food court s to meet with . At approxim 5:10 p.m., arrived and met with us at the food court. Ili provided a sworn taped statement in which she stated she had been at the Epstein house over fifty times. She going to Epstein's house when she turned eighteen years was asked if she knew of the on-going investigation. stated she was aware there was an investigation as she had been told by other girls that were interviewed. Additionally, she has had several telephone conversations with Epstein's assistants as to what had been going on during the investigation. I asked how she was introduced to Epstein. stated she did not want to disclose who brought her to the house but she would EFTA00231740 NA mall were Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 56 Time: 8:47:53 Incident Report Program: CMS301L Cat No • 1-05-000368 (Continued) respond y other questions. When I asked her what happened at the house, stated everything happened. It all began with the massages. Each time she went more things happened. She would massage Epstein and he would mastur • She stated things escalated from there. She on Epstein and he lso use a massager vibrator as she massaged him. He introduced his assistap to have vaginal intercourse with 'I'll.. She sta would utilize a strap-on (synthetic penis) to w' to masturbate herself as Epstein and . All this was done at Epstein's direction. ovide ex stated as she massaged him. When I asked her if there had been any vaginal intercourse ' ' h ated she did not have with him. She did admit , his assistant. stated not every time she went involved sexual favors. Sometimes she would just talk with him and get paid. I asked much she was paid each time she went to Epstein s residence. lir stated she got paid $300.00 every time she went to the She was told to bring other girls to him to provide massages. declined stating that she does what she doe did not want to introduce anyone else to do what she does. stated she had never received any formal training in providing massages. I showed a photo line up in which was placed in position si d the six photographs and immediately identified as the person with whom she had Additionally, it was the same person she watche with Epstein. She signed the photo line-up under s photo as the person she identified. We then left the and returned to the police station. The photo line up and tape placed in to evidence. Investigation Continues... illit ****************************NARRA ************************** 11/29/05 Entered By.: A. 12/01/05 On November 17, 2005, I received a phone message from Atty. Guy Fronstin who advised to call his cellular phone reference his client Jeffrey bpstein. I telephoned his cell phone and lett a message for him to return my call. I did not receive a call back on Thursday, November 17, 2005. On Friday, November 18 2005, I retrieved another voice mail from my work phone from Mr. Fronstin advising he would not produce his client Jeffrey Epstein for any statement. Fronstin stated he had spoken with ASA Lana Belohlavek and expressed Mr. Epstein has a passion for massages. I called ASA Lana Belohlavek and confirmed that Reported By: EFTA00231741 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 57 Time: 8:47:53 Incident Report Program: CMS301L Caste No • 1-05-000368 (Continued) Fronstin had telephoned her reference this case. Although nothing was discussed, Mr. Fronstin did advise her that Epstein is very passionate about massages. I also spoke with ASA Daliah Weiss reference the previous employees, Juan and Maria Alessi. She advised that they had been served through a subpoena process server. They were both scheduled to appear on Monday November 21, 2005 at 12:00 p.m. On November 21, 2005, I met with ASA Weiss, Atty. Donnie Murrell and Juan and Maria Alessi at the State Attorney Office. ASA Weiss had requested a court reporter to be present to take the statement of the Alessi s. I spoke with Maria Alessi, in the presence of her attorney, Donnie Murrell. She advised she had worked for Epstein for eight years, from the period of 1994 through 2002. She advised she had never had any direct conversations with him. She stated it was her husband who spoke directly with Epstein. Her work consisted of doing house cleaning, shopping and other preparations when Epstein would arrive in town. Alessi stated the preparations consisted of preparing the house and bathrooms for his arrival. She advised she did view several masseuses that arrived at the house. She advised that two or three girls would come during a day and provide the massages. The girls that arrived looked young in age. Mrs. Alessi did not know any of the girls personally and were always different. She was told that when Epstein was in residence he did not want to encounter the Alessis during his stay in Palm Beach. I then spoke with Mr. Alessi in the presence of his attorney, Donnie Murrell. Mr. Alessi stated that he was employed for eleven years with Mr. Epstein. He originally was hired as a part time employee and then moved up into a full time position. His duties included everything. Alessi stated he was the house manager, driver and house maintenance person. It was his responsibility to prepare the house for Epstein s arrival. When asked about cooks or assistants, Alessi stated they traveled with Epstein on his private plane. He remembered dealing with his girlfriend, Ms. Maxwell originally and then dealt with Epstein directly. I asked Mr. Alessi about massages that occurred within the home. Mr. Alessi stated Mr. Epstein had up to three massages a day. Each masseuse that visited the house was different. Alessi stated that towards the end of his employment, the masseuses were younger and younger. When asked how young, Mr. Alessi stated they appeared to be sixteen or seventeen years of age at the most. The massages would occur in Epstein's bedroom or bathroom. There were times he recalled that he would set up the massage tables either in Epstein s bedroom or in his bathroom. I asked if there were things going on other than a massage. Alessi stated that there were times towards the end of his employment that he would have to wash off a massager/vibrator and a long rubber penis, which were in the sink after the massage. Additionally, he stated the bed would almost always have to be made after the massage. Alessi was never privy to what went on during the EFTA00231742 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 58 Time: 8:47:53 Incident Report Program: CMS301L Cat, No • 1-05-000368 (Continued) massages. He was asked if he remembered any names of the girls that massaged Epstein. He tried to remember and was unable to provide any exact names of any girls. Alessi was asked about any contact with anyone from the Epstein organization. Alessi said he did speak with Mr. Epstein shortly after my initial contact with him to find out what was going on. Alessi also stated that approximately on November 11, 2005, he was contacted by a private investigator from the Law Office of Roy Black. The investigator had called him to meet with him to ascertain what he was going to tell the police. Alessi stated they met at the Carrabba s Restaurant in Boynton Beach and discussed the same questions I was asking him. I informed Mr. Alessi and Mr. Morrell that as this is an ongoing investigation and anything we discuss should be confidential. They both acknowledged the fact that the information would be kept confidential. It should be noted that a court reporter was present during the interviews and would be providing a copy of the statements to me when they become available. On November 21, 2005, I received a voice mail from Mr. Fronstin who advised he would not be making Mr. Epstein available for any statements. He did have some words that he wanted to relay on behalf of Mr. Epstein. I telephoned his office and left a message for him to return my call. On November 29, 2005, I received a call back from Mr. Fronstin who left a voice mail after hours on November 28, 2005, advising he would return my call during normal business hours to speak with me reference the case on November 29, 2005. NA illik ****************************NARRA ************************** Reported By: 11/29/05 Entered By.: 12/01/05 On November 29, 2005, at approximately 2:30 p.m. I received a telephone call on the department issued cell phone. Mr. Fronstin stated he was calling to relay information that Mr. Epstein wished he could relay. Mr. Fronstin stated that he would not allow Mr. Epstein to speak with me at this time. He further stated that Mr. Epstein is very passionate about massages. He continued that Mr. Epstein had allegedly donated over $100,000 to the Ballet of Florida for massages. The massages are therapeutic and spiritually sound for him that is why he has had many massages. Mr. Fronstin stated he appreciated the way the investigation has not been leaked out into the media. I explained- to Mr. Fronstin that it is as important to protect the innocent if the allegations are not substantiated. Mr. Fronstin was told of the allegations that the private investigators assigned to the case have been portraying themselves as police officers. Additionally, I explained that my cell phone had been called by the private investigators. Mr. Fronstin advised he was not aware of that and advised they were under the direction of Attorney Roy Black in EFTA00231743 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 59 Time: 8:47:53 Incident Report Program: CMS301L Cate No • 1-05-000368 (Continued) Miami. Mr Fronstin further stated Epstein had originally called Mr. Dershorwitz in Boston, who recommended Roy Black in Miami, who asked Mr. Fronstin to assist. I informed him that if and when any charges would be presented I would notify him. The call was then terminated. investigation continues. ****************************NARRA ft 25 ************************** NA Reported By: 12/15/05 Entered By.: 12/16/05 A review of the telephone message books, which were obtained during the search warrant, was conducted in which various messages from different dates were made to Jeffrey Epstein. The telephone message books have a duplicate copy (Carbon Copy) which, once a phone message is written into the book, the top copy is then torn on the perforated edge and the carbon copy is left in the book. First names of girls, dates and telephone numbers were on the copy of the messages. I recognized various numbers and names of girls that had already been interviewed. The body of the messages was time of the day that they called for confirmation of "work." Other names and telephone numbers were located in which the body of the messages were, "I have gir r him" or "I have 2 girls for him." These messages were taken by for Jeffrey Epstein. Based on the context of the body of the messages, I requested subpoenas for subscriber information on the telephone numbers and the time frame involved. Copies of the messages were made for evidentiary purposes. I obtained Royal Palm Beach High School yearbooks for 2005, 2004 and g 2O03. I first reviewed the 2005 yearbook and loc irls I had spoken with. Additionally, I locateda . Based on the corrected name spelling, I was able to l er to her residence in . On December 8, 2005, Det responded to in Loxahatchee. I located at her home. She advised she is attending Royal Palm Beach High and is participating in the early release program she can maintain her part time job. As she is still a minor, I left my business card to have her mother return my call to request an interview with her daughter. We then left the area. I also had previo ed the telephone number for " " and telephone numbe A subpoena had been issued for the elephone numbe • ered to very of revealed ughter of and currently residing at in West Palm Beach. Det. • and I attempted contact with with negative results. I left my business card on esting she return my call. We then responded to in West Palm Beach. I also attempted contact with Mr. with negative results. I left my business card for him to return my call. EFTA00231744 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 60 Incident Report Program: CMS301L Cab • No • 1-05-000368 (Continued) b 05, I received a telephone call from mother, who wile aware of the on going investigation in Palm Beach. advised she was told of everything that occurred at Epstein's house involving Epstein and his staff. She advised she would allow me to question her daug out what occurred and ooperate with the investigation. provided me with cellular telephone number to schedule an appointment for an official interview. I telephoned her cellular telephone and made a tentative appointment for Monday, December 12, 2005. received a telephone call from , father of , who stated he found the business car on his door. I explaiiiii that I was conducting an investigation and needed to speak with as she maiiiiii information that could assist in the investigation. Mr. stated that his daughter no longer resides with him and has her own trailer in another trailer park. He advised he would tell her to call me. On December 12, 2005, d c l with schedules, arrangements were made to meet with o day, December 13, 2005 at 5:00 pm. On December , • and I traveled to Loxahatchee et with During a sworn taped statement, stated t at w en she was sixteen years o e was taken to Epstein's house to provide a massage e stated it was before Christmas last year when roached her and asked if she needed to make money for Christ stated she did and agreed to de a massage for money. made arrangement ake IIIIII to the house and drove to the house to "work." stated she could not remember the street name but would be able to drive to the street. They drove to the last house on the street and pulled in the last house on left side. They walked up the driveway and entered through a side gate which led to a kitchen door y knocked on the door and were encountered by an employee who described as a "Spanish looking lady." They informed her that they were expectedly were then encountered by a white female with long blond hair. was unable to remember the name of the white female with blond hair but knew she was Epstein's assistant. She was led upstairs by the white female who explained that there would be lotions out already and Epstein would choose the lotion he wanted her to use. She was led through a spiral staircase which led to a master bedroom throom. The massage table was already set up in the bathroom. described the bathroom as a large spacious bathroom h a steam room and shower beside it with a sink to the right. was introduced to Jeff who was on the phone when she entered. Jeff was wearing a white towel and lay his stomach so that may massage his feet and calves. started the massage with the massage oil Jeff chose and ru e his feet and calves. yaLL got off the phone and requested she massage his back as well. IIIIII began rubbing his back and got to the small of his back. During the rubbing of his back Jeff asked her to get comfortable. He EFTA00231745 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 61 Incident Report Program: CMS301L continued from the front. snappin having Epstein then re Ca,. No • 1-05-000368 requested she remove her pa and pulled her pants off. (Continued) d shirt. Till removed her shirt stayed in r bra and thong panties. As she finished the small of the back, Jeff then turned onto his she rub his chest and pinch his nipples. As she , Jeff asked her questions about herself. remembers tel ing him she attended Royal Palm Beach Wi ll Schoo . Jeff asked her if she was sexually active. Before answer, he also asked what sexual positions does she enjoy. stated idn't like talking about those things. She Epstein reached up and unsnapped her bra e used had a front and asked her if she like said "no, I don't like that." towel and lay on the bed naked exposing his ouching his penis and masturbated as he explained Jeff then touched her vagina area by rubbing vagina with his fingers on the outside of her thong panties. tensed up and stated Jeff was aware that she was uncomfortable. stated that Jeff told her further explained Jeff commented he , "Relax, I'm not going inside." She to her how beautiful and sexy she g panties to one side and and apologized • Dur .is time he ke stated he as e was masturbating. said he climaxed onto t e towe a a• been previously wearing and got up from the table. Jeff told her there was $200.00 dollars for her on the dresser within the master bathroom. Jeff also her that there was an additional $100.00 that was to be given to for bringing her there to massage him. Jeff told her to leave her telephone number with his assistant as he wanted to see her again. Jeff stated his assistant would contact her to work again soon. Wild her if she ever rece stated she did not. any formal massage training to which stated it was the only time she ever went to work for Jeff and knew happened to her was wrong. "stated she no longer speaks to because she was upset that took her there. She further stated that she had never been contacted for any additional work. The interview was terminated and we left the area. Investigation Continues... **, ************************NAREA E ************************** NA Reported By: 12/18/05 Entered By.: 12/19/05 EFTA00231746 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 62 Time: 8:47:53 Incident Report Program: CMS301L Ca • No • 1-05-000368 (Continued) On 102005 at approx 0930hrs I assisted with the execution of a search warrant at 358 El Brillo Ave, Palm Beach. Initially I was assigned to enter the residence and conduct a sweep e premises for safety purposes. I then accompanied CSEU tech while she photographed the exterior of the house. Once this was ciiiiiie I was assigned to search certain areas of the house with Det. as part of the search warrant. We began in the garage, searching three Mercedes Benz vehicles, a Harley Davidson motorcycle and adjacent closets in the garage. Nothing of evidentiary value was located. We then searched two closets off the kitchen area on the east side. These can best be described as pantry or storage closets. Nothing of evidentiary value was obtained. A small office with adjoining bath was then searched. In the bath area I located a phone message book with recent messages. This item was seized as evidence. Please note this bath and shower area are not used as designed but are storage areas containing a variety of items to include a gun safe in the shower and assorted household items. We then searched a bath area and closet at the base of the main stairs in the foyer. Inside the closet two massage tables were located as well as partial nude female photographs. These items were later seized as evidence. Nothing of evidentiary value was noted in the bathroom. We then searched two bedrooms upstairs on the east side of the residence. Located in the bath room of the south bedroom was penis shaped soap. Located in the bedroom of the northern bedroom was penis and vagina shaped soap as well as an adult sex toy. These items were seized as evidence. We then searched the pool cabana located in the south west corner of the property. Several photographs of nude females were seized as evidence. I was then assigned to stand by with a person I believe was Douglas Schoettle. Mr. Schoettle was in the residence at the beginning of the search warrant. He was present during the warrant service and subsequent search. I stood by with him until the search was completed and I departed the residence. I had no conversation wittr him regarding the reason for our presence. Regarding seized evidence, all items were photographed in place and then collected by CSEU personnel. This concludes my involvement in this case. EFTA00231747 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 63 Time: 8:47:53 Incident Report Program: CMS301L Case No 1-05-000368 (Continued) ililliil ****************************NARRA ********************.****** NA Reported By: 12/21/05 Entered By.: 12/21/05 On Thursday, October 20, 2005 at approximately 0936 hours, I assisted in the execution of a search warrant located at 358 El Brillo Way, Palm Beach, Florida d Jeffrey Epstein. I was instructed by Case Agent Det. , to secure all computer and media related material from the residence. Upon my arrival I was directed by Det. to a room designated as the Kitchen Staff Office. I observed a, Silver in color, CPU with the left side cover removed, exposing the CPU s hardware sitting on floor next to a glass type desk. The CPU had no discernable identifiers or features indicating a make or model. This CPU was powered off with the power cord not plugged in. The keyboard and mouse were atop the CPU. It should be noted that the CPU was not connected to a monitor, printer, or other media device. On the back Panel of the CPU, I observed an A/V card with RCA jacks attached. This type of hardware would allow audio and video to be downloaded onto the CPU s hard disk. The ends of the RCA jacks were unattached at the time of the search and no external camera was located within this room. The CPU was located on the right side of a desk that held a flat panel LCD screen. The desk also held another keyboard and mouse, indicative of a second computer; however, no other computer was found. It appeared as though a second computer had been recently removed as the cables ends from the monitor, keyboard and mouse were in the same area. A further search of the room revealed no media storage devices, i.e. CD s, Floppy Disks, Zip Disks, etc. This type of media is commonly stored in an area where computers are placed, yet no media was found. After completing a search of this room, I secured the CPU and turned all items over to the Evidence Custodian for future forensic analysis via a property receipt. I was then directed by Det. to a room designated as the Garden Room, where I observed a wooden desk facing west. The desk held a flat screen LCD monitor, keyboard, mouse, media card reader and printer; however, no CPU was located. All of the cables were removed from an area where a computer had once been. A search of the desk area revealed no signs of any media devices. Det. directed me to a third location designated as the Cabana room, which is detached from the residence and located just south of the pool. In the South East corner of the room, I observed an office type setting, with an L-shaped desk holding a flat screen LCD monitor, keyboard, mouse and printer; however, no CPU was located. All of the cables were removed from an area where a computer had once been. A search of the desk area revealed no signs of any media devices. EFTA00231748 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Case No • 1-05-000368 Page: 64 Program: CMS301L (Continued) Det. directed me to a second detached structure located on the South East corner of the property. This area of this structure was assigned with single letters to identify a particular part of the room. In the office area, designated as Room B, I observed a powered on Dell Dimension 2350, attached to an LCD flat panel monitor. The screen displayed an open Microsoft Internet Explorer browser with URL address of http://home.bellsouth.net/. I observed no other active windows in the Start panel window and photographed screen. The power cord was removed from the back of the Dell CPU and I disconnected the cable modem to prevent rem ss. At that time, the Dell CPU, marked with Serial Number was secured and turned over the evidence custodian for future forensic analysis via property receipt. I also located several media related items within Room B, which were recorded onto a property receipt and turned over the Evidence Custodians. I then responded to a Bedroom designated as Room F, where I observed a white in color CPU marked Premio. The Premio CPU was in a computer desk which held a white CRT monitor, both of which were powered on. The CRT monitor displayed a message from Norton Antivirus software, warning of an expired subscription. I observed no other active windows in the Start panel window and photographed screen. I removed the power cable from the back of the Premio CPU an all other media. The Premio CPU, marked with Serial Number , was secured and turned over the evidence custodian for future forensic analysis via property receipt. I also located several media related items within Room F, which were recorded onto a property receipt and turned over the Evidence Custodians. This concluded my participation in the search of the residence. **************************** N A R R A # 2A ************************** NA Reported By: 12/21/05 Entered By.: ■ 12/21/05 On December 20, 2005, I contacted ASA Daliah Weiss in an attempt to subpoena the Epstein former houseman, Alfredo Rodriguez. Rodriguez, who resides in Miami, had eluded the process servers previously and was not served the investigative subpoena. A telephone message was left as she is not available during the week of 12/19/2005. I made contact with State Attorney Inv and requested the same via telephone message. I then researched the victim's II cellular telephone subpoena data which had been received from a previous subp . I analyzed the records which depict telephone calls start on which the victim and the at Epstein s residence at several calls from February 6, 2005 at 12:49 pm.; victim's father stated the in first incoming call was from The second incoming call from . The the same day ccurred EFTA00231749 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 65 Program: CMS301L Case No (Continued) cellular phonel occurred at 1:02 pm. The call durations were one minute or less. The ti ma was within thirteen minutes apart. It should be noted that IIIIII s residence was in close proximity to the v' 's. The next call occurred at 5:50 pm when the victim telephoned IIIIII s residence. Several calls were after the above mentioned calls both incoming and outgoing Further analy ' ed no telephone calls to either cellular telephone or residence were registered prior to February 6, 2005. I also conducted an analysis on the telephone calls from . The subscriber information confirmed that the number is registered to Paul A Lavery from Hialeah, Florida. The address was crossed referenced to the Office of Kiraly and Riley Private Investigators. I researched the web page www.rileykiraly.com which also showed various cases in which they assisted. I also located another web site under www.coralspringssparklandrotary.org in which Mr. Riley attended a Miami Rotary meeting and confirmed Atty. Roy Black is among his clientele. revea and ad telephone contact with either just after I attempted to interview them, or just prior. A ackground was conducted on Lavery which revealed he holds a current Private Investigator License. A criminal arrest record revealed he had been previously arrested for possession of cocaine and solicitation of prostitution. I also researched the girls using www.myspace.com. This web site is a new social networking service that allows members to create unique personal profiles online in order to find and communicate with old and new friends. The site allows one to establish your own myspace.com page and decorate the page a. , and I received a Cingular Wireless packet which contained a CD which • e results of the subpoena request for verbatim calls on . An analysis will be conducted in the near future on the phone numbers called. Investigation Continues. II ****************************NARRA ****** ****** ************** NA Reported By: ■ 12/27/05 Entered By.: Upon doing research on the message b... - .vered in the search ocated the identity was registered to " The telephone number 's seventeen years old and is atten ing t 12/29/05 I EFTA00231750 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 66 Incident Report Program: CMIS301L Case No • 1- (Continued) responded to , also known as th all. I located the Simon Youth Foundation. I located inside the foundation and informed her that I was investigati e against Jeffrey Epstein and knew she had been at the house. started to cry and advised she had put that part of her life behind her. I explained that although she is seventeen years old I needed to inform her parents that she would be interviewed. She provided her home telephone number. I attempted contact and left voice mail messages at the house to speak with her parents. * * NA Det d I then located at her residence located at in West Palm Beach. I attempted to interview her about Jeffrey Epstein. She advised she is so in love with Jeff Epstein and would do anything for him. She further explained that she would not speak with us about him either negative or positive. She asked us to leave her property. I informed her that although she did not wish to speak with us, I had sufficient information at this point in the investigation to know she was at Epstein's house and provided girls to Epstein to work. I also explained that prior to rrival residence I had telephone contact with he , who was told she would be interviewed. is currently seventeen years old and as a juvenile, parental notification would be required. We then left the area and returned to the police station. r ' the police station, I left another sage for parents. I began an an Cel one. The telephone number is assigned to and the financially responsible party is Jeffrey Epstein of 457 Madison Ave. in New York City, New York. The time frame which was subpoenaed was September 2005, through October 2005. There were eighty seven pages of calls made either to the cell phone or from the cell phone. The local (561) numbers were analyzed. A spread sheet was prepared and placed into the attachment file of who was called. The unknown numbers were researched using FoneFinder.com and subpoenas were requested to determine subscriber information. This was done to fy additional victims or witnesses. The analysis revealed that had called the victim/witnesses frequently when Epstein was in the Town of Palm Beach to "work." Thiii firms what the girls interviewed had previously stated. would notify them when Epstein was in town and their willingness to "work." The CD was placed into evidence. Investigation Continues. **************** ***** ***NARRA H 30 ************************** Reported By: MI 1/03/06 Entered By.: ■ 1/03/06 On December 29, 2005, I received a facsimile from National Compliance EFTA00231751 Date: Time: 7/25/06 8:47:53 PALM BEACH POLICE DEPARTMENT Incident Report Page: 67 Program: CMS301L Case No • 1-05-000368 IIIIIIIIiiiitinued) Center from Cingular Wireless r 1 ne number . This was the teleaLone number for during the time frame when the victim, II, was brought to t e Epstein house to "work." An analysis of the phone records, of all incoming and outgoing calls, showed that on ary 6, 2005, t ictim, II, was brought to first called , Epstein's assistant, at t 12:50 pm (EST). The next call was made to Epstein's house in Palm Baaph, at 12:52 pm (EST). The following call was made to the victim, II, at 1:01 pm (EST) and at 1:02 pm (EST). This confirms the information provided by the victim and victim's father. I photo copied ecords and enlarged the page 8 of 10 to show the calls made by on February 6, 2005. To this date, I have not heard from 's parents. I will attempt to establish contact with them during the evening hours. I received a package from Atty. Guy Fronstin, which was hand delivered at the police station. Within the package, was a letter were that of from Alan Der • two profiles. The profiles and . MySpace.com is a social networking service that allows me ers to create unique personal profiles online in order to find and communicate with old and new friends. This package was in response to a previous meeting in which Mr. Dershowitz called to assist in the investigation in providing any additional witnesses such as house employees who have been reluctant to speak with law enforcement. I reviewed the p s Mr. Der tz enclosed. , who designed her blog to be " Fucking ," still attends Royal Palm Beach High School, sends and receives messages from friends which contain some profanity. Upon reviewing her friends' comments section from Myspace, most of her good friends sent messages to establish contact and invite her to go out. I then reviewed web blog which provided by Mr. Dershowitz. Ms. designe her blog to be " ' ." Her blog states that her interests inclu usic, theater an weed (Marijuana). I reviewed her packet in which declares her love for her live-'ii end. She also describes using marijuana with her boyfriend The letter Mr. Dershowitz sent advised he was looking into the allegation that one of the private investigators used by the private attorneys of Epstein, attempted to impersonate or state that they were police officers from Palm Beach. Mr. Dershowitz advised that the —investigators used to interview had -"quite a disti speech impediment", did not claim to be nor id they impersonate themselves as a police officer. This package was sent to both ASA Lana Belohlavic and ASA Daliah Weiss at the State Attorney's Office. package and request an interview with I made telephone contact with ASA Weis • and Janusz Banasiak. She advised she would assist in attempting to EFTA00231752 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 68 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 contact Mr Dershowitz. (Continued) On January 3, 2006, I received a telephone call from ASA Weiss who informed me that she made telephone contact with Mr. Dershowitz. She had requested the employees be available the week of January 3, 2006. Mr. Dershowitz informed her that the assistants are out of the country and would require additional time to locate them and make them available. Investigation Continues. **************************** N A R R A E 31 ************************** NA Reported By: 1/03/06 Entered By.: , II 1/03/06 On Thursday, 03/31/05, I started conducting surveillance at 358 El FL tag . his point i observed at 1155 hours, a ltima bearing in Roadway, B L bearing FL tag in drive, Tan Brillo Honda Civic bearing FL tag in Roadway, Black Chevy Suburban in driveway and a Black Cad lade in driveway. At 1325 Hours I Tan Honda Civic in roadway, Black Chevy Suburban in lack Caddy Escalade in drive and a White Kia c ring FL At 1615 hours I observed a Tan Honda Civic, in Black Chevy Suburban ive, Black Caddy Escalade in and a White Kia car in roadway. observed driviiiiiir tag roadway, driveway On Friday, 04/01/05, I continued surveillance at 358 El o. At 1130 hours I observed a Tan Honda Civic bearing FL tag in roadway, Black Escalade in driveway and a Tan unknown make/model bearing FL t in roadway. At 1227 hours, I observed a Tan Honda Civic in roadway, Black Caddy Escalade in driveway and a Black Chevy SUV located behind the Escalade. At 1345 hours, I observed a Tan Honda Civic in roadway and a Blac SW in driveway. At 1558 hours, I observed a Tan Honda Civic in roadway, Black Chevy SW in driveway, Black Caddy Escalade in driveway and a dark unknown model/make car parked in garage. On Saturday, 04/02/05, I continued surveillance at 35 rillo. At 0713 hours, I observed a Red Explorer bearing FL tag in roadway and a Black C scalade in driveway. At 0814 hours, I observed a Red Explorer roadway, Black Caddy Escalade in driveway and a nda Civic At 0952 hours, I observed a Red Explorer in roadway, Black Caddy Escalade in driveway, Tan Honda Civic in roadway and also a Grey unknown make/model with a B.M in trunk retrieving landscaping tools. At 1155 hours, I observed a Grey Camaro bearing FL tag parking in the roadway in front of 358 El Brillo. A W/F, blond hair, teens to early 20's, thin and tall wearing a white tank top and short blue jean shorts, exited the vehicle angmaaliced to the rear of the house. also observed a Red Explorer IIIIII in roadway, Tan Honda Civic in roadway and a Black Caddy Escalade in driveway. At 1310 hours, I EFTA00231753 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Incident Report Page: 69 Program: CMS301L Case No 1-05-000368 (Continued) observed a Red Explorer W/F driver lea e area, Tan subcompact on roadway and a Red Neon bearing FL tag . Then observed 3 W/Fs, approximately 16 to 18 years of age jogging. All 3 females ran into the driveway. There were 2 with blond hair and one brown hair. On Sunday, 04/03/05, I continued surveil at 358 El Brillo. At 0719 hours I observed a Tan Honda Civic in roadway an ck Caddy Escalade. At 0934 hours, I observed a Tan Honda Civic in roadway and a Black Caddy Escalade veway. At 1057 hours I observed only the Tan Honda Civic On Tuesday, 1052 hours, Expl tag Mercedes in 04/05/05, I continued surveillance at 358 El Brillo. At driveway being washed by a B parked in the garage. At 1059 hours a Blue Chevy Suburban drove to the house of 358 El Brillo and paaagin the driveway. At 1119 hours, I observed the White Fort Truck IIIIII leave the area and the drive was the pool man. At 1126 hours, I observed a Grey unknown make/model car park in roadway. W/M got out of the car and walked to a house on the south side of El Brillo. At 1406 hours, I observed a Red Explorer parked on roadway and a large white box truck parked behind the surveillance suburban. I observed a lorer in roadway, a Green earing FL tag in roadw Grey Altima bearing FL in roadway, White Ford Truck in roadway, Black M and an unknown dark car ****************************NARRATIvg NA Reported By: Entered By.: # 32 ************************** 1 /03/06 /03/06 On 03/31/05, at approximately 1500 hours while conducting surveillance at 358 El Brillo, I observed a Black Cadillac Escalade, unknown tag, a Chevrolet Suburban, unknown tag, a Black Mercedes 5600 FL tag parked in the east dri ext to the 3-car garage. There was a Tan Honda Civic FL tag nparked on the street in front of the residence. At approximately 1700 hours, I observed the Black Suburban, Black Escalade, Black Mercedes and Tan Honda Civic parked in the same place. At 1750 hours, there was no change in vehicles. At 1840 hours, I observed the Black Escalade, Black S and Black Mercedes along with a Silver Hyundai Accent FL tag parked in the east driveway and a Red Ford Explorer FL tag- arked on the street in front of the residence. At 2000 hours, I observed the Black Escalade, Black Suburban parked in the ease driveway and the Red Explorer and Tan Civic parked on the street. On Friday, 04/01/05 at approximately 1700 hours, I observed the Black EFTA00231754 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 70 Time: 8:47:53 Incident Report Program: CMS301L Case No 1-05-000368 (Continued) Escalade and Black Suburban parked in the east driveway and the Tan Honda Civic parked on the street in front of the residence. At 1820 hours, I observed the suLaLLAa and Civic in the same place and a Gold Chevrolet Camaro FL tag IIIIII parked on the street in front of the residence. At 2250 there was no change. At 2330, I observed the Black Escalade parked in the driveway and the Red Explorer parked on the street in front of the residence. On Saturday, 04/02/05 at approximately 1700 hours, I observed a Black Escalade, unknown tag, parked in the driveway and a Tan Honda Civic FL tag X98AMP parked in the street in front of the residence. At 1805 hours the Escala Civic were in the same position and the Black Mercedes FL tag was also parked in the east driveway. At 192O hours the Escalade and Civic were the only vehicles and both were in the same position. At 2030 hours and 2145 hours there were no vehicles observed. At 2115 hours, I ed a Black Mercedes, 4-door parked in the east driveway FL tag r At 2300 hours, 2350 hours and 0045 hours, the Black Mercedes was the only vehicle observed. NA Sli NARRA ************************** Reported By: /05/06 Entered By.: 1/05/06 I made contact with Mr. Preston , father of who was told that I wished to interview his daughter. Mr. stated he was aware and had spoken with his daughter about the incident. He stated that his daughter had previously told hi she was hired to model lingerie at a Palm Beach mansion. Mr. stated he kn ing else about what she did when she went to "work." Mr. advised he would cooperate with the investigation and make his daughter availa interviews. I asked if she was available for an interview, stated she was not at home at the mome informed him I wou make contact with her at a later time. Mr. expressed his interest in the resolution in this matter as he stated this information has affected his daughter emotionally. On January 4, 2005, I acquired the subpoenas from the State Attorney's Office for Cingular Wireless, Metro PCS, Verizon, Bell South ' ions and Sprint for the unknown telephone numbers from cellular telephone. The subpoenas were sent to the respective telephone carriers for subscriber information. I received a telephone call from State Attorney's Office, who informed me that the former houseman for Jeffrey Epstein, Alfredo Rodriguez, was present at the State Attorney's Office for an interview. Rodriguez was issued an investigative subpoena for an interview on the on-goings at Epstein's house during his employ. I responded to the State Attorney's Office and encountered Mr. Rodriguez waiting in the lobby. I brought Mr. Rodriguez to the interview room. EFTA00231755 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 71 Time: 8:47:53 Incident Report Program: 0 00301L Case No • 1-05-000368 (Continued) During a sworn taped statement, Mr. Rodriguez stated he was employed by Jeffrey Epstein for approximately six months. He was referred by associates and his employment lasted the months of November 2004 through May 2005. His responsibilities as house manager included being the butler, chauffer, chef, houseman, run errands for Mr. Epstein and provide for Epstein's guests. Rodriguez advised he had very limited contact with Mr. Epstein. If Rodriguez needed to relay a message to Mr. Epstein, he would have to notify Epstein's secretary "Leslie" in York City, who would then notify Epstein's personal assistant, , who would relay the message to Epstein. Rodriguez stated Epstein did not want to see or hear the staff when he was in residence. I asked Rodriguez if Epstein received many guests during his stay in Palm Beach. Rodriguez advised he had many guests. I asked specifically about masseuses coming to the house. Rodriguez stated he would have two massages a day. Epstein would have one massage in the morning and one massage in the afternoon everyday he was in residence. Rodriguez stated he wou41 1aainformed to expect someone and make them comfortable until either IIIII or Epstein would meet with them. Rodriguez stated once the masseuses would arrive, he would allow them entry into the kitchen area and offer the ething to drink or eat. They would then be encountered by either or Epstein. They would be taken upstairs to provide the massage. I asked Rodriguez if any of the masseuses appeared young in age. He advised he didn't ask their ages but felt they were very young. Rodriguez stated they ate like his own daughter who is in high school. Rodriguez stated they would eat tons of cereal and drink milk all the time. Rodriguez stated the girls that would come appeared to be too young to be masseuses. He stated one time under Epstein's direction, he delivered a dozen roses to Royal Palm Beach High School for one of the girls that came to provide a massage. He knew the girls were still in high school and were of high school age. I asked Rodriguez about the massages. He felt there was a lot more going on than just massages. He would clean Mr. Epstein's bedroom after the alleged massages and would discover massager/vibrators and sex toys scattered on the floor. He also said he would wipe down the vibrators and sex toys and put them away in an armoire. He described the armoire as a small wood armoire which was on the wall close to Epstein's bed. Epstein ordered Rodriguez to go to the Dollar r t a car and rent a car for the same girl he brought the roses to, that she could drive ter-self-to Epstein's house without incident. Rodriguez said the girl always needed rides to and from the house. Rodriguez referred himself as a "human ATM machine" and was ordered by Epstein to maintain a minimum balance of $2,000 dollars on him at all times. When a girl would come by the house and Mr. Epstein was either not in residence or was not at home at the time, Rodriguez was to provide the girl (masseuse) several hundred dollars for their time and to notify Epstein the amount they were given. Epstein also ordered Rodriguez to EFTA00231756 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 72 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) purchase several gifts and provide them as tips to the girls. I asked what kind of gifts. Rodriguez stated he purchased IPODS, jewelry, anything the girls would want. Rodriguez stated the amount of girls that came to the house was approximately fifteen. Each of the girls knew each other and all seemed to know at Royal Palm Beach High School who Mr. Epstein was. When asked to identify these girls, Rodriguez stated he could not at the moment but knew he wrote their names down on a journal he kept during his employ with Mr. Epstein. He kept a journal in the event he needed to explain either to Mr. Epstein or his assistants what was done at the house or who visited the house as he stated he was in-charge of Mr. Epstein's personal security while in Palm Beach. I informed him I would need to view this journal to which he stated he would research the book and contact me to provide the book. The interview was concluded and left the area. I returned back to the police station where the micro cassette was placed into evidence. At approximately 7:20 pm, I was notified Rodriguez located the journal and would call me on January 5, 2005 to provide the journal. Investigation Continuesaa **************************** NA al NARRA ************************** Reported By: 1/09/06 Entered By.: 1/10/06 on January 5, 2006, I attempted to meet with Alfredo Rodriguez to recover the folder or journal in which he kept the notes that were given to him during his employ with Mr. Jeffrey Epstein. He kept this folder to justify what he did during his employ should the need arise to justify what occurred with the monies he had to keep or any questions as to the petty cash he withdrew from the household account from the bank. At approximately 10:00 pm, I attempted contact with Mr. Rodriguez and discovered he was assisting his wife at her place of employment and would not be able to meet with me. Mr. Rodriguez stated he would meet with me on January 6, 2006, in Broward County, in the morning hours. On January 6, 2006, at approximately 9:00 am, I received a telephone call from Mr. Rodriguez who advised he had the file in hand and would be traveling northbound to meet with me in Broward County. At 10:50 am, I met with Alfredo Rodriguez at the parking lot of Bank of America in Boca Raton on Yamato Road and Military Trail (known as the Polo Center). Rodriguez produced a green folder which contained documents, a note with Mr. Epstein's stationary with direction toagilyer bucket of roses to Royal Palm Beach High School after ( ) high school drama or e. Also in that same note was direction to rent a car for ( ) and direction to extend the rental contract. I returned to the Palm Beach Police Station and placed the folder into evidence. I received a fax from Verizon from the subpoena request sent on EFTA00231757 Date: Time: Case 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 73 8:47:53 Incident Report Program: CM1S301L No • 1-05-000368 01-04-06, for telephone number registered to Dr Perry Bard, from West chiropractor and has an office located Palm Beach. The cellular number is Dr number. (Continued) . The phone number is Palm Beach. Dr. Bard is a 4275 Okeechobee Blvd in West Bard's personal cellular On January 9, 2006, Det. and I tray Palm Beach Gardens in an attempt to locate , who been previously seen on the property and identified through her Florida Drivers License and Florida license Plate. A business card was left for her to return my Youth Foundation and located speak with us and in a private taped statement. During the sixteen ye associate, or early June 2004. S e was to she could model lingerie for money for a wealthy Palm Beacher. She remembered they traveled by yellow cab from their residence in West Palm Beach to Epstein's house. She remembered encountering Epstein at the front door during the evening hours. in had travelers o the Simon agreed to room within the school provided us a • statement, advised that when she was fifteen or en to Jeffrey Epstein's house by her stated this occurred late May 2004 He introduced himself and brought them into the kitchen II that the ould prepare somethin em to eat. After having a meal, and Epstein brought upstairs to a master bedroom which had a large bathroom. She observed a large style shower, sauna and there was a large massage bed also in the bathroom. Epstein d a room within the bathroom and came out wearing o wel. said they would a massage on his feet. asked why they are doing this. told her this was part of tine and told her to rub his comfortable. Epstein's direction, by herself. Epstein to • to get comforta her blouse and pants and stayed in her panties. was not wearing a bra. She believed she was wearing ontobeghisanb and ilialissisissi Epstein ' • to get calves eet. At e t the room leaving there removed stated she thong panties. stein ; he but stayed on panties. During the first massage, she stated Epstein was and began masturbating himself at the same-tIme. -He put his hands -under the towel and appeared as to ' if however she never saw his penis. She continued until he grabbed her and pulled her closer to him. He appeared to have climaxed because after he pulled her closer to him the massage was over. Epstein had told her that there was two hundred dollars for her on the dresser. He told her that she could not tel a what happened at the house or bad things could happen. stated she went to Epstein's house three EFTA00231758 Date: 7/25/06 Time: 8:47:53 Incident Report PALM BEACH POLICE DEPARTMENT Page Program Case No • 1-05-00036 (Continued) or four times total. was very scared and felt very nervous. She knew because of Epstein's money he was powerful. After the massage, Epstein ordered his houseman at the time to drive the girls home. The employee was to drop off the girls at their house and watch them go inside their house. could not er who the houseman was. She stated Epstein and his assistant would call her at her father's house to arrange for her to come and "work." She advised . e she returned to the house, Epstein would do the same thing. stated it was a routine with Epstein. She ' es. He would then turn over and begin to . The only differ • one without panties. Epstein's fingers would as he would masturbate and finally climax and the massage would be over. She was paid $200.00 each time she went. Each time she went she was reminded not to speak of what happened at the house and that she would be coed again. She began to purposely miss the calls when giLLgL or Epstein would work for Epstein. She was paid $200.00 for bringing call her. She once brought a friend, "111111" unknowil na . stated she no longer retuned to work for Epstein. She also stated e wanted to notify the police of what happened at the house. stated she was scared of what could have happened to her or her family if she notified authorities. On January 10, 2006, I received the results BellSouth Telecommunicatioiiiiiiiiiiiiho number is assigned to Mr. , Beach Gardens. I also received th confirmed the money order sent to from Jeffrey Epstein in New York City. The "wire" was sent by Jeffrey Epstein of 457 Madison Ave in New York City on December 23, 2004 at 12:05 pm. nt of $222.00 was charged to Epstein's credit card so that could receive $200.00 in Royal Palm Beach. The twenty-two dollars was for processing and local fees to send ey via Western Union. A copy of the check presented to attached to the receipt of the wire. This confirmed what advised she received as a Christmas bonus from Epstein. from t rom The father in Palm estern Union which Investigation continues. ****************************NARRA ************************** ES NA Reported By: 1/10/06 Entered By.: I received and reviewed the Cingular Wireless and , is assigned to Janusz Banasiak Epstein of 457 Madison Ave in New York City. houseman/house manaiiii iiiiiii,El Brillo Way The second number, , is assigned 1/10/06 results from the for telephone numbers The first number, in care of Jeffrey Banasiak is the current in Palm Beachiliiii3480. to Christina of EFTA00231759 Date: 7/25/06 Time: 8:47:53 Case NA PALM BEACH POLICE DEPARTMENT Incident Report Page: 75 Program: CMS301L 5-000368 in West Palm Beach. Research conducted on nued) revealed she is a licensed Massage 'st a Florida conditional/active license number had been previously arrested for battery / unwanted tout ing and DUI. Requests for copies of the reports involving the arrests were reques Palm Beach County ff's Office. The last number is assigned to Rofrano of 9850 Alt AlA in Palm Beach Gardens. Research on Mr. Rofrano, revealed that he is a Florida Chiropractic Physician. Vehicles that were previously documented on the property while surveillance was being conducted were rese I determined a tan Chevrolet Camaro, bearing Florida license , was seen on the property in which a young white female was seen entering the Epstein property. Res onducted which reveal at the vehicle is to La Mr. has two daughters, and is currently residing in Connecticut and rest trig with her father in Lake Worth. Research on revealed she was recently involved in a traffic stop in La e C ar e Shores in May 19, 2005. A request to discover any information from the stop was requested. I spoke with ASA Daliah Weiss who informed me that Janusz Banasiak will be available for an interview tomorrow at the State Attorney's Office in West Palm Beach at 1:30 pm. I informed her that I would be at her office for the interview. th l, ****************************NARRA ************************** Reported By: 1/23/06 Entered By.: A. 1/23/06 2006, Det. in Palm Beach Gardens. and I h IIIIIIIIIIIIIII at was 1 entl led as a licensed massage therapist who had previously b on Epstein's property when physical surveillance was done. was told of the on going investigation and I felt she may hav information pertaining to the case. During a sworn taped statement, stated she met Epstein three years ago when Ghaline Maxwell approached her while she was attending Palm Beach Atlantic College to work around Epstein's house. Maxwell had told her that they needed irls to work at the house to answer phones and run errands. accepted the job an working at Epstein's house on El Brillo in Palm.Beach. stated it was a part time job during the time she went to Palm Beach AtlantIc—College --She continued going to Epstein's ho would be notified when Epstein would travel to Palm B advised she would be notified by Maxwell, Epstei , his assistant, when he would travel to Palm Beach. stated she began providing massages to Epstein before she became a massage conantd his in iving massages was not lioEpstel d about nbut tc) what occurred during the massages. lig" stated as she was twenty EFTA00231760 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 76 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) three years old when she met Epstein, anything that happened was between two consenting adults. I explained to her that she was not in any trouble however of this investigation, I needed to ask certain questions. stated that there were times that Epstein would ask her to per orm uring the massage. uld instruct her to rub his nipples as he masturbated himself. stated she felt "grossed" ab behavior but as she was getting paid, she just continued. also advised she would on occasion perform the massages naked. Epstein would on occasion, utilize the r/massager on her vagina area when she performed the massages. explained that Epstein never exposed himself to her as he maintained himself covered under the towel he would be wearing. When Epstein would masturbate he would be covered. I asked if Epstein. Epstein took She received ever received any gifts, or any gratuities from advised aside from being paid well, she advised care of her tuition from Palm Beach Atlantic College. a rental car for a week when her scooter broke down. Additionally she received other gifts from Epstein. Epstein also recommended her to another client who resides at Breakers Row in Palm Beach. The client she was referred to was "Glenn" unknown last name, and his wife, who she provided a massages to. The statement was concluded and placed into evidence upon our return to the Palm Beach Police Department. While at the police station, I researched Florida tag which was also previously seen on the property when there was physical ' e being done at the property. The vehicleiiiiiegistered to r. and the „ of Lake Worth, Florida. vehicle revealed that his daughter, had been driving ' the vehicle and was cited for unlawful speed in Lake Clark Sho ehicle is a tan, Camaro, 2-doo , date o ' th, , resides at Lake Worth. has a my space page called yspace.com pinkpetals. In her web page, shows various photos of photographed at a beach. An interview is forthcoming. A review of the video disks which was extracted at the Palm Beach County Sheriff's Office Computer Crime Unit revealed that only one hidden camera was functional at the time. Several image ' worki t ' • e were seen. Additional footage of and was seen. There was other footage of females seen. The identity of the females is unknown at this time, until such time as r meet with certain females to_qhow_the video-footage- to confi f act, the video. At this time it appears that and are seen sitting with Epstein beside his desk in the evening hours. Due to poor lighting, a direct confirmation cannot be made at this time. Inv. Continues. EFTA00231761 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 77 Program: CMS301L Case No • 1-05-000368 (Continued) ****************************NARRA tt 37 *******************t****** Mil NA Reported By: ■ L/30/06 Entered By.: 1/30/06 iiiianuary 25, 2006, Det in Lake Worth and met with year, when she was seventeen through her former room Epstein at the time. when they modeled. dvised her that she was made arrangements to arrived and met Epstein and Beach Mall together and wen and explained in Palm Beach and requested to se it t she had received money from Epstein to go to the mall. They visited Victoria's Secret and purchased undergarments from the store utilizing s given by Epstein. advised she purchased one item and purchase various items. The money used to purchase the items was the money given by Epstein. stated and he has been paying all of her bills. claimed advised they met in New York and had been dating ever since. They later returned to Epstei ' ome and encountered Epstein. He had a brief conversation with out her modeling career. He knew of her modeling career from . He requested to see her modeling olio and explaine tat he coul p her with modeling jobs. had her book with her to show and showed the book to E n. He commented negatively about er photographs and portfolio. felt uncomfortable with the comments made as she had been working with other professional modeling companies who had offered her work from her photograph stein requested to see what was purchased at the mall. IIIII took out the undergarments which were purchased. She immediately showed E n different s iiurchased. Epstein then requested to view what purchased. was reluctant to show the outfit however since it was Epstein's money that purchased the i she pulled ' t of the bag. Epstein asked her to try it on. looked at who told her "yeah, try it on." Feeling compelled to try the un ergarment outfit on; she went to another room and put on the bra 'and panty set. She walked out to the living room where they were sitting, and modeled the suit. She then a back into the other room and ch ack into her clothes. duted- another-day-f returned into the room andl i ii she would be going home. Burns sche or to return for massages with her. stated last met Jeffrey Epstein was allegedly dating once cohabitated together called her on her telephone • at Ep 's house. went to Palm advised that and a continued shopping and having a day together. explained how she and Epstein been dat' ach other stated within t ame week, she returned to meet with and have a massage. had told her that she would be unable to with her as she woul be going on a bike ride with Epstein. explained she could stay at the house and take advantage of the massage. EFTA00231762 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 78 Time: 8:47:53 Incident Report Program: CMS301L Case concluded and 1-05-000368 (Continued) stated she met with an unknown ma therapist and had the table already set up in a guest room. removed her clothing, leaving he ties on, and wrapped herself with a towel for the massage. remembered that the door to the guest room was closed but not locked. As the therapist was working LA.LLack, the door was opened by Epstein and entered into the room. IIIII was trying to conceal herself as Epst as talking to her about his opractic session. Epstein told turn over onto her back. eas Epstein as he stated Epstein " removed her self the table, got dressed and left the house. further stated had attempted to call her several occasions toile her back to Epstein's house to which rent n 'm busy." advised she has not had contact with either Jeffrey Epstein. It should be noted that her mother, was present during the interview. The interview was we thanked them her for their time. **************************** N A R R A a 38 ************************** NA Reported By: 1/31/06 Entered By.: , II 1/31/06 On 00illiliade telephone contact with Christina , at . is a licensed massag mlja-Lapist who had frequented the home of Jeffrey Epstein. Ms. IIIIII has been unable to meet with me in Palm Beach County, and because she lives and works in Port cie, a telephone interview was conducted. I explained to Ms. that there was an on going investigation involving Jeffrey Epstein. stated she knows Epstein and has been approximately three years. Epstein has paid Massages (Deep Tissue) on him and other guests. approximately three year ago she met Ghislaine Maxwell and Jeffrey Epstein through a mut 'end. Epstein and Maxwell were looking for a massage therapist. stated sin t time, she is notified when Epstein is coming to Palm Beach. d she comes to his house and provides the massage or massages explained she has also massaged his guests and assistants. continued that she is paid $100.00 and hour for the massage. I asked if anything occ during the massage that would have made her feel uncomfortable. stated she only provided massages and that was it. She never was approached for anything else. I asked if Epstein ever asked her to rub his chest she sta., would not rub his chest as that is not part of her massage. explained that she was not Epstein's type. The girls she would mil Epstein's house were very thin, beautiful and without tattoos. explained she has several tattoos that are visible. Maxwell and Epstein have commented negatively about her tattoos previously when she has provided massages. ed by him for perform Swedish explained that EFTA00231763 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 79 Program: CMS301L Case No • 1-05-000368 stated she only provided massages for Epstein and associates and nothing happened during those massages. stated as she does Swedish style massages, the patient is usually sore after the massages. I thanked her for her assistance and the interview was concluded at this time. (Continued) I recei ile from T-Mobile Cellular service on telephone number , which is assigned to David Rodgers, pilot for Mr. Epstein, who resides in Lake Wo a' telephone number was dialed on several occasions by . A background on Rodgers indicated he has a valid FAA pi of icense First Class for the Southern FAA Region. Rodgers has another historical FAA license for Airline Transport Pilot. Investigation Continues. th l, ****************************NARRA ************************** NA Reported By: 2/14/06 Entered By.: 2/16/06 ary 3, 2006, I had made arrangements to meet with at the Palm Beac on. At approximately 1:OOpm, and her friend, arrived at the police station. During an interview wit , she stated she met Epstein when she turned eighteen years o d and was brought to Epstein's house to provide She advised this occurred on May of 2005. She advised informed her if she wanted to provide a massage for $200.00. eed and was brought to Epstein's house to provide a massage. stated she had been to the house on many occasions during the massage sessions. also state uld remove her clothing to provide the massage on Epstein. advised Epstein would pay her $300.00 to rub his back, legs and chest. During the massages, Epstein would mastiiiiii, ' she rubbed his chest. her if Epstein ever during the massages. replie " " I askeil her or massage her vagina. stated I asked her i r penetrated her with either his stated that during a massage he she massaged him. She stated this occurred one time only. stated the massage over when Epstein would climax onto a towel. I asked if she had al massage training to which she replied that she did not. R1 then asked if she ever brought anyone —to—the—house to "work stated she brought two people to the house. She advis eceived money for bringing people house to "w tated she brought a gir " and her friend was still wa r in the lobby of the police station. I thanked for her time and her cooperation and escorted her to the lobby. I asked Ms if I could speak with her about this investigation. I EFTA00231764 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 80 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) brought her to the interview room and explained to her that I was conducting an investigation on Jeffrey Epstein an it she may have informatio o the investigation. Ms identified herself as and resides in Wellington, Florida. She advised approximately a year site was brought to Epstein's house to provide a massage for money. stated she ded to make money and felt it was a quick way some money. stated she was brought to the house by and was introduced to Epstein and his assistant. She was brought to his main bathroom and provi a massage. I as " aked. ted she did. She . I asked if Epstein touched her during the massage. She advised he did not, however he did masturbate himself as she rubbed his chest. Once he climaxeillie massage was over. She was paid her money and left the area. advised it occurred one time and she n returned to Epstein's house. The interview was concluded and was escorted to the lobby. I located a telephone number for pted to contact hamo several occasions. I called and spoke with Ms. IIII who advised she would speak with me in Deerfield Beach where she resides. Due to a scheduling conflict, we were unable to meet. I informed her I would contact her to schedule another appointment to speak with her about this investigation. I have attempted to meet with her and make telephone contact with negative results. On February 13, 2006, I met with David Rodgers at 7318 Heathley Drive in Lake Worth. Rodgers was identified as Epstein's pilot. I spoke with Rodgers who advised he has been employed with Epstein since 1991. He flies both planes for Epstein depending where he wants to fly to. Rodgers was asked about passengers in the plane he flies. Rodgers stated unless Epstein flew to his island off of St Thomas, there would be no way of knowing who the passengers were. I menti ent flight to Ohio, where Rodgers flew to Ohio to pick up Rodgers sill he recalled flying on several occasions and did remember . Rodgers stated once he is in the cockpit, he does not know who the passengers are. When he prepares the passenger mani e lists Epstein and his assistants he knows by name, and . Rodgers stated he would list either female or male passengers on the manifests only to keep a count on the passengers. Mrs. Rodgers came into the living room and recommended that her husband consult with an attorney. Mr. Rodgers agreed he would speak with the family attorney to inform him of this questioning. I explained to Mr. Rodgers that he was not the suspect in this investigation and ceased all questions. Based on the fact Rodgers could not advise who passengers were in the plane, I then left the area. I attempted to locate at in Wellington. I left my business card for her to return my call. February 14, 2006, at 12:06 pm, I received a call back from Ms. EFTA00231765 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 81 Incident Report Program: CMS301L Case No • 1-05-00036A.... (Continued) on my Ms IIIII left her telephone number for a return call I • . I left her a message to return call. Investigation Continues.. ****************************NARRA # 40 ************************** 111 NA Reported By: 2/21/06 Entered By.: A. 2/22/06 On February 15, 2006, I made telephone contact with who provided dire could locate her. Det I ded to in La Park to meet with Upon my arrival, I met with in the parking lot directly behind MAACO Auto Painting. She was advised I was there to speak with her about an 2agsging investigation that concerned Jeffrey Epstein in Palm Beach. IIIII stated she knows Epstein very well and did not want to speak with me about Mr. Epstein. She was very fond of Epstein and did not want to speak with me about anything concerning Jeffrey Epstein. I explained to her that she was seen at the house and I would like to speak with her. She stated she knew there was an investigation and that I had spoken with other iiiiie and therefore I should know what happened at Epstein's house. ended the conversation and ack into her boyfriends business, Blanton Automotive. Det and I left the area and returned to the police station. Investigation continues. **************************** N A R NA sit R A ************************** Reported By: 4/10/06 Entered By.: ■ 4/10/06 A Grand Jury Session was requested during the month of February 2006, in which all the girls that had been interviewed would have been called to testify before the Grand Jury to seek an indictment against Jeffrey Epstein. Due to subsequent meetings with the State Attorney's Office and Defense Attorney Alan Dershowitz the Grand Jury was postponed until a later time. Dershowitz had provided a package of material on the main victims in this case in which they appear on myspace.com and speak about alcohol use and some marijuana use. The State Attorney's Office wanted time to review the material. I requested additional subpoenas from the State Attorney's Office in which I requested information from Dollar Rent a Car and Jet Aviation. The information requested from Dollar Rent a Car was for the rented vehicle by Alfredo Rodriguez while under the employ of Epstein for one of the victims. The other subpoena requested was for Jet Aviation for dates and times when Epstein's planes were in Palm Beach County. I continued to research other names that were acquired either from interviews or intelligence gathered during the investigation. I EFTA00231766 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Incident Report Page: 82 Program: CMS301L Case No. . - (Continued) in Royal Palm Beach. I respon ni Royce Beach. During the int stated she knew I would be speaking with her. stated she ' introduced to Epstein when she turned eighteen years old. stated she was sure of her age as it was her senior year in Royal Palm Beach High School. She advised she was brought there to make money and was told she would have to provide a massage to this each guy. She remembered she met Epstein and his assistant in She stated she went upstairs with kitchen area. She stated she was tali one of her friends, while got ready for the massage. He exited his bathroom naked and ound. Epstein asked her if being naked offended her. stated it made her able. Epstein then put on a towel and lay on the table. stated she rubbed his back and e stated she had no massage training or experience. s ing the massage, ouch her buttocks. pulled away as . She told him again s e was uncomfortable with im touching her. Epstein then cut the massage short and became upset with her. Epstein I $200.00 for the massage and told her to leave the house. ed to the house. She did advise of e she went with however she waited in the car for s she did not want to go into the house. clusion of 's visit with Epstein they left the area. stated she had heard from other girls that have gone to the house that Epstein now required them to do the massage naked and allow him to touch the • 'r private areas for monies. The interview was concluded as did not have any other information to provide. I then learned from the original victim, II, the defense attorney had learned of her identity. I spoke with the father of the victim, who stated there has been a private investigator on his house photographing his family and chasing v' 'tors who come to the house. He provided a Florida License of . This vehicle is registered to Ivan Robles of West Palm Beach. Robles is a private investigator intern who is licensed by the state. I informed the State Attorney's Office of the above information. I received the Grand Jury subpoenas to be delivered to three victims for a Grand Jury session to be held on April 18, through April 20, 2006. Investigation continues. ****************************NARRA 42 ************************** Wit NA Reported By: 4/14/06 Entered By.: ■ 4/18/06 The Grand Jury Subpoenas were personally served to the individuals they were issued to. On April 5,./006, at approximately 7:30 p.m., I personally served the parents of III, who had informed me that the private investigators were still photographing the family. On April EFTA00231767 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 83 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) 10, 2006, at approximately 2:30 p.m., I served II at her kapidence in Royal Palm Beach. The subpoena was given to her mother, III. I learned through one of the victims III that she was personally contacted through a.gource that has maintained contact with Epstein. The source assured II she would receive monetary comp sat ion for her assistance in not cooperating with law enforcement. Il also stated she was told, "Those who help him wile compensated and those who hurt him will be dealt with." I told that tampering with a witness/victim is an arrestable offense an ery serious. I asked her who approached her during this encounter. originally was reluctant to provide the name of the person who approached her to offer her not to testify because she felt they were still friends. On April 11, 2006, Det I traveled , Florida 'th the victim, identified , W/F, , as the person who approached her in RQyal Palm Beach while Il o skated she did not want to pursue the intimidation charges on II was s e was home during Spring Break in March 2006. concerned that the defense attorney was given a copy of the report as m ain things she had told me in confidence were repeated to her by . Prior to our departure, the victim was given a copy of her subpoena for the Grand Jury which was scheduled to commence April 18, 2006. Upon our return from Tallahassee, I notified the State Attorney's Office of what was told to me. I also notified them that the subpoenas were delivered to the witnesses and they would be calling for arrangements for the date and time needed for the Grand Jury. I spoke with ASA Weiss and informed her of the possible intimidation by the defense. On April 13, and April 14, 2006 I attempted contact on several occasions with ASA Weiss and ASA Belohlavic to ascertain when the victims needed to report for Grand Jury testimony. Messages were left on their voicemail. On April 17, 2006, during the hours of 9:00 am and 11:30 am, I again left messages for ASA Weiss and ASA Belohlavic for either of them to return my call as I had not heard from the State Attorney's Office as to the time and date of the Grand Jury. At approximately 12:30 pm, I went to the State Attorney's Office and located ASA Weiss and ASA Belohlavic in their offices. I entered ASA Belohlavic's office who informed me that she was going to return my call. She explained that an offer was made to the defense, Atty Guy Fronstin and Atty Alan tre-rihowitz. The offer is 1 count of Agg Assault with intent to commit a felony, five years probation, with adjudication withheld. Epstein would have to submit to psychiatric/sexual evaluation and no unsupervised visits with minors. When asked about the all the other victims, AS elohlavic stated that was the only offer made as to one victim, II. ASA Belohlavic cell phone rang and went to voice mail. She checked her voice mail and played the message on speaker. The caller identified himself as EFTA00231768 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 84 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) Atty Guy Fronstin and acknowledged the deal made between them. Fronstin stated in the message, he spoke with his client, Jeffrey Epstein, and agreed to the deal. Fronstin asked to call off the grand jury as they would accept this deal. Belohlavic stated a probable cause would be needed to book Epstein in the county jail and would let me know as to when it would be needed. I explained my disapproval of the deal and not being consulted prior to the deal being offered. However I expressed that was only my opinion and the final approval come from the Chief of Police. She explained to have Chief call Barry Krisher about the deal. I left the area and returned to the police station where I briefed the Chief about the deal offered. I checked my voice mail me ges and discovered a message from stepmother for the victim . She was calling because the State Attorney's Office still ha not returned any of her calls as to when they are needed for this case. I then called ASA Belohlavic's office and left messages for her to call the victims on this case and explained to them what the State Attorney's Office had done. On April 17, oximately 4:30 pm, State Attorney Investigator called to officially notify me of the cancellation of t e Gran Jury. He requested I contact the victims that ha ved to appear, to notify them of the cancellation. I advisedd that as this Grand Jury session was called based on the State Attorney's Office decision to have the victims heard by the Grand Jury that I felt it was the States Attorney's Office responsibility to contact the victims and advise them of the reason they were no longer needed. ****************************NARRA ************************** NA MI Reported By: 5/04/06 Entered By.: S/04/06 As I had not received any contact from anyone at the State Attorney's Office, on May 1, 2006, I prepared three arrest warrant requests and submitted them to the State Attorney's Office. The packages were delivered to the Crimes against Children Unit in care of ASA Lana Belohlavek. Jeffrey Epstein's arrest warrant was requested for 4 counts of Unlawful Sexual activity wi • inors and one count of Lewd and Lascivious Molestation. , Epstein's assistant's, arrest warrant request was for 4 counts of Principal in the 1st degree Unlawful Sexual activity with certain minors and one • ipat—in- the 1st degree Lewd and -Lascivious Molestation_ arrest warrant request was for Lewd and Lascivious Acts on a victim under 16 years of age. The receipt of delivery was signed and brought back to the records division at the police department. On May 3, 2006, at approximately 2:54 pm, I received a telephone call from ASA Daliah Weiss on my cellular telephone. ASA Weiss advised she EFTA00231769 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 85 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) has been taken off the Jeffrey Epstein case because her husband is employed with Attorney Jack Goldberger. Attorney Goldberger is the attorney of record for Jeffrey Epstein. His previous attorney, Guy Fronstin, has been fired from representation. ASA Lana Belohlavek has been assigned the case. ASA Weiss stated she can no longer speak about the Epstein case with me. I thanked her for her telephone call. ASA Weiss further stated that ASA Belohlavek would be calling me. IS ****************************NARRA •************************* NA Reported By: 5/15/06 Entered By.: 5/15/06 On May 10, 2006, information was received that Epstein's associate, Leslie Wexner, The Limited inc, CEO's, plane had arrived in West Palm Beach, PBIA. The plane, a Gulfstream 4 bearing a N900LS registration, was on the tarmac at Galaxy Aviation. As Epstein had recently acquired the services of a new attorney, and the fact that Epstein's house is currently under remodeling, it was believed that Epstein may be in Palm Beach. I conducted physical surveillance at the residence, 358 El Brillo Way. I observed a large construction crew conducting remodeling at the house. The contractor, David Norr, was observed driving a Ford E , white in color. The vehicle has a Florida registration of r left Epstein's house and traveled north on County Road. Det and I conducted surveillance on Norr. Norr traveled to several construction sites and check ertain jobs. Surveillance was discontinued on Norr and Det and I traveled to Galaxy Aviation. I observed the white plane with a blue stripe along the body and tail of the plane; the tail number was visible on the bottom of the tail, closer to the body of the plane. We maintained visual surveillance on the plane until 4:57 p.m., when a caravan of Cadillac Escalades drove onto the tarmac. We observed several people exit the vehicles and discovered that they were part of the executive team for Limited Inc. The executives were in Palm Beach County for an executive meeting for the day. They arrived in Palm Beach County on May 9, 2006 at 9:30 pm and were scheduled to leave on the 10th at 5:00 pm. On May 12, 2006, I met with ASA Lana Belohlavek at the State Attorney's Office. She explained that her boss, Barry Krischer, was requesting this case be taken to the Grand Jury again. I ' o her ted arrest warrants for Jeffrey Epstein, and . I asked that she either issue the warrants or direct file, as so much time has elapsed since the original request to the Grand Jury. I explained that the- Palm-Beach Police Department had concluded the case in December of 2005 and has been waiting for the case to go forward. Belohlavek stated the original offer was again offered to the new defense attorney. She was waiting for their answer by Friday May 19, 2006. She stated she would advise me of the answer. ****************************NARRA ************************** NA Reported By: 6/05/06 EFTA00231770 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 86 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) Entered By.: 6/06/06 On Mail" 2006, I received several phone calls throughout the day from , who rd he had been followed aggressively by a private investigator. stated that as he drove to and from work and running errands throughout the county, the same vehicle was behind him • other vehicles off the road in an attempt not to lose sight of vehicle. I explained to him as Mr. Epstein had retained new legal council it was possible it would be new private investigators following him to observe his daily activities. i also explained to him that there was a meeting scheduled with ASA Lana Belohlavek and Attorney Jack Goldberger at Mr. Krischer's office scheduled on June 1, 2006 at 9:0O am. I attempted to call ASA Lana.aalphlavek to inform her of the private investigators following however; she was on her vacation during the week of May 22 through May 30 2006. On May 23, 2006, I received other phone calls from Mr. and who advised they were able to acquire the private investigators license plate information. The t following them was ag iving very aggressively and caused to run off the road. the vehicle is a green Chevy Monte Carlo bearing Florida tag The vehicle is registered to Zachary Bechard of Jupiter Florida. Bechard is employed with Candor Investigations from Jupiter, Florida. Bechard is a licensed Private Investigator in the State of Florida. Since the diAcovery of the threat made against one of the victims in this case (IM subpoenas for all calls made to and received from during the month of M her and home phone. I had confirmed with the exact dates of Spring Break for 2006. The Spring Break was from March 4, 2006 through March 12, 2006. I received a subpoena from Sprint/Nextel with all calls made during the month of March 2006. I reviewed the 989 calls made and received during the month of March 2006. I observed on March 7, 2006, made and received thirty five calls during that day. Date 7-Mar-06 Time 11:03 AM Seconds 492 In/Out Outbound To/From 561XXXX 7-Mar-06 11:16 AM 6 Inbound 561= -Mar-06 11:22 AM 887.2 Inbound 561XXXX Mar-06 11:37 AM 48 Outbound lar-06 11:39 AM 28.2 Inbound ar-06 12:02 PM 727.2 inbound table reflects the date of the calls, time of day (EST), duration EFTA00231771 Date: 19,19: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 87 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) of ca econds, inbound or outbound calls and ca ade to or from p e. On March 7, 2006, at 11:03 am, made a call to the victim which lasted 492 seconds (8 minutes and 2 seconds). The victim then returned the call a-16 am which lasted 6 seconds. The victim then made contact with at 11:22 am for 877.2 seconds (14 minutes and 6 seconds). These sequences of calls were consistent with what the victim had described to me on the date of the intimidati • tely after speaking with the victim, makes a call to , Epstein's assistant, which lasts for forty-eight secon s. A call is then immediately received, a telephone number registered to a Corporation affiliated with Jeffrey Epstein located at 457 Madison Ave in New York. An extensive computer check revealed 457 Madison Ave is a business address in which Epstein has his corporations assigned to. Epstein had corporation attorney, Darren Indyke, register the businesses and register himself as an agent. I also observed Epstein has his El Zorro Ranch Corporation, New York Strategy Group, Ghislaine Corporation, J Epstein and Company and the Financial Strategy Group regigLaLgd to this same address. Finally, a third call is received by at 12:02 pm from the same corporate number which lasts 12 minutes and 1 second. It should be noted that there is no further contact with either the victim during the month of March or April of 2006. I also noted that there was no NA further contact with remainder of the mont or Jeffrey Epstein during the Marc or April 2006. On June 1, 2006, ASA Lana Belohlavek telephoned me to inform me of the meeting that occurred with Atty. Jack Goldberger and her reference this case. She advised she would make her determination on whether to file on this case or not by Monday June 5, 2006. Inv Continues. lilt ****************************NARRA ************************** Reported By: 7/12/06 Entered By.: 7/12/06 On June 29, 2006, I had spoken to ASA Lana Belohlavic who informed me that the case would be sent to the Grand Jury for charges. She informed me that the grand jury would convene on July 19, 2006 to hear the Epstein case. Belohlavic stated State Attorney Barry Krisher made the determination to go the Grand Jury to hear the case. On July 12, 2006, I spoke with , mother -ct the victlm,-II, who inquired about the status of the case. I explained to her that I was told we would be going to the Grand Jury during the week of July 19, 2006. She stated she had not been contacted as of yet by the State Attorney's Office for any information. I provided her with the telephone numbers to the State Attorney's Office. Investigation continues... * * * * * * * * * * * * * * * * END OF REPORT * * * * * * * * * * * * * * * * * EFTA00231772 LM BEACH/ ALICE DEPARTM PROPERTY RECEIPT "APO Form 05.1 CONTRIBUTORS COPY ..1 PROPERTY CI FOUND CI DECEASED (Probated) CI PERSONAL CI CONFISCATED la DESTROY -3( EVIDENCE 0 mutt 0 LABORATORY 0 STOLEN/RECOVERED ROTHER INCIDENT/CITATION NUMBER 0.7- 7:4_44€)€?.. DATFJMIE RECOVERED 01t0H- it- , PROPERTY NUMBER (Leave Blank) cc - ,9 7 - 1 BIN NUMBER (Leave BUM) (- ;- I 1±- 1 ION qp E NUM R PHONE NUMBER P . ADDTNL SUSPECT 10.0.8. . ADDRESS Street City ZIP PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM 0 90 DAYS NOT CLAIM 0 ITEMS • QUANTITY VALUE . DESCRIPTION • i I fe r Aci.' I% tc omOEY csItiosa ... ii .F 4,. i.kitirii ,: ‘,4T ?•:E. C. cc i t i (17 1: ' ,k ft • . ... v. ..7 ..„, t \ )* • \ ' .... • TOTAL PACKAGE WEIGHT I hereby admowledge that the above gat represehts all property taken from me and Ihat I have receive:leo:9y of his receipt. I hereby acknowledge that the above list represents all property Impounded by me In the official performance of my duty as Max --4 A '4Ct---121.1_____. . SIGNATURE ,.. DATE SIGNATURE 1 IDS UNfT ' RECEIVED BY REASON' . k. I DATE/TIME RECEIVED .7, ..1 .. ' E .. () 7'. l'' . C . e 7 , c. te -- I 0 . EFTA00231773 ') LM BEACH POLICE DEPARTMFCJ PROPERTY RECEIPT DETECTIVE. BUREAU • PSPD Form .052 1/ PROPERTY U FOUND Q DECEASED (Probated) U PERSONAL 0 CONFISCATED U DESTROY 4 EVIDENCE U TRIAL U LABORATORY U STOLENARECOVERED 0 OTHER INCIDENT/CITATION NUMBER 05- r - ' DATE/TIME RECOVERED PROPERTY NUMBER (Leave Blank) BIN NUMBER (Leave Blank) -/ , - r treef rry PH NE NUMBER OWNEEPS:NAME/ D.O.B. St 1 SIM Siiimasin PHONE NUMBER ADDT'NL. SUSPECT/ D.O.B. ADDRESS Street City Zip PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM U 90 DAYS NOT CLAIM .a.) - ITEM 0 QUANTITY VALUE I 1 (\flr.1)C.; p r) ; TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents an property taken from me and that I have received a copy of this receipt. I hereby acknowledge that the above lilt represents all property impounded ante of my duty as a police officer. 1 - SIGNATURE DATE SIGNATURE IDOt UNIT RECEIVED BY REASON DATE/TIME RECEIVED . /i \,.• 7 "?)' , ; q EFTA00231774 OLMSEACII-POLICE DEPARTM • PROPERTY RECEIPT CONTRIBUTOR'S COPY POPO Form ira - 2 -.PROPERTY O FOUND DECEAS (Probated) O PERSONAL O CONFISCATED a DESTROY IDENCE O TRIAL CI LABORATORY O STOLEN/RECOVERED O OTHER INCIDENT/CIT TION NUMBER DATE/1111E RECOVERED PROPERTY NUMBER (Leave Monk) , ..- ,..... BIN NUMBER (Lireve BIN* 11 PHONE NUMBER city W s' 2 041 'IPFroe, y G. t}fr.-A-4:,,i ka. 14 Ciry 43 PHONE NUMBER ;-)Z,41 et_ .:til c . 3f .' ( 1;,..i, ,k...' ADDTNL SUSPECT/ D.O.B. HONE NUMBER OUND PROPERTY CLAIM ID 90 DAYS NOT CLAIM O ITEM a QUANTITY VALUE I I WI IC i j 1 A cr.= - LIAtti,•II Yj TOTAL PACKAGE WEIGHT I hereby aclatowledge that the above 1st represents all property taken train me and that I have received a copy of this receipt. I hereby acknowledge that the above list represents all property b me in the official edomtance of my duty as a police officer. di ::`t Impounded b SIGNATURE DATE IDS UNIT RECEIVED BY REASON S, j DATE/TIME RECEIVED , , EFTA00231775 -siBiliWaSgSsanstashemi ELM BEACH POLICE DEPARTME / ;i1Crr PROPERTY RECEIPT PBPD Form 1052 r ) PROPERTY Cl. FOUND 0 DECEASED (Probated) la PERSONAL 3 CONFISCATED ca DESTROY r CIsEVIDENCE Ittul(RIAL 1.11 LABORATORY :-..I STOLEN/FIECOVERE0 fa OTHER I DENTiCITATION NUMBER 05-36i DATE/TIME 031%Ics RECOVERED ii 1. Q ,---‘, i4: PROPERTY NUMBER (Leave Blank) - D c -- BIN NUMBER (Leave Blank) i ? '2 L i (.7 ,. DI • : is : • • B. I ADDRESS Street City Zip PHONE NUMBER • a a 4:0/41.1.1314114* r.. , ADDRESS Street C. 2 PHONE NUMBER • - • . • • • : I ecctu6 eirtied.i 42015 A D E Poet ty Zecr 2,5g G.L 92,u3 Pt FL 33 (IST PH NE NUMB ADDT-NL. SUVECT/ D.O.B. ADDRESS Street Crrj 250 PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY J :TEM 0 . OUP I 4 F. i D SePlf ION • -.. . . . . , . .. . . . . '<el 6, .I C 1. ' A I . _ . 4., I .-------- i . . . • „ . r . . .• • . 4" . . . -- U i1L TOTAL PACKAGE WEIGHT I hereby acknowledge that the above 1st represents all property taken from me and that I have received a copy of this receipt SIGNATURE DATE I hereby acknowledge that the above list represents all property impounded Vs of my duty as a police officer. EPYI DI_ NATURE IDE UNIT RECEIVED BY REASON DATE/TIME RECEIVED DETECTIVE BUREAU EFTA00231776 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT 0 Form 152 immigumen EVIDENCE GUS I Minn o PROPERTY U FOUND U DECEASED (Probated) CI PERSONAL U CONFISCATED 0 DESTROY )ifEVIDENCE ATRIAL 0 LABORATORY U STOLEN/RECOVERED U OTHER INCIDENT/CITATION NUMBER 053& 14i; DATE/TIME RECOVERED 03300s 4:co I'M PROPERTY NUMBER On Blank) O S - ail BIN NUMBER (Leave erne e /21 IS-7 • . ca)51 PHONE NUMBER • PHONE NUMBER ADDTNL SUSPECT/ D.O.B. ADDRESS Street City Zip PHONE NUMBER SPECIAL NSTRUCRONS FOUND PROPERTY CLAIM Cl 90 DAYS NOT CLAIM 0 ITEM • QUANTITY VALUE DESCRIPTION I I thlDio TA.PE" MA/ELL" coNneckt_ e_Ati 4t2- 6-8 2— I MI-4-o TA-PC￾77 4 ilok -W a_ -is b k_- TOTAL PACKAGE WEIGHT I hereby acknowledge that the above let represents al property taken from me and that I have received a copy of this receipt. I hereby acknowledge that the above Est represents all property impounded by In the of my duly as a police officer. ri051 of Slr"ATURE DATE SI IN UNIT RECEIVED BY REASON DATE/TIME RECEIVED 3 , 7 67 0 9 . 3( ..0 S - 6956 IIS TOSS 11/1/4-kieSb or o 2 o 5- boo.6 0 tAnIA\94,:c --K0-0-rc rc 0 73 , 'eti ay 4Fe gimp_ 0 9-2* -or /94/S ...h S7, 7 fl -O$ 1U-5,4 EFTA00231777 eireaierim, voisei,se•v.....vn.-V7.17flOrasmin 11/64-1-••• . fl an( NV • *ITT‘FTraliltkta-71.CRI(Mr—ATratES51* P. '0 Farn s52 -I PROPERTY U FOUND Q DECEASED (Probated) 0 PERSONAL CI CONFISCATED 0 DESTROY ,EViDENCE RIAL DI LABORATORY Li STOLEN/RECOVERED U OTHER INCIDENT/CITATIONNUMBER OS - .172AC)P DATFJTIME m I RECOVERED L)•1 ?Or PROPERTY NUMBER (Leave Santo 05 - ''.:`,„;V ia BIN NUMBER (Leave VWSVI LI Blank) C ADDRESS WHERE PROPERTY IMPOUNDED DI O O B ADDRESS Street Cry Zp PHONE NUMBER • • : OD: • I ' • ... ; ' 0 • ; • 0 HE SS Street C Z. I PHONE NUMBER FOUND PROPERTY C.A0.4 ij ne C AY S NOT CI AIM j i r".1 Q.JAN ITV V E i .14/ .. _ b '• , Q.ESCRIPT10N 'e CO T a SI ):.ova 0,:v (..,, ry. I , ii.: . ' • u a 1 a .• a. ' Lijia.la ciI II' ) V -L. '.. • . 'a 4l7 if)r ! ...-- ... a Qt.. IL > , - - TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents all property taken from me and that I have received a copy of this receipt I hereby acknowledge that the above list represents all property impounded by me in the official performance of my duty as a police officer. SIGNATURE DATE SIGNATURE IDN UNIT REC: REASON DATE/TIME RECEIVED — 1- C- J q- C, 5 //),... r t .) r )LM BEACH POLICE DEPARTML PROPERTY RECEIPT DETECTIVE BUREAU EFTA00231778 ELM BEACH POLICE DEPARTMENrI PROPERTY RECEIPT DETECTIVE BUREAU POPO Form V52 I PROPERTY FOUND 3 DECEASED (Prcbatea) J PERSONAL CONFISCATED U DESTROY I‘IP EVIDENCE INCIDENT/CITATION NUMBER TRIAL J .LABORATORY STOLEN(RECOVERED OTHER • 7;‘• DATE/TIME RECOVERED ADDRESS WHERE PROPERTY IMPOUNDE c*) OlciTt\VS 7'/'" PROPERTY NUMBER (Leave Blank r _ DISC Street City Zep, OWNERS NAME / 0.0 B .SUSPECTS NAME/DOB E P.;1. ADDrNL. SUSPECT/ D.O.B. E ,ODANTITY•• ADDRESS ADDRESS Street City ADDRESS ADDRESS Street Street I Mareby acknowledge that the abo e list represents all property taken from Ole and that I have received a copy al Ibis receipt. TOTAL PACKAGE WEIGHT SIGNATURE DATE RECEIVED BY Cay iy SPECIAL INSTRUCTIONS BIN NUMBER (Leave ELvio PHONE NUMBER PHONE NUMBER PHONE NUMBER PHONE NUMBER FOUND PROPERTY cLA ADY,c1Alta: .; hereby acknowledge that the above list represents all property impounded b mein the official }°derma Ce of ny duty as a police &Seer. IDx UNIT .DATE/TIME RECEIVED EFTA00231779 artersorYnr• LM BEACH POLICE DEPARTME0 PROPERTY RECEIPT 0"' OD Pun .52 ,J PROPERTY 1 U FOUND U DECEASED (Probated) J PERSONAL j CONFISCATED U DESTROY a EVIDENCE 'Ewi TRIAL CI LABORATORY U STOLEN/RECOVERED 0 OTHER INCIDENTCITATION NUMBER DATFJTIME RECOVERED .CCI' 0 - 05- PROPERTY NUMBER (Leave !lank) ._ r 5- 3 -71 IBIN NUMBER (Leave Bank) /";)R -5 5-- ..- ADDRESS WHERE PROPERTY IMPOUNDED 7- , : _./. ..-- t e e, e • , I "1 ( ; CI 'DISCO :,1) i.. ADDRESS Sires✓ Cy 20 PHONE NUMBER OWNE ADDRESS Street Cie 4 , PHONE NUMBER SUSPECT'S NAME/ D.O.B I•^ U• '-_j ' :, •:: .N.1) )(t, ( r.': L.( y ADDRESS Street CM 4, .--• r PHONE.NUMBER ADDTNL. SUSPECT/ D.O.B. ADDRESS Street Cali Lp PHONE NUMBER -CAL INSTRUCTIONS FOUND PROPER ry : CLAIM 3. '-'W12'? '-:-•:, :Ncir:6 -Alla; - I Q • f JF b .c 4O41-ica 4 - .• . ' • ::s.,..t. ? y •• --1 TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents all property taken horn me and that I have received a copy or this receipt. I hereby acknowledge that the above list represents all property Impounded by me in the oflic4I performance of my duty as a police officer. . l ' 7 . . _ • ! ,1. r eh l I I LAI l V ., i \ -- SIGNATURE DATE _ . . SIGNATURE !Dot UNIT RECEIVED BY REASON DATEMNIE RECEIVED DETECTIVE BUREAU EFTA00231780 • Ir.. 9LM BEACH POLICE DEPARTMENT? PROPERTY RECEIPT PRP° Fenn $52 J PROPERTY FOUND 0 DECEASED (Probated) U PERSONAL 0 CONFISCATED irj DESTROY 10 EVIDENCE la TRIAL Li LABORATORY CI STOLEMRECOVERED a OTHER INCIDENT/CITATION NJMBER DATE/TIME RECOVERED PROPERTY NUMBER (Leave Prank) IBIN NUMBER (Leave B'are) _r; .. t ..— ADDRESS WHERE PROPERTY IMPOUNDED DISC O.B. ADDRESS Street City Zip PHONE NUMBER OWN O.B. ADDRESS Street Cey. Zas -.kJ PHONE NUMBER SUSPECTS NAME / D.0 B. ADDRESS SRO'S! Cory ID PHONE NUMBER ADOT'NL. SUSPECT/ 0.0 8 ADDRESS Street City ZP PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY Cr AIM -..1 00 DAYS NOT CLAM, ...1, ' , ITEM g OJAN7 'Y '/AWE • CRSCq1P,T;Ol a ul ' t ? : 1' • • -.. It '•''' :;,;.:>i: 1 . et. .filsc St( lac.4 .„„ --- •-•., t i yr, C r1St : 4 " 1"*.W.t15' 't * , 71u 5?11 : t. .. - ..... .. ,,4 . ..m?4 ...• • , _ • .,_ . . _ . . , . 1 t-- _, 7 -- - TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents all property taken from me and that I have received a copy of this receipt. - _ SIGNATURE DATE I horeby acknowledge that the above list represents all property impounded by mo in the official performance al my duty as a police officer. 1 SIGNATURE ID*. UNIT RECEIVED BY REASON DATE/TIME RECEIVED , _ —r , • : /-•• •c• r; - , , f— DETECTIVE BUREAU EFTA00231781 --)LM BEACH POLICE DEPARTMET) PROPERTY RECEIPT '1—; ( E-TECTIVE BUREAU PSPD Frrn 052 PROPERTY U FOUND 0 DECEASED (Probated) 0 PERSONAL U CONFISCATED U DESTROY \tpe EVIDENCE 1 ki TRIAL 0 LABORATORY .3 STOLENRECOVEFIED U OTHER INCIDENT/CITATION NUMBER GATE TIME RECOVERED PROPERTY NUMBER (Leave Blank) i BIN NUMBER (Leave Stank) -, c?-- ADDRESS WHERE PROPERTY IMPOUNDED 7- 5 ic: .:E L `..- :. I • /.. ., a / D.0. B. ” • - c (X:1 1 ADDRESS Street City Zip PHONE NUMBER t 0 O.O.B. ADDRESS Street City Zip PHONE NUMBER SUSPECT'S NAME / D.O.B c I . 2 0. c , Ece...Tt I ;\ t j .... i r i... ,4 c yd. 1 ADDRESS Street City Op ,,,I ,... C PHONE NUMBER ADDrNL SUSPECT/ D.O.S. ADDRESS Street City Zip PHONE NUMBER SPECIAL INSTRUCTIONS I) A tr\ i , .2-- FOUND PROPERTY CLAIM is BO DAYS NOT CLAIM j TEM ti QUANTITY I VALUE DESCRIPTION .., • I I I • In 4 t 01 `,.f ,i` .).e :',:,Z' i , ' •". 1'4\ 0* :) . . . 4 131v t faLe. 1., , 1 _ _ t. , i i. • :i- i')i--, F; — • -I- T i I , I . `II ' I F . I i i i Z-t -- ,C---:+1 C,( c. 1 $ h t1 I 1 ii&lmt_idC, 14/Int,_, 3- I b 0 L. 4, L., - /L 'U3 . i • ic ) • 1 I 1 (.i"!-:)-Z Of TOTAL PACKAGE WEIG I hereby acknowledge that the abovo list represents all property taken from me and that I have received a copy of this receipt I hereby acknowledge that the above list represents all property impounded by me in the ollicial performance of my duty as a police officer. - _ SIGNATURE DATE SI I Da UNIT RECEIVED BY REASON DATErTIME RECEIVED EFTA00231782 TIM BEACH POLICE DEPARTMEIN) PROPERTY RECEIPT DETECTIVE BUREAU PBPD Form it2 .1 PROPERTY D FOUND Q DECEASED (Probated) j PERSONAL 0 CONFISCATED Q DESTROY cd EVIDENCE ITRIAL J LABORATORY U STOLEN:RECOVERED i OTHER INCIDENT/CITATION NUMBER DATE/TIME RECOVERED PROPERTY NUMBER (Leave 81 ant) . K y. BIN NUMBER (Lea LP k) ADDRESS WHERE PROPERTY IMPOUNDED - 3T? EA C....H.t:.' I ,.. i DISCO 8 ?act) ADDRESS Street Crty Zp PHONE NUMBER OWNS B ADDRESS Street City Z.p PHONE NUMBER SUSPECTS NAME: 0 0 8 ADDRESS Street City Zp PHONE NUMBER AODTNL SUSPECT/0 0 8 ADDRESS Street City Zip PHONE NUMBER SPE CiAl INSTRUCTIONS : ..: FOUND.PROPERTY CLAIM j" : . . . . . - 90 DAYS, . NOT:CLAINfj..:t r( .1 t; I ' I `I' Al . DESCRIPTION kY iItt, , ..W? -,..' ' C(1 to , ( / i l te . ril _,, F 5#77)3oisit‘iii: k• t (r ! •,.)ii,.; kW, k!,) 4. :‘.. ; N M 1 kRti ‘tra . % ix ".` r"t!, _, 4,./. 4, ... • 4. e. , I ') . . . / 17 1 ... ,. . e — Ai r .0. IC.? it • r • ,. -_-- --------- r• . ''' ,•71 c--- " 1 . TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents all property taken 1 I hereby acknowledge that the above fist represents all property impounded from me and that I hmo received a copy of this receipt of my duty as a police offic0f. i ...____,_ SIGNATURE DATE ID# UNIT . .. RECEIVED BY - REASON ii DATE/TIME RECEIVED -15 c 7),C -e- 2 r.) I. Ccr O76 c . EFTA00231783 .p.e. erenrr: 37S,./a1WrednagreCart Areetrar;rrvcCril.tOgarancortnepteckt ThLM BEACH POLICE DEPARTMEr ) PROPERTY RECEIPT PeP0 Form IS2 1 PROPERTY 0 FOUND U DECEASED (Probated) 0 PERSONAL U CONFISCATED U DESTROY {:i EVIDENCE U TRIAL U LABORATORY U STOLEN/RECOVERED U OTHER INCIDENTiCITATION NUMBER . .- DATE/TIME RECOVERED -I NI C FPS !PROPERTY NUMBER (Leave &ark) - r 9 t y 0, ti — . ‘ ' BIN NUMBER (Leave Blank) e 1. l.' c - — a -- ADDRESS WHERE PROPERTY IMPOUNDED Di O.O B. . ' • I • .. /. I I ADDRESS Street City , Zip PHONE NUMBER OWNER'S NAME / D.O.B. ADDRESS Street City Zip PHONE NUMBER SUSPECT'S NAME/ D.O.B. , 3 e. . „. it, i, I .)," r• le et ! . ,,,-, ADDRESS Street City Zip I. •}-i: .. . PHONE NUMBER ADDTNL. SUSPECT/ D.O 8. i ADDRESS Slf0Of . City 2,0 PHONE NUMBER SPECIAL INSTRUCTIONS FOLD° ?RC PEP—. Cti0.r j A; DAYS Nor g ..A RI j .ITEM a `QUANTITY . VALUE. DESCAPTION . Ir. : •• -2,_ I . . 1,, Li. ., L €.c,:_-_' • ! I r ., jp. ,, - - ... : ,•• 5 -_. L- ....--4 "-: _ ' • . ._ - -11 . ''' ' . '--) I • . _. ...._ _ i - - ..- r•T' ,. 4:1,->il TOTAL PACKAGE WEIGHT I hereby acknowledge that the atio. o list represents all property taken from me and that I have received a copy of Ihisrocelpt. I hereby acknowledge that b me in the official rformance tho above list represents all property impounded of my duty as a police officer. t . ) el r ) / SIGNATURE DATE . ID.; UNIT RECEIVED BY REASON ' DATE/TIME RECEIVED " —775 k 7 eS c)//--4- o 4 6 7 " L DETECTIVE BUREAU EFTA00231784 iCtI9er nada51 r. till 10X“: '"L-,717SSoStfoira3rIStIelaSA Vtti!rre, .iirrar"" --)LM BEACH POLICE DEPARTMEn PROPERTY RECEIPT F"00 Form .52 J PROPERTY FOUND DECEASED (Probarad) D PERSONAL aCONFISCATED L/ DESTROY )71 EVIDENCE 0 TRIAL j LABORATORY LI STOLENRECOVERED ra OTHER INCIDENT/CITATION NUMBER DS- 3 Lg DATE/TIME RECOVERED 0 LI f II jo .-_, u PROPERTY NUMBER (Leave Blank) - c_ 7 72 •BIN NUMBER (Leave Blank) 1 7 gC52_ ADDRESS WHERE PROPERTY IMPOUNDED -'1'.‘;:r .i.. & I., ILK`.. i l' DI SC D.O.B. ?in 1 • ADDRESS Sayer Day Zip PHO E NUMBER OW N IN ADDRESS Street Cry Zip PHONE NUMBER SUSPECTS NAME / D.O.B. , ADDRESS Street City • Z'p ( PHONE NUMBER ADDT'NL. SUSPECT / D.O.B. ADDRESS Street City Zp PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPURTY GL al'. j 2CD;Wec NOT c: w./ i.j.. : II.`. 0— . OF CR:irII:CN - , _.-1._ I i I t I i. — TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents all property taken I r k e eve list represents all property impounded from me and that I have received a copy of this reCeipt f my duty as a policeofficer. 0 f SIGNATURE DATE IDu UNIT RECEIVED BY REASON -- DATE/TIME RECEIVED Ph C. 7,?G, .:;/-,, C DETECTIVE BUREAU EFTA00231785 --)LM BEACH POLICE DEPARTME, _ PROPERTY RECEIPT DETECTIVE BUREAU POPO Font 052 I n J PROPERTY 0 FOUND U DECEASED (Probated) U PERSONAL D CONFISCATED 0 DESTROY cli EVIDENCE D TRIAL D LABORATORY 0 STOLENiRECOVERED U OTHER INCIDENT/CITATION NUMBER L I _2.2!. DATFJITME CY! 1); 1 RECOVERED or c el/7) PROPERTY NUMBER (Leave Blank) r• C -- -7? ;:: (1 BIN NUMBER (Leave Blank) / 155 O2._ ADDRESS WHERE PROPERTY IMPOUNDED Sit / 0.0 8 ?Ir. I ADDRESS Street Ciry Zip PHONE NUMBER 0 / 00.8. ADDRESS Street Oty Ifip PHONE NUMBER SUSPECT'S NAME / D 0 El ADDRESS Street Crty Zip PHONE NUMBER ADDTNL SUSPECT/ D 0 B ' ADDRESS SIMS! City Zip PHONE NUMBER SPECIAL INSTRUCTIONS :1. •.n rPc)1q Rci C_,A.,‘,1 :_l DAY'; •.;07. CI AR,`.-_I ,FEM ..-, li. AN rlTY 1 .,A_'.-E ; DE:SC:WT.0% ; , L — ______ . . - — _ 7 - - i __Cq.-7. .:1:;)6e, t_rQ —i-h• . TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents all property taken Born me and that I have received a copy of this receipt. I hereby acknowledge that the above list represents all property impounded by me in the official performance of my duty as a police officer. --, I SIGNATURE DATE IGNATURE i Da UNIT RECEIVED BY REASON DATEfTIME RECEIVED — • t• . ,c 7 7 / E. 0-7/ - .,)/ /c c) —roc. / EFTA00231786 rre '..PricCibcv 'ThLM BEACH POLICE DEPARTME9 PROPERTY RECEIPT PBPO Form *52 3 PROPERTY 3 FOUND 0 DECEASED (Probated) 0 PERSONAL 3 CONFISCATED 0 DESTROY 54 EVIDENCE 1 -TRIAL 0 LABORATORY U STOLEN/RECOVERED 0 OTHER INCIDENT/CITATION NUMBER 5 - , ,: -,<• DATE/TIME .,' ,41 . -_, 105 RECOVERED mrs PROPERTY NUMBER (Leave Blau) . r .... -7, t•--- ,c- , , -)," BIN NUMBER 1 (Leave Blank) ADDRESS WHERE PROPERTY IMPOUNDED ..., DIS Or r-, ADDRESS Shoot City 29, PHONE NUMBER OW . ADDRESS Street City ZP PHONE NUMBER SUSPECT'S NAME / 0 0 B i t: 1.1. T - . r r ir (tit • ADDRESS Street Cay 79 --,:• •i--e PHONE NUMBER ADDTNL. SUSP CT / DO B ADDRESS Street CO ZIP PHONE NUMBER SPECIAL (Mk INSTRUCTIONS FOUND PROPERTY CLAW 0 c r 40 0,w5 NOT MU ITEM Il 0..AN Ti 'v VALUE r DESG,RIPT,ON , 4- -- . A / p 0 — I j ),./__ Li. 1 :C,q... L.,("ti, • ,.. i_ _ _______ $ • i __i___ - . ---1 • TOTAL PACKAGE WEIGHT I hereby acknowledge that the abo e list represents all property taken from me and that I have recorvod a copy of this receipt, I hereby acknowledge that the above list represents all property impounded by me in the official performance of my duty as a police officer. , _ __ (r I i 1 . SIGNATURE 1 - ' . SIGNATURE DATE lot UNIT RECEIVED BY REASON \-7 DATE/TIME RECEIVED ; . 7 7, f 6 7 6 41-tr.v- t, r 6 7c.c, e) ... . . . .. DETECTIVE BUREAU EFTA00231787 • --)LM BEACH POLICE DEPARTMET) PROPERTY RECEIPT DETECTIVE BUREAU PBPD Fern 952 1 PROPERTY LI FOUND U DECEASED (Probated) FLI PERSONAL J CONFISCATED Cl DESTROY A EVIDENCE ‘21 TRIAL CI LABORATORY D STOLEN/RECOVERED Cli OTHER INCIDENT/CITATION NUMBER ‘... ,, DATE/TIME RECOVERED 04licitri (.•.(1 i<7 PROPERTY NUMBER (Leave Wank) ,/,. )_-_, e &.' BIN NUMBER (Leave Bin) r"'" • , /Th ADDRESS WHERE PROPERTY IMPOUNDED • DISC B. To, ' r ADDRESS Street PHONE NUMBER OWN ADDRESS Strout Cry Zip PHONE NUMBER ----.. SUSPECTS NAME/DOB i ; • Ii . - - A:" it,,, :)1-: ).1 ADDRESS Streer Cry Zip , PHONE NUMBER ADDTNL. SUSPECT/ D 0 8 ADDRESS Street City Zp PHONE NUMBER SPECIAL INSTRUCTIONS . FOUND P ROPE REY CLEM') J .O DAYS NOT c..Ary J ITEP. O'JAN'.ITY V iLUE DESCR PT ON -L. rill • • 5 I * VI,' if117 a in,c't i INIticita- 1.i.ci 2.7. ( . 0 it; tH ,i4, b . rel ;d:M., - - ) L I)C. .. , ) I . 2,1 f 4/7 ••••••• TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents at property taken from me and that I have received a copy of this receipt. I hereby acknowledge that the above Lst represents all properly impounded b me in the Official enonnance of my duty as a poece officer. 4):,-,q Dt SIGNATURE. I SIGNATURE DATE IDs UNIT RECEIVED BY REASON DATE/TIME RECEIVED r .#: iQt.'?..;4";4iici 4 -a• . EFTA00231788 --)LM BEACH POLICE DEPARTME9 PROPERTY RECEIPT DETECTIVE BUREAU PBPD Fern 152 PROPERTY a FOUND a DECEASED (Proeatec) CI PERSONAL )(CONFISCATED CI DESTROY J EVIDENCE U TRIAL U LABORATORY GI STOLEN/RECOVERED U OTHER INCIDENT/CITATION NUMBER DATE/TIME RECOVERED Lit:vit:I - , 4 PROPERTY NUMBER (Leave Blank) r .s - < BIN NUMBER (Leave Dank) r a q c a ) ADDRESS WHERE PROPERTY IMPOUNDED _.1-.3 4 E. I. Cii, , i i .• ' / - ( DISC O.B. ADDRESS Street City /42 PHONE NUMBER OWNER'S,NAME i D.0 B. ADDRESS Street Cry Zq PHONE NUMBER SUSPECT'S NAME /0 OR I. t. i ADDRESS Street City Zip PHONE NUMBER ADDTNL. SUSPECT / D.O. B ADDRESS Street Cay Zo7 PHONE NUMBER SPECIAL INSTRuchoys f hof j N o N.1.1' he, - (,)Ntiv I FOUND PROPERTY CI.All.' J 93 DAYS NOT CLAIM.. `ITEM QUANTITY VALUE DEL(. ICY' 5 1 ''''' ' ♦Ce".i, ' .A.e . .” E: ., ,... . ..,-.-- ,-... . . PT TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents a property taken from me and that I have received a copy of this receipt. I hereby acknowledge that the above list represents all property impounded ante of my duty as a police officer. SIGNATURE DATE IDA UNIT RECEIVED BY REASON DATE/TIME RECEIVED .)'19 i ., -7 -, r // i' 1 EFTA00231789 .ThLM BEACH POLICE DEPARTMO PROPERTY RECEIPT DETECTIVE BUREAU PBPD Form itc2 3 PROPERTY CI FOUND 0 DECEASED (Probated) a PERSONAL Di CONFISCATED 0 DESTROY >4 EVIDENCE 2 TRIAL 0 LABORATORY U STOLENJRECOVERED 0 OTHER INCIDENT/CITATION NUMBER 5 - 3 S DATFJTIME RECOVERED X12 ( ( .er) 1 3) ." PROPERTY NUMBER r"save Blank) r - ,... ,.•. , td r -, f BIN NUMBER (Leave Blank) :::: / / ( ADDRESS WHERE PROPERTY IMPOUNDED , --?..) ‘ 4 • cs -7-3 . C. c c.,.—3 I4. t' . 0 A f 7) V I. ,1 - A{ t : DISCOVE ADDRESS 7. ' . Street Oily • a> PHONE NUMBER OWNER'S. . . . . ADDRESS Street Crty Zip PHONE NUMBER SUSPECTS NAME: 0 O.B. k t4/.I4 -5 1:: 1 - cc' 7-, - L s.r) )'-- ,'. ( c7 ,•-: ADDRESS Street - c dV Zip .'..„ PHONE NUMBER ADDVNL SUSPECT 1 D.0.8 ADDRESS Street City 7.47 PHONE NUMBER SPECIAL INSTRUCTIONS i CH `,:.:" %nnprmy 0 A 'A _1 it TEIM CHANT fv IA i- it k. -. — ....- _ TOTAL PACKAGE WEIGHT i hereby acknowledge mat the aboi o • st represents all property taken tram mo and that I have received a copy of this reed,Pl. t-- - _ . I hereby acknowledge that by mo in the official performance the above list represents all property Impounded of my duly as a poke officer. 1 i t - tve /__ .._ SIGNATURE DATE _ SI __ ID4 UNIT RECEIVED BY REASO DATE/TIME RECEIVED C CI 1., )• ..' 3 -7 . 7 _ / / - 6". 7 e../OC l , ri , i !? EFTA00231790 IMIOUSC*CitXUCtilwitevesriA PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT DETECTIVE BUREAU PBPD Form .52 Ti PROPERTY U FOUND D DECEASED (Probated) UI PERSONAL D CONFISCATED a DESTROY A,EViDENOE ATRIAL U LABORATORY rU STOLEN/RECOVERED U OTHER INCIDENT/CITATION NUMBER CD .))(&)________Cfrt DATE/T1ME RECOVE ED ..- k 030 PROPERTY NUMBER (Leave Bianiii) 05 - Ccrt' itS BIN NUMBER (Leave n C04 1 Blank) ADD.9.7KIE PROPERTYCMDEl ta iki I 1( -_ . ADDRESS Q 647 CilV Zip PHONE NUMBER ADDRESS Street City Zy PHONE NUMBER SUSPECTS NAME /D.0.8. t. c. I N ) I , ) 72: ADDRESS Street City Zip PHONE NUMBER ADDTNL. SUSPECT /6.0.8 . ADDRESS Street City Z./P PHONE NUMBER SPECIAL INSTRUCTIONS .1 n '1 A Lc 0 S :RIP ;ON • - •- . - - . : . .. . 'n' ' klif. -.;et si . I -.' " • . I \12 ,' ,,,o• , ) c . ,,,, rl .,,ite,k-,.,. A .. . __ _____ ___________ _____ ..._._._._ _________ . _ . • • _.. TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents all property taken from mo and that i have received a copy of this receipt. I hereby acknowledge that the above list represents all property impounded me in the official ponormance of my duty as a poll - ce officer. v, 6 i \ 02 -- SIGNATURE -- DATE IDO UNIT REASON DATE/TIME RECEIVED p ---O 7i ---C.: -t-azss - c>, j(,„3-) EFTA00231791 -'^--Iistlesaffilra;a0fir-Cfaam4;z4PerarrawrytarrisaArri- - en PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT DETECTIVE BUREAU PRPD Farm y52 1 PROPERTY 0 FOUND 0 DECEASED (Probated) U PERSONAL 0 CONFISCATED 0 DESTROY SEVIDENCE XTRrAL 0 LABORATORY STOLEN/RECOVERED U OTHER INCIDENT/CITATION NUMBER 05 . 3“;) DATE/TIME RECOVERED O? 2705" to•o PROPERTY NUMBER (Leave Blank) BIN NUMBER (Leave Blank) /` t7 2' ( ,-. , ADDRESS 14 -5 WHERE PROPE RC `IMPOUNDED Y --S E• AC ti \ V 5 , r-NA W 6 .W ya o Aes.i..) DISCOVERE OFT. ADDRESS Street City ZP S7(b 0 0 HONE NUMBER OWNER'S N ADDRESS Sue& City 47 PHONE NUMBER SUSPECTS NAME / Dp) L (0170`; C.:.1 1 - 1 ' , 3 pc￾ADDRESS Speer City .20 5-cip cup,o i Ito 927 PHONE NUMBER ADOTNL. SUSPECT tO 0.0. ADDRESS Street City 24) PHONE NUMBER -.-I SPECIAL INSTRUCTIONS rCuND PROPERTY CLAIM'..] [it) DAYS NUT CLAIM U 'TEM a QUANTITY VALUE DESCRIPTION 1 1SS , Os.g:, -7,41 C".:P--ell i' r :cit., ) c:c o imt Wneui -e k 1 ---kl\- tc-kjel SOM. illA c> 0 - . LCI ? -7 t IRA > \ --, - TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents at property taken from me and that I have received a copy of this receipt. , I hereby acknowledge Mal the above list represents all property impounded by me in the official performance of my duty as a polite officer. 1 Cti c 1) 2 " SIGNATURE DATE (DP UNIT RECEIVED Ere REAS N \ DATE/TIME RECEIVED r '4 • 1 is EFTA00231792 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT DETECTIVE. BUREAU PBeDForm e2 I U PROPERTY O FOUND Q DECEASED (Probated) CI PERSONAL U CONFISCATED U DESTROY I:EVIDENCE aTRIAL O LABORATORY CISTOLEWRECOVERED J OTHER INCIDENT/CITATION NUMBER 05 • 306 OATEMME RECOVERED oq 50O5 ci 4c)A. PROPERTY NUMBER (Leave r g. l , . BIN NUMBER (Leave Black) —. ADDRESS WHERE PROPERTY IMPOUNDED rtm, „::-„z L\ 5 5 Ca ) hsTv , •40 \ -.JAW 6, :_:.p.(0. DISCOVERED C . X. ''' 1 :- ADDRESS ••• C") ... Street City ro DO PHONE NUMBER OWNER'S NA. ADDRESS Street City act PHONE NUMBER SUSPECT'S NAME / D.O.B. I -20.53 ADDRESS Street CITy Zip PHONE NUMBER ADDTNL. SUSPECT/D.0.B. ADDRESS Street City bp • PHONE NUMBER SPECIAL INSTRUCTIONS ECU \ D PROPERTY :„,?•t.' -I ,NO7 L-41V LI ITEM 0 I 0.:AILT! i Y VALUE DESCITIPTION . .. . • l '''', r: (,:- LI , _____, v.,. '‘. -..: -,., IN .„..,.--,:••-• --•-,%, . .- - _ A-LEN .1:.3v. --. . iN,),t,v\ C. ._. -cc•-i-\_2- 1 1 -;', i ._ _ .. ---- I L , . . . _ • . . • . • _ . __ _ i . _ . . . TOTAL PACKAGE WEIGHT I hereby acknowledge that the abet a list represonts at property taken horn mo and that I have received a copy of th:s rocetpt SIGNATURE - DATE I hereby acknowledge that the above fist represents all property impounded by mo in the official performance of my duty as a police Mixer. 1 (-1 I ,-,,,- - . ...., 02--- SI . IDe - UNIT RECEIVED BY REASONLS DATE/TIME RECEIVED - A'S EFTA00231793 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT PRPCI Fawn *52 EVIDENCE CUSTODIAN ...) PROPERTY C) FOUND CI DECEASED (Probated) O PERSONAL. CI CONFISCATED CI DESTROY la -EVIDENCE ISTRIAL O LABORATORY 0 STOLEN/RECOVERED O OTHER INCIDENT/C1TATION NU5R 09 3(9 DATFJTIME RECOVERED 10-03-05 016 PROPERTY NUMBER (Leave Blare) BIN NUMBER (Leave Ella* ADDRESS WHERE PPOPERTIIMPOOAUNDED - 5 (?) . E ILO WAY PALAA- ci;epca. q., -;.se-q-o / . ADDRESS # MD P O 0 ADDRESS Street City re, P NAME ) /0.0.B t SUSPECTS Gli 2O43 I f ris fm m ADDRESS Stct . City Zip 729?) El 1 Mot PHONE NUMBER AlfICI TNL. SUSPELT/ D.O.B. ADDRESS Street 40 PHONE NUMBER SPECIAL NSTRUCTIONS FOUND PROPERTY 90 DAYS NOT CLAIM 0 ITEM IS QUANTITY VALUE DESCRIPTION 1 1 bpity (oat Of tivAit \k/ yOWAAYM Wnke 2 ‘AA14,.. ipittu, -\-W14/11 (At 11* OvociimeMictiovi 0 ihrittOWily rtirtoWd -tam • TOTAL PACKAGE WEIGHT I hereby admowledge that the above tat represents al property taken from me and that I have received a copy of this receipt. I hereby admowledge that the above list represents all property Impounded Ildal perfomance ol my duty anodic° officer. ta v2_ SIGNATURE DATE SIGNATURE IDS UNIT RECEIVED BY REASON DATE/TIME RECEIVED EFTA00231794 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT Pr‘PD Form 0/52 DETECTIVE BUREAU J PROPERTY U FCUND 0 DECEASED (Probated) 0 PERSONAL U CONFISCATED 0 DESTROY *EVIDENCE WTRIAL 0 LABORATORY CI STOLEN/AECOVERED fj OTHER 2 Pk e. .f INCID EN_ T/CITATION NUMBER 0 5- 565 DATE/TIME RECOVERED 10 -3 -CS 2160 PROPERTY NUMBER (Leave Blank) ' .(, r . (-1Q ("I I .; • BIN NUMBER (Leave Blank).eit ( 1 2,P '7 Ipsi • ADDRESS WHERE PROPER IMPOUNDED . 2- 9 3 Q) ..._,t-afx.fiti Arno gall ' thate-C￾DitefIE i ADDRESS (gip O City Zip PHONE NUMBER OWNER'S N ADDRESS Street Ch Zip PHONE NUMBER SUSPECTS NAME/ D.O.B. I— 70 S 3 r e ADDRESS Street City c 0 Zip VD PHONE NUMBER ADDTNL. SUSPECT / 0.0.0. ADDRESS Street City Zip PHONE NUMBER SPECIAL TM . C ..0 V 14/ ,1 FOUND PROPERTY CLAIM J 90 DAYS NOT CLAIM J ITEM# QUANTITY VALUE. DESCRiPT ON Ak,0 C.J\GS-E-Hre, 504,3•I . t-k kCi.c2c) c.fi S 5(iLvii-00 1 -2c6- 2. i ‘20-11.v‘ 4-At Loccitst.A2i-te \-u • si -vA-(/Gml cant, u Ku otsjege ( k) Iini) .., r TOTAL PACKAGE WEIGHT I hereby acknowledge that the above fist represents all property taken from me and that I have received a copy of this receipt. I hereby acknowie that the ve list represents all property impounded by me in 1 my duty as a police officer. -lot K 9ve SIGNATURE DATE SIGNAT IDI • UN RECEIVED BY REASON DATE/TIME RECEIVED 'la,' #1 -1,,( :5 - • ti - C t, '7 3e. ILt• EFTA00231795 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT EVIDENCE CUSTODIAN Planer Form 152 -I PROPERTY 0 FOUND 0 DECEASED (Probated) I:l PERSONAL CI CONFISCATED CI DESTROY ((EVIDENCE 0 TRIAL 0 LABORATORY CI STOLEN/RECOVERED 0 OTHER INCIDENT/CITATION NUMBER 09- MO45 DATE/TIME RECOVE w-o4-ac) ED 0412) PROPERTY NUMBER (Loan Blank) BIN NIIml‘FR (Leave Diana) Ar a,SWHEFIEP i.Prip\Tto NDED l ?o w y ev)eollit vie. 'M-CW VIA/ IADOREss coy Zp PHONE NUMBER B. ADDRESS street coy TP PHONE NUMBER SUSPECrS NAME / D ky3VAYI l Q O.B. 0 11411,777 ADDRESS pi.ill.477)45‘ ,0 /7 C) 4b 0 4?,(5011,(AvAY) PHONE NUMBER A' NL. SUSMCT / O.O.B. ADDRESS ZIP PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM 0 90 DAYS NOT CLAIM 0 ITEM I QUANTITY VALUE DESCFilPTION 1 • I 9 ,tI.4_ of a ty Ani-ki0Y\ rem vo % elA -) A vi t t TOTAL. PACKAGE WEIGHT I hereby acknovAedge that the above let represents al properly taken from me and that I have received a copy of Iles receipt. I hereby admovAedge that the above hat represents all official performance of my duty as a police property officer. impounded /is • i SIGNATURE DATE ID# U IT RECEIVED BY REASON DATE/TIME RECEIVED EFTA00231796 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT PIK) Form .52 DETECTIVE BUREAU J PROPERTY 0 FOUND 01 DECEASED (Probated) U PERSONAL J CONFISCATED DI DESTROY )4 EVIDENCE g TRIAL j LABORATORY 0 STOLEN/RECOVERED U OTHER INCIDENT/CITATION NUMBER 05-Bba DATE/TIME RECOVERED ‘o - 4-os ‘6c-s PROPERTY NUMBER (Leave Blank) a c:„. :i --?..) —. BIN NUMBER B.eave Blank) / 2 '.4?1 7r A5484WHERE F:BOPERTY....LMPOUNDED o. coorny pan c),NAm \14/C. --I -ACA-t • f L. COVER ‘ . ADDRESS y8tpt0 Gay Zip PHONE NUMBER OWNER'S . . . ADDRESS St eat City Lp PHONE NUMBER SUSPECTS NAME /D.O. B. (- --70*S4 2Pc -(63 , -mac ADDRESS Street 358 • L, PA-1 t\lo Lp „ Pj PHONE NUMBER ADDTNL. SUSPECT / 0.O 8. ADDRESS Street Ct Zrt PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM U 9pDAYS . NOT.CLAIIA4 : .lTEM a QUANTITY VALUE DESCRIPT.IONI % trkel Wt.k C ft OCA .. . . . • . , lka4 M 1 CaOCACAtrt \I 0 k CO.A.Al I ccp.n µ; crtoc-PC)CAET V bk CL- kuk (1.- },tEc)A GC• o1102:.) • I MIC:11.00$SCMC VbAkk)-) Qt-kon e ci (‘ 7- 2S- c.5? H TOTAL PACKAGE WEIGHT 4..• I hereby acknowledge that the above list rep ents all property taken from me and that I have received a ccp This receipt. I hereby acknowledge that the above Ilst represents all property impounded b ' ormanc,e of my duty as a ponce officer. 1 CVS — b2 - - - SIGNATURE DATE ID UNIT RECEIVED BY REASON DATE/TIME RECEIVED,- y It r 3 C -,• CC ' 0 C (/ / ..1 -- EFTA00231797 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT DETECTIVE BUREAU POPO Form .52 Li PROPERTY D FOUND 1.1 DECEASED (Probated) :I PERSONAL D CONFISCATED C3 DESTROY (EVIDENCE NITRiAL ❑ LABORATORY q STOLEN/RECOVERED U OTHER INCIDENT/CITATION ABER 0 5- 3 DATE/T1ME RECOVERED o- 5-4 tom PROPERTY NUMBER (Leave I BIN NUMBER (Leave Blank) C5 -(7L / ,:.-Lf /1-2 ( -,Ge￾AO RELIS WHERE "OPER 11•OUNDE C.. -) c20 NO ADDRESS (—() 6-10 Gay Lp PHONE NUMBER ADDRESS Street City LP -PHONE NUMBER SLAPECT'S NAME / DO B. t -70 s; eC(K>%-* • _VI ck (7 F c7 ADDRESS . i i _Etroer ‘ i CP rY • Zip 7S c‘ LLX-jc(ItO PHONE NUMBER ADOTNL_ SUSPECT /D.0.6. ADDRESS Street Cily Zip PHONE NUMBER SPECIAL INSTRUCTIONS reUM; PIITI`CPTY CLAN ITEM # QUANTITY. VA::.1E. L.E5C:IL' .eN --t . . . . , . . . t. C..> L' • I\ y ; r c.;,„: V- 4.. 1-..A. - • 1ItA i-A" \ C.) . . . . . . . . . . • ,-- ---1- - TOTAL PACKAGE WEIGHT hereby acknowledge that the above list represents all property taken rorn me and that I have received a copy et! the rempl. I hereby acknowledge that the above list represents all a in the o rformance of my duty as a police property impounded officer. . C Ty2e.- -IGNATURE DATE SIG ID* UNIT RECEIVED BY REASON DATUTIME RECEIVED EFTA00231798 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT DETECTIVE BUREAU PBPD Pcyrn #52 3 PROPERTY 3 FOUND 3 DECEASED (Prcbated) 3 PERSONAL 3 CONFISCATED 3 DESTROY ,• -* / 4 ifEVIDENCE `TRIAL 3 LABORATORY 3 STOLEN:RECOVERED 3 OTHER INCIDENT/CITATION NUMBER OS .- (OE) DATE/TIME RECOVERED [PROPERTY NUMBER (Leave Blank) I 8IN NUMBER (Leave Blank) '1 C / i ' ' \CDC6C . k 1 06 1 ,N: L. . • ./ (pi c_H‘. . I ADDRESS WHERE PROPERTY IMPOUNDED 3 1AS 5 C.--)..A.11-4 ‘ .c>..z) PAW tjrz.k 0 DISCOVER ADORES ...... eel Cily Zip PHONE NUMBER ..OWNERS .ADDRESS &root City ID PHONE NUMBER SUSPECTS NAME/ D.O.B. I )c • '2 iqi QS1-FiNi , i ADDRESS Street k Cary • Z I CL to PHONE NUMBER • AoorNL. SUSPECT / 0.0.B. ADDRESS Street Cry ZW PHONE NUMBER SPECIAL INSTRUCTION , rCU 0 PROPEnri CLAIM J C A j ITEM ✓ CU NTT.,' I VAii.)E1 L CR ..-'1v3r. . e:22C.;b-- . . . 1.11 O . ( Cl.. C):51:- • 1 _.. • .. . . ,.. i. - - _ _._.,.. --- . TOTAL PACKAGE WEIGHT 1 hereby acknonoctge that the abo, e list represents all property taken horn me and that I have received a cony of this receipt I ereby acknowledge that the above list reptesnntS by in the cttia:al performance of my duty as a polce l a l all property ;nit:Den:fed officer. I C b 2-- s IGNATUR !De UNE T RECEIVED BY REASON DATEIN E RECEIVED af. EFTA00231799 "-sir tit. erleittlate PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT Pan) Fotm 052 0 PROPERTY 0 FOUND C3 DECEASED (Probated) CI PERSONAL Q CONFISCATED 0 DESTROY EVIDENCE U TRIAL ,0 LABORATORY U STOLENRECOVERED Li OTHER INCIDENT/CITATION NUMBER Ci r 1 719 DATE TIME RECOVE ED W-N062 CAti th 'PROPERTY NUMBER (1.0000 Bank) t rc_9ti 7 BIN NUMBER (Leave Wank) / z____. 7 ', 47// _ -4:--) ADDRESS %WIER PROPERTY IMPOUNDED 14/C0 0 VA I 1 0 \ AAV I? AN Ple 04_11 V ../ L 2) 9 2#ko B. r Illa %lid° I /ADDRESS Street / City Zqb PHONE NUMBER ADDRESS Street Coy Zip PHONE NUMBER yy `SUSPECTS NAME WI 0(0 110(42 ADDRESS ,Street CA Zpi 7y1A1 t i \ 1 2A 1 \ \ ay VS /VI PHONE NUMBER i A! TNL. SUSyE i D.O.E1 1 itREQS S!root trry PHONE NUMBER SPECIAL INSTRUCTIONS FO, 1.7. . L,F'F ( LAI,: _.1 • ' I I TEMN QUANT Y VALUE n,-;;GRID"101. _ VO I (_t_LI 4_ 6_4_14_0 ( 14\ 1/ CO i29Zi_ I / ti .4 \RIAW INO TI "MIII2W1 l}m-ViOY\___Vtr.higik TOTAL PACKAGE WEIGHT I hereby acknowledge that the abo' a list represents all property taken I hereby acknowledge that the above list represents all property impounded from me and that t have received a copy of this receipt. itt loal perlomiance of my duty as a police officer. 3143htATURE DATE IDN UMIT RECEIVED BY REASON DATE/TIME RECEIVED DETECTIVE BUREAU EFTA00231800 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT PBPD Pent52 1 PROPERTY U FOUND J DECEASED (Probated) O PERSONAL O CONFISCATED ODESTROY N EVIDENCE %TRIAL j LABORATORY U STOLEN/RECOVERED U OTHER 7 , : / . C INCIDENT/CITATION NUMBER C5 °.. 3 DATE/TIME RECOVERED 1 0 - 0 % - 0 SiC e l lc PROPERTY NUMBER (Leave B ) cc, _ (1Li L./ BIN NUMBERiLrir 1 .. .,it d ,,.. 9 cs2 . i ,...) ADDRESS WHERE PROPERTY IMPOUNDED 2 ) L2- 1Q7 e PA2ikAD wAy Pi\u\A BE-A(.0. r --.224?S‘O IIIIIIM 2 it: ADDRESS ) 1429 $trout City Zip 0' PHONE.NUMBER ADDRESS Street City Zip P SUSPECTS L9 1 ) 111 NAME / 0.0 El CI 2C)f-j3 W j_Z o BA-y ADDRESS Streei Gay Zip 22cit?) k PAimoWkv iv -29-A0 PHONE UMBER AIDOTNL. SuSPEcT / D .8. ADDRESS Street 400 Zip PHONE NUMBER SPECIAL INSTRUCTONS FOUND PROPERTY CLAIM ._.1 • RC DAYS NOT oLAil.1 J F.M « I 03ANT T VAL u 0 SCRIPT!GN L —L _Qv/nu_ OUP4keykit .V, \it:e• (uy \key. i. Wu4€ 'pleith Salm( t4Vuly) Yt•vnove6 p_art_ -\110/1‘ otir 72% t 1 Ix i tkowAy. _ „._ ..I .:__.:.. ._,,t__ _ • • • .• .: . . . TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents all property taken from me and that I have received a copy of this receipt. I hereby acknowledge that the above fist represents all property impounded by me in the official perfomancia of my duty as a police officer. Vek V.1._ SIGNATURE DATE $ ID0 UNIT RECEIVED BY REASON DATE/TIME RECEIVED r h ... e • .) -1 — 1 ' '') -. ( r ( 7ir cir: DETECTIVE BUREAU EFTA00231801 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT PBPO Form #52 DETECTIVE BUREAU I .__, .1 PROPERTY a FOUND U DECEASED (Probated) O PERSONAL D CONFISCATED D DESTROY g' EVIDENCE *TRIAL O LABORATORY O STOLEN/RECOVERED O OTHER INCIDEIT/CITATION NUMBER 0 5 .3(5 ATE/TIME RECOVERED iarpooc c12 PROPERTY NUMBER (Loav 05- ((-) la Aele .4..... ; .....„ BIN NUMBER (Leave Black) /2 we/ / Arr HERE._.).°PERIN- IMPOUNDED. ___ \ , __ , - - KJ1 7 f, .O A O 0 P -kAA cLciy P Tk r2VER il ADDRESS Q .b r {,..5 City 27P PHONE NUMBER OWNER'S A ADDRESS Sheer city Zip PHONE NUMBER SUSPECTS NAME I D.O.g. ,..0 I zty\ 3 (1:)9-1PiNi ,i e- 34/-A A:/flqS &Met • ZO R ciati(c (LocnYiNo PHONE NUMBER ADOTNL SUSPECT/ D.O.B. ADDRESS Street City 4 , PHONE NUMBER -I SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM Q 90 DAYS NOTCLAIM J. ITEM # QUANTITY VALUE , DESCRIPTION 2 I t14/37 Pi (C 20 C_Acci.: is . ryi rric -I( -.7 'Tr D66._ C- , ,,, TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents all property taken from me and that I have received a copy of this receipt. I hereby b acknowledge that the above list represents all property impounded e in the official performance of my duty as a police officer. r i C ti C I) 2 ^- SIGNATURE DATE _. SI ION UNIT RECEIVED BY REASON DATE/TIME RECEIVED / '; q % ) ') \6 _ . 4 ) • c 7- 0 St ( 7 '. c S.,.. EFTA00231802 PALM BEACH POLICE DEPARTMENT ,PROPERTY RECEIPT Pen Form /052 I 1 I PROPERTY CI FOUND U DECEASED (Probated) 0 PERSONAL 0 CONFISCATED 1.3 DESTROY .6 EVIDENCE STRIAL 0 LABORATORY U STOLENRECOVERED Ci OTHER INCIDENTICITATIONAUMBER 71- ) b 6 DATWTIMEIRECOVERED . , . \o/i2/05 Ilex:ma, PROPERTY NUOER (Leave 6:5 - 9 Blank) --1, - BIN NUMBER (Leave Blank) 7 a. %/tit ADIffAS.WHERE PBOPERTY.IMPOUNDED 9 C.) .5-> . (._ _ 0 (.) o) 7 v /20 741) / - A Iv ILA. .4c- 1 DIS.,EgI!Ft ADDRESS /96Sprb City ZIP PHONE NUMBER OWNER'S NAME / D.O.B. ADDRESS Street City ZIP PHONE NUMBER SIMEECA-11U TS Natog /65srlit 1--..V rri — CR • Je:16C Street C4Pe A35? DDRESS sed/6 ZIP Ei PHONE NUMBER ADOTNL. SUSPECT / D.O.B. ADDRESS Strout City Zip PHONE NUMBER SPECIAL INSTRUCTIOkL ) - . i i\SE- CcQ y fr- FOUND•PROPERTY . CLAIM L.) 90 DAYS NOTC.3LA9.c.J.... ITEM 4 QUANTITY .VALUE • •DES0RIRTI0N - I C1TS y A_rn-Q. vs/ 6:14-1 ____._. V14/1.I.T4-'• t'-'05 -2.H r . t ‘ t f ft-, (- I k ,- So,vy i-rrctioci c St-Ng , / nift'rk.vi iki _ tutu Cc43 - . .• TOTAL PACKAGE WEIGHT I hereby acknowledge that the above hst represents all properly taken from me and that I have received a copy of this receipt. ... ...., . — ---• I hereby acknowledge that the above list represents all property impounded by me in the official performance of my duty as a police officer. 1 7(f .7--- ________. _ _. -- SIGNATURE DATE SI IDA UNIT RECEIVED BY . REASO DATE/TIME RECEIVED ,-- Ci f ,_, e.c. 7? (dD /0 73- 6 S.- /&r,0 k DETECTIVE BUREAU EFTA00231803 ,-••• ^re, • PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT P&P() Poem A52 I . 0 PROPERTY 0 FOUND 0 DECEASED (Probated) ra PERSONAL U CONFISCATED 0 DESTROY ≤EVIDENCE STRIAL Cl LABORATORY U STOLEN/RECOVERED Q OTHER INCIDENT/CITATION NUMBER .)-. ( J_...) DATENIWIE RECOVERED i D ‘ te.:GC I \ LI 0 PROPERTY NUMBER (Leave Bark) 05 - /6)6,S BIN NUMBER (Leave Blank) / 2 9 fi ti a AMR EpsLNHERE BETPERTYJMPOUNDED t, ) I J ----i ( _CONTI/ `2-OAF) kt ck.At AC “ ADDRESS 4----)...—.; v $14#4(5 City Zip -)19 PHONE NUMBER ADDRESS Street City Tip PHONE NUMBER SUSPECTS ER;rEI NAME /D.0 B V Z.0 5 4, t,-). J .P if. - ADDRESS Street City 20 -2..)st5 - t 1--1-4 r6 ( t 0 PHONE NUMBER ADDTNL. SUSPECT) D.O.B. ADDRESS Street Cey ZIP PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY .cuum :...1 90 DAYS NOT CLAIM U ITEM A QUANTITY VALUE DESCRIPT,ON • LI 11C • f •1,-)Cii—;\k)(i i tit.-- ---' 1 7 2A944 I LH 6 Gc, Dr--.-17 • 1 TOTAL PACKAGE WEIGHT ',As I hereby acknowledge that the above list represents all property taken from me and that I have received a copy of this recerpt. I hereby acknowledge that the above list represents all property impounded by me in the official performance of my duty as a police officer. SIGNATURE DATE SIGN ID# UNIT RECEIVED BY REASON I DATE/TIME RECEIVED S' 2 7)- ix-, (... /6 ./fr"- C 0 i C; 6 E DETECTIVE BUREAU EFTA00231804 penFarm rs2 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT SEARCH RARRAIC RETURV DETECTIVE BUREAU I Q PROPERTY D FOUND D DECEASED (Probated) A PERSONAL U CONFISCATED LI DESTROY U EVIDENCE U TRIAL U LABORATORY :1 STOLEN/RECOVERED U OTHER . iCIDENT/CITATION NUMBER DATE/T E RECOVERS 1" 240\ PROPERTY NUMBER (Leave Blank) o - BIN NUMBER (Leave EUank) ADDRESS WHERE PR ERTY IMPOUNDEri _CSI 1 A0Q, rr olC S58 EJ- Ay, Ho V D Y/ D.0 AD ESS Street City Zip PHONE NUMBER 7 ADDRESS Street City Zip PHONE NUMBER SUSPECTS NAME / D.O.B. F7r - S￾eF5TViv.) Fa, 3 cf fie/ . ADDRESS Street Cy - Zip 35S 'Et \?itillo PHONE NUMBER ADDT'NL SUSPECT/ D.O.B. ADDRESS -Street City Zip PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM O 90 DAYS NOT CLAIM LI ITEM e QUANTITY VALUE DESCRIPTION -Oil" \ci n.5 . iy)44 Il l INCi / CA. Dave%) • . o A __ TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents all property taken trom me and that I have received a copy of this receipt. 0:1).?)D•oc-' S DATE I hereby acknowledge that by me in the official performance SIG ) the above list represents all property impounded of my duty as a police officer. 79 t C 1)2.. IDa UNIT- "-1- -- A. ; 0 BY REASON I DATER- ME RECEIVED - cairc; A o St f AA. 10 yip z 0 a\ '..i. ni EFTA00231805 PBPD Form OS2 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT SEARCH WARRANT RETURN DETECTc)E BUREAU Qrg￾3 PROPERTY I L.) FOUND a DECEASED (Probated) 3 PERSONAL':. - 3 CONFISCATED Li DESTROY EVIDENCE 1 TRIA 3 LABORATORY D STOLEN/RECOVERED -I OTHER L i II IDENTCITATION NU ABER ..‘ 0 -2. 6 (/ 4 DATEITIME RECOVERED r..) - -L C) - -20 0 c • PROPERTY NUMBER (Leavy Bin) C C5 . 40a ( 1 , BIN NUMBER (Leave'Brahkr—, ADDRESS WHERE PROPERTY IMPOUNDE / L - SS l lh DISCOVERS i D O.B. ADDRESS Sueot City Zip PHONE NUMBER OWNER / VICTIM'S NAME; DO 8 ADDRESS Street City Zip PHONE NUMBER SUSPECTS NAME I D 0 B. /' CPS ein E i ADDRESS Street City zp 3V5 Fit 13#41/0 PHONE NUMBER ADDT.NL. SUt PECT f 070.8 ADDRESS Street City T1p PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM J .- 9O DAYS NOT CLAIM_' ITEM 0 QUANTITY VALUE sESCRIPTION 1 - --f-i c Vtii Ic , ( • I - . L--• : • / / _ e 4—'6/2-.2 ,-tcr . , _ , -_.---, / - 4 0 ter fr i 4/1 i . "4 1. / 4 2 (eT it y or s/ P 4/dfii / (4,1<11.2:77c/t - , It -- . , _ ., . op? ., . - / _ 7 ( ter / i ,--, LC /; 7.,' ddi cetrt f - '"= •• eve , , , 7 -#: 1 (.7-it fi,,i , • c i . 4 ,/,'' Or ., _.,.. .10 t v" try, I k - fiLliki.....en (,Lb t ,,5- e i s"! Lif \lilfat!./".1 i 131 ki In k ____------ " ,".4 '-5 Cf,t q (2 90 h/r) ",,,v, Cri rni4.,A pi; (2 24-) J,. 1 1 . lit, cf c. _iii_ / Ci • 1(:; 5.t al.ei.( v"-cS 7 , 6- ":2 . . iPe.; P r* /,‘ c47) : .74. -I .rt';t: br IN Ito 1 let; / 14 kJ ,, /3.1 52" Ph?) i Os V.0/77 el - / /' (7 Or r 6 r) / c Ph 040 C _litatt 1,13.4. --A _i...eL 1 -ii-- l 11. ,,,t; . -, Li- ,,,- ; r p i / r k 4- %, I _a. 0 a TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents all from me and that I have received a copy of this recopt wwnerow... SIGNATURE - property taken I hereby acknowledge that by me in the °Bloat performance SIGN • the above — 'st represents all property o, my duty as a police 11 ID# impounded office, i C D ela DATE UNIT RECEIVED BY REASON DATUTIME RECEIVED IIIIIIIIIIIII the officeL inventory, contains a true by wttg_this warrant li P res ted, do swear that. the above anC. detail -- - - - • •- •roperty i taken by me, under the authority of this warrant, Sworn to and subscribed before me tb.is21 day of Octnher 2005. .... -- EFTA00231806 ,p 5 PBPD Fc'i lit:2 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT SEARCH WARRANT RETURN tAKCc.2. DETECTIVE BUREAU D PROPERTY U FOUND U DECEASED (Probated) U PERSONAL U CONFISCATED U DESTROY EVIDENCE Sci TRIAL Li LABORATORY U STOLENRECOVERED U OTHER (Z.( 1_, INCIDENTCITATION NUMBER (7 5 - 3 g DATE/TIME RECOVERED „, -Jr. -c, s PROPERTY NUMBER (save Blank) 05- )c) (-/ BIN NUMBER 4Le ve Blank) ADDRESS WHERE PROPERTY IMPOUNDED DISCOVERED BY /0.0.B ADDRESS Street City Zip PHONE NUMBER OWNER r VICTIM'S NAME i 0 0.8. ADDRESS Street City Zip PHONE NUMBER susPctrs 4 NAME r lo. -- r i I'M e -rc-• _ ADDRESS 35-77 El' Street 12712( r City Zip (1O PHONE NUMBER i NL SUSPECT! CI 01,--\ ADDRESS Sere ) City Zip PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM U 9C DAYS - NOT CLAIM:.] ITEM QUANTITY VALUE DESCRIPTION (1 : ir‘ , 4\ , , - i 3 "45 - 2 fcc..-ia _1! -AS er Liy, L-2_2414.-..,..__eli --", b oEs_ __in_ _l Ph pi e. i - trrn •--/ if -r. 6, c f 47 ('ix 1:, c, r-74 -, j ,_. f -)7/,5 s69( h6c,A / -c- / ,/,,,,, 5,/,,, rol'll '4-'7 -S erryr- ber>0 lc ( i: f•-•( ,•••..‘ i z, ..-, , , ,,.. .,_, is_„,) 3 C .1.) -5 elk.c..):e_i-)._. cif ..1 X. - . ___. ___,.. _ .7 9 1 .4 L. . /--_,) v b Proo---) ,- I r ( A_ - ( it 7-.1 Ls - • % j 4,- d- Q..0 34 .,....' ",:. .i,... IQ 0 it, irtS .__al Pi' 64 -05 Per 0 ni OILS k ;.4k-4,10.-) / ' --I ri,,,,•;, _s •f:/• / a 1 , _ 41.-K,„,pri Ph.:1(.-:s iv': :2 nit- hte.c k : , . y: ..., ... T.-- .93 i {9 - `f _ y 0 WI pi)} ( ..)1'.1 {I 1- 0 c ii•011.4117 e t^ CAA) ( ft / k \ r- V _ii' . ,t,' ) NE 12,itriviri i ., • , . r, ., ,,,_ :74 er; , • i v; 7 (•)r iv-) • 7.1 I/ t' i tg.• fie ,o . t., 4.-,-.1 A.,--'1, ,t> l• ti -1 CO t sers4-04--- 0 (0\ Ct (Y., wit-A P, ( { Li I C ( 1 'c, ''' 1°I 1 ).'il-o 17 inc Vri . .., TOTAL PACKAGE WEIGHT vi ) /2:- el v c c -k I here acknowledge that the above -I st represents all properly taken from me and that I navy/crewed a copy of this receipt, I hereby acknowledge that the above list represents all property impounded by me, in the official pedormance of my duty as a police officer. --ilic 5-2.-- ' DATE SIG bit I LiNIT RECEIVED BY REASON DATE/TIME RECEIVED A ON.0 s Oi D-ArlTh EFTA00231807 •-4 PaP0 Form .52 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT SENCri WARRANT RETUFOI 1464 3 or 6 DETECTIVE BUREAU U PROPERTY O FOUND J DECEASED (Pr°baled) U PERSONAL j CONFISCATED J DESTROY NA EVIDENCE TRIAL J LABORATORY :—.) STOLEN RECOVERED U OTHER ( a C) INCIDENUCITATION NUMBER DATE/TIME RECOVERED /0 o76- OS PROPERTY NUMBER ;Leave Blank) -r 2 J - /Oa Li ( BIN NUMBER (Leave wane ADD E WHERE PROPERTY IMPOUNDED 2 /72 I- / epri DISCOVER TD BY/ D 0 B ADDRESS Street City Zip PHONE NUMBER OWNER /.VICTIM'S NAME / 0.0.8. ADDRESS Street City Zip PHONE NUMBER SUSPECT'S NAME / 0 0 8 01- r 0 ,,p_r,fri 2 V -I; ? re( ADDRESS 96 roe' ply I- 13i2iliu PHONE NUMBER AODT/NL SUSPECT / D 1) ES A5DDRESS Street City Zip PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY 90 DAYS NOT CCU:AIN: U 1O ITEM A QUANTITY VALU DESCRIPTION A 2 7 c =41 oii12,0eAtgmfr n4 17E, 6'.,),,,airt Dc SAC A,2 •S' ...i. Writ, 0#1 lay Ye Ity) in r /4 4 6 r Pinrol r g e 4V-iy;..41- m.y.y4,,r LI g ,:::71, , ___{. Ith 9 , A/C V AA.: T i) ) r)t. 0 7,et 5 :4f? So w 4N c 4;1 c 4 I r/V 74 0/01.7. firLI t: IL S414 NI 1--1 /4 , AP" • ,.... -7/ JI•3 0 C fi t.Cr f: A "11,- D fir V. r Cu." fi' Z. W&1.- A VI f n+ 170 ; r , t j.4 '7)/2 ', /V/ 1 / Wry. 6 f r e r.E IN 3:ef Kr 7 A c'ti ft i, f I P e 1 . t. 0-§ -111.17. it ..... 03c pi, //, fri_ . _, _ _ 3 Alt fr, . 714 Rt.( Ty /44: Ainit 4 AI; p er .n eni r r-;?:- 01 Cut OR)/ e7 50i r , ,( )L1 ni (0)9iiii) NoTe.: ftecgh loh A i' .. 4 i se Ofil C!( , .•4f`1µ, Szig ill, t%t ;',' _4 If . ... ., rr „ _ s I 0rri 4-2 +'r ' / C ,.. t—Cki .. i(0 .... gi i, :‘ - S tiff, ,.. ,-. r . y-49 ) 0,J, <i,, yr, c i ;VC c.- 12-Llu- Q ifb O,-. go 30 1 C.! ry .4 (.> 7,-.4 c , ,,.: (i_ ,i ,), 5 - .5:- 13-n Ti-i 0 . \ ..,.. I TOTAL PACKAGE WEIGHT 6 +At' 51 1.-10-4S C I hereby acknowledge that the above fist represents all property taken fromMe and that I have received a Copy of this receipt I hereby acknowledge that th by me in the official performance above list represents all property impounded of my duty as a peace officer IS- j)2--- SIGNATURE DATE SIG ID UNIT RECEIVED BY REASON DATE/TIME RECEIVED EFTA00231808 * • — $ • PBPD Fotrn '52 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT Ret I/ of 6 DETECTIVE BUREAU 0 PROPERTY 0 FOUND U DECEASED (Prebend) U PERSONAL 0 CONFISCATED U DESTROY TRIAL 0 LABORATORY U STOLERECOVERED N1 U OTHER ( a kr If EVIDENCE IDENT/CITATION NUM ER 3G8 DATE/TIME RECOVERED /o- (Po- 0 5 PROPERTY NUMBER (Leave Blank) BIN NUMBER (Leave BIarAl C 5 - I 0 -t_ ADORES WHERETROPERTY IMPOUNDED 5 F / L 2 - E, /fi) DISCOVERED BY / D.O.B. ADDRESS Street City Zip PHONE NUMBER OWNER'S NAME/ D.O.B. ADDRESS Street City PHONE NUMBER SUSPECTS NAME / D.01. ._../T2 L. Cr 5 .306;E tb E tteet W ) Zip PHONE NUMBER SUSPECT!! 0.0 B ADDRESS Street City Zip PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAW J 90 DAYS NOT CLAIM J ITEM N QUANTITY VALUE DESCRIPTION . , di 5 ttf ' l iee" 4---PY, ;deur _s_he/C12-e 2._i_ - _Le ,v{. „a isk rteQW1 a , 1441 fa so n..,_ ) et Pik 7 o aril fro ) -y.-- C Pet -vont, &ups A /3 .17 ef r 6)0 /. 7 I/ 8 3. i n PI vidfio... 7eir-r in go (.1 ?. ./ / 22 7.66, eyi,ti s-c ,-- 1)2n.v C/I CD ,n ( , , .., s ' di i, li fr./ i e_ c 4 - Dig kt,-. / yl ( - le,ii y d o x." . .. ___?Zza Taff.,IVIRTY-.—; 7-1 19: D. /S. & {ruin Ye m. ., . I . . . li r itnS b_14 e IRJRA$42 6166(0( +4. I . ., .. . DirICC?:( e. V g O . . i 6 pi e "- / e,• sr= iyenie/Ge• ? A ( 450 4,_ • ,•,-) , i, . r bfia.e. 17(31-00-4--) CO Alfa C ASA Ca /J ..(7 - iiit; t tivt. . .:64„, 1.b a A -5 • .2surti--) ythli 9"— V— - ,,_, • s --rc .45S r . c•P :- • '-4\a... .- . ' .. 6 In ei i A c.c , s-e (-) c-F7 -( e „c TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents all property taken from me and that I have received a copy of this receipt. I hereby acknowledge that the above list represents by me in the official performance of my duty as a police all property impounded officer. SIGNATUPE DATE SI IN UNIT RECEIVED BY REASO DATE/TIME RECEIVED 0%0 \ 1% 0 ,C, ,e-c) EFTA00231809 PBPD Fain *52 PALM BEACH POLICE DEPARTMENT 5 or 6 PROPERTY RECEIPT DETECTIVE BUREAU - U PROPERTY ............“ !, ......., ... j FOUND j DECEASED (Protatea) CI PERSONAL U CONFISCATED a DESTROY 4EVIDENCE )4 TRIAL U LABORATORY U STOLEN/RECOVERED U OTHER 4 INCIDENT,CITATICN NUMBF -,•••% O 5 - S 61 5/ DATE/TIME RECOVERED 70 ''. G2 o - 05 PROPERTY NUMBER (Leave Bank) 65 109 L 1 BIN NUMBER (Leave Stank) ADDRESS WIER ROPERTY IMp B OUNDEAL. 3-t 6 - L.- r, \ \ 0 P-iAliti 6 ,0 (-- DISCOVERED BY i D 0 B. ADDRESS Street City P NE NUMBER OWNER'S NAME / DO B. ADDRESS Street City Lp PHONE NUMBER SUSPECTS NAME/ D 0 B. Pr in jj 0 j--PC)- SSORESS fr Street City 20 357) 0.- zilici PHONE NUMBER B e ADDNL. S USPECT / ‘4O. ADDRESS Steer al) PHONE NUMBER SPECIAL INSTRUCT ONS FOUND PROPERTY CLAIM U 90 DAYS NOT CLAIM J ITEM ra CLAN'ITY VALUE DESORIPTIO \ '-'4 I &Weer. (00 1 14, rPa--t $1 53 11.. .( P CIL — , i ;kik (TT; .. - , . . Pot,7Pv c or . i 1-e 41 S 41 ‘... c. r - D t-s \LIAg______ 41 cc-5 7 • fitoryi Of . . nil ii( tiie\____ ( h ni esscLt t_ k-c(bLv... . __ vr, +c r_s . &sets , . ic-e11.44.--, 124---• tufa i-J f t ec kli N .- ate , TOTAL PACKAGE WEIGHT I I hereby acknoMedge that the above Ilst represents all property taken from me and that I have received a copy of thl% receipt I hereby ecknov.ledge that the s in the official performance above list represents all property impounded of my dory as a police officer. SIGNATURE DATE IDIt UNIT RECEIVED BY REAS DATE/TIME RECEIVED e it) • e \I\ EFTA00231810 t4t 4 as 4 P800 FOZ.1052 PALM BEACH POLICE DEPARTMENT ROPERTY eR/LTECEIPT /1/ P (1 VI E- 1: r /Mot 0, DETECTIVE BUREAU D PROPERTY U FOUND O DECEASED (Probated) U PERSONAL O CONFISCATED D DESTROY Pal bEVIDENCE L ....PRIAL ' LABORATORY U STOLEN'RECOVERED O OTHER ( 0 10. f BAIDEAT4TATIoN NUMBER , 0 DATFJTIME RECOVERED tO 2o 0 C 14fro PROPERTY NUMBER (Leave Stank) CS t. i 03 Li BIN NUMBER (Leave Bank) ADDRES!! )SPERTYCNOF& A 1 i O DISCOVERED BY / D 0.B. ADDRESS Street City L ao PHONE NUMBER OWNER'S NAME / D.O.B. ADDRESS Street City. Ire PHONE NUMBER Su? fr 11-Ou Je is 3 . ADDR_SSce Street ii.L. _ n ed Zip ...)(.4 -fig PHONE NUMBER — ADOT'NL SUSPECT / D 0 B ADDRESS Street Cly Zip PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM O SC DAYS NOT cLAim D ITEM JOUANTI7Y v E DESCRIPTION 9.(J.W. 672,6P-; P--k7 /7). lid- (Ai/J/4 • Q I ' a...• VVVVA P-titt,-k 4 -1 i v P- 1\)1r--403Mt41' . • Us:,--1-\:4 : -,••-d - 12CRA7)•.) T--- n c2k... c•-tJ v L -IA c' .7-1 / ce:12.1tfil r----) ' 251\ V TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represtints al: property taken from me and that I have received a copy of this receipt i., I hereby acknowledge that the above list represents all property impounded by me in the official performance of my duty as a police officer. — SIGNATURE DATE A SIGNATUR ID# UNIT RECEIVED By . REASON DATE/TIME RECEIVED 74( 123 :;. 3 2 ' 9 (9 /4) .• q; o - 0 C / 1 .O 0 ,. c. Ne • . c.) EFTA00231811 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT PBPO Pam 052 DETECTIVE BUREAU - 31 PROPERTY D FOUND U DECEASED (Prcbated) D PERSONAL CI CONFISCATED 0 DESTROY *EVIDENCE liTRIAL CI LABORATORY 0 STOLENRECOVERED 0 OTHER INCIDENT/CITATION NUMBER °S - C:Ilra DATE/TIME RECOVERED k O s \ \ .-OS (100 PROPERTY NUMBER (Leave Bank) IBIN NUMBER (Leave Blank) C ; . Cr) ‘' ( 0 - ;S 2 C1 k i t-j .f AD.C5101ERESIOPER IMPOUNDED my l2C;n0 D COVE • ADDRESS cep a City Zip PHONE NUMBER OWNER'S N ADDRESS Street City Zip PHONE NUMBER SUSPECT'S NAME / D.O.B /-2,01-7 ,_ 7EAV JE:Fr ADORES a Street , yitY Zip 5W Sell 6 • PHONE NUMBER ADDT'NL. SUSPECT / D.O.B. ADDRESS Street City Zip PHONE NUMBER SPECIAL INSTRUCTIONS FOUND. PROPERTY CLAIM 'L-I 90 DAYS NOT CLAIM CI ITEM * QUANTITY VALUE DES I I T>240.ure 14/16 Ri TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents al property taken from me and that I have received a copy of this receipt. I hereby acknowledge that by mo the above list represents all property impounded of my duty as a police officer. —71,K_ "b7...-,i SIGNATURE DATE SIGNA IDS UNIT RECEIVED BY REASON DATE/TIME RECEIVED /AP r<-3D?. Es; /a - e;2F • (-.S- c.77 ( . EFTA00231812 fhP PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT PBPD Form t57 DETECTIVE BUREAU J PROPERTY U FOUND U DECEASED (Probated) Q PERSONAL 0 CONFISCATED 0 DESTROY /4 EVIDENCE lig TRIAL 0 LABORATORY U STOLEN/RECOVERED 0 OTHER INCIDENT/CITATION NUMBER t)S- 5(re) DATE/TIME RECOVERED /o-2./-0( / a Ltd PROPERTY NUMBER (Leave Stank) r r. ...) - to-Z-7 BIN NUMBER (Leave Blank) 1 7 5 5 LI 1 AC3pS:A5EREPRCSRTY l?,.!cc UNDED ' Cant/FY (2e, 40 DI ESS Street City Zip PHONE NUMBER O ESS Street City Zip PHONE NUMBER SUSPECTS NAME! D. mitue 2 .E3 ADDRESS Street Ctly Zip PHONE NUMBER ADDTNL. SUSPECT/ D.O.B. ADDRESS Street City Lp PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM U SO DAYS NOT CLAW D ITEM N QUANTITY VALUE DESCRIPTION ) 41(-SC. tkokr I-4 Skew Hz cju Mks a 10 -2 1- us￾H TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents at property taken from me and that I have received a copy of this receipt. I hereby acknowledge that • ..; • • tail, • • • ;1. Oa the above list represents all property !Me of my duty as a police officer. impounded ic • SIGNATURE DATE Sic _92 1 / IDa UNIT RECEIVED BY REASON MOOPIF RI P DATE/TIME RECEIVED EFTA00231813 - ••,”44.-0014;;;;,Sk PALM BEACH POSICE DEPARTMENT PROPERt RECEIPT ^6PD Form 052 Di PROPERTY D FOUND 1 DECEASED (Probated) 0 PERSONAL U CONFISCATED CI DESTROY aL EVIDENCE It , If TRIAL LABORATORY U STOLEN/RECOVERED '' I—I OTHER 0 ' (-- kit 5' INCIDENT/CITATION NUMBER 0 5 - .56B DATE/TIME RECOVERED ‘ k 04oS 4 0S prvi PROPERTY NUMBER (Leave Blank) D 5- IC 5a-- BIN NUMBS (Leave Bank) j f 7? 11 1 `-\• LL - ' L i A3R4SgH Esp nap Ty 00 po u N D E D fTh t.... , 1.41V le ono PALui Ao-k 1 FL t 2_2 i 14/-1 1 ---4-A 1 ADDRESS 0 o rin CO Zip PHONE NUMBER OWNER'S NAME / D.O.B. ADDRESS Street City zip PHONE NUMBER SUSPECTS NAME i D.O.B. I..7.0 -53 CZ-PST-lc ilLi f /CDT ADDRESS Street Ow zp -59t) EL Ppilirk 1 0 PHONE NUMBER ADDT'NL. SUSPECT / D.O.B. ADDRESS Street City Le PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM J 2: .2M'E ic - c.._A]... J ITEMS • QUANTITY VALUE 1- -' OESCRIP'Y 'OIN ‘ • 1 - hAsibkq I I 1140 \.i \ si>e005Sic+16. N 15NV LA ( LOAD CASSC.14C . pi C -9 i PLierne-- 0 II TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list roprosonts all property taken from me and that I have received a copy of this receipt. I hereby acknowledge that the above list represents all property impounded me in the official performance of my duty as a police officer. 11-k C 1-02-07-. SIGNATURE DATE SIG IN UNIT RECEIVED BY REASON OAT EITIME RECEIVED ≥I (k -3-3 f it:2 ' ci 7 - 61 ( 7 ?c i•,- DETECTIVE BUREAU EFTA00231814 • PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT PD Fenn 152 DETECTIVE BUREAU j PROPERTY O FOUND O DECEASED (Probated) DI PERSONAL Q CONFISCATED CI DESTROY #1KEVIDENCE 0 TRIAL CI LABORATORY CI STOLEWRECOVERED D OTHER INCIDENTICITATION N MBER 05- DATE/TIME I 1010 RECOVERED 5 t2Lto PROPERTY NUMBER (Leave Skink) O S- Jr L-t! BIN NUMBER (Leave Blank) f .1 7 rya - .., es5cSA_WHEJSEPROpEifiTY IMPOUNDED 2 0 'Z.) . LOU kilt/ OrfapOVERE• uc ADDRESS pb rit,a71 Dry PHONE NUMBER OWNER ri S N ADDRESS Stfreet City Z0 PHONE NUMBER SUSPECTS El NAME D.O.B. I - 20 5 5 rilt•I ,..) ..ri ASSDDRESS goz. ) ." EL i Zip -54-,Y..) PHONE NUMBER ADDTNL SUSPECT/ 0.0.6. ADDRESS Street Cry Zip PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM Li 90 DAYS NOT;L'04 C4T. : ITEM it t QUANTITY VALUE DESCRIPTION .,....., ( ‘ ol• .1 .___ .,..1,-/ utc_RocAs6E- 4c • • WC. , -9o -- t.,. SrArknruST 3 tiesiti... Tit DIA Cc:unity ol - 4-kcNoLttl14/4 CAl• b14/ 511A- vekAltls /D it tveQ S Lk C -..1‘5C TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents all property taken from me and that I have received a copy of this receipt. I hereby acknowledge that b me in the offickalperformance the above list represents al! property impounded of my duty as a police officer. -1 9 nes SIGNATURE DATE ITO/ UNIT RECEIVED BY REAS DATE/TIME RECEIVED r(1 37o' /7 - 1 -.!. )- /ro c its EFTA00231815 • r Its Fain a52 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT DETECTIVE BUREAU U PROPERTY 0 FOUND J DECEASED (Prcbated) 0 PERSONAL U CONFISCATED U DESTROY EV1DENCE VTRIAL 0 LABORATORY U STOLEWRECOVERED U OTHER ) V, A -- t 5 INCIDENT/CITATION NUMBER 05-3‘€) DATE/TIME RECOVERED h O(aios (521 PROPERTY NUMBER (Leave Blank) c r - 4: ( 2 BIN NUMBER (Leave Blank) /9:7/c( A RESS WHERpROPE Y IMPOUNDED 4S ijr9 9.0A-0 045 DISCOVE ADDRESS 2 & Stnec,--\ City Zep i PHONE NUMBER OWNERS ADDRESS Street City Zip PHONE NUMBER SUSPECT'S NAME / D.O.B. t- 4.Q -N) -; . €.(Tk-ou.)T..CV ADDRE1 Street City 4) iii. (2) A. u PHONE NUMBER ADDT'NL. SUSPECT! D.O.B. ADDRESS Street City Zip PHONE NUMBER SPECIAL INSTRUCTIONS , FOUND PROPFRTY CLAIM J D 3AYS NOT CLAIM) TEM a QUANTITY VALUE • DESCRIPTION l t VAPV: ELL_ • < _ • - -- • SiterCI,NR IC _ 1 MA •-,4t- Li__ k-1 V10 •• iA - 4-kMa4 cnir TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents all property taken from me and that I have received a copy of this receipt. I hereby acknowledge that by me in the official performance the above list represents all properly impounded of my duty as a --- police officer. /91\ ) 2 _ ( _ . . .. CiONATURE DATE SIGN ID# UNIT RECEIVED BY REASON DATE/TIME RECEIVED EFTA00231816 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT PRP° Form *52 3 PROPERTY D FOUND U DECEASED (Probated) U PERSONAL 0 CONFISCATED 0 DESTROY EVIDENCE \IL TRIAL DI LABORATORY 0 STOLEN/RECOVERED 0 OTHER I CIDENT/CITATION-klUMBER DATEJTIME RECOVERED , PROPERTY NUMBER (Leave Blank} BIN NUMBER (Leave Bank) 7 ILLY ADepiESS V<AsifERE 2I OPERTY„IMPOLINErED 2 LACLI /14/ " (10 6 ° Q L e.5 ADDRESS Street City 43 PHONE NUMBER ADDRESS Street CO Zip - c 14/.: PHONE NUMBER susPFcrs t14/1,90 NAME) / D 0 B. ' :16 crs % NRe-c ADDR SS , qirk (I(IL L iorti I lu cie7 PHONE NUMBER ADDITNL. SUSPECT I D.O.S. ADDRESS Street City Itp PHONE NUMBER Splift...ltISIRSLCTIO \ St- 1.0An PrA 0 a kit..a O-1 FOUND PROPERTY CLAIM D .43 DAYS NOT Wilk( D ITEM e QUANTITY VALUE DESCRIPTION X ( 9ANI A Co ts.1 i C__ ea - U 5 3420 OtE;rkAk._ ( 2 E- Ct) (7 (Y1R_ AC-St ruTi4ar) -co 0 CC C2 E-C An- r`l - • rt\-frc: mkt* (xi ._. - ALS-RA:0 0 citzoo. L6.0 Ei￾khn i. r PrN 4 - 12-51-1 , cbtmer2_ 2. - Oct Q.itciv, 0 ivIc, rth-re A-4 O T1,I,A e 0 - CA() i. cbu) a_ 3 - -)kih.n. Ate95i tki)ki 2'r2-\0 a / ci:N --,---( r - -. r i• I-1/6 Yr) 4 / ...„ J • TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents a!I property taken from me and that I havo received a copy of this receipt. • I hereby acknowledge that the above list represents all property Impounded by me in the official ormance of my duty as a poke officer. I C I N TYZ../ -- ----- SIGNATURE DATE SIG DO UNIT RECEIVED BY REASON DATE/TIME RECEIVED OA - i ..- r' 4/ /1 /0 - Or /Z, ( h - .. DETECTIVE BUREAU EFTA00231817 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT DETECTIVE EJREAU P8PO Form rosp ;J PROPERTY ❑ FOUND ❑ DECEASED (Probated) PERSONAL 3 CONFISCATED 3 DESTROY EVIDENCE TRIAL 0 LABORATORY INCIDENT/CITATION NUMBER DATE/TIME RECOVERED 05- 368" io 20 vs ADDRESS WHERE PROPERTY IMPOUNDED 3T8- { WC, r) j STOLEN/RECOVERED U OTHER 6-S PROPERTY NUMBER (Leave Blank) BIN NUMBER ilnaVo Blank) /.),2 /LI • L DISCOVERED BY / D.O.B. ADDRESS Stree: Cory Zhe PHONE NUMBER ADDRESS Street City Zip PHONE NUMBER SUSPECTS NAME,' DCLB￾c) 73 ADDRESS ' Street Lp PHONE NUMBER ADDVNL SUSPECT/ D O.B. ADDRESS Street Cry Zq PHONE NUMBER SPECIAL INSTRUCTONS (.4 fi /IV J OHAN. 711.jE :tETIO . ') V TOTAL PACKAGE WEIGHT I hereby cknowIedge lhat the above ...st represent's al: property taken kern me and that I have received a copy of this receipt. SIGNATURE - - - — • DATE I hereby acknowledge that the above hst represents all property rrpounden by me in the official' performance of my buty,as a police officer. // IDe UNIT RECEIVED BY REASON DATEJTI TME RECEIVED •/ 3. - -?;Y" T ic EFTA00231818 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT °8P0 Form e52 DETECTIVE BUREAU .3 PROPERTY P FOUND P DECEASED (Probated) PERSONAL ❑ CONFISCATED O DESTROY XEVICIENCE INCIDENICITATION NUMBER DATE/TIME RECOVERED PROPERTY NUMBER (Leave Blank) /1.144-as /62E3 e 5- / o 9 1 .A3t 4E;Fjr RE Pkt0PERTY yP 1 OA)1 / 42 04.0 )65 16TRIAL D LABORATORY STOLEN/RECOVERED CI OTHER COVERE OWNERS NA SJSPECT'S NAME / D.O.B. -aosS PST1-;-)Aj, J47.€-Cr ADDRESS Street Cly Zap ADDRESS Street Ory Zip ADDRESS Street City n ccz. < ot.,.(z r ADDRESS Street Cdy Zip BIN NUMBER (Loava MAW / PHONE NUMBER PHONE NUMBER PHONE NUMBER ADDT'NL SUSPECT / D.O.D. PHONE NUMBER SPECIAL INSTRUCTIONS ITEM x QUANTITY VALUE FOUND PROPERTY 90 DAYS CLAIM NOT CLARI TOTAL PACKAGE WEIGHT &Lip DESCRIPTION I horoby acknowledge that the above list represents all property taken from me and that 1 have received a copy of this receipt. SIGNATURE RECEIVED BY I hereby acknowledge that tho above list represents all property impounded by me in the official performance of my duty as a poke officer. ID IC UNIT REAS' DATE/TIME RECEIVED EFTA00231819 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT ",,W0Forme52 a PROPERTY U FOUND 0 DECEASED (Probated) 0 PERSONAL CI CONFISCATED i.) r DESTROY EVIDENCE V TRIAL 0 LABORATORY a STOLEN/RECOVERED ta OTHER • INCIDENTiCiTATION BER C5 ' O (-) DATE/TIME RECOVERED I •C Oc l'oc. /14/4 PROPERTY NUMBER (Leave Bing cmc- 10(.20 - ..., SIN NUMBER (Len Bra* ?F/i/ - I ADDRESS WHEQEPR OPE 53ç3 1 --ii) i SltIS) No p AvA 6tpc (..; D6,C#ERED AD n_,,, r ftin Lea V 19-14// Li PHONE NUMBER OWNER'S NA ADDRESS Street Zip PHONE NUMBER S ECTS NAME: 0.0.B. 2.Q.S icWW 14/ ) ) ) r i (It ADORES Stre.et vjj p\t, 1 7-) -.0 fa. bila It PHONE NUMBER ADDTNL. SUSPECT / 0.O.B. ADDRESS Street 1 PHONE NUMBER SPECIAL' S MBC , ' FOUND PROPERTY -CLAIM 0 90 DAYS NOT CLAIM 0 ITEM a QUANTITY VALUE DESCRIPTION wer C.3 Cyr, ' " — /4/1 P iitrr WI X11 Lk: TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents all property taken from me and that I have received a copy Of this receipt. I hereby acknowledge that the above list represents all property impounded y me in the official performance of my duty as a police officer. T?1, ---l c:52 2 SIGNATURE DATE !DO UNIT RECEIVED BY EASON DATE/TIME RECEIVED 4 (& '; ' ? . *k /5-6r /VVS" DETECTIVE BUREAU EFTA00231820 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT PBPD Form *52 j PROPERTY D FOUND Ca DECEASED (Probated) CI PERSONAL U CONFISCATED D DESTROY EVIDENCE It TRIAL J LABORATORY D STOLEN/RECOVERED Di OTHER INCIDENT/CITATION NUMBER S= 5 6S0 DATE/TIME RECOVERED II ISC5 1 Cs& 30 PROPERTY NUMBER (Leave Blank) (, - ;2 - I (A a BIN NUMBER (Leave Blank) / -2 0iN cz cl #; .4- I ....; ESSEHERE PROPER .I_IVPOUND4ti. y ac...)44....... ) ils s. NAA-6enci-A DISCOV = Cr ADDRESS na pa w 'City 21O 1.- !...) PHONE NUMBER OWNER • ADDRESS Street City Zp PHONE NUMBER SUSPECTS NAME / D.O.B. tt —1C2 '3 3 EC - 1—I t • 4J i ..\ rL7 l'` ADDRESS Street City . . 9$g ri L '2._, it o PHONE NUMBER ADDTNL. SUSPECT./ D.O.B. ADDRESS Street City. ZS, PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLARt .-] SO DAYS NOT CLAIM -1 ITEM a I QUANTITY VALUE DESCRIPTION - I 1 SCr.V., \•-.1. k CPCCASCE14e . i 5 1 ATE4. ME NIT - I i . 0.4.0-Q., L I" i . TOTAL PACKAGE WEIGHT i hereby acknowledge that the above list represents all property taken from me and that I have received a copy of this receipt. I hereby acknowledge that the above kst represents all property impounded b me in the official rformance of my duty as a police officer. .1 9 i c Dt" SIGNATURE DATE ID# UNIT RECEIVED BY REA DATE/TIME RECEIVED DETECTIVE BUREAU EFTA00231821 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT , RPC. Form 052 DETECTIVE BUREAU :a.1 PROPERTY 0 FOUND 0 DECEASED (Probated) 711 0 PERSONAL 0 CONFISCATED J DESTROY %EVIDENCE X TRIAL 0 LABORATORY 0 STOLEN/RECOVERED U OTHER INCIDENT/CITATION NU ER 05 - DATE/TIME RECOVERED 12 t,-705- 5 4-5.? PROPERTY NUMBER (Leave (Bank) a5 Ps BIN NUMBER (Leave tank) • /2/Iii ADDRESS 345 WHERE PROPERTY IMPOUNDED 1-:2 - • Cou &TT y - poA.0 . t. (3 FV VERE / 1-• ADDRESS 2 ii_ SPAof f City Zip PHONE NUMBER OWNER'S N ADDRESS Street City Zip PHONE NUMBER SUSPECT'S NAME/ O.O.B. a,- 2.0 c, '6,...NT (Elki. jeic ADDRESS Street, City Zip SS% EL. Gref (to PHONE NUMBER AMINE SUSPECT/ D.O.B. ADDRESS Street City 29 PHONE NUMBER Sper INSTRUCTIONS i AsE. Cu() y oktio ShAyioNto usSr1.14-e" FOUND PROPERTY CLAIM, 'i 90 DAYS NOT CLAIM ii -ITEM Y 'QUANTITY VALUE DESCRIPTION 1 . e. ( 5 1D-4E_ 7. - -.) ... IQ T •- ',..,:- ' tj . I. , TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents all property taken from me and that I have received a copy of this receipt. I hereby acknowledge that the above ist represents by me in the official performance of my duty as a police 1 4 11c all property impounded officer. \) .3 SIGNATURE DATE !DO UNIT - RECEIVED BY REASON i DATE/TIME RECEIVED AIS 2 )1 c 2.- / t CS 6 730 •,..,- EFTA00231822 ..k•-kl?"4--."--kt'", • -kk- ki3O:kelikaikirkelPkvienrecasena.... PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT whca4e4**Wka"rEACISak DETECTIVE BUREAU Pe PO Font, 152 i U PROPERTY D FOUND 3 DECEASED (Probated) U PERSONAL 3 CONFISCATED DESTROY EVIDENCE RIA U LABORATORY C..1 STOLEN/RECOVERED :3 1 OTHER • INCIDE, I/CITATION NU ER DATE/TIME RECOVERED PROPERTY NUMBER (Leave Blank) BIN NUMBER (Leave Blank) , i T ADDRESS WHERE PROPERTY IMPOUNDED ? 5 5". Cct, ♦ .. A h c c DISC VER ADD Sit Oa C I Zip Pi FAZ i c/ r fr PHONE NUMBER OWNER'S N A RESS Stater Cy I PHONE NUMBER SUSPECTS N Et' D.O 8. 1-- 7-7-(2 • / / r ADDRESS Street .. // Zip PHONE NUMBER AD VNL. S SPEC 11.0 i ADCMESS Street City Zip PHONE NUMBER SPECIAL INSTRUCTIONS • /t tykt J ITEMS C 'ANTITY VA4. JE IiII::: I U e,/,/ tv,12/ 5...„(„76?---2.5_ Ityf _ r- ___ ----71.171ile:// . ft.,:yett / - c '41-e ' cc' f:iVir - '.. - - I A Cc i:e. ...ain -- , ... ( . .' ; .1 i "........-: / fr ' //.7 ' .-.1 • - - '''-tt..-'. • __._ -.--... . ...! .. . ". Y 't I(- . 62 ey ,... S -C - - - . . l/ *LS 04' - 0 i c;17 - OL" • • .L. TOTAL PACKAGEWEIGHT .1 hereby acknowledge that the above list represents all property taken Dom me and that I have received a copy of this receipt. I hereby acknowledge that the above list represents all property impounded by as a police officer. t e -,c71 - 7 V:-.??. . SI "- SIGNATURE DATE IOU UNIT RECEIVED BY REASO ATEfTIME RECEIVED 4 .4 :1 :1:.... i ..2t 3 .- e , i . • / 7 .7 i f '>• EFTA00231823 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT PSPO Form /52 a PROPERTY fa FOUND a DECEASED (Probated) O PERSONAL' a CONFISCATED a DESTROY aEVIDENCE taTRIAL O LABORATORY a STOLEN/RECOVERED a OTHER INCIDENT/CITATION NUMBER 05 - -)6ce) DATE/TIME RECOVERED 14.-._ u-1 O s. z:-..;-50 PROPERTY NUMBER (teen Blank) (-- : -1 1C) - BIN NUMBER pave Bibs() . ADDRESS WHERE PROPERTY IMPOUNDED DISCOVER ,ir: I ADDRESS n aty DP V" r > PHONE NUMBER OWNER'S ADDRESS Street Cay Zip PHONE NUMBER SUSPECTS NAME / D.O.B. \' ! U S 2.. P c)C, 1 I C." i.J, :r(4 ADDRESS Street , City a 3St.) r i 't--, --" 17 k\kka PHONE NUMBER ADDTNL SUSPECT/ D.O.B. ADDRESS Street CZ, a PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM CI 90 DAYS NOT CLAIM L] ITEM 0 QUANTITY VALUE DESCRIPTION .7 I k G 1) \I D. 2..- 0 k scs V {7 u, m ,Vr9 \ 7L s5\ 4- 1. 7 05 2500V7 'ARIA-ED , c ., 1 to 'lc( TEA N-) CI t14/1USE P ‘ L5 , ? TOTAL PACKAGE WEIGHT I hereby acknovAedge that the above list represents al property taken from me and that I have received a copy of this receipt. I hereby actmovAedge that the above list represents all property Impounded of my duty as a police officer. SIGNATURE DATE IN UNIT RECEIVED BY REASON \ DATE/TIME RECEIVED e 1 1 ----.._.../ . , • 1 a • CONTRIBUTORS COPY EFTA00231824 .7Tr.T.Tr iEnT• T TT, PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT POPO Form •52 DETECTIVE BUREAU CI PROPERTY CI FOUND 0 DECEASED (Probated) D PERSONAL 0 CONFISCATED CI DESTROY NC O . EVIDENCE STRIAL 0 LABORATORY 0 STOLEN/RECOVERED CI OTHER INCIDENT/CITATION NUMBER OS - 3(g DATE/TIME RECOVERED ' OI 010 to ‘ 1;0 PROPERTY NUMBER (Lkave Mat) !o ......) BIN NUMBER (lain Blank) /2 ? / 9-/ AD31294WHEFE-PROPEFY IMPOUNDED _) t LOAD DISCOVERED A • ADDRESS .-,)gtp 1) Gay LP PHONE NUMBER OWNER'S NA ADDRESS Stan/ - City Zp PHONE NUMBER SUSPECT'S NAME / 0.0.13. ' - Cr 'S5 t :1r 74MN . le c ADDRESS Street Cry DP SR 1.- c Pi:: , if ( , i ca PHONE NUMBER ADDTNL. SUSPECT/ 0.0.B. ADDRESS Street Cry ZIP PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM U BO DAYS NOT CLAIM ..) 1 ITEM a QUANTITY VALUE DESCRIPTION i 1 or.1 Pr Ck Lo CP Sc..) q 1, i TOTAL PACKAGE WEIGHT lereby acknowledge that the above list represents all property taken )m me and that I have received a copy of this receipt. I hereby acknowledge that the above list represents all property impounded b e in the official ;dodo:mance of my duty as a police officer. —1 (LO C \ s) Q ) BNATURE DATE SI IDtt UNIT RECEIVED BY REASON \ 1 WI DATE/TIME RECEIVED L iN— ig 3 M ‘C It - (1 / ' /0 — 0 (r 6 73 6 r ;or of EFTA00231825 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT PBK, CDrfn DETECTIVE BUREAU t. art I ...1PROPERTY ..J FOUND 7..) DECEASED IProbaled) UPERSONAL 0 CONFISCATED Ci DESTROY 21Eicii0E;4cE • ••01-FRIAL j LABORATORY U STOLEN.RECOVERED L.I OTHER INCIDENT CITATION NU BEIT 1DATEITIME RECOVERED PROPERTY NUMBER (Leave BtarS . r ION NUMBER (Leave Blank) -( e OYJNERS PAID PsAci4 6r)Qs . f L ADDRESS Street Gry Zip PHONE NUMBER ADDRESS Street ;City - . - Zip PHONE NUMBER ag.ISPECT'S NAME! 0:35 , "i V) +acne') i 3q ADDRESS Sneer\ • cry Z.p L Vail (I0 PHONE NUMBER ADDTNL SUSPECT.' D.O.B. ADDRESS Street Cary Zip . PHONE NUMBER SPECIAL INSTRUCTIONS t FOUND PROPERTY CLAIM 0 9O LAYS NOTCLAIM 0 ITEM a 01,A 'TI v VALUE 1 DESCRIPTION ‘.4 1C ILO CASSEC E rgilE . ) TOTAL PACKAGE WEIGHT I hereby acknowledge that the abo: e rst represents all property taken from me and Thai l have received a copy clihis receipt. . .. ,SIGNATURE DATE I hereby scknooedge that the above I:st represents all •• • - - - • • •• of my duty as a ['oho • IN' property impounded officer. - UNIT-, RECEIVED BY RE .ON DATE/TIME RECEIVED >10S) 3 3 IC (-- 7)) .1:)c.%:-Ott, 6 -7I Is' EFTA00231826 (ATTACH TOAFFIDAVIT) ff ROPY SEARCH WARRANT IN THE CIRCUIT COURT OF THE 1 Di 1 JENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA THE STATE OF FLORIDA ) COUNTY OF PALM BEACH ) IN THE NAME OF THE STATE OF FLORIDA, TO ALL AND SINGULAR: The SheriffofPalm Beach County, Florida, and his lawful Deputies, All Police Officers in Palm Beach County, Florida, The Commissioner of the Florida Bureau of Law Enforcement or any of his Duly Constituted Agents to-wit: Detective WHEREAS, complaint on oath and in writing, supported by affidavit of a credible witness, or witnesses, to wit: Detective which is attached hereto and made a part hereof, has this day been made before the undersigned: Judge Laura Johnson (CircuitXCounty) Court Judge in and for Palm Beach County, Florida, and WHEREAS, said facts made known to me and considered by me have caused me to certify and find that the facts set forth in said affidavit show and constitute probable cause for the issuance of this warrant and the Court being rstisfied of the existence of said grounds set forth in the affidavit and that the laws of the State of Florida have been violated on or in a Premises known and described as follows, to-wit: 358 El Brillo Road Palm Beach, Florida 33480 To reach the premise desired to be searched, begin at the middle span oldie Royal Park Bridge and travel East on Royal Palm Way approximately .6 (six tenths) of a mile until you reach South County Road. At South County Road, make a right or southbound tum and travel approximately .8 (eight tenths) of a mile to El Brillo Way. At El Brillo Way, make aright or westbound turn and travel approximately .1 (one tenth) of smile to the last house on the South side of El Brillo clearly marked with the number 358. The premises desired to be searched is two story, single family residence made of CBS construction. The residence is pink in color with white trim and has a white concrete tile roof. The residence has two separate . iveway entrances from El Brillo paved in large white tiles. The eastern most driveway is separated by a large white in color concrete wall with black in color numbers "358" clearly displayed from El Brillo and leads to the east side of the residence. EFTA00231827 On the east side of residence, there are three single car garage doors, which are white in color and an entry door also white in color to South. Each driveway entrance has a white in color call box, which is fixed on the east side of the driveways. The western most driveway leads to the North side of the residence, to a large white in color double door on the first floor. The second story of the North side ofthe residence shows a small walkway with white in color metal railway, and leads to three glass jalousie style doors. On the South East corner of the residence is a single story structure, made of CBS construction and is white in color with a white concrete tile roof. To enter and search the afore described place and premise together with the yard and curtilage thereof, and any and all outbuildings and vehicles thereon, and any persons residing therein, and any other person therein reasonably believed to be connected with said illegal activity. This is a complete description of the residence desired to be searched, including the curtilage attached thereof. being the premises occupied or under the control of: Jeffrey Epstein W/M Date of Birth 1-20-1953 and there is now being kept in the above described (vehicle)(premises) certain: 1) Computers, including any electronic magnetic, optical, electrochemical, or other high speed data processing device performing logical, arithmetic, or storage functions; data storage facilities such as magnetic tape, hard disk, floppy disk or drum, or cd rom; communications facilities directly relating to or operating in conjunction with such device; devices for printing records of data; and such records or data produced in various forms; manuals, documents, or instructional material relating to such devices. 2) Computers, personal computers, computer peripherals, modems, computer printers, floppy disk drives, hard isk drives, diskettes, tapes, computer printouts, computer software, computer programs and applications, computer manuals, systeni documentation. 3) Cameras, photographs, negatives, motion pictures, videotapes, magazines, books, and all other depictions of minors in sexual activity . 4) Any device or equipment that can be used to transfer images to a computer readable format. 5) Any written documentation or item containing password or encryption codes. 6) Any notes, ledger, personal phone books, roladex, books and any form of recording data of records of payments, telephone numbers and names of girls that have frequented the house. 7) Any sexual devices to which was used on the witness/victims. 8) Any hair fiber, semen, or other bodily fluids. which is being kept and used in violation of the laws of the State of Florida, to-wit the laws prohibiting: 1. Sexual Activity with certain minors Lewd and Lascivious Molestation FSS 794.05(1) FSS 800.04(5c2) 2M degree Felony 2ed degree Felony EFTA00231828 NOW THEREFORE, you, or either of you are hereby commanded with proper and necessary assistance, in the name of the State ofFlorida, in the daytime or in the nighttime, or on Sunday, to forthwith search the said premises hereinbefore specified, for the property specified, and if the same, or any part thereof shall be found in said premises then you are authorized and commanded to seize the same and to bring the property and any person tested in connection therewith before the Magistrate or any other Corot having jurisdiction of the offense, to be dealt with according to law, and to forthwith make return ofyour doings upon executing this warrant, which you are hereby commanded to execute as the law directs within ten (10) days from the date thereof. You are further commanded, in the event that you seize any of the said property hereinbefore described, to make up, at the time and place of seizure, a full, true and itemized list and inventory of all things seized and taken, in duplicate, signed by you, and to then and there give and deliver the said duplicate copy thereofto the person from whom possession shall be taken, iftaken from the possession ofanyone, together with a duplicate of this warrant, and if not taken from the possession of anyone, then to any person in charge of said premises, and in the absence of any such person, to leave the same on or in the premises. The original of this warrant, together with the original inventory, shall be returned and filed with the Clerk of the Court as stated above within ten (10) days of the issuance of this warrant. Further any property seized or taken shall be impounded for use as evidence at any trial of any criminal or penal cause growing out of the having or possession of said property. WITNESS my hand and seal this 18th day of October, A.D., 2005. JUDGE of the Circuit Court of the Fifteen Judicial Circuit in and for Palm Beach County, Florida. EFTA00231829 AFFIDAVIT AND APPLICATION FOR SEARCH WARRANT IN THE CIRCUIT COURT IN AND FOR PALM BEACH COUNTY, FLORIDA THE STATE OF FLORIDA, ) COUNTY OF PALM BEACH ) BEFORE ME: Honorable Judge Laura Johnson in and for Palm Beach County, personally appeared this day: Detective COPY who being by me first duly sworn, deposes and says that he believes and has good reason to believe that a certain Premises located in Palm Beach Florida, described as follows, to-wit: 358 El Brillo Road Palm Beach, Florida 33480 To reach the premise desired to be searched, begin at the middle span of the Royal Park Bridge and travel East on Royal Palm Way approximately .6 (six tenths) of a mile until you reach South County Road. At South County Road, make a right or southbound turn and travel approximately .8 (eight tenths) of a mile to El Brillo Way. At El Brill° Way, make a right or westbound turn and travel approximately .1 (one tenth) a mile to the last house on the South side of El Brillo clearly marked with the number 358. The premises desired to be searched is two story, single family residence made of CBS construction. The residence is pink in color with white trim and has a white concrete tile roof. The residence has two separate driveway entrances from El Brillo paved in large white tiles. The eastern most driveway is separated by a large white in color concrete wall with black in color numbers "358" clearly displayed from El Brillo and leads to the east side of the residence. On the east side of residence, there are three single car garage doors, which are white in color and an entry door also white in color to South. Each driveway entrance has a white in color call box, which is fixed on the east side of the driveways. The western most driveway leads to the North side of the residence, to a large white in color double door on the first floor. The second story of the North side of the residence shows a small walkway with a white in color metal railway, and leads to three glass jalousie style doors. On the South East corner of the residence is a single story structure, made of CBS construction and is white in color with a white concrete tile roof. To enter and search the afore described place and premise together with the yard and curtilage thereof, and any and all outbuildings and vehicles thereon, and any persons residing therein, and any other person therein reasonably believed to be connected with said illegal activity. This is a complete description of the residence tiecirritabeSearChed inrhu-lin • hr rurtilar sttarhed thereof. being the Premises occupied by or under the control of: Jeffrey Epstein -vfm Date of Birth 1-20-1953 Page 1 EFTA00231830 and there is now being kept on the above described Premises certain: 1) Computers, including any electronic magnetic, optical, electrochemical, or other high speed data processing device performing logical, arithmetic, or storage functions; data storage facilities such as .gnetic tape, hard disk, floppy disk or drum, or cd rom; communications facilities directly relating to or operating in conjunction with such device; devices for printing records of data; and such records or data produced in various forms; manuals, documents, or instructional material relating to such devices. 2) Computers, personal computers, computer peripherals, modems, computer printers, floppy disk drives, hard disk drives, diskettes, tapes, computer printouts, computer software, computer programs and applications, computer manuals, system documentation. 3) Cameras, photographs, negatives, motion pictures, videotapes, magazines, books, and all other depictions of minors in sexual activity . 4) Any device or equipment that can be used to transfer images to a computer readable format. 5) Any written documentation or item containing password or encryption codes. 6) Any notes, ledger, personal phone books, roladex, books and any form of recording data of records of payments, telephone numbers and names of girls that have frequented the house. 7) Any sexual devices to which was used on the witness/victims. 8) My hair fiber, semen, or other bodily fluids. which is being kept and used in violation of the laws of the State of Florida, to-wit: the laws prohibiting: 1. Sexual Activity with certain minors 2. Lewd and Lascivious Molestation FSS 794.05(1) FSS 800.04(5c2) • 2U degree Felony 2°' degree Felony That the facts establishing the grounds for this application and the probable cause for believing that such facts exist are as follows: On 03/15/2005, Det went to High Ridge/Sable Palm where she met with a fourteen ear old white female. The female will hereinafter referred to as "The Victim." Also present was the victim's thera ist. During an audio taped interview, spoke with the victim who admitted to knowing that worked for a wealthy man and possibly did sexual favors for him. She also admitted that had offered her an opportunity to make money. The victim identified￾identified asieff to Jeff's house. The victim stated boss as a white male named "Jeff who lived in Palm Beach Later positively to go with her told her that she would pick her up at the victims house on Sunda . The victim was not sure of the exact dates but knew it was a Sunday. According to the victim, along with a Hispanic female, later identified as =, picked her up at her father s house on 76th ane. The victim told her father that they were going shopping. It was later confirmed by the victim's father ...at picked his daughter up on February 6, 2005. According to the victim's father, drove Page 2 EFTA00231831 a pick up truck. drove the victim to Palm Beach. Sometime on the way there, a conversation occurred between and the victim whereas reportedly told the victim that if Jeff asked her (the victim) age, she should say she was eighteen. The victim recalled that Jeffs house was on a dead end street. The victim described Epstein's house as a two story pink house with a Cadillac Escalade parked in driveway. The girls walked up a driveway, past what appeared to be a snakard/security room. In ract, the victim recalled a male approaching them asking what they wanted. stated they were there to see Jeff. The male allowed them to continue walking up to the house. The victim stated the man told them that Epstein was not there but was expected back. He allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside. Shortly after, Epstein and a woman, described as white with blond hair entered the kitchen. The victim believed the woman was Epstein's assistant. The victim added that the woman did not seem friendly and kept her responses short and direct. Epstein introduced himself to the victim as Jeff . The victim described Epstein as being approximately forty-five years old, a long face, and bushy eyebrows, with graying hair. and Epstein left the kitchen leaving the victim alone in the kitchen. They returned a short time later. They all spoke briefly in the kitchen. The victim stated the woman instructed her to follow her upstairs, which she did. The victim recalled walking up a flight of stairs, lined with photographs, to a room. Upon entering the room there was a large bathroom to the right. The victim recalled a hot pink and green sofa in the room. There was a door on each side of the sofa. The victim recalled there being a mural of a naked woman in the room, as well as several photographs of naked women on a shelf. According to the victim, the woman led her to a room that had a massage table in it. The woman started to fix up the room, putting the covers on the table and taking lotions out. She then told the victim that Epstein would be up in a second. The woman left the room, and soon after, Epstein walked in wearing only a towel and told the victim to take ^ff her clothes. The victim stated he was stem when he told her to take off her clothes. The victim said she _A not know what to do as she was the only one there in the room. The victim took off her shirt leaving her bra on. Epstein, had removed his towel and told the victim to take off everything . The victim stated Epstein exposed himself when he took his towel off, placing it on the floor as he laid down on the table. The victim stated she removed her pants leaving her thong panties on. Epstein then instructed her to give him a massage pointing to a specific lotion for her to use. As the victim began to give Epstein the massage, he told her to :et on his back. The victim stated she straddled herself on Epstein s back. The victim stated The victim said Epstein was specific in his instruction to her on how to massage, telling her to go clockwise, etc. Epstein then turned over and instructed the victim, to massage his boobs. The victim resumed massaging his chest area. The victim was now standing on the ground. Epstein turned to his side, started to rub his penis in an up and down motion. The victim stated Epstein held on to the small of her back as she massa ed his chest and shoulder area. Epstein pulled out a u le vibrator and . The victim stated there was no penetration as the . The victim recalled Epstein ejaculating because he had to use the towel to wipe himself as he got off the table. E then left the room and the victim got dressed. She went back downstairs where she met with . The victim admitted to getting paid three hundred dollars in cash from Epstein. Before they left, Epstein asked the victim to leave her phone number. As they were leaving the house, stated she received only two hundred dollars that day for bringing her. Page 3 EFTA00231832 On October 3, 2005. 2:g and I responded to the address of and viewed her vehicle parked in the driveway. Sgt.= and I knocked on the door and met with was told that we were investigating a claim involving Jeffrey Epstein of El Brillo in Palm Beach.■ w was asked if she wanted to accompany us back to the police station for further questioning. She was also told that at the iclusion of the interview she would be returned home. Upon entry in the unmarked Detective vehicle, I placed a tape recorder within the vehicle to record any conversations within the vehicle. Durin the ride back to the olice station, advised she is attending in the and is majoring in journalism. Upon our arrival at the police station, was brought to the interview room in the Detective Bureau. I explained to , that I appreciated her willingness to assist us and informed her that should she desire to leave at any time she may do so. I further explained the interview room door is only closed for privacy. stated she understood. During the taped sworn was asked how she became in contact with Epstein. stated back when she turned of age she was approached by a friend a in the Canopy Beach Resort in Rivera Beach. was asked if she wanted to make money. She was told she would have to provide a massage and should make $200.00. thought about the offer and agreed to meet with Jeffrey. (Unknown last name) and (Unknown last name) picked her up and she was taken to Epstein's house. Upon her arrival to the house she was introduced to Epstein in the kitchen of the house. She was also introduced to a white female known to her as M. She was led upstairs to the main bedroom known to her as Jeff Epstein's bedroom . arranged the massage table and covered the table with a sheet. She brought out the massage oils and laid them next to the massage bed. then left the room and informed her Jeff would be in, in a minute. Jeff entered the bedroom wearing ply a towel. He laid on the table onto his stomach and picked a massage oil for to rub on him. stated "He tried to touch me and I sialhim." I asked how did he tried to and she felt uncomfortable. also stated Epstein has a vibrator told Epstein, I'll massage you but I don't want to be touched. -during the massa touch her. He which is large and white in color. stated she performed the massage naked. At the conclusion of the massage, Epstein paid $200.00 for the massage. He explained, I know ou're not comfortable, but I'll pay you if you bring some girls. He told her the younger the better. stated she once tried to bring a 23 year old female and Epstein stated that the female was too old. E stein. stated six that she can remember. was asked how many girls did she bria 61 total to stated she brought M. (16 female), (16 female), and at the time they were brought to Epstein's house, all the girls were 14 through 16 years of age. I asked which one was the yows. advised the victim was the youngest as she was fourteen when the massage occurred. stated every girl she brought knew what to expect when they arrived. They were told they would provide a massage, possibly naked, and some touching. I asked her if the victim was aware. She stated every girl she brought knew what to expect. She explained she knew the victim wanted to make money . She approached the victim and explained about going to work for Jeff. The victim agreed and arrangements were made to brin the victim to Epstein's house on a weekend. stated that she and (Later identified as ) picked up the victim at the victim's house. They traveled to E ns House and entered through the kitchen door. They met with the house chef and Epstein's assistant M. The victim was introduced to Epstein while they were in the kitchen area. led .e victim upstairs and Epstein went upstairs. When the massage was over, the victim returned to the kitchen area. Page 4 EFTA00231833 stated she was paid $200.00 for bringing the victim to Epstein's house. stated the victim told her she was paid $300.00 for the massage. Back in the vehicle, asked the victim what happened. The victim told her about the massage and they went shopping. stated the victim was the last person she brought to Epstein. She further stated that she had changed her cellular number to avoid ng contacted M. She continued that when Epstein announces to his assistant that he is traveling to Palm Beach, would contact to arrange girls for Epstein. stated that once her parents discovered that she was visiting Epstein, they disapproved of the encounters with him and she stopped. further stated that Estill tries to call the house and leaves messa es. With the assistance of , we were able to identify , DOB DOB DOB and DOB Sgt entered the room and explained that based on her own statements, she had implicated herself by bringing underage girls to Epsteins house. was aware of what she had stated and wished to assist further in hopes to receive a lesser charge . provided cellular telephone numbers for the girls she had mentioned previously. Additionally, she also provided possible addresses and areas in which they lived. As was being taken home in the vehicle, a tape recorder was placed within the vehicle to record any conversations within the vehicle. During the drive back to her home, made the comment " I'm like a Heidi Fliess". (Hollywood Madam who sent girls to clients for sexual favors in California). was dropped off at her house without incident. Sgt and I went to speak with We met with ( Mother) at the front door. We explained the ongoing investigation and felt tha may have additional in ormation as we had information that she had "worked" for M. introduced us to her husband and allowed us entry into the home. We sat in the dining room and met wi Date of Birth . As she was under the age of eighteen, was 'vised we would be spe n with her. She expressed if her daughter had information, she wanted to “osist. As we interviewed. she denied having any inappropriate encounters with Jeff (Epstein). She stated she had gone to Jeff's House with approximately eight months ago, and sat in the kitchen with the house chef, but nothing happened. As the parents were present during the interview, we felt that was withholding information from us. She made several comments as to she has put the entire incident behind her. I left my direct telephone number and advised should she wish to speak with me again to telephone me. Sgt and I thanked for her time and left the area. She stated she would ask her again after we left as to what happened at Epstein's house. I informed her thathad my telephone number and hopefully she would call. On October 4, 2005, Det and I drove to the home and met with . During a sworn taped statement, stated she was taken to house by She was told she could make money working for Jeff. She was told she would have to provide a massage to Jeff. met with the house chef who was already in the kitchen area. stated upon her arrival to the house she was brikt to the kitchen area b . They stated would wait for her in the kitchen. She was introduced to M, Jeff's assistant, and was brought upstairs to the mater bedroom.. prepared the room and massage table for a massage. Epstein entered the room wearing only a towel and she provided a massage. stated she kept her clothes on during the massage. She advised sometime during the massage, Epstein and pulled her close to him. said she was uncomfortable by the incident involving Jeff. At the conclusion of the massage, she as paid $200.00 for the massa e. I asked if she has any formal training in massages to which she replied no. I asked her if received any monies for taking her to perform the massage. Page 5 EFTA00231834 S tated also received money for takin her there but was unsure in the amount of monies received for bringing her to Epstein. stated she returned to Epstein's house on another occassion with and another girl, stated she waited in the kitchen with , while was taken upstairs by stated she only did the massage once as she was comfortable with the whole experience. At the conclusion of the interview, the tape was stopped. I was informed that. had attempted to reach via cell phone. A voice mail mess e on October 4, 2005 at 10:59 am, revealed a female voice who identified herself as . who requested to call her back reference the police questioning. This voice mail message was recorded onto a micro cassette. rovided the incoming telephone number as stated she inadvertently told about the police investigation because had called her to tell her about how she just received a rental car from Jeff Epstein. had called her to tell her that she was given a rental car, a 2005 Silver Nissan Sentra, to utilize to visit family and visit Jeff. asked her what was going on at the house that the police would be asking questions. stated then called Jeff and M and asked what was going on reference the ongoing police investigation. According to s, a . has since then been trying to contact her to ask about the I instructed not to contact. and do not provide any more information to as she would notify Jeff Epstein and. what was transpiring. On October4, 2005, I made telephone contact with.who had left several messages on voice mail. During the message, she advised she was not completely truthful when we met in person but would like to speak with me to advise what had happened. She further advised she did not wantaak of this incident in front of her mother. At approximately 15:48 pm I made telephone contact wit During a taped recorded statement,Mstated the following: Approximately a year a o when she was sixteen years of age, took her to house twice. The first time she went drove to the house. They entered rosik the kitchen area where she was introduced to and Jeff. She was taken upstairs to a bedroom uy and set the room up with a massage bed and brought out the oils to use. then entered the room wearing a towel . He laid on the table and picked out a lotion for J to mb on him. At one point during the massage, he tried to remove her shirt at which point she became very upset and discontinued the massage. Both • and Jeffrey had a verbal disagreement at which time she left without being paid. no money for that day. lso said that had told her if she was uncomfortable with what was She got with who was sittin in the kitchen and told her "let's go." .advised she received going on, to let him know and he'll stop. She knew that the more you do the more you get paid. ,advised that several weeks later, she agreed to be taken a second time by . Once they arrived at the residence, sat in the kitchen, and took her upstairs to the master bedroom again. El set the room up with a massage bed and brought out the oils to use. Jeff then entered the room wearing a towel. He laid on the table and picked out a lotion fore° rub on him. At one point during the massage, he tried to touch her buttocks. As Mwas wearing tight jeans and had a tight belt on Jeff was unable to touch her buttocks. Jeff then rolled nntn his hack during1he.marempted to touc er bre then ame u set a ain and told she didn't want to be touched. discontinued the massa e and was paid $200.00. then went downstairs where was waiting for her. She told she wanted to leave. said she never returned to the house. stated she is aware that her friend, was also at the house and had a problem with C. She provided a telephone number for The interview was concluded .nd the micro cassettes were turn in as evidence. Page 6 EFTA00231835 I later researched and discovered she resides in Royal Palm Beach. Det and I drove to Royal Palm Beach and met with at her residence in Royal Palm Beach. llowmg: On or about November 2004, She was approached by agreed to speak with us in the kitchen area. During a sworn to statement, stated the and asked if she wanted to make money. She agreed and was told she would provide a massage to wealthy man in Palm Beach. picked her up and drove her to a house in Palm Beach. She was brought into the kitchen area of the house. She further stated that M. and name with them. They were brought into the kitchen where she was introduced to Jeff and other females. stated she was introduced to a female helper of Jeff, the female was described as white female (unknown name ), with blond hair. She stated that the assistant was familiar with . The assistant brought her upstairs into a master bedroom area. The assistant set up the massage table and put out lotions to be used. She told , Jeff would be available in a minute. Jeff entered the room wearing only a towel. Jeff removed his towel, exposing himself , laid on the massage table and picked a lotion to rub on his thighs and back. further stated .du the massage, Jeff asked her to remove her clothes. She complied and removed her pants and blouse. didn't remember if she had removed her bra but feels that she did. was certain that she stayed in her thong underwear. continued the massage and at one point she straddled him to massage his back, which Jeff turned to have his chest rubbed. was instructed to return to the ground at advised she was unsure if he was masturbating. did not want to look at his penis area because she was uncomfortable. Jeff removed a lar e white vibrator which was next to the bed and turned it on. MI stated he began thong underwear on her vagina area. Shortly thereafter, ejaculated and removed himself from the table. He walked over to where the shower was and opened the glass door. She waited as he was taking a shower in her direct view. When I asked how old she was when this occurred, she stated she had just turned seventeen. At the conclusion of the shower, was paid either $350.00 or $400.00. She stated she rasn't sure , but knows it was close to $400.00. At the conclusion of the interview, stated she never returned to provide a massage for Jeff. She advised she was ashamed and uncomfortable with the situation. At approximately 2:10 pm, Det and I met with'. at her residence. As was only seventeen years of age, I had notified her mother , that she would be interviewed reference an ongoing investigation in Palm Beach. I assured her that her daughter was not a suspect. I explained the possibility of her being either a witness or victim. advised she wanted to cooperate and consented to the interview. During a sworn taped statement, stated the following: at the age of sixteen, during the month of September 2004 she was approached by for a chance to make money. was friends with the friends of and knew the same people. had been previously told by her friends what did for Jeff. called a person known to as and scheduled the appointment picked i up and drove her to Palm beach to a street called Brillo Way. They drove to the end of the street and entered a large driveway. They entered the kitchen area of the house and met with Jeff. U was introduced to Jeff. stated she observed numerous photographs of naked young girls throughout the house. led Upstairs In the main bedroom area and set uWom with a massage table and set out the oils. dimmed the lights and turned on soft music. exited the room and Jeff entered the room wearing only a towel. Jeff picked a oils and instructed her to rub his legs, under his buttocks, back and chest area. Jeff asked her to get comfortable. U advised she did not remove her clothes. She was wearing tight jeans and a cropped tank top exposing her belly area'. Page 7 EFTA00231836 During the massage, Jeff removed his towel and laid op the massage table naked. A e, Jeff attempted to reach down her pants through the buttocks area however wasitlible to due to the tightness of the jeans and a tight belt. advised Jeff began to masturbate as she rubbed his chest. le moaned as she rubbed his chest. She observed he was continuing to masturbate and attempted to reach up T tank top and touch her breasts. M, pulled back and Jeff stopped. However, he kept masturbating until Ile climaxed. He cleaned himself with the towel he was previously wearing. I asked if she knew the difference about circumcised and not circumcised meant. She explained she knew and advised ■ was circumcised. was paid $200.00 for the massage. And left the area. She met with who was waiting in the kitchen area and left the house. then explained she never provided another massage for She did however, go to the house with and 1 as they took another friend of . • advised she was present when went to work for Jeff. She advised she rode over and sat in the kitchen area with to wait for . advised while they waited for , the house chef prepared lunch for them as it was almost lunchtime when they went. As was finished with the massage, they left the area. I asked if ever told her what would be expected when she provided a massage. IN stated yes, told her that a massage would be expected possibly naked and possibly some touching involved. has no formal training in providing massages. e spoke about a third and last time she went to Jeff's house. drove another girl, who is friend, to Jeff's house. stated knew that had made money, massaging and wanted to make money herself. took them in the kitchen area of the house and introduced toe. and. took upstairs to the main bedroom. advised she doesn't know what happened as did not speak about what happened in the room. received $100.00 from for going with her to Jeff's house and recommending was unable to remember T acotta's telephone number. The interview was concluded and we left the area. On October 6, 2005, at 11:45 am, I met with at and lined to her why we there to interview her. She advised she was aware of the ongoing investigation. stated she had previously igen with who told her she was interviewed by detectives. During a sworn taped statement, stated she knew that worked for Jeff in Palm Beach. advised she has been there a lot of times for massages. I asked her if she had formal training in providing massages, which stated she had not. advised she was told what was expected of her by providing massages and would have to remove clothing but if she felt uncomfortable just to say so and Jeff would stop pushing the issue. began providing massages and advised she kept her clothes on. She considered Jeff a pervert and he kept pushing to go further and further. explained she would keep telling him she had a boyfriend and would not be right to her boyfriend. It wasn't until recently, admitted to removing her clothes and staying in her thong underwear to provide a massage. explained he wanted to be rubbed on his back and recently he began turning over and have her rub his chest as he masturbated. He would try to touch her breasts as she rubbed his chest. stated "Jeff would try to get away with more and more on each massage". Originally, drove her to the house for the original massage. left her cell phone number and every time Jeff would come into town, would call her for an appointment. Each time s e went, would meet her at the kitchen door area. She would bring her upstairs and re are the massage table. advised would ask hearestions about her. He knew she was and would be attending . I asked if he knew her real age, stated Jeff didn't care. The most recent massage she provided was in October 1, 2005. Page 8 EFTA00231837 Durig_. the massage, she asked Jeff if she could borrow one of his vehicles to visit her family and boyfriend in Jeff had told her she could borrow one of his vehicles but later stated he would rent her a car. She continued with the massage as Jeff and caressed the buttocks checks. I asked￾if she was wearing undergarments to which she replied her dagi: underwear. Once he tried to touch her hreasts, she would pull away from him and he would stop. was asked if he ever used a vibrator on was aware of the vibrator but advised she never would allow him to on her. She described the vibrator as the large white vibrator with alsic head on the tip of the vibrator. She stated he kept the vibrator in a closet near the massage table. advised she had been doing the massage for approximately two years which meant she would have started doing massages for Jeff at the age of sixteen. stated she was contacted by. on October 3, 2005. S had informed her that Jeff had rented her a new Nissan Sentra and she should come by the house to pick it up. IMI informed she would have the car for a month. stated Jeff knew her car was not working properly and had missed appointments in the past because of her car being inoperable. explained the car is currently parked next to the G field. I asked her if she ever took an one to the house. explained she took , a friend of hers who has returned to to attend college. I asked if she ever allowed another female in and I the room. advised no the was brou t into the room with her. At the conclusion of the interview, Det vent to the Gym area of and located the Silver Nissan Sentra bearing Florida tag . The vehicle is registered to Dollar rent a car out of the Palm Beach International Airport. On October, 11, 2005 Det and I had traveled to and met with date of birth, explained she had gone to Epstein house since she was sixteen. She explained she was brought to the house to perform a massage by Shasty . Once she began explaining that the massage immediately escalated to other things, she further explained she had gone to the house mdreds of times. S stated she became his "number one girl." She would enter the house and get naked in the bedroom. She would then start with a back massage. Epstein would roll on to his back and allow her to massa e his chest area. stated E stein would then began to masturbate himself and at the same time would with his fingers. S explained Epstein would continue thiLpLocess until he ejaculated. He would then utilize a vibrator/massager on her vagina until S ejaculated. M advised that during her frequent visits, Epstein asked for her real age, S stated she was sixteen. Epstein advised her not to tell an one her real age. • advised that thin s escalated within the home as Epstein would pay S to with his assistant, . Epstein would watch and masturbate as he was watchin . Occasionally, Epstein would then join in during the intercourse and provide oral sex to both S and . This occurred during the time- was sixteen years of age. advised this continued to escalate and occurred during two years. The routine became familiar to M. Epstein's assistant would telephone her every time E pstein was in the Town of Palm Beach and m ould lace a ointments for her to visit and work for Epstein. stated Epstein would photograph them and proudly display the photographs within the home. I continued to come to the house and was paid a stated during e involvin massa e bed and . S became upset over this . Page 9 roximatety 1400.W to $64.10.00 every time she went. , Epstein turned on to her stomach on the stated Epstein began to EFTA00231838 She said . She screamed no and Epstein stopped. She told him that she did not want to Epstein apologized for his actions and subsequently paid her a thousand dollars for that visit. stated she knows he still displays her photographs through out the house. cur affiant recalled working a previous case within Epstein's residence on October 5, 2003, when Epstein reported a theft from within his house. A former, disgruntled houseman was suspected in stealing monies from the house. At that time, I observed several covert cameras which, would capture and record images of anyone within the residence. Epstein had purchased covert cameras which were built in wall clocks and table clocks. These images were then downloaded onto a proprietary spy ware.software for later viewing. WHEREOF, affiant make this affidavit and pray the issuance of a search warrant in due form of law for the search of the above described premises for the said property, heretofore described, and for the seizure and safe keeping of the property, subject to the order of this Honorable Court or such other Court having jurisdiction over the offense, by the duly constituted officers of the law. Sworn to and subscribed before me this 18" day of October, 2005 . JUDGE in and for Palm Beach County, Florida Page 10 EFTA00231839 07/26/2006 15:44 5618354700 PBPD TRAINING PAGE 01/02 A TRUE BILL IN THE NAME OF AND BY THE AUTHORITY OF THE STATE OF FLORIDA IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA For Palm Beach County, at the Spring Term thereof, in the year of our Lord Two Thousand and Six, to-wit: The Grand Jurors of the State of Florida, inquiring in and for the body of said County of Palm Beach. upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid. in the Circuit and Slate aforesaid, COUNT ONE FELONY SOLICITATION OF PROSTITUTION on or about or between the 1st day of August in the year of our Lord Two Thousand and Four and October 31, 2005, did solicit, induce, entice, or procure another to commit prostitution lewdness, or assignation, contrary to Florida Statute 796.07(1) on three or more occasions between August 01, 2004 and October 31, 2005, contrary to Florida Statute 796.07(2)(f) and (4)(c). (3 DEG FEL)(LEVEL 1) against the form of the statute, to the evil example of all others, and against the peace and dignity of the State of Florida. I hereby certify that I have advised the Grand Jury returning this indictment as authorized and required by law. State Assistant Stale Attorney of the Fifteenth Judicial Circuit of the of Florida, prosecuting for the said Siete EFTA00231840 07/26/2006 15:44 5610354700 PBPD TRAINING PAGE 02/02 GRAND JURY FOREPERSON DATE Jeffrey E. Epstein, Race: White, Sex: Male, DOB: January 20, 1953, issue Warrant EFTA00231841 REQUEST FOR WARRANT • ')EFENDANT: Jeffrey Esotein DATE OF BIRTH 01-20-1953 HABITUAL OFFENDER: YES NO A/K/A VICTIM RELATED / ACQUAINTED WITH DEFENDANT? YES AGENCY CASE NUMBER: 05-368 (II LEAD OFFICER: Dct. AGENCY: PALM BEACH POLICE DEPARTMENT CURRENT SHIFT HOURS: 8 am TO 5 cm ADC NO PHONE NUMBER: DAYS OFF: LEAVE / SHIFT CHANGE INFO: WAS ARREST MADE FOR, OR IN CONJUNCTION WITH ANOTHER AGENCY. IF SO, WHAT AGENCY?: SENTENCING RECOMMENDATIONS: CONTACT DETECTIVE ADDITIONAL COMMENTS: ?ICING DOCUMENTS ATTACHED: X ARREST FORM )./ P.C. AFFIDAVIT (2 COPIES) %re WITNESS / EVIDENCE LIST GteartmSty avea 'TO P6A eLta SWORN STATEMENT OP MATERIAL WITNESS(ES) `)C OFFENSE REPORT (2 COPIES) ACCIDENT REPORTS (ALL) WITNESS STATEMENTS (ALL) Facicmgc CRIMINAL HISTORY NM lcut's REb rUESIDT FOttSsCONVCI SUCTIO64NLILIETTE " RS )C PROPERTY RECEIPT PO-volt:v-5 9-Nen ro Asa t;ei_owuk vee_ VEHICLE TOW RECEIPT OTHER ATTACHMENTS INCLUDE: INITIAL FOR COMPLETENESS: JR OITICER 7915 ID. 050106 DATB S -oi -O to EFTA00231842 OBIS nunoet i i _l i L i 1 _1 ARREST I NOTICE TO APPEAR I Met 3 Rawest lot warra-t Juvenile Referral Report 2 N T A 4 Ream! lOr Coe I1 ....mote Ul > P agency ORI Number FLO'. 5 1 0 1 0 1 6 1_ 0 1 0 Aoency Name I PALM BEACH POLICE DEPARTMENT I AspnCy Report Number INT.fral Only/ 7 L6 HL IA l_ l i l l Ri l l 2• 41Tren'emy :0..i. Felony C 3 Misderrearce 0 5 Omani.* V aptly 0 2. Traffic Freon C 4 franc MSOOMMIUX o i. 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Clipse • warrant/Cat Writer Bond w Charge Pealplion Counts IC/omega en N Statute Nagai number 1 !Ri l l ] (t i l l ) i-.ciaOlyi ol ORD sr Drug Atthey Drwa Type AniOunl / Unit ° Tense • Warrant i Capin Number 3 NOTICE TQ APPEAR C Instruction No. 1 MIWIBIONY Pailletance le Cant 0 tdiolon No. 2 lccabon (Coen, Room Nutter. Arklreeel Tau reed re< appear in Colt Cul must ownply WM matrucrions on Reverse Sai Court Oat. WC Tenet Month Bay Plc' I AGREE TO APPEAR AT THE TIME AND PLACE DESIGNATED TO ANSWER THE OFFENSE CHARGED OR TO PAY THE FINE SUBSCRIBED. I UNDERSTANDTHAT SHDULD I Wr-LFU.Lr FAIL TO APPEAR BEFORE THE COURT AS REQUIRED BY THIS NOT= TO APPEAR. THAT I WY BE HELD WI CONTEWT OF COURT AND A WARRANT FOR MY ARREST SHALL BE ISSUED. , .. Sown of Delenclant lot .kreenle and PrentfCustilea)s_ , te- ..* Date &pee " •XD ler other Agency le: Schen Well X Name Yeretation (Printed by Maw) i i • 0 Dangerous 0 Resisted Most Ms' Proof (PRINT) 1.4:. : • TrangatIng Caw L0.• AgVcy PAGE Intake DINT Ulf PRAM witness herea tuba armed MB all X. Or DISTRIBUTION: WHITE — COURT COPY GREEN — STATE ATTORNEY YELLOW — AGENCY PINK — JAIL GOLD • DEFENDANT (N TA's OILY; EFTA00231843 oars Numb« 1 1 1 3 1 1 l _i ARREST / NOTICE TO APPEAR I Angst 3 FIEFS for Warrant Juvenile Referral Report 2 N T A 4 Repues~ Cape — PeM ORI ~Ow Agency Name Ftio 5 1 0 1 0. 6 , 0 i 0_I PALM BEACH POLICE DEPARTMENT PAW Repor Rugg, IN.T.A4 Only) 7 i:6 -1 i I-1 i , i i J lit i "in" .1:3 I. Felony o a imarmany 2 5 Oronanoe I Weapon Seas at many 02 TIT° Felony 0 4. Trains Misoneanor O 6. Omer Enter Type llycre Cloa'Ance Clou--. .' - - • - ~don 44 MS Onoluding Nang ot ~meal [LoCalon al okras (Balrea News. Aaron( I i Da» of Arrest I I _I i t This ol And J_ I 1 Booking OM Booking Tens Jai Dada Jae trig Loudon al Wreck Name (Last. Flea MiOleal Ain ~be. DOB. Sot Sao a. Etc. I RRice Wm* I • American trishaw B • Blau 0 • Oriental/Asir 1 Ser Dale el Ban 1$1•06li 1 1 ' ' 1 I I be Colo 111k Caw Corratron [Bug SOWS. www 155005. Unge» Phystai Features ~aeon. Type, Desoiroon) ~tat Status Religion Waned, ol ce 6 2, Dew Sabena 0 0 1 .2 2 W Local ~den ISireet. Apl. Number) ICW) (See) op) Phone ( ) %Alen» Type I. Oty 3 Flea& 2. Courw 4. Dui o! Stew i ig Permanent Adana (Segel. frol. Nerier) IOW/ (Slate) Rol Pliant ( ) Actsess Source Business Aigren (Name. Stel) IOM (See) ino Phone ( ) Otoxpaton -CVL Number. Stale r Sea Wonder I WS Number I. Plate or Bra (Oty. 5151.1 Gezensng ILL CoGelen0anl Nuns (Last. Frst MieSSO Sex Date of Binh MasNO 12;. At Large be Latoneyene a e o r Be Juvenile CorDelenoard Mn Ma Fru. WOW Rase Sex Dale of Troi 2 I. Amazed S A: La rge g:. Z:m..no, dDneY 5 Jurors'. 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OF DISTRIBUTION — COURT COPY GREEN — STATE ATTORNEY YELLOW — AGENCY PINK — JAIL GOLD • DEFENDANT (N .TAY ONLY) EFTA00231844 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 Police Case#: 05-368 (1) Defendant: Race/Sex: DOB: Charges: Jeffrey Epstein White Male 01-20-1953 Unlawful Sexual Activity with a Minor (4) counts Lewd and Lascivious Molestation From March 15, 2005, through February006 the Palm Beach Police Department conducted a sexual battery investigation involving Jeffrey Epstein, Ml= and . Sworn taped statements were taken from five victims and seventeen witnesses concerning massages and unlawful sexual activity that took place at the residence of Jeffrey E stein, 358 El Brillo Way, Palm Beach. Several of the victims were recruited by and brought to the residence by to perform massages for Epstein, for which received monetary compensation. During the visit they would be introduced to , Epstein's assistant, who in turn would record their telephone numbers and name. The victims would be brought to Epstein's bedroom to provide the massage. Epstein would enter the room and order the victims to remove their clothing to provide the massage. As the victims complied and provided the massages, E stein would On occasion, Epstein would introduce a massager/vibrator and as they provided the massage. On three separate occasions, Epstein had intercourse and inserted his penis/fingers in the victims vaginas. At the conclusion of the massages the victims were paid sums of money ranging from $200 - $1,000. The facts, as reported, are as follows: On 03/15/2005, A fourteen year old white female, hereinafter referred to as ".," dob and her family reported unlawful sexual activity which occurred at a residence within the Town of Palm Beach. reported that a subject known to her as "Jeff" had touched her vaginal area with a vibrator/massager while within his residence. "Jeff" was later identified as Jeffrey Epstein through a photo line up. During a sworn taped interview, stated that , dob , a cousin of - boyfriend and classmate at Ro al Palm Beach High School; worked for a wealthy man and did sexual favors for him. She also admitted that had offered her an opportunity to make none . During the beginning of the month of February 2005 explained that she was first approached by to o with her.to Epstein's house. IN stated that alon with a Hispanic female, later identified at pick her up at her father's house on a Sunday. was not sure of the exact dates but kiiew it was a Sunday. told her father that they were going shopping but in reality drove them to Palm Beach. During the drive a The foregoing instrument was sworn to or affirmed before me this l d day of May, 2006 by Det , who is personally known to me. State of Florida Coun o Pal Beach Signa ling Officer Signature of Police Officer (F.S.S. 117.10) Date: i i 1/2006 Pagel of 22 EFTA00231845 Signature of Police Officer (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Atency ORD FLO 500600 conversation occurred between and whereas ortedly told that if Jeff asked her age, she should say she was eighteen. It was later confirmed by the IN Elie a father that picked his daughter up on February 6, 2005. According to father, drove a pick up truck. • described Epstein's house as a two-story pink house with a Cadillac Escalade parked in the driveway. She recalled that Jeff s house was on a dead end street. Upon arriving at the house . stated that they walked up a driveway ast what appeared to be a small guard/security room. A male approaching them asking what they wanted. stated they were there to see Epstein. The male allowed them to continue walking up to the house. stated the man told them that Epstein was not there but was expected back. He allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside. Shortl thereafter, Epstein and his assistant, described as white female with blond hair and later identified as entered the kitchen. Epstein introduced himself to M. M described Epstein as being approximately forty-five years old, having a long face and bushy eyebrows, with graying hair. and Epstein left the kitchen leaving M alone in the kitchen. They returned a short time later. They all spoke briefly in the kitchen. M was instructed to follow upstairs. M recalled walking up a flight of stairs, lined with photographs, to a room that had a massage table in it. Upon entering the room there was a large bathroom to the right and a hot pink and green sofa in the room. There was a door on each side of the sofa. M recalled there .1 1 a mural of a naked woman in the room, as well as several photographs of 'raked women on a shelf. told the victim that Epstein would be up in a second. Epstein entered the room wearing only a towel and told M to take off her clothes. M stated Epstein was stem when he told her to take off her clothes. M said she did not know what to do as she was the onl one there in the room I she took off her shirt leaving her bra on. Epstein had removed his towel and told thi. to take off everything. I stated Epstein was nude when he took his towel off, placing it on the floor as he laid down on the table. stated she then removed her pants leaving her tho anties on. Epstein then instructed her to give him a massage pointin to a specific lotion for her to use. As . began to give E stein the massy e, he told her to get on his back. stated she straddled herself on Epstein's back whereby . . M said Epstein was specific in his instruction to her on how to massage him, telling her to go clockwise or counter clockwise. Epstein then turned over and instructed M to massage his chest. . was now standing on the ground and resumed massaging Epstein's chest area. M stated Epstein held onto the small of her back as she massaged his chest and shoulder area. Epstein then turned to his side and started to rub his penis in an up and down motion. Epstein then pulled out a purple vibrator and began to The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det , who is personally known to me. State of Florida Co-u-nty Signat jtmg Officer Date: 0 i 1/2006 PageZof 22 EFTA00231846 Signature of Police Officer (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 Instated there was no penetration as the recalled Epstein ejaculating because he had to use the towel to wipe himself as he of off the table. Epstein then left the room and . got dressed. She went back downstairs where she met with . said she was paid three hundred dollars in cash from Epstein. Before she left, Epstein asked to leave her phone number. As M, and were leaving the house, told • she received two hundred dollars that day for bringing her. During the course of the investigation, parental consent was granted for to assist with the investigation. At our direction conducted controlled taped phone calls to cellular telephone spoke with in an attemitt ange another meeting with Epstein. asked what did she need to do to make more money. stated, "the more you do, the more you get paid." had subs uently called back and left a voice mail message for her indicating that she had set up an mointment for to go to Epstein's house at 11:00 am on April 5, 2005. This message was recorded from es voice mail. Based on the above, trash pulls were established at Epstein's residence with Supervisor Tony Higgins of the Sanitation Bureau of the Town of Palm Beach. The trash pull from April 5, 2005 revealed a telephone message for Epstein which stated and name at 11:00 am. This was the time frame had informed to be ready to go work at Epstein's house. On October 3, 2005, Sgt and I went to residence and viewed her vehicle parked in the driveway, a red Dodge Neon. Sgt. and I knocked on the door and met with . was told that we were investigating a claim involving Jeffrey Epstein of El Brill° Way, in Palm Beach. was asked if she would accompany us back to the police station for further questioning. She was also told that at the conclusion of the interview she would be returned home. voluntarily came with us back to the Palm Beach Police Department. Upon our arrival at the police station, was brought to the interview room in the Detective Bureau where I obtained a taped, sworn statement. I began the interview by asking how she became acquainted with Epstein. stated that approximately two years ago, just after she turner 17 ears of age, she was approached by a friend named at the Canopy Beach Resort in Rivera Beach. was asked if she wanted to make money. She was told she would have to provide a massage and should make $200.00. thought about the offer and agreed to meet with Jeffrey. The foregoing instrument was sworn to or affirmed before me this l a day of May, 2006 by Det who is personally known to me. State of Florida County of Palm Beach Page3of 22 EFTA00231847 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 (Unknown last name) and (Unknown last name) picked up and she was taken to Epstein's house. Upon her arrival to the house she was introduced to Epstein in the kitchen of the house. She was also introduced to a white female known to her as . She was led upstairs to the main bedroom known to her as Jeff Epstein's bedroom. arranged the massage table and covered the table with a sheet. She brought out the massage oils and laid them next to the massage bed. M, then left the room and informed Jeff would be in, in a minute. Jeff entered the bedroom wearing only a towel. He removed the towel and laid nude on the massage table. He laid on the table onto his stomach and picked a massage oil for to rub on him. During the massage, stated "He tried to touch me and I stopped him." I asked how he tried to touch her. stated that Epstein and she felt uncomfortable. told Epstein, I'll massage you but I don't want to be touched. stated she performed the massage naked. At the conclusion of the massage, Epstein paid $200. After the massage Epstein stated to that he understood she was not comfortable, but he would pay her if she brought over some girls. He told her the younger the better. stated she once tried to bring a 23 year old female and Epstein stated that the female was too old. stated that in total she only . remembers six girls that she brou t toarstein, each time she was paid $200. stated she had brought the followin iris: , , .. ( al6 year old female), (a 16 year old female) and . said that at the time she brought thesL is o Epstein's house they were all14 through 16 years of age. I asked which one was the youngest. advised . was the youngest as she was fourteen when the massage occurred. stated every girl she brought knew what to expect when they arrived. They were told they would provide a massage, possibly naked, and allow some touching. I asked her if . was aware. She stated every girl she brought knew what to expect. She explained she knew that wanted to make money. She approached . and explained about going to work for Jeff, . agreed and arrangements were made to bring her to Epstein's house on a weekend. stated that she and (Later identified as picked up . at her house. stated that at that time she was driving a red pickup truck. They traveled tatein's house and entered through the kitchen door. They met with the house chef and Epstein's assistant . . was introduced to Epstein while the were in the kitchen area. led I.I upstairs and Epstein went upstairs. When the massage was over returned to the kitchen area. stated she was paid $200.00 for bringing . to Epstein's house. stated . told her she was paid $300.00 for the massage. stated that was the last person she brought to Epstein's house. She had changed her cellular number to avoid being contacted by She continued stating that she had no direct contact with Epstein The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det , who is personally known to me. Signature of Polie Officer F.S.S. 117.10) State of Florida Signatur Date: 0 ing Officer 06 Pagegof 22 EFTA00231848 Probable Cause Affidavit Palm Beach Police Department Agency ORD FLO 500600 when he was going to travel to Palm Beach. said when Epstein announces to his assistant, that he is traveling to Palm Beach, would then contact to arrange girls to "work" for Epstein. stated that once hesrents discovered that she was visiting Epsteiri ad ilisapproved of the encounters with him and she stopped. Anther stated that still tries to call house and leaves messages. Sgt entered the room and explained to that based on her own statements, she had implicated herself by bringing underage girls to Epstein's house. provided cellular telephone numbers for the girls she had mentioned previously. Additionally, she also provided possible addresses and areas in which they lived. As was being taken home in the vehicle, a tape recorder was laced within the vehicle to record any conversations within the vehicle. During the drive back to her home, made the comment " I'm like a Heidi Fleiss." (Hollywood Madam who sent girls to clients for sexual favors in California). VMS dropped off at her house without incident. On October 3, 2005, Sgt and I went to speak with a sixteen year-old female who was . brought to Epstein's residence by We met with mother at their front door. We exained the on oing investigation and asked to speak with, as we had information that she had "worked" for M. introduced us to her husband and allowed us entry into the home. We sat in the dining room and met vith Date of Birth . As she was under the age of eighteen, was advised we would be speaking with her. She expressed if her daughter had information, she wanted to assist. We interviewed., who denied havin any inappropriate encounters with M(Epstein). She stated she had gone to Jeff s house with approximately eight months ago and sat in the ldtchen with the house chef, but nothing happened. As the parents were present during the interview, we felt that, was withholding information from us. She made several comments as to putting the entire incident behind her. I left my alone number and advised should she wish to speak with me again to telephone me. Sgt and I thanked for her time and left the area. She stated she would ask I again after we left as to what happened at Epstein's house. I informed her that I had my telephone number and hopefully she would call. On October 4 2005 Det and I drove to the dob . During a sworn taped statemen when she was seventeen years old, she was taken to a house by because they both attend Royal Palm Beach High School. home and met with and stated approximately a year ago stated she knows She was told she could make money working — —The-foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det , who is personally known to me. Signature of Police fficer ( . . . 117.10) State of Florida Page5ot 22 EFTA00231849 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO S00600 for III She was told she would have tarnride a massage to III. stated upon her arrival to the house she was brought to the kitchen area by . They met with the house chef who was already in the kitchen area. stated would wait for her in the kitchen. was introduced to , Jeff's assistant, who brought her upstairs to the master bedroom. prepared the room and massage table for a massage. Epstein entered the room wearing only a towel and she provided a massage. stated she k t her clothes on during the massage. She advised sometime during the massage, Epstein and pulled her close to him. said she was uncomfortableitite incident involving Jeff. At the conclusion of the massage, she was paid $200.00 for the massage. I asked if she has any formal training in massy which she I asked her if received any monies for taking her to perform the massage. stated had received money for taking her there but was unsure in the amount. stated she returned to Epstein's house on another occasion with and another stated she waited in the kitchen with , while was taken upstairs by stated she only did the massage once as she was uncomfortable with the whole experience. At the conclusion of the interview, the tape was stopped. I was informed that had attempted to reach via cell phone. A voice mail messy e on October 4, 2005 at 10:59 am, revealed a female voice who identified herself as who requested to call her back reference the police questionin provided the incoming telephone number as stated she inadvertently told about the police investigation because had called her to tell her about how she just received a rental car from Jeff Epstein. had called her to tell her that she was given a rental car, a 2005 Silver Nissan Sentra, to utilize to visit famand visit Epstein. asked her what was oin on at the house that the police would be asking questions. stated then called Jeff and and asked what was going on reference the ongoing police investigation. According to =, has since then been trying to contact her to ask about lei ,ice questions. I instructed M not to contact information to as she would notify Jeff Epstein and what was transpiring. and do not provide any more On October4, 2005, I made telephone contact with, who had left, several messages for me to contact her. During the message, she advised she was not completely truthful when we met in person but would like to speak with me to advise what had happened. She anther advised she did not want to speak of this incident in front of her mother. At approximately 3:48 pm I made telephone contact with I. During a taped recorded statement stated the following: approximately a year ago, when she was sixteen years of age, took her to Epstein's house twice. She knows because they both attend Royal Pal Beach High School. The first time she went, drove to the house. They entered through the kitchen area where she was The-foregoing-instnunent-was-sworn-toonaffirmed before me this 1" day of May, 2006 by Det , who is personally known to me. State of Florida Coun of Palm Beach Officer Signature of Police OYfrcer ( .S.S. 117.10) Date: 05/ice 06 Pagek,of 22 EFTA00231850 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 introduced to and Epstein. She was taken upstairs to a bedroom by who set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for I to rub on him. At one point during the massage he tried to remove her shirt, at which point she became very upset and discontinued the massage. Both and E stein had a verbal disagreement, at which time she left without being paid. She got with kitchen and told her "let's go." advised she received no money for that day. had told her if she was uncomfortable with what was going on, to let him know and he'll stop. She knew that the more ou do the more you get paid. I advised that several weeks later she agreed to be taken a second time by . Once they arrived at the residence, sat in the kitchen and took her upstairs to the master bedroom again. set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for, to nib on him. At one point during the massage he tried to touch her buttocks. As I was wearing tight jeans and had a tight belt on Epstein was unable to touch her buttocks. Epstein then rolled onto his back during the massage and then attempted to touch her breasts.. then became u set again and told Epstein she didn't want to be touched. I discontinued the massage and was paid $200.00.. then went downstairs where was waiting for her. She told she wanted to leave. I said she never returned to the house. stated she is aware that her friend, was also at the house and had a problem with Epstein. who was sitting in the also said that I later researched dob and met with her at her residence. During a sworn taped statement, stated the following: on or about November 2004 she was approached at Royal Palm Beach High School by , a fellow student. asked if she wanted to make money. She agreed and was told she would provide a massage to wealthy man in Palm Beach. picked her up and drove her to a house in Palm Beach. She was brosht into the kitchen area of the house. She further stated that fellow Royal Palm Beach High School students and ) came with them. They were brought into the kitchen where she was introduced to Epstein and other females. stated she was introduced to a female helper of Epstein, the female was described as white female (unknown name ), with blond hair. . She stated that the assistant was familiar with . The assistant brought her upstairs into a master bedroom area. The assistant set up the massage table and put out lotions to be used. She told Epstein would be available in a minute. Epstein entered the room wearing only a towel. Epstein removed his towel, and laid naked on the massage table and picked a lotion to rub on his thighs and back. further stated dune massage, Epstein asked her to remove her clothes. She complied and removed her pants and blouse. didn't remember if she had removed her bra but feels that she did. was certain that she stayed in her thong underwear. continued the massage and at one point she climbed onto the massage The foregoing instrument wassworn to or affirmed before me this 1" day of May, 2006 by Det , who is personally known to me. Signs ure o o ice leer . . 7.10) State of Florida Cou Signature/ Date: 05/0 Officer Page? of 22 EFTA00231851 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 table, straddling Epstein to massage his back. While doing this was instructed to return to the ground at which time Epstein turned to have his chest rubbed. advised she was sure he was masturbating based on his hand movements going up and down on his penis area. did not want to look at his penis area because she was uncomfortable. Epstein removed a lar e white vibrator which was next to the massa e table and turned it on. stated Epstein began Shortly thereafter, Epstein ejaculated and removed himself from the table. He walked over to where the shower was and opened the glass door. She waited as he was taking a shower in her direct view. When I asked bow old she was when this occurred, she stated she had just turned seventeen. At the conclusion of the shower, was paid either $350.00 or $400.00. She stated she wasn't sure, but knows it was close to $400.00. stated she never returned to provide a massage for Epstein. At approximately 2:10 pm, Det and I met with E, dob , at her residence. As was only seventeen years of age, I had notified her mother, that she would be interviewed reference an ongoing investigation in Palm Beach. I assured her that her daughter was not a suspect. I explained the possibility of her being either a witness or victim. advised she wanted E to cooperate and consented to the interview. During a sworn taped statement, stated the following: at the age of sixteen during the month of September 2004 she was approached by for a chance to make money. was friends with associates of and knew the same people. had been previously told by her friends ftom Royal Palm Beach High School, what did for Epstein. called a person known to E as and scheduled the appointment. picked E up and drove her to Palm Beach to a street called "Brillo Way". They drove to the end of the street and entered a large drivewa . The entered the kitchen area of the house and met with Epstein. E was introduced to Jeff Epstein. led upstairs to the main bedroom area and set up the room with a massage table and set out the oils. stated that while going up the stairs and into the bedroom she observed numerous photographs of naked young girls. dimmed the lights and turned on soft music. exited the room and Epstein entered the room wearing only a towel. Epstein picked oils and instructed her to rub his legs, under his buttocks, back and chest area. Epstein asked her to get comfortable. U advised she did not remove her clothes. She was wearing tight jeans and a cropped tank top ex pSniker it belly area. Durin the massage, Epstein removed his towel and laid on the massage table naked. As area, he attempted to reach down her pants to touch her buttocks area however was unable to due so due to the tightness of the jeans and a tight belt. E advised Epstein began to masturbate as she rubbed his chest. Epstein moaned as she rubbed his chest. She observed he was continuing to masturbate and The faregoinginstrument was sworn to or affirmed before me this 1" day of May, 2006 by Cou t aim mach Det who is personally known to me. Signature of Police ficer .S.S. 117.10) State of Florida Signatu mg Officer Date: 0 '06 Pagegof 22 EFTA00231852 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 attempted to reach up her tank top and touch her breasts. •, pulled back and Epstein stopped, however he kept masturbating until he climaxed. He cleaned himself with the towel he was previously wearing. E was paid $200.00 for the massage and left the area. She met with who was waiting in the kitchen area and left the house. with then explained she never provided another massage for E stein. She did however, go to the house and as they took another friend of . E advised she was present when went to work for Epstein. She advised she rode over and sat in the kitchen area with to wait for . • advised while they waited for the house chef prepared lunch for them as it was almost lunchtime when they went. When was finished with the massaEthey left the area. I asked E if ever told her what would be expected when she provided a massage.. stated yes, told her that a massage would be expected, possibly naked and possibly some touching involved. E has no formal training in providing massages. IMI spoke about a third and last time she went to Epstein's house. drove another girl, E, (sixteen years of age) who is friend, to Epstein's house. • stated knew that E had made money massaging &stein and wanted to make money herself. took them in the kitchen area of the house and introduced . to . and took E upstairs to the main bedroom. • advised she doesn't know what happened as did not speak about what happened in the room. E received $160.00 from for going with her to Epstein's house and recommending . On October 6, 2005, at 11:45 am, I met with dob , at and explained to her why we there to interview her. She advised she was aware of the ongoing investigation. stated she had previously spoken with sworn taped statement, stated she knew that who told her she was interviewed by detectives. Du, worked for Epstein in Palm Beach. advised she originally had been taken to the Epstein house by , whom she met when they both attended Royal Palm Beach High School. She began going to the house when she was sixteen years of age and stated she had been there a lot of times to provide massages over the past two years. I asked her if she had formal training in providing massages, which stated she had not. advised she was told what was expected of her by providing massages and she would have to remove clothing but if she felt uncomfortable just to say so and Epstein would stop pushing the issue. began providing massages and advised she kept her clothes on. She considered Epstein a pervert and he kept pushing to go further and further. explained she would keep telling hint she had a boyfriend and would not be right to her boyfriend. It wasn't until recently that began removing her clothes and staying in her thong underwear to provide a massage. explained The foregoing instrument was sworn to or affirmed State of Florida before me this day of May, 2006 by Coun Det who is personally known to me. Signature of Police Officer .S. . 117.10) Signature Date: 05/0 106 Officer Page 9 of 22 EFTA00231853 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 Epstein wanted to be rubbed on his back and recently he began turning over and have her rub his chest as he masturbated. He would try to touch her breasts as she rubbed his chest. stated "Jeff would try to get away with more and more on each massage". stated would try to touch her more and on one occasion he anointed to use a massager/vibrator on her. drove left her cell phone number and every time E stein would come into town, to the house for the original massage. would call her for an appointment to "work". Each time she went, would meet her at the kitchen door area. She would bring her upstairs and prepare the massage table. knew she was and would be attending advised E stein would ask heraestions about herself. Epstein . I asked III if Epstein knew her real age. stated Epstein did and didn't care. The most recent massage she provided was on October 1, 2005. aDi , massage, she asked Epstein if she could borrow one of his vehicles to visit her family and boyfriend in Florida. Epstein had told her she could borrow one of his vehicles but later stated he would rent her a car. She continued with the maggage as Epstein and . I asked if she was wearing undergarments to which she replied her thong underwear. Once he tried to touch her breasts, she would pull away from him and he would stop. was asked if he ever used a vibrator on her. was aware of the vibrator but advised she never would allow him to on her. She described the vibrator as the large white vibrator with a huge head on the tip of the vibrator. She stated he kept the vibrator in a closet near the massage table. stated that on October 3, 2005, she was contacted by Epstein's assistant, who informed her chat Jeff Eaein had rented her a new Nissan Sentra and she should come by the house to pick it up. informed she would have the car for a month. stated Epstein knew her car was not working properly and that she had missed appointments in the past because of her car being inoperable. explained the car is currently parked next to the Gym field. I asked her if she ever took any one to the house. explained she took , a friend of hers who attended Royal Palm Beach High School, who has relocated to to attend college. I asked if she ever allowed another female in the room. advised no one was brought into the room with her. At the conclusion of the interview, Det and I went to the gym area of and located the Silver Nissan Sentra bearing Florida tag . The vehicle is registered to Dollar Rent a Car out of the Palm Beach International Airport. The vehicle was rented by Janusz Banasiack, later learned to be Epstein's houseman, and paid with Epstein's credit card. On September 11, 2005, w/f e, dob , was arrested by the Palm Beach Police Department The foregoing-instrunient was &warn tn or affirmed State of Florida before me this 1" day of May, 2006 by Coun of Palm Beach Det , who is personally known to me. Signature of Police Officer (F.S.S. 117.10) Signatu mg Officer Date: /2006 Page leaf 22 EFTA00231854 Probable Cause Affidavit Palm Beach Police Department Agency OFtlit FLO 500600 for misdemeanor possession of marijuana. During the arrest . told the arresting officer that she bad information about sexual activity taking place at the residence of Jeffrey Epstein. Additionally, during the ongoing trash pulls from Epstein's residence, discarded papers were found which contained name and cell phone number. On October, 11, 2005, Det and I met with . and obtained a sworn taped statement. explained she had been going to Epstein's house since 2002, when she was sixteen years of age. Since then she has gone to the house hundreds of times. • stated she became his "number one girl." She explained that on her first visit she was brought to the house by fellow Royal Palm Beach Hi School classmate, • said she was brought through the kitchen area where she met . for the first time. was led to the master bedroom, Epstein s room. • explained that as she was walking up the stairs she observed several photographs of naked women alond the walls and tables of the house. . further explained that she was brought into the bedroom, where prepared the room by setting up the massage table and provided the oils for her to rub on Epstein. • explained she remembered the steam room area, which contained two large showers. Epstein entered the room from the steam room area and introduced himself. Epstein lay on the table and told her to get comfortable. • removed her skirt and kept her shirt on. Epstein then instructed her to remove her shirt. • removed her shirt and remembered she was not wearing a bra. li stated she provided the massage wearing only her anties. She continued rubbing his legs, thighs and feet. advised he turned over onto his back. Epstein and be an to masturbate. Epstein ejaculated which meant the massage was over. At the conclusion of the massage, was paid $200.00. They walked together downstairs where and were waiting. stated received an unknown amount of money for taking her to Epstein. Epstein instructed to leave her cellular telephone number so that he could contact her when he is in town. stated that during her many visits a routine was established between her and Epstein. She would enter the house and get naked in the bedroom. She would then start with a back massage. Epstein would roll on to his back and allow her to massa e his chest area. stated E stein would then began to masturbate himself and at the same time would with his fin ers. ex lained E stein would continue this process until he ejaculated. He would then . • advised that during her frequent visits, Epstein asked for her real age, Epstein advised her not to tell anyone her real age. would instruct and pay U to intercourse included Epstein would watch them stated she was sixteen. advised that things escalated within the home as Epstein explained the that Epstein had at his disposal. and masturbate himself . Occasionally, Epstein would then join in e foregoinginstrumentaas ato or affirmed State of Florida before me this V' day of May, 2006 by Det who is perSonally known to me. Signature of Police seer ( S.S. 117.10) ignatu r g Officer Date: 05/01/2006 Paget' of 22 EFTA00231855 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 during the to both and This occurred during the time was sixteen years of age. II advised this continued to escalate during two years. The routine became familiar toe. Epstein's assistant would telephone her every time Epstein was in the Town of Palm Beach and would place appointments for her to visit and work for Epstein. Each time something new was introduced, additional monies were produced and offered for e to allow the acts to happen. • consented to perform all these acts but was adamant that there was an understanding with E stein that no vaginal penetration would occur • . explained that Epstein's penis was deformed. . explained that his penis was oval shaped. claimed when Epstein's penis was erect, it was thick toward the bottom but was thin and small toward the head rtion. calleSiein's penis "egg-shaped." e stated Epstein would photo aph and her and proudly display the photographs within the home. stated during one visit to Epstein's house in which she provided a masse e to E stein, his female friend, was also resent. provided the massage in which and her would for Epstein to enjoy. Towards the end of this mass e E stein bed and turned her over onto her stomach on the massage table and stated E stein be an to became upset over this. She said her head was , as he continued to . She screamed "No!" and Epstein stopped. She told him that she did not want to Epstein did not eSculate inside of her and apologized for his actions and subsequently paid .ter a thousand dollars for that visit . stated she knows he still displays her photographs through out the house. • On October 12, 2005, Det and I met with dob who stated during a sworn taped statement, that nothing happened between her and Epstein. Murphy appeared nervous during the interview. I assured her that I have spoken with other people who advised differently. stated on several occasions sheprovided a massage to Epstein. She stated she was brought to the Epstein house in March of 2005. `made classmate at Royal Palm Beach Hi School, approached her and asked her if she wanted to "work". = made the arrangements with =, Epstein's assistant. , who has no formal training in providing masse es stated she provided a massage, fully clothed for $200.00 . As I sensed hesitancy in her answers, I asked if she had been contacted by anyone from Epstein's organizations or his house. stated she was interviewed already by a private investigator for E stein. He identified himself as "Paul" and about the police investigation, and left his telephone number for additional contact provided no additional information, as it appeared her responses were almost scripted. The fin eguing ifistrunrent-was-sworn-to-or-affirmed before me this 1" day of May, 2006 by Coun of Palm B; ch Det who is personally known to me. State of Florida Signs re o o ce leer . . . ) Signatu Date: 05/01/2006 g Officer Pagei2of 22 EFTA00231856 Probable Cause Affidavit Palm Beach Police Department Agency ORD FLO 500600 On November 6, 2005, at a roximately 3:30 pm, I met with dob at the Palm Beach Police Department. was identified as a potential witness/victim through information obtained during the trash pulls. During the sworn taped statement, advised she was at Jeffrey Epstein's house one time, approximately two months ago. She was approachedlystirl, , who was dating M ' roommate, for an opportunity to make some quick money. advised she needed to make some quick cash to make the rent that month. She agreed to go to the house. She had been told by that the massage would have to be done in her underwear. She advised drove with her and brought her into the house. They walked into the kitchen area, and took the stairs upstairs. further stated she was brought into a master bedroom area. She advised she recalled seeing portraits of naked women throughout the room. A massage table was already out near the sauna/shower area in the master bedroorrSein entered the room wearing only a towel and introduced himself as "Jeff." At Epstein's direction, and removed their clothing down to their panties, Epstein laid on his stomach area and they provided atssae on his legs and feet area. I asked if she had any formal massage training and she replied "no." advised she was topless and the panties she wore were the boy shorts lace panties. She and continued the massage until the last ten minutes of the massage, Epstein, told to leave the room so that could finish the massage. got dressed, and left the room as turned over onto his back. Epstein then removed the towel and laid naked . E stein requested that rub his chest area. stated , Epstein, began masturbating. stated Epstein pulled cloth' her boy short panties, and he produced a large white vibrator with a large head. She stated it was within his reach in a drawer in his master bathroom. He advised he never with the vibrator. He continued to as he continued to masturbate. stated she was very uncomfortable during the incident but knew it was almost over. Epstein climaxed and started to remove himself from the table. He wiped himself with the towel he had on previously and went into the shower area. got dressed and met with in the kitchen area. Epstein came into the kitchen and provided $200.00 for bringing and paid $200.00 to for providing the massage. was told to leave her telephone number with for future contact. provided her cellular telephone number. was asked if she was recently contacted about this investigation by an one from the Epstein organization. She replied she was called but it was for work. She stated she was called by for her to return to "work" for Epstein. stated "work" is the term used by to provide the massages and other things. advised she declined as she was not comfortable in providing that type of "work." On November 7, 2005, Det and I met with dob . During a sworn taped statement, stated she met Jeffrey Epstein through when they were still — The foregoing instrument-was-sworn to or affirmed State of Florida before me this 1" day of May, 2006 by Det , who is personally known to me. Signature o o tee icer . . 17.10) gna icer Date: 0 1 /2006 Pagela)f 22 EFTA00231857 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 attending Royal Palm Beach High School. would approach females who wished to work for Epstein. stated she was offered to work for Epstein but declined explained that "work" means ive massages. She was asked about any formal training in providing massages which she said "no." said she accompanied and other females who were taken to Epstein's house to provide massages. with further stated she had been to the house a roximat& 4 or 5 times in thepast year. She accompanied , M, and . Each time the girls were taken over, they were previously told they would have to provide a massage, possibly naked. They were also told that shouldi,require them to do anything extra, and they were not comfortable just to tell him and he would stop. stated received $200.00 for each girl she brought over to maq.cage Jeffrey Epstein. When I asked which girl appeared to be the youngest, she replied, M, who was really young, fifteen years old at the most. further stated each time she went to the house, she sat in the kitchen and waited with until the massage was over. She further stated that the cook would make lunch or a snack for them as they waited. I asked her if there was anything that caught her attention within the home. stated there were a lot of naked girls in photographs throughout the house. On November 8, 2005, at approximately 2:00pm , I met with Palm Beach Police Department. During a sworn taped statement, approximately two ago when she was first approached by High School. approached her about working for Epstein and providing a massage to him for $200.00. Aobson had made the arrangements however was unable to take her the day the arrangements were made. had take also attended Royal Palm Beach High School and was familiar with Epstein. with an assistant photographs of naked females throughout the house. towel, and laid on the table. stated Epstein came in the room, wearing only a stated he pe ced out the oils he wanted her to use and requested she remove her clothing to rovide the massage. stated that on the first massage she provided she did not remove her clothing. stated she had returned several times after that. Each time she returned it was more than a massage. Epstein would walk into the master bedroom/bathroom area wearing only a towel. He would masturbate as she provided a massage. stated she was unsure if he climaxed as he masturbated under the towel. Additionally, she never looked below his waist. She claimed that Epstein would convince her to remove her clothes. She eventually removed her clothes and stayed in her thong panties. On occasion, Epstein would use a mos er/vibrator which she described as white in color and a large head. Epstein would as he would masturbate. stated she had been to the house , dob , at the stated she had met Epstein , a classmate at Royal Palm Beach recalled she was brow t there and entered through the back kitchen door. She had met and another assistant brought her upstairs as she observed several The foregoing instrument was sworn-to-ot iti med _staff. of Florida before me this l m day of May, 2006 by Co Det , who is personally known to me. Signature of Police Cifficer (F.S.S. 117.10) Signature fficer Date: 05/01/2006 Page 22 EFTA00231858 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 numerous times. added she has no formal trainin in providing a massage. stated she brow t two females during her visits to provide massages. stated she brought a girl named' " and from Royal Palm Beach High School. stated she received $200.00 for each girl she brought. On November 8, 2005, I met with , W/F, at the Palm Beach Police • Department. During a sworn taped statement, stated she had met Jeffrey Epstein approximately one year ago. She was approached by a strict known to her as M. had asked her if she wanted to make money providing massages to Epstein. had heard that several girls from R272.1 Palm Beach High School were doing this and making money. She agreed and was taken to the house by M. had introduced her to - and Epstein and brotIglit her upstairs to a master bedroom where a mass table was prepared and the proper oils were selected. left the room and waited downstairs for her. stated Epstein entered the room wearing a towel and laid on his stomach. She provided a massage wearing only her thong panties. advised Epstein had masturbated every time she provided a massage. She stated Epstein continued to masturbate until he climaxed. Once that occurred the massage was over. She felt the whole situation was weird but she advised she was $200.00 for providing the massage. She also stated • was paid $200.00 by Epstein for bringing stated she had gone a total of 15 times to Epstein's residence to rovide a massage and things had escalated from just providing a massa e. E stein be an touchin and grabbed her closer to him as he masturbated. Epstein also and with his hands as she provided the massage. stated on one occasion, while she was only seventeen years of age, he offered extra monies to have va inal intercourse. She stated this all occurred on the massage table. stated Epstein and be an until he reached the point of climax. Epstein removed and climaxed onto the massage table. received $350.00 for her massage. I asked her if she had any formal training in providing massages stated she did not continued to state on one other occasion, Epstein introduced his girlfriend, r into the massage. brought into room with to provide a massage. Epstein had them as they provided a massage to Epstein. Epstein, watched and masturbated as this occurred. On other occasionsikein, introduced the large white vibrator/massager in the massage. Epstein on vagina as she provided the massage. On November 14, 2005, Det and I met with dob . During a sworn taped statement she advised she started going to the house approximately one year ago and has been there approximately five or six times. also stated she was sixteen years old when she first went to Epstein's house. On her first visit she was brought by a fellow student from Royal Palm Beach High School known to her The foregoing instrument was sworn itraraffirmed— • before me this 1" day of May, 2006 by Det who is personally known to me. State-ofFlo ridA Signatu g Officer Signature of Police fficer Ø.S.S. 117.10) Date: 0 006 Page t9of 22 EFTA00231859 Probable Cause Affidavit Palm Beach Police Department Agency ORBS FLO 500600 as stated brought her into the house and she was introduced to then brought her upstairs into a master bathroom, located within the bedroom. stated she met Epstein in the bathroom. He laid on the table and picked the massage oils. She provided the massage as he laid naked on the massage bed. She stated she rubbed his calves and back area. Upon the end of the massage, Epstein removed himself from the massage table and paid her $300.00 for the massage. said each subsequent time she went to the house, she was notified by that Epstein was in town and would like her to "work". stated she returned to the house and was again led upstairs by She provided the massage, clothed. was asked if she ever removed her clothing to rovide a massage. stated it was not until the third time that she went that she removed her clothing. stated she was notified by that Epstein wanted her to come to work. She arrived at the house and was ledsairs by . She started providing the massage when Epstein asked her toremove her clothing. removed her pants, shirt and bra. She stayed in her aganties tl and . Epstein turned over onto his back and she stated she knew he was masturbating himself as she providing the massage. stated she believed he climaxed based on his breathing. She did not want to view either the climax or the fact that he was masturbating. stated once the breathing relaxed he got up and told her to get dressed. She was paid $300.00 for her services. stated on the last time she went to provide a massage, she was notified by to come to the house and "work". stated she was now dating her current boyfriend and did not feel comfortable going. She recalled it was approximately January 2005. the said she went, already thinking that this would be the last time. She went upstairs and went into the master bathroom. She met with Epstein, who was wearing only a towel, and laid onto the table. stated Epstein caught her looking at the clock on several occasions. Epstein asked her if she was in a hurry. stated her boyfriend was in the car waiting for her. further stated that Epstein got upset as he wasn't enjoying the massage. She told him that she didn't want to continue and she would not be back. Epstein told her to leave as she was ruining his massage. advised she had no formal training in providing any massages. stated although she had a falling out with Epstein, she still received a Christmas bonus from Epstein. Western Union revealed money was sent from Jeffrey Epstein on December 23, 2004. stated she was wired money from Western Union for her Christmas bonus. Suli&ia results from received $200.00 from Epstein for her Christmas bonus. On November 15, 2005, Det. and I met with dob . During a sworn taped statement, stated she met Jeffrey Epstein over a year ago. She was sixteen years of age and was approached by , a fellow Royal Palm Beach High School student, who informed her that she could make $200.00 providing a massage to Epstein. had informed her that she would have to provide this The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det who is personally known to me. Signature of Police ( fticer ( .S.S. 11 .10) ate o or u Coun of Palm B ch Signatur Date: 05/01/2006 Officer If° Page of 22 EFTA00231860 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 stated rnassaggiess. and she entered through a glass door that led into a kitchen. She was taken upstairs by made the arrangements with Epstein and his assistants and took . to the house. , to a master bedroom. She recalled the master bathroom had a large couch, sauna and matching shower. Epstein entered into the room wearing only a towel.. and removed their clothing remaining only in thong underwear. She further stated that Epstein laid on his chest on the table. The oils were selected on which ones to use. Both and . provided the massage on his legs, back and feet. Forty minutes into the massage, Epstein turned over onto his back and re uested wait downstairs in the kitchen area for Epstein instructed . to finish the massage. As ot dressed startinALubbing Epstein's chest. left the room, and Epstein began masturbating as . M stated Epstein continued masturbating until he climaxed on the towel he was wearing. When asked if he had removed the towel she stated he turned the towel around th at the opening would allow him to expose himself. After he cleaned himself off with the towel he instructed the massage was done and to get dressed and meet with him downstairs. ot dressed and met with Epstein in the kitchen area. She was paid $200.00 dollars for providing the massage. stated she was aware that also received monies for the same thing. The second time she went to the house she was again approached by advised if she wanted to return to the house traEovide another massage.. agreed and the arrangements were made by for her to return to the house. M stated drove her to the house and knocked on the same glass door which leads to the kitchen area. They were allowed entry into the hot y) one of the staff members. led her upstairs to the master bedroom and master bathroom area. = left . this time to do the massage alone. Epstein entered the room again wearing only a towel. • began removing her clothing as she did the last time she was at the house. Epstein instructed her to get naked. He laid on the table onto his stomach as El began massagrim his legs and back. As . finished with Epstein's back and legs, Epstein then turned over onto his back. M started to rub his chest and he began masturbating. As ru bbed his chest, Epstein leaned over and produced a massager/vibrator. He turned it on gran rubbing vagina and masturbating himself at the same time.. stated she is this was occurring. She described the vibrator/massager as large grey with a large head. Epstein for approximately two to three minutes with the massager/vibrator. He then removed the and concentrated on masturbating himself.. stated Epstein climaxed onto the towel again and informed her that the massage was done. ot dressed and met with who. was waiting in the kitchen area. She received $200.00 for the massage. said she never returned to the house and had no desire to return to the house.. was asked if she received any formal massage training. She advised she had no formal training.. was asked if Epstein knew her real age.. stated he knew, as he asked her questions about herself and high school. He was aware she attended, and is still attending Royal Palm Beach High School. The foregoing instrument was sworn to or affirmed before me this ls' day of May, 2006 by Det , who is personally known to me. Signature of Police fficer .S.S. 117.10) Page of 22 EFTA00231861 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 During the course of the investigation a search warrant was executed at Jeffrey Epstein's home located at 358 El Brillo Way in Palm Beach. While in the home I observed the pink and green couch within the master bedroom area just as the girls previously mentioned. The stairway, which is located from the kitchen area to the master bedroom area, is lined with photos of naked young girls. Additionally, numerous photographs of naked young females, some of which appeared to be the girls I previously interviewed, were on display throughout the house. Also located in the house were various phone message books. The telephone message books have a duplicate copy (Carbon Copy) which, once a phone message is written into the book, the top copy is then torn on the perforated edge and the carbon copy is left in the book. First names of girls, dates and telephone numbers were on the copy of the messages. I recognized various numbers and names of girls that had already been interviewed. The body of the messages were time of the day that they called for confirmation of "work." Other names and telephone numbers were located in which the bod of the messages were, "I have girls for hint" or "I have 2 girls for him." These messages were taken by , who signed the bottom of the messages. During the execution of the warrant, I located a Royal Palm Beach High School transcript for U in Epstein's bedroom desk. This desk had stationary marked Jeffrey E Epstein. I located a wood colored armoire beside Epstein's bed that contained a bottle of "Joy Jelly," which is used to provide a warm massage. Several massage tables were located throughout the second floor of the residence, including a massage table found in Epstein's bedroom. On the first floor of the residence I found two covert cameras hidden within clocks. One was located in the garage and the other located in the library area on a shelf behind Epstein's desk. A computer was located which was believed to contain the ima es from the covert cameras. The computer's hard drive was reviewed which showed several images of and other witnesses that have been interviewed. All of these images appeared to come from the camera positioned behind Epstein's desk. On December 13, 2005, Det. and I met with U, dob . During a sworn taped statement, stated that when she was sixteen years old she was taken to Epstein's house to provide a massage for money. stated it was before Christmas last ear (2004) when an associate, approached her and asked if she needed to make money for Christmas. I. made arrangements to take to the house and drove to the house to "work." They were encountered by a white female with long blond hair.. was unable to remember the name of the white female with blond hair but knew she was Epstein's assistant. She was led upstairs by the white female who explained that there would be lotions out already and Epstein would choose the lotion he wanted her to use. She was led through a spiral staircase which led to a master bedroom and bathroom. The massage table was already set up in the bathroom.. described the bathroom as a large spacious bathroom with a steam room and shower beside it. • was introduced to Epstein who was on the phone when she entered the room. Epstein was wearing a white towel and laid on his stomach, that • may The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det who is personally known to me. Signature o o lee leer . . 17.10) State of Florida County of Palm Bea h S Date: 05 ficer Page of 22 EFTA00231862 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 massage his feet and calves. • started the massage with the oils Epstein chose and rubbed his feet and calves. Epstein got off the phone and requested she massage his back as well. began rubbing his back and got to the small of his back. During the rubbing of his back, Epstein asked her to get comfortable. He requested she remove her pants and shirt. removed her shirt and pulled her pants off. stayed in her bra and thong panties. As she finished massaging the small of Epstein's back, he then turned onto his back. Epstein instructed to rub his chest and pinch his nipples. As she , Epstein asked her questions about herself. • remembered telling him she attended Royal Palm Beach High School. Epstein asked her if stated she was shy and didn't like talking about those things. She continued she was sexually active. Before ■ could answer, he also asked what sexualposition does she enjoy. . Epstein reached u and unsna her bra from the front • explained the bra she used had a front snapping device. Epstein and asked her if she like having said "no, I don't like that." Epstein then removed his towel and laid on the bed naked exposing his penis to . He be an touchin his enis and masturbated as he explained Epstein then touched . • tensed up and stated Epstein was aware that she was uncomfortable. stated that Epstein said to her, "Relax, I'm not going inside." She further explained Epstein commented to her how beautiful and sexy she was. Epstein then moved her thong anties to one side and began said. "He commented how ." He then She tried pulling back to from within her 'agina. Epstein and apologized for Dus-inillis time, he kept his and continued to rub her vagina. stated he as he was masturbating. said he climaxed onto the towel he had been previously wearing and got up from the table. Epstein told her there was $200.00 dollars for her on the dresser within the master bathroom. Epstein also told her that there was an additional $100.00 that was to be given to for bringing her there to massage him. Epstein told her to leave her telephone number with his assistant as he wanted to see her again. Epstein stated his assistant would contact her to work again soon. I asked her if she ever received any formal massage training to which stated she did not. stated it was the only time she ever went to work for e and knew what happened to her was wrong. She further stated that she had never been contacted for any additional work. On January 9, 2006, I located and interviewed another victim, dob was identified as a potential victim/witness from information obtained during trash pulls from Epstein's residence. stated she met Epstein when she was fifteen years of age. She was approached by a friend from Royal Palm Beach High School, to be taken to Jeffrey Epstein's house to work. She was originally told she would be able The foregoing instrument was sworn to or afllrme before me this 1" day of May, 2006 by Det who is personally known to me. Signature of PoliceOfficer .S.S. 117.10) State-of-Florida Co Signatur icer Date: 05 Pagel /of 22 EFTA00231863 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 to model linzrie for a wealthy Palm Beacher. El was taken to Epstein's house located on El BrilloWay. introduced . to Jeffrey Epstein. Epstein had his personal chef prepare dinner for • and . At the conclusion of dinner, = and Epstein brought . upstairs into a master bedroom area. observed a large massage table with a sheet on it. Epstein entered through a door and exited wearing only a towel. informed El that they were going to provide a massage on Epstein. El asked why were they doing this instead of modeling lingerie. ex lained to . that this was his routine and to rub his calves and feet. Epstein had told . to get comfortable. removed her pants and blouse. . stated she stayed only in panties as she did not wear a bra that evening. stated while rubbing his calves and feet, Epstein turned over onto his back. Epstein told . to rub his chest and rub his ni les. stated that as she started Epstein began masturbating himself . Epstein and with his fingers. gEstein continued to masturbate himself as he . Epstein ejaculated on his towel and paid . $200.00 for the massage. Ipain told • that if she told anyone what happened at his house that bad things could happen. 1 .and = were brought home by Epstein's houseman and El was afraid that Epstein knew where she lived. stated that several days later she received a telephone call from who coordinated for • to return to "work." MI returned to the house and was brought to Epstein's bedroom area by who prepared the room for the massage. Epstein entered the room wearing only a towel. Epstein had remove her clothing and provide the massa e naked. be an rubbing his feet and calves and Epstein turned over onto his back. Epstein lownward motion on his penis. Epstein continued . E stein be an to masturbate himself with an upwards and with one hand and masturbate with the other hand. Once Epstein ejaculated onto the towel he was wearing, the massage was over. . was paid $200.00 for the massage. Epstein again told • not to speak of what happened at his house or bad things would happen. . wanted to notify authorities however she was afraid of what would happen to either her or her family. During the course of the investigation, several subjects were identified as a potential witness/victim through information obtained during the trash pulls, physical surveillance and telephone message books retrieved from the search warrant. While conducting research on the subjects, I discovered that the females were age eighteen or older. Interviews were conducted on the consenting adults whose statements provided the same massage routine when they went to "work" for Epstein. The females would be notified by and made appointments for the females to "work" for Epstein. The females would come to Epstein's house and were led upstairs, through a stairwell from the kitchen area, by to Epstein's bedroom. Epstein would then enter the room wearing only a towel, and ask them to et comfortable. The females would then provide the massage naked as Epstein would either and/or utilize the massager/vibrator on the foregoing instrument firmed before me this 1" day of May, 2006 by Det , who is personally known to me. Signature of Police ffice (F.S.S. 117.10) State of Florida Coun of Palm Bea Sig Date: 05/0 Page2Qtf 22 EFTA00231864 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 He would masturbate during the massage and upon his climaxing, the massage would end. The girls were then paid two or three hundred dollars for the massage. On November 21, 20051 interviewed Jose Alessi, a former houseman for Jeffrey Epstein. Alessi stated he was employed for eleven years with Mr. Epstein, from approximately 1993 through 2004. Alessi stated he was the house manager, driver and house maintenance person. It was his responsibility to prepare the house for Epstein s arrival. When asked about cooks or assistants, Alessi stated they traveled with Epstein on his private plane. I asked Mr. Alessi about the massages that have occurred at Epstein's home. Alessi stated Epstein receives three massages a day. Each masseuse that visited the house was different. Alessi stated that towards the end of his employment, the masseuses were younger and younger. When asked how young, Mr. Alessi stated they appeared to be sixteen or seventeen years of age at the most. The massages would occur in Epstein's bedroom or bathroom. He knew this because he often set up the massage tables. I asked if there were things going on other than a massage. Alessi stated that there were times towards the end of his employment that he would have to wash off a massager/vibrator and a long rubber penis, which were in the sink after the massage. Additionally, he stated the bed would almost always have to be made after the massage. On January 4, 2006 I interviewed another former houseman, Mr Alfredo Rodriguez. During a sworn taped statement, Mr. Rodriguez stated he was employed by Jeffrey Epstein for approximately'six months, from November 2004 through May of 2005. His responsibilities as house manager included being the butler, chauffeur, chef, houseman, run errands for Epstein and provide for Epstein's guests. I asked Rodriguez about masseuses coining to the house. Rodriguez stated Epstein would have two massages a day. Epstein would have one massage in the morning and one massage in the afternoon everyday he was in residence. Rodriguez stated he would be informed to expect someone and make them comfortable until either or Epstein would meet with them. Rodriguez stated once the masseuses would arrive, he would allow them en into the kitchen area and offer them something to drink or eat. They would then be encountered by either or Epstein. They would be taken upstairs to provide the massage. I asked Rodriguez if any of the masseuses appeared young in age. Rodriguez stated the girls that would come appeared to be too young to be masseuses. He stated one time under Epstein's direction, he delivered a dozen roses to Royal Palm Beach High School for one of the girls that came to provide a massage. He knew the girls were still in high school and were of high school age. I asked Rodriguez about the massages. He felt there was a lot more going on than just massages. He would often clean Mr. Epstein's bedroom after the alleged massages and would discover massagers/vibrators and sex toys scattered on the floor. He also said he would wipe down the vibrators and sex toys and put them away in an armoire. He described the armoire as a small wood armoire which was on the wall close to Epstein's The foregoing instrument was swu. ii to u. Ali sued before me this day of May, 2006 by Det a, who is personally known to me. Signature of Police ffice (F.S.S. 117.10) State of Florida Count Be , 'h Signature/A' Officer Date: 05/01 Page 1 4)f 22 EFTA00231865 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 bed. On one occasion E stein ordered Rodriguez to go to the Dollar rent a car and rent a car for the same girl he brought the roses to, that she could drive her self to Epstein's house without incident Rodriguez said the girl always needed rides to and from the house. Rodriguez produced a green folder which contained documents, and a note with Mr. Epstein's stationary with direction to deliver a bucket of roses to Royal Palm Beach Hi School after E high school drama performance. Also in that same note was direction to rent a car for and direction to extend the rental contract. During the course of the investigation, subpoenas were obtained for cell phone and home phone records from several victims and witnesses along with the cell phone records of records was conducted which found numerous telephone calls were made between and the victims. These records indicate the dates the calls were made are consistent with the dates and times they victims/witnesses stated they were contacted. Specificall , The phone records showed called during the exact times and dates when victim advised the incident occurred. also coordinated the encounters with E, and during the time frame the girls stated they occurred. An analysis of these Pursuant to a lawful subpoena I obtained Epstein's private plane records for 2005 from Jet Aviation. The plane records show arrival and departure of Epstein's lane at Palm Beach International airport. These records were compared to the cell phone records of This comparison found that all the phone calls made to and the victims were made in the days just prior to their arrival or during the time Epstein was in Palm Beach. Therefore, as Jeffrey E stein, who at the time of these incidents wasa one years of age, did have vaginal intercourse either or digitally with •, E, E and =, who were minors at the time this occurred, there is sufficient probable cause to charge Jeffrey Epstein with four counts of Unlawful Sexual Activity with a Minor, in violation of Florida State Statute 794.05(1), a second degree felony. As Epstein, who at the time of the incident was fifty two years of age, did use a vibrator on the external vaginal area of E, a fourteen year old minor, there is sufficient probable cause to charge him with Lewd and Lascivious Molestation, in violation of Florida State Statute 800.04 (5), a second degree felony. The foregoing instrument was sworn to or affirm before me this 1" day of May, 2006 by Det who is personally known to me. igna ure o cote ter . . . 117.10) Cou Signature/ filter Date: 051 Page22of 22 EFTA00231866 REQUEST FOR WARRANT DEFENDANT: DATE OF BIRTH HABITUAL OFFENDER: YES NO A/K/A VICTIM RELATED / ACQUAINTED WITH DEFENDANT? YES XX AGENCY CASE NUMBER: 05-368 M LEAD OFFICER: Det AGENCY: PALM BEACH POLICE DEPARTMENT NO PHONE NUMBER: (5611 838-5454 CURRENT SHIFT HOURS: 8 am TO 5 Dm DAYS OFF: LEAVE / SHIFT CHANGE INFO: WAS ARREST MADE FOR, OR IN CONJUNCTION WITH ANOTHER AGENCY. IF SO, WHAT AGENCY?: SENTENCING RECOMMENDATIONS: CONTACT DETECTIVE ADDITIONAL COMMENTS: TUNG DOCUMENTS ATTACHED: X ARREST FORM P.C. AFFIDAVIT (2 COPIES) >C. WITNESS / EVIDENV Clegultnatti 5 11/04 lb KS ems C SWORN STATEMENT MATERIAL WITNESS(ES) X OFFENSE REPORT (2 COPIES) ACCIDENT REPORTS (ALL) WITNESS STATEMENTS (ALL) GkIC/NCIC CRIMINAL HISTORY914‘,H4Ri.N in et% Irrati fteteittmeit￾QUEST FOR CONVICTION LETTERS PROPERTY RECEIPT PtraCUSI4 4.11Jen vE;Inpa tIt vir SW) Et OTHER ATTACHMENTS INCLUDE: INITIAL FOR COMPLETENESS: JR OflKER RECEIVED, STATE MOPNIEMFFICE ON: is t rbrA te 'tanft imet 7915 ID/ 050106 DATIS EFTA00231867 OBTS Minter «l i l t 1 J_ ARREST I NOTICE TO APPEAR 1 Angel 3 Repast ICIWinn Juvenile Referral Report 2 N TA a Request fOr Ca0a F--- w /— Agency OM NLinber FLO, 5,010[6,0(0 Agency Name PALM BEACH POLICE DEPARTMENT FOR NY IMport MAW (N.TA% of* 7 16H i H ll I 1 1 I I Ill i 6 Charzyrmy -,° 1 reicirY 0 3. Mnoemeara C S Ordnance I JI Weapon Seized • mty 'u 2. Traffic Faddy 0 4. Traffic Msdemesnor OS. Omit Enter Trde Maisie Cleenome t I A vx,alion it a Arrest (Including Name of Li,,adeam Locallon a 011pmea (Business Nerds Address) , . , rrocalor [ t Date a Arrest t I I IL _I Timeof Arrest Dare Booking 7 Jai Dale ail Time I I Locallen al MINS I Name BAN Rat ARUM DOB. Soc. Sept, Et) Rios son BVarrahall ok 0 1=ray= V.( 4 " ' SWS. Mims. Tuna. Lasted PING* Ftanil L ddaupp a El g` ❑ . Z t Loaf APTAIss rStreet, MX. Nurnberl (CM 10.410 (Zp) Phone R.Vdv Type: 1. Oly 3 Riede 2. County 4 Out ol Sin Liz 0 Address Source OccupaDon ._ Piano Gnh (City. Slam) Covina-to u. w 0 CO-Deferciani Name ;Last Fat, PAWN of i Arrested . tom 2 Al Large 4 Mscemeador . venire g Co- roam Name (Lae. Fant, Maas) Rico _ Sex DAN or Ban b Uf airy end Larq 4. Mischerraida 5. Aorilt S al Name MAO (Film (Vadae) Cusladan Residence Pdode I 40 Adirniss (Segel. Apt Number) (Cpl (Stale, (Zip) Oil rest Mom* -± U4 TOT JAC Dew r -re Tealt. address was proved by QD delencanl as/ ca 0 diarandamt canna The clad and For Parent was told ta keep Me JUVIIMIO Can Clines Office (Phone 355-2526) informed ol arty Orange of address_ a, by: (Name) 0 M. (Reason) School Attended Care arty Crime? 0 WIll 0 No DOICTIPOOO a Repay Yak* or Pr OPtel Itudir MY field/ SS R. Smuggle K D0rensed M Mantaari ( Odor UICYPO p B. Barb/area IL Kelludnogan P arapheruhar U. untrown C CocM'e Z Other 0 P. Posts T. Nano E. Use wale A. AffOlalarnAO E. Hew M.OpiAiDerw S. Scil= 1 ul I CpANglo 0040100fl Camp; ier , '..- • \dJk: T... • _I- \A 4. 00m4SOC Potence DY OA SUM* VOIAII0O MATS • , - 1, ( I 4 I-1 ' -1 --. 1 , 111 l I 1 IVIOAOCIA 0 OAD a C) Qua Acthaly (Drug Topa J.-.: , I Arraunl /UM Care PI.as,r Warrant / Capas NuMier aro 1 CAII9O Deactipeon I 1, . , ,. , 2 : . j , t Cowes IRA GINN Vidalia. Runts t I .-- irl • .t i _t III -I. I 1 viouraco a ORD . ) x 0 Only Act.*yl DRlplypa Amount f Uril Offense e Warrant (Capes Noma.. Bond iy, 1 Chug. DeScrIplon Counts _CI Domailbe 'Mende T OH SAWA 1,1o1aboo Number z I H I I I 11.1 1 .1 1 ) Volition or ORD a 0 Drug AcarAN I Ow type Arrebunt/ unt Odense. Waren /Camas Number l I Bond w Charge Disalpton COO'S LOCOIte n Y ON SWAN McNeal Number 1 t L I 1 I I 1(1 I 1 I Molina. of ORD a ): I Drug MOMS I Caup TYPO Amount f Una Menu a Weimar Capes Number BoN/ 0 Instnaion No, 1 fallinaral Pazianme• in Cain O Location (Court Moors Numaer, Address) 1 41 leetnxbon No. 2 You need nil appear in Coun but must ace* with astmarona on Ramose Ste. Coun Dale end Time month Day Year Time AM PM /— TO APPEARAT-THE-TIME ANOPLACE OESIONATEO R7r MOWER THEOPPINSECHARGEO CRTCPAY/NE FINE SUBSCRIBED7I UNDERSTANDTHAT SHOULD 1 VALLFULLY FAIL TO ; APPEAR BEFORE THE COURT AS REQUIRED BY THIS NOTICE TO APPEAR, THAT I MAY BE HELD IN CONTEMPT OF COURT AN0 A WARRANT FOR MY ARREST SHALLBE ISSUED. 2 sow.. or Gronsant (or Juvenile and Parent JOatoclisn) Dale Smiled HOLD for other Agency fo" 'A.. Signature ol Arresang Oacer - Name verinciation (Ported by MOWN) Z amorous (3 Resoled Arrest (PRINT' g O Suicidal 0 OMR PAGE < Intake DiMAY Mt a I Pouch , - -. -- . - • . Wens Mil rt slaw signed mid an • OF DISTRIBUTION: WHITE — COURT COPY GREEN — STATE AT- ORNEY YELLOW — AGENCY PPE — JAL GOLD • DEFENDANT (N.T.Ab ONLY) EFTA00231868 MS whom ARREST / NOTICE TO APPEAR 1 men 3 Reemill ke Warrani Juvenile Referral Repoli 2 N T A 4 Repeal for Cape 7 ,ann.e p i i i i i i . , Agency OM Number s-rtor 5 a 0a0 a 6 a 0a0 Ageism Name PALM BEACH POLICE DEPARTMENT Away NOCul Hunter (N.T.A.V ontY) 7 a 6i-i a I-I i t i i a Ill t i ) E . MI Many 0 a. Felony 0 a ukvaiThanot 0 5. Ordinance a Weapon Seised 0 2. Traffic Felony 0 4. TrelOc Mistlermance 0 6 Other Enter Type MAP* Orarence Many . A Location <, ot Mee (ram% Name of Business) Location of Mimes (Busmen Name. Addreas) Dam or Arrest Timed Arrest I I t_ _ Booking Dwr BCC/. , , I. Tv Jar Dale Jar Time Location of *hide Name (Last First lardel MIAs Name. DOB. Soc. Sec. I. Doi Race • White 1 • Amman (Mary El • Black 0 • Ono-4VA~ 1 Sea Dem of Beth _regal i t: N I L We0/1 Eye COW Has Color Complete:In Bid W Scars Mn,. Taco,. Unclue Physical Femmes Socaiton. Type. Liesotitoce) mental Siam Reopen tracanon i￾z or: AlCci" OL9 Irdcaccia lawka a a my DEFEND/ Local Address (Street Apt. Hunter) (Ohl (State) (zact Phone ( ) Roam* Type: 1. Cay 2. Gouty_ 1. °Metals* I Permanent Addeess (Street API Maniere (City) ISUle) (Zip) Panne I ) • Anus source Bearable Sees Name. Street! ICItyl (Stile/ (LP) Want ( ) Occupalton DA. Minter. Stint roc Sim Number INS cants Place ol Oct (LAM Stale I CilarteshiP U. CoMehanclant Name [Lam Fest MCON) Race Sex Date of Beth H2- k° new 4 rayons,net I Jimmie g. Catleternaol erne liar. First. Mn.) Race Sea Date 01 Bess HI MAT= a Felony 4. LesclemearrOf _ 5. Jwande IVENILE Bo Pare7t .4amain Name (Last) (Foil) MOM) Res din Phone 1 I Address :SWIM. ADC Nwnitier) (OW (Stale) (Zit) (kermess Phone I I TOT JAC Debi Tee C TI Ms:we — adtren wit provided De 0 Ofileard and / Or 0 Oaleadalle CrIfeelt. The dm end r Ce Darnel win IDIO eip the JUviOnehl Cam anal Odra (Phone 3554526) Ireaantee al any thWeillt W 'Ma M. by: (erne) 0 fatrabobsoab School AtMaded Grade • Poway OW& . I OM Otto Descr000n al Propel, Wu* of Property T i9.Rgi Acton t as. Buyi P Possess T. Trine Fe.ruffle KOtspanser M &Ionian Z. Other E. Use Mr* B.1rarbilwate N. titaNuonmen P Paratmematai C Came* M. Mantuan* Ermittineill A. Amphetarrane E. Heroin 0. OpeunvIDene S Swilhefic U. Unknown Z. Othe 0 Charge Dericreeon Tows DOMUC Stage VIOlaton Water Viamon of ORO I Q n i N I I Il l I 1 1 (1 I I I ) 1 L) dug AcOraly Drug Type AmouM / Uist Oftenee a Wrist (Cams Hiner Bond Charge Deectmoon Counts Domenic Weems 0 Y ON Singe Motabon Hurter I I I•I I I I II I I I Violation of ORD 0 ) br r I) Drug astivity Drug Type ArMunt / Una Obese a Warrant /Capes Welber Bond w Charge Dmatarin Coons Dorneek DO N Slats %%Won Number I L 1.1 A I I I (1 I i t tholaien or ORD a ) 1 C_, Drug Aaftly Ogg Type Antunt I Um I-I-rre r Wan WV I Capes fluent. Bend Charge Potation Coons Coneat 0 Y ELN Stage Votarien Plumber 1 I 1•11 , i I l(l t ' i ) %bop of ORD s i 0 Drug Mayey Drug Tim Amount/ UM °manse e Wirtarr / Camas Menem Bono 0 Irellnaclarn NO. I lAwatOrePOPIrmaCe In Count LOCalion (Court Poem Nureber. A6:Irees) 1 O Intension No. 2 You need MI WOW in coon but INS compg Mtn Instrucbons on Reverse Ste. Come Data at Time NW Tom AM. PIA e lo" _Cri I AGREE TO APPEAR AT THE TIME AND PUCE DESIGNATED TO ANSWER THE OFFENSE CHARGED OR TO MY THE FINE SUBSCRIBED. I UNDERSTAND THAT SHOULD I WILLFUU.Y FAP.10 APPEAR BEFORE THE COURT AS REWIRED BY THIS NOME TO APPEAR. THAT I MAY BE HELD *1 CONTEMPT OF COURT AND A WARRANT FOR MY ARRESTSANS BE ISSUED. § Somme of Defendant la Jimmie and Parent /ComocIlan) Due Seem! HOLD tor aim Agency II: Salta ol NIHON &ICS x Name Ventemon (Pile*, by Arrefie•) (Often 1 U Dangerous 0 Resisted Mem , Li Suckle! O Other Nano os ArroSing Officer (Wirt) 1.0. 1 PAGE Mtitlw DeoulY I.D. / POLIO Telogearen0 Officer I. D.1 Agency Wanes. ,we ri fartarICI Knee WM an x. OF DISTRIBUTION: WHITE — COURT COPY GREEN — STATE ATTORNEY YELLOW - AGENCY PINK - JAIL GLIM DEFENDANT (N.T.ASOM-Y) EFTA00231869 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 Police Case#: 05-368 (2) Defendant: Race/Sex: White Female DOB: Charges: Principal in the 1" Unlawful Sexual Activity with a Minor (4) counts Principal in the 1' Lewd and Lascivious Molestation (1) count From March 15, 2005, through February 2006 the Palm Beach Police Department conducted a sexual battery investigation involving Jeffrey Epstein, =I= and . Sworn taped statements were taken from five victims and seventeen witnesses concerning massages and unlawful sexual activity that took place at the residence of Jeffrey E stein, 358 El Brillo Way, Palm Beach. Several of the victims were recruited by and brought to the residence by to perform massages for Epstein for which received monetary compensation. During the visit they would be introduced to Epstein's assistant, who in turn would record their telephone numbers and name. The victims would be brought to Epstein's bedroom to provide the massage. Epstein would enter the mom and order the victims to remove their clothing to provide the massage. As the victims complied and provided the massages, E stein would On occasion, Epstein would introduce a massager/vibrator and as they provided the massage. On three separate occasions, Epstein had intercourse and inserted his penis/fingers in the victims vaginas. At the conclusion of the massages the victims were paid sums of money ranging from $200 - $1,000. The facts, as reported, are as follows: On 03/15/2005, A fourteen year old white female, hereinafter referred to as dob and her family reported unlawful sexual activity which occurred at a residence within the Town of Palm Beach. reported that a subject known to her as "Jeff' had touched her vaginal area with a vibrator/massager while within his residence. "Jeff" was later identified as Jeffrey Epstein through a photo line up. During a sworn taped interview, stated that , dob a cousin of boyfriend and classmate at Ro al Palm Beach High School, worked for a wealthy man and did sexual favors for him. She also admitted that had offered her an opportunity to make mone During the beginning of the month of February 2005 explained that she was first approached by to o with her to Epstein's house. stated that alon with a Hispanic female, later identified at p2k her up at her father's house on a Sunday. was not sure of the exact dates but knew it was a Sunday. told her father that they were going shopping but in reality drove them to Palm Beach. During the drive a The foregoing instrument was sworn to or affirmed before-mrthis 1" dayolMary,- 2006—by Det , who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida -- Conn f-Pahn-Beach Signa r esting Officer Date: i 01/2006 Page I of 22 EFTA00231870 Probable Cause Affidavit Palm. Beach Police Department Agency ORM FLO 500600 conversation occurred between and E whereas re ortedly told that if Jeff asked her aee, she should say she was eighteen. It was later confirmed by the father that picked his daughter up on February 6, 2005. According to . father, drove a pick up truck. . described Epstein's house as a two-story pink house with a Cadillac Escalade parked in the driveway. She recalled that Jeffs house was on a dead end street. Upon arriving at the house . stated that they walked up a driveway, past what appeared to be a small guard/security room. A male approaching them asking what they wanted. e stated they were there to see Epstein. The male allowed them to continue walking up to the house. stated the man told them that Epstein was not there but was expected back. He allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside. Short] thereafter, Epstein and his assistant, described as white female with blond hair and later identified as , entered the kitchen. Epstein introduced himself to M. . described Epstein as being approximately forty-five years old, having a long face and bushy eyebrows, with graying hair. and Epstein left the kitchen leaving . alone in the kitchen. They returned a short time later. They all spoke briefly in the kitchen. . was instructed to follow upstairs. • recalled walking up a flight of stairs, lined with photographs, to a room that had a massage table in it. Upon entering the room there was a large bathroom to the right and a hot pink and green sofa in the room. There was a door on each side of the soft . recalled there being a mural of a naked woman in the room, as well as several photographs of naked women on a shelf. told the victim that Epstein would be up in a second. Epstein entered the room wearing only a towel and told . to take off her clothes. II stated Epstein was stem when he told her to take off her clothes. . said she did not know what to do as she was the only one there in the room, she took off her shirt leaving her bra on. Epstein had removed his towel and told the . to take off everything. I stated Epstein was nude when he took his towel off, placing it on the floor as he laid down on the table. stated she then removed her pants leaving her thonisanties on. Epstein then instructed her to give him a massage pointin to a specific lotion for her to use. As . began to give E stein the massage, he told her to get on his back. stated she straddled herself on Epstein's back whereby . IN said Epstein was specific in his instruction to her on how to massage him, telling her to go clockwise or counter clockwise. Epstein then turned over and instructed . to massage his chest. El was now standing on the ground and resumed massaging Epstein's chest area. . stated Epstein held onto the small of her back as she massaged his chest and shoulder area. Epstein then turned to his side and started to rub his penis in an up and down motion. Epstein then pulled out a purple vibrator and began to The foregoing instrument was sworn to or affirmed beforn Det State of Florida who is personally known to me. Signature of Police O ficer (F.S.S. 117.10) aunty of Paltirgeach Signal .Tripting Officer Date: 1/2006 Page 2of 22 EFTA00231871 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 . . stated there was no penetration as the recalled Epstein ejaculating because he had to use the towel to wipe himself as he of off the table. Epstein then left the room and . got dressed. She went back downstairs where she met with . M said she was paid three hundred dollars in cash from Epstein. Before she left Epstein asked to leave her phone number. As M, and were leaving the house, told • she received two hundred dollars that day for bringing her. I L . During the course of the investigation, parental consent was granted for to assist with the investigation. At our direction conducted controlled taped phone calls to cellular telephone 561- 308-0282.. spoke with in an attemtusange another meeting with Epstein. M asked , what did she need to do to make more money. stated, "the more you do, the more you get paid." had subsequently called back . and left a voice mail message for her indicating that she had set up an mintment for • to go to Epstein's house at 11:00 am on April 5, 2005. This message was recorded from = voice mail. Based on the above, trash pulls were established at Epstein's residence with Supervisor Tony Higgins of the Sanitation Bureau of the Town of Palm Beach. The trash pull from April 5, 2005 revealed Sone message for Epstein which stated and name at 11:00 am. This was the time frame had informed to be ready to go work at Epstein's house. On October 3, 2005, Sgt and I went to residence and viewed her vehicle parked in the driveway, a red Dodge Neon. Sgt. and I knocked on the door and met with was told that we were investigating a claim involving Jeffrey Epstein of El Brillo Way, in Palm Beach. VMS asked if she would accompany us back to the police station for further questioning. She was also told that at the conclusion of the interview she would be returned home. voluntarily came with us back to the Palm Beach Police Department. Upon our arrival at the police station, was brought to the interview room in the Detective Bureau where I obtained a taped, sworn statement. I began the interview by asking how she became acquainted with Epstein. stated that approximately two years ago, just after she turned of age, she was approached by a friend named at the Canopy Beach Resort in Rivera Beach. was asked if she wanted to make money. She was told she would have to provide a massage and should make $200.00. thought about the offer and agreed to meet with Jeffrey. The foregoing instrument was sworn to or affirmed befltittalm ---day of frlayrI0N , —by Det who is personally known to me. Signs ure o o tee icer . 17.10) State of Florida County of Paoli Beach Signat ng Officer Date: /2006 Page3of 22 EFTA00231872 Probable Cause Affidavit Palm Beach Police Department Agency ORIN PLO 500600 Epstein's house. Upon her arrival to thei.c se she was introduced to Epstein in the kitchen of the house. She (Unknown last name) and (Unknown last name) picked up and she was taken to was also introduced to a white female known to her as . She was led upstairs to the main bedroom known to her as Jeff Epstein's bedroom. arranged the massage table and covered the table with a sheet. She brought out the massage oils and laid them next to the massage bed. , then left the room and informed Jeff would be in, in a minute. Jeff entered the bedroom wearing only a towel. He removed the towel and laid nude on the massage table. He laid on the table onto his stomach and picked a massage oil for to rub on him. During the massage, stated "He tried to touch me and I stopped him." I asked how he tried to touch her. stated that Epstein and she felt uncomfortable. told Epstein, I'll massage you but I don't want to be touched. stated she performed the massage naked. At the conclusion of the massage, Epstein paid $200. After the massage Epstein stated to that he understood she was not comfortable, but he would pay her if she brought over some girls. He told her the younger the better. stated she once tried to bring a 23 year old female and Epstein stated that the female was too old. stated that in total she only remembers six girls that she brow t to see each time she was paid $200. stated she had female) and brought the followin ' ls: . , , M. ( al6 year old female), (a 16 year old through 16 years of age. I asked said that at the time she brought these is Epstein's house they were al114 which one was the youngest. advised . was the youngest as she was fourteen when the massage occurred. stated every girl she brought knew what to expect when they arrived. They were told they would provide a massage, possibly naked, and allow some touching. I asked her if M was aware. She stated every girl she brought knew what to expect. She explained she knew that • wanted to make money. She approached . and explained about going to work for Jeff, . agreed and arrangements were made to brie her to Epstein's house on a weekend. stated that she and (Later identified as picked up . at her house. stated that at that time she was driving a red pickup truck. They traveled to E house and entered through the kitchen door. They met with the house chef and Epstein's assistant =. • was introduced to Epstein while the were in the kitchen area. led . upstairs and Epstein went upstairs. When the massage was over returned to the kitchen area. stated she was paid $200.00 for bringing M to Epstein's house. stated M told her she was paid $300.00 for the massage. stated that . was the last person she brought to Epstein's house. She had changed her cellular number to avoid being contacted by . She continued stating that she had no direct contact with Epstein The foregoing instrument was sworn to or affirmed ---- trefurrurrthislu—day-of -Mar-2006 by Det who is personally known to me. Signature of Police ficer Q.S.S. 117.10) State of Florida Signs mg Officer Date: lb 11/2006 PageSof 22 EFTA00231873 Probable Cause Affidavit Palm Beach Police Department Agency.ORIN FLO 500600 when he was going to travel to Palm Beach. said when Epstein announces to his assistant, that he is traveling to Palm Beach, would then contact to arrange girls to "work" for Epstein. stated that once her parents discovered that she was visiting Epsteiitlgrilisapproved of the encounters with him and she stopped. further stated that still tries to call house and leaves messages. Sgt entered the room and explained to that based on her own statements, she had implicated herself by bringing underage girls to Epstein's house. provided cellular telephone numbers for the girls she had mentioned previously. Additionally, she also provided possible addresses and areas in which they lived. As was being taken home in the vehicle, a tape recorder was laced the vehicle to record any conversations within the vehicle. During the drive back to her home, made the comment " I'm like a Heidi Fleiss." (Hollywood Madam who sent girls to clients for sexual favors in California). was dropped off at her house without incident. On October 3, 2005, Sgt and I went to speak with a sixteen year-old female who was brought to Epstein's residence by . We met with mother at their front door. We exaned the ongoing investigation and asked to speak with, as we had information that she had "worked" for N. introduced us to her husband and allowed us entry into the home. We sat in the dining room and met with i, Date of Birth . As she was under the age of eighteen, was advised we would be speaking with her. She expressed if her daughter had information, she wanted to assist. We interviewed., who denied haven any inappropriate encounters with Jeff (Epstein). She stated she had gone to Jeff's house with approximately eight months ago and sat in the kitchen with the house chef, but nothing happened. As the parents were present during the interview, we felt that, was withholding information from us. She made several comments as to putting the entire incident behind her. I left myarne number and advised should she wish to speak with me again to telephone me. Sgt and I thanked for her time and left the area. She stated she would ask i again after we left as to what happened at Epstein's house. I informed her that, had my telephone number and hopefully she would call. On Octoberi2005 Det and I drove to the dob During a sworn taped statement when she was seventeen years old, she was taken to a house by because they both attend Royal Palm Beach High School. home and met with and stated a 'proximately a year ago stated she knows She was told she could make money working The foregoing instrument was sworn to or affirmed before me this In day of May, 2006 by Det , who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida Coun P m Beach Signat Date: I of1 p 1/2006 sting Officer Page Sof 22 EFTA00231874 Probable Cause Affidavit Palm Beach Police Department Agency OPJ# FLO 500600 for Jeff. She was told she would have to rovide a massage to Jeff. stated upon her arrival to the house she was brought to the kitchen area by . They met with the house chef who was already in the kitchen area. stated would wait for her in the kitchen. was introduced to , Jeff's assistant, who brought her upstairs to the master bedroom. prepared the room and massage table for a massage. Epstein entered the room wearing only a towel and she provided a massage. stated she ke t her clothes on during the massage. She advised sometime during the massage, Epstein and pulled her close to him. the massage, she was paid $200.00 for the massage. I asked said she was uncomfortable' the incident involving . At the conclusion of if she has any formal training in mass es which she re no. I asked her if received any monies for taking her to perform the massage. stated had received money for taking her there but was unsure in the amount. stated she returned to Epstein's house on another occasion with and another '1.1 stated she waited in the kitchen with , while was taken upstairs by stated she only did the massage once as she was uncomfortable with the whole experience. At the conclusion of the interview, the tape was stopped. I was informed that had attempted to reach via cell phone. A voice mail mess a on October 4, 2005 at 10:59 am, revealed a female voice who identified herself as who requested to call her back reference the police questionin provided the incoming telephone number as stated she inadvertently told about the police investigation because had called her to tell her about how she just received a rental car from Jeff Epstein. had called her to tell her that she was given a rental car, a 2005 Silver Nissan Sentra, to utilize to visit famiad visit Epstein. be asking questions. stated asked her what was of on at the house that the police would then called Jeff and and asked what was going on reference the ongoing police investigation. Accsrlin: to =, has since then been trying to contact her to ask about the police •fc questions. I instructed M not to contact information to as she would notify Jeff Epstein and what was transpiring. and do not provide any more On October4, 2005, I made telephone contact with, who had left several messages for me to contact her. During the message, she advised she was not completely truthful when we met in person but would like to speak with me to advise what had happened. She further advised she did not want to speak of this incident in front of her mother. At approximately 3:48 pm I made telephone contact with,. During a taped recorded statement, stated the following: approximately a year ago, when she was sixteen years of age, took her to Epstein's house twice. She knows because they both attend Royal Pal Beach High School. The first time she went, drove to the house. They entered through the kitchen area where she was The foregoing instrument was sworn to or affirmed before me this 1' nay of May, LUU0. by Det MM., who is personally known to me. Signature o o is rce . . 117.10) State of Florida gnatu j1 mg Officer Date: 05 i /2006 Page 4of 22 EFTA00231875 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 introduced to and Epstein. She was taken upstairs to a bedroom by who set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for, to rub on him. At one point during the massage he tried to remove her shirt, at which point she became very upset and discontinued the massage. Both and E stein had a verbal disagreement, at which time she left without being paid. She got with who was sitting in the kitchen and told her "let's go." I advised she received no money for that day. also said that had told her if she was uncomfortable with what was going on, to let him know and he'll stop. She knew that the more ou do the more you get paid. I advised that several weeks later she agreed to be taken a second time by . Once they arrived at the residence, sat in the kitchen and took her upstairs to the master bedroom again. set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for, to rub on him. At one point during the massage he tried to touch her buttocks. As, was wearing tight jeans and had a tight belt on Epstein was unable to touch her buttocks. Epstein then rolled onto his back during the massage and then attempted to touch her breasts., then became u set again and told Epstein she didn't want to be touched. discontinued the massage and was paid $200.00. then went downstairs where was waiting for her. She told she wanted to leave. I said she never returned to the house. stated she is aware that her friend, was also at the house and had a problem with Epstein. I later researched , dob and met with her at her residence. During a sworn taped statement, stated the following: on or about November 2004, she was approached at Royal Palm Beach High School by , a fellow student. asked if she wanted to make money. She agreed and was told she would provide a massage to wealthy man in Palm Beach. picked her up and drove her to a house in Palm Beach. She was brow 1M into the kitchen area of the house. She further stated that fellow Royal Palm Beach High School students and came with them. They were brought into the kitchen where she was introduced to Epstein and other females. stated she was introduced to a female helper of Epstein, the female was described as white female (unknown name ), with blond hair. She stated that the assistant was familiar with . The assistant brought her upstairs into a master bedroom area. The assistant set up the massage table and put out lotions to be used. She told Epstein would be available in a minute. Epstein entered the room wearing only a towel. Epstein removed his towel, and laid naked on the massage table and picked a lotion to rub on his thighs and back. further stated duri.ie massage, Epstein asked her to remove her clothes. She complied and removed her pants and blouse. didn't remember if she had removed her bra but feels that she did. was certain that she stayed in her thong underwear. continued the massage and at one point she climbed onto the massage The foregoing instrument was sworn to or affirmed before me-this-I" Det y of Mny, 2006 b, State of Florida , who is personally known to me. uul uf'fahn-Beai.h Signs ur mg Officer Signature o o ice ter .S. 117.10) Date: 05 006 Pagel of 22 EFTA00231876 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 table, straddling Epstein to massage his back. While doing this . IS was instructed to return to the ground at which time Epstein turned to have his chest rubbed. advised she was sure he was masturbating based on his hand movements going up and down on his penis area. did not want to look at his penis area because she was uncomfortable. Epstein removed a lar e white vibrator which was next to the massage table and turned it on. stated Epstein began Shortly thereafter, Epstein ejaculated and removed himself from the table. He walked over to where the shower was and opened the glass door. She waited as he was taking a shower in her direct view. When I asked how old she was when this occurred, she stated she had just turned seventeen. At the conclusion of the shower, was paid either $350.00 or $400.00. She stated she wasn't sure, but knows it was close to $400.00. stated she never returned to provide a massage for Epstein. At approximately 2:10 pm, Det and I met with E, dob 03/05/1988, at her residence. As was only seventeen years of age, I had notified her mother, that she would be interviewed reference an ongoing investigation in Palm Beach. I assured her that her daughter was not a suspect. I explained the possibility of her being either a witness or victim. advised she wanted E to cooperate and consented to the interview. During a sworn taped statement, stated the following: at the age of sixteen, during the month of September 2004, she was approached by for a chance to make money. E was friends with associates of and knew the same people. had been previously told by her friends from Royal Palm Beach High School, what did for Epstein. called a person known to E as and scheduled the appointment. picked E up and drove her to Palm Beach to a street called "Brillo Way". They drove to the end of the street and entered a large drivewa . The entered the kitchen area of the house and met with Epstein. E was introduced to Jeff Epstein. led upstairs to the main bedroom area and set up the room with a massage table and set out the oils. stated that while going up the stairs and into the bedroom she observed numerous photographs of naked young girls. dimmed the lights and turned on soft music. exited the room and Epstein entered the room wearing only a towel. Epstein picked oils and instructed her to rub his legs, under his buttocks, back and chest area. Epstein asked her to get comfortable. E advised she did not remove her clothes. She was wearing tight jeans and a cropped tank top ex min her belly area. During the massage, Epstein removed his towel and laid on the massage table naked. As area, he attempted to reach down her pants to touch her buttocks area however was unable to due so due to the tightness of the jeans and a tight belt. E advised Epstein began to masturbate as she rubbed his chest. Epstein moaned as she rubbed his chest. She observed he was continuing to masturbate and The forelling instrument was sworn to or affirmed before me this In day of May, 2006 by Coun Det who is personally known to me. State of Florida Signatur Signature of Police fficer ( .S.S. 117.10) Date: 05/ tint Officer 006 Page Sof 22 EFTA00231877 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 attempted to reach up her tank top and touch her breasts. M, pulled back and Epstein stopped, however he kept masturbating until he climaxed. He cleaned himself with the towel he was previously wearing. was paid $200.00 for the massage and left the area. She met with who was waiting in the kitchen area and left the house. with then explained she never provided another massage for E stein. She did however, go to the house and ) as they took another friend of . . advised she was present when went to work for Epstein. She advised she rode over and sat in the kitchen area with to wait for . advised while they waited for the house chef prepared lunch for them as it was almost lunchtime when they went. When was finished with the massalithey left the area. I asked • if ever told her what would be expected when she provided a massage. II stated yes, told her that a massage would be expected ossibly naked and possibly some touching involved. M has no formal training in providing massages. . spoke about a third and last time she went to Epstein's house. drove another girl„ (sixteen years of age) who is friend, to Epstein's house. . stated knew that . had made money massaging EEtein and wanted to make money herself. took them in the kitchen area of the house and introduced . to . and took . upstairs to the main bedroom. advised she doesn't know what happened as did not speak about what happened in the room. . received . $100.00 from for going with her to Epstein's house and recommending M. On October 6, 2005, at 11:45 am, I met with dob at and explained to her why we there to interview her. She advised she was aware of the ongoing investigation. stated she had previouslywken with sworn taped statement, stated she knew that who told her she was interviewed by detectives. Dunn worked for Jeff Epstein in Palm Beach. advised she originally had been taken to the Epstein house by whom she met when they both attended Royal Palm Beach High School. She began going to the house when she was sixteen years of age and stated she had been there a lot of times to provide massages over the past two years. I asked her if she had formal training in providing massages, which stated she had not. advised she was told what was expected of her by providing massages and she would have to remove clothing but if she felt uncomfortable just to say and Epstein would stop pushing the issue. began providing massages and advised she kept her clothes on. She considered Epstein a pervert and he kept pushing to go further and thither. explained she would keep telling him she had a boyfriend and would not be right to her boyfriend. It wasn't until recently that began removing her clothes and staying in her thong underwear to provide a massage. explained The foregoing instrument was sworn to or affirmed State of Florida before me this 1" day of May, 2006 by Det , who is personally known to me. Si 117.10) Cow m Beach Sign ur csting Officer Date: 05/01/2006 Pagel of 22 EFTA00231878 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 Epstein wanted to be rubbed on his back and recently he began turning over and have her rub his chest as he masturbated. He would try to touch her breasts as she rubbed his chest. stated ". would try to get away with more and more on each massage". statecaitein would try to touch her more and on one occasion he attempted to use a massager/vibrator on her. drove. to the house for the original massage. left her cell phone number and every time E stein would come into town, would call her for an appointment to "work". Each time she went, would meet her at the kitchen door area. She would bring her upstairs and re are the massage table. g advised E stein would ask herstastions about herself. Epstein knew she was and would be attendin . I asked if Epstein knew her real age. stated Epstein did and didn't care. The most recent massage she provided was on October 1, 2005. Darin the massage, she asked Epstein if she could borrow one of his vehicles to visit her family and boyfriend in , Florida. Epstein had told her she could borrow one of his vehicles but later stated he would rent her a car. She continued with the massage as Epstein and . I asked if she was wearing undergarments to which she replied her thong underwear. Once he tried to touch her breasts, she would pull away from him and he would stop. was asked if he ever used a vibrator on her. was aware of the vibrator but advised she never would allow him to on her. She described the vibrator as the large white vibrator with a huge head on the tip of the vibrator. She stated he kept the vibrator in a closet near the massage table. stated that on October 3, 2005, she was contacted by Epstein's assistant, M, who informed her that Ei thhad rented her a new Nissan Sentra and she should come by the house to pick it up. informed she would have the car for a month. stated Epstein knew her car was not working properly and that she had missed appointments in the past because of her car being inoperable. explained the car is currently parked next to the Gym field. I asked her if she ever took any one to the house. explained she took , a friend of hers who attended Royal Palm Beach High School who has relocated to to attend college. I asked if she ever allowed another female in the room. advised no one was brought into the room with her. At the conclusion of the interview, Det and I went to the gym area of and located the Silver Nissan Sentra bearing Florida tag . The vehicle is registered to Dollar Rent a Car out of the Palm Beach International Airport. The vehicle was rented by Janusz Banasiack, later learned to be Epstein's houseman, and paid with Epstein's credit card. On September 11, 2005, dob , was arrested by the Palm Beach Police Department The_foregoine instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det , who is personally known to me. Signature of Police timer ( .S.S. 117.10) State of Florida Coun each Signa r ing Officer Date: 05 /2006 Pagel0of 22 EFTA00231879 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 for misdemeanor possession of marijuana. During the arrest . told the arresting officer that she had information about sexual activity taking place at the residence of Jeffrey Epstein. Additionally, during the ongoing trash pulls from Epstein's residence, discarded papers were found which contained AH's name and cell phone number. On October, 11, 2005, Det and ! met with . and obtained a sworn taped statement. explained she had been going to Epstein's house since 2002, when she was sixteen years of age. Since then she has gone to the house hundreds of times. • stated she became his "number one girl." She explained that on her first visit she was brought to the house by fellow Royal Palm Beach Hi School classmate, • said she was brought through the kitchen area where she met . for the fast time. was led to the master bedroom, Epstein s room. • explained that as she was walking up the stairs she observed several photographs of naked women alon. walls and tables of the house. • further explained that she was . brought into the bedroom, where prepared the room by setting up the massage table and provided the oils for her to rub on Epstein. • explained she remembered the steam room area, which contained two large showers. Epstein entered the room from the steam room area and introduced himself. Epstein lay on the table and told her to get comfortable. • removed her skirt and kept her shirt on. Epstein then instructed her to remove her shirt.. removed her shirt and remembered she was not wearing a bra. l stated she provided the massage wearing only her anties. She continued rubbing his legs, thighs and feet. advised he turned over onto his back. Epstein and be an to masturbate. Epstein ejaculated which meant the massa e was over. At the conclusion of the massage, was paid $200.00. They walked together downstairs where and were waiting. stated received an unknown amount of money for taking her to Epstein. Epstein instructed to leave her cellular telephone number, that he could contact her when he is in town. stated that during her many visits a routine was established between her and Epstein. She would enter the house and get naked in the bedroom. She would then start with a back massage. Epstein would roll on to his back and allow her to massa e his chest area. stated E• stein would then began to masturbate himself and at the same tune would with his fi ers. explained E stein would continue this process until he ejaculated. He would then . • advised that during her frequent visits Epstein asked for her real age, stated she was sixteen. Epstein advised her not to tell an one her real a advised that thin s escalated within the home as Epstein would instruct and pa to . explained the intercourse included that Epstein had at his disposal. Epstein would watch them and masturbate himself . Occasionally, Epstein would then join in The foregoing instrument was sworn to or affirmed before me this I" Jay of May, 2006 by I)et , who is personally known to me. Signs ure o o ice leer . . 117.10) State of Florida Coun of Palm each Date: 05/I 2006 Officer Paget) of 22 EFTA00231880 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 during the to both III and This occurred during the time was sixteen years of age. advised this continued to escalate during two years. The routine became familiar toe. Epstein's assistant would telephone her every time Epstein was in the Town of Palm Beach and would place appointments for her to visit and work for Epstein. Each time something new was introduced, additional monies were produced and offered for to allow the acts to happen. • consented to perform all these acts but was adamant that there was an understanding with Eatein that no vaginal penetration would occur explained that Epstein's penis was deformed. explained that his penis was oval shaped. claimed when Epstein's penis was erect, it was thick toward the bottom but was thin and small toward the head onion. ca dEitein's penis "egg-shaped." • stated Epstein would photo ph and her and proudly display the photographs within the home. stated during one visit to Epstein's house in which she provided a massage to E stein, his female friend, and her would , was also resent. provided the massage in which for Epstein to enjoy. Towards the end of this massa e, E stein abbed and turned her over onto her stomach on the massage table and stated E stein be an to became upset over this. She said her head was , as he continued . She screamed "No!" and Epstein stopped. She told him that she did not want to . Epstein did not ejaculate inside of her and apologized for his actions and subsequently paid her a thousand dollars for that visit. stated she knows he still displays her photographs through out the house. On October 12, 2005, Det and I met with dob , who stated during a sworn taped statement, that nothing happened between her and Epstein. appeared nervous during the interview. I assured her that I have spoken with other people who advised differently. stated on several occasions she rovided a massage to Epstein. She stated she was brought to the Epstein house in March of a classmate at Royal Palm Beach High School, approached her and asked her if she made the arrangements with , Epstein's assistant. , who has no formal training in providing massa es stated she provided a massage, fully clothed for $200.00 . As I sensed hesitancy in her answers, I asked if she had been contacted by anyone from Epstein's organizations or his house. stated she was interviewed already by a private investigator for E stein. He identified himself as "Paul" Sam ttuired about the police investigation, and left his telephone number for additional contact. provided no additional information, as it appeared her responses were almost scripted. The foregoing instrument was sworn to or affirmed before me this day of May, 2006 by Coun Det who is personally known to me. State of Florida Signature o o ice icer . . 117.10) Signature each Date: 05/01 i06 g Officer Page 14f 22 EFTA00231881 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 On November 6, 2005, at air.cimately 3:30 pm, I met with , dob , at the Palm Beach Police Department. was identified as a potential witness/victim through information obtained during the trash pulls. During the sworn taped statement, advised she was at Jeffrey Epstein's house one time, approximately two months ago. She was approachedSsel, , who was dating M ' roommate, for an opportunity to make some quick money. advised she needed to make some quick cash to make the rent that month. She agreed to go to the house. She had been told by that the massage would have to be done in her underwear. She advised drove with her and brought her into the house. They walked into the kitchen area, and took the stairs upstairs. further stated she was brought into a master bedroom area. She advised she recalled seeing portraits of naked women throughout the room. A massage table was already out near the sauna/shower area in the master bedroomaiin entered the room wearing only .a towel and introduced himself as "Jeff." At Epstein's direction, and removed their . clothing down to their panties, Epstein laid on his stomach area and they provided a mass on his legs and feet area I asked if she had any formal massage training and she replied "no." advised she was topless and the panties she wore were the boy shorts lace panties. She and continued the massage until the last ten minutes of the massage, Epstein, told to leave the room, that could finish the massage. got dressed, and left the room as turned over onto his back. Epstein then removed the towel and laid naked . E tt.s rt requested i that rub his chest area. stated , Epstein, began masturbating. stated Epstein pulled down her boy short panties, and he produced a large white vibrator with a large head. She stated it was within his reach in a drawer in his master bathroom. He advised he never with the vibrator. He continued to as he continued to masturbate. stated she was very uncomfortable during the incident but knew it was almost over. Epstein climaxed and started to remove himself from the table. He wiped himself with the towel he had on previously and went into the shower area. got dressed and met with in the kitchen area. Epstein came into the kitchen and provided $200.00 for bringing and paid $200.00 to for providing the massage. was told to leave her telephone number with for future contact. provided her cellular telephone number. was asked if she was recently contacted about this investigation by an one the Epstein organization. She replied she was called but it was for work. She stated she was called by for her to return to "work" for Epstein. stated "work" is the term used by to provide the massages and other things. advised she declined as she was not comfortable in providing that type of "work." On November 7 2005, Det and I met with dob . During a sworn taped statement, stated she met Jeffrey Epstein through when they were still The foregoing instrument was sworn to or affirmed • n darof Mar-2006— Det , who is personally known to me. State of Florida Signature of Police Officer (F.S.S. 117.10) Signatu ing Officer Date: 05/01/2006 Page i3of 22 EFTA00231882 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 sidin att Royal Palm Beach High School. would approach females who wished to work for Epstein. stated she was offered to work for Epstein but declined. explained that "work" means ive massages. She was asked about any formal training in providing massages which she said "no." said she accompanied and other females who were taken to Epstein's house to provide massages. further stated she had been to the house a roximax 4 or 5 times in the year. She accompanied with Pentek, , M, and . Each time the girls were taken over, they were previously told they would have to provide a massage, possibly naked. They were also told that should E stein require them to do anything extra, and they were not comfortable just to tell him and he would stop. stated received $200.00 for each girl she brought over to massage Jeffrey Epstein. When I asked which girl appeared to be the youngest, she replied, M, who was really young, fifteen years old at the most. further stated each time she went to the house, she sat in the kitchen and waited with until the massage was over. She further stated that the cook would make lunch or a snack for them as they waited. I asked her if there was anything that caught her attention within the home. stated there were a lot of naked girls in photographs throughout the house. On November 8, 2005, at approximately 2:00pm , I met with , dob at the Palm Beach Police Department. During a sworn taped statemen stated she had met Epstein approximately two years ago when she was first approached by , a classmate at Royal Palm Beach High School. approached her about working for Epstein and providing a massage to him for $200.00. had made the arrangements however was unable to take her the day the arrangements were made. had take also attended Royal Palm Beach High School and was familiar with Epstein. recalled she was brow t there and entered through the back kitchen door. She had met with an assistant and another assistant brought her upstairs as she observed several photographs of naked females throw out the house. stated Epstein came in the room, wearing only a towel, and laid on the table. stated he pSecl out the oils he wanted her to use and requested she remove her clothing to side the massage. stated that on the first massage she provided she did not remove her clothing. stated she had returned several times after that. Each time she returned it was more than a massage. Epstein would walk into the master bedroom/bathroom area wearing only a towel. He would masturbate as she provided a massage. stated she was unsure if he climaxed as he masturbated under the towel. Additionally, she never looked below his waist. She claimed that Epstein would convince her to remove her clothes. She eventually removed her clothes and stayed in her thong panties. On occasion,' stein would use a mass er/vibrator, which she described as white in color and a large head. Epstein would as he would masturbate. stated she had been to the house The foregoing instrument was sworn to or affirmed before me this day of May; 2006 by Det who is personally known to me. Signature of Police t5fficer (F.S.S. 117.10) State of Florida Conn each Signatu f3 ting Officer Date: 05 i /2006 Page/t/of 22 EFTA00231883 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 numerous times. IIII added she has no formal training in providing a massage. stated she brou t two females during her visits to provide massages. stated she brought a girl named "M" and from Royal Palm Beach High School. stated she received $200.00 for each girl she brought. On November 8, 2005, I met with , W/F, at the Palm Beach Police Department. During a sworn taped statement, stated she had met Jeffrey Epstein approximately one year ago. She was approached by a sulleaknown to her as M. • had asked her if she wanted to make money providing massages to Epstein. had heard that several girls from R22.1 Palm Beach High School were doing this and making money. She agreed and was taken to the house by E. had introduced her to and Epstein and brou t her upstairs to a master bedroom where a male table was prepared and the proper oils were selected. left the room and waited downstairs for her. stated Epstein entered the room wearing a towel and laid on his stomach. She provided a massage wearing only her. thong panties. advised Epstein had masturbated every time she provided a massage. She stated Epstein continued to masturbate until he climaxed. Once that occurred the massage was over. She felt the whole situation was weird but she advised she was $200.00 for providing the massage. She also stated was paid $200.00 by Epstein for bringing stated she had gone a total of 15 times to Epstein's residence to rovide a massage and things had escalated from just providing a masse e. E stein be an touchin and grabbed her closer to him as he masturbated. Epstein also and with his hands as she provided the massage. stated on one occasion, while she was only seventeen years of age, he offered extra monies to have vaginal intercourse. She stated this all occurred on the massage table. stated and began until he reached the point of and climaxed onto the massage table. received $350.00 for her massage. I asked her if she had any formal training in providing massages, stated she did not. continued to state on one other occasion, Epstein introduced his girlfriend into the massage. was brought into room with to provide a massage. Epstein had them as they provided a massage to Epstein. Epstein, watched and masturbated as this occurred. On other occasions, E stein, introduced the large white vibrator/massager in the massage. Epstein on vagina as she provided the massage. On November 14, 2005, Det and I met with , dob During a sworn taped statement she advised she started going to the house approximately one year ago and has.been there approximately five or six times. also stated she was sixteen years old when she first went to Epstein's house. On her first visit she was brought by a fellow student from Royal Palm Beach High School known to her The foregoing instrument was sworn to or affirmed State of Florida before me this 1 day of May, 2006 by Coun of Pal Beach Det , who is personally known to me. Signature of Polic Officer (F.S.S. 117.10). Sign Date: 0 006 ur ng Officer Page ig)f 22 EFTA00231884 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 as stated brought her into the house and she was introduced to then brought her upstairs into a master bathroom, located within the bedroom. stated she met Epstein in the bathroom. He laid on the table and picked the massage oils. She provided the massage as he laid naked on the massage bed. She stated she rubbed his calves and back area. Upon the end of the massage, Epstein removed himself from the massage table and paid her $300.00 for the massage. said each subsequent time she went to the house, she was notified by that Epstein was in town and would like her to "work". stated she returned to the house and was again led upstairs by She provided the massage, until the third time that she went that she removed her clothing. was asked if she ever removed her clothing to i.le ros a massage. stated it was not stated she was notified by that clothed. Epstein wanted her to come to work. She arrived at the house and was led it sirs by . She started providing the massage when Epstein asked her to remove her clothing. removed her pants, shirt and bra. She sta ed in her ad inties and . Epstein turned over onto his back and she stated she knew he was masturbating himself as she providing the massage. ' stated she believed he climaxed based on his breathing. She did not want to view either the climax or the fact that he was masturbating. stated once the breathing relaxed he got up and told her to get dressed. She was paid $300.00 for her services. stated on the last time she went to provide a massage, she was notified by to come to the house and "work". stated she was now dating her current boyfriend and did not feel comfortable going. She recalled it was approximately January 2005. She said she went, already thinking that this would be the last time. She went upstairs and went into the master bathroom. She met with Epstein, who was wearing only a towel, and laid onto the table. stated Epstein caught her looking at the clock on several occasions. Epstein asked her if she was in a hurry. stated her boyfriend was in the car waiting for her. further stated that Epstein got upset as he wasn't enjoying the massage. She told him that she didn't want to continue and she would not be back. Epstein told her to leave as she was ruining his massage. advised she had no formal training in providing any massages. stated although she had a falling out with Epstein, she still received a Christmas bonus from Epstein. Western Union revealed money was sent from Jeffrey Epstein on December 23, 2004. stated she was wired money from Western Union for her Christmas bonus. Suir•m results from received $200.00 from Epstein for her Christmas bonus. On November 15, 2005, Det. and I met with M, dob . During a sworn taped statement, ■ stated she met Jeffrey Epstein over a year ago. She was sixteen years of age and was approached by a fellow Royal Palm Beach High School student, who informed her that she could make $200.00 providing a massage to Epstein. had informed her that she would have to provide this The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det EM, who is personally known to me. State of Florida Count ach Signature/ r g Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/0 06 Pagekof 22 EFTA00231885 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 massage topless. made the arrangements with Epstein and his assistants and took MI to the house. • stated and she entered through a glass door that led into a kitchen. She was taken upstairs by , to a master bedroom. She recalled the master bathroom had a large ink couch, sauna and matching shower. Epstein entered into the room wearing only a towel. • and removed their clothing remaining only in thong underwear. She further stated that Epstein laid on his chest on the table. The oils were selected on which ones to use. Both and . provided the massage on his legs, back and feet. Forty minutes into the massage, Epstein turned over onto his back and re uested wait downstairs in the kitchen area for Epstein instructed . to finish the massage. As ot dressed, startinsiubbing Epstein's chest. left the room, and Epstein began masturbating as . • stated Epstein continued masturbating until he climaxed on the towel he was wearing. When asked if he had removed the towel she stated he turned the towel around 1 that the opening would allow him to expose himself. After he cleaned himself off with the towel he instructed the massage was done and to get dressed and meet with him downstairs. U ot dressed and met with Epstein in the kitchen area. She was paid $200.00 dollars for providing the massage. stated she was aware that also received monies for the same thing. The second time she went to the house she was again approached by advised if she wanted to return to the house turvide another magytge.. agreed and the arrangements were made by for her to return to the house. M stated drove her to the house and knocked on the same glass door which leads to the kitchen area. They were allowed entry into the house one of the staff members. led her upstairs to the master bedroom and master bathroom area. = left . this time to do the massage alone. Epstein entered the room again wearing only a towel. IMI began removing her clothing as she did the last time she was at the house. Epstein instructed her to get naked. He laid on the table onto his stomach as . began masse his legs and back. As . finished with Epstein's back and legs, Epstein then turned over onto his back. M started to rub his chest and he began masturbating. As il .rubbed his chest, Epstein leaned over and produced a massager/vibrator. He turned it on and began rubbing vagina and masturbating himself at the same time. . stated she as this was occurring. She described the vibrator/massager as large grey with a large head. Epstein for approximately two to three minutes with the massager/vibrator. He then removed the and concentrated on masturbating himself. • stated Epstein climaxed onto the towel again and informed her that the massage was done. S Igot dressed and met with who was waiting in the kitchen area. She received $200.00 for the massage. said she never returned to the house and had no desire to return to the house. • was asked if she received any formal massage training. She advised she had no formal training. • was asked if Epstein knew her real age. • stated he knew, as he asked her questions about herself and high school. He was aware she attended, and is still attending Royal Palm Beach High School. The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Coun of Pal • Beach Det who is personally known to me. State of Florida Signature of Poli Office Signature ing Officer (F.S.S. 117.10) Date: 05/ W 006 Paget? f 22 EFTA00231886 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 During the course of the investigation a search warrant was executed at Jeffrey Epstein's home located at 358 El Brillo Way in Palm Beach. While in the home I observed the pink and green couch within the master bedroom area just as the girls previously mentioned. The stairway, which is located from the kitchen area to the master bedroom area, is lined with photos of naked young girls. Additionally, numerous photographs of naked young females, some of which appeared to be the girls I previously interviewed, were on display throughout the house. Also located in the house were various phone message books. The telephone message books have a duplicate copy (Carbon Copy) which, once a phone message is written into the book, the top copy is then torn on the perforated edge and the carbon copy is left in the book. First names of girls, dates and telephone numbers were on the copy of the messages. I recognized various numbers and names of girls that had already been interviewed. The body of the messages were time of the day that they called for confirmation of "work." Other names and telephone numbers were located in which the bod of the messages were, "I have girls for him" or "I have 2 girls for him." These messages were taken by , who signed the bottom of the messages. During the execution of the warrant, I located a Royal Palm Beach High School transcript for in Epstein's bedroom desk. This desk had stationary marked Jeffrey E Epstein. I located a wood colored armoire beside Epstein's bed that contained a bottle of "Joy Jelly," which is used to provide a warm massage. Several massage tables were located throughout the second floor of the residence, including a massage table found in Epstein's bedroom. On the first floor of the residence I found two covert cameras hidden within clocks. One was located in the garage and the other located in the library area on a shelf behind Epstein's desk. A computer was located which was believed to contain the ima es from the covert cameras. The computer's hard drive was reviewed which showed several images of and other witnesses that have been interviewed. AU of these images appeared to come from the camera positioned behind Epstein's desk. On December 13, 2005, Det. and I met with M, dob During a sworn taped statement, stated that when she was sixteen years old she was taken to Epstein's house to provide a massage for money. stated it was before Christmas last year (2004) when an associate, approached her and asked if she needed to make money for Christmas. made arrangements to take to the house and drove to the house to "work." They were encountered by a white female with long blond hair.. was unable to remember the name of the white female with blond hair but knew she was Epstein's assistant. She was led upstairs by the white female who explained that there would be lotions out already and Epstein would choose the lotion he wanted her to use. She was led through a spiral staircase which led to a master bedroom and . bathroom. The massage table was already set up in the bathroom.. described the bathroom as a large spacious bathroom with a steam room and shower beside it. was introduced to Epstein who was on the phone when she entered the room. Epstein was wearing a white towel and laid on his stomach, that may The foregoing instrument was sworn to or affirmed State of Florida before me this 1" day of May, 2006 by Coun of Pa Beach Det who is personally known to me. Signature of Polic Office (F.S.S. 117.10) Sip ng Officer Date: 0 01 i 06 Pagetef 22 EFTA00231887 Probable Cause Affidavit Palm Beach Police Department Agency O121# FLO 500600 massage his feet and calves. II started the massage with the oils Epstein chose and rubbed his feet and calves. Epstein got off the phone and requested she macsage his back as well. • began rubbing his back and got to the small of his back. During the rubbing of his back, Epstein asked her to get comfortable. He requested she remove her pants and shirt. removed her shirt and pulled her pants off. stayed in her bra and thong panties. As she finished massaging the small of Epstein's back he then turned onto his back. Epstein instructed to rub his chest and pinch his nipples. As she , Epstein asked her questions about herself. • remembered telling him she attended Royal Palm Beach High School. Epstein asked her if stated she was shy and didn't like talking about those things. She continued she was sexually active. Before could answer, he also asked what sexualposition does she enjoy. . Epstein reached u and unsn ed her bra from the front. • explained the bra she used had a front snapping device. Epstein and asked her if she like having said "no, I don't like that." Epstein then removed his towel and laid on the bed naked exposing his penis to . He be an touch' his enis and masturbated as he explained Epstein then touched tensed up and stated Epstein was aware that she was uncomfortable. stated that Epstein said to her, "Relax, I'm not going inside." She further explained Epstein commented to her how beautiful and sexy she was. Epstein then moved her thong panties to one side and began said. "He commented how " He then . She tried pulling back to . Epstein and apologized for Dunn this time, he kept his and continued to rub her vagina. stated he - as he was masturbating. said he climaxed onto the towel he had been previously wearing and got up from the table. Epstein told her there was $200.00 dollars for her on the dresser within the master bathroom. Epstein also told her that there was an additional $100.00 that was to be given to for bringing her there to massage him. Epstein told her to leave her telephone number with his assistant as he wanted to see her again. Epstein stated his assistant would contact her to work again soon. I asked her if she ever received any formal massage training to which ■ stated she did not. stated it was the only time she ever went to work for and knew what happened to her was wrong. She further stated that she had never been contacted for any additional work. On January 9, 2006, I located and interviewed another victim, M, dob . was identified as a potential victim/witness from information obtained during trash pulls from Epstein's residence. stated she met Epstein when she was fifteen years of age. She was approached by a friend from Royal Palm Beach High School, to be taken to Jeffrey Epstein's house to work. She was originally told she would be able The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Coun of Palm each Det , who is personally known to me. State of Florida Signature of Polite Offic (F.S.S. 117.10) Signa ure Date: 05/0 )6 g ficer Pageoof 22 EFTA00231888 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 to model linmrie for a wealthy palm Beacher. . was taken to Epstein's house located on El BrilloWay. I= introduced . to JeffrifflEstein. Epstein had his ersonal chef prepare dinner for . and . At the conclusion of dinner, = and Epstein brought . upstairs into a master bedroom area. observed a large massage table with a sheet on it. Epstein entered through a door and exited wearing only a towel. informed . that they were going to provide a massage on Epstein. II asked why were they doing this instead of modeling lingerie. ex lathed to . that this was his routine and to rub his calves and feet. Epstein had told . to get comfortable. removed her pants and blouse. . stated she stayed only in panties as she did not wear a bra that evening. stated while rubbing his calves and feet, Epstein turned over onto his back. Epstein told . to rub his chest and rub his ni les. stated that as she started Epstein began masturbating himself . Epstein and with his fingers. Eastein continued to masturbate himself as he Epstein ejaculated on his towel and paid . $200.00 for the massage. lain told . that if she told anyone what happened at his house that bad things could happen. and were brought home by Epstein's houseman and . was afraid that Epstein knew where she lived stated that several days later she received a telephone call from who coordinated for to return to "work." . returned to the house and was brought to Epstein's bedroom area by who prepared the room for the massage. Epstein entered the room wearing only a towel. Epstein had remove her clothing and provide the massage naked. began rubbing his feet and calves and Epstein turned over onto his back. Epstein downward motion on his penis. Epstein continued . E stein be an to masturbate himself with an upwards and with one hand and masturbate with the other hand. Once Epstein ejaculated onto the towel he was wearing, the massage was over. . was paid $200.00 for the massage. Epstein again told • not to speak of what happened at his house or bad things would happen. . wanted to notify authorities however she was afraid of what would happen to either her or her family. During the course of the investigation, several subjects were identified as a potential witness/victim through information obtained during the trash pulls, physical surveillance and telephone message books retrieved from the search warrant. While conducting research on the subjects, I discovered that the females were age eighteen or older. Interviews were conducted on the consenting adults whose statements provided the same massage routine when they went to "work" for Epstein. The females would be notified by , and made appointments for the females to "work" for Epstein. The females would come to Epstein's house and were led upstairs, through a stairwell from the kitchen area, by to Epstein's bedroom. Epstein would then enter the room wearing only a towel, and ask them to et comfortable. The females would then provide the massage naked as Epstein would either and/or utilize the massager/vibrator on The foregoing instrument was sworn to or affirmed State of Florida before me this I" day of May, 2006 by Det , who is personally known to me. Signature of Polic Officer (F.S.S. 117.10) county alm each Signatur r yQ. Officer Date: 05/01 Pagyof 22 EFTA00231889 Probable Cause Affidavit Palm Beach Police Department Agency ORD FLO 500600 . He would masturbate during the massage and upon his climaxing, the massage would end. The girls were then paid two or three hundred dollars for the massage. On November 21, 2005 I interviewed Jose Alessi, a former houseman for Jeffrey Epstein. Alessi stated he was employed for eleven years with Mr. Epstein, from approximately 1993 through 2004. Alessi stated he was the house manager, driver and house maintenance person. It was his responsibility to prepare the house for Epstein s arrival. When asked about cooks or assistants, Alessi stated they traveled with Epstein on his private plane. I asked Mr. Alessi about the massages that have occurred at Epstein's home. Alessi stated Epstein receives three massages a day. Each masseuse that visited the house was different. Alessi stated that towards the end of his employment, the masseuses were younger and younger. When asked how young, Mr. Alessi stated they appeared to be sixteen or seventeen years of age at the most. The massages would occur in Epstein's bedroom or bathroom. He knew this because he often set up the massage tables. I asked if there were things going on other than a massage. Alessi stated that there were times towards the end of his employment that he would have to wash off a massager/vibrator and a long rubber penis, which were in the sink after the massage. Additionally, he stated the bed would almost always have to be made after the massage. On January 4, 2006 I interviewed another former houseman, Mr Alfredo Rodriguez. During a sworn taped statement, Mr. Rodriguez stated he was employed by Jeffrey Epstein for approximately six months, from November 2004 through May of 2005. His responsibilities as house manager included being the butler, chauffeur, chef, houseman, run errands for Epstein and provide for Epstein's guests. I asked Rodriguez about masseuses coming to the house. Rodriguez stated Epstein would have two massages a day. Epstein would have one massage in the morning and one massage in the afternoon everyday he was in residence. Rodriguez stated he would be informed to expect someone and make them comfortable until either or Epstein would meet with them. Rodriguez stated once the masseuses would arrive, he would allow them en into the kitchen area and offer them something to drink or eat. They would then be encountered by either or Epstein. They would be taken upstairs to provide the massage. I asked Rodriguez if any of the masseuses appeared young in age. Rodriguez stated the girls that would come appeared to be too young to be masseuses. He stated one time under Epstein's direction, he delivered a dozen roses to Royal Palm Beach High School for one of the girls that came to provide a massage. He knew the girls were still in high school and were of high school age. I asked Rodriguez about the massages. He felt there was a lot more going on than just massages. He would often clean Mr. Epstein's bedroom after the alleged massages and would discover massagers/vibrators and sex toys scattered on the floor. He also said he would wipe down the vibrators and sex toys and put them away in an armoire. He described the armoire as a small wood armoire which was on the wall close to Epstein's The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det , who is personally known to me. Signature of Polic Office (F.S.S. 117.10) State of Florida Page2lof 22 EFTA00231890 Signature of Poli e Offic (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency ORIN FL0 500600 bed. On one occasion Eztein ordered Rodriguez to go to the Dollar rent a car and rent a car for the same girl he brought the roses to, that she could drive her self to Epstein's house without incident. Rodriguez said the girl always needed rides to and from the house. Rodriguez produced a green folder which contained documents, and a note with Mr. Epstein's stationary with direction to deliver a bucket of roses to Royal Palm Beach High School after high school drama performance. Also in that same note was direction to rent a car for and direction to extend the rental contract. During the course of the investigation, subpoenas were obtained for cell hone and home phone records from several victims and witnesses along with the cell phone records of . An anal sis of these records was conducted which found numerous telephone calls were made between and the victims. These records indicate the dates the calls were made are consistent with the dates and times they victims/witnesses stated they were contacted. Specificall , The phone records showed called during the exact times and dates when victim advised the incident occurred. also coordinated the encounters with M, and during the time frame the girls stated they occurred. Pursuant to a lawful subpoena I obtained Epstein's private plane records for 2005 from Jet Aviation. The plane records show arrival and departure of Epstein's lane at Palm Beach International airport. These records were compared to the cell phone records of This' comparison found that all the phone calls made to and the victims were made in the days just prior to their arrival or during the time Epstein was in Palm Beach. Jeffrey E stein, who at the time of these incidents was fifty one years of age, did have vaginal intercourse either or digitally with U . and , who were minors at the time this occurred, and who at the time of the incident was fifty two ears of age, did use a vibrator on the external vaginal area of M, a fourteen year old minor. Therefore, as coordinated and aided in the recruitment of minors to frequent Epstein's house so that sexual services were provided to Epstein, scheduled the said minors to return to the work for Epstein, secured their appointments for the purpose of sexual activity and lewd and lascivious acts and arranged the bedroom for said minors, there is sufficient probable cause to charge with four counts of Principal in the 1' degree Unlawful Sexual Activity with a Minor, in violation of Florida State Statute 794.05(1) , a second degree felony and there is sufficient probable cause to charge her with Lewd and Lascivious Molestation, in violation of Florida State Statute 800.04 (5), a second degree felony. The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det who is personally known to me. State of Florida Coun Signature/ Date: 05/0 ng Officer Page2zof 22 EFTA00231891 REQUEST FOR WARRANT 'DEFENDANT: DATE OF BIRTH HABITUAL OFFENDER: YES NO A/K/A VICTIM RELATED / ACQUAINTED WITH DEFENDANT? YES AGENCY CASE NUMBER: LEAD OFFICER: 05-368 (3) )OC NO AGENCY: PALM BEACH POLICE DEPARTMENT PHONE NUMBER: CURRENT SHIFT HOURS: 8 am TO 5 vm DAYS OFF: LEAVE / SHIFT CHANGE INFO: WAS ARREST MADE FOR, OR IN CONJUNCTION WITH ANOTHER AGENCY. IF SO, WHAT AGENCY?: SENTENCING RECOMMENDATIONS: CONTACT DETECTIVE ADDITIONAL COMMENTS: ?ICING DOCUMENTS ATTACHED: ARREST FORM P.C. AFFIDAVIT (2 COPIES) y WITNESS / EVIDENCE LIST Pee4 cCuSt-1 41.6- DADA/Lmicu￾SWORN STATEMENT OF MATERIAL WITNESS(ES) - )(# OFFENSE REPORT (2 COPIES) ACCIDENT REPORTS (ALL) Gwen) WITNESS STATEMENTS (ALL) epagagatiete terwriok, / REQUEST FOR CONVICTION LETTERS paogignagIPTfritiaSty 51te0 _12.- ASA ei-to aver￾VEHICLE TOW RECEIPT OTHER ATTACHMENTS INCLUDE: JR INITIAL FOR COMPLETENESS: OPTICElt DELIVERED BY: DETBCITVB RECEIVED RECEIVED, STATMEAITPaS OFFICE ON: NTAK 7915 IDA 050106 DATE EFTA00231892 0BTS Number I I I i i _l I I I_ ARREST / NOTICE TO APPEAR I An 3 Reouest for Warrant L Juvenile %fermi Report 2 N T A 4 Request for Cape ,;_; en le .-----. PFLOI5i0a0t610e0 Myra ORI Wince/ Away Nan PALM BEACH POLICE DEPARTMENT Agency ANNA Number IN TA's Only) 7 i € kl i uL i i 1 i 1(1 I I) p Nur i Type "O 1. Felony OS Madafalanar 05 Cialinance per mew/ O 2 Traffic Faker 04. WOO heidenieenta OB. Caw r weacon Segel Enter Tpo rungs Clearance i i g LOCUOn < 01 Meat(Including Name of Business) ____ _ Location ol Offenses (Boren Name. AOSHM3) macaw i i Dem ol Mew Mt Tlme of An•SI &acing Da Mote. Vas Jul Dale Jai lime Locetion or Venice Name ant Fat WOG) Race W • Wm I . Amenca 9 • also 0 • Onentai i￾Scars. Marks. Tattoos. U Phone ( ) Moho, Influence bloomer 0 0 Ace HMS I. Clay COUIlly 3. Fledge 2. 4. Our of Stile yL ■ Femme ( ) Address Soon,* Phase ( ) am I act. s ace v Deis of Sarin 2 Al Large 4 a 0 co-o•lenClan: Name (Liel. OM WS) Rica Sex Dal of Ms Lji.Arreelad 02 Al Urge 4. hasdernsenor S. Amalie Name (Lam) IFImf) (Crude) nnisseoePIXice ❑ ii iniCusiodian wl ( I Apt. Nucor) (01y) (Sall Business Phone im Acidness (Same. (Zip) ( I z iv TOT JAC Dew Time = -> The atom skins was proaded by 0 dalandala aro/ or O cialenclanch pawls. The MSS and? or panne was Nan - lamp to Juvenal. Cowl Glides Office (Flow 355-2526) Mabee' or WY Menge 01/MMus ise by (Name) C No:Beason) School Mended 'Glade I Ally Crne? ol Prawn O les 0 No — Valued Property g slOsalpaon Precimw S R. Smug* K Disperse/ M. Itinufecturei D. Delver Diembuie Predate/ P. Possess T. 'Dyne E. Use ZOnve Drug Two N. N/A Enarbilwate H. Halminagen P. Pearnlie/ %Litwin C. Cocaine M. Merauens . r. A. Oungthelarfers EJ4eroin 0. °Pitman IRWIINI 0.0‘,0011 ' , OMW DamOWN E p a ll 0 NASEE040TEW , Li I I • 1 1 1 1(1 - II) i' l 17.1 :. %MS""4°. i Type Amount / Unit a W ON Orug twenty Drug arraNrCeolu Mantra Bond ... O: I CHARGE I Osage Oseonceon run DOtaelbe 61 15N Same VicRobon Hunt* i i In 1 I L 1 ( 1 i i i ) ),,,A r Cr ORD a 8‘ .7 Drug AOMY Drug Type Amours/ Una Odense 1 Warrant /Cagan Holotor 80m1 . lamp Deacnodon CASA% DOmeilt Violence 0Y ON SUMO Mast:fon Monter I I I•1 1 1 1 1(1 1 1 I L Ye] anon of ORD • 5 Drug Actorty Diva Type Amount/ Unit rinse II WW1'S) Cams Number Bond Ill Charge Cilecnolion Counts Damage _Q Wang/ TQ_N Statute Miamian Numb, I 1 L I_ I I I III I I I ) Violation of ORO . 5 Drug Mosey Peg Type AmOLMI , Unil <Menne Warrant / Capias Number Bond O Insane:eon No. 1 NanOolory /*mance In Court A (COO. ROOM NurneOf. A0itss( 1 O Instruakwi ti,. 2 You need not appear in Coon Ds must comply with newtons on Reverse Sae. mccLOCat:as Coo n D and Trite Div YOU Tea__ _A.a. --Pal PMIGAEUT0 APPEAR AT THE TIME AND PLACE DESIGNATED TO ANSWER THE OFFENSE CHARGED OR TO PAY THE FINE SUBSCRIBED I UNDERSTAND THAT SHOULD i WILLFULLY FAIL TO APPEAR BEFORE THE COURT AS REQUIRED BY THIS NOTICE TO APPEAR. THAT I MAY BE HELD IN CONTEmPT OF COURT MD A WARRANT FOR MY ARREST SHALL BE ISSUED. 2 sow., a Ogiendlint (Or Juytwil• and Patera /C4Saladial Dais Signed a NOLO !or abet Agency r ‘: anperOisS O Reseed Arrest D Scala O omit %palm of Meabrg Ole* x Name Venhcaoon (Printed by Arreswe) ..(PAINT) Transponing Officer f.O. a AOODOT PAGE fa meow Deputy I.D. I Pousn Will*es hate Illubled free with an X. Or DSTRIBLMION WHITE — COURT COPY GREEN — STATE ATTORNEY YELLOW — AGENCY Pita( — JAk. GOLD DEFENDANT (N.T.A's ONLY) EFTA00231893 (JBTS Number 1 I _t_ i i I 1 _1 I Juvenile ARREST/ NOTICE TO APPEAR i wrest 3 Request lor einem Referral Report 2 NIA 4 Repast hv Caha n Jeanie F-- LU > 07- Agency OPII Numb* not S j 0 _i_03_ 6 1 0 . 0 Agenag Num re:, Aston Number 04.T.4.1 only) 1 PALM BEACH POLICE DEPARTMENT L 7 1EN t U i _I i i i nt I) e. : ;O I. Few O 3. lAsiemeence O S. Ordnance IA Weapon Soled -VasT MOM matey O 2 Berne Felony 0 4. TreatMademenor Ott Oar Ear lype Mush IA Locum of Meet Draludie Name a euelnell) ---- [Lambe al Olherates (Business None. Mains) ir awn I to I Cote oe Arrest i _i I I I _ Time ol Mnl a _I_ I Scone Date Woking Dna Jet Data — MI Time _ Location of Venda DEFENDANT Name (Last ANL Waft) Alias (Name. DOB. Sot Sec. I. EM ) W - a Mule I , Menem hem 0 • BIM 0 - ChentaiMaten I Sex 04N aSeth I a I A_ a Heat Weil EY, Cdr I Hew Color Complecon Bye Mars. Mania. Tattoos. Un tie INIVSICM Fatalism llocaben. Type. Deepen) LIMN See Reece loonetinntl:ence 6 8 u8k. Drutaankehe 0 0 0 Leal Actress (Sireet..4O. Numbs) ICC (Patel Oa Phone ) ( Raid* ce Tape: i. Cry Floras 2 Covey 34 .. Out of State Permanent Mess (Street. Age. Number) (Oti) (Stale 120) Moe ( ) Address Source %Mantes Address Mame. Street) mon (Stale) (Z0) Phone ( ) Occupation Dt Number. Sus i - • . Soc. Sec Menet 045 Number _IMP)? or Binh (Coy. State) Oraarahop 8 u: , . Co-Delindent Name (Lest First 106:10 Race Sex Dm aBM LJ 9; . eakreL411 3. Felony,,.... S. Nene g CoDelenCen: Name (Lest. Fat. Mee) Race Sex A Date or Elm dLtranter;e 4 3 Feiony 4 akedeamenOr S JJVatlie g Nene (Len (Fat) Paddle) RtCustoclan Restaarm Phone w MOWS (Slue Apt IMMO (CM) ISMS) (Z9) RuSuess Phone I TOT JAC Otte R The Am attires ins proaclicl De OderanclaN Ara / or O cietencianes wear The Odd anti( Or Career was WO m keep Me Jayne Court Carts 011ie (More 355.2328) informed of any °nape of lanes. 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OlartujunrDeriv S. romeZil Charge Deception Counts Itolatestic MiraN Statue VelelOn Number 1 I IA t I 1 111 I I I .4 Inotabon or ORD ft 1 0 Dm Met, Drug Typo Amount/ Urn Offense 0 --• Warrant / Cans Neaten Bond r CHARGE I Chap Demean Ccum (Do mestic lAoirra 0 Y ON Stelae Poison Mater ( I I'll l 1 3 1(1 A l I lhOlabon a OAD e )I Drug ACteete Drug Tape [Amount / lira Oriente It Warmer Cape Mate Bora IHARGE I Cate Deencen Came Iterneett ElaTON Slane %Neon Note I I 1.1 1 1 1 1(1 I l l Violation en ORO I ) DrUg Name, Drug Type Amount / Urn Offense e Vaerraol (Cat Worts Borg w 0 Chore Demotion Counts bp:leac i YON Statute Yemen Mater L Voltam -I I Li i t 1(1 i t i a ORD 1 1 1 PIA Mae Drug Type Arratuni / UM °sense e Weeny Capes Number Bond NOTICE TO APPEAR O InNruCeOn NO. I Maredelory Appearance in Can O No. 2 Location (Court Room Nonce ACOness Li raccoon You need rot spew in Coun out must comply em Asuman. en Beene See Can Dee end Tyne month Oay Wer Tete A.M. _-Pm TAGREE TO APPEAFTATTRETIME MRIPILWEDESIGNATED APPEAR BEFORE THE COURT AS REQUIRED TO ANSWER THE OFFENSE CHARGED OR TO PAY THE FINE SUBSCRIBED I UNDERSTAND THAT SHOuLD i WiLLFuLLY FAL TO SY THIS NOTICE TO APPEAR. DIATOM'? BE HELD IN CoarEWSIOF COURT AND A WARRANT FOR MY ARREST SHALL BE ISSUED. Sateen of Deferdent (or Arent* and Parent f Cusleclan) Date Sped HOW lot other Agency ' me: Salaam of Meriting Officer X Name VenAcalca (Prole by Mama 2 (PRINT' a Anglian O Resisted Arrest o suicidal o °.r: Name Of Amateng ONCer (NMI I D. I .PAGE < IMO Oki* 1.0. 1 Pouch icecap:nap Pacer ; D e 4044c), Moms nem i subject signed wen on IC. OP DISTRIBUTION: WHITE — COURT COPY GREEN — STATE ATTORNEY YELLOW — AGENCY POW — JAIL GOLD • DEFENDANT (N.T.AltalLY) EFTA00231894 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 Police Case#: 05-368 (3) Defendant: Race/Sex: White Female DOB: Charges: Lewd and Lascivious Act on a child under 16 years of age 800.04(6)(2b) From March 15, 2005, through February 2006 the Palm Beach Police Department conducted a sexual battery investigation involving Jeffrey Epstein, and . Sworn taped statements were taken from five victims and seventeen witnesses concerning massages and unlawful sexual activity that took place at the residence of Jeffrey E stein, 358 El Brillo Way, Palm Beach. Several of the victims were recruited by and brought to the residence by to perform massages for Epstein for which received monetary compensation. During the visit they would be introduced to Epstein's assistant, who in turn would record their telephone numbers and name. The victims would be brought to Epstein's bedroom to ' provide the massage. Epstein would enter the room and order the victims to remove their clothing to provide the massage. As the victims complied and provided the massages, E stein would On occasion, Epstein would introduce a massager/vibrator and as they provided the massage. On three separate occasions, Epstein had intercourse and inserted his penis/fingers in the victims vaginas. At the conclusion of the massages the victims were paid sums of money ranging from $200 - $1,000. The facts, as reported, are as follows: On 03/15/2005, A fourteen year old white female, hereinafter referred to as ".," dob and her family reported unlawful sexual activity which occurred at a residence within the Town of Palm Beach. reported that a subject known to her as "Jeff' had touched her vaginal area with a vibrator/massager while within his residence. "Jeff' was later identified as Jeffrey Epstein through a photo line up. During a sworn taped interview, stated that dob a cousin of boyfriend and classmate at Ro al Palm Beach High School, worked for a wealthy man and did sexual favors for him. She also admitted that had offered her an opportunity to make mone During the beginning of the month of February 2005 explained that she was first approached by to o with her to Epstein's house. II stated that alon with a Hispanic female, later identified at , ick her up at her father's house on a Sunday. was not sure of the exact dates but knew it was a Sunday. told her father that they were going shoplinit in reality drove them to Palm Beach. During the drive a conversation occurred between and whereas reportedly told II that ifJeff asked her age, The foregoing instrument was sworn to or affirmed -before-me-this-ltday-of-Mayr2006—by Det , who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida Signatu ng Officer Date: 05/01/2006 Pagel of 22 EFTA00231895 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 she should say she was eighteen. It was later confirmed by the M's father that picked his daughter up on February 6, 2005. According to M father, drove a pick up truck. . described Epstein's house as a two-story pink house with a Cadillac Escalade parked in the driveway. She recalled that Jeffs house was on a dead end street. Upon arriving at the house . stated that they walked up a drivewaiy, mast what appeared to be a small guard/security room. A male approaching them asking what they wanted. stated they were there to see Epstein. The male allowed them to continue walking up to the house. stated the man told them that Epstein was not there but was expected back. He allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside. Shortl thereafter, Epstein and his assistant, described as white female with blond hair and later identified as , entered the kitchen. Epstein introduced himself to M. M described Epstein as being approximately forty-five years old, having a long face and bushy eyebrows, with graying hair. and Epstein left the kitchen leaving M alone in the kitchen. They returned a short time later. They all spoke briefly in the kitchen. M was instructed to follow upstairs. • recalled walking up a flight of stairs, lined with photographs, to a room that had a massage table in it. Upon entering the room there was a largilxahroom to the right and a hot pink and green soft in the room. There was a door on each side of the sofa.. recalled there SI a mural of a naked woman in the room, as well as several photographs of naked women on a shelf. = told the victim that Epstein would be up in a second. Epstein entered the room wearing only a towel and told IMI to take off her clothes. IMI stated Epstein was stem when he told her to take off her clothes. M said she did not know what to do as she was the only one there in the room I she took off her shirt leaving her bra on: Epstein had removed his towel and told the M to take off everything. I stated Epstein was nude when he took his towel off, placing it on the floor as he laid down on the table. stated she then removed her pants leaving her thonkpanties on. Epstein then instructed her to give him a massage pointin to a specific lotion for her to use. As . began to give E stein the massage, he told her to get on his back. stated she straddled herself on Epstein's back whereby Msaid Epstein was specific in his instruction to her on how to massage him, telling her to go clockwise or counter clockwise. Epstein then turned over and instructed M to massage his chest. M was now standing on the ground and resumed massaging Epstein's chest area. M stated Epstein held onto,the small of her back as she massaged his chest and shoulder area. Epstein then turned to his side and started to rub his penis in an up and down motion. Epstein then pulled out a purple vibrator and began to The foregoing instrument was sworn to or affirmed baoren this 1" d2y of M2y, 2006 by Det , who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida Date: 05/01/2006 PageRof 22 EFTA00231896 Probable Cause Affidavit Palm Beach Police Department Agency ORD FLO 500600 stated there was no penetration as the recalled Epstein ejaculating because he had to use the towel to wipe himself as he of off the table. Epstein then left the room and . got dressed. She went back downstairs where she met with . said she was paid three hundred dollars in cash from Epstein. Before she left, Epstein asked to leave her phone number. As M, and were leaving the house, told • she received two hundred dollars that day for bringing her. During the course of the investigation, parental consent was granted for to assist with the ation. At our direction direction conducted controlled taped phone calls to cellular telephone . . spoke with in an attemttsarrange another meeting with Epstein. Masked , what did she need to do to make more money. stated, "the more you do, the more you get paid." had sub uently called back . and left a voice mail message for her indicating that she had set up an a ointment for E to go to Epstein's house at 11:00 am on April 5, 2005. This message was recorded from voice mail. Based on the above, trash pulls were established at Epstein's residence with Supervisor Tony Higgins of the Sanitation Bureau of the Town of Palm Beach. The trash pull from April 5, 2005 revealed a tele hone message for Epstein which stated and name at 11:00 am. This was the time frame had informed to be ready to go work at Epstein's house. On October 3, 2005, Sgt and 1 went to residence and viewed her vehicle parked in the driveway, a red Dodge Neon. Sgt. and I knocked on the door and met with was told that we were investigating a claim involving Jeffrey Epstein of El Brillo Way, in Palm Beach was asked if she would accompany us back to the police station for further questioning. She was also told that at the conclusion of the interview she would be returned home. voluntarily came with us back to the Palm Beach Police Department. Upon our arrival at the police station, was brought to the interview room in the Detective Bureau where I obtained a taped, sworn statement. I began the interview by asking how she became acquainted with Epstein. stated that approximately two years ago, just after she turned 17 years of age, she was approached by a friend named at the Canopy Beach Resort in Rivera Beach. was asked if she wanted to make money. She was told she would have to provide a massage and should make $200.00. thought about the offer and agreed to meet with Jeffrey. The foregoing instrument was sworn to or affirmed State of Florida --before me this aday-of-May, 2006-by County_ Det , who is personally known to me. Signature of Police Officer (F.S.S. 117.10) Sign Date: 05/01/2006 icer Page3 of 22 EFTA00231897 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 (Unknown last name) and (Unknown last name) picked up and she was taken to Epstein's house. Upon her arrival to the house she was introduced to Epstein in the kitchen of the house. She was also introduced to a white female known to her as She was led upstairs to the main bedroom known to her as Jeff Epstein's bedroom. arranged the massage table and covered the table with a sheet. She brou t out the massage oils and laid them next to the massage bed. , then left the room and informed Jeff would be in, in a minute. Jeff entered the bedroom wearing only a towel. He removed the towel and laid nude on the massage table. He laid on the table onto his stomach and picked a massage oil for to rub on him. Durin stated "He tried to touch me and I stopped him." I asked how he tried to touch her. stated that Epstein and she felt uncomfortable. told Epstein, I'll massage you but I don't want to be touched. stated she performed the massage naked. At the conclusion of the massage, Epstein paid $200. After the massage Epstein stated to that he understood she was not comfortable, but he would pay her if she brought over some girls. He told her the younger the better. stated she once tried to bring a 23 year old female and Epstein stated that the female was too old. stated that in total she only remembers six girls that she brou ht stein each time she was paid $200. stated she had brought the followin "rls: , ( al 6 year old female), (a 16 year old female) and said that at the time she brought these irls to Epstein's house they were all14 through 16 years of age. I asked which one was the youngest. advised was the youngest as she was fourteen when the massage occurred. stated every girl she brought knew what to expect when .hey arrived. They were told they would provide a massage, possibly naked, and allow some touching. I asked her if E was aware. She stated every girl she brought knew what to expect. She explained she knew that wanted to make money. She approached and explained about going to work for Jeff, agreed and arrangements were made to brin her to Epstein's house on a weekend. stated that she and (Later identified as ) picked up at her house. stated that at that time she was driving a red pickup truck. They traveled tastein's house and entered through the kitchen door. They met with the house chef and Epstein's assistant . was introduced to Epstein while th were in the kitchen area. led upstairs and Epstein went upstairs. When the massage was over returned to the kitchen area. stated she was paid $200.00 for bringing to Epstein's house. stated told her she was paid $300.00 for the massage. stated that was the last person she brought to Epstein's house. She had changed her cellular number to avoid being contacted by . She continued stating that she had no direct contact with Epstein The foregoing instrument was sworn to or affirmed before-me-this ln day-of-Mayi-2006 -by Det who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida County of Pal i Beach Signature Date: 05/01/2006 Officer Pagel( of 22 EFTA00231898 Probable Cause Affidavit Palm Beach Police Department Agency ORIn FLO 500600 when he was going to travel to Palm Beach. said when Epstein announces to his assistant, that he is traveling to Palm Beach, would then contact to arrange girls to "work" for Epstein. stated that once herasents discovered that she was visiting Epstein, ..lisapproved ti of the encounters with him and she stopped. further stated that still tries to call house and leaves messages. Sgt entered the room and explained to that based on her own statements, she had implicated herself by bringing underage girls to Epstein's house. provided cellular telephone numbers for the girls she had mentioned previously. Additionally, she also provided possible addresses and areas in which they lived. As was being taken home in the vehicle, a tape recorder was laced within the vehicle to record any conversations within the vehicle. During the drive back to her home, made the comment " I'm like a Heidi Fleiss." (Hollywood Madam who sent girls to clients for sexual favors in California). was dropped off at her house without incident. On October 3, 2005, Sgt and I went to speak with , a sixteen year-old female who was brought to Epstein's residence by . We met with mother at their front door. We exaned the ongoing investigation and asked to speak with, as we had information that she had "worked" for M. MrstS introduced us to her husband and allowed us entry into the home. We sat in the dining room and met with,, Date of Birth . As she was under the age of eighteen, was advised we would be speaking with her. She expressed if her daughter had information, she wanted to assist. We interviewed,, who denied havin any inappropriate encounters with Jeff (Epstein). She stated she had gone to Jeff's house with approximately eight months ago and sat in the kitchen with the house chef, but nothing happened. As the parents were present during the interview, we felt that, was withholding information from us. She made several comments as to putting the entire incident behind her. I left my telephone number and advised should she wish to speak with me again to telephone me. Sgt and I thanked for her time and left the area. She stated she would ask, again after we left as to what happened at Epstein's house. I informed her that, had my telephone number and hopefully she would call. On October 4, 2005, Det and I drove to the , dob . During a sworn taped statement, when she was seventeen years old, she was taken to a house by because they both attend Royal Palm Beach High School. home and met with and stateslarproximately a year ago stated she knows She was told she could make money working The foregoing instrument was sworn to or affirmed — --before me this 1" day of May, 2006 by Det , who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida Beach Signatur Date: 05/ /2006 Officer PageCof 22 EFTA00231899 Probable Cause Affidavit Palm Beach Police Department Agency OFtl# FLO 500600 for Jeff. She was told she would have to rovide a massage to stated upon her arrival to the house she was brought to the kitchen area by . They met with the house chef who was already in the kitchen area. stated would wait for her in the kitchen. was introduced to , Jeff's assistant, who brought her upstairs to the master bedroom. prepared the room and massage table for a massage. Epstein entered the room wearing only a towel and she provided a massage. stated she ke her clothes on during the massage. She advised sometime during the massage, Epstein and pulled her close to him. said she was uncomfortableithie incident involving Jeff. At the conclusion of the massage, she was paid $200.00 for the massage. I asked if she has any formal training in masa, which she r lied no. I asked her if received any monies for taking her to perform the massage. stated had received money for taking her there but was unsure in the amount. stated she returned to Epstein's house on another occasion with and another irl stated she waited in the kitchen with , while was taken upstairs by stated she only did the massage once as she was uncomfortable with the whole experience. At the conclusion of the interview, the tape was stopped. I was informed that had attempted to reach via cell phone. A voice mail messa e on October 4, 2005 at 10:59 am, revealed a female voice who identified herself as who requested to call her back reference the police questionin provided the incoming telephone number as stated she inadvertently told about the police investi ation because had called her to tell her about how she just received a rental car from Jeff Epsteih. had called her to tell her that she was given a rental car, a 2005 Silver Nissan Sentra, to utilize to visit faniii.nd visit Epstein. be asking questions. stated asked her what was oin on at the house that the police would then called and and asked what was going on reference the ongoing police investigation. Accordin to has since then been trying to contact her to ask about the lice questions. I instructed not to contact and do not provide any more information to as she would notify Epstein and what.was transpiring. On October4, 2005, I made telephone contact with I who had left several messages for me to contact her. During the message, she advised she was not completely truthful when we met in person but would like to speak with me to advise what had happened. She further advised she did not want to speak of this incident in front of her mother. At approximately 3:48 pm I made telephone contact with,. During a taped recorded statement, stated the following: approximately a year ago, when she was sixteen years of age, took her to Epstein's house twice. She knows because they both attend Royal Pal Beach High School. The first time she went, drove to the house. They entered through the kitchen area where she was The foregoing instrument was sworn to or affirmed -me-this-1" day of-May, 2006 by County of Palm Beach Det who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida Signatur g Officer Date: 05/01/2006 Page t0of 22 EFTA00231900 Probable Cause Affidavit Palm Beach Police Department Agency ORIH FLO 500600 introduced to and Epstein. She was taken upstairs to a bedroom by who set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for to rub on him. At one point during the massage he tried to remove her shirt, at which point she became very upset and discontinued the massage. Both and E stein had a verbal disagreement, at which time she left without being paid. She got with who was sittin in the kitchen and told her "let's go." I advised she received no money for that day. also said that had told her if she was uncomfortable with what was going on, to let him know and he'll stop. She knew that the more you do the more you get paid. I advised that several weeks later she agreed to be taken a second time by . Once they arrived at the residence, sat in the kitchen and took her upstairs to the master bedroom again. set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for, to rub on him. At one point during the massage he tried to touch her buttocks. As, was wearing tight jeans and had a tight belt on Epstein was unable to touch her buttocks. Epstein then rolled onto his back during the massage and then attempted to touch her breasts. then became sset again and told Epstein she didn't want to be touched. I discontinued the massage and was paid $200.00. then went downstairs where was waiting for her. She told she wanted to leave. I said she never returned to the house. stated she is aware that her friend, was also at the house and had a problem with Epstein. I later researched dob , and met with her at her residence. During a sworn taped statement, stated the following: on or about November 2004, she was approached'at Royal Palm 3each High School by , a fellow student. asked if she wanted to make money. She agreed and was told she would provide a massage to wealthy man in Palm Beach. picked her up and drove her to a house in Palm Beach. She was brow :ht into the kitchen area of the house. She further stated that fellow Royal Palm Beach High School students and MIM) came with them. They were brought into the kitchen where she was introduced to Epstein and other females. stated she was introduced to a female helper of Epstein, the female was described as white female (unknown name ), with blond hair. She stated that the assistant was familiar with . The assistant brought her upstairs into a master bedroom area. The assistant set up the massage table and put out lotions to be used. She told Epstein would be available in a minute. Epstein entered the room wearing only a towel. Epstein removed his towel, and laid naked on the massage table and picked a lotion to rub on his thighs and back. further stated during the massage, Epstein asked her to remove her clothes. She complied and removed her pants and blouse. didn't remember if she bad removed her bra but feels that she did. was certain that she stayed in her thong underwear. continued the massage and at one point she climbed onto the massage The foregoing instrument was sworn to or affirmed State of Florida before me this 1" dafUf May, 2006 by Co Det , who is personally known to me. Signatur Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page" of 22 EFTA00231901 Signature of Police Officer (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 table, straddling Epstein to massage his back. While doing this was instructed to return to the ground at which time Epstein turned to have his chest rubbed. advised she was sure he was masturbating based on his hand movements going up and down on his penis area. did not want to look at his penis area because she was uncomfortable. Epstein removed a lar e white vibrator which was next to the massy e table and turned it on. stated Epstein began . Shortly thereafter, Epstein ejaculated and removed himself from the table. He walked over to where the shower was and opened the glass door. She waited as he was taking a shower in her direct view. When I asked how old she was when this occurred, she stated she had just turned seventeen. At the conclusion of the shower, was paid either S350.00 or $400.00. She stated she wasn't sure, but knows it was close to $400.00. stated she never returned to provide a massage for Epstein. At approximately 2:10 pm, Det and I met with • dob at her residence. As • was only seventeen years of age, I had notified her mother, that she would be interviewed reference an ongoing investigation in Palm Beach. I assured her that her daughter was not a suspect. I explained the possibility of her being either a witness or victim. advised she wanted • to cooperate and consented to the interview. During a sworn taped statement, stated the following: at the age of sixteen, during the month of September 21*.04 she was approached by for a chance to make money. was friends with associates of and knew the same people. had been previously told by her friends from Royal Palm 13each High School, what did for Epstein. called a person known to as and scheduled the appointment picked up and drove her to Palm Beach to a street called "Brillo Way". They drove to the end of the street and entered a large drivewa . The entered the kitchen area of the house and met with Epstein. was introduced to Jeff Epstein. led upstairs to the main bedroom area and set up the room with a massage table and set out the oils. stated that while going up the stairs and into the bedroom she observed numerous photographs of naked young girls. dimmed the lights and turned on soft music. exited the room and Epstein entered the room wearing only a towel. Epstein picked oils and instructed her to rub his legs, under his buttocks, back and chest area. Epstein asked her to get comfortable. advised she did not remove her clothes. She was wearing tight jeans and a cropped tank top exmaier belly area. Durin the massage, Epstein removed his towel and laid on the massage table naked. As • area, he attempted to reach down her pants to touch her buttocks area however was unable to due so due to the tightness of the jeans and a tight belt. advised Epstein began to masturbate as she rubbed his chest. Epstein moaned as she rubbed his chest. She observed he was continuing to masturbate and The foregoing instrument was sworn to or affirmed before me this 1" day of May, Mb by Det , who is personally known to me. State of Florida --- Csawty-otPater Reach-- Signal Date: 11/2006 Officer Pageof 22 EFTA00231902 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 attempted to reach up her tank top and touch her breasts. M, pulled back and Epstein stopped, however he kept masturbating until he climaxed. He cleaned himself with the towel he was previously wearing. was paid $200.00 for the massage and left the area. She met with who was waiting in the kitchen area and left the house. with then explained she never provided another massage for E stein. She did however, go to the house and as they took another friend of . . advised she was present when went to work for Epstein. She advised she rode over and sat in the kitchen area with to wait for . . advised while they waited for the house chef prepared lunch for them as it was almost lunchtime when they went. When was finished with the mass. aa: they left the area. I asked El if ever told her what would be expected when she provided a massage. . stated yes, told her that a massage would be expectedossibly naked and possibly some touching involved. IN has no formal training in providin massages. . spoke about a third and last time she went to Epstein's house. drove another girl, (sixteen years of age) who is friend, to Epstein's house. . stated knew that • had made money massaging to . and took. upstairs to the main bedroom. stein and wanted to make money herself. took them in the kitchen area of the house and introduced advised she doesn't know what happened as did not speak about what happened in the room. . received . . $100.00 from for going with her to Epstein's house and recommending a On October 6, 2005, at 11:45 am, I met with dob at and explained to her why we there to interview her. She advised she was aware of the ongoing investigation. stated she had previouslliaoken with sworn taped statement, stated she knew that who told her she was interviewed by detectives. Duras worked for Jeff Epstein in Palm Beach. advised she originally had been taken to the Epstein house by , whom she met when they both attended Royal Palm Beach High School. She began going to the house when she was sixteen years of age and stated she had been there a lot of times to provide massages over the past two years. I asked her if she had formal training in providing massages, which stated she had not. advised she was told what was expected of her by providing maccages and she would have to remove clothing but if she felt uncomfortable just to say so and Epstein would stop pushing the issue. began providing massages and advised she kept her clothes on. She considered Epstein a pervert and he kept pushing to go further and further. explained she would keep telling him she had a boyfriend and would not be right to her boyfriend. It wasn't until recently that began removing her clothes and staying in her thong underwear to provide a massage. explained The foregoing instrument was sworn to or affirmed bcforc me this 1" day of May, 2006 by Det , who is personally known to me. Signature of Police Officer (F. .S. 117.10) State of Florida Coffin of Palm D.ach Signa ng Officer Date: 0 '1/2006 Paget of 22 EFTA00231903 Probable Cause Affidavit Palm Beach Police Department Agency ORS FLO 500600 Epstein wanted to be rubbed on his back and recently he began turning over and have her rub his chest as he masturbated. He would try to touch her breasts as she rubbed his chest. stated "would try to get away with more and more on each massage". stated would try to touch her more and on one occasion he mated to use a massager/vibrator on her. M drove M to the house for the original massage. left her cell phone number and every time E stein would come into town, would call her for an appointment to "work". Each time she went, would meet her at the kitchen door area. She would bring her upstairs and re are the massage table. g advi sed E stein would ask herations about herself. Epstein knew she was and would be attendin . I asked if Epstein knew her real age. stated Epstein did and didn't care. The most recent massage she provided was on October I, 2005. Dur.ithe massage, she asked Epstein if she could borrow one of his vehicles to visit her family and boyfriend in , Florida. Epstein had told her she could borrow one of his vehicles but later stated he would rent her a car. She continued with the massage as Epstein and . I asked M if she was wearing undergarments to which she replied her thong underwear. Once he tried to touch her breasts, she would pull away from him and he would stop. M was asked if he ever used a vibrator on her. was aware of the vibrator but advised she never would allow him to on her. She described the vibrator as the large white vibrator with a huge head on the tip of the vibrator. She stated he kept the vibrator in a closet near the massage table. . stated that on October 3, 2005, she was contacted by Epstein's assistant, , who informed her that yin had rented her a new Nissan Sentra and she should come by the house to pick it up. .nformed she would have the car for a month. stated Epstein knew her car was not working properly and that she had missed appointments in the past because of her car being inoperable. explained the car is currently parked next to the Gym field. I asked her if she ever took any one to the house: explained she took , a friend of hers who attended Royal Palm Beach High School who has relocated to to attend college. I asked if she ever allowed another female in the room. advised no one was brought into the room with her. At the conclusion of the interview, Det and I went to the gym area of and located the Silver Nissan Sentra bearing Florida tag . The vehicle is registered to Dollar Rent a Car out of the Palm Beach International Airport. The vehicle was rented by Janusz Banasiack, later learned to be Epstein's houseman, and paid with Epstein's credit card. On September 11, 2005, w/f., dob, , was arrested by the Palm Beach Police Department The foregoing instrument was sworn to or affirmed bile Det State of Florida , who is personally known to me. Signature of Police Officer (F.S.S. 117.10) Signs tu Date: Im Bcal. ng Officer Pagdaof 22 EFTA00231904 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 for misdemeanor possession of marijuana. During the arrest s told the arresting officer that she had information about sexual activity taking place at the residence of Jeffrey Epstein. Additionally, during the ongoing trash pulls from Epstein's residence, discarded papers were found which contained name and cell phone number. On October, 11, 2005, Det and I met with S and obtained a sworn taped statement. S explained she had been going to Epstein's house since 2002, when she was sixteen years of age. Since then she has gone to the house hundreds of times. S stated she became his "number one girl." She explained that on her first visit she was brought to the house by fellow Royal Palm Beach Hi School classmate, • said she was brought through the kitchen area where she met . for the first time. was led to the master bedroom, Epstein s room. IS explained that as she was walking up the stairs she observed several photographs of naked women alonitlie walls and tables of the house. . further explained that she was brought into the bedroom, where prepared the room by setting up the massage table and provided the oils for her to rub on Epstein. • explained she remembered the steam room area, which contained two large showers. Epstein entered the room from the steam room area and introduced himself. Epstein lay on the table and told her to get comfortable. • removed her skirt and kept her shirt on. Epstein then instructed her to remove her shirt. • removed her shirt and remembered she was not wearing a bra. an Il istated she provided the massage wearing only her ties. She continued rubbing his legs, thighs and feet. advised he turned over onto his back. Epstein and be an to masturbate. Epstein ejaculated which meant the masse e was over. At the conclusion of the massage, was paid $200.00. They walked together downstairs where and were waiting. stated received an unknown amount of .money for taking her to Epstein. Epstein instructed to leave her cellular telephone number, that he could contact her when he is in town. stated that during her many visits a routine was established between her and Epstein. She would enter the house and get naked in the bedroom. She would then start with a back massage. Epstein would roll on to his back and allow her to massy e his chest area. stated E stein would then began to masturbate himself and at the same time would with his forgers. explained Epstein would continue this process until he ejaculated. He would then . IS advised that during her frequent visits, Epstein asked for her real age, stated she was sixteen. Epstein advised her not to tell anyone her real age. U advised that things escalated within the home as Epstein . explained the that Epstein had at his disposal, and masturbate himself . Occasionally, Epstein would then join in would instruct and pa intercourse included Epstein would watch them The foregoing instrument was sworn to or affirmed before me thIsl" day tifitan-2006—by Det who is personally known to me. Signature o o ice leer . . . .10) State of Florida Signatur ing Officer Date: /2006 Page‘ of 22 EFTA00231905 Signature of Police Officer (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 during the the time was sixteen years of age. advised this continued to escalate during two years. The routine became familiar to E. Epstein's assistant would telephone her every time Epstein was in the Town of Palm Beach and would place appointments for her to visit and work for Epstein. Each time something new was introduced, additional monies were produced and offered for . to allow the acts to happen. • consented to perform all these acts but was adamant that there was an understanding with Epistein that no vaginal penetration would occur explained that Epstein's penis was deformed.. explained that his penis was oval shaped. claimed when Epstein's penis was erect, it was thick toward the bottom but was thin and small toward the head onion. called Eistein's penis "egg-shaped." • stated Epstein would photo aph and her and proudly display the photographs within the home. stated during one visit to Epstein's house and her would in which she provided a mass e to E stein, his female friend was also resent. provided the massage in which IMI for Epstein to enjoy. Towards the end of this massa e E stein bed and turned her over onto her stomach on the massage table and stated E stein be an to became upset over this. She said her head was , as he continued to . She screamed "No!" and Epstein stopped. She told him that she did not want to . Epstein did not epaulate inside of her and apologized for his actions and subsequently paid her a thousand dollars for that visit. . stated she knows he still displays her photographs through out the house. to both ■ and . This occurred during On October 12, 2005, Det and I met with , dob , who stated during a sworn taped statement, that nothing happened between her and Epstein. appeared nervous during the interview. I assured her that I have spoken with other people who advised differently. stated on several occasions sheprovided a massage to Epstein. She stated she was brought to the Epstein house in March of 2005. , a classmate at Royal Palm Beach High School, approached her and asked her if she wanted to "work". made the arrangements with =, Epstein's assistant. , who has no formal training in providing masa stated she provided a massage, fully clothed for $200.00 . As I sensed hesitancy in her answers, I asked if she had been contacted by anyone from Epstein's organizations or his house. stated she was interviewed already by a private investigator for E stein. He identified himself as "Paul" and ired about the police investigation, and left his telephone number for additional contact. provided no additional information, as it appeared her responses were almost scripted. The foregoing instrument was sworn to or affirmed before me this day of May, 2006 by of Palm Beach Det who is personally known to me. State of Florida Signatur Officer Date: 05/01/2006 Pagd2of 22 EFTA00231906 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 On November 6, 2005, at airaimately 3:30 pm, I met with dob , at the Palm Beach Police Department. was identified as a potential witness/victim through information obtained during the trash pulls. During the sworn taped statement, advised she was at Jeffrey Epstein's house one time, approximately two months ago. She was approachedSigirl, , who was dating M ' roommate, for an opportunity to make some quick money. advised she needed to make some quick cash to make the rent that month. She agreed to go to the house. She had been told by that the massage would have to be done in her underwear. She advised drove with her and brought her into the house. They walked into the kitchen area, and took the stairs upstairs. further stated She was brought into a master bedroom area. She advised she recalled seeing portraits of naked women throughout the room. A massage table was already out near the sauna/shower area in the master bedroonSein entered the room wearing only a towel and introduced himself as "Jeff." At Epstein's direction, and removed their clothing down to their panties, Epstein laid on his stomach area and they provided a massa e on his legs and feet area. I asked if she had any formal massage training and she replied "no." advised she was topless and the panties she wore were the boy shorts lace panties. She and continued the massage until the last ten minutes of the massage, Epstein, told to leave the room so that could finish the massage. got dressed, and left the room as turned over onto his back. Epstein then removed the towel and laid naked . E stein requested that rub his chest area. stated , Epstein, began masturbating. stated Epstein pulled down her boy short panties, and he produced a large white vibrator with a large head. She stated it was within his reach in a drawer in his master bathroom. He advised he never with the vibrator. He continued to as he continued to masturbate. stated she was very uncomfortable during the incident but knew it was almost over. Epstein climaxed and started to remove himself from the table. He wiped himself with the towel he had on previously and went into the shower area. got dressed and met with in the kitchen area. Epstein came into the kitchen and provided $200.00 for bringing and paid $200.00 to for providing the massage. was told to leave her telephone number with for future contact. provided her cellular telephone number. was asked if she was recently contacted about this investigation by an one the Epstein organization. She replied she was called but it was for work. She stated she was called by for her to return to "work" for Epstein. stated "work" is the term used by to provide the massages and other things. advised she declined as she was not comfortable in providing that type of "work." On November 7, 2005, Det and I met with dob During a sworn taped statement, stated she met Jeffrey Epstein through when they were still The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Co Det , who is personally known to me. State of Florida Signature of Police Officer (F.S.S. 117.10) Signature Ricer Date: 05/01/2006 Pagd1 of 22 EFTA00231907 Signature of Police Officer (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 attending Royal Palm Beach High School. would approach females who wished to work for Epstein. stated she was offered to work for Epstein but declined. explained that "work" means ive massages. She was asked about any formal training in providing massages which she said "no." said she accompanied and other females who were taken to Epstein's house to provide massages. with ==> further stated she had been to the house roximat& 4 or 5 times in thepast year. She accompanied , M, and . Each time the girls were taken over, they were previously told they would have to provide a massage, possibly naked. They were also told that shouldist.ein require them to do anything extra, and they were not comfortable just to tell him and he would stop. stated received $200.00 for each girl she brought over to massage Jeffrey Epstein. When I asked which girl appeared to be the youngest, she replied, MI, who was really young, fifteen years old at the most. further stated each time she went to the house, she sat in the kitchen and waited with until the massage was over. She further stated that the cook would make lunch or a snack for them as they waited. I asked her if there was anything that caught her attention within the home. stated there were a lot of naked girls in photographs throughout the house. On November 8, 2005, at approximately 2:00pm , I met with , dob , at the Palm Beach Police Department. During a sworn taped statemen stated she had met Epstein approximately two ears ago when she was first approached by a classmate at Royal Palm Beach High School. approached her about working for Epstein and providing a massage to him for $200.00. had made the arrangements however was unable to take her the day the arrangements were made. with Epstein. with an assistant photographs of naked females throw out the house. stated Epstein came in the room, wearing only a towel, and laid on the table. stated hi ad out the oils he wanted her to use and requested she remove her clothing tol, i the massage. stated that on the first massage she provided she did not remove her clothing. stated she had returned several times after that. Each time she returned it was more than a massage. Epstein would walk into the master bedroom/bathroom area wearing only a towel. He would masturbate as she provided a massage. stated she was unsure if he climaxed as he masturbated under the towel. Additionally, she never looked below his waist. She claimed that Epstein would convince her to remove her clothes. She eventually removed her clothes and stayed in her thong panties. On occasion,ifin would use a mass er/vibrator which she described as white in color and a large head. Epstein would as he would masturbate. stated she had been to the house take recalled she was brou and another assistant also attended Royal Palm Beach High School and was familiar ht there and entered through the back kitchen door. She had met brought her upstairs as she observed several The foregoing instrument was sworn to or affirmed betore me this ayal-May;200r by Det , who is personally known to me. Signatur g Officer State of Florida lin-Beach Date: 05/01/2006 Pagltiof 22 EFTA00231908 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 numerous times. added she has no formal trainin in providing a massage. stated she brow ht two females during her visits to provide massages. stated she brought a girl named "M" and from Royal Palm Beach High School. stated she received $200.00 for each girl she brought. On November 8, 2005, I met with , W/F, at the Palm Beach Police Department. During a sworn taped statement, stated she had met Jeffrey Epstein approximately one year ago. She was approached by a subject known to her as M. • had asked her if she wanted to make money providing massages to Epstein. had heard that several girls from Ro 1 Palm Beach High School were doing this and making money. She agreed and was taken to the house by E. • had introduced her to and Epstein and brotIght her upstairs to a master bedroom where a masse e table was prepared and the proper oils were selected. • left the room and waited downstairs for her. stated Epstein entered the room wearing a towel and laid on his stomach. She provided a massage wearing only her thong panties. advised Epstein had masturbated every time she provided a massage. She stated Epstein continued to masturbate until he climaxed. Once that occurred the massage was over. She felt the whole situation was weird but she advised she was $200.00 for providing the massage. She also stated was paid $200.00 by Epstein for bringing stated she had gone a total of 15 times to Epstein's residence to provide a massage and things had escalated from just providing a masse e. E stein be an touchin grabbed her closer to him as he masturbated. Epstein also and $350.00 for her massage. I asked her if she had any formal training in providing massages, not. continued to state on one other occasion, Epstein introduced his girlfriend, was brou: into room with to provide a massage. Epstein had them as they provided a massage to Epstein. Epstein, watched and masturbated as this occurred. On other occasions, introduced the large white vibrator/massager in the massage. Epstein on vagina as she provided the massage. and with his hands as she provided the massage. stated on one occasion, while she was only seventeen years of age, he offered extra monies to have vaginal intercourse. She stated this all occurred on the massage table. stated Epstein and be an until he reached the point of climax. Epstein removed and climaxed onto the massage table. received stated she did into the massage. On November 14, 2005, Det and I met with dob . During a sworn taped statement she advised she started going to the house approximately one year ago and has been there approximately five or six times. also stated she was sixteen years old when she first went to Epstein's house. On her first visit she was brought by a fellow student from Royal Palm Beach High School known to her The foregoing instrument was sworn to or affirmed before me day of Mayieneo—by￾Det , who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida Signatu g Officer Date: 05/01/2006 Page of 22 EFTA00231909 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 as stated brought her into the house and she was introduced to then brought her upstairs into a master bathroom, located within the bedroom. stated she met Epstein in the bathroom. He laid on the table and picked the massage oils. She provided the massage as he laid naked on the massage bed. She stated she rubbed his calves and back area. Upon the end of the massage, Epstein removed himself from the massage table and paid her $300.00 for the massage. said each subsequent time she went to the house, she was notified by that Epstein was in town and would like her to "work". stated she returned to the house and was again led upstairs by . She provided the massage, clothed. was asked if she ever removed her clothing to aa massage. stated it was not until the third time that she went that she removed her clothing. stated she was notified by that Epstein wanted her to come to work. She arrived at the house and was led upstairs by She started providing the massage when Epstein asked her to remove her clothing. removed her pants, shirt and bra. She stayed in her thong panties and . Epstein turned over onto his back and she stated she knew he was masturbating himself as she providing the massage. stated she believed he climaxed based on his breathing. She did not want to view either the climax or the fact that he was masturbating. stated once the breathing relaxed he got up and told her to get dressed. She was paid $300.00 for her services. stated on the last time she went to provide a massage, she was notified by to come to the house and "work'!. stated she was now dating her current boyfriend and did not feel comfortable going. She recalled it was approximately January 2005. She said she went, already thinking that this would be the last time. She went upstairs and went into the master bathroom. She met with Epstein, who was wearing only a towel, and laid onto the table. stated Epstein caught her looking at the clock on several occasions. Epstein asked her if she was in a hurry. stated her boyfriend was in the car waiting for her. further stated that Epstein got upset as he wasn't enjoying the massage. She told.him that she didn't want to continue and she would not be back. Epstein told her to leave as she was ruining his massage. advised she had no formal training in providing any massages. stated although she had a falling out with Epstein, she still received a Christmas bonus from Epstein. stated she was wired money from Western Union for her Christmas bonus. Sultaresults from Western Union revealed money was sent from Jeffrey Epstein on December 23, 2004. received $200.00 from Epstein for her Christmas bonus. On November 15, 2005, Det. and I met with dob . During a sworn taped statement, stated she met Jeffrey Epstein over a year ago. She was sixteen years of age and was approached by , a fellow Royal Palm Beach High School student, who informed her that she could make $200.00 providing a massage to Epstein. had informed her that she would have to provide this The foregoing instrument was sworn to or affirmed betore me nus aay in May, 2006 by Det , who is personally known to me. State of Florida Signature of Police Officer (F.S.S. 117.10) on u (Palm Beach Signature/ ng Officer Date: 05/01/2006 Page Hof 22 EFTA00231910 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 massage to made the arrangements with Epstein and his assistants and took . to the house. • stated and she entered through a glass door that led into a kitchen. She was taken upstairs by to a master bedroom. She recalled the master bathroom had a large ink couch, sauna and matching shower. Epstein entered into the room wearing only a towel. • and removed their clothing remaining only in thong underwear. She further stated that Epstein laid on his chest on the table. The oils were selected on which ones to use. Both and . provided the massage on his legs, back and feet. Forty minutes into the massage, Epstein turned over onto his back and re uested wait downstairs in the kitchen area for Epstein instructed . to finish the massage. As ot dressed, startin rubbing Epstein's chest. left the room, and Epstein began masturbating as .. stated Epstein continued masturbating until he climaxed on the towel he was wearing. When asked if he had removed the towel she stated he turned the towel around 16that the opening would allow him to expose himself. After he cleaned himself off with the towel he instructed the massage was done and to get dressed and meet with him downstairs. ot dressed and met with Epstein in the kitchen area. She was paid $200.00 dollars for providing the massage. stated she was aware that also received monies for the same thing. The second time she went to the house she was again approached by advised if she wanted to return to the house tlEovide another massage.. agreed and the arrangements were made by for her to return to the house. M stated drove her to the house and knocked on the same glass door which leads to the kitchen area. They were allowed entry into the house by one of the staff members. led her upstairs to the master bedroom and master bathroom area. left IIM this time to do the massage alone. Epstein entered the room again wearing only a towel.. began removing her clothing as she did the last tithe she was at the house. Epstein instructed her to get naked. He laid on the table onto his stomach as . began massaShis legs and back. As . finished with Epstein's back and legs, Epstein then turned over onto his back. M started to mb his chest and he began masturbating. As Ili rubbed his chest, Eistein leaned over and produced a massager/vibrator. He turned it on and began rubbing vagina and masturbating himself at the same time. . stated she as this was occurring. She described the vibrator/massager as large grey with a large head. Epstein for a roximately two to three minutes with the massager/vibrator. He then removed the and concentrated on masturbating himself.. stated Epstein climaxed onto the towel again and informed her that the massage was done. lagot dressed and met with who was waiting in the kitchen area. She received $200.00 for the massage. said she never returned to the house and had no desire to return to the house.. was asked if she received any formal massage training. She advised she had no formal training. • was asked if Epstein knew her real age. • stated he knew, as he asked her questions about herself and high school. He was aware she attended, and is still attending Royal Palm Beach High School. The foregoing instrument was sworn to or affirmed before me-this 1" day of May, 2006 by Det , who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida ounty of Palm Beach Signatu ng Officer Date: 05/01/2006 Page of 22 EFTA00231911 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 During the course of the investigation a search warrant was executed at Jeffrey Epstein's home located at 358 El Brillo Way in Palm Beach. While in the home I observed the pink and green couch within the master bedroom area just as the girls previously mentioned. The stairway, which is located from the kitchen area to the master bedroom area, is lined with photos of naked young girls. Additionally, numerous photographs of naked young females, some of which appeared to be the girls I previously interviewed, were on display throughout the house. Also located in the house were various phone message books. The telephone message books have a duplicate copy (Carbon Copy) which, once a phone message is written into the book, the top copy is then torn on the perforated edge and the carbon copy is left in the book. First names of girls, dates and telephone numbers were on the copy of the messages. I recognized various numbers and names of girls that had already been interviewed. The body of the messages were time of the day that they called for confirmation of "work." Other names and telephone numbers were located in which the bod of the messages were, "I have girls for him" or "I have 2 girls for him." These messages were taken by , who signed the bottom of the messages. During the execution of the warrant, I located a Royal Palm Beach High School transcript for E in Epstein's bedroom desk. This desk had stationary marked Jeffrey E Epstein. I located a wood colored armoire beside Epstein's bed that contained a bottle of "Joy Jelly," which is used to provide a warm massage. Several massage tables were located throughout the second floor of the residence, including a massage table found in Epstein's bedroom. On the first floor of the residence I found two covert cameras hidden within clocks. One was located in the garage and the other located in the library area on a shelf behind Epstein's desk. A computer was located which was believed to contain the ima es from the covert cameras. The computer's hard drive was reviewed which showed several images of and other witnesses that have been interviewed. All of these images appeared to come from the camera positioned behind Epstein's desk. On December 13, 2005, Det. and I met with dob . During a sworn taped statement, stated that when she was sixteen years old she was taken to Epstein's house to provide a massage for money. stated it was before Christmas last year (2004) when an associate, approached her and asked if she needed to make money for Christmas. made arrangements to take to the house and drove E to the house to "work." They were encountered by a white female with long blond hair. E was unable to remember the name of the white female with blond hair but knew she was Epstein's assistant. She was led upstairs by the white female who explained that there would be lotions out already and Epstein would choose the lotion he wanted her to use. She was led through a spiral staircase which led to a master bedroom and bathroom. The massage table was already set up in the bathroom. E described the bathroom as a large spacious bathroom with a steam room and shower beside it. E was introduced to Epstein who was on the phone when she entered the room. Epstein was wearing a white towel and laid on his stomach, that. may Signature of Police 'Officer (F.S.S. 117.10) The foregoing instrument was sworn to or affirmed before me this r nay or May, 2u06 by Oct who is personally known to me. State of Florida Signature/ ng Officer Date: MI - 106 1P Page of 22 EFTA00231912 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 massage his feet and calves. • started the massage with the oils Epstein chose and rubbed his feet and calves. Epstein got off the phone and requested she massage his back as well. • began rubbing his back and got to the small of his back. During the rubbing of his back, Epstein asked her to g!et comfortable. He requested she remove her pants and shirt. removed her shirt and pulled her pants off. stayed in her bra and thong panties. As she fmished massaging the small of Epstein's back, he then turned onto his back. Epstein instructed to rub his chest and pinch his nipples. As she , Epstein asked her questions about herself. • remembered telling him she attended Royal Palm Beach High School. Epstein asked her if she was sexually active. Before could answer, he also asked what sexualposition does she enjoy. • stated she was shy and didn't like talking about those things. She continued . Epstein reached u and unsna her bra from the front. • explained the bra she used had a front snapping device. Epstein and asked her if she like having said "no, I don't like that." Epstein then removed his towel and laid on the bed naked exposing his penis to . He began touching his penis and masturbated as he explained Epstein then touched her vaginal area by rubbing her vagina with.his fingers on the outside of her thong panties. tensed up and stated Epstein was aware that she was uncomfortable. • stated that Epstein said to her, "Relax, I'm not going inside." She further explained Epstein commented to her how beautiful and sexy she was. Epstein then moved her thong panties to one side and began said, "He commented how " He then She tried pulling back to and apologized for 12!g urin this time, he kept his and continued to rub her vagina. stated he as he was masturbating. said he climaxed onto the towel he had been previously wearing and got up from the table. Epstein told her there was $200.00 dollars for her on the dresser within the master bathroom. Epstein also told her that there was an additional $100.00 that was to be given to for bringing her there to massage him. Epstein told her to leave her telephone number with his assistant as he wanted to see her again. Epstein stated his assistant would contact her to work again soon. I asked her if she ever received any formal massage training to which stated she did not stated it was the only time she ever went to work for Jeff and knew what happened to her was wrong. She further stated that she had never been contacted for any additional work. On January 9, 2006, I located and interviewed another victim, dob . was identified as a potential victim/witness from information obtained during trash pulls from Epstein's residence. stated she met Epstein when she was fifteen years of age. She was approached by a friend from Royal Palm Beach High School, to be taken to Jeffrey Epstein's house to work. She was originally told she would be able The foregoing instrument was sworn to or affirmed before me this 1 day of May, AIM by County-of as mi finch Det who is personally known to me. State of Florida ignature o ore icer . . 117.10) Signature Date: 05/ i /2006 Officer Pagel' of 22 EFTA00231913 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 to model linmrie for a wealthy Palm Beacher. Ill was taken to Epstein's house located on El BrilloWay. introduced . to Jeffrey Epstein. Epstein had his Ersonal chef prepare dinner for . and . At the conclusion of dinner, = and Epstein brought . upstairs into a master bedroom area. observed a large massage table with a sheet on it. Epstein entered through a door and exited wearing only a towel. informed . that they were going to provide a massage on Epstein.. asked why were they doing this instead of modeling lingerie. ex lained to . that this was his routine and to nib his calves and feet. Epstein had told . to get comfortable. removed her pants and blouse. . stated she stayed only in panties as she did not wear a bra that evening. stated while rubbing his calves and feet, Epstein turned over onto his back. Epstein told . to rub his chest and rub his ni les. stated that as she started , Epstein began masturbating himself . Epstein and with his fingers. Eetein continued to masturbate himself as he . Epstein ejaculated on his towel and paid . $200.00 for the massage. la in told . that if she told anyone what happened at his house that bad things could happen. I.and = were brought home by Epstein's houseman and . was afraid that Epstein knew where she lived. stated that several days later she received a telephone call from who coordinated for Ini to return to "work." . returned to the house and was brought to Epstein's bedroom area by who prepared the room for the massage. Epstein entered the room wearing only a towel. Epstein had remove her clothing and provide the mass e naked. be an rubbing his feet and calves and Epstein turned over onto his back. Epstein . E stein be an to masturbate himself with an upwards and downward motion on his penis. Epstein continued with one hand and masturbate with the other hand. Once Epstein ejaculated onto the towel he was wearing, the massage was over. . was paid $200.00 for the massage. Epstein again told El not to speak of what happened at his house or bad things would happen. . wanted to notify authorities however she was afraid of what would happen to either her or her family. During the course of the investigation, several subjects were identified as a potential witness/victim through information obtained during the trash pulls, physical surveillance and telephone message books retrieved from the search warrant. While conducting research on the subjects, I discovered that the females were age eighteen or older. Interviews were conducted on the consenting adults whose statements provided the same massage routine when they went to "work" for Epstein. The females would be notified by , and made appointments for the females to "work" for Epstein. The females would come to Epstein's house and were led upstairs, through a stairwell from the kitchen area, by to Epstein's bedroom. Epstein would then enter the room wearing only a towel, and ask them to et comfortable. The females would then provide the massage naked as Epstein would either and/or utilize the massager/vibrator on The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Cou Det State of Florida , who is personally known to me. orPalm Beach Signatur Signature of Polite Officer (F.S.S. 117.10) Date: 05/ ng Officer 006 Pag?Dof 22 EFTA00231914 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 He would masturbate during the massage and upon his climaxing, the massage would end. The girls were then paid two or three hundred dollars for the massage. On November 21, 2005 I interviewed Jose Alessi, a former houseman for Jeffrey Epstein. Alessi stated he was employed for eleven years with Mr. Epstein, from approximately 1993 through 2004. Alessi stated he was the house manager, driver and house maintenance person. It was his responsibility to prepare the house for Epstein s arrival. When asked about cooks or assistants, Alessi stated they traveled with Epstein on his private plane. I asked Mr. Alessi about the massages that have occurred at Epstein's home. Alessi stated Epstein receives three massages a day. Each masseuse that visited the house was different. Alessi stated that towards the end of his employment, the masseuses were younger and younger. When asked how young, Mr. Alessi stated they appeared to be sixteen or seventeen years of age at the most. The massages would occur in Epstein's bedroom or bathroom. He knew this because he often set up the massage tables. I asked if there were things going on other than a massage. Alessi stated that there were times towards the end of his employment that he would have to wash off a massager/vibrator and a long rubber penis, which were in the sink after the massage. Additionally, he stated the bed would almost always have to be made after the massage. On January 4, 2006 I interviewed another former houseman, Mr Alfredo Rodriguez. During a sworn taped statement, Mr. Rodriguez stated he was employed by Jeffrey Epstein for approximately six months, from November 2004 through May of 2005. His responsibilities as house manager included being the butler, chauffeur, chef, houseman, run errands for Epstein and provide for Epstein's guests. I asked Rodriguez about masseuses coming to the house. Rodriguez stated Epstein would have two massages a day. Epstein would have one massage in the morning and one massage in the afternoon everyday he was in residence. Rodriguez stated he would be informed to expect someone and make them comfortable until either or Epstein would meet with them. Rodriguez stated once the masseuses would arrive, he would allow them entry into the kitchen area and offer them something to drink or eat. They would then be encountered by either or Epstein. They would be taken upstairs to provide the massage. I asked Rodriguez if any of the masseuses appeared young in age. Rodriguez stated the girls that would come appeared to be too young to be masseuses. He stated one time under Epstein's direction, he delivered a dozen roses to Royal Palm Beach High School for one of the girls that came to provide a massage. He knew the girls were still in high school and were of high school age. I asked Rodriguez about the massages. He felt there was a lot more going on than just massages. He would often clean Mr. Epstein's bedroom after the alleged massages and would discover massagersIvibrators and sex toys scattered on the floor. He also said he would wipe down the vibrators and sex toys and put them away in an armoire. He described the armoire as a small wood armoire which was on the wall close to Epstein's The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det , who is personally known to me. Signature of Police fficer F.S.S. 117.10) State of Florida C Signatu ng Officer Date: i /2006 Pagf of 22 EFTA00231915 Signature of Police Office (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 bed. On one occasion Epstein ordered Rodriguez to go to the Dollar rent a car and rent a car for the same girl he brought the roses to, so that she could drive her self to Epstein's house without incident. Rodriguez said the girl always needed rides to and from the house. Rodriguez produced a green folder which contained documents, and a note with Mr. Epstein's stationary with direction to deliver a bucket of roses to Royal Palm Beach Hi School after high school drama performance. Also in that same note was direction to rent a car for and direction to extend the rental contract. During the course of the investigation, subpoenas were obtained for cell hone and home phone records from several victims and witnesses along with the cell phone records of . An anal sis of these records was conducted which found numerous telephone calls were made between and the victims. These records indicate the dates the calls were made are consistent with the dates and times they victims/witnesses stated they were contacted. Speciftcall , The phone records showed called during the exact times and dates when victim advised the incident occurred. also coordinated the encounters with U,N, and during the time frame the girls stated they occurred. Pursuant to a lawful subpoena I obtained Epstein's private plane records for 2005 from Jet Aviation. The plane records show arrival and departure of Epstein's lane at Palm Beach International airport. These records were compared to the cell phone records of This comparison found that all the phone calls made to and the victims were made in the days just prior to their arrival or during the time Epstein was in Palm Beach. As Epste who at the time of the incident was fifty two years of age, did commit lewd and lascivious molestation on E, a fourteen year old minor, by using a vibrator on her external vaginal area and as recruited, set up the appointment and drove to Epstein's residence, knowing that was fourteen years old and knowing there would be unlawful sexual activity between and Epstein that received monetary compensation for taking said fourteen year old female by Epstein, there is sufficient probable cause to arrest for Lewd and Lascivious Act on victim under 16 years of age in violation of Florida State Statue 800.04 (6)(2b) a second degree felony. The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by l)ct , who is personally known to me. State of Florida Signatu Officer Date: 05/01/2006 Pageaof 22 EFTA00231916