EFTA00231917

EFTA00231917 EFTA00231918 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 Police Case#: 05-368 (1) Defendant: Race/Sex: DOB: Charges: Unlawful Sexual Activity with a Minor (4) counts Lewd and Lascivious Molestation Jeffrey Epstein 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 ti 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 rub his fingers on their vaginas. On occasion, Epstein would introduce a massager/vibrator and rub the victims vaginas as they provided the massage. On three separate occasions, Epstein had intercourse and inserted his penis/cmgers 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 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 a cousin of boyfriend and classmate igh School, worked for a wealthy man and did sexullors 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 by EMo go with her to Epstein's house. Estated 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 Mlrove them to Palm Beach. During the drive a e lot egoinginstr wmentivar sworrrtoor affirmerl- Statevf-Horidn----- ' before me this day of May, 2006 by County of Palm Beach Det Joe Recarey, 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 EFTA00231919 Probable Cause Affidavit Palm Beach Police Department Agency OFt10 FLO 500600 conversation occurred between and =whereas a-portedly told Ethat if Jeff asked her age, she should say she was eighteennras later confirmed by the ms's father that picked his daughter up on February 6, 2005. According to Rs 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, past what appeared to be a small guard/security room. A male approaching them asking what they wanted. 1. stated they were there to see Epstein. The male allowed them to continue walking up to the house. tat 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. elescribed Epstein as being approximately forty-five years old, having a long face and bushy eyebrows, with graying hair. _and Epstein left the kitchen leaving Mlone in the kitchen. They returned a short time later. They all spoke briefly in the kitchen. Mvas instructed to follow upstairs. Erecalled 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 thels ' a omural of a naked woman in the room, as well as several photographs of naked women on a shelf. ld the victim that Epstein would be up in a second. Epstein entered the room wearing only a towel and told NM take off her clothes. . stated Epstein was stern when he told her to take off her clothes. Maid she did not know what to do as she was the only one there in the room so she took off her shirt leaving her bra on. Epstein had removed his towel and told the to take off everything. Mstated Epstein was nude when he took his towel off, placing it on the floor as he laid down on the table. dated she then removed her pants leaving her thon i ,anties on. Epstein then instructed her to give him a massage pointin to a specific lotion for her to use. As began to give Epstein the massage, he told her to get on his back. s tated she straddled herself on Epstein's ack whereby her exposed buttocks were touching Epstein's bare buttocks. Said Epstein was specific in his instruction to her on how to massage him, tellin her to go clockwise or counter clockwise. Epstein then turned over and instructed.to massage his chest. vas 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 turn o his side and started to nib his penis in an up and down motion. Epstein then pulled out a purple vibrator and began to e roregomg Instrument was swim u u us arlu before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. ..no County of Palm Beach Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00231920 Probable Cause Affidavit Palm Beach Police Department Agency 0111# FLO 500600 Mrecal pstein ejaculating ecause he had to use the towel to wipe himself as he of off the table. Epstein massage s vaginal area. tated there was no penetration as the vibrator was on top of her underwear. then left the room and got dressed. She went back downstairs where she met with Msaid she was paid three hundr ollars in cash from Epstein. Before she left, Epstein asked o leave her phone number. AsiMiand -were leaving the house, old El 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 561- ...spoke with in an attempt to arrange another meeting with pstein. Masked IMB what did she need to do to make more money._stated, "the more you do, the more you get paid." ointment for o go to Epstein's house at 11:00 am on April 5, 2005. This message was recorded from had subssently called back .and left a voice mail message for her indicating that she had set up an i i 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 a telephone message for Epstein which stated and II name at 11:00 am. This was the time frame Mad informed INto be ready to go work at Epstein's house. On October 3, 2005, Sgt Frick and I went ton residence and viewed her vehicle parked in the driveway, a red Dodge Neon. Sgt. Frick and I lame door and met with- lavas told that we were investigating a claim involving Jeffrey Epstein of El Brillo Way, in Palm Beach. at, 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, Illgv as brought to the interview room in the Detective Bureau where I obtained a taped, sworn statement. Ibegan e interview by asking 'ow she became acquainted with Epstein. Mintated that approximately two years ago, just after she turned of age, she was approached by a en named eat 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. =bought about the offer and agreed to meet with Jeffrey. lie foregoing histrum nt-was State of Florid before me this 1" day of May, 2006 by County of Palm Beach Det Joe Recarey, 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 EFTA00231921 Probable Cause Affidavit Palm Beach Police Department Agency O1W FIX) 500600 nknown last name) andl. (Unknown last name) picked up and she was taken to Epstein s house. Upon her arrival to the house she w uced to Epstein in the kitchen of the house. She was also introduced to a white fe own to her 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 az em 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 nib on him. Duriaietnassage, t Ipisfated "He tried to touch me and I stopped him." I asked how he tried to touch her. tated that pstem grabbed her buttocks and she felt uncomfortable. old Epstein, I'll massage you but I don't want to be touched. Mtated she performed the massage na ed. At the conclusion of the massage, Epstein paid $200. After the massage Epstein stated to at he understood she was not comfortable, but he would pay her if she brought over some girls. He tot 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. dated she had brought the following girls: said that at the time she brought these girls to Epstcin'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 possibly naked, and allow some touching. I asked her it as aware. She stated every girl she brought knew what to expect. She explained she knew that■ want make money. She approached nd 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 .at her house. tated that at that time she was driving a red pickup truck. They traveled ein's house and entered t u the kitchen door. They met with the house chef and Epstein's assistant .' as introduced to Epstein while they were in the kitchen area. ed.ipstairs and Epstein went upstairs. When the massage was over turned to the kitchen area. stated she was paid $200.00 for bringing.to Epstein's house. stated Mtold her she was paid $300.00 for the massage. d ated that vas the last erson 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 ne foregoing instrument was sworn lu or affirmed -----State-of-Florida￾before me this 1" day of May, 2006 by County of Palm Beach Det Joe Recarey, 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 EFTA00231922 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 when he was going to travel to Palm Beach. d en when Epstein announces to his assistant, that he is traveling to Palm Beach,eould t en oc ntact_ to arrange girls to "work" for Epstein. stated that once her arents discovered that she was visiting Epstein, they disapproved of the encounters wt m and she stopped. er stated tha=till tries to call house and leaves messages. Sgt Frick entered the room and explained to . hat 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. Asnas 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). =vas dropped off at her house without incident. On October 3, 2005, Sgt Frick and I went to speak with a sixteen year-old female who was brought to Epstein's residence ban' We met with other at their front door. We explained the ongoing investigation and asked to speak with Mas we had in ormation that she had "worked" for Jeff. 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 ,was advised we would be speaking with her. She expressed 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. 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. oft my tel c hone t number and advised should she wish to speak with me again to telephone me. Sgt Frick and I thanked Mrs or her time and left the area. She stated she would askillagain 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 Dawson 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 High School. ome and met with and stated • year ago tated she knows She was told she could make money working -- Thrforegatnrinstrumentwas sworn to-er affirmed before me this I' day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida County of Palm Beach Signature/Arresting Officer Date: 05/01/2006 Page of 22 EFTA00231923 Probable Cause Affidavit Palm Beach Police Department Agency ORD FLO 500600 for Jeff. She was told she would have to rovide a massage to Jeff. Mi stated t upon her arrival to the house she was brow t to the kitchen area by They met with the house c of who was alread in the kitchen area. tated....would wait for her in the kitchen. was introduced t Jeffs assistant, who brought her upstairs to the master bedroom. repared the room and massage table for a massage. Epstein entered the room wearing only a towel s e provided a massage. tated she kept her clothes on during the massa e. She advised sometime during the massage, Epstein gra ed her buttocks and pulled her close to him. . said she was uncomfortableilincident involving Jeff. At the conclusion of the massage, she was pal 00 for the massage. I asked 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 d received money for taking her there but was unsure in the returned to Epstein's house on another occasion withand another irl she waited in the kitchen with while-was taken upstairs b massage once as she was uncom orta le with the whole experience. At the conclusion of the interview, the tape was stopped. I was informed thataad 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 o call her back reference the police questionin provided the incoming to ep one number about the police investigation because had called her to to I er 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 famiavisit Epstein. be asking questions. stated asked her what was oin on at the house that the police would then called Jeff and and asked what was going on reference the ongoing police investigation. Accordin to IMI as since then been trying to contact her to ask about thepolice questions. I instructed not to contact and do not provide any more information to she would notify Jeff Epstein and'. what was transpiring. On October4, 2005, I made telephone contact withilwho 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 p[ tated the following: approximately a year ago, when sh of ageaook her to Epstein s ouse twice. She knows _because they both attend High School. The first time she went, IMMEdrove to the house. They entered through the kitchen area where she was tated she tated tated s e on y did the tated she inadvertently told i he foregoing lusu uweut wdsSW tate-of-Florida before me this day of May, 2006 by County of Palm Beach Det Joe Recarey, 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 EFTA00231924 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 introduced to and Epstein. She was taken upstairs to a bedroom b ho 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 'Ito 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 sifting in the kitchen and told her "let's go." tdvised she received no money for that day. lso 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, .at in the kitchen anaook her upstairs tote 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 .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. When became upset again and told Epstein she didn't want to be touched. Ildiscontinued the massage and was paid $200.00. *hen went downstairs where as waiting for her. She tot he wanted to leave. aid she never returned to the house. tated she is aware that her friend, was also at the house and had a problem with Epstein. I later researched and met with her at her residence. Durin a sworn ',statement, High School tated the following: on or about November 2004, she was approached at 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. Sicked 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 High School student and-came with them. They were brought into the kitchen where she was introduced stein 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 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. 'idn'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 affit and State_of Florida before me this 1" day of May, 2006 by County of Palm Beach Del Joe Recarey, 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 EFTA00231925 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 table, straddling Epstein to massage his back. While doing this her buttocks were touching Epsteins. was instructed to return to the ground at which time Epstein turned to have his chest rubbed. aadvised 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 massage table and turned it on. -fated Epstein began rubbing the vibrator over her thong underwear on her vaginal area. 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,IMMwas 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: I0 pm, Det Dawson 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. Mrs .advised she wanted to cooperate and consented to the interview. During a sworn taped statement,atated 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 ofand knew the same people. ad been previously told by her frien • I I II High School, what did for Epstein. called a person known to. and scheduled the appointment. _picked Eup and drove her to Palm Beach to a street ca . "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. Wu 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. ated that while going up the stairs and into the bedroom she observed numerous photographs of naked young girls.=Idimmed the lights and turned on soft music. IMF xited 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 so due to the tightness of the jeans and a tight belt. Madvised Epstein began to masturbate as she rubbed his chest. Epstein moaned as she rubbed his chest. She observed he was continuing to masturbate and — TrairreoThrt g ustrumunrwarsworn-to-or affirm before me this 1" day of May, 2006 by Det Joe Recarey, 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 EFTA00231926 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 attempted to reach up her tank top and touch her breasts. ulled back and Epstein stopped, however he kept masturbating until he climaxed. He cleaned himself wi the towel he was previously wearing. ■ was paid $200.00 for the massage and left the area. She met with 'ho 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 s they took another friend of I.....ltdvised 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 for....the house chef prepared hutch for them as it was almost lunchtime when they went. When...Ems finished with the massy e they left the area. I asked Eli f 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 ormal training in providing massages. =spoke about a third and last time she went to Epstein's house. drove another girl, ix te en years of age) who is ariend, to Epstein's house. Witted knew that =tad made money massaging Epstein and wanted to make money herself. ...litook them in the kitchen area of the house and introduced to andatook IIMIupstairs to the main bedroom. IN advised she doesn't know what happened as i not speak about what happened in the mom. eceived $100.00 froxafor going with her to Epstein's house and recommending■ On October 6, 2005, at 11:45 am, I met with t Lynn University and explained to her why we there to interview her. She advised she was aware o t to ongoing investigation. stated she had previously spoken wit ho told her she was interviewed by detectives. During a sworn taped statement, tated she knew a worked for Jeff Epstein in Palm Beach. advised she originally had beon taken to the Epstein house by whom she met when they both attended 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 so and Epstein would stop pushing the issue. Megan 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. •xplained The foregoing instrument was sworn to or affirmed State of-Florid' before me this 1" day of May, 2006 by County of Palm Beach Det Joe Recarey, 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 EFTA00231927 Probable Cause Affidavit Palm Beach Police Department Agency OM 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. Ho 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". awed 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 to ould call her for an appointment to "work". Each time she went would meet her at the kitchen poor area She would bring her upstairs and prepare the massage table. advised Epstein would ask her uestions about herself. Epstein knew she was a soccer player and would be attending Lynn University. I asked f Epstein knew her real Duna massage, she asked Epstein if she could borrow one of his vehicles to visit her family and boyfriend in age stated Epstein did and didn't care. The most recent massage she prow was on October 1, 2005. Orlando, 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 grabbed her buttocks and caressed the buttocks cheeks. I askedElf 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. aware of the vibrator but advised she never would allow him to use the vibrator 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. Instated that on October 3, 2005, she was contacted by Epstein's assistaawho informed her that Jeff 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 c ad missed appointments in the past because of her car being inoperable. explained the car is currently parked next to the Lynn University 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 Orlan o to atten co ege. I asked if she ever allowed another female in the room. IMpdvised no one was brought into the room with her. At the conclusion of the interview, Det Dawson 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 11, 2005, w/f was arrested by the Palm Beach Police Department me orego g before me this 1' day of May, 2006 by Det Joe Recarey, 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 EFTA00231928 Probable Cause Affidavit Palm Beach Police Department Agency OR1 FLO 500600 for misdemeanor possession of marijuana. During the arrestMtold 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 Dawson 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 t en she has gone to the house hundreds of times. Masted she became his "number one girl." She explained that on I her first visit she was brought to the house by fellow chool classmate, said she was brought through the kitchen area where she me for the first time. master bedroom, Epstein s room. explained that as she the stairs she observed several photographs of naked women al 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. Mxplained 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 getamfortable. . emoved her skirt and kept her shirt on. Epstein then instructed her to remove her shirt.. removed hersshirt 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. vised he turned over onto his back. Epstein touched her breasts and began to masturbate. Epstein ejaculated which meant the massa iiiir t the conclusion of the massage, as paid $200.00. They walked together downstairs where andavere waiting. stated received an unknown amount of money or mg er to Epstein. Epstein instructed to leave her cellular telephone number so that he could contact her when he is in town. .tated 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 Epstein would then began to masturbate himself and at the same time would insert his fingers in her vagina and masturbate her with his fingers. Mexplained Epstein would continue this process until he ejaculated. He would then utilize a vibrator/massa er on her vagina until ■ climaxed. advised that during her frequent visits, stein asked for her real ag tated she was sixteen. Epstein advised her not to tell anyone her real age. advised that thin s escalated wi the home as Epstein would instruct and pay.to have intercourse with his female friend, xplained the intercourse included using strap on dildos, large rubber penis' and other ern ad at his disposal. Epstein would watch them have intercourse and masturbate himself . Occasionally, Epstein would then join in 1 he foregoing instrument was sworn to or aff I med before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. of+leritla— County of Palm Beach Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00231929 Probable Cause Affidavit Palm Beach Police Department Agency ORIF FLO 500600 during the on female intercourse and provide oral sex to bothEan This occurred during the time as sixteen years of age. dvised 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 woo dplace appointments tor 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 in that no vaginal penetration would occur with his penis.. 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 ands he headportion. called Epstein's penis "egg-shaped." Estated Epstein would photo aph and her naked and having sex and proudly display the photographs within the home. unng one visit to Epstein's house in which she provided a massage to E stein his female friend, was also present. provided the massage in whic d her would fon e eac o ers reasts and kiss for Epstein to enjoy. Towards the end of this massage, Epstein grabbed nd turned her over onto her stomach on the massage table and forcibly inserted his penis into her vagina. stated Epstein began to pump his penis in her vagina. became upset over this. She said her head was being held against the table forcibly, as he continued to pump inside her. 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. Mtated she knows he still displays her photographs through out the house. On October 12, 2005, Det Dawson and I met wi who stated during a sworn taped statement, that nothing happened between her an pstem. appear nervous during the interview. I assured her that I have spoken with other people who advised differently. latated on several occasions she provided a massage to E stein. She stated she was brought to the Epstein house in March of 2005. classmate a Hi School, approached her and asked her if she wanted to "work". ade the arrangements with pstein's assistant. vho has no formal training in providing massages, stated she provided a massage, fully clothed for $200 I sensed hesitancy Il in her answers, I asked . f she had been contacted by anyone from Epstein's organizations or his house. an in uired about the police investigation, and left his telephone numbe fated she was interviewed already by a private investigator for E stein. He identified himself as ' or additional contact. rovided no additional information, as it appeared her responses were almost scripted. 1 he foregoing instrument was sworn to ur affil med before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. Statc 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 EFTA00231930 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 On November 6, 2005, at a roximately 3:30 pm, I met with at the Palm Beach Police Department. as identified as a potential witness victim u m ormation obtained during the trash pulls. Dunng sworn taped statement, vised she was at Jeffrey Epstein's house one time, approximately two months ago. She was approach y a girl ho was dating Ml oommate, for an opportunity to make some quick money. a vis s e ne ecl to make some quick cash to make the rent that month. She agreed to go to the house. She had been told by t the massage would have to be done in her underwear. She advis rove with her and brou 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, Hand m removedtheir clothing down to their anties, Epstein laid on his stomach area and they provided a massage on s legs and feet area. I ask f 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 andMontinued the massage until the last ten minutes of the massage, Epstein, told ao leave the room 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 al naked . E stein requested that Mil his chest area. Instated as she did this, Epstein, began masturbating. tated Epstein pu 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 rubbed the vibrator El vagina with the vibrator as e continued to masturbate. ...stated she was very uncomfortable during the on her vaginal area. dvised he never penetrated her vagina with the vibrator. He continued to rub her 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 pal 00.00 to for providing the massage. _was told to leave her telephone number wi for future contact. provided her cellular telephone number. was asked if she was recen contacted about this investigation by ar om the Epstein organization. She replied she was called but it was for work. She s was called by for her to return to "work" for Epstein. tated "work" is the term used by provide the massages and other things. 'dvised she ec me as she was not comfortable in prove ng that type of "work." On November 7, 2005, Det Sandman and I met with ring a sworn taped statement, stated she met Jeffrey Epstein through when they were still — allm-foregoing-instrument-Ins-swem-to-or-affirmed before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. Sheep 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 EFTA00231931 Probable Cause Affidavit Palm Beach Police Department Agency OFt10 FLO 500600 attendin High School. would approach females who wished to work for Epstein. tatcd 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 =land other females who were taken to Epstein's house to provide massages. further stated she had been to the house roximately 4 or 5 times in the past year. She accompanied 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 an require them to do anything extra, and they were not comfortable just to tell him and he would stop. EMstatedMEreceived $200.00 for each girl she brow t 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 E stein approximately two years ago when she was first approached b classmate at High School. I.Mapproached 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 da the arrangements were made. ad a also attended High School and was familiar wan pstein. ecalled s e was rou t there and entered through the back kitchen door. She had met with an assistan and another assistant rought her upstairs as she observed several photographs of naked females throughout the house. stated Epstein came in the room, wearing only a towel, and laid on the table. m tated he picked out the oils he wanted her to use and requested she remove her clothing toprovidehe massage. stated that on the first massage she provided she did not remove her clothing. ztated 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 large head. Epstein would rub the vibrator/massager on her vaginal area as he would masturbate. atated she had been to the house e fo, epilog lush uweat naa ono. n to or affirmed State of Florida before me this 1" day of May, 2006 by County of Palm Beach Det Joe Recarey, 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 EFTA00231932 Probable Cause Affidavit Palm Beach Police Department Agency ORD FLO 500600 numerous times. Ill= dded she has no form l• • 'n• providing a massage. tated she brought two female during her visits to rovide massages.A fated she brought a girl nam =tom High School. p tat ed she received $200.00 for eac girl s e roug . 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 sub'ect known to her as had asked her if she wanted to make money providing massages to Epstein. had heard that several girls from High School were doing this and making money. She agreed and was taken to the house by ad introduced her t and Epstein and brought her upstairs to a master bedroom where a massage ta e was prepared and the pr per oils were selected. Weft 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 "Iva s paid $200.00 by Epstein for bringing stated she had gone a total of 15 times to Epsteui s residence to provide a massage and things had escalated from just providing a massage. Epstein began touching her on her buttocks and grabbed her closer to him as he masturbated. Epstein also grabbed her breasts and fondled her breasts 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 penetrated her vagina with his penis and began having intercourse with her until he reached the point of climax. Epstein removed his penis from her vagina and climaxed onto the massage table. =received $350.00 for her massage. I asked her if she had any formal training in providing massages,atated she did not. =continued to state on one other occasion, Epstein introduced his girlfrien into the massage. _was brought into room with to provide a massage. Epstein had them kiss and fondle each other around the breasts and buttocks as 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 stroked the vibrator/massager on vagina as she provided the massage. On November 14, 2005, Det Sandman 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 house. On her first visit she was roug by a fellow student fro High School known to her approximately five or six times lso stated she was sixteen ears old when she first went to Epstein's The foregoing instrument was sworn to or afRs rut before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. ate of Florida County of Palm Reach Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00231933 Probable Cause Affidavit Palm Beach Police Department Agency GRIN FLO 500600 Militated Milbrought her into the house and she was introduced to then broug t er 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 tat Epstein was in town and would like her to "work". ated she returned to the house n was again led upstairs byi She provided the massage, clothed. as asked if she ever removed her clothing toprovide a massage. until the t time that she went that she removed her clothing. tated she -ratedd by that if not Epstein wanted her to come to work. She arrived at the house and was led u stairs be She start , providing the massage when Epstein asked her to remove her clothing. removed her pants, shirt and bra. She stayed in her at nties and continued rubbing Epstein. Epstein turned over onto his back and she rubbed his chest area. tated she knew he was masturbating himself as she providing the massage. the act he was masturbating. stated once the breathing relaxed he got up and told her to get tated she believed he climaxed based on his breathing. She did not want to view either the climax or dressed. She was paid $300.00 for her services. tated on the last time she went to provide a massage, she was notified b o come to the house and "work". 'tated she was now dating her current boyfriend an not eel 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. IMMIstated 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 ruining his massage. es stated although she had a falling out wi Epstein, she still received a Christmas bonus from Epstein. tatedshe was wired money from Western Union for her Christmas bonus. Subpoena results from es em nion revealed money was sent from Jeffrey Epstein on December 23, 2004. received $200.00 from Epstein for her Christmas bonus. urther stated that Epstein got upset as he wasn't bntinue and she would not be back. Epstein told her dvised she had no formal training in providing any massages. On November 15, 2005, Det. Sandman and I met with During a sworn taped statement, tated she met Jeffrey E stein over a ear ago. She was sixteen years of age and was approach y fellow 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 e fur egusug iusts u,uent-n as sworuto o. afFiri.ttd State-of Florida before me this 1" day of May, 2006 by County of Palm Beach . Det Joe Recarey, 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 EFTA00231934 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 massage topless. made the arrangements with Epstein and his assistants and took Ento 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 d■provided the massage on his legs, back and feet. Forty minutes into the massage, Epstein turn over onto his back and requested wait downstairs in the kitchen area for Epstein instructed Eno finish the massage. As at ot dressed, Mistartin rubbing Epstein's chest. left the room, and Epstein began masturbating as rubbed Epstein's chest. rated Epstein continued masturbating until he climaxed on the towel he was wearing. When asked if he h removed the towel she stated he turned the towel around so 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. s tressed 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 housc to it vide another massage. aigreed and the arrangements were made byeor 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 In 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 Ilibegan massaging his legs and back. As einished with Epstein's back and legs, Epstein then turned over onto his back. —tarred to rub his chest and he began m and began rubbing vagina and masturbating himself at the same time. estated she continued tomb his asturbating. As I&bed b his chest, Epstein leaned over and produced a massager/vibrator. He turned it on chest as this was occurring. She described the vibrator/massager as large grey with a large head. Epstein rubbed her vagina for approximately two to three minutes with the massager/vibrator. He then removed the vibrator from her vaginal area and concentrated on masturbating himself. Mated 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. aid she never returned to the house and had no desire to return to the house. ..was asked if she received an formal massage training. She advised she had no formal training. lavas asked if Epstein knew her real age. tated he knew, as he asked her questions about herself and high school. He was aware she attended, and is still attending High School. fhe foregoing lastr unit t wan 3wr rn-to-or-affirmed before me this 1" day of May, 2006 by County of Palm Beach Det Joe Recarey, who is personally known to me. Skate of Finrida Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00231935 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 t e messages were, "I have girls for him" or "I have 2 girls for him." These messages were taken b who signed the bottom of the messages. During the execution of the warrant, I located 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. Dawson and I met with During a sworn taped statement,Illstated that when she was sixteen years old she was taken to Epstein's house to provide a massage for money. Mated it was before Christmas last year (2004) when an associate,M approached her and asked if she needed to make money for Christmas. ade arrangements to take=to the house and drove ■to the house to "work." They were encount y a white female with long blond hair. as unable to er n 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 room 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 so that may ne foregoing lust. Iliiinnassworn to-era€firmed state of Florida before me this 1" day of May, 2006 by County of Palm Beach Det Joe Recarey, 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 EFTA00231936 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. Duriniarubbing of his back, Epstein asked her to get comfortable. He requested she remove her pants and shirt e 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 o rub his chest and pinch his nipples. As she be an to rub his chest, Epstein asked her questions about herself remembered telling him she attended 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 things. She continued rubbing his chest. Epstein reached up and unsnapped her bra from the front. -xplained the bra she used had a front snapping device. Epstein rubbed her breasts and asked her if she like having her breasts rubbed. aid "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 touched her breasts. explained Epstein then touched her vaginal area by rubbing her vagina with his fingers on the outside of her thong panties. Mensed 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 stroking her clitoris. Maid, "He commented how hard my clit was." He then inserted two fingers in her vagina and was stroking her within her vagina. She tried pulling back to pull out his fingers from within her vagina. Epstein removed his fingers from within her vagina and apologized for putting his fingers inside her. During this time, he kept his hand on her vaginal area and continued to rub her vagina.Mtated he rubbed her really hard as he was masturbating. Maid 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 'or 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. dated 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. tated she met Epstein when she was fifteen years of age. She was approached by a friend fro High School o be taken to Jeffrey Epstein's house to work. She was originally told she would be able The swora-to-or-affirmad before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. Statp of Flnridn County of Palm Beach Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00231937 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 to model linjirie for a wealthy Palm Beacher. =vas taken to Epstein's house located on El BrilloWay. introducedMto Jeffrey Epstein. Epstein had his personal chef prepare dinner foMnd At the conclusion of dinner,end Epstein broughtMpstairs into a master bedroom area. Mbserved a large massage table with a sheet on it. Epstein entered through a door and exited wearing only a towel. informed Mthat they were going to provide a massage on Epsteinflsked why were they doing this instead of modeling lingerie. explained tom that this was his routine and to rub his calves and feet. Epstein had toleto get comfortable. removed her pants and blouse. tated she stayed only in panties as she did not wear a bra that evening. tated while rubbing his calves and feet, Epstein turned over onto his back. Epstein told no rub his chest and rub his nipples. fated that as she started rubbing his chest, Epstein began masturbating himself . Epstein touched her breasts and stroked her vagina with his fingers. Epstein continued to masturbate himself as he stroked her vagina. Epstein ejaculated on his towel and paid IN $200.00 for the massage. E stein toldnhat if she told anyone what happened at his house that bad things could happen. d were 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 .to return to "work." Meturned to the house and was brought to Epstein s prepared the room for the massage. Epstein entered the room wearing only a towel. Epstein h clothing and provide the massage naked.Wegan rubbing his feet and calves and Epstein tumed over onto his back. Epstein rubbed her vagina with his fingers. Epstein began to masturbate himself with an upwards and downward motion on his penis. Epstein continued to touch her vagina 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. =vented 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 p 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 ouse and were led upstairs, through a stairwell from the kitchen area, by to Epstcin's bedroom. Epstein would then enter the room wearing only a towel, and ask them to get co o a e. The females would then provide the massage naked as Epstein would either touch their vaginas with his fingers and/or utilize the massager/vibrator on The-feregoing-instrumentwas sworn-to-or-affirmed before me this 1" day of May, 2006 by Det Joe Recarey, 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 EFTA00231938 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 their vaginal area. 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 1 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 r Epstein would meet with them. Rodriguez stated once the masseuses would arrive, he would allow em en into the kitchen area and offer them something to drink or eat. They would then be encountered by eith 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 our to be masseuses. He stated one time under Epstein's direction, he delivered a dozen roses t 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 ing-instrument-was-sworn to or affirmed State of Florida before me this 1" day of May, 2006 by County of Palm Beach Det Joe Recarey, 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 EFTA00231939 Probable Cause Affidavit Palm Beach Police Department Agency ORIF 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 High School afterahigh school drama performance. Also in that same note was direction to rent a car for Sand 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 d 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 show called￾uring the exact times and dat- w occurred. Is° coordinated 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 e to d the victims were made t prior to their arrival or during the time Epstein w in a m Beac . Therefore, as Jeffrey Epstein, who at the time of these incidents was fi 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 Je ey pstem 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 oflMi 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. TII P foragnittg-instrument-was-swocu-te-er-affir d Slate of Floc ida before me this 1" day of May, 2006 by County of Palm Beach Det Joe Recarey, 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 EFTA00231940 Probable Cause Affidavit Palm Beach Police Department Agency OFtln FLO 500600 Police Case#: 05-368 (2) Defendant: Race/Sex: White Female DOB: Charges: Principal in the la 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 I sexual battery investigation involving Jeffrey Epstein, Sworn taped statements were taken from five victims and seventeen wi esses 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 o perform massages for Epstein, for which eceived monetary compensation. During t e visa el would be introduced to Epstein's assistant, who in turn would record their telephone numbers and name. The vie ims wo 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 rub his fingers on their vaginas. On occasion, Epstein would introduce a massager/vibrator and rub the victims vaginas 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 and her f ' 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 High Sc , d did sexual favors for him. She also admitted that ad offered her an opportunity to make moneSig the beginning of the month of February explained that she was first approached by to go with her to E stein's house. latated that along with a Hispanic female, later identified at pick henat 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 ...Ind hereas MP foregoing instrument_wasswornaor affirmed State of Florida before me this 1" day of May, 2006 by County of Palm Beach Det Joe Recarey, 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 EFTA00231941 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 reportedl toldrhat 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 toMfather, rove 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 houseMtated that they walked up a driveway, past what ap ared 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. d 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 described Epstein as being approximately forty-five years old, having a long face and bushy eyebrows, with graying hair. Wild Epstein left the kitchen leaving Edone in the kitchen. They returned a short time later. ey a spoke briefly in the kitchen. Mwas instructed to folio pstairs. Ei recalled walking up a flight of stairs, lined with photographs, to a room that had e 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. Mrecalled 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 o take off her clothes.. stated Epstein was stem 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 so she took off her shirt caving her bra on. Epstein had removed his towel and told theCto take off everything. Mtated 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. AMegan to give Epstein the massage, he told her to get on his back. Instated she straddled herself on Epstein's back whereby her exposed buttocks were touching Epstein's bare buttocks. Maid Epstein was specific in his instruction to her on how to massa e him, telling her to go clockwise or counter clockwise. Epstein then turned over and instructed masae his chest. -,vas now standing on the ground and resumed massaging Epstein's c est area. Mtated 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 instrumanarstvonntronffirmed before me this 1" day of May, 2006 by Det Joe Recarey, 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 EFTA00231942 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 massage 9L_vaginal eeginal area. MS tated there was no penetration as the vibrator was on top of her underwear. ailed Epstein ejaculatin di because he had to use the towel to wipe himself as he got off the table. E. stein then left the room an of dressed. She went back downstairs where she met with 'd she was paid three hun dollars in cash from Epstein. Before she left, asked to cave r 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 assist with the investigation. At our direction conducted controlled taped phone calls to llular telephone 561 poke with Ifln an attempt to arran e another meeting with Epstein..asked • e need to do to make more money. red, "the more you do, the more you get pal . subsequent] called backen e a voice mail message for her indicating that she had set up an appointment fo 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 of the Sanitation Bureau of the Town of Palm Beach. The trash pull from April 5, 2005 revealed p message fa stein which stateamd name at 11:00 am. This was the time frame informed to be ready to go work at Epstein's house. On October 3, 2005, Sgt Frick and I went aresidence and viewed her vehicle parked in the driveway, a red Dodge Neon. Sgt. Frick and I knocked on the door and met with told that we were investigating a claim involving Jeffrey Epstein of El Brillo Way, in Palm Beach. vas 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 low she became acquainted with Epstein. stated that mapproximately a two years ago, just after she turned 17 years of age, she was approached by a friend named — t WI lake "s $200.00. nought about the offer and agreed to meet with Jeffrey. asked if she wanted to make money. S old she would have to provide a massage and Unknown last name) and (Unknown last name) pickedWirp and she was taken to Epstein s ouse. Upon her arrival to the house she was introduced to Eps em e kitchen of the -- Thrforegoing instrument was-sworn-to or affirmed State of /Ronda before me this 1" day of May, 2006 by County of Palm Beach Det Joe Recarey, 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 EFTA00231943 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 e massage table and covered the table with a sheet. She brow out the massage oils and em next to the massage bed. lin then left the room and inform 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 massageliptated "He tried to touch me and I stopped him." I asked how he tried to touch her. _stated ht at Epstein grabbed her buttocks and she felt uncomfortable. told Epstein, massage you but I don't want to be touched. IMIstated she performed the massage naked. At the conclusion of the massage, Epstein paid $200. After the massage Epstein stated to t 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. Ell tared she once tried to bring a 23 year old female and Epstein stated that the female was too old. fated that in total she only remembers six girls that she brought to see E ste' each time she was paid $200. stated she had brought the following girls: al6 year old female), M(a 16 year old female) and d that at the time she brought these girls to S tein's house the a1114 through 16 years of age. I asked _which one was the oungest. advised the youngest as she was fourteen when the massage occurred. 4ated 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 Mwas aware. She stated every girl she brought knew what to expect. She explained she knew that wanted to make money. She approachedand explained about going to work for Jeff, Intgreed and arrangements were made to bring her to Epstein's house on a weekend. ted that she and (Later identified as picked up t her house. that at that time she was driving a red pickup truck. They traveled to E tem s house and entered through the kitchen door. They met with the ho ef and aEli stein's assistant vas to Epstein while they were in the kitchen area. led rs and Epstein went upstairs. When the massage was over ereturned to the kitchen area. rated she was paid $200.00 for bringing -o Epstein's house. tednold her she was paid $300.00 for the massage. ted that .was the last person she brought to Epstein's house. She had changed her cellular num r 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 Eakannounces to his assistant= that he is traveling to Palm Beac wo en contact o arrange girls to "work" for Epstein. stated that once her parents 'scovered that she was visiting Epstein, they e foregoing instrument was-sworn-to or aftira before me this IM day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) date vi rruima County of Palm Beach Signature/Arresting Officer Date: 05/01/2006 Page of 22 EFTA00231944 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 id mmed of the encounters with him and she stopped. further stated tha= still tries to call house and leaves messages. Sgt Frick 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 placed within the vehicle to record any conversations within the vehicle. During the drive back to her home, de 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 Frick and I went to speak wi 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 s we had information that she had "worked" for Jeff. Mrs. Eno ed us entry into the home. We sat in the dining room and met wi As she was under the age of eighteen, Mrs. was advised we would be s' ing wi er. e expres r her daughter had information, she wanted to assist. We interviewed ho denied havin an 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 ppen . s the parents were present during the interview, we felt that Ewas 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 Frick and I thanked Mrs her time and left the area. She stated the would aslcM again after we left as to what happened at Epstein's house. I informed her thatEhad my telephone number and hopefully she would call. On October 4 2005 Det Dawson 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 stated she knows )ecatise they both attend High School. She was told she could make money working for Jeff. She was told she would have to provide a massage to Jeff. "Rutted upon her arrival to the house she was brow t to the Michey met wit t ehouse chef who was already in the kitchen area. tatedwould wait for her in the kitchen. was introduced toaff's assi an who irs to the master bedroom. prepared . ---- The-foregoing-instrument-warsworrrto m affir med before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. ate of a County of Palm Beach Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00231945 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 the room and massage table for a massage Epstein entered the room wearing only a towel and she provided a massage. ated she kept her clothes on during the massage. She advised sometime during the massage, rt n 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 masse ask 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 masse: stated received money for taking her there but was unsure in the amount. she return to Epstein's house on another occasion with d another girl. • ted she waited in the kitchen withehile en upstairs b stated she only did the massage once as she was uncomfortable with the whole experien nclusion of the interview, the tape was stopped. 1 was informed had attempted to reach is cell phone. 'cc mail messy e on October 4, 2005 at 10:59 am, revealed a female voice identified herself as who requested o call her back r questioning. rovided the incoming telephone num r as inadvertently to bout the police investigation becaus about how she just received a rental car from Jeff Epstein. given a rental car, a 2005 Silver Nissan Sentry; to utilize to visit amily and visit Epstein. her what was going on at se that the police would be asking questions. . then called Jeff and and asked what was going on reference the ongoing police investigation. .cordin to since then been trying to contact her to ask about the lice uestions. I instruct nd do not provide any more information to she would notify Je was transpiring. On October4, 2005, I made telephone contact witlawho 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 s 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 ecause they both attend Royal Pal B School. The first time she wen ove to the house. They entered throw the kitchen area where she was introduced to and Epstein. She was taken upstairs to a bedroom ho 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 jatried to remove her shirt, at which point she became very upset and discontinued the massage. Both Mud Epstein had a verbal disagreement, at which time she left without nee the police tated she ed her to tell her her to tell her that she was e foregoinginstrmiteirrwas-sworirto-or-a no before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. ate 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 EFTA00231946 Probable Cause Affidavit Palm Beach Police Department Agency Offlit FLO 500600 being paid. She got with ho was sitting in the kitchen and told her "let's go." advised she received no money or t at ay. t1so said that ad 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 othe more gal get paid. Illidvised that several weeks later she agreed to be taken a second time by nce 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 brow 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 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 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 02/08/1987, and met with her at her residence. During a sworn ed statement, stated the following: on or about November 2004, she was approached at 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 l 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 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 table, straddling Epstein to massage his back. While doing this her buttocks were touching Epstein. 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 massage table and turned it on. stated Epstein began rubbing the vibrator over her 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 me. State o lorida County of Pahn Beach Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00231947 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 thong underwear on her vaginal area. 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 Dawson and I met with 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. Mr. 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 High School, what did for Epstein. called a person known to as d 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 driveway. They entered the kitchen area of the house and met with Epstein. was introduced to Jeff Epstein. 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 exposing her belly area. During the massage, Epstein removed his towel and laid on the massage table naked. As. rubbed Epstein's chest 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 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. The foregoing instruWwas sworn to or affirmed before me this 1" day of May, 2006 by County of Palm Beach Det Joe Recarey, 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 EFTA00231948 Probable Cause Affidavit Palm Beach Police Department Agency ORM PLO 500600 then explained she never provided another massage for Epstein. She did however, go to the house with and present when area with as they took another friend of • advised she was went to work for Epstein. She advised she rode over and sat in the kitchen 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 ever told her what would be expected when she provided a massage. stated yes, r that a massage would be expected, possibly naked and possibly some touching involved. mal 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 Epstein and wanted to make moSerself. took them in the kitchen area of the house and introduced. to an ok upstairs to the main bedroom. advised she doesn't know what hap. as did not speak about what happened in the room. received $100.00 from for going with her to Epstein's house and recommending. On October 6, 2005, at 11:45 am, I met with dot at Lynn University and explained to her why we there to interview her. She advised she was aware of the ongoing investigation. stated she had previously spoken will who told her 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 attend High School. She began going to the house when she was sixteen years of age and stated the 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 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 maccagerivibrator on her. drove to the house for the massage. left Maier cell phone number and every time stem would come into town, ould call her for an appointment to "work". Each time she went would meet her at the kitchen oor 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 Joe Recarey, 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 EFTA00231949 Probable Cause Affidavit Palm Beach Police Department Agency OM FLO 500600 about herself. Epstein knew she was a soccer player and would be attending Lynn University. 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 Orlando, 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 grabbed her buttocks and caressed the buttocks cheeks. 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 use the vibrator 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 assistan who informed her that Jeff Epstein had rented her a new Nissan Sentra and she should come by the ouse o pick it up. e formed. 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 Lynn University Gym field. I asked her if she ever took an one to the house. explained she took , a friend of hen who attended High School, who has relocated to Orlando 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 Dawson 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 11, 2005, w/f. was arrested by the 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 name and cell phone number. On October, 11, 2005, Det Dawson and I met with. and obtained a sworn taped statement. MI 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 ' " e girl." She explained that on her first visit she was brought to the house by fello High School 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 me. State 01} fonds County of Palm Beach Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00231950 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 classmate said she was brought through the kitchen area where she me or first time. was was led to the master bedroom, Epstein s room.. explain as she ing up the stairs she observed several photographs of naked women alon the walls and tables of the house.. further explained that she was brought into the bedroom, whe repared the room by setting up the massage table and provided the oils for her to rub on Epstein. exp ained 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 touched her breasts and began to masturbate. Epstein ejaculated which meant the massage was onclusion 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 massage his chest area. stated Epstein would then began to masturbate himself and at the same time would insert his fingers in her vagina and masturbate her with his fingers. explained Epstein would continue this process until he ejaculated. He would then utilize a vibrator/massager on her vagina until climaxed. 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. advised that things es e as Epstein would instruct and pay. to have intercourse with his female friend explained the intercourse included using strap on dildos, large rubber penis' an pstein had at his disposal. Epstein would watch them have intercourse and masturbate himself . Occasional) E stein would then join in during the female on female intercourse and provide oral sex to both. an This occurred during the time. was sixteen years of age. advised this continued to escalate during two years. The routine became familiar to. Epstein's assistant iould telephone her every time Epstein was in the Town of Palm Beach and would place appointments or 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 with his penis. 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 Joe Recarey, 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 EFTA00231951 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 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 naked and having sex and proudly display the photographs within the home. n one visit to Epstein's house in which she provided a massaetE his female friend, also present. provided the massage in whic d her would fon and kiss for Epstein to enjoy. Towards the end o Epstein grabbed and turned her over onto her stomach on the massage table and forcibly inserted his penis into her vagina. • stated Epstein began to pump his penis in her vagina. ■ became upset over this. She said her head was being held against the table forcibly, as he continued to pump inside her. 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 Dawson and I met with dob ho 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 E stein. She stated she was brought to the Epstein house in March of 2005. a classmate a 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 prow ed 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'IM 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 girl, 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 e fm cgumg instrument-was sworn-to-or affirmed are of rru before me this 1" day of May, 2006 by County of Palm Beach Det Joe Recarey, 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 EFTA00231952 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. 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 room 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 nab his chest area. stated as she did this, 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 rubbed the vibrator on her vaginal area. advised he never penetrated her vagina with the vibrator. He continued to nib her 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 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 fsa_twiding the massage. was told to leave her telephone number withinfor future contact. IMI 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 b dilif or her to return to "work" for Epstein. stated "work" is the term used beo provi e t e massages and other things. advised she declined as she was not comfortable in providing that type of "work." stated she met Jeffrey Epstein through. when they were still . High School. would approach females who wished to work for 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 approximately 4 or 5 times in the past year. She accompanied with 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 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 On November 7, 2005, Det Sandman and I met with d b During a e foregoing ns mem-was-swam-to oraftirmetl State of Florida before me this 1" day of May, 2006 by County of Palm Beach Det Joe Recarey, 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 EFTA00231953 Probable Cause Affidavit Palm Beach Police Department Ageacy ORIN FLO 500600 youngest, she replied, IN 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 gnarl( 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 at the Palm Beach Police Department. During a sworn taped statement, stated she had met E stein a two years ago when she was first approached by a classmate at High School. approached her about working for Epstein and providing a massage to hint for $200.00. had made the arrangements however was unable to take her the da the arrangements were made. had take also attended High School and was familiar with Epstein. recalled she was brought there and entered through the back kitchen door. She had met with an assis and another assistant brought her upstairs as she observed several photographs of n emales throughout the house. stated 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 macqlge. 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 large head. Epstein would rub the vibrator/massager on her vaginal area as he would masturbate. stated she had been to the house numerous times. added she has no formal training in providing a massage. stated she brought two females during her visits to rovide maQqages. stated she brought a girl named and from 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 had asked her if she wanted to make money providing massages to Epstein. had heard that several girls from High School wert.ilang this and making money. She agreed and was taken to the house by had introduced her an. d Epstein and brought her upstairs to a master bedroom where a massage table e foregoing instrument was sworn to-or-affirmed before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. tale of I a County of Palm Beach Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00231954 Probable Cause Affidavit Palm Beach Police Department Agency OR1F FL() 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 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 provide a massage and things had escalated from just providing a massage. Epstein began touching her on her buttocks and grabbed her closer to him as he masturbated. Epstein also grabbed her breasts and fondled her breasts 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 penetrated her vagina with his penis and began having intercourse with her until he reached the point of climax. Epstein removed his penis from her vagina 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. eras brought into room with to provide a massage. Epstein had em 'ss and fondle each other around the breasts and buttocks as they provided a massage to Epstein. Epstein, watched and masturbated as this occurred. On other occasions, Epstein, introduced the large white vibrator/massager in the massage. Epstein stroked the vibrator/massager on vagina as she provided the massage. On November 14, 2005, Det Sandman 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 High School kno stated brought her into the house and she was introduced en brought her upstairs into a master bathroom, located within the bedroom. stat e 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 e massage. said each subsequent time she went to the house, she was notified that Epstein was in to would like her to "work". stated she returned to the by house and was again led upstairs b She provided the massage, clothed. was asked if she ever removed her clothing to provide a massage. stated it was not until the third time that she went that she removed her clothing. stated she was n t Epstein wanted her to come to work. She arrived at the house and was led upstairs b ed providing the massage 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 me. -- Staii 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 EFTA00231955 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 when Epstein asked her to remove her clothing. removed her pants, shirt and bra. She stayed in her thong panties and continued rubbing Epstein. Epstein turned over onto his back and she rubbed his chest area. 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. dressed. She was paid $300. massage, she was notified by dating her current boyfriend 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 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 mining his massage. advised she had no formal training in providing any massages. . mstated 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. stated once the breathing relaxed he got up and told her to get jces. stated on the last time she went to provide a come to the house and "work". stated she was now comfortable going. She recalled it was approximately On November 15, 2005, Det. Sandman and I met with. dob During a sworn taped statement,. stated she met Jeffrey E stein over a ear ago. She was sixteen years of age and was approached by a fello 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 massage topless. 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 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 the massage, Epstein turned over onto his back and requested 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. rubbed Epstein's chest.. 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 so that the opening would allow him to expose himself. After he cleaned himself off with the 1 he toregomg instrument was sworn to or attained before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. State of Fionda County of Palm Beach Signature/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00231956 Probable Cause Affidavit Palm Beach Police Department Agency ORI# 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 approached by advised if she wanted to return to the house to provide another massage.. 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 by one of the staff members. led her upstairs the master bedroom and master bathroom area. left . this time to do the maccage 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 massaging his legs and back. As. finished with Epstein's back and legs, Epstein then turned over onto his back.. started to rub his chest and he began masturbating. As. 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 continued to rub his chest as this was occurring. She described the vibrator/massager as large grey with a large head. Epstein rubbed her vagina for approximately two to three minutes with the massager/vibrator. He then removed the vibrator from her vaginal area 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 massage training. She advised she had no formal training. was asked if Epstein knew her real age.. stated he knew, as he asked herquestions about herself and high school. He was aware she attended, and is still attend* 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 e fu, tg,tillIg lusts umentwas swornixr or-affirmed us I before me this 1" day of May, 2006 by County of Palm Beach Det Joe Recarey, 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 EFTA00231957 Probable Cause Affidavit Palm Beach Police Department Agency ORIF PLO 500600 messages were taken b who signed the bottom of the messages. During the execution of the warrant, I located 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. Dawson 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 so 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. MI removed her shirt and pulled her pants off. MI 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 began to rub his chest uEpstein asked her questions about herself. remembered telling him she attended 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 things. She continued rubbing his chest Epstein reached up and unsnapped her bra from the front. explained the bra she used had a front snapping device. Epstein rubbed her breasts and asked her if she like having her breasts rubbed. 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 touched her breasts. explained Epstein then e fureguinginstr umentwas-sworn-to-or-affirmed ate ofFlorida before me this 1" day of May, 2006 by County of Palm Beach Det Joc Recarey, 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 EFTA00231958 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 touched her vaginal area by rubbing her vagina with his fingers on the outside of her thong panties. E 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 stroking her clitoris. Esaid, "He commented how hard my clit was." He then inserted two fingers in her vagina and was stroking her within her vagina. She tried pulling back to pull out his fingers from within her vagina. Epstein removed his fingers from within her vagina and apologized for putting his forgers inside her. During this time, he kept his hand on her vaginal area and continued to nib her vagina Estated he rubbed her really hard as he was masturbating. Esaid 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 sec 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 Estated she did not. 1. 1stated 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 fro 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 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. that they were going to provide a massage on Epstein.. 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. II 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 nipples.. stated that as she started rubbing his chest, Epstein began masturbating himself . Epstein touched her breasts and stroked her vagina with his fingers. Epstein continued to masturbate himself as he stroked her vagina. Epstein ejaculated on his towel and paid. $200.00 for the massage. 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 I he foregoing instrument was sworn to or affirmed State of Florida before me this 1" day of May, 2006 by County of Palm Beach Det Joe Recarey, who is personally known to me. Signature/Arresting Officer Signature of Police Officer W.S.S. 117.10) Date: 05/01/2006 Page of 22 EFTA00231959 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 who coordinated fo 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 rubbed her vagina with his fingers. Epstein began to masturbate himself with an upwards and downward motion on his penis. Epstein continued to touch her vagina with one hand and masturbate with the other hand. Once Epstein ejaculated onto the towel he was wearing, the massage was over. In was paid $200.00 for the massage. Epstein again told IN 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 pro ' e 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 get comfortable. The females would then provide the massage naked as Epstein would either touch their vaginas with his fingers and/or utilize the massager/vibrator on their vaginal area. 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 1" day of May, 2006 by Det Joe Recarey, 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 EFTA00231960 Probable Cause Affidavit Palm Beach Police Department Agency ORIN 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. Rodri ez 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 o to be masseuses. He stated one time under Epstein's direction, he delivered a dozen roses to 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 mm-cages and would discover maccagers/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, 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 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. Specifically, The phone records showed ■ called during the exact times and dates when victim advised the incident occurred. also coordinated the encounters with.. 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 foregomg instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det Joe Recarey, 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 EFTA00231961 Probe:hie Cause Affidavit Palm Beach Police Department Agency OEM 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 with his penis or digitally withlrn and who were minors at the time this occurred, and who at the time of the incident was fifty two years of a 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 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 Joe Recarey, 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 EFTA00231962 0 I EFTA00231963 t REQUEST FOR WARRANT DEFENDANT: Jeffrey Esptein DATE OF BIRTH HABITUAL OFFENDER: YES NO MICA VICTIM RELATED / ACQUAINTED WITH DEFENDANT? AGENCY CASE NUMBER: 05.368 (I ) LEAD OFFICER: Det. Joe Recaery AGENCY: PALM BEACH POLICE DEPARTMENT CURRENT SHIFT HOURS: 8 am TO 5 pm YES /IX 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: FILING DOCUMENTS ATTACHED: X ARREST FORM Y P.C. AFFIDAVIT (2 COPIES) lC s I EVIDENCE LIST PRSiauSly WITiaen I ASA eLDItibApaL. SWORN STATEMENT OF MATERIAL WITNESS(ES) "/C OFFENSE REPORT (2 COPIES) ACCIDENT REPORTS (ALL) WITNESS STATEMENTS (ALL) Y FCIC/PKIC CRIMINAL HIST0a9: 11; 4101 CrWeA Ss (361.014VO4 REQUEST FORCONVICTION RS NiC PROPERTY RECEIPT Pars; given Asa Fon.o kcit,45,14. VEHICLE TOW RECEIPT OTHER ATTACHMENTS INCLUDE: INITIAL FOR COMPLETENESS: JR OMCER 7915 050106 ID! IDI DELIVERED BY: Recarev r%Wle n crizir RECEIVED, STATE ATTORNEY'S OFFICE ON: Bot.. .V.‘i DATE S -LA -c) DATE TO EFTA00231964 tu > PFLOISIOICIA6,010 ,E d a 06TS Number f i l i a l I i l l_ ARREST/ NOTICE TO APPEAR i meet 3 Request bar Warrant Juvenile Referral Report 2 N TA 4 ROOMellOr Cape ri Amnia, Agercy ORI Number AOWCY Woe PALM BEACH POLICE DEPARTMENT Pomo, Raw Numbs (14.T.00.1 only) 7ta • 1 H i , , 1 i III i_ I) prajimafty 0 I. Remy 0 3. 1•Tadomeanor ❑0 5. Ordnance it Weapon Seized a00/Y. 0 2- Tragic FROM 0 A Trek laildinalanor 0 6. 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Malcie) _ Race _ Dew d Bann ❑ 1. 1Attahre.4eW i 8 —37Feicerc :4. LledeineanOf 7. 5. Juvenile 2 I Name 310 (Feld DIOdel p mt Na oats. ReselenCe Phone ) Adana* (Stmt. AN. akeroar) ICAY) (Stew (T;O) Business Phone I ) TOT JAC Da* tens The above SS was prcradael by 100011ndifil altift, 0 delOACIIMS wens_ The child and / ot parent was too to keep the Amalie Carl ORIN QM. (Phone 355-2526) witen4001 an el aDdrelia jp Yet. bY. MUM) 0 Na (Reason) school Aureed Grade Properly Crone 0 Yes 0 No J Descapeon of Property Vikie of Property Frar" R. BA P. Possess T. I c R. Snuggle K Dowse 1.1 Manulachre, _ D. Over 0,SIntvle S Us, I rher 'vale DUI) Type . ti NA A. AsThrliaMine I. itinutato H 1.8.4so Aver. P Paradhema OXa ne M. Memel. quprneril Hiroo, 0 Opum/Deny S S tar L Unknown Z. Otner nes CHARGE Charge Description • '. Counts l oDomestic . Viall.finaN Statute Votellon Number :i_ 1 ' '1I_ - a 1 , 1(1 i i I 11 Volabon of ORD sr Drug Active/ Dna? Type Amount/ Unit Owens. a Warren/Colds Feint Bond w Charge Desotpbon Counts Domestic 61:4 71N Spada atolaeon WINS : L I 1.1_• J I 1 I (I t I 1 I N on OP ORD a ) Drug AS'1y I Ortop Type Arrouni /Una Orem* s Warrant /Capra; Nwnter Bond 1C, Charge Deactletion Course _I:IVOR Domestic Wine 1 Statute Notation Minter i l l:1 1 1 1 10 1 1 E ) %elation of OAD I Cepa MOWN Ong Type Amount/ UM Menu I Wprent I Capas Nolte( Baal w 1 Charge Deacelaion Coins Domestic Malcom °YON &Mule Aolillial Minter i t n i l i M i l l potation of ORO a ill Drug Actrety Drug Type I Amount / Una Oer6e a Warrant/ Capas Nurtsir Bond O ineNdlon No. I MaRSTAcrYAretearanc• in Coun n No 2 Location (Court. ROW, Naimbee McNeal Ineirutakel NOTICE TO ARil You need n aws in GAM tut mis comply with estructele on Rennie Side. Coon ore Mier Mon, Day Veer Ilene AM. P.M. I AGREE TO APPEAR. THE TIME AND PLACE DESIGNATED TO ANSWER THE OFFENSE CHARGED OR TO PAY THE FINE SU&SCRIBE 0 I UNDERSTAND THAT SHOULD I WILLFULLY PALTO APPEAR BEFORETtr...OURT AS REQUIRED BY TallS NOTICE TO APPEAR, THAT I MAY OE HELD IN CONTEMPT OF COURT AND A WARRANT FOR MY ARREST SHALL BE ISSUED. Swain of Ditimdara (or Juvirele end Parent ICtisiocian)‘ Dale Se30. 3 i C3 a HOLD for caw/Agency Name, $wam of Arreetieg Caw x Name Veraostion (Printed by Arresatol DaNWOUS O MIMES Amt en dIArresang Once (Ping It . (PRINT) O sass O Other. PAGE DlipAY 1.D. II Porta lisesporarg Olitar I 0 1 A020cM Intake Winn bee d SAKI SOW lelln lic -r. _OE DISTRIBUTION: MITE — COURT COPY GREEN — STATE ATTORNEY YELLOW — AGENCY P1M —.AIL GOO • DEFENDANT (RYAS ONLY) EFTA00231965 i ADMINISTRATIVE I Girt mance ARREST/NOTICE TO APPEAR i Aires 3 Roam lo, VIA",i''' I I o ( L 1 I I Juvenile Referral Report 2 N T A 4 Reltalel lot Cepa i---1 ,,,,A,...E. n Agency ORl Number FLOI5i0a0.6L0,0 Agency Name [Agra? 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THAT I MAY BE HELD IN CONTE OF COURT AND A WARRANT FOR MY ARREST SHALL BE ISSUED. Scutum of oilmen Me Jennie and Parent /Came) Dam, Signed ‘ HOLD to other Agency None: Sgnature at Arresting Mar x Name Wrricabon (Printalby MANE 0 oanowas 0 Rtillifitd MOM Name of A/reeling Olice (Prot) ID. a (PRINT) 0 Suicidal 0 Otter PAGE make Deputy I D • Pouch Tramping Caw A0.! Ageral Witneas to et subject coned wee an 'A' OF _ D4STRIBUTON: WHITE — COURT COPY GREEN — SATEEN:0NET YELLOW — AGENCY PINK —JAIL GOLD - DE40404:4' +I TA's ONLY EFTA00231966 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 Police Casa: 05-368 (1) Defendant: Jeffrey Epstein Race/Sex: DOB: alb Charges: 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 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 clothing to provide the massage. As the victims complied and provided the massages, Epstein would rub his fingers on their vaginas. On occasion, Epstein would introduce a massager/vibrator and nib the victims vaginas 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. I. 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 .s boyfriend and classmate at 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, IN explained that she was first approached by to go with herto Epstein's house. • stated that along with a Hispanic female, later identified at pick her up at her father's house on a Sunday. IN 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 Signature of Police Officer (F.S.S. 117.10) 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 me. County o Pal Beach Signat ting Officer Date: '1/2006 Page 1 of 22 EFTA00231967 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 conversation occurred between and. whereas reportedly told. that if Jeff asked her age, 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. 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 • IN 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 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. to take off her clothes.. stated Epstein was stern 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 so 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 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 Epstein the massage, he told her to get on his back.. stated she straddled herself on Epstein's back whereby her exposed buttocks were touching Epstein's bare buttocks.. 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 toot ---"-iffirrai State-o€-Florida before me this 1" day of May, 2006 by County o alm Beach Det Joe Recarey, who is personally known to me. Signat ting Officer Signature of Police Officer (F.S.S. 111.10) Date: 0 1/2006 Page2of 22 EFTA00231968 Signature of Police Officer (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency ORO FLO 500600 massage vaginal area. • stated there was no penetration as the vibrator was on top of her underwear. recalled Epstein ejaculating because he had to use the towel to wipe himself as he got 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._ 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 561- . • spoke with in an attempt to arrange 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 subsequently called back. and left a voice mail message for her indicating that she had set up an appointment for a 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 Frick and I went to residence and viewed her vehicle parked in the driveway, a red Dodge Neon. Sgt. Frick 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 o or affirmed before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. County of Palm Beach Signs hog Officer Date: 1/2006 Page3of 22 EFTA00231969 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 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 hint During the massage, stated "He tried to touch me and I stopped him." I asked how he tried to touch her. stated that Epstein grabbed her buttocks and she felt uncomfortable. told Epstein, I'll massage you but 1 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 brought to see Epstein, each time she was paid $200. stated she had brought the following girls: ( al6 year old female),. (a 16 year old female) and said that at the time she 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 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 tastein'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 to or atilt Iliad State of Mari& _ before me this 1" day of May, 2006 by County of Pi Beach Det Joe Recarey, who is personally known to me. I(--1010 Signature of PoliceOfficer{F.S.S. 117.10) Signatur ng Officer Date: 0 06 Pagel-lot 22 EFTA00231970 Probable Cause Affidavit Palm Beach Police Department Agency OR1N 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, they disapproved of the encounters with him and she stopped. further stated that still tries to call house and leaves messages. Sgt Frick 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 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 Frick 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. Mrs. 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, Mrs l was advised we would be speaking with her. She expressed 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 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 Frick and I thanked Mrs.. 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 Dawson and I drove to the home and met with and 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 atten High School. She was told she could make money working The foregoing instrument was sworn to uraflfn before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. '1 1# Signature of Policeefficer (F.S.S. 117.10) Signatur Date: 05 i 1 i 06 PageSof 22 EFTA00231971 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 for Jeff. She was told she would have to provide 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 kept her clothes on during the massage. She advised sometime during the massage, Epstein 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 massage. 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. 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 to call her back reference the police questioning. 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 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 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 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. stated she inadvertently told On 0ctober4, 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 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 affirm before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer .S.S.117.10) County of Palm Beach Signatur Date: 05 06 g Officer Pagekof 22 EFTA00231972 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 Epstein 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 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. 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 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 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 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 High School students IN and (MI 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 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 swus r-affirmed before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of PoliceOfficer .S. 117.10) State of Florida County of Palm B Signatur Officer Date: 05/0 Pagel of 22 EFTA00231973 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 table, straddling Epstein to massage his back. While doing this her buttocks were touching Epsteins. 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 massage table and turned it on. stated Epstein began rubbing the vibrator over her thong underwear on her vaginal area. 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 Dawson and I met with. dob , at her residence. As E 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. 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 a and knew the same people. had been previously told by her friends from aigh 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 driveway. They entered the kitchen area of the house and met with Epstein. E was introduced to Jeff Epstein. led E 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. IE 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 E rubbed Epstein's chest 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 oraffirm before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. County of Palm Beach Siguteature .-c----2.. of Police -nficer .S.S. 117.10) Date: 0 06 Signatu ing Officer Page8of 22 EFTA00231974 Probable Cause Affidavit Palm Beach Police Department Agency ORIN PLO 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 explained 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 . 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. I. has no formal training in providing massages. • spoke about a third and last time she went to Epstein's house. drove another g,irl,M (sixteen years of age) who is IM friend, to Epstein's house.. stated. knew that • had made money massaging Epstein 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. MI received $100.00 from for going with her to Epstein's house and recommending . On October 6, 2005, at 11:45 am, I met with dob at Lynn University 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 Jeff Epstein in Palm Beach. advised she originally had been taken to the Epstein house by whom she met when they both attended 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 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--- ---StateitElorida before me this 1" day of May, 2006 by County of Palm Det Joe Recarey, who is personally known to me. Signature of Police(ffi recr S. 117.10) Signature Date: 05/0 Officer Paget' of 22 EFTA00231975 Probable Cause Affidavit Palm Beach Police Department Agency O111# 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 Epstein would try to touch her more and on one occasion he at-to ted 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, would meet her at the kitchen door area. She would bring her upstairs and prepare the massage table. advised Epstein would ask her questions about herself. Epstein knew she was a soccer player and would be attending Lynn University. 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 maggAge, she asked Epstein if she could borrow one of his vehicles to visit her family and boyfriend in Orlando, 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 grabbed her buttocks and caressed the buttocks cheeks. 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 use the vibrator 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 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 Lynn University Gym field. I asked her if she ever took any one to the house. explained she took a friend of hers who attended High School, who has relocated to Orlando 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 Dawson 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 11, 2005, w/fIM dob was arrested by the Palm Beach Police Department The foregoing instrument was sworn to or a rme before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. c Signature of Police•Officer (F.S.S. 117.10) County of Palm Beach Signat e A ing Officer Date: /2006 Pagel(bf 22 EFTA00231976 Probable Cause Affidavit Palm Beach Police Department Agency ORIN 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 Dawson 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 Hi h School classmate, MI said she was brought through the kitchen area where she me or the first time. iwas 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 the walls and tables of the house. MI further explained that she was brought into the bedroom, where 'repared the room by setting up the massage table and provided the oils for her to rub on Epstein. explain 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 touched her breasts and began to masturbate. Epstein ejaculated which meant the m 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 or ng er 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 massage his chest area. stated Epstein would then began to masturbate himself and at the same time would insert his fingers in her vagina and masturbate her with his fingers. explained Epstein would continue this process until he ejaculated. He would then utilize a vibrator/massager on her vagina until. climaxed. 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. advised that thin s escalated within the home as Epstein would instruct and pay. to have intercourse with his female friend, explained the intercourse included using strap on dildos, large rubber penis' and other evices at pstein had at his disposal. Epstein would watch them have intercourse and masturbate himself . Occasionally, Epstein would then join in The foregoing instrument was sworn Tto fl a r et, before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. eC ee4 Signature of Police Offica(1VS.S. 117.10) Stete-ef-Flarida_ Cou Signatur g Officer Date: 05/01/2006 Pageli of 22 EFTA00231977 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 during the female on female intercourse and provide oral sex to both. and IllnT1 This occurred during the time_ was sixteen years of age. advised this continued to escalate during two years. The routine became familiar to. Epstein's assistant ould telephone her every time Epstein was in the Town of Palm Beach and would place appoin 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 with his penis. • 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 naked and having sex and proudly display the photographs within the h 'ng one visit to Epstein's house in which she provided a masse e to E stein, his female frie was also present provided the massage in which and her would f is and kiss for Epstein to enjoy. Towards the end of this massage, Epstein grabbed. and turned her over onto her stomach on the massage table and forcibly inserted his penis into her vagina. stated Epstein began to pump his penis in her vagina. became upset over this. She said her head was being held against the table forcibly, as he continued to pump inside her. 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 Dawson 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 E stein. She stated she was brought to the Epstein house in March of 2005. a classmate at Hi h School, approached her and asked her if she wanted to "work". made the arrangements wit 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 E stein. 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 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. *-1 4 ; ,4fr Signature of Police &nicer (rs.s. 117.10) da County of Palm B Signatu g Officer Date: 05/0112006 Paget2of 22 EFTA00231978 Signature of Police Officer (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 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 girl, 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 'Baggage 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 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 room 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 area. stated as she did this, 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 rubbed the vibrator on her vaginal area. advised he never penetrated her vagina with the vibrator. He continued to rub her 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 5200.00 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 Sandman 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 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. ate a County of P lm Bc ch Signatu Officer Date: 0 I /2006 Page l3af 22 EFTA00231979 Probable Cause Affidavit Palm Beach Police Department Agency ORI0 Ft O 500600 attending 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 approximately 4 or 5 times in the past year. She accompanied with 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 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,. 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 ca at the Palm Beach Police Department. During a sworn taped statement, stated she had met E stein approximately two years ago when she was first approached by a classmate at 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 da the arrangements were made. had take also attended 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 throughout the house. stated 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 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 large head. Epstein would rub the vibrator/massager on her vaginal area as he would masturbate. stated she had been to the house The foregoing instrument was sworn to or affirmed before me this r day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Cifficer(P.S.S. 117.10) State of Honda County of Palm B h Signature/ fficer Date: 05/01/2006 Page of 22 EFTA00231980 Probable Cause Affidavit Palm Beach Police Department Agency O1W FLO 500600 numerous times. added she has no formal training in providing a massage. stated she brought two females durin her visits to rovide massages. stated she brought a girl named = and from High School. stated she received $200.00 for each girl she brought. On November 8, 2005, I met with aat 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 had asked her if she wanted to make money providing massages to Epstein. had heard that several girls from High School were doing this and 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 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 provide a massage and things had escalated from just providing a massage. Epstein began touching her on her buttocks and grabbed her closer to him as he masturbated. Epstein also grabbed her breasts and fondled her breasts 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 penetrated her vagina with his penis and began having intercourse with her until he reached the point of climax. Epstein removed his penis from her vagina and climaxed onto the massage table. received $350.00 for her massage. I asked her if she had any formal training in providing mas es, stated she did not continued to state on one other occasion, Epstein introduced his girlfrien into the massage. as brought into room with to provide a massage. Epstein had them kiss an ondle each other around the breasts and buttocks as they provided a massage to Epstein. Epstein, watched and masturbated as this occurred. On other occasionll=in, introduced the large white vibrator/massager in the massage. Epstein stroked the vibrator/massager on vagina as she provided the massage. On November 14, 2005, Det Sandman and I met with do' 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 ear Id when he first went to Epstein's house. On her first visit she was brought by a fellow student from High School known to her 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 me. Signature of Police Officer (F.S.S. 117.10) state of )TIUPIua County of Palm Beach Signatu Zi g Officer Date: 0 006 Paget o f 22 EFTA00231981 Probable Cause Affidavit Palm Beach Police Department Agency ORI# 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 maccage 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 provide 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 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 continued rubbing Epstein. Epstein turned over onto his back and she rubbed his chest area. 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. 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, Det Sandman and I met with dob During a sworn taped statement, IM stated she met Jeffrey E stein over a ear ago. She was sixteen years of age and was approached by a fello 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 Joe Recarey, who is personally known to me. 1 9.C, /, 4/ Signature of Police Officer (11.S.S. 117.10) Date: 05/0 /2006 State of Florida County of Palm B> ch Signatur Officer Ito Page of 22 EFTA00231982 Probable Cause Affidavit Palm Beach Police Department Agency OEM FLO 500600 massage topless. 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 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 the massage, Epstein turned over onto his back and requested 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 rubbed Epstein's chest.. 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 so 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 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 to provide another massage.. 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 by 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 massaging his legs and back. As. finished with Epstein's back and legs, Epstein then turned over onto his back.. started to rub his chest and he began masturbating. As IIrubbed his chest, Epstein leaned over and produced a massager/vibrator. He turned it on and began rubbings vagina and masturbating himself at the same time.. stated she continued to rub his chest as this was occurring. She described the vibrator/massager as large grey with a large head. Epstein rubbed her vagina for approximately two to three minutes with the massager/vibrator. He then removed the vibrator from her vaginal area and concentrated on masturbating himself.. stated Epstein climaxed onto the towel again and informed her that the massage was done. Igot dressed and met with who was waiting in the kitchen area. She received $200.00 for the massage.I 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 r questions about herself and high school. He was aware she attended, and is still attending High School. 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 me. a Signature of Police f fficer e( t .S.S. 117.10) State of Florida County of Palm B ch Signatur Date: 0 0l 006 g Officer Page of 22 EFTA00231983 Probable Cause Affidavit Palm Beach Police Department Agency ORD/ 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 bad 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 b , who signed the bottom of the messages. During the execution of the warrant, I located a High School transcript for in Epstein's bedroom desk. This desk had stationary marked Jeffrey E Epstein. notated 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. Dawson 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 so that. may The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det Joe Recarey, who is personalk knimi1 to rue. a 1(4 1 Signature of Police fficer (F.S.S. 117.10) Date: 05 State of Florida County of Palm Be Is Signature Officer Is Page of 22 EFTA00231984 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 be an to rub his chest, Epstein asked her questions about herself.. remembered telling him she attended 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 things. She continued rubbing his chest. Epstein reached up and unsnapped her bra from the front.. explained the bra she used had a front snapping device. Epstein rubbed her breasts and asked her if she like having her breasts rubbed. I 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 touched her breasts.. 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 stroking her clitoris.. said, "He commented how hard my clit was." He then inserted two fingers in her vagina and was stroking her within her vagina. She tried pulling back to pull out his fingers from within her vagina. Epstein removed his forgers from within her vagina and apologized for putting his forgers inside her. During this time, he kept his hand on her vaginal area and continued to rub her vagina.. stated he rubbed 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 . 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, 2006,1 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 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 Det Joe Recarey, who is personally k now n to me. Signature of Police Officer (F.S.S. 117.10) State of Florida County of Palm Beach Signatur Date: 05 fficer Pagellof 22 EFTA00231985 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 prepared the room for the massage. Epstein entered the room wearing only a towel. Epstein had clothing and provide the massage naked.. began rubbing his feet and calves and Epstein turned over onto his back. Epstein rubbed her vagina with his fingers. Epstein began to masturbate himself with an upwards and downward motion on his penis. Epstein continued to touch her vagina 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. 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 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 that they were going to provide a massage on Epstein. 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. 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 nipples. stated that as she started rubbing his chest, Epstein began masturbating himself . Epstein touched her breasts and stroked her vagina with his forgers. Epstein continued to masturbate himself as he stroked her vagina. Epstein ejaculated on his towel and paid $200.00 for the massage. Epstein told E that if she told anyone what happened at his house that bad things could happen. and were brought home by Epstein's houseman and U 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 remove her 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 e m s 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 get comfortable. The females would then provide the massage naked as Epstein would either touch their vaginas with his fingers and/or utilize the massager/vibrator on The foregoing instrument was sworn to or affirmed before me this lit day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police nS.S. fficer(F. 117.10) Date: 05/0 County of Palm Bea Signature/ fficer Page2lef 22 EFTA00231986 Probable Cause Affidavit Palm Beach Police Department Agency O1Wf FLO 500600 their vaginal area. 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 tr 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 oun to be masseuses. He stated one time under Epstein's direction, he delivered a dozen roses to 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 affirm before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police ftffice (F.S.S. 117.10) County of Palm Be h Signature/A ^ Officer Date: 05/0 PageLbf 22 EFTA00231987 Probable Cause Affidavit Palm Beach Police Department Agency OWN 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 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. Specifically, The phone records showed called during the exact times and dates when victim advised the incident occurred. also coordinated the encounters with.. 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. Therefore, as Jeffrey Epstein, who at the time of these incidents was fifty one years of age, did have vaginal intercourse either with his penis 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 aftltmed before me this In day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Poli 71e Offic r (F.S.S. 117.10) State of Florida County f Palm Beach Signature/ Date: 05/ ficer Pagellef 22 EFTA00231988 EFTA00231989 REQUEST FOR WARRANT DEFENDANT: DATE OF BIRTH HABITUAL OFFENDER: YES NO AIX/A VICTIM RELATED / ACQUAINTED WITH DEFENDANT? YES AGENCY CASE NUMBER: 05-368 (3) LEAD OFFICER: Det, Joe Retarev AGENCY: PALM BEACH POLICE DEPARTMENT XX NO PHONE NUMBER: CURRENT SHIFT HOURS: Ram TO 5 nin 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: ARREST FORM P.C. AFFIDAVIT (2 COPIES) y WITNESS / EVIDENCE LIST vesati-isLY eivem eta 13tattinarat￾SWORN STATEMENT OF MATERIAL WITNESS(ES) Y .. OFFENSE REPORT (2 COPIES) ACCIDENT REPORTS (ALL) WITtl9S STATEMENTS (ALL) FacmaccmINALEgagtewataly coit REQUEST FOR CONVIerlOrTTERS pRoPERTh REzrodOite vats 5 hew VEHICLE T()CV RECEIPTCfrver￾OTHER ATTACHMENTS INCLUDE: JR INITIAL FOR COMPLETENESS: t.F 3CFR DELIVERED BY: Retain SUPERVISOP. DI3113C7IVE siw,4r „ pl f Ck I; a, L? RECEIVED, STA4AZTPANWS OFFICE ON: 1r elk t 14, tz 7915 IDS 050106 DALE IDS 7915 LOP BY: DATII EFTA00231990 OBIS hanger I ARREST/ NOTICE TO APPEAR I Pam 3 Rogues: to. Nave-, Juvenile Referral Report 2 N T A 4 Request ir :Ape r-- J.rverrle i-- e. d W 2 A Agency ON Number "Agra no, 5 , 0 1 0 1 6 I_0 t 0 Name PALM BEACH POLICE DEPARTMENT Agency Awe Pester (N TA's only) 7i_BH ckl t I r r I id 1 l) TITe Was ' 0 I. Fee" 0 3. kewlerreanc. 0 5. Ortlinance many as egg 0 2. Traffic Eng .4. Trelaceladsmeanor DI Olher Y e Weapon SONO Erat!ype Runge Oestrus Logabon ol Arrest fleduchg Name ol fluaress) Lecakei el Wren (Business Name. Agnies) irdcarcv i I Date al Arrest s i l l lIng ci Amen Booing Dais Booking Tine as One As Tone Location ot Wage 1 DEFENDANT I NUM Cam Fest. Rate W - vents I • Anti B - Diana 0 • Cflaniaakaan I t ' l l Haig Comnexion Big Saes. PAPAS Tub as. Una* teal Fealties (Locat Description, Wench of likohot Influence a Doug Intone* it I mop Aging ( ) ,a Reamed Type i ty 3 2. Georg Mee( I • Out ot Siam 1 app Phone ( ) gains Sone i Rip) Prone ( ) Decticaion aiS motor P oe of Bote (Coy State] alizerrIP ' u: ui cl g Go.Deterciant Name (Last Fist Middle) Sae MN of Beth 3 ej 81 Z rtrue 4: Mowerneareor . Annie Co-DeNnont Name MS. Arel, Mono __ Pain Pace Sex Date 0 Dom :1111"' . Fe lony Lerpe 4. lifsgmeari 5 Annie or w — Name (URI (First) (model ggirCumockan Resigns paws p I ) Nags (Steel API Munger) (OW (Slate) (ZIP) Business Phone I I TOT JAC Dale In The above amens was Ironed by IL 0agneent nu orC) Onnotame pains The chid emit'a parent waste 10 keep me Jatertif 00u Clerk* Oahe (Phone 355-2520) ~flea a any GASP 0 Ong 0 Yes. by ?NM) 0 No: (Nelsen/ School AtranCIN Grille Prepares Came? 0 Ye 3 No Onaptch of Property Woo y Property g , • Activity S N. A II: guji.c P. Palau I R. Sczyggle K. Dispense/ . 14anurrel E ups Distroute Z. Other 2.ivIAlypo barbiturate /4 ttelluchreger P Pnorronenal U tsyncno Orme-, A ArltAhMentina 1 Mcrae IA MIAtuane Ech nem 0 °pose/Deny S mese Z Other g Drug Charge Oestagion ICoune Dommac ',ponce 0 Y ON Stakes Mollitem Mortar L I LI I t A. HI 1 1_ , VLolaten ol ORC 1 Anise Ong TWO l Arnarmt / Une Ovens* e Wanes /Capes Nag aced CHARGE I Large Neuters:on Cevets re caws YON Sate Woman Number I I Li 1 t_ t 1(1 i i_ i woman or ORD I Druz Panty Drug Type Amount/ Um Onenso or Wynn'/ PAPS Number Bona ui Charge Descremm Cams Omagh rl N Statute Volatan Honer 1_ 1 LI I 1 I la i 1 i Volareon or ORD 1 Drug Arany Drug Type [Amount/ UM Pierce 0 Mamie! iCapres Hunter Bed U ChNge DeSniebon Cone Einneelic O N Stain Waken Nogg I_ L t•E 1 I I RI t I I Modalion col ORD I ) Ono Annoy Drug Type 'moue / UM Owns. 0 Warrant /Cann Hinter Bono I_NOTICE TO APPEAR I 0 Instruction No. I Manostay Apputance In Coon 0 No Locacin (Gag Nam Nags Amen) Inatrudion 2 Yeu need not aortal, re Carl gut MP Gaul Dead lint amok with ill:A.00M on Haimme wow Day Year law A.M. P.N. I AGREE 10 APPEAR!. THE TUE AND PLACE DESKWATED TO ANSWER THE OFFENSE CHARGED OR TO PAY THE ENE SUBSCRIMO I UNDERSTAND THAT SkOIAD 1 WII.LFULLY FAIL TO APPEAR BEFORE T/4 •1.IPT AS REOUNE0 BY THIS NOTICE TO APPEAR, THAT I MAY BE HELD IN CONTEMPT OF COURT ANC, A WARRANT FOR MY ARREST SHALL BE ISSUED Sprats° or Dynan (or Juyeritegal Parent iCuSIOLleM Dag SONO 1031.1)I0r Ogg Agency Name: Synatura ci Arresbn2 Officer x Nome Vertealon (PONS by Nrestee) O Dangerous O ROMS great Sire or Arresung Cow IFFAD Lae • ' (PAM O Sad CI Other PAGE MOM DepAy LO. • raga Tramp:nig Plat I.D. 0 Agency Wins MN If keyed ogees +nth an Ir. OF DISTRIBUTION: WHITE — COURT COPY GREEN — STATE ATTORNEY YELLOW — AGENCY PINK — JAIL GOLD. DEFENDANT (N T.A1 ONLY) EFTA00231991 OBTS Were I I l t 1__L LA ARREST / NOTICE TO APPEAR I Arrest 3 Request 'or Warfare {-1 _ Juvenile Referral Repot 2 N TA 4 Ramat Ior Goa - 1 J yr a 0- Aglow ORI tree ROI 5 1 0 I 0 i 6 i 0 i 0 roomy Nam* PALM REACH POLICE DEPARTMENT an Report Number RYAS anal) 7 L 6 H I li i i L t i nt I) g bi • je s .0 I. Frey 0 3. Iffiroomeancr 0 6. Offices% As APBS 0 2 Traffic Pry 0 4. Traffic lascemsaror 0 & Oew " weapon Sono Er Type maple Crisco g A Leaman A or Arrest (Incluffirep it ,.,. or Burst) Lcceroo of Offenses Seines, Name. Mans) I noutoty l_ t Date ol Arrest 1 1_ 1 1 _1 Time elAnis 1 1 1 _ &Peng Cate Waft TIM ..lee Deb ail Mr* Loako 0 Wilde I DEFENDANT I Nam. Bea Rat Mrs) nos roe. Oat Soo Sect Eic 1 Race W • Wire I - evroncamotlem B- Bath 0 • Offintsffisien_ I Sex Dale et pen mi l ffier -- Wort Eye Color May Color Corepionon brio Start MOM Tars Uncere Ptysecal Freres (Location. 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GOLD• DEFENDANT (N.Y.AIONLY) EFTA00231992 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)(26) 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 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 clothing to provide the massage. As the victims complied and provided the massages, Epstein would nib his fingers on their vaginas. On occasion, Epstein would introduce a massager/vibrator and rub the victims vaginas 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 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, Ill explained that she was first approached by to go with her to Epstein's house. • stated that along with a Hispanic female, later identified at pick her up at her father's house on a Sunday. IN 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 conversation occurred between and IMI whereas reportedly told In that if Jeff asked her age, 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 me. Signature of Police Officer (F.S.S. 117.10) State of Florida County of P m Beach Signatu ng Officer Date: 05/01/2006 Pages of 22 EFTA00231993 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FL0 500600 she should say she was eighteen. It was later confirmed by the Es 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 IN 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 IN IN 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 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 U to take off her clothes. IN stated Epstein was stem when he told her to take off her clothes. U said she did not know what to do as she was the only one there in the room so 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. In 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 IN began to give Epstein the massage, he told her to get on his back. U stated she straddled herself on Epstein's back whereby her exposed buttocks were touching Epstein's bare buttocks. 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 IM to massage his chest. was now standing on the ground and resumed massaging Epstein's chest area. El 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 County of m Beach Det Joe Recarey, who is personally known to me. State of Florida Signature of Police Officer (FS.S. 117.10) Signatu g Officer Date: 05/01/2006 Page:A of 22 EFTA00231994 Probable Cause Affidavit Palm Beach Police Department Agency ORD, FLO 500600 massage vaginal arca. • stated there was no penetration as the vibrator was on top of her underwear. • recalled Epstein ejaculating because he had to use the towel to wipe himself as he got off the table. Epstein then left the room and le got dressed. She went back downstairs where she met with le said she was paid three hundred dollars in cash from Epstein. Before she left, Epstein asked to leave her phone number. As. and were leaving the house, told le 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 561- e spoke with in an attempt to arrange 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 subsequently called back • and left a voice mail message for her indicating that she had set up an appointment fore 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 es name at 11:00 am. This was the time frame had informed le to be ready to go work at Epstein's house. On October 3, 2005, Sgt Frick and I went to residence and viewed her vehicle parked in the driveway, a red Dodge Neon. Sgt. Frick 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 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. Zref e' ll County of Im Bea Signatur Date: 05/01/2006 Officer Signature of Police Officer (F.S.S. 117.10) Page3 of 22 EFTA00231995 Probable Cause Affidavit Palm Beach Police Department Agency ORD 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 grabbed her buttocks 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 brought to see Epstein, each time she was paid $200. stated she had brought the following girls: I. Faith_--. ( al6 year old female), (a 16 year old female) and said that at the time she 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 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 I. at her house. stated that at that time she was driving a red pickup truck. They traveled tl istein's house and entered through the kitchen door. They met with the house chef and Epstein's assistant . I. was introduced to Epstein while they were in the kitchen area. ale d I. upstairs and Epstein went upstairs. When the massage was over returned to the kitchen area. stated she was paid $200.00 for bringing I. to Epstein's house. stated I. 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 P' day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida County of Pal Beach Signature r Officer Date: 05/01/2006 Pagell of 22 EFTA00231996 Probable Cause Affidavit Palm Beach Police Department Agency ORIU 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, they disapproved of the encounters with him and she stopped. further stated that still tries to call house and leaves messages. Sgt Frick 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 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 Frick 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. We sat in the dining room and met with Date of Birth As she was under the age of eighteen, Mrs l was advised we would be speaking with her. She expressed 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 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 site wish to speak with me again to telephone me. Sgt Frick and I thanked Mrs. I 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 Dawson and I drove to the home and met with and 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 High School. 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 County of P Beach Det Joe Recarey, who is personally known to me. State of Florida p(d ies.4, Signature of Police lificer(F.S.S. 117.10) Date: 05 /2006 Signatur Officer PageCof 22 EFTA00231997 Probable Cause Affidavit Palm Beach Police Department Agency ORLY FLO 500600 for Jeff. She was told she would have to provide 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 kept her clothes on during the massage. She advised sometime during the massage, Epstein 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 massage. 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. 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 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. 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 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 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 within 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 IN 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 County of Palm Beach Det Joe Recarey, who is personally known to me. State of Florida Signature of Police Officer (F.S.S. 117.10) Signatur A g Officer Date: 05/01/2006 Page roof 22 EFTA00231998 Probable Cause Affidavit Palm Beach Police Department Agency O1W 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 Epstein 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 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. 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 0 to rub on him. At one point during the massage he tried to touch her buttocks. M . 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 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 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. Dunn a sworn statement, stated the following: on or about November 2004, she was approached at 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 High School students E 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 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 foregeing_ingteument mat cworn in nr affirmed before me this 1" day of May, 2006 by County of Palm Beach Det Joe Recarey, who is personally known to me. State of Florida Signature of Police Officer (F.S.S. 117.10) Signatur r t g Officer Date: 05/01/2006 Page of 22 EFTA00231999 Probable Cause Affidavit Palm Beach Police Department Agency ORIP FLO 500600 table, straddling Epstein to massage his back. While doing this her buttocks were touching Epsteins. 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 massage table and turned it on. stated Epstein began rubbing the vibrator over her thong underwear on her vaginal area. 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, 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 Dawson 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. Mrs. 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 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 driveway. They 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 exposing her belly area. During the massage, Epstein removed his towel and laid on the massage table naked. As . rubbed Epstein's chest 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 wassworn.to-or-siffirmed before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida County of Palm Beach Signat Date: i 11/2006 Officer Page 5--of 22 EFTA00232000 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FW 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 explained she never provided another massage for Epstein. She did however, go to the house with and (.I 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. 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.. 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 Epstein 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. I. 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. On October 6, 2005, at 11:45 am, I met with doti , at Lynn University 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 Jeff Epstein in Palm Beach. advised she originally had been taken to the Epstein house by whom she met when they both attended 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 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 f .oregeing incissimPlit WAS SWAM to or affirmed before me this 1" day of May, 2006 by County of Palm Beach Det Joe Recarey, who is personally known to me. State of Florida Signa ng Officer Signature of Police Officer (F:S.S. 117.10) Date: 0 i 1/2006 Pagel- of 22 EFTA00232001 Probable Cause Affidavit Palm Beach Police Department Agency ORO 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 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 about herself. Epstein knew she was a soccer player and would be attending Lynn University. 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. During the massage, she asked Epstein if she could borrow one of his vehicles to visit her family and boyfriend in Orlando, 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 grabbed her buttocks and caressed the buttocks cheeks. 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 use the vibrator 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 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 Lynn University Gym field. I asked her if she ever took any one to the house: explained she took a friend of hers who attended High School, who has relocated to Orlando 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 Dawson 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 11, 2005, dob was arrested by the Palm Beach Police Department The foregoing instrument wac sworn to or affirmed before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida County of Palm Beach Signatu ng Officer Date: r I 006 Pagd°of 22 EFTA00232002 Probable Cause Affidavit Palm Beach Police Department Agency ORM 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 Ms name and cell phone number. On October, 11, 2005, Det Dawson and 1 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 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 w mg up the stairs she observed several photographs of naked women alo the walls and tables of the house. I. further explained that she was brought into the bedroom, where repared the room by setting up the massage table and provided the oils for her to rub on Epstein. I. exp arced 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 touched her breasts and began 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 whe and were waiting. stated received an unknown amount of money or g er 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 massage his chest area. stated Epstein would then began to masturbate himself and at the same time would insert his fingers in her vagina and masturbate her with his fingers. I. explained Epstein would continue this process until he ejaculated. He would then utilize a vibrator/massager on her vagina until. climaxed. advised that during her frequent visits, Epstein asked for her real age, I. stated she was sixteen. Epstein advised her not to tell anyone her real age. I. advised that thin s escalated within the home as Epstein would instruct and pay. to have intercourse with his female friend, • explained the intercourse included using strap on dildos, large rubber penis' and other devices that Epstein had at his disposal. Epstein would watch them have intercourse and masturbate himself . Occasionally, Epstein would then join in The foregoing-iastrusini wac cwnrn to nr affirmed before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida County of P Beach Signatu ing Officer Date: /2006 Pageltot'"? EFTA00232003 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 during the female on female intercourse and provide oral sex to both. and This occurred during the time was sixteen years of age. advised this continued to escalate during two years. The routine became familiar to. 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 Epstein that no vaginal penetration would occur with his penis. 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 Epstcin's penis "egg-shaped." • stated Epstein would photograph and her naked and having sex and proudly display the photographs within the ho ing one visit to Epstein's house in which she provided a massage to E stein, his female friend, was also present. provided the massage in which and her would fondle each others breasts and kiss for Epstein to enjoy. Towards the end of this massage, Epstein grabbed. and turned her over onto her stomach on the massage table and forcibly inserted his penis into her vagina. stated Epstein began to pump his penis in her vagina. became upset over this. She said her head was being held against the table forcibly, as he continued to pump inside her. 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 Dawson 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. She stated she was brought to the Epstein house in March of 2005. a classmate at chool, 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 E stein. 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. ____Thea regehtg4ngtrument was invnrn to or affirmed State of Florida before me this 1" day of May, 2006 by County of Palm Beach Det Joe Recarey, who is personally known to me. Signature of Police fficer (F.S.S. 117.10) Signatur Officer Date: 05/01/2006 PagPof 22 EFTA00232004 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 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 girl, 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 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 room 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 area stated as she did this, 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 rubbed the vibrator on her vaginal area. advised he never penetrated her vagina with the vibrator. He continued to rub her • 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 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 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 bylino 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 Sandman and I met with dob uring a sworn taped statement, stated she met Jeffrey Epstein through when they were still The foregoing inctrnmeni wac sworn to or affirmed before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police nicer (F.S.S. 117.10) State of Florida County of Palm Beach Signature Officer Date: 05/01/2006 PagJ3of 22 EFTA00232005 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 attending 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 approximately 4 or 5 times in the past year. She accompanied with IN 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 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,. 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 approximately two years ago when she was first approached by a classmate at Palm Beach Police Department. During a sworn taped statement, stated she had met E stein High School. approached her about working for Epstein and providing a massage to him for $200.00. had made the arrangements however was unable tot arrangements were made. had take also attended 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 throughout the house. stated 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 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 large head. Epstein would rub the vibrator/massager on her vaginal area 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 Co r ty of Palm Beach Det Joe Recarey, who is personally known to me. State of Florida Signature of Police Officer (F.S.S. 117.10) Signatur' g Officer Date: 05/01/2006 PagItiof 22 EFTA00232006 Probable Cause Affidavit Palm Beach Police Department Agency ORIH FLO 500600 numerous times. added she has no formal training in providing a massage. stated she brought two females during her visits to rovide massages. stated she brought a girl named and from High School. stated she received $200.00 for each girl she brought. On November 8, 2005, I met with 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 had as to make money providing massages to Epstein. had heard that several girls from High School were • doing this and 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 where a massage table was prepared and the proper oils were selected. IN 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 IN 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 touching her on her buttocks and grabbed her closer to him as he masturbated. Epstein also grabbed her breasts and fondled her breasts 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 penetrated her vagina with his penis and began having intercourse with her until he reached the point of climax. Epstein removed his penis from her vagina 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. as brought into room with to provide a massage. Epstein had them kiss an ondle each other around the breasts and buttocks as they provided a massage to Epstein. Epstein, watched and masturbated as this occurred. On other occasions, Epstein, introduced the large white vibrator/massager in the massage. Epstein stroked the vibrator/massager on vagina as she provided the massage. W/F, the Palm Beach Police On November 14, 2005, Det Sandman 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 ears old when she first went to Epstein's house. On her first visit she was brought by a fellow student fro High School known to her The fnregning inctrumeng was sworn to or affirmed before me this 1" day of May, 2006 by C nty of Palm Beach Det Joe Recarey, 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 OS" Page of 22 EFTA00232007 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 provide 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 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 continued rubbing Epstein. Epstein turned over onto his back and she rubbed his chest area. 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. 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, Det. Sandman and I met with dob During a sworn taped statement,. stated she met Jeffrey E stein over a ear ago. She was sixteen years of age and was approached by a fellow 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 Cou ty of Palm Beach Det Joe Recarey, who is personally known to me. State of Florida Signature of Police Officer (F.S.S. 117.10) Signature/ f j e.jlngOfficer Date: 05/01/2006 PageI Hof 22 EFTA00232008 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 massage topless. 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 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 the massage, Epstein turned over onto his back and requested 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. rubbed Epstein's chest. 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 so 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 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 to provide another massage.. 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 by 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 massaging his legs and back. M. finished with Epstein's back and legs, Epstein then turned over onto his back. started to rub his chest and he began masturbating. As. 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 continued to rub his chest as this was occurring. She described the vibrator/massager as large grey with a large head. Epstein rubbed her vagina for approximately two to three minutes with the massager/vibrator. He then removed the vibrator from her vaginal area 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 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 High School. The foregoing internment was sworn to or affirmed before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida County of Palm Beach Signatu ng Officer Date: 05/01/2006 Page of 22 EFTA00232009 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 hod 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 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. Dawson 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 so that. may The feregoing-inarnmpnt %vac cwnrn to nr affirmed before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police fficer (F.S.S. 117.10) State of Florida Coun of Palm Beach Signature/ ng Officer Date: 05 1 P Page of 22 EFTA00232010 Probable Cause Affidavit Palm Beach Police Department Agency ORI0 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 be an to rub his chest, Epstein asked her questions about herself. remembered telling him she attended 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 things. She continued rubbing his chest. Epstein reached up and unsnapped her bra from the front. ■ explained the bra she used had a front snapping device. Epstein rubbed her breasts and asked her if she like having her breasts rubbed. 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 touched her breasts. 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 stroking her clitoris. said, "He commented how hard my clit was." He then inserted two fingers in her vagina and was stroking her within her vagina. She tried pulling back to pull out his fingers from within her vagina. Epstein removed his fingers from within her vagina and apologized for putting his fingers inside her. During this time, he kept his hand on her vaginal area and continued to rub her vagina.. stated he rubbed 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 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 Epste. ' stated she met Epstein when she was fifteen years of age. She was approached by a friend from .gh School, to be taken to Jeffrey Epstein's house to work. She was originally told she would be able ---The-foregoing-inutrument-ivas-sworn to nr 2Ffi rifled State of Florida before me this 1" day of May, 2006 by County of Palm Beach Det Joe Recarey, who is personally known to me. r at Signature of Poli e Officer (F.S.S. 117.10) Signature Date: 05/ i /2006 Officer Page Hof 22 EFTA00232011 Probable Cause Affidavit Palm Beach Police Department Agency ORDI FLO 500600 to model lingerie for a wealthy Palm Beadier. IN was taken to Epstein's house located on El BrilloWay. introduced IN 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 I. that they were going to provide a massage on Epstein. U 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. 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 nipples. U stated that as she started rubbing his chest, Epstein began masturbating himself . Epstein touched her breasts and stroked her vagina with his fingers. Epstein continued to masturbate himself as he stroked her vagina. Epstein ejaculated on his towel and paid $200.00 for the massage. 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 she lived.% stated that several days later she received a telephone call from and was afraid that Epstein knew where who coordinated for to return to "work." U returned to the house and was brought to Epstein's bedroom area by who prepared the mom for the massage. Epstein entered the room wearing only a towel. Epstein had remove her clothing and provide the massage naked. U began rubbing his feet and calves and Epstein turned over onto his back. Epstein rubbed her vagina with his fingers. Epstein began to masturbate himself with an upwards and downward motion on his penis. Epstein continued to touch her vagina 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 MM, 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 get comfortable. The females would then provide the massage naked as Epstein would either touch their vaginas with his fingers and/or utilize the massager/vibrator on Tin, fin tteing -instruntent-was-swern-to-or-affirmed State of Florida before me this 1" day of May, 2006 by Cou of Palm Beach Det Joe Recarey, who is personally known to me. re. al Signature of Pol' e Officer (F.S.S. 117.10) Signature ng Officer Date: 05/i 006 Pag?Rof 22 EFTA00232012 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 their vaginal area. 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 oun to be masseuses. He stated one time under Epstein's direction, he delivered a dozen roses to 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-swent-to-or_affirmed before me this 1" day of May, 2006 by Co ty of Palm Beach Det Joe Recarey, who is personally known to me. State of Florida Signature of Police() ffic0F.S.S. 117.10) Signatu ng Officer Date: i i 12006 Pagf of 22 EFTA00232013 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 High School after El high school drama performance. Also in that same note was direction to rent a car for E 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. Specifically, The phone records showed called during the exact times and dates when victim advised the incident occurred. also coordinated the encounters with.-_-_ 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 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 E was fourteen years old and knowing there would be unlawful sexual activity between E and Epstein that received monetary compensation for taking said fourteen year old female by Epstein, there is sufficient probable cause to arrest a 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 fv~ ogvr..g tint, wment-ins-sworn-to-or-afftrmed before me this P' day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Pelle Office (F.S.S. 117.10) State of Florid Co ty of Palm Beach Signatu Officer Date: 05/01/2006 Pageof 22 EFTA00232014 EFTA00232015 REQUEST FOR WARRANT DEFENDANT: DATE OF BIRTH HABITUAL OFFENDER: YES NO A/K/A VICTIM RELATED / ACQUAINTED WITH DEFENDANT? YES AGENCY CASE NUMBER: 05-368 (21 LEAD OFFICER: Dm, Joe Recaery AGENCY: PALM BEACH POLICE DEPARTMENT CURRENT SHIFT HOURS: 8 am TO 5 om XX 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: FILING DOCUMENTS ATTACHED: X ARREST FORM 31" P.C. AFFIDAVIT (2 COPIES) X WITNESS / EVIDENCE LIST 99-Evlbto( i 5 Weil lb Mils PjelaMta..re C.- SWORN STATEMENT OF MATERIAL WITNESS(ES) X. OFFENSE REPORT (2 COPIES) ACCIDENT REPORTS (ALL) WITNESS STATEMENTS (ALL) xg*iciNcic CRIMINAL HISTORY9640.144uN Ma i-SA Aftelltiveit— QUEST FOR CONVICTION LETTERS Y PROPERTY RECEIPT RZENRCUStai tale in 10 ASA eeLoµtaAE et. VEHICLE TOW RECEIPT OTHER ATTACHMENTS INCLUDE: INITIAL FOR COMPLETENESS: JR OFFICER 7915 050106 DATE SUPERVISOR DETISC7IVE : pleas g,4, AP.1.14 trZ 'oh is A 3 4' titvt.7 is! . .1`,%4 k.AtLy r; rr i t t , RECEIVED, STATE Atroistt ir i:4FICE ON: k' 1-'1 7 ilt 51 'AC'S K, 241 ' f • ism bcp I D• DATE EFTA00232016 DEPENDANT 1 AtliAINISTRMIVP --C*33 Hume« i s I l l t 1 1_ ARREST / NOTICE TO APPEAR 1 Angst J ~pm rot Wanen( Juvenile Relertal R3P011 2 N T A 4 Record Ier Care ri „won,. r — ! Afren OM Humt. ach 5 I 0 1 0 1 6 1 01 0 Mens" Name PALM BEACH POLICE DEPARTMENT Agency Non Nuntii (N.TA.'s only) 71 6H I EL i_ _L i i I 1(1 , -ri I. ne.), 0 3. Medemearo, saappa ":::iebr inanY 0 2 Treek Folony 0 4 Traffic IASdownearA, li PS. 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Felony 4. hteseereanor Juvrtole CcuEseteneant Name (Last Fint. lekker 'taco _ Sim Dar ot ISW) bl: At= Faltny 4.1Ateereanot P— Von» JUVENILE g dan Name Ms° (Fors» 949clel Flacienoe Pbone Mrtm Cum ... (Smet Apt numbet) (City) (Star) (2o) Burma %or* I ) "TOT JAC rate i l Toni 'Me above ~Ir MS rOulded by Q Menden! and C ce 0 delendon pang«. The e:bid and/or roert was tor Mended to keep Me Jouend* Carl Clerke Olec• (Rom 355-2526) rkirMed el airs Range c4 adireen. p Yes. ov (Name) o No: IFHason) Gade 0 Yes 0 No Propeny Crime? _n i Ofecncern oe PreRRY Value oc Properly 1: 1 R, peSt.? gke K Dopensa/ LI it p hI t eliv" B: Boy DnVidM P. Posen, T. Harp E tra Or e platen/ Z Oogt Cpist;ype Opnaai le II litirs-T" P FE"Pn err" gr if' U. A:Afnamen/se e Retor, 0. CRunvtenx S. 9 Mees CHARGE C.aatteDescriction Couna Drasse: 0 n N Stapte Naam korte- .1 '/ '1.1 I I I 1(1 I I 1 lAcemon c4 ORD e Drug Acen4ty Drug Type ~MI IUM j Maa • mort /glom Hunter Bond 0 Otarge DeaolptIon Con, Dommig 0 ilttnr6 N State ~Ron Nutter . e_ • j 'Al - t i 1 VI 1 i 1 ton el ORD • Ortg AcsWy Erop type Amounl C Und &ne cl Wurmt / OOM Nuirtgr Cl i Dar Carga Desalphon rweis ØSlattle Q Y CM Nolalion Hunter I i 1.1 I I I 1(1 1 I I `INrobben cl ORD • AOW). 'Drug Typ• lAtneunt / Uni Crinse i ~n I ~as kuiter Bond I 0 Cnarge Disalsbon cosO 00Ment aYn3N Serre Volake Munt« i ) L1 1 1 1 10 1 1 1 ratio , d ORD I Drup Acivey Drug Type !timet", / Unii Ceense • Watanc/Crias Momber Bond cc I El Insewoon No. 1 Mardalory Appeir loco in CDA C lownxison No 2 lecason Kan Room Humor. Addrijos) You nam rot ~we in Coat out mus, compy win inzout-nors or Revetse Stle Ccutt Dale end Tse Memo Da_y Wit Time A le PM I AGREETIDAPPEARAT0S: TIME AND PtACE DESIGNATED TO ANSWER »IE OFFENSE CHARGED OR TO PAY INE FOIE SUBSCRIBED. I tINDERSTANO THAT SHOIALD I WISPUILY MOL TO APPEAR (3EFORE t RT AS IllEOUIRED BY THIS HOME TO APPEAR, THAT I /JAY BE HEID IN CONTEMPT OF COURT AND A WARRANT FOR MY ARREST SHALL BE ISWED. -P t F 2 ~sta ot Delenctant (Ot Jouwde and Prent/ Cusleden) Date Senocl g HOU) lor ah« Apency Neme: Sgnature of Moer ~at x Name Vermeen (Porti by Moge*, 0 Clargerous ci ~ms Mal MMO Of Amen "et (Pront I. D I . , (MINT) O SØ D Ør: PAGE ~ka Depury I D t Poten Tramwoog 0~ i.D e Mens" Wener neme d stroop som*. SI .X. OISTRIBLITION WHITE— COURT COPY GREEN — STATE ATTORNEV YELLOW — AGENCY PINK — JAll ØD- DEFENDANT (N TAY OM» EFTA00232017 OBES Mmber 1 _1 1 1 1 1 I I I ARREST/ NOTICE TO APPEAR I Amps, 3 Rican lot Wattanl Juvenile Referral Report 2 N T A 4 ROWAN ler Cape TI Anorak E-- SAD'ILLSINITKIV I Agency ORI Numb, PLO' 5? 0 1 0 1 6, 0 1 0 Agency Nemo PALM BEACH POLICE DEPARTMENT boner Rat Num0Or IN.T AA levy) 7 1 6 I - I ill I I ) 81Zree many 0 1. Potty a aPPY, 0 2 Traffic felon 0 3. Mtaderneance C5 Od nance 0 4. Trade Wadarsalana fp A. Oder II weapon Send [Nitta eery Type 41 . g. I LonsOon ot ARON Onoicarg Nam* CS &sins) Lccabon of Offenses (Banns i Name Address) Dated Mnl Timed I Anal I I a Pocking Date Odder) Tee Jail Oats ad Time Letitia of iionoN i W IA Nano iUst. Rat. WON • Ants Nano. COB. Soc. Sic I. EN I Raw r . Bladr . While 8 ... Ainiocanknigni i Sex ale of Binh i HANN Eye Coix raw Cola COnWodon I Build Sea Marks. TalSedd llnicw• litsistai FeatureS (ldealion. Typos Dosolodon) Mantel Stand Rotten IArhol r tIn' ntonco py § 1' Crup In p . LOW (Stood. Apt. Norton (City) (Stale) (2 4i) Phone I ) I. Oly Tree: 3. Sofa 2 County_ 4. Out oi Stale Panamint Address (Sync Apt. Hunts) (OH) (Stale) (Lp) Phone { ) MOWS Smoot Bonnets AdctOSS (Nano. Sued) (Olyl (SUSI Ira Phone ( Ckacotion DO. Number. Sudo Sot. Sea. Numbs INS Rumble r. of inn (City. SINN Cintensho u: w ge i Cottalefolant Mime (Lat. Pm, WNW) Rico Sax 'Sox Date of Beth 1. Arrested 1 Felony 2. Ai Largo , no, S. .Avert' rdOeleadant Manilla Fara. WOO) Rata Dam 0 Seth _ El;. Milled g. , t 4. MISOemeanOr 5. Janina asi 1 L4 j rh,A g Pawcrent Inlardi (LW) ......,... (Res) (Maga) Rosidtmos Phone I ) mos. (Steel Apt MOWN) ICS/) Paste) RIP) sinto Business Phone ( ) TOT JAC ate Dm above address was provided by CI deNeclant re nom We Awing Coun Oen% Otim Mani 0 Yes. tyy: Meat and/ on 0 cWatiOsN's owns TIN dna end/apatite' was pat 35$2526) 'Memel ef PM d`wKaf 01adaress O_Noiffbasen) School Anew° Grade Prceeny Comet 0 Ye 0 No Si)Llesaunen of Property Witte of Property ,,,,.Buy R. Lni.go P Poston I 'Pal< E. USG X Dittos& IA lAs pronoicutare: 2 Onw Dsoilve Cure EvykATyne A. Addnertanne i Comnarate N HaNcncoin P Patecnemerai AI EtNiconynt Heroin 0 CenonDetv S. 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PM I EAR BEFORE TO APPEAR THEAT THERT7Ig REQuPASEBVSIGNATED AND APP Stratum TO HtS NOME ANSWER THE O CHARGED APPEAR. fFIEZEBm KR PAYTTI, FINERrEISCI ND Am. I UNE RANT rIcE3ForprACIRTtHEAsTTSHOUL SMALL S WILLFULLY FAIL TO of Dafanclani Hs Juvenile and Pawn t CoorCiaa) Deli Signed HOLD Mt other Agency Name. Scrubs' amounts Omar X Nee* vermemeon memo ey Ammer 0 Dangerous 0 Rewind Areal Mane of Arreeteg Olacer (Print) ID f (PRINT) 0 Sonoat 1.7 Cott PAGE intake Down I.D. 1 I Patch Transporting Mc. 1.0. A At m,/ Mini him d sued Wind "flan"- Of DISTRIWITION WHITE — COURT COPY GREEN — STATE ATTOFWEY YELLOW — AGENCY PINK — JAIL GOLD • DEPENDANT IN. TA's ONLY) EFTA00232018 Probable Cause Affidavit Palm Beach Police Department Agency ORIN PLO 500600 Police Case: 05-368 (2) Defendant: Race/Sex: 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, 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, Pahn 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, Epstein would rub his fingers on their vaginas. On occasion, Epstein would introduce a massager/vibrator and rub the victims vaginas 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 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. In stated that along with a Hispanic female, later identified at pick her up at her father's house on a Sunday. IN 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 affirmed before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. State of Florida t:--d-;•-t Signature of Police Officer (F.S.S. 117.10) County 01 Palm Mach Signa esting Officer Date: i 01/2006 Page 1 of 22 EFTA00232019 Probable Cause Affidavit Palm Beach Police Department Agency ORIN no 500600 conversation occurred between and whereas reportedly told that if Jeff asked her age, she should say she was eighteen. It was later confirmed by the IM 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. ir 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. Shoal thereafter, Epstein and his assistant, described as white female with blond hair and later identified as entered the kitchen. Epstein introduced himself to . IN 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 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. 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 so 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 Epstein the massage, he told her to get on his back.. stated she straddled herself on Epstein's back whereby her exposed buttocks were touching Epstein's bare buttocks.. 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 to or affirmed before me this la day of May, 2006 by County of Palm Beach Det Joe Recarey, who is personally known to me. Signature of Police 0 leer (F.S.S. 117.10) State of Florida Signat ting Officer Date: 1/2006 Page .2of 22 EFTA00232020 Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 massage vaginal area. IS stated there was no penetration as the vibrator was on top of her underwear. recalled Epstein ejaculating because he had to use the towel to wipe himself as he got 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 and were leaving the house, told IS 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 s conducted controlled taped phone calls to cellular telephone 561- IS spoke with in an attempt to arrange another meeting with Epstein. IS 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 appointment 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 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 Frick and I went to residence and viewed her vehicle parked in the driveway, a red Dodge Neon. Sgt. Frick 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 before me this ln day of May, 2006 by County of Pal Beach Det Joe Recarey, who is personally known to me. State of Florida r Signature of Police Offirer .S. 117.10) Signat ng Officer Date: /2006 Page3of 22 EFTA00232021 Probable Cause Affidavit Palm Beach Police Department Agency Offiti 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. , 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 grabbed her buttocks 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 brought to see Epstein, each time she was paid $200. stated she had brought the following girls: Faith__-'. ( al6 year old female), (a 16 year old female) and 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 I. 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 explained she knew that wanted to make money. She approached E and explained about going to work for Jeff, I. 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 to tein's house and entered through the kitchen door. They met with the house chef and Epstein's assistant . I. was introduced to Epstein while they were in the kitchen area. a led 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 State of Florida before me this 1" day of May, 2006 by Dct Joe Recarey, who is personally known to me. County of al Beach Signatu ring Date: 0 i 1/2006 Officer Signature of Police Officer (F.S.S. 117.10) Page Sof 22 EFTA00232022 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FL0 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, they disapproved of the encounters with him and she stopped. further stated that still tries to call house and leaves messages. Sgt Frick 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 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 Frick 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. Mrs. 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, Mrs I was advised we would be speaking with her. She expressed 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 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 Frick and I thanked Mrs., 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 Dawson and I drove to the home and met with and a 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 atten High School. 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 Joe Recarey, who is personally known to me. Signature CZ ofPolice Kit Meer .S.S. 117.10) State of Florida County P. m Beach Signat sting Officer Date: t. 11/2006 Page 5of 22 EFTA00232023 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 for Jeff. She was told she would have to provide 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 kept her clothes on during the massage. She advised sometime during the massage, Epstein 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 massage. 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. 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 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 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 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 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. to call her back reference the police questioning. stated she inadvertently told 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 statements 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 County of Pal Beach Det Joe Recarey, who is personally known to me. State of F orida Signature of Polic ‘/ Office Cit (F.S.S. 117.10) Date: 05) t 1/2006 Signatur .1 ing Officer Page4of 22 EFTA00232024 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 Epstein 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 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. 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 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 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 ad met with her at her residence. During a sworn High School by listatement, stated the following: on or about November 2004, she was approached at 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 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 during the moqqage, Epstein asked her to remove her clothes. She complied and removed her pantsand 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 Joe Recarey, who is personally known to me. State of Florida County of Palm Beach eca Signatu r ting Officer Signature of PolikOffi(er (F.S.S. 117.10) Date: 05 t 006 Page7 of 22 EFTA00232025 Probable Cause Affidavit Palm Beach Police Department Agency O1W FLO 500600 table, straddling Epstein to massage his back. While doing this her buttocks were touching Epsteins. 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 massage table and turned it on. stated Epstein began rubbing the vibrator over her thong underwear on her vaginal area. 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 Dawson 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. Mrs, 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 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 driveway. They 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 exposing her belly area. During the massage, Epstein removed his towel and laid on the massage table naked. As. rubbed Epstein's chest 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, 2006 by County of Pal Beach Det Joe Recarey, who is personally known to me. State of Florida Signature fi. ting Officer Signature of Polices Ulcer S.S. 117.10) Date: 05/ 006 Page8of 22 EFTA00232026 Probable Cause Affidavit Palm Beach Police Department Agency ORI# 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 explained 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 El 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. 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. I. 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 Epstein 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. U 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. On October 6, 2005, at 11:45 am, I met with dob at Lynn University 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 Jeff Epstein in Palm Beach. advised she originally had been taken to the Epstein house by whom she met when they both attended 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 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 County of P m Beach Det Joe Recarey, who is personally known to me. Ct Signature of Police Officer (F.S.S. 117.10) Date: 05/111/2006 Signatur esting Officer Pagel of 22 EFTA00232027 Probable Cause Affidavit Palm Beach Police Department Agency Oltitl 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 Epstein would try to touch her more and on one occasion he sated 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 about herself. Epstein knew she was a soccer player and would be attending Lynn University. 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 Orlando, 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 maccage as Epstein grabbed her buttocks and caressed the buttocks cheeks. 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 use the vibrator 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, MB 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 Lynn University Gym field. I asked her if she ever took any one to the house. explained she took a friend of hers who attended High School, who has relocated to Orlando 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 Dawson 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 11, 2005, 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 County of Pa each Det Joe Recarey, who is personally known to me. State of Florida K-0# Signature of Police Officer (F.S.S. 117.10) Signatur ting Officer Date: 05 i /2006 Pagel0of 22 EFTA00232028 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 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 Dawson 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 Hi School classmate, . said she was brought through the kitchen area where she me for the first time. was led to the, master bedroom, Epstein s room.. explained that as she was w mg up the stairs she observed several photographs of naked women alon the walls and tables of the house.. further explained that she was brought into the bedroom, wher repared 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 shut.. 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 touched her breasts and began 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 r 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 massage his chest area. stated Epstein would then began to masturbate himself and at the same time would insert his fingers in her vagina and masturbate her with his fingers. explained Epstein would continue this process until he ejaculated. He would then utilize a vibrator/massager on her vagina until climaxed. 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. advised that thin s escalated within the home as Epstein would instruct and pay. to have intercourse with his female friend, MI explained the intercourse included using strap on dildos, large rubber penis' and other evices at pstein had at his disposal. Epstein would watch them have intercourse and masturbate himself . Occasionally, Epstein would then join in The foregoing instrument was sworn to or affirmed before me this lu day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida County of Palm each Signature ng Officer Date: 05/ 006 Paged of 22 EFTA00232029 Probable Cause Affidavit Palm Beach Police Department Agency OFUN FLO 500600 during the female on female intercourse and provide oral sex to both. and This occurred during the lime was sixteen years of age. advised this continued to escalate during two years. The routine became familiar to. 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 Epstein that no vaginal penetration would occur with his penis. 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 naked and having sex and proudly display the photographs within the home. stated during one visit to Epstein's house in which she provided a mass e to E stein, his female friend was also present. provided the massage in which and her would fon e eac o ers reasts and kiss for Epstein to enjoy. Towards the end of this massage, Epstein grabbed. and turned her over onto her stomach on the massage table and forcibly inserted his penis into her vagina. stated Epstein began to pump his penis in her vagina. became upset over this. She said her head was being held against the table forcibly, as he continued to pump inside her. 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 Dawson 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 E stein. She stated she was brought to the Epstein house in March of 2005. a classmate at 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 E tein. 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 affirmed before me this ln day of May, 2006 by County of Palm each Det Joe Recarey, who is personally known to me. State of Florida 0 t 'si fl Signature of Police Officer (F.S.S. 117.10) Signature/ g Officer Date: 05/01/ 06 Page iZf 22 EFTA00232030 Probable Cause Affidavit Palm Beach Police Department Agency OM no 500600 On November 6, 2005, at approximately 3:30 pm, I met with dot , 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 girl, 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 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 room 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 area. stated as she did this, 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 rubbed the vibrator on her vaginal area. advised he never penetrated her vagina with the vibrator. He continued to rub her 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 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 recent 17 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 Sandman and I met with dob Cuing 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 County of Pal Beach Det Joe Recarey, who is personally known to me. State of Florida Signature of Police Officer ( .S.S. 117.10) Signatu ing Officer Date: 05/01/2006 Page oof 22 EFTA00232031 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 attending 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 approximately 4 or 5 times in the past year. She accompanied with 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 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, IN 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 two years ago when she was first approached by a classmate at 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 arrangements were made. had take also attended 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. stated 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 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 large head. Epstein would rub the vibrator/massager on her vaginal area 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 County of Pal Beach Det Joe Recarey, who is personally known to me. State of Florida Signature of Police tffficer .S.S. 117.10) K a Signatu ling Officer Date: 05 i /2006 Page/4bf 22 EFTA00232032 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 brought two females d • ovide massages. from High School. stated she brought a girl named and stated she received $200.00 for each girl she brought. On November 8, 2005, I met with 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 had asked her if she wanted to make money providing massages to Epstein. had heard that several girls from High School were doing this and 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 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 provide a massage and things had escalated from just providing a massage. Epstein began touching her on her buttocks and grabbed her closer to him as he masturbated. Epstein also grabbed her breasts and fondled her breasts 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 penetrated her vagina with his penis and began having intercourse with her until he reached the point of climax. Epstein removed his penis from her vagina and climaxed onto the massage table. received $350.00 for her massage. I asked her if she had any formal training in providing massa stated she did not. continued to state on one other occasion, Epstein introduced his girlfrien to the massage. brought into room with to provide a massage. Epstein had them kiss an ondle each other the breasts and buttocks as they provided a massage to Epstein. Epstein, watched and masturbated as this occurred. On other occasions, Epstein, introduced the large white vibrator/massager in the massage. Epstein stroked the vibrator/massager on vagina as she provided the massage. W/F, at the Palm Beach Police On November 14, 2005, Det Sandman and I met with dot- 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 High School known to her The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by County of Pal Beach Det Joe Recarey, who is personally known to me. State of Florida r Signatur ting Officer Signature of Polic Officer (F.S.S. 117.10) Date: 0 Page IV 22 EFTA00232033 Signature of Police Officer (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency ORIN PLO 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 0 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 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 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 continued rubbing Epstein. Epstein turned over onto his back and she rubbed his chest area. 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. 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, Det. Sandman and I met with dob During a sworn taped statement,. stated she met Jeffrey E stein over a ear ago. She was sixteen years of age and was approached by a fello igh 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 County of Palm o each Det Joe Recarey, who is personally known to me. State of Florida Signature/.. 'ng Officer Date: 05/0 06 Pagekof 22 EFTA00232034 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 massage topless. 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 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 the massage, Epstein turned over onto his back and requested 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 rubbed Epstein's chest.. 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 so 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. I. 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 approached by advised if she wanted to return to the house to provide another massage.. 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 by 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 massaging his legs and back. As. finished with Epstein's back and legs, Epstein then turned over onto his back.. started to rub his chest and he began masturbating. As.s 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 continued to rub his chest as this was occurring. She described the vibrator/massager as large grey with a large head. Epstein rubbed her vagina for approximately two to three minutes with the massager/vibrator. He then removed the vibrator from her vaginal area 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 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 High School. The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by County of Pal Beach Det Joe Recarey, who is personally known to me. Signature ing Officer State of Florida Signature of Poli Office (F.S.S. 117.10) Date: OS/ 006 Pagetiaf 22 EFTA00232035 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 b who signed the bottom of the messages. During the execution of the warrant, I located a 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. Dawson 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 so that may The foregoing instrument was sworn to or affirmed State of Florida before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. County of Pa Each Signatur' Date: 0 01 ting Officer Signature of Polic Offffice(F.S.S. 117.10) i 06 Pageief 22 EFTA00232036 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 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 be an to rub his chest, Epstein asked her questions about herself. remembered telling him she attended 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 things. She continued rubbing his chest. Epstein reached up and unsnapped her bra from the front. explained the bra she used had a front snapping device. Epstein rubbed her breasts and asked her if she like having her breasts rubbed. 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 touched her breasts. 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 stroking her clitoris. said, "He commented how hard my elk was." He then inserted two fingers in her vagina and was stroking her within her vagina. She tried pulling back to pull out his fingers from within her vagina. Epstein removed his fingers from within her vagina and apologized for putting his forgers inside her. During this time, he kept his hand on her vaginal area and continued to rub her vagina.. stated he rubbed 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 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. met Epstein when she was fifteen years of age. She was approached by a friend from School, to be taken to Jeffrey Epstein's house to work. She was originally told she would be able 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 High 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 me. aCtCrd 41 11 1 $ Signature of Pollee Officdr (F.S.S. 117.10) State of Florida County of Palm each Signature/ g Officer Date: 05/0 06 Pageoof 22 EFTA00232037 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 to model lingerie for a wealthy Palm Beacher. IE was taken to Epstein's house located on El BrilloWay. introduced E to Jeffrey Epstein. Epstein had his personal chef prepare dinner for E and At the conclusion of dinner, and Epstein brought E 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. E asked why were they doing this instead of modeling lingerie. explained to E that this was his routine and to rub his calves and feet. Epstein had told E to get comfortable. removed her pants and blouse. IE 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 IE to rub his chest and rub his nipples. • stated that as she started rubbing his chest, Epstein began masturbating himself . Epstein touched her breasts and stroked her vagina with his fingers. Epstein continued to masturbate himself as he stroked her vagina. Epstein ejaculated on his towel and paid. $200.00 for the massage. Epstein told. that if she told anyone what happened at his house that bad things could happen. IE and were brought home by Epstein's houseman and IE was afraid that Epstein knew where she lived. E stated that several days later she received a telephone call from who coordinated for • to return to "work." E 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 IE remove her clothing and provide the massage naked. E began rubbing his feet and calves and Epstein turned over onto his back. Epstein rubbed her vagina with his fingers. Epstein began to masturbate himself with an upwards and downward motion on his penis. Epstein continued to touch her vagina with one hand and masturbate with the other hand. Once Epstein ejaculated onto the towel he was wearing, the massage was over. IE was paid $200.00 for the massage. Epstein again told E not to speak of what happened at his house or bad things would happen. El 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 get comfortable. The females would then provide the massage naked as Epstein would either touch their vaginas with his fingers 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 p a alm Det Joe Recarey, who is personally known to me. Signature/Ar Officer Signature of Folic Officer (F.S.S. 117.10) Date: 05/01 Paggoof 22 EFTA00232038 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 their vaginal area. 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 ent 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 oun to be masseuses. He stated one time under Epstein's direction, he delivered a dozen roses to 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 County f P m B ach Det Joe Recarey, who is personally known to me. e</sele-r Signature/ g Officer Signature of Poll Office (F.S.S. 117.10) Date: 05/01 State of Florida Pagezof 22 EFTA00232039 Probable Cause Affidavit Palm Beach Police Department Agency ORIff 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 High School after MI 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. Specifically, The phone records showed called during the exact times and dates when victim advised the incident occurred. also coordinated the encounters with.. 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 Epstein, who at the time of these incidents was fifty one years of age, did have vaginal intercourse either with his penis or digitally with... 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. 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 1" day of May, 2006 by County Palm Beach Det Joe Recarey, who is personally known to me. State of Florida Signature of Poll fte Offic (F.S.S. 117.10) Date: 05/0 Signature/. rr t ng Officer Page2zif 22 EFTA00232040 1 :01L EFTA00232041 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 1 Incident Report Program: CMS301L Case No 1-05-000368 SPECIAL NOTES : DO NOT RELEASE Occur To Date : 1/27/05 0000 Day Of Week . : Thursday Common/Location: 358 EL BRILLO WY City PALM BEACH, FL Location Type : RESIDENCE-SINGLE Beat Assignment: DETECTIVE BUREAU Dept Class . . : SEXUAL BATTERY Case Status . : OPEN / Supervisory Dt.: Illilli, Entry Date . . : Names, Vehicles? Narrative? . . : . . : Occur From Date: 1/27/05 0000 Report Date . : 3/14/05 1600 FAMILY Map Reference Report Officer Case Status Dt 3/14/05 4/06/05 ********* V E H I C L E I N F O Case number . : 1-05-000368 State Veh Type : Make Model Name . . : Style Color - Bottom : VIN Disposition . : Insured by . . : Vehicle locked : Date recovered : 0/00/00 Street number : City Recovery code : Be On Look Out?: • ********* PERSON R E Case Number . : 1-05-000368 Street Number : City Birth Date/Age : Occupation . . Home Phone No. : Sex Female Weight 0 ************** Case Number . : Street Number City • ROYAL Birth Date . . : Employer? . . : Oper Lic No. . : Other Phone Nbr: Sex • Minimum Weight : SUSPECT 1-05-000368 P O R / A R Property? . . Offenses? . . Related Cases? : 10 : PAGAN, MICHELE : 3/14/05 RMATION # Category . . Year Model Permit Number Color - Top . License # . Stolen value . Insured . . . Keys in car . Lein holder . Recovery value 1 ********************* : 0 : 0 NCIC number . : TING Last Name N F O - . • : 1 33412 Employer? . Oper Lic No. Race White Height • 0 Other Phone Nbr: # 1 ********* RESTEE IN Prompt valid Female 0 PALM BEACH, • FORMATION - in: FL 334121460 Maximum Age . : Occupation . . : Home Phone No. : Race • Minimum Height : Maximum Height : 18 White 0 0 • # 1 * * EFTA00232042 Date: 7/25/06 Time: 8:47:53 Incident Report PALM BEACH POLICE DEPARTMENT Page: 2 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.: 1-05-000368 0 (Continued) Misc. ID# . . MO/Crime Spec? Hair Length Eye Color Complexion Build Speech Coat Pants Body Marks Body Marks Status Additional #1 : #3 : STILL SUSPECT UCR?: ************** S USPECT/ARRESTEE INFORMATION- # 2 ** Case Number . : 1-05-000368 Prompt valid in: Street Number : 358 EL BRILLO WY City • PALM BEACH. FL 000033480 Birth Date . . : Maximum Age . : 25 Employer? . . : Occupation . . : PERSONAL ASST/EPSTEIN Oper Lic No. . : Other Phone Nbr: MEP Home Phone No. Race ite Sex • Female Minimum Height : 0 Minimum Weight : 0 Maximum Height : 0 Maximum Weight : 0 Misc. ID# . . Aliases' MO/Crime Spec? Hair Color . Hair Style . Glasses . . Facial Hair Teeth Hat Shirt Shoes Body Marks #2 : Body Marks #4 : Arrest Case No.: Hair Length Eye Color Complexion Build Speech Coat Pants Body Marks #1 : Body Marks #3 : Status Additional UCR?: STILL SUSPECT ************** Case Number . Street Number S USPECT/ARRESTEE INFORMATION- # 3 ** : 1-05-000368 Prompt valid in: EPSTEIN, JEFFREY : 358 EL BRILLO WY City Birth Date . . Employer? . . : : PALM BEACH FL 000033480 Maximum Age . Occupation . . : : 52 Oper Lic No. Home Phone No. : Other Phone Nbr: Sex • Minimum Weight : Maximum Weight : Aliases, Male 0 0 Race Minimum Height Maximum Height Misc. ID# . . MO/Crime Spec? : : : White 0 0 Hair Color . . Hair Style . . : : Hair Length . Eye Color . . : EFTA00232043 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Incident Report Page: 3 Program: CMS301L Case No • 1-05-000368 Glasses . . Facial Hair Teeth Hat Shirt Shoes Body Marks #2 : Body Marks #4 : Arrest Case No.: . : . : **************VICTIM Case Number . : 1-05-000368 Prompt valid in: Street Number : City Birth Date/Age : Occupation . . : STUDENT Home Phone No. : Sex • 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 • Female Weight • 0 Be On Look Out?: Victim Type . Residency Sts : ADULT Residency Type : File Charges . : Can Identify . Victim Sobriety: Injury Extent : Injury Type 1 : Injury Type 2 : Hospital ID . : Med Treatment : Phys First. Name: Phys Last Name : ***** ********* ICTIM INFORMATION -# 3******************** Case Number . : 1-05-000368 Prompt valid in: Street Number : City Birth Date/Age • : PALM BEACH. FL 000033480 Employer? • • ICTIM 1-05-000368 PALM BEACH Complexion Build Speech Coat Pants Body Marks #1 : Body Marks #3 : Status Additional UCR?: (Continued) STILL SUSPECT INFORMATION - #1******************** 3412 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: INFORMATION -# 2******************** Prompt valid in: FL 000033480 Employer? . Oper Lic No. Race White Height 0 Misc. ID# . . Other Phone Nbr: EFTA00232044 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. : 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 : ************** VICTIM INFORMATION -# 4 *********** ***** **** Case Number . : 1-05-000368 Prompt valid in: Street Number : City • PALM BEACH FL 000033480 Birth Date/Age Employer? Occupation . . : Oper Lic No. Home Phone No. : Race • White Sex • leFma Weight • 0 Height • Misc. ID# . . : 0 Be On Look Out?: Other Phone Nbr: Victim Type . Residency Sts Can Identify . Injury Extent Injury Type 2 Med Treatment Phys Last Name Oper Lic No. . : Race • Height Misc. ID# . : Other Phone Nbr: White 0 (Continued) ************** : JUVENILE VICTIM Case Number . : 1-05-000368 Street Number : City PALM BEACH FL Birth Date/Age Occupation . . : Home Phone No. : Sex • Female Weight 0 Be On Look Out?: Victim Type . : ADULT Residency Sts : Can Identify . : Injury Extent Injury Type 2 : Med Treatment : Phys Last Name : **************VICTIM Case Number . : 1-05-000368 Prompt valid in: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: INFORMATION -# 5******************** Prompt valid in: A 000033480 Employer? Oper Lic No. Race • White Height • 0 Misc. ID# Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Imjury _Type 1 : Hospital ID . : Phys First Name: INFORMATION -# 6 *********** ***** **** EFTA00232045 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 5 Incident Report Program: CMS301L Case No • 1-05-000368 Street Number : City • PALM BEACH Birth Date/Age Occupation . . Home Phone No. : Sex Female 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 PALM BEACH, 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 : 0 JUVENILE ICTIM 1-05-000368 ************** V Case Number . : Street Number : City Birth Date/Age : Occupation . . Home Phone No. : Sex • Female Weight • 0 Be On Look Out?: Victim Type . : Residency Sts : Can Identify . : Injury Extent : Injury Type 2 : Med Treatment : Phys Last Name : Female 0 JUVENILE ICTIM 1-05-000368 PALM BEACH, JUVENILE ************** V I C T I M FL 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: (Continued) • White • 0 INFORMATION - # 7 ******************** Prompt valid in: FL 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: INFORMATION -# 8******************** Prompt valid in: FL 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: INFORMATION -# 9 * ***** ************** EFTA00232046 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 • Fema Weight • 0 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 : JUVENILE Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Med Treatment : Phys First Name: Phys Last Name : ************** ICTIM INFORMATION - # 11 ******************* Case Number . : 1-05-000368 Prompt valid in: Street Number : City • Birth Date/Age : PALM BEACH, 8/09/1986 18 FL 000033480 Employer? Occupation . . : Oper Lic No. . Home Phone No. : Race • White Sex Female Height 0 Weight 0 Misc. ID# . . : Be On Look Out?: Other Phone Nbr: Victim Type . : ADULT 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: 1-05-000368 1-05-000368 PALM BEACH. FL e JUVENILE ICTIM 1-05-000368 PALM BEACH. FL Female 0 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 Continued INFORMATION -# 10 ******************* 000033480 Employer? . Oper Lic No. Race • White Height • 0 Misc. ID# . . : Other Phone Nbr: EFTA00232047 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Incident Report Page: 7 Program: CMS301L Case No • 1-05-000368 Phys Last Name : ************** VICTIM Case Number . : 1-05-000368 Street Number : City Birth Date/Age : Occupation . . Home Phone No. Sex • Female Weight 0 Be On Look Out?: Victim Type . : ADULT 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 : (Continued) INFORMATION -# 12 ******************* Prompt valid in: PALM BEACH, FL 000033480 Employer? . Oper Lic No. Race Height Misc. ID# . . Other Phone Nbr: ************** VICTIM Case Number . : 1-05-000368 Street Number City Birth Date/Age : Occupation . . : Home Phone No. : 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 : ************** ICTIM INFORMATION -# 14 ******************* Case Number . : 1-05-000368 Prompt valid in: Street Number : City Birth Date/Age : PALM BEACH, FL 000033480 Employer? . Occupation . . : Oper Lic No. Home Phone No. : Race White Sex -r male Weight • 0 Be On Look Out?: Victim Type . : JUVENILE Residency Sts : Can Identify . : Injury Extent : . : . : White 0 INFORMATION -# 13 ******************* Prompt valid in: PALM BEACH, FL 000033480 Employer? . . : Oper Lic No. . : Race White Height 0 Misc. ID# . : Other Phone Nbr: meight . . . . :-O Misc. ID# . . • Other Phone Nbr: • Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : EFTA00232048 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 8 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) Injury Type 2 Med Treatment : Phys Last Name : ************** V ICTIM Hospital ID . : Phys First Name: INFORMATION -# 15 ******************* Case Number . : 1-05-000368 Prompt valid in: Street Number : City Birth Date/Age : PALM BEACH, FL 000033480 Employer? . . : Occupation . . : Oper Lic No. . : Home Phone No. : Sex • Weight • Female 0 Race • Height • Misc. ID# . . : White 0 Be On Look Out?: Other Phone Nbr: Victim Type . Residency Type : Residency Sts Can Identify . Injury Extent Injury Type 2 : Med Treatment : Phys Last Name : ************** Case Number Street Number : City Birth Date/Ill . : . : 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 : fl m Female 0 JUVENILE ICTIM 1-05-000368 PALM BEACH Female 0 JUVENILE File Charges . Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: INFORMATION - # 16 ********** ***** **** 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: INFORMATION - # 17 Prompt valid in: FL 000033480 ******************* Employer? . . : Opel_ . : Race • White Height 0 Misc. ID# . . Other Phone Nbr: Residency Type : File Charges . EFTA00232049 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 PERSON Case Number . : 1-05-000368 Street Number : City • WEST PALM Birth Date/Age : Occupation . . : STUDENT Home Phone No. : Sex Weight 0 Other Phone Nbr: ********* Case Number Street Number City Birth Date/Age Occupation . . Home Phone No Sex Weight Other Phone Nbr: (Continued) Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: INFORMATION - #1********* Last Name . . BEACHIIFL 33411 Employer? . Oper Lic No. Race OTHER PERSON *********OTHER PERS Case Number . : 1-05-000368 Street Number : City ROYAL PALM BEACH, FL Birth Date/Age : Occupation . . : Home Phone No. : Sex • leFma Weight 0 Other Phone Nbr: ********* 0 Case Number Street Number : City Birth Date/Age : Occupation . . : Home Phone No. : Sex • Weight Other Phone Nbr: THER PERSON . : 1-05-000368 • White Height • 0 Person Type : OTHER PERSON INFORMATION -# 2 ********* : 1-05-000368 Last Name . . : : 358 EL BRILLO WY • PALM BEACH FL : : 000033480 Employer? . Oper Lic No. : : Female 0 Race Height Person Type • • : 510 OTHER PERSON • O N INFORMATION - # 3********* Last Name . . : 33411 Employer? . Oper Lic No. Race • White Height • 0 Person Type : OTHER PERSON INFORMATION -# 4 ********* Last Name . . 33411 Employer? . . : Oper Lic No. . : Race • White Height • 0 Person Type . : OTHER PERSON *********OTHER PERSON Case Number . : 1-05-000368 INFORMATION -# 5********* Last Name . . : EFTA00232050 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Incident Report Page: 10 Program: CMS301L Case No 1-05-000368 (Continued) Street Number : City Birth Date/Age : 0/00/0000 0 Employer? . Occupation . . : FAMILY THERAPIST Oper Lic No. . : Home Phone No. : Race White Sex • Fema e Height • 0 Weight 0 Person Type : OTHER PERSON Other Phone Nbr: ***EMPLOYER INFORMATION*** Case Number . : 1-05-000368 Employer Name : PBC DIVISON OF YOUTH AFFAIRS Address . . . : 4200 N AUSTRALIAN AV City/State/Zip : WEST PALM BEACH, FL 33407 Phone Number . : *********OTHER PERS Case Number . : 1-05-000368 Last Name Street Number City • WELLINGTON. FL 33414 Birth Date/Age : Hom No. : • • Sex Weight Other Phone Nbr: Case Number . Address . . . City/State/Zip Phone Number . * * * ***** * Ma 0 O N INFORMATION ********* Employer? Oper Lic No. Race • White Height 0 Person Type . : OTHER PERSON ***EMPLOYER INFORMATION*** : 1-05-000368 Employer Name : WEST FL OTHER PERSO Case Number . : Street Number : City Birth Date/Age : Occupation . . : Home Phone No. : Sex • Weight Other Phone Nbr: 33415 . : N INFORMATION -# 7 ********* 1-05-000368 Last Name . . : WEST PALM BEACH, L 33412 0/00/0000 0 Employer? . . : Oper Lic No. : 561 Male 0 Race Height Person Type . : White 0 OTHER PERSON ********* OTHER Case NuMber . : Street Number : City Birth Date/Age : 0 00 0000 0 Occupation . . Home Phone No. : 561 Sex PERSON INFORMA - # 8 ********* Last -Name . . FL 33411 Employer? . Oper Lic No Race . : . : Height • 0 PALM BEACH, EFTA00232051 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Incident Report Page: 11 Program: CMS301L Case No • 1-05-000368 Weight • 0 Other Phone Nbr: ***-#***** O Case Number Street Number City Birth Date/Age : Occupation . . Home Phone No. Sex Weight Other Phone Nbr: THER PERSON . : 1-05-000368 WEST PALM • Female • 0 (Continued) Person Type . : OTHER PERSON INFORMATEM... ********* m Last Name . . BEACH, FL 33417 16 Employer? Oper Lic No. Race White Height 0 Person Type : OTHER PERSON FL **************************** N A R R A T I V E # 1* *********** ***** ******* Original Report LO Reported By: 9/20/05 Entered By.: , , 9/20/05 On 03/14/2005, I received a call from a woman who did not wish to identify herself (later identified as . She stated that her fourteen year old step daughtilillater identified as possibly ma have been molested in Palm Beach by a wea thy 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 conversation between her daughter and a male friend; they were talking about The conversation was about how had met with a 45- ear-old man and had sex with him and was paid for it. I advised that I would like to meet with her to obtain a more detailed statement and facts. stated she did not know what to do and had to discuss the matter with her husband. At this point did not provide me with a call back number or any other in ormation. She stated that she would contact me once she had spoken with her husband and mother. On 03/14/2005 received a call from Mr. & Mrs. They stated it was all right to speak to their daughter via cell phone 561 Her mother had been ma e aware of the case. Ri llilleed to meet me at t e po ice department later this date. (561 . On 03 14/2005, Mr. accompanied by his wife came to the Pa m Beac Po ice Department where they a vised me t at they believed their fourteen year old daughter may have had some type of sexual relationship with an older male who resided in Palm Beach. Neither knew the suspect. no name --or address. Both stated that their daughter did not talk to them about the incident, nor would she admit to it. 11111OB identified his daughter as biological mot er at is a EFTA00232052 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 12 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) her sister resides with Mr. Both IIIII and are currently attending vocational school, which is an involuntary admitte juveni e educational facility. stays at the facilit 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 believes the incident occurred on Sunday, Feb 6, 2005. A riend of named picked her up at initiate the relationshi not have any proof. further explained t at a boy she was dating . Mrs. continued their house and left. They believe with the older gentleman, though they lives close by with her mother. Mrs. U i was introduced to by goes to , plays base that on Sun ay, picked up "III and drove to Pa m Beach where they met the man. Supposedly, t e man has a lot of money and often has young girls come over to his house. III. offers these girls a way to make fast cash. The man starts wit a massa e. If he likes them, he keeps them around and does more. The did not have any information on other than she lives on 72n P ace North, the last house on right si e (north side). Mrs. foun it the call between talked of a conversation that she had with t e mother of a former friend of She strange that they were 111 Miger friends until she received from her mother tellin herof the conversation she overheard and a boy named Mrs. told me of an incident that occurred on 02/09/2005. IIII got into a fight at school HS). Mrs. Brown Assistant explanations for the large sum of money. Initiar the school Principal, found over $300.00 in s purse. gave different administration thought it was drug related but then dismissed the claim. Since that day, did not return to school; she ran away Thursday, 02/10th or Friday 02/11 and returned to her mother's house later that night after midni ht. It was not until after received the call from mother, 561 that she earne was t e gir that got into the fig t wit The fight was instigated when accused of being a prostitute. who has legal joint custody of his daughter IIII signed the affidavit of prosecution indicating he wished to prosecute against the inappropriate sexual behavior with his fourteen-year old daughter. Mr. stated that he had no objections with our agency speaking with is aughter about the incident. Mr. stated that mother is aware of the allegations an a so was willing to cooperate. Accor ing to Mrs. she does not believe her daughter had any additional contact with the suspect as she was with EFTA00232053 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 13 Time: 8:47:53 Incident Report Program: CMS301L Case No - 1-05-000368 her mother and then placed into (Continued) I contacted the School Board Police who rovided me the information for also known as Family Center 840 - 4540. 4200 N Austra ian Avenue, West Pa m Beach Florida. Checking the school board records for and there was no disciplinary record found. I was advise i no isciplinary 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 the Palm Beach County Sheriff's Office and left a message for PBSP Sgt. Chris Keen, Child Abuse Unit. On 03/15 2005 I went to female Also present was therapist. During an audiotaped interview I spoke wit about the allegations that were made. initially enie anything had ha ened onl admitting to going with (later identified as to Palm Beach to pick up money was owed. i enti ie as the cousin of her former boyfriend She u timairildmitted to knowing that worked for a wea t iiiiiiand possibly did sexual favors for him. S e also admitted that had offered her an opportunity to make money. where I met with white identified Till', boss as a white male named "Jeff" who lived in Palm Beach ter positively identified as Jeffrey Epstein). her to Jeff's house, when they were at explained that she was first aiiiiiiied by to go with house. Accordin to she was not sure exactl what was going on with but agreed toliiiiith her. ( boyfriend) became angry when he heard inviting to accom any her. believed it was to pick up money the man owed stated told her that she would pick her up at her ouse on Sunday. was not sure of the exact dates but knew it was a Sunday. According pic e er uplIRIr father's house on told her to along with an unknown possibly Hispanic female, Daniel father that they wereliiiii shopping. It was ater confirmed by that picked his daughter up. According to Mr. drove a pick up truck. drove II Sometime on the w whereby she along with the unknown female to Palm Beach. "Aire, a conversation occurred between and told that if Jeff asked her should-say eighteen. recalled that Jeff's house was on a dead end street. All ee thr girls walked up a drivewa guard/security room. In fact, them asking what they wanted. Jeff. The male allowed them to ast what appeared to be a small recalled a male approaching stated they were there to see continue walking up to the house. EFTA00232054 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Case No • 1-05-000368 Page: 14 Program: CMS301L (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 and a woman, described as white with blond hair entered the kitchen. believed the woman was Epstein's Assistant. added t at t e woman did not seem friendly and kept her responses short and direct. Epstein introduced himself to as Jeff . got the impression that Epstein and friend forty-five years oliTiong face, and bushy eyebrows, with graying knew eac of er. described Epstein as being approximately hair. and Epstein left the kitchen leaving and friend alone in the kitchen. They returned a short time later. They all spoke briefly in the kitchen. While speaking to me, became upset and started to cry. stated the woman instructed her to follow her upstairs, which s e i According to the woman led her to a room that had a massage table in it. T e woman started to fix up the room, uttin the covers on the table and taking lotions out. She then told that Epstein would be up in a second. The woman left the room, and soon after E stein walked in and told to take off her clothes. As was telling me what had appene , she looked away from me and wit a pointed finger, repeatedly pressed it into her thigh. stated he was stern when he told her to take off her clothes. said she did not know what to do as she was the only one there. took off her shirt leaving her bra on. stein, dressed in a towel told her to take off everything. 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. Epstein laid on the table, face down. As be an to give Epstein the massage, he told her to get on his ac c. stated she straddled herself on Epstein's back. state er exposed buttocks were touching Epstein s bare buttoc s. As was giving Epstein the massage, he turned around, and wacked off later explained that wacking off was masturbating). stated she was dis usted by 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 believed he masturbated again. Epstein returned to the room and told that he was done and gave her three hundred dollars. They went back down stairs where the met Epstein said good-bye and they left. asked ow 1 it go and asked what did she ( When told that E stein asked for a massage, allegedly stated "I now." stated they then went shopping. stated also got aid, but that she did not know why since s was con i ent that did not do anything. described Epstein's house as a two pink house with a Ca 1 ac Escalade parked in the drivewa . T ere were gates leading into the property. From the kitchen, recalled walking up a flight of stairs, lined with photograp s, to a room. Upon entering EFTA00232055 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 and reen 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 we as several photographs of naked women on a shelf. stated Epstein did not chap e in front of her but did take off his towel, exposing himself. recalled Epstein being hairy especially on his chest. E stein also had a hairline that continued to his buttocks. admitted to seeing his penis. I asked if she knew w at eing circumcised meant and she stated no. then said that she thought Epstein was on steroids because e was a "really built guy and his wee wee was very tiny." would explain that when she stated "wee wee" she meant penis. stated Epstein exposed himself when he took his towel off, cap ing it on the floor as he laid down on the table. said Epstein was specific in his instruction to her on how to massage, telling her to go clockwise, etc. recalled that Epstein got up from the table and went to the at room where she heard him making, what she believed to be sexual type of noises. (moaning) He then returned to the room where he again laid down on the table. Epstein then turned over and instructed to massage his boobs. As she did this, Epstein continued to ma ...ling i noises. ..or resumed massaging his chest area. was now standing ground. Epstein turned to his side, an wit the towel on the ground started to rub his penis in an up and down motion. stated Epstein held on to the small of her back as she massage is chest, back and shoulder area. recalled Epstein ejaculating because he had to 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 room and downstairs where she met an t e admitted to getting paid t ree hundred Before they left, Epstein asked As they were leaving the house, and how much she was paid. got dressed. She went back unknown white female. dollars in cash from Epstein. to leave her phone number. what had happened seemed upset or 1,ous when she told her that s e received t ree hundred dollars. stated received onliiiii hundred dollars that day. stated that she believed was paid two hundred dollars for bringing her. told e rich; sure where. never saw not spoken with asked stated that if they do this every Saturday, they could agreed. They then went shoppiA though she is not ssibly Po I at TJ Maxx or Marshall's. stated she again as she got into a fight at sc M oo . 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. EFTA00232056 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 l.oi L.lamily if she ever went to the po ice regarding the incident. stated that her father's vehicle was recently vandalized. admitted to tel what had happened with Epstein. According to in the wall. guessed that it was ecame angry and u set, punchin a hole 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 truth and lying. We talked about the color sweater she was wearing. denied having sexual intercourse with Epstein. She dente touching his penis. again admitted to observing Epstein masturbate. agreed to cooperating with the police department in placing a p one call to II in a controlled setting. I met with Ms. and advised her o the families' as well as MIE willingness to cooperate with this investigation. Cop es of this interview were placed into evidence. advised her briefly o my investigation. She was aware " Ili I made contact with mother of I incident and stated that she overheard a portion of a conversation that her daughter was having with a boy named stated that it was her opinion that both girls liked recalled hearing her daughter calling admitted that she did not listen to the entire conversation ut id confront her daughter about it later. III. told her mother that somethin to the effect that ha slept with an older man for money. stated that s e would not object to me speaking with her daug ter. It was s belief that everyone in the school ma have known about t is ecause of the fight that her daughter and had gotten into. I reminded that this was an ongoing investigation and requested she not iscuss the fact that I had contacted her. She agreed. On 03/16/2005, PBSO Sgt. Chris Keen left a message that he was returning my call. I spoke with Keen and discussed the case with him and inquired if he had any open allegations or cases where the suspect resided in Palm Beach. Keen stated he was unaware of any. Keen offered any assistance if needed. Keen 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 6f-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 EFTA00232057 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 17 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) a photo of Epstein to be used in a photo line up. I met with at which time she viewed the photo line up. She imme lately the photo line up under Epstein's picture. This signAl il l!p was recognized Epstein and pointed to him (Position #5). signed placed into evidence. On 03/18/2005, I met with at her residence for the purpose of placing a controlled call to spoke with and asked if she could arrange anot er meeting wit Jeff. stated that she would have to call him and make the arrangements. copy of this conversation was placed into evidence. 03/19/2005, I s oke with e IIII 'II. and was advised that ett state to visit wit er aunt and uncle. is sc e uled to return to Florida on 03/27/2005 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. Lee re ardin trash pulls from 358 El Brillo. On this same date I called to schedule an appointment to speak with She state t e sc ool guidance counselor was reluctant toll!!! police presence at the school. I assured her that I would respond to the school in civilian clothes and an unmarked vehicle. called me back and advised that I did not need to make an appointment to see I received a return phone call from stating that would be attending the familllierapy 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 n • Mark L a/m dob Maxwell, uk/f, dob A computer query history. On 03/23/2005, I spoke with cell phone wk I requested that she-not discuMeir. ..nt with anyone inclu ng her daughter as I did not want the investigation compromised. I was told at t is time that e have not been getting along due to the fact that IIIII has cided to continue living with her father. On 03 29/2005, I placed telephone calls to both the and residences requesting to speak with them regarding the • alm Beach, w/f, dob & Ghislaine N. for both returned no EFTA00232058 Time: 8:47:53 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Incident Report Page: 18 Program: CMS301L Case No • 1-05-000368 invests ation. I received return phone calls from Mrs. Mrs. and advised them that I would be contacting family therapist to coordinate a time to meet with the request of both Back and Mrs. that classroom and therapy schedule be disrupte as ittle as also u dated them to the investigation thus far. Both stated the had no objection to my meeting with spec in• with Ms. she identified the cell phone 561) as eing t e phone assigned to a• no objections and provided consent to giving po ice •e artment for the use of placing controlled phone it. stated the phone had been taken away from was at Continued) and This strict ossible. I and In er of Ms. it to the calls from as part of her unis ent for not doing well in school. According to used to be an excellent student, but in the past two III* mont s a siWome irritable, verbally abusive to the family and has run away. stated her daughter's recent behavior is the opposite o w at s e normally is. stated they are going through family therapy sessions witliK ilitool but none of this had come up. Arrangements were made for Det. Captain Gudger to retrieve the cell phone from at her place of employment. I called Family Center, 840-4540 and requested to speak with Ms. . Upon speaking with Ms. was in the middle of therapy sessions an sheadvised me that she call me back once the sessions were completed. Ms.IIIII stated the sessions should be concluded by 7:00 PM. At approximately 8:00PM I had called Ms. at which time I left a message on her 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 wou d again attempt to coordinate a time with the counselor so as not to disrupt s school schedule. had no objections. Shortly after spec ing with Ms. I received a call from Ms. . I explained the situation and requested a time to meet wit advised that would be avai able after 3:00PM. reviewed s schedule and On 03/30/2005, I met with Ms. and at Family Center. I reminded of il iconversation with Robson. During this time initiate a conversation with me in which she admitted that s e was not telling me everything that had ha ened during the time she was alone with Epstein. According to while she and Epstein were alone on the second floor Epstein used a purple vibrator to massage her vaginal area. stated there was no •enetration as the vibrator was on top o er underwear. I asked if Epstein ever asked her age and she stated he had. stated she told him she was eighteen. When Epstein asked w at sc ool she was in, responded she was in the twelfth grade at Wellington. During t e course of this incident, stated Epstein told her that had worked for him for years. We then continued with the controlled call to At iiiiiiimately 3:35pm from her cell pitTlimade a call to s home, (561) was not home. was told EFTA00232059 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Incident Report Page: 19 Program: CMS301L called During the conversation between and asked she a hear rumors t at asked if they, meaning claimed to have heard t at Jeffrey. tol know anything out Epstein. someone to work tomorrow and as stated she would call Epstein and then call Case No 1-05-000368 that 11 IIIIIIII. W/F, was at working a double and cell p one, .1 Olive Garden Restaurant, ocated on orest Hi (Continued) could be reached on her is employed at The is Blvd in Wellington. what happened, statInlik. was og ing to press charges. arents, knew about Jeffery. father had found out aout that the (her parents) did not told that Epstein needed e if she was available. back. During the course of these conversations with she would at times appear to be articulate and well spoken. S e wou d then start to act in an immature manner b looking around, not paying attention, drawing on a paper. would offer me a high five whenever she claimed to have tol me t 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 s e admitted that she did not tell me the all the details of her encounter with Epstein during our first meeting. As a means of positive reinforcement I would high five On 03/31/2005, subpoena requests for T-Mobile Wireless 56110111111, and Cingular Wireless, (561) and 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. Krauel 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 I queried various different web sites for a possible identification of the purple item retrieved from the trash pull from 358 El Brillo. The item was similar in description as the one described by 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 EFTA00232060 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, I obtained a copra' voice mail messages, dated 03/31 and 04/01 from to A female identifying herself as states that she cou plc 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 and me. There were several messages written on various forms of papers. There was a message from III." indicating 11:00. The following was additional information obtained from tras retrieved from 358 El Brillo: Jean Luc 6:20 AM. David ;655-0995; 1x; IITIFIllriday 5:30PM; a message receipt She is looking to speak to you . On 04/06/2005 I faxed sub oena requests to SA office for Epstein and s phone records. P one numbers (561) (561) ,(561) & (561) ). (Continued) On 04/06/2005, I called School, IIIIIIIIIIII, ext 311, and spoke with Prince He con arme t at they had a student by the name of He requested a written request prior to releasing any additions information. On this same date I faxed a request for student and parent information on IIII I advised that due to this being an open investigation he was not to discuss the matter with anyone. On 04/08/2005, I received a messa e from rovidin me the following information: w m DOB Wellington, Florida, 33414. Parents name: Det. Lee provided me with trash obtained from 358 El Brillo for 04/06 04 07 05. The following information was retrieved: Jet Aviation itinerary, indicating a departure date of 04/05/2005 at PM 4:00 wit an arrival in New York City of 6:15PM. Flight crew captain David Rodgers, co-ca tain, Larry Visoski, flight engineer Larr Morrison. Call sign • a note stating Bye J. thank you hand written notes & messages 11-Glenn 12.30 chicken, 4PM Monday after s ool?- left message or 4 3 September I l Big Screen x8, work Sunda @ works 4-9 Monday an Tues ya es e here—ran-arrow @ 10:30 Am; Mrs. There was no trash for 04/08/05. school @ Business 11:30 AM 04 22 05 received the results of a subpoena request from Bellsouth for The results only provided subscriber information. I contacte A ice Grant Investigative Subpoena Compliance Center who stated the request was not complete and the results would be sent to EFTA00232061 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 o taine from message notes via trash pulls, I identified the before mentioned individuals as being acquainted with someone at 358 El Brillo. DOB FL DL and DOB FL DL both above t elegal M illilisent. investigation. statedl t at was doing well in the On 05/03/2005, I s oke with and updated her on the school. Her contact with the 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 a one. 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. 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 conflictin appointments, with Ms. I also spoke with rescheduled until 06/02/2005, to meet and updated her to the investigation. On 06/02/2005, I met with and Sandborn advised that she could be reached via er cell p one 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 information that Epstein's plane was at Jet Aviation. I spoke with Det. Lee regarding surveillance. I called the Olive Garden and asked for she was not working today. This would il!)11111111 employed there. On 07/07/2005 I faxed Epstein and (561 (561) subpoena requests on y sub oena requests to SA s phone records. nd (561 prove ed subscri er an On 07/20/2005, conducted a trash pull arranged there were misc. papers with phone numbers and I was advised was still office for (Phone numbers The original billing information. by Ofc. Lee. Inside names. There were EFTA00232062 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 Track report residence is rillo, a ossible subject residing at the fit the description provided by officers w o con uc ed survei ance 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 out of state. who confirmed that was still living It appeare that all was going IF 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 the case notes of this file, as the case will be turned over to Det. Recarey. On 09/11/2005, while on patrol, I conducted a check residence and found that it still had the hurricane drive by the Palm Beach International Airport later did not observe Epstein's plane. at Epstein's shutters on. On a that afternoon, I 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 and to find out if there was an cb!!IIIIIIIMIs or hone bers num for Mt . ertc.n.ovide er wi e ec s 46, ********************** *************** # 2 *************************** NA Reported By: RECAREY, JOSEPH Entered By.: ALTOMARO, NICKIE A. On September 19, 2005, I met with Officer Pagan and received the information pertaining to this case. Members of the Burglary Strike Force had previously been conducting surveillance on both Epstein and Officer Munyan was assigned to monitor the E stein home and Sgt Sorge and Officer Minot were assigned to monitor Both teams provided a surveillance log that will be placed into the 9/21/05 9/21/05 EFTA00232063 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. Dawson was assigned to relieve Officer Munyan 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. ****************************NARRATIvE # 3 *************************** NA Reported By: PARKINSON, GREGORY A. 9/23/05 Entered By.: ALTOMARO, NICKIE 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 as it is as a prior copy had been made and turned over to Sergeant Frick. I immediately took the tape to Sergeant Frick and allowed him to examine it and then obtained the copy from him and Detective Recarey 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. ******************** ***** ***NARRATIVE # 4*************************** NA Reported By: PARKINSON, GREGORY A. 9/26/05 Entered By.: ALTOMARO, NICKIE A. 9/26/05 On 3-24-05 at 11:00 pm, a copy of tape 2 (case number 05-294) had been made for Det. Pagan by Evidence Specialist . The copy was turned over to Detective Recarey. 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 to s, that tape number 2 was blank. I notified Sgt. Frick and Det. Recarey. I was informed that they had a prior copy and I could use it to make a master tape. I did so and when reviewing and signing the evidence sheet, I noticed Evidence Specialist Badger had written "#2 is blank." I obtained that copy from Det. Recarey and made a new copy on a standard size tape. The new copy was placed in the evidence bag under EFTA00232064 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 24 Program: CMS301L Case No • 1-05-000368 property number 05-294 with the blank tape. (Continued) **************************** NARRATIVE # 5 *************************** NA Reported By: RECAREY, JOSEPH 9/26/05 Entered By.: ALTOMARO, NICKIE A. 9/28/05 Copies of the tapes that were submitted into evidence were requested. Additionally, trash pulls were started on September 21, 2005. Sgt. Szarszewski made telephone contact with Tony Higgins, Supervisor of the Sanitation Department, and requested that trash be collected at the Epstein House located at 358 El Brillo in Palm Beach. Sgt Szarszewski met with Sanitation worker, Jeff Williams and observed him enter the property at 358 El Brillo. Shortly thereafter, Williams exited the property and placed the three white trash bags in the empty well in the rear of the truck. Williams then drove away where he met with Sgt. Szarszewski 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 contained names of irls with times. Additionally, there was a note from and to Jeffrey Epstein on a note ad, which stated,"For a good time ca 1 and at " Also, there was another telephone n er on the 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 information on the telephone numbers listed above on the assi,Pto Cingular Cellular Service. i!!!!r notes note from and The cellular telephones III and were ound within the trash on Jeffrey Epstein ad papers that contained telephone numbers. One note had " with written on it. This cellular number is assigne to Cingulialular 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. Szarszewski 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 began to become familiar with the interviews that were conducted. Det. Krauel had met with Town of Palm-Beath Sanitation worker, Jeff Williams and observed_ him enter the property of 358 El Brillo. Shortly thereafter, Williams exited the property and placed the three white trash bags in the empty well in the rear of the truck. Williams then drove away where he met with Det. Krauel 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 EFTA00232065 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 25 Time: 8:47:53 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 affected were the control phone calls from the victim to the suspect I obtained the graphic equalizer and discovered that th 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. U on researching the file, it was discovered that the suspect, cellular calls were sub oenaed incorrectly. The suspect to e one number was 561 and the original request was for 561 . I requeste t e information through Cingular Cellular Service rom Februar 2005 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.... **** ***** *******************NARRATIVE # 6 *************************** NA Reported By: KRAUEL, CURTIS D. 10/06/05 Entered By.: ALTOMARO, NICKIE A. 10/06/05 On or about September 23, 2005 at approximately 0915 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jeff Williams. Williams had been previously notified to assist in trash pulls at the residence of Jeffrey Epstein, 358 El Brillo, Palm Beach, Florida. I observed Williams 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 Williams 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 documents of evidentiary value were removed and turned over to Det--RecarEw-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 EFTA00232066 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 26 Incident Report Program: CMS301L Case No • 1-05-000368 and notified Det. Recarey to that affect. (Continued) 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 documents of evidentiary value were removed and turned over to Det. Recarey for follow-up. On or about Monday October 3, 2005 at approximately 0915 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jeff Williams. I observed Williams 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 Williams 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 documents of evidentiary value were removed and turned over to Det. Recarey for follow-up. On or about Tuesday October 4, 2005 at approximately 0928 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jeff Williams. I observed Williams 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 Williams 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 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. All documents of evidentiary value were removed and turned over to Det. Recarey for follow-up. On or about Wednesday October 5, 2005 at approximately 0928 hours, I EFTA00232067 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 27 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) responded to 358 El Brillo and met with PB Sanitation worker Jeff Williams. I observed Williams 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 Williams 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, with the assistance of Det. Recarey. 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 documents of evidentiary value were removed and turned over to Det. Recarey for follow-up. **************************** NARRATIVE # 7 *************************** NA Reported By: RECAREY, JOSEPH 10/07/05 Entered By.: ALTOMARO, NICKIE A. 10/07/05 I met with Det. Krauel and requested further assistance to maintain trash collections at Epstein's residence at 358 El Brillo Road. On October 3, 2005, at approximately 10:30 am, I was contacted by Sgt. Frick to respond to the Palm Beach Police Station. Det. Krauel had observed Jeff Epstein riding his bicycle on South County Road. Upon my arrival, I met with S t Frick who advised, as Epstein was currently and the girls that are rougil illi his house. As we were to interview in Town; we interview as to her involvement with Epstein in the county, (outside of our jurisdiction), I contacted the State Attorney s Office Investigation Division, and made contact with Assistant Supervisor Investi ator Carlos Ortiz. I requested assistance to interview as the interview may occur in the county. Supervisor Ortiz assigned Investi ator Mike Waites to assist us at the location and interview of . baring Florida Tag of as pare in the drivewa of vilig il a red Plymouth Neon Det. Dicks had responded to the address of and viewed her vehicle parked in the drivewa IIIII in Loxahatchee. Sgt Frick and I responded to and awaited the arrival of Investigator Mike Waites. Upon his arrival, he was briefed that should she wish to be interviewed within her home he would be needed. However, should agree to return to the police station for further questioning, he wou d not be needegiiiiit. Frick and I knocked on the door and met with was told that we were investigatin a claim invo ving Je rey 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. Waites and advised she was going to voluntarily return to the police station. EFTA00232068 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 s entry in the unmarked Detective vehicle, I placed a tape recor er within the vehicle to record any conversations within the vehicle. During the ride back to the police station, advised she is attending Palm Beach Community College at the Pa m Beach Gardens Campus 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 t t should she desire to leave at any time she may do so. I further explained the interview room door is only closed for prlvac stated she understood. During the taped sworn interview, was asked how she came in contact with Epstein. state ack when she turned 17 years of age she was approached a riend M. in the Canopy Beach Resort in Rivera Beach. IIIIII was asked she wanted to make money. She was told she would have to provide a massage and should make $200.00. IIIIII thought about the offer.Agg agreed to meet with Jeffrey. (Unknown last name) and IIII (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 house. She was also introduced to a white female known to her as She was led u *rs to the main bedroom known to her as Jeff Epstein s bedroom. arranged the massage table and covered the table with a sheet. e brow 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. f entered the bedroom wearing only a towel. He lay on the table onto his stomach and icked massage oil for M. to rub on him. During the massage, stated, He tried to tout me and I stopped him. I asked how he trie to touch her. He grabbed her buttocks and she felt uncomfortable. also stated Epstein has a vibrator, which is large and white in co or. told Epstein, I'll massage you but I don't want to be touche stated she performed the massage naked. At the conclusion of the know you re not comfort but I'llailiou if you bring some girls. He told her the younger the better. stated she once tried to massage, Epstein paid $200.00 for the massage. He explained, I bring a 23- ear-old female and Epstein stated that the female was too old. was asked how many girls she brow ht in total to Epstein. stated six that she can remember• stated she brought an• t e tim vc in t is case. I asked which one was the youngest. advised the victim was the youngest. stated every girl s e rought knew what to expect when they arrive . 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 EFTA00232069 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 29 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) victim agreed and arrangements were made to bring the victim to Epstein's house on a weekend. stated that she and (later identified as picked up the victim at t e victim s house. They traveled to Epstein's House and entered through the kitch r. They met with the house chef and Epstein s assistant The victim was introduced to Epstein while they were in the kite en area. 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 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 then they went shopping. stated the victim was the last person she brought to Epstein. S e urther stated that she had changed her cellular number to avoid being contacted by =. She continued that when Epstein p e . announces to his assistant tETE—he is traveling to Palm Beach, would contact identified as Date of Birth 05 range girls for E-st25- in. , late 1979, had told that J have his fun with the girls. stated that once her parents discovered that she was visiting E stein, they disapproved of the encounters with him and she stopped. further stated that still tries to call the house and eaves messa es. With the tance of we were able to identify DOB DOB Sgt Frick entered the room and explained that based on her own statements, she had i licated herself with bringing underage girls to Epstein's house. was aware of what she had stated and wished to assist further in opes to receive a lesser charge. provided cellular telephone numbers for the girls she had mentioned previously. Additionally, she also rovided possible addresses and areas in which they lived. As was being taken home in the vehicle, a tape recorder was place 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 Frick and I went to Florida in an attem t to spea wit Mrs. ( s Mother) at t the ongoing investigation and felt that information as we had information that s home. We sat in the dinning room and met with introduced us-to her husband and- allowed us entr into the Date of Birth . As she was under the age o eighteen, Mrs. was a vise we would be speaking with her. She expressed, if her daughter had information she wanted to assist. As we interviewed she denied having any inappropriate encounters with Je Epstein . She stated she had gone to Jeff s in Loxahatchee, We met with oor. We explained may have additional worked for Jeff. Mrs. EFTA00232070 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 30 Incident Report Program: CMS301L Case No 1-05-000368 (Continued) House with approximately eight months ago and sat in the kitchen with the house chef but nothing hap ened. 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 s eak with me again to telephone me. Sgt Frick and I thanked Mrs. for her time and left the area. She stated she would ask er 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. S t Frick and I then attempted contact with at er aaug ter. was at t e We ington Ma ana was not home. We explained the ongoing investigation and felt the may have additional information as we had information thatitil had worked for Jeff. 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 approximate) 8:05 am, Sgt Frick had retrieved a voice mail message from She stated she had spoken with her daughter and she a information as to what occurred at Jeff s house. I contacted who stated her daughter was in the shower at the moment an woul e traveling back to Orlando to attend College. I informed her I would be en route to her home in Loxahatchee. Det. Dawson and I drove to the home and met with and taken to the house by She was told she could make money working for Jeff. She was told she would have to provide a massage to Jeff. stated „ rarrival to the house she was brought to the kitchen area by iL They met with the house 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 during the massage. She stated sometime during the massage Epstein grabbed her buttocks and pulled her close to him. said she was wierded out by the incident involving Jeff. At the conclusion of the massage, she was paid $200.00 for the massage. i asked if she has an formal training in massages to which she replied no. I asked her if received any monies for taking her to perform the massa e. stated IIIIII also received money for takin her there. state she went with and another girl, to Je 's house once. stated she waited-in the itc en wi While was taken upstairs by . stated she on y i the massage once, as she was wierded out by t e whole experience. At the conclusion of the interview and the tiiiiias stopped, I was informed that had attempted to reach 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 EFTA00232071 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 31 Incident Report Program: CMS301L Case No - 1-05-000368 (Continued) police questioning. This voice mail message was recorded onto a micro cassette. rovided the incoming telephone number as stated she inadvertently told the police investigation because had calle about jllii! W ill her about how she just received a rents car from Jeff Epstein. had called her to tell her that she was given a rental car, jiii iii Silver Nissan Sentra, to utilize to visit family and visit Jeff. asked her what was oing on at the house that the police would e asking questions. stated then called Jeff and and asked what was going on reference t e ongoing police investigation. According to has since then been t ing to contact her to ask about the po ice questions. I instructed not to contact Elli and do not providel more information to she would not]. Jeff Epstein and what was transpiring. as Investigation Continues... ****************************NA8RATIVE # 8 *************************** NA Reported By: LEE, LA'MONT 10/07/05 Entered By.: ALTOMARO, NICKIE A. 10/07/05 On March 30, 2005, I was asked by Sgt. Daniel Szarszewski to begin conducting surveillance and trash pulls reference Detective Pagan 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 Way and met with Town of Palm Beach sanitation employee, Jeffrey Williams. I observed Williams enter the driveway of 358 El Brillo Way, collect the trash bags from Epstein's property and place the contents into an empty sanitation truck. I followed Williams 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. 'l correspondence from Armani Exchan e addressed to Jeffrey E. Epstein notepaper with 561 messa e note a er addressed to date at 8:15 p.m. referenc , U.S Airways boarding pass copy for passenger, Janusz B on gomery County, Maryland Health Department food service ID for Janusz Banasiak and Ghislaine Maxwell notepaper with names and phone numbers. Photocopies of the trash collected were attached with the supplement. Detective Pagan was advised of the contents that were collected for evidentiary value. EFTA00232072 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 32 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) On March 31, 2005, Sgt. Daniel Szarszewski requested that I set up a surveillance vehicle on El Brillo 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 surveillance was concluded. I reviewed the video tapes and advised Detective Pagan 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 collect E stein s trash, I observed a white female, who I recognized as from her Florida driver's license photograph. I mad h . While parked in the area, I also observed Epstein s GMIII!!!!'"uck 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 Epstein, automotive records and personal documents for Janusz Banasiak and Beata Banasiak as well as Jeffre Epstein note aper with the names and appointment times for and No last names or other personal information was written on t e 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 rectal gratification. The sexual object was photographed for Detective Pagan, packaged in a biohazard evidence bag (possible body fluids) and secured as investigative evidence. All items collected from Epstein s trash were turned over to Detective Pagan 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 EFTA00232073 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. an piece o w ite paper II ( black paper black paper David ( MSN Hotmail web page with email address ( The following items were documented for Detective Pagan s 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 Epstein's trash during my assistance were turned over to Detective Pagan for evidentiary purposes. On June 14, 2005, Detective Pagan contacted me and advised that the airplane belonging to Je rey Epstein of 358 El Brillo Way was parked at the Palm Beach International Airport. Detective Pagan 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. EFTA00232074 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Case No • 1-05-000368 Page: 34 Program: CMS301L (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. ***** ***********************NARRATIVE # *********** ******** ******** NA Reported By: RECAREY, JOSEPH 10/07/05 Entered By.: ALTOMARO, NICKIE A. 10/10/05 On October 4, 2005, I made telephone contact with who had left several messages on voice mail. During t e message, s e 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 15:48 pm, I made telephone contact with at 561- During a taped recorded statement stated e o lowin : Approximately a year ago, when she was sixteen years of age took her to Jeff's house twice. The first time she went, drove to the house. They entered through the kitchen area w ere she was introduced to and Jeff. She was taken upstairs to a bedroom by who set the room up with a massage bed and brought out the oils to use. Jeff then entered the room wearing 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 er shirt at which oint she became very upset and discontinued the massage. Both and Jeffrey had a verbal disagreement at which time she le t wit out being paid. She met with who was sitting in the kitchen and told her let's o. advised she received no money for that day. also saw had told her if she was uncomforta e with what was going on, to let im know and he'll stop. She knew that the more you do the more you are paid. Several weeks later time by in the kiln an advised she agreed to be taken a second Once lley arrived at the residence, sat took her upstairs to the master bedroom again. set the room up with a massage bed and brought out the oils to use. Jeff then entered the room wearing a towel. He lay on the table and picked out a lotion for to rub on him. At one oint during the massage, he tried to touch her buttocks. As was wearing tight jeans and had a tight belt on Jeff was un e to touch her buttocks. Jeff then rolled onto his back during the massage; he . then became upset again and told him she didn't want to be touc e discontinued the attempted to touch her breasts. leave. was waiting for heli iiill i told llillouse. she wanted to said she never returned to m e and was paid $200.00. t en went downstairs where stated she is aware that her friend, was a so at the house and had a problem with Jeff. S e provide a telephone number EFTA00232075 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 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 October 5 2005 I researched the incoming telephone number that had left a message. The telephone number, was assigne to ATT Cingular Cellular service. I prepare 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. Palm Beach. Det. Dawson and at her residence in Royal Palm Beach. illitive to Royal Palm Beach and met with I later researched and discovered she resides in Royal agreed to s eak with us in the kitchen area. During a sworn tape statement, stated the following: On or about November 2004, she was approac ed by and asked if she wanted to make money. She agreed and was to s e would provide a massage to wealthy man in Palm Beach. picked her up and drove her to a house in Palm Beach. She was rou ht into the kitchen area of the house. She further stated that and ( went with them. They were brought into tillitchen w ere she was introduced to Jeff and other females. stated she was introduced to a helper of Jeff; the fema e was described as white female (unknown name) with blond hair. She stated that the assistant was familiar with The assistant set up the massage table and put out lotions to e used. She told Jeff would available in a minute. Jeff entered the room wearing on y a towel. Jeff lay on the massa e table and picked a lotion to rub on his thighs and back. further stated that during the massage Jeff asked her to remove er c othes. 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 touched his buttocks with hers. was instructed to return to the ground at which time Jeff turned to ave his chest rubbed. advised it was at this time she is sure he was masturbating. did not want to look at his penis area because she was uncomfort e. Jeff removed a large white vibrator and turned it on. stated he began rubbing the vibrator over her thong underwear on her vaginal area. Shortly thereafter, Jeff 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 turne 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. 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. EFTA00232076 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. Dawson and I then left the area and responded to the High School where III and all the above-mentioned girls had attended. I met with Sc oo Police Officer, Off Williams. I ex lained I was looking for a previous student who attended High School. I inquired abou . I further explained that I was working a case in which most of the girls I have interviewed are either witnesses or victims and felt that may be one as well. Officer Williams researched his previous stu ent records and foun She attended the same year and graduated in the same ear as t e other girls. i was provided the last known address o At approximatel 2:10 m Det. Dawson and I met with her residence age, I note er, Mrs. e 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. IIIII advised she wanted to cooperate and consented to the interview. During a sworn tape 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 rien s o ' III and knew the iiiimieople. had been previously told by her friends what did for Je called aperson known to III" as TITPT!heduled the appointment. picked up an drove her to Palm Beach to a street called Bri o Way. Ri l drove to the end of the street and entered a large drivewa . They entered the kitchen area of the house and met with Jeff. was introduced to Jeff. led upstairs to the main e room area and set up the room wit 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. e picked oils and instructed her to rub his legs, under his buttocks, back and chest area. Jeff asked her to get comfortable. IIIII advised she did not remove her clothes. She was wearing tight jeans and a cropped tank top exposing her belly area. During the massage, Jeff removed his towel. As rubbed his chest area, Jeff attempted to reach down her pants ilRgh the buttocks area, however was unable to due to the tightness of the jeans rubbed his chest. W moaned as she rubbed his chest. She observed and a tight belt. advised Jeff began to masturbate as she he was continuing to masturbate and attempted to reach up her tank top and touch her breasts. • pulled back and Jeff stopped. However, he kept masturbating untie climaxed. He cleaned himself with the towel he was previously wearing. I asked if she knew the difference-between—circumcised and not circumc sed. She explained she knew and advised Jeff 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 Jeff. She ilowever, go to the house with and as they EFTA00232077 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 37 Program: CMS301L Case No • 1-05-000368 took another friend of advised she went to wor or AP I She advised sat in the itchen area with that while they waited for to wait for was she (Continued) present when rode over and advised the house chef prepare unch for them, as it was almost lunc time. As was finished with the massage, they left the area. I asked if ever told what would be ex ected of her when she prove e a massage. IIIII stated yes, told her that a massage would be expected possibly naked and posse y some touching involved. has no formal training in providing massages. spoke about a third and last time she drove another girl, house. stated s knew t at providing girls for and she wanted to o t e same. Je 's them in the kitchen area of the house and introduced and took upstairs to the main be room. a vise she doesn t know w at ha pened as did not s what happened in the room. received 100.00 from going with her to Jeff s house and recommending unable to remember s telephone number. T e interview concluded and we le t t e area. Investigation Continues... went to Jeff's house. who is friend, ha made money to took eak about for was was **************************** N A R R A T I V E it 10 ** ******* ***************** NA Reported By: RECAREY, JOSEPH 10/09/05 Entered By.: ALTOMARO, NICKIE A. 10/10/05 On October 6, 2005, Det. Dawson and I went to L University located in Boca Raton. We met with Dean of Students, Turner. I explained to Mr. Turner that we were investigating a crime within the Town of Palm Beach and felt that a student, may have information. Turner confirmed that is a stu ent an currently on the soccer team for Lynn University. She was in computer class at the time of our arrival. Turner sent a security guard to locate in class and bring her to the office. Mr. Turner allowed us to interview in an empty conference room. to interview her. She a vise Ellis aware of the ongoing At 11:45 am I met with and explained to her why we there investigation. stated she had previously spoken with tape toldher she was interviewed by detectives. During a sworn tape statement, stated she knew that worked for Jeff in Palm Beac . advised she has been there many times for massages. I asked her i she had formal training in providing massages, stated she did not. advised she was told what o her by providing massages and would have to remove if she felt uncomfortable just to say so and Jeff would the issue. IKE began providing massages and advised clothes on. e considered Jeff a pervert who kept was expecte clothing but stop pushing she kept her EFTA00232078 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 38 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) pushing to go further and further. explained she would keep telling him she had a boyfriend and that it 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. 1111 turning over to have her rub his chest as he masturbated. He explained Jeff wanted to be rubbed on his back and recently he would try to touch her breasts as she rubbed his chest. stated, Jeff would tr to get away with more and more on each massage. iiiiinally, drove her to the house for the original massage. left er cell phone number and every time Jeff would come into town, would call her for an appointment. Each time she went, Mil wou d meet her at the kitchen door area. She would bring her upstairs and prepare the massage table. advised Jeff would ask her questions about herself. He knew she was a soccer player and would be attending Lynn University. I asked if he knew her real provill iiwas on October 1, 2005. During the massage she asked Jeff if age, stated Jeff didn t care. The most recent massage she she could borrow one of his vehicles to visit her family and boyfriend in Orlando. Jeff had told she could borrow one of his vehicles but later stated he would rent her a car. She continued with the massage as Jeff rabbed her buttocks and caressed the buttocks cheeks. I asked if she was wearing undergarments to which she replied her thong un erwear. Once he tried to touch her breasts she would pull vibrator on her. 'III, was aware Iiii e vibrator but advised she away from him and he would stop. was asked if he ever used a never would allow im to use the vibrator on her. She described the vibrator as a 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. 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. had in ormed her that Jeff had rented her a new Nissan Sentra and she should come by the house to ick it up. 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 as a her if she ever took any one to the house. explained she took a friend of hers who has returne to Orlando to attend cll.. I as ed 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. Dawson and I went to the G area and located the Silver Nissan Sentra bearing Florida tag . The vehicle is registered to Dollar rent a car out of the Palm Beach InieLnational Airport. Tele hone contact was made with the victim's mother, at I explained to he/1kt I was ollowing up on this case and provi e a complete update on the case. Investigation Continues. EFTA00232079 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 39 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) ****************************NARRATIVE # 11 ************************** NA Reported By: RECAREY, JOSEPH 10/21/05 Entered By.: ALTOMARO, NICKIE A. 10/21/05 On October 10 2005 at a roximately 2:30 p.m., I made tele hone contact with During a taped conversation, was told of an ongoing investigation in which I felt she had in ormation pertaining to Jeffrey Epstein. explained she met Epstein when she was just sixteen years of age. She was approached by a friend who also had previously gone to Epstein's ouse for massages. advised she was working at the Wellington Mall when she was approached. told her that she would have to provide a massage to Epstein an s e would have to perform this massage naked. ill minutes of work. She agreed to perform the massage and 30 on the appointment for her that same day. remembered it thought about the offer and stated she could make $200.00 for was a weekend as she only worked at the mall on the weekends. took her to the house where she was introduced to , Jeff Epstein's assistant. took her upstairs to a master bedroom. explained that as she was walking up the stairs she observed several hotographs of naked women along the walls and tables of the house. ill' further explained that she was brought into the bedroom where prepared the room by setting up the massage table and provided t e oils for her to rub on Epstein. Epstein entered the room and introduced himself. Epstein lay on the table and told her to get comfortable. could not remember if he was naked or if he entered the room with a towel. stated she provided the massage wearing only her panties. She continued rubbing his legs, thighs and feet. IIII advised he turned over onto his back. She continued to rub his legs with the oils. Epstein touched her breasts and began to masturbate. I asked if she knew what circumcised and un-circumcised meant. stated circumcised is when the penis has no foreskin and the head o the penis is visible. stated she had been to his houllitandreds of times over a two-year said Epstein is circumcised. began to cry on the telephone and period. She 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 upset, crying hysterically and stat and instructed to have sex with Epstein's assistant, by Epstein. Epstein continued to watch them have se himself as they had sex with each other. She further stated that things escalated further and-further. tpdtein used sexual toys such as vibrators, rubber penises and strap-on penises on She claimed he Epstein) put his fingers inside her vagina while he Additionally, stated he performed oral sex on her numerous times. masturbated in an attempt to make her climax. could not continue and wanted some time to regain her composure. I explained to to take her time. After taking several minutes to regain her composure I EFTA00232080 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 40 Incident Report Program: CMS301L Case No • 1-05-000368 explained that I would travel to meet had additional information to provide explained the importance to meet with agreed and made arraignments for Det. in Jacksonville, Florida. (Continued) with her in person as I felt she I met with Sgt. Frick and in person. Sgt. Frick Dawson and i to meet with On October 11 2005, at 4:10 p.m. Det. Dawson and I met with and her friend, at in ac sonvil!!!Florida. Ill' wan tlill" present or support. I explained to r that I did not ave iiiioblem as long as she wanted present during the interview. stated she wanted her present. I explained that as was present she was not allowed to comment or ask any questions uring the interview. She was only there to comfort should the interview upset her. During a sworn taped statement, e how everything bean. She said she was brought through t e kitchen area where she met for the first time. She was led to the master bedroom, Epstein s observe severalphotographs of naked women along the walls and tables room. explained that as she was walking up the stairs she of the house. further explained that she was brought into the bedroom, where prepared the room by setting u the massage table and provided the oils for her to rub on Epstein. explained she remembered the steam room area, which contained two arge showers. Epstein entered the room from the steam room area and introduced himself. Epstein lay on the table and told her to get comfortable. "li removed her skirt and kept her shirt on. She could not remember e was naked or if he entered the room with 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 onl her panties. She continued rubbing his legs, thighs and feet. advised he turned over onto his back. She continued to rub his egs with the oils. Epstein touched her breasts and began to masturbate. Epstein ejaculated which meant the massage was over. At the conclusion of the massa e, was paid $200.00. They walked together downstairs where and were waiting. stated received an unknown amount o 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. 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 there. There were times she went to dinners and parties with Epstein. explained that things began to escalate more than the massa e.ill.e encounters included bringing in his assistant, . explained Epstein had purchased her from her ami y in Yugos avia. Epstein bragged he brow ht her into the United States to be his Yugoslavian sex slave. advi, s ked in the bedroom, she entered and removed her c othing entered the room from the steam room area already naked. H to perform oral sex on EFTA00232081 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 41 Incident Report Program: CMS301L Case • 1-05-000368 (Continued) refused to perform that act. Epstein offered her five minutes. an additional 200.00 for her to perform oral sex on for minutes. agreed to perform the oral sex f $200.00. explained that Epstein would masturbate while he watched them perform sexual acts. had massagers, vibrators and strap on rubber penises used on her. Things continued to escalate by purchasing sex toys. stated she Each time somethin new was introduced additional monies were produced and offered for to allow the acts to happen. was adamant that she performs a 1 these acts but there was an understanding with Epstein that no vaginal penetration would occur with his penis. IIII explained that Epstein's penis was deformed. III 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 the sexual encounters with , Epstein and upstairs, here Marcia. and Epstein were waitin . would her became a ritual. would arrive at the ouse and walk herself clothing and join them on the bed. explained d she would begin by kissing and touc ing each other. ained sex toys were brought into the bed by either Epstein or and they would begin using the toys on each other. Epstein would per orm oral sex on either person depending who was on top during the intercourse. explanation revealed they were in a missionary position. t is incident occurred)""e came to the house after had informed advised one day, ( was unable to state and exact date when her that Epstein had arrived. She arrived at the house and went upstairs to the advised she immediately removed her clothin as E stein were already naked in the bedroom. exp sane t at and she had a sexual encounter to include kissing, ouc ing an oral sex. remembered that she climaxed and was removing her self from the massage table. asked for a sheet of paper and drew the massage table in the master bathroom and where Epstein, and she were. Epstein turned on to her stomach on t e massage ed and inserted his penis into her vagina. stated Epstein began to pump his penis in her vagina. became upset over this. She said her head was being held against the bed forcibly, as he continued to pump inside her. She screamed no, and Epstein stopped. She told him that she did not want to have his penis inside of her. 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 there were times that she was so sore when she left Epstein's house. IIII advised she was ripped, torn, in her vagina area. adviseaihe had difficulty walkiiiiio the car after leaving". house because she was so sore. advised that other EFTA00232082 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 42 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) than that one time, when Epstein inserted his penis inside her vagina, there was no other penile intercourse. provided names of girls that she knew of that have gone to Epstein's house. provided the name of and feels she still miiiiiigoing to the house to massage Epstein. According to is still sucking his dick." When asked if she had been recently contacted by anyone of the house, advised she received an email from , which is her email , from illicount. The email was just a e o, ow are you doing type of email. There had been no other contact from the house. The interview was concluded and left the area. The tapes and drawing were submitted into evidence. Investigation continues... ****************************NARRATIVE # 12 ************************** NA Reported By: RECAREY, JOSEPH 11/01/05 Entered By.: ALTOMARO, NICKIE A. 11/07/05 On October 12, 2005, Det. Dawson and I traveled to the Orlando area and made telephone contact with agreed to meet with us as we were in the Orlando area. rovi ed directions to her apartment. Det. Dawson and I met wit who stated, during a sworn taped statement that nothing happened etween her and Epstein. fillifoken with other people who advised differently. stated appeared nervous during the interview. I assured her that I she only went a couple of times and provided a massage to Epstein. She stated she was brought to the Epstein house in March of 2005. brought her to work. has no formal training in providing massages. stated si orovided a massage, fully clothed for $200.00. As I sensed hesitancy in her answers, I asked if she had been contacted by anyone from the house. stated she was interviewed already by an investigator for Epstein. He met with her on OctobeEAL 2005, at a Roadhouse in Orlando. He identified himself as IIII and in ired about the police investigation and left his telephone number for additional contact provided no additional in ormation, 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, 2005, 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 Brillo in Palm Beach. Members of the Investigations Unit included Capt Gudger, Sgt Frick, Det. Dicks, Det. Dawson, Det. Melnichok, Det. Sandman, Det. Krauel, the crime scene unit and myself. EFTA00232083 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 forced entr was made. made contact with Banasiak, Date of Birth Fl DL , and informed him of the searc 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 members exited the home. I read the search warrant to Banasiak as Mgr Parkinson 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 in New York. Mr. Estes stated he has worked for Zeff for seven years. He advised he personally worked on the New York and Palm Beach home for Mr. Epstein. He has previously met with and , Epstein's assistants in New York and in Florida. Estes state they travel with Epstein everywhere he goes. I interview& of Jersey City, New Jersey. stated s e just arrive l rom Scot and and has worked with Zeff or on y 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 Dr in New York City. Schoettle stated he has been Ep ect for seven years. He further stated he deals with Epstein's assistants and speaks with stein on the phone. Schoettle stated he mainly speaks with , Epstein s main assistant, who travels with Epstein. Schoettle state 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. Krauel and I began in the master bedroom area where several items were located. They were EFTA00232084 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 44 Time: 8:47:53 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 Jeffre Epstein we located a hi h school transcript from High School for Also in the room, was e resser /armoire where we ocated a ott e 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.. ****************************NARRATIVE # 13 **************** ****** **** NA Reported By: PARKINSON, GREGORY A. 10/20/05 Entered By.: ALTOMARO, NICKIE A. 11/07/05 On October 20, 2005, at approximately 8:30 a.m., Thursday morning, I was advised by Captain Gudger that a search warrant would be executed and that I was to assemble the Crime Scene Investigative Team and stand by the south side of the building ready to go. I designated Evidence Specialist to handle the inventory return, the documentation of the property receipts and the collection and bagging of the evidence at the scene. I further instructed CSI Kim Pavlik, ID # 8807, to accompany us and perform the role of photographing the scene and the items that may be taken into custody by the affiant, Detective Joseph Recarey, 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 search was conducted, items were collected by Evidence Specialists Badger, EFTA00232085 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 45 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) photographed by CSI Pavlik and then videotaped by myself. The search was concluded at approximately 3:05 p.m. whereupon Detective Recarey and I were the last two officers in the house. Upon securing the residence we met with the gentleman who identified himself to Detective Recarey 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 Recarey and I returned to Police Headquarters and secured for the day. ****************************NARRATIVE # 14 ************************** NA Reported By: DAWSON, MICHAEL C. 11/07/05 Entered By.: ALTOMARO, NICKIE A. 11/07/05 On October 20, 2005, I assisted Defective Recarey 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, Daniel Estes, and Mark Zeff. As other members of the police department cleared the home, I kept watch over these three males. Once the house was cleared, those males were turned over to Detective Recarey. Detective Dicks 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. The combination was entered by Banasiak in the presence of Sgt. Frick 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 EFTA00232086 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 1 s living quarters. Numerous CD s along with a message book was seized. See the property receipt for details. ****************************NARRATIVE # 15 ************************** NA Reported By: RECAREY, JOSEPH Entered By.: ALTOMARO, NICKIE A. 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 6, 2005, I attempted contact with at her residence. I left a business card for her to return my ca 1. Upon returnin to the olice department, I had received a telephone call from I returned her call at 561-M -MI and spoke with S e made arrangements to respond to the station to provi e an interview. At approximately 3:30 pm, she arrived at the Palm Beach Police Station with her boyfriend. Her boyfriend was allowed to sit in the lobby area while Ms. was interviewed. 11/08/05 11/08/05 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 one iiiiiiimately 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 rent t t III. month. She agreed to go to the house. She had been told by that the massage would have to be done in her underwearliii! 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. M il 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 time. EFTA00232087 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 47 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued introduced himself as Jeff. III, advised she recalled she and removed their clothing down to their panties, Epstein lay 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 s orts 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 Epstein turned over onto his back. Epstein then removed the towel, which had been around his waist. Epstein laid there naked and requested that rub his chest area. stated as she did this, EpsteinIIIMn masturbating as she MR his chest. stated he pulled down her boy short panties and he producedi li Rge white vibrator with a large head. She stated it was within a drawer in his master bathroom. He rubbed the vibrator on her vagina area. advised he never penetrated her vagina with the vibrator. He continued to rub her vagina with the vibrator as he continued to masturbate. stated she was very uncomfortable during the incident but ew it was almost over. Epstein climaxed and started to remove himself from the table. He wiped himself with the towel he had on previousl and went into the shower area. got dressed and met with provided in the kitchen area. Epstein cameinto the kitchen and $200.00 for bringing and paid $200.00 to for provi in the massage. was told to leave her telephone number with IIIII, his assistant or future contact. provided her cellular telephone number for future contact. was asked if she was recently contacted about this investigation y 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 Epstein. stated work is the term used by to provide the massage in un erwear. advised she decline , as she was not comfortable in providing that type of work. The interview was concluded and the videotape was placed into evidence. Investigation Continues.. ****************************NARRATIVE # 16 ************************** NA Reported By: RECAREY, JOSEPH 11/10/05 Entered By.: ALTOMARO, NICKIE A. 11/10/05 On November 7, 2005, I made telephone contact with IMII.Mj maxv:ho advised she would be able to meet wIrh me at her home. _ et. and I traveled to her home in During a sworn to Je frey Epstein through who wished to work for h him but declined. explained that work means give massages. She was asked about any ormal training in providing massages to which she said no. said she accompanied and other females and made contact with stated she met would approach females state she was asked to work for EFTA00232088 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 48 Incident Report Program: CMS301L Case No 1-05-000368 Continued) who were taken to Epstein s house to provide massages. further stated she had been to the house approximate) 4 or 5 times in III, the ast ear. iiiiima7le accompanied VitiLm, and Eac time t e gin rrere 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 and the were not comfortable just to tell him and he would stop. stated received $200.00 for each girl she brought over to massage Je rey Epstein. When I asked which girl appeared to be the youngest, she replied, the victim, as she stated she was fifteen years old at the most; she looked really young. further stated each time she went to the house, she sat in the itc en 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. The interview was concluded and the tape was turned into evidence. Investigation Continues.. ****************************NARRATIVE # 17 ************************** NA Reported By: RECAREY, JOSEPH 11/10/05 Entered By.: ALTOMARO, NICKIE A. 11/10/05 Det. Dawson and I attempted contact with in Royal Palm Beach. I left my business card at her front door. Ms returned my call and arranged a meeting with me at the Police Department for November 8, 2005. At approximately 2:00pm, arrived at the Palm Beach Police Department. She was brought into t e 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 encounters with him in the past. During a sworn taped statement, stated she had met Epstein a roximatel two ears ago. She was irst introduced to Epstein by approached her about working for Epstein and providin a massage to him for $200.00. The arrangements were made and as could not take her the day the arran ements were made, took also attended High PM an was fame tar 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 photograp s Plied females throughout the house. stated E stein 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 er Palm Beach EFTA00232089 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 49 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) clothing. stated she had returned several times after that. Each time s e returned more things happened. stated that the same thing would happen. Epstein would walk into t e master bedroom/bathroom area wearin only a towel. He would masturbate as she provided a massage. stated she was unsure if he climaxed as he masturbated under t e 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/vibrator, which she described as white in color with a large head, on her. Every time she provided a massage he would masturbate. formal training in providing a massage. two females during her visits to provide brought a girl named and High School. stated s e received 200.00 for eac girl she brought. Additions y, was given $200.00 for taking her in the very beginning. The interview was concluded and the tape was placed into evidence. Investigation continues... added she has no stated she brought massages. stated she from ****************************NARRATIVE # 18 ************************** NA Reported By: RECAREY, JOSEPH 11/13/05 Entered By.: ALTOMARO, NICKIE A. 11/14/05 On November 8, 2005, I made telephone contact with W/F, at her residence. responded to M il l ice 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 one year ago. She was approached by a subject known to her as had asked her if she wanted to make money providin massa es to Epstein. making money. She agreed and was taken to the house by High Scholl/it doiiiiiiis and had heard that several girls from had introduced her to EMIR and Epstein and brought her upstairs to a master bedroom and Master nathroom where a massage table was prepared and the proper oils were taken out. left the room and waited downstairs for stated Epstein entered the room wearing a towel and she prove ed 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 received $200.00 for bring to Epstein. IIIII stated she had gone a total of 15 times to his residence to provide a massage and things had escalated from just providing a EFTA00232090 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: SO Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) massage. Epstein began touching her on her buttocks and grabbed her closer to him as he masturbated. Epstein also grabbed her breasts and fondled her breast with his hands as she provided the massage. stated on one occasion, he offered extra monies to have vaginal intercourse. She stated this all occurred on the massage table. stated Epstein penetrated her vagina with his penis and began having intercourse with her until he reached the point of climax. Epstein removed his enis from her vagina and climaxed onto the massage table. received $350.00 for her massage. I asked her if she had any forma training in providing massages, stated she did not. IIIII continued to state on one other occasion, Epstein introduced his assistant, , into the massage. Illiwas brought into room with to provide a massage. Epstein a them kiss and fondle each of er around the breasts and buttocks as they provided a massage to Epstein. Epstein, watched and masturbated as this occurred. On other occasions, Epstein introduced the large white vibrator/massager during the massage. Epstein stroked the vibrator/massager on vagina as she provided the massage. stated the last time she spoke with anyone at the house, was with during the weekend of October 2 or 3, 2005. IIIII stated she had brow ht two eople to the Epstein house. She provided the names of and (unknown last name). It should noted, ha een previously identified as and had been previously interviewed. The interview was conc ude an the videotape was placed into evidence via the locker system. On November 9, 2005, Sgt Frick 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 then traveled to Lynn University and met with Dean of Students, Mr. Turner. We requested to speak with was re interviewed, as she still was inpossession 9 1111 renta car that Epstein had acquired for her. stated that Epstein's assistant, had called her on her ce lular telephone an informed her that rental was extended for her. stated she had paid an additional $625.00 for her to keep ental an extra month. was asked if she had any additional contact with either Epstein or anyone from his organization. stated she did not, other than the telephone call informing her t at 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 EFTA00232091 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 51 Program: CMS301L Case 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 home. I received a telephone call from Attorney Donald Morrell from 686-2700. 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. **************************** N A R R A T I V E # 19 ************************** NA Reported By: RECAREY, JOSEPH 11/15/05 Entered By.: ALTOMARO, NICKIE A. 11/16/05 On November 14, 2005, Det. Sandman and I traveled to in Loxahatchee, Florida and spoke with FM e was of the ongoing investigation involving Epstein. advised she had gone to the house on several occasions. During a sworn taped statement, she advised she started oing to the house approximates year a o and was brought by (Unknown last name). stated brought her into t e ouse and she was introduced to a girl name . Once she met her, brought her upstairs into a master bedroom athroom. state she met Jeffrey in the bathroom. He lay on the to e an 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 massage. stated she had only been at the house approximately five or six times. said each time she went to the house she was notified by , Epstein's assistant, 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. EFTA00232092 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Case No • 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 was not until the third time she went that she remove clothing. stated she was notified by that Epstein wanted her to come to work. She arrived at the ouse and was led upstairs by . She started providin the massage when Epstein asked her to remove her clothing. removed her pants, shirt and bra. She stayed in her thong panties and continued rubbing Epstein. E stein turned over onto his back and she rubbed his chest area. stated she knew he was masturbating himself as she providing t e massage. stated she believed he climaxed based on his breathing. She di 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 ressed. She was paid $300.00 for her services. stated on the last time she went to provide a massa e, she was notified by to come to the house and work. stated she was now dating her current boyfriend and did not fee com ortable 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 wearin only a towel as he entered the room to lie on the table. stated Epstein caught her looking at the clock on several occasions. Epstein asked her if she was in a hurr 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 or " stated she received $200.00 from Western Union in and Okeechobee Blvd as a Christmas gift. advised 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. I 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. --********-**a*****************NARRATIvE 4 2D ***********************t**-_ . NA Reported By: SANDMAN, R. 11/16/05 Entered By.: ALTOMARO, NICKIE A. 11/17/05 On 10/20/2005, I assisted executing a search warrant at 358 El Brillo Way in the Town of Palm Beach, Palm Beach County Florida under the direction of affiant Detective Joe Recarey. EFTA00232093 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 Melnichok 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 Suburb Florida tag registered to Jeffrey Epstein DOB which was located on e east side of the driveway facing south. I found a Thrifty rental agreement between the passenger seat and the middle console. The name on the rental agreement was from III Palm Beach Gardens, Florida 33411illieliM i number on t e rental agreement was (561) The vehicle rented was a white 2005 Chrysler Sebring bearing Florida tag The vehicle was rented on 9/25/05 at 17:58 hours and was returned on 9/26/05 at 16:52 hours. The last four numbers of the credit card used are Detective Melnichok found a piece of paper in the middle console that said I used the cash in here to fill up the tank and was signed by on searched the 2005 black Cadillac Escalade ESV bearing Florida tag registered to Jeffrey Epstein do4MMIIMMOMM, which was loca i e on he 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. ****************************NARRATIVE # 21 ************************** NA Reported By: RECAREY, JOSEPH 11/17/05 Entered By.: ALTOMARO, NICKIE A. 11/17/05 EFTA00232094 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Case No • 1-05-000368 Page: 54 Program: CMS301L (Continued) On November 15, 2005, Det. Sandman and I traveled to 2950 Fontana Place in Royal Palm Beach. We met with a seventeen-year old juvenile who was not n schoo t is day due to a cold from which she was suffering. was told that I needed to speak with her in reference to an ongo ng nvestigation 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 parents rior to speaking with her. She telephoned her father, Mr. on his cell phone and explained to him that Det. San an an I were there to speak with her. I spoke with Mr. on the telephone and informed him I needed to s eak with his aug ter in reference to an ongoing investigation. Mr. advised he had no problem with us speaking with his daug ter. During a sworn taped statement, stated she met Jeffrey Epstein over a ear a...She was sixteen years of age and was approached by who informed her that she could make monies providing a massage to Epstein for $200.00. had informed her that she would have to provide this massage top ess.made the arrangements with Epstein and his assistants and took to the house. stated and she entered through 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 matchin shower. stein entered into the room wearing only a towel. and removed their clothing remaining only in thong un erwear. She further stated that Epstein lay on his chest on the table. stein selected which oils to use for the massage. Both and 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 instructe to finish the massage. As reseed, starting rubbing his chest. lef!ill room, and Epstein e an masturbating himself as got rubbed Epstein s chest. stated he continued mastur at ng until he climaxed on the towe e was wearing. When asked if he had removed the towel she stated he turned the towel around so 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 met with him downstairs. got dressed and met with Epstein in the kitchen area. She was pal 200.00 dollars for providing the massage. stated she was aware that also received monies for the same t 'lag. The second time she went to the house she was again approached by asked if she wanted to return to the house to provide another massage; agreed and the arran ements were made by for her to return to the house. stated drove her to the house and knocked on the same glass oor that lea s to the kitchen area. The were allowed entry into the house by one of the staff members. led her upstairs to the master bedroom and EFTA00232095 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 massa e alone. Epstein enteredltliroom again wearing only a towel. began removing her clothing as she did the last time she was at t e house. Epstein instructed her to get naked. He lay on the table on his stomach as began massaging his legs and back. As finished with E stein's back and legs, Epstein then turned over onto is back. started to rub his chest and he began masturbating himself. As rubbed his chest, Epstein leaned over and roduced a massager vi rator. He turned it on and began rubbin• s vagina and masturbating himself at the same time. state• she continued to rub his chest as this was occurring. S escribed the vibrator/massager as large, grey with a large head. Epstein rubbed her vagina for approximately two to three minutes with the massager/vibrator. He then removed the vibrator from her vaginal climaxed onto the towel again and informed her till iIIIimassage was area and concentrated on masturbating himself. stated he kitchen area. She received $200.00 for ti!lissage. said done. got dressed and met with who was waitin in the she never returned to the house and had no desire to return to the traininjIlit ilildvised she had no formal training. was asked house. was asked if she received any formal massage if Epstein knew her real age. stated he knew as e asked her questions about herself and hi sc oo . He was aware she attended and is still attending High School. The interview was concluded. I suggested inform her parents of what occurred at the Epstein house. stated she would tell 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. ****************************NARRATIVE # 22 ************* ***** ******** NA Reported By: RECAREY, JOSEPH Entered By.: ALTOMARO, NICKIE A. 11/17/05 11/17/05 On November 15, 2005, Officer Munyan and I res onded to the Palm Beach Gardens Mall food court section to meet with At approximate) 5:10 p.m., arrived and met wit 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 be an going to Epstein's house when she turned eighteen years old. was asked if she knew of the on-going investigation. stated she was aware ttele 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 EFTA00232096 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 56 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) respond to an 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 masturbate and climax. She stated things escalated from there. She provided oral sex on Epstein and he provided oral sex on her. She stated he would also use a massager/vibrator on her va ina to s He introduced his assistant or with . She stated to her as she massaged him. to have vaginal intercourse would utilize a strap-on (sync etic penis) to have in ercourse with her. She was told to masturbate herself as Epstein and had sexual intercourse. All this was done at Epstein's directi could not rovide exact dates as she had been to the house so many times. stated Epstein inserted his fingers in her vagina to stimulate her as she massaged him. When I asked her if there had been any vaginal intercourse with Epstein, she stated she did not have IIIIII llistual favors. sex with him. She did admit having sex with his assistant. stated not every time she went involve sometimes she would just talk with him and get paid. I asked her how much she was paid each time she went to Epstein a residence. stated she got paid $300.00 every time she went to the house. She was told to bring other girls to him to provide massages. declined stating that she does what she does and 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 six. She reviewed the six photograp s an immediately identified as the person with whom she had intercourse. , it was the same person she watched have intercourse with Epstein. She signed the photo line-up under Illim s photo as the person she identified. We then left the mall and returned to the police station. The photo line up and tape were placed in to evidence. Investigation Continues... ****************************NARRATIVE # 23 ** ****** ****************** NA Reported By: RECAREY, JOSEPH 11/29/05 Entered By.: ALTOMARO, NICKIE 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 fcit 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 EFTA00232097 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 - 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 EFTA00232098 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. ****************************NARRATIVE # 24 ************************** NA Reported By: RECAREY, JOSEPH 11/29/05 Entered By.: ALTOMARO, NICKIE A. 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 EFTA00232099 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 59 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. ****************************NARRATIVE # 25 ******************* ****** * NA Reported By: RECAREY, JOSEPH 12/15/05 Entered By.: ALTOMARO, NICKIE 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 girls for 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 High School yearbooks for 2005, 2004 and 2003. I first reviewed the 2005 yearbook and located most of the girls I had spoken with. Additionally, I located Based on the corrected name spelling, I was able to locate her to her residence in Loxahatchee. On December 8, 2005, Det. Caristo and I responded to in Loxahatchee. I located at her home. She advised she is attending Hill. is participating in the early release program so 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 previously researched the telephone number for " and telephone number 561- A subpoena had been issued or t e information on 561- The telephone number was re istered to -of- A query of revealed that she is the aughter o and is current y residing at in West Pa m Beac . Det. Caristo and I attempted with negative results. I left my business card on her front door re nesting she return my call. We then responded to IIIII I in West Palm Beach. I also attempted contact with Mr. with negative results. I left my business card for him to return my call. contact with EFTA00232100 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 60 Incident Report Program: CMS301L Case No 1-05-000368 (Continued) On December 9 2005, I received a telephone call from IIII mother, who was made 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 daughter about what occurred and would cooperate with the investigation. provided me with cellular telephone number to sche u e an appointment for an o icial interview. I telephoned her cellular telephone and made a tentative appointment for Monday, December 12, 2005. I then received a telephone call from father of who stated he found the business carlitillis door. I explained that I was conducting an investigation and needed to speak with IIIII as she ma have 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, due to a conflict with schedules, arrangements were made to meet with on Tuesday, December 13, 2005 at 5:00 pm. On December 1 2005, Det. Dawson and I traveled to Loxahatchee and met with During a sworn taped statement, stated t at w en s e was sixteen years old, she was taken to Epstein's house to provide a massage for mone stated it was before Christmas last year when a roached her and asked if she needed to make money for C ristmas• stated she did and agreed to rovide a massage for money. ma e arrangements to take to the house and drove to the house to "work." state s e could not remember the street name but would be ab e 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. They knocked on the door and were encountered by an employee that ...were expected. They were then encountered by a white female who described as a "Spanish looking lady." They informed her with long blond hair. was unable to remember the name of the white female with blond air 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 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 la on his stomach so that may massage his feet and calves. started the massage with the massage oil Jeff chose and ru e is feet and calves. Jeff 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 EFTA00232101 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 61 Incident Report Program: CMS301L Case No 1-05-000368 (Continued) requested she remove her pants and shirt. 'pill removed her shirt and pulled her pants off. III" stayed in rbra and thong panties. As she finished the small o t e back, Jeff then turned onto his back. He instructed she rub his chest and pinch his nipples. As she be an to rub his chest, Jeff asked her questions about herself. remembered telling him she attended Scoo . Jeff asked her if she was sexually active. Before IIIIIIIIIIIIIIII ii ii could answer, he also asked what sexual positions does she enjoy. stated she was shy didn't like talking about those things. She continued rubbing his chest. Epstein reached up and unsnapped her bra from the front. explained the bra she used had a front snapping device. Epstein rubbed her breasts and asked her if she like having her breasts rubbed. said "no, I don't like that." Epstein then removed his tows an lay on the bed naked exposing his penis to He be an touching his penis and masturbated as he touched her reasts. explained Jeff then touched her vagina area by rubbing her 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 , "Relax, I'm not going inside." She urt er explained Jeff commented to her how beautiful and sexy she was. Jeff then moved her thong panties to one side and now was stroking her clitoris. said "Jeff commented how hard my clit was." He then inserted two angers in her vagina and was stroking her within her vagina. She tried pulling back to pull out his fingers from within her vagina. Jeff removed his fingers from within her vagina and apologized for putting his fingers inside her. Durin• this time he kept his hand on her vagina area rubbing her vagina. stated he rubbed her real hard as he was masturbating. sal• he climaxed onto the towel he had been previously wearing an got up from the table. Jeff told her there was $200.00 dollars for her on the dresser within the master bathroom. Jeff also told 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 IIIIIelephone number with his assistant as he wanted to see her again. Jeff 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 an ew what happened to her was wrong. She 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... ****************************NARRATIVE # 26 ***********+************** NA Reported By: DICKS, ALLEN C. 12/18/05 Entered By.: ALTOMARO, NICKIE A. 12/19/05 EFTA00232102 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 of the premises for safety purposes. I then accompanied CSEU tech Pavlik while she photographed the exterior of the house. Once this was complete I was assigned to search certain areas of the house with Det. Dawson 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 tth —ffini- 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. EFTA00232103 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 63 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) **************************** NARRATIVE # 27 ************************** NA Reported By: KRAUEL, CURTIS D. 12/21/05 Entered By.: ALTOMARO, NICKIE A. 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, residence of Jeffrey Epstein. I was instructed by Case Agent Det. Joseph Recarey, to secure all computer and media related material from the residence. Upon my arrival I was directed by Det. Recarey 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. Recarey 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. Recarey 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. EFTA00232104 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. Recarey 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 remote access. 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 and shutdown all other media. The Premio CPU, marked with Serial Number , was secured and turned over the evidence custodian foji li lig irensic 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. ****************************NARRATIV8 # 28 **************** ****** **** NA Reported By: RECAREY, JOSEPH 12/21/05 Entered By.: ALTOMARO, NICKIE 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 during the week of 12/19/2005. I made contact with State Attorney Inv Theresa Wyatt and requested the same via telephone message. I then researched the victim's li cellular telephone subpoena data which had been received from a previous subpoena re est. 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 incident occurred at Epstein s house. The first incoming call was from residence at 561 III The second incoming call from EFTA00232105 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 65 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) were one minute orlF3i. he time frame was within thirteen minutes cellular phone 561 occurred at 1:02 pm. The call durations apart. It should be noted that s residence was in close proximity to the victim's. The next call occurred at 5:50 pm when the victim telephoned s residence. Several calls were made after the above mention ca s both incoming and outgoing to Further analysis showed no telephone calls to either cellular telephone or residence were registered prior to Fe ruary 6, 2005. Additional) I also conducted an analysis on the telephone calls from 305- The subscriber information confirmed that the number is registers to A Lavery from Hialeah, Florida. The address was crossed reference 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. The tele hone calls revealed Lave had telephone contact with II and either just after I attempted to interview t em, 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 eo page and decorate the page an wa one wishes. I found the followin le have m s ace sites: h and I received a Cingular Wireless packet which contained a CD which contained the results of the subpoena request for verbatim calls on An analysis will be conducted in the near future on the p one n ers called. Investigation Continues ********** *****************_n B. R _A ra # 29 ************************** NA Reported By: RECAREY, JOSEPH 12/27/05 Entered By.: ALTOMARO, NICKIE A. 12/29/05 Upon doing research on the message warIaaLLlocated the identity of 561 was registered to seventeen years old and is atten books recovered in the search The telephone number She currently is ng t e Pa m ach Mall Academy. I EFTA00232106 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 66 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) responded to 1801 Palm Beach Lakes Boulevard, also known as the Palm Beach Mall. I located the Simon Youth Foundation. I located inside the foundation and informed her that I was investigatin a case 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. Caristo and I then located at her residence located at in West Palm BeallIIII attempted to interview her about Je rey 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 our arrival at her residence I had telephone contact with her father who was told she would be interviewed. is currently seventeen years old and as a juvenile, parents notification would be required. We then left the area and returned to the police station. while at the police station, I left another telephone message for parents. I began an anal sis of Cellular telephone. The telephone number is assignee to and the financially response• e party is Jeffrey Epstein o 457 Ma ison 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 identify 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." This confirms 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. ****************************NARRATIVE # 30 ************************** NA Reported By: RECAREY, JOSEPH 1/03/06 Entered By.: ALTOMARO, NICKIE A. 1/03/06 On December 29, 2005, I received a facsimile from National Compliance EFTA00232107 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 67 Incident Report Program: CMS301L Case No • 1-05-000368 Continued) Center from Cingular Wireless for tele hone number 561- This was the tele hone number for during the time rame when the victim, was brought to t e Epstein house to "work." An analysis of t e phone records, of all incoming and out Ding calls, showed that on February 6, 2005, t ictim, was brought to the house, first called , Epstein's assistant, at at 12:50 pm (EST). 11 was made to Epstein's house in Pa m Beach, at 12:52 pm (EST). The following call was made confirms the illrmation i provided by the victim and victim's father. to the victim, at 1:01 pm (EST) and at 1:02 pm (EST). This I photo copied the records 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 Langley's parents. I will attempt to establish contact wit t em 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 Dershowitz and two www.m s ace.com profiles. The profiles networking service t atillows members to create unique personal were that of and MySpace.com is a social 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 profiles Mr. Dershowitz enclosed. who designed her blog to be " Fucking still atten High School, sen s an 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. Dershowitz. Ms. esirlil ier blog to be "PimpJuice." Her blog I then reviewed web blog which was provided by Mr. states that her interests include music, theater and weed (Marijuana). I reviewed her packet in which II, declares her love for her live-in boyfriend. 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 speech impediment", did not claim to e JAL they impersonate investigators used-t-dihterview had "quite a distinct police officer. This package was sent to both ASA and ASA at the State Attorney's Office. I made telephone contact with ASA to confirm she received the package and request an interview with and Janusz Banasiak. She advised she would assist in attempting to EFTA00232108 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. ****************************NARRATIVE # 31 ************************** NA Reported By: MINOT, LORI S. 1/03/06 Entered By.: ALTOMARO, NICKIE A. 1/03/06 on Thursday, 03/31/05, I started conducting surveillance at 358 El Brillo. At this point I observed at 1155 hours, a Tan Altima bearing FL tag A303AN in Roadway, Black SL bearing FL tag V55RFW in drive, Tan driveway and a Black Cadd Esc, in driveway. At 1325 Hours I Honda Civic bearing FL tag in Roadway, Black Chevy Suburban in observed Tan Honda Civic in roadway, Black Chevy Suburban in drivewa Black Caddy Esca a e in drive and a White Kia car bearing FL tag At 1615 hours I observed a Tan Honda Civic, in roadway, E ack Chevy Suburban in drive, Black Caddy Escalade in driveway and a White Kia car in roadway. On Friday, 04/01/05, I continued surveillance at 358 El Brillo. At 1130 hours I observed a Tan Honda Civic bearing FL tag in roadway, Black Cadd Escalade in driveway and a Tan unknown make/model bearing FL to in roadway. At 1227 hours, I observed a Tan Honda Civic in roadway, Black Caddy Escalade in driveway and a Black Chevy SUV ocated behind the Escalade. At 1345 hours, I Honda Civic in roadway and a Black Chevy in driveway. At 1558 hours, Ill.rved a Tan Honda Civic in observed a Tan SUV roadway, Black Chevy SUV in driveway, Black Caddy Escala e in driveway and a dark unknown model/make car parked in garage. On Saturday, 04/02/05, I continued surveillance at 358 El Brillo. At 0713 hours, I observed a Red Explorer bearing FL tag in roadway Red Explorer in roadway, Black Caddy Escalade in driveway and a and a Black Caddy Escalade in driveway. At 0814 hours, I observed a Tan Honda Civic X98APM. 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 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 air, teens to early 20's, thin and tall wearing a white tank top and short blue jean shorts, exited the vehicle d to the rear of the house. I also observed a Red Explorer in roadway, Tan Honda Civic in roadway and a Black Caddy Escalade in driveway. At 1310 hours, I EFTA00232109 Date: 7/25/06 Time: 8:47:53 Incident Report PALM BEACH POLICE DEPARTMENT Page: 69 Program: CMS301L Case No • 1-05-000368 (Continued) observed a Red Explorer W/F driver leavin the 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 surveillance at 358 El Brillo. At 0719 hours I observed a Tan Honda Civic in roadway and a Black Caddy Escalade. At 0934 hours, I observe a Tan Honda Civic in roadway and a Black Caddy Escalade in driveway. At 1057 hours I observed only the Tan Honda Civic X98APM. On Tuesday, 04/05/05, I continued su ' e at 358 El Brillo. At 1052 hours, I observed a Red E lorer in roadway, a Green Explorer bearing FL tag in roa wa a Grey Altima bearing FL tag in roadway, White Ford Truck in roadway, Black Mercedes in driveway being washed by a B Man an unknown dark car parked in the garage. At 1059 hours a Blue Chevy Suburban drove to the house of 358 El Brillo and parked in the driveway. At 1119 hours, I observed the White Fort Truck H58LRA 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: BATES, MICHAEL J. 1/03/06 Entered By.: ALTOMARO, NICKIE 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 Black Chevrolet Suburban, unknown tag, a Black Mercedes S600 FL tag U90BQL parked in the east dril. ..rai • n next 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 Suburban and Black Mercedes along with a Silver Hyundai Accent FL to all parked in the east driveway and a Red Ford Explorer FL tag 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 EFTA00232110 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 Suburban 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 IIIIII parked in the street in front of the residence. At 1805 hours the Escalade and Civic were in the same position and the Black Mercedes FL tag sas 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, ed a Black Mercedes, 4-door parked in the east driveway FL tag At 2300 hours, 2350 hours and 0045 hours, the Black Mercedes only vehicle observed. ******************* ***** ****NARRATIVE # 33 ************************** NA Reported By: RECAREY, JOSEPH 1/05/06 Entered By.: ALTOMARO, NICKIE A. 1/05/06 I made contact with Mr. father of who was told that I wishe 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 that she was hired to model lingerie at a Palm Beach mansion. Mr. stated he knew nothing else about what she did when she went to "work." Mr. advised he would cooperate with the investigation and make his aug ter available for interviews. I asked if she was available for an interview, stated she was not at home at the moment. I informed him I wou ma e 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 Telecommunications 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 Officei- ha 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. EFTA00232111 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 New 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 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. 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 st • er Epstein's direction, he delivered a dozen roses to 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 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 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 EFTA00232112 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 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 **************************** N A R R A T I V E # 34 * ***** ******************** NA Reported By: RECAREY, JOSEPH 1/09/06 Entered By.: ALTOMARO, NICKIE 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 to deliver a biicket of-Ttses to-EleThlig Sck451 after l (IIIII high school drama erformance. Also in that same note was irection . to rent a car for ( and direction to extend the rental contract. I returne to the Palm Beach Police Station and placed the folder into evidence. I received a fax from Verizon from the subpoena request sent on EFTA00232113 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Incident Report 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. The (Continued) phone number is is a in West ular On January 9, 2006, Det. Caristo and I traveled to Palm Beach Gardens in an attempt to locate been previously seen on the property and identified t. Florida Drivers License and Florida license Plate. A was left for her to return my call. We then traveled Youth Foundation and located speak with us and in a private room wit in the sc oo taped statement. in who had roug her business card to the Simon agreed to provided us a During the statement, advised that when she was fifteen or sixteen years ofae sewas taken to Jeffrey Epstein's house by her associate, stated this occurred late May 2004 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. He introduced himself and brought them into the kitchen so that the chef could prepare somethin for them to eat. After having a meal, and Epstein brought upstairs to a master bedroom which ..•large bathroom. She o served a large style shower, sauna and there was a large massage bed also in the bathroom. Epstein entered a i Rl ihey room within the bathroom and came out wearing onl a towel. said they would provide a massage on his feet. asked are doing this. told her this was part o t e routine and told her to rub his le s an calves. Epstein had told to get comfortable. continued rubbing Epstein's ca ves and feet. At Epstein's direction, then left the room leaving there by herself. Epstein to to get comfortable. removed her blouse and pants and staye in her panties. stated she was not wearing a bra. She believed she was wearing t ong panties. Epstein turned over onto his back and began touching her. Epstein touched her breasts and began touching her in her vagina area. Epstein instructed her to rub his chest and rub his nipples. stated the touching consisted over the panties on the first time; e stroked her vagina but stayed on top of the panties. During the first massage, she stated Epstein was stroking her and began masturbating himself at the earne_time. He put his hands under the towel and appeared as to masturbate himself however she never saw his penis. She continued rubbing his chest 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 tell an one what happened at the house or bad things could happen. stated she went to Epstein's house three EFTA00232114 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 74 Time: 8:47:53 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. could not remember 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 each time she returned to the house, Epstein would do the same thing. stated it was a routine with Epstein. She would rub his feet and calves. He would then turn over and begin to touch her on her vagina area. The only difference was that it was done without panties. Epstein's fingers would stroke her vagina area 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 contacted again. She began to purposely miss the calls when either or Epstein would call her. She once brought a friend, " un own last name to work for Epstein. She was paid $200.00 for bringing stated she no longer retuned to work for Epstein. She also stated that she wanted to notify the police of what happened at the house. stated she was scared of what could have happened to her or er amily if she notified authorities. On January 10, 2006, I received the results from the silhooena from BellSouth Telecommunications foriiiiirone number 561-M -M The number is assigned to Mr. .= s father in Palm Beach Gardens. I also received the results from Western Union which confirmed the money order sent to from Jeffrey Epstein in New York City. The "wire" was sent y Jeffrey Epstein of 457 Madison Ave in New York City on December 23, 2004 at 12:05 pm. The amount of $222.00 was charged to Epstein's credit card so that could receive $200.00 in Royal Palm Beach. The twenty-two dol ars was for processing and local fees to send the money via Western Union. A copy of the check presented to was also attached to the receipt of the wire. This confirme w at advised she received as a Christmas bonus from Epstein. Investigation continues. **************************** NARRATIVE # 35 ************************** NA Reported By: RECAREY, JOSEPH 1/10/06 Entered By.: ALTOMARO, NICKIE A. 1/10/06 I received and reviewed the Cingular Wireless results from the subpoena requests for subscriber information for telephone numbers and . The first number, , is assigned to Janusz Banasiak in care of Jeffrey Epstein of 457 Madison Ave in New York City. Banasiak is the current houseman/house mans er for 358 El Brillo Way in Palm Beach Fl 33480. The second number, , is assigned to of EFTA00232115 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 75 Time: 8:47:53 Incident Report Program: CMS301L Case No 1-05-000368 (Continued) 1685 61st Drive in West Palm Beach. Research conducted on revealed she is a licensed Massage therapist with a Florida conditional/active license number . had been previously arrested for battery / unwanted touching and.", Requests for copies of the reports involving the arrests were requested from the Palm Beach County Sheriff's Office. The last number is assigned to Rofrano of AlA in Palm Beach Gardens. Research on Mr. Rofrano, revea e t a he is a Florida Chiropractic Physician. Vehicles that were previously documented on the property while surveillance was being conducted were researched. I determined a tan Chevrolet Camaro, bearing Florida license IIIVIIII was seen on the property in which a young white female was seen entering the Epstein property. Research was conducted which revealed that the vehicle is registered to of Lake Worth. Mr. has two daughters, and is currently residing in Connecticut an is rest ing with her father in Lake Worth. Research on revealed she was recently involved in a traffic stop in La e Clar e Shores in , 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. ****************************NARRATIVE # 36 ************************** NA Reported By: RECAREY, JOSEPH 1/23/06 Entered By.: ALTOMARO, NICKIE A. 1/23/06 On January_i_ in Palm Beach Gardens. was i entifie as a 19 2006, Det. Caristo and I met with at llense massage therapist who had previous ybeen seen on Epstein's i l property when physical surveillance was done. was told of the on going investigation and I felt she may have in ormation pertaining to the case. During a sworn taped statement, 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 some irls to work at the house to answer phones and run errands. accepted the job and be an working at Epstein's house on El Bri o n Palm Beach. Mil stated it was a part time job during the time she went to Palm Beac Atlantic College. She continued going to Epstein's house and would be notified when Epstein would travel to Palm Be advised she would be notified by Maxwell, Epstein or , is when he would travel to Palm Beach. stated she began providing massages to Epstein before she became a massage ntin iving massages not onl to Epstein but to and , his assistant. was asked about ng t e massages. state as she was twenty stated she met EFTA00232116 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 art of this investigation, I needed to ask certain questions. stated that there were times that Epstein would ask her to perform during the massage. He would instruct her to rub his nipples as he masturbated himself. stated she felt "grossed" about the behavior but as she was gets ng paid, she just continued. also advised she would on occasion perform the massages naked. Epstein would on occasion, utilize the vibrator/massager on her vagina area when she performed the massages. explained that Epstein never exposed himself to her as he mainta ned himself covered under the towel he would be wearing. When Epstein would masturbate he would be covered. I asked if ever received any gifts, or any gratuities from Epstein. advised aside from being paid well, she advised Epstein too care of her tuition from Palm Beach Atlantic College. She received 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 iiiiiii which was also previously seen on the property when there was physical surveillance being done at the property. The vehicle is registered to of Lake Worth, Florida. Researchin Mr. and the ve icle revealed that his daughter, had een driving the vehicle and was cited for unlaw u speed in Lake Clark Shores. The vehicle is a tan, Chevrolet Camaro, 2-door. I researched date of birth, Ilillilill, resides at in Lake Worth. has a space page called In her web page, shows various photos of p otograp e• at a •each. 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 images workin at his office were seen. Additional footage of and was seen. There was other footage seen. i e y f the females is unknown at this time, until such time as I meet with dertain females to show the video footage to confirm if in fact, it is them on the video. At this time it appears his des in t e eveniilliurs. Due to poor lighting, a direct that and are seen sitting with Epstein beside confirmation cannot be made at this time. Inv. Continues. EFTA00232117 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 77 Program: CMS301L Case No • 1-05-000368 **************************** N A R R A T I V E # 37 NA Reported By: RECAREY, JOSEPH Entered By.: ALTOMARO, NICKIE A. On January 25, 2006, Det Caristo and in Lake Worth and met with year, when she was seventeen ears through her former room mate Epstein at the time. when they modeled. explaine and advised her that s e was in Palm each and requested to see her. IIIII made arrangements to meet with her at Epstein's house. arrived and met Epstein and shopping. a v sed that and ' and went to the Pa m Beach Mall together and went she had received money from Epstein to go to the mall. They ilited Victoria's Secret and purchased undergarments from the store utilizing monies 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. (Continued) ************************** 1/30/06 1/30/06 I responded to stated est e, s e met Jeffrey Epstein was allegedly dating ad once cohabitated together called her on her telephone and stated explained how she and Epstein have been datin eacillier continued shopping and having a day together. and he as een paying all of her bills. claimed advised they met in New York and had been dating ever since. They later returned to Epstein's home and encountered Epstein. He had a brief conversation with about her modeling career. He knew of her modeling career from He requested to see her modeling portfolio and explaine at he could help her with modeling jobs. had her book with her to show and showed the book to stein. He commented negatively about er photographs and portfolio. felt uncomfortable with the comments made as she had been wor ing with other professional modeling companies who had offered her work from her photographs. stein requested to see what was purchased at the mall. took out the undergarments which were purchased. She immediate y showed stein different siiiiiurchased. Epstein then requested to view what purchased. was reluctant to show the outfit however since it was Epstein's money that purchased the item she pulled it out of the bag. Epstein asked her to try it on. looked at who told her "yeah, try it on." Feeling compelle to try the undergarment 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 went back into the other room and chaliiillack into her clothes. returned into the room and told she would be going home. scheduled another day for to return for massages with her. stated within that same week, she returned to meet with and have a massage. had told her that she would be unable. iiiiiwith her as she wou be going on a bike ride with Epstein. explained she could stay at the house and take advantage of the massage. EFTA00232118 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 78 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) stated she met with an unknown massage therapist and had the table already set up in a guest room. removed her clothing, leaving her anties on, and wrapped herself with a towel for the massage. remembered that the door to the guest room was closed but not loc e . As the therapist was working her back, 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 chiropractic session. Epstein told turn over onto her back. eventually turned over exposing her breasts to Epstein as e applied pressure on her shoulder and her waist. stated Epstein "popped" her back. removed her self from the to le, got dressed and left the house. further stated had attempted to call her on several occasions to invite her back to Epstein's house to which replied "I'm busy." advised she has not had contact with either or Jeffrey Epstein. It should be noted that her mother, was present during the interview. The interview was concluded and we thanked them her for their time. ****************************NARRATIV8 # 38 ************************** NA Reported By: RECAREY, JOSEPH 1/31/06 Entered By.: ALTOMARO, NICKIE A. 1/31/06 On Januar 27 200 Imade telephone contact with , at . 'I'll' is a licensed massage therapist who had frequented the home of Jeffrey Epstein. Ms. has been unable to meet with me in Palm Beach County, and because she lives and works in Port St Lucie, 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 em lo ed by him for approximately three years. Epstein has paid to erform Swedish Massages (Deep Tissue) on him and other guests. explained that approximately three year ago she met Ghislaine Maxwell and Jeffrey Epstein through a mutual friend. Epstein and Maxwell were looking for a massage therapist. stated since that time, she is notified when Epstein is coming to Palm Beach. stated 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 occurred 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 stated she 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 see at 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. EFTA00232119 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 79 Incident Report Program: CMS301L Case No 1-05-000368 (Continued) stated she only provided massages for Epstein and his associates and nothing happened during those massages. stated as she does Swedish style massages, the patient is usuall'ille after the massages. I thanked her for her assistance and the interview was concluded at this time. I received a facsimile from T-Mobile Cellular service on telephone number , which is assigned to David Rodgers, pilot for Mr. Epstein, w o rest es in Lake Worth. Rod ers' 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. ****************************NARRATIVE # 39 ************************** NA Reported By: RECAREY, JOSEPH 2/14/06 Entered By.: ALTOMARO, NICKIE A. 2/16/06 On Friday, February 3, 2006, I had made arrangements to meet with at the Palm Beach Police Station. At approximately 1:00pm, and her friend, arrived at the police station. During an interview wit she stated she met Epstein when she turned eighteen years o and was brought to Epstein's house to provide a massa•e. She advised this occurred on May of 2005. She advised had informed her if she wanted to provide a massage for $200.00. a•reed 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 stated she would remove her clothing to provide the massage on Epstein. advised Epstein would pay her $300.00 to rub his back, legs an c est. During the massages, Epstein would masturbate himself as she rubbed his chest. I asked her if Epstein ever touched her breasts during the massages. replied. "Yes." I asked her if Epstein ever touched or massage er vagina. stated he had on several occasions. I asked her if he ever penetrated her with either his penis or any other objects. stated that during a massage he inserted his fingers in her va Ina as she massaged him. She stated this occurred one time only. stated the massage would be over when Epstein would climax onto a towel. I asked if she had an formal massage training to which she replied that she did not. was then asked if she ever brought anyone to the house to "wor stated she brought two people to the house. She advised she receive money-for-bringing people to the house to "work." stated she brought a girl named " her friend and lobby of the police station. I thanked was still waitin for orher time and her in t e cooperation and escorted her to the lobby. I asked Ms if I could speak with her about this investigation. I EFTA00232120 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 ertainiiilio the investigation. Ms identified herself as and resides in Wellington, Florida. She advised approximately a year aiiiihe was brought to Epstein's house to provide a massage for money. stated she needed to make money and felt it was a quick way to make some money. stated she was brought to the house by and was intro uced to Epstein and his assistant. She was broug t to is main bathroom and provided a massage. I asked her if she provided the massage naked. stated she did. She rubbed Epstein's legs, back and chest. I as a if Epstein touched her during the massage. She advised he did not, however he did masturbate himself as she rubbed his chest. Once he climaxed the massage was over. She was paid her money and left the Epsteinill!ouse. The interview was concluded and was escorted to area. advised it occurred one time and she never returned to the lobby. I located a telephone number for and attempted to contact her on several occasions. I ca ell...II-Ell 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 in Lake Worth. Rodgers was identified as Epstein s pi o . 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 there would be no way of knowing who the passengers were. I mentioned a recent flight to Ohio, where Rodgers flew to Ohio to pick up Rodgers stated he recalled flying on several occasions and did remember Rodgers stated once he is in the cockpit, he does not know who ”assengers are. When he prepares the passenger manifests he lists Epstein and his assistants he knows by name, and IIIIIIII. 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 us ness card for her to return my call. On February 14, 2006, at 12:06 pm, I received a call back from Ms. EFTA00232121 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 81 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) on my voice mail. Ms !III left her telephone number for a return call 561 -=I e heramessage to return call. Investigation Continues.. ****************************NARRATIVE # 40 ************************** NA Reported By: RECAREY, JOSEPH 2/21/06 Entered By.: ALTOMARO, NICKIE A. 2/22/06 On February 15, 2006, I made telephone contact with who provided directions to where I could locate her. Det Caristo and I responded re to III III IIIII III in Lake Park to meet with Upon my arrival, I met with in the parking of erectly be in MAACO Auto Painting. She was a vised I was there to speak with her about an 2222ing 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 eo le and therefore I should know what happened at Epstein's house. ended the conversation and walked back into her boyfrien s usiness, Automotive. Det Caristo and I left the area and returned to t e police station. Investigation continues. ***************** ***** ******NARRATIVE # 41 ************************** NA Reported By: RECAREY, JOSEPH 4/10/06 Entered By.: ALTOMARO, NICKIE A. 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 EFTA00232122 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 82 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) l located in Royal Palm Beach. I responded to in Royal . Beach. During the interview stated she knew I would be speaking with her. stated she was first introduced to Epstein when she turned eighteen years old. stated she was sure of her age as it was her senior year in High School. She advised she was brought there to ma e money an was told she would have to provide a massage to this Palm Beach guy. She remembered she met Epstein and his assistant in the kitchen area. She stated she was taken b one of her riends, She stated she went upstairs with while E stein got ready for the massage. He exited his bathroom na ed and turned around. Epstein asked her if being naked offended her. stated it made her uncomfortable. Epstein then put on a towel and lay on the table. stated she rubbed his back and feet. She stated she had no massage training or experience. stated during the massage, Epstein attempted to touch her buttocks. pulled away as he touched her buttocks. She told him again she was uncomfortable with him touching her. Epstein then cut the massage short and became upset with her. Epstein aid her $200.00 for the massage and told her to leave the house. never returned to the house. She did advise of one time she went with however she waited in the car for as she did not want to go into the house. At the conclusion 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 them in their private areas for monies. The interview was concluded as did not have any other information to provide. I then learned from the original victim, III 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 chasin" visitors who come to the house. Illi He provided a Florida License of . This vehicle is registered to Ivan Robles of West Palm Beach. o es 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. --******** ****** *******Tht***NA KK ATIVE # 42- * W**-****************** 4** NA Reported By: RECAREY, JOSEPH 4/14/06 Entered By.: ALTOMARO, NICKIE A. 4/18/06 The Grand Jury Subpoenas were personally served to the individuals they were issued to. On April 5, 2006, at approximately 7:30 p.m., I personally served the parents of who had informed me that the private investigators were still irotographing the family. On April EFTA00232123 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 residence 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 source that has maintained contact with Epstein. The source assured • she would receive monetary compensation for her assistance in not cooperating with law enforcement. II also stated she was told, "Those who help him will be compensated and those who hurt him will be dealt with." I told III that tampering with a witness/victim is an arrestable offense and very 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 Dawson and I traveled to Tallahassee, Florida and met with the victim, III identified W/F, as the personlilo approached her in Ro a Pa m Beach while s e was ome during Spring Break in March 2006. also stated she did not want to pursue the intimidation charges on II was 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 subpoena for the Grand Jury which was scheduled to commence April 18, Prior to our departure, the victim was given a copy of her 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 intefft—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, ASA Belohlavic stated that was the only offer made as to one victim, ASA Belohlavic cell phone rang and went to voice mail. She chilled her voice mail and played the message on speaker. The caller identified himself as EFTA00232124 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 would come from the Chief of Police. She explained to have Chief Reiter 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 messages and discovered a message from III 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, 2006, at approximately 4:30 pm, State Attorney Investigator Tim Valentine called to officially notify me of the cancellation of the Grand Jury. He requested I contact the victims that had been served to appear, to notify them of the cancellation. I advised Valentine 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. ****************************NARRATIVE # 43 ************************** NA Reported By: RECAREY, JOSEPH 5/04/06 Entered By.: ALTOMARO, NICKIE A. 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 with certain 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 count of Principal in the 1st degree Lewd and.Lascivioua 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 EFTA00232125 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. ****************************NARRATIVE # 44 ***** ********************* NA Reported By: RECAREY, JOSEPH 5/15/06 Entered By.: ALTOMARO, NICKIE A. 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 Eiiiiiir, white in color. The vehicle has a Florida registration of . Norr left Epstein's house and traveled north on County Road. Det Caristo and I conducted surveillance on Norr. Norr traveled to several construction sites and checked on certain jobs. Surveillance was discontinued on Norr and Det Caristo 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 e lained to her I had re ested arrest warrants for Jeffrey Epstein, and I asked that she either issue the warrants or direct ile, as so much time has elapsed since the original request to the Grand Jurys___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. **************************** NA NARRATIVE # 45 ************************** Reported By: RECAREY, JOSEPH 6/05/06 EFTA00232126 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 86 Time: 8:47:53 incident Report Program: CMS301L Case No • 1-05-000368 Entered By.: ALTOMARO, NICKIE A. (Continued) 6/06/06 On May 222_2006, I received several phone calls throughout the day from Mr. II who stated he had been followed aggressively by a private investigator. Mr. stated that as he drove to and from work and running errands throughout the county, the same vehicle was behind him runnim other vehicles off the road in an attempt not to lose sight of Mr. III 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 Belohlavek to inform her of the private investigators following Mr. G 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 Mrs. I who advised they were able to acquire the private investigators license plate information. The subject following them was again driving very aggressively and caused Mrs. to run off the road. Mrs. stated 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 discovery of the threat made against one of the victims in this case III i re ested subpoenas for all calls made to and received from during the month of March 2006 for her cell phone and ome phone. I had confirmed with Florida State University 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 7-Mar-06 11:16 AM 6 7-Mar-06 11:22 AM 887.2 7-Mar-06 11:37 AM 48 7-Mar-06 11:39 AM 28.2 7-Mar-06 12:02 PM 727.2 In/Out Outbound Inbound Inbound Outbound Inbound Inbound To/From The table reflects the date of the calls, time of day (EST), duration EFTA00232127 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 87 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) of call in seconds, inbound or outbound calls and calls made to or from phone. On March 7, 2006, at 11:03 am, made a call to the victim II which lasted 492 seconds (8 minutes an 2 seconds). The victim then returned the call at 11:16 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 intimidation. Immediately 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 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 A ril of 2006. I also noted that there was no further contact with or Jeffrey Epstein during the remainder of the month of March 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. ****************************NARRATIVE # 46 ************************** NA Reported By: RECAREY, JOSEPH 7/12/06 Entered By.: ALTOMARO, NICKIE 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 Mrs.. mother of the victim, III 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 * * * * * * * * * * * * * * * * * EFTA00232128 EFTA00232129 07/27/2006 THU 16:22 FAX 07/25/2006 15:44 5618354700 rain.; immining 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 yoar 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 796.07(1) on three or more occasions between August 01, 2004 arid 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 aft others. and against the peace and dignity of the State of Fbrtda. 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 State of Florida, prosecuting for the said - State EFTA00232130 07/27/2006 THU 18:23 FAX 07/26/2066 15:44 5510354700 PBPD 1MAINiNU • GRAND JURY FOREPERSON DATE Jeffrey E Epstein, Race: White, Sex: Male, DOB: Issue Warrant EFTA00232131 EFTA00232132 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 08-80804-Civ-MARRA/JOHNSON CASE NO.: JANE DOE, a/k/a JANE DOE #1, Plaintiff, vs. JEFFREY EPSTEIN and Defendants. :me°D4° July 18, 2008 STEVEN M. LARIM0111 CLERK U4. DIST. CT. 5. 0. Of FLA. • MIAMI NOTICE OF REMOVAL In accordance with 28 U.S.C. §§ 1441, 1446, and 1332(aX1), 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 Doe HI v. Epstein, Case No. 08 cv 80069 KAM (SD. Fla. filed Doe v. Epstein et at, Case No. 50 2008 CA 006596 XXXX MB (Ha. 15th Cir. Ct. filed Mar. 6, 2008). Lewis Teinn. 3059 Quo Avuin.San 345 Cattssa Gitovt, Fume. 33133 1 51310 EFTA00232133 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 #1 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 Fein N. 3059 GLOM AVINUI. %WTI 340. COCONVI halm 33133 2 of 316 EFTA00232134 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 #1 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 refilled 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. Comp). ¶ 4), would ostensibly prevent complete diversity? As discussed below, however, was named in the relied 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. 1 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: If, 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 arlion 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 LeysFtin 3G59Guw mum,. Sun 340.Oxotito Gran, hone 33M 3 sots EFTA00232135 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.i4 (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. 1 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 Temp 3059 GismAnonn, Wort 340,Cocordtt:GOOMFLOODA 33133 ♦x1311 EFTA00232136 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. v. 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 EFTA00232137 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-ICAM (S.D. Fla. filed Jan. 24, 2008) (Compl. ¶ 6). That allegation is now deleted and the Amended Complaint substitutes a generic prayer for relief.5 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. (Ant. 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] ... $15,000? (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 Lewis 3059 Gump Art Nut . Sum 341, Comm Giovt. NOM* 33133 Go1316 EFTA00232138 Case 9:08-cv-80804-KANI 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 "[w]hen [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 (11th 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 1.) 6 6 Jane Doe may, in fact, be a citizen of Georgia, not Florida, as she pled in her Amended ________compiaint.,Se.041184V--Y04-P-084-JuIr4,4008--(-reperting that "On his .vvy into cool t gut his state-court guilty plea on June 30], Epstein was served with a copy of a lawsuit by 1)oc, who has since moved to another state."); Jane Doe Depo. at 77, 112 (indicating that 7 Lewitt Teinn. 3059 Gun Mt PM, lulu 340, cmowr GROW. (IOWA 33133 Tog 314 EFTA00232139 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 8 of 100 (b) Defendant Jeffrey Epstein is a citizen of the U.S. Virgin Islands' (c) Defendant is a citizen of New York. (Am. Comp!. ¶ 5.) 3. Defendant 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. sister lives with her mother in Georgia); Affidavit of LaVogue at y 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. l 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."). DE 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 ¶¶ I, 2, 7 (filed "on behalf of S.D.G.," alleging that "The mother is Da[w]n Lavogue 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 11.5. District Court for the Southern District of Florida, Case No. 08-80069, which was filed without the consent of the mother"), In re v. Case No. 50 2008 DR 001141 (Palm Beach Co. Family Ct.) (1/31/08). 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 Calecto 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 Lewin Teinn. 3010 Maw Ainsen,Sunt 340,Oxormart Coca, Flamm 31113 811319 EFTA00232140 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. Compl. ¶¶ 20-23); Intentional Infliction of Emotional Distress (Am. Comp!. ¶¶ 23-28); and civil RICO (Am. Compl. ¶¶ 29-34). These allegations, however, do not support these claims, or any other theory of liability that would allow recovery against Cl 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., Piquet v. Amoco Prod. Co., 513 F. Supp. 938, 941 (M.D. La. 1.981) (explaining that courts developed the fraudulent-joinder doctrine to protect "the right [of removal] granted to 8 In Bonner v. City of Prichard. 661 F.2d 1206, 1207 (11th Cir. 1981) (en banc), the -----Laieventh-Cifeklit-Goen-of-Appeals-adepted-as-binding-preeedent-all dvcisiuns of tllc former Fifth Circuit rendered prior to October 1, 1981. 9 LeSyjsjFein n. 3059 Gwe Sun 340. [Menu, GOOrt.ItOitrni. 33133 101319 EFTA00232141 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 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 30S9Gtsuo MAIM, Sun, 340, Comm, Giovt,FlOadm 33133 le et 313 EFTA00232142 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. (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 Mat/WCS, 2005 WL 517847, at *1-2 (N.D. 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'! 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 Tein PI 1059 GOADAvow Sun r 340. COCON-7 04:74. hum.. 13133 1101311 EFTA00232143 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 Cray. Colt, 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 parties 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 "[Ole 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 "'Mlle 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 n 3059 MIAS° Amkut.$44ti 340. CoccoanGtovi,404443433133 12 dile EFTA00232144 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. ¶¶ 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 no possibility 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 (Ha. 5th DCA 1984) (citations omitted) (emphasis added).1° 10 This case is governed by the general rule. CI Churruca v. Miami Jai-Alai, Inc., 353 So. 2d 547, 550 (Fla. 1977) (noting that while there is "ordinarily ... no independent tort 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 _609,41-1-,-(Mass,1939-M-(emphaffis-added). Plainlyithis-ctbe involvcb die geucral 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 Lewis 30$9GweAvoug, Sun( 340.03conta Griot CiaiuoA 33133 11.1311 EFTA00232145 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 14 of 100 Here, Jane Doe cannot assert a cause of action for "violation of Chapter 800, Florida Statutes" (Am. Compl. ¶ 18) because there is no private right of action under that Chapter. See generally Am. Home Assurance Co. v. Plaza Materials Corp., 908 So. 2d 360, 374 (Fla. 2005) (observing that "not every statutory violation carries a civil remedy" (citing Villazon v. Prudential Health Care Plan, Inc. 843 So. 2d 842, 852 (Fla. 2003))). See also, e.g., Miami Herald Publ'g Co. v. Ferre, 636 F. Stipp. 970 (S.D. Fla. 1985) (King, C.J.) (holding that violation of Florida's criminal extortion statute does not give rise to a civil cause of action for damages); Mantooth v. Richards, 557 So. 2d 646, 646 (Ha. 4th DCA 1990) (per curiam) (affirming dismissal of plaintiffs claim for parental kidnapping where "the mentioned statutes concern only criminal violations and do not afford a civil remedy") (citation omitted) (emphasis added); Wright v. Yurko, 446 So. 2d 1162, 1 165 (Ha. 5th DCA 1984) (holding that "[a]n act which does not constitute a basis for a cause of action against one person cannot be made the basis for a civil action for conspiracy"). In this case, Jane Doe's claim under Count H (civil conspiracy) fails because it derives exclusively from Count I (violation of Chapter 800, Florida Statutes). Cf grant of summary judgment against claim for independent conspiracy, noting that "lwihen the concerted acts of the defendants do not create a greater harm than if the acts v‘ ere committed by one person alone. then there can be no recovery"). 14 Lewis "rein it 3059 GuNoAvmvt,Suirt 340.,Cccaivr Grow. FLORIDA 33133 14 of 31$ EFTA00232146 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 15 01 100 Buchanan v. Miami Herald Publg Co., 230 So. 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 1, 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 plaintiff cannot prevail against nondiverse 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 plaintiff's purported IIED claim fails as a matter of law. 15 I e.s r8 Tein ri. 3059 Gum/A.44K Sum 340.CocordurGtovtitomm 13133 IS al 314 EFTA00232147 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 crime "to practice massage" without a license. § 480.047, Fla. 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 ( I I th 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 v. 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 Lets Tein n. 3059 Goma Aviout. Soot 340, Craw' Gion, Co w13133 II of ills EFTA00232148 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, (Fla. 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 "Injo court will lend its aid to a [plaintiff] who founds [a) cause of action upon an immoral or an illegal act'") (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. CI Feld & Sons, Inc. v. Pechner, Dorfman, Wolfe, 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 LevSTsin n 3059 Gime Mom, Sun HO, Cocann Coon, ftwoo. 33133 IT of 310 EFTA00232149 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 (Cr 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 plaintiffs LIED claim fails as a matter of law. To state a cause of action for LIED, 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 TIED claim flows from Epstein's alleged conduct, not the joint conduct of and Doe in planning the massage. 18 Lewis 'rein a 3059 Gine° Avinia, Sint 340, (=Mr Glen, 1IOMM 33133 11 o1318 EFTA00232150 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. ¶ 31.) According to the Amended Complaint, the defendants participated in a criminal enterprise . . . or conspir[acy]" (Am. Compl. ¶ 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 Lewis yein n. 3059 GKAPC Anhui, yull I 340, CocoNuT Gw/vt.FtWODA 33133 1901116 EFTA00232151 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 20 of 100 Comp!. ¶ 32). The alleged "pattern of criminal activity" comprises violations of Chapter 796, Florida Statutes—the chapter that proscribes various crimes of prostitution:3 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. 1 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 Balas 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(2Xf), 796.07(2Xh), 796.045, and 796.04, Fla. Stat. (Am. Comp!. ¶ 31.) 20 Lewis 'rein it 1059 G Pao A‘INW, Sun13n0,CucnwrGAM, itIMOA 33133 30 at Mil EFTA00232152 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. 111 9, 11, 12, 32), those activities are not alleged in any way to have impacted Jane Doe. Cf., e.g., Palmas YBambu, S.A. v. F..I. Dupont De Nemours & Co., Inc., 881 So. 2d 565, 570 (Fla. 3d DCA 2004) (holding that "'indirect injuries, that is injuries sustained not as a direct result of predicate acts . . wit! not allow recovery under Florida RICO."' (quoting O'Malley v. St. Univ., Inc., 599 So. 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 LeAxika !!!!!! 1059G...two Avom.Sum 140,Cof own Gnow,hotsm 33131 21 of 311 EFTA00232153 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(a)(1). 22 L.evyjp: in rs. 3029 Goma Avow.. Soot 340, (Mow, Wore, Rosa 33133 22 of 316 EFTA00232154 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: GUY A. LEWIS Fla. Bar No. MICHAEL R. TEIN Fla. Bar No. ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach. Florida 33401 Tel. Fax. By: Jack A. Goldbet.• Fla. Bar No Attorneys for Defendant Jeffrey Epstein 23 Leayip ysiri 3039 Gw.o Avow', Sum 340. Cocosul Geod. FICIOSOA 33133 23 o1316 EFTA00232155 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 24 of 100 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. re: Michael R. Tein 24 Lewis rein.. 3059GuaoAvinue, 5u0e 340,Coccom GAOVI.FLORW 33113 x40311 EFTA00232156 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 Plaintiffiane 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. III Counsel for Defendant Bruce E. P . Bruce E. , 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 Lewis Fein ,. )059 Gana An Nut. SuOT 340, CoOmul fitOvt. ?Iota 13)33 2$ of 3t1 EFTA00232157 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 26 of 100 EXHIBIT A 2001316 EFTA00232158 r Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 27 of 100 nsor & Associates Rcpniap slid Tummy:in% Inc. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 2006 CF09454AXX STATE OF FLORIDA, 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 copy Notary Public, State of Florida Consor & ASsociates Reporting and Transcription Phone - Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 atom EFTA00232159 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 28 of 100 nsor & Associates Repanitv and Transcripline. lnc 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 5 561.355.7100 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 :8 19 20 21 22 23 24 25 Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 280 3% EFTA00232160 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 29 of 100 sor & Associates Rep/irons and Traucripuna, 1 2 3 INDEX WITNESS: Page 3 PAGE: DIRECT EXAMINATION 4 4 BY MR. TEIN: 5 6 7 NOEXHIBITS MARKED - 23 24 25 Page - CERTIFIED QUESTIONS Line 53 22 55 1 59 2 111 14 112 2 Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 EFTA00232161 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 30 of 100 nsor & Associates Ropm.ans and iraftscdpro. 1.714 16 7 18 O. Thank you. 19 May I call you 4111W 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 O. If you at any time don't understand one of Page 4 1 Deposition taken before Judith F. Consor, 2 Court Reporter and Notary Public in and for the State of 3 Flsrida 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 O. Good afternoon. Please tell me your full 13 naue. 14 A. 15 0. And can you please spell it. A. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 30 of 3l EFTA00232162 Case 9:08-cv-80804-KAM ent 1 EnteredonFLSDDocket07/21/2008 Page 31 of 100 nsor & Associates Ruportias and Tractscriptice. lac 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 0. So 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. a my uncle. 23 24 25 Q. A. Q. Anyone else living there? No. The contempt motion that your mother filed Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 I 31 4:4316 EFTA00232163 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 32 of 100 nsor & Associates Rep/min; and Transcription. 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 A. Yes, sir. 11 Q. Okay. Didn't your firefighter boyfriend 12 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 6 to live in? 17 A. No, sir. 18 Q. 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 24 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 el 316 EFTA00232164 Case 9:08-cv-80804-KAM ent 1 EnteredonFLSODocket07/21/2008 Page 33 of 100 nsor & Associates tiertaniqf and transcriptim Inc 1 2 3 Q. Q. Where is that? A. Palm Beach Lakes. Have you spent the night over there? Page 7 4 A. No, sir. 5 Q. Do you know the address there? 6 A. I do not. 7 Q. Isn't your sister planning on living 8 with you and at 9 A. No. 10 Q. llIR 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 13.1316 EFTA00232165 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 34 of 100 nsor & Associates aornrtiap and Tratsctipoto. lac. Page 8 1 MR. LEOPOLD: Let me just object. 2 let me instruct you. Anything that 3 you have learned through conversations between you 4 and me are protected. So 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. IIIII1 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 of Mt EFTA00232166 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 35 of 100 sor & Associates Homing sold Tramscripam, Inc. 1 2 3 4 that. Page 9 MR. LEOPOLD: Lewis, we're not going to do MR. TEIN: My name is not Lewis. 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 you 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 19 BY MR. TEIN: 20 Q. You have no idea that Mr. Leopold filed a 21 fifty million-dollar lawsuit on your behalf against THE WITNESS: No. 22 Jeffrey Epstein? 23 24 MR. LEOPOLD: Same objection. 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 35013t6 EFTA00232167 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. So 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 EFTA00232168 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 37 of 100 nsor & Associates Re porung and Transciip<m). lnc 1 2 3 4 5 6 7 B 10 11 12 13 14 15 16 17 18 19 20 21 22 Page 11 objections. Check your rules. MR. LEOPOLD: Excuse me. For the record, Counsel asked me a question. I'll state the answer on the record. He asked me the question am I going to be answering that way throughout the deposition. So long as there's improper foundation and predicate asked by the attorney, I will protect my client and I make the record where appropriate. If counsel wishes to ask an appropriate worded question with the proper foundation and predicate, I will certainly allow the client to answer the question. MR. GOLDBERGER: Why don't you just state attorney/client privilege and just be done with it? MR. LEOPOLD: I want the record to be clear. MR. TEIN: You want to waste time is what you want to do. You were supposed to be here this morning and you totally broke the deal, the agreement that 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 37 of 310 EFTA00232169 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 38 of 100 nsor & Associates Reporting end Transcription. lac. Page 12 1 clear where we stand thus far. 2 Is there a recording taken of this 3 deposition? 4 THE COURT REPORTER: Yes. 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 that, are you aware that a lawyer named Jeffrey 10 Herman filed a lawsuit on your behalf, yes or no? 11 MR. LEOPOLD: Objection. 12 Any conversations that you and I have had 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 MR. LEOPOLD: I'm assuming Counsel is not 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, Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 31 d711 EFTA00232170 Case 9:08-cv-80804-KAKI ent 1 Entered on FLSD Docket 07/21/2008 Page 39 of 100 nsor & Associates Reporting and Traescriptico, Inc. Page 13 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 4IIIIIIIIIias opposed to gm, 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 Q. Thank you. 22 In fact, you know that Mr. Herman held a 23 press conference after he filed the fifty-million-dollar 24 lawsuit on your behalf, don't you? 25 After it happened. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 39 of 3I6 EFTA00232171 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 EFTA00232172 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 41 of 100 nsor & Associates Re ponies arid Transentman, Inc I 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 2_4 25 Page 15 MR. LEOPOLD: We're going to leave or we're going to take a break, because his demeanor is not appropriate. There's no reason to have this kind of demeanor. If you want to have this kind of demeanor with me -- MR. TEIN: You are obstructing this deposition. MR. GOLDBERGER: Why don't you guys go outside and just talk about MR. LEOPOLD: She -- her job is very difficult and she's not going to be able to take us both talking at the same time. MR. GOLDBERGER: Off the record. MR. LEOPOLD: We're not going off the record, Jack. We're not, Jack. Her job is very difficult. I'm going td make the record. I don't think it is appropriate, especially in the small confines of this room, to be very aggressive with this young lady. MR. TEIN: That's not happening. Stop, stop actually -- MR. LEOPOLD: If you're going to interrupt me, we're going to cancel this deposition MR. TEIN: Stop misrepresenting. 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 311 EFTA00232173 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 42 of 100 nsor & Associates Roparziap and Transcription. lac. 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 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. TEIN: We're not taking a break unless the witness needs a break. You're obstructing this deposition, Ted. MR. LEOPOLD: Come on, NW 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 Wile EFTA00232174 Case 9 08-cv-80804-KAM nt 1 EnteredonFLSpDocket07121/2008 Page 43 of 100 nsor & Associates Ropartin mod TrassaIptIra, lac. 1 Page 17 You were supposed to be here at nine a.m.; 2 it's now after two. Take your break and come 3 back. 4 5 6 7 MR. LEOPOLD: Okay. If the demeanor keeps up, we will not be here beyond those five minutes. MR. TEIN: Take your break and come back. MR. LEOPOLD: Okay. So I suggest that you 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. you agree that giving testimony 20 today at your deposition is something very serious, don't MR. TEIN: I suggest that you take your 21 you? 22 A. Yes. 23 Q. 24 And you respect the court, don't you? A. Yes. 25 Q. Let me show you Exhibit 31-O01. Can you Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 43,1311 EFTA00232175 Case 9:08-cv-80804-KAM nt 1 E terwdonFLSIDDlocket07/21/2008 Page 44 of 100 sor pi Associates Repartinp ad 1 rancti pucm, 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...1O1 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 Q. 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 Q. 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 44 of 314 EFTA00232176 Case 9:08-cv-80804-KAM D Q. ent 1 Entered on FLSD Docket 07/21/2006 Page 45 of 100 nsor & Associates Reporting ad Trossainakia. 1 2 yours on MySpace? 3 A. Sure, yes. Page 19 Did you send that message to a friend of 4 Q. Were you referring to this deposition? 5 A. Yes. 6 Q. Do you find the term n-i-g-g-e-r offensive? 7 A. That's not anywhere in there. 8 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 O. What question were you asking, 18 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 tne ciosing? Int MR. LEOPOLD: She doesn't ask questions. 24 A. Niggaa. 25 Q. Don't you find that term offensive? 4 a Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 4001314 EFTA00232177 Case 9:08-cv-80804-KAM nt 1 Entered on FLSD Docket 07/21/2008 Page 46 of 100 sor & Associates Reporting and Transcript.= In Page 20 1 A. No. 2 MR. LEOPOLD: Can you spell it for the 3 record, please. 4 THE WITNESS: N-i-g-g -- 5 MR. TEIN: No, no, no. You are not going 6 to be asking questions. 7 MR. LEOPOLD: I'm not asking questions. 8 I'm asking for the record the word to be spelled, 9 because we don't have a video here today. 10 MR. TEIN: These exhibits are part of the 11 record. You -- 12 MR. LEOPOLD: Well, it's not marked as an 13 exhibit. 14 MR. TEIN: Stop interrupting me, 15 Mr. Leopold. I have marked and identified as an 16 exhibit and you will get it. 17 MR. LEOPOLD: There has been no 18 identification of this document in the record. 19 MR. TEIN: Mr. Leopold, stop interrupting 20 this deposition. 21 MR. LEOPOLD: What is the exhibit number 22 marked for identification? 23 MR. TEIN: 31-001. 24 MR. LEOPOLD: Do we have copies? Is it on 25 the record anywhere? Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 MI et Ste EFTA00232178 Case 9:08-cv-80804-KAM entl EnteredonFLSpDocket07/21/2008 Page 47 of 100 nsor & Associates Reporting nil TenseOption. Inc 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 21 1 BY MR. TEIN: 2 Q. Let me ask you, did you in fact 3 write your friend this message about this deposition? 4 A. Yes. 5 Q. So you wrote your friend that this 6 deposition is stupid court s-h-i-t, correct? 7 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. Q. And you think this deposition is bull s-h-i-t, don't you? A. No. Q. You wrote that to your friend, didn't you? MR. LEOPOLD: Objection. Asked and answered. BY MR. TEIN: MR. TEIN: That's not an objection. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 470316 EFTA00232179 Case 9:08-cv-80804-KAM nt 1 Entered on FLSD Docket 07/21/2008 Page48of100 nsor & Associates Roponins and Trascripnna, Inc. Page 22 Q. You wrote that to your friend, didn't you? 2 MR. LEOPOLD: Objection. Asked and 3 answered, for the fourth time. 4 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. MR. TEIN: Then terminate the deposition if 9 you think it's been asked and answered. 10 MR. 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 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 MR. LEOPOLD: I won't do that. 23 MR. TEIN: Of course; because you want to 24 obstruct. 25 MR. LEOPOLD: All right. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 4804311 EFTA00232180 Case 9:08-cv-80804-KAM t 1 Entered on FLSD Docket 07/21/2008 Page 49 of 100 sor & Associates Reporting end Tr.uiscrtrion, loc. 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 8 answered. 9 THE WITNESS: No, I did not. 10 BY MR. TEIN: 11 Q. You didn't write this exhibit? 12 A. I wrote that, but I didn't write what you 13 said. 14 Q. You wrote in this exhibit, "I got some 15 stupid court s-h-i-t on the 20th. Bull s-h-i-t." Didn't 16 you write that? 17 A. Yes. 18 Q. Referring to this deposition, didn't you? 19 A. Referring to the court. I was• later 20 informed that it was a deposition. 21 Q. I'm going to ask you some questions now 22 about what happened when you went to Jeff Epstein's house — 2S-- three-Yearragerr— Gkeig 24 A. Uh -huh. 25 Q. When the police interviewed you one month Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 40 03111 EFTA00232181 Case 9:08-cv-80804-KAM * D u ent 1 Entered on FLSD Docket 07/21/2008 Page 50 of 100 16 17 18 19 ! 20 21 22 23 sor &Associates Reanntap and Transcription,Inc 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. Q. Were you totally shocked by what happened when you got to Epstein's house? A. Yes. O. You didn't expect it at all, did you? A. No. Q. You had absolutely no idea why your friend as taking you to Epstein's house, right? 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 510 31$ EFTA00232182 Case 9:08-cv-80804-KAM Anent1 Entered on FLSD Docket 07/21/2008 Page 51 of 100 sor & Associates Reporting and intim/1pda% loc. . Page 25 1 2 3 never said anything to you on the telephone about sexual 4 activity with Epstein, did she? 5 A. No. A. Yes. 0. 6 Q. 7 Before you got to Epstein's house And before you got to Epstein's house never 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 IIIIIII? 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 4. 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 110714 EFTA00232183 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 52 of 100 nsor & Associates Rennnens and Tin/airman, lac. Page 26 1 Q. 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. 6 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 Q. 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 32 W3141 EFTA00232184 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 53 of 100 nsor & Associates ReportenE mend Tranutirion. Inc 1 2 Page 27 MR. LEOPOLD: If you do it one more time, we're leaving. 3 BY MR. TEIN: 4 0. 5 6 7 8 9 10 11 12 S MR. LEOPOLD: I'm going to make the record. You cannot interrupt me when I'm making the record. Out of professional conduct, you cannot do that. I'm entitled to make the record. I made an objection, asked and answered. Your demeanor is inappropriate. You're willing and you are able and you're responsible to ask a question in a 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 of 315 EFTA00232185 Case 9:08-cv-80804-KAM q pent 1 EnteredonFLSDDocket07/2112008 Page 54 of 100 nsor & Associates Roparanp aac Transcrtrim, lne 1 Page 28 MR. TEIN: Stop misrepresenting the record 2 and calm down. I'm going to ask my question. 3 Stop it. 4 BY MR. TEIN: 5 Q• MR. LEOPOLD: I think the record is very 7 clear. 8 MR. GOLDBERGER: Let me just clarify 9 something. When you object to the form of a 10 question, you're not instructing the witness not 11 to answer the question, are you? 12 MR. LEOPOLD: No. And I'm not making that 13 objection; only on attorney/client privilege. 14 MR. TEIN: Will you stop speaking now so I 15 can ask my question? Are you done? 16 Okay. I'm going to ask my question. 17 18 19 20 21 22 23 24 25 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 S4 of 3101 EFTA00232186 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 55 of 100 nsor & Associates Reporting ad Trans< nfrtion. 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 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. 21 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. LEOPOLD: So long as you act MR. VEIN: Suit yourself. 23 THE WITNESS: I'm sure. 24 BY YR. TEIN: 25 0. Let me ask you a few questions about your Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 55 of SIO EFTA00232187 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 56 of 100 nsor & Associates Roponini ranscrip:u co. 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 Seat Sit EFTA00232188 Case 9:08-cv-80804-KAM p ent1 Entered on FLSD Docket 07/21/2008 Page 57 of 100 nsor & Associates Reporting sod Tratteriptra, 1 2 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 A. No. Page 31 Q. All right. Let me ask you two final areas 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 Q. MN 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. 3 O. 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 sr a SUP EFTA00232189 Case 9:08-cv-80804-KAM merit 1 Entered on FLSD Docket 07/21/2008 Page 58 of 100 n5Or & Associates Reporting ad Traatiptien. lac. 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 Q. 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 0. So it was Illillwho told you to lie about 15 your age to Jeff Epstein? 16 A. Yes, sir. 17 Q. And IIII 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 51cAlIll EFTA00232190 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 59 of 100 nsor & Associates Reportinp /ad Tunic apron, lnc. Page 33 1 Q. When you first met Jeff he tried to find 2 out how old you were, right? 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 21 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 St of 316 EFTA00232191 Case 9:08-cv-80804-KAM 4# 0 ent 1 Entered on FLSD Docket 07/21/2008 Page 60 of 100 nsor & Associates Reparunp Dad Transcriputo. 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 GO a/ 31f EFTA00232192 Case 9:08-cv-80804-KAM ent 1 teradonFLSCOocket07/21/2008 Page 61 of 100 nsor Associates Roaming and Trassansuice, lac Page 35 2 3 4 memory that in fact you told Mr. Epstein's assistant, the 5 one who walked you upstairs, that you went to college and 6 you had just moved down here from Ohio? 7 A. I don't remember saying that, but if you -- Q. You can answer the question. A. Sure. Q. Is there anything that would refresh your B 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 Pagan 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 Pagan 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 A. I don't remember the words exa 24 do remember telling her I told him I was 18. 25 Q. And do you remember telling Detective Pagan Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 61 at 316 EFTA00232193 Case 9:08-cv-80804-KAM ent 1 EnteredonFLSODocket07121/2008 Page 62 of 100 nsor & Associates • Reporting end 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 lyLng? 4 A. No, I don't remember saying those words 5 exactly to her. I remember telling her that I told 6 Epstein I was 18. 7 O. Does it sound right to you that you told 8 Detective Pagan that you said your age really fast to 9 Epstein -- MS. BELOHLAVEK: Objection. Asked and 11 answered. 12 BY MR. TEIN: 13 Q. -- so he wouldn't think that you were 14 lying? 15 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've 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 x1616 EFTA00232194 Case 9:08-cv-80804-KAM Qagkynent 1 Entered on FLSD Docket 07/21/2008 Page 63 of 100 sor & Associates Repornic and lranacripuon. kit 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 Pagan 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 WJTNESS: 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 63 el 316 EFTA00232195 Case9:08-cv-80804-KAM D u ent 1 Entered on FLSD Docket 07/21/2008 Page 64 of 100 nsor & Associates itencatinA and Transcnrian, Inc 1 2 A. Q. Page 38 Yes. Was that the truth? 3 A. No. 4 Q. In fact, you went to , 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 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I don't remember having that conversation with her, so I wouldn't know if that's what I said. Q. That was a lie, though, wasn't it? MR. LEOPOLD: Objection to the form of the question, lack of foundation. You're making an assumption. She just answered you she can't tell you that. MR. TEIN: Speaking objection. And you well know that, Mr. Leopold. MR. LEOPOLD: She can't answer that question. The way you phrased that question, you're purposely making her not be honest in her testimony. She can't answer a question like that. She doesn't remember. So then you say, "So you were lying." That's improper and you know that. That's not a proper question. And any attorney Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 84 or 310 EFTA00232196 Case 9:08-cv-80804-KAM D c ment 1 Entered on FLSD Docket 07/21/2008 Page 65 of 100 sor & Associates Resin/is aid Transcription. 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. -- 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. = 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 650111I EFTA00232197 Case 9:08-cv-80804-KAM ent 1 EnteredonFLSDpocket07/21/2008 Page 66 of 100 nsor & Associates Ropanint and Tranwription, Inc. Page 40 1 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 O. What does that mean? 8 A. Whack, like whacking off? 9 Q. Your term, what does that mean? 10 A. Masturbating. 11 Q. Mr. Epstein never tried at any time to grab 12 you: hand, did he? 13 A. No. 14 O. 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. 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. predicate. Well, you told the police, "At no time did Ph. - Fax. 1655 Pa 'm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 611013111 EFTA00232198 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 67 of 100 nsor & Associates Reporting and Transcription. lac. Page 41 1 Q. You told the police twice when you spoke to 2 Pagan 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 A. Correct. 8 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 0131$ EFTA00232199 Case 9:08-cv-80804-KAM DQcient 1 Entered on FLSD Docket 07/21/2008 Page 68 of 100 nsor & Associates Reponins and TillISCripli OD, 10C. 3 2 3 4 Page 42 A. No. Q. No type of intercourse with Jeff, correct? A. Correct. Q. All right. Let's talk about what happened 5 after the massage was over. 6 A. Okay. 7 Q. 8 you wanted to bring your sister back so she could 9 make some money, correct? 10 A. Incorrect. 11 Q. Your sister is III right? 12 A. Correct. 13 Q. And you love very much, don't you? 14 A. Yes. 15 Q. 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 After the massage, you told Epstein that And when you left the house you were joking Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 18.31316 EFTA00232200 Case 9:08-cv-80804-KAM Doqument1 Entered on FLSD Docket 07/21/2008 Page 69 of 100 sor & Associates 1 2 3 4 5 6 7 8 9 Reporting and Transcription. 3nc Page 43 things, but it wasn't joking about it at all. Q. You joked about it, didn't you? A. No. Q. You said to 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 glip MR. LEOPOLD: Objection. Asked and answered. 10 THE WITNESS: No. 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 A. Incorrect. I didn't spend any of the 16 money. 17 Q. You went to Marshall's, didn't you? 18 A. I went along, yes, but I didn't -- 19 Q. You went shopping with them at Marshall's, 20 didn't you? 21 MR. LEOPOLD: Objection. 22 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 09 of 010 EFTA00232201 Case 9:08-cv-80804-KAM D ent 1 Entered on FLSD Docket 07/21/2008 Page 70 of 100 nsor & Associates RI:Tarano and Transc dance, 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. 23 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 Thrall@ EFTA00232202 Case 9:08-cv-80804-KAM ent 1 QlteredonFLSDpocket07/21/2008 Page 71 of 100 sor &Associates Roponisq mod Trassaiption. 1 2 3 Page 45 A. It was not this year, no. Q. Was it 2007? 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 ; 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 Q. Did they speak to your parents? 20 A. That's something you'd have to ask my 21 parents. 22 0. Do you know whether they spoke to'your 23 par ' 24 A. No, sir. 25 Q. You have no idea? Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 71 Nits EFTA00232203 Case 9:08-cv-80804-KAM Qg g lent 1 Entered on FLSD Docket 07/21/2008 Page 72 of 100 nsor & Associates Agnomen and Trmuctirtian, 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. B Q. How many women and how many men came to 9 your house? 10 A. I 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 1 Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 72 of 316 EFTA00232204 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 73 of 100 nsor & A5soclates Reporting and lrinscriptioa Inc 2 3 4 BY MR. TEIN: fashion, you may answer. THE WITNESS: Okay. I wouldn't know. Page 47 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 71 et 311 EFTA00232205 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 74 of 100 sor & Associates [tenoning and Inniscrivinn. Inc. Page 48 1 Florida Bar? 2 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 0. And who else was there? 20 A. My Aunt 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 ?act 316 EFTA00232206 Case 9:08-cv-80804-KAM CZo ent 1 Entered on FLSD Docket 07/21/2008 Page 75 of 100 sor & Associates Reporting one Thinscripann, Inc. Page 49 1 Mr. Herman in the presence of ailla 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: 19 Q. You discussed the lawsuit? 20 A. Yes. 21 Q. Did tell 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$ ei EFTA00232207 Case 9:08-cv-80804-KAM D ent 1 Entered on FLSD Docket 07/21/2008 Page 76 of 100 100nsor & Associates Rcporiinp aid Transcription, Jac. Page 50 1 Q. Why did the meeting take place at 2 amuse? 3 A. I spent the night that night at her house. 4 O. 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 O. 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 O. How about an agent named Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 7101311 EFTA00232208 Case 9:08-cv-80804-KAM Do 4 ent 1 Entered on FLSD Docket 07/21/2008 Page 77 of 100 nsor & Associates Repartmg and Transeriimian, lac. 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 ;9 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 310 EFTA00232209 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 78 of 100 sor & Associates Kopm10)24,411flmmtthmelm. Page 52 4 if your parents have ever received a victim notification 7 6 A. 5 letter, correct? Q. Have you given any evidence to prosecutors Correct. 1 igneui.vcd a victim notification letter, correct? 2 rect. 3 Q. And your testimony is that you don't know 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. Pagan. 23 Q. Did she keep it? 24 A. Ask her. 25 O. You gave it to her and then you didn't get meomponiesSeillYienalipinahmell, ta•ff Imre". nod wary 71.1314 Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 EFTA00232210 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 79 of 100 sor & Assoctates Ropanisig and Tnascriptimi, lac. • Page 53 it back at the end of the meeting? 9 A. No. They -- yeah. No. They have it. I'm 3 guessing. I don't have it. 4 Q. How much money are you hoping to get out of 5 Mr. Epstein? 6 MR. LEOPOLD: Objection to the form of the 7 question. Attorney/client privilege. 8 BY MR. TEIN: 9 Q. How much money are you hoping to get, you, 10 yourself, hoping to get out of Epstein? 11 MR. LEOPOLD: Same. Same objection, 12 attorney/client privilege. 13 Don't answer the question. 14 BY MR. TEIN: 15 Q. I'm not asking about what your lawyer told 16 you. 17 MR. LEOPOLD: I'm instructing her not to 18 answer the question, because any of those 19 conversations involve her counsel. 20 MR. TEIN: Certify that. 21 MR. LEOPOLD: Please. 22 CERTIFIED QUESTION 23 BY MR. TEIN: 24 Q. Now, you lied to get out of this 25 deposition, didn't you? 79W070 Ph. - Fax. . 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 EFTA00232211 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 80 of 100 sor & Associates Roporunc and Transcription. Inc Page 54 1 A. No, sir. 2 Q. 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 Object to the form of the question. Lack 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 50 of 314 Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 EFTA00232212 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 81 of 100 nsor & Associates Roportang and lralosospoco. Inc . Page 55 1 CERTIFIED QUESTION 2 BY MR. TEIN: 3 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 friendIIIIIIIIPto 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 It el 31$ EFTA00232213 Case 9:08-cv-80804-KAM D ent 1 Entered on FLED Docket 07/21/2008 Page 82 of 100 nsor & Associates Ropaning cad Tuascrquice,. Inc. Page 56 1 has been marked for identification yet. 2 BY MR. TEIN: 3 Q. -- 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 13 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. us t'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. 14IIIIILon the left and me on the right. 22 Q. right? 23 A. Yes. 24 Q. IOW your friend at the 25 Quarterdeck Tavern, right? Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 eta 316 EFTA00232214 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 83 of 100 nsor 81 Associates Reporting tad Transertptim, Inc. 1 A. Yes. 2 Page 57 Q. IIIIIIIIIryour friend, who you say the day 3 that the process servers went to serve you with a 4 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 10 11 12 13 14 15 16 17 18 19 BY MR. TEIN: 20 Q. You said that wasn't the first day you were 21 going to be -- you thought you were being served with a 22 subpoena, correct? subpoena for this deposition, just happened -- just by A. Yes. Q. Your testimony under oath is that's just a coincidence, right? 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. 4 COM 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 EFTA00232215 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 84 of 100 sor & Associates R planing and Transcription. lac. Page 58 1 looting for you, didn't you? 54 et 3i6 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 I 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. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 EFTA00232216 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 85 of 100 sor & Associates Repanimp, and Transaipdan. inc. 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 N.R. LEOPOLD: Absolutely. I wasn't going pasta Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 EFTA00232217 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 86 of 100 sor & Associates • Rept-inns end Tali< ti pncm, Inc Page 60 of 316 20 21 22 23 24 25 1 to interrupt you. 2 MR. GOLDBERGER: Just requires us to say we 3 like the answer to that question. And it's not 4 you and I or you and Mr. Tein who are testifying 5 here. It's the witness. 6 MR. LEOPOLD: Fine. But after the sixth 7 time of asking the same question and then coming 8 back and pointing a finger at her and saying, 9 "You're a liar" -- 10 MR. TEIN: That didn't happen. 11 MR. LEOPOLD: That's fine. But I'm not 12 going to allow her to answer that question, 13 because she's answered that same question and has 14 explained it. 15 Now Counsel might be sitting there rubbing 16 his head with a migraine. That's his problem. 17 But if he can't ask a question appropriately in a 18 professional manner, we will leave. I will not 19 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 EFTA00232218 Case 91)8<v-80804-KAM ment 1 EnteredonFLSDDocket07/21/2008 Page87of100 nsor & Associates Stspornig and Transcaptiem, loc.... $7 of 316 Page 61 1 2 3 your question and move on. But do it one time. 4 If you don't understand it, I'll let you follow MR. LEOPOLD: This is really big stuff that you're going through. But that's fine; just ask 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 of the courtroom. You should know who I am. 23 MR. LEOPOLD: Well, that's the impression 24 you must have made in the courtroom. 25 I will not be quiet. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 EFTA00232219 Case 9:08-cv-80804-KAM Domen t 1 Entered on FLSD Docket 07/21/2008 Page 88of 100 sor & Associates Redd inp and ItAtasctijI:lay Page 62 1 MR. TEIN: That's obnoxious. Stop being 2 obnoxious. It's stupid. Let's go ahead with the 1111e4311 23 24 25 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. grAff 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 you, 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. IIIIIIII, 22 Q. And what did do to lie for you? A. Said I wasn't there. Q. And who did he tell wasn't there? A. Ask him. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 EFTA00232220 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 89 of 100 Gtof MG nsor & Associates Reparnaa and ltaascrinnon. Inc 1 2 3 4 5 6 7 8 9 Page 63 Q. Where were you when IIIIII,told this soreone that you were not at the Quarterdeck Tavern? A. Eating nachos. Q. At the Quarterdeck Tavern? A. Yes. Q. What did you do so that would lie to the process servers for you? A. Nothing. 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 15 servers had to ask the police to get you out of the 16 restaurant so that they could serve you? 17 18 foundation, predicate. 19 BY MR. TEIN: 20 Q. You can answer the question. 21 Isn't it true that Mr. Epstein's process MR. LEOPOLD: Objection. Lack of MR. LEOPOLD: If you know. Don't guess. 22 THE WITNESS: No. Can you repeat the I 23 question? 24 MR. TEIN: Don't coach. 25 MR. LEOPOLD: Don't guess. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 EFTA00232221 Case 9:08-cv-80804-KAM Doc ment 1 Entered on FLSD Docket 07/21/2008 Page 90 of 100 sor & Associates ROpOrtillg mJ TOLIIIICripliall, 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. I 25 deleted it. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 66 of 316 EFTA00232222 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 EFTA00232223 92 o1916 Case 9:08-cv-80804-KAM uncument 1 Entered on FLSD Docket 07/21/2008 Page 92 of 100 sor & Associates Reporting-and Transcripnrm. Inc. 1 2 3 in a second. Page 66 A. Nothing. Q. Well, we're going to come back to MySpace 4 A. You do that. 5 Q. I'm going to ask you some questions 6 abort why you lie about your age so often, okay? 7 MR. LEOPOLD: Objection to the form. 6 Argumentative. 9 BY MR. TEIN: 10 Q. You lie about your age all the time, don't 11 you? 12 N.R. 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 EFTA00232224 Case 9:08-cv-80804-KAM Dgpyypent 1 Entered on FLSD Docket 07/21/2008 Page 93 of 100 sor & Associates Reporting and Tresscriptiecloc Page 67 . 1 Q. And where is the one body piercing? A. Belly. 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 Q. And you've lied about your age to buy beer, 21 correct? 22 A. Incorrect. 1 I 23 0. 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 Pa,m Beach Lakes Blvd., Suite 500 - West Palm Beach, FL. 33401 9304316 EFTA00232225 Case 9:08-cv-80804-KAM D ment 1 Entered on FLSD Docket 07/21/2008 Page94 01100 l i k41 sor & Associates Roraniap anti Transcriptive, Inc. 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 B!vd., Suite 500 - West Palm Beach, FL 33401 140311 EFTA00232226 Case 9:08-cv-80804-KAM D ument 1 Entered on FLSD Docket 07/21/2008 Page 95 of 100 sor & Associates Repnninp bat! Transcription, Mr 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. I 1 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. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 1601016 EFTA00232227 Case 9:08-cv-80804-KAM Docyrnent 1 Entered on FLSD Docket 07/21/2008 Page 96 of 100 nsor & Associates Roportinp and Trauctipoon, )nc. 2 3 4 post on MySpace, right? 5 A. Yes. Page 70 A. Correct. There was a rule many years ago that you had to be 18 to have a MySpace. Q. So you lied about your age so you could 6 7 33-01. 8 Q. Let's go back to the top one on this page, Are you testifying now under oath that this 9 'MySpace page where the headline says, 'Sills do have more 10 fun," and the location is given as Lox, abbreviation for 11 Loxahatchee, and the age is 19, and it saysjillill, 12 is 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., Sulte 500 - West Palm Beach, FL 33401 No/316 EFTA00232228 Case 9:08-cv-80804-KAM D ent 1 Entered on FLSD Docket 07/21/2008 Page 97 of 100 sor & Associates itoponios nil Transcription, Mc. Page 71 THE WITNESS: I don't know which MySpace 2 you're talking about. 3 BY MR. TEIN: 4 Q. The MySpace page that you're just pointing 5 to, where it says you were 18. 6 A. Yes. 7 Q. And you were lying about your age, right? 8 A. Qh-huh. 9 Q. Why did you finally post your true age on 10 your MySpace profile -- 11 A. Uh -- 12 Q. -- four days before you were scheduled to 13 testify before the Grand Jury? 14 A. I honestly don't know which MySpace, 15 because I've had like a bazillion MySpaces, and in that 16 year, I had two, that one and another one, and that one's 17 been deleted. So I don't know which one you're referring 18 to. 19 Q. You remember that you changed your age on 20 your MySpace page from 18 to your true age just four days 21 before you went and testified in the Grand Jury? 22 A. No. 23 Q. You don't remember that. 24 A. No. 25 0. Do you remember Detective Recarey? Did you Sale M.I .,.••• MOVE. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 NOM, EFTA00232229 Case 9:08-cv-80804-KAM Dgcujnent 1 Entered on FLSD Docket 07/21/2008 Page 98 of 100 sor & Associates • Reporting and Transcription. Inc Page 72 ever meet a Detective Recafey? 2 A. I don't know the names. 3 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 Recarey 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 rice; 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 Recarey did 23 not drive you, correct? 24 MR. LEOPOLD: Objection. /asked and 25 answered. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 III a100 EFTA00232230 Case 9:08-cv-80804-KAM Dq ent 1 Entered on FLSD Docket 07/21/2008 Page 99 of 100 sor & Associates Reponota and Transcription, Inc. Page 73 THE WITNESS: No. I'm pretty sure my dad 2 drove me, because he was there with me. 3 BY MR. TEIN: 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 Pagan 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 Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 19 64 314 EFTA00232231 Case 9:08-cv-80804-KAM D ent1 Entered on FLSD Docket 07/21/2008 Page 100 of 100 ionsor & Associates Ropartinp and "franscription, inc 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 O. 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: ll Q. 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. 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 et 316 EFTA00232232 EPSTUN es morN TO SEAL NoN -PROS *air EFTA00232233 JUN-26-2009 FRI 02:28 P11 FAX NO. 5618358691 P. 01 Date: 6/26/09 ATTERBURY, GOLDBERGER & WEISS, P.A. ATTORNEY. LAW SUITE 400 250 AUSTRALIAN AVENUE SOUTH WEST PALM BEACH FLO 01-5066 TELEPHONE FAX￾FAX COVER SHEET To: R. Alexander Acosta, Esq. USAO Barbara Burns, Esq. ASAO Bradley J. Edwards, Esq. 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 SSION, 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. EFTA00232234 JUN-26-2009 FRI 02:28 PM TELECOPIED THIS DATE The Honorable Jeffrey Colbath Palm Beach County Courthouse 205 N. Dixie Highway Room 11F West Palm Beach, FL 33401 FAX NO. 5618358691 June 26, 2009 Re; State of Florida v. Jeffrey Epstein Dear Judge Colbath: P. JOSEPH R.ATTERBURY ' JACK A.GOLDBERGER JASON! S. WEISS Ulan' CCrtalIWI CrintoorPOI tome., ! MendKr of Now Jersoy A hot Hors 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,E'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 Contre,Suito 1400 230 Australian Avenue South Wftsr NMI Reach. FL. 3340i www.agwpa.com EFTA00232235 P. 03 JUN-26-2009 FRI 02:28 PM The Honorable Jeffrey Colbath June 26, 2009 Page 2 FAX NO. 5618368691 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 Attorneys Office(via facsimile) Deanna K. Shullman, Esquire (via facsimile) Bradley J. Edwards, Esquire (via facsimile) Spencer t. Kuvin, Esquire (via facsimile) EFTA00232236 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. 502008CF009381A>O(MB 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 GTIKDAiti t5 DATED JUN 2 6 nog JEFFREY 3 Circuit Court Judge EFTA00232237 Page Two Case No. 502008CF009381A)0(MB/502006CF009454AXXMB Order Denying Motion to Stay Disclosure Agreement Copies furnished: R. Alexander Acosta, U.S. Attorney's Office - Southern District 500 South Australian Avenue, Suite 400 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, Suite 400 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 EFTA00232238 i Judge Jeffrey 3. Colbath 205 North Dixie Highway West_Palm Beach, FL 33401 WEST PALM BEACH. FLORIDA 33401 Albeit AcoSTAi CSC\ U.S. Attorney's O ice Southern District 500 S. Australian Avenue Suite 400 West Palm Beach, FL 33401 334Oi4S2SS I II II I III IlAlmdeltdinhMI.A.AW EFTA00232239 ft EFTA00232240 IN THE CIRCUIT COURT OF THE 1.11. tEENTH 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 '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." EFTA00232241 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 So. 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. 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 's Motion to Vacate Order Scaling Records and Unseal Records, grant Palm Beach Post's Motion to Intervene and Petition for Access and/or deny 2 EFTA00232242 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 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 '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 ot Service WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Hand Delivery to ESQ., United States Attorney's Office — Southern District, 500 S. Australian Avenue, Suite 400, 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, Wect Palm Beach, FL 33401, SPENCER T. KUVIN, ESQ., Leopold-Kuvin, P.A., 2925 PGA BIvd., Suite 200, Palm Beach Gardens, FL 33410, and DEANNA K. SHULLMAN, 3 EFTA00232243 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, Suite 400 latch, FL 401 By: Robert D. Cri o i Jr. Florida Bar Michael J. Pike Florida Bar 31 Counsel for Defendant Jeffrey Epstein) and Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 Wes FL 33401-5012 Fax: Counsel for Defendant Jeffrey Epstein 4 EFTA00232244 iris el" 1"N /14 BURMAN, CRITTON, LUTTIER & COLEMAN LLP L'A'W - Y•B•R•S 515 N. FLAOLER DRIVE / sun 400 WEST PALM BEACH. FLORIDA 33401 Gi $ 00.44° MAILED r PC1A /iP C.c;0F . Attorneysice Southern District 500 S. Australian Avenue Suite 400 West Palm Beach, FL 33401 334O1:S623S c023 hili.M.LHL.AAndWM.Lidkdk.Md EFTA00232245 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 EFTA00232246 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 -seal. Accordingly, petitioner requests that this Court grant this motion and allow 2 EFTA00232247 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 3oM..day of June, 2009, to: U.S. Attorney's Office-Southern District 500 South Australian Avenue, Suite 400 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 anlens, 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, LUTHER & COLEMAN 515 North Flagler Drive, Suite 400 West Palm Beach, FL 33401 and ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 and 3 EFTA00232248 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: . N-Qi--- NE USLER-WALSH orida Bar No.M 4 EFTA00232249 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 EFTA00232250 Federal Express this 3**4., day of June, 2009, to: JEFFREY H. SLOMAN U.S. Attorney's Office-Southern District 500 South Australian Avenue, Suite 400 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 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. CRITFON BURMAN, CRITTON, LUTHER & COLEMAN 515 North Flagler Drive, Suite 400 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 EFTA00232251 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: oU,t•- &'-.AZEe1=R-WALSH lorida Bar No. 3 EFTA00232252 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(f), 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 so 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. • Petittoner Jeffrey Epstein is referred to bLuo • name. Non-party interveners,..,. 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 EFTA00232253 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 EFTA00232254 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 EFTA00232255 opposed disclosure (A-2). On August 16, 2008, Judge Main 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 EFTA00232256 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). 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 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). 5 EFTA00232257 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 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 M'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. 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 EFTA00232258 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, so 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 So. 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 So. 2d 389, 391 n.4 (Fla. 3d DCA 1999); see also State ex rel. Price v. McCord, 380 So. 2d 1037, 1038 n.3 (Fla. 1980). The trial court agreed that Mr. Epstein had established irreparable harm (A-17:16), denied a 7 EFTA00232259 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 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 8 EFTA00232260 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 EFTA00232261 Confidential") do not apply 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 non-criminal cases confidential in accordance with subdivision (c)(9)."); see also In re Amendments to Fla. R. Jud. Admin. 2.420--Sealing of Court Records & Dockets, 954 So. 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 So. 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 court record requiring confidentiality_is_requested during a judicial proceeding. The local administrative rule the non-parties cite, 15th Judicial Circuit 10 EFTA00232262 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 ofjudicial administration provided that court records be confidential" if a court has determined that confidentiality is required. Fla. R. Jud. Admin. 2.420(c)(9). Rule 2.420(c)(9) provides: (c) Exemptions. The following records of the judicial branch 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 EFTA00232263 (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 EFTA00232264 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 EFTA00232265 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 3ccu. day of June, 2009, to: JEFFREY H. SLOMAN U.S. Attorney's Office-Southern District 500 South Australian Avenue, Suite 400 West Palm Beach, FL 33401 WILLIAILLBERGER 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 IT WAN. 400 North Drive, Suite 1100 P. O. Box 2602 (33601) Tampa, FL 33602 Counsel for The Palm Beach Post 14 EFTA00232266 SPENCER T. KUVIN LEOPOLD-KUVIN, P.A. 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, FL 33410 Counsel for M. HONORABLE JEFFREY COLBATH Palm Beach County Courthouse 205 North Dixie Highway Room 11F West Palm Beach, FL 33401 ROBERT D. CRITTON BURMAN, CRITTON, LUTTTER & COLEMAN 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401 and JACK A. GOLDBERGER ATTEFLBURY, 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 By: or Petitioner NEIGREUSLER-WALSH lorida Bar No. 15 EFTA00232267 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, and Palm Beach Newspapers d/b/a The Palm Beach Post ("the Post").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 want a sealed c"py of that filed in this care"—and 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. 1 EFTA00232268 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 So. 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-deco irreparab! „}-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 EFTA00232269 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)(1)(D) as an order entered after a {hiding 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—emeeuted—a—nen-preseetition—agreentent—(4-7-.38)---Tii .3 prosecution agreement contains an express confidentiality provision (A￾3 The non-prosecution agreement and addendum are separately filed with a motion to seal. 3 EFTA00232270 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￾prosecution-agreement-644:39-40)z￾Judge Pucillo then instructed Mr. Epstein's attorney that she wanted 4 EFTA00232271 "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 (42). 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 EFTA00232272 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 ., 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)... 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, 4 The order is mistakenly dated February 12, 2008 (A-6). 6 EFTA00232273 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 ordcrly administration—of • , },elling 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 EFTA00232274 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 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 M'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 permission to not comply with U.S. District Court Kenneth Marra's previous a d‘rs." (A-16.3). Subsulticnt to this oral ruling, M. 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 8 EFTA00232275 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, so 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 The—tTia 14.1111 tnVC C 14 rt.gtlarcn lento OI law granting the motions to unseal the confidential federal non-prosecution agreement and addendum between the United States Attorney's Office and EFTA00232276 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 net-diselese-a-matter-eeetwring-before the grand j y." As 4 cons aeuce of the confidentiality provisions of the non-prosecution agreement, information that disclosed the existence and the subject matter of a federal grand jury 10 EFTA00232277 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 a 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 a ). By its terms, however, the procedures for sealing in Rule 2.420(d) (titled, "Request to Make Circuit and Cormtrecturt-Records2m-Noneintinal-eases-C-orrfidentian-du nut apply 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 EFTA00232278 non-criminal cases confidential in accordance with subdivision (c)(9)."); see also In re Amendments to Fla. R. Jud. Admin. 2.420--Sealing of Court Records & Dockets, 954 So. 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(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 closure, see Miami Herald Publishing Co. v. Lewis, 426 So. 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 court record requiring confidentiality is requested during a judicial proceeding. The local administrative rule the non-parties cite, 15th Judicial Circuit 12 EFTA00232279 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. Ha. R. Jud. Admin. 2.420(c)(9). Rule 2.420(c)(9) provides: —0)-Exemptionsr-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 13 EFTA00232280 (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 EFTA00232281 sought to be closed." Fla. R. Jud. Admin. 2.420(cX9Xi), (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 fast 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, 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 e-be-elosecl-.—Diselosurrof-these-doeumentr ir not-generallrinherent----------- in a state court plea hearing and will violate Mr. Epstein's common law right to confidentiality. 15 EFTA00232282 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 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 EFTA00232283 I HEREBY CERTIFY that a copy of the foregoing has been sent by E-Mail and Federal Express this 30*-4.day of June, 2009, to: JEFFREY H. SLOMAN U.S. Attorney's Office-Southern District 500 South Australian Avenue, Suite 400 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, LUITIER & COLEMAN 515 N. Flagler Drive, Suite 400 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 EFTA00232284 Counsel for Petitioner JANE KREUSLER-WALSH and BARBARA J. COMPIANI of KREUSLER-WALSH, COMPIANI & VARGAS, P.A. 501 South Flagler Dive, Suite 503 est Palm ch, FL 33401-5913 18 EFTA00232285 06-26-'09 13:39 FROM & LOCICERO 8139843070 T-059 P001/005 F-889 THOMAS LOCICERO B RALOW 400 IM O verSukel100•Tmm a FL 33602 (Phone (Fax) TolFree: [._ facsimile transmittal To: Marilyn, Judicial Assistant to Judge FAX 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 C For review El Please see attached proposed Order. Please comment jJ I_ Please reply U Please recycle El CONFIDESITIALITYSTATISSABNT This electronic message transmission contains Information from the law finn of— LoCicero it Bralow PL and is confidendal or privileged. The information is intended to be for tic use of the individual or entity ove. If you ere not the intended recipient, be aware that any disclosure. copying. disnl • contents of this information is whined. If you have received this eicetronie transmission in error. please notify us by telephone immediately. Thank you for your cooperation IRS Circular 230 Disclosure. To the extent rhis conesponderct contains federal tax advice, such advice was na intended to be used, and cannot be used by any taxptyct, for the purpose of (i) :voiding penalties under the Internal Revenue Code or (I) promoting, marketing, or recommending to another party any transacdon or matter addressed herein. If you would like us to prepare written tax advice designed to provide penalty prolectin please contact us and we will be happy to discuss the muter with you bi more detail confidential EFTA00232286 06-26-'09 13:39 FROMM 8, LOCICERO 8139843070 T-059 P002/005 F-889 THOMAS June 26, 2009 I OCICERO BRALOW VIA FASCIMILE The Honorable Jeffrey Colbath Fifteenth Judicial Circuit-Palm Beach Palm Beach County Courthouse Main Judicial Complex 205 N. Dixie Highway, Room 1 IF West Palm Beach, FL 33401 Re: State of Florida v. Jeffrey Epstein Dear Judge Colbath: Tampa dC0 N p., Ste. 1100, Tamed, FL 33602 P. - 02 ph. fax tea am Ft. Lauderdale tOi N E. Third Ave std. 1500 FL oh AI 3 MEtoll free New York City 220 E 42nd St., 10th Elder N 17 ph fax￾ww•SlS2M Dea Reply To Tampa 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, LOCICERO & BRALOW PL &swat K 0441411Vra%. Deanna K. Shullman EFTA00232287 06-26-'09 13:40 FROMM & LOCICERO 8139843070 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) EFTA00232288 06-26-'09 13:41 FROM & LOCICEPO 8139843070 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; EFTA00232289 06-26-'09 13:42 FROMM 8. LOCICERO 8139843070 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 J. Edwards, Esq. Deanna K. Shullman, Esq. Spencer T. Kuvin, Esq. 2 EFTA00232290 KREUSLER-WALSH, COMPLUsa & VARGAS, P.A. SUITE 503, FLAGLER CENTER SOI SOUTH FLAGLER DRIVE WEST PALM BEACH, FLORIDA 33401-5913 JANE KREUSLER-WALSH TELEPHONI BARBARA J COMPIANI PAESIMILE REBECCA MERCIER VARGAS BOARD CERTIFIED APPELLATE LAWYERS June 30, 2009 By Hand Delivery Honorable Jeffrey Colbath Palm Beach County Courthouse Fifteenth Judicial Circuit 205 North Dixie Highway, Room 11F West Palm Beach, FL 33401 Re: Epstein v. State of Florida 15th Circuit Court Case No. 2008CF009381A Dear Judge Colbath: JKW/bl Enclosure ostenerRebert-DrEritton Jack A. Goldberger Jeffrey H. Sloman Judith Stevenson Arco William J. Berger Deanna K. Shullman Spencer T. Kuvin 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. Very truly yours, ;---ICREUSLER-WALSH EFTA00232291 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, Suite 400 West Palm Beach, FL 33401 and JACK A. GOLDBERGER ATTERBURY, GOLDBERGER & , P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 and JANE KREUSLER-WALSH and BARBARA J. COMPIANI of KRETTST.F.12-WAT COMPLANT & VARGAS, P.A. 501 South Flagler Drive, Suite 503 West Palm Beach, FL 33401-5913 Counsel for Petitioner EFTA00232292 9. RECYCLED PAPER TO REORDER CALL EFTA00232293 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-S Opposition to Victims' Motion to Unseal Non-Prosecution Agreement (10/16/08) Judge Marra's Order Denying Petitioners' (Doe #1 and Doe #2). A-6 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) A-7 Epstein's Plea (6/30/08) A-8 Agreed Order Sealing Document in Court File (7/2/08) A-9 NonParty M's Motion to Vacate Order Sealing Records A- 1 0 And Unseal Records (5/12/09) Palm Beach Post's Motion to Intervene and Petition for A- 1 1 Access (6/1/09) Applicant, M.'s Motion to Intervene and Supporting A- 1 2 Memorandum of Law (6/11/09) EFTA00232294 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 EFTA00232295 nbs LEGAL : RECYCLED PAPER TO REORDER CALL EFTA00232296 Case 9:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07107/2008 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 08-80736-Civ-MARRA/JOHNSON CASE NO.: IN RE: JANE DOE, Petitioner. Fle-WelltitY1 ail) D.C. ELECTRUNC JULY 7, 2008 STITCH M. LARIM0Nt CLOW O.S. 0151. 5.0. OF FLA. MIAMI amers ewe y VICTIM'S PETITION FOR ENFORCEMENT OF CRIME VICTIM'S RIGHTS ACT, 18 U.S.C. 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 ("CVRA"), and files this Petition for Enforcement in the above styled action as follows: 1. 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 state offenses including solicitation of minors for prostitution. 3. Upon information and belief. the Defendant is _engaged in plea negotiations-with the Office of the United States Attorney for the Southern District of Florida concerning federal 10110 EFTA00232297 Case 9:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 Page 2 of 10 %or 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 Gene EFTA00232298 Case 9:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07107/2008 Page 3 of 10 vet 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, I I8 Stat. 2251 (codified at I8 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 Cowl 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 Party 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. § 3771(aX8). 3 o/10 EFTA00232299 Case 9:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 Page 4 of 10 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 "Where are clearly rights under the CVRA that apply before any prosecution is underway." 13P Prods., 2008 WL 501321 at *11, 2008 U.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. & 3771O)(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. In 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 Vicnm AND WITNESS I Further supporting this requirement is another statute. 42 U.S.C. § I0607(cX3), 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 of 10 EFTA00232300 Case 9:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 Page 5 of 10 Ist 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). II. 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 v. 5 50110 EFTA00232301 Case 9:08-cv-60736-KAM Document 1 Entered on FLSD Docket 07/07/2008 Page 6 of 10 %so 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 fbnctioned 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 CD. Cal., 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 Lid. 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 "jt]his is an intentionally broad definition because all victims of crime deserve to have their rights protected ." I.50 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 Fid-at-1015-71 6 (discussing significance of CVRA sponsors., floor statements). 6 gel Ill EFTA00232302 Case 9:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 Page 7 of 10 v✓ %or 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 rights 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 were committed against several other young females. These victims, too, are in danger of losing their right to confer under the CVRA. 7 7 0110 EFTA00232303 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(b)(1). The CVRA also confers on crime victims the right to "assert the rights described in (the CVRA)." 18 U.S.C. § 377I(d)(1). 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 of July, 2008. Respectfully Submitted, THE LAW OFFICE OF BRAD EDWARDS & ASSOCIATES, LLC Brad Edwards, Esquire Attorney for Petitioner Florida Bar if 2028 Harrison Street Suite 202 Hollywood, Florida 33020 Telephone: Facsimile: 8 $0410 EFTA00232304 Case 9:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 Page 9 of 10 r► vs, 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: AUSA, United States Attorney's Office, 500 South Australian Avenue, Suite 400, West Palm Beach, Florida 33401, this lth day of July, 2008. Brad Edwards, Esquire Attorney for Petitioner Florida Bar Nc 9 ol10 EFTA00232305 011:VaiThfecbSIMA/MAPPN 1•/1 44 1107 3 00 ntered on FLSD Docket 07/07/2008 FfP5lleyl0all 0 D.C. ELECTKOINIC CIVIL COVER SHEET ' 11 ,44 do 1month/enmities Infortoollon swanned herein nother replaecnoe supplement the Ming ondsesoke of &wimps or othe papere by rules of coon. 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El OTSITYK Crime fribgedn; t,4* Ref uSC. 57 7) At ANON :r cave to 11 SSW "vial' vita; ee late Cfreeige LENGTH OF TRIAL via 1 days railinated (Ex both sides to try mare too 0 CHECK IF THIS LS A CIASS ACTION DEMANDS CHECK YES only if danowlest in oanolaim. UNDER F.R.C.P. 23 VIII. REQUESTED IN COM PLAINT: ABOVE INFORMATION IS TRUE & CORRECT TO NowayRJ ten or RECORD on re lilt BEST OF MY KNOWLEDGE FOR OITICE USE ONLY A006111350 a *ECM 0 7,21/O3111 1 110110 JURY DEMAND: O Yes 2 No EFTA00232306 RECYCLED PAPER TO REORDER CALL N,D EFTA00232307 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. 011-80736-CrV-MARRA/JOHNSON IN RE: JANE DOES 1 AND 2, Petitioners. 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. (c) 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 EFTA00232308 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, so 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 terms 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. KENNETH A. MARRA UNITED STATES DISTRICT JUDGE Copies furnished to: all counsel of record By signing below, 1 certify that I have reviewed and agree to be bound by the terms of this Order. Dated: Signed by. Printed Name: 2 EFTA00232309 RECYCLED PAPER 10 REORDER 95.4.%44.939), ) EFTA00232310 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-Sled pleadings, creating a false impression that the agreement protects the victims. Finally, the agreement should be unsealed 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 1 EFTA00232311 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 so. No good cause has yet been shown. Cf. United . States v. Ochoa-Vasque, 428 F.3d 1015 (11th 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 EFTA00232312 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 so 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 CrYIP, Section 2255; will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein had been tried 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 had 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 EFTA00232313 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 in 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 pleadings 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 victims, containing different language. 4 EFTA00232314 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 Regresentation of the Victims in this Action and Related Civil Actions. The scaling 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 1. 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 htto://www.ncvli,ortzThavra.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. Jefrey Epstein, United States District Court, Southern District of Florida, Case No.: 08-CIV- -_8089.3.MARRAJORNSON. To facilitate all-these dim cssions, the agreement 5 EFTA00232315 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-MARRAJOHNSON. 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 $entember 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 EFTA00232316 Case 9:08-cv-80736-KAM Document 28 Entered on FLSD Docket 09/25/2008 Page 7 of 8 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 I and Jane Doe 2 Case No.: 08-80736-CV-MARRA/JOHNSON United States District Court, Southern District of Florida sststant U.S. Attorney 99 N.E. 4th Street Miami, Florida 33132 Telephone: Facsimile: EFTA00232317 Case 9:08-cv-80736-KAM Document 28 Entered on FLSD Docket 09/25/2008 Page 8 of 8 AUSA United States Attorney's Office 500 South Australian Avenue Suite 400 West Palm Beach, Florida 33401 s/ Brad Edwards Brad Edwards, Esquire Attorney for Petitioner Florida Bar No. 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 Atterburty, Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 Milorida 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 Suite 400 West Palm Beac Florida 33401 s/ Brad Edwards Brad Edwards, Esquire Attorney for Petitioner Florida Bar No. 8 EFTA00232318 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-MARRA/JOHNSON 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 Jeffity 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 EFTA00232319 v I fal e c.., g la a 0 g o i- 'it' g td s ) EFTA00232320 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-Marra/Johnson 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: L 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 States, either wider seal or otherwise, On August 14, 2008, this Court ?mid 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, EFTA00232321 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 v. Ochoa￾Vasaue, 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 so, 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. Lit 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 EFTA00232322 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, so 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." (DE 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. ( DE 26 at 1-2, subpart (d).) All 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 EFTA00232323 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. H. THE GOVERNMENT ACCURATELY DESCRIBED THE PROVISIONS OF THE AGREEMENT, • 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 Epstein alai neys-overwhat constituted the Agreement. Government counsel advised that, in its opinion, the Agreement had three parts. The first part was 4 EFTA00232324 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 A. Villafaila, 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 meatless. (See. e.g., 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 EFTA00232325 Case 9:08-cv-80736-KAM Document 29 Entered on Fl.SD 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. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: s/ A A. Assistant U.S. Attorne Fla. Bar No 99 N.E. 4th Street Miami. Florida 33132 6 Fax: E-mail: j usdoj.gov Attorney for Respondent EFTA00232326 RECYCLED PAPER TO REORDER CALL 954-84-9399 EFTA00232327 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/JORNSON JANE DOE #1 AND JANE DOE #2, Petitioners, v. UNITED STATES OF AMERICA, Respondent. VICTIMS' REPLY TO RESPONDENT'S OPPOSITION TO VICTIMS' MOTION TO UNSEAL IWN-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 from 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 inacrurare represenrationv nhout the nature of the non-prosecution agreementirrits-notices to the victims and in its filing before the Court. To set the record straight, therefore, the victims EFTA00232328 Case 9:08-cv-80736-KAM Document 30 Entered on FLSD 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 Sestina the Aereemeet In their motion to unseal the agreement, the victims argued that there was no good reason for the protective order requiring them not to fluffier 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 so. 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 es 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. EFTA00232329 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 D. 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-Government's representation-to victims of a right 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 EFTA00232330 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 Unfairlv Burdens the Victims. In their motion, the victims also explained how the protective order burdened their efforts to confer with other victims' tights 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 ligi 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 2028 Harrison Street - Suite 202 Hollywood, Telephone: E-Mail: EFTA00232331 Case 9:08-cv-80736-KAM Document 30 Entered on FLED Docket 10/16/2008 Page 5 of 6 Paul G. Cassell Attorney for Petitioners Pro Hac Vice 332 S. 1400 E. Salt Lake City 4 Telephone: Facsimile: E-Mail: Jay C. Howell, Esquire Attorney for Petitioners Pro Hac Vice 644 Cesery Boulevard - Suite 250 Jacksonville, F Telephone: Facsimile: E-Mail: CERTIFICATE OF SERVICE I HEREBY CERTIFY that on October 16. 2008, I electronically filed the foregoing document with the Clerk of the Court using CMJECF. 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, Flori Telephone: Facsimile: AUSA United States Attorney's Office 500 South Australian Avenue Suite 400 West Palm Beach, Florida 33401 s/ Brad Edwards Brad Edwards, Esquire Attorney for Petitioner Florida Bar No. EFTA00232332 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 16. 2008, a true and correct copy of the above and foregoing document is being provided by United States mall to: Jack Alan Goldberger, Esquire Atterburty, Goldberger & Weiss, PA. 250 Australian Avenue South Suite 1400 h Florida 33401 Michael FL Tein, Esquire Lewis Tein, P.L. 3059 Grand Avenue Suite 340 nda 33133 Robert D. Critton, Jr., Esquire Michael J. Pike, Esquire Burman, Critton, Luttier & Coleman, LLP 515 North Flagler Drive Suite 400 West Pa m B a h Florida 33401 s/ Brad Edwards Brad Edwards, Esquire Attorney for Petitioner Florida Bar No. . • • ii EFTA00232333 LEGAL 2=.72."*""• ® RECYCLED PAPER i 0 REO111)1..14 ('9) 1 9g-R.16•93. EFTA00232334 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-CIV-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-cut -the Agrcc,4„gut Vectb -filed-in this case, under seal or otherwise. Petitioners also assert that the Agreement should be "unsealed" because the victims EFTA00232335 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 relovtuit 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 12* day of February, 2008. KENNETH A. MARRA UNITED STATES DISTRICT JUDGE Copies furnished to: all counsel of record 2 EFTA00232336 RECYCLED PAPER TO REORDER CALL II= EFTA00232337 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT r -I 2 IN AND FOR PALM BEACH COUNTY, FLORIDA CRIMINAL DIVISION 3 4 5 6• 7 8 9 STATE OF FLORIDA ) ) vs ) CASE NO. 06 CF9454AMB ) 08 9381CFAMB JEFFREY EPSTEIN . Defendant. ) ) ) ) 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 EFTA00232338 2 A BE IT REMEMBERED that the following -------- 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 EFTA00232339 3 1 affidavit in both cases, please? 2 MS. BELOHLAVEK: There are no PC 3 4 5 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 B then? 9 10 11. 12 I have one Indictment, one Information? MS. BELOHLAVEK: Correct. THE COURT: So one case is charged by 13 Indictment, one is charged by Information? 14 MS. BELOHLAVEK: Correct. 15 THE COURT: In case 2006036744 you 16 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 EFTA00232340 Y:k 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? MS. BELOHLAVEK: Correct. 6 THE COURT: The defendant has no 7 prior criminal record? 8 MS. BELOHLAVEK: Correct. 9 MR. GOLDBERGER: Yes, Your Honor. 10 THE COURT: You checked the NCIC as 11 well as State records? 12 MS. BELOHLAVEK: Yes. 13 THE COURT: And the guideline score 14 sheet I have before me shows 21.5 months in 15 the Department of Corrections as the lowest 16 permissible prison sentence in months. 17 Both sides'agree to the preparation of the 18 guideline score sheet? 19 MR. GOLDBERGER: We so agree, Your 20 Honor. 21 MS. BELOHLAVEK: Yes. 22 THE COURT: What is proposed -- it 4 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 EFTA00232341 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 EFTA00232342 6 1 MS. BELOHLAVEK: Correct.. 2 THE COURT: Following the six months 3 sentence, the defendant will be placed on 4 12-months of community control one. The 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 13. 12 supervising adult must be approved -- and I would say, pre-approved, approved ahead of time, not after the fact by the Department 13 of Corrections. And you would mean by that 14 his community control officer? 15 MS. BELOHLAVEK: Correct. 16 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 is 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 EFTA00232343 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 EFTA00232344 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, its 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 EFTA00232345 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 EFTA00232346 10 1 probation officer, specified by who? 2 FIRITSATTON-1:5FTICECS-pecifiCd—by you, 3 Your Honor. 4 THE COURT: I don't see that in the 5 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 EFTA00232347 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 EFTA00232348 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 EFTA00232349 13 1 (Brief recess.) MR. GOLDBERbER: 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 20 21 22 23 24 25 offender pursuant to Florida Statute 942.035. MS. BELOHLAVEK: Correct. But the sex offender probation, the statute is different and only applies to certain offenses and this one was not enumerated. THE COURT: Okay. I want to make PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00232350 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: So circled are PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00232351 15 1 conditions, A, you will remain confined to C..4 2 your residence exce t one half hour before 3 and after your approved employment, 4 5 6 7 community service work or any other activity approved by your probation officer. B, you will maintain an hourly 8 accounting of all your activities on a 9 10 11 daily log which you will submit to your supervising officer upon request. My understanding about the daily 12 log, maybe I'm just confused from other 13 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: So 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 writing 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 EFTA00232352 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. So that 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 EFTA00232353 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 EFTA00232354 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: So 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 EFTA00232355 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: So 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 EFTA00232356 20 1 regularly congregate? 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. So 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 EFTA00232357 21 1 2 3 4 6 7 8 9 10 11 12 messages through carrier pigeon, no messages through third—parties, no—hey would you tell so and so for me, no having a friend, acquaintance or stranger approach any of these victims with a message of any sort from you, is that clear? THE DEPENDANT: Yes, ma'am 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 So, 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. 1.8 19 20 THE COURT: If the victim was under the age of 18, which was the case, you shall not until you have successfully 21 attended and completed the sex offender 22 program. So, 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 EFTA00232358 22 1 THE COURT: You did. MR7—GOLDBERGERT--That s a mi-TCURV- 15h 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: So it is just your 23 judgement -- 24 MS. BELOHLAVEK: Correct. 25 THE COURT: -- that his treatment PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00232359 23 1 with some fancy private psychiatrist or 2- psychologist—in his—case—rs—ckey9 3 MS. BELOHLAVEK: That is correct. 4 THE COURT: So 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 EFTA00232360 24 • 1 THE DEFENDANT: Yes, ma'am. 2 MR. GOIMB1 (2ER. your Honor, I'm 3 sorry to interrupt, we do cover the 4 employment later in the agreement as to 6 7 8 9 10 11 12 what he is going to be doing during the one year that he is on community control. THE COURT: Okay. And let me -- condition G, which is circled, unless otherwise indicated in the treatment plan provided by sexual offender treatment program. 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 EFTA00232361 25 1 signed them thoroughly. 2 magra-utherwIlmr-mrmarerrff-rme---------- 3 treatment plan. I'm just going to strike 4 out, provided by the sexual offender 5 treatment program. Is that what you 6 7 8 9 10 11 12 13 14 15 16 intend, that his therapist can MS. BELOHLAVEK: No. THE COURT: No? MS. BELOHLAVEK: No. THE COURT: Unless otherwise indicated. MR. GOLDBERGER: The parties have agreed that during the period that he is -- cannot be -- THE COURT: Condition G Swill now 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 EFTA00232362 26 1 MS. BELOHLAVEK: They have the 2 onliWion and—rireluded in 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 13 14 15 16 17 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 specimens of blood to the Florida Department of Law Enforcement to be registered in the DNA data bank. J, you shall submit to a 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 EFTA00232363 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 EFTA00232364 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 EFTA00232365 • 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 EFTA00232366 30 1 THE COURT: Okay. 2 MS. BELOHLAVEK: TM-de are 3 duplicates, you will see those are the same 4 as the ones on the previous page, however, 5 it was reproduced. 6 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 EFTA00232367 31 1 be done within 48 hours? 2 You shall not obtain or use a post 3 office box without prior approval of the 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 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 a added to victim, and G, we struck out the otherwise indicated language. Otherwise, it is as you agreed. 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 EFTA00232368 32 1 you choose -- or defense and the State c- 2 together, wffy—tWW1ve monthW—in the Palm 3 Beach County jail followed by six months? 4 Why not just send him to DOC? S 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 posit-ions 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 requirement 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 EFTA00232369 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: So 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 EFTA00232370 34 1 he has to do is the official State of 2 Florida regis ZUN? 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. So 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 EFTA00232371 35 1 THE COURT: And if my experience the 2 '— lam -fo fer-drf any va ue, they are 3 very serious about enforcing this. They 4 will be tracking you for the rest of your 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 registering; they will find and you will be 10 locked up. 11 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 EFTA00232372 36 n 1 2 3 4 THE DEFENDANT: No, ma'am. THE COURT: NDTMAlly—CWRing any prescribed medication? THE DEFENDANT: Only for cholesterol. 5 THE COURT: Does that interfere with 6 your mental ability? 7 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 14 15 16 right to confront and cross examine, do you understand you have a right to call witnesses of your own and the court would 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 EFTA00232373 37 ( 1 could subject you to deportation pursuant ) 2 to tne laws and er gulations governing the 3 United States Immigration and 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 1.0 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 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 EFTA00232374 38 1 on that, Your Honor? 2 THE—COURT7--Tt is—Tui 12- tv 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 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, I 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 EFTA00232375 39 1 nonprosecution agreement -- rlfgralTrAVE/Crhey sperl—all that 3 out. 4 THE COURT: Mr. Epstein needs to come closer. 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. 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 EFTA00232376 40 1 agreement very carefully spelled out if Chere—vrase—hieaeh that—would—vivlaLe thib 3 agreement, so 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. LJ 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 EFTA00232377 41 1 2- 3 4 5 6 two years from now saying, oh no, no; they bea rtre- laradTharren'r anything else that is influencing you to make this decision, then I need to know about it. 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 EFTA00232378 42 1 County also. 2 THE—COURT: r—fino a sufficient 3 5 factual basis to support the pleas. Are all of the victims in both of 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 counsel, through counsel as to the other 10 victim, and I believe, yes. 11 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 EFTA00232379 43 1 information will not be related to the Mem:Lane-1We wirrlYeM7TFd exclusivfly for 3 purposes of verifying compliance with this 4 agreement? 5 MS. BELOHLAVEK: Yes. 6 THE COURT: Is there anything else 7 from anybody else before I accept this 8 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 EFTA00232380 44 1 pursuant to it. I will adjudicate you 2 guilty of—felony -WEOFrEataon of Th 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, I 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 EFTA00232381 45 1 felony? 2 ----MS. ffELUHLAVEK: Correct, the one 3 that designates him a sexual offender. 4 THE COURT: Okay. So 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 EFTA00232382 46 1 You will be residing at 358 El 2 B kta—Way7—Palm Beach, PI-arida-11480. 3 Should you desire to move or go to a 4 different location upon release from 5 custody, you will get preapproval of that 6 location from the Department of 7 Corrections. You will have to contact your 8 community control officer a minimum of once 9 a week, it can be more often at their 10 discretion and you are to work at the 11 Florida Science Foundation at 250 12 Australian Avenue in West Palm Beach, 13 Florida. You will submit to a mandatory 14 curfew of 10 p.m. to 6 a.m. 15 You shall not live within a 16 thousand feet of a school, day care center, 17 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 EFTA00232383 r, CJ 1 children may congregate. You shall not 2 3 4 5 6 9 vrew7"-awn—or—gas-seu—any—cbscene 47 pornographic or sexually stimulating or visual, auditory material including telephone, electronic media, computer programs, computer services that are relevant to deviant behavior. You shall submit two specimens of blood to Florida Department of Law 10 Enforcement to be registered with the DNA .11 data bank. You shall submit to a 12 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 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 EFTA00232384 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 EFTA00232385 49 5 1 paying it? 2 3 4 MR GOLD.BERGER• Katually_there is_a_ cash bond posted, court cost can be 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 EFTA00232386 1 CERTIFICATE .50 C 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 EFTA00232387 LEGAL RECYCLED PAPER TO RWRDER CALL CO EFTA00232388 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 I 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 forrhe Defendant Date of Plea Defendant EFTA00232389 • The Defendant is designated as a Sexual Offender pursuant to Florida Statute 943.0435 and must abide by ail the comsaponceng requirements of the statute, a copy of which S attached hereto and incorporatd herein. The Defendant must provide a DNA sample in court at the time of Itits pie DOM Sreg at Dana PLEA IN THE CIRCUIT COURT THE FOLLO1MNG IS TO REFLECT ALL TERMS OF THE NEGOTIATED SETTLEMENT Name: Jeffrey E. Epsteki Plea: Guilty Case No. ___Qtarge Count Leer Pears 06CF009454AMB Felony Solicitation of Prostftubon 1 No 3 FEL OSCFO09361AMB Procuring Person Under 18 for Prostitubon 1 No 2 FEL PSt: Waived/Not Required _X Required/Requested ADJUO4CATipli: Adjudicate fx SENTENCE: On O6CFO09454AM8, the Defendant is sentenced to 12 months in the Palm Beach County Detention Faciky, with credk for 1 (one) day time served. ty ,Ci-cd On 08CF009381AMB, the Defendant S sentenced to 6 months4 the Palen Beach County Detention Facikty, with credit for 1 (one) day lime served. This 6 month sentence Is to be served consecutive to the 12 month sentence in 06CF009454AMB. Foloiting this 6 month sentence, the Defendant wit be placed on 12 months Community Control 1 (one). The conditions of community control are attached hereto and incorporated herein. OTHER COMERTS OR CONTIMOtie: Asa special condition of his community control, the Defendant is to have no unsupervised contact: with minors, and the supervising aduk must be approved by the Department of Corrections. IA% • ee..:y • EFTA00232390 948.101 Terms and conditions of community control and criminal quarantine community control.-- CO 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 requirsintonshe supervision and surveillance for an offender paced into community control, which may include but Is not limited to: 1. Specified contact with the parole and probation officer. 2. Confinement to an agreeditpon residence during hours away from employment and public service activities. ' 3. Mandatory public service. 4. Supervision by the Department of Corrections by means of an electronic monitoring devico • • or system. 5. Tho standard conditions of probation sat forth ins. 948.03. (b) For an offender placed on aiming quarantine community control, the court shall require: 1. Ilibactronic monitoring 24 hours par day. 2. Confinement to a designatod residence during designated hours. (2) The enumeration of specific kinds of terms and conditions does not prevent the court from adding thereto any other farms or conditions that the court considers proper. Howover, the sentencing court may only impose a condition of supervision allowing an offender convicted of s. 719.011 s. 800.04, s. 827.571 or s. 847.0145 to reside in another state if the order stipulates that it Is contingent upon the approval of the receiving sate interstate compact authority. The court may rescind Of 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 center 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 is 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 (parenting cornmunitycontrot program emphasizing intensive supervision with 24-hour-per-day electronic monibeirig. Criminal • quarantine community control status must include surveillance and may inctudo other measures normally associated with caavnwdty control, except that specific conditions necessary to monitor this population may be ordered. 0. EFTA00232391 '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 onion who moats the criteria In sub-subparagraph a., sub• subparagraph b., sub-subparagraph c., or sub-subparagraph d., as follows: a. (I) Has been convicted of committing, or attempting, soliciting, or conspiring to commit, any of tho criminal offenses proscribed in the following statutes hi this state or similar offenses In another jurisdiction: s. 7874)1_, s. 787.02 or s. 787.025(2)(c), whom 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. 796.035.s. 800.04. 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 ono of those listed in this sub-sit-subparagraph; and (II) Has been released on or after October 1, 1997, from the sanction imposed for any conviction of an offense described in sub-sub-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 release, or incarceration in o state prison, federal prison, prints correctional fealty, or local detention facility; b. Establishes or maintains a residence in this state and who has not been designated as a sexual predator by a cart 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 jurisdiction and was, as a result of such designation, subjected to registration or cormnunity or w'r••• public notification, or both, or would be If the person wore a reskiont 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 under 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. 787.01, 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 gueldien; s. 794.011, excluding s. 794.011(10); s. 794.05; s. 796.03; s. 7%.035;s. IDS s, 825.1025;s. 827.071. s. 847.0133; s. 847.0135, excluding s. 847.0135(4);s. 847.01Th s. 847.0138. s. 847.O145- or s. 985.701(1); or any similar offense committed in this state which has been redesignated from a former statute number to one of those listed in this sub-subparagraph; or d. On or alter 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 stets or similar offenses in another jurisdiction when the juvenile was 14 years of an or older at the time of the offense: (I) Section 794.011 excluding s. 794.011(10); (II) Section 800.04(4)(b) whore the victim is under 12 years of age or where the court finds sealed, activity by the use of force or coercion; (III) Section 800..04(5)(c)1. where the court finds molestation involving unclothed genitals; or EFTA00232392 (IV) Section 803.04(5)(d) whore the court finds the use of force or coercion and unclothed genitals. 2. for all qualifying offenses listed in sub-subparagraph (1)(a)1.d., the cart shall make a written finding of the ago of the offender at the time of the offense. • For each Notation of a qualifying offense listed in this subsection, the nowt shall make a written finding of the ago of the victim at the time of the offense. For a violation of s. 800 040), the court shall additionally make a written finding indicating that the offense did or did hot involve 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. lb) "Convicted means that there has bean a determination of guilt as a recta of a trial or the entry of a plea of guilty or nolo contendere, regardless of whether adjudication is withheld, and includes an adjudication of delinquency of a juvenile as specified in this section. Corniction of a similar offense includes, but is not limited to, a conviction by a federal or military tribunal, including courts-martal conducted by the Armed Forces of the United States, and includes a conviction or entry of a plea of guilty or nolo contenders resulting in a sanction in any state of the United States or other jurisdiction. A sanction includes, but is not limited to, 4 fine, probation, community control, parote, conditional release, centre( release, or incarceration in a state prison, federal prison, private correctional facility, or local detention facility. (c) 'Permanent residence end *temporary residence law the same meaning ascribed in s. 775.21 (d) institution of higher education' means a career carter, community college, college, state university, or independent postsecondary institution. (0) 'Change in enrollment or employment state means the commencement or termination of errolLment or amployinns. a• a change in location of wrotlincrt or employment. (f) 'Electronic mail address has the same meaning as provided in s. 668.602. (g) `Instant message name moans an identifier that allows a person to communicate in real time with another person using the Internet. (2) A sexual offender shell: la) Report in person at the sheriffs office; In tine county in which the offender establishes or maintains: a permanent or temporary residence within 4a hours after: a. .Btabllshing permanent or temporary residence in this state; or b. Being released from the cestody, control, or supervision of the Department of Corrections or from the custody of a private correctional facility; or 2. In the county whore ho a she was convicted within 48 hours after being comdctod fora cualifying offense for registotion under this section if the offender is not in tho custody or EFTA00232393 control of, or undor the suporvislon of, tho Department of Corroctions, or is not fn tho custody of a private correctional fecility. My dunge fn the sexual offender's permanent or temporary residenta, name, arry electronic man address and any intant massage name roeuired to be provided pursuant to paratraph (4)(d), after the sexual offender roports In person at this sheriffs office, stall be acoomplishod in tho marmor provided in subsections (4), (7), and (8). (b4) Provide his or her name, data of birth, social sectrity flundror, rate, sex, haght, weight, hair and oyo tofor, tattoos or other identifying marks, occupation and place of omploymont, address of permanent or lagat residenta or odörens of any ctrrent temporary residenta, within the state and out of gata, includIng a rural route odörs and a post office box, any eloctronic mall address and any instart massage name requirod to be provided pursuant to paragraph (4)(4), dato and place of nach conviction, and a brief description of the trim* or almes committod by tie °frontier. A post office box skalt not bo providod in lira of a physital residential aktras. 1. tf the sexual offender's place of rea/donne h a motor +ischias, trallor, mobile homo, or menufacturod homo, as defined in chapter 320, tho sexual offondor stall allo provide to the departmont through the sheriffs office written notice of the ~hick idantification manbar; tho titorso tag number; the registration numbor; and a descriptlon, inciuding toror schema, of the motor whiclo, trailer, mobile homo, or manafectured home. tf the sexual offendees place of residence Is a vassa, the-aboard vana, or housaboat, as &tinad in chaptor 327, the sexual offerler skall allo provide to the department writton notico of the hull identification rumba; the inanufecturers seraf numbor; tho name of tho vassa, live-aboard vyssa, or houseboat; the registration munbor; and a description, includIng color schema?, of the mag, limeaboard anad, or houseboat 2. if the sexual offendar is aerobod, ornat:lyx!, or carrying ona vocatIon at an institution of hiber educabon in this state, the sexual offender stall allo provide to the department through tho sheriffs office the navne, addrea, and county of oach institution, infading Bach campus attenlod, and the start offondark enralmont or omploymont status. Esch charge in enrallment or omp/oyment status skall bo reported in person at the sheriffs office, within 48 boers efter any charge In getas. The sheriff stialf prompfly notify °och institution of the sexual ofrondees prosene and any change in tho sexual offender's enrollment or employment status. Whon a sonat offendor roports at the sheriffs office, the sheriff gall taka a photograph and a sot of fingerprints of the offonder and forward the photograpiz and fingerprints to the department, alung with the information provided by thai sexual offender. The sheriff stall Prompt& provide to the department the information recotved from tho sexual offender. (3) Within 48 tours ofta the roport roquirod under subsoction (2), a sexual offender stall report in person at a dritar's literko office of the Department of il(ghway Safety and Motor Vehicles, unloss a driver's licens* or iden tification card that compfies with the nequirements of s 322.141(3) was previously socured or tarantel under s. 944.607. At the drivr's titone office tho ramat offondor shagt; fe) If otherwiso qualifled, snare a Florida drivi's licens., renew a Florida drivars licens, or 'ro an identification card. The stal offender skall idantify himself or horsolf as a sexual who is roquired to comply with this ~don and skall provide varg Mat the sexual offender reported as requirod in subsection (2). The sexual offerflor slugt provide my of the information specifiod in subsoction (2), if roquestod. The sexual offender IMU stbmit to tho taklag of a photograph for une in hauing a drivors timme, renowed licens., or identification card, and for uso by the dopertmert in maintalning current ratords of matt offendors. EFTA00232394 (b) Pay the costs messed by the Department of Highway Safety and Meter Vehkles 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). (I) 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 change in the offender's name by rotten of marriage or other legal process, the offender shall report in person to a themes license office, and shall be subject to the requirements specified in subsection (3). Tho Departrnont of Highway Safety and Motor Vehicles shall forward to the department all photographs and information provided by sexual offenders. Notwithstanding the restrictions set forth in s. 322.142, the Department of Highway Safety and Motor Vehicles Is authorized to release a reproduction of a color•photograph or digital-image license te the Department of Law Enforcement for purposes of public notification of sexual offenders as provided in this suction and ss. 9-43.043 and 944.606. (b) A sexual offender who vacates a permanent residence and fails to establish or maintain another permanent or temporary residence shall, within 48 hears after vacating the permanent residence, report in person to the sheriffs office of the county In which he or she is located. The sexual offender shall specify the data upon which he or she intends to or did vacate such residence. The sexual offender must provide or update all of the registration information required under paragraph (2)(b). The sexual offender must provide an address for the residence or other location that he or she is or Wilt S occupying during the time in which he or she fails to establish or maintain a permanent ortemporary residence. (c) A sexual offender who corsairs at a permanent residence after reporting his or her intent to vacate such residence within ea hours after the date open which the offender Indicated he or she would or did vacate such residence, report in person to the agency to which ho or she reported pursuant to paragraph (b) for the purees* of reporting his or her address at such residence. When the sheriff receives the report, the sheriff shalt promptly coney 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. 775.052, s. 775.063, or s. 775.064. (d) A sexual 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, 2037. The department shall establish an online system thorough which sexual offenders may securely access and update all electronic mail addreie and instant message name information. (5) This section does not apply to a sexual. offender who is also a sexual predator, as defined in S. 775.21. A sexual predator must register as required under s. 775.21. (6) County and local law enforcement agencies, in conjunction with the department, shall verity the addresses of sexual offenders who are not under the care, custody, controt, or suearvigon 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 Omar* applicable to such verification 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 roquirenxints, cis EFTA00232395 (7) A sexual offender who intends to establish residence in another stale or jurisdiction other thari the State of Florida shall report in person 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. The notification must include the address, municipality, county, and state of intended residence. The sheriff shalt promptly provide to the department the Information received from the sexual offender. The department shalt notify the stabowide law enforcement agency, or a comparable agency, in the intended state or jurisdiction of residence of the sexual offender's intended residence. Tie failure of a sexual offender to provide his or her Intended place of residence is punishable as provided in subsection (9). (8) A sexual 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 48 hours after the date upon which the sexual offender indicated he or she would leave this state, report in person to the sheriff to which the sexual 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. 775142, s. 775.C83 or s. 775.084. )(a) A sexual 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. 775.083 or s. 775.084. (b) A Sexual offender who commits any act or omission in violation of this section may be prosecubad for the act or omission in the county in which the act or omission was committed, tbetectety of the last registored address of the sexual offender, or the county in which the •corteictIctioccurred for the offense or offenses that meet the criteria for designating -a person ae a:social offender. (c) An arrest on charges of failure to register when the offender has been provided and advised of his 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 subserµsent charge of failure to register. A sexual offender charged with the crime of failure to register who assorts, or intends to assert, a lack of notice of the duty to register as a deforms to a charge of failure to register shall 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 a lack of notice of the duty to register, (d) Registration following such arrest, seryke, or arraignment h 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 Meter Vehicles, the Department of Correction, the Department of Juvenile Justice, any law enforcement agency In this state, and the personnel of those departments; an elected or appointed official, public employee, or school administrator; or an employee, agency, or any individual 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 the requirements of His section or for the release of information under this section, and shall be presumed to haw 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 Vehkles, the Department of Corrections, the Department of Juvenile EFTA00232396 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 fs incomplete or incorrect because a sexual offender falls to report or falsely reports his or her current place of permanent or temporary residers. (II) Except as provided in s. 943.04354, asexual offender must maintain registration with the department for the duration of his or her life, 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 parson as a sexual offender for purposes of registration. However, a sexual offender: (a)1. Who has bean 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. 787.01or s. 787.02; b. Per 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 involved a victim under 12 years of ergo or sexual activity by the use of force or coercion; d. Fora violation of s. 600.04(5)(b); a. For a violation of s. 800.64(5)c.2. where the court finds the offense involved unclothed genitals or genital area; f. For any attempt or conspiracy to commit any such offense; or g. For a violation of similar law of another jurisdiction, et n r'• may petition the criminal division of the circuit court of the circuit in which the sexual • • . ' 0 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 fodernst Adam Walsh Child Protection and Safety Act of 2006 and any other federal stancierds applicable to 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 'mist 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 futu-e date at which the sexual offender may again petition the court for relief, subject to the standards for relief provided in this subsection. 3. The department :MU remove an offender from classification as a sexual offender for purposes'. of recitation if the offender provides to the department a certified copy of the coat's written findings or order that indicates that the offender is no longer required to comply with the requirements for r.nfiab etion as a sexual offender. EFTA00232397 (b) As defined in sub-subparagraph (1)(a)l.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 predator, as 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 demonstrates to the department that such designation, if not imposed by a court, has been removed by operation of law or court 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 interact. Sexual offenders have a reduced expectation of privacy because of the public's interest in public safety and In the effective operation of government. Releasing information =corning sexual offenders to taw enforcement agencies and to persons who request such information, and the release of such information to the public by a law enforcement agency or public agency, will 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 intent 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: fa) Withholds information from, or does not notify, the law enforcement agency about the sexual offender's noncompliance with the requirements of this section, and, if known, the whereabouts of the sexual offender; (b) harbors, or attempts to harbor, or assists another person in harboring or attempting to harbor, the sexual offender; or (c) Conceals or attempts to conceal, or insists another person In concealing or attempting to conceal, the sexual offender; or (d) Provides information to the law enforce,n.aut agency regarding the sexual offender that the person knows to be false information, commits a felony of the third degree, punishable as provided in s. 775.082, s. 775.063, or s. 775.084. (14)(a) A sexual offender must report in person each year during the month of the sexual offender's birthday and during the sixth month following the sexual offender's birth month to the sheriffs office fn the county in which he or sho resides or is otherwise located to reregister. (b) 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 and the offender is not the victim's parent or guardian; EFTA00232398 f 2. Section 79-4.011 excluding s. 794.011(10); 3. Section 800.04(4)(b) whs. the court finds the offense involved a victim under 12 years of ate or smell( activity by the use of force or coercion; 4. Section M:940)(bk S. Section 800.04(5)(c)1. where the court finds molestation involving unclothed genitals or genital area; 6. Sectiong00.04(5)c.2. where the court finds molestation involving unclothed genitals or genital area; 7. Section $00.04(5)(d) whore the court finds the use of force or coercion and unclothed genitals or genital area; a. Any attempt or conspiracy to commit such offense; or 9. A violation of a similar law of another jurisdiction, mat reregister each year daring the month of the sexual offender's birthday and every third month thereafter. (c) The sheriffs office may determine the appropriate times and days for reporting by the sexual offends, which shall be consistent with the reporting requirements of this subsection. Reregistration shall include any changes to the following information: 1. Name; social security number; age; race; sex; date of birth; height; weight; hair and eye 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 mall address and any instant message name required to be provided pursuant to eln12/710 (4)(d); date and pato of any employment; vehicle 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 errolled, 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 vehicle identification number; the kers* tag number; the registration nurnber; and a 4.111,4kst... description, Including color scheme, of the motor vehicle, trailer, mobile home, or 114 . • manufacuxod home. if the sexual offender's place of residence is a vessel, live-aboard versiet; or houseboat, as defined in chapter 327, the sexual offender shall also provide the hull identification number; the manufacturer's serial number; the name of the versa, live-aboard • • vessel, or houseboat; the registration number; and a description, including color scheme, of the vessel, live-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 EFTA00232399 1 • p ' instant message names, commits a felony of the third degree, punishable as provided in s. 775.082 s. 775.081 ors. 775.084. (d) The sheriffs office shall, within 2 working days, electronically submit and update all information provided by the sexual offender to tho department in a manner prescribed by the department. I 1 EFTA00232400 ,I1‘25/2008 15: 2B 3553626 GiNtalt I lauteimic. rmoc VA/00 14 1. STATE OF FLORIDA Plaintiff Ns￾IN THE FIFTEENTH JUDICIAL CIRCUIT COURT, IN AND pop, PALM BEACH COUNTY CABENUMBER 302083CFV2,9231AXXXINIE JEFFREY E. InT2in . DIVISION >WORLEY "w'' Defendant DC NUMBBR 2/254,. - - . ... CIRCUIT NUIvIEER1 If-A/JAM SPLIT ORDER OP COMMUNITY CONTROL I This cause coming before the,Court to be heard, and you, the defendant, Wag now relent before the court,' and you. having 2 catereds plea guilty to ❑ been found gutty byJury verdict cf ❑ entered a plot °ratio outer:dare to ❑ boon toad sultry by tho mum trying the mu without a Jug of. Count 1 PEDCURRPERSON UNDER AGE OF 18 FOR PROSTITUTION siccno 1: JVDGMZNT OF GUILT CE1 7ho court buohy adiudui you to be guilty of thaw offotte(e). Now, therakte, it Is ordered and adjudged that S hapotthion of sentence it hereby withhold and that you be placed on Probation! Poe a puled of uric the eupereleloo of the Department cecorrectiene, subject to Florida law. 3tCTION It ORDER WITHHOLDING ADJUDICATION Now, therefore, it is mimed and adjudged that the atipdtoetton of ruin is hereby withheld and that you be plated ou Ptobatlrm fora period of_ under the cmentleien of the Department of Comdata, subject to Florida low. SECTION 3: INCARCERATION DURING PORTION OF SUPERVISION SENTENCE It la hereby ordered Led adJudged that you be: 0 cox:flood to the Deparanaar of Collection: Ur ❑ conSned la the Canty fail fora term of with credit for jeul tin*. Abu yvu haw senree_ of the tuna, you that! be pladed on Probation fora peeled of node- the ropervistor: of the Department of Corrottioni, subject it Florida law. or ccaSned In the County Jail fora tern of 8tX/61 MO! COMMUNITY CONTRQL I CONSECUTIVE TO THE flEt MONTE SENTENCE rat, CASES 2008C10094SAAMB with credit torPTE OD WetJail time, as a special comelltion of tuperehlon. 11/041110 /11101113 -13 Wino tiTI3E114.74 Ionia 51308 /108e . SS II lid I Z 1Fir 8001 VE Page 1 oft Form blind 03.114 EFTA00232401 11/25/2088 15:28 355362o t.;11tU: t t.M.1141f1P1- rfwmc 04140 lfialtgY EPSTEN CASESI5020013CF035381A)CDNB ' • 17 18 FURTH.MI ORDERED that you abellOocepiy With the Mounts lieredard 000d' limy of eotervildnnas.pf004ty Spats... ' taw . • (I) Yoo will report to the probstioil oleo as deemed. Not liter lbw the filth deY of moil mooth, loam 0fited9desdkolleds . nava • mkt i fun aid truthfulreportJo Your Moir Os the fottif ptovichd for thr PuT179e- . . (2) Yon will lag the Site ofl7oilde iiiiitioneltf350,90,Por oddla ite *On 93 4% ehrtherte, toward the pod °frit ourabicelit : ' mordant* wdth a. 448.09, Kt, haten &nein exempted hi oar:chance wit Florida Statutes • . . (3) You Will remain Ina specified place. You will not change your residence; or employment or leave the county of your mildest without fret procuring theconsent of Axle officer. • • (4) You will cot ponesa, envy or moony fiztann or weapon, =len authorized by the 'mum (5) You will live without violatum the law. A conviction le e court of law shall not be necessary for toot a violation to constitute a violation of your probettiateommunity control. (6) You Will not en00/1te writ ny person engaged hi say criminal acclivity. (7) You will not nice irked:rote to- exesen or posseas any limp or narcotics clan prescribed by a phystolari. 14or will you visit, , plops where intoxicants, drop or other dangerous substances aro uniaveAdly told, diapenfed or used. • ' (8) You will work diligently at a lawfid oommnion, Idyllic your employer of your pa-bailor. stalls, and support any dependent' to the Bert of your ability, is dinetteby your officer. (9) You will promptly end tuthfulho rawer all lnqufrles directed to you by the Donn or the effioer, end allow your officer to visit in, your holt:Ally= employment site or elsewhere, and you will comply within hoructions your officer may lave you; (1 0) You will pay readmtlo0, mun eau, and'or fees in accordance with ;punt/ conditions impanel or ill aectudarco with the attached (11)You will submit to random testing es direoted by your officio' or the lorofeeetooll stiff of the reahlteha Goner whore he/she le nook/Sag reter,ent to detennOu tbe prose= of alcohol or illept.drup. You will be required to pay for the tests unless exempt by the court. (12)You will submit two bHogical specimens, as direged by your ofIlork, for DNA analysla as proscribed In at. 943,325 and 948.014. F.S. (13)You will report In prix. within 72 hours of you: rola.. from Monoenstlon In the probation office In raelardcu County, fetid*, unless otbatwio karoted by the newt or deportment lTba condition nigin only tree:clop 3 on *A previous page is checked) Otherwise, you must report icanediatoly to the probation office mead at *444 Sorrow JAKE WORTH. P1,23451, Page 2 of 8 Fonn Rewind 03-IR-D8 EFTA00232402 11/25/2808 15:28 3553625 UthLvlI LiCINIIII4L emu. ...14/1t CIO . , • . ,ISEPPII . Y SPSIPIN CA513#502008CF0093SIA3OO043 . . . SPECIAL cci.rugnorls . .. . • . .... . . .. 0 1, You must undergo a Aug and Alcohol evaluation and, iftreatMent is deemed zutaury, you melt sucoessfbily complete dm trsumett, and be msponilblo for the ;amour of any oats bond Voile moolving said evaluation ancitivatcatu. union -1v% waived by the comb - • . . • • Additional histroododoideterk • • - .: : I. ... • • p . . . . . .. • O 2. You with 0mke teititatori to the following ViCtilltb. fa "direiiid iii,the obit, toll the obliptibn SsPaid bi full: : - • - • • 0.- - • • - • NAME: • . . . . TOTAL AMOUNT; 6___. , • , . • Additional instradoes ordered, hiatudIng voila° monthly amount, begin date, due data, oejoIrst & Sant . • : . . ••• . NAME: TOTAL AMOUNT: $ Addidonal iimputtiom ordered, including verde monthlyernowit, begin date, due due, 'Dilator & severe:: SPECIAL CONDITIONS — CONTINUED C S. You will *rater the Departmord of Calraititollti Non•Socuro Aug Treatment Program or otter residential treatmeta progiva/Probation sad RestlIntlan Center tit a period of sucusful completion a approved by your offioa You are to remain until you worMaldly omegleto said boom and Abornire. You em to comply with all Rules and Regulations of du Program You dull be acting In the county Jail until placement in said prostate, and if you art confaud in the jolt, the Sheriff will transport you to said ingrain ❑ 4. You will await entirely from the use of alcohol andior flogs) drugs, and you will net osacciste with anyone wbo Is illegally wing drugs re consuming alcohol, ❑ 5. You vAtisubcolt to irinalysia mating a a imathl.y basis to determine the prase:Ice of alcohol or Illegal drupe. You will In required to pay ibt the lute tbdC43 ( Pr.. by S court 0 6. You will not vbitirry otzblisturient where the primary business is Ise sib ad &missals ofeloohollo beveragoa, O 1. You will oueopuMly oompke Pours of community service at a rota of at a work silo approved by your oft cer. Addnlono) larootiont. ordered: ❑ S. You will made at your maidens between 10 p.m. and 6 a.m. due to a uric* haPetrdtalsa otherwise directed by the coon ❑ 9. You will submit m electronic rtioniunitg, follow thc rules of eleotronio :npohoring, and pay per moth for the cost of the moo:it:4ft twice, :m1taa :Atomise directed by the court 10. You will at amulets with cturi»g do petted of eupordslort 11, Yon will have no contact (direct or indirect) with the victim or the vietha's family during the period of supervieloo. 12. You wilt have Ito control (direct or indirte0 with during die Period uralcievision It. Yea will malnial foil time omploymont or attend achoolicoestbnal school fo11 time or a combination of school/work during the term of )car supervision. ❑ 14. You will make t good folth OffOr towed comparing bald or fu.notionallkraoy skill, er a high FL-hoe oquiyalcnoy dlplont. El IS, Yoe will suoteuhally complete the ProMdem PesdutIon Promo, abiding by all ruler lad rogulatfocu ❑ Page 3 of Pont Sahel 01-16.0t . . . • EFTA00232403 It/ 2b/Alldb ib: 21:: Slababra t,1RVAr11 Cnenereee. MCC. fJ•4 40 • JEFFREY FIPSTELY CASE#50200$0'009.381A)=MB . . . • 0 16. You will Oa AlookoSes Amoy:nous otbIarcollea Anatymont meetings et limit moatbly,USI01141;betiilltlei ;' by Mu °cult t • "- " • ❑ 11 You mil MEHIlsussotand be reepOnsith by the payment of say core 1soFtosS Ape ' receiving mid treatment. Seas waived. If cousicted of a Dove& Violence offense, nit defined In a. 74121, Fit you must attend end succittifully oompkto bottom.' iMervendoo PTV's; unless Mewls* directed by the ' ' " ' , • n Addition) ketruocioelothemi5: • You will clod HIV/AIDS Awareneas Pmgremauetsdos of a class oluot Imo than two (Xi bean a storee11,0 IOW — - • (4) bowl in Intl\ the Grist for *blob will *mid bY Yn C) 19. You shall taloa your person:mom% place of raid:nee., velohle cc Noon al atria to owuresilon nachat my dna, by Bay probation or ernareunity cannel officer or any taw enftecuroont °Meer. • O 20, DEFENDANT MUST REGISTER AS A SEXUAL OFFENDER WITHIN 48 HOURS OF RELEASE • • O 21. AB A SPECIAL CONDITION OF HIS COMMUNITY CONTROL, THEDEFENDANT IS TO HAVE NO. UNSUPERVISED CONTACT WITH MINORS, AND TEE SUPERY/SING ADULT MUST BE Anton]) BY . THE DEPARTMENT OF CORRECTIONS • • • . . . . .• • O 22. THE DEPENDANT IS DESIGNATED AS A SEXUAL OFFENDER PURSUANT TO FLORIDA STATUTE 944.05 AND MUST ABIDE EY ALL THE CORRESPONDING REQUIREMENTS OF THE STATUTE, A " " COPY OF WHICH IS ATTACHED HERETO AND INCORPORATED HEREIN IZ 23. DEFENDANT MUST PROVIDE A DNA SAMPLE IN COURT. THE TIME or THIS PLEA. OK a SPECIFIED CONTACT WITH in PAROLE AND PROBATION Omen O 25. CONFINEMENT TO AN AGREED-UPON RESIDENCE DURING HOURS AWAY FROM EMPLOYMENT AND PUBLIC SERVICE Aouvrrus PSI 23, MANDATORY PUBLIC SERVICE 2d. SUPERVISION, BY THE DEPARTMENT OE CORRECTIONS BY .MEANS OF AN Burr-Rolm MONITORING DEVICE OR SYSTEM 0 27, ELECTRONIC MONITORING 24 HOURS PER DAY 12 23 CONTR.:Emma TO A DESIGNATED RESIDENCE DURING DESIGNATED HOURS OF AND, IF PLACED oNHEISIDEDIUDICHATION, YOU WILL COMPLY WITH THE FOLLOWING CONDITION CONDITIONS SUPERVISION IN ADDITION TO THE STANDARD COSIDTTIONS LISTED ABOVE AND ANY onsra snout ORDERED WY THE COURT: • (14)You will partkipsta Fa a syedslized thus recto:al pronto. either es tr. In-patlent or out U•Vdnerilooddoll by the Footmen' provider. Yon • attend all coneeling acssiom, ruicialtto random urboalyais and, Han losedem, you will comply with all operating tats, repletion, and prooedurei of the inatnr-nt facility. You wilt pay for all out& noticed with treatment aced tendon totem °Omelet directed. Additioul iturroblonn ordered: O &mood (IS) Yoe wiE r=Mil at your raidsmo between • p.m aid am duo to a cu-kw imposed, mien otiumiso by dee oourt ADDITION AND, IF PLACED ON a mmvxrry comm. YOU WILL COMPLY WITH THE FOLLOWING CONDITIONS. ORDERED TO THISTANDARD CONDITIONS LISTED ABOVE AND ANY OTHER MGM. CONDITIONS BY THE COURTt Pogo 4 oft Pam Revisad 034E-0g EFTA00232404 11/25/2006 16:28 3553626 a ' JEFFREY EPSTEIN CASEIS02008CF009381A502:0413 DiNUUll UNIMIINAL rm.= gutoo • ' (I4)You will report to yob(' offitet its directed, it•leart'intetiatta a Ws*, unlearnt have written consentotherwise. 0.5) You will moth confined to Yaw approved residence except for oils habeas before and after your approved employment, ' . public service work, or any other 9,0514 activities approved by yam' officer. ' . . : .416)Yoo will nwhioinan haply accounting of all your activities ono daily jot. which You wit remit torous °Eno* nib ilettnert • • • (17) You will success thEY complete hours of community servirs mane of at I work site approved by you officer. Addinantl inetructiohe ordered( • (II) You will submit to electrode monitoring, follow tie mica of oleotronlc monitoring, and pay 6 pa °n th . for the coat of the manorfng tondos, valets otherwin directed by the mot AND, ri PLACED ON PROBATION OR COAfMtrwrrrY CONTROL FOR A SF,X OFFFNOE PROVIDED IN CHAPTER . • 121, 800,04, #27.071, or 047,014 6, atrine ON OR ATECERSCTIBER I,1595YOU WILL COMPLY WITH THE FOLLOWING STANDARD SEX OFFENDER CONDMONS, EV ADDITION TO THE STANDARD CONDEMNS LISTED ABOVE AND ANY OTHER smolt]; CONDITIONS ORDERED BY TUB COURT: a 04)A monitory meow from 10 p.m to 6 eat The court may eilsaaie. godly Fhour period if the offender's oroloymtth preoludoa the above speoffed time, and tho alternative is recommended bYthe Noncom:it of Corrections. lithe owl dthermices that Imposing a ccatew would endanger the V.ot121, the court may moist& alternative motions. (16)11 the victim was under the age of 18, a prohibition on living within 1,000 bet ore solsool, day an center, park, playground. of other piece whore children Mel* congregate, es prescribed by the court. The 1,000-foot distance shall be matured. in a IOWA fine from the candies place ofrosidenoo to gm nearest books,line of the school, day can canter, park, playground, or other place when children orgregate. '.he dlowint may act be rolsond by a pedestrian routs or mute mobilo route. (16) Aotht pargoipation in end suecessful completion of a sex effcnder trammed prove= with qualified practitioners specifically MOO to oat sex offender; at the offendm's own myna& Ifs qualified practitioner is not available ulthlo a 50-mile :Ohm of the offender's roldonce, the offender shall participate In cam appropriate therapy. (17)A prohibition on any contact with the sienna, dbtelly or indiredy, boluding through a third person, unless approved by vim vlodm, the offeretre Useen; end the sentencing alum (i8)1( the Viotm was odor the en of 18, a prohibition oo roman with a oMid under the age of 18 except as provided in this paregraph. The cowl may approve supervised contaM with• a ohild under the ago of 18 if the approval is based upon a moommonittlon for contra iesned by a qualified proddeor who is basing the roommodatIon on a risk Assessment. Pother, the alm offecder roust be correctly carolled in m have succentifily completed a oat offender therapy program. The court may tot pant superviond covet with a ohild if the contact is not recemomoded by ■ qualified notional' and may deny supervised contact with a ;bad at any One, • (19)1f the victim was under ate 18, a prohibition an workini fbr pay or as a volunteer at any place whim' children regularly oongtagste, including, but riot limited to any oboe!, day ova onto, Pak PlaYVaand, pet One, library, 200. theme park, or man .(10)Unlass otherwise indicated is the treantent plan provided by the anal offbeat tratroon program, a prohibidon on slowing, accessing, ocraIng, or poisoning any -obscene, pornographic), vr mushy tabulating vlsual or eadbory materiel, Windbag telephone, electronic media, eocarlter Programa, or computer S0nStif that ere relevant to the offender's &Anent behavior pattern. (21)A nthniretneml that the offender submit two specimens of blood or other approved biologioel specimen/ to the Florida Department • of law Enforcement to be registered with the DNA data bank. (12) A mainland that the offinder make eastimilon to the gob; es ordered by the owl under s. 275.089, lbr all nooemary medical and rotated protean:col mica relating to physical, payahlauto, and psychological ono. (13)Subrainier. to a warrontles: stench by the commurdac centre! 01 probilloa officer of the oftendar'epena rteidezhe, or vehicle. Pages of 8 Pena Reviled 03.1141 EFTA00232405 All 40/ LOW lot 415 AitOLe . 4 I . ; • pu.swwe I VI to111.1•••• I nw ,m ••••1 *OW. JEFFREY EPSTEIN CAS138502008C2009381A=MEI EFFECTIVE FOR PROSATIPNER•ORCOMMIMITY cobrreoun WHOSE CRIME WAS CONENTITED ON .. .:•••• TOR A VIOLATION OF.CRAITER221, s. EQ11, t. [ 417,071, era )µ7A146 nx ADDITION TO ANY. OTHER.PROYISIOS s . OF THIS SECTION, YOU MUST COMPLY WITH THE FOLLOWING CONDITIONS OF sup.tRyisioNt7, • .. , . . . • • • . • (24)M part of Imams PrcHgem, protialpilion liked enntelly in polygraph traniutions to Sala kiforomtke georoanry tot*, .• msmgemeot and aostmeot end to tedueothe see: offondoet denial mecheroura. A polygraph cxemblation'aroal hi conducted Flys— : pclygrapher trained imecilkany in the use of tht polygraph far the roonitcring of tea offenders, ten *Callable, end shell Iroptdil . , 1 . by the sex offender. (25)24eintorrenes of e Wog kg end a proldbIllon spine delving a motor Nohi:le alone without the prior approval of the ropervising offi=. (26)A proklbroon outlast obtaining or talrg a pon offNo box without :he prior approval of the roperwhing officer. (27)If that was Witte ititittic a atatlittill ro, it fire offirodere expense, en HIV Wit with themsults to be lamed to the vktim and/or Om Addis pandit gannyeas . • • • . . (28)Eleehonie monficffog erbeineemsd 'nem eery by rho probation officer and ouperolior, and iodated by the court at the recommits:dation of the Dtputment of Cperocdong • • • (29) Effective for an offender whose crime war committed once after July 1,2005, and who are placed CC riPervillon for Notation at chapter 794, $.890.04, s. 82/.071, ore. 847.0145,e prohibItkit on accessing the 'Liana or othar computer services mitil the offender's sex °tithe vestment property otter a risk suessmont is completed, rpprovet and implanters? a *stay plan for the offeoderi moronity cr using ths Intenset or other oorapitior sarvioa. . . • . (30)EffectIve for offenders wbote crime was oammlnel on or after September 1,2005, iron Is hefty Imposed, In ;Mem to any other provision in this motion, mandatory olcotronio monitoring a s oondltIon of supervision for those who: .c Axe placed on nmentelon for a violedon of *brow 794, a. 800.04(4), (5), or (6), a. 827.071, or t. 847.0145 end the unlawful usual activity involved a victim 15 ram of age or younger and the offerrom le II you. of age or older, or • Are dosipated sr e ;expel predator pumem to g 775.21; or • Has proViougly boot. co:Meted o f a violation of chapter 794, s. 800,04(4), (5), or (6), t. 827.071, or a. 847,0145 end the imlawfirl emet trinity Involved a victim 15 yeent (lege or younpr and oho offender le 18 years of ago or aloft You Sr. hereby placed on notketbst should you violate your probation or commtroky 00ThiTOI, end Si conditlotu at forth m t 948.03(1) ur (I) are sstroffed, whether your probation or community oonool is rot or not revoked, you shall be placed on ohs:prongs monitoring la accordmoe with F.S. 948.061. • • YOU ARE HEREBY PLACID ON NOTICE that the court may at any . time maid or =WY any of the oDeditions Pot ' probation, or may extend rho paiod of probation es authorised by law, or rosy diarbarge yon from &Mx smaryklon, If yen violate any °Me milldam of you probation, you may be *nested and tie court may revoke your probation, adjudicate you pithy if adjudication of pilt we withheld, and Impose any sontence that it might bon imposed before placing you on probation or requite' you to sone the balance of the entemeo. . • • • - Pogo 6 ofT Far RrAsidi:4-3-0$ EFTA00232406 1 ltlosialitl lb: .1:2›..4b2b . , 14.1.1~11 erururvt. rms. .101/ 40 JEFFREY EP67EITI CAS131502008Qt0093$1A7,50403 ; :.• !•• • . • ORDESUID !het white:yea We Icitiiteletruttåleu Wen Conditions of probation, you gall be released froto:••••• •: ' • ' ' ' 0000toly It you no id eagerly; ead !fie oteol•Illiefkiet teed, the surofia Ihefeø &bon stand cheek:Sod Row tablIttIt Pie paroinspb applito • only if wae! or "don 2 lo oheolce.d.) . • • ft.. • • • •0 • • .. rr 18 PORTION ORDERED that thrsolothefthle art& thlsordet In the Choke °Moe aod Feria Girded Goyim °film° Ye' • • • the oftleer IS we to cozen:cow %Ids the reeititretente °flew. Don AND °ROUEN Go • .ty NUNC PRO TUNC 115-30.2001 bite look*, viloolso ctotipt de copy of tills order 'Ed Choy ibe oon2Iticess Myth L. (plainoi *) to roe end I aim to abide by them, . Innveted bp W37•02•01 Suporeister 0S:or Defsadon: Perm Revised OM Sol EFTA00232407 8-222 8£12.9 Lag sum:cum zu ..wranco . . . . • P WSW SPBTRIN CASHM0200n0093111.1.700048 Vaf\We• .'a• 1S • ••••••••m• Potts mei.* • •. • • COURT ORDERED PAYMENTS • .• . . .' • • • • +•1•. • . Clad( ALL !RAT AltiORDiREDi ••• " • • • • • ' • •r. . ' • 'Total of flan attuned In seldom, porous! to a. 775.083 (1)(s) throne, (g) or Owns 316, 0,S, . .• • • • • •• Stotelonly nandoled 5% surchugokor Ifluo rasseasol (on fIrs1 hno) puma* to 938.04,ES. . tatt Come Stopper:et Fund rnniOnl 03. 938.06(1), F.S. Balytoriltnuadoted If Ore is : a. • 3.• . . • . • MANDATORY ("OM TULL CAMPS Additions! cooricoN hr M ow Winn. ponant to I. 93L0 (1);a), PS..S . A dtitilorul marl cart for lard IMMOOF or clams trunk °limos pursuant tot. 931.05(1)(6)eir (4, FS, Crania Carommation Trait Fund peasant to.. 91103(l), FS, • • • . ani 3 ty trims Punnet:03 Food purrant to k 775.083(2), p•5, Additional Cart Cab atmlog Trost Food ponamt to e. 938.01(1),F S. • Far month for tack month of atiscnIske fa Training Taus Fond Biadlaft% Puma 101.94409, r.s. • MANDATORY COSTS D1 ST.F.CIPIC TYPES OF c„ASU • Rope aids Program Thai Fold, moan to 4738.085, PS. Tor any violation, of a. 794.011, 784:024,114.03, 714244 ' . • 761.043, 714.018, 711.01, 784.01 184,081, 7144.062714.083, 784.085, et 794.011, F.S. • • •• • • . Dmontic YINinoeTrut Fund, passe* lo a. 938.03, FA far any violitions of 784.011, 784.021, 784.03, 7841081r714098. • 784,048,71401 784.04 794.081 791•082,784.0113, 714.015, 794.011, or my Minnie of Donor* Woltinar 06ealbedb I. ... ... . .. . . . Certain Cams Aping Minors, poramot to k 938.100. P.S, for my Holtdons Mk 184085, *soma 167, cbapter714.r: 796.03, a. 80084. chapter 827, a.8472145, or ossat,F.S. • • DUI Cart Oat; purmen to a. 931107,ES. foray violations offs 316.193 oe327.35, PR. • Sate Agemay Law Enforamat RadioSlum Tref Paul, puma*: to t 319,19071 PA br any niolotions otoffenses lined Ina. 318.17 baidirg a, 316.1935. 116.027, 316.0611177.111 chap*. B93! a. 316.193, 316.192, 316267, 3 16.072(3), 316.545(1), er my oilier offnam 1n {Samar 316 MAO la olsoollod a. onnenol vtolstloa. MANDATORY COURT COSTS AUTHORIZED BY LOCAL ODVERNMINTAL ENTITIES Criminal Jeatka Edamdm by Menleipalltto and COO, tits, purloin to.. 921. 13, it ' Additional cart 00fla for local requirement, Ant Ober county Snood programa puma* le 3. 939185(1M, P.S. Ten Corwin:mart to a. 93 8.1 v2). PS DOCRETICYIARY C Pfranora claim *a tern of aupervalon to No *amain& nonprofit organkallob eariblahod far the solopumas° of 49PSIstrataat ea maalliadve *Tani of du, Dayanmem of Carociarte. yavvuu in t 941.033(2), P.8.: ❑ /40424 retain Dafander A NMI utbo En, if tor yrtniontly oaltectoi or waved, Nam* to.. 27.52 end k 93827, P.S. 0 3.. Public Dahaular Fees sod Cork Punks tot Ma is... diannined 85 Ina ?roses trtlo ofbautigalva Cora paten to I. 93t27, O Oten ❑ Ober; • sZa ❑ 42,2.m DisCRVIONARY COSTS FOR SPECIFIC TYPTS OP CA8ZA County Altehd and Orbs: Drug Abula Trutt Food, yonnun tot 939.21 Ind a, 938.33, F.S. far *Madam oft Si 6.193, 856.011, t. 1$1015, or cheptar$62, defter 5.57, or Meow 568, P.S. • Ops Wag Trot Food of eta FDLIS, Novara a a. 93825, RS. tbr ufaCIOMP oft 093.13 offbua • *TOTAL $ 47310 PAYMENT IS TO BE MADE THROUGH AND PAYABLE TO: E) Dapvonem of OstendMI Of O Clerk of Conn (If oolimied by da Pawning of Corrections:, a trircharge ot414 will bo added to Ali peNamis 0419,91 999r1”10/00 toe. 9453 • Eat) O Ewa Costa/Finn Waived Cowl CcatoThas lathe amount of Coup Cow/flocs In the mow of SPECIFIC INSTRUCTIONS FOR PAYMENT; —Pia 8 ots_ conveyed to evirernmity tartlet, hours roduoM to olvEyadymens Reload 034 IDS EFTA00232408 RECYCLED PAPER TO REORDER CALI. 94.846.9399 EFTA00232409 IN TI FE CIRCUIT NIAN-D-84A-P*L-NtlitACT COURT OF THE FIFTEENTH WM Y. • LORI DA STATE OF FLORIDA vs. JEFFREY EPSTEIN, Defendant. CASE NO: 2006CF009454AXX DIVISON: 7I AG R E Eu_ORD ER 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 n ber. The Court being fully in the circumstances, it is hereby: ORDERED COVaC C? AND ADJUDGED that thndocument fi led by the Defendant be on July 2, 2008 sealed by the Clerk in the court file. DONE AND ORDERED this in chambers, West Palm Beach, Palm Beach County, Florida ;14/2 day of July, 2008. t7EBORAH DALE PUCILLO Circuit Court Judge Copies fonvarded to: Jack A. Goldberger. Esq. Counsel for the Defendant West 250 Australian Avenue South. Ste. (400 Palm Beach. Florida 3340L Lanna Belohlavek. Esq. Assistant State Attorney I interoffice) EFTA00232410 ' • - 2 EFTA00232411 ( • STATE OF FLORIDA, Vs. JEFFREY EPS'THENT, Defendant. / NONPARTY M'S MOTION TO VACATE ORDER SEALING RECORDS AND UNSEAL RECORDS M., 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. ENV 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".) M. presently has a pending civil action in this court against defendant for damages. Case number 502008CA028058)COCCM33 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 Sealing Document In Court File entered July 2, 2008 (Exhibit "B".) 3. The sealing of these documents was done without written motion required by IN THE CIRCUIT COURT OF THE FEREENTH-JUDiektellitetill IN AND FOR PALM BEACH COUNTY FLORIDA, CRIMINAL DIVISION Case Nos.2006-CF9454 AXX 2008-9381CF AXX — Rule 2.420(d)(1) 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 EFTA00232412 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 scaling 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 M.'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, M. is unable to obtain them or utilize them in her case. 7. Pursuant to Rule 2.420(d)(5), 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 CU. ) -11IBREBY CERTIFY that a true and correct cop.),of the foregoing has been served via S." and Facsmile this ( 92-Itay of May, 2009 to: Jack Alan Goldberger, Esq., Aiterbury Goldberger et al., 250 Australian Ave. South, Suite 1400, West Palm Beach, FL 33401. 2 EFTA00232413 ROTHSTEINSPOStotroL,u Aln-dit Attorneys for Plaintiff 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, Florida 33394 Telephone Telecopier By. Bradley I. Edwards Florida Bar Non= William UBerger Florida ar N . 3 EFTA00232414 p •ro v k i? J IN me cRIMINAI. DI% 'SION OP u I . dui r RT OF TI If! FIFTEENTH JUDICIAL OWL rr OP FLORIDA. IN AND FOR PALM REACH COUNTY 'c\SE "‘f O8TS NUMB!! J(//4)1Y STATE OP FLORIDA II I I . 2.1 OF ffaI lif/rapf(A-N9r) The above Dofendant. briny "ersondl I I RTI1 W. M RACE CONINIUNITY CONTROL IOLA ma PRORATION IOLATOR IIIIIIII111111111111111111111_ CFAI 20080267522 OR 8K 22760 PO 1061 RECORDED 07/17/ 2088 08 i 52:54 P.S. &nob County, Plar /do Pg Shoran R. Book, CLERK B CORPTROLLE 1081; 1pg GENDER SOCIAL SECt RITY NIIMBER JUDGMENT Weft th's Cntirt r c:ccnted Hm Ing been Merin:xi found guilty or the following evinces): Having cute cd a pica ur Itti lily to the ril I‘)“ ins crime(s): (allurne [ I Having entered a glen of nulo contendere to the following crime(c): Coiirrt /AWE DI' C~CL-) OFFENSE 6 /(z__)( sregije );(,\ wit ) , 1-29 DECREE 3aP￾10 )b-J-tuli and an ensue having been Onion why the Delenaant should nni be teljudicolcd guiky. rr IS ORDERED THAT the Defendant Is heron A DJUDICATED GUILTY of the ahtne admit& and hating been coin lewd nr found guilty M. or has Ing entered a plea of :yin conremlen: yr guiltyreganlleir of stkordleat ion. to anenips ar atones (dating to mute] battery ich. :04a lewd aid lasen iota eas.MI tall 3004 ur murder II '42 041. aggravated battery (s 784 04S I. klfglAl, is. 510O2i.g.atrehusg 44 312 LTA. or luene :atn runners a I35i..v ui” offn›e >panned in •eclien 943.325. the defonJant Jun iv Ny.ered ni yinnal Hon, .panten. I I and g•-• •!...r...• av..; a IT Di fIR insr.n vr Non inn ririN I a II T mum j) SEN TEN< 'E I I 'le C.tnet Lark. •Lo • and ninth...N.1 %..t.h•11».t• tg•t% .tr.d e•• 'r II:I:titian' on Sin Hi i IM•kan•1.w•.t.•rl I C raten.'• C'•• I.:4•541 I • • • f rnd n. SEN I E‘cy. DEFERRED I ; Ca•tit brrel+) &fen, unpostuon tit •enter.e . - P.:: I kt c. ie.sre • • • nr nit) da> • • ••••••i: JAI! g .••• • • :4•• .4•41...år å , . . a:. • 'era kIngrda: yrr4.1.å"'"...ts:•%riCa:•:•t!le • ; 4 id' in EXHIBIT -e '119 i A \Ire ../1. es \ Oglif FED .1 C inn In 111 I/T II Illif • (Irv.. Pr -.I lie.oay ^.r• I ' , EFTA00232415 " r',1 THE RISIINAL DIVISION Or ACCITCOCRT me FIFEF.ENTH JUDICIAL t'IRCUIT OF FLORIDA. IN AND FOR PALM BEACH COUNTY CASE NO Oars NL STMT. OF FLORIDA epSki TES DANT P /1 GENDER SOCIAL SECURITY NUMBER I I comm.:on. CONTROL VIOLATOR I I PROBATION VIOLATOR INIMAIIMEIHME1111 CFN 20080267252 OR SR 22760 PO 0565 RECORDED 07/17/2008 08 I 96s 42 Palo Beach County, Florida Sharon R. Bock. CLERK & COMPTROLLER Pg 0563; flpg/ JUDGMENT The 4hove Defendant. &Int •rsonall before this Court re •rescnted by Id I nuornc Hering been Wed and found guilty of the fallowing crime(:): Having ma:nada plea of guilty to the following edniefs): I Having entered a plea of nolo contendere o the following cri awls): 17758o-h PAL/ itkit OFFENSE STATUTE Nti.s.t9 ER(S) - 70.0 DEGREE VT￾I and nit cause having been shown why the Defendant should not he adnulletned rns ORDERED THAT the Defendant Is berth • ADJUDICATED GUILTY of ow oho% c crirnefsh. I I and hating been COM Rl.Tl C found guilty of. or hat Ins entered a plea Af nolo contendere or guilly.regardlest of adjudication to attempts or nirtrbet mbar', to wtual battery ht. 794‘ laud and luso% Hutt conduct 'ch. SOOt or trturder rs 7S: 04t, aunt teed battery is 7S4 015.. burglary is ID Mt capain,u. SI2.031. Of home int aaion nate° rt I 35t. or any other offense spect0ed m Whnfl 043.325. the tlefend.ud dull he :endued to WWII Mani !Mennen, I I :d'J re'd 'blip; %NIA n IT IS rift IN:"RED MAT AIM DR '•1 rioN to- rd •Ir r oh wroursq 9 . ,i • • . SEN I ENO? I i In: roan ncegiy., 43)...std %tit:tog. ung."Inlin of •V31,31i'v a OV.VIIV.• .r.4 0. ..".7, the LS:Sendant in STA Yri) I I PlohJIM'll DI1L'N't I roaltaINVI, colVitli Nikki ukr Arta% ormi lei in.. OEM ilti''''Pal'eviVtit . f pnr---r - ••• II.. le in weir Aro itidet I P Tli,„ .,, ERKEI) I I Th: l'atet !wren) defers unpositien of matt :nee wad __ _ .. _____ . ._ . rite Vet:sill-to :n rv‘ or V .1•.J.%:etlei b:• f $i'.11., vcrt.li f!..ell a.: i...b:. ....i 0,.., I:: ...: -.4.,:... .;.r,,, s •...,....c ;; 4.. • I ..an %eta: try; ..to • 1.1!•im tr.; iked.III•r:o.tc r. relf•••:JOrratontAn...trikte4 pa ouri to t. ...b..b.. anon The de fe.t.lan: .41 a, al..‘ a I.:•:.I.ab.• ::ahr t.: :Ise s.A:yt.t...: .. . . -1?••••2"•-bl in i..ton: 'ad -rival .e:br vttroc .1 is surer nes eYbantj intnIiiilet ' ' ' sp. A \PI MI 0di :11..• I 'tett .• .): Paboalle r. CI Ira.... fc.t. d.r :!:••. _ 1 _. 0 .1.* .. 1 _Etihia__....._ Il it 43 /r 1 eA, e e-t' ..ut..g. -/ . n. , : ..1,1 • , t 1 I Ir rot writ EFTA00232416 MT. OP FLORIDA v& -52 O1 Taste; n. ON "CA) Zy), Do g IN THE CIRCUIT COURT OF THE FIFTEEN PALM BEACH COVNTY tnr￾CASE No. a V V (I. C. , SY/4 • DIVISION 1,) • , . • D Psychiatric (Medic., etc, Report dated From Presenteoce Investigation Report dated fro., tia other NW7 - Prose,. 'oil I4 f1 ar7,77 4-- SEALED IN COURT FILE, NOT.T.P. I1E . OPENED WITHOUT MIS ORDER OF COURT EFTA00232417 IN THE CIRCUIT COURT OF THE FIFTEEN. JUDICIAL-GIRGUIT-OPPLORSDATIN-ATID,- PALM BEACH COUNTY CASE NO. %Cr do 5 9.3"Y 4-)\i STATE OF FLORIDA ON DIVISION Je e(1 g .pSte hp Psychiatric (Medic., etc.) Report dated from pre.ntence Investigation Report dated from ,CAN N.O AUG 10 2098 other lT(/4' A'LvO TD kkov pr SEALED IN COURT FILE, NOT TO BE OPENED WITHOUT ORDER OF COURT EFTA00232418 IN II IE CIRCUIT COURT OF THE FIFTEENTH 1W.D-ROR-PA-EM-BEXCIITTICWITFE5rDA STATE OF FLORIDA CASE NO.: 2006CF009454AXX DIVISON: "W" JEFFREY EPSTEIN, Defendant. PNC, R EFVN ORDER SEALING DOCUMENT IN COURT FILE •FHIS 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: affaCAng ORDERED AND ADJUDGED that thllocument filed by the Defendant on July 2, 2008 be sealectby the Clerk in the court file. DONE AND ORDERED in chambers, West Palm Beach, Palm Beach County, Florida this le day of July, 2008. BOFtAH DALE PUCILLO Circuit Court Judge Copies forwarded to: Jack A. Goldberger. F.sq. Counsel fur the Defendant 250 Australian Avenue South. Ste. 1400 West Palm Beach. Florida...13401 — Lanna Belohlavek. Esq. Assistant State Attorney t interoffice) . . . . . . . . . . s 0 .• . . EFTA00232419 1 IN THE CIRCUIT COURT OF THE FIFTEENTH C JUDICIAL CIRCUIT = 1 ====sanaccgam.. 2 . ..........t NANDFORr ..........._ rnALtl BEACH COUNT ORZDA---------- 3 DIVISION 4 6 7 8 9 10 PLEA CONFERENCE 11 PRESIDING: 12 APPEARANCES: STATE OF FLORIDA ) ) vs ) CASE NO. 06 CF9454AMB 111) JEFFREY ) 08 9381CFAM8 EPSTEIN Defendant. ) ) ) ) •••74, ro sn • • 1•1 ;12 (1 7, F:F%74 2C • HONORABLE DEBORAH DALE PUCILtark., 1.-;; 13 ON BEHALF OF THE STATE: 14 BARRY E. KRISCHER, ESQUIRE State Attorney 15 401 North Dixie Highway West Palm Beach, Florida 33401 By: LANNA BELOHLAIIEK, 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 3-0, 2008 Palm Beach Count? Courthouse West Palm Beach, Florida 33401 Beginning at 8:40 o'clock, a.m. ...... _ ........ _ PHYLLIS A. DAMES, PORTER EFTA00232420 e ri 1 on that, Your Honor? 2 THE COURT: It is Ding—t.o—las ) 38 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 to 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 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, I wanted 21 to tell the court. 22 THE COURT: I understand, that would 23 also_be invalidated-shoul-d he-violate-his 24 community control? 25 MR. GOLDBERGER: Absolutely. That PHYLLIS A. DAMES, OFFICIAL COURT REPORTER EFTA00232421 39 4 • 1 nonprosecution agreement -- 2 MS. BELOHLAVEK: 5 6 7 8 out. THE COURT: Mr. Epstein needs to come closer. Mr. 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 16 17 supposed to, they have, have agreed not to prosecute you federally, did you understand 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. DANES, OFPICIAL COURT REPORTER EFTA00232422 „. ) 40 agreement very carefully spelled out if 2 there was a bria.ach—h-at—woutd-71-761ate this 3 agreement, so 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 a 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 16 17 18 19 that's the right idea. (Return to open court.) THE COURT: Mr. Epstein, is there anything else? 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 PHYLLIS A. DAMES, OFFICIAL COURT REPORTER. EFTA00232423 d2 EFTA00232424 ti • t. . • I in this notbli rot thP qmired i• • • • se of seeking acqesa to;documents Sri radar seal. ; ThedoCuments relate ilitecily to the Del dant's guilty plea and seSenoe..' Thus, the sealed • • •hi 4 *I. h F6-91-'89 ;15:34 _ a & LOCICB0 8139843878 • T-988 P883/887 F-845 ,, • • I • I • • 1. . :. • .. • IN eilm CIRCUIT COVET OF THE FIFTEENTH JUDIOIALCIRCHTT I i.. . t • • *:.; li • . AND pm PAu4 BEAcs COUNTY, PWRiDik I . . IN . ; • CRIMINAL DIVISION • ti :, • i ,;:. : WAT? OP FLORI4, i gril ; I r tr(l i t I • •I . Case Nos.: 2006:-CFO.454-AX)i & . : .. • • . • :2008r93$ICF- : JEFFREY EP FTED1 • ; 1 . . • • 04 • I 1•P•i:i • T'6 MOTIONTO R'YE E .; "IIPPPerl12/ ON FORA a The Palm Beach Pest (the? ost, moves to i • • • ; , docuttuints go to theheirt of the disposition of this mac. :But In req gestinf that Stri p Pucillo • • • . ; • seafthicse !clocurnenti, ildni‘tio.'sifailt;d to I regoirgmerta fat seafingiudichil • records: • ; with Florida's egto!ligoceduraVand substantive • • .2; :' • h. pointless, because these documents have been discussed repea '.1.: • ' .1 ,.. ; • " of the.; rations, the dequments must be 4sealed. As grounds for ri : .; ! 4 I :1 , : • ji,..' • • .. k ii :41 ' ; ' 1.1. 1 ' : :1.1$11.95 ltia;didly npwsge er that has covered tis. • *%! .sigl • - .: 1• 1 ;! 1:::; !! : I . ! .1. . • • 0 in PI ETINtitOPeinpa Its sea err concerning these • ( 1 P.it . . . II ; I : 1 li : • th!POirl i•;0 7! II IInt I' rds and judicialrecOrdi)? !: . . . . .• • . it !, III i .. I dstk,p,manger of the news Media, the Post has a right to Intervene in criminal .. •Ir • :. ..; ! /.; tallow. eetti!nped seYl s'' giftless, 3ocumems is court records, For all i on, this Post states; related : Post i•elles uPon • • .• 1 !: : • • • • • I ; go irti Jhe Site& purpose. of seeking access to proceedinis d records., frSse Herron y, . • • ' Florght hitch:1m NeWspatiers. Inca 531 Sq. 2d 113, 118 (Fla. 1988) (news media have standing i • . ! to Oral: erre* RAY cloSure order); Miami Herald Publ'g Co. V. Loveili$4, SI. 2d 1,i, (Fla, 1982) ; ; 1 (news Media rtm aktai glyist an opportunity to be heard on questions, ulp‘), • : . .; , • . • .. ; • , , • F . . I : EFTA00232425 ' 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.: • ; EFTA00232426 • i . ; ; ' : t • (June 36, 2004, Such a representation fad well short of demonstraAjitc?mpeling interest,* ... • • I i I ? I ' . . : genuine necessity, =go* tailoring, and that no less restrictive mcastFW will WS • . ii . . • i 1/14 I ....;. N.,! Conseq,!ently, the sealing was improper en ought to be sct a.i.klei .1;::? • • l'fil ' • .1 ' " I 1' 6. • ' in Sint:41,1d this time gun cause exists for unsoaliiiith cements beciuse of • i i 1:. Li: • :. i ' ! i • .., i; . . i lie!! ; • • ; .:: 1 their 'WIC AO , .:. Sinop the Defend t pleaded guilty in 'Ir011in a minor for .. l . iiiii al leas 2 civil lawsuits that r ' • .:, k ges in this case - • girls to e hii home for, sex js." At: leas. . I I • n . . . I • • .t.;.: 1 I ' lavlisuit, ente of the Defendant's acr es has alleged that , :%-; • i t ferliral 'u1oni failed to consult with regarding the dispositieri dpossible charges , a i • i I ,1 , •) agahrsethe Dafendent.2 State prosecutors tilso have been criticizethae Palm Beach Police • . • • '. 05-21-'09 15:34 FROM-THOMAS & LCCICERO 8189848879 . -j88 P285/007 F-845 Yrd • • •.; • • • • ••.' it ../! • I I. • : 114 •!' r f • ••, Ch'divas faulted the Satte Attorney's haling of these cases as uldilliMuursual" and called fbr . • : 10;4 ' • • ' • . ' the State Attorney's ilisquidificationt equently, this case — and, cularly le Defendant's ,• 1 4! Thli• 11,!! Withkiliti•tirrr404,i le public interst aid cream. I ' • ', ::if .5'4.: '.; !I; i• . ; - :. ! tt • • • tdra also !las:.• . t . . ••., : 3:4 Defendant's riot)-prose I ; 1.1 to Itififfe;Plic,i!iti; 'As ktcl'i . r, ; .1 •:ie on agreement With. prosecu the Julio 2008 plea akin ' vieni (the. inducement 11. pCear r *Plea; • I. ! recollithei a strtnibu, , of acbese to • • with sentencing. $158111Sta Perak} Tribune: Dive . .! 2 ! • 1•1 IM,1‘))6tiv. 1 :Ecititilk Case N . 08-80069 (S.D. Fld. 2008);Doe No. 2 v. Epstein, Casc'No. 0840119 (S.D. 'Fla. 2008); ' Case NI: 08-80232 (SD. Fla. 2008); • :, r : Doe 4. v. Epstein 08.80380 (S.D. Fla. 2008);Doe No. p 4, Epstelni Casc No. 08- 1, • 80381 .(S.D. Fla. 2008) v. Epstein, Case No. 08-80811 (S.D. Fla. 2008); Doe v. Einstein, • ) CatioNo. 08;80893 (S.D.:Fla. 2008); LbilaSay„112goig, case Nii.:08-81)993 (S.D. Fla: 2008); Doe NO. .5 v, Ensteld, CAS* Ne.08-80994 (S.D. Fla. 2008);Poe II is; bistoin,Case No. 09-80469 : V ! (S.D. Fla. 2009); Dasukaaisatlin. Case No. 09-80591 (S.DliFla.!,2009). jibeNo. 102 v. . i;! ' Ensteh2610,9Case14o. 09-80656 (S.D. Fla. 2069); Pot No, 8 v• Ffesteln,toiseNo. 09-80802 (S.D. :. t • 1008)41 119,tii 3 I • I • • 1 1\' t / 1 !. 01 1 • • • I 1 • I ... • : • h • i :2Se{ Af/4024,24541Q• • • I • , •, •• . • I . • • • • •• !.. I .1 I . • • I I I *. I•4. " • ..2.1t I ... I I . C.; .1 rai l • • • . . I EFTA00232427 .1. I • • • 34 •Camila& toczcsti i • • , -81-1 9915. 8 lt139843878 , ,'. ' T-388 P096/807 F-845 I - -- ;': • t! $ i, . 11 • i I i: 3 sl . CP. ; !1. : ' :11•1• ;. ; I.: • ; . . 1. . in i; t • I ". : I ' .• i • . I. 1• • • ...s" .., : .. I of the New York Times O1,zaloitzendori . 507 So. 2d 667, 668 (Fla. 2d D.CA 1987) nithIle a . , • I i, j '. ' Judge may impose whatever legal sentencelbe chooses, if such senteiri4e is based op S. tangible • • . . ; , . • • . I • I !, ; I t • proceeding or documprit, it is within the p bile domain unless othes444 'Privileged."). in ilia . • li'l 1 •• • , case, no interest justifies continued sealing of those "significant" &Pinnate that Judge Prmillo . 1. 0. 1 , If . • I. . • • • :1, :. i i considered' in acceptikt fin plea and son jcing the Defendant. • Ilila 1141 ' .f any s L h • ' • • , 1 , • . . ' i . , • . it • 1 • • ; : ; compelling Serest —ui well as the parties failure to comply:with . " " r sealing l I • • I i ' c • ' • ; ,a00‘hit4 initially jpr0tkie lied cause the drmum tlfs time' : 4 I. : 1 . it . li - • . . • .: t. I ; .. i r . .. ,, . ..4. ..... ,,,..., nisnlit,OS4finue[lHeIrme . these documents is pot because malty portions . I I . ty, ' • • . , 1 • lit 4 °. , • :i.; r It, 1 id iltini41 irOpdyilimpio i made public. l'or examtle;ccityt papers quoti4 • il. Otitis a81e4aint bays ;eat madepublio in related federall;rmeeclings.3 As the Florida !. .J..II / ., •• , . ; i! : ''. • ki• i • Srmsrmie 'corm hat nistad-,31hesiket0uM be litliejustificatien for elOsing a pretrial )tearing in -1.--c , it, • ,, . . • . • . i 1I„ . i i.:i order! ii, prevent only the disclosure Of de*: which had already .bettOPubqoized.? Lewis. 426 1 I; • So 2c1I ii Simi . lol l 'into ' to the that information (Sidi gas 1•••••." made 'publics. • I: ri; l •• '• I i; 1.1 ..' rt : • ! • ' TP 1 5413' ,.Ilitat • • cl i 1 I • , ••' :I: 'I : '. .. eoridri3ed Plorme is 'ruses and, therefoce, Onermatitatirmat • . ;14 ' i • redaetionOf VictimP Of ) that t‘peer r.iii • ! 1:" ;;• Pet • Pe PPIthile,neetdeenee the • • t ,..• leaf Tr; ' ...., , hi, l;04.14 4. ni4nig, In 84411[011, . roes as the Defendant ?z• SISeitiorney leek confirmed i, : 1 •• F.; • • elosyri, tho Post rivals !lift dple .1110 documents In • .! • . ' : ' 1 • • 1 I ' • , I i .. • • I • • • • i :3 See, e.g.. tcfcndants Jeffrey P.prmin and Eget,.. selego. 0840811-(9-J*Fk-Juir 233-2008)-(filed in ha; , einidnu0k desire la peeper l• II:I I ••• u i : 13 •• I I I " • .• I •I i • I I I. I "•• I '. ; • • • I ; [ • • 4 in °dolt° esseqo • • • • I • 1 it i • .1 I I • .1! i . • : MOduli for Stay,"Ma, •?, 2009). 1:11 1 I 4 I }! i I • : • 1 %4 I 1 EFTA00232428 : p6-Y1-'ø9 15:34 FIltil-TECIMAS 8 LOCICEBO 8139843(378 " • * • T-E88 F8e7/3457 F-845 r.; 11 I i ••• lil. rt 1 i . • •j • • C.1; i i i :• :, ; • !• t• r •• • , 1 3 I 1 . . . i*DEREPIDS, die P. osiresPeotfuliy requests that this Cour! miind the no -prosecution . , : I • it: . : .ii eidiandaddertdurninntigranfthe Post such other relief aa thtf.Cpurt deems Proper. il . . . . . i ',A !I . • :: i I. ... I • r • • . i • r r I is •• 4 . V ! • J. I ''': • • i Nials4IntileTaixt U.S. Mail to; R. Ainstneter Acosta; United StatesAtIhnt&s Oiglet ;•Soulhorn • !I li. :' • i District; SQ0 S.Austttillati Ave., Ste. 400, West Palen Beach, FL 3,.41 91 11.fiutat . • . .. • r : • • * nit • • 1 ' ;':y i i !I i Illeitaa WiteAtiliffe,IEsq,i, and Judith Stevenson Arco, Rs.q? Stat4! ney's Office -*eat • • • ; • J.. •4 r; ii Palm Beach, 401 Noilh Dixie Highway, jest Palm Beach, FL 33 I. - •i ; Jack • :! is .. r • • : Man Goldberger, aq!; Åtbn•bpry . Goldberger, et at, 250 S.:AiiiStrktailliAte., Ste, i 1400, West I i i-i ti I. , : • ; ; .., : ' 1 • •• $.1 • i ht '. •• Palm Beach, FL 33401 (fax: =~; and Bradley4 • . and William J. , . • . • y llf 'I' i • . . : Berger; Esq., RothstakfRoeenlbldiAdler, 401 East Las Olas Blvd :111.; 3650, Fon Lauderdale, Ili • ' I ' , jr, !. Ir: ' .:ridri Pt 43JN (taxi bath's ist day off:Ina, 2009.! 1.11,1! : : • t.:( : : i• ! st. i ' re+ I • : . ! • ,•:, • il • r )h, i I li • E. 4i ' I : I I lk i : i i ii :p ..• i i. . , e : i.i . r • . •.i• 'I I : • I! : • l•• , ' ; • : • • Respectfully submitted, THOMAS, LOCSI`siii.0 fis BRAL OW PL • I • canna K. Sh Florida Be; No.: James B. Låke Florida Bar No.; 101 N.Ç. Third AvinVe, de 100 Fort Lauderdale :13301 ; Telephones. Facsimile: i fi) Wit ;• I •S' • le'l 1 I ; ' I I' i • • • •. . ! pERT1 CATE OF SERVICK • i, • : j•E: : I • 6. • i • • , • .1. •• I. I • Attorneys for 7a Beach 'lost flA : f I ; . I iiBRBB K /WY that a hue and correct copy of the fbriegOiniihas been furnished : F. • 71. • . • : . • • It ? • • • • • ttomcy 5 .1. EFTA00232429 LEGAL RECYCLED PAPER TO REORDER CAVIL MEM EFTA00232430 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 2006CF009454AXX, 2008CF009381A)OC STATE, vs. EPSTEIN, JEFFREY E, Defendant. MOTION TO INTERVENE AND SUPPORTING MEMORANDUM OF LAW COMES NOW, Applicant, ■. 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. EFTA00232431 5. Defense counsel, Robert Crinon, 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 So.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 So.2d 207, 211 (Fla. 1 st DCA 2003). "An intervention is thus only appropriate where the issue the intervenor raises are related to the case being litigated." Facing Properties. L.P.. v, Baldwin, 885 So.2d 881, 883 (Fla. 3rd 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 So.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." W. 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 Holdinns. Inc., 748 So.2d 1090, 1091 (Fla 4th DCA 2000). Page of 4 2 EFTA00232432 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'" 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. 1.280(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, M., respectfully requests the Court ■'s motion to intervene in the pending criminal matter. Page of 4 3 EFTA00232433 CERTIFICATE OF SERVICE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by U. S. Mail, postage prepaid, thisiL day of.,\641e, , Unti to Jack A. Goldberger, Esq., 250 Australian Avenue, Suite 1400, West Palm Beach, FL 334101; Bruce E. M, Esq., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401; Robert D. Critton, Jr., Michael J. Pike, 515 North Flagler Drive, Suite 400, West Palm Beach, FL 33401. LE0P0LD-KUV1N, PA. 2925 PGA Boulevard Suite 200 Palm ns, FL (561) (561) By: Pige of 4 4 EFTA00232434 EFTA00232435 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 attorney's, 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 ■. and Palm Beach Post Motion to Intervene on June 10, 2009 but took no immediate action orb Motion to Vacate Order Sealing Records and Unsealing Records or on Palm Beach Posts Petition For Access, pending a further hearing. EFTA00232436 6.. 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 faith and supported by a sound and factual legal basis. 4 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 d AZ ) -e---- My Commission Expires EFTA00232437 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via o U.S. Mail; ❑ Facsimile; a Overnight Delivery to R. Alexander Acosta, United States Attorney's Office-Southern District, 500 S. Australian Ave., Suite 400, 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 1650, Fort Lauderdale, FL 33394; Deanna K. Shullman, 400 North Drive, Suite 1100, P.O.Box 2602 (33601) Tampa, FL 33602, Robert D. Critton, BURMAN, CRITTON, LUTTIER, & COLEMAN, 515 N. Flagler Dr. Suite 400, West Palm Beach, Florida 33401. this 11 day of June, 2009. BURMAN, CRITTON, LUTTIER & COLEMAN ATTERBURY, GOLDBERGER & 515 N. Flagler Dr. Suite 400 WEISS, PA. ach, Florida 33401 250 Australian Avenue South Suite 1400 ach, Florida 33401 -c- 4 ERT D. C_, RITTON ESQ. CK A. GOLDBERGER, ESQ orida Bar NoME lorida Bar No. EFTA00232438 i 14 EFTA00232439 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." EFTA00232440 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 /Orator Health Care of Nashville. Inc, v. Baker, 739 So. 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. 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 ■'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 EFTA00232441 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 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 El'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 JEFFREY SLOMAN, ESQ., United States Attorney's Office — Southern District, 500 S. Australian Avenue, Suite 400, 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. SHIJLLMAN, 3 EFTA00232442 400 North Drive, Suite 1100, P.O. Box 2602 (33601) Tampa, FL 33602, this 25th day of June. 2009. BURMAN, CRITTON, LUTHER & COLEMAN, LLP 515 N. Flagler Drive, Suite 400 each, FL 401 By: Robert D. Cri Florida Bar Michael J. Pike Florida Bart_ Counsel for Defendant Jeffrey Epstein) and on, Jr. Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 W Pa a FL 33401-5012 Fax: Counsel for Defendant Jeffrey Epstein 4 EFTA00232443 EFTA00232444 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 2006CF009454AXX, 2008CF009381AXX STATE, vs. EPSTEIN, JE'FFREY INTERVENER'S E O u. 0 T i TAY AND UPPORTIN COMES NOW, Intervener,.. and files s Response endant 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. PursuaM to nirida 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 EFTA00232445 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(f) (emphasis added). Defendants ask the Court to stay disclosure of a public document which was never properly sealed. Factors to 'dared by a court when deciding whether to enter a stay "include the moving p s likeli success on the merits, and the likelihood of harm should a stay not be gra 769 So.2d 389, 391 n.4 (Fla. 3d DCA 1999). Defendants fail to adequately ad•` s 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 ad 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 procedifie for sealing court documents were ever followed, the NPA is a public record. Page 2of 3 EFTA00232446 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. Esq., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401; Robert D. Clifton, Jr., Michael J. Pike, 515 North Flagler Drive, Suit est Palm Beach, FL 33401. LEOPOLD-KUVIN, P.A. 2925 PGA Boulevard Suite 200 Page 3of 3 ens, FL 33410 (facsimile) T. KUVIN, Esq. ar No.: EFTA00232447 Page 2 of Wdstlaw. 769 So.2d 389 769 So.2d 389.24 Fla. L. Weekly D2439 (Cite as: 769 So.2d 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, held that: (1) 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 Headnotes [11 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. [2) Appeal and Error 30 C=479(1) 30 Appeal and Error 301X Supersedeas or Stay of Proceedings 30k476 Upon Allowance by Court or Judge 30k479 Grounds for Allowance 30k479( I) k. 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(0. (3) Child Custody 76D €:=7905 76D Child Custody 76DXfli 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 F.S.A. R.App.P.Rule 9.310(0. (4] Child Custody 76D sE :, 903 76D Child Custody 76DXHI Appeal or Judicial Review 76Dk903 k. Right of Review and Parties. Most Cited Cases (Formerly 211kI9.3(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. 2009 Thomson Reuters/West No Claim to Orig. US Gov. Works. http://web2.westlaw.eom/print/printstream.aspx?prfl=HTMLE&ifm=NotSet&destination=... 6/25/2009 EFTA00232448 Page 3 of 11 769 So.2d 389 769 So.2d 389, 24 Fla. L. Weekly D2439 (Cite as: 769 So.2d 389) (5] Infants 211 *:=85 211 Infants 211VII Actions 211k76 Guardian Ad Litem or Next Friend 211k85 k. Duties and Liabilities. Most. Cited Cases (Formerly 211k19.2(2)) Universally recognized function of guardian ad !item in custody dispute is to protect best interests of children. (6] Infants 2116577 211 Infants 211V11 Actions 211k76 Guardian Ad Litem or Next Friend 211k77 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. (7] Infants 211 re="85 211 Infants 211 VII Actions 211k76 Guardian Ad Litem or Next Friend 211k85 k. Duties and Liabilities. Most Cited Cases (Formerly 21Ik19.3(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 sE:=)900 76D Child Custody 76DXUI Appeal or Judicial Review 76Ok900 k. In General. Most Cited Cases (Formerly 211k 19.3(6)) Child Custody 76D 4C=,903 76D Child Custody Page 2 76DX1I1 Appeal or Judicial Review 76Dk903 k. Right of Review and Patties. Most Cited Cases (Formerly 211k19.3(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 4C=.85 211 Infants 211VII Actions 211k76 Guardian Ad Litem or Next Friend 21Ik85 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. (10] Child Custody 7613 sC=903 76D Child Custody 76DXJ1.1 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 litem 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 7613 C=>409 76D Child Custody 76DVIII 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 7613 e=•903__ it 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works. http://web2.westlaw.com/print/printstream.aspx?prft=HTMLEctifin=NotSet&destinationt... 6/25/2009 EFTA00232449 769 So.2d 389 769 Sold 389,24 Fla. L. Weekly 132439 (Cite as: 769 Sold 389) 76D Child Custody 76DX111 Appeal or Judicial Review 76Dk903 k. Right of Review and Parties. 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. Perwin, Miami; Bar￾ranco, Kircher, Vogelsang & BoIdt, and Kimberly L. Bolds, Miami, for appellee. Before GERSTEN, SHEVIN, and SORONDO, ON APPELLANT'S RENEWED MOTION TO PRO￾HIBIT FURTHER INVOLVEMENT IN THESE AP￾PELLATE PROCEEDINGS BY THE GUARDIAN .LITEM AND/OR COUNSEL APPEARING ON BEHALF OF THE GUARDIAN. 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• peal'*" FNI. 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 11 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 18, 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￾O 2009 Thomson Reuters/West. No Claim to Ong. US Gov. Works. http://wcb2.westlaw.com/print/printstream.aspx?prftnIITMLE&ifm—NotSet&destination=... 6/25/2009 EFTA00232450 Page 5 of II 769 So.2d 389 769 So.2d 389.24 Fla. L. Weekly D2439 (Cite as: 769 So.2d 389) mein, the children spent the *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.' The 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." 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. FN3. 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 11112113] 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." Fb14. This Court has authority to issue a stay under Rule 9.310(0, Florida Rules of Appellate Procedure, for the purpose of preserving the status quo during an appel￾late proceeding. See Hirsch v. Hirsch, 309 So.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 So.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 C 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works. http://web2.westlaw.com/print/printstream.aspx?prft=HTMLE8cifm=NotSet8cdestination=... 6/25/2009 EFTA00232451 769 So.2d 389 769 So.2d 389,24 Fla. L. Weekly D2439 (Cite as: 769 So.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 preserved. See Offer• man v. Offerman, 643 So.2d 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".m3 Not surprisingly, the Former Husband also filed an emergency motion for review of the order granting the stay. *4 On August 26, 1999, this Court denied both the Former Husband's and the Guardian's motions. FNS. 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 Litem." 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 panics' 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=HTMLEedfm=NotSet&destination=... 6/25/2009 EFTA00232452 Page 7 of 11 769 So.2d 389 769 So.2d 389, 24 Fla. L. Weekly D2439 (Cite as: 769 So.2d 389) est son. The Former Husband filed a similar motion entitled "Father/Appellees 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 lawyer to serve wins." See Sarasota County v. Lx, 645 So.2d 7 (Fla. 241 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. For 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 (4)[5)[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 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 Scorings v. Her. rick, 711 So.2d 204 (Fla. 2d DCA 1998); Repres￾enting Children: Standards For Attorneys and Guardians Ad 1.1tem In Custody or Visitation Pro￾ceedings (With Commentary), 13 J. Am. Acad. Matrim. Law. I (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. See 61.403 Fla. Stat. (1997). However, the duties and responsibilities of a guardian ad litem are not coextensive with those of an attorney. See Roski v. Rosk4 730 So.2d 413 (Fla. al DCA 1999); see also Representing Children: Standards For Attorneys and Guardians Ad Diem In Custody or Visitation Proceedings (With Commentary), 13 S. Am. Acad. Matrim. Law. 1 (Summer 1995)(a guardian ad litem 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 so 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 So.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 FIV7. The Former Husband contends that 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 EFTA00232453 769 So.2d 389 769 So.2d 389, 24 Fla. L. Weekly D2439 (Cite as: 769 So.2d 389) Section 61.401 should be interpreted broadly as permitting guardians ad litem 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.m FNS. 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. 19)(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 interests'394 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§ 61.403 Fla. Stat. (1997); Scaringe v. Herrick. 711 So.2d 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 I I Page 7 FN9. Although Betz involved the role of the guardian la 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. Posada, 760 So.2d 954 (Fla. 3d DCA 1999); Or￾ange County, Fla. v. Game and Fresh Water Fish Commission, 397 So.2d 411 (Fla. 5th DCA 1981); Florida Civil Practice Guide, Vol. 6, § 143.03 (Lexis Publishing 1998). [II) 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 C 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works. http://web2.westlaw.com/print/printstream.aspx?prft=HTMLE8cifm=NotSet&destination=... 6/25/2009 EFTA00232454 769 So.2d 389 769 So.2d 389, 24 Fla. L. Weekly D2439 (Cite as: 769 So.2d 389) custody proceeding are not considered as "necessary parties" to the action. See Shienvold v. liable. 622 So.2d 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. (121 We arc 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 filed 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. Betz. 254 Neb. 341, 575 N.W.2d 406, 410 (1998Xa 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.noo Guardianss395 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. State. Derr of Health and Rehabilitative Servs., 704 So.2d 583, 585 (Fla. 1st DCA 1997)(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 9 of 11 Page 8 pointed representative); Kingsley v. Kings￾ley, 623 So.2d 780, 784 (Fla. 5th DCA 1993)(guardian ad fitern or next friend is required to represent a minor in a termina￾tion of parental rights case), review denied, 634 So.2d 625 (Fla.1994);Fla. R. Civ. R, Rule 1.210(6) (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."'" FN11. The Guardian's motion for leave to file an amicus curiae brief pursuant to Florida Rule of Appellate Procedure 9370 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 (1991), precludes the guardian from taking a position in this appeal because the guardian's argu￾ments will place her in the role of advocate.'"" 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￾tit) 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works. http://web2.westlaw.com/print/printslream.aspx?prft=HTMLEetifm=NotSet&destination=... 6/25/2009 EFTA00232455 Page 10 of 11 769 So.2d 389 769 So.2d 389.24 Ha. L. Weekly D2439 (ate as: 769 So.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 !item to represent the child. As relevant to the issues before us, section 61.403, Florida Statutes (Supp.1990), stated: Guardians ad !item; 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 litem 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 litem 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. Slat. (1993))(emphasis added).*396 Section 61.403, as pertinent here, was also amended: Guardians ad litem; powers and authority. A guard￾ian ad [item when appointed shall act as next 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, Ha. 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), Fla. 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—NotSet&destination=... 6/25/2009 EFTA00232456 Page 11 of 11 769 So.2d 389 769 So.2d 389, 24 Fla. L. Weekly D2439 (Cite as: 769 So.2d 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 her 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 pleadings only through counsel-a "true" party could do so 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 I read the statute, the guardian does not have a party's 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 filly 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. "r I do not believe that this appeal calls for the guardian's participation. F1413. 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 sponse decision to hire counsel in this case, presumably at the expense of the parties, was highly im￾ProPer￾Fla.App. 3 Dist..1999. Perez v. Perez 769 So.2d 389,24 Fla. L. Weekly D2439 END OF DOCUMENT Q 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works. http://web2.westlaw.com/print/printstream.aspx?pr11-HTMLE8cifm=NotSettcdestination--... 6/25/2009 EFTA00232457 16 ' a t Ir t il EFTA00232458 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CRIMINAL DIVISION "W" CASE NO. 502008CF0093811=MB 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 M.'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 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: EFTA00232459 Page Two Case No. 502008CF009381100018/502006CF009454AXXMB 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 taseal thetourt records are denied. 3) The Motions to intervene are granted. 4) The Motion to unseal the documents is granted. EFTA00232460 day of June, 2009. Copies furnished: R. Alexander Acosta, U.S. Attorney's Office - Southern District 500 South Australian Avenue, Suite 400 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, Suite 400 West Palm Beach, FL 33401 Page Three Case No. 502008CF009381AXXM8/502006CF009454AXXMB 5) The originals will not be disdosed, however the undersigned will do an in￾camera inspection and redact the names of the underage victims, if any, so 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 disdosure 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 40 ounty, Florida this EFTA00232461 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 EFTA00232462 LE GAL RECYCLED PAPER TO REORDER CALF EFTA00232463 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CRIMINAL DIVISION "W" CASE NO. 502008CF009381AVMB 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 4t" 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 day of lune, 20O9. SIG ECTOVKTED JUN 2 6 2009 JEFFREY J. CO EvIEHEFFR EY J. COL8ATH Circuit Court Judge --------, EFTA00232464 Page Two Case No. 502008CF009381AXXMB/502006CF009454A10(MB Order Denying Motion to Stay Disclosure Agreement Copies furnished: R. Alexander Acosta, U.S. Attorney's Office - Southern District 500 South Australian Avenue, Sulte 400 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, Lauer & Coleman 515 North Flagler Drive, Sulte 400 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. 0. Box 2602 Tampa, FL 33602 EFTA00232465 ..,:s•• RECYCLED PAPER TO REORDER CALL 954446-9399 I- 1 CO EFTA00232466 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 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 EFTA00232467 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 EFTA00232468 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 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 EFTA00232469 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 so. 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 EFTA00232470 5 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 agreement to seal some portion of some documents, which she signed off on and now it is the intervener's and the Post's motion to unseal those documents; is that kind of procedurally where we are? MR. GOLDBERGER: Procedurally not exactly correct, I don't know if you want me to clarify that. THE COURT: Please do. MR. GOLDBERGER: Your Honor, this started during the course of a plea colloquy in Mr. Epstein's state proceeding before Judge Puccillo, who is a retired senior judge who was filling in for Judge McSorley on that day, who was the judge assigned to this division. It was a plea agreement with the state attorney's office and it is normal and consistent with any plea colloquy Judge Puccillo asked the defense whether there were any other promises or inducements for Mr. Epstein to enter into his plea agreement other than what was contained in the state standard plea agreement that we had. I felt obligated under the circumstances to alert SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00232471 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 EFTA00232472 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 EFTA00232473 8 1 THE COURT: All right. So 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 so that's -- I 22 hinted last meeting that we all had 23 together but that's where I'd go, so 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 EFTA00232474 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 EFTA00232475 10 1 colloquy in state court and just so 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 agreement 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 So, first, as a preliminary matter, SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00232476 1 2 3 4 S 6 7 8 9 11 it wasn't like we were coming into court on that day and asking to seal something, so it would have been presumptuous of me to file something to request to have something 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, so 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 EFTA00232477 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 EFTA00232478 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 EFTA00232479 14 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 nonprosecution agreement, they have it for their use, they know every clause that's in that nonprosecution agreement, and I suggest to the Court as to their motions why are we here; they have an agreement already. They went back to Judge Marra sometime thereafter expand their use of agreement, and they and asked the Court to the nonprosecution said, Judge Marra, we have the nonprosecution agreement but we would like to be able to disclose that agreement to other sides, and Judge Marra in another carefully crafted order said, nuh-uh, no, you have not satisfied your burden, you cannot disseminate this to anyone else, and the order that I have entered remains in place, but most significantly he said, you know what, this is without prejudice. If you have some basis, you have some need that you have not briefed, you have not litigated with me yet concerning dissemination of nonprosecution agreement, come back to me and I'll review it for you. SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00232480 15 1 And they have every right to do so, and 2 they have not done so, and it is this 3 motion to intervene that they filed in this 4 court is simply an effort to skirt and to S 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 so 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: So, 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 EFTA00232481 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 EFTA00232482 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, so 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 EFTA00232483 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 EFTA00232484 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, so -- 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 So 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 EFTA00232485 1 he will do it, but that's wh_ ere thi 2 need to be fought. 3 As a matter of comity, your t2 c=w- n 4 this Court should defer to j udge Ma sr a 5 because, A, he has already ruled on t.k - 6 disclosure of the nonpros ag reement. 7 even more importantly, the s -upremac 8 requires you to defer to the f ede re. fl r_ 1. 9 of criminal procedure that say thee e 10 matters should be protected and sho Zo 11 be disclosed unless the dists - ict 12 so. 13 If the Court is going to 9O Il=='" 14 wants to go to the issues that wo u 1 or￾15 contained if it were not dealing " 170. 16 grand jury proceeding, obviously th e 17 test that the Court must then use u s. a aLe 18 Rules of Judicial Administration ana. 19 says matters can be sealed but they s h 20 be sealed if there's a compel Ling 21 government interest or if the g 22 important to the administration of u s 23 There's a couple other criteria. but= 24 ones obviously that would app 1 Y in C._ Th. j. 25 case are the compelling government SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT R IDORTEI ..._ EFTA00232486 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 so. 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 EFTA00232487 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 EFTA00232488 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, so 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 EFTA00232489 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 ■'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 EFTA00232490 24 1 So 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, so 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 so 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, so 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 EFTA00232491 25 1 And so 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, so 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, so 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 EFTA00232492 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, so at SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00232493 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 so whenever. SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00232494 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 5 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 EFTA00232495 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 see the document and evaluate how they 6 might need to evaluate this document does 7 not apply to my client because she has 8 never seen it and, frankly, without 9 subjecting herself voluntarily to the ,10 jurisdiction of Judge Marra, which she 11 chooses not to do, then she cannot get this 12 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 EFTA00232496 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 EFTA00232497 31 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 convoluted situation that brings us to the courtroom. MS. SHULLMAN: Just this whole federal state situation. There is no hill for the public and the press to march up in Judge Marra's court as Mr. Edwards pointed out, Judge Marra has specifically held the agreement was not filed in this case under seal or otherwise, so were I to march into Judge Marra's courtroom and do my whole public access spiel, he would say take it to you, your Honor, because it's not a record in my court. It is a record here, and in the state court as we talked about the last time, presumption of Mr. Epstein to While he filed we were here, there's a openness. The burden is on overcome that presumption. a very brief memorandum after our last hearing, which identified for interest, he has by no means met the test of either establishing those interest or establishing the remainder of that test whiff would be that closures no broader than necessary ineffective no other reasonable alternatives, so if I could, I'd SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00232498 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 EFTA00232499 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 33 incidental filing, which cannot possibly be the case here, there is no mechanism in Florida law to call a Mulligan and to pull it out of the court file. As you know, the Floridians have a constitutional right of access, there's no mechanism in that law to just say, oopsy, let's take it out of the file, so they have to meet their burden and they have to show under Rule 2.420 that one of those interests is satisfied. They have identified four here. I have not heard them discuss them at any great length. But I will go through them quickly. The imminent threat to the fair, impartial orderly administration of justice, or to protect a compelling government interest. As your Honor is aware, the federal government is not here today. I have spoken with the state attorney's office who has indicated that their only interest is in protecting to the extent necessary because I've not seen these documents the identity of the victims of these crimes. The Post in its motion to intervene SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00232500 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 EFTA00232501 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 EFTA00232502 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 EFTA00232503 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 EFTA00232504 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 EFTA00232505 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 EFTA00232506 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 EFTA00232507 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 EFTA00232508 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 EFTA00232509 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 EFTA00232510 44 1 before, your Honor. 2 Your Honor, we do intend to take 3 certiorari on this to the Fourth District 4 Court. 5 THE COURT: That's why I figure 6 between the written rule and the disclosure 7 give you a chance to catch your breath and 8 do that. I guess you might want that. Is 9 Monday 5 p.m. enough time for you to get 10 over to the DCA? 11 MR. GOLDBERGER: Actually, your 12 Honor, the Rule of Appellate Procedure 13 maintains jurisdiction with you on this 14 matter to entertain the motion to stay. 15 THE COURT: So I need to handle the 16 motion to stay? 17 MR. GOLDBERGER: Correct, your Honor. 18 THE COURT: Do you want to argue that 19 now? Do you want to take a look at that, 20 catch your breath, come back and see me 21 Monday sometime; what's your pleasure? 22 MR. GOLDBERGER: We're ready to do it 23 now, your Honor. We're ready to do it now. 24 THE COURT: All right. Interveners, 25 your thoughts. SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00232511 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 BB's 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 24 25 an hour later tomorrow? THE COURT: 2:30. MR. GERBER: If possible. SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00232512 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 EFTA00232513 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 EFTA00232514 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 5 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 23 24 25 SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00232515 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 22 _ _ 23 — 24 25 C2644424 (.143ttli 4 SUSAN S. WIGGINS, .P.R. SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00232516 q W CW i 19 EFTA00232517 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 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 EFTA00232518 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 EFTA00232519 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 LoCicero and Bralow on behalf of 22 the Palm Beach Post. 23 MR. KUVIN: Spencer Kuvin on behalf 24 of the intervener III 25 MS. BURNS: Barbara Burns on behalf SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00232520 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 EFTA00232521 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 EFTA00232522 6 1 similar to that for which they would have 2 to obtain a preliminary injunction. 3 THE COURT: Right. 4 MS. SHULLMAN: So to demonstrate 5 likelihood of success and irreparable harm, 6 I don't think they can do that. I think 7 the plan that you put in -- proposed 8 yesterday is a good one, that is you redact 9 and you release on Monday and that gives 10 them today and Monday to get to the Fourth, 11 otherwise, we're stuck in a position where 12 we have a 30-day window to appeal, and we 13 are all delay, delay, delay. 14 THE COURT: What if I do that? I 15 don't know if it's a difference with that 16 or distinction, but, procedurally, I was 17 thinking I was leaning yesterday towards 18 issuing the order that I just issued. I 19 think that that's a fairly accurate 20 rendition of the written version of my oral 21 pronouncement yesterday, but I order that 22 nothing -- that the redacted orders not be 23 released until -- I'll make it, you know, 24 five of five Monday. That will give you 25 Monday to get down to the Fourth to get SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00232523 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 EFTA00232524 8 1 harm where no stay is granted, and the 2 second criteria, not necessary mutually 3 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 EFTA00232525 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 EFTA00232526 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 EFTA00232527 11 1 We cited a case called Mariner versus 2 Baker 3 -- So. 39, So.2d 608 First District 3 1989. In the Mariner case, this was not a 4 usual incident report and the Court, I know 5 your Honor previously did a great deal of 6 personal injury work and related work, 7 you're very familiar. In fact, you 8 commented yesterday and said, I don't see 9 how the MPA is going to be admissible in a 10 civil proceeding anyway. Again, you're not 11 ruling on that ultimately, the judges in 12 both the State and federal court cases will 13 do that. 14 In the Mariner case, the judge 15 ordered that the defendants object at the 16 direction of incident reports. The judge 17 said, sorry, you've got to produce those 18 incident reports. And the Court said, give 19 them to me under seal because, again, we 20 are talking about incident reports as 21 distinct from an agreement between two 22 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 EFTA00232528 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 EFTA00232529 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 EFTA00232530 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 EFTA00232531 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 EFTA00232532 16 1 right of access doesn't have a waiver 2 provision, your Honor. 3 THE COURT: Well, go ahead. Let me 4 hear -- I'm on board so far with 5 Mr. Critton's version of, Judge, if you let 6 it out, you let it out, so irreparable harm 7 is kind of easy. I think that it is a 8 two-prong test. I think he's got to jump 9 over both hurdles. I think he's got to 10 show some likelihood of success. If you 11 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 EFTA00232533 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 EFTA00232534 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 EFTA00232535 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. 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 III obviously, the 25 Court is inclined to delay the disclosure SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00232536 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 EFTA00232537 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 EFTA00232538 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 EFTA00232539 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 EFTA00232540 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 EFTA00232541 25 1 2 3 4 THE STATE OF FLORIDA, 5 COUNTY OF PALM BEACH. 6 7 8 9 10 11 12 13 14 15 16 17 18 June 2009. 19 20 21 22 23 24 25 CERTIFICATE 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 SUSAN S. WIGGINS,R.P.R. SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00232542 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been sent by E-Mail and Federal Express this 300-4 day of June, 2009, to: JEFFREY H. SLOMAN U.S. Attorney's Office-Southern District 500 South Australian Avenue, Suite 400 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 fore. 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, Suite 400 West Palm Beach, FL 33401 and JACK A. GOLDBERGER ATTERBURY, GOLDBERGER & P.A. 250 Australian Avenue South, Suite 1400 W t Pal ch, FL 33401 and EFTA00232543 Counsel for Petitioner JANE KREUSLER-WALSH and BARBARA J. COMPIANI of KREUSLER-WALSH, COMPIANI & VARGAS, P.A. 501 South Flagler Drive, Suite 503 ch, FL 33401-5913 NE 1=1.7; 2.-VVALSH 14 lorida Bar No. EFTA00232544 EFTA00232545 MARTIN G. WEINBERG, ATTORNEYELAW 20 PARK PLAZA SUMS/OM EMAIL ADDRESSES: IfdriTON, MASSACHUSETTS 02116 FAX July 22, 2011 Assistant United States Attorney United States Attorney's Office Southern District of Florida 500 S. Australian Ave. Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey Epstein Dear Ms. MB 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, 471a.,t 2gi Martin G. Weinberg cc: Roy Black EFTA00232546 07/22/2011 15:55 3053582006 BSKS PAGE 02 ZO PARK PLAZA, MIMI MN mem% MASUClitUrt9.92116 NUM' LIVERMICY: 017), II4i71 MARTIN G. WEINBERG, P.C. A 7TORNEMIAW Assistant United States Attorney United States Attorney's Office Southern District of Florida 500 S. Australian Ave. Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey Epstein Dear Ms. July 22, 2011 RAM 1): ADDRESSES" 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, 411 DS i9 Martin G. Weinberg cc: Roy Black EFTA00232547 07/22/2011 15:55 3853582006 BSKS PAGE 81 BLACK SPEBNICK KOPNSPAN STUMPF TO: RE: Afffee9 ep54eio￾DATE: July 22, 2011 SENDER: Jackie Perczek NO. OF PAGES (INCLUDING TRANSMITTAL SHEET): MESSAGE: Wr\ibLAI TRIAL ATTORNEYS Roy Black Howard M. Srebnick Scott A. Komspan Larry A. Stumpf Maria Neyra Jackie Peraek Mark A.J. Shapiro Jared= Marcos Beaton, Jr. Jessica Fonseca-Nader Kathleen P. Phillips Jenifer J. Soulikias Noah Fox Joshua Shore FACSIMILE TRANSMITTAL SHEET FAX: TELEPHONE: AUSA , Esq. N.•/- TARS, 11/Jo "IF YOU DO NOT RECEIVE ALL PAGES, PLEASE CALL THIS ractosms COlteATIMPERRIOSOISS ARE COMIthENTIAL DITORMATION. INTENDED ONLY. FOR PRE VSE-PII TW INDIVISKIAt. OR tIttnYEAMED ABOVE. PP THE READER OF THIS FACED= IB ROT TEE trots= RECIPIENT„ OR THE EMPLOYEE OR Assn. RESPONSIBLE FOR DELIVERING rr TO TEE INTERDED:gettpan, YOU ARE REMIT Norm= THAT ANY DURSOCNATIOR OR contra OP TIRE FACETRILZ TA STRICTLY TROROBtreD..; rr toy wont RS:4W= TED3 FACSIMILE DI ERROR Pinar BeotEtpAIELVVOTST BEEP TELEPHONE.. MD Ertl:IRS It ORIGINAL tAcsatat To US AT THE ABOVE ADDRESS VIA THE DE POSTAL SERVICE. TRAM YOU. • ' 201 8. Biscayne Boulevard, Suite 1300, Miami, Florida 33131 1(P) 1(F) I www royblack.com EFTA00232548 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: Jeffrey Epstein 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 "[Of 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 toTederal Rule of Cnmrnai Procedure 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 EFTA00232549 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, Wifzedo A. Ferrer United States Attorney. By: Assistant United States Attorney cc: Chief, Northern Division Deborah L. Morse, Assistant District Attorney, County of New York Roy Black, Esq. EFTA00232550 United States Attorney's Office Southern District of Florida 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401-6235 DATE -14/ 7/2 0// TO: ItA/K77A) Ale/N,8m0 ORGANIZATION FAX Si: SUBJECT: jerrim ElosrcliQ FROM: (Fax) NUMBER OF PAGES, INCLUDING THIS PAGE: COMMENTS: Original document: To follow via Federal Express To follow via hand delivery Nothireto follow, FAX -7. original EFTA00232551 Fax Send Report Date/Time Fax Number Fax Name Model Nacre NO. Name/Number : JUL-27-2011 03:01PM FLED : Phaser 33001.7P StartTime Time Mode Page Result 246 07-27 03:00PM 00'31 ECM 003/003 CLR United Slates Attorney's Unite Southern District of Florida 500 S. Australian Ave., Suite 400 West Palm Beach, IN. 33401-6235 DATE 7/42720c _area? WeavAatcit TO. ORGANIZATION: FAX IV: SUlialFcT. FROM: (561)820-8777 Vaal NUMBER OF PAGES. INCLUDING THIS PAGE: 3 _ COMMENTS. 0,49•An1 doaMint: 7o follow we regular mad To follow VILI Fads ft! EXPAIAs Tei Initow via ham) deswi y Nothearto loam, FAX r Angonai EFTA00232552 United States Attorney's Office Southern District of Florida 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401-6235 DATE: .7/2 712.O( TO: beloo-al Mcvse ORGANIZATION: New fork bisfritti44 FAX #: SUBJECT: s.71Fi FROM: (Fax) NUMBER OF PAGES. INCLUDING THIS PAGE: 3 COMMENTS: Original document: CL Tn follow via regular mail To follow via Federal Express To follow via hand delivery X Nothirrto follow, FAX = original EFTA00232553 Fax Send Report Date/Time Fax Number Fax Plane Model Name : JUL-27-2011 03:03PM ', No. Name/Number Phaser 3300MFP StartTime Time Made Page Result 247 10: ORGANIZATION Nein itAgraeti914?..4 FAX a: SUBJECT. <27 eft _ . FROM: - ax) NUMBER OF PAGES. INCLUDING THIS PAC,F 3_ _ . COMMENTS: 07-27 03:O1PM 00'57 ECM United States Attorney's Office Southern District of Florida SOO S. Australia° Ave., Sulu. 400 West Palm Beach, F1.334014335 DA1 E. :74n/zoo te-_se Origin,' I no m toe To follow via minim mai: 70 follow via Federal Erprass ro know via hood netnony • lailmv. FAX r. original 003/003 0.K EFTA00232554 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 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: Assistant United States Attorney cc: Chief, Northern Division Deborah L. Morse, Assistant District Attorney, County of New York EFTA00232555 United States Attorney's Office Southern District of Florida 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401-6235 DATE: 7/21/20 TO: .) Lc rkaki /(4OOe ORGANIZATION: biqrief FAX #: SUBJECT: FROM: (Fax) NUMBER OF PAGES. INCLUDING THIS PAGE: Z COMMENTS: Original document: Tn fnuow via regular mail To follow via Federal Express To follow via hand delivery NothiriTto follow, FAX = original EFTA00232556 Fax Send Report Date/Time : JUL-21-2011 02:08FMTHU Fax Number Fax Name Model Name : Phaser 3300MFP No. Name/Number 211 StartTime Time Mode Page Result 07-21 02:07PM 00'25 ECM 002/002 06K United SlaIM OrDey'S Office Southern DIstriel of Honda 500 S. Australian Ave., Suite 400 West Palm Reach, FL 334014235 DATE 7/21/70!? TO. ..tarntin Arse ORGANIZAI ION: blAlt.t AfirtiInt% FAX $. SUOJECT• FROM. (Fax) NUMOCRorPACIESJNCLOWNOTHISFACd COMMENTS: Oteginal docastnenf: EFTA00232557 Fax: Jul 17 2011 10:15pm P001/002 DISTRICT ATTORNEY CYRUS R. VANCE, JR. 661100T 4TTOR•L'Y Date: OF THE COUNTY OF NEW YORK ONE HOGAN PLACE Now York, N. Y. 10013 APPEALS BUREAU FAX DOCUMENT COVERSHEET FAX # 212-335-9288 gay /?Zo// To: 4 . 11 SA Fax: From: De eon: is Alarm— Tei #: # of Pages 2. (includes cover sheet) a URGENT o ROUTINE Deliver Immediately o Discuss with Appropriate Person(s) o As Requested o For Your Approval o Review and Comment o Take Necessary Action o For Your Information o Reply Via FAX o File o Reply Via Messenger o Reply Directly a Progress Report o c Investigate Prepare Reply for Signature o Let's Discuss o Other Action To Be Taken/Additional Comments: 41/04/ sated- Auk gindl shat A f A 41 7). F irett. Tf 17.Xn is 6 iorat, X te EFTA00232558 Fax: Jul 17 2011 10:15pn P002/002 DISTRICT ATTORNEY OF THE COUNTY OF NEW YORK ONE HOGAN PLACE New York. N. Y.10013 CYRUS R. VANCE, JR. DIAMCT ATTOANCY July 15, 2O11. , Esq. Assistant United States Attorney Office of the United States Attorney Southern District of Florida 5OO S. Australian Avenue Suite 4OO West Palm Reach, Florida 334O1 Dear Ms. 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, Deborah L. Morse Attorney EFTA00232559 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 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. By: Sincerely, Wifredo A. Ferrer United States Attorney sistant unneaMates attorney cc: Chief, Northern Division Deborah L. Morse, Assistant District Attorney, County of New York EFTA00232560 DISTRICT ATTORNEY al;4;. 477.‘ CYRUS R. VANCE, JR. C :WIC A TY <clic', OF THE COUNTY OF NEW YORK ONE HOGAN PLACE New York, N. Y. 10013 May 6, 2011 Esq. Assistant United States Attorney Office of the United States Attorney Southern District of Florida 500 S. Australian Avenue Suite 400 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 proceedings. If we furnish the minutes to the appellate court, we would do so 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 EFTA00232561 DISTRICT ATTORNEY OF THE COUNTY OF NEW YORK ONE HOGAN PLACE New York. N. Y. 10013 CYRUS R. VANCE, JR. OLITRICT ArfORW/T August 15, 2011 , Esq. Assistant United States Attorney Office of the United States Attorney Southern District of Florida 500 S. Australian Avenue Suite 400 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, Deborah L. Morse Attorney EFTA00232562 New York County Clerk's Index No. 30129/2010 'et' Vark tyrant arrurt APPELLATE DIVISION—FIRST DEPARTMENT PEOPLE OF THE STATE OF NEW YORK, —against— JEFFREY E. EPSTEIN, Respondent, Defendant-Appellant. APPENDIX CYRUS R. VANCE, JR. NEW YORK COUNTY DISTRICT ATTORNEY'S OFFICE One Hogan Place New York, New York 10013 Attorneys for Respondent JAY P. LEFICOWTIZ SANDRA LYNN MUSUMECI KIRK AND & Fs.r TS LLP 601 Lexington Avenue New York, New York 10022 Attorneys for Defendant-Appellant REPRODUCED ON RECYCLED PAPER EFTA00232563 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. Joe Recarey - 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-Office Booking-Card-for Jeffrey Epstein, dated June 30, 2008 A47 EFTA00232564 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 MO Letter from Jack A. Goldberger to NYS Sex Offender Registry Regarding Florida Registration Level applicable to Jeffrey E. Epstein, dated August 12, 2010 AM 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 EFTA00232565 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 EFTA00232566 Al Appellant's Pre-Argument Statement, dated February 9, 2011 Ipp. 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 PETITIONER: Jay P. Lefkowitz, 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, NYail 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 OBJECT OFIIIE 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 EFTA00232567 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 . Lefkowitz, P.C. S dra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, 111.1611 Telephone: Facsimile: Attorneys for Defendant-Appellant Jeffrey E. Esptein. -2- EFTA00232568 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: J . Lefkowitz, P.C. dra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, Ne Telephone: Facsimile: Attorneys for Defendant Jeffrey E.EPPILED .„ FEB OP 2u ,1 SUPREME COURT NEW YORK COUNTY APPNAL9. fr.‘UPMAk.3 EFTA00232569 A4 Order Appealed From, dated January 18, 2011 with Notice of Entry [pp. A4-A51 " v." S and of Ekarnkid;* 1tio nirdidichad103virafia. 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':3complete rril a..-Aittach and, attach This larili .. i jodr , a All : offender , „., , . -riiiitianadoiiIcoehe C.Ourts iirde,r PheasestitidbirtelhistemainkigtOpkes'astcated 0 •pAgsqvgc*ft : 1:O•Igiel14 41 --: 'tt"!•'"W, f!..;-,:FtWIlt"-P"I'lfrdeit: • !,CW,Ok V :1*i lla , c ; A.. . ... :-AfK14/:47-' VP:Stc,fii;:rflItt'Sit :;#1." "eg. 4%‘'rr:Sr 1100710€045 nfojmat i!anew Isla IM bpmpi. Sontehoftw.COOrt. •Abie .andfieeetlabliihetres ifeiluin;dei;relister!end in n on.for.the.. end . fl 0116CdtieetleiTtain ketieldeitiiiiifficriaehtfiS of sexually lidehk tte get' " 4?'• *NI tist*qi 'Mir"' "Cie &WI. aiii)ly:puitatta;ti 1: at 640 ti4 NYS. zr, • ginCaffe "401e. EFTA00232570 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, NYai m Telephone: Ja . Lefkowitz, P.C. Sandra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, Nelia-4611 Telephone: Facsimile: Attorneys for Defendant Jeffrey E. Epstein gat FEB Og "Asavna, irotecian cOp stir tnitirtmj • EFTA00232571 A6 Palm Beach Police Department - Probable Cause Affidavit of Det. Joe Recarey - Defendant dated May I. 2006 Ipp. A6-A271 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500400 Police Case,: 05-368 (2) Defendant: Race/Sex: White Female DOD: Charges: Principal in the r Unlawful Sexual Activity with a Minor (d) counts Principal in the 1" Lewd and Lascivious Molestation (1) count From March 15, 2005, through February 2006 the Palm Reach 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 Epstein, 358 El Grillo Way, Palm Beach. Several of the victims were recruited by and brought to the residence by to perform massages for Epstei for which received monetary compensation. During the visit they would be introduced to , Epstein's assistant, wbo 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 rub his fingers on their vaginas. On occasion, Epstein would introduce a massager/vibrator and rub the victims vaginas 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 ber 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 boyfriend and classmate a him. She also admitted that the month of February 2005, house. stated that 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 Death. During the drive a tated that doh a cousin High School, worked for a wealthy man and did sexual favors for had offered her an opportunity to make money. During the beginning of explained that she was first approached by to go with her to Epstein's along with a Hispanic female, later identified ag I Fick her up at The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Dee Joe Recarey, who is personally known to me. State of Florida County of Palm Beach Signature Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/ n 006 Page 1 of 22 EFTA00232572 A7 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500400 conversation occurred between and. whereas reportedly told that if Jeff asked her age, she should say she was was later confirmed by the lather 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. stated they were there to sec Epstein. The male allowed them to continue r 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 andlater identified as entered the kitchen. Epstein introduced himself to . . 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 Malone 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, 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 so 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 thong panties on_ Epstein then instructed her to give him a massage pointing to a specific lotion for her to usc. As U began to give Epstein the massage, he told her to get on his back.. stated she straddled herself on Epstein's back whereby her exposed buttocks were touching Epstein's bare buttocks.. 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 to or affirmed before me this l" day of May, 2006 by Det Joe Recarcy, who is personally known to me. Signature of Poli Kt e Officer (F.S.S. 112.10) Page 2of 22 State of Florida County of Palm B etch Signatur g Officer Date: OS 006 EFTA00232573 A8 Probable Cause Affidavit Palm Beach Police Department Agncy ORDI FLO 500600 massage. vaginal area. stated there was no penetration as the vibrator was on top of her underwear. MI recalled Epstein ejaculating because he had to use, the towel to wipe himself as he got 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. 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 561- Ia .. spoke with in an attempt to arrange 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 subsequently called back. and left a voice mail message for her indicating that she had set up an appointment for. to go to Epstein's house at 11:00 am on April 5, 2005. This message was recorded from IM 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 win 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 Frick and I went to residence and viewed her vehicle parked in the driveway, a red Dodge Neon. Sgt. Frick and 1 knocked on the door and met with was told that we were investigating a claim involving Jeffrey Epstein of El Brillo Way, in Pam Beac was asked if she would accompany us back to the police station for further questioning. She was also to at at the conclusion of the interview she would be returned home. Beach Police Department. voluntarily came with us back to the Palm 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 bcgan the interview by asking how she became acquainted with Epstein. stated that approximately two years ago, jui.she turned I 7 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 ri e $200.00. thought about the offer and agreed to meet with Jeffrey. The foregoing instrument was sworn to or affirmed before me this In day of May, 2006 by Det Joe Recarcy, who is personally known to me. State of Florida County of Palm Beach Signature Officer Signature of Police Qjfficer '.S.S. 117.10) Date: 05/0 006 Page3of 22 EFTA00232574 A9 Signature of Police filet (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency MS nn 500600 (Unknown last name) and Tony (Unknown last name) pickcd up and she was takcn 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 ler ern next to the massage bed. then left the room and informed Jeff would be in, in a minute. Jeffentered 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 grabbed her buttocks and she felt uncomfortable. told Epstein, ill 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. staled 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. stated she had brought the following girks: I MI mg ( al6 year old female), (a 16 year old female) said that at the time she brought these girls to Epstein's house they were x1114 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 thatE wanted to make money. She approached. and explained about going to work for Jeff,. agreed and anangements were made to bring her to Epstein's house on a weekend. stated that she and (law identified picked up. at her house. stated that at that time she was driving a red pickup truck. They traveled to E stein's house and entered through the kitchen door. They met with the 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 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 t" day of May, 2006 by Dot Joe Reearey, who is personalty known to me. State of Florida County of Palm Beach Signatur, g Officer Date: 05/01/2006 PageLlof 22 EFTA00232575 MO Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 when he was going to travel to a 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, they disapproved of the encounters with him and she stopped. further stated that still tries to call Robson's house and leaves messages. Sgt Frick 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 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 Frick 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: Mrs. introduced us to her husband and allowed us entry into the home. We sat in the dining room and met . with Date of Dirt. As she was under the age of eighteen, Mrsl was advised we would be i speaking with her. She expressed if her daughter had information, she wanted to assist. We interviewedll who 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 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 Frick and I thanked Mrs.' 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, Dot Dawson and I drove to the' ' ' home and met with and ,alt 0-. During a sworn taped statement, stated approximate y a year ago• when she was seventeen years old, she was taken to a house by stated she knows because they both attend High School. 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 Dct Joe Recarey, who is personally known to me. Signature of Police nicer .S.S. 117.10) State of Florida County of Palm Beach Signatur og Officer Date: 05/01/2006 Page 5of 22 EFTA00232576 All Probable Cause Affidavit Palm Beach Police Department Agency OFtrg FLO 500400 for Jeff She was told she would have to provide a massage to Jeff Mtated 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. 1 . was introduced to M 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 rowel an she provided a massage. ' lz stated she kept . her clothes on during the massage. She advised sometime during the massage, Epstein grabbed her buttocks and pulled her close to Null . said she was uncomfortable by the incident involving Jeff. At the conclusion of the massage, she was paid S200.00 for the massage. fa if she has any formal training in massages to which she replied no. I asked her it received any monies for taking her to perform the massage. stated had received money for taking her there but was unsure in the amount. I :c stated she returned to Epstein's house on another occasion with and another girl,. ''•a . II stated she waited in the kitchen with while- was taken upstairs by la stated she only did the massage once as she was uncomfortable with the whole experience. 'tie cell phone. A voice mail message on October 4, 2005 at 10:59 ant, revea ed a female voice At the conclusion of the interview, the tape was stepped. I was informed that .1had attempted to reach who identified herself as who requested : - to call her back reference the police questioning. M I provided the Incoming telephone number as a ' . stated she inadvertently told because M 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, about the police investilizt to utilize to visit family and visit Epstein. asked her what was going on at the house that the police would be asking ouestions.• stated'. then called Jeff and and asked what was going on reference the ongoing police investigation. According toll., has since then been trying to contact her to ask about the lice questions. I instructed I In not to contact and do not provide any mote information to . as she would notify Jeff Epstein and what was transpiring. On Ootober4, 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 statements 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 atten High School. The first time she went, drove to the house. They entered through the kite en area where she was The foregoing instrument was sworn to or affirmed before me this P day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Pirlin fficer .S.S. 117.10) State of Florida Coun of Palm Reath Signatur A r sti g Officer Date: 05/01/2006 Page &if 22 EFTA00232577 Al2 Probable Cause Affidavit Palm Beach Police Department Agency ORM PLO 500600 introduced to p and Epstein. She was taken upstairs to a bedroom by ho set the room up with a massage bed nought 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 Epstein 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 you do the more you get paid. . advised that several weeks later she agreed to be taken a second time WM Once they arrived at the residence, sat in the kitchen arldiptook her upstairs to the master bedroom again. =set the room up with a massage bed and brow ou 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. Mil was wearing tight jeans and bad 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. 0discontinued 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 thine that her friend, .__. ≥ was also at the house and had a problem with Epstein. fl I later researched .., dob and met with her at her residence. During a sworn ', statement, T ' • stated the following. on or about November 2004, she was approached at 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. IIM picked her up and drove her to a house in PaIMBeach. She was brought into the kitchen area of the housnhe further stated that fellow High School students. and .) came with them. They Nverc 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 ber 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 Pet Joe Reearey, who is personally known tome. Signature of Alt Police Office (F.S.S. 117.10) Date: 05/0 /2006 State of Florida County of Palm Be h Signatur> A f g Officer Pagel of 22 EFTA00232578 A13 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 . table, straddling Epstein to massage his back. While doing this her buttocks were touching Epsteins. ' was instructed to return to the ground at which time Epstein turned to have his chest rubbed. " I 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 the was.uncomfortable. Epstein removed a large white vibrator which was next to the massage table and turned it on. L..: 2... stated Epstein began rubbing the vibrator over her thong underwear on her vaginal area. 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, L.. was paid either 5350.00 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 Davison and I met with Ebb-, 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. Mrs, advised she wanted. to cooperate and consented to the interview.. During a sworn taped statement, ted 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 at and knew the same people. had been previously told by her friends from 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 driveway. They entered the kitchen arca 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 nib 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 rubbed Epstein's chest 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 r day of May, .2006 by Det Joe R.ecarey, who is personally known to me. Signature of Police fficcr ..3.5. 117.10) 7- 71 State of Florida County of Palm Beach Signatur Officer Date: 05/01/2006 Pagcaof 22 EFTA00232579 A14 Probable Cause Affidavit Palm Beach Police Department Agency ORD FLO 500600 , attempted to reach up her tank top and touch her breasts. pulled back and Epstein stopped, however lie 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 explained she never provided another massage for Epstein. She did however, go to the house with and -.- ___ ,::.,, as they took another ftiend -s.. advised she was present when , : went to work for Epstein. She advised she rode ova and sat in the kitchen area with to wait for L'. " ' ... advised while they waited for L " the house chef prepared lunch for them as it wa almost lunchtime when they went. When 1...- ' was finished with the massage they left the area. I asked I. if ever told her what would be expected when she provided a massage.. stated yes, told her that a massage would be expecteA, possibly naked and possibly some touching involved.. has no formal training in providing massages. IN spoke about a third and last time she went to Epstein's house.JIM drove another girl,. (sixteen years of age) who is I. friend, to Epstein's house. a stated knew that . had made money massaging Epstein and wanted to make money herself. took them in the kitchen area of the house and introduced. to and speak upstairs to the main om. . advised she doesn't know what happened as did not speak ut what happened in the room received $100.00 front for going with her to Epstein's house and recommending. On October 6, 2005, at 1 I:45 am, I met with -: . :, dob a. at Lynn University 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 . , J. :... ' who told her she was interviewed, by detectives. During a sworn taped statement, . stated she knew that otvorked for Jeff Epstein in Palm Beach. advised she oninall , had been taken to the Epstein house by whom she met when they both attended . 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 bad 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 F' day of May, 2006 by Det Joe Recarey, who is personally known to me. f Signature of Poli e Office (F.S.S. 117.10) State of Florida County of Palm Beach Signatur ing Officer Date: 05/012006 Pagelof 22 EFTA00232580 A15 Probable Cause Affidavit Palm Beach Police Department Agency ORIN NW 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". ..Z stated Epstein would try to touch her more and on one occasion he at to use a massager/vibrator on her. drove to the house for the original massage. left er 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. .___ vised Epstein would ask her questions about herself. Epstein knew she was a soccer player and would be attending Lynn University. 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 Orlando, 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 grabbed her buttocks and caressed the buttocks cheeks. 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 use the vibrator 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. .1 . 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 Lynn University Gym field. I asked her if she ever took any one to the house. . explained she took C. a friend of hors who attended High School, who has relocated to Orlando 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, bet Dawson 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 ve c e was rented by Janusz Banasiack, later learned to be Epstein's houseman, and paid with Epstein's credit card. On September 11, 2005, w/10 dotEM 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 Joe Recarey, who is personally known to me. Signature of Poll e Officer ar.s.s. 11710) State of Florida — County of Palm Beach Signatur Officer Date: 05/01/2006 Pageleof 22 EFTA00232581 A16 Probable Cause Affidavit Palm Beach Police Department Agency ORB Flo Segisoo 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 Dawson and I met with. and obtained a sworn taped statement El 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 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 the stairs she observed several photographs of naked women along the walls and tables of the house. further explained that she was for hcr to nth on Epstein. IS exiled shc remembered the steam room area, which containcd two large brought into the bedroom, where prepared the room by setting up the massage table and provided the oils 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 robbing his legs, thighs and feet. advised he turned over onto his back. Epstein touched her breasts and began to masturbate. Epstein ejaculated which meant the m c was over. At the conclusion of the massage, was paid $200.00. They walked together downstairs where nd were waiting. stated . .. received an unknown amount of money to Epstein. Epstein instructed to leave her cellular telephone number so that he could contact her when he is in town. IS 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 a Epstein would toll onto his back and allow her to massage his chest area. stated Epstein would then began to masturbate himself and at the same time would insert his fingers in her vagina and masturbate her with his fingers.. explained Epstein would continue this process until he ejaculated. He would then utilize a vibrator/massager on her vagina until. climaxed. 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.. advised that thin escalated within the home as Epstein would instruct and pays to have intercourse with his female friend, explained the intercourse included using strap on dildos, large rubber penis' and other e ces t pstein had at his disposal. Epstein would watch them have intercourse and masturbate himself . Occasionally, Epstein would then join in The foregoing instrument was sworn to or afftmted before me this I" day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (FS& 1(7.10) State of Florida County of Palm Beach Signatu eIA Asti g Officer Date: 05/01/2006 Pageffof 22 EFTA00232582 All Probable Cause Affidavit Palm Beach Police Department Agency ORD/ FL A) 500500 during the female on female intercourse and provide oral sex to both. and This occurred during the time. was sixteen years of age. 1. advised 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 appointmen or 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 with his penis. El 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 photographed her naked and having sex and proudly display the photographs within the home. . stated d isit to Epstein's house in which she provided a massage to E stein, his female friend, Nada Marcinkova, was also present.. provided the massage in which and her would fondle each others breasts and kiss for Epstein to enjoy. Towards the end of this massage, pstein grabbed. end turned her over onto her stomach on the massage table and forcibly inserted his penis into her vagina.. stated Epstein began to pump his penis in her vagina .became upset over this. She said her head was being held against the table forcibly, as he continued to pump inside her. 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 Dawson 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. Sh astated - she was brought to the Epstein house in March of 2005. , a classmate at-High School, approached her and asked her if she wanted to "work". made the arrangements with a Epstein's assistant. , , who has no formal training in providing massages, stated she provided a massage, fully clothed for S200.00 . 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 tinted. The foregoing instrument was sworn to or affirmed before me this 1° day of MI 2006 by bet Joe Reearey, who is personally known to me. Signature of Poele liceiteer .S.S. 117.10) State of Florida Coun of-Palin t s eh Signature j sti g Officer Date: 05/01/2006 Page Oaf 22 EFTA00232583 A18 Probable Cause Affidavit Palm Beach Police Department . Agency OR/if M0'500600 On November 6, 2005, at approximately 3:30 pm, I met with 7.. ., doh 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 girl, 1_1.1_, ...:_, 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 "_' . 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." 7 __I advised she was topless and the panties she wore were the boy shorts lace panties. She and : t 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 area, - stated as she did this, Epstein, began masturbating. stated Epstein pulled down her boy short panties, and he produced a large white vibrator with a. largo head. She stated it was within his reach int drawer in his master bathroom. He rubbed the vibrator on her vaginal area. advised he never penetrated her vagina with the vibrator. He continued to rub her 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 for future contact. wovided her cellular telephone number. was asked if she was recent. paid $200.00 to for providing the massage. was told to leave her telephone number with contacted about this investigation by an one from the Epstein organization. She replied she was called but it was for work. She e 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 Sandman and I mct with , do During a sworn taped statement, _ . stated she met Jeffrey Epstein through en y were still The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Oct Joe Recarey, who is personally lai#vn to me. 4 Signature of Police fficer (F.S.S. 11.7.t0) State of Florida County of Palm Reach Signatu rag Officer Date: 05/01/2006 Page l.fo (22 EFTA00232584 A19.- • I Ar..,•• Probable Cause Affidavit Palm Beach Police Department Agency ORM PLO 500600 attending *gb School. would approach females who wished to work for Epstein. • state s e 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 approximately 4 or 5 times in the past year. She accompanied with -, 1,1. 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 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,. 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 E stem approximately two ago when she was first approached by a classmate at 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 nigh 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 Adrianna. brought her upstairs as she observed several photographs of naked females throughout the house. staled 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 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 large head. Epstein would nib the vibrator/massager on her vaginal area as he would masturbate. stated she had been to the house The foregoing instrument was sworn to or affirmed before me this r day of May, 2006 by Del Joe Recarey, who is personally known to me. Cry —</ete# Signature of Police Weer 0'.S.S. 11'7.10) State of Florida County of Palm Beath Signata /A r• h g Officer Date: 05/01(2006 Page/t/of 22 EFTA00232585 A20 I y Probable Cause Affidavit Palm Beach Police Department Agency ORM FLU 500600 numerous titnes. 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 High School. stated she received 5200.00 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,' stat had met Jeffrey Epstein approximately one year ago. She was approached by a subject known to her as. had as to make money providing massages to Epstein. had heard that several girls Born High School doing this and making money. She agreed and was taken to the house by had introduced her to:i and Epstein and brought 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 S200.00 by Epstein for bringing 7 ... 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 touching her on her buttocks and grabbed her closer to him as he masturbated. Epstein also grabbed her breasts and fondled her breasts 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 Epstein penetrated her vagina with his penis and began having intercourse with her until he reached the point of climax. Epstein removed his penis from her vagina 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 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 kiss and ondle each other around the breasts and buttocks as they provided a massage to Epstein. Epstein, watched and masturbated as this occurred. On other occasions, Epstein, introduced the large white vibrator/massager in the massage. Epstein stroked the vibrator/massager on vagina as she provided the massage. On November 14, 2005, Dct Sandman 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 rust visit she was brought by a fellow student from High School known to her The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det Joe Reearey, who Is personally known to me. („<____ A,0 Signature of Police (ricer ‘.S.S. 117.10) State of Florida County of Paint Beach Signatur Ar td g Officer Date: 05/01/2006 Page fgof 22 EFTA00232586 A21-- - Probable Cause Affidavit Palm Beach Police Department Ageocy ORIN FLO 500600 • as dated • brought her into the house and she was introduced to then brought her upstairs into a master bathroom, located within the bedroom. toted 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 p 0 for the massage. , • said each subsequent time she went to the house, she was notified by that Epstein was and would like her to "vvork". • stated she returned to the house and was again led upstairs by M. She provided the massage, clothed. . • was asked if she ever removed her clothing to provide a massage. stated it was not until the third time that she went that she removed her clothing. stated she usified 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 ha thong panties and continued rubbing Epstein. Epstein turned over onto his back and she rubbed his chest area stated she knew he was masturbating himself as she providing the massage. stated the 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 bar looldng 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 site 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 format 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, Det. Sandman and f met with dol 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 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 thltr day of May, 2006 by Det Joe Reearcy, who is personally known to me. Signature of Fob f Officer at.S.S. 117.10) State of Florida County of Palm Beath Date: 05/01/2006 Pagekof 22 EFTA00232587 A22 --- Probable Cause Affidavit Palm Beach Police Department Agency ORDI MO 510600 massagetopless. — ' made the arrangements with Epstein and his assistants and took IN tti thertouse. --- - 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 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 the massage, Epstein turned over onto his back and requested . , 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. rubbed Epstein's chest.. 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 so that the opening would allow him to expose himself. Mier 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 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 t2i.rovide 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. :_ L. 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 massaging his legs and back. As. finished With Epstein's back and legs. Epstein then hurled over onto his back.. started to rub his chest and he began masturbating. As rubbed his chest, Epstein leaned over and produced a massager/vibrator. He turned it on and began rubbing 1 . vagina and masturbating himself at the same limo.. stated she continued to rub his chest as this was occurring. She described the vibrator/massager as large grey with a large head. Epstein rubbed her vagina for approximately two to three minutes with the massager/vibrator. He then removed the vibrator from her vaginal area and concentrated on masturbating himself. stated Epstein climaxed onto the towel again and informed her that the massage was done. She received $200.00 for the massage. said she never got dressed and met with .._. _ ._ who was waiting in the kitchen area. returned to the house and had no Il i 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 School. The foregoing instrument was sworn to or affirmed before me this la day of May, 2006 by Det Joe Reearey, who is personally known to me. Signature of Polk / Office 44t (F.S.S. 117.10) State of Florida County of Palm Beach Signat ng Officer Date: 0 i 1/2006 Pagetpf 22 EFTA00232588 A23 Probable Cause Affidavit Palm Beach Police Department Meaty ORS 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 e e messages were, "I have girls for him" or "I have 2 girls for hint" These messages were t who signed the bottom of the messages. During the execution of the warrant, I located igh 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. Seieral 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 f:rom the camera positioned behind Epstein's desk. On December 13, 2005, Dot. Dawson and I met with. doh Suring a sworn taped statement II 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 so that. may The foregoing instrument was sworn to or affirmed before day of May, 2006 by Det Joe who is personally known to nie. 7- 1 (1 7 Signature of Police Officer (F.S.S. 117.10) State of Florida County of Palm Beach Signatur A 3'ng Officer Date: 05 i /2006 Pagel (22 EFTA00232589 A24 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 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 nib his chest and pinch his nipples. As she began to rub his chest, Epstein asked her questions about herself.. remembered telling him she attended===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 things. She continued rubbing his chest. Epstein reached up and unsnapped her bra from the front.. explained the bra she used had a front snapping device. Epstein rubbed her breasts and asked her if she like having her breasts rubbed. I said "no, I don't like that." Epstein then removed his towel and bid on the bed naked exposing his penis to He began touching his penis and masturbated as he touched her breasts.. 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 stroking her clitoris.. said, "He commented how hard my clit was." He then inserted two fingers in her vagina and was stroking her within her vagina She tried pulling back to pull out his fingers from within her vagina. Epstein removed his fingers from within her vagina and apologized for putting his fingers inside her. During this time, he kept his hand on her vaginal area and continued to nib her vagina.. stated ho rubbed hes 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. 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 over went to work for. Jeff and knew what happened to her was wrong. She further stated that she had never been contacted fix any additional work. On January 9, 2006, I located and interviewed another victim,. dob . was identified as a potential victimiwitness from information obtained during trash pulls from Epstein's residence. II stated she met Epstein when she 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 he able The foregoing instrument was sworn to or affirmed before me this I" day of May, 2006 by Oct Joe Recarey, who is personally known to me. Signature of Police Meer (F.S.S. 117.10) State of Florida County of Palm Beach Signatur ing Officer Bate: 05 1 12006 Pagcoof 22 EFTA00232590 A25 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 to model lingerie for a wealthy Palm Beecher. Ewa, taken to Epstein's house located on El BrilloWay. introduced. to Jeffrey Epstein. Epstein had his personal chef prepare dinner for • arid At the conclusion of dinner, and Epstein brought. upstairs into a master bedroom area. r 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. 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. 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 nipples.. stated that as she started rubbing his chest, Epstein began masturbating himself . Epstein touched her breasts and stroked her vagina with his fingers. Eastein continued to masturbate himself as he stroked her vagina. Epstein ejaculated on his towel and paid . $200.00 for the massage. Epstein told • that if she told anyone what happened at his house that bad things could happen. . an . d stated that several days later she received a telephone call from were brought home by Epstein's houseman and. a i t Epstein knew where she lived who c dinated 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 bis back. Epstein rubbed ber vagina with his fingers. Epstein began to masturbate himself with an upwards and downward motion on his penis. Epstein continued to touch her vagina 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/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 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 get comfortable. The females would then provide the massage naked as Epstein would either touch their vaginas with his fingers and/or utilize the massager/vibrator on The foregoing instrument was sworn to or affirmed before me this r day of May, 2006 by Det Joe Reearey, who is personally known to me. State of Florida County off im each Signatur g Officer Signature of Police Officer (F.S.S. 117.10) Date: 0 /2006 Pagwpf 22 EFTA00232591 JM.y..iySV A4: OS JU.I. JUL) t A26 tw" Probable Cause Affidavit Palm Beach Police Department Agency OM FLO 500600 their vaginal area. 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 be 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. Ilia 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 cat. 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 oun to be masseuses. He stated one time under Epstein's direction, he delivered a dozen roses to 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 nit this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Poli Office .S.S. 117.10) State of Florida Coun of Palm Beach Signatu ng Officer Date: 05/01/2006 Page21nf 22 EFTA00232592 A2'7 r lt.11 I HUG it)/ Probable Cause Affidavit Palm Beach Police Department Agency O1W 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 front 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 igh School I ltigh 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 I 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 and the victims. These records indicate the dates the calls were made arc consistent with the dates and times t cy victims/witnesses stated they were contacted. Specifically, The phone records showed called during the exact tianes and dates when victim advised the incident occurred, also coordinated the encounters with.. and r , during the time e the girls stated they warted. 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 was in Palm Beach. made to and the vi s were made in ays just prior to their ' 'ng the e stei Jeffrey Epstein, who at the time of either with his penis or digitally with. who at the time of the incident was fifty two fourteen year old minor. Therefore, as 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 counts of Principal in the I" degree Unlawful Sexual Activity with a Minor, in violatillillit tate Statute and arranged the bedroom for said minors, there is sufficient probable cause to charge with four 794.05(1) , a second degree felony and there is sufficient probable cause to charge her with Lcwd and Lascivious Molestation, in violation of Florida State Statute 800.04 (5), a second degree felony. ee idents was fifty one years of age, did have vaginal intercourse ._who were minors at the time this occurred, and of age, did use a vibrator on the external vaginal areal. a coordinated and aided in the recruitment of minors to The foregoing instrument was sworn to or affirmed before me this I" day of May, 2006 by Det Joe Recarey, who is personally known to me. 7 •7 arfr Signature of Polk Officer (F.S.S. 117.10) State of Florida County of Palm Beath Signat tang Officer Date: i /01/2006 Page2zot 22 EFTA00232593 A28 Palm Beach Sheriffs Office Booking Card for Jeffrey Epstein, dated July 23, 2006 kr, • Ore LOW AM.UL • 1....1•1 EPSTEIN, JEFFREY ALIAS NAMES: OVER SHAMES: 0 SOT*, July 23.2008 2;0244 AM ICARCERATION DATEmME 07/23/2008 1:58 PRISONER TYPE LOCAL CHARGES D013: AGE: 63 SSA: ADDRESS: 358 EL BRILLO WY wi WIM MONT: B R 0 In WEIGHT: 180 PALM BEACH SHERIFFS OFFICE BOOKING CARD BKILOC: MDC INTAKE MOM. Mg HNR COLOR GRY en DXON sw g JACKET" 0338617 71" 2006036744 CRY: PALM BEACH ID ft 20080723017 SIDS: ALIENS: FBI 8: POOCH: 1291 AFM U.S. MARSHAL t OBTS AP.REST ADDRESS:3228 GUN CLUB ROAD ARREST DATE 07/23/2006 BKG. DATE 07/23/2006 WARRANT/CASES: 06009454CFA99 W MIRESTOMPICER: CASTILLO TRANS. OFFICER SELF SURRENDER ?ME TYPE: FELONY TOTE STATUTE COUNnosSCASTOtt STATe FL DP: 3300 HMO • DOC t • INCIDENT If: an: WPB ARREST TIME 1:30 STATE FL DP: 33405 BKG. TUE: 1:56 CURRENT BOND $3,000.03 COURT DIVISiON: T - MARX, KRISTA ARREST AGENCY: 01- PESO TRANS AGENCY: CASE RAC: 796.07 COMMIT ENGAGE 3RD sumo OFF 0 CT1) FELONY SOU CITATION OF PROSTITUTION can 0 0 —ssAuED INDKIBENT"NO INFORMATION GIVEN " SEALED women- JUDGE Pam 401.08: NOUS DATE/TIME: HOLD BY: WILD DEPT.: HOID RENDATUIDAE: HOLD REM. BY: POW REM DEPT: ALERTOESCRIPTIOR AL M NOARA111/61 NER 3 ALERTS: El KEEP SEPARATE FROM: NONE VER 6 HALOES: O SSIGNED HOUSING: CIC INTAKE: NCIC RELEASE: MIAS PHOTOS,: ED. CLEAR RELEASE MOVE: ?SASE DATE/TIME: RELEASE INFORMATION: M$T DATSJT1M8: COURT LOCATION NIA DATE/TINE: F.P. ENTERED.. NIA LOG: F.P. Urn CLASSIFICATION: M!O.CLEAR et CLERK O WARRANTS CI erne Any lj CENTRAL RCOS n GLASS EFTA00232594 A29 2006 Grand Jury Indictment of Felony Solicitation of Prostitution - Jeffrey E. Epstein [pp. A29-A301 vie V/. IV; tn JV1 OJJ ft144 I 4-1-1-1. 4 I PI JL. V • • tau 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)(1) 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 State EFTA00232595 A30 GRAND JURY FOREPERSON DATE Jeffrey E. Epstein, Race: White, Sex: Male, DOB: Issue Warrant EFTA00232596 A31 Information for Procuring Person under 18 for Prostitution - Jeffrey E. Epstein, dated June 26, 2008 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIM CIRCUIT • IN AND FOR PALM BEACH COUNTY, STATE OF FLORIDA CRIMINAL DIVISION "W" (LB) OWCF 9 3k / STATE OF FLORIDA MUSES FROM BOOKING NO.: 2006036744 vs. JEFFREY E EPSTEIN,\V/M,=, INFORMATION FOR: I) PROCURING PERSON UNDER 18 FOR PROSTITUION Ws > 7J ;0 070 •n rri= -=>.= nSCE) ' An n '7o n In the Name and by Authority of the State of Florida: :4; ce, a BARRY E. KRISCHER, State Attorney for the Fifteenth Judicial Circuit, Palm Beach caityMorida, by and through his undersigned Assistant State Attorney, charges that JEFFREY E EPSTEIN on or about or between thc I' day of August in the year of our Lord Two Thousand and Four and October 9, 2005, did kthowingly and unlawfully procure for prostitution, or caused to be prostituted, a person under the age of 18 years, contrary to Florida Statute 796.03. (2 DEG FEL) • ZeSt FL. BAR NO. Assistant State Attorney STATE OP 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 as true, and which, if true, would constitute the offense therein charged, that this prosecution is instituted in good faith, and certifies that testimony under oath has been received from the material witness or witne s for the off Assistant State Attorney Sworn to and subscribed to before me thia(ICC-day of June, 2008. LB/dp Dotork are tatccastancett t0510191 WAS Avauu Z 7010 10011ADDCWIWANIMULUCL IC NOTARY PUBLIC. ofFlori FCIC REFERENCE NUMBERS: I) FELONY SOLICITATION OF PROSTITUTION 3699 CAA UN 9 R 'inn" EFTA00232597 A32 Guilty Plea for Felony Solicitation of Prostitution and Procuring Person under 18 for Prostitution - Jeffrey E. Epstein, dated June 30, 2008 1 PLEA IN THE CIRCUIT COURT THE FOLLOWING IS TO REFLECT ALL TERMS OF THE NEGOTIATED SETTLEMENT Name: Jeffrey E. Epstein On: Guilty X call NO. fatertle Count Lesser DeflIV OSCF0094,54AMB Felony Solicitation of Prostitution 1 No 3 Fil • GlICFOlr381AM8 Procuring Person Under 18 for Prostitution 1 No 2 FF.t. PSI: Waked/Not Required _X Required:Requested 41Iaqattlf4: Adjudicate (x 5EN TENCE: Oil 08CF009454A.M8, the Defendant Ls sentenced to 12 months In the Palm Bench County Detention Fac-Fity, with credit for 1 (one) day time servedd. On 05CF0U9SSIAMS, the Defendant is sentenced to 8 monthein the Palm Beach County Detenden Faclay, with siert for 1 (one) day the served. This 6 month sentence Is to be served torracutIve to the 12 month sentence in MCP:109450MB. Following thi4.1 month sentence, the Defendant will be placed on 12 months Community Control 1 (one). The conditions of community control are attached hereto and Mcceporated hewn. OTtigl3SIORNENTS CR CONDITIONS: Asa special condition of his commonly control, the Defendant Is to have no imstporvised contact With minors, and the supervbing *tut must be approved try ate Depanmera of Correcti0ns. The Defendant is designated as a Sexual Mender pursuant to Florida Statute 943.0435 and must abide by al the corresponding recitilrements of the statute, a copy of which Is attached hereto and incorporated herein. The Defendant mast provide a DNA sample In court et the time of (oil/ tka4( D2b1 ofFe l6g 1 EFTA00232598 A33 Judgment for Procuring Person under 18 for Prostitution, dated June 30, 2008 04/26/2010 14:51 3553526 CIRCUIT CRIMINAL PAGE 06/ 20 ("IIE RIMINAI. 0 IVISION OF THE CIRCUIT COURT OP Tile FIFTEENTII JUDICIAL CIRCUIT OF FLORIDA. IN AND FOR PA IN REACII COUNTY CASE NO. 08TS STATE OF FLORIDA i E11$4cn EFENDANT DA RACE GENUER Il DIV. COMMUNITY CONTROL YIOLATOR PROKATION VIOIATOR aft CPM 20080267252 OR BK 22760 PG 0565 RECORDED OT /17/241Ø0 IN:06:42 Pitla 8~0 County, Florida Sliaron R. Back, CLERK 8 COMPTROLLER Pg 0565; ligg) CIAL SECUR/TY NUMSER JUDGMENT The abova Defendent bain); penonaily klore Dis Court repaenitd by 5 . 11 V r I I Ur. ing beta Ined and bond gaihy of .1 the foll oudinft. crime(41. ryt_ Horing enicred a pk or guilly to Ille follenting nime(s): ( J Haylni enka° a plen of nolo romendere to the Fellow/n% crinte(s): 'tome GODT« IM6 I en in, /ALV OFFWISE STATUTS mimet-Rfs) VEGRER >t I 1 and no eanse having /wen shnwn why the Defandant 'hauld nnt stkud;cated wity. IT IS ORDER ED TIIAT tbc Dciondtint is benby ADJUDICATED CUILTY «the alsove almer* . and having beta enniicted ot fond gulby ett or håving ente red a pica ti nolo ennierekre nr guilly.regardkes nf adjudiestion to anerripts offentes reising to starol bantry reb. 790. kwd and Iaseivinus eonduet kb. 300/ or munkTis. 782-IML affillnled 1121ICrY (*. 784° 45). bUr!larY (‘. 3I0.02‘. enjitkint (s. 8 I 2.101. or home invasion robber:. (s. 6 I3.13SI. or any Adler tiRcaisc specIlled InSectIon 94;.315. the defendwo stoll he rcquired lo ruhmli blad apeeimens. • • r!. I and good tain beine slunt: IT IS ORDERED THAT AEN LIDICATION OF (RULT DE WITHNEL% lo Cl g:1i%, yun ••• SENTENCE I I The Court herchyinvs and whhhads IMPOSitiOn of gnellet as to <onnen and gisent ilte Defendani ni • STAYED I I Prokation ondt'', I I Communitv Control under dit supervision of tbc Dept. of Correciione(onadinons of probation sel Innb In genar= orden. SENTENCE DEFERRED I I Tbc Court limt? *kn 'innsida, el sauen« urril The Oeferakat in Open Cniin was advised of bis vigil lø aPrCZI korn the Judgment hy nling noko nf appeal %am, the Clak cf (\mc o. /tilta %hin) &ty!, fnRowing the date seneciocc ;s imposed or peoh3tion is notlered otntuant to thi adjudictuittn The ckcendant omnsalen Mvised of bis right to tbc :os km« of ntunsel In i3king flid appeal :n the espense of the Siste opna shnu.ing ni int/igency. NE AND ORDrti D inDrift Cm 't Palen, Or County. Florida. ,his 3 D Jay nrilli).(- . 200 e.3 CIRCIIIT COURT RIODF. i JUL Of (PIR EFTA00232599 A34 Sentence for Procuring Person under 18 for Prostitution - Jeffrey E. Epstein, dated June 30, 2008 04/26/2010 14:51 3553626 CIRCUIT CRIMINAL PAGE 07/20 IN THE cmclir COURT OF THE FIFTEENTH JUIIIAL CIRCUIT. IN AND FOR PALM BEACH COUNTY, FLORIDA SENTENCE (As to Count(s) Defendant Aey Ep 4U-) Case NumbeOner 93 gury OBI'S Number The Defendant. being personally before this Court, accompanied by the defendant's attorney of record, szc ipotiThopoec , 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 jp epartment of Corrections (4 Sheriff of Palm Beach County, Florida Dcpanment of Corrections as a youthful offender for a term of (//7/.61-5 . 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. Iris further ordered that the composite term of all sentences imposed for the counts specified in the order *all run . rA consecutive to ( J concurrent with (check one) the following: J Any active sentence being served. JUN 3 y Specific sentences: clay;er 3(.700c0( In the event the above sentence is to the Department of Corrections. the Sheriff of Palm Bcach 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 §947.16(4), Florida Statutes. the Court retains jurisdiction over the Defendant. 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 pnvi lege to drive. The Clerk of the Court is Ordered to report the conviction and revocation to the Department of Highway Safety and Motor Vehicles. the defendant in Open Court was advised of the right to appeal from this Sentence by filing notice of appeal within .hiny 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. DONE AND ORDERED in Open Court at West Palm Beach. Palm 0 B • +County. rids this -111'kE_ , 20e. ci y Form Circuit 5 (rev 812000) n CIRCUIT COURT JUDGE. ';;1: EFTA00232600 A35 Community Control Standard Conditions, dated June 30, 2008 A35-A461 04/26/2610 14:51 3553626 CIRCUIT CRIMINAL rAGE_ 09/20 Ingram On-liffEED THAT yop SNAIL COMPLY vvrrn THE FOLLOWENGANDITIONSOF SUPERVES701%. . 1 TviMUNITY CONTROL .4.413ARD CONDITIONS: i r You will remain confined to year residence except one halt bow before and afteryour approved employment, . community service work, or any other activities approval by your probation officer. You will maintain an Isourly accounting of all your activities on a daily log which you wilt submit to your supervising officer upon request. . The Derianment of Corrections, may at its discretion, places yon oaelectrooic Monitoring during the tam of your Community Control. If plecalon Electronic Monitoring. you will weer a monitor at all times. You will maintain a private phone tine, be financially responsible.for any lost or damaged equipment and follow all rules and regulations as instructed. The telephone will be available within five working days of being placed on Electronic Monitoring Program. . While ou electronic monitoriog you will remain. confined to your residence and are probibited from being outside the residential walls. • • .. (d) 71 while being monitored and the monitor is found to have been tampered with you shall be taken into custody inenedi rely, if the officer determines that your were am at your schedules place of walk or school while allowed to be outside doe residence then in that event you that% be taken info malady immediately. If taken into custody, you shill be held without bond and then, on the next working day. brought before kludge preiitfiug over his or her care for further ~itaositon (c) (e) If placed on Electronic Monitoring you will pay to the State of Florida, (or the cost of Electronic Monitoring $1.00 per n..19) day, perP.S.948.09, a -9 Derg.nd..Ceitt (Ault (;f- rgeCi CI I 4- :S I ed. 31t F•''S •re=4; 11 Way, riel; dot_ 33 et CONDITIONS (a) You will submit to need, unless otherwise waived, be financially responsible foe thug testing. urbMlysis at least oo a monthly basis, end counseling if darned appeoptitte by your supervising officer. (b) You wilt eater and successfully complete a eon-scene or inpatient drug treatment program if deemed kpproptiate by your officer. (c) You will comply with my curfew restficiione, confinement approved residence or travel astrietioni as instructed by your officer and appeared by the Officer's Supervisor. • .ssixemmeusweiPeeptieterterrs, • fti . you shall submit to a mandatory curfew from MOO PM to 6:00 AM (if the victim wes•under die age of !Blears) you shall not live within 1000 feet of a school, day care centet,park, playground. or other place where children regularly Congregate. (c) you shall aria. actively participate in. and successfully complete &sexoffender treatment program with a therapist particularly trained to neat sex offender. at probationer's or conmwoiry controlces espenso. . ou shall nothann any contact with the vialhatclittaly or indirectly, including through a third person. unless approVed by the victim, the therapist and sentencing court . . (if the victim vas under the ego of le years) you shall not, mail you soceenfully attend and complete the sex offender program, have any unsupervised contact with e child nada the age of I B years, unless authorized by the sentencing court, without an adult present who is respoosible for the child's welfare and which adult hes been advised of the crime • and is approved by the ;cadencing court the victim was under the age of 13 years) you shall oat wait for payer ass voluoteer In any school, day cire center. k playground, or other place where children regularly congregate. lR lademodtaradre.Mditaiatintheprannetssidaevprewieled-by.the.scmseledteedetsearenearprograuL you shall out view, or paws soy obscene, pornogrephic or sexually stimulating *leveler auditory material, including telephone. electronic media, computer programs or Compiler settees that ere relevaer to your deviant behavior paha°. %:)•ot)trashall submit two specimens of blOod to the Floridateptutment of Law Enforcement to be registered with the DNA Dad ' (1) You shall Make restitution to the victim as ordered by this court Formant to P.S. 775.039 for all necessary medical and related professional services misting teethe physical. psychiatric and psychological cite of the victim. You shall submit to a werractleas search by your probation officer or oanansoity control officer pzet t:1; r. residence, or vekele. • CO•nfis 6) . Odadf l t1-4- 413 kg)-c- t44- L s i t apaSketvc A ct, rYLiA.; nit•I iNe't OYU- • • sAre-cdr-- • .33 p flit14 Sejoi of, Fri wild A* 61- ) Sri All.cfrnA; ail i 1 A Ft • EFTA00232601 A36 .4 84/26/2010 14:51 3553626 CIRCUIT CRIMINAL. PAGE 10/23 you shall submit to ar mandatory curfew from 10:00 PM to 6:00 AM (if the victim was under dr. age of 18 years) you dull not live within 1090 fret of a reboot, day care center. park. playground, or other place where children regularly ecnagteitte. you shall enter, actively participate in, and successfully complete a sex offender nutmeat program with a therapist particularly trained to treat set Offender. at probationer's or community eontralme expttite. you shall not have any contact with the victim, directly or indirectly. including through a third person. Wilma approved by the victim. the therapist and sentencing court. (if the victim was under the age of 18 years) you shall not, until you successfully attcod and complete the ter offender program, have any unsupervised contact with a child tinder the age of 18 yeari, unless authorized by the sentencing court, without an adult present who is tesponsible for the child's welfare and which adult has been advised of the-crime • and is approved by the sentencing court. (l1 the victim was under the age of 18 years). yen; &all not work for pay or as a volunteer in any school, day care center. pazk playgroluad, or other place where children regularly congregate. (g) Unless otherwise indicated in the treatment plan provided by the sexual offender treatment program, you shall not view. own, or posses any obscene. pornographic or sexually stimulating visual or auditory material, including telephone. electronic media. co:miter programs or computer services that are relevant to your deviant behavior patient You shall submit two specimens of blood Data Bank. (O You shall make restitution tothe victim as ordered by this court pursuant to F.S. 775.089 for all necessary medical and related professional-sr:trines relating to the physical, psychiatric and psychological•care of the victim. 6) You shall submit to a Warrantless search by your probation officer or tormactilty control officer of your person. residence or vehicle ocy- you shall, as pan of a treatment program. piuttapate once/twice annually in polygraph examination to obtain information necessary for risk management and treatment and to reduce your denial mechanisms: Your polygraph examinations must be conducted by a polygraph= trained specifically in the use of polygraphfor monitoring sex offendersand n shall be paid by you. The results of the polygraph examinations shall not be wed as evidenced in court to prove that a violstinc of community supervision occurryd. You MO maintain a driving log, you shall, not drive arnotor vehicle wide alone without prior approval of your supervising officer. . . lik!, (if there was seimal contact) you shell submit to. at probationes or. community controlees expense.. tin Fin, 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. rc3 YoU.will submit to electronic monitoring when deemed necossary by the community control or probation officer and has or her supervisor, and ordered by the court at the recomniendaKon of the Department of Corrections.' • bet . fe coma R2s1311VES THE RIGHT TO RESCIND, MODIFY, OR RHVORE S West Palm Perk Palm Beach County, Florida, this. one Pro Tuck' (Ts?NTTPROVID£D BY LAW • Honorable Sandra K. Mt:Sorter JdrIdge;Cirtuie Court have received a copy of the term and conditions of my ruptsuidon. I have read and understand these coedit art e- agree to report to the Department of cotenant pro bation Office for further instructions. Alto. I hereby consent to the disclosure of my alcohol and drug abuse patient reeds. the tonfidertnality which is fissfrnoly remitted under 42CPR. Part IT. for the duration of my fupervirien EFTA00232602 A37 04/26/2010 14:51 3553626 CIRCUIT CRIMINAL tAri 948.101 Tenn and tIM1d1 lkfil of community control and criminal quarantine Comm unity control. - if I Tho court shell netia-mino the tones and conditions of community control. Condition: tpoefiad in this set:not-than do not require oritt pronouncement at tho time of sontcrecIng and may no cortsfilond standard conditions of community control￾la) Tho court shall require Into/who super-vision and survoillanco for an offender plead loin community ociatvot, which may include but is rot Ihnitod Us: 1. Specified contact with the parole and probation office, 2. Confinement to an agroccrupon rod/loran rinsing hours away from employment rind publk 'Sulte artivitre 3. Mandatory puhlk tenelco. 4. Stawnision by Ow Dopartomet of Corte-tied by moans of an oinctronic Ironton-Mg dovico system. 5. The standard conditiorn of probation set forth hi s. 948.03. (b) re an offender plead on criminal oiteonntirmi community control, the court shell rapol. u. I. eloctronic mildewing 24 hose per day. 2. Confinement to a designated rosidanco during designated tours. (7) The onemorstion of specific kinds of tams end coratiom doe not provont the coin from ridding deacre arty other teem at conditions that the cowl considon propr. Movanor, the sentencing court nay ordy Impose, a condition of supervision allowing an offonde convicted of 7g4.011 I. 800.04 1. 827.071, or 1. 847.0145 to rydde in anefor state if the ordor snostratas that It is contineant upon the approval of the rote-vine earn intestate compact authority. P.O rotrt may reeind e modify at arty time the terms and rondifirlin theretrifoio Imposed by ft upon the offondor in community rant:rut lioinsair, If the tovt withholds ritiludicadon of guilt or imposes a period of interrogation in e condition of community control, the period may not exceed 364 days, and incwesration awn be restricted to a county facility, a probation and redItutlen cants telex the Juriaticticis of the Oopartmont of Corractiorn, e probation proporm drue punishment phase, I series roddiantirel treatment institution, or a temmtnity residential facility owned or omelet by any artily providing such services. (3) lb« .t may pinto a defendant who is being santoricel for criminal transmission of tirsi in violation of 775.0877 on criminal quarantine community control The Dopartmont of Corrections shall doneop end admIrdite a criminal quarantine cortmenity control program omphadzing infantrya supervision with 74-1sour-por-dey electronic monitoring. Crime& quarantine cornmtrAty retityr1 stitin must include surnallattnes end may include ether (unsure& normally associated with community control, sercopt that specific conditiorn necessary to monitor this population may be ordained. NW￾EFTA00232603 A38 04/26/2010 14:51 3553626 CIRCUIT CRIMINAL PAGE 12/20 • '943.0411 smoke offenders required to register with the deportment; penalty... (1) as used in this saction, IM tans: fail. 'Sexual offenders moans a person who meats the cattail, in sub-subparagraph a., sob• subparagraph b., sub-orbparaipaph c., or sub-subparagraph d., as follows: a.(1) Has been convicted of committing, or attempting, soliciting, a conspiring to commit, any of the criminal offerers proscrlbod in the following Statutes In this state or similar aflame, in another jurisdiction: s. 727.01, s. 787.02 or s. 7A? 025(2)(0, whore the victim is a minor and the defandant is not thewthns parent or guardian; s. 794.011 excluding t 794.011(10); s. 794.05; s. 796.03; s. 799.035' s. 600.01; s. 825.1025; s. 837.071; s. 847.01.1_3; s. 847.01,15 sixoluding s. 847.0115(44 s. 047.0137. s. 147.0138; s. 647.0,45- or s. 985.701 it I; or any sterna, aflame committed In this slate which has boon rodosignatod from a format sumo numbor to one of those listed in this sub-suboubparagraph; and (II) Has boon retained on or after October 1, 1997, from the sanction Imposed for any ciandcnon of en of few described in subouboubparegraph (1). Fa purposes of sub-sub￾subparagraph pi, a sanction imposed In this state or In any odor jurisdiction includes, but Is not limited to, a Are, probation, community control, peseta, conditional release, control release, or incarcoration In a state prison, federal prison, private correctional facility, or ince detention facility; b. establithas or maintains a residence in this state and who has not been designated as a awed predator by action or tads state but who has been designatad as a sextant predator, as ;oseualiy violent predator, or by another sexual offender dosignatiOn in another state or hefuliction and was, asa result of such designetion, subjected to togistration or cammunity or pub& notiffcetfort, or both, or would be if the person wore a nrsidant of that state or jurisdiction, without regard to whether the person °Me wls. most the triton for registration AS a sexual offender; c. Establishes or maintains a residence In this state who Is In des custody or control of, or under the lupines/on of, any other state or jurisdlcdon as a result of a conviction for committing, or attempting, sak's'', or corrspiring to commit, any of the criminal offenses proscribed in the following statutes or similar °Horne In another jtrisclIctlen: s. 787.01, s. 787.0‘ or s. 767.025(2)(c), whore the victim Kamen and the defendant is not ctim's parent or guarding s. 794.011 including s. 794.011(10); s. 794.05* s. 796.03; s. 796.035; s. 800.04; s. 935.1025- s. 827.071• s. 847.0133- s. 847.0135, excluding s. 347.0135.(41; s. S47.0137; s. 847.0738• s. S47.0145. or s. A85.701(11; or any similar offame committed In this state which has boon nidesIgnersed from a former statute numbor to ono of those listed In this sulr-subparagreph; or d. On or attar July 1, 2007, has bean adjudicated delinquent for commit:tint or attempting, soliciting, or r.onspfring to commit, any of the criminal aflame% proscribed in the following statutes in this state or similar offenses in anode jurisdiction whin tie Juvenile was if year' of eee or older at the time of to oftunsa: i0 Section 794.011, excluding s. 794.011(104 fli) Section 800.01.14)(h) Whore the victim is under 12 mars of ago or whore the court finds sated activity by the use of force or coercion; MO Suction SOD.04(5)(c)I. whin the court finds molestation involving unclothed gonita • EFTA00232604 A39 04/26/2010 14:51 3553626 CIRCUIT CRIMINAL PAGE 13/20 (IV) Salton 800.04(5)(d) when the coot finds the use of force or cordon and unclothed gaskets. 2. For ell qualifying ottoman listed in on-subparagraph (1)(a )1 ..d., the court shall make a writtem finding of the aye of the offender at rte Moe of the offense. for each violation of a qualifying efforts* listed in this subsection, the court shell make a writton finding of the age of the victim at the firm of the offense. For a violation of s. 800.04(4), the court shell additionally make a written finding fridicatieg that the offense did or did not involver seal activity and indicating that the offense did or did not In due force or coercion. fora violation of s. 803.04(9, the court shall additionally make a written finding that the offeme did or did not !melee unclothed gonitals or genital are and that the offense did or did not involve the ine of force or coercion. (b) tonvictar moons that the has been a determination of guilt at a result of a trial or the entry of • plea of guilty or nolo contender*, regardless of whether adjudication is withhold, and imiudes as adludication of delinquency of a juvartito as specified in this section. COMiction of a shrifts.offered. includes, but Is not lkolted to, a conviction by o federal a military trIbunid, Including courtemsartlal conductod by the Armed Forces of the United States, and includes a conviction or antry aleph). of guilty or note Contendere restating Ina sanction in any seats of the United States or other jurisdiction. A sanction inctudes, but is not limited to, a line, probation, ammurity contra, parole, conditional release, control release, or Incarcerationin a stata prison, federal prison, private correctional facility, or local detention facility. (c) 'Permanent residence and "tampons, rosidence few the same meaning ascribed Ins. 775.21. (d) "Institution of higher education" men a censor cantor, community college, college, stain university, or indepormised postsecondary institution. (o) 'Chang* in stnnellmont or ompienensatt status' moans the commencement or termination of seertalment or omptannent or a change in location of enrollment or employment. -Electronic mail address- has the ramie moaning es provided In s. 668.602. (g) 'instant message name means an Identifier that allows a person la communicate in real dine with another pan using the internat. (2) A sexual offender shall: (a) Report in person at the sheriff's office: . in tho county in which the offender establishes or maintains a permanent of temporary roe/darn within M tan after: a. establishing permanent or temporary reside co in this state; or b. Nem released from the custody, control, or supervision of the Orman:morn of Corrections or from the custody of a privets correctional facility; or 2. In the county where ho a she was convicted within 48 hours after being convicted for e qualifying offense far registration under this suction if the, offender Is not In the custody or EFTA00232605 A40 04/26/2910 14:51 3553626 S CIRCUIT CRIMINAL PAGE 14/20 control of, or under the ;upon/hien of, the nopartment of Corrections, or IS not In the custody of a poi vats correcdorui facility. any change In the sexual offender's permanent or temporary residence, name, any electronic mail address and any instant message name required to be provider, pursuant to paragraph (4)(d), site the usual offender reports In person at the datriffs office, shall ho accomplished in the manner provided In subsections (II, (7), and Ps) Provtde Ms or to name, data of birth, social security number, race, sex, height, weight, hair and cryo color, tattoos or other identifying marks, occupation and place of employment, address of pormanaot or local residence or address of any current temporary rosidente, within the state and nut of state, including a rural route address and a post office box, any electronic mail address and any Instant menage none required to be provided pursuant to paragraph date and place of each conviction, and a brief description of the crime or crimes committed by the °thunder. A post office box shill not be provided In lieu of a physical raddontial address 1. If the sexual offender's place of residence Is a motor vehicle, trailer, mobile home, or manufactured home, as chinned In chapter 320, the sexual offender shall also provide to the department through the sheriffs office written notice of the vehicle identification number; tho licence tag number; the registration number; and a description, Including color schema, of the motor whirls, trailer, mobilo home, at manufactured home. If the sexual offender's attire of rash:lance is a vassal, Ileadeboard cal, or houseboat, as defined In chapter 127, the sexual offender shall also provide to the department written notice of the hull Identification numbor; the manufachron serial number; tha name of tho seal Ilve-aboed wsrati, or houseboat; the ragistrarion number; and a description, Inducting color scheme, of the nee, Ile -aboard vessel, or hosnebeat. 2. It the eau& offercke Is enrolled, employed, or carrying on a vocation at an institution of higher edticatlen In this state, the 'flue/ ofteMICit shell also provide to the department through the sheriff's ofRro the name, address, and county of each institution, including each campus attended, and the canal offender's onroilmont or ompltrymaint status. Each change in onrcAlirtont or employment stabs shall bo rover-tad in parson et the sheriffs office, within 48 hours after any change in statsn. The sheriff inn promptly notify each Institution of tie sexual offenders presence and any change In the sexual offender's anrolirnent or ornployrnest status. When :eased offender reports at the sheriffs office, the sheriff shall take a photograph and a sat of fingerprints of too at/enter end forward the photographs end flnyerprints to the department, along 1.4th the Information provided by the moat offender. The sheriff shall promptly provide to the department the Information received from the sexual offender. (31 Within se hours allbar the report require* under subsection (2), a unuat offonckw shall report in parson et a Muir% Urania office of the Department of Highway Safety and Motor Vehicles, union a driver's license or identification card that complies with the requirements of s. 322.141(3) wets previously Secured or Updated undies. 544.607. At the driver's license office the tamed offender *MIL In) If otherwise qualified, secure a Florida driver\ license, renew a Florida driver's license, or :et ure an IdardiRcadon cord. nos sound offender shall fdautify himself or herself as a sexual offender who Is required to compty with this faction and shall provide proof that the sexual offender reported es roeufrod in subsection r21. The sexual offender shell provides tun of tho inFortne6on specified in subsection (21, If requested. The sexual offender shall submit to tho taking of a photograph fur Ma In Issuing a drivels license, renewed license, or Identification card, and for use by the department In maintaining current records of sexual of fonder.. i EFTA00232606 A41 04/26/2010 14:51 3553626 CIRCUIT CRIMINAL • do) Pay the costs assessed by the Department of ktighway 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 mud be in compliance with s. 122.141(3). lc) Provide, upon request, any additional information necessary to confirm the identity of the sanest offender, including a sot of fingerprints. (4)41 Each time a slued offender% driver % license or itionelficatton card is subject to renewal, and, without regard to the status of the offender's driver's license or identification card, within 40 hours after any change in the offender'[ permanent or temporary residence or change In the °insider's name by reason of marriage or other legal process, the offender shalt report in parson to a ddwr's license office, and shalt be subject to the requirements specified in subsection (3), The Department of f tighwuy Safety and Motor Vehicles shall forward to the department all ph otograpin and Information prodded by sons( offender[. Notwithstanding dm restrictions sat forth In s. 322.142, the Department of Highway Safety and miter vehicles is authodred ha rideasa a rcprodurtion of a color-photegorph or digital-Imago if GYM .10 tin Department of Law Enforcement for purposes of pubik notification of sexual offenders as provided In this section and n. 943.043 and 944.406. Ib) Asexual offends who vacates a permanent residence and fails to establish or maintain ansther parmarent a temporary residence shall, within 41 hours after vacating the permanent residence, report in parson to the sheriffs atilt-earths county in which ha or she Is located. The sexual offender shall specify the date upon which he a she intends to or did vacate such reslOonco. The mutual offender mud provide or update all of the rogratration information raglan:el lads paragraph (2)04. The sexual offender must provide en address for the residence or other loci:boo that he er she is or will be occupying during the time in which he or she tails to ertablfsh or maintain a permanent or tompotary residence. (c) A sexual affords who remains at a permanent orsidanm attar reporting his or her intent as tat. such residence shall, within 42 tours after the data upon which the offends Indic-mad he or she would or did vacate such residence, report In person to the mercy to which to of she reported pursuant to paragraph (b) for the purpose of reporting his or her address at such Tosidance. When the sheriff recarbern the roman., ihri sheriff dwell PremptlY convoy fie 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 (Sony of the second delarao, swarishablo is provided In s. 775.112, s. 775.003, or s- 775.014. (dl A sexual offends- mud register any electronic mail address or Instant message name ii.ah the thipartrnent prior to using such electronic mail address or Instant message name on crofts October 1, 2007. The department shall establish en online system through which sexual offerviers may securely rectos and update all electronic mail address and instant message name information. IS) nit metion does not apply to a meat offender who is also a sexual predator, as defined in s. 775.21. A usual predator mint refute as required enders. 775.21. I6] County and Meal ins enforcement spondee, in conjunction with the department, shall verify tie address% of sexual offenders who are not under the care, custody, control, or suporvidon of the Department of Corrections In a manner that is consistent with the provisions of the federal Mom Walsh Odd Protection and Safety Act of NM and any other federal -ireatorrts applicable to such verification or required to be mot as a condition for the receipt of federal funds by the state. Local law enforcement agendas shall report to the department nary tenure by a sexual offends to comply with registration requirements. PAS= 1F/2;3 EFTA00232607 A42 04/26/2010 14 :51 3553626 • CIRCUIT CRIMINAL PAGE 16/20 (7) Asexual offends: who intends to establish radiants In another stadia or jurisdiction other then the State of Florida shrill report in parson to dr. sheriff of the county of currant residence within 48 hours before the data he or tho intent to leave this state to establish rot-Wiens in another state or jurisdiction. The notification must includo the address, municipality, county. and state of intended recidance. The sheriff shall promptly provide to the dopartrnont the Information received from the sexual offender. The daparussont shall notify tho statewide (are onfewrement agency, re a rnmparahlo agency, in the intended state ref junsdiction of rosidonce of the vaunt °fitted:ors Intended residence. The felons of a sexual offiandar to provide his or her Intended place of residence is punishable as provided In artnaction (9). (S) A sexual offender who Indicates his or har intent to reside in another state or jurisdiction other than the state of Florida and later decides to remain In this state thallf within 417 hours after the date upon which the sexual of erder Indicated he of she would lame this state, roport in parson to the sheriff to which tie sanest offender reported the intended charge of remit:erica, and report his or ter Intent to remain In this state. The sheriff shall promptly report [hie irtionnatlion to the department_ A casual offender whe reports hit or her intent to reside in another state or jurisdiction but who remehrs in this state without reporting to sheriff In the manner required by this sot-section, commits a fotorry of the second degree, punishable as proeickni in s 7751182 r.. 775.083 rw s. 77531144. erne) A untie! offancior who reset not rompty with the requirrenrwitt of this torten commits a faintly of the third degree, punishable as provided in s. 775.062, s. 175.053, or s. //5.004. lls? A Lane offs:prefer van commits any act or omission In violation of this suction may be prosocutod for the art or omission In the county in which the act or omission was committed, the county of tho list rogistered ad.:Wats of tho sexual offender, or the county in which the reervictioo occurred for the offense or offenses that meat the critorle for dasignadeg a person as a sexual offender. lc) An arrest en charges of failure to register whim the offender has boon provided and adekod of Ms or het statutory ebtigatiarn to moister trader sulnactlon (7), the service of an information or a comrdelret for a violation of this section, or an arraignrmant on charges for n violation of this traction tomtit:eat ectoll notice of the duty to register. A sexual offoodois failure to immedietoly register as required by this section following such arrest, service, or arraignment creetitubirs grounds for a subsequent charge of failure to register. A sexual offender charged with the cares of faille* to rogitter who assorts, or Intend% to meet, a tack of notice of the duty to racists es a defense teacher's of terra in rollf star shall Immediately registrar its required by this section. A sexual offender who Is charted with a sotreequent fattier. to registor may not snort the defooso of a lar:k of notice of the duty to registet. Id) Registration following such arrest, tortice, or artalsimmire Is not a dofercia and does not •offevo the enlist offender of liability for the failure to register. (10) The riaipartrnent, the Oopartment of Ilighwey Safety and Motor Vehicles, the Dopartnont of Corrections, the Oopartroare of Juvenito Justice, any law onforcomant agency in this stale, and the personnel of those dopartrnants; an elected or appointed official, pulstir employe°, or school administrator; or an employea, egarrry, or any individual or entity acting at the rogernt or epee the direction of any !air enforcement agency is immune from civil liability fee damages for eond faith compliance with the roquiromentr of this :action or for the reheat* of information kinder this section, and shell be preemie( TO hero actod In gond faith In compiling, recording, report:IN. a reloasing the information. The presumption of good faith is not overcome If a torhrecal or clerical error Is rondo by the department, the °apartment of Highway Safety and motor Vohicles, the Department of Correction, the Dopartmant of Anemia EFTA00232608 A43 84/26/2010 14:51 3553626 • cIRcuir cRIMINnt PAGE 17/2e Justice, the personnel of those &pertinent or any individual or entity acting at the request or upon the direction of arty of those departments in compiling or providing information, or if information Is Incomplete or Incorrect because a sexual offender fails to report or Mon reports his or ha current place of permanent or temporary residence. (i Except as provide, in t. 943.04354 • sexual offender must maintain registration with the dapartment for the duration of iris or her life, union the sexual offender has rocoired • hill pardon or has had a conviction set aside in a postconviction proceeding for any (Moose that moots the criteria for danifylnq the person as a sexual offander for purposes of registration. Floworor, a sexual offender: WI. Who furs boon lawfully reioned from confinement, supervision, or sanction, which•vor is later, for at loan 25 peers and has not bon accosted for are, teeny or misdemeanor offarso since rakes, provided that the sexual offender's requirement to militia- was not baled upon an adult conviction: a. Far a violation of s. 787.01 or s. 717.02. b. Far a violation of s. 794.011 occluding s. 794.0111101; c. For a violation of S. 8CO.041.411b) whore the court finds the offense 'inched a victim undo/ 12 years of age or sexual activity by the use of force or coercion; d. For a violation of e. lifil.01(5)(b); a. For a violation of s. 800.04(5)c_2. whore the court finds the offonso Involrod unclothed genitals or genital arm; I. For any attempt a conspiracy to commit arty such Wonsan or V. For • violation of similar law of another jurisdiction, rruay patitlem the criminal' division of the circuit court of the circuit In which no 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 ho or she has not bean arrested for any crime since ralowsca; the requested relief complies with the provisions of the fader* Mans Walsh Child Protection and Safety Act of 2006 and any other hiderail standards applicahlo to the removal of registration requirements for a sexual offender or required to be rout as a condition for the rootlet of federal funds by the state; and the court is otherwise sathflod that the offoncior Is rota currant or potential threat to public safety. ihe state attorney in the circuit In which the petition is filed must be ran nonce of the petition at Iowa 3 watts Wore the honing on the matter. The than attorney may present aviderwo in cennitfon to the rochratod rile( a may otherwise demonstrate the reasons why the petition should be denied. If the court denies the petition, the court may sat a future, date at which the sexual offender may nialn petition the coat for relief, subject to the standards far relief provided in this subsection. 3. The department shall romooe an offends' from ciescfficerion as • sexual offnodar for purposes of registration if the offender provides to the department • fortified copy of the cotets written findings or order that indicates that the offender is no longer userrinel to comply with the roptirements for roglstration as a mutual offender. EFTA00232609 A44 04/26/2610 14:51 3553626 CIRCUIT CRIMINAL PACE 19/2ø (b) as defined In subsubparegraph (Walt .b. Far« maintain registration with the dopertmoni for the duration of his ar hoe life, until the person provides Use deeparsinont with art order issued by rho court that deslignetod the parson asa søtval predator, as e sexually vinlont grodator, or by another wined offend« dosigretien in the dato or Jurisdiction In which the orda was issued whiclt states that such designation has been nanovod or domonstratos to the department that such designation, if not imposed by a court, has been rammed by operation of law or court order in the dato or Jurisdiction in which the designation ras rn•do, and provided such person no longer meats the criteria for registration es a snauel offender under the laws of this state. (12) The legidaturo finds that sexual offondors, especially those who have committed offenses against minors, ofton pone/thigh risk of orginging In seared of/green men after being roloased from incarceration or commitment and that protection of the public from salami offenders is a paramount government intorost. Sexual offondors have a reduced axpuctsCon of privacy because of the publics interest in public safety and in the affective operation of govornmont. Roterasing information concerning sexual offorsders to law oreforcomont iegonces and to parsons wteo request such Information, end the ideas* of such information lo the, public bye law onkimement agency or public agency, will further the govanwriontal interests of public safety. The ckrifiiinetfon of a person as a swum! offender Is not a entionco nr e punishmemt but is simply the status of the °frond« which Is the' tenoAt of a conviction for having corrmittod certain crimes. (13) Any person who has rovson to bolfcreo doff a sexual offondrir is not complying, « has not complied, with tho requirements of this section and who, with the Intent to assist the sexual of fonder in eluding n 1aø enforcoment agency that is vaulting to had the sensual °Hand« to ntaircHnn the soused offender dwelt, or to arrest the sexual offered« for, his or be￾nuricemplianco with the rereulrernents of this section: elishbrAds infra-motion from, or «sirs not notify, the law OfifOrt ornont agency about too scorned offender's noncoretollanco with the rooulroments of this section, and, If known, tin whereabouts of the sexual offender; (b) Kerber, or attempts to harbor, or annals another person in herbireing nr attempting to hØ, the sexual offeencka; or (c) Conceals or attempts to conceal, o assists another person In r onroo(ing or attempting to ronconl, the wised offender; a fd) Provides information to the law enforcement ageenc-y regarding the sexual offender that tho parson knows to he false Infewrnation, coMmlb a %lorry of the third dopes, punishable as provided in s. 775 05Z 5. )75.00 or 5. T75.054. i 14)(10 A sexual offender mint ropert in person each star during the month of the sexual offoraher's birthday and during the sixth month following the sensel offonefor*r birth month to the shuriff s office In the county In which ho or she resides or Is otherwise located to finalist« (tel flowerr, a sexual offender who is rewired to register en a result of a conviction for: 1. Section 7117.01 or 1. 781.02 Wfgro the victim ise minor ond the offender is not the victim's parent a 'Mardi/1" EFTA00232610 A45 04/26/2010 14:51 3553626 2. Section 794.011, excluding s. 714.011(10); CIRCUIT CRIMINAL 3. Section 500.04(4)(b) whore the court finds the offense involved a victim under 12 years of age or taatual activity by the use of farce a COOrCiOnj 4. Section 1130.04(5)(b); 5. Section I00.04(5)Icit . where the cost flnds molestation Involving unclothed variants or genital area; 6. Section 1100.04(5)c.2. where the court Ands molostision irnotvlrq reiclothed genitals or genital area; 7. Section 100.04(51(d) whore the court finds the use of force or coercion and unclothed porritals or genital anis; a. Any attempt or conspiracy to commit such offense; or 9. A violation of a similar law of another )uH:Action, must reregister each year during the month of the sexual offenders birthday and ovary third month thereafter. (ci The sheriffs office may determine the appropnate timers and days for reporting by the sexual offender, which shall be consistent with the reverting requirements of this subsection. liareffstration shell Include any changes to the following information: 1. Name; social security number; age; race; sex; data of birth; height; weight; hair and eyo color; address of any permanent residence and address of any current temporary rosidenr.o, within the state or out of state, Including a twat route address wear* office box; any electronic mail address and any instant message name required to be provided PWSUOnt to paragraph Mid); data and place of any employment; vehicle make, model, color, and license tag number; firvorprints; and photograph. A pod office hox shall not be provided In lieu of a physical residential address. 2. if the smug offender is enrolled, employed, or carrying on a vocation at an Institution of higher education in this state, the sexual offender shall also preside to the department the nem*, address, and county of each institution, Including each campus attended, and the sexual offender's enrollment or employment status. 3. It the sexual offender's pin of residence is a motor vehicle, trailer, mobilo home, or manufactured home, es desired in chapter 320, the sexual offender shall also provide the vehicle identification number; dm license tag number; the registration number; and a decriptiort,inclucfing color scherne, of the motor chicle, trailer. mobil* borne, or manufactured home. If On sexual offender's place of residence Is a vessel, lfvo.aboard vessre, or houseboat, as defined in chapter 327, the sexual bffender shall also provide tbetwatt l estiRcntien number; the manufacturer's serial number; the name of the erratic thereboand vessel, or houseboat; the registration number; and a description, Ira-lotting color scheme, of the soma, live-aboard vessel or housaboat. 4. My snug offonde who fails to report In person as required at the sheriffs office, or who fells to respond to any address verification correspondence from the departrnont within 3 weeks of the date of the correspondence or who fails to report electronic mail addresses or PAGE 1 9/ 20 EFTA00232611 A46 84/26/2018 14:51 3553626 CIRCUIT CRIMINAL PAC*: 20/23 instent mosaic names, commits e Sony of this third degree, punIshabie en provided In s, 775.O82. t. 774.081, cur s. 775.064. (d) The sheriffs ofelca shall, within 2 working days, electronically submit and update sU Information provided by the Wallin offender to the departmixit in a mannor prowribod by the depertment. EFTA00232612 A47 Palm Beach Sheriffs Office Booking Card for Jeffrey Epstein, dated June 30, 2008 NAME': 04/26/2010 14:51 3553626 EPSTEIN, JEFFREY ALIAS NAMES, OVER SNARE& SISTE', JEFFREY - EPSTEIN, JEFFREY ECWARD - NIOAday. in 30.2008 PALM BEACH SHERIFFS OFFICE 11:33:10 A14 CIRCUIT CRIMINAL jAaCET" 03388170 e t. 2008039316 INCARCERATION DATEnTmE Rentyko0R ppusomen TYPE: LOCAL CHARGES Does Ws: WM AGE 55 WEIGKT: $ E 0 In SSW: WEIGHT: 200 BOOKING CARO EXO.LOC: HORNE BOOKING OKO. 0548 NAIR COLOR: SPY EYE COLOR Btu ADDRESS: 358 a GRILLO WY Orr: PALM REACH W 4: 20080030081 $IO 1 06587245 ALIEN R. re' 787075K6 STATE: Ft. DP: 33480 onzeN COUNTRY: usA PAGE 04/29 pcvcrt 3050 MS: 2006038/44 US. MARSKUL MITES. ARREST ADORESS:205 N DIXIE HWY (MAIN CT noose) ARREST DATE: ~woos SNO. DATE: 08/30/2008 WARRANDCASEM ARREST OFFICER: 0/S DepLA-To TRANS. OFFICER: CMS MCINTOSH CASE TYPE: RECOMMIT.FELONY Note STATUTE: CT: DESCRIPTION. 9999.0004 (NN) 1 -RECOIA1RT WPB ARREST TINE: 10:15 Rgc.mAp. 1132 COURT qviskom ARREST AGENCY: o1 - PESO TRANS. AGENCY: 01. pos0 CASE FLU,: NO BONO DOC it INODEN/ STATE: FT. Zr: CURRENT IHRID: $0.00 0 PROCURE PERSON UNDER AGE OF III FOR PROSTTAMONN CASE: 2008CP009361AXXAV HOLM NOW DATE/IMO 1 —.— 2 — —• . 3 NOW BY: • • 4 -- MID OEM: HOLDROADATENIME: MO ROL 810 HOW R94:40.941: "r.: re, ALERT DESCRIPTION PAM NARRATNe .."1-.:-.. - - .. 1 31 iff4;,-eiöreir4FneretiSier CrOWVICnON — . • . • 2 . -'• • .. ', • 41: 3 — . . OVER 3 ALERTS — — KEEP SEPARATE FROM NONE 14/SSIGNED HOUSING: VC INTAKE. ALMS RV.: ED. CLEAR REL. ELEASE DATE/TIME OURT DATE/TIME: . . HOC RELEASE PHOTO re. RELEASE MOVE! . . RELEASE INFORmATIONt COURT LOCATION: • • 1'1 0 . .1 ..... IfTA DATFJTIME: _ _ FP. ENTERED: . . . CIJWIRMATIOM . . WA IOC FP. CLEAR: MED.0.1.444 DE 111L.7 .I CLERK WARRANTS Li STATE Aviv CENTRAL1403S `.« EFTA00232613 • nCk",..c., . ccl r Iekergil, A48 Order granting Jeffrey E. Epstein's Motion for Travel, dated December 18, 2009 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA - CRIMINAL DIVISION CASE NO: STATE OF FLORIDA Vs. Cir Cqftei d - FY:Cv— • Defendant. ra. 04 cORDER ON MOTION US ) THIS MATTER comes before the Cotid upon DI . rvital-Ccr )04 Cf- 1,142 FILED Oiroult Criminal Department tics: 1 8 2009 SHARON R. BOCK Clerk & Comptroller Palm Beach County The Court, having been made aware that both counsel haVe agreed to said motion.. Accordingly, It is hereby. • • ORDERED and ADJUDGED that O nit3-Ver . s. ce,_ ,(1 Ilk 'Stiles, Ct Ja, -6•A-) . • d s -1-nkt., . I'D wete),O 0A7 j . ,,yAce j) (To, " TA fi at -kir rv:ea;i,ttlf,t0.4, **. k O in%s'ct O11" 1.1-€ '• Q&YC../ DONE and ORDERED in Chambers, est Palm Beach, Palm Beach Cou My, Florida, this day of /2 it/c-n rcuit Court Judge nfladt EFTA00232614 Ah Equal OPtaWRYEniployer 2601 Blair Stone Road Tallahassee, FL 32399-2500 Date: 701/2010 Mr. Epstein 358 El Erillio Way Mtn Beach, 19, 34480 A49 Letter from Florida Department of Corrections Regarding Termination of Supervision, dated July 21, 2010 FLORIDA DEPARTMENT of - • Pike& CORRECTIONS PritAlilaialle4 ?At li i?. BOCK 92ff .lealrigalt H. Governor CHARLIE CRIST Secretary JA.AIES R. MeBONOUGH. http://www.dc_stetc.flus RE: TERMINATION OF SUPERVISION MO W3575$ DOCKET= NO(S) S2Q21C52Q23.81212QQL Dear my. Epstein Von are hereby notified thatyoti hive completed your term(s) of supervision, as referenced above, and are no longer under the supervision oldie 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 a 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 win be mailed by the Office of Executive Clemency to your last mailing 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 questio a r civil rights, you may contact the Office of Executive Clemency for further information by calling or by writing to that office at Florida Parole Commission, 2601 Blair Stone Road, Building C, Tit a ILSSO;Florida 32399-2450. Information and application forms may be accessed through the following web site: vmAy.state.fl.usifoc/exclem.html. After eight (8) years from temrination 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 (IDLE) 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 inntE to youir1 1 k res J.-\ tor a very successful future. Sincerely, V i --) Candice Elkins 131 If you were on supervision for a sexual offense, attached is a copy of the Notice of Responsibilities, which outlines your continued responsibilities in emordanee with Florida Statutes. 0 U you were sentenced as a career offender, attached is a oopy of the Career Offender Notice of Responsibilities, which outlines your continued responsibilities in accordance with Florida Statutes. Original: Offender Copy: Of enderrile Florida Parole Commission (If applicable) Oak of Cows (if required) (Revised 03(03) EFTA00232615 A50 I (ter in halm Beach Sheriff's Office Regarding Jeffrey Epstein's Participation in the Work Release Program, dated August 12. 2010 eiglitERIFF'S RIC L. BRADSHAW, SHERIFF FAX: August 12th 2010 To Whom It May Concern: DEPUTY K. SMITH 3656 ALTERNATIVE CUSTODY 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 K. Smith 3228 Gun Club Road • West Palm Beach, Flonda 33406-3001 • • tutp://www.pbso.org WI20010 tWornonli EFTA00232616 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 GOLDBERGER ' JOSEPH R ATTERBURY ' 1 JACK A. GOLDBERGER ' JASON S.WEISS ' Board Certified Crimoal TrialAttorney I Member cd New Jersey & 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. ft 33401 P www.agwpa.coin EFTA00232617 A52 s I 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 EFTA00232618 A53 Letter from Martin G. Weinberg to NYS Board of Examiners of Sex Offenders Regarding Risk Level and Designation Determination for Jeffrey Epstein, dated August 16, 2010 [pp. A53-A571 MARTIN G. WEINBERG, P.C. ATTORNEY • LAW 20 PARK PLAZA, SUITE 1000 BOSTON. MASSACHUSETTS 02116 FAX August 16, 2010 New York State Board of Examiners of Sex Offenders 4 Tower Place Albany, New York 12203-3764 Re: Jeffrey Epstein NYSID # O51909 • Dear Sir or Madam: EMAIL ADDRESSES: 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 I. 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 M.the age of 17. Notably, as addressed in greater detail, infra, the conduct which occurred after 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. EFTA00232619 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 EFTA00232620 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 Triagerinz 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 rson under the age of 18 (the age of consent in Florida) for prostitution, specifically, here, one ''=" 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 AusLst 1, 2004, and October 9, 2005, see Information, Ex. C, that latter date being the day before M's 18th birthday: Thus, for almost all of the duration of the charged offense, M. 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(2XaXi)(§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 M. turned 17 years of age would not even have been a crime under that statute if the conduct had taken place in New York? 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. 2 In 2007, §230.04 was amended to extend its 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 M. was in the last three months of her 16th year, would only have been a misdemeanor had it been committed in New York. 3 EFTA00232621 A56 only one woman, and there was no force or violence involved at any time, nor did M. 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 i 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 hit 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 K. Smith, 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 his 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 ' One such travel order is attached as Ex. E. EFTA00232622 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 It Based on all the relevant factors, Mr. Epstein should be classified as a level I 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 so 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. 5 EFTA00232623 A58 Letter from Stephen R. Alexander, Psy.D. to Jack Goldberger Regarding Opinion of Jeffrey E. Epstein, dated August 16, 2010 ipp. A58-A611 Stephen R. Alexander, Psy.D. Clinical Psychologist 1825 Forest Hill Boulevard, Suite 204 West Palm Beach, Florida 33406 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 ortssion, 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 rcoffending 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 Epetein-06037-I2A EFTA00232624 A59 Stephen R. Alexander, Psy.D. Clinical Psychologist 1825 Forest Hill Boulevard, Suite 204 West Palterida 33406 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 te—Youth Service Bureau, 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 profbssional staff under the Chief Psychologist (5 Psy.D./Ph.D. psychologists, and 20 M.A./M.S.W. counselors). EFTA00232625 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. Program evaluation of 15 Head Start Centers in a four county area for HE.W. 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 throe 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 LW Medical Center, weekly psychoanalytic psychotherapy seminars and weekly psychodiagnostics seminars. PRACTICUM PLACEMENTS Neuropsychlatry Unit: Wuesthoff Memorial Hospital, Rockledge, Florida. 20 hours per week (200 total hours); January to March, 1984. EFTA00232626 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. EFTA00232627 Offender Name: JEFFREY E EPSTEIN NYSID th OS1909 1ST Reviewer Initials: SObp The 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.. 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: t EJ Sexually Violent Offender - a sex offender who has been convicted of a sexually violent offense defined In Correction Law section 168-a (3). Please check which conviction(s) apply, also please indicate whether the conviction was for an attempt at an offense: amino ammo 130.35 -Rape 1st degree 13030 - Sodomy 1st degree/Criminal Sexual Act 1st degree 130.65 - Sexual Abuse In degree 130.66 - Aggravated sexual abuse 3rd degree 130.67- Aggravated sexual abuse 2nd degree 130.70 - Aggravated sexual abuse I st degree 130.15 -Course of sexual conduct against a child 1st degree 130.80 - Course of sexual conduct against a child 2nd degree 2. O Predicate Sex Offender - a sex offender who has been convicted of an offense set forth In subd convicted of an offense set forth in subdivision 2 or 3 of Section 168-a, regardless of the date required to register for the previous conviction. Please identify below the offenders previous qualifying conviction(s) as well as the offender's current offense. Current Previous Attempt Current Previous Aget3)18 130.20 - Sexual Misconduct 130/5 - 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 130.53 - Persistent sexual abuse 130.65-a - Aggravated =coal 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 sectia485.05 of the penal law or as a crime of terronsan 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. eses C. o. S CE am Nc O cmmi. 1-4 ea to 1.1 co et. 0 O ow es "i• es rs e exsl &N) C Cia,k\ - = ro •EO. A Ivision 2 or 3 of Correction Law Section 168-n when the offender has been previously MI• of the prior conviction and regardless of whether the offender was 8. 0O qualifying conviction, also please indicate whether the conviction was for an attempt at an ' 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 knodsonment 1st degree r > clatrelg Pte LS Attanot ba els zo w 135.20 - ICIdnapping 2nd deg0 B re 135.25 - Kidnapping 1st degree a (`Note: 133.05,135.10.13520.135.25 the victim must be less than I/ years old and the offender must not be the parent of the victim) Continued on the next page. C rn O EFTA00232628 2. (Canted) Current Previous Attempt Current Previous Attempt 230.04 Patronizing a prostitute 3rd degree (victim <17 years old) 230.05 Patronizing a prostitute 2nd degree 230.06 Patronizing a prostitute In degree 230.30 (2)- Promoting prostitution 2nd degree 230.32 -.Promoting prostitution 1st degree 235.22 j Disseminating indecent material to minors 1st degree a convidtion of or a conviction for an attempt to commit any provisions of a — listed sex offense committed or attempted as a hate crime defined in section 485.05 Qf the penal law or as a clime of terrorism defined in section 490.25 of such law. 130.52 Forcible touching (victim<18 years old) 130.55 Sexual abuse 3rd degree (victirn<I 8 years old) Cony ictibn/Attempt to commit any provision of 130.52 or 130.55 of the penal law regardless of age of victim and the offender has previously been convicted of (i) a sex offense listed in Correction Law Section (68-a (2), or (i i) a sexually violent *Mose listed in Correction Law Section 168-a (3), or (iii) any of the provisions of section 130.52 or 130.55 of the penal law or an attempt I Aconvict n of (i) an offense in any other jurisdiction which includes all of the — essential efcmcnts 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. 18 U.S.C. 2252. IS V.S.C. 2252A, or 18 V.S.C. 2260 provided the elements of such crime of conviction are substantially the same as those which are pan of such intense as of March I I. 2002. 130.35 - Rape 1st degree 130.50 - Sodomy 1st degredCriminal 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 a sexually violent offense as set forth in Correction Law Section I68-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 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. Sexual Predator - a sex offender who has been convicted of a sottish violent offense defined in Correction La;vg; , 168-a (3) and who suffers from a mental abnormality or personality disorder that makes him or her likely to engage in sexually violent offenses. CP\ (6) 19 None of the above. EFTA00232629 SEX OFFENDER REGISTRATION ACT RISK ASSESSMENT INSTRUMENT RISK FACTOR VALUE SCORE I. CURRENT OFFENSES) I. Use of Violence Used forcible coo pulsioa +10 X 10 Inflicted physical injury +15 Armed with a dangerous instrument +30 2. Sexual Contact with Victim Contact over clothing Contact under clothing Sexual intercourse. deviate sexual intercourse of aggravated sexual abuse +5 25 +10 +25 X S. Number of Victims Two Three or more +20 30 + 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 to or kis. 63 or more +20 X 20 +30 6. Other victim characteristics Victim suffered from mental disability or • incapacity or from physical helplessness +20 0 20 7. Relationship with victim SUanget or established for mote of victimizing or professional relationship +20 X II. CRIMINAL HIS I OR% R. Age at first act of sexual misconduct 20 or less +10 0 9. Number and natal+ of prior crimes Prior history/no sex minus or felonies Prior historyinomviolent felony Prior violent felony, or misdaneanur Sc' crime or endangering welfare of a child +5 X +15 5 ' +30 It Recency of prior offense • Less dun 3 years +10 0 II. Dreg or Alcohol abuse History of ahem. +15 0 COLUMNS 1- 11 SUBTOTAL 130 SEX OFFENDER REGISTRATION ACT RISK ASSESSMENT INSTRUMENT RISK FACTOR VALUE SCORE III. POST-OFEEN3E BLIUVIOR 12. Acceptance of Respossibility Not accepted responsibility Not accepted responsibility I refused or expelled from treatment +10 0 +15 13. Conduct while confined / supervised Unsatisfactory . Unsatisfactory with sexual misconduct +10 0 -20 IV. EUXLEASk. LN VIRONMEN I 14. Supervision Release with specialized supervision Release with supervision Release without supervision 0 1:5 0 +15 LI. Living/ employment situation Living or employment inappropriate +10 0 COLUMNS 12-13 SUBTOTAL COLUMNS I-It SUBTOTAL 130 TOTAL RISK FACTOR SCORE (add 2 subtotals) 130 1 2 X Offender Name: JEFFREY E EPSTEIN NYSID #: 0S1909 Docket #: RISK LEVEL: 3 Assessor's Signature Date: - to A. Overrides Ofany ovenide is circled, offender is piesumpuvdy a Level 3) 1. Offender has a prior felony conviction foe a sex crime 2. Offender inflicted serious physical injury or caused death 3. Ott offender has made a recent threat that he will reoffend by committing a sexual or violent crime 4 There has been n 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 0 Yes El No Level I (low) 0 CO +70 2. If yes, elate the appropriate risk level I 2 3 Level 2 (moderate ) +73 to +105 Level 3 (high) +110 w +300 3. If yes, explain the basis for departure I See Summary) Note. The Sex Offender Registration Act requires the court ar Board of Examiners of Sex Offenders to consider any victim impact statement in determining a sex offender's level of risk EFTA00232630 A65 RE: JEFFREY E EPSTEIN NYSID #: 0S1909 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 I g for Prostitution and Felony Solicitation of Prostitution. He was sentenced tot 2 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 sexuallyassaulted 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 participants were age 18 or older. The contact included vaginal intercourse, mouth to vagina sodomy, the touching of the breasts and vagina, placing his fingers inside the vagina and Epstein using a vibrator on the victim's vaginal area. 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 touch the breasts or vagina of the victim with his hands or use the vibrator. One 14 year old.described how Epstein touched her vaginal area with a vibrator and thereafter, when contacted by law enforcement, she had to identify the offender through the use of a photo array. Another 16-year-old victim described giving Epstein massages for two years and at times, he grabbed her buttocks and caressed her butt cheeks as she gave him a massage. Another 16-year-old described going to the offender's home at least 100 times. He would touch her breasts, insert his fingers into her vagina and sometimes use the vibrator on her while masturbating. He would also pay this underage victim to have sex with a female friend while he watched. Occasionally, he would join both girls and perform oral sex on both. This 16-year-old victim described for police how one time, Epstein turned her over on t Triaasaa,, talk, and y alp I Iv bui‘amed, "NO: tic blooml and subsetptently-apotogized-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. 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. EFTA00232631 A66 RE: JEFFREY E EPSTEIN NYSLD #: OS1909 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 III Sex Offender with absolutely no basis for downward departure. EFTA00232632 A67 Letter from Supreme Court attaching Notification, Recommendation and Notice of Right to Appeal, dated August 26, 2010 SArperilt Calle of Up' „Stab of kitEtt ark 100 CENTRE STREET NEW YORK. N.Y. 1000 TO: PART 66 FROM: CORRESPONDENCE UNIT SUBJECT: SEX OFFENDER RISK ASSESSMENT RE: Jeffrey Epstein SCID. fi 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 ofthe 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 litmard the COURT FILE AND ASSESSMENTDOCUMENTSto this office. RE--FURTHER—ADYISEIt VISION OF—PAROLE MAY- nuttrrtt DEFENDANT UNTIL A RISK LEVEL HAS BEEN ASSIGNED. A REQUEST FOR 18B ASSIGNMENT HAS BEEN MADE. ONCE YOU END THE ATTACHED NOTIFICATION LETTER AND BOARD OF EXAMINER'S PACKAGE TO HIM/HER EFTA00232633 A68 Letter from Supreme Court to Jeffrey E. Epstein Informing of SORA Level Determination Hearing, dated August 26, 2010 Supreme Qintrit of Putt of !Seto 'fork August 26. 2011) • MO CENTRE STREET NEW YORK. N.Y. 60013 Mr. Jeffrey Epstein 9 East 711Street 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 will be classi lied as a level I , 2 or 3 sex offender and i Fyne will he designated as a sexual predator. a sexually violent offender or a predicate sex offender. The court's decision will determine how long you must register as a sex offenderand howmuch information can he provided to the public concerning your mgistration. The court'sdetermination may be higher. lower 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.. before the Hon. Ruth Pickholz in part 66 located at 111 Centre Street. New York, N.Y. You have a right to attend this hearing. I fyou wish to waive your appearance tin• the hearing enclosed is a waiver form which must be notarived and returned to this office within ten days of receipt. A request has been made for an attorney to represent you t this heari_L If you fail to appear at this proceeding, without sufficient excuse, it shall be held in your absence. Failure to appalr may result in a longer period ofregistration or a higher level of comma! iity notification because you are not present to offer evidence or contest evidence offered by the District Attorney. Enclosed please find the Board o Mxaminers summary with their recommendation that ”iti be assigned a risk level of3 and a document which describes what yourduties will be alleryou are assigned a risk level. At the conclusion onhedetennination hearing you will receive acopyolIN:tout-1s final rccammcndalinn with a notice to appeal. Very truly yours. Mary A. Price. CCS encs. Supreme Court - Criminal Tent Nem York 1 EFTA00232634 A69 Order Sheet for Jeffrey Epstein, dated August 26, 2010 A69-A70] ORDER SHEET Court Supreme Court, Criminal Tenn Date August 26, 2010 County New York Part Correxpondatce Unit People of the State of New York, • Docker ind.fl 301 29-20 10 Jeffrey I Mimi it I k ft it a et Highest (l'eml law) flomicide Li Felony Alisdctneattor Special Proceeding Sex Offender Nearing ■ Vii)611. Fl Being satisfied arty a review of the financial status of the defendant named, that he is financially unal,lr no obtain counsel, and upon his request for the :appointment of counsel. it is, /rdered that the folkiwingtitcmlx:r of die Bar be and hereby is -appointed to rcprescur such defendant in all matter, pertaining to this *Minn: gZ;l assaikiv — 4 414t-se...- tsi sCijeakietatata- .\djottmed Date tivrt. Defendant's Stann: I kfentlaites Address: Comments: .1djourned l'arr rd. Assigningpas Ruth Rickholt Pa min I Boiled Incarcerated 11 9 East 71' Sweet, New link, N.Y t Name: •'• Mary A. Price, CCS tvicrIblific EFTA00232635 A70 TRANSMISSION VERIFICATION F£ppRi TIME : 88/26/2810 10:58 NAME : CORRESP INIT FAX : TEL SER.11 : BROK53356431 DATE .TIME FAX Ml. /NAME DURATION PAGE C.) RESULT MODE 08/26 10.58 188 ASSIGNED 88:90:18 01 OK STANDARD ECM ORDER SHEET Colin Supreme Court. Criminal Term County New York The People or the State of :Icy York va. Jeffrey Epstein Defender Homicide Highest Chew: (Penal Law) Felony Dale Algatst26.2010 Pari Correspondence Unit Docket Ind.# 30129.2010 ttdc me n Special Pniceeding l-jra Offender Heating I 1 ltinlativu F1- Tieing satisfied after a review of the horndal flatus of the defendant named, tiler he is financially unable to obtain counsel. and upon his teasen fot the appointment of counsel, it is, hdeted that the following member of the Rar he and betel:7 it appointed to represent such defendant in .11 natters pertaining to this action: Åtemai;di simeitm‘atitasial￾r 1' 4/ ".t 7.01n Adjourned Part (16 EFTA00232636 A71 Letter from Supreme Court to Counsel Informing of SORA Level Determination Hearing (with attachments), dated August 26, 2010 [pp. A71-A76] Supreme gaud of fire Skits of pay VA 100 CENTRE STREET NEW YOR1C, N.Y. 10013 August 26. 2010 Defense Attorney 1813 To Be Assigned Ms. Inn-Young Park NYC District Attorneys Office 1 Hogan Place. Room 831 New York. N.Y. 10013 Re: Jeffrey Epstein SOD if 30129-2010 Dear Sir/Madam: The above named defendant is scheduled for a Sex Offender Risk Level Determination before the lion. 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 forwarded 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 Ivaive his appearance. Enclosed please find a copy or the Board of Ixaminers recommendation. t.aiy Mary A. Price. CC'S Supreme Court - Criminal 'Fenn New York County enc. EFTA00232637 Offender Name: JEFFREY E EPSTEIN NYS1D OS 1909 1ST Reviewer Initials: le 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• 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: . Sexually Violent Offender - a sex offender who has been convicted of • sexually violent offense defined in Correction Law section 168-a (3). Please check which convictions) apply. also please indictee whether the conviction was for an attempt at an offense: Attempt 2 0 130.35 - Rape I st degree 130.50 - Sodomy I si degree/Criminal Sexual Ac: 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 Attempt 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 otherjurisdiction for which the offender is required to register as a sex offender In the jurisdiction which the conviction occurred. 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 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 convictions) as well as the offender's current qualifying conviction. also please indicate whether the conviction was for an attempt at an Offense: -uproot Previotic AlEmni 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 flit-rent Previous Attemnt 130.60 • Sexual Abuse 2nd degree 235.25 - Incest Article 263 offense - Sexual Performance by a Child 135.05 - Unlawful Imprisonment 2nd degree 135.10- Unlawful Imprisonment 1st degree Current Previous Attempt 135.20 - Kidnapping 2nd degree 135.25 -Kidnapping 1st deluxe (*Noce: 135.05.135.10. 135.20. 135.25 - the victim must be less than 17 years old and the offender must not he the patent of the victim) Continued on the next page. EFTA00232638 iCont-di urrent Previous &Ha 230.04 Patronizing a prostitute 3rd degree (victim <12 Years old) 23(1.05 Patronizing a prostitute 2nd degree 230.(16 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 o convi listed se 485.05 of such ion of or a conviction for an attempt to commit any provisions of a offense committed or attempted as a hate crime defined in section the penal law or as a crime of terrorism defined in section 490.25 130.52 -Forcible touching (victim<18 years old) 130.55 -(Sexual abuse 3rd degree (victim<I8 years old) Convict' — penal las convict (ii) a sex (iii) any attempt A convict' essential e 168-a (2) required t occurred. U.S.C. 22 such cri such often n/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: (1)a sex offense listed in Correction Law Section 168-a (2), or ly 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 eof n of (i) an offense in any other jurisdiction which includes all of the meets 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 sec offender in the jurisdiction in which the conviction (iii) any of the provisions of 18 U.S.C. 2251, 18 U.S.C. 2251A. 18 2. IS U.S.C. 2252A. or 18 2260 provided the elements of of conviction are substantially the same as those which arc part of as of March 11. 2002. Current Previous Attempt 130.35- Rape 1st degree 130.50 - Sodomy 1st degree/Criminal Sexual Act I g degree 130.65 - Sexual Abuse 1st degrx 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 I 30.65-a - Auras eked 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 piw Section 168-a (3) committed or attempted as a hate crime defined in section 485.05 of the penal lax 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 felon) provided for above or conviction of. 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(21.(3)and(4) - Unlawful surveillance 2nd degree 250.50 - Unlawful surveillance I st degree E Sexual Predator - a sex • ender who has been convicted of a sexually violent offense defined in Correction Law Section 168.0 (3) and who suffers from a mental abnormality or personality disorder that ekes him or her likely to engage in sexually violent offenses. None of the above. EFTA00232639 SEX OFFENDER ma:ism-trim A(-r RISK ASSESSlIENT IXSTRUNIENT RISK FACTOR URKLIV1 FEISSMSI VALUE SCORE I Use of Violence •sed forcible compulsion +10 Inflicted pinsmal :Mon *15 10 Armed with a dangerous instrument +30 2. Snout, Contact with Victim, Contact over clothing +5 Camara under clothing +10 Sexual 25 imewinirse. tics late sexual iinesuourse or aggravated sexual abuse +15 x 3. Number of Victims Two +20 30 Three or mole +30 4. Duration of offense condom with viedm Continuing course of sexual nisconduci +20 20 5. Age of victim I I through 16 +20 20 10 or less. 03 or more +30 6. Other victim chtracterisites Victim suffered from mental disability ea incapacity err from physical helplessness +20 0 7. Relationship with victim Snarler or established for purpose of victimizing or professional relatiOnship • +20 x 20 II. L 11112/ 1 ORI S. Age at lint act of sexual misconduct 20 or loss +10 0 9. Number and mature of pilot crimes. Prior history/no sex crimes or felonies +5 x Prior histury/non-violent felony +15 5 Prior violeri felony. or misdemeanor sex crime or endangering welfare of a child +30 f 10. Recency of prior offense . Less than 3 years +10 0 II. Drug or Alcohol abuse History of shine +15 0 • COLUMNS II SUBTOTAL 130 SEX OFFENDER REGISTRATION ACT RISK ASSESSMENT INSTRUMENT RISK FACTOR VALUE SCORE Ill. POST .OFFENSE BEHAVIOR 12. Acceptance of Responsibility Not accepted responsibility Not accepted responsibility / refused or expelled from treatment U. Conduct while confined / supervised Unsatisfactory Unsatisfactory with sexual misconduct +10 0 0 +15 +10 ... . . +20 iv. FILLB.ASL ENVIRONMLNI Id. Supervision Release with specialized supervision Release with supervision _ Release without supervision IS 1.444-iinitillimeritiliiiiiiin— . — - --' Living Of anploymcni inappropriate — COLUMNS 12-IS SUBTOTAL 0 0 -- 0 - • - - 0 130 130 -175 +15 —. +10 • - — COLUMNS I-11 SUBTOTAL TOTAL RISK FACTOR SCORE —.- (add 2 subtotal/ 1 2 X Offender Name: JEFFREY E EPSTEIN NYSID OS 1909 Docket 0: RISK LEVEL: Assessor's Signature Date: 3 Level I (low) level 2 (moderate ) Level 3 (high) 0 10 470 475 to +105 +110 to +300 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 offender's level of risk A. Overrides (If any override is circled. offender is presumptively a Level Jr I. Offender bas a prior felony conviction fora sex crime 2. Offender inflicted serious physical injury or caused death 3. The offender has nude a recent threw that he will reoffend by committing a sexual or violent aline 4. There has been a clinical assessment that the offender has a psychological, physical, or organic abnormality that decreases ability to combat impulsive sexual behavior B. Departure I. A departure from the risk level is warranted yes kO No 2. If yes. circle the appropriate risk level I 2 3 3. :f yes. explain the basis for di:mature ( Sec Summary) EFTA00232640 A75 RE: JEFFREY E EPSTEIN NYSID 051909 DATE: 8123/2010 CASE SUMMARY 'Ibis 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 tinder 18 for Prostitution and Felony Solicitation of Prostitution. He was sentenced to12 months in jail followed by 12 months ofCommunity 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 I4 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 participants were age 18 or older. The contact included vaginal intercourse, mouth to vagina sodomy, the touching of the breasts and vagina, placing his fingers inside the vagina and Epstein using a vibrator on the victim's vaginal area. 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 touch the breasts or vagina of the victim with his hands or use the vibrator. One 14 year old described how Epstein touched her vaginal area with a vibrator and thereafter, when contacted by law enforcement, she had to identify the offender through the use of a photo array. Another 16-year-old victim described giving Epstein massages for two years and at times, he grabbed her buttocks and caressed her butt cheeks as she gave him a massage. Another 16-year-old described going to the offender's home at least 100 times. He would touch her breasts, insert his fingers into her vagina and sometimes use the vibrator on her while masturbating. He would also pay this underage victim to have sex with a female friend while he watched. Occasionally, he would join both girls and perform oral sex on both. This 16-year-old victim described for police how one time, Epstein turned her over on the massaue table and forcibly rated her " NO " an,4 uantly-apologized-for his actions. The offenders conduct while on Community Control will he 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 he 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. EFTA00232641 A76 RE: JEFFREY E EPSTEIN NYS1D#: OS1909 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. Ile scores as a Level III Sex Offender with absolu►ely no basis for downward depanure. EFTA00232642 A77 Letter from Jay P. Lefkowitz to Hon. Ruth Pickholz Requesting a Continuance of the Hearing, dated September 9, 2010 09/07/2010 09:55 FAX 0 2:00 2 KIRKLAND & ELLIS LLP NIO arnuarrn PAItTNIRSHIPS 601 Lexington Avenue Now York. NkY/ Yolk 10022 Jay P LelkowItz,. To Call WIWI Dimly: Facsinne awn.. kiridandccm BY FACSIMILE. The Honorable Ruth Pickholz New York County Supreme Court Part 66 111 Centre Street New York, NY 10013 September 7, 2010 1. Re: $CID 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 9:30a.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. Respe» fully submitted, . Lefkowitz, P.C. Chicago Hong Kong London Los Angeles Munich Palo Alto San Francisco Shanghai Washington. O. C. EFTA00232643 A78 Letter from Supreme Court to Sex Offender Registry Unit Enclosing Final Determinations, dated January 19, 2011 [pp. A78-A791 Si rant Camrt of for Pak of 14th Igor' CENTRE STREET IIEW YORK. NY KAU 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 10C21 Ind.# Risk Level 30129-2010 Three (3) Respectfully yours, F. Halwick, SCC Correspondence Unit Supreme Court, Criminal Term EFTA00232644 A79 ."'•':; 1;4: . • -tlri t -" qNoNE;OFFENDEA IS.UN P.EFtyISE • kv A . • :4•N, . • n• The •. 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P.C. illIM I.Fax talloc1/410022 lay Infecont:Okirkland c ft RECOGNIZANCE ROR 20 BAIL FIXED AMOUNT COURT CLERK COUNSEL PRESENT ON CONSENT OF ADA COURT REPORTER BAILED 20 SURETY JUSTICE INTERPRETER COURT CLERK COURT CLERK ROR REVOKED-BW 20 JUSTICE BAIL FORF.•BW JUSTICE BAIL EXONERATED JUSTICE SURR. BY SURETY 20 20 ARTICLE 730 EXAMINATION ORDERED 20 JUSTICE COURT CLERK COURT REPORTER SUBSEQUENT ACTION RE RECOGNIZANCE PART 20 JUSTICE ADA PRESENT COUNSEL PRESENT COURT REPORTER COURT CLERK ORDERED 20 PART 20 JUSTICE COURT CLERK COURT REPORTER COMMUTED TO COMMISSIONER OF MENTAL HYGIENE: JUSTICE ADA PRESENT COUNSEL PRESENT EFTA00232646 A81 Handwritten Notations on Court Jacket - Jeffrey Epstein, No. 30129-2010 0 i 9 2 4 (5 2 a. • C.) 0 •9 n t • r1 '4 • E ('1%. a EFTA00232647 2 3 4 5 A82 Transcript of SORA Hearing, dated [pp. A82-A961 SORA HEARING SUPREME COURT NEW YORK COUNTY TRIAL TERM PART 66 THE PEOPLE OF THE STATE OF NEW YORK: AGAINST January 18, 2011 x INDICTMENT # : 30129/2010 6 JEFFREY EPSTEIN Defendant. x SORA HEARING 7 8 111 Centre Street New York, New York 10013 9 January 18, 2011 10 BEFORE: 11 12 HONORABLE RUTH PICKHOLZ Justice of the Supreme Court 13 14 APPEARANCES: 15 16 For the People: CYRUS R. VANCE, JR., ESQ., New York County District Attorney 17 One Hogan Place NewY York 10013 18 BY: GAFFNEY, ESQ. Assis an strict Attorney 19 For the Defense: KIRKLAND & ELLI, LLP 20 153 East 53rd Street 21 New York, New York 10022 BY: JAY LEFKOWITZ, ESQ. 22 SANDRA MUSUMECI, ESQ. 23 24 Vikki J. Benkel Senior Court Reporter 25 Mk! J. Benkel Senior Coax Reporter page 1 EFTA00232648 A83 SORA HEARING page 2 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 CLERK: This is number two on the calendar, matter of Jeffrey Epstein. Your appearances please. MS. GAFFNEY: Gaffney for the People. Good afternoon, Your Honor. MR. LEFKOWITZ: Jay Lefkowdtz 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 Cowl Reporter EFTA00232649 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 A84 SORA HEARING page 3 one victim and that is what the defendant plead to. 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. 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 Cowl Reporter EFTA00232650 A85 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 4 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 Reponer EFTA00232651 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 EFTA00232652 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 page 6 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. Vat J. Bunke! Senior Court Reporter EFTA00232653 A88 SORA HEARING page 7 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 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 lamest 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 Vikki J. Benke! Senior Court Reporter EFTA00232654 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. lienkel Senior Court Reporter EFTA00232655 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 page 9 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 was 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 MS 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. Vikki J. Benkei Senior Cant Reporter EFTA00232656 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: Haw old was she? Vikki J. Benkel Senior Court Reporter EFTA00232657 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: Haw 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 Vinci J. Benkei Senior Cows Reporter EFTA00232658 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 A93 SORA HEARING page 12 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. 11S. 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 —right-to appeal Your Honor's ruling. THE COURT: Of course, do so. MS. GAFFNEY: For the record, Your Honor, he is Vikki J. Bacel Senior Court Reporter EFTA00232659 RECORD PRESS. INC., 229 West 36th Street, U.Y. 10018-28829 www.reconlpress.com EFTA00232660 I To be Argued By: JAY P. LEFicowrrz New York County Clerk's Index No. 30129/2010 Nefn V.arit *inane &curt 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 LYNN MusumEct KIRKLAND & aus LLP 601 Lexington Avenue New York New York 10022 Attorneys for Defendant-Appellant REPRODUCED ON RECYCLED PAPER EFTA00232661 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 II. 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 EFTA00232662 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 ll EFTA00232663 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 u. 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) 31 People v. Coffey, 45 A.D.3d 658 (2d Dep't 2007) 24 People v. Curthoys, 27 People v. David W., 95 N.Y.2d 130 (2000) 32 iii EFTA00232664 People v. Dominie, 42 A.D.3d 589 (3d Dep't 2007) 19 People v. Donk, 39 A.D.3d 1268 (4th Dep't 2007) 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 u. Mabee, 69 A.D.3d 820 (2d Dep't 2010) 27 People v. Mingo, 12 N.Y.3d 563 (2009) 26 People v. Miranda, 24 A.D.3d 909 (3d Dep't 2005) .17 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 u. Sherard, 73 A.D.3d 537 (1st Dep't 2010) 13 EFTA00232665 People v. Smith, 66 A.D.3d 981 (2d Dep't 2009) 24 People'. 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) 19 Solomon v. State of New York, 146 A.D.2d 439 (1st Dep't 1989) 19 Statutes 14 V.I.C. § 1722(b) 14 V.I.C. § 1724(d) 14 V.I.C. § 1724(e) Correction Law § 168-a(2) Correction Law § 168-a(2)(a) 7 7 7 9 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) passim Correction Law § 168-1(6) Correction Law § 168-1(6)(c) 8 Correction Law § 168-n 45 EFTA00232666 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 EFTA00232667 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 EFTA00232668 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 EFTA00232669 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- 89:3JM).2 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 "Tr." followed by the applicable page and line citation. 3 EFTA00232670 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 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 EFTA00232671 (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 Sheriffs 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 EFTA00232672 Fl 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). IL 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 EFTA00232673 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 (Tr.). 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 (Tr.). 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 A67 (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 -- 7 EFTA00232674 Level 3, representing a high risk of repeat offense -- without further designation.8 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, 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 EFTA00232675 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 Qiirection Law § 1C8 a(2)(d)(ii). (Notably, the New YorS-Pngnota 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)0), (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 EFTA00232676 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 convictedpertained to consensual, commercial, non-violent interaction with one woman, M., 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 (Tr.). 10 EFTA00232677 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 EFTA00232678 unprosecuted allegations in the probable cause affidavit cited by the Board. See A.83:14-84:19 (Pr.). 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. V. 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 EFTA00232679 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 A149:22-90:21. 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 EFTA00232680 exact age of complainant . 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 gr.). 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 (Tr. 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 EFTA00232681 evidence. See A.94:7-95:9 (Fr.). 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 (Tr.). 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 (Tr.). 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 .Tannery 19, 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 EFTA00232682 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 abaiguing a .:Mk Level 1 ideration of 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 11(B), infra. 16 EFTA00232683 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 COURTS 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 EFTA00232684 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 EFTA00232685 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 EFTA00232686 clear and convincing evidence" is assigned to the District Attorney, which represents the State in the proceeding. Correction Law §§ 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 EFTA00232687 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 9 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 A.6 (Palm Beach Police Department - Probable Cause Affidavit of Attorney r sly 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 EFTA00232688 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.83:14-84:19, 85:11-16, 87:10-12 (Fr.). 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 EFTA00232689 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 ).10 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 80 Of note, at one point during the SORA proceeding, the Court seemingly dismissed out of hand the SORA guidelines concerning uncharged allegations. See k84:7.13 (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 EFTA00232690 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 EFTA00232691 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 (Fr.). 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 (Tr.). 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 EFTA00232692 (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 rnuntervailing 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 EFTA00232693 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 EFTA00232694 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 J. Recarey, 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 ii 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 EFTA00232695 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 Me" and not citing specific contact with Florida authorities). Appellant also disputed the validity of many of the 29 EFTA00232696 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, exp sirstated-they-eould-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 EFTA00232697 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 v. 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 u. 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 ------ stimmiary-does-uot-establish-hy-elear-aud-coman her s 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 EFTA00232698 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 EFTA00232699 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 EFTA00232700 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. B.B. v. Verniero, 119 F.3d 1077, 1111 (3d Cir. 1997), art. denial, 622 U.S. 1109 (1998) (citing Addington v. Texas, 441 U.S. 418, 427 (1979)); see also Brooks, 303 A.D.2d at 106 (observing "a SORA determination 34 EFTA00232701 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 factfmder." 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 EFTA00232702 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 EFTA00232703 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 EFTA00232704 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 24 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 EFTA00232705 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,16 see Correction Law §§ 168- 15 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 a 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); ef. 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 EFTA00232706 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 EFTA00232707 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. le 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, 1,11 5, 6. 41 EFTA00232708 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 EFTA00232709 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. u. 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 u. Sherard, 73 A.D.3d 537, 537 (1st Dep't 2010) (citing People v. 854 N.Y.2d 43 EFTA00232710 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 EFTA00232711 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 EFTA00232712 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 EFTA00232713 legally insufficient under SORA. See, e.g. People u. 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 u. 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 u. Kelly, the U.S. Supreme Court held that, in relevant part, to demonstrate compliance with the procedural due process requirement 47 EFTA00232714 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 findings 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. I9 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 §§ 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 EFTA00232715 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 Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022 Telephone: Facsimile: Counsel for Defendant-Appellant Jeffrey E. Epstein EFTA00232716 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 EFTA00232717 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 P. efkowitz, P.C. Sandra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022 Telephone; Facsimile: EFTA00232718 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, Sandra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, Neiril4611 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, NYili 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 OBJECT OF THECAUSE 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 EFTA00232719 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, Ne i -4611 Telephone: Facsimile: Attorneys for Defendant-Appellant Jeffrey E. Esptein. -2- EFTA00232720 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. EFTA00232721 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 EFTA00232722 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 EFTA00232723 Un, 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 G. CASSELL Ronald N. Boyce Presidential Profes.f Criminal Law Telephone: cassellp@law.utah.edu September 29, 2011 Re: Follow-up on Jeffrey 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." OPR 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 OPR 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 111.11.City, Utah 84112-0730 EFTA00232724 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 WM, 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 left your office to work at a New York law firm representing white collar criminals. He also learned thai 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 =Is apartment, his role during the Epstein negotiations and his departure immediately after the NPA was signed, leads us to believe that l 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, Paul G. Casse cc: Assistant U.S. Attorney cc: Assistant U.S. AttorneyM • I 2 EFTA00232725 SJ.QUINNEY COLLEGE OF LAW THE UNIVERSITY OF UTAH 'Wifredo A. Ferrer United States Attorney Southern District of Florida. 99 N.E.4thStreet Miami, FL 33132 G. CASSELL Ronald N. Boyce Presidential Prol,t 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 20O6 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 Recarey and Police Chief Michael Reiter -- 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 orww.law.utah.eclu • Maio Office 1.11111 • Facsimile 332 South 1400 East, Room 1 1• At .a City, Utah 411.. EFTA00232726 deposition that Epstein's assistant, 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 im ro erl re resented people close to Epstein. During the federal investigation of Epstein, 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 pn 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, 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, 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 (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. 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, if anything, to fetterat anJ slateirtvestigater-s-sturing-the_crirninat 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 EFTA00232727 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 involvedin making important decisions abotit 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 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 Epsteln's victims (E) 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 yobr 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 mostiiral owered attorneys — namely Ken Starr and Lilly. Sanchez. Epstein settled the case wit 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 an t e e era ur a FBI wa.s_ratp,onsihic. 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 clearto us that thin' was consulted about this decision. Indeed, we have suspicions that the FBI was not informed of this decision until, perhaps, months later. 3 . EFTA00232728 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 NM. 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, Pau Cassel • 4 EFTA00232729 QUINNEY COLLEGE OF LAW THE UNIVERSITY OF UTAH March 1, 2011 Wifredo A. Ferrer United States Attorney Southern District of Florida 99 N.E.4th Street Miami, FL 33132 I. CASSELL Ronald N. Boyce Presidential Prof.f Criminal Law Telephone: Re: Jane Doe O. 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. Toda we had a telephone conference call with two of your attorneys, in . and 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 ossession 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 EFTA00232730 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 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. WithholdinR 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 EFTA00232731 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 "Coif-ricers 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 CVRAJ." 18 U.S.C. § 3771(c)(1) (emphasis added).1 It is simply impossible for I 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 fO fice represents the FBI on these issues, and are happyTo 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 EFTA00232732 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 EFTA00232733 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. dwards Sincerely, Paul Ci. 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 EFTA00232734 SEE (USAFLS) From: IIMI Cassell Sent: aindia rc t To: (USAFLS); , I. W I. (USAFLS) Cc: rdirrvards 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 so our pleading should not remain under seal — instead the public should have access to it so 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 so 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, IM 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.edu/orofiles/defaulLaso?Person1O=57&namp=cassell,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 EFTA00232735 Case 9:08-cv-80119-KAM 1 2 3 4 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, vs. JUNE 12, 2009 7 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 16 For Jane Doe 17 BRADLEY J. EDWARDS, ESQ. Rothstein Rosenfeldt Adler 18 401 East Las Olas Boulevard Port 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 23 RICHARD H. WILLITS, ESQ. 24 2290 10th Avenue North Lake Worth, FL 33461 25 For 1 TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00232736 Case 9:08-cv 80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 2 of 51 2 1 ROBERT JOSEFSBERG, ESQ. 2 Podhurst Orseck Josefsberg 25 West Flagler Street 3 Miami, FL 33130 For Jane Doe 101 4 (Via telephone) 5 KATHERINE W. EZELL, ESQ. Podhurst Orseck Josefsberg 6 25 West Flagler Street Miami, FL 33130 7 For Jane Doe 101 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 250 Australian Avenue South 13 West Palm Beach, FL 33401 14 As Amicas Cunie: , ESQ. 15 Assistant U.S. Attorney 500 East Broward Boulevard 16 Fort Lauderdale, FL 33394 For U.S.A. 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 HERB RPR-RMR-FCRR-AE 22 Official United States Court Reporter Federally Certified Realtime Reporter 23 400 North Miami Avenue, Room 8N09 Miami, FL 33128 24 25 TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00232737 Case 9:08-cv-80119-KAM 1 2 3 Document 180 Entered on FLSD Docket 06/24/2009 Page 3 of 51 THE COURT: We are here in the various Doe vs. Epstein cases. May I have counsel state their appearances? 4 MR. HOROWITZ: Adam Horowitz, counsel for plaintiffs 5 Jane 2 through Jane Doe 7. 6 THE COURT: Good morning. 7 MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane 8 Doe. 9 THE COURT: Good morning. 10 MR. GARCIA: Good morning, Your Honor. Sid Garcia for 11 Jane Doe II. 12 THE COURT: Good morning. 13 MR. WILLITS: Good morning, Your Honor. Richard 14 Willits, here on behalf of the plaintifflila. 15 THE COURT: Good morning. 16 MS. EZELL: Good morning, Your Honor. I'm Katherine 17 Ezell from Podhurst Orseck, here with Amy Adderly and Susan 18 Bennett, and I believe my partner, Bob Josefsberg, is going to 19 appear by telephone. 20 THE COURT: Mr. Josefsberg, are you there? 21 MR. JOSEFSBERG: I am, Your Honor. — 2 ThE Lutlxi: -Good morning. - 23 MR. JOSEFSBERG: Good morning. 24 THE COURT: All right. Do we have all the plaintiffs 25 stated their appearances? Okay. 3 TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00232738 Case 9:08-cv 1 2 3 80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 4 of 51 Defense? MR. CRITTON: Your Honor, Robert Critton on behalf of 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 4.4 which, as you all know, there s teen a motion by Mr. Epstein to 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 4 TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00232739 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 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 So 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: So 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 in Jam? -- 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 EFTA00232740 Case 9.08-cv-80119-KAM Document 180 EnteredonFLWDocket06/24/2009 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 reason I think the Court said I don't consider that to be a 15 pending proceeding or a proceeding at that particular time. 161 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 warranted. And what the court went -on to -say is 1_ iat it 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 EFTA00232741 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 7 of 51 7 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, so 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- 9,-sire-r1-1-indi-ct trim and-then he can-move to- digffter--ThaCrg-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 EFTA00232742 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 8 of 51 8 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 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 21I me and I know his mandate to his criminal lawyers, is: Make errata - T don -do anything, in -p 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 EFTA00232743 Case9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page9of51 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 --t -o- dts-ctors--.---Agathr, we think thars - not what- the- NPA--provitte-s, 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 EFTA00232744 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 10 of 51 10 1 this irreparable harm to Mr. Epstein under the circumstances. 2 In essence, we're left with a catch 22 in defending 3 the civil cases. We have a mandate to take no action, to take 4 any action which may be deemed to be a violation of the NPA, 5 either in the past or in the future, which would in any way 6 risk Mr. Epstein being indicted by the United States. 7 i He has the clear risk of an indictment based upon the 8 papers that the Government filed. It's real, it's not remote, 9 and it's not speculative. It chills the action of the defense 10 in this instance of both Mr. Epstein and his attorneys in 11 trying to defend these cases and decide under the circumstances 12 can we do this, can we take this position with regard to 13 depositions, can we take this legal position with regard to 14 motions to dismiss, with regard to responses, with regard to 15 replies? 16 And we send out paper discovery. Is this in some way 17 if we contact someone who may be an associate of these 18 individuals as part of our investigation, is that potentially 19 in any way a violation of the NPA? Again, we don't think so. 20 And, obviously, again, my direction has been from my 21 client: Don't take any action that would result in me being indicted under the NPA. Well, La `is great. But, yeueLatly, 23 civil lawyers or civil lawyers in defending a personal injury 24 case or a tort case, which is exactly what these are, and from 25 a practical standpoint, we use various tools to do discovery. TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00232745 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 11 of 51 11 1 They're standard. They're specific. They're very Lemporary. 2 Very typical. 3 I 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 so we can 7 obtain documents unless we have to filter it through the 8 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, and then they take a substantial -position is we- thin 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 EFTA00232746 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 12of51 12 1 in the question is, is can he defend these cases? That's what 2 I really want to know. Can he defend these cases and, in 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 N?A, 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 -unilateral, -which is the issue L1 at we argued - 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 EFTA00232747 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 13 of 51 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. --rtirr -Onty-concerned—about—wnether-anyL Li-acmes In 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 EFTA00232748 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 14 of 51 14 1 even ask the Government to give you an assurance that he hasn't 2 done anything that might have violated the agreement up till 3 today. I'm only interested in defending these civil actions. 4 i 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 bulk? 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 1 4 on in. And that's another issue that we have to deal with. 15 So 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 iced -del:it:raj-trans or not in thts -case but rf—your 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 TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00232749 Case 9:08-cv-80119-KAM 1 2 3 Document 180 Entered on FLSD Docket 06/24/2009 Page 15 of 51 in the context of this case been brought to your attention as a potential violation? 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 So what was it that caused you to make that initial /2 -assertion? — Because—tharntrat caug it my d tynti n, warTiOt- -- 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. 15 TOTALACCESSCOUUROOMNEM0RKREMJIMETWISCRIVI1ON EFTA00232750 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 16 of 51 16 1 So 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: So 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 ow the-Court doesn't want to—ge 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 EFTA00232751 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 8 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 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, so 30 times 150, or should be, or whether 20 it's 150, that's the amount of money that we want, so maybe $15 21 million, or whatever the number is. - Some- of- the other -plaintifts' lawyers--h￾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 EFTA00232752 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 18 of 51 18 1 consider to be, or that we will argue are violations, then we 2 can take 20 times the SO, or the 150, depending on which 3 statute is applicable. 4 So 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, so we raised that - i -ssund then- when the veLumeu 4-s L apuflue Lame- w. 1 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 TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00232753 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 19 of 51 19 1 ability to move forward. Thank you, Your Honor. 2 THE COURT: Thank you. Who wants to be heard from the 3 plaintiffs first? 4 Is there any plaintiff's attorney who is contending 5 that the defense of these civil actions by Mr. Epstein is going 6 to constitute a breach of the non-prosecution agreement? 7 MR. JOSEFSBERG: Your Honor, this is Bob Josefsberg. 8 i, May I speak? 9 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 invasive of- the- privacy of someone, and-they are—rel 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 EFTA00232754 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 20 of 51 20 1 to the agreement that I am a beneficiary of. One of them is 2 that he has agreed that on any action brought in the 2255, he 3 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 -opposite -of—the NPA. 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 EFTA00232755 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 21 of 51 2 1 2 3 4 5 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 23 24 25 come forward. We were appointed by Judge as a Special Master to represent these young ladies. And some of them don't even want to file suit. They don't even want to be known as Jane Doe 103. They don't want any of the risks for these motions that are pending. And part of the agreement was that if we represented them and they settle, Mr. Epstein would pay our fees. And he has written us as of yesterday that he is under no obligation to pay our fees on settling cases. Now, those two matters, I believe, may be breaches. But I am not asking this Court at this time to do anything about them. Nor am I telling the Government, I'm not running to the Government and saying indict him because I want you to pressure him to do what he agreed to. I'm a third-party beneficiary for that agreement, and I may move to enforce certain parts of it. But as far as the issue of staying the litigation, that is the exact opposite of the intent and the letter of the NPA. The purpose of the NPA was so that these 34 young ladies, these victims who have been severely traumatized, may move on with their lives. 74nd -tostay this—action—would be tie—exact the purpose of that agreement and would be horrible psychologically for all of my clients. THE COURT: Mr. Josefsberg, I understand your TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00232756 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 So 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-1 ikgr-t-have -a-prohlem: -Rut it frets￾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 EFTA00232757 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 23 of 51 23 1 MR. JOSEFSBERG: Your Honor, you're totally correct. 2 He can depose my client. That's not a problem. But the 3 problem is that these are not typical clients and this is not a 4 typical case. He has written in his pleadings that he wants to 5 publish the names of these girls in the newspapers so that 6 other people may come forward to discuss their sexual 7 activities with these different plaintiffs. That's not your 8 typical case. But are rulings that you'll make in this case, 9 and they're not part of the NPA. 10 As far as my going to the Government is concerned, I 11 find it very uncomfortable for me to use the Government to try 12 to pursue my financial interest in litigation. And I know that 13 Mr. Epstein and his counsel will make much ado about it. So I 14 am not going to be running there. 15 However, if they start taking depositions regarding 16 liability, I will consider that to be a breach because they're 17 supposed to have admitted liability. 18 THE COURT: But, again, I don't have the agreement and 19 I don't remember reading the agreement. But what I'm being 20 told is the part of the agreement that admits liability is only 21 as to a 2255 claim, and there are numerous other personal ink ry tort claims other than 2257 claims. 23 And there's a limit of damages on the 2255 claim, as I 24 understand it, but I presume that all the plaintiffs are going 25 to seek more than the limited or capped amount of damages in TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00232758 Case 9:08-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 so 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 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 22 /fly. I - there - woutd- no- need- to- starthir-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 EFTA00232759 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 25 of 51 25 1 way that is proper under the Rules of Evidence and your 2 rulings. The NPA has no limitation on his contesting damages 3 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 -Honor, -would-tre -be-posting-a_ band? 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 EFTA00232760 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. So, 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 i 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 III'S... 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, , 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 future. 23 I want to point out to the Court that Mr. Epstein went 24 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 EFTA00232761 Case 9:08-cv-801 19-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 27 of 51 27 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 23 24 25 didn't know it, his lawyers knew it. He appears to be having second thoughts now about he could have negotiated this way or he could have negotiated that way with the U.S. Attorney's Office. And they want to impose Lbeir second thoughts on the innocent plaintiffs. We don't think that's fair. We think it's in the nature of invited error, if there was any error whatsoever. Thank you. THE COURT: Ycu agree he should be able to take the Drdinary steps that a defendant in a civil action can take and nct be concerned about having to be prosecuted? MR. WILLITS: Of course. And we say the same thing Mr. Josefsberg said. It's all subject to your rulings and the direction of this Court as to what is proper and what is not proper. And we're prepared to abide by the rulings of this court, and we have no intention of running to the State's Attorney. THE COURT: The U.S. Attorney? MR. WILLITS: I'm sorry. The U.S. Attorney. THE COURT: Mr. Garcia. MR. GARCIA: Thank you, Your Honor. If--I may—briefly, I tl.a„kperhaps defense-counsel forgot about this, but on pages 17 and 19 of my memorandum of law in opposition to the motion to dismiss, I did make reference to the non-prosecution agreement, and I did say that TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00232762 Case 9:08-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 13 14 15 16 17 18 19 20 21 2 23 24 25 the contesting of the jurisdiction of this Court was a potential breach of the non-prosecution agreement. So 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. So to the extent that I raised this issue with defense counsel and the Court, I'm going to withdraw that aspect of it. THE COURT: Can you file something in writing on that point with the Court? MR. GARCIA: Yes. THE COURT: What do you say about this issue that we're here on today? MR. GARCIA: I think that the problem that I have with it is that this non-prosecution agreement is being used by defense counsel for the exact opposite purpose that it was intended. My perception of this thing, and I wasn't around, is titancEp -ste n --exam prosecution, which is wonderful for the victims in a way, and wonderful for him, too. Now he's trying to use the non-prosecution agreement TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00232763 Case9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 29 of 51 29 1 as a shield against the plaintiffs that he was supposed to make 2 restitution for. 3 And, certainly, he can take my client's depo. He's 4 done extensive discovery in the state court case -- very 5 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, ne- Doe-2 through- 7, have elected to--bring additton 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 TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00232764 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 30 of 51 30 1 it, it doesn't relate to our clients. 2 THE COURT: Okay. But, again, you're in agreement 3 with everyone else so 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? 101 Ms. , if you would be so 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. 1511 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. So 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 22 -the-case--films 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 TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00232765 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 31 of 51 31 11 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. -And so our idea was, our hope was that we 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 EFTA00232766 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 So we did through the non-prosecution agreement tried 7 to protect their rights while also protecting their privacy. 8 So, 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 So 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 So 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 EFTA00232767 Case 9:08-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. So 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. 22 .-THE—COURT-r ism 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 EFTA00232768 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 34 of 51 34 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 we had filed that response. And what we said in the response to the motion to stay is that the reason why he wants to stay the litigation is so that the non-prosecution agreement terminates based on a period of time, as he puts it. And then afterwards he would be able to come in here and make all of these arguments that clearly violate the non-prosecution agreement but we would be without remedy. THE COURT: But you're not taking the position that other than possibly doing something in litigation which is a violation of an express provision of the non-prosecution agreement, any other discovery, motion practice, investigations that someone would ordinarily do in the course of defending a civil case would constitute a violation of the agreement? MS. : No, Your Honor. I mean, civil litigation is civil litigation, and being able to take discovery is part of what civil litigation is about. And while there may be, for example, if someone were to try to subpoena the Government, we would obviously resist under statutory reasons, all that sort of stuff. But, no, Mr. Epstein is entitled to take the deposition of a plaintiff and to subpoena records, etc. - THE COURT: Ahd even if he seeks discovery rOM a Government agency, you have the right to resist it under the rules of procedure but that would not constitute a violation, again unless there's a provision in the prosecution agreement TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00232769 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 1 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 /wry: 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 EFTA00232770 Case9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page36of51 1 102 is a perfect example that he filed is, we have 2 e-mails going back and forth between the Government and my 3 clients' attorneys at the time that suggested that 102 probably 4 doesn't even fit within the statute of limitations. 5 I So under Mr. Josefsberg's argument is as well, we've 6 only brought a 2255 claim. We don't care whether she's within 7 or is outside the statute of limitations. Because she was on 8 the list and under the circumstances, he has to admit 9 liability, which we contest is under that set of circumstances 10 you're stuck with it. You can fight damages if you can, but 11 she's a real person and you can't raise statute of limitations. 12 The other point that kind of strikes out is there's 13 probably a difference. And I'm happy to provide a copy of the 14 NPA or a redacted portion of the NPA which deals with the civil 15 issues, which are paragraphs 7, 8, 9 and 10, and the entire 16 addenda in camera for the Court to look at, if plaintiff's 17 counsel and the Government, I guess, really, because they're 18 not a party, is if they have no objection because they all have 19 access based on a prior court order to the non-prosecution 20 agreement. 21 So I'm happy to provide that to the Court today and show it to counsel so that the Court can review that. 23 But our position with regard to the 2255 claims is 24 that -- there were two types of claims that could be filed, one 25 was consensual litigation, the second was contested litigation. TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00232771 Case 9:08-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 might be a violation. 18 MR. CRITTON: I agree. 19 THE COURT: So you would know that when you filed your 20 motion because it was right there for you to read. 21 And so to stay the case because I want to do something 22 that t e contract express y pro i•its me mom ffeirTg7 so stay 23 the case until the agreement expires so then I can do something 24 that the agreement said I couldn't do so 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 EFTA00232772 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page38o151 38 1 about. 2 I'm concerned about discovery, investigation, motion 3 1 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 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 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 /'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 in erpre a ion o e agreement, an• 23 believe me, we would not have filed 101, the motion to dismiss, 24 but for believing that there was a good faith basis to do that 25 under the circumstances. TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00232773 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 39 of 51 N 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. So does that mean that on 101 we have to back 8 off of it because we think in good faith 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, ah, 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. Ah, 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. Those are the -kind of things that I was worried about. 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 NETWORK REALTIME TRANSCRIPTION EFTA00232774 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 40 of 51 40 1 has raised. But part of it is that often cases are disposed of either on a summary basis or certainly legal issues that come before the Court during the course of the case, just like in a criminal case. That's clearly part of the, I'd say the defense of the case under the circumstances; and if, in fact, an individual can't legally bring a cause of action for certain reasons, such as has been suggested in 101, and may be suggested in 102 when that pleading is filed, that certainly is a position that puts my client at risk. As another example that I use with ., that they filed this 30-count complaint. Now, they have the state court claims as well. But they, in essence, have said they filed another pleading with the Court that says depending on what the Court rules, in essence, on whether we can file multiple claims 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 or one cause of action with the state court claims and, multiple violations, we may dump therefore, we'll just ride along on that. That's a very different -- Mr. Epstein would never have entered into, nor would his attorneys have allowed him to enter into that agreement under those circumstances where he had this unlimited lability. That clearly was never envisioned-by any of 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 EFTA00232775 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 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 not going to comment abraft it. But please don't take our lac 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 EFTA00232776 Case 9:08-cv-801 19-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 42 of 51 42 1 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NPA. I think that many of the questions you asked will be answered when you read the NPA, and I think it's very unfair of everyone who is sitting in front of you who have the NPA to be discussing with you whether it's being breached, whether there should be a stay when you're not that familiar with it. If we would give you a copy of it, I think it would be much more helpful in making your ruling. THE COURT: Maybe Judge Colvat will resolve this issue for me. MR. JOSEFSBERG: Even if he doesn't, Your Honor, : believe we are allowed to show it to you. THE COURT: I'll tell you what: I'll wait for Judge Colvat to rule, and then if he rules that it should remain sealed, then I'll consider whether or not I want to have it submitted to me in camera. Anything else, Mr. Josefsbcrg? MR. JOSEFSBERG: No. I thank you on behalf of myself_ and the other counsel on the phone for permitting us to appear by phone. THE COURT: All right. Anyone else have anything they want to add? FITC-EDWARD ra war s on e a ane oe. I only had one issue here, and when I read your motion Lhat you wanted to hear on the narrow issue of just defense in the civil actions filed against him violates the TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00232777 Case9:08-u-801194(kM Document 180 Entered on FLSD Docket 06/24/2009 Page43of51 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 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. Milt there 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 specific allegations that the U.S. Attorney's Office is TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00232778 Case9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page44of51 44 1 threatening a breach, and this is part of the motion to stay, 2 which we're all battling here. 3 So I just wanted to indicate to the Court or remind 4 the Court that there have been specific allegations made, the 5 United States Attorney's Office is making these allegations of 6 i breach, which we haven't heard any of the evidence of. 7 Thank you. 8 THE COURT: All right. 9 Ms. , did you want to respond to that 10 suggestion that there were other allegations of breach besides 11 the one that you've just mentioned today? 12 i MS. : No, Your Honor. 13 THE COURT: Thank you. I appreciate your giving me 14 the information, which I think has been very helpful today, and 15 I'll try and get an order out as soon as possible. 16 [Court adjourned at 11:10 a.m.]. 17 CERTIFICATE 18 I hereby certify that the foregoing is an accurate 19 transcription of proceedings in the above-entitled matter. 20 s/Larry Herr 21 DATE LARRY HERR, RPR-CM-RMR-FCRSC 22 Official United States Court Reporter 400 N. Miami Avenue 23 24 25 Miami, FL 33128 - email: (Fax) Quality Assurance by Proximity Ungulbase Technologies EFTA00232779 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 45 ofp5i c 4 A abide 27:15 ability 18:8 19:1 able 20:14 27:9 32:18 34:5,15 about 4:24 5:25 6:10 6:18 92 11:15 13:22 20:25 21:13 23:13 25:23 27:2 27:11,23 28:16 30:24 32:2,2,3 34:16 38:1,2,7,15 38:19 39:12,12,20 39:22 41:20,21,22 41:23 above 25:3 above-entitled 44:19 Absolutely 29:11 access 30:19,19 36:19 according 1921 accurate 44:18 accused 22:23 38:16 39:1,2 action 7:13 8:5 9:8 10:3,4,9,21 11:18 15:4 17:24 18:17 20:2 21:22 27:10 2923 40:7,16 43:8 actions 52513:23 14:3 16:11 19:5,17 22:16 25:4 42:25 activities 23:7 acts 9:11,1237:14 actual 41:18 actually 521 17:9 Adam 1:13 3:4 29:13 add 29:5 35:7 42:21 addenda 36:16 Adderly 3:17 additional 29:22 address 29:15 addressed 33:15 adjourned 44:16 Adler 1:17 admit 20:3,18 25:11 3223 36:8 admits 23:20 admitted 23:17 24:9 41:19 ado 23:13 advantage 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322 A 1:21,23 2:12 2:23 44:22 aware 6:6 13:14 15:4 a.m 44:16 B back 12:18 36:2 39:7 backgrounds 3921 balance 12:15 bank 32:10 based 6:12 10:7 12:6 13:11 17:4 34:4 36:19 3822 basically 7:16 13:10 39:5 basis 33:9 38:24 40:3 battling 442 Beach 1:2,4,212:10 2:13 before 1:11 6:5 15:13,18 24:10,11 24:13 40:4 behalf 3:14 4:2,6 6:7 14:16 22:10 26:10 26:15 30:3 39:3,4 42:17,22 being 9:17 10:6,21 23:19 26:4 28:19 29:19 34:15 39:1 41:23 42:4 believe 3:18 5:10,10 5:14,166:17,1721 7:13,19 8:11 14:18 21:11 31:1,5 332 33:5,13 37:6 3823 42:11 believes 35:11 believing 38:24 beneficiaries 19:12 beneficiary 20:1 21 16 25:15 Bennett 3:18 besides 44:10 between 8:6 9:23 13:1,21 19:14 20:11 36:2 beyond 13:16 Biscayne 1:14 Bob 3:1819:7 Boehringer 1:20 bond 25:22 Boston 2:18 both 10:10 16:25 35:11 bought 28:22 Boulevard 1:14,17 2:15 Brad 1.7 42:22 BRADLEY 1:16 breach 6:1,23 15:11 16:3 18:24 19:6,13 23:16 259,9 28:2 29:24 30:5 31:1,6 31:10 33:13,20 37:7 38:8 39:2,19 44:1,6,10 breathed 7:1912:24 1520 22:1142:4 43:6 breaches 7:15,17 19:11 21:11 22:16 43:22 breaching 22:1920 22:23 39:21 brief 15:18,23 briefing 5:4 briefly 27:22 bring 29:2240:7 broad 29:17 brought 15:1 202 24:17,20 28:6 32:4 36:6 37:13,16 43:17 Broward 2:15 brush 29:17 buffer 12:25 Burman 2:8,9 4:3 38:9 business 13:25 C C 2:144:17,17 came 6:5 12:18 17:6 18:22 33:25 43:20 43:24 camera 36:16 42:15 cap 32:21 capped 23:25 care 13:20,25 25:20 29:5 36:6 case 1:3 5:17,20,21 522 6:4,7 8:12 9:11 10:24,24 11:4 11:15,18 13:18,20 14:18,22 15:1,18 16:2 19:17 22:17 22:25 23:4,8,8 24:17,20 26:3,4 28:10 29:4,6,9 30:4,22 33:5,6 34:13 37:21,23 39:13 40:4,5,6 cases 3:2 6:9 7:3,11 8:13,22 9:3,5,5,15 10:3,11 12:1,2 14:9 17:15,16 21:10 24:8,11 26:2 29:18 30:12 33:17 379 40:2 casts 9:13 catastrophic 7:21 catch 7:21 10:2 caught 15:22 cause 17:24 18:17 26:5 40:7,16 caused 15:21 causes 2922 cavalierly 12:13 certain 8:22 11:18 17:2,6 21:17 25:16 40:7 certainly 8:16 9:1 EFTA00232780 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 46 ofp 46 29:3 40:3,9 Certified 2:22 committed 31:17 communications course 7:5 24:25 2621 27:12 30:4,6 .21:2 35:15 ay 3:4 39:19,25 discretionary 6:19 certify 44:18 43:13 30:163224,25 dea19:23 14:13,14 6:21 change 7:25 complainants 17:9 33:1 34:12 39:13 15:15 16:24,24 discuss 9:22 23:6 changes 7:8 complaining 25:11 40:4 18:6,9 discussing 42:4 charges 53 26:19 court 1:1 2:22 3:1,6 deals 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 5:24 6:6,11,13,14 decision 39:11 33:5,8,25 37:13,16 chosen 29:21 comply 41:10 6:18,20,21,227:6 decisions 38:12,14 38:23 circumstance 7:21 concern 4:24 5:10,24 8:1 9:6 113,10,25 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 26:139:23 14:5,11 15:5,13,15 defend 525 10:11 distinct 7:9 10:1,11 12:11,20 concerned 1322 16:10,13,22192,9 11:18 12:1,222:17 DISTRICT 1:1,1,11 1221 13:8,13 16:8 23:10 27:11 37/5 21:12,2523:18 22:18,22,2524:2 DIVISION 12 16:17 17:3,8,13,18 38:2,15,19 39:12 252326:1,8,13,17 26:3 docket 6:17 8:25 18:19 32:14 35:25 39:12 26:18,23 279,14 defendant 1:8 2:8 12:14 36:8,9 38:25 39:7 concerns 6:24 27:16,18,2028:1,4 6:23 11:13 16:16 documents 11:7 40:6,21,24 conduct 22:14 28:4,11,13,14,16 22:15,1827:10 14:24 dte 17:10 conducting 22:13 29:4,8,12 30:2,8 40:23 Doe 1:4,15,18,222:3 civil 4:23,25 5:25 7:3 30:5 39:13 30:16 32:22 33:22 defendants 25:5 2:7 3:1,5,8,11 5:17 73,11 8:5,22 9:4,7 confident 19:10 34:8,22 35:3,5,7 40:23 6:8,9,16 11:12 9:11 10:3,23,23 consensual 16:25 36:16,19,21,22 defendant's 16:23 21:5 29:14,22 33:5 13:23 14:3,9 15:7 36:25 37:1 37:4,6,19 39:9,10 defending 425 7:24 35:13 4222 16:5,11 19:5 20:20 consider 6:14 18:1 39:25 40:4,12,14 9:4 102,23 13:18 doing 8:9 29:9 34:9 22:14 26:25 27:10 23:16 3524 42:14 40:15,17 41:8,15 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35:2 different 6:5 12:21 enforce 21:17 25:17 come 8:8,13 13:11 correspondence D 16:19 23:7 40:18 enforcement 7:2 21:1 23:632:13 30:21 I) 1:13 2:8 direction 10:20 enforcing 25:10 34:5 40:3 counsel 3:3,4,7 12:7 damages 17:3 23:23 27:14 enter 40:20 comes 18:12 16:5 23:13 26:8,25 23:25 24:3,10,24 disadvantage 30:18 entered 33:12 40:19 coming 26:25 27:22 28:11,20 25:2 31:20 32:23 disagree 20:5,21 entire 5:15 20:25 comment 41:22 29:13 36:17,22 32:24 33:9 36:10 discovery 7:2,10,11 36:15 comments 15:10 42:18 43:8 10:16,2522:12 entitle 11:23 35:11 41:14 count 24:14 date 13:12,14 44:21 29:4 30:5,21 33:1 entitled 24:2 31:16 commitment 172 counts 17:17 41:8 Baton 1:21 34:11,16,22 38:2 32:25 33:1 34:20 _, _ _ EFTA00232781 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 47 o entry 6:17 8:25 12:14 enumerated 18:8,9 envisioned 40:22 Epstein 1:7 3:1 43,6 4:22 6:7 7:13,15 7:19 8:6,20 9:15 9:18,24 10:1,6,10 12:5,15 13:17,21 14:8 17:9 19:5,14 19:16 20:11,13 21:8 23:13 24:21 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1:24 2:13 1:22 2:10 6 6 1:18 2:19 7 71:18 3:5 29:14,22 36:15 8 36:15 8N09 2:23 9 9 3 6: 1 5 2:16 1:19 EFTA00232786 tli 5.1 QUINNEY COLLEGE OF LAW N 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: 801-585-5202 cassellp@kw.utah.edu 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 Recarey and Police Chief Michael Reiter -- 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 94112-0730 EFTA00232787 deposition that Epstein's assistant, a 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 dose to Epstein. During the federal investigation of Epstein, 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, 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, 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 (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. 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 —luew-vvtrat-evidence-the attorneys-fef the-victims Were-licit-1g HP also knew what 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 EFTA00232788 example, Florida R. Prof. Conduct 4-1.11(a) provides "la) 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 inia 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 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. • 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 ISh-powered - attorneys — namely Ken Starr and Lilly. Sanchez. Epstein settled the case with 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. ourth, fere aywe Ts-to-have-been-an unprecedented 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 EFTA00232789 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 NM. 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 EFTA00232790 EFTA00232791 U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 IVest Palm Beach. FL 33401 (561) 820-8 Facsimile: December 5, 2008 VIA ELECTRONIC MAIL Brad Edwards, Esq. 2028 Harrison Street, Suite 202 Hollywood, Florida 33020 Re: JefTr E teir 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, 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 have any questions regarding the work , please direct your inquiries to Captain David Sleeth, Palm Beach Sheriff's By: Sincerely, R. Alexander Acosta United States Attorney ssistant Attorney EFTA00232792 U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 h FL 33401 Facsimile: December 11, 2008 VIA HAND DELIVERY Captain David Sleeth 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 Sleeth: 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 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. gligibility 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 EFTA00232793 CAPTAIN DAVID SLEETH 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 *u y Richard Kahn lists Mr. Kahn's and the Foundation's telephone number as ' C1 ." 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 EFTA00232794 CAPTAIN DAVID SLEETH 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)(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. #926.01(V)(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/FinDoctunents/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 umentsi2004, i33/996/2UU4-133W6471-1-r.pcIf 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://wwvv.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 EFTA00232795 CAPTAIN DAVID SLEETH 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 Sheriffs 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? 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 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. lndyke lists his true address in Livingston, New Jersey. EFTA00232796 CAPTAIN DAVID SLEETH DECEMBER 11, 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 Michael Gauger Chief, Northern Division I EFTA00232797 EFTA00232798 U.S. Department ofJustice United States Attorney Southern District of Florida VIA HAND DELIVERY Captain David Sleeth Palm Beach Sheriff's Office Corrections Division 3228 Gun Club Road West Palm Beach, FL 33406 .500 South Australian Ave., Suite 400 each, FL 33401 Facsimile: December I I, 2008 Re: Work Release Application of Jeffrey Epstein Dear Captain Sleeth: 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 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 P135O. 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 /9b.0 I, and in his Alternative Custody Program Placement Synopsis," Mr. hpstem 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 EFTA00232799 CAPTAIN DAVID SLEETh DECEMBER 11, 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 'u by 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 intemet, I located the IRS returns of "The C.O.U.Q. Foundation, Inc." for fiscal years 1999 through 2006 (which covers the period EFTA00232800 CAPTAIN DAVID SLEETH DECEMBER I I, 2008 PAGE 3 through 2/28/07).1 These sworn filings show that Mr. Epstein worked for the Foundation for only one hour per week and earned no compensation. (S 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/2005/133/996/2005-133996471-02056acf-F.pdf r Y2003: nttp://www.guldestar.orgik muocuments/2004/133/996/2004-133996471-1-F.pdf FY 2002: hup://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 FYI999: 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 EFTA00232801 CAPTAIN DAVID SLEETH 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. 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 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 2On 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. EFTA00232802 CAPTAIN DAVID SLEETH DECEMBER 11, 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 Attorne By: Assistant United States Attorney cc: Colonel Michael Gauger Chief, Northern Division I EFTA00232803 FBI PALM BEACH COUNTY RA JEFFREY E. EPSTEIN 3 1E-MM EFTA00232804 EFTA00232805 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 OPEN / ACTIVE TRYLCH, JEFFREY OREGERO, LAURA *********VEHICLE I N FAMILY Map Reference Report Officer Case Status Dt 3/14/05 4/06/05 Property? . . Offenses? . . Related Cases? FORMATION # 10 PAGAN, MICHELE 3/14/05 1 ********************* Case number . : State Veh Type : 1-05-000368 Category . . . Year 0 Make • Model Name . . : Style Color Bottom : VIN Model Permit Number Color - Top . License # . . Stolen value . 0 Dir Isition Ins_red by . Vehicle locked : Date recovered : Insured . . . Keys in car . Lein holder . 0/00/00 Recovery value 0 Street number : City Recovery code : Be On Look Out?: NCIC number . ********* P E R S O N R E P O R T I N G INFO - #1 ********* Case Number . : 1-05-000368 Street Number : City Birth Date/Age Occupation . . Home Phone No. Sex Weight ************** S Case Number . : Street Number : City ROYAL Birth Date . . Employer? . . : Ope•• Lic NO. . Ott : Phone Nbr: Sex Female Minimum Weight : 0 • WEST PALM • Female • 0 Last Name . . BEACH, FL 33412 Employer? . Oper Lic No. Race Height Other Phone Nbr: • White • 0 USPECT/ARRESTEE IN 1-05-000368 Prompt valid FORMATION in: PALM BEACH, FL 334121460 18 Maximum Age . : 18 Occupation . . : FL Home Phone No. : Race White Minimum Height : 0 Maximum Height : 0 FL # 1 ** EFTA00232806 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 2 Incident Report Program: CMS301L Casa 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 . • Other Phone Nbr: Sex Mir'mum Weight : Ma). sum Weight : Aliases') Hair Color Hair Style Glasses . . . . . . . : : : Hair Length Eye Color Complexion Facial Hair Teeth Hat Shirt Shoes . : • • Build Speech Coat Pants Body Marks #1 : Body Marks #2 : Body Marks #3 : Body Marks #4 : Status STILL SUSPECT Arrest Case No.: 1-05-000368 0 (Continued) 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?: USPECT/ARRESTEE INFORMATION- # 2 ** 1-05-000368 Prompt valid in: 358 EL BRILLO WY PALM BEACH, FL 000033480 25 Maximum Age Occupation . . Home Phone No. 111111001. Race Female 0 0 Minimum Height Maximum Height Misc. ID# . MO/Crime Spec? 25 PERSONAL ASST/EPSTEIN 0 0 ************** S Case Number . : Street Number : City Birth Date . . : Employer? . . : Oper Lie No. 1 Other Phone Nbr: Sex Minimum Weight Maximum Weight Al sea' Hair Color . . Hair Style . . Additional UCR? : USPECT/ARRESTEE INFORMATION- # 3 ** 1-05-000368 Prompt valid in: EPSTEIN, JEFFREY 358 EL BRILLO WY PALM BEACH, FL 000033480 52 Maximum Age Occupation . Male 0 0 -FL me Le No; Race Minimum Height Maximum Height Misc. ID# . . MO/Crime Spec? Hair Length . Eye Color . . : 52 White : 0 : 0 EFTA00232807 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 3 Time: 8:47:53 incident Report Program: CMS301L Case No • 1-05-000368 Glasses . . . : Facial Hair . : Teeth Hat Shirt Shoes Body Marks #2 : Body Marks #4 : Arrest Case No.: ************** Case Number . : 1-05-000368 Prompt valid in: Street Number City • WEST Birth Date/Age : Occupation . . : STUDENT Home Phone No. : 561 Sex Weight 0 Be On Look Out?: Victim Type . : JUVENILE Residency Sts : Car Identify . : In; ry Extent : Injury Type 2 : Med Treatment : Phys Last Name : ICTIM ************** V Case Number . : Street Number : City Birth Date/Age : Occupation . . : Home Phone No. : Sex Female Weight 0 Be On Look Out?: Victim Type . : ADULT Residency Sts Can Identify . Injury Extent Injury Type 2 : -Med-Treatment Phys Last Name : ************** Caste Number . : 1-05-000368 St. Number : City • PALM BEACH, FL 000033480 Birth Date/Age : VICTIM Employer? ICTIM 1-05-000368 Complexion Build Speech Coat Pants Body Marks Body Marks Status Additional UCR? INFORMATIO PALM BEACH, FL 33412 (Continued) STILL SUSPECT N - # 1 ******************** 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 -# 2 ******************** Prompt valid in: PALM BEACH FL 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: INFORMATION - # 3 ******************** Prompt valid in: • EFTA00232808 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 4 Incident Report Program: CVIS301L Cass.: No • 1-05-000368 Occupation Home Phone No. : 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 : ************** VICTIM Case Number . : 1-05-000368 Street Number : City PALM BEACH, Birth Date/Age Occupation . . Home Phone No. Sex ▪ Female Weight • o Be On Look Out?: Vir'lm Type . Re= lency Sts Can Identify . Injury Extent Injury Type 2 Med Treatment Phys Last Name ************** : JUVENILE VICTIM Case Number . : 1-05-000368 Street Number : City • PALM BEACH Birth Date/Age Occupation . . : Home Phone No. : Sex • Female Weight • 0 Be On Look Out?: Victim Type . : ADULT Residency Sts : Can Identify . : Injury Extent Injury Type 2 : Med Treatment : Phys Last Name : ** .*********VICTIM Case Number . : 1-05-000368 Prompt valid in: 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: (Continued) INFORMATION -# 4******************** Prompt valid in: FL 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: INFORMATION -# 5 ******************** Prompt valid in: FL 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 INFORMATION -# 6******************** EFTA00232809 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 5 Incident Report Program: CMS301L Casc No • 1-05-000368 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 ************** PALM BEACH, FL 000033480 Employer? . Oper Lic No. Race White Height 0 0 Misc. ID# . . Other Phone Nbr: JUVENILE Residency Type : VICTIM Case Number . : 1-05-000368 Street Number : City PALM Birth Date/Age : Occupation . . Home Phone No. Ser • Female Wei .it 0 Be On Look Out?: Victim Type . : Residency Sts : Can Identify . : Injury Extent : Injury Type 2 : JUVENILE Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Med Treatment : Phys First Name: Phys Last Name : ************** CTIM INFORMATION -# 8******************** Case Number . : 1-05-000368 Prompt valid in: Street Number : City Birth Date/Age : Occupation . . : Home Phone No. : PALM BEACH. FL 000033480 Employer? . Oper Lic No. Race White Sex Female Height • 0 Weight Be On Look Out?: 0 Misc. ID# . Other Phone Nbr: Victim Type . : Residency Sts : JUVENILE- Residency Type . File Charges . : Can Identify . Injury Extent : Injury Type 2 Met reatment : Phys Last Name : . : File Charges . : Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: (Continued) INFORMATION -# 7******************** Prompt valid in: BEACH, FL 000033480 Employer? . Oper Lic No. Race White Height 0 Misc. ID# . . Other Phone Nbr: **************VICTIM Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: INFORMATION -# 9******************** EFTA00232810 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 : 1-05-000368 1-05-000368 PALM BEACH FL ************** Case Number . : Prompt valid in: Street Number : City Birth Date/Age : 0c, ,at ion . . : 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 Female 0 JUVENILE VICTIM ************** 1-05-000368 PALM BEACH, FL Female 0 JUVENILE VICTIM Case Number . : 1-05-000368 Street Number : City • PALM BEACH Birth Date/Age Occupation . . : Home Phone No. : Sex Female -Weight . . . • : 0 Be On Look Out?: Victim Type . : ADULT Residency Sts : Car Identify . : In ry Extent : Injury Type 2 : Med Treatment : 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: . : (Continual, INFORMATION -# 10 ******************* 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: . : . : INFORMATION - # 11 ******************* Prompt valid in: FL 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: EFTA00232811 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 7 Incident Report Program: CMS301L Cast No • 1-05-000368 Phys Last Name : ************** V Case Number . : Street Number : City Birth Date/Age : Occupation . . Home Phone No. Sex • Female Weight • 0 Be On Look Out?: Victim Type . : Residency Sts : Can Identify . : Injury Extent : Injury Type 2 : Med Treatment : Phys Last Name : ************** Case Number . Street Number : Cit Bil_A 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 . : Re: lency Sts : Can Identify . : Injury Extent ICTIM 1-05-000368 PALM BEACH ADULT (Continued) INFORMATION -# 12 ************* Prompt valid in: FL 000033480 ICTIM 1-05-000368 PALM BEACH. FL Female 0 JUVENILE ICTIM 1-05-000368 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: INFORMATION - # 13 ******* ****** ****** Prompt valid in: PALM BEACH. FL 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: INFORMATION -# 14 ******************* Prompt valid in: S61/OOO-04O8- --- Female 0 JUVENILE 000033480 Employer? . . : Oper Lic No. . : Race Whit Height 0 Misc. ID# . . : Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 : EFTA00232812 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 8 Incident Report Program: CMS301L Cas.. 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 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 PALM BEACH ************** V Cas- Number . : St]. .t Number : City Birth Date/Age : Occupation . . : Home Phone No. : Sex Fema Weight • 0 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 . Look Out?: Victim Type . : Residency Sts : ADULT ICTIM 1-05-000368 PALM BEACH e JUVENILE ICTIM 1-05-000368 PALM BEACH • Female • 0 JUVENILE (Continued) Hospital ID . : Phys First Name: INFORMATION -# 15 ****** ****** ******* Prompt valid in: FL 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: INFORMATION - # 16 ******************* Prompt valid in: FL 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: INFORMATION -# 17 ****** ***** ******** Prompt valid in: FL 000033480 Fmployer' Oper Lic No. . : Race White Height • 0 Misc. ID# . . Other Phone Nbr: Residency Type File Charges . : EFTA00232813 Date: 7/25/06 Time: 8:47:53 Incident Report PALM BEACH POLICE DEPARTMENT Page: 9 Program: ams3olL Cast No 1-05-000368 Can Identify . Injury Extent Injury Type 2 Med Treatment : Phys Last Name : ********* OTHER P E R S O N Case Number . : 1-05-000368 Street Number : III City • WEST PALM BEACH, Birth Date/Age : Occupation . . : Home Phone No. Sex Weight Other Phone Nbr: • Victim Sobriety: Injury Type 1 : Hospital ID . : Phys First Name: (Continued) INFORMATION -# 1 ********* Last Name . . : FL 33411 Employer? . STUDENT Oper Lic No. 561 Race White Height 0 0 Person Type : OTHER PERSON Last Name Street Number : 358 EL BRILLO WY INFORMATION - 2********* Case Number . : 1-05-000368 ********* OTHER PERSO N City • PALM BEACH FL 000033480 Birth Date/Age : Employer? . Occupation . . : Oper Lic No. FL Hor Phone No. : Race Sex Female Weight 0 Type Other Phone Nbr: *********OTHER PERSON Case Number . : 1-05-000368 Street Number : II City • NM! BEACH, FL Birth Date/Age : Occupation . . : Home Phone No. : 561 Sex Fernma! i Weight 0 Other Phone Nbr: *********OTHER P E R Case Number . : 1-05-000368 Street Number : City Birth Date/Age Occupation . : PAINTER Home Phone No. : 561 Sex • Male Weight • 0 Other Phone Nbr: INFORMAT Last Name . . 33411 Employer? . Oper Lic No. White Height 510 Person : OTHER PERSON I 0 N - # 3 Race White Height 0 Person Type : OTHER PERSON *******## S 0 N INFORMATION -# 4 ********* • ROYAL PALM BEACH, FL Last Name . 33411 Employer? --Olper--Bie—No. Race . • : 1 • White Height Person Type : 0 OTHER PERSON ********* OTHER P E R S Case Number . : 1-05-000368 0 N INFORMA - 5 ********* Last Name . . : EFTA00232814 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Incident Report Page: 10 Program: CMIS301L Caste No • 1-05-000368 (Continued) Street Number City Birth Date/Age : 0/00/0000 0 Employer? . . : Occupation . . : FAMILY THERAPIST Oper Lic No. . : Home Phone No. Sex • leFema Race Height • • White 0 Weight • 0 Person Type . : OTHER PERSON Other Phone Nbr: Case Number . : Employer Name : Address . . . : City/State/Zip : Phone Number . : ***EMPLOYER INFORMATION*** 1-05-000368 PBC DIVISON OF YOUTH AFFAIRS 4200 N AUSTRALIAN AV WEST PALM BEACH, FL 33407 ********* OTHER P E R S O N INFORMATION Iiiiiii ********* Case Number . : 1-05-000368 Last Name . . Street Number : City • WELLINGTON, FL 33414 Birth Date/Age : Occupation . . : Home Phone No. : Ser Wei .it Other Phone Nbr: Case Number . : Address . . : City/State/Zip : Phone Number . : STUDENT 561, Male 0 Employer? . . : Oper Lic No. . : Race White Height 0 Person Type . : OTHER PERSON ***EMPLOYER INFORMATION*** 1-05-000368 Employer Name 4900 SUMMIT BV WEST PALM BEACH, FL 33415 ********* OTHER P E R S O N Case Number . : Street Number : City Birth Date/Age : Occupation . . : Home Phone No. : Sex Weight Other Phone Nbr: SCHOOL INFORMATION -# 7 ********* 1-05-000368 Last Name . . : WEST PALM BEACH, FL 0/00/0000 0 Male 0 ********* OTHER ......._11_SHR-S-ON Case Number . Street Number City Birth Date/Age Oc, )ation . . Home Phone No Sex 33412 Employer? . Oper Lic No. Race White Height 0 Person Type : OTHER PERSON INFORMATION -# 8 * * *MA" : 1-05-000368 Last Name . . : WEST PALM BEACH, : 0/00/0000 0 FL 33411 Employer? . : Oper Lic No. : 561 Race • Height • 0 EFTA00232815 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 PERSON Case Number . : 1-05-000368 Last Name . . : INFORMATION ti, Street Number : City • WEST PALM BEACH, FL 33417 Birth Date/Age : Employer? . • : Home fill Occupation . . : Oper Lic No. . Phone No. : Race • Sex • Race Height 0 Weight • 0 Person Type : OTHER PERSON Other Phone Nbr: ********* FL. ****************************NARRATIVE # 1*************************** Original Report LO Reported By: PAGAN, MICHELE D. 9/20/05 Entered By.: , LAURA D. 9/20/05 On 03/14/2005, I received a call from a woman who 'd not wish to identify herself (later identified as . She stat . that her fourteen year old step daughtl'illater i entified as possibly ma have been molested in Palm Beach by a wealthy man. According to she learned of the possible molestation by a third party. e exp ained 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 friend; they were talking about The conversation was about how had met with a 45- ear-old man and had sex with him and was paid or it. I advised that I would like to meet with her to obtain a more detailed s a ement and facts. stated she did not know what iiillill do and had to discuss the ma ter with her husband. At this point did not provide me with a call back number or any other in ormation. She stated that she would contact me once she had spoken with her husband and mother. On 03/14/2005 received a call from Mr. & Mrs. They stated it was all right to speak to their daughter via cell phone 561 Her mother had been ma e aware of the case. T ey a reed to meet me at tirlice department later this date. (561) On 03 14/2005, Mr. III II TIT. accompanied by his wife came to the Pa m Bea Po ice Department where they advised me t at they believed their fourteen year old daughter may have had some type of serual_selationabip with an nidAr male who resided in 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. Daniel identified his daughter as IIIII w/f.4_22D • resides with her biological mother at IIIII RPB, 33411, (561) Ma is a EFTA00232816 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 12 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) currently attending vocational school, RR is an her sister resides with Mr. Both and are facilit during the week and comes home on the weekenil l'According to involuntary admitt educational facility. stays at the IIII, she was admitted to the school because of disciplinary pro ems that recently escalated. The facility also coordinates with the families to provide one on one as well as family counseling. According to Mrs. she believes the incident occurred on Sunday, Feb 6, 2005. A riend of s, named picked her up at their house and left. They believe initiate t e with the older gentleman, though they o not have any proof. lives close by with her mother. Mrs. further explained that goes plays i lie a . Mrs. continued was introduced to by a boy she was dating they met the man. Supposedly, M ilan has a lot of money and often that on Sun ay, picked up and drove to Pa m Beach where has young girls come over to his house. offers these girls a way to make fast cash. The man starts willill massa e. If he likes them, he keeps them around and does more. The other than she lives on did not have any information on the last house on right si e (north side). Mrs. talked of a conversation that she had with t e mother of a former friend of She foun it strange that they were no onger friends until she received the call from her mother telliniiiii of the conversation she overheard between and a boy named Mrs. told me of an incident that occurred on 02/09/2005. Min got into a fight at school l Palm HS). Mrs. Brown Assistant Principal, found over $300.00 in s purse. gave different explanations for the large sum o money. Initia y the school administration thought it was drug related but then dismissed the claim. Since that day, ay not return to school; she ran away Thursday, 02/10th or Fri ay 02/11 and returned to her mother's house later that night after midnight. It was not until after mother, that she earne was tie gi ig t wit The fight was instigated when being a prostitute. who has legal joint custody of his daughter IME signed the affidavit of prosecution indicating he wished to prosecute .a.ainat the-Inappropriate sexual behavior with his fourteen-year-old daughter. received the call from Mr. stated that he had no objections with with his aughter about the incident. Mr. mother is aware of the allegations an cooperate. Accor ing to Mrs. she does not daughter had any additional contact with the suspect rt ot into the accused of our agency speaking stated that so was willing to believe her as she was with EFTA00232817 three girls walked up a drivewa guard/security room. In fact, them asking what they wanted. Jeff. The male allowed them to Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 13 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 her mother and then placed into (Continued) I contacted the School Board Police who provided me the information for Sable Palm, also known as Family Center 840 - 4540. 4200 N Australian Avenue, west a m each Florida. Checking the school board records for and there was no disciplinary record found. I was a vise I 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 the Palm Beach County Sheriff's Office and left a message for PBSP Sgt. Chris Keen, Child Abuse Unit. On 03/15 2005 I went to /Sable Palm where female Also present was , therapist. During an audiotaped interview I spoke wit about the allegations that were made. initially ed anything had ha ened onl admitting to going with ern (later identified as to Palm Beach to pick up money Mill was owed. ldenti le as the cousin of her rmer boyfriend She u Imate y admitted to knowing that worked for a wea t man and possibly did sexual favors for him. S e also admitted that had offered her an opportunity to make money. I met with white identified boss as a white male named "Jeff" who lived in Palm Beach ater positively identified as Jeffrey Epstein). explained that she was first a roached by to go with her to Jeff's house, when they were at house. According to she was not sure exactl what was going on with but agreed to o with her. ( boyfriend) became angry when he heard inviting to accom any her. believed it was to plc up money t e man owed stated told her that she would pick her up at er ouse on Sunday. was not sure of the exact dates but knew it was a Sunday. According to along with an unknown, possibly picked her up ather father's house on 76th Lane. liiiiiiic female, told her father that they were going shopping. It was later confirmed by that IIIIII picked his daughter up. According to Mr. drove a pick up truck. IIIIII drove S. along with the unknown female to Palm Beach. Sometime on the wa t ere, a conversation occurred between and hereby- L td that if Jeff asked her age, s e s ould sair'iBi—Tsias eighteen. recalled that Jeff's house was on a dead end street. All ast what appeared to be a small recalled a male approaching stated they were there to see continue walking up to the house. EFTA00232818 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 14 Time: 8:47:53 Incident Report Program: CMS301L Case N • 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 and a woman, described as white with blond hair entered the kitchen. believed the woman was Epstein's Assistant. added that t e woman did not seem friendly and kept her responses short and direct. Epstein introduced himself to as Jeff . got the impression that Epstein and riend knew each otier. described Epstein as being approximately forty-five years o , a ong face, and bushy eyebrows, with graying hair. and Epstein left the kitchen leaving and friend alone in the kitchen. They returned a s ort time ater. They all spoke briefly in the kitchen. While speaking to me, became upset and started to cry. stated the woman instructed her to follow her upstairs, which s e i . According to the woman led her to a room that had a massage table in it. T e woman started to fix up the room, uttin the covers on the table and taking lotions out. She then told that Epstein would be up in a second. The woman left the room, and soon after E stein walked in and told to take off her clothes. As was telling me what had appene , she looked away from me and wit a pointed finger, repeatedly pressed it into her thigh. stated he was stern when he told her to take off her clothes. said she did not know what to do as she was the only one there. took off her shirt leaving her bra on. E stein, dressed in a towe er to stated she removed her pants leaving then instructed her to give him a lotion for her to use. Epstein laid on be an to give Epstein the massage, stated she straddled herself take off everything. her thong panties on. massage pointing to a the table, face down. he told her to •et on on Epstein's back. E stein s bare buttoc As e turne around, and wacked o wacking off was masturbating). Epstein's actions but did not say anyt ing. According to 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 her three hundred dollars. They went ack down stairs where the met Epstein said good-bye and the left. asked ow i it go and asked what did she ( do. When told that E stein asked for a massage, allegedly stated "I now." stated -Btate-d-they theti-vist— Shopping. since she was con i ent that also giiiiiid, but that she did not know why did not do anything. described Epstein's house as a two story pink house with a Ca i ac Escalade parked in the drivewa . There were gates leading into the property. From the kitchen, recalled walking up a flight of stairs, lined with photograp s, to a room. Upon entering Epstein specific As hi stated er was ose s were touching giving Epstein the massage, later explained that stated she was distrusted by EFTA00232819 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 Mil hot pink and reen 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 we , as several photographs of naked women on a shelf. stated Epstein did not chap e in front of her but did take off his towel, exposing himself. recalled Epstein being hairy especially on his chest. E stein a so had a hairline that continued to his buttocks. admitted to seeing his penis. I asked if she knew w atbeing circumcised meant and she stated no. then said that she thought Epstein was on steroids because e was a "really built guy and his wee wee was very tiny." 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 instruction 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 again laid down on the table. lMling noises. Epstein then turned over and instructed to massage his boobs. As she did this, Epstein continued to ma resumed massaging his chest area. was now standing on t e ground. Epstein turned to his side, an wit the towel he ground started to rub his penis in an up and down motion. stated Epstein held on to the small of her back as she massageed his chest, back and shoulder area. recalled Epstein ejaculating because he had to 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 room and got dressed. She went ba k downstairs where she met III, an t e unknown white female. admitted to getting paid three hundred dollars in cash from Epstein. Before they left, Epstein asked As they were leaving the house and how much she was paid. iiiiirs when she told her that s e received t ree hundred d . stated received onlyLE2 hundred dollars that day. stated that she believed IIIII was paid two hundred dollars for bringing her. to leave her phone number. asked what had happened stated seemed upset or told that if they do this every Saturday, they could e rich; agreed. They then went shoppin though she is not sure where. Possibly at TJ Maxx or Marshall's. stated she never saw a ain as she got into a fight at sc oo . She had not spoken wit 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. S e stated no. EFTA00232820 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 l'ill'ilamily if she ever went to the po ice regarding the incident. stated that her father's vehicle was recently vandalized. admitted to tells what had happened with Epstein. According to in the wall. guessed that it was ecame angry and u set, punchin a hole 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 truth and lying. We talked about the color sweater she was wearing. denied having sexual intercourse with Epstein. She dente touching his penis. again admitted to observing Epstein masturbate. agreed to cooperating with the police department in placing a phone call to the a controlled setting. I met with ms. and advised her o the families' as well as IIII 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 portion of a conversation that her daughter was having with a boy named stated that it was her opinion that both girls liked recalled hearing her daughter calling a whore. admitted that she did not listen to the entire conversatirb ut id confront her daughter about it later. told her mother that somethin to the effect that hillilpt with an older man for money. stated that s e would not object to me speaking with her daug ter. It was s belief that everyone in the school alive known about t is because of the fight that her daughter and had gotten into. I reminded that this was an ongoing _nvestigation and requested she not discuss the fact that I had contacted her. She agreed. On 03/16/2005, PBSO Sgt. Chris Keen left a message that he was returning my call. I spoke with Keen and discussed the case with him and inquired if he had any open allegations or cases where the suspect resided in Palm Beach. Keen stated he was unaware of any. Keen offered any assistance if needed. Keen 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 EFTA00232821 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 17 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) a hoto of Epstein to be used in a photo line up. I met with at which time she viewed the photo line up. She immediately 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 at her residence for the purpose of placing a controlled call to spoke with and asked if she could arrange anotilli.ting wit Jeff. stated that she would have to call him and make the arrangements. A copy of this conversation was placed into evidence. 03/19/2005, I s oke with advised that uncle. is scheduled 03/21/2005, I coordinated with surveillance on 358 El Brillo. and and was to visit wit er aunt and to return to Florida on 03/27/2005 PB BSF Unit and OCVAN to initiate 03/21/2005, Coordinated with Det. Lee re ardin trash pulls from 358 El Brillo. On this same date I called to schedule an appointment to speak with She state t e sc ool guidance counselor was reluctant toll, police presence at the school. I assured her that I would respond to the school in civilian clothes and an unmarked vehicle. called me back and advised that I did not need to make an appointment to see would be attending the familillerapy sess I received a return phone call from I received messages from stating that ions with 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 names: , Mark L. stein, w/m dob Maxwe , uk/f, dob . A computer history. -Orr01/23//TrOtc-1- spoke- with cell phone wk requested that she not discuss t e incident with anyone including her daughter as I did not want the investigation compromised. I was told at t is time ha and have not been getting along due to the fact that IIIII has ecided to continue living with her father. On 03 29/2005, I placed telephone calls to both the and residences requesting to speak with them regarding the query for Palm Beach, w/f, dob ine N. both returned no EFTA00232822 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 18 Program: CMS301L Case No • 1-05-000368 investi ation. I received return phone calls from Mrs. Mrs. and advised them that I would be contacting family therapist to coordinate a time to meet with was at the request of both and Mrs. that classroom and therapy schedule be disrupte as ittle as also u dated them to the investigation thus far. Both stated the had no objection to my meeting wit sneaking with Ms. she identified the cell phone as being t e phone assigned to had no objections and provided consent to giving police de artment for the use of placing controlled phone it. stated the phone had been taken away from This strict ossible. E and In er of Ms. it to the calls from as part of ment for not doing well in school. According to used to be an excellent student, but in the past two months hasilliome irritable, verbally abusive to the family and has run away. stated her daughter's recent behavior is the opposite of what she normally is. I.= stated they are going through family therapy sessions wit t e school but none of this had come up. Arrangements were made for Det. Captain Gudger to retrieve the cell phone from at her place of employment. I called Family Center, and requested to speak with Ms. upon speaking with Ms. she advised me that she was in the middle of therapy sessions and would call me back once the sessions were completed. Ms.IIIII stated the sessions should be concluded by 7:00 PM. At approximately 8:00PM I had called Ms. at which time I left a message on her voice mail requesting a return phone call. I spoke with Ms. 1=1i and advised her that I did not meet with her daughter and that I would again attempt to coordinate a time with the counselor so as not to disrupt s school schedule. I received a call from Ms. had no objectionsi liortly after spilling with Ms. . I explained the situation an advised that MO would be available after 3:00PM. requested a time to meet with reviewed s schedule and On 03/30/2005, I met with Ms. and at Family Center. I reminded of il iconversation with During this time initiate a conversation with me in which she admitted that s e was not telling me everything that had ha ened during the time she was alone with Epstein. According to while she and Epstein were alone on the second floor Epstein used a purple vibrator to massage her vaginal area. stated there was no enetration as the vibrator was on top o er underwear. asked if Epstein ever asked her age and she stated he had. stted—the tbld -him she was eighteen. -Whail Epstein asked responded she was in the twelfth t e course of this incident, had worked for him for years. what school she was in, grade at Wellington. During stated Epstein told her that We then continued with the controlled call to At approximately 3:35 m from her cell illilitade a call to s home, was not home. was told EFTA00232823 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 19 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) that was at working a double and could be reached on her cell p one, W/F, is employed at The Olive Garden Restaurant, ocated on Forest Hi is Blvd in Wellington. called During the conversation between and asked what happened, stating that she ad hear rumors t at was going to press charges. asked if they, meaning arents, knew about Jeffery. claimed to have heard t at father had found out a out Jeffrey. IIII ' tol that the her parents) did not know anything a out Epstein. told that Epstein needed someone to work tomorrow and as a if she was available. 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. e wou then start to act in an immature manner I b looking around, not paying attention, drawing on a paper. li, would offer me a high five whenever she claimed to have tol me t 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 s e admitted that she did not tell me the all the details of her encounter with Epstein during our first meeting. As a means of positive reinforcement I would high five on 03/31/2005, subpoena requests for T-Mobile Wireless 561) and Cingular Wireless, (561) and one 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. Krauel 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 I queried various different web sites for a possible identification of the purple item retrieved from the trash pull from 358 El Brillo. The item was similar in description as the one described by 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 1- ems 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 EFTA00232824 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, I obtained a cop of voice mail messages, dated 03/31 and 04/01 from III to A female identifying herself as states t at she cou 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. Lee and me. There were several messages written on various forms of papers. There was a message from indicating 11:00. The following was additional information obtained from tras retrieved from 358 El Brillo: Jean Luc 6:20 AM. David 881-8116;655-0995 - lx; fuliias Friday 5 a message receipt S e is loo Ing to speak to you .; 9 On 04/06/2005 I faxed sub oena requests to SA office for Epsteia, and s phone records. P one numbers (561) (561) (561) & (561) IIIF On 04/06/2005, I called 311, and spoke with Prince a Ric a student by the name of Bryan. e requested a written request prior to releasing any additional information. On this same date I faxed a request for student and parent information on I advised that due to this being an open investigation e was not to discuss the matter with anyone. (Continued) School, , ext He cor.11 1111,I they had On 04/08/2005, I received a messa e from rovidin me the following information: Wellington, Florida, 33414. Parents name: Det. Lee provided me with trash obtained from 358 El Brillo for 04/06 04 07 05. The following information was retrieved: Jet Aviation itinerary, indicating a departure date of 04/05/2005 at an arrival in New York City of 6:15PM. Flight crew captain David Rodgers, co-captain, Larry Visoski, flight engineer Larr Morrison. Call sign N908JE; a note stating Bye J. thank you hand written notes & messages 11-Glenn 12:30 chicken Big Screen x8, 1?. left message or works 4-9 Monday an Tuesday, eaves schoo @ 11:30 AM; •e here tomorrow @ 10:30 Am; Mrs. Business 654-6699 ;833-4533. There was no trash for 04/08/05. 04/22 05 received the results of a subpoena request from Bellsouth for 561 . The results only provided subscriber information. I contacte A ice Grant Investigative Subpoena Compliance Center who stated the request was not complete and the results would be sent to EFTA00232825 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 21 Incident Report Program: CHS301L 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 aine from message notes trash pulls, I identified the before mentioned individuals as acquainted with someone at 358 El Brillo. DOB DL and =IIM DOB IIMII both a ove t e egal age o consent. investigation. stail li t at was doing wel l in the On 05/03/2005, I s oke with and updated her on the school. Her contact with the 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 a one. 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. 111111111 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 via being 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 conflictin appointments, with Ms. I also spoke with rescheduled until 06/02/2005, to meet and updated her to the investigation. On 06/02/2005, I met with I'll. and Sandborn advised that she could be reached via er cell p one 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 information that Epstein's plane was at Jet Aviation. I spoke with Det. Lee regarding surveillance. I called the Olive Garden and asked for she was not working today. This would indicate that employed there. On 07/07/2005 Epstein subpoena requests I faxed and subpoena requests to SA s phone records. only provided subscriber and I was advised was still office for 2 one numbers The original billing information. On 07/20/2005, conducted a trash pull arranged by Ofc. Lee. Inside there were misc. papers with phone numbers and names. There were EFTA00232826 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 22 Incident Report Program: ans3on Case No • 1-05-000368 (Continued) misc. female hygiene products in the trash. Based on a prior Auto Track report done on 358 El Brillo a ossible subject residing at the residence is fit the description provided by officers w o a con uc e 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 appeare that all was going will' 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 the case notes of this file, as the case will be turned over to Det. Recarey. 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 and to find out if there was any change o a ress or hone numbers for I was told no. I left a message for at 67 ****************************NARRATIVE # 2 *************************** NA Reported By: RECAREY, JOSEPH atalhis Entered By.: ALTOMARO, NICKIE A. 9/21/05 On September 19, 2005, I met with Officer Pagan and received the information pertaining to this case. Members of the Burglary Strike Force had previously been conducting surveillance on both Epstein and Officer Munyan was assigned to monitor the E stein home and Sgt Sorge and Officer Minot were assigned to monitor Both teams provided a surveillance log that will be placed into the EFTA00232827 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. Dawson was assigned to relieve Officer Munyan 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 T I V E # 3 *************************** NA Reported By: PARKINSON, GREGORY A. 9/23/05 Entered By.: ALTOMARO, NICKIE 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 as it is as a prior copy had been made and turned over to Sergeant Frick. I immediately took the tape to Sergeant Frick and allowed him to examine it and then obtained the copy from him and Detective Recarey 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. ****************************NARRATIVE # 4 *************************** NA Reported By: PARKINSON, GREGORY A. 9/26/05 Entered By.: ALTOMARO, NICKIE A. 9/26/05 On 3-24-05 at 11:00 pm, a copy of tape 2 (case number 05-294) had been made for Det. Pagan by Evidence Specialist . The copy was turned over to Detective Recarey. 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 test review process, that tape number 2 was blank. I notified Sgt. Frick and Det. Recarey. I was informed that they had a prior copy and I could use it to make a master tape. I did so and when reviewing and signing the evidence sheet, I noticed Evidence Specialist Badger had written "#2 is blank." I obtained that copy from Det. Recarey and made a new copy on a standard size tape. The new copy was placed in the evidence bag under EFTA00232828 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 24 Time: 8:47:53 Incident Report Program: ams3olL Case No • 1-05-000368 property number 05-294 with the blank tape. (Continued) ****************************NARRATIVE # 5 *************************** NA Reported By: RECAREY, JOSEPH 9/26/05 Entered By.: ALTOMARO, NICKIE A. 9/28/05 Copies of the tapes that were submitted into evidence were requested. Additionally, trash pulls were started on September 21, 2005. Sgt. Szarszewski made telephone contact with Tony Higgins, Supervisor of the Sanitation Department, and requested that trash be collected at the Epstein House located at 358 El Brillo in Palm Beach. Sgt Szarszewski met with Sanitation worker, Jeff Williams and observed him enter the property at 358 El Brillo. Shortly thereafter, Williams exited the property and placed the three white trash bags in the empty well in the rear of the truck. Williams then drove away where he met with Sgt. Szarszewski 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 contained names of irls with times. Additionally, there was a note from and to Jeffrey Epstein on a note ad, which stated,"For a good time ca there was another telephone .1.11. found the note Also and at " Also, 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 information on the telephone numbers listed above on the note from and 'I'll' The cellular telephones and are of assigne to Cingular Cellular Service. Other notes were ound within the trash on Jeffrey Epstein ad papers that contained telephone numbers. One note had " with written on it. This cellular number is assi ned 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. Szarszewski 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 S_eptember 23, 2005, the tapes were received and I began to become familiar with the interviews that were conducted. Det. Krauel had met with Town of Palm Beach Sanitation worker, Jeff Williams and observed him enter the property of 358 El Brillo. Shortly thereafter, Williams exited the property and placed the three white trash bags in the empty well in the rear of the truck. Williams then drove away where he met with Det. Krauel 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 EFTA00232829 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 25 Incident Report Program: ams3on 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 affected were the control phone calls from the victim to the suspect I obtained the graphic equalizer and discovered that the ca is 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. U on researching the file, it was discovered that the suspect, cellular calls were sub oenaed incorrectly. The suspect I hone number wal nd the original request was for I requeste t e in ormation through Cingular Cellular Service from FebruaI 2005 through the present. The purpose was to have a record of IIII making calls to victim, Jeffrey Epstein and the frequency of ca s. The request was submitted to the State Attorney's Office. Investigation Continues.... ****************************NARRATIVE # 6 *************************** NA Reported By: KRAUEL, CURTIS D. 10/06/05 Entered By.: ALTOMARO, NICKIE A. 10/06/05 On or about September 23, 2005 at approximately 0915 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jeff Williams. Williams had been previously notified to assist in trash pulls at the residence of Jeffrey Epstein, 358 El Brillo, Palm Beach, Florida. I observed Williams 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 Williams 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 documents of evidentiary value were removed and_turnea over to Det. Recarey 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 EFTA00232830 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 26 Incident Report Program: CMS301L Case No • 1-05-000368 and notified Det. Recarey 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 documents of evidentiary value were removed and turned over to Det. Recarey for follow-up. On or about Monday October 3, 2005 at approximately 0915 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jeff Williams. I observed Williams 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 Williams 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 documents of evidentiary value were removed and turned over to Det. Recarey for follow-up. On or about Tuesday October 4, 2005 at approximately 0928 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jeff Williams. I observed Williams 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 Williams to a predetermined location and seized the trasn 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 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. All documents of evidentiary value were removed and turned over to Det. Recarey for follow-up. On or about Wednesday October 5, 2005 at approximately 0928 hours, I EFTA00232831 Date: 7/25/06 Time) 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 27 Incident Report Program: CMS301L Case No • 1-05-000368 responded to 358 El Brillo and Williams. I observed Williams remove several plastic bags of bed of the sanitation truck. (Continued) met with PB Sanitation worker Jeff enter the driveway of 358 El Brillo and trash and place the contents into the I then followed Williams 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, with the assistance of Det. Recarey. 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 documents of evidentiary value were removed and turned over to Det. Recarey for follow-up. ***************************seNARRATIVE # 7 *************************** NA Reported By: RECAREY, JOSEPH 10/07/05 Entered By.: ALTOMARO, NICKIE A. 10/07/05 I met with Det. Krauel and requested further assistance to maintain trash collections at Epstein's residence at 358 El Brillo Road. On October 3, 2005, at approximately 10:30 am, I was contacted by Sgt. Frick to respond to the Palm Beach Police Station. Det. Krauel had observed Jeff Epstein riding his bicycle on South County Road. Upon my arrival, I met with S t Frick who advised, as Epstein was currently and the girls that are roujilli i his house. As we were to interview in Town; we interview as to her involvement with Epstein in the county, (outside of our jurisdiction), I contacted the State Attorney s Office Investigation Division, and made contact with Assistant Supervisor Investi ator Carlos Ortiz. I requested assistance to interview as the interview may occur in the county. Supervisor Ortiz assigned Investi ator Mike Waites to assist us at the location and interview of Det. Dicks had responded to the address of and viewed her vehicle parked in the driveway. ve is e a red Plymouth Neon IIIII in Loxahatchee. W il rick and I responded to 120th Ave an baring Florida Tag of was pare in the driveway of awaited the arrival of Investigator Mike Waites. Upon his arrival, he was briefed that should she wish to be interviewed within her home he would be needed. However, should agree to return to the police station for further questioning, he wou d not be needeiiiiiit. Frick and I knocked on the door andnet with was told that we were investigating a claim involving Je rey 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. Waites and advised she was going to voluntarily return to the police station. EFTA00232832 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Case No • 1-05-000368 Page: 28 Program: 001S301L (Continued) Upon IIIIII s entry in the unmarked Detective vehicle, I placed a tape recorder within the vehicle to record any conversations within the vehicle. During the ride back to the police station, advised she is attending Palm Beach Community College at the Palm Beach Gardens Campus 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 privac stated she understood. During the taped sworn interview, was asked how she came in contact with Epstein. stated bac when she turned Beach Resort in Rivera Beach. IIIIII was askedi lliihe wanted to make 17 years of age she was approachedy a riend in the Canopy 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 IIII (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 house. She was also introduced to a white female known to her as . She was led unfL2irs to the main bedroom known to her as Jeff Epstein s bedroom. IIII 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 a minute. Jeff entered the bedroom wearing only a towel. He lay on the table onto his stomach and icked massage oil for to rub on him. During the massage, stated, He tried to touch me and I stopped him. I asked how he tr e to touch her. He grabbed her buttocks and she felt uncomfortable. also stated Epstein has a vibrator, which is large and white in co or. 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 $200.00 for the massage. He explained, I know you re not comforts e, but I'll pay you if you bring some girls. He told her the younger the better. bring a 23- old. stated she once tried to ear-old female and Epstein stated that the female was too was asked how many girls she brou ht in total to Epstein. IIIIIIIIil stated six that she can remember. stated she brought and the victim in this case. I asked which one was the youngest. advised the victim was the youngest. III stated every girl s e rought knew what to expect when they arrive . 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 EFTA00232833 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 29 Incident Report Program: CIMS301L Case No • 1-05-000368 victim agreed and arrangements Epstein's house on a weekend. (later identified as victim s house. They travele (Continued) were made to bring the victim to stated that she and picked up the victim at the to Epstein's House and entered through the kitchen door. They met with the house chef and Epstein s in the kit!. area. led the victim upstairs and Epstein went assistant . The victim was introduced to Epstein while they were 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 victim told her she was paid $300.0O for the massage. Back in the vehicle, asked the victim what happened. The victim told her about the massage and then they went Epstein. sillillither stated that she had changed her cellular number shopping. stated the victim was the last person she brought to announces to his assistant till he is traveling to Palm Beach, to avoid being contacted by . She continued that when Epstein would contact to arrange girls for stein. later identified as Date of Birth , had told that Jeff likes to have his fun wit t e girls. stated that once her parents discovered that she was visiting ifr .n, they disapproved of the encounters with him and she stopped. further stated that IIII still tries to call the house and ntif leaves messa es. With the assistance of we were able to ide DO an iIIIIIIIIIIII Sgt Frick entered the room and explained that based on her own statements, she had im licated herself with bringing underage girls to Epstein's house. was aware of what she had stated and wished to assist further in opes to receive a lesser charge. provided cellular telephone numbers for the girls she ha mentioned previously. Additionally, she also rovided possible addresses and areas in which they lived. As was being taken home in the vehicle, a tape recorder was place 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 Frick and I went to Florida in an attem t to spea wit Mrs. ( s Mother) at t the ongoing investigation and felt that information as we4iad information that s introduced us to her husband and allowed us entr into the home. We sat in the dinning room and met with Date of Birt . As she was under the age o eig teen, Mrs. was a vise we would be speaking with her. She expressed, if er daughter had information she wanted to assist. As we interviewed she denied having any inappropriate encounters wit Je Epstein She stated she had gone to Jeff s in Loxahatchee, We met with front door. We explained may have additional worked for-Jef-f. Mrs. EFTA00232834 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 30 Incident Report Program: CMS301L Case No 1-05-000368 (Continued) House with approximately eight months ago and sat in the kitchen will!!! ouse chef but nothing hap ened. As the parents were present during the interview, we felt that was withholding information from us. She made several commen s as to she has put the entire incident behind her. I left my direct telephone number and advised should she wish to s eak with me again to telephone me. Sgt Frick and I thanked Mrs. for her time and left the area. She stated she would ask er 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. Frick and I then attempted contact with at in her daughter. was at the Wellington Ma and was not ome. We Loxahatchee. We met with who stated was explained the ongoing investigation and felt the may have additional information as we had information thatit ill had worked for Jeff. 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 approximate) 8:05 am, Sgt Frick had retrieved a voice mail message from She stated she had spoken with her daughter and she a in orma ion as to what occurred at Jeff shower at the moment an woullTilraveling back to Orlando to attend s house. I contacted who stated her daughter was in the College. I informed her I would be en route to her home in Loxahatchee. Det. Dawson and I drove to the home and met with and During a sworn a ed statement, state she was to en o the house by She was told she could make money working for Jeff. it ill was o she would have to provide a massage to Jeff. T. stated u on her arrival to the house she was brought to the kitc en area by They met with the house 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 during the massage. She stated sometime during the massage Epstein grabbed her buttocks and pulled her close to him. said she was wierded out by the incident involving Jeff. At t e conclusion of the massage, she was paid $200.00 for the massage. I asked if she has an formal training in massages to which she replied no. I asked her if received also received money for takin• her there. and another girl, 'a house once. state she wegrill!. any monies for taking her to perform the massa•e . stated stated she waited in the kitc en wit while was taken upstairs by . stated she on y the massage once, as she was wierded out by t e whole experience. At the conclusion of the interview and the t22twas stopped, I was informed that had attempted to reach IIIII 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 her to call her back reference the EFTA00232835 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 31 Incident Report Program: cris3on Case No • 1-05-000368 (Continued) police questioning. This voice mail message was recorded onto a micro cassette. rovided the incoming telephone number as stated she inadvertently told about the po ice investigation because had calledher to to her about how she just received a rents car from Jeff Epstein. had called her to tell her that she was gjaansatal..sarr a--2-04.5 Silver Nissan Sentra, to utilize to visit family and visit Jeff. W asked her what was going on at the house that the police would be as ing questions. stated then called Jeff and and asked what was going on referen investigation. According to contact her to ask about the po to contact and do not provide, she would note y Jeff Epstein and Investigation Continues... tions. I instructed more information to what was transpiring. ongoing police has since then been trying to not as ****************************NARRATIVE # 8 *************************** NA Reported By: LEE, LA'MONT 10/07/05 Entered By.: ALTOMARO, NICKIE A. 10/07/05 On March 30, 2005, I was asked by Sgt. Daniel Szarszewski to begin conducting surveillance and trash pulls reference Detective Pagan 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 Way and met with Town of Palm Beach sanitation employee, Jeffrey Williams. I observed Williams enter the driveway of 358 El Brillo Way, collect the trash bags from Epstein's property and place the contents into an empty sanitation truck. I followed Williams 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 through its contents. Exchaiiiliddressed to with (561 J.E dated 03/29 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. Photocopies of the trash collected were attached with the supplement. Detective Pagan was advised of the contents that were collected for evidentiary value. to the sanitation department were I sifted lected mail correspondence from Armani Jeffrey E. Epstein notepaper message notepaper addressed to .15 p-.1rtn—reference Peggy- Seagatr U.S Airways￾EFTA00232836 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 32 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) On March 31, 2005, Sgt. Daniel Szarszewski requested that I set up a surveillance vehicle on El Brillo 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 surveillance was concluded. I reviewed the video tapes and advised Detective Pagan 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 collect stein s trash, I observed a white female, who I recognized as from her Florida driver's license photograph. I made no con act with . While parked in the area, I also observed Epstein s GMC Yu on 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 Epstein, automotive records and personal documents for Janusz Banasiak and Beata Banasiak as well as Jeffre Epstein note aper with the names and appointment times for and No last names or other personal information was written on t e 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 rectal gratification. The sexual object was photographed for Detective Pagan, packaged in a biohazard evidence bag (possible-body-flulds)-and-secured au investigative evidence. All items collected from Epstein s trash were turned over to Detective Pagan 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 EFTA00232837 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. filltilrece of white paper black paper black paper David MSN Hotmail web page with email address The following items were documented for Detective Pagan s 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 Epstein's trash during my assistance were turned over to Detective Pagan for evidentiary purposes. On June 14, 2005, Detective Pagan contacted me and advised that the airplane belonging to Je rey Epstein of 358 El Brillo Way was parked at the Palm Beach International Airport. Detective Pagan 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. EFTA00232838 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 34 Time: 8:47:53 Incident Report 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. ****************************NARRATIVE # 9 *************************** NA Reported By: RECAREY, JOSEPH 10/07/05 Entered By.: ALTOMARO, NICKIE A. 10/10/05 On October 4, 2005, I made telephone contact with who had left several messages on voice mail. Duri!IIMessage, s e 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 a roximatel 15.48 m, I made telephone contact with at . During a taped recorded statement, state t e ollowin : Approximately a year ago, when she was sixteen years of age took her to Jeff's house twice. The first time she went, drove to the house. They entered through the kitchen area w ere she was introduced to and Jeff. She was taken upstairs to a bedroom by who set the room up with a massage bed and brought out the oils to use. Jeff then entered the room wearing 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 er shirt- at which oint she became very upset and discontinued the massage. Both and Jeffrey had a verbal disagreement at which time she le t wit out being paid. She met with who was sitting in the kitchen and told her let's o. advised she received no money for that day. also sal t at had told her if she was uncomforta e with what was going on, to et im know and he'll stop. She knew that the more you do the more you are paid. Several weeks later time by in the kitchen an advised she agreed to be taken a second Once t ey arrived at the residence, sat took her upstairs to the master bedroom again. set the room up with a massage bed and brought out the oils to use. Jeff then entered the room wearing a towel. He lay on the table and picked out a lotion for to rub on him. At one oint during the massage, he tried to touch her buttocks. As was wearing tight jeans and had a tight belt on Jeff was un e to touch her buttocks Jeff then rolled nnro his hark during the massage; he attempted to touch her breasts. then became upset again and told him she didn't want to be tout e . discontinued the massage and was paid $200.00. then went downstairs where e was waiting for her. e told 'III! she wanted to eave. said she never returned to t ouse. stated she is aware that her friend, was 1111111he house and had a problem with Jeff. S e prow e a telephone number EFTA00232839 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 35 Incident Report Program: CMS301L CaL No • 1-05-000368 (Continued) for The interview was concluded and the micro cassettes were turn in as evidence. On Octobeimiim2005 I researched the incoming telephone number that had left a message. The telephone number, was assign! to ATT cingular Cellular service. I prepare a s poena 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 Palm Beach. Det. Dawson and at her residence in Royal Palm Beach. i llEve to Royal Palm Beach and met with I later researched and discovered she resides in Royal taped statement, stated the following: On or about November agreed to s eak with us in the kitchen area. During a sworn 2004, she was approac ed by and asked if she wanted to make money. She agreed and was o s e would provide a massage to wealthy man in Palm Beach. picked her up and drove her to a house in Palm Beach. She was rou ht into the kitchen area o en k. and gill, went with them. They were brought into w ere she house. She further stated that ( was introduced to Jeff and other females. stated she was introduced to a helper of Jeff; the fema e was described as white female (unknown name with blond hair. She stated that the assistant was familiar with The assistant set up the massage table and put out lotions to e used. She told Jeff would available in a minute. Jeff entered the room wearing on y a towel. Jeff lay on the massa e table and picked a lotion to rub on his thighs and back. e further stated that during the massage Jeff asked her ti ve r c othes. 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 touched his buttocks with hers. was instructed to return to the ground at which time Jeff turned to ave his chest advised it was at this time she is sure he was did not want to look at his penis area because rubbed. masturbating. she was uncomfort e. Jeff removed a large white vibrator and turned it on. stated he began rubbing the vibrator over her thong underwear on her vaginal area. Shortly thereafter, Jeff 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 turn! seventeen. At the conclusion of the shower, was paid either $350.00 or $400.00. She stated she wasn't sure, u knows it was close to $400.00. At the conclusion of the interview, stated she never returned to provide a massage for Jeff. e a vised she was ashamed and uncomfortable with the situation. EFTA00232840 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 36 Program: CMS301L Case No • 1-05-000368 Det Dawson and I then left the area and responded to the t High School where and all the above-mentioned girls had attended. I met with ScRAillolice Officer, Off Williams. explained I was looking for a previous student who attended high School. I inquired about I further explained that I was working a case in which most of the girls I have interviewed are either witnesses or victims and felt that may be one as well. Officer Williams researched his previous student records and found She attended the same year and graduated in the samiliiiilas t e other girls. I was provided the last known address of At approximatel 2:10 m Det. Dawson and I met with at her residence, in Royal Palm Bell i. was on seventeen years o age, I a 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 of her being either a witness or victim. Mrs. advised she wanted to cooperate and illil l of consented to the interview. During a sworn cape statement, stated the following: at the age of sixteen during the eptember 2004 she was approached by for a chance to make money. was friends with the frien s o and knew the samee eople. had been previously told by her riends what an did for Je M scheduled the appointmentcalled a erson known to as . Bri picked up and her . to Palm Beach to a street called o 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 Jeff. was introduced to Jeff. led upstairs to the main e room area and set up the room wit a massage table and set out the oils. dimmed the lights room wearing only a towel. I M ilpicked oils and instructed her to rub and turned on soft music. exited the room and Jeff entered the his legs, under his buttocks, back and chest area. Jeff 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 his chest area, Jeff attempted to reach down her pants I.gh the area. During the massage, Jeff removed his towel. As rubbed buttocks area, however was unable to due to the tightness of the jeans rubbed his chest. itllil moaned as she rubbed his chest. She observed and a tight belt. advised Jeff began to masturbate as she he was continuing to masturbate and attempted to reach up her tank top he kept masturbating until!! climaxed. He cleaned himself with the and touch her breasts. pulled back and Jeff stopped. However, _towel he was previously wearing. I asked 'III if she knew the difference between circumcised and not circumcised. She explained she knew and advised Jeff 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. liM then explained she never provided another massage for Jeff. She owever, go to the house with and as they EFTA00232841 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 37 Program: CMS301L Caere No • 1-05-000368 took another friend of advised she went to wor or Jill ' She advised sat in thillllhen i area with to wait for was she (Continued) present when rode over and advised that while they waited for the house chef prepared lunch for them, as it was almost lunc time. As was finished with the massage, they left the area. I asked if ever told what would be e ected of her when she prove e a massage. stated yes, told her that a massage would be expected possibly naked and posse y some touching involved. has no formal training in providing massages. spoke about a third and last time she went to Jeff's house. drove another girl, who is friend, to Je 's house. I'll' stated s e knew t at ha ma a mone providing girls or Jeff and she wanted to do t e same. took them in the kitchen area of the house and introduced upstairs to the main bedroom. a vise now w at ha pened as did not s what happened in the room. received 100.00 from going with her to Jeff s house and recommending unable to remember s telephone number. illitierview concluded and we left the area. and took she oesn t k Investigation Continues... about for was was ****************************NARRATIVE # 10 ************************** NA Reported By: RECAREY, JOSEPH 10/09/05 Entered By.: ALTOMARO, NICKIE A. 10/10/05 On October 6, 2005, Det. Dawson and I went to L n University located in Boca Raton. We met with Dean of Students, Turner. I explained to Mr. Turner that we were investi atin a crime within the Town of Palm Beach and felt that a student, may have information. Turner confirmed that is a stu ent and currently on the soccer team for Lynn University. She was in computer class at the time of our arrival. Turner sent a security guard to locate in class and bring her to the office. Mr. Turner allowed us to interview in an empty conference room. to interview her. She a vise t ill!as aware of the ongoing At 11:45 am I met with and explained to her why we there investigation. stated she had previously spoken with who told er she was interviewed by detectives. During a sworn tape statement,_ stated she knew that IIIIIIIIIIi_worked far_ Jeff in Palm Beac advised she has been there many times for massages. I asked her i she had formal training in providing massages, stated she did not. advised she was told what was expecte o 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. S e considered Jeff a pervert who kept EFTA00232842 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 38 Incident Report Program: CMS301L Ca. No 1-05-000368 (Continued) pushing to go further and further. at explained she would keep telling him she had a boyfriend and t at it 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 Jeff wanted to be rubbed on his back and recently he began turning over to have her rub his chest as he masturbated. He would try to touch her breasts as she rubbed his chest. stated, Jeff would tr to get away with more and more on each massage. iiiiinally, drove her to the house for the original massage. left er cell phone number and every time Jeff would come into town would call her for an appointment. Each time she went, wou d meet her at the kitchen door area. She would bring her upstairs and prepare the massage table. advised Jeff would ask her questions about herself. He knew she was a soccer player and would be attending Lynn University. I asked if he knew her real provillis on October 1, 2005. During the massage she asked Jeff if age, stated Jeff didn t care. The most recent massage she she could borrow one of his vehicles to visit her family and boyfriend in Orlando. Jeff had told she could borrow one of his vehicles but later stated he would rent her a car. She continued with the massage as Jeff rabbed her buttocks and caressed the buttocks cheeks. I asked if she was wearing undergarments to which she replied her thong un erwear. 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 o t e vibrator but advised she never would allow im to use the vibrator on her. She described the vibrator as a 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. 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. Ristated she was contacted by on October 3, 2005. had med her that Jeff had rented her a new Nissan Sentra and she should come by the house to ick it up. informed she would 'ill' have the car for a month. stated Jeff knew her car was not working properly and had misse 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 any one to the house. explained she took a friend of hers who has returne to Orlando to attend A. '. I as ed 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. Dawson and I went to the G area and located the Silver Nissan Sentra bearing Florida tag . The vehicle is registered to Dollar rent a car out of the Pa m Beac International Airport. Tele hone contact was made with the victim's mother, at I explained to heilliaMi liollowing up on this case and provi ed a complete update on the case. Investigation Continues. EFTA00232843 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 39 Incident Report Program: CMS301L Cas.. No 1-05-000368 (Continued) ****************************NARRATIVE # 11 ************************** NA Reported By: RECAREY, JOSEPH Entered By.: ALTOMARO, NICKIE A. 10/21/05 10/21/05 On October 10 2005 at a roximately 2:30 p.m., I made telephone contact with During a taped conversation, IIII was told of an ongo ng nvest gation in which I felt she had information pertaining to Jeffrey Epstein. explained she met Epst in when she was just sixteen years of age. She was approached by a friend who also had previously gone to Epstein's ouse for massages. advised she was working at the Wellington Mall when she was approached. told her that she would have to provide a massage to Epstein an s e would have to perform this massage naked. ll thought about the offer and stated she could make $200.00 for on 30 minutes of work. She agreed to perform the massage and set the appointment for her that same day. remembered i was a weekend as she only worked at the mall on the weekends. took her to the house where she was introduced to , Jeff Epstein's assistant. took her upstairs to a master bedroom. explained that as she was walking up the stairs she observed several photographs of naked women along the walls and tables of the house. 0e further explained that she was brought into the bedroom where prepared the room by setting up the massage table and provided t oils for her to rub on Epstein. Epstein entered the room and introduced himself. Epstein lay on the table and told her to get comfortable. could not remember if he was naked or if he entered the room with a towel. stated she provided the massage wearing only her panties. She continued rubbing his legs, thighs and feet. IIII advised he turned over onto his back. She continued to rub his legs with the oils. Epstein touched her breasts and began to masturbate. I asked if she knew what circumcised and un-circumcised meant. stated circumcised is when the penis has no foreskin and the head o the penis is visible. stated she had been to his houllilundreds of times over a two-year said Epstein is circumcised. began to cry on the telephone and period. She 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 upset, crying hysterically and stated she was aid and instructed to have sex with Epstein's assistant, by Epstein. Epstein continued to watch them have se himself as they had sex with each other. She further stated that things escalated further and further. Epstein used sexual toys such as vibrators, rubber penises and strap-on penises on She claimed he Epstein) put his fingers inside her vagina while he Additionally, stated he performed oral sex on her numerous times. masturbated in an attempt to make her climax. could not continue and wanted some time to regain her composure. I explained to to take her time. After taking several minutes to regain her composure I EFTA00232844 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 40 Incident Report Program: CMS301L Cab,: No • 1-05-000368 explained that I would travel to meet had additional information to provide explained the importance to meet with agreed and made arraignments for Det. in Jacksonville, Florida. (Continued) with her in person as I felt she I met with Sgt. Frick and in person. Sgt. Frick Dawson and I to meet with On October 11 2005, at 4:10 p.m. Det. Dawson and I met with and her friend, in Jac sonvilr7Florida. wanted to present or support. I explained to er that I did not ave iiiioblem as long as she wanted present during the interview. stated she wanted her present. I explained that as was present she was not allowed to comment or ask any questioning the interview. She was only there to comfort should the interview upset her. During a sworn taped statement, e how everything be an. She said she was brought through t e kitchen area where she met for the first time. She was led to the master bedroom, Epstein s observe lseveralphotographs of naked women along the walls and tables room. explained that as she was walking up the stairs she of the house. further explained that she was brought into the bedroom, where prepared the room by setting u the massage table and provided the oils for her to rub on Epstein. explained she remembered the steam room area, which contained two arge showers. Epstein entered the room from the steam room area and introduced himself. Epstein lay on the table and told her to get comfortable. liremoved her skirt and kept her shirt on. She could not remember e was naked or if he entered the room with 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 onl her panties. She continued rubbing his legs, thighs and feet. advised he turned over onto his back. She continued to rub his egs with the oils. Epstein touched her breasts and began to masturbate. Epstein ejaculated which meant the massage was over. At the conclusion of the maiiiie, was aid 200.00. They walked together downstairs where an were waiting. stated received an unknown amount o 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. 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 there. There were times she went to dicers andpartles.m2th Rpsteln. things began to escalate more than included bringing in his assistant, Epstein had purchased her from her am. y In ugos avia. Epstein bragged he brought her into the United States to be his Yugoslavian sex slave. advised he was naked in the bedroom, she entered and removed her clothing. entered the room from the steam room area already naked. He instructed to perform oral sex on explained that _ . encounters explained EFTA00232845 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 41 Program: CMS301L Case : 1-05-000368 (Continued) refused to perform that act. Epst her an a itional $200.00 for her to perform oral sex on for five minutes. agreed to perform the oral sex for the additional $200.00. explained that Epstein would masturbate while he watched them perform sexual acts. Things continued to escalate by purchasing sex toys. stated she had massagers, vibrators and strap on rubber penises used on her. Each time somethin new was introduced additional monies were produced and offered for to allow the acts to happen. was adamant that she performs a 1 these acts but there was an understanding with explained that Epstein's penis was deformed. III il. l Epstein that no vaginal penetration would occur with his penis. explained that 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. Illi . would arrive at the ouse and walk herself continued that the sexual encounters with Epstein and became a ritual upstairs, where and Epstein were wail. . would clot n them on the bed. explained and she would begin by kissing and touching each other. Dined sex toys were brought into the bed by either Epstein or and they would begin using the toys on each other. Epstein wou per orm oral sex on either person depending who was on top during the intercourse. explanation revealed they were in a missionary position. RI incident occurred), was unable to state and exact date when it came to the house after had informed advised one day, ( her that Epstein had arrived. She arrived at the house and went upstairs to the master bedroom. advised she immediately removed her clothin as an E stein were already naked in the bedroom. explained that .nd she had a sexual encounter to include kissing, touc ing an oral sex. remembered that she climaxed and was removing her self from the massage table. asked for a sheet of paper and drew the massage table in the master bathroom and where Epstein, and she were. Epstein turned on to her stomach on the massage ed and inserted his penis into her vagina. stated Epstein began to pump his penis in held against Il i bed forcibly, as he continued to pump inside her. her vagina. became upset over this. She said her head was being She screamed no, and Epstein stopped. She told him that she did not want to have his penis inside of her. 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 there were times that she was so sore when she left Epstein's house. IIII advised she was ripped, torn, in her vagina area. advise she had difficulty walkiiiiio the car after leavinji!!! house because she was so sore. advised that other EFTA00232846 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 42 Incident Report Program: CMS301L CaE No • 1-05-000368 (Continued) than that one time, when Epstein inserted his penis inside her vagina, there was no other penile intercourse. provided names of girls that she knew of that have gone to Epstein's house. provided the name of and feels she still mallilgoing to the house to massage Epstein. According to is still sucking his dick." When asked if she had been recently contacted by anyone of the house, advised she received an email from , from , which is her emaik.count. The email was just a hello, ow are you doing type of email. There had been no other contact from the house. The interview was concluded and left the area. The tapes and drawing were submitted into evidence. Investigation continues... ****************************NARRATIVE # 12 ************************** NA Reported By: RECAREY, JOSEPH 11/01/05 Entered By.: ALTOMARO, NICKIE A. 11/07/05 On October 12, 2005, Det. Dawson and I traveled to the Orlando area and made telephone contact with agreed to meet with us as we were in the Orlando area. rove ed directions to her apartment. Det. Dawson and I met wit who stated, during a sworn taped statement that nothing happene etween her and Epstein. appeared nervous IRMoken with other people who advised differently. stated during the interview. I assured her that I she only went a couple of times and provided a massage to Epstein. She stated she was brought to the Epstein house in March of 2005. brought her to work. has no formal training in prove ing massages. stated s e 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 the house. state she was interviewed already by an investigator for Epstein. He met with her on OctobeILia. 2005, at a Roadhouse in Orlando. He identified himself as IIII and in uired about the police investigation and left his telephone number for additional contact. provided no additional in ormation, 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, 2O057 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 Brillo in Palm Beach. Members of the Investigations Unit included Capt Gudger, Sgt Frick, Det. Dicks, Det. Dawson, Det. Melnichok, Det. Sandman, Det. Krauel, the crime scene unit and myself. EFTA00232847 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 43 Incident Report Program: CMS301L Cane 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 forced entr was made. I made contact with 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 members exited the home. I read the search warrant to Banasiak as Mgr Parkinson videotaped the search warrant execution. Several interior decorators were located on the property. I spoke with Mark Zeff, of in New York. Mr. Zeff stated he is the designer for r. Epstein's omes. 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 in New York. Mr. Estes stated he has worked for Ze or seven years. He advised he personally worked on the New York and Palm Beach home for Mr. Epstein. He has previously met with and , Epstein's assistants in New York and in Florida. Estes stated they travel with Epstein everywhere he goes. I interviewed of ersey City, New Jersey. stated ive rom Scot and 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 in New York City. Schoettle stated he has been Epstein's Arc itect for seven years. He further stated he deals with Epstein's assistants and spear ein on the phone. Schoettle stated he mainly speaks with , Epstein s main assistant, who travels with Epstein. Schoe esae 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 cther 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. Krauel and I began in the master bedroom area where several items were located. They were EFTA00232848 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 44 Time: 8:47:53 Incident Report 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 Jeffre Epstein we located a hi h school transcript fro High School for !M Also in the room, was the dresser /armoire where we ocated a e 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.. **************************** N A R R A T I V E # 13 ************************** NA Reported By: PARKINSON, GREGORY A. 10/20/05 Entered By.: ALTOMARO, NICKIE A. 11/07/05 On October 20, 2005, at approximately 8:30 a.m., Thursday morning, I was advised by Captain Gudger that a search warrant would be executed and that I was to assemble the Crime Scene Investigative Team and stand by the south side of the building ready to go. I designated Evidence Specialist to handle the inventory return, the documentation of the property receipts and the collection and bagging of the evidence at the scene. I further instructed CSI Kim Pavlik, ID # 8807, to accompany us and perform the role of photographing the scene and the items that may be taken into custody by the affiant, Detective Joseph Recarey, 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 search was conducted, items were collected by Evidence Specialists Badger, EFTA00232849 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Cas_ No • 1-05-000368 Page: 45 Program: CMS301L (Continued) photographed by CSI Pavlik and then videotaped by myself. The search was concluded at approximately 3:05 p.m. whereupon Detective Recarey and I were the last two officers in the house. Upon securing the residence we met with the gentleman who identified himself to Detective Recarey 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 Recarey and I returned to Police Headquarters and secured for the day. ****************************NARRATIVE # 14 ************************** NA Reported By: DAWSON, MICHAEL C. 11/07/05 Entered By.: ALTOMARO, NICKIE A. 11/07/05 On October 20, 2005, I assisted Defective Recarey 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, Daniel Estes, and Mark Zeff. As other members of the police department cleared the home, I kept watch over these three males. Once the house was cleared, those males were turned over to Detective Recarey. Detective Dicks 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. The combination was entered by Banasiak in the presence of Sgt. Frick 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 EFTA00232850 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. ****************************NARRATIvE # 15 ************************** NA Reported By: RECAREY, JOSEPH 11/08/05 Entered By.: ALTOMARO, NICKIE A. 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 6, 2005, I attempted contact with at her residence. I left a business card for her to return my ca l. Upon returnin to the olice department, I had received a telephone call with I returned her call at d spoke with S e made arrangements to respon o t e station to provi e an nterview. At approximately 3:30 pm, she arrived at the Palm Beach Police Station with her boyfriend. Her boyfriend was allowed to 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 one time. Approximately 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 rent t at month. She_agreed_to_go_to the been-told by that the massage would have to be done in her underwear. S e advised drove with her and brought her into the house. They R. ' walked into the kitchen area and took the stairs upstairs. further stated she was brought into a master bedroom area. 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 EFTA00232851 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 47 Incident Report Program: CMS301L Cat. No • 1-05-000368 (Continued introduced himself as Jeff. advised she recalled she and removed their clothing down to t eir panties, Epstein lay 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 s or s 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 Epstein turned over onto his back. Epstein then removed the towel, which had been around his waist. Epstein laid there naked and requested that rub his chest area. stated as she did this, EpsteinliMn masturbating as she !!!!!! his producedillial ge white vibrator with a large head. She stated it was chest. stated he pulled down her boy short panties and he within a drawer in his master bathroom. He rubbed the vibrator on her vagina area. advised he never penetrated her vagina with the vibrator. He continued to rub her vagina with the vibrator as he continued to masturbate. new stated she was very uncomfortable during the incident but new it was almost over. Epstein climaxed and started to remove himself from the table. He wiped himself with the towel he had on previousl and went into the shower area. got dressed and met with in the kitchen area. E stein came into the kitchen and provided $200.00 for brienging and paid $200.00 to for provi in the massage. was to d to leave her telephone number with , his assistant ill!' or 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 replied she was called but it was for work. She stated she was called by for her to return to work the massage in...iv:ear. advised she declined, as she was not for Epstein. stated work is the term used by to provide comfortable in providing that type of work. The interview was concluded and the videotape was placed into evidence. Investigation Continues.. **************** ***** ******* NARRATIVE # 16 ************************** NA Reported By: RECAREY, JOSEPH 11/10/05 Entered By.: ALTOMARO, NICKIE A. 11/10/05 On November 7, 2005, I made telephone contact with who advised she would be able to meet with me at her home. Det. and t traveled to-MY home in Royal Palm Beach and made contact with During a sworn taped statement Je rey Epstein through who wished to work for him. state She was asked about any training in providing massages to which him but declined. exp ained that work means give massages. she said no. said she accompanied and other females stated she met would approach females she was asked to work for EFTA00232852 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 48 Program: CMS301L Case No • 1-05-000368 Continued) who were taken to Epstein s house to provide massages. further stated she had been to the house approximately 4 or 5 times in glimigitmiiiiim She accompanied with the 14-year-o victim, and raTrrimrrhirlir s were taken over, they were previous y to t ey would have to provide a massage, possibly naked. It was also told that should Epstein require them to do anything extra and the 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, the victim, as she stated she was fifteen years old at the most; she looked really young. further stated each time she went to the house, she sat in the itc en and waited with until the massage was over. She further stated that the cook wou 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 throug out the house. The interview was concluded and the tape was turned into evidence. Investigation Continues.. **************************** N A R R A T I V E # 17 ************************** NA Reported By: RECAREY, JOSEPH 11/10/05 Entered By.: ALTOMARO, NICKIE A. 11/10/05 Beach. I left my business card at her Ms Det. Dawson and I attempted contact with in Ro al Palm returned my call and arranged a meeting with me at the Pa m Beach Police 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 encounters with him in the past. During a sworn taped statement, stated she had met Epstein approximately two years ago. She was irst introduced to Epstein by approached her about working for Epstein and providing a massage to him for $200.00. The arrangements were made and as could not take her the day the arr e, took also attended High School and was fame tar with Epstein. 1 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 throughout the house. stated E stein came in the room, wearing only a towel, and lai on the table. stated he picked out the oils he wanted her to use and requested s e remove her clothing to provide the massage. stated that on the first massage she provided she did not remove er EFTA00232853 Date: 7/25/06 Time: 8:47:53 Incident Report PALM BEACH POLICE DEPARTMENT Page: 49 Program: CMS301L Cat No • 1-05-000368 (Continued) clothing. stated she had returned several times after that. Each time she returned more things happened. stated that the same thing would happen. Epstein would walk into t e master bedroom/bathroom area wearin 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 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 massaaer/vibrator, which she described as white in color with a large head on her. Every time she provided a massage he would masturbate. added she has no formal training in providing a massage. stated she brought two females during her visits to rovide massages. III stated she brought a girl named and from Roya Palm Beach High School. stated s e receive 200.00 for each girl she brought. Additions y, was given $200.00 for taking her in the very beginning. The interview was concluded and the tape was placed into evidence. Investigation continues... ****************************NARRATIVE # 18 ************************** NA Reported By: RECAREY, JOSEPH 11/13/05 Entered By.: ALTOMARO, NICKIE A. 11/14/05 On November 8, 2005, I made telephone contact with W/F, at her residence. responded to the po ice station or 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 one year ago. She was approached by a subject known to her as had asked her if she wanted to make money providin massa es to Epstein. had heard that several girls from High Schoilli lle doin this and making money. She agree an was taken to the house by master bedroom and Master where a massage table was prepared had introduced her to and Epstein and brought her upstair s to a and the proper oils were taken out. left the room and waited downstairs for stated Epstein entered the room wearing a towel and she prove ed 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 whale situation was weird but she advised she was paid $200.00 for providing the massage. She also stated received $200.00 for bring 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 EFTA00232854 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 50 Incident Report Program: CMS301L No • 1-05-000368 (Continued) massage. Epstein began touching her on her buttocks and grabbed her closer to him as he masturbated. Epstein also grabbed her breasts and fondled her breast with his hands as she provided the massage. stated on one occasion, he offered extra monies to have vaginal intercourse. She stated this all occurred on the massage table. stated Epstein penetrated her vagina with his penis and began aving intercourse with her until he reached the point of climax. Epstein removed his enis from her vagina and climaxed onto the massage table. received $350.00 for her massage. I asked her if she had any orma training in providing massages, stated she did not. contiaasaw to state on one other occasion, Epstein introduced his assistant, IIIII into the massage. I was brought into room with to provide a massage. Epstein17-Mrthem kiss and fondle each other around the breasts and buttocks as they provided a massage to Epstein. Epstein, watched and masturbated as this occurred. On other occasions, Epstein introduced the large white vibrator/massager during the massage. Epstein stroked the vibrator/massager on milk vagina as she provided the massage. ed the last time she spoke with anyone at the house, was wit during the weekend of October 2 or 3, 2005. stated she ha rou ht two eople to the Epstein house. She prove ed the names of and (unknown last name . It should noted, ha een previously identified as 'pill and had been previously interviewed. The interview was cone ude and the videotape was placed into evidence via the locker system. On November 9, 2005, Sgt Frick 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 then traveled to Lynn University and met with Dean of Students, Mr. Turner. We requested to speak with was re interviewed, as she still was in ossession l'ille rental car that Epstein had acquired for her. stated that Epstein's assistant, had called her on her cc telephone and informed her that rental was extended for her. tated she had paid an additional $625.00 for her to keep t e rental an extra month. was asked if she had any additional contact with either Epstein or anyone from his organitetion. stated she did not, other than the telephone call informing heillit 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 EFTA00232855 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 51 Incident Report Program: CMS301L ,a-: 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 home. I 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. ****************************NARRATIVE # 19 ************************** NA Reported By: RECAREY, JOSEPH 11/15/05 Entered By.: AITOMARO, NICKIE A. 11/16/05 On November 14, 2005, Det. Sandman and I traveled to RIin Loxahatchee, Florida and spoke with e was of the ongoing investigation involving ps ein. advised she had gone to the house on several occasions. During a sworn taped statement, she advised she started oing to the house approximate) one year a o and was brought by (Unknown last name). stated brought her into t e ouse and she was introduce to a girl name . Once she met her, brought her upstairs into a master bedroom bathroom. state she met Jeffrey in the bathroom. He lay on the t e an 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—massage. stated she had only been at the house approximately five or six times. said each time she went to the house she was notified by , pstein's assistant, 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. EFTA00232856 Date: 7/25/06 PALM REACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 52 Program: CMS301L CaL No • 1-05-000368 Continued) advised it wasn't really weird until later on. was as e if she ever removed her clothing to provide a massage. stated it was not until the third time she went that she removed her clothing. stated she was notified by that Epstein wanted her to come to work. She arrived at the ouse and was led upstairs by . She started providin the massage when Epstein asked her to remove her clothing. removed her pants, shirt and bra. She stayed in her thong panties and continued rubbing Epstein. E stein turned over onto his back and she rubbed his chest area. stated she knew he was masturbating himself as she providing t e massage. stated she believed he climaxed based on his breathing. She di 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 ressed. She was paid $300.00 for her services. stated on the last time she went to provide a massa e, she was notified by to come to the house and work. stated she was now dating her current boyfriend and did not fee com ortable 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 wearin only a towel as he entered the room to lie on the table. stated Epstein caught her looking at the clock on several occasions. Epstein asked her if she was in a hurr 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 Western Union in Royal Palm Beach and Okeechobee Blvd as a Christmas gift. advised 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 a roximately 4:22 pm, I made telephone contact with at She agreed to meet with me at a public place. suggeste s e 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. ****************************NARRATIvE # 20 ************************** NA Reported By: IIIIIII, 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 Beach Palm Beach County Florida under the direction of affiant Detective EFTA00232857 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 53 Time: 8:47:-53 Incident Report Program: CMS301L Cas... No - 1-05-000368 (Continued) NA Detective Melnichok 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. We searched a 2004 black Chevy Suburban bearing Florida tag X99-EGL, registered to Jeffrey Epstein DOB , which was located on the east side of the driveway facing soutilliI l found a Thrifty rental agreement between the passenger seat and the middle console. The name on the rental agreement was from Palm Beach Gardens Florida 33410. T e p one numberillit illi rental agreement was The hicle rented was a white 2005 Chrysler Sebring earing F on a tag . The vehicle was rented on 9/25/05 at 17:58 hours and was returned on 9/26/05 at 16:52 hours. The last four numbers of the credit card used are Detective Melnichok found a piece of paper in the middle Ale that said I used the cash in here to fill up the tank and was signed by I searched the 2005 black Cadillac Escalade ESV bearing Florida tag Q29-9GT, registered to Jeffrey Epstein dob , which was located on the west side of the driveway facing sout 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. ************************NARRATIVE # 21 ************************** Reported By: RECAREY, JOSEPH 11/17/05 Entered By.: ALTOMARO, NICKIE A. 11/17/05 EFTA00232858 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 54 Time: 8:47:53 Incident Report Program: CMS301L Cas- No • 1-05-000368 (Continued) On November 15, 2005, Det. Sandman and I traveled t in Royal Palm Beach. We met with a seventeen-year old juvenile who was not in schoo t is 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 parentsprior to speaking with her. She telephoned her father, Mr. on his cell phone and explained to him that Det. San an an I were there to speak with her. I spoke with Mr. on the telephone and informed him I needed to s eak with his aug ter in reference to an ongoing investigation. Mr. advised he had no problem with us speaking with his daug ter. During a sworn taped statement, stated she met Jeffrey Epstein over a ear a o. She was six een years of age and was approached by who informed her that she could make monies providing a massage to pstein for $200.00. had informed her that she would have to provide this massage top ess.made the arrangements with Epstein and his assistants and took to the house. stated and she entered through 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 matchin shower. stein 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 the table. stein selected which oils to use for the massage. Both and 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 instructs As got ressed, starting ru ing his chest. lefil, room, and Epstein e an masturbating himself as rubbed Epstein s chest. stated he continued mastur ating until he climaxed on the tows e was wearing. When asked if he had removed the towel she stated he turned the towel around so 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 met with him downstairs. got dressed and met with Epstein in the kitchen area. She was pal 200.00 dollars for providing the massage. stated she was aware that also received monies for the same t Ing. The second time she went to the house she was again approached by asked if she wanted to return to the house to provide for her to return to the house. stated drove her another massage; agreed and the arrangements were made by to the house and knocked on the same glass door that leads to the kitchen area. The were allowed entry into the house by one of the staff members. led her upstairs to the master bedroom and to finish the massage. EFTA00232859 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 55 Time: 8:47:53 Incident Report Program: CMS301L Ca No • 1-05-000368 (Continued) alone. Epstein enteredi R i room again wearing only a towel. master bathroom area. left this time to do the massage began removing her clothing as she did the last time she was at t e house. Epstein instructed her to get naked. He lay on the table on his stomach as began massaging his legs and back. As finished with Epstein's back and legs, Epstein then turned started to rub his chest and he began masturbating himself. As rubbed his chest, Epstein leaned over and roduced a massager vi rator. He turned it on and began rubbin s vagina and masturbating himself at the same time. state she continued to rub his chest as this was occurring. cS escribed the vibrator/massager as large, grey with a large head. Epstein rubbed her vagina for approximately two to three minutes with the massager/vibrator. He then removed the vibrator from her vaginal area and concentrated on masturbating himself. stated he climaxed onto the towel again and informed her t at t e massage was done. got dressed and met with who was waitin in the kitchen area. She received $200.00 for tilli!!ssage. said she never returned to the house and had no desire to return to the house. was asked if she received any formal massa e training. She advised she had no formal training. was asked if Epstein knew her real age. stated he knew as e asked her questions about herself He was aware she attended and is still attending High School. over onto is back. The interview was concluded. I suggested inform her parents of what occurred at the Epstein house. stated 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. Investigation Continues. ****************************NARRATIvE # 22 ****************** ****** ** NA Reported By: RECAREY, JOSEPH 11/17/05 Entered By.: ALTOMARO, NICKIE A. 11/17/05 On November 15, 2005, Officer Munyan and I res onded to the Palm Beach Gardens Mall food court section to meet with . At approximate) 5:10 p.m., 1 1. arrived and met wit us at the food court. provided a sworn taped statement in which she stated she had . een at the Epstein house over fifty times. She be an going to Epstein's house when she turned eighteen years old. was asked if she knew of the on-going investigation. stated she was aware there-vms—arr-tnvestigatiOn 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. III. stated she did not want to disclose who brought her to the house ut she would EFTA00232860 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 to any 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 masturbate and climax. She stated things escalated from there. She provided oral sex on Epstein and he provided oral sex on her. She stated he would also use a massager/vibrator on her va ina to stimulate her as she massaged him. He introduced his assistant to have vaginal intercourse with IIIIIII She stated would utilize a strap-on (synthetic penis) to hav ith her. She was told to masturbate herself as Epstein an had sexual intercourse. All this was done at Epstein's direc could not provide exact dates as she had been to the house so many times. stated Epstein inserted his fingers in her vagina to stimulate er as she massaged him. When I asked her if there had been any vaginal intercourse with Epstein, she stated she did not have sex with him. She did admit having sex with S his assistant. stated not every time she went involved sexual favors. Sometimes she would just talk with him and get paid. I asked her how much she was paid each time she went to Epstein s residence. stated she got paid $300.00 every time she went to the house. She was told to bring other girls to him to provide massages. declined stating that she does what she does and 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 six. She reviewed the six photograp s an immediately identified as the person with whom she had intercourse. , it was the same person she watched have intercourse with Epstein. She signed the photo line-up under s photo as the person she identified. We then lefAR MI RWIcHreturned I- to the police station. The photo line up and tape were placed in to evidence. Investigation Continues... **************************** N A R R A T I V E # 23 ************************** NA Reported By: RECAREY, JOSEPH 11/29/05 Entered By.: ALTOMARO, NICKIE 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 tetephoned his cell phone and left a message far 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 EFTA00232861 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 EFTA00232862 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 58 Time: 8:47:53 Incident Report Program: CMS301L Ia 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. ****************************NARRATIVE # 24 ********************►***** NA Reported By: RECAREY, JOSEPH 11/29/05 Entered By.: ALTOMARO, A. 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 EFTA00232863 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 59 Incident Report Program: CMS301L Ca,...= 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. ****************************NARRATIv5 # 25 ************************** NA Reported By: RECAREY, JOSEPH 12/15/05 Entered By.: ALTOMARO, NICKIE 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 girls for 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 High School yearbooks for 2005, 2004 and 2003. I firs reviewe e 2005 yearbook and located most of the girls I had spoken with. Additionally, I located Based on the corrected name spelling, I was able to ocate er to her residence in Loxahatchee. On December 8, 2005, Det. Caristo and I responded to in Loxahatchee. at her home. She a vise she is attending HP. is participating in the early release program so s e 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 previousl researched the telephone number for " and telephone number A subpoena had been issued or t e information on The telephone number was re istered to of A • ery of revealed that she is the •aug er o and is current y residing at in West Pa m :eac . Det. Caristo and I attempted with negative results. I left my business card on her front door requesting she return my call. We then responded to in West Palm Beach. I also attempted contact with Mr. wit negative results. I left my business card for him to return my call. contact wit EFTA00232864 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 60 Incident Report Program: CMS301L Cat....; No • 1-05-000368 (Continued) On December 9 2005, I received a telephone call from mother, who was made 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 daughter about what occurred and would cooperate with the investigation. provided me with cellular telephone number to sche u e an appointment for an o icial interview. I telephoned her cellular telephone and made a tentative appointment for Monday, December 12, 2005. I then received a telephone call from father of who stated he found the business cajlillillis door. I exp ained that I was conducting an investigation and needed to speak with as she ma have 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, due to a conflict with schedules, arrangements were made to meet with on Tuesday, December 13, 2005 at 5:00 pm. On December 13 2005, Det. Dawson and I traveled to Loxahatchee and met with During a sworn taped statement, stated t at w en s e was sixteen years old, she was taken to Epstein's house to provide a massage for mone stated it was before Christmas last year when a roached her and asked if she needed to make money for 11/111!as. stated she did and agreed to rovide a massage for money. made arrangements to take to the house and drove to the house to "work." 'I'll' state 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. They knocked on the door and were encountered by an employee thati killi were expected. They were then encountered by a white female who described as a "Spanish looking lady." They informed her with long blond hair. was unable to remember the name of the white female with blond air 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 with a sink to the right. was introduced to Jeff who was on the phone when she entered. Je was wearing a white towel and la on his stomach so that may massage his feet and calves. started the massage with the massage oil Jeff chose and r e is feet and calves. Jeff 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 EFTA00232865 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 61 Program: CMS301L Ca,.. No • 1-05-000368 (Continued) requested she remove her pants and shirt. 'III' removed her shirt and pulled her pants off. III" stayed in rbra and thong panties. As she finished the small o t e back, Jeff then turned onto his back. He instructed she rub his chest and pinch his nipples. As she be an to rub his chest, Jeff asked her questions about herself. remembered telling him she attended Royal Palm Beach Hi h Schoo . Jeff asked her if she was sexually active. Before could answer, he also asked what sexual positions does she enjoy. stated she was shy didn't like talking about those things. She continued rubbing his chest. Epstein reached up and unsnapped her bra from the front. explained the bra she used had a front snapping device. Epstein rubbed her breasts and asked her if she like having her breasts rubbed. said "no, I don't like that." Epstein then removed his towel and lay on the bed naked exposing his penis to He be an touching his penis and masturbated as he touched her breasts. explained Jeff then touched her vagina area by rubbing her 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 , "Relax, I'm not going inside." She further explained Jeff commented to her how beautiful and sexy she was. Jeff then moved her thong panties to one side and now was was." He then inserted A llifigers in her vagina and was stroking her stroking her clitoris. said "Jeff commented how hard my clit within her vagina. She tried pulling back to pull out his fingers from within her vagina. Jeff removed his fingers from within her vagina and apologized for putting his fingers inside her. During this time he kept his hand on her vagina area rubbing her vagina. stated he rubbed her real hard as he was masturbating. sai he climaxed onto the towel he had been previously wearing an got up from the table. Jeff told her there was $200.00 dollars for her on the dresser within the master bathroom. Jeff also told 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 er telephone number with his assistant as he wanted to see her again. Jeff 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 an ew what happened to her was wrong. She 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... **, ************************NARRATIVE # 26 ************************** NA Reported By: DICKS, ALLEN C. 12/18/05 Entered By.: ALTOMARO, NICKIE A. 12/19/05 EFTA00232866 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 of the premises for safety purposes. I then accompanied CSEU tech Pavlik while she photographed the exterior of the house. Once this was complete I was assigned to search certain areas of the house with Det. Dawson 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-hilw 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. EFTA00232867 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 63 Time: 8:47:53 Incident Report Program: CMS301L Case No 1-05-000368 (Continued) ****************************NARRATIVE # 27 ************************** NA Reported By: KRAUEL, CURTIS D. 12/21/05 Entered By.: ALTOMARO, NICKIE A. 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, residence of Jeffrey Epstein. I was instructed by Case Agent Det. Joseph Recarey, to secure all computer and media related material from the residence. Upon my arrival I was directed by Det. Recarey 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. Recarey 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. Recarey 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. EFTA00232868 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. Recarey 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 remote access. At that time, the Dell CPU, marked with Serial Number 6WTVN21, 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 and shutdown all other media. The Premio CPU, marked with Serial Number 2000091078, 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 T I V E # 28 ******+******************* NA Reported By: RECAREY, JOSEPH 12/21/05 Entered By.: ALTOMARO, NICKIE 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 during the week of 12/19/2005. I made contact with State Attorney Inv Theresa Wyatt and requested the same via telephone message. I then researched the victim's cellular telephone subpoena data which had been received from a previous subpoena re uest. 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 incident occurred at Epstein s house. The first incoming call was from residence at The second incoming call from EFTA00232869 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 65 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) cellular phone occurred at 1:02 pm. The call durations were one minute or ess. The time frame was within thirteen minutes apart. It should be noted that s residence was in close proximity to the victim's. The next call occurred at 5:50 pm when the victim telephoned s residence. Several calls were made after the above mentions ca both incoming and outgoing to Further analysis showed no telephone calls to either cellular telephone or residence were registered prior to Fe ruary 6, 2005. Additional) , I also conducted an analysis on the telephone calls from The subscriber information confirmed that the number is registers to A Lavery from Hialeah, Florida. The address was crossed reference 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. The tele hone calls revealed Laver had telephone contact with and either just after I attempts to interview t em, 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 any way one wishes. I found the followin eo le have m and I received a Cingular Wireless packet which contained a CD which contained the results of the subpoena request for verbatim calls on An analysis will be conducted in the near future on the phone n ers called. Investigation Continues. -****************************NARRATIVE # 29 ******** ****************** NA Reported By: RECAREY, JOSEPH 12/27/05 Entered By.: ALTOMARO, NICKIE A. 12/29/05 Upon doing research on the message books recovered in the search warrant I located the identity of The telephone number was registered to She currently is seventeen years old and is atten ing t e Pa m Beach Mall Academy. EFTA00232870 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 66 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) responded to 1801 Palm Beach Lakes Boulevard, also known as the Palm Beach Mall. I located the Simon Youth Foundation. I located a l inside the foundation and informed her that I was investigatin a case 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. at in West Palm Beat iIIII attempted to interview her Det. Caristo and I then located at her residence located aboillielirripstein. 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 our arrival at her residence I had telephone contact with her fathe who was told she would be interviewed. is currently seventeen years old and as a juvenile, parents notification would be required. We then left the area and returned to the police station. While at the police station, I left another tele hone message for parents. I began an anal sis of Cellular to e one. The telephone number is assigned to IIIII and the financially respons e party is Jeffrey Epstein of 457 Ma ison 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 identify additional victims or witnesses. The analysis revealed that had called the victim/witnesses frequently when Epstein was in t e Town of Palm Beach to "work." This confirms 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. ** ************************NARRATIVE # 30 ************************** NA Reported By: RECAREY, JOSEPH 1/03/06 Entered By.: ALTOMARO, NICKIE A. 1/03/06 On December 29, 2005, i received a facsimile from National Compliance EFTA00232871 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Incident Report Page: 67 Program: CMS301L Case No • 1-05-000368 Continued) Center from Cingular Wireless for tele hone number 561- This was the tele hone number for during the time frame when the victim, was brought to t_ e Epstein house to "work." An analysis of the phone records, of all incoming and out oing calls, showed that on February 6, 2005, t ictim, was brought first called at 12:50 pm (EST). house in Pa m Beach, at 12:52 pm (EST). The following call was made to the victim, III 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 the records and enlarged the page 8 of 10 to show the calls made by on February 6, 2005. , Epstein's assistant, 11 was made to Epstein's To this date, I have not heard from parents. I will attempt to establish contact willi M iduring t e 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 Dershowitz and two www.m s ace.com profiles. The profiles were that of and MySpace.com is a social networking service t at a ows m 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 profiles Mr. Dershowitz enclosed. pill who designed her blog to be ° Fucking " still atten s Royal Palm Beach High School, sen s an 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. Dershowitz. Ms. desi!Tiffer blog to be "PimpJuice." Her blog I then reviewed web blog which was provided by Mr. states that her interests include music, theater and weed (Marijuana). I reviewed her packet in which IIII declares her love for her live-in boyfriend. 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 distinct - speech impediment", did not claim to e 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. I made telephone contact with ASA Weiss package and request an interview with and Janusz Banasiak. She advised she wou assist in attempting to to confirm she received the EFTA00232872 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 68 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. ****************************NARRATIVE # 31 NA Reported By: MINOT, LORI S. Entered By.: ALTOMARO, NICKIE A. ************************** 1/03/06 1/03/06 On Thursday, 03/31/05, I started conducting surveillance at 358 El Brillo. At this point I observed at 1155 hours, a Tan Altima bearing FL tag in Roadway, Black SL bearing FL tag in drive, Tan Honda Civic bearing FL tag Mill in Roadway, Black Chevy Suburban in driveway and a Black Cadd Escalade in driveway. At 1325 Hours I observed Tan Honda Civic in roadway, Black Chevy Suburban in drivewa Black Caddy Esca a e in drive and a White Kia car bearing FL tag At 1615 hours I observed a Tan Honda Civic, in roadway, B ack Chevy Suburban in drive, Black Caddy Escala a in driveway and a White Kia car in roadway. On Friday, 04/01/05, I continued surveillance at 358 El Brillo. At 1130 hours I observed a Tan Honda Civic bearing FL tag in roadway, Black S E Cadd Escalade in driveway and a Tan unknown make/model bearing FL to M 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 Black Chevy SW in driveway. At 1558 hours, I o served a Tan Honda Civic in roadway, Black Chevy SW in driveway, Black Caddy Escala e in driveway and a dark unknown model/make car parked in garage. On Saturday, 04/02/05, I continued surveillance at 358 El Brillo. At 0713 hours, I observed a Red Explorer bearing FL tag in roadway and a Black Cadd Escalade in driveway. At 0814 hours, I observed a Red Explorer in roadway, Black Caddy Escalade in driveway and a Tan Honda Civic At 0952 hours, I observed a Red Explorer in roadway, B ack 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 air, teens to early 20's, thin and tall wearing a white tank top and short blue jean shorts, exited the vehicle and walked to the rear of the house. I also observed a Red Explorer in roadway, Tan Honda Civic in roadway and a Black Caddy Esca ade in driveway. At 1310 hours, I EFTA00232873 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 leavin the 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 surveillance at 358 El Brillo. At 0719 hours I observed a Tan Honda Civic 'pill in roadway and a Black Caddy Escalade. At 0934 hours, I observe a Tan Honda Civic in roadway and a Black Caddy Escalade in driveway. At 1057 hours I observed only the Tan Honda Civic On Tuesday, 04/05/05, I continued surveillance at 358 El Brillo. At 1052 hours, I observed a Red Ex lorer in roadway, a Green Explorer bearing FL tag in road rey Altima bearing FL tag in roadway, White Ford Truck in roadway, Black Merce es in driveway being washed by a B M an an unknown dark car parked in the garage. At 1059 hours a Blue Chevy Suburban drove to the house of 358 El Brillo and arked 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: BATES, MICHAEL J. 1/03/06 Entered By.: ALTOMARO, NICKIE 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 Black Chevrolet Suburban, unknown tag, a Black Mercedes 5600 FL tag U90BQL parked in the east driv • ii next 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 Suburban and Black Mercedes along with a Silver Hyundai Accent FL tag parked in the east driveway -and a Red Ford Explorer FL tag 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 EFTA00232874 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 Suburban 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 parked in the street in front of the residence. At 1805 hours the Escalade and 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 observed a Black Mercedes, 4-door parked in the east driveway FL tag At 2300 hours, 2350 hours and 0045 hours, the Black Mercedes was t e only vehicle observed. ***-************************NARRATIVE # 33 ************************** NA Reported By: RECAREY, JOSEPH 1/05/06 Entered By.: ALTOMARO, NICKIE A. 1/05/06 I made contact with Mr. to father of who was told that I wishe to interview his daughter. Mr. stated he was aware and had spoken with his daughter about tie incident. He stated that his daughter had previously told him that she was hired to model lingerie at a Palm Beach mansion. Mr. stated he knew nothing else about what she did when she went to "work." Mr. advised he would cooperate with the investigation and make his aug ter available for interviews. I asked if she was available for an interview, stated she was not at home at the moment. I informed him I wou ma e 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 Telecommunications and Sprint for the unknown telephone numbers from cellular telephone. The subpoenas were sent to the respective to ephone 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. EFTA00232875 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 71 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 New York City, who would then notify Epstein's personal assistant, IIIII, 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 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. 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 s ' der Epstein's direction, he delivered a dozen roses to 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 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 wiLhoul iucideLAL. 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 EFTA00232876 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 High School who Mr. Epstein was. When asked to iden i y ese gir s, 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. ****************************NARRATIVE 4 34 ************************** NA Reported By: RECAREY, JOSEPH 1/09/06 Entered By.: ALTOMARO, NICKIE 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 to deliver a bucket of roses to i El High School after (MI high school drama er ormance. Aso l. in that same note wasdirection to rent a car for ( and direction to extend the rental contract. I returne toillli Palm Beach Police Station and placed the folder into evidence. I received a fax from Verizon from the subpoena request sent on EFTA00232877 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 73 Incident Report Program: CMS301L Case No • 1-05-000368 01-04-06, for telephone number registered to Dr Perry Bard, from est chiropractor and has an office located Palm Beach. The cellular number is Dr number. (Continued) The phone number is a m Beach. Dr. Bard is a 4275 Okeechobee Blvd in West Bard's personal cellular On January 9, 2006, Det. Caristo and I traveled to in been previously seen on the property and through her Palm Beach Gardens in an attempt to locate who had Florida Drivers License and Florida license Plate. A business card was left for her to return my call. We then traveled to the Simon Youth Foundation and located agreed to speak with us and in a private room will. school provided us a taped statement. During the statement, advised that when she was fifteen or sixteen years of a e s II, taken to Jeffrey Epstein's house by her associate, stated this occurred late May 2004 or early June 004. 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. He introduced himself and brought them into the kitchen so that the chef could prepare somethin for them to eat. After having a meal, .. and Epstein brought upstairs to a master bedroom which . large bathroom. She o served a large style shower, sauna and there was a large massage bed also in the bathroom. Epstein entered a room within the bathroom and came out wearing onl a towel. said they would provide a massage on his feet. asked why they are doing this. 'I'll' told her this was part o t e routine and told her to rub his le s an calves. Epstein had told to get comfortable. continued rubbing Epstein's ca ves and feet. At Epstein's direction, then left the room leaving there by herself. Epstein to to get comfortable. removed her blouse and pants and staye in her panties. stated she was not wearing a bra. She believed she was wearing thong panties. Epstein turned over onto his back and began touching her. Epstein touched her breasts and began touching her in her vagina area. Epstein instructed her to rub his chest and rub his nipples. stated the touching consisted over the panties on the first time; he stroked her vagina but stayed on top of the panties. During the first massage, she stated Epstein was stroking her and began masturbating himself-at -the-same timer He put his—hands—under the towel and appeared as to masturbate himself however she never saw his penis. She continued rubbing his chest 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 tell an one what happened at the house or bad things could happen. stated she went to Epstein's house three EFTA00232878 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page Time: 8:47:53 Incident Report Prograff Case No • 1-05-000368 (Continued) or four times total. was very scared and felt very nervous. She knew because of Eps ein 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 remember who the houseman was. She stated Epstein an is assistant would call her at her father's house to arrange for her to come and "work." She advised each time she returned to the house, Epstein would do the same thing. stated it was a routine with Epstein. She would rub his feet an ca ves. He would then turn over and begin to touch her on her vagina area. The only difference was that it was done without panties. Epstein's fingers would stroke her vagina area 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 contacted again. She began to purposely miss the calls when either or Epstein would call her. She once brought a friend, " un nown last name to work for Epstein. She was paid $200.00 or ringing stated she no longer retuned to work for Epstein. Shillilistate that she wanted to notify the police of what happened at the house. stated she was scared of what could have happened to her or her amily if she notified authorities. On January 10, 2006, I received the results from the sub oena from BellSouth Telecommunications for tele hone number 561- The number is assigned to Mr. father in Palm Beach Gardens. I also receive t e resullillrom Western Union which confirmed the money order sent to from Jeffrey Epstein in New York City. The "wire" was sent y Jeffrey Epstein of 457 Madison Ave in New York City on December 23, 2004 at 12:05 pm. The amount 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 the money via Western Union. A copy of the check presented to was also attached to the receipt of the wire. This confirme w at advised she received as a Christmas bonus from Epstein. Investigation continues. ****************************NARRATIVE # 35 ************************** NA Reported By: RECAREY, JOSEPH 1/10/06 Entered By.: ALTOMARO, NICKIE A. 1/10/06 I received and reviewed the Cingular Wireless results from the subpoena requests for subscriber information for telephone numbers and . The first number, , 'is as to Janusz Banasiak in care of Jeffrey Epstein of 457 Madison Ave in New York City. Banasiak is the current houseman/house mana er for 358 El Brillo Way in Palm Beach Fl 33480. The second number, , is assigned to of EFTA00232879 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 75 Time: 8:47:53 Incident Report Program: CMS301L Case • - -000368 (Continued) in West Palm Beach. Research conducted on revealed s e is a licensed Massage thera ist with 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 requested from the Palm Beach County Sheriff's Office. The last number is assigned to Rofrano of 9850 Alt AlA in Palm Beach Gardens. Research on Mr. ofrano, revealed that he is a Florida Chiropractic Physician. Vehicles that were previously documented on the property while surveillance was being conducted were researched. 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. Research was conducted which revealed that the vehicle is registered to and ■ is currently residing in of Lake Worth. Mr. has two daughters, Connecticut and ■ is rest ing with her father in Lake Worth. Research on revealed she was recently involved in a traffic stop in La e lar e Shores in A request to discover any information from the stop was requeste 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 T I V E # 36 ************************** NA Reported By: RECAREY, JOSEPH 1/23/06 Entered By.: ALTOMARO, NICKIE A. 1/23/06 On January 19 2006, Det. Caristo and I met with at in Palm Beach Gardens. was i enti ie as a licensed massage therapist who had previously been seen on Epstein's property when physical surveillance was done. was told of the on going investigation and I felt she may have in ormation 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 some irls to work at the house to answer phones and run errands. accepted the job nd be 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 ALlantic -College-. She continued going to Epstein's house -an would be notified when Epstein would travel to Palm Beach. advised she would be notified by Maxwell, Epstein or , his assistant, when he would travel to Palm Beach. s ated she began providing massages to Epstein before she became a massage ist. She continued iving massages not onl to Epstein but to and his assistant. was asked about w at occurre uring t e massages. state as she was twenty EFTA00232880 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 art 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. He would instruct her to rub his nipples as he masturbated himself. stated she felt "grossed" about the behavior but as she was getting paid, she just continued. also advised she would on occasion perform the massages nakillittein would on occasion, utilize the vibrator/massager on her vagina area when she performed the massages. Sjoberg 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 too 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 p ysical surveillance being done at the property. The vehicle is registered to of Lake Worth, Florida. Researchin Mr. and the vehicle revealed that his daughter, had een driving the vehicle and was cited for unlaw u speed in Lake Clark Shores. e vehicle is a tan, Chevrolet Camaro, 2-door. I researched Ail Worth. date of birth, resides at has a m space page called n In her web page, shows various photos of photograp e• at a each. 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' his office were seen. Additional footage of and was seen. There was other footage seen. f the females is unknown at this time, until such time as I.meet withilemtain females to show the video footage--to--- confirm if in fact, it is them on the video. At this time it appears that and are seen sitting with Epstein beside his desk in t e evening ours. Due to poor lighting, a direct confirmation cannot be made at this time. Inv. Continues. EFTA00232881 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 77 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 ****************************NARRA NA Reported By: Entered By.: (Continued) T I V E # 37 ************************** RECAREY, JOSEPH L/30/06 ALTOMARO, NICKIE A. L/30/06 On January 25, 2006, Det Caristo and I in Lake Worth and met with year, when she was seventeen years through her former room mate Epstein at the time. when they modeled. an explaine and advised her that s e was in Palm Beach and requested to see her. IIIII made arrangements to meet with her at Epstein's house. arrived and met Epstein and and I'l' went to the Palm Beach Mall together and went s opping. a vised that IIIII and she had received money from Epstein to go to the mall. They visited Victoria's Secret and purchased undergarments from the store utilizing monies 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. and continued shopping and having a day together. stated explained how she and Epstein have been datin each other and he as been paying all of her bills. claimed advised they met in New York and had been dating ever since. They ater returned to Epstein's home and encountered Epstein. He had a brief conversation with about her modeling career. He knew of her modeling career from res onded to state ast e, sne met Jeffrey Epstein was allegedly dating ad once cohabitated together called her on her telephone He requested to see her modeling portfolio and explaine t at he could help her with modeling jobs. had her book with her to show and showed the book to stein. He commented negatively about er photographs and portfolio. felt uncomfortable with the comments made as she had been wor ing with other professional modeling companies who had offered her work from her photographs. Epstein requested to see what was purchased at the mall. took out the undergarments which were purchased. She immediate y showed E stein different sets urchased. Epstein then requested to view what purchased. was reluctant to show the outfit however since it was Epstein's money that purchased the item she pulled it out of the bag. Epstein asked her to try it on. looked at who told her "yeah, try it on." Feeling compellTIM try the undergarment 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 went back into the other room and chaniiiiiack into her clothes. returned into the room and told she would be going home. Burns scheduled another day for to return for massayeD with L L. stated within that same week, she returned to meet with and have a massage. had told her that she would be unable to .. with her as she wou be going on a bike ride with Epstein. explained she could stay at the house and take advantage of the massage. EFTA00232882 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 78 Time: 8:47:53 Incident Report Program: CMS3011, Case No 1-05-000368 (Continued) stated she met with an unknown massa e therapist and had the to e already set up in a guest room. removed her clothing, leaving her anties on, and wrapped herse with a towel for the massage. remembered that the door to the guest room was closed but not locked. As the therapist was working her back, 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 chiropractic session. Epstein told turn over onto her back. eventually turned over exposing her breasts to Epstein as he applied pressure on her shoulder and her waist. stated Epstein "popped" her back. removed her self from the to le, got dressed and left the house. further stated had attempted to call her on several occasions to invite her bac to Epstein's house to which re lied "I'm busy." advised she has not had contact with eit er or Jeffrey Epstein. It should be noted that her mother, was present during the interview. The interview was conc u.e. an we thanked them her for their time. ****************************NAKRATIVE if 38 ************************** NA Reported By: RECAREY, JOSEPH 1/31/06 Entered By.: ALTOMARO, NICKIE A. 1/31/06 On Januar 27 2006 I made telephone contact with at . is a licensed massage therapist w o had frequents t e ome o Jeffrey Epstein. Ms. III. has been unable to meet with me in Palm Beach County, and because s e lives and works in Port St Lucie, 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 em lo ed by him for approximately three years. Epstein has paid to erform Swedish Massages (Deep Tissue) on him and other guests. explained that approximately three year ago she met Ghislaine Maxwe and Jeffrey Epstein through a mutual friend. Epstein and Maxwell were looking for a massage therapist. stated since that time, she is notified when Epstein is coming to alm Beach. stated 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. made herliM iuncomfortable. stated she only provided massages I asked if anything occurred during the massage that would have and that was it. She never was approached for anything else. I asked if Epstein ever asked her to rub his chest she stated she would not rub his chest as that is not part of her massage. explained that she was not Epstein's type. The girls she wou see at 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. EFTA00232883 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 79 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) stated she only provided massages for Epstein and his associates and nothing happened during those massages. stated as she does Swedish style massages, the patient is usuall.ne after the massages. I thanked her for her assistance and the interview was concluded at this time. I received a facsimile from T-Mobile Cellular service on telephone number , which is assigned to David Rodgers, pilot for Mr. Epstein, w o rest es in Lake Worth. Rod ere' telephone number was dialed on several occasions by . A background on Rodgers indicated he has a valid FAA pi o icense First Class for the Southern FAA Region. Rodgers has another historical FAA license for Airline Transport Pilot. Investigation Continues. **************************** N A R R A T I V E # 39 ************************** NA On Frida 1:00pm, station. Reported By: RECAREY, JOSEPH Entered By.: ALTOMARO, NICKIE A. During an interview wit Epstein when she turned eighteen years o and was brought to Epstein's house to provide a massa•e. She advised this occurred on May of 2005. She advised had informed her if she wanted to provide a massage for $200.00. a•reed and was brought to stated she had been to 2/14/06 2/16/06 February 3, 2006, I had made arrangements to meet with at the Palm Beach Police Station. At approximately and her friend, arrived at the police she stated she met Epstein's house to provide a massage. the house on many occasions during the massage sessions. also stated she would remove her clothing to provide the massage on back, legsi tiliklst. During the massages, Epstein would masturbate Epstein. advised Epstein would pay her $300.00 to rub his himself as she rubbed his chest. I asked her if Epstein ever touched her breasts during the massages. replied. "Yes." I asked her if Epstein ever touched or massage er vagina. stated he had on several occasions. I asked her if he ever penetrated her with either his penis or any other objects. stated that during a massage he inserted his fingers in her va ina as she massaged him. She stated this occurred one time only. stated the massage would be over when Epstein would climax onto a towel. I asked if she had an formal massage training to which she replied that s e did not. was then asked if she ever brought anyone -to-the-house-to-Awo -fated-she--brought two people-to-the￾house. She advised she money for bringing people to the house to "work." stated she brought a girl named limp and her friend was still wail.l.pgLr in t e lobby of the police station. I thanked IIIIIIII or er time and her cooperation and escorted her to the lobby. I asked Ms if I could speak with her about this investigation. I EFTA00232884 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 80 Time: 8:47:53 Incident Report Program: O4,5301L 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 ertainiiilio the investigation. Ms identified herself as an d resides in Wellington, Florida. She advised approximately a year ag2!he was brought to Epstein's house to provide a massage for money. IIII stated she needed to make money and felt it was a quick way to make some money. brought to the house by and was intro uced to Epstein and his assistant. She was broug t to is main bathroom and provided a massage. I asked her if she provided the massage naked. stated she did. She rubbed Epstein's legs, back and chest. 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 climaxed the massage was over. She was paid her money and left the Epsteinilliouse. The interview was concluded and was escorted to area. advised it occurred one time and she never returned to the lobby. stated she was I located a telephone number for and attempted to contact her on several occasions. I ca e!.1 -EM 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 in Lake Worth. Rodgers was identified as Epstein's pi o . 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 there would be no way of knowing who the passengers were. I mention a recent Rodgers stated he recalled flying on several occasions an did to Ohio, where Rodgers flew to Ohio to pick up remember Rodgers stated once he is in the cockpit, he does not know who t e passengers are. When he prepares the passenger manifests he 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 mylligss card foillir to return my call. On February 14, 2006, at 12:06 pm, I received a call back from Ms. EFTA00232885 Date: Time: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 81 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) on my voice mail. Ms !III, left her telephone number for a return call 561- I e t her a message to return call. Investigation Continues.. **************** ****** ******NAREA NA Reported By: RECAREY, JOSEPH Entered By.: ALTOMARO, NICKIE A. T I V E # 40 ************************** 2/21/06 2/22/06 On February 15, 2006, I made telephone contact with who provided directions to where I could locate her. Det Caristo and I res onded to III III III in Lake Park to meet with Upon my arrival, I met with in the parking lot directly behind MAACO Auto Painting. She was a vised I was there to speak with her about an on investigation that concerned Jeffrey Epstein in Palm Beach. 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 eo le and therefore I should know what happened at Epstein's house. ended the conversation and walked back into her boyfriends usiness, Automotive. Det Caristo and I left the area and returned to the police station. Investigation continues. ****************************NAREATIVE # 41 *********** ***** ********** NA Reported By: RECAREY, JOSEPH 4/10/06 Entered By.: ALTOMARO, NICKIE A. 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 EFTA00232886 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Incident Report Page: 82 Program: CMS301L Case No • 1-05-000368 (Continued) located in Royal Palm Beach. I responded to in Roya Pa m Beach. During the interview stated she knew I would be speaking with her. stated she was first introduced to Epstein when she turne eig teen years old. stated she was sure of her age as it was her senior year in High School. She advised she was brought there to make money and was told she would have to provide a massage to this Palm Beach guy. She remembered she met Epstein and his assistant in the kitchen area. She stated she was taken b one of her riends, for She stated she went upstairs with while E stet got ready or the massage. He exited his bathroom naked and turned around. Epstein asked her if being naked offended her. stated it made her uncomfortable. Epstein then put on a towe an lay on the table. stated she rubbed his back and feet. She stated she had no massage training or experience. stated during the massage, Epstein attempted to touch her him again sill!!!icomfortable il with him touching her. Epstein then uttoc s pulled away as he touched her buttocks. She told cut the massage short and became upset with her. Epstein aid her $200.00 for the massage and told her to leave the house. never returned to the house. She did advise of one time s e went with however she waited in the car for as she did not want to go into the house. At the conclusion of visit with Epstein they left the area. stated she a eard 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 them in their private areas for monies. The interview was concluded as did not have any other information to provide. I then learned from the original victim, III the defense attorney had learned of her identity. I spoke with the ather of the victim, who stated there has been a private investigator on his house photographing his family and chasing visitors 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 T T V R 47 ************* ************ 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, 2006, at approximately 7:30 p.m., I personally served the parents of who had informed me that the private investigators were still p otographing the family. On April EFTA00232887 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 Il at her residence in Royal Palm Beach. The subpoena was given to her mother, III I learned through one of the victims imi that she was personally contacted through a source that has maintained contact with Epstein. The source assured II she would receive monetary compensation for her assistance in not cooperating with law enforcement. II also stated she was told, "Those who help him will be compensated and those who hurt him will be dealt with." I told III that tampering with a witness/victim is an arrestable offense and very 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 Dawson and I traveled to Tallahassee, Florida and met with the victim, III identified w/F, as the perso!ilto approached her in Ro al Pa m Beach while s e was ome during Spring Break in March 2006. also stated she did not want to pursue the intimidation charges on II was 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 Beal. 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 -At-Ey- Alan Dershowitz. 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, ASA Belohlavic stated that was the only offer made as to one victim, ASA Belohlavic cell phone rang and went to voice mail. She chilled her voice mail and played the message on speaker. The caller identified himself as EFTA00232888 Date: 7/25/06 Time: 8:47:53 PALM BEACH POLICE DEPARTMENT Page: 84 Incident Report Program: CMS30IL 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 would come from the Chief of Police. She explained to have Chief Reiter 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 messages and discovered a message from EG, 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, 2006, at approximately 4:30 pm, State Attorney Investigator Tim Valentine called to officially notify me of the cancellation of the Grand Jury. He requested I contact the victims that had been served to appear, to notify them of the cancellation. I advised Valentine 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. ****************************NARRATIVE # 43 ************************** NA Reported By: RECAREY, JOSEPH 5/04/06 Entered By.: ALTOMARO, NICKIE A. 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 with certain minors and one count of Lewd and Lascivious Molestation. , Epstein's assistant's, arrest warrant request was or 4 counts of Principal in the 1st degree Unlawful Sexual activity with certain minors and one count of Principal in- the Iht degree Lewd and 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 EFTA00232889 Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 85 Time: 8:47:53 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. ****************************NARRATIVE # 44 ************************** NA Reported By: RECAREY, JOSEPH Entered By.: ALTOMARO, NICKIE A. 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 Explorer, white in color. The vehicle has a Florida registration of F30QQP. Norr left Epstein's house and traveled north on County Road. Det Caristo and I conducted surveillance on Norr. Norr traveled to several construction sites and checked on certain jobs. Surveillance was discontinued on Norr and Det Caristo 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 Inca 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 ex lained o her I had 'wiled arrest warrants for Jeffrey Epstein, and I asked that she either issue the warrants or direct ile, as so much time has elapsed since the original request to the Grand -Jury-.---1--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. It*************************** NA Reported By: 6/05/06 5/15/06 5/15/06 NARRATIVE # 45 ************************** EFTA00232890 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.: ALTOMARO, NICRIE A. 6/06/06 On May 22 2006, I received several phone calls throughout the day from Mr. II who stated he had been followed aggressively by a private investigator. Mr. stated that as he drove to and from work and running errands throughout the county, the same vehicle was behind him runnin other vehicles off the road in an attempt not to lose sight of Mr. 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. Rrischeris office scheduled on June 1, 2006 at 9:00 am. I attempted to call ASA Lana Belohlavek to inform her of the private investigators following Mr. 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 Mrs. I who advised they were able to acquire the private investigators license plate information. The subject following them was again driving very aggressively and caused Mrs. I to run off the road. Mrs.. stated 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 discovery of the threat made against one of the victims in this case ( I re ested subpoenas for all calls made to and received from during the month of March 2006 for her cell phone and home phone. I had confirmed with Florida State University 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 In/Out 7-Mar-06 11:03 AM 492 Outbound 7-Mar-06 11:16 AM 6 Inbound '-Mar-06 11:22 AM 887.2 Inbound ,Mar-06 11:37 AM 48 Outbound To/From 'oar-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 EFTA00232891 Date: Tim9: 7/25/06 8:47:53 PALM BEACH POLICE DEPARTMENT Incident Report Page: 87 Program: CMS301L Case No • 1-05-000368 (Continued) of call in seconds, inbound or outbound calls and calls made to or from phone. 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 at 11:16 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 intimidation. Immediately 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 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 A ril of 2006. I also noted that there was no 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. ****************************NARRATIVE # 46 ************************** NA Reported By: RECAREY, JOSEPH 7/12/06 Entered By.: ALTOMARO, NICKIE A. 7/12/06 On June 29, 2006, I had spoken to ASA who informed me that the case would be sent to the Grand Jury for charges. She informed me that the rand *ury would convene on July 19, 2006 to hear the Epstein case. stated State Attorney Barry Krisher made the determination to go the Grand Jury to hear the case. On July 12,___2006, I spoke with Mrs II mother ct_the victim, 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 * * * * * * * * * * * * * * * * * EFTA00232892 LM BEACHtiOLICE DEPARTM PROPERTY RECEIPT -1:IPD Fern. osz CONTRIBUTOR'S COPY PROPERTY CI FOUND 0 DECEASED (Probated) CI PERSONAL CI CONFISCATED U DESTROY 'EVIDENCE CI TRIAL U LABORATORY 0 STOLEWRECOVERED ROPIER ... INCIDENT/CITATION NUMBER Q DATEMME RECOVERED titilOc ItA ii ol --P-- ) PROPERTY. NUMBER (Leave MHO BIN NUMBER eantiordo A DRESS WERE PROPERTY IMPOUNDED :2;!Lt..). 4.-jt 34/)01 0 f ll) f`, l iet C 0 AD PC RC ';sLifir).0 P6P DISCOVERED BY I 0.0.B. ADDRESS Street City ZIP PHONE SUSPECTS NAME /D.0.B. ADDTNL SUSPECT / D.O.B. ADDRESS Street C4y Zip PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM CI GO DAYS NOT CLAIM 0 ITEM * QUANTITY VALUE DESCRIPTION ...t ':' - is' I"'. Y'N ' c:.0-7-'i ,,-.1 — i;;-- r i hi c :;-, r Art ::: - • i . 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 recetst I hereby acknowledge by me In the official e\ A, that the above list represents all property impounded performance of my duty as a police officer. --,\ . , I, ... jaicat bi SIGNATURE DATE SIGNATURE IDS . UNIT , RECEIVED BY REASON k I DATE/TIME RECEIVED `i t C, / 7 • c it—• . , s :: _ EFTA00232893 LM BEACH POLICE DEPARTMO PROPERTY RECEIPT .‘ DE rucT NIF EVREAU PBPD Farr OS2 -I PROPERTY 0 FOUND CI DECEASED (Probated) CI PERSONAL 0 CONFISCATED U DESTROY AEVIDENCE .cl TRIAL 0 LABORATORY CLI STOLEN:RECOVERED U OTHER INCIDENT/CITATION NUMBER 05 ' 1,.; 6 DATEMME RECOVERED osic.;?.c....::s PROPERTY NUMBER tteave Blank) 7—.. L.-) t-- . i 2 ; . — i-, Li _.) BIN NUMBER (Leave Bark) i 2 k 13 "1 ADDRESS WHERE PROPERTY IMPOUNDED LI "' Cr, fq . I.;_kff,,T c i.' , ' A ii td.; '.. DISCOVERED BY /0 0.8. ADDRESS Street City Zpo PHONE NUMBER ADDT'NL. SUSPECT, D.O.B. ADDRESS Street City Ea PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM U 50 DAYS NOT CLAIM U ITEM i QUANTITY VALUE } I . i:'...,C).‘...; TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represorts all properly taken from me and that I have received a copy of this receipt I hereby acknowledge that the abovo hit represents all property impounded by me in the official performance of my duty as a police officer. ; t SIGNATURE DATE SIGNATURE ID* UNIT RECEIVED BY REASON DATEITIME RECEIVED ' 1 1. . i • • • _.#4 EFTA00232894 OLM BEACII.POLICE DEPARTM PROPERTY RECEIPT CONTRIBUTOR'S COPY PBPO RCP 052 in. PROPERTY CI FOUND OECEAS (Probated) U PERSONAL 0 CONFISCATED 0 DESTROY SE-VIDENCE 0 TRIAL . 0 Lae° Y 0 STOLEN/RECOVERED CI OTHER INCIDENT/CITtRON NUMBER 3.1e,it), DATETME RECOVERED PROPERTY NUMBER (Lays Sena) ( , ' •J r C. BIN NUMBER Boom Blare) ‘,., / ..), if / 7 - 7 ADDRESS WHERE PROPERTY IMPOUNDED 4 , menea s•- .,. .,. • ../. PHONE NUMBER ' f'ker 4.. 2 C.: t , .... 1,--F i:/. :„ .? .7, . b•, .....1 r' 7 _.'!'g I- i. 1 ...7 I'L I L'I , :9'j ., :/.3q ‘ r it..., $. 1 1`C, ADDTNL. SUSPECT/ 0.0.8 ADDRESS Steel City Dp PHONE NUMBER , ERTY CLAIM CI 90 DAYS NOT CLAIM 0 ITEM t QUANTITY VALUE DESCRIPTION t I . It /C O TA AR ' I4%) .--i cc t: .‘ L't11,',t„r TOTAL PACKAGE WEIGHT I hereby acknowledge that the above 1st 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 knpounded by me inthe official performance-of my duty as a polIce officer. r . I 11 A; ii1 ', l SIGNATURE DATE SIGNATURE ID. UNIT RECEIVED BY REASON /I DATE/TIME RECEIVED L., , li. . EFTA00232895 " 1" 00MelloriFFROVOW:Ae3P.Ors re. :LM BEACH POLICE DEPARTME-n￾PROPERTY RECEIPT POPO Forn .!2 1 PROPERTY ... U FOUND Q DECEASED (Probated) 0 PERSONAL U CONFISCATED 0 DESTROY ?(EVIDENCE sS iTRIAL U LABORATORY USTOLEN:RECOVERED U OTHER I CIDENT,CITATICN NUMBER OS -310K DATE/TIME 031It6tec RECOVERED it TO i.- s PROPERTY NUMBER Mayo Blew ( /- • -"! C. 7 7 ' BIN NUMBER (Leave Mark) 7 2 t 1 (. j N. ADDRESS WHERE PROPERTY IMPOUNDED -2-LI C: __--- <7O (- (2-0 P4+ 1 C7r/ el- EA P6; ii- 1 32 ,-; :,-T DISCOVERED BY; D.O.B. PA 6A-v4 C1- :-.1‘ - ADDRESS Street Cry Zp PHONE NUMBER le.c.q.{ € ePlif . !r,1 O , . ' g r L 6,12.1.t.0, Pt Ft, 33ti Ill,) ADDTNL SUAPECT; D.O.B. AD DRESS Strom! City Ip PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CI Atm :...j ;40 DAYS . Ncy '• AR' i;, I EM e QUANTITY VALUE DESCRIPTION ... • ".,•;t: ; 6( Cd.fl e. .0 i . , . Oto , ' e u r . s ,... • --r .. •. . , - . i , . TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents all property taken Iron me and tat I have received a copy of this receipt. I hereby acknoeledgo that Ihe above I sI represents all property impounded b me in the official performance of my duty as a police officer : • I -. r'l r • . F,' P:Sel - . l---t SIGNATURE DATE NATURE • . ID* UNIT RECEIVED BY REASON DATE/TIME RECEIVED - ti ‘.7, 27, .) — C• ( 6 7 c• DETECTIVE BUREAU EFTA00232896 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT 0 comp 252 IMINIUM o N0IR 22849 EVIDENCE GU0S vuinal O PROPERTY O FOUND O DECEASED (Probated) U PERSONAL O CONFISCATED O DESTROY $.EVIDENCE isi MEAL O O STOLEN/RECOVERED O OTHER INCIDENT/CITATION NUMBER 05M% DATF-MME RECOVERED 033005 4:00 Mil PROPERTY NUMBER amo BleM) os--atitt BIN NUMBER (Isar NANO efzils-7 ADDRESS 4200 WHERE PROPERTY IMPOUNDED A 05TQA-Ct Ahl A WP6 Fl CifiGitaiD6e Pima mkt* DISCOVERED BY / D.O.B. PAiltr4 '3)51 ADDRESS PHONE NUMBER PHONE NUMBER PHONE NUMBER ADOTNL SUSPECT/ O.O.B. ADDRESS Snow cry 20 PHONE NUMBER SPECML INSTRUCTIONS FOUND PROPERTY CLARA CI 90 DAYS NOT CUUM O ITEM I QUANTITY VALUE DESCRIPTION I I tit/Di 0 TAPE 1' MAMA; 0O 4%2- 6-H 7,-- 4 w(ok *a_ -is buok..... TOTAL PACKAGE WEIGHT I hereby acknowledge that the above 1st represents a property taken from me and that I have received a copy of 999 receipt I hereby acknowledge that the above hat represents all property impounded by me In the official performance of my duty as a ponce officer. .._ c€05t Ot Sr`teiTURE DATE SIGNATURE IDI UNIT RECEIVED BY REASON DATE/TIME RECEIVED '41$3' 7 45-2 03- 31- O Se— 6'166 if ,AA, Toss -kwes-t) or 02 o i l 00'6 S14/ %ca F 7 V 0 yk\i: rzkncta kk 5 440, is- K0,0-;; - rca 0 3)-- c4ed a fa, if friiii._ 4r `Oh'eti 0 41' 20 -01". /94S ...b i '3 i ca... s7)-7 ' Sly' 411,4wz. . tre-0,5 mem EFTA00232897 itEc•"'"" 'flan* eF'firotamas.SeWtot-Pwa.,-41hWar.4,4"st .. .Wircrr.i. 11ar.emaucwaes P"'n0Forme52 (-7\ LM BEACH POLICE DEPARTMEel PROPERTY RECEIPT DETECTIVE BUREAU J PROPERTY O FOUND O DECEASED (Probated) .t.3 PERSONAL U CONFISCATED U DESTROY Z EVIDENCE REM a LABORATORY STOLEN/RECOVERED U OTHER IDENT/CITATION NUMBER 5' 9iet.0c) ‘ DATE/TIME N,t4, RECOVERED , , i, ,,,--- PROPERTY NUMBER (Leave Blank) --, . r. BINUMBER (Leave Am LI Blew (CC ADDRESS WHERE PROPERTY IMPOUNDED .91t - , ...v ,Th (7) •.' -1 ..' , . --4-:, -; "Th DISCOVERED BY / D 0 8 ADDRESS Smear Cray Zip PHONE NUMBER 1 e ADDTNL SUSPECT/ D ae ADDRESS aet City Zip PHONE NUMBER m HOPER1Y CLAIM —I . i ‘:: actv qkA/ ,(1a'ri t leaVAIS d TER i QUANTITY VA LIE. 0.; l'IW- ' t ' ."i tr:.f;DEgtEtirSlO sn" • r ,. .k.,";1.;,, , otkivfi, l*i.P.,: • q . '''.. A' (r' W •;45:F.,tilr, y r 4 , . _ _ ini _ _ 1 -- ,-- ,-- Orr - 1 TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents al property lakon 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 , ID/ UNIT RECEIVED BY ... REASON DATE/TIME RECEIVED - . . t..° ,_,..,../..._,- - L ' 1 c_ i z4 - o 4; /5c. c‘1 EFTA00232898 DLM BEACH POLICE DEPARTMEZ) PROPERTY RECEIPT DETECTIVE BUREAU PBPO Fonn 452 1 PROPERTY U Lrn FOUND U DECEASED Probated/ L.1 PERSONAL C:I COVFISCATED. U DESTROY EVIDENCE W TRIAL j LABORATORY U STOLEWRECOVERED U OTHER INCIDENT1CITATION NUMBER (''. c. • 3(.e/ IDATERIME ii At I:ARECOVERED ; PROPERTY NUMBER i Lowe Wank) IBM NUMBER (Leave Birk) o r _ 2.7 , I lir; ( i' I 'T i 4 I i t -: G ADDRESS WHERE PROPERTY IMPOUNDE / 1 IL :'.3 i ; 2. „... / DISCOVERED BY/ D.0 B. 1)C1( )1 , NI ' ' - ADORES Stroot Oty Zip PHONE NUMBER I OWNER'S NAME I O.O.B. ADDRESS Servo/ a Z p PHONE NUMBER SUSPK:TS NAME /DOB c, i-> . P: €0;rE, i ii - • 7-- - ,, /0.1 ADDRESS Street Gp /p ;5rt, ;t I. i PHONE NUMBER ADDTNL SUSPECT, D.0. B. ADDRESS Spoof Cry Zr PHONE NUMBER 7 SPECIAL INSTRJCIIONS FOUND PROPERTY - CLAtM ,...1 • e S9 DAYS. ::!. 1 ,i(Oy aiAkiJ : ' teM OUANTITYs /421/4, - PT 0 L.v, WW1 . /. • "t tn,kferni.7 )2:11 ... • L. ez., tt 41.4 ...-., 1 . I le _ I , 1 1 TOTAL PACKAGE WEIGHT '`fl rg: bi from ("lard SIGNAT JRE a:knsaredgc bat the above ',S! reproz.ent a I proper''. takon that . roe received a copy a' his receipt DATE I hereby ackt o &edge that the abode ;1st ropressnts all proporly ikpoundei by me in the ortcta1perfarmance of my dtry as a aohce cif cor. 1: 1. • .i. h - --,- — :-11 -,I ‘ r 7 ..". ',.. SIGNATURE 1 Qs UNIT L RECEIVED ._, ED BY REASON i DATE/TIME RECEIVED 54A ec: 7.—CP (// /(C L 7,, ,.. I EFTA00232899 DLM BEACH POLICE DEPARTMENT PROPERTY RECEIPT o- onForm .52 DETECTIVE,BUREAL. -1 PROPERTY j FOUND. U DECEASED (Probated) U PERSONAL U CONFISCATED LIDESTROY di EVIDENCE Q .TRIAL 0 LABORATORY O STOLEIVRECOVERED D OTHER INCIDENT/CITATION NUMBER DATE/TIME RECOVERED ° LI. 0) . 05 PROPERTY NUMBER (Lam) Blank) r 5 - 3-7'll BIN NUMBER (Leave Blank) /.), 5 5;-- ADDRESS WHERE PROPERTY IMPOUNDED ' • •-• I 1'. L L. - 1 : 1. ; - 1..: ".. _.;-: et - r r. ,. • r t ( / .. e . . DISCOVERED BY / D.O.S. I r: •, -,4 ffnti iz4 2t,-_,,-1 ADDRESS Streel Cly ' Zip PHONE NUMBER OWNER'S NAME / D.O.B. ADDRESS Street Pry Iv PHONE NUMBER SUSPECT'S NAME/DOB l ,../• _1 r . ‘ • P.) ) );-'_ r 4- ; t ADDRESS Street Cry Zip .-C. PHONE NUMBER ACDT-NL. SUSPECT, 0.0 B. ADDRESS Sweet Cry Zip PHONE. UMBER SPECIAL INSTRUCTIONS F rW F14::FE,;:"r IiI.A.1.1 -.1 '.K 'IAY:3 • ir 1. J11S1 Li. I N... I OJANI 'v' VA'_UF a. I i * I ■ It . I TOTAL PACKAGE' WEIGHT I h reby ackrowledge that the abo• e list represents all property taken me and that I haw, received a copy of th.s receipt. I hereby &knowledge thlt to apes° ist represents a I Property rn2Dunde d by me n the offioial perlormanCe of n-.y duty as a police officer. _...•i. t ' • f . i —. 1`) I 'SIGNATURE . . . SIGNATURE ID= EINiii . 1 DATE RECEIVED BY REASON DA- E IME RECEIVED t ,-: r '7 (e-• EFTA00232900 - 9LM BEACH POLICE DEPARTME PROPERTY RECEIPT POPO Fenn '52 3 PROPERTY ...1 FOUND U DECEASED (Probated) U PERSONAL U CONFISCATED C.) DESTROY 53 EVIDENCE J TRIAL U LABORATORY 0 STOLEN/RECOVERED CI OTHER INCIDENT/CITATION NUMBER DATE/TIME RECOVERED PROPERTY NUMBER (Loaye Blank) BIN NUMBER (Loave Blank7 ADDRESS WHERE PROPERTY IMPOUNDED DISCOVERED BY IO.O.O. ADDRESS Street Coy Z7r) PHONE NUMBER I OWNER'S NAME / D.O. B. ADDRESS SPOOF C141 Zp PHONE NUMBER SUSPECT'S NAME / D.O. B. ADDRESS Spool City Zp PHONE NUMBER ADDTNL. SUSPECT /DOB ADDRESS Strout City 4, PHONE NUMBER SPECIAL INSTRUCTIONS I FOUND PROPERTY CLAIM Q ., . , • IT- 90PAYS:•• . •NCIEPOSt.411 ITEM K , 1 QUANTITY ti VALUE, .: j * . - .*soirmom ;, 7 e.... f .''''.'4$4,14itb:..,;,,,s;, .e,-.ww. z.t. ..'. e ttli .r/ •p t i r& -•'-- i .. . . P i s _., .— — 1 --- TOTAL PACKAGE WEIGHT I Tereby adblowledge that the above list represents all property taken from me and that I have rece rved a copy of this receipt. I hereby ackncylodoo that the above list represents all pinny impoun d by me in the official performance of my duty as a police officer. _ _ - 'T -- ' I : — _ .... SIGNATURE DATE SIGNATURE ID*. UNIT RECEIVED BY REASON DATE/TIME RECEIVED it / •/?' ('"-- DETECT,VE BUREAU I EFTA00232901 1.)LM BEACH POLICE DEPARTMET PROPERTY RECEIPT DETECTIVE BUREAU PBPO Fenn 052 ri PROPERTY U FOUND Ul DECEASED ;Probaloce D PERSONAL 3 CONFISCATED CI DESTROY ‘'Ire EVIDENCE ja TRIAL LABORATORY 3 STOLEN/RECOVERED 3 OTHER INCIDENT/CITATION NUMBER 17):' l i., 7 DATE/TIME et -1' RECOVERED CK. 0'7 Oriic PROPERTY NUMBER (Leslie Baffle I SIN N MSR (Leave Blank) I - \ i . — 2,(C) L i -' r CA -- ADDRESS WHERE PROPERTY IMPOUNDED l; 5 ; -•1 It L C.. .. V • '. 1 ..) t k 1 ....• "..: i • DISCOVERED BY/ D 0 8 ADDRESS Street Cffy Zig 14 4: \ 1 il;q PHONE NUMBER OWNER'S NAME/ 0 0 8 ADDRESS Street City 21p PHONE NUMBER 1 - SUSPEcrs NAME / D.0.8 ADDRESS Street Cay Ip PHONE NUMBER €c".;:ii: ;A ,:j - r I i: 't t °it i ,,. • • • .'n e , • C￾ADDTNL SUSPECT/ D.0. 8 ADDRESS Street City 7p PHONE NUMBER SPECIAL INSTRUCTIONS FOI. ND PROPERLY et a v i ITEM a OJAN'ITY I VALUE i DESCRIPTION i _t ---. 7 ..I I_ i — -- - - - ':. ,.• L I I I I 1 I^r c ;lit; F. --- c.;--1÷.•:,;,;:1; Thc. VI i it i \ ' 14/ 4 - t La._ -In i r (-10z,,,, , I .h• • ,, ..,b, - TOTAL PACKAGE WEI I hereby acknowledge that the ahoy° list represents at property taken from me and that I have roceivod a copy of this receipt. I hereby acknowledge that me abevo list represents at property impounded by mo n the offal' performance of my duly as a police officer. -', SIGNATURE — - DATE SIGNATURE IDe UNIT RECEIVED BY REASON j DATE/TIME RECEIVED et IA t.1.-4 . n ., •71100.1Mlil W. EFTA00232902 :)LM BEACH POLICE DEPARTMEN(J PROPERTY RECEIPT DETECTIVE BUREAU PBPD Form N52 I r l PROPERTY D POUND U DECEASED (Probated) CI PERSONAL PERSONAL O CONFISCATED U DESTROY qa EVIDENCE ali TRIAL a LABORATORY I U STOLEN.RECOVERED $ OTHER INC:DEN 'CITAPON NUMBER DATE/TIME RECOVERED PROPERTY_ NUMB" ,Lea.e Blank) BIN NUMBER iLea..e titerk) m ,' C.-- --• ADDRESS WHERE PROPERTY IMPOUNDED 7, 5 e D. .1, IL.?, : • ! ,,, DISCOVERED BY co 0 El - a ,‘ Ph 1-7( INI FO541 ADDRESS Strest City Zp PHONE NUMBER OWNER'S NAME r/ DO 9 ADDRESS SToOl C,'/ Zp PHONE NUMBER SUSPECT'S NAME; 0 0 B. ADDRESS Street City Zp PHONE NUMBER ADOTNL SUSPECT/D.O. B ADDRESS Street Ip PHONE NUMBER SPEC al r.. .:TRUt;TIONS - Fol:V) '' ), F r CLA V J tA , AV T \. .I: f i 1;1- • ESCF.IIP FOP/ . .:1,1 , i r-. i c:1;c • _A i A . 'P ltt i Et a-- %kV 1.) I t 2 11— ' r ( — 2 C I -‘ -- 2- 1 L ,-, .. • z-- i r . • - .....1 • 1.) I ( • g i I t ' 4I I PI(' . H . .7r. _ i .-- . I I 1 1 -- __ ____ _ TOTAL PACKAGE WEIGHT I boreoy accnowtodge that 'ha abc-e at represents all pct. al i tcke- , from rno and that i hoe race "ed a copy of 'his race at 1 I t °tern ackrow edge Vat Yit) atone fly? represents all PraIDORY Impounded by me in 'ho off cia' pertorranw of ny duty as a police alba'? SIGNATURE D 4C E SIGNATURE I . UNIT I • RECEIVED al REASON DATE TIME RECEIVED C 7 ) ' I ' I by \ ...1 7 e 4,,, EFTA00232903 :Inigrflgliaaintaa-Crara)W.K.MyrApsce - -4”rvoonogarr.....twirrytain PEP] Pcfm '52 I PROPERTY I 0 FOUND 0 DECEASED (Probated) 1,0 PERSONAL 0 CONFISCATED 0 DESTROY Lie EVIDENCE i 0 TRIAL 0 LABORATORY 0 STOLEINMECOVERED 0 OTHER i INCIDENT:CITATION NUMBER DATE/TIME RECOVERED 00 'I I' e C ()Clic l'hiS PROPERTYNUMBER IL•av•Eliank) 1 .5- BIN NUMBER (..e. m3 flank' J ADDRESS WHERE PROPERTY IMPOUNDED DISCOVERED BY /DOB ADDRESS Street aty Lp PHONE NUMBER OWNERS NAME / D 0 8 ADDRESS Street City Ly PHONE NUMBER SUSPECTS NAME/ D.0 '''.> - • - ft t ', I P f -€ B. ADDRESS Stater City - ..,,, .1,4 PHONE NUMBER , C', i ,, ADDTNL. SUSPECT/ D 0.0. i ADDRESS Savor City PHONE NUMBER SPECIAL INSTRUCTIONS r,OLIND PROPPRT. TLA.v _I Y. DAYS NOT; .E.;',1 J ITEM p cuAnTrry VALUE, ' DESCRP7ION r ' ' .)_LL,. I I , 1 . ' • i i c0. I 13' 4$ - • ,, . — ? .--t•-, r. r:r •. 1 1 TOTAL PACKAGE WEIGHT I hereby acknowledge from me SIGNATURE that and that I nave the above received a list represents copy of Oils all receipt. properly taken I hereby acknowledge that by me in the official performance t . t '‘ ‘ \ :he above fist represents o my dr.ty V . M all property impounded as a poke officer. c t ri IDN UNIT .. •fp..k.il, DATE SGNATURE RECEIVED BY • REASON DATE/TIME RECEIVED • - --4.-...7./C - re . r 7 2/3/ D .17:--)) - t) c7 ( c % i let e '.1- 1•4 ,•e.t.a.ia76:te):4:4,4:or;o0e;ete ... -. • ., . .4 :fr..1,:J 4.. -' 1. ThLM BEACH POLICE DEPARTMET) . , PROPERTY RECEIPT DETECTIVE BUREAU EFTA00232904 viff enfavcrAzamearxantspnravirt. `v%n""r"+"""wn'i"'^a.ic'"':"F?t,,,v. MLM BEACH POLICE DEPARTMEr) PROPERTY RECEIPT Polin F)rrn cs, J PROPERTY U FOUND U DECEASED (Probated) D PERSONAL O CONFISCATED CI DESTROY EVIDENCC tila TRIAL iJ LABORATORY CI STOLENRECOVERED U OTHER INCIDENT/CITAT/ON NUMBER DATETIME RECOVERED PROPERTY NUMBER (Leave Stank) BIN NUMBER (Leave Burk) ADDRESS WHERE PROPERTY IMPOUNDED -./ JC• L.- ( !...JI(.. . ( I - , , .2 . ' I : _...,._,LE. DISCOVERED BY / D.O.B ADDRESS Street Cat Zip i PHONE NUMBER OWNER'S NAME / D.O.B.' ADDRESS Skeet Cay 2,o I I PHONE NUMBER SUSPECTS NAME i D O.B. ADDRESS Street City 2,e PHONE NUMBER ADDTNL. SUSPECT/ 0.0 0. ADDRESS Street Ce), Zp -i￾PHONE NUMBER SPECIAL INSTRUCTIONS IIIIL II DESCRIP- ,ON, ., J . I - 1 . _ _ — I _ _ --a. . . . TOTAL PACKAGE WEIGHT I hereby acknowledge that the above Ilst represents all properly taken from me and that I have received a copy of the receipt. --(• I hereby acknowledge that the above list represents art property impounded by mo in the official performance of my duly as a police officer. i. Li \--.. • ' ''' \ n' ' ' L)i .= SIGNATURE DATE SIGNATURE J I00 UNIT RECEIVED BY REASON DATE/TIME RECEIVED ) 1 , DETECTIVE BUREAU EFTA00232905 -)LM BEACH POLICE DEPARTME, _ "Th PROPERTY RECEIPT DETECTIVE BUREAU PBPD Form esc I ..-1 J PROPERTY U FOUND Ll DECEASED ;Probated) U PERSONAL CONFISCATED 0 DESTROY I.Jil EVIDENCE U TRIAL U LABORATORY ...I S LEN/RECOVERED r,-..1 OTHER INCIDENT/CiTATION NUMBER .. 1_ • 1 . ..:#41, r DATE/TIME 0., m RECOVERED or c ia PROPERTY NUMBER (LeaveLeona) f -',. C .,1 -• .2..,;:': 0 ,- • BIN NUMBER (Leave Blank) / -I er: CC - (;:r2. _r ADDRESS WHERE PROPERTY IMPOU 4DEO Y t . DISCOVERED BY/ D.0.8 PAC, IN \I?)):(1 ADDRESS Stroet Cl)' Zip PHONE NUMBER OWNER'S NAME!D.O.B. ADDRESS Street C.ty Zip PHONE NUMBER SUSPECTS NAME ID 0 B ADDRESS Street Cly Zip PHONE NUMBER ADDY NI. SUSPECT/ D.0.8..OB ADDRESS Street City Z/p PHONE NUMBER II SPECIAL INSTRUCTIONS -- '-, "Cli.', --f C....1 0,1 lj k'C] i hi. 0 ANTI TY . ,ALLE: . SC I I . ..;t- -Th ' I - I￾i- t - .. - _ 1±:-..*:, ::::_..i, .{. ;. t- •-•::-T- ,... -__:_J-i_s_ _ TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents al praperty taken from me and that I have received a copy of this receipt. I hereby acknowledge that the above list represents all property impourvied by me in the official podormance of my duty as a peace officer. t , ,• '-.. • .1 Di SIGNATURE DATE SIGNATURE 'Dr . UNIT RECEIVED BY REASON. DATE/TIME RECEIVED ____ EFTA00232906 7..~."•"'" , :lrcWS 0^ : 1." --"177/ - .^`TijOribtlaf - jeScstri.." ,r 4.1 nLM BEACH POLICE DEPARTME9 PROPERTY RECEIPT PBP0 Form 1052 3 PROPERTY J FOUND j DECEASED (Probated; LI PERSONAL U CONFISCATED C] DESTROY 561 EVIDENCE 21,TRIAL LI LABORATORY LI STOLENRiECOVEREO 0 OTHER INCIDENT/CITATION NUMBER 05 . C.':- K OATFJTIME C' 0 I RECOVERED I I I :_' 5 r i ; I: PROPERTY NUMBER (Leave Blank) r _ .: BIN NUMBER (Leave Blank) r ir m / e:- ( (-- .1 .i.., .C.•;-..-' ADDRESS WHERE PROPERTY IMPOUNDED - . —, DISCOVERED BY/ 0.0.B . P Ac--, Alm E.).)0 3 ci ADDRESS Sdoe, Cly ZIA PHONE NUMBER I OWNERS NAME / D.O.B. ADDRESS &Net City Zip PHONE NUMBER SUSPECTS NAME / D.O.B. . • • l', ' . . — II / I— I ..-1 II In i ytt.e ... , ii.., ADDRESS Sfrea Cary Zip ,.. • .). —t, ,___ PHONE NUMBER ADDTNL SUSPECT/ D.O.B. ' ADDRESS Stroof GWY a. PHCNE NUMBER SPEC/AL ()Lift; INSTRUCTIONS IT pC ,f.LI PRCIIENTY CLAN :_./ 7.) DX( S . \Cr ClIA'Y j ..I EM 1J I QuAN h TY ! VALUE --( HIPMON ' 1 ;-/- ' I 1_ L ..,, ,..... I I ., 1 _ -i- -.--.-...., • TOTAL PACKAGE WEIGHT I hereby acknoviledge that the above fist represents all property taken from me and that I have teemed a copy of this receipt, I hereby acknowledge that the above list represents alt property impounded by rre in the official performance of my duty as a police officer I' ) . • Vi. ,,,, . _ '0- 1_7 ,-L Di _ SIGNATURE ) SIGNATURE DATE IDA' UNIT RECEIVED BY .. REASON CATER-ME RECEIVED I I 1 il , - " " --,......a,-..:-. DETECTIVE BUREAU EFTA00232907 --)LM BEACH POLICE DEPARTMEn / PROPERTY RECEIPT DETECIVE BUREAU PPPO Cam 162 r I PROPERTY O FOUND j DECEASEC (Probated) D PERSONAL J CONFISCATED O DESTROY in EVIDENCE 'Wi TRIAL `]LABORATORY U STOLENRECOVERED Ca OTHER INCIDENMCITATION NUMBER ... „ DATE/TIME c4Iflur RECOVERED 'A i c PROPERTY NUMBER (Leave Blank) 7-, c., --..-7 ? (,----, , k — BIN NUMBER ;Leave Blank) _....1 /2A- "cc ADDRESS WHERE PROPERTY IMPOUNDED i . DISCOVERED BY/ D.O. B. i n G 0 -:,.- c ADD13ESS Street City Zp PHONE NUMBER OWNER'S NAME. D.0 B. ADDRESS Street City Ze PHCNE NUMBER SUSPECTS NAME:DOB , , 1 ,. ., , _. ADDRESS Street Cey Zp PHONE NUMBER ADDT'NL SUSPECT /DO B ADDRESS Street City Zr3 PHONE NJMBER SPECIAL INSTRUCTIONS FOUND PROPERTY ei.AiNt 0 7 H .. - a c q A kcf : NOT CLAIM Ct.j' ErEkilf4 ;.0-WANItl.Y.. VALUE .: , -,i.i‘,:u - :1).E$031e110611Li to. xp.45a., ' ::;: :. i -71. , •:, . e? . ,...r t, t .1- fitiat5 ,,, VS , k ..-.. .. ..1 . . .''.-- i'fite'a v,,i‘rpd : i, • i I Ni ;12+ : ( .r .-...i: u 2. - -,,. • :. " 2 I .. . , , 1_ 0 TOTAL PACKAGE WEIGHT I hereby acknowledge that the above Ilst rearesents all properly taken from mo and that I have receNed a copy of this receipt I hereby adutcrniedge that the above list represents all property tmpoundeU by to in the official performance of my duty as a police officer. ! . .i IA ; , i' - 1 ' , SIGNATURE Li SIGNATURE DATE ID* UNIT RECEIVED BY REASON DATE/TIME RECEIVED ril fk- ‘ C -ft( _ / il Cr j; '-' / 1..... j ; .,eA:t),-Ic;C:le....` .erreilkaler... -rlilAiiii<tikrartgirgiii;'; EFTA00232908 'ThLM BEACH POLICE DEPARTMEn PROPERTY RECEIPT DETECTIVE BUREAU PaPoFories2 I )4 PROPERTY 0 FOUND 0 DECEASED (Proeated) U PERSONAL XCONFISCATED 0 DESTROY LI EVIDENCE U TRIAL U LABORATORY 0 STOLESURECOVERED U OTHER INCIDENTiCITATION NUMBER DATE/TIME RECOVERED r_.71 2,;•;\ lc i PROPERTY NUMBER (Leave Bank) r5 tz - e- I: - ,7; BIN NUMBER (Leave Blank) I 2. q S-D- ) ADDRESS WHERE PROPERTY IMPOUNDED s') ( E: I lit , z I I ,, - i .,- t ...- ( DISCOVERED BY / DOZ. ) ADDRESS Street Cry ZiP PHONE NUMBER OWNER'S NAME 0 0.8. ADDRESS Street Ch, 43 PHONE NUMBER SUSPECT'S NAME ( D.0 B. ADDRESS Street Cety Zip • c . i PHONE NUMBER ADOrNL. SUSPECT/ D.O. B ADDRESS Street Crry Zip PHONE NUMBER SPECIAL INSTRUCTIONS * hot ( NL) trr-lot l cif. - '. Jrri trv. T De/ l'Acreir;,,i rDuND PROPERTY CLAIM J. Fir., DAYS NOT CLAIM,'.. I7E1. M 0,JAN iTY VALUE OcSCRII --0 4 I —fr ..------- ,...-- ...----- 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 byine in the official performance of my duty as a police often 'SIGNATURE DATE SIGNATURE IDN UNIT RECEIVED BY REASON DATE/TIME RECEIVED EFTA00232909 -Th'iLM BEACH POLICE DEPARTMET) PROPERTY RECEIPT DETECTIVE BUREAU POPOForm in.2 3 PROPERTY U FOUND U DECEASED (Probated) 0 PERSONAL El CONFISCATED 0 DESTROY Xi EVIDENCE 1d TRIAL J LABORATORY U STOLEN/RECOVERED 0 OTHER INCIDENT/CITATION NUMBER DATE/TIME RECOVERED PROPERTY NUMBER (Leave Bank) BIN NUMBER (Leave Blank) ADDRESS WHERE PROPERTY IMPOUNDED --23 LI CEL C..) . L.- 0 L..; "-T 14 " (7)A r) i• Ay\ .— — ,A( t T L DISCOVERED. BY /D.0.8. . ADDRESS - Street City Zip PHONE NUMBER OWNERS NAME, D.O.B. ADDRESS Street City Zip PHONE NUMBER SUSPECTS NAME 1 0.0, ' 1:- 1- c',-7 I T-. -I ' <- -;( 7i ADDRESS Street C. IY Zip -L.' .-- 1 , r;',1,:'I\ l'ic • 2 PHONE NUMBER ADOT'NL. SUSPECT / D.O.B ADDRESS Street f ^.' Zip PHONE NUMBER —SPEC/AL INSTRUCTIONS POUND :PROPERTY C, AIM ....I BO DAYS ' r; 1 j TEM 0 ANTIT .L D ., 2 P C)N It - L , .... ‘. .. ! ; . . . ' ' ) t • TOTAL PACKAGE WEIGHT I hereby acknowledge that the above kst represents all property taken from mo and that I have received a copy of this rebelat I hereby acknowledge that the above hst represents all property impounded by mo in the official performance of my duty as a police officer, ....--.. • . , SIGNATURE DATE SIGNATURE ID# UNIT RECEIVED BY REASON; t, DATE/TIME RECEIVED , EFTA00232910 rsaliikirr aht1)44W.:734W06SUURCAMPt" .".75•1 4gralli n t 14 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT DETECTIVE BUREAU PBPD Friar #53 I 1.3 PROPERTY 0 FOUND j DECEASED (Probated) C.:1 PERSONAL 0 CONFISCATED 3 DESTROY AEViDENCE TRIAL LABORATORY 0 STOLEN/RECOVERED 0 OTHER iNGiDENNCITATiON NUMBER CAL?, N o ? ) DATE/TIME RECOVE ED 0 9 7: /;:c 1 0 30 PROPERTY NUMBER (Leave Blank) CA. - 1- ( IS BIN NUMBER (Leave \ .)Ck 19 Blank) 1 ADD,SS MOE PROPERTYEIMFC tOr s..\\1 :-/ - - 1 ...%) C. liCk DISCOVERED BY/ D.O.B. (LE.(Jill r\ i ADDRESS 5stty0 City Zip PHONE. UMBER OWNER'S NAME/00.8. k ADDRESS Street City ZP PHONE NUMBER SUSPECTS NAME I D.O.S. Cc.7:e (SeccriNi - -Y 77' ADDRESS Street City Zip PHONE NUMBER ADOTWL. SUSPECT / D.O.B. ADDRESS Street Cry 4., PHONE NUMBER SPECIAL INSTRUCTIONS r 'S. i -Ni-f Plii-fPF,, 1 . , T_^,.1 0 QUANT:7 -1 W,:.1...E- .2.I.IScrili r• ON I I 1 ,-- _ ‘C-A c,( Qii_ciputIL .: ). ..,t .,, _„., , .,_ _ . .,i. .'Ir ) -T---.. -f- "--------7‘- ---7. .4.-- ' - . • . ... . 7---- 7"- - 7 -."7"--------,- - . • .... . - . -- • - • -- . . TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents as properly taken from me and that I have received a copy of this receipt. I hereby acknowledge that the above list represents all property irnpounded me in the official performance of my duty as a police officer. -4-N 7 1 )2-- SIGNATURE DATE --- SIG -- -c — - ATUR IDS UNIT RECEIVED BY REASON DATE/TIME RECEIVED ' I . \\ J •r-() k .'. 7 . 3 c-t-, ui, jk,3 -a_ EFTA00232911 .........-.—.•###HweleNtePrIeRVIIMPCrameraeletemlIatEMINI n^ PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT DETECTIVE BUREAU PBPD Form #52 PROPERTY CI FOUND U DECEASED (Probated) CI PERSONAL CI CONFISCATED CI DESTROY ' 1 EVIDENCE fXTRIAL LI LABORATORY C.3 STOLEN/RECOVERED CI OTHER INCIDENT/CITATION NUMBER OS - 36,(2), OATE/TIME RECOVERED lo 9 2705-- tom PROPERTY NUMBER (Leave Blank) BIN NUMBER (Leave Blank) / 2 12 4. 6., ADDRESS DLFS WHERE PROPE FIL IMPOUNDED S 'CA ) MTY 2-040 (Th n r \-4\ lAA r -it:- Act-' t L DISCOVERED 0 BY / 0.0B 1. a r.:(Aire •( ADDRESS Sweet City Z9 QP) 0 0 PHONE NUMBER OWNER'S NAME / D.O.B. ADDRESS Street Cry 20 PHONE NUMBER SUSPECTS iiit iC NAME / 0.0 i•.1 .SFr ADDRESS Street City bp 35?-) CLP,aolo 927 PHONE NUMBER ADDTNL. SUSPECT/ D.O.D. ADDRESS Street On., a PHONE NUMBER SPECIAL INSTRUCTIONS -J FOUND PROPERTY CLAIM :_:1 ' (#0 DAYS NOT CLAIM L.ji ITEM # QUANTITY VALUE DESCRIPTIO ^/ hAALA-211,473 Vi14/k)Aki -e MTV. `:-7 re•Al • ,' r : TO ‘) o Pk ,-- I --b_\'tcY In •kitt.AA. • '111Ac)(--k• • (3 ?-7 () i --Ifts,514. • 4-- TOTAL PACKAGE WEIGHT l.hereby acknowledge that the abo' o.list represents at property taken from me and that I have received a copy of this receipt. - I hereby acknoModge that the above list represents all property impounded by me in the official performance of my duty as a police officer. - -- ilic 1)2-- S R ION . UNIT - SIGNATURE DATE RECEIVED BY REAS N DATE/TIME RECEIVED x EFTA00232912 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT DETECTIVE BUREAU PaPo km, t52 I U PROPERTY 0 FOUND tj DECEASED (Probated) 0 PERSONAL Q CONFISCATED 3 DESTROY ItViDENCE ATRIAL I..) LABORATORY 0 STOLEN/RECOVERED 3 OTHER rNCIDENT;CITATION NUMBER 05 5(cQj DATE/TIME RECOVERED 01 .)(Ds q 4oA PROPERTY NUMBER man Stark) BIN NUMBER (Leave Banki ADDRESS WHERE PROPERTY IMPOUNDED i m 395 5 (Tli )pJT'/ C2-0A0 ‘k-}AW F3E-Pc7 EA DISCOVERED BY /0.0.8. Dr" :1- 'Q. . CALE N / ADDRESS .—..,) „ L Street City ZiR DO PHONE NUMBER OWNERS NAME! 0.0 B. ADDRESS Suvot City Zip PHONE NUMBER SUSPECT'S NAME/D.0.B. C:.,i- kiiT t..: ‘,..) , 1 c ADDRESS Street 9 tip 2. -_-;:;()- Cr I_ Pl;c1 ; \\,..._ \.' L.) PHONE NUMBER ADOTNL. SUSPECT !D D.O.B. ADDRESS Street City Zip PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY P: _A h'. J ',CT CLAM ...1 TEM J . QUANTITY VALUE DESCITIP ID!' ,...., (5-4b. ,...!{.1 f.:fc.,-. r\,..): ....,NA c_ , _ •,,T1',_ , ,,-, __I.!' .-- . .. . . ,,. . , TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents alt property taken horn me and that I have received a copy of this receipt. I hereby acknowledge that the above est represents all property impounded by and in the official performance of my duty as a pace Ohm. - 7:i i s U2.-- SIGNATURE _ __ - - DATE , . _ SIG ATU ION UNIT RECEIVED BY • REASON J DATEiTiME RECEIVED , , EFTA00232913 • PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT PRPO Form •52 EVIDENCE CUSTODIAN ...1 PROPERTY O FOUND U DECEASED (Probated) O PERSONAL. O CONFISCATED O DESTROY laEVIDENCE TRIAL CI Cl STOLENSIECOVEFIED Cl OTHER INCIOENT/CITAglt ;R DATEMME RECOVERED 10-03C6 MI5- PROPERTY NUMBER (Leave Mac BIN NUMBER (Leave Blank) ADDRESS WHERE PETOPERTtIMr DED 359) E 1 wAy ppluAselisco-, ru, -;2.),-k-0 DISCOVERED BY/ D.O.B. CAI-V-NArEL 94 0 , ADDRESS ' 20 112190 OWNERS. NAME/ D.O.B. ADDRESS &lug City ZIP PHONE NUMBER SUSPECTS NAME/ D.O. Ir. E, 1,111 Ztf ADORES stmu t waikcely 43 Wb el Ilyril ri, PHONE NUMBER AO TM. SUSP /D.O.B. ADDRESS PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM Cl 90 DAYS NOT CLAIM O ITEM 0 QUANTITY VALUE DESCRIPTION 1 1 bar ct ,tt. Di 1,A 1G Vi YOtp,AAAA £wV&c, 2- UtMath OtA) il, tat Ovi rant tirDM --kina4A (ht lifit ElibrillowAy --, 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 dad the above 1st represents all property Impounded by me in the official performance of my duty as a police officer. lab \ 1(/} SIGNATURE DATE SIGNATURE IDE/ UNIT RECEIVED BY REASON DATE/TIME RECEIVED EFTA00232914 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT PIPO Form *52 DETECTIVE BUREAU J PROPERTY 0 FOUND 0 DECEASED tProbated) J PERSONAL CONFISCATED CI DESTROY *EVIDENCE WTRIAL 3 LABORATORY r_i STOLEN/RECOVERED 0 OTHER r Pk 6E' INCIDE ia. T/CITATION NUMBER 05- 5.8 DATE/TIME RECOVERED ID-3-0S 2/60 PROPERTY NUMBER (Leave Blank) , r c; - (1.-Pc) BIN NUMBER (Leave Blank) ,e; t 1 2 i 7)31 • ADDRESS WHERE PRopERE IMPOUNDED A , : fr I / • 2- cf 34AS c, ..._.) exixdry Memo .44, exae'lj mgctaERED DI( / D.O.B. I f)e---r gt-641 et( ADDRESS pep O ( Zip PHONE NUMBER OWNER'S NAME /O O.O. ADDRESS Street City Zip PHONE NUMBER SUSPECTS NAME / D.O.B. ADDRESS Street Crty 0 Zp PHONE NUMBER 1 111) C 71) M ..._\ r SiC roi EL 9(2:00 ADDTNL. SUSPECT / D.O.D. ADDRESS Straw iv Zp PHONE NUMBER SPECIAL TZCAR. Coc7...1 FOUND PROPERTY CLAIM... 9O OA. NOT. CLAIM J ITEM# I OJAN /TY VALUE OESCH Ft ;UN . I kiki"tieF: L. .\) V kc. - ( I . 11Q:;<) C- -Si &4 l4 (1-1 . . '' " 1 S ( -- :-:-4-'-ittEMTEN at I " 7 0(11.41 *At C-00CitS`)Ith - \ - c4A. (7 (sm._ / , .___ t4 _ UK roc cAsSe iv 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 acknowle that the list represents all property impounded by me in the offici rforma of my duty as a police officer. TX 1- 1, SIGNATURE DATE SIGNATURE 100 UN RECEIVED BY REASON DATE/TIME RECEIVED EFTA00232915 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT EVIDENCE CUSTODIAN PBPOForm 02 el PROPERTY U FOUND U DECEASED (Probated) U❑PERSONAL U CONFISCATED U DESTROY N?..EVIDENCE 0 TRIAL DI LABORATORY U STOLEN/RECOVERED a OTHER INCIDENT/CITATION NUMBER 0 11 9 Ap DATEMMERECCI t0-014--0 ED 041, PROPERTY NUMBER B.eave Mated BIN NUMBER (Leave Blank) AD WmPnE PanDFATY fS IMPOI WDED WI-AMU\ TatnoNj4,121 9,211-g 1 SartyERED -1-1 I BY /shODa_ VA 10 tuk , /ADDRESS Shoot / PHONE NUMBER OWNER'S NAM / O.O.B. ADDRESS Street ay ZI, PHONE NUMBER SUSPECTS NAME / D.0.8, VIC_ Q, ADDRESS arnr Ave /7% El tri1.4\149MA411411 t vil PHONE NUMBER A TNL. SUM / 0.019 ADDRESS PHONE NUMBER SPECIAL NSTRUCTONS FOUND PROPERTY CLAIM U 90 DAYS NOT CLAIM fa ITEM IS QUANTITY VALUE DESC PTION 1 :: 9 1 1 ttit. t) Ct mu& kLikAwAtkioYI rewwei 1 vo vffoim 00 inw-7 t eVAIIIIMAty 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 IS represents all by me In the tel performance of my duty as a police property °racer. impounded es 4 r , SIGNATURE DATE SIGNATURE ID# U IT RECEIVED BY REASON DATE/TIME RECEIVED EFTA00232916 ,•-•cr•-.•-•• ,,...."-•""r • ...".. •••-r -••••,.. ...." -- ?.." . "^". -• PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT Pg100 Farr 452 DETECTIVE BUREAU ...I PROPERTY Ij FOUND J DECEASED (Probated) j PERSONAL 0 CONFISCATED 0 DESTROY Mr EVIDENCE g TRIAL 0 LABORATORY 0 STOLENiRECOVERED U OTHER INCIDEN17CtTATION NUMBER 05-.366 DATE/TIME RECOVERED ‘0-4-05 tb n PROPERTY NUMBER (Leave Rank) e) E.-7_ si -2, r7 BIN NUMBER (Leave Sank) / 2 i'? /'/ A5C1ESWHERE PBCPERTnMPOUNDED L(.(_tist-ty Q.....Op.n PpAkA ‘,..,ACL CL 0 COVER ftI )BYID.O.B .2_fe. \ • V -C -- "-Cfine t ADDRESS Q Or City ZO PHONE NUMBER OWNERS NAME /0.0.8. ADDRESS Street Cory Zip PHONE NUMBER SUSPECrS NAME / D.O.8. ADDRESS Street Zp 351. 'EL McD /I J PHONE NUMBER 4". 1‘04k ) , Sect ADDTNL SUSPECT/ D.0.8. ADDRESS Street City ZP(3 / PHONE NUMBER —1 SPECIAL INSTRUCTIONS FOUND PROPERTY CLAW J ' En, DAYS Nqr cuttr;i,j . . ITEM QJANTITV VALUE (*sea Ftle:).ti:.: ‘ :issNi 1-Ak CP0a9;ta . 2* t istm.:4s4 jjrifase.AcAtit - %,..n4 wititocossK4-1E- \.1 btu:. LAA P ES SC vuoi2ez:. - • t out ) Q-34/DeleCiA (1 TOTAL PACKAGE WEIGHT re I hereby acknowledge that the above 4s1 repipstents as property taken Irom me and that I ha ve received a ccp This race pt. I hereby acknowledge that the above itst represents all property impounded by me in I flicial performance of my duty as a poke officer. SIGNATURE DATE SIG TU IDi UNIT RECEIVED BY REASON DATE/TIME RECEIVED — ;33r e - c / -7 c h.- EFTA00232917 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT DETECTIVE BUREAU PEW° Form .52 I al PROPERTY D FOUND 'a DECEASED ;Probated) 0 PERSONAL U CONFISCATED 0 DESTROY (EVIDENCE *TRIAL Q LABORATORY U STOLENiRECOVERED 0 OTHER INCIDENT/CITATION MBER QS- .3 DATE/Tin RECOVERED Icy SUS O0O PROPERTY NUMBER (Leave ---, (,. 6' I L/ BIN NUMBER mays Bland , 1 f? < -, ' E./ 2 .. AO R SeVHERE PROPER .633 t-i- _---, , Qui\c) i\k,t t;ei la-\ pl,BCO__ER pEIAytt) B.f., iLEV ADDRESS Zp ICJ • PHONE NUMBER OWNER'S NAMES) D.O.B. ADDRESS Street 04, Zip PHONE NUMBER SUS,PEOrS ig NAMc r a a aa. tt k ' 3 V? c7( f￾ADDRESS . FiCcIt° SF/0 # CV Zip • LL: PHONE NUMBER ADDTWL. SUSPECT ;C) 0.0. ADDRESS Street Dry Zce PHONE NUMBER SPECIAL INSTRUCTIONS CU `. C PROPERrY .-.. ITEM v OCANT: Y JF Dr:-- '2 7:Fc2— .C:N . .. ,___ . . . _ ) / \ 01. . i iikjfi :, CL-- VA -:).P . ICS" (-) • . . • TOTAL PACKAGE WEIGHT hereby acknowledge that the above list repIesents all property taken rem me and that I havo received a copy of this receipt. I hereby acknowledge that the above list represents all properly impounded a in the a ' dormanco of my duty as a police officer. 1 Clic rti> IGNATURE DATE. SIGNATURE • ID# UNIT RECEIVED BY REASON DATE TIME RECEIVED . .• • EFTA00232918 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT DE'ECTIVE BUREAU { 0 PROPERTY 3 FOUND P DECEASED (Prcoared) 0 PERSONAL 3 CONFISCATED 0 DESTROY (EVIDENCE 'TRrAL P LABORATORY j STOLEN/RECOVERED P OTHER INCIDENT/CITATION NUMBER 0 5 — 3 6E) DATE/TIME RECOVERED \Op t :Cc 11 PROPERTY NUMBER (Leave Blank) 'BIN NUMBER (Lea... Blank; I 7 , / 4 f' /‘ Ci I 1 41 ADDRESS WHERE PROPERTY IMPOUNDED 'N 3. \ S 5 Clip_kNil NI V-OP4) k--7.\ VA uri Ac t i DISCOVERELBY; 0 0 B 0 17.1 ,k4 k;:ti kiLl ADDRESSfr, .,Skvet city P-IO zo NE I\ 62 C ) r— NUMBER OWNERS NAME. D.0. D. ADDRESS 5:reir zip — PHONE NUMBER — SUSPECT'S NAME / C.0.8 q-c )S i ViQ/ i ‘. ADDRESS Saoo! C/a/ Zip :;5C)( 1-7-1, 6 a 6 PHONE NUMBER ADOTNL. SUSPECT/D.O.D. ADDRESS Stever City Zrp PHONE NUMBER SPECIAL INSTRUCTION (.-C' FOUND pnoorskTy cLApt j 9.:: EAYS it,9T CLAM ..I . I EM P CJANT'TY l VALUE I D eCH ION ..:...O:JC. , 4 ier - , t I' f ,- i g 6,' ' ' - i i , .." Izi. Vitt ee ' ir v . A. ' h . Alt : \ sc • ;, v ‘ . ., __._ • ____. _j___ — TOTAL PACKAGE WEIGHT il t re (coy acknoMedge that the above LSI represents WI p rODarta taMyt trcm mu and that I have ilia/lved a copy of tNs rocoitit roby acknowledge that Ae aPdve list represents by in the official performance ol my duty as a pa' a!, ;,raperry impounded co cHicer SIGNATURE: --- - E •-• - idNAtutzl :De UN T R:CEIVED DY REASON DiTUTIME RECEIVED 'Ailik i. EFTA00232919 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT pePo Fotm *52 PROPERTY j FOUND Cil DECEASED (Probated) UPERSONAL O CONFISCATED ID DESTROY EVIDENCE U TRIAL LABORATORY STOLEN/RECOVERED I...) OTHER INCDENTICITATION NUMBER 0.11 'MO DATEJTIME RECOVE ED P ko-N 062 CtIfile 'PROPERTY NUMBER (Leave Blank) rC 9d 7 ,.., BIN NUMBER (Leave Wank) / a(...} 4-77,__? _./ , eLL-- ADDRESS VVHER PROPERTY IMPOUNDED 144b 0 lb ( 1 \ \ 0 Uy T (t‘ \An 1)2(061 VI, u _...)- t 2974-g0 CrTiRED BY r010.0?t LNEA'S (11C12 , ADDRESS Street / PHONE NUMBER N M /COB. ADDRESS Street C:ty Ao PHONE NUMBER SUSPECTS NAME/DD ..- 'tip n'T . ADDRESS Street lin ,- \ 11\ t\V114/y gp r PHONE NUMBER rm_. SUSrE / 0 B. AD RE S Smear ry RHONE NUMBER SPECIAL INSTRUCTIONS H Ai./ ...) l'- '-'A e — "*Nr•I'v : '14_J9 • ---(-;R:0-:ON I • , , { 14/.-t0A '• 04\4_1\1- 2 U W \tv\-1. 0Y\ ii•I,Oki , TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents alt property taken from me and that I have received a copy of this receipt. I hereby by me it acknowledge that the above list represents all properly impounded h the official performance of my duty as a police off cif. iteNAtURE DATE SIGN TuRE ID* \t; IT" RECEIVED BY REASON DATE/TIME RECEIVED qii. ( -1>ct.. (C_: / A - o 7 - tik" ( DETECTIVE BUREAU EFTA00232920 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT PsPo Fern P52 1 PROPERTY U FOUND U DECEASED (Probated) U PERSONAL U CONFISCATED O DESTROY A EVIDENCE .N TRIAL Li LABORATORY U STOLEN/RECOVERED U OTHER .7 1 . / • C IN CIDENT/CITATIO C C" 3 NUMBER DATE/TIME RECOVERED JO' C 2) -OS/C e l lc PROPERTY NUMBER (Leave . Blank) -t_,_ ,- )LiLi BIN NUMBERtrdirl. 1 .. ,,R-.- 9 (,-2 . A er) ADDRESS WHERE PROPERTY IMPOUNDED -2)5QD E P2R-i an WA V PAL _e to 8E-Aak VT-L. -2-2-Li-ccO DISCOVERED BY / D.O.B. CALeNAEL 2.16 ADDRESS ill I Strom City 0 2-90 OWNERS NAME / 0.0 B. ADDRESS Street City Zp PHONE NUMBER SUSPECTS U ttill NAME i D.O.B 1 wizt ADDRESS Streei City / Zip I vise-AIMvo-Aito PHONE NUMBER ADOTTIL. SUSPECT i EIL.B. ADDRESS Sfrout PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAM... 93 DAYS NOT CLAIM j ITEM X QUANTITY VALUE OLSCHIP NON 111/114k . ,CW teU crk Aikt.)\-11.., - V‘f\ytAiVitk.V.Vi c.i.AyVec_,_• ___ p_IEW2 Maim( --ttVi Dv) q tkovell talV1 , . ' N- u TR) 0122y1110 \Wiry_ .. . 1 . . . .• ••.•• . , . . . TOTAL PACKAGE WEIGHT I hereby acknowledge that the abcr a list represents all property taken from me and that I have received a copy of this receipt. I by hereby acknowledge that the above list represents all property impounded me in the official performance of my duty as a police officer. W_Clk T2 -- SIGNATURE DATE SIGNATURE . ID# UNIT RECEIVED BY REASON DATE/TIME RECEIVED /4. DETECTIVE BUREAU EFTA00232921 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT PBPD Form *52 1 J PROPERTY CI FOUND U DECEASED.(Probated) ID PERSONAL U CONFISCATED DESTROY KEVIDENCE SPIAL U LABORATORY CI STOLEN/RECOVERED U OTHER INCOEW7CITATION NUMBER 0 5 ....5(>5 TUTIME 00(00c RECOVERED . Sr - rPROPERTY NUMBER (Leem 0 5- it -ii SINN/ MB (LeaveBlank) 2 ?All ItErrHEFIEF )PErlar ry izo Ao 0 Aki tA keeirP WCOVERE Y / D.O.B. . ' 1 ADDRESS 9or City OP PHONE NUMBER OWNER'S NAME / D.O.B. L ADDRESS Street City Zip PHONE NUMBER SUSPECTS NAME / D.O. €,..0;MNJ,Jc￾ADDRE,§5 Street i P. &ilk City 1 Ao PHONE NUMBER ADDTNL SUSPECT/ D.O.B. ADDRESS Street City Ip PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM I—I ;0 DAYS NOT C_AIM i . ITEM It QUANTITY VALUE DESCRIPTION ► 2 I CSONN 1•'4 ( C (1,0 CASci---4 1 ( 5 nil Tr (-7- e / T - - TOTAL PACKAGE WEIGHT I hereby acknoAredge that the above !st represents al property taken from me and that I have received a copy of this receipt. I hereby acknowledge that the above list represents M property impounded b e in the oNicial performance of rn/ duty as a police officer. r ill C 1) r—L '' SIGNATURE DATE SIGN RE IDa UNIT RECEIVED BY REASON L DATE/TIME RECEIVED /•.: Is fi Ty -::.? k 6 r ---' • C —1 - Or ( 7 DETECTIVE BUREAU EFTA00232922 PALM BEACH POLICE DEPARTMENT .PROPERTY RECEIPT RBA] Form 152 1 - PROPERTY II FOUND U DECEASED (Probated) (0 PERSONAL U CONFISCATED ID DESTROY .CJEVIDENCE li.TRIAL CI LABORATORY CD STOLEN/RECOVERED U OTHER INCIDEJT/CITATI9NAUMBER 0 4) . :7) bd., DA ME RECOVERED .. !.., lc; i2/o5 lick.)41ecs PROPERTY NUM R (Leave C . —91,;.- Blank) BIN NUMBER (Leave Swami /A F/q( ADDI3ESfi .CERE ri3OPERIXIMPOUNDED ,f) . 71 4:; ,2.2 . L._ O Li Arrl/ &OM PA I'M 1:::4- )4rW Eify4V4REISDa ti cr y ADDRESS (/'/ n6 . City zip PHONE NUMBER OWNER'S NAME / D.O.B. ADDRESS Street City Zip PHONE NUMBER SILSRECTS NAME piat. CIT C:50 kJ . Je---- ADDRESS Street City() 3 Zip 35? Fri, e/1/6 vic. PHONE Nt,M8ER ADDrfill. SUSPECT/ 0.0.8. ADDRESS Strout City Zip PHONE NUMBER SPECIAL imsmucroa tkp lisr li if ) xi rr I-- C_OV Y .rouND PROPERTY CLAIM 0 X DAvs , , t.pr CLAIM O . ' ITEM a OLJAP/717Y VALUE. DESCRIPTiOtt ---a ------- — 4- - t, — ---- ..;:4: 7 y 1.A.; cr/ 0 c..../"sL-74-s• - —lira 17 vi t; ?-4-, -- 1 I ON y A .. evcrecot cst, Fr: -17,v7z-: i2 vi e-,--;,-, 6 frth TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents all property taken horn me and that I have received a copy of this receipt. i hereby acknowtedge that the above Psi represents ar property impounded by me in the official performance of my duty as a police officer. . . SIGNATURE DATE SIGNATUR ION UNIT RECEIVED BY REASON I DATE/TIME RECEIVED C/. ,_, C7 7-1X /072' 6 S- , Ak -7 0 1r DETECTIVE BUREAU EFTA00232923 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT PBPD Form e52 DETECTIVE BUREAU U PROPERTY U FOUND D DECEASED (Probated) U PERSONAL CONFISCATED O DESTROY J. EVIDENCE LABORATORY ❑ STOLENiFIECOVERED U OTHER INCIDENT/CITATION NUMBER DATE/TIME RECOVERED ! k 1. \Ric) PROPERTY NUMBER (Leave Black) c 5- /o05 ADDRUS WHERE pROPERTY POUNDED --A I _CONTI y 12.c,AO i?t￾papr y:EliEDei Cr ADDRESS 213r0 Cry PHONE NUMBER OWNERS NAME / 0 OR ADDRESS Street City ZP PHONE NUMBER SUSPECTS NAME /D0.0. ER -761Ni, ADDRESS -2,S5 Stint C* 2-9 4-1 (t PHONE NUMBER ADDTNL SUSPECT I D 0 B. ADDRESS Street Cary as. PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY 90 DAYS CLArm NOT CAW ITEM a QUANTITY VALUE DESORIPT?ON BIN NUMBER (Leave Break) TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents all properly 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 by me in the official perlotmance of my duty as a police officer. RECEIVED BY REASON 711( 1 -> 2 ••• 00 UNIT DATE/TIME RECEIVED --v S 7/) /6 /y-ci- g E EFTA00232924 ABPD Fees 452 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT SEARCH WARRANT RETURN DETECTIVE BUREAU U PROPERTY O FOUND D DECEASED (Probated) A PERSONAL LI CONFISCATED U DESTROY CD EVIDENCE U TRIAL U LABORATORY 7-U STOLEN/RECOVERED j OTHER . 4CIDENT/CITATION NUMBER C::) ) .`\.'' DA E RECOVERS r i in\ ° \ - PROPERTY NUMBER (Leave wank) o - 1 a q 3 BIN NUMBER (Leave Nam) I -,-,(ciLitis ADDRESS WHERE P Ri c,ERTY IMPOUNDE 12-(7 S ri &AQQ— fra-N b /C pt.,,A 9)5F .2-. - - igyillo DISCOVERED C.1\b-el etit ?VV/ D O. i N ' ADDRESS Street Cry a, PHONE NUMBER QWNER'S NAME / D.O.B. 7 ADDRESS Street City 4) PHONE NUMBER SUSPECTS NAME / D.O.B. /- zo 3 e ?SIC' v.) , Jr -254 FLE‘ ADDRESS Street RY, Zip 35S V_I__. ic2-A.,(110 PHONE NUMBER ADOTNL. SUSPECT/ O.O.B. ADDRESS Street City zip PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM Li 90 DAYS NOT CLAIM U ITEM # QUANTITY VALUE DESCRIPTION 3 flat pvos Qy_s_ .. I „„) / Ga 0004p) 4 r i • 4 . . . • ,...' TOTAL PACKAGE WEIGHT I hereby from acknowledge that the above list represents all property taken me and that I have received a copy of this receipt Cr. it) 0 Zip t Clicer __ I hereby by me in SIG acknowledge the official I performance that the above list represents all property impounded of my duty as a police officer. 711C— 1)2+ SIGNATURE DATE _____ . - IDa — UNIT- '51 - RECEIVED BY REASON DATEJT ME RECEIVED r A l ejjA‘ j«tira A CI St f AA. ) 0 01 I i Ws aim EFTA00232925 • P8PD Form 452 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT SEARCH WARRANT REIMAN DETECTc E BUREAU ° D PROPERTY ..1 FOUND Li DECEASED (Probated U 'PERSONAL . U CONFISCATED Li DESTROY EVIDENCE TRIAL Li LABORATORY j STOLEN,RECOVEREO j OTHER DENT/C_LTATION NU BER 0 5 - 3 DATE/TIME RECOVERED c)- -Lc: - -2,0 0 c • PROPERTY NUMBER (Cram Blass) r- ..., --, — BIN NUMBER ILoavelifrailkit-) ADDRESS WHERE PROPERTY IMPOUND _ a — L tDri DISCOVERED / D as ADDRESS Street City 4:, PHONE NUMBER OWNER / VICTIMS NAME I DC B. ADDRESS Street City Zip PHONE NUMBER SUSPECT'S NAME r De B e ADDRESS Street Crty Z 3Sb Fit PHONE NUMBER b ADM- L. SU PECT ADDRESS Street Cly Zip PHONE NUMBER ..:L.7.,,‘.. F, SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM I 90 DAYS NOT CLAIM:]. ITEM * QUANTITY VALUE -OESCRIPTION / . ' j ./: 1:7 A: 7 7.-.' jr } 1...L 7 : r t. 1 ° I i' i: / Atigtria l / / /1;2' u a fi . --.. _ / •-• /I / delf ae 'rt (:/ -it /16 , /° t becie ( ( ..4t.1- • t, .8 / i . -- : •• , . ., -) i , I. // ..'./.!, /. e 4l A;`, r' izikit l nice 1, Ar "(if --7 i- , /1' ny...5 2. 7C 1; 0r1,- ;f/ _I / . el-1 r" c 7 - . ,c,/ / ,./ / ' -/ A, / i CI -:-,, 4 pp.i5 .— 11 , i1- .Cmo..e la:( Lit ' uff., r" - „Li ej 4 11.- .. . .,. • • , -- \I I:4 ottil 1 i ) 1 . -----77 . .-cj'l ale-SC(1 ri P 7012.1e /....,4-, 7 7 / fI1,- :-. l: ''''' eZ( k 1'5;n stri-11 - Pho-i-t-) - c ii 17I t -4( ... i (arAl . . 'r 1 ‘ 6 77 ) ) rzy- 7 At fr, I dic4 ( , • ? . etie) I 03 2..0_07 0r .(. (.: „:, rir- 6 0/ O„en_ • lieg it,:r4his,. • .? ___2_6: V.1.1•A\.)‘!‘":">ay./ .0,2 •i--Irl ... .._.." 0 TOTAL PACKAGE WEIGHT I hereby acknowledge from no and that the above list represents all that I have received a copy of this recept vanifear888. properly taken I hereby acknowledge that the above by me in the official perlonmance list represents of my duty all property impounded as a police officer. 11 I C 1) 2 ' . SIGNATURE DATE SIGNATUR ID# UNIT RECEIVED BY REASON DATETIME RECEIVED AnReph Recarey, the officer, by whom this warrant ted, do swear that..the above inventory, a true and detail account of a the Froperty taken by me, under the authority of this warrant. 41-1 6( ice it A -4g4.44-1K.0 Sworn to and subscribed before me ti tTi:aiday of October 2005. EFTA00232926 • PBPO ECIT 152 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT SEARCH waRmar RETURN fAceaz a.- 6 7: DETECTIVE BUREAU I J PROPERTY 0 FOUND U DECEASED (Probated) U PERSONAL U CONFISCATED J DESTROY - 21 EVIDENCE. I dita TRIAL U LABORATORY Ul STOLENTiECOVERED U OTHER ^ INCIDENTCITATION NUMBER (9 5 - :--2) 6 DATE/TIME RECOVERED /0•2O _0 5 PROPERTY NUMBER fimayo Blank) C 5- IC 7i LI BIN NUMBER tea Blank) ADDRESS WHERE PROPERTY IMPOUNDED '? C i L￾6 r J I I‘ DISCOVERED BY / 0.0.B. ADDRESS Street City as PHONE NUMBER OWNER / VICTIM'S NAME 1 I) 0.8 ADDRESS Street Cmy Zp PHONE NUMBER susPetrs niAmE i opy- b/-4V—r3 in fc, ADDRESS 3575 Et Street , 127121110 City Zip PHONE NUMBER ADun _L . 4t- _A Ni:- SUSPEL, I / U.W Or e ADDRESS Street Ofy Zs; PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM 0 90 DAYS NOT CLAIM) ITEM QUANTITY VALUE DESCRIPTION At Di ' L113_ ,2 ( v th 1,, ,_ -,,e,s / C Ar :I 11.1 t r , 112/ els. f2,9 ./: ?•-.0.7 r ri_ 171_. -72 . . . .\ ./Y5 , c -r.-/ 1-1 • ;Arta 7, ..c‘ , el f r)Z-: o- t-r (45 - _ 4Ott—__. - 3 Ph nt ;23 .. fltt O i (-O ci f 4 e ict /..)?7, riA,_ CTI -- • • , :,A 7,—) (0eri .----'7" rili-= , i_rif J pyrzias,c 4,......, .2. (...... 52a, O fir- 1) im (7: k di r 3 .../ _ ., , (.D .- s ft-if-i :'7?-7 de' j/c' _ . . . CI I. 0 V OF (ie.' O O1--) /1 <7. f 4 Cie n-ts 4- Al 4 .- z 3- ,-?..0 al . '•i- o< 0 LI ii 1 . ..,,„ P/20405 '/Cli- QM Of es- k ',Itr r.c() 7 / - 1 . -.47L - . 6i Ile i . 9 ---4 1Yrinlai • ell 41CIS b 0 'In ()U .'S i I • a3 rp J., @i-,c nron, i 12 e , t, sit„, 6../.k„ 4/ Q A. , o ,.-1.p o i n i 0 ,), ,I , l'i WI I ( - I I., , r -P 7 r 1-I v:r Tor (61 0 in iZi-e)( on 'Lox ..: e ii),..., ) J. , 1 ir lt'r j/e 877;/,,-,:. ...... 4.• dr rt _ , 6k(0il (V-,:\ mfrA P, ( t t., i (i ( nt,,,, to ye,( MI-.° i 1 :, ) - j . , I _ _ — TOTAL PACKAGE WEIGHT a. . I, „ v. , ) 1 heregt acknowledge that the above 1st represents all property taken from me and that I navectived a copy of this receipt. I hereby acknowledge by me in the official performance that the above fist represents all property of my duty as a police officer. 1 Ci I impounded _ C SIGNATURE DATE SIGN TURF. _ IDS I _1) ---.2 L IT RECEIVED BY REASON I DATE/TIME RECEIVED k -rt. (IND :11.O)til EFTA00232927 '1..4 46." r .44 41. WOO Poem n2 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT SEARCH WARRANT RETURN 146L 3 or 6 DETECTIVE BUREAU U PROPERTY U FOUND J DECEASED (Probated) 7 PERSONAL J CONFISCATED DESTROY ‘Al EVIDENCE jO TRIAL j LABORATORY J STOL ENRECOVERED .3 OTHER rc b INC,DENT/CITATION NUMBER I(:f 62 DATE/TIME PECOVERED /6- (96- 0 PROPERTY NU !BER (Leave Blank) . ( i t_D LI BIN NUMBER (Leauta Blank/ ADD EgS.WHERE PROPERTY IMPOUNDED ? Jr / 6y, i DISCOVERYD BY i D.0 B. ADDRESS Stator City Zip PHONE NUMBER OWNER I VICTIMS NAME / D.0.0. ADDRESS Street Pty Zrp PHONE NUMBER i SUSPECT'S NAME /D.0.8 ADDRESS rio <,-I--t- tin 396 Iteeq p, ap -a{ IQ PHONE NUMBER ADDTINL SUSPECT/ D 0 0 ADDRESS Street C'ty Zip PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM r_r 9D DAYS NOT CLAIM 0 ITEM A QUANTITY VALUE ESCRIPTION '27 2' / — . 1 Air ':-.4.. c, li emtii,erzior ',Atte 31Att.3in Dc SK Wt. or Toy .7:e a I, n1 (JZ Bk JAC.; in ___ _ , ib / • 3 crici, _ koAs n, es 0 ;9e0 TAP E.S# Scum ( II ) L A 7 IF/ 7A 1)/...'ci t )) - y e: it,- sriv,4 4 cs-:-,0 A . r,,- , .,-,,, (132,0 4... Nr IX i f r.,A p: f. ) 7417C? r : 0 -i, p . Z.. en- e. A zt): .--) M4,1 4 1 ' ..11.), :' '' ' ;/Y7 /424 .5 C.4‘ r 1 A r.714; mi: fy -P . ,0- ie , 1, ..: 6, T,I, c,, fn _. - , % i > ) / 4VC i :Gree'N d .3 2 ' I ✓ v rip i -ri, ci Tyn_ „, r44 ,6 (er.), ceir , ; , r>, C JI I VI.' ./ FT 5 or r,, ,o174.n/ (CC441.6 %) , Anca7 e : ,f- Off 7 .44A ,... ,. .4 t 4, .4.1r. eta: •-• r .4( 77 tr,.1,, - ” P it "T. 4 4. fin .., • C -t,) S re r 1_11_0-1 I) Ill / C 0 N7 k ' I - i 1 ,' 1) 17 1.. . ''' '2- - 1 9 ' r A ' id • - • i' 7,(•,(11: c'l-t-e • ))flIVRA'd I • ' • • -1 l ref fri , lA .. .. .... . , . -,7' e4fi.7 .. 1, -I. -, 0 --,/e-• 9 i , ; :.- fe (fi t..•, - 107tt, \LW" r . _ 77-‘7:kr , 1 'skit:4,71 Ift -ry? 0,, ,. r, ( - I-, • c LIU17 :0 Ck,^ 2_ / 1,-) ( 1-; 1<, ri : ' ' 1=H1,1 o, -, VD — , r :/"... C. b‘ i-tt,,,,H. . ... . - -In_ c -6ce eNs5 -R c 2.et9 TOTAL PACKAGE WEIGHT 644e 51 i.,,,,,,s C I hereby acknowledge t at the above list represents all property taken from me anti that I have received a copy 0' this receipt I hereby acknowledge by me in ite °Pieta; that the above list represents all property performance of my duty as a police otter. impcurkled — SIGNATURE DATE SIGNAT RE ION UNIT RECEIVED BY REASON DATE/TIME RECEIVED 4. -11-. esti \\\P.I.Wit EFTA00232928 -• PBPD Fart 052 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT PN Mc / DETECTIVE BUREAU J PROPERTY J FOUND U DECEASED (Probated) IJ PERSONAL 0 CONFISCATED DESTROY TRIAL CI LABORATORY 0 STOLEN/RECOVERED OTHER i a I. IVEVIDENCE I IDENT/CITATION NUMBER D DATE/TIME RECOVERED /o- epo- 05 PROPERTY NUMBER (Leave Blank) 05- io Lt. BIN NUMBER (Leave Blan ADORES WHEREPROPERTY IMPOUNDED `25 F C 1 86 1 / a DISCOVERED BY 10.0,B. ADDRESS Street Oly Zp PHONE NUMBER OWNER'S NAME / D.0. B. ADDRESS PHONE NUMBER SUSPECTS NAME / 0 0 Ersk in e OL;E% goer V° Top PHONE NUMBER AD Mt. SUSPEC11/ DO B ADDRESS Street Cly Zip PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAW 1—I 90 DAYS NOT CLAIM U ITEM * QUANTITY VALUE. DESCRIPTION Cli 5 s " 6 0 °' --et ---r-/-C— r_r.) 'did(' She/(n.i2-e- - -, li t A_V e 6. , Pic I e p ,n it..._ _ i __i_ .d_i_ck._____&A .I 14/_-; (Wel rOd ienv (-Pik rroto 6 er (v./ too ii, ve - 1 ,2_ e P et f if ( in &u _c I- 6-,261r no r, 3. •-•g iii/Y) video 7eze,----r in tract/ Proffer/ i / rc , 1)7e-iyeit (0 -K ,j1 , .--5 .- :( J).,46 fiv,t- , 4 t V 0 Disks, - 1),) (fray ink V 7 / 12' D / Se r -rch,,rn 6/.. r 3'7 .:).-e7, Urt -TviR -I—) *YDS 14- 3 IA_ bad (41 1 /11?"_.<5v-i e bald 71 tcrn i ( • • " 1 % , .. cr." 676--.la e Pk CIPt,.. ( -, •• 0 i 9 , r c; MC /}(:(.. 1k ,z CC-M.R-r --) 'EV ..., 5,/ Co op art AAA rei. 'IS . 1-./ h, 14/)(751e 1.4/.74 C'D I-5 ticivq)---) ‘....- 5 -c. ,7 5; , c eik , -4,,, ni 6 c, til -4 A ott S- e c) 17 ( e 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. e I hereby acknowledge that the above list represents by me in the Ostia( performance of my duty as a police `196 all properly impounded officer. - BIGMIRUEIE DATE SIG ATU Ei\ ) IDS UNIT RECEIVED BY REASON V DATE/TIME RECEIVED -rs— Cho \Xs Oi rn EFTA00232929 AL 4 ._sal PBPD Feerrt52 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT ma- 5 of- 6 DETECTIVE BUREAU U PROPERTY J FOUND U DECEASED (Prctalecl) a PERSONAL U CONFISCATED U DESTROY EVIDENCE TRIAL J LABORATORY U STOLEN/RECOVERED j OTHER 4 b INCIDENT,CITATIO NUMB -0 e70 DATE/TIME RECOVERED - 0? D -- OS PROPERTY NUMBER (Leave Brads) c 5 - - I 0 91-1 BIN NUMBER (Leave Blank) . ADDRESS kiliERW,ROPERTY IMIOUNDELL at 6 L r,11D poi i it, 6 e6' II k .. DISCOVERED BY / D.O. B. ADDRESS Street City Zip PHONE NUMBER OWNER'S NAME /D.O.B. ADDRESS ., Street City Zip PHONE NUMBER SUSPECTS NAME/ D.O.R. I-c- in 3-3-e OF P0-5 fir SDRESS Street City Zip 357.> V- -lillti PHO E NUMBER ADD NL. SUSPECT i fly0.B. ADDRESS Street City Zip PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM U Ba DAYS NOT CLAIM Li ITEIM'M QUANTITY VALUE ESCRIIDT•0 >L I, PO tA.)/ #4 ( 0/ i „e c. P ZI-•. , 16' - 6 -- • . - . c..., . , . _3 C P f t_ Fr' ov.,. . ... . .. . . .. , • oi f a 7€ , -I t -e:n. . p .2:- ., . . eak,.)--v ( ciy- :{ j-t. I fr. n-, . •.?" c S "7- CD i•-5-----\LL-M VA h i SS---57 £ro01 th{,li e r• • Fr ki-I ( Li -es\ 1 ±i: -0 I , ..ilv ictp,...14 PPM ( )1 e)i e \ s a if 4- Lk_ - ciitiS -4-cA e- S -- • ._ - :. , • . 11-CCI5ofir a,.., ri • ,., izervi7},-) -) 2c-:/1112--r-J • tZstilitu---) i -. Eat TOTAL PACKAGE WEIGHT . . I hereby acknowledge that the above list represents e proporty taken from me and that I have received a copy of Bt ts receipt. I hereby acknowledge that the above list represents all property impounded ,e in the official performance of my duty as a police officer. (S — t )2—. SIGNATURE DATE !GNAT •E ID# UNIT RECEIVED BY REAS• DATE/TIME RECEIVED e lb .c",e \‘\<(-4) EFTA00232930 5510., l• • 40. - ft 7 • . . POPO Fo 052 PALM BEACH POLICE DEPARTMENT PtrtERTlizRILEFEIPT "Ace 0' 6 DETECTIVE BUREAU C.3 PROPERTY U FOUND 0 DECEASED (Probated) U PERSONAL 9 CONFISCATED 0 DESTROY blEVIDENCE i RIAL'. ' LABORATORY 9 STOI.ENRECOVERED D OTHER ( O 10 i 'S INIIDEItT rATIoN NUMBER 0 ...) DATE/TIME RECOVERED t 0 200( 14/0 PROPERTY NUMBER (Leave Blank) - OS -- i o 3 LA BIN NUMBER (Leave Blank) ADDREStig.AROPERTYttlPCUNDC:274A 1 i :1'177 i I 0 DISCOVERED BY /D.O.B ADDRESS Street City Zip PHONE NUMBER OWNER'S NAME / D.O.B. ADDRESS Street Coy Zip PHONE NUMBER SU Ears NAME: D.O.B. R:frouj ADDRESS Street CV , Zip 3 CY /i L - O PHONE NUMBER ADDT'NL SUSPECT / D.O.B. ADDRESS Street City Zip PHONE NUMBER • SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM U !k: Days NO' CLA'M ITEM OUANT TY VAZJE DESOR,RT ON ft!;.r.-SC 1 V :t4 672E-Lefru Pit 1D. . ci - ,,, -I I4 * knl! ilAuf.:1 _ . . _. . ._ fiji eliet O 0 . Co/ 4-P r. V.'LkiVA . I k2f-tal, 2.,/..,-4 -kstkr:!‘:,•,!*!:;. c Nr. 0 t• .;.* :r• )/ kle TM TIN!) O ii ', N-I . 29n 3 TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents a!: property taken , horn me and that I have received a copy of this receipt I hereby acknowledge by me in the official performance that the above list represents all property impounded of my duty as a police officer. ""Ncit t < 0 SIGNATURE DATE SIGNATUR ID# UNIT RECEIVED BY REASON DATE/TIME RECEIVED n-) 3 2..--' , 2 e /0- ,D o- US /Soo C rJ EFTA00232931 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT PRP° Fn'm 457 ,— - 3 PROPERTY 0 FOUND O DECEASED (ProbaleC) 3 PERSONAL, 0 CONFISCATED 0 DESTROY J/ICEV(DENCE TRIAL 0 LABORATORY 3 STOLENITIECOVERED OTHER INCIDENDCITATION NUMBER b5- 503 DATE/TIME RECOVERED lo-11-05 (goo PROPERTY NUMBER (Leave Blank) r: (r) - i 0 D -S. BIN NUMBER (Leave Blark) ‘ ..:_ c/ Li t'j "•-• ADMVERESOPER IMPOUNDED Anlit 2 0,O 0 COVER D /0.0.B. ADDRESS 19 Ca), ZIP PHONE NUMBER • - OWNER'S NAME i D.O.B. ADDRESS Sttoot Crty Zip PHONE NUMBER SUSPECTS NAME / D.0 B 1)....1 6-- ADDRgSL Street ty Zp .5 CY FLJ3er/o PHONE NUMBER ADD'INL. SUSPECT! D.O.B. -., ADDRESS Street City 4, PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM 1:1 90 DAYS NOT CLAIM D ITEM a QUANTITY VALUE DES TX2AtAit . IQ 6 P,y TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents all properly taken Irom me and that I have received a copy of this receipt. I hereby acknowledge that the above est represents all property impounded by me in the official performance of my duty as a police officer. Ili C .1)Z. > SIGNATURE DATE SIGNAT IDI UNIT RECEIVED BY REASON DATE/TIME RECEIVED jki ._ c(3)? F, /C()* 6 . c._ C77( 0, DETECTIVE BUREAU EFTA00232932 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT PIM Form esa DETECTIVE BUREAU ci PROPERTY 0 FOUND CI DECEASED (Probated) 0 PERSONAL. '. CI CONFISCATED 0 DESTROY R! EVIDENCE IQ tRIAL 0 LABORATORY 0 STOLEN/RECOVERED 0 OTHER INCIDENT/CITATION N MBER OS 56. DATE/TIME RECOVERED io-vros- to:45" PROPERlY NUMBER (Leave Blank) • (-6-. tot-1 BIN NUMBER I G. 9.5 (Leave Blink) LI 1 A3pS3ERE PR5RTY IMMUNDED • Calitin t ao AC DIKVER 0 BY /DC:B./ ADDRESS Street City 20, PHONE NUMBER • OWNERS NAME / DO./ DDRESS Stint City ZIP PHONE NUMBER SUSPECTS NAME/0.9.B. MAI j ADDRESS Street City ' 40 PHONE NUMBER ADDTNL SUSPECT/ D.O.B. ADDRESS Street Cary DP PHONE NUMBER SPECIALINSTRUCTIONS FOUND PROPERTY CLAIM C3 se DAYS NOT CLAIM) ITEM # OUANTrY VALUE DESCRIPTION ( )4.4 1SC kb) 140ASZ:- Pi c 5,4-COE'S flotok -CC/Asa ( to-2 f-us--) i TOTAL PACKAGE WEIGHT I hereby acknowledge that the above lisl represents all properly taken from me and that I have received a copy of this receipt. I horob me in acknowledge th that the above list represents all property impounded cial performance of my duty as a police officer. rc — 07/ SIGNATURE DATE SIGNA RE IC) UNIT RECEIVED BY REASON DATEITIME RECEIVED EFTA00232933 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT nePD Fars *52 U PROPERTY Li FOUND U DECEASED (Probated) U PERSONAL U CONFISCATED 0 DESTROY gEVIDENCE g TRIAL U LABORATORY :I STOLENRECOVERED S' 0 OTHER 0 P kg s INCIDENT/CITATION NUMBER 05- 5(45 DATE/TIME RECOVERED I tot4oS di : DS pkA PROPERTY NUMBER (Lowe Blank) ID 5. - i c.: Sa--- BIN NUM (Leese Stark) ( 19 '11 `-k Aze, - ( 3 R4sg HEs PRCRTY IMPOUNDED 1•31 V le Oftri 2 A tkA f)-)EAC 1-( 1 F L t 2_2114/4 1 --WA DISCOVERENSY /D.O.B. 1 -1 i<CECAllel ADDRESS n. ) .. ,City Zip PHONE NUMBER OWNERS NAME/ O.O.B. ADDRESS Street Cny Lp PHONE NUMBER SU,SPECT'S NAME/ D.O. ADDRESS Street . City Lp -59Z) •Dcz PHONE NUMBER ti psy c Ns .5 -it EL A 1 a ADDTNL. SUSPECT/ D.O.B. ADDRESS Street City Zip PHONE NUMBER SPECIAL INSTRUCTIONS rOur.D PROPERTY CLA M Li 9; CAV3 ND' CLAW {J ITEM a QUANTITY VALUE . . . DESCRIPTION . . , KAPAItq l 1 1. 111::O \J \0€0CASsrrtfe 2 '3:>tsiv LA t 04) ciksW44-C f‘A c -9 0 tAd&7%.0// TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list 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 .me in the official performance of my duly as a police officer. 1 9- 1 E TAIL; SIGNATURE DATE SIGNA JON UNIT RECEIVED BY REASON DATE/TIME RECEIVED i • A 7-3 r //-07- ei C 7 Tc, ke. DETECTIVE BUREAU EFTA00232934 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT OD Form 4.52 DETECTIVE BUREAU 3 PROPERTY cl FOUND U DECEASED (Probated/ U PERSONAL CONFISCATED CI DESTROY )(EVIDENCE TRIAL Ci LABORATORY CI STOLENRECOVERED Ci OTHER INCIDENT/CITATION N tEIER ;DATE/TIME RECOVERED 05- I I 1020 5 t 24o PRCPERTY NUMBER (Leave Starlit c, 5-- is (-.-. t / BIN NUMBER (Leave Blank) l' 9 c`i.a ADDIRESS_WHEBEPROSERTY IMPOUNDED fin 045 -O. OIR...H•fly VC) CtIGQOVEREW / D. B. Or ir Wer rl￾ADDRESS pb pStre) City It) PHONE NUMBER OWNERS NAME / O.O.B. ADDRESS Street City Zp PHONE NUMBER SUSPECT'S NAME / D.O. r ADDRESS _ Street AN. In PHONE NUMBER Vil AI N1 t3 Vi :))5/3i Et— isila.) 1 33 4 1C) ADDTNL. SUSPECT/ DO.B. ADDRESS Street City Zp PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLA; \ 1 ::.I q.) DAYS V...) I !...t.Art.t J OEM # [ QUANTITY - , VALUE DESCR Pi ,ON P.i C t .....D::4""4 1 LI 1 c.szoc...Asc44-c . rArc--1..A i • 09, 3 twAilLe. TRW CCukiry C.c • • t-lo,noltAtm 1)1V. rre I lAcsta. \goicik /Da Nevis. .l...k ( .-1‘'S . i TOTAL PACKAGE WEIGHT I hereby acicnowledge that the above list represents ail property taken from me and that I have received a copy of this receipt. I heresy ac<nowlodgo that the above list represents all property impounded by me in the official pedormance el my duty as a poliCe officer. . . 19(f be2.- SIGNATURE DATE IGNATU ID# UNIT RECEIVED BY REASO DATEfTIME RECEIVED A ii 2 37er 6: // '1-( l / r oc, /c.„. EFTA00232935 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT >D ram, n2 DETECTIVE BUREAU 0 PROPERTY CI FOUND 0 DECEASED (Probated) 0 PERSONAL j CONFISCATED LI DESTROY 'EVIDENCE TRIAL 0 LABORATORY 0 STOLEN/RECOVERED 0 OTHER 9 V. ii , t 5 INCIDENT/CITATION O NUMBER ,5, 2 (.7:8 DATE/TIME RECOVERED 1 daps tr.?2, PROPERTY NUMBER (Lokva Blank) c (-. /4...) ( ri BIN NUMBER (Leave Blank) / 91 : 7/(i L5ARESINHEFI c.U_ROZ6YP3UNDED / n iv) ..-) .....) C 1c0 1115 ISCOVERckBY/D.O.B. ADDRESS 0 i6 Syy. (cm CM), Zip PHONE NUMBER OWNER'S NAME / 0.0.8. ADDRESS Street City Zip PHONE NUMBER SUSPECTS NAME / D.O. 11 . €_,(s Th */ • IV: •! ADDREV Street City Zip 3< iii:L EL)" ") PHONE NUMBER ADDT'NL. SUSPECT/ D.O.B. ADDRESS Street Cu)' Zip PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM j 9C DAYS NOT CLAN 4. ITEM tt QUANTITY VALUE: DESCRIPTION I 1 WO,/ '1.-1__ \JI ' \c' > • \)‘Ce • ri-l- . • .• . • 7 fitiVtak' NT ■ I PN-A `zt- LA- ‘) v-I5 V kOtO O'CSC. fi E. 4404-Q1.4 C./Nit— 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 duly as a police officer. l iCirc i IYZ.ww SIGNATURE DATE SIGNA ID# UNIT RECEIVED BY REASON DATE/TIME RECEIVED C, .-t 7. • EFTA00232936 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT PRP° Form *52 J PROPERTY j FOUND U DECEASED (Probated) 0 PERSONAL 0 CONFISCATED 0 DESTROY EVIDENCE \IL TRIAL LI LABORATORY 0 STOLEN/RECOVERED 0 OTHER I CIDENT/CITATION-klUMBER 05 - i"3GY DATEJTIME RECOVERED , Mous bps PROPERTY NUMBER (Leave Blank) .--- .c_5- I 07 9 ' BIN NUMBER (Leave Bunk) 7 1 .:7 / ,4",;::. /3 ; i ADeljSS u WHERE 2I OPERTY„IMPOUNDED \ 2 LOUNYC I I (1 0 60 Q lb DISCOVERED Y i D.O.B. 4." -- te y ADDRESS Street City 4, PHONE NUMBER OWNER'S NAME / 0.0.8. ADDRESS Street CO bp- c L PHONE NUMBER SUS 4 TIANAE t / 0. B. ADDR SS ,„A.5freet ,Qty ,(Street'! iex I lu cie PHONE NUMBER AODTNL. SUSPECT / D.0.8. ADDRESS Street City Itp PHONE NUMBER Splift...II . NS:c:LA TIO 1.0A0 A-A 0 aviulf --) FOUND PROPERTY CLAIM 0 s,) DAYS NOT CLAIM L.I ITEM ft ( QUANTITY VALUE DESCRIPTION t (-)ANAcoN3i!... Q.2 - u 5 360 0 1 0 -1 AL 2._--(s) p FE -a_ pcsst tvild) -CD O rn Q.E( Arl-r V - STATEJAV err &__ - a iira k--o u . boa tbu E.:-/- w1,1 4 - 12. - 5 14 .... v-bLoe(-2_ 2 - 0cc a cAsi. L.,,- oce.),.„ 0 IV15 Mit- 46 0 11 'MELD CA t I cli_ 1 -12... - -v,th-n • At e55 I NIA./ .2- - rz- \ -0 a / ,... (LN -,-._..(i 1 1. r (Pit i'divv i r 1--vcini 4/ f e 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 list represents all by me in the official ormanco of my duty as a police lerl property Impounded officer. . K Tyz-- SIGNATURE DATE SIGNATU DO UNIT RECEIVED BY REASON t DATE/TIME RECEIVE OA -i ..- r ' 4/ //' /O - e)5.- co DETECTIVE BUREAU EFTA00232937 — PALM BEACH POLICE DEPARTMENT ) PROPERTY RECEIPT DETECTIVin. EJRFAU FISK/ Form 052 Q PROPERTY 0 FOUND (Probated) i PERSONAL 2 coNFiscATED 2 DESTROY A EVIDENCE >I TRIAL CI LABORATORY —I STOLENRECOVERED 0 OTHER C:- r d Pt e — S - INCIDENT/CITATION NUMBER O5- 368 .' DATE/TIME RECOVERED /0 20- 05 i • 374in PROPERTY NUMBER (Leave Bank) ...- , i - -- t--, • I c_.c. (:) BIN NUMBER (Leave Blank) ckL, /RF/ Lii" L ADDRESS. WHERE PROPERTY IMPOUNDED ,:\>) .7/ tr • au / - 2 355- ii 7'. //El) ,,,2 DISCOVERED BY /D.08. ADDRESS Stray: Qty. Zip PHONE NUMBER OWNERS NAME /00.B. ADDRESS Spoof Qty Zip PHONE NUMBER SUSPECT'S NAME / DO.B ADDRESS Srreef. Cm" Zip PHONE NUMBER AODT'NL SUSPECT /DOB ADDRESS Street err Zip PHD \ r NUMBER SPECIAL INSTRUCT ONS 1/ el . 7 i • CC), PC PiC)p P•Y CLAIM J cc) DAYS NOT CLAN j , . -.- '' lir CF SCRIP IO14/1 • .‘f ' •- ...7:. .., .1 I , ... . -2 / , _ ___ -___. _ ..../ -- / 1 .if ✓ '/ /I 0.0 _ _ ... _ _. .._ __ _ Y . V -1-- -L￾TOTAL PACKAGE WEIGHT I hereby acknowledge that the abo a Est represents al: property taken from me and that I have received a copy of this rococo( SIGNATURE DATE I hereby acknowledge that the above hst represents all propeny repounded by me in the official performance of my clutytas efioltco officer. iel- r ii c- 7 -/ SIGNATURE IDS. UN:T RECEIVED BY REASON DATE/TIME RECEIVED EFTA00232938 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT °en Corm t52 0 PROPERTY U FOJND 0 DECEASED (Probated) Li PERSONAL 0 CONPISCATED U DESTROY )119EVIDENCE IQ TFOAL 0 LABORATORY D STOLEN:RECOVERED U OTHER INCIDEN3iCITAT)ON NUMBER cy.) 5(ce, DATE/TIME RECOVERED 0./q..05 /628 PROPERTY NUMBER (Leave (Meek) o .,,,2• e ..) /Li BIN NUMBER (Leave (Siena) - ii•/t/i :59S e ta:LERE PkaaR . ERITe.ZDEO xim./ i61.42 a . SayERED1,2Z.O.B. ADDRESS Street City Zip PHONE NUNIBER OWNER'S NAME / D.O.B. ADDRESS Street City Zip PHONE NUMBER SUBPECTS NAME/ D.O. (IPS -rk) d je. i. ADDRESS Street Cu ryt ;. .? Zip ±-7 SK et at( e PHONE NUMBER ADOTNL. SUSPECT / D.O.D. ADDRESS Street City Zip PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM 0 90 DAYS NOT CLAIM J ITEM a QUANTITY VALUE DESCRIPTION ' . PI W- T /IC--- 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 mo In the official performance of my duty as a police off icor. -----1) SIGNATURE DATE SIGN ID* ^^ UN/T RECEIVED BY REASON DATEMME RECEIVED . , S -vs / // - / 1 0 c-- /rift:. DETECTIVE BUREAU EFTA00232939 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT ,^oPD Form 152 3 PROPERTY 3 FOUND CI DECEASED (Probated) 0 PERSONAL 0 CONFISCATED CII DESTROY &EVIDENCE V TRIAL 0 LABORATORY ' 0 STOLEN/RECOVERED CI OTHER - I ER CS ‘3{7b DATEMME RECOVERED k l-IS os- 1 u3ittvi PROPERTY NUMBER (Leave Elan. . c c; - I ote-lo BIN. NUMBER Bawl:Wank) / z gig i Astrttmos sopEcyccook4 c.LoNo P A.W-6t:Pc ki D643,,R.Drat . ti ADDRESS.Q (3(7.7), City ZP PHONE NUMBER OWNER'S NAME / 0.0.8. ADDRESS. Street Cly • Iv PHONE NUMBER TECTS NAME 1 Y14// 43 p.o.e. I.. N..) 2: A. DRESS, _ Stre,t • ay . ) - 's CL 6(11110 PHONE NUMBER ADOTNL SUSPECT/ D.0.8. ADDRESS Street ary Z. PHONE NUMBER SPECIAL ; ic14/ , Se... C o ql FOUND PROPERTY CLAIM Li 90 DAYS NOT CLAIM ITEM QUANTITY VALUE - DESCRIPTION I I _ ic ri-cc\ CS TI-16 • 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 me in the official performance of my duty as a police officer. TM - 0 92; s SIGNATURE DATE NA lb* • -UNIT RECEIVED BY EASON DATE/TIME RECEIVED t ; - }if ,4... i •/5-cl R/1/c /) DETECTIVE BUREAU EFTA00232940 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT PAPP ;aim •52 U PROPERTY CI FOUND U DECEASED (Probated) U PERSONAL . U CONFISCATED LI DESTROY WEVIDENCE va TRIAL U LABORATORY Q STOLEN1RECOVERED D OTHER INCIDENT/CITATION NUMBER 0 5 L:568 DATE/TIME RECOVERED I t iscc t t5 3o PROPERTY NUMBER (Leave Blare) _ BIN NUMBER (Leave Blank) I-7 6iNcs - qv; ADD.R.ESS WHERE PROPERTIIN/POLIND4) 1 :% S. Coy. Y Ron-4> (). . vp-14/AA eptinc._P DISCOVERED BY / D.O.B. Dell VECAREN/ ADDRESS pb Moo! City Zip PHONE NUMBER OWNER'S NAME 1 0.0 B. ADDRESS Street Call al PHONE NUMBER SUSPECraNAME: D.O.B IM r-Erriciii , sc:. -St ADDRESS Street City Zip scjg crz L. ?>2_, ii o PHONE NUMBER ADOTNL. SUSPEC/ C.O.B. ADDRESS Street City Zdp PHONE NUMBER. SPECIAL INSTRUCTIONS FOUND PROPERTY CLAIM .J 9C. LAYS '4:1 CLAIM J ITEM A QUANTITY VALUE .. . DESCRIPTION . • . 1 0 % . 04011, LI P4 i u 0 ( 1*()A 444QC 1 •JV 011,A. TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list from me and that I have received a copy SIGNATURE represents all property taken of this receipt. . _ i hereby acknowledge that the above list represents by me in the &lima] performance of my duty GNAT' 7 all property impounded as a poce officer. ____ —19 IS 0 DATE • • ID/t UNIT RECEIVED. BY REAS N DATE/TIME RECEIVED - Tr .) -3 > C- • //- /(:,- 67 <, 73(4,_ DETECTIVE BUREAU EFTA00232941 all"CitiPhTir PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT PD Form 452 DETECTIVE BUREAU Di PROPERTY )(EVIDENCE INCIDENT/CITATION NUPR t 2 te-30S- 54-5c) ADDRESS WHERE PRDP-ERTY IMPOUNDED 34-5 0. Coo (2OA-(-) 0 FOUND ❑ DECEASED (Probated) "I LI PERSONAL 16 TRIAL ❑ LABORATORY D CONFISCATED D DESTROY ❑ STOLENRECOVERED 0 OTHER DATE/TIME RECOVERED PROPERTY NUMBER (Leave Mark) o6-12, (1)t) 2 BIN NUMBER (Leave Blank) ISCOVEREMD.O.B. . OWNERS NAME / D.O.B. SUSPECT'S NAME /0.0.B. 'EPSTit-b jgcc ADDrNL. SUSPECT / D.O.B. sPftiCrTII I-N60y ITEM QUANTITY VALUE ADDRESS S get) City Tip PHONE NUMBER ADDRESS Street City Zip PHONE NUMBER ADDRESS Suer)! 1S% EL 60.((i0 City Zp PHONE NUMBER ADDRESS Street City PHONE NUMBER 111-0-40M0 CAW FOUND PROPERTY SC DAYS DESCRIPTION. %CT D C pau J TOTAL PACKAGE WEIGHT I hereby acknowledge that The abo o represents al! property taken from me and that I have received a copy of the receipt. SIGNATURE RECEIVED BY DATE pas eRT-3- 60 I hereby acknowledge that the above list all property impounded by me in the official performance of my duly as a police officer. ‘j3 UNIT DATE/TIME RECEIVED / tkiir o750 30 EFTA00232942 witomeeecio etiseinfema(r. rigiesi PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT Dc, ECTIVE BUREAU Para Gam #57 i U PROPERTY I.J FOUND U DECEASED (Probated) E.) PERSONAL U CONFISCATED Ut DESTROY EVIDENCE RIAL U LABORATORY U STOLEN/RECOVERED a OTHER INCIDE TiCITATION NUM ER 0 _ "-. ....?&9 DATE/TIME RECOVERED e/-/ -C.:, PROPERTY NUMBER (Leave Blank) r. I. BIN NUMBER (Leave Blank) in ) e '. .. e!Ni Z ADORES WHERE PROPERTY IMPOUNDED 77........ , - •5) , 1 Ct. . lei -LL) DISC VEAED BY/DOB 2Fr ADD S Saver Cary 1 Zp PI' t Cif r f— PHONE NUMBER OWNER S NAME/D 08 A RESS Sroor Zp PHONE NUMBER SUSPECTS N E:DOB vie ,v c- - -,7vir ADDRESS ` Streer Zip ir, /lir. PHONE NUMBER AD T NL S SPEC y /AO . i ADDRESS String Crfy Zp PHONE NUMBER SPECIAL INSTRUCTIONS c ,. '. , Pr' -i ,-<- r -, %i J • J (..-: ,,,, , C....'C:4H” 0% . „.._,..-- it l iA g // e. ,..... . G 1 "e 7 -01 Zei/eVi/(7 - CX (71 We; I . CIA;CC e -AY‘afigt4M li t ga j-4.:" n -. - _-- -I- - ....-- - - / ,,,,y 6: 4/ .. (....-„<„--- 1,2 - -- (.(- , i iy fie; G)'/_ S .0 F ... --.),-7 _ p ,-- - • TOTAL PACKAGE WEIGHT I hereby acknowledge that the abo' o list represents all property taken From me and that I have received a copy 01 this receipt. _ I hereby acknowledge that the above fist represents all property impounded by me In the official performance of my duty as a peace officer. —..t -......-- SIGNATURE DATE SIGN URE ID* UNIT RECEIVED BY REASON DATE/TIME RECEIVED ,... . EFTA00232943 PALM BEACH POUCE DEPARTMENT PROPERTY-RECEIPT PBPD Form #52 U PROPERTY 9 FOUND CI DECEASED (Probated) CI PERSONAL' CI CONFISCATED j DESTROY a EvIDENCE tdTRIAL CI 0 STOLENMECOVERED CI OTHER INCIDENT/CITATION NUMBER '05 - 3 W.., DATFJT114E RECOVERED i2o710c tc-2,0 PROPERTY NUMBER (Leos Blank) ' _- - ; 4. i i BIN NUMBER (Leave Brim . ADDRESS WHERE PROPERTY IMPOUNDED 2 o An INk tWVEREDfrt, vt L.- / 0.0). . _\/ r ADDRESS Al v r+, Ho tepee( City Z9 ) PHONE NUMBER OWNERS NAME/ D.O.B. ADDRESS Street Cry Zip PHONE NUMBER SUSPECTS NAME / D.O. F- ociti c N. T7F 7. . ADDRESS Street City 4) 3S5 tTi I Br( (\\c_4 'i26 NUMBER ADDT'NL SUSPECT/ D.O.& ADDRESS are.: fly' - ZO PHONE NUMBER SPECIAL INSTRUCTIONS FOUND PROPERTY CLAM CI 90 DAYS . NOT CLAIM CI ITEM # QUANTITY VALUE DESCRIPTION I k i:'') 1 ) \I D • LL ( .. Th i:) c , v c> Pk Pr 71 ,0 . • ,7. Li"." -:, 05 7c, 0067 LA:=1,. LO') (3<>1.1:1 1IV Ci KJ C , E. fl‘ ri r . t TOTAL PACKAGE WEIGHT I hereby acknowledge that the above list represents al proporty takon from me and that I have received a Copy of this Metal. I horeby acknowledge that the above list represents all property impounded by me in the official performance of my duty as a poeCe officer. '‘ S . SIGMA RE .11 SIGNATURE DATE IDI UNIT RECEIVED BY REASON DATFJTIME RECEIVED I ..., „ • CONTRIBUTORS COPY EFTA00232944 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT PBPD Forrnit52 ❑ PROPERTY 0 FOUND a DECEASED (Probated) PEPSONAL EVIDENCE STRIAL a LABORATORY , J gTOLFN FCCVEREO INCIDENT/CITATION NUMBER O e 3c,g • ADIRESrEEE7pROPERTY IMPOUNDED 4 C. . R.cAn DISCOVERED BY! D.O.D. OWNER'S NAME I ache. °AMBLE RECOVERED ' 00106 \SU DETECTIVE BUREAU 0 CONFISCATED U DESTROY 0 OTHER PROPERTY NUMBER (Lowe Blank) O r i BIN NUMBER (Leave Bin) /2 f-/ SUSPECT'S NAME / D.O.B. ADDTNL. SUSPECT / O.O.B. SPECIAL INSTRUCTIONS ADDRESS pgfrp Cary PHONE NUMBER ADDRESS SUM CI) ZP PHONE NUMBER ADDRESS 5R Sheet cc Cry Zip PHONE NUMBER ADDRESS Skeet City zip PHONE NUMBER FOUND PROPERTY SO DAYS CLAIM U NOT CLAIM .,) r ITEM 4 QUANTITY VALUE DESCRIPTION ot--1\1 Cir,c;) Ht: TOTAL PACKAGE WEIGHT weby acknowledge that the above list represents al property taken vn me and that I have race ved a copy at this receipt --- SNATURE DATE I hereby acknowledge that the above list represents all property Impounded b e in the office( performance of my duty as a police officer. SIONATUR RECEIVED BY REASON -19k ION UNIT yr\ DATE/TIME RECEIVED 4 rya- io-o () O736 EFTA00232945 PALM BEACH POLICE DEPARTMENT PROPERTY RECEIPT Keil) Lyn. 65 DETECTIVE BUREAU rt I ...) PROPERTY I j rowto j GE:EASED (Prctatee) Jpiril:c.AL ❑ CONFISCATED CI DESTROY gE 4.PDPLCE I l i d TRIAL •J LABORATORY ...) STOLERRECOVERED L.1 OTHER INCIOF NT CITATION NU SER DATE/TIME RECOVERED PROPERTY NUMBER tLoaye Drank) B N NUMBER (Leave Blank1 PAM f)EAC 2 I-4 6Ot3S _ ft FESS SPeo: C•ry Zp PHONE IshAtJ3ER OWNERS-1FL/ D OS ADUFESS Street L. :v Zp PHONE NUMBER .',.LISPECTS NAME" iasnio , O sM ir DOPESS 3sc 6L Stre Zp Nutt° PHONE NUNTBER AODTINL SUSPECT/OOB ADDRESS .Street Cat Zp PHONE RUMEX, SPECIAL INS- RUCTIONS t FOU,NG PROPERTY CLA SI J I ,L DAY S NOT CLA I.' J — EM e OUANT ‘ `VALUE DESCRIPTION E I I kk AC. to CASS .,-.:1311/4) )1 1 ( ‘rYITE elf% TOTAL PACKAGE WEIGHT I I hereby acknowledge that the above I st represents all property taken torn me and that I have receivet a copy of 'h s rece•Pt _ I hereby acknowledge that the above list reprose/es all property impounded me m the olrolat Porgormance of my duty as a pol:co pricer, SI Alt - - SIGNATURE DATE RECEIVED BY RE ON DATE/TIME RECEIVED > 1 / 1 5 73 k TI o -3 G,... t --7 3, , L EFTA00232946 SEARCH WARRANT fitOPY • (A7TACH TO AFFIDAVIT) IN THE CIRCUIT COURT OF THE 1. tt. 1 t.ENTH JUDICIAL CIRCUIT N 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 Joseph Recarey WHEREAS, complaint on oath and in writing, supported by affidavit of a credible witness, or witnesses, to wit: Detective Joseph Recarey which is attached hereto and made a part hereof, has this day been made before the undersigned: Judge Laura Johnson (Circuit)(County) 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 ofthis warrant and the Court being catisfiedofthe existence of said grounds set forth in the affidavit and that the laws ofthe 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 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 %lin Way, make a right or westbound turn and travel Approximately .1 (one tenth) of 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 . 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. EFTA00232947 Op 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 ofthe North side of the 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 oldie 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 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) 2' degree Felony 2nd degree Felony EFTA00232948 NOW THEREFORE, you, or either of you are hereby commanded with proper and necessary assistance, in the name ofthe 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 ifthe 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 rested in connection therewith before the Magistrate or any other Court 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 thetime 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 betaken, 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. EFTA00232949 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 Joseph Recarey awry 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 tight or southbound turn and travel approximately .8 (eight tenths) of a mile to El Brillo Way. At El Brillo 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 desired to be searrhed, iv-hiding the curtilar attached thereof being the Premises occupied by or under the control of: Jeffrey Epstein v/M Date of Birtl Page 1 EFTA00232950 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 mm; 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 chives, 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) My 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) 2" degree Felony 2'd 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 Michele Pagan went to /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 therapist. During an audio taped interview, Pagan 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 boss as a white male named "Jeff who lived in Palm Beach (Later positively identified as teffrey Epstein).--11e-victimexplainedthat she was to go with her to Jeff's house. The victim stated told her that she would pick her up at the victims house on Sunday. 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 fathers house on 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 EFTA00232951 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 small guard/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 af her clothes. The victim stated he was stern when he told her to take off her clothes. The victim said she 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 get on his back. The victim stated she straddled herself on Epstein s back. The victim stated her exposed buttocks were touching Epstein s bare buttocks. 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 massaged his chest and shoulder area. Epstein pulled out a purple vibrator and began to massage her vaginal area. The victim stated there was no penetration as the vibrator was on top of her underwear. The victim recalled Epstein ejaculating because he had to use the towel to wipe himself as he got off the table. E stein 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 EFTA00232952 On October 3, 2005, Sgt Frick and I responded to the address of and viewed her vehicle parked in the driveway. Sgt. Frick 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. 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 unmarkedDetective vehicle, I placed a tape recorder within the vehicle to record any conversations within the vehicle. During the ride back to the police station, advised she is attending Palm Beach Community College in the Palm Beach Gardens Campus 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 interview was asked how she became in contact with Epstein. stated back when she turned 17 years of age she was approached by a friend 'M 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 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 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. ..wring the massage, stated "He tried to touch me and I stopped him." I asked how did he tried to touch her. He grabbed her buttocks 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 the massage naked. At the conclusion of the massage, Epstein paid $200.00 for the massage. He explained, I know you'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. was asked how many girls did she bring in total to Epstein. stated six that she can remember. stated she brought 1.1(16 female), t16 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 youngest. advised the victim was the youngest as she was fourteen when' he 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 bring 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 steins House and entered through the kitchen door. They met with the house chef and Epstein's assistant 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 EFTA00232953 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 brow t to Epstein. She further stated that she had changed her cellular number to avoid ng contacterS . 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. still tries to call the house and leaves messages. With the assistance of we were able to identify , DOB DOB Sgt Frick 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 Frick and I went to speak wi We met with Mrs. Mother) at the front door. We explained the ongoing investigation and felt tha may have additional information as we had information that she had "worked" for Jeff . Mrs. I 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, Mrs I was 'vised we would be speaking with her. She expressed if her daughter had information, she wanted to “asist. 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 Frick and I thanked Mrs. I 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 that' had my telephone number and hopefully she would call. On October 4, 2005, Det Dawson and I drove to the home and met with 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. 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 th • en. She was introduced to., Jeff's assistant, and was brought upstairs to the mater bedroo 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 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 as paid $200.00 for the massage. 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 EFTA00232954 stated also received money for takin received for bringing her to Epstein. occassion with and another girl, , while was taken upstairs by her there but was unsure in the amount of monies stated she returned to Epstein's house on another stated she waited in the kitchen with 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 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. This voice mail message was recorded onto a micro cassette. 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 Jeff. asked her what was going 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 INnot 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 want to speak of this incident in front of her mother. At approximately 15:48 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 Jeff's house twice. The first time she went, drove to the house. They entered 'rug 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. Jeff then entered the room wearing a towel. He laid on the table and picked out a lotion fore to nib 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. She got with who was sitting in the kitchen and told her "let's go." le 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. le 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. IN 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 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 Jeff was unable to touch her buttocks. Jeff then rolled onto his back during the massage—he attempted to touch her breasts. then became upset again and told 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 Jeff. She provided a telephone number for The interview was concluded .nd the micro cassettes were turn in as evidence. Page 6 EFTA00232955 I later researched and discovered she resides in Royal Palm Beach. Det Dawson and I drove to Royal Palm Beach and met with at her residence 111 Segovia Ave in Royal Palm Beach. agreed to speak with us in the kitchen area. During a sworn taped statement, stated the Bowing: On or about November 2004, She was approached by 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 and (=came 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 during 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 touched his buttocks with hers. was instructed to return to the ground at which Jeff turned to have his chest rubbed. advised she was unsure if he was masturbating. did not want to look at his penis area because she was uncomfortable. Jeff removed a large white vibrator which was next to the bed and turned it on. stated he began rubbing the vibrator over her thong underwear on her vagina area. Shortly thereafter, Jeff 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 •asn'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 Dawson and I met with at her residence. As was only seventeen years of age, I had notified her mother Mrs I , 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 advised she wanted IN 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. IN was friends with the friends of and knew the same people. had been previously told by her friends what M i did for Jeff. 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 driveway. They entered the kitchen area of the house and met with Jeff. IN was introduced to Jeff. stated she observed numerous photographs of naked young girls throughout the house. led irtnin to the main bedroom area and set up the room 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. advised she did not remove her clothes. She was wearing tight jeans and a cropped tank top exposing her belly area. Page 7 EFTA00232956 During the massage, Jeff removed his towel and laid on the massage table naked. AM rubbed his chest area, Jeff attempted to reach down her pants through the buttocks area however was unable to due to the tightness of the jeans and a tight belt. IE advised Jeff began to masturbate as she rubbed his chest. Jeff moaned as she rubbed his chest. She observed he was continuing to masturbate and attempted to reach up ,r tank top and touch her breasts. pulled back and Jeff stopped. However, he kept masturbating until ire climaxed. He cleaned himself with the towel he was previously wearing. I asked E if she knew the difference about circumcised and not circumcised meant. She explained she knew and advised Jeff 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 Jeff. She did however, go to the house with 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. IE stated yes, told her that a massage would be expected possibly naked and possibly some touching involved. has no formal training in providing massages. • 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 Jeff 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 a for going with her to Jeff's house and recommending was unable to remember telephone number. The interview was concluded and we left the area. On October 6, 2005, at 11:45 am. I met with at Lynn University 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 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 prepare the massage table. advised Jeff would ask her questions about her. He knew she was a soccer player and would be attending Lynn University. 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 EFTA00232957 During the massage, she asked Jeff if she could borrow one of his vehicles to visit her family and boyfriend in Orlando. 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 grabbed her buttocks and caressed the buttocks checks. I asked￾if she was wearing undergarments to which she replied her thong underwear. Once he tried to touch her ',masts, 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 use the vibrator 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. 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 b on October 3, 2005 ad informed her that Jeff had rented her a new Nissan Sentra and she shoo come by the house to pick it up. 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 Gym field. I asked her if she ever took any one to the house. explained she took a friend of hers who has returned to Orlando 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 Dawson 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. On October, 11, 2005, Det Dawson and I had traveled to Jacksonville, Florida and met with date of birth, . explained she had gone to Epsteins house since she was sixteen. She explained she was brought to the house to perform a massage by Once she began explaining that the massage immediately escalated to other things, she further explained she had gone to the house mdreds of times. 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 massage his chest area. stated Epstein would then began to masturbate himself and at the same time would insert his fingers in her vagina and masturbate her with his fingers. explained Epstein would continue this process until he ejaculated. He would then utilize a vibrator/massager on her vagina until. ejaculated. NM 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. advised that thin s escalated within the home as Epstein would pay. to have intercourse 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. and . This occurred during the time was sixteen years of age. advised this catiamed to escalate and occurred 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.. stated Epstein would photograph them naked and having sex and proudly display the photographs within the home. continued to -con W3 -the house an ately $41.10.UU to Sbuo. every time she went. stated during a massage involving turned . on to her stomach on the massage bed and inserted his penis into her vagina. . stated Epstein began to pump his penis in her vagina. . became upset over this . Page 9 EFTA00232958 She said her head was being held against the bed forcibly, as he continued to pump inside her. She screamed no and Epstein stopped. She told him that she did not want to have his penis inside of her. 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. Jur 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 18th day of October, 2005 . JUDGE in and for Palm Beach County, Florida Page 10 EFTA00232959 07/26/2006 15:44 5618354700 PEP]) 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 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 assignaUon, contrary to Florida Statute 796.07(1) on three or more occasions between August 01, 2004 and October 3/, 2005. contrary to Florida Statute 798.07(2)(f) and (4)(e). (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 Fifteenih Judicial Circuit of the of Florida, prosecuting for the said S.tate EFTA00232960 07/26/2006 15:44 5618354700 PBPD TRAINING PAGE 02/02 GRAND JURY FOREPERSON DATE Jeffrey E. Epstein, Race: White, Sex: Male, DOB Issue Warrant EFTA00232961 REQUEST FOR WARRANT • *DEFENDANT: Jeffrey Esotein DATE OF BIRTH HABITUAL OFFENDER: YES NO A/K/A VICTIM RELATED / ACQUAINTED WITH DEFENDANT? YES )O( NO AGENCY CASE NUMBER: 05.368 (11 LEAD OFFICER: Det. Joe Recaery AGENCY: PALM BEACH POLICE DEPARTMENT 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 SO, WHAT AGENCY?: SENTENCING RECOMMENDATIONS: CONTACT DETECTIVE ADDITIONAL COMMENTS: /ICING DOCUMENTS ATTACHED: X ARREST FORM WITNESS STATEMENTS (ALL) Y P.C. AFFIDAVIT (2 COPIES) 1 FCIONQIC CRIMINAL HISTORY Pity latest., Nie WITTVSS / EVIDENCE LIST IFSIY 6010A 40 pSaf ea:MU ye if￾REQUEST FOR CONVICTION LETTERS consam it ASA .‘3 tt SWORN STATEMENT OF MATE WTINESS(ES) y PROPERTY RECEIPT Paakaltva s Nen ro Asir gC OFFENSE REPORT (2 COPIES) VEHICLE TOW RECEIPT ACCIDENT REPORTS (ALL) OTHER ATTACHMENTS INCLUDE: INITIAL FOR COMPLETENESS: JR Omen 7915 :Ds 050106 DATA • SUPERVISOR '1 DELIVERED BY: Recarev D fro Fan!. kvot L n 7Th-co 5 RECEIVED, STA ATTORNEY'S. TWICE ON: IDS DAIS EFTA00232962 Cent tante. I _I ARREST / NOTICE TO APPEAR 1 Anna 3 ROWAN W Wynn' Juvenile Referral Report 2 N T A 4 Rawest Tor Caw YI pricy W11 FLOy5i010i 6 1 0 x 0 PALM BEACH POLICE DEPARTMENT Number NORnOt Nam* vice Type ASLI. Felony not es many L_ a app 2 Traffic Felony Lawlor.< Arrest faicluSIN Name of Flairiebb ANInCy Report Number (NTAN only) 7 L6 11 1 1 -1 1 1 1 0 3. leaderneenor 0 5. 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UNDERSTAND THAT MOLD I WILLFULLY FAIL 70 APPEAR BEFORE L/FIT AS REQUIRED BY THIS NOTICE TO APPEAR, THAT I MAY BE 1ELDW CCNTEMPT OF COURT AND A WARRANT FOR MY ARREST SHN..1 BE ISSUED. &gnaw* of Delondaw la ANNA, are Print I "- Clele Spree a 2 "'YD la sew Agency Saran otArreseflo Caber X • • ) Neems4..„AnsMIng Mow (RYE) •• t.f. ;‘.k. I '•.., Tramonteartcrx 1.0.1 0 Dangerous 0 Reim mow O Stow O Other. Wake PONY 1.0.1 Name WrIncalon (Primal by AnNOWN) (PRINT) Pcuce FINN Rims hes a suttea WINE NIB an if • PAGE OF DISTRIBUTICet BICE — COURT WRY GREEN — STATE ATTORNEY YELLOW — AGENCY PINE — JAIL GOLD • DEFENDANT (N.T.As ONLY) EFTA00232963 OBIS Number i_ i t _L I I i t ARREST / NOTICE TO APPEAR I Mimi 3 Reams, Ice Wanvit Juvenile Peden' Report 2 N TA 4 Iliptemt to, Cepa FT Juverge 1---- sotsAgency F OR* Natter mot 5 1 0 1 0 t 6 1 0 i 0 Agency Name PALM BEACH POLICE DEPARTMENT Agency Report Number (NT.A.'s only) 7 1.6 H i Ft 1 I I A III t I) F nr a .0 I. 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I UNDERSTANO THAT SHOULO I WILLFULLY RAIL TO APPEAR BEFORE RT AS RECUIRED Y THIS NOME TOAPP1AR. TO% I MAY BE HELD INCOVTEMIT OF COURT AND A WARRANT FOR MY ARREST SHALL SE ISSvED. 2 Wakes or CtetsSlini (cr Justices arc Parent e Cobden) Due Sind SIT, 01r other Agency Sows. of Meiling Once X Name Venhcaan (Pala, FY SITIIFIFFI (PRINT) 0 Dangerous 0 Refitted Arras 0 Souse 0 Oliw￾HIM of toeing Office (Phil) I.D. • PAGE masa Deputy LD I 1 rasa Tranliparene Officer ID.A Aga" Moen here it Sad Maroc, with ant OF DISTRIBUTION: WHITE — COURT COPY GREEN — STATE ATTORNEY YELLOW — AGENCY PINK — JAIL GOLD • DEFENDANT fle Tiks COLT) EFTA00232964 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 Police Casa: 05-368 (1) Defendant: Jeffrey Epstein Race/Sex: White Male DOB: Charges: 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 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 clothing to provide the massage. As the victims complied and provided the massages, Epstein would rub his fingers on their vaginas. On occasion, Epstein would introduce a massager/vibrator and rub the victims vaginas 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 ' dot- 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 tated that dob a cousin of boyfriend and classmate igh School, worked for a wealthy man and did sexual favors for him. She also admitted that ha o ered 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 herto Epstein's house. IMI stated that along with a Hispanic female, later identified at pick her up at her father's house on a Sunday. In was not sure of the exact dates but knew it was a Sunday. IMI 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 County Palrp Beach Det Joe Recarey, who is personally known to me. State of Florida Signature of Police Officer (F.S.S. 117.10) Signat sting Officer Date: 112006 Pagel of 22 EFTA00232965 Signature of Police Officer (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Atency ORM FLO 500600 conversation occurred between and • whereas reportedly told that if Jeff asked her age, 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 IMI 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. Shortly thereafter, Epstein and his assistant, described as white female with blond hair and later identified as entered the kitchen. Epstein introduced himself to . IN 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. El 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 al 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. to take off her clothes. El stated Epstein was stern when he told her to take off her clothes. IN said she did not know what to do as she was the only one them in the room so 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 thong panties on. Epstein then instructed her to give him a massage pointing to a specific lotion for her to use. As IN began to give Epstein the massage, he told her to get on his back.. stated she straddled herself on Epstein's back whereby her exposed buttocks were touching Epstein's bare buttocks.. 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 to or affirmed before me this 1' day o Det Joe Recarey, who is personally known to me. State of Florida y, Signat ting Officer Date: 0 1/2006 Page2of 22 EFTA00232966 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 massage Es vaginal area. • stated there was no penetration as the vibrator was on top of her underwear. recalled Epstein ejaculating because he had to use the towel to wipe himself as he got 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 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 a to assist with the investigation. At our direction • conducted controlled taped phone calls to cellular telephone 561- M= • spoke with in an attempt to arrange 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 subsequently called back • and left a voice mail message for her indicating that she had set up an appointment 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 Frick and I went to residence and viewed her vehicle parked in the driveway, a red Dodge Neon. Sgt. Frick 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 before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida County of Palm Beach Signa urT r sting Officer Date: 1/2006 Page3of 22 EFTA00232967 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. 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 grabbed her buttocks 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 brought to see Epstein, each time she was paid $200. stated she had brought the following girls: • ( al6 year old female), (a 16 year old female) and said that at the time she brought these girls to Epstein's house they were al114 through 16 years of age. I asked which one was the youngest advised I. 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 tclitein's house and entered through the kitchen door. They met with the house chef and Epstein's assistant . I. 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 to or affirmed before me this In day of May, 2006 by pet Joe Recarey, who is personally known to me. •," • Signature of Polict4fficert(F.S.S. 117.10) State of Florida ounty o eac Signatur "ng Officer Date: 05Y0112006 Page4of 22 EFTA00232968 Probable Cause Affidavit Palm Beach Police Department Agency OW 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, they disapproved of the encounters with him and she stopped. further stated that still tries to call house and leaves messages. Sgt Frick 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 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). dropped off at her house without incident. On October 3, 2005, Sgt Frick 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. Mrs. I 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, Mrs I was advised we would be speaking with her. She expressed 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 Jeffs 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 Frick and I thanked Mrs. I 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 Dawson and I drove to the home and met with and dob . During a sworn taped statement, stated approximately a year ago when she was seventeen years ol a house by stated she knows because they both attend High School. She was told she could make money working The foregoing instrument was sworn to or affirmed State of Florida before me this 1" day of May, 2006 by County of m Beach Det Joe Recarey, who is personally known to me. datete Signatur g Officer Signature of Police fficer .S.S. 117.10) Date: 05 1 i 06 Page. of 22 EFTA00232969 Probable Cause Affidavit Palm Beach Police Department Agency OFUN FLO 500600 Signature of Police .S.S. 117.10) for Jeff. She was told she would have to provide 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 kept her clothes on during the massage. She advised sometime during the massage, Epstein 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 massage. 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. 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 "r1 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. stated 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 to call her back reference the police questioning. 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 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 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 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 of age, took her to Epstein's house twice. She knows because they both atten ' 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 oraffirmerl before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. State of Florida County of Palm Beach Signatur g Officer Date: 05 06 Pageloof 22 EFTA00232970 Probable Cause Affidavit Palm Beach Police Department Agency ORD/ 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 massage he tried to remove her shirt, at which point she became very upset and discontinued the massage. Both and Epstein 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 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. 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 upset again and told Epstein she didn't want to be touched. In discontinued the massage and was paid $200.00. then went downstairs where was waiting for her. She told she wanted to leave. IN 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 m Beach. She was brought into the kitchen area of the house. She further stated that fellow 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 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 before me this 1" day of May, 2006 by County of Palm Bea h Det Joe Recarey, who is personally known to me. t#C e-e* Signature of Police OtficernS. 117.10) State of Florida Signature/ Date: 0510 Officer Page7 of 22 EFTA00232971 Probable Cause Affidavit Palm Beach Police Department Agency ORIM FLO 500600 table, straddling Epstein to massage his back. While doing this her buttocks were touching Epsteins. 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 massage table and turned it on. stated Epstein began rubbing the vibrator over her thong underwear on her vaginal area. 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 Dawson 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. Mrs I 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 O r igh School, what es of H and knew the same people. had been previously told by her friends from 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 driveway. They 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 exposing her belly area. During the massage, Epstein removed his towel and laid on the massage table naked. As. rubbed Epstein's chest 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-foregoinginstrument was sworn to or affirmed before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. 7ftet Signature of Police freer ( .S.S. 117.10) State of Florida County of ?aim Beach Signatu ng Officer Date: 0 '06 PageSof 22 EFTA00232972 Probable Cause Affidavit Palm Beach Police Department Agency O111# 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. I. then explained 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 . 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. IN 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. IN stated Ell knew that • had made money massaging Epstein 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 IM On October 6, 2005, at 11:45 am, I met with dob , at Lynn University 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 Jeff Epstein in Palm Beach. advised s taken to the Epstein house by whom she met when they both attended 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 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-iastniment was sworn to or affirmed State of Florida before me this 1" day of May, 2006 by County of Palm ac Det Joe Recarey, who is personally known to me. Signature of Police er-Officer ft.S.S. 117.10) Date: 05/0 06 Signature A Officer Page 'of 22 EFTA00232973 Probable Cause Affidavit Palm Beach Police Department Agency ORIff 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 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 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 about herself. Epstein knew she was a soccer player and would be attending Lynn University. 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 Orlando, 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 grabbed her buttocks and caressed the buttocks cheeks. 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 use the vibrator 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 Lynn University 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 Orlando 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 Dawson 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 11, 2005, w/f. dob was arrested by the Palm Beach Police Department -- The-foregoing-instrument-wat swore to ir affirmed before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. t•C ds* Signature of Police'Dfficer (F.S.S. 117.10) State of Florida County of Palm Beach Signat Date: ing Officer 2006 Pagel(bf 22 EFTA00232974 Probable Cause Affidavit Palm Beach Police Department Agency ORD/ 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 Dawson and I met with IN and obtained a sworn taped statement. MI 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 School classmate, said she was brought through the kitchen area where she met for the first time. rwas led to the master bedroom, Epstein s room. IN explained that as she was w g up the stairs she observed several photographs of naked women alon the walls and tables of the house. further explained that she was brought into the bedroom, where repared the room by setting up the massage table and provided the oils for her to rub on Epstein. exp ame 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 touched her breasts and began to masturbate. Epstein ejaculated which meant the mass 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 or ng er 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 massage his chest area. IN stated Epstein would then began to masturbate himself and at the same time would insert his fingers in her vagina and masturbate her with his fingers. IN explained Epstein would continue this process until he ejaculated. He would then utilize a vibrator/massager on her vagina until IN climaxed. 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. advised that thin s escalated within the home as Epstein would instruct and pay to have intercourse with his female friend, El explained the intercourse included using strap on dildos, large rubber penis' and other vices a pstein had at his disposal. Epstein would watch them have intercourse and masturbate himself . Occasionally, Epstein would then join in foregoing-instrument was sworn to or affirmed before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police leer ( S.S. 117.10) State of Florida Cou Signatur= Air tTT g Officer Date: 05/01/2006 Pagel) of 22 EFTA00232975 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 during the female on female intercourse and provide oral sex to both. and This occurred during the time. was sixteen years of age. advised this continued to escalate during two years. The routine became familiar to. Epstein's assistant ould telephone her every time Epstein was in the Town of Palm Beach and would place appointme or 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 with his penis. 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 naked and having sex and proudly display the photographs within the ho e. state unng one visit to Epstein's house in which she provided a masse e to E stein, his female friend, was also present. provided the massage in which and her would fon a eac o ers 'casts and kiss for Epstein to enjoy. Towards the end of this massage, Epstein grabbed. and turned her over onto her stomach on the massage table and forcibly inserted his penis into her vagina. • stated Epstein began to pump his penis in her vagina. became upset over this. She said her head was being held against the table forcibly, as he continued to pump inside her. 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 der a thousand dollars for that visit. stated she knows he still displays her photographs through out the house. On October 12, 2005, Det Dawson and I met with d b ho 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 E • stein. She stated she was brought to the Epstein house in March of 2005. a classmate at i 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 E stein. e 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 lost, Utiilatt -was - 9Wer -D4O-Or-affirni l d before me this day of May, 2006 by County of Palm B ch Det Joe Recarey, who is personally known to me. State of Florida Signature of Police Olficer(ES.S. 117.10) Signatu g Officer Date: 05/01/2006 Page'2of 22 EFTA00232976 Probable Cause Affidavit Pahn Beach Police 'Department Agency O1W FLO 500600 On November 6, 2005, at approximately 3:30 pm, I met with 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 tune, approximately two months ago. She was approached by a girl, 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 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 room so that could finish the maccage. 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 area. stated as she did this, 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 rubbed the vibrator on her vaginal area. advised he never penetrated her vagina with the vibrator. He continued to rub her 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 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 Sandman and I met with dob During a sworn taped statement, stated she met Jeffrey Epstein through when they were still The furcgoing-instrumentwas-swarn_to_or affirmed State of Florida before me this l m day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) County of P Im B ch Signatu Date: 0 I /2006 Officer Pagel3A 22 EFTA00232977 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 attending 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 approximately 4 or 5 times in the past year. She accompanied with 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 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,. 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 the Palm Beach Police Department. During a sworn taped statement, stated she had met stein approximately two years ago when she was first approached by a classmate at High School. approached her about working for Epstein and providing a massage to him for $200.00. _cobson 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 throughout the house. stated 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 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 large head. Epstein would rub the vibrator/massager on her vaginal area as he would masturbate. stated she had been to the house The foregoing instrument was o-or affirma before me this lg day of May, 2006 by Det Joe Recarey, who is personally known to me. 7 ,7e 0 Signature of Police fficer (F.S.S. 117.10) State of Finrida County of Palm B Signature/ Date: 05/01/2006 Page ttif22 EFTA00232978 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 brought two females d rovide massages. stated she brought a girl named ' and from High School. stated she received $200.00 for each girl she brought. On November 8, 2005, I met with W/F, 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 had asked her if she wanted to make money providing massages to Epstein. had heard that several girls from "gh School were doing this and 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 where a massage table was prepared and the proper oils were selected. 'Olen 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 provide a massage and things had escalated from just providing a massage. Epstein began touching her on her buttocks and grabbed her closer to him as he masturbated. Epstein also grabbed her breasts and fondled her breasts with his 'lands 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 penetrated her vagina with his penis and began having intercourse with her until he reached the point of climax. Epstein removed his penis from her vagina 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 d dl 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 kis e each other around the breasts and buttocks as they provided a massage to Epstein. Epstein, watched and masturbated as this occurred. On other occasions, Epstein, introduced the large white vibrator/massager in the massage. Epstein stroked the vibrator/massager on vagina as she provided the massage. On November 14, 2005, Det Sandman 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 High School known to her The foregoing instrument was sworn to or-affirmed State-of-F-lorld2 before me this 1" day of May, 2006 by County of Palm Beach Det Joe Recarey, who is personally known to me. t/ 1 Signature of Police fficer .S.S. 117.10) Signatu Date: 0 006 g Officer Page!Sof 22 EFTA00232979 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 provide a massage. stated it was not until the third lime 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 continued rubbing Epstein. Epstein turned over onto his back and she rubbed his chest area. 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. 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, Det. Sandman and I met with dob During a sworn taped statement,. stated she met Jeffrey • ago. She was sixteen years of age and was approached by a fello 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 Joe Recarey, who is.personally known to me. ,Ci*d Signature of Police Officer .S. S.117.10) Date: 05/0 /2006 State of F County of Palm B' ch Signatur' Officer to Page of 22 EFTA00232980 Probable Cause Affidavit Palm Beach Police Department Agency ORIe PLC) 500600 massage topless. 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 i 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 the massage, Epstein turned over onto his back and requested 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 rubbed Epstein's chest.. 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 so 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 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 to provide another massage.. 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 by 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 massaging his legs and back. As. finished with Epstein's back and legs, Epstein then turned over onto his back.. started to rub his chest and he began masturbating. As 16rubbed 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 continued to rub his chest as this was occurring. She described the vibrator/massager as large grey with a large head. Epstein rubbed her vagina for approximately two to three minutes with the massager/vibrator. He then removed the vibrator from her vaginal area and concentrated on masturbating himself.. stated Epstein climaxed onto the towel again and informed her that the massage was done. igot dressed and met with who. was waiting in the kitchen area. She received $200.00 for the massage.l 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 High School. The foregoing instrument was sworn to or affirm-6d before me this 1" day of May, 2006 by Det Joe Recarey, who is personalty known to me. Signature a of Police ftfficer .S.S. 117.10) Slatrof Florida County of Palm B Signatur g Officer Date: 0 006 Page of 22 EFTA00232981 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 During the course of the investigation a search warrant was executed at Jeffrey Epstein's home located at 358 El Brill° 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 tak who signed the bottom of the messages. During the execution of the warrant, I located a igh 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. Dawson and I met with. dob During a sworn taped statement, l istated 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 so that. may The foregoing instrument was sworn to o lined before me this In day of May, 2006 by Det Joe Recarey, who is personally known to me. et_fora Signature of Police flicer (F.S.S. 117.10) State of Florida County of Palm Be Signature"' Officer Date: 05 Is Page of 22 EFTA00232982 Probable Cause Affidavit Palm Beach Police Department Agency ORI# 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 be an to rub is chest, Epstein asked her questions about herself . remembered telling him she attended 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 things. She continued rubbing his chest. Epstein reached up and unsnapped her bra from the front.. explained the bra she used had a front snapping device. Epstein rubbed her breasts and asked her if she like having her breasts rubbed. asaid "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 touched her breasts.. 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 stroking her clitoris.. said, "He commented how hard my clit was." He then inserted two fingers in her vagina and was stroking her within her vagina. She tried pulling back to pull out his fingers from within her 'agina. Epstein removed his fingers from within her vagina and apologized for putting his fingers inside her. During this time, he kept his hand on her vaginal area and continued to rub her vagina.. stated he rubbed 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. 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 I. 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,. dol . 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 Ugh 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 Det Joe Recarey, who is personally known to me. 2.C2, Signature of Police Officer (F.S.S. 117.10) State of Florida County of Palm Beach Signatur Ricer Date: 1)5 Pageltof 22 EFTA00232983 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 to model lingerie for a wealthy Palm Beadier. 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 that they were going to provide a massage on Epstein.. 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. 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 nipples. stated that as she started rubbing his chest, Epstein began masturbating himself . Epstein touched her breasts and stroked her vagina with his fingers. Epstein continued to masturbate himself as he stroked her vagina. Epstein ejaculated on his towel and paid. $200.00 for the massage. 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 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 rubbed her vagina with his fingers. Epstein began to masturbate himself with an upwards and iownward motion on his penis. Epstein continued to touch her vagina 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 get comfortable. The females would then provide the massage naked as Epstein would either touch their vaginas with his forgers and/or utilize the massager/vibrator on e toregotng In before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. e rl ie04 Signature of Police ‘Ticer(F.S.S. 117.10) Stott. of Florida County of Palm Bea Signature/ Date: 05/0 Page2gif 22 EFTA00232984 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 their vaginal area. 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. appeared young in age. Rodriguez stated the girls that would come appe He stated one time under Epstein's direction, he delivered a dozen roses to High School for one of the girls that came to provide a massage. He knew the girls were sb sc 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 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 to be masseuses. The foregoatins rumen before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. State of Florida County of Palm Be h Signature/A Officer Signature of Police ffice (F.S.S. 117.10) Date: 05/0 PageZrof 22 EFTA00232985 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 w ments, and a note with Mr. Epstein's stationary with direction to deliver a bucket of roses to igh School after le high school drama performance. Also in that same note was direction to rent a car fore 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. Specifically, The phone records showed called during the exact times and dates when victim le advised the incident occurred. also coordinated the encounters with 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. Therefore, as Jeffrey Epstein, who at the time of these incidents was fifty one years of age, did have vaginal intercourse either with his penis or digitally within le 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 ofe 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 affirowc1----------State of Florids before me this 1" day of May, 2006 by County f Palm Beach Det Joe Recarey, who is personally known to me. Signature of ir71 Poli e Offic r (F.S.S. 117.10) Signature/ Date: 05/ fficer Page24f 22 EFTA00232986 REQUEST FOR WARRANT DEFENDANT: DATE OF BIRTH ciABITUAL OFFENDER YES NO A/K/A VICTIM RELATED / ACQUAINTED WITH DEFENDANT? YES AGENCY CASE NUMBER: 05.368 (21 LEAD OFFICER: Det. Joe Recaetv AGENCY: PALM BEACH POLICE DEPARTMENT CURRENT SHIFT HOURS: 8 am TO 5 Dm XX 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: USING DOCUMENTS ATTACHED: X ARREST FORM 1r P.C. AFFIDAVIT (2 COPIES) X WITNESS / EVIDENCE LIST 9easkynkl &v lb Was east4tmat SWORN STATEMENT OF MATERIAL WITNESS(ES) X. OFFENSE REPORT (2 COPIES) ACCIDENT REPORTS (ALL) WITNESS STATEMENTS (ALL) fiC Scra IC/NCIC CRIMINAL HISTORY9taas.1141/ 4/$01% esadAmtele— QUEST FOR CONVICTION LETTERS Y. PROPERTY REIC P2TaCUSL/ VEHICLE TOW IPT "ID ASA ot.a...jet OTHER ATTACHMENTS INCLUDE: INITIAL FOR COMPLETENESS: JR 7915 ID* 050106 an EFTA00232987 ARREST / NOTICE TO APPEAR i _L i o i 1 Juvenile Referral Report 1.000:11 0RI t&Sit ao.5 1 0 1 0,6i0 A 0 PALM BEACH POLICE DEPARTMENT hem Noe OBIS ALimber Chira Ternany 5 My a Law of MeV (hCludIng Named Busnals) 3 .•O1. ROM `0 2. Nato FturraY 0 3. 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I Date o' Date or Hrr U1. Amelia OE Al Large 1. Annan 2. At Large 1 3 Fecony 4. Madmen t Mi Fog 4 meo . . y MoOmneanor 5. Ant U. z 8 Dag Activity ICIng Typo .: Amount / unt 2 Parent Name (Lam) Le Custodian ots. AdOsiss Ogees Am. Number) (Fat) (Mode Reggerce Phone ( ) Ellniegla Phone ( ) rtaNi (242 TOT SAC On Time TM More Selma was proNtled by 0 Oelertard ant! or Ocksterstags omens The Mid arc or print was tokl in keep me ,kryeete coon GM 'S Olha (Phone 355•2526) Memel of any Menge ol actin Y. by!Bin) 0 Nts fReesenk &McGinn? n j Descriplion at Properly 0 Yes 0 No Drug ArmIty . I H. Smug). K. asperse/ IA Menufacrwor Z Other a But D Deaver Cfairibule Pratte P Possess T Tram E Um School Mantled Gm% Anthetornne Wilim of Property e . Coc riatloiril Notole Stsluonoger M Marara O. Cp...ssiDerw r rapnerrara, J. Unknown tmornern 2 GINO, S 1111)1C Commit Nowa _13 Y Mein* 71tsje t). Statute Moloch Number A 2.11 • 1_ Warmed /Copts Number [if I I Motaton of ORD • l ead Osarger Descripbon Chat USN (.3 Sae A1113041 / Una Manse I Gaut I Cionamte &l WNW Number ` l_•. , I W /Capes Numb IL Wean Number Stature Yblacn Hunter I LI Warrant / Cmas camber Mciafan of ORD o I Outgo DeSOlpign Carne Dore %Nonce OY ON III Vldalon of ORD/ Drug Type Amount/ Um atom Boob omicie amatation coos Derma EA N Slawie Violako Hunter Ylotaton of ORD, Drug MASAN orva Ts* Amour.: un Plena Wane lemmas Narrow 0 Instruction No. 1 Mamiatory Mama n Coati O Insbunich No. 2 You neat not appear in Court but mum roast with instructions on Femme S.M. Localton (Can Room Nunter. Abberml Coon DM mg Time Month Day You Thee AM. PIA O - ----14•GREB-TGAPPEST414E-TIME PLAGES.E9113NATC-D-TerneWeRTP1BOPPMSECHAIKIBDOR TO PAY TIC FINE SUBSCRIBED TLINuov. ;AMU MAT SHOIAD URALS' FAL TO 1/J APPEAR BEFORE THE COURT AS RECAARED BY Tss.5 NOME TO APPEAR, THAT I MAY BE HELD IN CONTEMPT OF COURT MD A WARRANT FOR WARMEST SMALL BE ISSUED. 0 Sunup.; al Defendant ler Juvenile and Parent / Omlodlori) Dab, Synod HOLD ler ghee Agency ••• Scrotum of Mm011it Paw / X Name of ArresDng Cmcm (Ent* g anogrott O Resisted Ants: a c)Suital 0 Other Intake Oaculy Poucn NaNSCOONS 011t0EY L0.1 JO. berme Nome Venecalion IFYinted by Arrealim) p. (PRIM) WIDNISS here a 4401:00 slow NB an IC. PAGE OF DISTRIBUTION. WHITE — COURT COPY GREEN — STATE ATTORNEY YELLOW — AGENCY PIM( — JAR. GOLD- DEFENDANT (1STAS ONLY) EFTA00232988 w OiITS Number I - I I nay OM Numbs re FLO, 5 L 0 0 i 6 L 0 1 O re. DI. FOOny aarny •2 , goy D t Tine %hay Ltaton DI Ma (nOuding Name Of Banal) 0 I I 1 PALM BEACH POLICE DEPARTMENT Agency Name Irtiarneanor 0 5, °nano! CI 4. WaRC IMOOMIlosOr O & Other ARREST I NOTICE TO APPEAR I Ana 3 Rant le Warfare Juvenile Referral Report 2 N T A 4 Rang opt Ceps ben Maçon NW*" (N.T.A's prey) 7 1 6 ' 1 1-1 t_ 1(1 Il Weapon Sean Ewer Two Linen a Canes (Busmen Name. AtillaSS) Mae Clean non I are of Attest Time 0iAm« Booking Date Bookeg Tars Jed Dee ail Time Loa bon a Venn Name (Last. Fat NOW) Alas Nana. DOB. Soc. Seca. RIC I Race W • Who I • Amarcan Inclarry B • Mack O - Overeat/Asian Scare. Mara Tar.00s Un'Qua PRYNCRI Faint (Locae. Type. Den0a) Set Oiled fletn Neon I I I I _I_ Eye Cow Hat Calot Conine rkmd Man Status Rene nine Anol Mann GIGWan Rumen Type: I City 3. Mot* 2 COunN 4 OA °ISIS Poses. Source Local MAIMS (Sae. *pi human 3 u. tar %melee ihabefa lalreel. A#1 nkJrneen (Coy) (Slate) (City) (Suite) (Zip) Rio I Phone ) Phone &Minas Andress (Name. &tee (City) (Slate) (Zip) Prone ) Occupaoon at Number. Stale Soc Sa tame INS Number Rota of Ama(O*, Slate) Crmenere CO-OWNXIant Name (LIN. Feu Min) Ra Sex Dee of Ben U I 02 MAiLaenarge 3. FelCaf 4 IMperreanor Co-tlerenciani Name item NIL Modal Pee Sex Dale or BM t. Men 2. AI Large A Maerrieence S. Jwersle pi Parent Cascolien Name (Lash (Flail (*0001 Amass (Greet. Aix Number) TOT JAC Km) z TM Mow ants wat pea by CI cielenciam trol /or O alma«, parents. Theca:1P ano /or pareM was UP es la Jaen» Carl Gen On (Prone 355-2528).Monhaa any ere* 04 «men a by: (an) O No: (Reason) PrOpatly Carnet . O Ws CI No Drtig Mtn S.Srm PL WA P. Pane ?..Terifre Large Description Defence ol Properly IA Stage It Una& D. Delver Dan E. Us IA Winutaaurie 2. laar Pincer CULDF. Care Dona nonce OY ON (Slate) (Zip) L v.,.a Properly SchoolMeted la Imo Rena* Pane ( Grea Drug Type rate II welanopen P RaratemnaM/ U. Unknown N Cocaine LI Manna Ennioni Z Caw k Amerman» I Finn O OputWDenv S min Stan WONINI Norte a 1.1 e Waal Capes number ?._ Vence ol ORD 0 Drug hasty Cevg Type Amount UNI Carle a Sue CUSP Doemehn Drug Panty Drug Type Amount / Uril Olen. Gaunt, 0010•40C N Sian Vora Hurts l i lt I l l 1(1 I 1 I I) Warring /Clan MAR. SUN. WaltiOn WOW I I 6I 1 t I 1(1 I I I I) Warrant 'Capes Motor Swum Vane lute a e 1.1 e e Warrant temples Newts Vasco a ORD Chum Desonpiren Drug Activity Ong Type Amount Urn Onerse Connu OeffaSIC \faience Or ON *Yon ol ORD Charge Descepan Drug Aawy Drug Type Amaun: I J^a Cane # L Counts Ooerrmat mt th Y ON 1(1 1 I 1 Memo, a ORD • Bono Insireac No I Maneatay Mataramo n Court O ineiructece No. 2 You no roi appal in CONTI WO met comply WU insucz as on Rasta So. I AGREE TO APPEATteME AND PLACE DESGNATED TOA1JSWER THE OFFENSE CHARGED OR TO PAY The Ire SuBSCMIBE C I UNDERSTAND THAT SHOULD WILLFULLY FAIL TO APPEAR BEFORE AS REWIRED BY TM* NOME TO APPEAR nit I MAY BE HELD IN CONTEMPT OF COURT AND A WARRANT FOR MY ARREST SHALL BE ISSUED. tram (Coon. Room Watt/ Addrem) Coon Dale and Tyne Day Year Time AM Pu Steno a Delendant Juvenile vo Pan /Cuseelani oime Signed HOLD IX aner Agency e: Signature ce Arresting °Mar • U Dangerous O Rasta Mtn a o Suaaa O Ghee Imahe Deputy 10. # Poudi NW* olNreSting One (Ple) Transporter; Oka LO. ID # Agency Name Menton (Prated by Anent (PAINT) WanesS here ol SeejeCI urea wan 4r 'X' PAGE OF DISTMEuTiON. wwiTE ccuRT COPY GREEN — &TATE ATTOEWEY YELLOW — AGENCY Peer — JAIL GOLD DEFENDANT (t1 T A I ONLY) EFTA00232989 Probable Cause Affidavit Palm Beach Police Department Agency ORI# 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 In 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, 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 to perform massages for Ep tei 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, Epstein would rub his fingers on their vaginas. On occasion, Epstein would introduce a massager/vibrator and rub the victims vaginas 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. IN 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 though a photo line up. During a sworn taped interview stated that dob a cousin of boyfriend and classmate at 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. IN stated that along with a Hispanic female, later identified at pick her up at her father's house on a Sunday. IN 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 Signature of Police Officer (F.S.S. 117.10) The foregoing instrument was sworn to or affirmed trefot c me this 1n day of May, 2006 by Det Joe Recarey, who is personally known to me. State of Florida y of Palm Dvat, Signs 7. r esting Officer Date: 0 01/2006 Page I of 22 EFTA00232990 Probable Cause Affidavit Palm Beach Police Department `gent",O1U# FLO 500600 conversation occurred between and E whereas reportedly told IS that if Jeff asked her age, 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. NI 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 SI stated that they walked up a drivewa 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. IS 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 Sarah Kellen, entered the kitchen. Epstein introduced himself to IS • described Epstein as being approximately forty-five years old, having a long face and bushy eyebrows, with graying hair. and Epstein left the kitchen leavings alone in the kitchen. They returned a short time later. They all spoke briefly in the kitchen. IS was instructed to follow Kellen upstairs. IS 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. IS recalled there being a mural of a naked woman in the room, as well as several photographs of naked women on a shelf. Kellen 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. IS stated Epstein was stern 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 so she took off her shirt leaving her bra on. Epstein had removed his towel and told the IS to take off everything. U stated Epstein was nude when he took his towel off, placing it on the floor as he laid down on the table. U 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 U began to give Epstein the massage, he told her to get on his back. U stated she straddled herself on Epstein's back whereby her exposed buttocks were touching Epstein's bare buttocks. IS 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 U to massage his chest. U was now standing on the ground and resumed massaging Epstein's chest area. IS 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 I' day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police °Aker (F:S.S. 117.10) State of Florida County of Palm Beach Signat ting Officer Date: /2006 Page 2of 22 EFTA00232991 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 massage vaginal area.. stated there was no penetration as the vibrator was on top of her underwear. • recalled Epstein ejaculating because he had to use the towel to wipe himself as he got 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._ 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 IS to assist with the investigation. At our direction S conducted controlled taped phone calls to cellular telephone 561- S spoke with in an attempt to arrange another meeting with Epstein. IS 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 s and left a voice mail message for her indicating that she had set up an appointment 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 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 Frick and I went to residence and viewed her vehicle parked in the driveway, a red Dodge Neon. Sgt. Frick 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 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 before me this 1" day of May; 2006—hy Det Joe Recarey, who is personally known to me. State of Florida unty of Pat t each Signat ng Officer Signature of Police .S. 117.10) Date: • /2006 Page3of 22 EFTA00232992 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 wasaduced to Epstein in the kitchen of the house. She was also introduced to a white fe e own to her as . She was led upstairs to the main bedroom known to her as Jeff Epstein's bedroom. arranged the massage table altered 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 grabbed her buttocks 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 brought to see Epstein, each time she was paid $200. stated she had brought the following girls: II ( al6 year old female), (a 16 year old female) and said that at the time she brought these girls to Epstein's house they were al114 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 In at her house. stated that at that time she was driving a red pickup truck. They traveled ein's house and entered through the kitchen door. They met with the e chef and Epstein's assistant. was introduced to Epstein while they were in the kitchen area. i 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 t 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 Signature of Police S.S. 117.10) 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 me. State of Florida unty of, at eac Signatu ting Officer Date: 0 i 1/2006 Page 34/1of 22 EFTA00232993 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 when he was going to travel tol 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 w visiting Epstein, they disapproved of the encounters with him and she stopped. further stated that still tries to call house and leaves messages. Sgt Frick 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 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). dropped off at her house without incident. On October 3, 2005, Sgt Frick 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. Mrs. 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, Mrs. was advised we would be speaking with her. She expressed 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 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 Frick and I thanked Mrs. I 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 Dawson and I drove to the home and met with and 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 berAnse they both attend High School. She was told she could make money working The foregoing instrument was sworn to or affirmed State of Florida before me this 1" day of May, 2006 by County P m Beach Det Joe Recarey, who is personally known to me. Signat sting Officer Signature of PoliceOfficer .S.S. 117.10) Date: i i 1/2006 Page 5of 22 EFTA00232994 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 for Jeff. She was told she would have to provide 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 ' en. was introduced to M, 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 kept her clothes on during the massage. She advised sometime during the massage, Epstein 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 massage. 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. 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 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. 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 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 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 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 le day of May, 20U6 by County of Pal Beach Det Joe Recarey, who is personally known to me. Signature of ?(Folic I Office tet (F.S.S. 117.10) State of Florida Signatur l ing Officer Date: 05 i /2006 Page &of 22 EFTA00232995 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 and Epstein had a verbal disagreement, at which time she left without being paid. She got with who was sifting 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 you do the more you get paid. II 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 E 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 upset again and told Epstein she didn't want to be touched. discontinued the massage and was paid $200.00. E then went downstairs where was waiting for her. She told she wanted to leave. said she never returned to the house. IE 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. Duri taped statement, stated the following: on or about November 2004, she was approached at n a sworn nigh 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 High School students. and (= came with them. They were brought into the kitchen where she was introduced to Epstein and other females. stated the 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 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-131-day of May, 2006 by Det Joe Recarey, who is personally known to me. State of Florida auto ILU Citl. I Signatur tmg Officer Signature of PolicCOmier (F.S.S. 117.10) Date: 05 006 Pagel of 22 EFTA00232996 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 table, straddling Epstein to massage his back. While doing this her buttocks were touching Epsteins. 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 massage table and turned it on. stated Epstein began rubbing the vibrator over her thong underwear on her vaginal area. 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 Dawson and I met with dob at her residence. As El 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. 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 fa associates of and knew the same people. had been previously told by her friends from Weigh School, what did d the appointment. picked up and drove her to Palm Beach to a street called `Grillo 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 Epstein. was introduced to Jeff Epstein. led IN upstairs to the main bedroom area and set up the room with a massage table and set out the oils. IN 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 exposing her belly area. During the massage, Epstein removed his towel and laid on the massage table naked. As IN rubbed Epstein's chest 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, 2006 by County of Pal Beach Det Joe Recarey, who is personally known to me. State of Florida C •P- 01 9 Signature of Policebfficer(F.S.S. 117.10) Signatur f ,e ting Officer Date: 05//006 Page Sof 22 EFTA00232997 Probable Cause Affidavit Palm Beach Police Department Agency ORM 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 explained 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 I. 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 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.. 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 Epstein and wanted to make money herself took them in the kitchen area of the house and introduced. to i r. and took. upstairs to the main bedroom. • advised she doesn't know what happened as did not speak about what happened in the room. I. received $100.00 from for going with her to Epstein's house and recommending. On October 6, 2005, at 11:45 am, I met with dob at Lynn University 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 Jeff Epstein in Palm Beach. advised she originally had been taken to the Epstein house by whom she met when they both attended 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 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 1" day of May, 2006 by Det Joe Recarey, who is personally known to me. State of Flo 'da Coun Signatur csting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Pagel of 22 EFTA00232998 Probable Cause Affidavit Palm Beach Police Department Agency ORM 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 Epstein would try to touch her more and on one occasion he attem ted 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 about herself. Epstein knew she was a soccer player and would be attending Lynn University. 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 Orlando, 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 grabbed her buttocks and caressed the buttocks cheeks. 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 use the vibrator 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 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 Lynn University Gym field. I asked ' y one to the house. explained she took a friend of hers who attended High School, who has relocated to Orlando 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 Dawson 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 11, 2005, w/f. 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 Joe Recarey, who is personally known to me. K/fee.# Signature of Police Officer (F.S.S. 117.10) State of Florida County of Pa each Signatur ting Officer Date: 05 /2006 Page lOof 22 EFTA00232999 Signature of Police Officer (F.S.S. 117.10) 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 Dawson and I met with. and obtained a sworn taped statement. I.I 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 tunes.. stated her first visit she was brought to the house by fellow • " ber one girl." She explained that on hool classmate, . said she was brought through the kitchen area where she me for the first time. was led to the master bedroom, Epstein s room.. explained that as she w w mg up the stairs she observed several photographs of naked women alit. walls and tables of the house. I. 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 touched her breasts and began to masturbate. Epstein ejaculated which meant the mass 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 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 massage his chest area. stated Epstein would then began to masturbate himself and at the same time would insert his fingers in her vagina and masturbate her with his fingers. explained Epstein would continue this process until he ejaculated. He would then utilize a vibrator/massager on her vagina until climaxed. 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. adVised that thi s escalated within the home as Epstein would instruct and pay. to have intercourse with his female friend, explained the intercourse included using strap on dildos, large rubber penis' and other evices a pstein had at his disposal. Epstein would watch them have intercourse and masturbate himself . Occasionally, Epstein would then join in The foregoing instrument was sworn to or affirmed State of Florida .forego this 1" day of May,2806 by Det Joe Recarey, who is personally known to me. County ofPalntJBeach Signature is ng Officer Date: 05/ 006 Pagel, of 22 EFTA00233000 Probable Cause Affidavit Palm Beach Police Department Agency ORIP FLO 500600 during the female on female intercourse and provide oral sex to both • an This during the time. was sixteen years of age. advised 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. consented to perform all these acts but was adamant that there was an understanding with Epstein that no vaginal penetration would occur with his penis. 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." MI stated Epstein would photograph d her naked and having sex and proudly display the photographs within the home. state uring one visit to Epstein's house in which she provided a massy e to E stein his female friend was also present. provided the massage in whic d her would fondle each others breasts and kiss for Epstein to enjoy. Towards the end of this massage, pstein grabbed. and turned her over onto her stomach on the massage table and forcibly inserted his penis into her vagina. stated Epstein began to pump his penis in her vagina. became upset over this. She said her head was being held against the table forcibly, as he continued to pump inside her. 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 provided a massage to E stein. She stated she was brought to the Epstein house in March of 2005. a classmate at 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 massages, stated she provided a massage, fully clothed for 5200.00 . 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 'IMI 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 affirmed before me this 1" day of May, 2006 by On Joe Recarey, who is personally known to me. Signature of Police Ricer .S.S. 117.10) State of Florida County of Palm each Signature/ g Officer Date: 05/01 i06 Page I34 22 EFTA00233001 sworn taped statement, stated she met Jeffrey Epstein through Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 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 girl, 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 upstaiL 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 room 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 area stated as she did this, 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 rubbed the vibrator on her vaginal area. advised he never penetrated her vagina with the vibrator. He continued to nib her 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 had on previously and went into the shower area got dressed and met with the massage. was told to leave her telephone number with $200.00 for bringing and $200.00 to for providing in the kitchen area. Epstein came into the kitchen and provided for future contact. provided her cellular telephone number. was asked if she was recently contacted about this investigation by antysfrom 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 Sandman and I met with dot . During a when they were still The foregoing instrument was sworn to or affirmed before-me-thisr—day-of Mayr Det Joe Recarey, who is personally known to me. c Klie# Signature of Police Officer (F.S.S. 117.10) State of Florida Signatu ing Officer Date: 05/01/2006 Page oaf 22 EFTA00233002 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 attending 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 approximately 4 or 5 times in the past year. She accompanied with PS 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 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, • 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 approximately two years ago when she was first approached by • a classmate at 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 ements were made. had take also attend High School and was familiar with Epstein. recalled she was brow t there and enter e ack 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. stated 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 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 large head. Epstein would rub the vibrator/massager on her vaginal area 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 County of Pal Beach Det Joe Recarey, who is personally known to me. State of Florida Signature of Police officer (F.S.S. 117.10) Signatu ting Officer Date: 05 i /2006 Page/I/of 22 EFTA00233003 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 brought two females d .• ovide massarcs from stated she brought a girl named = and 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 had asked her if she wanted to make money providing massages to Epstein. had heard that several girls from High School were doing this and 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 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 provide a massage and things had escalated from just providing a massage. Epstein began touching her on her buttocks and grabbed her closer to him as he masturbated. Epstein also grabbed her breasts and fondled her breasts 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 penetrated her vagina with his penis and began having intercourse with her until he reached the point of climax. Epstein removed his penis from her vagina and climaxed onto the massage table. received $350.00 for her massage. I asked her if she had any formal training in providing massa es stated she did continued to state on one other occasion, Epstein introduced his girlfrien into the massage. was brought into room with to provide a massage. Epstein had them kiss and fondle each other aroun the breasts and buttocks as they provided a massage to Epstein. Epstein, watched and masturbated as this occurred. On other occasions, Epstein, introduced the large white vibrator/massager in the massage. Epstein stroked the vibrator/massager on vagina as she provided the massage. On November 14, 2005, Det Sandman and I met with doll 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 sixtee e first went to Epstein's house. On her first visit she was brought by a fellow student from High School known to her The foregoing instrument was sworn to or affirmed State of Florida betore me this 1" day of May, 2006 by County of Pal Beach Det Joe Recarey, who is personally known to me. Signature of Folic Officer (F.S.S. 117.10)- Signatur ting Officer Date: 0 006 Page f V22 EFTA00233004 Probable Cause Affidavit Palm Beach Police Department Agency ORI# 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 provide 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 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 continued rubbing Epstein. Epstein turned over onto his back and she rubbed his chest area. 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. 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, Det. Sandman and I met with dob During a sworn taped statement,. stated she met Jeffrey E stein over a ear ago. She was sixteen years of age and was approached by a fellow 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 Joe Recarey, who is personally known to me. Signature of Pol e Officer (F.S.S. 117.10) State of Florida County of Palm each Signature/ 'ng Officer Date: 05/0 i 06 PagetLof 22 EFTA00233005 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 massage topless. 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 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 the massage, Epstein turned over onto his back and requested 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 rubbed Epstein's chest. 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 so 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 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 to provide another massage.. 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 by 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 massaging his legs and back. As finished with Epstein's back and legs, Epstein then turned over onto his back. started to rub his chest and he began masturbating. As. 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 continued to rub his chest as this was occurring. She described the vibrator/massager as large grey with a large head. Epstein rubbed her vagina for approximately two to three minutes with the massager/vibrator. He then removed the vibrator from her vaginal area 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 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 High School. 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 me. e,7 eat Signature of Poli Office (F.S.S. 117.10) State of Florida County of Pal Beach Signature ing Officer Date: 05/ 006 Pagerff 22 EFTA00233006 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 tak who signed the bottom of the messages. During the execution of the warrant, I located a 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. Dawson and I met with. dot . During a sworn taped statement, I I 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, MI 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. I. 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 1" day of May, 2006 by County of Pal i Beach Det Joe Recarey, who is personally known to me. State of Florida Signature of ?(- Folic 71Office (F.S.S. 9 117.10) Signatur Ling Officer Date: 0 011 106 Pagetaif 22 EFTA00233007 Probable Cause Affidavit Palm Beach Police Department PC 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 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 be an to mb his chest, Epstein asked her questions about herself. remembered telling him she attended igh 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 things. She continued rubbing his chest. Epstein reached up and unsnapped her bra from the front. • explained the bra she used had a front snapping device. Epstein rubbed her breasts and asked her if she like having her breasts rubbed. 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 touched her breasts. Mexplained 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. Mistated 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 stroking her clitoris. said, "He commented how hard my clit was." He then inserted two fingers in her vagina and was stroking her within her vagina. She tried pulling back to pull out his forgers from within her vagina. Epstein removed his fingers from within her vagina and apologized for putting his fingers inside her. During this time, he kept his hand on her vaginal area and continued to rub her vagina.. stated he rubbed her really hard as he was masturbating. 1.1said 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,. do'. 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 High School, to be taken to Jeffrey Epstein's house to work. She was origin y to s e wou be able The foregoing instrument was sworn to or affirmed before me this lm day of May, 2006 by Det Joe Recarey, who is personally known to me. eCi Signature/ g Officer Signature of Pollee Offic (F.S.S. 117.10) Date: 05/0 06 State of Florida County of Palm each Pageoof 22 EFTA00233008 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 5004500 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 personal chef prepare dinner for U 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. explained to U 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 E to rub his chest and rub his nipples. stated that as she started rubbing his chest, Epstein began masturbating himself . Epstein touched her breasts and stroked her vagina with his fingers. Epstein continued to masturbate himself as he stroked her vagina. Epstein ejaculated on his towel and paid • $200.00 for the massage. 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 U 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 rubbed her vagina with his fingers. Epstein began to masturbate himself with an upwards and downward motion on his penis. Epstein continued to touch her vagina 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 MI=, 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 get comfortable. The females would then provide the massage naked as Epstein would either touch their vaginas with his fingers and/or utilize the massager/vibrator on The foregoing instrument was sworn to or affirmed State of Florida before me this Pt day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Folic Officer (F .S. 117.10) County 2.aim 3C Date: 05/01/ Signature/Ar Officer Pagscpf 22 Officer EFTA00233009 Probable Cause Affidavit • Palm Beach Police Department Agency ORIN FLO 500600 their vaginal area. 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 though 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 ap to be masseuses. He stated one time under Epstein's direction, he delivered a dozen roses to 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 Joe Recarey, who is personally known to me. ? r as,/ State of Florida Signature of Poll Office r (F.S.S. 117.10) Date: 05/01 County i I ra III IS SCR Signature/ rr g Officer Page21of 22 EFTA00233010 Probable Cause Affidavit Palm Beach Police Department Agency ORM 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 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. Specifically, The phone records showed called during the exact times and dates when victim advised the incident occurred. also coordinated the encounters with.. 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 Epstein, who at the time of these incidents was fifty one years of age, did have vaginal intercourse either with his penis or digitally with... 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 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 1' day of May, 2006 by County Palm Beach Det Joe Recarey, who is personally known to me. State of Florida Signature of /Can Poli e Offic (F.S.S. 11'7.10) Signature/ Date: 05/0 rig Officer Page2zof 22 EFTA00233011 REQUEST FOR WARRANT nEFENDANT: DATE OF BIRTH HABITUAL OFFENDER: YES NO AfIC/A VICTIM RELATED/ACQUAINTED WITH DEFENDANT? YES XX AGENCY CASE NUMBER: 05-368 C3) LEAD OFFICER: Det. Joe Recarev AGENCY: PALM BEACH POLICE DEPARTMENT CURRENT SHIFT HOURS: Sam TO 5 am PHONE NUMBER NO 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: ?ILING DOCUMENTS ATTACHED: ARREST FORM P.C. AFFIDAVIT (2 COPIES) WITNESS EVIDENCE LIST P2e4itust4 a 1a A{d Tba.o4Iffrint.. SWORN STATEMENT OF MATERIAL WITNESS(ES) Y s. OFFENSE REPORT (2 COPIES) ACCIDENT REPORTS (ALL) STATEMENTS (ALL) FeigagCRir AL HISTORYav hie tic04)47 Gmt 6 tectf ar￾ItSQUBST FOR CONVICTION LETTERS PROPERR REZPTikatitalitt sitert VEHICLE TOW RECcEIPTIAnC￾OTHER ATTACHMENTS INCLUDE: JR INITIAL FOR COMPLETENESS: 0171Cal 7915 DELIVERED BY: DETICTIVI RECEIVED MAY RECEIVED, STATE A O 'S OFFICE ON: 3 N TAKE ID/ Ok BY: 050106 DAR EFTA00233012 COTS Nolo Amer:le • Away OM Nutty t i t l e PONY Nana FLOISI 0 t C/ a6t01_ 0_I PALM BEACH POLICE DEPARTMENT ARREST 1 NOTICE TO APPEAR Amodio Referral Report I MOO 2 Roues( Mr Warrant 2 N T A a Flouesisor Cana Arienes Report Nonce IN TA's only. 7 1 6 0 'WA Felony Oa messamsn o a Ordfierca 01 Dale Fakery 0 4. Wale Illedemearot Oa 00w Location cit Arno (IncloMe2 NOW of asaalso l t weaPon SO000 Eno Toe I LocatOn aI Memo (Biomes Nene. ADIretal • t OLT Clearance I) Goa of moo T"-of Anew Bo.NnpOw Bookew Tione I s a r Name (last. Rat MOS Rao W Mee I . 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Acidteso Coun Dale and Toe orb ak Day Tar Da* • 14 0 —1-1MGREtTOAPPEAtEATIME AND PLACE DESIGNATED TO ANSWER THE OFFENSE CHARGED OR TO PAY THE FOE SUI3SCRIBED. I UNDERSTAND TOT SHOULD I WILLFULLY Ma TO g REBFORE APPEARS T WIRED BY THIS NOME TO APPEAR. THAT I IMO BE HELD IN CONTEMPT OF COURT AND AWARRANT FOR LW ARREST SHALL BE ISSUED. 2 Sonora or Delendanf (cr Juvenile and Parent /CORSO Dee sons HOLD for Ow Nancy Sirsto• OA/ovum Celefir X NOM at Pilleang OtIOIr (POI* ' lopertuS n Restos] Attest a o SKIS, 0 Other • IDIT Nine Veriecoon (Prow Weneele0 'Mika GOO P.O. e I Pouch Toneconivu Chow 1.0. 1 Da n wrtw here Imbaxt Oared wen an X. PAGE CC DGTRIBUTION: SWOT( — COURT CODY GREEN — STATE ATTORNEY YELLOW — AGENCY RN(— JAIL COLD - OEFENDANT (N.T.As ONLY) EFTA00233013 OBTS NumW I i 1 1 _I _ ARREST! 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Bo's, .. 3 Maruction No.1 Mandatory Appemance m Can 0 Intettibb a. 2 Locaon (Court Room Renter AWNS) i You wog not Wear In Can but must eranmay with kistruebOnt MI Menus Son Cal Date and Time AbMh Day Year Tow 0 - — --RS __. I OGREE112 APPENTATTFWITUE AM-PUCE DESIGNATED TO AN N'EII THE OFFENSE CHARGED OR TO PAY THE FINE SUBSCRIBED I UNDERSTAND THAT SP4OULD I WILLISALY FAIL TO APPEAR BEFORE THE COURT AS REQUIRED BY THIS NOTICE TO APPEAR. THAT I MAY BE HELD IN CONTEMPT OF COURT AND A WARRANT FOR MY ARREST SHALL BE ISSUED. 2 Sign re ol Deferden: (cc WNW* at Parent / Otalen) Date SOW HOLD It, other Agency ' "V: Scalar. OlArreseng War X Name %imitation IlInmoi aY Annie, / a AWNS 0 Realeted Arrest (PRINT) 0 &POW 0 Other Name of Mewg Oacer (WM 4.0. it PAGE nap Doom W. C ' Poucn Tranwang Chloe( LD. a keg Minas We aSuetaCt slow vale an -a- op _ DISTRIBUTION: WHITE — COURT COPY GREEN — STATE ATTORNEY YELLOW — AGENCY PINK — JAIL GOLD. DEFENDANT IN TA's ONLY) EFTA00233014 Probable Cause Affidavit Palm Beach Police Department Agency ORI# 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 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 Ell=, 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 rub his fingers on their vaginas. On occasion, Epstein would introduce a massager/vibrator and rub the victims vaginas 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 `1M clotl 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 cousin of boyfriend and classmate at 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. MI stated that along 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 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 conversation occurred between and whereas reportedly told that if Jeff asked her age, The foregoing instrument was sworn to or affirmed State of Florida before-me this In day of May, 2006 by Cou Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) Signatu Ong Officer Date: 05/01/2006 Pagel of 22 EFTA00233015 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 she should say she was eighteen. It was later confirmed by the Sis 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 IS 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. .1 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 • 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 s alone in the kitchen. They returned a short time later. They all spoke briefly in the kitchen. IS was instructed to follow upstairs. S 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. IS recalled 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 SI to take off her clothes. • 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 so she took off her shirt leaving her bra ori. Epstein had removed his towel and told the I. 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 IS began to give Epstein the massage, he told her to get on his back. • stated she straddled herself on Epstein's back whereby her exposed buttocks were touching Epstein's bare buttocks. S 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 began to The foregoing instrument was sworn to or affirmed State of Florida bAfore me this 1" day of Allay, 2°06 by rouaty_of finch Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) Signatu g Officer Date: 05/01/2006 Pageis2 of 22 EFTA00233016 Probable Cause Affidavit Palm Beach Police Department Agency ORLI FLO 500600 massage vaginal area. • stated there was no penetration as the vibrator was on top of her underwear. IN recalled Epstein ejaculating because he had to use the towel to wipe himself as he got off the table. Epstein then left the room and got dressed. She went back downstairs where she met wit h h I. said she was paid three hundred dollars in cash from Epstein. Before she left, Epstein asked ve her phone number. As and were leaving the house, told IN 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 561- n spoke with in an attempt to arrange 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 subsequently called back • and left a voice mail message for her indicating that she had set up an appointment for IN to go to Epstein's house at 11:00 am on April 5, 2005. This message was recorded from Ms 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 tithe frame had informed to be ready to go work at Epstein's house. On October 3, 2005, Sgt Frick and I went to residence and viewed her vehicle parked in the driveway, a red Dodge Neon. Sgt. Frick 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 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 before me this 1" dsky of May, 7illi‘ by Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida County of P Im Sea Signature Officer Date: 05/01/2006 Page3 of 22 EFTA00233017 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FL0 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. 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 grabbed her buttocks 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 brought to see Epstein, each time she was paid $200. stated she had brought the following girls: II ( al6 year old female), (a 16 year old female) and said that at the time she 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 .hey 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 ta isi tein'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. a 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 Signature of Police Officer (F.S.S. 117.10) The foregoing instrument was sworn to or affirmed before-me-this-Pt-day-of May,,-2006-by Det Joe Recarey, who is personally known to me. State of Florida County-of-Pal. Beach Signature Date: 05/01/2006 Officer Pageflof 22 EFTA00233018 Probable Cause Affidavit Palm Beach Police Department Agency ORM PLO 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, they disapproved of the encounters with him and she stopped. further stated that still tries to call house and leaves messages. Sgt Frick 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 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). VMS dropped off at her house without incident. On October 3, 2005, Sgt Frick 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. Mn,i 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, Mrs I was advised we would be speaking with her. She expressed if her daughter had information, she wanted to assist. We interviewed IN who 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 M 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 Frick and I thanked Mrs.' for her time and left the area. She stated she would ask II 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 Dawson and I drove to the dob During a sworn taped statement, when she was seventeen years old she w taken to a house by because they both attend 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 beferenasai.s_vt day_of.may,2oo6__by__ Det Joe Recarey, who is personally known to me. eti ore4 Signature of Police Officer (F.S.S. 117.10) State of Florida County of P9le4 Reach Signatur Date: 05/ /2006 Officer PageCof 22 EFTA00233019 Probable Cause Affidavit Palm Beach Police Department Agency OIRIN FLO 500600 for Jeff. She was told she would have to provide 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 kept her clothes on during the massage. She advised sometime during the massage, Epstein 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 massage. 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. 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 message on October 4, 2005 at 10:59 am, revealed a female voice provided the incoming telephone number as to call her back reference stated she inadvertently told who identified herself as who requested the police questioning. about the.police, investigation 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 family and 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 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 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 bcfot a me-Ibis-1n day of Mayr2006 by Det Joe Recarey, who is personally known to me. State of Florida County-of-Fains-Beaelt Signatur g Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page ltof 22 EFTA00233020 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 hint 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 Epstein 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 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. 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. 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 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 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' t 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 brought into the kitchen area of the house. She further stated that fellow High School students • and (MI 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 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 State of Florida e ere we tnis ay ul may, Det Joe Recarey, who is personally known to me. Signature of Police °dicer (F.S.S. 117.10) uuuty of itn Dc Signatur g Officer Date: 05/01/2006 Page" of 22 EFTA00233021 Probable Cause Affidavit Palm Beach Police Department Agency 01W FLO 500600 table, straddling Epstein to massage his back. While doing this her buttocks were touching Epsteins. 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 massage table and turned it on. stated Epstein began rubbing the vibrator over her thong underwear on her vaginal area. 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 Dawson and I met with E dob at her residence. As E 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 I 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 r3each High School, what did for Epstein. called a person known to E as and scheduled the appointment picked IE 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 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 exposing her belly area. During the massage, Epstein removed his towel and laid on the massage table naked. As E rubbed Epstein's chest 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 Signature of Police Officer (F'.S.S. 117.10) 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 me. State of Florida County ofPalm Be Signs Date: i i 1/2006 Officer Pageof 22. EFTA00233022 Probable Cause Affidavit Palm Beach Police Department Agency OEM 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 explained 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. 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.. 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 Epstein 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. On October 6, 2005, at 11:45 am, I met with dob , at Lynn University 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 Jeff Epstein in Palm Beach. advised she ori 'nail had been taken to the Epstein house by whom she met when they both attend 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 --before-me-this-1n day of May, 2006 by Det Joe Recarey, who is personally known to me. 1<le# Signature of Police Officer (F:S.S. 117.10) State of Florida Camay Palm Bach Signa ng Officer Date: 0 i 1/2006 Pagel of 22 EFTA00233023 Signature of Police Officer (F.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 "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 stem 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 about herself. Epstein knew she was a soccer player and would be attending Lynn University. 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. During the massage, she asked Epstein if she could borrow one of his vehicles to visit her family and boyfriend in Orlando, 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 grabbed her buttocks and caressed the buttocks cheeks. 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 use the vibrator 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 Jeff Epstein 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 Lynn University Gym field. I asked her if she ever took any one to the house, explained she took a friend of hers who attended High School, who has relocated to Orlando 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 Dawson 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 11, 2005, w/fM dob ., was arrested by the Palm Beach Police Department The foregoing instrument was sworn to or affirmed be tore me this ay of May,1t106 Det Recarey, who is personally known to me. State of Florida Conn n la Bwc Signatu Date: ng Officer 2006 Pagdaof 22 EFTA00233024 Signature of Police Officer (F.S.S. 117.10) Probable Cause Affidavit Palm Beach Police Department Agency ORI# 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 Dawson 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 chool 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. I. explained that as she was w up the stairs she observed several photographs of naked women alon the walls and tables of the house. I. further explained that she was brought into the bedroom, where repared the room by setting up the massage table and provided the oils for her to rub on Epstein.. exp ame 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 stated she provided massage wearing only her panties. She continued rubbing his legs, thighs and feet. advised he turned over onto his back. Epstein touched her breasts and began 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 whe and were waiting. stated received an unknown amount of .noney or ng er 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 massage his chest area. stated Epstein would then began to masturbate himself and at the same time would insert his fingers in her vagina and masturbate her with his fingers. explained Epstein would continue this process until he ejaculated. He would then utilize a vibrator/massager on her vagina until. climaxed. 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. advised that thin s escalated within the home as Epstein would instruct and pay. to have intercourse with his female friend, I. explained the intercourse included using strap on dildos, large rubber penis' and other evices a ps in had at his disposal.. Epstein would watch them have intercourse and masturbate himself . Occasionally, Epstein would then join in The foregoing instrument was sworn to or affirmed State of Florida before me thtrla-dayof May; 2006 by Coun Det Joe Recarey, who is personally known to me. Signatu ng Officer Date: /2006 Pagel t of 22 EFTA00233025 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 during the female on female intercourse and provide oral sex to both. and his occurred during the time. was sixteen years of age. advised this continued to escalate during two years. The routine became familiar to. Epstein's assistant ould telephone her every time Epstein was in the Town of Palm Beach and would place appoin 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 with his penis. • 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 photograpla her naked and having sex and proudly display the photographs within the home. ' g one visit to Epstein's house in which she provided a massa e to E stein his female friend, was also present. • provided the massage in which and her would fon e eac of ers is and kiss for Epstein to enjoy. Towards the end of this massage, pstein grabbed and turned her over onto her stomach on the massage table and forcibly inserted his penis into her vagina. • stated Epstein began to pump his penis in her vagina. became upset over this. She said her head was being held against the table forcibly, as he continued to pump inside her. 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 Dawson and I met with 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 E • stein. She stated she was brought to the Epstein house in March of 2005. a classmate at 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 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. and inquired about the police investigation, and left his telephone number for additional contact. stated she was interviewed already by a private investigator for stein. He identified himself as provided no additional information, as it appeared her responses were almost scripted. The foregoing instrument was sworn to or affirmed e ore me is ay o ay, Det Joe Recarey, who is personally known to me. State of Florida e ( l a f Signature of Police Officer (F.S.S. 117.10) Signatur Officer Date: 05/01/2006 Pagi2of 22 EFTA00233026 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 On November 6, 2005, at approximately 3:30 pm, I met with doti , 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 girl, 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 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 room 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 area. stated as she did this, 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 rubbed the vibrator on her vaginal area. advised he never penetrated her vagina with the vibrator. He continued to rub her 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 had on previously and went into the shower area. got dressed and met with the massage. was told to leave her telephone number with $200.00 for bringing and paid $200.00 to for providing in the kitchen area. Epstein came into the kitchen and provided 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 Sandman 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 Joe Recarey, who is personally known to me. State of Florida county of Palm Reach Signatur Officer Signature of Police fficer (F.S.S. 117.10) Date: 05/ 1/2006 Pagilof 22 EFTA00233027 Probable Cause Affidavit Palm Beach Police Department Agency ORD* FLO 500600 attending 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 approximately 4 or 5 times in the past year. She accompanied with 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 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, 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 two years ago when she was first approached by a classmate at High School. approached her about working for Epstein and providing a massage to him for S200.00. had made the arrangements however was unable to take her the da the arrangements were made. had take also attended High School and was familiar with an assistant and another assistant brought her upstairs as she observed several with Epstein. recalled she was brow ht there and entered through the back kitchen door. She had met photographs of naked females throughout the house. stated 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 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 maccager/vibrator, which she described as white in color and a large head. Epstein would rub the vibrator/massager on her vaginal area as he would masturbate. stated she had been to the house The foregoing instrument was sworn to or affirmed e ore me Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida of-Palm-Beach Signatur=Are g Officer Date: 05/01/2006 PagJ%f 22 EFTA00233028 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 duri her visits to rovide massages. from High School. stated she brought a girl named `4= and stated she received $200.00 for each girl she brought. On November 8, 2005, I met with Department. During a sworn taped statement, ago. She was approached by a subject known to her as providing massages to Epstein. had heard that several girls from doing this and making money. She agreed and was taken to the house by and Epstein and brought her upstairs to a master bedroom where a massage table was prepared and the proper oils were selected. IN 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 provide a massage and things had escalated from just providing a massage. Epstein began touching her on her buttocks and grabbed her closer to him as he masturbated. Epstein also grabbed her breasts and fondled her breasts 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 penetrated her vagina with his penis and began having intercourse with her until he reached the point of climax. Epstein removed his penis from her vagina 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 continued to state on one other occasion, Epstein introduced his girlfriend into the massage. brought into room with to provide a massage. Epstein had them kiss an ondle each other aroun the breasts and buttocks as they provided a massage to Epstein. Epstein, watched and masturbated as this occurred. On other occasioniikein, introduced the large white vibrator/massager in the massage. Epstein stroked the vibrator/massager on vagina as she provided the massage. W/F, at the Palm Beach Police stated she had met Jeffrey Epstein approximately one year had asked e wanted to make money High School were had introduced her to On November 14, 2005, Det Sandman 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 ears old when she first went to Epstein's house. On her first visit she was brought by a fellow student from High School known to her The foregoing instrument was sworn to or affirmed -----beforrmrthis r day of May,- 200frby Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida tv of Palm-Beach Signatu g Officer Date: 05/01/2006 Page of 22 EFTA00233029 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, clothed. was asked if she ever removed her clothing to provide 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 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 continued rubbing Epstein. Epstein turned over onto his back and she rubbed his chest area. 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. 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, Det. and I met with IM dob During a sworn taped statement, I. stated she met Jeffrey ' v ago. She was sixteen years of age and was approached by a fellow 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 e ore me Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida syt1 lin-Reath Signature/ ng Officer Date: 05/01/2006 Pad Hof 22 EFTA00233030 Probable Cause Affidavit Palm Beach Police Department Signature of Police Officer (F.S.S. 117.10) Agency ORD/ FLO 500600 massage topless. 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 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 the massage, Epstein turned over onto his back and requested 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. rubbed Epstein's chest.. 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 so 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. I. 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 to provide another massage.. 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 by 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 massaging his legs and back. As. finished with Epstein's back and legs, Epstein then turned over onto his back.. started to mb his chest and he began masturbating. As l ovrubbedhis chest, Epitein leaned over and produced a massager/vibrator. He turned it on and began rubbing agina and masturbating himself at the same time.. stated she continued to rub his chest as this was occurring. She described the vibrator/massager as large grey with a large head. Epstein rubbed her vagina for approximately two to three minutes with the massager/vibrator. He then removed the vibrator from her vaginal area 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 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 High School. The foregoing instrument was sworn to or affirmed State of Florida e ore me TnIs 1. clay or ay, 6VO0 ny Det Joe Recarey, who is personally known to me. Signatu ng Officer Date: 05/01/2006 i Page of 22 EFTA00233031 Probable Cause Affidavit Palm Beach Police Department Agency 01101 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 tak who signed the bottom of the messages. During the execution of the warrant, I located a 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. Dawson 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 so that. may The foregoing instrument was sworn to or affirmed before me tins it'd ro f"May, 2006 by Det Joe Recarey, who is personally known to me. State of Florida Signature of Police fficer (F.S.S. 117.10) Signature/ r ng Officer Date: 05/ 06 Page of 22 EFTA00233032 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 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 be an to rub his chest, Epstein asked her questions about herself. remembered telling him she attended 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 things. She continued rubbing his chest. Epstein reached up and unsnapped her bra from the front. explained the bra she used had a front snapping device. Epstein rubbed her breasts and asked her if she like having her breasts rubbed. 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 touched her breasts. 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 stroking her clitoris. said, "He commented how hard my cult was." He then inserted two fingers in her vagina and was stroking her within her vagina. She tried pulling back to pull out his fingers from within her vagina Epstein removed his fingers from within her vagina and apologized for putting his forgers inside her. During this time, he kept his hand on her vaginal area and continued to rub her vagina.. stated he rubbed 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. 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 ' stated she met Epstein when she was fifteen years of age. She was approached by a friend from 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 Det Joe Recarey, who is personally known to me. t(11 Signature of Pollee Officer (F.S.S. 117.10) Date: 05/ 1/2006 State of Florida uu ty Signature Officer PagelHof 22 EFTA00233033 Probable Cause Affidavit Palm Beach Police Department Agency ORM FLO 500600 to model lingerie for a wealthy Palm Beadier. le was taken to Epstein's house located on El BrilloWay. introduced le to Jeffrey Epstein. Epstein had his personal chef prepare dinner for le 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. explained to • that this was his routine and to rub his calves and feet. Epstein had told • to get comfortable. le 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 nipples. • stated that as she started rubbing his chest, Epstein began masturbating himself . Epstein touched her breasts and stroked her vagina with his fingers. Epstein continued to masturbate himself as he stroked her vagina. Epstein ejaculated on his towel and paid le $200.00 for the massage. Epstein told • that if she told anyone what happened at his house that bad things could happen. le and were brought home by Epstein's houseman and le was afraid that Epstein knew where she lived. le 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 rubbed her vagina with his fingers. Epstein began to masturbate himself with an upwards and downward motion on his penis. Epstein continued to touch her vagina with one hand and masturbate with the other hand. Once Epstein ejaculated onto the towel he was wearing, the massage was over. le was paid $200.00 for the massage. Epstein again told not to speak of what happened at his house or bad things would happen. le 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 though 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 get comfortable. The females would then provide the massage naked as Epstein would either touch their vaginas with his fingers 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 of raim Beach Det Joe Recarey, who is personally known to me. State of Florida /fel Signature of Pol' e Officer (F.S.S. 117.10) Signature Date: 05/' 006 g Officer Pag#°of 22 EFTA00233034 Probable Cause Affidavit Palm Beach Police Department Agency ORIN FLO 500600 their vaginal area. 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. 1 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 tolEi 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 Toe Recarey, who is personally known to me. a 6-leeir Signature of Police 6fficer (F.S.S. 117.10) State of Florida Co ty of Palm Beac Signatu e/ r "ng Officer Date: I /2006 R‘ Page of 22 EFTA00233035 Probable Cause Affidavit Palm Beach Police Department Agency ORI# 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 w uments, and a note with Mr. Epstein's stationary with direction to deliver a bucket of roses to 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. Specifically, The phone records showed called during the exact times and dates when victim advised the incident occurred. also coordinated the encounters with.-_-_- 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 Epstein, who at the time of the incident was fifty two years of age, did commit lewd and lascivious molestation on 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 I" day of May, 2006 by Co ty of Palm Beath Det Joe Recarey, who is personally known to me. State of Florida Signature of Folic Office (F.S.S. 117.10) Signatu Officer Date: 05/01/2006 Paeof 22 EFTA00233036