New York County Clerk's Index No. 30129/2010
New York County Clerk's Index No. 30129/2010
Neftx *ark Supreme (Jlmxrt
APPELLATE DIVISION -FIRST DEPARTMENT
I)
tt
1 PEOPLE OF THE STATE OF NEW YORK,
—against—
JEFFREY E. EPSTEIN, Respondent,
Defendant -Appellant.
APPENDIX
CYRys R. VANCE, JR.
NEW YORK COUNTY DISTRICT
ATTORNEY'S OFFICE
One Hogan Place
New York, New York 10013
Attorneys for Respondent JAY P. LEFKOWITZ
SANDRA LYNN MUSUMECI
KIRKLAND & PJ r is LLP
601 Lexington Avenue
New York New York 10022
Attorneys for Defendant -Appellant
REPRODUCED ON RECYCLED PAPER
EFTA00180921
.
.
EFTA00180922
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
EFTA00180923
ii
PAGE
Order Granting Jeffrey E. Epstein's Motion for Travel,
dated December 18, 2009 A48
Letter from Florida Department of Corrections Regarding Termination
of Supervision, dated July 21, 2010 A49
Letter from Palm Beach Sheriff's Office Regarding
Jeffrey Epstein's Participation in the Work Release Program,
dated August 12, 2010 A50
Letter from Jack A. Goldberger to NYS Sex Offender Registry
Regarding Florida Registration Level applicable to
Jeffrey E. Epstein, dated August 12, 2010 A51
Letter from Martin G. Weinberg to NYS Board of Examiners of
Sex Offenders Regarding Level and Designation Determination
for Jeffrey Epstein, dated August 16, 2010 A53
Letter from Stephen R. Alexander, Psy.D. to Jack Goldberger
Regarding Opinion of Jeffrey E. Epstein, dated August 16, 2010 A58
Recommendation of Board of Examiners of Sex Offenders, Including
Risk Assessment Instrument, dated August 19, 2010 and Case
Summary, dated August 23, 2010 A62
Letter from Supreme Court attaching Notification, Recommendation
and Notice of Right to Appeal, dated August 26, 2010 A67
Letter from Supreme Court to Jeffrey E. Epstein informing of SORA
Level Determination Hearing, dated August 26, 2010 A68
Order Sheet for Jeffrey Epstein, dated August 26, 2010 A69
Letter from Supreme Court to Counsel Informing of
SORA Level Determination Hearing (with attachment),
dated August 26, 2010 A71
EFTA00180924
iii
PAGE
Letter from Jay P. Lefkowitz 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 A81
Transcript of SORA Hearing, dated January 18, 2011 A82
•
EFTA00180925
.
EFTA00180926
Al
Appellant's Pre-Argument Statement, dated February 9, 2011
[pp. A1-A2]
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, Ne1.14611
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 THE CAUSE OF ACTION OR SPECIAL
PROCEEDING: Sex Offender Registration Act (SORA) hearing, pursuant to Article 6-C of the
Correction Law.
7. RESULT REACHED IN THE COURT OF ADMINISTRATIVE BODY BELOW:
Supreme Court, New York County, adjudged appellant Jeffrey E. Epstein to be a Level 3 sexual
offender, without additional designation.
8. GROUNDS FOR SEEKING REVERSAL, ANNULMENT, OR MODIFICATION: The
Court's designation of appellant Jeffrey E. Epstein as a Level 3 sexual offender was an abuse of
EFTA00180927
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 Jar. Lefkowitz, P.C.
S dra Lynn Musumeci
KIRKLAND & ELLIS LLP
601 Lexington Avenue
New York, New York 10022-4611
Telephone:
Facsimile:
Attorneys for Defendant -Appellant Jeffrey A
Esptein.
-2-
EFTA00180928
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 PICKFIOLZ
PLEASE TAKE NOTICE that the above named defendant, Jeffrey E. Epstein, hereby
appeals to the Appellate Division of the New York Supreme Court in and for the First
Department, from an order entered in the above entitled action in the office of the Clerk of New
York County on the 18th day of January 2011, which order adjudged defendant Jeffrey E.
Epstein to be a Level 3 sexual offender pursuant to Article 6-C of the Correction Law, and this
appeal is taken from each and every part of that order as well as from the whole thereof.
Dated: February 9, 2011
To:
Clerk, New York County
Cyrus R. Vance, Jr.
NEW YORK DISTRICT ATTORNEY'S
OFFICE
One Hogan Place
New York, NY
Telephone: Lefkowitz, P.C.
dra Lynn Musumeci
KIRKLAND & ELLIS LLP
601 Lexington Avenue
New York, Ne
Telephone:
Facsimile:
Attorneys for Defendant
Jeffrey E. E stein
PF 1 L F
FEB 0 q Yull
ESUPREIViE COURT
relIEW YORK COUtellY
APPWASSt 7;41.11Filtak.3
EFTA00180929
A4
Order Appealed From, dated January 18, 2011 with Notice of Entry
Epp. Ad-AS]
PA. STATE OF NEW Y,ORR•7• F. EXAMINERS OP SEX OFFENDERS lx.14 TOWER PLACE
tieff,NEW. YORK 1220 376 V.4.11.c.:1•:1-;ifigiii '
'11.tiAk • ":viiEst
The • y dr. ct •:-,A ill •,,h. Bta4) I: ! . oveLreterenos vidtialhe:trthti ;an offense an , s' blIs ttitiiit thn:addrisitin -dIctired:rlt fill bp95,3144fininiid,litittine,offend r- Is_requiina td)i,egItteire Wit. tteeitiftendatitthew York ' ' , ii•iterf. 'f.,•••1, . el lififectoiitiiiitittistl
t.brkalitlireS064(11;4:11V:° 7.1ftintateD fe
latstIkluirinintnefistillittitilriftitAr ilklia tin
itA 16* tehli74a196024Th II
• ••f.68442r..the Cattily 61":8 'Court til; ettenntiottesIdinS of the offendensliall•aninrininIFficeliffiiiiirift :anVileXtgnatIntattliteatitt 'rtiii*clObi Tittellisitthe offender"; meets ire $fiiigate linx.0ffindtki,or:peinil itontak t filth In conichoti LieSabi0n lei 't Wt.lipIP, 40 igki,IgfinllMOMV. , 4.4:Viritritte*ZsCi,;'. fiPt_574 l'.4rf '1(4rhea' et .4:105Is'bi uici-obel, 20. 6.1 o ego °CO •ariEina;h 1hlitsiellieferCanntiidettal • eithiltiii.totlrfihniUidlid UW:iisii Iiiiitandrcigidananigi,hinhnt tJI1 e A oSnderr Having been givers noS'J?tdtldinjt'the'daktlina, and place of the. ntiOnctiOlallatinifiSlif3.MS160 ..LL Iff Ali 4)idiiiict7, Plea ettnnteithat ti entpermimi the Offender's deli hitnii,nb aimiiriniinti. notilleati6if 6-Went " ItO:StTiag011ratt. p.:!t7144 ::ks9AWnti.V.,16:(;7..k f.
WAftx?py or, e'orde'rli ing f ' .1_ . naval arid oesignegoil ottinnirialloitcand. i d hg a 8 81 Wi hICIV:Su idetniminalloni;arlbSede: _.„„, s, . ., , ,...,,,, ...,„ . ,..,:erille is ,,,il: , ...1_,,,R",.., gei be • a to4thalomi‘eoric.ilmlfiejiittiaqtatAWMATON flifignWtinit spytthe.C.hutt4; In • „ 410, alealiwcinOnle: and.intlacn,musiolTn , ulFa VIrfl°4;?-711sers 'risk' iillikinatititiloiltil te0nn der P101Sen Chsfribttte thei,ternainIng netts an I tt r t, ItVigib:1•.:4,0rtC. 't!1 .:,-7- • Fr itk,i?..“-Xliti.:,;-F:**,:?1;te, 1;.';i• 'Ait`l?.W45 rgfre
' lit.tt4-1}ciritt:161:Al ift,tiat ets ..1 Z '''fris.It IF i MinationfiefoW filo be bomp_ . Sonitinclh W, 4.:0 r. 1esseASkizregilrel
VEL,PETERAIINATION: Oro tort,
.-? . ge,,wilte,ittlieatp.I.Ibtri1U617,...Uatl.r?7Airorti"ctai-hv'04.thki.INYt
.7.4 'prsiNoeteeix Offs
1/21:;
EFTA00180930
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 AYI'ORNEY'S
OFFICE
One Hogan Place
New York, NY
Telephone: Ja P. Lefkowitz, P.C.
Sandra Lynn Musumeci
KIRKLAND & ELLIS LLP
601 Lexington Avenue
New York, Neill -4611
Telephone:
Facsimile:
Attorneys for Defendant Jeffrey E. Epstein
PILED
FEB 0 P
New nne C
AapItAIC O8°Prr
it" OU UMY nittAU
EFTA00180931
A6
Palm Beach Police Department - Probable Cause Affidavit of Det. Joe Recarey - Defendant
dated May 1, 2006
1pp. A6-A271
Probable Cause Affidavit
Palm Beach Police Department Agency ORIN FL0 500600
Police Casetl: 05-368 (2)
Defendant:
Race/Sex: White Female
DOB: 0545-1975
Charges: Principal in the 1" Unlawful Sexual Activity with a Minor (4) counts
Principal in the I" Lewd and Lascivious Molestation (1) count
From March 15, 2005, through February 2006, the Palm Beach Police Department conducted a sexual
battery investigation involving Jeffrey Epstein, and . Sworn taped statements were
taken from five victims and seventeen witnesses concerning massages and unlawful sexual activity that took place
at the residence of Jeffrey E stein, 358 El Brill° 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 , Epstein's assistant, who in
turn would record their telephone numbers and name. The victims would be brought to Epstcin's bedroom to
provide the massage. Epstein would enter the room and order the victims to remove their 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 peuis/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 "SG," and
her family reported unlawful sexual activity which occurred at a residence within the Town o m cite . SG
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, SG stated that IME=, a cousin of SCI's
boyfriend and classmate at lm Beach High School, worked for a wealthy man and did sexual favors for
him. She also admitted that had offered her an opportunity to make ne . During the beginning of
the month of February O explained that she was first approached by to go with her to Epstein's
house, SO stated that along with a Hispanic female, later identified at L . pick her up at
her father's house on a Sunday. SG was not sure act dates but know it was a Sunday. SO 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 in day of May, 2006 by
Det Joe Ranee'', who is personally known to rue.
Signature of Police Officer F.S.S.( 117.10) State of Florida
County of Palm Beach
Signature Officer
Date: 05/n 006
Page 1 of 22
EFTA00180932
A7
Probable Cause Affidavit
Palm Beach. Police Department Agency OEM FLO 500600
ill
d' conversation occurred between and SG whereas reportedly toliiiiit if Jeff asked her age,
she should say she was eighteen. t was later co y the SG's.father that picked his daughter up
on February 6, 2005. According to SG's father, drove a pick up truck.
• SO 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 SG stated that
they walked up a driveway ast what appeared to be a small guard/security room. A male approaching them
asking what they wanted. stated they were there to secs Epstein. The male allowed them to continue
walking up to the house. SG 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 andlater identified as
, entered the kitchen. Epstein introduced himself to SG. SG 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 SG alone in the kitchen. They returned a short time later.
They all spoke briefly in the kitchen. SG was instructed to follow upstairs: SO 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. SG recalled there bein 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 SG to take off her clothes. SO stated Epstein
was stem when he told her to take off her clothes. SG 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 SG to
take off everything. SG stated Epstein was nude when he took his towel off, placing it on the floor as he laid
down on the table. SG 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 SG began to give Epstein the massage,
he told her to get on his back. SG stated she straddled herself on Epstein's back whereby her exposed buttocks
were touching Epstein's bare buttocks. SG 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 SG to massage his
chest. SG was now standing on the ground and resumed massaging Epstein's chest area. SG 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 rue this I" day of May, 2006 by
Det Joe Recarcy, who Is personally known to me. State of Florida
County of Palm B ech
,44.L. Kai Signatur g Officer
Signature of Poll‘Officer F.S.S.( 117.10) Date: OS 006
Page 2of 22
EFTA00180933
A8
Probable Cause Affidavit
Palm Beach Police Department Apncy ORM FLO S00600
massage SO's vaginal area. SO stated there was no penetration as the vibrator was on top of her underwear.
SG recalled Epstein ejaculating because he had to use the towel to wipe himself as he he table. Epstein
then left the room and SG got dressed. She went back downstairs where she met with SG said she
was paid three hundred dollars in cash from Epstein. Before she left Epstein asked SG to leave her phone
number. As SO, and Figueroa were leaving the house, told SG she received two hundred
dollars that day or ringing her.
During the course of the investigation, parental consent was granted for SG to assist with the
investigation. At our direction SG conducted controlled taped phone calls to cellular telephone 561-
308-0282. SO spoke with in an attemmange another meeting with Epstein. SG 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 SO and left a voice mail message for her indicating that she had set up an
appointment for SO to go to Epstcin's house at 11:00 am on April 5, 2005. This message was recorded from
SG's voice mail. I-
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 la:one
message for Epstein which stated Haley and SG's name at 11:00 am. This was the time frame had
informed SG 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 koocked on the door and met with a. as
told that we were investigatinga 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 to tat at the
conclusion of the interview she would be returned home.
Beach Police Department. voluntarily came with us back to the Pam
Upon our arrival at the police station, was brought to the interview room in the Detective. ureau
where I obtained a taped, atement. I began the interview by asking how she became
state pproximately two yearsago, just a cr she turned 17 Pears of age, acquainted with Epstein.
she was approached by a friend named at the Canopy Beach Resort in Rivera Beach. was asked
Manted to make money. She was told she would have to provide a massage and she m e $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 Recarcy, who is personally known to me. State of Florida
County of Palm Beach
Signaturc Ar Z t1 Officer
Signature of Police Meer 4. 117.10) Date: 05/0 006 L
Page3of 22
EFTA00180934
A9
Probable CauseAffidavit
Palm Beach Police Department
Anne), ORO FLO 500600
(Unknown last name) and (Unknown last name) picked up and she was taken to
Epstein's house. Upon her arrival to the ouse 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
brow t out the massage oils and laid them next to the massage bed. , then left the room and informed
Jeff would be in, in a minute. Jeff entered the bedroom wearing only a towel. He removed the towel
and laid nude on the massage table. He laid on the table onto his stomach and picked a massage oil for
to rub on him. Untie 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 but1 don't want to he touched. stated she performed the massage naked. At
the conclusion of the massage, Epstein paid $200.
After the message 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: SO :-...:.1. " • • , • . • , J.S. ( al6 year old female), VL (a 16 year old
female) and :..._.' — . :.
through 16 years of age. I asked said that at the time she brought these Epstein's house they werealll 4
which one was the youngest. advised SG 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 SO was aware. She stated every girl she brought knew what to expect. She explained she knew that SO
wanted to make money. She approached SO and explained about going to work for Jeff, SG agreed and
arrangements were made to bring her to Epstein's house on a weekend. stated that she and __
(Later identified as ' —",„ . ) picked up SG at her house. stated that at that time she was driving
a red pickup truck. They traveled tatein's house and entered through the kitchen door. They met with the
house chef and Epstein's assistant . SO was introduced to Epstein while they were in the kitchen area.
aled SG upstairs and Epstein wont upstairs. When the massage was over SG returned to the kitchen area.
stated she was paid $200.00 for bringing SO to Epstein's house. stated SO told her she was
paid $300.00 for the massage.
slated that SO was the last person she brought to Epstein's house. Shc had changed her cellular
number to avoid being contacted by She continued stating that she had no direct contact with Epstein
Tho foregoing instrument was sworn to or affirmed
before me this 1" day of May, 2006 by
Oct Joe Reearey, who is personally known to Inc.
Signature of Police Rice (F.S.S. 117.10)
itState of Florida
County of Palm Scach
Signatur g Officer
Date: 05/01/2006
Page40122
EFTA00180935
A10
Probable Cause Affidavit
Palma Beach Police Department Agoncy ORI# FLO 500600
when he was going to travel to a Beach. sai Epstein announces to his assistant,
he is traveling to Palm Beach, would then contact to arrange girls to "work" for Epstein.
stated that once her arents discovered that shes visitingEpstein thry d* approved of the encounters with him
and she stopped. further stated that still tries to call 's house and leaves messages.
Sgt Frick entered the room and explained to that ha 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 within the vehicle to record
any converse ons within the vehicle. During the drive back to her home made the co " I'm like
a Heidi Fleiss." (Hollywood Madam who sent girls to clients for sexual favors in California). r
watt
dropped off at her house without incident.
On October 3, 2005, Sgt Frick and I went to speak with IS, a sixteen year-old female who was
brought to Epstein's residence by . We met with JS's mother at their front door. We explained
the ongoing investigation and asked to speak with JS as we had information that she had "worked" for Jeff.
Mrs. S introduced us to her husband and allowed us entry into the home. We sat in the dining room and met
with IS, a As she was under the age of eighteen, Mrs S was advised we would be
speaking with her. She expressed if her daughter had information, she wanted to assist, We interviewed JS, who
denied havin any inappropriate encounters with Jeff (Epstein). She stated she had gone to Jeff's house with
approximately eight months ago and sat In the kitchen with the house chef, but nothing happened.
As the parents were present during the interview, we felt that JS 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. S for her time and left the area. She
stated she would ask JS again after we left as to what happened at Epstein's house. I informed her that IS had
my telephone number and hopefully she would call.
On October 4, 2005, Dot Dawson and I drove to the'" ' '• home and met with 3/41.......1..:... ' and
During a sworn taped statement . ._ . • stated approximately a year ago.
e was seventeen years old, she was to a house by MM . stated she knows
because they both attend Royal Palm Beach High School. She was told she could make money working
The (ongoing instrument was sworn to or affirmed
before me this 1" day of May, 2006 by
Del Joe Recarey, who is personally known to me.
Signature of Police Meer .S.S. 117.10) State of Florida
County of Palm Beach
Signatur ng Officer
Date: 05/01/2006
Page Sof 22
EFTA00180936
All
Probable Cause 4Ifidervil
Palm Beach Police Department Agency ORE# FLO 500400
for Jeff. She was told she would have pinnide a massage to Jeff. 7', .:_ stated upon her arrival to the house
she was brought to the kitchen area by M. They met with the house chef who was already in the kitchen
area. . stated would wait for her in the kitchen. I. . was introduced ton 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. 7 ' it 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. T ....: said she was uncomfortable by the incident involving Jeff. At the conclusion of
the manage, she was paid 5200.00 for the massage. I asked : • if she has any formal training in massages to
which she re lied no. 1 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. 7 :c stated she
returned to Epstein's house on another occasion with and anotheri111.•
she waited in the kitchen with , while E. was taken upstairs by . ......_::c stated
stated she only'did
L.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...., *1
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 taller that she was given a rental car, a 2005 Silver Nissan Sentra,
to utilize to visit family and visit Epstein. : ..... • asked her what was mil on at the house that the police would
be asking questions. .' .. • stated . thenealled 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 7 ' not to contact and do not provide any more
information to as she would notify Jeff Epstein and what was transpiring.
On Ootober4, 2005, I made telephone contact with JS 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 JS. During a taped recorded
statement JS 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
Det Joe Reearey, who is personally known to me..
r. Signature of Police Meer F.S.S. 117.10) State of Florida
Conn of Palm Beach
Signatur A r qti g Officer
Date: 05/01/2006
Page tool 22
EFTA00180937
Al2,
Probable Cause Affidavit
Palm Beach Police Department Agency ORM FLO 5O600
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 JS 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 JS and E stein had a verbal
disagreement, at which time she left without being paid. She got with who was sitting in the
kitchen and told her "let's go." JS advised she received no money for that day. JS also said that
had told her if she was uncomfortable with what was going on, to let him know and he'll stop. She knew that the
• more ou do the more you get paid. JS 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 IS to rub
on him. At one point during the massage he tried to touch her buttocks. As JS 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. IS then became upset again and told Epstein she didn't want to be touched.
JS discontinued the massage and was paid $200.00. IS then went downstairs where was waiting
for her. She told she wanted to leave. JS said she never returned to the house. .13 stated she is aware
that her friend, .....__. !: was also at the house and had a problem with Epstein.
rl
f later researched doh 02/08/1987, and mot with her at her residence. During a sworn
taped statement, stated the following: on or about November 2004, she was approached at Royal Palm
Beach High School by , a fellow student. asked ' • if she wanted to make money.
She agreed and was told she would provide a massage to wealthy man in Palm Beach. picked her up
and drove her to a house in Palm•Beach. She was brought into the kitchen area of the house. She further stated
that fellow Royal Palm Beach High School students YL 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 half. She stated that the assistant was familiar with . The assistant brought her upstairs into a
master bedroom area. The assistant set up the massage table and put out lotions to be used. She told • '
Epstein would be available in a minute. Epstein entered the room wearing only a towel. Epstein removed his
towel, and laid naked on the massage table and picked a lotion to rub on his thighs and back. . • ' I further
stated during the massage, Epstein asked her to remove her clothes. She complied and removed her pants and
blouse. didn't remember if she had removed her bra but feels that she did. . " was certain that she
stayed in her thong underwear. • continued the massage and at one point she climbed onto the massage
The foregoing instrument was sworn to or affirmed
before me this 1" day Of May, 2006 by
Det Joe Recarey, who is personally known to me.
Signature of Polic Office (F.S.S. 117.10) State of Florida
County of Palm Be 11
Signatur> A ti g Officer
Date: 05/0 /2006
Pagel of 22
EFTA00180938
A13
Probable Cause Affidavit
Palm Beach Police Department Agency OIRIN FLO 500600
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 pews area because she was.uncomfortable. Epstein removed a large white vibrator which
was next to the massage table and turned it on. 1..22... stated Epstein began rubbing the vibrator over her thong
underwear on her vaginal area. Shortly thereafter, Epstein ejaculated and removed himself from the table. tie
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 L.:. • how old she was when this occulted, 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 dose to $400.00. stated she never returned to provide a massage for
Epstein.
At approximately 2:10 pm, Det Dawson and I met with YL, at her residence. As YL
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 L advised she wanted YL to cooperate and consented to the interview.
During a sworn taped statement, Y L stated the following: at the age of sixteen, during the month of
September 2004, she was approached by for a chance to make money. YL was friends with
associates of and knew the same people. YL had been previously told by her friends from Royal Palm
Beach High School, what did for Epstein. called a person known to YL as and
scheduled the appointment. picked YL up and drove her to Palm. Beach to a street ca e "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. YL was introduced to Jeff Epstein. led YL upstairs to the main bedroom area and
set up the room with a massage table and set out the oils. L 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. YL
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 It 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. YL advised Epstein began to masturbate as she rubbed
his chest. Epstein moaned as she tubbed his chest She observed he was continuing to masturbate and
The foregoing instrument was sworn to or affirmed
before me this day of May, .2006 by
Det Joe Recarey, who is personally, known to me.
Signature of Police flied- .S.S. 117.10) 7171 State of Florida
County of Palm Beach
Signatur Officer
Date: 05/01/2006
Page8of 22
EFTA00180939
A14
Probable Cause Affidavit
Palm Beach Police Department Agency ORIN FLO 500600 ,
attempted to reach up her tank top and touch her breasts. YL, pulled back and Epstein stopped, however he kept masturbating until he climaxed. He cleaned himself wi wet he was previously wearing. YL was
paid $200.00 for the massage and left the area. She met with who wastwaiting in the kitchen area and left the house.
YL then explained she never provided another massage n. She did however, go to the house
with and -: ;.72. ; as they took another friend of . YL advised she was prese
: went to work for Epstein. She advised she rode over and sat in the kitchen area with to •
wait for :. " .. YL advised while they waited for L. • ' the house chef prepared lunch for them as it was
almost lunchtime when they went. When...... ' was finished with the massage they left the asked YL if
Mever told her what would be expected when she provided a massage. YL stated yes, told her
assage would be expected, possibly naked and possibly some touching involved. YL has nolii
training in providing messages. YL spoke about a third and last time she went to Epstein's house.
drove another girl, ML, (sixteen years of age) who is YL's friend, to Epstein' YL stated ML knew that
YL had made money massaging Epstein and m Oy herself. took them in the kitchen
area of the house and introduced ML to and took ML upstairs to the main bedroom. YL
advised she doesn't know what happen as id not speak about what happened in the room. YL received
$100.00 front for going with her to Epstein's house and recommending ML.
On October 6, 2005, at 11:45 am, I met with ''. .. :, dob i, at Lynn University and
explained to her why we there to interview her. She advised she was aware of the ongoing investigation. ...:_s
stated she had previously spoken with : , .1. : .... " who told i er she was interviewedhy detectives. During a
sworn taped statement, . . stated she knew that w Jeff Epstein in Palm Beach.
advised she originally had been taken to the Epstein house by whom eke met when they both
attended Royal Palm Beach High School. She began going to the house when she was sixteen years of age and
stated she had been there a lot of times to provide massages over the past two ybars. I asked her if she had
formal training in providing massages, which stated she had not. advised she was told what was
expected of her by providing massages and she would have to remove clothing but if she felt uncomfortable Just
to say so and Epstein would stop pushing the issue. • - began providing massages and advised she kept her
Clothes on. She considered Epstein a pervert and he kept pushing to go further and further. • explained she
would keep telling him she had a boyfriend and would not be right to her boyfriend. It wasn't until recently that
began removing her clothes and staying in het thong underwear to provide a massage. explained
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
Signature of Poli e Office (F.S.S. 117.10) State of Florida
County of Palm Beach
Signatur ring Officer
Date: 0S/01/2006
Pagelof 22
EFTA00180940
A 1 5
Probable Cause Affidavit
Palm Beach Police Department Agency OEM PLO 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". J.: sus' %stein would try to touch her more and on one occasion
he:tainted to use a massager/vibrator on her. drove to the house for the original massage. :L—
ie 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. I 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 faniily 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 vibtator 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 assistent,M, who informed her
that Jeff Epstein bad 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 L. 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 cant
On September II, 2005, alai, 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 Recarcy, who is personally known to me.
Signature of Poll elf Medi' (F.S.S. 117.10) State of Florida
County of Palm Bench
Signatur Officer
Date: 05/01/2006
Pagclfbf 22
EFTA00180941
A16
Probable Cause Affidavit
Palm Beach Police Department Agency oiw FLO 500600
for misdemeanor possession of marijuana. During the arrest AN told the arrest-nig officer that she had information
about sexual activity taking place at the residence of Jeffrey Epstein. Additionally, during the ongoing trash pulls
from Epstcin'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 AH and obtained a sworn taped statement. AN
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. All stated she became his "number one girt" She explained that on
her first visit she was brought to the house by fellow Royal Palm Beac i chool classmate,
AH said she was brought through the kitchen area where she met for the first time. All was led to
the master bedroom, Epstein s room. All explained that as she was walking up the stairs she observed several
photographs of naked women aloe the and tables of the house. Hall 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. AN 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. AH removed her skid and kept her shirt on. Epstein then instructed her to
remove her shirt. AH removed her shirt and remembered she was not wearing a bra. AN stated she provided
the massage wearing only her panties. She continued rubbing his legs, thighs and feet. All advised he turned
over onto his back. Epstein touched her breasts and began to masturbate. Epstegi ejaculated which meant the
mas c was over. At the conclusion of the massage, AN was paid S200.00. They walked together downstairs . .where and were waiting. AH 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.
AH 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 onto his
back and allow her to massage his chest area. A14 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. AH explained Epstein
would continue this process until he ejaculated. He would then utilize a vibrator/massager on her vagina until AN
climaxed. AN advised that during her frequent visits, Epstein asked for her real age, AN stated she was sixteen.
Epstein advised het not to tell anyone her real age. All advised that things escalated within the home as Epstein
would instruct and pay AN to have intercourse with his female ftiend, . AH explained the
intercourse included using strap on dildos, large rubber penis' and other devices that Epstein had at his b disposal.
Epstein would watch them have intercourse and masturbate himself . Occasionally, Epstein would than join in
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 Poli o Officer (F.S.S. 117.10) State of Florida
County of Palm Beach
Signatu g Officer
Date: 05/01/2006
Pagetlef 22
EFTA00180942
A17
Probable Cause Affidavit
Palm Beach Police Department Agency °TUN PLO 500600
during the female on female intercourse and provide oral sex to both AB girds occurred during
the time All was sixteen years of age.
All advised this continued to escalate during two years. The routine became familiar to AH. Epstein's
assistant EN 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 AH to allow the acts to happen. All 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. All
explained that Epstein's penis was deformed. AR explained that his penis was oval shaped. AH claimed when
Epstein's penis was erect, it was thick toward the bottom but was thin ands he head portion. AN •
called Epstein's penis "egg-shaped." All stated Epstein would photograph and her naked and
having sex and proudly display the photographs within the home. H stated during one visit to Epstein's house
in which she provided a massage to Epstein, his female friend, was also present. AH
provided the massage in which Marcinkova and her would fondle each others breasts and kiss for Epstein to
enjoy. Towards the end of this massage, Epstein grabbed AH and turned her over onto her stomach on the
massage table and forcibly inserted his penis into her vagina. AH stated Epstein began to pump his penis in her
vagina. AH 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. Shc 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. AH 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 Epstein. Sheestated she was brought to the E
📷 Images in this document (102 detected; 6 largest described)
AI-generated factual descriptions of embedded images (llava:13b). These are searchable across the corpus.
[Image 1] The image shows a document that appears to be a letter or a form with various fields filled out. The document is partially obscured, with some sections cut off, making it difficult to read the entire content. The visible fields include a title or heading, a date, and a signature at the bottom. The text is too small and blurry to read the specific details of the document. The document is printed on
[Image 2] The image appears to be a document scan, specifically a letter or a form. The text is somewhat blurred, making it difficult to read the entire content. However, the visible parts suggest that it is an official document, possibly related to a legal or administrative matter. There are visible fields for names, dates, and possibly other details, but the specifics are not clear due to the quality of t
[Image 3] The image is a document scan, specifically a police report. It contains text detailing an incident that occurred on a specific date. The document includes the names of individuals involved, the date and time of the incident, and a description of the events that took place. The text is written in English and is structured in a formal, official manner typical of police reports.
[Image 4] The image shows a document with handwritten annotations. The document appears to be a page from a book or manual, with text and numbered points. The text is too small to read clearly, but the handwritten annotations include corrections or clarifications to the text. The annotations are made with a pen or marker, and they are written in a way that suggests the person is reviewing or editing the con
[Image 5] The image shows a document that appears to be a letter or a report. It is a scanned document with text and a signature at the bottom. The text is written in English and discusses a problematic situation involving a person named "Ms. Smith." The document mentions a "Ms. Smith" who was found to be in possession of a stolen item, and it refers to a "Ms. Smith" who was involved in a theft. The documen
[Image 6] The image shows a document with text, which appears to be a letter or a report. The document is titled "A12" and is addressed to "Palm Beach County Sheriff's Office." It mentions a "Probable Cause Affidavit" and includes a date and a signature at the bottom. The text is redacted, with black lines covering certain parts of the text, indicating that sensitive information is being withheld. The docum