MARTIN G. WEINBERG, P.C.

EFTA00181217 Dataset 9 68 pages Download original PDF Download as text
MARTIN G. WEINBERG, P.C. ATTORNEY AT MW 20 PARK PLAZA, SUITE 1000 ROSTON, MASSACUUSEITS 02116 FAX NIGHT EAIERGRNCV: 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 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, avic )21i id Martin G. Weinberg cc: Roy Black EFTA00181217 07/22/2011 15:55 3053582006 BSKS PAC£ 02 20 PARK NAZI, WE IMO IIIISTON,MA$XACIIIITETIR 02716 FAX NI Aft NCY: • MARTIN C WEINBERG, P.C. ATTORNEY AT LAW 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. Villafafia: July 22, 2011 EAVAILADDREMS Roy Black forwarded to me your letter to hlm dated July 21, 2011, from the District Attomey 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, /roadc VV Martin G. Weinberg cc: Roy Black EFTA00181218 -n11 15:55 3053582006 B S K S PAGE 01 BLACK SPEBNICK KOPNSPAN STUMPF 111 TRIAL ATTORNEYS Email: Roy Black Howard M. Srebnick Scott A. Kornspan Larry A. Stumpf Maria Neyra Jackie Perczek Mark A.J. Shapiro Jared Lopez Marcos Beaton, Jr. Jessica Fonseca•Nader Kathleen P. Phillips Jenifer J. Soulikias Noah Fox Joshua Shore FACSIMILERANSMITTAL SHEET FAX: ( TELEPHONE: TO: AUSA RE: )oneni "DA, -ly-e DATE: July 22, 2011 SENDER: Jackie Perczek NO. OF PAGES (INCLUDING TRANSMITTAL SHEET): "IWO • MESSAGE: **IF YOU YOU DO NOT RECEIVE PAGES, PLEASE CALL ** THIS PACSEMILE CONTADIA PRIVD.E0ED AHD C0NPIDENTIAL INTORMATIONANTENOED OMIT .POR THE:lust .OP THE INDIVIDUAL OR ENTITY NAMED ABOVE. IP THE READER OP THIRPACSIMILE MINOT THEINIENDED RECWIESTibR THE EMPLOYEE OR AbENT RESPONSIBLE FOR-DELIVERING IT TO THE u frannotroanst You. Ant gain INYTInED THAT ANY erastiamarunt OR COPPING rep tuteradestas IS. STRICTLYPROHMITED.. 1 tr. tort newt ntektvw /Ws TACSIMME IN ERROR PLEASE ISIMEITTATIELTINOT/M/ERVTELEPHONE AND WISH THE ORIGINAL PACSIM/Lti TO VS. AT THE AIME ADDRESS VIA THE U.B. POSTAL SERVICE. 'THANK YOU. 201 S. Biscayne Boulevard, Suite 1300, Miami. Florida 33131 1 (P) 305-371-G421 1 (F) 305-358-20051www.ioybiack com EFTA00181219 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 "[i]f the United States receives a Freedom of Information Act request or any compulsory process"; the Agreement does not require Mr. Epstein's concurrence in any disclosure. Contrary to your suggestion, the Agreement (including paragraph 13) also does not make the Agreement itself "confidential." On the contrary, the Agreement expressly contemplates that disclosures of the Agreement may be made, and the Agreement further contemplates, contrary to your suggestion, that such disclosures of the Agreement may be made other than in response to "compulsory process." Here, moreover, the District Attorney of the County of New York, as a local law enforcement agency, has provided a legitimate request for disclosure of the requested information, as well as a promise to maintain the confidentiality of the information, particularly the names of the minor victims. Your objection pursuant to Federal Rule of Criminal 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 EFTA00181220 MARTIN WEINBERG, ESQ. JULY 27, 2011 PAGE 2 OF 2 the victim list to the District Attorney of the County of New York, we would be willing to consider those authorities before making any disclosure, provided that any such authorities are furnished to us before 5:00 p.m. on July 29, 2011. Otherwise, seeing no obstacle to the previously -planned disclosures, the Office will be disclosing copies of both the Non-Prosecution Agreement and the list of identified victims that was provided to Mr. Epstein to the District Attorney of the County of New York at 5:00 p.m. on July 29, 2011. Sincerely, Wifredo A. Ferrer cc: United States Attome By: Assistant United States Attorney Chief, Northern Division Deborah L. Morse, Assistant District Attorney, County of New York Roy Black, Esq. EFTA00181221 United States Attorney's Office Southern District of Florida 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401-6235 DATE: -1/47/20" TO: AiliVrpo 1tk/NfE ORGANIZATION: FAX #: SUBJECT: FROM: (Fax) NUMBER OF PAGES, INCLUDING THIS PAGE: COMMENTS: Original document: To follow via regular mail To follow via Federal Express To follow via hand delivery Nothirfto follow, FAX = original EFTA00181222 Fax Send Report Date/Time : JUL-27-2011 03:01PM WED Fax Number Fax Name Model Name : Phaser 3300MFP No. Name/Number StartTime Time Mode Page Result 246 07-27 03:00PM 00'31 ECM Mired Slates mionicy's Office Southern District of Florida SOS. Australian Ave., Sulk 400 Weal Palm Beach, F1.33101-6235 DATE• ligilEolt TO. analitkomAc§a_ ORGANIZATION: FAX II: GI 1 338-153i SUB.IFCT: Sat FROM: (Fax) NUMBER or PAGES. INCLUDING rtelS PAGE: 3 COMMENTS: Original document So follow VIA vegeta malt To We* via Federal Express. To Inflow vie hand delivery Nothing% loiknv. FAX r reigned 003/003 0.K EFTA00181223 United States Attorney's Office Southern District of Florida 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401-6235 DATE: 7(2.7/ao TO: be-60'al Ms-,se ORGANIZATION: /vets FAX ti: SUBJECT: FROM: ork. bc.strief Ailarrvit oP6rA (Fax) NUMBER OF PAGES, INCLUDING THIS PAGE: 3 COMMENTS: Original document: To follow via regular mail To follow via Federal Express To follow via hand delivery X Nothinno follow, FAX = original EFTA00181224 Fax Send Report Date/Time f JUL-27-2011 03:03PM WED Fax Number Fax Name Model Name Phaser 3300MFP No. Name/Number StartTime Tine Mode 247 07-27 03:01PM 00'57 ECM United States Attorney's Were Southern District of Marina 500 S. Australia,' Ave., Suite 400 West Palm Beach, P1.33401-6235 OA1E :747/10.a 1O: T ethink &se_ ORGANIZATION: Ns FAX a: SUBJECT . . e — — -- FROM: (roil — — — — — NUMBER OF PAGE$. INCLUOING THIS PAGE: _ COMMENTS: mtiikeititoRritt _ 0bigineldowment --- To Sow Via mourn. mai) 70 loNow rya Fettered EePrOn ro fellow wed bond nohoory A _ NottAnrioloArAv. FAX n Otigeistai Page Result 003/003 a R EFTA00181225 U.S. Department of Justice United States Attorney Southern District of Florida SOO 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 B Assistant United States Attorney cc: , Chief, Northern Division Deborah L. Morse, Assistant District Attorney, County of New York EFTA00181226 United States Attorney's Office Southern District of Florida 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401-6235 DATE: 772_/40 TO: )1Izinth /407-se ORGANIZATION: FAX SUBJECT: FROM: ibt.qicki. A (Fax) NUMBER OF PAGES, INCLUDING THIS PAGE: Z COMMENTS: Original document: xTo follow via regular mail To follow via Federal Express To follow via hand delivery Nothirrto follow, FAX = original EFTA00181227 Fax Send Report Date/Time : JUL-21-2011 02:08PM THU Fax Number Fax Name Model Name Phaser 3300MFP No. Name/Number StartTime Time Mode Page Result 211 07-21 02:07PM 00'25 ECM 002/002 0.1( I Inked Stales Attorney's Office Southern District of Florida 500 S. Australian Ave., Suite 400 West Palm Reach, 33401.6235 ORGANILAIION . FAX S: SUBJECT - FROM. NUMBER OF PAGES. INCLUDING THIS PA COMMENTS: Onginal dot:Innen,. EFTA00181228 2123359288 Fax; DISTRICT ATTORNEY Jul 17 2011 10:15pm P001/002 CYRUS R. VANCE, JR. OSTRICT ArnCRPC Date: To: Fax: From: Tel #: OF THE COUNTY OF NEW YORK ONE HOGAN PLACE Now York, N. Y. 10013 APPEALS BUREAU FAX DOCUMENT COVERSHEET FAX # Z6, /?z on 5,4 lane 141/47;44 t # of Pages 2- (includes cover sheet) ❑ URGENT ❑ ROUTINE ❑ Deliver Immediately o Discuss with Appropriate Person(s) ❑ As Requested o For Your Approval ❑ Review and Comment o Take Necessary Action o For Your Information o Reply Via FAX ❑ File o Reply Via Messenger ❑ Reply Directly o Progress Report ❑ Investigate o Let's Discuss ❑ Prepare Reply for Signature ❑ Other Action To Be Taken/Additional Comments: EFTA00181229 2123359288 Fax: Jul 17 2011 10:15pa P002/002 DISTRICT ATTORNEY OF THE COUNTY OF NEW YORK ONE HOGAN PLACE New York, N. Y. 10013 CYRUS R. VANCE, JR, DISTRICT ATTOPMIY July 15, 2O11 EIMI, Esq. ',tent United States Attorney Office of the United States Attorney Southern District of Florida 5OO S. Australian Avenue Suite 4OO West Palm Beach, Florida 334O1 Dear Ms.MI, 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 Assistant District Attorney EFTA00181230 U.S. Department of Justice United States Attorney Southern District of Florida 500 S. Australian Ave, Ste 400 fr, FL 33401 Facsimile: DELIVERY BY ELECTRONIC MAIL Roy Black, Esq. Black Srebnick Kornspan & Stumpf P.A. 201 S. Biscayne Blvd, Suite 1300 Miami, FL 33131 Re: Jeffrey Epstein Dear Mr. Black: July 21, 2011 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 nited States Attorn ssistantUnited SCates ttorney cc: , Chief, Northern Division Deborah L. Morse, Assistant District Attorney, County of New York EFTA00181231 DISTRICT ATTORNEY OF THE COUNTY OF NEW YORK ONE HOGAN PLACE Now York N. Y. 10013 CYRUS R. VANCE, JR. 0:STRICT ATTORNEY 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 thoseiroceedings. If we furnish the minutes to the appellate court, we would do under seal for the purpose of an in camera review. Please let me know if you need any further information in order to make the materials available. I appreciate your assistance, and courtesy, in this matter. Yours truly, Deborah L. Morse Assista t District Attorney EFTA00181232 DISTRICT ATTORNEY OF THE COUNTY OF NEW YORK ONE HOGAN PLACE New York, N. Y. 10013 CYRUS R. VANCE, JR. CI:STRICT ATTORNEY 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, (44.e /-C__) Deborah L. Morse Assistant District Attorney EFTA00181233 New York County Clerk's Index No. 30129/2010 Nye 1' Ink *inane (&mrt APPELLATE DIVISION -FIRST DEPARTMENT I, 14 I PEOPLE OF THE STATE OF NEW YORK, —against— JEFFREY E. EPsTEmr, Respondent, Defendant -Appellant. APPENDIX CYRUS R. VANCE, JR. NEW Yon( COUNTY DISTRICT ATTORNEY'S OFFICE One Hogan Place New Yor New York 10013 Attorneys for Respondent JAY P. LEFKOWITZ SANDRA LYNN Mustmen KIRKLAND & Rt us LLP 601 Lexington Avenue New York. New York 10022 Attorneys for Defendant -Appellant REPRODUCED ON RECYCLED PAPER EFTA00181234 TABLE OF CONTENTS PAGE Appellant's Pre-Argument Statement, dated February 9, 2011 Al Appellant's Notice of Appeal, dated February 9, 2011 A3 Order Appealed From, dated January 18, 2011 with Notice of Entry A4 Palm Beach Police Department - Probable Cause Affidavit of Det. - Defendant dated May 1, 2006 A6 Palm Beach Sheriffs Office Booking Card for Jeffrey Epstein, dated July 23, 2006 A28 2006 Grand Jury Indictment of Felony Solicitation of Prostitution - Jeffrey E. Epstein A29 Information for Procuring Person under 18 for Prostitution - Jeffrey E. Epstein, dated June 26, 2008 A31 Guilty Plea for Felony Solicitation of Prostitution and Procuring Person under 18 for Prostitution - Jeffrey E. Epstein, dated June 30, 2008 A32 Judgment for Procuring Person under 18 for Prostitution - Jeffrey E. Epstein, dated June 30, 2008 A33 Sentence for Procuring Person under 18 for Prostitution - Jeffrey E. Epstein, dated June 30, 2008 A34 Community Control Standard Conditions, dated June 30, 2008 A35 Palm Beach Sheriffs Office Booking Card for Jeffrey Epstein, dated June 30, 2008 A47 EFTA00181235 UI 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 EFTA00181236 Al Appellant's Pre-Argument Statement, dated February 9, 2011 [pp. Al-A21 SUPREME COURT FOR THE STATE OF NEW YORK COUNTY OF NEW YORK PEOPLE OF THE STATE OF NEW YORK, Plaintiff-Respondent, - against - JEFFREY E. EPSTEIN, Defendant -Appellant. Index No.: 30129-2010 • PRE-ARGUMENT STATEMENT 1. TITLE OF ACTION: As set forth in caption. 2. FULL NAMES OF ORIGINAL PARTIES AND ANY CHANGE IN THE PARTIES: As set forth in caption. There has been no change in the parties. 3. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR APPELLANT OR PETITIONER: Jay P. Lefkowitz, P.C. Sandra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New Ynrk 10022-4611 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, NY 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 EFTA00181237 A3 Appellant's Notice of Appeal, dated February 9, 2011 SUPREME COURT FOR THE STATE OF NEW YORK COUNTY OF NEW YORK THE PEOPLE OF THE STATE OF NEW YORK, Plaintiff, - against - JEFFREY E. EPSTEIN, Defendant. NOTICE OF APPEAL Index No. 30129-2010 CRIMINAL TERM PART 66 JUSTICE RUTH PICKHOLZ PLEASE TAKE NOTICE that the above named defendant, Jeffrey E. Epstein, hereby appeals to the Appellate Division of the New York Supreme Court in and for the First •'.." Department, from an order entered in the above entitled action in the office of the Clerk of New York County on the 18th day of January 2011, which order adjudged defendant Jeffrey E. Epstein to be a Level 3 sexual offender pursuant to Article 6-C of the Correction Law, and this appeal is taken from each and every part of that order as well as from the whole thereof. Dated: February 9, 2011 To: Clerk, New York County Cyrus R. Vance, Jr. NEW YORK DISTRICT ATTORNEY'S OFFICE One Hogan Place New York, NY Telephone: Lefkowitz, P.C. dra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, Ne Telephone: Facsimile: Y. Attorneys for Defendant JeffreyE. EV a E FEB 09 201 RUPRIEME COURT NEW YORK COUPCY APPRALVI, EFTA00181238 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 ATIORNEY'S OFFICE One Hogan Place New York, NY Telephone: Ja . Lefkowitz, P.C. Sandra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, Neill611 Telephone: Facsimile: Attorneys for Defendant Jeffiey E. Epstein Pit ED FEB 0.9 zon aupni.,-pony -mecca, apps.,.._Ycnvic cou itr toir uneuku EFTA00181239 A7 Probable Cause Affidavit Palm Beach Police Department Agency arm FLO 500600 conversation occurred between she should say she was eighteen. t was later con y the that on February 6, 2005. According to father, drove a pick up truck. t if Jeff asked her age, . picked his daughter up . described Epstein's house as a two-story pink house with a Cadillac Escalade park 'n the i driveway. She recalled that Jeffs house was on a dead end street. Upon arriving at the house stated that they walked up a driveway ast what appeared to be a small guard/security room. A male approaching them asking what they wanted. stated they were there to see Epstein. The male allowed them to continue walking up to the house. stated the man told them that Epstein was not there but was expected back. He allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside. Shortly thereafter, Epstein and his assistant, described as white femile with blond hair and later identified as entered the kitchen. Epstein Introduced himself to M.. described Epstein as being approximately forty-five years old, having a long face and bushy eyebrows, with graying hair. and Epstein left the kitchen leaving. alone in the kitchen. They returned a short time later. They 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 larelathroom 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 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. to take off her clothes.. stated Epstein was stem when lictpld her to take off her clothes.. said she did not know what to do as she was the onl one there in the room I 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 Olen anties on. Epstein than instructed her to give him a massage poi to a specific ive Epstein the massage, c Epstein was specific in his instruction to her on how to massage g her to go clockwise or counter clockwise. Epstein then turned over and instructed to masse c his p rig on the ground and resumed massaging Epstein's chest area. stated Epstein. as she massaged his chest and shoulder area. Epstein then hunt 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 day of May, 2006 by bet , who is personally known to mc. State of Florida oun of Palm B itch gnatur g Officer Date: 05 006 Page 2of 22 EFTA00181240 A9 Probable Cause Affidavit Palm Beach Police Department Agency OTWO PLO 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 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. Dutiiihimassage, stated "He tried to touch me and I stonier) him." I asked how he tried to touch her. stated that Epstein and she felt uncomfortable, told Epstein, I'll massage you but I don't want to be touched. stated she performed the massage naked. At the conclusion of the massage; Epstein paid $200. After the massage Epstein stated to that he understood she was not comfortable, but lie would pay her If she brought over some girls. hIe 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: " ' , • . ( a16 year old female), (a 16 year old through 16 years of age. I asked Robson which one was the youngest. said that at the time she brought these girls Epstein's house they were a1/14 female) and advised. was the youngest as she was fourteen when the massage occurred. stated every girl she brought know 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 wore made to bring her to Epstein's house on a weekend. stated that she and .__ (Later identified as 7:e. ) picked up. at her house. stated that at that time she was driving a red pickup truck. They traveled to E st ' ' 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. fed. upstairs and Epstein wont 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. Shc had changed her cellular number to avoid being contacted by... She continued stating that she had no direct contact with Epstein The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Oct who is personally known to me. Signature of Police ffice (F. . 117. State of Florida Coun of Palm Beach Sign/Ito g Officer Date: 05/01/2006 ragetlof 22 EFTA00181241 Probable Cause Affidcrvil Palm Beach Police Department Agency ORE it PLO SOOT OO for Jeff. She was told she would have toprovide a massage to Jeft stated upon her arrival to the house . she was brought to the kitchen area by . They met with the house chef who was alreadishe kitchen area statedlilla would wait for her in the kitchen. . was introduced to Jeff's assistant, who brought her upstairs to the master bedroom. El prepared the room and massage table for a massage. Epstein entered the room wearing only a towel and she provided a massage. • ": stated she kc t her clothes on during the massage. She advised sometime during the massage, Epstein and pulled her close to him. T ._.: 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 re lied no. I asked her if= received any monies for taking her to perform the massage. stated had received money for taking her there but was unsure in the amount. 7 Ic 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 eel! phone. A voice mail message on October 4, 2005 at 10:59 am, revealed a female voice who identified herself asIM who requested : to c I 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 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 . thencalled Jeff and and asked what was going on reference the ongoing police investigation. Accotding to 7.. , 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 Ootober4, 2005, I made telephone contact with who had left several messages for me to contact her. During the message, site 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 3:4/Jprn I made telephone contact with During a taped recorded statement, stated the folloWing: approximately a year ago, when she was sixteen years of age, took her to Epstein's house twice. She knows because they both attend Royal Pal Beach High School. The first time she went, drove to the house. They entered through the kitchen area where she was The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by . bet who is personally known to me. Signature of Police Meer F.S.S. 117.10) Signatur r g Officer State of Florida of Palm Beach Date: 05/01/2006 Page Leif 22 EFTA00181242 A13 Probable Cause Affidavit Palm Beach Police Department Agency WON FLO 500600 table, straddling Epstein to massage his back. While doing this 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 band movements going up and down on his penis area. 7... • • did not want to look at his penis area because she was.uncomfortable. Epstein removed a lar e white vibrator which was next to the massa e table and turned it on. L.: L. stated Epstein began Shortly thereafter, Epstein ejaculated and removed himself from the table. e walked over to w sere 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 staled 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, hut knows it was close to $400.00. stated she never returned to provide a nvm.sage for Epstein. At approximately 2:10 pm, Det and I met with dob =, at her residence. M 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 wasnot a suspect. I explained the possibility of her being either a witness or victim. advised she wanted to cooperate and consented to the interview. During a sworn taped statement, September 2Sie was approached by associates of and knew the same people. Beach High School, what scheduled the appointment. did for Epe2In. picked . up and drove her to Palm Beach to a street called "Brillo Way". They drove to the end of the street and entered a large drivewa . The entered the kitchen area of the house and met with Epstein. was introduced to Jeff Epstein. led upstairs to the main bedroom area and set up the room with a massage table and set out the oils. stated tut while going up the stairs and into the bedroom shobserved numerous photographs of naked young girls. dimmed the lights and turned on soft music. exited the room and Epstein entered the room wearing only a towel. Epstein picked oils and instructed her to rub his legs, under his buttocks, back and chest area Epstein asked her to get comfortable. advised she did not remove her clothes. She was wearing tight jeans and a cropped tank top ex osing her be y i area. During the massage, Epstein removed his towel and laid on the massage table naked. As rubbed Bps • 's chest area, he attempted to reach down her par> touch her buttocks area however was unable to • e to the tightness of the ' • ' belt. advised Epstein began to masturbate as she Epstein moaned as she . She o served he was continuing to masturbate and stated the following: at the age of sixteen, during the month of for a chance to make money. was friends with had been previously told by her friends from Royal Palm called a person known to ■ as and The foregoing instrument was sworn to or affirmed befoaarstigat day of May, .2006 by Det who is personally known to me. Signature of Police facer c.S.S. 117.10) State of Florida County of Palm Beach Siguatur Officer Date: 05/01/2006 Page8of 22 EFTA00181243 A 1 5 Probable Cause Affidavit Palm Beach Police Department Agency ORIN PLO 500600 • Epstein wanted to be rubbed on his back and recently he be an ' g over and have her rub his chest as he masturbated. He would fry to touch as she . 1...._ stated "Jeff would try to get away with more and more on each massage". .1•:: stated would try to touch her more and on one occasion he attempted to use a massager/vibrator on her. ME droVe - to the house for the original massage. C. her cell phone number and every time stein would come into town, would call her for an appointment to "work". Each time she went, would meet her at the kitchen door area. She would bring her upstairs and re are the massage table..:: advised stein would ask her questiOns about herself. Epstein knew she was a and would be attending . I asked : if Epstein knew her real age. tstated Epstein did and didn't care. The most recent massage she provided was on October 1, 2005. Dun massage, she asked Epstein if she could borrow one of his vehicles to visit her faniily and boyfriend in , Florida. Epstein had told her she could borrow one of his vehicles but ater stated he would rent her a car. She continued with the massage as Epstein and I . asked ' • if she was wearing undergarments to which she replied her thong underwear. Once he tried to touch , 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 toe 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 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 MEM Gym field. I asked her if she ever took any one to the house. explained she took L. p friend of hers who attended Royal Palm Beach High School, who has relocated to to attend college. I asked if she ever allowed another female in the room. . iadvised no one was brought into the room with her. At the conclusion of the`interview, Det and I went to the gym area o 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 Banasiaek, later learned to be Epstein's houseman, and paid with Epstein's credit rand. On September 11, 2005, wife, dob 12/30/1986, 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 Co..t 'am Bench Det , who is personally known to me. Signature of Poll e Officer (F.S.S. 117.10) State of Florida Signatur Officer Date: 05/01/2006 Pagcl0of 22 EFTA00181244 A17 Probable Cause Affidavit Palm Beach Police Department Agency OR it FLO 5006D0 during the female on female intercourse and provide oral sex to hot. and rtis occurred during the time. was sixteen years of age. advised this continued to escalate during two years. The routine became familiar toe Epstein's assistant would telephone her every time Epstein was in the Town of Palm Beach and would place appointments for her to visit and work for Epstein. Each tune something new was introduced, additional monies were produced and offered fore to allow the acts to happen. consented to perform' these acts but was adamant that there was an understanding with E stein 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. AJI called Epstein's penis "egg-shaped." • stated Epstein would photo phi...and her naked and having sex and proudly display the photographs within the home. in which she provided a masse e to E stein, his•female friend provided the massage in which and her would enjoy. Towards the end of this massage, Epstein grabbed massage table and stated during one visit to Epstein's house was also Eresent. If for Epstein to and turned her over onto her stomach on the ■ stated Epstein began to became upset over this. She said her head was being held against the table She screamed "No I" and Epstein stopped. She told him that she did not want to have his penis inside of her. Epstein did not talulate 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 Me, 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. Shirstated she was brought to the Epstein house in March of 2005. , a classmate at Royal Palm Beach Hi School, approached her and asked her If she wanted to "work". ; made the arrangements with, Epstein's assistant. who has no formal training in providing massages, stated she provided a massage, fully clothed for $200.00. As I sensed hesitancy in her answers, I asked if she bad been contacted by anyone from Epstein's organizations or his house. stated she was interviewed already by a private investigator for stein. He identified himself as "Paul". and inquired about the police investigation, and left his telephone number for additional contact. • provided no additional information, as it appeared her responses were almost scripted. The foregoing Instrument was sworn to or affirmed before me this day of May, 2006 by Pet , who Is personally known to me. mpSignature of Police facer .S.S. 117.10) State of Florida Court of Palm Signature Date: 05/01/2006 eh g Officer Page Ilef 22 EFTA00181245 •••• • tj • 4.0“.....# I ma. Probable Cause Affidavit Palm Beach Police Department Agency ogler FLO 500600 attending Royal Palm Beach High School... would approach females who wished to work for Epstein. • stated she was offered to work for Epstein but declined. explained that "work" means 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. I further stated she had been to the house approximate) 4 or 5 times in the past year. She accompanied= with la, and . .. Each time the girls were taken over, they were previously told they wottki 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 tho house. On November 8, 2005, at approximately 2:00pm , I met with dob 'MI, at the • Palm Beach Police Department. During a sworn taped statement stated she had met Epstein approximately two ears ago when she was first approached by a classmate at Royal Palm Beach school. approached her about working for Epstein and providing a massage to him for $200.00. bad made the arrangements however was unable to take her the day the arrangements were made. had take , • also attended Royal Palm Beach High School and was familiar with Epstein. , recalled she was 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. ;gated 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 eventual) removed her clothes and sta ed in her thou anties. On occasion Epstein would stated she had been to the house The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Oct , who is personally known to me. Signature of Police Officer r.S.S. 117.10) State of Florida Coun of Paint Beach Date: 05/0112006 Pagettiof 22 EFTA00181246 A21--- • Probable Cause Affidavit Palm Beach Pollee Department Agency ORtW PLO 500600 • as ;fated • brought her into the house and she was introduced to then brought her upstairs into a master bathroom, located within the bedroom. statedlinet 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 dives 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 MEM 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. • Toted it was not until the third time that she went that she removed her clothing. stated she was notified by Illithat providing the massage when Epstein asked her to remove her clothing. • temoiller pants, shirt and Epstein wanted her to come to work. She arrived at the house and was led upstairs by She started bra. She sta ed in her thong panties and continued rubbing Epstein. Epstein turned over onto his back and she 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 ho 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 l5, 2005, Det. and T met with dab During a sworn taped statement, stated she met Jeffrey Epstein over a year ago. She was sixteen years of age and was approached by , a fellow Royal Palm Beach High School student, who informed her that she could make $200.00 providing a massage to Epstein. had informed her that she would have to provide this The foregoing instrument was sworn to or affirmed State of Florida before me this 1" day of May, 2006 by Co bet who is personally known to me. Signatu g Officer Signature of PolirtOfficer .5.8. 117.10) Date: 05/01/2006 Pagel4of 22 EFTA00181247 A23 Probable Cause Affidavit Palm Beach Police Department Agency ORM PLO 500600 During the course of the investigation a search wax-rant 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 perforatectedge 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 tl e • e messages were, "1 have girls for him" or "I have 2 girls for him." These messages were taken by who signed the bottom oficia messages. During the execution of the warrant, I located a Royal Palm Beach High School transcript for . in Epstein's bedroom desk. This desk had stationary marked Jeffrey E Epstein. I located a wood colored armoire beside Epstein's bed that contained a bottle of "Joy Jelly," which is used to provide a warm massage. SeVeral massage tables were located throughout the second floor of the residence, including a massage table found in Epstein's bedroom. On the first floor of the residence I found two covert cameras hidden within clocks. One was located in the garage and the other located in the library area on a shelf behind Epstein's desk. A computer was located which was believed to contain the images from the covert cameras. The computer's bard drive was reviewer' which showed several images of and other witnesses that have been interviewe

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[Image 1] The image appears to be a scanned document, possibly a letter or a form, with text and signatures. The text is too small to read clearly, but it seems to be a formal document with sections for recipient information, sender information, and possibly a description or purpose of the document. There is a visible signature at the bottom, indicating that the document has been signed by an individual. Th [Image 2] The image shows a document that appears to be a community standard operating procedures manual. It contains a list of numbered items, which seem to be guidelines or rules for a specific community or organization. The document is marked with handwritten annotations, including corrections and notes, suggesting it is a draft or a working document. The text is too small to read in detail, but the docu [Image 3] The image shows a document with text, which appears to be a police report or a similar official document. The text is partially obscured by black rectangles, indicating that certain information has been redacted or censored. The visible text includes the title "PALM BEACH POLICE DEPARTMENT" and a reference number "A29". The document is dated "12/05/06" and is signed by a person whose name is redac [Image 4] The image shows a document that appears to be a police report or incident report. It contains text that describes an incident involving a person named "Elizabeth." The document includes details such as the date and time of the incident, the location, and the actions taken by the police. There are also sections for the names of the involved parties, descriptions of the incident, and any evidence or [Image 5] The image shows a document with text that has been redacted, likely to protect sensitive information. The document appears to be a form or a letter, as indicated by the header and footer. The visible text includes a date and a signature line, but the content of the document is obscured by black rectangles covering the text. The document is titled "A/17," which suggests it might be a form or letter [Image 6] The image shows a document with text that has been redacted, meaning certain parts of the text have been blacked out to conceal information. The document appears to be a form or a letter, but the specific type of document is not clear due to the redactions. The visible text includes a date, a name, and a signature, but the details are obscured. The document is titled "POLICE DEPARTMENT," which sug