MARTIN G. WEINBERG, P.C.
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
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DATE: July 22, 2011
SENDER: Jackie Perczek
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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.
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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:
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NUMBER OF PAGE$. INCLUOING THIS PAGE: _
COMMENTS: mtiikeititoRritt _
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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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