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le- is registered to Dollar Rent a Oaf- out of the Palin Beach'International Airpoi t The velucjewyas m by Janusz: Banasiac^. .later learned to' .be; Epsteinis lioiis.pnian, and paid with Epstem’sBfedi'^ On.'September 11..200 5jjW/f^R4ob;^MH^^;was arrestedby.the,PalmBeachBbli(^;^ The foregoing instrument w a
want-State Attorney x Fifteenth.Judicial Circiiit of the State Florida , prosecuting for the; said ^&-o0>utYCiWK ' ‘State. ’ GRAND JURY FOREPERSON *1 Jeffrey E. Epstein, Race:White, Sexi Male, DOB: SS#: t IssueWarrant CA/Aronberg-000761 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A C
&-o0>utYCiWK ' ‘State. ’ GRAND JURY FOREPERSON *1 Jeffrey E. Epstein, Race:White, Sexi Male, DOB: SS#: t Issu
erg-000777 R:. AtEXANDERACOSTA UNITED s:r'.iTESATI◊R.NEY • A. :MARIE VILLAFANA AssfsTANT fos .• ATTQ~N-tY ·OERALi;:>.L13FCbUJ{t;:ESQ: C0VNSELTQ JEFFREY EJJ,SJEJN LiLLY ANN'SANCIJ~Z; isQ'. NFTORNEY FQR J½FFREY EPSTEIN FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM tBytsign
criminal act 18 for prostitution in.a home. But: it appears, from 19 this information here that these two girls were paid 2 0 for-sexual contact with Mr:,Epstein, at least" 21 .according to what Detective Recarey investigated. 22 Were there any additional 2-3 investigations ongoing regarding allegations of 24
told every one of these girls that they could sue Mr. Epstein for money, and I was not comfortable with that, I
Independent of 1 7 What might b~ iil' tl1etepq[t. 18 A No, noMhrit I can recall. 19 Q Page 87, last page .. Middle ofthe page 20 refotences: Epsteill's corporation attoniey,_,a 21 ·gentleman bythename:ofDarren'Indyke, l-NcD 0 Y-K-E 22 D9 you, ~ee thai?, 2 3 A Not yet. Okay, yes. 2 4 Q Do y
n the kitchen of the house. She was also introduced to a white female known to her as Sarah. She was led upstairs to the main bedroom known to her as Jeff Epstein’s bedroom. Sarah arranged the massage table and covered the table with a sheet. She brought out the massage oils and laid them next to the massage bed.
tbaUJ-i¢re \V3S· ?I~ ,i.friderit~11Q,ihg'\vitli'.Epsteirl'Jh~tr10 Vctgihal penefrat iqit:\YOU.IQ OC-CUr;_\\.,itll,his periis ... - 'CXRl?Ji1~cJ: Q1at Epsteifr's pe/1is ;\\'as de'for-hie~, @8explc1in~eci Q1at,b\~ :p~his.was, oval s"haJ1eq· .•••. cl?imed \\1~e1;. --·, Epsteih'sipeilis: ,,,as,efe~t;,i twas'th
2:22:44 PM NOT A CERTIFIED COPY . ' .Entered on FLSD Docl<et 03./21/2011 P~e. 2. of 15 ., f-,t€ 71 [Att I~ . I ' ~ INRE: INVESTIGATION OF JE~YEPStEIN' ----------................. --~' N_QN~PROSECJJDON AGREEMENT IT APPEARING that {h_e ~!ty 6~ P~lz? Beach Police Department i and th~ State
ILLY ANN SA'Nqmz, ESQ. -- - - ATTORNEY FOR. JEPFR.EY EPSTEIN Page 12 ot1s FILED: PALM BEACH COUNTY, FL, JOSE
. _ __ , ■ ' . ■ - - . . ’ ■" ' GERALD LEFCOURT, ESQ. COWSEL.TOIEFFREyE^^ Dated; .7,-: — ■... / .. . .... . ■ . .. . sErcuy^mSANCHEZ^^^ rATTORNEY FOR JEFFREYEPSTEIN CA/Aronberg-000784 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • , , . ,By:signirl'g'tlifs,&d~
ted a vast network of underage victlms for him to sexually, exploit, .oft.en or, a dailY, l:>asis; in locations including New Yqrk c1ng Palm Beach. EPSJEIN's victims were as young as. 14 at the tim_e he abused them, and were, .for various reasons, often particularly vu Iner.able to exploitation·. Moreov
fternoon everyday he was in residence. Rodriguez stated he would be informed to expect someone and make them comfortable until either Sarah Kellen or Epsteiri wo <he masseuses would amve. he area and offer them something to dnnk or eat. They would then be encountered by either Sarah Kellen or Epstein They w
as evidence. See Fed! R. Crim. P. 11(f) (“The admissibility or inadmissibility of a plea, a plea discussion, and any related statement is governed by Federal Rule of Evidence 410.”). In any case, the victims could have been impeached regarding the possibility' of their obtaining monetary damages through either a ci
tness an individual ("Employee-1") who worked for Jeffrey Epstein immediately 35 EFTA00088837 followin
osed testimony concerns the experience of manipulated and coerced victims, rather than the intentions of perpetrators. 19 EFTA00088821 return to Epstein's home for sexual abuse, or why some occasionally expressed affection for the defendant and Epstein. Although Dr. will not testify about these spe
consideration of the Court's pretrial order denying the defense's motion to strike Minor Victim-3 from the Indictment. Evidence of the defendant and Jeffrey Epstein's abuse of Minor Victim-3 is direct evidence of the offense charged in the Indictment, including the overt acts in the Indictment that pertain to Mino
elationship between the defendant and Epstein. For instance, to the extent the defense at trial argues that the defendant was merely an employee of Epstein's, this photograph is evidence to the contrary. Sixth, the defense argues that Government Exhibit 606 lacks evidentiary foundation, is hearsay, and i
hallenge. "Although the Government did not present 71 EFTA00088873 evidence regarding the circumstances surrounding the seizure of the USB drive, Federal Rule of Evidence 901(b)(4) permits authentication based on Mlle appearance, contents, substance, internal patterns, or other distinctive characteristics of t
y Lefkowitz in Support of Their Motion for a Protective Order Concerning Production, Use, and Disclosure of Plea Negotiations (Doc. 161); Intervenor Jeffrey Epstein's Motion for a Protective Order and Opposition to Motions of Jane Doe 1 and Jane Doe 2 for Production, Use, and Disclosure of Plea Negotiations (Doc.
ecutors in the Southern District of Florida made with the specific purpose of obtaining a favorable resolution of the criminal investigation of Mr. Epstein through attorney-to-attorney settlement negotiations. In determining whether to grant a stay pending appeal, the Court is to consider four factors:
rs Roy Black, Martin Weinberg, Jay Lefkowitz, and Jeffrey Epstein hereby request that this Honorable Court
continuing exchanges of letters and memos where Mr. Epstein's counsel addressed the reasons why Mr. Epstein s
led to obtain those materials in discovery in the first instance. That question must be answered by reference to Fed. R. Civ. P. 26, which refers to Federal Rule of Evidence 501, which "empower[s] the federal courts to `continue the evolutionary development of [evidentiary] privileges!" Adkins v. Christie, 488 F.
of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid, in
specifics of the victim interviews. The FBI reports memorializing each interview primarily addressed the facts elicited from the victim regarding Epstein’s abuse and did not describe any discussion about the status of the case or the victim’s view about the prosecution of Epstein.433 When asked w
Six, to-wit: The Grand Jurors of the State of Florida, inquiring in and for the body of said County of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid, in the Circuit and State aforesaid, COUNT ONE FELONY SOLICITATION OF PROSTITUTION on or about or between t
of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid, i
evidence. See Fed. R. Crim. P. 11(f) (“The admissibility or inadmissibility of a plea, a plea discussion, and any related statement is governed by Federal Rule of Evidence 410.”). In any case, the victims could have been impeached regarding the possibility of their obtaining monetary damages through either a c
dditional "Know Your Customer" records for Jeffrey Epstein-affiliated accounts (labeled DB-SDNY-0002515 through 0002894), and account statements for Jeffrey Epstein's custody account (labeled DB-SDNY-0001711 through 0002514). The decryption password for the production will be provided by separate email. As we hav
ditional "Know Your Customer" records for Jeffrey Epstein-affiliated accounts (labeled DB-SDNY-0002515 thr
rtain additional "Know Your Customer" records for Jeffrey Epstein-affiliated accounts (labeled DB-SDNY-000
cing these materials pursuant to a grand jury subpoena, it is our understanding that this production will be treated as confidential consistent with Federal Rule of Criminal Procedure 6(e). Notwithstanding the confidentiality of the enclosed materials and information, should you receive any request for disclosure
remaining sealed materials. I. BACKGROUND A. Jeffrey Epstein's Conviction and the CVRA Suit The origins of this
Jeffrey Epstein's Conviction and the CVRA Suit The origins of this case lie in a decade-old criminal proceeding against financier Jeffrey Epstein ("Epstein"). On June 30, 2008, Epstein pleaded guilty to Florida state charges of soliciting, and procuring a person under the age of eighteen for, prostitut
remaining sealed materials. I. BACKGROUND A. Jeffrey Epstein's Conviction and the CVRA Suit The origi
t court's decision whether to discharge or retain a Receiver); see also FTC. v. Standard Fin. Mgmt. Corp., 830 F.2d 404, 409 (1st Cir. 1987) (citing Federal Rule of Evidence 401's "having any tendency" definition of relevance in determining whether documents were "judicial documents"). 1' As we explain below, th
cifically, the enclosed documents—labeled DB-SDNY-0001289 through 0001710—include account opening documentation for certain accounts associated with Jeffrey Epstein. The decryption password for the production will be provided by separate email. As we have discussed, we continue to collect relevant information re
ion for certain accounts associated with Jeffrey Epstein. The decryption password for the production will
ocumentation for certain accounts associated with Jeffrey Epstein. The decryption password for the product
cing these materials pursuant to a grand jury subpoena, it is our understanding that this production will be treated as confidential consistent with Federal Rule of Criminal Procedure 6(e). Notwithstanding the confidentiality of the enclosed materials and information, should you receive any request for disclosure
nsive to items 3 and 16 of the Subpoena. Specifically, the production contains account statements, labeled DB-SDNY-008310 through 0012674, for seven Jeffrey Epstein- controlled brokerage accounts. The production also contains ten currency transaction reports ("CTRs") filed in connection with cash withdra
trolled brokerage accounts. The production also contains ten currency transaction reports ("CTRs") filed in connection with cash withdrawals made by Jeffrey Epstein's associates, Darren Indyke and Harry Beller. The CURs are labeled DB-SDNY-0012675 through 00012727. The decryption password for the production will
DB-SDNY-008310 through 0012674, for seven Jeffrey Epstein- controlled brokerage accounts. The production al
cing these materials pursuant to a grand jury subpoena, it is our understanding that this production will be treated as confidential consistent with Federal Rule of Criminal Procedure 6(e). Notwithstanding the confidentiality of the enclosed materials and information, should you receive any request for disclosure
ments responsive to item 12 of the Subpoena. Specifically, the production contains check images for approximately twenty bank accounts controlled by Jeffrey Epstein and/or Epstein's close associates, labeled DB-SDNY-00 12728 through 00016251. The decryption password for the production will be provided by separa
m 12 of the Subpoena. Specifically, the production contains check images for approximately twenty bank accounts controlled by Jeffrey Epstein and/or Epstein's close associates, labeled DB-SDNY-00 12728 through 00016251. The decryption password for the production will be provided by separate email. As we
approximately twenty bank accounts controlled by Jeffrey Epstein and/or Epstein's close associates, label
cing these materials pursuant to a grand jury subpoena, it is our understanding that this production will be treated as confidential consistent with Federal Rule of Criminal Procedure 6(e). Notwithstanding the confidentiality of the enclosed materials and information, should you receive any request for disclosure
gh 5, 7, 17, IS, 23, 24 and 27 of the Subpoena. Specifically: • Included at DB-SDNY-0000479 through 0000504 are additional KYC records related to Epstein-affiliated accounts; and • Included at DB-SDNY-0000505 through 0001288 are documents related to Epstein- affiliated accounts, including account ope
cing these materials pursuant to a grand jury subpoena, it is our understanding that this production will be treated as confidential consistent with Federal Rule of Criminal Procedure 6(e). Notwithstanding the confidentiality of the enclosed materials and information, should you receive any request for disclosure
Entities connected to both Jeffrey Epstein and Federal Rule of
Darren Indyke
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Jes Staley
PERSON
Prince Charles
PERSONSouthern District
LOCATIONJane Doe
PERSON
Barry Diller
PERSON
Department of Justice
ORGANIZATIONMartin Weinberg
PERSON
Alfredo Rodriguez
PERSON
Kenneth Marra
PERSON
Julie K. Brown
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATION