Epstein Secrets

CT OF FLORIDA IN RE GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY-63 and OLY-64 / FGJ 07-103(WPB) EX PARTE DECLARATION NUMBER TWO IN SUPPORT OF UNITED STATES' RESPONSE TO MOTION TO OUASH SUBPOENAS FILED UNDER SEAL EFTA00179184 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE GRAND JURY

uash Grand Jury Subpoenas and Cross-Motion to Compel ("Epstein Reply") at 5-8. 3 The government's effort at reductio ad absurdum is not well-taken. See United States' Surreply at 2 n.2. If the subpoenaed party's act ofproducing his mother's coffee cake recipe were potentially incriminating, then the act of produc

ny_info.Man 7/30/2007 EFTA00179203 Company Info Page 2 of 2 around the world. Mr. Kiraly works with numerous law firms and corporations within the United States and internationally on high profile, complicated litigation matters involving fraud, internal theft, asset location, and recovery as well as a broad

ed to escalate and occurred during two years. The routine became familiar to M. Epstein's assistant III would telephone her every time Epaein was in the Town of Palm Beach and would place appointments for her to visit and work for Epstein. = stated Epstein would photograph them naked and having sex and proudly displa

ly desires that result, whatever the likelihood of that result happening from his conduct." United Stalest Bailey, 444 U.S. 394, 404 (1980), quoting United States' United States Gypsum Co., 438 U.S. 422, 445 (1978).7 The Supreme Court has repeatedly interpreted this language to require that the illegal activity

to which the legislation is addressed. After all, it is a first principle that the Constitution creates a federal government of enumerated powers. See United States v.= 514 U.S. 549, 552 (1995) ("Just as the separation and independence of the coordinate branches of the Federal Government serve to prevent the a

****************** Reported By: R. 11/16/05 Entered By.: 11/17/05 On 10/20/2005, I assisted executing a search warrant at 358 El Brillo Way in the Town of Palm Beach, Palm Beach County Florida under the direction of affiant Detective Joe EFTA00176313 Date: 2/17/06 Time: 11:36:35 PALM BEACH POLICE DEPARTMENT

is was done to identify additional victims or witnesses. The analysis revealed that had called the victim/witnesses frequently when Epstein was in the Town of Palm Beach to "work." This confirms what the girls interviewed had previously stated. would notify them when Epstein was in town and their willingness to "wo

Criminal Justice System. The examiner has qualified an expert witness on numerous occasions in state and federalcourt, and was the polygraphist in United States'. Piccinonna [8B5 F2d 1539 (11th Cir. 1989)1, United States. . Luis Rodriguez (Uniteig States District Court, Southern District of Florida, case num

. daldat nanonal 061fn, ctiterksni), op, dlostdry. 'mu* of; untsUon a metal Malt Vieletlat Sawa Stres,acatly Its adaddultaidIrraedtatalittnuala in the Unitod States. Oro sEleelka SECRET Sdnedua, Desired: °Sul Tim (IC Tcnry 0 le:wary I Suntans &day Expected: "egitet V1-(1-fte"' Dab AvaWaa' CtuGS 4 1 acbc

ised this continued to escalate during two years. The routine became familiar tom Epstein's assistant would telephone her every time Epstein was in the Town of Palm Beach and would place appointments for her to visit and work for Epstein. Each time something new was introduced, additional monies were produced and off

en year old white female, hereinafter referred to asellladoballbnd her family reported unlawful sexual activity which occurred at a residence within the Town of Palm Beach. as reported that a subject known to her as "Jeff' had touched her vaginal area with a vibrator/massager while within his residence. "Jeff" was lat

1 of 7 EXHIBIT 37 EFTA00184577 Case 9:08-cv-80736-KAM Document 361-37 Entered on FLSD Docket 02/10/2016 Page 2 of 7 U.S. Department of Justice United Stales Attorney Southern District of Florida DELIVERY BY FACSIMILE Jay P. Lefkowitz, Esq. Kirkland & Ellis LIP Citigroup Center New York, New York 100

ustralian Ave., Suite 400 West Palm Beach, FL 33401 aesimt June 30, 2008 NOTIFICATION OF IDENTIFIED VICTIMS NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED STATES CODE, SECTION 3509(d) AND FLORIDA LAW, THE ATTACHED DOCUMENT IS TO BE TREATED AS CONFIDENTIAL AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTION WITH

MAN, JENNIFER R. 11/16/05 Entered By.: ALTOMARO, NICKIE A. 11/17/05 On 10/20/2005, I assisted executing a search warrant at 358 El Brillo Way in the Town of Palm Beach, Palm Beach County Florida under the direction of affiant Detective Joe Recarey. EFTA00184518 Case 9:08-cv-80736-KAM Document 361-34 Entered on F

t's unusual in this case is the chief of police not accepting the charged decisions made by the State Attorney, brought this investigation over to the United States Attorneys office. That's a first for you, isn't it? MS. ARBOUR: Form. THE WITNESS: There were many firsts in this case. BY MR. WEINBERG: • Q.

told all, I believe that 7 they were either a victimaitness to an investigation 8 that I was conducting about an individual that lived 9 within the Town of Palm Beach. 10 Q. When you met with Jane Doe 7 and spoke with 11 her, did she cry? 12 A. She was scared and she was nervous. We were 13 sitting -- the f

w that there were pages sent of the Page 510 1 correct? 2 MS. ARBOUR: Form. 3 THE WITNESS: f know that when there's 4 misdemeanor arrests in the Town of Palm Beach, a 5 lot of officers pretty much try to gain any 6 intelligence they can from any of the people that 7 they encounter. Some of the information

ax Name Model Name : Phaser 33001, SP NO. Name/Number StartTime Time Mode Page Result 211 07-21 02:07PM 00'25 ECM 002/002 O.K - • - United Stales Attorney's Office Southern District Of Florida 500 S. Australian Ave., West Palm Reach, VIL 33401-6235 DATE. 7 /21/loll TO: Dineati / /kwve n

ld white female, hereinafter referred to est." dob 05/13/1990, and her family reported unlawful sexual activity which occurred at a residence within the Town of Palm Beach. reported that a subject known to her as "Jeff" had t while within his residence. "Jeff' was later identified as Jeffrey Epstein through a photo li

this continued to evtalate during two years. The routine became familiar to Il. Epstein's assistant i would telephone her every time Epstein was in the Town of Palm Beach and would place appointments for her to visit ork for Epstein. Each timeisiething new was introduced, additional monies were produced and offered

Nacre NO. Name/Number : JUL-27-2011 03:01PM FLED : Phaser 33001.7P StartTime Time Mode Page Result 246 07-27 03:00PM 00'31 ECM 003/003 CLR United Slates Attorney's Unite Southern District of Florida 500 S. Australian Ave., Suite 400 West Palm Beach, IN. 33401-6235 DATE 7/42720c _area? WeavAatcit

urteen year old white female, hereinafter referred to as dob and ber family reported unlawful sexual activity which occurred at a residence within the Town of Palm Beach. reported that a subject known to her as "Jeff" had touched her vaginal area with a vibrator/massager while within his residence. "Jeff" was later

ised this continued to escalate during two years. The routine became familiar to. Epstein's assistant would telephone her every time Epstein was in the Town of Palm Beach and would place appointmen or her to visit and work for Epstein. Each time something new was introduced, additional monies were produced and offer

ss in Palm Beach County, Florida, and who committed the acts alleged within the jurisdiction of Palm Beach County, Florida, within the boundaries of the United States District Court in and for the Southern District of Florida. Defendant -is a natural person, who is an adult, believed to reside in the State of New

imes relevant to this action, a part time resident of Palm Beach County, Florida. All acts complained of herein occurred at his estate residence in the Town of Palm Beach, Florida. 8. Defendant EPSTEIN has a history of enticing young women, who are minors (under 18 years of age), and soliciting them to engage in pro

r offense includes, but is not limited to, a conviction by a federal or mititary tribimai, including courts-martial conductod by the Armed forces of the United Status, and includes a conviction or entry of a plea of guilty or mile contender* rosulting Ina sanction In any state of the United States or either juris

sed 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 off

ages will be evaluated by a jury who will provide their own methods of computation in an amount of at least the statutory minimum established by 18 U.S.C.A. § 2266. Discovery is ongoing. 11. List the names and business addresses of each physician (including psychiatrist, psychologist, chiropractor or

m each Police Department 345 South County Road Palm Beach. FL 33480 Tel: 20. Subject matter: Investigator. 21. supervisor Sat igatBureau of the Town of Palm Beach 3101 N.W. 16th Terrace Pompano Beach, FL 33064 Tel: (877) 46-WASTE Subject matter: The incident which is the subject matter of this lawsuit. Di