TAB | HOUSE_OVERSIGHT_012197

U.S. Department of Justice United States Attorney Southern District of Florida First Assistant U.S. Attorney 7 99 N.E. 4 Street Miami, FL 33132 (305) 961-9100 DELIVERY BY FACSIMILE May 19, 2008 Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP Citigroup Center 153 East 53rd Street New York, New York 10022-4675 Re: Jeffrey Epstein Dear Mr. Lefkowitz, I am in receipt of your e-mail dated May 19, 2008 to the United States Attorney. The U.S. Attomey would like me to advise you that all communications and inquiries related to the Epstein matter, will be handled by AUSA Marie Villafana and/or her supervisor, Karen Atkinson, so he does not intend to respond to your e-mail or calls unless AUSA Villafana and/or her supetvisors advise him otherwise. Furthermore, you make reference to “our July 8 deadline.” Respectfully, the United _ States.Attorney’s Office for the Southern District of Florida (“SDFL”) has never agreed to any such deadline. Should you decide to provide the SDFL with any additional information, please do so through AUSA Villafana, and, in her absence, AUSA Atkinson. On September 24, 2007, your client, Jeffrey Epstein, in consultation with Gerald Lefcourt, Esq. and Lilly Ann Sanchez, Esq., as well as numerous other nationally-renowned lawyers, including but not limited to Harvard Law Professor Alan Dershowitz, former Independent Counsel and Solicitor General of the United States Kenneth Starr, just to name a few, entered into a global resolution of state and federal liabilities faced by your client (“the Agreement”) with the SDFL. Although you and other members of the défense team have since claimed that the Agreement was the product of adhesion, the following facts demonstrate that Epstein knowingly and voluntarily entered into the Agreement in order to avoid a federal indictment regarding his sexual conduct involving minor victims. Despite the fact that by signing the Agreement, Epstein gave up the right to object to its provisions, the SDFL bent over backwards to exhaustively consider and re-consider your objections. Since these objections have finally been exhausted and Epstein has previously expressed his intent to not comply with several of the terms and conditions of the Agreement as set forth below, the SDFL hereby notifies you that unless he complies with all of the terms and conditions of the Agreement, as modified by the United States Attorney’s December 19, 2007 letter to Ms. Sanchez by close of business on Monday, June 2, 2008, the SDFL will elect to terminate the Agreement. HOUSE_OVERSIGHT_012198

_ Jay P. LEFKOWITz, Esq. May 19, 2008 PAGE 2 OF 6 Background _ The Agreement was the product of months of negotiations. Specifically, you requested and received numerous meetings, at the highest levels of the SDFL and DOJ’s Child Exploitation and Obscenity Section (CEOS) concerning claims that (a) the investigation merely produced evidence of telatively innocuous sexual conduct with some minors who, unbeknownst to Epstein, misrepresented their ages; (b) the authorities investigating Epstein engaged in misconduct; (c) the contemplated federal statutes have no applicability to this matter; and (d) the federal authorities disregarded the fundamental policy against federal intervention with state criminal proceedings. Aftercareful review, the SDFL ultimately rejected those claims. Subsequent to its decision, however, but before proceeding any further, the SDFL provided you with 30 days to appeal the decision to the Assistant Attorney General of the United States, Alice Fisher. As you recall, you chose to forego an appeal to AAG Fisher, and instead pursued a negotiated resolution which, ultimately, resulted in the _ execution of the Agreement. The Negotiation Phase During negotiations, you tried to avoid a resolution that called for incarceration and registration as a sexual offender — both of which would be triggered by a successful federal prosecution. The SDFL believed and continues to believe that should this matter proceed to trial, your client would be convicted of the federal statutes identified in the Agreement. In order to achieve a global resolution, the SDFL indicated a willingness to defer to the State the length of incarceration; however, it remained adamant that Epstein register as a sex offender and that all victims identified during the investigation remain eligible for compensation. In order to achieve this result, the parties considered two alternatives, a plea to federal charges that limited Epstein’s sentencing exposure, or, as suggested by you, a plea to state charges encompassing Epstein’s conduct. Ultimately, the parties agreed to, inter alia, a plea to the state charges outlined in the Agreement, registration and a method of compensation. The Agreement The crux of the Agreement defers in favor of the State federal prosecution of Epstein for his sexual conduct involving those minor victims identified as of September 24, 2007, in exchange for a guilty plea to a state-offense that requires registration as a sex offender; a sufficient term of imprisonment; and a method of compensation for the victims such that they would be placed in the same position as if Epstein had been convicted of one of the enumerated offenses set forth in Title 18, United States Code, Section 2255. Specifically, the Agreement mandates, inter alia, (1) a guilty plea in Palm Beach County Circuit Court to solicitation of prostitution (F1. Stat. Section 796.07) and procurement of minors to engage in prostitution (FI. Stat. Section 796.03) (an offense that requires him to register as a sex offender); (2) a 30-month sentence including 18 months’ incarceration in county jail; (3) a methodology to compensate the victims identified by the United States; (4) entry HOUSE_OVERSIGHT_012199

a JAY P. LEFKOWITZ, ESQ. May 19, 2008 PAGE 3 OF 6 of the guilty plea and sentence no later than October 26, 2007; and (5) the start of the above- mentioned sentence no later than January 4, 2008. Furthermore, and significantly, Epstein agreed that he had the burden of ensuring compliance of the Agreement with the Palm Beach County State Attorney’s Office and the Judge of the 15 Judicial Circuit and “that the failure to do so will be a breach of the agreement” (emphasis added). Post-Execution of the Agreement Within weeks of the execution of the Agreement, you sought to delay the entry of Epstein’s guilty plea and sentence. After the SDFL agreed to accommodate your requést, counse/ for Epstein began taking issue with the methodology of compensation, notification to the victims, and the issues that had been previously considered and rejected during negotiations, i.e., that the conduct does not require registration and the contemplated state and federal statutes have no applicability to the instant matter. , A. Delay. The Agreement required that “Epstein shall use his best efforts to enter his guilty plea and be sentenced not later than October 26, 2007. The United States has no objection to Epstein self- reporting to begin serving his sentence not later than January 4, 2008.” Agreement, pages 4-5, paragraph | 1 (emphasis added). After the Agreement was executed, the SDFL accommodated your request to extend the October 26th plea deadline to November 20" based upon, what seemed to be, reasonable scheduling conflict issues.' By early November, you represented that the presiding state court judge would not “stagger the plea and sentencing as contemplated in the Agreement.” Although the Agreement clearly did not contemplate a staggered “plea and sentencing,” the SDFL again agreed to accommodate Epstein’s request to appear in state court for plea and sentencing on January 4, 2008.” t “Accordingly, I have now confirmed with Mr. Epstein's Florida counsel that the state's attorney's office and the court will be available to have him enter his plea on November 20. So we will plan to proceed on one that date.” October 18, 2007 email from Jay Lefkowitz to USA R. Alexander Acosta. ° On the same day, Mr. Lefkowitz confirmed with First Assistant Jeffrey H. Sloman that this postponement “ will not affect when Epstein begins serving his sentence.” Correspondence from Jay Lefkowitz to FAUSA Sloman dated November 8, 2007 (“the judge has invited the parties to appear for the plea and sentencing on January 4", we do not anticipate any delay beyond that date.”) HOUSE_OVERSIGHT_012200

JAY P. LEFKOWITZ, Esq. May 19, 2008 PAGE 4 OF 6 B. Method of Compensation and Notification. During this same time period, you and others, including the former Solicitor General of the United States Kenneth Starr, took issue with the implementation of the methodology of compensation (hereinafter “the 2255 provision”)’ and the SDFL’s intention to notify the victims under 18 U.S.C. Section 3771 (you objected to victims being notified of time and place of Epstein’s state court sentencing hearing). In response, the SDFL offered, in my opinion, numerous and various reasonable modifications and accommodations which ultimately resulted in United States Attorney R. Alexander Acosta’s December 19, 2007 letter to Lilly Ann Sanchez. In that letter, the United States Attorney tried to eliminate all concerns which, quite frankly, the SDFL was not obligated to address, let alone consider. He proposed the following language regarding the 2255 provision: “Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” Regarding the issue of notice to the victims, USA Acosta proposed to notify them of the federal resolution as required by law; however, “[w]e will defer to the discretion of the State Attomey regarding whether he wishes to provide victims with notice of the state proceedings, although we will provide him with the information necessary to do so if he wishes.” As you know, _ you rejected these proposals as well. See December 26, 2007 correspondence from J ay Lefkowitz to USA Acosta. . ? Prior to any issues arising concerning the implementation of the 2255 provision, the SDFL unilaterally agreed to assign its responsibility to select the attorney representative for the alleged victims to an independent third-party. This was done to avoid even the appearance of favoritism in the selection of the attorney representative. As a result, on October 29, 2007, the parties executed an Addendum wherein it was mutually agreed that former United States District Court Judge Edward B: Davis would serve as the independent third-party. Judge Davis selected the venerable law firm of Podhurst and Josefsberg to represent the approximately 34 alleged identified victims. HOUSE_OVERSIGHT_012201

JAY P. LEFKOWITZ, ESQ. May 19, 2008 PAGE 5 OF 6 C. “Mr. Epstein Does Not Believe He Is Guilty Of The Federal Charges Enumerated Under Section 2255.” At our December 14, 2007 meeting at the U.S. Attorney’s Office in Miami, counsel for Epstein announced, inter alia, that it was a “profound injustice” to require Epstein to register as a sex offender and reiterated that no federal crime, especially 18 U.S.C. Section 2422(b), had been committed since the statute is only violated if a telephone or means of interstate commerce is used to do the persuading or inducing. This particular attack on this statute had been previously raised and thoroughly considered and rejected by the SDFL and CEOS prior to the execution of the Agreement. You also argued that the facts were inapplicable to the contemplated state statutes and that Epstein should not have been allowed to have been induced into the Agreement because the facts were not "what he understood them to be. It should be noted that the SDFL.has never provided you with any evidence supporting its investigation. This is not, and has never been, an Alford plea situation (see North Carolina v. Alford, 400 U.S. 25, 91 S.Ct. 160 (1970)). Ultimately, you requested an independent review. Subsequent to the above-mentioned meeting, the SDFL received three letters from you and/or Mr. Starr which expanded on some of the themes announced in the December 14” meeting. Essentially, you portrayed the SDFL as trying to coerce’a plea to unknown allegations and incoherent theories. On December 17, 2007, you decreed that Epstein’s conduct did not meet the requirements of solicitation of minors to engage in prostitution (FI. Stat. Section 796.03) one of the enumerated crimes Epstein had previously agreed to plead guilty to; that Epstein’s conduct does not require registration under Florida law; and the State Attorney’s Office does not believe the conduct is registrable. On December 21, 2007, you rejected the USA’s proposed resolution of the 2255 provision because you “strongly believe that the provable conduct of Mr. Epstein with respect to these individuals fails to satisfy the requisite elements of either 18 U.S.C. Section[s] 2422(b) ... or .-. 2423(b).” In your December 26, 2007 correspondence you stated that “we have reiterated in previous submissions that Mr. Epstein does not believe he is guilty of the federal charges enumerated under section 2255” and requiring “Mr. Epstein to in essence admit guilt, though he believes he did not commit the requisite offense.” As the SDFL has reiterated time and time again, it does not want, nor does it expect, Epstein " to plead guilty to a charge he does not believe he committed. As a result, we obliged your request for an independent de novo review of the investigation and facilitated such a review at the highest levels of the Department of Justice. It is our understanding that that independent review is now complete and a determination has been made that there are no impediments to a federal prosecution by the SDFL. HOUSE_OVERSIGHT_012202

JAY P. LEFKOWITz, Esq. May 19, 2008 PAGE 6 OF 6 Conclusion On February 25, 2008, I sent-you an e-mail setting forth a timetable for moving forward in the event that CEOS disagreed with your position. That time is now. As you know, my February 25" email stated that I would give you one week to comply with the terms and conditions of the Agreement, as modified by the USA’s December 19" letter to Ms. Sanchez. In light of the upcoming Memorial Day weekend, I have decided to extend that timetable to the close of business on Monday, June 2, 2008, which is a full two weeks. Sincerely, R. Alexander Acosta United States Attorney By: ae Jeffrey H: Sloman First Assistant United States Attorney ce: . R. Alexander Acosta United States Attorney A. Marie Villafana Assistant U.S. Attorney Karen Atkinson Assistant U.S. Attorney HOUSE_OVERSIGHT_012203

TAB 2 HOUSE_OVERSIGHT_012204

a ° “ é \ 11/05/2007 11:26 FAX 11/05/07 MON 10:05 FAX 305 530 6449 EXECUTIVE OFFICE U.S. Department of Justice United States Attorney Southern District of Florida UNITED STATES ATTORNEY'S OFFICE SOUTHERN DISTRICT OF FLORIDA 99 NE 4™ STREET MIAMI], FLORIDA 33132-2111 Jeffrey H, Sloman First Assistant U.S, Attorney 305 961 9299 Cyndee Campas Stalf Assistant 305 961 9461 305 530-6444 fax FACSIMILE TRANSMISSION COVER SHEET DATE: November 5, 2007 TO: Jay Lefkowitz, Esquire FAX NUMBER: (212) 446 4900 SUBJECT: Jeffrey Epstein NUMBER OF PAGES, INCLUDING THIS PACE: 3 Message/Comments: This facsimile contains FRIVILEGED AND CONFIDENTIAL INFORMATION intended only for the use of the Addressee(s) named above. Ifyuu are not the intended tecipicnt of this facsimile, or the employe or agent responsible for delivering it to the intended Técipleat, you are hereby notified that any disscrhination or coping of this facsimile is strintly prohibited. Ifyou have received this fhosimile in error, please immediatel y notify us by telephone and return the onyonal facsimile to us at the above address vig the U.S, Postal Service, Thank you, HOUSE_OVERSIGHT_012205 001/003

002/003 11/05/2007 11:27 FAX a etapa p pata 11/05/07 MON 10:05 FAX $05 530 6440 EXECUTIVE OFFICE United States Attorney Southern District of Florida 99 NLC. 2" Street Miami, FL §3742.2132 (305) 963-9299 Fausimile: (308) 5306dd4 November 5, 2007 Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP Citigroup Center 153 Bast 53rd Street New York, New York 10022-4675 Re: Jaffrey Epstein Dear Jay; Several things have come to my attention that Seem contrary to your client intending ta abide by his obligations uder the Non-Prosecution A ereement. As you know, that agreement requires our Office to inform you of potential breaches to give you and your client the opportunity to respond before an indictment is filed. At this tire, I do not believe that the agreement has been breached; however, I have sufficient concerns that need to be addressed, First, understand that private investigators working for Mr. Epstein have contacted victims to ask them whether any detectives or FBI agents have discussed a financial settlement with them, On one occasion, the private investigators told the parent of a victim that she should get an attorney for her daughter and she should do so right away. These actions are troublesome because the FRI agents legally are required to advise the victims of the resolution of the matter, which includes informing them that, as part of the resolution, that Mr, Epstein has agreed to pay damages in some circumstances. Furthetmore, Mr, Epstein well knows that we are in the process of selecting an attorney to represent the vietims and, but for the inordinate amount of time spent negotiating the Addendum, that attorney would already have been selected, Paragraph 7 of the Non-Prosecution Agreement explicitly provides that contact with the victims shall be through that counsel, Accordingly, please confirm that there will ba no further efforts to contact any victims until Judge Davis selects the attomey representative and that, thereafter, contact will be made only through that counsel. Second, the Non-Prosecution Agreement requires Mr, Epstein to use his best efforts to enter his guilty plea and to be sentenced not later than October 26, 2007, Despite this obligation, the Oifice agreed that My, Epstein could postpone this deadline to November, but reiterated that My. HOUSE_OVERSIGHT_012206 idoos

003/003 11/05/2007 11:27 FAX ; ; ; A1/05/707 MON 10:06 FAX 305 530 6440 EXECUTIVE OFFICE NOVEMBER 5, 2007 PAGE 2 OF 2 =pstein iad to begin his term of incarceration not later than January 4, 2008, Thave learned that the November hearing has been removed from the calendar and the next case disposition conference hag not been set until Jamnary 7, 2008. This delay is unacceptable, and, pursuant to your obligations, the Office requests that you confer with the State Attorney’s Office to try to find a date in November when the judge is available to conduct a simultaneous plea and sentencing. Ifyou cannot find such a date, please provide documentation of your efforts to abide by the terms of the Non-Prosecution Agreement, Third, there have been several press reports that Mr. Epstein no longer intends to enter a guilty plea. Normally 1 would not Pay any attention to such reports, but your recent correspondence attempting to restrict our Offlee from communicating with the State Attormey’s Office and the allusion to the imposition of sentences that vlearly fall outside the terms of the Non-Prosecution Agreement raises concer. Please confirm that Mr. Epstein intends to abide by hig agreement to plead guilty to the specified charges and to make a binding recommendation that the Court impose a sentence of 18 months of cuntinuous confinement in the county jail, Finally, the Non-Prosecution Agreenient requires that you provide the Office with copics of all proposed agreements with the State Attomey’s Office before Mr. Epstein signs any such aercements. To date, no such agreements have been received. Please provide me with copies ofany and all agreements with the State Attomey’s Office for our review. The Office also would like to have someone present at the change of plea and sentencing to monitor Mr. Epstcin's compliance with the terms of the Non-Prosecution Agreement, $0 please keep me informed of the date, time, and location of the hearing, Please provide me with a written response, adopted by Mr. Epstein, addressing these concerns and reiterating Mr, Epstein’s intention to comply with the terms ol the Non-Prosecution Agreement by November 8, 2007, Sincerely, R, Alexander Acosta United States Attomey Jeffrey Sloman First Assistant United States Attorney ee! R, Alexander Acosta, U.S. Attomey AUSA A. Marie Villafaia HOUSE_OVERSIGHT_012207 Id) 063

TAB 3 HOUSE_OVERSIGHT_012208

TOLL RECORDS OF SARAH KELLEN’S CALLS e MR. EPSTEIN DID NOT KNOW WHO WOULD BE COMING TO GIVE HIM A MASSAGE. Wednesday, April 27, 2005 Wednesday, April 27, 2005 Wednesday, April 27, 2005 Wednesday, April 27, 2005 Wednesday, April 27, 2005 Wednesday, April 27, 2005 Thursday, May 05, 2005 Thursday, May 05, 2005 Thursday, May 05, 2005 Thursday, May 05, 2005 Thursday, May 05, 2005 Friday, May 06, 2005 Friday, May 06, 2005 Friday, May 06, 2005 Friday, May 06, 2005 Friday, May 06, 2005 Friday, May 06, 2005 Friday, May 06, 2005 Friday, May 06, 2005 Saturday, May 07, 2005 Saturday, May 07, 2005 Sunday, May 08, 2005 Sunday, May 08, 2005 Sunday, May 08, 2005 Sunday, May 08, 2005 9:02AM 9:03AM 12:14PM 12:15PM 3:16PM 3:20PM 3:28PM 8:43PM 8:48PM 9:13PM 10:03PM 8:30AM 8:59AM 9:33AM 9:34AM 9:35AM 10:58AM 5:35PM 7:50PM 11:03AM 11:04AM 11:39AM 12:28PM 3:20PM 3:21PM * Mr. Rofrano is Mr. Epstein’s chiropractor. (561) 635- 3454 (561) 801- 3590 (561) 714- 0546 (561) 714- 0546 (561) 309- 0079 (561) 309- 0079 (561) 644- 3713 (561) 644- 3713 (561) 644- 3713 (561) 644- 3713 (561) 644- 3713 (561) 389- 6874 (561) 644- 3713 (561) 714- 0546 (561) 389- (561) 644- 3713 (561) 644- 3713 (561) 644- 3713 (561) 644- 3713 (561) 389- 6874 (561) 262- 6186 (561) 684- 6642 (561) 262- 6186 (561) 262- 6186 HOUSE_OVERSIGHT_012209

e MR. EPSTEIN DID NOT TARGET ANY ONE PARTICULAR INDIVIDUAL, NOR DID HE TARGET MINORS. ALL OF THE CALLS BELOW WERE MADE TO WOMEN OVER THE AGE OF 18. Saturday, July 02, 2005 Saturday, July 02, 2005 Saturday, July 02, 2005 Saturday, July 02, 2005 Saturday, July 02, 2005 Saturday, July 02, 2005 Saturday, July 02, 2005 Saturday, July 02, 2005 Saturday, July 02, 2005 Saturday, July 02, 2005 Saturday, July 02, 2005 Saturday, July 02, 2005 Sunday, July 03, 2005 Sunday, July 03, 2005 Sunday, July 03, 2005 Sunday, September 18, 2005 Sunday, September 18, 2005 Sunday, September 18, 2005 Sunday, September 18, 2005 Sunday, September 18, 2005 Sunday, September 18, 2005 Sunday, September 18, 2005 Sunday, September 18, 2005 Sunday, September 18, 2005 Sunday, September 18, 2005 Sunday, September 18, 2005 9:50AM 11:33AM 11:54AM 12:03PM 1:49PM 3:21PM 3:22PM 3:58PM 4:10PM 4:11PM 6:20PM 9:25PM 1:14PM 1:44PM 9:57PM 9:58AM 9:59AM 9:59AM 10:02AM 10:04AM 10:44AM 1:10PM 4:10PM 5:17PM 9:36PM 9:45PM (561) 389- 6874 (561) 635- 3454 (561) 856- 2974 (561) 635- 3454 (561) 324- 7996 (561) 324- 7996 (561) 635- 3454 (561) 324- 7996 (561) 262- 6186 (561) 635- 3454 (561) 302- 1844 (561) 389- 6874 (561) 324- 7996 (561) 574- (561) 714- 0546 (561) 324- 7996 (561) 635- 3454 (561) 801- 3590 (561) 662- 3098 (561) 302- 1844 (561) 389- 6874 (561) 389- 6874 (561) 324- 7996 (561) 714- 0546 (561) 714- 0546 HOUSE_OVERSIGHT_012210

TAB 4 HOUSE_OVERSIGHT_012211

N 10 11 12 13 18 19 20 21 22 23 MP: Detective Michele Pagan KB: MP: Kathy Back |.D. #8059, reference case number 05-368. The time now, by my watch, is approximately 6 minutes past 2pm on 3/15/05. (Inaudible) High Ridge Family Center, Sable Palm School. > Just High Ridge Family Center. Okay, the High Ridge Family Center. Present also is...could you state your name please? MP: Spell your name please? MP: And your daie of birth? MP: And you are? Cathy Back, Family Therapist. Could you spell your name please? K-A-T-H-Y B-A-C-K, And you're her family therapist? Arm | correct? Yes. Okay. I'm here today anc | have stated briefly why {'m here is in reference to an incident that happened to a friend of yours, or a girl you knaw. Page tof 43 HOUSE_OVERSIGHT_012212 OS8

NS 10 11 12 12. 14 15 16 17 18 19 20 21 2S MP: MP: MP: ES EE MP: MP: i 0 0 MP: !'m not sure if she’s friend of yours or net, by the name im Do you Know what I'm talking about? Yes. Okay. ! hear your voice got very low al! of a sudden so if you don't mind.. Oh, okay. "ll even hold it. Okay. Can you tell me how you know, She’s my ex-boyfriend's cousin. And what's your ex-boyfriend's name? Zack is that his last name? J? Yes. What schcol does he go to? {inaudible} Summit Christian School. And you said he’s your ex-boyfriend. How long ago was that? | don't know. Like two months, two months and a half ago. Hew long did you go out with him? Three weeks...? Not tong? AndfP You met her through Zack? Yeah, | met her when { went to dinner at his grandmother's house. Okay. And do you know a: last name? No. |} don't. Do you know where she lives? Yes. She lives on ER streets away from me. Page Zof 43 OSn9 HOUSE_OVERSIGHT_012213

oe 14 18 16 18 19 20 ho RO NO res) MP: MP: Okay, (maudible) Okay. And tell me now what happened with a Okay, well, the third time of hanging out with i cause | was a cousin, well, fF And we were over there watching a movie and this guy called or actually it was a woman but it was for a guy. i. nd then we went, | don't know what day it was cause she picked me up. I’m pretty sure it was a Saturday or a Sunday. So she picked me up and we get in the car and she (inaudible) and then we left and we were still driving and then we went to his house and we were waiting in the kitchen and the old man came and he's like, hello, 'm...1 don't even know, | think it's Jeff. I'm Jeff and then we, I'm like I'm] And then she um went upstairs and | guess gave him money and we went back downstairs we weren't there, we were only there for tike 30 minutes and then we left and Page 3 of 43 09120 HOUSE_OVERSIGHT_012214

a 10 41 12 MP: MP: MP: MP: MP: MP: | MP: MP: (D then she went to go to Marshall's to go get some, a skirt and a purse but sh didn't get the skirt. She only ended up getting the purse and that was like a black purse. That's alt that happened? Um hm. Well, I’m hearing a lot more happened. Like what, | know, jike what went around the school? Like what went around the school. Tejl me what happened at school. In school, everybody was saying thai} got paid $300 with the, for the old man. That old guy. Cause he’s....ch, first of all, is that | gct fingered by the old man, then it was | had sex with the old man and then it was I'm just a prostitutc and | got paid $300. Who was spreading these rumors araund? Um, my, this girl, she used to be my friend] but | guess... Where would she get .... From Zack because | broke up with him. Well, that's what | think. | think when | broke up with him, he got very mad and told the gir! cause this girl, she hated mo because | wer out him and she likes him. Which girl was this? a ME hiked Zack? Yeah. ...went out with him so she started spreading these rumors? Page 4 of 43 05121 HOUSE_OVERSIGHT_012215

> 10 11 12 13 14 =" oO 17 19 20 21 22 23 p Cause | went out to the fair and she was supposed to go with him but, | guess, he didn’t like her and then we started talking and she got mad because | was talking to him. . MP: What does...can you lell me more aboullgP S| t don't really know that much. All! know is that she, the only thing | know about her is that her boyfriend, but then they broke up, like, she met him at a party. That's the only thing | know and that she has brown hair and like, | don’t really know about her. | went to her house Cnaudible) MP: Are you telling me?...and | want you te know something, okay? a Um hm. MP: Regardless of what has happened, okay? t'm being very honest. You're not in trouble for anything. | | I know. MP: Whether you did something with this man or net. Hmr.... MP: Whether you did something with this man. What I'm trying to do is fird out if this type of thing is going on and you're not the only one and | don't think you are the only one. | | [ don’t think so either cause the other kid Anthony {inaudible} he knows | Pee and |, cause he’s telling me, he’s like where do you knowlilend then | was like she’s my boyfriend's cousin. Oh that girl's bad and !'m like okay, too bad. MP: Did you do anything with this man? p No, we went upstairs and just got money and t don't know... Page 5o0f 43 05122 HOUSE_OVERSIGHT_012216

ho Cw 2 13 14 16 17 18 19 20 21 | | And there's like little circle chairs, that you can sit on. MP: MP: MP: MP: MP: Stools. Stools. And we were just sitting there waiting cause he wasn't there yet. Then he came inside after we were standing there about 5 minutes. Cause like, there was a gate and a bodyguard guy. When we opened the gate and knocked on the door, security, some guy, like a bodyguard kind of, type of guy. Same an walked up and he’s like, excuse me, what are you here for and we're here to see Jeff. And then he was okay, well come inside, Jeffll be here in like 5 minutes. And then we waited and he was like you can help yourself to a drink. And then he left anc then like 2 minutes after the guy left, Jeff and a lady walked in and they introduced themselves and we're like, hi, my name is and then she's tike IE inaudible) and then there's likc a walk in door thing, that you walk in like a cabinet thing, not a cabinet but the island thing (inaudible) and then the door would be right there. Okay. Yeah, (inaudible} So they walked away out of your sight? Lm hm. Well there was another girl there. | was never by myself. | don’t remember the girl's name but she's is friend. Okay. she was is... What does da you have an idea of what, why this woman, this assistant, would ask 7 | had anybody with her? Page 7 of 43 03123 HOUSE_OVERSIGHT_012217

10 1 12 13 14 15 16 7 18 19 20 21 22 23 MP: MP: MP: MP: MP: MP: 1 don't know but what you call, the lady, she really like (inaudible) | don’t know what's wrong. | mean when she walked in, she was like kind of like, | don’t know, but she was just like, um, she couldn't say anything about her, she was just first name and that's it and then she was just like right to the point.. She didn’t try to be friendly, you know. What do you mean she didn't try to be friendly? She wasn't like hi, I'm like, you know (inaudible) she was just like hi, I'm and | don’t remember her name but she said she was from | remember that. And your friend, ors friend stayed in the car? No, she was with us. When we walked in, and she sat, she was just there, she didn't do anything, she was with me. We were just right at the table, like we were sitting having a conversation for like two seconds. Ther came back downstairs and then she’s like thanks Jeff and then I'm like bye Jeff and then the other girl was like bye and then we left. Okay, did ce you what was going on upstairs? No. She just, | didn't ask because ike tne only reason | know the money was to go shopping. That's what (inaudible). Did she give you any money? Um hr. How much money? $300. What did you do with the $3007? | didn't spend it. And then | went to school and then my principal, cause | got Page 8 of 43 Q5124 HOUSE_OVERSIGHT_012218

as V7 18 19 20 21 22 23 MP: MP: MP: MP: into a fight with a girl, a. for saying that. Because she said that | was, had done all that with the old man to get that money and that’s nottrue. That's why | gol really angry and then we (inaudible) before that and then when | went to the office to (inaudible) the principal but actually she didn't say anything at first and then she was ike Sto her side of the story, can! see your purse and | was like go ahead and (inaudible) and I'm like yes and then my dad, my dad and the principal and my step-mom, they were all like um, why did you do that with an old man and who is the old man. I'l kill him, blah, blah, blah. And then I was like 1 didn't do anything! | didn't do anything! And they didn’t believe me. And | kind of got mad at and then the whole thing, that’s when | moved back to my mom's house because my dad thought | was a prostitute. And it was really... You know that just because something may have happened, that doesn’t make you a prostitute. I know. Do you? Yes. Okay. Do you want something to drink? No. Are you sure? Yeah, You know, !'ve been doing this for a long time and {’m not saying you're not telling me the truth, | think you're not telling me the whole truth about what happened. Okay? Matter of fact, | know you're not. And I know you might be a Page 9 of 43 05125 HOUSE_OVERSIGHT_012219

10 4 12 16 17 18 ag 29 2 22 23 MP: MP: KB: MP: MP: MP: little afraia looking on it... Okay, |... (inaudible) because they already came ta my dad’s house and they did something to my dad's tires and my dad almost died. Okay. Give me your hand. I’m here to help you. Look at me. i don’t want him to get hurt because he already almost killed him. i'm here to help you. Honey, I'm gonna get you some water. Okay? Okay. I'm here to help you, okay? I’m being honest, okay? I’m going to be very up front but | need you to be up front with me, okay? Okay. The only way | can help you is if you're honest with me, a hundred percent honest with me. Okay. Your counselor's not here. Tell me what happened. Now be honest about it. Okay. When | got there, that Jeff guy and the lady were there and then the lady wanted me to come upstairs and she’s like, she's talking to me and then she was putting out a table like for a massage. And then um, and then when and then she like put the covers on the table and they like, it comes to like (inaudible) whatever and she’s like, oh Jeff will be up in a second. And then the Jeff guy got there, she was like, she was like, take off your clothes and I didn’t know what to do because | was the only ane up there and so | just took off my shirt and | was in a bra and then he came in and had a towel over him and he was like no, take Page 10 af 43 05126 HOUSE_OVERSIGHT_012220

14 15 16 17 18 MP: MP: KB: off everything. So | just took off my pants and | was in my bra and underwear and he was like now you're gorina give me a massage. Then he went on the table and he's like here, the lady that was putting down the table, got out three lotions and put them on the table and then he picked up out which jotion. He was like, give me a massage with this lotion and then | was giving him a massage and he said you can get on my back. So he was on the table and | was straddling him on his back and giving him a massage and then he was turning around and then he whacked off and then he’s like oh yau have a really hot body and then | was like, that's disgusting, but | didn’t say that and then he’s like oh, excuse me for a second and he, | guess he went into the other room and he whacked off again and then he came back and said to me like, I’m done. And then he’s like, here’s your money and then | was going downstairs and he acted all nice and stuff, he’s like bye, nice to meet you, hope you can come back again and therlfis tike how did it go, what did you do. And ’m like, P'm like, he made me give him a massage end she’s like, fknow. And then we went to Marshall's and she got a purse and stuff cause she got paid too but |, she didn't do anything, | don't think because she was downstairs the whole time whije she knew | was up there. When she asked you to go with her... Um hm.... ..did you know...here’s your water. Thank you. (inaudible) Page 11 of 43 05127 HOUSE_OVERSIGHT_012221

—_s Lox) 10 14 12 16 17 18 19 20 21 22 | | Okay. Bye. (Inaudible) KB: Um, you know what (Inaudible), I'm gonna down to the dorm. She knows how to find me. MP: Okay. You feel better without her here? Yeah, because I'm embarrassed cause it’s really gross and she.... MP: Itis. MP: MP: MP: MP: ..might tell my mom. That's why I’m here. Okay? And | don't want my parents to find out. Well... Because I told them it wasn't true. Your parents love you. Okay? And their main thing is for you to be healthy. Okay? Not only physically but up here. And they know that right now your have a lot of issues and I think this is one of them. Because Jike you said, you thought it was gross. Right? Cause he’s like 45 years old. That's okay. Let's backtrack a bit. When you went with tell me the part where it was the truth. Okay? You were with Zack and i said \el’s go? Yeah. Okay, we were watching, | don'd remember the movie, but | know we were watching a movie and then we were gonna go and take a ride. Cause me and Zack were gonna get dropped off at the bowling alley so a (inaudible) she was saying about her boyfriend and cot a phone call and then she was Page 12 of 43 05128 HOUSE_OVERSIGHT_012222

co 10 11 wok ND 13 14 15 MP: talking to that lady and the lady was cm was actually saying [m coming, I’m coming, andi was like, can | bring somebody? And then _ was like, the fady was Jike what does she look like and she started describing me and then Zack turned around and said tojwho are you talking to. And then went like that and she was talking to the lady and like just describing me, what ] was wearing that night and then the lady was like okay, well Jeff is gonna want to talk to you and iiwas like, that’s fine. And then she got off the phone and then Zack said, | was like too, why are you describing me, who are you talking to. And she was ike do you want ta go with me tomorrow, I’m gonna go pick up some money from my boss’s house. And then she’s like. cause | get paid tomorrow and then I said okay. And Zack’s like no because | guess Zack knew what she did because Zack said no and he got really mad at me and said no, you're not going, you're not going with her. And then | was like, and she’s like, you know, but you just have to come with me and | was like cause the old man’s gonna give us both money so we can go shopping. Cause that's like my boss and he’s really nice. And | was like okay. And then Zack didn't say anything the rest of the night about it, he was just like really (inaudible) out there and mad. Not really mad but he was just like frustrated that | guess, would s2y that. And you didn’t know what was really going on. | | didn't know it was gonna, that | had to give him a massage and get naked. Me: What did you think was going to happen? | | That, like she just said, | don't know but | knew something was wrong, nobedy’'s Page 13 of 43 HOUSE_OVERSIGHT_012223 05129

_ 45 16 7 19 20 21 22 MP: MP: just gonna pay you money but | didn't think that !, | thought that was just ma: business whatever [iii do, just gonna go over there. And she told me that it was a rich guy and she was saying oh my God, he’s so rich, blah, blah, blah. And he has like a new Mercedes and all this stuff and she’s like explaining him. And then, what's it called...so actually we didn’t, we left but we didn’t end up going to the bowling alley. Her boyfriend went to his house really fast to go get HE something from his house and then he (inaudible) brought his car back to HE s house and we were just sitting there watching the movie but she was like, | are you sure you're going to go with me and | was like okay, I'll go with you. |’m like last time, I’m like, what are we gonna do ii we were going to. go shopping and we were discussing what we were going to buy with our money, cause she told me how much money | was gonna get, $300. And | was cool, | know whal I'm gonna buy. We're just like saying what we were gonna buy with the money. She said | need to go buy a purse and then the next day, actually | gave her my phone number that night so she could call, so she could pick me up. And when | went in the house that moming, she called me, she | Ee you still gonna come with me and !'m like yeah. So she’s like okay, get ready. !’m gonna be there in like 30 minutes and then she came to the house in like 30 minutes. And she had a friend with her. Do you remember the name of tne friend? | don't know her name but she was like really dark, kind of like a Spanish girl. | don't (inaudible)... Darker than me? Page 14 0f 43 05130 HOUSE_OVERSIGHT_012224

ie 16 17 18 419 20 21 22 MP: MP: MA truck. And she had like short hair and she had like a styled hair, like a cute little style. | don't remember her name. i talked to her but | didn’t remember her name cause (inaudible) right after | got in the car. And then all the way there, we were just fistening to music and singing and stuff and like just Jaughing and stuff. And she told me the girl about her boyfriend and stuff (inaudible). So you're driving, So BB picks you up. Do you remember what day it was? No but | know it was a Sunday because | told my dad, Dad can { please go on Sunday with Haley to go shopping and my dad goes where are you guys going shopping because he didn’t know and he said no at first and | was like Dad, that’s, you know Zack’s cousin and then my dad says okay but | have to meet her. So then [called me afterward and then she’s like I'm gonna need $10 for gas and she was like can your dad give me $10? And then! was like sure but! didn’t ask my dad, | just (inaudible) $10. And then my dad was. okay and my dad called me, he's like (inaudible) I'm not gonna be able to give you money. So then | was really mad but then | didn't tell out my dad ended up {inaudibie) (inaudible) wher was pulling up, my dad ended up pulling up sol and my dad saw each other. And] was like, oh my God, your dad is so hot. And then | said yeah, right. Started laughing about it. And then my dad gave Haley $10 for the gas. So you got in the car. What kind of car did she drive? Page 15 0f 43 03131 HOUSE_OVERSIGHT_012225

10 11 12 13 22 23 MP: MP: MP: MP: MP: MP: MP: What color? i don't remember but | think it was a bluish color. { think so. So she drove. Yeah, she drove. ‘She drove? Yeah and | was in the passenger seat and there was like a whole bunch of junk back behind her and | was sitting next to it, like (inaudible) or stuff for school. And was there....like but | don’t know but it took a pretty long time to get — And you know where, like, the rich people are, what is that street? Where the Kravis Center is but further than that. Like towards the beach more. That way. Yeah, fcsmerrdls the beach. Yeah. That way. And that’s where, yeah, that’s like where he lives but when she pulled into, | know for a fact it’s a pink house, | remember the pink house and then he had an Escalade in his driveway and then a Mercedes in his garage. | remember that much. Okay. Do you remember... so you took the Kravis way or did you.... | don't remember where we... You don't remember which way... | just remember the building. It was near the ocean? Yeah. | know....cause one day when | was with my frien i, that's exactly where we went, like around that area, not the CityPlace area but you know, it kind of looks like that area. Like where the Kravis Center was and | Page 16 of 43 05132 HOUSE_OVERSIGHT_012226

10 11 12 13 14 15 16 MP: MP: MP: MP: MP: MP: remember....that’s how | remember. Do you remember seeing the beach and the ocean? No but we went over that bridge where the ocean was and then the bridge went over. Okay. So you definitely went over the bridge. Yeah. Went over a bridge. And it was up and we had wait for it to go down. So we were there for like 5 minutes. That was time you were wit Yes. Okay. And then the house, you said, you described it as pink? It was like a, it was a two story house and then it was like a pinkish color, pinkish pink color. Were there gates or samething in front? Well, it wasn't a gate but, the back door had a gate to it and it was a white gate and | | just like she knew that you had to open it and it wasn'tlocked so we just opened it and there were three, two or three steps and you just walk up and then he had a pool and it had, like the floor, the floor was like a hard something, it wasn't concrete, tt was squares of !tke concrete, but they were like... Like tile, you mean? It was like a coral concrete, you know like.. And then the pool was there and the house was there, | guess it was Jike a security house because a man that was with the securily came out and he was like whal are you guys here for, cause you're knocking on the door and thenlsaid we're here to see Jeff and Page 17 of 43 05133 HOUSE_OVERSIGHT_012227

10 11 13 i4 15 16 17 18 20 21 22 23 MP: MP: MP: | | MP: MP: MP: MIP: MP: then... What did that man say? He was like oh, okay and she’s like, she smiles and then he let her in (inaudib!e) but he opened the door and then we went in and then {inaudibie) and the counter, here’s the door when you walk in and there’s a (inaudible) refrigerator and then the window, a glass sliding window looks out at the pool. Okay. And then like the cabinet, | mean not the cabinet, the island, was like here and then there's like a cabinet over there and the door was right here. Okay, just for the tape purposes, the way that you described it, okay? Is you walk in and on the left hand side? Um hm. Cause you motioned right now, who's there? (inaudibie) And then when you walked in, on the left hand side. what did you see? Like if | was getting out of the doorway? Um hm. Okay. Well, there's a door. If you looked straight, it would be straight from you but a little towards the right. Okay. And... It wasn’t a door, door. It was just a doorway (inaudible) Okay. No, wait, maybe it, | don't know, cause it was open, but there could have been Page 18 of 43 05134 HOUSE_OVERSIGHT_012228

OS cr 10 11 15 16 17 18 19 20 21 oe = = ie Es Ba EF MP: door, but it was open so | didn't really pay attention. But | know it was a doorway going up. Okay. So new you're in that kitchen area. Right? Um hm. The three of you? Yes. Where did you park the car? in his little driveway area. So you're in the kitchen area. What happens next? We were waiting there. We were talking, just about how cool the house was. I’m like ch my gosh, I’ve never been in a house like this. And then the lady and the man came in, Jeff. I'm pretty sure...like 90% positive. And he walked in, he was like in a t-shirt and pants, not pants but you know, like maybe tike kind of dressy. Do you know what | mean? Um him. GER anc then he’s like okay, well, then follow my, | don’t remember the lady's name but she’s, he said follow her (the name) upstairs. So she’s like, come on oe and then we walked upstairs and | thought...... Page 19 of 43 05135 HOUSE_OVERSIGHT_012229

2 14 15 16 17 18 19 20 21 22 23 MP: MP: MP: By yourself? Yes, but | thought that i cause she said she was gonna get paid, so | though and the girl was gonna get paid in like, you know, like private, privacy and cause it was just him and her and the other giri in the kitchen. And so | went upstairs and as | was walking upstairs, there was a picture of him in like a different country and then I'm like that's really cool and the lady said isn’t it and she was just walking upstairs and there was like a door and then, it was like to a little (inaudible) this big and it had a couch and a couch and it was like another watkway towards that way. And then walked towards, like keep walking forward and then to my right and there was a bedroom and then we turned right again and there was a big bathroom, a big...it was humongous. And the bathroom. It wasn't like a bathroom, bathroom, it was like a sitting area with a shower there. Humongous shower. Like a jillion people could be in that shower. And then it was humongous. And there was like a door here and you opened it and there was like a little desk with paper and pads and stuff. And | don’t know (inaudible) like sitting on the couch right here, like against my... there’s big long couch. And it was pink and green. Hot pink and green. And there..... The room or the sofa? The sofa. Okay. And there’s a table with a phone on it. And um, during when | was giving him a massage, he made a phone call but ! don’t remember whether he just said, like he said four words and then hung up. Yeah, | don't remember. And he made a Page 20 of 43 03136 HOUSE_OVERSIGHT_012230

om, 13 14 15 16 VF 18 19 20 21 22 MP: MP: MP: By yourself? Yes, but | thought that J cause she said she was gonna get paid, so | thought and the gir was gonna get paid in like, you know, like private, privacy and cause it was just him and her and the other girl in the kitchen. And so | went upstairs and as | was walking upstairs, there was a picture of him in like a different country and then I'm like that’s really cool and the lady said isn’t it and she was just walking upstairs and there was like a door and then, it was like to a little (inaudible) this big and it had a couch and a couch and it was like another walkway towards that way. And then walked towards, like keep walking forward and then to my right and there was a bedroom and then we turned right again and there was a big bathroom, a big...it was humongous. And the bathroom. It wasn't like a bathroom, bathroom, it was like a sitting area with a shower there. Humongous shower, Like a jilllon people could be in that shower. And then it was humongous. And there was like a door here and you opened it and there was like a little desk with paper and pads and stuff. And | don’t Know (inaudible) like sitting 0 the couch right here, like against my... there’s big long couch. And it was pink and green. Hot pink and green. And there..... The room or the sofa? The sofa. Okay. And there’s a table with a phone on it. And um, during when | was giving him a massage, he made a phone call but | don’t remember whether he just said, like he said four words and then hung up. Yeah, ! don’t remember. And he made a Page 20 of 43 05137 HOUSE_OVERSIGHT_012231

an od 19 20 21 MP: MP: phone call and then he put the table back where it was (inaudible). And then.... But the lady...so you're upstairs and you're sitting down and the lady's there. What is she doing? Oh, she's, well, there’s a closet right here, with a table in it. Like the massage table... Near the sofas? Yes. Like a door on each side and um, towards the door, there's a door for the table. She took that out and there's like a safe and then like she put it in the middle. it's this way, like long ways. And then she put like put the cloth over it but she's looking around the room, | guess just to took, like she was remembering something, t guess, like where the lotion was. And there are pictures of like, naked girls on the wall and there was like, there was like one big mural of naked girls’ like, bults. And then, towards the door, there was like a cabinet here, like a built in thing, like a {inaudible} and um, there’s drawers in it and she opened the last drawer and there was a whole bunch of lotions, like millions and millions of kinds of totions. And she picked out three kinds of lotions ard put them on like an armoire kind of thing with a mirror. And she set it there. And then after, she told me, sit here for 5 minutes. Like, just sit there. And eventually he came in and he was like, hi i'm Jeff and I'm like hi, ' i And he's like, I'll be right back, you can take off your clothes. And then he left. And there's a bedroom out there and he just went out there and | don't know but there’s like, pictures out there, | think, | don’t remember, he took off his clothes and put a towel over himself. But | don’t know if there was a towel thing back Page 21 of 43 05138 HOUSE_OVERSIGHT_012232

“a 10 14 12 13 14 15 16 17 18 19 20 21 22 23 MP: MP: MP: MP: MP: MP: MP: there cause it’s like, | don’t remember... Did he undress in front of you? No, he didn’t. But he took off his towel in front of me. Okay. So he came back in.... Yeah, he came back into the room and he was.... Were you dressed? i was in a bra and he said no, | meant get naked. And then | was, | went like that and he was you can keep your bra and underwear on and but get down to your bra and underwear so | took off my pants. Cause he was real stern about it, like Take Off Your Pants. And then | just took aff my pants and then he laid down on ihe table but like, after he was laying on the table, he took off the towel just enough, you know, like you could see... Did you see him naked? Yes | did. And it was disgusting. | don't mean to... | Know maybe it’s disgusting but can you describe him? Did he have any marks, tattoos, was he hairy? Yes, he was really very hairy on his chest and on his back and towards...okay | don’t mean to sound gross but... No, say it the way you would if you were speaking to one of your best friends. Okay. (inaudible) Okay. He was laying on his belly side so his butt was like, up. And there was like, he had a very hairy back all the way to here and then there was just like a Page 22 af 43 05139 HOUSE_OVERSIGHT_012233

14 15 16 17 19 20 21 22 23 a: se MP: MP: MP: MP: MP: VIP: MP: hairy butt line going down to his butt. Okay. So gross. Okay, and then...f{inaudible) Did you see the front of him? Yeah. Cause when he got off the table, he like turned this way so everything showed towards me and then he got off and then he went and whacked off and then he came back in. But he was very hairy on his chest area and | just looked for like one second and it was very, very disgusting. Okay. That's all ! have to say about that. Do you know what it means....and |] nave to ask only because there are some people that don’'t.....to be circumcised? No. I don't, } don't really know... but | think he was on steroids because he was a built guy and his weinie was very tiny. His wee wee was very tiny. Yes. And when you mean wee wee, you mean what? His penis. Yes, his penis. Okay. Yes, his penis. People call it different things. Alright. | just wanted to make sure we know. Okay. He laid down, he took off his towel and he laid down. He laid down on the ..... Did he take his towel completely off or just open it so... Page 23 of 43 05140 HOUSE_OVERSIGHT_012234

so™ 10 4 12 13 14 16 17 18 MP: MP: MP: No, completely off. Okay. Where did he put the towel? On the floor. Right like, the table underneath. Okay. So he {aid down, took the towel off. What happened next? And then he's like, get the lotion. So | grabbed the lotion. Which, | had to walk almost naked, but | was in like a thong so yeah, my butt was showing and he, the table is like, | mean the sink was, you know, the lotions were right there and | was over here and he was like go get the lotions just so | could walk past him with my butt showing to go get the lotions. So | got the lotions and he’s like, he’s like this Iotion and then | took that lotion and he’s like squirt it on your hands and then massage clockwise on my back cause | didn't know how to do it? and then he’s like. telling me where he would like the massage, here and here, the right to the left, down more, up more. So | was just massaging and he turned and started having a conversation, oh what happened ol and I'm like, (inaudible) my ex-boyfriend (inaudible) what’s your boyfriend's name. Zack. And he was kind of questioning me and then he said what, he’s like, could you stop? !need to go. And i just stopped and I'm like okay. And he got off the table. He put the towel over him. He bent down and got the towel and then he left the room and you could hear him, like, you know, you could obviously tell what he was doing, just like... idon't..... !wor't look at you but do what he was doing, what you heard. | know it's kind of embarrassing but... | He was making like sex noises. You know, like..... | don't.. They were very Page 24 of 43 Ool41 HOUSE_OVERSIGHT_012235

MP: Me: MP: MP; MP: MP: MP: strange noises. That's all] can say. Okay. | don’t know how to describe them, they were very strange. Can you imitate them? | don’t, | don’t want to make a foot out of myself. You won't. You're not making a fool. You know, it might say it's sex noises. He may say | was singing. Okay. He was liké.... | won't look at you, go ahead. He was \ike ogoohhhh, ocohhh. Okay, okay, he’s making groaning noises. Yes, groaning noises, that’s it. Okay. That was really embarrassing. It really was. He was making those kinds of noises and then he walked back into the room, took off his towel again and laid back on the thing and then he wanted the same kind of massage but he was like oh use your {inaucibie) a little bit more. You were massaging his back? Yeah. And then he, he’s like, could you, turn over for a second.. (inaudible) {inaudible) go back out of the room. He turned over and he said okay, please massage my boobs. And then | was massaging his boobs and he's like, he's like, oh, like as | was doing it, as | was massaging, he was making the same noises again like, oh my God, it’s so embarrassing to do this. He was like... | won't look, He was going like ooohhh, making those noises. And like 5 minutes after that, Page 25 of 43 05142 HOUSE_OVERSIGHT_012236

17 18 19 20 21 22 23 and then he turned back around and he just started touching himself and | think the massage was like a half an hour but cause | don’t know, the time | think was a half an hour to 45 minutes and then! was done. And then he, | think he has like a safe somewhere because around us he didn’t have his wallet or something because right when we got out the door, he left to go put the towel on again and he put the towel on again and went out of the room and he goes you can put your clothes back on. So | put my clothes back on and he walked right out there, like two seconds and then came back like within two seconds. And he’s like here's your money. And then he gave me $300 in hundred dollar bills and they were like brand new because they only had like one crease in them and that’s when they're folded in half. And he said thank you for your time. And then he left. And he said you can see your way out and | was just walking and | got lost cause there’s so many different rooms and j got lost and | walked back downstairs and | ERS like just smiling and giggling, like, | guess it was what the lady was saying and then she looked at me and she looked back at the lady and then she’s like, the iady’s like oh, bye fl cause it was time to go cause | guess because | was done. And then, then we left the same way we came in and then I's like oh my gosh, Wcoes how did you like it. Like how much did he give you, how much did he pay you. And |’m like $300. And I was kind ef tike $300, Cause the girl was like this. She was looking at me really weird. The other girl that was with her. She's tike really quiet though. And then she just looked at me really weird and she’s like trying to gaze into my eyeballs. And ihen we went in the car and when we got in the car, Bs like, let me see what Page 26 of 43 05143 HOUSE_OVERSIGHT_012237

ae ™ F P \ 40 12 13 44 15 16 17 18 19 20 21 22 23 MP: MP: MP: MP: ne gave you. And then | showed her my $300 and she’s like, we're going to Marshalls. And then, give me back my money and | put it in my back pocket. And then she was trying to get me to describe what happened so } told her what happened. And she’s like, you could do this every Saturday. He's is like so rich. And | was just kind of like, yeah, we could. And then, she put back on the music. And then, when we were leaving, the lady was walking outside and | (inaudible) one of the cars really fast but she was just going to the passenger seat and she opened the door and then closed it. What cid fi s friend say? Did she say anything about ii? She was just like interested in what happened, like when we were talking, we're like into the canversation and then she was kind of like giggling and laughing. like, | think, | wouldn't say, | mean, | don't know if (inaudible) or not but she wasn't acting surprised, you know, like giggling. She was just of like giggling and Jaughing along with And tnerfigces um, and then when | was giving the guy the massage, he goes, | know BB she's been working with me for a long time and then when | came back downstairs, goes, you only paid me $200. So.... He liked you better. i don't know. Well, after you left, where did you go? Marshalls or to TJ Maxx, one of those two. TJ Maxx or Marshalls. And she bought a black purse. Okay. Did you seeljJafter that again? Page 27 of 43 05144 HOUSE_OVERSIGHT_012238

—_ 16 17 18 19 20 21 22 23 i Um, | don't think so because that's when | got grounded. And then that's when | MP: MP: MP: MP: MP: got in trouble with the fight. So after that, I'm pretty sure | didn’t. Most likely. Did you ever speak to her again? No, because | got my ceil phone taken away. Okay. So you haven't see TE since the day you went to Jeff's house. Correct. Are you sure? Yeah. I’m 100 percent sure. How do you know she....now tell me what happened with your dad. Okay. Because my dad, | didn't know about until my sister told me when she came here. But my sister, on a Thursday, was coming here. And wait, Wednesday night, my dad said that he heard the dog barking and my dog is inside. So he’s barking and he’s outside, like barking towards outside and then my dad is like shut up cause he forgets the dog's name and the dog wouldn't be quiet. So he’s like, I'm taking the dog outside. And then my dad took the dog outside and the dog was way in towards my dad's truck, like my dad thought he was attacking the animals but my dad, a person, a boy, ! don’t know for a fact but | know in my heart its Zack. Because Zack got really mad over the whole situation. Did you tell Zack what happened? Yeah. And that’s when, he punched a wall and he like my face was right there and he punched the wall, like my face was right there and he punched the wall right next to my face. And he started getting all upset and crying and calling Page 28 of 43 05145 HOUSE_OVERSIGHT_012239

on™ ~~ 10 11 12 13 14 16 17 18 19 20 21 22 MP: MP: | | how could you do this? Biah, blah, blah. And then['s like, okay, | won't do it again. And like she just kind of like hung up and he was like | hate her, | hate her and then | hate you too. And | was like okay and we broke up and then | think (inaudible) on the computer and | think he told PE wat happened and she turned it into an extraordinary, like story so at school so | would look like, you know, like I'm the bad persan, {ike ('m a slut, I'm a whore or something and she’s going around school saying all this stuff and then so my parents came, cause that's when | got mad at her and told her to stop talking but she wouldn't stop talking about it. So | just gotin a fight with her, like a fist fight at school. And | got suspended and so did she but she only got suspended for one day because | started the fight. So | got in trouble more. And my dad got really mad and he grounded me for it, because he found the $300 in my walict and then my dad was like, you're grounded, you're grounded forever and he's ail freaking out, how could you do this, blah, blah. The school said you did. And um, | didn't tell the schoof how, | told them | got it from my job, cause | worked at Chick Filet but! quit. So | said | (inaudible) but nobody believed me so | was just like believe what you want. Cause | didn't want to tell the principal or my parents. Well, | think that the best thing that you're doing is that you're being honest. Okay? Um hm. You already know that they have a pretty good idea what happened. Okay? | didn’t even know there was like an investigation. Page 29 of 43 05146 HOUSE_OVERSIGHT_012240

we’ -_~ 10 11 13 14 15 21 22 23 MP: Well, that’s... | | I just knew. MP: Well, this is why. What's happening is that | was made aware of this situation... Fon my school? MP: MP: MP: I'm not gonna Say, okay? | was made aware of this situation. And they look at it like you were taken advantage of. Not that you did anything wrong, okay? Even though you went there willingly. Even though you went there willingly, you were still taken advantage of. Okay? Because you were pul into a pasition that you felt you had no choice. Once you were there, before when you were telling me about how Jeff told you to take off your clothes? You took your pointer and you said he was really stern and you banged your leg, you put the pointer on your leg when you said that. How did you feel when he told you to fake your clothes off? 1 don't know. I didn’t know what else to do because | was the only person up there and he’s like 45 years old and he has like big muscles, because, | don't know, but I'm pretty sure 45 years ald and big muscles, body builder. Okay. So | just felt intimidated because he’s guy, first of all, and ’'m a girl and | know that JI was all the way downstairs with the lady and what was [boing to do to help me ali the way upstairs so | just did it. Okay. Now, there's one way I’m a little confused at because you said that, and I'm using your words okay, that he whacked off twice. You said before that he whacked off twice. When did he do thar? P| In between giving him a massage, like when | was giving him a massage, he was Page 30 of 43 05147 HOUSE_OVERSIGHT_012241

13 14 15 13 19 20 22 23 MP: MP: MP: MP: MP: MP: | MP: MP: got, he was like, excuse me for a minute and he just left the room. Okay, so that’s once. When was the other time? Like during the thing, like when | was massaging his boobs. When you..okay, when you were massaging his boobs, was his back flat on the table? How was he positioned? Weil, he was at first and then when he started to whack off, he got like, his back went off the table, kind of like leaning... Okay, where were you standing? Iwas standing up. | was not on him. | was standing up (inaudible) and | was like....he was towards, okay, he was on the table. I’m right here and he’s leaning that way. Okay. like (inaudible) cause | guess, | don’t know, but... and he was like, my face, it got hard to see what was going on because of how low [| was and he just kind of moved his head the other way and he was like, wants.... Okay, but just now, when you're saying that, you moved your hand. Did you see him whacking off? Yes. | saw him whacking off. Okay. That's what | need to know. Cause you said he whacked off twice. Um hm. So he whacked off in front of you? Um hm. And you saw his hand doing or you saw his eyes, what was going on? Page 31 of 43 05148 HOUSE_OVERSIGHT_012242

10 11 42 13 14 16 17 18 19 20 21 22 MP: MP: MP: MP: MP: MP: Okay. i saw his face, facial expressions and noises. Okay. What else did you see? | just saw him... You keep moving your hand so...in other words, he took his hand and what was he doing with his hand? i don’t know how to explain it. He was just whacking off. Okay, describe...don’l.... Okay, sorry, Ne put his hand on his penis and he put if up and down and he was like making facial noises, | mean facial expressions and making noises. So you saw him doing that, he did that in front of you? Yes. Do you know what it means when someone ejaculates? It means they're horny? No, what it means is that once they, while they're whacking off and I’m using your words, okay. Another word for that is masturbating. Okay? Yes. Do you know what it means to masturbate? A boy does it? i don't know why they do it or | know why they do it but ] don’t know what it does... Okay. To them. In other words, fluid comes out of their... Oh, okay. Page 32 of 43 05149 HOUSE_OVERSIGHT_012243

10 41 12 16 V7 18 19 20 24 22 MP: MP: Okay? |'m just being very... I'm gonna tell you because | think... 1 know that part. Okay. So fluid comes out and that’s ejaculating. And it’s called semen. So while he was whacking off, okay, did you see any fluid come out? oe It was, yes, because he had to take the towel and wipe his thing before he got off MP: MP: MP: MP: MIP: the table again to go get the $300. Okay. He took the towel and like... And then, okay, like he took the towel to wipe himself and then like as he was getting off and then this way instead of this way, this way, like that. Okay. Since you've seen his penis, was there anything distinctive about it? Like did he have a mole on it? No, it was very small. Very small, that’s fine. Did you notice...you said he was very hairy on his chest. Did he have any tattoos? Uh uh, not that | saw. Did he have any scars? No, but he had freckles somewhere becausc he was huge. You're pointing at the chest area. Yeah, some freckies. Like a mole or a freckle? A freckle. Okay. Can you tell me what he looks like? Page 33 of 43 Q5150 HOUSE_OVERSIGHT_012244

2s 10 11 12 13 14 18 19 20 21 22 a a) ma He had like nat white hair but itwas, not white but it, you know, it was kind of like, like me. twas like.... | don't know. MP: He was going gray. } | Yes. He was going gray. And he had... MP: What color hair did he have before? Blonde, brown? | No. MP: You were describing Jeff to me, with the freckle and he was going gray and what else? a Um, like he, like his skin color is like, when | saw him, when you have a sunburn, but its like when you have it a couple of days and it’s turning into a tan. It was tike a reddish tannish color. And he had like a long face and that's about all | can remember and he had a white t shirt when he first came in. Okay. | don't really remember... Did he have any king of like jewelry on his body that you noticed? | didn't, | don’t remember. Okay. Do you remember what color eyes he had? Nope. Did he have any facial hair, like a mustache? Or a goatee or anything? Te ee U v 0 A Hmm....No but his eyebrows were really thick and they were bushy, like everywhere. Page 34 of 43 Qo151 HOUSE_OVERSIGHT_012245

oo™. 10 44 12 13 7 18 19 20 21 22 23 MP: on v MP: Okay. You Said that you straddled him. Um hr. What do you mean by that’? When..he was on his stomach and | was giving him a massage, like | was, you know where, like, on...on, like the butt? And then like, | was sitting on his butt but a litte bit above his butt. And J, it was, | was butt naked and he was butt naked and... Okay. ..my butt was, my butt cheeks were on the top of his butt and the reat little of his back. MP: MP: Okay. Now, did he ask you to get on top of him? Um hm. Or did you do that on your own? No, he’s like..because al first, | was giving him a massage like you know, standing up. And he, then he’s like it would be fee! more comfortable if you got on my back. Could you please do that....and then | did that. Like, | did, um, like, Page 35 af 43 05152 HOUSE_OVERSIGHT_012246

10 14 12 13 14 16 V7 13 19 20 21 MP: MP: CE 0 a MP: MP: MP: | wasn't, at first I didn't want to sit on his hairy you know, bult. So it was Kind of like, you know, like, pushing my legs on the table so like | could kind of sit up and he was like could you please just put all...like sit on me, pul all your body weight onme. And then | went, | was just kind of like kind of think | did when | was actually sitting on htm, | didn’t realize what it was and then like, | got grossed out and as tm going down, kind of like popped up again. Cause it was gross. Okay. He never tried to touch you? Besides like, you know, well, what do you mean by touching, like sexually touching me? No, did fe try to touch you or... He put his hand on my back when he was whacking off or masturbating. Like, he was just like.... You keep, like motioning, like smacking. No... What do you.... Like, when you're leaning on something, putting your force on it? He was going like that, fike...pulling, not, you know, like.... Can you show me what you mean? Okay. He was..... Let's say mon my back. Where would you be, I'm Jeff, where would you be standing? I'm right here. | was like, | was like sitting right here. Okay. Page 36 of 43 05153 HOUSE_OVERSIGHT_012247

ooo, ao 10 11 42 13 15 16 17 18 20 21 23 Okay and when he backed up. Which way, this way? Yeah. Okay, I’m going to my left. | All the way around til your back’s on the table. MP: MP: ai U Okay. I’m facing you. And then yourre, your face is a little bit that way... My right. Okay. And (inaudible) towards, like on his knees, kind of... Okay, I’m hunched over a little bit. And I'm over here. And I"m stilt giving you a massage and everything but this hand is around me and (inaudible) Okay. My left hand would be...so is my left hand around your shoulders? No, under my arm while I'm going like that... Okay. So I’m holding you like around by the waist. Um hm. And that hand was on his... His right hand. Yes. Okay. It just gives me a better picture of trying to understand, that’s why. Um hm. And | appreciate you doing that. | don't mean to make you feel uncomfortable. Do you feel uncomfonable? No. Page 37 of 43 05154 HOUSE_OVERSIGHT_012248

15 16 17 18 MP: MP: MP: MP: MP: a U MP: Okay. After everything was done, okay, did he watch you get dressed? No. Cause | was getting dressed while he was out there getting the $300. | guess that’s what he was doing. That’s the only thing he came back in with. He was stillin a towel and stuff. In the room, at all, do you think...and | don't know if there is or not, but do you think there is anything in there that may have recorded what you did? Oh my gesh.... A video camera... Oh my gosh. | didn’t think about that. There was lots of places there could have been one because there's pictures, that could have been, | don’t know.... When he walked out... the reason why | ask is because he walked out once and then came back in, right? Yes. So it could be just so he could whack off. | was just curious. | don't know if there is or not. if there was, | did not know about it. Okay. So you get dressed, you go downstairs. Where is that woman again? Downstairs talking to i and the other girl. Okay. They were having a conversation. Page 38 of 43 05155 HOUSE_OVERSIGHT_012249

16 17 18 19 20 21 22 23 MP: So what other things did he ask you? Um, how | know what school | went to. MP: Did you tell him what school you went to? Yeah but i told him Wellington. {didn’t tell him Royal Palm. MP: Okay. What else did you talk about? BM, that’s about it. And he was kind of asking me like how | knevE is PE vice to me and then he told me how he knew and he was like, | was kind of like, how do you know Cause | brought up the conversation. He said well | know Haley because she’s been working for me for a long time. And Page 39 of 43 05156 HOUSE_OVERSIGHT_012250

co 10 14 12 14 15 16 17 16 1 20 21 MP: MP: MP: MP: then like, | kind of, you kind of get the picture, working for you and hello, I'm sitting there giving him a back massage. So] kind of figured it oul. He never said that, he just... Yes.. ..said that she worked for him. Yeah but don'’t...on our way back home, that, like, doesn’t make any sense if she didn't do that because why would iia be doing {inaudibte) for almost the same amount of money as me. Right. Well, why couldn't he pay her that day? } doen't know, because that’s a good question. Cause she didn't, as far as | know, but | don't know but I'm pretty sure she didn’t tell me. she didn't think. She was just downstairs having a conversation. And | think that when | went up to the lady, he paid her because like, you Know, so because, he paid her while | went upstairs and when | went downstairs, she was siill talking to the lady still and she gces, when we were in the kitchen waiting, the ald man to come to the house still, she said, oh the chef is so hot, he works here and she was like, and she’s like he’s so hot, you know, saying his face and then the other girl (inaudible) because when we saw the chef come in, he was old, toc. He was like... So J likes older guys. a Must like it. MP: Okay. So you left and that was the last time you see him. MM Yes and that’s the last time | went... MP: Has Jeff ever tried to call you? Page 40 of 43 05157 HOUSE_OVERSIGHT_012251

por ty 10 14 12 13 14 18 19 20 21 22 MP: MP: MP: MP: MP: MP: MP: MP: MP: Nope, And... Did you leave a phone number? Yeah. Actually | did. Cause when | was leaving, he goes um, please leave your phone number so can keep in touch with you because she doesn't have your phone number. So I didn’t, | just gave him my cell phone number. | didn’t give him my house number, | gave him my ceil phone number. And how long ago was this? Oh my gosh, | couldn't tell you the date but....it was about maybe, oh my gosh, a month and a haif ago. | don’t really know.. In February? Because we're in March right now. Either ihe very beginning of February or the end of January. | couldn't tell you... How jong after did you get into that fight with a: Um, like a week, cause... You got into a fight with [Jon the 9". Okay, so yes, it was about a week after....or before. Okay. And who else besides Zack dic you tell what happened? That's it. Besides of course. Zack and J Do you think i has brought anybody else that you know of? No, but she wanted me to bring my sister but that same day was going to her Page 41 of 43 05158 HOUSE_OVERSIGHT_012252

10 41 MP: MP: MP: MP: MP: MP: MP: MP: boyfrienc’s house. Okay. And, when | was in that guy's room, there was a like, where the drawers of lotion were, ihere’s like a shelf of pictures and he had so many pictures of girls about 16, 17, around that age, 17 or 18. And they were like on the walls and most of....alt the girls were topless or just plain naked. And they were in positions or they were just standing up. Okay. Looking at pictures. Okay. Well, | have to ask you. Do you know the difference between....and you're a grown woman, so I'm asking you. You're pretty mature for your age. Okay? Do you know the difference between right and wrong? Yes. Do you know the difference between the truth and a lie? yes. Can you tell me what a lie would be? Um, not saying the truth. Okay. So if | tell you you are wearing a biue sweater right now..... | could tell you you're lying. Why? Because I’m wearing a pink one. You gotit. ts everything you've to'd me the truth? Yes. Page 42 cf 43 05159 HOUSE_OVERSIGHT_012253

11 12 13 44 2: 23 MP: Are you lying about anything? No. /'ll swear on the bible. Okay. Swearing to God, that’s good enough for me. | swear to God. Okay. Is there anything else you'd like to talk to me about? No, because thal’s about....nothing else about the whale thing. At any time, did he touch you..... At no time... Besides puiting his hands... Besides that, no times did he touch me. And just so | can be sure, you saw him whacking off once. Yes, | saw him. Okay. And as far as you think..... i think, | know, well, | couldn't say f know, but it’s the same noises were being made when he was (inaudible). And that’s it. | thank you very much. This will conclude the interview. The time now by my watch is approximately 3:05. Page 43 of 43 HOUSE_OVERSIGHT_012254

TAB 5 HOUSE_OVERSIGHT_012255

THR STATE OF FLORIDA, COUNTY OF PALM BEACH. JEFFREY EPSTEIN. / SWORN STATEMENT OF Friday, March 21, 2008 12:05 p.m. - 12:15 p.m. Avenue South Suite 2400 West Palm Beach, Florida 33401 250 Australian Reported By: Judith F. Consor, FPR State of Florida Notary Public, Consor & Associates Reporting and Transcription West Palm Beach Office Phone - 561.682.0905 HOUSE_OVERSIGHT_012256

Re APPEARANCES: On behalf of the Defendant: JACK A. GOLDBERGBER, ESQ. ATTERBURY, GOLDBERGER & WEISS, P.A. 250 AUSTRALIAN AVENUE SOUTH SUITE 1400 WEST PALM BEACH, FLORIDA 33401 561.659.8300 ALSO PRESENT LILLY ANN SANCHEZ, ESO. FOWLER WHITE, ATTORNEYS AT LAW rete ae No Se ore aOsN TTI SERIE SSS TTT ESTO TENT AO Tea HOUSE_OVERSIGHT_012257

nsor & Associates FEU Reporting and Trenscziption, inc. Page 3 Statement taken before Judith F, Consor, if Court Reporter and Notary Public in and for the State of [ Florida at Large, in the above cause. Thereupon, having been first duly sworn or affirmed, was examined and stated as follows: THE WITNESS: Yes, ma'am. BY MR. GOLDBERGER: 0. Jennifer, my name is Jack Goldberger and I'm here with Lilly Sanchez. And we are two lawyers that MEER lcci pans represent Jeffrey Epstein in some matters that are being investigated here in Palm Beach County. We've asked you to come in here today, and Wea )on an tence f we really appreciate that you came in here voluntarily. You've just been sworn to tell the truth, PON DEeTODeNCaeT rae este and really all that means is that we're going to take a statement from you. And it's obvious that we just want you to tell us what you know. pyc A EN GA SOO IE HR STETOTF TOTP A, Uh-huh. Q. We don't want you to tell us anything that riilvht ers is incorrect or a lie in any way. We simply want the truth here. And we’re going to do this very, very eT eAaseant ohieceelelocermanes quickly. Okay? CCU USFS POZE TOTAL SR TSAR ATRE TURE PSS Oo eB SE PIRSA CAV CFV T PECL PIR a 8s VEIT S TATE MACY SYN ES SO SLATE HOUSE_OVERSIGHT_012258

isor & Associates Reporting and Trenuziption, Ine. Page 4 A. Uh-huh. Q. If you don't understand -- you know, I talk in what's called lawyerese sometimes. And if you don't understand what I'm saying, just say, “Jack, what are you talking about?” And we'll get it straight for you. Okay? A. Un-huh. Q. Will you tell me what your full name is. Aw ©. Okay. And your birthday, | sg As Okay. Now where do you live right now? Is that here in West Palm Beach? How long have you lived there at that address? And you live there with your son? A. Yes. And my parents. Q. Ckay. You've never been in court before for anything, have you? A. Traffic. | Your own traffic? Nothing, nothing serious. Sela a AEST RRC SACI ICA POTN AMET BRE COSI ROY VE SOU ERE HOUSE_OVERSIGHT_012259

isor & Assoc - Reporting asd Transeriptics, fee, QO. Just your own traffic matters? A. Yes. Q. Have you ever had to have an attorney represent you for anything? A. No. Q. Good for you. Okay I want to talk to you about a man that you know by the name of Jeffrey Epstein. A. Uh-huh. You know Jeffrey, do you not? I met him once, Q. Okay. And now before you went to Jeffrey Epstein's house, had you ever heard of him before? A. Yes, | | had told me about him, [I Q. And what had RR coi you about Mr. Epstein? A, She told me that he was having girls such as I =:¢ J. enc otners that 1 don't know their names, were setting up girls to bring them over and give him massages, and it was going to be strictly massages, no physical contact other than that, and that I would be HOUSE_OVERSIGHT_012260

sor & Associates ” Reporting and Transerigtion, ine. Page 6 getting paid -- I don't remember what she told me. I think she said a hundred dollars for a half-hour or something, two hundred; either a hundred or two hundred, I can't remember. It was a long time ago. Q. Sure. A, But it was only going to be for a half-hour and that was it. HOUSE_OVERSIGHT_012261

_ mnsor & Associates _~ Reporting and ‘Trenseripticn, inn, Page 7 anyone that worked for Mr. Epstein before going over Q. Okay. So a <2: you that you could go over to Mr. Epstein's house and do a straight, aT are gS CNTF TY CUNO PU HCA Fy QUEENS fe RRS RAFU RR LR ra URC T legitimate massage, correct? Sd ae serra A. Yes. Q. And that there would be no physical or TIGR NTE eae eee sexual contact in any way? A. Right. Q. And I assume that was important to you to, to make sure that there would be no sexual contact? A. Yeah. I nean was one of my good friends. She was one of my best friends at the time and I trusted her word, and what she told me sounded legitimate and legal, to my understanding. I wasn't | doing anything out of the way. So I believed it wasn't too bad to do to clear my bank account up and get that straightened out. E HOUSE_OVERSIGHT_012262

sor & Associates " Reporting and Trenssziption, Jac. Q. Okay, Now, I think you just what answered the question, but let me just ask -~ I'm going to do what I told you I wouldn’t do; I’m going to ask it to you in legalese. Before going over to Mr. Epstein's house, anyone try to persuade you te engage in that kind of sexual activity or sex with Mr. Epstein? A. No. Q. Okay. A. when (pac -- becausefi——n vas the one that had drove me over there ~~ Q. Right. A, iad P| told me that would be the one driving me -- they were following -- and | aS said that if -- he might ask if I wanted to do anything else, that it was up to me, I could say yes or no. She said, "He may ask you to do other things." Q. But no one was asking you before you —- A. No one was telling me that I had to do anything. She was just stating that it was a possibility HOUSE_OVERSIGHT_012263

nsor & Associates Reporting wud Trerseription, Inv. he may ask me to do other things. Pace 9 Q. Most importantly though, before you went over there, no one tried to persuade you to engage in any kind of sex? A. No, no one persuaded me. Q. No one was inducing you or enticing you to do any kind of sex? A. No. on Okay. And certainly no one that had any association with Mr. Epstein tried to persuade you or induce you to engage in any kind of sex? A. No. Q. Okay. As far as what JM saia she said he may ask you whether you want to do anything to you, and it was totally within your rights to decide? A, Totally within my rights to do whatever I wanted to do. Q. And I assume she told you that if anything was asked of you, whether you wanted to do anything else, I assume told you that Mr. Epstein would absolutely respect that. In other words, if you were asked to do anything and you said no, he would say, "Fine. I understand." A. Yeah. Because he told me in the room if I didn't want to -- whatever I didn't want to do, just say HOUSE_OVERSIGHT_012264

isor & Associates ; Reporting and Thenscrptiog, Ine. no and he said that was fine. QO. Okay. As That's what I was understanding. Q. Okay. But that conversation only took place after you got to his house, right? A. Yeah, right. Q. Okay. And going back to, :o ii she never communicated to you, with you by e-mail or text messaging about any engaging in any kind of sexual activity? A. No. It was just that day that I had decided that I was going to go over there that had took me over oT - house and then ae »:: drove me there and p | and PE «c2icec. Q. Okay. I know the answer to this is obvious, because you only went there to Mr. Epstein's house one time, but I've got to ask you this. You never traveled anywhere with Mr. Epstein, did you? A. No. Q. You never left the state to meet with Mr. Epstein, did you? A. No. Heard other girls did. Q. Okay. Ms. Sanchez just reminded me of a question I forgot to ask. HOUSE_OVERSIGHT_012265

: ‘Reporting and Trenserpioa, Tan. telephone at any time, did you? A. No. pen Tarpaty oreo cys yA SRE EE Q. Thank you. So I think what I'm hearing you tell me is RFT a ARE CATT that your going over there was entirely voluntary; it was consensual on your part? A. It was consensual on my part, yes. Q. No one told you that you had to dress in PANT Metals ia retinanrercestincora rive ee any particular way? A. No. I was wearing jeans and a tee shirt. Q. Kind of like today, right? E A. Exactly. 0: Now, you were told that you didn't have to take your clothes off, right? A. Yeah. She was -- well, they told me it was up to me, They said that it was just going to be a massage. They didn't tell me anything further than that. They said if he did ask me, it was entirely up to me, Q. Right. SUT BRS ae TTT A. And that was that. Os Right. And you were told you could say no to anything if anything was asked? A. Yes. Q. And that was clearly the atmosphere that existed when you went to the house? Pmt mare eee EAT STR R ECOG H BN APP IMCS NET STU TSNLS STORY Sn TaLD et chat a aE NANDA DETECTS o TIE OETA TVET ho eT ae ANT HOUSE_OVERSIGHT_012266

wor & Associates Reporting and Transoription, Tac. Page 12 A. ‘Uh-huh. | Q. Anything that was done was totally your bang ise PALI EA THEN decision? A. Exactly. Q. All right. Great. Now you never -- during the one time that TEA Tes These de ea ent Pda ae you were with Mr. Epstein, you never told him at any time ETS E ated erence eect that you were uncomfortable with him in any way, did you? A. No. Q. You weren't afraid to say no to him about anything, were you? A. Nothing. Or anybody. Q. Did he ever touch any of your private parts No. MR. GOLDBERGER: Let's go off the record for a second. Te arr can rw Pence LE 33131 (Discussion held off the record.} MR. GOLDBERGER: Back on the record, BY MR. GOLDBERGER: TSS seaereace neuro et SUA TENT TD TPOTRESI eeu TET GNESI HOUSE_OVERSIGHT_012267

msor & Associates * Floparting and Trenseviption, In. Q. Okay. Now while you were with Epstein, did he touch his penis at all? Bus No, he did not. Q. Did he masturbate in front of you? Ne. And you didn't touch his penis, I assume? No. You didn't help him masturbate? No. ( a And certainly -- Sex A. Sorry. He was too old. Q. I hear you. And I'm sorry to ask these questions that are so obvious. A. It's your job. Q. Mr. Epstein did rot have any sex with you in any way? A. No. Q. You didn't have any kind of oral sex with A. No. Q. Okay. Did Mr. Epstein ever penetrate you in any way with his finger or anything? HOUSE_OVERSIGHT_012268

Page 14 1 Q. And I would assume based on what you've been telling me, that Mr. Epstein never threatened you in any way? A. No. 5 Q. In fact, I think you described him as being a nice guy, right? 7 A. He was a nice guy. I mean I'm not going to sit here and actually defend him, because I know he was wrong for some parts maybe in his case, but as far as I go, it was -- he was not threatening me. He didn't make me do anything that I didn't want to do. I said no if I didn't want to do something and -- 13 Q. So clearly, you were not afraid when you were there or anything like that? A. No. 16 Q. All vight. And Mr. Epstein didn't offer you drugs of any kind? A. No, 19 Q. Okay. He didn't offer you any alcohol? 20 A. Nothing. Qt Q. And I think you told me already -- but let's make sure we're clear on the record, -- you went to Mr. Epstein's house one time and one time only, correct? A. Correct. And that's the only time that you've ever a LOE RBA AE RSET AV VTE TONS IULOT? 2 ET EY ONESIES LEST ST ICT. TY aT PESTS SEAVER eV OPEN TTT HOUSE_OVERSIGHT_012269

ws sor & Associates Soper vod Thence ne seen Mr. Epstein? A. Correct. Q. Okay. And you certainly never called the police as a result of this? A. No. Q. And you never contacted the State Attorney's Office? A. No. besides f | which was my best friend. LI always talked to her. She asked if I ever wanted to go back again and I told her no. And she was just asking me that as a friend question, not to ask me if I was actually willing to go back over there. Q. She wasn't speaking as a representative of Mr. Bpstein? A. Right. Q, It was just a friend -~ Right, just a friend conversation. HOUSE_OVERSIGHT_012270

insor & Associates Tiesaries and Trenseriptiog, Ino. were told that you had to be 18 to go over to Mr. Epstein's house? Avs Yeah. Q. Okay. You were, I guess, 17? I think 17. HOUSE_OVERSIGHT_012271

a nsor & Associates “Reporting and Tremesiption, Ine, Q. Okay. And clearly, you had some debt based on what your boyfriend had done ta you and you wanted to get paid for this massage? A. Correct. He swiped out my bank account and I needed a way to come up with $200 that -.was over my bank. So I’d get paid 300. JI put 200 in my bank and I believe I gave i a hundred for taking me. QO. Given your debt situation, it was important to you to convince Mr. Epstein that you were over 18, because you wanted to do this job? A. Correct. @.. Gotcha, Okay. Believe it or not -- let me just check with Ms, Sanchez, ~- but I think I've got everything covered here. A. I don't believe it was so much Epstein as it was the girls that were working for him, that were bringing in the service, because the girls were the ones telling everybody to lie, to bring in the business so that they could get paid. I know he was traveling them back and forth and renting them rental cars. Q. So I think what you're telling me is that you really believe that Mr. Epstein was relying on what HOUSE_OVERSIGHT_012272

o™ 19 20 21 22 23 24 sor & Associates Reporting and Trenzeripiion, Ins. Page 18 : the other girls were doing to make sure that the women that were brought -- A. Por the most part, yes. I believe that -- I mean of course that this is what he wanted and this is what he set up. Q. Uh-huh. A. But I believe he had the girls doing all the work for him, so that they were the ones that were more getting in trouble for bringing in the business than him. Correct. Okay. You've understood all the questions I have asked you today, right? A. Yes. Q. Any questions about what I've asked you? HOUSE_OVERSIGHT_012273

nsor & Associates , Reporting and Transesiption, Inc. Page 19 § coming in here today. We got this done much quicker than if we had to go to the courthouse to do it. Bee Thank you. Q. I didn't coerce you in any way to give any particular answers, did I? A. No, Q. I asked you to do was tell the absolute truth? Es fine. That's good. that's what you did, you told the truth? Told the truth. we. coLpBerceR: MM tanks so much for coming in today. I appreciale it very much. THE WITNESS: No problem. MS. SANCHEZ: Thank you. (Thereupon, the sworn statement was iS concluded at 12:15 p.m.) : ARF ER Tose tet Soe mT TUN IERIE Ts VT EDT ETISE TSMC UG SP REVS EIS Bn RD ICY aH MD aS LEAL IN AUEN DECI DD TOTTI RIN A CEN HOUSE_OVERSIGHT_012274

-~ "Topselingsac Teesusiities, inc. THE STATE OF FLORIDA, COUNTY OF PALM BEACH. ) i, the undersigned authority, certify that 5 EE »--s02211y appeared before me on the 21st : of March, 2008 and was duly sworn. WITNESS my hand and official seal this 22nd day of March, 2008. Chad L Judith F. Consor, FPR Notary Public - State of Florida Pee SN eENT LSS RIE TUTRTALEC NES SCRAP Oe TOOT Tp oN RCAC? EEN et ee ae ab bY BEAN NANT! SELECT DENT STOP TaD eT Lt UCI Os DLL) EEN LY NTT Cn an epen oe cops Tae bec TESTA HOUSE_OVERSIGHT_012275

sor & Associates Reporting aod Transcription, Inc, 10 11 12 13: 14 15 16 17 18 19 Page 21 f CERMCF TOR eS The State Of Florida, ) County Of Palm Beach. ) I, Judith F. Consor, Court Reporter and Notary Public in and for the State of Florida at large, do hereby certify that I was authorized to and did stenographically report the sworn statement of | GMM, that @ xeview of the transcript was not requested; and that the foregoing pages, numbered from 1 to 19, inclusive, are a tme and correct transcription of my stenographic notes of said sworn statement. I further certify that said sworn statement was taken at the time and place hereinabove set forth and that the taking of said sworn statement was commenced and completed as hereinabove set out. I further certify that I am not an attorney or counsel of any of the parties, nor am I a relative or employee of any attorney or counsel of party connected with the action, nor am I financially interested in the action. The foregoing certification of this transcript does not apply to any reproduction of the same by any means unless under the direct control and/or direction of the certifying reporter, DATED this 22nd day of March, 2008. AKL Lercrpe _ Judith F. Consor, Court Reporter Florida Professional Reporter HOUSE_OVERSIGHT_012276

sor & Associates s Reporting and Transcription, ine. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 HOUSE_OVERSIGHT_012277

snsor & Associates - Roporting and Transeziption, Ian. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Bivd., Suite 500 - West Palm Beach, FL 33401 HOUSE_OVERSIGHT_012278

or & Associates : Reparting and Transoription, Tas. pees creat my) a ss a NAPE GASB SLD BTL EN AE ATE TTY I A ACERS Ph. 561.682.0905 - Fax, 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 HOUSE_OVERSIGHT_012279

snsor & Associates Roparting sod Trensssipfios, Jas. Page 25 iaToucra une FIMU RT BESTE EEE OTT G ATES ee TT NT Sa aT ON EE Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Bivd., Suite 500 - West Palm Beach, FL 33401 HOUSE_OVERSIGHT_012280

TAB 6 HOUSE_OVERSIGHT_012281

oO oan A ww BP WN NN NN NY N BF BR BP BP Re Be eB bP Pp BB MW BWN FP OO AN DOU BR WN FO 2007-04-25 .1xT IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA STATE OF FLORIDA STATE OF FLORIDA, vs. JEFFREY EPSTEIN, Defendant. TRANSCRIPT OF TAPED STATEMENT or 4-24-07 Transcribed by: vicki S. Woodham, Court Reporter Notary Public, State of Florida consor & Associates 1655 Palm Beach Lakes Boulevard, Suite 500 west Palm Beach, Florida 33401 Phone - 561.682.0905 Page 1 HOUSE_OVERSIGHT_012282

— fo™ 2007-04-25 | ay 2 1 (Taped statement as follows:) 2 AGENT RICHARDS: This is Special Agent Jason 3 Richards with the FBI along with Special Agent 4 Nesbit Kirkendul and Assistant United States 5 Attorney Marie Bilafonia here to conduct an 6 interview with vs. AISO present is 7 her attorney, Jim Eisenberg and Carrie Sheehan. 8 MR. EISENBERG: And we are here -- This is Jim 9 Eisenberg and my investigator, Ms. Sheehan is here. 10 And we're here pursuant to a subpoena that was 11 served on me for MMM and that's why we're 12 here. So Ms. Bilafonia, it’s your show. 13 MS. BILAFONIA: Okay, great. 14 AGENT RICHARDS: I also want to add that the 15 date is 4-24-07, and the time by my watch is 4:21 16 p.m. 17 BY AGENT RICHARDS: 18 Q. | | we just want to start off and I'l] lead 19 off first. We just want to get some basic info about 20 you, simple stuff. I’ve got your date of birth as 21 i is that correct? 22 A. Yes, sir. 23 Q. I just want to get like your basics like that 24 stuff first. Your current address? . Page 2 HOUSE_OVERSIGHT_012283

uo oN OH WH BP WwW NY NN NN NN BP BP BP BBP BP Pp Bp Bp wi BP WN FP GO Oo FN DU HR WwW NY FH CO Q A Q. A Q 2007-04-25 | i You have a cell phone or -- And home phone? only cell. Only cell, okay. Now have you had other cell phone numbers in the past and do you know any of those? A. Q. A. Q. f that's the only one I can remember. Okay. But you had some others? uh-huh. Okay. BY MS. BILAFONIA: Oo P © > who's your service provider? Metro. Metro. And for that other number as well? Yes. BY AGENT RICHARDS: Q. A. Q. A. Q. remember? A. Q. Where did you go to high school? And what year did you graduate? What year was that that you dropped out, do you No. what year were you supposed to graduate, your Page 3 HOUSE_OVERSIGHT_012284

fo™ oOo oN DO MW BB WN Bf 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2007-04-25 | ba 4 class? . Q. Okay. A. I had got my GED. Q. when did you get that? A, About three months ago. Q. And are you going to college anywhere currently? A. Not right now. Q. Plans? A. I have plans. BY MS. BILAFONIA: Q. where are you thinking about going? A. I'm not positive what I want to do. There's a lot of things on my mind, but right now I'm focusing on my son. I have a two year old so right now I'm just working. AGENT RICHARDS: He's a handful? THE WITNESS: Yeah. AGENT RICHARDS: TI have one, too. THE WITNESS: Yeah. So in the future, I'm definitely going to go to college. I'm going definitely going to go to school. But I have, you know, a modeling career going on right now that's Page 4 HOUSE_OVERSIGHT_012285

Oo AN DM BP WN NN NN B RP eB BP RP Be BP Be eB BE Wn FF Oo AN DU BwWN FO 2007-04-25 a... hopefully going to -- some of you will notice me, hopefully, and that would be great, but I don't know. BY MS. BILAFONTA: Q. Where else are you working? A. I work for Advanced Cleaning Systems. They clean carpets. AGENT RICHARDS: Advanced what was it? THE WITNESS: System Cleaning. BY MS. BILAFONIA: Q. And where are they located? A. Las Palmas, 11 Swanee, S-w-a-n-e-e, Swanee Drive. Q. Are you working in an office there or do you go out to people's homes? A. Iwork in an office there. BY AGENT RICHARDS: Q. Obviously, you know why we're here and what we want to talk about. So let me just kind of lead into do you know Jeffrey Epstein? A. Yes. Q. Yes, of course, you do. Now when did you meet Jeff? Does he go by Jeff or Jeffrey or -- A. Jeffrey. Page 5 HOUSE_OVERSIGHT_012286

24 25 Oo Aan DHT PW NY NN PP Pb eB BR eB eB Pp BY Ke Oo ODO Dn HD UM BP WwW NY KF OC 2007-04-25 | aa Q. Okay. when did you meet him and who introduced you to Jeffrey? 6 Q. Do you know her Tast name? A. No. She was a friend of one of my friends, so I really didn't know her. BY MS. BILAFONIA: Q. when was that? A. I really couldn't tell you. I don't even remember. It's been so long ago. BY AGENT RICHARDS: Q. So RMI introduced you to him. was it ata party setting or how did you guys meet? A. No. She came to me and she said hey, would you like to make a couple dollars and I said sure. TI said doing what? She said, well, I know this Jeffrey. He lives on Palm Beach Island and I bring girls there and he likes massages and I was like okay. So I asked her, I said well, what about my age? Q. Okay. And about what time period was it that Page 6 HOUSE_OVERSIGHT_012287

a“ Se f 22 23 24 25 wo on DTD wT eRe WwW NH b Oo 11 12 13 14 15 16 17 18 19 20 2007-04-25 | a you went over there first, do you remember? A. what time period? Q. Yes. As far aS what year was that that you were in school? BY MS. BILAFONTIA: Q. were you a freshman or a sophomore, do you remember? A. I couldn't tell you. I couldn't tell you. Probably a sophomore. Q. Now you said that l& Did she elaborate on what types of massages? Q. And do you know whether PE hac given him massages? A. Yeah, she said she's done it before. Q. And do you know whether [A had taken any other girls over to see Jeffrey? A. Yes, she probably did. Q. Did she tell how much you would make? Page 7 HOUSE_OVERSIGHT_012288

fo” 21 22 23 24 25 ow AN DU KR WN BP PoP BP Re Be Be ep ep Ep aon TO UW Bh WwW NY HP OC 2007-04-25 FE pc Yes. what did she tell you? We go there and we make $200 in 30 minutes. Oo F DH PLP Now you said that you asked her, you know, what -- do I need to be worried about my age. A. Because I don’t want to be -- you know, it was like I was underage and I was young and I was pretty stupid and I didn’t want to get -- I didn't want to get in trouble, BY AGENT RICHARDS: Q. Now RJ did she -- at? In school? what setting? A. “my girlfriend's house. I don't know what girlfriend's house it was. Everybody was just hanging out. And she said -- she came up to me and she asked me. She said, do you want to make a couple bucks and © said sure. Page 8 HOUSE_OVERSIGHT_012289

fo™ 1 2 3 4 5 6 7 8 9 FEF FP RP YF RP RP KF F “SN HD Uw DBP W NP FEF OO BY MS. BILAFONIA: Q. so iii took you that first time, but then after that you communicated directly with Jeffrey? A. Uh-huh. Q. Tell us about that first time that you went to his house. Who -- how did you get there? A. one of a : friends and they dropped us off and then we went. You know, we got escorted up to the massage room and he told me everything. He said, Listen, I like massages. And we had the whole massage table laid out, the lotions and everything. And she was in there for the first like five minutes. And the first time I gave him a massage, she left the room and I gave him a massage. And she told me, she says he likes women topless massages. So & willingly the first time took off my top when I gave him a massage and nothing more than that. HOUSE_OVERSIGHT_012290

18 19 20 21 22 23 24 25 wow oN OD WN BR wWN FPF FP FPF FE RP wu & WwW hw FF © 2007-04-25 | au Q. Okay. Let me just ask you a couple of was out of there. follow-up questions. You said that someone escorted you up to the room. Do you know who that was? A. One of -- what's her name? Actually, | | PE jusc said, you know, it's up there and she just told me where it was. Q. And then you said that you and || went 10 upstairs together? A. Uh-huh. Q. And | | stayed in there for the first few minutes? A. uh-huh. Q. Was Jeffrey already in the room by the time a | eft? A. Yeah, he was in the room. Q. Okay. Was he there when you guys showed up in the room or did he come in after you were already there? Q. And you said that you took your top off. Did anybody ask you to take it off, Tike did i say it's time for you to take it off? A. No, she wasn't in the room. Page 10 HOUSE_OVERSIGHT_012291

16 17 18 19 20 21 22 23 24 25 mo a VN OD wa BR W N - PoP RP PRP pb BR WH FHF OO 2007-04-25 [EE xt Q. By the time you took it off, okay. Q. okay. And during that first massage, you said that you gave him a shoulder and neck massage? A. Q. was he face down the entire time that he got his massage? 11 A. Yeah. Q. And what did you do during the massage? Did you talk or -- A. Yeah, we talked. Q. And what would you talk about with him? A. well, we were just getting to know each other. we talked about how my lifestyle was, what he did for a living and just all positive things, really nice things. Q. Okay. what was he wearing when you first came in the room? A. I'm sorry. When he first -- when he first came in the room, he was fully clothed. And then he said, you know, wait a second. I'm going to go on the massage table and he put a towel over him just like a normal Page 11 HOUSE_OVERSIGHT_012292

15 16 17 18 19 20 21 22 23 24 25 oO ON DOD Ww FR WwW NY HF HR oe NY BO masseuse would do. Did he undress and put a towel around him? Uh-huh. > Okay. a Q. And after the massage was over, you received the $2007 A. He gives money right away. Q. I'm sorry. Was that before you started the massage or after the massage he gave you? 12 A. The first time, he gave me the money right away. Q. Okay. And he's the person that paid you the $200? A. No, it’s always I Q. HE gave you the money? A. uh-huh. BY AGENT RICHARDS: Q. What's a: Tast name, do you know? A. I don't know. MR. EISENBERG: You can't look at papers. If you think you know, you know. If you don't know, -- Page 12 HOUSE_OVERSIGHT_012293

14 15 16 17 18 19 20 21 22 23 24 25 ——— Oo ON Du BF WN BP hr he Fr oO 2007-04-25 MEE 1x7 THE WITNESS: No, I don’t know. TI don't know i : last name. He does. BY MS. BILAFONIA: Q. Okay. The only thing I'm confused about is you said that J dian’ even take you upstairs. She just told you where you should go? A. Uh-huh. Q. So when did she pay you the money? A. She paid me then and there when I first walked in the door, me and P| BY AGENT. RICHARDS: Q. She paid you before you went upstairs? A. Yes. 13 BY MS. BILAFONTIA: Q. And how much was F | paid? A. Everybody got paid $200. Q. And after -~ So after the massage was finished, you said that you had already been paid. who asked you for your name and telephone number? A, Jeffrey said, well, I'd like to see you again. Can I have your number? From what I remember, I'm pretty sure he asked me for my number and I gave him my number. Q. Okay. BY AGENT RICHARDS: Page 13 HOUSE_OVERSIGHT_012294

12 13 14 15 16 17 18 19 20 21 22 23 24 25 Oo Own DA UW BR wWN BP 2007-04-25 IE x Q. Did he write it down upstairs? He had a pen handy, I hope? | A. uh-huh. BY MS. BILAFONTA: Q. On that first massage, you said that you worked on him topless. But when you first started, did you take -- what were you wearing? And he’s like yeah, I do. I prefer that. And who wouldn't, you know? So I said okay and I took it off. Q. And you took off your bra as well? A. Q. A. Q. 14 Yes. And you left your jeans on? Yes. Oo Fr» YH Y So you said that that day you gave your name Page 14 HOUSE_OVERSIGHT_012295

“oN fo ™ 10 14 12 13 14 15 16 17 18 19 20 21 22 23 24 25 on DN OM BR WN pp 2007-04-25 Ext and number to Jeffrey. When was your next contact from him or anybody who worked for him? A. The next day, he had called me and he said would like to come out again and I'd like to see you again. I said sure. I took a taxi there and I went there again. The following day? The next day. Q. Okay. And she said Jeffrey says he wants to see you again? A. Yes. 15 Q. And then you said you took a taxi? A. Yes. Q. Is that how you would normally get to and from his house? A. uh-huh, if I didn't have friends because f don't drive, yeah. BY AGENT RICHARDS: Q. How did you get home the first time when Page 15 HOUSE_OVERSIGHT_012296

so~\ 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2007-04-25 [EE 17 PE 00k you over? Did she get a taxi? A. No, our friend came back and picked us up. Q. which friend was that? A. His name was Brian. TI don't know his last name. I really didn't know [Jand « didn't know her friends or whatever, but I met Jeffrey. And once I met Jeffrey, he was a very awesome guy and I just -- I don't know. <I ended up giving him my number so x could -- I didn't want J or Brian to drive me anymore. I would rather go to him on my own. BY MS. BILAFONIA: Q. when you would take the taxis to and from, would he pay for them? uh-huh. And he would pay when you arrived? Uh-huh. D> 2 > And then he would just give you extra money 16 when you left to pay for the taxi? Q. okay. So from the money that he paid you for the massage? A. Two hundred, yeah. Page 16 HOUSE_OVERSIGHT_012297

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Vw Bm WN 2007-04-25 a... Q. Where were you living at the time? located on MJ «So 1 would take, you know, straight SE down to where I lived. Q. Do you remember about how much that taxi fare was each way? A. ‘Twenty dollars. Q. And did you always use the same taxi service or -- A. No, I used different taxis all the time, so -- Q. And you would just call and have them come to your house? A. Uh-huh. I used a whole bunch of different taxis, whatever is available. Q. So you mentioned that the second massage, was it any different than the first one? A. Yes. Q. How was it different? A. when I went there, I went there by myself. And 17 I went up to the massage room and Jeffrey was just like regular like he was before on his stomach and he had a towel over and we started the massage and And after the massage, Page 17 HOUSE_OVERSIGHT_012298

Oo wm nN DN 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2007-04-25 [EEE xr And this was like at the end of the massage, our 30-minutes massage, usually it was even shorter than that. And he masturbated at the end of the massage and it was like two seconds and I was just topless. Q. And when he turned over Okay. I cut you off. You said he didn't even? Q. Did he ever ask you to rub his chest or rub his nipples during the massage? A. Actually, later on -- because I saw him for a long time. Later on, I asked him, you know, and I asked him -- I would give him -- you know, I would rub his 18 chest or whatever Q. So eventually you would continue the massage Page 18 HOUSE_OVERSIGHT_012299

oo™N uo ea nN DM f 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2007-04-25 TXT and he would masturbate at the same time? A. Yeah, but it wasn't on his lower area. Q. Okay. So that was during the second massage. You were paid $200 again? A, Always. Q. Always? Every time you went there? A. Always. BY AGENT RICHARDS: Q. Was it always BE char paid you? A. Sometimes Jeffrey would and sometimes Ti would. BY MS. BILAFONIA: Q. Was it usually before or after the massage? A. After the first time, it was always after. I would go downstairs and I'd get paid. Q. So just sort of tell us, when a massage ended, which I assume was after he ejaculated? A. Q. Okay. A. It wasn't like every time we went there he 19 released. Page 19 HOUSE_OVERSIGHT_012300

<——~ oO DAN DWH BP WwW 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2007-04-25 Txt Q. Okay. But when the massage was over however it ended, you would just get dressed and go downstairs by yourself or did take you downstairs? A. Yeah. The chef would make us food and it'd be great. And Jeffrey would get dressed and he'd come down with us sometimes or, you know, it wasn't -- we had fun. Q. Okay. How many massages do you think that you gave jeffrey? I can't tell you. Q. And how many times -- would you see him weekly or more than once a week? A. Yeah. Q. More than once a week? A. Q. Okay. But either you would or either a girl that you brought? A. Yeah, uh-huh. Q. Okay. A. But after a while, it wasn't me anymore. I had brought girls, but I got paid $200 to bring girls. Q. Okay. So let's talk just about when you were 20 Page 20 HOUSE_OVERSIGHT_012301

2007-04-25 carrer Ae performing the massages. what other sorts of things would happen? You said that sometimes he would just like his feet massaged. > OD PF © Okay. Totally fine with it. And how did that massage go? Actually, Page 21 HOUSE_OVERSIGHT_012302

-_ wo ON DM B&B WN BS NN NN NN BB BP BP BB Bp Be op wu F&F WwW NY FP CO HO ON DN B&B WY NY f&- CO 21 Q. And how much were you paid for that? > Two hundred every single time. Q. Okay. BY AGENT RICHARDS: Q. why not? A. why not? Why would he? Q. You seem like a nice young lady, attractive. He never had any urges to -- A. I asked him, I said, when are you going to get married? when are you going to get married, Jeffrey? He said, I'm never getting married. He has, you know, beautiful women al] the time. why would he -- no, huh-uh. BY MS. BILAFONIA: Q. Okay. Now you said that at some point you started bringing other girls over? Page 22 HOUSE_OVERSIGHT_012303

a f mo ON HD WV KR WN N N N N N N BP BP RP BP RP HY RP RP RF Be wu fF Ww NY FH OF YO) w~A N DB MH BP WwW NY FH OO 22 Uh-huh. How did that start? He likes to see different faces. O » DH > So he asked you if you had friends that you could bring over or other girls? A. Uh-huh. Q. And did any of them tell you what happened after that? A. Always, always, I even asked them. Page 23 HOUSE_OVERSIGHT_012304

—_ Oo SN Dw FF WY NY H NON N NN NN B&B Be RP Be BP BP BP BP BR BB “we WN EF OG © ON OW kB wWN BS 2007-04-25 EE <7 23 Q. Okay. And with the other girls, was it the same as what you did or different? A. Yeah, yeah. I mean, well, I was more willingly to do more, you know. Like I said, i Q. Were there girls that you brought back multiple times? A. A couple, a couple, but he really liked to see different faces. Q. Okay. I'm just wondering are there some girls he really liked and others he didn’t Tike or did he have any preferences in terms of blondes, brunettes? A. He liked girls like me. Q. Okay. Thin and attractive? A. I guess. Yeah, very attractive women. And he Did you ever bring anybody he didn't care for? How was she different than the others? Q. A. Huh-uh. Q. Yeah? A. Yeah. Q. A. Black. I screwed up. Page 24 HOUSE_OVERSIGHT_012305

Oo Oe N OD MW Rh WwW NF NON NN NN BP BP Be EPP BP eB PR “Vw BW N BP OW &DN DU BW NN BO 2007-04-25 | 24 Q. How did you know you screwed up? A. He doesn't like black women, obviously. Q. So he let you know? He told you that? A. Yeah, but he was still nice and he still gave her her 200 even though he didn't even have a massage by her. Q. How did he -- he paid you $200 for bringing each girl? A. Uh-huh. Q. And when he told you that, I mean, that's what he told you that he would pay you $200 for bringing the girls? A. Yeah. He said if you bring me -- if you bring me girls, I'll definitely, you know, give you money, compensate you for your time and willing to do that for me, yeah. Q. And you said at that point you stopped performing massages for him? A. At that point, I didn't -- it would be sporadically like. Usually, I had so many girlfriends at the time that, you know, there were some new faces to be saw. And if no one was available, then BB would go. Q. I got you. Aw So -- Q. Do you know some of the girls that you brought, Page 25 HOUSE_OVERSIGHT_012306

— a \ Oo mn nun BRwWHN NNN NN BB FP BH BP BH eB eB BE mB WN FH Oo ON AU BwWNH PO 2007-04-25 a. 25 some of the their names? A. I don't remember, really. They were like not even friends. Q. we have -- X don't know. We have some messages I guess that some girls’ names that would call Jeffrey and leave a massage. There's some giris names that are referenced. We were just wondering if you knew them? A. If you name them, I can probably remember. MS. BILAFONTA: Jason, do you have that? BY AGENT RICHARDS: A. I don't know Do you know her last name? MS. BILAFONIA: We were hoping you did. THE WITNESS: No, I don’t. BY AGENT RICHARDS: a i A. a’ No, that sounds like a black girl's name. Q. well, you brought a black girl. what was her name? A. I don't know. Don't ask me. Page 26 HOUSE_OVERSIGHT_012307

25 oO MON DH BWN B NN NN EB BP BP eB YH eB RB Ee BP Bp wnyny fF OF WO WDN DD WwW BP WO Ww FE OO 2007-04-25 MEE +x1 iz A. f yeah, I brought a. 26 Q. who is she? Tell us about i A. Sabrina, we look just alike, if that’s the girl I'm thinking about. We went to school together and I brought her one time and then she ended up moving so she couldn't come with me. Q. were you guys in the same grade or -- No, she was older than me. A Q. A year or two? A . So when you were a sophomore, she was a senior? I just met her in school and I told her. BY MS. BILAFONIA: Q. what was her last name? A. I don't know. BY AGENT RICHARDS: Q. Do you know where she lived? A. I just met her in school and I told her about it. Q. You told her about it at school? Is that where your discussion was or -- A. well, I said give me your number. I said you can make a couple of dollars. It's real easy. And if Page 27 HOUSE_OVERSIGHT_012308

2007-04-25) 24 you're comfortable with it, give me a call. 25 Q. 27 1 A. 2 Q. At school. You're not sure what her last name 3 was? 4 A. I have no idea. 5 Q. Do you know where she lived or anything like 6 that, what car she drove? 7 A. No. 8 Q. what'd she look Tike? 9 A. what she looked like? 10 Q. Yeah. 11 A. Like me, everything, PE pair, f | eyes. 12 . (Start Side B of tape.) 13 AGENT RICHARDS: Time recorder is being 14 restarted is approximately 4:50 p.m 15 BY MS. BILAFONIA: 16 Q. we were talking about MM you were at 18 A No, I was at ee. 19 q. a aay. 20 A. And that's where BE went to school. 21 Q what about a girl named Page 28 HOUSE_OVERSIGHT_012309

22 23 24 25 mo A nN DO uw fF WN NP FP BP PF RP FP FE RB ep SC 6O ea N A UM BW DnN BO A. | eal | Ra BY AGENT RICHARDS: 28 Q. I want to know about every one you brought. A. well, one of them died recently, so -- Q. what was her name? In a car accident or something? A. No, she died. Unfortunately, she got shot in the head. You guys probably heard it on the news. She got shot in the head by this guy. I don't want to even talk about it because I'll cry. BY MS. BILAFONIA: Q. Let's talk about the other Sg. A. I don't even know. TF don't know. I don’t know. There were some girls that just I would take one time and then I would never talk to again, so I don't know. Q. How many girls do you think you brought to Jeffrey's house? A. That's a good question. TI bring a lot, like maybe -- I don't know, maybe 30, maybe 30. It was all about the money to me at that time. Q. Now any of the girls that you brought, did any Page 29 HOUSE_OVERSIGHT_012310

21 22 23 24 25 Oo AN DY FW NY PRP BP PP Be BP Pp BE So n DD UW Ff W NSN FE © 2007-04-25 9 1x7 of them leave their names and numbers and then they would get appointments directly from Jeffrey or did they always go through you? Q. So you don't know? BY AGENT RICHARDS: Q. You weren't getting paid, right? A. I told them, Er said, Don’t give him your number. BY MS. BILAFONIA: Q. If you brought the same girl more than once, would you get paid each time you brought them or just get the initial $200? A. Every single time I brought a girl, okay, or I referred a girl, I always got $200, always. Q. Even if she came a second time? A. Yes. Q. You would get $200 every time she came? A. Yes. Q. Good deal. Okay. What about EP A. EEE 10? Q. any i that you brought to Mr. Epstein’s house. Page 30 HOUSE_OVERSIGHT_012311

19 20 21 22 23 24 25 ay oO 11 12 13 14 15 16 17 mo AN OD uo S&F WwW KN 04-25 Po where did she go to school? She didn't go to school. okay. How did you know RRP HS sbeen my -- she's my friend in the past. How did I neet at a party or she was my -- Actually, she was my baby's father’s girlfriend at the > © FF OD PY 30 time and AES Q. You asked her if she'd be willing to go to Jeffrey's house? A. Uh-huh, Q. And when -- do you remember when that would have been? A. Actually, a couple weeks, a couple weeks. I do remember her. A couple weeks after I met him. Q. So you brought her pretty soon after you met Jeffrey? A. Uh-huh. Q A Q. And what happened when you brought a: A The same thing. Q. Okay. Well, I know that sometimes you said that the girls would tell you what happened? Page 31 HOUSE_OVERSIGHT_012312

18 19 20 21 22 23 24 25 oO wa nN DMD UV BW NY ee un & WN BF Oo 2007-04-25 i Txt A. She went in there. She had a massage -- she gave a massage on his back. She went a couple times. He liked her. She went a couple times. And then she went, I think, like two times after that. And yeah, he masturbated, but no touching. She didn't -- there's no touching of him. No 31 touching of her. Q. How would -- how would you make appointments for girls to go over there? A. I'd call them and they'd say hi, do you want to go to Jeffrey's house? And they'd say yes or no and we'd call a taxi. Q. How would you know when Jeffrey was going to be Q. Did she always call when they were already in in town? A. Page 32 HOUSE_OVERSIGHT_012313

i aan \ 16 17 18 19 20 21 22 23 24 25 Oo CBN HD Ww BP WN FH a ee B WN FO 2007-04-25 a ..; town or would she -- how far in advance would she call you? never called me from anywhere else. It was always when I was in Palm Beach. They'd say hi, we're down here. If you want to come and see Jeffrey, you're more than welcome to. Q. So you wouldn't have like a specific time when you would go over, like be here at 11 or be here at two? 32 A. well, I'd tell them, I'd say -- well, I mean, I'd have to work around his schedule. He'd have to work around mine. Q. Do you -- I know that you said you talked to | on the phone. was there anybody else that you would talk to on the phone? A. If Jeffrey wasn't there like if I'd call him to see how he was doing or whatever, you know, he had -- his chef would answer the phone. His maid would answer the phone. That's -- Q. But was MB the only one you talked to about making appointments? A, Uh-huh, yeah. well, yeah, if Jeffrey wasn't Page 33 HOUSE_OVERSIGHT_012314

15 16 17 18 19 20 21 22 23 24 25 Oo BN WD WwW BP W NY we PR NF oO 2007-04-25 AE 1x7 available, they'd, you know, he said, the chef or you know, whoever, said Jeffrey will get back to you. Yeah, f made the appointments. Q. So when you were calling to talk to Jeffrey, you were calling the house phone over in Palm Beach? A. Uh-huh, yeah. Q. And how often would you talk to Jeffrey on the phone as opposed to talking to one of his assistants? A. Me and Jeffrey hardly ever talked on the phone. He was always busy. It was mostly [ie we'd talk when Z would get there, you know. So it was like hey, do you 33 want to come in? Yes, cool, you know. Come there, no, cool, bye. Q Do you know someone who works for Jeffrey named a A. I think I met her one time. Q. And what do you know about her? A. She was there. And the person ne, I think, I'm not positive, okay. I'm pretty sure she said that she’s from New York and she travels with Jeffrey, but I think I met her one time, if that's the girl that rings the bel], you know, in my head. Nadia I think is that one person I met one time. Page 34 HOUSE_OVERSIGHT_012315

14 15 16 17 18 19 20 24 22 23 24 25 Oo On DM FP W NY FH bt ie! uw 8 2007-04-25) <r Q. Now you said that you had teased Jeffrey about whether he was getting married. Did you ever know him to have a girlfriend or a steady? A. No, he told me he’s never been married. He’s never had a girlfriend and he doesn't want to have a girlfriend. Q. Were you ever asked to bring a girl for someone else like to give a massage to somebody else or to anyone other than Jeffrey? 34 Q. But anybody else, either any friends that were in town or -- A. No. See, my mother is a masseuse and I have experience massaging and he always liked my massages. So he told J about my massages and she said, yeah, I want a massage so I'd go over there. I think it was one or two times and I gave her a massage. Q. Now when the girts were upstairs with Jeffrey in the bedroom, what would you do? A. The chef would make me carved tomatoes, put some crab. meat in it and I'd just eat, wine and dine. It Page 35 HOUSE_OVERSIGHT_012316

fo™ 42 13 14 15 16 17 18 19 20 21 22 23 24 25 Oo AN Du BP WwW NY 2007-04-25 EE. 1x1 was wonderful, great. Q. And when you would talk to the chef -- A. Yes. Q. -- would anybody else from the house be there? A. Yes. I don’t know their names. I can't remember. There were like all these foreign girls from -- like they're beautiful, beautiful models that are from different -- they have accents. And no, but it was real interesting because we'd talk. And, you know, I'd learn a lot from them and they'd learn a lot from me just being American. And no, every time I went there it was a good Q. And how Tong you would the other gir! be 35 upstairs normally? A. Twenty, 25, 20 to 30 minutes. BY AGENT RICHARDS: Q. Back cm ttstsiSY is there anything else about her that you can remember? You were friends with her, She went three times, you think? Did she go back without going through you to set up any appointments that you know about? A. I don't know. Page 36 HOUSE_OVERSIGHT_012317

10 i1 12 13 14 15 17 18 19 20 22 23 24 25 2007-04-25 EEL Q. okay. Were there any other brought? I know you brought other SE or multiple that you Britanys. A. Yeah. I don't know. If you would say like a last name, then I would probably remember, but I don't. q. Any BBP pid you bring a? A. a. yeah, that sounds familiar. Yeah, iii HE yeah. . Uh-huh. what can you tell me about her? How old was she? A. She's older than me. Q. Do you know her from school or -- A. No. where did I meet her? I met her in my neighborhood and I asked her if she wanted to go and 36 yeah, BBE «she was only there one time, though. Q. Did she tel? you how it went with him upstairs? Yeah. , what'd she say? She said -- she's like ah, I don't know. She freaked out or something? > Oo > Oo P No, no, but he didn't want her again. He likes tall, slender and she was like short. Page 37 HOUSE_OVERSIGHT_012318

10 11 12 13 14 45 16 17 18 19 20 21 22 23 24 25 nO wu B® WN BB 2007-04-25 J. nr What did she say happened up there? Q. What did she say about him? A. She had fun. Q. She had fun? A. Uh-huh. Q. A. BY MS. BILAFONIA: Q. Did you ever, either when you gave him a massage or any of the girls, did you ever use a big back massager or it was only manual massage? A. No, it was only my hands. we never used anything else. Q. Now when you were working for him, when you were going over to Jeffrey's house to give massages, did you have a boyfriend? A. Yeah, yeah. 37 Q. Okay. How did he feel about you going to Jeffrey's house? A. He waS a jealous little boy, but he didn't care. Bring home the bacon. Q. what's your boyfriends? . Page 38 HOUSE_OVERSIGHT_012319

aN 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2007-04-25 MEE 11 Q. Now I know you that you mentioned that you had a baby. Is that the baby's father? A. No, no, thank God. Q. who is the baby's father? — Q. Okay, PY And were you still going to Jeffrey's when you were pregnant? A. I would bring girls there when I was pregnant. what you were doing at Jeffrey's house? Q. So did -- Jeffrey actually threw me my baby shower and he got me furniture and a nice rattle for my son and just really nice things, I love mommy frames. Q. was the shower at his house and did he attend? A. No, no, at my house, at my house. And no, jeffrey wasn’t there. He just sent to bring me gifts for the baby. Q. oh, okay. 38 BY AGENT RICHARDS: q. oid ever go over there with you? No. He stayed away. > HD PF No, he didn't go, no. Page 39 HOUSE_OVERSIGHT_012320

oO a N OM 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 — = Q. Did Jeffrey ask you about boyfriends? BY MS. BILAFONIA: was he curious about -- I mean, A. Yeah, we always talked about everything, yeah. Do you have a boyfriend, yeah, no, you know. We like friends. I don’t know. Just about our life talked stories. You know, he probably knows my whole life story. BY AGENT RICHARDS: Q. Now do you still have contact with him or -- who? A Q. jeffrey. A No, no one's allowing me. BY MS. BILAFONTA: 39 Page 40 HOUSE_OVERSIGHT_012321

po oN DH Lf 10 11 12 13 14 415 16 17 18 19 20 21 22 23 24 25 1 2 Q. what did you say to him? How did you put him of Ff? A. I don't know. oh, well, I don't know. No, he wasn't like begging me or anything. He asked me a couple times and I said -- I just -- there was like no say about it. I just -- I didn't go. And it wasn't like he asked me al] the time. He just it's a couple times he asked. He said I'll bring you to New York or whatever we do and we can, you know, try to fulfill your dreams, Q. Did -- when you got pregnant, did he react in any way? I mean, did he tell you if you want to be a model, you know, this is going to mess with your chances as a model or offer any -- A. No. Q. I'm wondering like how much was he giving you advice? How much stuff were you really -- what did you talk about? A. After the baby, we didn't really even talk. I 40 was -~ I was totally -- I changed. You know, I was a bad little girl and I totally changed. My whole life Page 41 HOUSE_OVERSIGHT_012322

oO ea nN DA uo Se W 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2007-04-25 xr changed. <A couple times after I had the baby, I brought a couple girls there. It was like two times. And then me and Jeffrey really stopped talking. We just stopped talking. I had my own tife and he had his, so ft don't know. BY AGENT RICHARDS: Q. Did he ever make any arrangements knowing that you wanted to be a model or were modeling? He has a Jot of connections with photographers and stuff. I mean, did he ever set up any photo shoots or anything like that? A. No. No, because he asked me if I would like to go to pursue what I wanted to do, but like I said, for the second time -- Q. I mean in town here, not to travel to New York for a shoot or anything? BY MS. BILAFONTA: Q. Did you ever get money from Jeffrey when you didn't either give a massage or bring a girl over? A. Yes. Q. Okay. when did that happen? A. I had to pay rent and I was vate on my rent. 41 Page 42 HOUSE_OVERSIGHT_012323

som \, \ fo™ oO eon DOD WwW BP WN HB 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2007-04-25 | This was before the baby. And I asked him -- I asked him for like 300. I don't I couldn't tell you how I got it was he there when you went to get the money? No. Do you know was he in town or did you call him? fp PF Pp I don't even - Q. Was that the only time that he gave you money that wasn't connected either to a massage or to bringing a girl? A. He bought gifts for the baby shower. TI can't remember now. Not off the top of my head, no. I never asked him for anything because I just felt -- I'm not like that, you know. I'm not a user and I'm not -- I don't like that. I've never asked him for money, so -- Q. What about presents, either birthday presents? You mentioned gifts for the baby. Any other gifts that he gave you? A. Yeah, he gave me a -- he had went to Brazil and he came back with a whole bunch of bikinis and he told me to choose one, so I chose one. Q. Any other gifts, Christmastime or birthdays or anything like that? Page 43 HOUSE_OVERSIGHT_012324

— Oo ON A HW KR WN NNN NN N BOB BB RB ew BB BB BE wm fF WN FP CO YO AN DMV RW NY FP FD 2007-04-25 | a 42 A. No. Q. Did he give any of your friends that you brought gifts? A, Yeah, the girl who died, He gave her a bathing suit, too, from Brazil. Q. we have some telephone numbers that we wanted to ask you about. BY AGENT RICHARDS: Q. Just to see if you recognize these or if you ever used any of these numbers that might have been old telephone numbers for you at some point. I don't know how many cell phones you may have had through the years. See if you recognize any of those. A. a 2; my number. BY MS. BILAFONIA: Q. what was Qs number? A. Es? Q. Yeah. A. What, my baby's father? Q. Yeah. A. Oh, I never knew his. Always I just, you know, calted him and I never knew his number. BY AGENT RICHARDS: Q. It was programmed in your phone? A. Yeah. So I don't know. I just know Page 44 HOUSE_OVERSIGHT_012325

Oo Aa NN DO wm BF W NY fF NNN NN NF BB BP BP Pp BB em Bp BL “AB WN HE OO AN DARD BP GS 2007-04-25 | a 43 because that was my old number like a tong time ago. BY MS. BILAFONIA: Q. At the time that you were bringing girls over to the house, were you also working a regutar job? A. I worked at City Pizza for a Tittle while, but no, kind of retired and splurged. I didn't have any bills to pay. I saved. I put money in the bank, so -- Q. we had talked about MM before. po you know someone named — Q. And who is that? A. I brought her a couple times. who is that? Q. I mean, did you go to school with her or how did you know her? A. Oh, I had asked one of my friends. I said do you have any -- It was a guy friend. I said do you have any girls that are willing to give massages and I met up with her. I called her. I talked to her on the phone. I met up with her and she said yeah, cool. Page 45 HOUSE_OVERSIGHT_012326

Oo ON A mW BB wn pe Pom bf YR Oo 13 44 A. That I know of. That I know of, yeah. Q. okay. Did you ever tell any of the girls that they would be going I told them we were going to go Jeffrey's house and it's going to be a topless massage pretty much. Anything you don't want to do, you don't have to do and it's $200, badda-bing, badda-boom. You make $200 in 30 minutes. Q. Q. No one called you and said, I think that you should call -- Q. we just have phone calls that seem to contradict what you're telling us? A. Oh, so you think that people came to me and said that I'm to call the police on Jeffrey? BY AGENT RICHARDS: Q. Was there anyone that thought that what mr. Epstein was doing was inappropriate and was concerned Page 46 HOUSE_OVERSIGHT_012327

Oo on DH BP WN NN N NN KN RS BE RP RB BP BP RB Ye eS eB Vw BP WN FP OF YOY ON DM BF WN BK OC 2007-04-25) 13<7 45 about that? far as I know, we all had fun there. Q. I mean, was there anyone that thought what he was doing may have been a Vittle bit wrong? Not wanting to report to the police, but just saying, you know, that's kind of weird? But other than that, not calling the cops. BY MS. BILAFONIA: Q. Was anybody upset that he was masturbating? I know that you said you told them that they would possibly do the massage topless. They might have expected that. Was somebody shocked -- A. Yeah, of course. I mean, he always told them, okay, and I told them, too. Page 47 HOUSE_OVERSIGHT_012328

po On Om Vw BP WwW KN eH NNN NN BP BP BP Be BP Pp Be EB Pp BE BWN FEF OO MN OH BW NN BO 2007-04-25 | Be 46 A couple girls when they did come out of there, they're like oh, my God, I wasn't expecting all of that, but he always asked them and I asked them. Maybe they were scared, who knows. But yeah, they came out of there like oh, my God, that was kind of weird, you know, yeah. Q. were any of them upset about it? A. Do they like regret it or something? BY AGENT RICHARDS: Q. Just shaken up, you know, just kind of shocked? A. A couple of girls -- well, see, we were so young and Jeffrey didn't know that. Like the whole thing was shooken up when 1 brought them there. And see, IE don’t know. ae But and afterwards like if he climaxed or whatever, if they were like shooken up, I'm like it's okay, you know. And they were like oh, I wasn't Page 48 HOUSE_OVERSIGHT_012329

ao 25 oO ON DD MV FR WwW NY NN NN BOP BRB Be eB BP BP BP BP Ww NP OCH ON ARH BW DN BO 2007-04-25 MB +x: expecting that, but they told Jeffrey that, you know, 47 they were comfortable with it. If anything, you know, maybe they were scared and they felt like otTigated, “Vike they didn't want to say. I was thinking that they didn't want to say like no, you know, I don't want to do that, so who knows. I wasn't up there with them, so I couldn't tell you. BY AGENT RICHARDS: Q. Who were the ladies who mentioned that to you who were kind of shocked? A. Usually, the girls that I would bring like one time and I wouldn't even see them again. Q. Can you help me out with some names, though? A. Huh-uh, no. I can't remember her name. She's on the top of my -- oh, my God, I don't remember. I can't remember. BY MS. BILAFONIA Nobody was that upset that called you or spoke to you that was upset with what had happened to the point that they wanted to report it? BY AGENT RICHARDS: Page 49 HOUSE_OVERSIGHT_012330

24 25 ue AN DD WH BP WwW NY BH NN FP BP FP PP PB BP Bp Bp Ke Oo ODO BN OD Uw RR WY NY RP OO 2007-04-25 [EEE xr Q. Do you know the names of some of the girls that you brought? 48 A. Huh? Q. Do you know the name of some of the girls you brought other than the ones that we've talked about right now? A, Like I said, I can't remember because usually there -- Q. There's about 30 of them, so you've got to know -- A. No, I don't know because there were girls that I didn’t even know so, you know, I just asked them. I said, Hey, would you like to make some money? Here's my number. Do you want to make money? Here’s my number, you know, and that's how it went. So I don't remember the names and I really didn't care to know their names, anyway. Q. Do you know their phone numbers? A. Now? Q. Yeah. A. No. Q. Do you know any of their phone numbers? A. No, no, no. That was years ago. Page 50 HOUSE_OVERSIGHT_012331

f™ 2007-04-25 a: 22 Q. We're just trying to find any other ladies out 23 there that we haven't already seen and you brought 30 of 24 them and we're just trying to -- 25 A. TI don't know if I brought 30 of them. 49 1 Q. Approximate? 2 A. Yeah. No, I have no clue, no idea. 3 BY MS. BILAFONTA: 4 Q. Did you stay in touch with any of the girls 5 that you brought? 6 A. | Huh-uh, 7 Q. [ER any of the girls that we've 8 talked about?: D' 9 10 11 12 13 14 15 16 17 18 19 20 Page 51 HOUSE_OVERSIGHT_012332

21 22 23 24 25 © ON DU FB wWN BP Te eel =a oe ON DO MO RB wWN BO 2007-04-2 TxT Q. And just so you know, | | we're not talking about necessarily crack cocaine. we're wondering if anybody was taking any prescription medication? A. I don’t know if they were taking prescription medication. That's their problem. 1 don't know. 50 Q. And you didn't give anybody else any prescription drugs? A. No, no. when E was 16, I smoked pot, but no. (Start of Tape 2.) MR. EISENBERG: Okay, gang, back on the record. And I assume you mean prescription medication not for prescription purposes? THE WITNESS: i thought you meant like for prescription, prescribed. No, I don't know. AGENT RICHARDS: Okay, BY MS. BILAFONIA: Q. But you weren't taking any anti-depressants or pills or anything? A. No, no, I just smoked pot. But I mostly went there sober. I was comfortable with Jeffrey. Jeffrey always made me feel so comfortable. I thought I was a big girl. Iwas 18. Q. You said that you stopped. why did you stop Page 52 HOUSE_OVERSIGHT_012333

—_~ 19 20 21 22 23 24 25 Oo wn nD uu BP WN FB He ee Pe BP Pp N Dm WV F® W NY SP OC 2007-04-27 going over there? You said you had a baby and you changed? A. Yeah. Q. what happened? A. Everything changed in my life, everything. I ended up getting a job and I just stopped. I just stopped. I don't know. 51 A. I just stopped because I have a son now and I didn't feel like it was right. First off, I was a stay-at-home mommy, okay. And what am I going to do, bring my son over there to Jeffrey's, no, you know. So I focused on my son. I had a beautiful baby boy that was my pride and joy. I didn't care for anything else. I didn’t care to tell friends. I dropped all my friends. Like he asked me do I have any numbers, no, you know. If anybody does call me, that's my mother. Like it was just me and my baby boy and it's been like that ever since. BY AGENT RICHARDS: Q. Having a baby is a life-changing experience, isn’t it? A. Having a baby? Q. Yes, it's full-time. Page 53 HOUSE_OVERSIGHT_012334

18 19 20 21 22 23 24 25 po ON Dw BP Ww NY PF Poe Pe Fe HL uw PB WN FO 2007-04-25 I 11 A, Awesome, I love it. I love it. Q. Yeah, he'll be two in August. A, Mine will be two in June. BY MS. BILAFONIA: Q. Is that when you started working with the company you're working for now? A. Well, I was -- the whole time I was pregnant, I was taken care of by my baby's father. Then I was a 52 stay-at-home mommy for eight months. After that, I worked at LA fitness, Romeo Pizza. It’s-been a year now. And what do you mean, is that why I'm working? Q. No, I just didn't know where you were working. I thought you said you had gotten a job afterwards, after the baby was born? A. Yeah, I worked at the Taundromat for a couple of days. I just like to -- I wanted to soak in my son. That*s all I did and I was like a hermit crab in the house, you know. And if anybody -- I told -- I told | | I said, you know, I have a baby now and you know, I'd rather stay at home with my baby. my old man was taking care of me. I didn't care about money. Everything was good, so a new life. BY AGENT RICHARDS: Page 54 HOUSE_OVERSIGHT_012335

16 17 18 19 20 21 22 23 24 25 oan nn wu Bw ny Bp PP RP FP Bb pe WN fF OO A. No. Q. -- how did she -- were any terms used or just in general? Did she ask you if you had any girls that can work or did you have any girls that can come over? Do you have any girls that can give a Jeffrey a massage? How did she ask for these appointments? 53 Q. Okay. BY MS. BILAFONTIA: Q. You said that you and had developed a friendly relationship. vidi” ever tell you what types of girls Jeffrey wanted or I think you said that sometimes she would say he likes this girl or I'm sorry, he likes this girl? Page 55 HOUSE_OVERSIGHT_012336

15 16 17 18 19 20 21 22 23 24 25 Oo oN OD VM BP WY KN eR BP Pow N FE © 2007-04-25 | Q. what exactly -- what guidance did she give you A. Yeah. about recruiting the girls? A. She didn't give me guidance. Jeffrey from the get-go, I really like women Tike you. So when I would go searching to make money or whatever or my girlfriends, I know what an attractive person looks like and I would -- I would bring them, you know. I didn't bring any overweight people. I just knew what Jeffrey liked, you know. Q. Did you ever talk to GE ntassages when you 54 gave them, what you did, what you would do? A. Huh-uh. Q. I have a picture of someone and I'm just wondering if you recognize this person? A. No. Was she a girl that was over there? Q. Just a face that we wanted to -- A. Okay. No, I don't know. BY AGENT RICHARDS: Q. When you would ask the ladies if they'd like to go over to see Jeffrey, what was the percentage? How many people would say sure, that sounds good. Let's go do it. And how many would just say, no, I'm not Page 56 HOUSE_OVERSIGHT_012337

pos 13 14 15 16 17 18 19 20 21 22 23 24 25 oO ont DW TH BR WY NY & Ho a 2007-04-25 i: interested. I mean, do you have -- how often when you would ask the girls -- A. It was usually girls that I brought, the girls that I had brought : Say, I would So if I was off the wall, say I was, you know, at a ciub or something and I was like hey, girl, do you want to -- they'd be like you're crazy, you know. Q. That's what I wondered, when you approached them what was the reaction? A. But when I talked to them over the phone, if it 55 was one of my girlfriends’ friends or one of their you know, how your morals are or whatever, if you're comfortable with your body, if you're comfortable with giving an old man a massage for $200. Q. For 30 minutes. A You know, everybody is a different person. Q. Sure. A But most of the girls were -- they were like yeah, sure, yeah. Page 57 HOUSE_OVERSIGHT_012338

12 13 14 15 16 17 18 19 20 21 22 23 24 25 mo ON DBD Vu S&S WY Nf 2007-04-25 [ll ocr BY MS. BILAFONIA: Q. Did you ever say anything about, you know, be careful who you talk to about this or I guess I'm wondering why, you know, were rumors going around at school or how did everything keep under wraps? A. Everybody knew. <I don't know. Everybody made jokes about it. Like it was not in school. It was more like in my neighborhood. They would cal] me Heidi Fleish and everybody just made jokes about it. I don't know. It wasn't -- but I didn't care. Q. Right. A. You know, it wasn't if you didn't get out -- it wasn’t really a big thing to me at all. Q. I guess I’m just wondering, you know, kind of 56 the way that this all came out was finally a parent found out about it -- A. Yeah, I heard. Q. -~- and went ballistic. How did you keep these girls’ parents from finding out? A. I don't know, probably embarrassing. Q. Did anybody hassle you at school? Did anybody Page 58 HOUSE_OVERSIGHT_012339

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2007-04-25 | ne call you Heidi Fleish at school? A. No, no, no, I was out of school by then, No. Q. why did you drop out of school? A. well, actually, -- why? Q. I'm sorry. I interrupted you. A. Because -- no, you didn't. well, my mother had took me me out of school to home-school me. And then I had went back to a school because I was really behind because she didn't home-school me and I had got pregnant, that’s why. And that's in the eleventh grade, that’s when I got out because I was pregnant. And I decided that I was -- I mean, I didn't know what I was doing. I wanted to have a house. I said I'm going to have this baby. I need to have a house, a car, and I set out all my goals and that's what happened. But then I ended up getting my GED and I have a life. 57 BY AGENT RICHARDS: Q. Do you remember any of their names or were they classmates or -- Page 59 HOUSE_OVERSIGHT_012340

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. It wasn't --It wasn't involved in the school so much, It was just that ae rl in the school. Q. Okay. So she was really the only like school-related -- A. Like person from school, yeah. Q. okay. A. But it was mostly out of school. So I wasn't really hanging out with the best crowd. And all the people that I did hang out with, they were dropouts. So it wasn't anything in school. It was mostly Vike the neighborhood people or my friend, one of my guy friends’ girlfriend or whatever, you know. we were all young and stupid, but -- BY MS. BILAFONIA: Q. Anything else? Do you have any questions for any of us, for me or -- 58 Q. Are you in love with him at all? A. My God, no. I love him as a friend. TI love Page 60 HOUSE_OVERSIGHT_012341

10 il 12 13 14 15 16 17 18 19 20 21 22 23 24 25 “Ph WN 2007-04-25 EE Dr him as a friend. He has done so much for me. No, I'm not in love with him. I tell Jeffrey, do you want to marry me with all of the money that you have. AGENT RICHARDS: All right. At this time, we're going to conclude the interview. It is 5:34 by my watch. MR. EISENBERG: The only thing we'll correct is that there might have been a reference to an old guy at 50 and we'll just say a-more mature individual who may be in his 50s. Thank you. (End of the tape.) 59 CERTIFICATE The State of Florida, ) Page 61 HOUSE_OVERSIGHT_012342

io fe N DD 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2007-04-25 | ag County of Palm Beach. ) I, Vicki S. Woodham, Notary Public, do hereby certify that I was authorized to and did listen to and stenographically transcribe the foregoing tape-recorded proceedings and that the transcript is a true record to the best of my ability. Dated this 26th day of April, 2007. Vicki S. Woodham My Commission Expires: December 08, 2010 Commission No.: 0D617559 60 Page 62 HOUSE_OVERSIGHT_012343

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J. Consor r & Associates Reporting & Transcription 561.682.0905 98ae64ed-fabi-461a-b5d2-heB5289cc56a 01910 HOUSE_OVERSIGHT_012346

] (Thereupon, the following interview was had:) 2 DETECTIVE RECAREY: -- December 13th, 2005. 4 This ts 1D number -- Detective Joe Recarey with 4 the Town of Palm Beach Police Department. Present & is Detective Dawson with the Palm Beach Police fi Department. vy BY DEFECTIVE RECAREY: ts Q Can you state your name tor the recard, please. 38 A 1 Q _ Spell it. please. Q Your date of birth? 14 A 15 Q How eld are you? i€ A Seventeen. 7 Q. Okay. You saw J just spoke to your mom and she 78 has given me authorizanon ro speak to you. Lam Inveshg@aling 4 case invelying a gendeman by the name of Jeffrey. You may know him as Jeff cr Jefirey lives mm the 72 Town of Palm Beach. We believe that you may have some 7? information pertaining to his residence and/or a visit at “7 his house. I'm going to ask you in your own werds tell ine 441 exactly what bappened fram the bevinning. [ may interrupt 22 you to ask you some more questions dul belore we b 2a zaise your right hand fer me. Do you solemnly swear zo tell the truth. the whole truth and nothing bet the truth su help = you Ged? 4 Addo. ie ra i (inaudible) not really friends. IE 3 that she found a way of making mene And then she sand that if Lever told anybody she'd bo beat my ass and so | didn’t even know what she was talki 12 before we got im there she’s like oh, he might ask you to Li: like take off your shirt or something. But J didn't -- it didn't matier so J saicl okay. And Pwent in his house. A lady escorted ne up to his roum. Hada bed on it. Q0 Okay. det ime back you up fora second A Uh buh. Q Yau said this was right befive Christmas. Christmas of last vear or the year besore? Last year QO Last year, A Uh-huh. Sa tls is December of 2004. nghi? I czm. cup oT ke 4a? Pd = Fanny A Uh-huh. (2 Okay. How old were you then? A lthink 14. QQ Okay. A And then i went up there. He was on the phone and he just told me to massage his feet so J went over there and did it. (inaudible} and everything and then -- Q Ilold en fora second. Hold on, Take me from when you got to the housc in Palm Beach. First of all, do you remember the name of the street? A You said it before but | just can't remember. 1) Okay. Da you remember any specifics of the house? A know where itis if] were te go back. 1] could find it. {? Okay. A twas at the end on the lefi side. OQ The end on the leti side? Okay. Do you remember the calor of dhe house? A Oh. It was too long ago. Q Okay. I know it's been some time and we did speak ance before A) Uh-huh. J Allright. So you were watking in with a: A Uh-huh. Do vou go Lhrough the garage’? A No. Yeni eo to the side vate. Yor have to knack an the back door kind of. 4} Uh-huh. A And a lady wall ask you ltke what's your name and why you're there. Q Okay. What's the lady's namie? Do you know? A No. Lihink she was the inaid because she was like fold-ng. up towels and she was bringing them upstairs Q Do you know -- can you deseribe her to me? A She might be a Spanish lady. T can't remember so weil. {) Okay. A And when you walked in, there was food on the table. They offered you food. And I waited a couple of Minutes, | guess he was in another session. I don't know. Because like a pirl walked out before | walked in and this really pretty lady. he walked in with two ladies and they were hike. they looked Jike models or something and one had blond long hair and one of them came down and told me I could go upstairs, That's probably her. And as we were walking up the staizs she told me what was voing to happen like welt, he's going to have same Jofious there and he'll probably be on the phone tor a little while. Q Okay. Did the blond lady with the long hair take J. Consor & Associates Reporting & Tran: 961.682.0905 98ae64ed-fabi-461a-b5d2-be85289cc56a HOUSE_OVERSIGHT_012347 191

ao eer Ge ee =? OAL IN Lote v0) PB RAE eH we gh fa Me ! Lie you upstairs? A Yeah. Q. Okay. How does she take you upstairs? How did vou -- A She just sar follow me. Q Did she -- did you go up a big staircase? Litle starrease? ' A Itwas ike a living room. {1 was the kitchen and then a iving room and you tumed right and then it was like a Staircase that would hke | pness it's kind of-- like spirals. Q Okay. Did she take you to where’? A lt kind of looked like a bathroom but there was no toilets. It was a cold room and it had like a sauna in there. QQ Okay. A Abdip sauna. Just a table where he was going to lay on. A place where you could wash your hands and iv just: 7! kind of looked like it was a room for that. Q Okay, Okay. So take me from there. A He turned the lights dewn some and be was on the phone. [He's hike oh. just Qnaudible) lotions are here and vou can sla by rubbing iny feet. So | put some Jotion, tubbed his feet. and then he tokl me to rub his calves, his Jees or whatever. And then Pm trying to remember. And Yeah. and then he wanted me to rub his back. J started up top and then he kept asking me to vo ower and Jower and he sui! had the towel on at uns point and then when | got tight io where bis -- right above his like butt like kid of nght above here -- Q. Ub-heh. A -- he like {lipped over and he just told me to like stan rubbing like bis stomach and stuff Jéke that and his chest and then he told me, he's like why don't vou just take off your shirt and pants. [ was Hike (inaudible), so | did that and then -- Q You had your shirt and pants on when you were rubbing his leet and calves? A Uh-buh. Q Okay. You took olf your pants 2nd shirt. A Uh-huh. Q. Okav. A And then hke he got more Gmaudibic) and he took otf his towel. Q Okay. A 1 dor’t really Eke know why he was doing that but end then he -- he was kind of like talking 10 me like trying to get to know me about my sex fe He's like oh. you're such a beautifud girl, He's lke well what are you like when you have sex. I didn’t really answer him. [ was like. Pade well. Tdorr't really like todo anything. (Inaudible) a massage. That's it. And he’s hke oh, but you're so beautiful. And he kept saying ihat for some reason. Q. Allright. Let me stop you for a secand. When he took ol fhis tawel. was be completely naked? A \h-huh, Yes. Q Okay. And you were in bra and panties? A Uh huh. Q Okay. Okay. Take me trom there. So he took off his towel. he's lething you how beautiful you are. A And he teld me. he told me to mb his nipples like he's like oh. just pinch them or something. And | was like allright. And then be had one hand on his P. Q. Okay. A And tien he like ined rubbing on my prives (phonetic) and he had like the imddle of my bra was the snap of parl and he ke snapped it off and be was tying to feel my boobs and then he jusi grabbed my thighs and he was jacking humsell off at the same time und then he went down to -- sbould Tsay that? Q. Savit A My vagina. BY DETECTIVE DAWSON: QQ We've beard if all A Yeah. And he like didn't take off my panties but Li he like pushed them to the side and he's like {celing down there and he's tike don't worry. don't worry. I'm not going to go in, dada da. [t's so weird. Tm lke anyway. And then he stared rubbing dewn there and then he started talksug dirty. He's like ah, your clit feels so hard and stuff And {like backed away. I was like (inaudible). Q Okay. AC any time did you tell him no? Did you tel] hin yeu're not comfortable with this? A PLeucked away and T said [was like well. [don’t know if E shoule do that and 1 was like very hesitant and so seared that] didn’t know what to do. Kind of Jike you just Want to eetilover with to get tover with, And then -- and f was fecling so tense. } guess that’s why he was saying it. And then he actually stuck his fingers in there and 1 backed away again. He goes oh. don't worry. don't worry And te's bike okay. Pm sorry. Then he went Back to the outside and he was still jerking himisell off and then finally he finished himself. wrapped up his towel and said there was $200 0n the counter amd then there’s an extra hundred for Hfe’s itke oh. I'd like to see you again. | was [ike yeah. | don't know. Q Okay. Let me bring yeu back to when he snapped olf your bra. A Uh-huh, Q When he snapped it off. did you take it off or did 3 (Pades @ ta 9) J. Consor & Associates Reporting & Transcription 961.682.0905 98aeb4ed-fabf-461a-bSd2-be85289cc56a Q1912 HOUSE_OVERSIGHT_012348

aoe he slip it offof you or did you just have it on and it was just banging? A Yealy, it was just hanging. He had snapped it off and it was just right here, Gt IS oy By Q Okay. At any time did he touch your breasts? & A Yeah. ‘7 Q When -- okay. So vou're standing there, your bra 8 has been unsnapped. What kind of panties did you have on? ; © Do you remember? A Athone. Q A thong? La A Uh-hub. Q He started touching you on the outside of your panGes os did he move your panties to one side? eae peor boat 5 A On the outside first and then he moved, he maved °@ them over. au Q. Okay. And then he started touching you on the 12 outside of your vagina? 3 A Uh-huh. 29 Q And he told you he was not going to ge inside. 24 A Yeah. Be Q Atwhat point did that change? PP? A When he started feeling dewn there and then 24 when -- pretty soon. an Q When you say Higers, did he use more than one TL fuper? Z A Cthink he used two but { don't know, I Q Okay. & A And then afler T told him, | backed away and |] was S kind of like shaking my head no, he's like okay, I’m sorry. 6 And then he kind of still put bis fingers down there. He was just like pushing really hard on me like, | don't knaw,. he just, just tet ke his Gngers weren't in me bul it was ciose enough lo where it stil felt weird. ( How cid you -- how did -- when be had his fingers inside you, you backed up to ect them out or -- A Yeah. And to Jet him knew that [ don't want to do thar. Q Okay. And none of this was told to you by | thar this would happen? A No. Q. Okay. A That's why when [ got out ] was freaking out but ] OW fe pe fd Wal NO age we ets ~l toy: 1 i 2 happened and 7 told her wha? happened and she said oh. it’s okay. He did that to one of my other frtends | brought here. And | was like and you let him do that and still got me in there’? And she's dike oh, it's okay. You got $200. Does it matter? | said did you have te do that? She said no. Twas fike all right, then you don't know how it feels. Page 10) ea) A Umni, then {inaudible.) No. | krow what it is. 3G Q Okay, Did you visually see his penis? i? A Ub-hub. Yeab. “48 Q Would you say it was circumcised or uncircumcised? |- : 73 A [would think it would be circumcised but J tned .23 didn’t want to see what was actually happening. , igh A tle came. a. gue A No He didn'task me foranything. Like [ think didn't even say anvthing to her and then she asked me what : ‘ $ Lao Q Okay. How long would you say this session lasted? Page 12 4. wal She's like let's just zo shopping and stuff and I was Itke 2 no. 2 Q Okay. During this time that this was occurring, 4 he was jerking off you said? 3 A Uh-huh. ic (Q Okay. What does that mean to you? 1 mean like is = it something that -- do you know whal masturbation is? g A Yeah. 2 Q Is that what you consider -- iG A Yeah as Q Okay. Did you -- I'm sorry. Le A That's okay. Q De you knew what a circumeised and uncircumcised 24° penis 1s? not to look. Q. Okay. AN dowas kind of just like locking away because | Q Okay, You said that he had Hnished. Q Okay. é A Because he was dike a bie sigh of relief like he had been done and he just got right back wp and -- Q De you know where he came on? Was it or the iowel? Was it on himself? On the bed er -- A Tibink it was on the towel lilce nght between his ees probably. 3 Q Okay. As] told you before and | explained to % yorr mom, what he did was wrong, okay? Sf A Ub-huh. 12 Q Cwant to reassure you an that, Okay? Atany point did be ever ask you to leave your phone number or -- yee y on he asked ine my name in the beginning. Zo Q Po you have any formal massave training? 4 A No, That's why | thought (inaudible). J. Consor & Associates Reporting & Transcription ate 561.682.0305 98ae64ed-fabt-461a-b5d2-be85289cc56a 01913 HOUSE_OVERSIGHT_012349

c™ Page la: Fage 16 1 A Probably like around 45 minutes. - DETECTIVE RECAREY: Okay. Can you think of } 2 Q Forty-five minutes? Okay. og anything else? 3 You said he wanied to see you again. Did the 3. BY DEFECTIVE DAWSON: 4 blond hair lady try to take your information or -- 4 Q Was he im good shape? Was he a blob? 5 A We said oh, well, | think eave my 5 A He was old but he wasn't as muscular or anything & secretary your name and number and smffandT'dliketosee ~ 6 Jike thal. He was like a regular old guy. 7 you again and -- “ BY DETECTIVE RECARFY: & Q Did anybody from the house ever call you again? . 8 Q Did he have any accents or anything or -- 9 A Hub-huh. a A Huh-huh. Ne. 10 QQ Nobody ever called you? 18 Q Did he ever introduce himself to you? Lah A No. “ha A No, That's why E don't know who you're talking 1a Q Okay. So you only went there that one time? '2 about. | guess | heard that name in front of 3 A Yeah. (Inaudible) took notes on his name er anything. 14 Q Okay. Is there anything else you'd ke to add? Q I know this is difficult for you and } know it was 15 A Yes. There was another girl that tike I -- difficult from talking to vou the other day and il’s 16 there were other mumors ike they were partners in doing “16 difficult talking to you now. Lv that. a A Uh-huh. 14 Q Who was that? Dlg Q But I've talked to a lot of people and f really 1 A. This i fm not. I'm not quite sure. iS appreciate you talking to me ahout this. 2G My brother would probably know because she's older than us | 20 A Ub-huh. 22. becanse she met her at Publix afterwards anc vent 2 and gave her some money. | think they had to shure the $100 | 23 that they did. (Inaudible} a hundred bucks. And then I A No. 1 heard another thing at my school that there was fike a numer DETECTIVE RECAREY: No? [nr going to go 25 about this other girl it happened to. | just didn't sav eee ahead and conclude this statcment. ‘The ime by my Q Is there anything else you'd like to add to this statement? By tm anythurg because | didn't want anyone te know about me. 1 walch 1s 3:25 pun. 2 Q Do you know who the other girl was? z (Thereupon, the interview ended.) 3 A Ycould ask. is se 4 Q > No. Don't worry about it. 4 3 A Okay. i) 5 Q Did he know you went oI 6 3 A i don't think he knew anything about me. 6 2 Q Like the questcons that he asked vou in trying to 2 2 20) get to know you, what kind cf question I mean other than (he LG 3.1 sexual questions? lL Wes A He didn't really ask me -- oh, wait. he asked me Jif £3) what school Pwent to. He was just asking ine like how | is ié felt because you're good at massaving. Ginaudible) how Twot - 14 23 om the business. | thought yeah. that'd be coel. And he LS 1& ined to ask me se do vou have a boyfriend, what do you do; 1.4 1? for fan. Pretty much like it was kind of weird how often “4? L8 Gnaudible). How do you like to have sex. Oh. do you like + 18 193 i} when peopie bke touch your boobs. Tsaid no, I don't 19 “20° really bke when people touch my body because nishy und 28 finaudible) dot let anyone touch my boobs anyway. He did 2 1 it, a QO Ohay. 73 A But he kept asking me like abeut his nipples. 24 25 He's like ch, that feels so goad like -- aS J. Consor & Associates Reporting & Transcription 561.682.0905 98aeb4ea-fabf-461a-b5d2-be85289cc56a 01914 HOUSE_OVERSIGHT_012350

Pays 18% CERTIFICATE STATE OF FLORIDA) COUNTY OF PALM BEACH ) 1, Sandra Rossi. Court Reporter, State of Florida at Large. certify that | was authorized to and did stenogrephically report the forgomez proceedings, and that the transcript is a true and complete record of the tape as listened to by me. Dated this 30th day of January. 2007. Sandra Rossi, Court Reporter 0 iFade 28 4 ' tr J. Consor & Associates Reporting & Pranscription 261.682.9905 98ae64ed-fabf-461a-b5d2-beB5289cc56a 01915 HOUSE_OVERSIGHT_012351

TAB 8 HOUSE_OVERSIGHT_012352

IN RE: J&FFREY EPSTEIN DRAFT TAPED CAR INTERVIEW ii 02505 HOUSE_OVERSIGHT_012353

(Thereupon, the following interview was had:) MS. ROBSON: -- say anything to you about this (inaudible), nght? BY UNIDENTIFIED MALE SPEAKER: Q You know we're nol going to argne again. We're not gomg lo keep much from you. A {just don't want to rat anybody out. I’m not an 9 idiot. Came on. now. 10 QQ Thal wasn't more of a ratting out. It was more of ll oa-- 12 Complaint? 13 You got it. (inaudible.) You're a sinart girl. I'm not an idiot. Yeah. No. vou're not an idiot. Sol guess kanna. you know. (Inaudiblc.) I'm kidding I'm kidding. | don't even know who he is. A Idon't know. It’s such a big -- there's so many girls oul there that have worked for him it's not even funny. Q Really? _A_,_ Like I said. some bring friends who bring fricnds RH tse he Se OpDAS NM ho -t 22 23 24 So) Page 3; Who boing fiends, DETECTIVE RECAREY: Allright. You notified Jimmy? We w he DETECTIVE RECAREY: Give him a call, (Inaudible) 692 -- our ending mileape was 692323. I'm sory, 6923. Our begmning mileage to head pack southwest -- Gnaucdtble). Gnaudible} white Female Gnaudible) same mileage 6923 What vas that? UINTDENTIFIED MALE SPEAKER: Fire truck. Ms. ROBSON: So when will L know what's going to happen” BY UNIDENTIFERD MALE SPEAKER: Q Well. here's the thing. What are you doing tomorrow? Well, no. aere's our goal We would like {9 at least tu talk (o -- help me. wsl on UNIDENTIFIED MALI SPEAKER 2: We want te ty! lo Inlerview some of these -- MS. ROBSON: (Inaudible.) BY UNIDENTIFIED MALLE SPEAKER: Q Right Tonipht. A Tonight t'm free so -- Q Okay. 25 BY DETECTIVE RECAREY: ar) ws Ww far r (oe) oN rR No No UNIDENTIFIED MALI SPEAKER: | notified Jimmy; SoA nom tk wpe ye pe RR ow a dH um fon Oo Rs an) Bho ND om WwW ran) from college and stuf. QQ. Temorrow yor're working? A ‘Fomorrow } go to school from 12 ta 4. BY ENIDENTIFIFID MALE SPEAKER. Q) Uh-huh. A Wednesday I go to (inaudible). Q Well. tomorrow whal are you doing after 4:00? A Nothing. Q Okay. BY DETECTIVE RECAREY: QQ Do vou have to po to work? A (Inaudible) Thursday BY UNIDENTIFIED MALE SPEAKER: Q. Okay. We would prefer to do it sooner than later and our, our request from vou at ths pomt as we move along as really for vou to make that phone call and introduce us and say, vou know, these are the detectives from the Palm Beach Pole Department. Uye told them evervihing. They're on their way lo your house. Do vou know these girls’ schedules by chance or anvthing like that? Do they sill go to high school? A Well, BBBBRil goes to high school, She's a senior. Q Okay. And that's. that’s who we want to speak to tomehbt. From what youre telling us, we're confident 25 will not be going and talking to Jeffrey. Depending on how : Page Sf that goes we night pive you g call and ask you to make another phone call for us. [f we could break out the list as we drive, make sare we have a little order of obviously based on what vou're saving, should be the last on our dist. We don't know if she's still -- DEPECH VE RECAREY: [RE she’s in Orlando. We can do that one ever the phone. BY UNIDENTIFIED MALE SPEAKER: Q) Now didn't vou sav she was back though? A TBR s back. 1 don't know if she has class tomorraw but I don't know if she felt already or not. Q. What kind of class? |s she in college or something? A College. Yeah. she’s up in Orlando. T don't : know. She might hive already daft, What ix today?) Monday? | QQ Yeah A Ob. well she might have afready feft todas. She had class today. Q. Oh. today. veah. A Yeah, she does. Verv rarely just to see her parents and stulf. [ike she lives up in Orlando, She might come back once a menth on the weekend to visit her parents. Q Now do vos talk to at all or net really? A {hung out with her last night. She came dewn 2 (Pages 2 Lo 5) 02506 HOUSE_OVERSIGHT_012354

Nom Go Oop Ww wo ~~ aowmip Wwe a Do OoVan 2 ree wow ©. 16 Ll? 13 19 20 21 99° ee 23 24 25 Q Uh-huh. : 9 A But-- i 2 Q That was Suaday night. So she was around just . 3 last might. i 4 A She was around last night but. like I said. J : don't -- she might be still here. she might be upin Orlando ; 6 now. i 7 BY DETECTIVE RECAREY- : 8 Q Okay What aboufiP 3 A Oh. E don't like her. 7 don't like her. What i 10 about her? She never worked for. she never worked for | 11 Jeffrey bul she's been te his house before. She knows about : 12 it. Knows about everything that went on. She was the one ; 13 thai was with (inaudible). ; 14 Q Okay. Docs know Do they i15 know cach other? 16 A | dou't Know. ii? BY UNIDENTIFIED MALE SPEAKER: :18 Q Then phonetic) tives like a couple blacks ,19 away from you, yeah? 2 A Yeah. BY DETECTIVE RECAREY: : Q Okay. Bives (inandibic.) A (Inaudible.) Q Okay. Why are vou afraid of Gnaudible)? Page 7: A Oh, ne. Fri not afraid you know whut it comes 1 dewn to? Ht comes down to this. Cin not afraid of any of 2 these girls but when [ almost rough I crits to 3 BS nova; brought mn to our group whieh was stupid 4 and instead of being mature about what happened three vears 5 ago. vas hke I'm going to kick vour ass. da da di. i: 6 and Twas like you know what? You taik a good pame. Leave | 7 me wone prelly much. It get ridiculous se | bad lo change : 8 my number and | saw her at (inaudible) one night. She : o Jumped me bora behind. | go vou didn't sav anything tome 10 all mghl and when she jumped me trom behind she jumped me | 71 so whatever. Garls are stupid. :12 BY UNIDENTIFIED MALE SPEAKER: 13 42) Alright. Whe else was on that list vou got i there? BY DETECTIVE RECAREY: Q Do you know a girl named IP il (Celular telephone discussion as follows:) DEVECTIVE RECAREY: Hello? Yes. Hey, Dablia. Okay. Right. Okay. Right. right. night riyht, nght, right, right. Well, that’s the casc, that's the situation. Right. Okay. Allright. Right. We're gonna meet with her tonight. (Inaudible.) Okay? All ripht. Bye. MS ROBSON: So what 1} not heme? BY DISTECTIVE RECAREY: QQ Ohav. Wellwwe'll trove an. BY UNEDLNEERIED MALE SPEAKER: QQ ‘That's our -- right now we want you to help us with an order of who in your mind (inaudible) vou're confident was 16 or maybe 37 when they went there, who prebably no longer bas anv connections with Jeff (inaudible) who ut least maybe a day might keep their mouth shut. A Okay. Well with I don't know how ald she is because she hed about her age. She hed lo me when | first met ber When | was 18 she lold me she was 18. (mnaudible.) Well she Jer her purse at my heuse and she luld me to make sure that | didn't took in her purse. When Twent through her purse | found her state license that said she was 16. So she hed to me about her age. | don't care about working for Jeffrey but -- Q We're looking for pirls that went upstairs with Jeff. A Yeah. Q Those three or four girls, whatever vou can, yout know, help us out with here, that is our goal in the next let's sav 24 hours. A Okay. QQ lstorea y OUE Page $f might be as simple as we give vou a call on your cell phone -- A And you call them. Q And you suy hey, we need you to call this girl and tel] Inere we are out front because that’s one thing we want tu do is figure out where these girls live tonight su that we can reach out te them and sav bev we're oulin front of so amd so's hottse, cam you pive her a call and let ber know that there's 2 couple of detectives outside and na, vuu're not Kidding. they reully are there and heads up. You Koow what] nea? A Yeah. QQ That's what we'd like to -- we've got a hal! hour there if we can make some details on thal so we're all on lhe same page. that’s what we're goimeg to do. So how many girls was on the sl that we started with? A You asked me if | knew on Q We dont know -- what we're going lo need is the Jius| names of these girls as well. So if you've got some last names. A don'tknew. | mean -- Q That's okay T mean -- what abun A P I've heard of a gir] named but | 25 don't know (inaudible), vou know? ‘To my knowledge I don't 3 (Paces 6 to 9) 02507 HOUSE_OVERSIGHT_012355

y 1 know. (Inaudible?) 21 / 2 Q No. (Inaudible?) : 2 ( 3 BY DETECTIVE RECAREY: = : 4 Q No. (Inandible.) 1 4 5 inaudible), Not that} know of Ihnowa : 5 6 girl ne 1 definitely Ginandible) not like i 6 7 that. i 7 8 Q (audible?) : 8 9 A Don't know. I know (inaudible). 9 10 BY UNIDENTIFIED MALE SPEAKER: 710 il Q Besides vho clse ended up upstairs with Jeff? } 11 12 A That's it. 12 13. Q Okay. 13 14 =A = 14 15 Q Okay. £15 16 A (Inaudible.) 16 17 Q Okay. Do you know their last names? ;1? 18 pom last name | don't know. } don't know i18 1g s last name. (phonctic). :19 20 And | know EB brother. 20 21 @i i I think the lasi name is | Ldon't $21 22. know if (inaudible) or anvihing because [ know like : 22 23 (inaudible). It might be BR i2 24° Q. (inaudible?) 25 A__ Royal Palm (inaudible.) oo Page 11; J Q Unaudibic’?} 1 2 (Inaudible.) 2 . 3 Q Do you know their phone uumbers by chance or do; 3 : 4 you have them in your phone maybe or -- i 4 C 5 A Let me check. Okay. What's the first girl? i 5 6 Q ' 6 7 A I know by heart. It's f | and ? 8 isa 8 ont cyen have in my phone. Q m 2 . 1 know hers by heart. | Area code How about p no, | don't know her number at al 14 Q 15 A (Inaudible. ) --H I'm pretty sure that's her number 16 Q 1? A becausc that’s ihe only ones [| have. 1g Q 2 A {know her brother's numbcr mC l don't have her number. 22 Q Is that his cell? 122 23 A (Inaudible.} 23 ‘ Q. Okay. (Inaudible) i24 A__ Uh-huh. (inaudible.) Page 127 Siciliano should have | (hey hung oul (0 Fw hang out. A_ Quine abit. And vou should also (inaudible) and E know the fitst three digits it's wmight b bit Phaven't talked te ber in a while. Q Seal we start with Jhomphs. based on what you Just said iSbouta Introduce us to HE who then could introduce us Lo -- A Vo Jen Reves. DETECTIVE RECAREY: Okay, | HE hanes oulwilh Obviously ‘in gone lo tuk to | BY UINTDOLENPERTIED MALI SPEAKER: Q Right. We want to avoid Do all costs. So our guestion lo vou ds thes group of three pirls -- A Phew all Know each other Q They Know each other A Thev all know each other, () von [I A ‘Yhev know P| They know everybody. It's ike a group of people who all know each other. Q Faith Gnaudib‘e) A The only one thev might not know is Page 13 Q All we've pot is a group of girls that -- A They've all heard of each other (inaudible). Q Now do they all go to school with cach other to your knowledge? A Some of them. Not all of them but sone of them still po to school together. Q EERE ces she still go to school? Q Unaudibic.) a t don't know if HE craduatca last A year or (maudiblc). YY I'm not quite sure. || might have graduated last vcar. Inaudible.) Q Okay. So they wouldn't have as much contact as the other group. (Inaudible) that goes to school. A (Inaudibie.} Q. My office is warm. The bullpen out there is luke wann. UNIDENTIFIED MALE SPEAKER 2: cald. BY UNIDENTIFIED MALE SPEAKER: Q Yeah. and it's a (wenty-year old building so nothing really circulates as wel! as it should that old but Cinaudible) in the car. If there’s anybody that we need to (inaudible). iS e' re not going to talk to. } love the 4 (Page Ss 10 £o 13) 02508 HOUSE_OVERSIGHT_012356

yo Wok WIN a a) RuUBWNHOWOND = IM NNM NNN Be iO BWNE Ow © SMe ON NUsWNe nied — 12 13 14 16 16 1? 18 19 20 21 22 23 4 yan chspatch. A couple of female: BY DETECTIVIE RECAREY: Q (hnaudible.) A Qnaudible) call her, open veur mouth to anv of them. - BY DETECTIVE RECAREY: (2) We will absolutely tell them that that they be obstructing an investigation. A The only one that’s going to open her mot would ith s probabl EEE The only one (inaudible) sav anything wouk! be Q Ave these girls, you know, are they embarrassed about what they've done? Would they rather nobody know Wl: it possible or are they out there Maunung it? A They don't care. Q Okay That was my question. A These girls don't care, For the most part Urey don't vare. QQ Oksy A Otherwise they wouldn't do it. Q I tend to agree but that dvesn't mean you everybody clse Qnaudible) get in on the action or Gnaudible) in general. A (Inaudibfe.) Q Jhear that: Oh, okay. Cnaudible) call addresses. After we're done with think talking about next? (Inandible.) Oh, okay. A Well. I don't know (inaudible) well. , Gnaudible) get some Page 1); hve were! © We should probably try her since she would be feaving. You wanl to try -- Es off to college. A (naudible.) UNIDENTIFIED MALE SPEAKER: (Inaudible) necessary. (Two minntes of inaudible conversation.) (Thereupon, the tape ended.) 5 (Pages 14 to 16) 02509 HOUSE_OVERSIGHT_012357

TAB 9 HOUSE_OVERSIGHT_012358

TN RF: JBPPREY EPSTEIN TAPED INTERVIEW OF P| DIRAF T 02420 HOUSE_OVERSIGHT_012359

DANN Bw NE has KO ONE RON (Therenpon, the following interview w nd:) BY DETECTIVE RFCAREY Q Today's date is October 4th, 2005. ‘This is 1D number 7915 Detective Joe Reearey of the Palm Beach Police Department. Present at 1301 (inaudible) Road is Detective Michael Dawson of the Palm Beach Police Department. And can you shite your name for the record? how do vou spell your Jast name? Okay. How old are you! I'm 18. Taghteen, Okay. You're currently in college? Yeah, Okay. What college are you attending? Okay. And your dats ef birth is? Okay. Can you raise your right hand for me? Do you solemnly swear to lell the truth, the whole truth and nothing but the truth so help you God? A Yes. Q Okay EE if you could tell me From the : ipstein. | know you have some information and we are conducting an investigation, We were here last mght, spoke with vour mom and dad. Tfyou ean : just start from the bepmning as to how you met him. A Okay Q And how i came about. A | (Audio 1:26) Q Okay. Tlow long ago was that? A Itweus probably about almost a year ago. Q Okay. Okay A of scared me when | went there so | just decided nat to go back. Q Okay. The first time you wenr with BEE aid yon go upstairs with him? : A No, J slaved down in the kitchen. (Andio at 2:03): Q Okay. Didlrel! vou that -- what was i entailed as 10 what had to be donc? A Well she said the first time vou go it's just like : amassage and she said like well, the more sou go supposedly | the more he bke expects and staris Mirting with girls and that’s what kind of like scared me. QQ Okay. I’ve sntersiewed other gitls and thev've the mass Pow RyInunewWwnek there's more fo that. More to the massage. Okay”? ‘That's why | didnt want more to be in here. And you can talk lo me about anything. Okav? Like } said, I've interviewed other people already who have tok me what Wanspired in that room. I know it's going to be difficult for you but... A Well, the hirst trme | went there ? did a massage and he was just asking mea Jot of questions. He seemed Dke really mice. And then he kept like staring al me and stuff, And ther like } did a massage and he just kept looking atr vas hike oh, you're bemp shy and I'm like yeu. c yeah And he was like why are you like being shy and I was like oh, 1 don't know. And then he would Itke change the subject and he started talking about other things. And then when we were done he said that if hike [wanted to come back and do more then he would like pay me more and then T would have tof talk to Haley and [ could come back. Q Okay. What kind of questions did he ask you as you Were massaging him? A He was asking about -- it was a year ago. | don't remember evervuune but... Q Right. A Fle was just asking me iP bad any friends that Page 5 might want to give a taussage and [ said T doen't know. ‘Shen he asked me about what ] wanted to de when T grew up and stuff like that and ] asked him what he did and he said he was like a scientist basically Q Okay. Pid he ever ask you how old you were? A No. {Audio at 4:08) Q No. Did he know that vou were 17? A No, I don't Uunk so. Q Wellit would have been 16 if it was a year ae, night? A) Wellithike was almost a vear age, (maudible) 17. Q. Okay. During the massage did you -- were vou naked or -- A No. Thad my clothes cn Q You had afl vour clothes on? A Uh-hoh. Q Okay. Did be touch vou in apy way? A He was like kind of like leaning towards it but | was hke you could tell [ was shy so E think that's why he didn't wy. But | heard about other girls that be -- that he gol ‘irtatious with them and he snade them take off (heir clothes and stuif. Q Okay. Whal -- that was the first (ame you went, right? HOUSE_OVERSIGHT_012360 02421

BW Nw wa m oO Nes it 1? 13 14 lb 16 1? 18 aS) 20 °° ce 22 ye 24 Zo 19 1} lé 13 14 15 16 slay 18 13 20 22 23 24 25 A Yeuh. Q Okay. A Well ano. Jt was the second lime that! gave him apiassage. ‘The first time F went up with : 4 Q Okay, You went upstairs with Ey i 5 A No, ! was in the kitchen. : & Q You were in the kitchen. That was -- you only had : 7 iyo limes that you wenl there? : 8 A Youh, 9 QQ) The firsi time you didn't do anythmg but just sit i10 in the kitchen? i7 A Yeuh, 4? Q Who did vou sit in the kitehen with? °43 A Tle had a cook that was there and he had -- there i 14 was ke two other girls there that live wrth him. ilb Q Okay. Did you massage his back? Was he naked :16 when vou were massaping hn’? : 1? A Well. he bad like a towel around his -- his upper ils was (inaudible) but he had like a towel around him. i419 Q Okay. Did he ever remove that towel? 20 A No. 21 Q When vou were inassuging him he never removed the towel? A No Q Okay. Did you -- did he have vou touch his Page private area? 1 A No. No. J wouldn't du that. {Audio at 5:50) 2 Q You wouldn't do that? 3 Okay. Did he touch vou in your private area? 4 A No. No. 5 QQ No. 6 A Ee kept Ithe staring af ie and Like, 1 don't knesw, a Tyust felt uncomfortable and] left. But] heard other & stories that like -- S QQ Right. Pm concerned with vou | know about : 10 other stories and I’ve interviewed other people have told me f 11 different things. ‘Vhat’s why I'm Uving te find out what 12 happened tu vou. Okay? 13 A Uh-huh i414 Q You're the viernn in this so that's why Tia using :15 to Fmd out what happens to vou. 16 A Uh-huh. :17 Q Okay? Who teak you upstairs to the moon? :18 A This oir that hives with him. : 19 Q a So Bok: vou up? : 20 A :Z1 Q io she tell vou anything? )id she say anvihing? 122 A Huh-huh. There's a massage lable and she just 223 laid a towel down and she said that Jeffrey will be out for i24 his massage. :25 like, you know, Eke Q Okay. Have vou received any massage tuning? A No () No fhave to ask. Was one of the two girls that was in the kitehen wath you? A Yes. (2) Okay, Did vou ever go back to his house? A Well. 1 just went there vice. () Right A After that -- Q Alter that you've never come back? Never went back? How much did vou receive for the massage? A ‘Iwo hundred. Q You received 200. {Audio at 7:43) Okay. Did I explain to you what ¥ as going to be invelved? A She said the first Gme vou go there vou pretty much just give a massage, but the more you go there like the mare he expects. And that's it. That seared me. Q That's what seared you? BY DETECTIVIE DAWSON: QQ) Pal she say (inaudible) or did she Gnandibie -- A Sav didn't have to say thesactly but she implied cing your clothes ulf and stuff like : Page G thal. BY DETECTIVE RECAREY: Q Okay. So you didn’t remove any of vour clothing? A No Qo. What were you wearing?) Can you remember? A Edon't knew [twas along time apo. | don't remember enactly. Q) Okuy. A T don't want lo tell you wrong. QQ TRnow. And Pknow vou already told vour moni what happened. And hike | said d know thos is hard for veau but... A dasas just scared. P just didn't want my name to hke -- Q Dovtworry, Youre not the only person [ve talked to. Okav? There's a tot of people that I've talked te and I'm going to talk to. Yow did vou gel to his house? A) Wih Q. Naley. m the kitchen. A Yeah, Q What about the second lime? A The second ume ! drove and she came with me. Bevanse [ didn't want to -- took vou the first time and you sat 3 {Pages 6 to 9) 02422 HOUSE_OVERSIGHT_012361

aa DINO fb We 9 10 il 12 13 14 15 16 1? 18 wo 14 16 17 18 19 20 21 22 23 24 25 Q You drove. A Yeah. (2. Okay. What is it vou drive? A Lused to have a Cavalier. Q A Cavalier. Whal color? A Red. Q Okay. Can vou describe to me what Mr. Epstei looks like? Jeffrey looks like? A He's tal! and he has like grevish/black hair and he usually wears like glasses and he has bluc eves. : Q Okay. When you massaged him. you massaged his! back area? : No. Can you describe what his body looks like? He's not fat but he's not like thin. He's like normal like average. A Yes. And | did his fect too. Q And his fect. Okay. Did vou do his leps? A Yeah. like hts calves. Q His calves. Thigh arca’? A No. (9 No. His chest area? A No. Q A Q Average? Okay. Is he hairy? Is he not hairy? _Q Alte bit? A liule bit he's got hair on his Page Vt: back’? A Yeah. Q Yeah? How about hair on his chest? A Um-- Q You don'tremember? Okay. He did not touch vou inappropriately? A No. Q No. Did he masturbate? A No. Q No. Do you know what masturbate means? A Yeah. : Q Okay. Why don't you tell me what it means just so} I know so you know. A Plaving with vourself. i QQ) Okay. Okay. E have to make sure you understand : what i nicins. : A Yeah. Q. Okay? J know it's difficult, He didn't touch himsclf - A No. Q -- while you were massaging him? A No. Q No. Is there anything cise you'd like to add? A No. I mean I heard of other stories that he did DOMIH HAWN HY 11 :12 :13 :14 16 19 20 :22 25 QO Right A -- the stories that | heard. Q Rogbt Well. a lot of peeple that ve been talking to are about your uge and a couple younger than vou. So that's the part that | have serious problems with. A Yeah. DETROFEVE RECAREY. Do vou have any Questions? BY DETECTIVE DAWSON: Q Did vou see any others -- when vou were there you said vou talked to twa pirls in the kitchen. ‘he second ume vou went, vou went with -- A Paley. Q Haley. Were there any other pirts there? A Yeoh, there were the same ove girls that were there, QQ Sante (wo pirls? Okav. A Tm pretty sure they like live and travel with hin. DETECTIVE RECARLY: Okay. Ali right. Well at this time I'm gomg to conclude this statement. its P45 am. (Thereupon, the interview ended.) (Pages 10 to 13) 4 HOUSE_OVERSIGHT_012362 Page 12}: Page 13 02423

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IN RE: JEFFREY EPSTEIN VZIDEOTAPED INTERVIEW as 060ml 02528 HOUSE_OVERSIGHT_012364

1 (Uhereupon, the following videotaped interview was 1 2 had:} : 2 4 BY DETECTIVE RECAREY: DA 5 Q. Allnght. Pappereciate you coming down again. 25 6 Altyight. The reason why T asked you lo come down was that! & 7 Tm nvestigating a case m winch my investigation, | i 7 8 beheve thal vou have information on Jeff Epstein. Okay’? : 8 9 A Okay. : 9 10 (9 First of all, before we even begin, Jet me just 1G 12 swear vou, Okav? Raise your right band forme. Doveu fit 12) sdlenmly swear te tell the uth, the whole truth and 212 13° nothing but the truth so help veu God? 13 14 A Yes, de. :14 15 Q. Okay. Do vou understand what tm saving? 1s 16 A Yeah, :16 17 Q. ] know veu're Spanish, i17 18 A Vknow Yeah. 18 19 Q > Tecan speak Spanish. :1¢ 20 A Yeah. i ge 2 Q. Allmght. [First of all, do vou remember Jett? : 21 22 A Yeh. i22 23 Q. Okav. Lives on [i] Brillo? i282 24 A {No audible response.) i 25 Q Okay. Why don't vou tefl me frem the beginning Page 3 : L how vou met him. Pa 2 A Okay. Itwas something in high school. Everybody 2 3 was like trying to make maney and at the time | had two jobs 3 4 Tpuess. That was like twe years ago. : 4 5 (About bvo years age? 5 6 A. Yeah. : 6 7 Q When vou first met him? i 7 8 A {Ne uudtble response ) 8 3 (QQ Okay. ig 10 A Yeah. [was 17. :10 Ll Q You were 1? then? : 11 12 A UW teluh. (Video at 1:37) i412 413 (2) What is dt that you were told vou would have to i143 14 do? 12 LS A Give him a rassape 15 16 QO Okay. : 16 1? A That was it i 17? 28 (Okay Who tovk you there? : 18 i9 A Her name i :19 29 Q Okay. Allright. And do vou have any formal 20 21) massage training? i 21 22 A No. 22 73 Q No. Did -- so BB 00 vou there. 223 24 A || didn't take me there. JJiook one of my 124 i) Page 4|- a couldn’ltike me. QO oOkn Ei A oe Okay. When you gol there. whot Q happened? A It sevens really weird, the whole situation. “There were more irs in the house and then they just saw me po upstairs. thes show me (be room, i was a massage room. Pretty nenmal Then he came und, you know, [ give him a Massage. Q Oke. [ve talked to a lot ol girls and a lot of girls have told me different things. A Uh-huh. Q Okay? So}'m very aware of what happens when vou provide a massage. Okav? A Yeati Q When you vot to the house you went here with A Yeah. Q. Okay. low did you come into the house? De yeu remember? A What do vou mean? Q Did vou ge into the front door? A Yeah. Q Did vou come through the garage? Page S|} A Well. when you vo inside there's like a door. 1 don't know if it's the front door. 1 don't know. QQ Isit a wood door? A A wood door, veah. Qt ts a wood door? A_ It's probably the back because it goes through the krichen. Q it goes through the kitchen? A Yeah. Q Okay. And you were brought into the kitchen. right? A. Yeah. QQ Who was in the kitchen there? A Oh. my God. it’s so long ago. Q So long ago? A Yeah. Q Okay. A I don't remember. Q Dovou remember any of his assistants? A Q ? A She was the one. Q She was the one that you met with? A And there was the one that cal] me and I told her { wasn't going to do it anymore. i think her name was 2 (Pages 2 to 5) 02529 HOUSE_OVERSIGHT_012365

Onn bd WwM re gol P Okay So when you come rite the house, : 2 you go mito the kitchen, you meet with some people there whe | 3 takes you up -- i 4 A Wii 5 Q You met with |g : 6 A Yeah. Therfkay sit down and tell sit down 7 and everything § go and call Jeffrey. That's what £ was : 8 confused when you say Jelf [don't know any Jel And 9 then she takes me upslits and stays there and Faith TO stays there like all the gme white I'm upstairs pil Q Okay Okay. Soljhakes vou upstairs. Did 12 you use the stairs -- : 13 A Yes. , 414 Q -- lo go upstairs? 25 Okay. De vou recall anything weird when you were | 16 going up the stairs? 217 A The pictures. 18 QQ Ohay. Pictures of what? :19 A Naked people. i206 Q Naked people. Okay. Okay. She brings vou inte i21 this you said it was a massage room? : 22 A Yes. Q Is Jeffrey aiready there? A No. Page Q No? Whit did vou do next? 1 A [sit down there and she tells ine just wait a i 2 second. Then she comes back and we put like the little bed = 3 for the massage and she's Dke okay, thete’s some lotions iq and he'll be right out. a) QQ Okay. 1 6 A Then he comes in, hes tike okay. Then he knows FF my tame already. [im Chen he’s like okay, just a : 8 Thassuge. _— Q Okay. When he came in wos he ina towel? Was be 10 ina robe? : 11 A No. He had like clothes. Ie was rimming or il2 something like that. 13 (2 Itacd regular clothes on? :14 A Yeah. 15 QQ And he got on the table with the clothes an? 16 A No. He took his efothes off and ke puts like a 217 towel, :18 Q He puta little towel over hits. Okay. So at any :19 point did you see him naked? : 20 A Noten the first ime. 2] Q No, Okay. So he lays on the bed, massape bed i 22 with his towel and vou start massaging him. Do vou remember! 23 where you provided the massage? 24 A On the back and his legs. P25 PhD te Pula Page QQ On his back and on bis Jugs. Ohaw Plow were sou dressed when you were giving the massage”? A | wasm yeans and a T-shirt Q Okay. Okav. At any pont did be ask vou to Temove your clothes’? A Yeah GQ Okay. This is during the first massape? A Yeah And f say no, @ And vou said ne, Okay. Okay. Do yott continue wilh the massage? A Yeah [twas kind of weird that he asked me take my clothes off. @ Okav. So take me through then from there. You're domg the massage? A: dothe massage. After | finish he's tke okav. Actually he pay me before | start domy tbe massage Q Tepaid Tow much did he pay vou? A $200, Q $200. Atany ime daring when vou're giving him the massage, did he ever turn over -- A Yeah. QQ -- onto his back? A Uh-huh. . Fell me what happened after that. Fage Gr Qin hts chest area? A On his chest. yeah. Q During the time you're massaging him on his chest, is he touching himself? A Yes. Q Okay. LiNplain, explain that to nic. A Well, he start geting a litle excited about it amd he start iouching himself and [told him stop, and that, that wars a, Q Okay. When vou mean by fouchmg himself, you mean be was masturbating? A Yes. Q And vou told him ta stop? A Nod didn't tell him to stop. Q Oh. okay. Okay. Su while you're rubbing his chest, did he ever take off hus towel? A No Q So how would he be able to masturbate if -- A Well. Hike he had his hand under the towel. Q Under. So vou never saw him. Did vou eves see Inm naked? A No. Not the first time but] saw him like the second ine. Q Okay. Okay. Okay. So then von did your ma -- continued wilh your mass assage like on [ don't know how vou sav ib : 3 (Pages € ta HOUSE_OVERSIGHT_012366

f™ 12 13 14 ) 16 1? 18 12 20 oe) 23 ayn up wher oa Peer eee ere be 2 fa bo POs wh oe ba bs A Yes. Q Okay. What clse happened after that? A Nothing elsc. After | was finished. Actualls like it was supposed to be an hour. But the first time it was just 30 minutes. Q Okay. The time you were rubbing his chest and he : was masturbating, did he evcy climax? A No. Q You know what ! mean by that? A Yeah. Q Okay. How did vou cond the massage? Did he just say that's cnough? A Yeah. Q Okay. Okay. So then you went back downstairs? A Yeah. Andi say to kay. I'm done. and we Icft. Q Okay. Did he ever ask you to leave your tclephone wumnber to call vou back if von wanted to work? He — for my phone number. He asked for your phone number? Yeah. Did Mvive him your phone number? (Nods head yes.) Okay. Did Hf ect paid for taking you? OYvrOrea d& Page ll: Now much did she get paid? $200 Q She got paid $200 for taking you as well) Okay. So tell me about the second time. A Second tine | don’t remember who took me. f never wenl by mssel!. | was scared to go bul it was Kind of like the same. Same situation than the first one but he offer me more Money just lo luke my shirt eff and 7 didn't do dtand he was the same. [le did the same things and then he took his towel oll Q Okay. A And Ike after Ie was done hke he never like got tothe climax. [never saw him. Q You never saw him’? A (Shakes head no.) Q Okay. You were going eT de A Yeah. That's how evervthing started, Q That's how everthing started? A Fail of the school knew about it. Q. Half of the school knew about it? Let me, let me back up fer a second, You go the second time. Who calls you to go back to the house? A CONN ae Ow nD bw Ne foe, Q calls vou Now you make an appointment toe Page 12 go to go work. A Yes. (2 Okay. The same thing, you go into the back door to the kitchen arca? A Uh-huh. Q You meet with A Yeah. And she takes me upstairs. Q She takes vou upstairs. Okay. He offered you more moncy to gel naked? A Yes. Weill. he told me just to take my shirt off. He didn’t sav anything clse. Q) Okay. Okay. And did you? A No. Q No. But that's not the only two times vou'd gone. You've gone more times? A It was like around three. four times and then I Just -- | was just scared that he was gonna do something. Did he ever photograph you? No. Not thal | know. Did he ever take videos of you? No. Okay. Did you ever give the massage with any other woman? A No, OpPoryD Page 12f massage? Any of the massages? A Once. Q. Onee. A Bulit was in my undenvear, ft was never completely naked. Q Okay. You stayed your bottanr?) Under wear? A And my top. Q And your tep So vou slayed in bra and panties” A (No audible response.) Q Okay. A | think there was one that | lake un bra off but That was it. (QQ) Okey. And each time vou went did he offer you more Monies to do more things? A Yes, Actually [ knew that because of BB ste (inaudible). || ] don't know her last name. Q Okay, A Because she ask me. she savs he'd offer more money if] have sew wath him and f said that's never poime io happen. There's no way I’m going to da that for money. Q Okay. Aml by having sex means intercourse or -- A Yes. F guess. 1 don't know, [ don't like talking about, Q Okay. The second time, did he offer you more 4 (Pages 10 to 13: 0253] HOUSE_OVERSIGHT_012367

WDIHDUOA WHE Ps 8 ha WD BIN Yeah. $100 more just to take my shirt off. A Es Q Okay. And you said you didn’t do it. 2 A No. 3 Q Okay. Did he masturbate on the sccond time? 4 A Yeah. ss) Q And did he ever climax? 6 A Actually the second time like it wasn't that bad a because he was like on the phone all the time and so he 8 wasn't paying attention to what was going on. 3 Q Didhe ever at any point masturbate the second 0 time? 1 A No. Not that J remember. i12 Q Did he cver ask vou any questions or speak lo you | 13 or ask you anything? 4 A Well. he tricd to talk to you just to make vou 215 comfortable with the situation like where do you work and : 16 like how much do youn make at your work and then he sta 7 saying vou can make snore with me. but E didn’t feel like i 8 was night. 9 Q Did he exer know your real age? 0 A After a while like because somebody told him. 1 Q That vou were -- 2 A Yeah. 3 Q +17) 4 _A, Like li told us. we wore supposed to say we | 25 Page l were 18. 1 And who told sou that to sav that? 2 A (Video at £4:57)) 3 Q 4 A Was the ong who brought everthing to 5 & everyone al school. That's how we know about st. Then she took ors Mhook me. dio 15:02) Q Okuy. So each ume vou did go, did Bel money Jor Gikiny vou en = A Well, went wilh me twice F guess. And that was it. Then [wont «ish Q Okay. And did she meke money? Did Bp make money for taking you lo dim: ww ~! Burl didn't get = £17 moncy out of that. :18 Q. Okay. (Did anvbody ever help vou di a massage with : 19 hin? : 20 A No. sted me to do it with ber and I didn't :21 feel comfortable. : 22 Q Allmeht. Allright. Talk tome about the third 23 lime vou went. 24 A don't remember i was like kind of always -- : H was always -- il was the same. Q lt was the sume? A ht was the same. : Q Obviously more stuff happened because. you know. he paid you more to do more things. right? A Yeah. The third tiie it was when T took my stiri off. Q Staved with your bra or were you -- A Stayed in my bra. Q Okay. A And that was when he paid me 300. Q He paid vou 300 for that? A Uhb-buh. © And same thing -- A Yeah. Q Hecame in. Was he naked again? A Yeah. Q. Okay. You pave hin a uassage and al that point was he stil playing with himsclr? A Yeah. Q) Masturbating? A Uh-huh. Q Okay. Do you know if at any point did he ever climan during this? A No. “ Penne e ce teneeesetnene Page 17} Q. Okay. Plow would the massages end? Would he just sav that’s it, that’s enough? A Yeah, he would just stand up and take a shower and could grab my things and feave. Q Okay. Allright. Talk % me about the part when vou got down to vour undere var A That was the Jast ime that] saw hun, Q When wis the Just time?) Wis thal -- A It was Jorg ago, More than six months ago. Q You sure it's potuny time sconer than thal? A | don'tremember | the | old didy't want to do itanvmore } was scared he was poing lo do something. Q Okay Why de vou say vou were seared he was geing, todo something’? A Beeanse | tke know he has a fot of girls and I don’ know, Tike he was offering nore money for it. Like E think be beught ber a car er something like that. She just gota car and she told me he got it for her. Q BDoveu know what kind of car it was? A think it's a Dodee cr something. QA Dodpe? A And then she fike then had money for anything and she ended up going to Eurepe ror hke the summer. Q Did she go with hin? 5 (Pages 14 to 17) HOUSE_OVERSIGHT_012368 02532

o 1 A ( 2 was -- 1] didn't like the whole situation. N. 3 QQ Okay. Did he ever touch you” 4 A ¥cah, 5 Q Inwhat way? 6 A My back and my butt. 7 Q Did he ever. did he ever take oul any tovs? B A No. 9 Q Did he ever touch your breast arca? 10 A (Nods head ves.) li Q Did he touch your vaginal arca? 12 A Yeah. 13 Q. Allright. Did he touch you with his hands or 14° with something else? 15 A With his hands. 16 Q Okay. Okay. Was this over your undenvcar or 1? under? 1.8 A Over ny underwear. 19 Q. Over or under? 20 A Over. 2] €) Over. Did be ever insert his fingers in you? 22 A (Shakes head no.) 23 Q And as he was doing this, he was paving more 24 money? 2D A The maximum that he pai was 3 Page 1° 1 © Three hundred. And that was the last time vou 2 weul? - 3 A (Nods head ves.) : ( 4 Q > When he touched your breast area. you didn’t have : K 5 a bra on? ~ 6 A (didn’t have a bra on. 7 © You didn't have a bra on. And vour buttocks? OPS > 13 A 14 Q Ss A 16 O 1? A 1&8 9 19 area’? } don't know. We never tatk about it because | Uh-huh. Was thal over your pantics or under your pantics” Like | have a thong on so... You had thongs. Okay. AH right. Did he pull 2 you close to him’? Yeah. And all this while he was masturbating? (Nods head yes.) Did he have you touch him” No. Astde from the massage. touch him in his penis (Video at 20:22) Iuh-huh. No. Did you bring anyone else other than -- ——— Do you know last name? CO Mm Ua WB Wh PR “A A Q i No. No tdea. 2 (2 Flow cbout IR 5 (Im! 4 Q Does she also gu to 5 A Uh-huh, 6 Q And what about | 7 A Yes, 8 (Did vou receive monies for inking | om 9 A : Q Did vou reccive money for Jor - 212 A I don'tremember. Pn pretty sure | didn't. :13 (2) Okay, When was the last ume you had contact with :14 apvone from the house? ils A Well, J don't know because she told me they were 216 poing to New York the last time we tulked. The last ime | P17 went, 18 Q What's a while ago” :19 A Probably two months or more. z Q Who called you? A Q And she said thal she was going where? A Thev were pong to New York, Q New York? Nobody else from the house has called you Co say the police are looking mo it? Page 215 (Shakes head ne.) Okuy. Tins case is basically an investigation, an open mvestigation. so f appreciate it what we discuss stays here. Okay? A 8) Q A Q A Q A Q Uh-huh. Don't tell anvborly (hat we thatwe talked Okay? Oka Dats ou ever have any intercourse with bin? No, (Video at 22:41) No oraf? i Shakes head no.) Nounng? Nothing else. Okay. Tm potny lo show vou a praup of photographs, I'm goiy to show vou a group of six photographs. Okay? I’m trying, trving to sec if this is in these six photos. Okav? It's important that vou look at all six of them and be sure who you pick as the person as || Okav? She may or may not be in these six photos but it’s aMportant for vou to pick the right one, Okav’? No. Uh-huh. ‘Take vour ime looking al those six photos there. (don’t see her. She's not im those photos there? 6 (Pages 18 to 21) 02533 HOUSE_OVERSIGHT_012369

MS RH fp — rows ~ ON ts dro nm ta Wey AOA SB Wh Woy nus wre mt OD we te ta th QQ How would you describe A She would be here bul she’s She's avi! She looks like her bot I'm not sure Q. Okay. That's why J needed vou te be absulutels sare. fappreciate ¥ou being honest and not picking anvone out because [hat's important Yon know? You have my card, : night? A No, Pfostat, Like DP thank [left it atimy jeb. Q Okay. F gave your sister one. That's my card. A You went back to my house? Q Yeah, ] went by Coday. She's the one who pave me your cell) Your sister A You tell her what it was? Q No. No. | jest told her that vou were a witness and [needed to talk fo you. A Ishe going to know anv ibing about any ef this? QQ About the mvestipgattun? Eventnally I'm sure he will find oul about the investigation. | would appreciate iL iF anvone did contact you that you call me and give me Just -- basically let me know that somebody called vou A §€they calf me? Q if they cali von. 1s there anything else you'd like to add to this statement or -- A No. I'm just seared Uhat he’s gonna know Q. Why are vou seared of hin? Page 23; A That he's gonna do something. (He's not gona do ans thing What did he tell you he did Jor a living? A He was in brain sumething. He studied the brain. Q Fle's an mvestor and that's it. Justa meney investor “That's it T's rot -- haif of the things that he totd some of these people. be’s just a money investor. That's i Su don't be afraid. And if they do call vot, just call me and let me know A Mf they ask me lo come over there sbould 1 just savno? Like Pdontwant to vo Q You haven't been there’? A (Shakes head no.) QQ Whenos [be Just lime you said vou were there’? A Like three. four months ago. Loaper than that. don't remember, Q [think it's about three or four mantis apo. T think it’s three or four months apo because -- 3s there any thing else you'd like to add? A) Not really. Q No” Okay. L appreciate vou coming down. And let mv walk vou oul. A Ts something going to heppen to me? Q No. No. Ejust, like P said, vou're not in any trouble whatsoever. J just wanted to talk to you. | Re 7 0 thee 2 P= onwn NOD Boo BO BO re ™m on Bm Ws ee Page 24 apprectalc vou coming down. Okay’? A Thank vou. QO Ali right. (Thereupon. the interview ended.) HOUSE_OVERSIGHT_012370 02534

TAB 11 HOUSE_OVERSIGHT_012371

U.S. Departnent of Justice Office of Legislative Affairs i I i tt srs a Office of the Assistant Attomey General Washington, D.C. 20530 November 9, 2007 The Honorable John Conyers, Jr. Chairman Committee on the Judiciary U.S. House of Representatives Washington, D.C. 20515 Dear Mr. Chairman: This letter presents the views of the Department of Justice (the Department or DOJ) on H.R. 3887, the “William Wilberforce Trafficking Victims Protection Reauthorization Act of 2007,” as introduced by Congressman Lantos on October 18, 2007, The Department has significant concerns, which are detailed below in a section-by-section analysis. The proposed legislation, as drafted, would eliminate the Department’s role in several important steps in the victim identification process, and thereby negatively impact our ability to ensure the safety of victims and their families, rescue additional victims, and apprehend and prosecute human traffickers; it would broaden the criminal statutes regarding prosecution in a manner that detracts from effective enforcement efforts and raises serious federalism implications; and it would unconstitutionally intrude into Executive authority. 1. Sevtion 102 The provision in subsection (e)(2)(B) authorizing the Director of the Office to Monitor and Combat Trafficking in Persons (G/TIP) at the Department of State to interview victims should clarify that the Director is authorized to do so only with the consent of the Attorney General in any case where an ongoing investigation or prosecution may exist. Otherwise, serious issues could arise that would complicate or even scutile prosecution. For example, any statements made to the Director would presumptively have to be turned over to the defense and any statements that contradict statements made to law enforcement or prosecutors would be required to be turned over to the defense. 2. Section 103 DOJ finds section 103 unnecessary and duplicative of existing efforts and, therefore, opposes its inclusion in the bill. DOJ and other Federal agencies are already offering the types of assistance that are described in the section. Furthermore, the new subsection (a)()(3) would require the United States Government to provide “technical assistance to provide legal frameworks and other programs to foreign governments and nongovernmental organizations to HOUSE_OVERSIGHT_012372

ensure that foreign migrant workers are provided protection equal to nationals of the foreign country.” This provision does not differentiate between legal and non-legal migrant workers, nor does it distinguish between forced labor and non-coerced mi grant labor. DOJ believes that any international standard that we promote must mirror our domestic standards. Similarly, the new subsection (a)(i)(4) could be read as encouraging countries to loosen their immigration laws, ‘something that the United States Government might not be willing to do. Subsection (b) amends the Foreign Assistance Act of 1961 (22 U.S.C. § 2151 ef seq) to provide specific assistance for anti-trafficking investigation and prosecution units in foreign countries. This subsection could be construed as prioritizing sex trafficking over labor trafficking. As stated above, DOJ believes that any international standard that we promote musi mitror our domestic standards, which prioritize both sex trafficking and labor trafficking. Further, the amendment to 22 U.S.C. § 2152(d)(a)(2) should include a reference to labor trafficking and should, therefore, read “including investigation of individuals and entities that may be involved in trafficking in persons involving sexual exploitation or forced labor.” 3. Section 104 The Department objects to the language in this section that specifies the groups with which the United States Government must consult and coordinate in offering assistance and protection to victims of human trafficking. Such language both places undue restrictions on the United States Government and could limit the Government’s ability to deal with some necessary groups. It has been the consistent practice of the Department to consult widely with a range of stake holders and others before designing a program of foreign assistance on human trafficking, Such an additional requirement in the statutory language is unnecessary. We suggest that the language be amended to read, “[i]n cooperation and coordination with organizations which may include the [UNHCR], the International Organization [for] Migration, and other relevant organizations....” 4, Section 105 DOJ recommends that subsection (a) also require that the effectiveness of assistance programs be measured based on best efforts to facilitate cooperation with law enforcement, along with the other criteria. 5, Section 106 DOJ opposes the bar in subsection (b)(1) against including cases in which probation or low sentences are given. Some of the most important cases are the ones against cooperating defendants that result in minimal sentences in exchange for information or testimony. Embassies Should have the discretion to take such situations into account when evaluating foreign government efforts to combat trafficking. The Department recommends amending section (b)(1)(B) by striking “shall not be considered to be an” and inserting in its place “shall be considered on a case by case basis to determine if it will be considered an” so that it will give the tL Secretary of State greater flexibility in evaluating the efforts of other countries. 7 HOUSE_OVERSIGHT_012373

The Department also objects to the new paragraph (11), which lists as a criterion for ascertaining whether the government in question has made “serious and sustained” efforts to eliminate trafficking “[w]hether the government has made serious and sustained efforts to reduce demand for commercial sex acts and for participation in international sex tourism by nationals of the country.” We object to this language because it is vague and will, by implication, require the United States Government to evaluate itself under this “serious and sustained” standard. The Department prefers the language that was added by the 2005 reauthorization of the Trafficking Victims Protection Act, which evaluated whether countries “adopted measures” to reduce demand, 6. Section 107 Section 107(a) of the Act raises separation of powers and Chadha concerns. Section 107(a) would add a new 22 U.S.C. § 7107(b)(3)(D), which would limit the amount of time that a country could remain on the Tier IT Watch List to two years, “unless the Secretary of State provides to the appropriate congressional committees credible evidence that” the country had taken certain steps to make significant efforts to counter trafficking. That provision further requires that “[s]uch credible evidence” shall be provided to Congress in a report. To the extent that section 107(a) purports to give congressional committees authority to determine whether the Secretary’s decision to exempt a country from the watch list is based on sufficiently “credible evidence,” the provision would give the committees a role in executing the law that the Constitution does not allow. “{O]nce Congress makes its choice in enacting legislation, its participation ends. Congress can thereafter contro! the execution of its enactment only indirectly—by passing new legislation” —that complies with the bicameralism and presentment requirements of Article I. Bowsher v. Synar, 478 U.S. 714, 733-34 (1986); see also INS v. Chadha, 462 U.S. 919, 951-52, 958 (1983). To avoid this concern, we recommend replacing “provides to the appropriate congressional committees credible evidence” with “determines;” and replacing “Such credible evidence” with “Such determination.” Ts Section 108 DOJ opposes the requirement in section 108 to create a database “combining all applicable data collected by each Federal department and agency represented on the Interagency Task Force to Monitor and Combat Trafficking.” The database would contain law enforcement sensitive information, which would prevent the data from being accessible to non-law enforcement agencies, many of which are a part of the interagency task force, Furthermore, such a database would be difficult to create, particularly within the timeframe provided in the statute, because it would require information from multiple agencies that collect data in varying forms and levels of specificity, 8. Section 109 This section authorizes the President to establish an award for efforts against trafficking and directs him to establish procedures for selecting recipients of the award. DOJ opposes this provision, as it interferes with the President’s policy-making authority. HOUSE_OVERSIGHT_012374

9, Section 110 The Department opposes the statutory language in subsection 1 10(a)(1)(B) that specifically mentions the U.S. Government sponsored hotlines for reporting instances of- trafficking in persons. Statutorily providing for the names of the hotlincs would interfcre with the President’s policy-making authority to change the hotline structure at a later date. Furthermore, the Act, as written, misnames the hotlines. 10. Section 201 In section 201, the Department objects to the new subsection “(bb).” To the extent that such a subsection is necessary, a question that we defer to the Department of Homeland Security (DHS), the decision regarding cooperation should include the Attomey General in addition to the Secretary of the Department of Homeland Security, as it does in Section 201(b). DOJ defers to DHS in regard to subsection (a)(1)(E), although we would note that by removing the “unusual and severe harm” standard, victims will be eligible for a T-visa upon a lower showing of “extreme hardship.” The Department also defers to DHS in regard to subsection (a)(2), which would extend T-visas to parents and siblings of trafficking victims. As a factual matter, however, the provision should be amended to strike any reference to “as a result of the alien’s cooperation with law enforcement.” Traffickers threaten victims to intimidate them into compliance with traffickers’ demands and to retaliate for victims’ escape, not because of law enforcement cooperation. It is counter-factual to describe the pattern of threats and retaliation as linked to law enforcement cooperation, and disregards the fact that threats often only subside when law enforcement takes measures to secure the family or punish the traffickers and their associates who threaten victims’ families, Furthermore, it is unclear whether the reference to siblings encompasses both minor and adult siblings, and whether spouses and children of adult siblings would be eligible for a T- visa, : In subsection (b), DOJ opposes the new subsection (8)(B), which grants sole authority to the Secretary of DHS to consider whether “extreme hardship” exists. The new section, however, also requires consultation with “prosecutors,” which presumably refers to prosecutors at DOJ, since DOJ is the lead prosecutorial agency for cases involving human trafficking. Since these prosecutors are under the Attomey General’s authority, the consultation requirement should include consultation with the Attorncy General. Subsection (c)(1), which creates the new subsection (3)(A)(i) in section 107(c) of the Trafficking Victims Protection Act (TVPA), should limit applications for continued presence to those being made by “Federal” law enforcement officials, Limiting the applications to those submitted by Federal law enforcement assists in the victim identification process. The Department has established a memorandum of understanding with DHS that ensures that the Department’s prosecutors are informed when investigators apply for continued presence. Furthermore, limiting the applications to those submitted by Federal law enforcement ensures the uniformity of standards in making the determination as to whether an individual is a victim of a HOUSE_OVERSIGHT_012375

severe form of trafficking in persons and eligible for continued presence. Finally, Federal law enforcement involvement in the process allows Federal prosecutors the ability to identify patterns of human trafficking activity that might span multiple local law enforcement jurisdictions. For these same reasons, the new subsection (3)(B) should add “Federal” before “law enforcement” to limit the authority to request parole for relatives to Federal law enforcement officials. The new subsection (c)(3)(A\{ii) should add “endeavor to” after “shall” so that a legally actionable obligation is not created as to Federal law enforcement’s role in protecting the safety of trafficking victims and family members. While the U.S. Government makes every effort to protect trafficking victims, the statutory language, as written, could be construed to create a legally cognizable right and could lead to litigation. In the new subsection (c)(3)(A)(iii), DOJ opposes extending continued presence for the duration of a civil suit. It also raises the potential for abuse because of the lengthy and plaintiff/victim-controlled delays in conducting civil litigation. Furthermore, physical presence in the United States is not necessary for the successful maintenance of a civil action. Victims have other options to obtain status in the United States, such as T- and U-visas. DOJ notes a technical change to subsection (d), which currently has two subsection (2)s. DOJ recommends striking the second “(2)” and replacing it with a “(3).” I. Section 202 The Department opposes the language in section (a) that legislates the existence of a specific task force, such as the Trafficking in Persons and Worker Exploitation Task Force. DOJ recommends deletion of this reference and the replacement of the cue task force with “the i Attorney General.” DOJ also opposes the 120 day deadline in subsection (f) as unreasonable due to language barriers and translation needs. 12. Section 203 In subsections (a), (b)(1-2), and (c), DOJ opposes the language removing the Attorney General’s role in determining whether the relevant applicant has complied with reasonable requests for assistance, an important factor in the decisions regarding T-visas, and that the investigation or prosecution is complete. Because the Department is involved in its prosecutorial as well as its investigative roles, DOJ participation is critical in assessing assistance with law enforcement, and it is well-situated to assess whether a victim has complied with reasonable requests for assistance that went through investigative agencies outside DHS, such as cases investigated by FBI or DOL. Therefore, a joint determination is appropriate because of the number of different law enforcement agencies that may be involved in a particular matter. i HOUSE_OVERSIGHT_012376

13, Section 205 DOJ opposes the addition of the new subsection 240.A(b)(6)(A) of the Immigration and Nationality 21 Act (8 U.S.C. 1229b(b)) unless the word “Federal” is added before “law enforcement official.” The same proposed subsection currently states that the Secrctary of the Department of Homeland Security “shall grant parole” to the relatives of trafficking victims. DOJ recommends changing this language to read “may grant parole” so the Secretary has the latitude to make an appropriate decision, There may be reasons pertaining to the circumstances of the relatives of the trafficking victim for which the Secretary should have discretion to deny parole, Further, DOJ finds it necessary to strike any reference to “as a result of the alien’s cooperation with law enforcement” for the reasons noted above. In subsection, (6)(B)(i)(1, DOJ opposes a statutory requirement that parole be extended during pending civil actions. As indicated above, this action would create a potential for abuse because of the lengthy and plaintiff/victim-controlled delays in conducting civil Litigation. 14. = Section 211 The Department opposes the change of the “and” in subsection (1)(A) to an “or.” Both the Attorney General and the Secretary of DHS need to be involved in the certification process. The current certification process is well-established and needs no statutory revisions. DOJ also opposes the change in subsection (1)(B), which would remove the Attorney General's authority in stating whether a person’s presence is necessary in cnsuring an effective prosecution. As the agency that prosecutes cases of human trafficking, DOJ’s involvement is vitally important. The | Department has the same concern with the proposed change in subsection (2). 15. Section 213 We strongly oppose the language in this section that inappropriately removes law enforcement from any initial determination of victim status or benefits eligibility. DOJ and DHS play a critical role in protecting the safety of victims and service providers. Any failure to involve Federal law enforcement immediately upon suspicion that a crime has been committed _ could threaten the safety of the victim, impeded efforts to promptly rescue victims still in jeopardy, and possibly man that the offenders avoid apprehension. DOJ recognizes the important of including HHS at the initial stages for the purpose of facilitating prompt delivery of the full range of available benefits and services to trafficking victims. DOJ will continue to work with DHS and HHS to ensure that interagency procedures afford victims of trafficking prompt protection and access to these services. : The Department further objects to the provision set forth in paragraph (G), which would require both Federal and state law enforcement officials to inform the Department of Health and , Human Services (HHS) of the existence of a potential victim, but does not require HHS, other Government officials, or non-governmental service providers to inform Federal or state law enforcement of such a victim. To the extent that such a notification procedure must exist, it must also include notification to the Attorney General and the Secretary of DHS, who bear responsibility for prosecuting and investigating instances of human trafficking. HOUSE_OVERSIGHT_012377

oS DOJ also opposes subsection (b). Since the passage of the TVPA, DOJ has been one of the principal agencies conducting trainings for a multitude of audiences, including task forces and Federal, state, and local law enforcement, on the issue of trafficking in persons. The Department also has experience in conducting training on juvenile victims through the Innocence Lost National Initiative. Effective efforts to combat trafficking must mobilize the expertise of HAS, DHS, and DOJ. DOJ also notes a misspelling in the new subsection (F)(ii)— “edibility” instead of “eligibility”. 16. Section 214 Section 214 of the bill authorizes the Attorney General to make grants to assist victims of severe forms of trafficking up to $2.5 million in 2008, increasing to $15 million in 2011. The Department of Justice already has authority to make grants for the provision of services for crime victims and does so at a level in excess of $250 million a year. Also, the authorization of yet another grant program runs counter to the Administration’s proposal in the 2008 Budget to consolidate DOJ’s more than 70 grant programs, Moreover, any provision purporting to expand or alter definitions of individuals of qualifying for victim benefits must include the requirement that a Federal law enforcement agent must declare the individual to be a victim of a severe form of trafficking in persons, and that the victim agree to cooperate in the investigation and prosecution, or that the victim be under the age of 18, DOJ opposes the consultation requirement in subsection (a}(1) with the Secretary of State for establishing programs to serve domestic, U.S. citizen trafficking victims. Such domestic authority falls outside of the mission and expertise of the Department of State. DOJ also opposes the mandatory consultation with non-government organizations (NGOs) regarding the provision of services, This creates a conflict of interest since many of the NGOs will apply for and could receive grants under the program. Finally, any section regarding the provision of victim services must also contain language that includes organizations that provide services to “juveniles subjected to trafficking, as defined in section 203(g) of the Trafficking Victims Protection Reauthorization Act of 2005,” which would ensure that the funds authorized to the Attorney General for establishment of grants will go toward the work and development of the Innocence Lost Task Forces. DOJ opposes subsection (b) because it provides Victims of Crime Act of 1984 funds to prostitutes implicated in violations of the Mann Act (criminalizing transportation of prostitutes in interstate commerce), Such persons do not meet the legal definition of “victim” as that term is defined in the law, unless the person prostituted is under the age of 18 at the time the crime was committed or the petson, through the application of another Federal statute or regulation, satisfies the legal definition of a victim. Such persons are already eligibie under the Crime Victims Fund Act to receive benefits. HOUSE_OVERSIGHT_012378

DOJ opposes section 214(d), as it could be construed to require the Attorney General and the Secretary of Health and Human Services to make legislative recommendations to Congress in violation of the Recommendations Clause. To avoid this concern, we recommend inserting “, if any,” after “recommendations” in section 214(d)(2)(E). Further, DOJ finds subsection (d) redundant. A thorough study of services available to domestic and foreign victims was conducted by the Senior Policy Operating Group in 2005-2006 and found few statutory differences between the treatment of domestic and foreign victims. Subsection (d)(2)(C) contains a redundant statement. Victims of sex trafficking are victims of severe forms of trafficking in persons. 17. Section 221 In subscction (a), DOJ opposes the proposed change o This change of law would create a strict ability crime, similar to 18 U.S.C. § 2423{a), with a similarly severe 10 year } is exceedingly Therefore, the suggested subsection (a) would create a rare circumstance wherein there is a substantial mandatory minimum sentence for an already unusual strict liability crime. Accordingly, this provision is likely to face significant legal challenges. DOJ opposes subsection (b) in its entirety, The proposed language is both over-inclusive and under-inclusive of human trafficking activities, and the language is vague, Moreover, the provision is unnecessary because section 1589 already prohibits many of these activities when they result in “serious harm,” whether physical or emotional, to the victim. The Department opposes subsection (f)(1), which would expand the Mann Act to include cases “affecting” interstate commerce. The Department does not require any additional statutory authority or expanded jurisdiction in order to continue its successful prosecution of human <* The Department’s record during the last six years demonstrates its success gating prosecuting trafficking and related crimes and in convicting and securing appropriate sentences for traffickers. This allocation between state and Federal enforcement authority does not imply that these crimes are less serious, but rather rcflects important structural allocations of responsibility between state and Federal governments. The federalization of these crimes would treat them differently than other serious crimes such as murder and rape, which are prosecuted at the state level. Kidnapping, similarly, is a Federal crime only when it involves transportation “in” interstate commerce. HOUSE_OVERSIGHT_012379

a, ry. Finally, due to the high volume of prostitution-related crimes, the Federal government lacks the necessary resources and capacity to prosecute these offenses. Therefore, to the extent that thi DOJ also opposes subsection (g), which would expand the sex tourism offenses to include those who travel for purposes of illicit sexual activity with adults. The Department’s current efforts with regard to extraterritorial offenses focus on child sex tourism, which are very demanding and resource-intensive cases, requiring gathering evidence abroad, bringing victims to the United States to testify, and coordination with foreign law enforcement agencies and foreign governments generally, among other matters. Any expansion of authority would be a distraction from those priority cases and would exacerbate existing burdens on investigation and prosecution. The Department believes that the addition of 18 U.S.C. § 2423 is unnecessary and that 18 U.S.C. § 2423 does not need to be amended. Should Congress create 18 U.S.C. § 2423A, DOJ believes that language should be retained in 18 U.S.C. § 2423(e) that allows the Government to charge attempt or conspiracy for 18 U.S.C. § 2423{a) crimes. Finally, DOJ notes that the definition of illicit sexual conduct needs to be updated to include production of child pornography. 18. Section 222 AS a general matter, the Department opposes the expansion of jurisdiction over offenses involving non-American offenders or victims that are committed outside the United States. The expansion of jurisdiction in this section would place an enormous strain on available resources. In addition, this new section’s jurisdiction description overlaps with 18 U.S.C. § 3271. Should the choice be made to keep the jurisdictional provisions provided for in this section, perhaps it would be more effective to expand section 3271. 19, Section 223 These provisions are not directly related to trafficking. As this section is related to aliens brought into the country for the purposes of prostitution, without a showing of force, fraud, or coercion, and the International Marriage Brokers Act (IMBRA), this bill is not the vehicle for this language. Furthermore, subsection (a)(1) removes the requirement from section 278 of the Immigration and Nationality Act that such conduct be done in furtherance of the importation of the alien. By removing this requirement, the bill extends the statute to cover all instances of “pimping” an alien. HOUSE_OVERSIGHT_012380

f 20, Section 224 This section misunderstands the purpose and effect of the model Jaw and should be deleted. The Department’s model law was never designed to supplant pre-existing state laws which target pimping, pandering, or prostitution, but rather to supplement those laws. At the time that the Department’s model law was issued, most states had comprehensive laws addressing prostitution, pimping, and pandering. However, most states did not have laws focused on human trafficking. The Depattment’s law was designed to raise awareness of the issue of trafficking and to encourage states to closely examine cases to ensure that cases involving fraud, force, and coercion are not labeled as prostitution offenses. The Department believes the law has been successful in accomplishing this goal. 21. Section 231 The Department opposes any statutory changes to the annual report, The change in subsection (1) is unnecessary as this language is currently included in the annual report. The information requested in the new subsection (I) would be excessively burdensome to gather. 22, Section 232 DO3 opposes this addition as unnecessary. Human trafficking laws that do not require the proof of force, fraud, or coercion, namely laws that concern minor victims of severe forms of buman trafficking, are already discussed at the annual conferences. To the extent that this provision would require the Department to discuss human trafficking laws pertaining to adult victims that do not require the showing of force, fraud, or coercion, such laws would not fall under the definition of human trafficking and the annual conference would be an inappropriate venue for the discussion of such laws. However, DOJ trafficking prosecutors utilize a wide range of statutes in addition to Chapter 77 offenses to address all criminal conduct associated with human trafficking. This includes the Mann Act, money laundering, visa fraud, immigration offenses, criminal labor violations, and extortion, in addition to other criminal statutes, Accordingly, DOJ traiming at annual conferences, the National Advocacy Center, the National Center for Missing and Exploited Children, and field training with the Department of Justice funded Human Trafficking Task Forces and provided through the Innocence Lost National Initiative include discussion on the importance of using all available criminal statutes as essential tools in charging decisions. Thus, this section is unnecessary. 23. Section 233 DOJ opposes the change to section 206 of the Trafficking Victims Protection Reauthorization Act of 2005, which would remove the discretion of agencies in informing the Senior Policy Operating Group (SPOG) of grants. Such a change could be read as giving the SPOG oversight authority over grants. It also fails to take into consideration situations where gtant-making agencies may be unable to notify the SPOG of the grant. i 10 HOUSE_OVERSIGHT_012381

24. Section 234 The Department opposes subsection (a) as an excessively burdensome and unnecessary creation of a new layer of bureaucracy within our agency. The Department does not believe that there is currently any lack of coordination, and a new position could lead to duplication of efforts. Furthermore, subsection (a}(2)(A} incorrectly lists the Civil Division and not the Civil Rights Division. 255 Section 236 In subsection (a), DOJ questions the reliability of the congressional findings, especially with respect to the estimated number of victims and the inference that the lack of child victims is directly related to a lack of education individuals who may come into contact with human trafficking victims. Such findings, without a full body of evidence, are counter-productive. The Department also opposes subsection (b). The Attorney General should be involved in any program that focuses on combating child trafficking at the border. We propose that section (b}(1} is amended fo read “The Secretary of Homeland Security, in conjunction with the Secretary of State, Attorney Genera], and the Secretary of Health and Human Services.” Further, most of the children interdicted at the border are used for smuggling and are not trafficking victims. In subsection (b)(5)(D), DOJ believes that the proceedings for removal to non- contiguous countries are problematic because DHS needs more flexibility to handle gang members, terrorists, repeat offenders, and state offenders. Furthermore, the terrorism exception provided is too narrow to protect the national security interests of the country. We oppose subsection (c)(1) to the extent that it limits the Administration's ability to determine the best arrangement for custody or various classes of UACs. The administration will work with DHS, DOJ, and HHS to refine and modify current detention practices where necessary. The interagency process is the best forum to consider the various interests of unaccompanied minors and law enforcement and to develop and adapt policies thai, among other things, provide for the safety of all concerned. We look forward to discussing these developments with Congress in the future. The Department opposes subsection (d)(2) as too narrowly construed. There are numerous reasons, outside of the child proving to be a danger to himself or others, that require children to be kept in a secure facility, including the safety of the child from danger that is not self-imposed. In addition, the standard for placing minors in “secure” care is too strict. It requires the “least restrictive setting that is in the best interest of the child.” HHS only places 1.4 percent of minors in its care into a “secure” custody arrangement. This could mean that minors who need this arrangement would instead be housed with children who have no history of violence or criminal behavior. HHS needs more flexibility and there should not, therefore, be required to make an “independent finding” of the child’s danger to self or others. DOJ opposes the language of subsection (d)(3)(c) that would afford HHS access to law enforcement sensitive databases. 1] HOUSE_OVERSIGHT_012382

The language of subsection (d){5} must be changed from “shall ensure.” This implies a legal obligation on the Federal government to provide counsel and a concomitant right on behalf of victims to government-funded counsel, which is inappropriate and would subject the government to litigation over the nature and scope of the purported obligation and right. The Department also opposes subsection (d)(6), which creates a guardian‘ad litem program. Such program raises serious conflict of interest concerns, and DOJ has opposed similar language in the past. Establishment of a guardian ad litem program is also unnecessary in that 18 U.S.C. §3509(h) already sets forth detailed pracedures which provide for court appointed guardians ad litem for children who are victims of or witnesses to crimes involving abuse or exploitation. Subsection (d)(7) may result in pnintended consequences due to this confidentiality section. To effectively combat trafficking, relevant information must be transmitted to law enforcement. Law enforcement is well-equipped to preserve confidentiality concerns, The Department believes that subsection (e) undermines the 1997 Special Immigrant ij Juvenile reforms and opposes turning this back over to the states, where it was inherently flawed. In section 236(j), the effect of the apparent retroactivity of the general applicability of these amendments to “all aliens in the United States before, an, or after the date of enactment of this Act” raises serious concerns about the provision of benefits and services and has the potential to create serious problems for the Department ix its implementation of the programs ( described im this section. 26. Section 301 DOJ recommends striking the 2 percent cap on funding for training and technical assistance that is in 22 U.S.C, 7105(b)(2)(B). The unique’ complexity of the trafficking issue and the level of coordination necessary to effectively serve trafficking victims requires much more 4 training and technical assistance than a typical OJP program. Striking the cap on training and technical assistance will allow OJP to better allocate the trafficking funds it receives. The change could be implemented by the following statutory language: “Paragraph 107(b)(2)(B)of Pub. L. 106-386 is amended by: “{1) inserting ‘and’ after the first semicolon; “(2) striking ‘(ii)’ through *;and’; and “(3) striking ‘(iii)’ and inserting ‘{ii).”” 27. Section 302 Section 302 re-authorizes the $5,000,000 appropriation for the Pilot Program that was first authorized by Section 203 of the 2005 version of this Act. The 2007 version, therefore, should add language amending section 203 of the 2005 version to provide that HHS does not have the exclusive authority for development of the pilot program. DOJ and DHS must be included in the development of this program to ensure that the ability of Federal prosecutors and HOUSE_OVERSIGHT_012383

. law enforcement to gain access to these victims is not negatively impacted. Moreover, the Departments’ knowledge about these victims, their behaviors, and the dangers that are inherent | in providing shelter and services to them would be instrumental to ensuring the success of the pilot program. This section should also amend subsection 203(a) of the 2005 reauthorization to include after “Secretary of Health and Human Services”, “in collaboration with the Attorney General and the Secretary of Homeland Security,” Subsection 203(c) should be likewise amended. The Office of Management and Budget has advised that there is no objection to the presentation of this Jetter from the standpoint of the Administration’s programs. Sincerely, San A. x. AGL a Principal Deputy Assistant Attorney General cc: The Honorable Lamar S. Smith, Ranking Member, House Committee on the Judiciary The Honorable Tom Lantos, Chairman, House Committee on Foreign Affairs — The Honorable Ileana Ros-Lehtinen, Ranking Member, House Committee on Foreign Affairs C The Honorable Patrick J. Leahy, Chairman, Senate Committee on the Judiciary The Honorable Arlen Specter, Ranking Member, Senate Committee on the Judiciary The Honorable Edward M. Kennedy, Chairman, Senate Committee on Health, Education, Labor, and Pensions The Honorable Michael B, Enzi, Ranking Member, Senate Committee on Health, Education, Labor, and Pensions The Honorable Joseph Biden, Chairman, Senate Committee on Foreign Relations The Honorable Richard Lugar, Ranking Member, Senate Committee on Foreign Relations 13 fo HOUSE_OVERSIGHT_012384

TAB 12 HOUSE_OVERSIGHT_012385

PRESIDENTIAL AUTHORITY TO DECLINE TO EXECUTE UNCONSTITUTIONAL STATUTES This memorandum discusses the President's constitutional authority to decline to execute unconstitutional statutes. | November 2, 1994 MEMORANDUM FOR THE HONORABLE ABNER J. MIKVA COUNSEL TO THE PRESIDENT I have reflected further on the difficult questions surrounding a President's decision to decline to execute statutory provisions that the President believes are unconstitutional, and I have a few thoughts to share with you. Let me start with a general proposition that I believe to be uncontroversial: there are circumstances in which the President may appropriately decline to enforce a statute that he views as unconstitutional. __ First, there is significant judicial approval of this proposition. Most notable is the Court's decision in Myers v. United States, 272 U.S. 52 (1926). There the Court sustained the President's view that the ' ' Statute at issue was unconstitutional without any member of the Court suggesting that the President had acted improperly in refusing to abide by the statute. More recently, in Freytag v. Commissioner, 501 U.S. 868 (1991), all four of the Justices who addressed the issue agreed that the President has "the power to veto encroaching laws . . . or even to disregard them when they are unconstitutional." Id, at 906 (Scalia, J., concurring); see also Youngstown Sheet & Tube Co. v. Sawyer, 343 U.S. 579, 635-38 (1952) (Jackson, J., concurring) (recognizing existence of President's authority to act contrary to a statutory command). Second, consistent and substantial executive practice also confirms this general proposition. Opinions dating to at least 1860 assert the President's authority to decline to effectuate enactments that the President views as unconstitutional. See, e.g., Memorial of Captain Meigs, 9 Op. Att'y Gen. 462, 469-70 (1860) (asserting that the President need not enforce a statute purporting to appoint an officer); see also annotations of attached Attorney General and Office of Legal Counsel opinions. Moreover, as we discuss more fully below, numerous Presidents have provided advance notice of their intention not to enforce specific statutory requirements that they have viewed as unconstitutional, and the Supreme Court has implicitly endorsed this practice. See INS v. Chadha, 462 U.S. 919, 942 n.13 (1983) (noting that Presidents often sign legislation containing constitutionally objectionable provisions and indicate . that they will not comply with those provisions). While the general proposition that in some situations the President may decline to enforce unconstitutional statutes is unassailable, it does not offer sufficient guidance as to the appropriate course in specific circumstances. To continue our conversation about these complex issues, I offer the following propositions for your consideration. 1. The President's office and authority are created and bounded by the Constitution; he is required to act within its terms. Put somewhat differently, in serving as the executive created by the Constitution, the President is required to act in accordance with the laws -- including the Constitution, which takes precedence over other forms of law. This obligation is reflected’ in the Take Care Clause and in the President's oath of office. 2. When bills are under consideration by Congress, the executive branch should promptly identify unconstitutional provisions and communicate its concerns to Congress so that the provisions can be corrected. Although this may seem elementary, in practice there have been occasions in which the _ President has been presented with enrolled bills containing constitutional flaws that should have been HOUSE_OVERSIGHT_012386

corrected in the legislative process. 3. The President should presume that enactments are constitutional. There will be some occasions, however, when a statute appears to conflict with the Constitution. In such cases, the President can and should exercise his independent judgment to determine whether the statute is constitutional. In reaching a conclusion, the President should give great deference to the fact that Congress passed the statute and that Congress believed it was upholding ‘its obligation to enact constitutional legislation. Where possible, the President should construe provisions to avoid constitutional problems. 4. The Supreme Court plays a special role in resolving disputes about the constitutionality of . enactments. As a general matter, if the President believes that the Court would sustain a particular provision as constitutional, the President should execute the statute, notwithstanding his own beliefs about the constitutional issue. If, however, the President, exercising his independent judgment, determines both that a provision would violate the Constitution and that it is probable that the Court would agree with him, the President has the authority to decline to execute the statute. 5. | Where the President's independent constitutional judgment and his determination of the Court's probable decision converge on a conclusion of unconstitutionality, the President must make a decision about whether‘or not to comply with the provision. That decision is necessarily specific to context, and it should be reached after careful weighing of the effect of compliance with the provision on the constitutional rights of affected individuals and on the executive branch's constitutional authority. Also relevant is the likelihood that compliance or non-compliance will permit judicial resolution of the issue. That is, the President may base his decision to comply (or decline to comply) in part on a desire to afford the Supreme Court an opportunity to review the constitutional judgment of the legislative branch. 6. The President has enhanced responsibility to resist unconstitutional provisions that encroach upon the constitutional powers of the Presidency. Where the President believes that an enactment unconstitutionally limits his powers, he has the authority to defend his office and decline to abide by it, unless he is convinced that the Court would disagree with his assessment. If the President does not challenge such provisions (i.e., by refusing to execute them), there often will be no occasion for judicial consideration of their constitutionality; a policy of consistent Presidential enforcement of statutes limiting his power thus would deny the Supreme Court the opportunity to review the limitations and thereby would allow for unconstitutional restrictions on the President's authority. Some legislative encroachments on executive authority, however, will not be justiciable or are for other reasons unlikely to be resolved in court. If resolution in the courts is unlikely and the President cannot look to a judicial determination, he must shoulder the responsibility of protecting the constitutional role of the presidency. This is usually true, for example, of provisions limiting the President's authority as Commander in Chief. Where it is not possible to construe such provisions constitutionally, the President has the authority to act on his understanding of the Constitution. One example of a Presidential challenge to a statute encroaching upon his powers that did result in litigation was Myers v. United States, 272 U.S. 52 (1926). In that case, President Wilson had defied a statute that prevented him from removing postmasters without Senate approval; the Supreme Court ultimately struck down the statute as an unconstitutional limitation on the President's removal power. Myers is particularly instructive because, at the time President Wilson acted, there was no Supreme Court precedent on point and the statute was not manifestly unconstitutional. In fact, the constitutionality of restrictions on the President's authority to remove executive branch officials had been debated since the passage of the Tenure of Office Act in 1867 over President Johnson's veto. The closeness of the question was underscored by the fact that three Justices, including Justices Holmes and Brandeis, dissented in Myers. Yet, despite the unsettled constitutionality of President Wilson's action, ‘no member of the Court in Myers suggested that Wilson overstepped his constitutional authority -- or HOUSE_OVERSIGHT_012387

even acted improperly -- by refusing to comply with a statute he believed was unconstitutional. The Court in Myers can be seen to have implicitly vindicated the view that the President may réfuse to comply with a statute that limits his constitutional powers if he believes it is unconstitutional. As Attorney General Civiletti stated in a 1980 opinion, Myers is very nearly decisive of the issue [of Presidential denial of the validity of statutes]. Myers holds that the President's constitutional duty does not require him to execute unconstitutional statutes; nor does it require him to execute them provisionally, against the day that they are declared unconstitutional by the courts. He cannot be required by statute to retain postmasters against his will unless and until a court says that he may lawfully let them go. If the statute is unconstitutional, it is unconstitutional from the start. The Attorney General's Duty to Defend and Enforce Constitutionally Objectionable Legislation, 4A Op. O.L.C. 55, 59 (1980). 7. The fact that a sitting President signed the statute in question does not change this analysis. The text of the Constitution offers no basis for distinguishing bills based on who signed them; there is no constitutional analogue to the principles of waiver and estoppel. Moreover, every President since Eisenhower has issued signing statements in which he stated that he would refuse to execute unconstitutional provisions. See annotations of attached signing statements. As we noted in our memorandum on Presidential signing statements, the President "may properly announce to Congress and to the public that he will not enforce a provision of an enactment he is signing. If so, then a signing statement that challenges what the President determines to be an unconstitutional encroachment on his power, or that announces the President's unwillingness to enforce (or willingness to litigate) such a provision, can be a valid and reasonable exercise of Presidential authority." Memorandum for Bernard N. Nussbaum, Counsel to the President, from Walter Dellinger, Assistant Attorney General, Office of Legal Counsel at 4 (Nov. 3, 1993). (Of course, the President is not obligated to announce his reservations in a signing statement; he can convey his views in the time, manner, and form of his choosing.) Finally, the Supreme Court recognized this practice in INS v. Chadha, 462 U.S. 919 (1983): the Court stated that "it is not uncommon for Presidents to approve legislation containing parts which are objectionable on constitutional grounds" and then cited the example of President Franklin Roosevelt's memorandum to Attorney General Jackson, in which he indicated his intention not to implement an unconstitutional provision in a statute that he had just signed. Id. at 942 n.13. These sources suggest that the President's signing of a bill does not affect his authority to decline to enforce constitutionally objectionable provisions thereof. In accordance with these propositions, we do not believe that a President is limited to choosing between vetoing, for example, the Defense Appropriations Act and executing an unconstitutional provision in it. In our view, the President has the authority to sign legislation containing desirable elements while refusing to execute a constitutionally defective provision. We recognize that these issues are difficult ones. When the President's obligation to act in accord ' with the Constitution appears to be in tension with his duty to execute laws enacted by Congress, questions are raised that go to the heart of our constitutional structure. In these circumstances, a President should proceed with caution and with respect for the obligation that each of the branches shares for the maintenance of constitutional government. Walter Dellinger Assistant Attorney General Brief Description of Attached Materials HOUSE_OVERSIGHT_012388

Attorney General Opinions 1) Memorial of Captain Meigs, 9 Op. Att'y Gen. 462 (1860): In this opinion the Attorney General concluded that the President is permitted to disregard an unconstitutional statute. Specifically, Attorney General Black concluded that a statute purporting to appoint an officer should not be enforced: "Every law is to be carried out so far forth as is consistent with the Constitution, and no further. The sound part of it must be executed, and the vicious portion of it suffered to drop." Id. at 469. 2) Constitutionality of Congress' Disapproval of Agency Regulations by Resolutions Not Presented to the President, 4A Op. O.L.C. 21 (1980): In this opinion Attorney General Civiletti instructed Secretary of Education Hufstedler that she was authorized to implement regulations that had been disapproved by concurrent congressional resolutions, pursuant to a statutory legislative veto. The Attorney General’ noted that "the Attorney General must scrutinize with caution any claim that he or any other executive officer may decline to defend or enforce a statute whose constitutionality is merely in doubt." Id. at 29. He concluded, however, that "[t]o regard these concurrent resolutions as legally binding would impair the Executive's constitutional role and might well foreclose effective judicial challenge to their constitutionality. More important, I believe that your recognition of these concurrent resolutions as legally binding would constitute an abdication of the responsibility of the executive branch, as an equal and coordinate branch of government with the legislative branch, to preserve the integrity of its functions against constitutional encroachment." Id. . 3) The Attorney General's Duty to Defend and Enforce Constitutionally Objectionable Legislation, 4A Op. O.L.C. 55.(1980): Attorney General Civiletti, in answer to a congressional inquiry, observed that “Myers holds that the President's constitutional duty does not require him to execute unconstitutional statutes; nor does it require him to execute them provisionally, against the day that-they are declared unconstitutional by the courts." Id. at 59. He added as a cautionary note that "[t]he President has no “dispensing power,'" meaning that the President and his subordinates “may not lawfully defy an Act of Congress if the Act is constitutional. . . . In those rare instances in which the Executive may lawfully act in contravention of a statute, it is the Constitution that dispenses with the operation of the statute. The Executive cannot." Id. at 59-60. 4) Letter from William French Smith, Attorney General, to Peter W. Rodino, Jr., Chairman, House Judiciary Committee (Feb. 22, 1985): This letter discussed the legal precedent and authority for the President's refusal to execute a provision of the Competition in Contracting Act. The Attorney General noted that the decision "not to implement the disputed provisions has the beneficial byproduct of increasing the likelihood of a prompt judicial resolution. Thus, far from unilaterally nullifying an Act of Congress, the Department's actions are fully consistent with the allocation of judicial power by the Constitution to the courts." Id. at 8. The letter also stated that "the President's failure to veto a measure does not prevent him subsequently from challenging the Act in court, nor does presidential approval of an enactment cure constitutional defects." Id. at 3. Office of Legal Counsel Opinions 1) Memorandum to the Honorable Robert J. Lipshutz, Counsel to the President, from John M. Harmon, Assistant Attorney General, Office of Legal Counsel (Sept. 27, 1977): This opinion concluded that the President may lawfully disregard a statute that he interprets to be unconstitutional. We asserted that "cases may arise in which the unconstitutionality of the relevant statute will be certain, and in such a case the Executive could decline to enforce the statute for that reason alone." Id. at 13. We continued, stating that "[uJnless the unconstitutionality of a statute is clear, the President Should attempt to resolve his doubts in a way that favors the statute, and he should not decline to enforce it unless he concludes that he is compelled to do so under the circumstances." Id. We declined to catalogue all the considerations that would weigh in favor of non-enforcement, but we identified two: first the extent of the harm to individuals or the government resulting from enforcement; and, HOUSE_OVERSIGHT_012389

~ second, the creation of an opportunity for a court challenge through non-enforcement (e.g., Myers). 2) Appropriations Limitation for Rules Vetoed by Congress, 4B Op. O.L.C. 731 (1980): In this opinion we rejected the constitutionality of a proposed legislative veto, prior to the Court's decision in Chadha. We opined that "[t]o regard this provision as legally binding would impair the Executive's constitutional role and would constitute an abdication of the responsibility of the Executive Branch." Id. at 734. It should be noted that the legislation in question was pending in Congress, and the possibility that President Carter would sign the legislation did not affect our analysis of the constitutional issue. We simply stated that, "if enacted, the [legislative veto provision] will not have any legal effect." Id. 3) Issues Raised by Section 102(c)(2) of H.R. 3792, 14 Op. O.L.C. 38 (1990) (preliminary print): This opinion also addressed then-pending legislation, in this case the foreign relations authorization bill for fiscal years 1990 and 1991. The opinion found that a provision of the bill was unconstitutional and severable. Regarding non-execution, the opinion stated that "at least in the context of legislation that infringes the separation of powers, the President has the constitutional authority to refuse to enforce unconstitutional laws." Id. at 53. The opinion concluded that “if the President chooses to sign H.R. 3792, he would be constitutionally authorized to decline to enforce" the constitutionally objectionable section. Id. at 38. 4) Issues Raised by Section 129 of Pub. L. No. 102-138 and Section 503 of Pub. L. No. 102-140, 16 Op. O.L.C. 18 (1992) (preliminary print): This opinion concluded that two statutory provisions that limited the issuance of official and diplomatic passports were unconstitutional and were severable from the remainder of the two statutes. On the question of non-execution, the opinion rejected "the argument that the President may not treat a statute as invalid prior to a judicial determination." Id. at 40. The opinion concluded that the Constitution authorizes the President to refuse to enforce a law that he believes is unconstitutional. 5) Memorandum for Bernard N. Nussbaum, Counsel to the President, from. Walter Dellinger, Assistant Attorney General, Office of Legal Counsel (Nov. 3, 1993): This opinion discusses different categories of signing statements, including those construing bills to avoid constitutional problems and those in which the President declares “that a provision of the bill before him is flatly unconstitutional, and that he will refuse to enforce it." Id. at 3. The opinion concludes that such "uses of Presidential signing statements generally serve legitimate and defensible purposes." Id. at 7. Presidential Signing Statements 1) Statement by the State Department (Announcing President Wilson's Refusal to Carry Out the Section of the Jones Merchant Marine Act of June 5, 1920, directing him to terminate treaty provisions restricting the Government's right to impose discriminatory tonnage dues and tariff duties )I7A Compilation of the Messages and Papers of the Presidents 8871 (Sept. 24, 1920) (Pres. Wilson): The State Department announced that it "has been informed by the President that he does not deem the direction contained in Section 34 of the so-called Merchant Marine Act an exercise of any constitutional power possessed by the Congress." Id. The statement also defended President Wilson's — ‘decision to sign the bill and noted that "the fact that one section of the law involves elements of illegality rendering the section inoperative need not affect the validity and operation of the Act as a whole." 5.Green Haywood Hackworth, Digest of International Law 324 (1943). 2) Special Message to the Congress Upon Signing the Department of Defense Appropriation Act, Pub. Papers of Dwight D, Eisenhower 688 (July 13, 1955): President Eisenhower, in signing a bill (H.R. 6042) that contained a legislative veto, stated that the legislative veto "will be regarded as invalid by the executive branch of the Government in the administration of H.R. 6042, unless otherwise determined by a court of competent jurisdiction." Id. at 689.- HOUSE_OVERSIGHT_012390

a 3) Memorandum on Informing Congressional Committees of Changes Involving Foreign Economic Assistance Funds, Pub. Papers of John F. Kennedy 6 (Jan. 9, 1963): President Kennedy stated that a provision in the bill he was signing contained an unconstitutional legislative veto. He announced that "[i]t is therefore my intention .. . to treat this provision as a request for information." Id. 4) Statement by the President Upon Approving the Public Works Appropriations Act, Pub. Papers of Lyndon B. Johnson 104 (Dec. 31, 1963): President Johnson also found that a legislative veto provision was unconstitutional and stated that he would treat it as a request for information. 5) Statement About Signing the Public Buildings Amendments of 1972, Pub. Papers of Richard Nixon 686 (June.17, 1972): President Nixon stated that a clause conditioning the use of authority by the executive branch on the approval of a congressional committee was unconstitutional. He ordered the agency involved to comply with "the acceptable procedures" in the bill “without regard to the unconstitutional provisions I have previously referred to." Id: at 687. 6) Statement on Signing the Department of Defense Appropriation Act of 1976, Pub. Papers of Gerald R. Ford 241 (Feb. 10, 1976): President Ford stated that a committee approval mechanism was unconstitutional and announced that he would "treat the unconstitutional provision . . . to the extent it requires further Congressional committee approval, as a complete nullity." Id. at 242. 7) Statement on Signing Coastal Zone Management Improvement Act of 1980, Pub. Papers of Jimmy Carter 2335 (Oct. 18, 1980): President Carter stated that a legislative veto provision was unconstitutional and that any attempt at a legislative veto would "not [be] regarded as legally binding." Id. 8) Statement on Signing the Union Station Redevelopment Act of 1981, Pub. Papers of Ronald Reagan 1207 (Dec. 29, 1981): President Reagan stated that a legislative veto was unconstitutional and announced that "[t]he Secretary of Transportation will not... regard himself as legally bound by any such resolution." Id. 9) Statement On Signing the National and Community Service Act of 1990, Pub. Papers of George Bush 1613 (Nov. 16, 1990): President Bush rejected the constitutionality of provisions that required a Presidentially appointed board exercising executive authority to include, among its 21 members, “seven members nominated by the Speaker of the House of Representatives... [and] seven members nominated by the Majority Leader of the Senate." Id. at 1614. He announced that the restrictions on his choice of nominees to the board "are without legal force or effect." Id. 10) 7 A Compilation of the Messages and Papers of the Presidents 377 (Aug. 14, 1876) (Pres. Grant): This is one of the earliest of many instances of a President "construing" a provision (to avoid constitutional problems) in a way that seems to amount to a refusal to enforce a provision of it. An 1876 statute directed that notices be sent to certain diplomatic and consular officers "to close their offices." President Grant, in signing the bill, stated that, “[iJn the literal sense of this direction it would be an invasion of the constitutional prerogatives and duty of the Executive." Id. In order to avoid this problem, President Grant "constru[ed]" this provision "only to exercise the constitutional prerogative of Congress over the expenditures of the Government," not to "imply{] a right in the legislative branch to direct the closing or discontinuing of any of the diplomatic or consular offices of the Government." Id. at 378. _ Other Presidential Documents 1) A Presidential Legal Opinion, 66 Harv. L. Rev. 1353 (1953): This was a legal opinion from President Franklin Roosevelt to Attorney General Jackson. President Roosevelt stated that he was signing the Lend-Lease Act despite a provision providing for a legislative veto, "a provision which, in HOUSE_OVERSIGHT_012391

my opinion, is clearly unconstitutional." Id. at 1357. The President stated that, "[i]n order that I may be on record as indicating my opinion that the foregoing provision of the so-called Lend-Lease Act is unconstitutional, and in order that my approval of the bill, due to the existing exigencies of the world situation, may not be construed as a tacit acquiescence in any contrary view, I am requesting you to place this memorandum in the official files of the Department of Justice. I am desirous of having this done for the further reason that I should not wish my action in approving the bill which includes this invalid clause, to be used as a precedent for any future legislation comprising provisions of a similar nature." Id. at 1358. 2) Message to the Congress on Legislative Vetoes, Pub. Papers of Jimmy Carter 1146 (Jun. 21, 1978 ): In this memorandum President Carter expressed his strong opposition to legislative vetoes and stated that "[t]he inclusion of [a legislative veto] in a bill will be an important factor in my decision to sign or to veto it." Id. at 1148. He further stated that, "[a]s for legislative vetoes over the execution of programs already prescribed in legislation and in bills I must sign for other reasons, the Executive Branch will generally treat them as 'report-and-wait' provisions. In such a case, if Congress subsequently adopts a resolution to veto an Executive action, we will give it serious consideration, but we will not, under our reading of the Constitution, consider it legally binding." Id. at 1149. Historical Materials 1) Statement of James Wilson on December 1, 1787 on the Adoption of the Federal Constitution, reprinted in 2 Jonathan Elliot, Debates on the Federal Constitution 418 (1836): Wilson argued that the Constitution imposed significant -- and sufficient -- restraints on the power of the legislature, and that the President would not be dependent upon the legislature. In this context, he stated that "the power of the Constitution was paramount to the power of the legislature acting under that Constitution; for it is possible that the legislature . . . may transgress the bounds assigned to it, and an act may pass, in the usual mode, notwithstanding that transgression; but when it comes to be discussed before the judges,-- when they consider its principles, and find it to be incompatible with the superior power of the Constitution,-- it is their duty to pronounce it void . . . . In the same manner, the President of the United States could shield himself, and refuse to carry into effect an act that violates the Constitution." Id. at 445-46. 2) Letter from Chief Justice Chase to Gerrit Smith (Apr. 19, 1868), quoted in J. Schuckers, The Life and Public Services of Salmon Portland Chase 577 (1874): Chase stated that President Johnson took the proper action in removing Secretary of War Stanton without Senate approval, in light of Johnson's belief that the statutory restriction on his removal authority was unconstitutional. In this regard, Chase commented that "the President had a perfect right, and indeed was under the highest obligation, to remove Mr. Stanton, if he made the removal not in wanton disregard of a constitutional law, but with a sincere belief that the Tenure-of-Office Act was unconstitutional and for the purpose of bringing the question before the Supreme Court." Id. at 578. Congressional Materials 1) The President's Suspension of the Competition in Contracting Act is Unconstitutional, H.R. Rep. No. 138, 99th Cong., Ist Sess. (1985): The House Committee on Government Operations concluded thatthe President lacked the authority to refuse to implement any provision of the Competition in Contracting Act. The Committee stated that, "[t]o adopt the view that one's oath to support and defend the Constitution is a license to exercise any available power in furtherance of one's own constitutional interpretation would quickly destroy the entire constitutional scheme. Such a view, whereby the President pledges allegiance to the Constitution but then determines what the Constitution means, inexorably leads to the usurpation by the Executive of the others' roles." Id. at 11. The Committee also stated that "[t]he Executive's suspension of the law circumvents the constitutionally specified means for expressing Executive objections to law and is a constitutionally impermissible absolute veto HOUSE_OVERSIGHT_012392

power." Id. at 13. 2) Memorandum from the Congressional Research Service to the Committee on Government Operations concerning “The Executive's Duty to Enforce the Laws" (Feb. 6, 1985), reprinted in Constitutionality of GAO's Bid Protest Function: Hearings Before a Subcomm. of the House Comm. on Government Operations, 99th Cong., Ist Sess. 544 (1985): This memorandum stated that the President lacks the authority to decline to enforce statutes. The CRS argued that "[t]he refusal of the President to execute the law is indistinguishable from the power to suspend the laws. That power, as is true of the power to amend or to revive an expired law, is a legislative power." Id. at 554. Cases (not included in the submitted materials) 1) Myers v. United States, 272 U.S. 52 (1926): The President refused to comply with -- that is, enforce -- a limitation on his power of removal that he regarded as unconstitutional, even though the question had not been addressed by the Supreme Court. A member of Congress, Senator Pepper, urged the Supreme Court to uphold the validity of the provision. The Supreme Court vindicated the President's interpretation without any member of the Court indicating that the President had acted unlawfully or inappropriately in refusing to enforce the removal restriction based on his belief that it was unconstitutional. 2) United States v. Lovett, 328 U.S. 303 (1946): The President enforced a statute that directed him to withhold compensation from three named employees, even though the President believed the law to be unconstitutional. The Justice Department argued against the constitutionality of the statute in the ensuing litigation. (The Court permitted an attorney to appear on behalf of Congress, amicus curiae, to defend the statute.) 3) INS v. Chadha, 462 U.S. 919 (1983): This case involved the withholding of citizenship from an applicant pursuant to a legislative veto of an Attorney General decision to grant citizenship. Despite a Carter Administration policy against complying with legislative vetoes (see Carter Presidential memorandum, supra), the executive branch enforced the legislative veto, and, in so doing, allowed for judicial review of the statute. As with Lovett, the Justice Department argued against the constitutionality of the statute. 4) Morrison v. Olson, 487 U.S. 654 (1988): The President viewed the independent counsel statute as unconstitutional. The Attorney General enforced it, making findings and forwarding them to the Special Division. In litigation, however, the Justice Department attacked the constitutionality of the statute and left its defense to the Senate Counsel, as amicus curiae, and the independent counsel herself. , 5) Freytag v. Commissioner, 501 U.S. 868 (1991): A unanimous Court ruled that the appointment of special trial judges by the Chief Judge of the United States Tax Court did not violate the Appointments Clause. Five Justices concluded that the Tax Court was a "Court of Law" for Appointments Clause purposes, despite the fact that it was an Article I court, so that the Tax Court could constitutionally appoint inferior officers. Four Justices, in a concurrence by Justice Scalia, contended that the Tax Court was a "Department" under the Appointments Clause. The concurrence stated that "Court of Law" did not include Article I courts and that the Framers intended to prevent Congress from having the power both to create offices and to appoint officers. In this regard, the concurrence stated that "it was not enough simply to repose the power to execute the laws (or to appoint) in the President; it was also necessary to provide him with the means to resist legislative encroachment upon that power. The means selected were various, including a separate political constituency, to which he alone was responsible, and the power to veto encroaching laws, see Art. I, § 7, or even to disregard them when they are unconstitutional." Id. at 906 (Scalia, J., concurring). HOUSE_OVERSIGHT_012393

6) Lear Siegler, Inc., Energy Products Division v. Lehman, 842 F.2d 1102 (9th Cir. 1988), withdrawn in part 893 F.2d 205 (9th Cir. 1990) (en banc): The President refused to comply with provisions of the Competition.in Contracting Act that he viewed as unconstitutional and thereby allowed for judicial resolution of the issue. The Ninth Circuit rejected the President's arguments about the constitutionality of the provisions. The court further determined that Lear Siegler was a prevailing party and was entitled to attorneys' fees, because the executive branch acted in bad faith in refusing to execute the contested provisions. In this regard, the court stated that the President's action was “utterly at odds with the texture and plain language of the Constitution," because a statute is part of the law of the land that the President is obligated to execute. Id. at 1121, 1124. On rehearing en banc, the court ruled that Lear Siegler was not a prevailing party and withdrew the sections of the opinion quoted above. HOUSE_OVERSIGHT_012394

TAB 13 HOUSE_OVERSIGHT_012395

room. on OD oO FB WwW NH ~0929104. TXT IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 2006 CFOS454AXX STATE OF FLORIDA, -VS- JEFFREY EPSTEIN, Defendant. / Wednesday, February 20, 2008 2:00 p.m. - 4:30 p.m. Palm Beach County Courthouse 205 North Dixie Highway West Palm Beach, Florida 33401 Reported By: Judith F. Consor, FPR Notary Public, State of Florida Consor & Associates Reporting and Transcription Phone - 561.682.0905 APPEARANCES: On behalf of the State: LANNA BELOHLAVEK, ESQ. ASSISTANT STATE ATTORNEY 401 North Dixie Highway West Palm Beach, Florida 33401 561.355.7100 On behalf of the Defendant: MICHAEL R. TEIN, ESQ. KATHRYN A. MEYERS, ESQ. LEWIS TEIN, PL 3059 GRAND AVENUE, SUITE 340 Page 1 HOUSE_OVERSIGHT_012396

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 —_ oO BW NY ODO oO FB WwW KN ~0929104. TXT COCONUT GROVE, FL 33133 On behalf of the Defendant: JACK A. GOLDBERGER, ESQ. ATTERBURY, GOLDBERGER & WEISS 250 AUSTRALIAN AVENUE SOUTH SUITE 1400 WEST PALM BEACH, FLORIDA 33401 561.659.8300 ALSO PRESENT: KEITH J. BRETT, DIRECTOR OF MULTIMEDIA DIVISION, LEGAL -EZE | NDE X WITNESS: PAGE: DIRECT EXAMINATION 4 BY MR. TEIN: NO EXH!BITS MARKED Page 2 HOUSE_OVERSIGHT_012397

~0929104. TXT 14 15 16 17 18 19 20 21 22 23 24 25 4 7 Deposition taken before Judith F. Consor, 2 Court Reporter and Notary Public in and for the State of 3 Florida at Large, in the above cause. 4 ~ » « 5 Thereupon, 6 a 7 having been first duly sworn or affirmed, was examined 8 and testified as follows: 9 THE WITNESS: 1! do. 10 DIRECT EXAMINATION 11 BY MR. TEIN: 12 Q. Good afternoon. Please tell me your full 13 name. 14 a 15 Q. And can you please spel! it? — 7 Page 3 HOUSE_OVERSIGHT_012398

fo™ 18 19 20 21 22 23 24 25 —_ oOo Ont OD nN Be Ww NY 16 17 18 19 20 21 22 ~0929104 . TXT Q. Thank you. May | call you i? A. Uh-huh. Q. | I'm going to ask you a few questions, several questions today. If at any time you want to take a break, you just fet me know. Okay? A. Okay. Q. if you at any time don't understand one of my questions, will you just please let me know? A. Yes. Q. And if at any time you’re not feeling well or something like that, you'll! tell us, right? A. Yes. Q. Do you feel okay today? A. Yes. Q. Not taking any alcohol or drugs or anything like that, right? A. No. Q. So you feel ready to have your deposition taken? A. Yes. Q. MMMM what is your address? A. ]’m currently living at my aunt's house and | don’t know it off the top of my head. Q A Q. A Q A Where is it? In Jupiter. Who is your aunt? Who else is living there? PS vy uncle. Page 4 HOUSE_OVERSIGHT_012399

ue sy / 23 24 25 — oO Oo CNY Oo oO FF WwW DY ~0929104. TXT Q. Anyone else living there? A. No. Q. The contempt motion that your mother filed 6 against your father regarding your fifty million-dollar lawsuit against Jeffrey Epstein says that you live with your aunt and uncle and have been !iving there; is that correct? A. Yes. Q. How long have you been living with your aunt and uncle? A. Since my father kicked me out. Q. That was Thanksgiving of this past year? A. Yes, sir. Q, Okay. Didn't did your firefighter boy friend Po get an apartment for the two of you? A. No, sir. He has an apartment, but by himself. Q. Did he get an apartment for the two of you to live in? A, No, sir. Q. Are you planning to move in with him? A. Maybe one day in the future. Q. Do you have a plan to move in with him presently? A. No. Q. Have you been to the apartment that you and ae: discussed moving in together? Page 5 HOUSE_OVERSIGHT_012400

—_ oO Oo ON DO oO ek we o Pr WwW NM ~0929104. TXT | have been to the apartment. Where is that? Have you spent the night over there? No, sir. Do you know the address there? | do not. o> oP oP DD . Isn't your sister planning on living with you and ir A. No. Q. | you know that this court case is a criminal prosecution, correct? A. Correct. Q. And you know that it's a criminal prosecution against a man who has no criminal background. Do you know that? A. | do now. Q. You agree that court is a very serious matter? A. Yes. Q. And you're here with your lawyer Mr. Leopold, right? A. Yes. Q. And you know that Mr. Leopold recently Filed a lawsuit in federal court against Jeffrey Epstein, seeking fifty million dollars. MR. LEOPOLD: Let me just object. f let me instruct you. Anything that you have learned through conversations between you Page 6 HOUSE_OVERSIGHT_012401

BY MR. ~0929104.TXT and me are protected. So if you know any of that information outside of those discussions, you may answer. But if the only way you know it is through our discussions, do not answer that question. TEIN: Q. L you know that Mr. Leopold recently filed a lawsuit in federal court on your behalf against Jeffrey Epstein seeking fifty million dollars. BY MR. BY MR. MR. LEOPOLD: Same objection. If you know the answer to that outside of our discussions, you may answer. If it is the only way that you know the answer is through our discussions, do not answer that question. THE WITNESS: Okay. MR. LEOPOLD: Attorney/client privilege. TEIN: Q. You can answer the question unless -- MR. LEOPOLD: Same objection. MR. TEIN: Let me finish. MR. LEOPOLD: Excuse me. We're -- 9 MR. TEIN: No. Let me finish. MR. LEOPOLD: Lewis, we're not going to do that. MR. TEIN: My name is not Lewis. I'm going to finish my question. Okay? MR. LEOPOLD: Do not answer until you hear from me. TEIN: Page 7 HOUSE_OVERSIGHT_012402

—_ 10 11 12 13 14 15 16 7 18 19 20 21 22 23 24 25 — oO Oo OW NY TD oO FP WwW DY ~0929104. TXT Q. Other than conversations that you have had with Mr. Leopold -- |'m not asking about that -- are you aware that Mr. Leopold has filed a lawsuit in federal court. seeking fifty million dollars from Jeffrey Epstein on your behalf? MR. LEOPOLD: Same objection. Anything that you learn through conversations between you and me, do not answer. Those are protected. If you know through any other realm of Knowledge, you may answer. THE WITNESS: No. BY MR. TEIN: Q. You have no idea that Mr. Leopold filed a Fifty million-dollar lawsuit on your behalf against Jeffrey Epstein? MR. LEOPOLD: Same objection. Do not answer that question if it's through 10 discussions that you and | had. Outside of that, you may answer. So do not answer that question if that is the only basis by which you understand that answer. THE WITNESS: No. BY MR. TEIN: Q. You didn't know that? MR. LEOPOLD: Don't answer that question. Against, it's attorney/client privilege. Any information you've learned through conversations between you and [ are protected. If you know it through any other realm, you may answer. MR. TEIN: Are you going to say that for Page 8 HOUSE_OVERSIGHT_012403

14 15 16 17 18 19 20 21 22 23 24 25 —_ oO Oo MO 4 OD oO PF WwW PD ~0929104. TXT every question in the deposition, Mr. Leopold? MR. LEOPOLD: When you ask improper questions like that without the proper -- MR. TEIN: You're going to stop your speaking objections right now. Okay? MR. LEOPOLD: Without the proper -- MR. TEIN: You need to stop your speaking objections. Let's continue. MR. LEOPOLD: Counsel, you just asked me a question and I'm going to state jit on the record -- 1 MR. TEIN: You need to stop your speaking objections. Check your rules. MR. LEOPOLD: Excuse me. For the record, Counsel asked me a question. I'1!l state the answer on the record. He asked me the question am | going to be answering that way throughout the deposition. So long as there's improper foundation and predicate asked by the attorney, | will protect my client and | make the record where appropriate. If counsel wishes to ask an appropriate worded question with the proper foundation and predicate, | will certainly allow the client to answer the question. MR. GOLDBERGER: Why don't you just state attorney/client privilege and just be done with it. MR. LEOPOLD: | want the record to be Page 9 HOUSE_OVERSIGHT_012404

18 19 20 21 22 23 24 25 7 oO fm SN ODO oO Be WwW NY ~0929104. TXT clear. MR. TEIN: You want to waste time is what you want to do. You were supposed to be here this morning and you totally broke the deal, the agreement that you had with us if your hearing got cancel led. But let's move on and maybe you'll stop obstructing this deposition. 12 MR. LEOPOLD: | think the record is very clear where we stand thus far. Is there a recording taken of this deposition? THE COURT REPORTER: Yes. MR. LEOPOLD: Just make sure that's preserved. BY MR. TEIN: Q. Go to Exhibit 20-01 -- well, before you do that, i, are you aware that a lawyer named Jeffrey Herman Filed a lawsuit on your behalf, yes or no? MR. LEOPOLD: Objection. Any conversations that you and | have had regarding that, if that is the only way by which you understand how to answer that question, so not answer. It's attorney/client privilege, as wel| as any conversations you may have had with the attorney from Miami. That is also attorney/client privilege. And I'm assuming -- MR. TEIN: You're actually wrong about the attorney/client privilege. MR. LEOPOLD: I'm assuming Counsel is not Page 10 HOUSE_OVERSIGHT_012405

~0929104.TXT 23 asking you to divulge attorney/client -- 24 MR. TEIN: Of course not. 25 BY MR. TEIN: 13 3 4 MR. LEOPOLD: Same objection. 5 MR. TEIN: We've heard the objection 10 6 times already. 7 MR. LEOPOLD: Counsel, excuse me. 8 MR. TEIN: Just say attorney/client 9 privilege. Stop interrupting my questions. 10 MR. LEOPOLD: I'm entitled to make an 11 objection for the record, which !'m doing, and 12 I’ || make the same objection. And if it calls for 13 attorney/client privilege, any conversations you 14 and | have had, do not answer the question. 15 And | think that it might be appropriate 16 for the record to ask questions i iii 17 as opposed to J | think that would be more 18 appropriate for this deposition. 19 BY MR. TEIN: 20 Q. Go ahead. Please answer yes or no. 21 22 Q. Thank you. 23 in fact, you know that Mr. Herman held a 24 press conference after he filed the fFifty-million-do} lar 25 lawsuit on your behalf, don't you? Page 11 HOUSE_OVERSIGHT_012406

—_ oO oOo ON OD oO Pe wH ON - WwW DM ~0929104. TXT 14 A. After it happened. Q. don’t you, yes or no? Ae Q. In fact, let's go to Exhibit 20-01. MR. GOLDBERGER: Look behind you. You'l] see it. BY MR. TEIN: Q. Have you ever seen that picture before? A. Yes. Q. Is that a picture of your father, your stepmother and Mr. Herman at the press conference regarding your lawsuit? A. Yes. Q. Now you know that this is a very serious matter, don't you? MR. LEOPOLD: Asked and answered. Objection. MR. GOLDBERGER: All right. You can object. You're representing a witness here, Mr. Leopold. You can object on privilege grounds. You cannot make legal objections. You have no standing to do so. MR. LEOPOLD: I'm going to make them and then -- 15 MR. GOLDBERGER: We're -- MR. LEOPOLD: We're going to leave or we're going to take a break because his demeanor is not appropriate. There's no reason to have this kind Page 12 HOUSE_OVERSIGHT_012407

= on mn oo F&F WwW DN ~0929104.TXT of demeanor. !f you want to have this kind of demeanor with me -- MR. TEIN: You are obstructing this deposition. MR. GOLDBERGER: Why don't you guys go outside and just talk about -- MR. LEOPOLD: She -- her job is very difficult and she’s not going to be able to take us both talking at he same time. MR. GOLDBERGER: Off the record. MR. LEOPOLD: We're not going off the record, Jack. We're not, Jack. Her job is very difficult. |'m going to make the record. | don't think it is appropriate, especially in the smal! confines of this room, to be very aggressive with this young lady. MR. TEIN: That’s not happening. Stop, stop actually -- MR. LEOPOLD: If you're going to interrupt me, we're going to cancel this deposition -- MR. TEIN: Stop misrepresenting. 16 THE COURT REPORTER: | need on at a time, no matter who it is. MR. LEOPOLD: | think we're going to take a break. Perhaps you might want to talk to your co-counsel -- MR. TEIN: I don't need to talk to him. MR. LEOPOLD: But we're going to take a break. Page 13 HOUSE_OVERSIGHT_012408

oo, 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 —_ (o> en «°° ©? ©) 0 ~0929104. TXT MR. TEIN: Not taking a break unless the witness needs a break. You're obstructing this deposition, Ted. MR. LEOPOLD: Come on, You all want to continue in this demeanor -- MR. TEIN: You're obstructing the deposition. Stop making speeches. We're not discussing this with you. The questions are to your client. Go take your five-minute break. MR. LEOPOLD: Fine. We need to make sure the record's clear and clean. And | want to make sure as I've already asked you -- | know that you're one of the best in town -- that this audio -- this needs to be preserved. Okay? MR. TEIN: Go take your five-minute break, 7 Mr. Leopold, now. You were supposed to be here at nine a.m.; it's now after two. Take your break and come back. MR. LEOPOLD: Okay. If the demeanor keeps up, we will not be here beyond those five minutes. MR. TEIN: Take your break and come back. MR. LEOPOLD: Okay. So [ suggest that you relax. MR. TEIN: | suggest that you take your break. MR. GOLDBERGER: Let them take that five-minute break. Page 14 HOUSE_OVERSIGHT_012409

~0929104. TXT 14 MR. LEOPOLD: But | would suggest that you 15 take deep breaths. 16 MR. TEIN: Suggest whatever you want. Go 17 take a break. 18 (Thereupon, a recess was taken.) 19 BY MR. TEIN: 20 Q. | you agree that giving testimony 21 today at your deposition is something very serious, don't 22 you? 23 A. Yes. 24 25 18 1 Q. Let me show you Exhibit 31-001. Can you 2 read that out loud, please? 3 A. Okay. What do you want? 4 Q Will you read that out loud, please. 5 A. Oh. 6 Q Thank you. 7 A & @: Like after so long wow 10 im sorry... well yah well we wil! definitely havta make 11 plans for sure..because i miss u tons times a million and 12 no no no i love you...0 p.s. ji love ur default pic 13° niggaa. Muah xo. 14 Q. Did you send that message last week to a 15 friend of yours on MySpace? 16 A. 1 wouldn't know. There's no dates and I've 17 deleted that MySpace, so -- Page 15 HOUSE_OVERSIGHT_012410

o™ 18 19 20 21 22 23 24 25 ~0929104. TXT We're going to talk about that in a second. Okay. Did you send that message last week -- Right. o> o> OS Let me Finish my question. Did you send that message last week to a friend of yours on MySpace? A. ! wouldn't know the date, but obviously, 19 it's to a friend. Do you find the term n-i-g-g-e-r offensive? That's not anywhere in there. What word did you use in there? MR. LEOPOLD: Where are you referring to, Counsel? There's 20 plus words in there. MR. TEIN: Don't make a speaking objection. THE WITNESS: Are you referring to anything -- MR. LEOPOLD: no, i Don't -- don't -- fet him ask you the question. BY MR. TEIN: Q. What question were you asking MR. LEOPOLD: She doesn't ask questions. You ask the questions. What is the question pending? BY MR. TEIN: Page 16 HOUSE_OVERSIGHT_012411

23 24 25 — oOo Oo ON ODO oO PF WwW NY ~0929104 . TXT Q. F | what is the last word on there in the text of your message before the closing? A. Niggaa. 20 Q. Don't you find that term offensive? No. MR. LEOPOLD: Can you spel! it for the record, please. THE WITNESS: N-i-g-g -- MR. TEIN: No, no, no. You are not going to be asking questions. MR. LEOPOLD: I|'m not asking questions. I'm asking for the record the word to be spelled because we don't have a video here today. MR. TEIN: These exhibits are part of the record. You -- MR. LEOPOLD: Well, it's not marked as an exhibit. MR. TEIN: Stop interrupting me, Mr. Leopold. | have marked and identified as an exhibit and you will get it. MR. LEOPOLD: There has been no identification of this document in the record. MR. TEIN: Mr. Leopold, stop interrupting this deposition. MR. LEOPOLD: What is the exhibit number marked for identification? MR. TEIN: 31-001. MR. LEOPOLD: Do we have copies? Is it on Page 17 HOUSE_OVERSIGHT_012412

coo wb oO O OA 4 Oo eF WwW NH — & WwW NY ~0929104. TXT 21 the record anywhere? BY MR. TEIN: Q. Let me ask you, | | did you in fact write your friend this message about this deposition? A. Yes. A. Yes. Q. Because you think this deposition is stupid court s-h-j-t, don't you? A. No. Q. You wrote that to your friend, didn't you? A. Yes. Q. You think that court is stupid, don't you? A. In some cases. Q. And you think that court is bull s-h-i-t, don't you? A. No. Q. And you think this deposition is bul! s-h-i-t, don't you? A. No. Q. You wrote that to your friend, didn't you? MR. LEOPOLD: Objection. Asked and answered. MR. TEIN: That's not an objection. 22 BY MR. TEIN: Q. You wrote that to your friend, didn't you? MR. LEOPOLD: Objection. Asked and answered, for the fourth time. Page 18 HOUSE_OVERSIGHT_012413

? — non 4 MD oO FP W LD ~0929104. TXT MR. TEIN: You are improperly objecting, Mr. Leopold. You have no grounds to object. And that's not an objection. MR. LEOPOLD: It is an objection. MR. TEIN: Then terminate the deposition if you think it's been asked and answered. MR. LEOPOLD: Counsel, | am not precluded from just making an objection to the form of the question. As the courts wel! know, and if you practice here in West Palm Beach, many of the judges require you to set the objection with specificity. And 1 will do that. And if you don't want me to, you can make the record. But | will do that. MR. TEIN: Here's what we'll! do, Ted. You can -- | will allow you to reserve an objection to form for every single one of my questions. Otherwise, all you're doing is obstructing. MR. LEOPOLD: | won't do that. MR. TEIN: Of course; because you want to obstruct. 23 MR. LEOPOLD: ATt right. BY MR. TEIN: Q. Saige, you think that giving testimony today, under oath, is bull s-h-i-t, don't you? A. No. Q. And you wrote that to your friend on MySpace last week, didn’t you? MR. LEOPOLD: Objection. Asked and Page 19 HOUSE_OVERSIGHT_012414

a 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 12 13 ~0929104. TXT answered. THE WITNESS: No, | did not. BY MR. TEIN: Q. You didn't write this exhibit? A. ! wrote that, but | didn't write what you said. Q. You wrote in this exhibit, “1! got some stupid court s-h-i-t on the 20th. Bull s-h-i-t." Didn't you write that? A. Yes. Q. Referring to this deposition, didn't you? A. Referring to the court. | was later informed that it was a deposition. Q. ['m going to ask you some questions now about what happened when you went to Jeff Epstein'’s house three years ago. Okay? A. Uh-huh. 24 Q. Now the civil complaint that you filed against Mr. Epstein for fifty million dollars alleged Page 20 HOUSE_OVERSIGHT_012415

14 15 16 7 18 19 20 21 11 12 13 14 15 16 17 ~0929104. TXT that you were totally shocked by what happened when you got there. A. Yes. Q. Were you totally shocked by what happened when you got to Epstein's house? A, Yes. Q. You didn't expect it at all, did you? No. Q. Did Zack JMJever try to convince you to engage in any sexual activity with Epstein? A. No. Q. Did Anthony P| every try to convince you to engage in any sexual activity with Epstein? A. | don't know who Anthony I is. Q. Do you have a friend Anthony? Page 21 HOUSE_OVERSIGHT_012416

18 ~0929104. TXT 26 Q. You're sure that -- let me ask the question again. MR. LEOPOLD: Objection. Asked and answered. And |'ve already answered that a bazillion times. BY MR. TEIN: Q. He's coaching you now. So I'm going to ask the question -- MR. LEOPOLD: Counsel, I've made an objection for the record. MR. TEIN: Stop speaking. MR. LEOPOLD: I'm not going to stop speaking. You can't interrupt me when I'm making the record. MR. TEIN: You're coaching the witness. MR. LEOPOLD: Counsel -- MR. TEIN: Stop coaching the witness. Page 22 HOUSE_OVERSIGHT_012417

23 24 25 —_ oO Oo ON DO oO Be wD NY ~0929104. TXT BY MR. TEIN: Q. | | let me ask you -- MR. LEOPOLD: If you continue to -- 27 MR. TEIN: Stop interrupting my questions. MR. LEOPOLD: Jf you do it one more time, we're leaving. BY MR. TEIN: MR. LEOPOLD: I'm going to make the record. You cannot interrupt me when I'm making the record. Out of professional conduct, you cannot do that. 1|’m entitled to make the record. | made an objection, asked and answered. You demeanor is inappropriate. You're willing and you are able and you're responsible to ask a question in a professional manner and ask the question and once you get the answer, to either follow up on it or move on, but not continuously browbeat and ask the same question over and over because you don't like the answer. MR. TEIN: Calm down, sir. MR. LEOPOLD: Trust me, I'm very calm here. When I'm not calm you'll know it. I'm very calm. So please continue on, but | will not allow you to continue to harass her in the demeanor that you're doing. Ask her a question and move on. MR. TEIN: Are you done? MR. LEOPOLD: Thank you. 1 am. Page 23 HOUSE_OVERSIGHT_012418

a oO O BN OO oO FF WwW DN - WwW DY ~0929104. TXT 28 MR. TEIN: Stop misrepresenting the record and calm down. I'm going to ask my question. Stop it. BY MR. TEIN: MR. LEOPOLD: | think the record is very clear. MR. GOLDBERGER: Let me just clarify something. When you object to the form of a question, you're not instructing the witness not to answer the question, are you? MR. LEOPOLD: No. And |'m not making that objection; only on attorney/client privilege. MR. TEIN: Will you stop speaking now so | can ask my question? Are you done? Okay. I'm going to ask my question. BY MR. TEIN: Q, Listen, I -- MR. LEOPOLD: Hold on. Stop. I've been doing this for 20 plus years and have met a lot of attorneys, but I’ve never had an experience like this where I've -- MR. TEIN: Stop your speeches. MR. LEOPOLD: If you continue to do this, whether it's with me or with my client, | will not 29 put up with it and | don't need to put up with it and it's not appropriate. And I'm sure Mr. Goldberger knows al! this, because | know that he wouldn't do this. So ft will not put up with it. Page 24 HOUSE_OVERSIGHT_012419

~0929104. TXT 5 And | think it's highly inappropriate to do this 6 with this child sitting here, the way you're 7 acting, primarily towards me, and | wil] not put 8 up with it. 9 MR. TEIN: Will you please stop your speech 10 so | can ask questions? 11 MR. LEQPOLD: So long as you act 12 professionally, | will do so. But if you continue 13 to do it this way, | will leave. 14 MR. TEIN: Suit yourself. 15 BY MR. TEIN: 16 Ls 19 MR. LEOPOLD: Asked and answered. 20 Objection. 21 MR. TEIN: Did you get her answer? 22 THE COURT REPORTER: No, | did not. 23 24 BY MR. TEIN: Page 25 HOUSE_OVERSIGHT_012420

potty ~0929104 . TXT 31 A. No. Q. All right. Let me ask you two fina! areas of questioning about this and we'!! move onto something else. Okay? A. Uh-huh. Yes. I'm sorry. HOUSE_OVERSIGHT_012421

oN 20 21 22 23 24 25 a oO DSN DOD HO FP WwW DN ~0929104 . TXT Q. Was 7 or was it the other girl in the car who you rode over with toa Epstein's house? . Q. Who was the other girl in the car with you that day? A. | honestly don't know. 32 Q. Had you ever seen her before? A. No, sir. Q. You told the police that when you rode over to Epstein's you had no idea who she was, right? A. Correct. Q. You told the police that you didn't know her name, but she was like really dark, kind of like a Spanish girl? A. Yes. Q Those were your words, right? A Yes. Q. Do you now know who she is? A No, sir. Q So it was who told you to lie about your age to Jeff Epstein? A. Yes, Sir. Page 27 HOUSE_OVERSIGHT_012422

18 19 20 21 22 23 24 25 _— oO OWN OD om KH w when you out how you were assistan to colle BY MR. T much. on that? Q. All right. Let's talk for a minute about First met Jeff. Okay? A. Sure. Q. When you first met Jeff he tried to find old you were, right? A. Excuse me? 33 Q. During the massage Jeff asked you how old , correct? A. Yes, yes. Q. Now hadn't you already told Jeff's t, the one who walked you upstairs, that you went ge and had just moved down here from Ohio? A. ! never spoke to the lady. Q. Do you want to rethink that answer? MR. LEOPOLD: is that a question? EIN: Q. Do you want to rethink that answer? A. No. I didn't really speak with her that Q. Do you want to try to refresh your memory MR. LEOPOLD: Do you have something to refresh her memory with? MR. TEIN: Do you want to stop making Page 28 HOUSE_OVERSIGHT_012423

oo 23 24 25 — oO Oo OA NN Oo BP WwW YH speaking MR. ~0929104. TXT objections? LEOPOLD: No. But to refresh someone's memory you show them a document. 34 MR. TEIN: | know how to do this. MR. LEOPOLD: Then show her a document. MR. TEIN: Stop speaking. MR. LEOPOLD: I'm not going to stop speaking. I'm going to continue to make the record. MR. TEIN: You're obstructing. Please stop. MR. LEOPOLD: I'm not obstructing. But if you want to refresh her recollection, you need to show her something. That's not a proper question. | object to the foundation and the predicate of that question. MR. MR. BY MR. TEIN: Q. Do TEIN: Are you done? LEOPOLD: | am now. Thank you. you want. to try to refresh your memory as to whether you had any conversation with the woman who walked you upstairs in Epstein's house in which you told her that you went to college and had just moved down from Ohio? MR. LEOPOLD: Objection. Object to the form of the question. Lack of foundation and predicate. BY MR. TEIN: Page 29 HOUSE_OVERSIGHT_012424

—_ oO O© 8B “4 OO oO FB WwW DH 14 15 16 17 18 19 25 2 3 4 Q. A. Q. ~0929104. TXT 35 You can answer the question. Sure. Is there anything that would refresh your memory that in fact you told Mr. Epstein's assistant, the one who walked you upstairs, that you went to college and you had just moved down here from Ohio? A. 1 don't remember saying that, but if you -- | don't remember saying that myself, so -- Q. A. Q. That would be a lie, right? No. | really don't remember. Do you remember Detective Michelle Pagan of the Police Department, Palm Beach Police Department? A. Q A. Q Q. Yes. Do you remember you spoke to her? Yes. Do you remember that you told Detective And do you remember telling Detective Pagan 36 that when you lied to Epstein about your age that you said it really fast so Epstein wouldn't realize you were lying? No, | don't remember saying those words Page 30 HOUSE_OVERSIGHT_012425

11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 oO ON KB wo ~0929104. TXT exactly to her. Q. Does it sound right to you that you told Detective Pagan that you said your age really fast to Epstein -- MS. BELOHLAVEK: Objection. Asked and answered. BY MR. TEIN: Q. ~- so he wouldn't think that you were lying? MR. LEOPOLD: Objection. Asked and answered, lack of Foundation, mischaracterization of her earlier testimony. She's already answered that question. BY MR. TEIN: Q. You can answer it. MR. LEOPOLD: Same objection. It's been asked and answered. You can answer. I've made the objection. THE WITNESS: | forget the question, now. 37 BY MR. TEIN: Q. Let me put it again. MR. LEOPOLD: Objection. Lack of foundation, asked and answered. Page 31 HOUSE_OVERSIGHT_012426

~0929104. TXT 11 BY MR. TEIN: 38 71 A. Yes, 2 Be | 4 In fact, you went of right? 5 Yes. 6 8 Q. Is Wellington the college that you told 9 Jeff's assistant that you were attending? 10 A. | don’t remember having that conversation 11 with her, so | wouldn't know if that's what | said. 12 Q. That was a fie, though, wasn't it? 13 MR. LEOPOLD: Objection to the form of the Page 32 HOUSE_OVERSIGHT_012427

~0929104 . TXT 14 question, lack of Foundation. You're making an 15 assumption. She just answered you she can't tell 16 you that. 17 MR. TEIN: Speaking objection. And you 18 well know that, Mr. Leopold. 19 MR. LEOPOLD: She can't answer that 20 question. The way you phrased that question, 21 you're purposely making her not be honest in her 22 testimony. She can't answer a question like that. 23 She doesn't remember. So then you say, "So you 24 were lying.” That's improper and you know that. 25 That's not a proper question. And any attorney 39 ~ that would do that to a witnesses or to a person 2 that's sitting in this chair is not acting 3 professionally. You can't ask a question like 4 that. You can do it, but it's not proper. And 5 I'm sure you weren't trained that way, certainly 6 not ethically. 7 MR. TEIN: Will you stop? 8 MR. LEOPOLD: I'm not going to stop, 9 because the way you're asking that question is 10 improper and you know it. 11 MR. TEIN: You're losing your cool. 12 BY MR. TEIN: 13 . 14 MR. LEOPOLD: Trust me. I'm very calm. 15 When 1 lose my cool, you'll know it. 16 MR. TEIN: 1 do know it. 17 BY MR. TEIN: Page 33 HOUSE_OVERSIGHT_012428

25 21 22 MR. LEOPOLD: Objection. Foundation, 40 predicate. BY MR. TEIN: Q. THE WITNESS: Correct. Incorrect. Well, you told the police, “At no time did Page 34 HOUSE_OVERSIGHT_012429

~0929104. TXT 23 he touch me." Were you lying to the police then? 24 A. No. Well, | wasn't being fully truthful, 25 but | wasn't lying. 41 1 Q. You told the police twice when you spoke to 2 Michelle Pagan that “at no time did he touch me." Didn't 3 you say that to the police? 4 A. Yeah. 5 Q. And you're saying that that was not fully 6 truthful. Is that what you're saying now? 7 A. Correct. 8 Q. And you're saying if you're not fully 9 truthful, that's not a lie. Correct? 10 14 Q. You told the police, "At no times did he 15 touch me." You agree with that, correct? 16 A. No, | don't agree with that, because he did 17° = touch me. 18 Q. Did you tell the police that he did not 19 touch you, yes or no? 20 A. It's a possibility, but | do not remember. 21 OK Page 35 HOUSE_OVERSIGHT_012430

~0929104. TXT 42 3 4 Q. All right. Let's talk about what happened 5 after the massage was over. 6 A. Okay. 7 Q. After the massage you told Epstein that you 8 wanted to bring your twin sister back so she could make 9 some money, correct? 10 A. Incorrect. 11 Q. Your twin sister isi right? 12 A. Correct. 13 Q. And you love | very much, don’t you? 14 A. Yes. 15 Q. And when you left the house you were joking 16 with the other girls, weren't you? 17 A. Incorrect. 18 Q. Well, when and the other girl in the 19 car that day made their statements to the police they 20 told the police that you were joking afterwards. Are you 21 saying that they were lying to the police about that? 22 A. No. But a question or -- questions from 23 a -- like she asked me questions, but it wasn't 24 joking. She was kind of like in a happy way, like, "Oh, 25 what did you do? What did you do?” Like those kind of 43 —_ things, but it wasn't joking about it at all. 2 Q. You joked about it, didn't you? 3 A. No. 4 Q. You said to ME that if you did this Page 36 HOUSE_OVERSIGHT_012431

~0929104. TXT every weekend you'd be rich, didn't you? A. No. That's what i told me. Q. You didn’t tell that to MR. LEOPOLD: Objection. Asked and answered. THE WITNESS: No. BY MR. TEIN: 15 16 17 18 21 22 23 24 25 on ~~ Dn wo SF WwW DY A. Incorrect. 1 didn't spend any of the money. You went to Marshall's, didn't you? A. | went along, yes, but | didn't -- MR. LEOPOLD: Objection. THE WITNESS: | guess you could say that. MR. LEOPOLD: Objection. Lack of predicate and foundation. Mischaracterization of earlier testimony. 44 BY MR. TEIN: Q. and bought a purse, right? A. Yes. Q. And you were with her the whole time at Marshall's, correct? A. Yes. Q. Now tell me about when the federal prosecutors told you about getting reimbursed. Page 37 HOUSE_OVERSIGHT_012432

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 =— oO ODN Oo FPF WwW YN ~0929104. TXT A. | have no idea what you're talking about. Q. Tell me about when the federal prosecutors spoke to you about getting money you feel you're entitled to from Mr. Epstein. A. | don't know what you're talking about. Q. Do you know who Marie Villafona is? A. No, sir. Q. Did you ever meet with any federal prosecutors? A. | think -- yeah. | think they were -- | think they were like FBI. Q. Uh-huh. Did you meet with federal prosecutors? A. They came to my house one time, yes. Q When did they come to your house? A. Very long ago. Q Was it this year, 2008? 45 It was not this year, no. Was it 2007? I'd have to say at least two years ago or a year ago, yeah. So it would be 2007, 2006; but it was a while ago. Q. How many federal prosecutors or FB! agents came to your house? A. i'm trying to remember. 1 want to say four people came. Q. Did they give you their business cards? A. If they did, | don't remember, and they weren't toward me. Maybe my parents have them. | don't know. Page 38 HOUSE_OVERSIGHT_012433

14 15 16 17 18 19 20 21 22 23 24 25 J 0 Oo OD NN ODO oO BP W PDH ~0929104. TXT Did they give you their cell phone numbers? No. Did you ever speak to them on their cel | phones? A. No, sir. Did they speak to your parents? A. That's something you'd have to ask my parents. Q. Do you know whether they spoke to your parent's? A. No, sir. Q. You have no idea? 46 A. No, sir. MR. LEOPOLD: Objection. Asked and answered, BY MR. TEIN: Q. So if | say the name to you Marie Villafona, you don't know who that is? A. No, sir. Q. How many women and how many men came to your house? A. 1 want to say two ladies and two guys. Q. Did someone named Jeffrey Sloman come to your house? A. | don't Know names, sir. Q Do you Know who Jeffrey Sloman is? A. No, sir. Q Do you Know who Jeffrey Herman is? A Yes. Page 39 HOUSE_OVERSIGHT_012434

18 19 20 21 22 23 24 25 —_ So Oo ONY OO oO Be WwW LD ~0929104. TXT Q. That's the lawyer who first sued Epstein on your behalf, right? A. Yes. Q. Has Mr. Herman advanced your family any money? MR. LEOPOLD: Any conversations that you've had with Mr. Herman regarding that issue, you are not to disctose. If you've learned in some other 47 fashion, you may answer. THE WITNESS: Okay. | wouldn't Know. BY MR. TEIN: Q, You don't know? Bo No. MR. LEOPOLD: Objection. Foundation. Attorney/client privilege. BY MR. TEIN: Q. And you say you don't know who Jeff Sloman is? A. No, sir. Q. Does it refresh your recollection that he's the number two prosecutor at the U.S. Attorney's Office? A. No. Q. That he’s Marie Villafona's boss? A. No. Q. Does it refresh your memory that he's the ex-partner of Jeff Herman, the first lawyer who sued you -- sued Mr. Epstein on your behalf for fifty million dol lars? A. No. | don't know who he is. Page 40 HOUSE_OVERSIGHT_012435

23 24 25 —y oo ON ODO oN BRB Ww ND ~0929104. TXT Q. Without telling me any conversations that you've had with your lawyers, how is it that you selected Mr. Herman as your lawyer from the 81,000 members of the 48 Florida Bar? A. | did not select him. Q Who did? A My father. Q. Did you ever meet Mr. Herman? A Once. Q Don't -- don’t tel! me what you discussed with him. Where did you meet him? A. | was shopping in my -- he showed up at my friend's house. Whose house? my triend i is that iii + on Yes. And did you have a meeting with him at ‘s house? Yes. | guess you could say that. And who else was there? My Aunt And what was that meeting about? oD. = P MR. LEOPOLD: Objection. That calls for attorney/client privilege. BY MR. TEIN: Q. What discussions did you have with Page 41 HOUSE_OVERSIGHT_012436

= o Oo On DOD oO FPF WN 1 ~0929104. TXT 49 Mr. Herman in the presence of i: A. None. Q. What discussions did you have in the presence of her aunt? A. Of my aunt? MR. GOLDBERGER: It's the witness's aunt. BY MR. TEIN: Q. On, of your aunt. A. The only one that we've ever discussed or ever had. Q. And so you were in a conversation with Mr. Herman and your aunt? A. Yes, sir. Q. And you discussed privileged matters during that conversation? MR. LEOPOLD: Object to the form. | think you might have to educate her on that question. BY MR. TEIN: Q. You discussed the lawsuit? A. Yes. Q. Did TT te you about any conversations that she had with Mr. Herman? A. As far as |’m concerned, she's never spoken or she's never had a conversation. She only opened the door and then left. She's the one who answered the door. 50 Q. Why did the meeting take place at a 2 fF house? 3 4 A. | spent the night that night at her house. Q. And when was this? Page 42 HOUSE_OVERSIGHT_012437

non ~ Oo on fF WwW DN ~0929104. TXT A while ago. How long ago? A month and a half ago. !'m guessing. A month and a half ago? Uh-huh. = f - 2 - Q. Did you meet what an FBI agent named Nesbit Kirkendall, a woman? A. | don't know. Q. Did Ms. Kirkendall speak to you about getting reimbursed from Mr. Epstein? A. I’ve never had a discussion with anyone about getting reimbursed from Mr. Epstein. Q, Have you met with an agent named Jason Richards? A. Not to my knowledge. Q How about an agent named Tim Slater? A. No, sir. Q How about an agent named Junior Ortiz? 51 A. No. Q. And we've learned that many of the girls, some of whom are as old as 23, were told by the government that they would get money at the end of the criminal prosecution. Does that sound familiar to you? A. No, sir. Q. Other than Mr. Leopold here -- I'm not asking about Mr. Herman either -- Page 43 HOUSE_OVERSIGHT_012438

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 —_ oO Oo OA OD TO SF W DN ~0929104. TXT A. Uh-huh. Q. -- did anyone ever discuss with you that you could get reimbursement for your damages? A. No, sir. Q. Did you or any member -- MR. LEOPOLD: Are you referring to a criminal matter or a civil matter? BY MR. TEIN: Q. Did you or any member -- MR. LEOPOLD: Excuse me. Let me object to the form of the question. BY MR. TEIN: Q. Did you or any member of your family ever get a victim notification letter from anyone? A. | no longer live at that residence and | wouldn't know. Q. So your testimony is that you have never 52 received a victim notification letter, correct? A. Correct. Q. And your testimony is that you don't know if your parents have ever received a victim notification letter, correct? A. Correct. Q. Have you given any evidence to prosecutors or law enforcement in this case? A. What do you mean by evidence? Q. Well. Anything that you can touch or feel? A. No. MR. LEOPOLD: Objection to the form of the question. Page 44 HOUSE_OVERSIGHT_012439

14 15 16 17 18 19 20 21 22 23 24 25 —_t oo Oo ON OD oO Be Bw PY ~0929104. TXT BY MR. TEIN: Q. So you haven't given anything physical -- A. No. Q. -- any item to any prosecutor, police officer or law enforcement agent, correct? A. My cell phone four years ago or three years ago, but that's it. Q. You gave your cell phone to whom? A. Michelle Pagan. “ Q. Did she keep it? Avs Ask her. Q. You gave it to her and then you didn't get 53 it back at the end of the meeting? A. No. They -- yeah. No. They have it. I'm guessing. [| don't have it. Q. How much money are you hoping to get out of Mr. Epstein? MR. LEOPOLD: Objection to the form of the question. Attorney/client privilege. BY MR. TEIN: Q. How much money are you hoping to get, you, yourself, hoping to get out of Epstein? MR. LEOPOLD: Same. Same objection, attorney/client privilege. Don't answer the question. BY MR. TEIN: Q. I'm not asking about what your lawyer told you. MR. LEOPOLD: [t'm instructing her not to Page 45 HOUSE_OVERSIGHT_012440

18 19 20 21 22 23 24 25 —_ oro Oo Oa NN OD oO Fe WwW NY ~0929104. TXT answer the question, because any of those conversations involve her counsel. MR. TEIN: Certify that. MR. LEOPOLD: Please. BY MR. TEIN: Q. Now, Saige, you lied to get out of this deposition, didn't you? 54 A. No, sir. Q. You didn't want to come to court today and tell the story that you had told to the police under oath, did you? MR. LEOPOLD: Object to the form of the question. Lack of foundation, predicate. THE WITNESS: No. | have no problem coming here and talking to you. BY MR. TEIN: Q. And to avoid getting served with a lawful subpoena, you lied about your name, didn't you? A. No. Q. And in fact, just lying yourself wasn't enough, was it? MR. LEOPOLD: Objects to the form of the question. Don't answer it. It's not a question. Object to the form of the question. Lack of foundation. MR. TEIN: Are you instructing her not to answer? MR. LEOPOLD: | am. Page 46 HOUSE_OVERSIGHT_012441

yay 23 24 25 —_ oO Oo an Om ao FF WwW LD ~0929104. TXT MR. TEIN: Certify it. MR. LEOPOLD: Please. 55 BY MR. TEIN: Q. You asked your co-workers -- MR. LEOPOLD: [t's vague and ambiguous. BY MR. TEIN: Q. You asked your co-workers at the ae lie for you, didn't you? A. No. | informed my boss about what was going on and he told me that he would help in any way that he can. Q. Okay. You got your friend J to lic by switching name tags with you, correct? A. Incorrect. It was a coincidence that same night she was not wearing her name tag; she was wearing mine. But | was also not wearing -- | was wearing my name tag. Everyone switches name tags. It just so happens it was a coincidence that same night the people came with the papers. MR. TEIN: Will you put up Exhibit 18-001? MR. GOLDBERGER: And mark 18-001 for identification purposes to this deposition. MR. LEOPOLD: None of them have been marked yet. Can we mark them and put them as attachment to the depositions? Because | think you've shown three photos now. And this is the only one that Page 47 HOUSE_OVERSIGHT_012442

- Ww NWN BY MR. T BY MR. T up on th ~0929104.TXT 56 has been marked for identification yet. EIN: 0. i MR. LEOPOLD: Hold on just a second. Just so the record is clear -- MR. TEIN: I'm not speaking to you. MR. LEQPOLD: Okay. Then don't speak to me then. But |'!! speak to Mr. Goldberger, perhaps. But at least for the record, can we put on the record what the previous two photographs were marked for identification? MR. GOLDBERGER: We wil! make sure that the record is clear at the end of the deposition so that there's no ambiguity. MR. LEOPOLD: Thank you. EIN: Q. | |'ve put a photograph marked 18-001 e screen. Do you see that? A. Yup. Q Who is that in the photo? A on the left and me on the right. Q. right? A Yes. Q FY your friend at the that the subpoena 57 A. Yes. Q. Pe your friend, who you say the day process servers went to serve you with a for this deposition, just happened -- just by Page 48 HOUSE_OVERSIGHT_012443

os oO ~~ OM oO FF W DY ~0929104 . TXT coincidence, was wearing your name tag? A. Yes, sir. Q. And just by coincidence, you were wearing her name tag, correct? A. Yes. Q. Your testimony under oath is that's just a coincidence, right? | A. Total honesty. Q. lt just happens to be the day that you were going to be served with a subpoena, correct? A. That wasn't the first day that -- MR. LEOPOLD: Lo just answer the question. It calls for a yes or no. THE WITNESS: Yes. BY MR. TEIN: Q. 58 looking for you, didn't you? A. No. 1 knew -- MR. LEOPOLD: Just answer it. it calls for a yes or no. THE WITNESS: Okay. No. BY MR. TEIN: Q. Now you can explain the answer that your counsel! stopped you from explaining. Page 49 HOUSE_OVERSIGHT_012444

10 11 12 13 14 15 16 7 18 19 20 21 22 23 24 25 ay oO Oo OD NN OD oO PF WwW KN ~0929104. TXT A. Okay. ! work at MJ and people were telling me that people were looking for me. So yes, | was aware that people were searching for me, but | had no idea who they were or what their intentions were, but | thought they were just people | didn't want to talk to. So | just didn't want to talk to them. And every time they'd come to work | wasn’t there. And so happens the night that they came in me and my friend switched name tags. No big deal. Q. That's a tie, isn’t it? MR. LEOPOLD: Objection. Don't answer that question. That's harassment and | wil! not allow it. He could ask the questions and we'll allow a jury to make that determination, but not counsel. | will not allow her to answer that question. MR. TEIN: Certify it. 59 MR. LEOPOLD: I'Il certify it. She's answered that question. She's explained it five times already. The fact that Counsel doesn't jike the answer, that's a different query. MR. TEIN: Stop making speaking objections. MR. LEOPOLD: I'm not. I'm not going to put up with it, because it's in appropriate, Jack, and you know it. | will not allow Counsel to berate a witness, whether it's in a criminal case or a civil case, whether my client or -- MR. TEIN: Calm down. MR. LEOPOLD: Excuse me. Page 50 HOUSE_OVERSIGHT_012445

co™ 14 15 16 17 18 19 20 21 22 23 24 25 — oOo BOs Oo oO FP WwW DN ~0929104. TXT No, I’m not going to allow it. That is not proper. MR. GOLDBERGER: Okay. MR. LEOPOLD: If he wants to say that she's lying after asking it Five times and her explaining in great detail, he can do that. But |'m not going to allow her to answer, nor be harassed by him. It's improper. MR. GOLDBERGER: Okay. But your response that Counsel doesn't like the question -- or doesn't like the answer -- just let me finish. MR. LEOPOLD: Absolutely. 1! wasn't going 60 to interrupt you. MR. GOLDBERGER: Just requires us to say we like the answer to that question. And it’s not you and | or you and Mr. Tein who are testifying here. It's the witness. MR. LEOPOLD: Fine. But after the sixth time of asking the same question and then coming back and pointing a finger at her and saying, you're a liar -- MR. TEIN: That didn't happen. MR. LEOPOLD: That's fine. But I'm not going to allow her to answer that question because she's answered that same question and has explained it. Now Counsel might be sitting there rubbing his head with a migraine. That's his problem. But if he can't ask a question appropriately in a Page 51 HOUSE_OVERSIGHT_012446

18 19 20 21 22 23 24 25 —_ oOo ON OD oH eR Ww NY ; ~0929104. TXT professional manner, we will leave. [| will not allow her to be berated like that. MR. GOLDBERGER: Actually, we're very happy with the answer. MR. LEOPOLD: That's great. MR. GOLDBERGER: Do you want us to get into that? MR. TEIN: Ted -- 61 MR. LEOPOLD: This is really big stuff that you're going through, but that's fine; just ask your question and move on. But do it one time. If you don't understand it, I'll let you fotlow up, but |'m not going to allow you to ask the same question the time and again and then call her a liar. Just ask the question, get the answer and move to the next subject matter. MR. TEIN: Ted, I'm sitting right across the table from you. MR. LEOPOLD: Yes, sir. MR. TEIN: Please be quiet. Don't yell. MR. LEOPOLD: { will not be quiet. MR. TEIN: Stop yelling. MR. LEOPOLD: Lewis, when I'm yelling you'll know it. | will not -- MR. TEIN: My name is not Lewis. MR. LEOPOLD: | thought your first name was Lewis, Mr. Tein. MR. TEIN: You watched me for three days at the evidentiary hearing where you sat in the back of the courtroom. You should know who | am. Page 52 HOUSE_OVERSIGHT_012447

23 24 25 — oO Oo 8B NN DO oO PP & NG ~0929104. TXT MR. LEOPOLD: Well, that's the impression you must have made in the courtroom. | will not be quiet. 62 MR. TEIN: That's obnoxious. Stop being obnoxious. It's stupid. Let's go ahead with the questions. MR. LEOPOLD: { will make the record. MR. TEIN: Let's get on with the questions. MR. LEOPOLD: Do you need a break? (Thereupon, a recess was taken.) BY MR. TEIN: Q. Okay. P| after you told your manager at the [EE everything that was going on and he told you he would help you any way he could, he hid you in the kitchen from the process servers, correct? A. Incorrect. Q. isn't it true that lying to avoid service is a meaningless lie to you A. Incorrect. Q. What is your manager's name? A. 1 have three. Would you like to know all -- Q. Who's the one who Jied for you? A. Justin. Q. And what did Justin do to lie for you? A. Said | wasn't there. Q. And who did he tell wasn't there? A. Ask him. Page 53 HOUSE_OVERSIGHT_012448

dt oo A NN OD oO BR WwW NN - WwW NW ~0929104. TXT 63 Q. Where were you when Justin told this someone that you were not at the ee: A. Eating nachos. A. Yes. Q. What did you do so that Justin would lie to the process servers for you? A. Nothing. Q. You just got him to lie for you, didn't you? A. No. | had no influence on him saying | wasn't there. Q. He took that upon himself? Isn't it true that Mr. Epstein's process servers had to ask the police to get you out of the restaurant so that they could serve you? MR. LEOPOLD: Objection. Lack of foundation, predicate. BY MR. TEIN: Q. You can answer the question. MR. LEOPOLD: If you Know. Don't guess. THE WITNESS: No. Can you repeat the question? MR. TEIN: Don't coach. MR. LEQPOLD: Don’t guess. 64 MR. TEIN: That's a coaching. MR. LEOPOLD: No. That's an instruction to the client. MR. TEIN: No. You don't do that. Page 54 HOUSE_OVERSIGHT_012449

— on Oo TO B&B WwW DN ~0929104.TXT THE WITNESS: Can you repeat the question? MR. LEOPOLD: Let me just state for the record -- BY MR. TEIN: Q. Once the police -- isn't it true that Mr. Epstein's process serves had to ask the police to get you out of the restaurant so that they could serve you? A. Incorrect. My boss called the police. Q. And once the police showed up, to stop you from lying to avoid service, you made up another lie that the process servers had harassed you. t[sn't that correct? A. Incorrect. You lie all the time, don't you? MR. LEOPOLD: Objection. THE WITNESS: Incorrect. BY MR. TEIN: Q. You have a MySpace page, don't you? A. No longer do | have a MySpace page. | deleted it. . Q. When did you delete your MySpace page? 65 A. A couple days ago. Q. Who told you to take your MySpace page down a couple of days ago? A, Nobody. I'm sick and tired of MySpace. Q. You all of a sudden got sick and tired of MySpace and just a few days before this deposition you decided to delete your MySpace page, correct? A. Correct. Page 55 HOUSE_OVERSIGHT_012450

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 —_ oo Oo ON OF OH FPF WwW DN ~0929104. TXT Q. Is that your testimony under oath? A. Yes. Q. Did you take your MySpace page down because you thought the government might subpoena it? A. Incorrect. Q. Hadn't your MySpace page been up for over three months before you took it down? A. Correct. But | also had made tons of MySpaces over the last years. | just get tired of them and delete them because drama and make new ones. Q. We're going to talk about that. So you deleted your MySpace page after you were already under subpoena for this deposition, correct? A. Correct. Q. What about the MySpace page didn't you want us to see, pg A. Nothing. 66 Q. Well, we're going to come back to MySpace in a second. A. You do that. Q. | | I'm going to ask you some questions about why you lie about your age so often, okay? MR. LEOPOLD: Objection to the form. Argumentative. BY MR. TEIN: Q. You lie about your age all the time, don't you? MR. LEOPOLD: Objection, argumentative. THE WITNESS: Incorrect. BY MR. TEIN: Page 56 HOUSE_OVERSIGHT_012451

: a 14 15 16 17 18 19 20 21 22 23 24 25 _ Co Oo BS OO ee WwW LD ~0929104. TXT Q. You lie about your age to get body piercings, don't you? A. Incorrect. Q You have body piercings, don't you? A. Yes. Q You have four body piercings; isn't that right? A. Five. Q. Other than the pierceings on your ears -- I'm not talking about that -- A. Oh, then no; just one. Q. And where is the one body piercing? 67 Belly. When did you get that? For my birthday, with my stepmother and my father. Q. And when was that? A. When | was 14. Q. Okay. So you had that body piercing when you met Epstein, correct? A. It might have been, or maybe that -- yeah, either my 14th birthday or my 15th. | honestly don't remember . Q. Now you've lied about your age to get into bars by using driver's licenses that aren't yours, correct? A. Incorrect. Q. Are you swearing under oath that you've never done that? Page 57 HOUSE_OVERSIGHT_012452

18 19 20 21 22 23 24 25 —_ oO 8 OD SD HO BF WwW DN ~0929104. TXT A. Yes, | swear under oath. Q. And you've lied about your age to buy beer, correct? A. Incorrect. Q. You're swearing under oath that you've never lied to stores about your age? A. I've never lied to a store about my age or anything. 68 Q. You try to look much older than you are, don't you? A. Incorrect. Q. And you've lied about your age on your MySpace pages, don't you? A. Incorrect. Q. All right. Let's look at Exhibit 26-01 one. MS. BELOHLAVEK: 26-0017? MR. TEIN: Yes. BY MR. TEIN: Q. Let's go to Exhibit 33. MS. BELOHLAVEK: That's 33-001? TEIN: Correct. BY MR. TEIN: Q. On this page you lied to everyone that you were 19, didn't you? A. Incorrect. MR. LEOPOLD: Just answer the question. Page 58 HOUSE_OVERSIGHT_012453

23 24 25 — oO oO BAN Oo on FF WwW LD ~0929104. TXT THE WITNESS: Oh, incorrect. BY MR. TEIN: Q. Now you can explain your answer. 69 A. | Know that | have seen all of these and | Know that this one is mine. Can you go down? MR. LEOPOLD: Just for the record, you're pointing to the photo. THE WITNESS: I'm pointing to -- BY MR. TEIN: Q. That's yours, right? A. Correct. That's mine from a couple years ago that | have not been on base | don't use that. Please keep going down, please. And | think that's it, because there's no one -- just that one is mine. Q. And when you wrote 18 as your age on your MySpace page, that was a lie, wouldn't it? A. Correct. Q. Did you lie about your MySpace page back then because you couldn't post on MySpace unless you were 18? A. Correct. There was a rule many years ago Page 59 HOUSE_OVERSIGHT_012454

— 14 15 16 17 18 19 20 21 22 23 24 25 —_ &- WwW DY ~0929104 . TXT 70 that you had to be 18 to have a MySpace. Q. So you lied about your age so you could post on MySpace, right? A. Yes. Q. Let's go back to the top one on this page, 33-01. Q. Now let's go back to the one that you were pointing to before on this page, where it says your age is 18 and you lied about your age to post MySpace, okay? A. Uh-huh, yes. Q. Atl right. Why did you finally put your true age on your MySpace profile four days before you MR. LEOPOLD: If you don't understand, ask him to ask the question again. MR. TEIN: Don't coach. THE WITNESS: | don’t know which MySpace 71 you're talking about. BY MR. TEIN: Q. The MySpace page that you're just pointing to, where it says you were 18. Page 60 HOUSE_OVERSIGHT_012455

Oo ~~ Dm oO FP WwW DN ~0929104. TXT A. Yes. Q. Why did you finally post your true age on your MySpace profile -- A. Uh -- Q. -- four days before you were scheduled to testify before the Grand Jury? A. | honestly don't know which MySpace, because I've had like a bazillion MySpaces and in that year, | had two, that one and another one and that one's been deleted. So | don't know which one you're referring to. A. No. Q. You don't remember that. A. No. Q. Do you remember Detective Recarey? Did you ever meet a Detective Recarey? 72 As, | don't know the names. Q. How many different detectives have you met with on this case from Palm Beach? A. Probably a good six or seven, maybe. Q. Did one of the detectives tell you before you testified in the Grand Jury that you should take your MySpace age and put your true age? A. No. Page 61 HOUSE_OVERSIGHT_012456

10 17 12 13 14 15 16 17 18 19 20 21 22 23 24 25 om oO On OD TO BP W PD 12 13 ~0929104. TXT Q. Didn't Detective Recarey have to come to your house to pick you up to get you to testify in front of the Grand Jury? A. Possibly, maybe because | didn't have a ride. | was only 14 or 15 at the time. Q. Your mom didn't drive you? A. No. Q. Stepmom didn't drive you? A. | think my dad. Oh, my dad / my dad drove me. Q. Your dad drove you? A. Yes, sir. Q. So your testimony is Detective Recarey did not drive you, correct? MR. LEOPOLD: Objection /asked and answered. THE WITNESS: No. I'm pretty sure my dad 73 drove me because he was there with me. BY MR. TEIN: Q. Did any detective tell you to change your age on your MySpace page to put your true age? A. No, sir. Q. Now you also lied on your MySpace page about your income, didn't you? As Yes. Q. That was a lie, wasn't it? Yes. Page 62 HOUSE_OVERSIGHT_012457

a 14 15 16 17 18 19 20 21 22 23 24 25 “ oOo ON ODO oO PF WwW NH ~0929104. TXT Q. Now you also tie to the police, don't you? A. No. Q. Well, you lied to the police in your tape-recorded statement that you gave to Detective Michelle Pagan three years ago, didn't you? A. To my knowledge, no, | did not. Q. Well, you lied to the police when you accused Mr. Epstein of attempting to murder your father, 74 didn't you? A. No. 1 never heard a statement saying that Mr. Epstein tried to murder my father. Q, You made that statement, didn't you? MR. LEOPOLD: Do you have a statement to show her? That's been asked and answered. MR. TEIN: I'm sorry. | didn't hear the witness’ answer, Mr. Leopold. BY MR. TEIN: Q. | | you told the police, didn't you, that Mr. Epstein almost killed your father, didn't you? A. No. | Q. Three years ago, before Mr. Epstein even Knew about this investigation, you told the police that Epstein had “already come to my dad's house and did something to my dad's tires and my dad almost died. | didn't want my dad to get hurt, because Jeff already Page 63 HOUSE_OVERSIGHT_012458

18 19 20 21 22 23 24 25 —_ oO Oo Oa 4 OD oO fF WO NWN ~0929104.TXT almost killed him." Didn't you say that? A. Not to my knowledge or recollection. | have never said anything !ike that. A. Yeah. Q. Because Mr. Epstein never came to your 75 dad's house, correct? A. Correct. Q. And no one who worked for Mr. Epstein ever did something to your dad's tires. Did they? MR. LEOPOLD: Objection. Lack of foundation, predicate. Don't guess. BY MR. TEIN: Q. It's not true that Mr. Epstein almost killed your father, is it? MR. LEOPOLD: Objection. Asked and answered, lack of foundation, predicate. BY MR. TEIN: Q. You can answer. A. No. Q. Now you told the police that you didn't know who was in the car with you and Hayley on the day you went to Epstein's house, didn't you? Yes. And that was a lie, wasn't it? It's the truth. o> 2 > You told the police that there was someone Page 64 HOUSE_OVERSIGHT_012459

23 24 25 —_- oOo Os DOD oO FR WwW DN ~0929104. TXT in the car next to you and you specifically said you didn't know her name, right? A. Correct. | do not know her name. 76 Q. You said, “I don’t know her name, but she was dark like a Spanish girl." Those were your words, right? A. Yes. MR. LEOPOLD: Objection. Asked and answered. BY MR. TEIN: Q. Who was in the car that day with you and a A. Again, |t do not know. Q. It was your good friend i . wasn't it? A. No. 1 don't know a x. Q. You [ied to the police about who was in the car with you and | | didn't you? A. Incorrect. Q. Let. me ask you some questions about who you may have spoken to about this case. All right? A. Go ahead. Q. Did you speak to your I sister A. Not in detail, but of course she knows; she's family and yes. Q. What's her e-mail? A. | don't think she has an e-mail. Q. What is her phone number? Page 65 HOUSE_OVERSIGHT_012460

aa kt - WwW DY ~0929104. TXT 77 A. Oh, gosh. | don't know off the top of my head. Q. And what is her home address? ie She lives with my mom. Q. In Georgta? A. Yes, Sir. Q. What about is boy friend Paul? Did you speak to him about Epstein's case? A. That's my mom's boy friend. My sister doesn't have a boy friend. My mom's husband's name is Paul, so maybe you get them confused. Q. Do you know his phone number? A. No. Q. Where does he live? A. With my mom. Q. In the same house with her? A. Yes. They're married. Q. So not boy friend; husband? A. Yeah, husband. Q. Have you spoken to prect [i about what happened in Mr. Epstein's house? A. Not in detail, but he knows the basics, yes. What is his e-mail? | don’t know. 78 Q. What is his phone number? A. How is that relevant? Q. What is his phone number? A. Page 66 HOUSE_OVERSIGHT_012461

~~ porn ~0929104. TXT 5 Q. What is his home address? 6 A. | don't know. 7 Q. Where does he live? 8 A. in EE somewhere. 9 Q. Ever been to his house? 10 A. Yes. 11 Q. You don't know what his address is? 12 MR. LEOPOLD: Objection. Asked and 13 answered. She just said she doesn't know. 14 MR. TEIN: Don't coach. 15 MR. LEOPOLD: Objection. Asked and 16 answered. 17 BY MR. TEIN: 18 Q. You can answer the question. 19 A | don't Know the exact address. 20 Q. What street is it on? 21 A It'S an apartment complex; its not a 22 street. 23 Q. What's the name of the apartment complex? 25 Q. What apartment number is it? 79 1 A. 1} couldn't tell you. 2 Q. When was the last time you went there? 3 A. Just visited this past weekend. That's the 4 first and fast time | went there. 5 Q. How about steven IP Have you spoken 6 to him about your case? 7 A. No. We no longer speak. 8 Q. What's his phone number? Actually, we Page 67 HOUSE_OVERSIGHT_012462

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 — oO OD NN TD oO FP WwW NY ~0929104.TXT already have his phone number room and e-mail. How about ee: Have you ever spoken to her about your case? A. ! don't know an FY Q. Have you ever met ae: A. No. But just to let you know, | don't really know names. If you have pictures, of there faces |} could tell you. Q. All right. Let me see if | can refresh your memory. A. Okay. Q. Does it refresh your memory that Is the other gir! who made allegations about Epstein, but refused to show to the Grand Jury when she had to testify about them under oath? A. No, sir. 1 have no knowledge of any other girls in this whole situation. We're not allowed to know 80 each other. Q. And what about a: Have you of met her? A. No, sir. Q. Let's see if | can refresh your memory on her. She's the other person represented by your lawyer Mr. Herman, who is suing Epstein for fifty million dollars. A. | have no knowledge of her. Never met her? Never met her. Page 68 HOUSE_OVERSIGHT_012463

— 14 15 16 17 18 19 21 22 23 24 25 —_ oo oO ON OO Fe WwW | Q. A. Q. ~0929104. TXT vony | don't know who that is either. A person named Anthony who knows SP Is that Tony i? A. | don't know, sir. Q. Do you remember making a statement to ' Detective Pagan that’s in the police reports? A. No. Q. Have you read the police reports in this case? A. Yes. Q. They're on the Internet, right? 81 A. Yes, | think. Q. You didn't want to see that happen, right? No. So you're saying you don't know a Tony MR. LEOPOLD: Objection. Asked and answered. BY MR. TEIN: Q. Does it refresh your memory that he was somebody who had gone to jail for drugs and car theft? A. No, sir. Q. Someone who knows a? No. Page 69 HOUSE_OVERSIGHT_012464

18 19 20 21 22 23 24 25 —_ oO © © Ns DMD oH & WwW DN ~0929104. TXT Q. You don't know if he met with Detective Recarey? A No, sir. Q How about Zack A. Yes, | remember. | know who that is. Q Did you ever speak to Zack J about what happened at Mr. Epstein’s house? A. He Knows what happened four years ago. He 82 doesn't know this is still going on today. Q. What's his address? I'm sorry. 1 have his address. A. | don't Know. Q. How about Nick a: Q. You know who that is? A. | know who that is, yes. Q. He's the one you stayed out drinking al! night one night last year when your dad reported you missing? A. No, sir. Q. Remember the baseball! game you were supposed to go to? A. No, sir. Q. Did you speak to Nick MM about this case? No, sir. How about Patrick | lg That's my sister's ex-boy friend. PF Go He's the one with the sawed-off shotgun with the obliterated serial number? Page 70 HOUSE_OVERSIGHT_012465

23 24 25 —_ oo Oo OWN ODO OH BR WwW DY 22 23 24 25 A. information. Q. case? A. Q. case? A. Q. A. Q. to who he is. A. Q. your father? A. Q. A. ~0929104. TXT Ask him. | would not know that Did you speak to Patrick PE abou this 83 No, sir. Have you spoken to John P| about this No. | don't know who John is. Did your parents speak to John Ask my parents. Let's see if | can refresh your memory as Okay? Uh-huh. How much money did John Connolly give to | don't even know he gave money to my dad. I'm sorry? | didn't even Know he gave money to my dad. Page 71 HOUSE_OVERSIGHT_012466

—_ oo © ONY DO oO FPF WD > WwW DN ~0929104 . TXT 84 Q. What do you know about the dea! that John Connolly has with your father? A. | only know they spoke on the telephone once. | don't know anything else. Q. When was that? A. This was a while ago, a year or two or a year ago. 1 honestly don't know. Q. Did John Connolly the Vanity Fair reporter offer any money to your father? A. i don't know. Q. Did John Connolly, the Vanity Fair reporter, give you any money? A. No, sir. Q Did he offer you any money? A No, sir. Never spoke to him. Q. What reporters have you spoken to? A Zero. Q. What about your fem Iy members? What reporters have they spoken to? A. The whole Palm Beach County, obviously, as you can see in that newspaper. Q. Tell me -- let's go through each one that you remember. OQther than the Vanity Fair reporter, John Connolly, what other reporters have any member of your family spoken to? 85 A. i don't know. And | know my mom has spoken to zero. My sister spoke to zero. My father and stepmother, | wouldn't know. You'd have to ask them. | don't contact them. Page 72 HOUSE_OVERSIGHT_012467

a ao nt fm oO fF WwW DN ~0929104. TXT Q. Well, | just want to know -- | don't want you to -- | want to know what's in your mind? AIl right? MR. LEOPOLD: She just told you. She just answered -- MR. TEIN: Be quiet. BY MR. TEIN: Q. What | want to know is what you know from your personal knowledge. My opinion question to you is: What knowledge do you have about family members of yours speaking to reporters? MR. LEOPOLD: Objection. Asked and answered. And if you can't talk professionally, we're going to leave. MR. TEIN: Do what you want to do. MR. LEOPOLD: Are you going to continue to talk this way? MR. TEIN: I'm not going to answer any question that you ask me, Mr. Leopold. MR. LEOPOLD: Okay. MR. TEIN: But you are misrepresenting the 86 record and you are grandstanding for your client and it's wrong. So be quiet. And you know how to make an objection. Make it. Otherwise stop talking. BY MR. TEIN: Q. Saige -- MR. LEOPOLD: €&xcuse me. MR TEIN: If you want to leave the Page 73 HOUSE_OVERSIGHT_012468

c™ 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 oy oOo ON OF ON Rh WwW DN ~0929104. TXT deposition, leave. But you'l| be back here. MR. LEOPOLD: Excuse me. if | could just make the record, instead of interrupting me, please, that's what we do professionally. There's a recorder here. I|'m certainly not being obstructionist. I|'m going to make the record. But we're going to act with some semblance of professionalism, hopefully, by all parties in the room. That goes to me, that goes to your co-counsel sitting behind you and next to you, the court reporter and everyone else in the room. Everyone goes entitled to that. You've asked a question. She answered the question fully and she's not going to be harassed because you don't like the answer. If you want to follow up -- MR. TEIN: Stop engaging me. Make your 87 speech and then we'!l! ask the questions. MR. LEOPOLD: Well, you won't let me finish making the objection, so it's difficult to do that. But if you want to follow with an appropriate question, feel free to do that. But we're not going to harass the witness. MR. TEIN: 1 disagree with everything you've said. Let's ask the questions. Okay? MR. LEOPOLD: Ask an appropriate question. MR. TEIN: Are you going to stop talking? MR. LEOPOLD: I'm going to make -- protect my client and make appropriate objection, but there's not a question pending right now. Page 74 HOUSE_OVERSIGHT_012469

aoo™ 14 15 16 17 18 19 20 21 22 23 24 25 son oO Oo ON TD oO FP WwW DY ~0929104. TXT BY MR. TEIN: Q, a has spoken to any reporters? A. No, MR. LEOPOLD: Objection. Asked and answered. BY MR. TEIN: Q. Has MB ocon given money by any reporters? A. No. Q. Has your mom spoken to any reporters? MR. LEOPOLD: Objection. Asked and answered. 88 THE WITNESS: No. BY MR. TEIN: Q. Has your mom's husband Paul spoken to any reporters? A, No. Q. Has your mom's husband Paul received any money from reporters? A. No. Q. Are you sure you don't know a: MR. LEOPOLD: Objection. Asked and answered. THE WITNESS: I'm positive. BY MR. TEIN: Q. I’ ll try again to refresh your memory. A. Okay. Q. Does it refresh your memory that she had been arrested for drugs and was cooperating with Page 75 HOUSE_OVERSIGHT_012470

18 19 20 21 22 23 24 25 ad oO Oo Os DMD oO BR WwW DY ~0929104. TXT Detective Recarey against Epstein to get herself a better deal? A. No. | don't know who she is. Q. Have you spoken to anyone else who's been at Epstein's house? A. No. Q. Without telling me what was said -- ! don't want to Know about any conversations with any lawyers, 89 okay -- A. Uh-huh. Q. -- did you or your parents speak to any other law firms besides Mr. Herman and Mr. Leopold's law Firms? No. Q. Now without telling me about anything that was said, what -- did one just come to mind? A, No. | was thinking about something else. Q. What were you thinking about? A. Does family court matter? Q. Okay. Without telling me what was said, who prepared you for todays deposition? A. What do you mean prepared? Q. Did you talk about this deposition, about what would happen, with anybody? A, Yes. Q Don't tell me what was said? A. Okay. Q I'm not asking that. | don't want to know that. A. Okay. Page 76 HOUSE_OVERSIGHT_012471

23 24 25 — oo 8B 4 TO NO RF WwW PD A. Q. ~0929104 . TXT Who prepared you for today's deposition? Mr. Leopold. Anybody else? 90 No. When did you meet with Mr. Leopold to prepare for today's deposition? A. Q A. Q This morning. And how long did that meeting last? Until it started. Now you told me that you previously had read the police reports in this case? A. Q. Yes. Have you read your statement that you gave to the police? A. Q. A. Q. transcript? A. Q. it. A police A. Q. A. ago. Yes, sir. And in what form was that statement? What do you mean? Was it in the form of a police report or a What's the difference? A transcript has questions and answers on report is just typed out narrative. Oh, it's a police report. And when did you read the police report? A few days ago. | overread it a few days Had you read it before that? No. Page 77 HOUSE_OVERSIGHT_012472

— oo Oo OD NY OD oH BF WwW —_ > W DY ~0929104. TXT 91 Q. Now you told me -- again, | don't want to know what was said. A. Uh-huh. Q. You told me that you met with Mr. Leopold this morning to prepare for your deposition, right? A. Yes. Q. When did you set up that meeting with Mr. Leopold to take place this morning? A. Gee, like, like five days ago, four days ago. Q. So you're aware that Mr. Leopold told us that he could not start the deposition this morning because he had a court appearance, correct? MR. LEOPOLD: Don't answer that question. Calls for attorney/client communications. BY MR. TEIN: Q. Have you seen the letter that Mr. Leopold wrote to us stating that he -- an e-mail that Mr. Leopold wrote to Mr. Goldberger stating that he could not be here this morning because healed a court appearance? Did you see that e-mail? MR. LEOPOLD: You can answer that question. THE WITNESS: No. BY MR. TEIN: Q. Have you listened to your tape-recorded 92 statement to the police? A. Yes. Q. Where did you listen to that? A. In, | think, this building. 1 don't know. Page 78 HOUSE_OVERSIGHT_012473

ao 4s DO oO FF WwW ND ~0929104. TXT It was here. Q. When did you listen to that statement? A. This morning. Q. And who was present when you |istened to that statement? A. Mr. Leopold -- and | forget your name. MR. GOLDBERGER: Ms. Belohlavek. THE WITNESS: Ms. Belohlavek. BY MR. TEIN: Q. And you hadn't listened to your statement before that, correct? A. No, str. Q. Have you met with lawyers representing anyone else suing Epstein? A. No, sir. Q. When was the last time you spoke with officers of the Palm Beach Police Department? 93 A. A while ago. I'd say a year ago. Q. A year ago? A. Yeah. Maybe a year and a half. Q. Do you remember Detective Recarey? A. No. Q. Do you remember Michelle Pagan, Detective Pagan? A. Yes. Page 79 HOUSE_OVERSIGHT_012474

(~~ 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 oO Oo Os OD OH BF WwW DY ee or | wo NO = ~0929104. TXT Q. How many times have you spoken to Detective Pagan? A. She was the only one | spoke to about this until for some reason she wasn't on the case anymore. Q. When was that? A. The first meeting | ever had was with her and then | think like |! met with her And who was that? | don't remember. Q. And what type of questions did they ask you? A. The same, Q. The same questions all over again? A. Basically. Q. How many taped statements have you given to 94 the police? A. One that | know of. Q. Just the one with Detective Pagan? A. Yes, sir. Q. How about to the FBI? Did you give any statements to them? A. No. Well, actually. 1 don't really remember if that was taped or not to be honest with you. | had one meeting with them at my house and don't know if it was taped. Q. You were interviewed at Po house? A. No. That was by the lawyer. Page 80 HOUSE_OVERSIGHT_012475

14 15 16 7 18 19 20 21 22 23 24 25 —_ oo On ODO om PB we PY 17 ~0929104.TXT Q. Oh, boy the lawyer? A. Uh-huh. Q. Where did the conversation that you had with the FBI take place? At my father's residence. Which is where? On Downers in Loxahatchee. On where? Downers Road in Loxahatchee. - Fr FP And when did that take place? A. ['d have to say like a year and a half ago, a year ago. It was a long time ago. 95 (Discussion held off the record.) MR. TEIN: Tell me the last answer, please. (Thereupon, a portion of the record was read by the reporter.) BY MR. TEIN: Q. And who was present when the FBI spoke to you at your father's house? A. My stepmother was there, but she wasn't around. She made herself like do other things. Q. And how many FB! agents were there? A. ! think four. Q. And you don't remember any of their names? A. No, sir. Q, And were there any lawyers there? A. Not that I know of. Q. And none of them gave you their cel! phone numbers? Page 81 HOUSE_OVERSIGHT_012476

om 18 19 20 24 22 23 24 25 —_ oo Oo OND OH Rh WwW NY ~0929104. TXT A. lt was a while ago. MR. LEOPOLD: Objection. Asked and answered. BY MR. TEIN: Q. And the last time you spoke to the federal 96 prosecutor's office was when? A. | don't know. Q. Did any of the FBI agents tell you that Marie Villafona had spoken with Mr. Leopold? A. No. Q. Did any of the FBI agents tell you that Marie Villafona had spoken with Mr. Herman? A. No. Q. Did any FBI agents tell you that Jeff Sloman spoke with Mr. Herman. A. No. Q. Did any FBI agents tell you that Jeff Sloman spoke with Mr. Leopold? A. No. Q. Do you know whether any of the federal prosecutors allowed Mr. Herman to review a draft indictment? A. i wouldn't know. Q. Da you know if any of the federal prosecutors discussed a draft indictment with Mr. Herman? A. f wouldn't know. Q. Have you ever e-mailed with any FBI agent Page 82 HOUSE_OVERSIGHT_012477

23 24 25 7 oO OD SN OO FF WwW DH ~0929104 . TXT or any federal prosecutor? A. No. Q. Have you ever text messaged with any FBI 97 agent or any federal prosecutor? A. No. Q. Has the FBI told you about other testimony? A. No. Q. Has the FBI told you about what other girls have said? A, No. Q. Have federal prosecutors told you what other girls have said? A. No. Q. Do you have any way of getting in touch with the FBI tf you wanted to get in touch with them? A. No. Q. How about your parents? Do they know how to get in touch with the FBI? A. } don't know. Q. And by your parents, I'm referring to both sets, okay? A. Oh. Well, I'm referring to only my dad, because my mom really doesn’t care to know any of this stuff. Q. So the answer would be the same for your mom and Paul? A. Yeah. —~ Q. Have you spoken to a lawyer named Burt Page 83 HOUSE_OVERSIGHT_012478

— oc Oo OWN DO Be Ww NY b&b W DY ~0929104. TXT 98 Ocariz about this case? A. No. Q. Do you know who Burt Ocariz is? Let's see if | can refresh your memory. Does it refresh your memory that he's a good friend of Marie Villafona's boyfriend? A. | don't know who Mari Villafona is. Q. Marie Villafona is the lead federal prosecutor that's on the federal part of this case. Okay? A. No. Q. So does it refresh your memory that Ocariz is the good friend of Marie Villafona's boy friend? A, Not at all. Q. Does it refresh your memory that Villafona tried to get Epstein to pay for Ocariz to represent you in the federal case? A. No. Q. Do you know if Detective Recarey has spoken with your father? A. No. Q. Do you know if Detective Recarey has spoken to your stepmother? A. No. Q. How about with amber? 99 A. Yes, | would know, and no, she did not. Q. Let's put up -- let me ask you some questions about the photo that you had posted on your MySpace page before you erased it last week. Okay? Page 84 HOUSE_OVERSIGHT_012479

—_ on OD ao FB W DY ~0929104. TXT A. Okay. MR. TEIN: Do you mind if we close the door a second, please. MR. LEOPOLD: Exhibit number, please. MR. TEIN: Put up 25-005. Hold on a second. MR. LEOPOLD: Don’t say anything. She was talking to her counsel. MR. TEIN: Put up 25-006. MR. LEOPOLD: Is that 005 right there? MR. TEIN: Yes. BY MR. TEIN: MR. LEOPOLD: Objection. Mischaracterizes the photograph, and lack of foundation and predicate. Fully explain if you need to. THE WITNESS: | will. First of all. 100 Second of all, I’m not being gang-raped. Everyone has their clothing on. Thirdly, if you look at all the other pictures in this album, |'m drinking -- what's when you're sick you drink it? BY MR. TEIN: Q. You can't ask questions of your counsel. A. All right. -'m drinking Tike Sprite. t'm Page 85 HOUSE_OVERSIGHT_012480

om 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 oO Oo oO 4 TO OH FPF WwW DY —_— tk —_ 12 13 ; ~0929104.TXT note drinking any kind of alcohol, if you would lIaok at my other pictures in that album. You guys picked the possibly worst pictures out of there to present. And it was just a goofy picture. All of these kids like to be goofy. And that's what we were doing. Q. Who's the man on the left of the picture holding his -- holding a beer bottle as if it were a penis towards your mouth? A. Steven a. Q. Who's the man behind you, right up towards your backs side, with you bent over? A. That one? Q. The right side, kissing with his mouth. A. That's Nick SD Q. He's the one grabbing towards the groin area of Steven | A. Yes. 101 Q. And there's three other men in the photo. What are their names? The one on the left with the hat? A. That's Robbie P| (phonetic) . Q. Smiling? A. Yes. Q. Who's the one kissing -- MR. LEOPOLD: Don't interrupt. Let her finish the record. She's testifying. MR. TEIN: § Know you don't like this picture, my friend. MR. LEOPOLD: The picture is fine. BY MR. TEIN: Q. Who's the one with the hat? Page 86 HOUSE_OVERSIGHT_012481

fo ™ 14 15 16 7 18 19 20 21 22 23 24 25 wood oO on OO Fe WwW LH ~0929104.TXT MR. LEOPOLD: No. Hold on. Stop, iia You have to let the witness finish her answer. She was in the process of explaining and you cut her off. Please finish what you were saying and then Counsel can ask you whatever he wishes after that. THE WITNESS: Okay. This guy -- MR. LEOPOLD: Just make it so the record is clear who you're referring to. THE WITNESS: -- on the far left is John BY MR. TEIN: 102 Q. He's the one whose head is near the groin of Steven a, right? A. Yes. Q. And in the middle there's a man smiling. Who's that? A. That's Robbie nn Q. Who's the one in the red hat, kissing? A. Most Brandon | (phonetic). Q. Let me stop you for a second. Are you done? A. Yes, I'm done. Q. who is iP A. My sister's friend. Well, she’s a mutual friend, but more my sister's. Q. What is her last name? . Q. Spell that. Page 87 HOUSE_OVERSIGHT_012482

a, ‘. 18 19 20 21 22 23 24 25 —_ oo 0 Oo NY ODO oO eB Ww > Oo > o> ~0929104. TXT | don't know how to -- Have you spoken to her about this case? No. Who's Vince? My sister's friend. | don't really speak to him at all. case? What's his last name? 103 And have you spoken to Vince about this No, sir. Have you spoken to a about this case? Not in detail, but yes. MS. BELOHLAVEK: Are we referring to BY MR. TEIN: ca) SP > P+ o> DO > THE WITNESS: Yes. MR. TEIN: Yes. MS. BELOHLAVEK: Okay. Have you spoken to Justin about this case? Justin? Do you have a friend named Justin? | do not have a friend named Justin. From freshman year? No. How about |g No. Have you spoken to || about this case? Page 88 HOUSE_OVERSIGHT_012483

f—™ ~0929104. TXT 23 A. No. 24 Q. What's her last name? 25 A. a. | don't Know how to spell it? 104 1 Q. is she the person whose house you went to 2 on New Year's this year? 3 A. No. | wasn't at her house on New Year's. 4 Q. Where were you when you took the picture of 5 Can you say blazed? That on your website? 6 A. | wouldn't know or -- wait. We were at a 7 birthday party for some girl's 16th birthday. 8 Q. Were you drinking at that party? 9 No. There was no alcohol or anything 10 ~=there. 11 Q. What does "blaze" mean to you? 12 A. It's Like -- it just means like messed up. 13 But we weren't, if you look at the picture. 14 Q. Messed up like drunk, right? 15 A. Sure. 16 Q. Who's a: 17 A. A girl | know like from like two years ago. 18 Q She's the one you were supposed to be 19 staying with when you went drinking with Nick iP 20 A. No. 21 Q. what's Ss fast name? 22 J i. 23 Q. Where does she live? 24 A. | don't know. In Royal Palm. Page 89 HOUSE_OVERSIGHT_012484

— oO Oo 8 4S DO oO FF WwW DN —_ - WwW NY oO FoF Oo drinking. pretending to Who are they? A. Q. A. ~0929104. TXT 105 Uh-huh. {'m guessing. Do you know her phone number? No, | do not. Let's look at 25-010. See, I'm drinking -- I'm not asking you about what you're Who are the men in this photo who are gang up on you and stab you with knives? Nick | and Brandon BE (phonet ic). Are they firemen? Are those? Steven a -- he said the two stabbing with knives. That's why | said that. | don't know. That's Steven | and John a. Q. A. Are these firemen? No. They're all on -- except Steven, they're all on full rights for football. Q. BY MR. TEIN: Q. penis? A. idea? A. Go to 025-015? MR. LEOPOLD: 025- dash? MR. TEIN: 015. THE WITNESS: Gosh, that's so long ago. Who took the photo have you ticking the 106 My stepmother. Whose idea -- that was your stepmother's lt was in Buca di Beppo, where she works Page 90 HOUSE_OVERSIGHT_012485

on DO oO FR WwW DN ~0929104. TXT currently and that was before she worked there, and we just thought it would be funny. MR. TEIN: 19-007. Can you enlarge that? BY MR. TEIN: Q. Who took this photo of you simulating you having sex with a man? A. We're not simulating having sex, and it's -- oh, and the person who took it was, I'm pretty sure, Chris, but | know him as | don't Know his last name. Q. Go to 19-006, please. Who took this photo of you simulating sex with a man? A. The same person. And we're not simulating having sex, Mr. -- Q. Tein. Did you post that on the Internet? A. Actually, this is an old MySpace | never Finished and | never [ike did anything. 1 just kind of made it and left it. Q. So the answer is yes, you posted this on 107 MySpace? A. Yup. Q. Go to 25-016. Who took this photo of you simulating sex with a woman? MR. LEOPOLD: Object to the form of the question. Argumentative. THE WITNESS: First off, she's piercing my belly button or repiercing it, and I'm pretty sure Page 91 HOUSE_OVERSIGHT_012486

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 ccorh oO OWN DMD OH PB WwW DN ~0929104. TXT it was just like we put up a camera somewhere and put a timer on it. We didn't have anybody take it. BY MR. TEIN: D ep FD > BY MR. TEIN: Q. correct? A. Q. You posted that on your MySpace page? Yeah. Go to 25-013. Is that a photo of you? Yep. Who's in the photo with you? Steven. Steven a: Yep. is this you coming out of the shower? Yes. Are you clothed in this picture? Yeah. 1 have a halter dress on. Where is that picture taken? 108 In Steven's house. Did you post that on the Internet? Yes. All right. MR. TEIN: You can take that down. Now your boy friend is Brett Yeah. You lie about your age in order to conceal something about your relationship with Brett a. isn't that correct? A. No. Page 92 HOUSE_OVERSIGHT_012487

14 15 16 7 18 19 20 21 22 23 24 25 ver oO oOo OWN OOo eR Oh UN ~0929104.TXT Q. Brett's 22 years old, isn’t he? A, Yes. Q. And Brett is a firefighter with the Palm Beach Fire Department, right? A. Yup. Q. Does the Palm Beach Fire Department know that your boy friend is dating an underage girl? A, Actually, Mister, it's legal. Q. Well -- MR. LEOPOLD: Just answer the question, a THE WITNESS: Yes. 109 BY MR. TEIN: Q. Did they know two weeks ago that you were dating an underage gir! (sic)? A. Yes. | met everybody in there. Q. Did they know your age? A. Yes. Q. Did you lie about your age so that the fire department wouldn't think that Brett is committing a crime by having a sexual relationship with an underage girl? MS. BELOHLAVEK: Objection. Assumes facts not in evidence. BY MR. TEIN: Q. You can answer the question. A. No. Q. Does the Palm Beach Police Department know that Brett is having a sexual relationship with an Page 93 HOUSE_OVERSIGHT_012488

18 19 20 21 22 23 24 25 —_— oO Oo OA SYS OD oO B® Ww DY ~0929104. TXT underage girl? MR. LEOPOLD: Don't guess. Answer if you know. THE WITNESS: Can you repeat the question? BY MR. TEIN: Q. You lie about your twin sister don't you? MR. LEOPOLD: Objection. Argumentative. BY MR. TEIN: Q. Don't you? A. No. | have never lied for or to | | Q. You lie about the fact that she has as drug habit, right? A. No. | would never accuse my sister of having a drug habit. Q. Do you try to conceal the fact that she has a drug habit? MR. LEOPOLD: Objection. Argumentative. BY MR. TEIN: Q. You can answer the question. A. No. My sister does not have a drug habit. Q. You [ied when you went to the crack house in Georgia, didn't you? MR. LEOPOLD: Objection. Argumentative. Lack of foundation, lack of predicate. THE WITNESS: Never -- what did you say? Page 94 HOUSE_OVERSIGHT_012489

oo 23 24 25 oO Oo OW SN OD oO F WwW DY = mM mM NM NY NY ND S| BB BSB ew |S | ws Go a 4 ao fF WwW NY -F= FC 0 8 4 DBD A BF WwW DY =F ~0929104. TXT BY MR. TEIN: Q. You |ied when you went to the crack house in Georgia, didn’t you? 111 MR. LEOPOLD: Objection. Argumentative. Lack of foundation, lack of predicate. BY MR. TEIN: Q. You can answer the question. A. | have never been to a crack house. Q. Who don't you lie to? MR. LEOPOLD: Objection. Argumentative. Don't answer the question. MR. TEIN: Certify it, Le eee eee eee CERTIFIED QUESTION.................. BY MR. TEIN: Q. You don't lie to | do you? MR. LEOPOLD: Objection. Asked and answered. Don't answer the question. BY MR. TEIN: Q. No. You can answer that question. MR. LEOPOLD: No. I| just told her not to. You've asked that question about five -- MR. TEIN: No, | haven't. MR. LEOPOLD: Don't answer the question. MR. TEIN: I'll certify it. MR. LEOPOLD: For the record, you have to stop interrupting me because she can't take down Page 95 HOUSE_OVERSIGHT_012490

pes, 2 3 4 ~0929104. TXT both of us talking at the same time. BY MR. TEIN: Q. You tell | i truth, don't you? Excuse me? You tell | truth, don't you? When it's -- yes, | tel! HE tne truth. who's [BBs drug dealer? ep SP, My sister does not have a drug dealer. She lives in Georgia with my mother. Q. Okay . you and a or at 5:45 a.m. in 2006, after being out all night, the two of you, using drugs at Palm Beach Country Estates where your father called the police? A. | Q. He's the drug dealer? A. He is a drug dealer. Q. Do you remember Jl was arrested by the Palm Beach Police Department and taken to the Juvenile Assessment Center that morning? A. 1 do remember that. Q. Now before you massaged Epstein, you were involuntarily admitted into a juvenile educational facility; isn't that right? A. Did you say involuntarily. Q. Yes. 113 A. No. | was willing to go. | -- duly said sure. Q. And you went there because you were lying so much, no one could control you; isn’t that correct? Page 96 HOUSE_OVERSIGHT_012491

7 18 19 20 21 22 23 24 25 oO ~~ DMD oO fF W DN ~0929104. TXT A. Very incorrect. Q. Now you lie to your parents all the time, don't you? A. Incorrect. MR. LEOPOLD: Objection. Argumentative. BY MR. TEIN: Q. Sorry? A. Incorrect. Q. You admitted to the police that you told your father that you were going shopping, didn't you? A. Yes. Q. And isn't it true that your father has accused you of lying? A. Atl the time. Q. Didn't your father throw you out of the house Thanksgiving of this past year because you were lying so much to him? A, Yes, he did kick me out. No, that’s not the reasons why. Q. Didn't your father throw your sister out of the house, too? A. Yes. Q. And he threw her out of the house the week Page 97 HOUSE_OVERSIGHT_012492

— _ 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 oO Oo BAN OD oO SF WwW NB ey wo No ~0929104 . TXT after Thanksgivings, right? A. | don't know the date, but sure. Q. Sounds about right? A. Sure. Q. And the reason he threw her out of the house was because she was lying, too? MR. LEOPOLD: Objection. Lack of foundation. Calls for speculation. BY MR. TEIN: Q. When your counsel coaches you, you say it's correct, right? A. I've never been coached. MR. LEOPOLD: Objection. BY MR. TEIN: Q. Okay. When your counsel! that it was there was lack of foundation, you agree with your counsel, right? As | was like saying, Yeah, let's move on, because there was no point to asking that question. Q. Your father threw I out of the house because she was lying, correct? MR. LEOPOLD: Objection. Lack of foundation. Hold on, i Let me just make the objection. Lack of foundation, predicate, calls for speculation. BY MR. TEIN: Q. Answer . A. t'm not my sister. | don't know. Page 98 HOUSE_OVERSIGHT_012493

14 15 16 17 18 19 20 21 22 23 24 25 —_ oO OO OB Ss OD oT FB WwW DN ~0929104. TXT Q | want to know what you know only. A | don't know. Q. You don’t Know. That's your answer? A Yes. Q Now your parents filed the police report regarding Mr. Epstein, right? they? A. Yes. Q. Now your parents are also lying, aren't A. Yes. MR. LEOPOLD: Just so the record is clear, the father -- because the mother was up north. MR. TEIN: Don't testify, Counsel. MR. LEOPOLD: So the record is clear, the father -- the mother was -- MR. TEIN: Counsel, don't coach and testify, please. That's absolutely improper. MR. LEOPOLD: You just asked the wrong question. MR. TEIN: You can't coach her that way and you wel! know it. MR. LEOPOLD: For the record, it's the father. He's remarried, | think on his third marriage. MR. TEIN: You cannot -- it's absolutely, totally against the rules and you know it. MR. LEOPOLD: The natural mother fives in Georgia. MR. TEIN: You need to behave yourself, Page 99 HOUSE_OVERSIGHT_012494

18 19 20 21 22 23 24 25 —_ oO © A 4 DP oO fF WwW DN ~0929104. TXT lawyer. MR. LEOPOLD: The natural mother lives in Georgia. The father is here locally. MR. TEIN: Stop coaching. Stop talking. You object. You know the rules. You just lectured me about the rules, Counsel. So why don't you play by the rules. Or only when they Fit you? Why don't you grandstand a little more 17 now. Give us a five-minute speech, Mr. Leopold. MR. LEOPOLD: Are you finished, for the record. MR. TEIN: I'm not talking to you. Do what you want. MR. LEOPOLD: Don't say anything yet. BY MR. TEIN: Q. a your parents -- MR. LEOPOLD: Hold it. Don't say anything yet. Let me -- BY MR. TEIN: Q. Your parents, who filed the police report are also liars. MR. LEOPOLD: Don't answer the question. We're not going to answer until! | make the record. | want to put on the record, now that Counse| appears to be finished with his comments for the record, that the previous question was inappropriate, was intentiona!!ly misleading. Now you can ask the question. BY MR. TEIN: Q. Your parents, who filed the police report Page 100 HOUSE_OVERSIGHT_012495

i ™ 23 24 25 — oO 0 Oa NOD HN Be WwW ON ~0929104. TXT in this case, are also proven liars, aren't they? MR. LEOPOLD: Same objection. BY MR. TEIN: 118 Q. Aren't your parents liars? MR. LEOPOLD: Calls for speculation. Lack of predicate. MR. TEIN: Stop coaching. You know what that is, Leopold. MR. LEOPOLD: Calls for speculation. Lack of foundation. THE WITNESS: When you say parents, my mom is not, but sure, yeah, my dad has been to jail for iying. BY MR. TEIN: Don't jook to your lawyer for the answer. MR. LEOPOLD: You can answer if you know the answer to it. 1 have no idea. Page 101 HOUSE_OVERSIGHT_012496

—_ oO ODN OOO Fw ON —_ > WwW NY ~0929104. TXT 119 THE WITNESS: Yeah. BY MR. TEIN: Q. And your father filed a lawsuit, the first lawsuit for fifty million dollars against Mr. Epstein without consulting you, correct? Q. And your father had a lawyer file the first fawsuit on your behalf for fifty million dollars against Mr. Epstein without your knowledge, correct? A. Correct. Q. And you don't trust your father, do you? A. Correct. Q. And you believe he’s trying to manipulate you for his own gain, don't you? A. Sort of. Q. Well, you know that your mother filed a statement, an affidavit, saying that you don't trust your father and that you believe he's trying to manipulate you for his own gain; isn't that correct? A. Correct. Q. You agree with that statement, don't you? A. Uh-huh. Yes. Q. Do you trust your stepmother? A. My stepmother, no. Q. You think she's also trying to steal your 120 Epstein lawsuit money away from you, don't you? A. | would like to clarify something. You keep saying my Epstein lawsuit money. | don't have any money, and it's just a lawsuit at the moment. So | just Page 102 HOUSE_OVERSIGHT_012497

~0929104. TXT 5 don't trust her. 6 Q. Okay. You think that your stepmother is 7 ~=trying to take advantage of this lawsuit to try to get 8 money from Mr. Epstein that belongs to you, right? 9 A. Yes. 0 Q. Did your stepmother tel! you why she was 11 arrested? 12 A. No. 13 Q. Did your stepmother tell you that she's 14 ever been arrested? 15 A. No. 16 Q. Did she tell you she was arrested for 17. ~~ «~fraud? 18 A. Never. 19 Q. Did she tell you that she was fired from 0 21 A. No. 22 Q. Did she tell you that whe was fired from 23 £0" stealing? 24 A. No. 25 MR. TEIN: Let's take a break. 121 1 (Thereupon, a recess was taken.) BY MR. TEIN: Page 103 HOUSE_OVERSIGHT_012498

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 —_ oO oO Oo VN OD HN BF WwW NN ~0929104. TXT A. Two. Q. How old were they? A. Zack JJ being one year older than me, and then the other person was two years older than me. Q. What was his name? A. Ryan | Q. How old were you when you first had sexual intercourse? Q. How many -- before you met Epstein, how many different men had you had any type of sexual activity with? Q. Are you saying you never kissed a man other than those two? MR. LEOPOLD: Objection to the form of the question. 122 THE WITNESS: Yes, | had kissed people before. BY MR. TEIN: Q. Before you met Epstein, had you ever had oral sex? A. No. Q. Ever in your Jife, have you exchanged sex for something of value? A. No. MR. TEIN: We're done. THE WITNESS: Oh, okay. MR. LEOPOLD: We'll read. MS. BELOHLAVEK: | don’t have any Page 104 HOUSE_OVERSIGHT_012499

O™ 14 15 16 17 18 19 20 21 22 23 24 25 — oO Oo Oo SI ODO oO Be WwW FH ~0929104. TXT questions. Thank you. MR. LEOPOLD: Before we go off the record, it's my understanding -- Mr. Goldberger can correct the record, but we have stipulated that color copies of the documents that were identified for identification certainly will be attached to the deposition and counsel! will be taking the photographs across street so that they can be laser color copied so that we have a copy, and I'm assuming he'!l1 get a copy to the court reporter, too, to attach, actually a certified copy to the deposition. MR. GOLDBERGER: Done. MR. LEOPOLD: That's if you agree to that. If not, then | want to pull each one out and put exhibit labels on them, which we should do before we leave. MR. GOLDBERGER: We're not going to do either. I'll have copies sent to the court reporter and she can attach them to the deposition. MR. LEOPOLD: So you're not going to agree to what we talked about during the break then. MR. GOLDBERGER: I'm not quite sure what your asking me to do. Let me finish. MR. LEOPOLD: Okay. Sure. That's fine. MR. GOLDBERGER: Okay. If you want me to go over to Ms. Belohlavek's office and make copies and then I'll give those to the court reporter, Page 105 HOUSE_OVERSIGHT_012500

18 19 20 21 22 23 24 25 ol o Oo ON OD oO Fe WY PY ~0929104. TXT fine. Al! I'm saying is that | would avoid that process. | would send copies to the court reporter. But if it will make you happier -- MR. LEOPOLD: I'm not? MR. GOLDBERGER: Let me finish. MR. LEOPOLD: I'm not interrupting now. MR. GOLDBERGER: But if it will make you happier if | go over to Ms. Belohlavek's office 124 and make a copy of those photos that were part of this deposition and then |'1I!t give them to the court reporter, I'l! be happy to do it. MR. LEOPOLD: | trust you implicitly, however you with to do it. However, the documents, before they leave this room, need to have an exhibit sticky on them with the appropriate -- MR. GOLDBERGER: Want to go get some? We don't have any. MR. LEOPOLD: 1 will do that. Excuse me. Let me finish the record, please. You can't do that to the court reporter. She's going to stroke out. You can’t do that. You have to let me -- MR. TEIN: Finish your sentence, Ted. You are the most long-winded lawyer I've ever seen in my life. Finish your sentence. MR. LEOPOLD: Jack, tell him not to raise his voice, please. MR. TEIN: Finish your sentence. Is there going to be a period at the end of the sentence or is it just going to be comma after comma after Page 106 HOUSE_OVERSIGHT_012501

-_ 23 24 25 = oo Oo OA NN OO on BR WB PLY ~0929104.TXT comma? Go ahead, lawyer. MR. LEOPOLD: All right. The exhibits, | 125 can't prevent you from taking them, but | wil! object and | will be bringing. it to the court for sanctions. You cannot take the exhibits out of the room without them being marked. | want them marked, because you cannot identify in the record what was used. And with all due respect to Mr. Goldberger, | do not -- the way this deposition is going, | do not want to rely on Counsel from Miami to mark the appropriate exhibits. | will not do that. Jt cannot prevent you from taking them. But if you do, | will be bringing the matter to the court with appropriate sanctions, because that is improper. That is improper. When you use something in a deposition, they are to be marked. And you have refused to do that throughout for what ever reason. MR. TEIN: You're wrong. Finish your sentence because you're talking about something you have no idea. Every single one is marked, Ted. Every single one is already marked. But you want to argue about everything. Ever single one is already marked. Isn't that silly, Ted? MR. GOLDBERGER: Thirty years of doing this and | have never had an argument over this. Page 107 HOUSE_OVERSIGHT_012502

— oo Oo WD NY ODO oO BP WwW NN &k WwW DM ~0929104.TXT 126 MR. TEIN: You've made -- Ted, you are obstructionist, you are a liar. You have lied and misrepresented things, for the record. You are grandstanding. MR. LEOPOLD: You need to back up. MR. TEIN: No, no. I'm going to finish. MR. LEOPOLD: You can finish, but don't hover over me. MR. TEIN: No one is hovering over you. Stop trying to make a lying record. Let me say something else. Don’t you dare threaten me with sanctions, after you lied in a letter to my co-counsel about the fact -- be quiet. Be quiet and let me finish. You lied in a letter to my co-counsel, Mr. Leopold, in which you said -- it was a complete and utter lie -- that you were unavaifable this morning because you had a hearing. That was a lie. | have never seen each lawyer deign to do something like that. So you will get the ex -- be quiet. Let me finish. You behave. MR. LEOPOLD: Don't point your finger at me. MR. TEIN: Listen. Be quiet and | won't 127 have a need to point it at you. MR. LEOPOLD: Don't point your finger at -- MR. TEIN: Mr. Leopold -- MR. LEOPOLD: Don't point your finger at Page 108 HOUSE_OVERSIGHT_012503

— on Oo on FF WwW DY ~0929104. TXT me. MR. TEIN: Mr. Leopold, let me finish. MR. LEOPOLD: Don't raise your voice either. MR. TEIN: Mr. Leopold -- MR. LEOPOLD: Jack, do you want to take care of this? MR. TEIN: Let me finish my sentence. The exhibits are marked. We are walking out of here. You are someone who misrepresents the record. It is absolutely atrocious what you do. That is not how a lawyer should behave. This deposition is over. You will get your exhibits, Mr. Leopold. MR. GOLDBERGER: | understand what you're saying, Michael, and | understand Ted's position. Just so there's -- we're going to have tots offer issues in this case. We're going to have lots of reasons to disagree. I'm going to take it over now and 1|'m going to make copies and I'm going to give them to 128 Ms. Consor. If you want to go find some exhibit labels and put some exhibit labels on it, be my guest. But that's what I'm offering to do. THE WITNESS: Let me say two things, because | am happy to always disagree and with you, | have no problem; we could always do it professionally. | want to say two things so the record is Page 109 HOUSE_OVERSIGHT_012504

oo 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 —_ oO OO OD NN OD oO FF WwW YN ~0929104 .TXT very clear. Since for whatever reason | have not been able to look at exhibits because they have been refused to have been shown to me -- MR. TEIN: That's a lie. MR. LEOPOLD: Jack, if you represent that the documents have the appropriate exhibit numbers or some identifying markings, 25, 30.000, whatever they may be, then you can take them, make copies, send me a copy, make sure the court reporter gets a copy and then send me a bill for my copy, that's fine. | didn't know that they are marked that way because | haven't been able to look at them. MR. GOLDBERGER: They are barcoded and the number that we've made reference to in the deposition coincides with the barcoding. MR. LEOPOLD: That's fine. Eight by eleven color laser copies are fine. 129 MS. BELOHLAVEK: The State Attorneys Office iS not going to charge anybody for color copies | print out. MR. LEOPOLD: That's fine. He's going to take them back to his office . Secondly -- and | will be more than happy to do it, because it sounds !ike you all know more about it than |, but |'m happy to get affidavits from Mr. Pincus, Judge Stern, everybody else about what happened with this hearing today, because | know very [ittle about it. But my representations are what they are. MR. GOLDBERGER: They stay -- Page 110 HOUSE_OVERSIGHT_012505

14 15 16 17 18 19 20 21 22 23 24 25 —_ oo oOo OD SN OD oO F WwW ED ~0929104. TXT MR. LEOPOLD: Let me just finish for the record. Representations or comments about what happened, representation about this hearing this morning, | know very little about it. I -- MR. GOLDBERGER: !'11 take your word on that. MR. LEOPOLD: No, no, no. I! just put it on the record. | will get an affidavit -- I'm assuming it sounds like you need it -- from Mr. Pincus. | have no clue about what happened and why it was canceled. All | was told when | was 130 out of town yesterday was that the hearing this morning was cancelled. MR. GOLDBERGER: I’!] take your word for MR. LEOPOLD: If you want an affidavit, I'tl get it for you. MR. GOLDBERGER: It's a personal issue for me because | had to disrupt a vacation and if it was done just because it wasn't convenient for you, then i'm offended by that. But if you're telling me that it was planned and it didn't happen, |'!f take your word for it. MR. LEOPOLD: | am more than happy to get you an affidavit, because | don't know the reason why it was canceled other than the fact that I'm assuming since my deposition was taken for four hours on Monday for preparation for the hearing Page 111 HOUSE_OVERSIGHT_012506

18 19 20 21 22 23 24 25 —_ o oO An OD ao BF WwW DN ~0929104 . TXT today, for whatever reason it was canceled, | am told it is being re-noticed. Why it was canceled 1 have no idea, but if your co-counse! wishes an affidavit to that effect from Mr. Pincus, |'m more than happy to get it. But | don’t know the reason why it was canceled. MR. TEIN: | don't need it. But what | do take issue with is regardless of why it was 131 canceled, you owed us the courtesy of saying, you know what? We can start earlier this morning. MR. LEOPOLD: | owe you nothing. MR. TEIN: {! don't care. Don't interrupt me. Because Jack canceled his vacation plans because of you. MR. GOLDBERGER: That's all right, that's all right. MR. TEIN: And you're selfish. And this deposition is over. Good-by Mr. Leopold. MR. GOLDBERGER: You can go off the record. Page 112 HOUSE_OVERSIGHT_012507

23 24 25 —_ oO Oo ON ODO ON eR WwW DY ~0929104. TXT 132 CERTIFICATE The State of Florida, ) County of Palm Beach. ) | hereby certify that | have read the foregoing deposition by me given, and that the statements contained herein are true and correct to the best of my knowledge and belief, with the exception of any corrections or notations made on the errata sheet, if one was executed. Dated this day of _ , 2008. Page 113 HOUSE_OVERSIGHT_012508

oo — oOo ON DH F&F WN = b WwW WN ~0929104 . TXT 133 DATE: [!MONTH2] DATE2, 2008 X X X, Florida X IN RE: CASENAME CASE NO.: 2006 CFOS454AXX Please take notice that on Wednesday, the DATE1 of [!MONTH1], 2008, you gave your deposition in the above-referred matter. At that time, you did not waive signature. It is now necessary that you sign your deposition. “ Please call our office at the below-listed number to schedule an appointment between the hours of 9:00 a.m. and 4:30 p.m., Monday through Friday. “As a professional courtesy, I am enclosing a condensed copy of your deposition transcript. a As previously agreed to, the transcript will be furnished to you through your counsel. Please read the following instructions: At Page * of the transcript, you will find an errata sheet. AS you read your deposition, any changes or corrections that you wish to make should be noted on the errata sheet, citing page and line number of said change. DO NOT write on the transcript itself. Once you have read the transcript and noted any changes, be sure to sign and date the errata sheet and return these pages. You need not return the entire transcript. If you do not read and sign the deposition within a reasonable time, the original, which has already been forwarded to the ordering attorney, may be filed with the Clerk of the Court. If you wish to waive your signature, sign your name in the blank at the bottom of this letter and return it to us. Very truly yours, Judith F. Consor, FPR Consor & Associates Reporting and Transcription 1655 Palm Beach Lakes Boulevard, Suite 500 West Palm Beach, Florida 33401 | do hereby waive my signature: SAIGE GONZALEZ 134 ce via transcript: JACK A. GOLDBERGER, Esquire LANNA BELOHKLAVEK, Esquire MICHAEL R. TEIN, Esquire file copy Page 114 HOUSE_OVERSIGHT_012509

oO nt mn ao PF WwW DH ~0929104. TXT 135 ERRATA SHEET IN RE: CASENAME DEPOS|TION OF: [MM = TAKEN: [!MoNTH1] DATE1, 2008 DO NOT WRITE ON keene - ENTER CHANGES HERE PAGE # LINE # CHAN REASON Page 115 HOUSE_OVERSIGHT_012510

am 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 —_ oO Oo Oo 4 DO oO BF WwW NW ~0929104. TXT Please forward the original signed errata sheet to this office so that copies may be distributed to all parties. Under penalty of perjury, | declare that | have read my rITYPEY and that it 1s true and correct subject to any changes in form or substance entered here. DATE: SIGNATURE OF DEPONENT: 136 THE STATE OF FLORIDA, ) COUNTY OF PALM BEACH. ) 1, the undersigned authority, certify that EE Dersona! ly appeared before me on the DATE1 of [!MONTH1], 2008 and was duly sworn. WITNESS my hand and official seal this DATE2 day of [!MONTH2], 2008. Page 116 HOUSE_OVERSIGHT_012511

—_, 14 15 16 17 18 19 20 21 22 23 24 25 oc O© ODO NN DO oO FPF W DY = re a rn On Oo a DO oO BP W NY = ~0929104. TXT Judith F. Consor, FPR Notary Public - State of Florida CERTIFICATE The State Of Florida, ) County Of Palm Beach. ) |, Judith F. Consor, Court Reporter and Notary Public in and for the State of Florida at large, do hereby certify that | was authorized t stenographically report the [!TYPE] of that a review of the rranscr ipt was not requested; and that the foregoing pages, numbered from 1 to *, inclusive, are a true and correct transcription of my stenographic notes of said [!TYPE]. | further certify that said [!TYPE] was taken at the time and place hereinabove set forth and that the taking of said [!TYPE] was commenced and completed as hereinabove set out. | further certify that | am not an attorney or counsel of any of the parties, nor am ! a relative or employee of any attorney or counsel of party connected with the action, nor am | financially interested in the action. The foregoing certification of this transcript does not apply to any reproduction of the same by an means unless under the direct control and/or direction of the certifying reporter. DATED this DATE2 day of [!MONTH2], 2008. Page 117 HOUSE_OVERSIGHT_012512

a \ 18 19 20 21 22 23 24 25 ~0929104. TXT Judith F. Consor, Court Reporter Florida Professional Reporter Page 118 HOUSE_OVERSIGHT_012513

TAB 14 HOUSE_OVERSIGHT_012514

nsor & Associates : Reporting and Transsalgtiea, Ja. THE STATE OF FLORIDA, COUNTY OF PALM BEACH, JEFFREY EPSTEIN. / SWORN STATEMENT rh! Friday, March 21, 2008 4:00 p.m. - 4:20 p.m. 250 Australian Avenue South Suite 1400 West Palm Beach, Florida 33401 Reported By: Judith F. Consor, FPR Notary Public, State of Florida Consor & Associates Reporting and Transcription West Palm Beach Office Phone — 561.682.0905 HOUSE_OVERSIGHT_012515

nsor & Associates Baporing and Transcription, Ins. APPEARANCES: On behalf of the Defendant: JACK A. GOLDBERGER, ESQ. ATTERBURY, GOLDBERGER & WEISS 250 AUSTRALIAN AVENUE SOUTH SUITE 1400 WEST PALM BEACH, FLORIDA 33401 561.659.8300 ALSO PRESENT LILLY ANN SANCHEZ, ESQ. FOWLER WHITE, ATTORNEYS AT LAW HOUSE_OVERSIGHT_012516

ssor & Associate ' Reporting and Transeription, inv. Page 3 Statement taken before Judith F. Consor, Court Revorter and Notary Public in and for the State of Florida at Large, in the above cause. Thereupon, having been first duly sworn or affirmed, was examined and stated as follows: THE WITNESS: BY MR. GOLDBERGER: Q. Would you state your name for the record, Okay. po where do you live now? Address? Sure, Q. Do you Live there alone or do you live with somebody there? A. My father. Q. Very good. And are you working now or not working? Sometimes you work and sometimes you don’t? A, When I want to. Okay. And how old are you today? HOUSE_OVERSIGHT_012517

sor & Associates ‘Reporting and Transesiptics, Ins. Twenty-one. Very good. What we're going to do today is we're going to take what's know as a sworn statement from you. And | my court reporter just put you under oath. So ail I want you to do is tell the absolute truth today. d A. Right. i Q. I don't want you to color what you're saying in any way. Really, the only thing that will be of any use to anyone is if you just tell the absolute truth. ; : C 2 < Right. : ~ F So those are the instructions, okay? A. Okay. Q. All right. And sometimes -- I've been : doing this for a lot of years and sometimes I talk like a lawyer too much, and if you don't understand what I'm -- As That's your job. 5 Q. I guess. But if you don't understand what I'm saying at some point, just say, "Jack, say it in English," and I'll make it better for you. Okay? A. Okay. QO. So tell me how you First met Jeffrey ql HOUSE_OVERSIGHT_012518

o~ nsor & Associates Reporting and Transeuptioa, ine. Page 5 : And | ES a frienc of yours at the A. Yes. Q. Okay. And tell me a little bit about the introduction, how PR introduced you to Jeffrey. Okay. So let's break that down a little She toid you you could go over there to Jeffrey Epstein's hovse and give a massage? A. Right. Q. When she said go give a massage did she tell you what she meant by that? A. Just are -- no. Just a massage. She didn't really give me any details. Q. Okay. Let me ask it to you another way. A. Okay. Ou Was there any suggestion that what you were being offered the opportunity to do would be sexual in any way? HOUSE_OVERSIGHT_012519

sor & Associates Reporting and Treseription, Ine. ToDo Page 6 Q. Okay. So as far as you understood it and as far as what told you, you would be going over to Mr. Epstein's house and just giving him a normal therapeutic massage? A. Right. Q. Okay. And I assume Ji 010 you you would be paid for it? i A, Yes. ; 0. Did she tell you how much you would be : Rx Yes. Two hundred. Q. Okay. When was the first time that you went to Jeffrey Epstein's house? Was it after you spoke to Alex? A. Yes. Q. Okay. And the first time that you went to Mr. Epstein’s house, that was in response im talking to you in person. In other words, she said -- avernp rae you saw her somewhere, be it at the store that you worked at or around the neighborhood, she said to you in person, "Do you want to go over to Jeffrey Epstein's house?” Right? HOUSE_OVERSIGHT_012520

msor & Associates * Reporting and Trensexipticn, Ine. 0. And I take it you said okay and you went over there? A, Yes. Qs All right. Now at the time that you went over there, you were not yet 18, but you were almost 18? A. Yes. Q. You were within a couple of months of being 18 years old? A, Yes, I do believe so. Q. Okay. And what dic re you about if asked, how old you should tell anyone you were when you went over to his house? Was that a bad question? A. Repeat that. HOUSE_OVERSIGHT_012521

Snsor & Associates ” Reporting and Trenscziption, inc, Page 8 : Before you went cver to Jeffrey's house after you net ii in person, did she tell you if anyone asked you how old you were, how old you were supposed to Say you were? A. Q. She didn't give you a script and say as soon as you walk in the house you're supposed to say, "I'm 18," right? A. No. Q. And I assume if you were asked, you wanted to be convincing that you were cver the age of 18, because you wanted to do the work, right? A, Right. QO. By the way, were you ever asked? Eventually. Okay. A. Not the first day, I don't believe. Q. Okay. Was it Jeffrey or someone else that asked you whether you were over the age of 18? HOUSE_OVERSIGHT_012522

nsor & Associates " Reporting and Transcription, (ae. Page 9 Bre It was probably Jeffrey. I don't remember very clearly. Q. A. Yes. Q. Okay. Now the first time that you went to Jeffrey's house did you give him a massage that day? A. Uh-huh. MS, SANCHEZ: Answer yes or no so the record is clear. THE WITNESS: Yes. Okay. (Discussion keld off the record.) BY MR. GOLDBERGER: Q. Okay. So you go to Jeffrey's house and you meet him and you're going to do a massage that day, right? HOUSE_OVERSIGHT_012523

sor & Associates * Reporting aod Transsrigies, Jas, QO. one offered you any drugs to do a massage? A. Q. one offered you any alcohol to doa message? A. HOUSE_OVERSIGHT_012524

—_ . ‘Reporting and Trusciption, Ino, Right. Q. Okay. So aid tell you what to expect when you went there, as far as keeping your clothes on or taking your clothes off? A. It was no problem. He wouldn't be upset. Q. All right. so told you there would be no pressure on you whatsoever? Right. Yes, And if you didn’t want to do something, you All right. And in your experiences with HOUSE_OVERSIGHT_012525

insor & Associates ‘Koportiog and Transcription, ine, C Page 12 i Mr. Epstein, by the way, was there ever a time when that didn't play out, when he tried to force you to do i 1? something that you didn't want to do? Q. All right. Now the first time that you went there do you remember whether you gave Jeffrey a massage with your clothes on or your clothes off? < A. At the beginning, it was with all my clothes on. Q. Uh-huh. A. But the most that -- I mean I was still in my bra and panties. Q. Okay. The whole time? A. Yes, Q. Right. A. I'm pretty sure, yes. Q. Did you see during that massage -- did he try and touch you in any way during that massage? A. No. Q. Did he use any kind of device on you in any ( way Guring that massage? HOUSE_OVERSIGHT_012526

nsor & Associates Reporting snd Treasoription, Inc, A. No. Q. Do you knew -- he was wearing a towel through that massage? A. Yes. 9. Do you know whether he touched himself in any way, his penis or anything like that, during the massage? Yeah, like towards the end. Okay. Do you know whether he masturbated? Oh, my gosh, QO. If you don't know, you don't know. A. I mean probably, but I don't know. I can't remember exactiy. It was so long ago. Q. Okay. There was nothing that you were uncomfortable with in this massage? A. No. Yeah. And like I said, he also, you know, reassured if I wasn't comfortable with anything, then just tell him and -- Q. He would stop? A. -- that would be the end of it. Q. Okay. Now after that first time you met at Jeffrey’s house, you left. And did there come other times that you went to Jeffrey's house? A, Yes. And how would that occur? How would that HOUSE_OVERSIGHT_012527

snisor & Assaciates ‘Reporting and Trensauption, Inc, Q. So would it be primarily Jf that would call or would there be others? A. Most of the time. Okay. Unless I didn't answer my phone. HOUSE_OVERSIGHT_012528

_~* Hees comtittiswat tn da Page 15 £ SUTRAS Memon a er Sy 7 Q. Never, ever suggested, right? No. A. 9 . Q. Okay. The only thing that ever occurred on any of these phone calls was, "Are you willing to come 11 over," or, "Would you like to come over and give a massage?" aS EAST 17 Q. Okay. The phone call from or any other assistant would always -- it would be sporadic, right? They always said, "Jeffrey's going to be in town. Do you want to come over this afternoon at four o'clock?" Pl A. Yeah, yeah. It wasn't -- 22 Q. There was nothing regular about it? No. A. 24 Q. Okay. Other than Si who else would have called you to ask whether you wanted to come over and HOUSE_OVERSIGHT_012529

sor & Associates Storage and Traseription, tne, Page 16 resrasaee cake 1 give a massage? 2 A. If it wasn't | | then I believe P| : 3 maybe one other person I don't know the name of. Just -- é And PY I spoke to a time I mean it was mostly | or two. 6 O. Okay. Now when you would go over to Jeffrey's house after getting a phone call, you would go DAMA Sah ere rial eee DNS and you'd go to give him a massage, right? A. Yes. 10 Q. And occasionally would there be more than a massage that occurred? 12 A. It happened a few times. 13 Q. Okay. And the few times that it happened, though, it was very sporadic and it was nothing that was 15 planned? ARTES aT 16 Bes No way. Q. It just occurred? ape (ssi: beer erereraieysei di 18 A. Right. Q. So it wasn't like there was a phone call, you know, "Today we want you to come over and do more than just a massage with Jeffrey"? OG A. Right. 23 Q. When anything more occurred you'd be over there and it would be totally voluntary on your part? 25 A. Yes; definitely consensual, SAV TL TOSENN BT aiTG he Ae EPO TE Hane Pe We eee Ur TN EC ARNTRE ET CRT NY CTE PY 2 TS Ae OTN EE LYASE TLE YEN or Teale ECO eee HOUSE_OVERSIGHT_012530

( Page 17 | Q. Okay. Now when we're talking about more than just a massage, what sort of conduct are we talking about that might have occurred? A. It was probably mostly -~ maybe not, not particularly oral, but, Q. Okay. So let's put it into perspective. You certainly never had intercourse with him, right? A, No. Q. And did you actually ever really have oral sex with him? C A. Maybe once or twice. I barely even remember that. Okay. I mean it was all just mostly -- I'm sorry. Mostly what? A. Mostly like hand oriented. Q. Okay. So on occasion you would touch his penis with your hand? A, It's happened a few times, Q. Okay. And anytime that occurred it would be totally voluntary on your part? A. HOUSE_OVERSIGHT_012531

Page 18 1 Q. And it would just be totally random and it would occur during the moment? A. Uh-huh. 4 Q. Okay. There was nothing that was planned in advance concerning that? A. No. 7 QO. And it didn’t become every time you went over there that would happen, right? A. Yean. No. 10 Q. No, no. I mean just you would go over and give a massage one day and the phone call would be the 12 same, "Do you want to come over and give a massage,” and maybe -~ A. Yes. 15 0. -- maybe another time you woutd get a phone call, "Do you want to come over and give a massage," and just because of the day it was or whatever was going on, it may have gone a little further where they may have been some touching, correct? 20 A. Right. 21 QO. And then the next time you could go over there and it could have been a regular massage again, right? Uh-huh. Okay. So the point that I guess I'm trying HOUSE_OVERSIGHT_012532

nsor & Associates ‘Reporting and Trenserintion, fas, Page 19 f to make was that there were never phone calis that would come to you and they would say, "Do you want to come over and give a massage," and you just assumed it would be to go have sex? That was not the case? A. No. QO. Never, never, never, right? A. Yes. Q. All right. There were times when you would be away and not be in Palm Beach and —— I mean you very much thought that Jeffrey was your friend? You treated him as a friend? A. Yes, definitely. I felt that he was my friend. Q. And there were times when maybe you were out of town and for whatever reason, you found yourself in a situation where you needed some money, correct? A. Yes. Q. Okay. And you felt that the relationship was such that you could call Jeffrey and it never had anything to do with a massage or anything. You would say, "Listen, I could use a couple of dollars. I have a problem.” A. Yes. Q. And would he ever hesitate to help you out? HOUSE_OVERSIGHT_012533

nsor & Assaciates Reporting and Transeription, inc. Page 20 # QO. And in fact, did he not tell you that, listen ~- he would talk to you about life and about -- A. Yes. Q. -~ about what you wanted to do with your Yes. And he said, "If you ever find yourself in trouble, you have a friend in me and you can give me a cali"? A. Yes. Q. Okay. If you had to guess -- and recognizing that there can be no accuracy here -- if you had to guess, how many times do you think you went over to Jeffrey's house? A. I would say at least five, less than ten. QO. Okay. I think that's kind of a fair range. And during those five to ten times that you went there, was there ever anything uncomfortable, in your mind, that occurred over at Jeffrey's house? A. No. Q. Okay. I know we've touched on this, but just Lilly, the detail person, makes sure that we get everything. After you met Jeffrey the first time did you ever talk to him on the telephone about arranging a massage or anything like that? HOUSE_OVERSIGHT_012534

ooo ” Reporting and’ Transoriptiva, fun. A. No. Q. Okay. And you never e-mailed him or anything like that? A. No, no. Q. Never text-messaged him? A. No. Q. Okay. Now at times when you would go over to give a massage, Jeffrey, while he was getting the massage, would be preoccupied doing a lot of things, right? A. Yes, very often. Q. He was a busy guy? Bos Yes. Q. He would be on-the telephone talking to folks while you were giving a massage? A. Yes. Sometimes it would be just a massage and he'd be pretty much doing business the whole time. Q. Right. Certainly it wasn't sex or anything like that? A, No. Q. He would be doing business and you'd be massaging hin? A. Yes. Q. Okay. Give me one second. (Discussion held off the record.) HOUSE_OVERS TD DEIN recand acer tv cara Cara ITN AP RCV IY AH ore eT eT amir naa oe, laters ONL ACCEL ETSI EINE FTI IGHT_012535

nsor & Associates Reporting and Transeuiptioa, Ins. Page 22 ' BY MR. GOLDBERGER: Q, Every time you went back to Jeffrey's house you went back there because you wanted to, right? A. Uh-huh, yes. Q. No one -- certainly Mr. Epstein never tried to persuade you or induce you or entice you or coerce you to engage in any kind of sex? A. No. QO. And no one representing Jeffrey Epstein ever tried to persuade or induce you to engage in sex? A. No. Okay. Like there was no ifs, ands or buts about Q. There was a time when there was a concert or a show down in Fort Lauderdale and Jeffrey got you tickets to go to that show because it was your birthday, right? Correct. HOUSE_OVERSIGHT_012536 Sev SU es ecaee Tae are Tarienrnaae Mason nahn

oo wor & Associates \ Reporting and Transeripiion, foe. I tried not to like even touch upon But I know you didn't try and touch upon Okay. Great. Here's the lawyer talking now. I didn't try to influence you in any way to say anything, did I? Bes No. Q. In fact, all I asked you to do is tell me the absolute truth here today? A, Yes. And that's what you've done? HOUSE_OVERSIGHT_012537

fe A. 2 Q. Ckay. And you've understood all my questions, have you? A» Yes. 5 MR. GOLDBERGER: Okay. I thank you very much for coming in today and it really made it much easier for us to do it this way. So thanks a lot. (Thereupon, the sworn statement was concluded at 4:20 p.m.) HOUSE_OVERSIGHT_012538

oo nsor & Associates ” Reporting and Trenseriptiva, fas. pease ai rety THE STATE OF FLORIDA, } COUNTY OF PALM BEACH. } Manca aD SRST OIAM CP FF OH EST I, the undersigned authority, certify that 6 .--:-2227 appeared before me on the 21 of March, 2008 and was duly sworn. z Ae reserva crise WITNESS my hand and official seal this 22nd day of March, 2008. Judith F. Consor, FPR i Notary Public - State of Florida i HOUSE_OVERSIGHT_012539

Snsor & Associates ~~ Reporting and Trenspripiiog, ins. SINISE aay CERTIFICATE Ee The State Of Florida, ) County Of Paim Beach. ) I, Judith F. Consor, Court Reporter and Notary Public in and for the State of Florida at large, do hereby certify that I was authorized to and did stenographically report the sworn statement of PF P| that a review of the transcript was requested; and that the foregoing pages, numbered from 1 to 24, MRIS Spe rete ITC E SDs inclusive, are a true and correct transcription of my stenographic notes of said sworn statement. Hiiihaltalccceanlal 1 further certify that said sworn statement was taken at the time and place hereinabove set forth and B that the taking of said sworn statement was commenced and completed as hereinabove set out. I further certify that I am not an attorney or counsel of any of the parties, nor am I a relative or reste [art] Cissaicear ese tsy employee of any attorney cr counsel of party connected with the action, nor am I financially interested in the action. The foregoing certification of this transcript does not apply to any reproduction of the same by any EB means unless under the direct control and/or direction of the certifying reporter. SEU Pee TAG DATED this 22nd day of March, 2007. Judith F. Consor, Court Reporte Florida Professional Reporter ° i 3; Sha es RGN AAT td RIM 8 HE G8 AS TMP EMPL ERI OS EE BET PD SD SIE A ATTA LEAT AE URNS REL EAE AUS PY SEED fi ripe EERE ASL Ee OP OY RENT NSE A FATTO TO ery | HOUSE_OVERSIGHT_012540

snsor & Associates Roparting and Teenseiption, Ino. rates Eb AEST eS ASSLT MIAME MSA en eS EE EEL TOTS CTR Be Poa Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Bivd., Suite 500 - West Palm Beach, FL 33401 HOUSE_OVERSIGHT_012541

Page 28 Ph, 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 HOUSE_OVERSIGHT_012542

sor & Associates Reporting and Trensesipiion, Inn. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 HOUSE_OVERSIGHT_012543

AOS Reporting and Transoription, Inc. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 HOUSE_OVERSIGHT_012544

TAB 15 HOUSE_OVERSIGHT_012545

: nsor & Associates .. denoning aml Transeripsinn daa... THE STATE OF FLORIDA. COUNTY OF PALM BEACH. JEFFREY EPSTEIN, CONTINUED SWORN STATEMENT OF March 26, 2008 6:05 p.m. to 6:22 p.m. South 86th Terrace West Palm Beach, Florida Reported By: Maria C. Powers, Notary Public State of Florida J. Consor & Associates Reporting & Transcription West Palm Beach Office Phone 561.682.0905 ORIGINAL F A ( Ph. 561.682.0905 - Fax. 561.682.1771 meen tn woes ees sone! «FD Palth Beach Lakes’ Bivd.;Stite 500°- West Palm Beach, FL 33401 °° ~*: s77~ ONY Shao dela AE a Sie Hehe an ae OOO HOUSE_OVERSIGHT_012546

ensor & Associ ates MO § Heporting and Trenseripiion, Ine -- APPEARANCES On Behalf of the Defendant: JACK A. GOLDBERGER, ESQ.. ATTERBURY, GOLDBERGER & WEISS 250 South Australian Avenue Suite 1400 West Palm Beach, Florida 33401 [PRR DPE MUNITY SEE OOS STIL EE CLS EE ED STIS TOSE PSNR DESLERTIC TINY SUE DOT TET EEE A ETRE IIET SESE SPOTS FTE EDL ERGY Oto SET WA ENE LATELY RY CLOSET SRL PREP SELLY WEE SETI Ph. 561.682.0905 - Fax. 561.682.1771 “1655 Palit Beach Lakes Bivd.; Suite 500 - West’Palin Bédch, FL 33401" "tn i HOUSE_OVERSIGHT_012547

ESSERE AT nsor & Associ ates | rel Reparcing and Trenscriptinn, Ine. gu WITNESS: DIRECT By Mr. Goldberger DS 2 EEC LEO BDL RICE SEE BEE TA LOSI EST DET CENT SET EEE ETS 59 SEES SEBO ESA GI EN CALIECCES SCOP TET 372297 COSSLAE LET ETSI TES TEN MEETS PRETEND Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palfri Beach Lakes’BlVd-; Suite 500°- West Palm Beach, FL 33401" vt et HOUSE_OVERSIGHT_012548

nsor & Associates | Aeporsing onl Jrznseription, Ins. ‘ Page 4 Sworn Statement taken before Maria Powers, Court Reporter and Notary Public in and for the State of Florida at Large, in the above cause. Thereupon, F i having been first duly sworn, was examined and H testified as follows: DIRECT EXAMINATION BY MR. GOLDBERGER: Q P| as you remember, my name is Jack f iE fg Goldberger. I think we met last Friday, actually. You voluntarily came in and gave a sworn C ) statement to me concerning your knowledge and your friendship with Jeffrey Epstein. I would like to very, very, briefly continue that statement today, and just focus on one area that we forgot to question you about last Friday. A Yes. : Q All I want you to tell me is the absolute truth here this evening. There's no right answer, | other than the truth, okay? : LA Right. | Q I haven't promised you or asked you to do ! anything, one way or the other, have I? | fos A No. | 7 7 Ph. 561.682.0905 - Fax. 561.682.1771 oe "1655 Pali Beach Lakés Blvd; Suité 500 - West Pali Beach, FL33401°° “tt HOUSE_OVERSIGHT_012549

, nsor r & Associates: < \ Page 5 So, we covered a lot of ground last time. One area that I didn't ask you about is contact that -you've had with either the FBI or the U.S. Attorney's Office, within the last two or three years. Can you guess or estimate how many times someone from the FBI or the U.S. Attorney's Office or some other law enforcement agency, has attempted to contact you in the last couple of years? A I'd have to say -- well, maybe five or six meetings with, and more than that with phone contact. Q Let's try to break it down by meetings and f : | a 7 phone contacts. I think that would be the best way to Of the actual meetings that you've had with | someone from law enforcement or from the U.S. | Attorney's Office, who do you remember being present at those meetings? — | ; ! A Nesbith was at all of them. | Q When we're talking about "Nesbith”" we're | | talking about an FBI agent by the name of "Nesbith | Kurkendali"? | A Yes. : Q And Nesbith was present at all those | meetings? | ’ ; i f ee PF ptbsatowdis Wen mcltiie Wauansk Wi wacaesee te on wee FREEING EIEN REE REL NTL RSE ENS EE SIE TCTSES OO E SEH TEN PSOE T ICES Ds WORE CEU BULAN OSMOSIS TOUTES | * Ph. 561.682.0905 - Fax. 561.682.1771 | ome "1655 Parti Béachi Lakes’ Bivd.; Suite 500°- West Palrn’Béach, FL'33401 7 “ty HOUSE_OVERSIGHT_012550

sensor & Associates Page 6 Q Okay, go ahead. A The first one was a guy, I'm not sure of his name. And then there's another one that had -- another lady with the victim's rights. fe) She was victim's right representative? A Yes. Q We talked about a lawyer by the name "Marie Villafona;" do you know whether she was present during any of those meetings? A I'm not sure of the name. Q The first time that you met with Nesbith, where did that take place? A Here, in my backyard. Q In your backyard, at your home in Western Palm Beach County, right? A Yes. Q Did she announce to you that she was coming, or did she just show up? A She showed up. Q Unannounced? A Yes. Q During that time, I assume that you told her about your relationship with Jeffrey Epstein and any contact you've had with him, correct? A Correct. nen occ oe Ee roe Ph. 561.682.0905 - Fax. 561.6 ar nt Eg rch ted nb ed ne Mea EEE a aD NE Eh TD 82.1771 "1655 Palfh Beach Lakes’Blvd;, Suité 500°- West ‘Palin Beach, FL’ 33401 “ro HOUSE_OVERSIGHT_012551

nsor & Associates ae ‘Reporting and -Tranzeriptinn, Inc. Page 7 Q Did she tell you anything about whether you were a victim in this case, or anything like that, at that meeting? A Yes, she said I was a victim/witness in this, and that there’s victim rights that I'm entitled to, which include counseling and whatnot. Q Did you tell her, at that time, that you didn't feel that you were a victim at all, and that anything that you've done with Jeffrey Epstein was totally voluntary? A Yeah, I did tell her that everything was, you know, consensual with everything, and I don't agree with anything that's going on. Q Did she try and pressure you into being a victim in this thing, when you were not a victim? A I wouldn't say that she pressured me, but tried to be as convincing as possible. Q Maybe the use of the word "pressure" is too strong. But she was trying to change your opinion of what the relationship was with Jeffrey? A Yes, she was trying to make me feel bad about it, in a way, about what was going on. Q And you didn't feel bad about it, you felt everything was okay, but she was trying to make you feel bad, like something wrong had occurred? rea nena Wenn OE I Te AE wT RES Lee UN Bet Ga ert ETE PROSSER TC RSEIEL EIT ET FCAT S FSD BRT COCO ST ELT SPE EEOC Ph. 561.682.0905 - Fax. 561.682.1771 *"™ 1655 Palm Beach Lakes Blvd.’ Suite 500 - West Palm Beach; FL’33401° °°" **"" HOUSE_OVERSIGHT_012552 i ee a a a

ansor & Associates — + Hepocing ond Trsascrigina, Ine. , Yeah. How long did that meeting go on for? Probably about -- at least an hour. Q When was the next time that you had contact with Nesbith or someone else from law enforcement? A I'm not sure, probably a month or later. I mean, she probably called me and let me know that she was going to -- you know, she wanted to meet sometime soon, to deliver the victim's rights papers to me. Q So there was a time, after you first met, where, despite the fact that you said, I don't consider myself a victim in this, she called you and said, I want to bring you some paperwork that talks about your victim's rights? A Yes, 0) What was your response to her when she told you that? A I told her I would meet with her, 'cause she wanted me to meet with the other woman involved. And they gave them to me. I took them, but I never really told them I needed counseling or anything like that. Q Where did that meeting take place? A I believe it was Panera Bread in Wellington. SESE SBS EES ht SEIT CE EN IIS SSeS TY SES SRC LE ESEES ERE IE TOE LIED D 2 EPR Ph. 561.682.0905 - Fax. 561.682.1771 "1655 Palm Bedch Lakes Blvd.; Suite’500 - West’Palm Beach, FL°'33401°" “te eo HOUSE_OVERSIGHT_012553

oo™ es a snsor & Associates ee ie Heporting and TranseripiinnJow. . - Page 9 |: 0) She actually came and sought you out at a restaurant? A Well, I told her to meet me there. Q Were you working there or were you just -- A No, I was just there. Q So she called you and said, I really, really want to see you. And you said, if you want to see me, meet me at Panera Bread? A Yes. Q Did you feel if you didn't meet her, she wasn't going to go away, that you had to deal with her? A Well, I mean, it wasn't particularly that. I knew that she was going to contact me because of this case. Because, whether I want to be involved or not, I have to be. Q Okay. That's two meetings that I know of. I think you indicated that, if you had to guess, there were maybe a total of five meetings. Are there other meetings that we haven't talked about that occurred? A Yeah, but they were very vague. They weren't anything of importance. And, I mean, it was just her -- or of importance to me, anyway. Would she call you and say, listen, I really, Fax. 561.682.1771 "1655 Palm’Beach Lakes Blvd.; Suité 500 - West’Palm Beath; FI 33401: °°" HOUSE_OVERSIGHT_012554 SE PRET MITE Y OATS TLE SERS OS SM CY TUBB EAT RECITES SE SS ESCNEE E7CSTNAY SSPCESTESSPOOCHOE|

- touch upon the fact that if I need any help or "1655 Palty Beach Lakés Blvd:, Suite’500°- West Palm’ Beach, FL 33401°° "> oT tere nsor & Associates — \ Reporting and Transeription, Jne:. Page 10 : really, want to talk to you about being a victim or -- A It wasn't always directly about being a victim. And, every*time we talked, she would always i so-on-and-so-forth, because I am a victim in this case. 5 Q I assume, based on what you're telling me, you continued to tell her, I'm not a victim? A I just let her say what she said. I never got counseling. But she knows from the beginning, and, I continued to reassure her, that I don't feel that way. Q So, the first time you met with her, when you spent about an hour with her and you went through all your contact with Jeffrey, that's what occurred at that meeting, and she talked to you about being a victim at that meeting? A Yes. Q And then there was this second meeting, where she brought a victim's rights person with her, and that took place at Panera Bread, right? A Yes. Q And you had the same response, listen, you think I'm a victim. You could give me the information, but I don't need that information, right? SEIS TET ERS OR PEATE TS ST DOTS CEE EEE SSCL BPSD AOE TS ONE TOTP OT TEREST Ph, 561.682.0905 - Fax. 561.682.1771 HOUSE_OVERSIGHT_012555

ansor & Associates” ~. henarting onl Transcription, Jvc. - A Right, pretty much. Q And then there were some other contacts. Would she call you and want to talk to you about the specific facts about the case? I mean, why would she contact -- A Yeah, I mean, just to re-question me about certain things, because she wasn't sure that the answers were -~ Q Were those in-person meetings? A I mean, a lot of them were on the phone. mean, it wasn't very often that we would meet. 6) Was there any other time that you did meet? We talked about two times that you actually did meet, once here at your home and once at Panera Bread. Were there any other actual meetings, or did the others occur on the phone? A There were other meetings, but they were, like I said, not really important. Q Do you remember where they were that they took place? A They came to my job, I think, two times. Q When you say "they" -- A Well, it Nesbith the first time, and, the second time, it was the David Copperfield investigators Tape NL OOP SAIS Sant am ETS PF SEL BER DEOL SSE RL ORNS SLE ESN ePIC TEN EASES BLOT AR RELI TN On Py PEE SNES SE CTE SEES SOOTCE OOESDSESET Ba co PAL Lids Evin tea Reda Wonins. a? Boeke Riv Sal WP Re Aen Reeder, Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Bedch Lakes Blvd." Suite’500 - West Palm: Beach, FL’33401" °° HOUSE_OVERSIGHT_012556 ee OE Te

with Nesbith. fo) Right. So, the third time that you met with Nesbith, she came to your job, and she wanted to talk to you about more facts of the case? A Ah-huh. Q And, during that meeting, she also talked to you about your rights as a victim again? 9 A Yeah, she always reassured me of my rights as a victim. Then there would have been a fourth time Q we're talking about now, where there were investigators from Washington coming down, concerning David and Nesbith introduced them to you, Copperfield, correct? 16 A Right. 17 Q I take it what you're telling me is that Nesbith seized the opportunity to talk to you again about being a victim, right? 20 A She always kind of comes out as asking if I'm okay, and if everything okay. And if I ever need any kind of help or anything, with -- you know, I could always have help. listen, I'm fine, Q Did you continue to say, there's no issues here? EERE ES ENS OPS EE RTE CRS aa ENN UE DCCC MESES BESS SNE TEERTOCEE ESOT S BT BTR CENCE TR SEIN PERN ESOP SEES TBC ETL POE ACTER MRSS A SCPTIS TRUELY ZEEE Ph. 561.682.0905 - Fax. 561.682.1771 T655 Palm Beach’ Lakes Bivd-, Suite 500°- West Palit’ Bédch, FL‘33401“*° -"°r* ' HOUSE_OVERSIGHT_012557

Tin Sateen cot ats Reeien OR! “"1655 Palm Beach’Lakes Bivd., Suite’500 - West Palm’ Beach, FL 3340f"" on ens ansor & Associates | PAPAS. deporting and ‘Transcription, ine>: Page 13 A I just -- I mean, I was never pushy on it. I just, like I said, she always knows. I may not tell her every time, but she always knows how I feel about this case. Q Meaning? I don't need anything. Q Meaning that you made it really clear to her that you didn't need any help? A Yeah, from the beginning, I was very, very reassuring about how I felt about it. And I wasn't. very happy. Q All right. I understand. Now, we're about four contacts with Nesbith -- your house, Panera Bread, work, the David Copperfield investigators. A ‘Yaa. Q Were there any other meetings that we have not spoken about? A There may have been like one or two. But they're -- I don't even remember. I mean, those are the ones, like, that remember the most. Q That you really remember, okay. Now, were there other telephone calls that occurred, where, kind of the same kind of conversation would occur? You know, there's help for you and you'd DPS Wa SoM dah cow te ce oi adhe A Sa SEY EBSD EPAPER EIS CEN L ECNO T Sate SCT RIN PETS TE MICS Ph. 561.682.0905 - Fax. 561.682.1771 Tyan Sea ts Panaderia HOUSE_OVERSIGHT_012558

snsor r & Associates Page 14 say, I'm really not a victim here? A Like I said, I was, like, okay. You know, she would always continuously tell me. I mean, but every time, it was the same thing. I mean I was never -- I mean, I was never mean to any of them. I never gave anybody attitude about anything. But, I mean, she knows that. She knows how I feel. Q I think what I hear you saying is that she knows how you feel, and you made it clear to her from the start, that you were not a victim? A Yeah, I mean, she pretty much, does it because that's what she has to do. She has te gortinne to tell me. And, you know, in a way, try to convince me that I am a victim. I just let her say what's she's going to say, and, then, you know, okay, goodbye. Q Do you think that's what she was trying to : do, is try to convince you to change your attitude as H | to how you felt? | A in away, yes. Q Is there anything else that we need to discuss that we haven't talked about? A No, I think that's mostly it. I appreciate your courtesies once again for Darel ee e8 att wa Ce teen aes a Te aa a ln a Si a le i Cia ham a Sa ae ie eee citi OE ad hia Sa Ro Nee eT Tea 2 ac Duper nE RCE Once aceecrerst } Ph. 561.682.0905 - Fax. 561.682.1771 “""1655°Palr Beach Lakés Blvd; Suite "500 -West’Pdlrn Bédth; FI33402"~"" tm ees HOUSE_OVERSIGHT_012559

ed "1655 Palfiv Beach Lakés BIVa:, “Suite 500 -'West' Palni Beach; FL 334047" 8" or en msor & Associates af APIAS Boporing andl Teenseription, Jas. Page 15 seeing me oné more time, and doing this voluntarily. And, thanks so much for making yourself available today: A No problem. Q That will do it -- actually, one more time. Brittany, let me say one more time: Everything you've told me here today is the absolute truth, right? A Yes. Q I haven't tried to convince you to say one thing, one way or the other, have I? A No. All right. That's it. Thank you very much. (Thereupon, the sworn statement was concluded at 6:22 p.m.) Ph. 561.682.0905 - Fax. 561.682.1771 } IEE EET CSCS SEEPS EY EMT ak col SL Rois RED content Gann eres NE Eo a Os see aR ETRE OT EL, . | § t HOUSE_OVERSIGHT_012560

nsor & Associ ates: +. Reporking anal Transcripiiva; Ias.: -.-- a a THE STATE OF FLORIDA COUNTY OF PALM BEACH I, the undersigned authority, certify that > <-sonaity appeared before me on March 26, 2008 and was duly sworn. WITNESS my hand and office seal this 26TH day : of MARCH, 2008. F | | Maria C. Powers, Court Reporter Notary Public - State of Florida | My Commission No. DD149010 | My Commission Expires: 9/10/10 | I Ph. 361. 682. 0905 - Fax. 561. 682. 1771 ) HOUSE_OVERSIGHT_012561

5 nsor & Associates ELS Heporting and-Transcripiiva, Jac. CERTIFICATE The State of Florida County Of Palm Beach I, MARTA C. POWERS, a Shorthand Reporter, State of Florida at Large, do hereby certify that was by me first duly sworn to testify the whole truth; that I was authorized to and did report said deposition in stenotype; and that the foregoing pages, numbered from 1 to 17 inclusive, are a true and correct transcription of my shorthand notes of said deposition. I further certify that said deposition was taken at the time and place hereinabove set forth and that the taking of said proceeding was commenced and completed as hereinabove set out. I further certify that I am not an attorney or counsel of any of the parties, nor am Ia relative or employee of any attorney or counsel of party connected with the action, nor am I financially interested in the action. The foregoing certification of this transcript does not apply to any reproduction of the same by any means, unless under the direct control and/or direction of the certifying reporter. IN WITNESS WHEREOF, I have hereunto set my hand this 26TH day of MARCH, 2008. Maria C. Powers, Notary Public In and for the State of Florida My Commission No. DD149010 My Commission Expires: 9/10 Tenet EN oee ae Eee Sey ee eee EE RCN ITE ERT SPIED PUTT EEC rE Ee Be aN NTS TLE AR AER ern cas a TOR oHA Fca oechch ans pera” Poa APARNA Foe Ph. 561.682.0905 - Fax. 561.682.1771 HOUSE_OVERSIGHT_012562 “"""T655 Palm Beach Lakes Bivd:, Suite 500- Wést Palm Beach, FL'33401 °° “no

sor & Ass ociates r | ring and ‘Tra Jne EEE ST EE EEN COE EEE EY RES RPES REELS SST EES Ph. 561.682.0905 - Fax. 561.682.1771 | HOUSE_OVERSIGHT_012563

Sonne SIPTRTN TD re FS RAST IE SEPT - Ph. 561.682.0905 - Fax. 561.682.1771 : , ome" T6855 Palit’ Beach Lakés Blvd., Suite 500°- West Palm Beach, FL'33401" °°" ~* > me HOUSE_OVERSIGHT_012564

‘ ‘eparting anni 1: r2nzeription, ies - “pee Ph. 561.682.0905 - Fax. 561.682.1771 ome"1655 Paliti Beach Lakes Bivd.,Suité500°-"West Palin’ Beach, Fi 33401 © “nr teeter HOUSE_OVERSIGHT_012565

TAB 16 HOUSE_OVERSIGHT_012566

14/16/2006 16:31 FAX 5618021787 USAO WPB FL 002 U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: (561) 820-6777 November 16, 2006 VIA FACSIMILE Lilly Ann Sanchez, Esq. Fowler White Bumett 1395 Brickell Ave Fl 14 Miami Florida 33131-3300 Re: Jeffrey Epsteim Dear Ms. Sanchez: Thank you for your letter and voicemail. 1 will plan to direct all correspondence fo you unless you provide other instructions. In tum, please direct all future communications with the Office to my attention. As I mentioned in my voicemail, Mr. Lewis stated that Mr. Epstein is willing to provide documents and information that we deem necessary to the investigation. I would appreciate if you would forward the documents and information Listed below to my attention or, if you prefer, to Special Agent E. Nesbitt Kuyrkendall, Federal Bureau of Investigation, 500 South Flagler Drive, Suite 500, West Palm Beach, FL 33404. If yourequire a grand jury subpoena for any of the items, please let me know. i, Documentation related to the ownership of the property located at 358 El Brilio Way, Palm Beach, Florida, including the purchase agreement and any mortgages, liens, or other encumbrances. 2. Documentation related to the ownership of Gulfstream Aircraft NS09JE, Model G1159B, and Boeing Airctaft N908JE, Model 727-31, including purchase information, lease agreements, liens or other encumbrances, and payments for maintenance and storage. 3. All documents and information provided to the Palm Beach County State Attomey’s Office in connection with its investigation of Mr. Epstein. 4. Bank information, account numbers, bank statements and billing statements for any bank accounts and/ot credit cards used by Mr. Epstein (or any of his employees) to pay for Mr. Epstein’s personal expenses, from January 1, 2004 to the present. 00269 HOUSE_OVERSIGHT_012567

11/16/2008 16:31 FAX 5618021787 USAO WPB FL (003 LILLy ANN SANCHEZ, ESQ. NOVEMBER 16, 2006 PAGE 20F 3 5. Information and billing statements for any “fand lines,” cellular telephones, Blackberry units, e-mail addresses, webpages, or the like for Mr. Epstei and all of - his personal assistants (including but not Hmited to [J and from January 1, 2004 to the present. 6. The computers, hard drives, CPUs, and any other computer media (including CD- ROMs, DVDs, floppy disks, flash drives, etc.) removed from 358 El Brillo Way, Palm Beach, Florida prior to the execution of the search warrant at that premises in October 2005. 7. Al! calendars, diaries, and address books kept by Mr. Epstein and alll of his personal assistants from January 1, 2004 to the present, including electronic calendars and _ address books, whether stored on computer, PDA, or cellular telephone. g. For persons in his employ at any time from January 1, 2004 to the present, employment and/or separation agreements between Mr. Epstein (or his company) and his personal assistants, airplane pilots, personal chefs, and for anyone who worked at 358 El Brillo Way, Palm Beach, Florida. 9. The names and contact information of all persons who performed “massage services” for Mr. Epstein at 358 El Brillo Way, Palm Beach, Florida or at his residences in New Albany, Ohio, Little St. James, U.S.V.I, and New York, NY; and documentation of payments made to or gifts given to any such persons, 10. Wageand earnings statements and other tax documents forall individuals referenced in items (8) and (9), supra. 11. Mr, Epstein’s tax retums for 2004 and 2005. 12. From January 1, 2004, to the present, flight manifests and passenger lists for travel via Gulfstream Aircraft N9O9JE, Model G1159B and Boeing Aircraft N9OSJE, Model 727-31 (to the extent not already provided). 13. Documentation regarding any other interstate or interational travel undertaken by Mr. Epstein from January 1, 2004, to the present, including but not limited to aisplane tickets, car rental records, and hotel receipts. After I have a chance to review the documents, I will contact you to set up a time to interview Mr. Epstein. 00270 HOUSE_OVERSIGHT_012568

14/16/2008 18:32 FAX 5618021787 USAC WPB FL oo LILLY ANN SANCHEZ, ESQ. NOVEMBER 16, 2006 PAGE 3 OF3 Thank you for your assistance with this matter, and I look forward to working with you and Mr. Lefcourt. Sincerely, R. Alexander Acosta United States Attorney 5 4 By: e A. Marie Villafatia Assistant United States Attorney HOUSE_OVERSIGHT_012569

TAB 17 HOUSE_OVERSIGHT_012570

. JUN-26~-26@7 11:18 FRI WEST PALM BEACH RA P.@L FU-448 (Kev. -2-¥/) FBI FACSIMILE F COVER SHEET PRECEDENCE CLASSIPICATION 1 immediate LJ Top Seeret Time Transmitted: CI Priority LI Secret Sender's Initials: jxr Routine CJ Confidential Number of Pages: _ 5 ; C1 Sensitive (including cover sheet) IX] Unclassified ; To: William Riley Date: 06/20/2007 Name of Office Facsimile Number. 954-905-4922 Attn: . Name | Room Telephone « . From: FBI Name of Office Subject: Service of Federal Grand Jury Subpoenas Special Handling Instructions: Originator's Name: SA Jason Richards Telephone: 561-833-7517 Originator's Facsimile Number: 561-833-7970 Approved: Brief Description of Communication Faxed: Two subpoenas: 1) William Riley and 2) Custodian of Records, Riley Kiraly . WARNING ( Informotion attached fo the cover sheet is U.S. Goverment Property. If you arc not the intended recipient of this information, disclosure, reproduction, distribution, ot use of this information is prohibited (18.USC, § 641), Please notily the ~ . originator or the local FBI Office immediately to arrange for proper disposition. ‘ HOUSE_OVERSIGHT_012571

JUN-28-2607 11:18 FBI WEST PALM BEACH RA P.@2 United States District Court SOUTHERN DISTRICT OF FLORIDA TO: | Custodian of Records | SUBPOENA TO TESTIFY Riley Kiraly BEFORE GRAND JURY Commercial Center of Miami Miami, FL 33015 SUBPOENA FOR: PERSON DOCUMENTS OR OBJECTIS} ‘YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District Court at the place, date and time specified below. ROOM: Grand Jury Room PLACE: United States District Courthouse 70] Clematis Street West Palin Beach, Florida 33401 DATE AND TIME: July 10, 2007 100 pm* YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s): THE DOCUMENTS AND OBJECTS LISTED ON ATTACHMENT A. *Please coordinate your compliance with this subpoena and confirm the date, time, and location of your appearance with S/A Nesbitt Kuyrkendall, Federal Bureau of Investigation, Telephone: (561) 822-5946. This subpoena shall remain in effect until you are granted Jeave to depart by the court or by an officer acting on behalf of the court. June 18, 2007 (BY) DEPUTY CLERK Name, Address and Phone Number of Assistant U.S, Attomey Aun Marie C, Villafaiia, Assistant U.S. Anomey . 500 So. Australian Avenve, Suite 400 West Palm Beach, FL 33401-6235 Tel: (561) 820-8711 x3047. Fax; (561) 802-1787 To be uset in Bon of ADLIO FORM ORD-237 ‘ JAN.86 Thie subpoena is issued wpon application of tha United States of America *)f not applicable, enter “none.” HOUSE_OVERSIGHT_012572

‘JUN-26-2007 11:19 FBI WEST PALM BEACH RA P.@3 ATTACHMENT A SUBPOENA TO PAUL A. LAVERY I, Al} computer equipment and electronic storage media removed from the residence located at 358 El Brillo Way, Palm Beach, Florida, including but not limited to central processing units (“CPUs”), laptop computers, keyboards, printers, modems, routers, hard drives, flash drives, thumb drives, CD-Roms, DVDs, floppy diskettes, digital cameras, and memory cards. 2, All computer equipment and electronic storage media that currently belongs to, or has ever belonged to, Jeffrey Epstein, inchiding but not limited to ceniral processing units (“CPUs”), laptop computers, keyboards, printers, modems, routers, hard drives, flash drives, thumb drives, CD-Roms, DVDs, floppy diskettes, digital cameras, and memory cards. 3. All documents and information related to the nature of the selationship between Mr. William Riley and/or Riley Kiraly and Mr. Jeffrey Epstein, including, but not limited to, retainer agreements; employment agreements; ' billing statements (whether submitted directly to Mr. Epstein or to a third party for reimbursement); records of the dates when services were performed and the hours worked; telephone logs or records of dates of communications with Mr. Epstem {or with a third party on Mr. Epstein’s behalf); appointment calendars/datebooks and the like (whether in hard copy or electronic form) for any period when work was performed on behalf of Mr, Epstein or when any communication was had with Mr. Epsiem (or with a third party on Mr. Epstein’s behalf); and records of fee arrangements and payments received for work performed on Mr, Epstein’s behalf, HOUSE_OVERSIGHT_012573

JUN-28-2687 14:19 _ FBI WEST PALM BEACH RA P.@4 United States District Court SOUTHERN DISTRICT OF FLORIDA TO: William Riley SUBPOENA TO TESTIFY Raley raly BEFORE GRAND JURY Commercial Center of Miami Miami, FL 33015 SUBPOENA FOR: PERSON DOCUMENTS OR OBJECTS] YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury ofthe United States District Court at the place, date and time specified below. ROOM: Grand Jury Room PLACE: United States District Courthouse 701 Clematis Street West Palm Beach, Florida 33401 DATE AND TIME: ’ ‘July 10, 2007 1:00 pm* YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s): THE DOCUMENTS AND OBJECTS LISTED ON ATTACHMENT A. *Please coordinate your compliance with this subpoena and confirm the date, time, and location of your appearance with S/A Nesbitt Kuyrkendall, Federal Bureau of Investigation, Telephone: (361) 822-5946. This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf of the court. June 18, 2007 " (BY) DEPUTY CLERK Name, Address and Phone Number of Assiatant U.S. Attormey Ann Marie C, Villafafiz, Assistant U.S. Attomey 500 So. Australian Avenue, Suite 400 West Paim Beach, FL 33401-6235 Tel: (561) 820-8721 23047 Fax: (561) 802-1787 *I{ noi anpligabls, enter “none.” ; Tobe nsed in Tits of AQUIO : , FORM OR[TR227 JAn_B6 This subpoena is issued upon application ofthe United States of America HOUSE_OVERSIGHT_012574

JUN-20-2007 «11:19 FBI WEST PALM BEACH RA P.@5 ATTACHMENT A SUBPOENA TO PAUL A. LAVERY 1. All computer equipment and electronic storage media removed from the residence located at 358 E] Brillo Way, Palm Beach, Florida, including but not limited to central processing units (“CPUs”), laptop computers, keyboards, ‘printers, modems, routers, hard drives, flash drives, thumb drives, CD-Roms, DVDs, floppy diskettes, digital cameras, and memory cards. 2. All computer equipment and electronic storage media that currently belongs to, or has ever belonged to, Jeffrey Epstein, including but not limited to central processing units (“CPUs”), laptop computers, keyboards, printers, modems, routers, hard drives, flash drives, thumb drives, CD-Roms, DVDs, ie diskettes, digital cameras, and memory cards. 3, All documents and information:related to the nature of the relationship between Mr. William Riley and/or Riley Kiraly and Mr. Jeffrey Epstein, including, but not limited to, retainer agreements; employment agreements; _ billing statements (whether submitted directly to Mr, Epstein or to a third party for reimbursement); records of the dates when services were performed and the hours worked; telephone logs or records of dates of communications with Mr. Epstem (or with a third party on Mr. Epstein’s behalf); appointment calendars/datebooks and the like (whether in hard copy or electronic form) for any period when work was performed on behalf of Mr, Epstein or when any communication was had with Mr. Epstein (or with a third party on Mr. Epstein’s behalf); and records of fee arrangements and payments Teceived for work performed on Mr, Epstein’s behalf, TOTAL P.@5 HOUSE_OVERSIGHT_012575

TAB 18 HOUSE_OVERSIGHT_012576

\ is U.S. Department of Justice United States Attorney Southern District of Florida 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: (561) 820-8777 December 13, 2007 DELIVERY BY ELECTRONIC MAIL Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP Citigroup Center 153 East 53rd Street New York, New York 10022-4675 Re: Jeffrey Epstein Dear Jay: Tam writing not to respond to your asserted “policy concerns” regarding Mr. Epstein’ s Non- Prosecution Agreement, which will be addressed by the United States Attorney, but the time has come for me to respond to the ever-increasing attacks on my role in the investigation and negotiations. It is an understatement to say that I am surprised by your allegations regarding my role because I thought that we had worked very well together in resolving this dispute. I also am surprised because I feel that I bent over backwards to keep in mind the effect that the agreement would have on Mr. Epstein and to make sure that you (and he) understood the repercussions of the agreement. For example, I brought to your attention that one potential plea could result in no gain time for your client; I corrected one of your calculations of the Sentencing Guidelines that would have resulted in Mr. Epstein spending far more time in prison than you projected; I contacted the Bureau of Prisons to see whether Mr. Epstein would be eligible for the prison camp that you desired; and I told you my suspicions about the source of the press “leak” and suggested ways to avoid the press. Importantly, I continued to work with you in a professional manner even after I learned that you had been proceeding in bad faith for several weeks — thinking that I had incorrectly concluded that solicitation of minors to engage in prostitution was a registrable offense and that you would “fool” our Office into letting Mr. Epstein plead to a non-registrable offense. Even now, when it is clear that neither you nor your client ever intended to abide by the terms of the agreement that he signed, I have never alleged misconduct on your part. The first allegation that you raise is that I “assiduously” hid from you the fact that Bert Ocariz is a friend of my boyfriend and that I have a “longstanding relationship” with Mr. Ocariz. HOUSE_OVERSIGHT_012577

JAY P. LEFKOWITZ, Eso. DECEMBER 13, 2007 PAGE 2 OF 5 I informed you that I selected Mr. Ocariz because he was a friend and classmate of two people whom I respected, and that I had never met or spoken with Mr. Ocariz prior to contacting him about this case. All of those facts are true. I still have never met Mr. Ocariz, and, at the time that he and I spoke about this case, he did not know about my relationship with his friend. You suggest that I should have explicitly informed you that one of the referrals came from my “boyfriend” rather than simply a “friend,” which is the term I used, but it is not my nature to discuss my personal relationships with opposing counsel. Your attacks on me and on the victims establish why I wanted to find someone whom I could trust with safeguarding the victims’ best interests in the face of intense pressure from an unlimited number of highly skilled and well paid attorneys. Mr. Ocariz was that person. One of your letters suggests a business relationship between Mr. Ocariz and my boyfriend. This is patently untrue and neither my boyfriend nor I would have received any financial benefit from Mr. Ocariz’s appointment. Furthermore, after Mr. Ocariz learned more about Mr. Epstein’ s actions (as described below), he expressed a willingness to handle the case pro bono, with no financial benefit even to himself. Furthermore, you were given several other options to choose from, including the Podhurst firm, which was later selected by Judge Davis. You rejected those other options. You also allege that I improperly disclosed information about the case to Mr. Ocariz. I provided Mr. Ocariz with a bare bones summary of the agreement’ s terms related to his appointment to help him decide whether the case was something he and his firm would be willing to undertake. I did not provide Mr. Ocariz with facts related to the investigation because they were confidential and instead recommended that he “Google” Mr. Epstein’s name for background information. When Mr. Ocariz asked for additional information to assist his firm in addressing conflicts issues, I forwarded those questions to you, and you raised objections for the first time. I did not share any further information about Mr. Epstein or the case. Since Mr. Ocariz had been told that you concurred in his selection, out of professional courtesy, I informed Mr. Ocariz of the Office's decision to use a Special Master to make the selection and told him that the Office had made contact with Judge Davis. We have had no further contact since then and I have never had contact with Judge Davis. I understand from you that Mr. Ocariz contacted Judge Davis. You criticize his decision to do so, yet you feel that you and your co-counsel were entitled to contact Judge Davis to try to “lobby” him to select someone to your liking, despite the fact that the Non-Prosecution Agreement vested the Office with the exclusive right to select the attorney representative. Another reason for my surprise about your allegations regarding misconduct related to the Section 2255 litigation is your earlier desire to have me perform the role of “facilitator” to convince the victims that the lawyer representative was selected by the Office to represent their interests alone and that the out-of-court settlement of their claims was in their best interests. You now state that doing the same things that you had asked me to do earlier is improper meddling in civil litigation. Much of your letter reiterates the challenges to Detective Recarey’s investigation that have HOUSE_OVERSIGHT_012578

JAY P. LEFKOWITZ, Eso. DECEMBER 13, 2007 PAGE 3 OF 5 already been submitted to the Office on several occasions and you suggest that I have kept that information from those who reviewed the proposed indictment package. Contrary to your suggestion, those submissions were attached to and incorporated in the proposed indictment package, so your suggestion that I tried to hide something from the reviewers is false. I also take issue with the duplicity of stating that we must accept as true those parts of the Recarey reports and witness statements that you like and we must accept as false those parts that you do not like. You and your co-counsel also impressed upon me from the beginning the need to undertake an independent investigation. It seems inappropriate now to complain because our independent investigation uncovered facts that are unfavorable to your client. You complain that I “forced” your client and the State Attorney's Office to proceed on charges that they do not believe in, yet you do not want our Office to inform the State Attorney’ s Office of facts that support the additional charge nor do you want any of the victims of that charge to contact Ms. Belohlavek or the Court. Ms. Belohlavek’s opinion may change if she knows the full scope of your client’s actions. You and I spent several weeks trying to identify and put together a plea to federal charges that your client was willing to accept. Yet your letter now accuses me of “manufacturing” charges of obstruction of justice, making obscene phone calls, and violating child privacy laws. When Mr. Lourie told you that those charges would “embarrass the Office,” he meant that the Office was unwilling to bend the facts to satisfy Mr. Epstein’s desired prison sentence — a statement with which I agree. I hope that you understand how your accusations that I imposed “ultimatums” and “forced” you and your client to agree to unconscionable contract terms cannot square with the true facts of this case. As explained in letters from Messrs. Acosta and Sloman, the indictment was postponed for more than five months to allow you and Mr. Epstein’s other attorneys to make presentations to the Office to convince the Office not to prosecute. Those presentations were unsuccessful. As you mention in your letter, I -a simple line AUSA ~ handled the primary negotiations for the Office, and conducted those negotiations with you, Ms. Sanchez, Mr. Lewis, and a host of other highly skilled and experienced practitioners. As you put it, your group has a “combined 250 years experience” to my fourteen. The agreement itself was signed by Mr. Epstein, Ms. Sanchez, and Mr. Lefcourt, whose experience speaks for itself. You and I spent hours negotiating the terms, including when to use “a” versus “the” and other minutiae. When you and I could not reach agreement, you repeatedly went over my head, involving Messrs. Lourie, Menchel, Sloman, and Acosta in the negotiations at various times. In any and all plea negotiations the defendant understands that his options are to plead or to continue with the investigation and proceed to trial. Those were the same options that were proposed to Mr. Epstein, and they are not “persecution or intimidation tactics.”. Mr. Epstein chose to sign the agreement with the advice of a multitude of extremely noteworthy counsel. You also make much of the fact that the names of the victims were not released to Mr. Epstein prior to signing the Agreement. You never asked for such a term. During an earlier meeting, where Mr. Black was present, he raised the concern that you now voice. Mr. Black and I did not have a chance to discuss the issue, but I had already conceived of a way to resolve that HOUSE_OVERSIGHT_012579

JAY P. LEFKOWITZ, Eso. DECEMBER 13, 2007 PAGE 4 OF 5 issue if it were raised during negotiations. As I stated, it was not, leading me to believe that it was not a matter of concern to the defense. Since the signing of the Non-Prosecution Agreement, the agents and I have vetted the list of victims more than once. In one instance, we decided to remove a name because, although the minor victim was touched inappropriately by Mr. Epstein, we decided that the link to a payment was insufficient to call it “prostitution.” 1 have always remained open to a challenge to the list, so your suggestion that Mr. Epstein was forced to write a blank check is simply unfounded. Your last set of allegations relates to the investigation of the matter. For instance, you claim that some of the victims were informed of their right to collect damages prior to a thorough investigation of their allegations against Mr. Epstein. This also is false. None of the victims was informed of the right to sue under Section 2255 prior to the investigation of the claims. Three victims were notified shortly after the signing of the Non-Prosecution Agreement of the general terms of that Agreement. You raised objections to any victim notification, and no further notifications were done. Throughout this process you have seen that I have prepared this case as though it would proceed to trial. Notifying the witnesses of the possibility of damages claims prior to concluding the matter by plea or trial would only undermine my case. If my reassurances are insufficient, the fact that not a single victim has threatened to sue Mr. Epstein should assure you of the integrity of the investigation.' ‘There are numerous other unfounded allegations in your letter about document demands, the money laundering investigation, contacting potential witnesses, speaking with the press, and the like. For the most part, these allegations have been raised and disproven earlier and need not be readdressed. However, with respect to the subpoena served upon the private investigator, contrary to your assertion, and as your co-counsel has already been told, I did consult with the Justice Department prior to issuing the subpoena and I was told that because I was not subpoenaing an attorney’s office or an office physically located within an attorney's office, and because the business did private investigation work for individuals (rather than working exclusively for Mr. Black), I could issue a grand jury subpoena in the normal course, which is what I did. I also did not “threaten” the State Attorney's Office with a grand jury subpoena, as the correspondence with their grand jury coordinator makes perfectly clear. With regard to your allegation of my filing the Palm Beach Police Department’s probable cause affidavit “with the court knowing that the public could access it,” I do not know to what you are referring. All documents related to the grand jury investigation have been filed under seal, and the Palm Beach Police Department’s probable cause affidavit has never been filed with the Court. If, in fact, you are referring to the Ex Parte Declaration of Joseph Recarey that was filed in response to the motion to quash the grand jury subpoena, it was filed both under seal and ex parte, so no one should have access to it except the Court and myself. Those documents are still in the Court file only because you have violated one of the terms of the Agreement by failing to “withdraw [Epstein’s] pending motion to intervene and to quash certain grand jury subpoenas.” HOUSE_OVERSIGHT_012580

JAY P. LEFKOWITZ, Eso. DECEMBER 13, 2007 PAGE 5 OF 5 With respect to Ms. Miller, I contacted her attorney - who was paid for by Mr. Epstein and was directed by counsel for Mr. Epstein to demand immunity — and asked only whether he still represented Ms. Miller and if he wanted me to send the victim notification letter to him. He asked what the letter would say and I told him that the letter would be forthcoming in about a week and that I could not provide him with the terms. With respect to Ms. Miller’s status as a victim, you again want us to accept as true only facts that are beneficial to your client and to reject as false anything detrimental to him. Ms. Miller made a number of statements that are contradicted by documentary evidence and a review of her recorded statement shows her lack of credibility with respect to anumber of statements. Based upon all of the evidence collected, Ms. Miller is classified as a victim as defined by statute. Of course, that does not mean that Ms. Miller considers herself a victim or that she would seek damages from Mr. Epstein. I believe that a number of the identified victims will not seek damages, but that does not negate their legal status as victims. I hope that you now understand that your accusations against myself and the agents are unfounded. In the future, I recommend that you address your accusations to me so that I can correct any misunderstandings before you make false allegations to others in the Department. I hope that we can move forward with a professional resolution of this matter, whether that be by your client’s adherence to the contract that he signed, or by virtue of a trial. Sincerely, R. Alexander Acosta United States Attorney By: s/A. Marie Villafaria A. Marie Villafafia Assistant United States Attorney cc: — R. Alexander Acosta, U.S. Attorney Jeffrey Sloman, First Assistant U.S. Attorney You also accuse me of “broaden[ing] the scope of the investigation without any foundation for doing so by adding charges of money laundering and violations of amoney transmitting business to the investigation.” Again, I consulted with the Justice Department’s Money Laundering Section about my analysis before expanding that scope. The duty attorney agreed with my analysis. HOUSE_OVERSIGHT_012581

TAB 19 HOUSE_OVERSIGHT_012582

AO110 (Rev. 04/07) Subpoena tn Testify Before Grand Jury 7 . ; cose UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA TO: P| SUBPOENA TO TESTIFY BEFORE.GRAND JURY FGJ 07-103 (WPB)-Tues. No. OLY-85/1 SUBPOENA FOR: W PERSON © DOCUMENT(S) OR OBJECTIS) YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District Court at the place, date, and time specified below. “[GOURTROOM Grand Jury Room United States District Court | 701 Clematis Street . [BATEAND TIME West Palm Beach, Florida 33401 7/1/2008 10:30 am YOU ARE.ALSO COMMANDED to bring with you the following document(s) or object(s):* ALL DOCUMENTS AND INFORMATION REFERENCED IN THE ATTACHMENT TO THIS SUBPOENA. O Please see additional Information on revi jf This subpoena shall remain in ef{¢pi-uspt? behalf of the court. a “By dem Cee | "T NAME. ADDRESS AND PHONE NUMBER OF ASSISTANT US. ATTORNEY Ann Marie C. Villafafia, Assistant U.S. Attorney ie 1500 South Australian Avenue, Suite 400 + West Palm Beach, Florida 33401-6235 | Tel: (561) 820-8711, ext 3047 * if not applicable, enter “none”. | HOUSE_OVERSIGHT_012583

ATTACHMENT TO GRAND JURY SUBPOENA OLY-85/1 ADDRESSED TO PLEASE BRING THE FOLLOWING DOCUMENTS, ITEMS, AND INFORMATION WITH YOU TO YOUR GRAND JURY APPEARANCE: l. Any and.all notes, letters, cards, gifts, payments, photographs, or other items that you have received from Jeffrey Epstein, MM Lesley Groff, Ghislaine Maxwell, and/or any other employee or associate of Jeffrey Epstein. 2. Any. and all photographs, whether printed or digital, of Jeffrey Epstein, i Se Lesley Groff, Ghislaine Maxwell, and/or any other employee or associate of Jeffrey Epstein. 3, Any and all e-mails, instant messages, chats, text messages, voicemails, or telephone messages that_you_have sent_to_and/or received from Jeffrey Epstein, | — es Lesley Groff, Ghislaine Maxwell, and/or any other t employee or associate of J effrey Epstein. 4, A list of all telephone numbers (cellular and “land line”), e-mail addresses, screen names, addresses, and any other contact information that you have for the following persons during the period of January 1, 2003 to the present: a yourself: b Jeffrey Epstein; c d. €. g Lesley Groff; h Ghislaine Maxwell; i. any person(s) who introduced you to Jeffrey Epstein and/or Ghislaine Maxwell; ‘ j. any person(s) whom you introduced to Jeffrey Epstein and/or Ghislaine Maxwell; k, any person(s) who communicated with you to arrange appointments to. meet with Jeffrey Epstein and/or Ghislaine Maxwell. 5, Any billing statements for telephone service (cellular and “land line”) for any telephone you used during the period of January 1, 2003 to the present. HOUSE_OVERSIGHT_012584

TAB 20 HOUSE_OVERSIGHT_012585

CONFIDENTIAL PLEA NEGOTIATIONS TERMS OF EPSTEIN NON-PROSECUTION AGREEMENT Epstein pleads guilty (not nolo contendere) to an Information filed by the Palm Beach County State Attorney’s Office charging him with: (a) lewd and lascivious battery on a child, in violation of FI. Stat. 800.04(4); (b) solicitation of minors to érigage in prostitution, in violation of Fl. Stat. 796.03; and (c) engaging in sexual activity with minors at least sixteen years of age, in violation of Fl. Stat. 794.05. Epstein and the State Attorney’s Office make a joint, binding dation that E in pri Epstein agrees to waive all challenges to the information filed by the State and the right to appeal. Epstein agrees that, if any of the victims identified in the federal investigation file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the U.S. District Court for the Southern District of Florida over his person and the subject matter. Epstein will not contest that the identified victims are persons who, while minors, were victims of violations of Title 18, United States Code, Sections(s) 2422 and/or 2423. After Epstein enters his state court plea and is sentenced, the FBI and the U.S, Attorney’s Office will close their investigations into violations of 18 UIS.C. §§ 1591, 2422, and 2423, HOUSE_OVERSIGHT_012586

Each count of §§ 1591, 2422(b) and 2423(6): Base Offerise Level under 261.3: 24 Offense-invelved sexual ‘contact: +2 Counts-do not group;'s6.add'5. [évels-for more:than 5 units, pursnant'te 3D 1.4. Offense Lével 31 Apply Repeat atid: Dangerous Sex Offender against Minors enhanoeriéitt af 4B1.5 ‘Total Offense Level 36 Assuring Criniinal History Category I, advisory guideline range is 188 - 235 months with lifetime supervised release, HOUSE_OVERSIGHT_012587

TAB 21 HOUSE_OVERSIGHT_012588

IN RE: INVESTIGATION OF JEFFREY EPSTEIN / NON-PROSECUTION AGREEMENT IT APPEARING that the City of Palm Beach Police Department and the State Attorney’s Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, the “State Attorney’s Office”) have conducted an investigation into the conduct of Jeffrey Epstein (hereinafter “Epstein”); IT APPEARING that the State Attorney’s Office has charged Epstein by indictment with solicitation of prostitution, in violation of Florida Statutes Section 796.07; IT APPEARING that the United States Attorney’s Office and the Federal Bureau of Investigation have conducted their own investigation into Epstein’s background and any offenses that may have been committed by Epstein against the United States from in or around 2001 through in or around September 2007, including: (1) knowingly and willfully conspiring with others known and unknown to commit an offense against the United States, that is, to use a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution, in violation of Title 18, United States Code, Section 2422(b); all in violation of Title 18, United States Code, Section 371; (2) knowingly and willfully conspiring with others known and unknown to travel in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18, United States Code, Section 2423(b); all in violation of Title 18, United States Code, Section 2423(e); (3) using a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2; (4) traveling in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(8), with minor females; in violation Page | of 7 HOUSE_OVERSIGHT_012589

of Title 18, United States Code, Section 2423(b); and (5) knowingly, in and affecting interstate and foreign commerce, recruiting, enticing, and obtaining by any means a person, knowing that the person had not attained the age of 18 years and would be caused to engage in a commercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title 18, United States Code, Sections 1591(a)(1) and 2; and TT APPEARING that Epstein seeks to resolve globally his state and federal criminal liability and Epstein understands and acknowledges that, in exchange for the benefits provided by this agreement, he agrees to comply with its terms, including undertaking certain actions with the State Attorney’s Office; IT APPEARING, after an investigation of the offenses and Epstein's background by both State and Federal law enforcement agencies, and after due consultation with the State Attorney's Office, that the interests of the United States, the State of Florida, and the Defendant will be served by the following procedure; THEREFORE, on the authority of R. Alexander Acosta, United States Attomey for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the following conditions and the requirements of this Agreement set forth below. If the United States Attorney should determine, based on reliable evidence, that, during the period of the Agreement, Epstein willfully violated any of the conditions of this Agreement, then the United States Attorney may, within ninety (90) days following the expiration of the term of home confinement discussed below, provide Epstein with timely notice specifying the condition(s) of the Agreement that he has violated, and shall initiate its prosecution on any offense within sixty (60) days’ of giving notice of the violation. Any notice provided to Epstein pursuant to this paragraph shall be provided within 60 days of the United States learning of facts which may provide a basis for a determination of a breach of the Agreement. After timely fulfilling all the terms and conditions of the Agreement, no prosecution for the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney’s Office, nor any offenses that arose from the Federal Grand Jury investigation will be instituted in this District, and the charges against Epstein if any, will be dismissed. Page 2 of 7 HOUSE_OVERSIGHT_012590

Terms of the Agreement: 1, Epstein shall plead guilty (not nolo contendere) to the Indictment as currently pending against him in the 15th Judicial Circuit in and for Palm Beach County (Case No. 2006-cf-009495AXXXMB) charging one (1) count of solicitation of prostitution, in violation of Fl. Stat. § 796.07. In addition, Epstein shall plead guilty to an Information filed by the State Attorney’s Office charging Epstein with an offense that requires him to register as a sex offender, that is, the 3 in violation of Florida Statutes Section 796.03 2. Epstein shall make a binding recommendation that the Court impose a thirty (0) month sentence to be divided as follows: (a) (b) Epstein shall be sentenced to a term of twelve (12) months of community control consecutive to his two terms in county jail as described in Term 2(a), supra. 3. This agreement is contingent upon a Judge of the 15th Judicial Circuit accepting and executing the sentence agreed upon between the State Attorney’s Office and Epstein, the details of which are set forth in this agreement. 4. The terms contained in paragraphs 1 and 2, supra, do not foreclose Epstein and the State Attorney’s Office from agreeing to recommend any additional charge(s) or any additional term(s) of probation and/or incarceration. 5. Epstein shall waive all challenges to the Information filed by the State Attorney’s Office and shall waive the right to appeal his conviction and sentence, except a sentence that exceeds what is set forth in paragraph (2), supra. 6. Epstein shall provide to the U.S. Attomey’s Office copies of all Page 3 of 7 HOUSE_OVERSIGHT_012591

10. 11. proposed agreements with the State Attorney’s Office prior to entering into those agreements. The United States shall provide Epstein’s attorneys with a list of Pi through that representative. If any of the individuals referred to in paragraph (7), supra, elects to file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the United States District Court for the Southern District of Florida over his person and/or the subject matter, an Pp exclusively under 18 U.S.C. § 2255, and agrees to waive any other claim for damages, whether pursuant to state, federal, or common law. Notwithstanding this waiver, as to those individuals whose names appear on the list provided by the United States, Epstein’s signature on this agreement, his waivers and failures to contest liability and such damages in any suit are not to be construed as an admission of any criminal or civil liability. Epstein’s signature on this agreement also is not to be construed as an admission of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person whose name does not appear on the list provided by the United States. Except as to those individuals who elect to proceed exclusively under 18 U.S.C. § 2255, as set forth in paragraph (8), supra, neither Epstein’s signature on this agreement, nor its terms, nor any resulting waivers or settlements by Epstein are to be construed as admissions or evidence of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person, whether or not her name appears on the list provided by the United States. Epstein shall use his best efforts to enter his guilty plea and be Page 4 of 7 HOUSE_OVERSIGHT_012592

sentenced not later than October 26, 2007. The United States has no objection to Epstein self-reporting to begin serving his sentence not later than January 4, 2008. 12. _ Epstein agrees that he will not be afforded any benefits with respect to gain time, other than the rights, opportunities, and benefits as any other inmate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States’ request, Epstein agrees to provide an accounting of the gain time he eared during his period of incarceration. 13. The parties anticipate that this agreement will not be made part of any public record. If the United States receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before making that disclosure. Epstein understands that the United States Attorney has n In consideration of Epstein’s agreement to plead guilty and to provide compensation in the manner described above, if Epstein successfully fulfills all of the terms and conditions of this agreement, the United States also agrees that it will not institute any criminal an against any potential co-conspirators of Epstein, including but not limited to | Lesley Groff, or nn Further, upon execution of this agreement and a plea agreement with the State Attorney’s Office, the federal Grand Jury investigation will be suspended, and all pending federal Grand Jury subpoenas will be held in abeyance unless and until the defendant violates any term of this agreement. The defendant likewise agrees to withdraw his pending motion to intervene and to quash certain. grand jury subpoenas. Both parties agree to maintain their evidence, specifically evidence requested by or directly related to the grand jury subpoenas that have been issued, and including certain computer equipment, inviolate until all of the terms of this agreement have been satisfied. Upon the successful completion of the terms of this agreement, all outstanding grand jury subpoenas shall be deemed withdrawn. Page 5 of 7 HOUSE_OVERSIGHT_012593

ao By signing this agreement, Epstein asserts and certifies that each of these terms is material to this agreement and is supported by independent consideration and that a breach of any one of these conditions allows the United States to elect to terminate the agreement and to investigate and prosecute Epstein and any other individual or entity for any and all federal offenses. , By signing this agreement, Epstein asserts and certifies that he is aware of the fact that the Sixth Amendment to the Constitution of the United States provides that in all criminal prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court may dismiss an indictment, information, or complaint for unnecessary delay in presenting a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein hereby requests that the United States Attorney for the Southern District of Florida defer such prosecution, Epstein agrees and consents that any delay from the date of this Agreement to the date of initiation of prosecution, as provided for in the terms expressed herein, shall be deemed to be a necessary delay at his own request, and he hereby waives any defense to such prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the United States to a speedy trial or to bar the prosecution by reason of the running of the statute of limitations for a period of months equal to the period between the signing of this agreement and the breach of this agreement as to those offenses that were the subject of the grand jury’s investigation. Epstein further asserts and certifies that he understands that the Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all felonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees and consents that, if a prosecution against him is instituted for any offense that was the subject of the grand jury’s investigation, it may be by way of an Information signed and filed by the United States Attorney, and hereby waives his right to be indicted by a grand jury as to any such offense. //T- /fl /f] Page 6 of 7 HOUSE_OVERSIGHT_012594

By signing this agreement, Epstein asserts and certifies that the above has been read and explained io him, Epstein hereby states that he understands the conditions of this Non- Prosecution Agreement and agrees to comply with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: By: A. MARIE VILLAFANA ASSISTANT U.S. ATTORNEY Dated: vA i La Dated: GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN Dated: LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 HOUSE_OVERSIGHT_012595

By signing this agreement, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the conditions of this Non- Prosecution Agreement and agrees to comply with them. Dated: Dated: Dated: 9 [> 07 Dated: R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: A. MARIE VILLAFANA ASSISTANT U.S. ATTORNEY COUNSEL TONE FFREY EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 HOUSE_OVERSIGHT_012596

By signing this agreement, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the conditions of this Non- Prosecution Agreement and agrees to comply with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: By: A. MARIE VILLAFANA ASSISTANT U.S. ATTORNEY Dated: JEFFREY EPSTEIN Dated: GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN Dated: F-4Y- 09- ANN Z, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 HOUSE_OVERSIGHT_012597

TAB 22 HOUSE_OVERSIGHT_012598

08/31/2007 13:03 PAX 5618021787 USAD WEB FL i oo2 U.S. Department of Justice United Stutes Attorney Southern District of Florida S500 South Austration Ave. Suite 400 West Palm Beach, FL 3340] (561) §20-871] Angust 31, 2007 DELIVERY BY FACSIMILE Ms. In care of Bruce Lyons, Esq. Lyons and Sanders 600 Northeast 3rd Avenue Fort Landerdale,; FL 33304 Re: Grand Jury investigation—Confidential Dea i This letter is an invitation for you to testify before a federal Grand Jury, and is supplied in order to provide helpful background information about the Grand Jury. The Grand Jury consists of from sixteen to twenty-three persons from the Southern District of - Florida. It-is their responsibility to inquire into federal crimes which may have been committed m this District. Asa Grand Jury witness you will be asked to testify and answer questions under oath, and to produce records and documents. Only the members of the Grand Jury, attorneys for the United States anda stenographer are permitted in the.Grand Jury room while you testify.. The U.S. Department of Justice encourages prosecutors to notify an individual in appropriate cases that he or she is a target of a grand jury investigation. Accordingly, you are hereby notified that you are a target of a federal grand jury investigation in the Southern District of Florida concerning suspected violations of federal law, including but not limrted to, possible violations of Title 18, United States Code, Sections 2, 371, 1512, 1591, 1952, 1956, 1960, 2421, 2422, and 2423. You are advised that the destruction or alteration of any document required to be produced before the grand jury constitutes serious violation of federal law, including butnot tumited to Obstruction of Justice. ' A “target” is a person as to whom the prosecutors or the Grand Jury have substantial HOUSE_OVERSIGHT_012599 sf orarhaten ele emenaner pa ceioin poetics tnt err mempnainipe ett tre et erate en ne rere ere er Orit

08/31/2007 13:04 FAX 5618021787 USAG WPB FL 003 Ms. August 31, 2007 Page 2 Fee re ere ene tenner arti ee erent ret ener re evidence linking him or her to the commussion of a crime and who, in the judgment of the prosecutors, is a putative defendant. This letter constitutes an invitation to you to testify on your own behalf before the grand jury about matters under investigation. Of course, you are not required to appear before the grand jury. The decision whether to do so is a voluntary matter which 1s entirely up to you, The grand jury, if in fact it learns of this opporhmity afforded to you, will be instructed not to draw any adverse inference from your failure to appear should you decide not to accept this invitation. You must further understand that should you decide to testify, your testitnony could be used agaist you if any crimimal charges should be filed against you. FO eS ney ren yarn aerate Nt se pt eerie ao ne Should you decide to appear before the grand jury, you will have the same tights and obligations as any non-immunized grand jury witness, Specifically, You may refuse to answer any question if a truthful answer to the question -would tend to incriminate you. You have the nght to stop answering questions at any time. Anything you say may be used against you at the grand jury or in a subsequent legal proceeding. ~ .. The grand jury will permit you a reasonable opportunity to step outside the grand jury room to consult with your attorney, if you so desire,.at any point during the testimony you give. Please be further advised that the giving of false testimony before the grand jury will subject you to a prosecution for perjury in addition to the violations set forth above. 7” As a target of a grand jury investigation who has been asked to appear before the grand jury, you may wish to retain the services of an attomey. If you cannot afford the services of independent counsel, the Court may be able to appoint counsel to represent you. Ifyou would like the United States to ask the Court to appoint an attorney to represent you, piease contact the undersigned at 561 209-1047, The United States is investigating other individuals, and you may be interested m cooperating with the United States agamst those other targets. Jf you hire an attomey, or if the Court appoints one to represent you, that _ counsel can contact meé to disciiss that possibility, HOUSE_OVERSIGHT_012600

- 08/51/2007 13:04 FAX 5618021787 . USAO WPB FL . [dj 004 Ms. August 31, 2007 Page 3 Please advise me whether you wish to testify before the grand jury by close of busimess Wednesday, September 12,2007. If] do not receive notification from you or your counsel by this date, I will assume that you do not wish to testify before the grand jury. Sincerely, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY A. Marie Villafaita ' Assistant United States Attorney. . ae oA Ned arate ener Ao me Re er ee a Se a ENA RETNA LARA iret Pc ere re eulnge eoraneep merep Aton wae fh HOUSE_OVERSIGHT_012601

TAB 23 HOUSE_OVERSIGHT_012602

sp 98/16/2007_17:05 FAX 5618021787 USAO WPB FL ooz U.S. Department of Justice United States Attorney Southern District of Florida 500 South Austrakon Ave., Suite 400 * West Palm Beach, FL 33401 (561) 820-8711 . Facsimile: (561) 820-8777 August 16, 2007 VIA FACSIMILE Gerald Lefcourt, Esq. Gerald P. Lefcourt, P.C. 148 Bast 78th Street New York, NY 10021 Re: Subpoena to Custodian of Records. ‘Dear Mr. Lefcourt: , < I write in response to your letter of July 18, 2007 regarding the grand jury subpoena issued SF to the Custodian of Records for NES, LLC. Ihave attached an identical subpoena containing aretum’ date of September 11, 2007, and subpoenas for two NES employees, Eric Gany and Harry Beller. if you will not be representing Messrs. Gany and Beller, please let me know. First, as [mentioned in my earlier correspondence, a properly executed declaration from the Custodian of Records is needed, and, ifno documents responsive to a particular request exist, the Custodian should certify that under penalty of perjury. Second, you write that NES has no documents responsive to Requests 1 through 5. I know fg that NES has several credit card accounts for the benefit of the persons who manage Mr. Epstcin’s Dy properties, inchiding Janusz Banasiak and Alfredo Rodriguez. I also know that NES regularly ee receives money from an account that is used to pay expenses at 358 El Brillo Way and also wires money to that same account. Those. wire transfers fall within the time period called for by the subpoena and number in the hundreds of thousands of dollars. If NES does not maintain records of its banking activities, then I would like to see a copy of its document retention policy, so I have added that to the Attachment to the Subpoena. ; Third, Mt. Menchel’s comment to you about potential money laundering charges related only to aresolution of the case. In other words, if the sex offense case is resolved, the Office would close its investigation into other areas as well. The matter has not been, and it does not appear that it will be, resolved so the money laundering investigation continues, and Request Number 6 will not be withdrawn. The request is not overbroad and is stated with particularity, so please comply with the fo ’ request by the new deadline. owe F HOUSE_OVERSIGHT_012603

98/36/2007 17:06 FAX 5618021787 USAO HPB FL oos GERALD LEFCOURT, ESQ. AUGUST 16, 2007 PAGE 2 OF 2 With respect fo paragraph 7, the information provided regarding the pilots came from the corporate records of Hyperion and JEGE, Inc., not NES. However, I have provided a shorter list in the new subpoena attachment. I also have enclosed another certification for the Custodian of Records’ signature. Thank you again for your assistance. | | Sincerely, R. Alexander Acosta United States Atotaiey A. “Marie Villafatia sO Assistant United States Attomey ( cet B, Nesbitt Kuyrkendall, FBI (with enclosures), HOUSE_OVERSIGHT_012604

08/16/2007 17:06 5618021787 USAO WPB FL - Tooa United States District Court SOUTHERN DISTRICT OF FLORIDA TO: Custodian of Records ve SUBPOEN. ATO TESTIFY se a BEFORE GRAND JURY , FGJ 07-103(WPBY/No. OLY-65/2 SUBPOENAFOR: [x] PERSON DOCUMENTS OR OBJECT|S] YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District Court at the a date and time specified below. PLACE: United States District Courthouse 701 Clematis Street West Palm Beach, Florida 33401 DATE AND TIME: September 11, 2007 1:00 pm* _ you ARE ALSO ‘COMMANDED to bring with you the following Mosermenit or object(s): THE DOCUMENTS AND OBJECTS LISTED ON ATTACHMENT A. *Please coordinate your compliance with this subpoena and confirm the date, time, and location of your appearance with S/A Nesbitt Kuyrkendall, Federal Bureau of Investigation, Telephone: (561) 822-5946. This subpoena shall remain in effect until you are granted I leave to depart by the court or by an officer acting on behalf of the court. August 16, 2007 This subpoeaa is issued upon ppieaten _t Name, Address and Phone Number of Assistant U.S. Attomey Amn Marie C, Villafaiia, Assistant U.S. Attorney 500 So. Australian Averme, Suite 400 West Palm Beach, FL 33401-6235 Tel: (561) 820-8711 x3047 «: Fax: (561) 802-1787 * not applicable, enter “none.” To beused in Rea of AQ110 FORM ORD-227 ‘ , JANSG HOUSE_OVERSIGHT_012605

" s2.08/46/2007 17:06 FAX 5618021787 USAO PB FL . Boos —~ I. - For the period of January 1, 2003 to the present, all calendars, agendas, daily all metadata included within the electronic/physical files. ATTACHMENT TO SUBPOENA OLY-65/2 NES, LLC diaries, or other records of appointmenis, travel, meetings and the like, kept by or on behalf of Jeffrey Epstein, He Lesley Groff, and/or . This request includes information that is kept in physical “hard copy” and/or electronic form, whether stored on a personal computer, database server, cellular telephone, “Blackberry” unit, personal digital assistant (“PDA”) or other handheld electronic device, or in any other electronic form, and For the period of January 1, 2003 to the present, all address books, contact lists, or other records of names, telephone numbers, addresses, and/or e-mail addresses kept by or on behalf of Jeffrey Epstein A TN Lesley Groff, and/or BE This request includes information that is kept in physical “hard copy’’ and/or electronic form, whether stored on a personal computer, database sexver, cellular telephone, “Blackberry” unit, personal digital assistant (“PDA”) or other handheld electronic device, or in any other electronic form, and all metadata included within the electronic/physical files. For the period of January 1, 2003 to the present, all e-mails, instant messages, text messages, meeting invitations, and any other electronic Communication sent by Jeffrey Epstein, Lesley Groff, and/or BE. Jeriey Epsici, A PMI Lesley Croft, endo Po This request includes information that is kept im physical “hard copy” and/or electronic form, whether stored on a petsonal computer, -database server, cellular telephone, “Blackberry” unit, personal digital assistant (“PDA”) orother handheld electronic device, or in any other electronic form, and all metadata included within the electronic/physical files. For the period of January 1, 2003 to the present, all documents and information referring or relating to the transfer of funds to or from any account owned by NES, LLC to or from any bank account used for the maintenance of the property located at 358 El Brillo Way, Palm Beach, Florida, or for the payment of any person working at 358 E] Brillo Way, Palm Beach, Florida. Page 1 of 2 HOUSE_OVERSIGHT_012606

. 08/16/2007 17:07 FAX 5618021787 USAO WPB FL 2 (W006 Any and ali document retention and/or destruction policies. For the period of January 1, 2003 to the present, all documents and information _ referring or relating to the transfer of funds to or from any account owned by NES, LLC to or from any bank account on which Janusz Banasiak and/or Alfredo Rodriguez had or has check-writing authority and/or access to via debit/ATM card. For the period of January 1, 2003 to the present, all doouments and information referring or relating to the transfer of fund to or from any account owned by NES, LLC to or from any account owned by JEGE, Inc., Jeffrey E. Epstein, Hyperion Air, Inc., Financial Trust Co., New York Strategy Group, Inc., J. Epstein Virgin Islands Foundations, Inc., and/or Epstein Interests. For the period of January 1, 2003 to the present, the names of all employees and all corporate directors, board members, and shareholdezs. For the period of January 1, 2003 to the present, copies of all W-2s and/or 1099s for the following persons: Jeffrey Epstein, Lesley Groff, Janusz Banasiak, Alfredo Rodnguez, Harry - Beller, and Eric T. Gany. _ Page 2 of 2 HOUSE_OVERSIGHT_012607

08/16/2007 17:97 FAX 5618021787 USAO WPB FL : 007 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA INRE FEDERAL GRAND JURY SUBPOENA OLY-65/2 ADDRESSED TO NES, LLC CERTIFICATION REGARDING DOMESTIC RECORDS OF REGULARLY CONDUCTED ACTIVITY 1, the undersigned... ; declare that lam employed by NES, LLC in the position of, ___, and, by reason of my position, i authorized and qualified to make this declaration. Ls Inmy carp Joyment with NES, LLC, I am familiar with the business records it maintains. 2s I certify that the records attached to this certification: (a) | were made at or near the time of the occurrence of the matters set forth therein, by or from information transmitted by, a — with knowledge of — those matters; (b) were kept mm the course of regularly conducted business activity; sre (c) were made by the regularly conducted activity as a regular practice. 2. Among the records so maintained are the attached zecords itemized in Appendix A (Document Inventory). | 3. I further certify that the documents attached hereto ate responsive to Grand Jury Subpoena 65/2 served upon NES, LLC. Page 1 of 2 HOUSE_OVERSIGHT_012608

__08/16/2007 17:07 FAX 5618021787 USAO WPB FL. “Hoos: 4. I further certify that NES, LLC has no documents responsive to request number(s) information is frie and correct. Executed this ss dayoof ____ 5 2007. Place of exectition: } Signature Page 2.0f 2 in Grand Jury Subpoena number 65/2. [Fill in or strike out as appropriate. ] Pursuant to 28 U.S.C. § 1746, I declare under penalty of petjury that the foregoing HOUSE_OVERSIGHT_012609

_.08/16/2007 17:07 FAX 3618021787 USAO WPB FL Boog | United States District Court SOUTHERN DISTRICT OF FLORIDA. TO: HARRY BELLER ‘SUBPOENA TO TESTIFY BES, ELE BEFORE GRAND JURY FGI 07-103(WPBY/No. OLY-75 SUBPOENA FOR: PERSON [ DOCUMENTS OR OBJECTS] YOU ARE HEREBY COMMANDED to appear aud testify before the Grand Jury of the United States District _.. Court at the place, date and time specified below. ie, misw epics aky Honrmieimenieseecins iy ee ‘PLAGE: : ; ROOM: United States District Courthouse | Grand Jury Room * 701 Clematis Street - _ West Palm Beach, Florida 33401 } DATE AND TIME: September 11, 2007 ese gee a ies _. __ | 1:00 pm* YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s): *Please coordinate your compliance with this sabpoena.and confirm the date, time, and location of your appearance with 8/A Nesbitt Kuyrkendall, Federal Burcau of Investigation, Telephone; (561) 822-5946. ‘This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf of the court. ; DATE: (BY) DEAUTY CLERK apenas, SCE This subpoena is issued upon application Name, Address and Phone Number of Assistant U.S. “Attomey of the United Statcs.of America Ann Marie C. Villafata, Assistant U.S. Attomey Ya P\f yy. fy 500 So. Australian Avenue, Suite 400 West Palm Beach, FL 33401-6235 Tel: (S61) 820-8711 x3047 ofaoiie . FORM ORD-227 JAN.86 Teo boured in fice HOUSE_OVERSIGHT_012610

oo, 08/16/2007 17:07 FAX 5618021787 USAC HPB FL. Bore | United States District Court | SOUTHERN DISTRICT OF FLORIDA TO: ERIC GANY . SUBPOENA TO TESTIFY BES TS | BEFORE GRAND JURY , . * FGJ 07-103(WPB)/No. OLY-76 . SUBPOENA FOR: PERSON [ | DOCUMENTS OR OBJECT{S] YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District Court at the place, date and time specified below. | Rodi: PLACE: United States District Courthouse Grand Jury Room . 701 Clematis Street . West Palm Beach, Florida 33401 DATE AND TIME: . September 11, 2007 1:00 pm* ‘YOU ARE ALSO COMMANDED to bring with you the following document(s) or object() *Please coordinate your compliance with this subpoena and confirm the date, time, and location of your _ appearance with S/A Nesbitt Kuyrkendall, Federal Bureau of Investigation, Telephone: (561) 822-5946. This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf of the court. : (BY) DEPUTY CLERK Name, Address snd Phone Number of Assistant U.S. Attorncy This subpoena is issued upon application Ann Marie C. Villafaia, Assistant U.S. Attomcy Sf the United Stites ofanmeyica. <. pp — 500 So. Australian Avenue, Suite 400 Wy) West Palm Beach, FL 33401-6235 Tel: (561) 820-8711 x3047 Fax: (561) 802-1787 To bewsedin Fea af A0ite — FORM ORD-237 “SANG *LEnol upplicable, enter "none." HOUSE_OVERSIGHT_012611

"08/16/2007 17:05 FAX .5618021787 USAO WPB FL 601 U.S. Department of Justice United States Attorney Southern District of Florida A. Marie Villafatia 500 S. Australian Ave, 4th Floor West Pala Beach, Florida 33401 (564) 820-8731 Facsimile (561) 820-8777 FACSIMILE COVER SHEET TO: Gerald Lefcourt, Esq. DATE: August 16,2007 | ‘FAXNO. _232-988.6192 gorpraces:__ | O PHONE NO. _ 242-737-0400 RE: NES ILC C FROM: A. MARTE VILLAFANA, Assistant U.S. Attorney 7 PHONE NO, _ 561-209-1047 _- | COMMENTS: HOUSE_OVERSIGHT_012612

TAB 24 HOUSE_OVERSIGHT_012613

"Villafana, Ann Marie C. To “Jay Lefkowitz" Sinn \(USAFLS\)" cc bec 09/19/2007 12:14 PM Subject RE: Meeting Judge Johnson has duty next week. Jay — [hate to have to be firm about this, but we need to wrap this up by Monday. I will not miss my indictment date when this has dragged on for several weeks already and then, if things fail apart, be left in a less advantageous position than before the negotiations. [ have had an 82-page pros memo and 53-page indictment sitting on the shelf since May to engage in these negotiations. There has to be an ending date, and that date is Monday. A. Marie Villafafia ~ - psomey From: Jay Lefkowitz [mailto Sent: Wednesday, September 19, 2007 11:58 AM To: Villafana, Ann Marie C. (USAFLS) Subject: Re: Meeting We may want to meet monday and potentially continue to tues if necessary. Which mag is on duty? ———~ Original Message ----- From: “Villafana, Ann Marie C. (USAFLS\)" | Sent: 09/19/2007 11:51 AM AST To: Jay Lefkowitz Subject: Meeting Barry is available Monday morning. Our most flexible West Palm Beach magistrate is on duty on Monday, so, assuming we have signed documents by 1:30 or so, we should be able to get Mr. Epstein arraigned on Monday. I doubt that we will be able to get everything finished up here, get down to Miami, and try to find a Miami mag by close of business on Monday. A. Marie Villafafia Assistant U.S. Attorney AAR IR RIOR kk foi ka ob ak ok HOUSE_OVERSIGHT_012614

The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. SIO IGOR Gk ik koko Gok kkk oR Rae ok HOUSE_OVERSIGHT_012615

TAB 25 HOUSE_OVERSIGHT_012616

"Villafana, Ann Marie C. To “Jay Lefkowitz" Po 09/23/2007 08:04 PM Subject RE: Revised agreement 1 BB at is definitely under 18 still, and | think there is a second minor. The appointment of #8 Hidteiast ad litem is to provide you with a mechanism to make contact with the girls and to give them the assistance of an independent attorney who represents them (as opposed to me, who represents the government). If you are willing to provide the girls with independent counsel, at Mr. Epstein’s expense (and | get to pick the attorney), that is alright with me. From: Jay Lefkowitz [mailto Sent: Sunday, September 23, 2007 6:55 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Re: Revised agreement Will do. AlS8, WHY do you need a guardian ad litem at all? Are any of the 40 under 18 now? ----- Original Message ----- From: "Villafana, Ann Marie C. \(USAFLS\) nn Sent: 09/23/2007 06:52 PM AST _ To: Jay Lefkowitz ~ : Subject: Revised agreement Hi Jay - Can you look at this? Especially paragraph 7. | think this covers the exclusive remedy concern you had. <<070923 Epstein Non-Prosecution Agreement final.pdf>> FIG a OR RO IORI RR kK a ao dook kk ak ok ok ak akc The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. A OR a GR aig a ROR a ka ak kok kak ok ook ake deo HOUSE_OVERSIGHT_012617

TAB 26 HOUSE_OVERSIGHT_012618

"Villafana, Ann Marie C. To "Jay Lefkowitz” [nn S Ww cc "Martin Weinberg" "Lourie, Andrew" "Garcia, Rolando \(USAFLS\)" 09/24/2007 01:27 PM bec Subject RE: Epstein agreement as reviewed by the U.S. Attorney Hi Jay - Sorry for the delay. The U.S. Attorney had a last-minute concern, that I think I fixed (it is in the first “It Appearing” clause following the list of statutes potentially violated). After you get the green light, let’s discuss the potential representative. The person I am thinking of has run a preliminary conflicts check and it looks alright. Also, to address Mr. Epstein’s concern regarding the list of names, I wanted to tell you that I have compiled a list of 34 confirmed minors. There are six others, whose names we already have, who need to be interviewed by the FBI to confirm whether they were 17 or 18 at the time of their activity with Mr. Epstein. Once those interviews are completed, I can finalize the list of identified victims, which I will put in a formal document that I will maintain until the time of Mr. Epstein’s sentencing. Assuming that this agreement is fine, please execute at least three copies, and send one to me by fax and the rest by FedEx. I will execute and send the copies back. Thank you. A. Marie Villafaiia Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 HOUSE_OVERSIGHT_012619

From:Jay Lefkowitz Sent: Monday, September 24, 2007 11:46 AM To: Villafana, Ann Marie C. (USAFLS) Cc: Martin Weinberg; Lourie, Andrew Subject: Re: Epstein agreement as reviewed by the U.S. Attomey Marie - Here are what I hope are final edits to the agreement. I will call in 15 min. thanks -- Jay "Villafana, Ann Marie C. \(USAFLS\)" To "Jay Lefkowitz" Po cc 09/24/2007 10:13 AM Subje Epstein agreement as reviewed by the U.S. ct Attorney Hi Jay — Here is the agreement with Alex’s edits. Thank you. <<070924 Epstein Non-Prosecution Agreement w Acosta edits v2.pdf>> A. Marie Villafatia Assistant U.S. Attorney 900 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 HOUSE_OVERSIGHT_012620

070924 Final Epstein Non-Prosecution Agreement.pdf HOUSE_OVERSIGHT_012621

TAB 27 HOUSE_OVERSIGHT_012622

aaa \(USAFLS\)" co bec 09/24/2007 04:34 PM Subject RE: Do you have a signed copy? Thank you, Jay. | have forwarded your message only io Alex, Andy, and Rolando. | don't aniicipate it going any further than that. When | receive the originals, | will sign and return one copy to you. The other will be placed in the case file, which will ba kept confidential since it also contains identifying information about the girls. When we reach an agreement about the altiorney representative for the girls, we can discuss what | can tell him and the girls about the agreement. | know that Andy promised Chief Reiter an update when a resolution was achieved. (Something | wouldn’t have promised in light of what happened last year.) Rolando is calling, but Rolando knows not to tell Chief Reiter about the money issue, just about what crimes Mr. Epstein is pleading guilty to and the amount of time that has been agreed to. Rolanda also is telling Chief Reiter not to disclase the outcome to anyone. From: Jay Lefkowitz Sent: Monday, September 24, 2007 4:06 PM To: Villafana, Ann Marie C, (USAFLS) Subject: Re: Do you have a signed copy? Marie - Please do whatever you can to keep this from becoming public. thanks -- Jay e a ce 09/24/2007 04:04 PM SubjectDo you have a signed copy? Hi Jay — Sorry to be a bother, but do you have a copy that at least contains Mr. Epstein’s signature? I need to pass it along to the powers that be. Thanks. HOUSE_OVERSIGHT_012623

TAB 28 HOUSE_OVERSIGHT_012624

—_ \ \(USAFLS\)" ; cc bec 09/26/2007 11:01 AM Subject RE: Other attomeys Hi Jay — Can you give mea call at RE his morning? | am meeting with the agents and want to give them their marching orders regarding what they can tell the girls. Also, please remove Babbitt and Searcy from the list. There is too great a chance of an appearance of impropriety with Babbitt and I received a bad report about Searcy last night. Thank you. A. Marie Villafatia Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, September 25, 2007 8:37 PM To: ‘Jay Lefkowitz’ Subject: Other attorneys Hi Jay — These four people were recommended. I have not contacted them to find out what their rates are. All are very active in the plaintiffs’ bar in the West Palm area. Ted Babbitt would be my first choice of these four but I think he is conflicted out because one of his partners is married to an AUSA here. Stuart Grossman is probably my second choice. Ted Babbitt -- http://www.babbitt-johnson.com/tbabbitt. html Stuart Grossman -- http://www.grossmanandroth.com/sgrossman.htm Chris Searcy -- h www.searcylaw.com/CHRISTIANDSEARC Y/tabid/935/default.aspx Lake Lytal, Jr. -- http://www.lytalreiter.com/index.php?page_id=37 HOUSE_OVERSIGHT_012625

Talk to Jack Goldberger about this group. They are all very good personal injury lawyers, but I have concerns about whether there would be an inherent tension because they may feel that THEY might make more money (and get a lot more press coverage) if they proceed outside the terms of the plea agreement. (Sorry — I just have a bias against plaintiffs’ attorneys.) One nice thing about Bert i is that he is in Miami where there has been almost no coverage of this case. Just so you know, I have never met Bert, but a good friend in our appellate section and one of the district judges in Miami are good friends with him and recommended him. Can you let me know tomorrow? I am going to be out for a while starting on Friday, and I _ would like to get this underway before I leave. Thank you. A. Marie Villafatia Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 HOUSE_OVERSIGHT_012626

TAB 29 HOUSE_OVERSIGHT_012627

"Villafana, Ann Martie C. To “Jay Lefkowitz" Ia USAFLS)" cc bcc 10/05/2007 07:48 AM Subject RE: Proposed Letter to Speciat Master ORES 1 = = Good morning, Jay. We need to resolve the attorney issue today. It has been weeks since execution of the contract, and there is no need for further delay. As far as the five attorney names that we will be providing, I propose Bert Ocariz, Katherine Ezell at Podhurst Orseck, Stuart Grossman, Ed Rogers, and Walter Cobath. If you would like to use the same Special Master to resolve fees disputes as well as to handie the selection of the attorney, I would recommend that we use retired llth Circuit Judge Joseph Hatchett instead of Judge Davis because of Judge Davis's heaith problems. (No one has contacted Judge Hatchett yet, but one of the District Judges in Miami mentioned him as a good choice.) I am available for a conference call between 9:00 and 10:00, and between 3:15 and 6:00. Please call me on my cell and let me know which of those times works best for you. Thank you. From: Jay Lefkowitz Sent: Wed 10/3/2007 4:26 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Re: Proposed Letter to Special Master Marie - I, too, am interested in speed. But I really need to go over this and then discuss with Jeffrey. So please do not send this to any Special Master ’ before we discuss.the next steps. ; Thanks -- Jay 10/03/2007 04:24 PM To "Jay Lefkowitz" iy cc Subject Proposed Letter to Special Master HOUSE_OVERSIGHT_012628

—_ Hi Jay - To move things along, I also have enclosed the proposed text of a letter to the Special Master. <<PROPOSED Letter to Special Master.pdf>> A. Marie Villafafia Assistant U.S. Attorney HOUSE_OVERSIGHT_012629

TAB 30 HOUSE_OVERSIGHT_012630

—_, cc bec (USAFLS)” 09/27/2007 03:06 PM Subject RE: Conference Call with Bert Ocariz Hi Jay — J already told Bert that there is no indictment and, as 1 mentioned, he doesn’t really need to/want to see the entire plea agreement, just the relevant paragraphs so that he understands what the scope of his representation will be. I think they would be happy knowing that their hourly rate will be paid when it is billed. The concern is, if all 40 girls decide they want to sue, they don’t want to be in a situation where Mr. Epstein says this is getting too expensive, we won’ t pay any more attorneys’ fees. ‘wo suggestions, that I] haven't run past Bert, are: i. Mr. Epstein signs a standard fee agreement, where one of his attorneys or accountants whe is not working on the damages litigation receives a monthly bill with attorney's fees charged at an hourly rate and cosis billed monthly. The bills will have any privileged information redacted. If there is a dispute about a bill that cannot be resolved, it will be submitted to a mediator for resolution. 2. If that is too open-ended for Mr. Epstein, do the hourly/monthily billing until Bert has had a chance to confer with all of the girls to determine how many want him to represent them. Once it is known how many girls will be represented by Bert, and mayhe who those girls are, there can be a more educated discussion about estimated fees and costs. Just some food for thought. I will be out of the office tomorrow, but I will be reachable by cell phone. I will make sure Bert is available and confirm the time with you. A, Marie Villafafia Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 From: Jay Lefkowitz Sent: Thursday, September 27, 2007 2:53 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Re: Conference Call with Bert Ocariz Marie - I will not be able to get back to you until tomorrow. However, some of the questions he raised cause me HOUSE_OVERSIGHT_012631

some serious concern. 1. Can we get a copy of the indictment (or can you tell me the nature of the crimes against the girls)? Certainly he should not get a copy of any indictment. 2. When will it be possible to see the plea agreement so that we understand exactly what Epstein concedes to in the civil case? I don't think he should get the plea agreement either. 3. Is there any cap or other limitation on attorney's fees that the defendant will pay in the civil case? I can’t imagine he would be entitled to anything other than an hourly fee. 4. What is the contemplated procedure for, and timing of, the payment of attorney's fees and costs? In any event, I need to consider these issues carefully and I cannot agree to any of these issues before we speak. I would suggest we plan on talking tomorrow at 12 pm if you are available. none Original Message ----- From: "Villafana, Ann Marie C. (USAFLS)" Sent: 09/27/2007 10:51 AM AST To: Jay Lefkowitz Subject: Conference Call with Bert Ocariz Hi Jay — Bert's firm has raised a number of good questions about how they are going to get paid and setting up a procedure that avoids any conflict of interest with their clients. Are you around today to do a conference call? Let me know what times work for you because Bert wants to get their conflicts counsel on the call with us. These are some of the questions he sent to me. I told Bert that as part of our agreement we (the federal government) are not going to indict Mr. Epstein, but gave him an idea of the charges that we had planned to bring as related to 18 USC 2255. With respect to question 2, do I have your permission to send Bert just that section of the plea agreement that applies to the damages claims (I would recommend sending paragraphs 7 through 10, or at least 7 and 8)? Can you talk with your client about items 3 and 4? I envisioned Shook Hardy sending regular bills to you, with any privileged information redacted, and being paid like every other client pays the bills. 1. Can we get a copy of the indictment (or can you tell me the nature of the crimes against the girls)? 2. When will it be possible to see the plea agreement so that we understand exactly what Epstein concedes to in the civil case? HOUSE_OVERSIGHT_012632

3. Is there any cap or other limitation on attorney's fees that the defendant will pay in the civil case? 4. What is the contemplated procedure for, and timing of, the payment of attorney's fees and costs? A. Marie Villafana Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 3 A AS os os fg 2s aS eS is 2 2 2s os 2g 2 os 2g fs of ot is fs os 2 oe as of of ofc a oS oc oko 2c oc ok i 2 ok 2 ok ok fs akc oft os The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. FRI CIC AK AICI AICO IO IK ICI KK OK KK Ik ok ak ok a ok ok ok ok a ok ok ok ok ok ok ok ok HOUSE_OVERSIGHT_012633

TAB 31 HOUSE_OVERSIGHT_012634

Member Search Page 1 of 1 Inside-the Bar Find a Lawyer Jeffrey Marc Herman Member in Good Standing Eligible to practice in Florida ID Number: _- 521647 Address: Herman & Mermelstein PA 18205 Biscayne Bivd Ste 2218 North Miami Beach, Florida 331602148 United States Phone: 305.9312200 E-Mail: [email protected] County: Miami-Dade Circuit: 11 , Admitted: 12/26/1985 10-Year None Discipline History aN, Firm: erman Sloman & Mermelstein PA The Find A La directory provides limited basic information about attorneys licensed to practice in Florida and is provided as a public service by The Florida Bar. The information contained herein is provided “as is” with no warranty of any kind, express or implied. The Florida Bar, its Board of Governors, employees, and agents thereof are not responsible for the accuracy of the data. Much of the information is provided by the attorney and it is the attorney's responsibility to review and update ° the information. Publication of attorneys’ contact information within this listing x SNGMPRSEES construed as their consent to receive unsolicited communications in any form. Certain unauthorized uses of this data may result in civil or criminal penalties: zi d-A-Lawyer directory is not a lawyer referral service. (Updated: 03-05-2008 J © 2005 The Florida Bar hitp://www .floridabar.org/names.nsf/AIl/EDE6C2013E4B06CB85256A8400091E5520pen.( 3/5/2008 HOUSE_OVERSIGHT_012635

TAB 32 HOUSE_OVERSIGHT_012636

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 20069 " JANE DOE NO. 1, by and through JANE DOE’s FATHER as parent and natural guardian, and JANE DOR’s FATHER, and . . JANE DOE’s STEPMOTHER, individually, ciV-MA RRA Plaintiffs, MAGISTRATE JUDGH vs. ' JOHNSON LED by D.C. JEFFREY EPSTEIN, INTAKE Defendant. JAN 24 2008 COMPLAINT Plaintiff, Jane Doe No. 1 (“Jane” or “Jane Doe”), by and through Jane Doe’s Father as parent and natural guardian, and Jane Doe’s Father and Jane Doe’s Stepmother, individually, bring this Complaint against Jeffrey Epstein, as follows: Parties, Jurisdiction and Venue 1. Jane Doe is a citizen and resident of the State of Florida. She is a minor under the age of 18 years. 2. Jane Doe’s Father brings this action individually and as parent and natural guardian of Jane Doe. Jane Doe’s Father is a citizen and resident of the State of Florida. 3, Jane Doe’s Stepmother brings this action individually. Jane Doe’s Stepmother is a citizen and resident of the State of Florida. 4, This Complaint is bronght under fictitious names to protect the identity of the Minor Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a HERMAN & MERMELSTEIN, P. A. www.hermaniaw.com HOUSE_OVERSIGHT_012637

minor, 5. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 6. This is an action for damages in excess of $50 million. 7. ‘This Court has jurisdiction of this action and the claims set forth herein pursuant to 28 U.S.C. §1332(a), as the matter in controversy (i) exceeds $75,000, exclusive of interest and costs; and (ii) is between citizens of different states. 8. This Court has venue of this action pursuant to 28 U.S.C. §1391(a) as a substantial part of the events or omissions giving rise to the claim occurred in this District. Factual Allegations a, At all relevant times, Defendant Jeffrey Epstein (“Epstein”) was an adult male, 52 years old. Epstein is a financier and money manager with a secret clientele limited exclusively to billionaires. He is himself a man of tremendous wealth, power and influence. He maintains his principal home in New York and also owns residences in New Mexico, St. Thomas and Palm Beach, FL. The allegations herein concern Epstein’s conduct while at his lavish estate in Palm Beach. 10. Upon information and belief, Epstem has a sexual preference and obsession for underage minor girls. He engaged in a plan and scheme in which he gained access to primarily economically disadvantaged minor girls in his home, sexually assaulted these girls, and then gave them money. In or about 2005, Jane Doe, then 14 years old, fell into Epstein’s trap and became one of his victims. | 11. Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted girls m Florida, New York and on his private island, known as Little St. James, in St. Thomas, 12. An integral player in Epstein’s Florida scheme was Haley Robson, a Palm Beach HERMAN & MERMELSTEIN, P, A. www.hermaniaw.com HOUSE_OVERSIGHT_012638

Comnmnity College student from Loxahatchee, Florida. She recmited girls ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. Under Epstein’s plan, Ms. Robson would be contacted when Epstein was planning to be at his Palm Beach residence or soon after he had arrived there. Epstein or someone on his behalf directed Ms. Robson to bring one or more underage girls to the residence. Ms. Robson, upon information and belief, generally sought out economically disadvantaged underage girls from Loxahatchee and surrounding areas who would be enticed by the money being offered - generally $200 to $300 per “massage” session - and who were perceived as less likely to complain to authorities or have credibility if allegations of improper conduct were made. This was an important element of Epstein’s plan. 13. Epstein’s plan and scheme reflected a particular pattern and method. Upon arrival at Epstein’s mansion, Mr. Robson would introduce each victim to Sarah Kellen, Epstein’s assistant, who pathered the girl’s personal information, including her name and telephone number. Ms. Kellen would then bring the girl up a flight of stairs to a bedroom that contained a massage table in addition to other fumishings. There were photographs of nude women lining the stairway hall and in the bedroom. Ms. Kellen would then leave the girl alone in this room, whereupon Epstein would enter wearing only a towel. He would then remove his towel, lay down naked on the massage table, and direct the girl to remove her clothes. He then would perform one or more lewd, lascivious and sexual acts, including masturbation and touching the girl’s vagina with a vibrator. 14, Consistent with the foregoing plan and scheme, Ms. Robson recruited Jane Doe to give Epstein a massage for monetary compensation. Ms, Robson brought Jane to Epstein’s mansion in Palm Beach. Jane was introduced.to Sarah Kellen, who led her up the flight of stairs to the room with the massage table. She was alone in the room when Epstein arrived wearing only a towel. He HERMAN & MERMELSTEIN, P. A, www.hermaniew.com HOUSE_OVERSIGHT_012639

removed his towel, and laid down naked on the massage table. He demanded that Jane remove her clothes. In shock, fear and trepidation, Jane complied, removing her clothes except for her underwear. Epstein then sexually assaulted Jane, 15. After Epstein had completed the assault, he left the room. Jane was then able to get dressed, leave the room and go back down the stairs. She then met Ms. Robson again who brought Janehome. Jane was paid $300 by Epstein. Ms. Robson was paid $200 by Epstein for bringing Jane to him. 16. As a result of this encounter with Epstem, the 14-year old Jane experienced confusion, shame, humiliation, embarrassment and the assault sent her life into a downward spiral. COUNT I Sexual Assault 17. Plaintiff Jane Doe by and through her Father, as parent and natural guardian, repeats and realleges paragraphs 1 through 16 above. 18. Epstein tortiously assaulted Jane Doe sexually in or about 2005. 19. This sexual assault was in violation of Chapter 800 of the Florida Statutes, which recognizes as a crime the lewd and lascivious acts committed by Epstein upon Jane. 20. Asa direct and proximate result of Epstein’s assault on Jane, she has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and emotional damages. WHEREFORE, Plaintiff Jane Doe, by and through her Father, as parent and natural guardian, demands judgment against Defendant J effrey Epstem for compensatory damages, punitive damages, costs, and such other and further relief as this Court deems just and proper. HERMAN & MERMELSTEIN, P. A. www.hermaniaw.com HOUSE_OVERSIGHT_012640

COUNT fi Intentional Infliction of Emotional Distress 21. Plaintiffs Jane Doe by and through her Father, as parent and natural guardian, Jane Doe’s Father and Jane Doe’s Stepmother, individually, repeat and reallege paragraphs 1 through 16 above, . 22. Epstein’s conduct was intentional or reckless. 23. Epstein's conduct was outrageous, going beyond all bounds of decency. 24. _Epstein’s conduct caused severe emotional distress not only to Jane Doe, but also to her parents, Jane Doe’s Father and Jane Doe’s Stepmother. Epstein knew or had reason to know that his intentional and outrageous conduct would cause emotional trauma and damage to Jane Doe’s parents. 25. Asa direct and proximate result of Epstein’s intentional or reckless conduct, Jane Doe, Jane Does’ Father and Jane Doe’s Stepmother have suffered and will continue to suffer severe mental anguish and pain. WHEREFORE, Plaintiffs Jane Doe by and through her Father, as parent and natural guardian, Jane Doe’s Father and Jane Doe’s Stepmother demand judgment against Defendant J effrey Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this Court deems just and proper. . COUNT It Loss of Parental Consortium 26. Plaintiff Jane Doe’s Father repeats and realleges paragraphs 1 through 16 above. 27, Epstein’s tortious conduct is the direct and proximate cause of damages to Jane Doe’s Father, consisting of parental loss of comfort, companionship and society and healthcare costs HERMAN & MERMELSTEN, P. A, www.hermaniaw.com HOUSE_OVERSIGHT_012641

poy associated with the treatment of Jane. 28. Jane Doe’s Father experienced and will continue to experience great mental anguish, pain and suffering from the time that Defendant’s tortious conduct occurred. WHEREFORE, Plaintiff Jane Doe’s Father demands judgment for loss of consortium damages, costs and such other and further relief as this Court deems proper. JURY TRIAL DEMAND Plaintiffs demand a jury trial in this action. Dated: January a 2008 HERMAN & MERMELSTEIN, P. A. Respectfully submitted, HERMAN & MERMELSTEIN, P.A. Attorneys for Plaintiffs 18205 Biscayne Blvd. Suite 2218 Miami, Florida 33160 Tel: 305-931-2200 Fax: 305-931-0877 By: M. Herman [email protected] Florida Bar No. 521647 Stuart S. Mermelstein [email protected] Florida Bar No. 947245 Adam D. Horowitz Florida Bar No. 376980 [email protected] www. hermanlaw.com HOUSE_OVERSIGHT_012642

HOUSE_OVERSIGHT_012643

f> anne. « Case 9:08-cv-80232-KAM Document1 Entered on FLSD Docket 03/05/2008 FiUBecpy “WE D.C. ELECTRONIC 7 March 5, 2008 STEVEN M. LARIMORE UNITED STATES DISTRICT COURT Gear de Mae oy SOUTHERN DISTRICT OF FLORIDA ieee amelie CASE NO.: Plaintiff, vs. | JEFFREY EPSTEIN, . | Defendant. COMPLAINT | Plaintiff, Jane Doe No.3 (“Jane” or “Jane Doe”), brings this Complaint against Jeffrey Epstein, as follows: Parties, Jurisdiction and Venue | 1, Jane Doe is a citizen and resident of the State of Florida, and is sui juris. 2. This Complaint is brought under a fictitious name to protect the identity of the Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon her when she was a minor. De Defendant Jeffrey Epstein is a citizen and resident of the State of New York. ! 4. This is an action for damages in excess of $50 million. 5. This Court has jurisdiction of this action and the claims set forth herein pursuant to 28 U.S.C. §1332(a), as the matter in controversy (1) exceeds $75,000, exclusive of interest and costs; and (ii) is between citizens of different states. | 6. This Court has venue of this action pursuant to 28 U.S.C. §1391(a) as a substantial part of the events or omissions giving rise to the claim occurred in this District. ] HERMAN & MERMELSTEIN, P. A. www.hermaniaw.com | 10f6 HOUSE_OVERSIGHT_012644

; Case 9:08-cv-80232-KAM Document1 Entered on FLSD Docket 03/05/2008 Page 2of6 i Factual Allegations Te At all relevant times, Defendant Jeffrey Epstein (“Epstein”) was an adult male, 52 years old. Epstein is a financier and money manager with a secret clientele limited exclusively to billionaires. He is himself a man of tremendous wealth, power and influence. He maintains his principal home in New York and also owns residences in New Mexico, St. Thomas and Palm Beach, FL. The allegations herein concern Epstein’s conduct while at his lavish estate in Palm Beach. 8. Upon information and belief, Epstein has a sexual preference and obsession for underage minor girls. He engaged in a plan and scheme in which he gained access to primarily economically disadvantaged minor girls in his home, sexually assaulted these girls, and then gave them money. In or about 2004-2005, Jane Doe, then 16 years old, fell into Epstein’s trap and became one of his victims. 9. Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted girls in Florida, New York and on his private island, known as Little St. James, in St. Thomas. 10. An integral player in Epstein’s Florida scheme was Haley Robson, a Palm Beach Community College student from Loxahatchee, Florida. She recruited girls ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. Under Epstein’s plan, Ms. Robson would be contacted when Epstein was planning to be at his Palm Beach residence or soon after he had arrived there. Epstein or someone on his behalf directed Ms. Robson to bring one or more underage girls to the residence, Ms. Robson, upon information and belief, generally sought out economically disadvantaged underage girls from Loxahatchee and surrounding areas who would be enticed by the money being offered - generally $200 to $3 00 per “massage” session - and who were perceived as less likely to complain to authorities or have credibility if allegations of HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com 20f6 HOUSE_OVERSIGHT_012645

3 of 8 + Case 9:08-cv-80232-KAM Document1 Entered on FLSD Docket 03/05/2008 Page 3 of 6 improper conduct were made. This was an important element of Epstein’s plan. 11. Epstein’s plan and scheme reflected a particular pattern and method. Upon arrival at Epstein’s mansion, the victim would be brought to the kitchen. She would then be led up a flight of stairs to a bedroom that contained a massage table in addition to other furnishings. Once the girl was alone in this room, Epstein would enter wearing only a towel to cover his private area. He then would lay down on the massage table and perform one or more lewd, lascivious and sexual acts, including masturbation and touching the girl sexually. 12. Consistent with the foregoing plan and scheme, Ms. Robson recruited Jane Doe to give Epstein a massage for monetary compensation. Ms. Robson brought Jane to Epstein’s mansion in Palm Beach. Jane was led up the flight of stairs to the room with the massage table. | She was alone in the room when Epstein arrived wearing a towel to cover his private parts. He laid down on the massage table, and sexually assaulted Jane Doe during the massage. In addition, Jeffrey Epstein masturbated during the massage. 13. After Epstein had completed the assault, he left the room. Jane was then able to leave the room and go back down the stains. She then met Ms. Robson again who brought Jane home. Jane was paid $200 by Epstein. Ms. Robson was also paid by Epstein for bringing Jane to him. 14. Asaresult of this encounter with Epstein, the 16-year old Jane experienced trauma, shock, confusion, shame, humiliation and embarrassment. COUNT I Sexual Assault 15. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above. 16. Epstein tortiously assaulted Jane Doe sexually in or about 2004-2005. Epstein’s acts were intentional, unlawful, offensive and harmful. HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com HOUSE_OVERSIGHT_012646

» Case 9:08-cv-80232-KAM Document 1 Entered on FLSD Docket 03/05/2008 Page 4 of 6 17. Epstein’s plan and scheme in which he committed such acts upon Jane Doe were done willfully and maliciously. 18. This sexual assault was in violation of Chapter 800 of the Florida Statutes, which ~ recognizes as a crime the lewd and lascivious acts committed by Epstein upon Jane. 19, Asadirect and proximate result of Epstein’s assault on Jane, she has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and emotional damages. . WHEREFORE, Plaintiff Jane Doe, demands jiiement against Defendant Jeffrey Epstein for compensatory damages, punitive damages, costs, and such other and further relief as this Court deems just and proper. COUNT I Intentional Infliction of Emotional Distress intentional Iniliction Of Fmouonal LIStess 20. Plaintiffs Jane Doe repeats and realleges paragraphs 1 through 14 above. 21. Epstein’s conduct was intentional or reckless. 22. Epstein's conduct was outrageous, going beyond all bounds of decency. | 23. Epstein’s conduct caused severe emotional distress to Jane Doe. Epstein knew or had reason to know that his intentional and outrageous conduct would cause emotional trauma and damage to Jane Doe. | 24. Asadirect and proximate result of Epstein’s intentional or reckless conduct, Jane Doe has suffered and will continue to suffer severe mental anguish and pain. WHEREFORE, Plaintiff Jane Doe demands judgment against Defendant Jeffrey Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this Court HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com 40f6 HOUSE_OVERSIGHT_012647

* Case 9:08-cv-80232-KAM Document 1 deems just and proper. Entered on FLSD Docket 03/05/2008 Page 5of6 JURY TRIAL DEMAND Plaintiffs demand a jury trial in this action. Dated: March “f ; 2008 HERMAN & MERMELSTEIN, P. A. S5ofé Respectfully submitted, HERMAN & MERMELSTEIN, P.A. Attorneys for Plaintiffs 18205 Biscayne Blvd. Suite 2218 Miami, Florida 33160 Tel: 305-931-2200 Fax: 305-931-0877 By: Jeffrey M. Herman [email protected] Florida Bar No. 521647 Stuart S. Mermelstein [email protected] Florida Bar No. 947245 Adam D. Horowitz Florida Bar No. 376980 [email protected] www.hermanlaw.com HOUSE_OVERSIGHT_012648

Digunet Case 9:08-cv-80232-KAM DocurfelMlk COMERGHRE ED Docket 03/05/2008 The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing, and service ng or other page Sas 8 ofS by law, except as provided by local rules of court. This form, approved by the Judiciat Conference of the United States in September 1974, is required for the use of the Clerk of the Court for the purpose of initlating the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.) DEFENDANTS JEFFREY EPSTEIN (a) PLAINTIFFS JANE DOE NO. 3, ) (b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF PALM BEACH COUNTY (EXCEPT IN U.S, PLAINTIFF CASES) COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT NEW YORK (IN U.S. PLAINTIFF CASES ONLY) (c) ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER) ATTORNEYS (IF KNOWN) Herman & Mermelstein, P.A., 18205 Biscayne Bivd., Suite 2218, Miami, FL 33160, (305) 931-2200 {d) CIRCLE COUNTY WHERE ACTION AROSE: PALM BEACH tl. BASIS OF JURISDICTION lI. CITIZENSHIP OF PRINCIPAL PARTIES PLACE AN X IN ONE BOX FOR Pence (PLACE AN X ONE BOX ONLY) (For Diversity Case Only) ; AND ONE FOR DEFENDANT PTF DEF Incorporated of Principal Place of Q4 a4 0 1. U.S. Government O 3. Federal Question Cilizen of This State x1 01 . Business in This State Plaintiff (U.S. Government Not a Party) Citizen of Another State ' Q2 x2 . Incorporated and Principal Placeof Q5 O05 O 2. US. Government X 4. Diversity Citizen or Subject of a Foreign Country Q 3 0 3 Busingss in Another State Defendant (Indicate Citizenship of Parties in Item nN) Forelgn Nation QO6 O86 iV. CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE. DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY.) DIVERSITY ACTION UNDER 28 U.S.C. §1332(a) FOR SEXUAL ASSAULT \Va._5_ days estimated (for both sides) to try entire case V. NATURE OF SUIT (PLACE AN X IN ONE BOX ONLY) A CONTRACT A TORTS B FORFEITURE A BANKRUPTCY A OTHER STATUS PENALTY 0422 Appeal 28 USC 158 0 400 Status Reappointment i 6 410 Antitrust 03423 Withdrawal 28 USC 157 1 430. Banks and Banking EB a0 Commerce/lCC Rates/etc. B Deportation A PROPERTY RIGHTS 5 70 Racketaer Intuenced and Corrupt Organizations G 810 Selective Service © 110Msurance PERSONAL INJURY 1810 Agricultura %20Marine (1 820 Other Food & Drug OF 130Miler Act 0825 Drug Related Seizure 0310 Aplano 1382 Personal InfuryMed Matpractice 0 315 Auplane Product Liability 1365 Personal InfuryProduc Liability 320 Assault, Libel & Slander (0368 Asbestos Personnel ederal Employers’ Liabfity Injury Product Llabilay O 14QNegotiable Instrument of Properly 21 USC 881 O 150Recovery of Overpayment & Enforcemant of Judgment 0650 Aline Regs 0880 Occupational $51 Medicare Act D tSzRecaveryof elated 7 PERSONAL PROPERTY Safetyhealth 2820 Copyrights 850 Securities! Commodities! Student Loans (Exc) 11680 Other (830 Patent Exchange Q 840 Trademark © 675 Customer Challange Veterans) B O 153 Racovery of Overpayment of Vetcran’s Benefits 8° 12USC3410 D 881 Agricultural Acts D 882 Economic Stabiitation Act O 883 Environmental Matters a B64 Enemy Allocation Act 0 885 Freedom of Information Act 0 800 Appeafof Fee Determination dee! saul Actess to 0371 Truth in Lending B 0380 Other Personne? Property Damage 0965 Property Damage Product Liability X 380 Other Parsonat Injury is} (ep stocknoiiers Sule O 4000ther Contra a BS Contact Produce Uabtiy . B SOCIAL SECURITY 881 HIA (1985ff) 01862 Black Lung (823) 0.883 DIWC/DIWW (405(9)) 2864 SSID Tile XVI 1865 RSI (405(9)) Oo 950 Carcusorenyel’sae O 240 Land Condemnation D 441Votng © 540Motions to Vacate Sentenca X710 Far Labor Standards. Statutes O 220 Forecasure B © 442Employment Habeas Corpus. Act © 880 Other Statutory Actions” O 230 Rent Lease & Ejectment QO 443HousingiAccommodatons G §30Genaral” 0 720 Labor Management "Aord D 240 Torts to Land D0 446 Welfare (2) $35Death Panalty Relations B A FEDERAL TAX SUITS O 245 Ton Product Liabilty G 4400ther Civil Rights O 540 Mandamus & Other 0730 Labar Management Declaratory relaf and stale law claims O 290 All Other Real Property © S550CMi Rights for defamation Raporting & Disclosure Act © 740 Ralhway Labor Act © 780 Other Labor Lilgalion 0751 Employee Ret. inc, Security Aci B “AorB 870 Taxes (U.S. Plainiltf or Oefendant) 471 IRS-Third Party 28 USC 7808 Vi. ORIGIN x1. Original 0 2. Removed from 03.Remanded from 4. Refilled 6. Multidistrict Litigation O7. Appeal to District Judge from Proceeding State Court Appellate Court 01 5. Transferred from another district (Specify) Magistrate Judgment GLARENGE MAB Vil. REQUESTED CHECK IF THIS IS A O CLASS ACTION DEMAND $ QO Check she Aded ubx YES iN COMPLAINT O UNDER F.R.C.P. 23 complaint: JURY DEMAND: . go NO Vill. RELATED (See Instructions): (SEE ATTACHED) : CASE(S) IF ANY JUDGE KENNETH A. MARRA DOCKET NUMBER 08-CV-80119-MARRA-JOHNSON Jane Doe 2 v. Jeffrey Epstein 3-W-O*€ SIGNATURE OF ATTORNEY OF RECORD UNITED STATES DISTRICT COURT FOR OFFICE USE ONLY: Recelpt No. REV. 9/94 Date Paid: I 24 R64 6of6 HOUSE_OVERSIGHT_012649

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Another suit alleges sex during massage Page 1 of 2 @2) PRINTTHIS Palm Beach Post Staff Writer . - Browse Specials Thursday, March 06, 2008 2 Deals From Local Dealerships WEST PALM BEACH — Another woman filed a federal lawsuit against Jeffrey Epstein on Wednesday, alleging that he turned a massage she gave him at his Palm Beach mansion into a sexual episode when she was 16 years old. Identified as "Jane Doe No. 3," she is seeking more than $50 million, the same as a two other "Jane Does" who filed similar lawsuits in the past six weeks. All three suits were filed by Miami lawyer Jeffrey Herman. More crime coverage Herman subsequently withdrew the first Jane Doe's lawsuit because of squabbling by her parents over the litigation. The girl may refile the suit after she turns 18 in May and can make her own decisions, Herman said. Most recent headlines Fugitives | Sex offenders crime blog Ost Other alleged victims also have contacted him, Herman said. "I do anticipate more cases," he said. More local news Latest breaking news, photos and all of today's Post stories. Share This Story In the latest litigation, Jane Doe No. 3 alleges that she was recruited by a former college student, Haley Robson, to give Epstein a massage for money at his waterfront home late in 2004 or early in.2005. The lawsuit alleges that, while on the massage table, Epstein sexually touched Jane Doe No. 3, then masturbated. She is suing on grounds of sexual assault and intentional infliction of emotional distress. "She felt intimidated. She felt scared," Herman said. Jane- Doe No. 3 made only the one visit to Epstein's home, he said. “It's just another copycat lawsuit filed by the same lawyer who appears less interested in the truth than in grandstanding with these press conferences," said Jack Goldberger, one of Epstein's attorneys. "We now have sworn testimony that girls lied about their age to Jeffrey Epstein, and they were careful in being http://palmbeachpost.printthis.clickability.com/pt/cpt?action=cpt&title=Another-+tsuittalleg... 4/2/2008 HOUSE_OVERSIGHT_012651

Another suit alleges sex during massage Page 2 of 2 convincing that they were over the age of 18." Herman said Robson instructed Jane Doe No. 3, "When he asks how old you are, tell him 18 or 19 years old." But he said it doesn't matter. "They were underage girls," Herman said. "They were sexually assaulted." OS In addition to the civil lawsuits, Epstein was indicted on a single count of felony solicitation of prostitution in July 2006 after a lengthy Palm Beach Police Department investigation into his activities with underage girls at his home. A resolution has been delayed continually. The case is on Monday's court docket but is expected to be rescheduled once again. "One of the reasons (Jane Doe No. 3) came forward is she is tired of waiting for justice," Herman said. Find this article at: : http:/Awww.palmbeachpost.com/localnews/content/local_news/epaper/2008/03/06/s3b_epstein_0306.htmI? ; cxtype=rss&cxsvc=7&cxcat=76 Check the box to include the list of links referenced in the article. http://palmbeachpost printthis.clickability.com/pt/cpt?action=cpt&title=Another+suittalleg... 4/2/2008 . HOUSE_OVERSIGHT_012652

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Jay Lefkowitz/New To Ami Sheth/New York/Kirkland-Ellis@K&E York/Kirktand-Eli Sent by: Kasin AndarsarvNee cc Eugene Kornel/New York/Kirkland-Ellis@K&E York/Kirkland-Ellis bcc 12/12/2007 04:20 PM Subject Fw: Epstein ~— Forwarded by Kristin Andersen/New York/Kirkland-Ellis on 12/12/2007 04:19 PM —-- “Sloman, Jeff (USAFLS)" ns To “Jay Lefkowitz" isn 11/27/2007 01:55 PM co "Acosta, Alex (USAFLS)" i Subject Epstein Jay, Please accept my apologies for not getting back to you sooner but I was a little under the weather yesterday. I hope that you enjoyed your Thanksgiving. Regarding the issue of due diligence concerning Judge Davis’ selection, I’d like to make a few observations. First, Guy Lewis has known for some time that Judge Davis was making reasonable efforts to secure Aaron Podhurst and Bob Josephsberg for this assignment. In fact, when I told you of Judge Davis’s selection during our meeting last Wednesday, November 21°, you and Professor Dershowitz seemed very comfortable, and certainly not surprised, with the selection. Podhurst and Josephsberg are no strangers to nearly the entire Epstein defense team including Guy Lewis, Lili Ann Sanchez, Roy Black, and, apparently, Professor Dershowitz who said he knew Mr. Josephsberg from law school. Second, Podhurst and Josephsberg have long-standing stellar reputations for their legal acumen and ethics. It’s hard for me to imagine how much more vetting needs to be done. The United States has a statutory obligation (Justice for All Act of 2004) to notify the victims of the anticipated upcoming events and their tights associated with the agreement entered into by the United States and Mr. Epstein in a timely fashion. Tomorrow will make one full week since you were formally notified of the selection. I must insist that the vetting process come to an end, Therefore, unless you provide me with a good faith objection to Judge Davis’s selection by COB tomorrow, November 28, 2007, I will authorize the notification of the victims. Should you give me the go-ahead on Podhurst and Josephsberg selection by COB tomorrow, I will simultaneously send you a draft of the letter. I intend to notify the victims by letter after COB Thursday, November 29". Thanks, Jeff HOUSE_OVERSIGHT_012654

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KIRKLAND & ELLIS LLP AND AFFILIATED PARTNERSHIPS 777 South Figueroa Street Los Angeles, Califomla 90017 Kenneth W. Starr PF Facsimile: To Call Writer Directly: (213) 680-8500 www.kiddand.com November 28, 2007 VIA FACSIMILE Honorable Alice S. Fisher Assistant Attorney General Department of Justice Criminal Division 950 Pennsylvania Avenue NW Room 2107 Washington, DC 20530 Re: Jeffrey Epstein Dear Ms. Fisher: « T represent Jeffrey Epstein, who, as you may be aware, was the target of a dual investigation by both state and federal authorities in Florida for acts relating to his interactions with numerous young women. As you may also be aware, Mr. Epstein has entered into a Deferred Prosecution Agreement (the “Agreement”) with the United States Attorney’s Office for the Southern District of Florida (the “USAO”) to resolve its criminal investigation of him. I am writing to. request a meeting with you to discuss certain aspects of this case that I find especially troublesome. As part of the agreement Mr. Epstein was required to sign to avoid a federal indictment, Mr. Epstein was required to waive jurisdiction and liability under 18 U.S.C. §2255 for the _ Settlement of monetary claims that might-be made by a group of unidentified alleged victims who will be identified by the USAO at some point in the future. Neither I, nor any of the other defense lawyers involved in this matter, have ever héard of sucha procedure. And as part of this Agreement, Mr. Epstein is precluded from contesting liability as to civil lawsuits secking monetary compensation for damages brought by any of the identified individuals who elect to : settle their civil claims for the statutory minimum of either $50,000 (the amount set by Congress as of the date of the occurrences) or $150,000 (the amount currently set by statute) or some other agreed upon damage amount. ‘We believe that the utilization of 18 U.S.C. § 2255 asa pre- condition of criminal plea agreements or nhon-prosecution agreements is highly unusual and requires careful consideration and additional guidance by your Office. We also believe that the . : \ Chicago Hang Kong London Munich New York . San Francisco Washington, D.C. HOUSE_OVERSIGHT_012656

—, ' KIRKLAND & ELLIS Honorable Alice S. Fisher November 28, 2007 Page 2 manner in which the USAO has interpreted the settlement process for these identified individuals under the Agreement requires guidance. These areas are more fully detailed below.* First. Federal criminal investigators and prosecutors should not be in the business of promoting civil lawsuits as a condition precedent to entering non-prosecution or deferred. prosecution agreements. This is especially true where the vehicle for the financial settlement under the Agreement requires payment in a lump sum without requiring proof of actual injury or loss — federal authorities should therefore be particularly sensitive to avoid causing a prejudiced and unfair result. 18 U.S.C. § 2255 is a civil statute implanted in the criminal code; in contrast to all other criminal restitution statutes, § 2255 fails to correlate payments to specific injuries or losses. Instead, the statute presumes that victims have sustained damages of at least a minimum lump sum without regard to whether the complainants suffered actual medical, psychological or other forms of individualized harm. We presume that it is for this reason that 18 U.S.C. § 2255 has never before been employed in this manner in connection with a non-prosecution or, as here, a deferred prosecution agreement. In short, the USAO is operating in uncharted territory. Second, 18 U.S.C. § 2255 creates the potential for compromising witness testimony. Although generally the Government may promise or provide traditional consideration to potential witnesses, employing a civil statute that promises a lump sumi payment to potential Witnesses without proof of actual liability or damage provides an extraordinary incentive that is incompatible with the truth-seeking functions of the criminal justice system. Guidelines or other policy directives should be considered to control the extent to which witnesses are informed by - investigators about the availability of such financial windfalls. Additionally, an inquiry is necessary in this specific case to assure that disclosures to potential witnesses did not undermine the reliability of the results of the federal criminal investigation of Mr. Epstein. Third. The USAO has provided no information as to the specific claims made by each identified individual, nor were we provided the names or ages of those individuals or the time-frame of the alleged conduct. The USAO’s reluctance to provide Mr. Epstein with any information with respect to the allegations against him leaves wide open the opportunity for misconduct by federal investigators. In addition, this information vacuum eliminates the ability for Mr. Epstein and/or his agents to verify that the allegations at issue are grounded in real evidence. Indeed, the requirement that a target of federal criminal prosecution agree to waive his tight to contest liability as to unnamed civil complainants creates at minimum an appearance of injustice, both because of the obvious Due Process concems of waiving rights without notice of * In addition to the areas identified below, it was and remains our position that federal prosecution of this matter is entirely inappropriate based on the prior application and legislative histories of the relevant federal statutes. HOUSE_OVERSIGHT_012657

KIRKLAND & ELLIS Honorable Alice S. Fisher November 28, 2007 Page 3 even the identity of the complainant(s) and because of the involvement of the federal criminal justice system in civil séttlements between private individuals. Fourth. The USAO has improperly insisted that the chosen attorney representative should be able to litigate the claims of individuals, which violates the terms of the Agreement and deeply infringes upon the spirit and nature of the Agreement. Initially, for the sake-of expediting a settlement in this matter, we suggested that Mr. Epstein establish a restitution fund specifically for the settlement of the identified individuals’ civil claims and that an impartial, independent representative be. appointed to administer that fund. Notably, such a restitution fund was created in a federal case, U.S. v. Boehm, Case No. 3:04CR00003 (D. Alaska 2004). The federal prosecutors here rejected this idea, and they insisted that an attorney representative, paid for by Mr, Epstein, be appointed. Yet, there was ho suggestion at the time that the attomey representative’s duties included litigating claims on behalf of the identified individuals. However, after the parties agreed to the appointment of an attorney representative, the prosecutors announced that the criteria for choosing an appropriate attorney representative now includéd that the individual be “a plaintiffs lawyer capable of handlirig multiple lawsuits against high profile attorneys.” This interpretation of the scope of the attorney representative’s ole is far outside the common understanding that existed when we negotiated Mr. Epstein’s settlement with the USAO. Furthermore, we firmly believe that ethics rules preclude the representative from litigating claims on behalf of the identified individuals. In sum, we believe that the actions undertaken in this matter by the USAO with respect to the 18 U.S.C. § 2255 provisions of the Agreement are highly unusual. We respectfully request a meeting with you at your earliest convenience to discuss the important issues raised by the USAO’s conduct in this deeply policy-laden matter. Sincerely, MD WS. Kenneth W. Starr HOUSE_OVERSIGHT_012658

11/28/07 WED 09:19 FAX 1 213 680 8500 KIRKLAND&ELLIS LLP (qj001 SHEXSHELES ESTE TE TTCAS BEE TX REPORT #22 ¥ELAEASRESETSELTS ATT SS TRANSMISSION OK TX/RX NO CONNECTION TEL 912025149412 SUBADDRESS CONNECTION ID ST. TIME 11/28 09:17 USAGE T_ 01°57 PGS. 4 RESULT OK KIRKLAND & ELLIS LLP Fax Transmittal 777 South Figueroa Street Los Angeles, Califomia 90017 Phone: (213) 680-8400 Fax: (213) 680-8500 Please notify us immediately.if any pages are not received. * . THE INFORMATION CONTAINED IN THIS COMMUNICATION IS CONFIDENTIAL, MAY - BE ATTORNEY-CLIENT. PRIVILEGED, MAY CONSTITUTE INSIDE INFORMATION, AND ’ 1S INTENDED ONLY FOR THE USE OF THE ADDRESSEE. UNAUTHORIZED USE, DISCLOSURE OR COPYING IS STRICTLY PROHIBITED AND MAY BE UNLAWFUL. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, ' PLEASE NOTIFY US IMMEDIATELY AT: — (213) 680-8400. To: ' Company: Hon. Alice S. Fisher | Department of Justice From: ~ Dates — , Pages wicover: Kenneth W. Starr © November 28, 2007 ' 4 Message: HOUSE_OVERSIGHT_012659

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oof "Villafana, Ann Marie C. (USAFLS)" To "Jay Lefkowitz" cc "Sloman, Jeff (USAFLS)" "Acosta, Alex (USAFLS)” bec 11/28/2007 04:46 PM Subject Epstein: Victim Notification Letter Dear Jay: Jeff asked that I forward the victim notification letter to you. It is attached. Thank you. <<Victim Notification Ltr.pdf>> A. Marie Villafania Assistant U.S. Attorney 900 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 I Victim Notification Ltr.pdf HOUSE_OVERSIGHT_012661

AN U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: (861) 820-8777 November 29, 2007 DELIVERY BY HAND Miss Re: Crime Victims’ Rights — Notification of Resolution of Epstein Investigation Dear Miss : Several months ago, I provided you with a letter notifying you of your rights as a victim pursuant to the Justice for All Act of 2004 and other federal legislation, including: (1) The right to be reasonably protected from the accused. (2) The sight to reasonable, accurate, and timely notice of any public court proceeding involving the crime or of any release or escape of the accused. (3) The right not to be excluded from any public court proceeding, unless the court determines that your testimony may be materially altered if you are present for other portions of a proceeding. (4) The right to be reasonably heard at any public proceeding in the district court involving release, plea, or sentencing. (5) The reasonable right to confer with the attorney for the United States in the case. (6) The right to full and timely restitution as provided in law. (7) The right to proceedings free from unreasonable delay. (8) The right to be treated with fairness and with respect for the victim's dignity and privacy. I am writing to inform you that the federal investigation of Jeffrey Epstein has been completed, and Mr. Epstein and the U.S. Attorney’s Office have reached an agreement containing the following terms. /ill plead guilty to two state offenses, includi which will require him to register as HOUSE_OVERSIGHT_012662

Miss NOVEMBER 29, 2007 PAGE 2 Second, Mr. Epstein has agreed to make a binding recommendation of 18 months’ imprisonment to the state court judge who sentences him. Mr. Epstein will serve that sentence of imprisonment at the Palm Beach County Jail. Third, Mr. Epstein has agreed that h if you elect to jages from him because the United States has identified you as a minor victim of certain federal offenses, including travel in interstate commerce to engage in prostitution with minors and anticipate that someone from their law firm will be contacting you shortly. ‘must also advise you that you are not obligated to use these attorneys. In fact, you have the absolute right to select your own attorney, so you can decide not to speak with Mssrs. Podhurst/ losefsberg at all, or you can speak with them and decide at any tim i § § . 4 you are unable to reach a settlement with Mr. Epstein, you and Mr. Josefsberg can discuss how best to proceed. As I mentioned above, as part of the resolution of the federal investigation, Mr. Epstein has agreed to plead guilty to state charges. Mr. Epstein’s change of plea and sentencing will occur on December 14, 2007, at a.m., before Judge Sandra K. McSorley, in Courtroom 11F at the Palm Beach County Courthouse, 205 North Dixie Highway, West Palm Beach, Florida. Pursuant t i Sections 960.001 (1)(k) and 921.143(1) gat: If you choose, you can submit a written statement under oath, which will be filed by the State Attorney’s Office on your behalf. If you elect to prepare a written statement, it should address the following: the facts of the case and the extent of any harm, including social, psychological, or physical harm, financial losses, loss of earnings directly or indirectly resulting from the crime for which the defendant is being sentenced, and any matter relevant to an appropriate disposition and sentence. FI. Stat. 921.143(2). You also are entitled to notification when Mr. Epstein is released from imprisonment at the end of his prison term and/or if he is allowed to participate in a work release program. To receive such notification, please provide the State Attorney’s Office with the following information: 1. Your name 2. Your address 3. Your home, work, and/or cell phone numbers HOUSE_OVERSIGHT_012663

Miss NOVEMBER 29, 2007 PAGE 3 4. Your e-mail address 5. A notation of whether you would like to participate in the “VINE system,” which provides automated notification calls any time an inmate is moved. (To use this system, your calls must go to you directly, not through a switchboard.) Thank you for all of your help during the course of the investigation. If you have any questions or concerns, please do not hesitate to contact me or Special Agent Nesbitt Kuyrkendall at (561) 822-5946. Sincerely, R. Alexander Acosta United States Attorney By: A. Marie Villafafia Assistant United States Attorney cc: Special Agent Nesbitt Kuyrkendall, F.B.1. Ms. Clearetha Wright, Victim-Witness Coordinator, U.S. Attorney’s Office HOUSE_OVERSIGHT_012664

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cc "Oosterbaan, Andrew" 02/27/2008 09:45 PM bec Subject Fw: Epstein Sent from my BlackBerry Wireless Handheld ----- Original Message ----- From: Jeffrey Sloman To: Sloman, Jeff (USAFLS) Sent: Wed Feb 27 21:37:02 2008 Subject: Epstein Jay, You have renewed your request for certain information which this Office does not generally make available in similar pre-indictment situations. After carefully considering your request, I have decided, in my capacity as the First Assistant U.S. Attorney, not to make an exception here. Regarding the Landon Thomas matter, Mr. Thomas was given, pursuant to his request, non-case specific information concerning specific federal statutes. Regarding the offer to extend the current deadline of March 3, 2008 contained in my February 25th email. That offer was based on counsel for Mr. Epstein meeting with CEOS the week of March 3rd. You indicate that you are unavailable. It is hard to imagine that some or all of the other attorneys representing Mr. Epstein cannot serve this function. After all, Mr. Epstein is also represented by Dean Kenneth Starr, Martin Weinberg, Roy Black, Gerald Lefcourt, Harvard Professor Alan Dershowitz, Lily Ann Sanchez, and Guy Lewis. That being said, the Southern District of Florida will only renew the offer to extend the current deadline if you and the CEOS Section Chief mutually agree on a timetable by close of business on Friday, February 29, 2008 to meet and complete presentations no later than March 19, 2008. Given that CEOS is ready to proceed immediately, this seems like more than ample time. As I indicated in my previous email, if CEOS subsequently decides that a federal prosecution should not be undertaken against Mr. Epstein, this Office will close its investigation. However, should CEOS disagree with Mr. Epstein’s position, Mr. Epstein shall have one week to abide by the terms and conditions of the September 24, 2007 Agreement as amended by letter from United States Attorney Acosta. HOUSE_OVERSIGHT_012666

ia Me Jeffrey H. Sloman First Asst. US Attorney Southern District of Florida HOUSE_OVERSIGHT_012667

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[dj001/006 05/16/2008 11:16 FAX Boor 05/16/08 FRI 11:08 FAX a § SNITED STATES DEPARTMENT OF J USTICE Criminal Division Chita Exploitation and Obscenity Section 1400 New York Avenue, NW oe ‘CEOS: (202) 5 14-5780 Suite 600 . Washington, DC eyes OL ee PAX: (202) 514-1793 FO: ~R. Alexander Acosta, Esq. . Jay Lefkowitz, Esq. . OFFICE NUMBER: FROM: Alexandra Gelber. DATE/TIME: . May 16, 2008 . OFFICE NUMBER: = (202) 514-5780 | NUMBER OF PAGES, EXCLUDING THIS SHEET: 5 ‘SPECIAL INSTRUCTIONS: — HOUSE_OVERSIGHT_012669

0027006 05/16/2008 11:16 FAX gooz a 05/16/08 FRI 11:08 FAX U.S, Department of Justice Criminal Division Andrew G, Oosterbaan, Chief 1460 New York Avanue, NW Suite 600 Washington, DC 20530 (202) 514-8780 FAN: (202) §}4-1793 Child Exploitation and Obscenity Section May 15, 2008 Jay Lefkowitz, Esq. Kirkland & Ellis LLP Citigroup Center | 153 E. 53™ St. New York, NY 10022-4611 Re: Investigation of Jeffery Epstein Dear Mr. Lefkowitz: Pursuant to your request and the request of U.S. Attorney R. Alexander Acosta, we have independently evaluated certain issues raised in the investigation of Jeffrey Epstein to determine federal prosecution. We have discussed the factual and legal issues you raise with the Criminal Division’s Appellate Section, and we consulted with the Office of Enforcement Operations concerning the petite policy. We are examining the narrow question as to whether there is a legitimate basis for the U.S. Attorney’s Office to proceed with a federal prosecution of Mr. Epstein. Ultimately, the prosecutorial decision making authority within a U.S, Attomey’s Office lies with the U.S. Attommey. Therefore, to borrow a phrase from the case law, the question we sought to answer was whether U.S, Attemey Acosta would abuse his discretion if he authorized prosecution in this case. As you know, our review of this case is limited, both factually and legally. We have not looked at the entire universe of facts in this case. It is not the role of the Criminal Division to re- conduct a complete factual inquiry from scratch. Furthermore, we did not analyze any issues _ concerming prosecution under federal Statutes that do not pertain to child exploitation, such as the money laundering statutes, HOUSE_OVERSIGHT_012670

{2003/7006 05/16/2008 11:16 FAX 003 05/16/08 FRI 11:08 FAX As was made clear at the outset, we did not review the facts, circumstances, or terms included in the plea offer, nor any allegations that individuals involved in the investigation engaged in misconduct. Despite that agreement, we note that your letters of April 8, April 28, and May 14 focus in large part on accusations of investigative or prosecutorial misconduct. Not only do allegations of prosecutorial misconduct fall outside the boundary of our agreed review, they also fall outside the authority of the Criminal Division in the first instance. Simply, the Criminal Division does not investi gate or resolve allegations of professional misconduct by federal prosecutors. For these Teasons, we do not respond to the portion of those letters that discuss alleged misconduct, Based on our review of all of these materials, and after careful consideration of the issues, we conclude that U.S. Attomey Acosta could properly use his discretion to authorize prosecution in this case. We will briefly address each of the issues that you have raised, Knowledge of age. Federal child exploitation statutes differ as to whether there must be proof that the defendant was aware that the children were under the age of 18. However, even for those statutes where knowledge of age is an element of the offense, it is possible to satisfy that element with proof that the defendant was deliberately ignorant of facts which would suggest that the person was a minor. For that reason, the fact that some of the individuals allegedly lied to Mr. Epstein about their age is not dispositive of the issue. While there may be an open factual issue as to Mr. Epstein’s knowledge, we cannot say that it would be impossible to prove knowledge of age for any such charges which require it. Therefore, Mr. Acosta could rightfully conclude that this factual issue is best resolved by a jury. Travel for the purpose. In the materials you prepared, you suggest that Mr. Epstein should not be charged with violating 18 U.S.C. § 2423(b) because his dominant purpose in going to Florida was not to engage in iNegal sexual activity, but rather to return to one of his residences, While we fully understand your argument, we also find that the U.S. Attorney’s office has a good faith basis fully to develop the facts on this issue and brief the law to permit a court to decide whether the law properly reaches such conduct. Mr. Acosta would not be abusing his discretion if he decided to pursue such a course of action, 2 HOUSE_OVERSIGHT_012671

2] 004/006 05/16/2008 11:16 FAX ioe 05/16/08 FRI 11:09 FAX 80 novel as to implicate the so-called “‘clear statement rule,” the Ex Post Facto clause, or the Due Process clause. As with the other legal issues, Mr. Acosta may elect to proceed with the case. Absence of coercion. With respect to 18 U.S.C, § 1591, the alleged absence of the use of force, fraud, or coercion is of no moment. The statute does not require the use of force, fraud, and coercion against minors. Because of their age, a degree of coercion is presumed. In your materials, you note that the statute requires that the minors must be “caused” to engage ina conunercial sex act, further arguing that the word “cause” suggests that a certain amount of undue influerice was used, We reject that interpretation, as it would read back into the offense an element-coercion—that Congress has expressly excluded. We have successfully prosecuted | defendants for the commercial sexual exploitation of minors, even when the minors testified that not only did they voluntarily engage in the commercial sex acts, it was their idea to do so. As such, Mr. Acosta could properly decide to pursue charges under Section 1591 even if there is no evidence of coercion. More broadly, a defendant’s criminal liabili ty does not hinge on his victim i dentifying as having suffered at his hands. Therefore, a prosecution could proceed, should Mr. Acosta decide to do so, even though some of the young women allegedly have said that they do not view themselves as victims, Witness credibility. As all prosecutors know, there are no perfect witnesses. Particularly in Cases involving exploited children, as one member of your defense team, Ms, Thacker, surely knows from her work at CEOS, it is not uncommon for victim-witnesses to give conflicting statements. The prosecutors are in the best position to assess the witness's credibility, Often, the Prosecutor may decide that the best approach is to present the witness, let defeuse counsel explore the credibili ty problems on cross-cxamination, and let the jury resolve the issue. Mr. Acosta would be within his authority to select that approach, especially when here there are nuultiple, mutually-corroborating witnesses. Contradictions and omissions in the search warrant application, We have carefully reviewed the factual issues you raise conceming the search warrant application. For a search warrant to be suppressed, however, the factual errors must be material, and the officers must nor have proceeded in good faith, Despite the numerous factual errors you describe, the U.S. Attomey’s Office could stil] plausibly argue that the mistakes—whether inadvertent or intentional—were not material to the determination that probable cause existed for a search, and that the search was in good faith in any event. As such, Mr. Acosta could properly elect to defend the search warrant in court rather than forego prosecution. Petite Policy: After reviewing the petite policy and consulting with the Office of Enforcement Operations (“OEO”), we conclude that the petite policy does not prohibit federal prosecution in this case, According to the U.S. Attomey’s Manual, the petite policy “applies whenever there has been a prior state or federal prosecution resulting in an acquittal, a conviction, including one resulting from a plea agreement, or a dismissal or other termination of 3 HOUSE_OVERSIGHT_012672

[41005/006 05/16/2008 11:17 FAX os 05/18/08 FRI 11:09 FAX the case on the merits after jeopardy has attached.” USAM 9-2.03 W(C). Our understanding is - that the state case is stil] pending. As such, the procedural posture of the state case does not implicate the petite policy. the policy “does not apply ... where the [state] prosecution, involved only 4 minor part of the contemplated federal charges.” USAM 9-2.03 1(B). Based on our understanding of the possible federal charges and existing state charges, we do not think the petite policy would be an issue should federal proceedings take place, Federalism and Prosecutorial Discretion. All of the above issues essentially ask whether a federal prosecution can proceed. We understand, however, that you also ask whether a federal prosecution skoudd proceed, even in the event that all of the elements of a federal offense could be proven. On this issue, you raised two arguments: thal the conduct at issue here is traditional ly a4 state concern because the activity is entirely local, and that the typical prosecution under federal policy that a United States Attomey’s Office should not pursue a prosecution. We do not think Simply, the commercial sexual exploitation of children is a federal concern, even when the conduct is local, and tegardless of whether the defendant provided the child (the “pimp”) or fraud, or coercion was used. Indeed, the point being made in that letter is that the Department’s efforts are Properly focused on the commercial sexual exploitation of children and the exploitation of adults through the use of force, fraud, or coercion, As such, there is no inconsistency between the position taken in that letter and the federal prosecution of wholly local instances of the commercial Sexual exploitation of children, If Congress wanted to limit the reach of federal statutes only to those who profit from the commercial sexual exploitation of children, or only to those who actually traffic children across state lines, it could have done so. It did not. Finally, that a prosecution of Mr. Epstein might not look precisely like the cases that came before it is not dispositive, We can say with confidence that this case is consistent in principle with other federal prosecutions nationwide. As such, Mr, Acosta can soundly exercise his authority to decide to pursve 4 prosecution even though it might involve a novel application of a federal statute, Conclusion. After carefully considering all the factual and legal issues taised, as well as the arguments concerning the general propriety of a federal case against Mr. Epstein on these 4 HOUSE_OVERSIGHT_012673

kj006/006 05/16/2008 11:17 FAX Bons 05/16/68 FRI 11:10 FAX facts, we conclude that federal prosecution in this case would not be improper or inappropriate, While you raise many compelling arguments, we do not see anything that says to us categorically that a federal case should not be brought. Mr. Acosta would nat be abusing his prosecutorial discretion should he authorize federal prosecution of Mr. a a cc: AAG Alice S. Fisher DAAG Sigal P. Mandetker ( U.S. Attorney R. Alexander Acosta HOUSE_OVERSIGHT_012674

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Jay Lefkowitz/New To Ami Sheth/New York/Kirkland-Ellis@K&E Sent byt Kilt Areiersen iRexe ce Eugene Kornel/New York/Kirkland-Ellis@K&E York/Kirkland-Ellis bec 42/12/2007 04:19 PM Subject Fw: Epstein ----~ Forwarded by Kristin Andersen/New York/Kirkland-Ellis on 12/12/2007 04:19 PM ----- Jay Lefkowitz/New York/Kirkland-Ellis To "Sloman, Jeff (USAFLS)" 11/28/2007 04:29 PM cc "Acosta, Alex (USAFLS)" Subject Re: Epstein) Dear Jeff: I received your email yesterday and was a little surprised at the tone of your letter, given the fact that we spoke last week and had what I thought was a productive meeting. I was especially surprised given that your letter arrived on only the second day back to work after the Thanksgiving Holiday, and yet your demands regarding timing suggest that I have been sitting on my hands for days. You should know that the first time I learned about Judge Davis’s selection of Podhurst and Josephsberg, and indeed the first time I ever heard their names, was in our meeting with you on Wednesday of last week. Nevertheless, I have now been able to confer with my client, and we have determined that the selection of Podhurst and Josephsberg are acceptable to us, reserving, of course, our previously stated objections to the manner in which you have interpreted the section 2255 portions of the Agreement. We do, however, strongly and emphatically object to your sending a letter to the alleged victims. Without a fair opportunity to review and the ability to make objections to this letter, it is completely unacceptable that you would send it without our consideration. Additionally, given that the US Attorney’s office has made clear it cannot vouch for the claims of the victims, it would be incendiary and inappropriate for your Office to send such a letter. Indeed, because it is a certainty that any such letter would immediately be leaked to the press, your actions will only have the effect of injuring Mr. Epstein and promoting spurious civil litigation directed at him. We believe it is entirely unprecedented, and in any event, inappropriate for the Government to be the instigator of such lawsuits. Finally, we disagree with your view that you are required to notify the alleged victims pursuant to the Justice for All Act of 2004. First, 18 USC section 2255, the relevant statute under the Non-Prosecution Agreement for the settlement of civil remedies, does not have any connection to the Justice for All Act. Section 2255 was enacted as part of a different statute. Second, the Justice for All Act refers to restitution, and section 2255 is not a restitution statute. It is a civil remedy. As you know, we had offered to provide a restitution fund for the alleged . HOUSE_OVERSIGHT_012676

AE AOE UAYAL AMMO) 2RO YUU RU TY, WO MEU UL WU PLU LUN @ LOL U LULU LU LUN age victims in this matter; however that option was rejected by your Office. Had that option been chosen, we would not object to your notifying the alleged victims at this point. At this juncture, however, we do not accept your contention that there is a requirement that the government notify the alleged victims of a potential civil remedy in this case. Accordingly, for all the reasons we have stated above, we respectfully -- and firmly -- object to your sending any letter whatsoever to the alleged victims in this matter. Furthermore, if a letter is to be sent to these individuals, we believe we should have a right to review and make objections to that submission prior to it being sent to any alleged victims. We also request that if your Office believes that it must send a letter to go to the alleged victims, who still have not been identified to us, it should happen only after Mr. Epstein has entered his plea. This letter should then come from the attorney representative, and not from the Government, to avoid any bias. As you know, Judge Starr has requested a meeting with Assistant Attorney General Fisher to address what we believe is the unprecedented nature of the section 2255 component of the Agreement. We are hopeful that this meeting will take place as early as next week. Accordingly, we respectfully request that we postpone our discussion of sending a letter to the alleged victims until after that meeting. We strongly believe that rushing to send any letter out this week is not the wisest manner in which to proceed. Given that Mr. Epstein will not even enter his plea for another few weeks, time is clearly not of the essence regarding any notification to the identified individuals. Thanks very much, Jay “Sloman, Jeff (USAFLS)" To “Jay Lefkowitz" . 11/27/2007 01:55 PM ce "Acosta, Alex (USAFLS)" Po Subject Epstein Jay, Please accept my apologies for not getting back to you sooner but I was a little under the weather yesterday. I hope that you enjoyed your Thanksgiving. Regarding the issue of due diligence concerning Judge Davis’ selection, I’d like to make a few observations. First, Guy Lewis has known for some time that Judge Davis was making reasonable efforts to secure Aaron Podhurst and Bob Josephsberg for this assignment. In fact, when I told you of Judge Davis’s selection during our meeting last Wednesday, November 21°, HOUSE_OVERSIGHT_012677

you and Professor Dershowitz seemed very comfortable, and certainly not surprised, with the selection. Podhurst and Josephsberg are no strangers to nearly the entire Epstein defense team including Guy Lewis, Lili Ann Sanchez, Roy Black, and, apparently, Professor Dershowitz who said he knew Mr. Josephsberg from law school. Second, Podhurst and Josephsberg have long-standing stellar reputations for their legal acumen and ethics. It’s hard for me to imagine how much more vetting needs to be done. The United States has a statutory obligation (Justice for All Act of 2004) to notify the victims of the anticipated upcoming events and their rights associated with the agreement entered into. by the United States and Mr. Epstein in a timely fashion. Tomorrow will make one full week since you were formally notified of the selection. I must insist that the vetting process come to an end. Therefore, unless you provide me with a good faith objection to Judge Davis’s selection by COB tomorrow, November 28, 2007, I will authorize the notification of the victims. Should you give me the go-ahead on Podhurst and Josephsberg selection by COB tomorrow, I will simultaneously send you a draft of the letter. I intend to notify the victims by letter after COB Thursday, November 29", Thanks, Jeff HOUSE_OVERSIGHT_012678

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**TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication (including attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. If you would like such advice, please contact us.*** *** Attention: The information contained in this E-mail message is attorney privileged and confidential information intended only for the use of the individual(s) named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this communication is strictly prohibited. If you have received this communication in error, please contact the sender by reply E-mail and destroy all copies of the original message. Thank you. “= Message from "A. on Fri, ----- To: "Lilly Subject: Menchel Dear Lilly: Thank you for your letter of August 2nd regarding your proposal on how to resolve the Epstein matter. ‘ As we explained at our meeting on July 31, 2007, the Office believes that the federal interest will not be vindicated in the absence of a two-year term of state imprisonment for Mr. Epstein. That offer was not meant as a starting point for negotiations, it is the minimum term of imprisonment that will obviate the need for federal prosecution. The Office has never agreed that a state prison sentence is not appropriate for Mr. Epstein. Rather we simply stated that if Mr. Epstein preferred to serve his sentence in a federal penetentiary, we would be willing to explore a federal conviction that may allow that in lieu of any state resolution. Further, as I made clear in HOUSE_OVERSIGHT_012680

our follow up telephone conversation after the meeting, a plea to two federal misdemeanors was never extended or meant as an offer. We also would reiterate that the agreement to Section 2255 liability applies to all of the minor girls identified during the federal investigation, not just the 12 that form the basis of an initial planned charging instrument. As you know, the ability to engage in flexible plea negotiations is dramatically changed upon the return of an indictment. Once an indictment is returned, the Office does not intend to file a Superseding Information containing a lesser charge or to dismiss the case in favor of state prosecution. Please let us know your client’s decision by no later than August 17. I have conferred with U.S. Attorney Acosta who has asked me to communicate that the two-year term of incarceration is a non-negotiable minimum to vindicate a federal interest, and, at this time, he is not inclined to meet with counsel for Mr. Epstein. Sincerely, R. Alexander Acosta United States Attorney By: Matthew Menchel — Chief, Criminal Division cc: Roy Black Gerald Lefcourt R. Alexander Acosta Jeffrey Sloman Andrew Lourie A. Marie Villafafia Margot Moss, Esq. Fowler White Burnett, PA Espirito Santo Plaza 1395 Brickell Avenue, 14th Floor Miami, FL 33131 HOUSE_OVERSIGHT_012681

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To “Jey Leto" cc 10/31/2007 04:33 PM . bec Subject Epstein Jay, Your understanding from Jack Goldberger conforms to my understanding that Mr. Epstein’s plea and sentence will take place on the same day. I understand that the plea and sentence will occur on or before the January 4th date. Jeff HOUSE_OVERSIGHT_012683