IFiling # 101840557 E-Filed 01/17/2020 12:23:06 PM i i ! | IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CA FLORIDA HOLDINGS, LLC, Publisher of THE PALMBEACH POST, CASE NO.: 50-2019-CA-O14681-XXXX-MB Div.: AG Plaintiff, v. DAVE ARONBERG, as State Attorney of Palm Beach County, Florida; SHARON R. BOCK, as Clerk and Comptroller of Palm Beach County, Florida, Defendants. FIRST AMENDED COMPLAINT CA Florida Holdings, LLC, publisher of The Palm Beach Post, for its First Amended Complaint against Dave Aronberg, the State Attorney for Palm Beach County, Florida, in his official capacity (“State Attorney”), and Sharon R. Bock, the Clerk of the Court for Palm Beach County, Florida, in her official capacity (“Court Clerk”), alleges as follows: JURISDICTION L This is an action within the exclusive,jurisdiction of the Circuit Court pursuant to Fla. Stat. Sections 26.012(2)(a) and 86.011 et seq. PARTIES 2. The Palm Beach Post is a daily community newspaper published by Plaintiff CA Florida Holdings, LLC, with offices located at 2751 S- Dixie Highway, West Palm Beach, Florida. 3. Defendant Dave Aronberg is the duly elected State Attorney for the Fifteenth Judicial Circuit in and for Palm Beach County, Florida, pursuant to Fla. Stat. Section 27.01 and has authority in grand jury proceedings pursuant to Fla. Stat, Section 27.03. He is sued herein in Party JOINT . ID#. J09 EV#Jbq DATE ADMITTED: Case No. 2019-CA-014681 JOSEPH ABRUZZO CLERK x CIRCUIT COURT —* Joint Exhibit J09 - CA/ArcFiBHgJOMtM BEACH COUNTY, FL, JiBfePH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM ’ 1 NOT A CERTIFIED COPY _ IFiling # 101_840557 E-Filed 0l/17/2020 12:23:06 PM IN THE CIRCUIT I COURT OF THE FIFTEENTH JUDICIAi, CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CA FLORIDA HQLDINCrS, LLC, Publisher of THE_PAIM BEACH POST, CASE NO,: 50-2019-CA-:014681.,XXXX-MB Div_.: AG Plaintiff, v. DA VE ARONBERG, as State Attorney of Palm Beach County, Florida; SHARON R. BOCK, as Clerk and Comptroller of Palm Beach County, Florida, Defendants. FIRST AMENDED COMPLAINT CA Florida Holdings, LLC, publisher of Th_e Palri1 Bedch Post, fot its First Amended Complaint agains~ Dave Aronberg, the State Attqrney for Palm Beach County, Florida, in his official capacity ("State Attorney"), _and Sharon R. Bock, .the Clerk of the :Court for Palm Beach County, Florida, iil her official capacity ("Court Clerk"), alleges as follows: JURISDICTION l. This is ari action Within the exclusivejuri•sdiction offue Circuit Court purst.fant to Fla. Stat. Sections 26.0i2(2)(a) and 86.0li et seq. PARTIES 2. The Palm Beach Post is a daily community newspaper published by Plaintiff CA Flonda_Hcildings, LLC, with offices located at 2751 S. Dixie Highway, West Palm_ Be~ch, Florida. 3. Defendant Dave Aronberg is the duly elected State Aitofney for the Fifteenth Judicial Circuit in and for Palm:i3each County, Florida, pursuantto Fla. Stat. Section 27.01 and ha~ ~uthqrity in grand jury proceedjngs pursuant_t.o Fla. Stat. Section 27.0f He is sued herein in • r ' Party JOINT ID#.J09 EV#Jbg_ DATEADMITTEO: q lf:J{'2o22 Case No. 2019-CA-014681 JOSEPH ABRUZZO CLERK vC"'l-. c1Rcurr COURT CA/Arct'ihsRli)-01)~1,M BEACH COUNTY, FL, JtmEPH ABRUZZO, CLERK. 3✓27/2023 2:57:43 PM ' • I » I I ; I his official capacity as his office is in possession and/or control of documents that are the subject of this action. 4. Defendant Sharon R. Bock is the duly elected Clerk and Comptroller ofPalm Beach County, Florida. She is sued herein in her official capacity as her office is in possession and/or control of documents that are the subject ofthis action. INTRODUCTION 5. In what is now widely if belatedly recognized as a colossal miscarriage ofjustice - which led to the further needless victimization of countless young girls and women - a wealthy, politically connected, and powerful financier was not held accountable for, nor even forced to confront, allegations of serious sex trafficking crimes. While it is clear that Jeffrey Epstein’s 2008 deal with the State of Florida was not consistent with the evidence gathered against him, what remains shrouded in mystery is how that evidence was presented - and the extent to which it was presented - to the grand jury that returned an indictment far more limited in scope than expected and deserved. 6. Through this action, The Palm Beach Post seeks public access to the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County grand jury empaneled during the first Epstein sex abuse investigation. Typically, access to such materials is limited, for example, in order to prevent the flight of those whose indictment may be contemplated and their ability to conceal or destroy evidence; to ensure jurors’ candor in deliberations; and to protect an accused who is later exonerated. However, these factors are inapplicable here. Also, Florida law expressly authorizes the disclosure of grand jury proceedings under certain circumstances, including, as here, in the furtherance ofjustice. Fla. Stat. § 905.27(l)(c). 7. It can no longer credibly be maintained that continued blanket secrecy over the proceedings that led to the egregiously flawed 2006 Epstein indictment is warranted under the law. 2 CA/Aronbera-000118 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY I I I his official capacity as his office is in possession and/or control of documei;its that are the subject of this action. 4. Defendant Sharon R. Bock is the duly elected Clerk and Comptroller of Palm Beach County, Florida. She is sued herein in her official capacity as her office is in possession and/or control of documents that are the subject of this action. INTRODUCTION 5. In what is now widely if belatedly recognized as a colossal miscarriage of justice- which led to the further needless victimization of countless young girls and women - a wealthy, politically connected, and powerful financier was not held accountable for, nor even forced to confront, allegations of serious sex trafficking crimes. While it is clear that Jeffrey Epstein's 2008 deal with the State of Florida was not consistent with the evidence gathered against him, what remains shrouded in mystery is how that evidence was presented - and the extent to which it was presented - to the grand jury that returned an indictment far more limited in scope than expected and deserved. 6. Through this action, The Palm Beach Post seeks public access to the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County grand jury empaneled during the first Epstein sex abuse investigation. Typically, access to such materials is limited, for example, in order to prevent the flight of those whose indictment may be contemplated and their ability to conceal or destroy evidence; to ensure jurors' candor in deliberations; and to protect an accused who is later exonerated. However, these factors are inapplicable here. Also, Florida law expressly authorizes the disclosure of grand jury proceedings under certain circumstances, including, as here, in the furtherance of justice. Fla. Stat.§ 905.27(l)(c). 7. It can no longer credibly be maintained that continued blanket secrecy over the proceedings that led to the egregiously flawed 2006 Epstein indictment is warranted under the law. 2 CA/Aronbem:-000118 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM To the contrary, transparency is required to promote public understanding of the criminal justice system and public confidence in the fair administration ofjustice. As detailed below, Epstein was accused of sexually abusing and trafficking dozens of women and girls in south Florida (among other locations) over a period of several years while exploiting his wealth and political connections to obstruct the administration ofjustice at every turn. Public disclosure of the Epstein grand jury proceedings will shed light on the extent to which those in our government entrusted with the solemn responsibility of enforcing our criminal laws equally as to all citizens fulfilled their duties in this instance. Justice will be furthered where it is either (1) demonstrated that Epstein was treated like others accused of similar heinous crimes, or (2) as appears more likely to be the case, those who chose to give Epstein favorable - “unusual,” in the words of the Town of Palm Beach Police Chief- treatment, are exposed and held accountable. From what limited information is now in the public domain, the State Attorney’s referral of Epstein’s case to the grand jury - which would be out of the ordinary for this type of case - gives rise to a strong inference of favoritism and corresponding disregard for the rights of the minor victims ofEpstein’s sex trafficking. Access to the grand jury materials will allow the public to determine whether the grand jury process, and the secrecy that comes with it, was used to further justice or, instead, operated to shield Epstein and his co-conspirators from the consequences of their criminal activities. Accordingly, Fla. Stat. Section 905.27 authorizes the disclosure ofEpstein’s 2006 grand jury proceedings. 8. Even in the absence of such a statutory basis, this Court is empowered to order public disclosure pursuant to its inherent authority and supervisory powers over the grand jury. Indeed, courts throughout the country in the past several decades have ordered the disclosure of high-profile grand jury proceedings pursuant to their inherent authority where the public’s interest in those proceedings has outweighed the general need for secrecy. This is particularly so where, 3 CA/Aronbera-000119 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY To the contrary, transparency is required to promote public understanding ~f the criminal justice system and public confidence in the fair administration of justice. As detailed below, Epstein was accused of sexually abusing and trafficking dozens of women and girls in south Florida (among other locations) over a period of several years while exploiting his wealth and political connections to obstruct the administration of justice at every tum. Public disclosure of the Epstein grand jury proceedings will shed light on the extent to which those in our government entrusted with the solemn responsibility of enforcing our criminal laws equally as to all citizens fulfilled their duties in this instance. Justice will be furthered where it is either (1) demonstrated that Epstein was treated like others accused of similar heinous crimes, or (2) as appears more likely to be the case, those who chose to give Epstein favorable - "unusual," in the words of the Town of Palm Beach Police Chief - treatment, are exposed and held accountable. From what limited information is now in the public domain, the State Attorney's referral of Epstein's case to the grand jury -which would be out of the ordinary for this type of case - gives rise to a strong inference of favoritism and corresponding disregard for the rights of the minor victims of Epstein's sex trafficking. Access to the grand jury materials will allow the public to determine whether the grand jury process, and the secrecy that comes with it, was used to further justice or, instead, operated to shield Epstein and his co-conspirators from the consequences of their criminal activities. Accordingly, Fla. Stat. Section 905.27 authorizes the disclosure of Epstein's 2006 grand jury proceedings. 8. Even in the absence of such a statutory basis, this Court is empowered to order public disclosure pursuant to its inherent authority and supervisory powers over the grand jury. Indeed, courts throughout the country in the past several decades have ordered the disclosure of high-profile grand jury proceedings pursuant to their inherent authority where the public's interest in those proceedings has outweighed the general need for secrecy. This is particularly so where, 3 CA/AronbeLQ.:-000119 FILb1J: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM as here, many of the details of Epstein’s criminal misdeeds have already been made available in the public domain through extensive news reporting by, among others, The Palm Beach Post, by the many civil suits brought against Epstein and his co-conspirators; and by the victims themselves. 9. In recognition of the sensitivity of the materials being sought, and in the interest of protecting any victims who wish to remain anonymous, The Palm Beach Post has no objection to copies of the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County grand jury first being submitted to this Court for in camera review, where they may be redacted, as appropriate, to protect those who deserve such protection. FACTUAL BACKGROUND 10. The following facts were gathered, in large part, from documents obtained by The Palm Beach Post through various Florida Public Records Law requests, documents unsealed or publicly available in other related judicial proceedings, and information and documents in the public record. A. First Epstein Sex Crimes Investigation, Indictment, and Plea Agreement: 2005—2008. 11. The investigation into Epstein’s sex crimes began more than fourteen years ago, when a 14-year-old girl’s stepmother reported to police in the Town of Palm Beach, Florida, that Epstein and others who worked for him arranged for her to give Epstein a “massage.” Epstein required the girl to strip, exposed himself, and masturbated while touching her. The girl was paid S300. Epstein was 52 years old at the time. 12. Following this initial report in 2005, the Town of Palm Beach Police, and later, in 2006, the FBI, investigated Epstein. Interviews under oath with five additional alleged victims and seventeen witnesses revealed that the events described by the 14-year-old girl occurred, with disturbingly similar details, with each of the other victims. I 4 ! BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY • as here, many of the details of Epstein's criminal misdeeds have already b,een made available in ' the public domain through extensive news reporting by, among others, Th~ Palm Beach Post; by the many civil suits brought against Epstein and his co-conspirators; and by the victims themselves. 9. In recognition of the sensitivity of the materials being sought, and in the interest of protecting any victims who wish to remain anonymous, The Palm Beach Post has no objection to copies of the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County grand jury first being submitted to this Court for in camera review, where they may be redacted, as appropriate, to protect those who deserve such protection. FACTUAL BACKGROUND 10. The following facts were gathered, in large part, from documents obtained by The Palm Beach Post through various Florida Public Records Law requests, documents unsealed or publicly available in other related judicial proceedings, and information and documents in the public record. A. First Epstein Sex Crimes Investigation, Indictment, and Plea Agreement: 2005--2008. 11. The investigation into Epstein's sex crimes began more than fourteen years ago, when a 14-year-old girl's stepmother reported to police in the Town of Palm Beach, Florida, that Epstein and others who worked for him arranged for her to give Epstein a "massage." Epstein required the girl to strip, exposed himself, and masturbated while touching her. The girl was paid $300. Epstein was 52 years old at the time. 12. Following this initial report in 2005, the Town of Palm Beach Police, and later, in 2006, the FBI, investigated Epstein. Interviews under oath with five additional alleged victims and seventeen witnesses revealed that the events described by the 14-year-old girl occurred, with disturbingly similar details, with each of the other victims. 4 CA/Aroptffil5?Wl\3Bi BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 13. Both the victim/witness interviews, as well as evidence retrieved following a search of Epstein’s home, showed that some of the girls involved were under the-age of 18. The police search of Epstein’s residence also found two hidden cameras and, throughout the house, large numbers of nude photos of girls, including victims whom the police had not interviewed in the course oftheir investigation. 14. In March 2006, a State grand jury was scheduled at which all of the victims were expected to testify. The proceeding was postponed, however, due to meetings between the State Attorney’s office and Epstein’s prominent criminal defense lawyer and personal friend, Alan Dershowitz. 15. Another grand jury was convened in April 2006, but canceled the day before it was to begin receiving evidence. (1) Police Chief Reiter’s Letter to the State Attorney. 16. On May 1, 2006, Town of Palm Beach Police Chief Michael Reiter wrote a “personal and confidential” letter to then Palm Beach County State Attorney, Barry Krischer, stating: I must renew my prior observation to you that I continue to find your office’s treatment of [the Epstein] cases highly unusual. It is regrettable that I am forced to communicate in this manner, but my most recent telephone calls to you and those of the lead detective to your assigned attorneys have been unanswered and messages remain unreturned. After giving this much thought and consideration, I must urge you to examine the unusual course thatyour office’s handling ofthis matter has taken and consider ifgood and sufficient reason exists to requireyour disqualificationfrom theprosecution ofthese cases. (Emphasis supplied) 17. Chief Reiter’s letter to State Attorney Krischer enclosed the Town of Palm Beach Police Department’s probable cause affidavits charging Epstein and two of his assistants with multiple counts of unlawful sex acts with a minor and one count of sexual abuse, and requested 5 CA/Aronberg-000121 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY r, 13. Both the victim/witness interviews, as well as evidence retrieved following a search I of Epstein's home, showed that some of the girls involved were under the~age of 18. The police search of Epstein's residence also found two hidden cameras and, throughout the house, large numbers of nude photos of girls, including victims whom the police had not interviewed in the course of their investigation. 14. In March 2006, a State grand jury was scheduled at which all of the victims were expected to testify. The proceeding was postponed, however, due to meetings between the State Attorney's office and Epstein's prominent criminal defense lawyer and personal friend, Alan Dershowitz. 15. Another grand jury was convened in April 2006, but canceled the day before it was to begin receiving evidence. (1) Police Chief Reiter's Letter to the State Attorney. • 16. On May 1, 2006, Town of Palm Beach Police Chief Michael Reiter wrote a "personal and confidential" letter to then Palm Beach County State Attorney, Barry Krischer, stating: I must renew my prior observation to you that I continue to find your office's treatment of [the Epstein] cases highly unusual. It is regrettable that I am forced to communicate in this manner, but my most recent telephone calls to you and those of the lead detective to your assigned attorneys have been unanswered and messages remain unreturned. After giving this much thought and consideration, I must urge you to e.."\:amine the unusual course that your office's handling of this matter has taken and consider if good and sufficient reason exists to require your disqualification from the prosecution of these cases. (Emphasis supplied) 17. ChiefReiter's letter to State Attorney Krischer enclosed the Town of Palm Beach Police Department's probable cause affidavits charging Epstein and two of his assistants with multiple counts of unlawful sex acts with a minor and one count of sexual abuse, and requested 5 CA/AronbeLQ-000121 FILEU: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM that either an arrest warrant be issued for Epstein or the State Attorney directly initiate the charges against him, which would be public. (2) The July 2006 State Grand Jury Presentation. 18. Instead, State Attorney Krischer elected to refer the case to a grand jury, which is mandatory for capital cases but rarely used for all other crimes. According to an official spokesperson, this was the first time that a sex crimes case was presented to a grand jury in Palm Beach County. 19. In July 2006, after State Attorney Krischer presented testimony and evidence from one victim, the grand jury returned an indictment on a sole count of solicitation of prostitution. There is no mention in the indictment of the victim being a minor. 20. On information and belief, a second of Epstein’s victims was supposed to testify before the grand jury, but was unable to attend because of a school exam. 21. No reasonable explanation has been provided as to why the numerous other known victims were not presented as witnesses and crime victims to the grand jury convened in July 2006. Nor has any reasonable explanation been provided as to why State Attorney Krischer, who was initially eager to investigate and prosecute Epstein for his crimes, over time lost the desire to do so. 22. On information and belief, during the grand jury appearance of the single victim who testified, the State Attorney presented evidence that vilified the victim and attacked her credibility, including soliciting testimony regarding underage drinking and questionable personal behavior that was unrelated to the charges against Epstein. Further upon information and belief, this information was initially brought to the attention of the State Attorney’s office by Epstein’s defense counsel. 6 : l i CA/Aronbera-000122 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY that either an arrest warrant be issued for Epstein or the State Attorney direc~ly initiate the charges I ' against him, which would be public. (2) The July 2006 State Grand Jury Presentation. 18. Instead, State Attorney Krischer elected to refer the case to a grand jury, which is mandatory for capital cases but rarely used for all other crimes. According to an official spokesperson, this was the first time that a sex crimes case was presented to a grand jury in Palm Beach County. 19. In July 2006, after State Attorney Krischer presented testimony and evidence from one victim, the grand jury returned an indictment on a sole count of solicitation of prostitution. There is no mention in the indictment of the victim being a minor. 20. On information and belief, a second of Epstein's victims was supposed to testify before the grand jury, but was unable to attend because of a school exam. 21. No reasonable explanation has been provided as to why the numerous other known victims were not presented as witnesses and crime victims to the grand jury convened in July 2006. Nor has any reasonable explanation been provided as to why State Attorney Krischer, who was initially eager to investigate and prosecute Epstein for his crimes, over time lost the desire to do SO. 22. On information and belief, during the grand jury appearance of the single victim who testified, the State Attorney presented evidence that vilified the victim and attacked her credibility, including soliciting testimony regarding underage drinking and questionable personal behavior that was unrelated to the charges against Epstein. Further upon information and belief, this information was initially brought to the attention of the State Attorne~'s office by Epstein's defense counsel. 6 CA/Aronbe&000122 FILb1J: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM (3) The FBI’s Investigation and Epstein’s Non-Prosecution Agreement With Federal Authorities. 23. On information and belief, following the deficient July 2006 indictment, and with Chief Reiter’s encouragement, the FBI began its own investigation of Epstein. 24. Records unsealed in 2015 revealed that the FBI compiled reports on “34 confirmed minors” that were victims ofEpstein’s sexual predations. Based on evidence gathered by the FBI, a 53-page indictment was prepared by the U.S. Attorney’s Office in June 2007. However, at the request ofEpstein’s lawyers, the indictment was never presented to a federal grand jury. 25. Instead, then U.S. Attorney for the Southern District ofFlorida, Alexander Acosta, negotiated a plea deal with Epstein’s team of lawyers to grant immunity to Epstein (along with four named co-conspirators and any unnamed potential co-conspirators) from all federal criminal charges. 26. Throughout the remainder of 2007 and through the first half of 2008, Epstein’s lawyers and the U.S. Attorney continued negotiating the plea arrangement. Upon information and belief, Epstein’s lawyers insisted that (1) the victims not be notified, (2) the deal be kept confidential and under seal, and (3) all grand jury subpoenas (including one that had already been issued for Epstein’s computers) be withdrawn. 27. On June 30, 2008, Epstein pled guilty to State charges: one count of solicitation of prostitution and one count of solicitation of prostitution with a minor under the age of 18. He was sentenced to 18 months in jail, followed by a year of community control or house arrest, and was adjudicated as a convicted sex offender required to register twice a year in Florida. 28. The plea deal, called a non-prosecution agreement (“NPA”), allowed Epstein to receive immunity from federal sex-trafficking charges that could have sent him to prison for life. 7 ' CA/Aronbera-000123 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY (3) The FBl's Investigation and Epstein's Non-Prosecution Agreement With Federal Authorities. 23. On information and belief, following the deficient July 2006 indictment, and with ChiefReiter's encouragement, the FBI began its own investigation of Epstein. 24. Records unsealed in 2015 revealed that the FBI compiled reports on "34 confirmed minors" that were victims of Epstein's sexual predations. Based on evidence gathered by the FBI, a 53-page indictment was prepared by the U.S. Attorney's Office in June 2007. However, at the request of Epstein's lawyers, the indictment was never presented to a federal grand jury. 25. Instead, then U.S. Attorney for the Southern District of Florida, Alexander Acosta, negotiated a plea deal with Epstein's team of lawyers to grant immunity to Epstein (along with four named co-conspirators and any unnamed potential co-conspirators) from all federal criminal charges. 26. Throughout the remainder of 2007 and through the first half of 2008, Epstein's lawyers and the U.S. Attorney continued negotiating the plea arrangement. Upon information and belief, Epstein's lawyers insisted that (1) the victims not be notified, (2) the deal be kept confidential and under seal, and (3) all grand jury subpoenas (including one that had already been issued for Epstein's computers) be withdrawn. 27. On June 30, 2008, Epstein pied guilty to State charges: one count of solicitation of prostitution and one count of solicitation of prostitution with a minor under the age of 18. He was sentenced to 18 months in jail, followed by a year of community contr<?l or house arrest, and was adjudicated as a convicted sex offender required to register twice a year in Florida. 28. The plea deal, called a non-prosecution agreement ("NPA) allowed Epstein to receive immunity from federal sex-trafficking charges that could have sent him to prison for life. 7 CA/Aronbern::-000123 FILblJ: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM On information and belief, based on public records, former State Attorney Krischer communicated with then U.S. Attorney Acosta concerning the NPA’s negotiation with Epstein’s lawyers. 29. Indeed, Epstein was not incarcerated in a Florida prison for the State crimes for which he was convicted. Instead, he was placed in a private wing of the Palm Beach County Stockade, where, after 3 1/2 months, he was allowed to leave the jail on “work release” for up to 12 hours a day, 6 days a week. His private driver provided his transportation to and from “work.” 30. Epstein was released five months early. 31. Upon information and belief, Epstein violated the terms of his probation, but was not prosecuted. (4) The Crime Victims’ Rights Act Litigation. 32. Epstein’s victims only learned after the fact about his plea in State court and filed an emergency petition to force federal prosecutors to comply with the Crime Victims’ Rights Act (18 U.S.C. § 3771, “CVRA”), which mandates certain rights for crime victims, including the right to be informed about plea agreements and the right to appear at sentencing. U.S. District Judge Kenneth A. Marra recently ruled that federal prosecutors violated the CVRA by failing to notify Epstein’s victims before allowing him to plead guilty to only the two State offenses. 33. The prosecution’s failure to keep the victims apprised, among other things, also contravenes the Florida Constitution, Article 1, § 16(b) and Fla. Stat. § 960.001. 34. Following publicity exposing the extraordinary leniency of the plea deal, dozens of civil suits were brought against Epstein, most of which Epstein’s lawyers settled out-of-court. 35. In 2010, Epstein was registered as a “level three” (i.e., high risk of repeat offense) sex offender in New York, a lifelong designation. In 2011, the New York County District Attorney’s office unsuccessfully sought to lower his registration to low-risk “level one.” 8 CA/Aronberq-000124 ni.H): PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY I On infonnation and belief, based on public records, fonner State Attorney Krischer communicated I with then U.S. Attorney Acosta concerning the NPA's negotiation with Epstein's lawyers. 29. Indeed, Epstein was not incarcerated in a Florida prison for the State crimes for which he was convicted. Instead, he was placed in a private wing of the Palm Beach County Stockade, where, after 3 ];2 months, he was allowed to leave the jail on "work release" for up to 12 hours a day, 6 days a week. His private driver provided his transportation to and from "work." 30. Epstein was released five months early. 31. Upon infonnation and belief, Epstein violated the tenns of his probation, but was not prosecuted. (4) The Crime Victims' Rights Act Litigation. 32. Epstein's victims only learned after the fact about his plea in State court and filed an emergency petition to force federal prosecutors to comply with the Crime Victims' Rights Act (18 U.S.C. § 3771, ''CVRA"), which mandates certain rights for crime victims, including the right to be infonned about plea agreements and the right to appear at sentencing. U.S. District Judge Kenneth A. Marra recently ruled that federal prosecutors violated the CVRA by failing to notify Epstein's victims before allowing him to plead guilty to only the two State offenses. 33. The prosecution's failure to keep the victims apprised, among other things, also contravenes the Florida Constitution, Article 1, § 16(b) and Fla. Stat. § 960.001. 34. Following publicity exposing the extraordinary leniency of the plea deal, dozens of civil suits were brought against Epstein, most of which Epstein's la\vyers settled out-of-court. 35. In 2010, Epstein was registered as a "level three" (i.e., high risk of repeat offense) sex offender in New York, a lifelong designation. In 2011, the New York County District Attorney's office unsuccessfully sought to lower his registration to low-risk "level one." 8 CA/Aronberg-000124 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM I ) I - I • ( I I I 36. Upon information and belief, during the course ofthe Town ofPalm Beach and FBI investigations, Epstein retained private investigators to follow, harass, and photograph his victims and their families, as well as ChiefReiter and the Town ofPalm Beach detective who investigated the case against Epstein. 37. Upon information and belief, Epstein’s victims were threatened against cooperating with law enforcement and told that they would be compensated only ifthey did not cooperate with law enforcement. B. Second Epstein Sex Crimes Investigation, Indictment, Suicide: 2019. 38. On July 6, 2019, Epstein was arrested on federal sex trafficking charges. 39. Upon information and belief, the United States government’s investigation of new allegations and charges stemmed, in part, from continued press investigations into and reporting on the mishandling of the 2006 charges and the civil suits that followed. 40. In a July 8, 2019, letter to the federal district court by the U.S. Attorney for the Southern District ofNew York, Epstein was described as “a serial sexual predator who preyed on dozens of minor girls over a period of years.” The letter emphasized that “the Government has real concerns - grounded in past experience with this defendant - that if allowed to remain out on bail, the defendant could attempt to pressure and intimidate witnesses and potential witnesses in this case, including victims and their families, and otherwise attempt to obstruct justice.” It also described the results of the FBI’s search of Epstein’s Manhattan townhouse: evidence of sex trafficking in the form of “hundreds - and perhaps thousands - of sexually suggestive photographs of fully- or partially-nude females,” including underage females. In a locked safe, compact discs were found with handwritten labels including the descriptions: “Young [Name] + [Name],” “Mise nudes 1,” and “Girl pics nude.” 9 CA/Aronberg-000125 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY I I I I 36. Upon information and belief, during the course of the Town cif Palm Beach and FBI I investigations, Epstein retained private investigators to follow, harass, and photograph his victims and their families, as well as Chief Reiter and the Town of Palm Beach detective who investigated the case against Epstein. 37. Upon information and belief, Epstein's victims were threatened against cooperating with law enforcement and told that they would be compensated only if they did not cooperate with law enforcement. B. Second Epstein Sex Crimes Investigation, Indictment, Suicide: 2019. 38. On July 6, 2019, Epstein was arrested on federal sex trafficking charges. 39. Upon information and belief, the United States government's investigation of new allegations and charges stemmed, in part, from continued press investigations into and reporting on the mishandling of the 2006 charges and the civil suits that followed. 40. In a July 8, 2019, letter to the federal district court by the U.S. Attorney for the Southern District of New York, Epstein was described as "a serial sexual predator who preyed on dozens of minor girls over a period of years." The letter emphasized that "the Government has real concerns - grounded in past experience with this defendant - that if allowed to remain out on bail, the defendant could attempt to pressure and intimidate witnesses and potential witnesses in this case, including victims and their families, and otherwise attempt to obstruct justice." It also described the results of the FBI's search of Epstein's Manhattan townhouse: evidence of sex trafficking in the form of "hundreds - and perhaps thousands - of sexually suggestive photographs of fully- or partially-nude females," including underage females. In a locked safe, compact discs were found with handwritten labels including the descriptions: "Young [Name]+ [Name]," "Misc nudes l," and "Girl pies nude." 9 CA/AronbeLQ::-000125 FILb1J: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM J I I - 41. On July 8,2019, prosecutors with the Public Corruption Unit ofthe U.S. Attorney’s office for the Southern District ofNew York charged Epstein with sex trafficking and conspiracy to traffic minors for sex. The grand jury indictment alleges that “dozens” of underage girls were brought into Epstein’s mansions for sexual encounters. A few days later, owing to public outcry over the NPA with Epstein entered into by the U.S. Attorney for the Southern District of Florida, Alexander Acosta, who by then was serving as U.S. Secretary of Labor in the Trump administration, resigned from office. 42. Epstein was denied bail and was placed into pretrial detention at the federal Metropolitan Correction Center in lower Manhattan. 43. On or about August 6, 2019, Florida Gov. Ron DeSantis ordered a state criminal probe into the actions of the Palm Beach Sheriff and former State Attorney Krischer for their handling of the Epstein underage sex trafficking case. 44. On August 10, 2019, Epstein was found dead in his cell at the Metropolitan Correctional Center. His cause of death was determined to be suicide. C. The August 27, 2019, SDNY Hearing: Epstein’s Victims Speak. 45. On account of his death, prosecutors sought to dismiss the indictment against Epstein, while maintaining that they would continue to investigate his co-conspirators. 46. United States Senior District Judge Richard M. Berman ordered a hearing on August 27, 2019, on the prosecutors’ decision to dismiss the indictment and allowed victims to speak at the hearing. 47. In the course of the hearing, more than two dozen victims delivered their personal stories of pain, frustration, and sexual abuse at the hands of Epstein. Several victims spoke of violent rape by Epstein. Many more victims were present in the courtroom but did not testify. 10 ! i CA/Aronbera-000126 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY v 41. On July 8, 2019, prosecutors with the Public Corruption Unit of the U.S. Attorney's office for the Southern District of New York charged Epstein with sex trafficking and conspiracy to traffic minors for sex. The grand jury indictment alleges that "dozens" of underage girls were brought into Epstein's mansions for sexual encounters. A few days later, owing to public outcry over the NP A with Epstein entered into by the U.S. Attorney for the Southern District of Florida, Alexander Acosta, who by then was serving as U.S. Secretary of Labor in the Trump administration, resigned from office. 42. Epstein was denied bail and was placed into pretrial detention at the federal Metropolitan Correction Center in lower Manhattan. 43. On or about August 6, 2019, Florida Gov. Ron DeSantis ordered a state criminal probe into the actions of the Palm Beach Sheriff and former State Attorney Krischer for their handling of the Epstein underage sex trafficking case. 44. On August 10, 2019, Epstein was found dead in his cell at the Metropolitan Correctional Center. His cause of death was determined to be suicide. C. The August 27, 2019, SDNY Hearing: Epstein's Victims Speak. 45. On account of his death, prosecutors sought to dismiss the indictment against Epstein, while maintaining that they would continue to investigate his co-conspirators. 46. United States Senior District Judge Richard M. Berman ordered a hearing on August 27, 2019, on the prosecutors' decision to dismiss the indictment and allowed victims to speak at the hearing. 47. In the course of the hearing, more than two dozen victims delivered their personal stories of pain, frustration, and sexual abuse at the hands of Epstein. Sev;eral victims spoke of violent rape by Epstein. Many more victims were present in the courtroom put did not testify. CA/Aronbem-000 126 FILEU: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 48. While some questioned the reasoning behind the court’s decision to give the victims voice after Epstein’s death, District Judge Berman noted that “a public hearing is [the] preferred vehicle of resolution,” emphasizing that “public hearings are exactly what judges do. Hearings promote transparency and they provide the court with insights and information which the court may not otherwise be aware of.” Indeed, even Epstein’s defense lawyer noted at the hearing that the court “is the institution that most people have confidence in, in these very troubled times.” 49. At the August 27th hearing, the girls, now women, spoke about their “exploitation and coercion,” and to the fact that many ofthem “were in very vulnerable situations and in extreme poverty, circumstances where [they] didn’t have anyone on [their] side, to speak on [their] behalf...One victim lamented that “as a victim, [she] never got to see what the agreement was or why the special treatment got approved” in the Florida case years earlier. Another noted how “completely different” the investigators leading to the 2019 federal indictment were from the prosecutors in the Florida case, both in their treatment of her and their investigation of her victimization by Epstein. 50. A former federal judge in attendance at the August 27th hearing emphasized that “transparency is one ofthe overriding objectives in our criminal justice system.” 51. Nearly all of the victims expressed the conviction that the secrecy that shielded Epstein has caused them “irreparable harm” and that an opportunity to address his criminal wrongdoings, and those of the individuals who enabled his sexual racketeering, would allow for at least some measure ofjustice to be served after his death. Indeed, one victim stated: “Any efforts made to protect Epstein’s name and legacy send a message to the victims that he wins and that he is untouchable.” Another victim expressed fear that this is a world “where there are predators in power, a world where people can avoid justice if their pockets run deep enough.” In short, the 11 I CA/Aronberg-000127 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY i 48. While some questioned the reasoning behind the court's decision to give the victims ! voice after Epstein's death, District Judge Berman noted that "a public hearing is [the] preferred vehicle of resolution," emphasizing that "public hearings are exactly what judges do. Hearings promote transparency and they provide the court with insights and information which the court may not otherwise be aware of." Indeed, even Epstein's defense lawyer noted at the hearing that the court "is the institution that most people have confidence in, in these very troubled times." 49. At the August 27th hearing, the girls, now women, spoke about their "exploitation and coercion," and to the fact that many of them "were in very vulnerable situations and in extreme poverty, circumstances where [they] didn't have anyone on [their] side, to speak on [their] behalf.. .. " One victim lamented that "as a victim, [she] never got to see what the agreement was or why the special treatment got approved" in the Florida case years earlier. Another noted how "completely different" the investigators leading to the 2019 federal indictment were from the prosecutors in the Florida case, both in their treatment of her and their investigation of her victimization by Epstein. 50. A former federal judge in attendance at the August 27th hearing emphasized that "transparency is one of the overriding objectives in our criminal justice system." 51. Nearly all of the victims expressed the conviction that the secrecy that shielded Epstein has caused them "irreparable harm" and that an opportunity to address his criminal wrongdoings, and those of the individuals who enabled his sexual racketeering, would allow for at least some measure of justice to be served after his death. Indeed, one victim stated: "Any efforts made to protect Epstein's name and legacy send a message to the victims that he wins and that he is untouchable." Another victim expressed fear that this is a world "where there are predators in power, a world where people can avoid justice if their pockets run deep enough." In short, the 11 CA/Aronbe_rn_-000127 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM “unusual” treatment Epstein received in Florida in 2006 based on his wealth, social status, and connections severely eroded the public’s faith in the integrity and impartiality of the criminal justice system. D. The Palm Beach Post's Standing and the Public Interest. (1) The Palm Beach Post Has Reported Extensively On Epstein’s Crimes For Nearly 15 Years. 52. Plaintiff, The Palm Beach Post, is a community newspaper serving readers in Palm Beach County and the Treasure Coast vicinity. 53. The Palm Beach Post has been a Pulitzer Prize winner and nominated as a finalist three other times. 54. Beginning in 2004, The Palm Beach Post has extensively investigated and reported on the allegations against, the law enforcement investigation of, and the crimes committed by, Epstein and his co-conspirators. The Newspaper’s reportage has included publication of the following articles: • “The Man Who Had Everything: Jeffrey Epstein Craved Big Homes, Elite Friends and, Investigators Say, Underage Girls.,” published on August 14, 2006, reporting that: Haley Robson, a local community college student, admitted in a sworn statement to police that “she had taken at least six girls to visit Epstein, all between the ages of 14 and 16;” Palm Beach Police “interviewed five alleged victims and 17 witnesses;” “Dershowitz, the Harvard law professor, traveled to West Palm Beach with information about the girls,” including social media discussions about “their use of alcohol and marijuana;” after meeting with Epstein’s legal team, “prosecutors postponed their decision to take the case to a grand jury;” Palm Beach Police subsequently “received complaints that two of the victims or their families had been harassed or threatened;” “relations between police and prosecutors were fraying” as the investigation continued; and “one girl who was subpoenaed - the one who said she had sexual intercourse with Epstein - never showed up” to testify before the grand jury'. • “Trump Snags Gosman Estate for $41 Million” published on November 16, 2004, reporting on the bidding war between Donald Trump and Jeffrey Epstein for the purchase of a seven-bedroom estate on 6 oceanfront acres along the storied ‘Raider’s Row’ ” in Palm Beach. 12 CA/Aronberg-000128 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY I I "unusual" treatment Epstein received in Florida in 2006 based on his wealth, social status, and I connections severely eroded the public's faith in the integrity and impartiality of the criminal justice system. D. The Palm Beach Post's Standing and the Public Interest. (1) The Palm Beach Post Has Reported Extensively On Epstein's Crimes For Nearly 15 Years. 52. Plaintiff, The Palm Beach Post, is a community newspaper serving readers in Palm Beach County and the Treasure Coast vicinity. 53. The Palm Beach Post has been a Pulitzer Prize winner and nominated as a finalist three other times. 54. Beginning in 2004, The Palm Beach Post has extensively investigated and reported on the allegations against, the law enforcement investigation of, and the crimes committed by, Epstein and his co-conspirators. The Newspaper's reportage has included publication of the following articles: • "The Man Who Had Everything: Jeffrey Epstein Craved Big Homes, Elite Friends and, Investigators Say, Underage Girls.," published on August 14, 2006, reporting that: Haley Robson, a local community college student, admitted in a sworn statement to police that "she had taken at least six girls to visit Epstein, all between the ages of 14 and 16;" Palm Beach Police "interviewed five alleged victims and 17 witnesses;" "Dershowitz, the Harvard law professor, traveled to West Palm Beach with information about the girls," including social media discussions about "their use of alcohol and marijuana;" after meeting with Epstein's legal team, "prosecutors postponed their decision to take the case to a grand jury;" Palm Beach Police subsequently "received complaints that two of the victims or their families had been harassed or threatened;" "relations between police and prosecutors were fraying" as the investigation continued; and "one girl who was subpoenaed - the one who said she had sexual intercourse with Epstein - never showed up" to testify before the grand jury. • "Trump Snags Gosman Estate for $41 Million" published on November 16, 2004, reporting on the bidding war between Donald Trump and Jeffrey Epstein for the purchase of a "43,000-square-foot, seven-bedroom estate on 6 oceanfront acres along the storied 'Raider's Row' "in Palm Beach. 12 CA/Aronbem.-000128 FILEU: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM • “Indictment: Billionaire Solicited 3 Times” published on July 25, 2006, reporting that “Billionaire money manager and Palm Beach part-time resident Jeffrey Epstein solicited or procured prostitutes three or more times between Aug. 1 and Oct. 31 oflast year, according to an indictment charging him with felony solicitation of prostitution.” The article further reported that “Epstein’s case is unusual in that suspected prostitution johns are usually charged with a misdemeanor, and even a felony charge is typically made in a criminal information - an alternative to an indictment charging a person with the commission of a crime.” • “After Long Probe, Billionaire Faces Solicitation Charge” published on July 26, 2006, reporting that “Palm Beach police thought there was probable cause to charge Epstein with unlawful sex acts with a minor and lewd and lascivious molestation.” The article further reported that “Police Chief Michael Reiter was so angry with State Attorney Barry Krischer’s handling of the case that he wrote a memo suggesting the county’s top prosecutor disqualify himself,” and identified a 20-year-old on-the-record female source who said “she gave Epstein a massage in the nude, then brought him six girls, ages 14 to 16, for massage and sex-tinged sessions at his home.” • “Police Say Lawyer Tried to Discredit Teenage Girls” published on July 29, 2006, reporting that “[f]amed Harvard law professor Alan Dershowitz met with the Palm Beach County State Attorney’s Office and provided damaging information about teenage girls who say they gave his client, Palm Beach billionaire Jeffrey Epstein, sexually charged massages” and that “[t]he state attorney’s office said it presented the Epstein case to a county grand jury this month rather than directly charging Epstein because of concerns about the girls’ credibility.” • “Expert: Ignorance of Age Isn’t Defense In Sex Cases” published on August 5, 2006, reporting that “[r]ather than file charges, the state attorney’s office presented the case to a county grand jury” which “indicted Epstein last week on a single, less serious charge of felony solicitation of prostitution,” and that “[t]he case raised eyebrows because the state attorney’s office rarely, if ever, kicks such charges to a grand jury.” • “Epstein Camp Calls Female Accusers Liars” published on August 8, 2006, reporting that “[a] state attorney’s spokesman would say only that the office refers cases to the grand jury when there are issues with the viability of the evidence or witnesses’ credibility.” • “Palm Beach Chief Focus of Fire In Epstein Case” published on August 14, 2006, reporting that Chief Reiter “pressed for Epstein to be charged with the more serious crimes of sexual activity with minors” and “slammed State Attorney Barry Krischer in blunt language seldom used by one law enforcement official with another because of what he perceived as that office’s mishandling ofthe case.” • “Delays In Epstein Case Unusual, Lawyers Say” published on March 13, 2007, reporting that “[n]early eight months after Palm Beach tycoon Jeffrey Epstein was charged with felony solicitation of prostitution, there has been no discernible progress in his case.” CA/Aronbera-000129 FILHO: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY i i I • "Indictment: Billionaire Solicited 3 Times" published on July 2~, 2006, reporting that "Billionaire money manager and Palm Beach part-time resident Jeffrey Epstein I solicited or procured prostitutes three or more times between Aug. 1 and Oct. 31 oflast year, according to an indictment charging him with felony solicitation of prostitution." The article further reported that "Epstein's case is unusual in that suspected prostitution johns are usually charged with a misdemeanor, and even a felony charge is typically made in a criminal information - an alternative to an indictment charging a person with the commission of a crime." • "After Long Probe, Billionaire Faces Solicitation Charge" published on July 26, 2006, reporting that "Palm Beach police thought there was probable cause to charge Epstein with unlawful sex acts with a minor and lewd and lascivious molestation." The article further reported that "Police Chief Michael Reiter was so angry with State Attorney Barry Krischer's handling of the case that he wrote a memo suggesting the county's top prosecutor disqualify himself," and identified a 20-year-old on-the-record female source who said "she gave Epstein a massage in the nude, then brought him six girls, ages 14 to 16, for massage and sex-tinged sessions at his home." • "Police Say Lawyer Tried to Discredit Teenage Girls" published on July 29, 2006, reporting that "[flamed Harvard law professor Alan Dershowitz met with the Palm Beach County State Attorney's Office and provided damaging information about teenage girls who say they gave his client, Palm Beach billionaire Jeffrey Epstein, sexually charged massages" and that "[t]he state attorney's office said it presented the Epstein case to a county grand jury this month rather than directly charging Epstein because of concerns· about the girls' credibility." • "Expert: Ignorance of Age Isn't Defense In Sex Cases" published on August 5, 2006, reporting that "[r]ather than file charges, the state attorney's office presented the case to a county grand jury" which "indicted Epstein last week on a single, less serious charge of felony solicitation of prostitution," and that "[t]he case raised eyebrows because the state attorney's office rarely, if ever, kicks such charges to a grand jury." • "Epstein Camp Calls Female Accusers Liars" published on August 8, 2006, reporting that "[a] state attorney's spokesman would say only that the office refers cases to the grand jury when there are issues with the viability of the evidence or witnesses' credibility." • "Palm Beach Chief Focus of Fire In Epstein Case" published on August 14, 2006, reporting that Chief Reiter "pressed for Epstein to be charged with the more serious crimes of sexual activity with minors" and "slammed State Attorney Barry Krischer in blunt language seldom used by one law enforcement official with another because of what he perceived as that office's mishandling of the case." • "Delays In Epstein Case Unusual, Lawyers Say" published on March 13, 2007, reporting that "[n]early eight months after Palm Beach tycoon Jeffrey Epstein was charged with felony solicitation of prostitution, there has been no discernible progress in his case." 13 CA/Aronbem-000129 FILEU: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM • “Woman Sues Billionaire Investor, Says They Had Sex When She Was 16” published on October 18, 2007, reporting on a lawsuit brought in New York State court against Epstein “by a young woman who says he had sex with her when she was 16 and had sought his help becoming a model.” • “Palm Beacher Pleads In Sex Case” published on July 1, 2008, reporting that “Epstein, 55, pleaded guilty ... to felony solicitation ofprostitution and procuring a person under the age of 18 for prostitution,” resulting in “a lifelong obligation to register as a sex offender,” and that “[a]s part of the plea deal, federal investigators agreed to drop their investigation of Epstein, which they had taken to a grand jury.” • “Jeffrey Epstein: Scientist, Stuntman, ‘Sex Slave’ Visit Jailed Tycoon” published on August 13, 2008, reporting that “[d]uring his first month of confinement” Epstein was visited by Sarah Kellen, who allegedly escorted victims “upon their arrival at his Palm Beach waterfront home to an upstairs room, where she prepared the massage table and provided the oils for their encounters” with Epstein, and by Nadia Marcinkova, “a young woman whom Epstein purportedly described as his Yugoslavian sex slave.” • “Billionaire Sex Offender Leaves Jail Six Days a Week For Work” published on July 1, 2008, reporting that Epstein “is allowed to leave the Palm Beach County Stockade six days a week on a work-release program.” • “Women Want Epstein Sex Plea Deal Unsealed” published on June 10, 2009, reporting that attorneys for women suing Epstein in various courts “want his [non-prosecution] agreement [NPA] with federal prosecutors unsealed” and were moving to unseal the agreement in Circuit Court ofthe Fifteenth Judicial Circuit, and that “Epstein now faces at least a dozen civil lawsuits in federal and state courts filed by young women who said they had sex with him and now are seeking damages.” On that date, The Palm Beach Post moved to intervene in the matter for the purpose of obtaining public access to the NPA, which was ordered disclosed by this Court on June 25, 2009. • “Epstein’s Secret Pact With Feds Reveals ‘Highly Unusual’ Terms” published on September 19, 2009, reporting that, owing to Epstein’s non-prosecution agreement, “federal prosecutors backed down and agreed to recall grand jury subpoenas ifEpstein pleaded guilty to felonies in state court” and “also agreed not to charge any of Epstein’s possible co-conspirators: Sarah Kellen, Adriana Ross, Lesley Groff and Nadia Marcinkova.” The article further reported that, according to an attorney representing three of Epstein’s victims, “none of the 30 to 40 wom[e]n identified as victims in the federal investigation” were informed ahead of time about the NPA. • “Judge Rules Epstein Attorneys Can Subpoena Abortion Records” published on January 27, 2010, reporting that “a judge . . . gave lawyers representing multi¬ millionaire sex offender Jeffrey Epstein the right to subpoena abortion records from women who are seeking millions in damages from the part-time Palm Beach resident.” 14 CA/Aronberg-000130 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY I • "Woman Sues Billionaire Investor, Says They Had Sex When She Was 16" published I on October 18, 2007, reporting on a lawsuit brought in New York State court against Epstein "by a young woman who says he had sex with her when she was 16 and had sought his help becoming a model." • "Palm Beacher Pleads In Sex Case" published on July 1, 2008, reporting that "Epstein, 55, pleaded guilty ... to felony solicitation of prostitution and procuring a person under the age of 18 for prostitution," resulting in "a lifelong obligation to register as a sex offender," and that "[a]s part of the plea deal, federal investigators agreed to drop their investigation of Epstein, which they had taken to a grand jury." • "Jeffrey Epstein: Scientist, Stuntman, 'Sex Slave' Visit Jailed Tycoon" published on August 13, 2008, reporting that "[d]uring his first month of confinement" Epstein was visited by Sarah Kellen, who allegedly escorted victims "upon their arrival at his Palm Beach waterfront home to an upstairs room, where she prepared the massage table and provided the oils for their encounters" with Epstein, and by Nadia Marcinkova, "a young woman whom Epstein purportedly described as his Yugoslavian sex slave." • "Billionaire Sex Offender Leaves Jail Six Days a Week For Work" published on July 1, 2008, reporting that Epstein "is allowed to leave the Palm Beach County Stockade six days a week on a work-release program." • "Women Want Epstein Sex Plea Deal Unsealed" published on June 10, 2009, reporting that attorneys for women suing Epstein in various courts "want his [non-prosecution] agreement [NPA] with federal prosecutors unsealed" and were moving to unseal the agreement in Circuit Court of the Fifteenth Judicial Circuit, and that "Epstein now faces at least a dozen civil lawsuits in federal and state courts filed by young women who said they had sex with him and now are seeking damages." On that date, The Palm Beach Post moved to intervene in the matter for the purpose of obtaining public access to the 1\TPA, which was ordered disclosed by this Court on June 25, 2009. • "Epstein's Secret Pact With Feds Reveals 'Highly Unusual' Terms" published on September 19, 2009, reporting that, owing to Epstein's non-prosecution agreement, "federal prosecutors backed down and agreed to recall grand jury subpoenas if Epstein pleaded guilty to prostitution-related felonies in state court" and "also agreed not to charge any of Epstein's possible co-conspirators: Sarah Kellen, Adriana Ross, Lesley Groff and Nadia Marcinkova." The article further reported that, according to an attorney representing three of Epstein's victims, "none of the 30 to 40 wom[e]n identified as victims in the federal investigation" were informed ahead of time about the NPA. • "Judge Rules Epstein Attorneys Can Subpoena Abortion Records" published on January 27, 2010, reporting that "a judge ... gave lawyers representing multi- millionaire sex offender Jeffrey Epstein the right to subpoena abortion records from women who are seeking millions in damages from the part-time Palm Beach resident." 14 CA/Aronbe_rg_-000130 FILEU: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM • “Epstein Journal’s Findings Could Resurrect Abuse Case” published on March 20, 2010, reporting that “[a] purloined journal that is said to contain the names of ‘hundreds’ ofvictims of convicted sex offender Jeffrey Epstein could be used to reopen the investigation into the multi-millionaire’s appetite for teenage girls.” • “Epstein Paid Three Women $5.5 Million to End Underage Sex Lawsuits” published on October 4, 2017, reporting that, according to court documents, Epstein “shelled out $5.5 million to settle lawsuits with three of more than two dozen teens who sued him.” • “Judge Rules Feds’ Agreement With Jeffrey Epstein Pact Violated Teen Victims’ Rights” published on February 22, 2019, reporting on a ruling by U.S. District Judge Kenneth Marra that “Federal prosecutors violated the rights of Jeffrey Epstein’s teenage victims [under the Crime Victims’ Rights Act] by failing to reveal they had dropped plans to prosecute the billionaire on dozens of federal charges in connection with the girls’ claims that he paid them for sex at his Palm Beach mansion.” • “Epstein Indicted On Sex Charges/Part-Time Palm Beacher Pleads Not Guilty to Sex Trafficking, Conspiracy Charges In Federal Court In Manhattan” published on July 9, 2019, reporting on Epstein’s appearance in U.S. District Court for the Southern District ofNew York in which he “pleaded not guilty to charges accusing him of creating a vast network of girls as young as 14 that he exploited for his sexual pleasure at his homes in Palm Beach and Manhattan.” A true and correct copy of the above news articles, in either the computerized format in which they are maintained in The Palm Beach PosCs electronic archives or the news print edition in which originally published, is annexed hereto as Exhibit 1. 55. Since the filing ofthe initial Complaint in this matter, The Palm Beach Post- along with media worldwide - has continued to report on Epstein’s crimes and the ongoing official proceedings resulting from those crimes. (2) The Palm Beach Post's Standing and the Public Interest. 56. The press has a constitutional right of access to criminal proceedings, see, e.g., Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 573 (1980), including pre-trial criminal proceedings. Newman v. Graddick, 696 F.2d 796 (11th Cir. 1983). Indeed, “the integrity of the judicial process, which public scrutiny is supposed to safeguard, is just as much at issue in proceedings of this kind [pre- and post-trial] as at trial.” Id. at 801; see also Miami HeraldPubl. 15 CA/Aronbera-000131 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY • "Epstein Journal's Findings Could Resurrect Abuse Case" puplished on March 20, 2010, reporting that "[a] purloined journal that is said to contain the names of 'hundreds' of victims of convicted sex offender Jeffrey Epstein c~uld be used to reopen the investigation into the multi-millionaire's appetite for teenage girls." • "Epstein Paid Three Women $5.5 Million to End Underage Sex Lawsuits" published on October 4, 2017, reporting that, according to court documents, Epstein "shelled out $5.5 million to settle lawsuits with three of more than two dozen teens who sued him." • "Judge Rules Feds' Agreement With Jeffrey Epstein Pact Violated Teen Victims' Rights" published on February 22, 2019, reporting on a ruling by U.S. District Judge Kenneth Marra that "Federal prosecutors violated the rights of Jeffrey Epstein's teenage victims [under the Crime Victims' Rights Act] by failing to reveal they had dropped plans to prosecute the billionaire on dozens of federal charges in connection with the girls' claims that he paid them for sex at his Palm Beach mansion." • "Epstein Indicted On Sex Charges/Part-Time Palm Beacher Pleads Not Guilty to Sex Trafficking, Conspiracy Charges In Federal Court In Manhattan" published on July 9, 2019, reporting on Epstein's appearance in U.S. District Court for the Southern District of New York in which he "pleaded not guilty to charges accusing him of creating a vast network of girls as young as 14 that he exploited for his sexual pleasure at his homes in Palm Beach and Manhattan." A true and correct copy of the above news articles, in either the computerized format in which they are maintained in The Palm Beach Post's electronic archives or the news print edition in which originally published, is annexed hereto as Exhibit 1. 55. Since the filing of the initial Complaint in this matter, The Palm Beach Post- along with media worldwide - has continued to report on Epstein's crimes and the ongoing official proceedings resulting from those crimes. (2) The Palm Beach Post's Standing and the Public Interest. 56. The press has a constitutional right of access to criminal proceedings, see, e.g., Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 573 (1980), including pre-trial criminal proceedings. Newman v. Graddick, 696 F.2d 796 (11th Cir. 1983). Indeed, "the integrity of the judicial process, which public scrutiny is supposed to safeguard, is just as much at issue in proceedings of this kind [pre- and post-trial] as at trial." Id. at 801; see also Miami Herald Pub!. 15 CA/Aronberg-000131 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM Co. v. Lewis, 426 So. 2d 1, 6-7 (Fla. 1982) (identifying the news media as a “public surrogate” in matters concerning the closure of judicial proceedings). The press also has a First Amendment interest in receiving information from willing speakers. See Va. Pharmacy Bd. v. Va. Consumer Council, 425 U.S. 748, 756-57 (1976) (“Where a speaker exists . . . the protection afforded [by the First Amendment] is to the communication, to its source and to its recipients both.”); Pittman v. Cole, 267 F.3d 1269, 1283 n. 12 (11th Cir. 2001) (“The Supreme Court has recognized that the First Amendment offers protection to both speakers and those wishing to receive speech.”); see also Stephens v. Cty. ofAlbemarle, Va., 524 F.3d 485,492 (4th Cir. 2008) (providing that a plaintiff has “standing to assert a right to receive speech” by “showing] that there exists a speaker willing to convey the information to her”). 57. Because of the unique role performed by the press as a “public surrogate” (Lewis, 426 So. 2d at 6-7) in protecting the right of access and its interest in reporting information about criminal proceedings, news organizations “presumptively have a right to access judicial records,” Comm ’r, Ala. Dep’t ofCorr. v. Advance LocalMedia, LLC, 918 F.3d 1161, 1166 (11th Cir. 2019), and “standing to question the validity of an order restricting publicity because its ability to gather news is directly impaired or curtailed.” Lewis, 426 So. 2d at 4; see also Carlson v. United States, 837 F.3d 753, 757-58 (7th Cir. 2016) (“[a]s a member of the public, [the Reporters Committee] has standing to assert [its] claim” to grand jury materials because such materials are “public records to which the public may seek access, even if that effort is ultimately unsuccessful”). 58. Here, the continued denial of access to information The Palm Beach Post seeks on behalf of its journalists and the public it serves “unquestionably constitutes irreparable injury.” Gainesville Woman Care, LLC v. State ofFlorida, 210 So. 3d 1243, 1263 (Fla. 2017); see also Zerilli v. Smith, 656 F.2d 705, 711 (D.C. Cir. 1981) (noting that “the press’ function as a vital 16 CA/Aronberg-000132 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY Co. v. Lewis, 426 So. 2d 1, 6-7 (Fla. 1982) (identifying the news media as ~ "public surrogate" in matters concerning the closure of judicial proceedings). The press also has a First Amendment interest in receiving information from willing speakers. See Va. Pharmacy Ed. v. Va. Consumer Council, 425 U.S. 748, 756-57 (I 976) ("Where a speaker exists ... the protection afforded [by the First Amendment] is to the communication, to its source and to its recipients both."); Pittman v. Cole, 267 F.3d 1269, 1283 n.12 (11th Cir. 2001) ("The Supreme Court has recognized that the First Amendment offers protection to both speakers and those wishing to receive speech."); see also Stephens v. Cty. of Albemarle, Va., 524 F.3d 485,492 (4th Cir. 2008) (providing that a plaintiff has "standing to assert a right to receive speech" by "show[ing] that there exists a speaker willing to convey the information to her"). 57. Because of the unique role performed by the press as a "public surrogate" (Lewis, 426 So. 2d at 6-7) in protecting the right of access and its interest in reporting information about criminal proceedings, news organizations "presumptively have a right to access judicial records," Comm 'r, Ala. Dep 't of Corr. v. Advance Local Media, LLC, 918 F.3d 1161, 1166 (11th Cir. 2019), and "standing to question the validity of an order restricting publicity because its ability to gather news is directly impaired or curtailed." Lewis, 426 So. 2d at 4; see also Carlson v. United States, 837 F.3d 753, 757-58 (7th Cir. 2016) ("[a]s a member of the public, [the Reporters Committee] has standing to assert [its] claim" to grand jury materials because such materials are "public records to which the public may seek access, even if that effort is ultimately unsuccessful"). 58. Here, the continued denial of access to information The Palm Beach Post seeks on behalf of its journalists and the public it serves "unquestionably constitutes irreparable injury." Gainesville Woman Care, LLC v. State of Florida, 210 So. 3d 1243, 1263 (Fla. 2017); see also Zerilli v. Smith, 656 F.2d 705, 711 (D.C. Cir. 1981) (noting that "the press' function as a vital 16 CA/Aronberg-000132 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM source of information is weakened whenever the ability of journalists to gather information is impaired,” as it is by Attorney General’s refusal to disclose unredacted report and underlying grand jury materials). 59. The Palm Beach Post has the right to maintain this private right of action because the furtherance ofjustice, an express legislative exception to grand jury secrecy, is intended for the public benefit, and The Palm Beach Post seeks access on behalf of the public. Fla. Stat. § 905.27(l)(c). It is further express in Fla. Stat. § 905.27 that the legislature intended for a court to be the party to make the determination of disclosure. Fla. Stat. § 905.27(1). In other words, the legislature intended for recourse to the courts in considering and determining the propriety and scope of grand jury secrecy. E. The Court’s Jurisdiction And Authority. (1) The Court’s Supervision of the Grand Jury Process and Its Authority to Order Public Disclosure of the Epstein Evidence. 60. The Florida Supreme Court has noted that “in states such as Florida, where the grand jury is preserved, it is an important appendage of the court which impanels it. At the same time it should not be forgotten that the judge of that court is equally important and he is generally charged with the supervision of the grand jury’s activities... It is, therefore, of vital importance to maintain the dignity and the integrity of both the grand jury and the presiding judge.” State v. Clemons, 150 So. 2d 231, 233-34 (Fla. 1963). 61. Chapter 905 of the Florida Statutes governs the empanelment and conduct of Florida grand juries. The court gives the grand jury its initial charge and advises the grand jury about its legal duties. Fla. Stat. § 905.18. 62. Florida Stat. Section 905.27(1) provides that “the testimony of a witness examined before the grand jury ... or other evidence received by it” may be disclosed “when required by a 17 CA/Aronberg-000133 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY source of information is weakened whenever the ability of journalists to: gather information is impaired," as it is by Attorney General's refusal to disclose unredacted report and underlying grand jury materials). 59. The Palm Beach Post has the right to maintain this private right of action because the furtherance of justice, an express legislative exception to grand jury secrecy, is intended for the public benefit, and The Palm Beach Post seeks access on behalf of the public. Fla. Stat. § 905.27(l)(c). It is further express in Fla. Stat. § 905.27 that the legislature intended for a court to be the party to make the determination of disclosure. Fla. Stat. § 905.27(1 ). In other words, the legislature intended for recourse to the courts in considering and determining the propriety and scope of grand jury secrecy. E. The Court's Jurisdiction And Authority. (1) The Court's Supervision of the Grand Jury Process and Its Authority to Order Public Disclosure of the Epstein Evidence. 60. The Florida Supreme Court has noted that "in states such as Florida, where the grand jury is preserved, it is an important appendage of the court which impanels it. At the same time it should not be forgotten that the judge of that court is equally important and he is generally charged with the supervision of the grand jury's activities .. .It is, therefore, of vital importance to maintain the dignity and the integrity of both the grand jury and the presiding judge." State v. Clemons, 150 So. 2d 231, 233-34 (Fla. 1963). 61. Chapter 905 of the Florida Statutes governs the empanelment and conduct of Florida grand juries. The court gives the grand jury its initial charge and advises the grand jury about its legal duties. Fla. Stat. § 905.18. 62. Florida Stat. Section 905.27(1) provides that "the testimony of a witness examined before the grand jury ... or other evidence received by it" may be disclosed "when required by a 17 CA/ Aronbern.:-000133 FILE]): PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM court... for the purpose of: (a) Ascertaining whether it is consistent with the testimony given by the witness before the court; (b) Determining whether the witness is guilty of peijury; or (c) Furtheringjustice.” Fla. Stat. § 905.27(l)(a)-(c). 63. Further, disclosure is appropriate pursuant to this Court’s inherent authority over grand jury proceedings because of the exceptional public interest in this case and the compelling circumstances supporting transparency. Carlson v. UnitedStates, 837 F.3d at 766 (“a district court has the inherent power to disclose [grand jury] materials in exceptional circumstances and . . . historic importance can be a sufficient reason when there is little countervailing need for secrecy”). 64. The Florida Supreme Court has confirmed that grand jury secrecy is not absolute and that any “potential harm to public officeholders” from disclosure “will be the product of their own conduct, and not the consequence of an unrestrained body of misguided citizens.” Miami Herald Pub. Co. v. Marko, 352 So. 2d 518 (1977) (“The benefits to be derived from this extraordinary exercise in citizen participation [in the grand jury] would be severely limited if the fruits of that activity were not available to the public on whose behalf it is undertaken. Implicit in the power of the grand jury to investigate and expose official misconduct is the right ofthe people to be informed of its findings. While public disclosure of grand jury findings inevitably entails the risk of reputational damage, the legislature has ensured that any potential harm to public officeholders will be the product oftheir own conduct, and not the consequence of an unrestrained body of misguided citizens”). (2) The Court’s Jurisdiction To Declare Rights And Construe Statutes. 65. This Court has jurisdiction to declare rights, status, and other equitable or legal relations whether or not further relief is or could be claimed. Florida Stat. Section 86.011. 18 CA/Aronberg-000134 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY court ... for the purpose of: (a) Ascertaining whether it is consistent with the testimony given by I the witness before the court; (b) Determining whether the witness is guilty of perjury; or (c) Furthering justice." Fla. Stat. § 905.27(1 )(a)-( c ). 63. Further, disclosure is appropriate pursuant to this Court's inherent authority over grand jury proceedings because of the exceptional public interest in this case and the compelling circumstances supporting transparency. Carlson v. United States, 83 7 F .3d at 766 ("a district court has the inherent power to disclose [grand jury] materials in exceptional circumstances and ... historic importance can be a sufficient reason when there is little countervailing need for secrecy"). 64. The Florida Supreme Court has confirmed that grand jury secrecy is not absolute and that any "potential harm to public officeholders" from disclosure "will be the product of their own conduct, and not the consequence of an unrestrained body of misguided citizens." Miami Herald Pub. Co. v. Marko, 3 52 So. 2d 518 (1977) ("The benefits to be derived from this extraordinary exercise in citizen participation [in the grand jury] would be severely limited if the fruits of that activity were not available to the public on whose behalf it is undertaken. Implicit in the power of the grand jury to investigate and expose official misconduct is the right of the people to be informed of its findings. While public disclosure of grand jury findings inevitably entails the risk of reputational damage, the legislature has ensured that any potential harm to public officeholders will be the product of their own conduct, and not the consequence of an unrestrained body of misguided citizens."). (2) The Court's Jurisdiction To Declare Rights And Construe Statutes. 65. This Court has jurisdiction to declare rights, status, and other equitable or legal relations whether or not further relief is or could be claimed. Florida Stat. Section 86.011. 18 CA/Aropf{E¥s?~11(~ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 66. Florida law specifically provides that a declaration may be sought from the Court concerning a petitioner’s rights under a statute. Florida Stat. Section 86.021 (“Any person... whose rights, status, or other equitable or legal relations are affected by a statute, or any regulation made under statutory authority,...may have determined any question of construction or validity arising under such statute,... or any part thereof, and obtain a declaration ofrights, status, or other equitable or legal relations thereunder.”). 67. The Court’s exercise of its power to declare rights “is to be liberally administered and construed.” Florida Stat. Section 86.101. COUNT I (Declaratory Relief - Florida Stat. Sections 86.011 et seq.) 68. The allegations set forth in paragraphs 1 through 67 are incorporated by reference as if fully set forth herein. 69. This is an action for Declaratory Relief pursuant to Chapter 86, Florida Statutes, and other supplemental relief. 70. The Palm Beach Post respectfully requests that the Court declare that pursuant to Fla. Stat. Section 905.27(1), it is entitled access to the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County grand jury because such disclosure and access would be in the furtherance of justice. Fla. Stat. § 905.27(l)(c). Because The Palm Beach Post is not seeking these materials in connection with either a civil or criminal case, it seeks a declaration that the scope of its use of the disclosed materials is not limited. See Fla. Stat. § 905.27(2). 71. The Palm Beach Post further seeks a declaration that disclosure of the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County grand jury is appropriate 19 CA/Aronberg-000135 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY 66. Florida law specifically provides that a declaration may be sought from the Court I concerning a petitioner's rights under a statute. Florida Stat. Section 86.021 ("Any person ... whose rights, status, or other equitable or legal relations are affected by a statute, or any regulation made under statutory authority, ... may have determined any question of construction or validity arising under such statute, ... or any part thereof, and obtain a declaration of rights, status, or other equitable or legal relations thereunder."). 67. The Court's exercise of its power to declare rights "is to be liberally administered and construed." Florida Stat. Section 86.101. COUNT! (Declaratory Relief - Florida Stat. Sections 86.011 et seq.) 68. The allegations set forth in paragraphs 1 through 67 are incorporated by reference as if fully set forth herein. 69. This is an action for Declaratory Relief pursuant to Chapter 86, Florida Statutes, and other supplemental relief. 70. The Palm Beach Post respectfully requests that the Court declare that pursuant to Fla. Stat. Section 905.27(1), it is entitled access to the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County grand jury because such disclosure and access would be in the furtherance of justice. Fla. Stat. § 905.27(l)(c). Because The Palm Beach Post is not seeking these materials in connection with either a civil or criminal case, it seeks a declaration that the scope of its use of the disclosed materials is not limited. See Fla. Stat. § 905.27(2). 71. The Palm Beach Post further seeks a declaration that disclosure of the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County grand jury is appropriate 19 CA/AronbeLq-.000135 FILEU: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM pursuant to this Court’s inherent authority over grand jury proceedings because of the exceptional public interest in this case and the compelling circumstances supporting transparency. 72. The Palm Beach Post has sought from Defendants, but Defendants have refused to provide, access to the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County grand jury. Indeed, Defendants have each filed motions to dismiss the Complaint and the relief it sought under Fla. Stat. Section 905.27(1). Accordingly, a good-faith dispute exists between the parties. 73. Through this Complaint, The Palm Beach Post presently has a justiciable question concerning its rights to obtain the 2006 grandjury materials pursuant to Fla. Stat. Section 905.27(1) and the Court’s inherent authority. 74. A bona fide, actual, present, and practical need for the declaration exists in that Defendants have denied to The Palm Beach Post - and to the public at large - the grand jury materials sought to be disclosed. The relief sought from the Court is therefore not merely the giving of legal advice or to answer hypothetical questions. WHEREFORE, The Palm Beach Post respectfully requests that the Court determine the rights and obligations of the parties by declaring that pursuant to Fla. Stat. Section 905.27(l)(c) and the Court’s inherent authority, The Palm Beach Post may gain access to the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County grand jury and use those materials for the purpose of informing the public. COUNT n (Florida Stat. Section 905.27) 75. The allegations set forth in paragraphs 1 through 74 are incorporated by reference as if fully set forth herein. 20 CA/Aronberg-000136 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY I pursuant to this Court's inherent authority over grand jury proceedings because of the exceptional public interest in this case and the compelling circumstances supporting transparency. 72. The Palm Beach Post has sought from Defendants, but Defendants have refused to provide, access to the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County grand jury. Indeed, Defendants have each filed motions to dismiss the Complaint and the relief it sought under Fla. Stat. Section 905.27(1). Accordingly, a good-faith dispute exists between the parties. 73. Through this Complaint, The Palm Beach Post presently has a justiciable question concerning its rights to obtain the 2006 grand jury materials pursuant to Fla. Stat. Section 905.27(1) and the Court's inherent authority. 74. A bona fide, actual, present, and practical need for the declaration exists in that Defendants have denied to The Palm Beach Post - and to the public at large - the grand jury materials sought to be disclosed. The relief sought from the Court is therefore not mere! y the giving of legal advice or to answer hypothetical questions. WHEREFORE, The Palm Beach Post respectfully requests that the Court determine the rights and obligations of the parties by declaring that pursuant to Fla. Stat. Section 905.27(l)(c) and the Court's inherent authority, The Palm Beach Post may gain access to the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County grand jury and use those materials for the purpose of informing the public. COUNT II (Florida Stat. Section 905.27) 75. The allegations set forth in paragraphs 1 through 74 are incorporated by reference as if fully set forth herein. 20 CA/Aronbera-000136 FILEU: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 76. Based on information learned by The Palm Beach Post through its Florida Public Records Law requests, law enforcement sources with direct knowledge of the grand jury evidence and proceedings, judicial documents obtained from independent but related court proceedings, and documents otherwise available in the public record, the State Attorney for Palm Beach County presented truncated evidence ofEpstein’s criminal wrongdoing to the 2006 grand jury in a manner that precluded his indictment for the serious crimes he committed, including sex trafficking and sexual assault. 77. Pursuant to Florida Stat. Section 905.27, in order to further justice for Epstein’s victims and the public, and to provide public disclosure to illuminate whether Epstein received unreasonably lenient treatment based on the available evidence, The Palm Beach Post requests immediate access to the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County grand jury. 78. In a case of this magnitude and importance, where the accused is dead and so many of his crimes, as well as the identities and crimes of his co-conspirators, and the identities of the victims have already been exposed, the need for grand jury secrecy is no more. See United States v. Socony-Vacuum Oil Co., 310 U.S. 150, 234 (1940) (“[A]fter the grand jury’s functions are ended, disclosure is wholly proper where the ends ofjustice require it.”). WHEREFORE, The Palm Beach Post respectfully requests that thi s Court, pursuant to Fla. Stat. Section 905.27(1) and the Court’s inherent authority, order the State Attorney and the Clerk of the Court to file with this Court copies of the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County grand jury during the first Epstein sex abuse investigation so that, following an in camera inspection, it can be made available to The Palm Beach Post and the 21 CA/Aronberg-000137 FILET): PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY I 76. Based on information learned by The Palm Beach Post through its Florida Public Records Law requests, law enforcement sources with direct knowledge of the grand jury evidence and proceedings, judicial documents obtained from independent but related court proceedings, and documents otherwise available in the public record, the State Attorney for Palm Beach County presented truncated evidence of Epstein's criminal wrongdoing to the 2006 grand jury in a manner that precluded his indictment for the serious crimes he committed, including sex trafficking and sexual assault. 77. Pursuant to Florida Stat. Section 905.27, in order to further justice for Epstein's victims and the public, and to provide public disclosure to illuminate whether Epstein received unreasonably lenient treatment based on the available evidence, The Palm Beach Post requests immediate access to the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County grand jury. 78. In a case of this magnitude and importance, where the accused is dead and so many of his crimes, as well as the identities and crimes of his co-conspirators, and the identities of the victims have already been exposed, the need for grand jury secrecy is no more. See United States v. Socony-Vacuum Oil Co., 310 U.S. 150, 234 (1940) ("[A]fter the grand jury's functions are ended, disclosure is wholly proper where the ends of justice require it."). WHEREFORE, The Palm Beach Post respectfully requests that this Court, pursuant to Fla. Stat. Section 905.27(1) and the Court's inherent authority, order the State Attorney and the Clerk of the Court to file with this Court copies of the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County grand jury during the first Epstein sex abuse investigation so that, following an in camera inspection, it can be made available to The Palm Beach Post and the 21 CA/AronbeLQ-000137 FILEU: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM public on an expedited basis, and grant any other and further equitable of legal relief the Court deems just and proper. Dated: January 17, 2020 Respectfully submitted, GREENBERG TRAURIG, P.A. Attorneys for CA Florida Holdings, LLC, Publisher of The Palm Beach Post Stephen A. Mendelsohn, Esq. 5100 Town Center Circle, Suite 400 Boca Raton, Florida 33486 Telephone: (561) 955-7629 Facsimile: (561) 338-7099 By: /s/Stephen A.Mendelsohn_ STEPHEN A. MENDELSOHN Florida Bar No. 849324 [email protected] [email protected] [email protected] By: /s/MichaelJGrygiel_ MICHAEL J GRYGIEL (Admitted Pro Hac Vice) 54 State St., 6th Floor Albany, New York 12207 Telephone: (518) 689-1400 Facsimile: (518)689-1499 [email protected] By: /s/NinaD.Boyajian_ NINA D. BOYAJIAN (Pro Hac Vice application pending) 1840 Century Park East, Suite 1900 Los Angeles CA 90067 Telephone: (310) 586 -7700 Facsimile: (310) 586 -7800 boyaj [email protected] [email protected] 22 CA/Aronberg-000138 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY public on an expedited basis, and grant any other and further equitable or; legal relief the Court deems just and proper. Dated: January 17, 2020 Respectfully submitted, GREENBERG TRAURIG, P.A. Attorneys for CA Florida Holdings, LLC, Publisher of The Palm Beach Post Stephen A. Mendelsohn, Esq. 5100 Town Center Circle, Suite 400 Boca Raton, Florida 33486 Telephone: (561) 955-7629 Facsimile: (561) 338-7099 By: Isl Stephen A. Mendelsohn STEPHEN A. MENDELSOHN Florida Bar No. 849324 [email protected] [email protected] [email protected] By: Isl Michael J G,ygiel MICHAEL J GRYGIEL (Admitted Pro Hae Vice) 54 State St., 6th Floor Albany, New York 12207 Telephone: (518) 689-1400 Facsimile: (518) 689-1499 [email protected] By: Isl Nina D. Boyaiian NINA D. BOY AJIAN (Pro Hae Vice application pending) 1840 Century Park East, Suite 1900 Los Angeles CA 90067 Telephone: (310) 586 -7700 Facsimile: (310) 586 -7800 [email protected] [email protected] 22 CA/AronbeLQ:-000138 FILb1J: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 17th day of January, 2020, a copy of the foregoing has been electronically filed with the Florida E-File Portal for e-service on all parties of record herein. /s/Stephen A.Mendelsohn_ STEPHEN A. MENDELSOHN CA/Aronberq-000139 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 17th day of January, 2020, a copy of the foregoing has been electronically filed with the Florida E-File Portal fore-service on all parties of record herein. Isl Stephen A. Mendelsohn STEPHEN A MENDELSOHN 23 CA/Aro¥~rms?W1~r~ BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM EXHIBIT 1 The Newspaper’ s Reportage on Jeffrey Epstein CA/Aronberg FILE!1-000140 ): PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY The Newspaper's Reportage on Jeffrey Epstein CA/AronbeLQ-000140 FILEU: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM ... . , .... ... _ ...... I, TheMm Beach fbst _ REALNEWSSTARTS HERE The Man WhoHad Everything: Jeffrey Epstein craved big homes, elite friends and underage girls By Andrew Marra Posted Jul 17; 2019 at 6:02 AM From the archives: When Palm Beach detectives started asking questions and teenage girls started talking, a wave of legal resistance followed, Editor's Note:, This article appeared in The Palm Beach Post on August 14,2006, three weeks after Jeffrey Epstein’s arrest in Palm Beach County on a charge offelony solicitation ofprostitution. WINGED GARGOYLES guarded the gate at Jeffrey Epstein’s Palm Beach mansion. Inside, hidden cameras trolled two rooms, while the. girls came and went. For the police detectives who sifted through the garbage outside and kept records ofvisitors, it was the lair of a troubling target. Epstein, one ofthe most mysterious of the country’s mega-rich, was known as much for his secrecy as for his love of fine things: magnificent homes,, private jets, beautiful women, friendships with the world’s elite. But at Palm Beach police headquarters, he was becoming known for something else: the regular arrival ofteenage girls he hired to: give: him massages and, police say, perform sexual fayprs. Epstein Was different from most sexual abuse suspects; he was far more powerful. He counted among his friends former President Bill.Clinton, Donald Truinp and Prince Andrew, along with some of the most prominent legal, scientific and business minds in the country. When detectives started asking questions and teenage girls started' talking, a wave of legal resistance, followed. CA/Aronberg-000141 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY I 'The Palm Beach Post REAUNEWS{STARTS HERE __ _ . .... _________ _ The\ :M'alJ; Wb.o: lll:all :Eveiyt.hillg_; Je.ffrey: E~p,slbi:n ·orated big, h-onles, elite :,friends ,and- u-rad;era'ge::Igi"rls B,y. Andrl!W Marrc1 P9s:t"~d)ui17.,"ii5i9.~16:02 AM From the archives: When Palm Beach detectives started asking questions and teenage girls started talk:ing1 a wave of legal resistance followed. E.ditor-'s-No.te:, This arti_de_ appeared in The Palm Beach Post on August 14,200.6, three wee.ks after Jrffrey Epstein's attest in.Palm Beach County on a charge of felony solicitation ofpr.ostitution. WINGED GAR.GOYLES:guardedthe gate at Jeffrey Epstein's· Paln:i Beach man.siqn. Insicie, h1dden cam~ras trolkd two ro·oms, while the, girls came and w~nt. :For the police de.te.ctives who sifted through the garb.age outside and kept re~cor.ds of visitors, it was the lair of a troublin& target . .Epstein, one of the most mysterious of the country's mega-rich, was known as much for his se~recy as for his love of fine things: n1:agpi.fice_Ilt hm:nes,, prjvafe je_ts, be<1lltift1l women, friendships with the world's elite. But at Palm Beach police headquarters, he was becoming known for something else: the s • ,, • regular arrival of teenage girls he hired t<> give him ma_s~ages ~d, polic:e s~y, perform ·sexual . . . fayors. Epstein was differehtfrom.m·ost sexual abuse suspects; he·wa:sfar more powerfuL He cotuited ai:hohg his friends former President BiltClinton, Donald Ttutnp and Pri.rlce•.Andrew, along with some of tl;ie mostprqip.1_n~p~ l~g~, ~cientific a11d busjn~ss mind~ in \he q;n1ntry. Whe11 detectives sfa_rted a~king ques.tion:s and t~en~ge girls Stc!rted· talking, a waye oflegal resistance followed. CA/Aronbeni-000141 FILEU: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3/27/2023 2:57:43 PM » NEW: Jeffrey Epstein: Lawyer said financier had sex with woman during work- release ’ If Palm Beach police didn’t know quite who Jeffrey Epstein was, they found out soon enough. Epstein, now 53, was a quintessential man ofmystery. He amassed his fortune and friends quietly, always in the background as he navigated New York high society. When he first attracted notice in the early 1990s, it was on account of the woman he was dating: Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell. In a lengthy article, headlined "The Mystery of Ghislaine Maxwell’s Secret Love,” the British Mail on Sunday tabloid laid out speculative stories that the socialite’s beau was a CIA spook, a math teacher, a concert pianist or a corporate headhunter, "But what is the truth about him?” the newspaper wondered. "Like Maxwell, Epstein is both flamboyant and intensely private.” The media frenzy did not begin in full until a decade later. In September 2002, Epstein was flung into the limefight when he flew Clinton and actors Kevin Spacey and Chris Tucker to Africa on his private jet. Suddenly everyone wanted to know who Epstein was. New York magazine and Vanity Fair published lengthy profiles. The New York Post fisted him as one ofthe city’s most eligible bachelors and began; describing him in its gossip columns with adjectives such as “mysterious” and “reclusive.” Although Epstein gave no interviews, the broad strokes of his past started to come into focus; Building a life ofextravagance He was born blue-collar in 1953, the son of a New York City parks department employee, and raised in Brooklyn’s Coney Island neighborhood. He left college without a bachelor’s degree but became a math teacher at the prestigious- Dalton School, in Manhattan; The story goes that the father of one of Epsteins students was so impressed with theman that he put him in touch with a senior partner at Bear Stearns, the global investment bank and securities firm. CA/Aronberq-000142 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY >> NEW: Jeffrey·Epstein: Lawyer said financier liad sex with woi'p.an during work- /·:~~~.:.~:~:::~,:~· ..... ,-, ... '<"'·-: • .:,;.-.. < > .-.. -, ':.~.~•'_'~-:~~:.-., •• ,,,._, .• -.-..: ., . •'--,.,_,~~;~;;";'~~:~';'': ., .. , .• v-~ 1 .. -- -~"· _ ..... , · -. __ . "· -,,::t.':-::t release :if Palm BeaGh,,pdlice didn't know quite who Jeffrey Epstein was, they found out soon enougp,. Epstein, now.53,was a: quintessential man ofmystery. He amassed his.fortune and friends quietly, always in the background as he .navigated New Y otk high society. When: he first attrac:t~d nqtice in the early l 990s, it was on account of the v,r9man he was dating: Ghislaine Maxwell, daughter of the late British media: tycoon Robert Maxwell. In a len~thyartide, headlined ;The Mystery of Ghislaine Maxwell's Secret Love," the British Mail ort Sunday tabloid laid out speculative stories fuatthe socialite's beau wa:s a CIA spook, a .math. te~cher, ,a coP,certpfamist or a c_orpornte J1eadht1nter; ''Bu_t what is the truth ,!boµt hhn?" the n~wsp.:1per wqndeJ.~d. "Like ,Ivtaxwell, Epstein is_ both flamboyant- and inte:nseiy private/ The media:frenzy did not begin in full until a decade later; In September 2002, Epstein was flung into the limelight when he. flew CH.nton and actors Kevin Spacey and Chris Tucker to Africa on his private jet. :Suddenly everyone wanted to know who Epsteir1 was. New York magazine a11d Van:icy Fair J)_\l!:>Ji.~~t4J!~g!l?:ypt_2f~.~~- The New York Post listed him as one of the city's most eligible ,b.i_cbelqrs Imd bega_n.: desc,:ri.bing hirp in its gossip: columns with a.djectiyes. suc:h a,s "mystedout a:nd '' recl'usiye/· Although Epstein gave no interviews, the" broad strokes' :of his past started to come into fc>:cus; Buildin~ .a life, of extravagance He was bor_nblue-collar'in 195:3! the son of a New York City, parks depar.tment employee, and raised in Bro0klyn'sConey Island neighborhood, He kfr college without-a bachelor's. degr~e butbetame a: math teacher at the prestigio:t:1s' Dalton Schooi in Manhattan, The story goes that the father of one of Epstein's studenfs,was·so impressed with the man that he puthim fo to:uc:h Witha seniorpartner: at'BearStearns,the glob~ investmentbank and ,se.curities firm. CA/Aronberg-000142 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM In 1976, Epstein left Dalton for a job at Bear Stearns. By the early 1980s, he had started}. Epstein and Co. That is,when he began making:his millions in earnest. ' Little is known or said about Epstein’s business except this: He manages money for the extremely wealthy. He is said to handle accounts only of 51 billion or greater. It has been estimated he has roughly 15 clients, but their identities are the subject of only speculation. All.except for one: Leslie Wexner, founder of The Limited retail chain and a former Palm Beacher who is said to have been a mentor to Epstein. Wexner sold Epstein one of his most lavish residences: a massive townhouse that dominates a blockon Manhattan’s Upper East Side. It is reported to have, among its finer features, closed- circuit television and a heated sidewalk to melt away fallen snow. That townhouse, thought to be the largest private,residence in Manhattan, is only a piece of the extravagant world Epstein built over time. In New Mexico, he constructed a 27,000.-square-foot:hilltop mansion on a 10,000-acre ranch outside Santa Fe. Many believed it to be.the largest home in the state. In Palm Beach, he bought a waterfront home on El Brillo Way. And he owns a 100-acre private island in the Virgin Islands. » PHOTOS: The players in the Jeffrey Epstein saga Perhaps as remarkable as his lavish homes is his extensive network of friends and associates at the highest echelons ofpower. This includes not only socialites but also business tycoons, media moguls, politicians, royalty and Nobel Prize-winning scientists whose research he often funds. "Just like other people, collect art, he collects scientists,” said Martin Nowak, who directs the Program for Evolutionary Dynamics at Harvard University and was reportedly the recipient of a $30 million research donation from Epstein. Epstein is said to have befriended former Harvard President Larry Summers, prominent law Professor Alan Dershowitz, Donald Trump and New York Daily News. Publisher Mort Zuckerman. CA/Aronberg-000143 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY ' h1_ 1976, Ep~tejn_ left DaJt9n for .i,· jol? a,t :aear Stea,:rp.~"' l?y th~ ea:rly l980s11he ~h~g. ~tarted J. I Epstein and Co. That is, when he began making his millions in earnest. : ' I Little is known or said about Epstein's business except 1:his: He manages )119_ney for the extremely wealthy. He -is said to handle ·accounts only-of $1 billion -or ~reatet. It has:heenestiniated he has toughly 15 clients, but their.identities are the subject of only specµl_a.tiqn. All except for o_ne:L_eshe Wexne_r, fowic;ier ofTh~ L_imited retail,~hai_n a.nd a former Palm Beacher who is said to have been a mentotto Epstein~ W exner sold Epstein one of his most lavish: res'idences: a ·massive towiih6.use that dominates a bloc;k on MaJlhatt;m's Upper: East .Side. It is ,reported to b.a.ve, among, its :finer features, c;lqsed,. circ11it television a.nd a he.at,edsidewalk to meh-awayJailen snow. That townhouse, thought to .be the. iargest private.residence in Manhattan, is only a: piece of the extravagant world Epstein built over time. In New Mexico_; he constructed a 27,000.-square-foot:hilltop mansion on a 10,000-acre ranch outside Sant.a Fe. Many believed;it to be:the la.rgest home in the state, In Palm Beach, he bought a waterfront home on El Brillo Way. And: he owns a 100-acre private island in the Vir~in Islands. ·Perhaps as reIParkible _as his fav.ish h:o.rnes is his extensive network •Of fdends and a.ssocjates a.t the highest echefons ofp:ow.er. This includes not only socialites but also business tycoons, media moguls, politicians, royalty a:rtd Nobel Prize-Winning scientists whose research he often Jur1ds. ''.)11st like o_ther p~ople c_pll_ec;t art, he c:qll~ct~ sc:i~ntists," ~~id Marti11 Nowak, who directs the Program for Evolutionary Dyhatnits· a:tHatva:rd University and was' r~pottedly the recipi'entof a $30 million research donation from Epstein. I _Epstei11 is gid to b~v~ befri~I1<;led fo:rrner Ba.rvard P.re~tde11t cL_ar_ry S11IJ1m.ers, prnllli:n,ent I.i,w Professor. Alan Dershowitz1 borialc:l Tn1mp and New York Daily News. Pµ.blisher Mort Zuckerman. CA/AronbeLq-000143 FILEU: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM And yet he managed for decades to maintain a low profile. He avoids eating out and was rarely photographed. i "The odd thing is I never met him,” said Dominick Dunne, the famous chronicler of the trials and tribulations of the very rich. “I wasn’t even aware of him,” except for a Vanity Fair article. Epstein’s friendship with Clinton has attracted the most attention. Epstein met Clinton as early as 1995, when he paid' tens of thousands of dollars to join him at ah intimate fund-raising dinner in Palm Beach. But from all appearances,.they did not become close friends until after Clinton left the Oval Office and moved to New York. Epstein has donated more than $100,000 to Democratic candidates’ campaigns, including John Kerry’s presidential bid, the reelection campaign ofNew Mexico Gov. Bill Richardson and the Senate bids ofJoe Lieberman, Hillary Rodham Clinton, Christopher, Dodd and Charles Schumer. Powerful friends and enemies A Vanity Fair profilefound cracks in the veneer of Epstein’s life story. The 2003 article said he left Bear Stearns in the wake of a federal probe and a possible Securities and Exchange Commission violation. It also pointed out that Citibank once sued him for defaulting on a $20 million loan. The article suggested that one of his business mentors and previous employers was Steven Hoffenberg, now serving a prison term.after"bilking investors out of more than $450 million in one ofthe largest Ponzi schemes in .American history.” As he amassed his wealth, Epstein made enemies in disputes, both large and small. He sued the man who in 1990 sold him his Palm Beach home over a dispute abdut.less than $16,000 in furnishings. A former friend claimed Epstein backed out of a promise to reimburse him hundreds of thousands of dollars after their failed investment in Texas Oil wells. A judge decided Epstein owed him nothing. » Jeffrey Epstein: Model prisoner who syyept, mopped floors, official says CA/Aronberg-000144 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY I . .. . ' ! . . And yet he managed for dec:a.des to maintain a low profile. He a:void's eatii1g out and was ta.rely photographed. I 'The odd:thing is I never met him;" said Dominick Dunne, the .famous chronicler of the trials and tribulations of the·very rich. "I wasn'.t even .aware of him,J' except. for a Vanity Fair article., ,Epstein's friendship with Clii:)tim has.attracted: the most attention. Epstdn met Clinton. as early a:s 1995_, when. he_ paid' tens •Cif thousands of doiiars to join him a:t ah 'intimate fond..,raisirtg dirtn:er irt P'alrn. Beach. But from all appearances,, they did not become close friends until after Cli_r1ton.left the Oval Office and moved t9 N.ewYoik. Epstein has donated more than $100,0QO to :Democratic candidates' camp_aigns, including John Kerry's presidential bid, the reelection. campaign of New Mexico, Gov. Bill Richardson and the Senate bids of Joe Liebetrna:n, Hillary Rodham Clinton, Christopher: Dodd and Charles Schumer. ·p9werfµl fti~_n<ls and ~n_enn.es A Vanity Fair profile.round cracks in tne veneer of Epsteirt'.s iif~ story. The<2003 article said he left Bear Stearns in the wake of~ federal probe and a possible Securities and :Exchange Commi,ssion yiqlation. It al$o pQirit~d oµt tha~ Gitibank 011,ce .sJJe_d h_i111 fqr !iefatJ,lting on a $20 million loan. The article suggested that one· of his business mentors and J,tevichis employers was Steven Hoffenberg, now serving a pris·on term after 'bilking investors out of more than $450 rniJlion in one ofthdcJ.rge;;t PoAzi s~h~mes in Amgriqm ,hi~tory.11 As h~ :;i,mc1~sed his wealtb., Epst.ei.n made enemies m disputes, both farge and smail., He:sued the mart who in 1990 sold him his multimillion-dollar Palm Beat~ home.over a: dis·pute aboufless than $16,000 in furnishings. A fonn~r friend cJai,m,~d Epste1n J:,a~k~d QU.t of a prqmisg !()relmbu.r.se him htJ.ndreds: of thousands of dollars after their failed in:ves.tment in Texas oil welis, A judge decided E_pstein owed him riothing. CA/Aronberg~000144 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3/27/2023 2:57:43 PM “It’s a bad memory. I would rather not have ever met Jeffrey Epstein,” said Michael Stroll; the retired former- president of Williams Electronics and Sega Corp. “Sufficejit to say I have nothing good to say about him.” j Among the characteristics most attributed to Epstein is a penchant for women. He has been linked to Maxwell, a fixture on the high-society party circuits in both New York and London. are said to include a former Ms. Sweden and a Romanian model. “He’s a lot offun to be with,” Donald Trump told New York magazine in 2002. “It is even said that he likes beautiful women as much as I do, and many of them are on the younger side. No doubt about it, Jeffrey enjoys his social life.” Investigation leads to Epstein Although he was not a frequenter1of the Palm Beach social scene, he made his presence felt. Among his charitable donations, he gave 590,000 to the Palm Beach Police Department and SI00,000 to Ballet Florida. In Palm Beach, he lived in luxury. Three black Mercedes sat in his garage, alongside a green Harley-Davidson, His jet waited at a hangar at Palm Beach International Airport. At home, a private chef and a small staff stood at the ready. From a window in his mansion, he could look out on the Intracoastal Waterway and the West Palm Beach skyline.. He seemed to be a man who had everything. But extraordinary wealth can fuel extraordinary desires. » Epstein wants to leave jail for mansion in sex-trafficking case In March 2005, a worried mother contacted Palm Beach police. She said another parent had overheard a conversation between their children. Now the mother was afraid her 14-year-old daughter had been molested by a man on the island. The phone call triggered an extensive investigation, .one that would lead detectives to Epstein, but leave them frustrated. i i i CA/Aronberq-000145 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY I I .. I . . . . ·. I "IJ' s :a: b~d roem01:y I woulci rather n.ot have, evei: met J e,ffrey Epstein," saicl Mic::ha.el Str,qll; the retire<l forme1: presid'ent of Williams, Eleetton:ics ·an·a Sega Cor:I?· "SuffrceJit to sayl have' • nothing good to say aboUt liim." Among the characteristics 'inost attributed to Epstein is a penchant for women. He, ha$ been lir:ilce,dto M~ell, •?-. fixtµre .9n the high-sqciety pa.i;ty c.ircuits 111 both New York and London. Previo:us:girlfriends are said to inc.::lude aJormer Ms. Swe.den and a Romanian mooeL "He's.a lot of fun to be with," Donald Trump tolqNewYork,magazine in 2002. ''.It is even said that. he likes be,autifol women.as 111uch as l do, anq many·qf them a.re on th'e younger side. No doubt abo.ut it;Jeftrey enjoys his social lifet Investigation leads to Epstein Although he was. not a frequenter of the, Palm Beach social scene, he made .his presence felt. Among his charitable donations, he gave $90,000 to the. ·PalmJ~e_ach Po Hee :Department and. $100,000 .to 8ailet Fiodda. InPalm Beach, he Jived in lllXllry. Three blatkMercedes<sat in his garage; alongside a green Harley-Davidson, His jet waited at ahangar at Palm Beach International Airport. Athome, a private chef :md a sma.11 staff stood at the ready. From a window in his mansion, he cowd look out cm the Intraco.astal Waterway and the West Palm Beach skyline .. He :seemed to be a man Who had everything. Sut ~xtraordin~.rywe_alth mm fuer extrawdin;iry desires. » Ep~t~in w:c1.nt~ t<>lec1.v~jau for mc1.n~i_<>n 1n_sex-trnffic:kingc,c1.se -;-- --- _-_ ·:.: :·. -~~ .-. . ., ~ "" - :-·- -~ .- :. :.·. ·.::·;:·_,. ·: ,- - -~ ---.·-~--:~ __ ·_:_·-··· --~- -.: ::: • _-.'":~YY:!:'::_:_-- ."0:~·_·:·-:·_-;.·····.-::." :_ -.-_---·· _3·_-···"0·. ".".~-. ··:·:• ..•.. :·;:_-_, :). '". .- ::: .. :.: In Match 2005, a- worried mother. contacted Palin Beach p:olice. She said another patent had overheard a conversation between their tliildteii. Now the mqth~r Wei,$ afra.id h~r 14-yt;ar-qld d?,ughter had been. wolestecLby a. rn,a,11 on th~ island, The phone c:all triggered an extensive; investigation, .one that would lead _detectives to Epstein; but leave them frustrated. CA/Aronbern_,-000145 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM Palm Beach police and the state attorney’s office have declined to discuss the case. But a Palm Beach police report detailing the criminal probe offers a window into what detectives:faced as they sought to close in on Epstein. ; Detectives interviewed the girl, who told them a friend had invited her to a rich man’s house to perform a massage. She said the friend,told her to say she was 18 if asked. At the house, she said she was paid $300 after stripping to her panties arid massaging the man while he masturbated. Police interview 5 alleged victims The investigation began in full after the girl identified Epstein in a photo as the man who had paid her. Police arranged for garbage trucks to set aside Epstein’s trash so police could sift through it. They set up a video camera to record the comings and goings at his home., They monitored ait airport'hangar for signs ofhis private jet’s arrivals and departures. They quickly learned that the woman who took the 14-year-old girl to Epstein’s house was Haley Robson, a Palm Beach Community College student from Loxahatchee. In a sworn statement at police headquarters, Robson, then 18, admitted she had taken at least six girls to visit Epstein, all between the ages of 14 and 16. Epstein paid her for each visit, she said. During the drive.back toher house, Robson told detectives, “I’m like a Heidi Fleiss.” Police interviewed five alleged victims arid 17 witnesses. Their report.shows some of the girls said they had been instructed to have sex with another woman in front of Epstein, arid one said she had direct intercourse with him.. In October,, police searched the Palm Beach mansion. They discovered photos of naked, young- looking femalesJust as several of the girls had described in interviews. Hidden cameras were found in the garage area and inside a clock on Epstein’s desk, alongside a girl’s high school transcript. Two of Epstein’s former employees told investigators that young-looking girls showed up to perform massages two or three times a day when Epstein was in town. ; They said the girls were permitted many indulgences, A chef cooked for them, Workers gave .7 ‘ * - - - . ./ 7. ( them rides and handed out hundreds of dollars at a time. CA/Aronberg-000146 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY I I I I i I Palm Beach poliee and 'b.' sta(e atton,•Ys ~ffiee !rave declilled to ~iscl!Ss ~• <ase. But a )'aim Beach police report deta1lmg the cnmmal probe offers a-wmdow mto wliat .detectives faced as • . ' they ~qught to close in onEpstein. Dete~tfves interviewed the g_id, who told them a friend had invited her to a rich man's: house to perform a massage. She said the: friend told her to' _say she was 18 if asked'. A..t the house, she said she was paid $3:00 a:ftersttippirtg to het ·pa·nties and ma·ssaging'the man while he m,_3,stl1rbated. Polfoe interview S.alleged victims Th~ investigation began in fufi after the girl identified Epstein in a· photo is the man who had paid her. Police arranged for garbage trucks to set.aside Epsteirfstrash so police could sift W,rQµgh ft, Tlv~y set up a video ·camera to record the :comings and goings: at his home., They monitored an airport hangar for-,signs q{his private j!=t' s. arrivals and depart:ures. They quickly learned' that the: woman who took the 14-year-old:girl to Epstein~s hquse was Haley Robson, a Palm Beach Community College student from Loxahatchee. In a: sw.ofii statement :it police 1:ieadql,larters, Rops9n! th.en 181 admitted she had taken at least six g_irls to visit Epstein, ali be~een the ages of 14 a,nd'l6. Ep_stein pc1id her for !=ach 0sit, .she said, During the dtive.bat:k.to her :house, Robson: told cletedives, 'Tm like a Heidi Pleiss/' Police interviewed five alleged victims and J 7 witnesses, Their rep.orrshows some of the ,girls said. they :hgd l;>ee11. instructed to have sex with another woman in front of Epstein, and one said she nad' direct intercourse with him .. In October, police sear.thed the Palm Beach mansion. They discovere_d photos of:naked, young- looking Jemales,just as several of the girls had des.cribed iri interviews. Hidden caineras;were found in the ga_n.J.ge area :and inside a, clock on.Epstein's de.sk, aJo_ngside a gi_rrs high school transcript. Two of Ep·steinis former .employees told investigators that young~looking girl's showed up to perform massages two-or three times a day when Epstein was hi tbWii. '. The.y said tl;i~ girls we.re p~rmiJted manyi11dufgences .. A chef cooked Io_r th,em, W 9rkers gave I them rides and handed out hundreds of dollars at a time. CA/ Aronberg-000146 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM One employee told detectives he was told to send a dozen roses to one teenage girl after a high school drama performance. Others were given rental cars. One, according to police, received a I $200 Christmas bonus. The cops moved to cement their case. But as they tried to tighten the noose, they encountered, other forces, at work. In Orlando they interviewed a possible victim who told them nothing inappropriate had happened between her and Epstein. They asked her whether she had spoken to anyone’else. She said yes, a private investigator had asked her the same questions. » Jeffrey Epstein: Acosta, Krischer trade barbs over sweethealrt deal When they subpoenaed one of Epstein's former employees, he told them the same thing. He and a private eye had met at a restaurant days earlier to go over what the man would tell investigators. Detectives received complaints that private eyes were posing as police officers. When they told Epstein’s local attorney, Guy Fronstin, he said the investigators worked for Roy Black, the high-powered Miami lawyer who has defended the likes of Rush Limbaugh and William Kennedy Smith. While the private eyes were conducting a parallel investigation, Dershowitz, the Harvard laiw professor, traveled to WestPalm Beach with information about the girls. From their own profiles on the popular Web site MySpace.com, he obtained copies of their discussions about their use of alcohol and marijuana. He took his research to a meeting with prosecutors in early 2006, where he sought to cast doubt on the-teens’ reliability, The. private eyes had dug up enough dirt on the girls to make prosecutors skeptical. Not only did some of the girls have issues with drugs or alcohol, but also some had 'criminal, records and other troubles, Epstein’s legal team claimed. And at least one of them, they said, lied when she told police she was younger than 18 when she started performing massages for Epstein. After the meeting, prosecutors postponed their decision to take the case to a grand jury; CA/Aronberg-000147 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY i I I One employ)~e told dete'ctives he was told to send a. dozen roses to one_ teenage girl aftet a high . I . school drama performance. Others we:te-giv:e:h rental cars. One; according to police; received a • I $200 Christmas bqnt1s. • The cops moved to ceI11ent thefr case. :Butas tf1ey tried to tighten Jhe noose, they encountered. other forces at work. In Orlando they interviewed a possible victim who told them nothing. inappropriate had happened.betvveenherand Epstein. Theyaskedh~r-wheth,er sh.e;had spoken to;:iny9ne·dsf. She said yes, a private investigator had asked her the same qµestions. >> Jeffrey EJfstein: Acosta, Krischer trade barbs over sweetheatt de·aI •~••~••:,;-.,.:~-•-•>_,,-,.,.,0-, • ..:.;,;,,,-_, _-,_ - C • • ~-•••~••~.-•-•••,•·;,,,.•~•-:-•"7"-•·•.•• • < • • •· • - • - • - • - • - • .-,.. ··• • • - • • • .••',~-• .. -••••-••••"••~••-.. When they subpoenaed .one of Epstein's former employees, he told them the same thihg. He and a private eye had,II1et_c1,t a.restaµrantdays ~adfer t9 go,oyer: what the m,a.n,wgu1dtell investigators. Detectives received complaints thaq,rivate eyes Were posing as polite officers. When they told Epstein's local attorney, Guy Fronstin, he said the investigators workedfor Roy Black, the high~powered,Mia.mi hrwyer who ha~ defended thel~es of Rush Limba.vgh.and Wilham Kennedy Smith. Whiie the _private ey:es were conducting a parallel iitvesti'&atioh,- Detshowitz, the Harvard law professor, travelea to West Palm Beath with information about the girls. From their own profiles on the popular Web site MySpace.com, he obtalned copies oftheir discussions about their use of alcohol and ma:rijuaha. He took his research fo a meeting with prosecutors in early 2006, -where he sou_ghtto cast doubt on th_e,teens' :reliabiljty. The. private eyes ha.dd:µg up en~::n1gh &rt on the gfrl,s to mcikeprosecut~Jr~ skepti~al.N_ot only oid some of the girls have issues with drugs or a:kohol but aJso s·ome .h:a:d. criminal records 'and other troubles, Epstein's legal team claimed. And.at least one ofthem,. they said, lied when she toJ<;l. poHge $he was younger th.an_ lSwhim she started_perforI11ing nias~ages forEpstein. After tlre meeting, prosecutors:postpQned their de.e:isjon to take.the_c~e to a grandjury:, CA/ Aron berg-00014 7 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3/27/2023 2:57:43 PM In the following weeks, police received complaints that two ofthe victims or their families had been harassed of threatened. Epstein's legal team maintains that its private’ investigators did nothing illegal or unethical during their research. i By then, relations between, police and.prosecutors were fraying. At a key meeting with prosecutors and the defense, Detective Joseph Recarey, the lead investigator, was a no-show, according to Epsteins attorney. "The embarrassment on the prosecutor's face was evident when the police officer never, showed up for the meeting,” attorneyJack Goldberger said. Later in April, Recarey walked into a prosecutor’s office at the state attorney’s office and learned the case was taking an unexpected turn. The prosecutor, Lanna Belohlavek, told Recarey the state attorney's office had offered Epstein a plea deal that would not require him to serve jail time or receive a felony conviction.; Recarey told her he disapproved of the plea offer. The deal never came to pass, however, Future unclear after charge On May 1, the department asked prosecutors to approve Warrants to arrest Epstein on four counts ofunlawful sexual activity with a minor and to charge his personal assistant, Sarah Kellen, now 27, for her alleged role in arranging.the visits. Police officials also wanted to charge Robson, the self-described Heidi Fleiss, with lewd and lascivious acts. By then, the, department was frustrated with the way the state attorney’s office had handled the case. On the same day the warrants were requested, Palm Beach Police ChiefMichael Reiter Wrote a letter to State Attorney Barry Krischer suggesting hedisqualifyhimselffromthe case if he would not act. Two weeks later, Recarey was told that prosecutors had decided once again to take the case to the grand jury. CA/Aronberq-000148 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY I I . .. . .. . I -• In the following weeks, police received,compfaints that two of the vic:tim;s or th~ir familie~ haJl beeii harassed bt threatened. Epstein's• legal team rrYaintains that its priyate· investigators did . . I _npt;l)._ing ,illegal or µ_nethical during their research. 1 I By th~n, r~fo.ti'ons betwe~JJ. police and. pro~ecutors were fraying; At a key meeting: with prosecutors and· the defense, Detective Joseph R.ecarey, the le_ad iny~stigatqr, w::1.s a,no·-~how, according to Epstein's attorney. "The elllbar.rassnient on the prosecutor's face was evident when the police officer never showed up for the Ill\:!eti11,g," a~orney J ~cl GoJpq~rg~r ~c11q. Later in April) Retarey wilked into a pro·se_cut_or's. office at the stt1.te. attorney'.s office and learned .the case was takfug· ah tmexpected turn. The prosecutor, Lanna Belohlavek, toldRecare:ythe .state attotney's office had offered Epstein a plea deal that_ would, _not requi.re:b.iw to serve jail time or receive ,a felony conviction., Recareytold her he disapproved of the plea offer:'.. On May 1 ! the department asked prosecutors to ap{>rove waYrahts to arrest Epstein on four co-qn.ts of.unlawful sexu;1l:aGtivity with ~ n;iil1,or-and to cp.arge his pers~mal assistant! Sarah Kellen, now 27, for her-allegedro'leih art::1.nging.thevisits. Polic:e offidals alsow,anted to charge Robson, the self:-desttibed Heidi Pleiss, •with.lewd and lascivious acts. By then, the. depar;qnent was fru~trated with the way the state attorney's office had haiialed the case. On th~ sa111._e day th~ warr,ants we.re. r~qµ~s_te.d1 Palm Be.ac:J1:PqJi_c~ C:hi_efivHchael Re1t€=r wrote a.letter to State Attorney'Barry Krischer suggesting he disqualify;himselt from the c_ase if h~ would n9t ai;:t. Two weeks later) Recarey wa_s. told that prose~4to_rshad decided once ~gain to take the case to the grand jury. CA/Ar0nbe.!:9c000148 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM It is not known how many of the girls testified before the; grand jury; But Epstein’s defense team said one girl Who Was subpoenaed - the one who said,she had sexual intercourse:with Epstein - never showed up. ' The grand jury’s indictment was handed down in July. It was not the one the police department had wanted. Jnstead ofbeing slapped with a charge ofunlawful sexual activity with a minor, Epstein was charged with one count of felony solicitation of prostitution, which carries a maximum penalty of five years inprison, He was booked into the Palm BeachCountyJail earlyJuly 23 and released hours later. Epstein’s legal team "doesn’t dispute that he had girls over for massages,” Goldberger said. But; he said their claims that they had sexual encounters with him lack credibility. “They are- incapable of being believed," he said, “They had criminal.records. They had accusations of theft made against them by their employers. There was evidence of drug use by ■some ofthem." What remains for Epstein is yet to be seen. The Palm Beach Police Department has asked the FBI to investigate the case. It also has returned the $90,000 Epstein donated-in 2004. In New York, candidates for governor and state attorney general have vowed to return a total of atleast $60)000 in campaign contributions from Epstein. Meanwhile, Epstein’s powerful friends have remained silent as tabloids and Internet blogs feast on the public details ofthe police investigation. Goldberger maintains Epstein’s innocence but says the legal team has riot ruled out a future plea deal. He insists Epstein will emerge in the end with his: reputation untarnished. "He will recover from this," he said. Staffwriter Larry. Keller and staff researchers Bridget Bulger, Angelica Cortez, AmyHanaway and Melanie Mend contributed id this'story. [email protected] CA/Aronberg-000149 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY His not known hoW:rn:<lny ofthe girls testiJieci bero:re the: grand jury. Bu~ Ep·stein's defense . I ·team said one gi:rl who was subpoenaed "' the on·e -who sai'd. she had sexual ihtettoutse with -- ., ! Epstein - never showed up. The gra,pdjury's iIJ.dictmentwas handed down inJuly. It was not the one, the police departmenthad wanted. Jnsteaci of:being siappedwith. a.charge .ofunlawful sexual activity with amfuor; Epstein was charged with cine count of felontsolicitatiori of prostitution, which cardes a maxim1up_ penalty 9ffiyE;! y~~rs in pdsol.).._ H~ wa_s bqok~d int9 the fal111 B,ec1c:h CoµntyJaiJ early July 23 and released ho\lrs_ iater. Epstein's legal team "do.es:n't dispute tliarhe had girls over for massages," Goldberger said. But he said their claims that they had sexual encounters witl). him l_ac.:k credibi_lity .. "Th_ey are, incapable of being :believed," he sa1d. "They had -criminal records. ihe_y had ,accusations of the.rt made :against them _bythei'r employers. There was evidence of drug u:se by -some ofthem." What:temainsfor Epstein is yet to be seen. The Palm Beach Police- D~partment has asked the FBJ to _1.nye,stigat~ _the qs.~. n aj_so has retu_rned the $90,000 Epstein donated-in 2004. In:NewYork, cartdidates for governor and state attorney general have vowe·dto teturn-a.tofal of at'least-$60;000 ih tampaigh contributions from.Epstein. Mean:while,Epstein1s powerful friends ha,_ve rer:µained si.lent as tabloid~ an_d In~er:n~t ]?logs f~;ist on t4~ public deta.ils of the police investigation. Goldberger maintains Epstein's innocence but says the· legal team has Iiot ruled out a future plea deal. He insists Epstein will emerge in the end with hfa repu:t~tion UM<!rnished. "H~ willr:ecover from thi~," he said. S.tciff writer Larry. Keller and s_taffresfarcber.s Bridge_t Bulger, Angelica Cortez,, Amy Hanaway and Melanie Mena contributed to tliis•stor_y. [email protected] ···--········-···· .. -· ...................... ---- CA/Aronberg_-000149 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM @AMarraPBPost CA/Aronberg-000150 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 27 2023 2:57:43 PM NOT A CERTIFIED COPY ; @AMarraPBPost CA/Aronbem-000150 FILEU: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 213 / 278 - Tuesday, November 16, 2004 ; Edition: FINAL Section: A SECTION Page: 1A Source: By PAUL 0WERS Palm Beach Post Staff Writer Illustration: PHOTO (C & 2 B&W) & MAP (B&W) Memo: Ran all editions. Dateline: WEST PALM BEACH TRUMP SNAGS GOSMAN ESTATE FOR $41 MILLION When it came time to:bid Monday for the palatial Palm Beach digs of Abe: Gosmah, The Donald was not about to be trumped. "Nobody was going to outbid me." the brash developer-turned-TV-personality said from his New York office. Trump bested two other bidders with a $41.35 million offer for the 43,000-square-foot, seven-bedroom estate on 6 oceanfront acres along the storied "Raider's Row." But Trump, 58, proud possessor of.Maf-a-Lago, has ho plans to live in the Gosman home at 513 N, County Road. He wants to - what else? - sell it and make more money. The star ofthe mega-hit The Apprentice said he intends to redevelop the site into a "super luxury house" that would be the "finest anywhere in the United States." He might build another, house before flipping the entire package. "I've known about this house for quite some time," Trump said. "It's probably the best piece of land in Florida - and probably the country - for luxury real estate." Although Trump said he could subdivide the property into nine lots, Palm.Beach Mayor Lesly Smith said zoning regulations allow for only two houses - and maybe a third. Smith said she's not worried about Trump's plans. "He's been a very good property owner in the town of Palm Beach," she said. "He does his projects very, well. He's: a perfectionist." Monday's auction took place at U.S. Bankruptcy Court in West Palm Beach as part of Gosman's Chapter 7 bankruptcy case. Proceeds from the sale will go into escrow for eventual distribution to creditors. The auction began at exactly .noon after Judge Steven Friedman dismissed an objection from an attorney representing money manager. Jeffrey Epstein. The lawyer argued unsuccessfully that Trump was not a qualified bidder because his contract stipulated that he would not close on the sale unless title insurance was in place beforehand. With Trump listening via conference call, Epstein began the bidding at $37.25 million - $250,000 higher than Trump's initial offer. Mark Pulte, son ofthe founder of home-building giant Pulte Homes, passed when his turn came, letting lawyers for Trump and Esptein bid against each other until the price hit $38.85 million. Pulte then bid $3,9.1 million, briefly raising the ire of Trump, who believed that Pulte had given up his right to bid by passing the first time. CA/Aronberq-000151 FILET): PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY 27.3 /278 - Tuesday, November 16, 2004 Edition: FINAL Section: A SBOTION; Page: lA Source: By PAUL OWERS P-l'J.lm BeachPost_·StaffWrit~r IllustratiotE PHOTO (C -& 2 B&W} & MAP (B&W) .M~_rnq: Ran "~ll eclition,s, Dateline, WEST PALM BEACH TRUMP· SNAGS GOSMAN ESTATE FOR $41 :MILLION When it came. time fo, bid Monday for the palatial Palm. Beacfi digs of Abe Gosman, The Donald was npt a,bout to be trumped·. • • • "Nobody was going to outbid me," the brash developer-tu:rrted-TV-petsohality said from his New York of:fic~. • Trump bested two other bidders with a $41.35 million offer fodhe 43,000-'square-foot, sev~n.:bedroom estate on 6 oceanfront acres aiong the storfod "Raider's Row.'' But Trump, 5 8, proud possessor" of.Mat-a-Lago; has ho pla·ns to live in the Gosman home at 513. N. County Road. Jfo wants to - what eise? - s~Ii it and make more money, The star of the mega"'hit The Apprentice. said he intends to redevelop the site into a "super lllX,lffY hpµs(t j:hl'j.tw9µlcl_ be the "finestanyWber~ in the Unit~d States." He might build another.ho-use before flipping the entire package. ·••r•ve known about this'ho_use for quite s_ome tiine," Trump said. "It's probably the best piece of land in Florida "' and probably the cohhtcy - for .luxury real estate:" AJthpt1gh Trµmp sJ1_icl h~ cotilci suJJ.diy1cl_e the property into nine lots, Paim. Beach Mayor Lesly'Smith saidzon:ing regulations allow for only.two houses - and maybe a third. Smith .s~i.d she's no.t worrie4 about ·trump's ·plans. • "He's been a very good property ownet in the town of Palm Beach," she said. "He does his projects very wdl,}I~_•sia, perfectiOlifot'' Monday's auction took plate at U.S. Rahk.r-uptcy Court in West Palin Beach a~ part of Gosman;s Chapter 7 bankruptcy case. Proceeds from the: sale wlll go into escrow for eventual distribution to creditors, The ~µction·began at exactly_noorrafter Judge SteyenFrie.dman dismissed.an objection from ari attorney representing inohey manager.Jeffrey Epstein. The fawyer a_rgued unsu<;:ces~fully th,!t 'frµmp was not a' qualified bidder because his contract stipulated that he Would :n:ot close on the sale unless title insutimce was in place, beforehanc;i. With.Trµmp Itstenfng vi.a conference· c.all, Epstein began· the-bidding -at $3 7.25 m'illion - $250,0'00 higher than Truinp;s initial offer. Mark Pulte; son of the founder of home-'building giant .Pulte Homes, passed when his turn tame, letting lawyers for Trump a,nc;iBsptein bid against ea~h other u11til' tbepnce hit $38._85 m"illion·. • • • Pulte theti bid $"]9. l million, briefly raisjngthe i_re of Trump, who ,believed that:Pi.ilt~ ha,d given _up his right to bid.by passing the, first time. CNAronbe__m-000151 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM But Friedman allowed the offer to stand, and Pulte and Trump went back and forth until Pulte dropped out at $41.1 million. Epstein, a part-time Palm Beach resident, bowed out at $38.6 million. ; Friedman closed the bidding .10 minutes after it started, leaving Trump with the right to buy the 29.000-square-foot home (a typical Palm Beach County single-family house is about 2,200 square feet). The property also has a tennis house, a pool house and 1930s-era service quarters. ; The closing could take place within a week but probably won't happen until next month. Trustee Joe Luzinski and creditors said they were pleased with the outcome. "We knew we were dealing with some substantial people .. . who were going to bid it up a bit," Luzinski said. "The system worked," said Charles Tatelbaum, a lawyer for creditor JPMorgan Chase Bank. "In bankruptcy court, the idea is to get the most for creditors, and that's what happened." The auction proved to be a bonanza for creditors, Luzinski said, noting that the highest offer former listing agent Sotheby's International Realty received was $32 million. Sotheby's won't receive a commission, he said. Pulte,. 42, of Boca Raton, said he figured Trump wouldn't back down Monday. "I got the' feeling he was willing to go a lot higher, and I didn't want to chase it,” Pulte said. Pulte sajd Gosman asked him before the auction whether he would be willing to let him stay in the mansion after the closing until he decides where he wants to move. Trump and Luzinski said they have had no such discussions with Gosman. Gosman, 75, had the house built after paying $12.1 million for the land in 1986. T he former health-care magnate declined interview requests before and after the auction Monday. He was at the courthouse but left before the auction took place.. The $41.35 million price tag eclipses the $30.35 million sale of Lowell "Bud" Paxson's Palm Beach home and guest house but’falls short ofthe $45 million that Virginia home builder Dwight Schar paid for Ron Perelman’s 26.000-squarc-foot estate, Casa Apava. a designated landmark. Schar also paid $ 18.6 million for a lakefront lot across the street from the main house, for a total of $63.6 million. Insiders say Schar spent a total Of $70 million for his.hew property, making it the priciest residential sale in U.S. history, Gosman once had a fortune that Forbes magazine estimated at $480 million. He voluntarily filed for Chapter 11 bankruptcy protection in 2001, listing assets of $250 million and ■liabilities of $233.6 million. When a judge ruled that Gosman had to give up all of his exempt assets to creditors if he wanted to reorganize under Chapter 11, Gosman converted the case to Chapter 7 liquidation. Last year, U.S. Bankruptcy Judge Larry Lessen.ruled that Abe and Lin Gosman's marriage is invalid because Florida law does not recognize a Dominican Republic, divorce,that Lin Gosman tried to obtain from another man, Michael Castre. The judge's decision was a huge victory for creditors because it prevents Abe Gosman from protecting assets by claiming joint ownership with his wife. Gosman's assets, which include an extensive collection of artwork, could total as much as $70 million and will be soldlater. Without Lessen's ruling, Luzinski wouldhave had a much harder time selling Gosman's estate, said David.Cimo, special counsel for the trustee. "We would have been thwarted . . . or at least substantially impaired," Cimo said. i I i CA/Aronberq-000152 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY I I I I I . . .. .. . . ·.. . . .. i ·. .... . But Fnedman allowed the offer to sta,nd, and :Pulte and 1'rt.1II1p w~nt bacl{ anc;l forth u.nt1l Pulte dropped out at $41.1 million. Epsfoin,a part.,.time Palm Beach resident; bowed out at $38.6 million. Frkclmarr dosed the bidding JO minutes after it started, leaving Trump with Jhe,rightto buy . . , -· ·- . I .. . . the 29 ,000-squarec:foofhome, ( a ·typical Palm Beach Cou11ty single~ family house is about ·2,200 square feet} The property also has a tennis house; a,pool house and 1930s-era service quarters. , The dosing c:o.uld take place within a week but probably won't happen until next month. Trustee foe. Luzinski and cn;ditors' said tbey were pleaseci with: the outcome. "We knew we were dealing with some substantial people, .. who were going to bid it up a bit,"·Luzinski said. ·• • "The system worked," said Charles Tatelbaum;. a la.Wyer for creditor JPMorgan Chas·e Bank. "In bankruptcy court, the idea is to get the- rnost for creditors, apci that's what happen.ed. ;, The auction pro.v.e·ct to be a bonanza for creditors, Luzinski said, noting that the high·est offer foITI1er listing agent Sotheby's fotemc1ti.on;:1l Real.ty received was $).2 IIliUion,. 8qtheby's won't receive a commission, he said. Pulte,. 42, oJJ3oca Raton, said J1e Jigi;ired Trump woiJldn't bac,k down Monday. "I gottne·Jeeling he was willing to go a: lot higher, and I didn't want to chase if,11 Pulte said. PµJte said OosJn® q3ked him•be,fo,rethe, _auctfon whether hewo:µip.he w{lli.Dg to leJ him:.stay in the mansion after the closing until he de.tides where he wants to move. Trump ahd Luzinski said they have had no such discµssions with Gosn1c1n. Gosman, 75, had the house built after paying.$12.l m:illion:fot the. la:ndih 1986. Tlw f9nner health-p:irn magnate, de~lined inte,rview re,qµests be:fore and afte,r the auctiQn Monday. He was at the courthouse but left before the auction .took place .. The $41.3 5·m.illion price tag eclipses the $30 .3 5 niilfom s.ale of Lowell ''Bud:'' Pax.son's Palm Beach home and guest house but falls short ofthe $45. million that Virginia home builder Dwight Scharpaid for Ron Perelman's 26,00Q-sqllare-foot estate, CasaApava, a designated landmark. §~han1lso paicl $ l8·.6 million for a lalce,front lot aci;qss the stre,e,t fron,1 tbe mai1:r house, for a .total of$63 .6 million. Insiders say Schat spent a total of $70 million for his, new property, making it the prkiest residentiiil sale in tfs. history, • Gosman once had a fortune that Forbes magazine· estimated at $480 millioi1. He·voluntarily filed, for 8hapter 11 bankr1Jptcy protection iIJ2Q0l, listing 8$Sets of $250 million and ·liabilities c5f $233.6 million. \,Vhen a ju<ig~ ruied' that dosmanhad to give llp all ofhis exempt assets to creditors if he wanted to reorganize under Chapter l l , Gosman cotrverted the case to Chapter 7 liquidation. Lc1st year; VS;Bankrllptcy Jµdge Larry Lessen.r.ul~d that Abe and Lin Gosman's marriage is: invalid because Florida Ia:w·does .not .recognize a Dominican Republic. di'@rce that Lin Gosman tried to obtain from another man,' Michael Castre. • The.judge's decision was. a huge victory for creditors because it prevents Abe Gosman from protecting assets by claimingjoint ownership: with his wife. Gosmart's a:s'setsf which include an extensive collection of art\V6rk, ·could total as much as $70 million and will be sold' later. Without Lessen's ruling, Luzinski would, have had a.much harder time. ·s~lling Gosman'-s estate, said David. Cimq, special counsel for the trustee. "We would have been thwarte.d .· .. or at least substantially impaired;" Cimo said. CA/Aronberg-000152 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3/27/2023 2:57:43 PM The trustee alleged during a weeklong trial in May that Gosman fraudulently gave his,wife an ownership interest in-his home and other belongings only to avoid losing them in bankruptcy. Gosman has denied any wrongdoing, saying he made the property transfers in 1999, well before he.filed for bankruptcy,. Lessen is expected to rule in the next two months whether Gosman made improper transfers, a decision that,will affect how much money will be available to creditors. Cimo acknowledged that Monday wasn't the best of days for the Gosmaris but said they were willingto moye forward, in part because the upkeep ofthe estate now exceeds their means, "This is not a happy occasion, for them, but at least we're moving to the next level," Cimo said. "That's not a house you want to live in unless you're making large amounts of money like Donald Trump." [email protected] CA/Aronbercb000153 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY I i The trustee .alleged during .a weeklong; trial in May that Gos111an: fraudul~rttly gave his wife an ownership interest in.his bo1ne and otby~ belongings only to avoid l9s 1ing th~m in bankruptcy. Gosman has denied any wrongdoing;; sayirtg he 'made: the :property transfers in 1999, w.elJ before.h,efjled{o1: banlp-µptcy,_ Lessen is expected to rule in the next two. months whether Gosman mad¢ improper transfers, a deci~ion that will c1ffect bow much mcmey will be ava,ilahle to creditors. Cimo acknowle.dged that Monday wasn't the b,est of days for the Gosmaris but. said they were wiJling to ,rn9ye for.ward, ip part ]J.ecal,lse the lJpkeep of the estate-now -~x..c~~~rs their ITiean.s, "This:is.not a happy ·occasibn. for them, b:ut atleast. we're moving to the riext level," Cimo .s.cUd. ,;That's n_ot a hous~ you want to· live in µ11less you're making large i,im,ounts of money like Donald Trump." paul [email protected] CA/Aronben1-000153 · FILEU: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 11/11/2019 indictment: Billionaire Solicited 3 Times - News - the. Palm Beach Post - West Palm Beach, FL The Palm Beach Post ~. ■” '■—... “ ■ ■n.- - Indictment: Billionaire Solicited 3 Times Posted Jul 1,2008 at 12:01 AM I Updated Oct 2,2019 at 2:30 PM i (EDITOR’S NOTE: This story originally published in The. Palm Beach Post onJuly 25, 2006) Billionaire money manager and Palm Beach part-time residentJeffrey Epstein solicited or procured prostitutes three or more times: between Aug. 1 and Oct. 31 of last year, according to an indictment charging him with felony solicitation of prostitution. Epstein, 53, was booked at the Palm Beach County jail at 1:45 a.m. Sunday. He was released on S3,000 bond. Epstein’s case is unusual in that suspected prostitution johris are usually charged with a misdemeanor, and even a felony charge is typically made in a criminal information - an alternative to an indictment charging a person with the commission of a crime. His attorney,Jack Goldberger, declined to discuss the charge. State attorney s office spokesman Mike Edmondson also had little to say. "Generally speaking, there is a case that has a number of different aspects to it," Edmondson said of a charge being submitted to a grand jury. “We first became aware of the case months ago by Palm Beach police.” Prosecutors and police worked together to bring the case to the grand jury, he said. I I i https://www.palmbeachpost.eom/news/2068070l/indictment-billionaireTSOlicited-3-times ] 1/2 CA/Aronbera-000154 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY 11h112o'i s ·r· ! ' Indictment: Bi 1Hio.naire Solicited 3. Times PQl>Jed J.uJ 1, 2008 at 12:Q1 AM Updated Oct 2, 2019 ·at:2:·30 PM (ED!TQIJ 'S N.QTE: This storyorigi11ally py~[isheq, iti-' The Palm Bead! Post,on]uly25, 2006) Billionaire money manager and Balm Beach part-time resident Jeffrey Epstein solidted or pr.ocured prostitutes three or more times between Aug; 1 and Oct. 31 of fa,st yea_r, according to an indictment charging him with_ felony solicitation 9f prostitution. Epsteh1, 53,·was booked at the P.aJm:13eaph_(;ountyjail at 1:45a.m. Sunday.Jie was releas.ed.on $3,000 bond. Epstein's case is tiilusuaUn that suspected prostitution johns· are usually charged with a misdemeanor,. and even a felony charge is: typically made ifi a criminal ir1foIJI1atiop. - an aJtemative tq ap indictment charging a person with the q:immission 9f a criJne. His ·at.torney, Jack Gol.dber.ger, dec:lined to dhcuss the char_ge_t State attQrney's office spokesman Mike Edroonclson also h:icl little to s:,iy,j "Generally spealcing, th~re is a c_ase. th.at has a :gµmber qf q.fffrrent a.specJs to lt," Edmondson. said of a prostitution-related charge being submitted to a grand jury. "We first became a:wate of the case months· ago by Palm Beach police." Prosecutors and police worked together to bring the case to the grand jury, he ~aid. https:/fvN.lw.palmbeachpost:com/news/20080701/indictmentsbillionaire,solicifed-3'1imes CA/Aronberg_-000154 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 1/2 • -11/11/2019 t Indictment;Billionaire.Solicited 3 Times.7 News:- The Palm Beach Post West Palm.Beach, FL. i I i I I i Palm Beach police confirmed that and-said the department will release a report today regarding its investigation. Epstein has owned a five-bedroom, 7 1/2-bath, 7,234-square-foot home with a pool and a boat dock oh the Intracoastal Waterway since 1990, according to property records. A man answering the door there Monday said that Epstein, wasn’t home. A Cadillac Escalade registered to him was parked in the driveway, which is flanked by two massive gargoyles. Epstein sued Property Appraiser Gary Nikplits in 2001, contending that the assessment of his home exceeded its. fair market value. He dismissed his lawsuit in December 2002. A profile of Epstein in VanityFair magazine said he owns what are believed to be the largest private homes in Manhattan - 51,000 square feet -and in New Mexico - a 7,500-acre ranch. Those are in addition.to his 70-acre island in the U.S. Virgin. Islands and fleet of aircraft. Epstein’s friends and admirers, according to the magazine, include prominent, businessmen, academics and. scientists and famed Harvard law professor Alan. Dershowitz. larry [email protected] i https://www.paimbeachppst.eom/news/20080701/indictment-biiiionaire-soiicited-3-times i 2/2; CA/Aronberg-000155 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY • -11/11/201,9 I ! I I lr:idJctrnent: .Billion~ire.SoliciJed ~ Tirnes ." News - The paJm Beach Ppst" \(Vest Palin.Beach, .FL Palm Beach polic~ confirmed that and.said ·the department will release a report today :r~garding •its investigation. Ep·steih has owned a five..:.b_edrootn, 7 l/2,..hath, 7,234-square-toot:home with a pool artd a bcfat dock o'ii-thelntracoastal Waterway since 1990, actotdingto property records. A man answering the door there Monday said that Epstein wa,sri't home .. A CaMJ.a~ Escaj.,!d~ r~gi.st~i::~d to hi.m was pai:.k..ecJ i11- the cl.r:i'vewc1y, which is flan,k~d RY twC> ma.ssj've g~rgoyi~s, Epst.~~11' s_µecl l~rnp~rty Apprab~r Ga.ry Niko lits in 2001 r contendi.p.g that th~ assessment' ofhis· home e:x:c~~ded its. fa,ir .market valµe, H~ dlsmissec:l his law~uit in December 2002. A profile• of Epstein in V anity•F~iir magazine said he owns what are· believe·d to bethe largest private homes in Manhattan - 51,000 square feet - aridirtNew M~xico - a 7,5O0-acreranch. Those arein addition.to his70-acre island iffthe U.S. Virgin Islands and fleet ofafrcn1ft. Epstein's fri~;nds and c1dmir~rs, accord{ng to tile in3:gaziile, include promi.ne;nt businessmen, ac:a<iemics and scientis.ts and fam~ci H::u:vard law·pro'fes,sor Alan Dershowitz. h ttps :/ /WVffl. pa lmbe a chp9s t. co.rntn ews/20080_7 O 1 lind ictme n 1-bil Uo11a ire-so licited-3-tirnes. CA/Aronbem-000155 FILEU: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 2/2 11/11/2019 After long probe, billionaire faces solicitation charge - News - TheiPalm Beach Post - West Palm Beach, FL The Palm Beach Post REALNEWSSTARTSHERE : After longprobe, billionaire faces solicitation charge Posted Jul 27,2006 at 12:01 AM Updated Oct 3,2019 at 3:11 PM (EDITOR’S NOTE: This story originally published in The Palm Beach Post on July 26, 2006) Palm: Beach billionaire'Jeffrey Epstein,paid to have underage girls and young women brought to his home, where he received massages and sometimes sex, according to an investigation by the Palm Beach Police Department. Palm Beach police spent months sifting through Epstein’s trash and watching his. 'waterfront home and Palm Beach International Airport to keep tabs oh his private jet. An indictment charging Epstein, 53, was unsealed Monday, charging him with one count of felony solicitation ofprostitution, Palm Beach police thought there was probable cause to charge Epstein with unlawful sex acts with a minor and lewd and lascivious molestation. Police Chief Michael Reiter was so angry with State Attorney Barry Krischer s handling ofthe case that he wrote a memo suggesting the county’s top prosecutor disqualify himself. “I must urge you to examine the unusual course that your office’s handling ofthis matter has taken and consider if good and sufficient reason exists to require your disqualification from the prosecution ofthese cases,” Reiter wrote in a May 1 memo to Krischer. While not commenting specifically on the Epstein case,.Mike Edmondson, spokesman for the state attorney,, said his office presents: cases other than murders to a grand jury when there are questions about witnesses’ credibility arid their ability to testify. https://www.palmbeachpost.com/news/20060727/after-long-probe-billionaire-faces-solicitation-charge 1/5 CA/Aronberg-000156 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY \:. 11/11/2019 After long_ probe, billionaire faces solicitation'.charge - News - The:Palm Beach Post - West Palm Beach, FL After l;ong probe, biJlio11aire faces solicitation charge Posted Juf 27,2006 at 12:ot AM Updated Oc;t:~, 201. 9 at:3J 1 PM (EDITOR'S NOTE: This story originally publishea in The Palm Beach Post o·n Jidy 26, 2006) Pa:lm: Beach billion:aireJeffrey Epstein_paid to have underage girls and young women brought to. his home,where heteceived. :massages and sometimes sex, according to .ari investigation by tlie Palm Beach Police Department. Palm Beach polite spent months sifting· through· Epsteiifs trash and watching .his. Waterfront home, and Palm Beath. International Airport to keep tabs on his private jet. An indictment charging Epstein, 53, was unsealed Monday, charging him with one c.o~rit qf felc,my s9µci~tio11- ofpr9stitution, Palm Beach pofo:e tho:ught there was prob?ble ~a use to charge Epstein with 'unlawful sex acts with a minor and' lewd,an:d.iasciyiousmolestation. Police Chief Mich~el R,eiter·was s.o angry with State Attorney Barry 'Kris\;:her's ha·ndling.of the case-that he. wro.te a meino suggesting .the county's top ptosecutot disqualify himself. "Jmµsturge you to examine the unusual coursethatyour office's handling ofthis lllatter h~s t~ken ~n.d. COll~rc;ier: 'if good arr.q sufficient rec1.~on ~xists to :require yo:ur disqualifica.tion from the prosecutfon of these cases," Reiter wrote in: a May 1 memo to Krischer: While n·ot commenting specifi.Gaily on the :Epst_ein case,. Mike Eciroo.ndso:n, spokesman for the state attorney,. Said his office presents: cases oth~r than murders to a grandjury when there are questions about witnesses1 credibility arid their ability tq. testify. hitps://W\11W.palmbeachpost.com/news/20060727/after-long-probe-billionaire0facescsoliciiaiion'-Charge- CA/ Aronberg-000156 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 1/5 11/11/2019 After long probe, billionaire faces solicitation charge.<News - The Palm Beach Fjbstjr West Pairri Beach, FL j By the nature of their jobs, police officers look at evidence from a ‘ one-sided perspective,” Edmondson said. “A prosecutor has to look at it in a much broader fashion,” weighing the veracity ofwitnesses; and how they may fare under defense attorneys’ questioning, he said. Epstein’s attorney, Jack Goldberger, said his client committed no crimes. “The reports and statements in question refer to false accusations that were not charged because the Palm Beach County state attorney questioned the credibility of the witnesses,” Goldberger said. A county grand jury “found the allegations wholly unsubstantiated and not credible,” and that’s why his client was not charged with sexual activity with minors, he said. Goldberger said Epstein passed a lie detector test administered by a reputable polygraph examiner in which he said he did not know the girls Were minors. Also, a search warrant served on Epstein's home found.no evidence to corroborate the girls’ allegations, Goldberger said. According to police documents: - A Palm BeachCommunity College student said she gave Epstein a massage in the nude, then brought him six girls, ages 14 to 16, for massage and sex-tinged sessions at his. home, - A 27-year-old woman who worked as Epstein's personal assistant also facilitated the liaisons, phoning the PBCC student to arrange for girls when Epstein was coming to town. And she escorted the girls upstairs when they arrived, putting fresh sheets on a massage table and placing massage oils nearby. - Police took sworn statements from five alleged victims and 17 witnesses. They contend that on three occasions, Epstein had sexwith the girls. A money manager for the ultra-rich, Epstein was named one of New York’s most eligible bachelors in 2003 by The New York Post. He reportedly hobnobs with the likes of former President Clinton, former Harvard University President Lawrence Summers and Donald Trump, and;has;lavish homes in Manhattan, New Mexico and the Virgin Islands. i i i https://www.palmbeachpoia,corn/iipw^2006072'^ ! CA/Aronberg-000157 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 27 2023 2:57:43 PM 2/5 NOT A CERTIFIED COPY 11/11/2019 I I After long probe, billionaire faces solicitation charge." News 0• The Palm Beach Fjbst\ West Palm Beach, FL I . . I . By the nature of thefr jobs, police officers look at .evidence from a j" one• .. sided perspective," Edmondson said. "A prosecutor has to look a:t it in a !much broader fashfon,"'weighingthe veracity ofwitnesses• and how they may fa~e under defense at:tg.rneys' questioni:ng, he said. • Epstein's attQrney,Jack Goldberger, sai'd his client cqmrnitted no crimes. "The reports and sta,teme11ts 1.n question :refer to false a,ccusations that: were: not cha,~ged because the Palm Be:ich County sta,te attprney qugsJioned the <credibility of the witnesses/' Geldbei;get said,: A county grand jury ''fo\fnd the ·allegations wholly unsubstantiated and not credible/' and that's why his clientwas not charg_ed with sexual acfrvi.tywith mi'nors, he said. Coldberger said, Epstein pgssecl a lie·dete<:t:pr t:e.s.t :1d111inistered by a reput:aple polygtaph examiner in which he said he did not know the girls Wete minors. Also,: a search warrantserved on Epsteirfs home found.no evidence to corroborate the girls' allegations, Goldberger said. According to polite documents, - A P·alrri Beac:h,Communify College student said she gave E,psteina massage in. the nude, then brought him six girls, ages 14 to 16, for massage and sex,-tinged scissio11s aJ his. horn~, -A 27-year'-oldwoman wh9 worked as Epstein's personal assistant also facilft_ated the 1iaiso_ns1 _phoning .the PBCC st,uder1ttp ·an::ange_-for girls when Epstein_ was corning t.o tow:rL A11d She esc:orted. the gfrls upstairs when they arriVe'<l, putting fresh sheets on a massage table and placing massage oils n·earby. - Police took sworn statements from five alleged Victims and 1 t witnesses, They contend that o.n three _occasions, Epstein had sex with the girls. A money manager for the ultra-:rich, Epstein was named one ofNew York's most eligibl,~ pachel9rs in 2,003 by The N~w:York Post, Be rep9rte_qly ho.bJJ9ps witl:i the likes of former Pr~siden:t Clinton, former Harvard P niversity :Presid'ent Lawrence Sunmiers andDonald Trump, andhas;lavish homes in Manhattan, I New Mexico and the; Viti:;in Islands. CA/Aronberg~000157 . FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 2i5 11/11/2019 After long probe, billionaire faces solicitation charge'- News - The Palm Beach Post - West Palm Beach, FL He has contributed tens of thousands of dollars to Democratic Party candidates and organizations, including Sen. John Kerry’s presidential bid, and the Senate campaigns ofJoe. Lieberman, Hillary Clinton, Christopher Dodd and Charles Schumer. Goldberger is one of five attorneys Epstein has retained since he became the subject of an investigation, Edmondson said. Among the others: Alan Dershowitz, the well-known Harvard law professor and author, who is a friend of Epstein. Dershowitz could not be reached for comment. Police said the woman who enlisted young girls for Epstein was Haley Robson, 20, of Royal Palm Beach. Robson has worked at an Olive Garden restaurant in Wellington and said she was a journalism major at Palm Beach Community College when she was questioned by police last October. She has ail unlisted phone number and could not be reached for comment. Robson said she met Epstein when, at age 17, a friend askedher if she would, like to make; money giving him a massage. She said she was driven to his five- bedroom, 7 1/2-bath home on the Ihtracoastal Waterway^ then escorted upstairs to a bedroom with a massage, table and oils. Epstein and Robson were both naked during the massage, she said, but when he grabbed her buttocks, she said she didn’t want to be touched. https://wvjvApalmbeachpost.com/news/20060727/after-long-probe-billionaire-faces-solicitation-charge CA/Aronberg-000158 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 3/5 NOT A CERTIFIED COPY 11/11/2019 After long probe, b-illionaire:faces solicitation ·cliarge'- News - The Palm Beach Post - West Palm Beach, FL He hc,1s contributed teI_ls ofthousc,1nds o(do1iars to Democratic- Pa;ty rnndidates I arid otga11izations1 induding Sen. John Kerry's presidential bid, a1d the Senate campaigns of Joe, Lieberman, Hillary Clinton, Christopher Dodd ~n:d Charles Schumer. Goldberger is one of five attorneys Epstein has retained since he became the subject 9fan investig<1.tion 1 Edmond~on.said. Among the.others: Alan Dershowitz,_ t_he wefl-known Harv::ird Jaw professor and aµthor_, who is a friend ·o(Epstein. Dershowitz couid not be reached for comment. Police said the woma_n who enlisteq.· young girls for Epstein wa~ Haley Robson, 20, of Royal Palm Beach. Robson has worked at an Olive Garden restaurant in Wellingto-r1. and said she wa:s a journalism rtfajor at Palm Be·ach Com.mun:ity Colle~e ·when: she was guestioned by polite last October. She .ha:s ab.. unlisted phone number and could not be reached for comment. Robson saicf she met Epstein when, ·at age 11, P. fr1errd asked her if ~he woulc;Uike to, make money giving him a massage. She said she was driven to his five- bedtdom, 7 l /2-bath home· on the In ttatoastal Waterway; then _es cotted upstairs to ahedtoorh with a massage table and oils. Epstein and Robson were both naked dt;1ring the r:nas~<!ge, ~he sa,id, but when he grabbed her b1.1ttocks, sh~ said she didn't wa_n't_ to b~ t_ouched. htips://www.paimbeachposi.com/news/20060727iafter-iong-probe-billionaire-facescsolicitation,charge· CA/Aronbem-000158 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 3/5 11/11/2019 After long probe, billionaire faces solicitation charge - News- The Palm Beach Post r West Palm Beach, FL Epstein said he’d pay her to bring him more girls - the younger the better, Robson told police. When she tried once to bring a 23-year,-old woman to him, Epstein said she was too old, Robson said. Robson, who has not been charged in the case, said she eventually brought six girls to Epstein who were paid $200 each time, Robson, said; “I’m like a Heidi Fleiss,” police quoted her as saying. The girls knew what to expect:when they were taken to Epstein’s home, Robson said. Give a massage - maybehaked - and allow some touching. One 14-year-old girl Robson took to meet Epstein led police to start the investigation ofhim in March 2005. A relative ofthe girl called to say she thought the child had recently engaged in sex with a Palm Beach man. The girl then got into a fight with a classmate who accused her of being a prostitute, and she couldn’t explain why she had $300 in her purse. The .girl gave police this account ofher meeting with Epstein: She accompanied Robson and a second girl to Epstein’s house on a Sunday in February 2005. Once there, a woman she thought was Epstein’s assistant told the girl to follow her upstairs to a room featuring a mural ofa naked woman, several photographs ofnaked women on a shelf, a hot pink and green sofa and. a massage table. She stripped to her bra and panties and gave him a massage. Epstein gave the 14-year-old $300 and.she and the other girls left, she said. She said Robson told her that Epstein paid her $200 that day. Other girls, told similar stories. In most accounts, Epstein’s personal assistant at the time, Sarah Kellen, now 27, escorted the girls to Epstein's bedroom. Kellen, whose most recent known address is in North Carolina, has not been charged in the case. Palm Beach police often conducted surveillance of Epstein’s home) and at Palm Beach International Airport to see ifhis private jet was there, so they would know when he was in town. Police also arranged repeatedly-to receive his trash https://www.palmbeachpost.com/news/20060727/after-long-probe-bi1lionaire-faces-solicitation-charge 4/5 CA/Aronberg-000159 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY 11/11/201_9_ After long probe,:bHlionaire fi;ices solicit~tiori charge - N!;!WS; Ther~alm Beach Ppslas West Pali:ri Beac::h, FL E'.psteip ~aid he'd pay her to bring him mote girls - the youilget,the better; R,.9bson t9l9 .police, When she tried once to bring a 23'-'year.-old w.oman to him, Epstein said she was too olcl., Robson Sc;lid. Robson, who has;not been charged in the case, s_clid she eventually broughfsix girls to Epstein who. were paid $200 each time, Robson. said, ''I'm like a Heidi Heiss;" police quoted her as saying. The girls]mew whano expecnvhen they were t~e.IJ. to Epstein's home, Robson said. G1ve a massage - maybe:haked -, and allow spme tquc:b1ng, O:rie t4-ye;ir-old girl Rob$on took to meet-Epste1ii led polite to start the investig<!tipn ofhhn jn M.i,rc:;h'.20Q5, A rela_ti:ve qftlie girJ c;iHec;I t_o s?,y s}:ie thought the' child ha:d recently engagedin_sex with ·a Pilm Be.a.ch man. The girl then. got into a fight With· .a: classmate who accus:ed her of being a pmstitute,. and she couldn't exp fain why she had $300 in her purse. The,gir:l_ g;iye.police this account of her meeting with Epstein: She accompanied Robson and a second' girl to Epstein's house .on a Sunday in Februc1.ry· 2005. Qn,ce-there, a woman she thought was Epstei'n's assistant told the girl. to follow her µpstair~ to a roQ~ featll_r:iI1g .i,_ mur~ of .i, 11a~ed w.oman, several photographs of naked worn:en ·on a she_lr,. a hot pirik and green sofa and:;i m_ass_age table. She stripped to her bra: and panties ·and gave him a massage: Epstein gave the 14-year-old $300 and.she and the: other .girls left; she said. She said Robson told her that Epstein paid her $200·that day ():ther girls.told similar sto:des. In most accounts, Epstein's personal assistant at the time, Sarah Kellen, now 2-7, escorted the girls to Epstein's bedroo:rn. Kellen, whose most recent known_ ad4r~ss ·is fo Nortl;i Ca,rolin_a, .h?.s :Q.Ot been _Gharged in. the case. Palm Beach-police often conducted surveillance of Epstein's home; and ·at Palm Beach International Airport.to see if his private jet \vas tliete; -s0-they would l<,11ow when he was in town. Police-also arranged repeatedlfto retei've his trash https://www,palmbeachpostcom/news/200.60727/afler-long-probe'-l)illic>naire-faces-soljc~a_tion,-c!i.irge CA/Aronbe_m_-000159 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 4/__5 11/11/2019 After long probe, billionaire faces solicitation charge- News - The Palm Beach Post - West Palm Beach, FL from Palm Beach sanitation workers, collecting papers with names and phone numbers, sex toys and female hygiene products. One note stated that a female could not come over at 7 p.m. because ofsoccer. Another said a girl had to work Sunday - "Monday after school?” And still another note contained the work hours of a girl, saying she leaves school at 11:30 a.m. and would come over the next day at 10:30 a.m. Only three months before the police department probe began, Epstein donated $90,000 to the department for the purchase of a firearms simulator, said Jane Struder, town finance director. The purchase was. never made.. The money was returned to Epstein on Monday, she-said. https://www.palmbeachpost.com/news/20060727/after-long-probe-billionaire-faces-solicitation-charge 5/5 CA/Aronberg-000160 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY 11/11i2019 " After long probe, billionaire faces solicitation charge - liiews - The Palm Beach Post - West Palm Beach, FL from Palm B¢ac:h ?ariitc1,tiozy w9rkers, collectipg papers with nc11n~~ a_nd p_hone 'numbers, s_ex toys a11d %m~l~ ·hygiene produc:ts. One note stated that a female could not cpmeoverat 7 p.ni. becau,se ots_occer. Another said a girl had to work Sunday - ,;Monday after school?" And still another note contained the workhours ofa girl, saying she lea.ves: school at 11:30 c1.m. and would come over the next day at 10:30 a,m. Only three months before the. police ·departrneht probe began, Epstein donated $90~000 tp the depa_rtnu~nt for the 0purchase of a fireafl1ls s_imµla.tor:, saidJane $trud~r, town fina_n<:~ di_r~c:t9ri J:he purQhase wc1.s JJ~Y~r ma_de. Th~ money was r_eturned to Epstein on Monday, she· said. https:/twww.palmbeachpost.com/news/20060727/after-long-probe-billionaire-faces-solicitation°.charg_e CA/Aronberg~000160 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 5/5 11/11/2019 Police say lawyer tried to discredit teenage girls - News - Palm Beach Daily News - Pajrn Beach, FL Palm Beach DailyNews Police say lawyer tried to discredit teenage girls Posted Jul 29, 2006 at 12:01 AM Updated Oct 3, 20.19 at 2:00 PM (EDITOR’S NOTE: This story originally was published in The Palm Beadi Post on July 29, 2006) Earned Harvard law professor Alan Dershowitz met with the Palm Beach County State Attorney’s Office and provided damaging information.about teenage girls who say they gave his client, Palm. Beach billionaireJeffrey Epstein, sexually charged massages, according to police reports. Thereports also state that another Epstein attorney agreed to a plea bargain that would have allowed Epstein to have no criminal record. His current attorney denies this happened. And the documents also reveal that the father of at least one girl complained that private investigators aggressively followed his car, photographed his.home and, chased off visitors. Police also talked to s'omebddy who said she was offered money if she refused to cooperate with the Palm Beach Police Department probe of Epstein. The state attorney’s office said it presented the Epstein case to a county grand jury this month rather .than directly charging Epstein because, ofconcerns about the girls’ credibility. The grand jury indicted Epstein, 53, on a single count of felony solicitation ofprostitution, which carries a maximum penalty offive years in prison. Police believed there was probable cause to charge Epstein with the more serious crimes of unlawful sex acts with a minor and lewd and lascivious molestation. Police Chief Michael Reiter was so angry that he wrote State Attorney Barry Krischer a memo in May suggesting'he disqualify himself from the case. i https://wvzw.paimbeachclailynews.com/article/20060729/NEWS/190917573' 1/4 CA/Aronberq-000161 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY 11/11/2019 Police say lawyer tried to discredit teenage girls - News - Paim Beach Daily ~ew~" Pajn, !:lea-ch, ,FL Pu-lice say lawyer trted lo discre,dit teenage ginis Posted Jul 29, 2006,at 12:01.AM Upoated Oct 3, 2019 at 2:00 PM (EDITOR'.S NOTE: This story originally was published in The PalmBeacJiPost on]uly , 29, 2006} Famed Ha:rva:rdlaw-professor Alan Dershowitz met :with the Palrri Beach County State Attorney's Office and proVIded damaging· foformation.about teenage girls who .say they gave hi~ client, .PaJin, Beach Qil,li9na.ireJeffrey Ep.stein, s~x;ually charged rnassag1.:s, acc_ordin.g_ t:q: pofic;e reports .. The :reports also state that ·another Epstein attorney agreed to. a plea. ba..rgain that wol!lcl ha.ye allowed Epstein t.o have no crimlnal regord. His c:urrent att.or,ney d1.:nies this ha.ppenecL And the documents also reveal that the father of at least one girl complained that private investigators aggressively followed his car, :photographed his.home and. chased off visi'tors. Police also talked to somebody, who said she Was offered' money if she refused to cooperate with the Palm Beach Police Departrp.ept probe pf EpsteiP,. The •state attorney's· Qffic_e said;it pres.ent~d the. Epstein :c:ase fo a county grand jury this mpnth rather .than directly charging Epstein because .. ofcortterhs about the girls' credibility. The gran.djufy indicted Epsteih153,,dn a single count of felony solicitation ofprostltution, which carries a maximum penalty of five years in pri§q_n,, Police believed there was probable cause to charge ·Ep~tein with them.ore ~eriou~ crimes of unlawful se.x acts whh a m1nor and lewd and lascivious molestation. PQlice Chief Michael Reiter was so angry thaJ he wrote State Attorney Barry Krisoher a memo in May suggesting<he di'squalify himself from. the case, https://wwW.paimoeachda ilynews.com/artide/20060729/NEWS/1~091757~ • CA/ Aronberg-000161 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 1.14 11/11/2019 Police say lawyer tried to "discredit teenage girls - News - Palm Beach Daily News -Palm Beach, FL, The case originally was going to be presented to the. grand jury in February, but i was postponed after Dershowitz produced information gleaned from the Web site myspace.com showing some of the alleged victims commenting on alcohol and marijuana use, according to the police report prepared by Detective Joseph Recarey. Haley Robson, a 20-year-old Royal Palm Beach woman who told police she recruited girls for Epstein,.also is profiled on myspace.com. Her page includes photos of her and her friends, including one using the name "Pimpin’ Made EZ/’ Robson, who was not charged in the case, is a potential prosecution witness. According to Recarey, prosecutor Lanna Belohlavek offered Epstein, attorneys Dershowitz and Guy Fronstin a plea deal in April. Fronstin, after speaking with Epstein, accepted the deal, in which Epstein would plead guilty to one count of aggravated assault with intent to commit a felony, be placed on five years’ probation and have ho criminal record. The deal also called for Epstein to submit to a psychiatric and sexual evaluation and have no unsupervised visits with, minors, according to Recarey’s report. The plea bargain was made in connection with only one of the five alleged victims, the. report states. Fronstin - who declined to comment on the case - was subsequently fired and veteran defense" attorneyJack Goldberger was hired. He denies there was any agreement by any of Epstein’s attorneys to a plea deal. “We absolutely did not agree to a plea in this case,” he said. Neither Belohlavek nor a state attorney’s spokesman could be reached for comment. The parent or parents of alleged victims who complained of being harassed by private investigators provided license tag numbers of two ofthe men. Police found the vehicles were registered to a private eye in West Palm Beach and another in Jupiter, according to Recarey’s report. "I have no knowledge of it,”defense, attorney Goldberger said. The report also says a woman connected to the Epstein case was contacted by somebody who was still in touch with Epstein. That person told her she would be compensated if she didn’t cooperate with police, Recarey’s report says. Those https://VA'Ay.palmbeachdailynews.coni/article/20060729/NEWS/190917573 2/4 CA/Aronbera-000162 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY 11/11/2019 Police say laWyer tried to B\scrediUeena·ge girls - News -Palm Beach Daily News 0 -Palm Beach, FL The tase originally was going to be ptesented to the. grand jury in 1 February, but • • I was postponed after Detsliowitz produced information gleaned from the Web • . - I site myspace.com showing some of the alleged victims .commentii:ig ·on alcohol ;md ma,rifu;_i._n_q us~! acc9r.cting to the polic;:e report prepared by Detective J9_seph Recarey. Haley Robson, a 20-year--old Royal Palm Beach woman who told polite she recruited girls for Epstein,.also is profiled oh myspace.tom. Her pa~e includes photos of her and her friends, including one using the name "Pimpin'MadeEZ:' Robson, whp was 11ot cha,rged i11 t,he case, is a. pote_nti'cd prosecution wfrn~ss. According to Recarey, prosecutor Lanna Belohlavek offered Epstein, attorneys Dershovvitz and Guy Fronsti11 a plea de,tl in April. F:r:onstin! after speaki.IJ.g wfrh Epstein, accepte·d the deal, in which Epstein wouid _plead guilty to one count of aggra:vateclassault with intent to commit a felony, be placed on five yeats' probation a:nd have no criminal record. The deal also called for Epstein to submit to a psychiatric and sexualevaluation and have rto unsupervised.visits ,vith, minor~, accord~1;1g to :Recareis :report. The ple.i bargain wa,s mqde in ~onnection. with only Ol;l~ of the five alleged victim~, the. report states_. Fronstin - who declined to conim:ent on the case ., was subsequently fired and veteran defense attorney Jack Goldberger was hired. He denies there was any agreement by any of Epstein's attorneys to a plea deal. "We absolutelydi·d not agree to a plea in this.case/ he said. Neither Belohlavek nor a state attorneys spokesman could be.reached fofcomment. Th~ pai:ent Qr parents ofaUeg_ed yictillls -..yhb complained of being ha,:r;as~ed by private investigators proyided_ lic:~nse t~g n u_mbers gf two of the men. Police found th-e vehicles were registered fo a pri'7'ate eye in West Palm: Beach and another irt J upitet, according to R:ecarey;s report. "I have no. knowled&e ofit/ defen:se,attorrtey Goldberger said. The report also says a woman connected to the Epstein case. was contacted by- s9m~body vih9 was still in touch with Epstein. That person told her she would be compensated if she ·didn't cooperate with_ police, Rgcarey's report says. Those https//yM'Y'.,P.a.lm_b:~i3c:(1gailyn_~ws.c:oily<!rt]cJe/20Q60729/~EWS/.1 fl091757~ CA/ Aronberg-000162 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3/27/2023 2:57:43 PM 2/4 11/11/2019 > Police say lawyer tried to discredit teenage girls - News - Palm Beach Daily News - Palm Beach, FL who did talk "will be dealt with,” the woman said she was told. Phone records show the woman talked with the person who allegedly intimidated her around the time she said, Recarey reported. Phone records, also show that the person said to have made the threat: then placed a call to Epstein's personal assistant, who in turn called a New York corporation affiliated with Epstein, the report states. The issue in the Epstein case is not whether females came to his waterfront home, but whether he knew their ages. "He’s never denied girls came to the house," Goldberger said. But when.Epstein was given a polygraph test, “he passed on knowledge of age,” the attorney said. Afterthe indictment against Epstein Was unsealed this week, Police. Chief Reiter referred the matter to the FBI. “We've received the referral, and we’re reviewing it,” said FBI spokeswoman Judy Orihuela in Miami. The chief himself has come under attack from Epstein’s lawyers and friends in New York, where he has a home. TheNew York Post quoted Epstein’s prominent New York lawyer, Gerald Lefcourt, as saying-his client:was indicted only "because ofthe craziness ofthe police chief.” Reiter has declined to comment on the: case... Prosecutors have not presented a sex-related'case,like Epstein’sto a grand jury before,, said Mike Edmondson, spokesman for the: state attorney’s office. “That’s what you do with a case that falls into a gray area,” he said. The state attorney’s office did not recommend a particular criminal charge on which to indict Epstein, Edmondson said. The grand jury was presented with a list of charges from highest to lowest, then deliberated with the prosecutor out of the room, he said. “People are surprised at the grandjury proceeding,’’ West Palm Beach defense attorney Richard Tendler said. “It’s a way for the prosecutor’s office to not take the full responsibility for not filing the (charge), and not doing what the Palm Beach Police Department wanted. I think something fell apart with those underage witnesses.” https://www.palmbeachdailynews.eom/article/2p060729/NEWS/190917573 3/4 CA/Aronberq-000163 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY 11/11/2019 Polis;e say lawyer triei:t to discre.dit teenage gLHs - News - Palm Be_ach DaHy ,News - Palm Beach; FL Who did talk "will be dealt with," the woman said she was told. Fh 1one records 1·· . •. show the woman talked with the person who allegedly:intimiaat~g her:around the tin;te she :said, .Recarey reported. Phone records. also s_how that. the person said to have made the threat: then place·d a eali to Epstein's personal assistant, who iil turn called a New York corporation affiliated with Epstein; the report states. The issue in the Epstein case is not whether females came to hrs waterfr9nt lwme, b1,1t whether he knew theiniges. "J:Ie's nJ~VeFc.iep.i~d girl$ c_amg to the Jroµse/' G9ld.be:rger sa)d,., But when,Epstein was given a golygraph test, "he passed on knowledge ofage;'! the attorney said. Aftenhe indictment against Ei:rsteih wa:s· uns:e·ated this week; Police. Chief Reiter referred the .matter'to the· FBI. "We've received the referral,. and we're revfewing it," said FBI spokeswoman,Judy Orihuela in Miami. The chief himself has come uhdet attack from Epstein's lawyers and friends in New York, Where he has a home. The. New York Post quoted Epstein'.s· prominent New York lawyer, Gerald Lefcourt, a.s saying.hrs client was indicted only "because. of the craziness. of the police chid." Reiter has de.clined to e,omment on the. case .. Pros_ecutors have· not.presented. ·a sex:-related •cas.eJi.ke Epstein's fo a_gran'J:l jury hefore,said Mike Ecimondson;.spokesman for the·state attorneis office. ''That'.s wliatyou do with a case that falls irtt0 a gray area," he said. The state attorney's offrce did not recommend a partic:ula:r c,rimi11.i.l charge on which to indict Ep~teih·1 Edmo.µdsqn ~aid. The gra,nd jury was presented with a list of charges from highesf to lowest; then deliberated wjth the ptose~utor out of the room, he said. "People:are surprised at the grandju,ry proceeding/' West Palm Beath defens.e attorney RichardTendlet said. "Itls away fot theptosettito:r's office to not take the foll fesp.onsibility fot not filing the (charge), and .not doing what the Palm Beach Police Department wanted. I think sometlii11g fell apart with those unf:ieq.ge witnesses .. " tl!tpsl/lwvfw,pqlf[lp~ac.hdailyn§.v.'S,COITI(article/2Q060729/f'! EW,S/190917 573 CA/AronbeLq-000163 FILEU: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 3/4 11/11/2019 Police say lawyer tried to discredit teenage girls - News - Paim Beach Daily News - Palm Beach, FL Defense attorney Robert Gershman was a prosecutor for six years. "Those girls must have been incredible or untrustworthy, I don’t know,” he said. Other attorneys said Epstein’s case raises the issue ofwhether wealthy, connected defendants like Epstein - whose friends- include former President Clinton and Donald.Trump - are treated differently from others. Once he knew he was the subject of a criminal probe, Epstein hir.ed a phalanx of powerful attorneys such as Dershowitz and Lefcourt, who is a past president of the National Association of Criminal Defense Lawyers. Miami lawyer Roy Black - who became nationally known when he successfully defended William Kennedy Smith on a rape charge in Palm Beach - also was involved at one point. Said defense attorney Michelle Suskauer: "I think it’s unfortunate the public may get the perception that with power, you may be treated differently than the average Joe.” https://www:pairribeachdailynews:com/article/20060729/NEWS/i 90917573 4/4 CA/Aronbera-000164 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY 11/11/2019 Police say lawyer trfed to discredit teenage girls - News - Paim Beach DaHy ~ews - Paim Beach, FL Defense attorney Robert Gershman was'. a prosecutor for six yea:rs. "Those .girls i rtm·st have been.ihctedible or tinttuStW.orthy, I don'tkhow/' he sai'd. Other attorneys said Epstein'.s case raises the .issue of whether wealthy, connected defendant~ like Epstein -·whose .friends-include former President Ch11tQn anc:i Donald.Trump - are treated differe_ntly frQm_ others. Onc:e he knew he,was the subject ofa criminal probe, Epstein hir.eda· phalanx of powerful.attorneys such as Dershowitz: and Leftourt; who is a past president ·of the National Association of Criminal Defense Lawyers. Miami lawyer Rox Black ~ who became nationally known when he successfully defended William Kennedy Smith on a rape chat~e ih Palm Beach- also was involved atone point Said defense attorney Michelle Suskauen "I tliinkit's unfortunate the public may get the perception that with p.ower, you :may be treated' differently than the av.erage)oe.·" https:/twww:palnibeachda ilynews,coniiarticle/20060729/NEWSi190917 573 CA/Aronbe.m_-000164 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 414 The Palm Beach Post REALNEWSSTARTSHERE Expert: Ignorance of age isn1 defense in sex cases Posted Aug 5, 2006 at 12:01 AM Updated Oct 3,2019 at 1:38 PM (EDITOR’S NOTE: This story originally published in The Palm Beach Post on Aug. 5j 2006) Even if Palm Beach money managerJeffrey Epstein didn’t know that girls who police say gave him sexual massages at his Intracoastal home were under the legal age, that alone wouldn't have exempted him from criminal charges of sexual activity with minors. “Ignorance is not a valid defense,” said Bob Dekle, a legal skills professor who Was a Lake City prosecutor for nearly 30 years, half of that time specializing in sex crimes against children, “There is no knowledge element as far as the age is concerned," Dekle said. After an 11 -month investigation, Palm Beach police said there was probable cause to charge Epstein, 53,with unlawful sex acts with a minor and lewd and lascivious molestation. They contend that Epstein - friend of the rich and famous and financial patron of Democratic.Party organizations and candidates - committed those acts with five underage girls. In the past week, New York Attorney General and gubernatorial candidate Eliot Spitzer has returned about S50,000 in campaign contributions he received from Epstein, and Mark Green, a candidate to replace Spitzer in CA/Aronberg-000165 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY SEi~p,grt,: lgo.oia,llCQ :qf 11g1\ is11l't :defense: ln: stx)ca:s:es Posted Aug 5, 2006 at 12:0l AM Updated O~t ~. 2Ql9 atl :3~PM (EDITOR'S NOTJ:: This_ stqry origino.lly pitbJi.s_h._e,fi11 The Palm Beath Post on Aug. 5; 2006). Even if Palm Beach money manager Jeffrey Epstein didn't kn9wth;i.t_ grrls wh_o poHc~ say gave, hi111 sexµaJ massage,s ~l his Intra.coastal home were under the legal a·ge, that alone wouldn't have exempted him from criminal.charges of sexµal activity with,rrii_no_rs. ,;Ignorance is not a valid',defense," said Bob Dekle, a legal skills ,professor who was a: Lake City prosecUtot for ne'arly 30 years, half of that time specializing in sex crimes against cliildren, '~There.is 110 krrowleclge element as for as the age is concerned," Dekle said. After an 11-month investigation, Palm Beach police Said there w.as pi:obable calls_e to GA<!fgl:'. Epste.i11,,·s.3., w.ith unlawful sex acts with a: minor and lewd ;a:nd lasciyio4s molestation. They contend that Epstein "'friend of the rich ~.ml fa111ous aµd fi.n~cial patron of Democratic Party organizations and candidates· - committed those acts with five underage girls. In the past week, New York Attorney General and gubernatorial c;andidat~ Eliot Spitzer has retµrn~d abou_t $SO ;000 .ih campaign .contributions he received from Epstein, and Ma:tk Green; a candidate to replace Spitzer in CA/Aronbernc000165 FILEU: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3/27/2023 2:57:43 PM his current job, has returned Si0,000 to him because ofthe Palm Beach scandal, the New York Daily News has reported. i Rather than file charges, the state attorney’s office presented the case to a county grand jury, The panel indicted Epstein last week on a single, less; serious charge of felony solicitation of prostitution. The case raised eyebrows because the state attorney’s office rarely, if ever, kicks such charges to a grand jury. Arid it increases the difficulty of prosecuting child sex abuse cases, especially when the defendant is enormously wealthy and can hire high-priced, top-tier lawyers. At least one of Epstein’s alleged victims told police he knew she was underage when the two of them got naked for massages and sexual activity. She was 16 years old at the time and said Epstein asked her questions about her high school, according to police reports. A girl who said she fnet Epstein when she was 15 said he told her ifshe told anybody what happened at his house,, bad things could happen, the police reports; state. Epstein’s youngest alleged victim was 14 when she says she gave:him a massage that included some sexual activity. She is now 16'. The girl’s.father says he doesn’t knowwhether she told Epstein her age. “My daughter has kept a lot of what happened from me because of sheer embarrassment,” he said. “But she very much looked 14. Any prudent man would have had second thoughts about that.” Defense attorneyJack Goldberger maintains that not only did Epstein pass a polygraph test showing he did not know the girls were minors, but their stories weren’t credible. The state attdrriey’s office also implied that their credibility was an issue when it decided not to charge Epstein directly, but instead give the case to the grand jury. i CA/Aronbera-000166 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY his currentjob, has ret:um:ed $10,000 to him because ·of the Palm Beach scandal, the New York Daily News has reported. Ra_ther th:m_ f1l_e charges, the _st3,te a.ttorney'~- office presented, the case to a c.:ounty gra:nd jµry. The pan,el indicted Epstein lastweek.on a single, fess,serious cha:r~e-of felonysolicifation of prostitution. The case r3,ised ~yebrows peq.use th.estate attor,ney's 9rfi_ce rarely, ifever,kicks such charges to a grand jury. And it increases the difficulty of prosecuting child sex abuse cases; ~~peci?,)ly wl1e:t;1 th-~ defendant {s enorm~)Usly we.al!hY. a.µg tan hire high-priced, top-tier lawyers. At leastone of Epstein's alleged Victims told I?olice·heknew she'was underage when the tvvo of them got naked for p:iassages and se~al ac:tivity._ She was 16 ye;i.rs old at th~ time and said Epstein asked her questions about her high school; actotdihg to police reports. A girf who said she,met Epstein when. she was f 5 said he tol_c;I her ifsli~ told apyb9ay wll~t happeneg a:t llis; P.9US(;!, bad things couid happen, the police reports: state, Epstein's youngest alleged victim was 14 when she says she gavei him a massage that included some sexual activity. She is n9w 16. The girl's father says he cloesn'tkn_owwhether she told .Epstein her a~e. "My-daughter has kept a lot ofwhat ha_ppenea from me qecallse o6heer e111b3,rrn_ssroent," he sa.iq. "But s_he ve:cy much looked 14. Any prudent man would have 'had se·cpnd thoughts about that." Defense attorney.Jack Goldberger maintains that not only did Epstein_pass a polygraph test showing he qid_ not kn_ow the giris were minors, but their stories weren't uedible-, The state attorney's office also implied that their credibility w~s an i~su~ yv-1).en it dec;:1ded.n,ot to ch;i.rge ~ps,tein dj:rectly! but instead give the ca.se to the grand jury. CA/Aronberg-000166 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM “A prosecutor has to look at it in a much broader fashion,” a state attorney’s spokesman said last-week. ■ rtTKWQENT 0 EL-'1 Epstein hired Harvard law Professor Alan Dershowitz when he became aware he was under investigation, and Dershowitz.gave prosecutors information that some of the alleged victims had spoke of using alcohol and marijuana on a popular Web site, according: to a Palm Beach police report. Prosecutors typically consider two things in deciding whether to charge somebody with sex-related offenses against minors - whether there is sufficient evidence arid whether there is a public interest in doing so, Dekle said. If two teens are in a sexual relationship and the boy turns 18 before the girl, he could be charged with a sex crime if the; sex continues. There would be no public interest in. pursuing that, Dekle said. But where there is a large gap in "ages - and especially in cases of teachers with students - there is a public interest in prosecuting, he said. Likewise if the accused has a track record of sex with minors. CA/Aronberg-000167 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY CA/Aronberg~000167 ''.A prosecutor has to look atit in a much broader fashion/ a state attorney's spokesman said last'week. Epstein hi'r.ed Haivatdlaw ProfessorAlanDershowitz whe1Jlte ):,e~ru.ne: awa.re. he was under investigation, and Dershowitz,.gave prosecut0,rs information. that sorpg of the allegedvittims had sI5oke ofusing alcohol and marijuana on a pop11lar Web site, according;toa Palm Beachpolice report. Prosecutors:typi,caily,c.onsider two ,things in deciding 'whether to charge somebody with sex-related offenses a,ga.inst mipop; -whether there is sufficient evide·nce an:d whether iliere is 'a public in_teresti:n d.oiI1g so, Dekle said, If two teens are in a s~xµal relationship anc:l the :bpytµrns 1 S before tli:e girl, he could be, chatged With a sex <:time if the: sex condnues,. Then~ w9uld:be no public interest in. pursuing that, Dekle saia., But where there is a large gap in ages ., and ¢specially in ca.ses ofteachers with students· - thete is a public interest.in prns,ecuting, he· said. Li_kewise if the ,:/.q:µsed has a track record of sex with minors, FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3/27/2023 2:57:43 PM Still there is a "universal constant” in prosecuting these j cases, Dekle said. Men who exploit underage children for sex often carefully choose their victims in ways that will minimize the risk to them, he said. 1 Victims usually are from a lower social,status, and they may suffer from psychological problems, Dekle said. “Lots of child sexual abuse victims have been victimized by multiple people over a period of time. Then the act of abuse produces behavior in the victims that further damages their credibility.” Examples include promiscuous behavior and drug abuse. Some ofthe alleged victims in the Epstein case returned to his home multiple times for the massage sessions and the S200 to S300 he typically paid them per visit. “That would be a definite problem for the prosecutor," said Betty Resch, who prosecuted crimes against children in Palm Beach County for five years and now is in private practice in Lake Worth. “The victim becomes less sympathetic” to a jury, Resch said; “But she’s a victim nevertheless. She’s a kid.” Most men charged with sex crimes against minors look normal, Dekle said. A jury expecting to see a monster seldom will. And the victims’ ages work against them and in favor of the defendant in a trial, Dekle said. If a child and an adult tell different stories and both swear they’re telling the truth, adult jurors are more likely to believe the adult, Dekle said. “You have all these, things working againstyou in a child sex abuse case. Prosecutors normally try to be very Careful in filing those cases because they know what they’re getting into. There is no such thing as an iron-clad child sexual abuse case.” CA/Aronberg-000168 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY Still there is a ''universal constarit" in prosecµting th,ese1 . . . . . J cases, Dekle said. Men who ,exploit underage children for - I sex often carefully choose their victims irt ways that will minimize the risk to them, he said. Victi111s u_sua)ly are. frorp -~ l9wer ~ocj;IL ~tatus, arrd they may· suffer from psychological problems, 'Dekle said_. "Lots of child sexu·al abuse vittims have been victimized by multiple- people o:ver a period of time; Then the act of abuse produces behi:3.vior in th€!- victims thatfu,rther dam_;iges th_eir credibility::' Examples in dude promiscuous behavior and drug abuse. Some of the a1leged victims in the Epstein case returned to his home multiple times for the .massage sessions ;md the. $200 to $JOO he: typically paid them ·per visit, "That would be a definite problem for-the prosecutor," said BettyResch1 who prosecuted crimes agiinstchildren.irr_P:ihn"Beach County·f◊r five·ye:ars and now is in private·practice in 'Lake Worth. "The victim becomes Jess sympathetic" to a jury, Resch said, "But she's a vktim nevertheless. She's .:!J<ici." Most men charged with sex crimes against minors look normal, Dekle said. A jut.y expecting to see a monster seldom will. Al].d the victims' ages woikagai.nst- them and in favor of the defendant in a trial, l)ekle said. Ifa child and art. adult telL different stories and both swear they're telling the truth1 adult juror's are more. likely to hefieve the adµlt 1 Dekle said. '£You have ali these, things working ag_ainstyoµ in a chi.Id sex abuse case; Prosecutors rtotmally tryto. b:e Very. careful in fihngtho~e cases because :they know what they're getting into. There is no s_uch th1ng as an iron-cl~cl chlld"sexµal; abuse ca:se." CA/Aronberg-000168 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM The Palm Beach Post REALNEWSSTARTSHERE ' i Epstein camp calls female accusers liars Posted Aug 8,2006 at 12:01 AM Updated Oct 3, 2019 at 3:35 PM (EDITOR’S NOTE: This story originally published in The Palm Beach Post on Aug. 8, 2006). Attorneys and publicists for Palm Beach financierJeffrey Epstein went on the offensive Monday, contending that teenage girls who have accused Epstein of sexual shenanigans at his Waterfront home are liars and saying that the Palm Beach Police Department is 'childish.” "There never was any sex between Jeffrey Epstein arid any underage women," his lead attorney, Jack Goldberger, said frbiri Idaho where he was vacationing with his family. Epstein did have young women come to his house to give him massages, Goldberger-said. "Mr.. Epstein absolutely insisted anybody who came to his house be over the. age of 18. How he verified that, I don’t know. The question is, did anything illegal occur. The law was not violated here.” He had no explanation as to why Epstein would pay girls or women with no massage training - as the alleged victims said was the case - $200 to $300 for their visits. “The credibility, of these witnesses has been seriously questioned ” Goldberger said. Epstein, 53, was indicted by a county grand jury last,month on a charge of felony solicitation of prostitution. After an 11-month investigation that included sifting through Epstein’s trash arid surveilling his home, Palm Beach police concluded there was enough evidence to charge him with sexual activity with minors. When the. grand jury indicted CA/Aronberg-000169 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY I . . I Th i. ·e··. '. U.-:sl'lm;·. ·,; 'B·•··· ·;e· ~,pib' : . ! Po·cbt . • • ..-.r~JALMEWs'SfiRJS·nw~ •c '~v.~ Epstein ·cam·n,,,,calls fem·a1e, accusers - ·---·•· .. ' .•:·'.: ... ··. ---~·-·,., ,.· --1~ -·~· .. : -..... - .. ~"-'·•-~~-- -.. ,•.-. .. - . ,,.,.. ___ .. __ ,. ,<. ,,, . ,, .. •.·· .li'.ars Posted Aug 8, 2006 at 12,01 AM UpqaJed Oc:t ~. -2019 ~t 3:3~ PM (EDITOR'S NOTE: This story origind.lly pubtishe.d in tire Palni Beach Post oli Aug. 8, 20CX,) Attorneys and publicists for Palm Beach financier] effrey Epstdn w~nt on the offensiv~ Monday, C9Jlt~nding that teena~e ~irls who have atcused:Epsteih of sexual shenanigans at his waterfront home are fiats and saying that the P;tlm Bea<;h Pplice Departlnent-is "childish." 1'Thereneverwas any·~sex between Jeffrey Epstein arrdany underagewomen,".hislead attotney,.Jack G6ldber$er.~ said from Idaho Where he was vacationing with his family. ~p~te_il). µ{cl .have young WOl.Jl~n c9m~ to ~I~ house t.P ,give him mass.ages, Goldberger, said. ''J'vlr. Epstein absolu,tely insisted anybody who came to his house be over the. a:ge of 18. How he verified that, I don't know. The questior1is,; did. an,y,thfng illegal oc~ur. The Jaw Wcl,S l)ot yiolate:d here." He had no explanation as to why Epstein woµld·pay: girls.or women with no· rriassa&e training - as the alleged victims said wa_s thg CcJ_Se - $200 ~o $~do for-their VlSltS. "The credibility of these witnesses has been seriously questioned/' Goldbet_get said. Epstein, 53, was indicted by a.county grandjury lastm9nth on a charge: of felony solicitation of prostit1.J.tiOn. After an l l-'mOrtth investi$ation that include,d .sifting throu~h' Epstein's trash ahd surveilling his home, Palm Beach police concluded there was enq:ugh evi._d~nc;:e to cha,rge hiTTI wiJh sexual activity with minors. Whell the. grand jury indicted CA/Aronbem._-000169 FILEU: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM Epstein on the less serious charge, Police ChiefMichael Reiter referred the case to the FBI to determine whether there "were federal law violations. After a spate of stories about the case last week, New York publicist Dan Klores - whose client list has included Paris Hilton and Jennifer Lopez - said on Saturday that Epstein’s camp was ready “to get their story out." They did that Monday via Goldberger and a Los Angeles publicist for Miami criminal defense attorney Roy Black, who also has represented Epstein in the case. "We just think there has been a distorted view of this case in the media presented by the Palm Beach police,” Goldberger said. Reiter has consistently declined to comment on the case arid did not respond to a request for comment Monday. The implication that State Attorney Barry Krischer was easy on Epstein by presenting the case to a grand jury rather than filing charges directly against him is wrong-, Goldberger said. CA/Aronberq-000170 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY Epstein on the'Ie~s serfous charge,-Pohce Chief Michael Reiter referred the ,case to the FBI to, determine wheth~r there were federal law violations; After a spate of stories· about the case last week, New York publicist Da11 Kl ores - whose client 11st has :included· P.aris Hilton andJenniferLopez - s_aid on. Saturday that Epstein's camp was ready "to ·~et their story out.'; They did that Mondayvia Goldberger and a Los Angeles publicist for Miami .criminal :pefense attorney Roy Slack, who .also has represented Epstein in the case. "We just-think ther.e has been a: .distorted view·of tliis .case in,the media presented by the Palm Beach police;" Goldberger said. Reiter has consist:entiy dedined to comment on the case artd did not respond to·a request for corn:ment Monday: The implitat'ioh tharState Attorney Barry Kristhetwas ea,_sy on Epstein by presendng the case to a grand jury r_ather than tiling charges d1rec:tJy against h,im .is wrong? Goldberger said. CA/Aronberg~000170 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM The Palm Beach Police Department was "happy and [ ecstatic” that the panel was going to review the evidence. T think what happened is they weren’t happy with the. result. They decided to use the press to embarrass Mr. Epstein.” i But records show that Reiter wrote Krischer on.May 1 well before the case went to the grand jury - suggesting that Krischer “consider if good and sufficient reason exists ro require your disqualification from the prosecution ofthese cases.” Rather than flat-out decline to charge Epstein, Krischer referred the case to the grand jury to “appease” the chief, Goldberger said. A state attorney’s spokesman would say only that the office refers cases to the grand jury when there are issues with the viability of the evidence or witnesses’ credibility. Both the state attorney and the grand jury concluded there was not sufficient evidence that Epstein had sex with minors, according to Goldberger. “It was just a childish performance by the Palm Beach Police Department,” Goldberger said. The defense attorney said one ofthe alleged victims who claimed she was a minor was in fact over the. age of 18. Another alleged victim who was subpoenaed to testify to the grand jury failed to do so. Epstein’s accusers, he added, have histori es of drug abuse and thefts. “These women are liars. We’ve established that.” But why would they all invent their stories about meeting Epstein for sexual massages? “I don’t have an answer as to what was the motivation for these women to come forward and make these allegations," Goldberger said. I I CA/Aronbera-000171 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY i The Pafm Beach Polii;:e bepartment was "happy and i . I ecstatid' that the ·p:anel was going to review the evidence. ''I think wha:r happened.is they were:n\ happy with the tefult. -- - -- I They decided to use the press to embarrass Mr. Epsteil" I But records show ihat Reiter wrote Krischer on May 1 :- -- I wellbefor.e the case went to the grand jµry - suggesting that Ktischer "consider if good and sufficie•nt reason exists tb· require your disqi.rn,ll'ffcation from the prosecutionofthese ~ases/' Rather than flat-.out dedi:ne· to charge Epstein, krischer referred the case to· the gt and jury. to "appease" the chief, GoJdberger ,said. A state attorney's spokesman would say onlythattheoffice refer!{ cases to the grand jury when there are issues with the viabilfry.ofthe evidence ot ,witnesses' credibility. Both the state attorney and the grand jury concluded there was notsufficient evidence that Epstein had s_ex with minors, according to Goldberger.- "It was just a childish performance. by the Palm Beach Police Department," Golcll:>erger said. The defense attomey said one :of the alleged victims who· claimed she was a: minor was in fact over the age of 18. Another ;illeged victim who was subpoenaed to testify to the grand}llryfailedJo do so. Epstein's _acct1.sers1 he adcied, have histories of drng, abuse and. thefts, ,;These women are liars. We've .established that." B')t why would they all invent ihefr stories about meeting Epstein for sexuai massages? "I don't have ah answer as towhatwas the motivation fot these women to come forward and make these allegations," Goldberger said. CA/Aronberg.-000171 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM Newspapers' The Palm Beach.Post (West, Palm Beach, Florida) • 14 Aug 2006, Mon • Page 7 t Downloaded on Nov 11.2019 assimaaaiisiaiaasssaaisa it?- Jt Wf Grf nv^b'an 5ufawsiltj?5 sJHtuted'»^r, h '#» ftj^SnMi4«Tcss*- ^dki^S^Clas^^ f i <iurw* ■it -aai&t.', ^Epsiiltt t«*y^YtwpWw^^' rnassaalttWward »l*lbc2 .? ^SUy^orjriSJn^S e«^ hi*tc^iVr «W3» to* £tM'ik^6stxa^iHwt&atV'' \ •%■■ ■Wpnlrofpbsi g ihb*/ratmttr^iy/iaxOrffl.& * tc» tiuiiir a VKk ^tas- - Idhwt-irati Hiinfr/J^ fast fc8«lW tJuhiiJ a fr». 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All Rig_hts Res_erved. I • , Downloaded on Nov 11, __ 2019 CA/Aronberg..-000172 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM The Palm Beach Post REALNEWSSTARTSHERE r i Delays in Epstein case unusual, i lawyers say Posted Mar 13, 2007 at 12:01 AM Updated Oct 3,2019 at 3:48 PM (EDITOR'SNOTE: This story originally published in The Palm Beach Post March 13, 2007) A federal probe or a plea deal could explain the wait in the Palm Beachcr’s solicitation case: Nearly eight months after Palm Beach tycoon Jeffrey Epstein was charged with felony solicitation ofprostitution, there has been no. discernible progress in his case. No witnesses deposed. No trial date set. Nothing, save for routine court hearings reset without explanation. "Usually that would be unusual/’ said criminal defense attorney Glenn Mitchell, who has no involvement in the case. "As a general rule, it would be unusual for nothing to have happened,” agreed Michael Dutko, a criminal defense attorney in Fort Lauderdale. He represents Haley Robson, 20, of Royal Palm Beach, potentially a key witness in the case. A routine hearing for Epstein was pulled from the court docket last week and reset for May 16. The delays and inaction could be due to a potential federal probe of Epstein or because a plea deal is in the works, attorneys say. Unusual is the Word that best describes everything about the case against Epstein, 54, an enigmatic money manager in New York City who counts Bill Clinton and Donald: Trump among his friends. , CA/Aronbera-000173 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 27 2023 2:57:43 PM NOT A CERTIFIED COPY ... - l j ll l , ' .,, ·i· t :•. ., ',• ,.• '' ·.·' ', .... ' '', ,.,. ·. '' ., I I e ay.s n1 . ,p_s e:i1un .case~ unusua , lai:yets say: Posted Mar 13,2007 at 12:01 AM Updated bet 3, 2019 at3:48. PM (EDITORSNaTE:: This story originally published in The Palm Beach Post Ma.rch f:t 2007) A federal probe or a plea deal .could explain the wait in the Palm Beacher's solicitation case; Nearly eight months after Falm Beach tycoon Jeffrey Epstefo was charge.d with folony solicitation ofprostitutior1, there has heen no. discernibi'eprogress in his ca:se, No. witnesses deposed. No trial date set. Notliing, save for rou,tipe coµrthearing~ Jese:t without expla.p::itio.n. "Usually that would.be unusual," said criminal defense· atto:rn:ey Glenn Mitcheii; who has no involvement in the case. "As a general rule, .it would l:>e unusual for nothing t_o 'have happene:d/ agreed Michael Dutko, a criminal qefense attorneyin :Fort Lauderdale. He teJ>tesents Haley Robson; 20,. of R,qy~l Palm Beach! potentially a key witne~s _i.11 th.~ case. A :routine hearing for Epstein was pulied fro·m the·court docket]ast week and resetfor Ma:y 16. The delays and ' inaction could be: d.ue, to a potential federalprobe of Ep~tefo or beca:use a plea deai is in the works1 attorneys say. Unusual is:the word that best describes everything about the case against Epstein, 54, an enigmatic money manager in New York Citywho c;otmts Bill Clinton andbonald Tru.tnp, a:mong his friends. CA/Aronbern:_-000173 FlLEU: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM "Highly unusual” is how Palm Beach Police Chief Michael .r Reiter described State Attorney Barry Krischer’s handling • v • . . . . I ofthe case in a bluntly critical letter to Krischer last year before Epstein was indicted; I I Reiter referred the matter to the FBI to determine: whether any federal laws had been violated. Epstein’s allies countered by attacking the chief personally and professionally. Reiters department investigated Epstein for 11 months; Police sifted repeatedly through his trash and conducted surveillance on his five-bedroom, 7 1/2-batb, 7,234-square- foot home oh the Intfacoastal Waterway. Police said Epstein paid women and girls as young, as 1.4 to give him erotic massages at his home. Police thought there was probable cause to charge him with unlawful sex acts with a minor and lewd and lascivious molestation. Epstein responded by hiring a phalanx of lawyers. One of them. Harvard law professor and author Alan Dershowitz, provided the state attorney’s office with information about alcohol and marijuana use by some ofthe girls who said they were with Epstein. Prosecutors then referred the case to the grand jury rather than file charges directly against Epstein. Epstein’s attorneys deny he had sex with underage girls. The:lawyers say .the girls’ stories' are not credible. But if the court file is any indicator, ’they’ve made no effort to depose the girls. Neither prosecutors: nor defense attorneys have sought to question Robson, said Dutko, her attorney. She recruited teenage girls to visit Epstein for massages and sexual activity,. Palm Beach police said, and presumably would be a key witness. CA/Aronbera-000174 FILFD: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY ' "Highly unusual" is how Palm Beach Police Chief Mic:b:4(;1 • I Reiter d~_scdb(;dState _A.tt91;neyJ3;irry Kdscher's handli"hg - . . . . . I ofl:he c:as_e in a bhmtly critical leuert:o Krischer la.st ye·ar before Epstein was indicted, I Reitet referred the mattef·to the,FBlto determine whether any federal l~ws had been viol;ited. Epstein's allie_s c.91Jntered by attacking the chief personally and professionally. Reiter's department investigated Epstein for l 1 months; Pqfice ·slfted ,repe.atedly thro1J.gh h1s tr~sh and, condµcted. surveillance:on.his ri\re,..bedro:om,7 1/2-'bath, 7]234-squate-· foot home on the Irtttacoastal Waterway. Police said Epstein paid women and girls as young «!-S l4 to give him-erotic massages ath1s.home. Police thought there was probable cause to charge him with unlawful. sex acts with a minor and lewd. and lascivious molestation. Epstein responded by hlring a phc!lanx oflawyer:s. bne of them! H:irvard law pro(essor and author Alan.Pershowitz; p·to.vided the. state attorney's office with information about alcohol and marijuana use by some of the girls who said they wt=r:e \\9th Epstein. Prosecutors tht=n refer:red. the case .to the. grand. jury rathe_r than file charges directly against Epstein. Epstein'.s attorneys deny he had sex with ·underage girl~. The lawYers say the girls" stories· c1Ie not credible. Bµt jfthe court fiie is any indicator-; theive·made n·o effort to depos·e the girls. Neither prose_cutors nor defense attorneys haye ·sought to qu·estion Robson, ·said Dutko, her attorney; She recruited teenage gitls to visit Epstein for massages and sexual activity, Pahn Beai:,:h police. said, apd presumibly would be a key witness. CA/Aronberg-000174 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM Epstein’s attorneyJack Goldberger did not return phone messages. : A source close: to the case suggested it is languishing ' pending a decision by the FBI on whether to refer it to federal prosecutors. "We still have a pending case,” FBI spokeswomanJudy ■ Orihuela said Monday. State Attorney Krischer did not return a call for comment. His spokesman, Mike Edmondson, declined to say whether federal investigators are delaying the Epstein case. But, he added, “if another agency is looking at something, we wouldn’t want to step on their toes.” Attorneys say inertia in a criminal case often points to a pending plea deal, “It would not. surprise me if something has happened that’s not reflected in the court file,” said Dutko, such as an agreement that will be formalized later. Defense attorney Marc Shiner said defense attorneys sometimes put off overtly conducting discovery — deposing witnesses, requesting documents and the like — because doing so creates more work for harried prosecutors who may become angry and not offer a plea.deal. “Sometimes defense lawyers, knowing that, will try and do discovery without taking depositions,” said Shiner, a former prosecutor for 13 years. Instead, they may conduct a below-the-radar probe such as having a private investigator check.out leads, he said, Shiner and others say a plea deal for Epstein probably would,result in pretrial intervention, in. which a defendant maybe ordered to undergo a psychological evaluation, counseling or other conditions in return for dropping the charge. CA/Aronberg-000175 FILET): PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY _Epste1n'' s .attorney Jack Goldberger did not return phorte messages. A sourc·e dose to. the case :suggested it ·is lantuishing pendin~ a decis'ic>ii bytheFBI chi whetherto refer itto federal pr9secµtors. "Westillhave.a,.pe_nd.ing case/ FBI spokeswomanJudy, Orihuela said Monday. State Attorney Krisclier did not return a call for comment. His spokesman, Mike Edm9r1dsop, qec:lined to sc1y·whether federal investigators ate: delaying: the Epstein case, But, he added, ''if another agency is looking at something, vie w:ouldn\ want to step on t,hei.r tqes." Attorneys .say jnertiajn c1 c:rimiQ'a1 case ofteµ points to a pending plea deal, "Itwouldnot;surptisemeifsotnethin:g has happened that's not reflected in the court file," said Dutko, such c1_s clil ;igree;mgn,t that wi11 be fofillaJiz;edJat,er. Defense attorney Marc Shiner said defense attorneys sometimes put off overtly conducting discovery -- deposi'ng witnesses, requesting documents and the Jfke -- .because 9911).g sq c_rea,tes more workJo.r harried .. prose:cutors who may he~ome an·gty and. not off et a plea deal. "Sometimes defense lawyers, knowing that, will try and do discovery witbout taking depositions/' said Shin~r, a former proseq1tor for 13 years. Inste·ad,theymay conduct a below,;.the--tadar probe such as having a ,private investigator check out leads, he .sai~i_, Shiner and others say·a plec1 deal for Epstein probably wo:uld.resu1t in pretr:ial intervention, in which a defendant may be ordered to undergo a psychological e:Valuation, counseling or other conditions in ret\lrn for dropping the charge. CA/Aronberg-000175 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM Edmondson, spokesman for State Attorney Krischer, said there is no plea offer and no request for the prosecution to show its cards. ! “To my knowledge, it’s never happened before on a filed case,” he said,. CA/Aronbera-000176 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY Edmondson, spokesman for Stat~ Attorney Krischer,, said there is no plea offer and' no request for t:he prose-cutio~ to show its ta:tds. "To my knowledg~, it's never: happened before on a filed ca_se/ he s.aiq_. CA/ Aronberg-000176 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 252 / 278 - Thursday, October 18, 2007 ; I Edition: FINAL Section: LOCAL Page: 5B Source: The.Associated Press Illustration:-PHOTO (B&W) Memo: Ran all editions. Dateline: NEW YORK WOMAN SUES BILLIONAIRE INVESTOR, SAYS THEY HAD SEX WHEN SHE WAS 16 A billionaire investor, already facing jail in Palm Beach County on charges of soliciting underage prostitutes, is being sued by a young woman who says he had sex with her when she was 16 and had sought hisLeip becoming a model; The lawsuit, filed late Tuesday in Manhattan's state Supreme Court, says financier Jeffrey Epstein had the teen perform a sex act when she brought photographs of herself for him to review in his Upper East Side mansion; sometime in 2000. Epstein, 54, a money manager, told the teen he managed finances for Victoria's Secret and "Could get you into the catalog" if she were "nice" to him, court papers say, The papers say being "nice" included massages and Other favors. When the girl told Epstein, "I am 1.6 years old and just want to model," he replied, "Don't worry, I won’t tell anybody," court papers say. Epstein, said by London's Mail on Sunday to be a close friend of England's Prince Andrew, has been indicted in Palm Beach on charges Of soliciting underage prostitutes. That case is pending. The girl visited Epstein "several times over the several months and engaged in bizarre and unnatural sex acts” while she was a minor, the lawsuit says. Epstein "repeatedly requested that (the girl) return with her 14-, 15-, and I6-year-old girlfriends, stating, ’Come by with your friends your age next time. Don't bring Sherrie (a mutual friend in her 40s). I love girls your age,'" The young woman, now 23, kept returning to Epstein because she has "mental issues," said her lawyer, William J. Unroch. He refused to elaborate, but court papers say she was "disabled as a result of severe mental disease and defect." Epstein's lawyer in New York, Gerald Lcfcourt, said, "The girl has admitted she is insane, but she can read a newspaper and recognize the word 'rich.'-" Lefcourt also said.the statute of limitations has expired for the woman's case criminally and civilly, and will almost Certainly be dismissed. He refused to comment on Epstein's Florida charges. Meanwhile, Unroch, 57, also acknowledged that his client was living with him and was at the center of a $10 million lawsuit he filed last year against a neighbor who said he was having sex with underage girls. That case is pending. "What she was doing at 22 is irrelevant to what happened to her when she was 16," Unroch said Wednesday. He went on the say he hoped Epstein would agree to "do right” by his Client.and resolve the case Out of court. CA/Aronbera-000177 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY 252127& ~ Thursday~ October 'ls:, 2007 Edition: FINAL Section:: LOCAL Pag·e: .SB Source: Th_eAssociateg Press Illustration:; PHOTO (B&W) Memo: Jlan:_all: editions. Dateline: NEW·YORK WOMAN SUES: BILLIONAIRE INVESTOR, SAYS THEY HAD: SEX WHEN SHE WAS 16 A billionaire investor, already facing jail 'in Pa:lm B:each County on charges of soliciting underage prostih.ites~ is being sµed by a young WQTJ.1ar1 who says he had_ ~~-x w1ih her: when :she wa_s lfand had sought his :help becoming a model. The laws"[Jit,. filed fate Tuesciay in Manha~an's state SlJpreme Court, s'1ys fi11~uwier Jeffrey Epstein had the teen perform.a.sex act when she brought photographs of herself for him.to review in his Upper East Sid~mansio_n sometime in 2000. Epstein,. 54, a money manager, told the teen he-managed finances for Victoria's Secret and "could get you into the cat~log'' if $he we.r:e ''nice" t9 him, court p'1pe.r~ say_. The papers ~ay l;,eing i•n.fce'' 'included massages and other favors. • •• • • - When the girl told Epstein, "I am 16 years old l3lldjustwantto model," he replieci, ,;Don't worry, I Won't tell anybody," court papers say. Epst~in;. saici by London's: M_ail. on $µndc1y to be a clo~e frjenocl o( Englanq's Prince. Andrew, has been. indicted in 'Palm Beach. on charges of soliciting underage. prostitutes. That case is pending.- The girl v:isited Epstein' i•severai times over the several months and engaged in bizarre and unnatural ·sex acts" While she was a minor~ the lawsuit says. Ep~tein "repeatedly reqµ_ested. that_ { the girl) ren,im with hgr J 4-r IS-, and J 6-rear-old gir lfi\~r1ds? stating, !Corne by with'your friends,your age next time, Dori't l5ting Sherrie (a mutual friend in her .40s). Ilove _girls your age.' ;, The young woman, .now 23, kepi' returning to Epstein because. she has "mental issues;" sa:id her lawyer,, Wiiffam J, Unroch. l{e' re(used to eial)orl'lte, bllt court pap~rn say she W,!S ·;; di.sabled as l'l reslllt of severe inental disease and defect.'' Epstein's lawyer in. New York, Qeralci _Lefi~oµ11; safcl, "Th~ gi_rL_h,!s ac;ln;i.itted she is insane, btJt she can read a newspaper and tecognize·the word 'rich.'!' Lefoourt ;also. 1said, the statute of limitations has,'e}{pir.ed for the woman's case criminally cJJ1d civilly, and will almost certainly be dismissed . . He refused-tocommeI1t:onEpsteih's Florida Gh$:ges. Meanwhile, Urrroch, 57, also acknowledgedthat his client was li.v.ing with him and was at the center of a $10 m"illion lawsuithe filed. last ye_ar against a neighbor who saici h_e was.:havipg sex with· underage girls. That case is pending. "What she was doing af 221s irrelevant to what happened to her when.she w~s 16·, 11 Unroch said Wednesday. He went ori the say he.hoped Epstein would agree to "do tight" by his tliertt.and.resolve the case out of court CA/ Aronberg-000177 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM The Palm Beach Pest REALNEWSSTARTSHERE Palm Beacher pleads in sex case: Posted Jul 1,2008 at 12:01 AM Updated Oct 3,2019 at 1:47 PM (EDITOR’S NOTE: This story originally published in The Paint Beach Post onJuly 1, 2008) Jeffrey Epstein will serve 1 1/2 years on teen solicitation charges. He lives:in a Palm Beach waterfront mansion and has kept company with the: likes of President Clinton, Prince Andrew and Donald Trump, but investment bankerJeffrey Epstein will call the Palm Beach CountyJail home for the next 18 months. Epstein, 55, pleaded,guilty Monday to felony solicitation of prostitution and procuring a person under the age of 18 for prostitution. After serving 18 months in jail, he will be under house arrest for a year. And he. will have a lifelong obligation to register as a sex offender; He must submit to an HIV test within 48 hours, with the results being provided to his victims or their parents. As part of the plea deal, federal investigators agreed to drop their investigation of Epstein, which they had taken to a grandJury, two law enforcement sources said, Epstein was indicted two years ago after an 11 -month investigation by Palm Beach police; They received a complaint from a relative of a 14-year-old girl who had given Epstein a naked massage, at his five-bedroom, 7,234- square-foot, 38; 5 million Intracoastal home. Police concluded that there were several other girls brought in 2004 and 2005 to an upstairs room at the home for similar massages and sexual touching. CA/Aronberq-000178 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY .. ltaltn :B·e.·a:cbe,r: p_l~ads ln sti '.;~~ie~ Po:st~d Jul 1, 20Q8 at 1_2:01 AM Updated Oct 3, 2019 at 1:47 PM (EDITOR'S NOTE; This ~_tory originally published in Th~ Palm Beach. Post onjuly-1, -2008) Jeffrey Epstein will serve J 1 /2 years on teen solicitation charge,s. He Hv~s:in a PalmBeachwat~.r_fr9~t rnansiQn: ~9 J:.ia,~ kept companywith ·the· iikes of President Clinton, Prince Andrew and Donald Trurnp;hutihvestment oankerJefftey Epstein will fall th_e, Palm Beach County Jail home- for the n:ext 18,months. Epstein, 55, pleacfod guilty Monday to felony solicitation of prostitution andproturing a petsoh under the age of18 for prost_hvtjo.n,. After s~iyjng 1 $ Jnont_hs in 'j~l, he will be under house ·arre,s_t for a year. And he,wi11 have a lifelong_ obligation to re~ister asa sex offendet, He must submit to a,n HIV test within 48 hours, with the results being provided to'his victims or their pc1,rents. As part of the plea deal, federal investigators agreed to drop their investigation of Epstein, which they had taken, to a grand.jury, two law enforcement sources s:iid, Epstein wa:s indfoted two years ago after an ii-:mon:th investigation by Palm 'Beach poiice, They received -a coro.plai.ntfrom arelad've of a 14-year,,,;old girl who had_ given_ Epstein a na_ked massage at hi_s _flve-pedroom, 7~2:34- square_,foot, $8,5 million Intra-coasta:i home. Police concluded that ·there were several other- _girls br6tight in 2004 a,nd 2005 to an upstairs room at the home for similar-massages a,nd sexual touching. CA/Aronberg-000178 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM The indictment charged Epstein only with felony ; solicitation ofprostitution. The state attorney’s office later added the charge ofprocuring underage girls for that ' purpose. Prosecutor Lanna Belohlavek said of the plea: “I took into consideration the length the trial would have been and witnesses having to testify” about sometimes embarrassing incidents. Epstein may have made a serious mistake soon after he was charged. He rejected an offer to plead guilty to one count of aggravated assault with intent to commit a felony, according to police documents. He would have gotten five years’ probation, had ho criminal record and hot been a registered sex offender, the documents indicate. Epstein arrived in court Monday with at least three attorneys. He wore a blue blazer, blue shirt, blue,jeans and white and gray sneaker's. After Circuit Judge Deborah Dale Pucillo accepted the plea, he was fingerprinted. Epstein then removed his blazer and was handcuffed for the trip to jail while his attorneys tried to shield him from photographers’ lenses. When he eventually is released to house arrest, Epstein will have to observe a 10 p.m. to 6 a.m. curfew, have no uhsupervised contact with anyone younger than 18 and neither own nor possess pornographic or sexual materials "that are relevant to your deviant behavior,” the judge said. Epstein will be allowed to leave home for work. The New York-based money manager told the judge he has formed the not-for-profit Florida Science Foundation to finance scientific research. "I’m there every day,” Epstein said. The foundation was incorporated in November. Epstein said he already has awarded money to Harvardand MIT. CA/Aronberg-000179 FILET): PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY The. indictment charged:Epstein only with felony solicitation ofprostitution. The state attorney's office l~te:t a,dded the chc1.rge of procuring underage: girls for that 1 purpose. ProsecJ.1tQr La·nna B:efohfavek said pfthe.:plea; ''i to·ok iJ:l;tq considetatiort the length the -trial would have been ancf witnesses having·to testify" about sometimes enibarrassing incidents. Epstein may ha:ve made a serious rriislake ssoon after he was charged. He rejected an: offer to plead gt1iltyto one count of aggr.iya,~ed a_ss~ult-wi.tl:i i_ntent to cgmmit a felony, according to police do.cum en ts. :He would have gotten five years' ptobatioh, had ho criminal.record and hot been a registered sex offerrder! the documents indicate. Ep~tein arrived .iff court Monday with at least three attorneys. He wore a blue blazer, blue shirt, blue jeans and white and gtay sneakers. After Circuit Judge Deborah ,Dale Puc:Ulo aq:epted the plea, he was fingerprinted. Epstein thenremoved.his blazer and wc1.s handcuffed for-the tiip to jail while hiini:ttorneys tried to· shield him from photographer{ lenses. When he. eventuaHy i$ releasedto house arrest, Epstein will have toobserve:a.l0 p,m. to 6 .a.rn.(mrfew, have no unsup.etvised contact with anyone younger than 18 a:nd neither own nor possess pornographic or sexual materials ·"that are relevant to your d.evian.t behavior/' the'ju_dge said. Epstein will be allowed to leave home for'work. The New York-based money manager told the judge he has formed the 1wt-for-p_rofit-Florid,a. Science~ Fo1Jnci:1J10J1. to· financ_e scientific research. "I'm there every day," Epstein said. The foundation was incorporated in November. Et:fstein ~aid he already has awarded money to Harvard and MIT. CNAronbe.rn_-000179 FILETI: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM When he is released.from jail, there is a chance that Epstein will be forced to move. Sex offenders are not allowed to live within 1,000 feet of a school, park or other areas where children may gather. No determination has been made as to whether Epstein’s home complies, but attorneys said it likely does. Sex offenders also typically must attend counseling sessions. Belohlavek said that was waived for Epstein because his private psychiatrist is working; with him. The judge was skeptical but agreed to it. Epstein’s legal woes don’t end with Monday’s plea. There are four pending federal civil lawsuits, and one in state court related to his behavior. At least; one woman has sued him in New York, where he owns Manhattan mansion. “It’s validation ofwhat we’re saying; in the civil cases,” said Miami attorneyJeffrey Herman, who represents the alleged victims in the federal lawsuits. West Palm Beach attorney Ted Leopold.represents one alleged victim in a civil suit in state court. He said he anticipates amending that lawsuit to add “a few other clients” as well. In the criminal case, police went so far as to scour Epstein’s trash and conduct surveillance at Palin Beach International Airport, where they watched for his private jet so they would know when, he was in town. They concluded that Epstein paid girls $200 to $’300 each after the massage sessions. Tm like a Heidi Fleiss,” Haley Robson, now 22, told police about her efforts, in recruiting girls for Epstein. There was probable cause to charge Epstein with unlawful sex acts' with a minor arid lewd arid lascivious rnolestation, police concluded. CA/Aronbera-000180 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY When he is released.from jail, there is a chance that Epstein will be forced to move. Sex offenders ·are hot allowed to live within 1,900 f~~t qfa s_c)109l, P?-fk qr ()tll,~r are?-s·where children may gather-. No· determination has been made as to whether Epstein'.s home complies~ but attorneys. said it· likely does. Sex offenders also typkally111,usr attend coun~eling ~ess}ons. Belohlavek:said that was waived for Epstein because his private psychiatrist is working· with him. The judge was skeptical but agreed to it, tpsteh:1' s Jegal w9es dpn't e119 with 'M()nd,:iy' s ple.il., Ther~ are four :pertdirtg federal civil lawsuits and one in state co.urt related to- his behavior. At least one ,vomafi has sued him in New Y oik, whe_re .he owns a. Sl,000-squ.are-foqt fylgnhatta,n mansion. "It's validation ofwha:ewe're sayinKin the civil cases;_".said Miami attomeyJeffr-ey Hetman, \~ho represents the alleged vic;tims i]) the federaJ la,wsuits. West l: alro 13each attorney Ted Leopold represents one alleged vidim in a civil suit in state court. He said he anticipates amending tha:rlawstiit to adcf"afew other c:lie1,1ti(,:is w~ll_. In the criminal case, police went so tar as to scoµr Epst~"i'n's trash and conduct ·surveillance at Pal:tn Beach Intetnationai Air.port, ·where they Watched for. his private jet so they· would know when. he was in town. They concluded that Epstein paid girls $:200 to $300 each atter the massage sessicm·s. 'Tm like a, Heidi fl~iss," Haley Robson., now 22, told police abou.ther efforts in recruiting girl's Jor Epstein. There was p·roba:ble cause to charge Epstein with unlawfoi sex acts with a minor and lewd an:d lascivious molestation, police cond1,1ded. CA/ Amnberg-000180 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM The state attorney’s office said questions about the girls' credibility led it to take the unprecedented step of presenting the evidence against Epstein to a grand jury, rather than directly charging him. Palm Beach Police Chief Michael Reiterwas furious, with State Attorney Barry Krischer, saying in a May 2006 letter that the prosecutor should disqualify himself "I continue to find your office's treatment of these cases highly unusual/’ he wrote. He then asked for and got a federal investigation. Epstein hired a phalanx ofhigh-priced lawyers - including Harvard law professor and author Alan Dershowitz - and public, relations, people who questioned Reiter's competence and the yictims’ truthfulness. In addition to mansions in Palm: Beach, and Manhattan, Epstein owns homes in New Mexico and the Virgin Islands.. He's a frequent.'contributor to Democratic Party candidates; He also donated $30 million to Harvard in 2003. Former New York Goy. Eliot Spitzer returned a $50,000 campaign contribution, from Epstein after his indictment, then resigned this year during ^his own sex scandal. And the same Palm Beach Police Department that vigorously investigated Epstein returned his $90,000 donation for the purchase of a firearms simulator. Staffwriter Eliot Kleinberg arid foririer.staff researcher' Michelle Quigley contributed to this story. CA/Aronbera-000181 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY The state attorney's office. sa.id q:uestions about the _girls' credibility l~d it to take the unprecedented step of presend.ng the e_vid~nc:e'. ;igiJcins,t Epsteh1 to a ,g_rMcl jll_ry, rather than-directly chargi'n:g him. Pa.Im Beach Police Chief Michael Reiter-was flirioµs_ with State Attorney'Barry Krischer,saying ina May 2006 le~tet that the prqsecutor sholJ}d d1squ;ilify himself "I c::ontimie to find yout office's treatment c>fthese cases highly unusual'," he wrote. He then asked fonmd got a..federa.l investigation. Epst~in hired a phalanx of high-prited lawyers - including Harvard law professor cJJ1d allth9r Algp. bers_l).qwit:z: - and p"t1blit relatio-ns. people who que•stioned Reiter's .competence an_c;l the v,i_c;:tim~' truthfulness. In ad~iti.on to ma,n_siQ]J._s fo ;Palm BecJ.ch, and Manhattan, Epstein owns homes inNew Mexico,and th~ Virginlsl_ands,; He's a frequent:tontributor to Demotta:tic p·a:rty candidate's". He a.l__sq· dc:m_ated· $30 milHon lo Harvard in .2003. Forll_ler N_gw Y9_r:k Gov. Eliot Spitzer retw.J1~d a, $~Q;0Od carn,paign contribution from Epstein a.tter his irnHct1I1_ent, then resigned this year during:his oWh sex se::andal. And the ScJ,JP..e Palm ;Beacp. P9lice Department that vigorously investigated Epstein returned 'his $90,000 donation for.the purchase of a firea.rtns si'i:nulator. Staff writer Eliot Kleinberg and fotmet ,staffresea.tchet· Mi.~heUe QtJigley contributed to t_his story. CA/Aronberg-000181 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 'The Bata Beach Post REALNEWSSTURTSHERE Jeffrey Epstean: Scientist, Stuntman, ‘sex shve’ visit jailed tycoon By LARRY KELLER / Palm Beach Post Staff Writer Posted Aug 13,2008 at 12:01 AM Updated Jul 16.2019 at 4:54 PM TycoonJeffrey Epstein, mingled with ah eclectic mix of people, including beautiful young women, before he got into, trouble for paying: teenage girls to give him sexual massages at his Palm Beach mansion.- Not much has changed, even though he how resides in a dorm at the Palm Beach County Sheriffs Office’s 17-acre, 967-bed stockade near the fairgrounds. During his first month,of confinement, Epstein was visited by the female assistant who, girls told police, had escorted them, to the room at his mansion where they gave him naked massages. Also trekking to the jail was a young woman whom Epstein purportedly described as his Yugoslavian sex slave. The wealthy financier and science wonk also has been visited by an expert on artificial intelligence, as well as a man who is a mixed martial arts aficionado and sometime movie stuntman. The only other people to visit.him at the jail, according to records, are a Singer Island, man and an individual who listed Epstein’s Palm Beach, address as his own. Epstein, 55, pleaded guilty onJune 30 to two prostitution- related charges and was sentenced .to 18 months in jail, followed by a year of house arrest'. Epstein paid teenage CA/Aronberg-000182 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY lef:fre·-; E' :slein: Scienlisl . ' )J ·- p ... -· --. -.. - . -- . .. ' stuntm-an', '·stot slalltf visit j'.a'iled: ty1;0-0J.l, ey· LARRY KELLER/ Palm Beach Post Staff Write'r Postea Aug 13, 2008-at 12:01 AM Updated Jul 16, 2019 .at 4:54 PM Tycoon Jeffrey Epstein mingled with ah eclectic mix of people1 including beautiful young women! before he got into trouble for paying teenage: girls to give him s_exual massages at his Palm. Beach mansioh., Not much has changed; evert, th6ugh he now resides in a clorm ;it the I\1hp l:3ea,~h <:o\!Il.ty Sh_~riff s Offic;e's 17-;iq~, 967-bed stockade near-the- fairgrouncls. During his first month. of confine-ment~ Eps_tein was visited by the female assistant ·who, $ids told polfte, had escorted them.to the room:at.his m,a11siQil where they:g.:!-ve h1_:rri naked massages. Also trekkin~ to the jail was a young·woman: whoin Epstein purportedly described as .his Yugoslavian ;sex slave. Thf wealthy finail~ier a.nd sc;iepce wqn,l{ .also J1as- l:ieen visite:d .-by an expert on artific_ial intelligence, as well as a mat1 who is a •mixed martial. arts aficionado and sometime rnovi~ stµntman: .. The only other people to visit him at the jail, 3,ccording to re·cords, are a Singer Island, man and an indivic:luaf who listed Epstein's Palm Beach. address as his own. Epstein, 5$, pleaded guilty onJune 30to two prostitution- related charges and was SC:!ntenced .to 18 months. in jail, followed by·a year of house arrest~ Epstein paid teenage CA/Aronberg~000182 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM girls $200 to $300 in 2004 and 2005 for massages in his home that sometimes included sexual touching, Palm Beach police said. His jail visitors in Julyincluded: - Sarah Kellen, 29, who some of the teen masseuses said phoned them when Epstein was in town and escorted them upon their arrival at his Palm Beach waterfront home to an upstairs room, where she prepared.the massage table and provided, the oils for their encounters with him. Kellen visited Epstein three times in July, according to a jail visitor’s log. Kellen lists a Manhattan home address. Reached by telephone, she declined to discuss Epstein. - Nadia Marcinkova, 23, whose family in Yugoslavia Epstein paid money to so that he could bring her to the United States to be his “sex slave,” two teenage girls told police. One. girl told police that Epstein instructed Marcirikova arid her to kiss and have sex while he watched and masturbated. Another said she engaged in sex with Marcinkova at Epstein’s urging. Marcinkova visited Epstein in jail four tirries in 13 days. She lists her address as on the Upper East side of Manhattan, not far from Epstein's enormous apartment. - Roger Schank, 62, founder of the Institute for Learning Sciences at Northwestern University and art expert On artificial intelligence, paid one visit to Epstein. Schank has written numerous books on that subject and has a doctorate degree fforri Yale University in linguistics; He was one of 19 people who applied to be president of Florida Atlantic University in 2003. He became“chieflearning officer” at the online Trump University in 2005. Schank.listed his address as being in Stuart, and records show he also owns a home in Lake Worth. CA/Aronberg-000183 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY .;- girls $200 to $300 irt 2004 and 2005 for massages in his home. that sometimes included sexual touc:hing, Palm Beach pol_ice. s~id. Bis. ja,jl vis_itors jn,Jµly{nclu.qecl: - Sarah Kellen, 29, wh_Q some 9f the teen masseu_ses sa.'I~l phoned them when Epstein was in town a:nd es_corted them upon their arrivaiat.hisPalm Beach waterfront home to-an t1pstairs.r:9o_m, whe,re· sh_e prepar:ed the Jil~ss._age t_a_ble aIJ,d provided the oils for their encounters with him, Keilen visited Epstein three times iriJuly; ac:coraing. to a: jail visitor's log. I<ellen lists· a Manha.ttan borne address .. Reached by telephon·e, she declined to· d1scuss Epstein. - Nadia Marcinkova1 23, whose family in Yugoslavia Epstein paidmoneyto so that he could bring her to the United States to· be his "sex: sla.,ve;" two teenage girls· tplci police. One. gitl told :polite that Epstein instructed. Marciriko:va a:rtd het to kiss and have sex while .he watched and mastur:pated. ,Anot_her said she engaged i.IJ, sex. witl:i Marcinkova-at Epstein's urging, Marcinkova visited Epstein in jail four times.in 13 da:ys. She-lists hetaddte·s·s as on the. Upper 'East ,si_de of Manhattan, not far from Epstein\ enormous apartment. - Roger Schank, 62, founder of theJnstitute for Learning Sciences at Northwestetii University and an expert on artificial 1.ntelligence, paid one visit to Epstei.n.. Schank has writtennumerous books on'fh•at subject and has a doctorate degree from Yale University in linguistics: He·was one o'fl9 p_eople who appliecl to be pi;esi(jent ofFloi:ipa, Atlan.ti.c University in 2003. }-Ie became;, chiefiearning officer'; _at the onliiieTrilltlp University in 2005. Sc.hank]isted his address as beingfo Sn1art~ md records ~how he al~o owns a .. home .in Lake Worth, CA/Aronbe.m.-000183 FILEU: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM Epstein has financed a number of scientists over the years, including Nobel Prize winners. He gave $30 million to Harvard University in 2Q03. In November, he: formed the not-for-profit Florida Science Foundation, which he said finances scientific research. - Igor Zinoviev, a Russian mixed martial arts fighter, who coaches a Chicago team in the International Fight League, He also has worked as a personal trainer,, celebrity bodyguard and movie stuntman, according to the league’s Web site, The NewJersey resident visited Epstein seven times in July. Zinoviev, Schank and Marcinkova could not be reached for comment, Staff researcher Niels Heimeriks. contributed to this stoty: CA/Aronberg-000184 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY Epstein has financed a number of scientists over the years, including Nobel Prtze winners. H~ gave$30 IIlillJon to: Harvard University in 2003. In November, he: formed tpe hot-for-profit Florida Science Foundation, which he said finances scientific research. - lgpr Zinpviev, a Ru~sian .mixed rnartial arts fighter, who coaches a Chicago· teaITI in the Inte:rn:atio_nal Fight L!;!agµ,e. He also has worked as a personal trainer,. celebrity body,g\lard and 111ovie stuntman1 according to the league's Web site. Th!;! New J~r~ey resident: yi~itedEp~t~in seven times irtJuly. Zinoviev, Stharik and Marcinkova could rtot be r.eached for c.omrne_nt. Staffresearcher Niels Heim~riks. contdbut_ed to this ~tory: CA/ Aronberg-000184 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM Palm Beach DailyNews Billionaire sex offender leaves jail six days a week for work Posted Jul i, 20,08 at 12:01 AM Updated Oct 4,2019 at 9:27 AM Palm Beach billionaire Jeffrey Epstein, who’s serving 18 months, in jail for soliciting an underage girl for prostitution, is allowed to leave the Palm Beach County Stockade six days a.week on a work-release program. Teri Barbera, spokeswoman for the Palm Beach County Sheriffs Office, confirmed that Epstein, 55, has been in the work-release program since Oct. 10. "He works six days a week: Friday through Wednesday 10 a.m. to 10 p.m.,” Barbera said via e-mail. ”(He) works at his local West: Palm Beach office, monitored on an active GPS system (he wears an ankle bracelet), Mr. Epstein hires a permit deputy, at his expense, for his own security at his workplace during the time he is out." Miami attorneyJeffrey Herman represents six young women who’ve sued Epstein, claiming he sexually abused them at his Palm Beach home when they were minors. Herman said he received a letter about the work-release program from the U.S. Attorney’s Office within the past few days. But Herman says Epstein had,been, out on work- release for several weeks before the notification. “My clients expressed shock and disappointment,” Herman said. “I find it incredible that he’s on work-release in the community and my clients aren’tnotified ofthis and we get this letter weeks after the fact.” Jack Goldberger, Epstein’s criminal attorney, said the CA/Aronberq-000185 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY BUlbuiair, s111 offPnd:Q~ .IQa.v,sJa:il six :da .. s a;··wee:kJrir \w_ork ................... ¥ ........... .' .............. ·-- -····· , ....... . Posted Jul 1, 20.08 at 12:01 AM Updated Oct 4, 2019 at 9:27 AM Palm ~ea,ch bi.1Honc1ire Jeffrey J;pstein,. who's serving 18 months.'in jail for soliciting an underage girl for prostitution, .is allowed to leave the Palm Beach Cou,11ty StocJ<,ade s.µc da,ys. a. weekon ~ w9_rk-relea,se program. Teri B,arb_era, spokeswoman fof'the Palm .BeaGh County Sheriffs Office, confirmed that Epstein, 55; has been irt the work-release program since Oct. 10. "Hg works six days ·a week: Friday through W ednesdc1y 10 a.m. to 10 p.m.;'.' Barbera: said via e-ma:il. "(He) works at his local West Palm Beach office, monitored on ah active GPS system (he wears an ankle bracelet), Mr. _Epste.in. hires ·c1 peflll{t ,depucy, at his expense, for his own se~urity ·at his workplace durini; the time he is out-." Miami attorney Jeffrey Hen:nan represents six-young women wbo1ye ~ued Epsteip., c;l;µming he $e)wc11ly abused: them athis Palm 13.eac:h home when they were minors. Herrrian said he received a: letter about the work..:release program from the U.S. Attorney's Office wit4m the·past few dc1ys. B\lt' H~n;nan says Epst~in had. heel) O\lt on. work- reie·ase for several weeks before the notificatio11. "My clients expressed s.hockand disappoiIJ,(ment," H~rma,n said. "I find it in-credible that he's ort work-release ih the community and my clients areil;t notified of this and we get this letter weeks after the fact." Jack Goldberger,, Epstejp's crirni11al a,tto,rn~y, s~id the CA/Aronberg-000185 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM arrangement is not unusual. "He goes to work,every single day and goes back to jail at night, just like everybody else (in the program),” Goldberger said. Epstein pleaded guiltyJune 30 to two felony counts: soliciting prostitution and procuring a person under 18 for prostitution. As part ofthe plea agreement, Epstein must serve one year Of house arrest and register as a lifelong sex offender. CA/Aronberg-000186 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY arrangement is not unusual. "He goes to work every single, day an-d goes back to ja,il at ni~ht, justlike everybody else (in the pro~tam}," Goldberger said. Epstein pleaded g_uiltyJune 30 to two felony cotlilts: soliciting prostitution and procuring a: person U;I1der 18 for· prostitution. As part of the plea agreement, Epstein must setve·oneyeat of house arrest and register as a lifelong sex of{en<:le.r. CA/ Aronberg-000186 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM The Palm Beach Post REALNEWSSTARTSHERE Women want; Epstein sax plea deal unsealed' Posted Jul 1, 2008 at 12:01 AM Updated Oct 2,2019 at 2:23 PM (EDITORS NOTE: This story originally published in The Palm Beach PostJune 10, 2009) Their attorneys will ask a judge to open Jeffrey Epstein’s records. When wealthy money manager Jeffrey Epstein of Palm Beach pleaded guilty last year to procuring teens for prostitution, his case detoured around local and.state rules regarding the sealing of court documents. At a plea conference on the state charges, a judge, a defense lawyer and. a prosecutor huddled at the bench and decided that a deal Epstein had struck with federal prosecutors to avoid charges should be sealed, according to a transcript of the hearing. And so it was. But Florida rules ofjudicial administration,, as well as rules of the Palm Beach County court system, require public notification that a court document has been or will be sealed,, meaning kept from public view. The rules also require a judge to find a significant reason .to seal, such as protecting a trade secret dr a compelling government interest. Yet no notification or reason occurred in Epstein’s case, according to court records. CA/Aronberg-000187 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY :women.1 w;anl Epsl1ih s~lt ple_a. dtal unseaJed' Posted Jul 1, 2'008 at 12:01· AM Updated Oct 2, 2019 at.2:23 PM (EDITOR'$_ NOTE: This story originally publishe,d in The Palm Beach Post June 10, 2009)' Their: attorneys will ~s,k a jµdge to open Jeffrey Eps.tein's. records. When wealthy money manager Jeffrey Epstein of Paim Beach pleaded guih:ylast year to procuring teens for pros_titution, h1s. case d_etour~d aro:µ»dJq<:al a,ndstate rules regarding tne ;sfaling of court do_cume·nts. At a: plea conference on the state chars.es, a judge, a defense lawyer and.a prosecutor huddled at the bench and decided that a, dgal Epste111 ha:d stru<:k wifu federal prosecutors to avoid charges should be sealed, according to a. transcript of the heating. A.IJ.d so it Wa$_. But Flor:ida rul.es ofj1Jdicial administr:ation, ~ well as rules of the Palm Bea.th County c◊urt sys.tern, require public notification that a: court documentha:s been or will be seakd,:meaningkeptfrom pµblic:: view_. The nµes . .i1s,g· require a judge to· firrd a significant reason. to seal, such as protecting a.trade secret or a compelling government interes,t. Yet no notific_ation or reason occurred in Epstein~s <:ase~ according to court record~, CA/ Aronberg-000187 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM Epstein’s own attorneys, in federal filings, have referred to his confidential deferred prosecution agreement with the U.S. attorney’s office, struck in September 2007, as "unprecedented” and “highly unusual/’ And. it was "a significant inducement” for Epstein to accept the state’s deal, observed the state judge who accepted his plea, Countyjudge Deborah Dale Pucillo. Epstein,now faces at least a dozencivil lawsuits in federal and state courts Filed;by young women,who said they had sex with him and now are seeking damages. Attorneys for some of those women want his agreement with federal prosecutors unsealed and.will ask Circuit Judge Jeffrey Colbath to do so today. "It is against public policy for these documents to be have been sealed and hidden from public scrutiny.. As a member of the public, E.W' has a right to have these documents unsealed/’wrote former CircuitJudge Bill Berger, now in private practice arid representing one of the women. The Palm Beach Post also will ask Colbath to unseal the agreement., Post attorney Deanna Shullmari will argue that the public has a right to know the specifics of Epstein’s deal-.. According to various media accounts, Epstein moved in circles that included President Clinton, Donald Trump and Prince Andrew. “International Moneyman of Mystery/’ declared a 2002 New York magazine profile of Epstein. Epstein, 56, is in the Palm Beach County Stockade, serving an 18-month sentence: after pleading guilty nearly a year ago to felony solicitation of prostitution and procuring teenagers for prostitution. He is allowed out from 7 a.m. to 11 p.m., escorted by a deputy, said Palm Beach County Sheriffs Office spokeswoman Teri Barbera. CA/Aronberg-000188 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY Epst~in's own atto_rneys,. in .federai filings, have·referred to his contide-ntial deferred prosecution a~teertieht with·the U.S. attorney's office; struck in Septerriber 2007, as "unprecedented" and "highly Qnusu.al." And it was "a significant inducement" for Epstein to acc~pt the state'.s deal, observe:d the state judge who accepted his plea; CountyJudg.e Deborah Dale Pucillo. Epstein.now faces at least 8,- d,oz_en. civil lawsuits in federal aI1,d sta,t~ courts tiled. by young women. who said t:hey·h-ad sex with him and now are seeking damages; Attorneys for some of those women want his a,gre~r.nent with federal proseQutors :imsealed .and will a:sk CircuitJudge Jeffrey Coibath to do so today. ,ilt,is against public policyfot these dotumen:ts to be have been sealed and hidden from public scru~in.y.. As a mgmber of the,public, E. Wi has a right to have _these documents unsea:le·d/ wrote former CircuitJudge Bill Bet~e'f, now in private practice and representing one ofthe women. Th~ Palm Beac.h Post also will a,sk Colb.:ath tp unseal the agr,eement.,Post attomey:Oea:nna Shullman will argue that the public has a: right to know the ~pecifics of Epstefn's cleal. According to various meciia accotJ.nts, Epstein moved in cfrcles th_at: 111ch.1,dep :President Clinton, Donald Trump and Printe Andrew. 'Tritetnatiortal Moneymari 6f Mystery;" declared a 2002 New York m:i.gazii:re profil~ of Epstein. Epstein, Sp, 'is in the Palm Beach County Stockade, s.erving _an 18-rnonth sentence after pleading· guiity nearly a year ago to felony solicitation of prostitution and proc;uring teenagers fqr: prostit11don. He is allowed out from 7 a.m. to U p.m., es.corted by a deputy, said ·Pa:lm Beach County Shetiff s Office· spokeswoman Teri Barbera. CA/ Aronberg,.Q00 188 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM During a Palm Beach .Police Department investigation,'five victims and. 17 witnesses gave statements. They told of young women brought by his assistants to Epstein’s mansion on El Brillo Way for massages and sexual activity, and then being paid afterward. At Epstein's plea conference last year, his attorney, Jack Goldberger, and then-Assistant State Attorney Lanna Belohlavek approached Pucillo in a sidebar conference. Pucillo, who had left the bench nine years earlier, was filling in temporarily as a senior judge. According to a transcript, Goldberger told Pucillo: that Epstein had entered a confidential agreement with the. U.S. attorney’s office in which federal prosecutors brokered not pursuing charges against him if he pleaded guilty in state court. Pucillo then said she wanted a sealed copy of the agreement filed in his case, and Goldberger concurred that he wanted it sealed. Belohlavek later signed off on it. The Florida Supreme Court has expressed '‘serious concern" arid launched an all-out inquiry into, sealirig procedures across the state following media reports in 2006 of entire cases being sealed and disappearing from court records. “The public’s constitutional right of access to court records must remain inviolate, arid this court is fully cornrhitted to safeguarding this right,” justices wrote in their final report. Epstein’s office on Tuesday referred any questions to Goldberger, who declined to comment. Pucillo also has declined to comment. CA/Aronbera-000189 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY During a Palm Beach .Polite Department investigation/ five victims and. 17 wit11esses gave stateinents, T~ey fol~ qf young wpmen brollghtby his assis_ta,11ts to EP,stein's mansion on 'El Brillo Way for massages and sexual activity, and thert being paid afterward. At Epstein's plea conference last year! his attorney,Jack Golq.berger,, and then-Assistant St~te Atto.rney Lanna Belohlavekapptoached Pucillo in a sidebar tonfe'tehte. Pucillo, who hadleft the bench nine years earlier, was fillil!g i_n tem,ponirUy as a, senior judge. Accqr:ding to a transcript, Go1dbe;r:ger told P.ucilto that Epstein had ehte~ed a confidential agteei:rteht with the, U.S. attorney's offic:e :in wlJJch (ed,eraJ pr:osecµtor_s 1?.rokere<;i' not pursµing charge·s against him ifhe pleaded guifry: in s_tate court. Pucillo then said she wanted a se·aled' copy of the agreement filed in his case, and Goldberger concurred that he wanted it seale-d. Belohlavek later signe·d off on it. The Florida S,up,rerne Court has expressed "serious concern" and launched an all-out inquiry into. sealing procedures across-the state following media r~ports in 2006 of entire cases ·being. sealed and disappear:ing from court records. "The public's tOnstittitiOha.l right ofactess to c·ou:rt 'records must remain inviolate, and this court is folly committed to safeguarding:this .right/' justices wrote in their f~nal report. Ep~tem' s office· on Tuesday refrrred any questi'ons to Goldbetger;-who dedinecI to comment. Pucillo also has: declined to comment. CA/ Aron berg-000189 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM The Mm Beach Post MkIwWe I Epstein secret,pact withMs reveals “highly unusual” terms Posted Jun 10,2009 at 12:01 AM Updated Oct 4,2019 at 9:23 AM (EDITOR S NOTE: T7iis story originally published in The Palm Beach Post on September 19, 2009) A secret non-prosecution agreement multimillionaire financierJeffrey Epstein struck with federal prosecutors is being called “highly unusual” by former federal prosecutors and downright outrageous by attorneys now representing young women who serviced him. The deal reveals that the FBI and the. U.S. Attorneys Office investigated him for several federal crimes, including engaging minors in commercial sex. The crimes are punishable by anywhere from 10 years to life in prison. But federal prosecutors backed down and agreed to recall grand jury subpoenas if Epstein pleaded guilty to felonies in state court, which he ultimately did. He received an 18-month jail sentence, of which he served 13 months. The U.S. Attorney’s Office also'agreed not to charge any of Epstein’s possible co-conspirators: Sarah Kellen, Adriana Ross, Lesley Groff and Nadia Marcinkova. The deal was negotiated in part by heavyweight New York criminal defense attorney Gerald Lefcourt, Unsealed on Friday after attorneys for some of Epstein’s victims and The Palm Beach Post sought its release, it offers the first public look at the deal Epstein’s high-powered legal counsel brokered on his behalf. CA/Aronberg-000190 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY .Ep:sfdirt se.9};ret.i.Plf;l wil.hA ff)d'.s teveals "hJ 'ht·; :un11,stud" terms .. - - g _y - - --- - -- - Posted Jun 10, 2009 at 12:01 AM Update_d Oct 4, 2019 at 9~23 AM (EDITORjs: NOTE: This story originaJly p_ublfsbe_d {n 'fh_e Palm Beach Postiin September 19, 2009) A sec:ret n_qn-prosec;utiqn a_greement multimillionaire financier Jeffrey Epstein struck ·with federal prqsectttor~ is being_ called "highly unusual"· hy fohn.er federal :prosecutors ~ng doWI1,right 9utrageous by attorneys now representing young women who: serviced him. The d·eal reveals thatthe FBI artdJhe lLS. Attorney's Office investigated him for several foderal triines, indudin~ engag_ing minors tn commercial .sex. The crimes are punishable by anywhere from 10 years to life in pd.son. But federal pr.osecutors ba~ke.d down and c1greeci_ to recall grand jury subpoenas if Epstein pleadedg:uiJtyto pros_dtution:-reh1ted feJ9nie$ 1n state, court; which he ultimately did. He received :an: 18-mqnth ja_il sentence, of which he served 13 months. The D.S. Attorney's Office ahro•agreed i16tto that~eanyof Epstein's possible cq-conspiratqrs: s·c1_ra_h Kellen, Adriana Ross, LesleyGro'ffand. Nadia Ma:rcinkova. The deal was negotiated. in parfbyheavyweight New York crimin~ defe,nse att9rney Ger3,ld Lefcourt, Uns,ealed on Friday after ;ittorneys fqnorn.eof Epsteil)'.s victims and The Palm B,each Po.st. sought its. r:eieas_e, it _offers the first public look at the deal. Epstein's higli:'-poweted legal counsel prolcered on hf~ pe):i~lf. CA/ Aronberg-000190 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3/27/2023 2:57:43 PM MarkJohnson of Stuart, a former federal prosecutor., described the disparity in potential sentences as unusual, But even more so; a provision bn attorney payment. The first draft of the agreement in September 2007 required that Epstein pay an attorney -- tapped by the U.S, Attorneys Office and approved by Epstein -- to represent some of the victims. That attorney is prominent Miami lawyer Bob Josefsberg. But an addendum to the agreement Signed the following month struck Epstein’s duty to payJosefsberg if he and the victims did not accept settlements.-- capped at §150,000 — and .instead pursued lawsuits. Johnson said it appears the government was trying to balance the lesser sentence for Epstein,with recovering §150,000 for each victim, Tve never, ever seen anything like: that in my life," he said. “It’s highly unusual.” The deal does not say whether any victims were contacted of consulted before the deal,was made. Attorney Brad Edwards of Fort Lauderdale, who represents three of the young women, believes' that none of the 30 to 40 woman identified as victims in the federal investigation were told ahead of time. Edwards said his: clients received letters from the U.S. Attorney’s Office months after the deal Was signed, assuring them Epstein would be prosecuted. "Never consulting the victims is probably the most outrageous aspect ofit,” Edwards said. “It taught them that someone with money can buy his Way out of anything. It’s outrageous and embarrassing for United States Attorney’s Office and the State Attorney’s Office.” Epstein now faces many civil lawsuits filed by the women, who are represented by a variety of attorneys. In many, the allegations are the same: that Epstein had a,predilection for teenage girls, identified, poor, vulnerable ones and used CA/Aronberg-000191 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY Mark Johnson ofSt:uart, a former federa:lprosecutor., ' I aesttibed the. disparity in:poterttial sentences as unusual,: but ·even more so, a provision on attorney payment. The first draft of the agreement in September .2007 req:uire<;l th.at Epst_ei,n pay :in ;it_torpgy -- tapped by fue lJ,S_. Attorney's Office and aP,ptoved by Epstein -~ to represent some of the victims. That attorney is prominent Miami lawyer Bob JQsefsberg. But an a:dden:dum to the agreement signed the following month sttuckEpstein'sdutyto payJosefsbetgif he·and!the victims did not accept settlements -- capped at $150,000 -- and _instead pur~ued lawsuits. Johnson said it appears the·goverilinehtwas trying to balance the lesser sentence fot Epstein With recovering. $15(),0dO for each victim_. 'Tve 11ever, eyer seen anythi~g like. that in iny1ife," he said. "It's highly unusual/' The deal does not say whether- anyvittims were contacted or c:orfsulted before the de·at was made. Attorney Brad Edwards-of Fort Lauderdale, who represents three ofthe young worn.en, believes· that; npr1e of the 30 to 40 woman: identified a:s victims in the federal investigation were told ahead. of time. Edwards Said.his dierits-received letters-from the U.S. Attorney'~ Office months aiter the deal. was signe.d, assuring them Epstein would be prosecuted-. "Never consulting the victims is probably-the most Qutrageous asp,ec,tofit;" Edwards said. "Jt. taµgh.t them that someone with mtYney can. buy his way out of anything; It;s outrageous and embarrassing.for United States Attorney's Office and the State Att,orney's Office."· Epstein now faces many civi.Uaw:suits filed by the women, who ate. represented by a variety -of attorneys . .In many, the allegations are the same: that Epstein had a._predilection for teena,ge girls, identified, po·or, Vllln_erable ·ones. anci used CA/ Aronberg-000191 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM other young women to lure them to his Palm Beach mansion. They walked away with between $200 and $1,000. Former CircuitJudge Bill Berger, also representing victims, called the agreement a "sweetheart deal." “Why was it so important for the government to make this deal?” Berger asked rhetorically. “We have not yet had ari honest explanation by any public official as to why it was made ... and why the victims were sold down the; river.” Former federal prosecutor Ryon McCabe described the. agreement as “very unorthodox:” Such agreements, he said, are; usually reserved for corporations, not individuals. “It’s very, very rare. I’ve never seen or heard of the procedure that was set up here,” said McCabe, who has no involvement in any Epstein litigation. “He’s essentially avoiding federal prosecution because he can afford to pay that many lawyers to help those victims review their cases..;. If a person has no money, he couldn’t be able to strike a deal like this and avoid federal prosecution.” The backroom deal with federal prosecutors'is all the more interesting in light ofthe legal powerhouses who have worked for Epstein, including Harvard professor Alan Dershowitz and Bill Clinton investigator Kenneth Starr. Lefcourt is a past president of the National Association of Criminal Defense Lawyers. Epstein’s local, defense attorney, jack Goldberger, issued a statement Friday saying he had fought the release of the sealed agreement to protect the third parties named there. “Mr. Epstein has fully abided by all of its terms and conditions. He is looking forward to putting this difficult period in his lifebehind him. He is continuing his long¬ standing history of science philanthropy.” CA/Aronberq-000192 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY other yo:u,.ng wome-n to lure them tQ his Palm Beach mansion. They walked away with between $200 and $1;000. Fornier Circuit Judge Bill Berg¢r, also representing victims, c;illec;l tb.e _ag~eeme1.1tg "sweetl]:e;rrt deal." "Why yvas it.so important for the government to make this. deal?"Betget askedthetorically, ,;W·e have not yet had art honest explanation by'any public:official as to Whyitwas made .,. :and why the vic;tims were sqld down the. i:iver.'.' Fonner federal prosecutor Ryon :McCabe destribed the. agteefnenr as, ",/ety unorthodox.'.;; S.uch agree1hents, he said, are. usually reserved for corporations, not individuals: "ItJs very, ye_ry r:are~ I've never seeIJ. or hea_rcf qfthe ptocedtirethat was set·uphere,'' said McCabe, who has no involvement in any Ep·stein litigation. "He's essentially avoiding federal prosecution 'because he can afford to pay that many la:wyers to help those victims revie:Wtheit cases."· If a: person has no money, he couldn't be able to strike. a deal like this and avoid federal pr9sec;µtfo_n;" The ba_ckroom deal with feder;il prosecutors· is all the more interesting in li~ht oftnelegal poWethouses who have worked for.Epstein, includirtgHarvard professor Alan D_e:qi_hoWI_t_z and BiU Clintoninvestfgator KemJeih Starr. Leftour:t is a past president of th-e 'National Association of • Criminal Defense Lawyers. Epstein'~ loc~ldefepse attomey,JacR Goldbe,rger, Iss\led a statement Friday saying he:had fought.the release ofthe sealed agreement to protect .the third parties named there. "Mr. Epstel.n ha? fully abided by all ofits terms and c_onditions. He is looking forward to putting this diffku:lt J>eriod in his life:behind him, He is continuing his long- standing history of science philanthropy." CA/Aronberg.-000192 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM The investigation triggered tensions between police and prosecutors, with then-Palm Beach Chief Michael Reiter saying in a May 2006 letter to then-State Attorney Barry Krischer that the chief prosecutor should disqualify himself.. "1 continue to find your office's treatment ofthese cases highly unusual,” Reiter wrote. He then asked for and got the federal investigation that ended in the sealed deal. "The Jeffrey Epstein matter was an experience ofwhat a many-million-dollar defense can accomplish,” Reiter told the Palm Beach Daily News upon his retirement. CA/Aronberg-000193 FILUD: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY The iI1vestigation trigge_r_ed teil~ions between polic;e and ·prosecutors I with then-Palm B.each Chief Michael. Reitrr saying in a: May 2006 letter to then ~Sta:te Attorney Ba.try: Krischer that the chief prosecutor should disqualify himself., "I .c9:rjtinue to find. yo.ur qffice's treatment of these cases highly unusual," Reiter wr.ote. ,He then asked for ,md.got the federal ,investigation that ended in the sealed deal. "TheJeffrey Epstein.mattet:was ah experience ofwha:t a many-milHon-clollar defonse· can accomplish," Reiter told the Palm Beach Daily News upon his retirement. CA/ Aronberg-000193 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 187 / 278 - Wednesday, January 2-7, 2010 Edition: FINAL Section: LOCAL & BUSINESS Page: 3B Source: By JANE MUSGRAVE Palm Beach Post Staff Writer Dateline: WEST PALM BEACH JUDGE RULES EPSTEIN ATTORNEYS CAN SUBPOENA ABORTION RECORDS Tn a decision that could spark, a constitutional, showdown over privacy fights, ajudge Tuesday gave lawyers representing multimillionaire sex offenderJeffrey Epstein the-right to subpoena abortion records from women who are seeking millions in damages from the part- time Palm Beach resident. Palm Beach County Circuit Judge: Donald Hafele said the records could help Epstein rebut the women's claims that they suffered psychological ills after being paid to give him sexually-charged massages at his Palm Beach mansion when they were as young as 14. Hafele told Epstein's attorneys they couldn't go on a fishing expedition. The medical records, he said, can't be sought until the women are asked whether they have ever had an abortion, how many and where. Further, he said, the records would not be made public and might not be admissible during trial. But, he said, since the women claim Epstein, now 57, is responsible for their emotional distress, his attorneys can explore the impact of other events. Medical records, Hafele said, are a better source of information than a person's memory . Attorney Louis Silver, who represents the Presidential. Women's Health Center, a West Palm Beach clinic where abortions are performed, warned Hafele that he was stepping on shaky constitutional grounds. "These records are protected by our, constitutional right of privacy," he said, referring to the Florida Constitution. After the hearing, Silver said an appeal won't be necessary until Epstein attorneys seek the records. In another ruling Wednesday, Hafele also said that videos from depositions in the state cases can't be; released without a cOurt order. The ruling came; after Epstein attorney Robert Critton complained that a video of Epstein being asked whether he had,an "egg-shaped" penis became a youtube.com sensation. It first appeared on The Palm Beach Post Web site. Critton blamed attorney Spencer Kuvin for releasing it. Kuvin said it was public record. The civil suits began mounting after Epstein agreed to plead guilty to two state charges: procuring a minor for prostitution and soliciting prostitution. He served 13 months of an 18- month sentence: As part ofthe deal brokered with federal prosecutors, he agreed not to contest the accusations in the civil lawsuits. He can argue the women don't deserve the millions they are seeking. ~j com CA/Aronberg-000194 F1LH): PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY 187 / 278- Wednesday, January 27,2010 Edition: FINAL Sec;:tion: LOCAL & BUSINESS Page:JB Source: Et~ JANE MUSGRAVE J>alm Beach Post StaffWriter Dateline: WEST PALM BEACH JUDGE RULES EPSTEIN ATTORNEYS CAN SUBPOENA ABORTION RECORDS Th a decision that could spark a constitutional.showdown over privacy tights, a.judge Tuesday gave lawyers representing mµltiniilli_on_aire s_ex of(enderJe,:ffre)' Epstein the-right to subpoena aborti011 records from women ,vho are seeking millions in :damages from the part- timi Palm Beach resident. Palm Beach Coun~y Circuit Judge Donald Hafele said the records could help Epstein rebut the women's claims that they sµ(f.ered psycholog1c:~l ills after being pa1d to give him sexually-charged massages at his Palm Beath mansion when they. ,vere as young as 14. Hafele told Epste'in's attorneys they c·ouidn\ go on a fishing expedition. The medical records, he said, can't' be-soughnmtil the women ate asked whether they have ever had .an abortion, how many and where. Further,_ he sa1d,-the n~cords wouid not be made public and might not lie admissible dUtihg trial. But, _he said, since .the women claim Epste1n, -now SJf is responsfble for their emotional distress, his attorneys can explore the impact-of other events. Medical records, Hafele said, are a better source otinformation than a person's memory. Attorney Loui's Silver, who tepres·ents the .Presidential. Womeh1s Health Center~ a West Palm Beach clinic where abon:ions are performed, wamed flafele that'b:e \J,'.aS 'Stepping on shaky constitutional grounds. "These re.cords are protected, by our. ~onstitutional :right of privacy," he said; .refenfog to the Florida Cohstituti6i1. After the heating, Silver-said an app_eal won't .be neG.ess_ary µntil .Epstein attorneys s_e_ek the records. Ih another ruling Wednesday, Hafele, afso said that videos from, depositions in the state cases can't be released without a court order; The ruling came: after Epstein att9rn~y Robert Critton complained that,a video of Epstein being·asked_ whether'he had,an "egg'-'.shapedll penis becan1e a youtube.cont sensation. It first appeared on The Palm Beach Post Web site. Critton blame<l attorney Spencer Kuvin for releasing_ it. Kuvin said it was public record. The civil suits began mounting after Epst~in ~greed to plead guilty to two stc:1te charges: proc.uring a minor for prostitution and ·soliciting prostitution; He served 13 rrrnnths of a:n 18- hiotith sentence: As part of the deal brokerecl with fed.era) prosect,1tor~, he agreed not tq contest the accusations in the civil lawsuits. He can argue the women don't deserve the millions they are seeking. -jane _ [email protected] CA/AronbeBi-000194 FILb1J: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM The Mm Beach Post REALNEWSSTARTSHERE Epstein Journals FindingsCould Resurrect Case By Jane Musgrave Posted Sep 17,2019 at 12:01 AM Updated Oct 1,2019 at 10:51 AM (EDITOR’S NOTE: This story originally published in The Palm Beach Poston March 20, 2010) A purloined journal that is said to 'contain the names' of "hundreds” ofvictims of convicted sex offenderJeffrey Epstein could be used to,reopen the investigation into the multi-millionaire’s appetite for teenage girls, an attorney representing seven of the victims said Friday. New details about the contents of the journal were released this week when.Alfredo Rodriguez,,who worked as a property manager for the Palm Beach resident, pleaded guilty to obstruction ofjustice for lying to federal agents: when asked if he had any information about.his former boss’ criminal activity. He later tried to, sell the journal he stole from Epstein for $50,000 to an unidentified person, who alerted authorities, according to court records. As part of the plea agreement, federal prosecutors said the journal "contains:information material to the Epstein investigation,, including the names ofmaterial witnesses and additional victims.” "Had theitems been produced in response to the: inquiries of state or federal authorities ... the materials would have been presented to the federal grand jury,” federal prosecutors wrote. CA/Aronberg-000195 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY CA/ Aronberg-000195 By .JCln~MusgrClv.e: Posted Sep 17, 2019 at 12:01 AM Updc;iteg 0Gt 1, 20l9 at 1 Q:51 AM (EDITOR'S N'PTE: This story originczlly pukl~she<J-frz J]w Palin Beach Poston March-20; 2010) A purloined journal that is said to contain the n:am:es· of "lrnndreds" qfvjc;tims of convic;ted se~ offender Jeffrey Epstein could be, used to ,reop·en the investigation in to the. multi-millionaire's appetite for teenage girls, art attorney rep.r:e.senti11,g s_eye.11 of.the victim~ said Friday. New detaih about the. ~ont.ents of the .jqt,ir_na.l were rele,\sed this week when Alfredo Rodriguez,, who worked as a property manager for the Palm Beath resident, ple·aded guilty to ob~trµctiqI.l ofjustice for lying to federal agents: when asked if he had any information abouthis former boss' criminal activity. He later tried to, sell the journal he stole from Epstein for -$50,ooo: to an unidentified person, who alerted J1uiliorities, according to. court records .. As part of the plea agreement,, federal prosecutors said the journal "contains information material to the Epstein investigat:'i9n, i11c;luping th.e n_a:i;nes. of rna(erial witnesses and ·additional victims." "Had the'items been produced in response to theinquiries of state or federal authorities ... the materials would have been presented to .th~ fed~ral grand jury," fe.deral prosecutors wrote, FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM Instead, prosecutors short-circuited the grand jury investigation and cut a deal with Epstein. They agreed hot to pursue federal charges if he didn’t contest prostitution- related felonies in state court The money manager pleaded guilty in July 2008 to procuring a minor for prostitution, and soliciting prostitution. He served ,13 months of an 18- month sentence. Attorney Adam Horowitz, who represents seven ofthe roughly 18women who have filed civil suits against Epstein, said the new information could trump the so- called non-prosecution agreement. The multifaceted agreement, he said, deals only with a specific list ofvictims that the U.S. Attorneys Office knew about when it penned the deal in 2007. If additional victims are listed in the journal Rodriguez stole, Horowitz said, federal prosecutors could reopen the investigation. “It opens the door for further prosecution,” he said. In addition to turning- oyer the journal to federal agents, Rodriguez told them he knew his former boss was haying sex:with underage girls when he worked for him in 2004 and 2005. He had seen naked girls, who looked like-minors, in the pool of Epstein’s $8.6 million mansion. He had seen pornographic images of young girls on Epstein’s computer, according to court records'. Neither Epstein’s criminal defense attorney, Jack Goldberger, riof attorney Robert Critton, who represents Epstein in the civil lawsuits, could be reached. Federal prosecutors have consistently declined comment. The wording ofthe controversial agreement is: unclear. It says federal prosecutors would provide Epstein’s attorneys “with a: list of individuals whom it has identified as victims." Miami attorney Robert Josefsberg was. appointed to CA/Aronberq-000196 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY Instead, prosecutors short-circuited the grand' jufy investi_gati6n arid cut a deal with Epstein. They agreed iiot tQ pµr.stH~ (ec:ie:ral ~tu1rge$ ifhe didn't contest prqsti.tuttcm- . I relatedfelonies. in state court The money manager plec1-ded guilty inJuly 2008 to procuring a minor for prostitution. and soliciting: prostitution. He served J3 months of an 18- month senterrce. Attorney Adam Horowitz, who represents seven of the roughly 18 women who have filed civil suits against Epstein, said the new informatfon: could trump the so- called non~pros.ecution agreement. The multifaceted agtee·m·ent, he sa:id, deals only with ·a: specific list.of Vi'ctims that the U.S. Attorney's Office knew al,)oµt.wher1 it pennec:i the deaJ m 2007'. lfadditional yfctims a:re listed in the journal Rodriguez stole, Horowitz said. fedetal ptosecutots· could :reopen the investigation. "It opens the door for further prosecution," .he said. In c1dcJitic;m. tq. turnlng. oyer the joum~l t9 foder.il c1g~nt§, Rodrigt1ez: told them he knew his foorn!r pqs~· was haying sex with underage _girls when he worked for him in 2004 and 2005. He had.seen naked gfrls, who looked like'.minors,. in the· pool of Bpstein's $8.6 million m:i.nsion. He had seen ~pornographic: ima:g·es .of y_Oll11g girls on Epstein's :computer,. according to court retards'. Neither Epstein's c;riminal defens.e attorney; Jack Goldb.erger, not attorney Rohert Critton, who repre·sents Epstein in the civil lawsuits, could be reached. Federal prQsecu_t9rs have consistently d:edinecl ~omJJH~nt. The wording ofthe controversial.agreement is undear . .It says federal :prosecutors would provide Epstein's attotn:eys "with a list ofiI1diyidu_alswhoTI1 it h,1s identified c1s yictims." Miami attorney Robert Josefsberg w~s. appointed to CA/Aronberg-000196 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM represent any of the victims on the list who wanted to pursue Epstein in civil court-. As part of the agreement, Epstein is to pay for Josefsberg to represent the women, Some of the women, most identified as Jane Doe in lawsuits, had already hired attorneys to represent them. Some have since settled their-suits with Epstein, although terms were not disclosed. Horowitz said he has filed court.papers to get the journal that Rodriguez stole. “It’s another piece of evidence that shows our clients were at Epstein’s mansion," he said. Rodriguez told prosecutors he didn’t turn over the journal when both.FBI and Palm Beach police asked for it because he wanted money for it. He also said he was afraid Epstein would make him “disappear.” The information, he told investigators, was his “insurance policy.” He faces a maximum 20 years in prison when he is sentenced on June 18. [email protected] @pbpcourts CA/Aronberg-000197 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY represent any of the victims on the list who wanted to; pursue Epstein in .civii court, As pI1.rt of the agreement;: I Epstein is to pay for Josefsbetg to represent the women, Some of the women; most identified as Jane Doe in law~uits, h;id :ah:eady hired attorneys to r~present them. Some have since settled their- suits with Epstein, although terms were not disclosed. Horowitz- said he has filed court:papers to get the journal that RQdriguez stole. "It's another piece of evidence that shows our clients were at Epstein;s fnansion/"he said. Rodriguez told ptos·etutofs he didn't turn over the journal when both FBI and Palm Beachpolic;:e c1sked for it becal.}se he wanted money for it. He a]so sa:id he was afraid Epstein would make him iidisappear.;'·The information, he told investigators~ was his "insurance poli_cy." He faces ama,ximum td·years fn pri,5Qnwhen he is sentenced on June 18. [email protected] CA/ Aronberg-000197 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM The Palm Beach Post Ml. NEWSSTARTSHERE.~ Epstein paid three women $5.5 million to end underage¬ sex lawsuits By Jane Musgrave Posted Oct 3,2017 at 12:01 AM Updated Oct 4,2017 at 12:46 AM Ending years of speculation about how much Palm Beach billionaire Jeffrey Epstein paid young women who claimed he used them as sex toys, court documents filed last week show he shelled out $5.5 million to settle lawsuits with three of more than two dozen teens who suedhim. Responding to requests from Epstein’s attorneys in a complex lawsuit that was spawned by the sex scandal, attorney Bradley Edwards said the politically-connected 64-year-old convicted sex offender paid more than St million to each of the three women Edwards represented. Identified in court papers only by their initials or pseudonyms because of the nature ofthe allegations and their youthful, ages, L.M. Was paid $1 million, E.W. $2 million andJane Doe $2.5 million, Edwards said ofthe settlements he negotiated with Epstein to end the lawsuits. Jack Goldberger, one of Epstein's criminal defense attorneys, on Tuesday declined comment on the revelations, citing confidentiality agreements that,were part of the settlements. For the same reason, he declined to say whether Epstein paid similar amounts to settle roughly two dozen lawsuits filed byother young women against Epstein, claiming he paid them for sex when some were as young as 14 years old. AttorneyJack Scarola, who is representing Edwards, said his client was compelled to divulge the confidential settlements to answer questions posed byEpstein’s attorneys. “Brilliant move on their part,” he said. Even if Epstein’s attorneys hadn’t'opened the door, Scarola said the information would have likely come out. He says,the information will help him undermine Epstein’s claims that Edwards “ginned up” the allegations to help his former law partner, imprisoned and disbarred Fort Lauderdale lawyer Scott Rothstein, perpetuate a $1.2 billion Ponzi scheme. CA/Aronberg-000198 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY !;Jy Ja(i~: Musgr!lve Posted cfod, 2017 at i 2:01 AM Updated Oct 4, 2017 at 12:46 AM '.Ending years of !fpecula:tion about how much Palm Beach billionafreJeffrey Epstein paid young women whq cl_:µ_I_Iledhe lJSed the,:qi a~ ~ex·toys, cou_rt dqcu.ment~JiJedJast we,e,k show he shelled out $5.5 million to settle lawsuits with tlm~e of mo:re than· two d9z~n teens who sued 'him. Respondin~ to re.quests from Erpstein's attorneys in a com:piex laws.uit that was spawned by t:he sex scandal, attorney Bradley Edwards said.the politically';-.cohnected 64-year-old. convicted sex offenc,ler paid :qio:re th~n $1 m.i.llion to eac:h 9f the, thi:ee wome,n Edwanis rep:re,sentecl. ldentifled in c:ourt pape,rs pnly })y their initf~s or ps~~donyms :beca_use ◊f tlle natvre of the alle~ations ,and their youthfui.ages, L.M·. was paid $1 miliiort, E.W. $2 million and Jane Doe $2.5 million, Ed\vards said of the settlements:he negotiated with Epstefo to end the lawsuits. Jack Goldl:>erge,r, one ofEpst~in's criminal defen~e.attorney~1 on Tuesdaydecljned·~omment on the revelations, citing confidentiality: agreements that:were part of the s_effiements. For the same 'reason; he declined to. say whether Epstein paid similar amounts to settle roughly two dozen lawsuits filed 'by" other young women ,against Epstein, claiming he paid them for sex "f• .•. ·-· ,,_ • .. ,. _.J} when some were as young as l4 years old. Attorney Jack Scarola, who is representing Edw2,rds1 said his client was c.orn:pelled to divulge the confidential settlements to answer q~estions posed by'Epstein's-attorneys. "Brilliant move on their part," 11~ said. Even ifEpst~in's attorneys hadn'fop~ned th~ door, Sc:arola said the intor.mation would h<!ve likely come out, He says, the, information will helJ? him undermine Epsteirf s claims that Edwards<'ginned up"'the allegations to help his former law partner, imprisoned and disbarred Fort Lauderdale law-yer Scott Rothstein, perpetu_at~ a $1.2 billion Ponzi scheme. CA/Aronbe_m__-000198 FILEU: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM The revelations’of the settlements came as part of an ongoing lawsuit that started as a dispute between Epstein and Rothstein, both billionaires. i A year after Epstein in 2008 pleaded guilty to solicitation ofprostitution- and procuring a minor for prostitution, he sued Rothstein and Edwards, claiming they trumped up the allegations of sexual molestation to perpetuate the Ponzi scheme. Rothstein was sentenced to 50 years in prison in 2010 after admitting he had built his Wildly successful law firm by forging the names of federal judges and others to persuade;investors he had negotiated settlements in lawsuits against high-profile people. Investors were fold they could get a cut of the cash. One ofthe high-profile people Rothstein used tolure investors was Epstein, according to a lawsuit West Palm Beach attorney Robert Critton filed on Epstein’s behalf. According to the lawsuit, Rothstein told investors Epstein, a money manager, had agreed to settle the lawsuits with the teens for $200 million — a claim Critton described as “a complete fabrication.” After Epstein dropped the lawsuit in 2012, Edwards turned the tables on him. Edwards; accused Epstein of filing the lawsuit maliciously to punish him for representing the young women. Although Edwards was a partner in Rothstein’s now defunct firm, Scarola claims Epstein had no evidence Edwards was involved in the Ponzi scheme. Federal prosecutors successfully charged other attorneys and members of the firm, but; Edwards was never implicated, Scarola said in the malicious prosecution lawsuit. The revelations about the money Epstein paid to three of the young woman came last:week in documents filed for a hearing Tuesday in preparation for a December trial on the lawsuit. Attorney Tonja Haddad Coleman, who represents Epstein, on Tuesday sought a delay ofthe trial, in part, because she claimed she has been unable to talk to her client since his estate on his private island in the;U.S. Virgin Islands was devastated last month by Hurricane Irma. “I’ve had no ability to communicate with Mr. Epstein,” she said. CA/Aronberg-000199 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY The revelations' of the settlements came as ·part of ah ongoingJawstiit.thatstatted as· a .dispute . I between Epstein and Rothstein, both billionaires. ; A year after Epstei.n ip 2008 ·pleaded gt1i.lty to ;sqlicita:tiqn of prqstjtution. a,nd pro<;urjng a minor for prostitution, he sued Rothstein and Edwards, claiming. they trµmped up the allegations df sexual molestation to, perpetuate the Portzi scheme. Rothstein was sentenced to so years irt prison in 201 O after admitting he, ha:d built his wildly successful la.w finn by forging the na.II1es of federal Judges. and others to persuade investor~ he ha:d negotiate:d.settleme·nts in iaws.uitsagairtst high:"protile people. Investors were fold.they could get a. cut of the cash. One of the high-pr9file people R_gthstein used to lure investors. wa~ ~ps.teil!, a,c;cordfpg te> a laws:uit West Palm Beach attorney Robert Critton filed on Epstein's: behalf. According to the lawsuiti Rothstein told investors Epstein, a morteymanager, had a~teed to settle. the. lawsuits With the teens for $200 million - a· claim Critton described .as ''.a complete fabrication." After Epstein dropped the lawsuft in 2012·, Edw;ml.sttn-ned the tables on hhn. Edwards, accused Epstein- of filingtheJawsuitmaliciousiy·t.o punish him for representing the young women. Although Edwards wa:s a partner in Rothstein !s ·n:ow defunct firm, Sca:tola claims Epstein had no evidence Edwards was involved in the Ponzi scheme. Federal prosecutors successfully charged other a.ttorneys and members of the firm, but Edwards was never implicated, Scarola. said in the malicious prosecution iawsuit, The revelations aboutthe money Epstein paid to three of the young woman came last:week in documents filed fQr a hearing Tuesday in prepara,tion for <! Dece~lJertri~l on the lawst11t. Attorney Tonja Haddad Coleman, who represents.Epsteini on Tuesday sought a defayof the tri_al! in par:t, bec;:~lJS~ s_he cl?-11:nfd sh~ h~s be~n. un_t!bl~ t_o talk to her cli~JJ.t sinc_e his ~s_ta_te on _his privat_e isiand in the lJ$. Virgin Islands_ was devastated last month_ hy Hurricane Irm.a. ('I've had no ability tocorhrtmhitate with Mt. Epstein/' she said. CA/Aronberg,.000199 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM t Pointing out Epstein’s enormous wealth and his private jet, Palm Beach County Circuit Judge Donald Hafele rejected her request. While saying he didn’t want to appear insensitive to those victimized by the storm that hammered the Caribbean and roared through South Florida, he said Coleman offered no proof, such as an affidavit from Epstein, to shore up her claims. Still,. Hafele gave Coleman extra time to respond to various motions that he will have to decide before the case goes to trial. DespiteScarOlas insistence that Edwards had nothing to do>with.Rothstein's Ponzi scheme, Coleman said the evidence indicates otherwise. Why else would he try to depose Epstein's well-known friends, such as now President Donald Trump, former President Bill Clinton and illusionist David Copperfield, she asked. He used the celebrities as a draw, she said. “The Epstein cases were used to fleece money and defraud investors,” she said. Edward’s malicious prosecution case has been difficult for both sides because bdth.Epstein and Edwards have refused to answer questions. As he did in the civil, lawsuits, Epstein has invoked his Fifth.Amendment right against self-incrimination when questioned by Scarola. Edwards has claimed that much of the information Epstein is seeking is protected by attorney-client privilege. The malicious prosecution lawsuit is one of two hotly-contested lawsuits that continue to pit Edwards against Epstein. Edwards also is suing the U.S, attorney’s office, claiming it violated the federal Crime Victims Rights Act when it negotiated a.non-prosecution agreement with Epstein. Only after federal prosecutors agreed to drop their investigation of Epstein, did he agree to plead guilty to two prostitution charges in Palm Beach County Circuit Court. In federal Court records, prosecutors claim one of the key reasons they agreed to drop their case was Epstein’s agreement to settle lawsuits filed against him by dozens of his underage victims, CA/Aronbera-000200 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY I Pointing 0µ1 Epsteil)'s enor:mous wealth and his private jet, Palm Beach qounty Circt11t Jqdge ' Donald Hafele rejected her request: While saying he didn't want to appe.ar insensitive to those victimized by the storm that hammered the Ca.rib bean and roared through. South Florida, he said Coleman offerec;I-no proqf, sugh as an atnclavit fro·m: Epstein, to shore up her claims. StiH,. Hafele gave Cokman extra· time to respond to various motions that he will hc_lv~ to decide before the case· ·go~es to trial, Des_pite· ,Scarola' s ihifisterice that Edwards. h~d:no.thing to do, with. Rothstein!s Ponzi scheme, Coleman sa:id the- ~vidence. foJicat~s Qtherwise. Why else would he. try to depose Epstein's weU-1mmv11 frien:ds,, such as now President Donald Trump, former P:r;-esident BIii Clinton ,and illusionist David Copperfield, she asked. He used the ci=lebrities as a draw, she said. 'The Epstein cases Were used to fleece money _and defraud investors/' she said. Edward's :malicious prosecudon qse has been difficukfor.both sides'becalise both Epstein and Edwards have refusJ!d to answer q~estions, As he did in the civil. lawsuits, Epstein has :invoked his Fifth Amendment right against self-incrimination when que~tfoned by Scarola-. Edwards ha:s claimed that much of the infc;>Jmati_on Epstein is se:eking is J)'rotected by attorney-client privilege. The n;ialicioµs prosec::µtion lawsuit is .one oftwo hotly~coiitested lawsuits th~t c;ontj11µe t9 pit Edwards against Epstein. Edwards also is suing the l).$, .attorney's office, da:irn:ing it violated • . . I . the federal Crime Victims Riglits Ad \Vhen ft ·negotiated a.non,-prosecution agreement with Epstein . . Oply after federal prosecutors agreed' to drop their investigation ·of Epstein, did he agree fo plead guilty·to two prostitution, charges in I?alrn Bea~h. Co\lnty Circuit Court, In federal court records, prosecutor~ daim on~ of the 'key.reasons they agreed to drop their case was Epsteln's <!greement to _se_ttJe iawsuits filed against him. by dozens of his underage victim~, CA/Aronberg-000200 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3/27/2023 2:57:43 PM Palm fetch DailyNews t Judge rules feds’ agreement with! Jeffrey Epstein past violated teen victims’ rights By Jane Musgrave Posted Sep 17,2019 at 4:02 PM Updated Oct 8,2019 at 12:31 PM (EDITOR’S NOTE: This story originally published in The Palm Beach Post on February, 22, 2019) Federal prosecutors violated the rights ofJeffrey Epstein’s teenage victims by failing to reveal they had dropped plans to prosecute the billionaire on dozens of federal charges in connection with the girls’ claims that he paid them for sex at his Palm Beach mansion,, U.S. Districtjudge Kenneth Marra ruled on.Thursday. In a blistering 33-page ruling, Marra meticulously and methodically detailed the numerous steps federal prosecutors took to hide the agreement from, more than 40 young women who claim Epstein paid them for sex when they were as young as 14. “While the government'spent untold hours negotiating the terms and implications of the NPA with Epstein's attorneys, scant information was shared with the victims," Marra wrote. “Instead,;the victims were told to be patient’ while the investigation proceeded.” By then, it was too late. A deal had already been cut with then-South Florida U.S. Attorney Alex Acosta and Epstein’s attorneys to shelve a. 52-page federal indictment against Epstein, a former math teacher turned money manager who counts Presidents Donald Trump and, Bill Clinton among his friends. CA/Aronberg-000201 FILH): PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY CA/Aronberg-000201 Jud ei' rule.s Je'ds' ]1 • reaiment. withi - _g ········- ,. ·---·· __ g _ - -·· .,,, ... , .. Je_ff~ey: iEpsteUt: p:a·cf vi:olate'd leeri \vi.c:tiJ1ls' ,r,lghls ey J.!l~~.M·µ~gr,~~e Posted Sep 17, 20·19 at 4:02 PM Updated Oct 8; 2019 at 12:31 PM (EDITOR'S NOTE: This story ori.ginally publishfd in The Pqlm B~qc:h, Post 9n F~b~ciry 22, 2019) Federal prosecutors violated the rights ofJe{frey Epstdn!s teenage victims byfailihg to reveal they had dropp~ed pians to prq§ecute,the bHlionaire on dozens offedetal charges. ih connection with the girls' claims tlia,the paid the:i;n for sex at his Palm Beach mansion,, U.S. DistrictJudge Kenn·eth MarraTuled on.Thursday. Jn a blistering 33-page ruling, Marra meticulously a:rtd methodically detail eel th.e numerous steps federal_ prosecutors took to hide the ·agreem·en:t from more than 40 young women Who claim,Epstein paid them for sex when they were a,s young .~s i4, "While the goveriiment'Spent :untold'hours negotfating the terms and implications. ofthe NPA with Epstein's attorneys, sca11t iQfor:mation was shared with the victims/',Marra wrote. "Instead,) the victims wen~, told to be 'p~ti~nt' whik the investigation proceeded.'' By·then, 1t was too fate. A deal had alfeady been ctit with the.n-Sollth Floriµa U.S. Attqr{l~y Alex Acosta and Epstein's attorneys to shelve a.52-pagefederal indictment agains.t Epstein, a former ma:fu teacher turned money manager who co11_nts Rresidents Donald Trump and, Bill Clinton among his friends. FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM Prosecutors’ failure to alert the young women about the deal,violated the Crime Victims’ Rights Act, Marra ruled. “At a bare minimurn the (act) required the government'to inform,(the young women) that it intended to enter into an agreement riot to prosecute Epsteiri,” he wrote. Still, Marra said he wasn’t second-guessing prosecutors’ decision not to pursue Epstein on federal charges ifhe pleaded guilty to minor state prostitution charges' arid agreed to corriperisate his victims for the trauma he caused. “The court is not ruling that the decision not to prosecute was improper,” Marra wrote; “The court is simply ruling that, urider the facts of this case, there was a violation under the CVRA.” Further, he made no decision about what the remedy should be. He gave prosecutors and attorneys representing the young women 15 days to meet to decide how to unravel the complex legal.web that has been hanging Over Epsteiri and his young victims for more than a decade. The chances an accord will be reached are slim, said attorneyJack Scarola, who is representing the two Jane Does who challenged the; prosecutors’ actions. Further, he said, there is no road map to follow, The lawsuit attorney Bradley Edwards filed on behalf of the two unidentified young women, clairning prosecutors violated the federal act, is unique, he said, “We are: treading on virgin ground, to use what is probably aft inappropriate phrase in this situation,” he said. Scarola said he and Edwards will ask that the riori- prosecution agreement be thrown out. That would open the possibility that the long-Shelved federal indictment could be dusted off and filed against the 66-year-old Epstein, who spends most:of his time on a private island he owns in the U.S. Virgin Islands. CA/Aronberq-000202 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY Prosecutors' failure-to alert the young women about the . . . . - .. . . . - . . I deal.violatedtheCrime Victims' Rights Act, Marra ruled. I "At a b~re mi_n1m~m the (c1ct) re.qu_ii:ed Jhe governmei;&to inform (the young women) that it intended to enter in~o· an agreement riot to prosecute Epstein} he wrote. Still, Marra said he wasn't second-guessing prosecutors' dec_ision_ n_ot to pursue Epstein onfeder;ilch9-rges .ifhe pleaded .guilty to rninot state prostitution charges and agreed to compensate his victims for the trati.fila he· caused. 'The coµrt fs not .rnHng that 'the deci.sion not to prosecute was. iinproper," Marrc1: wrote, ''The 5=_ot1,rt is shnply niling that, undenhe facts of this case, there was .a: violation. un·der the CVRA." Fµrtl:)er! he made no decision .af?out what the remedy should be. He gave prose!=ufor.s and atto:rneys represeIJ.ting the youn_g women 15 clays'. to meet to decide how to u:nra:vel the complex, le_gal.web that has been hanging over Epstein and his young victims for Ill ore than a dec~de. The Ghances. an c1.(:tord wilLbe reached· are slim, s_aid attorney.Jack Scarola, who is representing the two Jane Does wl:io <;:liaUenged the prosecutors' actfons, Further, :he said, there is r1,o ;r9ad mc1.r. tq follow, ,:'he lawsuit attorney Bradley Edwards filed on behalf of the two uniden.lifiedyoung women; -claiming ptosecutors·violated the foderc1l <_!.ct, isv_n}qug1"he s~{d._ "We are: treading on virgin ,gr:ou11d, to use what .is. prdbably an inappropriate phrase in this .situation/ he said. Scarola said he and Edwards will ask that the rtort~ prosecution agreement be throwr:i out That would opt?n the p:ossibilitythat the long-shelvedfederal indictment could be dusted offond filed against the 66-year-old Epst~in,1 who ~pe:p.ds m,Qs,t:of his time on a private island he owns in the'V.S. Virgiil Islan,ds,, CA/Aronberg~000202 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM "I don’t see the government conceding to that remedy,” Scarola admitted. Further, he said, it is likely Epstein will be allowed to weigh in. Miami attorney Rov Black years ago filed papers asking to intervene on Epstein’s behalf. The U.S. Attorney’s Office said it wouldn’t comment oh Marra’s ruling. Neither Black nor New York City attorney Jay Lefkowitz,,who led efforts to bury the federal indictment, responded to emails or phone calls for comment. West Palm Beach attorneyJack Goldberger, who represents Epstein, also didn’t respond. Scarola said it is likely Epstein’s star-studded legal team will argue that Epstein fully complied with the terms of the agreement he made in 2007 with federal prosecutors and therefore the agreement can’t be undone. As he promised,,Epstein pleaded guilty in June 2008 to state charges of soliciting a minor for prostitution and soliciting prostitution. He served 13 months of an 18-month jail term in a vacant wing of the county stockade that he was allowed to leave 12 hours a day, six days week. Further, as agreed, he paid settlements to the young women who sued him. While the settlements were confidential, court records show he paid three women a total of $5.5 ■rnillio'il. In return, federal prosecutors held up their end of the bargain. Their investigation ceased. Haying done all that prosecutors, asked of him, Scarola said Epstein will make a simple argument: “YOii can’t turn around and deprive me of the benefits I bargained for.” However, Scarola said, using Marra’s ruling, he will counter that the contract Epstein signed was illegal,and therefore unenforceable. CA/Aronberg-000203 FILW: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY "I don\ see the gover:tnnerit conceding to that r,emedy,": I Scarola admitted. Further, he sard, it 1s likely.Epste1n wµl be aJloweq to w~igh 1n, Miami .J.ttomey Roy :Black years ago fHeci papers asking to intervene: oh Epstein's·behalf. The: U.S. Attorney's Office said it wouldn't comment ori Marra' s ruling. Neither Black nor New Y:ork City atton;iey Jay L_efkowitz,.who led efforts to bury th~ federal indictment; respon<led to email's ◊-t phone calls for conimerit. West Palm Beach attorney J a:ck Goldberger:, who represents Epstein, also didn't re_spo_nd. SGarola said it is likely Epstein's star:.studded legal te~m will atgu·e that E_pstein fully complied with the. terms -of the agreement he made in 2007 with federal prosecutors.al}.9 then~_fore the .3.gr:e1=ITient c;an't be·.µndpne, As he promised,,Epstein pleaded g:uiltyinJune 2008 .to state charges of soliciting a minor for prosii'tutioiui.nd soliciting prostitution. He served 13 month~ .of an; l 8-m9nth jatL te_rm in a v~~ant wing oft.he <::ounty stockad,e that he w;i.s alfowed to ieave 12 hours a day, six days week. Further, as agreed, he paid settlements to the young women who sued him. While the settlements wer:e confid,ential, court records show he_paid tliree: women a total of $5.5 'million. In return, federal' prosecutors held up their end of the b~Jgc1,1p.. '[heir i]).yesti'gatJ9n ceased:. Having done all that prosec:utprs asked of him, Scarola sa:id Epstein will make a simple argument "You can't turn around and deprive me of the peneff ts I bargained for/ . Howe:ver, Scarola said, using Marr:a's. ruling, he will counter tha:t the· contract Epstein signed. was illegal and therefor,e unenforceable. CA/ Aronberg-000203 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM Even if Marfa agrees to toss out the non-prosecution ! agreement, Scarola conceded that doesn’t mean Epstein' will I face federal charges. ' “The contract can be set aside and the federal government can attempt to enter into the same agreement,” he said. “Except the spotlight ofpublic attention, will be on them and the. 40 victims will be able to explain to the court why this sweetheart deal should not be approved.” Scarola said that,prosecutors may have had good reason not to pursue’Epstein. "There:maybe a reasonable explanation but we don’t know what that:reason may have been,” he said. In court papers-, federal prosecutors have said that many of the young women were afraid to cross-the.powerful, politically connected money manager and simply refused to testify against him. In other cases, they said, the women changed their stories. Jane Doe 2, who is trying to have the non-prpsecution agreement thrown out, initially described Epstein as "an awesome man" arid told prosecutors she hoped “nothing happens” to him. While she later agreed to testify against Epstein, prosecutors said they feared Epstein's attorneys would use her words to destroy her if she ever took the witness stand. Marra, however, said the young woman’s comments didn’t mean she wasn't entitled to know about the prosecutors’ plans to drop the charges. “There is no dispute that Epstein sexually abusedJane Doe 2 while she was a minor,” he Wrote. “Therefore, regardless of her comments to the prosecutor, she was a victim.” Before the case is finally resolved, Scarola predicted that “a lot of people, are going to have to answer a lot ofquestions.” CA/Aronberg-000204 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY Even if Marra: agrees to toss outthe,non-J_)r.osecution 1 I agreement, Scarola conceded that doesn't mean Epstein; will. face, fedgral cha.rges. ' "The contra_ct c_an he s.et asid¢ an:d the fe:deral gQvernmJnt ca.Ii attempt to enter into the same agreementthe said.- "Exceptthe spotlight of public attention.will be ori them and the 40 vic;:tims_ will.be able to explain to the cqurt why this sweetheart ·deal should not he a:pprove:d.;, Scarola said that pr6se.ctitors, may have ha:d good reason not tn pursµe· Epstein. "There: p:iay be a reasonable explanation but we qqn't kn9w what.that reason may &_ave been/ h~ said. In court papers; federal prosecutors have said that many of the ygung WQmen_ were afplid tq cross, the, powerful, politically c.onnected money·m.anager:an·d simply refused'to testify a.$ainst liim. In other cases, they said, tlie women changed their stoties.-, Jp.ne I)Qe 2, wh.o Js trying;to have the n9p-pr9se(:uti9n agreement thrown out, initially Je·scdbed Epstein as iian awesome man" arid told prosecutors she hoped "nothing hap pegs" tq l)_i.rp._, While she l_a:ter a_greed to testify ~gainst Ep:stein, prosecutors said they feared Epstein's attorn·eys would use her words tO' destroy her if she ever took the witness stand. Ma.rra,h9wever, sai9 the yo@gWQJJl~n'$ coII1rµents c:U,9p'.'t mean she wasn't entitled to know about the pros_ecutors' plans to drop the, charges. "There is no dispute that:Epsteifl se:x;ually ~Jm~edJaneD9e 2, while,she w;i,s,~mi110.r," be wro.te, ''Therefore, regardless of her,comments to the prosetutot, -she was a Victirn.!' Before :the case is finally resolved, Scarola predicted that" a lot of p!:!ople.are goin,gto h;1ye to an_s:vyer ,!)ofofqu~stipris:" CA/Aronberg-000204 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM In his ruling, Marfa detailed what appeared to be a cozy relationship between Acosta, his line prosecutors and ; Epstein’s team of lawyers. His phalanx of lawyers included noted Harvard law professor Alan Dershowitz and Kenneth Starr, the former U.S. solicitor general whose investigation led to; the impeachment ofPresident Clinton. Marra describes an October 2007 breakfast meeting between Acosta, who,is now U.S; labor secretary, and Lefkowitz shortly after the noh-prosecution agreement was inked, After the meeting, Lefkowitz sent Acosta a note thanking him for “the commitment you made to me during'Our October 12 meeting in which you assured me that your Office would not... contact any ofthe identified individuals, potential witnesses, or potential civil claimants and their respective counsel in this matter.” Marra quoted an equally pleasant note then-Palm Beach County State Attorney Barry Krischer sent to Assistant U.S. Attorney Marie Villafana, who was the lead prosecutor in Epstein’s case. “Glad we could get this worked out for reasons: I won’t put in writing,” Krischer wrote, shortly after the non-prosecution agreement was sighed. "After this is resolved I would love to buy you a cup at Starbucks .and have a conversation.” Many ofthe notes that were exchanged dealt with prosecutors’ and Epstein’s lawyers’ shared desire to keep the deal secret from Epstein’s accusers. In a September email, Villafana asked Lefkowitz for guidance about what she should reveal. “And can wehave a conference call to discuss what I may disclose to ... the girls regarding, the Agreement,” she asked. CA/Aronbera-000205 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY In his ruling, Marra detailed what appeared to be.a cozy relationship between.Acosta, his line prosecutors and ; EpsteJ:n's t~am ofla:wyer~. Hi.~ P,ha};in,x of l:1wy~rs i:ndu<led note:d Harvard law professor Alan Detshowitz ·and Ken'neth I Starr, the former U.S. solicitor general whose investigation ,led to the impeachment of President Clinton. Marra d~sc:ribes an October 2007 breakfast meeting betwe:en Acosta, who ,is now U.'S.1a:bor secretary-,_ and Lefkowitz shortly aftetthe non-pt6Secution,agreement was inked. Aft~r tlie. meeting, Le{lcowitz sept :A~osta.a no_te thanking him for ''the conimitmertt you tnade to me during,out October 12 meeting -in: which you assured me that you_r Off}ce wouJd not ... coptact a_ny ofthefdentifieq individuals, potential witnesses, or potential civil claimants· and their respective co.uri.sel iri this matter." Marra quotedan equally pleasant note then-Pg.lrp ]?each County State Attorney 13;ircy Ifrischer sent to Assi~tc1nt U .S, Attorney Marie Viilafana:, who was the lead prosecutor in Epstein's case. "Glad We could get this worked out for feel.son~ l won't put in wrhing," K.risc_her WTQte, shortly after the n·on'"'prosecuticin agreement was signed. "After this is. resolved, I would love to; buy you a cup .at Starbutks .and have a conversation." Many of:thenotes that:wer:e exchanged dealtwith pr.osecutors' and Epstein's lawyers; shared de•sire to keep the deal secret from Epstein's accusers. In a Septemberem;iU, VH1afan;1 :isl<:ed LefkowitzJor guidam:e about what,she· should reveal. ''And .c:an we·have· a: conference call to discuss wha:t I may disclose to ... the _girls regarding. the Agreeme:r;tt," she ask~d. CAI Aronberg-000205 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM Such cooperation between prosecutors and defense attorneys is unusual, Marra said. "It was a deviation from the government’s: standard practice to negotiate with ' defense counsel about the extent of crime victim notifications,” he wrote. Further, he noted, that when Edwards and his two young clients asked for information, they were repeatedly misled. “The CRVA was designed to protect victims’ right arid ensure their involvement in the criminal justice process," Marra wrote. “When the government gives information to victims it cannot be misleading.” Ultimately; the terms of the non-prosecution agreement were revealed only after Edwards and attorneys for the press successfully sued to make them public. @pbpcourts i CA/Aronberg-000206 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY i • Such cooperation between prosecutors and defens,e att_orneys: is unllS\lal, _M,;m::a sa_id. "It wa.s a deviation froµi the government's standard practice to negotiate with defense counsel abo.uttheextent of crime vic:tiin notifications," he wrote. Fµrthe_r, he noted, th.at w4en Edwards and hi.s two young clients ,asked for: information, they were repeate:dly misled; 'The. CRV A was designed to protec:t'-vic:tims' tight and ensure: thei:r.involvei:n.eIJ.t fo the cdminal justke process," Marra wrote .. "When the government giv.es information to vittims it c:an11ot be misleading." Ultimately; the terms of the non-prosecution.agreement were Teve~led only afte.r; Edwards a;id attorn~ys for the press suq:::essfully s.ued to make them public. jin usgrave@pbp·ost;com @pbptotirts CN Aronberg-000206 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM 76 / 278 - Tuesday, July 9, 2019 Edition: Final Section: A Section Page: 1A Source: By Jane Musgrave, The Palm Beach Post Epstein indicted on; sex charges Part-timeAWBeadier pleads not guilty to sex trafficking, conspiracy charges in Bderal court in Ifanhattan Dressed in a.blue prison jumpsuit, billionaire Jeffrey Epstein on Monday pleaded,riot guilty to charges accusing him of creating a vast network of girls as young as 14 that he exploited for his sexual pleasure at his homes in Palm Beach .and Manhattan. The 66-year-old money manager's appearance in U.S. District Court in New York City capped more than a decade of recriminations by young women and their, attorneys,who claimed Epstein used his money and political influence to avoid federal prosecution, 'Epstein's attorney Reid Weingarten dismissed the two-count indictment oh sex trafficking charges as "essentially a do-over" of allegations that landed Epstein in the Palm Beach County Jail for 13 months more.than a decade ago. However, unlike in 2007 when then-South Florida U.S, Attorney Alex Acosta agreed to shelve a 53-page federal indictment after Epstein agreed to plead guilty to two state prostitution charges, prosecutors in New York indicated they aren't willing to deal. Acosta is now U.S. labor secretary. "The alleged behavior shocks the conscience." New York City U.S. Attorney Geoffrey Berman said at a morning news conference, "And while the charged conduct is from a number of years ago, it. is still profoundly important to many of the alleged victims, now young women. They deserve their day in court," At a: detention hearing scheduled for Monday, Berman said he will ask a.federal judge to keep Epstein behind bars until he is tried on charges of sex trafficking and conspiracy to commit sex trafficking. Epstein paid dozens of young women to give him nude massages’ that, for most, led to sex, he said. If convicted of exploiting dozens ofyoung women, including many Palm Beach County girls who were students at Royal Palm Beach High School, Epstein faces, a maximum 45-year prison sentence. Citing Epstein's enormous, wealth, his homes in New York, Palm Beach, the U.S. Virgin Islands, New Mexico and Paris arid his ownership of two jets, Berman said there are few conditions that could keep Epstein from fleeing to a foreign country to evade prosecution: CA/Aronberg-000207 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY i 76/-278 "'Tuesday, July 9, 2019' Edition: Final Section: A Section· Page: 1A Source: By Jane Musgrave, The Palm B_each Post E.pstebl indicted op; sex: cltarges .r:art:-time ;flllijt lleach:er pleads )jot' gi,iilty to sex traffJCk.ing, co11sp,iracy cl1arges ip f~Jlera_I coJtrt ht.: M~nhattari. • • Dressed irr a. blue prison jumpsuit, billionaire Jeffrey Epstein on Monday' pleaded,riot guilty to 9h_arg~~ .accµ$ing hirrr of cre<1tipg ~ va.s.t netwqrk qfgirl~ as yo4ng ·as J4 that h~ explo,iJ:eg for his ·sexual :pleasure.at his homes in: Palm Beach.and Manhattan. The 66-year-olcl.I11011ey I11@ager:'sappearance 'inU.S, District Court in:New York City capped more than a ·decade of recriminations by young women and their. attorneys. who dai_med Ep~tein µsed his money <111d political influen~e. to !!Void. reder<1l prqsecµtion. 'Epstein's attorney Reid Weingarten dismisse.d the fwoa..count indictment 011 sex trafficking charges as "essentially a qoa..over" of aHeg_ations that lMde<l Epstein in the Palm Beach County fail for 13 m·onths rri:ore; than. a decade ago, }Ioweve_r, unl*e in 2007 whentheri-So~tlJ.Fioriqa{J.S. Attorney Alex A,co;5ta agreed. tq shelve a 5J..:page federal indictment after Epstein agreed to. plead guilty to·two state ·prQstfrution c;h_arg~~. prQsecµtor~ ipNew Yorl5. indicated they aren't wiflipg to de~l. Acosta'i~ n:ow·u.s. labor secretary. . ;,the a.lleged behav·ior shoc;ks the cp11s<den~e,'''N,ew YorkQity T).S. AttQmey Geoffrey Berman said at a moming news conferenct:!_. ''At)d while th.e c.harge9c conduct is frorr.i a nµmber of years ago, it. is still profoundly important to many ofthe alleged victims, now young women. They deserve their day in court" • • At a: .detention hearing scheduled for Monday, Berman said he will ask a.federal judge to .keep Ep~tein pel1incl bars·µnjil 4~ is trie4 9n charges pf se"traffo::king <1D.d c;qn.spi_racy tp com'init sex traffi'cking. Epstein paid dozens of'young women fo give him nude rnass·ages· that, for most, led to sex, he said. • If convicted of exploiting dozens of young Women, including many Palm Beach County,girls who were• students at Royal Palm Beach H1gh School, Epstein faces a maximum 45~ year prison sentence. Citiryg Epstein's enormolJ.S wealth, his homes in New York, Palm Beach,_ the U.S. Virgin Islands, New Mexico and P'aris and his ownership oftwojets, Berman said there are.few conditi'ons that cot1ld keep Epstein :from fleeing to a f ordgn country to evade prosecution, CA/Aronberg-000207 . FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3/27/2023 2:57:43 PM "We think he's a significant flight risk," Berman said of the man who ferried Britain’s Prince Andrew, actor Kevin Spacey, famed Harvard law professor Alan Dershowitz and former President Bill Clinton on his jet, dubbed the Lolita Express. Berman's hard-line stance was. welcomed by young women who for years have been told that Epstein couldn't be touched because Acosta signed off on the nonprosecutibn agreement, promising not to charge Epstein in federal court. Former Palm Beach County resident Virginia Guiffre, who has accused Epstein of turning her into his sex slave and forcing her to have sex with others, including Dershowitz and Prince Andrew, praised Berman.. He showed the case is "being taken- in a serious way," she told the Associated Press. Dershowitz has vehemently denied Guiffre's claims. New York prosecutors were able to ignore the controversial nonprosecutibn agreement because it contained some significant fine print; said former federal Judge Patil Cassell, who for years has fought to get the agreement thrown.but. It says only that ho charges could be filed.against Epstein in South Florida, he said. Berman agreed. "That agreement only binds, by its terms, only binds the Southern District of Florida," he said. "The Southern District ofNew York is not bound by that, agreement and wasn't a signatory of it." Thatmeans the sordid allegations that have been leveled at Epstein for years are now part of a federal indictment., Contrary to Epstein's claims, he knew the women who came to his homes in New York and Palm Beach were minors because they told him their ages, according to the indictment. Epstein preyed, on young girls because he knew they were "vulnerable;to exploitation," prosecutors added. As part of a Carefully orchestrated sex Ting, Epstein or his associates would Call girls while he was in New York so they would be available for sex once he returned to Palm Beach, the indictment says. The employees weren't named. They were identified, only as. "Employee-1," "Employce-2" and "Employee^." To ensure he had a steady stream of young girls, Epstein would turn some victims into recruiters.. He would pay them to bring new girls to his home on El Bri 1lb Way along the Intracoastal Waterway in Palm Beach or to his palatial townhouse on New York's Upper East Side. "This allowed Epstein to create an ever-expanding web of new victims," Berman said. In both New York and Palm Beach, the lurid operation was similar. Unidentified employees of Epstein's would escort the teens into a room. They were told to take off all or most of their clothes; before, giving the, naked billionaire massages, according to the indictment. "Epstein would also during these encounters, ask victims to touch him while, he masturbated, and touch victims' genitals with.his hands or with sex toys," the indictment says. As part of the criminal complaint, prosecutors are asking that Epstein be forced to turn over his multimillion-dollar townhouse on East 71 st Street. The complaint does not seek forfeiture of Epstein's house in Palm Beach. While heartened that Epstein howfaces serious Criminal charges in New York, Cassell said he would continue to push a West Palm Beach-based federal judge to throw out the nonprosecutibn agreement that Acosta forged with Epstein's star-studded legal team. CA/Aronberg-000208 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY i "We think J:i,e1$ f! ·_significant flight .risk, II Berman said of the mart who ferried Britain's Ptihce Andrew,, ·actor Kevin Spacey; famed Harvard lawpro:fessor.Aian Dershowitz and former President Bill Clinton on hisjet, dubbedtheLolita Express. Berman's hard-line stance wa:s, welcomed by young w·omen who for yea~s have been told tnat Epsteincouldn't be touched because Acosta signed ·off oh the nonprosetution agteeme:nt, promising not to charge Epstein infederal court. Fonner Palm Beach County resident Virginia Guiffre, who· has accused Epstein of turning. her into his sex slave and ford:ng her to have sex with others, fndu.dhrg.bershowhz and: Prince Andrew, praised Berman .. He showed the case is "being taken· in a serious way,11 she told the: Associated Press·. Detshowitz has vehemently denfod' Gui'ffre's claims. • New York_ prqseclltor~ were able to ,ignore the controversial nOhprosecutibn agreement because it contained some significant.fine print; sa1d former federal Judge Paul Casseil; who for years Jias-foughtto get the agreement thrown.out. It says. only that no charges could be fikdagainsf Epsteinin South Florida, he said, B,erml:l11 agreed.. "Th~t agree.ment 9nly ·binds, by its terms, only binds the Southern District of Florida/ he said. "The Southern' DistricfofNew York.is not bound by that. agreement and w.:1sn't a signatory ofit." That means the sordid allegations that have been leveled at Epstein for years are now part of a federal indictroent. Contrary to Epstein's claims, he knew the. women who came to his homes in New York and Palm Beach were minors because they told him their ages, according to the indictment. Epstein ·preyed. ony,oung girls because he knew they were "vulnerable_ to explohation," proseq1tors ~dded. As part of a carefully orchestrated sex ring, Epstein .or his asso·ci'ates would call girls while he was in New York so they would be 11vail~ble for sex once he returned to Palm Beach, the indictment says. The ·employees weren't named, They were identified. oniy as. "Enwioyee-1," ''°Ernployee~2'' and ''Ernpfoyee,J. '' To ensure he had a steady stream of young .girls, Epstein would tum some victims into recrµiters. He wot1ld gay tµe111to btipg11e~v girls to his home on El.Brillo Way along the, Irtttacoasfal Waterway in Palm Beach or ro his palatial townhouse on New Y ark's Upper East Side. ''This allowed Epstein to create an ever-expanding web of new victims," Berman said; In both New York and Palm Beac:.l}I the lwid operatfon was simiiar. U1)jde11tifieci employees of Epstein's would. escort the teens into a room. They were-told to take off all .or most of their clothes: b.efore. giving·th~ naked. billionaire massages, c;!Ccordin.g t.o th~ indictment. "Epstein would also- typically ·masturbate during these encounters, a:sk: victims to touch him whlle he masturbated, and touch vi•ctirns' ,genitals with.his h,;mds 9.r with se~ toys/ the indictment says. As part of the crimin~l compiaint,prosecutors _are asking that Epstein be forced to tllm over his multimillion-dollar townhouse on East 71 st Street. The complaint do.es not seek forfeiture of Epstein's house in Paim Beach. • Wl}ile :heartened that Epstein how faces serious crimi11a:l charges in New York, Cassell said he would continue top.ush a West Palm Beach-based federaljudge to throw out the nqnprosecution agreement that Acosta· forged with Epstein's-star-studded lega:l team. CA/Aronberg-000208 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM U.S. District Judge Kenenth Marra has already ruled that Acosta violated the federal Crime Victims' Rights Act by not telling Epstein's victims about the agreement before it was inked. Coincidentally, Cassell arid Epstein attorney Roy Black had to file papers by midnight Monday, explaining what action Marra should take to redress that wrong. Cassell insisted Epstein should face charges in federal court in West Palm Beach. "Florida victims deserve justice in Florida," said Cassell, who is working on behalf of Epstein's victims with attorneys'Bradley Edwards and Jack Scarola. Since it's likely Florida women will getto testify against Epstein in New York, Scarola said, he's not focused on whether Epstein will face charges here. Instead, he said he wants to know how and why the agreement was reached. "There's been no explanation as to how a deal like this could have been cut and how the federal government could have been involved in a conspiracy to violate federal law," Scarola said of his interest in continuing the legal battle over the nonprosecution agreement. When Acosta agreed to drop the federal investigation, Epstein in 2008 pleaded guilty to two prostitution charges and.served 13 months of ah 18-inonth sentence in a vacant wing of the Palm Beach County Jail - a ceil he was allowed to leave. 12 hours a day, six days a week. He was also forced to register as a sex offender and settle civil lawsuits more than 30 young Women filed against him. U.S, Rep. Lois Frankel, D-West Palm Beach, said she shares Scarola's interest in finding out how the agreement came to be."I am especially more interested in why Epstein got the deal he got," Frankel. Said. "We need to know why he was given such an easy sentence. While she has asked,the House Oversight Committee to investigate Acosta, Frankel said she is not sure that will happen. "It just seems to me it was a travesty that this guy got. off the way he did and, without pre-judging it, let's have a proper court case," Frankel said. Former Palm Beach Police Chief Michael Reiter was inflamed in 2006 when then-State Attorney Barry Krispher refused to charge Epstein with serious crimes, Reiter to'ok the information his officers had gathered from dozens of Epstein's victims to Acosta, believing he would prosecute Epstein. He didn't. Reiter said he was heartened that 13 years later, Epstein will finally face justice. "Thankfully, U. S. Attorney Berman and the other authorities in New York have the good judgment to investigate and prosecute Epstein in the way that should have occurred in Florida over a decade ago," Reiter said in a statement. And, Scarola said, there are signals that.Berman's investigation is far from over; Berman declined to answer questions about whether others, such as Epstein's high-powered friends, would be charged. He brushed off questions, about the significance that the investigation was being handled by the Public Corruption Unit. While agents on Saturday were arresting Epstein aboard his private jet at;the Teterboro Airport in New Jersey .after returning:from Paris, other officers were searching his New York City townhouse, Agents seized nude photos of young girls who appeared to be minors, Berman said. He said his focus was on finding more women who were exploited, and abused by Epstein. Turning to a poster,, detailing the charges that had been filed against Epstein, he pointed a finger at a photo of the convicted sex offender who was once described as "a man of mystery." CA/Aronberq-000209 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY i U.S. District J tidge, Ken en th Marta has already ruled that Acosta violated the federal Crime Vktims; Rights Act by noUelling Epstein1s vfctims abou.tthe agreement before 1t was "inked. Coincidentally, Cassell and Epstein attorney Roy Black had to file papers' by midnight Monday, e0:plainir.ig what ac_t1on Marra shouid tak~ JQ redress tha( wrong, - • Cassell insisted Epstein should face charges in federal court in West Palrh Beach. "Florida victims· deserve justice in Fiorida1 i• saicf Cassell,whois, wor:king on behaif ofEpstein's; victims: with attorneys: Bradley Edwards and Jack ScatoHL ,Since it's likeiy Flori cl.~ women wfli get:to testify :against .Epstein jn New York, Scarola s_aid he's not focused on whether Epstein will face charges here. Instead, he said he want~ to know how and why the agreem·ent was reached. • "There's been no explanation as to how a deal like this could have been cut and how the federal government could have been involved in a conspiracy tov1olate foderal law;" Scarola said of his interest in continuing the legal battle. over the nonprosecution agreement When Acosta agreed to .drop the federal investigation, Epstein in 2008 pleaded guilty to two prostitution charges and. served 13 months :of ail 18-month sentence, in ~ vacant wing of the Palm Beach County Jail. - a cell he was_ allowed to leave. 12 hours ,a day, six days a week. He was 'al_so forced to register as a sex offender and settle civil lawsuit,s more tl)an 3.0 young won1en filed ~gainst him. U.S. Rep. Lois :Frankel, D-West Pa.Im Beach, s~id sh~ s_hares_ Scarol?'.~ ipt~rest jn fin.ding oµt how the agreement came to. be, "lam especially more interested in why Epstein got the deal he got," Frankel, said. "We need to know whr he Wa.$ given $UCh an e~y s~nJence. While she has asked, the House Oversight .Committee to investigate Acosta; Frankel said 'she 'is not sure that will happen, "It just seems to me :it:w~s a tn!YY~ty tha.t this gµy got. offJhe way he did and, without pre-'judging it, let's have a proper courf case," Frahkel said .. Former P·alm Beach Police ChiefMichael Reiter wi;ts inflamec:l in 2QQ(i wh~n tb.en_-State Attorney Barry Kris¢herrefose.d to· charge Epstein w.ith serious crimes, Reiter :took the information his officers had gatheryq from dozen$ of ,Ep~t\iip._'s vtctims to A.cost!!, believing he would prosecute Epste'in. He didn't. Reiter said he was heartened that 13 _years later, Epstein w.iUfinally f~ce justice. "ThankfuJly, U. S, Attorney Berman and the other authorities in New York have the go.od judgment to investi'gate and prosecµte Epstein i_n the way that shoµl_d have occµrred 'in Florida: over a decade a::go;" Reiter said in a statement. And, Scarola s.aid, th.ere ctre signaJs that Bynnan's :_i;rivestigaJiQn is Ja.r from pye_r: Berman declined t:o answer questions abo:ut whether others, such as. Ep·steirt's high-pov{ered friends) wouJd be ·charged. He br:1J.shed off qµ,estiops; aboµt the: significance that the investigation was. being handle.ct by the Public Corruption Unit. While agents OT) S_aturday were ?rresting Epstein ~b9w-c;l .his privaty jet at: tbe Teter&oro Airport in New Jersey .after returni:ng;from· Paris, otlfet-officers were. searching his NevtYork City townhouse. Ag_eDts sei:z:ed m1de photos of young girls who- appeared to,be,minors, Berma:Il'.said. He s1:1idhis focus was on fjnding more women who were exploited_ and abused by Epstein. Turning to a poster,. detailing the charges, that had been :filed against Epstein, he poitited a finger at ~ photo of the convicted ,sex. offender who was: once d~scribed as Ila. man of mystery.·'·' CN Aronberg,.000209 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM "If you believe you arc a victim of this man, Jeffrey Epstein, we want to hear from you," Berman said. A special number, 1-800-CALLFBI, will link victims of authorities. Bill Sweeney, assistant director ofthe FBI's New York office, said after years of being ignored by federal agents, the victims7 voices will be heard. "The Jeffrey Epstein matter is No. 1 on the major case list in the country," Sweeney said. Turning to address Epstein's victims directly, he said: "Your bravery may empower others to speak out against crimes against them." CA/Aronberq-000210 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM NOT A CERTIFIED COPY "If you believe you are a victim of this,iii.an, Jeffrey Epstein, we want.to.he-at from you,"' BeIT11~n sai_d.. A specJ,al oumber, l_-8Q0~CALLFBtwill Hnkvictims of al)thorities. Bill Sweeney, assistant director of the FBI's New York office, said after years of being ignored by federaJ agents, tl)e victims' voic~s will be b~ard. • • ·"The Jeffrey Epstein matter is No. 1 ort the major case list in the country," Sweeney said. Tumi.ngtp a4ch:ess EpsteiJJ.'.s victims dih:ctly1 he said: "Your bravery may empower others to speak out against crimes against them." [email protected] CA/ Aronberg-00021 0 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3/27/2023 2:57:43 PM

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