• • I I B. Acosta Exercised Poor Judgment When He Failed to Ensure That Victims Identified in the Federal Investigation Were Informed of the State Plea Hearing Although Acosta (or the USAO) was not required by law or policy to notify victims of the state’s plea hearing, he also was not prohibited by law or policy from notifying the victims that the federal investigation had been resolved through an agreement that included pleas to state charges. As the contemporary records indicate, Acosta consistently expressed hesitancy to interfere in the state’s processes or to “dictate” actions to the State Attorney. His decision that the USAO refrain from notifying victims about the state plea hearing and defer to the State Attorney’s judgment regarding whether and whom to notify was consistent with this view. However, OPR found no evidence that Acosta’s decision to defer victim notification “to the discretion ofthe State Attorney” was ever actually communicated to any state authorities or that Acosta recognized that the state, absent significant coordination with federal authorities, was unlikely to contact all of the victims identified in the state and federal investigations or that the state would inform the victims that it did notify that the state plea hearing was part of an agreement that resolved the federal investigation into their own cases.423 Even taking into account Acosta’s views on principles of federalism and his reluctance to interfere in state processes, Acosta should have recognized the problems that would likely stem from passing the task of notifying victims to the State Attorney’s Office and made appropriate efforts to ensure that those problems were minimized. Appropriate notification would have included advising victims identified in the federal investigation that the USAO had declined to bring charges and that the matter was being handled by the State Attorney, and, at a minimum, provided the victims with Belohlavek’s contact information. Acosta could have interacted with the State Attorney, or instructed Villafana or others to do so, to ensure the state intended to make notifications in a way that reached the most possible victims and that it had the information necessary to accomplish the task. Instead, Acosta deferred the responsibility for victim notification entirely to the State Attorney’s discretion without providing that office with the names of individuals the USAO believed were victims and, apparently, without even informing the state prosecutors that he was deferring to them to make the notifications, if they chose to do so. Epstein was required by the NPA to plead to only two state charges, and even assuming that each charge was premised on a crime against a different victim, and the solicitation charge involved three separate victims, there were thus only at most four victims of the charged state offenses. Without at least inquiring into the state’s intentions, Acosta had no way of determining whether the state intended to notify more than those few victims. Moreover, the federal investigation had resulted in the identification of several victims who had not been identified by inform the victim and to the extent that it will not interfere with Ilie investigation.” See 42 U.S.C. §§ 10607(c)(1)(B) and (c)(3)(A). 423 Through counsel, Acosta argued tliat OPR’s criticism of liim for “electing to ‘defer’ the notification obligation to the state” was inappropriate and “a non sequitur” because “where no federal notification obligation exists, it cannot be deferred.” OPR’s criticism, as explained further below, is not with (lie decision itself, but rather with the fact tliat although Acosta intended for the federal victims to be notified of the state plea hearing, and believed tliat they should receive such notification, he nonetheless left responsibility for such notification to the state without ensuring tliat it had the information needed to do so and without determining the state’s intended course of action. 269 l I CA/Aronberg-000737 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • I B. Acosta Exercised Poor Judgment When He Failed to Ensure That Victims Identified in the Federal Investigation Were Informed of the State Plea Hearing Although Acosta (or the USAO) was not required by law or policy to notify victims of the state's plea hearing, he also was not prohibited by law or policy from notifying the victims that the federal investigation had been resolved through an agreement that included pleas to state charges. As the contemporary records indicate, Acosta consistently expressed hesitancy to interfere in the state's processes or to "dictate" actions to the State Attorney. His decision that the USAO refrain from notifying victims about the state plea hearing and defer to the State Attorney's judgment regarding whether and whom to notify was consistent with this view. However, OPR found no evidence that Acosta's decision to defer victim notification "to the discretion of the State Attorney" was ever actually communicated to any state authorities or that Acosta recognized that the state, absent significant coordination with federal authorities, was unlikely to contact all of the victims identified in the state and federal investigations or that the state would inform the victims that it did notify that the state plea hearing was part of an agreement that resolved the federal investigation into their own cases. 423 Even taking into account Acosta's views on principles of federalism and his reluctance to interfere in state processes, Acosta should have recognized the problems that would likely stem from passing the task of notifying victims to the State Attorney's Office and made appropriate efforts to ensure that those problems were minimized. Appropriate notification would have included advising victims identified in the federal investigation that the USAO had declined to bring charges and that the matter was being handled by the State Attorney, and, at a minimum, provided the victims with Belohlavek's contact information. Acosta could have interacted with the State Attorney, or instructed Villafana or others to do so, to ensure the state intended to make notifications in a way that reached the most possible victims and that it had the information necessary to accomplish the task. Instead, Acosta deferred the responsibility for victim notification entirely to the State Attorney's discretion without providing that office with the names of individuals the USAO believed were victims and, apparently, without even informing the state prosecutors that he was deferring to them to make the notifications, if they chose to do so. Epstein was required by the NPA to plead to only two state charges, and even assuming that each charge was premised on a crime against a different victim, and the solicitation charge involved three separate victims, there were thus only at most four victims of the charged state offenses. Without at least inquiring into the state's intentions, Acosta had no way of determining whether the state intended to notify more than those few victims. Moreover, the federal investigation had resulted in the identification of several victims who had not been identified by infonn the victim and to the extent that it will not interfere with U1e investigation." See 42 U.S.C. §§ 10607(c)(l)(B) and (c)(3)(A). 423 Through counsel, Acosta argued that OPR's criticism of him for "electing tp 'defer' the notification obligation to the state" was inappropriate and "a 11011 sequilur'' because "where no fede'ral notification obligation exists, it cannot be deferred." OPR's criticism, as exl)lained further below, is not with U1~ decision itself, but raU1er with the fact that although Acosta intended for U1e federal victims to be notified of U1e state plea hearing, and believed that they should receive such notification, he nonetheless left responsibility for such notification Lo the state wiU1out ensuring Uiat it had the infomiation needed to do so and wiU1oul determining the state's intended course of action 269 CA/Aronberg-000737 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM the PBPD during its investigation into Epstein’s conduct. Absent information from the USAO, the state would not have been in a position to notify those additional victims of the state plea proceeding, even if the State Attorney had decided to include other victims identified during the state investigation. Furthermore, at the time he made his decision, Acosta had already been advised by Villafana that Belohlavek, in November 2007, had requested that the USAO notify victims, presumably those identified during the federal-investigation, about the state plea hearing. Acosta told OPR that it had been his understanding at the time of Epstein’s plea that the victims would be made aware of the proceeding and would have an opportunity to speak. Acosta also told OPR that he expected the state would have “notified [the victims] that that was an all- encompassing plea, that the state court sentence would also mean that the federal government was not proceeding.” There is no evidence, however, that he verified this understanding with Sloman or Villafana, let alone the State Attorney. OPR found no indication that Acosta ever communicated, or directed Sloman or Villafana to communicate, his decision to the State Attorney or to provide the State Attorney’s Office with a complete list of victims identified during the federal investigation. OPR located a draft letter to the State Attorney’s Office that Villafana prepared and forwarded to Acosta in December 2007, which did provide such information, but OPR found no evidence that the letter was ever sent, and it was not among materials publicly released from the State Attorney’s Office.424 OPR also found evidence that both Sloman and Villafana interacted with the State Attorney’s Office in the months leading up to the June 30, 2008 plea hearing, but there is no indication that they discussed victim notification issues with that office, and Villafana’s last minute request to PBPD Chief Reiter to notify victims indicates that the USAO had not coordinated with the State Attorney’s Office. Belohlavek told OPR that no one from the USAO provided her with a list of victims or coordinated any notification of victims to appear at the hearing. Krischer and Belohlavek were thus evidently unaware that Acosta had decided to leave it to them to decide whether to notify victims about the state proceeding. In the absence of some discussion of which or how many victims the state intended to notify, what the state intended to tell them about Epstein’s plea, and whether the state intended to let the victims speak at the plea hearing, Acosta had no way to ensure that his assumption about victim notification was accurate. In other words, Acosta failed to plan for how all of the identified victims ofEpstein’s crimes, both federal and state, “would be aware of what was happening in the state court and have an opportunity to speak up at the state court hearing.” OPR did not find evidence that Acosta acted for the purpose of excluding victims from the plea hearing, and Acosta’s assumption that the state would handle victim notification appropriately was not unsupported. State prosecutors are subject to victim notification requirements under the Florida Constitution, and the state prosecution offices have victim witness personnel, resources, and processes to help accomplish notification. However, Acosta was aware—through the prosecution memoranda, the draft indictment, and email communications from Villafana—that the USAO’s investigation had expanded beyond those victims identified in the original PBPD 424 The text of the letter indicated that Epstein’s attorneys asked the USAO not to inform victims of “any rights they may have as victims of the charges filed by the State Attorney’s Office” and that the' USAO was providing Ilie State Attorney’s Office with a list of the 33 identified federal victims “in case you are required to provide them with any further notification regarding their rights under Florida law.” 270 i I CA/Aronberg-000738 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • the PBPD during its investigation into Epstein's conduct. Absent information from the USAO, the state would not have been in a position to notify those additional victims of the state plea proceeding, even if the State Attorney had decided to include other victim~ identified during the state investigation. Furthermore, at the time he made his decision, Acosta had already been advised by Villafana that Belohlavek, in November 2007, had requested that the USAO notify victims, presumably those identified during the federal-investigation, about the state plea hearing. Acosta told OPR that it had been his understanding at the time of Epstein's plea that the victims would be made aware of the proceeding and would have an opportunity to speak. Acosta also told OPR that he expected the state would have "notified [the victims] that that was an all- encompassing plea, that the state court sentence would also mean that the federal government was not proceeding." There is no evidence, however, that he verified this understanding with Sloman or Villafana, let alone the State Attorney. OPR found no indication that Acosta ever communicated, or directed Sloman or Villafana to communicate, his decision to the State Attorney or to provide the State Attorney's Office with a complete list of victims identified during the federal investigation. OPR located a draft letter to the State Attorney's Office that Villafana prepared and forwarded to Acosta in December 2007, which did provide such information, but OPR found no evidence that the letter was ever sent, and it was not among materials publicly released from the State Attorney's Office. 424 OPR also found evidence that both Sloman and Villafana interacted with the State Attorney's Office in the months leading up to the June 30, 2008 plea hearing, but there is no indication that they discussed victim notification issues with that office, and Villafana's last minute request to PBPD Chief Reiter to notify victims indicates that the USAO had not coordinated with the State Attorney's Office. Belohlavek told OPR that no one from the USAO provided her with a list of victims or coordinated any notification of victims to appear at the hearing. Krischer and Belohlavek were thus evidently unaware that Acosta had decided to leave it to them to decide whether to notify victims about the state proceeding. In the absence of some discussion of which or how many victims the state intended to notify, what the state intended to tell them about Epstein's plea, and whether the state intended to let the victims speak at the plea hearing, Acosta had no way to ensure that his assumption about victim notification was accurate. In other words, Acosta failed to plan for how all of the identified victims of Epstein's crimes, both federal and state, "would be aware of what was happening in the state court and have an opportunity to speak up at the state court hearing." OPR did not find evidence that Acosta acted for the purpose of excluding victims from the plea hearing, and Acosta's assumption that the state would handle victim notification appropriately was not unsupported. State prosecutors are subject to victim notification requirements under the Florida Constitution, and the state prosecution offices have victim witness personnel, resources, and processes to help accomplish notification. However, Acosta was aware-through the prosecution memoranda, the draft indictment, and email communications frdm Villafana-that the USAO's investigation had expanded beyond those victims identified in the original PBPD 424 The te:\.1 of the letter indicated that Epstein's attorneys asked the USAO not to infonn victims of"any rights they may have as victims of the charges filed by the State Attorney's Office" and that the;usAO was providing U1e State Attorney's Office wiU1 a list of the 33 identified federal victims "in case you are required to provide U1em wiU1 any further notification regarding their rights under Florida law." I 270 CA/Aronberg-000738 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM • • investigation. Because the state indictment and information appeared to pertain to far fewer than the total victims identified in either the state or the federal investigation, and no one at the USAO was certain which victims were covered by the state charges, it should have been apparent to Acosta that without advance planning between the USAO and the State Attorney’s Office, there was a substantial risk that most of the victims identified in the federal investigation would not receive notice ofthe hearing.425 Notification to the broadest possible number of identified victims could only have been successful if there was appropriate communication between the USAO and the state prosecutors, communication that had previously been lacking regarding other significant issues relating to Epstein. Villafana and Sloman’s hastily arranged effort to enlist in the notification process PBPD Chief Reiter, who likely played little role in complying with the state’s victim notification obligations in a typical case, was not an adequate substitute for careful planning and coordination with the State Attorney’s Office.426 Even ifthe State Attorney’s Office had notified all ofthe identified victims ofthe upcoming plea hearing, there was no guarantee that such notification would have included information that the state plea was resolving notjust the state’s investigation ofEpstein, but the federal investigation as well. The State Attorney was not obligated by state statutes to inform the victims of the status of the federal investigation, and there was little reason to assume Krischer, or one of his staff, would voluntarily do so, thereby putting the State Attorney’s Office in the position of fielding victim questions and concerns about the outcome. Furthermore, as both the USAO and the defense had differing views as to who could lawfully participate in the state plea hearing, there is no indication that Acosta, Sloman, or Villafana took steps to confirm that, if victims appeared, they could actually participate in the state court proceeding when they were not victims of the charged • 4?7 crimes. Through counsel, Acosta asserted to OPR that because Villafana and Sloman both told OPR that they believed that state officials would notify the victims, “OPR identified no reason why Secretary Acosta should have distrusted his team on these points.” Acosta’s counsel further 125 Krischer told OPR that the state’s notification obligation extended to all victims identified in tire state investigation. Nonetheless, which victims were encompassed in the state’s investigation was unclear. The PBPD’s probable cause affidavit included crimes against only 5 victims, not the 19 identified in the state investigation. According to state records made public, the state subpoenaed to the grand jury' only 3 victims. After Epstein’s guilty plea, the state sent notification letters to only 2 victims. Belohlavek told OPR that because of the nature of the charges, she did not know whether “technically under the law” the girls were “victims” she was required to notify of the plea hearing. 426 The State Attorney’s Office liad its own procedures and employees who handled victim notification, and Belohlavek told OPR that the Chief of the Police Department would not regularly play a role in the state victim notification process. 427 Although Villafaiia’s notes indicate that she researched Florida Statutes §§ 960.001 and 921.143 when she drafted unsent letters to victims in November and December 2007 inviting them to participate in the state plea hearing pursuant to those statues, the caselaw was not clear that all federal victims would liavc been allowed to participate in the state plea hearing. In Lefkowitz’s November 29, 2007 letter to Acosta, he argued tliat Ilie statutes afforded a right to speak at a defendant’s sentencing or to submit a statement only to the victims of the crime for which the defendant was being sentenced. In April 2008, a Florida District Court of Appeal ruled against a defendant who argued that Florida Statute § 921.143(1) did not allow the testimony of the victim’s relatives at the sentencing hearing. The court ruled that § 921.143(1) “should not be read as limiting the testimony Rule 3.720(b) allows trial courts to consider at sentencing hearings.” Smith v. State. 982 So. 2d 69, 72 (Fla. Dist. Ct. App. 2008). j I 271 | CA/Aronberg-000739 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • I investigation. Because the state indictment and information appeared to pehain to far fewer than I the total victims identified in either the state or the federal investigation, and no one at the USAO was certain which victims were covered by the state charges, it should h~ve been apparent to Acosta that without advance planning between the USAO and the State Attorney's Office, there was a substantial risk that most of the victims identified in the federal in~estigation would not receive notice of the hearing. 425 Notification to the broadest possible number of identified victims could only have been successful if there was appropriate communication between the USAO and the state prosecutors, communication that had previously been lacking regarding other significant issues relating to Epstein. Villafana and Sloman's hastily arranged effort to enlist in the notification process PBPD Chief Reiter, who likely played little role in complying with the state's victim notification obligations in a typical case, was not an adequate substitute for careful planning and coordination with the State Attorney's Office. 426 Even if the State Attorney's Office had notified all of the identified victims of the upcoming plea hearing, there was no guarantee that such notification would have included information that the state plea was resolving not just the state's investigation of Epstein, but the federal investigation as well. The State Attorney was not obligated by state statutes to inform the victims of the status of the federal investigation, and there was little reason to assume Krischer, or one of his staff, would voluntarily do so, thereby putting the State Attorney's Office in the position of fielding victim questions and concerns about the outcome. Furthermore, as both the USAO and the defense had differing views as to who could lawfully participate in the state plea hearing, there is no indication that Acosta, Sloman, or Villafana took steps to confirm that, if victims appeared, they could actually participate in the state court proceeding when they were not victims of the charged crimes. 427 Through counsel, Acosta asserted to OPR that because Villafana and Sloman both told OPR that they believed that state officials would notify the victims, "OPR identified no reason why Secretary Acosta should have distrusted his team on these points." Acosta's counsel further .m Krischer told OPR that the state's notification obligation e:\.iended to all victims identified in the state im,estigation. Nonetheless, which victims were encompassed in the state's investigation was unclear. The PBPD's probable cause affidavit included crimes against only 5 victims, not the 19 identified in the state investigation. According to state records made public, the state subpoenaed to the grand jury only 3 victims. After Epstein's guilty plea, the state sent notification letters to only 2 victims. Belohlavek told OPR that because of the nature of the charges, she did not know whether "technically under the law" the girls were "victims" she was required to notify of the plea hearing. 426 The State Attorney's Office had its own procedures and employees who handled victim notification, and Belohlavek told OPR that the Chief of the Police Department would not regularly play a role in the state victim notification process. 427 Although Villafafia's notes indicate that she researched Florida Statutes§§ 960.001 and 921.143 when she drafted unsent lcllcrs to victims in November and December 2007 inviting them to participate in the state pica hearing pursuant to t11osc statues, t11c casclaw was not clear tliat all federal victims would liavc been allowed to participate in the state plea hearing. In Lefkowitz's November 29, 2007 leller to Acosta, he argued that t11e statutes afforded a right to speak at a defendant's sentencing or to submit a statement only to the victims of the cri1ne for which t11e defendant was being sentenced. In April 2008, a Florida District Court of Appeal ruled against a defendant who argued that Florida Statute§ 921.143(1) did not allow t11e testimony of the victim's relatives at t11e sentencing hearing. The court ruled t11at § 921.143(1) "should not be read as limiting the testimony Rule 3.720(b) allows trial courts to consider at sentencing hearings." Smith v. State, 982 So. 2d 69, 72 (Fla. Dist. Ct. App. 2008). ! 271 CNAronberg-000739 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM argued that Acosta should have been able to rely on his staff to accomplish the victim notification task, and thus had no responsibility to personally confirm that Chief Reiter would notify the victims of the hearing.428 Acosta is correct that under usual circumstances!,USAO management played no role in the victim notification process; however, in this case, the issue of victim notification had been elevated from a rote administrative task to a major area of dispute with the defense. Acosta personally involved himself by resolving the notification dispute with defense counsel in his December 19, 2007 letter. Villafafia provided Acosta with a draft letter to state officials that would have opened a dialogue concerning the notification of all the victims identified in the federal investigation. OPR found no evidence, however, that Acosta sent the letter or any similar communication to the State Attorney’s Office or that he provided Villafafia and Sloman with instructions concerning victim notification other than those contained in his December 19, 2007 letter. Having inserted himself into the notification process, Acosta had a responsibility to ensure that his expectation that the victims would be notified could be accomplished through the state process. Many victims only learned of Epstein’s state court pleas when they later received a letter from the USAO informing them that those pleas had resolved the federal investigation, and some victims only learned of the state court pleas and sentencing from the news media. In the end, although Villafafia and Sloman hastily attempted to ensure victim notification through Chief Reiter, their effort was too little and too late to ensure that victims had the opportunity to attend the plea hearing or were given sufficient information about its significance to their own cases.429 Although Acosta may have conferred with others about the decision to defer the responsibility for notifying victims to the State Attorney, Acosta was responsible for choosing this course of action. OPR concludes that under these unique circumstances, its criticisms are warranted because Acosta personally decided to change the process initiated by his staff, and although he expected that the federal victims would be notified, he did not take the necessary steps to ensure that they would be. Acosta could have authorized disclosure of the plea hearing to victims, even if he did not believe the CVRA required it, to ensure that the victims identified in the federal investigation were aware ofthe state court proceeding. Because the state pleas ended the federal investigation into Epstein’s conduct, ensuring that the victims were notified of the state plea hearing would have been consistent with the Department’s overarching commitment to treat victims with fairness, dignity, and sensitivity. Acosta’s failure to prioritize notification and coordinate communication about the 428 As noted, in his comments on OPR’s draft report, Acosta’s counsel strongly objected to OPR’s finding of poorjudgment with respect to victim notification, arguing that OPR “unwarranted!}’ applies a standard never before expected of any US Attorney,” and inappropriately criticizes Acosta for “not personally confirming that the State Attorney had the information needed” to notify the victims and for “not personally confirming” that Chief Reiter liad actually notified the victims. For the reasons discussed, the issue is not whether Acosta “personally” took certain specific steps but that he stopped Iris staff from implementing a notification plan they had devised, and instead, shifted responsibility’ for notification to another entity’ while failing to consider how or even whether that entity' would be able to accomplish the notification that Acosta expected to happen. 429 OPR notes that Villafafia contacted Reiter soon after the state plea hearing was scheduled, and the resulting window of time for Reiter to make any notifications was short. Had the USAO coordinated with the State Attorney at some point in time closer to Acosta’s December 19, 2007 letter and decision, the USAO could have ensured that the State Attorney had an appropriate notification process in place to act quickly when the hearing was scheduled and tliat issues concerning the victims’ appearance at the hearing were appropriately considered by state authorities. Similarly, if the USAO believed that Reiter should make the notifications, it could have coordinated with Reiter in the months tliat the matter was under review by the Department. ! j 272 CA/Aronberg-000740 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY • • argued that Acosta should have been able to rely on his staff to accomplish the victim notification task, and thus had no responsibility to personally confirm that Chief Reher would notify the victims of the hearing. 428 Acosta is correct that under usual circumstances[ USAO management played no role in the victim notification process; however, in this case; the issue of victim notification had been elevated from a rote administrative task to a major area of dispute with the defense. Acosta personally involved himself by resolving the notification dispute with defense counsel in his December 19, 2007 letter. Villafana provided Acosta with a draft letter to state officials that would have opened a dialogue concerning the notification of all the victims identified in the federal investigation. OPR found no evidence, however, that Acosta sent the letter or any similar communication to the State Attorney's Office or that he provided Villafana and Sloman with instructions concerning victim notification other than those contained in his December 19, 2007 letter. Having inserted himself into the notification process, Acosta had a responsibility to ensure that his expectation that the victims would be notified could be accomplished through the state process. Many victims only learned of Epstein's state court pleas when they later received a letter from the USAO informing them that those pleas had resolved the federal investigation, and some victims only learned of the state court pleas and sentencing from the news media. In the end, although Villafana and Sloman hastily attempted to ensure victim notification through Chief Reiter, their effort was too little and too late to ensure that victims had the opportunity to attend the plea hearing or were given sufficient information about its significance to their own cases. 429 Although Acosta may have conferred with others about the decision to defer the responsibility for notifying victims to the State Attorney, Acosta was responsible for choosing this course of action. OPR concludes that under these unique circumstances, its criticisms are warranted because Acosta personally decided to change the process initiated by his staff, and although he expected that the federal victims would be notified, he did not take the necessary steps to ensure that they would be. Acosta could have authorized disclosure of the plea hearing to victims, even if he did not believe the CVRA required it, to ensure that the victims identified in the federal investigation were aware of the state court proceeding. Because the state pleas ended the federal investigation into Epstein's conduct, ensuring that the victims were notified of the state plea hearing would have been consistent with the Department's overarching commitment to treat victims with fairness, dignity, and sensitivity. Acosta's failure to prioritize notification and coordinate communication about the 428 As noted, in his conunents on OPR's draft report, Acosta's counsel strongly objected to OPR's finding of poor judgment with respect to victim notification, arguing that OPR "unwarrantedly applies a standard never before expected of any US Attorney," and inappropriately criticizes Acosta for "not personally confirming that the State Attorney had the information needed" to notify the victims and for "not personally confirming" that Chief Reiter had actually notified the victims. For the reasons discussed, the issue is not whether Acosta "personally" took certain specific steps but that he stopped his staff from implementing a notification plan they had devised, and instead, shifted responsibility for notification to another entity while failing to consider how or even whether that entity would be able to accomplish the notification that Acosta ex-peeled to happen. 429 OPR notes that Villafana contacted Reiter soon after the stale pica hearing was scheduled, and the resulting window of time for Reiter to make any notifications was short. Had the USAO coordinated with the State Attorney at some point in time closer to Acosta's December 19, 2007 letter and decision, the USA9 could have ensured that the State Attorney had an appropriate notification process in place to act quickly when the hearing was scheduled and that issues concerning the victims' appearance at the hearing were appropriately considered by slate authorities. Similarly. if the USAO believed that Reiter should make the notifications. it could have cocirdinated with Reiter in the months tl~t the matter was under review by the Department. • ! . ' 272 CA/Aronberg-000740 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. ~/28/2023 2:22:44 PM I resolution of the case to ensure Epstein’s victims were given an opportunity to attend the plea hearing, and to possibly speak about the impact of Epstein’s crimes, presented a glaring contrast with Acosta’s responsiveness to the demands of Epstein’s attorneys, which)included the unusual courtesy of allowing them to preview and respond to the USAO’s draft victim notifications. This contrast added to the victims’ perception that they had been treated unfairly,' a view shared by the public. Nothing in the documentary record suggests that Acosta thought through the issue of determining which victims would be notified by the state, or that he took any steps to ensure that all ofthe known federal victims received information about the state plea hearing. Instead, as with his decision to resolve the federal investigation through a state-based resolution, Acosta exercised poorjudgment when he made critical decisions affecting the federal investigation and the victims, but also failed to consider the full consequences of those decisions or what was needed to implement them. Acosta’s failure to consider these issues before simply leaving the responsibility for making notifications entirely to the State Attorney’s discretion reflected poorly on the USAO and the Department as a whole. It left victims in the dark about an important proceeding that resolved the federal investigation, an investigation about which the USAO had communicated with victims for months. It also ultimately created the misimpression that the Department intentionally sought to silence the victims by keeping them uninformed about the NPA and the resulting state proceeding. Acosta failed to ensure that victims were afforded an opportunity to attend a hearing that was related to their own cases and thus failed to ensure that victims were treated with forthrightness and dignity. V. VILLAFANA DID NOT COMMIT PROFESSIONAL MISCONDUCT IN HER ORAL COMMUNICATIONS TO VICTIMS AND VICTIMS’ ATTORNEYS, IN WHICH SHE DESCRIBED THE CASE AS “UNDER INVESTIGATION” BUT DID NOT DISCLOSE THE EXISTENCE OF THE NPA TO SOME VICTIMS From September 24, 2007, when the NPA was signed, until after Epstein’s June 30, 2008 state court plea, the case agents, acting under Villafana’s direction, directly informed only three victims-that the government had signed an NPA and that, if Epstein complied with its terms, the federal investigation would be closed. During this time period, Villafana and the case agents interacted with several victims and their attorneys, and Villafana contacted victims’ attorney Bradley Edwards to encourage him to attend the state court plea hearing, but she did not inform victims or Edwards of the NPA or the resolution of the federal investigation. As described in Part One of this chapter, after the NPA was signed, the FBI case agent and co-case agent began notifying victims about the NPA.430 After speaking to three victims, however, the FBI case agent became concerned that informing the victims about the NPA and the monetary damages provision would create potential impeachment material for the victims and the agent should Epstein breach the NPA and the case proceed to indictment and trial. As the case agent told OPR, “I would . . . have to testify that I told every one of these girls that they could sue Mr. Epstein for money, and I was not comfortable with that, I didn’t think it was right.” The case 430 Although Wild disputed that she was informed of the resolution of the federal case, the case agent’s email to Villafana from this time period reflects tliat at least one victim understood dial the federal case was resolved and tliat she was unhappy with the resolution. i I 273 CA/Aronberg-000741 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • resolution of the case to ensure Epstein's victims were given an opportunity to attend the plea hearing, and to possibly speak about the impact of Epstein's crimes, prese~ted a glaring contrast with Acosta's responsiveness to the demands of Epstein's attorneys, whichlincluded the unusual courtesy of allowing them to preview and respond to the USAO' s draft victim notifications. This contrast added to the victims' perception that they had been treated unfairly; a view shared by the public. Nothing in the documentary record suggests that Acosta thought through the issue of determining which victims would be notified by the state, or that he took any steps to ensure that all of the known federal victims received information about the state plea hearing. Instead, as with his decision to resolve the federal investigation through a state-based resolution, Acosta exercised poor judgment when he made critical decisions affecting the federal investigation and the victims, but also failed to consider the full consequences of those decisions or what was needed to implement them. Acosta's failure to consider these issues before simply leaving the responsibility for making notifications entirely to the State Attorney's discretion reflected poorly on the USAO and the Department as a whole. It left victims in the dark about an important proceeding that resolved the federal investigation, an investigation about which the USAO had communicated with victims for months. It also ultimately created the misimpression that the Department intentionally sought to silence the victims by keeping them uninformed about the NP A and the resulting state proceeding. Acosta failed to ensure that victims were afforded an opportunity to attend a hearing that was related to their own cases and thus failed to ensure that victims were treated with forthrightness and dignity. V. VILLAFANA DID NOT COMMIT PROFESSIONAL MISCONDUCT IN HER ORAL COMMUNICATIONS TO VICTThfS AND VICTThfS' ATTORNEYS, IN WHICH SHE DESCRIBED THE CASE AS "UNDER INVESTIGATION" BUT DID NOT DISCLOSE THE EXISTENCE OF THE NPA TO SOME VICTThfS From September 24, 2007, when the NPA was signed, until after Epstein's June 30, 2008 state court plea, the case agents, acting under Villafana's direction, directly informed only three victims-that the government had signed an NPA and that, if Epstein complied with its terms, the federal investigation would be closed. During this time period, Villafana and the case agents interacted with several victims and their attorneys, and Villafana contacted victims' attorney Bradley Edwards to encourage him to attend the state court plea hearing, but she did not inform victims or Edwards of the NPA or the resolution of the federal investigation. I As described in Part One of this chapter, after the NP A was signed, the FBI case agent and co-case agent began notifying victims about the NP A. 430 After speaking to three victims, however, the FBI case agent became concerned that informing the victims about the NP A and the monetary damages provision would create potential impeachment material for the victims and the agent should Epstein breach the NP A and the case proceed to indictment and trial. As the case agent told OPR, "I would ... have to testify that I told every one of these girls that they could sue Mr. Epstein for money, and I was not comfortable with that, I didn't think it was right." The case 430 Although Wild disputed that she was infonned of the resolution of the federal case, the case agent's email to Villafana from this time period reflects that at least one victim understood that the federal base was resolved and that she was unhappy wit11 the resolution. I I I 273 CA/Aronberg-0007 41 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM ' ! agent and Villafana consulted with the USAO’s Professional Responsibility Officer about the matter, and thereafter stopped notifying the victims about the NPA and their ability to pursue monetary damages according to its terms. ■ Villafana advised Sloman by email of her concerns regarding the potential impeachment evidence, telling him, “One thing I am concerned about is that, if we [file charges] now, cross- examination will consist of- ‘and the government told you that ifMr. Epstein is convicted, you are entitled to a large amount of damages right?’” Explaining the decision in her later CVRA declaration, Villafana said that after Epstein’s attorneys “complained that the victims were receiving an incentive to overstate their involvement with Mr. Epstein in order to increase their damages claims,” she “concluded that informing additional victims could compromise the witnesses’ credibility at trial if Epstein reneged on the agreement.” Acosta was aware of these concerns as he referred to them in an August 2008 email, “[W]e also believed that contacting the victims would compromise them as potential witnesses. Epstein argued very forcefully that they were doing this for the money, and we did not want to discuss liability with them, which was [a] key part of [the] agree[ment].” The case agents interviewed victims in October and November 2007, but did not inform them about the NPA.431 On January 31, 2008, the FBI agents, Villafana, and the CEOS Trial Attorney interviewed three victims, including Courtney Wild, and they interviewed at least one more victim the next day.432 Wild and two others had been contacted by the FBI in the fall of 2007 and may have been informed about the resolution of the federal investigation. Villafana told OPR that during the January 31, 2008 interviews, she did not specifically tell the victims that “there was a signed non-prosecution agreement that had these terms.” She stated that she would not use “terminology” such as “NPA” because “most people don’t understand what that means.” Instead, with respect to the three victims who, according to Villafana, had been informed by the FBI about the resolution, she stated that “an agreement had been reached where [Epstein] was going to be entering a guilty plea, but it doesn’t look [like] he intends to actually perform . . . [and] now it looks like this may have to be charged . . . and may have to go to trial.” Villafana recalled telling some victims that Epstein “was supposed to enter a plea in state court” that would end the investigation, but she did not recall distinguishing between the “federal investigation versus a state investigation.” Villafana told OPR she explained “the case was under investigation,” she and the agents “were preparing . . . again” to file charges, and they hoped “that charges would be brought.” An email from Villafana to Sloman and Acosta during this time period reflects that she had such discussions with at least one victim interviewed on this date: “The second girl . . . was very upset about the 18 month deal she had read about in the paper. . . . [S]he would rather not get any money and have Epstein spend a significant time in jail.” Villafana, however, did not recall telling all of the victims interviewed at this time of the state plea; rather, she likely only told those who knew about the resolution from the FBI. In her own 2015 CVRA- case declaration, Wild stated that she “was not told about any [NPA] or any potential resolution of 431 FBI agents also interviewed victims in March and May of 2008, without prosecutors, and did not inform the victims of the NPA. 432 Two additional victims were scheduled to be interviewed on February 1, 2008, but the evidence is unclear as to whether the interviews occurred. ; 274 CA/Aronberg-000742 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY • • I I agent and Villafana consulted with the USAO's Professional Responsibility Officer about the matter, and thereafter stopped notifying the victims about the NP A and t~eir ability to pursue monetary damages according to its terms. Villafana advised Sloman by email of her concerns regarding the potential impeachment evidence, telling him, "One thing I am concerned about is that, if we [file charges] now, cross- examination will consist of- 'and the government told you that if Mr. Epstein is convicted, you are entitled to a large amount of damages right?"' Explaining the decision in her later CVRA declaration, Villafana said that after Epstein's attorneys "complained that the victims were receiving an incentive to overstate their involvement with Mr. Epstein in order to increase their damages claims," she "concluded that informing additional victims could compromise the witnesses' credibility at trial if Epstein reneged on the agreement." Acosta was aware of these concerns as he referred to them in an August 2008 email, "[W]e also believed that contacting the victims would compromise them as potential witnesses. Epstein argued very forcefully that they were doing this for the money, and we did not want to discuss liability with them, which was [a] key part of [the] agree[ment]." The case agents interviewed victims in October and November 2007, but did not inform them about the NPA. 431 On January 31, 2008, the FBI agents, Villafana, and the CEOS Trial Attorney interviewed three victims, including Courtney Wild, and they interviewed at least one more victim the next day. 432 Wild and two others had been contacted by the FBI in the fall of 2007 and may have been informed about the resolution of the federal investigation. Villafana told OPR that during the January 31, 2008 interviews, she did not specifically tell the victims that "there was a signed non-prosecution agreement that had these terms." She stated that she would not use "terminology" such as "NP A" because "most people don't understand what that means." Instead, with respect to the three victims who, according to Villafana, had been informed by the FBI about the resolution, she stated that "an agreement had been reached where [Epstein] was going to be entering a guilty plea, but it doesn't look [like] he intends to actually perform ... [and] now it looks like this may have to be charged ... and may have to go to trial." Villafana recalled telling some victims that Epstein "was supposed to enter a plea in state court" that would end the investigation, but she did not recall distinguishing between the "federal investigation versus a state investigation." Villafana told OPR she explained "the case was under investigation," she and the agents "were preparing ... again" to file charges, and they hoped "that charges would be brought." An email from Villafana to Sloman and Acosta during this time period reflects that she had such discussions with at least one victim interviewed on this date: "The second girl ... was very upset about the 18 month deal she had read about in the paper. . . . [S]he would rather not get any money and have Epstein spend a significant time in jail." Villafana, however, did not recall telling all of the victims interviewed at this time of the state plea; rather, she likely only told those who knew about the resolution from the FBI. In her own 2015 CVRA- case declaration, Wild stated that she "was not told about any [NP A] or any potential resolution of 431 FBI agents also interviewed victims in March and May of 2008, without prosecutors, and did not inform the victims of the NP A. 1 I Two additional victims were scheduled to be interviewed on February L 2008. but the evidence is unclear as • . . I to whether the interviews occurred. : 432 274 CA/Aronberg-000742 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3./28/2023 2:22:44 PM the federal investigation I was cooperating in. If I had been told of a[n NPA], I would have objected.” Wild further stated in her declaration that, “Based on what the FBI had been telling me, I thought they were still investigating my case.” Neither the CEOS Trial Attorney nor the FBI case agent recalled the specifics ofthe victim interviews. The FBI reports memorializing each interview primarily addressed the facts elicited from the victim regarding Epstein’s abuse and did not describe any discussion about the status of the case or the victim’s view about the prosecution ofEpstein.433 When asked whether she was concerned that failing to tell victims about the NPA when she was interviewing them would mislead victims, as previously noted, Villafana told OPR that she believed she and the agents were conducting an investigation because they continued “interviewing witnesses” and “doing all these things” to file charges and prepare for a federal trial. As Villafana stated, “So to me, saying to a victim the case is now back under investigation is perfectly accurate.” Villafana was also aware that some victims were represented by counsel in connection with civil lawsuits against Epstein, but did not proactively inform the victims’ attorneys about the NPA. In a 2017 affidavit filed in the CVRA litigation, victims’ attorney Bradley Edwards alleged that during telephone calls with Villafana, he “asked very specific questions about what stage the investigation was in,” and Villafana replied that she could not answer his questions because the matter “was an on-going active investigation.” Edwards stated that Villafana gave him “the impression that the Federal investigation was on-going, very expansive, and continuously growing, both in the number of identified victims and complexity.” Edwards also stated, “A fair characterization of each call was that I provided information and asked questions and Villafana listened and expressed that she was unable to say much or answer the questions I was asking.” In her written response to OPR, Villafana stated that she “listened more than [she] spoke” during her interactions with Edwards and that due to the “uncertainty of the situation” and the possibility of a trial, she “did not feel comfortable sharing any information about the case.” Villafana also told OPR that because of “all of these concerns and instructions that I had been given by Alex [Acosta] and Jeff [Sloman] not to disclose things further and not to have any involvement in victim notification,” she felt “prohibited” from providing additional information to Edwards. Sloman told OPR that although neither the NPA terms nor the CVRA prevented the USAO from exercising its discretion to notify the victims, “[I]t was [of] concern that this was going to break down and ... result in us prosecuting Epstein and that the victims were going to be witnesses and if we provided a victim notification indicating, hey, you’re going to get $150,000, that’s . . . going to be instant impeachment for the defense.”434 Acosta told OPR that, because Epstein did As noted above, the FBI agent’s notes for one victim’s interview reported that she wanted another victim to be prosecuted. 434 When asked why the USAO did not simply notify' the victims of the change of plea hearing, Sloman responded that he “was more focused on the restitution provisions. I didn’t get the sense that Ilie victims were overly interested in showing up ... at the change of plea.” 275 CA/Aronberg-000743 I FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY • • I the federal investigation I was cooperating in. If I had been told of a[n INPA], I would have objected." Wild further stated in her declaration that, "Based on what the FBI had been telling me, I thought they were still investigating my case." I Neither the CEOS Trial Attorney nor the FBI case agent recalled the specifics of the victim interviews. The FBI reports memorializing each interview primarily addressed the facts elicited from the victim regarding Epstein's abuse and did not describe any discussion about the status of the case or the victim's view about the prosecution of Epstein. 433 When asked whether she was concerned that failing to tell victims about the NP A when she was interviewing them would mislead victims, as previously noted, Villafana told OPR that she believed she and the agents were conducting an investigation because they continued "interviewing witnesses" and "doing all these things" to file charges and prepare for a federal trial. As Villafana stated, "So to me, saying to a victim the case is now back under investigation is perfectly accurate." Villafana was also aware that some victims were represented by coun,sel in connection with civil lawsuits against Epstein, but did not proactively inform the victims' attorneys about the NP A. In a 2017 affidavit filed in the CVRA litigation, victims' attorney Bradley Edwards alleged that during telephone calls with Villafana, he "asked very specific questions about what stage the investigation was in," and Villafana replied that she could not answer his questions because the matter "was an on-going active investigation." Edwards stated that Villafana gave him "the impression that the Federal investigation was on-going, very expansive, and continuously growing, both in the number of identified victims and complexity." Edwards also stated, "A fair characterization of each call was that I provided information and asked questions and Villafana listened and expressed that she was unable to say much or answer the questions I was asking." In her written response to OPR, Villafana stated that she "listened more than [she] spoke" during her interactions with Edwards and that due to the "uncertainty of the situation" and the possibility of a trial, she "did not feel comfortable sharing any information about the case." Villafana also told OPR that because of "all of these concerns and instructions that I had been given by Alex [Acosta] and Jeff [Sloman] not to disclose things further:and not to have any involvement in victim notification," she felt "prohibited" from providing additional information I to Edwards. Sloman told OPR that although neither the NP A terms nor the CVRA prevented the USAO from exercising its discretion to notify the victims, "[I]t was [of] concern that this was going to break down and ... result in us prosecuting Epstein and that the victims were going to be witnesses and ifwe provided a victim notification indicating, hey, you're going to get $150,000, that's ... going to be instant impeachment for the defense." 434 Acosta told OPR that, because Epstein did m As noted above, the FBI agent's notes for one victim's interview reported that she wanted another victim to be prosecuted. 434 When asked why the USAO did not simply notify the victims of the change of plea hearing, Sloman responded that he "was more focused on the restitution provisions. I didn't gel the sense that the victims were overly interested in showing up ... at the change of plea." I ! I 275 I CN Aronberg-0007 43 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM not plead guilty in October 2007 as the USAO expected, it was a “very op'en question” whether the case would go to trial, and Acosta thought that “where there is no legal requirement[,] [t]here has to be discretion to judge how much you can tell the victims and when.” Epstein’s attorneys’ conduct during the period between the signing of the NPA and Epstein’s entry of his state guilty pleas illustrated the risk that Acosta, Sloman, and Villafana all identified. As Epstein’s counsel deposed victims related to the state court criminal charges and civil cases against Epstein, counsel suggested that the victims were motivated to testify against Epstein by the government’s promises of financial gain. For example, during a February 20, 2008 state deposition of a victim, defense counsel asked her whether the federal prosecutors or FBI agents told her that she was entitled to receive money from Epstein.435 In her 2017 declaration in the CVRA litigation, Villafana identified that line of questioning as a motivating factor in the government’s decision to stop notifying the victims about the potential for 18 U.S.C. § 2255 recovery. On June 27, 2008, the Friday before Epstein’s Monday, June 30, 2008 state court guilty plea hearing, Villafana contacted Edwards to inform him about that upcoming hearing. Villafana told OPR she “was not given authorization to contact” any victim’s attorney other than Edwards about the scheduled state plea hearing.436 In his 2017 affidavit prepared for the CVRA litigation, Edwards stated that Villafana “gave the impression that she was caught off-guard herself that Epstein was pleading guilty or that this event was happening at all.” Edwards said in a 2016 court filing that Villafana told him only that “Epstein was pleading guilty to state solicitation of prostitution charges involving other victims—not Mr. Edward’s clients nor any of the victims.” Villafana stated in her 2017 declaration that she “never told Attorney Edwards that the state charges involved ‘other victims,’ and neither the state court charging instrument nor the factual proffer limited the procurement of prostitution charge to a specific victim.” Villafana told OPR she “strongly encouraged [Edwards] and his clients to attend” the plea hearing but “could not be more explicit” because she was not “authorized by the Office to disclose the terms of the NPA.” In his 2017 affidavit, Edwards acknowledged that “Villafana did express that this hearing was important, but never told me why she felt that way.” Edwards claimed that Villafana’s failure to inform him that the “guilty pleas in state court would bring an end to the possibility of federal prosecution pursuant to the plea agreement” resulted in his clients not attending the hearing. Edwards himself was out of town and not able to 435 As previously noted, the defense used Florida criminal procedure to depose potential federal victims to learn information concerning the federal investigation even though those individuals were not involved in the state prosecution. For example, in a March 2008 email, Villafana informed her managers tliat she spoke to a victim who had received a subpoena “issued in connection with the state criminal case, which, as you know, doesn’t involve most of the victims in our case (including the girl who was subpoenaed).” Villafana further observed that because Epstein is “going to plead to the solicitation ofadults for prostitution charge [in state court], [the act of subpoenaing the victim] seems to be a clear effort to find out about our case through the state case.” 436 Villafana’s June 30, 2008 handwritten notes reflect tliat, at the time of Epstein’s state court guilty plea, Villafana was aware of the identities of a least five oilier attorneys representing Epstein'S victims. In her written response to OPR, Villafana stated, “I requested permission to make oral notifications tojthe victims regarding the upcoming change of plea, but the Office decided dial victim notification could only come from a state investigator, and Jeff Sloman asked PBPD Cliief Reiter to assist.” On Saturday, June 28,2008, VillafanajemailedSloman to inform him tliat PBPD Cliief Reiter “is going to notify victims about the plea.” Sloman replied, “Good.” 276 CA/Aronberg-000744 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY • • not plead guilty in October 2007 as the USAO expected, it was a "very open question" whether the case would go to trial, and Acosta thought that "where there is no legal ~equirement[,] [t]here has to be discretion to judge how much you can tell the victims and when." I Epstein's attorneys' conduct during the period between the signing of the NPA and Epstein's entry of his state guilty pleas illustrated the risk that Acosta, Sloman, and Villafana all identified. As Epstein's counsel deposed victims related to the state court criminal charges and civil cases against Epstein, counsel suggested that the victims were motivated to testify against Epstein by the government's promises of financial gain. For example, during a February 20, 2008 state deposition of a victim, defense counsel asked her whether the federal prosecutors or FBI agents told her that she was entitled to receive money from Epstein. 435 In her 2017 declaration in the CVRA litigation, Villafana identified that line of questioning as a motivating factor in the government's decision to stop notifying the victims about the potential for 18 U.S.C. § 2255 recovery. On June 27, 2008, the Friday before Epstein's Monday, June 30, 2008 state court guilty plea hearing, Villafana contacted Edwards to inform him about that upcoming hearing. Villafana told OPR she "was not given authorization to contact" any victim's attorney other than Edwards about the scheduled state plea hearing. 436 In his 2017 affidavit prepared for the CVRA litigation, Edwards stated that Villafana "gave the impression that she was caught off-guard herself that Epstein was pleading guilty or that this event was happening at all." Edwards said in a 2016 court filing that Villafana told him only that "Epstein was pleading guilty to state solicitation of prostitution charges involving other victims-not Mr. Edward's clients nor any of the federally-identified victims." Villafana stated in her 2017 declaration that she "never told Attorney Edwards that the state charges involved 'other victims,' and neither the state court charging instrument nor the factual proffer limited the procurement of prostitution charge to a specific victim." Villafana told OPR she "strongly encouraged [Edwards] and his clients to attend" the plea hearing but "could not be more explicit" because she was not "authorized by the Office to disclose the terms of the NP A." In his 2017 affidavit, Edwards acknowledged that "Villafana did express that this hearing was important, but never told me why she felt that way." Edwards claimed that Villafana's failure to inforn1 him that the "guilty pleas in state court would bring an end to the possibility of federal prosecution pursuant to the plea agreement" resulted in his clients not attending the hearing. Edwards himself was out of town and not able to 435 As previously noted, the defense used Florida criminal procedure to depose potent,ial federal victims to learn information concerning the federal investigation even though those individuals were not involved in the state prosecution. For example, in a March 2008 email, Villafafia infonned her managers that she spoke to a victim who had received a subpoena "issued in connection wit11 the state criminal case, which, as you ki-10w, doesn't involve most of the victims in our case (including the girl who was subpoenaed)." Villafafia further observed that because Epstein is "going to plead to t11e solicitation of adults for prostitution charge [in state court], [the act of subpoenaing the victim] seems to be a clear effort to find out about our case through t11e state case." 436 Villafafia's June 30. 2008 handwrilten notes reflect that. at t11e time of Epstein's state court guilty plea. Villafana was aware of the identities of a least five ot11er altorne)'S representing Epstein;s victims. In her writte~ response to OPR, Villafana stated, "I requested pennission to make oral notifications toj t11e victims regarding the upcoming change of plea, but Ute Office decided t11c1t victim notification could only come from a state investigator, and JeJI Sloman asked PBPD Chief Reiter to assist." On Saturday. June 28. 2008. Villafafia1emailed Sloman to infonn him that PBPD Chief Reiter "is going to notify victims about the .plea." Siornan.replied, "<;}ood." 276 CA/ Aronberg-0007 44 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. V28/2023 2:22:44 PM • • attend the hearing. In his affidavit, Edwards asserted, “[T]here was no possible way I could have believed that this state plea could affect the federal investigation or the rights of my clients in that federal investigation.” I In Wild, the Eleventh Circuit panel stated that the government “seemingly” deferred to Epstein’s attorneys’ requests not to notify the victims about the NPA, and that in sending the January and May 2008 FBI letters, the government’s efforts “seem to have graduated from passive nondisclosure to (or at least close to) active misrepresentation.”437 Although both the appellate court and district court focused on the FBI’s letters for which OPR concludes that neither Villafana, Sloman, nor Acosta was responsible, OPR considered the courts’ analyses in evaluating whether similar representations Villafana made to the victims whom she interviewed on January 31 and February 1, 2008, and to Edwards, were misleading. Therefore, OPR considered whether Villafana’s statements that the matter was “under investigation” and her failure to inform all ofthe victims whom she interviewed or Edwards about the NPA violated FRPC 4-4.1(a), 4-8.4(c), or 4-8.4(d). FRPC 4-4.1(a) prohibits an attorney from “knowingly makfing] a false statement of material fact or law to a third person” during the representation of a client. The FRPC defines “knowingly” as “denot[ing] actual knowledge of the fact in question” and states that such knowledge may be “inferred from circumstances.”438 The comment to FRPC 4-4.1 states that “[m]isrepresentations can also occur by partially true but misleading statements or omissions that are the equivalent of affirmative false statements.” The comment references FRPC 4-8.4 “[f]or dishonest conduct that does not amount to a false statement.” Like FRPC 4-4.1(a), Rule 4-8.4(c) requires evidence that the attorney knew the statement in question wasfalse. Under FRPC 4-8.4(c), the intent requirement can be satisfied “merely by showing that the conduct was deliberate or knowing” and the “motive underlying the lawyer’s conductis not determinative; instead the issue is whether he or she purposefully acted.”439 In Feinberg, the court concluded that the prosecutor violated FRPC 4-4.1 and 4-8.4(c) and (d) by deliberately making untruthful statements to a defense attorney, despite evidence that the prosecutor intended to help the defendant by making the statements.440 In this case, Villafana was fully aware ofthe signed NPA when she interviewed the victims on January 31 and February 1, 2008, arid when she spoke to Edwards on the telephone, but she did not inform them specifically of the signed NPA. The question is whether this omission amounted to a knowing false statement of misrepresentation. One difficulty is determining what Villafana actually said duririg conversations that participants were asked to recall many years later. With respect to three of the victims whom she interviewed in January and February 2008, Villafana contended that she discussed the agreement with them, even if she did not specifically refer to it as the NPA or discuss all of its terms, and as 437 Wild, 955 F.3d at 1199-1200. ; 438 See R. Regulating Fla. Bar 4-Preamble: A Lawyer's Responsibilities, “Terminology/' 439 Florida Bar v. Schwartz, 284 So. 3d 393, 396 (Fla. 2019) (citing Florida Bar v. Berthiaume, 78 So. 3d 503, 510 n.2 (Fla. 2011); Florida Bar v. Riggs, 944 So. 2d 167, 171 (Fla. 2006); Florida Bar v. Smith, 866 So. 2d 41, 46 (Fla. 2004)). ] 440 Florida Bar v. Feinberg, 760 So. 2d 933, 937-38 (Fla. 2000). 277 CA/Aronberg-000745 I FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY • • I attend the hearing. In his affidavit, Edwards asserted, "[T]here was no possible way I could have believed that this state plea could affect the federal investigation or the right 1s of my clients in that federal investigation." / In Wild, the Eleventh Circuit panel stated that the government "sJemingly" deferred to Epstein's attorneys' requests not to notify the victims about the NPA, and that in sending the January and May 2008 FBI letters, the government's efforts "seem to have graduated from passive nondisclosure to (or at least close to) active misrepresentation."437 Although both the appellate court and district court focused on the FBI' s letters for which OPR concludes that neither Villafana, Sloman, nor Acosta was responsible, OPR considered the courts' analyses in evaluating whether similar representations Villafana made to the victims whom she interviewed on January 31 and February 1, 2008, and to Edwards, were misleading. Therefore, OPR considered whether Villafana's statements that the matter was "under investigation" and her failure to inform all of the victims whom she interviewed or Edwards about the NPA violated FRPC 4-4. l(a), 4-8.4(c), or 4-8.4(d). FRPC 4-4. l(a) prohibits an attorney from "knowingly mak[ing] a false statement of material fact or law to a third person" during the representation of a client. The FRPC defines "knowingly" as "denot[ing] actual knowledge of the fact in question" and states that such knowledge may be "inferred from circumstances."438 The comment to FR.PC 4-4.1 states that "[m]isrepresentations can also occur by partially true but misleading statements or omissions that are the equivalent of affirmative false statements." The comment references FRPC 4-8.4 "[f]or dishonest conduct that does not amount to a false statement." Like FRPC 4-4. l(a), Rule 4-8.4(c) requires evidence that the attorney knew the statement in question was: false. Under FRPC 4-8.4(c), the intent requirement can be satisfied "merely by showing that the conduct was deliberate or knowing" and the "motive underlying the lawyer's conduct'is not determinative; instead the issue is whether he or she purposefully acted." 439 In Feinberg, the court concluded that the prosecutor violated FRPC 4-4.1 and 4-8.4(c) and (d) by deliberately making untruthful statements to a defense attorney, despite evidence that the prosecutor ,intended to help the defendant by making the statements. 440 In this case, Villafana was fully aware of the signed NPA when she interviewed the victims on January 31 and February 1, 2008, arid when she spoke to Edwards on the telephone, but she did not inform them specifically of the signed NPA. The question is whether this omission amounted to a knowing false statement or' misrepresentation. ' One difficulty is determining what Villafana actually said duririg conversations that participants were asked to recall many years later. With respect to three of the victims whom she interviewed in January and February 2008, Villafana contended that she di~cussed the agreement with them, even if she did not specifically refer to it as the NP A or discuss all of its terms, and as 437 Wild, 955 F.3d at 1199-1200. 438 See R. Regulating Fla. Bar 4-Preamble: A Lawyer's Responsibilities, "Tenninology." 439 Florida Bar v. Schwartz, 284 So. 3d 393, 396 (Fla.2019) (citing Florida Bar v. IJerthiaume, 78 So. 3d 503, 510 n.2 (Fla. 2011); Florida Bar v. Riggs, 944 So. 2d 167, 171 (Fla. 2006); Florida Bar v; Smith, 866 So. 2d 41, 46 (Fla. 2004)). ! 440 Florida Bar v. Feinberg, 760 So. 2d 933, 937-38 (Fla. 2000). 277 CA/Aronberg-0007 45 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM • • previously noted, there is some contemporaneous evidence supporting her assertion. Villafana’s mention of the agreement, even if not described in specific terms, would have been sufficient to apprise those victims of the status of the federal investigation. Nevertheless, Villafana did not recall discussing the NPA specifically or in general terms with other victims interviewed at that time, nor did she do so with Edwards or any other victim’s attorney. OPR therefore considered whether the omission of information about the existence of the NPA during these interactions rose to the level of professional misconduct in violation ofFRPC 4-4.1 or 4-8.4.441 OPR evaluated Villafana’s conduct in light of the comment to FRPC 4-4.1: A lawyer is required to be truthful when dealing with others on a client’s behalf, but generally has no affirmative duty to inform an opposing party of relevant facts. A misrepresentation can occur if the lawyer incorporates or affirms a statement of another person that the lawyer knows is false. Misrepresentations can also occur by partially true but misleading statements or omissions that are the equivalent of affirmative false statements. The victims and their attorneys were certainly not “opposing parties]” to the USAO, but the comment indicates that the rule recognizes that omissions made during discussions with third parties, even of relevant facts, are not always treated as false statements. Here, the evidence does not show that Villafana knowingly made an affirmative false statement to the victims or Edwards or that her omissions were “the equivalent of affirmative false statements” about material facts. First, Villafana told OPR that she believed the investigation was ongoing and her statement to that effect truthful, and as discussed earlier in this Chapter, the evidence shows that Villafana and the agents did continue to investigate the case until Epstein entered his guilty plea in state court in June 2008. Villafana’s email correspondence with her supervisors reflects her strong advocacy during that timeframe to declare Epstein in breach and to charge him. The evidence similarly does not show that Villafana knowingly made any affirmative false statement to Edwards when she informed him of the state court plea, although she declined to provide additional information in response to his questions.442 Second, in reaching its conclusion, OPR considered the full context in which Villafana interacted with the victims and Edwards. Prosecutors routinely make decisions about what information will be disclosed to witnesses, including victims, for a variety of strategic reasons. In many cases, prosecutors must make difficult decisions about providing information to witnesses, In Florida Bar v. Joy, the court affirmed a referee’s conclusion that Joy violated FRPCs 4-4.1(a) and 4-8.4(c) “for making false statements by omission of material facts in his representations [to counsel].” Florida Bar v. Joy, 679 So. 2d 1165, 1166-68 (Fla. 1996). See also Florida Bar re Webster, 647 So. 2d 816 (Fla. 1994) (petition for reinstatement denied due to “misrepresentation by omission”). | 442 In Feinberg, 760 So. 2d at 938, the court found that an Assistant State Attorney lacked candor and violated ethics rules when, after meeting with a defendant outside liis attorney’s presence, the prosecutor falsely slated to the defense attorney that he (the prosecutor) had not met with the defendant. I i 278 CA/Aronberg-000746 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM 7 7 7 NOT A CERTIFIED COPY • • previously noted, there is some contemporaneous evidence supporting her Lsertion. Villafana's mention of the agreement, even if not described in specific terms, would hhve been sufficient to apprise those victims of the status of the federal investigation. ! Nevertheless, Villafana did not recall discussing the NP A specifically or in general terms with other victims interviewed at that time, nor did she do so with Edwards or any other victim's attorney. OPR therefore considered whether the omission of information about the existence of the NP A during these interactions rose to the level of professional misconduct in violation ofFRPC 4-4.1 or4-8.4. 441 OPR evaluated Villafana's conduct in light of the comment to FRPC 4-4.1: A lawyer is required to be truthful when dealing with others on a client's behalf, but generally has no affirmative duty to inform an opposing party of relevant facts. A misrepresentation can occur if the lawyer incorporates or affirms a statement of another person that the lawyer knows is false. Misrepresentations can also occur by partially true but misleading statements or omissions that are the equivalent of affirmative false statements. The victims and their attorneys were certainly not "opposing part[ies]" to the USAO, but the comment indicates that the rule recognizes that omissions made during discussions with third parties, even of relevant facts, are not always treated as false statements. Here, the evidence does not show that Villafana knowingly made an affirmative false statement to the victims or Edwards or that her omissions were "the equivalent of affirmative false statements" about material facts. First, Villafana told OPR that she believed the investigation was ongoing and her statement to that effect truthful, and as discussed earlier in this Chapter, the evidence shows that Villafana and the agents did continue to investigate the case until Epstein entered his guilty plea in state court in June 2008. Villafana's email correspondence with her supervisors reflects her strong advocacy during that timeframe to declare Epstein in breach and to charge him. The evidence similarly does not show that Villafana knowingly made any affirmative false statement to Edwards when she informed him of the state court plea, although she declined to provide additional information in response to his questions. 442 Second, in reaching its conclusion, OPR considered the full context in which Villafana interacted with the victims and Edwards. Prosecutors routinely make decisions about what information will be disclosed to witnesses, including victims, for a variety of strategic reasons. In many cases, prosecutors must make difficult decisions about providing information to witnesses, 441 In Florida Bar v. Joy, lhe court affinned a referee's conclusion lhal Joy violated FRPCs 4-4. l(a) and 4-8.4(c) "for making false statemenls by omission of material facts in his representations [lo col1Il5el]." Florida Bar v. Joy, 679 So. 2d 1165, 1166-68 (Fla. 1996). See also Florida Bar re Webster, 647 So. 2d 816 (Fla. 1994) (petition for reinslatement denied due to "misrepresentation by omission"). I 442 In Feinberg, 760 So. 2d at 938, the court found that an Assistant State Attorney lacked candor and violated ethics rules when, afler meeting wiU1 a defendant outside his altorney's presence, U1e prosbculor falsely slated lo the defense attorney that he (the prosecutor) had not met with the defendant. I I 278 CA/Aronberg-0007 46 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. ~/28/2023 2:22:44 PM and they often cannot fully reveal either the facts or the status of an investigation, even with victims. The 2005 Guidelines advise that in consulting with a victim, prosecutors may be limited in their disclosures: “Because victims are not clients, may become adverse to the Government, and may disclose whatever they have learned from consulting with prosecutors, such consultations may be limited to gathering information from victims and conveying only nonsensitive data and public information.”443 Villafaha’s concern about generating potential impeachment evidence by informing victims of their potential to recover monetary damages from Epstein was not unreasonable. Indeed, the case agents initially raised the impeachment issue, and after considering the problem, Villafana agreed with the agents’ concerns. Villafana raised those concerns with the USAO’s Professional Responsibility Officer in October 2007 after the agents brought the issue to her attention, and she ultimately raised the issue with Sloman and Acosta as well, neither of whom advised her that those concerns were improper or unsound. OPR also considered that although Villafana had sought to notify the victims in writing of the NPA soon after it was signed, her supervisor, the U.S. Attorney, had decided otherwise. When authorized to inform Edwards of the scheduled change of plea hearing, she did so. Although she did not inform Edwards that the plea was part ofa global resolution that would end the federal investigation, the evidence does not show that Villafana acted for the purpose of deceiving Edwards or preventing him from attending the hearing. Had she sought to exclude him from the state proceedings, she could have elected not to inform Edwards at all, or she could have discouraged him from attending the state proceedings. Rather, as Edwards confirmed, Villafana told him the hearing was “important.” Villafana sought to strike a difficult balance of securing Edwards’s (and his clients’) attendance at the state court plea, while obeying her management’s directive that informing victims of the resolution of the federal investigation should not be done until completion ofthe state plea. Therefore, after carefully considering all of the circumstances, OPR concludes that the evidence does not establish that Villafana violated her obligations under FRPC 4-4.1 or 4-8.4(c) or (d).444 Nonetheless, as discussed below, Villafaha’s interactions with victims and victims’ attorneys without informing them of the NPA and the potential conclusion of the federal investigation contributed to the likelihood that the victims would feel that the government was ■M3 2005 Guidelines, Art. IV, B.2.c( I). As noted, some victims continued to express favorable views ofEpstein during interviews with the government and they, or their attorneys, could have provided information to Epstein about the government’s communications. For example, within a day of Villafana contacting a victim’s attorney about a potential victim notification letter, Starr complained to Acosta that the government had recently inappropriately provided “oral notification of tire victim notification letter” to one girl’s attorney, even though it was clear from the girl’s recorded FBI interview that she “did not in any manner view herself as a victim.” m4 The case most directly on point is Smith, 109 A.3d 1184, in which the Man kind Court of Appeals affirmed a violation of Maryland Rule of Professional Conduct 8.4(d) based on a prosecutor’s failure to notify the victim of the resolution of a sex abuse case. However, as noted previously, in Smith, the criminal defendant had been arrested and charged before entering a plea, and various specific statutes afforded victims the right to receive notices and an opportunity to be heard concerning “a case originating by indictment or information in a circuit court.” In tliis case, for (lie reasons previously discussed, Villafana did not have, a clear and unambiguous obligation to inform the victims or Edwards of the NPA. i 279 j CA/Aronberg-000747 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY • • and they often cannot fully reveal either the facts or the status of an investigation, even with victims. The 2005 Guidelines advise that in consulting with a victim, prosetutors may be limited in their disclosures: "Because victims are not clients, may become adversb to the Government, and may disclose whatever they have learned from consulting with prosecutdrs, such consultations may be limited to gathering information from victims and conveying only honsensitive data and public information. "443 Villafana's concern about generating potential impeachment evidence by informing victims of their potential to recover monetary damages from Epstein was not unreasonable. Indeed, the case agents initially raised the impeachment issue, and after considering the problem, Villafana agreed with the agents' concerns. Villafana raised those concerns with the USAO's Professional Responsibility Officer in Oct9ber 2007 after the agents brought the issue to her attention, and she ultimately raised the issue with Sloman and Acosta as well, neither of whom advised her that those concerns were improper or unsound. OPR also considered that although Villafana had sought to notify the victims in writing of the NPA soon after it was signed, her supervisor, the U.S. Attorney, had decided otherwise. When authorized to inform Edwards of the scheduled change of plea hearing, she did so. Although she did not inform Edwards that the plea was part of a global resolution that would end the federal investigation, the evidence does not show that Villafana acted for the purpose of deceiving Edwards or preventing him from attending the hearing. Had she sought to exclude him from the state proceedings, she could have elected not to inform Edwards at all, or she could have discouraged him from attending the state proceedings. Rather, as Edwards confirmed, Villafana told him the hearing was "important." Villafana sought to strike a difficult balance of securing Edwards's (and his clients') attendance at the state court plea, while obeying her management's directive that informing victims of the resolution of the federal investigation should not be done until completion of the state plea. Therefore, after carefully considering all of the circumstances, OPR concludes that the evidence does not establish that Villafana violated her obligations under FRPC 4-4.1 or 4-8.4(c) or (d). 444 Nonetheless, as discussed below, Villafana's interactions with victims and victims' attorneys without informing them of the NPA and the potential conclusion of the federal investigation contributed to the likelihood that the victims would feel that the government was 443 2005 Guidelines, Art. IV, ,i B.2.c(I ). As noted, some victims continued to express favorable views of Epstein during interviews with the government and they, or their attorneys, could have provided infonnation to Epstein about the govenunent's conununications. For example, within a day of Villafafia contacting a \,ictim's attorney about a potential victim notification letter, Starr complained to Acosta that the govenunent had recently inappropriately provided "orn.l notification of tl1e victim notification letter" to one girl's attorney, even though it was clear from the girl's recorded FBI interview that she "did not in any manner view herself as a victim." 444 The case most directly on point is Smilh, 109 A.3d 1184, in which the Maryland Court of Appeals aflinncd a violation of Maryland Rule of Professional Conduct 8.4(d) based on a prosecutor's failure to notify the victim of the resolution of a sex abuse case. However, as noted previously, in Smilh, the criminal defen4ant had been arrested and charged before entering a plea, and various specific statutes afforded victims tl1e right lo receive notices and an opportunity lo be heard concerning "a case originating by indictment or infonnalion in a circuit court." In tlris case, for tl1e reasons previously discussed, Villafafia did not have. a clear and unambiguous oblig~ tion to infonn the victi1ns or Edwards of the NP A. 279 CNAronberg-0007 47 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM intentionally concealing information from them and was part of a series of interactions with victims that led to condemnation of the government’s treatment of victims.445 VI. THE GOVERNMENT FAILED TO TREAT VICTIMS FORTHRIGHTLY AND WITH SENSITIVITY WHEN IT FAILED TO TIMELY PROVIDE VICTIMS WITH IMPORTANT INFORMATION ABOUT THE RESOLUTION OF THE FEDERAL INVESTIGATION Although OPR does not conclude that any of the subjects committed professional misconduct, either by failing to consult with the victims before the NPA was signed or in interactions afterwards, OPR’s findings are not an endorsement of the government’s course of action. The government’s interactions with victims confused and frustrated many of the victims, particularly the two CVRA petitioners and the two victims who had unsuccessfully attempted to join in the CVRA litigation. As a result, the victims’ and the public’s perception of the matter is that the prosecutors worked with Epstein’s attorneys to disenfranchise and silence the victims. It is unfortunate, and appears fundamentally unfair to the victims, that Acosta and Sloman (after Menchel and Lourie departed) took the unusual step of deciding to vet the USAO victim notification letters with the defense after the NPA was signed, but failed to go beyond the requirements ofthe CVRA or the 2005 Guidelines to consult with the victims before the NPA was signed. This result is contrary to the Department’s intent, as set forth in the 2005 Guidelines, that Department employees work to “minimize the frustration and confusion that victims of crime endure in its wake.” When considering the entirety of the government’s interactions with victims, OPR concludes that victims were not treated with the forthrightness and sensitivity expected by the Department. 1 Wild’s criticisms of the government’s conduct were based on interactions that are similar to and generally representative of the government’s interactions with other Epstein victims and that demonstrate an overall lack of sensitivity to the victims by the government. Wild experienced a series of confusing and inconsistent communications in her interactions with Villafana and the case agents. Wild received Villafana’s letter in June 2007 stating inaccurately that she was a federal victim entitled to CVRA rights. She was interviewed by the FBI in August 2007 but was not told that a potential outcome was a state plea. Shortly after the September 24, 2007 signing of the NPA, the FBI contacted her to inform her of the resolution of the federal case. Nonetheless, on January 10, 2008, the FBI sent her a victims’ rights letter indicating that the case was under investigation and that some of her CVRA rights may not apply until after the defendant was charged. On January 31, 2008, Villafana re-interviewed Wild, along with a CEOS attorney and the FBI agents, and told Wild that the case was under investigation, but did not specifically mention the NPA, although she may have mentioned a possible resolution. In mid-June 2008, when Edwards contacted Villafana on Wild’s behalf, Villafana informed him that the case was under investigation but did not mention the NPA. Just before Epstein’s June 30, 2008 state court plea, 445 OPR notes tliat, similar to Villafana, Sloman interacted with a victim’s attorney during the time period between the signing of the NPA and Epstein’s state guilty plea. In January 2008, Sloman received a telephone call from liis former law partner, who represented one of the victims and who asked Sloman whether the federal government could bring cliarges against Epstein. Sloman, concerned about the potential for conflict of interest allegations due to his prior business relations with the attorney, refused to answer any questions regarding Epstein. Because Sloman refused to provide any information, OPR found no basis for finding that Sloman misled the attorney. 280 I CA/Aronberg-000748 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • intentionally concealing information from them and was part of a series of interactions with victims that led to condemnation of the government's treatment of victims. 4~5 I I I VI. THE GOVERNMENT FAILED TO TREAT VICTIMS FORTHRIGHTLY AND WITH SENSITIVITY WHEN IT FAILED TO TIMELY PROVJDE VICTIMS WITH IMPORTANT INFORMATION ABOUT THE RESOLUTION OF THE FEDERAL INVESTIGATION Although OPR does not conclude that any of the subjects committed professional misconduct, either by failing to consult with the victims before the NPA was signed or in interactions afterwards, OPR's findings are not an endorsement of the government's course of action. The government's interactions with victims confused and frustrated many of the victims, particularly the two CVRA petitioners and the two victims who had unsuccessfully attempted to join in the CVRA litigation. As a result, the victims' and the public's perception of the matter is that the prosecutors worked with Epstein's attorneys to disenfranchise and silence the victims. It is unfortunate, and appears fundamentally unfair to the victims, that Acosta and Sloman (after Menchel and Lourie departed) took the unusual step of deciding to vet the USAO victim notification letters with the defense after the NP A was signed, but failed to go beyond the requirements of the CYRA or the 2005 Guidelines to consult with the victims before the NPA was signed. This result is contrary to the Department's intent, as set forth in the 2005 Guidelines, that Department employees work to "minimize the frustration and confusion that victims of crime endure in its wake." When considering the entirety of the government's interactions with victims, OPR concludes that victims were not treated with the forthrightness and sensitivity expected by the Department. Wild's criticisms of the government's conduct were based on interactions that are similar to and generally representative of the government's interactions with other Epstein victims and that demonstrate an overall lack of sensitivity to the victims by the governm~nt. Wild experienced a series of confusing and inconsistent communications in her interactions with Villafana and the case agents. Wild received Villafana's letter in June 2007 stating inaccurately that she was a federal victim entitled to CVRA rights. She was interviewed by the FBI in August 2007 but was not told that a potential outcome was a state plea. Shortly after the September 24, 2007 signing of the NPA, the FBI contacted her to inform her of the resolution of the feder.al case. Nonetheless, on January 10, 2008, the FBI sent her a victims' rights letter indicating th11t the case was under investigation and that some of her CVRA rights may not apply until after the defendant was charged. On January 31, 2008, Villafana re-interviewed Wild, along with a CEOS attorney and the FBI agents, and told Wild that the case was under investigation, but did n6t specifically mention the NP A, although she may have mentioned a possible resolution. In mid-June 2008, when Edwards contacted Villafana on Wild's behalf, Villafana informed him that the case was under investi~ation but did not mention the NPA. Just before Epstein's June 30, 2008 state court plea, 445 OPR notes that, similar to Villafafia, Sloman interacted wit11 a victim's attorney during the time period between the signing of the NPA and Epstein's state guilty plea. In January 2008, Sloma11 received a telephone call from his former law partner, who represented one of t11e victims and who asked SlomaI1 whether the federal govenunent could bring charges against Epstein. SlomaI1, concerned about the potential for conflict of interest allegations due to his prior business relations with t11e attorney, refused to a11Swer 311)' qu~stions regarding Epstein. Because Sloman refused to provide any infonnation, OPR found no basis for finding that S!oman misled the attorney. 280 CNAronberg-0007 48 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM • • Villafana informed Edwards about the state plea, but did not mention the NPA or the fact that the state pleas would resolve the federal investigation. Edwards then filed the CVRA petition and learned about the NPA signed months earlier and that the federal investigation of Epstein had concluded with Epstein’s state guilty pleas. Wild only received access to the NPA when a judge permitted it in August 2008 pursuant to a protective order. After considering this series of interactions, it is not surprising that Wild came away from the experience.feeling confused and believing she had been misled. OPR did not find evidence supporting a conclusion that Villafana, Acosta, Sloman, Menchel, or Lourie opted not to consult with the victims in order to protect Epstein or shield the NPA from public scrutiny. Although neither Sloman nor Acosta could recall a specific discussion of CVRA obligations before the NPA was signed, both recalled knowing that victim consultation was not required, and Menchel also told OPR that consultation was not required, at least not up to the point when he left the USAO. The evidence is clear that Villafana sought at various points to consult with and to notify victims about the details of the NPA but was constrained before the NPA was signed by managers who either made a decision to not consult victims or did not address the issue after it was raised, and after the signing by her own concern about creating possible impeachment evidence that would damage the victims’ credibility at a possible trial. Nonetheless, a more open and straightforward approach with the victims, both before and after the signing of the NPA, would have been the better practice. Before the NPA was signed, victims could have been asked for their views about the general terms the USAO was contemplating offering, including that a plea to state charges was one of the options being considered; asked for their views in general about a guilty plea; or, at a minimum, asked to share their views of how the case should be resolved. Even if the USAO ultimately determined to proceed with the NPA, the government would have had the benefit of the victims’ thoughts and concerns, particularly on the issue of punishment, and victims would have felt included in the process. OPR found no evidence that the benefits of victim consultation were discussed or considered before the NPA was signed. After the NPA was signed, no one from the government explained the agreement to the majority of the victims until months later and only after the entry of Epstein’s guilty plea. Although the evidence supports Villafafia’s assertion that she acted from a good faith belief that Epstein might breach the NPA and a potential trial would be harmed if information about the NPA was divulged to the victims and their counsel, she, Sloman, and Acosta failed to consider how the desire to shield the victims from that potential impeachment might impact the victims’ sense of the openness and fairness of the process. As Wild stated during the CVRA litigation, she believed she had been “mistreated in the process.” When deciding not to inform the victims of the NPA to avoid creating impeachment evidence, Villafana, Sloman, and Acosta do not appear to have carefully considered possible alternatives to, or all of the ramifications of, that decision, nor did they revisit the decision before Villafana met the victims in person to discuss a potential trial or spoke to Edwards or other attorneys representing victims.446 Furthermore, more attention needed 446 It is not at all clear whether a court would have permitted impeachment of tlie victims concerning one provision in a plea agreement that otherwise could not be used as evidence. See Fed! R. Crim. P. 11(f) (“The admissibility or inadmissibility of a plea, a plea discussion, and any related statement is governed by Federal Rule of Evidence 410.”). In any case, the victims could have been impeached regarding the possibility' of their obtaining monetary damages through either a civil suit or through 18 U.S.C. § 2255 (if Epstein we:re convicted after a trial), 281 CA/Aronberg-000749 i FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY • • Villafana informed Edwards about the state plea, but did not mention the NPA or the fact that the state pleas would resolve the federal investigation. Edwards then filed th~ CVRA petition and learned about the NP A signed months earlier and that the federal investigation of Epstein had concluded with Epstein's state guilty pleas. Wild only received access to the NPA when a judge permitted it in August 2008 pursuant to a protective order. After considering this series of interactions, it is not surprising that Wild came away from the experience feeling confused and believing she had been misled. OPR did not find evidence supporting a conclusion that Villafana, Acosta, Sloman, Menchel, or Lourie opted not to consult with the victims in order to protect Epstein or shield the NPA from public scrutiny. Although neither Sloman nor Acosta could recall a specific discussion of CVRA obligations before the NP A was signed, both recalled knowing that victim consultation was not required, and Menchel also told OPR that consultation was not required, at least not up to the point when he left the USAO. The evidence is clear that Villafana sought at various points to consult with and to notify victims about the details of the NPA but was constrained before the NP A was signed by managers who either made a decision to not consult victims or did not address the issue after it was raised, and after the signing by her own concern about creating possible impeachment evidence that would damage the victims' credibility at a possible trial. Nonetheless, a more open and straightforward approach with the victims, both before and after the signing of the NP A, would have been the better practice. Before the NP A was signed, victims could have been asked for their views about the general terms the USAO was contemplating offering, including that a plea to state charges was one of the options being considered; asked for their views in general about a guilty plea; or, at a mif\imum, asked to share their views of how the case should be resolved. Even if the USAO ultimately determined to proceed with the NP A, the government would have had the benefit of the victims' thoughts and concerns, particularly on the issue of punishment, and victims would have felt included in the process. OPR found no evidence that the benefits of victim consultation were discussed or considered before the NP A was signed. After the NP A was signed, no one from the government explained the agreement to the majority of the victims until months later and only after the entry of Epstein's guilty plea. Although the evidence supports Villafana's assertion that she acted from a·good faith belief that Epstein might breach the NPA and a potential trial would be harmed if information about the NPA was divulged to the victims and their counsel, she, Sloman, and Acosta failed to consider how the desire to shield the victims from that potential impeachment might impact: the victims' sense of the openness and fairness of the process. As Wild stated during the CVRA litigation, she believed she had been "mistreated in the process." When deciding not to inform the victims of the NPA to avoid creating impeachment evidence, Villafana, Sloman, and Acosta do not appear to have carefully considered possible alternatives to, or all of the ramifications of, ,that decision, nor did they revisit the decision before Villafana met the victims in person to discuss a potential trial or spoke to Edwards or other attorneys representing victims. 446 Furthermore, more attention needed ' 446 It is not at all clear whether a court would have permitted impeaclunent of the victims concerning one provision in a pica agreement Uiat otherwise could not be used as evidence. See Fed! R. Crim. P. 11(1) ("The admissibility or inadmissibility of a plea, a plea discussion, and any related statement is go'vemed by Federal Rule of Evidence 410."). In any case, U1e victims could have been impeached regarding the po~sibility of their obtaining monetary damages through either a civil suit or through 18 U.S.C. § 2255 (if Epstein w~re convicted after a trial), 281 CN Aronberg-0007 49 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM • • to be paid to the FBI’s communications to ensure that the victims were receiving accurate and timely information that was consistent with the status of the case and with the USAO’s communications with victims.447 | The decision not to inform victims and their attorneys about the existence of the NPA gave victims and the public the misimpression that the government had colluded with Epstein’s counsel to keep the agreement secret from the victims. Moreover, the lack of openness about the NPA gave the impression that the USAO lacked sensitivity for the victims in resolving the matter and undercut public confidence in the legitimacy ofthe resulting plea agreement. The overall result of the subjects’ anomalous handling of this case left at least some of the victims feeling ignored and frustrated, failed to promote their healing process, and resulted in extensive public criticism. Although OPR credits Villafana’s statements that she wanted to go beyond her obligations in dealing with victims, the end result nonetheless was that communications with victims were not prioritized by the USAO. In part this was due to the fact that interactions with victims are generally handled by staff in the USAO and the FBI who are trained and have expertise in dealing with victims and other witnesses. However, decisions made by Acosta, Sloman, and Villafana also contributed to the problems. The government, as it ultimately acknowledged in the CVRA litigation, could have, and should have, engaged with the victims in a more transparent and unified fashion. OPR recognizes that the Epstein investigation occurred soon after the passage of the CVRA. In the years since, the Department’s prosecutors and personnel have become more familiar with its'provisions. OPR encourages the Department as a whole to take the issues discussed above into account when providing training and direction to its employees regarding victims’ rights to ensure that in the future, Department attorneys’ actions promote victim inclusion whenever possible.448 For example, although the division of responsibility between the FBI and the USAO for communicating with victims works efficiently and appropriately in the average case, the USAO failed to consider that in a case involving a pre-charge disposition, the victims were receiving inconsistent and confusing communications from the separate entities. In certain cases, such as the Epstein case, prosecutors may need to provide more oversight when imultiple Department components are communicating with victims to avoid providing confusing and contradictory messages. independent of the NPA provision OPR also notes that impeachment regarding the NPA provision may have permitted the government to rehabilitate the victims through their prior statements to law enforcement. In other words, while the USAO’s view concerning potential impeachment was not unreasonable, more extensive consideration of the case agent’s concerns might have led the prosecutors to conclude that the risk of tire information being used to significantly damage the credibility of the victims was low. 447 In addition to the FBI letters previously discussed, another example of the inconsistent conununication can be seen in letters tliat were to be sent after Epstein entered Iris guilty plea to two victims residing in foreign countries. Although OPR was unable to confirm that the two victims actually received the letters, it appears from the records OPR reviewed that the government intended to provide them with a standard FBI letter stating that the case was under investigation while also providing them with a USAO letter stating tliat the case had been resolved through Epstein’s state guilty plea. OPR understands tliat the Department is in the process of revising the 2011 Guidelines. 282 CA/Aronberg-000750 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • to be paid to the FBI's communications to ensure that the victims were receiving accurate and timely information that was consistent with the status of the case add with the USAO' s communications with victims. 447 I ! The decision not to inform victims and their attorneys about the existence of the NP A gave victims and the public the misimpression that the government had colluded with Epstein's counsel to keep the agreement secret from the victims. Moreover, the lack of openness about the NP A gave the impression that the USAO lacked sensitivity for the victims in res'olving the matter and undercut public confidence in the legitimacy of the resulting plea agreement. The overall result of the subjects' anomalous handling of this case left at least some of the victims feeling ignored and frustrated, failed to promote their healing process, and resulted in extensive public criticism. Although OPR credits Villafafia's statements that she wanted to go beyo'nd her obligations in dealing with victims, the end result nonetheless was that communications with victims were not prioritized by the USAO. In part this was due to the fact that interactions with victims are generally handled by staff in the USAO and the FBI who are trained and have expertise in dealing with victims and other witnesses. However, decisions made by Acosta, Sloman, and Villafana also contributed to the problems. The government, as it ultimately acknowledged in the CVRA litigation, could have, and should have, engaged with the victims in a more transparent and unified fashion. OPR recognizes that the Epstein investigation occurred soon after the passage of the CVRA. In the years since, the Department's prosecutors and personnel have become more familiar with its ·provisions. OPR encourages the Department as a whole to take the issues discussed above into account when providing training and direction to its employees regarding victims' rights to ensure that in the future, Department attorneys' actions promote victim inclusion whenever possible. 448 For example, although the division of responsibility between the FBI and the USAO for communicating with victims works efficiently and appropriately in the average case, the USAO failed to consider that in a case involving a pre-charge disposition, the victims were receiving inconsistent and confusing communications from the separate entities. In certain cases, such as the Epstein case, prosecutors may need to provide more oversight when imultiple Department components are communicating with victims to avoid providing confusing and contradictory messages. independent of the NPA provisio11 OPR also notes that impeaclunent regarding the 1'JPA provision may have pennitted the govenunent to rehabilitate the victims through their prior statements to law enforcement. In other words, while the USAO's view concerning potential impeachment was not unreasonable, more extensive consideration of the case agent's concerns might have led the prosecutors to conclude that the risk of the information being used to significantly damage the credibility of the victims was low. 447 In addition to tl1e FBI letters previously discussed, another example of the inconsistent conununication can be seen in letters that were to be sent after Epstein entered his guilty plea to two victims residing in foreign countries. Although OPR was unable to confinn that the two victims actually received the letters, it appears from the records OPR reviewed that t11e govenunent intended to provide them with a standard FBI letter stating that the case was under im,estigation while also providing them with a USAO letter stating that the case had been ksolved through Epstein's state guilty plea. I 4'18 OPR understands that the Department is in the process of revising the 2011 Guidelines. 282 CNAronberg-000750 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM CONCLUSION In November 2018, the Miami Herald published an extensive investigative report about state and federal criminal investigations initiated more than 12 years earlier into allegations that Jeffrey Epstein, a wealthy financier with residences in Florida, New York, and other United States and foreign locations, had coerced girls into engaging in sexual activity with him at his Palm Beach, Florida estate. The Miami Herald reported that in 2007, the U.S. Attorney for the Southern District of Florida, R. Alexander Acosta, entered into an “extraordinary” deal with Epstein that permitted Epstein to avoid federal prosecution and a potentially lengthy prison sentence by pleading guilty in state court to “two prostitution charges,” immunized from prosecution Epstein’s co-conspirators, and concealed from Epstein’s victims the terms of the NPA. Following the Miami Herald’s report, and after receiving a Congressional request to investigate, OPR. initiated an investigation into the allegations that prosecutors in the USAO improperly resolved the federal investigation into the criminal conduct of Jeffrey Epstein by negotiating and executing the NPA. OPR subsequently included in its investigation allegations stemming from judicial criticism of the government’s conduct relating to federal prosecutors’ and law enforcement agents’ interactions with Epstein’s victims. In July 2008, a victim, later joined by a second victim, filed in federal court in the Southern District of Florida an emergency petition for enforcement of her rights under the CVRA. In February 2019, the district court found that the government violated the CVRA by failing to advise victims about its intention to enter into the NPA. The court also found that letters the government sent to victims after the NPA was signed, describing the investigation as ongoing, were misleading. During the course of its investigation, OPR obtained and reviewed hundreds of thousands of records from the USAO, the FBI, and other Department of Justice components. The records included emails, letters, memoranda, and investigative materials. OPR also collected and reviewed materials relating to the state investigation and prosecution ofEpstein, including sealed pleadings, grand jury transcripts, and grand jury audio recordings; examined extensive publicly available information, including depositions, pleadings, orders, and other court records; and reviewed media reports and interviews, articles, podcasts, and books relating to the Epstein case. OPR conducted more than 60 interviews of witnesses, including the FBI case agents, their supervisors, and FBI administrative personnel; current and former USAO staff and attorneys; current and former Department attorneys and senior managers; and the former State Attorney and Assistant State Attorney in charge of the state investigation of Epstein. OPR also interviewed or received written information from several victims and attorneys representing victims concerning victim contacts with the USAO and federal law enforcement. OPR identified the following five former USAO attorneys as subjects of its investigation based on information indicating that each of them was involved in the decision to resolve the case through the NPA or in the negotiations leading to the agreement: former U.S. Attorney R. Alexander Acosta, and former AUSAs Jeffrey H. Sloman, Matthew I. Menchel, Andrew C. Lourie, and Ann Marie C. Villafana. Each subject submitted written responses detailing their involvement in the federal investigation of Epstein, the drafting and execution of the NPA, and decisions relating to victim notification and consultation. OPR conducted extensive interviews of all five subjects. The subjects also submitted comments on OPR’s draft report. 283 ; CA/Aronberg-000751 FILED; PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • CONCLUSION I In November 2018, the Miami Herald published an extensive invebtigative report about state and federal criminal investigations initiated more than 12 years earlier into allegations that Jeffrey Epstein, a wealthy financier with residences in Florida, New York, and other United States and foreign locations, had coerced girls into engaging in sexual activity ~ith him at his Palm Beach, Florida estate. The Miami Herald reported that in 2007, the U.S. Attorney for the Southern District of Florida, R. Alexander Acosta, entered into an "extraordinary" deal with Epstein that permitted Epstein to avoid federal prosecution and a potentially lengthy prison sentence by pleading guilty in state court to "two prostitution charges," immunized from prosecution Epstein's co-conspirators, and concealed from Epstein's victims the terms of the NPA. Following the Miami Herald's report, and after receiving a Congressional request to investigate, OPR initiated an investigation into the allegations that prosecutors in the USAO improperly resolved the federal investigation into the criminal conduct of Jeffrey Epstein by negotiating and executing the NP A. OPR subsequently included in its investigation allegations stemming from judicial criticism of the government's conduct relating to federal prosecutors' and law enforcement agents' interactions with Epstein's victims. In July 2008, a victim, later joined by a second victim, filed in federal court in the Southern District of Florida an emergency petition for enforcement of her rights under the CVRA. In February 2019, the district court found that the government violated the CYRA by failing to advise victims about its intention to enter into the NPA. The court also found that letters the government sent to victims after the NPA was signed, describing the investigation as ongoing, were misleading. During the course of its investigation, OPR obtained and reviewed hundreds of thousands of records from the USAO, the FBI, and other Department of Justice components. The records included emails, letters, memoranda, and investigative materials. OPR also collected and reviewed materials relating to the state investigation and prosecution of Epstein, including sealed pleadings, grand jury transcripts, and grand jury audio recordings; examined extensive publicly available information, including depositions, pleadings, orders, and other court records; and reviewed media reports and interviews, articles, podcasts, and books relating to the Epstein case. OPR conducted more than 60 interviews of witnesses, including the FBI case agents, their supervisors, and FBI administrative personnel; current and former USAO staff and attorneys; current and former Department attorneys and senior managers; and the former State Attorney and Assistant State Attorney in charge of the state investigation of Epstein. OPR also interviewed or received written information from several victims and attorneys representing victims concerning victim contacts with the USAO and federal law enforcement. OPR identified the following five former USAO attorneys as subjects of its investigation based on information indicating that each of them was involved in the decision to resolve the case through the NPA or in the negotiations leading to the agreement: former U.S. Attorney R. Alexander Acosta, and forn1er AUSAs Jeffrey H. Sloman, Matthew I. Menchel, Andrew C. Lourie, and Ann Marie C. Villafana. Each subject submitted written responses detailing their involvement in the federal investigation of Epstein, the drafting and execution of the NP A, and decisions relating to victim notification and consultation. OPR conducted extensive interviews of all five subjects. The subjects also submitted comments on OPR's draft reJort. i 283 CA/Aronberg-000751 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3./28/2023 2:22:44 PM OPR evaluated the conduct of each subject based on his or her individual role in various decisions and events and assessed that conduct pursuant to OPR’s analytical framework. OPR found that Acosta made the pivotal decision to resolve the federal investigationof Epstein through a state-based plea and either developed or approved the terms ofthe initial offer to the defense that set the beginning point for the subsequent negotiations that led to the NPA. Although Acosta did not sign the NPA, he participated in its drafting and approved it, with knowledge of its terms. Therefore, OPR considers Acosta to be responsible for the NPA and for the actions of the other subjects who implemented his decisions. Based on its extensive investigation, OPR concludes that the subjects did not commit professional misconduct with respect to the development, negotiation, and approval of the NPA. Under OPR’s framework, professional misconduct requires a finding that a subject attorney intentionally or recklessly violated a clear and unambiguous standard governing the conduct at issue. OPR found no clear and unambiguous standard that required Acosta to indict Epstein on federal charges or that prohibited his decision to defer prosecution to the state. Furthermore, none of the individual terms of the NPA violated Department or other applicable standards. As the U.S. Attorney, Acosta had the “plenary authority” under established federal law and Department policy to resolve the case as he deemed necessary and appropriate, as long as his decision was not motivated or influenced by improper factors. Acosta’s decision to decline to initiate a federal prosecution of Epstein was within the scope of his authority, and OPR did not find evidence that his decision was based on corruption or other impermissible considerations, such as Epstein’s wealth, status, or associations. Evidence shows that Acosta resisted defense efforts to have the matter returned to the state for whatever result state authorities deemed appropriate, and he refused to eliminate the incarceration and sexual offender registration requirements. OPR did not find evidence establishing that Acosta’s “breakfast meeting” with one ofEpstein’s defense counsel in October 2007 led to the NPA, which had been signed weeks earlier, or to any other significant decision that benefited Epstein. The contemporaneous records show that USAO managers’ concerns about legal issues, witness credibility, and the impact of a trial on the victims led them to prefer a pre-charge resolution and that Acosta’s concerns about the proper role of the federal government in prosecuting solicitation crimes resulted in his preference for a state-based resolution. Accordingly, OPR does not find that Acosta engaged in professional misconduct by resolving the federal investigation of Epstein in the way he did or that the other subjects committed professional misconduct through their implementation of Acosta’s decisions. Nevertheless, OPR concludes that Acosta’s decision to resolve the federal investigation through the NPA constitutes poor judgment. Although this decision was within the scope of Acosta’s broad discretion and OPR does not find that it resulted from improper factors, the NPA was a flawed mechanism for satisfying the federal interest that caused the government to open its investigation of Epstein. In Acosta’s view, the federal government’s role in prosecuting Epstein was limited by principles of federalism, under which the independent authority of the state should be recognized, and the federal responsibility in this situation was to serve as a “backstop” to state authorities by encouraging them to do more. However, Acosta failed to consider the difficulties inherent in a resolution that relied heavily on action by numerous state officials over whom he had no authority; he resolved the federal investigation before significant investigative steps were completed; and he agreed to several unusual and problematic terms in the NPA without the consideration required under the circumstances. In sum, Acosta’s application of federalism 284 CA/Aronberg-000752 ! FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY • • I I I OPR evaluated the conduct of each subject based on his or her indiridual role in various decisions and events and assessed that conduct pursuant to OPR's analytical framework. OPR found that Acosta made the pivotal decision to resolve the federal investigati;on of Epstein through a state-based plea and either developed or approved the terms of the initial offer to the defense that set the beginning point for the subsequent negotiations that led to the NP A. Although Acosta did not sign the NPA, he participated in its drafting and approved it, with knowledge of its terms. Therefore, OPR considers Acosta to be responsible for the NP A and for the actions of the other subjects who implemented his decisions. Based on its extensive investigation, OPR concludes that the subjects did not commit professional misconduct with respect to the development, negotiation, and approval of the NP A. Under OPR's framework, professional misconduct requires a finding that a subject attorney intentionally or recklessly violated a clear and unambiguous standard governing the conduct at issue. OPR found no clear and unambiguous standard that required Acosta to indict Epstein on federal charges or that prohibited his decision to defer prosecution to the state. Furthermore, none of the individual terms of the NPA violated Department or other applicable standards. As the U.S. Attorney, Acosta had the "plenary authority" under established federal law and Department policy to resolve the case as he deemed necessary and appropriate, as long as his decision was not motivated or influenced by improper factors. Acosta's decision to decline to initiate a federal prosecution of Epstein was within the scope of his authority, and OPR did not find evidence that his decision was based on corruption or other impermissible considerations, such as Epstein's wealth, status, or associations. Evidence shows that Acosta resisted defense efforts to have the matter returned to the state for whatever result state authorities deemed appropriate, and he refused to eliminate the incarceration and sexual offender registration requirements. OPR did not find evidence establishing that Acosta's "breakfast meeting" with one of Epstein's defense counsel in October 2007 led to the NPA, which had been signed weeks earlier, or to any other significant decision that benefited Epstein. The contemporaneous records show that USAO managers' concerns about legal issues, witness credibility, and the impact of a trial on the victims led them to prefer a pre-charge resolution and that Acosta's concerns about the proper role of the federal government in prosecuting solicitation crimes resulted in his preference for a state-based resolution. Accordingly, OPR does not find that Acosta engaged in professional misconduct by resolving the federal investigation of Epstein in the way he did or that the other subjects committed professional misconduct through their implementation of Acosta's decisions. Nevertheless, OPR concludes that Acosta's decision to resolve the federal investigation through the NPA constitutes poor judgment. Although this decision was within the scope of Acosta's broad discretion and OPR does not find that it resulted from improper factors, the NPA was a flawed mechanism for satisfying the federal interest that caused the government to open its investigation of Epstein. ln Acosta's view, the federal government's role in prosecuting Epstein was limited by principles offederalism, under which the independent authority of the state should be recognized, and the federal responsibility in this situation was to serve as a "backstop" to state authorities by encouraging them to do more. However, Acosta failed to consider the difficulties inherent in a resolution that relied heavily on action by numerous state officials over whom he had no authority; he resolved the federal investigation before significant investigative steps were completed; and he agreed to several unusual and problematic terms in the NPA without the consideration required under the circumstances. In sum, Acosta's appl'ication of federalism ' 284 CA/Aronberg-000752 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM principles was too expansive, his view of the federal interest in prosecuting Epstein was too narrow, and his understanding of the state system was too imperfect to justify the decision to use the NPA. Furthermore, because Acosta assumed a significant role in reviewing and drafting the NPA and the other three subjects who were supervisors left the USAO, were transitioning to other jobs, or were absent at critical junctures, Acosta should have ensured more effective coordination and communication during the negotiations and before approving the final NPA. The NPA was a unique resolution, and one that required greater oversight and supervision than Acosta provided. OPR further concludes that none of the subject attorneys committed professional misconduct with respect to the government’s interactions with victims. The subjects did not intentionally or recklessly violate a clear and unambiguous duty under the CVRA by entering into the NPA without consulting with victims, because the USAO resolved the Epstein investigation without a federal criminal charge. Significantly, at the time the NPA was signed, the Department did not interpret CVRA rights to attach unless and until federal charges had been filed, and the federal courts had not established a clear and unambiguous standard applying the CVRA before criminal charges were brought. In addition, OPR did not find evidence that the lack ofconsultation was for the purpose of silencing victims. Nonetheless, the lack of consultation was part of a series of government interactions with victims that ultimately led to public and court condemnation of the government’s treatment of the victims, reflected poorly on the Department as a whole, and is contradictory to the Department’s mission to minimize the frustration and confusion that victims of a crime endure. OPR determined that none of the subjects was responsible for communications sent to certain victims after the NPA was signed that described the case as “under investigation” and that failed to inform them of the NPA. The letters were sent by an FBI administrative employee who was not directly involved in the investigation, incorporated standard form language used by the FBI when communicating with victims, and were not drafted or reviewed by the subjects. Moreover, the statement that the matter was “under investigation” was not false because the government in fact continued to investigate the case in anticipation that Epstein would not fulfill the terms of the NPA. However, the letters risked misleading the victims and contributed to victim frustration and confusion by failing to provide important information about the status of the investigation. The letters also demonstrated a lack of coordination between the federal agencies responsible for communicating with Epstein’s victims and showed a lack of attention to and oversight regarding communication with victims. ’ After the NPA was signed, Acosta elected to defer to the State Attorney the decision whether to notify victims about the state’s plea hearing pursuant to the state,’s own victim’s rights requirements. Although Acosta’s decision was within his authority and did not constitute professional misconduct, OPR concludes that Acosta exercised poor judgment when he failed to make certain that the state intended to and would notify victims identified through the federal investigation about the state plea hearing. His decision left victims uninformed about an important proceeding that resolved the federal investigation, an investigation about which the USAO had communicated with victims for months. It also ultimately created the misimpression that the Department intentionally sought to silence the victims. Acosta failed to ensure that victims were made aware of a court proceeding that was related to their own cases, and thus he failed to ensure that victims were treated with forthrightness and dignity. ! I i 285 ! i i CA/Aronberg-000753 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • principles was too expansive, his view of the federal interest in prosecuting Epstein was too I narrow, and his understanding of the state system was too imperfect to justify the decision to use the NP A. Furthermore, because Acosta assumed a significant role in revie~ing and drafting the NPA and the other three subjects who were supervisors left the USAO, were 1transitioning to other jobs, or were absent at critical junctures, Acosta should have ensured more effective coordination and communication during the negotiations and before approving the final NP A. The NP A was a unique resolution, and one that required greater oversight and supervision than Acosta provided. OPR further concludes that none of the subject attorneys committed professional misconduct with respect to the government's interactions with victims. The subjects did not intentionally or recklessly violate a clear and unambiguous duty under the CVRA by entering into the NP A without consulting with victims, because the USAO resolved the Epstein investigation without a federal criminal charge. Significantly, at the time the NPA was signed, the Department did not interpret CVRA rights to attach unless and until federal charges had been filed, and the federal courts had not established a clear and unambiguous standard applying the CVRA before criminal charges were brought. In addition, OPR did not find evidence that the lack of consultation was for the purpose of silencing victims. Nonetheless, the lack of consultation was part of a series of government interactions with victims that ultimately led to public and court condemnation of the government's treatment of the victims, reflected poorly on the Department as a whole, and is contradictory to the Department's mission to minimize the frustration and confusion that victims of a crime endure. OPR determined that none of the subjects was responsible for communications sent to certain victims after the NP A was signed that described the case as "under iµvestigation" and that failed to inform them of the NPA. The letters were sent by an FBI administrative employee who was not directly involved in the investigation, incorporated standard form language used by the FBI when communicating with victims, and were not drafted or reviewed by the subjects. Moreover, the statement that the matter was "under investigation" was not false because the government in fact continued to investigate the case in anticipation that Epstein would not fulfill the terms of the NP A. However, the letters risked misleading the victims and contributed to victim frustration and confusion by failing to provide important information about the status of the investigation. The letters also demonstrated a lack of coordination between the federal agencies responsible for communicating with Epstein's victims and showed a lack of attention to and oversight regarding communication with victims. After the NP A was signed, Acosta elected to defer to the State Attorney the decision whether to notify victims about the state's plea hearing pursuant to the state.'s own victim's rights requirements. Although Acosta's decision was within his authority and did not constitute professional misconduct, OPR concludes that Acosta exercised poor judgment when he failed to make certain that the state intended to and would notify victims identified through the federal investigation about the state plea hearing. His decision left victims uninformed about an important proceeding that resolved the federal investigation, an investigation about which the USAO had communicated with victims for months. It also ultimately created the rriisimpression that the I Department intentionally sought to silence the victims. Acosta failed to ensure that victims were made aware of a court proceeding that was related to their own cases, and thus he failed to ensure I that victims were treated with forthrightness and dignity. I I i 285 i CA/Aronberg-000753 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM OPR concludes that the decision to postpone notifying victims about the terms of the NPA after it was signed and the omission of information about the NPA during victim interviews and conversations with victims’ attorneys in 2008 do not constitute professional misconduct. Contemporaneous records show that these actions were based on strategic concerns about creating impeachment evidence that Epstein’s victims had financial motives to make claims against him, evidence that could be used against victims at a trial, and were not for the purpose of silencing victims. Nonetheless, the failure to reevaluate the strategy prior to interviews of victims and discussions with victims’ attorneys occurring in 2008 led to interactions that contributed to victims’ feelings that the government was intentionally concealing information from them. After examining the full scope and context of the government’s interactions with victims, OPR concludes that the government’s lack of transparency and its inconsistent messages led to victims feeling confused and ill-treated by the government; gave victims and the public the misimpression that the government had colluded with Epstein’s counsel to; keep the NPA secret from the victims; and undercut public confidence in the legitimacy ofthe resulting agreement. The overall result of the subjects’ anomalous handling of this case understandably left many victims feeling ignored and frustrated and resulted in extensive public criticism. In sum, OPR concludes that the victims were not treated with the forthrightness and sensitiyity expected by the Department. 286 CA/Aronberg-000754 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY • • OPR concludes that the decision to postpone notifying victims about the terms of the NP A after it was signed and the omission of information about the NP A during yictim interviews and conversations with victims' attorneys in 2008 do not constitute professional misconduct. Contemporaneous records show that these actions were based on strategic ccincerns about creating impeachment evidence that Epstein's victims had financial motives to ma~e claims against him, evidence that could be used against victims at a trial, and were not for th~ purpose of silencing victims. Nonetheless, the failure to reevaluate the strategy prior to inter\liews of victims and discussions with victims' attorneys occurring in 2008 led to interactions that contributed to victims' feelings that the government was intentionally concealing information from them. After examining the full scope and context of the government's interactions with victims, OPR concludes that the government's lack of transparency and its inconsistent messages led to victims feeling confused and ill-treated by the government; gave victims and the public the misimpression that the government had colluded with Epstein's counsel to: keep the NPA secret from the victims; and undercut public confidence in the legitimacy of the res9lting agreement. The overall result of the subjects' anomalous handling of this case understandably left many victims feeling ignored and frustrated and resulted in extensive public criticism. In sum, OPR concludes that the victims were not treated with the forthrightness and sensiti~ity expected by the Department. 286 CA/Aronberg-000754 i FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM METHODOLOGY A. Document Review As referenced in the Executive Summary, OPR obtained and reviewed hundreds of thousands of pages of documents from the U.S. Attorney’s Office for the Southern District of Florida (USAO), other U.S. Attorney’s offices, the FBI, and other Department components, including the Office of the Deputy Attorney General, the Criminal Division, and the Executive Office for U.S. Attorneys (EOUSA). The categories of documents reviewed by OPR, and their sources, are set forth below. 1. USAO Records The USAO provided OPR with access to all of its records from its handling of the Epstein investigation and the CVRA litigation. The records included, but were not limited to, boxes of material that Villafana updated and maintained through the course ofboth actions, which contained pleadings from the Epstein investigation, the CVRA litigation, and other related cases; extensive compilations of internal and external correspondence, including letters and emails; evidence such as telephone records, FBI reports, material received from the state investigation, and other confidential investigative records; court transcripts; investigative transcripts; prosecution team handwritten notes; research material; and draft and final case documents such as the NPA, prosecution memoranda, and federal indictments. The USAO also provided OPR with access to filings, productions, and privileged material in the CVRA litigation; Outlook data collected to respond to production requests in that case; a set ofEpstein case documents maintained by Acosta and Sloman; computer files regarding the Epstein case collected by Sloman; Villafafia’s Outlook data; Acosta’s hard drive; and the permanently retained official U.S. Attorney records of Acosta held by the Federal Records Center. 2. EOUSA Records EOUSA provided OPR with Outlook data from all five subjects and six additional witnesses. This information, dating back to 2005, included all inbox, outbox, sent, deleted, and saved emails, and calendar entries that it maintained. EOUSA provided OPR with over 850,000 Outlook records in total (not including email attachments or excluding duplicate records). OPR identified key time periods and fully reviewed those records. OPR applied search terms to the remainder of the records and reviewed any responsive documents. After reviewing the emails, OPR identified a data gap in Acosta’s email records: his inbox contained no emails from May 26, 2007, through November 2, 2008. This gap, however, was not present with respect to Acosta’s sent email. OPR requested that EOUSA investigate. During its investigation, EOUSA discovered a data association error that incorrectly associated Acosta’s data with an unrelated employee who had a similar name. Once the data was properly associated, EOUSA found and produced 11,248 Acosta emails from April 3, 2008, through the end of his tenure at the USAO. However, with respect to the remaining emails, EOUSA concluded that the emails were not transferred from the USAO when, in 2008 and 2009, Outlook data for all U.S. 287 I ' I CA/Aronberg-000755 1 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • METHODOLOGY A. Document Review As referenced in the Executive Summary, OPR obtained and reviewed hundreds of thousands of pages of documents from the U.S. Attorney's Office for the Southern District of Florida (USAO), other U.S. Attorney's offices, the FBI, and other Department components, including the Office of the Deputy Attorney General, the Criminal Division, and the Executive Office for U.S. Attorneys (EOUSA). The categories of documents reviewed by OPR, and their sources, are set forth below. 1. USAO Records The USAO provided OPR with access to all of its records from its handling of the Epstein investigation and the CVRA litigation. The records included, but were not limited to, boxes of material that Villafana updated and maintained through the course of both actions, which contained pleadings from the Epstein investigation, the CVRA litigation, and other related cases; extensive compilations of internal and external correspondence, including letters and emails; evidence such as telephone records, FBI reports, material received from the state investigation, and other confidential investigative records; court transcripts; investigative transcripts; prosecution team handwritten notes; research material; and draft and final case documents such as the NP A, prosecution memoranda, and federal indictments. The USAO also provided OPR with access to filings, productions, and privileged material in the CVRA litigation; Outlook data collected to respond to production requests in that case; a set of Epstein case documents maintained by Acosta and Sloman; computer files regarding the Epstein case collected by Sloman; Villafafia's Outlook data; Acosta's hard drive; and the permanently retained official U.S. Attorney records of Acosta held by the Federal Records Center. 2. EOUSA Records EOUSA provided OPR with Outlook data from all five subjects and six additional witnesses. This information, dating back to 2005, included all inbox, out~ox, sent, deleted, and saved emails, and calendar entries that it maintained. EOUSA provided OPR with over 850,000 Outlook records in total (not including email attachments or excluding duplicate records). OPR identified key time periods and fully reviewed those records. OPR applied search terms to the remainder of the records and reviewed any responsive documents. After reviewing the emails, OPR identified a data gap in Acosta's erriail records: his inbox contained no emails from May 26, 2007, through November 2, 2008. This gap, however, was not present with respect to Acosta's sent email. OPR requested that EOUSA investigate. During its investigation, EOUSA discovered a data association error that incorrectly associated Acosta's data with an unrelated employee who had a similar name. Once the data wa~ properly associated, EOUSA found and produced 11,248 Acosta emails from April 3, 2008, through the end of his . I tenure at the USAO. However, with respect to the remaining emails, EOUSA concluded that the emails were not transferred from the USAO when, in 2008 and 2009, Outlook data for all U.S. I I 287 I CA/Aronberg-000755 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM • • Attorney’s Offices was migrated to EOUSA’s centralized system to be maintained. The USAO’s data was migrated between March and June 2008. | EOUSA and OPR separately confirmed with the USAO that it was unable to locate any additional emails. OPR questioned Acosta, as well as numerous administrative staff, about the email gap. Acosta and the witnesses denied having any knowledge of the problem, or that they or, to their knowledge, anyone else made any efforts to intentionally delete the emails. In addition, at OPR’s request, EOUSA conducted an analysis of records migrated from four other U.S. Attorney’s Offices and found that each office provided data that also contained significant gaps in their U.S. Attorney email records, although the time periods varied for each office. OPR found no evidence indicating that the gap in Acosta’s emails was caused by any intentional act or for the purpose of concealing evidence relating to the Epstein investigation and concludes that it was most likely the result of a technological error. Although a gap in Acosta’s email inbox from May 26, 2007, through April 2, 2008, remained, OPR was nonetheless able to examine a significant number of Acosta’s emails from this time due to the extensive case files kept by the USAO; the availability of Acosta’s sent email, which did not contain a similar gap; and the availability of emails of other USAO subjects and witnesses who were included on emails with Acosta. 3. Federal Bureau of Investigation Records OPR worked with the FBI’s Palm Beach Office, including with two case agents and the Victim Witness Specialist who worked on the Epstein matter, to obtain relevant FBI documents. In addition, the FBI searched its Automated Case Support system and also provided documentation concerning its victim notification system. 4. Criminal Division Records The Office of the Assistant Attorney General for the Criminal Division provided OPR with Outlook data for the four individuals from that Office who examined issues connected to the USAO’s Epstein investigation. The data included the individuals’ inbox, outbox, sent, deleted, and saved emails, and calendar entries. CEOS also provided OPR with Outlook data for the four individuals from that office who worked on, or examined issues connected to, the USAO’s Epstein investigation. The data included the individuals’ inbox, outbox, sent, deleted, and saved emails. CEOS also conducted a check of its shared hard drive and provided documents that were potentially relevant to OPR’s investigation. 5. Office of the Deputy Attorney General Records OPR obtained Outlook data for the three individuals from the Office of the Deputy Attorney who examined issues connected to the USAO’s Epstein investigation, including the former Deputy Attorney General. The data included the individuals’ inbox,!outbox, sent, deleted, and saved emails, and calendar entries. 288 CA/Aronberg-000756 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Attorney's Offices was migrated to EOUSA's centralized system to be maintained. The USAO's • I data was migrated between March and June 2008. I ' EOUSA and OPR separately confirmed with the USAO that it was unable to locate any additional emails. OPR questioned Acosta, as well as numerous administrative staff, about the email gap. Acosta and the witnesses denied having any knowledge of the problem, or that they or, to their knowledge, anyone else made any efforts to intentionally delete the emails. In addition, at OPR' s request, EOUSA conducted an analysis of records migrated from four other U.S. Attorney's Offices and found that each office provided data that also contained significant gaps in their U.S. Attorney email records, although the time periods varied for each office. OPR found no evidence indicating that the gap in Acosta's emails was caused by any intentional act or for the purpose of concealing evidence relating to the Epstein investigation and concludes that it was most likely the result of a technological error. Although a gap in Acosta's email inbox from May 26, 2007, through April 2, 2008, remained, OPR was nonetheless able to examine a significant number of Acosta's emails from this time due to the extensive case files kept by the USAO; the availability of Acosta's sent email, which did not contain a similar gap; and the availability of emails of other USAO subjects and witnesses who were included on emails with Acosta. 3. Federal Bureau of Investigation Records OPR worked with the FBI's Palm Beach Office, including with two case agents and the Victim Witness Specialist who worked on the Epstein matter, to obtain relevant FBI documents. In addition, the FBI searched its Automated Case Support system and also provided documentation concerning its victim notification system. 4. Criminal Division Records The Office of the Assistant Attorney General for the Criminal Division provided OPR with Outlook data for the four individuals from that Office who examined issues connected to the USAO's Epstein investigation. The data included the individuals' inbox, outbox, sent, deleted, and saved emails, and calendar entries. CEOS also provided OPR with Outlook data for the four individuals from that office who worked on, or examined issues connected to, the USA O's Epstein investigation. The data included the individuals' inbox, outbox, sent, deleted, and saved emails. CEOS also conducted a check of its shared hard drive and provided documents that were potentially relevant to OPR's investigation. 5. Office of the Deputy Attorney General Records OPR obtained Outlook data for the three individuals from the Office of the Deputy Attorney who examined issues connected to the USAO's Epstein investigation, including the former Deputy Attorney General. The data included the individuals' inbox,! outbox, sent, deleted, and saved emails, and calendar entries. ; i I I 288 CA/Aronberg-000756 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM 6. U.S. Attorney’s Office for the Middle District of F orida Records The U.S. Attorney’s Office for the Middle District of Florida provided OPR with records related to its review of evidence against Epstein, after he concluded his Florida state sentence, when the Department recused the USAO in August 2011 from “all matters, to include the investigation and potential prosecution, relating to Jeffrey Epstein’s alleged sexual activities with minor females,” and assigned the matter to the Middle District of Florida U.S. Attorney’s Office for further consideration. The records included a declination of the matter due to the NPA. 7. U.S. Attorney’s Office for the Northern District of Georgia Records The U.S. Attorney’s Office for the Northern District ofGeorgia provided OPR with records related to its work on the CVRA litigation after the recusal of the USAO. 8. Public Records OPR obtained and reviewed a variety of public records, including publicly released records of the Palm Beach Police Department, the State Attorney’s Office for the 15th Judicial Circuit, and the Palm Beach Sheriffs Office; documents pertaining to the CVRA litigation and other court proceedings involving Epstein and related individuals; and books and media reports. B. Information from Subjects, Witnesses, and Victims 1. Subjects OPR requested that all five subjects provide written responses detailing their involvement in the federal investigation of Epstein, the drafting and execution of the NPA, and decisions relating to victim notification and consultation. In addition, OPR conducted extensive interviews of each subject under oath and before a court reporter. Each subject was represented by counsel and had access to relevant contemporaneous documents before the subject’s OPR interview. The subjects reviewed and provided comments on their interview transcripts and on OPR’s draft report. 2. Witnesses OPR conducted more than 60 interviews of witnesses, including the FBI case agents, their supervisors, and FBI administrative personnel. OPR interviewed current and former USAO staff and attorneys and current and former Department attorneys and senior managers, including former Deputy Attorney General Mark Filip and former Assistant Attorney General for the Criminal Division Alice Fisher. OPR also interviewed former State Attorney Barry Krischer and former Assistant State Attorney Lanna Behlolovick. 3. Communications with Victims and Victims’ Attorneys OPR contacted attorneys known to represent 26 victims among the 30 surviving individuals who were identified in the USAO’s July 2008 listing of 32 victims the USAO was prepared to include in federal charges against Epstein and who accordingly were entitled to the benefits of the 18 U.S.C. § 2255 monetary damages provision ofthe NPA. OPR contacted Ithe attorneys to invite 289 CA/Aronberg-000757 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3728/2023 2:22:44 PM NOT A CERTIFIED COPY • • 6. U.S. Attorney's Office for the Middle District of Florida Records I The U.S. Attorney's Office for the Middle District of Florida provided OPR with records I related to its review of evidence against Epstein, after he concluded his Florida state sentence, when the Department recused the USAO in August 2011 from "all matters, to include the investigation and potential prosecution, relating to Jeffrey Epstein's alleged:sexual activities with minor females," and assigned the matter to the Middle District of Florida U.S. Attorney's Office for further consideration. The records included a declination of tlie matter due to the NP A. 7. U.S. Attorney's Office for the Northern District of;Georgia Records The U.S. Attorney's Office for the Northern District of Georgia provided OPR with records related to its work on the CVRA litigation after the recusal of the USAO. 8. Public Records OPR obtained and reviewed a variety of public records, including publicly released records of the Palm Beach Police Department, the State Attorney's Office for the 15th Judicial Circuit, and the Palm Beach Sheriff's Office; documents pertaining to the CVRA litigation and other court proceedings involving Epstein and related individuals; and books and media reports. B. Information from Subjects, Witnesses, and Victims 1. Subjects OPR requested that all five subjects provide written responses detailing their involvement in the federal investigation of Epstein, the drafting and execution of the NPA, and decisions relating to victim notification and consultation. In addition, OPR conducted extensive interviews of each subject under oath and before a court reporter. Each subject was represented by counsel and had access to relevant contemporaneous documents before the subject's OPR interview. The subjects reviewed and provided comments on their interview transcripts and on OPR's draft report. 2. Witnesses OPR conducted more than 60 interviews of witnesses, including the .FBI case agents, their supervisors, and FBI administrative personnel. OPR interviewed current aqd former USAO staff and attorneys and current and former Department attorneys and senior managers, including former Deputy Attorney General Mark Filip and former Assistant Attorney Gen:eral for the Criminal Division Alice Fisher. OPR also interviewed former State Attorney Barry Krischer and former Assistant State Attorney Lanna Behlolovick. 3. Communications with Victims and Victims' Attorneys OPR contacted attorneys known to represent 26 victims among the 39 surviving individuals who were identified in the USAO's July 2008 listing of 32 victims the USAO was prepared to I include in federal charges against Epstein and who accordingly were entitled to the benefits of the 18 U.S.C. § 2255 monetary damages provision of the NPA. OPR contacted 1the attorneys to invite 289 CA/Aronberg-000757 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM the victims to provide OPR with information regarding their contacts \yith, and notification received from, the FBI and USAO, during the period before the NPA was signed or before Epstein’s state plea hearing, about the status of the federal investigation, about Epstein’s state plea, or about the NPA. OPR received information from or pertaining to 13 victims. 290 CA/Aronberg-000758 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3728/2023 2:22:44 PM NOT A CERTIFIED COPY • • the victims to provide OPR with information regarding their contacts -»1ith, and notification received from, the FBI and USAO, during the period before the NPA was signed or before Epstein's state plea hearing, about the status of the federal investigation, abo~t Epstein's state plea, or about the NPA. OPR received information from or pertaining to 13 victih'ls. 290 CA/Aronberg-000758 I FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM I EXHIBIT 1 State Indictment CA/Aronberg-000759 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY • • EXHIBIT 1 State Indictment CA/Aronberg-000759 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. ~/28/2023 2:22:44 PM CA/Aronberg-000760 [Page Intentionally Left Blank] FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM i NOT A CERTIFIED COPY • • [Page Intentionally Left Blank] CNAronberg-000760 i FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. ~/28/2023 2:22:44 PM I INDICTMENT A TRUE BILL ^6 < rn IN THE NAME OF AND BY THE AUTHORITY OF THE STATE OF FLdRjD’A ..- • "1 *■r.-J-CD ■INLINE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA no • '^cn, For Palm Beach County, at the Spring Term thereof, in the-year of our Lord Two ThouSg^d IWd Six. to-wit: The Grand Jurors of the State of-Florida, inquiring^ Beach, upon their oaths do present that JEFFREYX. EPSTEIN in> the County of Palm Beach aforesaid, inthe Circuit and State. aforesaid, COUNT ONE •FELONY SOLICITATION OF PROSTITUTION On or aboutor betweemthe 1 st day of August in the year.of our Lord Two' Thousand and Four and October 31., 2005,. did solicit, induce, entice, or procure another to commit prostitution lewdness, or assignation, contrary to Florida Statute'796.07(1) on three or more occasions between August:0i, 2004.,and .October-31,;2005,. contrary to Florida Statute 796.07(2)(f) and:(4)(c). (3 DEG'FEL)(LEVEL1) against the form of the statute, to the evil example of all others, and against therpeace and dignity of the State ,of Florida; I hereby certify that I recortf in!my Wice. Y-Ci* 7// r/7 7/ -7> 3)wt&MUgutW ^ssiwant-State Attorney x Fifteenth.Judicial Circiiit of the State Florida , prosecuting for the; said ^&-o0>utYCiWK ' ‘State. ’ GRAND JURY FOREPERSON *1 Jeffrey E. Epstein, Race:White, Sexi Male, DOB: SS#: t IssueWarrant CA/Aronberg-000761 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • INDICTMENT,' .<{J ·;,6 • . • •• • •• • . .. · . ... . ·l~~· ·p, •• A~TRUE Bit.,L -(){,, r· q 1/.f 1/;,:(;r ~]-;_, 3. ,t_· -:_, • • • • • JCt, l.,, Jr.,:;: .;=. · f 1N ,rHe·NAM1;:oF AND av·THe·ALJTHOR~i-v. of:tH1;·stAte·~F F~1ffigA· \.::>· ~:-=· ;IN }tHE CIRCUiT·coURt OF THE, FIFTEENTH 'JUDICIAL. )8~. /~ }:J , •••••• ·c1RCUll.QF."J'.HE~STATE.OF:flORtOA .}~;;, '.~ '.,?]· .-::<:;; }:;; For Palm. 1:3,ea~h ,~ou~ty. ·at ,th_e Spring. "!ern). tt\er~of,: in ·the :Y~Br Qf our, Lora:·TYJo Thqµs~d ~d Sl;, !?;wib Th~ Gra,nc:i Jurors'.~J the· State of,f:iorjda;'inquiririg'.in;~ria:for the•pody·of ;said•Co~nty·of' Palm:Be~ch, upon ~heir ·oaths do :J?,resent "that Jl;FFREY: E., EPSTEIN. in, t~e Courity of P~lm 'sea ch. afor~S?ld, :ir1 •.tt,e Circuit. 'and' Stat~ af<>resaid_; :COUNT ONE· ·F~LONY·souciTA'T'ION OF,RF{osr1tut10.N· on•or ab~ut_orbetwe.en,tt,~:HS!.day ·at Augustin the._y~ar.of, our t;.or~,Tw9'Thousanda_nr:J Four-~rid•Qct<:>t>t'3r :31,, :·2oqs,:c:t1d ~qlicJt;Jriquc::~. ent!c~; .6( prqcure.af!6therto commit .P'9~,1tution,1ewd[19.~s,,or ass!gn.atioli; coritr~"ry -t<:> ·-F.lorid~·St~tute'796'.07( 1).on t~ree or,_ more occasio.ns.between ·A~~ust 0 1',. 2004,.;:~n.d ·.October3l,; ~OO;i;. contrary to Florida Stc!tUte'796:07(~)(f) and:(4)(c): ,(_3 D~G~FEt)(~EVEL 1,) against, the_ fomi_ ofthe sta_tuie;. to tt:ie evil exc1mple. of. all ot_hers, ·and :against 'the:peace and:digr,,ity•of the State,· • '\ • • • - • • • • I '-. ,• • • • ,of Floriga, .I hereby c • • • • • . • • t~f.i~ '1(WYetUrn,ing this indictment as.au,ttiorfzed.and,required by'iaw'. , ' . : . ~ ... ·:; , . . ·- , •• ~ .. ' , • • • l!l.~,e.trr~:111tyAn. a\.'.".~ /) . ' .1 18iegoing •is .nrue copy . ,_.,• •: . •I ~e n!co111 iti'.inY:ii«.tce. • :- ' • L: • • ~ •~ ;~;,, • . • .. EL •JE,!ffrey E. _Epstein, Rae~: White". S~i: Mc1le,DOB: SS#: Issue Warrant CA/ Aronberg-000761 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3/28/2023 2:22:44 PM CA/Aronberg-000762 [Page Intentionally Left Blank] FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY • • [Page Intentionally Left Blank] CNAronberg-000762 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3./28/2023 2:22:44 PM EXHIBIT 2 I September 6, 2007 Draft Non-Prosecution Agreement CA/Aronberg-000763 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY CA/Aronberg-000763 • • EXHIBIT 2 September 6, 2007 Draft Non-Prosecution Agreement FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. J/28/2023 2:22:44 PM I [Page Intentionally Left Blank] I CA/Aronberg-000764 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • [Page Intentionally Left Blank] CA/Aronberg-000764 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM ' IN RE: INVESTIGATION OF JEFFREY EPSTEIN_/ NON-PROSECUTION AGREEMENT IT APPEARING that Jeffrey Epstein (hereinafter “Epstein”) is reported to have committed offenses against the United States from in or around 2001 through in or around October 2005, including: (1) knowingly and willfully conspiring with others known and unknown to commit an offense against the United States, that is, to use a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution, in violation of Title 18, United States Code, Section 2422(b); all in violation of Title 18, United States Code, Section 371; (2) knowingly and willfully conspiring with others known and unknown to travel in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18, United States Code, Section 2423(b); all in violation of Title 18, United States Code, Section 2423(e); (3) using a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2; (4) . traveling in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f), with minor females; in violation of Title 18, United States Code, Section 2423(b); and (5) knowingly, in and affecting interstate and foreign commerce, recruiting, enticing, and obtaining by any means a person, knowing that the person had not attained the age of 18 years and would be caused to engage in a commercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title 18^United States Code, Sections 1591(a)(1) and 2; and IT APPEARING that Epstein has accepted responsibility for {hisbehavior by his flays 1 o<j) 4 j CA/Aronberg-000765 FILED; PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • INRE: INVESTIGATION OF JEFFREY EPSTEIN I ------------ NON-PROSECUTION AGREEMENT IT APPEARING that Jeffrey Epstein (hereinafter "Epstein") is reported to have committed offenses against the United States from in or around 2001 through in or around October 2005, including: (1) (2) (4) ' (5) knowingly and willfully conspiring with others known and unknown to commit an offense against the United States, that is, to use a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution, in violation of Title 18, United States Code, Section 2422(b ); all in violation of Title 18, United States Code, Section 3 71; knowingly and willfully conspiring with others known and unknown to travel in interstate commerce for the purpose of engaging in illidt sexual conduct, as defined in 18 U.S.C. § 2423(£), with minor females, in violation of Title 18, United States Code, Section 2423(b ); all in violation of Title 18, United States Code, Section 2423(e); using a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2; traveling in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(£), with minor females; in violation of Title 18, United States Code, Section 2423(b ); and knowingly, in and affecting interstate and foreign commerce, recruiting, enticing, and obtaining by any means a person, knowing that the person had not attained the age of 18 years and would be caused to engage in a commercial sex act as defined in 18 U.S.C. § 159l(c)(l); in violation of Title 18'. United States Code, Sections 1591(a)(l) and 2; and ' IT APPEARING that Epstein has accepted responsibility for ihis behavior by his I Tiay6 1 o<p 4 i l CNAronberg-000765 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. f28/2023 2:22:44 PM signature on this Agreement; and i IT APPEARING, after an investigation of the offenses and Epstein’s background, that the interest of the United States and Epstein’s own interest and the interest of justice will be served by the following procedure; THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the following conditions and the requirements of this Agreement set out below. Should Epstein violate any of the conditions of this Agreement, the United States Attorney may at any time initiate prosecution against Epstein for any offense. In this case, the United States Attorney will furnish Epstein with notice specifying the conditions of the Agreement which he has violated. After timely fulfilling all the terms and conditions of the Agreement, no prosecution for the offenses set out on page 1 of this Agreement will be instituted in this District, and the charges against Epstein if any, will be dismissed. Neither this Agreement nor any other document filed with the United States Attorney as part of this Agreement will be used against Epstein, except for impeachment purposes, in connection with any prosecution for the above-described offenses. Terms of the Agreement: 1. Epstein shall plead guilty (not nolo contendere) to an Information filed by the State Attorney’s Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, the “State Attorney’s Office”) charging violations of the following Florida Statutes: (a) lewd and lascivious battery on a child, in violation of Fl. Stat. 800.04(4); (b) solicitation of minors to engage in prostitution, in violation of Fl. Stat. 796.03; and (c) engaging in sexual activity with minors at least sixteen years of age, in violation of Fl. Stat. 794.05. 2. Epstein and the State Attorney’s Office shall make a joint, binding recommendation that Epstein serve at least two years in prison, without any opportunity for withholding adjudication or sentencing; and without probation or community control in lieu of imprisonment. Haye 2 o<|) 4 CA/Aronberg-000766 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • signature on this Agreement; and I IT APPEARING, after an investigation of the offenses and Epstein's background, that the interest of the United States and Epstein's own interest and the inter~st of justice will be served by the following procedure; 1 THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the following conditions and the requirements of this Agreement set out below. Should Epstein violate any of the conditions of this Agreement, the United States Attorney may at any time initiate prosecution against Epstein for any offense. In this case, the United States Attorney will furnish Epstein with notice specifying the conditions of the Agreement which he has violated. After timely fulfilling all the terms and conditions of the Agreement, no prosecution for the offenses set out on page 1 of this Agreement will be instituted in this District, and the charges against Epstein if any, will be dismissed. Neither this Agreement nor any other document filed with the United States Attorney as part o( this Agreement will be used against Epstein, except for impeachment purposes, m connection with any prosecution for the above-described offenses. Terms of the Agreement: CA/Aronberg-000766 1. Epstein shall plead guilty (not nolo contendere) to an Information filed by the State Attorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, the "State Attorney's Office") charging violations of the following Florida Statutes: (a) lewd and lascivious battery on a child, in violation of Fl. Stat. 800.04(4); (b) solicitation of minors to engage in prostitution, in violation of Fl. Stat. 796.03; and • (c) engaging in sexual activity with minors at least sixteen years of age, in violation of Fl. Stat. 794.05. 2. Epstein and the State Attorney's Office shall make a joint, binding recommendation that Epstein serve at least two years in prison, without any opportunity for withholding adjudication or se&tencing; and without probation or community control in lieu of imprisonm 1ent. I IlayE 2 ocp 4 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM 3. Epstein shall waive all challenges to the Information filed by the State Attorney’s Office and shall waive the right to appeal his conviction and sentence. 4. Epstein agrees that, if any of the victims identified in the federal investigation file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the U.S. District Court for the Southern District of Florida over his person and/or the subject matter, and Epstein will not contest that the identified victims are persons who, while minors, were victims of violations of Title 18, United States Code, Sections(s) 2422 and/or 2423. 5. The United States shall provide Epstein’s attorneys with a list of the identified victims, which will not exceed forty, after Epstein has signed this agreement and entered his guilty plea. The United States shall make a motion with the United States District Court for the Southern District of Florida for the appointment of a guardian ad litem for the identified victims and Epstein’s counsel may contact the identified victims through that counsel. 6. Epstein shall enter his guilty plea and be sentenced not later than September 28, 2007, and shall begin service of his sentence not later than October 15, 2007. By signing this agreement, Epstein asserts and certifies that each of these terms is material to this agreement and is supported by independent consideration and that a breach of any one of these conditions allows the United States to elect to terminate the agreement and to investigate and prosecute Epstein for any and all federal offenses. By signing this agreement, Epstein asserts and certifies that he is aware of the fact that the Sixth Amendment to the Constitution of the United States provides that in all criminal prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court may dismiss an indictment, information, or complaint for unnecessary delay in presenting a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein hereby requests that the United States Attorney for the Southern District of Florida defer such prosecution. Epstein agrees and consents that any delay from the date of this Agreement to the date of initiation of prosecution, as provided for in the terms expressed herein, shall be deemed to be a necessary delay at his own request, and he hereby waives any defense to such prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the United States to a speedy trial or to bar the prosecution by reason of the running of the statute of limitations for a period of months equal to the period between the signing of this agreemenVand the breach of this Uaye 3 o<j> 4 CA/Aronberg-000767 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • 3. Epstein shall waive all challenges to the Information filed by the State Attorney's Office and shall waive the right to appekl his conviction and sentence. j 4. Epstein agrees that, if any of the victims identified in the federal investigation file suit pursuant to 18 U.S.C. § 22'.55, Epstein will not contest the jurisdiction of the U.S. District Court for the Southern District of Florida over his person and/or the subject matter,' and Epstein will not contest that the identified· victims are persons who, while minors, were victims of violations of Title 18, United States Code, Sections(s) 2422 and/or 2423. 5. The United States shall provide Epstein's attorneys with a list of the identified victims, which will not exceed forty, after Epstein has signed this agreement and entered his guilty plea. The United States shall make a motion with the United States District Court for the Southern District of Florida for the appointment of a guardian ad !item for the identified victims and Epstein's counsel may contact the identified victims through that counsel. 6. Epstein shall enter his guilty plea and be sentenced not later than September 28, 2007, and shall begin service of his sentence not later than October 15, 2007. By signing this agreement, Epstein asserts and certifies that each of these terms is material to this agreement and is supported by independent consideration and that a breach of any one of these conditions allows the United States to elect to terminate the agreement and to investigate and prosecute Epstein for any and all federal offenses. By signing this agreement, Epstein asserts and certifies that he is aware of the fact that the Sixth Amendment to the Constitution of the United States provides that in all criminal prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court may dismiss an indictment, information, or complaint for unnecessary delay in presenting a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein hereby requests that the United States Attorney for the Southern District of Florida defer such prosecution. Epstein agrees and consents that any delay from the date of this Agreement to the date of initiation of prosecution, as provided for in the terms expressed herein, shall be deemed to be a necessary delay at his own request, and he hereby waives any defense to such prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the United States to a speedy trial or to bar the prosecution by reason of the running of the statJte of limitations for a period of months equal to the period between the signing of this agreement:and the breach of this Daye 3 ocp 4 CA/Aronberg-000767 I I I FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM agreement. Epstein further asserts and certifies that he understands that the Fifth Amendment and Rule 7(a) of the Federal Rules of Civil Procedure provide that all felonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees and consents that, if a prosecution against him is instituted, it may be by way of an Information signed and filed by the United States Attorney, and hereby waives his right to be indicted by a grand jury. By signing this agreement, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the conditions of this non-Prosecution Agreement and agrees to comply with them. - Dated:_ Jeffrey Epstein Dated:_ Roy Black, Esq. Counsel to Jeffrey Epstein R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated:_ By: A. Marie Villafana Assistant United States Attorney Hays 4 o(|) 4 CA/Aronberg-000768 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • agreement. Epstein further asserts and certifies.that he understands that the Fifth Amendment and Rule 7(a) of the Federal Rules of Civil Procedure provide that all felo 1nies must be charged in an indictment presented to a grand jury. Epstein hereby agrees ana consents that, if a I prosecution against him is instituted, it may be by way of an Information signed and filed by the United States Attorney, and hereby waives his right to be indicted by a gran:d jury. By signing this agreement, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the' conditions of this non-Prosecution Agreement and agrees to comply with them. Dated: ----- Dated: ----- Dated: ----- CA/Aronberg-000768 Jeffrey Epstein Roy Black, Esq. Counsel to Jeffrey Epstein R. ALEXANDER ACOSTA UNITED ST A TES ATTORNEY By: A. Marie Villafana Assistant United States Attorney Ilaye 4 o<f> 4 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM EXHIBIT 3 September 24, 2007 Non-Prosecution Agreement CA/Aronberg-000769 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY CA/Aronberg-000769 • • EXHIBIT 3 September 24, 2007 Non-Prosecution Agreement FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM [Page Intentionally Left Blank] CA/Aronberg-000770 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY • • [Page Intentionally Left Blank] CA/Aronberg-000770 ' FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM I IN RE: INVESTIGATION OF JEFFREY EPSTEIN_/ NON-PROSECUTION AGREEMENT IT APPEARING that the City of Palm Beach Police Department and the State Attorney’s Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, the “State Attorney’s Office”) have conducted an investigation into the conduct of Jeffrey Epstein (hereinafter “Epstein”); IT APPEARING that the State Attorney’s Office has charged Epstein by indictment with solicitation ofprostitution, in violation of Florida Statutes Section 796.07; IT APPEARING that the United States Attorney’s Office and the Federal Bureau of Investigation have conducted their own investigation into Epstein’s background and any offenses that may have been committed by Epstein against the United States from in or around 2001 through in or around September 2007, including: (1) knowingly and willfully conspiring with others known and unknown to commit an offense against the United States, that is, to use a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution, in violation ofTitle 18, United States Code, Section 2422(b); all in violation ofTitle 18, United States Code, Section 371; (2) knowingly and willfully conspiring with others known and unknown to travel in interstate commerce for the purpose ofengaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18, United States Code, Section 2423(b); all in violation ofTitle 18, United States Code, Section 2423(e); (3) using a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2; (4) traveling in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f), with minor females; in violation ! i

Page 1 of 7 t i CA/Aronberg-000771 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • INRE: INVESTIGATION OF JEFFREY EPSTEIN ------------'' NON-PROSECUTION AGREEMENT IT APPEARING that the City of Palm Beach Police Department and the State Attorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey Epstein (hereinafter "Epstein"); IT APPEARING that the State Attorney's Office has charged Epstein by indictment with solicitation of prostitution, in violation of Florida Statutes Section 796.07; IT APPEARING that the United States Attorney's Office and the Federal Bureau of Investigation have conducted their own investigation into Epstein's background and any offenses that may have been committed by Epstein against the United States from in or around 2001 through in or around September 2007, including: (1) (2) (3) (4) CA/ Aronberg-000771 knowingly and willfully conspiring with others known and unknown to commit an offense against the United States, that is, to use a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution, in violation of Title 18, United States Code, Section 2422(b ); all in violation of Title 18, United States Code, Section 371; knowingly and willfully conspiring with others known and unknown to travel in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18, United States Code, Section 2423(b ); all in violation of Title 18, United States Code, Section 2423(e); using a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2; traveling in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f), with minor fe~ales; in violation i

Page 1 of 7 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM of Title 18, United States Code, Section 2423(b); and (5) knowingly, in and affecting interstate and foreign commerce, recruiting, enticing, and obtaining by any means a person, knowing that the person had not attained the age of 18 years and would be caused, to engage in a commercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation ofTitle 18, United States Code, Sections 1591(a)(1) and 2; and IT APPEARING that Epstein seeks to resolve globally his state and federal criminal liability and Epstein understands and acknowledges that, in exchange, for the benefits provided by this agreement, he agrees to comply with its terms, including undertaking certain actions with the State Attorney’s Office; IT APPEARING, after an investigation ofthe offenses and Epstein's background by both State and Federal law enforcement agencies, and after due consultation with the State Attorney's Office, that the interests of the United States, the State of Florida, and the Defendant will be served by the following procedure; THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor ofprosecution by the State ofFlorida, provided that Epstein abides by the following conditions and the requirements of this Agreement set forth below. If the United States Attorney should determine, based on reliable evidence, that, during the period ofthe Agreement, Epstein willfully violated any of the conditions of this Agreement, then the United States Attorney may, within ninety (90) days following the expiration of the term of home confinement discussed below, provide Epstein with timely notice specifying the condition(s) ofthe Agreement that he has violated, and shall initiate its prosecution on any offense within sixty (60) days’ of giving notice of the violation. Any notice provided to Epstein pursuant to this paragraph shall be provided within 60 days ofthe United States learning of facts which may provide a basis for a determination ofa breach of the Agreement. After timely fulfilling all the terms and conditions ofthe Agreement, no prosecution for the offenses set out on pages 1 and 2 ofthis Agreement, nor any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney’s Office, nor any offenses that arose from the Federal Grand Jury investigation will be instituted in this District, and the charges against Epstein ifany, will be dismissed.

Page 2 of 7 CA/Aronberg-000772 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM ’ ’ 5 I NOT A CERTIFIED COPY (5) • • of Title 18, United States Code, Section 2423(b); and I kn • 1. d f:C.. dfi • j •• owrng y, rn an a 1ectmg mterstate an ore1gn commerce, recnntrng, enticing, and obtaining by any means a person,_knowing th~t the person had not attained the age of 18 years and would be caused, to engage in a commercial sex act as defrned in 18 U.S.C. § 1591(c)(l); in violation of Title 18, United States Code, Sections 159l(a)(l) and 2; and IT APPEARING that Epstein seeks to resolve globally his state and federal criminal liability and Epstein understands and acknowledges that, in exchange, for the benefits provided by this agreement, he agrees to comply with its terms, including undertaking certain actions with the State Attorney's Office; IT APPEARING, after an investigation of the offenses and Epstein's background by both State and Federal law enforcement agencies, and after due consultation with the State Attorney's Office, that the interests of the United States, the State of Florida, and the Defendant will be served by the following procedure; TIIEREFORE, on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the following conditions and the requirements of this Agreement set forth below. If the United States Attorney should determine, based on reliable evidence, that, during the period of the Agreement, Epstein willfully violated any of the conditions of this Agreement, then the United States Attorney may, within ninety (90) days following the expiration of the term of home confinement discussed below, provide Epstein with timely notice specifying the condition(s) of the Agreement that he has violated, and shall initiate its prosecution on any offense within sixty (60) days' of giving notice of the violation. Any notice provided to Epstein pursuant to this paragraph shall be provided within 60 days of the United States learning of facts which may provide a basis for a determination of a breach of the Agreement. After timely fulfilling all the terms and conditions of the Agreemerit, no prosecution for the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United, States Attorney's Office, nor any offenses that arose from the Federal Grand Jury investigation will be instituted in this District, and the charges against Epstein if any, will be dismissed.

Page 2 of 7 CNAronberg-000772 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. V28/2023 2:22:44 PM • • Terms ofthe Agreement: 1. Epstein shall plead guilty (not nolo contendere) to the Indictment as currently pending against him in the 15th Judicial Circuit in and for Palm Beach County (Case No. 2006-cf-009495AXXXMB) charging one (1) count of solicitation of prostitution, in violation of Fl. Stat. § 796.07. In addition, Epstein shall plead guilty to an Information filed by the State Attorney’s Office charging Epstein with an offense that requires him to register as a sex offender, that is, the solicitation of minors to engage in prostitution, in violation ofFlorida Statutes Section 796.03; 2. Epstein shall make a binding recommendation that the Court impose a thirty (30) month sentence to be divided as follows: (a) Epstein shall be sentenced to consecutive terms of twelve (12) months and six (6) months in countyjail for all charges, without any opportunity for withholding adjudication or sentencing, and without probation or community control in lieu of imprisonment; and (b) Epstein shall be sentenced to a term of twelve (12) months of community control consecutive to his two terms in county jail as described in Term 2(a), supra. 3. This agreement is contingent upon a Judge ofthe 15th Judicial Circuit accepting and executing the sentence agreed upon between the State Attorney’s Office and Epstein, the details ofwhich are set forth in this agreement. 4. The terms contained in paragraphs 1 and 2, supra, do not foreclose Epstein and the State Attorney’s Office from agreeing to recommend any additional charge(s) or any additional term(s) of probation and/or incarceration. 5. Epstein shall waive all challenges to the Information filed by the State Attorney’s Office and shall waive the right to appeal his conviction and sentence, except a sentence that exceeds what is set forth in paragraph (2), supra. 6. Epstein shall provide to the U.S. Attorney’s Office copies of all

Page 3 of 7 CA/Aronberg-000773 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Tenns of the Agreement: CA/Aronberg-000773 1. Epstein shall plead guilty (not nolo contendere) to the Indictment as currently pending against him in the 15th Judicial Circuit in and for Palm Beach County (Case No. 2006-cf-009495AXXXMB) charging one (1) count of solicitation of prostitution, in violation of FL Stat.§ 796.07. In addition, Epstein shall plead guilty to an Infonnation filed by the State Attorney's Office charging Epstein with an offense that requires him to register as a sex offender, that is, the solicitation of minors to engage in prostitution, in violation of Florida Statutes Section 796.03; 2. Epstein shall make a binding recommendation that the Court impose a thirty (30) month sentence to be divided as follows: (a) Epstein shall be sentenced to consecutive terms of twelve (12) months and six (6) months in county jail for all charges, without any opportunity for withholding adjudication or sentencing, and without probation or community control in lieu of imprisonment; and (b) Epstein shall be sentenced to a term of twelve (12) months of community control consecutive to his two terms in county jail as described in Term 2(a), supra. 3. This agreement is contingent upon a Judge of the 15th Judicial Circuit accepting and executing the sentence agreed upon between the State Attorney's Office and Epstein, the details of which ate set forth in this agreement. 4. The terms contained in paragraphs 1 and 2, supra, do not foreclose Epstein and the State Attorney's Office from agreeing to recommend any additional charge(s) or any additional term(s) of probation and/or incarceration. 5. Epstein shall waive all challenges to the Information filed by the State Attorney's Office and shall waive the right to appeal his conviction and sentence, except a sentence that exceeds what is set forth in paragraph (2), supra. 6. Epstein shall provide to the U.S.

Page 3 of 7 Attorney's Office copies of all I I I I ! I FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM proposed agreements with the State Attorney’s Office prior to entering into those agreements. 7. The United States shall provide Epstein’s attorneys with a list of individuals whom it has identified as victims, as defined in 18 U.S.C. § 2255, after Epstein has signed this agreement and been sentenced. Upon the execution ofthis agreement, the United States, in consultation with and subject to the good faith approval ofEpstein’s counsel, shall select an attorney representative forthese persons, who shall be paid for by Epstein. Epstein’s counsel may contact the identified individuals through that representative. 8. If any of the individuals referred to in paragraph (7), supra, elects to file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction ofthe United States District Court for the Southern District ofFlorida over his person and/or the subject matter, and Epstein waives his right to contest liability and also waives his right to contest damages up to an amount as agreed to between the identified individual and Epstein, so long as the identified individual elects to proceed exclusively under 18 U.S.C. § 2255, and agrees to waive any other claim for damages, whether pursuant to state, federal, or common law. Notwithstanding this waiver, as to those individuals whose names appear on the list provided by the United States, Epstein’s signature on this agreement, his waivers and failures to contest liability and such damages in any suit are not to be construed as an admission of any criminal or civil liability. 9. Epstein’s signature on this agreement also is not to be construed as an admission ofcivil or criminal liability or a waiver of any jurisdictional or other defense as to any person whose name does not appear on the list provided by the United States. 10. Except as to those individuals who elect to proceed exclusively under 18 U.S.C. § 2255, as set forth in paragraph (8), supra, neither Epstein’s signature on this agreement, nor its terms, nor any resulting waivers or settlements by Epstein are to be construed as admissions or evidence of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person, whether or not her name appears on the list provided by the United States. 11. Epstein shall use his best efforts to enter his guilty plea and be i

Page 4 of 7 I i i CA/Aronberg-000774 ' FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY CA/Aronberg-000774 • • proposed agreements with the State Attorney's Office prior to entering into those agreements. I I I 7. The United States shall provide Epstein's attorneys with a list of individuals whom it has identified as victims, as defined in 18 U.S.C. § 2255, after Epstein has signed this agreement and been sentenced. Upon the execution of this agreement, the United States, in consultation with and subject to the good faith approval of Epstein's counsel, shall select an attorney representative for these persons, who shall be paid for by Epstein. Epstein's counsel may contact the identified individuals through that representative. 8. If any of the individuals referred to in paragraph (7), supra, elects to file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the United States District Court for the Southern District of Florida over his person and/or the subject matter, and Epstein waives his right to contest liability and also waives his right to contest damages up to an amount as agreed to between the identified individual and Epstein, so long as the identified individual elects to proceed exclusively under 18 U.S.C. § 2255, and agrees to waive any other claim for damages, whether pursuant to state, federal, or common law. Notwithstanding this waiver, as to those individuals whose names appear on the list provided by the United States, Epstein's signature on this agreement, his waivers and failures to contest liability and such damages in any suit are not to be construed as an admission of any criminal or civil liability. 9. Epstein's signature on this agreement also is not to be construed as an admission of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person whose name does not appear on the list provided by the United States. 10. Except as to those individuals who elect to proceed exclusively under 18 U.S.C. § 2255, as set forth in paragraph (8), supra, neither Epstein's signature on this agreement, nor its terms, nor any resulting waivers or settlements by Epstein are to be construed as admissions or evidence of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person, whether or not her name appears on the list provided by the United States. 11. Epstein shall use his best efforts to enter his guilty plea and be !

Page 4 of 7 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM sentenced not later than October 26, 2007. The United States has no objection to Epstein self-reporting to begin serving his sentence not later than January 4,2008. 12. Epstein agrees that he will not be afforded any benefits with respect to gain time, other than thefights, opportunities, arid benefits as tiny other inmate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States’ request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration. 13. The parties anticipate that this agreement will not be made part of any public record. Ifthe United States receives a Freedom ofInformation Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before making that disclosure. Epstein understands that the United States Attorney has no authority to require the State Attorney’s Office to abide by any terms of this agreement. Epstein understands that it is his obligation to undertake discussions with the State Attorney’s Office and to use his best efforts to ensure compliance withthese procedures, which compliance will be necessary to satisfy the United States’ interest. Epstein also understands that it is his obligation to use his best efforts to convince the Judge ofthe 15th Judicial Circuit to accept Epstein’s binding recommendation regarding the sentence to be imposed, and understands that the failure to do so will be a breach ofthe agreement. In consideration ofEpstein’s agreement to plead guilty and to provide compensation inthe manner described above, ifEpstein successfully fulfills all ofthe terms and conditions ofthis agreement, the United States also agrees that it will not institute any crimina^hames against any potential co-conspirators of Epstein, including but not limited to Further, execution agreement and a plea agreement with the State Attorney’s Office, the federal Grand Jury investigation will be suspended, and all pending federal Grand Jury subpoenas will be held in abeyance unless and until the defendant violates any term of this agreement. The defendant likewise agrees to withdraw his pending motion to intervene and to quash certain grand jury subpoenas. Both parties agree to maintain their evidence, specifically evidence requested by or directly related to the grand jury subpoenas that have beeri issued, and including certain computer equipment, inviolate until all ofthe terms ofthis agreement have been satisfied. Upon the successful completion of the terms of this agreement, all outstanding grand jury subpoenas shall be deemed withdrawn.

Page 5 of 7 CA/Aronberg-000775 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • sentenced not later than October26, 2007. The United States has no objection to Epstein self-reporting to begin serving his sentence not later than January 4, 2008. 12. Epstein agrees that he will not be afforded any benefits with respect to gairi time, other than the tights, opportunities, and benefits as any other inmate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned. during his period of incarceration. 13. The parties anticipate that tlus agreement will not be macie part of any public record. If the United States receives a Freedom oflnformation Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before making that disclosure. Epstein understands that the United States Attorney has· no authority to require the State Attorney's Office to abide by any terms of this agreement. Epstein understands that it is his obligation to undertake discussions with the State Attorney's Office and to use his best efforts to ensure compliance with these procedures, which compliance will be necessary to satisfy the United States' interest. Epstein also under~tands that it is his obligationtouse his best efforts to convince the Judge of the 15th Judicial Circuit to accept Epstein's binding r~ommendation regarding the sentence to be imposed, and understands that the failure to do so will be a breach of the agreement. In consideration of Epstein's agreement to plead guilty and to provide coml)(:nsation inthe manner described· above, if Epstein successfully fulfills all of the terms and conditions of this agreement, the United States also agrees that it will not institute any criminal char es against any potential cerconspirators of Epstein, lncluding but not limited to Further, upon execution of this • agreement and a plea agreement with the State Attomcy's Office, the fed~ral Grand Jury investigation will be suspended, and all pending federal Grand Jury subpoenas will be held in abeyance unless and until the defendant violates any term of this agreement. The defendant likewise agrees to withdraw his pending motion to intervene and to quash certain. grand jury subpoenas. Both parties agree to maintain their evidence, specifically evidence rcqu~tcd by or dit:ectly related to the grand jury subpoenas that have beert issued, and including certain computer equipment, inviolate until all of the terms of this agreement have been satisfied. Upon the .successful completion .of the terms of this agreement, all outstanding grand jury subpoenas shall be deemed withdrawn.

Page 5 of 7 CA/Aronberg-000775 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM By signing this agreement, Epstein asserts and certifies that each of these terms is material to this agreement and is supported by independent consideration and that a breach of any one of these conditions allows the United States to elect to terminate the agreement and to investigate and prosecute Epstein and any other individual or entity for any and all federal offenses. By signing this agreement, Epstein asserts and certifies that he is aware ofthe fact that the Sixth Amendment to the Constitution of the United States provides that in all criminal prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further is aware that Rule 48(b) ofthe Federal Rules ofCriminal Procedure provides that the Court may dismiss an indictment, information, or complaint for unnecessary delay in presenting a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein hereby requests that the United States Attorney forthe Southern District ofFlorida defer such prosecution. Epstein agrees and consents that any delay from the date ofthis Agreement to the date of initiation of prosecution, as provided for in the terms expressed herein, shall be deemed to be a necessary delay at his own request, and he hereby waives any defense to such prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of the Federal Rules ofCriminal Procedure and the Sixth Amendment to the Constitution ofthe United States to a speedy trial or to bar the prosecution by reason ofthe running ofthe statute of limitations for a period of months equal to the period between the signing of this agreement and the breach ofthis agreement as to those offenses that were the subject of the grandjury’s investigation. Epstein further asserts and certifies that he understands that the Fifth Amendment and Rule 7(a) ofthe Federal Rules of Criminal Procedure provide that all felonies must be charged in an indictment presented to a grandjury. Epstein hereby agrees and consents that, if a prosecution against him is instituted for any offense that was the subject ofthe grandjury’s investigation, it may be by way ofan Information signed and filed by the United States Attorney, and hereby waives his right to be indicted by a grandjury as to any such offense. Ill III III

Page 6 of 7 CA/Aronberg-000776 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • By signing this agreement, Epstein asserts and certifies that each of these terms is material to this agreement and is supported by independent consideration and that a breach of any one of these conditions allows the United States to elect to terminate the agreement and to investigate and prosecute Epstein and any other individual or entity for any and all federal offenses. By signing this agreement, Epstein asserts and certifies that he is aware of the fact that the Sixth Amendment to the Constitution of the United States provides that in all criminal prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court may dismiss an indictment, information, or complaint for unnecessary delay in presenting a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein hereby requests that the United States Attorney for the Southern District ofFlorida defer such prosecution. Epstein agrees and consents that any delay from the date of this Agreement to the date of initiation of prosecution, as provided for in the terms expressed herein, shall be deemed to be a necessary delay at his own request, and he hereby waives any defense to such prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the United States to a speedy trial or to bar the prosecution by reason of the running of the statute of limitations for a period of months equal to the period between the signing of this agreement and the breach of this agreement as to those offenses that were the subject of the grand jury's investigation. Epstein further asserts and certifies that he understands that the Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all felonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees and consents that, if a prosecution against him is instituted for any offense that was the subject of the grand jury's investigation, it may be by way of an Information signed and filed by the United States Attorney, and hereby waives his right to be indicted by a grand jury as to any such offense. II I II I Ill CNAronberg-000776

Page 6 of 7 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 312812023 2:22:44 PM By signing lliisagreement, Epstein asserts aiici certifies that the above has been read and explained to him. Epstein hereby states that he understands the conditions of this Non¬ Prosecution Agreement and agrees to comply with. them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY A. MARIE VILLAFANA ASSISTANT U.S. ATTORNEY Dated JEFFREY’ Dated: GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN Dated LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7of7 CA/Aronberg-000777 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • -· ·13y_sig11i'qg Lliis agrcerpe11t;.Ep},teii1,asserts aiid 'c~tljftes that:thc)ibove has,bee1i 1'e~d ai1d expla\ned to :!1\m:. Epstein Hei·cby states t11at he undcrst~pds the cond i tions 0 qf t!1 is,~ on~ ~roscclilion_.Agrccmcnt and agrees to somrly. with. thcrp. By; CA/ Aronberg-000777 R:. AtEXANDERACOSTA UNITED s:r'.iTESATI◊R.NEY • A. :MARIE VILLAFANA AssfsTANT fos .• ATTQ~N-tY ·OERALi;:>.L13FCbUJ{t;:ESQ: C0VNSELTQ JEFFREY EJJ,SJEJN LiLLY ANN'SANCIJ~Z; isQ'. NFTORNEY FQR J½FFREY EPSTEIN FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM tBytsignmg-tblsrt^rccmfenUJ^THe above has been read and explained to him.J Epstein:hereby stales that he understands the.conditions of this Non¬ Prosecution Agreement and agrees to comply with them. R. ALEXANDEK ACOSTA UNITEDSTATESATTORNEY By: ASSISTANT U.S ATTORNEY Dated: . JEFFREY EPSTEIN Dated: 0 7 Dated:. ^RAED^K^liR^ES^ ' ' COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPS TEIN

Page 7 of 7' CA/Aronberg-000778 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • .1 13y:~ig11ing thi~,agl'ccm'9nt,'Eµ~tcincasscrls a11~Lccitifics that Hlc above h4s b~en rcaci anti cxplainc:d lo him, Epstcin:hcreby:slalc:rllmt he understands the concliti61\s ofthis'Nori:, i>ros,ec~ticrn ,A~recmci1t ,md,agrne; to,co1nply'•v;ith ·thcm. • • • By: ,?· Dated: , ... ~~-- CA/ Aronberg-000778 R. A1:i:xANDEll Atos\A UNJT~D STATJ2S A1TOR,Nl{Y ASSIS'FANTU.S. -Al~TDRNEY ~, --- - .. '·. ' ' -"---'--~~~-------'--'----: ULLYANN SANCHEZ, ESQ:. • ATI0RNEY }·oii '11::iiirni El'S'r~lN FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM By sighing;this agreement, Epstein asserts and certifies;that the abovchas.becn read and explained to him. Epstein herebystates that hc understands the conditions of this Non- Prosecution Agreement and agrees to comply with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: By: ___.___—- A. MARIE VJLLAFANA ASSISTANT U.S. ATTORNEY Dated: Dated: JEFFREY EPSTEIN GERALD, LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN Dated^cA^-^" TILLY ANN SAN^TlZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN

Page 7 of 7 CA/Aronberg-000779 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • l3y sigiJi,i1g(this agreement; ~stein_ ~~serts and ccrtifies;that ~he abovc·h!ls~becn ryaci and·cxplaincd.fo'niin, Epstcin·hercby·slales,that:hc'.undcrstands the·cohditions ofthisNoiic ~rosecution Agr.e1::111ent,and <1.gr(?c_s to comply_-\vith 01hem .. I)atcd: ____ .,.,--_ CA/ Aronberg-000779 R. ALEX:ANDERACOSTJ;\. 'UNTTED STATES ATTORJ'ffiY A;tviARJE-VJLLA;FANA ASSISTA.i\1T_;lJ;S. A'.TTORNEY ••• - •-- • •, A JEPEREY EP~TEIN. ••• GBRALD,LEfCO_Uitf, ~S,Q, COUNS~LTOJEFFRE'(EPS:TEIN~. ~-... A'l'TORNJ?Y'f.QRJEFFREYEPSTJ::TN P~gc7of: 7 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM CA/Aronberg-000780 [Page Intentionally Left Blank] FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • [Page Intentionally Left Blank] CA/Aronberg-000780 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM EXHIBIT 4 Addendum to the Non-Prosecution Agreement CA/Aronberg-000781 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • EXHIBIT 4 Addendum to the Non-Prosecution Agreement CA/Aronberg-000781 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM CA/Aronberg-000782 [Page Intentionally Left Blank] FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • [Page Intentionally Left Blank] CA/Aronberg-000782 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM IN RE: INVESTIGATION OF JEFFREY EPSTEIN_t ADDENDUM TO THE NON-PROSECUTION AGREEMENT IT APPEARING that the parties seek to clarify certain provisions ofpage 4, paragraph 7 of the Non-Prosecution Agreement (hereinafter “paragraph 7”), that agreement is modified as follows: 7A. the United States has the rightto assign to an independent third-party, the responsibility for consulting with and, subject to the good faith approval of Epstein's counsel, selecting the attorney representative for the individuals identified under the Agreement. If the United States elects to assign this responsibility to an independent third-party, both the United States and Epstein retain the right to make good faith objections to the attorney representative suggested by the independent third-party prior to the final designation of the attorney representative. 7B. The parties will jointly prepare a short written submission to the,independent third-party regarding the role of.the attorney representative and regarding Epstein’s Agreement to pay such attorney representative his or her regular customary hourly rate,for representing: such victims subject to the provisions of paragraph C, infra. 7C. Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the attorney representative selected by the independent third party. This provision, however, shall not obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus, ifafter consideration.Of potentialsettlements, an attorney representative elects to file a contested lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested remedy, the paragraph 7 obligation ofthe Agreement to pay the costs of the attorney representative, as opposed to any statutory or other obligations to pay reasonable attorneys fees and costs such as those containedin si2255 to bear the costs ofthe attorney representative, shall, cease. CA/Aronberg-000783 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • INRE: JNVESUGATION'OF JEFFREY :EPSTEIN ________ _,( ADDENDUM TOT~ ~ON-PROSECUTION AGI_IBEMENT • IT APPEARING that the parties seektoclarit'y'certajn provisions of page 4, paragraph 7 -of the Non-Prosecution Agreement (hereinafter ,;paragraph 7''), that agreement ,is modifi~ as follows: • 7 A. The United States has the right to assign to an independent thirdsparty. the responsibility for co11~u!ting .with and, ~ubject to the ·goc;id Jaith approv_al ofEpst.tim•~- co~nsel, s~lecting the attorney representative· for the individuals identified under the Agreement. If the United States elects to assign thisresponsibilify'to lili independentthird~party, both the- United States and Epstein retain the right to make good faith ob'jectiol)s to· the attorney .representative suggested by .the independent third-party prior to the finai designation of the.attorney representative. 7B. The parties will jointly prepare a short written submission to the,independent third-party regarding the r_ole of.the attorney representative and regarding Epstein 's:Agreemert(to pay such,attorney representative his:or her regular'customary hourly rate.for .representing such·victims. subjcctto the provisions of paragraph C, infra. 7C. Pursuant:to additional paragraph 7A, Epsteirthas agreed to pay the fees of the attorney .representative selected by the independent.third party. This provision, however, shall not obligate Epstein to pay:the fees and costs of contested litigation.filed-against hiin. Thus, if after consi,deration.ofpotentiatsettlements, an attorney ·representative electno file a contested lawsuit pursuantto 18 u:s.c. s 225l oi"elects to pursue an)' other-contested remedy, the paragraph 7 obligation of the Agreement to pay the costs. of the attorney representative, as opposed to any statutory-or other obligations:to pay reasonable attorneys Jees and costs such as .those contained in s 2255 to bear the costs of the attorney representativt:, shall. cease. CA/ Aronberg-00O783 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM iBysignin’g'this Addendum;Epsrein^erts and^ has been read and explained “to him; Epstein? hereby, states' that he understands the-clarifications to the.Non; \Pjosecution .Agreement and agrees tocomplywith them. iR?ALE^NbER. ACOSTA s rUNITED-STATES ATTORNEY .fe w " ' ' " ~ ~ 'WfAUMAME VlLLAFANA *~ ■" .ASSIST^ U.SJ-ATTORNEY !Dated\/^^-“ Dated: •... . _ __ , ■ ' . ■ - - . . ’ ■" ' GERALD LEFCOURT, ESQ. COWSEL.TOIEFFREyE^^ Dated; .7,-: — ■... / .. . .... . ■ . .. . sErcuy^mSANCHEZ^^^ rATTORNEY FOR JEFFREYEPSTEIN CA/Aronberg-000784 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • , , . ,By:signirl'g'tlifs,&d~na~;-:Epstein'.asserts ancli&iitifi.efttilit tb.eJ11>crvi:h~{-!,cen-f«fa~~~\cb : , ~~¥in~~:,,ro ,iji~:: • ~~te{n:f,hlf!Br.~ -~.~~~~(e~~tJ~;~~e~~\BAds '~~.;~1~#f !9~f !~ f:he;~!'fef ~;-·· • '-fj~~~uti~n::~~~nt.y,d'~grees to .co~P,ly;~tlj th~,. • • ' . .,.. .,. CA/Aronberg-000784 -t.-,, ~ '~' •.•:::~-,_,~, ......... "'A~•,_•~:~<• •-",_~- ,R;<':.\CEXANOER'ACOSTA~, . If~~M~Tf$'.~#o~et:. •By, ::~flHli~zY!:f ~~ fflWlf· '\mfA~:MA.RlB Vl~A~A1 ~ • '.:" • -~-· .AsststANT:u.s::A n:oRi-lEt • - • . ., '-0 .•• -If, •• ~ ' .......... ..,, , ':-· ~-~: -. ;-· .. :::: . FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM ; /By-Signing this-Addendum, Epstein asserts-^ certifieslffiat t^ai^ ^explained to-hinv.;Epstein:thereby- states;that hejunderstands the.clarifications-to*iheiNdn-. ‘Prosecution Agreement and agrees to' comply with them.. ’ ■ -* t Rd ALEXANDER ACOSTA, 'UNITED STATES ATTORNEY1 Dated Dated By: 7 // / '-O' A. MARIE VILLAFARA r ' ' assistantu^^ JEFFREY EPSTEIN. Dated:/^/^ 10? 'QEj^DmEFeoMTjES.QF " ' Dated L1EEY ANNSANCHEZ, ESQ'.-.-“ .AT^RfeYFOK CA/Aronberg-000785 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • CA/ Aronberg-000785 •· 1, JEFFREY'.EPSTEIN: • · -•--.-•·· . " sE(-1'6° . .. • iTEINn :.T -.-1-.s!- ·"-~- ... ;~, ·£'";.. ·:.w,..-... \;,, ',:..-">J •_-:J :-••;, -'••"J,,·• 'im1;v~ANRSANCHEZ,·Es~\ -~ ·: -~-- • . Nrm~-~tF QR: Jj3FF~Y~E.P.~TEhf • FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM By signing this Addendum, Epstein asserts and certifies that the above hw been read and; • explained to him. - Epstein hereby ‘stales that; he understands the clarifications ‘to the Non— Prosecution Agreement and agrees tb’comply with them.- ' 1 Dated: R. ALEXANDERACOSTA ;UNnw/s^ ' -.jg^MARIEVlEEAFANA J ASSISTANT U.S.‘ATTORNEY’ 'Datedt;..-. Dated: _ : TEFFREY EPSTEIN GERALD LEFCOURT, ESQ; - COUNSEL TO JEFFREY-EPSTEIN; ULLYANN^ANCHEZ, ESQ?-^” 7 ATTORNEYFORJEFFREYEPSTEIN I CA/Aronberg-000786 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY -~ __ r:•c: :·c ·t J "~.e • • ' . • -*.~_:' .'_~: .. :' -~~---~\-'.:~ .. -~ :._ • ;--:-: ----.'~ -.·:" :· --:-_"0t :.~~- - ~- .-~--=--;~~- ~'--:-·- ~- ~_{ - '-. ~~--.. :-; ~ . . -.! .. _ .:_: .: •• »~::--/?~ ~> .---~-- - ~--)·'.·;-,-",-:.·'\'·• ,_. ,-.-; ~- •. . . _ '~i;,si~~~~ tliis,,A,~~~ti~~;J~e5le~•s~~&it~ $ifi.~ ~a,i-ili~ ~gg~~;~~-~be~~~J~1~ • •'.CXJ>Lai1_1;d_ ;!9 •J!JlJ~ ,fl;!P-~,t:1_n~,li~.•$f~, ~~-ti he .. ~I?~~ta,m!s; .tb~"£l!l:f1fiyi1+1e>!l,S.:•!9.itl_l~.-]'!Qn:-: ~~~~~tiof~~ir}~t'~f~~~~ ~:~iit~~f~ii,!h ~~: • • ' •• • • - <~*~i'.=-=:··=•·==-=--=' .•. ii l H 1 l .. CA/ Aronberg-000786 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM EXHIBIT 5 State Information CA/Aronberg-000787 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • EXHIBIT 5 State Information CNAronberg-000787 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM CA/Aronberg-000788 [Page Intentionally Left Blank] FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • [Page Intentionally Left Blank] CA/Aronberg-000788 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT INAND FORTALM BEACH COUNTY, STATE OFFLORIDA CRIMINAL.DIVISION (LB) STATE OF FLORIDA ARISES FROM BOOKING NO;: 2006036744 vs. JEFFREY E EPSTEIN, W/M, | co INFORMATION FOR: I) PROCURING PERSON UNDER 18 FORPROST1TU1ON .1 FT! Ihthe.Nameandiby Authority pfthe State ofFlorid BARRY E. KR1SCHER, State Attorney for the Fifteenth'Judicial‘Circuit,’ Palm by and; through His undersigned Assistant State Attorney, charges that JEFFREY EEPSTEIN on or about or between the l “;day\>f August in the .year ofpurarid Four and October9,2005,/did knowingly and urilawfully procure for prdstitu causedto be .under theage of 1:8 yerirs; contrary to Florida Statute 796.03. (2 DEG FEE)’ TANNABELuITLAyEI FL. BAR NO. 0776726 Assistant State Attorney STATE OF FLORIDA COUNTY OF. PALM BEACH Appeared before me, LANNA BELOHLAVEK Assistant State Attorney for Palm Beach County, Florida,- personally kndwritome, who, being first duly’sworn,says.thatthe allegations;as set forth in the fpregbihg iriformatipn are basediupoh facts that have: been swdnftpas/true.and which, if true, would constitute the offense therein chargedLthat this.prosecutidn isTnstitutaj in good faith, and certifies that testimony under path hasbeenreceived/froiri thematerial witness or witness for the offensj^y/ Assistant. StateAttorney Sworn to and subscribed to before me thi^G^^ayofJune, 2008. NOTARY PUBLIC,^te ofFlorida STATE pf FLORIDA • PALM BEACH COUMY — DamaAPta ® W MTCOMMSSKW# ■!CO$i0M. rws L0/dp FC1C REFERENCE/NUMBERS: 1) FELONY SOLICITATION OF PROSTITUTION 3699 £1 t hereby cw lily tNai the RI; toreooing iss a true copy fl tt °f J?c°!d ’n W office. SHARON R. 80CK / COmROLLGR; ^7 fHM ’OA -aS CA/Aronberg-000789 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • ,wniE c1RcuJouR.:i. OF 'THE0f'1F'IEENTII illoic\;tlc1Rtorr • .nt:ANo i=oifrAi:rvt.aEAtH couN:rv;: st ATE oF:Fl;;oRmA • , , ·, CRIMIN/2L,DIVISI6N "W~ .(l;BJ •. o: i't_f · 1·3 :?/ STA;fE:OF FLOf{,IDA .ARISES' FR6tvtB00KING·N0::: '200603'674~ • , • • . . , , .• , STATE'OF.·FLORlDA ·cOtJNTY,oF:•rALM ·BEACH ·lNfORMATION,f,OR: • Appe~elbefo~e me; ~ANNA·.BE LOHLAVEK Assistant .State Attorney sf or Palm:Be.acl(Couill)\ Florida;·p~Of.lailtknown'fo me, who, being-first duly•SWOI1);,says.lhat,t~e 3!legat1ons,a~ se_t -fo~in the , .foregoing-information·a.te:based'upon facts;that,have:been swoirf·to as;We,.and which, iftiue~,would constitute • t~e offc'ns;thcrei~ charge<ii that ihis'.p~os~utidn .fs,fostinited. in-goti faith,:1m.d, ¢et:t1fies 1hat· t~tiino'ny Wlder oatn has,bee:n,rece!ved,Jrom:the.material witness-or .wi~~ -~·-.· ;\ssistan,t:~tatc:A~of!lC?Y • Sworfrto•tlild subscribed to bt!fore, me,thi~C1'¾ay ofJ\Ule, 700~. . ,. -· - - '. •• . .. ' ,LB/<ip FCICREFEREN<.%:NUMBERS: -1)'-fE!,;o~-~Qt•ciTATl@N QF:P~osrrr~:r10N 3~99 CA/Aronberg-000789 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3/28/2023 2:22:44 PM CA/Aronberg-000790 [Page Intentionally Left Blank] FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • [Page Intentionally Left Blank] CA/Aronberg-000790 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Appendix 4 CA/Aronberg-000791 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Appendix 4 CA/Aronberg-000791 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Page 1 IN THE FIFTEENTH JUDICIAL CIRCUIT COURT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502008GA037319 XXXX MB AB B.B., Plaintiff, vs. JEFFREY EPSTEIN, Defendant._! VOLUME I VIDEO-TAPED DEPOSITION OF MICHAEL REITER A WITNESS TAKEN BY THE PLAINTIFF DATE: November 23, 2009 TIME: 10:12 a.m. - 7:38 p.m. Page 3 i The deposition of MICHAEL REITER, a witness‘in the 2 above-entitled and numbered cause was taken before me. • 3 Vanessa G. Archer; Court'Repprter. NotaryTublic.fqr.the; 4 State .of Florida at Large, at 2925 PGA Boulevard, Palm Beach 5 Gardens, Florida, on the 23rd day of November, 2009, 6 pursuant to Notice in said cause for theitaking ofsaid 7 deposilion.on behalfof the Plaintiff. 8' 9 OF PLAINTIFF B.B.r 10 SPENCER T. KUVIN. ESQ. LEOPOLiKKUVIN,P.A. 11 2925.*PGA Boulevard, Suite 200 Palm Beach Gardens, Florida ,33410 12 13 .APPEARING ONBEHAEEOF PLAINTIFFS'JANE DOES 2-8: 14 ADAM HOROWITZ. ESQ. MERMH-STEIN & HOROWITZ, P:A. 1-5 18205iBiscayne Boulevard, Suite 2218 Miami, Fldrida:33160 16 .17 APPEARING ON BEHALF OF PLAINTIFF C.A.. 18 JACK.HILU.ESQ: SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, RA 19 - 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 20 21. APPEARING ON BEHALF OF PLAINTIFF: 22 ISIDRO GARCIA, Esq. GARCIA LAW FIRM, RA. 23 The/Harvey Building 224 Datura Street, Suite 900 24 West Palm Beach, Florida 33401 25 Page. 2 1 l-N-D-E-X 2 November^ J2009; 3 MICHAEL REITER 4 DIRECT CROSS REDIRECT RECROSS 5 By Mr. Kuvin 8 352 6 By Mr. Garcia 155 364 7 By Mr: Crittoh 190. 8 9 IO EXHIBITS 11 Marked 12 Plaintiffs ExhibitNo. 1 1_6 13 (Palm.Beach PD Intelligence.Report 11/28/04) Plaintiffs Exhibit No/2 31 14 (Incident.Reports) Plaintiffs Exhibit No. 3 99 15* (LettertoBarry Krischer) Plaintiffs Exhibit Noj4 131 16 (Photographs of.El Brilip Way) •Plaintiff’s Exhibit No. 5 132 17 (Photo of 358 El Brillo Way) Defendant’s Exhibit'No. 6 218: 18 (Subpeona Duces Tecum) Plaintiffs Exhibit No. 7 .356 19 (Money Transfers) Plaintiffs Exhibit No. 8 357 20 (Flight Summary) 21 .Certified Question:: Page 160, Line 10 22 23 24= Letter to John Randolph,.Esq.: 25. Errata-Shects (to be forwarded upon completion) Page 4 1 APPEARING ON BEHALF OF DEFENDANT: 2 ROBERT D. CRITTON. ESQ. BURMAN. CRITTON,EUTT1ER & COLEMAN. LLP. 3 515'North‘Flagler Drive, Suite 400 VVest Palm Beach,- Florida 33401 .4 5 JACK GOLDBERGER,:ESQ. ATTENBURY. GOLDBERGER. RICHARDSON & WEISS, P:A. 6 250 South Australian Avenue, Suite 1400 West Palm Beach'. Florida 33401 7 8 APPEARING ON BEHALF OF WITNESS: 9 JOANNE O'CONNOR, ESQ. JOHN RANDOLPH, ESQ. 10 JONES. FOSTER, JOHNSTON & STUBBS. R:A. 505 South' Flagler Drive, Suite 1100 11 West Palm Beach. Florida 33401 12 13 ALSO PRESENT: JEFFREY EPSTEIN 14 15 VIDEOGRAPHERS:: MICHAEL D. DO^EY EDDIE GUERRERO 16 VISUALEVIDENCE 601 .North pixie Highway, Suite A 17 West Palm'Beacb, Tlorida 33401 18 .. 19 20 21 23 24 25 1. '('Pages 1 to 4) Pleasanton, Greenhill, Meek and Associates 561-833-7811 CA/Aronberg-000792 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY VS. • Page 1 TN T}IE Fl HEE NTH JUDiCiAL cf RCQiT co-Urn IN AND FOR PALMBEACH COUNTY, FLORIDA CASE NO.: 502008CA03 7319 XXXX MB AB Plaintif~ JEFFREY EPSTEIN, Defendant. ----------------'/ V.OLUfyl.E I i 2 ·3 n 15 VIDEO-TAPED DEPOSITIONOF'MlCHAELREITER 16 1 2 3 4 5. 6 T 8 9 A WITNESS TAKEN BYTHE PLAINTIFF DATE: .November23; 2009 TIME: 10:12 a.m. - 7:38p.m. ·1-N,D'E-X November;23,:2009: MICi-ili.Et REITER DIRECT CROSS REDIRECT RECROSS By Mr. Kuvin By-Mr. Garcia S 352 155 364 By'Mr: Crittoi1 I 90. 10 EXHIBITS n Marked 12 Plaintifl's Exhibit No. I 16 13 (1''1lll1°&'1ch PDhitclligcilcc Rcportli/28/04) Plaintifl's fahibit No.'2 31 14 (incident.Reports) Plainiifl's Exhibit No. 3 99 .15 (Letter;to· Barry krischer) Plaintiffs Exhibit No.A • 131 16 (Photographs of.El Brill<> Way) :Plaihtitl's Exhibit No. 5 • 132 n (Phcito of358 El. BriHo \Y,ay) Defendiinis F.xhibit:No. 6 2 is: 'l·B (Subpeona Duces Tecum) Plaintiffs Exliibi(No. i .356 19 (MoneyTransfers) Plaintitl's ExliibifNo: 8 357 20 (Flight Sumiliary) ·21 Certified Qt1csiion:: Page'l60, fine 10 22 23 .2 f Letter'to John Randolrli. Esq., 2 5 Errata'Shecis (to be forwarded uoon comoletfori) Page, 2 18 19 23 24 25 1 2 3 A 5 6 7 1.0 11 12 13 14 15 1,6 17 18 1·9 20 21 n 23 24 25 • Page 3 The deposition of MICHAEL REITER, a witness 'in the abov~,eniitled and_numbered c;iuse was iaken b<lfore.me. Vanessa G. Archer.,Court·Reporter. No\ary:PublicJor.the siit~offi<Jrid:l ~t Llll'ge.at ~92~J>GX Iloule~~- p;1~:Beach Gardens, Florida, on the 23rd day ofNovember,2009, pursuant to Notice Ill said cause·foi ihe;taking of.said deposition.on belialfciftiie Piaintiff. APPEAR]NG·ON,DEHALF \)F PI.:AINTIFl'.13.8.: SPENGER T. KUYIN. ESQ, LEOPOLIFKUVIN, P,A. 2925:J'GA Bo~lcvard, Suitc.200 Palm Beach Gardens, Flon<la .3341 <i .APP,EARJNG Ol'./.1:3.EHALE OF PL,'.\INl;IFFS' JANE I>QF.<; 2~8: AQAM 1:10Jl9WJTZ,.E~Q. MERMELSTEIN & HOROWITZ, P:A. 18205.Discayne Boulevard, Suit,\:2218 i-.1iami, Florida·33 i 60 AP.PEARINGON BEHALFOFPLAINTIEF CA. JACKJTTLL,,ESQ, SEARCY. DENNEY; SCAROLA. BARNHART & SHIPLEY, P,A 2 ! 039 Pcil~ I3e~~h Lak~s Bo~iev;{;d • • • • • • • • ,, • West Palin Deacli, Jiiorida 33409 APPEARING ON BEHALF OF PI:AINTIFF: ISIDRO GAR:CIA. Esq. GARC:JAL,AW FIRlyl; P:A, l'he'.Harvey Building 2240:ituia Street. Suite 900 West Palm Beach, Florida33401 APPEARING ON BEIIALFOF DEFENDANT: ROBERT D. CRITTON, ESQ. Pa.ge 4 BUfu'viAi"I, CRITTON, LUTTIER &COLEMAN. LLP. 515'Norih'.Flagler Drive, Suite 400. \Vest Palm Bea.ch; Florida ')340 I JACK GOLDl3ERGER,:ESQ. ATTENBURY. GOLDBERGER. RICIIARDSON & WEISS, P:A. 250 South A nstralian A venue, Suite 1.400 West P.ahn B.each'. Florida 33401 Af,'.PE~J.UNG 01'/ BEI-IALF OF \VITNE~S, JQANNE Q'CONNQR,ESQ. JOHN RANOOLPH,:ESQ. JONES. FOSTER, JOHNSTON & STUBBS'. P.:A. 505.South·Fiagler Drive, Suite 1100 • Wesi Palm BeachiFlorida -33401 ALSO PRESENT: JEFFREY EPSTEIN VIDEOGilAPHERS:, MiCl-iAEL D. DOWNEY EDDIE GUERRERO VISUAL EVIDENCE §!)I l;,lorth'Dixie Highway, Suije A West Pain] Beacl~. Floiicla 3340.l ·1. (Pages 1 to 4) Pleasanton, Greenhill, Meek and Associates 561-833-7811 CA/Aronberg-000792 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM 1 2 3 4 .5 6. 7 8 9 10 11 12 1-3 14. 15 16: 17 18 19 2 0 21 22 23 24^ 25 Page 53 And at what point did you learn that Mr. Epstein, in fact, did become aware of the investigation? A I think the point that I actually knew that it was, it was reported to meby one ofthe detectives that one ofthe victims had been contacted by a private investigator thatthe department believed was employed by a lawyer of — employed by Mr, Epstein, Q On that topic, at some point did you become aware that Mr. Epstein was actually investigating you? MR. CRITTON: Form. THE WITNESS: Yes. BY MR. KUVIN: Q Tell me about that? A Well I heard through various individuals that one of his lawyers, Mr; Dershowitz, had been contacting private investigators in the area to perform background investigations on me. I know that there was a public records law demand filed by several private investigators on the Town of Palm Beach for my personnel records. And Tactually ran into one of the private investigators very early on - you asked me when I first became aware — I Page 55 1. A No. I 2 Q First time ever? 3 MR. CRITTON: Form. 4 BY MR. KUVIN: 5 Q First time you,can recall it going to this 6 extent? 7 A The only time,lever recall.anyone ever 8 going to this extent. 9 Q How long were you aware there was 1Q surveillance on you personally? 11 A Well, you know, I justtook the approach 12 that I have nothing to hide, and I just lived my 13 life so I tried not to look around every corner. I 14 fe 11 like it was around three months. 15 Q At any time during the investigation, did 16 you become aware that investigators were also 17 sUrveilling and investigating potential victims? 18 A, That had been reported to us by victims. 19 And the lead investigator in the case also felt like 20 he was being surveilled, people were picking up his 21 trash and so on, 22 Q Is that Detective Recarcy? 23 A. Yes. 2 4 Q So there was a time that your officers 2.5 became aware it was being investigated on? Page 54 i 2 3 4 .5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21. 22 23 24 2:5 Q Yeah. A — that basically-toldI me that. I.also — I mean I Saw surveillances number of times, I didn't know precisely who had hired those persons, but 1 mean 1 had,surveillance for a fair1y long period of time. Q There was surveillance you noticed on you? A Yes.- Q Do you know why? A No, no, I don't. It would be an assumption. In general sense, you know, there's an attack on the case and ifthat doesn't work there's an attack on the investigators. I don't know, I don't know. Shouldn't,say that. MR. CRITTON: Form, move to strike. BY MR. KU VIN: Q You were working as a police officer for twenty-eight years and then as a chief — well ■- A And two years prior to that actually. Q Right. During your entire history as a police officer, can you, ever recall someone going to that length? In other words, a suspect conducting an investigation oh you such as the lengths that occurred in this case which include surveillance on you? 1 ■2 .3 4 5 6 7 8 9 10 11 12 1.3 14 15 16: 17 18 1.9 20 21 22 23 24 25 Page 5.6 MR. CRITTON: Form. THE WITNESS: One officer, one detective, BY MR. KUVTN: Q To the extent they were picking up his trash? A Yes, Q Were-you awareof that ever occurring in your career to officers working under you? A I didn't say it never occurred to this degree. Q Got you. A 1 think if you're asking the question do I know of any other law enforcement officers who know as part of their job somebody investigated them and picked up their.trash, not that I can specifically recall. Q Okay. A Other than the police department itself, we’ve had private investigators take trash at the police department itself, we've caught people doing that. Q Obviously at some point Mr. Epstein was tipped off as to the investigation because of the investigators that you becameaware of" Did you ultimately know how he became tipped off? 1.4 (Pages 53 to 56) Pleasanton, Greenhill, Meek and Associates: !>61-833-7 811 CA/Aronberg-000793 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY 1 2 3 4 $ 6. 7 8 9 10 11 12 13 14, 15 16 17 18 19 20 21 22 23 24 25 • Page 53 And atwhat point did you learn that 1. Mr. Epstein, irt fact, did be.come a.ware of the 2 investigation? 3 A I think the point thflt I a;ctually knew 4 that it was, iHvas reported to. me by one of the 5 detectives that on\_: of the victims had bc(;m 6 contacted by a priyatc investigator tha:tthe 7 dcpartmentbelieved was employed by a lawyer of-- 8 ernployeci by'Mc Epstein. 9 Q On that topic, at some poiritdid you io b\,:come a\1/are that Mr. Epstein ,vas actiJally 11 investigating you? • • • 12 MR. CRJTibN: Form. 13 '(HE WITNESS: Yes. 14 l3YMR.kUVIN: is Q Tell me about that? 16 .A Well I heatd through various ii1dividuals 17 that.one of his lawyers, Mr. Dershowitz, had·becn 18 contacting priyate investigators in the area' to 19 perform background investigations on me. I know 20 thatthyre '\Vas a public recprcii(la\V ciemand filed by 2.1 several private investigators on the town of Palm 2 2 Beach for my personnehecords. And I actually ran 2 3 into one of the priyatc: invc~tigators very early 2 4 on -- you asked me when I first became aware -- 2 5 Page 54 1 Q Yeah. 1 2 A -- that basicaliy·told me that. laiso -- 2 3 I mean I saw slirveillance,a number of times, l .3 !l didn't know precisely who had hired those persons, 4 5 but lmeanJ had. st1rvi;:illance fgr c1 fairly lot;g 5 6 period of time. • 6 7 Q There was surveillance yoµ noticed 'on yot1? 7 8 A Yes, • 8 9 Q Do you know why? 9 10 A No, np; I do11't It woµld be;an 10 l'i assµmption. In generalsense, you know, there's an 11 12 attack on the case ancl if that cloesn't work there's 12 13 art attack on the investigators, I don't know. I l3 14 don't know. Shouldn;tsay that. 14 15 MR. CRITTON: form, rnove to strike. 15 16 BY MR. KUVIN: 16 17 Q You were working as a police officer for 17 18 twerity-eigtit years and then as a chief,- well -0 1 s 19 A And two years p1ior to that actually. 1_9 2 O Q Right. P\lring your entire histmy as a ,2 O 21. police officer, can you, ever recall someone guirtg to 21 2 2 that length? In qther words, a suspect conclucting 22 2 3 ah investigation on you such. as the :lengths that 2 3 2 4 occUITed in this case which.include surveiliance on 2 4 25 vou? 25 I i Page 55 , ! A N.o. 1 Q First time eve~? MR. dRJTTON: Form. BYMRKlJYJN, Q Ffrsttimc you;can recall it going to this extynt? A The only timeJ ever re·call anyone ever going to this extent. •• I Q How long wereyouawaretherewas ·- 1 surveillance. on you personally? A Well, you know, I just.took the approach that I have nothing to hide; and I jUst lived my l lifc:so I tri'ed not to look around every corner. I I felt hke it was around three months. • Q At any time dming the investigation, did you become aware that i]lvestigc1tors were also sutveilling and investigating potential victims? A Thathad been reported to us by victims. And th~ ]~ad investigaJor:inthe case al~o'felt like., j '.he was ben1g surve11led, people were p1ckmg up his I trash :::1nq so on. Q is that Detective Rec·arey? A Yes. Q So there was a time that your .officers became aware it was being investigated on? Page 5.6 MR. CRITTON: Forrn. THE WITNESS: One officer, one detective. BY MR. KUVIN: Q To the extent they were picking up his trash? A Yes. Q Were·yuu aware 0of that ever occurring in yoµr career to 9fficers working under ycm? • A {didn't say it never occurred to this degree. Q (iutyot( A Ttfunk 1fyou're asking the question do I I kn_ow of anyotherJawen(orcefilent officers who know as part oftheir job somebody investigated them and i picked up their.trash, not thatf can specifically r.ecall. Q 'Okay. A Qther thart jhe pqljc:e clepartment itselt: we've had.private investigators take trash atthe police department itself, \\'.e've caught people doing Th~ . . .. Q Obviously at some point Mr. Epstein was tipped. Q.ff as: tQ 01(: inyestigc1tion beca_use Qfthe, investigators:that you became,aware of: Did you ultimately know how he became tipped.off? • 14 (Pages 53 to 56) Pieasantoh, G:te.ehhill, Meek arid Associa.tes 561-833~7811 CA/ Aronberg-000793 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM 1. 2 ■3 4 5 6 7 8 9 10 11 12 1.3 14 15 16' 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 8: 9 10 11, 12 13 14. 15 16 17 18 1? 20 '21 22 23 2 4. 25 Page 69 Q How did you keep that information when you were there? A It was a letter that 1 received from the U.S, Attorney, Q Hang on. back up, you misunderstood my question. I'm talking about the state, your investigation, In other words, what did you match the forty some odd victims in the U.S. Attorney's letter with in your 1ist? I'm looking; for your list. A The incident reports. Q Okay. How many incident reports did you all generate? A I don't recall if the latter victim, or victims, generated a new case number or if they're included in this. It seems like it probably generated a new case number but 1 can't say for sure. But Detective; Recarey would know. Q Okay. All right. Would all of the potential victims,that wcrc being investigated by your department prior to let's say July of2006, have been, listed in this incident report we've marked as Exhibit?? Were,there any additional, incident reports? MR. GRITTON: Form. Page 70 THE WITNESS:, For the time period that that covers — BYMR. KUVIN: Q Yeah. For the time period of January 27 of '05 through the lastpage of this Exhibit .2;is July 12of '06. A I think.there was only one report. Q Okay. A When you mention victims, and that's sort of a subjective word, there were individuals that we; felt their activity had constituted a crime but,they were not cooperative. Q Right A You know, they're not.victims but-they're in here and the numbers change ifyou want to add all them in. Q Okay. And what I'm just trying to find is, is in this particular report we've;marked as Exhibit 2, it has, if I recall, seventeen victims listed and it goes through the date of July of '06 . Do you know how many girls approached the department later on, total number? A Definitely one and possibly more, I'm not, sure exactly. But once I realized that they had been considered by the federal investigation, 1 knew 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 .3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 1.9 -20 21 22 23 24 25 1 Page 71 we had no further involvement. So-it wasn't something that I would be completely informed about. Q Okay. At any point did someone, anyone, come to you and either formally or informally ask you to back off the investigation, stop the investigation, or alter your investigation in any way? A I had individuals suggest that the department's approach to the investigation and my’ referral of the investigation to the FBI was more horse power than the investigation deserved., And I had other individuals suggest that -- yeah, the term back off probably fits, yes. Q Who? A I think that Barry Krischer would be included in that description. Q Who else? A 1 had people in the community in Palm Beach that either made comments directly to me or to others who relayed them to me that.I didn't need to take the tact in the investigation that we did, which is completely investigate it arid then refer it to the FBI after the state case was.resolved. Q Dp you remember any of those people that mentioned iteither-to you directly or through your Page 72 department? A Wefl.it wouldn't be, I think, appropriate for me to list individuals.that I don't know first-hand said that. I had many people relate conversations of anotheron the cocktail party circuit that suggested that we approach this in a way that wasn't necessary. I had one individual who actually came to see me a couple of times about this. ,Q Who was that? A Jerry GdldSmith. Q Okay. What did he say? A, He said that this wasn't necessary, this was a case that really was very minor. The victims had.lifestyles that don't make them — shouldn't make them-believable to the police department And he said that! shouldn't haveireferred.it to the EBI and Palm Beach solves its own problems, why did I do that, why am I after.Jeffrey Epstein. A couple of occasions that was the general, topic of the discussion. Q Did you know who Mr. Goldsmith was? A Yes. 1 know them all. Q Lives on the island? A As far as I know, yes. 18 (Pages; 69 to 72.) Pleasanton, Greenhill, Meek and Associates- 561-833-7811 CA/Aronberg-000794 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY 1 2 '~ 4 5 6. 7 8 9 10 n 12 13 14 15 16' 17 18 19 20 21 22 23 2ll 25 • Page 69 Q How did you keep that infonnation when you 1 Wer~ there? • 2 A It was a letter that I received from the 3 U.S. Atto_rney. 4 Q Hang on, backup, youniisunderstood my 5 question. I'm talk:ing:about the state, your 6 in\i(;stigaiion, In oihcr Word~, Whal did you match 7 the forty some odd victims in the U.S. Attorney's 8 letter with in your'list.? l'.mloolcing fiJr-your· 9 list. id A The incident reports. 11 Q Okay, How many ihcident reports did you 12 all,generate? 1:3 A 1. do.n't recall if the latter victim, or 14 victims, generated a new case humbcr,or if they're 15 inch,1de,d in this, It seems like j(probably 16 generated a, new: case ,number b_ut l can!t say for 17 sure. But. Detective:Recarey would know. 18 Q Okay. All right. Would all of the 19 potential victims, thatwcre bdng investigated by 2 0 you.r departme,nt pri9r to le,t's say July of 2006, 21 have beeo listed in t)lis jocident reportWe\,--e 22 marked as Exhibit 2? Were, there any additional 2 3 incide11t rcpor~? 2 4 MR. GRITTON: Form. 25 Page 70 1 THE W-ITN_ES_S:. I'ptthe:tiip_e period that i 2 that covers -- 2 3 BY MR. KUVTN: .3 4 Q Yeah. for,the,time p_eriod oOanuary 27 4 5 of'05 through the lastpage of this Exhibit2js 5 6 July 12 of '06. 6 7 A I think.there was only-one report. 7 8. Q Okay. 8 9 A When you mention vic_tims, and that's s.ort 9 10 of a subjective word, there were.individuals that:we. 10 it (elt their activity had constituted a crime buttlfr)' 11 12 were no.t cooperative. 12 13 Q Right l3 14. A You:)mow, they'renot.victims,but-they're 14 15 inhere and the numbers.change·if.youwanUo add 15 i 6 _aU them in. 1 6 1 7 Q Okay. And WhatTm just trying to find 17 18 is, is iil this partiq1lar report \Ve've:marked a·s 18 19 Exhibit 2, it has, if I recall, seventeen victims 19 20 listed and it goes through the date ofJuly of'06. ,20 21 -Do you know how many girls approached ihe dcpartmel1 21 2 2 later on, total'number? 2 2 2 3 A Dc;finitt:ly one and possibly more; I'm not 2 3 2 4 sure exactly. :But once I r~alized that they.had 2 4 2 5 been considered by the federal investigation, I knew 2 5 • Page 71 we had no further involvement. 'So-1t wasn't sorneti:tjl)g thatr wqulcj be corriplete)y informeq i;tbout. Q: Okay. At any point did someone, anyone, come:to yoµ and e.ithel' formally or•infcmnally ask ·yoif to back off the investigation, stop the .investigation, or alter_your investigation in any w_ay? A I had individual's suggest thatthe gepartment's approac;h to the investigation and my· referral o'f the investigation to the,FBI was more horse power than the investigation.deserved., And T had other individuals suggest that a-·yeah; the term back off probably fits, yes, Q· Who? A, I thinkthat Barry Krischer would.'be :included in that description. Q Who else? A 1 had people in the community in Palm Beach that either_ made cqrmnenh, ·dire,ctly fo .me or to others who relayed them tome:thad didn't need to take the tact in the investigation that we did, which is coinpletely investigate it artd theh re(er i~ to the FBI after the state case was:resolved. .Q· I)o ycmre111eniber any oftli.CJ~e peopl~ tbat mentioned iteither·to you directly or through your Page 72 d~p~rtinent? A Welbt wouldn't be, I think, appropriate for me to list individuals:that I dori'fknow first 0hand said that. I had' many:people relate conversations of an:other:on the cocktail party ,cir¢uit that suggested that we approach this fo a. way that wasn't necessary. r had one:ind1vidual who actually came to see me a couple. of times about. this. • Q Who-was that? A Jerry GoldSmith. Q ·Okay. What dici he say? A He sajq:that this wa~n't.nece.ssary, this was a case that really was very minor. The victims hadJife~tyles that tion'tmake them -- ~hqµl(Jn't make them:believabl_e to the police dep~rtrrtent And he said thatT shouldn't have-~eforred.it to the EBI and Palm Bea,cn solves its own ptoblenis;, wny did I do that, why am I after.Jeffrey Epstein. A couple of occasions thatwa~ the,generar topic of the oiscussion, • • Q ·oid you know who Mr. Goldsmith was? A Ye~- lknqwtliemaH. Q Lives on the 1sland? A As far as'Iknow, yes. 18 (Pages 69 to 72) Pieasanton, Greenhi11,- M'eek and Associates· 5:6:l-8.3<3-7811 CA/Aronberg-000794 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Page 9.3 1 MR. CR1TTON: Form, 2 THE WITNESS: That's not my role as Police 3 Ghief. 4 BY MR. KUVIN: 5 Q Bow did you ultimately learn what was 6. going to happen with respect to the federal 7 investigation: who told you that for the first time? 8 A Well it changed so many different times. 9 The final outcome when it had been agreed upon, 10 Assistant US. Attorney Marie Villafana shared with 11 . me in a general sense that there was a 12 nonrprosecution agreement, and told me what 13 Mr. Epstein would plea to in state court, and just 14 in a very general sense, 15 Q Whatwere your thoughts about what 16 oceurred with respeefto thefederal investigation? 17 MR. CR1TTON: Form. 18 BY MR. KUVIN: 19 Q In other words, did you respond to her and 20 tell her. what you were thinking? 21 MR, CRITTON: Form. 22 THE WITNESS: 1 had been telling her what 2 3 my thoughts were about the investigation and 24 the prosecution all along: I don't think when. 2-5 she told me what was going to happen -- did 1 Page 9.5 1 that you should not answer that question. 2 BY MR, KUVIN: 3 Q I certainly don't think once your 4 investigation is closed that there's any problem 5 with havinglhc discussion if it's.a closed 6 investigation, which it is now. 7 Well let me ask that. Is your 8 investigation closed with respect to Mr. Epstein? 9 A I'm retired. So as far as I know when I 10 left it was a closed investigation, yes. 11 Q Okay. So when you left, the investigation 12 with respect to. Mr. Epstein was closed? 13 A Yes. Ldonf know ifthe federal | 14 investigation is closed, 15 Q Fair enough. 16 You didn't though learn of any new 17 investigation with respeetto the Town ofPalm 18 Beach's duties after you left,, did you? 19 A No. ' ' | 2 0 Q So as far as you know, as you sit here 21 today, the Town of Palm Beach's investigation is 2 2 over as far as you know? 23 A Yes. 2 4 MR. KUVIN: Then atthat point, once the 25 investigation's :c!osed, Tcertainly don't see Page 94 1 make a comment about it? 2 BY MR. KU VIN: 3 Q Yes. 4 A If that's what your question is, yes. All 5 along my concern was that he would be classified as 6 a sexual offender and all of the provisions that 7 travel along with that so there wouldn't be 8 opportunity, or be far less opportunity, for 9 additional victims to fake place. And I think ! 10 shared with her some sense of relief that that was a 11 part ofthe plea. Beyond that, there really wasn't 12 a need to say anything else, 13 Q Did you discuss with het the fact that the 14 feds were not going to prosecute; in other words, 15 the federal government weren't going to prosecute 16 the case? 17 A You know, I guess I have to sort of pose 18 this question that this is part of the, I suppose, 19 the work product of the U.S. Attorney's Office. Is 20 this the kind of thing that 1 should be talking 21 about? I mean is this privileged from the federal 2 2 end forme to talk about the conversations Lhad 23 with the United States Attorney? 2 4 MR. RANDOLPH: I think if you have any 2.5 discomfort at all in regard to whether it is, Page 96 1 that there's any privilege with respect to 2 those communications that he may have had on a 3 closed investigation. 4 MR. RANDOLPH:, He's not stating a concern 5 in regard to the closed investigation of the 6 town, he's stating his concern in regard to a 7 federal investigation and stated he does not 8 knowwhetherthere'sany ongoing investigation 9 in that regard, I believe, and he has concerns 10 revealing that, 11 BY MR. KUVIN: 12 Q Well with respect, to your communications: 13 with the U S..Attorney's Office regarding your now 14 closed Investigation, do you recall discussing with 15 them the non-prosecution agreement, let's juststart 1'6 there? Generally, did.you discuss that with.them? 17 A Yes, I discussed that with them. And it's 18 different iterations as it went along. Theyshared 19 some portion ofthe information. I still today have 20 not seen the non-prosecution agreement but they 21 shared some of the provisions with me. 22 Q Okay. Based upon what was shared with 23 you, did you at any point discuss your 24 dissatisfaction with that.agreement;in any regard? 25 A- Yes. 24 (Pages 93 to 96.) Pleasanton, Greenhill, Meek arid Associates 561-833-7811 CA/Aronberg-000795 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • Page 93 1 MR. CRITTON: Form'. 1 2 THE WITNESS: That'.s notirty role as Police 2 3 Ghicf. 3 4 BY MR. KUVJN: 4 5 Q How did' you ultimately learn what was 5 6. gQing to happen with respect to th~ fe(Jeral 6 7 investigation; who told you that for tlie first tirne? 7 8 A Well it changed so many different times. 8 9 The finc1l outcome when it.had been c1greed upon, 9 Hi Assistant u:s. AttomeyMarie Villafana shared with 10 11. me in a. general s~nse that tht,:re was a 11 12 non,prosecution agreement:and told me what 12 l3 Mr. Epstein would plea to 111 state.court, and just 13 14 "in a very general sense, 14 15 Q 'What.were your thoughts about what 15 16 occµned with nespecfto the ff;(ieral investigation? 16 17 MR. CRITTON: Form. 17 18 BYMR. KUVIN: 18 19 Q In· other wor:ds, dig you respond to her and 19 20 tell her what you were thinking? 2 0 2.1 MR. CRITTQN: For:nt 21 2 2 THEWITNESS: I had been telhiig hei" wliat 2:2 2 3 my thoughts were about the investigation and 23 2/J ·th~ prosl!cution allalqng: I cion'tthirikwh_cn. 2 4 25 she told mc,what was going to happen -- dtd I 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 2i 22 23 24 2.5 Page 94 n1akc a comine1it aboutit? i 'BY MR. KUVIN: 2 Q Yes, 3 .A If that's what-your qucstion..is., yes. All 4 ~lqng my c.:oncern Wq~ thafh,e would be classified.as. 5 a sexua)offendet and all of-the provisions that 6 travel along with that so there W()lllcln't be 7 qpportuhity, or·.be fat less oppofhirtjty, for 8 additional victims to fake place: And l thinkJ 9 sh~red with hcrsqme sense· of relief that thiitw~s a 10 part of the pica. Beyond that, there really wasn;t i 1 a need to say anything else. 12 Q :Did:you discuss with her the facnhanhe 13 feds were not going to prosecute; in other words, 14 the federal goyernment weren't going to pros.ecute 15 ~c~~ • - ~ A You know, T guess I have to sort 9f:pose 1 7 this question that this is part of the, 1 suppose, 18 the work product of the U:S.Attomey's·Office . .Is 19 this the ki,nc!.ofthing'that I should bda1king 20 about? I mcanis this privileged from the fcdcrnl 2 i end for·me to talk abo1}t the c9nversati9ns Ihacl. 22 with the United States Attorney? 23 MR. RANDOLPH: lthink 1.fyou have any 24 discomfort at all in regard to whether it is 25 • Page 95 that you should not answer that qµestfon. BYMltKUVlN: Q I certainly don't think once your irty_cstigafion is clo_scd \ha.tthc:tcls, any proljlcm ·with having:thc discussion ·if it;s a closed investigation, which it is now. • • Well let me ask that. Is your ·invcstigafron closed with respect to Mr. :Epstein? A I'm retired. So as far as I know when I left it was a closed investigation, yes. Q Okay. So whe_l1 yo_u, left, tl!ei11ve~tig3-tion witlircSpcct to Mr. Epstein was.closed? A Yes. Ldon'.t know if the federal investigation 'is closed .. Q Fair enough. You didn'.t though learn of any new investigation with respect to the Town of Palm Beach's duties after yo~ -left,, did ·you? A No. • • Q So as far as you know, as you sit here toc:lay, the T9wn ofT'?l.in Bf;ach's investigation i's ovei::as far as you ki10.w? A Yes. MR. KUVJN: 111en;at .tliat point, once the invcstlgation;s :closed, I :certainly don't sec Page 96 that there's any priviiegewith respect to those communications that'be may have bad on a· ' closed investigation. MR. RANDOLPH:. He's not statinga·concern in regiinj to ~he closecl _in.Y~stig*on of th_~ 'town, he's stating his cbnc.erri in regard to a federal investigation and stated 'he does not know·w,hcthcr .there's tiny ongoing invcstigalioil 'in that regard, 1 believe, and he has conc~rns revealing th~L BY MR. KWIN: Q Well.with rcspcct:io your communications with the U'.S. Attome)i!s Office regarding your now ciosed:investigation, do you recall discussing with them the·nqnapr,osecutio.n. ~grce111cnt, let's Ju.sf; s'ta_rt there.? Gcncra'lly; did you-discuss that with them? A Yes, I d,iscµsscc;lthat ,vith.thcm. And it's .different iterations as ihvertr along. They-shared some portion of:tbe information. I still today have 1 n.ot ,5een t]:ie ripn-prosecution agreement buJ; th~y j :shared.some of the provisions with me. ::J Q Okay. Based UP.On what was sharecj \Vith you,. did you at any point discuss your dissatisfaction with ·thatagreemenbn any regard? A Yes. 24 (Pages 93 to 96J P1ea.santoh, Greenhill, Meek and Associates 561-833-7811 CA/ Aronberg-000795 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Page 97 1 Q Why? 2 A Weil l had been told by the U.S. 3 Attorney's.Office that typically these kinds of 4 . cases with one victim would end rip in a ten-year 5 sentence. And they told me early on that they had, 6 I guess in earlier iterations ofagreement, tried to 7 get some sort of a fund set up which I understand 8 there are provisions for in federal law to 9 compensafethc victims. And i thinkil,remember 10 asking that when they told me that the agreement had 11 been signed, and I think it was changed a time or 12 two and they told me that that was not a part of it. 13 Because I always felt that this casc, 14 . it was all. about the.victim, that's reason to do 15 this. And I did - I think they told me that this 16 fund had not been a part of the final version and I 17 told them that I was disappointed in that. But they 18 didn't really give me the details of it, they gave 19 me an.ovcrallcxplanationand they said it was going; 20 to be sealed. 21 And i understand it's been unsealed. 2 2 but 1 haven't — I haven't read it. Along the Way 1 23 gave general comment;when they would inform me abou 2 4 parts of if. Because they asked for;my input, I 2 5 would give them general Comment about the parts of Page 98 1 it that were important to me. And the part that was 2 important to me is the classification as a sexual 3 offender. 4 Q Okay. Did.you, at any time, learn why 5 they entered into a non-prosecution agreement as 6 opposed to prosecuting the forty some odd cases? 7 MR. CRITTON: Form, 8 THE WITNESS: No. 9 BY MR. KUVIN: 10 Q Never gave you an'explanation on that? 11 A No. 12 Q You know the name Ken Starr? 13 A Yes, 14 Q Did you learn.that.name with respect to 15 this i nvestigation at all? 16 A From the news media. Arid I think maybe 17 the U.S. Attorney's Office:mentioned to me that he 18 either represents or did represent M r. Ejpsteih. 19 Q Do you know what discussions were had with 2 0 Ken Starr regarding the federal investigation at 21 all; did you ever become aware of that? 22 A No. 23 Q Do you know what, influence. Mr. Stam may 24 'have exerted on the U.S. Attorney's;Office and the 2 5 DC Office at all regarding this investigation, if Page 9.9 1 -any? ; 2 A No. i 3 Q At some point you sent a letter to State 4 Attorney Barry Krischer. Let me show you what we'll 5 mark as Exhibit 3. Let me give you a chance to just 6 read through this letter again toTelp refresh your 7 recollection. 8 A I've read it: 9 Q- At this point, in May of 2006, I'm 10 assuming based on what you told us before, that you 11 had had some conversations with Barry Krischer 12 directly at this point by phone, correct, prior to 13 this letter? 14 A. I had conversations in person and by 15 phone, 16 Q Okay. But nonetheless in May,: May 1, 17 2006, you felt the need to write this letter: is 18 that correct? 19 A. Yes. 20 Q Can you tell us why? 21 A Well I felt the handling and just 22 continued to feel that the way the State Attorney's 23 Office, handled this case was;extremely unusual. I: 2 4 felt that Mr. Krischer's — I knew, that Mr. Krischer 25 was making decisions about this case. ,1 felt that Page 100. 1 his objactivitywas lacking, and I felt that the 2 appropriate way after reading the statute that .3 governed the assignment of cases to other circuits, 4 I felt;that his action met-the; standard. f used 5 some of the words from the statute in here. Andi 6 attempted to call him and he wouldn'treturn my 7 phone calls. 8 The detective attempted to contact — 9 his contact; in the State Attorney's Office, Lanna 10 Belohlavek, however you pronounce that, I apologize 11 if I have it wrong, and she wouldn't return his 12 calls. Sol wrote the letter in hope that he.would 13 think about his; situation and realize that his 14 objectivity was insufficient to prosecute the case: 15 and ask the governor to appoint someone else. And I 16 felt like, that was necessary for a fair prosecution 17 of our case that we submitted to him. 18 Q Could you tell us. explain to us, Why you. 19 felt that his objectivity may be lacking in regards 20 to this prosecution? 21 MR. CRITTON: Form. 22 BY MR. KU VIN: 23 Q In other words, what evidence did you see 2 4 here uncover that you felt made.it potentially 25 non-objective? 25 (Pages 97 to 100.) Pleasanton, Greenhill,: Meek and Associates 501-833-/811 CA/Aronberg-000796 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • Page 97 1 Q Why? 1 2 A WellThad·been told by the U.S. 2 3 Attomey's:Qffice that:typicallythese kinds of 3 4 ·cases with one victim would end upin a ten~year 4 5 sentence. And they-told me early.on thi.it they had; 5 6 I guess in earlier iterations of:agrccmcnt, tried to 6 7 .get some $ort ofa fund set'upwhich I understancl 7 8 there an, provis'ions for in federa_l law to 8 9 compensafo·thcvictims. Andi think'.l.remcmbcr 9 i b askiµg that \.vb:cnthcy tole! me; that the agrccmcnrhad. 10 11 been signed, and I think ihvas changed a time .or 11 12 t\vo and.they told me that that \\;'as not a part of it 12 13 Because l always folt-thatthis,c;ise, 1 J 14 it was all.about the.victim, that's reason to do 14 :Cs this, And f did -d tiliiik they told me thaftljis 15 I 6 fund had not been a.part of the final version and I 16 1 7 told them i:hat I was clisappointe,d in that Bµt they 17 l? didn't really give me the details of it, they gave_ 18 19 me an ovcralLcxplanation and they said ii was ,going 19 20 to'be sealed. 20 21 And Lunderstand it's been unsealed. 21 22 hut I haven't -- I hayeil't read.it. Along the\vay I 22 2 3 gave general commcnt·whcn _they would inform me abou 2 3 2 4 parts of it. :Because they asked for my input, I 2 4 2 5 would give them geheta'l comment about the parts of 25 Page 98 1. it that ''"'eteimpotta:nTfome, And.the_parrthatwas i 2 important to me is the classification as a:sexual 2 3 offender. 3. 4 Q Okay. Did.you, at any time,learn why 4 5 they entered into anon-prqsec:µtion agreement as 5 E? opposed to prosecuting _the t orty some odd cases? 6 7 MR. CRITTON: Form. 7 8 THE WITNESS, No. 8 9 BY MR... KUVIN: 9 10 Q Never,gavt:; you an·explanation on.th.at? 10 1i A No. 11 12 Q You know thc-nfillle Ken Starr?· 12 13 A Yes. 13 14 Q Did you fearnthatname with respect to 14 15 thts jnv~stigatio11,at alJ? 15 J 6 A From the. hews media. Atid lthink maybe 16 17 the U;S. Attorney's Office,mentioned tome thathe 1 7 1s either represents or did represent.Mr. Epstein. 18 19 Q Db you 'know what discussions were bad with 19 2 0 Ken Starr rega.rding the federal investigati.on a.t 2 0 21 all; didyou.evefbecome aware-ofthat? 21 22 A No. 22 23 Q Do you kriciw whatinfluence. Mrc Starr may 23 2 4 ·have exerted on the U:S. Attorney's: Office and the 2·4 2 5 DC Office at all regarding this investigation, if 2 5 • Page 9.9 I any? 1 A No. i Q· At some point you sent 3' letter to State Att9rneyBan-y Krisch~r. Let me show yoµ whatw~:ll I mark as Exhibit 3. Let 1rte giv'e xou a chance to just read through this letter again to,help refresh your teciJllection. A tve read it: Q· Atthis point, in.May of2006,I'm assli1rting based on wharyoli told us .beforei that you had had some conversations with Barry Krischer directly at this point by phone, correct, prior tO' I. this letter? •• • • • . A. I had conyersations in person and by phone. Q. Okay. But nonetheless in May, May l, 20Q(i, you: feltthe need to write this letter; is that correct? I A 'Yes, l Q Can you:tell us why? 1 1 A Well I felt the handling·andjust ·con:tin.µ(:clto feel th~nlie way the State Attorney's Office. handled this case was: extremely unusual. .I t~lt that Mr. Krischer's --1 kl}_!!w that Mr. Kli~9_her was making dedsions abouMhis case . .I felt that Page 100 his objectivitywas lackihg,,arid I feltthaHhe appropriate way afterreading the·statute that goVem:ed ti1e, assigrunent of cases to 0th.er circuits, I feltthat his action meHhe, standard. I used ·some of the \YQrds from· the statµte ih here. And.I atteinpted to ca]J hint and he wouldn't.return my phone .calls. The detective atterhj:Jted to contact -- his contact in the State Attorney's Office, Lanna Belohlavek, however you pronounce,that, I apologize ifrhave itwrohg, a'nd she wouldn't.return hii calls. So I wrote the lefter in hope .that he would thipk c1boiit hii;, situation and realize that his objectivity was insufficient to prosecute the case ·1 and askthe governor to appoint' someone els~. And I felt like. that~was·necessary for·a fair prosecution of our.case that we submitted to him. j Q Could you tell us, explain tp us, why you t felt that his objectivity may be lacking in regards _i 1 to this prosec_ution? j MR. CRITTON: Form. BYMR.KUVIN: Q lh oth:etwords, what evidehct:: clicl you see 'here uncover that you· felt made .It potentiaHy non-objective? I 25 (Pages 97 to 100) P1easanton, G:teenhill,c Meek and Associates 561-833~7811 CA/ Aronberg-000796 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Page 101 P.age 1.03 1 2 3 4 .5 6 7 8 9 10 11, 12 13 14. 15 16; 17 18 19 20 21 22 23 2 4 2 5 1 2 3 4 5 6 7 8 9 10 11. 12 13 14 15 16 17 18 19 20 21. 22 23 24 2.5 MR. GRITTON: Form. THE WITNESS: Well, early on I had - When I first told him about the case and I realized that it was a serious case, there were multiple victims, that,the suspect was very well known, I told him about if, And we were — it was in person, I talked to him after a meeting that he and I were both involved in. And I had known him to be a victim advocate and to protect the rights of children.. Well I know that he even wrote a portion of the statute that addresses those issues. And when I told him about it originally he said lefs go for it, this is an adult male in his fifties, who's had sexual contact with children ofthe ages of the victims. He said this is somebody who we have: to stop,? And whatever we need, he said, in the State Attorney's Office, we have a unit that's equipped to investigate and prosecute these kinds of cases. I think,he probably mentioned Lanna's name to me and anything that you need and, you know, this is basically a case that needs to be prosecuted. Andi didn't have too many facts early on when ! talked with him, but I knew that there Page 102 Were multiple victims and to our detectives they were believable. So when time went on and Mr. Epstein became aware of the investigation and his lawyers contacted the State:Attorney's Office’ they told me that. And from that point on, and 1 believe it was Mr. Dershowitz initially, the tone and tenor of the discussions ofthis case With Mr. Krischer changed completely. One point he suggested that we write him a notice to appear which would be for a misdemeanor. He just completely changed from not.only our first conversation about this and he didn't know the name;Jeffrey Epstein, till:when he had been informed on Mr. Epstein's reputation and his wealth, and Ijustthought that very unusual. I feel like I know him or knew him very well, the State Attorney, and I just felt like he:could not objectively make decisions about this case; that is why 1 wrote it. BY MR. KUVIN: Q Was there anything that you learned through discussions with him that, led you to believe maybe his objectivity had been altered in some regards: in other words, anything he told you ! 1 ' 2 3 , 4 5 6 . 7 8 9 10 11 12 13 14 15 16 : 17 1.8 19 20 21 22 . 23 24 ' 25 •directly? | MR. CRITTON: Form. THE “WITNESS: He told me that he had conversations with Mr. Dershowitz: I know Roy Black. At least the news media reporter was involved in this and I thirikthat he said that he had a conversation with him. I think Roy Black,had another case with that circuit around the same time and maybe even other lawyers that represented Mr. Epstein, and they were obviously discussing the case. And he basically told me that he looked at Facebook pages of some of the victims and that he fell like they were incredible. And I have never felt like prosecutions, evidence should be weighed outside of the judicial process. I just don't — we wouldn't cover our ears and eyes when a person under investigation's: lawyer would bring forward exculpatoiy evidence, but on the otherhand we're not the weigher of fact in these things. We reach the standard ofprobable cause ,and beyond, and that's when a judge, or inthis: particular case a State Attorney, should,make those decisions. ’ 1 2 3 .4 . 5 6 7 8 9. 10 11 12 13 ; 14 15 16 17 18 19 20 21 2.2 23 24 25 Page 1,04 Arid he had been meeting with them without the presence of.our investigators. Fdon't mean he personally but at least — probably he personally butdefinitely members ofhis office, and he hadn't been sharing that information with us. He hadn't, you know— he characterized it with me but he didn't show us the things, at leastnot exhaustively,, that had been given to him by Mr. Epstein's attorneys. I just felt like that was wrong. Those are the reasons. BY MR. KUVIN: Q Have we exhausted the reasons why you felt that this case,, at least you put in your letter, was the handling of this case was highly unusual? Was there anything else that;you felt was highly unusual.regarding the investigation? A Well the Dahlia Weiss being involved in this case with her husband as a lawyer for — I'm not saying that anything happened there, but there's certainly an appearance of impropriety. I felt.like that alone should have been reason enough. First of all for her to be disqualified as soon as she became aware that a law firm,that — not disqualified but removed from the case as soOn, as she became aware 26 (Pages 101 to 104) Pleasanton., Greenhill,- Meek arid Associates: 56'1-833-7811 ; CA/Aronberg-000797 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY 1 2 3 4 $ 6 7 8 9 lb 11 12 )_3 14, J,5 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 i6 17 l8 19 20 21. 22 23 24 2.5 • Page 101 MR. CRITTON: Form. 1 THE WITNE~)S·: Well, early onrhad ""when. 2 T firsMoid him aboutthe case arid I realized 3 that it wa:., ;i s~rim1s case, th~re were rn.µHiple 4 victims, that the suspect was Vefy well kno:Wn, 5 I told him about if. Anci }Ve were -- it was in 6 person, I talked to ,him after a meeting that he 7 andlwere both involved in. And I had known 8 him to be a victim advocate 'and to protect tl:te 9 rights of children .. Well I know that he even i Q wrote a portion of the stah}te that addresi?eS n those'issues. And when I told him about it 12 originally he said let's go for·it, this is .an 13 adult,male in his fifties who's ha.d 1:,exual 14 contact with children ot'the ages of the 1 !:i victims. He said this is somebociy who y.,e have 16 to stop. And whatever· we need, J-ie said, .iri the 1 7 State Attorney's Office, we have a unitthat's 18 equipped fo inyei?tigate and prosecute these 1.9 kinds of cases. I think,he probably mentioned 2 0 Lanna's name to me and anything that y9u need 21 and, you know, this is basically a case that 22 needs to be prosecuted. • 2 3 ADd I dicin't hav.c too many facts early on 2 4 whenJ talked with him, but I knew that there 2 5 Page 102 were rimltiple victims and to our detectives :i they were believabie, So whentimewent on and 2 Mr. Epstein became aware of the investigation 3 and his lawyers contacted the State·Attorney's .4 Offic;e; they told me that 5 Andfrom·that point on, andlbelieveit 6 was Mr. Dershowitz initially, the tone and 7 tenor ohbc discussions of this case with 8 Mr. Krischer changed completely. One point he 9 suggested that we write hi.ma notice to appear 10 which would be for a. misdemeanor. He just 11 completely changed fromnotorily ourfirs,t 12 convetsatioh abciut this and he didn't kno,v the 13 name·Jeffrey Epstein, till when he had been 1-4 informed on.Mr. Epstein's reputation a]1d his 15 wealth, and! just thought that very unusual. i6 I feel I ike Tknow him or knew him very 1 7 well, the State A ttomey, and I just felt like rs he could not objectively make decisions about 1 Q this case; thafis why I wrote it. 2 0 BY MR. KUVIN: 21 Q Was there anything·thatyou learned 22 throligh discussions with him that led you· to believe 2 3 maybe his objectivity had been .aitered in some 2 4 regards; in other words anything hdold you 2 5 I ' el I directly? 1 MR..CRJTTON, forth. Page 1.03 THE \vITNE.SS: He told'me that he had. . c9nyernµtioµs witn. Mr: Dersh?witz: l,kpow Roy j Blade At.least thenews:media tepoi1erwas l involved in this an1 I thi~:t~atht:: s~id that I he hadaconvetsahon w1tb him. J thnikRoy I Black,had_another case with that_ circuit around ! the sa.me time and.maybe even othe1Jawyers that represented Mr. Epstein, andtheywere opvioµsly <;liscu.ssing the case. And he basically·told me that he looked at Facebook pages of some of the victims and :that he felt lik,ethey were incredible. Andl.have never folt like prosecutions; evidence should be weighed outside of the judicial process. Jjustdon'J-- we wouldn't: cover our ears and eyes when a person under •investigation's la'YJer would bring forward exculpatory evidence, but on the other hand we'.re not the weighic.:r 9f fa<;t in these things, We reach the standai'd of probable cause.arid 'beyond, and that's when ajudg~, or in.this pmiicular case a State Attorney; shoulc,tmai<e those decfaions. Page 1.04 And he had been meeting with them without the presence .of.our investigators. I don't mean.he personally but at least-- probably he pcrsonalfy butdefinitely members of his l information with·us. , office, a11d he );rndn't bic.:en sharing that , 1 He hadn't, you know-- he characterized it with me but he didn't show us the things, at least·not exhaustively;, that had been givento him by l'vk Epstein'.s attorneys. l jusJ felt likethatwas' wrong. Those arc the reasons. BYMR.KlJVIN: Q Have we exhausted the•reasons why you felt thatthis case,, a ti east you put in your letter, was t.h~ handling ofth,is cas,ewas higi1Jy unusua.l? l. Was there anything else that:you·feltwashighly µnusuaLregarciing the investigation'? A Well the Dahlia Weiss being involved in this case with her husband as a lawyer for.-- I'm not saying that anything lrnppcned there, buf ther.e's , ~ i certainly an appearance of impropriety. I fcltJike • that alone sh91.1ld have been.reas9n enough. First of all rofherto b.e disqualified as soon as slie became aware that a:law firm.that --not disquallfied but removed from the case as soon. as she became aware 1 26 ,{Pages 101 to 104) Pleasanton, Greenhill, Meek and Associates 5;6·1-8.33-7811 CA/ Aronberg-000797 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Page 105 1 that her husband's law firm had represented Mr. 2 Epstein. And maybe even done damage to the point 3 that because that happened it should be handled by 4 another circuit 5 This was a case that I felt 6 absolutely needed the attention of the State 1 Attorney's Office, that needed to be prosecuted in 8 state court. It's not.generally something,that's 9 prosecuted in a federal court- And ,1.knew that it 10 didn't really matter what the facts were in this 11 case, it was pretty clear to me that Mr. Krischer 12 did hot want to prosecute this case. 13 Q Did he, in fact, make that clear to you at 14 some point verbally? 15 A Not in those exact words. But the 16 suggestion that multiple victims and some ofthe 17 crimes, felonies^ thathe'should writea notice to 18 appear for a misdemeanor and the scheduling of a 19 grand jury on an issue like this is extremely rare. 20 The fact that he and 1 had an 21 excellent relationship. I was the speaker at his 22 swearing in ceremony. And that he wouldn't return 2 3 my phone calls, I mean it was clear to me by his 2 4 actions that he could not objectively look at this 25 case. Page 106: 1 . Q At some point, did you feel, or did you 2 : becomeaware, that maybe he had been.threatened.in 3 some regard, either regarding hisjob or personally 4 in any regard? 5 A No, 6 MR. CRITTON: Form, 7 BYMR.KUVIN: 8 Q You're aware that obviously his position 9 is an elected position? 10 A T am aware. 11 Q Did you know whether or not he had had any T 2 discussions with anyone about his political career 13 if this case did not go a certain way; did you ever 14 become, aware of that in any regard? 15 MR. CRITTON: Form. 16 THE WITNESS: No. He had already publicly 17 announced he wasn't running for re-election. 18. MR. KUVIN: All right. This. is.actually a 19 good,stopping point tor a quick lunch if you 20 want to take a quickone, I just have to eat. 21 I'm hopefully not far from concluding. 22 THE VIDEOGRAPHER: We're off the record al 23 12:35. This is the end of tape 2. 24 (Recess) 25 THE VIDEOGRAPHER: We're back on the Page- 1.07 1 record at 1:44. This is the'beginning of tape 2 3. 3 BYMR.KUVIN: 4 Q Okay. When we left off we were talking 5 about Barry Krischer's office. And before I move on 6 Trom that subject I just have one other question. 7 Are you aware of any contact that Was 8 made with Mr. Krischerls office from anyone in the 9 democratic party or the DNC at all? 10 MR. CRITTON: Form. 11 THE WITNESS: ^Relative to this case? 12 BY MR. KUVIN: 13 Q Yes, relative to the Epstein case? 14 A No. 15 Q Are al 1 of the officers that were involved 16 in the investigation listed or contained within the 17 incident report that we've marked as Exhibit 2. and 18 were there any additional officers that were 19 involved that may not be listed in there? 20 A Typically and generally when you say 21 involved, I mean that could encompass all sorts of 22 different people. It might be -1 don't even know 23 that this was the case but it might ask the patrol 24 officer in the area to collect license tags from a 25 street or something like that. Lmeanif they Page 1.08. ■1 aren't writing a report and they aren't doing 2 somethingthat's probably important later on.as a 3 witness, they might not appear in there. But the 4 detectives who conducted the investigation arc 5 listed in there from what Frecall the last time I 6- read it, and it's been a while, but as far as I 7 know. 8 Q At any point, did you have to remove for 9 any reason anyone in.your department from the 10 investigafion for any reason? 11 A No. It took place over a fairly long 12 period oftime so: people were transferred and so on, 13 but I didn't personally remove someone for any 14 reason. 15 Q And it may not have been you personally, 16 but just to make sure that it encompasses, all 17 potential iterations of that question, was anyone 18 removed for any reason other than just someone 19 transferring,out? 2 0 A Dp you mean for — I think you have to 21 explainthat. 2 2 Q Were any of the investigating police 23 officers removed for any potential conflicts, 2 4 refusal to follow direction, any reason, other than 25 just a transfer out of the department for some 27 (Pages ,105 to 108) Pleasanton,, Greenhill,- Meek and Associates 561-833-7811 CA/Aronberg-000798 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY 1 2 j 4 5 6 7 8 9 10 11 12 l3 14 15 16 17 18 19 20 21 22 23 24 25 l, 2: 3 4 5 6 7 8 9 10 .11. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 • Page 105 thather hl!sband's law firm had represent~ci Mr. Epstein. And IQaybe eveh done damage to fhe point thatbecausc that happened it shoulcfbc handled by ;:in9tl}er circuit. This was a .case thatT felt absolutely neec;led the· attention of the· State Amwney!s Offic:e, th<it needed to be prosecuted in state court. 'It's not:generaily something:that's pros_ecutc;d in a_ federal court. And lknewtJiat it didn;t really matter what the facts were in this ca~e, it \Va~ pretty clear to me that Mr. Krischer did .hot want to prosecute this case. Q Did he, ·in fact, make that clear to you at some point verbally? ,A .Not inthose exactwords. Butthe suggesti9n tharmultiple victims and some ofthe cl'imes, felonies, that he,should write·a notice to appear for a misdemeanor and the scheduling of a grandjury on an· issue _like this is extremely rare. The ract that.he and I had an i::xi::ellent, r~laJib11~hip, I W?.s-the spea)<er at h_is swearing in cererribni And that he wouldn't retuni my phone calls, I .mean it was clear to me by his actions that h,!,: c:oulci 11ot objectively look a(thjs case. Page 106 Q Atsorne point, clid you feel,.cir die! you become.aware, that maybe he had been.threatened.in some regard, either regarding his job or personally in any regard? • • • A No. MR, CRITTON: fcmn. BYMR. 'KUVIN:. 1 2 j 4 5 6 7 8 9 to 11 12 13 14 15 16 17 18 19 20 21 ·22 23 24 2:5 :1 2 -3 4 5 6- 7 Q You're aware that'obyiously:his positio_n 8 is an elected:position? 9 A Tam aware. 10 Q Did you kl)o\v whether or not:he hµd had any i 1 discussions with anyone about hi's politicai career • 12 if tbis ca_se djd not go a .cert:iin way; did_ you ever 13 become. aware of that·in any regard? • 14 MR. CRITTON: form. 15 THE WITNESS: No. He had alreac.ly publicly i6 announced .he wasn'.t running for re-eiection. 1 7 MR. KUVlN: AH right l'his is actually:a 18 good stopping point for a quick lunch if you 19 want to take a quick:one, Tjust have t9 eat. 2 0 T'.111 hopefully not far from tondudihg, 21 THE VIDEOGRAPHER: We're off the record a 22 12:35, This is:the ~nd oftape2. 23 (Recess) 2 4 THE VIDEOGRAP-HER: We're back on the 2 5 • Page 1.07 record at I :44. This js the,beginning of t~pe l BY MR. KUVIN: Q Okay. Wh¢n \Ve h;(t off we w,erc:talking aboutBarfy krischcr's office. And beforeT mbve oh· ·from that subject I Just have one other question. Arc you aware of any contact iha:t Was made with Mr. Kriscner'.s o!'iice from anyone-in the ·democratic party or Ihe DNC a_t all? MR. CRITTON: Form. THE WITNESS: :Relative to this case? :BY MR. KUVIN: Q Yes, relative to the Epstein.case? A No. Q Arc all ofthe officers that were .involved in thecinvestigation listt::d 9r contained withiinhe incident report that we've marked as Exhibit 2; and were there any additional officers that were 'invoJved thafmay not be list!!d .in tbf:re? .A Typically and generally when you say inyolved, I mean that could:~ncomp~s all sons of different people, It rtiigh(be 0 -J' don't even kno,v that this was the case but it might ask the patrol officer in ih~ arc.:c1 t_o collccJ lic:cnsc tags from a street or something like that. Lmean:ir'they Page 108. ai'en't writing a report and they aren't doing something that's probably important later on.as a witness; they might not appear in there: But the detectives who conducted the·investigation arc listt;!d in the_re from·what I'reca)l tlre l_ast tiqi~ I read it, and it's beeii a while; buta:s Jar as I 'know. Q Ata.nypoitit, didyouhavc to remoVdor any reason anyone·in:your dt;partment from :the investigation for any reason? A No. It took place over a fairly long periqd oftim~ •so peoplt;: \Vere transferrecl.. and so on, but I didn't petsonaHy renioVe-someone•for any reason. Q And' it maynofhav<:! been you personally, but just to make sure that it encompasses. aH • potential iterations of that question, was anyone removed for anyr,eason other than just someone transferring.out? A Do you mean for-~ I think you have io cxplainthat. Q Were any of the· investigating police officers removed for. any-'poteiltial conflicts, refusal to follow direction, anyreason, other than just a transfer out of the-department for sotne 27 (Pages 105 to 108) Pleasanton, Greehhi11, Meek arid Associates 5:6'1-833-7811 CA/ Aronberg-000798 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Page 141 1 Q Ifwe lookat thcbottom of page 67, 2 second paragraph down - sorry, second paragraph 3 from the bottom, excuse me, it says here letter to 4 Mr. Dershowitz sent advised.he was looking into the; 5 allegation that one of the-private investigators 6 used by the private attorneys of Epstein, attempted 7 to impersonate or state that they were police 8 officers.from Palm Beach. Do yourecall hearing 9 about that? 10 A 1 didn't rccall, not till 1 read this. 11. Q Okay: Apparently there was a package sent 12 to both ASA Lanna Belohlayek and ASA Dahlia Weiss at 13 the State.Attorney's Office, Do you see that? 14. A I sec that sentence, yes. 15 Q Did you see that package that was sent? 16 A 1 don't;remember that I did. I wouldn't 17 normally. 18 Q Ifweturn to page 73,topof the page it 19 lias the name of a Dr. Perry Bard. Do you see that 2 0 in the first paragraph? .21 A Ido. 22 Q Did you ever Come to learn who Dr. Perry' 2 3 Bard was other than,what might.be stated in here? 24. A T read this at one time so I was informed 2 5 of it, but 1 had not recalled the name until I read. J Page 143 1 A No. 2 Q Ifyou turn to page 79, it appears that; on 3 -the dale of.February 16, 2006, there's a meeting 4 that takes place between the investigator Joseph 5 Recafey and two women, Joanna Harrison and.a 6 Victoria Bean. Do you see that? 7 MR. CRITTON: Are we at 79? 8 MR. KUVIN: Yeah. 9 THE. WITNESS: Yes, 10 BY MR. KUVIN: 11 Q Okay. Did you learn any additional • 12 information regarding those two women other than 13 what might be in here, in the report? 14 A No. not personally. 15 Q This may go along with what you discussed 16 ;at the beginning with.respect to not really 17 prosecuting what technically would be a criminal act 18 for prostitution in.a home. But: it appears, from 19 this information here that these two girls were paid 2 0 for-sexual contact with Mr:,Epstein, at least" 21 .according to what Detective Recarey investigated. 22 Were there any additional 2-3 investigations ongoing regarding allegations of 24 prostitution at the home? 25 MR, GRITTON: Form, Page 142 1 it again here. 2 Q No additionalinformation regarding 3 Dr. Bard? 4 .A No. 5 Q And with respect to the next paragraph it 6 mentions a woman by the name of Johanna Sjoberg, 7 spelled S-J-O-B-E-R-G. Do you see that? 8 A I see it, yes. 9 Q Do you recall anything in particular with 10 respect to Ms. .Sjoberg? .11. ,A No. 12 Q If we turn to page 74 for a moment, there 13 are, at the bottom of the page, .last paragraph, four 14 separate telephone numbers, listed for a Cingular 15 wireless, one ofwhich is listed to a Janusz, 1.6 J-A-N-U-S-Z, Banasiak. Do you know who Janusz 17 Banasiak is? 18 A No. Only from what it says here. 19 Q No additional information though? 20 .A No. 21 Q Christina Venero at the bottom of the 22 page, do you see that name? 23 A I See it 24 Q Any additional information that you're 25 aware of regarding her? Page 144 1 THE WITNESS: The only way I can answer 2 that question is 1 don't consider 3 fifteen-year-olds,- sixteeh-year-oldS who .are 4 paid money to engage in sexual contact 5 prostitution, by the legal definition of the & law, for purposes ofprosecuting them. I 7 really don't know what you're getting at beyond 8 that.- I mean that's — 1 don't know how else 9 to answer that: 10 BY MR. KU VIN: 11 Q Maybe Ephrased it wrong. But these 12 girls, Ms. Bean and Ms. Harrison, were apparently 13 over the age of eighteen. These were girls that 14 were over the :age ofmajority that were; apparently 15 paid for sexual contact with Mr, Epstein. 16 Were there any ongoing investigations 17 regarding solicitation for prostitution against 18 .Mr. Epstein regarding girls over the age of 19 eighteen? 2 0 A No. These kinds of situations arc not 2;i prosecutable. The State Attorney's Office some 22 years earlier even suggested that we no longer do 23 sting operations for prostitution because they 24 didn't want to prosecute them. This is a case where 25 you have willing participants after the facVand no 36 (Pages 141 to 144) Pleasanton, Greenhill,- Meek and Associat.es 561-8.33-7 811 CA/Aronberg-000799 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY Page 141 1 Q Jfwe iookat the bottom ofpage 67, 2 second paragraph .. down -- sorry, second paragraph 3 frbin the bottom, :etcuse fne,jtsl!ys·here letter .to 4 Mr. Dershowitz sent advised.he was lookinginto the 5 ·a:11ega:tion .thatorte ofthe:private:investigatots 6 used by the private attorneys of Epstein, :attempted 7 to impersonate or state that theywere police 8 .officers.from Palm Beach. Do·yourecall hearing 9 about that?· 10 A I didn't-recall, not till I rc,ad.th_i~. 1 2 .j 4 5 6 7 8 9 tci 11. 12 1_3 14 15 16 17 18 19 20 21 22 23 24 25 Q Okay: Apparentiytherewas a·package sent_ n to.both A.SA Lanna Belohlavekand ASA Dahlia Weis~ at • ·12 :the State:Attorney's Qff!ce. Po you see tha(! 13. A I sec that sentence, yes. 14 Q Pid yo!) see that piic,k_a:ge that\\ias sent? 1~ A I don't remember that I did. I wouldn'.t 16 nonnally. Q Tfwe tum to page 73, top of the page it liasthe name ofa Dr. Perry. Bard. Doyou see.that ifrtbc fi.rst paragrllph? A I.do. Q Did you ever c(>rrte to learn tvho Dr. Perry Bard \\'.as other than. what might: be stated in here? .A I read this at one time so Iwas informed ofo, but lnad not recailecJ the hl!irie uritii I i:ead. Page 142 17 18 19 26 21 22 23 24 2-5 1 it again hei'e. i 2 Q .No additional 1nformat1on regarding 2 3 Dr. Bard? • 3 4 .A No. A 5 Q An.d wj_th re~pec:t to ~lle 11ext par?"gn1ph i_t 5 6 mei1tions a Woman by the name of Johaima Sjoberg, 6- 7 spelled S-J-O-B-E-R0Q. Do yo~ see that? 7 8 A I sec it, yes. ·8 9 Q Do you recall anything in paiticular with 9 10 respect to Ms. Sjoperg? 10 11 .A No. il 12 Q If we tumto page 7 4 for a m9ment, then; 12 13 are, ·at the bottom of the page, .last paragraph, foul' 1'3. 14 separate telephone,nun:ibers listed for a Cingular 14 15 wireless, one o'fwhich·js listed to a Janusz, 15 i6 J~A~N-U~S-Z, Banasiak. bo you know who Janusz 1.6 17 Banasiak is? 1 7 18 .A No. Only from what irsays here. 18 19 Q No additionalinformation though? 19 20 .A .No. 20 21 Q Christina Vcncro at the bottom of the 2 i 2 2 page, do you see that name? 22 23 .A I see it 2_3 2 4 Q Any additJonai information that·you're 2 4 2 5 aware of regarding her? 2 5 • Page 143 A No. ' Q ff you tum to ·page 79, it appears j_hat ort the date of.February i:6, 2006, there's a meeting that lakes place behve§n the investj_gat_o:r J9_seph 1tecarey and two women, Joanna Harrison and.a Victoria Bean. Do you see. that? MR., CRITTON! Ar~\1/c-~t 79? MR. KUVIN: Yeah. THE. WITNES;>: Yes .. BY MR. KUVIN: Q Okay. Did you learn any•additional :information regarding those two women other tha.n what might be in here, in the report? A No, potpersonaHy. Q This.may go alongwith wha.t you discussed ,at the beginning with. respect to not really :Prosecuting what technically would be acrii.nihaLact, for prostitution in:a home. But it appears from this inforrna_tion here that these i:\vo, girls were paid for· sexual .contact with Mr:. Epstein, at least .accorging to what Detectiye Recarey investigated. Were there any additional investigations ongoing regarding allegations of ·prosGti,ition at thf home? • MR. CRITTON: Form. Page 144 THE WITNESS: The only wayl Cati. ai1swer' that question i~ I clon't consider fifteen-year-olds,- sixteen~year-olds who .are paid money to engage in sexual contact pr9stitution, by t_hi;: lr;:gal ddi11itiQll oftll~ faw, for purposes of prosecuting them. l really cion't know what you'r~ getting at~eyoncl thaL I mean that's -0 • I don't:know how else to- answer that: BY MR. KUVIN: Q Maybe I phrased itwrong. But these girl~, Ms. Bean and Ms. Harrison, were apparently- over theatfe of eighteen. These were girls that were over the age of majority that were apparently paid for sexual contact with M.r .. E:pstein .•• Were .there any ongoing investigations regarding solicitation for prosfitµtion against .Mi·. Epstein regarding girls over the,age of eighteen? • A No. These kinds of sitµations arq not ,prosc1.;utablc. The State Attorney's Office some years earli~revr;:n sµgge_st~d th.at we no ·1cmgercio sting operations for prostitution because they didn't want to prosecute them. This is a case where ·you have willing participants after thc·fact,and no 36 (Pages 141 to 144) Pleasanton, Greehhi11, Meek and Associates 56:1-8:3·3~ 7 811 CA/ Aronberg-000799 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Page 145 1 physical evidence. 2 No. the resources of the department 3 are nofdedicatedfor these kind of semi-victimless 4 crimes in private residences unless it presents some 5 other problem. 6 Q Okay. If we turn to page 81, bottom of 7 the page dated April 10 of 2006. Second to last 8 paragraph.it references — 9 MR. CRITTON: I'm sorry, Spencer, what 10 page? 1’1 MR. KUVIN: 81. 12 BY MR. KUVIN: 13 Q Additional subpoenasfrom the State 14 Attorney's Office requesting information from Dollar 15 Rent a Car and Jet Aviation. Do you see that? 16' A Yes. 17 Q Do you recall seeing any of the records 18 that, were produced in response to this subpoena to 19 Dollar Rent a Car or Jet Aviation? 20 A No. 21 Q Turn to page 84 if you would. Top of page 22 84 there's discussion - and this goes back to the 23 initial note as begun on April 14, 2006 and actually 2 4 begins on page 82 — regarding grand jury subpoenas 2 5 and discussions with the State Attorney's Office. Page 14 6 1 If we go to page 84 though, it talks 2 about the quote, unquote, deal being offered to 3 Mr. Epstein. And ifyou look, at paragraph one here, 4 in. the middle ofthe paragraph it says however, I 5 expressed that was only my opinion and that the 6 final approval would come from the Chiefof Police; 7 She explained to have ChiefReiter call Barry 8 Kriseher about the deal. Do you see that? 9 A I do. 10 Q Did Officer Recarey talk to you about the 11 deal? 12 A There were so many potential deals, deals 13 being the plea agreement, that had been suggested, I 14 don't know which one they're talking about here. 15 Q Bottom ofpage 83, if you read the last 16 paragraph it'll explain it, might help refresh your 17 recollection. 18 A Well after reading this it refreshed my 19 recollection on one ofthe different;proposed 20 agreements, which 21 Q Okay. 22 A — I guess some ofwhich they asked for 23 our input. And what;this reflects is that in this 2 4 particular case with all of its unusual twists and 25 turns, I told Detective Recarey that he should not: Page 147 1 offer an opinion, on behalf of the departmentof 2 whether we think any deal is appropriate, that I 3 would want to reserve that for myself. So that's 4 what happened here. 5 Q. Okay. All.right. 6 Do you recall having direct 7 conversation with Barry Kriseher about this 8 particular deal that's discussed here on pages 83 9 and 84? 10 In other words, it looks here on page 11 83 to be a deal where the offer is, one count of 12 aggravated assault with intent to commit a felony, 13 five years probation with adjudication withheld, 14 which was conveyed to Mr. Epstein's attorneys at the 15 time. Guy Fronstin and Mr. Dershowitz. 16 A I always told Barry Kriseher when we had 17 conversations about how this would resolve itself 18 that my biggest concern, really my main concern was 19 that Mr. Epstein be classified as a sexual offender 2 0 to. reduce the likelihood,that this would continue in 21 the future. I never formed an opinion or 22 communicated-it to him about how many years of this 23 or how many years of that, so on, other than to tell 2 4 him that 1 feIt like a Notice to Appear was not the 25 appropriate way to resolve this. Page 148 1 Q Okay. All.right. Bottom of page 84 2 there's a documented call with Officer Recarey, 3 Detectiye Recarey, Says here on May 3rd, 2006 at 4 approximately 2:54 p.m., I, meaning Detective 5 Recarey, received a telephone call from ASA.Dahlia 6 Weiss on my cellular telephone. ASA Weiss advised 7 she has been taken:off the Jeffrey Epstein case 8 because her husband is employed with Attorney Jack 9 Goldberger. Do you see that? 10 A Yes. 11 MR. CRITTON: Is there a date there, 12 Spencer, ofreference? 1.3 MR. KUVIN: Yes, May 3rd, 2006. 14 MR. CRITTON: Thank you. 15 BY MR. KUVIN: 16 Q Is that the first time that — or shortly 17 after that call that you became aware of the 18 relationship between ASA Weiss and Mr. Goldberger's 1.9 office? 20 A Like I said earlier, I became aware ofthe 2-1 relationship prior to learning of her being taken 22 offthe case, so I would ,have known about the 23 relationship before this day. 2 4 Q It appears, and I don't want you to guess, ■25 so all 1 want to know is whether you had a 37 (Pages'. 14 5 to 148) Pleasanton,,. Greenhill, Meek and Associates: 561.-8.33-7811 CA/Aronberg-000800 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY 1 .2 j 4 5 6 7 8 9 10 n 12 13 14 15 16' 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 1_6 17 ],8 19 20 21 22 23 24 25 • Page 145 physical evidence. N_o, the,re_so,urces ofth~ clepartme_nt are not dedicated for-these kind of semi-victimless 1 2 3 ~ri.mtc:s in privare, r_c:sisltc:nc·~s ((hl,ess i_t pte~ents :~on1e 4 othcq:iroblein. 5 Q Ok<].y. If we turn to page 81, bottom of 6 the page dtHcd April JO of 2006. Second Jo fast ·7 paragraph it references -- 8 MR. CRITTON: I'm sorry, Spencer, wha( 9 page? iO MR. KUVTN: 8;1. 11 BY MR. KUVIN: 12 Q Additional subpoenas.from the State 1.3 Attorney's Office requ_esting information from Pollar 14 .Rent a Car andJct Aviation. Do you sec that? is A Yes. 16 Q Do you recall seeing any of the records 17 that;were produced in response to this subpoena to 18 Dollar Rent a Car or Jet Aviation? 1.9 A N~ 20 Q Turn'to page 84'ifyou would. Top ofpage 21 84 ·there's -discussion --0 and this goes back to. tile • 2·2 initial note.as begun on April 140 2006 and actually 23 ·begins on. page 82-- regarding grand jury subpoenas 2 4 and discussions with the State Attorney's Office. 25 p·age 146' Ifwe go to page 84 though, it talks 1 about'the quote, ·unquote, deal being offered .to 2 Mr. Epstein. And if you look at paragraph one here, .3 in the middle of the paragraph it says however, I 4 tc:xpress~d that was ol}ly !JlY 9pini9_n and Jll.1! t,he 5 final:apptoval would come from i:he Chiefofl'olice; 6 $he c:xplained to have-Chief Reiter call Barry 7 Krischct about the dcaL Do'you sec that? • 8 A I do. 9 Q Did Officc:r Recarey talk tq you _about the 10 deal? 11 .A There: were so many:p9tential deals, deals 12 being the plea agre_ement, thtit had bec::n suggested; I .13 don;t know which one·they'i·e talking about here. • 14 Q t}ottom of page 83, if yo,\l read Jhe last 15 para.graph it'll explain 'it, might help refresh your 16 rc:collcction. 17 .A Well after readingthis it refreshed my 18 recollection on one oftlie differentproposed 19 agreements, which ~- •2 0 Q Okay. 21 A -- I gues$ some of"".hich they asked for 22 our irij:itit Andwhatthis teflectsis that in this 2 3 particular case with all of its unusual twists and 2 4 turns, T told,Dctcdivc Recatcy that he should not -2 5 Page 147 offer an opinion on behaif ofthe department of whethetwethirtk any-deal is-_apptopi:iate,that I would want to,reserve that for myseif. So that;s what happened here. Q: Okay. AILright: Do you recall having direct· conversation with Baiiy,KJis~lier, abouqhis particular cieaL'that's-discusseci here on pages 83 'and84? ·in other words, it looks here on page ·33 to be a deal where the offer is, one count of" ;aggravat~d assault With int~nt to commit a felony; five years probation with ·adjudication withheld, which wa:s conveyec_l to Mr. Epstein's, attorneys at the time; Guy Fronstfo and Mr. Dershowitz. - A I always told Barry Krischer when we had convetsations,about h9-w this w,oi.Jld resolve itself -tha·t my biggest concern, reafly·my main concern was that Mr. Epstein be classified as, a sexual offender to_ reduce the likelihood that this would continue in the future. I never: formed an opinion or comrriuriicatecl ·it to hitn about hoW ma11y years .of this or how many years ofthat, so on, other than to teli him that lfel_t like a Notice to Appear was not the appropriate way,to resolve. this. Page 148. Q Qkay:; A.ILrigbt. Bottom o(page 84 there's a. documented ca II with Officer Recarex, Dete\;tive Recarey; Says here on May 3nl, 2006 at' approximately 2:54 p.m., { meaning Detective Recarey, received a telephone call from ASADahlia Weis_S'<.ih rrty. cellul;_ir teleph9ne. A.SA Wejss advise,d she has 'been taken:ott'the Jeffrey Epstein case because her husbancl"is er,nployed, witll.Attorn_ey Jack Goldberger. Do you see that? • A Yes. MR CRITTON: Is there a date there, Spencer, :of reference?. MR. 15.UVIN: Yes; May-3rd, 2006, MR. CRiTTON: Thank you. BY MR.KUVfN: Q .Is that the first time that - or shortly after thatcall that you became ,aware of the rel<1tions_hip bet:wet;h ASA Wei$s and Mr. Goldberger's oftJCe? • A 'Liker said earlier, I became aware of the relationship pricfrto lea.ming ofher being taken off the case; so Lwould,have known abotitthe -rel:,itionship bef9re thi~ dlly. Q It appears, and'I don't want youto guess, so-all Lwant to know is whether you had a 37 (Pages l45 to 148) Plea.santon, Greenhill,- M:'eek and Associates 56'1-833-7811 CA/ Aronberg-000800 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Page 149: 1 conversationwith Detective Recarey about this, 2 whether he said anything directly to you that she ■3 was removed as opposed to. removing:herself 4 voluntarily from the case? 5 MR. CRITTON: Form. You're asking him to 6 speculate. 7 MR. KUVIN: No, I'm not. I'm asking for 8 any conversation he had with Detective Recarey. 9 THE WITNESS: I don't remember: 10 BY MR. KUVIN: 11 Q Okay. Page 85, again going down to the 12 date of May 15, 2006, there's a reference to a 13 contractor by the name: of David Norr, N-O-R-R, and 14 apparentlyhe was surveilled for a short period of 15 time. 16' A Let me find that, 17 Q Sure. Middle of the page. 18 A Okay. 19 Q Do you recall whether your department 20 obtained any records regarding the renovations, that 21 were, going on at Mr. Epstein's’home; blue prints,, 22 construction diagrams, anything like that, documents 2 3 from the contractor? 24 A No, 25 Q No, you didn't, or no — ■ Page 151 i i 1 with Mr. Indyke? 2 A No. 3 Q There appear to be a number of 4 corporations. El Zorro Ranch Corporation, New York 5 Strategy Group, Ghislaine, G-HT-S-L-ArEN-E, 6 Corporation, J. Epstein and Company and the 7 Financial Strategy Group. Do you see those? 8 A Ido. 9 Q‘ Do you recall anything, seeing any 10 documents.or information regarding those companies? 11 A’. I've read this report before. And if it's 12 in the report ! read it previously, but 1 don't have: 13 anything independent of the report, nor do I recall 14 any more than what you've shown me here. 15 Q I'm just looking to see whether or.not you 16 saw any corporate printouts or corporate documents 17 or anything like that that might have been obtained 18 online or through other sources? 19 A, I did not get involved in this 2 0 investigation at. that level, 21 Q Okay. Last entry here of July T2, 2006, 22 it says here Belohlavek - and spelled for the 23 benefit of the court reporter, we've used.it before, 2 4 but j ust for her sake it's B-E- L-O-H-L-A-V-E4C r- 25 stated State Attorney Barry Krischer made the Page 150 1 A No, .1 don't recall. It would have been 2 easily available to us from the building department. 3 ,Q Right, building and zoning? 4 A I have nd idea ifwedid. 5 Q Turn to page 86. Top of the page on May 6 22nd, 2006,1 received several phone calls 7 throughout the day from Mr., and then it's blacked 8 out; who stated he had been followed aggressively by 9 a private investigator. Who was that? 10 A I don't know. 11 Q It appears if you.go further down that the 12 vehicle that was following this person was traced by 13 Florida tag I35-XGA tp a Mr. Zachary Bechard of 14 Candor Investigations. Do you see that? 15 A Yes. 16 Q Did you come to learn anything about that 17 particular investigative agency? Independent of 18 what might be in the report, 19 A No, not that I can recall. 20 Q Page 87, last page. Middle of the page 21 references Epstein's corporation attorney, a 22 gentleman by the name: of Darren Indyke/I-N-D-Y-K-E 23 Dp you see that? 24 A Not yet. Okay, yes. 25 Q Do you recall having any conversations: Page 152 1 determination to go to the Grand Jury to hear the 2 case. 3 Did you; or do you recall discussing 4 directly-with him why he was taking this to a Grand 5 Jury as opposed to just charging Mr. Epstein, his 6 office doing it themselves? , 7 A No: 8 Q You agree with rhe that thatwould be out 9 of the ordinary based on the charges that were 10 brought? 11 MR. CRITTON: Form. 12 THE WITNESS: My experience, yes. 13 BY MR. KUVIN: 14 Q Do you agree:with me that you.learned that: 15 it was Mr, Krischer that made that decision himself? 16 MR. CRITTON: Form. 17 THE WITNESS: That's my understanding. 18 BY MR. KUVIN: 19 Q Did,you.ever get any explanation from 20 anyone, not just him, but anyone, as to why they did 21 that? 22 MR, CRITTON: Form, 2 3 THE WITNESS: Sometime after the fact, the: 2 4 Grand Jury, maybe evcn possibly long after the : 25 fact; he told me that it was a political —. not 38 (Pages 149 to 152) Pleasanton, Greenhill, Meek and Associates 561-833-7811 CA/Aronberg-000801 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY 1. 2 -3 4 5 6 7 8 9 10 n 1:2 13 14 -is 16' 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 8 9 10 11 12 13 :14 15 16' 17 18 ,19 20 21 22 23 2~ 25 • Page 149 conversationwith Detective Recarey about this, 1 ,vhether he s.iid .inything directly to you that she 2 was, removed as opposed to. removing·herseif 3 volunfarily from tb~ cas~? 4 MR. CRITTON: FOnn. You're asking him .to s speculate. 6 MR. KUVJN: No,J'm noti l'maskingfor 7 any conversation he had-with Detective Recarey.. 8 THJ2 WIJNE.SS: I don't remember: 9 BY MR. Rt:.J\ITN: 1 o Q Okay. Page 85, .again going down to the 11 date or May 16, 2006, there's a reference. to a 12 contractor by the name:or David Norr, N~O-R-R, and 13 apparently he-was surveilled fqr a sl;lort period of 14 time. 15 A Let me find that 16 Q Sure. Middle of the page, 1 7 A Okay. 18 Q Do ycmrecaH whether-yourdepari:ment 19 obtained any records rcgard!ng the renovationsJhat 20 were. going 9n at Mr. Epstein's'home; blue prints,. 21 construction diagrams; anything like that, docurnents_ 22 from the contractor? 23 A Nb, 24 Q No, you didn't; orno -- is Page 150 A 1-{o, I don't'"recall. I_t woul,Jhave been easily avaiiable to us from the buiiding department Q Righi, building and zon1ng? A !have no idea if:we did. Q Tum to page 86. Top of the page on May 2211d_, 200(?; I received s_everal phone calls throughout the day from Mr., ·and;then it's biaeked out; who siated he had' been followecl aggressively by a private ii1vestigator. Who was that? • A I doti't know. Q It appears if you.go further do\vh tlfat.the vehicle ,that was following this.person was traced by Floricla tag 135-XGA to-a Mr. Zachary B~chard.of -Candor ·investigations. Do you see _tl1at? A Yes. 2 5 6 7 8 9 10 11 12 13 14 15 Q Diel you come to lea.m anything apoutihat 16 particular investigative agency? Independent of 1 7 What might b~ iil' tl1etepq[t. 18 A No, noMhrit I can recall. 19 Q Page 87, last page .. Middle ofthe page 20 refotences: Epsteill's corporation attoniey,_,a 21 ·gentleman bythename:ofDarren'Indyke, l-NcD 0 Y-K-E 22 D9 you, ~ee thai?, 2 3 A Not yet. Okay, yes. 2 4 Q Do you recall having any conversations, 25 • P.age 15.1 with.Mr. lndyke? A r-lq. Q: There appearto be a number of corporations. El Zorro Ranch Corporation, N~w York :Strategy Grm1p, Ghislaine, G~H~l~S-L-A,I~N-E, Corporation, J.Epstdn anci Company and the • Financial Str~tegy Group .. Do you see tho§e? A Ido. Q· Do you r\!call anything, !;eeing any ·documents or infonilation r'egatding those companies? A. I've read this report before. And if it's in the report'! read it previously, butI don't have anything independent of the report, nor do I recall 'any more than what you've shown me here, Q I'tn just looki"ng to s_ee whether or. not you -saw any corporate printouts or corporate documents or ,!nything like thattqat might have bee11 obtained online orthrough other sources? A, I did-not g~t inyolved in this investigation at_ that level. Q Okay. Last entry here of July n, 2006, ,it says here"Belohlavek -" a11~ Spelle_dfor the benefit of the court-reporter, we've used.it before, butjust fm: h_er sake it'i; _B~E,L-O-H.~L-AN sE¥ ,- stated State Attorney Barry Krischer made the Page 1521 ·detem1ination:t6 go -to the Gnif1dJury to:hear the case. Did you, or do yourecall discussi~g dircctly0with him whYhe was taking this•to a Grand. Jµry as opposed to j_ust chc1rging .Mr: Epstei11, his office doing:it themselves? A No: Q ¥ou agree with rhc thatthatwould be out of the ordinary based on the charges that·were brought? •• MR. CRITTON: Form. THE WITNESS: My experienc~, yes. BYMR. KUVIN: - • • Q Do you agree:with methatyouleamed that: it wa_s M_r._ Kris¢her that made that decision himse]f1 MR. CRJTTON: Form. THE WITNESS: That's my. understanding. BYMR. KUVIN: • Q Did.you.ever get any explanation from ,anyone, n·otjllst him,• _l:iut anyone, as fo why t_hey did that? MR CRlTTON: Form, THE WITNESS: Sometu:ne aftetthefact, the Grand Jury; maybe even:possibly long after the fact hdold me thatit was a t,olitkal ---.not j 38 (Pages 149 to 152) Pleasanton, G:te.erthi11; Meek and Associates 5.61-833-7 811 CA/ Aronberg-000801 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Page 153, 1 a political, but it was a noteworthy 2 investigation, a noteworthy prosecution. And 3 in these kind ofcontroversial situations, an 4 independent body ofthe Grand Jury, it was 5 appropriate to have them exam him. Recalled 6 other grand juries for things, I can't say 7 similar^ but a homicide that-had racial 8 overtones and so on, and he made reference to 9 that, that that was his choice to deal with 10 these kinds, of things. That could have been as 11 recent as,, you know, within the last year and a 12 half or so. 13 BY MR. KUVIN: 14 Q Do you; recall your department being 15 involved in any other high profile- type of 16 investigations; for example, the investigation that 17 involved a radio personality that lives in Palm 18 Beach and the investigation of a potential boater 19 fraud as a result of another author or radio 20 personality on.Palm Beach, or.was this the only high 21 profile investigation you can recall working on in 2 2 your history in the. city, of the town? 23 A Involved in the.department,and personally 2 4 been involved in many high profileinvestigations. 25 Q Many being more than ten? fm justifying Page 155 1 perspectives but not necessarily the news media 2 coverage. 3 BY MR. KU VIN: 4 ,Q Was it handled any differently than you 5 handled other high profile cases that you may have 6 handled in the past?' 7 MR. CRITTON: Form. 8 BY MR. KUV1N: 9 Q- From your perspective? 10 A, I don't think it was handled any 11 differently by the PalmBeach Police Department than 12 from any of the other high profile cases. 13 Q- Okay. I appreciate it. That's all the 14 questions ! have.at this point, Urn going to turn 15 it oyer tothe otherplaintiffattorneys who may 16 have a few for you. 17 MR. HILL: I don't have any. Thank you, 18 sir. 19 THE WITNESS: You're welcome. 20 MR. GARCIA: I just have a couple here. 21 GROSS-EXAMINATION. 22 BY MR. GARCIA: 23 Q. Chief, my name is Sid Garcia, I represent 24 one of the plaintiffs in,the case. 1 think we met 25 before in another case, another deposition years Page 154 1 to get an idea — 2 A The standard rules don'treally help me. 3 We used to joke about how very small things in Palm 4 .Beach would become jnoleworlhyin the news media, 5 that they would be meaningless everywhere else; 6 Q Right. 7 A If you mean national political interest, 8 at that level profile, yes, at least ten, probably 9 more than ten. 10 Q In your experience in dealing with even 11 those high profile investigations, was this one 12 different? 13 MR. CRITTON: Form. 14 THE WITNESS: It wasn'.t different in the 15 amount of, you know, at the level of profile of ! 6 had we been involved in that before where it 17 gets international news media coverageand all 18 of the things that come with that. It was 1.9 different in the respect that probably what 20 should have remained a state case had to become 21 a federal case, which they ended it and it all 22 ended in an agreed plea in the state case. It 2 3 was different for me in that 1 asked the State 2 4 Attorney to remove himself from the case, you 25 know'. It was different from many different Page 15'6 T -ago. 2 Just want to ask you a few questions 3 beginning with, the — asking basically your opinion ■4 as to why Mr. Krischer did not pursue the case with 5 the diligence that .you thought he should have 6 pursued itwith? 7 MR, CRITTON: Form. 8 THE WITNESS: I'm not sure I understand 9 the question. 10 BY MR. GARCIA: 11 Q, In other words, you talked about that,you 12 sent a letter to Mf, Krischer asking him’to 13 disqualify his office from the case. Why do you 14 believe that.he did not pursue the case with the 15 zeal that you thought he should-pursue it with? 16 A I don't-.know. 17 MR. CRITTON: Form. 18 BY MR. GARCIA: 19 Q What is your opinion of why he didn't 20 pursue it that way? 21 MR. CRITTON: Form. 2 2 THE WITNESS: That's not my role. I 23 haven't formed an opinion oh that, I don't know 2 4 why. 25 39 (Pages' 153 to 15 6) Pleasanton, Greenhill, Meek arid Associates 561-833-7811 CA/Aronberg-000802 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY 1 2 3 4 5 6 7 8 9 10 11 12 13 14, 15 16. 17 18 19 20 21 22 23 24· 25 1. 2 3 4. 5 6 7 8 9 10 li 12 13 14 15 16 17 18 19 20 21 22 23 24 25 • Page 153 a·political, but 1t was a noteworthy investigation, a notewor:thy prosecution. And in these. kind ofeontroversialsituations, an i11dept;m9ent boqy ofthG Or;mdJury, itwas appropriate to have them exam hin'f. He called other granq juries for things; I can't say similar, but a homicide that-had.racial overtones and so on, and.he made reference to that, that that wa.s .h:is choice to d.eal with these kinds, of things. That could have been as r1;:eent as,eyoµ know, \vi thin the last year and a halforso. BY MR. KUVIN: 1 2 3 4 5 6 7 8 9 iO 11 12 13 Q .Do you recall yo.ur department being 14 involved in any other.high profile type of 15 investigations; forexample; the investigation that 16 i11volved a radio personality that lives in Palm 17 Beach anci the investigation of a potentialboater 18 fraud as a res_ult ofanother author or radio 19 personality on.Palm Beach, or. was this the only high 20 profile investigation yoll can rec:all working on in 21 ·your history in the. city, or'the town? :z 2 • A Involved inthe:department.and personaiJy, 23 been, inyolvc;d 'in many high.profile investiga'tioris. 2 4 Q Many being more than ten? i'mjusttrying is Page 154 ·to get. an idea -- :J: A The standard rules don't:really'help me. 2 We used to joke about how very small things in Palm 3 Beach wouldbecome:noteworthyin the news medfa, .4 that'they wo1,1ld be·meaningh;ss everywhere else,. 5 Q .Right. • • 9 A If you meall' national political interest, 7 at that level pro(i(c, yes·, ·al lcaSt:tcil, probably 8 .more than ten. 9 Q Ip yolclr·experi_ence in dealing•with even· 1 0 those high profile investigations, was this one i 1 different? l'2 .MR. CRITTON: form. 13 THE WITNESS: Itwasn'.t different inthe· 14 amount of, yoµ know, at the [evelq(profiJe o( 15 had w.cbccn involved in tha{beforewherc it 16 gets international news media coverage and all 1 7 ofthe things that C:oine with that It ,vas 18 different in the respect tbatprobablywhat 19 sboulg bave _n:rn<!iT)ed a state qse had to tiecome 2 0 a;federal case; which they ehded it.and it all 21 ended in an agreeq plea in the ~tate case. It 22 Was differentfor:me irtthatlasked th1;: State 2~ Attorney to remove himself from the cas~, you 2 4 know: lt was different from many differeni 2 5 • Page 155 perspectives but notnecessanly the news media coveragi;:., BYMR. KUVIN: Q Was it handl~d any differently than yoµ .handled other high profile cases that you may nave handled in the pasti • MR, CRITTON:: Forni, ,BYMR.,KUVIN: Q· Frqm yot1r perspec:tive? A I don't think it was handled any differently by the Patm:Beach Police Departmentthan from aIJy i:)f the other high profile. cases. Q· Okay. I appreciate 1t. That's a:llthe questionsThave .. at this point Jim going to tum it o;ver to·the other plaintiff attorneys who. may have a feW'foryou. MR. Hl[L ld61_1 1t have 1!ny. Thank you, SIL THE WITNESS: You're wi;:lcome. MR. GARCIA: I just have a couple here. .CROSS-EXAMINATION. :BY MR. GARCIA: Q: Chief, my name is Sid Garcia, I represent on~ of the plaiJ1tif[s jn:the case. Ithi~ we rnet before in another case, ·another deposition years Page 15·5 ago. Just want to ask you a few questions beginning with the Sa asking basically your opinion as·to why Mr. Krise her did not pursue the•casc with. the qilig~nce tha,t.you thought he shouldh<1ve pursued it with? • MR. CRITTON: Form. 1J-1E WITNESS: I'tn not sure I understand the question. BY MR. GARQA: Q In other words, you talked about that. you sent a letterto Mr, Krischer asking him to disqualify his office from 'the case. Why dcryou. believe that.he did not pursuethe case with the :zeal tha,t you thought he sho.uld-pursµe it with? A 1 don't:know. MR, CRITTON: Form, BY MR GARCIA: Q 'Whatis your opinion.ofwhy he didn'.t pursue·it that way? • • MR. CR1TTON: Form. THE WJT:NES_S: That'snotmyrole: I have11't foiinea an opinion oh that, I do11't know why. 39 {Pages 153 to 156) P1easantoh, Greenhi'il, Meek and Associates 5 61 - 83 3 ~ 7 8 11 CA/ Aronberg-000802 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Page 157 1 BY MR. GARCIA: 2 Q Did you think that — were you aware or 3 did you become aware at some point that Mr; Epstein 4 was a contributor to the democratic party? 5 A Yes. 6, Q Are you. aware that’Mr. Krischer. has ties 7 to the democratic party? 8 MR. GRITTON: Form. 9 THE WITNESS: Yes. 10 BY MR. GARCIA: 1’1 Q Did you suspect at any point in,time that 12 there was a connection between M r. Epstein's 13 political connections with the .democratic:party and 14 Mr. Krischcr's refusal or neglect to prosecute in 15 this case with the zeal he should have pursued it 16' with? 17 MR. CRITTON: Form. 18 THE WITNESS: 1 didn't allow myself to 19 explore that. 20 BY MR. GARCIA: 21 Q Did you have any discussions with Mr, 2 2 Krischer about that issue, whether or not 2 3 Mr. Epstein was receiving favorable treatment from, 2 4 the State- A ttorney's Office because of Mr. Epstein's 25 politicalconnections? Page 159 1 criminal charges.against Mr. Epstein, correct? 2 MR. CRITTON: Form, 3 THE WITNESS: Yes. 4 BY MR. GARCIA: 5 Q. This is hot a. situation where there was 6 maybe a situation, an age 7 difference and the victim was not cooperating in the 8 investigation; is that correct? 9 MR, CRITTON: Form. j 10 THE WITNESS: That's correct. 11 BY MR,GARCIA: 12 Q IDid you challenge him' oil that issue? 13 A . Yes. 14 Q And what was his response? 15 A He continued to reiterate that the case, 16 that it was.his.ethical obligation. And he had told 17 me this before about other cases that we had 18 discussed, Palm Beach Police:Department cases and 19 other cases, that he has an ethical responsibility 20 to. feel — to be reasonably certain that the case is 21 winnable before: he prosecutes it. And he said,that 22 because of all of those reasons and others involving 2 3 :some of the: reputation and Facebook pages and so on 24 of certain victims, that he couldn’t feel that he 25 could be: successful in the prosecution. Page 158 1 MR. CRITTON: Form. 2 THE WITNESS: J asked him why he was 3 treating the case in the way that he did. 4 BY MR. GARCIA: 5 Q And what was his response? 6 A His response was that the victims weren't 7 credible in his mind. I don't know — I don't mean 8 all the victims weren't credible but some of the 9 victims weren't credible. He didn't believe that - 10 sixteen and seventeen-year-old victims, he told me, 11 Were — he said it Was the policy of the State 12 Attorney's Office not to charge molestation type 13 cases ,of even a sex type battery case when it was 14 consensual. His answer to that question was about 15 the merits of the case, i 6 Q So he told you it was the policy of the 17 State Attorney's Office not to; charge victims of 18 lewd and lascivious who were sixteen and seventeen 19 years old? 2 0 A Well when it was a consensual — I know 21 it's kind of a misnomer because they can't legally 22 consent to it, but he said when it was practically a 23 consensual situation it.Was their general policy not 24; to prosecute those kinds of cases, yes; 25 Q .But these victims were willing to press Page 160. 1 Q Did he show you any of the Facebook pages 2 that he had considered? 3 A He did not; 4 Q You said when he presented this case to 5 the' Grand Jury he gave you sonic explanation as to 6 - why he presented it that way. Did your detectives 7 and investigators, were they subpoenaed to appear 8 before the Grand Jury? 9 A At least one: detective was, 10 Q You know who that was? 11 A I have to ask my lawyer the question of 12 whether or not I can answer that because Grand Jury 13 material, I know, always remains sealed. I don't 14 know ifl do something;improper by identifying that 15 person alone without — I don't know what they said, 16 I wasn't in the Grand Jury. 17 Q, I think'the tcstimony would remain 18 privileged of confidential, but the Grand Jury did 19 :return an indictment; is that correct? 20 A That's my understanding,yes. 21 Q So I'm not asking you; to — you don't have 22 access to the testimony I'm assuming? 23 A Thal's correct. 24 Q I'm just asking you for the identity of 25 the person who was subpoenaed to appear before the 4 0 .(Pages 157 to 160.) Pleasanton, Greenhill,- Meek and Associates 561-8.33-7811 CA/Aronberg-000803 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • Page 157 1 BY MR. GARCJA: 1 2 Q Did ycm think that-- Were you aware oi; 2 3 ,did you become aware at some poinl that Mr: Epstein 3 4 Was a cqµtributor lo the q~l_llqc,ratic party? 4 5 A Y~. s 6. Q Are you aware that'Mr. Krischer has ties 6 J (q tlw democratic pa:rtyJ 7 8 MR. GRJTION: Form. 8 9 THE \VrTNE_SS: Yes. 9 10 BY MR. GARCIA:, to n Q Did you suspect at any point in, time that 11 12 there wa:s,a connection.betWeeriMr: Epstein's 12 13 political connectionswitb the democratic'.party and 13 14 'J\Jlr. Krischer's refusal or neglect to prosecute in 14 15 tfiis case with the zeal he should have pursued it is 16' with? 16 n MR. CRJTTON: Form, 17 18 THE WITNESS: 1 didn't allow myselfto 18 19 explore that. 19 20 BYMR.GARCIA: 20 21 Q Did you bay~ any.discus:;ions With Mr, 21 22 Krischetabout tha_t issue; whether ornot 22 2 3 ,Mr. Epstein was receiving fa\'.Orable treatment from 23 2 4 the Statc·,Ai:torncy!s Office because of Mr. Epst¢in's 2 4 25 politicalconnections? 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 i. 6 17 18 19 20 21 22 23 24 25 Page 158 MR. CR1TtON: form. THE WITNESS: J asked him why he was treating the case 'in the way that he did. BY MR. GARCIA: • Q _ffi1d 'Yl1a_t was his re~po.n~e? A His response wa·s thaflhe victims werei1't credible in his mind. I don't know --J don'tmean i 2 3 4 .5 6- 7 all'thc' victims weren't credible butsorrie of the 8 victims weren't credible: He didn't believe that-- 9 sixtee11 and seventeen-year0oJd \,'ictims, he told ITit:, 10 were -- be said itwas the policy of the :state • t1 Attorney's Office not to charge molestation type 12 cases ,ore:ven a sex type'battecy case when it was 13 consensua"L • His answer to'that question was about 14 the meri_ts of the cc1se, 15 Q So he told you it was the policy of the i E;i State Attorney's Office .not to charge·victims of 1 7 lewd and lasci_vious Who were sixteen ano seventeen 18 years old? 19 A W¢11 whcn1itwas a co11scns,1.1al ~~ !know 20 it's.kind of a misnomer because they can't legally 2i consent'to it, bllt he said when it was pra9tically a 22 co1tsensua:l situation it was their genera] polii::y not 2 3 to prosecute those kinds of cases, yes. 2 4 Q .But these victiinswerc willing to press -25 • I Page 159 criminal charges against Mr. 'Epstein, correct? MR. CRJTIONi fonn .. THE WITNESS: Yes. BY MR. GARCIA; Q: This is nota.siti.1ation where there Was, maybe a boyfriend/girlfriend situation, an age difference and th:e ,;;icti111 wa:;; rjqJ ¢liopetatingin the investigation;h that correct? MR, CRITTON; Form. THE W'rtNESS: That's correct: ,BY;MR.GARCJA': Q Pid yoµ cbaHen_ge hirr1 on that issue? A" Yes. Q At1d what wa.s his response? A He continued to,reiterate that the case, that itwas.his.ethical obligation. And he hadtold me thi_s b~fore about other Ci!Ses that we h!!.d discussed, Palm Beach Police,Department,cases and other cases, th;it.he has an_ ethical:responsibility to. feel -- to be reasonably certain that the case 'is winnable before he prosecutes it .And he said.that because of,all ofthos·e reasoris.and others ihVol'vi11g 'some of the reputation and Facebook pages and so on of c:_ert~in vicj:ims,. tha( he c:ouldn'tfeel that he c.ould be·successi'ul in:the prosecution, Page 160. Q Did he show you any of the Face book pages that he had considered? A He did not Q You said when.he presented this case to 'the' Grand Jury _be ga_\'.t; yo_µ son1e explanatiop as to why he presented It that way. Did your detectives ;and investigators,.were they subpoenaed to appear before the Gn1nd Jury? • A Atleast one:detect1ve was. Q You kne>w wh:o that \\'a~? A lhave to ask my lawyer the question of -whether or not I can answer thatbecause Grand Jury :material, I knoW, always remains sealed. I don't 'know ifl,do something:improper'by identifying that :person alon.e without -- .I d_gn't know what tiley said, l wasn't in the-Grand Jury. - Q. T think the tcstimony'would remain privileged or eonffdeniial, butthe Grand Jury did :return an i·ndictment; is that correct? A T}:tat's Ill)' @ders,ta11ding,_yes. Q. :So I'.m not asking you to -- you don't have accc~s 'to th~ testimony I'm ass!,)llling? A That's correct Q I'm just asking_you:for the identity of ·the person who was subpoenacd to appear before the 4"0 { Pages 157 to 160.) Pleasanton, Greehhi'Il, Meek and Associates 5,6'1-8.33-7811 CA/ Aronberg-000803 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Page 18 6: IN THE FIFTEENTH JUDICIAL CIRCUIT COURT IN AND FOR PALM BEACH COUNTY, FLORIDA CASEN0.: 502008CA037319 XXXX:MB AB B.B, Plaintiff, vs. JEFFREY EPSTEIN, Defendant._1 VOLUME II VIDEO-TAPED DEPOSITION 01 MICHAEL REITER A WITNESS TAKEN BY THE PLAINTIFF DATE: November,23, 2009 TIME: 10:12 a.m. - 7:38 p.m. i Page 188 1 .2 . 3 4 -5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2.5 Page 187 1 1-N^D-ErX 2 November^,7009: 3 MICHAEL REITER. 4 DIRECT CROSS REDIRECT RECROSS 5 By Mr. Kuvin 8 352 6 By Mn Garcia 155 364 7- By Mr: Crittoii 190. 8 9 10 EXHIBITS 11 Marked 12 Plaintiffs Exhibit No. 1 16 13 (Palm.Beach PD Intelligence Rcpdrtli/28/04) Plaintiffs Exhibit No.'2 31, 14 (incident.Reports) Plaintiffs Exhibit No. 3 99 15' (Letterto Baiiy Krischer) Plaintiffs Exhibit No/4 131 16 (Photographs of.El Brillp Way) Plaintiffs Exhibit Nd. 5 132 1'7 (Photo of358 El Brillo Way) Defendant's Exiiibit'.No. 6 218: 18 (Subpeona Duces Tecum) Plaintiffs Exhibit No. 7 .356. 19 (Money Transfers) Plaintiffs Exhibit No. 8 357 20 (Flight Summary) 21 Certified Question:: Page 160, Line 10 22 •23 2$ Lettef to John Randolph,.Esq.: 25' ErrataSheets (to be forwarded upon completion) Page ,189 1. The:dep6siti6n of MICHAEL REITER, a withess:ih’the 2 above-entitled arid numbered cause wastriken before/me. '3 Vanessa G Archer, Court Reporter, Notary.Public forthc 4 . Staie ofFlorida at Large, at 2925 PGA Boulevard. Palm Beach \ 5 Gardens,.Florida, on the 23rd day of November? 2009, 6 pursuant to Notice in said causeifor the taking ofsaid 7 deposition oh.behalfofthe Plaintiff. a i 9 APPEARING ON BEHALF OF PLAINTIFF B;B.:: 10 SPENCER T. KUVIN. ESQ. EEOPOLD-KUVIN.P.A. 11. 2925 PGA Boulevard,'Suite 200 Palm Beach.Gardens,Florida 33410 12 13 APPEARING ON BEHALF OF PLAINTIFFS’ JANE DOES 2-8: ; 14 ADAM HOROWITZ. ESQ: MERMELSTEIN & HOROWITZ. P.A. 15 18205(Biscayne Boulevard. Suite 2218 16 17 APPEARING ON BEHALF OF PLAINTIFF: C.A. 18 JACK. HILL,ESQ. SEARCY. DENNEY, SGAROLA. BARNHART & SHIPLEY. P.A 19 2139' Palm Beach Lakes Boulevard West Palm Beach. Florida 33409 20 21 APPEARING ON BEHALF OE PLAINTIFF: 22 ISIDRO .GARCIA,.Esq’. GARCIA LAW EIRM; P.A. 23 The Harvey Building 224 Datura Street, Suite 900 24 West Palm Beach, Florida 33401 25 1 (Pages 186 to 189) Pleasanton, Greenhill, Meek and Associates; 561-833-7811 CA/Aronberg-000804 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY 1 2 3 4 5_ i; 8 9 10 11 12 13 14 16 18 19 VS. • Page 186 TN TJIE FIF:TEENl'.i-l JODiCIAL CfRCUiT COURT IN AND'FORP,ALMBEACH COUNTY, FLORIDA CASE NO.: 502008GA03 7319 XXXX,MB AB Plaintiff, JEFFREY EPSTEIN, Defendant. -----------------'/ 1 2 3 4 ,5 6 7 8 9 10 111 1,2 13 14 VOLUME II VIDEO-TAPED DEPOSITION OEMlCHAELRElTER. 15 A WITNESS TAKEN BYTHE PLAINTifF DATE: .November, '23, '2009 TIME: 10:12 a.m. - 7:38 p.m. ·[-N°D~E,X ·Novembcr:23,:2009: MICH/\EL RE_ITER DIRECT CROSS REDIRECT RECROSS By·Mr. Kuvin 'By-Mr. Garcia 8 352 155 364 By'Mr. Criltori I 90. EXHIRITS _Marked Plainiifl's Exhibit No. 1 I 6 (I'~hn:&;ch PDb1tcUigcncc Rcportiit28/04) Plaintifl's Exhibit No.'2 3 I (Incident Reports) Plainiifl's Exhibit No. 3 99 (i:etter,to Harry krischer) Plaintiffs Exliibit NoA. 131 (Ph<?tographs of.El Brillo Way) .Plaintiffs Exhibit No. 5 • 132 (Photo of358 El_ Brillo \yay) Dcfei1diint's Exhibil'.No. 6 218 (Subpeona Duces Tecum) Plaintiti's Exliibit-No. 7 S56. (Money·Transfers) Plaintifl's Exliibi!No'. 8 357 (Flight Sun1iliary) Ccnificd Q,,csiion:; Page' I 60; Line I 0 Letter to John Randolph. Esq., Errata-Sheets (to be fmwarded uoon comoletiori) Page iB7 16 17 18 19 20 21 ~2 23 24 ?5 1. 2 '3 4 5 6 7 8 9 10 lL 12 13. 14 15 16 17 18 20 21 22 23 24 25 • Page 188 Pa9e Hj9 Jhe:deposition of MICHAEL REITER. iiwililess iil'the above-c1itiilcd arid nwnbcred cause was'taKcn bcfore:me. Vanessa G. Archer. Court Reporter, Notary:Public for,the Staie of.Florida at Large, at 2925'PGA Boulevard, Palm Beach .Garden~,.Florida, <m tjle 2_3rd clay ofN_ovenil;ier;· 2Q09, _pursuant to.Notice in said cause•for.the taking of said deposition on.behalf of the Plaihtiff. API$AIUNG.0N BEHALF .OF PLAINTIFFRB.: SPENCER T KU\llN, ESQ. l'.EOPOLD-KUVlNYA 292S:PGA Boulevard.=Suite 200 P.~lni Behch Garden;)iorida 3341 o APPEARING ON BEHALF OF PLAJNTiFFS' JANE DOES 2-8: ADAM HOROWITZ, ESQ:. MERMELSTEIN & HOROWITZ, tA .. 18205,_Bis~ay!_le Boulc-:ard ~uite_2218 Miami,-Floiida·J3 l 60 APPEARING ONBEHALF OF.PLAINTIFF, CA JACK HILL,.ESQ. SEAR'cY. DENNEY, SCAROLA. BARNHART & SHJPLEY. P.A 2139· Palm Beach Lakes Boulevard \Vest Pal~ Beach, Fiorida33409 • .APPEARINGDN irnHALF OF PLAINTIFF: ISIDRO .GARCIA,.Esq: GARCIA LAW EIRJvl; P.A. The Harvey Building 224 Daiura Street, Suiie'900 West Palni ri~ach, Florid~ 33401 1 (Pag,es 186 to 189) Pleasanton, Greenhill, Meek and Associates: 5p1-833-7811 CA/Aronberg-000804 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Page 298 1 , Q You're talking about alittie over a year,. 2 a dozen or so communications between at least calls 3 ’ to or from Ms. Villafana to you? 4. A Right. 5 Q What are we talking about? 6 A Do you want me to guess about thenumber? 7 Q No, I asked for your best estimate and you 8 said approximately.a dozen calls. 9 A The. best estimate is a guess in this case. 10 Q So what did you do, did you call up arid 11 say what's going on with regard to the Epstein 12 matter? 13 A Sometimes when.we hadn't.heard from them 14 for months or when.Detectiye Recarey would call the 15 EBI .and the EBI would say I’m not - 16 Q Oh, Em sorry, he has to change the tape. 17 THE VIDEOGRAPHER: We're off the record al 18 5:50. This is the end of tape 5. 19 (Off the record) 20 THE VIDEOGRAPHER: We're back on the 21 record at 5:58. Thisds the beginning of tape 22 6. 23 BY MR. CRITTON: 24; Q Mr. Reiter, has there ever been an 2 5 occasion, another, occasion, when you've been the ' Page 3.00 1 with.them that,you were disappointed with the manner 2 in which the State Attorney had prosecuted or had 3 handled the Epstein matter? 4 MR. HILL: Objection, asked and answered, 5 MR. KU VIN: Twice, join. 6 THE WITNESS:: Yeah, I don't know that I 7 used that exact word. I didn't feel as though 8 justice had.been sufficiently served. 9 BY MR,CRITTON: 10 Q Had there ever-been another instance^where 11 the State: Attorney had either, filed charges, had 12 gone to a Grand Jury, as they did in the Epstein 13 case, and then you subsequently contacted either the 14 EBI or the U.S- Attorney's.Office and/or they 15 contacted you? 16 A. I'll try to stay, with you better this 17 time, Could you — 18 Q In this particular instance Mr. Krischer 19 took the Epsteimcharges, or the allegations, to a 20 Grand Jury, the Grand Jury came back with an 2.1 indictment and he subsequently was arrested. You 22 subsequently had contact with the EBI and the FBI 23 and the USAO did their own independent 24 investigation, correct? 25 A Yes; Page 299 1 Chief, when you were Chief of Police, where you went 2: to the EBI and/or the EBI called you about pursuing 3 a prosecution because you felt what the state’had 4 done was not adequate or not acceptable to you? 5 A No. 6 Q This: was’ the first and only occasion, 7 correct? 8 A Well that was kind of a complicated set of 9 situation, circumstances. But what you described, 10 this is the first time that I was not — didn't 11 think thatjustice was sufficiently served and that 12 the EBI contacted me to initiate an investigation. 13 That unusual thing, yes, that's true. 14 Q And in fact you were in large part relying 15 on the report thathad been done in the 16 investigation thathad beemdone by the Palm Beach 17 Police Department? 18 A Yes, 19 Q; Had there ever been an.occasion where — 20 let me strike that. 21 At any time, did you tell the EBI not 2 2 to discuss the case with the State Attorney's 23 Office? 24 A No. 25 Q Did you tell the FBI when you first met Page 3,01 1 Q Had you ever had another circumstance like 2 that during the time that you had been the Chief or 3 the Assistant Chief or a police officer for the Town 4 of Palm Beach; that is, where the State:Attorney had 5 filed either charges that you didn't agree with,or 6 - had taken it to a Grand Jury. Grand Jury had come 7 back and had returned, an Indictment and then you 8 went to the FBI or the FBI contacted you, or was 9 this the first'and only occasion? 10 A This was the first.occasion in which I 11 ever had a case go to a State Grand Jury that wash't 12 a homicide. There have been-other instances that 13 the case bogged down in the state prosecution and.it 14 was clear that the most appropriate place to be 15 would be a federal prosecution. And the case was 16 eventually investigated by the FBI or the DEA or the. 17 Secret Service or somebody being: prosecuted by the 18 US Attorney. 19 Q In that particular situation though, did 20 the state-work— the State Attorney's Office work 21 with the FBI or the U.S. AO's office to bring the 22 federal charges because it got bogged down ;in the 23 state investigation and/or process? 24 A Yes, typically that's how it would go. 25 Q So the state was then actively involved 29 (Pages 298 to 301) Pleasanton, Greenhill, Meek and Associates 561-833-7811 CA/Aronberg-000805 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • Page 298 l Q You're,talking abouta:Httle over a year,. 1 2 a doz~n or so com1J111nic;atioI1s bet\yt:e_n at Jeast calls 2 3· to or from Ms. Villafana to you? 3 4 A Right. 4 s Q What are we talking about? 5 6 A Do you want me to.guess aboutthe·number? 6 7 Q _No, I ask~Q fgr your best estimate and yoµ. 7 8 ·said approximately-a dozen calls. • 8 9 A The.best estimate is a guess in this case. 9 1 o Q So what did you-do, did you tall up artd i () :11 say what's going onw!th regard to the Epstein. 11 12 matter? 12 ·13 A Sometimes when:we hadnifheard from them 13 14 for.months or whenDt:tective Rec:arey woµld call the 14 15 EBI _artd the EBL\voi.lld say i'mnot-- 15 16 Q Oh, I'm,son-y, he has to change the tape. 16 1 7 THE VIJ)E0G.lu\f>HE_R: We're o,ffthe rec:ord a 17 '18 5:50. This is the end of tape 5. 18 19 (0ffthe record) 19 20 THE V[OEQGRAPHEit We'je back.on the 20 21 record at 5:58. This'1s·the beginning of tape 2.1 22 6, ;t2 2 3 BY MR. CRITTON: 2 3 2 4 Q Mr. Reiter, has th~re evefbt:en an 2 4 25 occasion, another occasion, when you'Ye been the is 1 2: 3 ':I 5 6 7 8. 9 10 11 12 13 14 15 Hi. 17 18 19 20 21 22 23 24 25 P'age :299 Chief; when yoi.1 were Chief of Police, where you went 1 to the FBI and/orthe FBI called you ~bout pursuing 2 a prosecution because you'felt ',1/hat tl:ie state'.had 3 done,was not adequate or not acceptable to you? 4 A No. 5 Q This was' the first and only occasion, fr correct? 7 A Well thatwaskind of a cpmplicated set of .8 ·situation, circumstances. But whatyou described, 9 this. is the first time that I :was not -- clic:ln't 10 think that justice was sufficiently served andthat i 1 the,,EBicontacted me to.initiate an investigation. 12 'Thgt 11n11sual tl;Ling, y~1_,, tha't'_s true. 13 Q And in fact you were in large part relying 14 qn the report thathad been done in the 15 investigation that-had been;dorie by the I'alm Beac:h Hi .Pofice.Department? 1 7 A Yes. 10 Q; Had there ever been an. occasion where -- 19 l~t me strike that. 2·0 -At any time, ,did youteH the FBI, not 21 to discuss the case with .the State Attorney's 2-2 ·Office? 23 A No. 24 Q Did you tell the FBI when you first met 2 5 • Page 3.00 with. them that you were disappointed with the manner )n 'YQich tti.e SJ13te Aitorpey had pro;,ecuted or hacl :handied the Epstein matter? MR, HILL: Objection, asked and answered, MR. KU VIN:- Twice; Join. THE WITNESS: Yeah. I don'tknow than used thatcexact \vor__cL I didti't (et:! as th9tigh justice had.been sufliciently,served. BY MR,. CRITTON; Q Had there ev.er bt:eii another inStance,where the State:Attomey had either. filed charges, had gone to a Grand Jury, as they diclin the Epstein case, and then you:subsequently contacted either the 'FBI or.the U,S. Attorney's.Office and/or they .contacted you?· A I'll try to stay with you better this tiiile. Cplild ygu -0 Q: ln. this particularinstance Mr. Krischer took'th(! Epstein:ch13rges, or t!w allt!gation~,-to a ·ornnd Jury, the Grand Jury came back with an indictment an:d he subsequently was arrested. You subseqiJent!y'ha<:1 contact With the EBi ancf the FBl •and the USAO did thdr own independent inves_tigation, ,correc;t? A Yes, Page 3,01 Q Had you ever had another circumstance like ·that during the time that you bad been the Chief or ·the Assistant Chief or a police officer for the Town ofPalm Beach; that is, where the State Attorney had :filed either charge~ that yoll didn't agree with.or had taken it to a Grand Jury, .Grand Jury .had come back. and had returned. an :indictment and then you ·wc:n(to the· FBI cir the FBI contacted you, or-wa:s this· the 1irst'and only occasion? .A This w.;is the _first.occasionjn whigh l :ever.had a case go to a State Grand Jury that·wasi11t a homicide, There have bee□' other instances that the case 1,ogged down in the state prosecutipn and.it was dear that the most appropriate piace to be ·would.beg fed_eral_prqsec:ution. Alld th.le cast: wa,s eventually investigated by the FBI or the'DEA or the Secret Service or somebody·being:prosecuted by the US Attorney.. • • Q In that particular situation though, did the stat~•wor;k-s th~ StaJ<:, Attomey!s Office \york with the FBI ot the U.S. Ab's office to bring the fed.era! charges because it gqt b9gg~d dmyn 'in the stat¢ investigation and/ot proe~ss? A Yes, typically, that's hoW it woufd go. Q So the stale wa:s ·then actively involved 29 (Pages 298 to 301) Pleasanton, G:te.enhi'Il, Meek and Associates 5:6·1-8,33-7 811 CA/ Aronberg-000805 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Appendix 5 CA/Aronberg-000806 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Appendix 5 CA/Aronberg-000806 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM TOWN W PALM BEACH POLICE DEPARTMENT A NATIONAL AND STATE ACCREDITED LAW ENFORCEMENT AGENCY May 1, 2006 PERSONAL AND CONFIDENTIAL Mr. Barry E. Krischer, State Attorney Office of the State Attorney Fifteenth. Judicial Circuit 401 North Dixie Highway West Palm Beach, FL 33401 Dear Mr. Krischer, Please find enclosed the probable cause affidavits and case filing packages thus, far resulting from the Palm Beach Police Department’s investigation of Jeffrey Epstein, Sarah Kellen and Haley Robson. The submission of these documents are both in response to Assistant State Attorney Lanna Belohlavek's request for them and to serve as the Palm Beach Police Department's presentation for prosecution. I know that you agree that it is our shared responsibility to seek justice and to serve the public interest by discharging our duties with fairness and accountability, I must renew my prior observation to you that I continue to find your office's treatment of these 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 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. Sincerely, Michael S. Reiter Chief of Police MSR:nt 345 Small County Road 07/26/17 Palm Beach. Florida 334X0-4443 •- (561) H3X-54604 Fax (561) X15-4700 ■www.parmbeachpolicexoin

Page 5 of 120 Public Records Request No:: 17-295 CA/Aronberg-000807 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • A NATIONAL A'.ND STA TE ACCREDITED LAW ENFORCEMENT AGENCY May 1, 2_006 PERSONAL AND CONFIDENTIAL Mr. Barry E. Krischer, Stat1:1 Attorney Office of .the 'StatE3 Atto_rney Fifteenth. Judicial Circuit 401 North· Dixie· Highway WestPalm.Beach; FL 3'3401 Dea..r Mr. Krischer. Please find enclos·ed the prc;>l::lcJble c-ause affidc1_vits ar1d case fiiing packages .thus. far resulting, from the Palm Beach Police Dep~rtmehfs i,nve~tig~tion ofJeffr~y E:p~te.in, Sarah Kellen and Haley Robson. Th·e submission ofthese documf;ints· are bottfi!'I re~ponse to Assistant State Attorney Lanna Belohlavek's requestfar themand to serve as the Palm Beach :Police Department's presentation for prosecution. I know that you agree that it is our· shared respcm_sibility to seekjtJstice and to serve ·the public interest by discharging our duties with fairness and 'c!Ccoun.tabillty.J mu.st renew rny prior observation to you that' I continueto·find your office'.s treatment ofthese cases,highly ur:,usµal. It i~ regrettable that I am·forced to communicate in this manner but my most recent teiephone call_s to you and those of'the lead detective to your assigned attorneys have oeen unanswered ari.d messages remain unreturned. • After giving this much thought and consideratio11, I must urge you to e><amine the unusual course that your office's handling of this matter ha$ taken ari9 cor:15.ider if good arid sufficient -reason exists to require your disqualification from the prosecution of these cases. MSR:nt Sincer:ely, Michaels. Reiter Chief of Police 34~ .Sm,rh County Road • Palm Bca<:h, f;l11riua 1~1480-444.l , (5(>1) 1!1k-54i',O-, F:n '(5h OH 15-47\)0 •, ww~.palm),cachpolice,com 07/26/)7 Page 5:of 120 Public Records Request No:: 17-295 CA/Aronberg-000807 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM OBTS Number .ARREST / NOTICE TO APPEAR juvenile Referral Report •' .' AumiTmiS tHAiivt- AgencyORl Number • aoi 5 0 ,0161b 0 ; AgencyName. PALM BEACH. POLICE-DEPARTMENT Cha^P Type;, .felony, □;3/ Misdemeanor ’ □5: Ordinance S’ap^y'^3^ Q 2-> Foiony 04. Traffic Mkt^meano' O ‘6l Other Lqcat'onol Anest:(lnciuding Name^ Business) " • < DaieoJ Hame^Usi,-F‘rs!.M«Mie); .1. Arrest 3/Request ior?Warrani . * 2. NTA. . 4.;Reqwsl tor Cap^a : i^ncy,Report Number.(N.TA?^^ Juvenile H Weapon Seized?5" T Enter type ’ ■ 1 - 1 i 1 / Multiple CleerariceK ,$ Indicalor: r j . , /^cationo! Offenses (Business Name/Address)?/^ • ’ YY 7 ’ i’F* e.c M*? y Time'o! Aries! : i r.- Booking Date' Boohing Time: 1 Jail Date' JaifTtme1 Location dtvenicir . , Alias (Name/D< Race- ' . . ■ - □- - ,• wu-’WMa 'i;- Amencan indanp. B-. BiacX ? • O - OrieintaVAsian j ?: pate di Birth^; L 1 - He^pl s { Weight-- i cyA.Cdlor Y_ . ■! Lp!C.. Complexion lion'; - Marital Status ; Religion: ScarshMa^> Tattoos. Unique Physical Feaiufes Indication ok. Alcohol Influence *.-- . ’ > OfUQlnfluence; ’□ O ’Cr Local Motas (SlrMi.'-Aot: NumbarK-, i>. . . f . r, -CM,. ■ . slSinoir • • (Zio) . . Residence/type; - • /i^City,-* • :3?Fiorida.. 1 ! 2. County '.a^Out of Stale. | PermaneniAMress(Slre«l,^>I.Nvmt»<J^-- <CitX>-r - ~-.(S(aja) - (zar phone? ( > .i Address Source — —-.- - ySw ' M1>’■ . ZtuM-"' Phone-• < )■ . ..: Occupation' - —- - • INS Number: Place pKBirth (City,- State)- C^iz^nshij’ ■ ’ D/UNumber,.State7: . Y4~c£>tvvWb &-p0eiWftf Name.fCasi.’Ft^ '• .- Race?" • Sew- ■Daleol Birth'- •’ "L Oy. Arrested. □?. Ai Large: ■’,Q3?Felony:-." - - iO 4, Misdemeanor . □SrUtiveW* ca-Defertani Ha<ae (laslfn^i;.^ Race • Sev Oai« 01 Bnh □t; Arrested ’ ’ □2/AiLarpo 03.Felony^ ■□A k Misderiteanor: 05; Juvenile .. 1 ' 3 Parent' - - • -Name(Last) 5-Logai Custodian j Other! .. . .-. . .... (FKSlU (Middle)'' Residence Phone " k 1. ' /WCrass (Street.' Apt. Number) ' " (CCyl, (Stale)’ Business Phone ; (? "i ’ ' J: TOT.JAC ' ' ’ Date? • - Time- ‘ The above aittess was provided by □defendant and ZorDdelendanrs-parenu. Thexhi^ and/orpireni was told.' " . to keepme Juvenile CourtClerks Office (fhb-ne 355-2526)Tntdrmed of any change cl address:. ' " .CTYesi byi(Name) " • □Ney (Reason); ' ? ‘ Property. Crime?' DYes..’ □No Description 6l Property;' SchbbiAnerided '-' .. ’ ■Grade. Value of Property - N: WA' 1 B. Buy .'D. Defiver - ' /Distribute ’PfOOy^ P/Pcssess -. T./Tianic* .. ■E/Use' ' * . r- -. ..Cultivate Charge tescriptiprtj/ DfugActiviY Oryg-Typp J 'Amount-/Unit • ‘O; ’ Kj'jc Offense * Counts ' Domestic? ;" XT ■'Violence- iO^^N ihai^Descripiipn; Counts// Domestic -.f . Violence,. DrugAcliv.ty DrugTyjpe Jryg Activity; Drug Type?- •harge Description ' Vug Activity1 OfugTypo 'ArnbunlZUfiib 'Amount ZUnii' Amount Unit■' j Tnsfruaio'h^ ' ’ /; ” , Mandatory Appearance in C^ ^Mnstnjcibri No, 2' Ycu,noeO not appMHn.Couri but .m^ comply with inslructions on-Reverse $do. . Offense/ Counts Domestic- Violence/ ... O T- ON Offense'* • - : Counts. ' Domestic < ■' ' Violence ' ; ; GLY’ D N [Offense^' OfugType ’ ‘.'B: Barbiturate : H.Halluanogen * P. Paraphernalia' ■:UcUnkn6wh- ;n;wA . • C, Cocaine :=M?Marijuana • .’ Equipment £Other A^Kmghelamin'^^^^Emtero^ ~.. * - Stetirte^fiafatioa Number t ’ Warrant ZCapias.Numbef S|£ruio.y^lai^;Nu^^ Warrani V Capas Number StatuteyoiatigriNumbbr WanantZCapiasNumber "■ - O/Opium/Deriv,; . S. Synthetic.' J.’'’."-' I in A . i(i i 1 1 Vkrtatign.btpRp-a? '■ ■ Bonar Statute'Violation Number- _L_'I 11 1 i 1 KI •Warrant ZCa^aS'Number," 'TyjdaiioaoTpRDjr” Bono Vrpiaiton of ORQ/' 1.1- Bondi’’' i i- - violation 01 ORO» • ’ : Bond' Location (Court, Room'Number, Address^ Court Date-arid T>me ’ - . - - Month. .‘Day-., . .. . -Year Time'- ,. -a:m. -P.M. iGREE TO APPEARAT-THEJIME ANDPLACEiDESiGMATED TO ANSWER THE OFFENSE CHARGED.OR TO^PAYTHE FinE SUBSCRIBED' I UNOERSTAnO ThaT SHOULDJ'WILLFUUIYTAII.TO ?REAR BEFORE-THE COURT AS REQUIRED BY THIS ^TlCE TO APPEAR,THATTMAY<BE HELD IN CONTEMPTOF.COyRT A^D A WARRANT fOR MYARREST SHA^ 1 'Sigrialwebf Defendant,(or/Juveifclea^^aren!/^^ < UDforptner Agency fme:. Signature’ 6l Ariesiii^dhicffr ■’ x' . ' . 7 /.A ' ) Dangerous' " r D;Rosisled Arrest' ItSuicidai. ' -n diher: ' _- - - -• Nameiof Arresiing Officer CPrint)-^' . .LD,^ ' \ n"' jo"-* c v y He’Oeputy: " .'l.03»i Pouch 'Transporting Officer?' 1 Agency.' j- . . ... .■..... - (PRINT}' Witness here if subject sigriec.wilh an ’X' DateSigned- .Name’Verifi&|iGri;(Rri^ /PAGE; jOE. DfSlRI^TlONt .WHITE -^COURT-COPY GREEN;—‘STATEAHORNEY.: YELLOW.:— AGENCY PJNK’.—JAK- ; GOLD-1DEE ENDANT '(N;EA ;s .ONLVj CA/Aronberg-000808 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • . C)BTS Number ,. ,ARREST/ NOJ<ICE/f() fiRPEAR,. ' - •• I i I 'i· +. I j. ' "' .. ... . JlivenilfReiiifoal'R&po_rt-;, • .. Nam~ 11:as1) 'Property.Crim•.?· .,O_es~. p.1lo~ii\!'1pperty_·_ .. • ,_ .. CJY'is. O!io __ J··1n~~(Utpo-n=No)1· . _ '-:~~~~o~ .(~(?y11, ~?om ~~(!ltje_r. "Adg!!Ssf • . J~a!".(fa16,Y ~arenc~flfC_ou!l J{1nstructirill No, _2-· . . . - . • .i:A.u0$i ,21-1i..i.'. -~_CMO_I Anended ' ,. I (I' '.'30rqu95t ~O!.,Wairan1· ll~I io,'i;:aJlia 101; AIT8SIOO O2..-Alla•oo _; i ,, I • Res_iger.ce. PfM?ne, -- • ~~•~!~s-Ptibne_ (, i -· Violation ol ORO ••• l ,_ ·.. •. .. •• • Violation ol ORD,. n ,... . . . ·,YtU_noe-:t.nOJ"apperi,,ir\_Coun:bu(riitisl _ Coury Qau(·a~ f'r.e. oo_~p~•wllh-in~t1~51i~!:1~."orf~.e\'e~e S.oo. MO,fol_ ·Oa,,_~ -YO"a/ Time~, _~;.:M. .,P,M. 1GREE TOA.PPEAA'AT •THE.TIME ANO.PI.ACE'DESIGtiATEO TO ANSWER THE OFrENSE CHARGED ORTO'PAY,THE·FltiE SUBSCRIBED' t UN0Ef1STANO·THAT•SHOULD IWILLFU~lY.FAil:. TQ >PEA~ BEFOR_E THE C!)URT•AS RE<lUlflEI? (lY THIS NOTICE 1:9 AP~!c~R,:THATJf,A~Y:jlE /'§LO It-/ CON!E.MPT;c:J_r y9._~RT/ND~ WJ\RR,\t;rFOf'! ":IY ~RRf,ST ,SHm,Bp.lSSUEO. • •• ;~[) I~! ~!her AQern:y liig~a1ur~Jil.o;ne~it.1i-.flll'7P, •• ', i'rne:_. x· .. , .,.,•·•,l ·:.-.~-~-k,d-!J-.i-~.--u•-. _....,c,... "';:g-·_"':""&"'t"":'"s.:_ed.,.: ,..,~,..,,-•.• -.i-·· -----------,+.~,-,t--;-,{--~-~:-, ::-·:·'..es""_'"'.~-,)~gJ~:,:~-<,"'i-~""~Pt~ __ .,.~,,.)""z"':t_l __ l-;~-~-7-]i,-;-.~-:--J'"---.'" ... '"t"',:~-f...,:r'"•c---.,,-i·:' • (i>R1i-ir1. l_SfOeii<,ty • •W .. j' .. '."Pou· ... en· Tra~SIX)niog ?ff)ter!' I Clc'i • ~•r>:y. :f · . .,w1~n~.~~e. ir_ su~~;-~_sig~~*w!ll'I ~~ ~~:-. CA/Aronberg-000808 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM '. Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 Police Case#: 05-368 (1) Defendant: Jeffrey Epstein Race/Sex: White Male DOB: 01-20-1953 Charges: Unlawful Sexual Activity with a Minor (4) counts Lewd and Lascivious Molestation From March 15, 2005, through February 2006, the Palm Beach Police Department conducted a sexual battery investigation involving Jeffrey Epstein, Sarah Kellen and Haley Robson. Sworn taped statements were taken from five victims and seventeen witnesses concerning massages and unlawful sexual activity that took place at the residence of Jeffrey Epstein, 358 El Brillo Way, Palm Beach. Several of the victims were recruited by and brought to the residence by Haley Robson to perform massages for Epstein, for which Robson received monetary compensation. During the visit they would be introduced to Sarah Kellen, Epstein’s assistant, who in turn would record their telephone numbers and name. The victims would be brought to Epstein’s bedroom to provide the massage. Epstein would enter the room and order the victims to remove their clothing to provide the massage. As the victims complied and provided the massages, Epstein would rub his fingers on their vaginas. On occasion, Epstein would introduce a massager/vibrator and rub the victims vaginas as they provided the massage. On three separate occasions, Epstein had intercourse and inserted his penis/fingers in the victims vaginas. At the conclusion ofthe massages the victims were paid sums of money ranging from $200 - $1,000. The facts, as reported, are as follows: On 03/15/2005, A fourteen year old white female, hereinafter referred to asM^^dobtf^mi^^^hnd her family reported unlawful sexual activity which occurred at a residence within the Town of Palm Beach. reported that a subject known to her as “Jeff’ had touched her vaginal area with a vibrator/massager while within his residence. “Jeff’ was later identified as Jeffrey Epstein through a photo line up. During a sworn taped interview^ltated that Haley Robson, dob 04/09/1986, a cousin boyfriend and classmate at^^^^^^n^^H^worked for a wealthy man and did sexual favors for him. She also admitted that Robson had offered her an opportunity to make money. During the beginning of the montl^’February 2005,®^fexplained that she was first approached by Robson to go with her to Epstein’s house. W^Ftated that Robson along with a Hispanic female, later identified at^H^m^^iickher up at her father’s house on a Sunday, ^^/as not sure of the exact dates but knew it was a Sunday. ^£lold her father that they were going shopping but in reality Robson drove them to Palm Beach. During the drive a The foregoing instrument was sworn to or affirmed before me this lsl day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida County of Palm Beach Signature/A^stingOfficer Date: 05/01/2006 I CA/Aronberg-000809 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY Defendant: Race/Sex: DOB: Charges: • • Probable Cause Affidavit Palm Beach Police Department Jeffrey Epstein White Male 01-20-1953 • Agency ORI# FLO S00600 Police Case#: 05-368 (I) Unlawful Sexual Activity with a Minor (4) counts Lewd and Lascivious Molestation From March 15, 2005, through February 2006, the Palm Beach Police Department conducted a sexual battery investigation involving Jeffrey Epstein, Sarah Kellen and Haley Robson. Sworn taped statements were taken from five victims and seventeen witnesses concerning massages and unlawful sexual activity that took place at the r~sidence of Jeffrey Epstein, 358 El Brillo Way, Palm Beach. Several of the victims were rec~ited by and brought to the residence by Haley Robson to perform massages for Epstein, for which Robson received monetary compensation. During the visit they would be introduced to Sarah Kellen, Epstein's assistant, who in turn would record their telephone numbers and name. The victims would be brought to Epstein's bedroom to provide the massage. Epstein would enter the room and order the victims to remove their clothing to provide the massage. As the victims complied and provided the massages, Epstein would rub his fingers on their vaginas. On occasion, Epstein would introduce a massager/vibrator and rub the victims vaginas as they provided the massage. On three separate occasions; Epstein had intercourse and inserted his penis/fingers in the victims vaginas. At the conclusion of the massages the victims were paid sums of money ranging from $200 - $1,000. The facts, as reported, are as follows: On 03/15/2005, A fourteen year old white female, hereinafter referred to as•·•dob~d her family reported unlawful sexual activity which occurred at a residence within the Town of Palm Beach. ... reported that a subject known to her as "Jeff' had touched her vaginal area with a vibrator/massager while within his residence. "Jeff' was later identified as Jeffrey Epstein through a photo line up. During a sworn taped interview,atated that Haley Robson, dob 04/09/1986, a cousin o boyfriend and classmate at•••••••llllll■llltworked for a wealthy man and did sexual favors for him. She also admitted that Robson had offered her an opportunity to make money. During the beginning of the month of February 2005,~xplained that she was first approached by Robson to go with her-to Epstein's ho11se ... tated that Robson along with a Hispanic female, later identi~ed at~ick her .up at her father's house on a Sunday. atvas not sure of the exact dates but knew it was a Sunday. llltold her father that they were going shopping but in reality Robson drove them to Palm Beach. During the drive a The foregoing instrument was sworn to or affirmed before me this !51 day of May, 2006 by Det Joe Recarey, who is personally known to me. ,ignature of Police Officer (F.S.S. 117.10) CA/Aronberg-000809 Beach sting Officer FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 conversation occurred between Robson and^^whereas Robson reportedly told^bthat if Jeff asked her age, she should say she was eighteen. It was later confirmed by theOBBfather that Robson picked his daughter up on February 6, 2005. According tc^^fefather, Robson drove a pick up truck. ^^Bescribed Epstein's house as a two-story pink house with a Cadillac Escalade parked in the driveway. She recalled that Jeffs house was on a dead end street. Upon arriving at the houseOBstated that they walked up a driveway, past what appeared to be a small guard/security room. A male approaching them asking what they wanted. Robson stated they were there to see Epstein. The male allowed them to continue walking up to the house.B^tated the man told them that Epstein was not there but was expected back. He allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside Shortly thereafter, Epstein and his assistant, described as white female with blond hair and later identified as Sarah Kellen, entered the kitchen. Epstein introduced himself toMB OBdescribed Epstein as being approximately forty-five years old, having a long face and bushy eyebrows, with graying hair. Robson and Epstein left the kitchen leaving^^^lone in the kitchen. They returned a short time later. They all spoke briefly in the kitchen. ^|^vas instructed to follow Kellen upstairs. I^Becalled walking up a flight of stairs, lined with photographs, to a room that had a massage table in it. Upon entering the room there was a large bathroom to the right and a hot pink and green sofa in the room. There was a door on each side of the sofa, •■►ecalled there being a mural of a naked woman in the room, as well as several photographs of naked women on a shelf. Kellen told the victim that Epstein would be up in a second. Epstein entered the room wearing only a towel and toldflMo take off her clothes.MMstated Epstein was stem when he told her to take off her clothes.^Kaid she did not know what to do as she was the only one there in the room so she took off her shirt leaving her bra on. Epstein had removed his towel and told the^Bto take off everything. MBstated Epstein was nude when he took his towel off, placing it on the floor as he laid down on the table.I^^tated she then removed her pants leaving her thong panties on. Epstein then instructed her to give him a massage pointing to a specific lotion for her to use. AsBBbegan to give Epstein the massage, he told her to get on his back. ®Bstated she straddled herself on Epstein’s back whereby her exposed buttocks were touching Epstein’s bare buttocks. BBcaid Epstein was specific in his instruction to her on how to massage him, telling her to go clockwise or counter clockwise. Epstein then turned over and instructedOMto massage his chest. 4^^lvas now standing on the ground and resumed massaging Epstein’s chest area. B^htated Epstein held onto the small ofher back as she massaged his chest and shoulder area. Epstein then turned to his side and started to rub his penis in an up and down motion. Epstein then pulled out a purple vibrator and began to The foregoing instrument was sworn to or affirmed before me this 1st day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida County oTPalm Beach SignatJr£Wrrelsting Officer Date: ^701/2006 Pape7of 22 CA/Aronberg-000810 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 conversation occurred between Robson andililwhereas Robson reportedly tol.~hat if Jeff asked her age, she should say she was eighteen. It was later confirmed by the41-•father that Robson picked his daughter up on February 6, 2005. According t, C f ther, Robson drove a pick up truck. ..-iescribed Epstein's house as a two-story pink house with a Cadillac Escalade parked in the driveway. She recalled that Jeffs house was on a dead end street. Upon arriving at the house~tated that they walked up a driveway, past what appeared to be a small guard/security room. A male approaching them asking what they' wanted. Robson stated they were there to see Epstein. The male allowed them to continue • walking up to the house ... tated the man told them that Epstein was not there but was expected back. He allowed them to enter the house, via the kitcheri. He offered them something to drink while they waited inside. Shortly thereafter, Epstein and his assistant, described as white female with blond hair and later identified as Sarah Kellen, entered the kitchen. Epstein introduced himself to_.. a:Iescribed Epstein as being approximately forty-five years old, having a long face and bushy eyebrows, with graying hair. Robson and Epstein left the kitchen leavin~lone in the lcjtchen. They returned a short time later. They all spoke briefly in the kitchen. a.vas instructed to follow Kellen upstairs. taecalled walking up a flight of stairs, lined with photographs, to a room that had a massage table in it. Upon entering the room there was a large bathroom to the r_ight and a hot pink and green sofa in the room. There was a door on each side of the sofa. llllltecalled there being a mural of a naked woman in the room, as well as several photographs of naked women on a shelf. Kellen told the victim that Epstein would be _up in a second. Epstein entered the room wearing only a towel and told-..0 take off her clothes.'9stated Epstein was stern when he told her to take off her clothes. -.aid she did not know what to do as she·was the only one there in the room so she took off her shirt leaving her bra on.· Epstein had removed his towel and told the-to take off everything. 9stated Epstein was nude when he took his towel off, placing it on the floor as he laid down on the table ... tated she then removed her pants leaving her thong panties on. Epstein then instructed her to give him a massage pointing to a specific lotion for her to use. Asallabegan to give Epstein the massage, he told her to get on his back. ~tated she straddled herself on Epstein's back whereby her exposed buttocks were touching Epstein's bare buttocks. •aid Epstein was specific in his instruction to her on how to massage him, telling her to go clockwise or counter clockwise. Ep~tein then turned over and instructed~o massage his chest. ~as now standing on the ground and resumed massaging Epstein's chest area. -.lated Epstein held onto the small of her back as she massaged his chest and shoulder area. Epstein then turned to his side and started to rub his penis in an up and down motion. Epstein then pulled out a purple vibrator and began to The foregoing instrument was sworn to or affirmed before me this 1'1 day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) Paee2of22 CNAronberg-000810 State of Florida FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 massage^4 vaginal area, ^^stated there was no penetration as the vibrator was on top of her underwear. 14recalled Epstein ejaculating because he had to use the towel to wipe himself as he got off the table. Epstein then left the room andH^ot dressed. She went back downstairs where she met with Robson. <^aid she was paid three hundred dollars in cash from Epstein. Before she left, Epstein askedO4to leave her phone number. As Robson and400^4were leaving the house, Robson told4b she received two hundred dollars that day for bringing her. During the course of the investigation, parental consent was granted for4Bto assist with the investigation. At our direction14conducted controlled taped phone calls to Robson’s cellular telephone 561- 308-0282,4>spoke with Robson in an attempt to arrange another meeting with Epstein. ®4sked Robson, what did she need to do to make more money. Robson stated, “the more you do, the more you get paid.” Robson had subsequently called back^4^ left a voice ma^ message for her indicating that she had set up an appointment for^^^to go to Epstein’s house at 11:00 am on April 5, 2005. This message was recorded from 1^4 voice mail. Based on the above, trash pulls were established at Epstein’s residence with Supervisor Tony Higgins of the Sanitation Bureau of the Town of Palm Beach. The trash pull from April 5, 2005 revealed a telephone message for Epstein which stated Haley and49 name at 11:00 am. This was the time frame Robson had informed04 to be ready to go work at Epstein’s house. On October 3, 2005, Sgt Frick and I went to Robson’s residence and viewed her vehicle parked in the driveway, a red Dodge Neon. Sgt. Frick and I knocked on the door and met with Haley Robson. Robson was told that we were investigating a claim involving Jeffrey Epstein of El Brillo Way, in Palm Beach. Robson was asked if she would accompany us back to the police station for further questioning. She was also told that at the conclusion of the interview she would be returned home. Robson voluntarily came with us back to the Palm Beach Police Department. Upon our arrival at the police station, Robson was brought to the interview room in the Detective Bureau where I obtained a taped, sworn statement. I began the interview by asking Robson how she became acquainted with Epstein. Robson stated that approximately two years ago, just after she turned 17 years of age, she was approached by a friend named Molly at the Canopy Beach Resort in Rivera Beach. Robson was asked if she wanted to make money. She was told she would have to provide a massage and should make $200.00. Robson thought about the offer and agreed to meet with Jeffrey. The foregoing instrument was sworn to or affirmed before me this 1st day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida County of Palm Beach Signaiur&A/rr^sting Officer Date: \ 05/01/2006 Page3of 22 CA/Aronberg-000811 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 massage ... vagina] area. -stated there was no penetration as the vibrator was on top of her underwear. •recal1ed Epstein ejaculating because he had to use the towel to wipe himself as he got off the table. Epstein then left the room andll9got dressed. She went back downstairs where she met with Robson. 4'Psaid she was paid three hundred dollars in cash from Epstein. Before she left, Epstein askedllllato leave her phone number. As ··Robson and J b were leaving the house, Robson told-she received two hundred dollars that day for bringing her. During the course of the investigation, parental consent was granted for-to assist with the investigation. At our direction-conducted controlled taped phone calls to Robson's cellular telephone 561- 308~0.2~2 .. -spoke with Robson in an attempt to arrange another meeting with Epstein. a.sked Robson, what did she need to do to make more money. Robson stated, "the more you do, the more you get paid." Robson had subsequent]y called backemd left a voice mail message for her indicating that she had set up an appointment foI9to go to Epstein's house at J 1 :00 am on April 5, 2005. This.message was recorded from ... voice mail. Based on the above, trash pulls were established at Epstein's residence with Supervisor Tony Higgins of the Sanitation Bureau of the Town of Palm Beach. The trash pull from April 5, 2005 revealed a telephone message for Epstein which stated Haley and .. name at 11 :00 am. This was the time frame Robson had informedlllto be ready to go work at Epstein's house. On October 3, 2005, ·Sgt Frick and I went to Robson's residence and viewed her vehicle parked in the driveway, a red Dodge Neon. Sgt. Frick and I knocked on the door and met with Haley Robson. Robson was told that we were investigating a claim involving Jeffrey Epstein of El Brillo Way, in Palm 'Beach. Robson was . asked if she wou]d accompany us back to the police station for further questioning. She was also told that at the conclusion of the interview she would be returned home. Robson voluntarily came with us back to the Palm Beach Police Department. Upon our arrival at the police station, Robson was brought to the interview room in the Detective Bureau wbere I obtained a taped, sworn statement. I began the interview by asking Robson how she became acq.uai.Qted with Epstein. Robson stated that approximately two years ago, just after she turned 17 years of age, she was approached by a friend named Molly at the Canopy Beach Resort in Rivera Beach. Robson was asked if she wanted to make money. She was told she would have to provide a massage and should make $200.00. Robson thought about the offer and agreed to meet with Jeffrey. The foregoing instrument was sworn to or affirmed before me this 1•1 day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) Page.:3of 22 CA/Aronberg-000811 State of Florida County of Palm Beach FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 Molly (Unknown last name) and Tony (Unknown last name) picked Robson up and she was taken to Epstein’s house. Upon her arrival to the house she was introduced to Epstein in the kitchen of the house. She was also introduced to a white female known to her as Sarah. She was led upstairs to the main bedroom known to her as Jeff Epstein’s bedroom. Sarah arranged the massage table and covered the table with a sheet. She brought out the massage oils and laid them next to the massage bed. Sarah, then left the room and informed Robson Jeff would be in, in a minute. Jeff entered the bedroom wearing only a towel. He removed the towel and laid nude on the massage table. He laid on the table onto his stomach and picked a massage oil for Robson to rub on him. During the massage, Robson stated “He tried to touch me and I stopped him.” I asked how he tried to touch her. Robson stated that Epstein grabbed her buttocks and she felt uncomfortable. Robson told Epstein, I’ll massage you but I don’t want to be touched. Robson stated she performed the massage naked. At the conclusion of the massage, Epstein paid Robson $200. After the massage Epstein stated to Robson that he understood she was not comfortable, but he would pay her if she brought over some girls. He told her the younger the better. Robson stated she once tried to bring a 23 year old female and Epstein stated that the female was too old. Robson stated that in total she only remembers six girls that she brought to see Epstein, each time she was paid $200. Robson stated she had brought the following girls: (a 16 year old female),^^(a 16 year old female) and Robson said thal at 1116 time she brought 111650 Sirls t0 Epstein’s house they were all 14 through 16 years of age. I asked Robson which one was the youngest. Robson advised ^^►was the youngest as she was fourteen when the massage occurred. Robson stated every girl she brought knew what to expect when they arrived. They were told they would provide a massage, possibly naked, and allow some touching. I asked her if^^was aware. She stated every girl she brought knew what to expect. She explained she knew that wanted to make money. She approached^^and explained about going to work for Jeff, ^^agreed an^^ arrangements were made to bring her to Epstein’s house on a weekend. Robson stated that she and (Later identified asflHKflHMH picked up flfeat her house. Robson stated that at that time she was driving a red pickup truck. They traveled to Epstein’s house and entered through the kitchen door. They met with the house chef and Epstein’s assistant Sarah, fl^vas introduced to Epstein while they were in the kitchen area. Sarah iedfeflupstairs and Epstein went upstairs. When the massage was overfefceturnedto the kitchen area. Robson stated she was paid $200.00 for bringingflfeto Epstein’s house. Robson stated^•told her she was paid $300.00 for the massage. Robson stated that^^vas the last person she brought to Epstein’s house. She had changed her cellular number to avoid being contacted by Sarah. She continued stating that she had no direct contact with Epstein The foregoing instrument was sworn to or affirmed before me this ls‘ day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police^fficer'fi'.S.S.117.10) State of Florida County of P^Jm Beach SignaturpAXKMting Officer Date: O^Ql/^OOb Fagenof 22 CA/Aronberg-000812 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 • Molly (Unknown last name) and Tony (Unknown last name) picked ·Robson up and she was taken to Epstein's house. Upon her arrival to the house she was introduced to Epstein in the kitchen of the house. She was also introduced to a white female known to her as Sarah. She was led upstairs to the main bedroom known to her as Jeff Epstein's bedroom. Sarah arranged the massage table and covered the table with a sheet. She brought out the massage oils and laid them next to the massage bed. Sarah, then left the room and informed Robson Jeff would be in, in a minute. Jeff entered the bedroom wearing only a towel. He removed the towel and laid nude on the massage table. He laid on the table onto his stomach and picked a massage oil for Robson to rub on him. During the massage, Robson stated "He tried to touch me and I stopped him." I asked how he tried to touch her. Robson stated that Epstein grabbed her buttocks and she felt uncomfortable. Robson told Epstein, I'll massage you but I don't want to be touched. Robson stated she performed the massage naked. At the conclusion of the massage, Epstein paid Robson $200. After the massage Epstein stated to Robson that he understood she was not comfortable, but he would pay her if she brought over some girls. He told her the younger the better. Robson stated she once tried to bring a 23 year old female and Epstein stated that the female was too old. Robson stated that in total she only remembers six girls that she brought to see Epstein, each time she was paid $200. Robson stated she had brought the following girls:-----• --( al6 year old female),_a 16 year old female) and-. Robson said that at the time she brought these girls to Epstein's house they were all14 through 16 years of age. I asked Robson which one was the youngest. Robson advised ~as the youngest as she was fourteen when the massage occurred. Robson stated every girl she brought knew what to expect when they arrived. They were told they would provide a massage, possibly naked, and allow some touching. I asked her if ~as aware. She stated every girl she brought knew what to expect. She explained she knew that - wanted to make money. She approached-and explained about going to work for Jeff, .agreed and arrangements were made to bring her to Epstein's house on a weekend. Robson stated that she and (Later identified asa•N■■• picked up 9lt her house. Robson stated that at that time she was driving a red pickup truck. They traveled to Epstein's house and entered through the kitchen door. They met with the house chef and Epstein's assistant Sarah. 119was introduced to Epstein while they were in the kitchen area. Sarah led-,Upstairs and Epstein went upstairs. When the massage was overa9returned to the kitchen area. Robson stated she was paid $200.00 for bringing9to Epstein's house. Robson stated9told her she was paid $300.00 for the massage. Robson stated tha~as the last person she brought to Epstein's house. She had changed her cellular number to avoid being contacted by Sarah. She continued stating that she had no direct contact with Epstein The foregoing instrument was sworn to or affirmed before me this I" day of May, 2006 by Det Joe Recarey, who is personally known to me. PageL{of 22 CA/Aronberg-000812 ing Officer Date: FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 when he was going to travel to Palm Beach. Robson said when Epstein announces to his assistant, Sarah, that he is traveling to Palm Beach, Sarah would then contact Robson to arrange girls to “work” for Epstein. Robson stated that once her parents discovered that she was visiting Epstein, they disapproved of the encounters with him and she stopped. Robson further stated that Sarah still tries to call Robson’s house and leaves messages. Sgt Frick entered the room and explained to Robson that based on her own statements, she had implicated herself by bringing underage girls to Epstein’s house. Robson provided cellular telephone numbers for the girls she had mentioned previously. Additionally, she also provided possible addresses and areas in which they lived. As Robson was being taken home in the vehicle, a tape recorder was placed within the vehicle to record any conversations within the vehicle. During the drive back to her home, Robson made the comment “ I’m like a Heidi Fleiss.” (Hollywood Madam who sent girls to clients for sexual favors in California). Robson was dropped off at her house without incident. On October 3, 2005, Sgt Frick and I went to speak with a sixteen year-old female who was brought to Epstein’s residence by Haley Robson. We met with fl^mother at their front door. We explained the ongoing investigation and asked to speak withl^as we had information that she had “worked” for Jeff. Mrs.introduced us to her husband and allowed us entry into the home. We sat in the dining room and met with j^Date ofBirthAs she was under the age of eighteen, Mrsivas advised we would be speaking with her. She expressed if her daughter had information, she wanted to assist. We interviewed who denied having any inappropriate encounters with Jeff (Epstein). She stated she had gone to Jeffs house with Haley Robson approximately eight months ago and sat in the kitchen with the house chef, but nothing happened. As the parents were present during the interview, we felt that^^was withholding information from us. She made several comments as to putting the entire incident behind her. I left my telephone number and advised should she wish to speak with me again to telephone me. Sgt Frick and I thanked Mrs.•for her time and left the area. She stated she would ask^hgain after we left as to what happened at Epstein’s house. I informed her that^^had my telephone number and hopefully she would call. On October 4, 2005, Det Dawson and I drove to theOBB^home and met with^H^B^M^and B^B^BB^dobflHMI^^ During a sworn taped statement,•(•■B^Bstated approximately a year ago when she was seventeen years old, she was taken to a house by Haley Robson. MBK stated she knows Robson because they both attend She was told she could make money working The foregoing instrument was sworn to or affirmed State of Florida before me this Is' day of May, 2006 by County of Palm Beach Det Joe Recarey, who is personally known to me. ^X/ K / Signature of Police-Officer (F.S.S. 117.10) Signature A ting Officer Date: 05701/2006 Page^of 22 CA/Aronberg-000813 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Probable Cause Affidavit • Palm Beach Police Department Ag,mcy ORI# FLO S00600 when he was going to travel to Palm Beach. Robson said when Epstein announces to his assistant, Sarah, that he is traveling to Palm Beach, Sarah would then contact Robson to arrange girls to "work" for Epstein. Robson stated that once her parents discovered that she was visiting Epstein, they disapproved of the encounters with him and she stopped. Robson further stated that Sarah still tries to call Robson's house and leaves messages. Sgt Frick entered the room and explained to Robson that based on her own statements, she had implicated herself by bringing underage girls to Epstein's house. Robson provided cellular telephone numbers for the girls she had mentioned previously. Additiona11y, she also provided possible addresses and areas in which they Jived. As Robson was being taken home in the vehicle, a tape recorder was placed within the vehicle to record any conversations within the .vehicle. During the drive back to her home, Robson made the comment " I'm like a Heidi Fleiss." (Hollywood Madam who sent girls to clients for sexual favors in California). Robson was dropped off at her house without incident. On October 3, 2005, Sgt Frick and I went to speak with• a sixteen year-old female who was brought to Epstein's residence by Haley Robson. We met with -mother at their front door. We explained the ongoing investigation and asked to speak with~ we had information that she had "worked" for Jeff. Mrs .• ntroduced us to her husband and allowed us entry into the home. We sat in the dining room and met with .Date of Birth·••• As she was under th!! age of eighteen, Mrs►as advised we would be speaking with her. She expressed if her daughter had information, she wanted to assist. We interviewed ewho denied having any inappropriate encounters with Jeff (Epstein). She stated she had gone to Jeff's house with Haley Robson approximately eight months ago and sat in the kitchen with the house chef, but nothing happened. As the parents were present during the interview, we felt tha.was withholding infonnation from us. She made • several comments as to putting the entire incident behind her. I left my telephone number and advised should she wish to speak with me again to telephone me. Sgt Frick and I thanked Mrs.tlfor her time and left the area. She stated she would ask~ain after we left as to what happened at Epstein's house. I informed her that.had my telephone number and hopefully she would call. On October 4, 2005, Det Dawson and.I drove to the home and met with 3 ,n<l L I dob••■■~ During a sworn taped statement,~•••tated approximately a-year ago when she was seventeen years old, she was taken to a house by Haley Robson. ••• stated she knows Robson because they both attend••••••••■••• She was told she could make money working The foregoing instrument was sworn to or affirmed before me this 15' day of May, 2006 by Det Joe Recarey, who is personally known to me. Page5of22 CA/Aronberg-000813 State of Florida FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORB FLO 500600 for Jeff. She was told she would have to provide a massage to Jeff, ®^tstated upon her arrival to the house she was brought to the kitchen area by Robson. They met with the house chef who was already in the kitchen area. ®®^stated Haley Robson would wait for her in the kitchen. ®®B. was introduced to Sarah, Jeff’s assistant, who brought her upstairs to the master bedroom. Sarah prepared the room and massage table for a massage. Epstein entered the room wearing only a towel and she provided a massage. stated she kept her clothes on during the massage. She advised sometime during the massage, Epstein grabbed her buttocks and pulled her close to him. 1^®^ said she was uncomfortable by the incident involving Jeff. At the conclusion of the massage, she was paid $200.00 for the massage. I asked ®®^if she has any formal training in massages to which she replied no. I asked her if Robson received any monies for taking her to perform the massage. ®BB stated Robson had received money for taking her there but was unsure in the amount. BB®stated she returned to Epstein’s house on another occasion with Robson and another girl, ®®|^®®. MB® stated she waited in the kitchen with Robson, while®® was taken upstairs by Sarah. ®B®^stated she only did the massage once as she was uncomfortable with the whole experience. At the conclusion of the interview, the tape was stopped. I was informed that Sarah had attempted to reachMBB^via cell phone. A voice mail message on October 4, 2005 at 10:59 am, revealed a female voice who identified herself as Sarah who requested®® to call her back reference the police questioning. provided the incoming telephone number asl^BB®BB. ^^^stated she inadvertently told®®^^^®P about the police investigation because®® had called her to tell her about how she just received a rental car from Jeff Epstein.®BBBhad called her to tell her that she was given a rental car, a 2005 Silver Nissan Sentra, to utilize to visit family and visit Epstein. ®®®asked her what was going on at the house that the police would be asking questions. ®®® stated^®^®^® then called Jeff and Sarah and asked what was going on reference the ongoing police investigation. According tol^BB Sarah has since then been trying to contact her to ask about the police questions. I instructed®^®not to contact Sarah and do not provide any more information to ^^®®s she would notify Jeff Epstein and Sarah what was transpiring. On October4, 2005,1 made telephone contact with^^vho had left several messages for me to contact her. During the message, she advised she was not completely truthful when we met in person but would like to speak with me to advise what had happened. She further advised she did not want to speak of this incident in front of her mother. At approximately 3:48 pm I made telephone contact with® During a taped recorded statement®6tated the following: approximately a year ago, when she was sixteen years of age, Robson took her to Epstein’s house twice. She knows Robson because they both attend®®B®®®®®®^®* The first time she went, Haley Robson drove to the house. They entered through the kitchen area where she was The foregoing instrument was sworn to or affirmed before me this Is' day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (^.S.S. 117.10) State of Florida County of Palm Beach Signature/Arrestlng Officer Date: 05/^13006 Pagekof 22 CA/Aronberg-000814 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 for Jeff. She was told she would have to provide a massage to Jeff. -stated upon her arrival to the house she was brought to the kitchen area by R9bson. They met with the house chef who was already in the kitchen area. Q ■ stated Haley Robson would wait for her in the kitchen. 3 M _ was introduced to Sarah, Jeffs assistant, who brought her upstairs to the master bedroom. Sarah prepared the room and massage table for a massage. Epstein entered the room wearing only a towel and she provided a massage. I stated she kept her clothes on during the massage. She advised sometime during the massage, Epstein grabbed her buttocks and pulled her close to him. S J said she was uncomfortable by the incident involving Jeff. At the conclusion of the massage, she was paid $200.00 for the massage. I asked ■ if she has any formal training in massages to which_she replied no. I asked her if Robson received any monies for taking her to perform the massage. stated Robson had received money for taking her there but was unsure in the amount. ••tstated she returned to Ep~tein's house on another occasion with Robson and another girl,••••• ••• stated she waited in the kitchen with Robson, while .. was taken upstairs by Sarah. stated she only did the massage once as she was uncomfortable with the whole experience. At the conclusion of the interview, the tape was stopped. I was informed that Sarah had attempted to reach•-~via cell phone. A voice mail message on October 4, 2005 at 10:59 am, revealed a female voice who identified her·self as Sarah who requested •at to call her back reference the police questioning ... provided the incoming telephon~ number asa••••· .. stated she inadvertently to], 9 J P about the police investigation because had called her to tell her about how she just received a rental car from Jeff Epstein.•••tiad called her to tell her that she was given a rental car, a 2005 Silver Nissan Sentra, to utilize to visit family and visit Epstein. asked her what was going on at the house that the police would be asking questions. --~ stated Q s·• then called Jeff and Sarah and asked what was going on reference the ongoing police investigation. According to •■I Sarah has since then been trying to contact her to ask about the police questions. 'I instructed not to contact Sarah and do not provide any more information to••■~ she would notify Jeff Epstein and Sarah what was transpiring. On October4, 2005, I made telephone contact wi~ho had left several messages for me to contact her. During the message, she advised she was not completely truthful when we met in person but would like to speak with me fo advise what had happened. She further advised she did not want to speak of this incident in front of her mother. At approximately 3:48 pm I made telephone contact with• During a taped recorded statement.tated the following: approximately a year ago, when she was sixteen years of age, Robson took her to Epstein's house twice. She knows Robson because they both attend . The first time she went, Haley Robson drove to the house. They entered through the kitchen area where she was The foregoing instrument was sworn to or affirmed _before me this 1st day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Policeficer(.S.S. 117.10) Pagek>of22 CA/Aronberg-000814 State of Florida County of Palm Beach Date: FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 introduced to Sarah and Epstein. She was taken upstairs to a bedroom by Sarah who set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for^to rub on him. At one point during the massage he tried to remove her shirt, at which point she became very upset and discontinued the massage. BothW and Epstein had a verbal disagreement, at which time she left without being paid. She got with Haley Robson who was sitting in the kitchen and told her “let’s go.” ^Bhdvised she received no money for that day. BBalso said that Haley Robson had told her if she was uncomfortable with what was going on, to let him know and he’ll stop. She knew that the more you do the more you get paid. BB&dvised that several weeks later she agreed to be taken a second time by Haley Robson. Once they arrived at the residence, Haley Robson sat in the kitchen and Sarah took her upstairs to the master bedroom again. Sarah set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table andpicked out a lotion for^^o rub on him At one point during the massage he tried to touch her buttocks. As^^vas wearing tight jeans and had a tight belt on Epstein was unable to touch her buttocks. Epstein then rolled onto his back during the massage and then attempted to touch her breastsflBhen became upset again and told Epstein she didn’t want to be touched, ^^discontinued the massage and was paid $200.00. <^then went downstairs where Haley Robson was waiting for her. She told Robson she wanted to leave, ^aid she never returned to the house, ^stated she is aware that her friend,•■^■■■fcvas also at the house and had a problem with Epstein. Hater researched•■■^•■^dob «■■■■>and met with her at her residence. During a sworn taped statement,^MBstated the following: on or about November 2004^hewas approachedat^|fl^^ Haley Robson, a fellow student. Robson asked^HBif she wanted to make money. She agreed and was told she would provide a massage to wealthy man in Palm Beach. Robson picked her up and drove her to a house in Palm Beach. She was brought into the kitchen area of the house. She further stated that fellow^^BB^HHI0Bstudents OB and4BB*<—^came withthem. They were brought into the kitchen where she was introduced to Epstein and other females.^B^^tated she was introduced to a female helper of Epstein, the female was described as white female (unknown name ), with blond hair. She stated that the assistant was familiar with Robson. The assistant brought her upstair^^^a master bedroom area. The assistant set up the massage table and put out lotions to be used. She toldB^^W Epstein would be available in a minute. Epstein entered the room wearing only a towel. Epsteu^emoved his towel, and laid naked on the massage table and picked a lotion to rub on his thighs and back. further stated during the massage, Epstein asked her to remove her clothes. She complied and removed her pants and blouse.^Bfcdidn’t remember if she had removed her bra but feels that she did. OB^Bwas certain that she stayed in her thong underwear. OB^continued the massage and at one point she climbed onto the massage The foregoing instrument was sworn to or affirmed before me this 1st day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (F^S-S.117.10) State of Florida County of Palm Beaph Signature/Ar^emn^ Officer Date: OS/Ol/Wb

Page 7 of 22 CA/Aronberg-000815 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Probable Cause Affidavit Palni Beach Police Department Agency ORI# FLO 5006(10 introduced to Sarah and Epstein. She was taken upstairs to a bedroom by Sarah who set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for.to rub on him. At one point during the massage he tried to remove her shirt, at which point she became very upset and discontinued the massage. Bothe and Epstein had a verbal disagreement, at which time she left without being paid. She got with Haley Robson who was sitting in the kitchen and told her "let's go." Advised she received no money for that day. ea.Isa said that Haley Robson . had told her if she was uncomfortable with what was going on, to let him know and he'l1 stop. She knew that the more you do the qiore you get paid. 9lidvised that several weeks later she agreed to be taken a second time by Haley Robson. Once they arrived at the residence, Haley Robson sat in the kitchen and Sarah took her upstairs to the master bedroom again. Sarah set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion foreo rub on him. At one point during the massage he tried to touch her buttocks. A~as wearing tight jeans and had a tight belt on Epstein was unable to touch her buttocks. Epstein then rolled onto his back during the massage and then attempted to touch her breastsathen became upset again and told Epstein she didn't want to be touched. tll9discontinued the massage and was paid $200.00. -.ihen went downstairs where Haley Robson was waiting for her. She told Robson she wanted to leave. -aid she never returned to the house. 4II stated she is aware that her friend, I Q as also at the house and had a problem with Epstein. I later researchec I glob and met with her at her residence. During a sworn taped statement,. stated the following: on or about November 2004, she was approached at...-. -■■■••thy Haley Robson, a fellow student. Robson asked~ if she wanted to make money. She agreed and was told she would provide a massage to wealthy man in Palm Beach. Robson picked her up and drove her to a house in Palm Beach. She was brought into the kitchen area of the house. She further stated that fellow •• ■■-•students .. and O ■-~,came· with them. They were brought into the kitchen where she was introduced to Epstein and other females.a■■~·tated she was introduced to a female helper of Epstein, the female was described as white female ( unknown name ), with blond hair. She stated that the assistant was familiar with Robson. The assistant brought her upstairs into a master bedroom area The assistant set up the massage table and put out lotions to be used. She told .... Epstein would be available in a minute. Epstein entered the room wearing only a towel. Epstein removed his towel, and laid naked on the massage table and picked a lotion to rub on his thighs and back. - further stated·d.uring the massage, Epstein asked her to remove her clothes. She complied and removed her pants and blouse.•■- dido 't remember if she had removed her bra but feels that she did. ••awas certain that she stayed in her thong underwear. •••~ontinued the massage artd at one point she climbed onto the massage The foregoing instrument was sworn to or affirmed before me this 1 it day of May, 2006 by Det Joe Recarey, who is personally known to me.

Page 7 of 22 CA/Aronberg-000815 State of Florida County of Palm Bea h Date: FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM PiobableCauseAffiduvil Palm Beach Police Department Agcnc/ORlS FIX) 500600 'table/straddling EpSteihW^ XVhile doihgThiMiefbuttp^yw^ return^io-the,groundjat'vvhich-tinie>Ep5te)ntuiiied.tQ!h she was-surLhe was riiasturbatihg/bas^pn hiyhand hipv^^ts^^ noi want to look at his penis;areaWa\^ uncomfortable. ;Epst,ein,remov:^^ wasmextlodheintissage/tablc’and'turped-ir underwear on her vaginal-area. Shortly thereafter, Epstein ejaculated and rembveiiihjmself 1 He Shbwaited-a^he was taking a shower m^^ di’i-ectwiefv\Vhenl asked®|Bhbw’ old’she was when this occuired, she-stWsheEad^ ^iiieem'ALthecbhdusirf wasn't sure, hit knows-it was close,to S400 00. ®a».stated she never returned to provide a niassage for Epstein. At approximately 2:10,pm, Det Dawson and I mi?tAvith:fl^’dpb;flH^^ residence? has only seventeen years of age, .1 had notified'her mother, that she would be intervievyed reference an ongoing investigation in Palm Beach. ihssuiedW that-her daughter was not a.suspect: i explained the possibility of her bdiheeilhbr^ jtfrsjfedyBed.-;^ consented -to-the .interview; puring asworn;tdped;statemeht; iSHfctated the fbllpwing^at the. age-ofSixteen,-during thc-mpnth. of .associates ofRobsphTnd-knew did sanie pebp told byJier^ehdsfrom^|MM» Robson called 3:iperspn, knowing Sarah and- scheduled the appointment. Dobsonpicked^dp imd.droveherWRalm^ fbhstreet cdW<Brtll^^ They drove to the end ofthe street and-entered a large; driveway. Tliey entered the kitchen area of the houseanc •.-rietwithEps^ Ppbson led® upstairs-to thgmam bedroom area apd: sefupdhofobmAvith,a massage table and; set-out tfedils:«»stated that uhil^ing^ bedroom;she observed numerous photographs of naked young gu Is Robson dimmed: the hghts and turned on , sb Ifmusic- Robson exitcddhd-rdom.arid Epstein.entefeddhe-room wearing onlya towel. ihstcuctedTcr to mb hiklegs, underKiybutto^ area EPsicimaskedW;tb getoonrfortablg. advised she did'not remo^henclbthesv She was weafmg^ jeans and apropp^nkH^exg^ W During the massage. :Epsteinrehiovi« the massagedablemh^ Epstein’s-Chest area,he-htteimpted-tdhci buttocl^areadiowever due so due to the tightness oi the leans and a tight bell ®adc ised Epstein begairto masturbate as she mbbed his chest Epstein moaned.as shc. rubbed his chest. She observed he was continuing to masturbate and The foregoing instrument was swvrn to dr affirmed, beforemethis 1sl day ofMay, 2006 by Det Jpe Recarey, who is personally known to me., Signaiurefof Police OTficer (E.S,S. 11.7.JO,)' State ol l jofida- Cou ntyoPRalm Beat li Sngnatuni^^^ er Date: O3Q1^<M)6' Rage^pf‘2? CA/Aronberg-000816 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • . P,tql/a Lil~cGt1us,e,;_1JJi(]m,.f 1 ·:r:aJi:n,-'13:e~d1 .PJlice, ~'.~pattJfi ent ~gcn.cx'b_Rl/1 ,FLQ,?00600, ;~ab Ji,. s.t~add] ing E:pit€irl't<:)1i1~-ss~g~:)_'11sh~ck \\( hili dojJ'.lg'tl1i·s·h~t ljµttp·~:kp\vere to_t;thing 6pstein~, \\;i1s',i)1sfrl)c"fo~.io. tetuni 'to-'ih:c grq411~\-~J: wqrcl1-tirne:,Epste'inl~rj1ecl ~o·have njs cl}e~i:'nfbb_e.<l·--~:_.-_ ••• - • ad\lisecf. she \\!:}~,sure.he_ \\ias m:a~ttu'.bflti!ig))ase_q .◊fl his h~ncl fiYoV~nYe~ts,g9lgg·ljp ai)ci' gown :on,hi~·-peni_s\~r,ea:~ ,- •••• wrlid; 1191 \\'3ill fo ,look .~tJiis p_e11_i,s:~,v¢a:bfc?~S~ shi•nvas U:r1t:Cll"ifrbrt?hi~;' ,fpstein r~1119ved,;aJa:rge; \yl))t~,-vibfator \(:iiich _cwas. n~xt to· tN.iu~ss'tg,~-tabl~- ~n~f>i\lf{le.~~11 oh,_$ CT ~tgiteg Ep~tei'r(biegafr,~ubbing tJie<~'j9r11tq_r,~ve~-he(!hp1~g. _llr1def\iiear :911 J1et \:aginal'itr¢a. Shci.r:tlY-ffjer·e~fter, -~pst,ein ·cjac_ur~ied·:,ind 're1n0\1~~)-iin1_sett>ir9hi•tne'tibie. He; '\V,<)l~ed~9yer,t,:o \\i!1ere U1~ shO}\;et·was-:ap'd ·ope;~~cl :th,e;;gl<1st _d'oq1',, sh_~ ,~v~ited as:Jie w~s;ttiRiJ~~-f:l~~b9v-;t('ii~i1:el> . 8 i_i~~ctVie\\', Whei~,J <!S_ke_g' . '•• a~)9\~I qlq's_he \.Vas ,vh¢rftl-iis o¢2.u1'~~q; •sh_~- ~tate~r shs:,'hfi,d.1usLttirned ·;iC\'Ci1(e¢i1, ,At .th~ t,l'.5nc:J us ion ,9,(Jhe, st10\ver .... ,vas·.paid either.$3'~();0Q' of:$~,O'Qi.O'Q:., :sh~ ~}ated',s_M wasn't ~i,ire, 'i:iu~.:~_hows:'ii .v/,1s·c!o~.e JQ'$40J).00: .. 11·.stai~cl ~he:never,r~turn_eq':[9,pro,V'icfe··a-1119SS\lg'e,·for _Epst~,}n. - - • ·: • • - • - - • • • -At aj)pt\,)x.irnately 2:lO\pm; .Q.etb¥ws0ri· ai1Wl inet:\vith-'cioB/ . ____ ,t 1tihl3r res,i_d9flc,e~ :A~,-- \\3s bii_ly· ~C\'e11lee11·,ye1,trs-0J\1g2; '.i:tracf n:qtified 1•h~r 1110ther;,that·i1w wt(uld'be :i11tiryj~\y~d r~'fet~~)C~ .an o,hgojhgi :ip \!~sii'gati'9~1:1n~Palm Beas:h .' :{ ,assuredifrer thc1. i\t~e)'., daught~r W~\ nofa'),uspec.t: :ff• ex'j:>)a_ihed .tlie,ii?OS;SJ b}l_i fy,9fh~r be'ii1g eftpi::r :a,\Yitiless:or v1di1~1, _Mrs.d'vis~d_she,wanJt!,d'-tb toope~~te atii;t~pii$t~te.dJcrtlie lntet~,j~w; • ' ..._ - ~ • > . - •• • . . - ~ • . -~ ~ - - . • • • , . ;n!:lf Ah,g a, S\\'.()I'li: tajj~d. :stc}.teJil_eflt :-.-.r~ ll:.tj the Io I lo \~fog; Jlt ti)~ ~ge ·o{si~te.e1J;'6~ri r,,g the-mop iii,. 0 f :Slijtem bcr 1004j she; ":as· i)i"l2l'Oat:11e<l:qy}lal~y R'obsoit {or <!-,c:h;mcte,((l mak~ ri1oiief -~yas.frie1td_s' wit)1 __ ,assQdat~s 9f Rolf1cihJ111d· KJ1~-\:y ih~. same-r,e'Oj?le.,a{aa: bee1,:rteYfriusl)' told,by ~e'rfriei'lds lYbi11 ..... '• • • . J • --·. lt.i\vh'a_t:Roµ_son.d.id;fc>riEpstefo. Rob~on c~lfe.c! ~person kn"o.wirto-~s Sarah ~d -. - s¢)1edul'e,d th~- appointment. :-Rohs:Oii pi~k~dtlt1Jp ~nd,,drove her'to P,~)(l},Bea:ch·fo,a'."?treet Q,tilled,''.B}iJJo;\\fzif ', 'lihey,drnve,;to ,the end 9 f ihe.stteeJan9:ent~red •~. large; driyyway. TJ:iex ~nte~ed iheiki(ghc:n ar~a,6f the hous_e. (l,~1i:F 'ni~l wi ti\ Epst~in .• V'1S'i1ftrQdUced',to.:Tei'f' Eps_teiil,: f .. Cib~ort !~d'.~upsJai1°s~to the:;rnai il 'be~_rd0in ar~acllJ~i) SCJ'tiffthetoom ·With,a ,massagctaiil~ ~11d· set 9_ut the· citls;' .. statep'tlizit,:while'gping:,up th/; .stai_ts a~1:I ii1J9:_tlje b~qroo1i1;;;:h¢ obscrved'.ni,in1efo4~:ph9i9gt'!-P~~ -61: 11ake:~;y<:;·t1rig gid{ Jf9bso1i ~ihliijed:,ii{~'\j gl\ts ancl tutjled .oil saft-111usic. t:~bso1rexJwd>ih'ii·r00111,an-ci ·l;:psteifl ~:11teit;d-i1~~·roo111 ,\vea:tii1g, 011\y, ;l,tpiv.tr Ep$tei11\ pi'c.k~d-.Qii~:and_ iiisti:uc.tecr her ,to riih ti:i:s leg:;,_ t_md1;.r .Iii~·: l1ut1ock_s; :b·ac~'an~ :ch¢s(,"ctr~_a, ~ps(e{njisk:ecfh}~rJo. gefco1n{o_rta:bl~. '9: ac!\;ise_d she,di\f,n,ot r"eniov,ehcr:¢,1<:iihes'. • She,,V¥1S \\1~.af.1i~g)igl}t:j_emi!'!Jand a .~ropp~~:t~!ik-iqp·~\po~:ing)\e_rbellY, <Jte}L DJ!fihgJhc);qa~sagc, '~pstsin n;{11iOi,'ed 0l1is .. 10.w~I an~ la{d'. o'n,tbf m~ss.1ge-t~hle'.'!\<lkeft -A'.s-r'lllW:iecf -~pste,ih's ,c:f1e~t fgya,)ie ;atl~in p}ed ;i~ • r~ayh do~,:n he'r'ptji1tsito tou¢frh<::rb1J(to~ks,t1rea·.llbs,iiv~i:·~,,;·11~··ni1aql~~Jo - ;d~ir so di.ifk>~tn_e Ugh !tiei?•,oif the .j e_q.115' and .a,tigli l '~e) (, ~d:yi'se&-Ep;; te,in,!J~gari'tciri1astt1r~tfte:•asj)ll r_li6B~d. h1~·'.9h.es1,.:J;psre,in.Ihoa~ed:as,shetl!~bed'his chest • $\1e· oJjse.n,e.cf he \\1as ti:inti11~hig to•mt1sturoatrand: Tl~e--fbrcgoi~g- instrum~n(was sj't:ti:i;i1 .to ~·~: af'fih~1c4, :bc(or,e,,~lC, tbk1st;;_diiy of.~lay, ·20_1_}b 'I?)' :µe.( Jp~ ·.Re'catcy, ,~·It() 1s.per~6nalb: kn·ow1J_,t,o _nie;, CA/Aronberg-000816 State ofiFioi-iti~, - . -- '., - ,,_ - ; .. •CountV'of:.Palm Beach < ,..... • ~ -. • • • • - •• -- ~ FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 attempted to reach up her tank top and touch her breasts.« pulled back and Epstein stopped, however he kept masturbating until he climaxed. He cleaned himself with the towel he was previously wearing.® was paid $200.00 for the massage and left the area. She met with Robson who was waiting in the kitchen area and left the house. ■•then explained she never provided another massage for Epstein. She did however, go to the house lobson and®BB®Bas they took another friend of Robson’s, ®advised she was present when wait for•■■•■Badvised while they waited for«® the house chef prepared lunch for them as it was almost lunchtime when they went. When•■•was finished with the massage they left the area, I asked• if Robson ever told her what would be expected when she provided a massage. ®stated yes^Robsontold her that a massage would be expected, possibly naked and possibly some touching involved. ®has no formal training in providing massages. ®poke about a thirdand last time she went to that drove another girl,® (sixteen years of age) who is® friend, to Epstein s house. W^^ted® »had made money massaging Epstein and wanted to make money herself. Robson took them in the kitchen area of the house and introduced®to Sarah. Robson and Sarah took®upstairs to the main bedroom. ® advised she doesn’t know what happenedas®id not speak about what happened in the room. Received $ 100.00 from Robson for going with her to Epstein’s house and recommending^^B On October 6, 2005, at 11:45 am, I met with«WBB^^dob^^^^R explained to her why we there to interview her. She advised she was aware of the ongoing investigation. MB had previously spoken wid.—— »ho told her she-s interviewe by sworn taped statement,••stated she knew that Haley Robson worked for Jeff Epstein in Palm Beach^BM advised she originally had been taken to the Epstein house by Haley Robson, whom she met when they bo She began going t0 the house when she was n years f d stated she had been there a lot of times to provide massages over the pasttwo years. I asked her if she had formal training in providing massages, whichB®tated she had not. •• advised she was told what was expected ofher by providing massages and she would have to remove clothing but if she f®Jt to say so and Epstein would stop pushing the issue. Mbegan providing massages and^ad^he clothes on She considered Epstein a pervert and he kept pushing to go further and further.1®xplamed he would keep telling him she had a boyfriend and would not be right to her boyfriend. Itwasn^^^* ••began removing her clothes and staying in her thong underwear to provide a massage.^^B p The foregoing instrument was sworn to or affirmed before me this 1st day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of PoliceOfficer ^F.S.S.117.10) State of Florida County of Palm B^ach SignaturelAri^^in^ Officer Date: 05/0172006 Page of 22 CA/Aronberg-000817 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 • attempted to reach up her tank top and touch her breasts. - pulled back and Epstein stopped, however he kept masturbating until he climaxed. He cleaned himself with the towel he was previously wearing .• was paid $200.00 for the massage and left the area. She met with Robson who was waiting in the kitchen area and left the house. -then explained she never provided another massage for Epstein. She did however, go to the house with Robson and,•••--as they took another friend of Robson's. -advised she was present when ~.ent to work for Epstein. She advised she rode over and sat in the kitchen area with Robson to wait for••• eidvised while they waited for••- .the house chef prepared lunch for them as it was almost lunchtime when they went. When•atwas finished with the massage they left the area. I asked e if Robson ever told her what would be expected when she provided a massage. a stated yes, Robson told her that a massage would be expected, possibly naked and possibly some touching involved. 9has no formal training in providing massages. 9,poke about a third and last time she went to Epstein's house. Robson drove another girl,. (sixteen years of age) who is .. friend, to Epstein's house. 91►.,tated-knew that 9had made money massaging Epstein and wanted to make money herself. Robson took them in the kitchen area of the house and introduced .to Sarah. _ Robson and Sarah took -upstairs to the main bedroom. - advised she doesn't know what happened aslaiid not speak about what happened in the room. aeceived $100.00 from Robson for going with her to Epstein's house and recommending~ a On October 6, 2005, at 11 :45 am, I met with jiob , ~ Q £ nd explained to her why we there to interview her. She advised she was aware of the ongoing investigation .... stated she had previously spoken with•■~••who told her she was interviewed by detectives. During a sworn taped statement, ... stated she knew that Haley Robson worked for Jeff Epstein in Palm Beach. advised she originally had been taken to the Epstein house by Haley Robson, whom she met when they both attende ·g -■•• She began going to the house when she was sixteen years of age and stated she had been there a lot of times to provide massages over the past two years. I asked her if she had formal training _in providing massages, which,••-tated she had not. .. advised she was told what was expected.of her by providing massages and she would have to remove clothing but if she felt uncomfortable just to say so and Epstein would stop pushing the issue .... began providing massages and advised she kept her clothes on. She considered Epstein a pervert and he kept pushing to go further and further. _ xplained she would keep telling him she had a boyfriend and would not be right to her boyfriend. It wasn't until recently that ••~b~gan removing her clothes and staying in her thong underwear to provide a massage .... explained The foregoing instrument was sworn to or affirmed before me this !51 day of May, 2006 by Det Joe Recarey, who is personally known to me. Sigoa.ture of Police Page~of 22 CA/Aronberg-000817 Officer Date: FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable'Cause Affidavit Palin Beaeli PohceDepartment Agency OR IM ELO 500600 Epstein wanted to be rubbed on his back and recently he began turning ovei and have her rub his chest as he masturbated. HCWpuld try icfbdcUhbrb^ O»:statW‘JeffA^ try tgrgebawgy’' .vvRh mdre and moreen eabh.^ he attempted to use a rhassager/vibrator on-hen Rbbsoiidrw houseTb'rthe original massage.- left Sarah herxeikphone iwniber and every timeEpsteih; ^pukr^ appointment to Work-’. Each time she went, Sarah, wouldmeet her at the kitchen door .area. She would bririg. Epstein, would asUfeW^QP5 aboutherself Epstein- knew-she. wasja soccer player and;wouldlie .attendihg$iB^.®8iMrt^^ knew ..her real agefl^Wed Mpstein;didiajtddidmt care, the most- recent massage she provider} was p'n October 1,2005 During the massage:-she asked Epstein if she cpuldibpmow.one of his vehicles tQwisii jhef family and boyfriend in . iOrlan.W Epstein: JiadfoldJiCr’shecw^ of.his vehicles:,buiJatppstateiLh her a. ear. .She continuedAvith.the:massage as£psteimgrabbed;,herbu^ A^W^Mfeitshe waX tvearmir uiidergannehtsitp whicirshe -replied herdhong tifidefweam -©n^keifiedtQ<tpuch Her breasts.-she wbiild puE axvay fr.dm hinfandrhe yvould.s^ u^&aMbifat^ (jSj^vas/aWare-.of’.the-vibraterbut.adyised.shey^^^ .She described-, the vibrator as the large white vibrator, with a huge head on the tip of the vibrator. She stated he kept the vibfatoi in a closet near the massage table. 18®$ stated that .on October % 21)05',,She^wafECphiacted.-fe^£p'steinJs.-as^^^ that Jeff Epstein had rented her a new Nissan Sentra-and she should conic by the.house to pick it up. Sarah infoimedii^she would hate the cai for a month €S^taicd Epstein knew her car was not working properly and that sheW missed appointments^ currenth parked nextmO Held. 1 asked her if she, everjb61e.anYfoe^ explained she.jookWHB^^^^a..triendiof.hers: who:attended^MM^B^^^^^^Who-has relocated (p Orlando to attend college, laskedif she ever allowed .another, femalein the fppm,;O»advis^ one w»as brbughl.into tliMppmW At the conclusion ofthe interview-; Det Dawson and 1'went to the gym area and located the Silver.Nissan Sentfa bearing EJorida tag X9S-APM . The vehicle- is registered to Dollar Rent a Oaf- out of the Palin Beach'International Airpoi t The velucjewyas m by Janusz: Banasiac^. .later learned to' .be; Epsteinis lioiis.pnian, and paid with Epstem’sBfedi'^ On.'September 11..200 5jjW/f^R4ob;^MH^^;was arrestedby.the,PalmBeachBbli(^;^ The foregoing instrument w as sworn to or affirmed State of Florida before me this F' day of May.. -2006 by County of Palm Beach Det Joe Recarey, w ho is personally known to me.. Signafii re<>fl’o Iicebifficer (F.S.S. 117.1(1) ■I’agelDi^ CA/Aronberg-000818 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • · ftob.t1 Jjf edJtu,se ::Jffitjdvii J~alw.I.Jea,d1-P,olice<Qepartni'erit· -Ag'~'nc)'.ORill FL:O:500"600· :E:pst_efo _· {yanted: to be:' i:i}bbccfo)ri bis ba<;k anq'rece11iiy:l1e. byg~11:tt1thing•0\1·er ~nd;li~'.;;~:her/ruhhis "bhe~t a§;Jte' n~a_stuibate·d, iHc:i'oul~ try w.foµt,h,frer.b~~asfs. 9s ~ipe.,rubb~d hi"s-qhe.s.{ .. ~tiited ''Jeffwgt1ld tty t,9,geta-,Y<!Y" \.Vith -hlo.re m19.~9re :OJ! e~c'h f!l?S$~ge;'. • llliillistat~d'E1:istei~ ,ybµlcl,-try ·t9{ t9µch ·heq:i'i0re and,9n _ohe .ci<;9asi'6n·~ .be, atte,npted·,tc)' ~·se ·~,:1jlass.ag~r j,,•ibra tor.on'.J1t;L 'Robso;i'l ·ardve~6 :lhe :hoU~e Jor-·the;_;rigi_nal•ri;~;s~ge: •••• left S~~afr l~ei,cei1.-pl;ione,ntill1_beirantj e.:-.(ery {ii]ie"Eps_1ei_i-t \v.oUUi\cqi}1e,into to~_v'[i,· Sar_ah-·-i.Votjic!;c~ll '.herJo~:art" appoihtpientlO";";_,:qrk": EuJi tirne: she Went, -~_ar;al1,,,\IQ~Jd·me~f her at tl~e. kitt~ef! door:area,:Sh~~, .. -9~ld'bririg. qei'· u.pstairs ·and.':Pr9pare:•tlt~dT1aSsage.• taJ5I~; i~Q\'.JSed "Ep·s1eii1 '-''O,Ul~ ~}_k'frer;q~1e_s{io.rfs abqHt-hersei f. Ep~teiii . kne\v,she_wci'.s;a·s6c.c_~r1)Jcfrer .ai1di\~ioµld g'e attendii;£7i • ·_ . • • J.g~l<p:tHllliilillf:;~p~t~i'n'lqie\\'J}~r;6~J agi!-'st~teg_Ep$teij1;did~aji'd di_cl~J ~-- Car.~. The f!10$.I· recc1ii mis_Sag~•:sh¢ 'p;tj\:ja~~ Mis~ b1HQ.cto!5¢rj ;.,zpp~, .Dudng:_tht! m<1s~agi;-she,asked?Ep'st~ih: i(slft:: f0\1lg~b9rro~v.opeT1fhis,V¢!'lii-ies 'fo•{iisit;n~'f-fa111iiy:;and'.1J0Yfiiiirtffih:, :orra~1i:lo1 fl~r,ida. -FPS1¢:in :had t61<l :h~:r-~h~ .co.,u'i:d-.b~[r6,~~; ofie•,0£[{j5",\\ehiil.~~-.bu~'laJ~f:stated h~ ivoµld·renr hefa .. car: -~{he -~onfi'nue~l':Witii-!he inassag~ as J::pst.eiii_.,grabbe&her, bi.ltt_oC:ks;'~i19'.¢<!fess~# t.h'e:~:~tJoc¥s e,)liek~, .L ' aske~.■.Jjt(sl1e i;y}i~_.\\1e<!riqgilil}"dergarq1e.~1t~;t9, '-Yb'ich-she ,replielhyi;'thOT)g .UJ}t,fet,i;,;;ea(... Qiji;:eihe, triecl tq;tcil.)9h lie{breasis: dhe would pun a\~;ay.fi:orn-hi1ii:a1idihe''\ii6Uld stop.'. ,• ·- •• \ias· asked1i'Lh~-e\ier used,a·vihtatdr.,ori\1er: -v~f ;{~~re:.~f.Ji1~~vl'l;iral6r 'b,VLacl\1sed ~he'.I)CWC i .W6t,1ld ·aH~\Vltim ,l~ -~si 'tn;.-\i'i't,r~Jor WJ;i~et~ :sh;:_d~~~!j_b:;d, th_e,fibt,:Hcir ~s:theJa1cgewllite vibr.1.i9C-\\;i\h a:huge head o:n rhe}_lp qfth.~-\1i)jr<itor. ts:11~•,stat~cl'he•ke,pr,me -1.{bja'tor :in a e,l_os~_t:i"!ea'r the:n1assa·g~Jable, - - • '-~~tat{d t_h?t on October '3~ ;2pos,,sh~"\~ia:~_,cbi1facted l:jy;Epsfeiil~S _assis~~n(.$:arah1.:Wh6:iijforrpe~Ll1eY .rhatJeff:Epftein;hadt¢11ted'J1~r a new· N1s~~~\Se!1in1,and.·she ~hciuid ,cot1i~lW,tpe·. hot•stTP 'pjcKft .. tip·. '.Sa~aJ1 ·.i.rc~fqnne·d--- shei\\io:Lilq .h'4ve th'c:.ca(for.o n1o_qlly,· . ..,tfrief_Epste\~ loie:\V;hi;r ·<:•ii( \Vas p()t '."!'C>Tk!ng propetlY· a.ricl '{b~fsheli;drri1sse9· appoiriti11e11(s>1n:"th_¢:pa$t'.bc~au~tof ')ier-91r,~?i11g illOJ!~rqhl~: ·- . __ • •. -.•. :xpl'afhed ~h~ '9~·is~_ c:urreJit)y p_arl,<e'dne:xttothef ,, ••• & ·_ . . llt Gyitt ,fielcL {<lSkGcldJyf 'i.fsh~, eVedcYok:·,any OI)e t.9 th~ ll_ou~t::~ e~pla1n~c1;'ifi:e..:todkL • •t -_ -• • a t)'i~n.d'.ofh.ers,who al~~~de'q~ • • • - ; who '.hc,is . - r~lo~ilt~d-ii¢(Oi)ai1_d_o ~6 att~,nd c6ll@~Q, ·1 ·c1s~:~cl· if $h_e ~ ~,,~ ... allb\~1~d,artoibir.f errfril~•iff Hie ip§m,, ••• __ •· --- - .advised_:bCi -011e0(vc1s:~r§\ightin_to tl1Moorn·~Yitli.1fer: ,AtJl_1e•co.nclusf9n:dLtf]e'i~fery:jei;\ii,Tjet Pa:\VSp,it and'f\\1e1ii;to,\he 8)'.111 fir~a. 6--~-. • ••• '· . and Jo~~!ecf the"S i')ve:r: N i~s,\n Sei1 tra••!Jear\ hgf fo)'iqf! .tat X?$, AP Iv! . TliG ;veh ii;le. ,j s ,r~-gjs L.t!{~~ :fo'.Dollar~Re,,nt c1·.Car, ,oufofth_e.f>;i!m,B·eac.l);lnt~maJiopah~\itport: The·,veli_ic}e,'5'aS,ryrire~l;hy:JAn_y.s~:Baq~siac~,1~rerl<!arned·w.be.- ·Epstein:s·f~o~$,rflJan1 agcf-p~i'1 '\¥ith ~pSt~i!.ifS::cre~ifcNcf •• - • ·1:,hiJot~g9.in~·irstrtim~n.('5;~s{s~'iji:n:to:_01•iafftfti1:e4 'before m~·-thish 51' ,&1,•·ur ~{av ... 1006 by • .:- , ., -- - - , - - .,. - .; ... - ". . ... : ~ .~ . - ,-,-- ~ .. CA/ Aronberg-000818 State o(Ffor;icfo- Cbu~~-tv.~of•P~f~ :neacli - ... • !.'··.. . • ·- - - - ; ~ . - " FILED: PA~M BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 for misdemeanor possession of marijuana. During the arrest•told the arresting officer that she had information about sexual activity taking place at the residence of Jeffrey Epstein. Additionally, during the ongoing trash pulls from Epstein’s residence, discarded papers were found which contained name and cell phone number. On October 11 2005, Det Dawson and I met with^^nd obtained a sworn taped statement. explained she had been going to Epstein’s house since 2002, when she was sixteen years of age. Since then she has gone to the house hundreds of times, •stated she became his “number one girl. She explame^haton her first visit she was brought to the house by fellov*^II^BIMMii^BB^classmate> •said she was brought through the kitchen area where she met Sarah Kellen, for the first time. led ° the master bedroom, Epstein s room, •explained that as she was walking up the stairs she observed several photographs of naked women along the walls and tables of the house, •►further explained that she was brought into the bedroom, where Sarah prepared the room by setting up the massage table and provided the oils for her to rub on Epstein, •explained she remembered the steam room area, which contained two large showers Epstein entered the room from the steam room area and introduced himself. Epstein lay on the and told her to get comfortable, •removed her skirt and kept her shirt on. Epstein then instructed her to remove her shirt,•removed her shirt and remembered she was not wearing a bra. •Stated she P^^ded the massage wearing only her panties. She continued rubbing his legs, thighs and feet. ►•dvised he turned over onto his back. Epstein touched her breasts and began to masturbate. Epstein ejaculated which meant the ZsagTwi over. At the conclusion of the massage,•vas paid $200.00. They walked together downstairs Ze Sarah Kellen and I || — | were waiting, •stated ••received an unknown amountof money for taking her to Epstein. Epstein instructed to leave her cellular telephone number so that he could contact her when he is in town. •slated that during her many visits a routine was established between her and Epstein. She would enter the house and get naked in the bedroom. She would then start with a back massage. Epstein would roll on to hs back and allow her to massage his chest area,•slated Epstein would then began to mariurbate the same time would insert his fingers in her vagina and masturbate her with his finger . P would continue this process until he ejaculated. He would then utilize a vibrator/massager orthe.-vagina.«• climaxed.•advised that during her Sequent visits, Epstein asked for her real s“ . Epstein advised her not to tell anyone her real age.•advised that things escalated w>thin the home as.Epst would instruct and pay• to have intercourse with his female friend, Nada Marcmkova. •explained the intercourse included using strap on dildos, large rubber penis’ and other devices that Epstein had at his dispos . Fp^in would watch them have intercourse and masturbate himself Occasionally, Epstein would then join in The foregoing instrument was sworn to or affirmed before me this 1“ day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (F&S. 117.10) State of Florida CouwtystfPaimyBeach Signature/Arrksimg Officer Date: 05/01/2006 Page'^ of 22 CA/Aronberg-000819 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 for misdemeanor possession of marijuana. During the arrest 9told the arresting officer that she had information about sexual activity taking place at the residence of Jeffrey ·Epstein. Additionally, during the ongoing trash pulls from Epstein's residence, discarded papers were found which contained .. name and cell phone number. On October, 11, 2005, Det Dawson and I met withli9md obtained a sworn taped statement. - explained she had been going to Epstein's house since 2002, when she was sixteen years of age. Since then she has gone to the house hundreds oftimes. 1111►.;tateq she became his "number one girl." She explained that on her first visit she was brought to the house by fello • classmate, ~aid she was brought through the kitchen area where she met Sarah Kellen. for the first time. ~as led to the master bedroom, Epstein s room ... explained that as she was walking up the stairs she observed several photographs of naked women along the walls and tables of the house .... further explained that she was brought into the bedroom, where Sarah prepared the room by setting up the massage table arid provided the oils for her to rub on Epstein. lltexplained she remembered the steam room area, which contained two large showers. Epstein entered the room from the steam room area and introduced himself. Epstein lay on the table and told her to get comfortable ..... em6ved her skirt and kept her shirt on. Epstein then instructed her to remove her shirt ... removed her shirt and remembered she was not wearing a bra. all6tated she provided the massage wearing only her panties. She continued rubbing his legs, thighs and feet. tll9idvised he turned over onto his back. Epstein touched her breasts and began to masturbate. Epstein ejaculated which meant the massage was over. At the conclusion of the massage,lla,¥as paid $200.00. They walked together downstairs where Sarah Kellen and••-'••itwere waiting. -stated •••.-1eceived an unknown amount of money for taking her to Epstein. Epstein instructed to leave her cellular telephone number so that he could contact her when he is in town. -stated that during her many visits a routine was established between her and Epstein. She would enter the house and get naked in the bedroom. She would then start with a back massage. Epstein would roll on to his back and allow her to massage his chest area. allstated Epstein would then began to masturbate himself and at the same time would insert his fingers in her vagina and masturbate her with his fingers. ~xplained Epstein would continue this process until he ejaculated. He would then utilize a vibrator/massager on her vagina unti.1411118 climaxed ..... advised that during her frequent visits, Epstein asked for her real age, 9stated she was sixteen. Epstein advised her not to tell anyone her real age.-advised that things escalated within the home as Epstein . would instruct and pay- to have intercourse with his female friend, Nada Marcinkova ... explained the intercourse included using strap on dildos, large rubber penis' and other devices that Epstein had at his Qisposal. Epstein would watch them have intercourse and masturbate himself. Occasionally, Epstein would then join in The foregoing instrument was sworn to or affirmed before me this 1st day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Pagel\of 22 CA/Aronberg-000819 State of Florida Cou Date: 05/01/2006 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Agency ORI* FLO 500600 on female intercourse and provide oral sek;tO;b0ili«Aand:Ma^^^ This occurred during the-time a^vasosixieen.years of age. fil^dydsedThisxohtirit^^ The routine became fanriliaH^ assistant Sarah .would telephone her even' time Epstein was in the 1 own of Palm Beach^nd would place appointments forher to visit and work for Epstein. Each time something new was introduced., additional monies were produced and offcied for®to allow (he acts to happen ^consented to peiform all these acts but "as^ adamant that there was an understanding with Epstein that no x aginal penetration would 0CCU^Ilh his Pcn1^W ■explained that'Epstein'spcnis-was deformed, ^explained that his penis xxas oval shaped.® claimed when Epstein's perns waserect.it was thick toward the bottom but was thin and small toward the head portion.;»■ calledEpsteiir’s'penisttipgg-Shape^y O stated Epstein would’photogiaph Marcinkova and her naked and hayihg'se^andproudlyidispiay We photographs:^ the home;, gpstatefdurihgbnWsm^ in wlijch-.fe^^^ Epstein; WisTei^ friend, Nada Maicinkpya; was also,present. provided the .massage im which Marcinkova and 'her would.fondle each others breasts and kiss for Epstein to eniov Towards the:erid:oWlta^^ lier ow onto her stomach onih.c manage table and fored^y inserted his.penis-into her vagina. Wstated Epstein beganWumpWt^ became-upset oven this; 'SheYaitWWW held against-the table to pump inside her. Shescreamed “NqU' and Epstein stopped She told him that she did.npt want to have ns penis inside of her Epstein did not ejaculate inside of her and apologized for his actions and subsequent!} pan hiMNhGu3tari&M displays her photographs tliropghrout the houses DiiOcwber 12,30,0.5;,;Det.Dawson,and. ImietywiW a sworn taped-statement., that nothing happened between her and Epstein /disappeared nervous during t ae interview- TassureddieLthW have spoken xvithqtherpe^letxvho adv ischd^ occasions she prox ided a massage to Epstein She staled she was brought to the Epstein house in March of 2005 classmate at flMMaMMMMBIM^-approached her and asked her it she ivanted t^“-wor^-diB^rnddStfie^hg^ assistant. who has no formal Wi.ih.jM clothed for S200 00- . As 1 sensed hesitancy; fro,n EPsle,n s organizations o'^hpug, ®»siated she was interviewed already by a pnvate investigator for Epstein He identified himself as aul Tndinquired about the police investigate and left hrs telephone number 305-^10-5165 foi additional contact no-aijdiMWl'fa^ were almost scripted.. The foregoing instrument was sworn to or affirmed, before me this 1" davofMav, 2006 by Det Joe Recarey^ Signature of1h)liceX^ficef (I 1 frt-.lOj State of Florida- County of Palm Oichi Signature/A^esfi)ig<3ffietr Date 05/01/2006 Page.l2of22 CA/Aronberg-000820 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • Probahfe,CrtiJse--.Affi,daVit l~a1tn, Bea~b -~~_IJC~. D~p·a-rtml;nt° A~c.iifiQ.B:ili. -FLP soCJ~_Q:o • duri:ngJi~~ :fe1pa.l~ onf irilile iht~~c;ui:s'e and prQyidc ;6rALs~x.·;to :b'i;i:th _a_nd. Ki~r~i;~~oxr Thi,~ pc-~tJrr~fdt1"r:G1~ foe-time ~as,six(eeh-Y!=a.ts :of:~&¢: - - ~cjv/se'd 'this:conliriue·d t6,fsc~I.ati:q_1,1fjngj\V9;ye:al"s, Tlie}roi.itine.bec}irtie"fatnili~rto,_ Epstiin's -ass,stai'it ·Efa:ral, -,_wqtild tel_ephone. h~r eyir5,:1inie J?is.t1:;1p,~asj11)~ej'p\Vnp-ttaJn2Jka:ecp,anc1 .W~itJld pfo~i ii p 1~0.i rt trJ1e:i1 ts''f orc·hefi to -vi.sit?.n,d:,work:.Tf!(E:ps te:i'n. • Ea6l(titp e -~o-~1e1!1i 1rn::ne\\'·\ \;as'·in froqti ce.cl,\a:adi t t ori;il m o(l :f s -'W<;fC:pr~dtic~-d~a11d· ciff~r~.cl:f6r • Z(; ~l)c)w'tJ1e:acts Jo :h<tppeh. :~Qh§~~Iit~d lOJ)E!tforfl})~lliti~~s'.e:a~tsibu1 was •• ,&1da!1Jcll1t tbaUJ-i¢re \V3S· ?I~ ,i.friderit~11Q,ihg'\vitli'.Epsteirl'Jh~tr10 Vctgihal penefrat iqit:\YOU.IQ OC-CUr;_\\.,itll,his periis ... - 'CXRl?Ji1~cJ: Q1at Epsteifr's pe/1is ;\\'as de'for-hie~, @8explc1in~eci Q1at,b\~ :p~his.was, oval s"haJ1eq· .•••. cl?imed \\1~e1;. --·, Epsteih'sipeilis: ,,,as,efe~t;,i twas'thiclqoy;rard ,u-(6: 'bOJlc;iil)JJ.ut ·1.vas thfll a,~d;siiiall Jp~yar<:1-Uw Jj_eacl -p:qrt,orf. i-: c:al_l~4J,p$ieii1' s· _P.eni~: :'.~~g:.~lrnp:~9}"_ ••·st~te~ EpBtc}i~ woutH::phqtqgraph tvl~rci nk~Va artd he_r' na!<.ed and . . l:iayi1-1g se~; a_n,ct,proll9Jf:displ?Y·the.J)ji_q1tigraphs \\l!~hih ih~ h6111e:c ,.~faiE'.g during_cfr(e,visfl l_O. Epsteitr's;house• ifr:wbjc,h,sM-p"ro\!icl¢d-a,:111ds~ige (:o:.Ep~t~i1i :n{sf e1~~~!t!-;[riync;('N~di ·J\,far,q11)kQY~, \,y~s ·aJso .!)T\:Stnt .• - • prov_ided\he·,rriass~ge ·iir\yhi9lrK1arcfnkova ~ri_d'h~i',wiul9,fondJ1: ·eathqihers'tir~a.s1s ?t)d,k_iss- (or ·Ep},teji1· iq -~11j.oy" TowafC::1$- t~e :q:n·ctofthi's· 111il:i$age5 Epstein·gral,h¢d:llland)!ur!J~·cl.her·ov_er qnt6' her sJomatli:ort ·ih_e· . m;s~·Me t~ole aT1d for~iJ2lf,ins~rt<c:<l"h1$,p_en\'s,inJo li~t vagi_ria. -;stafedEpstei11l:iega1j,Jq:pv1_11p.J!isptnis.ln'Jier ·-,,ag_ina;-bepai;i1e ·_Lips.¢! ovc;:u~\s; 'Shr said~het "h~~(l'v/05;~ii11g freld 'a,gaihst-the,'JrJ,DIC fofoibl)'; ,as_;he·'c91Hi11ued lp putnp. insi:d~\er' She· $Cre,cl!}ls!~ '~Nq!:' andt;P,Stein_,stopp~d;'. sne:·tolcl hiii\ tha:r?h:~:dicl~not •w:,li1t-to~ha\1e-Hi s ,pei1i;shwicJe'ofli¢r .. ppst~indicl,fi:o:rfjacµJ~!fin~id~dfl~eiind'apoi·ctgizfd:fot,1)i~acti\:lli_s'.a·na:~Lili$eqµe"rj_t}S':pii'.d h,er :!Uhol)"sanq. Jgl ).ars '.ro):s~hci'i :vi,si(' -· ~lpted. slje~~ni:{y.'rl~e-sfi 11:displ_ays her .pfo;go£tt<iph,s, thr0Ugj119uf ~he h9,use:· ,0n.'O.smhei: 12;~).005;_:Qet.D*wson _find 1:me,t.vi~g - _ -_ • . -, i, 900 ( • -~ho stateiJ dtirjng· il _;;:,,:oni ·Hip_eq, statement,. tff ai'ilolliing:happeriecfl:iet,ye_e11·h~rand, Ei)iteiii. . app:eai'ecl' 11ervous: i:lurjhitth(: inter.Vi~\\/, •rass,med'J1ei·tp<:1t) ha:ve ~pciken \\,ith 9thetp'~9pJ~:}vho~i:h.'isr{J.:differentlj';; •.. - ,srnt~s\'.bn,se.\'e'raC- ()C~asio11s she·cj:fro,1i~~d:,p1nass~ge to lpsteiri, ·She?statGd -she;{\\:as:~r9µght 1 lq-the-Epitiin fa)l,jse -in M?i'~h -~)f 1005~. -~ .. • • : ,- _La c:lassfn:ale ar .- S' : _· ·_···· -·. _ • __ c- ~· _ .:. - _ ·, _ .. _ · .• -'c, :app~r,o,ac.f!~d>J,efc~n.?r,~$k~_dih~c-ifil1e . . _ \~antc'.d lO·'\)iClr~~'.\. ,flllD11'1ade't)~e:aqa~gemc11ts \vith··.S_~r~q,)~r.s_t~in';S;~~-sis~irit_:4' . ) . ,wJig)J:~sn~:fo~m<1L irai11ing. ii1 ,providinJ ·ii"i;:ts$a,g.es/sia,ted she::p_ro'Video .amassage;,ftJl)y 'clo;hed fof~2()Q:O.O .... As 1 s~nseci hyS!tc).ncr • ;{Q h~r~S\\i¢i;s~ f<'.iskec' !, ... - I} _i(sh~:h~d been,-c·o11t·as.\ed by°;inYone.f1.:c~1p'Epsiein' ~- q_i-g?h1zations oF;llis)Jo'use: . • ' b .. a,icd she, ~yc1s•;i11t_er~1iC.\\'.e,d;alfo?s!Y by-a rh.:vat~ ,ijl\1e.stigc1.t9rfo,~::~psteiJ.1,, ·. Ij~~i'dpnJi:fi~d:,l'limself as· "P;aul'i -:~hd;:i11g~jred fl?cil;if ili~:pbl{c~ j11,y~.sfrg~g9q; !1-0d 'l~ft ,ni~?telephone.11ll111J:ier-}0§.7l0Sl,65, foJ:-aclclitiorial corit,ac,'({. V. • • j:ifCJyid¢d no a6,qitiQl1a,Vi,rif0rination, '.as:it._app~~l~ycl '11c:::i::1'espon~C$' were ~!n1QSfS<;Tipted: i:t1.e''for~g~ing;·i~:;frunien·t ,rai;§~~•oft1 'to~or•frfi-im~d, - beforc'me thisJ<r da,· o'fi:t\1av. 2006 '.by • .. , ·,, ···'""' --· , ' ..... ,, ...... , . . l)et-.Joc Reta~e)',,l,:lrn • i~-pctseina,I_J~:.%10\rn -!<?: 1n~; CA/ Aronberg-000820 .State ofFJo~idh: '(;i)unty o{P.fiiv(~ --, ch: FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 P7nBe“oep^ XXinXXiV^ house one time approximately two months ago. She was approached by a girl.OI^^'^^^W roommate^ for an opportunity to make some quick money. ■■advisedshe neededtomakesome Thckcash to make the rent that month. She agreed to go to the house. She had been told by■^■■kh the« have to be done in her underwear. She advised■•drove with her and brought her into the house They walked into the kitchen area, and took the stairs upstairs, ■■further stated she was broug into a master bedroom area. She advised she recalled seeing portraits of naked women throughout the room. A massage table was already out near the sauna/shower area in the master bedroon^pstem enteredthe^roo wearing only a towel and introduced himself as “Jeff.” At Epstein’s direction,and®^ removed th . clothing doLto their punties. Bpstem laid on his stomach area and they provideda^^d shewas area I asked if she had any formal massage training and she replied no. “ d“s she wore were the boy shorts lace panties. She an—coined fee massage uiml.be last ten minutes of the massage, Epstein, told^^o leave the room so ha d towd —gotdressed, and .eftdx" short panties, and he produced a large white vibrator on her vaginal area. stated she was very uncomfortable during the himself with the towel he had on previously and went into the shower area _ inin thp k tc.hen and DrovidedOB* 3>ZUU.UU ror oringiug paid $200.00 to •■Bfor providing the massage told to leave her telephone number with Sarah for future contact. ■■provided ner cenunu -- che reDiied she was called but it was contacted about this investigation by anyone from the Epstein organt • stated “work” is for work. She stated she was called by Sarah for her to remm to the term used by Sarah to provide the massages and other thugs. advtsed she comfortable in providing that type of work. sworntX^^ Epsteinlhirough HaleyX^wh^eywere still The foregoing instrument was sworn to or affirmed before me this Is* day of May, 2006 by Det Joe Recarey, who is personally known to me. State of Florida County of Palm Begch Signature/AYre^tip^ Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/61/2006 CA/Aronberg-000821 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 • On November 6, 2005, at approximately 3:30 pm, I met with dob , at the Palm Beach Police Department. ■■awas identified as a potential witness/victim through information obtained during the trash pulls. During the sworn taped statement,••• advised she was at Jeffrey Epstein's house one time, approximately two months ago. She was approached by a girl,••'4•• who was dating £ 1 ~oommate, for an opportunity to make some quick money. •••advised she nee_ded to make some quick cash to make the rent that month. She agreed to go to the house. She had been told by ••-••that - the massage would have to be done in her underwear. She advised dl'ove with her and brought her into the house. They walked into the kitchen area, and took the stairs upstairs. •••further stated she was brought into a master-bedroom area. She advised she recalled seeing portraits of naked women throughout the room. A massage table was already out near the sauna/shower area in the master bedroom. Epstein entered:the room wearing only a towel and introduced himself as "Jeff." At Epstein's direction, C andll•II removed their clothing down to their panties, Epstein laid on his stomach area and they provided a massage on his legs and feet area. I asked••• if she had any formal massage training and she replied "no." ••• advised she was topless and the panties she wore were the boy shorts lace panties. She an F I continued the massage until the last ten minutes of the massage, Epstein, told••••o leave the room so that •••~ould finish the massage. got dressed, and left the room as Epstein turned over onto his back. Epstein then removed the towel and laid naked . Epstein requested that•••rub his chest area. •••stated as she did this, Epstein, began masturbating. ••• stated Epstein pulled down her boy short panties, and he produced a large white vibrator . with a large head. She stated it was within his reach in a drawer in his master bathroom. He rubbed the vibrator on her vaginal area. •••advised he never penetrated her vagina with the vibrator. He continued to rub her vagina with the vibrator as he continued to masturbate. ••• stated she was very uncomfortable during the incident but knew it was almost over. Epstein climaxed and started to remove himself from the table. He wiped himself with the towel he had on previously and went into the shower area. gnt dressed and met with J ·a the kitchen area. Epstein came into the kitchen and provided $200.00 for bringing••• and paid $200.00 to fur providing the massage. ••awas told to leave her telephone nwnber with Sarah for future contact. p1ovided her cellular telephone number. •••was asked if she was recently contacted about this investigation by anyone from the Epstein orgapization. She replied she was called but it was for work. She stated she was called by Sarah for her to return to "work" for Epstein. •••stated "work" is the term used by Sarah to provide the massages and other things. ■■• advised she declined as she was not comfortable in provid1.ng that type of "work." On November 7, 2005, Det Sandman and I met with•••••••dob During a sworn taped statement, L stated she met Jeffrey Epstein through Haley Robson when they were still The foregoing instrument was sworn to or affirmed before me this 1st day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) Pagel~f22 CN Aron berg-000821 State of Florida Officer FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Agency ORIP FLO. 500600 •'tilidine'kbbsbhiwbu^ females who wished -.WB^mexrfain^W . Usages..She wakasked about any formalltraining.in providing massages which she said. no? WPM^d ih^'adcompanWRpbsomahdoth^ further stated sheYiad been to the house appfoxiihately 4 or 5 timesin the past year. She accompanied Robson over- thcy were previously told they vvould have to provide a massage, possiblynaked. They-were also told that dwuld Epsteiii require them to do a^^ ‘hey weic not comfortable just to tell him and he would' $20Wfor each girl sheibrp.ugMi'oye^^ . , \Vheh basked>which girl appeared to be theyoungest, she repiied^^hb was reallyyoun^ fifteen years old at aheanpsWfiiBtefufthCT^^^^ the house, she sat.in the kitchen.and waited with Robson nhtil Hidhiassiage;^ She. ftrfthersiated. thatThe cook woplfriaiRe^^ waited ' I.asked her inhere was anything that caught he, atlent.on wtthin theIm Stated' there Wereal iotiYfinakedVgSsfinjphd^ Uuiiirig/a sworn taped statement,«Hm*.tate^s^ approximately'^ first approached by Haley Robsqnya Qla.s^ Ro.^ for Epstein and proyiding;a:mass^ for $WP:' was unable to takelier the:day the amangenignts were made. RPbson'MifilBMiBfrtakeWM^ she was brought there and entered througlvthe back kitchen door. She had.me ■with an assistant/Sarah and anothcr.assisiantA.drianna. Sarah'brought her upstairs as she observed^ ■phdt^^ EpstetearnmM towef add laid omthetable. «».stated.W^ oils he wanted her to usetand requested shq reni0Ve:her^iothihgto:prb^e'the'massage.M^^tatea.thaLonfthefirstmassage5hfc;.proy reinbve‘Her ciotli^ ‘»»stated she had returned several times-after that. Each.time^ ■more than.aanassaue. Epstein would walk into the master bedroom/bathrooni.area wearing pnly-a/towef He wduYd-masfcrba'^^ S^Wsiated.sfe^wakuhsure.rf he pljmaxed :as^nnist^^ .under.the towei. Additionally, she never looked belbw his waist. She claimed thaLEpstei^wquld^ lemovehe.r clothes.'She eventually rem ■would use a masbager/vibfator, which she descfibed^s W^ in i^lq^d.'a.'large^^ ■™ ‘ vibratbr/massager on her vagina! area as he would masturbate. The foregoing instrument was sworn to or affirmed before me this-ls' dawpfjMayj 2006 by Det Joe Ketaiiey, who is personally known to tpe. State of Florida County of 3' S igna t ure/ArFfe^tlng fficer li^igjiatUiiepfipbricqb^ilcer 117.10) Date: 05)01/2006: Fagedy^f22. CA/Aronberg-000822 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • . Phi/J.µlfie· ¢a:,/§e AJfilia,vit Pifrn u·e?¢J1:;r-on~~- ])~_lf?.'V:ffutJil c:A;geiicx ORI#'FL0~5006QO •~t~~11gi~g~- □ .. -. . ·_. --.---·. ■: ~ . '·){6~~ojfa:~,ol1·1g;,apprqac~-£6mal~s·~1;0,~\;l:§li~9 tdi\\1oik.ff~t,J;p·steh1, & • .. ~tated she was o'ffer~d 19 -~.vorEf.or:Epstefo but declin~q: • - • _ ,yXJ?!sihwd,.tliaJ ''wqrk"'.ll}~e~hs,~ve 1l1i~S{l&,es .. 'Sh~• :\\'.,aS.a~Red a99tit:~rY. (6rmal~!riflii!}g(JQ,,provi4irig·n:iass~iGs Whfch ,she sii9'.- "rio?' ---:siici -sh~•ac.co1nj5?.f!'1¢0 :Rgbsqfr 3:n9: 9t]\et fem_ale~~\\1l10,,ver6-:takertfo Epste1i1',\:~oiis~cl.o j:i'rQ\\tj~ inass~ges~- • • • • • . t\1rther,~tated ·she)nads.ll~~~ _tp (he hq~-5~ aforo~jtj_:i<ft~lX'.,1' Ofi?•tim.es:ipJq.e •pa~U'ear-; Slk aJ:corrtpaniecUZ~))~~-1) •• wrni_~,, .,· _,, .. . . ., . ' __ :_ .. · -_....,;.and_f( - ,r "f,-!EacliJi1!1e.-the-gfrJs,,iJefetaR¢i1 _oy~_i,,;thfv'werc ,pr.evib\1sly. to[Q. th~Yi'o.lll_fliave ·io pi:pvid¢ ~ ·1Uassa.g~, .pp~~i_q'ly➔n~l<ec!':/T_li~y,wer.e a)so,JoJa;tl)a.t "·~hij_(J,l!=CEps_tef~ ·r~quirf.t_he11y tci µ_b ai1yti:Ung. extr~; an,cf they?,vt;(~ n0t:c6trifprtai;1<[. iu.$t,·l~Ne'.ll, h}m-~i1tl_ hi! :~Vo~(4' ·s~6R '· u .. -~-~~ted Rqb's9!1·,fecefve~ $200:00for·ea~l1_gir]she,;bi:{iµg!H ;0\'.er ,lO•,fl?,ffss~&~Jeffrey:·jspste_iil:, . \Vhe!l/l-,a,iKed,whidf-gi_fL~ppearec:l to>be'the;y6\.J_ngest; s~e ~rep_i iect,.«a:,wh9,\~1~S,lf~a. lf;1:Y,QUF1Jt: fifteen ycars·-oJd'.alC: • •the;mp~t,;4 .2 + furth~~ §.t~t~d;e~cli tEile shl\V<:\nf y) tj~e·hc5\i§~;·She,~at)il.'(h~;~i'~qh~n~c1nd·:waite~ ~yith·to~~qn •~iiitil. th~/n:i~ss~ge. \.1/a~,0\1e( She, f µrthentated. tMt:ib.e, cooK-wo(1! g'1f~·a1;e,-'J u:n¢ft or:·~ :~n.a,~k :fct !l_l'ep'1. cis:fh~Y- :wai te~, .JJ1sked . .l1er>if :thecr,~ • \~As· ftn;'th:iQg :tha~.c?-tl&hilfor: a)[~11t~ph \\iitiiirf'!_~~:1:l_oni~. ... . • 'sJa(~cl ·th<fre.· ,ver~.cp: Jqtqfn~'i-;¢d,glflsii11,;pho.tqgr~p_hs•t1i[oµg{1·oqi ·theJi6t1?e. •• •• •.Q1i)1'Joyeipbcr:8; ~oos,. -~!'•appr9~ihliftely:2~QQp111-.;,J1net':\;ilf,:• ·w, 16~;· ~ ~tthe,, Pa_lpi,1J?e_3.ch\)?Ollc::e 'bep,~itn,1en~, J)u.6ng:p,~.v!ott1, i,apeB':staJ~i!iiht, •.••• r.. • . _;?tat~p ihe•:ti~~':iiteJtg°pste'_in_: . . . ' :appr.~xi_ni,~1¢1):t:wo-_.)!,ears agtr {~,~~i1 ,she -~y_qs• fir5-f;4pp_roacl'fed06i ,H~le-yJ~:oo_s9_q~. ~ s)~ssm<1te\c:ll • _ _ .. ____ ,,_ __ .. ·,. :f~l'. -Rob~ o!l appr9a.ct1 e:d ~her ,abp;ul: f o,f k,'j11g ·Jo i:Epite: fri':~11d -prov.idintt ~ Jfias s~ie• t9. hj_rn' for· $t0,.0:8Q :. /Ko 9's6ri-lfad,mad.~ 'the.,?-rt~ng e.111eri,ts,l1,o \Ve\'. er- \V<!S' rn{al;,] cf JQ; take~hei··tJie~d;'Jy"the ·aiTaifg em~5ts \V~f e-rn~de:' gc{bsoi1'limi%_ .. --~-- _t~k.l __ •• _ .• ... ~~soatit;il¢bf : l .•. ·, _ .-- a'. ·'. j.~ptjN,;~:>'J~iniYiar \viJl1:~p_@~fr1. . . _ ~c;ill\?,d slie ,vas brought(t .. ~·~re and eht~red t&io\1g~,t~e ·Gac~:kfrch~_n Jjipr. ·She }Jaq.ajet- ·\•{itli~n_. a?sisiariH3!rrah apd, aoot&et :tlSsl-s_tant);\dfiflD..!lst: Sar~;btoilgt:ii hers1:1psjai}s ciI she OP~t~)e_o,se,y~ni'l,: ;-pho.togr~p11s" f51o?:J<.¢cf [C!J1il,r~s: ilµOJ!,gh§u 0UheJ16t1st ; -__ .•. . • . \fot~.4-'J::ps1ei~;came,'in tfo ro'qn~;;:y,i~Mh~g, Cii'i!Y,,a tQ\.veii.~11g;t;i1J: on,the:'taJile.-: a- • -• -~t~1~d h~-,picl,:yd; OPt-tt,e-oHsJie,•;watJ!ed her(c\ ~1S.<?'.anirique.~Jed:dli~ fe.moy~;h~r1:ci othi.frg -t_o,p~o,j9e \h~·-JJ(a:s~age, • • •. /sf~ted ,that.,ci,1~tfle fir~t rna~~age·sl~c;.p,:o\tided she cljd'!)ql' ,~e-ii1ove'-l1.~r ~J9thing, • ... _ • ..... it?te~ $he-had tetµ_t.rwff·s~vcrciKti11ies;a_ft~r th~t: l;:ii~b.ti~j1e1sh~ r~tur:i1ecl\it y.,as. ;m0r~:fhai1,a1naf{~ge, ,Bpsie{n·\\,.0l)lchyaik.J!1tqthe~rnas'(er'oe,dio:9fnJJJ~tl_lro.9rt1,c'trea'.,,v.earingphl_y,:~:t9w~J; fl~: \\'o ulci~rt1~r;tuj9ate,as sHe:provi:<:le,&a,ma;,sagc.. in tilt. stat~d, sl_re\va~'· ~fhSt1f~-~ifhe ylirnax~ci as .µbi1~~ti,1r.b_a£eci . " t , . . . . . • . .. - . - . . •... , . ,uiid~rJl1e:tovi¢) .. i\9.c!i 1ionall)', slre pe\1_ei',lookcicl belqw'his \Va(sf S,h1; t:laime<;i tlj~('.J;::pste.il)'W~U )9 '.COfl'1'ince, He}":,toi reJnoy_e· her:cloflierr. ~he.,evertt\'.iallyre:n1'<)ved;h~-r d0Jhes•i1i1d .$tayed, in ,l:)y1'.:tho11g,pantfos. 'Off c(tc~iion;'.Ep$jd;1, .\\'.ohl_o. u;e :il mas$ager/,1i})tardr;· ~:Ytticfr ~h~- cii?tti.Geq :~s-,:~{i'ite:\n c'.c:)lqt.:anq'~<l~g~.Ji~~P, JZpsteii1 ·W61,1ki,. n.ib;.t11e. ·v1hrnrbr/rita}sager .69 lier: ~i~g'iii~i area as·he\voµ}q'inasturbil~.e, I • q s(aJ~d:s),i~;•h~d 'b~en'Jo,'the-hou_se· ·:r-he·'.f o 1:egF'ii1;g,iin~iru-m~c11t \,,ai s,v91;i! :to ();·;fti_hl)c:g •before mc:tfosd 5( ·i:J:'i)\Of;M£1y, .Z(l0'6 by l)et:Ji>c Jl(c~l'.¢Y, ,tho;is·g.ets_dnally·~~fown· to·J1ie, ·~·~4~ ' ·- CA/ Aronberg-000822 :SJa~c, ti'.f:-Fl<!ri4:la; - ·co1.1nJy ol)~~.lm, 'B • _ '!~ FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 numerous times. added she has no formal training in providing a massage. «M£tated she brought two females during her visits to provide massages,•^^stated she brought a girl named an f WB*stated she received $200.00 for each girl she brought. Department During a’swomtaped statement,•* stated she had met Jeffrey Epstein approximately one year ago She was approached by a subject known to her as* *had asked her if she wanted to make money providing massages to Epstein. ■■>had heard that several girls doing this and making money. She agreed and was taken to the houseby* *ad introduced her to Sarah and Epstein and brought her upstairs to a master bedroom where a massage table was prepared mid the proper oils were selected. *kft the room and waited downstairs for her. stated Epstein entered theroom wearing a towel and laid on his stomach. She provided a massage wearing only her thong panties^ advised Epstein had masturbated every time she provided a massage. She stated Epstein continued to masturbate until he climaxed. Once that occurred the massage was over. She felt the whole situation was weird but she advised she was paid $200.00 for providing the massage. She also stated *was paid $200.00 by Epstein for bringing *^tated she had gone a total of 15 times to Epstein s residence to provide a massage and things had escalated from just providing a massage. Epstein began touching her on her buttocks and grabbed her closer to him as he masturbated. Epstein also grabbed her breasts and fondled her breasts with hi tends as she provided the massage. *»stated on one occasion, while she was only seventeen yearsofag, offered extra monies to have vaginal intercourse. She stated this all occurred on the massage table^* stated Epstein penetrated her vagina with his penis and began having intercourse with her until he reached the pom climax Epstein removed his penis from her vagina and climaxed onto the massage tab e. ^^recewe $350 00 for her massage. I asked her if she had any formal training in providing massages,stated she not iXontinued to state on one other occasion, Epstein introduced his girlfriend, Nadia, into the massage. Nadia was brought into room with«*to provide a massage. Epstein had them kiss and fondle each o er around the breasts and buttocks as they provided a massage to Epstein. Epstein, watched an "b^ed this occurred. On other occasions, Epstein, introduced the large white vibrator/massager in the massage. Epstem stroked the vibrator/massager onOHM^vagina as she provided the massage. On November 14, 2005, Det Sandman and I metwith«^»^^m dob^^^^ K 5»om taped statement she advised she started going to the house approximately one year ago and approximately five or six times. also stated she was sixteen years old when shefirst went to Epstein house. On her first visit she was brought by a fellow student The foregoing instrument was sworn to or affirmed before me this 1st day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (&S.S. 117.10) State of Florida County of Palm Beach Signatuw^nfesKng Officer Date: oWv2OO6 CA/Aronberg-000823 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • Probable Cause Affidavit Palm Beach Police Department • Agency ORJ# FLO 500600 nwnerous times. added she has no formal training in providing a massage. s£-.ted she brought two females during her visits to provide massages. •••stated she brought a girl named. and b from•••••■■■ 1••tstated she received $200.00 for each girl she brought. On November 8, 2005, I met with L 1, W/F, , at the Palm Beach Police Department. During a sworn taped statement,_ stated she had met Jeffrey Epstein approximately one year ago. She was approached by a subject known to her as Illa .ahad asked her if she wanted to make money providing massages to Epstein. --had heard that several girls from•••••••■■■■■ were doing this and making money. She agreed and was taken to the house by .. Alaiad introduced her to Sarah and Eps.tein and brought her upstairs to a master bedroom where a massage table was prepared and the proper oils were selected. lllieft the room and waited downstairs for her. ••astated Epstein entered the room wearing a towel and laid on his stomach. She provided a massage wearing only her thong panties. C advised Epstein had masturbated every time she provided a massage. She stated Epstein continued to masturbate until he climaxed. Once that occurred the massage was over. She felt the whole situation was weird but she advised she was paid $200.00 for providing the massage. She also stated -was paid $200.00 by 7 Epstein for bringing ••l _ £ stated she had gone a total of 15 times to Epstein's residence to provide a massage and things had escalated from just providing a massage. Epstein began touching her on her buttocks and grabbed her closer to him as he masturbated. Epstein also grabbed her breasts and fondled her breasts with his hands as she· provided the massage. •••stated on one occasion, while she was only seventeen years of age, he offered extra monies to have vaginal intercourse. She stated this all occurred on the massage table. - stated Epstein penetrated her vagina with his penis and began having intercourse with her until he reached the point of climax. Epstein r~rnoved his penis from her vagina and climaxed onto the massage table .... received $350.00 for her massage. I asked her if she had any formal training in providing massages,••tstated she did not. ••~ontinued to state on one other occasion, Epstein introduced his girlfriend, Nadia, into the massage. Nadia was brought into room with•••to provide a massage. Epstein had them kiss and fondle each other around the breasts and buttocks as they provided a massage to Epstein. Epstein, watched and masturbated as this occurred. On other occasions, Epstein, introduced the large white vibrator/massager in the massage. Epstein stroked the vibrator/massager on••evagina as she provided the massage. On November 14, 2005, Det Sandman and I met with , dob During a sworn taped statement she advised she started going to _the house approximately one year ago and has been thet~ approximately five or six times ..... also stated she was sixteen years ol_d when she first went to Epstein's house. On her first visit she was brought by a fellow student from 411111. -••• known to her The foregoing instrument was sworn to or affirmed before me this 1st day of May, 2006 by Det Joe Recarey, who is personally kno,vn to me. Signature of Police efm.cer (.F.S.S. 117.10) TL _ _15_,.,.,,, CA/Aronberg-000823 State of Florida County of Palm Beach FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM ProbableCause Affidavit Palm Beach Police Department Agency ORI# Fli0'500600. as OMHpr mted bi ought her into (he house and she was introduced to Sarah Sarah then brought hei upstans into a master bathroom, located within the, bedroom. stated she met Epstein in the bathroom HelaidsOn the tuble and picked the massage oils. She provided the massage as he laid naked on the massage bed She staled she rubbed his calves and back.area. Upon the end of the massage. Epstein removed himself from the massage table and paid her $3 (JOTO for the .massage ^^M^ftsaid each.subsequent time she., went to the house, she was notified by Sarah Kellen that Epstein was in town and would like her to -work”. 'CUglUgH^tated sire returned to the house and was again led upstans by Sarah. She provided the massage, TwhZTgWMM&wns asked if she ever removed hei clothing to provide a massage stated it was not until the third time that she went that she removed her clothing. stated she was notified by Sarah that '.Epstein wanted her to come to work. .She arrived.at the house; and .was'led upstairs by Sarah. She started piiividihg the massage when Epstein asked.her to remove hei clothing. <WHMjWtrcnro\ ed her pants^irtrand* bra. She stayed in hei thong parities and continued rubbing Epstein Epstein turned over onto his back and she rubbed his chest area ^B^Bbtaud she knew he was masturbating himself as she providing the massage ^^^^^stated she^beheved he chriiaxedbased on his breathing She did not uant to \ iew-either thepjirnax or the fact that he was masturbating.MIMBst.ated once the.breathing relaxed he got up and told her to get diessed She was paid $30.0 00 for hei services <Q|bstatcd on the last time'she went to proc ide a massage she was notified bv Saiah Kellen to come to the house, and “work’ stated she was now dating her cuncnt boyfriend and didmot feel comfortable going She lecalled it was approximately January 2005 She said she went, already thinking that this would be the last time She went upstans tbe maslcr bathroom She met-with Epstein/who vas wearing only a towel, and laid onto the table Epstein caught Iter looking at the clock on several occasions Epstein a>ked her if she was in a hurry seatedhebbovfriend was in the car waiting for her MM further stated.that Epstein gut upset as he wasn't enjoving the massage She told him that she didn't want to continue and she. would not be.back Epstein told her. to leaves she was ruining his massage «®Mdvised she had no formal training mpioviding any manages. agM^vmted although she had a falling out with Epstein; she still received a Christmas bonus from Epstein: stated she was wned money from Western Union for her Christmas bonus’. Subpoenaresults fiom Western Union revealed money was sent fiom Jeffrey Epstein'on December 23. 2004 tKSv received $200.00 from Epstein for her Chr istmas bonus. iOn November 15. 2005, Det Sandman and 1 met withflB dobQlM During a sworn taped statement Unstated she met Jefti ev Epstein ov er a’year ago -She was sixteen y eai s of age and w as approached.byflMBa fellow^^^^^^^^^^^tudent, who informed herdhat she could make $200 00. providing a massage to Epstein ^Miad informed her that she would have to provide this The foregoing instrument was sworn <tp oraffirmed before me this P‘ day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Ihilice G^ficer (j/.S^ I 17-10) State of Florida Conntv of Palm Bppch Signa t u rfl/Ar t i Offtper Date: 05W2006 IU CA/Aronberg-000824 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • J>nfpg_b}e'C~~U'#,j~lfi,ltniit • 1.fairrh'(a~a~fl· ~PolJ~e JJep:~rtm~~.t· ,A;~n·cy QRI#,:FLO;MO<iOO: • • ,. • [1$'. . . . < •. • •• • . . . n~~•t~t.ed . ·. • •• c;.h,:ought l!er.t'n'tb.·',(h~:·~10µsc anq,sne ~\~~s-:ifltrodt1c~~ t9:_$arnh: $arabHi1~i1 br:ou'ght ,h~r,,upst~[i'sihto~~crri,~$lfr bathrq~1i\)~cci!9<:I \,\;itl}i1i"the,~e&0"ohr. / ••• • . . 'statect·~ii~.rfiet J='.pste\n :in,th¢ ·. :ba(ljroo1n; He··laiJJ';9~1 the.tablc;ar1ci·p:i,,(k~d._the ipa,s?.age'oi'ls, sfre•,providid,ithe 'fo·a~tage, as;he:l:a:icl,11~ked·o1Nrii:· massageJied, She·slaie<lshe' rtibbe&hitqIIYis aI)ti;:bfc~. ai·cfl, 'tlpo,ntlie:rn<i ,orth~J1ia?s3:ge; ·Epst~ih rr;mov~d lii,Q1$Cl ffrom thC,-'J113§!_>.~ge t~ble,;attd pai<:i lier:: $'.JOJtOOfor the :mas,s~g~ .•• f • .••••• : • i~aid,ea.tb ,subs,equyhl :ti'nie sh~· \\;e,il'lb the.l;fotis~ .. ,~Ji~··1v~.~:119tiJ1ed· qy<1ja,rah 1>,elie11.thatJ~ps)ejn. \\'~S;ip;lO':Ynarid,,\\io.uldJike'hetio ~'\VOrl{\ • • ,tii'teg)he.;reitiiiiei:11 ,lQ 0Jl\~'.!1qi.1~~ a,n1:\~3,s,c1gal ri '!eel tlj5stafrs bf Sarah: 'Shepf:ovfde~ ihe.mass,ag~,;, ,c'J(:)th,e;d, • . . :ya~ askec:l .if ;11e·,eve1)en10..;,ca;IX~r:c;Jo{}iing\9:provide,a·ma:ss?ge. • •• • • . st11tecfit y,1as n9t .jin_t(I t12~·ii1ird~frrn~ctharspe:,,ve11Ltfi<,1t . she,xemq'vecF\1er:dotl1ing.: ·.. . ' st?r~'d .she v,if nbtiµed: ~f~[lfah that Epst~i,1,{•iaµtcil her\to co111etd Work, ;Sh~,atfiveffat tb~'l10Use ai1d:,waf1~d·yp,~lairs ,b)"Sflrah .. She·siarted pi:byidii1g ,the: n1assag~ \\J1e:n E,pstcin:c1sked. her to'ren1qvt;.,J~er ciothfrig. •. • .· ... ·w,rertioved ,her:tpants, §llirLancr · br~. She,~ta);'<?d 'ii),Jfe~: thofrg,p'anties an:d, C~)ll~ih~e'd:/ubhing Epste'ili:' ,Epsieiri tuttie'd;over;onto ,his b~ck ~'id sJ1c ., 11.;i.L-?be.d:bis chesi.:w,y.:'. :_ Q k 1ated she irne,,i,, :h¢,yas rnasturbating hiin~elf't.1s ~Hej1roviding tfi~. massage, • • ·siated sheJ;iii'eved lie'clirirnxed·b·a~edofl·.fosbreathinl( Sl;e di'd,nciCwanttb view•eithe:r'·iJ,e 21,max·or • ,tbe -f~d -1hat)1iwas rmisturbating/ • • • • • • • • iaiedgn'c:e,,Jhe. breii}iii'igr~lax€d:Jk,go£ up ,iiiat9Jci lier fo ge} •• ,, dr~s~ed .. '$.lkwa,s pciid)3.0JtOQJor hen s~tViye,s.·•· • st<1!etF◊J)ithe,y1st tir11¢)1)~)..Vent'tc5;provide,:i • :rnas~sagt;, s)19,vas.n9iifi e.d'by:'$a1·ah.Kel le11fo• c,oni~ .fo; ili¢ 'house. ::fr1d' >,'..\y,Qrk'' .·,. • statei:l:·sJif was·now dati11g'he~ CllI;l'Cllt Q,oyffrend arid ,d1df:not,fe6l ·co1n{ortabl~ gdifrg, Sl;ie r~Galle~ 'it was:;appr~~-i[n:at¢lt)?1;1.laJY 200:5., Sl~e $a1cJ· she \vent; .alret1B)f thillkiilg th?VtHis \\'OU!d.,q~'.Jl\e'list tjint,i Slie·(v~nt,vpstairs,~nd'.:y,ent{Jlt~'.ii1e.:9rnster haihi,oo.m, She:• rnet Mith E1:i};tei'11,·,~·lrn {,;:•~·s Weifring on~ly 11,Jo':\iel~ imdJaiq,onto the·~~bJe. •■ .· staitlq .fpsitilr·caugh(]1er)'o.oki't1g .ut the dock oii se,\~eraroccas16n,s. tpsteil1\f,{Skeg h~r·i(sh~•\\lasiri .~. hurry, •. stated'hei•;boyfden9,.wa$ ,jn the car :wafti11gfop he,c ., fofther st<!t~d.1hat .Epst~in,g9t ui.isevas he,,\vasn!,t • e~1joyli}g th~,.iTif!SSage.: ':she;:tolq )1_irrdh,at'.sl1e, didri'.t:waq1 io co,ntit1tie and ,she. ,\\IQtlld 1).9i ,9¢{back, Er1>t¢,i Q '\gld iief fo!{,'.a\ie,as. she.\,;;ash1ini~g hisil;<ts·,s,age'.G ·,. idyise9;she'Had,110 fqfl).1ql (Ta,ihirig ihpro,dcling any i))3S_sages, 4 ' a ' ·s~g1Je:cI,altl1pcig11~$,pChad' a falli11g out·y•i!th,Edsfeiri; ?·he:·s,tilJ' t:e·~ei.Ye:~.a Clifi~fmas boiitis Jf-orri ,Epsfe1,1L. & • .. • . ♦ stated sH~-wa~ ,\>?ij:e,d.· f'l1011~5',.1/<J,1-1}West~r6 Uniqii:for-'he;r;Cpi'1~1tp;1~ ,QO!lllSL:'S,t!R~()~:11~,results,'f'ron~~ Wester!i,Li1ii9n re,);,~Jleg,11io'r\yy:was se;11t fro111:Je,ffr\fr,µp9i1::1n'()r1:p,e,cembr:r:,2~3;.2004'.' .. _ . . ..... r~¢eiwd • i{2QO,OO frpmEpsteiri f~H;:her Clu·)sfrnas-bonJJs.. ' •• • • • 0:Qn Novemberf§';, 200$~ Q~L ~fahdiJiarr,~i1d'Jn1eh9itl~-- d9~----· :Du[ii1g ~·:~worn t<}pe~ .:s.taten1eri\;ajsfafe'dshe::1i1et :JeffreY-:Eps\e111 O\ief"_a'year ago, •Sht;-.Cwas'sixt~~n year~,:9f~geand',wa? ' ii1ptqri,ch<:.d•,b{. •. • ._ . - a'.fell_o~v', . ·,· •• • • • •• . tutlefih who'intbrme9)1erith~t~h~· coiil,4 1i)a_ke $1QO,QQ,,pfo\1i4in$'ftf11[1S~£ig¢ tci:!:'.pstei'n'<~ . •• -);~~i11fcirn:i~d'h~.rthat:sh_e-wouldJ1a..;reto pr,9,1fd~·lh1s • Tbc,Jo:r~gi)irig;'jfr~truhienf ,,\ia~·s\,',{irh,;tp:9r,affit111ed. b,cfore· ni~ thif·V'' ,daV·Of}\ila:f 200'6 b,,., • D;et .Joe: Retare~i;:i'lf~;. is 0 1tefs◊~~lly •k1]61vr1 ·t(y me, CA/ Aronberg-000824 ,$rare o{ElmJda Counfr of Palm B' ,: • -~,_ .- • • "! ~c ' Officcfr• FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM ProbableCiiiiseAfjidavit Palm -Beach PolBe Department Agency-ORI# FL0 500600* statedis^nd'idle entered'through.a;glass:do^ She!was taken upstairs* to a- blaster bedroom Shefoctiliedthe master?bathi®mdiaci.a largepiiiEEouch, ‘smma^andmatchr^^ thong underwear.. .She further, stated thatEpsten Duel on his chest on the table.. J^otoere-sel^te^ ones to use. on Kis4egs>ba<andjfeet... forty pitnutes.intptl^ massage.- Epstein turned over onto hiskacfeaiidlfeqpested^B wait downstairs tn^fotehep^ insiiiiciedBRlo Efnishlhe-m Ak^^Ot-dress^ schpV®» left-the1 room’AndEpstein began.masturbatihg^s^rubbed Epstein’s chest. -<&stalgd Epstein con inued ma^urbatinu un^ When asked if hc had removed the towel she stated Te.fornedfoefowefaround;^ Uhthe towel he instructed® the massage was done and to get dressed mid meetwthfoi^ vot dressed'and met With Epstein in the kitchen area. She was paid $200.0.0 dollars forp^ ^stated she-was momcs-forWesanrwthmgx phesecond time she went tp^e , massaee^agmed and the arrangements wetc made by®<for her to return to the house stated^B ■dfovelehtb4he:kouseandknocked ohkhe.same gl ass door whiehjeads toThofc^^ pewwei^g owe... entrvimo the house by one cd'the staff men^ «S»'led her upstairs to. the maStef bedroom and Wer- 'b'riiirdom area ■th&massageaione.y Epsteitfienteredsthe.TOOm.agaih. weaiing op w towel •®tegamrerhdvii^ Epstein tnsggedhem Xii-bTh-sidriWback-ahdTe^ .■naLLine ' iW chest. Epstein leaned over and produced He turned it on Chest as this.was occurring. She rubbed her vaginadbTapproximately two to three minutes/With^^ '. -t owelaoaih and informed -herWihle massage was done.»got:drcss^.and« in the>ldicbeh area. She,received $200.00 for the massa^Wsaidlshe never^ she had J r . .. .. fhp' hniisb asked if she i ec<ved. -any formalmiassage training.. She\gdvisecl sh,.... if Epstein knew herWi ofiW .■about hei^el|and^b sdlwi^ W'was-^waie she attended, and is still.attendmg^®Bl^^M^^^^^ The foregoi ng instru in ent was sworn to or affirmed b'eforeme this 1st day of May,ZOObyb) Det Joe Recarey, who is personally known to me. State of Elorida County ofTa Im Beach Signatu^w^rr^stAig Officer Signature of Police-Officer (F.S.S. 117.10) Date: WOlgOW T’npe <>f 22 CA/Aronberg-000825 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Fro/Jq,Mgd;aiisf-J~{fifi,g,iiit J.>.?h\l ]~each PQU¢e I)ep)ittintnf Xuen'<:v--ORIII FL◊'50il600· - . c, • .:~-·-· ... : .-• • ... · ' /T1[\SSag~•lopf~s~J---·niade:.the auang~m~i-its:·,v1iH Epsiein-?n~i-'hisassisja~t;;.and·tciok -lcFthe.,hotise: ---- -stat_ed • - ♦- -,id•she enterep'through a,·glass doqt:thatle.d·niro,a~,kitcheh. She'\vas:ta)<eri ~psiE!ii's'll:Y_~ --,t9 a' -- ihaster b·~drpo1,n_ she-r.ecallea'il1e µ~aster;baJli[ciQnyhaid.,a i,~rg,e "p\iili·coµcl\ 'S~U11~J1~d• n)atchitjg: sljb\}'et. • - Epstd11r~o1ered)mo•.t_l}e'.rOb111 weaf_ing_,oi:liy !i_'Wf,1cf .,aJid, - •-• _f,rndve!:!,'~he.~r-~lotbtngJe"n1ainii1g o'rily-Sih_ :thong UJ~(lcrwe:'!L ,Slfe f-urther/stat~d°fhat;6psfoi11Jaid~i;,11:j1iicQeSton -thCtt;ble_. ti1hf o_i]s_;_\V~re'.s~l~e,t~d oi'.{,\-\ih\ch c.1·11d to u~e. BOtli .... ,a_n-d~r:9\1ided:.t~e:ii1a~st.fge 9n;liis,-legs, ba¢k ap~Jeet. l?orty .minute~:fi;to tl1c -- -• nJassagc_; Ep~k11f:tup1ed ovcr9r1t9-iiis bflcki11~tt.~m1ested-.,v4it_cl6Wp~t~'j_rs 111 •~he:ki tcll,t:il. :aryaf~t-·; };,psiei11 i,isli:.l,tStecwlJto ;'r n'isli.the tnas~a,~e: As<ff'LJ& g_otdres~~-Cl, ~ , -- ~t-~rti'qg~ru~J~it)~ ~psf effr' s:~,~~~L :.-_ - -,. Jyft· Jlle'roo.111;_;mcl E1r:itfin· b:~gat1 i~wsturbating,11s-rti~pe_cl £pste'ini_,nihe~L ,.s(a_ttc:l'~P,!l~t?iff continued'. : mzistlfr.b~tittg.~unhf he, c:I ii11a:f{ed'-oq ·tH~: t.6",.vethi -w_as.\.v~aring, When c!Skeg' i(J,e 'hadt~nio,ved:the _to,:-.:el .she: isJa1~d :b_e/t9mdd ;thoe :io\~:<:): ;r9un·a:·sd. tha( -t~e, 9pen)ng,wo 11liLal IQW, l"li into ~e:-:.pos~j11(11se-lf. After, J~~•.cl Cflij;lhirt1se}f ()ff ·.\\i th. the;_tQ\>.(elJ!e iJ1s.tru~ted--·the.'rtictssag_e·,\vl/l doile,@.cl fo getQrt!SSed•,ai1d ni~e'i-~vi ii~ -h11n.do~Vi1stails.;"9 ,g9~,dressc_d:A11<l.f11~1- i,\!itlyEps}ein-'in th~ lcit9he11 afe,ll. $.he was p<;1id s200:0:0-dolfiirs,·foi:,pr~.,.r1di~g:,th'e,11ia,ssage. -.~·tat~d sl'!c·,was a\(;arp·tfra~---also're,sej'yed 1n911i6$-for·Jlie ~;'llll~Ahii1g:. Jhe~set911d ¢in1e .·sh~ .\\'.Clll-1() ltl_ie. . ·house. s~1·e. ,\\1as;agaih •qpprbached'.~y - _- -- -•-. - Q--~yised'ifshe'. \Vf!I1ie~· 1q_re,tufir to;Jhe,,h.0Us~;tqjpr9:vi~ie a.11other l 1"ilassage'..,iigr,ye~, £rrd'.~l1e)rr<!iigeJh"ept§ wer~-ma,df '~);) ... (fpr:·1w, to,rft_u,rp,19 (He:hou?e:.~ st3:t~d - ' .--·· ___ ' -~li~vebei:-ti):tht{frouse ilfld:J(nocked dnJhe,$ame gl_a_ss.:d'(\Oj. wh1th)e<1d,st,6:JheJjg:Ji~n.:;:ire:a, T'J1e)'1\vei:l!:'sii)0Wi~:(l .bnlry,into ·.the:Jfo,t1s:C by,q_i_:fe -ofth.e;;$.t.aff 111e,mbers·: -- illllf!e-:d'h1:a:,i.Jj)stafrs fr,nhe 'i:ri;a·s:r6r'beqroci1i} 3).lcl h1pSter- (ba'ili[601il .area. ~ie,f(-this-,til1):e-t9 di? tfre.·nf~;;~gt~Jilt>_n~.~ -EpsJeib')~nter,ed:t~e:foofn: ~ga1,l}.\\1e~rJr1g 6111)\~' towel, -~pegan :re1i:i6,,j,1g;,h~-.r• clothing ;i~ she didJh~:·l~sl (Jrhe:-sifo \\lil~;~Lthe ·hq.µse:: 'E1?stei'li_ns_t_r.u~-tedi_1~:r,t9, .gehii1ked. t-J/!{1i &0;1 -!1J¢' t~~le.()i1to, hii· irohi<ich}1__,:~t;g0c~•:rnarf{agihg,.his 1¢gs'.~n·i:l\bucjlc_ As -..J n_i~he.d .v{i th:Epstei11'.s_-back.aiid'l~g~;Jj?stf.ip•the1~ turne&,:o\;Ct gr1to-:His Jiact -§tatte.cr t9 mfr h1s-9best:and:)1'e qega,1y ,;i:l<!,S.llJi"b~! 1!1 £!- •A.s' •. r:ubbed 'his-ches't, Ep_st~-in. ;k3.!ied'over: -ancfp1:odu~eµ 1<!''.V1~~s~ige_r/•/ihra lQL }l~· turned it 011 •. a~1cJ 'b.~gan rt;bb'i11g _, v~gina·ab~· i11astt1i'):iaJ_iqg-h/1ns~lfati.he iam~' tim'e: -·~tf,lt~q. sHe.ccintJnµed: to::rnb.h~s- c_liesl_as this•,~\:as otcurring, s1ie.cits:ctibej:l 0the,,,:iil)_n1tor/tnass_ager asJarge,grey \~\iJh ~;rf,lrg~ heacl, :Epstein r\.J bbed_ h~r \'~giqa lot ;_apP:r9xim~tely ·two f.g.t_hrr;e. i11i IiUt§.S, ~vi,f h,1iw.-ijiass<}gerfvi pta_tOL. ~eJtlJe,ri'!emo vecrti,~ vi_brator fr.6m;J.1er \'flginaCarea iina cqqcerttrateo '.QI} m;isfut'b~ting';hfrns,cl( ..... _>(<1fea·-Ep§_t~i1j ,cl!fi1a.'-;Gd'fl!llO;the- lO\VCI ·a12aii1 ai1d it1fot11kd-herlliafllie riiassa.1;:e>\vas doi1f :fill QoU:ir.essed:~nd.mdtvfai\' -•• who; wZis w,iiJ1)1g ,in tl1e~ki;cb~~,,.:area. ·s11b;re~e1,;~~,:s,199,oo fo;:111~:~1~ss~gi' 111fsa_i~l;_si1? rt,ever:-r.e:t~_lf:h~·d·~t~-;tb&.hobs~ '~ncl:h(ltj Il£) d~_s1tc '~0 rd ~rn JO .the, 'ho,ifse,, .• .... vas -~~ked'1[~i1e"reQei\1~d-:a11)1-f otm~!' n1as~_a,g~'tra iriinjf ·sh~tt!vtsed ~hy l\ad no.forirni1•t;§}'tW1fof-kasas~ip.ifEpst~in.kne,~i:h_e.r.re._al agei~t1}H:\ci:J-i.¢'~e,y;as,'.lie:'._?~ke!d'b_er.q\f~Sti611s. --abo'ui hcrselfand i1'i'gh sci1tYOL He'was,awai:e-she att6;1ded. a11ct·1sstili.attehdin' ,· • - • , ~ • • • • .. ••• •- • • • •,- v• ._ - • ,.-• • _., - as -• •- • • • • • "• f • C • • • .;• - •• • •• • ,: • Tl1 e {o-r.egoirl g in.strq m ~nf,~,a~;,s5,,9r,iJ;{9: 9-fa frip'i1~e:c1• 'l.>'eforc.,nie this:111 di1h;il~·l~y, 2Qff6•;!Jf - - ·bct:iloe Recarcv. ~tho ls pcrsonaih;_ know-ri:-to ,inc., • • • • 0 • • • > 0 ,.,., • • :- •• 0 0 T • • • ~- -- • :-'' 7 ; . •• T ' • • • • -, CA/ Aronberg-000825 :sratc'_ofi:Elorid:l <;:·oct~~·-'qf~f?lm'·s. ach 1)3.tc: FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 - Duri the course of the investigation a search warrant was executed at Jeffrey Epstein’s home located at 358 El Brillo Way in Palm Beach. While in the home I observed the pink and green couch within the master bedroom area just as the girls previously mentioned. The stairway, which is located from the kitchen area to the master bedroom area, is lined with photos of naked young girls. Additionally, numerous photographs ofnake young females, some of which appeared to be the girls I previously interviewed, were on display throughout the house Also located in the house were various phone message books. The telephone message books have a duplicate copy (Carbon Copy) which, once a phone message is written into the book the top copy is then torn on the perforated edge and the carbon copy is left in the book. First names of girls dates and telephone numbers were on the copy of the messages. I recognized various numbers and names of girls that had already been interviewed. The body of the messages were time of the day that they called for confinnation of work O names and telephone numbers were located in which the body of the messages were I have girls for him have 2 girls for him." These messages were taken by Sarah Kellen, who signed the bottom of die messages. E)Xthe execution of the warrant, I located foiOm Epstein s bedroom desk. This desk had stationary marked Jeffrey E Epstein. I located a wood colored armoire beside Epstein’s bed that contained a bottle of “Joy Jelly,” which is used to provide a warm massage. Several massage tables were located throughout the second floor of the residence, including a massage table found in Epstein s bedroom On the first floor of the residence I found two covert cameras hidden within clocks. One was locate. Lthe garage and the other located in the library area on a shelf behind Epstein’s desk. A computer was located Xh wasbeheved to contain the images from the covert cameras. The computer’s hard drive which showed several images of Haley Robson and other witnesses that have been interviewed. All of images appeared to come from the camera positioned behind Epstein’s desk. On December 13, 2005, Det. Dawson and 1 met with^, dob®MB® During a sworn taped statement —stated that when she was sixteen years old she was taken to Epstein^house to provide a massage formoney* stated it was before Christmas last year (2004) when an associate,* approached her and Xd7she"ded to make money for Christmas. W-de arrangements to take—tothe house and drove — to the house to “work.” They were encountered by a white female with long blond ham—was unable remember the name of the white female with blond hair but knew she was Epstein’s assistant. She was led _ upstairs by the white female who explained that there would be lotions out already and Epstein would choose th lotion he wanted her to use. She was led through a spiral staircase which led to a master bedroom and bathroom The massage table was already set up in the bathroom.—described the bathroom as a larg spaXbaSoom with a steam room and shower beside it. •was introduced to Epstein who was onthe phone when she entered the room. Epstein was wearing a white towel and laid on his stomach so that^m y The foregoing instrument was sworn to or affirmed before me this ls< day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police officer (F.S.S. 117.10) State of Florida County of Palm Bea^h Signature?AimB^titJ^ Officer Date: 05/01/2000 . r CA/Aronberg-000826 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 During the course of the investigation a search warrant was executed at Jeffrey Epstein's home located at 358 El Brillo Way in Palm Beach. While in the home I observed the pink and green couch within the master bedroom area just as the girls previously mentioned. The stairway, which is located from the kitchen area to the master bedroom area, is lined with photos of naked young girls. Additionally, numerous photographs of naked young females, some of which appeared to be the girls I previously interviewed, were on display throughout the house. Also located in the house were various phone message books. The telephone message books have a duplicate copy (Carbon Copy) which, once a phone message is written into the book, the top copy is then tom on the perforated edge and the carbon copy is left in the book. First names of girls, dates and telephone numbers were on ~he copy of the messages. I recognized various numbers and names of girls that had already been interviewed. The body of the messages were time of the day that they called for confirmation of "work." Other nam~s and telephone numbers were located in which the body of the messages were, "I have girls for him" or "I have 2 girls for him." These messages were taken by Sarah Kellen, who signed the bottom of the messages. During the execution of the warrant, I located a••• ••tr,anscript fortllltin Epstein's bedroom desk. Tlus desk had stationary marked Jeffrey E Epstein. I located a wood colored armoire beside Epstein's bed that contained a bottle of "Joy Jelly," which is used to provide a warm massage. Several massage tables were located throughout the second floor of the residence, including a massage table found in Epstein's bedroom. On the first floor of the residence I found two covert cameras hidden within clocks. One was located in the garage and the other located in the library area on a shelf behind Epstein's desk. A computer was located which was believed to contain the images from the covert cameras. The computer's hard drive was reviewed which showed several images of Haley Robson and other witnesses that have been interviewed. All of these images appeared to come from the camera positioned behind Epstein's desk. On December 13, 2005, Det. Dawson and I met with., do_b•••• During a sworn taped statement,.stated that when she was sixteen years old she was taken to Epstein's house to provide a massage for money .• stated it was before Christmas last year (2004) when an associate,. approached her and asked if she needed to make money for Christmas. emade arrangements to take1111t to the house arid drove - to the house to "work." They were encountered by a white female with long blond hair. --.was unable to remember the name of the white female with blond hair but knew she was Epstein's assistant. She was led . upstairs by the white female who explained that there would be lotions out already and Epstein would choose the lotion be wanted her to use. She was led through a spiral staircase which led to a master bedroom and bathroom. The massage table was already set up in the bathroom .• described the bathroom as a large spacious bathroom with a steam _room and shower beside it. -was introduced to Epstein who was on the phone when she entered the room. Epstein was wearing a white towel and laid on his stomach so that-may The foregoing instrument was sworn to or affirmed before me this 151 day of May, 2006 by Det Joe Recarey, who is personally known to me. CA/ Aron berg-000826 State of Florida Date: FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 -""7-7ithe massage with the oils Epstein chose and rubbed his feet and calves, massage his feet and calves.. his back as well ••began rubbing his back and got to Epstein got off the phone and requested she “ d her to get comfortable. He requested she about herself. enj°y she was sexually active. Before^® ’ continued rubbing his chest. Epstein reached -^ewasshya^^ ^XXXifsheiikehavt^^ removed his her vagina! area by ebbing her masturbated as he touched her breasts.p P □lin and stated Enstein was aware that she was uncomfortable, ^^siaieo inai nysuci moved her thong panties to one side Epstein commented to her how beaunM my dit was.» He then inserted two fingers in During this time, he kept his hand on her vagmal area and p“Ously wearing and got number with his assistant as he wanted to see her again. XeXXZXXhTdX^ ^dSw Wha^happened to her was wrong. She further stated that she had never been contacted or any additional work. ■ , doh ••was identified me-EpsUtaw^^ told she would be able The foregoing instrument was sworn to or affirmed before me this I5' day of May, 2006 by Det Joe Recarey, who is personally known to me. State of Florida County of Palm Beach Signature7^^8sting)Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/20' Hof 77 CA/Aronberg-000827 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • el Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 massage his feet and calves .. 9started the massage with the oils Epstein chose and rubbed his feet and calves. Epstein got off the phone and requested she massage his back as well ... began rubbing his back and got to the small of his back. During the rubbing of his back, Epstein asked her to get comfortable. He requested she remove her pants and shirt. -removed her shirt and pulled her pants off. -stayed in her bra and thong panties. As she finished massaging the small of Epstein's back, he then turned onto his back. Epstein instructed .. o rub his chest and pinch his nipples. As she began to rub his chest, Epstein asked her questions about herself -remembered telling him she attended••••••• .. •■•· Epstein asked her if • she was sexually active. Before-could answer, he also asked what sexual position does she enjoy. 4111. stated she was shy and didn't like talking about those things. She continued rubbing his chest. Epstein reached up ancl unsnapped her bra from the front. -explained the bra she used had a front snapping device. Epstein rubbed her breasts and asked her if she like having her breasts rubbed. tlasaid "no, I don't like that." Epstein then removed his towel and laid on the bed naked exposing his penis t~ He began touching his penis and masturbated as he touched her breasts .... explained Epstein then touched her vaginal area by rubbing her vagina with his fingers on the outside of her thong panties . .-aitensed up and stated Epstein was aware _that she was uncomfortable. -stated that Epstein said to her, "Relax, l'm not going inside." She further explained Epstein commented to her how beautiful and sexy she was. Epstein then moved her thong panties to one side . and began stroking her clitoris. - said, "He commented how hard my clit was." He then inserted two fingers in her vagina and was stroking her within her vagina. She tried pulling back to pull out his fingers from within her vagina. Epstein removed his fingers from within her vagina and apologized for putting his fingers inside her. During this time, he kept his hand on her vaginal area and continued to rub her vagina. - stated he rubbed her really hard as he was masturbating ... said he climaxed onto the towel he had been previously wearing and got up from the table. Epstein told her there was $200.00 dollars for her on the dresser within the master bathroom. Epstein also told her that there was an additional $100.00 that was to be given to-fo! bringing her there to massage him. Epstein told her to leave her telephone number with his assistant as he wanted to see her again. Epstein stated his assistant would contact her to work again soon. I asked her if she ever received any formal massage training to which .. stated she did not. ~tated it was the only time she ever went to work for Jeff and knew what happened to her was wrong. She further stated that she had never been contacted for any additional work. On January 9, 2006, I located and interviewed another victim,. dob . -was identified as a potential victim/witness from information obtained during trash pulls from Epstein's residence. •stated she met Epstein when she was fifteen years of age. She was approached by a friend froma••■ [ ? ] $ C f to be taken to Jeffrey Epstein's house to work. She was originally told she would be able The foregoing instrument was sworn to or affirmed before me this 151 day of May, 2006 by Det Joe Recarey, who is personally known.to me. Signature of Police CA/Aronberg-000827 "Dnnol'lnf ?? State of Florida County of Palm Beach FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORT# FLO 500600 tTmndel lingerie for a wealthy Palm Beacher. Wwas taken to Epstein’s house located onElBnlloWay. introducedWto Jeffrey Epstein. Epstein had his personal chef prepare dinner foiWandJ^^ A X^^er^ Epstein brought^tpstairs into a master bedroom area.^obsen^arge massage table with a sheet on it. Epstein entered instead routi„e and ,o rub his calves and feet. Epstein had "omfoX her P** “d blouse,•stated she stayed only in panties as she thd prepared the room for the massage. Epstein entered the.room wearing family.=3—=££=« eighteen oroide,, htterviews by Sarah KeUen, and massage routine when they went to work forbP ■ 1H come to Epstein’s house and were made appointments for the females to work or pstein. ® ® t0 Rnstein’s bedroom Epstein would then led upstairs, through a stairwell from the kitchen area, by Sarah Kei en * the hls utll,2e,he"" M The foregoing instrument was sworn to or affirmed before me this 1“ day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police<5ffice/(F.S.S. 117.10) State of Florida County of Palm Beach Signature/M^^inlj^ffR^ Date: 05/01/2006) CA/Aronberg-000828 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 to model lingerie for a wealthy Palm Beacher.-was taken to Epstein's house located on El Brillo Way. introduced'9to Jeffrey Epstein. Epstein had his personal chef prepare dinner fot9and••1 At the conclusion of dinner, I md Epstein brought .... pstairs into a master bedroom area .• observed a large massage table with a sheet on it. Epstein entered through a door and exited wearing only a towel. infonned •that they were going to provide a massage on Epstein.aitaasked why were they doing this instead of modeling lingerie. J L e;~plained toethat this was his routine and to rub his calves and feet. Epstein had toldtllato get comfortable. -removed her pants and blouse. tlllastated she stayed only in panties as she did not wear a bra that evening. •stated while rubbing his calves and feet, Epstein turned over onto his back. Epstein toldaato rub his chest and rub his nipples. aa,tated that as she started rubbing his chest, Epstein began masturbating himself. Epstein touched her breasts and stroked her vagina with his fingers. Epstein continued to masturbate himself as he stroked her vagina. Epstein ejaculated on his towel and paid-$200.00 for the massage. ·Epstein told lllthat if she told anyone ·what happened at his house that bad things could happen. 9end . ere brought borne by Epstein's houseman anc 'las afraid that Epstein knew where she lived--stated that several days later she received a telephone call from Sarah Kellen who coordinated for l/lllto return to "work." ~etm11ed to the house and was brought to Epstein's bedroom area by Sarah who prepared the room for the massage. Epstein entered the room wearing only a towel. Epstein had• remove h~r clothing and provide the massage naked .• began rubbing his feet and calves and Epstein turned over onto his back. Epstein rubbed her vagina with his fingers. Epstein began to masturbate himself with an upwards and downward motion on his penis. Epstein continued to touch her vagina with one hand and masturbate with the other hand. Once Epstein ejaculated onto the towel he was wearing, the massage was over ... was paid $200.00 for the massage. Epstein again told .. not to speak of what happened at his house or bad things would happen. -..wanted to notify authorities however she was afraid of what would happen to either her or her family. During the course of the investigation, several subjects were identified as a potential witness/victim through information obtained during the trash pulls, physical surveillance and telephone message books retrieved from the search warrant. While conducting research on the subjects, I discovered that the females were age eighteen or older. Interviews were conducted on the consenting adµlts whose statements provided the same massage routine when they went to "work" for Epstein. The females would be notified by Sarah Kellen, and made app.9intments for the females to "work" for Epstein. The females would come to Epstein's house and were l~d upstairi ·through a stairwell from the kitchen area, by Sarah Kellen t.o Epstein's bedroom. Epstein wouid then enter the room wearing only a towel, and ask them to get comfortable. The females would then provide the massage naked as Epstein would either touch their vaginas with his fingers and/or utilize the massager/vibrator on The foregoing instrument was sworn to or affirmed before me this l51 day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Policefficer(F.S.s. 117.10) CA/Aronberg-000828 State of Florida County of Palm Bea Date: fficer FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 their vaginal area. He would masturbate during the massage and upon his climaxing, the massage would end. The girls were then paid two or three hundred dollars for the massage. On November 21, 2005 I interviewed Jose Alessi, a former houseman for Jeffrey Epstein. Alessi stated he was employed for eleven years with Mr. Epstein, from approximately 1993 through 2004. Alessi stated he wXTousemanager, driver and house maintenance person. It was his responsibility to prepare the house or Epstein s arrival. When asked about cooks or assistants, Alessi stated they traveled with Epstein on his private plane I asked Mr. Alessi about the massages that have occurred at Epstein’s home. Alessi stated Epstein recedes Xeemassages a day. Each masseuse that visited the house was different. Alessi stated that towards the end of his employment, the masseuses were younger and younger. When asked how young, Mr. Alessi stated they appeared to be sixteen or seventeen years of age at the most. The massages would occur in Eps bXm or bLoom.He knew this because he often set up the massage tables. I asked rf there were ±mgs going on other than a massage. Alessi stated that there were times towards the end of his employment that he would have to wash off a massager/vibrator and a long rubber penis, which were in the sink after the massage. Additionally, he stated the bed would almost always have to be made after the massage. On January 4 2006 I interviewed another former houseman, Mr Alfredo Rodriguez. During a sworn taped statement, Mr. Rodriguez stated he was employed by Jeffrey Epstein for fr°” November 2004 through May of 2005. His responsibilities as house manager included being the butler, XX Xf houseman, X errands for Epstein and provide for Epstein's guests. I asked Rodriguez about masseuses coming to the house. Rodriguez stated Epstein would have two massages a day. Epstein would hi e one massage in the morning and one massage in the afternoon everyday he was in residence. Rodriguez stated he would be informed to expect someone and make them comfortable until either Sarah Kellen or Epsteiri wo <he masseuses would amve. he area and offer them something to dnnk or eat. They would then be encountered by either Sarah Kellen or Epstein They would be taken upstairs to provide the massage. I asked Rodriguez if any o e masse X “dXZe. Rodriguez staled .he girls the. would comeappearedtobe^^^j™ stated one time under Epstein's direction, he delivered a dozen roses to one of die girls that came to provide a massage He knew the girls were still in high school age I asked Rodriguez about the massages. He felt there was a lot more going on than just massages. He would often clean Mr. Epstein's bedroom after the alleged massages and would discover massagers vi r Xscattered on the floor. He also said he would wipe down the vibrators and sex toys an put diem away in an armoire. He described the armoire as a small wood armoire which was on e wa c o The foregoing instrument was sworn to or affirmed before me this 1st day of May, 2006 by Det Joe Recarey, who is personally known to me. State of Florida County of Palm Bea€h Signature/ Officer Signature of Police/6fficer (F.S.S. 117.10) Date: 05/01V2006 CA/Aronberg-000829 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 their vaginal area. He would masturbate during the massage and upon his climaxing, the massage would end. The girls were then paid two or three hundred dollars for the massage. On November 21, 2005 I interviewed Jose Ales·si, a former houseman for Jeffrey Epstein. Alessi stated be was employed for eleven years with Mr. Epstein, from approximately 1993 through 2004. Alessi stated he was the house manager, driver and house maintenance person. It was his responsibility to prepare the house for Epstein s arrival. When asked about cooks or assistants, Alessi stated they traveled with Epstein on his private plane. I asked Mr. Alessi about the massages that have occurred at Epstein's home. Alessi stated Epstein receives three massages a day. Each masseuse that visited the house was different. Alessi stated that towards the ~nd ofhis employment, the masseuses were younger and younger. When asked how young, Mr. Alessi stated they appeared to be sixteen or seventeen years of age at the most. The massages would occur in Epstein's bedroom or bathroom. He knew this because he often set up the massage tables. I asked if there were things going on other than a massage. Alessi stated that there were times towards the end of his employment that he would have to wash off a massager/vibrator and a long rubber penis, which were in the sink after the massage. Additionally, he stated the bed would almost always have to be made after the massage. On January 4, 20061 interviewed another former houseman, Mr Alfredo Rodriguez. During a sworn taped statement, Mr. Rodriguez stated he was employed by Jeffrey Epstein for approximately·six months, from November 2004 through May of 2005. His responsibilities as house manager included being the butler, chauffeur, chef, houseman, run errands for Epstein and provide for Epstein's guests. I asked Rodriguez about masseuses coming to the house. Rodriguez stated Epstein would have two massages a day. Epstein would have one massage in the morning and one massage in the afternoon everyday he was in residence. Rodriguez stated . he would be informed to expect someone and make them comfortable until either Sarah Kellen or Epstein would meet with them. Rodriguez stated once the masseuses would arrive, he would allow them entry into the kitchen area and offer them something to drink or eat. They would then be encountered by either Sarah Kellen or Epstein. They would be taken upstairs to provide the massage. I asked Rodriguez if any of the masseuses appeared young in age. Rodriguez stated the girls that would come appeared to be too young to be masseuses. He stated one time under Epstein's direction, he delivered a dozen roses to•■• or one of the girls that came to provide a massage. He knew the girls were still in high school and were of high school age. I asked Rodriguez about the massages. He felt there was a lot more going on than jtistmassag~s. He would often clean Mr. Epstein's bedroom after the alleged massages and would discover_ massagers/vibrators and sex toys scattered on the floor. He also said he would wipe.down the vibrators and sex toys and put them away in an armoire. He described the armoire as a small wood armoire which was on the wall close to Epstein's The foregoing instrument was sworn to or affirmed before me this 151 day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police,6ffice{F.s.S. 117.10) CA/Aronberg-000829 State of Florida h Officer Date: FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORW FLO 500600 n a On one occasion Epstein ordered Rodriguez to go to the Dollar rent a car and rent a car for the same girl “brought she could drive her self to Epstein's house without mcdent. Rodriguez sa.d the girl always needed rides to and from the house. Rodriguez produced a green foider which contained documents, anda note with Mr.Wpenary performance" s^enote^directionto rent a ear for^nd direction to extend the rental contract. During the course of the investigation, subpoenas were obtained for cell phone and home phone.records These records indicate the dates the calls were made are consistent with the dates and times ey the encounters with stated they occurred. Pursuant to a lawful subpoena I obtained Epstein’s private plane records for 2005 from Jet AviaUon. ttep!a„erecords showarnv.andde=fEp^ RedenXXtiL were made in the days just prior to their arrive or dering the time Epstein was in Palm Beach. Therefore, as Jeffrey Epstein, who at the of““^neyX this Florida State Statute 800.04 (5), a second degree felony. The foregoing instrument was sworn to or affirmed before me this 1“ day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida County^f Palm Beach Signature/ArresHmyOfficer Date: 05/A1/2006/ CA/Aronberg-000830 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Probable Cause Affldavii Palm Beach ·Police Department Agency ORI# FLO 500600 bed. On one occasion Epstein ordered Rodriguez to go to the Dollar rent a car and rent a car for the same gi_rl be brought the roses to, so that she could drive her self to Epstein's house without incident. Rodriguez said the girl always needed rides to and from the house. Rodiiguez produced a green folder which contained documents, and a note with Mr. Epstein's stationary with direction to deliver a bucket of roses to •·•••••··••a:fterllllltugh school drama performance. Also in that same note was direction to rent a car for a.nd direction to extend the rental contract. During the course of the investigation, subpoenas were obtained for cell phone and home phone records from several victims and witnesses along with the cell phone records of Sarah Kellen. An analysis of these records was conducted which found numerous telephone calls were made between Sarah Kellen and the victims. These records indicate the dates the calls were made are consistent with the dates and times they victims/witnesses stated they were contacted. Specifically, The phone records showed Kellen called Haley Robson during the exact times and dates when victim eadvised the incident occurred. Kellen also coordinated the encounters with ...... ,w•••••••--and... during the time frame the girls stated they occurred. Pursuant to a lawful subpoena I obtained Epstein's private plane records for 2005 from Jet Aviation. The plane records show arrival and departure of Epstein's plane at Palm Beach International airport. These records were compared to the cell phone records of Sarah Kellen ~is comparison found that all the phone calls Kellen made to Robson and the victims were made in the days just prior to their arrival or-during the time Epstein was in Palm Beach. Therefore, as Jeffrey Epstein, who at the time of these incidents was fifty one years .of age, did have vaginal intercourse either with his penis or digitally with • ~-and •••who were minors at the time this occurred, there is sufficient probable cause to charge Jeffrey Epstein with four counts of Unlawful Sexual Activity with-a Minor, in violation of Florida State Statute 794.05(1), a second degree.felony. As Epstein, wh~ at -~~_time of the incident was fifty two years of age, did use a vibrator on the external vaginal area of. a fourteen year old minor, there is sufficient probable cause to charge him with Lewd and Lascivious Molestation, in violation of Florida State Statute 800.04 (5), a second degree felony. The foregoing instrument was sworn to or affirmed before me this 1'1 day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of PolieOfficr(F.S.S. 117.10) CA/Aronberg-000830 State of Florida County f Palm Beach Date: fficer FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM OBTS, Number ■? LU£ Agency ORl;Number.' ’ . ' FLOt S., 0 I 0 I 6 p 0 I 0 £. ARREST/ NOTICE TO APPEAR Juvenile Referral:Repori wz § Charge-Typer — ChDCxasmsny; as’appiy/ , .sFejony” jTraffipFelony Agency Name-.’ ■ — • PALM BEACH POLICE-DEPARTMENT ■0'3^ .Misdemeanor ' R5;. Ordinance ’ D 4. Traffic Misdemeanor D6;, Other- Location ofArrest (Induding Name of Business)^ 1 /Arrests 3- ReguesUqr Warrant, 2/N.T'A : \. Agency Report Number(N.TA’S only) : H Weapon Seized ? Ehler Typb^ . .L^tio\orprtebses (Business NamelAddfesj ■Oaiedf Arresi. ■|Tmebl Arresi Booking pate * Booting Times JaiDaie ' I II 1 - 1 1 1 -I 1 Jail-Tune Name I Lbcaiidribf Vehicle Juvenile T ; Multiple': Clearance Ingsatof sAlias (Naniei DOB?Sbc.-Sdc?i. -Eit)'. Race .|Seju. loatoofBirth ; W- While. /I.'American indiant \\t- B --Black’ 0-'Oriental/Asian. | ivKj |; X" - |/i|Ssi xi/jMi / .. Height: .We«ghii< • Eye Color ’ Hak.Cotor Compleiioh; BuRj Local Ad^e&sXSlresL-Apt iNumoer): (City)" ‘ ’ (States Uio) Phone. it Permaheni AddressJStreej, AptiNumber) ’(C«y) (Stale)’ Business Adless (Name.- Street) '■‘.(City); ’(State) tYr:). (Zip) Phono. Paone;'' DA. Number.-Stalo Co-Defenoant Name (Last? First; Middle) iNS;Numboc- Race: Sex; Date pl Birth • o Indication of;: . Y ;N- v Uhk Alcohol Influence D O : D Drug Influence?- D ..?Ql p.. Residence Type;; ? :T.;C»ry " l.Fbrida- M Z Countyi •„ < Out pt Stale: | Addres$;Souite? . — Occupation - Piace^oLBirtn (City. State) WTAfresied" 02. At,Large. Cm/onship TJTTelOny^^r^ 0'4.-Misdemeanor aSrduveniie: 3.1 Felony . : □4; Misdemeanor CorDefendamName^Last/FifsuMidtfe) Race? Dale pl &rih: &t; Arrested’ O2.AI Large_. . -D5?Juvenile"- j □Parente ’. _ ? "Name (Last)" j Local Custodiari* * . j Otner:-?.' ?‘ ..'./ ... -(FirslXj Residenee/pnone . | 1- ) 7 | Address UJ I . . _ (C-lj-l (Siatel" •' ■ ,<Zip) Business Phono . 1 .. 1’ 2 tot/jac*.. ----- Date; Time' |‘ School Attended ’ ; Grade. ’ST The above address wasjxovided by E) defendant and Let □delendanrsparents Thechild to *eep the Juvenile Court.Cieiv.'s Office (Phone 355-2526) informed ol anyjcharige bl a^^ D?YeSibyHNamej ’ ’ O No:(Reason).' “.Vl?-. . . .. Property.Crime?' Description ol Property"' □Yes /D’N.o . Value of Property N?N/A: ' iBi Buy' ?D.?Defiver "Distribute' ' Produce/- - P. Possess/ . ’T.-Trnhic . . •.-E.-Use-’ : . —- Cuiivate?. . 5x XJ Charge Description T/..J/7 A- ug Activity ^DrugType Amount/ Unit, Offense* Cwnts' Domestic.'- Valence-' □Y GM ^ugType^^^T-nSrb^^ ‘Ni wA/. . 'C?Cocaine- ' ■AMmohetamtrie^ -E.Heroin^ Statute Violalion Numbor; WangritZCapias^umber ^FHaBanogerr^'^n^ar^^ M; Marijuana- _ . ■Equipmerii- Zi Other- ’ 'O/OphjnVDeriv. • S.^Synihetic: •> Violation of ORD Bond u 3 IX . C JC ^harge Description: ’? Counts Domestic Violence.- . violence V J D Y. CM Statute Violation Number Violation ofORD* Drug Activity; DrugType ■ ChargeiOescription Amounl/U^'t Offense Counts Domestic ■ Violence .- - OY’Q N Warrant / Capias Number. Statute Violation Number Bono ' / Violation otORD> Drug Activity1 Drug Type' Amount;/ Ural \ OffenseA Warrant/ Capias Number Bond- ChargeDescription Drug Activity- Drug Type. Amount/ Unit OlfensoJ ’ ' Counts • Domestic •' ’ - . Violence : DY .DM Statute Violation Number ■ • Warrant / CapiasNumber? ;o iJnstruciidh Nd: t ~ . ‘ ; ’Mandatory Appearance in Court? j Instruction No.'2' You need net appear in Court but must .comply with instructions on Reverse Side.. Location (Court, Room Number. Address). Court Date and Time? Month; Day1 Year: Timb Violation^ ORO * ‘ Bond* ’ . A,MJ. RM, IAGREETO APPEAR ATTHE TlMEAND PLACE DESIGNATED TO ANSWERTHE OFFENSE CHARGED ORTO PAYjHE*FINE‘SUBSCR18EDZl-UNDERSTANDTHAT SHOULDJ WILLFULLY FAILTO - APPEAR BEFORE-THE COURT-AS.REOUIREDBYTHIS NOTICE TO APPEAR; THATfl MAY BE HELD IN A WARRANTFORMY’ARREST-SHALLBEISSUED;/'' ' " " Dato Signed1 ^Signature of pefendahffW'Juv'onile.ahd Parent/ Custodian) 7 N OLD lor blher Agency? ame: .. _ . S$na:ure\of Ah(^ ‘ I 0.Dangerous D’Surcidal 'D • Resisted Arrest OtOihst;__- - Named Arresting Officer (Prin)}?-* ' -DSL :l L/ ’.intake Deputy? - ' - ' ;I.DS»< POUCh; TransportingOfficer "" ' J.DJi' 7 ” ' Agency' ; :Name?Vflrificatibri;(P^^ (PFHNTK ;PAGE"' ' _.OF._> Witness here U subjqci signeo^ih an.’XT. piSTRlBUTldN! .WHITE.;t- COURT CORY GREEN — STATEATTORNEY ’.YELLOW-— AGENCY' PINK’ — JAIL -GOLD - OEFENpANTJNj’As ONLY) CA/Aronberg-000831 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • 0BT.S_MlmD&r ·1,'_. ;fiJ~REST'1NOTfCE :fOAPREAR: '1 Arres1; i Request 1orwarranI ; , ,. , I· . , ,. ., ,. " I • ,.rweriH_e,F]elerral'Repoi1 • • . '? :,{r,;, X:fa~1ro,cai,ia • Busi_ne~Addr~(tl~me_:'_S11~-~•1· ·'.19:YL ,(Stale) ·,(?•Pl •• Paone: ( __ .f • P.foi;orti' Crime?'. .,l)f!ScilPiion ~t l'i~perty □-Yos •. □,110. •. . ... i fherge_:Oescriptio_~ ,?;, ._, .. } _Drug AC1ivjl'( j ClrugJyPf _A~~tlnl:! Ufit _,. . ,,. . .' '· ':: \)!tig AC\ivity_ I Qfug Type. , _Atno~iu I Unil ,, : , - l -O\lnsfruc1;ori·No:. 1. . . . .. , ·• . ·: ~8:n,da~OIY Appf?&!~nco jn C:Ou.rt. ,O lnstructlo_n 1-1o.:2 • 1SIotel-" I~~;~;,; ! ,Sia.tuts. _v,o!ation ~moor :10,Y•ON. I ,1 JI I ' Warranl'/ fapq,s Njimber, SchOolAnellde<,!• ·Ill _BlisjO:e~s P_hoiio (, ) ··f Gr/Jdri ---~1 ..... . tjBono • ·, Violation of 0R0;t I . . V,olatio~ (!I ORI) t •• I . I· - ''(ou~ ne~ ~• appea,,in·CoUn_~t ,ravSI- '. 9~~,fp~i~ a_f!d_ Jim&; _.~_~P!f_v.1_th_i_~"!~1.iO~ On,J~ev~r&e-5k!e> ' Moniti·, oar Year: Tim·o . A,;,,c_ __ P.M. • !AGREE ,TO APPEARAT •THE TIME'AND PLACE· DESIGNATEDJ0.ANSWER,THE OFFENSE CHARGED ORTO. PAV,,THE'FtNE·SUBSCRIBED: :I.UNOERSTAND'THAT SH0Ulo:I WILLFULLY FAIU0 -- • ~P.PEA,fl ~F9RE'.:1:i.E qou~T-AS.A§0UIRED_BVTHl!l NOTIC~ r9 /,PPEAR!~T:I.~AY_BE 1-iELI? IN cqNTE,MPTQFCOU_F!TAND A WAF1Rprr,Ft:>R MY'ARl'IE~T~~Hi>:W BE.[5S~Eo,.- ✓ • • • . . ' ~_9~0Jor .olher ~~cf ' /lame: • i, 0: DanQlltOUS • - □-'.Resisieo Arresi. O,Su1c;_dal • O,Qther; • • • ;1.0.'•··-i:·~oueh: . . -· . ,. 'WHITE_..,. COURT COP'!' >YELLOw,.,,.c. AGENCY· . . . CA/ Aronberg-000831 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM CA/Aronberg-000832 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY •··· -. ··-:· ..• '·. ····. • • . -~- CA/ Aronberg-000832 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 Police Case#: 05-368 (2) Defendant: Race/Sex: DOB: Sarah Kellen White Female 05-25-1975 Charges: Principal in the 1“ Unlawful Sexual Activity with a Minor (4) counts Principal in the 1st Lewd and Lascivious Molestation (1) count From March 15, 2005, through February 2006, the Palm Beach Police Department conducted a sexual battery investigation involving Jeffrey Epstein, Sarah Kellen and Haley Robson. Sworn taped statements were taken from five victims and seventeen witnesses concerning massages and unlawful sexual activity that took place at the residence of Jeffrey Epstein, 358 El Brillo Way, Palm Beach. Several ofthe victims were recruited by and brought to the residence by Haley Robson to perform massages for Epstein, for which Robson received monetary compensation. During the visit they would be introduced to Sarah Kellen, Epstein’s assistant, who in turn would record their telephone numbers and name. The victims would be brought to Epstein’s bedroom to provide the massage. Epstein would enter the room and order the victims to remove their clothing to provide the massage. As the victims complied and provided the massages, Epstein would rub his fingers on their vaginas. On occasion, Epstein would introduce a massager/vibrator and rub the victims vaginas as they provided the massage. On three separate occasions, Epstein had intercourse and inserted his penis/fingers in the victims vaginas. At the conclusion of the massages the victims were paid sums of money ranging from $200 - $ 1,000. The facts, as reported, are as follows: On 03/15/2005, A fourteen year old white female, hereinafter referred to as ‘W dobl^H^B^ and her family reported unlawful sexual activity which occurred at a residence within the Town of Palm Beach. reported that a subject known to her as “Jeff’ had touched her vaginal area with a vibrator/massager while within his residence. “Jeff” was later identified as Jeffrey Epstein through a photo line up. During a sworn taped interview,••stated that Haley Robson, dob 04/09/1986, a cousin ofttl^^ boyfriend and classmate worked for a wealthy man and did sexual favors for him. She also admitted that Robson had offered her an opportunity to make money. During the beginning of the month of February 2005,••explained that she was first approached by Robson to go with her to Epstein’s house. •Stated that Robson along with a Hispanic female, later identified at<MfeO|MH^pick her up at her father’s house on a Sunday. i^^vas not sure of the exact dates but knew it was a Sunday. •• told her father that they were going shopping but in reality Robson drove them to Palm Beach. During the drive a The foregoing instrument was sworn to or affirmed State of Florida before me this 1” day of May, 2006 by County of Palm Beach Det Joe Recarey, who is personally known to me. p Signal u' rkesting Officer Signature of Police Officer (F.S.S. 117.10) 05701/2006 Page I of 22 CA/Aronberg-000833 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Probable Cause Affidavit Palm Beach Police Department Defendant: Race/Sex: DOB: Sarah Kellen White Female 05-25-1975 Agency ORI# FLO 500600 Police Case#: 05-368 (2) Charges: Principal in the 1st Unlawful Sexual Activity with a Minor ( 4) counts Principal in the pt Lewd and Lascivious Molestation (1) count From March 15, 2005, through February 2006, the Palm Beach Police Department conducted a sexual . battery investigation involving Jeffrey Epstein, Sarah Kellen and Haley Robson. Sworn taped statements were taken from five victims and seventeen witnesses concerning massages and unlawful sexual activity that took place at the residence of Jeffrey Epstein, 358 El Brillo Way, Palm Beach. Several of the victims were recruited by and brought to the residence by Haley Robson to perform massages for Epstein, for which Robson received monetary compensation. During the visit they would be introduced to Sarah Kellen, Epstein's assistant, who in turn would record their telephone numbers and name. The victims would be brought to Epstein's bedroom to provide the massage. Epstein would enter the room and order the victims to remove their clothing to provide the massage. As the victims complied and provided the massages, Epstein would rub his fingers on their vaginas. On occasion, Epstein would introduce a massager/vibrator and rub the victims vaginas as they provided the massage. On three separate occasions, Epstein had intercourse and inserted his penis/fingers in the victims vaginas. At the conclusion of the massages the victims were paid sums of money ranging from $200 - $1,000. The facts, as reported, are as follows: On 03/15/2005, A fourteen year old white female, hereinafter referred to as 'IIIJ dob- and her family reported unlawful sexual activity which occurred at a residence within the Town of Palm Beach. - reported that a subject known to her as "Jeff' had touched her vaginal area with a vibrator/massager while within his residence. "Jeff' was later identified as Jeffrey Epstein through a photo line up. During a sworn taped interview, ~tated that Haley Robson, dob 04/09/1986, a cousin of- boyfriend and classmate at•••••••••••worked for a wealthy man and did sexual favors for him. She also admitted that Robson had offered her an opportunity to make money. During the beginning of the month of February 2005,altexplained that she was first approached by Robson to go with her to Epstein's house. etated that Robson along with a Hispanic female, later identified at Q I pick her up at her father's house on a Sunday. t/8Nas not sure of the exact dates but knew it was a Sunday. - told her father that they were going shopping but in reality Robson drove them to Palm Beach. During the drive a The foregoing instrument was sworn to or affirmed before me this 15' day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) Page I of22 CA/Aronberg-000833 State of Florida County of Palm Beach FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 conversation occurred between Robson and* whereas Robson reportedly told•that if Jeff asked her age, she should say she was eighteen. It was later confirmed by the^^father that Robson picked his daughter up on February 6, 2005. According to••father, Robson drove a pick up truck. •(^described Epstein's house as a two-story pink house with a Cadillac Escalade parked in the driveway. She recalled that Jeffs house was on a dead end street. Upon arriving at the house^^stated that they walked up a driveway, past what appeared to be a small guard/security room. A male approaching them asking what they wanted. Robson stated they were there to see Epstein. The male allowed them to continue walking up to the house.^^^tated the man told them that Epstein was not there but was expected back. He allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside. Shortly thereafter, Epstein and his assistant, described as white female with blond hair and later identified as Sarah Kellen, entered the kitchen. Epstein introduced himself to described Epstein as being approximately forty-five years old, having a long face and bushy eyebrows, with graying hair. Robson and Epstein left the kitchen leaving®B alone in the kitchen. They returned a short time later. They all spoke briefly in the kitchen, ^^was instructed to follow Kellen upstairs. recalled walking up a flight of stairs, lined with photographs, to a room that had a massage table in it. Upon entering the room there was a large bathroom to the right and a hot pink and green sofa in the room. There was a door on each side of the sofa, ••recalled there being a mural of a naked woman in the room, as well as several photographs of naked women on a shelf. Kellen told the victim that Epstein would be up in a second. Epstein entered the room wearing only a towel and told•to take off her clothes. stated Epstein was stem when he told her to take off her clothes, •►said she did not know what to do as she was the only one there in the room so she took off her shirt leaving her bra on. Epstein had removed his towel and told the^^to take off everything. stated Epstein was nude when he took his towel off, placing it on the floor as he laid down on the table. ^Bstated she then removed her pants leaving her thong panties on. Epstein then instructed her to give him a massage pointing to a specific lotion for her to use. AsBB began to give Epstein the massage, he told her to get on his back. BBstated she straddled herself on Epstein’s back whereby her exposed buttocks were touching Epstein’s bare buttocks. ••said Epstein was specific in his instruction to her on how to massage him, telling her to go clockwise or counter clockwise. Epstein then turned over and instructed massage his chest, ••was now standing on the ground and resumed massaging Epstein’s chest area, ••stated Epstein held onto the small of her back as she massaged his chest and shoulder area. Epstein then turned to his side and started to rub his penis in an up and down motion. Epstein then pulled out a purple vibrator and began to The foregoing instrument was sworn to or affirmed before me this 1st day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida County of Palm Beach Signature/Anrekting Officer Date: 05/01/2006 Page 2of 22 CA/Aronberg-000834 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO S00600 conversation occurred between Robson and• whereas Robson reportedly told -that if Jeff asked her age, she should say she was eighteen. It was later confirmed by the I father that Robson picked his daughter up on February 6, 2005. According to .. father, Robson drove a pick up truck. -described Epstein's house as a two-story pink house with a Cadillac Escalade parked in the driveway. She recalled that Jeffs house was on a dead end street. Upon arriving at the house9stated that they walked up a driveway, past what appeared to be a small guard/security room. A male approaching them asking what they wanted. Robson stated they were there to see Epstein. The male allowed them to continue walking up to the house.9stated the man told them that Epstein was not there but was expected back. He allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside. Shortly thereafter, Epstein and his assistant, described as white female with blond hair and later identified as Sarah· Kellen, entered the kitchen. Epstein introduced himself to. • described Epstein as being approximately forty-five years old, having a long face and bushy eyebrows, with graying hair. Robson and Epstein left the kitchen leaving• alone in the kitchen. They returned a short time later. They all spoke briefly in the kitchen. ewas instructed to follow Kellen upstairs. -recalled walking up a flight of stairs, lined with photographs, to a room that had a massage table in it. Upon entering the room there was a large bathroom to the right and a hot pink and green sofa in the room. There was a door on each side of the sofa. ~ecalled there being a mural of a naked woman in the room, as well as several photographs of naked women on a shelf. Kellen told the victim that Epstein would be up in a second. Epstein entered the room wearing only a towel and told •to take off her clothes. - stated Epstein was stern when he told her to take off her clothes. tlasaid she did not know what to do as she was the only one there in the room so she took off her shirt leaving her bra on. Epstein had removed his towel and told thellt to take off everything. -stated Epstein was nude when he took his towel off, placing it on the floor as he laid down on the table. estated she then removed her pants leaving her thong panties on. Epstein then instrucJed her to give him a massage pointing to a specific lotion for her to use. As• began to.give Epstein the massage, he told her to get on his back. •stated she straddled herself on Epstein's back whereby her exposed buttocks were touching Epstein's bare buttocks. •said Epstein was specific in his instruction to her on how to massage him, telling her to go clockwise or counter clockwise. Epstein then turned over and instructed-o massage his chest. -.Was now standing on the ground and resumed massaging Epstein's chest area. llllstated Epstein held onto the small of her back as she massaged his chest and shoulder area. Epstein then turned to his side and started to rub his penis in an up and down motion. Epstein then pulled out a purple vibrator and began to The foregoing instrument was sworn to or affirmed before me this l5' day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police 0~ 117.10) Pagelof22· CNAronberg-000834 State of Florida County of Palm Beach Date: FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 massage MB vaginal area. IM stated there was no penetration as the vibrator was on top of her underwear. iMrecalled Epstein ejaculating because he had to use the towel to wipe himself as he got off the table. Epstein then left the room andl^got dressed. She went back downstairs where she met with Robson. BBsaid she was paid three hundred dollars in cash from Epstein. Before she left, Epstein asked^Bto leave her phone number. AsM Robson and were leaving the house, Robson told she received two hundred dollars that day for bringing her. During the course of the investigation, parental consent was granted for B^to assist with the investigation. At our direction ••conducted controlled taped phone calls to Robson’s cellular telephone 561- 308-0282. Wspoke with Robson in an attempt to arrange another meeting with Epstein, ^•usked Robson, what did she need to do to make more money. Robson stated, “the more you do, the more you get paid.” Robson had subsequently called back^Mand left a voice mail message for her indicating that she had set up an appointment foiBMto go to Epstein’s house at 11:00 am on April 5, 2005. This message was recorded from 1MB voice mail. Based on the above, trash pulls were established at Epstein’s residence with Supervisor Tony Higgins of the Sanitation Bureau of the Town of Palm Beach. The trash pull from April 5, 2005 revealed a telephone message for Epstein which stated Haley and•••name at 11:00 am. This was the time frame Robson had informed•• to be ready to go work at Epstein’s house. On October 3, 2005, Sgt Frick and I went to Robson’s residence and viewed her vehicle parked in the driveway, a red Dodge Neon. Sgt. Frick and I knocked on the door and met with Haley Robson. Robson was told that we were investigating a claim involving Jeffrey Epstein of El Brillo Way, in Palm Beach. Robson was asked if she would accompany us back to the police station for further questioning. She was also told that at the conclusion of the interview she would be returned home. Robson voluntarily came with us back to the Palm Beach Police Department. Upon our arrival at the police station, Robson was brought to the interview room in the Detective Bureau where I obtained a taped, sworn statement. I began the interview by asking Robson how she became acquainted with Epstein. Robson stated that approximately two years ago, just after she turned 17 years of age, she was approached by a friend named Molly at the Canopy Beach Resort in Rivera Beach. Robson was asked if she wanted to make money. She was told she would have to provide a massage and should make $200.00. Robson thought about the offer and agreed to meet with Jeffrey. The foregoing instrument was sworn to or affirmed State of Florida before me this 1st day of May, 2006 by County of Palrii Beach Det Joe Recarey, who is personally known to me. / Signature/Anresling Officer Signature of Police Officer (FfS.S. 117.10) Page3of 22 CA/Aronberg-000835 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 massage - vaginal area. - stated there was no penetration as the vibrator was on top of her underwear. 9recalled Epstein ejaculating because he had to use the towel to wipe himself as he got off the table. Epstein then left the room and-got dressed. She went back downstairs where she met with Robson. •said she was paid three hundred dollars in cash from Epstein. Before she left, Epstein asked.to leave her phone nwnber. As• Robson and g were leaving the house, Robson told. she received two hundred dollars that day for bringing her. During the course of the investigation, parental consent was granted for lllltto assist with the investigation. At our direction-conducted controlled taped phone calls to Robson's cellular telephone 561- 308-:0282. •spoke with Robson in an attempt to arrange another meeting with Epstein. 9isked Robson, what did she need to do to make more money. Robson stated, "the more you do, the more you get paid." Robson had subsequently called backtl9e.nd left a voice mail message for her indicating that she had set up an appointrnt:nt for9iltto go to Epstein's house at 11 :00 am on April 5, 2005. This message was recorded from - voice mail. Based on the above, trash pulls were established at Epstein's residence with Supervisor Tony Higgins of the Sanitation Bureau of the Town of Palm Beach. The trash pull from April 5, 2005 revealed a telephone message for Epstein which stated Haley andlllatname at 11 :00 am. This was the time frame Robson had informed- to be ready to go work at Epstein's house. On October 3, 2005, Sgt Frick and I went to Robson's residence and viewed her vehicle parked in the driveway, a red Dodge Neon. Sgt. Frick and I knocked on the door and met with Haley Robson. Robson was told that we were investigating a claim involving Jeffrey Epstein of El Brillo Way, in Palm Beach. Robson was asked if she would accompany us back to the police station for further questioning. She was also told that at the conclusion of the interview she would be returned home. Robson voluntarily came with us back to the Palm Beach Police Department. Upon our arrival at the police station, Robson was brought to the interview room in the Detective Bureau where I obtained a taped, sworn statement. I began the interview by asking Robson how she became • acquainted with Epstein. Robson stated that approximately two years ago, just after she turned 17 years of age, she:was approached by a friend named Molly at the Canopy Beach Resort in Rivera Beach. Robson was asked if she wanted to make money. She was told she would have to provide a massage and should make $200.00. Robson thought about the offer and agreed to meet with Jeffrey. The foregoing instrument was sworn to or affirmed before me this 15' day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Page,3of22 CA/ Aron berg-000835 State of Florida FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 Molly (Unknown last name) and Tony (Unknown last name) picked Robson up and she was taken to Epstein’s house. Upon her arrival to the house she was introduced to Epstein in the kitchen of the house. She was also introduced to a white female known to her as Sarah. She was led upstairs to the main bedroom known to her as JeffEpstein s bedroom. Sarah arranged the massage table and covered the table with a sheet. She brought out the massage oils and laid them next to the massage bed. Sarah, then left the room and informed Robson Jeff would be in, in a minute. Jeff entered the bedroom wearing only a towel. He removed the towel and laid nude on the massage table. He laid on the table onto his stomach and picked a massage oil for Robson to rub on him. During the massage, Robson stated “He tried to touch me and I stopped him.” I asked how he tried to touch her. Robson stated that Epstein grabbed her buttocks and she felt uncomfortable. Robson told Epstein, 111 massage you but I don’t want to be touched. Robson stated she performed the massage naked. At the conclusion of the massage, Epstein paid Robson $200. After the massage Epstein stated to Robson that he understood she was not comfortable, but he would pay her if she brought over some girls. He told her the younger the better. Robson stated she once tried to bring a 23 year old female and Epstein stated that the female was too old. Robson stated that in total she only remembers six girls that she brought to see Epstein, each time she was paid $200. Robson stated she had brought the follovnn^irls: ( al6 year old female),I® (a 16 year old female) andflflP^D Robson said that at the time she brought these girls to Epstein’s house they were all 14 through 16 years of age. I asked Robson which one was the youngest. Robson advised was the youngest as she was fourteen when the massage occurred. Robson stated every girl she brought knew what to expect when they arrived. They were told they would provide a massage, possibly naked, and allow some touching. I asked herif^ was aware. She stated every girl she brought knew what to expect. She explained she knew thatM wanted to make money. She approached®^nd explained about going to work for JeffOagreed and arrangements were made to bring her to Epstein’s house on a weekend. Robson stated that she andMH* (Later identified picked upOfct her house. Robson stated that at that time she was driving a red pickup truck. They traveled to Epstein’s house and entered through the kitchen door. They met with the house chefand Epstein s assistant Sarah. O^kvas introduced to Epstein while they were in the kitchen area. Sarah led^^upstairs and Epstein went upstairs. When the massage was over^Oteturned to the kitchen area. Robson stated she was paid $200.00 for bringingflfco Epstein’s house. Robson stated OOtold her she was paid $300.00 for the massage. Robson stated that^^was the last person she brought to Epstein’s house. She had changed her cellular number to avoid being contacted by Sarah. She continued stating that she had no direct contact with Epstein The foregoing instrument was sworn to or affirmed before me this 1” day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida County ofPalm Beach Signature/Arresting Officer Date: 0^71)1/2006 PageMof22 CA/Aronberg-000836 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 Molly (Unknown last name) and Tony (Unknown last name) picked Robson up and she was taken to Epstein's house. Upon her arrival to the house she was introduced to Epstein in the kitchen of the house. She was also introduced to a white female known to her as Sarah. She was led upstairs to the main bedroom known to her as Jeff Epstein's bedroom. Sarah arranged the massage table and covered the table with a sheet. She brought out the massage oils and laid them next to the massage bed. Sarah, then left the room and informed Robson Jeff would be in, in a minute. Jeff entered the bedroom wearing only a towel. He removed the towel and laid nude on the massage table. He laid on the table onto his stomach and picked a massage oil for Robson to rub on him. During the massage, Robson stated "He tried to touch me and I stopped him." I asked how he tried to touch her. Robson stated that Epstein grabbed her buttocks and she felt uncomfortable. Robson told Epstein, I'll massage you but I don't want to be touched. Robson stated she performed the massage naked. At the conclusion of the massage, Epstein paid Robson $200. After the massage Epstein stated to Robson that he understood she was not comfortable, but he would pay her if she brought over some girls. He told her the younger the better. Robson stated she once tried to bring a 23 year old female and Epstein stated that the female was too old. Robson stated that in total she only remembers six girls that she brought to see Epstein, each time she was paid $200. Robson stated she had brought the following girls:•.- 7 &,$ -•-( al6 year old female),.(a 16 year old female) and-Robson said that at the time she brought these girls to Epstein's house they were all14 through 16 years of age. I asked Robson which one was the youngest. Robson advised -was the youngest as she was fourteen when the massage occurred. Robson stated every girl she brought knew what to expect when they arrived. They were told they would provide a massage, possibly naked, and allow some touching. I asked her i. was aware. She stated every girl she brought knew what to expect. She explained she knew that. wanted to make money. She approachedlliltand explained about going to work for Jeff,.agreed and arrangements were made to bring her to Epstein's house on a weekend. Robson stated that she and (Later identified as~ picked up9:it her house. Robson stated that at that time she was driving a red pickup truck. They traveled to Epstein's house and entered through the kitchen door. They met with the house chef and Epstein's assistant Sarah.119Nas introduced to Epstein while they were in the kitchen area. Sarah led.upstairs and Epstein went upstairs. When the massage was over .. etumed to the kitchen area. Robson stated she was paid $200.00 for bringing-to Epstein's house. Robson stated •told her she was paid.$300.00 for the massage. Robson stated thatawas the last person she brought to Epstein's house. She had changed her cellular number to avoid-being contacted by Sarah. She continued stating that she had no direct contact with Epstein The foregoing instrument was sworn to or affirmed before me this 151 day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Page'iof 22 CA/ Aron be rg-000836 State of Florida County of al Beach FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 when he was going to travel to Palm Beach. Robson said when Epstein announces to his assistant, Sarah, that he is traveling to Palm Beach, Sarah would then contact Robson to arrange girls to “work” for Epstein. Robson stated that once her parents discovered that she was visiting Epstein, they disapproved of the encounters with him and she stopped. Robson further stated that Sarah still tries to call Robson’s house and leaves messages. Sgt Frick entered the room and explained to Robson that based on her own statements, she had implicated herself by bringing underage girls to Epstein’s house. Robson provided cellular telephone numbers for the girls she had mentioned previously. Additionally, she also provided possible addresses and areas in which they lived. As Robson was being taken home in the vehicle, a tape recorder was placed within the vehicle to record any conversations within the vehicle. During the drive back to her home, Robson made the comment “ I’m like a Heidi Fleiss.” (Hollywood Madam who sent girls to clients for sexual favors in California). Robson was dropped off at her house without incident. On October 3, 2005, Sgt Frick and I went to speak with^^a sixteen year-old female who was brought to Epstein’s residence by Haley Robson. We met with mother at their frontdoor. We explained the ongoing investigation and asked to speak with^^s we had information that she had “worked” for Jeff. Mrs. ♦introduced us to her husband and allowed us entry into the home. We sat in the dining room and met with^ Date ofBirthAs she was under the age of eighteen, Mrs^was advised we would be speaking with her. She expressed if her daughter had information, she wanted to assist. We interviewed 0? who denied having any inappropriate encounters with Jeff (Epstein). She stated she had gone to Jeffs house with Haley Robson approximately eight months ago and sat in the kitchen with the house chef, but nothing happened. As the parents were present during the interview, we felt that•was withholding information from us. She made several comments as to putting the entire incident behind her. I left my telephone number and advised should she wish to speak with me again to telephone me. Sgt Frick and I thanked Mrs.• for her time and left the area. She stated she would askl^again after we left as to what happened at Epstein’s house. I informed her thatO had my telephone number and hopefully she would call. On October 4, 2005, Det Dawson and I drove to theMHKiome and met withflHIB l^H^and doblMm^B During a sworn taped statement,•P^B^Vstated approximately a year ago when she was seventeen years old, she was taken to a house by Haley Robson, ^■•stated she knows Robson because they both attend She was told she could make money working The foregoing instrument was sworn to or affirmed State of Florida before me this 1“ day of May, 2006 by County of Palm Beach Det Joe Recarey, who is personally known to me. Kj Signati re/Arresting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/2006 Page Sof 22 CA/Aronberg-000837 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 when he was going to travel to Palm Beach. Robson said when Epstein announces to his assistant, Sarah, that he is traveling to Palm Beach, Sarah would then contact Robson to arrange girls to "work" for Epstein. Robson stated that once her parents discovered that she was visiting Epstein, they disapproved of the encounters with him and she stopped. Robson further stated that Sarah still tries to call Robson's house and leaves messages. Sgt Frick entered the room and explained to Robson that based on her own statements, she had implicated herself by bringing underage girls to Epstein's house. Robson provided cellular telephone numbers for the girls she had mentioned previously. Additionally, she also provided possible addresses and areas in which they lived. As Robson was being taken home in the vehicle, a tape recorder was placed within the vehicle to record any conversations within the vehicle. During the drive back to her home, Robson made the comment "I'm like a Heidi Fleiss." (Hollywood Madam who sent girls to clients for sexual favors in California). Robson was dropped off at her house without incident. On October 3, 2005, Sgt Frick and I went to speak with.a sixteen year-old female who was brought to Epstein's residence by Haley Robson. We met with -mother at their front door. We explained the ongoing investigation and asked to speak with~ we-had information that she had "worked".for Jeff. Mrs. •introduced us to her husband and allowed us entry into the home. We sat in the dining room and met with .. Date of Birth- As she was under the age of eighteen, Mrsewas advised we would be speaking with her. She expressed if her daughter had information, she wanted to assist. We interviewed~ who denied having any inappropriate encounters with Jeff (Epstein). She stated she had gone to Jeffs house with Haley Robson approximately eight months ago and sat in the kitchen with the house chef, but nothing happened. As the parents were present during the interview, we felt that-was withholding information from us. She made several comments as to putting the entire incident behind her. I left my telephone number and advised should she wish to speak with me again to telephone me. Sgt Frick and I thanked Mrs.• for her time and left the area. She stated she would ask9again after we left as to what happened at Epstein's house. I informed her that• had my teleph0ne number and hopefully she would c~,t/. • •• 011 October 4, 2005, Det Dawson and I drove to the L.ome and met with and dob .. . During a sworn taped statement, _, •• 9!itated approximately a year ago when she was seventeen years old, she was taken to a house by Haley Robson. •••stated she knows Robson because they both attend ■■•■ ■■••. She was told she could make money working The foregoing instrument was sworn to or affirmed before me this P' day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Page5of22 CA/Aronberg-000837 State of Florida County Date: FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 for Jeff. She was told she would have to provide a massage to Jeff. stated upon her arrival to the house she was brought to the kitchen area by Robson. They met with the house chef who was already in the kitchen area, O^Bstated Haley Robson would wait for her in the kitchen. ^|^was introduced to Sarah, Jeffs assistant, who brought her upstairs to the master bedroom. Sarah prepared the room and massage table for a massage. Epstein entered the room wearing only a towel and she provided a massage. OIB stated she kept her clothes on during the massage. She advised sometime during the massage, Epstein grabbed her buttocks and pulled her close to him. said she was uncomfortable by the incident involving Jeff. At the conclusion of the massage, she was paid $200.00 for the massage. I asked if she has any formal training in massages to which she replied no. I asked her if Robson received any monies for taking her to perform the massage. stated Robson had received money for taking her there but was unsure in the amount. fl^B stated she returned to Epstein’s house on another occasion with Robson and another girl,■■■■■! stated she waited in the kitchen with Robson, while was taken upstairs by Sarah. ^I^Bstated she only did the massage once as she was uncomfortable with the whole experience. At the conclusion of the interview, the tape was stopped. I was informed that Sarah had attempted to reach■■■via cell phone. A voice mail message on October 4, 2005 at 10:59 am, revealed a female voice who identified herself as Sarah who requested■■•to call her back reference the police questioning. provided the incoming telephone number as 917-855-3363.^•stated she inadvertently told ■^■M^B about the police investigation becauseBHB had called her to tell her about how she just received a rental car from Jeff Epstein,■■■■had called her to tell her that she was given a rental car, a 2005 Silver Nissan Sentra, to utilize to visit family and visit Epstein, asked her what was going on at the house that the police would be asking questions. stated■■■Bfl^M then called Jeff and Sarah and asked what was going on reference the ongoing police investigation. According toiM*Sarah has since then been trying to contact her to ask about the police questions. I instructedB^B^B not to contact Sarah and do not provide any more information to■■■Bas she would notify Jeff Epstein and Sarah what was transpiring. On October4, 2005,1 made telephone contact withBbwho had left several messages for me to contact her. During the message, she advised she was not completely truthful when we met in person but would like to speak with me to advise what had happened. She further advised she did not want to speak of this incident in front of her mother. At approximately 3:48 pm I made telephone contact withBB During a taped recorded statement^Bstated the following: approximately a year ago, when she was sixteen years of age, Robson took her to Epstein’s house twice. Shejcnows Robson because they both attend■•■IMIBBBVBBMBBr' time she went, Haley Robson drove to the house. They entered throughthe kitchen area where she was he first The foregoing instrument was sworn to or affirmed before me this lsl day of May, 2006 by Det Joe Recarey, who is personally known to me. State of Florida County of Palm Beach Signature/Arresting Officer Signature of 117.10) Date: 05/01/2006 Page^of 22 CA/Aronberg-000838 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 for Jeff. She was told she would have to provide a massage to Jeff. ... stated upon her arrival to the house she was brought to the kitchen area by Robson. They met with the house chef who was already in the kitchen area. C ;tated Haley Robson would wait for her in the kitchen .... was introduced to Sarah, Jeff's assistant, who brought her upstairs to the master bedroom. Sarah prepared the room and massage table for a massage. Epstein entered the room wearing only a towel and she provided a massage. ••t stated she kept her clothes on during the massage. She advised sometime during the massage, Epstein grabbed her buttocks and _pulled her close to him.••- said she was uncomfortable by the incident involving Jeff. At the conclusion of the massage, she was paid $200.00 for the massage. I asked•-~if she has any formal training in massages to which she replied no. I asked her if Robson received any monies for taking her to perform the massage. - stated Robson had received money for taking her there but was unsure in the amount. ••l stated she returned to Epstein's house on another occasion with Robson and another girl,•••1-- ••tstated she waited in the kitchen with Robson, while .. was taken upstairs by Sarah. S ;tated she only did the massage once as she was uncomfortable with the whole ·experience. At the conclusion of the interview, the tape was stopped. I was informed that Sarah had attempted to reach••~via celJ phone. A voice mail message on October 4, 2005 at 10:59 am, revealed a female voice who identified herself as Sarah who requested to call her back reference the police questioning. ... provided the incoming telephone number as 917-855-3363 . ._stated she inadvertently told abc;rn_t.the police investigation because .. had called her to tell her about how she just received a rental car from Jeff Epstein. had called her to tell her that she was given a rental car, a 2005 Silver Nissan Sentra, to utilize to visit family and visit Epstein. t1ll9 asked her what was going on at the house that the police would be asking questions.•••stated•••••then.called Jeff and Sarah and asked what was going on reference the ongoing poli~e investigation. According to•••Sarah has si•nce then been trying to contact her to ask about the police questions. I instructed not to contact Sarah and do not provide any more information to•••as she would notify Jeff Epstein and Sarah what was transpiring. On October4, 2005, I made telephone contact with awho had left several messages for me to contact her. During the message, she advised she was not completely truthful when we met in person but would like to . ,s. speak with me to advise what had happened. She further advised she did not want to speak of this incident in front of her mother. At approximately 3:48 pm I made telephone contact with8 During a taped recorded :~a~;~~~:eed !:!~l~i:~~~:;oxb::t~:c:~s:~ae~oble~tl~~ was sixteen years qf _a&Jt-Rpbn t~o~r~:r ti~t;;he went, Haley Rob~;~drove to the house. They entered thl~~gh th!·kftch~n ar\;:a where she was The foregoing instrument was sworn to or affirmed before me this r• day of May, 2006 by Det Joe Recarey, who is personally known to me. Page'-of 22 CNAronberg-000838 - .... ll State of Florida County of Pal Beach FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 introduced to Sarah and Epstein. She was taken upstairs to a bedroom by Sarah who set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for*to rub on him. At one point during the massage he tried to remove her shirt, at which point she became very upset and discontinued the massage. Both*and Epstein had a verbal disagreement, at which time she left without being paid. She got with Haley Robson who was sitting in the kitchen and told her “let’s go.” •Badvised she received no money for that day.^Balso said that Haley Robson had told her if she was uncomfortable with what was going on, to let him know and he’ll stop. She knew that the more you do the more you get paid. ■•advised that several weeks later she agreed to be taken a second time by Haley Robson. Once they arrived at the residence, Haley Robson sat in the kitchen and Sarah took her upstairs to the master bedroom again. Sarah set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for^to rub on him. At one point during the massage he tried to touch her buttocks. As ^•vas wearing tightjeans and had a tight belt on Epstein was unable to touch her buttocks. Epstein then rolled onto his back during the massage and then attempted to touch her breasts.••then became upset again and told Epstein she didn’t want to be touched, •■discontinued the massage and was paid $200.00.^then went downstairs where Haley Robson was waiting for her. She told Robson she wanted to leave, ^^aid she never returned to the house.^Bstated she is aware that her ffiend,IBlB^4BB^was also at the house and had a problem with Epstein. 1 later researchedBIBB^BB^^dob •M^M^and met with her at her residence. During a sworn taped statement,stated the following: on or about November 2004, she was approached atB^H^^^ •HBHHHBBBby Haley Robson, a fellow student. Robson askedI^H^if she wanted to make money. She agreed and was told she would provide a massage to wealthy man in Palm Beach. Robson picked her up and drove her to a house in Palm Beach. She was brought into the kitchen area of the house. She further stated that fellowflBMH^BBHBB^^HP^tudents andBHMbBBB came with them. They were brought into the kitchen where she was introduced to Epstein and other females.OB* stated she was introduced to a female helper of Epstein, the female was described as white female (unknown name ), with blond hair. She stated that the assistant was familiar with Robson. The assistant brought her upstairs into a master bedroom area. The assistant set up the massage table and put out lotions to be used. She told BHIB Epstein would be available in a minute. Epstein entered the room wearing only a towel. Epstein removed his towel, and laid naked on the massage table and picked a lotion to rub on his thighs and back. ^BMV further stated during the massage, Epstein asked her to remove her clothes. She complied and removed her pants and blouse.^^H^didn’t remember if she had removed her bra but feels that she did. ^B^Awas certain that she stayed in her thong underwear.BBSB continued the massage and at one point she climbed onto the massage The foregoing instrument was sworn to or affirmed before me this ls< day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida County of Palm Beach Signature/Arresting Officer Date: 05/BF/2006 Page7 of 22 CA/Aronberg-000839 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO S00600 introduced to Sarah and Epstein. She was taken upstairs to a bedroom by Sarah who set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for ato rub on him. At one point during the massage he tried to remove her shirt, at which point she became very upset and discontinued the massage. Both •and Epstein had a verbal disagreement, at which time she left without being paid. She got with Haley Robson who was sitting in the kitchen and told her "let's go." -advised she received no money for that day.-also said that Haley Robson had told her if she was uncomfortable with what was going on, to let him know and he'll stop. She knew that the more you do the more you get paid. •advised that several weeks later she agreed to be taken a second time by Haley Robson. Once th_ey arrived at the residence, Haley Robson sat in the kitchen and Sarah took her upstairs to the master bedroom again. Sarah set the room up with a massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for9to rub on him. At one point during the massage he tried to touch her buttocks. As -..Vas wearing tight jeans and had a tight belt on Epstein was unable to touch her buttocks. Epstein then rolled onto his back during the massage and then attempted to touch her breasts.athen became upset again and told Epstein she didn't want to be touched. ealiscontinued the massage and was paid $200.00. 9fuen went downstairs where Haley Robson was waiting for her. She told Robson she wanted to leave .... aid she never returned to the house. estated she is aware that her friend,Q L was also at the house and had a problem with Epstein. I later researched dob and met with her at her residence. During a sworn taped statement,.•-~stated the following: on or about November 2004, she was approached at y Haley Robson, a fellow student. Robson asked 'f she wanted to make money. She agreed and was told she would provide a massage to wealthy man in Palm Beach. Robson picked her up and drove her to a house in Palm Beach. She was brought into the kitchen area of the house. She further stated that fellowt1•■ •••■I tudents •and ....... came with them. They were brought into the kitchen where she was introduced to Epstein and other females.■•• stated she was introduced to a female helper of Epstein, the female was described as white female (unknown name ), with blond hair. She stated that the assistant was familiar with Robson. The assistant brought her upstairs into a master bedroom area. The assistant set up the massage table and put out lotions to be used. She told Epstein would be available in a minute. Epstein entered the room wearing only a towel. Epstein removed his towel, and laid naked on the massage table and picked a lotion to rub on his thighs and back. ••• further stated during the massage, Epstein asked her to remove her clothes. She complied and removed her pants and blouse.9lltdidn't remember if she had removed her bra but feels that she did. •••was certain that she 1 stayed in her thong underwear. I ■ continued the massage and at one point she climbed onto the massage The foregoing instrument was sworn to or affirmed before me this 1 s' day of May, 2006 by Det Joe Recarey, who is personally known to me. Page7 of22 CA/Aronberg-000839 State of Florida County of Palm Beach ting Officer Date: FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 table, straddling Epstein to massage his back. While doing this her buttocks were touching Epsteins. 4H^* was instructed to return to the ground at which time Epstein turned to have his chest rubbed.^0* advised she was sure he was masturbating based on his hand movements going up and down on his penis area. flflifldid not want to look at his penis area because she was uncomfortable. Epstein removed a large white vibrator which was next to the massage table and turned it on.flflfl stated Epstein began rubbing the vibrator over her thong underwear on her vaginal area. Shortly thereafter, Epstein ejaculated and removed himself from the table. He walked over to where the shower was and opened the glass door. She waited as he was taking a shower in her direct view. When I asked^^flhow old she was when this occurred, she stated she had just turned seventeen. At the conclusion of the shower,fl|^fl was paid either $350.00 or $400.00. She stated she wasn’t sure, but knows it was close to $400.00. flM*stated she never returned to provide a massage for Epstein. At approximately 2:10 pm, Det Dawson and I met withfl, dob flflflfl) at her residence. Asfl* was only seventeen years of age, I had notified her mother, that she would be interviewed reference an ongoing investigation in Palm Beach. I assured her that her daughter was not a suspect. I explained the possibility of her being either a witness or victim. Mrsfladvised she wanted1^* to cooperate and consented to the interview. During a sworn taped statement,fl* stated the following: at the age of sixteen, during the month of September 2004, she was approached by Haley Robson for a chance to make money.*flwas friends with associates of Robson and knew the same people, fl* had been previously told by her friends from flH^fl* ^^flflBB^^*flwhat Robson did for Epstein. Robson called a person known tofl*as Sarah and scheduled the appointment. Robson pickedfflup and drove her to Palm Beach to a street called “Brillo Way”. They drove to the end of the street and entered a large driveway. They entered the kitchen area of the house and met with Epstein, fl*was introduced to Jeff Epstein. Robson ledfl*upstairs to the main bedroom area and set up the room with a massage table and set out the oils, flflstated that while going up the stairs and into the bedroom she observed numerous photographs of naked young girls. Robson dimmed the lights and turned on soft music. Robson exited the room and Epstein entered the room wearing only a towel. Epstein picked oils and instructed her to rub his legs, under his buttocks, back and chest area. Epstein asked her to get comfortable, fl* advised she did not remove her clothes. She was wearing tightjeans and a cropped tank top exposing her belly area. During the massage, Epstein removed his towel and laid on the massage table naked. As flrubbed Epstein’s chest area, he attempted to reach down her pants to touch her buttocks area however was unable to due so due to the tightness of the jeans and a tight belt, fl* advised Epstein began to masturbate as she rubbed his chest. Epstein moaned as she rubbed his chest. She observed he was continuing to masturbate and The foregoing instrument was sworn to or affirmed before me this Is' day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of PoliceZfrficer (F.S.S. 117.10) State of Florida County of Palm Beach SignatureU/rreYtingOfficer Date: 05/01/2006 Page8of 22 CA/Aronberg-000840 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 table, straddling Epstein to massage his back. While doing this her buttocks were touching Epsteins. .... was instructed to return to the ground at which time Epstein turned to have his chest rubbed. - advised she was sure he was masturbating based on his hand movements going up and down on his penis area. ••ladid not want to look at his penis area because she was uncomfortable. Epstein removed a large white vibrator which was next to the massage table and turned it on.••• stated Epstein began rubbing the vibrator over her thong underwear on her vaginal area. Shortly thereafter, Epstein ejaculated and removed himself from the table. He walked over to where the shower was and opened the glass door. She waited as he was taking a shower in her direct view. When I asked•••:how old she was when this occurred, she stated she had just turned seventeen. At the conclusion of the shower,•••was paid either $350.00 or $400.00. She stated she wasn't sure, but knows it was close to $400.00. •■lll~tated she never returned to provide a massage for Epstein. At approximately 2: 10 pm, Det Dawson and I met with a, dob at her residence. Asaa was only seventeen years of age, I had notified her mother, that she would be interviewed reference an ongoing investigation in Palm Beach. I assured her that her daughter was not a suspect. I explained the possibility of her being either a witness or victim. Mrs.dvised she wanted .. to cooperate and consented to the interview. During a sworn taped statement,-stated the following: at the age of sixteen, during the month of September 2004, she was approached by Haley Robson for a chance to make money . .-Was friends with associates of Robson and knew the same people. a had been previously told by her friends from - ~hat Robson did for Epstein. Robson called a person known to9as Sarah and scheduled the appointment. Robson picked-up and drove her to Palm Beach to a street called "Brillo Way". l They drove to the end of the street and entered a large driveway. They entered the kitchen area of the house and met with Epstein. -was introduced to Jeff Epstein. Robson led-upstairs to the main bedroom area and set up the room with a massage table and set out the oils. ~tated that while going up the stairs and into the bedroom she observed numerous photographs of naked young girls. Robson dimmed the lights and turned on soft music. Robson exited the room and Epstein entered the room wearing only a towel. Epstein picked oils and instructed her to rub his legs, under his buttocks, back and chest area. Epstein asked her to get comfortable. • advised she did not remove her clothes. She was wearing tight jeans and a cropped tank top exposing her belly area. During the massage,_ Epstein removed his towel and laid on the massage table naked. As •rubbed Epstein's chest area, he attempted to reach down her pants to touch her buttocks area however was unable to due so due to the tightness of the jeans and a tight belt. -advised Epstein began to masturbate as she rubbed his chest. Epstein moaned as she rubbed his chest. She observed he was continuing to masturbate and The foregoing instrument was sworn to or affirmed before me this 1 51 day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Page8of22 CA/Aronberg-000840 State of Florida FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 attempted to reach up her tank top and touch her breasts. pulled back and EpStein stopped, however he kept masturbating until he climaxed. He cleaned himself with the towel he was previously wearing, lb was paid $200.00 for the massage and left the area. She met with Robson who was waiting in the kitchen area and left the house. •then explained she never provided another massage for Epstein. She did however, go to the house with Robson and^^H^^^^as they took another friend of Robson’s. ^Badvised she was present when tffl^flHH^vent to work for Epstein. She advised she rode over and sat in the kitchen area with Robson to wait for^H^^ ••advised while they waited the house chefprepared lunch for them as it was almost lunchtime when they went. When^fl^was finished with the massage they left the area. I askedA if Robson ever told her what would be expected when she provided a massage. stated yes, Robson told her that a massage would be expected, possibly naked and possibly some touching involved. B^has no formal training in providing massages. spoke about a third and last time she went to Epstein’s house. Robson drove another girl,(sixteen years of age) who istf^Bfriend, to Epstein’s house. stated••knew that ^►had made money massaging Epstein and wanted to make money herself. Robson took them in the kitchen area of the house and introducedfl* to Sarah. Robson and Sarah took•■upstairs to the main bedroom. advised she doesn’t know what happened as^^did not speak about what happened in the room. ■•received $100.00 from Robson for going with her to Epstein’s house and recommending■■• On October 6, 2005, at 11:45 am, I met with ■iMBPflHBdob at^|^®BI^B^ and explained to her why we there to interview her. She advised she was aware of the ongoing investigation. ■■• stated she had previously spoken with^^ ■■•who told her she was interviewed by detectives. During a sworn taped statement,stated she knew that Haley Robson worked for Jeff Epstein in Palm Beach, flb advised she originally had been taken to the Epstein house by Haley Robson, whom she met when they both attendedShe began going to the house when she was sixteen years of age and stated she had been there a lot of times to provide massages over the past two years. I asked her if she had formal training in providing massages, whichlH®stated she had not. flBiadvised she was told what was expected of her by providing massages and she would have to remove clothing but if she felt uncomfortable just to say so and Epstein would stop pushing the issue.•■•began providing massages and advised she kept her clothes on. She considered Epstein a pervert and he kept pushing to go further and further, ■••explained she would keep telling him she had a boyfriend and would not be right to her boyfriend. It wasn’t until recently that ■* began removing her clothes and staying in her thong underwear to provide a massage, ■■•explained The foregoing instrument was sworn to or affirmed State of Florida before me this lsl day of May, 2006 by County of Palm Beach Det Joe Recarey, who is personally known to me. \\/K Signature of Police Officer (F.S.S. 117.10) Signaturl/^rkesting Officer Date: 05/01/2006 Page%f 22 CA/Aronberg-000841 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 attempted to reach up her tank top and touch her breasts . ._ pulled back and Epstein stopped, however he kept masturbating until he climaxed. He cleaned himself with the towel he was previously wearing. a was paid $200.00 for the massage and left the area. She met with Robson who was waiting in the kitchen area and left the house . .. then explained she never provided another massage for Epstein. She did however, go to the house with Robson and••-~as they took another friend of Robson's. •advised she was present when ,,;.:ent to work for Epstein. She advised she rode over and sat in the kitchen area with Robson to wait for ~dvised while they waited fo,ra•• the house chef prepared lunch for them as it was almost lunchtime when they went. WheJ ···as finished with the massage they left the area. • ·r asked• if Robson ever told her what would be expected when she provided a massage. ■ stated yes, Robson told her • that a massage would be expected, possibly naked and possibly some touching involved ... bas no formal training in providing massages. -spoke about a third and last time she went to Epstein's house. Robson drove another girl, .. (sixteen years of age) who i•••friend, to Epstein's house.-stated .. knew that ehad made money massaging Epstein and wanted to make money herself. Robson took them in the kitchen area of the house and introduced• to Sarah. Robson and Sarah took-upstairs to the main bedroom. - advised she doesn't know what happened ~did not speak about what happened in the room. •received $ I 00.00 from Robson for going with her to Epstein's house and recommencling- On October 6, 2005, at 11 :45 am, I met with ••IN-ltdob -• ~ Q 3 ) md explained to her why we there to interview her. She advised she was aware of the ongoing investigation ... stated she had previously spoken withll9 a•t1who told her she was interviewed by detectives. During a sworn taped statement, .. stated she knew that Haley Robson worked for Jeff Epstein in Palm Beach. ... advised she originally had been taken to the Epstein house by Haley Robson, whom she met when they both attended ■■••■ She began going to the house when she was sixteen years of age and stated she had been there a lot of times to provide massages over the past two years. I asked her if she had formal training in providing massages, whichllllllastated she had not. alladvised she was told what was expected of her by providing massages and she would have to remove clothing but if she felt uncomfortable just to say so and Epstein would stop pushing the issue .... began providing massages and advised she kept her clothes on. She considered Epstein a pervert and he kept pushing to go further and further .... explained she would keep telling him she had a boyfriend and would not be right to her boyfriend. It wasn't until recently that -began removing her clothes and staying in her thong underwear to provide a massage. ~xplained The foregoing instrument was sworn to or affirmed before me this 151 day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Page~ of 22 CA/Aronberg-000841 esting Officer FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 Epstein wanted to be rubbed on his back and recently he began turning over and have her rub his chest as he masturbated. He would try to touch her breasts as she rubbed his chest. ■■•stated “Jeff would try to get away with more and more on each massage”, ■^•stated Epstein would try to touch her more and on one occasion he attempted to use a massager/vibrator on her. Robson drove■■to the house for the original massage. ■■ left Sarah her cell phone number and every time Epstein would come into town, Sarah would call her for an appointment to “work”. Each time she went, Sarah would meet her at the kitchen door area. She would bring her upstairs and prepare the massage table, •■•advised Epstein would ask her questions about herself. Epstein knew she was a soccer player and would be attending^iBflS^|^ I asked■■if Epstein knew her real age.®B^ stated Epstein did and didn’t care. The most recent massage she provided was on October 1, 2005. During the massage, she asked Epstein if she could borrow one of his vehicles to visit her family and boyfriend in Orlando, Florida. Epstein had told her she could borrow one of his vehicles but later stated he would rent her a car. She continued with the massage as Epstein grabbed her buttocks and caressed the buttocks cheeks. I askedOB^if she was wearing undergarments to which she replied_her thong underwear. Once he tried to touch her breasts, she would pull away from him and he would stop, ^^^was asked if he ever used a vibrator on her. ■•was aware of the vibrator but advised she never would allow him to use the vibrator on her.. She described 4he vibrator as the large white vibrator with a huge head on the tip of the vibrator. She stated he kept the vibrator in a closet near the massage table. * •' ^■stated that on October 3, 2005, she was contacted by Epstein’s assistant, Sarah, who informed her that JeffEpstein had rented her a new Nissan Sentra and she should come by the house to pick it up. Sarah informedOBBshe would have the car for a month. ■■stated Epstein knew her car was not working properly and that she had missed appointments in the past because of her car being inoperable. ■■Explained the car is currently parked next to theB^BflH^^Gym field. I asked her if she ever took any one to the house. explained she took a friend of hers who attendedBBPIHMBMBBBBBI^B_who has relocated to Orlando to attend college. I asked if she ever allowed another female in the room. ^^•advised no one was brought into the room with her. At the conclusion of the interview, Det Dawson and 1 went to the gym area and located the Silver Nissan Sentra bearing Florida tag X98-APM . The vehicle is registered to Dollar Rent a Car out of the Palm Beach International Airport. The vehicle was rented by Janusz Banasiack, later learned to be Epstein’s houseman, and paid with Epstein’s credit card. On September 11,2005, w/f€R dob was arrested by the Palm Beach Police Department The foregoing instrument was sworn to or affirmed State of Florida before me this Is* day of May, 2006 by County of PalmJBeach Det Joe Recarey, who is personally known to me. < /I / Signatur iting Officer Signature of Police Officer (F.S.S. 117.10) Date: 05701/2006 PagelOof 22 CA/Aronberg-000842 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 Epstein wanted to be rubbed on his back and recently he began turning over and have her rub his chest as he masturbated. He would try to touch her breasts as she rubbed his chest. ~tated "Jeff would try to get away with more and more on each massage". • stated Epstein would try to touch her more and on one occasion he attempted to use a massager/vibrator on her. Robson drove-to the house for the original massage. - left Sarah her cell phone number and every time Epstein would come into town, Sarah would call her for an appointment to ''work". Each time she went, Sarah would meet her at the kitchen door area. She would bring her upstairs and prepare the massage table. advised Epstein would ask her questions about herself. Epstein knew she was a soccer player and would be attending- I askedalltifEpstein knew her real age ... stated Epstein did and didn't care. The most recent massage she provided was on October I, 2005. Duripg the massage, she asked Epstein if she could borrow one of his vehicles to visit her family and boyfriend in Orlando, Florida Epstein had told her she could borrow one of his vehicles but later stated he would rent her a car. She continued with the massage as Epstein grabbed her buttocks and caressed the buttocks cheeks. I askedtll9if she was wearing undergarments to which she replied her thong underwear. Once he tried to touch her breasts, she would pull away from him and he would stop. alawas asked if he ever used a vibrator on her. --was aware of the vibrator but advised she never would allow him to use the vibrator on her .. She described -the vibrator as the large white vibrator with a huge head on the tip of the vibrator. She stated he kept the vibrator in a closet near the massage table. ,. • • -~stated that on October 3, 2005, she was contacted by Epstein's assistant, Sarah, who informed her that Jeff Epstein had rented her a new Nissan Sentra and she should come by the house to pick it up. Sarah informed-•he would have the car for a month ... stated Epstein lrnew her car was not working properly and that she had missed appointments in the past because of her car being inoperable. ••'explained the car is· currently parked next to thletl•-•••Gym field. I asked her if she ever took any one to the _house. 11111 explained she took •••-a friend of hers who attende , who has relocated to Orlando to attend college. I asked if she ever allowed another female in the room. -advised no one was brought into the room with her. At the conclusion of the interview, Det Dawson and I went to the gym area o and located the Silver Nissan Sentra bearing Florida tag X98-APM . The vehicle is registered to Dollar Rent a Car out-of the P_alm Beach International Airport. The vehicle was rented by Janusz Banasiack, later learned to be Epstein's houseman, and paid with Epstein's credit card. On September 11, 2005, w/f- dob .._,, was arrested by the Palm Beach Police Department The foregoing instrument was sworn to or affirmed before me this 151 day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Pagel~f 22 CNAronberg-000842 FILED: PA~M BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 for misdemeanor possession ofmarijuana. During the arrest Octoid the arresting officer that she had information about sexual activity taking place at the residence of Jeffrey Epstein. Additionally, during the ongoing trash pulls from Epstein’s residence, discarded papers were found which contained name and cell phone number. On October, 11, 2005, Det Dawson and I met with HBhnd obtained a sworn taped statement. 00 explained she had been going to Epstein’s house since 2002, when she was sixteen years of age. Since then she has gone to the house hundreds of times, ••stated she became his “number one girl.” She explained that on her first visit she was brought to the house by feIlow4HpOHMBMH||^^HHM^classmate,fllHO^Oi^0 ^said she was brought through the kitchen area where she met Sarah Kellen, for the first time, ••was led to the master bedroom, Epstein s room. |0explained that as she was walking up the stairs she observed several photographs ofnaked women along the walls and tables of the house. ^Bfurther explained that she was brought into the bedroom, where Sarah prepared the room by setting up the massage table and provided the oils for her to rub on Epstein, ••explained she remembered the steam room area, which contained two large showers. Epstein entered the room from the steam room area and introduced himself. Epstein lay on the table and told her to get comfortable. ••emoved her skirt and kept her shirt on. Epstein then instructed her to remove her shirt, •^removed her shirt and remembered she was not wearing a bra. •►stated she provided the massage wearing only her panties. She continued rubbing his legs, thighs and feet.•! advised he turned over onto his back. Epstein touched her breasts and began to masturbate. Epstein ejaculated which meant the massage was over. At the conclusion of the massage,••was paid $200.00. They walked together downstairs where Sarah Kellen and^^BJPMU^^vere waiting. ^0stated received an unknown amount of money for taking her to Epstein. Epstein instructed to leave her cellular telephone number so that he could contact her when he is in town. stated that during her many visits a routine was established between her and Epstein. She would enter the house and get naked in the bedroom. She would then start with a back massage. Epstein would roll on to his back and allow her to massage his chest area, ••stated Epstein would then began to masturbate himself and at the same time would insert his fingers in her vagina and masturbate her with his fingers. ••Explained Epstein would continue this process until he ejaculated. He would then utilize a vibrator/massager on her vagina until climaxed,••advised that during her frequent visits, Epstein asked for her real age,MB stated she was sixteen. Epstein advised her not to tell anyone her real age.•• advised that things escalated within the home as Epstein would instruct and pay®>to have intercourse with his female friend, Nada Marcinkova. ••xplained the intercourse included using strap on dildos, large rubber penis’ and other devices that Epstein had at his disposal. Epstein would watch them have intercourse and masturbate himself. Occasionally, Epstein would then join in The foregoing instrument was sworn to or affirmed State of Florida/ before me this I5* day of May, 2006 by County of Palm/Beach Det Joe Recarey, who is personally known to me. /k I Signature/ ing Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/0172006 Pagel} of 22 CA/Aronberg-000843 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 for misdemeanor possession of marijuana. During the arrest llttold the arresting officer that she had information about sexual activity taking place at the residence of Jeffrey Epstein. Additionally, during the ongoing trash pulls from Epstein's residence, discarded papers were found which contained .. name and cell phone number. On October, 11, 2005, Det Dawson and I met with llllmd obtained a sworn taped statement. • explained she had been going to Epstein's house since 2002, when she was sixteen years of age. Since then she has gone to the house hundreds of times ... stated she became his "number one girl." She explained that on her first visit she was brought to the house by fellowa•■•••■l■■•tclassmate, ••t'-- .said she was brought through the kitchen area where she met Sarah Kellen. for the first time. 119was led to the master bedroom, Epstein s room. iaexplained that as she was walking up the stairs she observed several photographs of naked women along the walls and tables of the house. lllllturther explained that she was brought into the bedroom, where Sarah prepared the room by setting up the massage table and provided the oils for her to rub on Epstein . .-explained she remembered the steam room area, which contained two large showers. Epstein entered the room from the steam room area and introduced himself. Epstein lay on the table and told her to get comfortable ..... emoved her skirt and kept her shirt on. Epstein then instructed her to remove her shirt. tlltrernoved her shirt and remembered she was not wearing a bra. .stated she provided the massage wearing only her panties. She continued rubbing his legs, thighs and feet. - advised he turned over onto his back. Epstein touched her breasts and began to masturbate. Epstein ejaculated which meant the m~sage was over. At the conclusion of the massage,~as paid $200.00. They walked together downstairs whe;e Sarah Kellen and • ere waiting .• stated ■•• received an unknown amount of money for taking her to Epstein. Epstein instructed to leave her cellular telephone number so that he could contact her when he is in town. fl/I stated that during her many visits a routine was established between her and Epstein. She would enter the house and get naked in the bedroom. She would then start with a back massage. Epstein would roll on to his back and allow her to massage his chest area. •stated Epstein would then began to masturbate himself and at the same time would insert his fingers in her vagina and masturbate her with his fingers. ~xplained Epstein would continue this process until he ejaculated. He would then utilize a vibrator/massager on her vagina until_, climaxed. -advised that during her frequent visits, Epstein asked for her real age,• stated she was sixteen. Epstein advised her not to tell anyone her real age. - advised that things escalated within the home as Epstein would instruct and paytlltto have intercourse with his female friend, Nada Marcinkova ... xplained the intercourse included using strap on dildos, large rubber penis' and other devices that Epstein had at his disposal. Epstein would watch them have intercourse and masturbate himself. Occasionally, Epstein would then join in • The foregoing instrument was sworn to or affirmed before me this 151 day of May, 2006 by Det Joe Recarey, who is personaUy known to me. Signature of Police Officer (F.S.S. 117 .10) Pagelfof 22 CA/Aronberg-000843 each ·ng Officer Date: FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 during the female on female intercourse and provide oral sex to bothl^fcnd Marcinkova. This occurred during the time iflBwas sixteen years of age. ■Advised this continued to escalate during two years. The routine became familiar to*B Epstein’s assistant Sarah would telephone her every time Epstein was in the Town of Palm Beach and would place appointments for her to visit and work for Epstein. Each time something new was introduced, additional monies were produced and offered for^^Bo allow the acts to happen. flflBconsented to perform all these acts but was adamant that there was an understanding with Epstein that no vaginal penetration would occur with his penis, fl* explained that Epstein's penis was deformed, ^*explained that his penis was oval shaped, ^^claimed when Epstein's penis was erect, it was thick toward the bottom but was thin and small toward the head portion, fl* called Epstein’s penis “egg-shaped.” fl*stated Epstein would photograph Marcinkova and her naked and having sex and proudly display the photographs within the home. ^fl*tated during one visit to Epstein’s house in which she provided a massage to Epstein, his female friend, Nada Marcinkova, was also present, fl^fl provided the massage in which Marcinkova and her would fondle each others breasts and kiss for Epstein to enjoy. Towards the end of this massage, Epstein grabbed fl*and turned her over onto her stomach on the massage table and forcibly inserted his penis into her vagina. fl*stated Epstein began to pump his penis in her vagina. ^*became upset over this. She said her head was being held against the table forcibly, as he continued to pump inside her. She screamed “No!” and Epstein stopped. She told him that she did not want to have his penis inside ofher. Epstein did not ejaculate inside of her and apologized for his actions and subsequently paid her a thousand dollars for that visit, fl*stated she knows he still displays her photographs through out the house. On October 12,2005, Det Dawson and I met withlMHflflflfl^)dobwho stated during a sworn taped statement, that nothing happened between her and Epstein, fljf^appeared nervous during the interview. I assured her that I have spoken with other people who advised differently. stated on several occasions she provided a massage to Epstein. She stated she was brought to the Epstein house in March of 2005. fl^**fl*a classmate approached her and asked her if she wanted to “work”. **Bmade the arrangements with Sarah, Epstein’s assistant. ^^Bwho has no formal training in providing massages, stated she provided a massage, fully clothed for $200.00 . As I sensed hesitancy in her answers, I askedim*if she had been contacted by anyone from Epstein’s organizations or his house. stated she was interviewed already by a private investigator for Epstein. He identified himself as “Paul” and inquired about the police investigation, and left his telephone number 305-710-5165 for additional contact. 4feH*^rovided no additional information, as it appeared her responses were almost scripted. The foregoing instrument was sworn to or affirmed before me this 1st day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police (Officer (F.S.S. 117.10) State of Florida County of Palm Beach Signature/Arrtasbng Officer Date: O5/OlWo6 Pagelif 22 CA/Aronberg-000844 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 during the female on female intercourse and provide oral sex to both tliaind Marcinkova. This occurred during the time aawas sixteen years of age. a9:tdvised this continued to escalate during two years. The routine became familiar to .. Epstein's assistant Sarah would telephone her every time Epstein was in the Town of Palm Beach and would place appointments for her to visit and work for Epstein. Each time something new was introduced, additional monies were produced and offered for lato allow the acts to happen. ~onsented to perform all these acts but was adamant that there was an understanding with Epstein that no vaginal penetration would occur with his penis. ,,. explained that Epstein's penis was deformed. -explained that his penis was oval shaped. -claimed when Epstein's penis was erect, it was thick toward the bottom but was thin and small toward the head portion. - called Epstein's penis "egg-shaped." -stated Epstein would photograph Marcinkova and her naked and having sex and proudly display the photographs within the home. ..tated during one visit to Epstein's house in which she provided a massage to Epstein, his female friend, Nada Marcinkova, was also present. ... provided the massage in which Marcinkova and her would fondle each others breasts and kiss for Epstein to enjoy. Towards the end of this massage, Epstein grabbed •and turned her over onto her stomach on the massage table and forcibly inserted his penis into her vagina. -.Stated Epstein began to pump his penis in her vagina ... became upset over this. She said her head was being held against the table forcibly, as he continued to pump inside her. She screamed "No!" and Epstein stopped. She told him that she did not want to have his penis inside of her. Epstein did not ejaculate inside of her and apologized for his actions and subsequently paid her a thousand dollars for that visit. •stated she knows he still displays her photographs through out the house. On October 12, 2005, Det Dawson and I met with.•••••11 doh I who stated during a sworn taped statement, that nothing happened between her and Epstein. ~peared nervous during the interview. I assured her that I have spoken with other people who advised differently. -stated on several occasions she provided a massage to Epstein. She stated she was brought to the Epstein house in March of 2005. ] a classmate a.•■••■ I■••• approached her and asked her if she wanted to "work". 1 ... ade the arrangements with Sarah, Epstein's assistant. -who has no formal training in providing massages, stated she provided a massage, fully clothed for $200.00 . As I sensed hesitancy in her answers, I asked~f she had been contacted by anyone from Epstein's organizations or his house . .. stated she was interviewed already by a private investigator for Epstein. He identified himself as "Paul" and inquired about the police investigation, and left his telephone number 305-710-5165 for additional contact. Q provided no additional information, as it appeared her responses were almost scripted. The foregoing instrument was sworn to or affirmed before me this 151 day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Pagel•f 22 CA/Aronberg-000844 Date: FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI// FLO 500600 On November 6, 2005, at approximately 3:30 pm, I metwithdob at the Palm Beach Police Department. ^BI9was identified as a potential witness/victim through information obtained during the trash pulls. During the sworn taped statement, M^BBndvised she was at Jeffrey Epstein’s house one time, approximately two months ago. She was approached by agirl,who was dating BBM^"oommate, for an opportunity to make some quick money. advised she needed to make some quick cash to make the rent that month. She agreed to go to the house. She had been told by that the massage would have to be done in her underwear. She advisedBBAdrove with her and brought her into the house. They walked into the kitchen area, and took the stairs upstairs.^^^^Bfurther stated she was brought into a master bedroom area. She advised she recalled seeing portraits of naked women throughout the room. A massage table was already out near the sauna/shower area in the master bedroom. Epstein entered the room wearing only a towel and introduced himself as “Jeff.” At Epstein’s direction,BMBAndMBBtemoved their clothing down to their panties, Epstein laid on his stomach area and they provided a massage on his legs and feet area. I asked^^^^if she had any formal massage training and she replied “no.” MBAadvised she was topless and the panties she wore were the boy shorts lace panties. She andMMfcontinued the massage until the last ten minutes of the massage, Epstein, toldMMftto leave the room so that ISlBcould finish the massage. MMBgot dressed, and left the room as Epstein turned over onto his back. Epstein then removed the towel and laid naked . Epstein requested that his chest area. MMMstated as she did this, Epstein, began masturbating. ^M^Mstated Epstein pulled down her boy short panties, and he produced a large white vibrator with a large head. She stated it was within his reach in a drawer in his master bathroom. He rubbed the vibrator on her vaginal area. MMAadvised he never penetrated her vagina with the vibrator. He continued to rub her vagina with the vibrator as he continued to masturbate. stated she was very uncomfortable during the incident but knew it was almost over. Epstein climaxed and started to remove himself from the table. He wiped himself with the towel he had on previously and went into the shower area. ^^Hbgot dressed and met with MBin the kitchen area. Epstein came into the kitchen and providedMBB$200.00 for bringing^MMand paid $200.00 toiBHB^01' providing the massage. ^MAwas told to leave her telephone number with Sarah for future contact. B^BBBF>rov^e^ her cellular telephone number. BA^A was asked if she was recently contacted about this investigation by anyone from the Epstein organization. She replied she was called but it was for work. She stated she was called by Sarah for her to return to “work” for Epstein. ^^^Bstated “work” is the term used by Sarah to provide the massages and other things. MA advised she declined as she was not comfortable in providing that type of “work.” On November 7, 2005, Det Sandman and I met withMMBMBB> dob MBMBDuring a sworn taped she met Jeffrey Epstein through Haley Robson when they were still The foregoing instrument was sworn to or affirmed before me this 1st day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida County of PalmiBeach Signature/AMe&ing Officer Date: 05/01/2006 Page Oof 22 CA/Aronberg-000845 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 On November 6, 2005, at approximately 3:30 pm, I met with C dob at the Palm Beach Police Department. ■■-was identified as a potential witness/victim through information obtained during the trash pulls. During the sworn taped statement, idvised she was at Jeffrey Epstein's house one time, approximately two months ago. She was approached by a girl,•1111,1111 who was dating ~oornmate, for an opportunity to make some quick money. ■••advised she needed to make some quick cash to make the rent that month. She agreed to go to the house. She had been told by ••M•• that the massage would have to be done in her underwear. She advised .... drove with her and brought her into the house. They walked into the kitchen area, and took the stairs upstairs.-.rurther stated she was brought into a master bedroom area. She advised she recalled seeing portraits of naked women throughout the room. A massage table was already out near the sauna/shower area in the master bedroom. Epstein entered the room wearing only a towel and introduced himself as "Jeff." At Epstein's direction, 111d•••emoved their clothing down to their panties, Epstein laid on his stomach area and they provided a massage on his legs and feet area. I asked if she had any formal massage training and she replied "no." advised she was topless and the panties she wore were the boy shorts lace panties. She and-•kontinued the massage until the last ten minutes of the massage, Epstein, told••lo leave the room so that R could finish the massage. got dressed, and left the room as Epstein turned over onto his back. Epstein then removed the towel and laid naked . Epstein requested that ~b his chest area .... stated as she did_ this, Epstein, began masturbating. stated Epstein pulled down her boy short panties, and he produced a large white vibrator with a large head. She stated it was within his reach in a drawer in his master bathroom. He rubbed the vibrator on her vaginal area. •••advised he never penetrated her vagina with the vibrator. He continued to rub her vagina with the vibrator as he continued to masturbate. ••11 stated she was very uncomfortable during the incident but knew it was almost over. Epstein climaxed· and started to remove himself from the table. He wiped himself with the towel he had on previously and went into the shower area. _.got dressed and met with [ ·n the kitchen area. Epstein came into the kitchen and provided.•-~200.00 for bringing ind paid $200.00 to-or providing the massage. ■ was told to leave her telephone number with Sarah for future contact. _,rovided her cellular telephone number. •••was asked if she was recently contacted about this investigation by anyone from the Epstein organization. She replied she was called but it was for work. She stated she was called by Sarah for her to return to "work" for Epstein. •■-stated "work" is the term used by Sarah to provide the massages and other things. ••tadvised she declined as she was not comfortable in providing that type of "work." On November 7, 2005, Det Sandman and I met with dob During a sworn taped statement, .... tated she met Jeffrey Epstein through Haley Robson when they were still The foregoing instrument was sworn to or affirmed before me this 1st day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Pagel))f 22 CA/Aronberg-000845 State of Florida County of Pal Beach ing Officer Date: 05/01/2006 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM • • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 attendingSMU^I^^B^H^BHO^Robson would approach females who wished to work for Epstein. stated she was offered to work for Epstein but declined. explained that “work” means give massages. She was asked about any formal training in providing massages which she said “no.” ^0Bkaid she accompanied Robson and other females who were taken to Epstein’s house to provide massages. further stated she had been to the house approximately 4 or 5 times in the past year. She accompanied Robson with^^HKMb Each time the girls were-taken over, they were previously told they would have to provide a massage, possibly naked. They were also told that should Epstein require them to do anything extra, and they were not comfortable just to tell him and he would stop. 4|^pHb stated Robson received $200.00 for each girl she brought over to massage Jeffrey Epstein. When I asked which girl appeared to be the youngest, she replied,WB who was really young, fifteen years old at the most. m0B*further stated each time she went to the house, she sat in the kitchen and waited with Robson until the massage was over. She further stated that the cook would make lunch or a snack for them as they waited. I asked her if there was anything that caught her attention within the home. stated there were a lot of naked girls in photographs throughout the house. On November 8, 2005, at approximately 2:00pm , I met withflfllWMBb, dobOtf^^H^at the Palm Beach Police Department. During a sworn taped statement, stated she had met Epstein approximately two years ago when she was first approached by Haley Robson, a classmate Robson approached her about working for Epstein and providing a massage to him for $200.00. Robson had made the arrangements however was unable to take her the day the arrangements were made. Robson had^^H^take MMso attended^^WB^HHHBBband was familiar with Epstein. BBBb recalled she was brought there and entered through the back kitchen door. She had met with an assistant Sarah and another assistant Adrianna. Sarah brought her upstairs as she observed several photographs ofnaked females throughout the house. Bib stated Epstein came in the room, wearing only a towel, and laid on the table. ^^Bb stated he picked out the oils he wanted her to use and requested she remove her clothing to provide the massage. WBBBbstated that on the first massage she provided she did not remove her clothing. ^BB^bstated she had returned several times after that. Each time she returned it was more than a massage. Epstein would walk into the master bedroom/bathroom area wearing only a towel. He would masturbate as she provided a massage. stated she was unsure if he climaxed as he masturbated under the towel. Additionally, she never looked below his waist. She claimed that Epstein would convince her to' remove her clothes. She eventually removed her clothes and stayed in her thong panties. On occasion, Epstein would use a massager/vibrator, which she described as white in color and a large head. Epstein would rub the vibrator/massager on her vaginal area as he would masturbate. BHB^stated she had been to the house The foregoing instrument was sworn to or affirmed before me this 1st day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officer (F.S.S. 117.10) State of Florida County of Pairfi Beach SignaturpA^Asting Officer Date: 05?Ul/2006 Page/^of22 CA/Aronberg-000846 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 • attendin Robson would approach females who wished to work for Epstein. tta. stated she was offered to work for Epstein but declined ..... explained that "work" means give massages. She was asked about any formal training in providing massages which she said "no." •■-~aid she accompanied Robson and other females who were taken to Epstein's house to provide massages. -- further stated she had been to the house approximately 4 or 5 times in the past year. She accompanied Robson with ...... I I ], •··•••1tand • . Each time the girls were-taken over, they were previously told they would have to provide a massage, possibly naked. They were also told that should Epstein require them to do anything extra, and they were not comfortable just to tell him and he would stop. S stated Robson received $200.00 for each girl she brought over to massage Jeffrey Epstein. When I asked which girl appeared to be the youngest, she replied, - who was really young, fifteen years old at • the-most. fwther stated each time she went to the house, she sat in the kitchen and waited with Robson until the massage was over. She further stated that the cook would make lunch or a snack for them as they waited. I asked her if there was anything that caught her attention within the home. ~stated there were a lot of naked girls in photographs throughout the house. On November 8, 2005, at approximately 2:00pm, I met with ....... , dob•••aat the Palm Beach Police Department. During a sworn taped statement, -- stated she had met Epstein approximately two years ago when she was first approached by Haley Robson, a classmate at _... Robson approached her about working for Epstein and providing a massage to him for $200.00. Robson had made the arrangements however was unable to take her the day the arrangements were made. Robson had ~e ••• ■••ttso attended ·•• _ and was familiar with Epstein. •••recalled she was brought there and entered through the back kitchen door. She had met with an assistant Sarah and another assistant Adrianna. Sarah brought her upstairs as she observed several photographs of naked females throughout the house ..... stated Epstein came in the room, wearing only a towel, and laid on the table. ■•• stated he picked out the oils he wanted her to use and requested she relJlOVe her clothing to provide the massage. •••~tated that on the first massage she provided she did not remove her clothing. ••9stated she had returned several times after that. Each time she returned it was more than a massage. Epstein would walk into the master bedroom/bathroom area wearing only a towel. He would masturbate as she provided a massage. ••• stated she was unsure if he climaxed as he masturbated under the towel. Additionally, she never looked below his waist. She claimed that Epstein would convince her to'. remove her clothes. She eventually removed her clothes and stayed in her thong panties. On occasion, Epstein would use a massager/vibrator, which she described as white in color and a large head. Epstein would rub the vibrator/massager on her vaginal area as he would masturbate. •••~tated she had been to the house The foregoing instrument was sworn to or affirmed before me this 1st day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Page/'{of 22 CNAronberg-000846 State of Florida County of Pal Beach ting Officer Date: FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit i Palm Beach Police Department Agency ORI# FLO 500600 I numerous times. ^HB*added she has no formal training in providing a massage. stated she brought two females during her visits to provide massages. 9HBB^6tated she brought a girl namedWHIP and^H^ om stated she received $200.00 for each girl she brought. On November 8, 2005,1 met with9^^^MH9W/F, the Palm Beach Police Department. During a sworn taped statement, ■■^stated she had met Jeffrey Epstein approximately one year ago. She was approached by a subject known to her as fl^^Bhad asked her if she wanted to make money providing massages to Epstein.<Bfl£had heard that several girls from were doing this and making money. She agreed and was taken to the house by flB MBhad introduced her to Sarah and Epstein and brought her upstairs to a master bedroom where a massage table was prepared and the proper oils were selected. ^Bleft the room and waited downstairs for her. stated Epstein entered the room wearing a towel and laid on his stomach. She provided a massage wearing only her thong panties. advised Epstein had masturbated every time she provided a massage. She stated Epstein continued to masturbate until he climaxed. Once that occurred the massage was over. She felt the whole situation was weird but she advised she was paid $200.00 for providing the massage. She also stated^Bwas paid $200.00 by Epstein for bringing^B^^J^^stated she had gone a total of 15 times to Epstein’s residence to provide a massage and things had escalated from just providing a massage. Epstein began touching her on her buttocks and grabbed her closer to him as he masturbated. Epstein also grabbed her breasts and fondled her breasts with his hands as she provided the massage. I^B9stated on one occasion, while she was only seventeen years of age, he offered extra monies to have vaginal intercourse. She stated this all occurred on the massage table. O*stated Epstein penetrated her vagina with his penis and began having intercourse with her until he reached the point of climax. Epstein removed his penis from her vagina and climaxed onto the massage table. received $350.00 for her massage. I asked her if she had any formal training in providing massages, stated she did not. continued to state on one other occasion, Epstein introduced his girlfriend, Nadia, into the massage. Nadia was brought into room with09 to provide a massage. Epstein had them kiss and fondle each other around the breasts and buttocks as they provided a massage to Epstein. Epstein, watched and masturbated as this occurred. On other occasions, Epstein, introduced the large white vibrator/massager in the massage. Epstein stroked the vibrator/massager onVIBO vagina as she provided the massage. On November 14, 2005, Det Sandman and I met withSMB^j^B^dob During a sworn taped statement she advised she started going to the house approximately one year ago and has been there approximately five or six times. also stated she was sixteen years old when she first went to Epstein’s house. On her first visit she was brought by a fellow student from known to her The foregoing instrument was sworn to or affirmed before me this Is* day of May, 2006 by Det Joe Recarey, who is personally known to me. State of Florida County of PalA Beach Signature/A ting Officer Signature of PolicZofficer (F.S.S. 117.10) Date: 05/0172006 Page 22 CA/Aronberg-000847 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Probable Cause Affulavit Palm Beach Police Department Agency ORI# FLO 500600 I numerous times. added she has no formal training in providing a massag~. ••• stated she brought two females during her visits to provide massages.•■•-.tated she brought a grrl named••~ and fo.Jm ••••••■ l■■tstated she received $20o:oo for each girl she brought. On November 8, 2005, I met with--••~·w/F, •••■at the Palm Beach Police Department. During a sworn taped statement, ••~tated she had met Jeffrey Epstein approximately one year ago. She was approached by a subject known to her as ... 9}iad asked her if she wanted to make money providing massages to Epstein. ~ad heard that several girls from ••■ were doing this and making money. She agreed and was taken to the house by- ~ad introduced her to Sarah and Epstein and brought her upstairs to a master bedroom where a massage table was prepared and the proper oils were selected. -left the room and waited downstairs for her. -stated Epstein entered the room wearing a towel and laid on his stomach. She provided a massage wearing only her thong panties. - advised Epstein had masturbated every time she provided a massage. She stated Epstein continued to masturbate until he climaxed. Once that occurred the massage was over. She felt the whole situation was weird but she advised she was paid $200.00 for providing the massage. She also stated...,,,as paid $200.00 by Epstein for bringing 6 ~stated she had gone a total of 15 times to Epstein's residence to provide a massage and things had escalated from just providing a massage. Epstein began touching her on her buttocks and grabbed her closer to him as he masturbated. Epstein also grabbed her breasts and fondled her breasts with his hands as she provided the massage. C stated on one occasion, while she was only seventeen years of age, he offe~ed extra monies to have vaginal intercourse. She stated this all occurred on the massage table .... stated Epstein penetrated her vagina with his penis and began having intercourse with her until he reached the point of climax. Epstein removed his penis from her vagina and climaxed onto the massage table. lllllreceived $350.00 for her massage. I asked her if she had any formal training in providing massages,-stated she did not.1111111; continued to state on one other occasion, Epstein introduced his girlfriend, Nadia, into the massage. Nadia was brought into room with .. to provide a massage. Epstein had them kiss and fondle each other around the breasts and buttocks as they provided a massage to Epstein. Epstein, watched and masturbated as this occurred. On other occasions, Epstein, introduced the large white vibrator/massager in the massage. Epstein stroked the vibrator/massager on••1tvagina as she provided the massage. On November 14, 2005, Det Sandman and I met with••llll■•tdob - During a sworn taped statement she advised she started going to the house approximately on~ year ago and has been there approximately five or six times . ._. also stated she was sixteen years old when she first went to Epstein's house. On her first visit she was brought by a fellow student from 11••••111111 1 known to her The foregoing instrument was sworn to or affirmed before me this l 51 day of May, 2006 by Det Joe Recarey, who is personally known to me. Seof~~-S.S.117.10) Page(g.r22 CA/Aronberg-000847 State of Florida County of Pal Beach Signa Date: I ting Officer FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 Esposito statedBHB brought her into the house and she was introduced to Sarah. Sarah then brought her upstairs into a master bathroom, located within the bedroom. BBH^ stated she met Epstein in the bathroom. He laid on the table and picked the massage oils. She provided the massage as he laid naked on the massage bed. She stated she rubbed his calves and back area. Upon the end of the massage, Epstein removed himselffrom the massage table and paid her $300.00 for the massage. BBBBsaid each subsequent time she went to the house, she was notified by Sarah Kellen that Epstein was in town and would like her to “work”. she returned to the house and was again led upstairs by Sarah. She provided the massage, clothed.d^^P^was asked if she ever removed her clothing to provide a massage.f^JBB stated it was not until the third time that she went that she removed her clothing. HH^stated she was notified by Sarah that Epstein wanted her to come to work. She arrived at the house and was led upstairs by Sarah. She started providing the massage when Epstein asked her to remove her clothing. ^H^removed her pants, shirt and bra. She stayed in her thong panties and continued rubbing Epstein. Epstein turned over onto his back and she rubbed his chest area.^I^^BBstated she knew he was masturbating himself as she providing the massage. she believed he climaxed based on his breathing. She did not want to view either the climax or the fact that he was masturbating. BI^BBFstated once the breathing relaxed he got up and told her to get dressed. She was paid $300.00 for her services. stated on the last time she went to provide a massage, she was notified by Sarah Kellen to come to the house and “work”. BIIMBstated she was now dating her current boyfriend and did not feel comfortable going. She recalled it was approximately January 2005. She said she went, already thinking that this would be the last time. She went upstairs and went into the master bathroom. She met with Epstein, who was wearing only a towel, and laid onto the table. stated Epstein caught her looking at the clock on several occasions. Epstein asked her if she was in a hurry. stated her boyfriend was in the car waiting for her. stated that Epstein got upset as he wasn’t enjoying the massage. She told him that she didn’t want to continue and she would not be back. Epstein told her to leave as she was ruining his massage. vised she had no formal training in providing any massages. ^m^Mstated although she had a falling out with Epstein, she still received a Christmas bonus from Epstein, stated she was wired money from Western Union for her Christmas bonus. Subpoena results from Western Union revealed money was sent from Jeffrey Epstein on December 23, 2004. received $200.00 from Epstein for her Christmas bonus. On November 15, 2005, Det. Sandman and I met with dob During a sworn taped statement,••stated she met Jeffrey Epstein over a year ago. She was sixteen years of age and was approached by^P^MiB^ fellovM|^BBBHHHII^^BM*student, who informed her that she could make $200.00 providing a massage to Epstein. ^■BMrad informed her that she would have to provide this The foregoing instrument was sworn to or affirmed State of Florida before me this 1“ day of May, 2006 by County of Palm Beach Det Joe Recarey, who is personally known to me. Vx/lj Signature/. ling Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/0 Page/£of22 CA/Aronberg-000848 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 as~ Esposito state~brought her into the house and she was introd*ed to Sarah. Sarah then brought her upstairs into a master bathroom, located within the bedroom. • stated she met Epstein in the bathroom. He laid on the table and picked the massage oils. She provided the massage as he laid naked on the massage bed. She stated she rubbed his calves and back area. Upon the end of the massage, Epstein removed himself from the massage table and paid her $300.00 for the massage. •■-said each subsequent time she went to the house, she was notified by Sarah Kellen that Epstein was in town and would like her to "work". ~tated she returned to the house and was again led upstairs by Sarah. She provided the massage, clothed. --•ll►was asked if she ever removed her clothing to provide a massage. l9llt stated it was not until the third time that she went that she removed her clothing. -stated she was notified by Sarah that Epstein wanted her to come to work. She arrived at the house and was led upstairs by Sarah. She started providing the massage when Epstein asked her to remove her clothing. ...removed her pants, shirt and bra. She stayed in her thong panties and continued rubbing Epstein. Epstein turned over onto his back and she rubbed his chest area. -■■llltated she knew he was masturbating himself as she providing the massage. tated she believed he climaxed based on his breathing. She did not want to view either the climax or the fact that he was masturbating. _,stated once the breathing relaxed he got up and told her to get dressed. She was paid $300.00 for her services. --stated on the last time she went to provide a massage, she was notified by Sarah Kellen to come to the house and "work". _.stated she was now dating her current boyfriend and did not feel comfortable going. She recalled it-was approximately January 2005. She said she went, already thinking that this would be the last time. She went upstairs and went into the master bathroom. She met with Epstein, who was wearing only a towel, and laid onto the table. ... stated Epstein caught her looking at the clock on several occasions. Epstein asked her if she was in a hurry. .., stated her boyfriend was in the car waiting for her. ~er stated that Epstein got upset as he wasn't enjoying the massage. She told him that she didn't want to continue and she would not be back. Epstein told her to leave as she was ruining his massage. ---advised she had no formal training in providing any massages. tated although she had a falling out with Epstein, she still received a Christmas bonus from Epstein. stated she was wired money from Western Union for her Christmas bonus. Subpoena results from Western Union revealed money was sent from Jeffrey Epstein on December 23, 2004 .... received $200.00 from Epstein for her Christmas bonus. On November 15, 2005, Det.· Sandman and I met with - dob During a sworn taped statement,.-Stated she met Jeffrey Epstein over a year ago. She was sixteen years of age and was approached by Q ••a fello •••• student, who: informed her that she could make $200.00 providing a massage to Epstein. --had informed her that she would have to provide this The foregoing instrument was sworn to or affirmed before me this l5' day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Polke Officer (F.S.S. 117.10) CA/Aronberg-000848 State of ;,Florida County qf Palm each Date: FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit j Palm Beach Police Department Agency ORI# FLO 500600 ' ii_ massage topless, ^^Pmade the arrangements with Epstein and his assistants and took MB to the house. 191 stated l^^and she entered through a glass door that led into a kitchen. She was taken upstairs by9i9, to a master bedroom. She recalled the master bathroom had a large pink couch, sauna and matching shower. Epstein entered into the room wearing only a towel. 09 andflBBtemoved their clothing remaining only in thong underwear. She further stated that Epstein laid on his chest on the table. The oils were selected on which ones to use. Both0l^0and0^Bprovided the massage on his legs, back and feet. Forty minutes into the massage, Epstein turned over onto his back and requestedB^Bwait downstairs in the kitchen area forl^B Epstein instructed■•□finish the massage. AsBBIBgot dressed,■■starting rubbing Epstein’s chest. BHb left the room, and Epstein began masturbating asrubbed Epstein’s chest. stated Epstein continued masturbating until he climaxed on the towel he was wearing. When asked if he had removed the towel she stated he turned the towel around so that the opening would allow him to expose himself: After he cleaned himself off with the towel he instructed ■•the massage was done and to get dressed and meet with him downstairs. ■■ got dressed and met with Epstein in the kitchen area. She was paid $200.00 dollars for providing the massage, ■■stated she was aware thatBBBBalso received monies for the same thing. The second time she went to the house she was again approached by9i9 (H^fedvised if she wanted to return to the house to provide another massage99 agreed and the arrangements were made byWIBfor her to return to the house, ■■stated^BB drove her to the house and knocked on the same glass door which leads to the kitchen area. They were allowed entry into the house by one ofthe staff members, ■■■led her upstairs to the master bedroom and master bathroom area.■■•left<9Bhis time to do the massage alone. Epstein entered the room again wearing only a towel, ^flbbegan removing her clothing as she did the last time she was at the house. Epstein instructed her to get naked. He laid on the table onto his stomach asO^began massaging his legs and back. As^B finished with Epstein’s back and legs, Epstein then turned over onto his back. started to rub his chest and he began masturbating. As OB rubbed his chest, Epstein leaned over and produced a massager/vibratof. He turned it on and began rubbing9B vagina and masturbating himself at the same time. IB stated she continued to rub his chest as this was occurring. She described the vibrator/massager as large grey with a large head. Epstein rubbed her vagina for approximately two to three minutes with the massager/vibrator. He then removed the vibrator from her vaginal area and concentrated on masturbating himself. B^Bstated Epstein climaxed onto the towel again and informed her that the massage was done. ■■got dressed and met withBBB who was waiting in the kitchen area. She received $200.00 for the massage.B9 said she never returned to the house and had no desire to return to the house. B^Bwas asked if she received any formal massage training. She advised she had no formal training. ■■was asked if Epstein knew her real age. ■■stated he knew, as he asked her questions about herself and high school. He was aware she attended, and is still attendingBH^HBMH^W^^ The foregoing instrument was sworn to or affirmed before me this Is' day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Polic/Officer (F.S.S. 117.10) State of Florida County of Palm Beach Signatu'relAhA^ting Officer Date: O5/WoO6 Page^>f 22 CA/Aronberg-000849 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 • massage topless. ~ade the arrangements with Epstein and his assistants and took • to the house. - stated 6 and she entered through a glass door that led into a kitchen. She was taken upstairs by.... to a master bedroom. She recalled the master bathroom had a large pink couch, sauna and matching shower. Epstein entered into the room wearing only a towel. - and•••,emoved their clothing remaining only in thong underwear. She further stated that Epstein laid on his chest on the table. The oils were selected on which ones to use. Both a .. d tlaprovided the massage on his legs, back and feet. Forty minutes into the massage, Epstein turned over onto his back and requested wait downstairs in the kitchen area for - Epstein instructed-a finish the massage. As••tot dressed,_ starting rubbing Epstein's chest. a left the room, and Epstein began masturbating as-rubbed Epstein's chest. • stated Epstein continued mastu,rbating until he climaxed on the towel he was wearing. When asked if he had removed the towel she stated he turned the towel around so that the opening would allow him to expose himself· After he cleaned himself off with the towel he instructed llllathe massage was done and to get dressed and meet with him downstairs. - got dressed and met with Epstein in the kitchen area. She was paid $200.00 dollars for providing the massage. ~tated she was aware th<1t also received monies for the same thing. The second time she went to the house she was again approached by••• •••1dvised if she wanted to return to the house to provide another massage ... agreed and the arrangements were made by ... for her to return to the house. llllstated drove her to the house and knocked on the same glass door which leads to the kitchen area. They were allowed entry into the house by one of the staff members. -led her upstairs to the master bedroom -~d master bathroom area.••~leftaahis time to do the massage alone. Epstein entered the room again wearing only a towel. ~egan removing her clothing as she did the last time she was at the house. Epstein instructed her to get naked. He laid on the table onto his stomach as .. began massaging his legs and back. As- finished with Epstein's back and legs, Epstein then turned over onto his back. - started to rub his chest and he began masturbating. As - rubbed his chest, Epstein leaned over and produced a massager/vibrator. He turned it on and began rubbing - vagina and masturbating himself at the same time. • stated she continued to rub his chest as this was occurring. She described the vibrator/massager as large grey with a large head. Epstein rubbed her vagina for approximately two to three minutes with the massager/vibrator. He then removed the vibrator from her vaginal area and concentrated on masturbating himself. lastated Epstein climaxed onto the towel again and informed her that the massage was done. - got dressed and met with .. who was waiting in the kitchen area. She received $200.00 for the massage.- said she never returned to the house and had no desire 'to return to the house. -was asked if she received any formal massage training. She advised she had no formal training. - was asked if Epstein knew her real age. __ stated he knew, as he asked her questions about herself and high school. He was aware she attended, and is still attending The foregoing instrument was sworn to or affirmed before me this 1st day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Poli Pagetff22 CA/ Aronberg-000849 State of Florida County of Pal I Date: ting Officer FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 ■ _ _ i_ During the course of the investigation a search warrant was executed at Jeffrey Epstein’s home located at 358 El Brillo Way in Palm Beach. While in the home I observed the pink and green couch within the master bedroom areajust as the girls previously mentioned. The stairway, which is located from the kitchen area to the master bedroom area, is lined with photos ofnaked young girls. Additionally, numerous photographs of naked young females, some of which appeared to be the girls I previously interviewed, were on display throughout the house. Also located in the house were various phone message books. The telephone message books have a duplicate copy (Carbon Copy) which, once a phone message is written into the book, the top copy is then tom on the perforated edge and the carbon copy is left in the book. First names ofgirls, dates and telephone numbers were on the copy of the messages. I recognized various numbers and names of girls that had already been interviewed. The body of the messages were time of the day that they called for confirmation of "work." Other names and telephone numbers were located in which the body of the messages were, "I have girls for him" or "I have 2 girls for him." These messages were taken by Sarah Kellen, who signed the bottom of the messages. During the execution of the warrant, I located transcript for Epstein’s bedroom desk. This desk had stationary marked Jeffrey E Epstein. I located a wood colored armoire beside Epstein’s bed that contained a bottle of “Joy Jelly,” which is used to provide a warm massage. Several massage tables were located throughout the second floor of the residence, including a massage table found in Epstein’s bedroom. On the first floor of the residence I found two covert cameras hidden within clocks. One was located in the garage and the other located in the library area on a shelf behind Epstein’s desk. A computer was located which was believed to contain the images from the covert cameras. The computer’s hard drive was reviewed which showed several images of Haley Robson and other witnesses that have been interviewed. All of these images appeared to come from the camera positioned behind Epstein’s desk. On December 13, 2005, Det. Dawson and I met with^B dob During a sworn taped statement, stated that when she was sixteen years old she was taken to Epstein’s house to provide a massage for money. OBstated it was before Christmas last year (2004) when an associate, approached her and asked if she needed to make money for Christmas, ^Bmade arrangements to take to the house and drove to the house to “work.” They were encountered by a white female with long blond hair. ^Bwas unable to remember the name ofthe white female with blond hair but knew she was Epstein’s assistant. She was led upstairs by the white female who explained that there would be lotions out already and Epstein would choose the lotion he wanted her to use. She was led through a spiral staircase which led to a master bedroom.and bathroom. The massage table was already set up in the bathroom.Ml described the bathroom as a large spacious bathroom with a steam room and shower beside it. was introduced to Epstein who was on the phone when she entered the room. Epstein was wearing a white towel and laid on his stomach so thalBB maY The foregoing instrument was sworn to or affirmed before me this 1st day of May, 2006 by Det Joe Recarey, who is personally known to me. State of Florida County of Palm Beach Signature of 117.10) Signature Date: 0: sting Officer 06 Page^f 22 CA/Aronberg-000850 j FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY • • ..--- ---·------ Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 During the course of the investigation a search warrant was executed at Jeffrey Epstein's home located at 358 El Brillo Way in Palm Beach. While in the home I observed the pink and green couch within the master bedroom area just as the girls previously mentioned. The stairway, which is locat~d from the kitchen area to the master bedroom area, is lined with photos of naked young girls. Additionally, numerous photographs of naked young females, some of which appeared to be the girls I previously interviewed, were on display throughout the house. Also located in the house were various phone message books. The telephone message books have a duplicate copy (Carbon Copy) which, once a phone message is written into the book, the top copy is then torn on the perforated edge and the carbon copy is left in the book. First names of girls, dates and telephone numbers were on the copy of the messages. I recognized various numbers and names of girls that had already been interviewed. The body of the messages were time of the day that they called for confirmation of "work." Other • names and telephone numbers were located in which the body of the messages were, "I have girls for him" or "I have 2 girls for him." These messages were taken by Sarah Kellen, who signed the bottom of the messages. During the execution of the warrant, Ilocated a ••■■Ill transcript for 9n Epstein's bedroom desk. This desk had stationary marked Jeffrey E Epstein. I located a wood colored annoire beside Epstein's bed that contained a bottle of "Joy Jelly," which is used to provide a warm massage. Several massage tables were located throughout the second floor of the residence, including a massage table found in Epstein's bedroom. On the first floor of the residence I found two covert cameras hidden within clocks. One was located in the garage and the other located in the library area on a shelf behind Epstein's desk. A computer was located whi~b was believed to contain the images from the covert cameras. The computer's hard drive was reviewed which showed several images of Haley Robson and other witnesses that have been interviewed. All of these images appeared to come from the camera positioned behind Epstein's desk. On December I 3, 2005, Det. Dawson and I met with-doh During a sworn taped statement, .. stated that when she was sixteen years old she was taken to Epstein's house to provide a massage for money. llllstated it was before·Christmas last year (2004) when an associate, - approached her and asked if she needed to make money for Christmas. - made arrangements to fake a to the house and drove • to the house to "work." They were encountered by a white female with long blond hair. -was unable to remember the name of the white female with blond hair but knew she was Epstein's assistant. She was led upstairs by the white female who explained that there would be lotions out already and Epstein would choose the lotion he wanted her to use. She was led through a spiral staircase which led to a master bedroom.and . bathroom. The massage table was already set up in the bathroom.A described the bathroom as a large spacious bathroom with a steam room and shower beside it. - was introduced to Epstein who was on the phone when she entered the room. Epstein was wearing a white towel and laid on his stomach so tha .. may The foregoing instrument was sworn to or affirmed before me this 1st day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of PolicOfficeiF.S.s. 117.10) CA/ Aronberg-000850 State of Florida County of Pal Beach i I ting Officer Date: I FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM I Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 massage his feet and calves. started the massage with the oils Epstein chose and rubbed his feet and calves. Epstein got off the phone and requested she massage his back as well.^^ began rubbing his back and got to the small of his back. During the rubbing of his back, Epstein asked her to get comfortable. He requested she remove her pants and shirt. removed her shirt and pulled her pants off. stayed in her bra and thong panties. As she finished massaging the small of Epstein‘s back, he then turned onto his back. Epstein instructed^B to rub his chest and pinch his nipples. As she began to rub his chest, Epstein asked her questions about herself, remembered telling him she attended^mHHMH^H^^^Bl. Epstein asked her if she was sexually active. Before Mbcould answer, he also asked what sexual position does she enjoy, stated she was shy and didn’t like talking about those things. She continued rubbing his chest. Epstein reached up and unsnapped her bra from the front. I^bexplained the bra she used had a front snapping device. Epstein rubbed her breasts and asked her if she like having her breasts rubbed, tflsaid “no, I don’t like that.” Epstein then removed his towel and laid on the bed naked exposing his penis to He began touching his penis and masturbated as he touched her breasts, ^^explained Epstein then touched her vaginal area by rubbing her vagina with his fingers on the outside of her thong panties. tensed up and stated Epstein was aware that she was uncomfortable. stated that Epstein said to her, “Relax, I’m not going inside.” She further explained Epstein commented to her how beautiful and sexy she was. Epstein then moved her thong panties to one side and began stroking her clitoris. said, “He commented how hard my clit was.” He then inserted two fingers in her vagina and was stroking her within her vagina. She tried pulling back to pull out his fingers from within her vagina. Epstein removed his fingers from within her vagina and apologized for putting his fingers inside her. During this time, he kept his hand on her vaginal area and continued to rub her vagina.stated he rubbed her really hard as he was masturbating, fl^said he climaxed onto the towel he had been previously wearing and got up from the table. Epstein told her there was $200.00 dollars for her on the dresser within the master bathroom. Epstein also told her that there was an additional $100.00 that was to be given to WBfor bringing her there to massage him. Epstein told her to leave her telephone number with his assistant as he wanted to see her again. Epstein stated his assistant would contact her to work again soon. I asked her if she ever received any formal massage training to whichW stated she did not. stated it was the only time she ever went to work for Jeff and knew what happened to her was wrong. She further stated that she had never been contacted for any additional work. On January 9, 2006,1 located and interviewed another victim,®^ dob ^IBHB^Pwas identified as a potential victim/witness from information obtained during trash pulls from Epstein’s residence. ^Ostated she met Epstein when she was fifteen years of age. She was approached by a friend from^^HHU^HHMBB to be taken to Jeffrey Epstein’s house to work. She was originally told she would be able The foregoing instrument was sworn to or affirmed before me this ls< day of May, 2006 by Det Joe Recarey, who is personally known to me. State ofFlorida County of Palm Signature of Polide Officer (F.S.S. 117.10) SignatureM rrestiii Date: 05/0^2006 ig Officer Page^of 22 CA/Aronberg-000851 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY • • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 massage his feet and calves. - started the massage with the oils Epstein chose ahd rubbed his feet and calves. Epstein got off the phone and requested she massage his back as well.- began ~bbing his back and got to the small of his back. During the rubbing of his back, Epstein asked her to get co~fortable. He requested she remove her pants and shirt. - removed her shirt and pulled her pants off. • stayed in her bra and thong panties. As she finished massaging the small of Epstein's back, he then turned onto his back. Epstein instructedlllla to rub his chest and pinch his nipples. As she began to rub his chest, Epstein asked her questions about herself. - remembered telling him she attended•■■•• . . Epstein asked her if she was sexually active. Before9could answer, he also asked what sexual position does she enjoy. - stated she was shy and didn't like talking about those things. She continued rubbing his chest. Epstein reached up_ and unsnapped her bra from the front. aexplained the bra she used had a front snapping device. Epstein rubbed her breasts and asked her if she like having her breasts rubbed. • said "no, I don't like that." Epstein then removed his towel and laid on the bed naked exposing his penis to •. He began touching his penis and masturbated as he touched her breasts .• explained Epstein then touched her vaginal area by rubbing her vagina with his fingers on the outside of her thong panties. -tensed up and stated Epstein was aware that she was uncomfortable. - stated that Epstein said to her, "Relax, I'm not goinginside." She further explained Epstein commented to her how beautiful and sexy she was. Epstein then moved her thong panties to one side and began stroking her clitoris. - said, "He commented how hard my clit was." He then inserted two fingers in her vagina anq was stroking her within her vagina. She tried pulling back to pull out his fingers from within her vagina. Epstein removed his fingers from within her vagina and apologized for putting his fingers inside her. During this time, he kept his hand on her vaginal area and continued to rub her vagina .• stated he rubbed her really hard as he was masturbating. 9said he climaxed onto the towel he had been previously wearing and got up from the table. Epstein told her there was $200.00 dollars for her on the dresserwithin the master bathroom. Epstein also told her that there was an additional $100.00 that was to be given t~ --or bringing her there to massage him. Epstein told her to leave her telephone number with his assistant as he wanted to see her again. Epstein stated his assistant would contact her to work again soon. I asked her if she ever received any formal massage training to which-stated she did not. -stated it was the only time she ever went to work for Jeff and knew what happened to her was wrong. She further stated that she had never been contacted for any additional work.· On January 9, 2006, I located and intervi~wed another victim,_ dob -9was identified as a potential victim/witness from information obtained during trash pulls from Epstein's residence. -stated she met Epstein when she was fifteen years of age. She was approached by a friend from .. , to be taken to Jeffrey Epstein's house to work. She was originally told she would be able The foregoing instrument was sworn to or affirmed before me this 151 day of May, 2006 by Det Joe Recarey, who is personally known to me. CA/Aronberg-000851 State of,Florida FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. :5/28/2023 2:22:44 PM I Probable Cause Affidavit \ Palm Beach Police Department ; Agency ORI# FLO 500600 __ !_ to model lingerie for a wealthy Palm Beacher. ^^was taken to Epstein’s house located on El BrilloWay. introducedBBto Jeffrey Epstein. Epstein had his personal chefprepare dinner foiiMandflHB At the conclusion ofdinner,^^^^and Epstein broughl^^upstairs into a master bedroom area.^^observed a large massage table with a sheet on it. Epstein entered through a door and exited wearing only a towel. MH* informedBBthat they were going to provide a massage on Epstein^^asked why were they doing this instead of modeling lingerie. explained toWBthat this was his routine and to rub his calves and feet. Epstein had toldf^to get comfortable, ^^removed her pants and blouse, ^^stated she stayed only in panties as she did not wear a bra that evening, ^^stated while rubbing his calves and feet, Epstein turned over onto his back. Epstein told^Bto rub his chest and rub his nipples, ^^stated that as she started rubbing his chest, Epstein began masturbating himself. Epstein touched her breasts and stroked her vagina with his fingers. Epstein continued to masturbate himself as he stroked her vagina. Epstein ejaculated on his towel and paidBb$200.00 for the massage. Epstein told that if she told anyone what happened at his house that bad things could happen. BBand BI^Bwere brought home by Epstein’s houseman and^^was afraid that Epstein knew where she lived.^bstated that several days later she received a telephone call from Sarah Kellen who coordinated for •to return to “work.” BRreturned to the house and was brought to Epstein’s bedroom area by Sarah who prepared the room for the massage. Epstein entered the room wearing only a towel. Epstein had^B-emove her clothing and provide the massage naked.BBbegan rubbing his feet and calves and Epstein turned over onto his back. Epstein rubbed her vagina with his fingers. Epstein began to masturbate himself with an upwards and downward motion on his penis. Epstein continued to touch her vagina with one hand and masturbate with the other hand. Once Epstein ejaculated onto the towel he was wearing, the massage was over. BBwas paid $200.00 for the massage. Epstein again toldBBnot to speak of what happened at his house or bad things would happen.®^wanted to notify authorities however she was afraid of what would happen to either her or her family. During the course of the investigation, several subjects were identified as a potential witness/victim through information obtained during the trash pulls, physical surveillance and telephone message books retrieved from the search warrant. While conducting research on the subjects, I discovered that the females were age eighteen or older. Interviews were conducted on the consenting adults whose statements provided the same massage routine when they went to “work” for Epstein. The females would be notified by Sarah Kellen, and made appointments for the females to “work” for Epstein. The females would come to Epstein’s house and were led upstairs, through a stairwell from the kitchen area, by Sarah Kellen to Epstein’s bedroom. Epstein would then enter the room wearing only a towel, and ask them to get comfortable. The females would then provide the massage naked as Epstein would either touch their vaginas with his fingers and/or utilize the massager/vibrator on The foregoing instrument was sworn to or affirmed before me this Is' day of May, 2006 by Det Joe Recarey, who is personally known to me. State of Florida * County o£Palm E each Officer Signature of Police Officer (F.S.S. 117.10) Date: 05/01/zQQi Page^f 22 CA/Aronberg-000852 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY • • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 to model lingerie for a wealthy Palm Beacher. ewas taken to Epstein's house Iodated on El Brillo Way. introduced-to Jeffrey Epstein. Epstein had his personal chef prepare dinner fo:rtlltand••• At the conclusion of dinner~d Epstein brough~pstairs into a master bedroom area.~bserved a large massage table with a sheet on it. Epstein entered through a door and exited wearing only a towel. infonned .. that they were going to provide a massage on Epsteintaasked why were they doing this instead of modeling lingerie. •••explained tolathat this was his routine and to rub his calves and feet. Epstein had told .o get comfortable .• removed her pants and blouse. estated she stayed only in panties as she did not wear a bra that evening .• stated while rubbing his calves and feet, Epstein turned over onto his back. Epstein told 9to rub his chest and rub his nipples. -tated that as she started rubbing his chest, Epstein began masturbating himself. Epstein touched her breasts and stroked her yagina with his fingers. Epstein continued to masturbate himself as he stroked her vagina. Epstein ejaculated on his towel and paid-$200. 00 for the massage. Epstein told a that if she told anyone what happened at his house that bad things could happen. taand ■•twere brought home by Epstein's houseman andlawas afuµd that Epstein knew where she lived.-stated that several days later she received a telephone call from Sarah Kellen who coordinated for -to return to "work." ereturned to the house and was brought to Epstein's bedroom area by Sarah who prepared the room for the massage. Epstein entered the room wearing only a towel. Epstein had--emove her clothing and provide the massage naked. aabegan rubbing his feet and calves and Epstein turned over onto his back. Epstein rubbed her vagina with his fingers. Epstein began to masturbate himself with an upwards and downward motion on his penis. Epstein continued to touch her vagina with one hand and masturbate with the other hand. Once Epstein ejaculated onto the towel he was wearing, the massage was over ... was paid $200. 00 for the massage. Epstein again toldllllllfnot to speak of what happened at his house or bad things would happen ... wanted to notify authorities however she was afraid of what would happen to either her or her family. During the course of the investigation, several subjects were identified as a potential witness/victim through information obtained during the trash pulls, physical surveillance and telephone message books retrieved from the search warrant. While conducting research on the subjects, I discovered that the females were age eighteen or older. Interviews were conducted on the consenting adults whose statements provided the same massage routine when they went to "work" for Epstein. The females would be notified by Sarah Kellen, and made appointments for the females to "work" for Epstein. The females would come to Epstein's house and were led upstairs, through a stairwell from the kitchen area, by Sarah Kellen to Epstein's bedroom. Epstein would then enter the room wearing only a towel, and ask them to get comfortable. The females would then provide the massage naked as Epstein would either touch their vaginas with his fingers and/or utilize the massager/vibrator on The foregoing instrument was sworn to or affirmed before me this 1st day of May, 2006 by Det Joe Recarey, who is personally known to me. CA/ Aronberg-000852 County Signature/Ar I Date: Officer FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600_ I_ their vaginal area. He would masturbate during the massage and upon his climaxing, the massage would end. The girls were then paid two or three hundred dollars for the massage. On November 21, 2005 I interviewed Jose Alessi, a former houseman for Jeffrey Epstein. Alessi stated he was employed for eleven years with Mr. Epstein, from approximately 1993 through 2004. Alessi stated he was the house manager, driver and house maintenance person. It was his responsibility to prepare the house for Epstein s arrival. When asked about cooks or assistants, Alessi stated they traveled with Epstein on his private plane. I asked Mr. Alessi about the massages that have occurred at Epstein’s home. Alessi stated Epstein receives three massages a day. Each masseuse that visited the house was different. Alessi stated that towards the end of his employment, the masseuses were younger and younger. When asked how young, Mr. Alessi stated they appeared to be sixteen or seventeen years of age at the most. The massages would occur in Epstein's bedroom or bathroom. He knew this because he often set up the massage tables. I asked if there were things going on other than a massage. Alessi stated that there were times towards the end of his employment that he would have to wash off a massager/vibrator and a long rubber penis, which were in the sink after the massage. Additionally, he stated the bed would almost always have to be made after the massage. On January 4, 2006 I interviewed another former houseman, Mr Alfredo Rodriguez. During a sworn taped statement, Mr. Rodriguez stated he was employed by Jeffrey Epstein for approximately six months, from November 2004 through May of 2005. His responsibilities as house manager included being the butler, chauffeur, chef, houseman, run errands for Epstein and provide for Epstein's guests. I asked Rodriguez about masseuses coming to the house. Rodriguez stated Epstein would have two massages a day. Epstein would have one massage in the morning and one massage in the afternoon everyday he was in residence. Rodriguez stated he would be informed to expect someone and make them comfortable until either Sarah Kellen or Epstein would meet with them. Rodriguez stated once the masseuses would arrive, he would allow them entry into the kitchen area and offer them something to drink or eat. They would then be encountered by either Sarah Kellen or Epstein. They would be taken upstairs to provide the massage. I asked Rodriguez if any ofthe masseuses appeared young in age. Rodriguez stated the girls that would come appeared to be too young to be masseuses. He stated one time under Epstein's direction, he delivered a dozen roses to^HHHtaHH^S^Mbfor one of the girls that came to provide a massage. He knew the girls were still in high school and were of high school age. I asked Rodriguez about the massages. He felt there was a lot more going on than just massages. He would often clean Mr. Epstein's bedroom after the alleged massages and would discover massagers/vibrators and sex toys scattered on the floor. He also said he would wipe down the vibrators and sex toys and put them away in an armoire. He described the armoire as a small wood armoire which was on the wall close to Epstein's The foregoing instrument was sworn to or affirmed before me this 1st day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of Police Officep(F.S.S. 117.10) State of Florida County of Pdlm B^ach Signature/Arrmtihg Officer Date: 05/0iWo6 I Page2|0f 22 CA/Aronberg-000853 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY • • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 their vaginal area. He would masturbate dwing the massage and upon his climaxing, the massage would end. The girls were then paid two or three hundred dollars for the massage. On November 21, 2005 I interviewed Jose A]essi, a former houseman for Jeffrey Epstein. Alessi stated he was employed for eleven years with Mr. Epstein, from approximately 1993 through 2004. Alessi stated he was the house manager, driver and house maintenance person. It was his responsibility to prepare the house for Epstein s arrival. When asked about cooks or assistants, Alessi stated they traveled with Epstein on his private plane. I asked Mr. Alessi about the massages that have occurred at Epstein's home. Alessi stated Epstein receives three massages a day. Each masseuse that visited the house was different. Alessi stated that towards the end of his employment, the masseuses were younger and younger. When asked how young, Mr. Alessi stated they appeared to be sixteen or seventeen years of age at the most. The massages would occur in Epstein's bedroom or bathroom. He knew this because he often set up the massage tables. I asked if there were things going on other than a massage. Alessi stated that there were times towards the end of his employment that he would have to wash off a massager/vibrator and a long rubber penis, which were in the sink after the massage. AdditionaJly, he stated the bed would almost always have to be made after the mas~age. On January 4, 2006 I interviewed another former houseman, Mr Alfredo Rodriguez. During a sworn taped statement, Mr. Rodriguez stated he was employed by Jeffrey Epstein for approximately six months, from November 2004 through May of 2005. His responsibilities as house manager included being the butler, chauffeur, chef, houseman, run errands for Epstein and pr_ovide for Epstein's guests. I asked Rodriguez about masseuses coming to the house. Rodriguez stated Epstein would have two massag~s a day. Epstein would have one massage in the morning and one massage in the afternoon everyday he was in residence. Rodriguez stated he would be informed to expect someone and make them comfortable until either Sarah Kellen or Epstein would meet with them. Rodriguez stated once the masseuses would arrive, he would allow them entry into the kitchen area and offer them something to drink or eat. They would then be encountered by either Sarah Kellen or Epstein. They would be taken upstairs to provide the massage. I asked Rodriguez if any of the masseuses appeared young in age. Rodriguez stated the girls that would come appeared to be too young to be masseuses. He stated one time under Epstein's direction, he delivered a dozen roses to ■■■■••••■ for one of the girls that came to provide a massage. He knew the girls were still in high school and were of high school age. I asked Rodriguez about the massages. He felt there was a lot more going on than just massages. He would often clean Mr. Epstein's bedroom after the alleged massages and would piscover massagers/vibrators and sex toys scattered on the floor. He also said he would wipe down the vibrators and sex toys and put them aw~y in an armoire. He described the annoire as a small wood armoire which was on the wall close to Epstein's The foregoing instrument was sworn to or affirmed before me this l5' day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of PoHOffice(F.$.S. 117.10) CA/Aronberg-000853 State of Florida County f P Date: FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 bed. On one occasion Epstein ordered Rodriguez to go to the Dollar rent a car and rent a car for the same girl he brought the roses to, so that she could drive her self to Epstein's house without incident. Rodriguez said the girl always needed rides to and from the house. Rodriguez produced a green folder which contained documents, and a note with Mr. Epstein's stationary with direction to deliver a bucket of roses to ^l^^after^^high school drama performance. Also in that same note was direction to rent a car for flband direction to extend the rental contract. During the course of the investigation, subpoenas were obtained for cell phone and home phone records from several victims and witnesses along with the cell phone records of Sarah Kellen. An analysis ofthese records was conducted which found numerous telephone calls were made between Sarah Kellen and the victims. These records indicate the dates the calls were made are consistent with the dates and times they victims/witnesses stated they were contacted. Specifically, The phone records showed Kellen called Haley Robson during the exact times and dates when victimflbadvised the incident occurred. Kellen also coordinated the encounters withflflWWflBMB,during the time frame the girls stated they occurred. Pursuant to a lawful subpoena I obtained Epstein’s private plane records for 2005 from Jet Aviation. The plane records show arrival and departure of Epstein’s plane at Palm Beach International airport. These records were compared to the cell phone records of Sarah Kellen This comparison found that all the phone calls Kellen made to Robson and the victims were made in the days just prior to their arrival or during the time Epstein was in Palm Beach. Jeffrey Epstein, who at the time of these incidents was fifty one years of age, did have vaginal intercourse either with his penis or digitally withMl,Ml, M andM who were minors at the time this occurred, and who at the time of the incident was fifty two years of age, did use a vibrator on the external vaginal area of a fourteen year old minor. Therefore, as Sarah Kellen coordinated and aided in the recruitment of minors to frequent Epstein’s house so that sexual services were provided to Epstein, scheduled the said minors to return to the work for Epstein, secured their appointments for the purpose of sexual activity and lewd and lascivious acts and arranged the bedroom for said minors, there is sufficient probable cause to charge Sarah Kellen with four counts of Principal in the 1st degree Unlawful Sexual Activity with a Minor, in violation ofFlorida State Statute 794.05(1), a second degree felony and there is sufficient probable cause to charge her with Lewd and Lascivious Molestation, in violation of Florida State Statute 800.04 (5), a second degree felony. The foregoing instrument was sworn to or affirmed State of Florida before me this F* day of May, 2006 by County^fPalm Beach Det Joe Recarey, who is personally known to me. YMm Signature/Arr^snng Officer Signature of Poli^ Officer (F.S.S. 117.10) Date: 05/01/20'06 Page^^of 22 CA/Aronberg-000854 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3728/2023 2:22:44 PM NOT A CERTIFIED COPY • • Probable Cause Affidavit Palm Beach Police Department Agency ORI# FLO 500600 • bed. On one occasion Epstein ordered Rodriguez to go to the Dollar rent a car and 1rent a car for the same girl he brought the roses to, so that she could drive her self to Epstein's house without incident. Rodriguez said the girl always needed rides to and from the house. Rodriguez produced a green folder which contained documents, and a note with Mr. Epstein's stationary with direction to deliver a bucket ofroses to ..... after tllhigh school drama performance. Also in that same note was direction to rent a car for 9and direction to extend the rental contract. During the course of the investigation, subpoenas were obtained for cell phone and home phone records from several victims and witnesses along with the cell phone records of Sarah Kellen. An analysis of these records was conducted which found numerous telephone calls were made between Sarah Kellen and the victims. These records indicate the dates the calls were made are consistent with the dates and times they victims/witnesses stated they were contacted. Specifically, The phone records showed Kellen called Haley Robson during the exact times and dates when victim~dvised the incident occurred. Kellen also coordinated the encounters with_"_•••---~■ and ...... during the time frame the girls stated they occurred. Pursuant to a lawful subpoena I obtained Epstein's private plane records for, 2005 from Jet Aviation. The plane records show arrival and departure of Epstein's plane at Palm Beach International airport. These records were compared to the cell phone records of Sarah Kellen This compariso~ found that all the phone calls Kellen made to Robson and the victims were made in the days just prior to their arrival or during the time Epstein ~inP~B~. • Jeffrey Epstein, who at the time of these incidents was fifty one years of age, did have vaginal intercourse either with his penis or digitally with••••• and -• who were minors at the time this occurred, and who at the time of the incident was fifty two years of age, did use a vibrator on_ the ~xtemal vaginal area of- a fourteen year old minor. Therefore, as Sarah Kellen coordinated and aided in the recruitment of minors to frequent Epstein's house so that sexual services were provided to Epstein, schedul~d the said minors to return to the work for Epstein, secured their appointments for the purpose of sexual activity and lewd and lascivious acts and arranged the bedroom for said minors, there is sufficient probable cause to charge Sarah Kellen with four counts of Principal in the l5' degree Unlawful Sexual Activity with a Minor, in violation of Florida State Statute 794.05(1), a second degree felony and there is sufficient probable cause to charge her with Lewd and Lascivious Molestation, in violation of Florida State Statute 800.04 (5), a second qegree felony. The foregoing instrument was sworn to or affirmed before me this JS' day of May, 2006 by Det Joe Recarey, who is personally known to me. Signature of PoHeOffic (F.s.s. 117.10) Page_z~f22 CA/Aronberg-000854 State of Florida County Palm Beach Signatu: ng Officer I I Date: ;o FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM I Appendix 6 CA/Aronberg-000855 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Appendix 6 CA/Aronberg-000855 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM i ' .p _ INDICTMENT . . ■F w ' A'TRUE BILL j ' , - - ■ . - ■ ” IN THE NAMEOF AND BY THE AUTHORITY OF THE STATE OF FLORIDA IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OE THE STATE OF FLORIDA ] For Palm Beach County, at the Spring Term thereof, in the-year of our Lord Two Thousand and Six, to-wit: The'GrandjJurors of-ttie'.StaJe'of Florida; inquinngJmand (or the/body, of said County of PalrruBeach. ypon their paths do present that JEFFREYS. EPSTEIN in the'County of Palm‘Beach aforesaid, in the Circuit and State ■ ■ — V J . .. - : -: aforesaid, ' - j COUNT ONE . ■ ; FELONY SOLICITATION OF PROSTITUTION dn'or abOLitfor betweerrthe IsLday of August in'the-year oLour Lord Two Thousand and Four and October 31, '2005;,did solicit;.induce,pentice;.wprocure another to commit prostitution lewdness, or assignation, contrarysto. Florida Statute 796.07(4) on three or more occasions;between August 01,2004 and October 31,2005, contrary to Florida Statute 796:07(2)(f) and (4)(c). (3 DEG FEL)(LEVEL 1) I ; ■ ' — ‘ ■' r ’ ■/F j : F ■ ' I. ' • • L . ' , . .. > " ■' 1 against the.fprm of the statute, to the evil example of all others, and against the peace and dignity of the State F .. .,v ‘ F ’ of Florida. ' < i :V ' .' ■ . I F ■... -F -• ’ -t ’ • . - .» - . -~ T’herebyice'rtify that I have advised the Grand Jury returning this indictment as authorized and required by law. ■Assistant state Attorney of thep^ Fifteenth Judicial Circuit of the State ;of'Elorida;-;prosecutingdor:the said' State? ; . ’i. . i I'- GRAND JURY.:FQREPERSON 4. ’■ ' - ';c"v'F DATE. "F.«.. Jeffrey E. Epstein; Race: White,?Sex:‘Male'; DOB:January 20; .1953; SS#. 090-44-3348; Issue Warrant *07/26/17 Page42 of 114 Public Records Request No; 17?295 CA/Aronberg-000856 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY ., ,,i J~~l1~~g~f C ,:1fi,1~~~i~,1,r, ·•· C ·~ . -· • . , ,' ... - > ' . . , _; :. , ·:=·!::~:'..~~-~~-, • ., ... 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P.... z: •• .• .. _ . • ,i ·qq[ltra,ty.(tq:fl_q'fi_~,~;,§~atu_tij,J~f?\0J(g):(f>',~i;i~;~~Y,(s)1T(~~g~~D5~J.t)'.(~E-~~~ 1;); .l . . ..... - . .. . . .. l l. L ! •~/!~iii,s)'i,ti~;iit(l):iir)(Qj,1~1~t/,'.t~i(~'iif ~1~!'ii~\<(\(l)plt~f ~tQit(~(s..,~6t~°gl!lD~i,lfi?'i>~~'1il1'<!(~~.1tt.r: 9f \fi'f $f '(~) I• I ':.t·· ·' . I . . . Ji~~{ffebyii.~ctl1:itb,iiJ:iHb,e~j~;lcfy1~:~if iH~iG,t~9._s1tJ~fy/rjjy[glnfJ:\ij!$i)r:iiist~:~H!if ~tJl~9iii~~~!t~n~;r~~1.r@:'ti~ft!~;~, : •• • :\,'RAND1Jl'.JBYJEORERERS6r-.f '. •;>·, •:,•··:t,.:.:..·/''i.- •, ·'.:•·· .•;. ,,-_,.h. ,.,. , .. ;·"<! •'. ~-# .-... • •:- •, , .' :1}.1 •:.::;,_, . t I · .,.,, J •-:. ... . . . . _ . i , • ::;:; •. f' .• ~gst;rq,,ijacef Whi,~jSex:;M~ie;00Eic.Jan~•t,: 2~, :11~J $~1>/iiO,J~~fiSSli~'.~•r~n1 . . '07/26/17 Page 42ot114 PubHc\Rec~rds Request No,,: f7:2_95 - _-.l•-_ . __ ....,..""r,.. ,...............,.-'--.:..:._..:__:..:=:· =·-··..;;;c~"--· ~---· .. .ac=~--..a..-.- CA/Aronberg-000856 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM IN THE CIRCUI JOURT OF THE FIFTEENTH JUDI XL CIRCUIT, 1 = IN And for palm beach county, Florida, criminal division ’ COURT CASE NO AGENCY & CASE NO INVESTIGATING OFFICER NAME • 05-3L8 --y, TO: ALL SHERIFFS OF THE STATE OF FLORIDA YOU ARE COMMANDED TO ARREST AD%RESS' TBUSINESS?ADDRESS:T^Ll_2Li±i_2rii;£____J__^__^— MIRAGE; HAIR:, eye^.:- (BUSINESS) DOB I i O HEIGHT _SSil_K WEIGHT:-. G2 Us FOR'APPEARANCE a -• FCIC ■i.- ? -NCIC? !.W x1 u'* * of- 'i, EXTRADITION AUTHORIZATION.^YES NO This capias is issued pursuanfto an,informatiori<liled by the.State Attorney,sFifteenth'Judicial.Circuit, Palm Beach County,* Flonda APPEARANCE BOND set by Court Order per bondjschedule’ - ^WITNESS my hand and the seal oMhls Court on this v ■ of 199_ I? : ARREST WARRANT BAIL ENDORSEMENT ' /. The defendant is to be admitted to bad in Me sum of .K"Fer schedule □ OWN RECOGNIZANCE □OTHERS_ returnable to this Court on the third Friday following the date ol , arrest at 9.00 A.M. before the Judge assigned Ihe case (SEAL) DOROTHY H WILKEN, bLERKpF COURT GIVEN UNDER my hand and seal on the day of BY: : <Deputy-Clerk- . Stalo of Florida (SEAL) .199 ;’at Palm Beach County, UUOG^1FTEEI'JTH^^ . ■z - i - . x •" Executedionthe//L day of 199 .~ W by namediv ■ , By 07/26/17 PBSO«OOia)REV.:lO/95^ ■- v:_----- o - f - - .- i.d # §lj>$ritf_-'Palm Beach C^fe Records Request NoS 17-295 - , _• _ a. » > j 1 CA/Aronberg-000857 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY ,, . .,,·,>, ' :;~t~~r~~it.~, .. ~. '<'.S i, ~ '.;,~.," i .. ,J[t CA/ Aronberg-000857 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3/28/2023 2:22:44 PM V,7^/7 ■4 yrz;5: 3 _ , - 1 Z OBTSNumoer^ ~ U -8 4 i - t * i <•*» * i * *1 *i <( ) ‘ i t r f I * A » ■——< / r h HX^XRRESTi/cNOTlCE-TO ARPEARvX<<7v = <iy , ^1; An-■2/-.^3-2Request tor-Warrant ^' /j^/Juvenite-: ' Juvenile Referral Report ’ -»* * ^entat 4 Request to* Capias' i I-4 Age;;^:ORl Number * ' : floZs Zb:. o . o',"o. o Agency Name a <. ** PALM BEACH COUNTY SHERIFF’S OFFICE.' ,Agency^Report Number i j -« u* r o/6l-l >i ^lwLx-r i -m ”M* UiVlvJ! ctSr.1^ ’ □hV*ony> ‘ .-□53tMW«n.«xx ’ as;apply. - Ji .. .-^LJ 2? ' Traflic Fokjny> ,‘LJ>T4,->Tra!fte Misdemeanor □^5 Ortfnance^ , Zb 6 Otrw_ IIWeaponSeUed T • <. v— Enter Type Mumpie-*^' %)*♦ ’Clearance^- s-i • indicator h 4 Locafeon otAnost {Including Named Business) ■z ‘ y 4 . ■? 37ZC ^/r/ ZP- YnrP / / Location of Offense (Busmess^Name.-Address)^ r: ■ Date of arrest ax yO. .<71-^ r-“7 uV? 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Address). - • v-:.: - -; ■...?; -v. . ■> ;• /1 Coun Date and .Timor. _ ' . . , f ' Month . .Day. x Year " Time _ A-M__==-: rAGRFE^TO^PPEAR ATiTHE-TIME’ANO PLACeiDESK3NAT6D JO ANSWERSTrtE<OFFENSE Ci<ARGED!OR>TO PAY JiUNDERS FAIlMO’APPEAR'BEFORE‘TME^COURT*AS REQUIRED BY’THlS!NOTIC€.TOjAPPEAR,.THAT.-l MAY<8E: HELO lN CONTEMPT,OF;COURTLAND A.WARRANT; F .W .f<. 2 • r • r * .. .• -.-■■ ■>■ -7- •> - •■ | , , - 1.. iWILLFULLY. OR MY ARREST SH4Ll5nE ISSUED 1 i” :■ ' Signaturool Detondanl (or.'JuvontlO'and.P&renV Custodian)- >; • 4r?y, •-.< • .v? • .^ate'Signod 2o -NOLD'lor.otha»r.’Agoncyrr.‘; ' < Name:*'. .a..- _ss.-r „•-- ■-■ —...•. ... -.- — , ^Sjgnaiure olArrestingOtticoix'/:- X UO) ;Name Vefilicanon^Prrnled.by. Arrestee), ' ” ' “ * (PRINT)". L ...1 -.Z... ,. -a- A r ... • _._L ?EL-Dangerous A'Eh-Reststed^Arrest' * ’iQ 'SuKidai Other:.-- • - - - -c •_••.■ * Name.otArrestmg Officer (Pr«nt)\- : * ID. • i - Pxce < ’ -X'-OF_ ^W;07,26/17 10 * ?Rouch*. » -J.a^orups ^4 0^114 V *90«Y 'i’-OlSTRIBUTlON- ’WHITE-- COURT COPY.’ ’(GREEN - STATE ATTORNEY. I YELLOW - AGENCY.’ PINK • AGENCY" GOLD'-.pEFENDANT;(N.T.A.?S.ONLY); paso>i4s‘rev h. r - • v * -- _ I -J CA/Aronberg-000858 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY ~'.;{'?~-· ... .,,. .. _,: .... - ~!1\1.': ·:~~·. < :._.... \ ; .'' .'. ~_,.., •. ioh1'r.~1 ~· -~ .; .·· • . . ,,';!I_ • " ;;; • - ·~J;, --~;~~;~!~!~ .~~- /=✓ :,~/:~~,\~ - ~ . -. : \c .... ' 1~l{t'fr~tl ~~ : __ ._ ~::~?i-:_/ .t't~ .. i~ f~Jqurt.'~if°'i\,N~~-~'?~!i -,• f ,: · .. - J·'. #" CA/ Aronberg-000858 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM i Appendix 7 CA/Aronberg-000859 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY • • Appendix 7 CNAronberg-000859 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Case 9:08-cv-8Q736-KAM L)ocument 48-5 Entered on FLSD Docket 03/21/2011 Paqe 2 of 15 € IN RE; INVESTIGATION OF JEFFREY EPSTEIN __ 7 NON-PROSECUTION AGREEMENT IT APPEARING that the City of Palm Beach Police Department and the State Attorney’s Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, the “State Attorney’s Office") have conducted an investigation into the conduct ofJeffrey Epstein (hereinafter “Epstein"); IT APPEARING that the State Attorney’s Office has charged Epstein by indictment with solicitation of prostitution, in violation ofFlorida Statutes Section 796.07; IT APPEARING that the United States Attorney's Office and the Federal Bureau of Investigation have conducted their own investigation into Epstein’s background and any offenses that may have been committed by Epstein against the United States from in or around 2001 through in or around September 2007, including: (1) knowingly and willfully conspiring with others known and unknown to commit an offense against the United States, that is, to use a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution, in violation ofTitle 18, United States Code,Section 2422(b); all in violation ofTitle 18, United States Code, Section 371; ■ (2) knowingly and willfully conspiring with others known and unknown to travel in interstate commerce for the purpose ofengaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18, United States Code. Section 2423(b); all in violation ofTitle 18, United States Code, Section 2423(e); (3) using a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to, engage in prostitution; in violation ofTitle 18, United States Code, Sections 2422(b) and 2; (4) traveling in interstate commerce forthe purpose of engaging in illicit sexual conduct, as defined in 18 US-C § 2423(f), with minor females; in violation Page 1 of 7 ; i i j i CA/Aronberg-000860 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY . ' .Entered on FLSD Docl<et 03./21/2011 P~e. 2. of 15 ., f-,t€ 71 [Att I~ . I ' ~ INRE: INVESTIGATION OF JE~YEPStEIN' ----------................. --~' N_QN~PROSECJJDON AGREEMENT IT APPEARING that {h_e ~!ty 6~ P~lz? Beach Police Department i and th~ State Attorney's Office for the ISthJud1c11il Crrcwt m and,for Pa,lrn l3eacll Co1JI1ty,(here1IU1.fter, .the "State Attorney's Office'') h11ve ce>ndµcted an investigation into the conduct of Jeffrey Epstein (hereina.fler .. ijpstein'1); ITAJ>PEARIN_G ~at the State Attorney's Office has charged Epstein: by indictment with solicitation of prostitution, in violation ofFlorid11.StaMes Sectio11 7?~;()7; ITAPPEARING that the United States Attorney's Office and the fed~al Bureau of Investigation have conduct~ thei_r own investigation into Epstein's background and any offenses that may have been committed by Epstein againstthe United Sta.~~s from in or arouaj ~00 I through in or around' September 2007, includin~: 'i _ (I) knowingly and w_illf\illy ·conspiring with othe'rs known an~ wikn:own t9 CA/Aronberg-000860 cornmit an offense against the Unite:d States, that is, w µse·a fa~ijity or means ofinterstilte or foreign COllllllCI'Ce to knowingly p~e; induce, or entice , minorJCIIl!Ue~ to engage iJtprostituiion, inviolation:ofTitle 18;'Unite,d States Code, Section 24220>)} aUin violation ofTitle 18, United States;Code, Section 371; , I '(2) knowiogly and 'Viii fully conspiring with others knowp and unkpovm to travel in interstate commerce for the purpose of engaging in illicit sexual conduct; as ·qef~ed •in '18 U .S.C. §' 2423(f);- with minor females, in violation-of: Title 18, United States Code; Section 2423(\J);.all in violation ofTitlc l s;United States Code, Section·2423(e); (3) (4) ~ing !1 facility or meaiill of ihterstate or foreign commerce, tc:>. lrnowingly pefstiad~, induce, {lf e.JttiCe minor females to, engage ifi pfOStitutioii; in violation of Title 18, Unit® States Code, Sections 2422(b) and 2; • . I I traveling in il].~rstate :commerce for the purpose of engaging ip illicit sexual conduct, as defined in 18 U.S.C, §: 2423(1), with minorfemale,s; in violation Page I of 7 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3;/28/2023 2:22:44 PM I \ \ I I r I i .. .1 Case9:08-cv-80736-KAM^^ocument 48-5 Entered on FLSD DoJ^^03/21/2011

Page 3 of 15 i ofTitle 18, United States Code, Section 2423(b); and (5) knowingly, in and affecting interstate and foreign commerce, recruiting, enticing, and obtaining by any means a person, knowing that the person had not attained the age of 18 years and would be caused to engage in a commercial sex act as defined in 18 U.S.C. § 1591 (c)( 1); in violation ofTitle 18, United States Code, Sections 1591 (a)(1) and 2; and IT APPEARING that Epstein seeks to resolve globally his state and federal criminal liability and Epstein understands and acknowledges that, in exchange for the benefits provided,by this agreement, he agrees to comply with its terms, includingundertaking certain actions with the State Attorney’s Office; IT APPEARING, after an investigation ofthe offenses and Epstein's background by both State and Federal law enforcement agencies, and after due consultation with the State Attorney’s Office, that the interests of the United States, the State of Florida, and the Defendant will be served by the following procedure; THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor ofprosecution by the State of Florida, provided that Epstein abides by the following conditions and the requirements of this Agreement set forth below. If the United States Attorney should determine, based on reliable evidence, that, during the period of the Agreement, Epstein willfully violated any ofthe conditions of this Agreement, then the United States Attorney may, within ninety (90) days following the expiration ofthe term of home confinement discussed below, provide Epstein with timely notice specifying the conditions) ofthe Agreement that he has violated, and shall initiate its prosecution on any offense within sixty (60) days’ of giving notice of theviolation. Any notice provided to Epstein pursuant to this paragraph shall be provided within 60days ofthe United States learning offacts which may provide a basis for a determination of a breach of the Agreement: After timely fulfilling all the terms and conditions of the Agreement, no prosecution for the offenses: set out on pages 1 and 2 of this Agreement, nor any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States.Attorney’s Office, nor any offenses that arose from the Federal Grand Jury investigation will be instituted in this District, and the charges againstEpstein ifany, will be dismissed.

Page 2 of 7 . i i l I CA/Aronberg-000861 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY _Entered on FLSD Dp.03/21/2011 I Pa,ge 3 of 15 of'title 18, United States Code, Section 2423(b); and (5) knowingly, i_n and affecting interstaJe and, foreign commerce, recruiting, enticing; and obtaining by any m~s a person; knowing that the person had ~not attained· the age of 18 ·years and would be caused to engage in a com~_ercial sex !lCtas defmed in 18 U,S.C. §. IS91(c)(l); in violation ofTitle 18, United State!! CC><i_e; Sectiqns 159l(a)(l)and 2;,and • • • • iT APPEARING thatEpsteinseeks t(l resolve globallyhis sta~ and federal criminal liability and Ep11tein llnderstan,ds and acknowledges that, in exchange for the benefits provided,by tlµs agreement he agrees to cotnply with its terrns, mcludi))g tmQ~rtak.ing cer_tain actions with the State Attorney's Office; • i:r APPEARING; after aniovelltigatjon of the offenses and Epstein's background by both State and Federal law enforcement agencies, and after due consultation with the State Attorney's Office,·•~t the interests of ihe United St,ates, the State of Fl9rid!I, and the Dc(en<hlnt will be· served by thc.{Qllowing procedure;. ' THEREFORE, on the authority of R.Alexander Acosta, United,States Attomey'for th~ Southern District of FJorid!l. prosecution jn this District for these of'[t-:nses shJlll be deferred inf11.vor of prosecution by the State.ofFiorida, provided that Epstein abides;by the following conditions and tl1e requirements ofthis Agreement setforth below, If the United SJates Attorney should determine, qased:on reliable evidence, that, during the period of the Agreement, F;pstein willfully vioiated a:ny of the ~o~d.itions of this Agn;cment, then the. :Unite.d States Attorney may. within ninety (90) days -following the , e,q,iratlop of~e tenn of home confmement discussed below, provide;Epst~in with timelr notice specifying the condition(s) of the Agreement illat'hellas yi,9la~ 1111d'shall initiate its prosecution.on any offense within sixty(60) days'of giving notice oftheviolation. Any notice provided to Epstein pursuant·~ th.is. paragraph shal I oe J)t'Ovide:d _withiri60 dJiys of the United States leamirtg of facts which may provide .a basis for a detcnnination of a breach of • - theAgreernerit: '· • • ' • After timely fulfilling all the terms and conditions of the Agreement, ho prosecution for. the offenseoet qµt qn pages. I ·and 2 of this Agreement, nor any .qther off~,i~s that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States.t\ttomcy's Office, nor aliy offenses that arose from the Federal Grand Jury inve,sijgation.will be instituted i11.tliis :District; and the charges against Epstein if any; will be dismissed. • Page 2of 7 CA/ Aronberg-000861 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3,/28/2023 2:22:44 PM Case 9:08-cv-80736-KAM^uocument 48-5 Entered on FLSD Docket 03/21/2011

Page 4 of 15 Terms of the Agreement: [ 1. Epstein shall plead guilty (not nolo contendere) to the; Indictment as currently pending against him in the 15th Judicial Circuit in and for Palm Beach Comity (Case No. 2006-cf-009495AXXXMB) charging one (1) count of solicitation of prostitution, in violation ofFl. Stat § 796^07. In addition, Epstein shall plead guilty to an Information filed by the State Attorney’s Office charging Epstein with an offense that requires him to register as a sex offender, that is, the solicitation of minors to engage in prostitution, in violation ofFlorida Statutes Section 796.03; 2. Epstein shall make a binding recommendation that the Court impose a thirty (30) month sentence to be divided as follows: (a) Epstein shall be sentenced to consecutive terms oftwelve (12) months and six (6) months in countyjailfor all charges, without any opportunity forwithholding adjudicationor sentencing, and without probation or community control in lieu of imprisonment; and (b) Epstein shall be sentenced to a term of twelve (12) months of community control consecutive to his two terms in county jail as described in Tenn 2(a), supra. 3. This agreement is contingent upon a Judge ofthe 15th Judicial Circuit accepting and executing the sentence agreed upon between the State Attorney’s Office and Epstein, the details ofwhich are set forth in this agreement. 4, The terms contained in paragraphs 1 and 2, supra, do not foreclose > Epsteinand the State Attorney' s Office- from agreeing to recommend any additional charge(s) or any additional term(s) ofprobation and/or incarceration. 5. Epstein shall waive all challenges to the Information filed by the State Attorney’s Office and shall waive the right to appeal his conviction and sentence, except a sentence that exceeds what is set forth in paragraph (2), supra. 6. Epstein shall provide to the U.S. Attorney's Office copies of all

Page 3 of 7 I CA/Aronberg-000862 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY Case 9.:08-CV'80736-KAM~OCUl)lent 48-5 Entered on FLSD Do.03/2112011 . . . I

Page 4 of 15 CA/ Aronberg-000862 I I I Terms of the l\~ment: i I 1; Epsteip sllall plead guilty (not ne>lo qontendere) to the: Indictment as currently pending against him in the 15th Judicial Circuitin and for Palm B.eac:h C::oU!ity (Case No: 2006-'cf-00949 5AXXXMB) charging l)OC ( IJ count of solicitation of pro!!titution, in yiolatipr;i of Pl. Stat § 796;07. In addition, Epste_in ~ball plead guilty to ari lnfonnlition filed by the State Attotney's,Office charging Ep*ill with ~ offe_!lse thilt requires hiin to register •as a sex offender, that is, the ·solicitation of ,mine>rs to engage in prostitution, in violation ofFlorida Statµtes Section 796.03; • :2~ Epstein shall make a \:?iildi.ng recommcmdaiioifthat the Court impose a thirty (30)'mon1h sentence.to oe divided as foll.ows: (a) (bj Epstc::iD shall be•sentenced to consecutive tem)softwelye.(J2) months and six (6):months iri CQuntyjaiHor aH charges, without anyo?PQrtllnity. forwithholdirig adjudication or sentencing, and witljout probation .<>r :cpmrouni_ty :control in lieu of itnprisonment,:and Epstein shall be sentenced to a term oftWelve (12) IJl,pnths of comniunitycontrol consecutive to his two tcnns iricoi.intyjall as .described in Tenn 2(a), supra; 3. This agreemc:nt'is ce>ntingent upon a Judge of the 15th Judicial Circuit a~cepting and executing the, senteric1e agreed upon be¥een the State Attorney's Office and Epstein. the details of whicl'! are st:t f<>rth in-t~is .agreexnent 4, The ~rms contained in paragraphs I: 11t1d 2, supra, do not foreclose , Epsteut and the State Attorney's Oflit£from ag~eeing lo reconunend llilY 11dditional charge(s) or any additi<>nal t!7ID(s) of pr~batiori and/or incarceration. 5. Epstein sha.U v,,aiv~ all challengcs·to the Informiltion.fili:<f by the~~ Attorney's Office and shall waive the•Jigbt to appea! his conviction and sentet1ce, ex~pt a sentence that exceeds what is set forth in paragraph (2),supra. 6. Epstein shall provide to the U,S. Attorney's Office. ·copies of all PageJ of7 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Case9:08-cv-80736-KAM^^ocument 48-5 Entered on FLSD DoJOfOG 721/2011

Page 5 of 15 proposed agreements with the State Attorney’s Office prior to entering into those agreements. 7. The United States shall provide Epstein's attorneys with a list of individuals whom it has identified as victims, as defined in 18 U.S.C. § 2255, after Epstein has signed this agreement and been sentenced. Uponthe execution ofthis agreement, the United States, in consultation with and subject to the good faith approval ofEpstein’s counsel, shall select ah attorneyrepresentative forthesepersons, who shall bepaid for by Epstein. Epstein’s counsel may contact the identified individuals through that representative. 8. Ifany of the individuals referred to in paragraph (7), supra,elects,to file suit pursuant to 18 U.S.C. § 2255, Epstein..will not contestthe jurisdictionofthe United.States District Court forthe Southem Disttict ofFlondaoverhis person and/or the subject matter, and Epsteinwaives his rightte contest liability and also waives his right to contest damages up to ah amount as agreed to between the identified Individual and Epstein, so long as the identified individual elects to proceed exclusively under 18 U.S.C. § 2255, and agrees to waive any other claimfor damages, whether pursuant to state; federal, or common law. Notwithstanding this waiver, as to those individuals whose names appear on the list provided by the United States, Epstein’ssignature on this agreement, his waivers and failures to contest liability and such damages in any suit are not to be construed as an admission of any criminal or civil liability. 9. Epstein’s signature on this agreement also is not to be construed as an primission ofcivil or criminal liability or a waiver ofanyjurisdictional or other defense as to any person whose name does not appear on the list provided by the United States. 10. Except as to those individuals who elect to proceed exclusively under 18 U S C § 2255, as set forth in paragraph (8), supra, neither Epstein’s signature.on this agreement, nor its terms, nor any resulting waivers or settlements by Epstein are to be construed as admissions or evidence of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person, whether or not her name appears on the list: provided by the United States. 11. Epstein shall use his best efforts to enter his guilty plea and be

Page 4 of 7 CA/Aronberg-000863 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY Case 9:08,cv;.;80736-KAMttocument 48-5 Entered on FLSD Do.03/21/2011 Pqg_e .5 of 15 7. 9. IL CA/ Aron berg-000863 I I proposed agreements with the State Attorney's Office prior \Q enterj_ng i.rlto those;agreerilerits. • The United, States shall provide Epstein's attorneys •with a list of individuals vih0111 It has identified as victims, 'as defined in 18 U.S.C. §' 2255. after Epstein has signed this agreement ~d J,een ,s~ntenced. Upon the execution of 1his agi:eemerit. the United States; in consultation with !IIld subjectto the\good faith:approval ofEpsteill'~ counsel; shall select an attorney representative for these persons, who shall be paid for by. Epstein. Epstein's counsel may contact thcfidentifi~cf individlJ!lls througll that representative. lf:any.:'of_lfi{i;di_vidual_s:referred to in pajagrapll.(1), SUJlrq; ~.i~J() file, sult'.PIJ,[SUIUlt Jo l.8 ·u~;ct f;2s5-;.i~p~te_iri:~Liiot_,i;_on~'ibe jurisdictioh:ofthe United StatesDistrictCouri for the SouthemOistrict . qf;f_i9~~~j:v,if;hj~ pi=rs<>~ and/oJthe 'subjeH~att¢~ iuJd EJ)!ie~{W~iic¥ his rigltfiocontest liability imchlso waives tilifJ'igbl w C9ntesi•ies, up to ail amoW1t as agreed to between the identified individual' and Epstein, so long as the ·identified incljviduaJ elec~ to proceed exch,1siv<1lY under 18 U.S.C.::§ 2255"and 1:1,grec=s to waive any other claim for damages,whethcr pursuantto state, federal; or common law. l'-lotwithstandirig this waiver; as to those irulividuals-whose- names appear on th~ list provided by the United States; Epstein's signatµre on, ·tJus agreement, his. waivers and failw-es "to contest liability and such damages ;in-any--~~ are- not to be constnied as an adIDission of any .crit;rlihal or,,civi(li~oHity . . . :- ;}•\~ -. - Epstein's signature on this agreemen..t also is notto be construed as an admission of civil or criminal liability ora wai\'er of anyjuri!l(iictio_nal. Qr other defense as to. any person whose ~c does ·not appear-on the listprovided by the United States. Except es to those in<ilviduals who,elect ;t9 proceed exclusively under fs)J.~~c: §.2255, asset.forth in parag,raplf(~); supra, n~i~erEpsfi=in's signature.on this agreetnent, nor its terms, nor anyresulting waiv.ersor settlements by Epstein are to be construed as aW'I)issjons'or evidence of civil or crimin~J • liabiHty or a waiver of any jurisdictional or other defense as to arty person, whether or. noi her n_ame appears on the list: provid~ by the United States. Epstein shell use his !?est efforts to enter his guilty pl~ and:be

Page 4 of 7 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Case9:08-cv-8.0736-KAM^^ocurnerit 48-5 Entered on FLSD Do^Bu03/21/20T1

Page 6 of 15 ■sentenced not later than October 26, 2007. The United States has no objection to Epstein self-reporting to begin serving his sentence not later than January 4,2008. 12. Epstein agrees that he will not be afforded any benefits with respect to gain time, other than the rights, opportunities, and benefits as any other inmate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration. 13. The parties anticipate that this agreement will not be made part of any public record. If the United States receives a Freedom ofInformation Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before making that disclosure. Epstein understands that the United States Attorney has no authority to require the State Attorney’s Office to abide by any terms of this agreement. Epstein understands that it is his obligation to undertake discussions with the State Attorney’s Office and to use his best efforts to ensure compliance with these procedures, which compliance will be necessary to satisfy the United States’ interest. Epstein also understands that it is his obligation to use his best efforts to convince the Judge ofthe 15th Judicial Circuit to accept Epstein’s binding recommendation regarding the sentence to be imposed, and understands that the failure to do so will be a breach of the agreement. In consideration ofEpstein’s agreement to plead guilty and to provide compensation in the manner described above, ifEpstein successfully fulfills all of the terms gnd,conditions ofthis agreement, the United States also agrees that it will riot institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Mareinkova. Further, upon execution of this agreement and a plea agreement with the State Attorney’s Office, the federal Grand Jury investigation will be suspended, and all pending federal Grand Jury subpoenas will be held in abeyance unless and until the defendant violates any term of ,thw; agreement. The defendant likewise agrees to withdraw his pending motion to intervene and to qyash certain grand jury subpoenas. Both parties agree to maintain their evidence, specifically evidence requested by or directly related to the grand jury subpoenas that have been issued, and including certain computer equipment, inviolate until all ofthe terms ofthis agreement have been satisfied. Upon the successful completion of the terms of this agreement, all outstanding grand jury subpoenas-shallbe deemed withdrawn. .

Page 5 of 7 CA/Aronberg-000864 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY Case 9:08-cv,80736-KA.ocurnen\ 48-5 Emered on FLSD Do.03/21/2011 I I :sentenced not later y,an October 26, 2007-. the UnitedjStates bas 110 objection to J;:pstein seJfsreporting to begin ~rving hls sentence ·not later than January 4, 2008. • 12. Epstein agrees that.he will not be aff otded.any benefits With respect to gain time, c;,iqer than the rights,_opportuniti~, !1f1d bepefits 8$ anyother lllDlate,, including but not- liDiited to, eligibility for gain time credit ·based ori ~dard rules and regulations that Elpply i11 the State of Flonda. A_t the United States' request, Epstein. agrees 'to provide an -acc~W'iting of the gaiQ time he- earned, during his ·period of .n:icarceration. 13. The'parties anticipate that this agreement will i:ie>t be made part of any public record. If the United States receives a Freedom oflnformation Act request ·ora,ny ~Illpµlsory process· commanding the disclos~ of the .agreement, it will provide notice to Epstein before making that disclosure. ·Epstein widerstands ,t_hat the United States ,'.\~rney has no authority :t<> ~quire the State Attontey's Office te> a.bide by any terms of this agr~ent. Epstein \UlOCi'stands that itis his obligation to µndertake discussions~ the.State Attomefs Office and to use hi~ .best efforts to ensure ®mpliance with these pi'ocedµrcs, whic~ compliance will be necessary to satisfy the United States''interest Epstein also understands that if is.hisobl_1gation to-use his best efl"orts.to convince the Judge of the 15th Judicial Cir:cuit to acceptEpstein~s binding r~mmendation regarding the sentence t9 lxl :imposed. and understands that the failure to do so will be a breach of the agr~ement; •• In e9r1~ideration of Epstein's agreement to plea(j. guilty and to ·provide compensation in the tQanner aescribed ab()ye, ifEpsteirt successfully fulfills allt>fthe tenns ~ _conditi9M of this agreement, the United Stat~s 1,1~0 agrees that it will niH institute: BilY criminal charges against any potential ~~onspirators ofEpstein, inclµding but not limited toi Sarah Kelle~ • Adriana Ross; Le~ley '.Groff,~ or l'f ~qiii Marciftkoya. Further; upon execution of this • agreem~nt and 'a plea agreement with the State Attorney's Office, the federal Orand Jury investigation will be suspended, and_ all:pending federal Grand Jury subpoenas will be held in abey~ce unless and lm,til the· defendant violates llllY tenn of.this agreement. The defendant likewise agrees·to withdraw ~i~ pending motion toiniervcn~and tq quash certain gr~q jµry subpoenas. Both p!lrties agree to maintain their evidence, specifically. evidence requested by or: cli~tly related to ·the• gI1U1g jury. subpoenas that have. bc:~Jl issu~d, and including certain computer equipment, inviolate until all of the terms of this agreement have been satisfied. Upon the successful complet(on .of the terms of this ~een:ient, ell outs~ding grandjury subpoenas,shall be deemed withcirawn . .

Page 5 of 7 CA/Aronberg-00O864 Pqge 6of 15 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM Case9:08-cv^80736-KAM^^ocument 48-5 Entered on FLSD Dodft)</21/2011

Page 7 of 15 I i I By signing this agreement, Epstein asserts and certifies that each of these terms is material to this agreement and is supported by independent consideration and that a breach of any one ofthese conditions allows the United States to elect toterminate the agreement and to investigate and prosecute Epstein and any other individual or entity for any and all federal offenses. By signing this agreement, Epstein asserts and certifies that he is aware ofthe fact that the Sixth Amendment to the Constitution of the United States provides that in all criminal prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further is aware that Rule 48(b) ofthe Federal Rules ofCriminal Procedure provides that the Court may dismiss an indictment, information, or complaint for unnecessary delay in presenting a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein hereby requests thatthe United States Attorney forthe SouthernDistrict ofFloridadefer such prosecution. Epstein agrees and consents that any delay from the date ofthis Agreementto the date ofinitiation ofprosecution, as provided for in the terms expressed herein, shall be deemed to be a necessary delay at his own request, and he hereby waivesany defense to such prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of the FederalRules ofCriminal Procedure and the Sixth Amendment to the Constitution ofthe United States to a speedy trial or to bar the prosecution by reason ofthe running ofthe statute of limitations for a period of months equal to the period between the signing of this agreement and the breach of this agreement as to those offenses that were the subject of the grandjury’s investigation. Epstein further asserts and certifies that he understands that the Fifth Amendment and Rule 7(a) ofthe Federal Rules of Criminal Procedure provide that all felonies must be charged in an indictment presented,to a grand jury. Epstein hereby agrees and consents that, if a prosecution against him is instituted for any offense that was the subject of.the grandjury’,s investigation, it may be by way ofan Information signed and filed by the United States Attorney, and hereby waives his right to be indicted by a grandjury as to any such offense. Ill . . Ill iri

Page 6 of 7 i i i ’ . ! I CA/Aronberg-000865 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY Case 9.:08-cv 080736-KAM.ocumenJ 48-5 .Entered on FLSD Doc,03/21/2011 I I ! By signing this agrcemen~ 'Epstein asserts and ccrlifi~. th~ ~ach qfthese terms is material t9 this agreement and issupponed;by independent consideration and that a breach of any one of these _conditioll$ flllows U>e United States to elect 'to terminate _the agreement and to investigate and prosecute: Epstein-and any other individual qr entity for any and a:JJ fcde@l offenses. By signing this agreemen~ Epstein asserts a.ild certifies that he is aware of the facttbat the Sixth Amendment to the Constitution o(lli~ United States provides that 1n all criminal prosecutiqns the B~llSed shall enj<>y the right to a speedy .and public trial. -Epstein further •is aware that Rule 48(b)oftheFederalRules ofCriminalProce<t~ provides thauhe Court may dismiss an indictment,_ info~i<m,, or c!)mplaint for unnecessary delay in presenting a charg~ to the Grand Jury, filing an.information, or in bringing a defendant.to trial. ,Epstein hereby requests that theUnite<fStates Attomey for the SoµtherqPistrict of Florida defer such prosecutioµ. Epstein agrees and CQnsen~ ~ any delay from the date of thisAgreemenno P&ge 7 of 15 the date-of initiation of'prosecuti<;>n, as providedfor'in the term_s expressed herein, ~aU be deemed to bl, a·necessary delay at his own request, and he hereby waiveiumy defense to such '> prosecution on the gi'(>und that such:delay operated to deny hiin rights under; Rule. 4S(Q) of the Federal Rules of Criminal Procedure and'the Sixth Amendment to the Constitution of the United States to a ~y trialor: to bar-tm:.prosecution by ~son of the running of the statute of limitations for a period of months equal to the perjO<l between the s!gning of this ,agreemc:nt ~d ·tJ,,e breach of this agreemeI!t'as to those offenses that were .th~ subject of the grand jufy 's investiga,tion. Epstein further asserts and etmifies that he understand., that the Fifth Amendm~t and Rule 7(a) of.the FederafRules:of Criminal Procedure provide that all f.elon1es must be charged in.an indictment presente:dJo a grand,jqry. Ep~tein:hereby agrees a.r1d consen~ that; if a prosecution agai~ him is in~ituted fot any offense that was the subJectoftJu, gnmdjury'_s invt:stigation, it'Inay be by way qfan lnfQIJllation signed and filed by the t.Jnitc_d Sm,te~ Attorney, and '1erebyw~i:ves his'riJht.to be indicted by-a: grand jury.as to ·w;iy such.offense. 11 l Page.6'of 7 CA/ Aronberg-000865 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM i Case 9:08-cv-80736-KAM Document 48-5 Entered on FLSD Docket 03/21/2011

Page 8 of 15 By signing Ihis agreement, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the conditions ofthisNon- Prosecution Agreement and agrees to comply with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By:--- A. MARIE VILLAFANA ASSISTANT U.S. ATTORNEY EPS' Dated: GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Pago 7 of 7 CA/Aronberg-000866 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY Case 9_:08-cv.s8.Q736-KAM4'ocument 48-5 Entered on FLSD D0!03/21/2011 Pqge a of 15 • . i . • :By signing this agreement. Epstein assert,und certifies that the ab;o~e has ~ read and explained to hiDl. Epstein hereby states ~\he understands the conditions of this Non- Proi.c~tion Agreement and a~ to comply with them. Paled: 'j'" CA/Aronberg-000866 By: R. AL.EXANDER ACOSTA UNITED STATES ATTORNEY A MARIEVILLAF~A •. - • - -- • 1 . ASSI_STANT U.S. ATTORNEY OERALDLEFCOURT~ ESQ. COUNSEL TO JEFFREY ·EPS:rEIN LILLY ANN SANCHEZ ESQ. ATTORNEY;FORJEFFREY EPSTEIN

Page 7 of 7 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM ' Case 9:08-cv-80736-KAM L)ocument 48-5 Entered on FLSD Docket 03/21/2011

Page 9 of 15 By signing this agreement, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby stales that he understands the conditions ofthis Non¬ Prosecution Agreement and agrees to comply with them, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated:__ AMARIE VILLAFANA 1 ASSISTANT: U.S. ATTORNEY Dated:_ Dated: ^^^C7 JEFFREY EPSTEIN feRALDTEFCOtfRTi'ESQ. ' - ‘OUNSEL TO JEFFREY EPSTEIN Dated:_ LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN

Page 7 of 7 .1 CA/Aronberg-000867 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY Case 9:08-cv,8.0736-KAMttocument 48-5 Entered on FLSD Do!o~/21/2011.

Page 9 of 15 I I .By signing this agreement, Epstein asserts and ccrtitfos· that;thc a~~e has b~n read and explained to. him, Epstein hereby states that he µnderstands the conditions of:th1s _Non. Prosecution Agreement !llld agrees to comply withJhym, Dated:--.---- Dated: ____ __ Dated: 7 / '-•1t/ 07 Daied: .----,-- CA/ Aronberg-000867 R. ALEXANDER ACOSTA t)NITEDSTATESAITO:RNEY By: -----~-==,-:,:--:--=-:-~~-;--- A, MARIE VP:,LAFANA. ASSISTANT U.S. A TIO~"( Lll,LY ANN SANC_HEZ, ESQ, ATIORNEY f0~ JEFfREY .~ PSTEIN Pago 7 of 7 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM I 1 ' i I . I :I i ·l I I l • • Case 9:08-cv-80736-KAM ijocument 48-5 Entered on FLSD Docket 03/21/2011

Page 10 of 15 Bv sinning this agreement, Epstein asserts and certifies^ the above has beerread andexSdnSto him. EfrsSn hereby states that he understands the conditions ofthis Non¬ Prosecution Agreement and agrees to comply with them. R ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: A MARIE VILLAFANA ASSISTANT U.S. ATTORNEY Dated: JEFFREY EPSTEIN Dated: GERALD LEFCOURT, ESQ, COUNSEL TO JEFFREY EPSTEIN Dated: *22 na#ANNW*Sffi£ ESQ- ATTORNEY FOR JEFFREY EPSTEIN

Page 7 of 7 CA/Aronberg-000868 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY Case 9:08-cvs80736-KAM .cument 48-5 Entered on FLSO Doc.312112011

Page 10 of 15 B . • • • g tbts agreement, Eps~ili assertund certifieB'that th~ ~e bas~ read and expl~= hizii_. Epstein bcrcby states tb.at;hc undetstands the. conditions:QfthJS Non- Prosec.ution Agreement and agrees to comply with lhc,m. Dated: ----------,- Dated:----"'--"-- D_ated: ___ _ CA/Aronberg-000868 By: R. ALEXANDER ACOSTA t.JN1TED STA~:ATTO~EY A.MARIEVU.LAF ANA ASSISTAl'l'fu:s. ATTO~Y .JEFfR¥Y EPSTEIN GERALD LEFCOURT, F.sQ.· COUNSBL TO mfFREY 1EPSTBIN ·. • ~-------::::> ~; • ATI'ORNEY FOR JEFFREY EPSTBll,J Page 7of 7 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3_/28/2023 2:22:44 PM i \ \ .l • • I Case 9:08-cv-80736-KAM 'Document 48-5 Entered on FLSD Docket 03/21/2011

Page 11 of 15 IN RE: INVESTIGATION OF JEFFREY EPSTEIN ___/ ADDENDUM TO THE NON-PROSECUTION AGREEMENT IT APPEARING that the parties seek to clarify certain provisions of page 4, paragraph 7 of the Non-Prosecution Agreement (hereinafter"paragraph 7"), that agreement is modified as follows 7A. 7B. 7C. The United States has the right to assign to an independent third-party the responsibility for consulting with and, subject to the good faith approval of Epstein's counsel electing the attorney representative for the individuals identified under the AgreementJflhe United States elects to assign this responsibility to an independent third-party, both the United States and Epstein retain the right to make good faith objections to the attorney- representative suggested by the independent third-party prior to the final designation of theattorney representative. The parties will jointly prepare a short written submission to the independent third-party regarding the role of the attorney representative and regarding Epstein' s Agreement to pay such attorney representative his or her regular customary hourly rate for representing such victims subject to the provisions ofparagraph C, infra. Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees ofthe attorney representative selected by the independent third party, piis provision, however, shall not obligate Epstein to pay the fees^and.costsofcontested litiga1ian.filed against him.Thus, ifafter consideration ofpotential settlements, an attorney representative elects to file a contested lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested remedy the paragraph 7 obligation ofthe Agreement to pay the costs of the attorney renresentative, as opposed to any statutory or.Other obligations, to pay reasonable attorneys fees and costs such as those contained,ins 2255 to bear the costs of the attorney representative, shall cease. CA/Aronberg-000869 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY Case 9:0B-cv-80736-KAM 4ilcument 48-5 Entered on FLS.O oocl3121/2011 - I I ! I rN~E: INVESTIGATION OF JEF17REV EPSTEIN --------------' ADDENDUM':O ~ NON-PROSECUTION AGREEMENT ITAPJJEARING,that-the parti~ ~ck.to clarify certain provisjpns o( page A, paragraph 7 ofthc N911-1?n>secution AgreemcnJ(hcrcinaflcr "paragraph 7'?, that l!g~ent ls modified as • t9llows: • • 7 A. Tho United States has the right to assign io an ~ndependent third~party the r\:SPO~ibility fur consulting \Vith and, llubject to the ·good faith approval of Epstein's couns~I, selecting the attorney rep~tativefor the individuals identified under the A~t.. Jf thc United St11tes elects to assign this re~nslbllitfto an· indcpenden~_third-part)t, l,oth the United States and Epstcin:rcta.in the right to make good faith-objections to tho littomoy representative S\lggested by the independent third~party prior to the final des1gnation.of theattorney··represen~tivC:. 7]3. 7C .. The p11rties will Jointly prepare a short written submission to the lndepe!)dent third-pmy regl!fding the. role of the attqmey representative and regarding Epstein's Agri:emcnt to pay.such attorney ~presentatNe bis or h~ regular customary hourjy r11te for ~presenting such -.1ctims subject to the provlslc>ns of paragraph c_, infra. Pi.n'suant to additional paragraph 7A, Ep*in has agreed to:pay tl,e fees of the attorney repl"C:Scntative selected by the _ind_ep~4entJhird party/Ibis provision, howe:v_er;sha!l not

Page 11 of 15 obligate Epstein to pay the:fCCS-:and,oostsofconteste~UitigationJiled.against h.h:n . .Th~ _ ___ ___ _ _ _ _ __ _ _ __ _ __ if utter consideration of potential scttl~nta, an arlQ_mcy rep.esentaiiv_e ~Mets to fi~ 1f _ ,contested lawsuit pu11uant to 18 tts~C._s,2255 or elects to pursue any other _conJested __ remedy, the p~g"-'f'h 7 obflgation of.the A~~rnent to pay the costs of the·ati9mey representative, as opposed. to any statutory or other obligatio11s t_o pay r~onab~ ·- attorneys fees and costs such a~ thqsc conu.in~d, in~ 2_~55 to ~r the costs ofthe attorney representative, shall cease. • - ! i I r CA/ Aronberg-000869 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM I I l _, i j I Case 9:08-cv-80736-KAM Document 48-5 Entered on FLSD Docket 03/21/2011

Page 12 of 15 i: been read and By sisniw ih» *~ ■ 1 o ALEXANDERACOSTA UNITED STATES ATTORNEY Dated: By‘ A. MARIE VILLA?ANA ! ASSISTANTU.S. ATTORNEY Dated; /. 'STEIN Dated: GERALD LEFCOURJ, bSq. COUNSEL TO JEFFREY EPSTEIN Dated: LILLY ANN SANCHEZ, ES$ ATTORNEY FOR JEFFREY EPSTEIN CA/Aronberg-000870 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY • Case 9:qa-cv~807;36,.KAM Document 48-5 .1 Entered on FLSD Docket 0i2l/2011 CA/Aronberg-000870 - - --- • - -• nd cettifies thal tbe above .has been read_ and By·signing thi.s,Acldend'll,ll1, E=~ :~e understands die ~larificatfon~ to the Non- ~xplaine~ to lilm. Bp,tedln =~ comply with them. r ProsecutJoffASreanent an •111.--· . bated: ___ _ Dated:---,--- it ALEXANI>ER ACOSTA, _ -- - ---·s·r· ATESATTO~Y UNITED _ - - . - - - - - - - -- - STETN - -- - - GERALD LEFCOURJ'; ESQ. _ 1N COUNSEL TO-JBF'FREY ~STE . LILLY ANN SA'Nqmz, ESQ. -- - - ATTORNEY FOR. JEPFR.EY EPSTEIN Page 12 ot1s FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 1/28/2023 2:22:44 PM 1 Case 9:08-cv-80736-KAM^bcument 48-5 Entered on FLSD DockeT03/21/2011

Page 13 of 15 By signing this Addendum, Epstein asserts and certifies that the above has .been read, and ’ explained to him. Epstein hereby states that he understands the clarifications to the Non- Prosccution Agreement and agrees to comply with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY A. MARIE VILLAFANA ~ ASSISTANT U.S. ATTORNEY Dated; Datcd:/^/^ JEFFREY EPSTEIN ^RALD LEFCOWRT]ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN CA/Aronberg-000871 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY Case 9:08-cv080736,KAM.cument 48-5 Entered.on FLS.D Doc.3/21/2011

Page 13 of 15 ' i I I By, 0s igning this Addendum, Epstein asserts ~d ~_i:titi~ that the ab9v~ has ;beet! read, and' explained to him". Epstr:in hc~by states th11t he; understands the clarifications t<> the Nol!- Ptosecuti~n ,A.grc~ment and agrees to comply with them. Dated: ___ _ By: Dated: ___ _ Dated: ___ _ CA/ Aronberg-000871 R. ALEXANDERACOSTA l/NITED STA TES A lTQ~Y A. MARIE VILI..AFA~A ASSISTANT 0.$. A TTORNE:Y JEFJ7R,EYEPSTeIN PSTEJN LILLY ANN.SANCHEZ; ESQ. ATTORNEY fb~JEFFRE'(EPSTEIN FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM i I I I Case 9:08-cv-80736-KAM^Document 48-5' Entered on FLSD Docket 03/21/2011

Page 14 of 15 By signing this Addendum, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states .that he understands the clarifications to the Non- Prosecution Agreement and agrees to comply with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY A. MARIE VILLAFASA ASSISTANT U.S. ATTORNEY Dated: JEFFREY EPSTEIN GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN Dated: LILLY ANN'SANCHEZ, BS' ATTORNEY FOR JEFFREY EPSTEIN CA/Aronberg-000872 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY Case 9:@8-cy-80736-KAM.cument 48-5, Entered on FLSO Oocfo3l2112011

Page 14 of 15 ·• (' -··----· .-·•.•- ,.·· .... ---····• -- ~ ,.-..;-.,~ .............. ·-·-·--··•····-· I By slgnlng'thls ~ddend11111, Epstein asserts and certifies that the abovo has been.read_ and expllllticd to. him: Ep~ln hereby states ,that ho undcrm.iids the ~lanfitjdi9ns' i.o the Non• Pr;osecutiori Agreement and ogrecs to comply with them. Dated:-------- Dated: _____ __ Dated: /frr'A t:fr -------------. . -------- CA/ Aronberg-000872 R. ALEXANDBRACOSTA .UNITBD STATBS AT:rORNBY A. MARIE YILLAF AAA ASSISTANT U.S, A TI'ORNEY JEFFRBY·EPSTEIN GBRALD LEFGO~T •. BSQ .• . COUNSEL TO JEFFREY EPSTEIN ~ ATI'ORNEY FOR .IBFFRBY EPSTEIN FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3,/28/2023 2:22:44 PM I I l f i '1 i I ·i I Case 9:08-cv-80736-KAM Document 48-5 Entered on FLSD Docket 03/2172011

Page 15 of 15 D«c-O7-O7 B4:S5pa Fron-Fwlir-Wil Burnitt 3057883201 T-866 P.003/004 F-B76 AffinnatiBn IJeSnyi. Epsteindohereby ro-effinn theNan-Proseoulicn Agreement andAddendum to Mme dated October 30,2007, CA/Aronberg-000873 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY • Entered .on FLSD Docket 03/,21/2011 Page 15, of 15 I Dac-DT-07 il•:!b11 FrorFowlu-whl t, Burnett I mmm1 r-,ss P.ooum M_T& I AJJ!niiadu I. Je5,,y B. E~da hereby n~llffiim thi: NmrProseagtign Ap:cmc:Dt and. ~ddemd:lnn m liADlC -4 Oc:tiJbm- 30, 2007, CA/ Aronberg-000873 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM i Appendix 8 I CA/Aronberg-000874 ( FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY • • Appendix 8 CA/Aronberg-00087 4 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM I IN THE CIRCU'n COURT OF THE-FIFTEENTH JUDICiAL C RCUIT IN ANDFORPALM BEACH COUNTY, STATE OF FLORIDA CRIMINAL DIVISION "W" (LB) n L STATE OF FLORIDA ARISES FROM BOOKINGNO.: 2006036744 I vs JEFFREY'E'EPSTEIN, W/M„01720/1953 INFORMATION FOR: 1) PROCURING .PERSON UNDER 18 FOR PROSTITUION Circu!TC.--T-r>>' - - /{•, ~ ; Oon,, In the'Name and by Authority of the State of Florida: ' BARRYE. KRISCHER,State Attorneyforthe Fifteenth Judicial Circuit,-Palm Beach County,.Florida, by and through his undersigned Assistant state Attorney,-charges that/JEFFREY E EPSTEIN on.or/about or-between thc l -' dayiOf Augustnn the year ofourLord Two Thousand and Four and OctoberP^OOSi did knowingly and unlawfully procureTor,prostitution, or caused to be prostituted; A.D, a person under the age of I'8;years, contrary' to Florida Statute 796.03. (2 DEG FEL) ■ UANNABELOHLAVE FL. BAR NO. 0776726 Assistant State Attorney. STATE OF FLORIDA COUNTY OF PALM BEACH i -Appeared’ bcfore<mc, LANNA BELOHLAVEK Assistant State Attorney for.Palm Beach County, Florida, personally known to me; who, being first duly sworn,;says that the allegations as setiforth in the, foregoing information are based upon facts that have been swom to as true, and which, if true, would constitute the offense thercinzcharged, that this prosecution,is institutedjn good faith, and certifies thabtestimony,under oath hasbeen. received5 from the material witness or witnesses for the ofiensey^zA,-,. ssistant-State Attorney -:$womTo and subscribed: to before me thisoUtzday of June, 20.08. NOTARY PUBLIC/Statc of Florida ■ .Damaris Pina .. ... ■ * DDS60T98. ’ EXPIRES> r >d7^5 ' ?:‘ i W" ;5t-* ArfflUStT, 2010 . FCIC REFERENCE NUMBERS' 1) FELONY.SOLICITATION OF PROSTITUTION 3699 07/26/17 Page 1 of 114 Public Records Request No.: 17-295 CA/Aronberg-000875 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY ,r. ·,zi; N0TA'.RY'PlJBLl€ ,Stafci6f<Rlollda~ • • •• •• ' ·>. • • ... • •• ·• ,_ • • • " - 'j . -.; ! t l~GIC?REEERE·NGE'.iNtfMBERS:. . .. ! ·\) :t:i;r1o~K'YsbJi!s;1:zi\~xlfff¢!';1t~#'at~osJti)tl:Jj{i9J~t,~i~: 07/26/U Page 1 <if 1j 4 P.ublicj Re<':cirds: Request No,: 17-295 CA/Aronberg~000815 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM I CLOSE OUT SHEET Defendant: S>$Wa Date Closed: /O ASA b& Case Number: Division: NolleProssed:_■_ “ j Pled to LesserFelony:._Pled to Lesser Misd: < ' J NegotiatedPlea:_L_Pled toCourt:_L-- Jury Trial: : . • ' ■ Non- JuryTrial:_L-a Acquitted: Dismissed:__— - - . ■ ’ ■ Y ’ > , Guidelines Score > j , Non DOC: v^,,. ... . .,.Y-t . Y^^ Mandatory DOC:(minimum)...--■-- Pre October 1998 Discretionary DOC: .:._-.- Adjudicated:: , Withheld:--- County Jail:< Probation: IxMlLh^h^bOC: . . Months - Days - Years - Time Served < :,... : Mnnthty CnntmlI 5 Habitual Offender: . Youthful Offender: Juvenile:-- PRR: . . 10-20-Life:. . . ..- | Restitution: Amount-__!- ' 07/26/1/

Page 2 of 114 Public Records Request No : 17-295 . CA/Aronberg-000876 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. S/28/2023 2:22:44 PM NOT A CERTIFIED COPY :.~tl1.-~, - . •_,~ "' !'-," I , .. .;,: -, ' _,:,";',~· ... -:·_:..·:.~.~~· ... /~i.' \<" \ .. _~ i€!?;0SEOlJ.t:'SHEEF .,.,•, . •· •· ·-·/·=:··;=-,~~:.+cc-~~~··•~·-<=,;•·~··•·-.··•··-•••• :c.·.-a·s·····e"\N·-.U.:':m •... ,.b,-e~:.Jc~.~•r;:':\~Jif 'I)Ucnciant:J·.' ... •• • • • • ·- ' ·.,A"o· " •• ' ' • ,: ••. , ·-· ·····.-·.-.··.·. <. ··•::r•:,1 .r.\.· .. :.· .. '1•_'v'.c1;'.-s'-~1· . -o. •· .. n·_·.· . ·.·.·••·,•· ~_atcJ~H?l~f!.= :,',?~~.: . __ -· t -...... ·~~-,- :&01uf Pi:o~sdi:.-:..;;·-··;....· '"'--...,_;_~~,_;=~· l. '{:Hfii!'PQP~:;;.;../·~--"-• .......;:.. __ ~__;__:____;_~...:.;;;_:_-....a..,-_,.,....__,...-",,,___,..,,,,.____,~,..,.:..--'-:'--,-,...,,,--+,-:-~~ M?ndat2q;,n.ot;";~mfoim4mi,-"'-.;,;;,.\.-'-.'';;;;..·· ---·;;...·· .'""-----"'---""~~~::;.;..Y ..::.••'--', ~'-'--~"---:.,_;;__;,__;;,.;.;.,;..~=~,..,...- !?l-e'Q~!9-~r Itl9.9§~~lsfJ~hgv.frY:{~)~Q?,pj .....;...; ......... ___;,;,;.__ _ _;;;_~;..___;_--"c...c..;;;.j_•--"- ·- A~l'u:d,lcat~d\ ...... -,c. ;w1l~tie14:-__ -'""-'-_........_~--"--"'--"~· ·c;ou nty,'JOi t;J irra:wg]®@))0~/ II · . M(!nlh"& - I!~y~ - '>'.~~ - 'J"iiii0•~~'¥~ff •• -~f_~(Ob:~~-io~·::· • ,·_ .·-:.",:: : ,;Mbri~~;l~a~~:~it1;'.io~tr~\:,J,.~.-J:~{~~:., '1. "",;·; -~p .~~:.;fr"'.'.('.,~· .. _; •. ~t '·:; ?t:._, -.\·.J\,· ~·:.- &/~•-.. ·, • ~::-•. ::'1"·: ~ "'""-:- !.•~~~f;~. ~. -t,:~,:.,. ;'~ ••• , J-Iahihlaf Of(¢hd 1 er:X .••. , ~, *'")Y6ti.thit1I•~If end~r:~--'=-"-'--'""'-'-= .iiii~vif it'---~"'-'-------- >i. d,7/26h7 Page,2 of f14 Public Recoril.s Reque~l;No:: 17;295 _ : ,. ; ';- - ., -.,~,.,, < ' • ·- .> CA/ Aronberg-000876 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM I I ' - I' J i '· J I . I· r l l t V ! CLOSE OUT SHEET Defendant:. »O DateClosed^ Q ASA Case Number: O ~ t T r - , / - 1 Division:! l/V^ Nolle Prpsscd: J i . • i / " : L S - - ■ ■ ‘ ,, '; ' . ’ , \ . ' Pled to Lcsscr Felony: ■-.- - Pled to Lesser Misd: •;_ Negotiated Plea: ' Pled toCourt:_]_ ■■ ,J P’ <£•-,. ' Jury-Trial:. ;. _Non- Jury Trial: 1_ A > i Acquitted: . Dismissed:_-■J -y_u- < .4 - ••• ■’ ' '? ‘ •* ■’ Guide1ihe§/Score,// - " ? ‘ / < NonDOC: .-* ■ -• MandatorypOC:(mm^ _-. • _ . - -, Pre October l998;Discret.ionary DQC: _ . x" \ ! Adjudicated: - - Withheld: ; . . Cpiinty Jail: Months - Days - Years '- Time Served ”, Probation:_Months- Years • CommunityControl:_'- '■ yV -J \ '' li- ' * V" ■ '' ’ ■’* L‘ *' ■ 7- ' ‘‘z ' '*•" V *• *4- ' C'j "r ' /’ M Habitual Offenders . - A Youthful Offender: Juveriile’: - -__—_ PRE: .. - 10-20-Lifc: - ' _ I _ —- ■ I Restitution: . - „ - - Amount: 07/26/17 - CA/Aronberg-000877 Page3 of 114 Public RecordsRequest.No.: 17-295 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY -~~~ ,_;~•" -~;.· j .I>_,,. ~ ;Pled\fo:1:e:sseJ:2Felony,: __ >:--,. ·'"="'::--·-:,-·, "'"'=-:c,--~=-~~.:J;f }edc,ici~sseitMisd:~.~-o~~l~ .• T~.7':'., , .. -'-.. -:-::._'.;'."; ·;:,::::-: ~--·-:-, ~= ~§gqg1~~4if;!~t;:;.,._,...· __ ._·~,,,,.':•_?_.·_--,-__ ,..,,,..._,=:',,J?rJggJq•·¢{iij,i'.ti _,,;...,_,;;;..'.;._j:,,,-' ·,_. ~";,:--"':, .• ~.~,:-,:<,,,.... ~-:-:-·: ,>· _,.=}:?!?~ . } r --·~---)_ .-. I , /Non~rJu.~'ffiriah.. . r . -.~,.. _,,,~_f.. ~· ~:-.;." ___ '·'--'""· '-".-:'_.--c,,,'=,.-=-,*--""'.~:-,--· ..,...a~~;,,:--- 1 .. , :~c~gi)J!f'><}\.,,,-:'.,,_·,,,,,, . .,.,, __ ==-""'•·,.,..·,..,,,··,,,,,..,~,...,.,.,---,---~~-·..,...,4:?.i~ri:iisifd'::-=--=-.~-,~--.'-····:,.:..!."""·._--··,....·'.,..:~:_, ~~,,,,.,..:,'""'."".~ I j 1. ' '"'r•-~i. c,/ ;:; ,r~~ • h.' I ~: , dt1iai1T~el·~corl~.,. :t 1Non~tibc?,;,;.,-· -~· ~_:;:;,;,,_;,..___::..,..;.;~~-,---'~"--,.~~-"-=~'""="..,.,,,..:"--:~· ···=: ·c,,.,· ~~~~~-=--: ' .. ;, i ·:filtngjJQti'.}!1t9.~;X(fui~iift~ln), ;.,,.· ... '""" ..................... -_,.,,_ ..... "'"'· ~-,-''-,------"'-,~----+1~-'--,-~ .. ""-f_ -. ,,,....,,._.-,,:,-:- )te$,litulio-n::_.,._-,---'-'~,--,,--,--=:----,----, 07/26/17. CA/ Aronberg-000877 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3/28/2023 2:22:44 PM ~{;.; •• <.. '>' ; . , :• 'I! ,i,. 948.101 Toons and conditions of community control and criminal quarantine community (1 ) The court sholldctermino the terms and conditions of community control. Conditions specified fri this sulisoctfon do not require oral pronouncement at the time of sentencing and may beenntidorod standard conditions of community control. (aj The court shall require irrtonsvs supervision and surveillance for.an offender placed into .communftycontnAi which may include but is not Limited to: 1. Specified contact with the parole and probation officer. 2. Confinement to an agreed-upon residence dunng hours away from employment and public 3. Mandatory public service. 4. Supervision by the Department of Corrections by means ofan electronic monitoring device - 5. The standard conditions of probation sot forth in s. 948.03. (b) For an offender placed on criminal quarantino community control, the court shall'require: 1. Electronic monitoring 24 hours p^r day. ": Confinement to a designatediotidtmee during designated hours. : ■J.,. (2) Tha enumeration of specific kinds of terms and conditions doos not prevent the court from adding thereto .any .other terms or conditions that the court considers proper.'However, the sentencing court may only.impose a condition of supervision allowing an offender convicted of s- 7941011,s. 800.04. s. 827.071. or s. 847.0145 to reside in another stato.lf tho order .. stipulates thet-it is contingent upon the approval of tha receiving state interstate compact authority. The court may rescind or modify at any hmo tha terms end conditions theretofore imposed by It upon tho offender in community control. However, If the court withholds adjudication of guilt or imposes a period of incarceration as a condition of community control, the period may rot exceed 364 days, and Incarceration shall bo restricted to a county facility, a probation and restitution canter under tho jurisdiction of tho Department of Corrections, a probation program drug punishment phase I secure residential treatment institution, or a community roridentiat facility owned or operated by arty entity providing such services. (3) Tho court may place a defendant who is being sentenced for criminal transmission of-HiV In violation of s. 775.0877 on criminal quarantino community control. Tho Department of Corrections shall develop and administer a criminal quarantine community control program emphasizing intensive supervision with 24-hour-por -day electronic monitoring. Criminal quarantine community control status must include surveillance and may include other measures normally asswnatedwithcommunfty control, except that specific conditions nocossary to . monitor this population may-bo ordered. - 'X gig A 07/20/1'Zl, . Jr/. XT J-

Page 4 of 114' ; Public i - Recdrds;RequesVNoJJ17 20o >7'. .--v * ' " ■■MS CA/Aronberg-000878 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY CA/ Aronberg~000878 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM '943.0435 Sexual offenders required to roaster with Che dojurlracnt, penalty.- (1) As used in tills section, th? tenn: (a)1. *Soxual offender* moans a person who moots Uio criteria in sub-subparagraph a., sub- subparagraph b., wb-cubparag'^h or sub-subparagraph d., as follows: a.(I) Has boon convicted of committing, or attempting, soliciting, or conspiring to commit, any of the critninal-oflonsos proscribed in the following statutes in this state or similar offenses in another jurisdiction: s. 787.01. s. 787.02. or s. 7B7.<B5(2)(c), where ths victim is a minor and tho defendant is not Ute victim's parent or guardian; s. 794.011. excluding s. 794.011(101; s. 7M.Q5; 4. 796,03; S. 796.035; s. 800.04: S. 825.1025; s. 827.071; S. 847.0133; s. 847.0135, excluding s. 847.0135(4): s. 847.0137; s. 847.0138; s. 847.0145; or s. 985.701(11; or atty similar offense committed in this state which has boon redesignated from a former statute number to one of those listed in this sub-sub-subparagraph; and (II) Kas been released on or after October 1,1997, from the sanction imposed for any cpnvtalon of an offense described in (I). For pteposos ofsub-sub- subparagraph (I), a sanction imposed in tills state or in any other jurisdiction includes, but is not limited to, a fine, probation, community control, parolo, conditional ratoare, control igIoosc, or incarceration in a state prison, fadrral prison, private correctional facility, or local detention facility; b. Establishes or maintains a residence in this state ond who has not boon designated os a saxual predator by a court oi tin's slate but who has been designated as a sexual p/odatoi, as a sexuallyviolent predator, or by another sexual offondor designation in snothsr state nr jurisdiction and was, as a result of such designation, subjected to registration or community or public notification, or both, or would be if the person were a resident of that state or jurisdiction, without regard to whether tho person otherwise meets the criteria for registration «s a sexual offender; c. Establishes or maintains a residence in this state who is in the custody or control of, or undqr tho supervision of, any other states or jurisdiction as a result ofa conviction for committing or attempting, soliciting, or conspiring tn commit, any of the criminal offenses proscribed in the following statutes or similar offense in another Jurisdiction: s. 787.01. s. 787.02, or s. 7B7.025(2)(c), where tho victim is a minor and the defendant is not tho victim's parent or guafdian; s. 794.011, excluding s. 794.011(10); s. 794.05; e. 796.03; s. 796.Q35; s. 800.04; s. 825-1025; 5. 827.071: s. 847.0133; s. 847.0135, excluding s. 847.0135(4); s. 847.0137; s. 847.0138; s. 847.0145; or s. 985.7(H<1); or any similar offense committed in tills state which has been redesignated from a former statute number to eno of these listed in this sub-subparagraph; or d On or after July i, 2007, Iuk boon adjudicated delinquent for committing, or attempting, soliciting, or conspiring to commit, any of ths criminal offenses proscribed In tiie following statutes in this state or similar offenses in anotiter jurisdiction when the juvenile was 14 years of ago or older at tho timo of tiro offense: (I) Section 794.011, excluding s. 794.011(10); (II) Section 800.04(4)(b) whore the victim is under 12 years of ago or whore tiro court finds sexual activity by the use of force or coercion: (III) Section 800 04(S)(c)1- where tho court finds molestation involving unclothod genitals; or 07/26/17‘y!- , ", - Page 5 of,11’4" ' Public Records RequesI No 17-295 ; Ml CA/Aronberg-000879 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM i NOT A CERTIFIED COPY CA/ Aron berg~000879 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3:128/2023 2:22:44 PM I (IV) Soction MO.M(S)M) where the court fin* tho use of force or coercion and unclothed 2. For all qualifying offenses listed in sub-subparagraph (1Ka)1.d., the court shall make a for each violation of a qualifying offense listed In this subsection, the court stall make a written finding of the age'of tho victim at the time of the offonso. For a violation of s. 800.MW/the court slall additionally make a written finding Indicating that the offense did or : - did hot irivrivosoxual activity and Indkatlngthat the offensedid dr did notffwrive farce or ' coercion; For.a.viplation of s. 600.04(5). tho court stall additionally mate a written finding that the oflomo^dl^ or did hot involve unclothed genitals or genital area and that tho offonso did cr.did-not involve tho'use of force or coercion. (b) "Convicted* moans that there has boon a determination ofguilt as a result ofa trial or the ?: entry ofa plea ofguilty or holo contendere, regardless of whether adjudication Is withhold, and includes an adjudication of delinquency of a juvenile as specified in this station. Conviction of a similar offense Includes, but 1s not limited to, a conviction by a federal or -military tribunal, Including courts-martiat conducted by tho Armed Forces of tho United States, and.lnidud« a conviction or entry of a plea of guilty or nolo contendere rosulting In a sanction tn any state ofthe United States or other jurisdiction. A sanction includes, but is notlimltcrl community control, parole, conditional release, control release, or incarceration In a state prison, federal prison, private cornoctional fccllity, or local detention (c) "Permanent'residence* and "temporary rcsldence' havo the samp meriting awrtbed.fh^. ■ ' .. ■(d) "Institution ofhigher education* means a career center, community college, utitege, state •. ■ : ^university, or independent postsecondary Institution. . (o) ‘Change in enrollment or employment status* moans tho commencement or termination of enrollment or'employment or a change In location of enrollment or employment. (f) "Electronic mall address* has tho samo moaning as provided in s. 668.602 (g) "Instant message name* moans an identifier that allows a person to communicate in real time with another.person using the Internet. (2) Asexual offender stall: 7(a)§fiSiw^Jn ’ ?< ' ‘_r', ‘ / i - X , 1. in tho cauntyfnwhich tirooffender establishes or maintains a permanent oi temporary ; a. Establishing permanent ri',temporary residence in,this state; or b. firing rriri^tfrW.tiw citttr^i^ if tho Department of Corrections or from tho custody,of a pnvato corrcctiorul facillty; or;~ W- 1' 7" ' 1 In tho.coimty where ho or she was convicted*within .48 hours after being co rrictod for a ■q^ under this section if the offender is. riot In tho custody or , ■;, —• j .. w 07/26/.17 Pagej6 of 114 1 » Public Records Request Nj 11 255 CA/Aronberg-000880 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY CA/ Aron berg~000880 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. ~/28/2023 2:22:44 PM control of, or undorthe supavision of, tho Department of Conroctions, or is not in tho custody ofa private correctional facility. Any change fn tho sexual offender’s permanent or temporary residence, name, any electronic ■mail address and any instant message name required to be providod pursuant to paragraph (4)(d), niter the sexual offender reports in person at tho sheriffs office, shall bo accomplish.'d in the manner provided in subsections (4), (7), and (8). (b) Provide his or her name, date of birth, social security number, race, sex, height, weight hair and cyo color, tattoos or other identifying marks, occupation and place of employment, address ofpermanentor legal residence or address of any current tamporary.rasidence,.wilhin the state and out of state, Including a rural route address and a post office box, any electronic mail address and any instant message name required to bo provided pursuant to paragraph (4)(dj, date andptaoeof each conviction,-and a brief description of tho crime or.crimes , conmittod by,the offphdor.Apost office box shad not bo provided In Ifsu.of a physical reddontial address. 1. if tho sexual offendor's pteco of ras'donoa fs a motor voltaic, trailer, mobilo homo, or manufactured:homQ, es daflnad in chapter- 320, tho sexual offender shall also provide to tiio department through tho sheriffs office written notice of the vohlclo.Tcfentlfication number; tho liconso tag number; the registration number; and a doscription, Including color scheme, of tho nibtor.veHclo,-trailer, mobile home, or manufactured homo. If tho sexual offender's ptaco of residence is a vessel, livo-abcord vessel, or houseboat, as defined in chapter 327, tire sexual offender shall also provide to the department written notice of tho hull identification number; tho tnanufacturer’s serial numb6r;-th© name of tho vassal, livo-aboard vessel, or. houseboat; tho registration number; and a description, including color scheme, of the vassal, live*aboara vassal, or houiebaat. - './T ||i|g||||||||||||||||^^ 2. if tha sexual offender is enrolled; employed, or carrying on a vocation at an institution of ■ higher education (ri.this state, tho sexual offender shall also provide to the department through .- .the sheriffs office thonarrio, address, and county ofeach institution,,includihgeach campus .attended; and the sexual offender^ enrollment or employment status. Each change in airaUmont or employment states shall be reported in person at tho sheriffs office, within <18 hours after any change in states. The sheriff shall promptly notify oach institution of tho sexual offender's presence and any change in tho sexual offender's enrollment or employment static. When a sexual offender reports at the sheriffs office, tho sheriff shall take a photograph and a sol of fingerprints of the offender and forward tho photographs and fingerprints to tius department, along with tho information provided by tha sexual offender. Tho sheriff shall promptly'provfda to the department tho information rocofvod from tho sexual offender. (3) Within 48hours after tho report required under subsection (2), a sexual offender shall report In person at a driver's liconso office of the Department of Highway Safety and Motor Vehicles, unless a driver's license or Identification card tliat complies with tho requirements of s. 322:141(3) was previously secured or updated undor s. 944.&07. At tho driver's license office tho.taxual offender shall:- ? (a) If otherwise qualified; secure a Florida driver's license, renew a Florida drivers license, or secure an idoritificatiori card. Th© saxual offender shallidGntifyhimself or herself as a sexual offender who fs required to comply with this section and shall provide proof tlwt Hie sexual offender reported as required in subsection (2). The sexual offender shall provide any of tho information specified in subsection (2), if requestorI. Tho sexual offender shat’, su-xnit to tho taking of a photograph for use In Issuing a driver's liconso, ronowed license, or Identification card, and for use by the department in maintaining current records of sexual offenders. 07/26/17“■ -- I2age7of114 - _z Public RecordsRequesINo^^ZOS CA/Aronberg-000881 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY CA/ Aron berg-000881 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM (b) Pay tho costs assessed bythe Department of Highway Safety and Motor Vehicles for issuing or renowing a drivort Ucomo or identification card as required by this section. The driwA liconio or Identification card issued must be In compliance with s. 322.141(3). (c) Provide, upon request, any.addltienal information necessary to confirm the identityof the sexual offender, including a sot of fingerprints. (4)fa) Each time a sexual offender's driiw's license? w identification card is subject to renewal, and, without regard to the status of the offender's driver's license or Identification card, within 48 hours after any change in tho offender's permanent or temporary residence or change in the offender's name by reason of marriage or other legal process, the offender shall report in. K person to a.driver^ license office, and shall be subtact to tho requirements specified in subsection (3); -Tho-Departmont 'of-Hlghway Safety and Motor Vehicles stall-forward to tho dopartnumt allphotographs and’infennation provided bysexuatoffenders. Notwithstanding tho restrictions set forth in s. 322.142, tho Department of Highway Safety and Motor Vohlete is - authorized to roleass a reproduction ofa color-photograph or digital-image license to'tho Department of Law Enforcement for purposes of public notification of sexual offenders as provided in this soction and ss. 943.043 and 944.606. [ffl . (b) A sexual offender who vacate a permanent residence and fails to ostaHi^i or main another permanent or temporary residence dall, within 48'hqurs after vacatin^titoJiiGr resldonco^ roportin parson to tho sheHffs office of tho county in whichf» or steJbl^Uw-. Tho sexual offender stall specify tho date upon which he or sho intends to or did vacate such residence.- Tho sexual offender must provide or update all of tho registration information required under paragraph (2)(b). The sexual offender must provide on address'WIh^r^dorwx orothor location that ho or sho Is or will-be occupying during the timo in ’ to establish or maintain a permanent or temporary residence ■ intent ■I ■ ^iiMwriyHon®|tiii^ d<&i^|^shBblo as provided In y 775.08&Xml083r6r £<775*08441®- V' ‘ "• ' (d) A sexual offender must register any electronic mall address « instant message name with II ■ Octebsfl,2007.1113 department dwir<Mtab((sh'an online systemithreugh v :offeftft&in»yisceui^wad^ •-■"■■*•-- ' —*«.**»*?. nameinformation. '-'v^ 4 '' . (5) ;This section does notspply/foasexual offortdorwho is also n soxual pn ■ ’ W.iCmmty and local taw enforcement agencies, in conjunction with th&:departmdnt,shiU ® , - verifytho addresses of sexual offondors who are not urxfor.the caro,-custody, contr^or-^ supervision of tho Departmont of.Corrections in a mannor that is consistent with the provisions . of the federal Adam WaishtChild Protection and.Safety Act of 2006 and any other federal . '.?• standards applicable to> such verification or required tu be met as a condition for- ths receipt of - .'.federal-funds by five state. LocaUaw enforcement agencies shall roport to the department any failurebya.soxuatoffcndar to comply with registrationraqiiireinents. - ' ; and update all electronic mail address and instant message in? »/ 07/26/17 Page 8'of 114 Public SB iiawf ho®® St wu I s CA/Aronberg-000882 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY CA/ Aron berg~ooo,882 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM (7) A soxuat offender who Intends to establish residence in another state or jurisdiction other than the State ofFlorida shall report in person to the sheriff of tho county of current resdcnco within 48 hours boforo too date ho or sho intends to loew this state to establish residence In another state or Jurisdiction. Ths notification must include too address, municipality, county, and state of intended residence. The sheriff shall promptly provide to tin department the ' information racsivod from the sexual offender. The department shall notify the statewide taw . enfort^nont agency, or a comparable agency, in tho intended state or jurisdiction of rasfdonco of the sexral offenders intended residence. Tho failure of a sexual offender to provide Ms or her Intended place of residence is punishable ns provided in'subsection (9); (8) A sexual offender who indicates Ms or her intent to reside In another stateor jurisdiction other than the State of Florida and later docidas to remain In this state shall, within 48 hours after tho date upon whfehthe sexual offender indicated he or too would leave.this state/ . report in person,to the sheriff to.which the sexual offendor reported the.intended change of rotidenco, and report his or her intent to remain in this state. The sheriff shall promptly report this information to.the department. A sexual.offender who reports Ms or her intent to rcsido in another state or jurisdiction but who remains in this state.without reporting to ths towiff In the manner required by this subsection commits a felony ofthe second degree, punishable as . ■; , provided in s. 775.082, s. 225=083, or s. ZZ5sQg£ (9)(q) A sexual offender who does not comply with tho requirements of this section commits a felony of the third degree, punishable as provided In s. 775.082, s. 775.083; or s. 775.084. (b) A sexual offendor who commits any act or omission in violation of this section may bo prosecuted for the act or omission in tho county in which tho act or omission was committed, 1 the county of the last registered address of the sexual offender, or tho county in which tho conviction occurred for the offonso or offenses that meet'the criteria for daignaHnga person (c) An arrest on charges offailure to register whon tho offender has bean provided and advised / of Ms or her statutory obligations to registerunder subsection (2),.the soryfee of an. information or a complaint for a violation of this section^ or an arraffptmont on charges fora violation of this section constitutes actual notice of the duty to register. A sexual offender’s failure to fimnedlateiy registeras required by this section following such arrest, wrvico, or . arraignment constitutes grounds for a subsequent charge of failure to register. A sexual s offendor charged with tho crime of failure to register who asserts, or Intends to assart, a lack of notice of tho duty to register as a defense to a charge of failure to register shall immediately register as required by this section. A sexual offender who is charged with a subsequent failure to register may not assert the defense of a lack of notice of the duty to id) Registration following such arrest, sorvico, or arraignment Is not a defense and does not relievo the sexual offender of criminal liability for tho failure to register. (10) Tho department,,the Department of Highway Safety and Motor Vohlclos,tlio Department of Q)rrections,tho Department of Juvonila Justice, any.law enforcamontagoncyinthissteto, " * and th© personnel of thosa departments; an elected or appointed official, public employed,:or *; // 4/ school administrator; or an emptoyoe/agency.’or any individual-or entity acting at tho rcqUost - or upon tho direction of.anyl^ enforcement agency isimmune from.clvllti^lity^^ / ,. for good faith compliance with tho requirements of this section or for tho reisase of - intormation under this section,,und shall bo pnasumedto hnva acted ingoedfaithjn compiling,/ recording, reporting, or releasing tiro information, The presumption of goodfafth is not ’• J. • overcome If a technical or clerical error ismado by tho department’tho Departmont of - j Highway Safety and Motor Vchicles, thQ ttaparbnent of Corroctlons, tho Depertmont of'Juvwrile/^x, 07/26/171 .

Page 9 of 114 CA/Aronberg-000883 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY CA/ Aron berg~0Q0883 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM - Justice, the personnel of those departments, or any Individual or entity acting at the request or upon the direction of any of.those departments In compiling or providing Information, or if ~ Information fs Incomplete or Incorrect because a sexual offender fails to report or falsely * reports hts or her current place of permanent or temporary raridonce. (11) Except as provided in $. 943.04354, a sexual offender must maintain registration with tho department far tho duration ofhfs or her'Ufo, unless tho sexual offender has racofvod a full .pardon or has had a conviction set aside in'a posbconviction proceeding for any offered that moots tho criteria for classifying tho person as a sexual offender far purposes of registration. However, a sexual offender: (a)1. Who has boon lawfully released from confinement, supervfsfon, or sanction, whichever Is later, fer at toast 25 years and has not been arrested for any felony or misdemeanor offense since rcloase, provided that tho sexual offender's requirement to register was not based upon an adult conviction: a. Por a violation of s. 787.01 or s, 787.02; * b. For a violation of s. 794.011. excluding s. 794.011(10); c. For a violation of s. a00.04(4)(b) where the court finds the offense involved a victim’under 12 years of ago or sexual activity by the use of force or coercion; d. For a violation of s 800.04(51(6); o. . For a violation ofs. &Q0.O4(5)c.2- whore the court findstho offense involved unclothed' • genitals or genital area; f. For anyattempt or conspiracy to commit any such offense; or For a violation of similar law of-another- jurisdiction, , may petition tho criminal division of the circuit court of the circuit tn which tho soxual ’ offender'resides for the purpose of removing tho requirement for registration as a sexual 2 The court may grant or deny relief If tho offender demonstrates to the court that he or sho has not bean arrested for any crime since release; tho requested relief complies with tho 0 ft provisions of the federal Adam Walsh Child Protection and Safety Act of 2006 and any other federal standards applicable to tho removal of registration requirements for a sexual offender cr required to bo met as a condition for ths receipt of federal funds,by the state; and the court is otherwise satisfied that tho offender is not a current or potential tiiroat to public safety. Tho state attorney in tho circuit in which tho petition is filed must be given notice of tho petition atleast 3 weeks before tho (tearing on tho matter. Tho state attorney may present evidence in opposition to theroquested!rellef or mayothsrwfsctdemanstrat® the reasons whythe petition sh^dbedohioddf the court denios the petition, thecourt may sot a futuro date at which the sexual offetufar mayagain petition tho court forrolibf,subject to tho starwiards’for relief providedthis subsection. / C : y '7 , ^T'., ,70 3^The department slwtl remoire an qffondpr frqm classlflcationasa sexual offender for ‘ purposes of registration if tho offondorprovides to the department axertified copy of tho ‘ court's written findingsprerdar that indicates that tho offender is nd longer required tn lA <- I . "comply with tho'requirements for rogistratton.as a sexual offender. 7 -07/26/17 '4? - ’

Page 10 of 114 A , si * v - _. Public Record's Request No', 17-295 CA/Aronberg-000884 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY CA/ Aronberg-000884 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM (b).As dcfinod tn sub-subparagraph (1)(a)1.b. must maintain registration.'with the dppartment for tho duration of his or hw’liftj’until tiki person provides the department withanordor issued /. by tho court that as a1 sexual predator, as a sexually violent predator, or try anothe<r-$exual offender designation in tho state or-jurisdiction Inwhich tho order was issued which states that such designation has been removed or demonstrates to tho department that such designation, if not imposed by a court, has been removed by operation of tew or court order in tho state or jurisdiction tn which tho dusignation-was made, and provided such person no longer moots the entona for registration as a sexual offender under the laws of (12) Tho Logidatura finds that sexual offenders, especially those who have committed offenses against minors, often peso a Heh risk ofengaging in sexual offenses oven after being ratoasod from irtcarceretion er commitment and that protection of the public from sexual offenders is a paramoimt government interest. Sexual offenders have a reduced expectation of pnvacy because of the public's interest in pubtfesofoty and In the effective operation ofgovernment. .; Releasing information Concerning soxuaVoffonders to law enforcement agencies and to persons ■ wf» requortsuch information; arid thercloaso of such information to tho. public by a taw ... enforcement agency or public agency,,will’further tho governmental interests of public safety. . The dedgnatidn ef a personasa texuaTaiffendor is not a sentence of a punfshment but is simply the status of the offender whtchis the result of a conviction fair having committeti certain (13) Any person wire has reason to believe that a sexual offender is not complying,.or has-not . complied, with the requirements of this section and who, with thointont to assist th© sexual ' offender in.eluding a taw enforcement agency that is seeking to find the sexual offender to quextion the sexual offender about, or to arrest tho sexual offender for, his or her : noneomptianco with tha requirements ofthis section: . (a) WitWxXds information from, or doos notnotify, the law enforcement agency about the sexual offenders noncomplfanc© with tho requirements of this section, and, if known, tho . 'whereabouts of.the sexual offender; ■(b) Harbors, or.attempts to harbor, or assists another person in harboring or attempting.to .-..harbor, the sexual offender; or^ - (c) 'Conceals or attempts to conceal, or assists another person in concealing or attempting to .' conceal, tho sexual offender; or (d) Provides Information to tho taw enforcement agency regarding tho sexual offender that tho person knows to bo false information, commits a felony of the third degree, punishable as provided in s. 775.082, s. 775.083, or s. ■775.084. r* gte H (14)(a) A sexual offender must report in person each year during the month of tho sexual offender's birthday and during tho sixth month following tho sexual offender's birth month to office in,t)w couhty/fh^ich Iw.ortsh© ^Idos.ords:^ to reregister. j.(b)j.ktojwvor;’a soxual offender,<wl».fs!requtnBi<toregister.aswrasult of a-conviction for: 1* Section 787.01 or $.1787.02 whore tho victim h b minor and the offender is not the victims ',^H^t^iuwdfen;-r -‘f’ ' z*'- \ ■;<./| ’ - ¥ ^07/26/17^ Rage 11 of-11*4 Public Records Request No '17£295 CA/Aronberg-000885 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY CA/ Aronberg~0Q0885 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM K a j - 2. Section 794.QH.oxcludlnsts.794.6l1(10); : \<Station 8OO.O4(4Mb) where.the court finds the offense involwd a victim under 12'years of ago or sexual activity by tho uso of force or coercion; <^j5oc^<>n806.04(5>fl>): — . .\r ' ■5. Section 8OO.M(5l(c)1. where the court finds molestation involving unclothed genitals or 'jjgartfCBrwoa;, . / ■ J 6?.Section 800.04(5lcJ. where the court finds molestation involving unclothed genitals or -> 7< Section gOO.MiSKd) whore the court finds the use of force or coercion and unclothed /genitalsorgcnftal area; gjgjlliMMIIIM -'Utt ■Any attempt or conspiracyto .commit'such offense; or 9. A violation of a similar tew of another jurisdiction, must reregister each year during tho month of the sexual offender's birthday,and every third - fnenth theroofter. ;(c)/Thoshoriffs office may dot^rmfno tho appropriate times end days for- reporting by the withtho reporting reqirfremontsof th<s subsection. Reregistration stall include any changes to the following information: UY.;Name;,social security member; age; rare;1sex; date of birth; height; weight; tair and oyo r-cblprj'addrass'of any permanent rosidonce and uddress of any current temporary residence, '< wifitin thostatecr out of state,including a rural route address and a post office box; any ;. electronic mail address and any instant meAsago name required,to bo provided pursuant to pan^raph. of^any employment; vehicle make, model, color, and license .Itag numbar;.fingerprints; and photograph. A postoffice box shall not bolprovfdcd tn Hou ofa physical residential address. 2. If the sexual offender is onrollod, employed, ar carrying on a vocation at an institution of higher education In this state, the sexual offender shall also provide to tits department the ‘ name, address, and county.ofoach institution, including each campus attended, and tho sexual offender's enrollment or employment status. •f- 3. If tho of residence is an manufactured hDmq,as.defln9d:ln chapter 320, the wMclo idtmtiflcaHj^uml^^ tag num? description, includingcoloir scheme, ofthe mofory r manufactured t£^f(lj|tlw^^ or houseboat, asi&ofined in chapter327, tho sexual identification vessel, or houseboat;.tho rogistration num^ nd the vessel, llve-aboard vessel or houseboat. ,otor; vehicle, traitor,.mobile homo, or ’sexual offendorsheUalso provide tho thej^stretipn number; and a 3hlcte, trancr, mobho homo, or jfftHidonce.lsa vessel, livo-eboard vessel, offondorshallalsoprovide tho hull rnberj thonamb of the vessel, livo-aboard a description, Including color scheme, of 4. Any sexual offender who fails to report in person as required at tho shcriffs office, or who fails to respond to any address verification correspondence from ti^departmont within 3 weeks of the date of the correspondence or who fails to rcjwrt electronic mail addresses or ■ 07/26/17-J: 5- .jStsr-irwJy-Srv’W Put Ik Ri uj dv F6 qu< I No 17-295 4 CA/Aronberg-000886 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY CA/ Aronberg-000886 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM ■ s T Hl Us iu.t'GuT- ■ ■ MM llllli Mil Mati ■ii ililB >third* ■MM |||||H a ■g — jjjii f!|| ISOS! K (lllllllll g|jil|!||B■Sig llljlll^^ B u .u? BSSBlBOliW 07/26/17 CA/Aronberg-000887 Ws ■ III ill M ■III iggaMgi^ ■■■HM SiWt ■■ MaB ■ ■isi® s iMlM SglSaS fig ■gill ■ii iSWil^ gfStgfs^^ |j|BM| '' • ^*~.*--* Yr ■I life i ■|IMI|jji MiB SMii® SB hMM ■tiiiiMiiii Sags MHii| Ww ■ ■ ■liiiW ■ilM W ' Public1 Records'Request No_ 17-295 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY CA/ Aronberg-000887 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM r ' r.-^v ~ CTATEp®gg^ % VS - - IN.THHko-V * • x COURTL^f-K IN’ANDFOR P, .DIVISION OF THE CIRCUIT . FTEENTHJUDICIAL CIRCUIT, x / vl BEACH COUNTYfFLORIDAr’, „ / I CASENUMBERfS). GS 1 DEFENDANT . 2. DERENDANT:,, writ? 3?DEFENDANT: -3" / *.> * 4. DEFENDANT 5. DEFENDANT. i i * - < 6. DEFENDANT: foLEATNjrHE CIRCUIT COURT /'jpam’the defendant in' the above-mentioned,matlerfs), and i-am>represented by;thc attorney indicated below* I * ; - understand I have theright to berepresentedby an attorncyat all stages pf.the proceeding unti[the case is terminated,, .^nd'if Tcannot afford ah attorney, one.will ^ appointed free of charge. ; I ] '• /I'understand I’have tHe’rigiifto a speedy and public',trial cither-byjury or by cpurt./I herebywaive and’givc up this , B ’ funderstandl Havcthcrightto be'confrontedby the witnessesagainst meand to.crossexaminethemby myself or. ,. ’ /''through* my-attorney" I,hereby, givemp these rights. , , ’** . t . " ' _ 1/’... V I understand Fhavc the right toteslify-onhiyown behalf,>but‘l cannorbe compelled to,be a witness against myselj / '''andmay renkin silentifl so choose/1 hereby/gtve upthese rights. ’ - FA*>J • , 7.” ' ; ■ 21 understar«i.rhaveithelrtght’to’cal] witnesses todestifyrin mysbehalf and’,to,inyoke,thexompulsdry processiofthe- , Gourt to subp<^a;(norc:witncss<s.isHicreb^^ » » I J ’ - . ' v° " ' r • , _ “f , - AU'XS’kr >r,understand fhaveJhe,rightto appcal all majtcrs relating to thcchargefs) and,'unless ! plea Guilty pr.No CohtesV specifically rcservmg'inynghi to appeal,"I«will give up suclFright of appeal , ’ , ( ] ^DEFENDANT ?1 understand that ifl amindt a United StatesfCitizen,1my. pleamay subject me to deportauon pursuant^ the laws and .regulationS ROvernine the United Statcs Immigration and N0luralization Scrvice;-and, this Court has no junsdictipn. s . », - - - , [• A 1 ';(authonty):in'such'matters; - , ,x .L /miMr (authontyjinsuchmatters 8. DEFENDANT: A* ' 1 / ' ^DEFENDANT: J . 10 DEFENDANT: / Llhavc not received any promises from anyone, including my„attbrney, conccmingeligibility for any,form of early , ■ ‘ .-release authorized byilaw and further ndpromiscs'have beenmade tome as to the actual amount of time thpt Twill' /sefye under the sentence to be imposed. ’Further. I plea may..fe’;UstxliU\cnhance>fa 'penalties'in ankcourt system, cvch’if adjudication ofguilt is-withhcld. I • _ - -. ■I:offer,my plea/freely.and.volijntarily andofmy:owniaccord:<with:full;undcrstandingofallmattcrssetforth ih the . -pleadings and this' waiver , J *’ F / “• k ‘ \ L I have personally placed my initials in each bracket above, and I understand each and eyery one of the rights outlined .above. I Hereby waive and'give pp each ofthem in order to enter my plea to the'within chargc(s). I understand that *[- ■' cvcn though the Gourt may approvc the agreement ofsentcnce; tKc;Gourt is not bou'nd by the agreement, the Court > < may withdraw its approval at any timc-bcfore pronouncingyudg'incnt,:tn ,which,caseJisliallitx able to.withdraw.my - ipleashouFdiLdc^reJodo.so.v . I . a- > • II: DEFENDANT (Choose one: , Ifjapplicable.-I chdose a program which is of.may be spiritually-based, w. ! Tfappltcable,-l:clioosea;program which, i- Inapplicable,;Thavehapreferenceiftheprogram'isorjnayt>espirituallybase’<J. J. * I t DEFENDANT^ DEFENDANT’S ATTORNEY ONLY:- DATE I am attorney erf record: I have explained each ofthe above rights tb thc dcfendant and havc expldred the facts wilh him/her and studied his/her , ,possible defenses to the chargc(s) I concurwith:his/her decisipn.to waive the nghtsiand.io enter,tfaS:plea.;Ffurthcr stipulate,thaithis document 1 may be received by;theCotulas*'evidcncc ofdefendant’s intelligentwaiver ofthese rights and that ilshall be filed by the.Clerk as.permanent record 1 of,that waiver: 'AITORiNEY FOR ITIE^ ’ V , JOrigmah-Clerlt-'/iSrMmf.iStNc.Attonley^ yellow/iDefe^ 'Fonri-Circuit l (rcySAlOOO): ’ CA/Aronberg-000888 / ? DATE | : Goid&V^'^M^^ 1 form 002 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY ·11;, __ , -.. \.f?_._.;, .. ~~~ ~ .. ;;,:; ,.'ti,; .. 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'",,}<,.;.,<'.. -.~ '""" ~..., ~- ,. .. ·•,.;3,,:,->-< IA,>~.~,,, ... - CA/ Aronberg-000888 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3/28/2023 2:22:44 PM • V' ■MSI RULE 3.992(a) cOllNAL PUNISHMENT CODE S ^0/^ % 2 PREPARER 9 NAMc Q DC^'SAO 6 DOO/ " 1 3 COUNTY 3 RACE 7 DCtl J GENDER ^eLonyZ-' F.S.# DEGREE'. ' If Quahfier please check I 7 10 P^lMARY'^Fdate ‘-a- " '->.7 Millie $_C_R (A=At cmpl. S^'Sci'iclalicn C-Cpnsri racy.-,RvRed issilical on) DESCRIPTION, ■ OFFENSE;;’.' 'LEVEL. ^7 '(JOINTS^; ■..? ?.:(L^'-fe4^=15b.^.1G^5^552<6^^ (9=92^116) Prior capital felony tnples Pnmary CTfcnse points0, r -■ ' ft 'F?* ?«- 'V' Bl I ^’ADDITIONAL OFFENSE(S):. Supplemental‘page attached □ 7- DOCKET# FEL/MM F S #,^7 (2 . ... , DEGREE,: , ■QUALIFY. CpUNIS';. POINTS’ •TOTAL IS ||agg||K v.. ( g i Ill ■script _ X ■X ■■ L Be /.• r-.5S8. , x. ir.caoitaifelonvtriDles*'AWilionalO^^ I c.. &1 ?. &X> ■; Az ■•JrijP’A J'S ■4? ii. IW w VICTIM INJURY , . ,7 ‘ ‘S’ a, V" ' 2S, Degree Murder Death ^Severe ' , •Moderate., < • Number„ iwTotals IV K .240 X, 120 Xs ' 40 X’ C18% u^^'Sox'Ponctrabon? <y Sex Contact ; ro!o1 OMIliB =_■ • ■_ 2-c .J^RfORiRECORD/^Supptenientalpageialta’dieS:^^^ .'.X . ...7 A- ’ Y ■IS hi FE17MM .ES#. .DEGREE OFFENSE LEVEL, QUALIFY," 'DESCRIPTH ... . . _' I / /• / 'A S OR, 1- r ’ “ /"□□□□ / □□□□> it ' t,? -T igfc. ; / 7 □□□□ ' ; • I □□□□ .. (Level - Points" M=0 2. 1=05:,2=08 -3=1 G,:,4=2 4, ,5=3 G, 6=9; >7=i4,-8=19;, 9=23,,10=29) 07/26/17

Page 15 of 114; CA/Aronberg-000889 NUMBER POINTS TOTAL X X' / / I X X x , . Supplemental pagepoints• ■ IV Page 1 Subtotal. Public Records Request No 17.-295 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY ~,"-:: :-;, ... , . ,i• -;··., .c-;:-;;::;c;,,=----:--:-:;;:r':;-:;J},-,,(;_.,_ 'f.lj; ,c:J □Q' s>i;l~j~52/~;i/i,;jli;_f'_~: f_ • ··y-_ CA/ Aron berg-000889 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3/28/2023 2:22:44 PM srF:'T. j r fir. X4P'. ,7 ' - /’ Ut>ga[Status violatia-n^ryPoinL " ; ConMunitySanction vlBbtion before the court f m sentencing C g'^Tntsp-xeach successive violation OR ' 1 vtv NeiSlefony cohvictionL=T-2'pointsx each successive violation _a.Y-shW 7'^7, "'^ri Page 1 Subtotal _ V. VI. M tar ; t^'if*'.'sFircarm/SemiO\utom^ ftvyiif' .* ■8 *■ iacHine;Gurii or 25 Polnts^/V ' VII VII < > Subtotal Sentence Points WK Enhancements (onlyifthe^rima^ffense quallfie ^enhancement)/!?; siM,veKts®^-«a»y <• ’.tLx .^-•' R / - ■ x 1 5 Enhanced-SubtotahSentence Points i !«■ • ■ ■ If total sentence pc nlsiaro;less;thanor-equal:tc ieil leYsenfence is 'TOTALSENTENCE POINTS jwsmsbMm;ts . any non-state onson>sanctlon / ’ •>i >■ If total scntence.pcintsaregreater^han;44A ij^ntence prflgls xX/f lowest permissible,'prison ciissfws-;*- -T3«iWPS^>x?i3»wimaiB^ •^unemiy'or aonsecubvely IMotal^^ arfg^ter thayore^t^ya hfe-bentence ma^jmposed, W ’ ’‘-W •L'' '' >1'1, ''11 l i3’» l> <€2 ^t'oi - maximum sentences- 7 '« . ' ^<.1 -m 3S» .*’.■/ -S'.-. -. »«> »t . -> ’iDays^ ;■ ' > : ■ - ■■ f .* t. . □State Prison □Life : ' . .V!, . x '“ •S□•bounty.Jali• i^rTIme.-Senred, L v i .rj/xe* f*. Ji sh\'j'z-’□Community Control;?... : ; ,.y^O Probation i •. , T?please check If sentenced-’ast’Oitiabilual offender.. :Q) tiabllu; ,’Teoffender, ora □mandatory.minimum applies? AZ ,sr . U-x p , HZ .' VLUf ft I , ] violent cateer criminal.-^□prison re •M '•’ OUier Reason Yr.- •-Lil*’ JUDGE'S SIGNATURE R-^S. 07/26/17 LS69Sa« Page. 16 of. 114 ' “I Public Recoriis-Request No? 17-295 CA/Aronberg-000890 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY . 07/26/17 ·L~6958~:, - •• -•,'.-~"<· , 7&~~~,~~~,i~t.~~.'i'f;··•·· \. i•• CA/ Aronberg-000890 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM L- w,-’ Pago'’11Subtotal - ■Mm & the court for beiileruing 6,pom's x each sujceb5i,.,e.,o'--,i' n ■’-K , .Ni^fejphy.-cbw^ x.ea'ch successiveiyinlation -V(i- 'Firea'^/S'emj-Aufor^ ne Gun = IB or 25 Points 'Vill.' PrioFSonous Felony = 30 Points • - VI VII ■111 IX. . .Enha F<y enMnccninnt) ; Subtotal Sentence'Points -. ^S'-WGonQ _X1 5 x20 Ehhariced’Subtotal'Scntencc[Points IXF /'■ l TOTAL SENTENCE POINTS 'SENTENCE COMPUTATION than 'i/fs^ . nils 2d « lowest pcrmiscbloprison' sentence In months' ^maximum sentefice'iS.up'tbjthe statutory mgjyptum roKthe pnmary.gndapy adcit’onal otfenses-as provided in s. 775.082, ■^’fuplessih8<ilowe£t 'peiTOls§fo^ <xde;'exc«eds tnytatiit^ sentences'may.be imposed' pncunerilly.or consecutively. If totalis,ente'Tce po nts are.greater than or eqijai'tp/363,-a Me sentence may:be imposed ■rnaxin-uni sertencu' .in years -. TOTAL SENTENCE IMPOSED ’ i.Y,cars^ Months P‘’?,s -V...- □Slate Prison;; GOunty Jail □Community Centro’ □Probation - Please check if sentenced as ' □Life' fl Time Served reoffender, or a □mandatory m nunum applies. □habitual o'fender, □habitual vio'ent offender, □violentcareer cnm.nal; □prison rcleascej n'Mitigaled Departure/□Plea Bargain -Other Reason JUDGE S SIGNATURE 07/26; 1/ lneosoa Public Records Request No '17-295 CA/Aronberg-000891 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY CA/ Aron berg-000891 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. V28/2023 2:22:44 PM I Page-1Subtotal1. i ■WA^'.'&q'aLStatus vidiatidn^4iEoints,£-!' ■ . • ^.VL.'i Cbmlputvty-.Sanciioi^viQfdtiq^ the court for'scntencing ' Sji^ints.xeach’„successive violation OR .-‘f Ndw:feioriy..convictiori;:=,T2;pc>iintsx each-successive violation U/'" " '|VII:;.? Efrearrn'Serni-'Autgmatic’nr.Machine Cun = 18 or.25 Points ’VIII. Pricr.'Serious Eelony-='30 Po-nts ■ ". V. VI VII. ■ VIII? !\ c « ■Subtotal.Sentence Points -■ IX. Enhancements’(only .if the primary offense qualifie x20 ;sr s’ ■ Enhanced-Subtotal Scntonco Points’ IX?/ . X ' • / TOTAL SENTENCE POINTS’.. ' ’ . SENTENCE C'OMP,UTATIO‘N If-tc'al-seiitencepuirilsarejess Ilian or equal.to 44, the lowest permissible sentence is any non-state onson sanction. i Ji * l,,to!al_sen'r»'t c<» p j nts are greater than 4£ f ' > ' \ ‘I itQlitrseiitencp’pcints: ^frjfhus 28^^ 5 = lowest pe miss b'q prison • sen'nnco in months; js/up lo.Uie stHtutcry nia^rmumTor the pdniary arid any additional offenses os provided In s 775 082, ■f0j$unlessVwjowest p'flh^^ 'the-coSo. cxccocs the statutory maximum. Such sentences may be imposed '’concurrently or consecubvely. if total.ser.tenco points arc greater than or cqdahto 363. a’ ite sentence may be imposed X'.- 7 st mayitrum sentence n yea's TOTAL SENTENCE IMPOSED Mcnlhs -'Days ■in Slate Prison '>4; "vtj County Jail □Community Control □Probal'on Please check if sentenced os □Life □ I line Served if □habitual offender, □hnb'li.al vio'ent offender, □violent career criminal , Q^rison . reotfender,. or a □mandatory minimum applies .□’Mitigated Departure □Plea Dargaui. Other Reason /t re'ea^ee JUDGE’S SIGNATURE Is ‘S .■.,07/26/17 gage 18 of 114. Public Records Request No 17-295 CA/Aronberg-000892 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY CA/ Aronberg:..000892 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM PLEA IN THE CIRCUIT COURT- TH£ FOLLO\MNG .IS TO REFLECT ALL TERMS’OF THE NEGOTIATED SETTLEMENT Name: Jeffrey E Epstein Ptea-GuMyjc CaseNo.Charge__ __ _Count Lesser..Degree’ 05CF009454AMB Felony Solicitation of Prostitution T No <3 Fl I. 08CF009381AMB Procuring Person-Under 18 (or Prostitution 1 No 2 FEI PSI: Waived/Not Required X Required/Requested j ADJUDICATION: Adjudicate (x ] I . SENTENCE: I On 06CF009454AMB, the Defendant Is sentenced to 12 months in the Palm Beach County Detention Facility, with credit for 1 (one) day timeserved. ; On Q8CF009381 AMB.the Defendant is sentenced to 6 months in the Palm Beach County Detention Facility, with credit tor i (one) day time' served. This 6 month sentence is to be served consecutive to the 12 month sentience in 08CF009454AMB. Following this 6 month sentence, the Defendant will beplaced on 12 months Community Control^(one). The conditions of community-control are attached hereto and incorporated herein < OTHER COMMENTS OR CONDITIONS ’ As a; special condition of his community control, the Defendant is to have’no unsupervteed contact with minors; and Ore supervising adult must be approved by the Department of Corrections. ’ ; The Defendant is designated as a SexualOffenderpursuant to Florida Statute 943.0435 and must abide by all the corresponding requirements of the statute, a copyof which is attached thereto and’incorporatediherein. ! The Defendant must provide a DNA sample in court at the time of this plea. ] . i . _L_ Assistant State Attorney " Attorney for the Defendant . - - - .'?v V- '’V ‘ ‘; ■ - ;• -- . . DateofPtea Defendant ; OZ/26/17 CA/Aronberg-000893

Page 20 of 114 Public Records RequesbNo;:-17-295 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 5 28 2023 2:22:44 PM NOT A CERTIFIED COPY ::1::(-T"'"'~•i' • ·.: ~ ;ir~;;::.r:;J;( ·, ~'·,· .. . . ,,'•: • ·. ,> . .- . ·•· •;. i -~:.,I~~M:jij,,JH~-~~·~~,H!I;£P'.Qij1>, . . >,:A -~.-;/;i 1 1:'~f, • ·-rH8/f\OlLO\IVING\IS<tORffLEe1•AtEJERl\fiSi,0F/THENEGOJ,lA\f;E[)S!:'11i1._&:tvj!:~J:._- . _. N~~tlj·,;~;i~i;~,,~;\:,.· V/·· •• , •• , •• re'-•··.-.--••· • -~ • _"···::_r •" --;~:.',:~?.:'._·•_--!, •• -· ''.'::•Jr ::t'"';;l\ ;@~:~:,.c,;ri)fu,}~f _ ,y t < • ~,y-!~~~o_; _ ... : ;'~,~- ctiar~'--· ~.:,::.·.·~~- .. ~. --,/~!::(-e,~~:r:~·-;~-.~/)3~~i!'~-(;,, .oijt~~~$~~1t te1o~v/~~J1~ij§~r€dit?~tf1,yii~n • -~l~ •• . • fNo: ... }~':@fI '.;_~ OQC~~t...;IB 'ili•~iiW f>e"9N\!il\iiC·i~!ro/ ek~¥tii!~.i . 3~¥ ~~€{;~ • ,~~f::~n,,e.~l~<>t}t9qijifo~:-,"¥. 1 •.. • i~~~\l@gtRi9~~t,#'~- ·•~~~yo~C~TJ~N~ • · ~.A,~fo~~~e•tx ·r 'SENTENCE:- .. , .. ~-:r:. ~,·.,~. ·.· ~--- ,--__ • .: .·.: .. ~ -~;-.: ... :-:; __ -___ :_·.,- --~·-·:"<::•~~- _· _" __ -_ ·,:t,·_--_.;~<"-'c.,,:.- ·I r 'OntER'.COMMENTS'.OR,CONDITIONSi:: ~'.,•:;•<•.,_;~•'•a,-,-,-•---- :'•-T-::'•-• '• .__,. ---:--'-r • ••• •••-s••~• ,--• -•-,- -=-~:••/• • - l '.r '~t~~lldarWT~~t~~#;a/gijA'~~,n,fp_\Efiry'_c;<>trt';ft~~:~,r~e()fffiis:~ie~. I Li, l L r I. 948.101 Termstahd condttionsofcomm^^control and/crlmlnal quarantine community control." | (1V The courtshall determinetheterms and conditionsipfcommunity control. Conditions specified in this subsection do not requiro^oral pronouncement at the time of sentencing and may bo considered standard-conditions of communi ty control. (a) Ute court shall require intensive supervision and surveillance for an offender placcdinto community control, which;may;include but is not limited to: j 1. Specified contact‘with the paroleand probation officer.; I 2. Confinement to an agreed-upon residence during hours away from employment and public ■serviceactivitics. 3; Mandatory public service. 1 4. Supervision by the Department of Con actions by means of an electronic inonitorihgdovire or system. ' ?5. -The standard conditions of probation,set-.forth,in; s.? 948; 03.. (b) . For an offondor placed on crirninal quarantine community control, the court shall require: 4s .Electronic monitoring 24 hours per day; 2; Confinement to a designated^residence during designated hours. (2) . The enumeration of specific kinds of terms and conditions doos not prevent tho court from, adding thereto any otherAmms or conditions that tho court'considers proper .-I lowovcr, the sentencing court'may only impose a condition of supervision allowing an offender convicted of s. 794.011, s. 800.04,.s. 827.071, or s. 847.0145 to reside in another state if the order stipulates that it is contingent upon the approval of tho receiving state interstate compact authority. The court may rescind or modify at any time the terms and conditions theretofore imposed by it upon tho offender in community control. However, if tho court withholds adjudication of guilt or imposes a period,of incarceration as a condition of community control, tho period may not exceed -364.days, and incarceration shall bo restricted to a county facility, a probationand restitution center under the jurisdiction of-tho Dopartment of Corrections; a probation program drug punishment phase I secure losidcntial treatment institution, oi a community residential fadHty owned or operated by any entity providing such services. (3) The court may place a-dofendant who is being sentcnccd-for criminal transmission of H!V in violation of s. 775.0877 on ci iminal quarantine community control. The Deportment of Corrections shall develop and administer a criminal quaiantine community control program emphasizing intensive supervision with;?4:hour-per -dayelectronic-monitoring- Criminal;: quarantine community control statusmust include surveillance and may include othor measures normally associated with community cohuol,-except that specific conditions ne<:ossai y to monitor this population may be ordered; . 07/26/17

Page 21 of 114 Public Records Request No.:17-295 CA/Aronberg-000894 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM I NOT A CERTIFIED COPY I -v -- ), ~;~-~~ ~ =, ~·:·,: .. :-~:t~/y;; .. : i·::··--:,;:'2J(f>>·:·-:~- ~ ::;:.,.:,,,;._~- . - _-- ·-·;:.(~(:;-:-: ; ·:- :;~!i~[;;f 4f ~f ,09J,{i\i(i/i~\f >;o~<•,i,in••;~,Sj'n~J~D~~i•~f !i•~t,(!\i,1!!~t,•J§~L•Xic, ·· ~. .,,~l,~)\f-~f i51~il!~f l!if Jtri~f!:t~;~~i,i1 ;(~f ;ij,~i~~rt;s~tiJ'r~gfr~yi~l:(!11~{VQ'S\J@r.~•~8b}~~:l~iir,vqi!tri}i~~;f_fit;a,)tt>ffohQ~j;(a,i1·~t!Ni :.comirioni' conttol .wnicn::n1a :>inclucic butMnot>limitad;to:'- - - .• • • • ",~ · - • •• '·-.•- ... --··:-·~~-.. ,-~·--·'.,:'•, ..... , ,.,,,,"',Y, •... ,,,,-._• - ··- ·•··"" -. ·•i,,"·,.·.·.•-- .. • -.- ".... • ~ 'J:, ',S~'.ocjfi~~ii'?t•}}~ct'~ t!l t.h~~pa~0,le;~-l)~tpr~#or,{&:rfii:~~/- f ·}il~f~Th~Wt~~r;n,r,~iir~::upg}1[tit{t1i1n{~94C!•Jt(li~tJf~~~Ji;n;ortJ,oiliJ?toYrri9.nta+:p@nc: ' -~' . t 3; '~ndat~ey_'.public servici,;_ , ) ·ir:j~si~Tily'!fu>'.!Jk~•'~o~t,Of!S.;/i~!i"f'~[lf i~~.,;,, S(),;, ~\~ifO\li~•,i,OiJtJ;~'!!t¾f . . • -;~x·;Thjrs,~~t.lc1f~:~9~i§9n{#f1rl>~e§n,~~tj§ttHiiri"iJ?~~-~!~: J~)/t=ofa6'~f{~~-~l3!'.:rt~cec!·oh:(cfi)'~,f!'altq~~adil~ff_imti11,1nit.y:~°'rifrol~:t~rl{ou~~:s~al/;r~J(~i1i:½ ·;1\:_Jt~ij~ni¢.1n6~t~~~ifi~11:io.11rf~e.t~~~x;-.. • ·1' ;~~n:~~(:~rf d~iin~t~ fr~1qc)11~ej~~ti,i'tf~~1j~~to~;tto\id .. . (2)/i•~-srium~r.~ti~fi,'.9.ffo~lfi~Jinds;pft.~,;~a~f:i:i~a,Jfip_tjsA~·nf>t,~r;~YS.f!~Jhgcd~yf~}i:~mf ••addirC sthel'efoian. iothe1,~t:ern:is 0.qr condi tiofo,th~~•tfio·.touft\fa_,1isj9µr,~ pro1Je(,'tl:l6\'iO''Yt, ;llifJ• .. ••. ··•,£~~Jst6ti'~~4tt,,J;x,i11W:}rfie~i~:~<}ri~(tl§Jifo'f"·,,,ifi\1C?ri ~tfu~i,va,j~Jqff99Jff'1:9_1l~?t;a-9f . s,.;7.<)~iOU,•,s.·:800:0fu;;s:;827.071, Q(;S'.<584'L0.145': . .··1opi_i1~11othor,~~at¢;iJ;tl1~ ord.~f. : )i!t?iJ{§~i~~ififJs'(c:~if~1:;}nit-llP,P~ihi':~#r1,~;:t~\,;fl.~h~f¼~~t~,~~)t~t~'.i,\t~1J~~ti,~iw,P~~J::· '-! ,,,~f::l<>r1ty;:[fi~:f9u..rt;may,r~~1!:.14i_Of;OJtr91ft~tc39.y,t1mq,~h~;\qrrn~,!nft,q.1ng1t19n~.t!,~;9!9,fo.ro. . :imP4)seo b Jfo) • •· nf tnj:> qffoi:fidort inJ:oininl'.in1 f 'contf olVit:iowewrr, i f[th~\court.withholcisi • .. ,:~}tli~?:l1£i111~iillit!ll~iliili1tl' ~ommun1t:y,r:OS1dent1ahfo1:il y\owruxi·or:,operatoo;by;any entity pro:v1i:hng such•scrvices.,· •"--,,.~a:.--~:;,=y-1~"'.c\;' , __ ,..,_, :_- . .--_/S'." ••. __ "'.f,r:- -•,i,i - -, _ • "''"·· -..':'•'~,, __ ,- ~ - :·----, --- ,.._ ,,...-,.-:.:.,,-:,.~:. ___ , "'.., • -- --, -,--_ ,, »-.-·.-~•"--~ .• .,, __ "" ---._---,-_ -=~ ~ - -,··,.i,-,.r,-,. _ _, :mil""A~~t11,riiitt;~,:~~r.:;11:~1t1r:iidiG~'.l~t:i1~t•'~•r1~,· :\Gorr' halEdove ' •• •• • Jaainir,H(e • - '•" ·nat/'ua'rzi'ntino-:co1ni11unif'-· con&:'ol >r<> trarir. _h,Ji~ti'~§i~fifg'.jnt~·· ••••••• ' itbnS\~f!{ljj[ .. , ', 'Jf-~~fr{~f~{(fujrf f C ' ' i,g'.)trfo\ii~~t/ c,;, ' . ' tju~ran~lrn-1'.<:om. - ,e,f,statlJ<r.;mtisbindudo,su,;veilla~ioi'ridn • 'f{jcj;j_othdrtn:ic2f,.i1rnr.< .firi, , is~~er .~ . "'t~~ij:~}i~f jttriw: !Jl;'i~f[~~Ji,~r.I~W,g;ti~ri,1ii½~~r;tr ,... :; (ji/26117.

Page 21 of 114 CA/ Aronberg-000894 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3/28/2023 2:22:44 PM I ,943.O435 Sexuai offendoisrequirodtorogister.withthedepartment;penalty.-- (1)faused in thissecticn,the term: -; * • i . ... .. _ ■ •- . . ... . : j . ... ■ ./ (a)1. ^Sexual offender’means a porternwhotmeets the criteria in sub/subparagraph a1’.,sub- subparagraph b./wbrsubparagraph c.ror sub-subparagraph d., as follows: ! a.(l)* Has been cbhvicted of committing,,pr, attempting,<solia'ting,iOr conspiring.tojcommit,.anyA of the crimirraboffenses proscribedtin tho rfollowingistatutes in this state or dmflaroffenses in another jurisdiction: s. 787.01; s, 787.02, or s.787.025C2)(c).wherctho victim is a minprand the'dofehdaht ifhot-the victim'siparontior guardian;:s..794fh^ exciudingis;;^^ 794.05; s.*~796.03; s. 796.035;s. 800.04; s. 825.1075, s. 827.071;-s.t847ldl33?.s. 847.0135, excluding s. 847.0135(4); s. 847.0137; s 847.0138; s 847.0145; or s. 985.701 (1); or,.any,similar offense committed in this state’which has been redosignatedfrom.afo'rmw statutenu^ one of thoso listed in this sub-sub-subparagraph; and J t . , A' ' (II)* Hafbeen*released on or after-Octobor 1/1997; from,the sanction imposed forany* 'convictionof an’offensedescribedinsub;sub-subparagraph(l).Foripurposes;ofsub-sub: subparagraph(i)7asanct)onimposcdinthisstateorinanyotherjuri^ictioninclude,s,buti5 „ not limited to, a fine;* control-,/parole,/conditional-release,^control release;,or incarceration In a state prison; federal-prison,private correctional facility,/prMocal detention facility; ’ i ’ b. Establishes or maintains a rosidencein this stato and who has not been designated as a sexual predatorby a court of thisstatebutwhohasboendesignatedasasexualpredator/as as sexually violent predator, or/by/another “sexual offender’designation,in/anotheLstateor jurisdiction and,was; as a result ofsuch-designation, subjectod’-to registration on community or public notification, or both, oc would be if thp person were arosidontofthatstateor jurisdiction; without regard to whether the person otherwise meets the criteria for registration as a sexuatoffendbr;; ' . 1 ! c. Establishes or maintains a^esidoncein-thisstata who is in the custody, or, control of,-.or junderthb supervisioh.of; any.othprstate or juriKUctionas-'aresulttofo convictidnfor', committing; orattampting;,soliciting; cr conspirihg to coihmit,’any-of>tho crimihal pffch5es; proscribod in thb following statutes or similar offense,in another jurisdiction: s.^787^01,xs.» 787.02, or s; 787;O25(2)(c),' where the-victini is/a minor and^ defendant,is notithe^victim's . parent or guardian; s. 794.011; excluding s. 794.011 (10):'s.-794.05; s. 796/03; s. 796.035; s. 800.04; s. 825.1025; s. 827.071; s.-847.0133; s.- 847JM35, excluding s. 847.0135(4); s. 847:0137; s; 847,0138; s. 847.0145; or s. 985.701 (1)^oranY'similar^offensoLConimittc^m this;. state>wliich has been redesignated from a,former.statuteinumbor to«one:offhose'listcd;in.this: sub-subparagraph'j-or, ! idiOn.or afterJuly-1; 2007, hasbeenadjudicatedideUnquenbfor. committing, or attempting, solicitingpor-conspiring to commit, any ofithe criminaldffenses proscnbedinlhe following.’ statutes'in^tin's state or>similar,;offonSGSiimanother.'jurisdictiomwhomtiie-juvenile.was’-14,years of ago or older at the’-time of the offensc: ! (I) Section 7.94.014, excluding.s:,7-94.011(10):: -(H)- Section 800.04 (4) (b).whore the-victim is'undcr 12 .yoarsof age or-twhore the court finds* sexual activityiby theiuso of.force or coorcidn;- .(lll)1 Section 800.04(5)(c)1;; where,thecourtifintisfiibipstationjh^hnngii^icfeth^ig^ni^^ '07/26/17 Page 22 of114 Public Records Request-blo.:’ 17-295 CA/Aronberg-000895 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY Ihr!!'ll.~' -~~~:~u..i.~,si~~i~\\D•r.~•"1'<-w!thi!ii•;<t~~~~~~•~:;;, 1 'Jf[·;@A~'.iM!tii.fi~.t:Jili,f.l~\!~!Jii} ~ 'i ; ' .•. . - _.·.,· • '· i .. :!~-$~~~,;1:~1~ir.v~~i,w;ic,:~t~~~-¥1*1''\¥, ·a.'<i);:H,as'.6eon co~victed;ofcommih1n • o,i~~ptiha;:souctin , -or.;to -• :i,i~;hfcdm~tt;;~~vt l<>ltho:'cri'''-•····;~ficnser· 'oscri~rh(~,:fo'iio~h'is!atutes-/i'n~J&~te?rstmitaffoffemos011t,• , ~~~11~~k~~n.~:~iJ~?:;~~:;~-'.i'!~at'.!:~~~t¥~~?,~"!'02:sqrt~,i~~~~~~~1}~~~rnf!~:~;m~,~~ii~t~. : the 'doferidanfls'.not:tlie•vactim ·s~~ront ior;.guard1an ;\S\)79.4:01,1 '; • excluding:s:'·794,011 (,1 O);ts,1" ''"\~;'--.•·:l'·"-'.·'!-' ... ~t ... ,.'.·--' ._,..,,.·_;.-.;;_,.,- ..... ...;.,/--~--.· ·.- ":·,/"'.•'. ........... ,.,.,)-•./', • .:,;,,-1;•"•,1:.,..·;::1;:,,,,,;,';'•('1 , . . ...,,,--:·:,,..~.:is~:•&·,t.~;::::._~1}_;;>,J._~--- -•· -~.,:,:\';'_..,-,··, 794 ;~~ ~.:·796: 03 F~t;7.96'~035i;'.~:t_8oo:04 ;: ~;;:azs;,1 ozs;: ~._0 a21;01s1 ;~~d~~lJW;•'. 847 ;01-35~; • .. ,. _ '~~~~Jna:S: 847';0'i-l5M);r~2847,~01'37; \~:184Z:0138;'~s;V847: 0IAS:~~r-1~;~98517,01,(1, >rn:~r;~~:s1m.it~r,·, ,, -' _ :.offomato'mmittec:Fiifthis:stato'. wtiictiitiastooer{ret1asi •• oatootfrornia\fo'rmer'-statu£ern'umoeri,to,;· • ;~~\,f~~itj'~.i<f!riithj~isl,~~:S'~i{~7~r~~F~l11!}JL. ·"' .,,.,v .. : :''·'.: • "·. ".'~··,:, 0tr •¥ ~,, •• •• . . - . - l • :'JI}; ,tla.l'~11;t~J~~£~:ot,~!~rS~~~{:fr.sW9Z; ·:~~~·'~\~J!s:(i~•ft~~~~(J~j:~~~Y,•. ••• • : ~coi't\ilctfon,of;an foffense\describedtfn,sub:sub:.SUb' ara' • _,,, • i, 1(1):if.or/ ~,. •. osei:yo[sub::'.sw ;'; ·; su •• ~fa·· ii\ "Rr, ,,.:!,i;"siin'ctk>ilYiwt•~;Jii;rthii :s't.ar.!'o1-a~~· :itfleirt~cti&'J;iiilti:att~tbudit:: fno'mirili~it<li':iin,F/ i-'oti~tia'~';&;,;,cn,;;~-it' }ccintrit;,'~iiJr~-:,~~itioilal\'i~f onfrciti. C: . - ~~~t~;k~.~l~T/i~;)'.~"if ~~it'i1:'°-');:~~rffii/>tll.§i;!!A~ij'~~iJ%, •·· a • r~l}tfil~c,~il ., ib:!•£statili~'cof•niafntains ~f:l"OSidonce'io :this;~tato'fan&·Wtio>JNis•nit"beori dosi -.rnit~:ai:a,. • ·;~)f:~t~~tt~f:ttlttt1if~~lt~~;;~~~1l~~~~i,,~ti,tt~,~t~i~t~}~t$'O\.: . :Jµri~r~W?hl1!~}w.a~,·~~-,°"\f~1Jlt,.qf-gicJfd~~ift~.tj~(r)/(w~j~~9(11~~i~i~tr.a{i~nr~;§m~1unl~y;Jir,; • , • • • utilic not1ru::aiio'r1 :or;both, ,o,;:Woula' botitXllio; • rson:w:erer'a'lresidoof6t:thatstiito'·o,/> -- --, • • .. . _:fuif~g#~~~~;~~\·rij~r.~(tf\~1¥iijf~:~tfff!?;P.~:n,.i~~rii(~;rn~~j~~~~BJ9ii~i~~r:~1~v~l.i~')1~· .c,\S-?,l,'.~)('::'~~i~fffan<f,o~;, - - • - ! • • • . '.·.'" .,,.·. . ., . . . ! 1111\illi~ll~(:-'.i\c!:li:l • ::~r~,:i~':<>~.,~~~r:~i,€i)f<~.';?94,;01:r;;pxc.l~l!;'ifi~Jj;794;01;1'(!19);~,s_.;'79.~:0S; }' ,96:03;~~;,'.'796~035;1:~::. · ':SOO:O'f;,cs,:::az5~;1025 ;~'s;',·82'7,:071.;'~~;847!013 J;(s:<8~7t0.1 ~35~/exdijdi_rjirs:::8-17 ~0l35'(1'msr; • ·• •• · . • 0·8-47c~01l7;':'s~;a4zfo1-as;1~fr8<17~o1·iJS;'.'~rls~\985'.701'{:1;);::qt,{~ffi11!simU¥i¥:$tfu·~if,§1m!~t1xtJ.1~~4!fa~, ·sµ~~f;'.whidit1asib'oon,<i:~osi "nate0'fi:omtii1'cfoi-'mer,{st.1ttte'1numboiitoro"We:otitnosQ1u\t~tE1h'fi1W~, . '.:ili~~:~~~1~\f~H;:(J:r: .. · .-,'.~.. . , ... ·- -···-··- · .,,:;•·- · '"" ·· · :>····· -.-- • .. ,~'''"-f'' ,._,-"" .~~i~1ii~Jj~t~iii:~i~(~~~~¥l:~(it:€i-~~!;:~1~~w;:;iii~;i~,~t{if;j~ii½r·':,~.·· ·.~~~l:~~.t•rfth,1,s:,,~-taJ~:~r:i,s.irml,c11:;;9_ff~.,!_ll'~n,oth~,>J.unsd1ct10_n.:,wl1~,-~-'.o;JIJVQm.l~:Y,,a,~,!ftiY.~.!lr; ~.o.f~a~~:Qf~W,?l'.'j~,~!i,8;,tjrita:'~f-,~!tf~!f~ri~~.: ··· · • • • • • - l • • • - • •• -·' •• : .... ': ,' -., .; : . l ~ '_:,. •• , • " .• " .• - l '.(I) ·~~~i<l.ti:1.94:0M~~9~~~~<iii)g)i~~7.94.011'.(~JJ,);~ • • '07/26/17 f'age 22 cif 1'1<f l:,iJbhcRE;C9rds. Re,qui:5,\;No,: 17-295 CA/ Aron berg-000895 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM (IV) >Soction l^:04(5)(d)‘whero*tho;courtifinds the wo of force or coorcionand unclotncd genual^" ' ,-•> ' I . " ■■ . . . ■ 1 -.v : C J . . 2.. Forall-qualifying offonscsjlistedimsubrsubparagraph (1 )(a)1.d., the court shall make^a writtonfindingof at tho tunc‘of tho offense ■ For eachMolationipfra quatifying offenso listed in this subsection, the court shalbmake.a writtbn/finding-of thdiago?ofIhoMctimat the.time.otthe offense. For a violationof s1. 8ML04(4)’ tho courtshalhadditionally. make atwritcon finding indicating that;tho .offense di‘,i?or did not involve sexual activity and indicating that the offense did or did not involve force or coercion. For a violation ofs. 800.04(5), the court shall additionally make a-written finding that the offensedid ordid notinvolvounr lothed genitals oi genital area and tliat the.offense ;did'or- did;not’invoive:tho uso^oft-forcoiorcoercion... j . . ■ .i (b) Xonvictod^moans-,thatthere has^bcon.a>dot'irmination of guiltras/a result,of .a trial,orAhe, entry of a plea-of guilty ornolocontondQro, regardless of whether 'adjudication, is withholo,: and includes^anjadjudication qfsdelinquoncy of a juvenile as specified in this section, i Conviction of a similar offense includcs; ;but is net limitadto; a conviction liy a foderabor miUtary'tribunal,-including courts-martial conducted by the Armed Forcos of tho United Status,, >and includes a conviction-orentry of a ploa of',guilty or nolo contendere resulting in a-sanctiun in anyistato of dio United-States or other jurisdiction. A sanction includes, but is not limited to, a-finoy. control;, parolopconditionalreleaso, control tclease,/or incarccratiomin a state’pnson, federal prison, private correctional facility; or local deteiitfqu .facility;.: i . . ? '. . . . -.A. : . ■< . . i- . . (c) 'Permanent rc$idenc©7andi>tempofar.y,'re5idehCe'';Ha^t^ 775.21. ' ‘ ' •' -v---...- - - , ' (dj. -lnstitution of'liigher ediicatioiv means a career-center, community-college, college, university/onindopendent postsccondarydnstitution. (©) "Change in-enrollment or employment status' means Ure commimcotiuml pi termination^? enrollmont or employmehtor aichango invocation of enrollment or employment. (f) ?Qectronlc‘mail address" has the same meaning as provided in s.-668%602; (g) -■Instantmessagemame-'ineans anndentifier tiuit allows a‘person to communicate^n real time with another person using tho Internet. (2) .A>wxuafcqff^^ ; (a), Report in person al the sheriffs1 office- , •- . •• . . t.;. A.; - ; v _ . L , ...... I.- In thp.countynn whichi'thmoffondoi establishes ot maintains arpernianenUoi temporary:- -fesidoiKp/W^ : av Ekhblfshihgip^ res'dciKQ .n this state^br ; b Being icleaspd fcprriWb;Custp'dy, control, or supervision pfithc^Dop,^ or from the custody ohaspnvate correctional facility:-m. ■2. In: the countyswhero ho or.sho was convicted within 48mojjr.s afteMwiiiH convicted for 'b qualifying-off^ under .this,s<iction>ifxtheio.ffender--is-.not'in tho Custedy ’dr 07/26/17' Rage;23:of 114 Public Records Request No.: 17-295 CA/Aronberg-000896 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY .· • . ·.• •. . • 1l1~~(!91'~s_lXl?<!t!i~W!'i.i'w•:t\;iliCf •~ijni/,::l¥. ~~f ~1?.,iiii?~~l.o" •nil'"\i<'•rh'fd~ tJW;1!i~{~:1!\l~t~im;rittt~~~i1~~i~'~~,•.~win~r••1 ·!!ilit~f i!f i~f !~t~,!ii!l1l~it1:r' .• .. so~.c ... iP,!!::f~r,Ji.'.yi.~,~t1_g,!f~,f~,,~OOJ.Q1~~)iJ\!t\~'~.~r.t,11'1.~J!t~J1d,m<>p'31ly;,f'!llI~~·~fVi(l_tt~1~:,f1p~JQU,· thatt,ho:offon~:'dfd;or,'.oi<f;notfinvolw1unr;ltithod,.-•onitals'~h "enitar'aroa,ano~tl~'i{t}1o'offo1,~;- • :iiii~«iiiilil(itiif i~~:\•. -· rnilitar 7tnbunaHini:l :courts"imirtiitl"cBnductoo1b'",'th,f • • eif'.F,orcos'oLtnc·:Ui,iteiJ-'Sfatci'>'- _ '.~r~i,r,r~~iji~qi~ii{;.{~t~~~~itl¼ 0~;i~tj]~~~iJf:1~1:~~~J(i~7~FX: ,to;:a!fino-t rooatiori'-'coirimuhi •• \c:::ontfol•;. -rofo-/Conditictrial'release· coritrof:rcleiliio'!;oJ' •• ;·':, • • ."'- •r•-,<-:•.~ ,P., •,. •. ~·:., Jl, ., ,·· "·•~CK • ,.;. ~ cy __ •'"<"•~-• •.·. ,o:~J' .. ~•'• "'-l'•."·; ~- .. ·.~·.,,,~ ··:.-<.:,."".t~ ':,...":·•ft~..,,,··.-.._-c.,'<J ·--v•. . • .• • .• .. ''" ••-.,~• t .... J; :7_ '.• ;1~rcoratfo'niin~a::statorP.ii1-o,n'/f~ora!l:1w1son;, i;iiyifto ~co,.-roctionali'racility, ,i,f • 1oca1,,ai;it:6,jtr,n • _ ~ : . .-;'' ·,-.·\i·.S.~~···.'·."· ,., .... ...-.·.,. ......... .._.,,;••.?.,.:t:;t'- '- r ,.· ;,, . ~,. ..... ,, .... •.-.... • , ... _,.,, __ , •• ~ • ";:< .• ••. c·· .. -•··· ,·,:..,-,,--~ . .,. • :i:,,. ,y • f , Jaci\it)':_: • • • i '< , -'".l ~ • • . • . • ! ·. • . : :~k;tfma'ri,o~t_ rosi~et)~i?~nd.;"-t9Tpp,rary,2rosi~.er,1ce"1~~\t_hi,}$lm-:G'nl~~,n.fh?,~s¢.ii.b,J:iil ,i:,_ ':tll\i~111~r1ilil:~,r~iii:~~l~;{(;r~t!t;~f~?t~t;)<A~t11~ri.ii~i!=~Jl~{),•·~qll{}~~:':~ta(f:> (~)': • ~i11ars<{:Jn;.enr9llfnei\tio{ ·e,.nplpY!flii~t,~tat0::; ,W~iij;:~.1?. c_on;i1ne,h~<il-!r1cn~,9i: i(o1:i~i.hiitppr1:/,\f '¢'nr<ill_irwnt''oi'!~mploymen~'oi'.::a•cl1:a'r'.igo in:locatioiiof enf9llment:orj:imRloy111l?flL: . '. ·.•.·',. •.:~, • ..... ..-~•-,/l .·,· .. • -~., •• ,.~ .. .'.-. ••.•·:c.•- ··.,,. -:-·-·~.· ... ,·.?;>,.:-'·.. . ·,, ,; . •<ff 7~~~{~(ontc1(!laif:~~,~~~,~~:t1,g;~Q•·me~,1inaia;1W?vi~aj'.),f$·.1~iQ?;:,,, ·!fl;1:~;}~tt~,~i~~ii~f~:;tfgi1rt~~fief·,tno~,'~tJ~}halP,_~~~l}·t{f<9)l1~nVrii~afotjij<r:e,~f· l?) A':S8xutikotfohiJor;;sttaH: • •. .. ;·.: , := : :, ~ . ., : .. --·,; -~· .,, • ·•·, ;;, , _,., • :_(~l; :R~P?r~fii,'.P;9S'S!J"'t_~!:1~\~,'{!½r@t.~:,c,ffi~p: .)t;it:®t~i~t!~t.Jt~{\!ii•a',' ,,i#.a,;t!.li~,,ec'MB\Ota;,;, ·.~,j'f f ol•O<!iJt;Q,>.Stj,01\~l!ii('t i , _it:, -i1:~J~)i;!ii~~~9,~t~ia,rt5 :~15~2r\l_sf>~~, ?&1t/J>~t 51t,j.1!g1¢~i{in ,9.~~tt\<f Q1~)J.~lncn:, gf;{f~~~)\:tt o_n:, 9rfr.~1~'.U),1"i(;ll~te><!Y'<?f;~rpQv~t(),t:~rr,~~;~!9.n~! ~a~c1l,l,tYt'?!: - ' r '·!~1~si}~,f~~;iiti~~z~~t~r:11:~,~~titi~):i~titt:it:;}l::ir~,~t~~t;h1it:,~~tit{t 07/26/17' Page;:23:cif f14 ~ublic Records R-equE;st:No.: 17-295, CA/ Aron berg~000896 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM ' control of, or undor the supervision of, the Dbpai tmenVof Corrections, .or is not in tho custody of a pnvate correctional facility. i ■ Wiy'change inThe texualMfender'sipGrmanenhorjtemporary rcsidonco;inamej any eloctronic mail address and any instant message name requiredto’bo provided'pursuant!tpiparagraph (4)(d), after the sbxual offender roportsTn person at the sheriffs'office,,shall boaccomplishod . in the mannor provided in.subsections,^), (7),-and J8) . : ' • / T • '"i • ’ . f (b) Provide his or her name, date of-birth. social security numberi<rac<^ sex,?hc^^^ hair and cyo color, tattoos or other identifying rnarkSjAoccupation ahdplaceqfjcmployment,.= address of permanent or legajjosidence or address of any current .temporary residence, within the state andout.of state, including a rural route add, ess and a post'office box, any electronic mail address and any instant message name required to-be providodpufsuant to paragraph (4)(d), date and place of each conviction^and a bnePdescriptionpf. the crimeior crimes committed by the offender. Apqst office.Box shalhnot be provitlcdJnfbeu of a-physical residentialaddress. , V. If tho sexual offender's place of residcncp.is a'motor vehicle, trailer, mobile homo, or manufactured homo, as defined in chapter 320, the sexual .offender shall also provide to the department throughjhe sheriffs offico wnttenmotico of tho vehicleidontification number, the license tag number;"the registration number; and a description; including color scheme, of tho motor vohictertrailer, mobile homo, or,manufactured home. If tho sexual offender's place of residence is"a'vossdi; liw-aboard-vossol:, or;housoboat;-as'dcfincd .in.chaptor.327,^the. sexual . offender shall also'provide’ to ths department,yzntton notice-of'tho hull identificationinumber; tho mahufecturer's>soriat numbof/ tho namo,of tho .vessel;4ive?aboard vessel, or houseboat, the registration numborjrandta dGscripb'on,including,color-scheme,:of> the vessel,-livoraboard ” i vessel, or houseboat.. , i . . ■ ■ 1 . 2.. If the sexual offender is enrolled; employed, or .carrying on a vccatiomat an institution^’ higher education in this state,: the sexual offonderr<shall>ajso providesto thedepartment through* tho sheriffs office:thd name;zaddrossj.and couhtyio'f each, institution; including each:campus attendedpand the:$exualoffenders enrollment pr .employmentstatus; Each change irv :enrollment .shall be reportedimperspmat the sheriffs offree,within 48 hounsaftcranychangcan status; The sheriff’shall promptly-notify each-institution ofthe se/nat soffonder'sipresencciand-any-chango in.the sexual offender's enrollment-oi employment status, When a'sexual'offender, reports at the sheriffs office,: the;sh<:riff shall taite a photograph and a sot.cf fingorprints-df.tfib'qffcndoriahd'forwardxho.'photographsandfingcrprints Withe,- idepartrnontjialohg with the information provided .by. the sexual offender. Tlie sheriff shall; promptly provide*to tlieidenartment the.information;receivod from the. sexual.offender. 43) Within 48jhours;afterthc>jreport required: ijriaersubsc^ticn.iZ),-.a sexual^ ’ropcrbin person at a;driycr’silicense‘Officc:ofithc Department otHighway .Saretyiand Motor- Vehicle,^unless-a'drivorTbccnse'or tliatcomplies-witothe.i.equireirieiiuM^ <s.,^2^4T(3Vwas'previcusly secured or updates under s. 944.607. At tho drivers license office ithGisaxualoffandbr-shisU: i I 4a); If secure a Florida drivers license./enow a f lorida driver’s license; or securoian iaontincationxardi lhe sexual offendersliall identify hmisolfot herself asjasoxuSl offender whons-required to comply withlthis section end shall provide proof that the;sexual .offender reportodas requirodiinsubspcuonUl);. Tho sexual offender-.shall p< ovide any of the inforrnatiomspemficd'in'.sub-section:,|Z),vif roquestarj Tho sexual offender dull submit- to tl taking of a photogi aph for use in issuing a drivei Ybccnse, renewed license^, or identification card; ano for use byThQ'departinent-in.matntaining currontfreccrds-.of.sexual offenders. OZ/26/1.7

Page 24 of 114 Public*Records Request-No.: 17-295 CA/Aronberg-000897 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY l\titiltt{t:l®\~~;~111i1lt.i!~i\'if f illS~itl'.ilW!lfltit ,~,,,}fl .,1 '11 ('J)t,~a]:'P,f~n~':'sly,, SO\:.!Jf qd;~!i'l.lP~.il_te.a :!Jtl~lqcs·". _9!14':!!,,9].::,_: At(t!io ,s1f:!Yct;'! ,~1.ce{1~~~tf iY~ , '·' '!~m'f'.~~i.i~!toffin~HF~ha,\!/. • • • • . ' • •• • i • • '•, . . I :f-; f: 1{ '~~~~;~r1~19~1~~-i.t~-~,~~ --~~.~~,r: -~ f \<2c:~~,a.;,9j 1Vf-:,(~;'~~~c,~q,;r~,<?~'?:~:,!~f t~.d!tf~(s J\<;~!)~$i jr: ,~'#';:~~, J<l.9!1i.!~.~~,W:>J}::c~_rd.,: J. ~r,:~;;i~t:•.~ftcn,d~rc:;11~!!, 1dei1!1!'1-.11!t,lJ~tr:-0r!1<lf~~-.,; f ~sl~, s,t?.~'tl~L. ,gff.£11,~~ ,'.:'".O· iS:[P51~ r~ t,?-.~qr:np~y _-.:,,1.~)nhi ~}9~}Li?.ttan<1:sh{J l!~,m~~~q•-(_p!,:~(? f thet· t}!"'i S_t1~~1il. ·,g.~fon,<;t~f !9PP~OO;.~t r~lJi.[O~)ii11si1l?~~iori, rJZ)~ ':Tlj:O ~~"<(i_~l off~cn~~IJ'-~!)al\; P.f~"-i::!.f :9:.trof 'th'J -inf ?t~~~tfon1~p9q r~~~:-~~:i~idf(cc,tior'1 •;(~) ;:ft r: ei.il!.~j,totJ: Tho si.>x\.fii 1' ~ff_~_n9~r,,tl):'l_l l 'r~u)~11j,j~,: toA'i,~, '.J~~Jrjg,of:~,~li~farAP,}J:;for,;i.i_~fe}~'<.i'.}~U!r:i~_;~-~r;i'tCl~A~cgn.u, f.~l\f!,'!1,~-~'~igf1~~;,10J_'idq~,WJ¢4t.iqn c~!<li ana, fo, •. us.,,bY,JJi••diap;!<tmO.n.ttn,,neiOra[Oiftt.su""""'oco,n,~r,,.;,ua!" 6ff e.,,<j'lr,.. _ . C . • . . . CPJAronb::::~~0897 pa9eµ ~ 114 P••roro~s Re,:7'"" 17-~s FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM - . 5 - / I - I ■h: -- - #■- 4 . . < - " . : j ’/ -.- (b) Pay’the;costs assessed,byTheDepartmonvqfdJighway Safetytand Motor Vehides^fordswiing fer- tenewing a’drivcrs’licensa oridontificationxard' asirequired by this section. I ho’ dnyors ■license oridontiftcationxard issued must-be in compliance.with s. 322.141(3). ■ -(c)- Provide," Upon’request; any additional'inforination-nocessary to confirm.-thc identity;ofi4he sexual-offendi^'-.Ta.set of fingerprints.-, (4)(a) Each time a sexual .offenders drivor's hcGnso or idontificationxard-is.subject to renewal, and; withouVrcgard to the status of the effonder s drivePs license or within • 48 hburs aftorariy cKango in tho;offendor‘s permanent,or or chahgedn the - offorderyname byrrdason^pf marria^o'r dther legal process,vthQ offendor. sha^^ person to a'dnwr'sTicense ofhcej andshall'be subject’itO’tho requirements spoafiod in! subtectipm (3), The; Department of Highway Safety and Motor Vehicles shalbforward to the , .dQpartmonbalkphotographsand-informatiomprbyided-bysexuaboffehders.iNotwithstaiidingtha ^restrictions seVforth ini s. 322.142Hhc;Department- ofHighv/ay5afoty and MotorVehicles is .authorized-to roleasea raproduetton of a colorrphotograph orsdigital-image Uconsoto the ’Dopartrnont:ofLaw Enforcement for purposes of;publicnotification:of«>xual;offenders as prdvidedTnitfiLslrcfibh-^ i (b) A sexual offender who.vacatesia permanent residence and fails to establish or maintain anotherpermanent or,,temporary residenceishall,;withm 48;hqurs aftorvacating the permanent - resfcfonco;: report iniporson;toithe.sheriffs>office'tof tho county in which he qr-she is located. The soxual-offondor shall specifythesdate upon;which ha orshe ihtends to oridichvacatesuch, residonco. The sexuahoffender must provide or update albof tho registration information requiredmnder paragraph:(2)(b).The;sexuaOoffender must, provide an.addross forithe residence or otherjocation that he or sho-is or wilkbe occupying during thetime in. vvhich hejor sho,fails to;eztabli^or;maintain a pcrmanenVor temporary^residences ! ‘ (c) A sexual-offender, whoiremains at a'permanent residence after roporting his or her intent to vacate such residence shall,,within 48.hours after the date upon which the.offender indicated he or she would>or did»vacate such-residence, report >in person to’;the agency to .which :he;or shQireported'pursuant'to;paragraph :(b) ,for>ithe purpa5o of reporting.his- or honaddress at : the,sheriff receives-the roportj-Vhe shixiff the informationito the dopartmente'An offender >who makos,a>roport as required ,undorr paragraph (b)sbut failslqirnal(O arcport as.required-underthis paragraph commits a felony oftho;second •dcgroo;:punishablo as provided ims. 775 O82,;s.-7.Z5.O83, or^ i (d) A:sexuaLoffendsr:must,register;any electronicsmairaddresssor instant message name with- tfio;departmont prior to.usmE 'such electronic mail address or instant message name on of after ■’October.:!, 2007.- ("he department shall.establish an online sexual offonrlerssmay securely eiccoss and update all electronic, mail address and'instant message- ’ . i (5) .This section'coes not apply to a sexual offender who is also-a "sexual f5redator,.'6s defimvl in ^• ■Z'ZSjZT. -A'.sexuahpredBtor must ragistanas.required uitderis. 7T5£21. I ibT'-Gounty and-.local law;eilforcement.agencies;Tn conjunction.withithe:department, shall- vorify the addresxis of'sexual offenders who aie not under the caie, custody, n ntioi. or supervision of thcjDepartmoiit of Correction-, in a manner that is consistent w.th the provision, of thcTodoral Adam Walsh'Child Protection and Safety Act of 2006 and any other federal standards applicable tc such verification or required to be met as a condition f >r die rcceipi of federal funds'by tin-"state. ! ocal law enforcement agencies shall loport to the department x./ failuraby-a sexuahoffender toxomply witn registration re^ Or/26/17

Page 25 of 114, Public Records Request No.: 17-295 CA/Aronberg-000898 i FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY ,~98~(2,i.P.~t~!~l?,lo~;J_~'p_r~Y)q~_,J(l'.s;, 775'.082·;;'.\l,-~ts9.r-i.~,775:08<t., ' , • • ~········ •• •• ·-·-- ••• r.·-··"';•·~•- -·--·---.•.···· -----~ :;. -· . . Jm,.;;~11Ktt~~~;~tt~~:!t~t~1ti~1t1~t~rr;t;JI:~1;t ttt~1},t.!/~~ -~ ,;-~:~tnlt\~llr _, 0.<=.!ofi :1.! ·_2907 .;:fl{~fd,e~a-~~~!}f sha.~I; ~f~~.i:il_is:1.:~1~_6n~irto,1~1tf!f th:-b-':~h;t!h1d-i~9"x,uf-'~ . off~nd_i;t~sm1!lY·S~(!r~~y-n_c~~~ apg, ~pqat0 i.tl!:~1~tron1c;l'!1~_1\:~d.dfc.'?J ?I1thflS!-~11t r~e2s~eB,· l~~•t!o)h~orm~ti9_!'1,, • •• " • • ,· • • • - • - -, • • - -, · • - i -· • -- • • ':(?.l;,l[!J(~,;s~:~i?_QJ~~-~~\lp~ti'I:°;~ais?1t1~VfFJn~-~rr;J.~g:cir~(~J~fajf~~l1p.'.r,e<ta,toiJ~~:#,ffef]ri,Sirfi1J•· --s./Z:~1:~;l,~·.:As~~t,ial'P,f-~ftr,to.r, mµ~_t, r,am:.i~,cl'S,r!f\'.!1Jlf~9'.U..IJCl~r;S~_c '{]2:,J!.;, l . :f t~if il~~;Jf!IJJ(lllllltISill~1: '~9,"'J 1~/t!,1;1.Q,sJ.JJYiHl!?i,.~!:~ t9r·t'Jt:~k~a, •~i!.QfOft;'{1r:';)t, , :?,~\\?~QC::lf~.-'c::\Vi:l~"EOP<>r:t'.~~tb,G' d9!l?f~~il5?~1t ?{ii'/.} '. f<!illff~f t;>S~ie '}f.!~lf~n oJf1~-~.~r ~rCfJfll 1~l Y.'"'!L~ll'{~J:-_;tr:;,£t[9p;f.£9~/ii:.4i'.f ~!1;~; : l • • • l -- - - -. l / -- d7!26i1:7

Page 25 of 114 8u6ncc~ords Req:e:,IN,o.;t?-295 CA/ Aronberg~000898 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK j/28/2023 2:22:44 PM i (7) A sexualteffonder whomteiids to establish residencoJin*anodior,stato?cr jurisdiction otlior? than the Stateohfiionda shall report in person to tho.shanff of the.coiinty cocurrent residence within 48 hours bofcrc;tho date ho1 or she intends to leave this state to establish residence m another state'or‘jurisdiction..^ must include'theaddr;o5s;«municipality,i county, and state of intohdedtresioence-iThe sheriff shall promptly provide to the department the information recdivodfrom the sexual offender Pio department shall notify the statewide law enforcement agency, or'a comparable agency, in the intended'state or jurisdiction of residence of the sexual offender's ihtenood residence The failure of a sexual offoncier to provide his or her Intended-place oft residonce'ls punishable asiprovided in subsection!'(9). ' ’ (8) A sexual offender whohndicates his or her intent to roside in another state or jurisdiction other than the State of Florida and later decides to remain in this state shall, within 48 hours aftoKtho elate upbnwhich this'soxuaboffender mdicated he or.she.swould leave this state, report in^pdfsoh to the sheriffito wl-nch the sexual offender reportod the/intended .change of residqiica, and report his or her;intent to remain in this state. The sheriff shalVpromptly report this information to’tho dapartrnent. .A sexual offenderwho reports his onher intent-.reside? in anothdrstato of jurisdiction;tiut wltosreniains in thisstafe without reporting>td the;sHenff in the manner- required by this subsection commlts a felonyoft’tho second degree, punisliableias: -provided in s. 775;O82; s..77.5;083;[ ors. 775rM4c (9)(a) A scxual offonder’who does.not .comply wicb:the;rcquirGihentsiof<this section comiTiiu. a felony 'of tliia;third degree, punishablQias provided in;5: .775 0827<s. 775;083.;or s.. 775-.084, ~~,, .- , . , . .. .. . . .. .. . .. ... ., | <; !(b) Asexual offender;who commits any act or omission In vlolation:ofrthis section may be prosecuted for the act of cinission in the county in which.tho act or omission was committed, the county of'thelast registered address of the sexual offender, or tho county in which>tho conviction occurred for tlic? offbnso or offenses that meet the criteria'for designating a person as asexualoffendor. : ‘(c) An arrest on charges:of>failuro’to.register;when the offender has;been provided;cind,ad*>ted of hisiot hei statutory obligations to register under.subsection (2), the-service of pn, ! information or a complaint for a violation.of this section; or an arraignmentoncharges for a ■.violation of this-soctioniconstitutes-actual notice,ohthe duty to register. A’5exual,offendcr\ ’^failure to immediatelyYcgister?as r<^uirod’by this sectioiT.followingjSuch,arrest, seiM^ arraignment constitutes,groundsifor a subsequent charge of failurq;to;r,egistor. A sexual offender:charged with?tho ci imo'of failure to rcgistertwho asserts; or IntGnds’to assert, a lack of noticc of tho.duty. tc.rGgister asfa defonso.to a charge of failure to registor-shall . r immediately registeras required by this section A sexual offoridei who is charged witKa subsoquenUfailure'toxegister may not assort tho'dofenso of a lack of noticccf the duty to -.register:. ■ i (d| Registration: follow! ng such arrestpservicepun’aFraigninentiis-ino^atdefetisc and deus nut ■relievo tile sexual offender of criminal liability fortho failure to rogirter.. ; HOr-Tho department, the,Department of Highway Safety and Motor Vehicles, the Departmc.c of Gorrections.-rthe Department of Juvenile Justice, any law enforcenu'ntiagcnr v in this state ■and thepersonnelof thoseidopartnientsjten elected or appointee: officjaU. publicemployee. sdTOobadministretor;iorAan employee, agency, or any individual or entity actin-,fat the req x-rt :or upon tlie diroctiontef any law enforcement agency is immuno from,civn liabilTty'foi damages for good faith compliance-with the requirements of tins section oi for the rcleas.:- of 1 information-under this’section, and shall be presumed to have actodhn pood faith in compiling, racoiding, importing, or.i,’leasing the information Tne presumptions! .pood-failings not overcome if a technical or clerical error is made by the department, the Department o> >Hignway-Sofoty'and-Motop^nhiclas, the Department of Cori odium; the Department of Ju‘v: mtc 07/26/17

Page 26 of 114: Public Recoils Request No : 17-295 CA/Aronberg-000899 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY ·····--c·;:·--· ... . . · !~~~!~~~~~;6l:.~~~r.~'MW~6.~f',~~iA~~if~~fa\"k::~;~~~'." ~ •• £f~)i,~,s~~Y~ti>ff~nd~r{~Wfu\~~rpjr}i~a!1~;,as5oi-);rrf!:~ll:itt!r1.'.~J9;~~fr,>,rr1qt,;~~if~~~0rim~{~ .· .. • .. ·.P,r<>secute<!Jfor;,tho:acf,or,·oinisgcin:iiitho,cQUi"!fy,il'l:.wnicn;tho:act:Ioi"1oiiiissioh_;~as•c:"0Wimitto<i, •• . ·.i~ci ~ci®W:~Bt!f~:i~{~1f~gf{t1f ~tViiddf~:irit~~~S()-XMtl~!ffe.tide1;/<ir;~h9i()uflit1:~ ~~mi,~rni, : :tom-1 cti01,:ccc:urrod: for,! tl'i<i: off0nso oi"'of (onscs :tfultmtiiof tl'ict c·n todi.dorri:lcsi • • nc1thi •• ta·, er,spn: ;~ .. ~;i~ti.~t\qtt~K~br:: ... •,v.• ,... •• .... • • • ··-- •••• , •• • •• , ...... -~ , •• , •••••••• -~- •• '~' •• P<·. . - . _/ \9t:UR9.'\E19:~.1~'1~~10.~,~f;.i9Y,c,l~~91_1f~r~~m~>11f<1flQ,1y:yt1s !flJ~liJP,n@• ~rpp1)c;1v!Hgi_b1b1.ty•fo.r:i;{_a1.1J•tt'.'?1 ;11tiM~llilill!liiiW!ilitt::: 07/2611} P?ge'2f3 of 11'1 Public: Recoti:Js Req[J_esi:No.j 17-2.~5 CA/ Aronberg-000899 I FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM i Justice, tho personnel of those departmont$;>qr,any indiwdua^ acting at the request or upon the direction of anysof those departments in compiling/or/pro^ information, or if information is incoinpleteorincorrect^because a sexual offender- fails;to report or falsely reports his or her current place of permanent or temporary residence. j (11) Except as provided jn s. 943104354, a sexual offender must maintain registration with the department for the duration o'f his or her life, unless the sexual offender has received a full pardon or has had a conviction set aside in a ppstconviction proceeding forany offense that moots tho criteria for classifying the person as a sexual offender for purposes of registration. However, a sexual offender: J (a)1-. Who has beotvlawfully’ released frorn confinomcmt, supervision,.or sanction^ whichewr is later,’for at least 25 years and has not been arrested for any folony o^misdemoandroffenso since release, provided thattho sexual'offender’s requirement to register was not basodsupon an adult conviction:; ! ■a. For a vioiation of S; 7^2.;pl ors-! b. For a violation of s. 794.011, excluding s. 794.011(10); i c. For a violation of s. 800’04(4) (b) where tho court finds the offense involved a victim tinder •12 years of age or sexual activity by the use of force or coercion; d. For a violation of s. 800,04(5)(b); o. For aviolation of s. 800.04(5)c,2. where tho courtjinds the offense.involved unclothed genitals or genital area; | f. For any attempt or conspiracy to commit any sm-h offense; or- | gi For a violation of similar law of another jurisdiction, - j .may petition tho criminal dhision of the circuit court of the circuit in which th<- sexual, offender resides for the purpose of removing the requirement for registration as ajsexual offender. ! .• ; i ■ 2. Tho court may grant or deny relief if the offender demonstrates to tho courtthat he or,she has not been arrested for any crime since release; the requested relief complies,with the provisions of the federal Adam Walsh Child Protection and Safety Act of2006 and any other federal standards applicable to the removal of ragiotraticn’’raquiromonts for a soxuahoffender or required to.be met as a'condition for,the receipt"of federal funds by the state; and tho court is othorwiso satisfied that the* offender Anol a cur: out oi potential, throat to public safety. lh<> state attorney in the circuit in w hich the petition is filed-must be givoh notice of the petition at least 3 weeks before the hearing omthe mattbi The state attorney may present ovidor.ee in opposition to the requested'relief or may otherwise demonstiato the reasons why the petition should bo denied. If the court'donics the petition, tho court may set a,future date at which the sexual offender may again petition the court foi rabof, subject to the standards for relief provided in this subsectioni j 3. Thp department shall remove an offender from classification as a sexual offender for ,purposes of registration if the offundoi pi ovidcs to tho department a ceitifiod copy of the court s written findings or order that indicates that the offender is no longer rcquiredAo comply with Xhorcquirernentsifor. registration as a ,sexual,offender. 07/26/17 Page 2/of 114 Public Records Request No :17-295 CA/Aronberg-000900 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY .f :; ·I l i ; -:G~.--:f9~;}f-il~j,a.tii>rrifi~:.:1,9;~:~11.;:~g!t~~J,rI1J~r,z9,i3J.}ftffot; • ! :,i!~~trJ;~;~~f~i{~it¼i1f1%;~tr~~tti~;! 0~fo~~I-+Vtt'ffili~ ~ "> , __ ---_ -- /·-\~,-.,-:_'.~-"; -,·~ -,,_; ... ~· :,·_:_:·:,.:: __ !:·"·"=~,.} .. J. ·-., 9• ,f,9"'~ v,io~at1<;1:1.:9!;\o;;:.:;~:-,!t1(?tf~.h • f. trli.1ti~; ii~~'~i~1,rt,~~~ .,,. ~~V!'Jff ('<"' ,1w ~,;;.~;,,&i,,.,1:1~1sjfi,\l t'' it ;for,:~9t~~tt~r,npr;o.?'~2l\sgjf!!<;y,t~iEV:!1J:'Tif~:,~J1t:Af11ib~~Jf~l'i~; or,• ' l ,-, ! • itit~iH1$\~fltltill;i1~t t~~i6~h~ 1t~~titjtif'"A!~l:~~( . ~ ,:.: .l11il!itl::tliiii~;r~ !!!iilil~l~i!lii:. ,pr,r;~t,nrcd tOib(J!'met a:.:a·c9nd1t1onJe>r,:th0recQ . f .federa.lA . , Y thes. • and,ttj~if9.~ll'..t llllf ~il&!;~itt~l~!tli::~~;;;fif i Cs~x~itltoff oilcler;J-r1.iiyfi!gisfn,i10tit.'ior\ >thccoud'. flf!:,rdliof;.:-sul:ij&:t;to;tlic':.st~ridar.diif,::,r1rot iofi• • '·• ,;;;~;;;~;;~~;[;~s~;:;tti;~l½;~~,1;~;~,~J;1~- '.<:!}.lift:Si~fitt:e.12J1nd,iDJ?:.;9(<ir<lei'Jh~t-jndfoatc.~;~h£1t,1b$;<?ff~Qd'irctS·J11?JQf!8f!f)(~t1~tr,e.q1fl?.···· • ~~_rhf?Jy:wJthJhI?:i:¥~ui;-9,r~~i1W(or.,r.~~t~t{atiRn'~J,;;~f~~x11~F-<r(f9,iJ~~r:~' • - • • ., • , . . 07/26/17

Page 27 of 1-14' 8ublit Reqxds Regu~sFNa:, 17-295 CAI Aronberg-000900 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 4128/2023 2:22:44 PM f \ l i (b) As dofintrijn subTSUbparagraph (1)(a)L^^^ maintain registration with:the department, for thQ duratiorf'of hisior. her.4ifo;untibthe person provides.the depaftmont-with arvo'fderi issued* by tho courtlthat-designated the person as.asexual predator,jas-a sexually violontjpredatorror by/anothcrisoxuaFoffondor. designation in thejstate or jurisdiction in/which the ordpr-iwas • fssued-which states thabsucludesignationshns been removed or I department that such designation, if not imposed by a court, has boon rotnovtxTby operation of Iaw.or court'orderin thoistate/or.jurisdiction in.,which the designation was;mado,;andjpfpvidcd such person nolongermeets die criteria for registration as a sexual1offender under the laws of thisstoto. ! (12) -The Legislature findsithat.sexualioffenders; especially those who,havexommitted^ffenses, <against'minors;>ofton pose a?high:risk'of engaging in sexual offenses even afterbeing released' ■from*incarcerationior'CommitmcntTandsthatprotoction.ofthe pubhc from:sexuahoffenders>>s a. paramount government interest; Scxuahoffendersthave a reduced expectation*©! privacy1 because of tlie public'siinterast'.in public*safety anddntthe offective’operation .of government.; Releasing.information concerning sexual offenders to, law enforcementragenciesandltopocsons! who request sUchdnformation; and the release of such informationtoitho publicby alaw, enforcement?agencyorpubhcjagoncy,will, furtiiertho, governmental-interests of;pub(ic,safely. ;Tho dosignation ofa'person;as arsoxual offender.is;not-^sentence.or-^ punishment buttis.sunply.i the status of tho offender which is the result of;a conviction for. having committed certain .crimes.1; ■ '' '■ { ? (13) Any person who has reason to believe tl>at/a sexual offender is not complying, or has not complied,, with the requirements of this section and who, with the,intent to assist tho sexual offender in eluding a law enforcement agency that is seeking to find tlio sexual offender to. .question the sexual offender about, or to arrest the sexual offender for, his orher noncornpliaiic^witlrtlie.requiremontsLof.'this section: (a) Withholds*informatioivfrom, or does not notify, *the law enforcement agency aboutithe sexuaLoffendensiiioncompUance v.'tth theToquiremonts.of- this section, .and;, if'knownj tho.. :wheroabouts.of’the’sexuakvqffendcr;? j (b) Harbors, or attempts4toharbor. or assists another parson tn.harboring or attomptingito* harbor. tholsQxuaK6ffehder;;6f . . i (0 Conccals'or .attempts\tp'Conceal, or-.assi'kkanother personal concealingior atterhptiiig to (dk-Providesunformation’tO'thedaw enforcement agency.regarding-the.soxuakoftender, that person knows to be/false,information; ! commits a -felony of the thirddegroe; punishable as provided in s 775 08Z, s.7:7'5.083/07-s-; 775.034: ~ 414) (a):- A^sexual.offendoiunustooport in persorreach yearduring the month of-.tho'sexuaL offendersibirthday andidunngXhe.sixtirmonth following thG:sexual’offeiideds birth>montlrto < the sheriffs office in tho county,m which Iki or sho residos„or,is otherwise,located,to'r<.rcgi:.iar< .••• - '• _ ■ ■- - .•-'‘--I ’ • ’ . , : | ... ’ V (b) I luwevur, a'saxuul offender who u required tu register as a result of a conviction ror. 1'. Section 787^01 or s.tfSv.lQ-jwhci e the victim h minor and the offender'll not the .victim; parent?or’guardian;, .07/26/17

Page 28 of 114 Public Records' Request Na: 17-295 CA/Aronberg-000901 ' FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY ,et>f .:A~,~0(t~~)t~Y~ti~~~J~~,r~qJ~'(jJ(aJ~~,. ',~~/~~iritiif~fr:~t~,~~~!~~,~tl!~Yi0·:~~ft-~W-~l,. Jor: '.tho-<furation"'of li1S101; Hed 1fc1until •ttH~; per son,p(OYI e· depnrtmoiit1with •aii"'o'rcler;, .. sueq} ~/(',""-"<':,.: Y.' .lf #•.._:i,.",•~,,,...,v- ~.,,t-"' t, ~ ;,...-,. ~ ~\ \.,..~- , y J~ ,; v"-.. ~..,,,. ""¾").,...,.••"'f"-4,"' .,_ ~., ~,,:.,. . b~ ~~,c~~ur_t,~~~~·.dC'}J~1~~~-~-?,_P,~Q_n~J-;~,~.xual,p~ _ . fi~!!f~':,;~tu!JlY.f~~,~~}1gf:~it9rt9.~; . \~Yia~,$<;:-~~~~~Al~~!f.9.,:i~pr:. d9:1_g~t_t<?.~ .}.1!J~: ~~~t00 . .?~ 1_u_n~i~~n1,i_Q:i;"'.f!~~,_N!_h~.or~t).'!"~~: . ,, ,~ i~~,Jiti1f:_h•W1te!>':tf1~t<sych,19es1_g11~;1p,n.l)as o~n.~~~9~,,;n:.p~~<?.r:i.~tra~(~~;~;i. _ . ~ , ., • :·de •· 'rtmcint::tliliHsucll' aesi • nation;'. i(riot1impo~~:tby;a[court,/lias\0oon,romo;}O<J;1f 0c} ·",iratioi,j oft •~t~J~J~~f~_e?jij,th'~~;,~(~JohJ~rJ~dj2tfi~ffiry!~'%~Jfh1ihf@~f""':tt?~'*~~J~i~~;/f~Jf~~~,d~: ;Slict,irfersoh'rniil8·n8er;;meei:fall~;cfitc)1Ji\fof:reeis,tta~o,ra(a•· . {tC>ftenoefiundor.-;th,t'.\ta\s,sf&f:: Xtni~ts:&¥~-d,., ... -,_: ·,:--., .... •. __ , ··,•· .... , ~·- ... •, ... ,, .. :"•' :.c· ,·• •• '"• ·!l.liJtl!i1fll1111\t;;: \WOO re. uost'such';ihformatiori anditho{relea'se:of-sucffinfofmatiorhtoithor ublii::b';zflaw, • ·,,:. •·:• 'J~k,., · .. <' . . ·'" ·, ... , • .. • ,C ~ .. •" • • • •., • • n •, •"'-~-"<'> •,•/'" :• , ,,.· •:• ✓ ,.• •• , "" 5.;,,. ,, P ,,. , . , •:•Y,., Y:'' . , ·.,• ., , . :~fof~~ri,:~@:~eO:rif:y;f>fPHl?.li_~~~t1~11fY(:'-'."(!f;fL![;!,!lilt;,:~r"§..:eo,~nl'.!lcri~tJri~i.>r~~;~f/~µt,i.li¢{~!~~y~·. --~~:~t¥ti~.~~n .. ~f:~~\~~~irJii(~)~~~Q~l·:~,t~e!\~Ji1;.1;~':1j}~:~·~~~~<:~:<;:[0tt)?~~?i~~~~~i~~-~ii~j~j~j:P,Ji-" -,~:;~~~~"~1tli~fo((end9r0'~~J.f_K1,s\th~:r;,q~ulrgtcfC.~r,l;<'1C!t,9,n:·f()r,t1,a"11Jg!~.or;nmit~ed.•~gft.~!'! . :CcH.~~'.i •• • • · · • • • •• • • ··, - • • • • · •• • 1 •• . -- ' . . ··;tji)_:~f P.~t~:~'.~~¥1b~•-t~a~ob~to:,bi~)f,~:,t!~~t}~.'.,~~{~~(§f{on~~r1l~\[0(¥0.furftVJNt/?r/hilt~;i. <c'orrfptied"-}.~th;tlje:rqquii'etrieiits.of:thi_s:soctio~t~nd<who·,.•with;too'!inti..int,to;assfsti,th,:t..otual. ~flit !i~f «J~iit='i!i-,t (~iz~~tii~~&,,r, •• '(~)i~JV'J:ifl~sii_~f or;(n,~~Jijfitf~cirn.,,or,;~#~j'.6§,t{~~&;,;th~•-l~f•-.:Aflfoti~111.§ni~ricy,:'~~i'4?~H~, '-~~'1cll (o'~f e.!'tdei~s_1no~co,r.np(i:,,inc~:-v.JiP1. th~!t::o,quib~iJ'lqi'its-\of; this· s~~{oi,:;;a'odi-: if t\(rioY!'.rt;:,i:l:i§,. • ;,~h§fii~¼~f§'f~i.,9.',~~-ti~!\6ff~~di?r;; • • ·' • • • ,., .,,, • ,· • ., ~ • • .. '"' • • • • t~~F~0i~~1~~t~!it~f ~~lrf 1tl~i'.!;~i', ~s~t~ls\3'~ot{t,e,~J?6!s~rj_i1j\,i1~f~4hn~',o_r:;a~t~Hiri,i)~·;l§,, I ;c~Jit~o~:~~,s~~fi~,t:!J'1P.~~-t?'$:,,:nt9ai;_:9'fia$i~is:nn?Wcr'.p~t~or,,Ji1l'.corilie~'ti½_et§rn1tt'ui;ngiµ-i~:Jc•, conc:oal· :tha;_sexua{ offendet; ,or -• '. ,, . ... ', ..... ., .!_· "c,' t~. . • -· .... " - ,,~ .. ., ......... ~;·,, ---·"' - -~ •. :(~}:Pti~,Qg~':!~f<J.t1Pl9~:~'}~}t]lfl{~?~rf2~(¢1;fr.t'.~.119tzj,~~~~~l~Jrig;t~e.¼>}ui:ili§{(o!i~i;_r,:fh~t,:~;;\-.,, il?.~~_l'~_l'.l,9'!"~~t(?'J5~.cf c1l.s,2 ,!rl,Y Pfllll:,l_tlQ~i • • • • • . . , -··· . . ~ ' . .· . ... . . . .... ·,~m~~~?~.it<j!~~y,o~i.i.n~,:~1il9·~~~0~; •. P\~1:1i~~~~l~~a2·~ro'yi~~%··~/jj~;:~::s,;?:15:'0_~3_;:'.Cifi~t • /(1 t! (~:~ ( iir{~,~~tff fE(i}~'.f:l.'~}[\~Ji~p,~ttii? ··pJi:~tr?:s~;r~?f1?1_Jr~9j;f~-~?ti~~/~f~!ll<?ii0~t,ii . • .. , plfQ.~~~r, S,;~~r-~~l!;,:(~t1<:!J,dyn!'f,t,th?,~'X,t,~••1,1.1~ntl'.lto,llo!l'{JO,iL!¥}sexva..tio!f01_1~_er~sb1rth1fTIO~~h,~'.J ':. ·;t_~:tti'gt,itt:.~,offit~'i~-~.~~;;~o.vii(iJii):\ijN~l1:~;:o].st~:t.f;H~~~:gr:t\.9~!is'i&~:1~J9git<i91~l1",f~}tt~rt ff :;::;;;;;;;;::::::::::~;::;:~:::1!~::::~:;::;:::~::~::t:~t\.i,i'.f '.o1i2§hi ~age:28 of 114 CA/Aronberg-000901 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM '■i'.- Section 794:011 ^.excluding s: .794.011(10); 3. Section'8b0.04(4)(b): where tho.courtfihdsthGoffenscinvolved,avictimun<jer 12 years of ago or sexual actMtyjby*thcIusc:qf: force or coercion; |- - . ' ’■ 7k. ’.7 4. Section 800.04(S)(b); J . ' :. J . Section 800:04(5) (c)T. where the court .finds molestationcinvolving;unclothed^ '' genitabarca;. ' I b.Section*800.’04(5)c.2; where the court'finds molcstatiohnnvolving unclothed genitals or genitalarea; t 7; Sectioh800/04(5)(d),whore-the;court finds the/uso/of forco or coercion/and unclothed genitals or genital-arqa; J 8.- Any attempt or conspiracy to commit such offense; or 9. A'violation,of a similar law ofanother jurisdiction, .. ,7 , ■ , . . V ... ..... ..... i .‘ . - .. must reregister each: yearduring the month of the sexual offenders birthday and every third month thereafter., ' i i (c) The sheriffs'offico;may.detormino;tlio appropriate, timos^and days for, rcportingvby the sexual offender, .which shall be consistent with tho reporting1 rcquiiomonts of this subsection. Reregistration shalbinclucie'anychanges to the fotlowingnhformation: . i 1: Name; social security number;' age;-race; sox; date ofhirth; 'height;: weight; hair.and oye color; address of ahy^permanent residencmand address of any current temporary residence, within the stato oroutiof/state, including a-fural route addr.ess and-a post officp.box; any electronic.maikaddress’and'ahyanstantmessage namo ro<iuirod to:beiprovid pursuant to paragraph.(4)(d); date and-place of any employment;; vehicle malm/.modol//color,;and bcense- .tag number;?fingerpririts;:and photograph..A'.post offico:;box>,shall.beprovided in hornet 3 physical residential address; • • ■ £ .2. If the sexual offender is enrolled, employed, oi carrying on a vocation at an institution pi higher education in this state, the sexual offender shairalsd-provide to,the department the name, address; aruJ/county.of each.institution, including each campus attended, and the sexual offenders'onroUmentor. employment status; - 3 .; If ^aco of residence is,a motor vehicle^trailer,:'^ manufacturedihomo,’sas;definedfin>.chaptf;r 320; the sexual offepder.'Shall also;provide,the /vehicle.identification number;.the licensQitag numberj.’Xha registration description,;including colop.schome; of the motor/vehicle;,trailer, mobile/homa; or , rnanufactured;hornewlf<tiij^sexuaioffendcr s placciof residence;is?a,;,vessel; livc-abo’ard vessel; oi houseboat, as dofinQdhn^chaptor 327, the sexual offender shall also provide the hull identificatioivnumberj/the manufacturers soriabnumbarj/tno nameipfthe-vcsscl, liye-,abo«ruh vessel, or houseboat;: the:registratiorT.numbar;iand.a description,.including color 3chr»mo,sot tho vessel, livelaboard vessabbr'h^ ] 4 Any sexual offender who fails to rapmt’in pet sun a'jequncd at the sheriffs office, or v.Lu fails to respond to uny^ddress verification cotresnondeneb from the department s.ithin 3 weeks of'the'datemfithOjCorrespondence’.Qncwho-fails to;?cport’.c4QCtronic mad addresses.cv 0//26/17 Page 29 of. 1-14 Public Records'Request hip.:. 17-295 CA/Aronberg-000902 j FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY . '". ~-,·,~- . .,.,,,.,,... . ,..., ". ,v,,,C M.)• I .,., "'~·:. ""'.'" . . . ~':\• ---~$·- ' i~: 1~tI~~{!~~~~-l.t.~:~~~(uJ.!iq!;;;:,.!:~~:§f1J~Xop. .<s ·}~/¼l~f ~~~~;tj~lf {~t~~J;f )i{'?i\•\,\f~ief½~/iffl!tii;J<;,;,j~~,t,a,:sof • ,1 .. ~$&~~kaa~~~c~!·~~h: t . ' . • • · ... 1 . ;5;,-,Sectit>n'soo:d4'csHc')1·. ,Where\tho~cicirttffnds'rri~!e~tationti11volvintJ:inclothrid(g'd{taltor ~~~1{ijI!~f~;( ... a,, .•. ,,;,, • • -~'". ,·.,,;'' ,'Y'.•C, ·.- ·.,'""''"'"' ·c,:,•.,·,.• .. , •;- •••••• , .,, .... _. ' • ·,,,· ··c,.,,•v. "./"T''.'.'·C'""'' ;~tti\f~~,-~I~t{:2;;.•~~r<t'~~~'.f;~r.t:~_~cj~{FTl9l~t~~iOn;in~j0;n:~:;uncJ~-~1if-j§i\lf ~l~io~" . M~t~~;;~l~z"hoi~•t!Ji;,c~u,f fl)jifa•t~,.~,~i'tJ,,~j,,b, ,~.,,.CiO.~,~,)<l•'<,n<;l*lt>ii/i' ,~;, :AJiy}~~~f3r!ipr9r:.c;'.gr.t¥,~r,~rJ~J~i'.t:imlf~sfr§!'li~~;·,;or- -;;;;;;.:~;:::::;:;;:~:::::~~y.t9iteh~•r"':•?"~•r;odd'it•• -~'r<I'· • J~f ~!l)f sh¼~t~s!Q.f!'.!,i~Vfi~Y;.s.t~~~r.f ~*r~_i),a~pr,9r>~}~s::tlfyg~J~A~.:'.~·~YJ}~r,·t!?fii:\faej1?i/~~- .s~~~-~~~~ff~i1<!er:i,~r".!i!~hii~~ll:~.:.c<>11~1~t~,:,~:\\'.1.~~;!~2;r91,.o,ttJoe'.focf~lJ~rn,91~~:~.r,~b1$\~'f~s~~!:-19!N . :_~~Ggi~tt~Si~i, ~~lliJh~!,IJ~ei.;tc111y\~.!:!~ng~?f t.~ll!'.ie,l~~-ll9.~i,h~Hn.f9t,m.i3-t.i_on; · •. _ ! ·§1~A~~~~~~tr;:rtt.i:ittri{t\lt1tt11~;~~j;~tir~tit;J1~:t~:~~:;~;~t~~~nt1~: ii:, . -c:i~!!Mt,: -~«;lc;lr,es~i ,c1~i:);,«;_5>~!'_~y;qf;'91Jdl\l~t1tt519!1nt1c::l t,1~l l)R:9a~l1:C<)ITIP,~S/al'.t1~nq~; :~ni:i ,tl-'!.Or.S?>;ugi1-· 9,ff~ri~§r;sf?r•r.§Jl!Jlorit?f!:iJnp\~~gi;!t$~~-tu~: .. • • • - -" • • "'. . • • • , , 1 • .•. '· .• I ,. - ., ... ·--: . .. · ." - .•..• , : .. •• \'."·.' . • ... · .. : •. : ·· .. ,.:"=. .. ~-; --- :'\,' . . . . •. -·> . / "' . . ·: .. _. . .·.le"',.;'." ··:¾-\.-. ,·:. 3;, "If_ t!~ S<?Xlial:offender.:s ;~laco;of> resi dhnto"ii~a.mo tor' v'enide; ;fruilor; ;_111_cii'ijlo ~(!In<) ,<01:c ' ~nitVcs*1,;ti_ye[~J:i9~ff~~~~<ii:}~~f~~~i:;, .. • • - • -- • • , • l · # :~i~5f i(~l~!i!liimtlli~tli1V!i!&~i\?%f llfit~~f iii·t:~, '07/26117 Rage·29 of. M4 RubliclRecords·R~:esl No.· 17-295 CA/ Aronberg~0Q0.902 I FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK 3/28/2023 2:22:44 PM i . ···-··--·---·-·. -----. ,'·.·" .. , • instant message names, commits a'felony of the third degree, punishable as provided in s. 775.082, s. 775.083, or s. 775.084. ' ? i(d) The:shoriffs office shall,twithin:2 working<days; electronicallyisubmit and update all information provided by the sexual offender to the department in a manner proscribed by tho department;, 07Z26/17 Page.30of114 Public Records^ Request No.: 17-295 v I •, 2.4. - .. ~ . 1". f r. ~ CA/Aronberg-000903 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY r,._-_; ~· ,_. :.,, .. '. '07/26/17 CA/ Aron berg~000903 , . t· I : . j, I l i I i J I I I I FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. V28/2023 2:22:44 PM I Appendix 9 CA/Aronberg-000904 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM ’ ’ ’i NOT A CERTIFIED COPY • • Appendix 9 CNAronberg-000904 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM l • • U.S. Department of Justice United States Attorney | Southern District, ofNew York The Silvio J. Mblld Building One Saint Andrew ’s Plaza New.York- New York 10007 July 8, 2019 VTAECF The: Honorable Henry Pitman United States District Court Southern District of New York United States Courthouse 500 Pearl Street New York, New York 10007 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Judge Pitman': The Government respectfully submits this letter in advance of the bail hearing scheduled forJuly 8, 2019, in the above-captioned case. For the reasons, set forth herein, the Court should Order that the defendant be detained pending trial; he cannot meet his burden of overcoming the presumption that there is no combination of conditions that would reasonably assure his continued appearance in this case or protect the safety of the community were he to be released. As Set. forth below, the charges in this case are exceptionally serious: the defendant is alleged to be a serial sexual predator who preyed on dozens of minor girls Over a period of years, arid he now faces a potentially massive prison sentence predicated on substantial arid multifaceted evidence of his guilt. In light of the strength of the Government’s evidence and the substantial incarceratory term the defendant would face upon conviction, there is an'extraordinary risk of flight, particularly given the defendant’s exorbitant wealth, his ownership of and access to private planes capable of international travel, and his significant international ties. Indeed, the arrest of the defendant occurred when he arrived in the United States on his private jet after having returned from a multi-week stay abroad. Finally, and as detailed herein, 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. Asa result, he poses both an acute danger to the community, including some ofits most vulnerable members, and a significant risk of flight. The defendant,thus cannot overcome the statutory presumption that detention is appropriate in this case, and the Court: should order that he be detained pending trial. : I CA/Aronberg-000905 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY • VIAECF TheJionorable Henry Pitman United States Di~trict Court S.outhern Distri:ct-ofNew York United. States Courthouse 500 Pearl Street New York, New York I 0007 • U.S. DepartmentofJustice Uni/ed Stat,es A_ttwney I . S9uthern D1stnctofNqv Yqrk The Silvio J. i.io/ld Building One Saint Andrew:~ Plaza New:York; New York J()()(/7 Jµ)y 8, 2Ql9 Re: Uni(edStates: v. Jeffrey Epstein, 19 Cr; 490 (RMB) Dear Judge Pi tnian: The Government respectfully· submits thi's letter 111 advauce of the bail .hearing scheduled for.July 8, 2Pl 9, in. the above 0 capJioned case. Forthe reasons, set. forth herein, the Court should order that the defendant be detained pending trial; he cart not meethi's burden of overcoming the presumption that there-is no combination of conditions that would reasonably assure his torttinued appearance in thi~ case or protect th~ safety·of the community were he to b~released. As set_ forth below, the charges in this case are exceptionally serious: the defendant is alleged tci be a serial Sexual predator who pteyed. cni dozens of mi hot girls over a period of ·years, and he nowfaces a potentially massive pti'son sentence predicated oh substantial and multifaceted evidence of his guilt. In light of the strength of the Government's evidence and the substantial incarceratory tenn the clefendant would face upon conviction, there is an'extraordinary risk of flight, particµiarly ,g1 yen the defendant's exorbitau.twealth, h1s. ownership of and access to private planes cap·able ofinternational travel, and his significant international ties.· Indeed, the. arrest of the defendartt:occurred when he, arrived in the United States oil his private jet after having returned from a multi-week stay abroad. Finally, and as detailed herein, the Government has reai concerns-grounded in past e}(periencewiththis. ,:lefendant-that.ifallowedto remain out on bail, the defendant could attempt to pressure ,a:nd intimidate witnesses and potential witnesses 'in, this case, including victims a:nd their families, and otherwise attempt to obstruct justice. As a result, he poses both an acute danger to the'community; inclµding i,.om~-ofits most vulnerable memb~rs, ancl a i,.ignificantrisk pf flight The defendant;tlius cannot overcome the statutory pr.esu111.ption that detenti'on i~ appropriate io this case, and the 'Court should order that he be detained pending trial. CA/ Aronberg-0009O5 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 4128/2023 2:22:44 PM • • Honorable Henry Pitman United States Magistrate Judge July 8, 2019 Page 2 BACKGROUND A. Overview On July 2,2019, a federal grandjury in the Southern District ofNew York returned a sealed indictment (the “Indictment”) charging the defendant with one count of sex trafficking of minors, in violation of 18 U.S.C. § 1591, and one count of conspiracy to commit sex trafficking of minors, in violation of 18 U.S.C. § 371. As charged by the grand jury, the facts underlying the charges in the Indictment arise from a years-long scheme to sexually abuse underage girls. In particular, beginning in at least 2002, the defendant enticed and recruited dozens of minor girls to engage in sex acts with him, for which he paid the victims hundreds of dollars in cash. i He undertook this activity in at least two different locations, including his mansion in Manhattan, New York (the “New York Residence”) and his estate in Palm Beach, Florida (the “Palm Beach Residence”). In both New York and Florida, the defendant perpetuated this abuse in similar ways. Victims were initially recruited to provide “massages” to the defendant, which would be performed nude or partially nude, would become increasingly sexual in nature, and would typically include one or more sex acts, including groping and direct or indirect contact with victims’ genitals. The defendant paid his victims hundreds of dollars in cash for each separate encounter. Moreover, the defendant actively encouraged certain of his victims to recruit additional girls to be similarly sexually abused. He incentivized his victims to become recruiters by paying these victim-recruiters hundreds of dollars for each additional girl they brought to him. In this fashion, the defendant created a vast network of underage victims for him to exploit, in locations including New York and Palm Beach. The defendant’s victims were as young as 14 years old when he abused them. Many of his victims were, for various reasons, often particularly vulnerable to exploitation. The defendant intentionally sought out—and knew that he was abusing—minors. Indeed, in some instances, his victims expressly told him they were underage before or during the period in which he abused them. ' In creating and maintaining a network of minor victims whom he abused, the defendant worked with others, including employees and associates who facilitated his exploitation of minors by, among other things, contacting victims and scheduling their sexual encounters with the defendant, both in New York and in Florida. ' B. The Defendant Jeffrey Epstein designed, financed, and perpetrated this scheme, both as its main participant and through his direction of others, including certain of his employees, to further facilitate his rampant abuse of underage girls. CA/Aronberg-000906 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • Honorable Henry Pitman United States Magistrate Judge July8,2019 Page2 • BACKGROUND I I A. Overview I I On July 2, 2019, a federal grand jury in the Southern District ofNew York returned a sealed indictment (the "Indictment") charging the defendant with one count of sex 'trafficking of minors, in violation of 18 U.S.C. § 1591, and one count ofconspiracy to commit sex trafficking of minors, in violation of 18 U.S.C. § 371. • As charged by the grand jury, the facts underlying the charges in the ,Indictment arise from a years-long scheme to sexually abuse underage girls. In particular, beginning in at least 2002, the defendant enticed and recruited dozens of minor girls to engage in sex acts with him, for which he paid the victims hundreds of dollars in cash. • He undertook this activity in at least two different locations, including his mansion in Manhattan, New York (the "New York Residence") and his estate in Palm Beach, Florida (the "Palm Beach Residence"). In both New York and Florida, the defendant perpetuated this abuse in similar ways. Victims were initially recruited to provide "massages" to 'the defendant, which would be performed nude or partially nude, would become increasingly sexual in nature, and would typically include one or more sex acts, including groping and direct or indirect contact with victims' genitals. The defendant paid his victims hundreds of dollars in dash for each separate encounter. Moreover, the defendant actively encouraged certain of his victims to recruit additional girls to be similarly sexually abused. He incentivized his victims to become recruiters by paying these victim-recruiters hundreds of dollars for each additional girl they brought to him. In this fashion, the defendant created a vast network of underage victims for him tp exploit, in locations including New York and Palm Beach. The defendant's victims were as young as 14 years old when he abus.ed them. Many of his victims were, for various reasons, often particularly vulnerable to exploitation. The defendant intentionally sought out-and knew that he was abusing-minors. Indeed, in some instances, his victims expressly told him they were underage before or during the perioa in which he abused th~. I in creating and maintaining a network of minor victims whom he abused, the defendant worked with others, including employees and associates who facilitated his ~xploitation of minors by, among other things, contacting victims and scheduling their sexual: encounters with the defendant, both in New York and in Florida. B. The Defendant i Jeffrey Epstein designed, financed, and perpetrated this scheme, both/as its main participant and through his direction of others, including certain of his employees, to further facilitate his rampant abuse of underage girls. CA/Aronberg-000906 1 I FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. ~/28/2023 2:22:44 PM I • • Honorable Henry Pitman United States Magistrate Judge July 8, 2019 Page 3 As has been widely reported, the defendant is extraordinarily wealthy, and he owns and maintains luxury properties and residences around the world, including in Manhattan, New York; Palm Beach, Florida; Stanley, New Mexico; and Paris, France. Additionally, Epstein owns a private island in the U.S. Virgin Islands which, as noted above, is believed to be his primary residence in the United States. His mansion in Manhattan alone—a multi-story townhouse reported to be one of the largest single residences in all of Manhattan, which previously housed a school and which he owns through an LLC—has been valued at approximately $77 million. Entities controlled by the defendant also own at least two privatejets in active service, at least one of which is capable of intercontinental travel. As described further below, the defendant possesses three active United States passports, and his international connections and travels are extensive. For example, in addition to maintaining a residence in Paris, France, as described above, in the past 18 months alone, the defendant has traveled abroad, via private jet, either into or out of the country on approximately more than 20 occasions. C. The Prior Florida Investigation In or about 2005, the defendant was investigated by local police in Palm Beach, Florida, in connection with allegations that he had committed similar sex offenses against minor girls. The investigation ultimately also involved federal authorities, namely the U.S. Attorney’s Office for the Southern District of Florida (“SDFL”) and the FBI’s Miami Office, and included interviews with victims based in the Palm Beach area, including some of the alleged victims relevant to Count One of the instant Indictment.1 In fall 2007, the defendant entered into a non-prosecution agreement with the SDFL in connection with the conduct at issue in that investigation, which the non-prosecution agreement identified as including investigations into the defendant’s abuse of minor girls in the Palm Beach area. The Southern District ofNew York was not a signatory to that agreement, and the defendant was never charged federally.2 In June 2008, the defendant pled guilty in state court to one count of procuring a person under the age of 18 for prostitution, a felony, and one count of solicitation of prostitution, a felony. As a result, the defendant was designated as a sex offender with registration requirements under the national Sex Offender Registration and Notification Act. 1 The non-prosecution agreement, further discussed below, was entered into at the conclusion of the SDFL investigation and did not purport to cover any victims outside of the State of Florida. As noted above, the instant Indictment expressly alleges the existence of dozens of victims who were abused in this District in addition to dozens of victims who were abused in Florida. 2 While beyond the scope of a bail hearing, as discussed further below, it is well-established in the Second Circuit that absent an express provision to the contrary in the agreement, one District is not bound by the terms of an agreement entered into between a defendant and a U.S. Attorney’s Office in another district. See page 6, infra. I CA/Aronberg-000907 i FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • Honorable Henry Pitman United States Magistrate Judge July 8, 2019 Page 3 • I As has been widely reported, the defendant is extraordinarily wealthy, and he owns and I maintains luxury properties and residences around the world, including in !Vlanhattan, New York; Palm Beach, Florida; Stanley, New Mexico; and Paris, France. Addition!ally, Epstein owns a private island in the U.S. Virgin Islands which, as noted above, is believed to be his primary residence in the United States. His mansion in Manhattan alone-a multi-story townhouse reported to be one of the largest single residences in all of Manhattan, which previously housed a school and which he owns through an LLC-has been valued at approximately $77 million. Entities controlled by the defendant also own at least two private jets in active service, at least one of which is capable of intercontinental travel. As described further below, the defendant possesses three active United States passports, and his international connections and travels are extensive. For example, in addition to maintaining a residence in Paris, France, as described above, in the past 18 months alone, the defendant has traveled abroad, via private jet, either into or out of the country on approximately more than 20 occasions. C. The Prior Florida Investigation In or about 2005, the defendant was investigated by local police in Palm Beach, Florida, in connection with allegations that he had committed similar sex offenses against minor girls. The investigation ultimately also involved federal authorities, namely the U.S. Attorney's Office for the Southern District of Florida ("SDFL") and the FBI's Miami Office, and included interviews with victims based in the Palm Beach area, including some of the alleged vic6ms relevant to Count One of the instant lndictment. 1 In fall 2007, the defendant entered into a non-prosecution agreement with the SDFL in connection with the conduct at issue in that investigation, which the non-prosecution agreement identified as including investigations into the defendant's abuse of minor girls in the Palm Beach area. The Southern District of New York was not a signatory to that agreement, and the defendant was never charged federally. 2 In June 2008, the defendant pied guilty in state court to one count of procuring a person under the age of 18 for prostitution, a felony, and one count of solicitation of prostitution, a felony. As a result, the defendant was designated as a sex offender with registration requirements under the national Sex Offender Registration and Notification Act. 1 The non-prosecution agreement, further discussed below, was entered into at the conclusion of the SDFL investigation and did not purport to cover any victims outside of the State of Florida. As noted above, the instant Indictment expressly alleges the existence of dpzens of victims who were abused in this District in addition to dozens of victims who were abused in Florida. 2 While beyond the scope of a bail hearing, as discussed further below, it is lell-established in the I Second Circuit that absent an express provision to the contrary in the agre~ment, one District is not bound by the terms of an agreement entered into between a defendant and a U.S. Attorney's Office in another district. See page 6, infra. i CA/Aronberg-000907 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM • • Honorable Henry Pitman United States Magistrate Judge July 8, 2019 Page 4 ARGUMENT I I. Applicable Law ; Under the Bail Reform Act, 18 U.S.C. §§ 3141 et seq., federal courts are empowered to order a defendant’s detention pending trial upon a determination that the defendant is either a danger to the community or a risk of flight. 18 U.S.C. § 3142(e) (“no condition or combination of conditions would reasonably assure the appearance of the person as required and the safety of any other person and the community”). A finding of risk of flight must be supported by a preponderance of the evidence. See, e.g., United States v. Jackson, 823 F.2d 4, 5 (2d Cir. 1987); United States v. Chimurenga, 760 F.2d 400, 405 (2d Cir. 1985). A finding of dangerousness must be supported by clear and convincing evidence. See, e.g., United States v. Ferranti, 66 F.3d 540, 542 (2d Cir. 1995); Chimurenga, 760 F.2d at 405. In addition, a court may also order detention if there is “a serious risk that the [defendant] will . . . attempt to obstruct justice, or ... to threaten, injure, or intimidate, a prospective witness or juror.” 18 U.S.C. § 3142(f)(2)(B); see also United States v. Friedman, 837 F.2d 48 (2d Cir. 1988). The Bail Reform Act lists four factors to be considered in the detention analysis: (1) the nature and circumstances of the crimes charged; (2) the weight of the evidence against the person; (3) the history and characteristics of the defendant, including the person’s “character . . . [and] financial resources”; and (4) the seriousness of the danger posed by the defendant’s release. See 18 U.S.C. § 3142(g). Evidentiary rules do not apply at detention hearings and the government is entitled to present evidence by way of proffer, among other means. See 18. U.S.C. § 3142(f)(2); see also United States v. LaFontaine, 210 F.3d 125, 130-31 (2d Cir. 2000) (government entitled to proceed by proffer in detention hearings); Ferranti, 66 F.3d at 542 (same); United States v. Martir, 782 F.2d 1141, 1145 (2d Cir. 1986) (same). Where a judicial officer concludes after a hearing that “no condition or combination of conditions will reasonably assure the appearance of the person as required and the safety of any other person and the community, such judicial officer shall order the detention of the person before trial.” 18 U.S.C. § 3142(e)(1). Additionally, where, as here, a defendant is charged with committing an offense involving a minor victim under 18 U.S.C. § 1591, it shall be presumed, subject to rebuttal, that no condition or combination of conditions will reasonably assure the appearance of the defendant as required and the safety of the community. 18 U.S.C. § 3142(e)(3)(E). II. Discussion The defendant should be detained pending trial. For the reasons set forth below, it is difficult to overstate the risk of flight and danger to the community if the defendant is released, and for those reasons, the defendant cannot overcome the statutory presumption in favor of detention in this case. I CA/Aronberg-000908 [ FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3.28 2023 2:22:44 PM NOT A CERTIFIED COPY • Honorable Henry Pitman United States Magistrate Judge July 8, 2019 Page4 I. Applicable Law • ARGUMENT Under the Bail Reform Act, 18 U.S.C. §§ 3141 et seq., federal courts are empowered to order a defendant's detention pending trial upon a determination that the defendant is either a danger to the community or a risk of flight. 18 U.S.C. § 3142(e) ("no condition or combination of conditions would reasonably assure the appearance of the person as required and the safety of any other person and the community"). A finding of risk of flight must be supported by a preponderance of the evidence. See, e.g., United States v. Jackson, 823 F.2p 4, 5 (2d Cir. 1987); United States v. Chimurenga, 760 F .2d 400, 405 (2d Cir. 1985). A finding of dangerousness must be supported by clear and convincing evidence. See, e.g., United States v. Ferranti, 66 F.3d 540, 542 (2d Cir. 1995); Chimurenga, 760 F.2d at 405. In addition, a court may also order detention if there is "a serious risk that the [defendant] will.· .. attempt to obstruct justice, or ... to threaten, injure, or intimidate, a prospective witness or juror." 18 U.S.C. § 3142(t)(2)(B); see also United States v. Friedman, 837 F.2d 48 (2d Cir. 1988). The Bail Reform Act lists four factors to be considered in the detention analysis: (1) the nature and circumstances of the crimes charged; (2) the weight of the eviden~e against the person; (3) the history and characteristics of the defendant, including the person's "character ... [and] financial resources"; and (4) the seriousness of the danger posed by the defendant's release. See 18 U.S.C. § 3142(g). Evidentiary rules do not apply at detention hearings and the government is entitled to present evidence by way of proffer, among other means. See 18. U. S.C. § 3142(t)(2); see also United States v. LaFontaine, 210 F.3d 125, 130-31 (2d Cir. 2000) (government entitled to proceed by proffer in detention hearings); Ferranti, 66 F.3d at 542 (same); United States v. Martir, 782 F.2d 1141, 1145 (2d Cir. 1986) (same). Where a judicial officer concludes after a hearing that "no condition or combination of conditions will reasonably assure the appearance of the person as required and the safety of any other person and the community, such judicial officer shall order the detention of the person before trial." 18 U.S.C. § 3142(e)(l). Additionally, where, as here, a defendant is charged with committing an offense involving a minor victim under 18 U.S.C. § 1591, it shall be presumed, subject to rebuttal, that no condition or combination of conditions will reasonably assure the appearance of the defendant as required and the safety of the community. 18 U.S.C. § 3142(e)(3)(E). II. Discussion The defendant should be detained pending trial. For the reasons set forth below, it is difficult to overstate the risk of flight and danger to the community if the defendant is released, and for those reasons, the defendant cannot overcome the statutory presumption in favor of detention in this case. ! CA/Aronberg-000908 I I I I I I I I FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3(28/2023 2:22:44 PM I • • Honorable Henry Pitman United States Magistrate Judge July 8, 2019 Page 5 ; A. The Defendant Poses an Extreme Flight Risk Each ofthe relevant factors to be considered as to flight risk- the nature and circumstances of the offense, the strength of the evidence, and the history and characteristics of the defendant - counsel strongly in favor of detention. 1. The Nature and Circumstances of the Offense and the Strength of the Evidence The “nature and circumstances” of this offense plainly favor detention. 18 U.S.C. § 3142(g)(1) (specifically enumerating “whether the offense. . . involves a minor victim” as a factor in bail applications). Indeed, the crime of sex trafficking of a minor is so serious that for a defendant charged with that offense, there is a presumption that no condition or combination of conditions will reasonably assure the appearance of the defendant as required and the safety of the community. 18 U.S.C. § 3142 (e)(3)(E). Here, as specified in the Indictment, the defendant’s conduct was committed serially, over a period of years, and affected dozens.of victims. The seriousness of the charge is also reflected in the penalties the defendant faces, which include up to 45 years of incarceration for Counts One and Two ofthe Indictment.3 As the Second Circuit has noted, the possibility of a severe sentence is a significant factor in assessing the risk of flight. See Jackson, 823 F.2d at 7; see also United States v. Cisneros, 328 F.3d 610, 618 (10th Cir. 2003) (defendant was a flight risk because her knowledge of the seriousness ofthe charges against her gave her a strong incentive to abscond); United States v. Townsend, 897 F.2d 989, 995 (9th Cir. 1990) (“Facing the much graver penalties possible under the present indictment, the defendants have an even greater incentive to consider flight.”). Here, the defendant is facing a statutory maximum of decades in prison. Even in the absence of means—which, as discussed in detail below, the defendant has in abundance—this fact alone would provide a compelling incentive for anyone to fail to appear. It is particularly compelling for a defendant who is 66 years old and therefore faces the very real prospect of spending the rest of his life in prison if convicted. The likelihood of a substantial period of incarceration is buttressed by the strength of the evidence. As set forth in the Indictment, the evidence in this case is strong. The Indictment alleges that the defendant sexually abused dozens of minor victims, and the conspiracy count lists numerous overt acts committed in furtherance of the defendant’s crimes.4 3 The current penalties for violations of 18 U.S.C. § 1591 include a 10 year mandatory minimum sentence. However, that punishment was created through an amendment to the statute in 2006. The penalty for a violation of Section 1591 during the period charged in the Indictment, and therefore relevant here, was a maximum of 40 years’ imprisonment. 4 With respect to the evidence in this case, the Court should start its analysis by accepting that the Indictment is sufficient, on its own, to establish probable cause that the defendant committed the crimes of sex trafficking and sex trafficking conspiracy. Contreras, 776 F.2d at 54. (“Were an evidentiary hearing addressing the existence of probable cause required in every § 3142(e) case in which an indictment had been filed, the court would spend scarce judicial resources considering that which a grand jury had already determined, and have less time to focus on the application of CA/Aronberg-000909 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • Honorable Heniy Pitman United States Magistrate Judge July8,2019 Page 5 A. The Defendant Poses an Extreme Flight Risk • Each of the relevant factors to be considered as to flight risk-the nature and circumstances of the offense, the strength of the evidence, and the histoiy and characteristics of the defendant - counsel strongly in favor of detention. 1. The Nature and Circumstances of the Offense and the Strength of the Evidence The "nature and circumstances" of this offense plainly favor detention. 18 U.S.C. § 3142(g)(1) (specifically enumerating "whether the offense ... involves a minor victim" as a factor in bail applications). Indeed, the crime of sex trafficking of a minor is so serious that for a defendant charged with that offense, there is a presumption that no condition or combination of conditions will reasonably assure the appearance of the defendant as required and the safety of the I community. 18 U.S.C. § 3142 (e)(3)(E). Here, as specified in the Indictment, the defendant's conduct was committed serially, over a period of years, and affected dozens.of victims. The seriousness of the charge is also reflected in the penalties the defendant faces, which include up to 45 years of incarceration for Counts One and Two of the lndictment.3 As the Second Circuit has noted, the possibility of a severe sentence is a significant factor in assessing the risk of flight. See Jackson, 823 F.2d at 7; see also United States v. Cisneros, 328 F.3d 610, 618 (10th Cir. 2003) (defendant was a flight risk because her knowledge of the seriousness of the charges against her gave her a strong incentive to abscond); United States v. Townsend, 897 F.2d 989, 995 (9th Cir. 1990) ("Facing the much graver penalties possible under the present indictment, the defendants have an even greater incentive to consider flight."). Here, the defendant is facing a statutoiy maximum of decades in prison. Even in the absence of means-which, as discussed in detail below, the defendant has in abundance-this fact alone would provide a compelling incentive for anyone to fail to appear. lt is particularly compelling for a defendant who is 66 years old and therefore faces the veiy real prospect of spending the rest of his life in prison if convicted. The likelihood of a substantial period of incarceration is buttressed by the strength of the evidence. As set forth in the Indictment, the evidence in this case is strong. The Indictment alleges that the defendant sexually abused dozens of minor victims, and the conspiracy count lists numerous overt acts committed in furtherance of the defendant's crimes. 4 3 The current penalties for violations of 18 U.S.C. § 1591 include a 10 year mandatoiy minimum sentence. However, that punishment was created through an amendment to the statute in 2006. The penalty for a violation of Section 1591 during the period charged in the Indictment, and therefore relevant here, was a maximum of 40 years' imprisonment. 4 With respect to the evidence in this case, the Court should start its analysis by accepting that the Indictment is sufficient, on its own, to establish probable cause that the def~ndant committed the crimes of sex trafficking and sex trafficking conspiracy. Contreras, 776 F.2d at 54. ("Were an evidentiaiy hearing addressing the existence of probable cause required in eteiy § 3142( e) case in which an indictment had been filed, the court would spend scarce judicial tesources considering that which a grand juiy had already determined, and have less time to focu~ on the application of CNAronberg-000909 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM I I Honorable Henry Pitman United States Magistrate Judge July 8, 2019 Page 6 Multiple victims, including several specified in the Indictment, have provided information against the defendant. That information is detailed, credible, and corroborated, in many instances, by other witnesses and contemporaneous documents, records and other evidence—including, as further detailed below, evidence from a search of the New York Residence on the night of the defendant’s arrest that reflects an extraordinary volume of photographs of nude and partially-nude young women or girls. Such corroborating evidence also includes documents and other materials, such as contemporaneous notes, messages recovered from the defendant’s residence that include names and contact information for certain victims, and call records that confirm the defendant and his agents were repeatedly in contact with various victims during the charged period. Put simply, all of this evidence - the voluminous and credible testimony of individuals who were sexually abused by the defendant as minors, each of whom are backed up by other evidence - will be devastating evidence of guilt at any trial in this case and weighs heavily in favor of detention. Finally, it bears noting that neither the age ofthe conduct nor the defendant’s previous non¬ prosecution agreement (“NPA”) with a different federal district pose any impediment to his conviction. As an initial matter, all ofthe conduct is timely charged, pursuant to 18 U.S.C. § 3283, which was amended in 2003 to extend the limitations period for conduct that was timely as of the date of the amendment, to any time during the lifetime of the minor victim. See United States v. Chief, 438 F.3d 920, 922-25 (9th Cir. 2006) (finding that because Congress extended the statute of limitations for sex offenses involving minors during the time the previous statute was still running, the extension was permissible); United States v. Pierre-Louis, No. 16Cr. 541 (CM), 2018 WL 4043140, at *1 (S.D.N.Y. Aug. 9, 2018) (same). Moreover, with respect to the NPA, that agreement, to which the Southern District ofNew York was not a party, which by its express language pertained exclusively to the SDFL investigation, and which did not purport to bind any other Office or District, does not preclude prosecution in this District for at least two reasons. First, it is well settled in the Second Circuit that “a plea agreement in one U.S. Attorney’s office does not, unless otherwise stated, bind another.” United States v. Prisco, 391 F. App’x 920, 921 (2d Cir. 2010) (“A plea agreement binds only the office of the United States Attorney for the district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction ”) (citing United States v. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per curiam)). This is true even if the text of the agreement purports to bind “the Government.” See Annabi, Tl\ F.2d at 672. This analysis similarly extends to a non-prosecution agreement. See United States v. Laskow, 688 F. Supp. 851, 854 (E.D.N.Y. 1988) (“Defendant’s argument, in effect, is that unless there is an explicit statement to the contrary, it is presumed that a non-prosecution agreement binds offices of the United States Attorney that are not parties to the agreement. This position is at odds with the law in this Circuit, which presumes a narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively establish that a more expansive interpretation was contemplated”) (citing Annabi, 771 F.2d at 672). Second, the Indictment charges conduct not covered by the NPA, namely the presumptions and the § 3142(g) factors in deciding whether the ^defendant should be detained”). I CA/Aronberg-000910 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • Honorable Henry Pitman United States Magistrate Judge July 8, 2019 Page6 • Multiple victims, including several specified in the Indictment, have provided information against the defendant. That information is detailed, credible, and corroborated, in many instances, by other witnesses and contemporaneous documents, records and other evidence-including, as further detailed below, evidence from a search of the New York Residenc.e on the night of the defendant's arrest that reflects an extraordinary volume of photographs of nu.de and partially-nude young women or girls. Such corroborating evidence also includes documents and other materials, such as contemporaneous notes, messages recovered from the defendant's residence that include names and contact information for certain victims, and call records that confirm the defendant and his agents were repeatedly in contact with various victims during the charged period. Put simply, all of this evidence - the voluminous and credible testimony of individuals who were sexually abused by the defendant as minors, each of whom are backed up by other evidence - will be devastating evidence of guilt at any trial in this case and weighs heavily in favor of detention. Finally, it bears noting that neither the age of the conduct nor the defendant's previous non- prosecution agreement ("NPA") with a different federal district pose any impediment to his conviction. As an initial matter, all of the conduct is timely charged, pursuant to 18 U.S.C. § 3283, which was amended in 2003 to extend the limitations period for conduct that was timely as of the date of the amendment, to any time during the lifetime of the minor victim. See United States v. Chief 438 F.3d 920, 922-25 (9th Cir. 2006) (finding that because Congress extended the statute of limitations for sex offenses involving minors during the time the previous statute was still running, the extension was permissible); United States v. Pierre-Louis, No. 16 Cr. 541 (CM), 2018 WL 4043140, at *l (S.D.N.Y. Aug. 9, 2018) (same). Moreover, with respect to the NPA, that agreement, to which the Southern District of New York was not a party, which by its express language pertained exclusively to the SDFL investigation, and which did not purport to bind any other Office or District, does not preclude prosecution in this District for at least two reasons. First, it is well settled in the Second Circuit that "a plea agreement in one U.S. Attorney's office does not, unless otherwise stated, bind another." United States v. Prisco, 391 F. App'x 920, 921 (2d Cir. 2010) ("A plea agreement binds only the office of the United States Attorney for the district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.") ( citing United States v. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per curiam)). This is true even if the text of the agreement purports to bind "the Government." See Annabi, 771 F.2d at 672. This analysis similarly extends to a non-prosecution agreement. See United States v. Laskow, 688 F. Supp. 851, 854 (E.D.N.Y. 1988) ("Defendant's argument, in effect, is that unless there is an explicit statement to the contrary, it is presumed that a non-prosecution agreement binds offices of the United States Attorney that are not parties to the agreement. This position is at odds with the law in this Circuit, which presumes a narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively establish that a more expansive interpretation was contemplated.") (citing Annabi, 771 F.2d at 672). Second, the Indictment charges conduct not covered by the NPA, namely I I the presumptions and the § 3142(g) factors m deciding whether the ;defendant should be detained."). CNAronberg-00091 0 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM • • Honorable Henry Pitman United States Magistrate Judge July 8, 2019 Page 7 conduct that occurred in New York. The prior NPA included a list of several dozen victims identified in the prior investigation, all of whom were abused in the State of Florida, and none of whom are a part of the conduct charged in Count Two of the instant Indictment. Each of these factors—the seriousness of the allegations, the strength of the evidence, and the possibility of lengthy incarceration—creates an extraordinary incentive to flee. And as further described below, the defendant has the means and money to do so. 2. The Characteristics of the Defendant The history and characteristics of the defendant also strongly support detention. The defendant is extraordinarily wealthy and has access to vast financial resources to fund any attempt to flee. Indeed, his potential avenues of flight from justice are practically limitless. As the defendant acknowledged in his most recent New York State sex offender registration, he has six residences, including two in the U.S. Virgin Islands (including his own private island), and one each in Palm Beach, Florida; Paris, France; New York, New York; and Stanley, New Mexico. The most recent estimated value ofthe defendant’s New York City mansion alone is more than $77 million. The most recent tax-assessed value ofthe defendant’s Palm Beach estate is more than $12 million. The defendant’s primary residence is aprivate island in the U.S. Virgin Islands, a place where any sort of meaningful supervision would be all but impossible. Moreover, the defendant has access to innumerable means to flee. His sex registration documentation of “current vehicles” lists no fewer than 15 motor vehicles, including seven Chevrolet Suburbans, a cargo van, a Range Rover, a Mercedez-Benz sedan, a Cadillac Escalade, and a Hummer II. These cars are registered in various states and territories including the Virgin Islands, New York, Florida, and New Mexico. The defendant also has access to two private jets, giving him the ability to leave the country secretly and on a moment’s notice and to go virtually anywhere he wants to travel. He is a very frequent international traveler and regularly travels to and from the United States by private plane. In particular, between January 1, 2018, and the present, U.S. Customs and Border Patrol has logged approximately more than 20 flights in which Epstein was traveling to or from a foreign country. Indeed, he was arrested at Teterboro Airport arriving on just such a private international flight after having spent approximately three weeks abroad. Extensive international travel of this nature further demonstrates a significant risk of flight. See, e.g., United States v. Anderson, 384 F. Supp. 2d 32, 36 (D.D.C. 2005). There can be no assurance that, upon release, the defendant would suddenly lack access to such means of travel. Finally, the defendant has no meaningful ties that would keep him in this country. The defendant has no known immediate family. He is not married and has no children. He has friends and associates worldwide, as demonstrated by his extensive international travel, and his professional obligations, if any, can and seemingly are plainly capable of being handled by the defendant remotely. Simply put, there would be no meaningful reason for the defendant to remain in the country, while he would have every incentive (and every resource needed) to flee. Nor would home confinement with electronic monitoring reasonably assure the defendant’s presence as required. At best, home confinement with electronic monitoring would CA/Aronberg-000911 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY • Honorable Henry Pitman United States Magistrate Judge July 8, 2019 Page 7 • conduct that occurred in New York. The prior NP A included a list of leveral dozen victims I identified in the prior investigation, all of whom were abused in the State of Florida, and none of whom are a part of the conduct charged in Count Two of the instant Indictnient. Each of these factors-the seriousness of the allegations, the strength of the evidence, and the possibility of lengthy incarceration-creates an extraordinary incentive to flee. And as further described below, the defendant has the means and money to do so. 2. The Characteristics of the Defendant The history and characteristics of the defendant also strongly support detention. The defendant is extraordinarily·wealthy and has access to vast financial resources to fund any attempt to flee. Indeed, his potential avenues of flight from justice are practically limitless. As the defendant acknowledged in his most recent New York State sex offender registration, he has six residences, including two in the U.S. Virgin Islands (including his own private island), and one each in Palm Beach, Florida; Paris, France; New York, New York; and Stanley, New Mexico. The most recent estimated value of the defendant's New York City mansion alone is more than $77 million. The most recent tax-assessed value of the defendant's Palm Beach estate is more than $12 million. The defendant's primary residence is a private island in the U.S. Virgin Islands, a place where any sort of meaningful supervision would be all but impossible. Moreover, the defendant has access to innumerable means to flee. His sex registration documentation of "current vehicles" lists no fewer than 15 motor vehicles, including seven Chevrolet Suburbans, a cargo van, a Range Rover, a Mercedez-Benz sedan, a Cadillac Escalade, and a Hummer II. These cars are registered in various states and territories including the Virgin Islands, New York, Florida, and New Mexico. The defendant also has access to two private jets, giving him the ability to leave the country secretly and on a moment's notice and to go virtually anywhere he wants to travel. He is a very frequent international traveler and regularly travels to and from the United States by private plane. In particular, between January 1, 2018, and the present, U.S. Customs and Border Patrol has logged approximately more than 20 flights in which Epstein was traveling to or from a foreign country. Indeed, he was arrested at Teterboro Airport arriving on just such a private international flight after having spent approximately three weeks abroad. Extensive international travel of this nature further demonstrates a significant risk of flight. See, e.g., United States v. Anderson, 384 F. Supp. 2d 32, 36 (D.D.C. 2005). There can be no assurance that, upon release, the defendant would suddenly lack access to such means of travel. Finally, the defendant has no meaningful ties that would keep him in this country. The defendant has no known immediate family. He is not married and has no children. He has friends and associates worldwide, as demonstrated by his extensive international travel, and his professional obligations, if any, can and seemingly are plainly capable of< being handled by the defendant remotely. Simply put, there would be no meaningful reason for the defendant to remain I in the country, while he would have every incentive (and every resource ne 1eded) to flee. I Nor would home confinement with electronic monitoring r6asonably assure the defendant's presence as required. At best, home confinement with electrdnic monitoring would I CA/Aronberg-000911 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. f28/2023 2:22:44 PM Honorable Henry Pitman United States Magistrate Judge July 8, 2019 Page 8 merely reduce his head start should he decide to flee. See United States v. Zarger, No. 00 Cr. 773, 2000 WL 1134364, at *1 (E.D.N.Y. Aug. 4, 2000) (Gleeson, J.) (rejecting defendant’s application for bail in part because home detention with electronic monitoring “at best . . . limits a fleeing defendant’s head start”); see also United States v. Casteneda, No. 18 Cr. 047, 2018 WL 888744, at *9 (N.D. Cal. Feb. 2018) (same); United States v. Anderson, 384 F.Supp.2d 32, 41 (D.D.C. 2005) (same); United States v. Benatar, No. 02 Cr. 099, 2002 WL 31410262, at *3 (E.D.N.Y. Oct. 10, 2002) (same). : Finally, there can be little doubt that the defendant is in a position to abandon millions of dollars in cash and property securing any potential bond and still live comfortably for the rest of his life. These resources, and the ease with which the defendant could flee and live outside the reach of law enforcement—particularly considering his vast wealth and lack of meaningful ties to this District—make the risk of flight exceptionally high in this case, particularly when considered in conjunction with the strength of the government’s case and the lengthy sentence the defendant could receive if convicted. i B. The Defendant Poses a Risk of Danger to the Community and of Engaging in Obstruction of Justice ' i The release of the defendant, under any conditions, would pose a significant threat to the community and to the ongoing investigation. As described above, where there is probable cause to believe that an individual has committed an offense under 18 U.S.C. § 1591, it is presumed that no condition or combination of conditions can reasonably assure the safety of the community. 18 U.S.C. §;3142(e)(3). Here, not only is the defendant charged with very serious sex crimes against minors, he has already previously admitted to—and been convicted of—engaging in related conduct. Specifically, in June 2008, the defendant pled guilty in state court to one count of procuring a person under the age of 18 for prostitution, a felony, and he currently is a registered, sex offender, under classification level three in New York—defined as presenting a “high” risk of committing another sex crime and harm to the community. While the conduct presently allegeddoes not post-date the 2008 conviction, it nevertheless underscores the risk he poses to the community if released. Additionally, and in connection with the investigation ofthe defendant’s offense in Florida, there were credible allegations that the defendant engaged in witness tampering, harassment, or other obstructive behaviors. In fact, according to publicly-filed court documents, there were discussions between prosecutors and the defendant’s then-counsel about’the possibility of the defendant pleading guilty to counts relating to “obstruction,” as well as “harassment,” with reference to 18 U.S.C. §1512, which criminalizes “[t]ampering with a witness, victim, or informant.” For example, in a communication from the defendant’s then-counsel to prosecutors in SDFL, his counsel set forth a possible factual proffer that included statements that the defendant had “attempted to harass both [redacted] delay and hinder their receipt of a [redacted] to attend an official proceeding” and that the defendant “in particular, changed travel plans and flew with both [redacted] to the United States Virgin Islands rather than to an airport in TjJewJersey in order to attempt to delay their receipt ofwhat Mr. Epstein expected to be a [redacted]” and “further verbally CA/Aronberg-000912 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • Honorable Henry Pitman United States Magistrate Judge July 8, 2019 Page 8 • merely reduce his head start should he decide to flee. See United States v. Zarger, No. 00 Cr. 773, 2000 WL 1134364, at *1 (E.D.N.Y. Aug. 4, 2000) (Gleeson, J.) (rejecting d~fendant's application for bail in part because home detention with electronic monitoring "at be~t ... limits a fleeing defendant's head start"); see also United States v. Casteneda, No. 18 Cr. 047, 2018 WL 888744, at *9 (N.D. Cal. Feb. 2018) (same); United States v. Anderson, 384 F.Supp.2d 32, 41 (D.D.C. 2005) (same); United States v. Benatar, No. 02 Cr. 099, 2002 WL 31410262, at *3 (E.D.N.Y. Oct. 10, 2002) (same). : Finally, there can be little doubt that the defendant is in a position to abandon millions of dollars in cash and property securing any potential bond and still live comfortably for the rest of his life. These resources, and the ease with which the defendant could fl~e and live outside the reach of law enforcement-particularly considering his vast wealth and lack of meaningful ties to this District-make the risk of flight exceptionally high in this case, particuiarly when considered in conjunction with the strength of the government's case and the lengthy s_entence the defendant could receive if convicted. B. The Defendant Poses a Risk of Danger to the Community and of Engaging in Obstruction of Justice ! The release of the defendant, under any conditions, would pose a significant threat to the community and to the ongoing investigation. • As described above, where there is probable cause to believe that an individual has committed an offense under 18 U.S.C. § 1591, it is presumed that no condifion or combination of conditions can reasonably assure the safety of the community. 18 U.S.C. § :3142(e)(3). Here, not only is the defendant charged with very serious sex crimes against minors, he has already previously admitted to-and been convicted of-engaging in related conduct. Specifically, in June 2008, the defendant pied guilty in state court to one count of procuripg a person under the age of 18 for prostitution, a felony, and he currently is a registered: sex offender, under classification level three in New York-defined as presenting a "high" risk of committing another sex crime and harm to the community. While the conduct presently allegedldoes not post-date the 2008 conviction, it nevertheless underscores the risk he poses to the comm~nity if released. Additionally, and in connection with the investigation of the defendant's offense in Florida, there were credible allegations that the defendant engaged in witness tampering, harassment, or other obstructive behaviors. In fact, according to publicly-filed court documents, there were discussions between prosecutors and the defendant's then-counsel about: the possibility of the defendant pleading guilty to counts relating to "obstruction," as well as "harassment," with reference to 18 U.S.C. § 1512, which criminalizes "[t]ampering with 11- witness, victim, or informant." For example, in a communication from the defendant's then-counsel to prosecutors in SDFL, his counsel set forth a possible factual proffer that included statem:ents that the defendant I had "attempted to harass both [redacted] delay and hinder their receipt of a [redacted] to attend an official proceeding" and that the defendant "in particular, changed travel plhns and flew with both [redacted] to the United States Virgin Islands rather than to an airport in ::$ew Jersey in order to attempt to delay their receipt of what Mr. Epstein expected to be a [redacted]" and "further verbally CA/Aronberg-000912 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. /28/2023 2:22:44 PM • • Honorable Henry Pitman United States Magistrate Judge July 8, 2019 Page 9 harassed both [redacted] in connection to this attempt to delay their voluntary receipt of process all in violation of 18 USC 1512(d)(1).”5 Doe v. United States, 08 Civ. 80736 (S.D. Fla.), Dkts. 361 at 3-4, 361-7 through 361-11. In addition to 18 U.S.C. § 1512(d), prosecutors also proposed that the defendant could plead guilty to 18 U.S.C. § 403, that is, a knowing of intentional violation of the privacy protection of child victims and child witnesses, to which the defendant’s then- counsel replied: “Already thinking about the same statutes.” Id. Dkt. 361-11. They also discussed a possible obstruction plea that “could rely on the incident where Mr. Epstein’s private investigators followed [redacted] father, forcing off the road.” Id. Dkt. 361-10. The defendant’s apparent previous willingness to obstruct a federal investigation, harass or tamper with witnesses, and hire private investigators that “forc[ed] offthe road’ the father of an individual relevant in the investigation is alarming. It should especially weigh on the Court’s consideration here because the defendant was apparently willing to take those steps before even being charged and thus facing federal indictment; the incentive to interfere in the Government’s case here, where an Indictment has been returned, is exponentially greater. And as discussed above, the defendant has nearly limitless means to do so. Finally, despite having been previously convicted of a sex offense involving an underage victim, the defendant has continued to maintain a vast trove of lewd photographs ofyoung-looking women or girls in his Manhattan mansion. In a search of the New York Residence on the night of his arrest, on July 6-7, 2019, pursuant to judicially-authorized warrants, law enforcement officers discovered not only specific evidence consistent with victim recollections of the inside of the mansion, further strengthening the evidence of the conduct charged in the Indictment, but also at least hundreds—and perhaps thousands—of sexually suggestive photographs of fully- or partially- nude females. While these items were only seized this weekend and are still being reviewed, some ofthe nude or partially-nude photographs appear to be of underage girls, including at least one girl who, according to her counsel, was underage at the time the relevant photographs were taken. Additionally, some ofthe photographs referenced herein were discovered in a locked safe, in which law enforcement officers also found compact discs with hand-written labels including the following: “Young [Name] + [Name],” “Mise nudes 1,” and “Girl pics nude.” The defendant, a registered sex offender, is not reformed, he is not chastened, he is not repentant;6 rather, he is a continuing danger to the community and an individual who faces devastating evidence supporting deeply serious charges. 5 The redactions above are contained in the publicly filed version of the quoted document. 6 See, e.g., Amber Southerland, Billionaire Jeffrey Epstein: I’m a sex offender, not a predator, N.Y. Post (2011) (“Tm not a sexual predator, I’m an “offender,” the financier told The Post yesterday. ‘It’s the difference between a murderer and a person who steals a bagel.’”); Philip Weiss, The Fantasist, New York Magazine (2007) (“Tf s the Icarus story, someone who flies too close to the sun,’ I said. ‘Did Icarus like massages?’ Epstein asked.”). CA/Aronberg-000913 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • Honorable Henry Pitman United States Magistrate Judge July 8, 2019 Page 9 • harassed both [redacted] in connection to this attempt to delay their voluntary receipt of process all in violation of 18 USC 1512(d)(1)."5 Doe v. United States, 08 Civ. 80736 (S.D. Fla.), Dkts. I 361 at 3-4, 361-7 through 361-1 l. In addition to 18 U.S.C. § l512(d), prosecutors also proposed that the defendant could plead guilty to 18 U.S.C. § 403, that is, a knowing or intentional violation of the privacy protection of child victims and child witnesses, to which the defendant's then- counsel replied: "Already thinking about the same statutes." Id Dkt. 361-11. They also discussed a possible obstruction plea that "could rely on the incident where Mr. Epstein's private investigators followed [redacted] father, forcing off the road." Id. 0kt. 361-}0. The defendant's apparent previous willingness to obstruct a federal investigation, harass or tamper with witnesses, and hire private investigators that ''forc[ed] off the road' the father of an individual relevant in the investigation is alarming. It should especially r"eigh on the Court's consideration here because the defendant was apparently willing to take those steps before even being charged and thus facing federal indictment; the incentive to interfere in the Government's case here, where an Indictment has been returned, is exponentially greater. And as discussed above, the defendant has nearly limitless means to do so. Finally, despite having been previously convicted of a sex offense involving an underage victim, the defendant has continued to maintain a vast trove oflewd photographs of young-looking women or girls in his Manhattan mansion. In a search of the New York Residence on the night of his arrest, on July 6-7, 2019, pursuant to judicially-authorized warrants, law enforcement officers discovered not only specific evidence consistent with victim recollections of the inside of the mansion, further strengthening the evidence of the conduct charged in the Indictment, but also at 1 east hundreds-and perhaps thousands-of sexual I y suggestive photographs of fully- or partial 1 y- nude females. While these items were only seized this weekend and are still being reviewed, some of the nude or partially-nude photographs appear to be of underage girls, including at least one girl who, according to her counsel, was underage at the time the relevant photographs were taken. Additionally, some of the photographs referenced herein were discovered in a locked safe, in which law enforcement officers also found compact discs with hand-written labels including the following: "Young [Name]+ [Name]," "Misc nudes l," and "Girl pies nude." The defendant, a registered sex offender, is not reformed, he is not chastened, he is not repentant;6 rather, he is a continuing danger to the community and an individual who faces devastating evidence supporting deeply serious charges. 5 The redactions above are contained in the publicly filed version of the quoted document. 6 See, e.g., Amber Southerland, Billionaire Jeffrey Epstein: I'm a sex offender, not a predator, N.Y. Post (2011) ('"I'm not a sexual predator, I'm an "offender," the financier told The Post yesterday. 'It's the difference between a murderer and a person who ste11 s a bagel."'); Philip Weiss, The Fantasist, New York Magazine (2007) ("'It's the Icarus story, s 1omeone who flies too close to the sun,' I said. 'Did Icarus like massages?' Epstein asked."). CA/Aronberg-000913 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3(28/2023 2:22:44 PM Honorable Henry Pitman United States Magistrate Judge July 8, 2019 Page 10 CONCLUSION As set forth above, in this case, the risk, of flight in this case.is extraordinarily real. The; defendant is extremely wealthy, has extensive foreign contacts, and is charged with serious offenses that carry a potential statutory, sentence of up to 45 years’ imprisonment—even a fraction of which could result in the defendant, who is 66 years old, spending the rest of his life in j ail. In sum, the defendant’s transient lifestyle, his lack of family or community ties,, his extensive international travel and. ties outside the country, and his vast wealth, including his access to and, ownership of private; planes, all provide the defendant with the motive and means to become a successful fugitive. Further, the nature ofthe offenses he is alleged to have perpetrated—the abuse dozens of underage, vulnerable girls—along with his demonstrated willingness to harass, intimidate and otherwise tamper with.victims arid other, potential witnesses against him, render his dangerousness readily apparent. Accordingly, the Government respectfully submits that the defendant cannot and will, not be able to meet his burden ofovercoming the strong presumption in favor of detention, that there are ho Conditions of bail that would assure the defendant’s presence in court proceedings in thi s case or protect the safety of the community, and that any application for bail should be denied. Very truly yours, GEOFFREY S. BERMAN: United/States Attorney By:______ Alex Rossmiller/ Alison Moe/Maurene Comey Assistant United States Attorney Southern DistrictofNew York Tel: (212) 637-2415 / 2225’/ 2324 CC: Martin Weinberg, Esq., and Reid Weingarten, Esq., counselfor defendant Hon. Richard M. Berman, United States District Judge CA/Aronberg-000914 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY • Honorable Henry Pitman United States Magistrate Judge JulyS,2019 • • Page 10 • CONCLUSION As set forth above, in this case, the risk of flight in this case is extraordinarily real. The defenciant is e,ctremely wealthy, h<1s extensiye fore,igl) contcJcts, i:tn_d is charged wi{h seri_ous offenses that.carry a potential stafutqry sentence Qf t1p to 45 years' 1mpri'sonn'.ient_:__even afractiQn ofwhi.C:h could result in the defendant, who is 66. year:s old, spending the .rest of his life inJail. In sum, the defendant's transient lifestyle, his lack of family or community ties,. his extensive international travel anil ties outside the country, ,and :I1is vasf'wealth, including his access to and, .owner_ship of pr.ivate planes, all pr9yide the d~fendant with the motive anci mei:tns ·to become a successful fugi_tive. Further, the nature of-the offenseS:he is alleged to.have:perpetrated___..:the abuse dozens of underage, vulnerable ,girls:-along with his demonstrated Willingness to harass, intimidate a:nd otherwisetamperwith.victims:ahd other potential witnesses against him,reilder his dangerouSileSSreadily apparent. Accordillgly, ·the Government respectfully submits that the-defendant cannot and wilL not be a:bleJo meet'his burden ofovercoming the strong presumpti'on in favor ofdetention, that there are ho conditions of bail that would assure the defenda·nt' s. presence in court proceedings in thi'!; case orprotectthe safety ofthe community; and that any application for bail should be denied. Very tl]Jly yours, By.:---+-+---------------· Alex Rossmiller/ Alison Moe/ Maurene Corney Assistant'United States Attorney Southern District'ofNew York Tel: (212)637-2415 / 2225' /-2324 Cc: Martin Weinberg, Esq., and' Reid Weingarten, Esq., counselfor defehdant Hon. Richard M. Berfuan, United States District Judge CA/ Aronberg-000914 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM i Appendix 10 CA/Aronberg-000915 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Appendix 10 CA/Aronberg-000915 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM ' • • Lnitccl Stures Dcpnxrmcfir nJ.lustice; ■,.??' THE UNITED STATES ATTORNEY’S? OFFICE SOUTHERN plSTRICT^/0NEW YORK I U.S. Attorneys » Southern District of New York » News » Press Releases Department of Justice U.S. Attorney’s: Office Southern District of New York FOR IMMEDIATE RELEASE Monday, July 8, 2019 Jeffrey Epstein Charged In Manhattan Federal Court With Sex Trafficking OfMinors Alleged Conduct Occurred in both NewYork and Florida over Multiple Years, Involving Dozens ofVictims Geoffrey S. Berman, the United States Attorney for the Southern District of New York, William F. Sweeney Jr., the Assistant Director in Charge of the New York Field Office of the Federal Bureau of Investigation (“FBI”), and Jafhes P. O’Neill, Commissioner of the New York City Police Department (“NYPD”), announced that JEFFREY EPSTEIN was arrested Saturday and charged with sex trafficking of minors.and conspiracy to commit sex trafficking of friiriors. The indictment unsealed today alleges that, between 2002 through 2005, EPSTEIN sexually exploited, and abused dozens of underage girls by enticing them to engage in sex acts with him in exchange for money. Epstein allegedly worked with several employees and associates to ensure that he had a steady supply of minor victims to abuse, and paid several of those victims themselves to recruit other underage girls to engage in similar sex acts for money. He committed these offenses in locations including New York, New York, arid Palm Beach, Florida. EPSTEIN is expected to be presented in Manhattan federal court this afternoon before U.S. Magistrate Judge Henry B. Pitman; The case is assigned to U.S. District judge Richard M. Berman. U.S. Attorney Geoffrey S.. Berman said: “As.alleged, Jeffrey Epstein abused underage girls for years, operating a scheme in which girls he victimized would recruit others for Epstein to fexploit and abuse. Epstein exploited girls, who were vulnerable to abuse, enticed them with cash payments, and escalated his conduct to include sex acts, often occurring at his residence on the Upper East Side of Manhattan. While the charged conduct,is from a number of years ago, the victims - then children and now young women - are no less entitled to their day in court. My Office is proud to stand up for these victims by bringing this indictment.” FBI Assistant Director William R Sweeney Jr. said: “We are asking anyone, who may have been victimized by Jeffrey Epstein, or anyone who may have information about his alleged criminal behavior, to please call us. The number is 1-800-CALL-FBI. We want to hear from you, regardless of the age you are now, or whatever age you were then, no matter where the incident took place- The bravery it takes to call us might empower others to speak out about.the crirnes committed,against them. It is impo'rtant to remember there was never, nor will there ever be an excuse for this type of behavior. In the eyes of the FBI, the victims will always come first.” CA/Aronberg-000916 I FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY • • &i Ll~1!tcd,St~rcs'8epr1Fmf_~-:(11fJusti~e· . • • . , :_:~_:~ ,;_. ,-· . ·: • · • _ :~ ·, , ' V ,_ ,,... ; ,_ ~ ~ > • • ' \ ~ , V < ,< V ·,... 0, " ✓ ; - , THE UN!Tf::D STATES ,'\TTORNEY'S,OFFIC:£ SOUTHERN .QlSTRIC'I'§NEW YORK U.S. Attorney.§;» Southern District.of New York» News» Press Releases_ Depar'tmE!m of JusticEl FOR IMMEDIATE RELEASE V.S. Attorney's Office Southern Distdct of New York Monday, July 8, 2ff19 Jeffrey Epstein Charged In Manhattan Federal Court With Sex Trafficking Of Minors Alleged Conduct Occurred in both New York and Florida over Multiple Years, Involving • Dozens· of Victims • Geoffrey S. Berman, the United States Attorney for·the Southern District of New York, William F Sweeney .Jr., the Assistant Dire_ctor in Charge of the New York Field Office of the Federal Burnau of Investigation ("FBI"), and James P. 6:Neifl, commissioner of the NewYork City Police. Department ('.'NYP·D,;), announced that JEFFREY EPSTEIN was arrested:Saturday and char_gedwith: sex trafficking of minors and conspiracy to commit sex trafficking of minors. The indictment unsealed today •alleges that, between 2002 through 2005;_ EPSTEIN ?exually exploited i=Jnd abusecl dozens of u_nc:lerage girls by enticing tl}e!"(l to engage in_ sex clefs: with him in exchange for money. Epstein allegedly wor.ke_d with several employees and ·associates to ensure that- he had a steady supply of minor victims to abuse, and paid several of those victims themselves to recruit other underage girls to engage. in similar sex acts for money, He committed these offenses in locations including New York, New York, and Palm Beach, Fiorida. EPSTEiN is e~pecfed to be- presented in M~nh_attan fedt:?rc:il cggri this aftemopn before U,$, Magistrate Judge Hen_ry B, P_itman, The case is assignecl to U.S. District.Judge .Richard M. Berman. U.S. Attorney Geoffrey S. Berman said: "As allege:d, Jeffrey Epstein abused underage girls for years, operatinQ a scheme in which girls he victimizedwould recruit others for Epstein to exploit and abuse. Epstein exploited girls_ who were vulnerable to abuse, enticed them with cash payments, and ·escalated his conduct to include sex acts·, otte·n occurring at h\s residence onJhe Upper East Sitje-of Manhatta·n. Wnile the. coarge.d conclqct ,is fr.o_m .i=l n_1,1_mbe.r of years agp, the yic_!ims - th.en chjl<:lren an~ novv ye>Lmg wcirnen - are no less ~ntitled to their day in court. My Office is proud to stand up for these victirr,ts by bringiqg this indictm~nt." FBI Assistant Director William F: Sweeney. Jr. said: "We are asking anyone.who may have been victimized by Jeffr.ey Epstein, qr anyqne who may have information abo\Jt his alleged criminal behavior; to please call us. The number.is t-800-CALLsFBI. We want to hear from you, regardless of the !ag~fyou are now, or whatever age you were then, no matter where the inc;iQEmt took pl~ce, Ttie _bravery itt~k~s. to-<::all us_ rnight empower others :to speak out .about. the crimes committed against them. It is impdrtant to remember there w~~ never, nor will there ~ver be an excuse forthis·type of pehavior. l_n the eye?cif the FBI, the victirns w:ill always come first." CA/ Aronberg-000916 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM I • • NYPD Commissioner James P. O’Neill said: “Today’s charges serve as a warning to individuals who continue to prey upon some of our society’s most vulnerable population: we are coming for you. I thank and commend the U.S. Attorney’s Office for the Southern District and the FBI for their tireless'efforts to ensure, child predators are taken off bur streets. The NYPD will continue to work with dur law enforcement partners^ to eradicate the trafficking of children in our city and nation and work to bring justice to victims of these heinous crimes.” If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact the FBI at 1-800-CALL FBI, and reference this case. ' According to the Indictmentfl] unsealed today in Manhattan federal court: From at least 2002 through at least 2005, JEFFREY EPSTEIN enticed and recruited, and caused to be entice.d and recruited, dozens of minor girls to visit his mansion in New York, New York (the “New York Residence”), arid his estate in Palm.Beach, Florida (the “Palm Beach Residence”), to engage in sex acts with him, after which he would give the victims hundreds of dollars in cash. In order to maintain and increase his supply of victims, EPSTEIN also paid certain victims to recruit additional underage girls whom ha could similarly abuse. In this way, EPSTEIN created a vast network of underage victims for him to sexually exploit, often on a daily basis, in locations including New York and Palm Beach. EPSTEIN’s victims were as young as 14 at the time he abused them, and were, for various reasons, often particularly vulnerable to exploitation. Moreover, EPSTEIN, knew that many of his victims were under 18, including because, in some instances, victims expressly told him they were underage. In creating and maintaining this network of minor victims in multiple states, to. abuse and exploit .sexually, EPSTEIN worked with others, including employees and associates who facilitated his conduct by, among other things, contacting victims and scheduling their sexual encounters with EPSTEIN at,the New York Residence and at the Palm Beach Residence; In both New York and Florida, EPSTEIN perpetuated this abuse in similar ways. Victims were initially recruited to provide “massages’ to EPSTEIN, which became increasingly sexual in nature and would typically include one dr more sexacts. EPSTEIN paid his victims hundreds of dollars in cash for each encounter. In particular, during encounters at the New York Residence, victims would be taken to a room .where they would perform a massage on EPSTEIN, during which EPSTEIN would frequently escalate the nature and scope of physical contact with his victims to include, among other things, sex acts'such as groping and direct and indirect contact with the victims’ genitals. In connection with the encounters, EPSTEIN, or one of his employees or associates, typically paid each victim hundreds of dollars in cash. Once minor victims were recruited, EPSTEIN or his employees or associates would contact victims to schedule appointments for “massages.” As a result, many victims were abused by EPSTEIN oh multiple subsequent occasions. To further enable him to abuse underage girls, EPSTEIN asked and enticed certain of his victims to recruit additional minor girls to perform “massages” and similarly engage in sex acts with EPSTEIN. When a victim would recruit another underage girt for EPSTEIN, he paid both the. victim-recruiter and the new victim hundreds of dollars in. cash. Through these victim-recruiters, EPSTEIN maintained a steady supply of new victims to exploit, and gained access to dozens of additional underage girls to abuse. * *■ *■ | i JEFFREY EPSTEIN, 66, is charged with one count of sex trafficking of minors, which carries a maximum sentence of 40 years in prison, and one count of conspiracy to engage in sex trafficking of minors, which carries a maximum sentence of five years in prison. ! CA/Aronberg-000917 ' FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • NYPD Commissioner·James P., d'.Neill said: "Today's charges serve as a warning ·to individuals who continue to prey upon some of our society's most vulnerable population: we are cohiing forsou. I thank' and .. . ·., I . cQrnmend the U .$. AttQrr:,efs Office Jor the Southern District and the FBI for their tireless' effQrts to ensure, child predators are taken off our streets. The NYPD will continue to work with our law enforcement partners- to eradicate the tra-ffic-kin-g qf chilclrer, in our c-ity and nc1tion-aocl -w-ork't9 bring just--ic_el'_ to victims of these. - heinous crimes._" If you b:elieve you are .a Victim of the sexual al:>Use perpetrated by J.effrey Ep~tein, please, contact the FBI at 1-800-CALL FBl,-and reference this case. According to the lndictrnent[1] unsealed today in Manhattan federal court: From at least 2002 through at least 2005, JEFFREY EPSTEIN enticed and recruited, and caused to be entice_d and recruited, 'oo.ze_ns. of minor girls. to visit his mansiprJ in New Yo.Jk, New·York, (the "New Y/:>rk Residence"), arid his estate in Palm Beach', Florida (the "Palm Beach Residence"),, to ,engage in sex acts with him, after which he would give the victims hundreds of dollars in .cash. In order to maintain and increase his supply of victims, EPSTEI Nalso paid certain victims ,to recr,uit additional underage girts whom he, could similarly abuse. In this way, EPSTEIN created a vast network of underage victlms for him to sexually, exploit, .oft.en or, a dailY, l:>asis; in locations including New Yqrk c1ng Palm Beach. EPSJEIN's victims were as young as. 14 at the tim_e he abused them, and were, .for various reasons, often particularly vu Iner.able to exploitation·. Moreover;, EPSTEIN. knew that many of his Victims were under 18, including because, in some instances, victims expressly told him they were underage. in creating and maintaining this network of minor vlctirns in multiple states, to abuse and exploit sexually, EPSTEIN worked with others, including employees and associates who facilitated his conduct by, among either things, contacting victims and scheduling their sexuai encounters, with EPSTEIN at .the New York Resic:leJ1(:e clnd at the Pa.lrn ~e.aQh Residence, Jn _1:>oth New York anq FJ9rida, EPSTEIN per;petuated th.is at>yse. in similar ways. ''v'.idims were 'initially recruited to provide ''.massages" to EPSTEIN,, which became increasingly sexual in nature and would typically include. one or more sex acts .. EPSTEIN paid his victims hundreds of dollars in cash for each enco_unter In particular, c:IUring encquriters at the Ne\lV York Residence, victims would be taker;, to a room wti,ere they wouldperform-a massage on EPSTEIN, during Which EPSTEIN would frequently escalate the nature and scope of physical contc:1ct with his·victims to Jnclu<:le, among,other. things., seX: acts ;such _as groping and direct and in.direct co:ntact with the victims' genitals. In cqnnection with the e_ncounters., EPSTEIN, or one .of his employees or associates, typically paid each victim hundreds of dollars in cash. Once rnirior victims were recruited, EPSTEIN or his employe~s orassqciates would tQntac_tvictims tq schedule appQintments. for "massages.'; As a res·u1t, many vidims were abu·sed by EPSTEIN on multiple. subsequent occasions. To further enable him to abuse underage .girls,, EPSTEIN asked ,and enticed certain' of his victims, to, recruit ad_ditio_nc!I minorgirts to PElrform "massages" and s_im_ilarty engaQe in, s~~ acts with EPSTEIN. VVhen a vic.tirn would re.cruit another underage girt for EPSTEIN, he paid b.oth the victim~recruiter and the new victim hundreds of doilars in. cash. Through these victi~-r'ecruiters, EPSTEIN maintafned a steady supply of new victims to exploit, and gajneq acc_ess to dozens of addi.tional unqerage girls to abuse. • j * * * ! JEFFREY EP$TEIN, 66, is c.harg~d wit_h Oil!:! co1,1nJ of s~x.trafficking of _rn_i_nors, whicb 9a_rries <;1 rn~xi.!J1.um, sentence of 40 years in prison, and o_ne count of conspiracy to engage in sex traffi,cking of minors,! which carries a maximum sentence offiVeyears in prison. I I CA/ Aronberg-000917 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. ~/28/2023 2:22:44 PM • • The statutory maximum and mandatory penalties are prescribed by Congress and are provided here for informational purposes only, as any sentencing of the defendant would be determined by the judge. IVIr. Berman praised the outstanding investigative work of the FBI and the NYPD. He also thanked the U.S. Customs and Border Protection for their assistance.; This case is being handled by the Office’s Public Corruption, Unit. Assistant U.S. Attorneys Alex- Rossmiller, Alison Moe, and Maurene Comey are in charge of the prosecution, with assistance from the Office’s Human Trafficking Co-Coordinator, Abigail Kurland. The charges contained in the Indictment are merely accusations. The defendant is presumed innocent unless and Until proven guilty. [1 ] As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein, constitute only allegations, and every fact described therein should be treated as an allegation. i Attachment(s): Download U.S, v Jeffrey Epstein Indictment Topic(s): Project Safe Childhood Component(s): USAO - New York. Southern Press Release Number: 19-211 i Updated July 9, 2019 CA/Aronberg-0009.18 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • The statutory maximum and mandatory penalties are prescribed by Congress and are provided here for informational purposes only; as any·sentencing ofthe defendant would be determi~ed by the judge. Mr .•. B.erman···P .. r.a··,s·e·d··· the ou.tst.an.di·n·g··inv.estig. ativ.e •. work of the FBI and the NYPD; ~ 1 e also thanked the U.S. Customs and Border Prqtection Jor their assistance. This case is being handled. by the Offic::e's Public Corruption, Unit. Assistant U.S, Attorneys Alex Rossmiller, Alison Moe, and Maurene Corney are in charge ofthe prosecution, with assistanc~ from the Office's Human Trafficking Co.-Coordinator, Abigail Kurland. . .. . . . . I . The charges contained :in the Indictment are merely accusations. The defendant is presumed innocent unless and until proven guilty. I [11 As the introductory phrase signifies, the entirety of the text of the Indictment, an:d the description of the Indictment set forth herein, constitute only allegations, and every fact described th~rein should be treated as . . ' an allegation. • Attach111ent{s): Download U.S. v: Jeffrey_J;12stein Indictment Topic(s): ProjectSafe Childhood Comporierit(s): USAO - New York, Southern Press Release• Number: 19..:211 CA/Aronberg-000918 Updated July 9, 2019 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 31/28/2023 2:22:44 PM Appendix 11 i CA/Aronberg-000919 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY • • Appendix 11 CA/Aronberg-000919 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM i 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 • • J8RsEPSl UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK-x UNITED STATES OF AMERICA, v. 19 CR 490 (RMB) JEFFREY EPSTEIN, Defendant.-x New York, N.Y. August 27, 2019 10:30 a.m. Before: HON. RICHARD M. BERMAN, District Judge APPEARANCES GEOFFREY S. BERMAN United States Attorney for the Southern District of New York BY: MAURENE R. COMEY ALISON MOE Assistant United States Attorneys MARTIN G. WEINBERG, PC Attorney for Defendant BY: MARTIN G. WEINBERG STEPTOE & JOHNSON, LLP Attorneys for Defendant BY: REID WEINGARTEN MICHAEL MILLER SOUTHERN DISTRICT REPORTERS, P.O. (212) 805-0300 j CA/Aronberg-000920 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 28 2023 2:22:44 PM NOT A CERTIFIED COPY 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 • J8RsEPS1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ------------------------------x UNITED STATES OF AMERICA, v. JEFFREY EPSTEIN, Defendant. ------------------------------x Before: • 19 CR 490 (RMB) New York, N.Y. August 27, 2019 10:30 a.m. HON. RICHARD M. BERMAN, APPEARANCES GEOFFREY S. BERMAN United States Attorney for the Southern District of New York BY: MAURENE R. COMEY ALISON MOE Assistant United States Attorneys MARTING. WEINBERG, PC Attorney for Defendant BY: MARTING. WEINBERG STEPTOE & JOHNSON, LLP Attorneys for Defendant BY: REID WEINGARTEN MICHAEL MILLER District Judge SOUTHERN DISTRICT REPORTERS, P.~. (212) 805-0300 CA/Aronberg-000920 1 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 • • J8RsEPSl (Case called) THE COURT: Good morning, everybody. Please be seated. So just some housekeeping. We have a podium here for both attorneys and others who may be speaking, and so we would like you, attorneys and others who are speaking, to come up to the podium. This room is a little cavernous. We thought the podium over there would be more comfortable. For starters, and for this you don't have to go up to the podium, if you could just indicate your names. This table in front to my left, your right, are defense counsel, and that table to my right, your left, are government attorneys. If we could just ask the attorneys to introduce themselves. MS. COMEY: Good morning, your Honor. Maureen Comey and Alison Moe for the government. Joining us at counsel table are Special Agent Amanda Young of the FBI and Detective Paul Byrne of the NYPD. : MR. WEINGARTEN: Good morning, your Honor. Reid Weingarten. MR. WEINBERG: Martin Weinberg. Good morning, your Honor. THE COURT: Good morning. MR. MILLER: Good morning, your Honor1. Michael Miller from Steptoe & Johnson:on behalf of the i SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 CA/Aronberg-000921 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTIFIED COPY 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 • • 2 J8RsEPSl (Case called) seated. THE COURT: Good morning, everybody. Please be I So just some housekeeping. We have a podium here for both attorneys and others who may be speaking, and so we would like you, attorneys and others who are speaking, to come up to the podium. This room is a little cavernous. We thought the podium over there would be more comfortable. For starters, and for this you don't have to go up to the podium, if you could just indicate your names. This table in front to my left, your right, are defense counsel, and that table to my right, your left, are government attorneys. If we could just ask the attorneys to ,introduce themselves. MS. COMEY: Good morning, your Honor. Maureen Corney and Alison Moe for the government. Joining us at counsel table are Special Agent Amanda Young of the FBI and Detective Paul Byrne of the NYPD. MR. WEINGARTEN: Good morning, your Honor. Reid Weingarten. MR. WEINBERG: Martin Weinberg. Good morning, your Honor. THE COURT: Good morning. MR. MILLER: Good morning, your Honor i, Michael Miller from Steptoe & Johnson on behalf of the I I SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 I CA/ Aronberg-000921 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM I 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 • • J8RsEPSl defendant. THE COURT: Great. Again, good morning to all of you. This hearing that we're having today considers the government's motion to dismiss the indictment in this case. I must add that it also serves as the opportunity for me to thank all of you, the attorneys and the victims who are here today, among others, for your very hard work and dedication in this case. We also have here today the U.S. Attorney for the Southern District of New York, Geoffrey Berman, who has also been very helpful and indispensable in this matter. The news on August 10, 2019, that Jeffrey Epstein had been found dead in his cell at the Metropolitan Correctional Center, at the MCC, was certainly shocking. Most of you, and myself for that matter, were anticipating that the next steps in this case would be defense motion practice, including a motion to dismiss, followed by a trial on the merits before a jury, if the motions were not successful, and through which the accusers and the accused would come face to face, allowing everyone to get their day in court. Mr. Epstein's death obviously means that a trial in which he is a defendant cannot take place. It is a rather stunning turn of events. The government's motion to dismiss the indictment because of Jeffrey Epstein's death on August 10, 2019, is SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 I CA/Aronberg-000922 , FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. |/28/2023 2:22:44 PM NOT A CERTIFIED COPY 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 • • 3 J8RsEPS1 defendant. THE COURT: Great. Again, good morning to all of you. This hearing that we're having today considers the government's motion to dismiss the indictment in this case. I must add that it also serves as the opportunity for me to thank all of you, the attorneys and the victims who are here today, among others, for your very hard work and dedication in this case. We also have here today the U.S. Attorney for the Southern District of New York, Geoffrey Berman, who has also been very helpful and indispensable in this matter. The news on August 10, 2019, that Jeffrey Epstein had been found dead in his cell at the Metropolitan Correctional Center, at the MCC, was certainly shocking. Most of you, and myself for that matter, were anticipating that the next steps in this case would be defense motion practice, including a motion to dismiss, followed by a trial on the merits before a jury, if the motions were not successful, and through which the accusers and the accused would come face to face, allowing everyone to get their day in court. Mr. Epstein's death obviously means that a trial in which he is a defendant cannot take place. It is a rather stunning turn of events. I The government's motion to dismiss th~ indictment I because of Jeffrey Epstein's death on August 19, 2019, is SOUTHERN DISTRICT REPORTERS, P.C. (212) 8o5-o3oo I CA/Aronberg-000922 i FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. :B/28/2023 2:22:44 PM !

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